&EPA
United States
Environmental Protection
Agency
The 2011 Annual Effluent Guidelines
Review Report
December 2012
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U.S. Environmental Protection Agency
Office of Water (4303T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
EPA-821-R-12-001
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CONTENTS
Page
1. Background 1-1
1.1 Background References 1-2
2. Public Comments on the Final 2010 Effluent Guidelines Program
Plan 2-1
3. Methodology, Data Sources, and Limitations 3-1
3.1 Data Sources and Limitations 3-1
3.1.1 SIC Codes 3-2
3.1.2 NAICS Codes 3-3
3.1.3 Toxic Weighting Factors 3-4
3.1.4 Data from TRI 3-5
3.1.5 Data from PCS and ICIS-NPDES 3-7
3.2 Methodology Correction Affecting Both Toxicity Rankings Analysis Databases 3-10
3.3 Corrections to the DMRLoads2009 Database 3-10
3.3.1 DMRLoads2009: Categorization of Discharges 3-10
3.3.2 DMRLoads2009: Internal Monitoring 3-11
3.3.3 DMRLoads2009: Intermittent Discharges 3-11
3.3.4 DMRLoads2009: Excluded Pollutant Parameters 3-12
3.3.5 DMRLoads2009: Pollutant Corrections 3-12
3.3.6 DMRLoads2009: Data Quality Review 3-12
3.3.7 DMRLoads2009: Facility Reviews 3-15
3.4 Corrections to the TRIReleases2009 Database 3-23
3.4.1 TRIReleases2009: Categorization of Discharges 3-23
3.4.2 TRIReleases2009: Pollutant Corrections 3-24
3.4.3 TRIReleases2009: Data Quality Review 3-25
3.4.4 TRIReleases2009: Facility Reviews 3-26
3.4.5 Trends in TRI Data 3-31
3.5 TRIReleases2009 Rankings and DMRLoads2009 Rankings 3-31
3.6 Methodology, Data Sources, and Limitations References 3-32
4. Aluminum Forming (40 CFR Part 467) 4-1
4.1 Aluminum Forming Category 2011 Toxicity Rankings Analysis 4-1
4.2 Aluminum Forming Category Pollutants of Concern 4-1
4.3 Aluminum Forming Category Lead Discharges in DMR 4-3
4.4 Aluminum Forming Category Conclusions 4-5
4.5 Aluminum Forming Category References 4-5
5. Centralized Waste Treatment (40 CFR Part 437) 5-1
5.1 CWT Category 2011 Toxicity Rankings Analysis 5-1
5.2 CWT Category Pollutants of Concern 5-1
5.3 CWT Category Hexachlorobenzene Discharges in DMR 5-3
5.4 CWT Category Conclusions 5-4
5.5 CWT Category References 5-4
6. Coal Mining (40 CFR Part 434) 6-1
6.1 Coal Mining Category Toxicity Rankings Analysis 6-1
6.2 Coal Mining Manufacturing Category Pollutants of Concern 6-2
v
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CONTENTS (Continued)
Page
6.3 Coal Mining Category Iron and Manganese Discharges in DMR 6-2
6.4 Coal Mining Pollutants Not Currently Regulated by Part 434 6-6
6.5 Coal Mining Category Conclusions 6-6
6.6 Coal Mining Category References 6-7
7. Fertilizer Manufacturing (40 CFR Part 418) 7-1
7.1 Fertilizer Manufacturing Category 2011 Toxicity Rankings Analysis 7-1
7.2 Fertilizer Manufacturing Category Pollutants of Concern 7-1
7.3 Fertilizer Manufacturing Category Fluoride Discharges in DMR 7-3
7.4 Fertilizer Manufacturing Category Conclusions 7-5
7.5 Fertilizer Manufacturing Category References 7-6
8. Inorganic Chemicals Manufacturing (40 CFR Part 415) 8-1
8.1 Inorganic Chemicals Category Toxicity Rankings Analysis 8-1
8.2 Inorganic Chemicals Category Pollutants of Concern 8-1
8.3 Inorganic Chemicals Category Manganese and Manganese Compound
Discharges in TRI 8-4
8.4 Inorganic Chemicals Category Dioxin and Dioxin-Like Compound Discharges in
TRI 8-5
8.5 Inorganic Chemicals Category Conclusions 8-8
8.6 Inorganic Chemicals Category References 8-9
9. Iron and Steel Manufacturing (40 CFR Part 420) 9-1
9.1 Iron and Steel Manufacturing Category Background 9-1
9.1.1 Iron and Steel Manufacturing Industry Profile 9-1
9.1.2 40 CFR Part 420 9-2
9.2 Iron and Steel Manufacturing Category 2011 Toxicity Rankings Analysis 9-6
9.3 Iron and Steel Manufacturing Category Pollutants of Concern 9-6
9.4 Iron and Steel Manufacturing Category Cyanide Discharges in DMR 9-7
9.4.1 U.S. Steel Corporation-Clairton Works 9-8
9.4.2 Mountain State Carbon, LLC 9-9
9.5 Iron and Steel Manufacturing Category Chlorine Discharges in DMR 9-9
9.5.1 ISG Sparrows Point, Inc 9-10
9.6 Iron and Steel Manufacturing Category Chromium Discharges in DMR 9-11
9.6.1 Arcelormittal Weirton Inc 9-11
9.7 Iron and Steel Manufacturing Category Fluoride Discharges in DMR 9-12
9.7.1 Arcelormittal Weirton Inc 9-12
9.8 Iron and Steel Manufacturing Category Aluminum Discharges in DMR 9-13
9.8.1 Ipsco Tubulars (KY) Inc. Wilder 9-13
9.8.2 Nucor Steel Tuscaloosa Inc 9-14
9.8.3 Nucor Steel Decatur LLC 9-15
9.9 Iron and Steel Manufacturing Category Conclusions 9-16
9.10 Iron and Steel Manufacturing Category References 9-17
10. Landfills (40 CFR Part 445) 10-1
10.1 Landfills Category 2011 Toxicity Rankings Analysis 10-1
10.2 Landfills Category Pollutants of Concern 10-1
10.3 Landfills Category Top Dischargers in DMR 10-2
10.3.1 Butler County Landfill 10-2
vi
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CONTENTS (Continued)
Page
10.3.2 Tunnel Hill Reclamation 10-3
10.3.3 BFI Backridge Sanitary Landfill 10-4
10.4 Landfills Category Iron Discharges in DMR 10-5
10.5 Landfills Category Conclusions 10-8
10.6 Landfills Category References 10-8
11. Meat and Poultry Products (40 CFR Part 432) 11-1
11.1 Meat and Poultry Category Background 11-1
11.1.1 Meat and Poultry Industry Profile 11-1
11.1.2 40 CFR Part 432 11-2
11.2 Meat and Poultry Category 2011 Toxicity Rankings Analysis 11-4
11.3 Meat and Poultry Category Pollutants of Concern 11-5
11.4 Meat and Poultry Category Nitrate Compound Discharges in TRI 11-6
11.4.1 Tyson Fresh Meats, Inc 11-9
11.4.2 Tyson Fresh Meats, Inc 11-9
11.4.3 Cargill Meat Solutions Corporation 11-9
11.4.4 Farmland Foods, Inc 11-10
11.4.5 Cargill Meat Solutions Corporation 11-10
11.5 Nitrate Concentrations in the 2009 DMR Database 11-10
11.6 Meat and Poultry Category Conclusions 11-11
11.7 Meat and Poultry Category References 11-12
12. Metal Finishing (40 CFR Part 433) 12-1
12.1 Metal Finishing Category Background 12-1
12.1.1 Metal Finishing Industry Profile 12-1
12.1.2 40 CFR Part 433 12-2
12.2 Metal Finishing Category 2011 Toxicity Rankings Analysis 12-3
12.3 Metal Finishing Category Pollutants of Concern 12-3
12.4 Metal Finishing Category Silver Discharges in DMR 12-4
12.5 Metal Finishing Category Cyanide Discharges in DMR 12-5
12.6 Metal Finishing Category PCB-1248 Discharges in DMR 12-6
12.6.1 General Motors Powertrain, Tonawanda Engine Plant 12-7
12.6.2 General Motors Powertrain - Massena Plant 12-8
12.7 Metal Finishing Category Conclusions 12-10
12.8 Metal Finishing Category References 12-11
13. Mineral Mining and Processing (40 CFR Part 436) 13-1
13.1 Mineral Mining Category 2011 Toxicity Rankings Analysis 13-1
13.2 Mineral Mining Category Pollutants of Concern 13-1
13.3 Mineral Mining Category Cadmium Discharges in DMR 13-3
13.3.1 Butala Sand and Gravel 13-3
13.4 Mineral Mining Category Fluoride Discharges in DMR 13-4
13.4.1 US Agri-Chemicals Corporation 13-5
13.4.2 Feldspar Corporation Spruce Pine Facility 13-5
13.5 Florida Fluoride Dischargers 13-6
13.5.1 Mosaic Fertilizer, LLC, Fort Green Mine Complex 13-7
13.5.2 Mosaic Fertilizer, LLC, Four Corners Mine 13-8
13.5.3 South Fort Meade Mine 13-10
13.5.4 Fluoride Wastewater Treatment 13-10
vii
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CONTENTS (Continued)
Page
13.6 Mineral Mining Category Chlorine Discharges in DMR 13-11
13.7 Mineral Mining Category Conclusions 13-12
13.8 Mineral Mining Category References 13-13
14. Nonferrous Metals Manufacturing (40 CFR Part 421) 14-1
14.1 NFMM Category 2011 Toxicity Rankings Analysis 14-1
14.2 NFMM Category Pollutants of Concern 14-1
14.3 NFMM Category Mercury Discharges in DMR 14-2
14.4 NFMM Category Fluoride Discharges in DMR 14-3
14.5 NFMM Category Lead Discharges in DMR 14-5
14.6 NFMM Category Cadmium Discharges in DMR 14-7
14.6.1 Nyrstar Clarksville, Inc 14-8
14.7 NFMM Category Molybdenum Discharges in DMR 14-9
14.8 NFMM Category Conclusions 14-11
14.9 NFMM Category References 14-13
15. Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 15-1
15.1 OCPSF Category 2011 Toxicity Rankings Analysis 15-1
15.2 OCPSF Pollutants of Concern 15-1
15.3 OCPSF Category Hexachlorobenzene Dischargers in DMR 15-3
15.3.1 Daikin American, Inc 15-3
15.3.2 Chevron Oronite Co., LLC, Oak Point Plant 15-5
15.3.3 Nalco Company 15-5
15.4 OCPSF Category Conclusions 15-7
15.5 OCSPF Category References 15-8
16. Oil & Gas Extraction (40 CFR Part 435) 16-1
16.1 Oil and Gas Category 2011 Toxicity Rankings Analysis 16-1
16.2 Oil and Gas Category Pollutants of Concern 16-2
16.3 Oil and Gas Category Sulfide Discharges in DMR 16-4
16.4 Oil and Gas Category Conclusions 16-6
16.5 Oil and Gas Category References 16-7
17. Ore Mining and Dressing (40 CFR Part 440) 17-1
17.1 Ore Mining and Dressing Category 2011 Toxicity Rankings Analysis 17-1
17.2 Ore Mining and Dressing Category Top Facilities in DMR 17-1
17.3 Ore Mining and Dressing Category Conclusions 17-4
17.4 Ore Mining and Dressing Category References 17-4
18. Pesticide Chemicals (40 CFR Part 455) 18-1
18.1 Pesticide Chemicals Category 2011 Toxicity Rankings Analysis 18-1
18.2 Pesticide Chemicals Category Pollutants of Concern 18-1
18.3 Pesticide Chemicals Category PCB Discharges in TRI 18-3
18.4 Pesticide Chemicals Category Conclusions 18-4
18.5 Pesticide Chemicals Category References 18-4
19. Petroleum Refining (40 CFR Part 419) 19-1
19.1 Petroleum Refining Category 2011 Toxicity Rankings Analysis 19-1
viii
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CONTENTS (Continued)
Page
19.2 Petroleum Refining Category Pollutants of Concern 19-1
19.3 Petroleum Refining Category Dioxin and Dioxin-Like Compound Discharges in
TRI 19-2
19.4 Petroleum Refining Category PAC Discharges in TRI 19-5
19.5 Petroleum Refining Category Sulfide Discharges in DMR 19-5
19.5.1 Sulfide Wastewater Treatment 19-6
19.5.2 Biological Treatment 19-7
19.5.3 Aeration and Air Stripping 19-7
19.5.4 Hydrogen Peroxide Oxidation 19-7
19.6 Petroleum Refining Category Chlorine Discharges in DMR 19-8
19.7 Petroleum Refining Category Metals Discharges in DMR 19-9
19.8 Petroleum Refining Category Conclusions 19-11
19.9 Petroleum Refining Category References 19-12
20. Pulp, Paper, and Paperboard (40 CFR Part 430) 20-1
20.1 Pulp and Paper Toxicity Rankings Analysis 20-1
20.2 Pulp and Paper Category Pollutants of Concern 20-1
20.3 Pulp and Paper Category Dioxin and Dioxin-like Compound Discharges in TRI 20-3
20.3.1 Simpson Tacoma Kraft Co., LLC 20-4
20.3.2 Remaining Dioxin and Dioxin-Like Discharging Facilities 20-5
20.4 Pulp and Paper Category Manganese and Manganese Compound Discharges in
TRI 20-10
20.5 Pulp and Paper Category Sulfide Discharges in DMR 20-11
20.5.1 Sulfide Formation and Treatment Options 20-11
20.5.2 Smurfit-Stone Container 20-12
20.6 Pulp and Paper Category Aluminum Discharges in DMR 20-13
20.6.1 International Paper 20-14
20.6.2 Remaining Aluminum Dischargers 20-14
20.7 Pulp and Paper Category Conclusions 20-15
20.8 Pulp and Paper Category References 20-16
21. Timber Products Processing (40 CFR Part 429) 21-1
21.1 Timber Products Category 2011 Toxicity Rankings Analysis 21-1
21.2 Timber Products Category Pollutants of Concern 21-1
21.3 Timber Products Category Copper Discharges in DMR 21-3
21.4 Timber Products Category Dioxin and Dioxin-Like Compounds Discharges in
TRI 21-4
21.5 Timber Products Category Conclusions 21-7
21.6 Timber Products Category References 21-7
22. Textile Mills (40 CFR Part 410) 22-1
22.1 Textiles Category 2011 Toxicity Rankings Analysis 22-1
22.2 Textiles Category Pollutants of Concern 22-1
22.3 Textiles Category Sulfide Discharges in DMR 22-3
22.3.1 Mohawk Industries, Inc 22-4
22.3.2 Gold Mills, Inc 22-7
22.4 Textiles Category Conclusions 22-8
22.5 Textiles Category References 22-8
IX
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LIST OF TABLES
Page
Table 1-1. Point Source Categories Collectively Discharging Over 95% of the Total TWPE 1-1
Table 2-1. Comments on the Final 2010 Effluent Guidelines Program Plan EPA Docket Number:
EPA-HQ-OW-2008-0517 2-2
Table 3-1. Nomenclature and Format ofNAICS and SIC Codes 3-3
Table 3-2. Summary of DMRLoads2009 Facility Review 3-16
Table 3-3. Summary of TRIReleases2009 Facility Review 3-27
Table 3-4. Number of Facilities with Data in TRI for Reporting Years 2002 Through 2009 3-31
Table 4-1. Aluminum Forming Category TRI and DMR Discharges for the 2006 Through 2011
Toxicity Rankings Analyses 4-1
Table 4-2. Aluminum Forming Category Top DMR Pollutants 4-2
Table 4-3. Top Lead Discharging Facilities in 2008 and 2009 DMR Databases 4-4
Table 5-1. CWT Category TRI and DMR Discharges for the 2006 Through 2011 Toxicity
Rankings Analyses 5-1
Table 5-2. CWT Category Top DMR Pollutants 5-2
Table 5-3. 2007-2010 Monthly Hexachlorobenzene Discharges for Clean Harbors Baton Rouge
as Reported in Discharge Monitoring Reports 5-3
Table 6-1. Coal Mining Category TRI and DMR Discharges for the 2006 Through 2011 Toxicity
Rankings Analyses 6-1
Table 6-2. Coal Mining Manufacturing Category Top DMR Pollutants 6-2
Table 6-3. Coal Mining ELGs Subpart C Manganese and Iron Limits 6-3
Table 6-4. Top Manganese and Iron Discharging Facilities in the 2009 DMR Database 6-3
Table 6-5. Freeman United Coal-Industry 2009 Original DMR and Corrected Flow Discharges 6-4
Table 6-6. Freeman United Coal-Industry's 2009 Manganese and Iron Concentrations 6-5
Table 6-7. Freeman United Coal-Crown 2 2009 Original DMR and Corrected Flow Discharges 6-6
Table 6-8. Freeman United Coal - Crown 3 2009 Original DMR and Corrected Flow Discharges 6-6
Table 7-1. Fertilizer Manufacturing Category TRI and DMR Discharges for the 2006 Through
2011 Toxicity Rankings Analyses 7-1
Table 7-2. Fertilizer Manufacturing Category Top DMR Pollutants 7-2
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LIST OF TABLES (Continued)
Page
Table 7-3. Top Fluoride-Discharging Facilities in 2008 and 2009 DMR Databases 7-4
Table 8-1. Inorganic Chemicals Category TRI and DMR Discharges for the 2006 Through 2011
Toxicity Rankings Analyses 8-1
Table 8-2. Inorganic Chemicals Category Top TRI Pollutants 8-3
Table 8-3. Manganese and Manganese Compound Discharging Facilities in the Inorganic
Chemicals Category in the 2009 TRI Database 8-4
Table 8-4. Manganese and Manganese Compound Discharges for Tronox Pigments, Inc 8-5
Table 8-5. Manganese and Manganese Compound Discharges for Tronox LLC 8-5
Table 8-6. Dioxin and Dioxin-Like Compound Discharging Facilities in the 2009 TRI Database 8-6
Table 8-7. Dioxin and Dioxin-Like Compound Discharges for DuPont Edgemoor 8-6
Table 8-8. 2009 Concentrations of Dioxin and Dioxin-Like Compounds in Effluent Samples
(pg/L) From DuPont Edgemoor and EPA Method 1613B Minimum Levels 8-8
Table 9-1. Number of Iron and Steel Manufacturing Facilities 9-2
Table 9-2. Applicability and Regulated Pollutants for the Iron and Steel Manufacturing Category 9-3
Table 9-3. Iron and Steel Manufacturing Category TRI and DMR Discharges for the 2009
Through 2011 Toxicity Rankings Analyses 9-6
Table 9-4. Iron and Steel Manufacturing Category Top DMR Pollutants 9-6
Table 9-5. Iron and Steel Manufacturing Category Cyanide Dischargers in the 2009 DMR
Database 9-7
Table 9-6. Operating U.S. Coke Plants as of September 1, 2011 9-7
Table 9-7. U.S. Steel's Outfall 183 2009 Monthly Cyanide and Flow Discharge Data 9-8
Table 9-8. Mountain State Carbon's Outfall 205 2009 Monthly Cyanide and Flow Discharge
Data 9-9
Table 9-9. Iron and Steel Manufacturing Category Chlorine Dischargers in the 2009 DMR
Database 9-10
Table 9-10. ISG Sparrows Point's Outfall 001 2009 Monthly Chlorine Discharge and Flow Data 9-10
Table 9-11. Iron and Steel Manufacturing Category Chromium Dischargers in the 2009 DMR
Database 9-11
Table 9-12. Arcelormittal Weirton's 2009 Chromium Discharge and Flow Data 9-12
xi
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LIST OF TABLES (Continued)
Page
Table 9-13. Iron and Steel Manufacturing Category Fluoride Dischargers in the 2009 DMR
Database 9-12
Table 9-14. Arcelormittal Weirton's Outfall 003 2009 Monthly Fluoride Discharge and Flow
Data 9-13
Table 9-15. Iron and Steel Manufacturing Category Aluminum Dischargers in the 2009 DMR
Database 9-13
Table 9-16. Ipsco Tubulars's Outfall 003 2009 Monthly Aluminum Discharge and Flow Data 9-14
Table 9-17. Nucor Steel's Outfall 001 Tuscaloosa 2009 Aluminum Discharge and Flow Data 9-15
Table 9-18. Nucor Steel Decatur's Outfall 002 2009 Monthly Aluminum Discharge and Flow
Data 9-15
Table 10-1. Landfills Category TRI and DMR Discharges for the 2009 Through 2011 Toxicity
Rankings Analyses 10-1
Table 10-2. Landfills Category Top DMR Pollutants 10-2
Table 10-3. Top Facilities Discharging Pollutants of Concern in the 2009 DMR Database 10-2
Table 10-4. Butler County Landfill 2009 Top Discharges in the DMR Database 10-3
Table 10-5. Butler County Landfill 2009 Monthly Top Pollutant Discharge Data 10-3
Table 10-6. Tunnel Hill Reclamation 2009 Top Discharges in the DMR Database 10-3
Table 10-7. Tunnel Hill Reclamation 2009 Monthly Manganese Discharges for Outfall 001 10-4
Table 10-8. BFI Backridge Sanitary Landfill 2009 Discharges in the DMR Database 10-4
Table 10-9. BFI Backridge Sanitary Landfill 2009 Monthly Iron Discharges 10-5
Table 10-10. Iron Concentrations in the 2008 and 2009 DMR Database Compared to Treatability
Concentrations 10-7
Table 11-1. Number of Meat and Poultry Facilities 11-2
Table 11-2. Applicability, Regulated Pollutants, and BAT ELG Limits for the Meat and Poultry
Category 11-3
Table 11-3. Meat and Poultry Category TRI and DMR Discharges for the 2009 Through 2011
Toxicity Rankings Analyses 11-5
Table 11-4. Meat and Poultry Category Top TRI Pollutants 11-5
Table 11-5. Meat and Poultry Category Nitrate Compounds Dischargers in the 2009 TRI
Database 11-7
xii
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LIST OF TABLES (Continued)
Page
Table 11-6. BAT Treatment Basis for the Meat and Poultry Subcategories 11-8
Table 11-7. Minimum, Maximum, and Median Nitrate Concentrations in the 2009 DMR
Loadings Tool 11-11
Table 12-1. Number of Metal Finishing Facilities 12-1
Table 12-2. Applicability, Regulated Pollutants, and ELG Limits for the Metal Finishing
Category 12-2
Table 12-3. Metal Finishing Category TRI and DMR Discharges for the 2009 Through 2011
Toxicity Rankings Analyses 12-3
Table 12-4. Metal Finishing Category Top DMR Pollutants 12-3
Table 12-5. Metal Finishing Category Silver Dischargers in the 2009 DMR Database 12-4
Table 12-6. Eastman Kodak Park 2009 Monthly Silver and Flow Discharge Data for Outfall 001 12-4
Table 12-7. Metal Finishing Category Cyanide Dischargers in the 2009 DMR Database 12-5
Table 12-8. Eastman Kodak Windsor 2008 and 2009 Monthly Cyanide and Flow Discharge Data
for Outfall 001 12-6
Table 12-9. Metal Finishing Category PCB-1248 Dischargers in the 2009 DMR Database 12-6
Table 12-10. GM Tonawanda Outfall 001 2009 Monthly PCB-1248 Discharge and Flow Data 12-7
Table 12-11 GM Massena 2009 Monthly PCB-1248 Discharge and Flow Data 12-9
Table 13-1. Mineral Mining Category TRI and DMR Discharges for the 2006 Through 2011
Toxicity Rankings Analyses 13-1
Table 13-2. Mineral Mining Category Top DMR Pollutants 13-2
Table 13-3. Mineral Mining Category Cadmium Dischargers in the 2009 DMR Database 13-3
Table 13-4. Butala 2009 Monthly Cadmium and Flow Discharge Data for Outfall 002 13-4
Table 13-5. Mineral Mining Category Fluoride Dischargers in the 2009 DMR Database 13-4
Table 13-6. Feldspar 2009 Monthly Fluoride and Flow Discharge Data for Outfall 002 13-6
Table 13-7. Fort Green Mine Complex 2009 Fluoride and Flow Discharge Data 13-7
Table 13-8. Four Corners Mine 2009 Fluoride and Flow Discharge Data 13-9
Table 13-9. Four Corners Mine 2009 Flow Discharge Data 13-10
Xlll
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LIST OF TABLES (Continued)
Page
Table 13-10. South Fort Meade Mine 2009 Monthly Fluoride and Flow Discharge Data for
Outfall 001 13-10
Table 13-11. Mineral Mining Category Chlorine Dischargers in the 2009 DMR Database 13-11
Table 13-12. Carmeuse 2009 Monthly Chlorine and Flow Discharge Data for Outfall 015 13-11
Table 14-1. NFMM Category TRI and DMR Discharges for 2006 Through 2011 Toxicity
Rankings Analyses 14-1
Table 14-2. 2009 NFMM Category Top DMR Pollutants 14-2
Table 14-3. NFMM Category Top Mercury Discharging Facilities in the 2009 DMR Database 14-2
Table 14-4. NFMM Category Top Fluoride Discharging Facility in the 2009 DMR Database 14-3
Table 14-5. 2009 Monthly Fluoride and Flow Discharge Data for Horsehead Corporation 14-4
Table 14-6. NFMM Category Top Lead Discharging Facility in the 2009 DMR Database 14-5
Table 14-7. 2009 Monthly Lead and Flow Discharge Data for Buick Resource Recycling 14-6
Table 14-8. NFMM Category Top Cadmium Discharging Facilities in the 2009 DMR Database 14-8
Table 14-9. 2009 Monthly Cadmium and Flow Discharge Data for Nyrstar's Outfall 001 14-9
Table 14-10. NFMM Category Top Molybdenum Discharging Facility in the 2009 DMR
Databases 14-9
Table 14-11. 2009 Monthly Molybdenum Data for GulfChem's Outfalls 001 and 002 14-10
Table 15-1. OCPSF Category TRI and DMR Discharges for the 2006 Through 2011 Toxicity
Rankings Analysis 15-1
Table 15-2. OCPSF Category Top DMR Pollutants 15-2
Table 15-3. OCPSF Category Hexachlorobenzene Dischargers in the 2009 DMR Database 15-3
Table 15-4. 2009 DMR Hexachlorobenzene Discharges for Daikin American, Inc 15-4
Table 15-5. 2008 and 2009 Hexachlorobenzene Discharge Data for Chevron Oronite Outfall 202 15-5
Table 15-6. 2009 DMR Hexachlorobenzene Discharges for Nalco Company 15-6
Table 16-1. Oil and Gas Category TRI and DMR Discharges for the 2006 Through 2011 Toxicity
Rankings Analysis 16-1
Table 16-2. Oil and Gas Category Top DMR Pollutants 16-3
xiv
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LIST OF TABLES (Continued)
Page
Table 16-3. Oil and Gas Category Top Sulfide Discharging Facilities in the 2008 and 2009 DMR
Databases 16-5
Table 16-4. Marathon Oil Maverick Springs's Outfall 001 2007 Through 2009 Sulfide Discharge
Data 16-6
Table 17-1. Ore Mining Category TRI and DMR Discharges for 2002 Through 2009 17-1
Table 17-2. Summary of 2009 Ore Mining Facilities With Data in the DMR Database 17-2
Table 17-3. Top Facility Discharges in the 2009 DMR and TRI Databases3 17-3
Table 18-1. Pesticide Chemicals Category TRI and DMR Discharges for the 2006 Through 2011
Toxicity Rankings Analysis 18-1
Table 18-2. Pesticide Chemicals Category Top TRI Pollutants 18-2
Table 18-3. 2003-2010 GB Biosciences Corp. TRI PCB Discharges 18-3
Table 19-1. Petroleum Refining Category TRI and DMR Discharges for 2007 Through 2011
Toxicity Rankings Analysis 19-1
Table 19-2. Petroleum Refining Category Top TRI Pollutants 19-2
Table 19-3. Petroleum Refining Category Top DMR Pollutants 19-2
Table 19-4. Summary of Dioxin and Dioxin-Like Compound Discharges, 2004-2009 19-3
Table 19-5. Basis of Estimate Summary for 2009 Dioxin and Dioxin-Like Compound Discharges 19-3
Table 19-6. Bay Area Refineries Reformer Water Results3 19-4
Table 19-7. Total TRI PACs Discharges for Years 2004-2009 19-5
Table 19-8. Petroleum Refining Category Sulfide Dischargers in the 2009 DMR Database 19-5
Table 19-9. Top Sulfide Discharging Facilities 19-8
Table 19-10. Petroleum Refining Category Chlorine Dischargers in the 2009 DMR Database 19-9
Table 19-11. Premcor's Outfall 001 2009 Monthly Chlorine and Flow Discharge Data 19-9
Table 19-12. DMR Metal Discharges, 2000-2009 19-10
Table 19-13. 2009 Petroleum Refinery Metals DMR Discharges 19-10
Table 19-14. 2009 Top Petroleum Refineries Discharging Metals in DMR 19-11
Table 19-15. Dioxin and Dioxin-Like Discharges From Petroleum Refineries Reported to TRI in
2004-2009 19-14
xv
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LIST OF TABLES (Continued)
Page
Table 19-16. PAC Discharges from Petroleum Refineries Reported to TRI in 2004-2009 19-17
Table 20-1. Pulp and Paper Category TRI and DMR Discharges for 2007 Through 2011 Toxicity
Rankings Analysis 20-1
Table 20-2. Pulp and Paper Category Top TRI Pollutants 20-2
Table 20-3. Pulp and Paper Category Top DMR Pollutants 20-2
Table 20-4. Summary of Dioxin and Dioxin-Like Compound Discharges, 2004-2009 20-3
Table 20-5. Basis of Estimate Summary for 2009 Dioxin and Dioxin-Like Compound Discharges 20-4
Table 20-6. Dioxin and Dioxin-Like Compound Discharges in TRI for Simpson Tacoma, 2005-
2009 20-4
Table 20-7. Facility-Specific Dioxin and Dioxin-Like Congener Distribution 20-5
Table 20-8. Information on Top Pulp and Paper Category 2009 TRI Dioxin and Dioxin-Like
Compound Dischargers 20-7
Table 20-9. 2002-2009 Manganese and Manganese Compound Discharges in TRI and DMR 20-11
Table 20-10. Pulp and Paper Category Top Sulfide Discharging Facilities in the 2009 DMR
Database 20-11
Table 20-11. Sulfide Wastewater Treatment Options 20-12
Table 20-12. Smurfit-Stone Container's Outfall 001 2009 Monthly Sulfide Discharge Data 20-13
Table 20-13. Pulp and Paper Category Aluminum Dischargers in the 2009 DMR Database 20-13
Table 20-14. International Paper's Outfall 001 2009 Monthly Aluminum Discharge Data 20-14
Table 20-15. Median Concentration of Aluminum in Pulp and Paper Mill Effluent ((.ig/L) 20-15
Table 20-16. Dioxin and Dioxin-Like Discharges From Pulp and Paper Category Reported to TRI
in 2004-2009 20-18
Table 21-1. Timber Products Category TRI and DMR Discharges for the 2006 Through 2011
Toxicity Rankings Analysis 21-1
Table 21-2. Timber Products Category Top DMR Pollutants 21-2
Table 21-3. Timber Products Category Top TRI Chemicals 21-2
Table 21-4. Top Copper Discharging Facilities in the 2009 DMR Database 21-3
Table 21-5. Ed Arey's 2009 DMR Copper and Flow Discharge Data 21-4
xvi
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LIST OF TABLES (Continued)
Page
Table 21-6. Dioxin and Dioxin-Like Compounds Discharging Facilities in the 2009 TRI Database 21-5
Table 22-1. Textiles Category TRI and DMR Discharges for the 2006 Through 2011 Toxicity
Rankings Analysis 22-1
Table 22-2. Textiles Category Top DMR Pollutants 22-2
Table 22-3. Textiles Category Top Sulfide Discharging Facilities in the 2009 DMR Database 22-3
Table 22-4. Sulfide Wastewater Treatment Options 22-4
Table 22-5. Mohawk Industries 2008 and 2009 Monthly Sulfide Discharge Data for Outfall 0A1 22-6
Table 22-6. Gold Mills 2009 Monthly Sulfide Discharge Data 22-7
xvii
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LIST OF FIGURES
Page
Figure 11-1. Meat and Poultry Nitrate Concentration Probability Plot 11-11
xviii
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Section 1—Background
1. Background
This document supports EPA's Office of Water's Preliminary 2012 Effluent Guidelines
Program Plan (Preliminary 2012 Plan) (U.S. EPA, 2013). The Preliminary 2012 Plan provides
background on the CWA, the ELG planning process and review methodology and presents the
results of the 2011 Annual Reviews. This document details how EPA used reported discharge
data from the Toxic Release Inventory (TRI) and discharge monitoring reports (DMRs) to create
databases and estimate the toxicity of industrial discharges.
EPA is responsible for developing the programs and tools authorized under the Clean
Water Act (CWA), which enables EPA and the states to protect and restore the Nation's waters.
These programs and tools generally rely either on water-quality-based controls, such as water
quality standards and water-quality-based effluent limitations, or technology-based controls,
such as effluent guidelines and technology-based effluent limitations. In addition to developing
new regulations, the CWA requires EPA to review existing effluent guidelines annually. EPA
reviews all point source categories subject to existing effluent guidelines and pretreatment
standards to identify potential candidates for revision, consistent with CWA sections 304(b),
301(d), 304(g), and 307(b).
EPA has established ELGs to regulate wastewater discharges from 57 point source
categories and annually reviews the ELGs for these categories. EPA first conducts a toxicity
rankings analysis of all categories subject to existing ELGs to prioritize the categories for further
review. The Agency may then conduct another review, either an in-depth "preliminary or
detailed study" or a somewhat less detailed "preliminary category review," to identify existing
categories for potential ELGs revision.
Based on its toxicity rankings analysis, EPA was able to prioritize for further review (i.e.,
a preliminary or detailed study or preliminary category review) those industrial categories whose
pollutant discharges potentially pose the greatest hazards to human health or the environment
because of their toxicity (i.e., categories that collectively discharge over 95 percent of the total
TWPE). Table 1-1 presents the 19 industrial categories that EPA recently identified for
preliminary category review and one industrial category, Plastics Molding and Forming (40 CFR
Part 463), for a preliminary study. Sections 3 through 21 of this report provide the details of
EPA's review and conclusions for the top ranking industrial categories.
Table 1-1. Point Source Categories Collectively Discharging
Over 95% of the Total TWPE
40 CFR
Part
Point Source Category
Total TWPE
Cumulative
Percentage of Total
TWPE
Rank
430
Pulp, paper and paperboard
1,240,000
20.4%
1
418
Fertilizer manufacturing
912,000
35.5%
2
419
Petroleum refining
731,000
47.5%
3
414
Organic chemicals, plastics and synthetic fibers
687,000
58.8%
4
433
Metal finishing
283,000
63.5%
5
435
Oil & gas extraction3
238,000
67.4%
6
420
Iron and steel manufacturing
230,000
71.2%
7
1-1
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Section 1—Background
Table 1-1. Point Source Categories Collectively Discharging
Over 95% of the Total TWPE
40 CFR
Part
Point Source Category
Total TWPE
Cumulative
Percentage of Total
TWPE
Rank
445
Landfills
222,000
74.8%
8
421
Nonferrous metals manufacturing
215,000
78.4%
9
440
Ore mining and dressing
208,000
81.8%
10
463
Plastics molding and forming
177,000
84.7%
11
415
Inorganic chemicals manufacturing
124,000
86.8%
12
429
Timber products processing
121,000
88.8%
13
436
Mineral mining and processing
85,500
90.2%
14
432
Meat and poultry products
71,000
91.3%
15
434
Coal mining
66,800
92.4%
16
437
Centralized waste treatment
51,000
93.3%
17
455
Pesticide chemicals
45,700
94.0%
18
467
Aluminum forming
39,700
94.7%
19
410
Textile mills
39,100
95.3%
20
Total
6,070,000b
a The 2011 preliminary category review did not include the review of the shale gas extraction or coalbed methane
sectors as they are currently under review by EPA. See 76 FR 66286 (October 26, 2011) (although EPA is
proposing to delist from rulemaking the coalbed methane extraction subcategory from the effluent guidelines
plan).
b Total industry TWPE is the sum of the combined 2009 TWPE for all point source categories, not just the top 95
percent.
1.1 Background References
1. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
1-2
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Section 2—Public Comments on the Final 2010 Effluent Guidelines Program Plan
2. Public Comments on the Final 2010 Effluent Guidelines Program Plan
EPA published its Final 2010 Effluent Guidelines Program Plan (Final 2010 Plan) on
October 26, 2011 (76 FRN 27742) and requested comments on various aspects of its analyses,
data, and information to inform its 2011 annual review and one detailed study. The Agency
received 31 sets of comments on the Final 2010 Plan. The comment period closed November 25,
2011 but was extended until February 27, 2012 after EPA received four requests for extension.
Table 2-1 lists the commenters as well as a synopsis of the comments.
2-1
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Section 2—Public Comments on the Final 2010 Effluent Guidelines Program Plan
Table 2-1. Comments on the Final 2010 Effluent Guidelines Program Plan EPA Docket Number: EPA-HQ-OW-2008-0517
No.
Commcnter Name
EPA
Docket
No.
Comment Summary
1
Graham Brannin (City of Tulsa,
OK)
0817
Supports dental amalgam best management practices (BMPs) only, does not support numerical limits or
clarification of dental offices as standard industrial users (SIUs); opposes traditional effluent guidelines
to regulate discharges of unused pharmaceuticals.
2
Rosalind Volpe (Silver
Nanotechnology Working Group
(SNWG))
0819
Recommends collaborating with the EPA Office of Pesticides Programs (OPP) for information on
nanosilver.
3
Barry Russell (Independent
Petroleum Association of
America (IPAA) et. Al)
0820
Requests a 60-day comment period extension.
4
Dennis Lathem (Coalbed
Methane Association of
Alabama)
0821
Requests a 60-day comment period extension.
5
Jonathan Bridges
(Littleton/Englewood
Wastewater Treatment Plant)
0822
Recommends reconsidering moving forward with National Dental Amalgam regulations, stating that
standards should apply only to publicly owned treatment works (POTWs) that discharge to mercury-
impaired receiving waters. Notes that state and local programs already exist and it is it unnecessary to
change the regulations.
6
Roger Claff (American
Petroleum Institute (API))
0823
Supports moving forward with an ELG for CBM but urges EPA to investigate non-water quality impacts
of treatment technologies and maintain collaboration with industry stakeholders. Supports moving
forward with SGE pretreatment standards but recommends maintaining collaboration with industry
stakeholders.
7
David Snyder (Los Angeles
County Sanitation Districts)
0824
Supports dental amalgam BMPs because the cost of regulating dental amalgam would be high.
Recommends EPA take a leading role in convening a volunteer National Amalgam Separator Review
Committee.
8
Terrie Mitchell (Sacramento
Regional County Sanitation
District)
0825
Supports dental amalgam BMPs only to minimize POTW burden, stating standards should apply only to
POTWs that discharge to mercury-impaired receiving waters. Provided additional information on dental
amalgam discharges.
9
Luther Strange (State of Alabama
Office of the Attorney General)
0826
Requests a 60-day comment period extension.
10
Robert Aderhold (Congress of
the United States, House of
Representatives)
0827
Requests a 60-day comment period extension.
2-2
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Section 2—Public Comments on the Final 2010 Effluent Guidelines Program Plan
Table 2-1. Comments on the Final 2010 Effluent Guidelines Program Plan EPA Docket Number: EPA-HQ-OW-2008-0517
No.
Commcnter Name
EPA
Docket
No.
Comment Summary
11
Peter Berglund (Metropolitan
Council Environmental Services)
0828
Recommends that EPA take a leading role in convening a volunteer National Amalgam Separator
Review Committee. Provided data supporting the National Review of Amalgam Separators.
12
Kathryn Klaber (Marcellus Shale
Coalition (MSC))
0829
Opposes moving forward with ELGs for SGE.
13
Cynthia A. Finley (National
Association of Clean Water
Agencies (NACWA))
0830
Supports dental amalgam BMPs, does not support numerical limits or clarification of dental offices as
SIUs; supports moving forward with an ELG for nanosilver manufacturing because EPA needs to
address the problem of nanosilver and silver discharges from domestic sources; supports moving
forward with an ELGs for SGE as long as the standards are scientifically and economically sound.
14
J. Dillard
0831
Recommends EPA examine electric vehicle batter manufacturing and landfills for unregulated
discharges.
15
Pete Miller (Range Resources)
0832
Opposes moving forward with the ELGs for CBM because the wastewater is mostly recycled or reused.
Opposes moving forward with ELGs and pretreatment standards for SGE because current regulations
and treatment methods are sufficient and the majority of wastewater is recycled and reused.
16
Lee Fuller (Independent
Petroleum Association of
America (IPAA))
0833
Opposes moving forward with ELGs for CBM because CBM wastewaters are already regulated and an
ELG is inflexible and does not account for future technological improvement. Opposes moving forward
with ELGs for SGE due to the high variability of the wastewater.
17
Eric Uram (Coalition for
SafeMinds)
0834
Supports ELGs for ethyl mercury specifically, particularly for the pharmaceutical manufacturing
industry.
18
John V. Corra (Wyoming
Department of Environmental
Quality)
0835
Supports moving forward with ELGs for SGE. Opposes moving forward with ELGs for CBM because
the ELG is inflexible and does not account for future technological improvement and CBM wastewaters
are beneficially used in agricultural applications.
19
John Pastor (Southern California
Alliance of Publicly Owned
Treatment Works (SCAP))
0836
Supports dental amalgam BMPs, states that standards should apply only to POTWs that discharge to
mercury-impaired receiving waters.
20
DonM. Nevin (LAMNIpipe Inc.)
0837
Provided data on technology solutions for treating naturally occurring radioactive material (NORM) in
SGE produced water.
21
Christopher T. Hall
(Metropolitan Sewer District of
Greater Cincinnati)
0838
Supports moving forward with ELGs for CBM and SGE. Supports dental amalgam BMPs, does not
support numerical limits or clarification of dental offices as SIUs.
2-3
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Section 2—Public Comments on the Final 2010 Effluent Guidelines Program Plan
Table 2-1. Comments on the Final 2010 Effluent Guidelines Program Plan EPA Docket Number: EPA-HQ-OW-2008-0517
No.
Commcnter Name
EPA
Docket
No.
Comment Summary
22
Patrick O'Neil (Geological
Survey of Alabama)
0846
Provided detailed comments on the CBM Detailed Study Report.
23
Suzanne Wienke (Los Angeles
County Sanitation Districts)
0847
Recommends EPA look into nanosilver and silver discharges from domestic sources. Opposes ELGs for
nanosilver because local limits are sufficient.
24
John Downs (Cabot Specialty
Fluids Limited)
0848
Recommends EPA consider recognizing formate brines as a unique class of green chemistry fluids and
improve the hazard assessment technique so that it is sufficiently discriminating.
25
Rebecca Hammer (Natural
Resources Defense Council et
al.)
0849
Recommends that pretreatment standards should be developed for all oil and gas wastewaters. Supports
moving forward with ELGs for SGE because POTWs alone cannot sufficiently treat SGE wastewater.
States that if SGE discharges to POTWs are allowed, the pretreatment standards should be set as
stringently as possible. Recommends that ELGs for Centralized Waste Treatment facilities should be
updated in order to address SGE wastewater.
26
Rayza Santiago (University of
Pittsburgh Environmental Law
Clinic on behalf of Clean Water
Action)
0850
Supports moving forward with ELGs for CBM and urges EPA to advance the timeline for the proposal
of ELGs for CBM because treatment technologies are available. Commenter provided additional data on
SGE and CBM treatment technologies.
27
Walter Baker (Association of
Clean Water Administrators
(ACWA))
0851
Supports moving forward with ELGs for CBM. Recommends EPA develop ELGs for emerging
pollutants, study the effects of all nanoparticles on the environment, reexamine the metal finishing
category due to significant changes in the industry over the last few years, continue study of proper
pharmaceutical disposal, and look into electric vehicle batter manufacturing wastewater discharges. Also
recommends that EPA should not shift away from technology-based regulations because total reliance
on water quality standards is not effective.
28
Rob Beranek (Cliffs Natural
Resources Inc.)
0852
Provides comments on the Ore Mining Preliminary Study.
29
Dennis Lathem (Coalbed
Methane Association of Alabama
(CMAA))
0853
Opposes moving forward with ELGs for CBM because CBM wastewaters are highly variable and ELGs
are not flexible.
30
Amanda E. Aspatore (National
Mining Association (NMA))
0854
Supports EPA's decision not to move forward with revision to the Ore Mining ELGs. States that the data
in the Ore Mining Preliminary Study is outdated, faulty, and misused.
31
Robert J. Lenney (Reynolds
Metals Company, subsidiary of
Alcoa, Inc.)
0855
Provided a petition to revise the Nonferrous Metals Manufacturing Potline S02 Wet Air Pollution
Control Subcategory.
2-4
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Section 3—Methodology, Data Sources, and Limitations
3. Methodology, Data Sources, and Limitations
EPA reviewed effluent discharge data to fulfill its Clean Water Act obligations,
generating the preliminary rankings shown in Table 1-1. The Clean Water Act (CWA) requires
EPA to conduct an annual review of existing effluent limitations guidelines and pretreatment
standards (ELGs) (U.S. EPA, 2013). It also requires EPA to identify industrial categories without
applicable ELGs. EPA's methodology for the 2011 Annual Reviews and new point source
category identification involves several components, as discussed the Preliminary 2012 Plan
(U.S. EPA, 2013). This report discusses the toxicity rankings analysis and further review of point
source categories subject to existing ELGs.
First, EPA performs a toxicity rankings analysis of all point source categories subject to
existing ELGs to identify categories discharging high levels of toxic and nonconventional
pollutants relative to other categories. Second, EPA identifies priority categories as possible
candidate ELGs for revision, consistent with CWA sections 304(b), 301(d), 304(g), and 307(b).
EPA then performs further review of the priority categories. Section 4 of the Preliminary 2012
Plan discusses the findings of EPA's 2011 Annual Reviews (U.S. EPA, 2013). Sections 3
through 21 of this report provide more details on the individual category reviews and their
conclusions.
In performing the toxicity rankings analysis of existing ELGs, EPA generates databases
to evaluate discharge monitoring report (DMR) data, contained in EPA's Permit Compliance
System (PCS) and the Integrated Compliance Information System for the National Pollutant
Discharge Elimination System (ICIS-NPDES), and the Toxics Release Inventory (TRI). This
section discusses these databases, related data sources, and their limitations.
EPA developed two toxicity rankings analysis tools, the TRIReleases and DMRLoads
databases, to facilitate analysis of TRI and PCS/ICIS-NPDES data. EPA previously explained
the creation of these toxicity rankings analysis tools in the Technical Support Document for the
Annual Review of Existing Effluent Guidelines and Identification of Potential New Point Source
Categories (2009 Screening-Level Analysis (SLA) Report) (U.S. EPA, 2009). The 2009 SLA
Report provides the detailed methodology used to process thousands of data records and generate
national estimates of industrial effluent discharges. This section does not revisit the details of
creating the database tools. Instead, it lists the methodology corrections made to the DMRLoads
and TRIReleases databases as part of EPA's 2011 Annual Reviews.
3.1 Data Sources and Limitations
This subsection provides general information on the use of Standard Industrial
Classification (SIC) and North American Industry Classification System (NAICS) codes, toxic
weighting factors (TWFs), TRI data, and DMR data. The following reports supplement this
section and discuss EPA's methodology for developing and using the two toxicity rankings
analysis tools:
• Technical Support Document for the Annual Review of Existing Effluent
Guidelines and Identification of Potential New Point Source Categories, (2009
SLA Report) (U.S. EPA, 2009). Documents the methodology and development of
the DMRLoads2009 and TRIReleases2009 databases, including (but not limited
3-1
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Section 3—Methodology, Data Sources, and Limitations
to) matching NAICS and SIC codes to point source categories and using TWFs to
estimate toxic-weighted pound equivalents (TWPE).
• Draft Toxic Weighting Factor Development in Support of the CWA 304(m)
Planning Process (Draft TWF Development Document), dated July 2005 (U.S.
EPA, 2005). Explains how EPA developed the December 2004 TWFs.
• Toxic Weighting Factor Development in Support of the CWA 304(m) Planning
Process (Final TWF Development Document) (U.S. EPA, 2006b). Explains how
EPA developed the April 2006 TWFs.
3.1.1 SIC Codes
The SIC code system was developed to help with the collection, aggregation,
presentation, and analysis of data from the U.S. economy (OMB, 1987). The different parts of
the SIC code signify the following:
• The first two digits represent the major industry group;
• The third digit represents the industry group; and
• The fourth digit represents the industry.
For example, major SIC code 26: Paper and Allied Products includes all pulp, paper, and
paperboard manufacturing operations. Within SIC code 26, the three-digit SIC codes are used to
distinguish the type of facility: 263 for paperboard mills, 265 for paperboard containers and
boxes, etc. Within SIC code 265, the four-digit SIC codes are used to separate facilities by
product type: 2652 for setup paperboard boxes, 2653 for corrugated and solid fiber boxes, etc.
The SIC system is used by many government agencies, including EPA, to promote data
comparability. In the SIC system, each establishment is classified according to its primary
economic activity, which is determined by its principal product or group of products. An
establishment may have activities in more than one SIC code. Some data collection organizations
track only the primary SIC code for each establishment. PCS and ICIS-NPDES include one four-
digit SIC code, reflecting the principal activity causing the discharge at each facility.
Regulations for an individual point source category may apply to one SIC code, multiple
SIC codes, or a portion of the facilities in an SIC code. Therefore, to use databases that identify
facilities by SIC code, EPA linked each four-digit SIC code to an appropriate point source
category, as summarized in the "SIC/Point Source Category Crosswalk" table (Table A-l in
Appendix A).
There are some SIC codes for which EPA has not established national ELGs. Table A-2
in Appendix A lists the SIC codes for which facility discharge data are available in PCS and
ICIS-NPDES, but for which EPA could not identify an applicable point source category. For a
more detailed discussion, see Section 6 of the 2009 SLA Report (U.S. EPA, 2009).
3-2
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Section 3—Methodology, Data Sources, and Limitations
3.1.2 NAICS Codes
In 1997, the U.S. Census Bureau introduced the NAICS code system, to better represent
the economic structure of countries participating in the North American Free Trade Agreement
and to respond to criticism about the SIC code system. Table 3-1 explains the nomenclature and
format of NAICS and SIC codes.
Table 3-1. Nomenclature and Format of NAICS and SIC Codes
NAICS
SIC
2-digit
Sector
Letter
Division
3-digit
Subsector
2-digit
Major Group
4-digit
Industry Group
3-digit
Industry Group
5-digit
NAICS Industry
4-digit
Industry
6-digit
U.S. Industry
N/A
N/A
For example, below are the SIC and NAICS code for the Folding Paperboard Box
Manufacturing industry.
In the SIC code system the classification is less stratified:
• 26: Paper and Allied Paper Products;
— 265: Paperboard containers and boxes;
o 2657: Folding Paperboard Boxes, Including Sanitary (except
paperboard backs for blister or skin packages).
In the NAICS code system the classification is more stratified:
• 32: Manufacturing;
— 322: Paper Manufacturing;
o 3222: Converted Paper Product Manufacturing;
• 322212: Folding Paperboard Box Manufacturing.
The NAICS system is used for industrial classification purposes at many government
agencies, including EPA. As in the SIC system, each establishment is classified according to its
primary economic activity, which is determined by its principal product or group of products. An
establishment may have activities in more than one NAICS code.
Regulations for an individual point source category may apply to one NAICS code,
multiple NAICS codes, or a portion of the facilities in an NAICS code. Therefore, to use
databases that identify facilities by NAICS code (e.g., TRI), EPA linked each six-digit NAICS
code to an appropriate point source category, as summarized in the "NAICS/Point Source
Category Crosswalk" table (Table A-3 in Appendix A). This table was based on the SIC/Point
3-3
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Section 3—Methodology, Data Sources, and Limitations
Source Category Crosswalk table (Table A-l in Appendix A) and the NAICS/SIC Code
Crosswalk that EPA developed for past comparisons.
There are some NAICS codes for which EPA has not established national ELGs. Table
A-4 in Appendix A lists the NAICS codes for which facility discharge data are available in TRI,
but for which EPA could not identify an applicable point source category. For a more detailed
discussion, see Section 6 of the 2009 SLA Report (U.S. EPA, 2009).
3.1.3 Toxic Weighting Factors
As part of the Effluent Guidelines Program, EPA developed a wide variety of tools and
methodologies to evaluate effluent discharges. EPA's Office of Water, Engineering and Analysis
Division (EAD) maintains a Toxics Database compiled from over 100 references for more than
1,900 pollutants. The Toxics Database includes aquatic life and human health toxicity data, as
well as physical and chemical property data. Each pollutant in this database is identified by a
unique Chemical Abstract Service (CAS) number. EPA calculates TWFs from these data to
account for differences in toxicity across pollutants and to provide the means to compare mass
loadings of different pollutants. In its analyses, EPA multiplies a mass loading of a pollutant in
pounds per year (lb/yr) by a pollutant-specific weighting factor to derive a "toxic-equivalent"
loading (lb-equivalent/yr). Throughout this document, the toxic-equivalent is also referred to as
TWPE. The Draft and Final TWF Development Documents discuss the use and development of
TWFs in detail (U.S. EPA, 2005; U.S. EPA, 2006b).
EPA derives TWFs from chronic aquatic life criteria (or toxic effect levels) and human
health criteria (or toxic effect levels) established for the consumption of fish. In the TWF method
for assessing water-based effects, these aquatic life and human health toxicity levels are
compared to a benchmark value that represents the toxicity level of a specified pollutant. EPA
selected copper, a metal commonly detected and removed from industrial effluent, as the
benchmark pollutant. The Final TWF Development Document contains details on how EPA
developed its TWFs (U.S. EPA, 2006b). Table A-5 in Appendix A lists the TWFs for those
chemicals in the DMRLoads2009 and TRIReleases2009 databases for which EPA has developed
TWFs.
3.1.3.1 New Toxic Weighting Factors Developed During the 2011 Annual
Reviews
During the 2011 Annual Reviews, EPA did not revise any TWFs or develop TWFs for
any chemicals that had not previously had TWFs.
3.1.3.2 Calculation of TWPE
EPA weighted the annual pollutant discharges calculated from the TRIReleases (see
Section 3.1.4) andDMRLoads (see Sections 3.1.5) databases using EAD's TWFs to calculate
TWPE for each reported discharge. EPA summed the estimated TWPE discharged by each
facility in a point source category to understand the potential hazard of the discharges from each
category. The following subsections discuss the calculation of TWPE.
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Section 3—Methodology, Data Sources, and Limitations
3.1.4 Data from TRI
TRI is the common name for Section 313 of the Emergency Planning and Community
Right-to-Know Act. Each year, facilities that meet certain thresholds must report their releases
and other waste management activities for listed toxic chemicals. Facilities must report the
quantities of toxic chemicals recycled, collected, and combusted for energy recovery, treated for
destruction, or disposed of. A separate report must be filed for each chemical that exceeds the
reporting threshold. The TRI list of chemicals for reporting year 2009 includes more than 650
chemicals and chemical categories. For the 2011 toxicity rankings analysis, EPA used data for
reporting year 2009, because they were the most recent available at the time the review began.
A facility must meet the following three criteria to be required to submit a TRI report for
a given reporting year:
1. NAICS Code Determination. The primary NAICS code determines if TRI
reporting is required. The primary NAICS code is associated with the facility's
revenues, and may not relate to its pollutant discharges (73 FR 324666). Certain
facilities in NAICS codes 11, 21, 22, 31 through 33, 42, 48 through 49, 51, 54, 56
and 81, and federal facilities are potentially subject to TRI reporting. EPA
generally relies on facility claims regarding the NAICS code identification.
2. Number of Employees. Facilities must have 10 or more full-time employees or
their equivalent. EPA defines a "full-time equivalent" as a person that works
2,000 hours in the reporting year (there are several exceptions and special
circumstances that are well defined in the TRI reporting instructions).
3. Activity Thresholds. If the facility is in a covered NAICS code and has 10 or more
full-time employee equivalents, it must conduct an activity threshold analysis for
every chemical and chemical category on the current TRI list. The facility must
determine whether it manufactures, processes, or otherwise uses each chemical at
or above the appropriate activity threshold. Reporting thresholds are not based on
the amount of release. All TRI thresholds are based on mass, not concentration.
Different thresholds apply for persistent bioaccumulative toxic (PBT) chemicals
than for non-PBT chemicals. Generally, non-PBT chemical threshold quantities
are 25,000 pounds for manufacturing and processing activities and 10,000 pounds
for other use activities. All thresholds are determined per chemical over the
calendar year. For example, dioxin and dioxin-like compounds are considered
PBT chemicals. The TRI reporting guidance requires any facility that
manufactures, processes, or otherwise uses 0.1 grams of dioxin and dioxin-like
compounds to report it to TRI (U.S. EPA, 2000).
In TRI, facilities report annual loads released to the environment of each toxic chemical
or chemical category that meets reporting requirements. Facilities must report onsite releases or
disposal to air, receiving streams, land, underground wells, and several other categories. They
must also report the amount of toxic chemicals in wastes transferred to off-site locations, (e.g.,
POTWs, commercial waste disposal facilities).
For its toxicity rankings analysis, EPA focused on the amount of chemicals facilities
reported either discharging directly to a receiving stream or transferring to a POTW. For
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Section 3—Methodology, Data Sources, and Limitations
facilities discharging directly to a stream, EPA took the annual loads directly from the reported
TRI data for calendar year 2009. For facilities transferring to POTWs, EPA first adjusted the TRI
pollutant loads reported to account for pollutant removal that occurs at the POTWs prior to
discharge to the receiving stream. Table A-6 in Appendix A lists the POTW removals used for
all TRI chemicals reported as transferred to POTWs.
Facilities reporting to TRI are not required to sample and analyze waste streams to
determine the quantities of toxic chemicals released. They may estimate releases based on mass
balance calculations, published emission factors, site-specific emission factors, or other
approaches. Facilities are required to indicate, by a reporting code, the basis of their release
estimate. TRI's reporting guidance is that, for most chemicals reasonably expected to be present
but measured below the detection limit, facilities should use half the detection limit to estimate
the mass released. However, for dioxins and dioxin-like compounds, non detects should be
treated as zero.
TRI allows facilities to report releases as specific numbers or as ranges, if appropriate.
Specific estimates are encouraged if data are available to ensure the accuracy; however, EPA
allows facilities to report releases in the following ranges: 1 to 10 pounds, 11 to 499 pounds, and
500 to 999 pounds. For its toxicity rankings analyses, EPA used the midpoint of each reported
range to represent a facility's releases, as applicable.
3.1.4.1 Utility of TRI Data
The data collected in TRI are particularly useful for ELG planning for the following
reasons:
• TRI is national in scope, including data from all 50 states and U.S.
territories/tribes;
• TRI includes releases to POTWs, not just direct discharges to surface water;
• TRI includes discharge data from manufacturing NAICS codes and some other
industrial categories; and
• TRI includes releases of many toxic chemicals, not just those in facility discharge
permits.
3.1.4.2 Limitations of TRI
For purposes of ELG planning, limitations of the data collected in TRI include the
following:
• Small establishments (less than 10 employees) are not required to report, nor are
facilities that do not meet the reporting thresholds. Thus, facilities reporting to
TRI may be a subset of an industry.
• Release reports are, in part, based on estimates, not measurements, and, due to
TRI guidance, may overstate releases, especially at facilities with large
wastewater flows.
3-6
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Section 3—Methodology, Data Sources, and Limitations
• Certain chemicals (polycyclic aromatic compounds (PACs), dioxin and dioxin-
like compounds, metal compounds) are reported as a class, not as individual
compounds. Because the individual compounds in most classes have widely
varying toxic effects, the potential toxicity of chemical releases can be
inaccurately estimated.
• Facilities are identified by NAICS code, not point source category. For some
NAICS codes, it may be difficult or impossible to identify the point source
category that is the source of the toxic wastewater releases.
Despite these limitations, EPA determined that the data summarized in TRIReleases2009
were usable for the 2011 toxicity rankings analysis and prioritization of the toxic-weighted
pollutant loadings discharged by industrial categories.
3.1.5 Data from PCS and ICIS-NPDES
EPA has used data reported to PCS as a part of its toxicity rankings analysis of existing
effluent guidelines since the 2003 Annual Reviews (68 FRN 75515). Since 2002, EPA has been
working to modernize PCS by creating a new data system called ICIS-NPDES. In 2006, some
states began transitioning their DMR reporting from PCS to ICIS-NPDES. Currently 57 of the 71
states and territories/tribes have migrated to ICIS-NPDES. Therefore, for the 2011 Annual
Reviews, EPA's view of nationwide discharges was split between two sets of data. EPA created
the 2009 DMR Loadings Tool to combine the two systems (PCS and ICIS-NPDES) and generate
industrial category rankings for all U.S. states and territories/tribes. EPA extracted the loads from
the 2009 DMR Loadings Tool to create the DMRLoads2009 database. Both PCS and ICIS-
NPDES automate entering, updating, and retrieving NPDES data and track permit issuance,
permit limits, monitoring data, and other data pertaining to facilities regulated by the NPDES
program under the CWA.
More than 65,000 industrial facilities and wastewater treatment plants have permits for
wastewater discharges to waters of the United States. To provide an initial framework for setting
permitting priorities, EPA developed a major/minor classification system for industrial and
municipal wastewater discharges. Major discharges usually have the capability to impact
receiving waters if not controlled and, therefore, have received more regulatory attention than
minor discharges. There are approximately 7,000 facilities (including sewerage systems) with
major discharges and 15,000 facilities with minor discharges for which PCS and ICIS-NPDES
have extensive records. Permitting authorities classify discharges as major based on an
assessment of six characteristics (U.S. EPA, 2010):
1.
Toxic pollutant potential;
2.
Discharge flow: stream flow ratio;
3.
Conventional pollutant loading;
4.
Public health impact;
5.
Water quality factors; and
3-7
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Section 3—Methodology, Data Sources, and Limitations
6. Proximity to coastal waters.
Facilities with major discharges must report compliance with NPDES permit limits via
monthly DMRs submitted to the permitting authority. The permitting authority enters the
reported DMR data into PCS or ICIS-NPDES, including pollutant concentration and quantity
values and identification of any types of permit violations.
Minor discharges may, or may not, adversely impact receiving water if not controlled.
Facilities with minor discharges must report compliance with NPDES permit limits via monthly
DMRs submitted to the permitting authority; however, EPA does not require the permitting
authority to enter data in the PCS and ICIS-NPDES databases. For this reason, the PCS and
ICIS-NPDES databases include data only for a limited set of minor discharges (i.e., if the state or
other permitting authority chooses to include these data).
Parameters in PCS and ICIS-NPDES include water quality parameters (such as pH and
temperature), specific chemicals, conventional parameters (such as biochemical oxygen demand
(BOD5) and total suspended solids (TSS)), and flow rates. Although other pollutants may be
discharged, PCS and ICIS-NPDES contain data only for the parameters identified in the facility's
NPDES permit. Facilities typically report monthly average pounds per day discharged, but also
report daily maxima and average pollutant concentrations.
For the 2011 Annual Reviews, EPA used data for reporting year 2009, to correspond to
the data obtained from TRI. For the 2011 Annual Reviews, EPA corrected certain aspects of the
2009 data (see Section 3.3). Using the DMR Loadings Tool, EPA calculated annual loads for the
PCS and ICIS-NPDES data and then combined the calculated loads for each set of data. EPA
extracted the results of the annual loads calculations in the DMRLoads2009 database. Section 2
of the 2009 SLA Report provides details on the methodology and development of
DMRLoads2009 (U.S. EPA, 2009).
3.1.5.1 Utility of PSC and ICIS-NPDES
The data collected in the PCS and ICIS-NPDES data systems are particularly useful for
the ELG planning process for the following reasons:
• PCS and ICIS-NPDES combined are national in scope, including data from all 50
states and 21 U.S. territories/tribes.
• Discharge reports included in PCS and ICIS-NPDES are based on effluent
chemical analysis and metered flows.
• PCS and ICIS-NPDES include facilities in all SIC codes.
• PCS and ICIS-NPDES include data on conventional pollutants for most facilities
and for the nutrients nitrogen and phosphorus for many facilities.
3.1.5.2 Limitations of PCS and ICIS-NPDES
Limitations of the data collected in the PCS and ICIS-NPDES data systems include the
following:
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Section 3—Methodology, Data Sources, and Limitations
• The data systems contain data only for pollutants a facility is required by permit
to monitor; the facility is not required to monitor or report all pollutants actually
discharged.
• The data systems include limited discharge monitoring data from minor
dischargers.
• The data systems do not include data characterizing indirect discharges from
industrial facilities to POTWs.
• Many of the pollutant parameters included in the data systems are reported as a
group parameter and not as individual compounds (e.g., "Total Kjeldahl
Nitrogen," "oil and grease"). Because the individual compounds in the group
parameter may have widely varying toxic effects, the potential toxicity of
chemical releases can be inaccurately estimated.
• In some cases, the data systems identify the type of wastewater (e.g., process
wastewater, stormwater, noncontact cooling water) being discharged; however,
most do not and, therefore, total flow rates reported to PCS and ICIS-NPDES may
include stormwater and noncontact cooling water, as well as process wastewater.
• Pipe identification is not always clear. For some facilities, internal monitoring
points are labeled as outfalls, and PCS and ICIS-NPDES may double-count a
facility's discharge. In other cases, an outfall may be labeled as an internal
monitoring point, and PCS and ICIS-NPDES may not account for all of a
facility's discharge.
• Facilities are identified by SIC code, not point source category. For some SIC
codes, it may be difficult or impossible to identify the point source category that
is the source of the reported wastewater discharges1.
• PCS and ICIS-NPDES were designed as a permit compliance tracking system and
do not contain production information.
• PCS and ICIS-NPDES data may be entered into the data systems manually, which
leads to data-entry errors.
• In PCS and ICIS-NPDES, data may be reported as an average quantity, maximum
quantity, average concentration, maximum concentration, and/or minimum
concentration. For many facilities and/or pollutants, average quantity values are
not provided. In these cases, EPA is limited to estimating facility loads based on
the maximum quantity. Section 3.2.3 of the 2009 SLA Report discusses the
maximum quantity issue in detail (U.S. EPA, 2009).
• PCS and ICIS-NPDES data on conventional pollutants and the nutrients nitrogen
and phosphorus are not used because of data quality concerns.
1 ICIS-NPDES includes a data field for applicable ELGs; however, it is not required and typically not populated.
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Section 3—Methodology, Data Sources, and Limitations
Despite these limitations, EPA determined that the data summarized in DMRLoads2009
were usable for the toxicity rankings analyses and prioritizations of the toxic-weighted pollutant
loadings discharged by industrial facilities. The combined PCS and ICIS-NPDES databases
remain the only data source quantifying the pounds of regulated pollutants discharged directly to
surface waters of the United States.
3.2 Methodology Correction Affecting Both Toxicity Rankings Analysis Databases
The 2009 SLA Report provides detailed information on the methodology EPA used to
develop the toxicity rankings analysis databases (U.S. EPA, 2009). For the 2011 Annual
Reviews, EPA did not make any methodological changes to the toxicity rankings analysis
databases, TRIReleases2009 and DMRLoads2009.
3.3 Corrections to the DMRLoads2009 Database
EPA developed the DMRLoads2009 database as part of the 2011 Annual Reviews using
the methodology explained in the 2009 SLA Report (U.S. EPA, 2009) with the methodology
updates described in Section 4.2.1 of the 2010 TSD (U.S. EPA, 2011).
During previous toxicity rankings analyses, EPA identified numerous facility-specific
corrections for PCS and ICIS-NDPES data reported for calendar years 2000, 2002, 2004, and
2006 though 2008. Several of these corrections similarly apply to the 2009 DMR data. In
addition, EPA reviewed the quality of the 2009 DMR data and facilities with discharges that
have the greatest impact on total category loads and category rankings. Table B-2 in Appendix B
of this report lists all corrections made to the 2009 DMR data in the DMR Loadings Tool.
3.3.1 DMRLoads2009: Categorization of Discharges
This subsection describes database corrections to facility categorization and pollutant
discharges in DMRLoads2009. Section 4 of the 2009 SLA Report describes the SIC/Point Source
Category Crosswalk development, which EPA uses to link between facility SIC codes and
categories with existing ELGs (U.S. EPA, 2009). Because most point source categories are not
defined by SIC code, the relationship between SIC code and point source category is not a one-
to-one correlation. A single SIC code may include facilities in more than one point source
category, and associating an SIC code with only one category may be an oversimplification.
Also, many facilities have operations subject to more than one point source category. Further,
facilities in some categories cannot be identified by SIC code (e.g., Centralized Waste Treatment
facilities). Section 4 of the 2009 SLA Report describes the database changes, summarized below
(U.S. EPA, 2009):
• Facility-Level Point Source Category Assignment. For some SIC codes that
include facilities subject to guidelines from more than one point source category,
EPA was able to assign each facility to the category that best applied to the
majority of its discharges. EPA reviewed information available about each facility
to determine which point source category applied to the facility's operations.
• Pollutant-Level Point Source Category Assignment. Many facilities have
operations subject to more than one point source category. For most of these
facilities, EPA cannot divide the pollutant discharges among the applicable point
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Section 3—Methodology, Data Sources, and Limitations
source categories. Two exceptions where EPA was able to assign wastewater
discharges of certain chemicals to the appropriate point source category are listed
below:
— Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF)/Pesticide
Chemicals. EPA removed all pesticide discharges from the OCPSF
Category and included them as discharges from the Pesticide Chemicals
Category.
— Metal Products and Machinery (MP&M)/Metal Finishing. EPA used the
methodologies described in Section 4 of the 2009 SLA Report (U.S. EPA,
2009) to apportion pollutant loads between the MP&M and Metal
Finishing Categories.
3.3.2 DMRLoads2009: Internal Monitoring
This subsection describes database corrections to identify internal monitoring points in
DMRLoads2009. As discussed in Sections 3.2.1.3 and 3.2.3.2 of the 2009 SLA Report (U.S.
EPA, 2009), the 2009 DMR Loadings Tool calculated loads only for monitoring locations that
are labeled as effluent. The effluent monitoring locations in the 2009 DMR Loadings Tool are:
• MLOC 1 - Effluent net discharge;
• MLOC 2 - Effluent gross discharge;
• MLOC A - After disinfection;
• MLOC B - Before disinfection; and
• MLOC SC - See comments.
As a result, the DMR Loadings Tool excludes discharges for internal monitoring
locations such as intake water, influent to treatment, and intermediate points in the wastewater
treatment system. However, during previous category reviews and detailed studies, EPA
identified instances of double-counting that resulted from including certain internal monitoring
points in the loads database. For example, a facility monitors for Pollutant A at the effluent from
its wastewater treatment system (internal Outfall 101). Outfall 101 wastewater is later combined
with other plant discharges at final Outfall 001 and is discharged to a receiving stream. The
facility also monitors for Pollutant A at final Outfall 001. Both outfalls are effluent monitoring
points identified as MLOC 1 or MLOC 2; however, Outfall 101 is upstream of the final outfall.
Calculating loads for Pollutant A at both the internal and final outfalls double-counting Pollutant
A discharges. EPA identified instances where pollutant discharges are reported for multiple
monitoring locations along the same discharge line and eliminated the discharges for the
upstream monitoring locations. EPA made these corrections to the 2009 data in the DMR
Loadings Tool. A complete list of these corrections made in the DMR Loadings Tool can be
found in Table B-2 of Appendix B of this report.
3.3.3 DMRLoads2009: Intermittent Discharges
This section describes database corrections made for intermittent discharges in
DMRLoads2009. As described in Sections 3.2.1.3 and 3.2.3.2 of the 2009 SLA Report (U.S.
EPA, 2009), the DMR Loadings Tool assumes that all discharges in PCS and ICIS-NPDES are
continuous (24 hours per day for all days in the monitoring period). During previous annual
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Section 3—Methodology, Data Sources, and Limitations
reviews, EPA identified facility discharges that are intermittent and therefore are overestimated
by the DMR Loadings Tool. EPA calculated annual loads for these discharges based on
information obtained from the facility on the frequency and duration of wastewater discharges.
EPA made these corrections in the 2009 data in the DMR Loadings Tool.
3.3.4 DMRLoads2009: Excluded Pollutant Parameters
This section describes database corrections made to exclude selected water quality
parameters and flow from the annual load calculation in 2009 DMR Loadings Tool. As described
in Sections 3.2.1.3 and 3.2.3.2 of the 2009 SLA Report (U.S. EPA, 2009), facilities report
pollutant mass quantities, pollutant concentrations, and wastewater flow rates to PCS and ICIS-
NPDES using a variety of units. EPA's PCS CNVRT program and the ICIS-NPDES Convert
Module convert the discharges into standard units of kilograms per day (kg/day) for mass
quantities, milligrams per liter (mg/L) for concentrations, and millions of gallons per day (MGD)
for flow rates. However, some parameters are reported in units that cannot be converted into
kg/day or mg/L (e.g., temperature, pH, fecal coliform, whole effluent toxicity). EPA excluded
these parameters from the toxicity rankings analysis. Table B-3 of Appendix B lists the excluded
parameters.
3.3.5 DMRLoads2009: Pollutant Corrections
This section describes database changes made to discharges of specific pollutants
reported to the DMR for EPA's 2011 toxicity rankings analysis in the 2009 DMR Loadings Tool.
During the reasonableness checks of the PCS CNVRT output, EPA identified unusually
high mercury concentrations reported to PCS by facilities located in Ohio in the PCS CNVRT
output. These facilities reported mercury discharges using PRAM 50092 (Mercury Total Low
Level). The PRAM 50092 concentrations in the 2004 CNVRT output ranged from 0.2 to 673
mg/L and from 2 pg/L to 4.1 mg/L in the 2009 CNVRT output. EPA contacted the Ohio
Environmental Protection Agency (Ohio EPA) to determine the correct reporting units for
PRAM 50092 (Stuhlfauth, 2007). An Ohio EPA representative explained that Ohio EPA started
requiring low level mercury analyses in 2002. At that time, some facilities had limits in
micrograms per liter ((J,g/L). Currently, all of the limits are in nanograms per liter (ng/L).
As a result of this contact, EPA concluded that the units for the PRAM 50092
concentrations for the 2004 PCS data should be ng/L, not mg/L. Based on the 2009 distribution
of Ohio mercury concentrations, EPA concluded that the error for the 2004 data persisted in
2009. Therefore, EPA corrected the concentrations by dividing all concentrations for PRAM
50092 reported by facilities in Ohio in the DMR Pollutant Loadings Tool by one million.
3.3.6 DMRLoads2009: Data Quality Review
EPA evaluated the quality of the PCS and ICIS-NPDES DMR data for use in
DMRLoads2009 as part of the 2011 toxicity rankings analysis. This evaluation considered data
completeness, accuracy, reasonableness, and comparability. The Quality Assurance Project Plan
for the 2009 Annual Screening-Level Analysis of TRI and PCS Industrial Category Discharge
Data describe the quality objectives in more detail (ERG, 2009). EPA conducted quality reviews
for three stages of the development of DMRLoads2009: 1) PCS CNVRT and ICIS-NPDES
3-12
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Section 3—Methodology, Data Sources, and Limitations
Convert Module outputs; 2) the 2009 DMR Loadings Tool output; and 3) DMRLoads2009
results. The following discussion provides an overview of the quality review steps for each stage:
• PCS CNVRT and ICIS-NPDES Convert Module outputs. EPA conducted an
initial quality review of the extracted PCS CNVRT and ICIS-NPDES DMR data
to evaluate its completeness, reasonableness, and comparability. For
completeness, EPA compared the number of major facilities and the universe of
SIC codes in the 2009 DMR data to the DMR data in 2008.
EPA reviewed the DMR data for reasonableness to identify any data quality
issues, such as misreported units that the PCS CNVRT and ICIS-NPDES Convert
Module did not correct. EPA identified several wastewater flows that exceeded
the reasonable range. EPA reviewed these flows and developed the flow
correction function for the PCS CNVRT and ICIS-NPDES Convert Module
(described in Section 3.2.3 of the 2009 SLA Report (U.S. EPA, 2009)). This
function is designed to identify data entry errors for flows greater than 1,000
MGD. The PCS CNVRT and ICIS-NPDES Convert Module corrects all flows
exceeding 5,000 MGD and applies more conservative criteria to correct flows
from 1,000 to 5,000 MGD. The PCS CNVRT and ICIS-NPDES Convert Module
made the following corrections to the PCS and ICIS-NPDES wastewater flows:
— 2,230 corrections based on month-to-month variations;
— 1,281 corrections based on comparing flows to design flows; and
— 1,186 corrections based on assuming that flows exceeding 5,000 MGD are
reported in units of GPD.
• Load Calculator routines. EPA's quality review for the Load Calculator routines
included accuracy checks for database queries on the 2009 data in the DMR
Loadings Tool. EPA reviewed the programming code used to develop each query
to verify the logic and verified that the number of records in the output table
equaled the number of records in intermediate queries to ensure that no data were
missing and that there were no duplicate data. In addition, EPA performed hand
calculations to verify the accuracy of the Load Calculator module outputs during
reviews of facility discharges for DMRLoads2009 results.
• DMRLoads2009 results. EPA's quality review of the DMRLoads2009 results
included the following:
— Completeness checks. EPA compared counts of dischargers in
DMRLoads2009 to DMRLoads2008 to confirm the completeness of the
database. There were 2,036 major discharging facilities that reported a
load to DMRLoads2008 and 1,944 major discharging facilities that
reported a load to DMRLoads2009. There were 14,888 minor discharging
facilities that reported a load to DMRLoads2008 and 15,565 minor
discharging facilities that reported a load to DMRLoads2009.
— Accuracy of facility discharges. EPA reviewed the accuracy of facilities'
discharges that had the greatest impact on total category loads and
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Section 3—Methodology, Data Sources, and Limitations
category rankings to identify possible calculation errors. EPA reviewed
monitoring period data in PCS and ICIS-NPDES, measurement data
available on EPA's Envirofacts web page, and information from each
facility's NPDES permit and permit fact sheet. In some cases, EPA
contacted facilities to verify the measurements in their DMR. Section
3.3.7 describes EPA's review of facility discharges in more detail.
Accuracy of category discharges. EPA reviewed the accuracy of category
discharges by verifying that pollutant discharges in PCS and ICIS-NPDES
were assigned to the appropriate point source category. EPA used
engineering judgment to determine if the pollutant discharge was
reasonably associated with the point source category. Section 3.3.1
discusses facility-level and pollutant-level category assignments.
Accuracy of database queries. EPA's quality review for the development
of DMRLoads2009 included accuracy checks for database queries in
DMRLoadsAnalysis20092 and DMRLoads2009. Documentation of
accuracy checks is provided in a QC table in each Microsoft Access™
database.
Reasonableness of pollutant loads. EPA reviewed the DMR Loadings
Tool's 2009 output (i.e., the calculated kg/year for each pollutant at each
discharge pipe and monitoring location) for those pollutant discharges
with the highest toxic-weighted loads (e.g., dioxins, polychlorinated
biphenyls (PCBs), and mercury). To identify possible errors in recording
units of measure, EPA identified calculated discharges that were orders of
magnitude higher than previous years' discharges or discharges from other
facilities within the same category. EPA reviewed quantities or
concentrations and flows that the DMR Loadings Tool database used to
calculate the annual discharge. EPA compared these measurements with
measurements available on EPA's Envirofacts web page. If the
measurements were similar, then EPA concluded that the output was
acceptable. If the data did not match between the databases and
Envirofacts, EPA corrected the data to match Envirofacts. When EPA was
unsure what the correct data were, EPA contacted the facility or permitting
authority for more information (see Section 3.3.7).
Reasonableness of facility loads. EPA identified facility discharges with
the highest TWPE. EPA identified facilities for review whose pollutant
discharges accounted for more than 95 percent of the TWPE for their point
source category. EPA compared 2009 DMR data to other available
information, such as information from EPA's Envirofacts web page, and
the facility's NPDES permit and permit fact sheet. If the data did not
match between the database and Envirofacts, EPA corrected the data to
match Envirofacts. When EPA was unsure what the correct data were,
2 DMRLoadsAnaysis2009 is a database used to evaluate the impacts of calculation assumptions and corrects SIC
Code classifications for certain facilities and certain discharges (i.e., OCSPF and Pesticide discharges). See Section
3.2 of the 2009 SLA Report for further information (U.S. EPA, 2009).
3-14
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Section 3—Methodology, Data Sources, and Limitations
EPA contacted the facility or permitting authority for more information
(see Section 3.3.7).
— Comparability. EPA compared DMRLoads2009 to DMRLoads2008 to
identify pollutant discharges or wastewater flows that differed more than
the year-to-year variation of other chemicals and facilities. EPA used this
comparison to determine if quantity, concentration, or flow corrections
were needed for facility discharges with the highest TWPE. If the
comparison was unavailable (e.g., the pollutant was not previously
reported) EPA contacted the facility or permitting authority (see Section
3.3.7).
3.3.7 DMRLoads2009: Facility Reviews
EPA reviewed the accuracy of facility discharges that had the greatest impact on total
category loads and category rankings in DMRLoads2009. EPA reviewed facilities with the
highest toxic-weighted discharges of individual pollutant parameters. For the identified facilities,
EPA used the following steps to review the accuracy of the loads calculated from PCS and ICIS-
NPDES data:
1. Reviewed database corrections for DMRLoads2008, DMRLoads2007,
PCSLoads2004, PCSLoads2002, and PCSLoads2000 to determine whether
corrections made during previous reviews should apply to the 2009 DMR
discharges.
2. Reviewed 2009 DMR data, hand-calculated annual pollutant loads, and compared
the results to loads calculated by the DMR Loading Tool and stored in
DMRLoads2009.
3. Reviewed PCS and ICIS-NPDES pipe description information available in PCS,
EPA's on-line Envirofacts data system, ICIS-NPDES supporting tables, or from
the facility's NPDES permit and permit fact sheet to identify monitored pollutant
discharges that are:
— Intermittent (e.g., tidal, seasonal, or occur after a storm event);
— Internal monitoring locations from which wastewater is combined with
other waste streams and monitored again, resulting in double-counting
loads; and
— Not representative of category discharges (e.g., stormwater runoff from
nonprocess areas, noncontact cooling water, or wastewater related to
operations in another point source category).
Table 3-2 presents EPA's facility review and corrections made to the DMRLoads2009
database.
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Section 3—Methodology, Data Sources, and Limitations
Table 3-2. Summary of DMRLoads2009 Facility Review
locution
Poinl Source
CsilcKon
I'olliiliiiiKs) in
Question
Uc\ ic\\ l-'indin^s
Art ion 1 iikcn/Diiliihiiso
(oiicclion
Ahlstrom
Cogeneration Facility
Windsor
Locks, CT
Pulp & Paper
Chlorine
Outfall 006 2009 Oct and Nov, and
outfall 008 2009 Jan through Sept
chlorine concentrations are 1,000 times
higher than other monthly concentrations.
Outfall 006 and 008 specified chlorine
concentrations were in mg/L in the DMR
Loadings Tool, while Envirofacts
concentrations are in ug/L.
Revise specified 2009 chlorine
concentrations for outfalls 006
and 008 by dividing by 1,000.
Angola Wire Products
Inc.
Angola, IN
Metal Finishing
Copper
Outfall 001 2009 flows are greater than
2,000 MGD; however, the facility is a
minor discharger.
Revise 2009 flows for outfall
001 by dividing by 1,000,000.
Anniston Army Depot
Anniston,
AL
Metal Finishing
Copper
Outfall 020 Dec 2009 iron, copper, and
TSS concentrations are 100 times higher
than other monthly concentrations.
Revise Dec 2009 iron, copper,
and TSS concentrations for
outfall 020 by dividing by
100.
Barton Lexa Water
Association
Poplar
Grove, AR
Drinking Water
Chlorine
Facility contact identified that the 2009
flow values for outfall 101 should be
reported in GPD, not MGD (Carruth,
2011).
Revise 2009 flow values for
outfall 101 by dividing by
1,000,000.
BASF-Wyandotte
Wyandotte,
MI
OCPSF
Mercury
Outfall 001 2009 Jan, Mar, Jun, Jul, and
Aug 2009 mercury concentrations are in
the DMR Loadings Tool as mg/L, while
the concentrations in Envirofacts are in
ng/L.
Revise Jan, Mar, Jun, Jul, and
Aug 2009 mercury
concentrations for outfall 001
by dividing by 1,000,000.
Bass Point Resort
Condos
Morgan
County, MO
Amusement &
Recreation Services
Chlorine
Outfall 001 2009 flows are greater than
2,000 MGD; however, the facility is a
minor discharger.
Revise 2009 flows for outfall
001 by dividing by 1,000,000.
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Section 3—Methodology, Data Sources, and Limitations
Table 3-2. Summary of DMRLoads2009 Facility Review
l.oi'iilion
Poinl Source
CsilcKon
I'olliiliiiiKs) in
Question
Uc\ ic'\\ l-'inriin^s
Art ion 1 iikcn/Diiliihiiso
( onvrtion
Bayer CropSciences
Institute
Institute, WV
Pesticide Chemicals
Carbaryl
Outfall 005 Sept 2009 carbaryl quantity is
1,000 times higher than all other
quantities. In 2010, facility contact
identified that the 2008 carbaryl
concentrations and quantities were below
the detection limit at 0.003 mg/L and 2
lbs/day. 2009 concentrations and
quantities are below the BDL values
indicated by the facility contact (Smith,
2010).
Revise Sept 2009 quantity by
dividing by 1,000. Add BDL
indicators to all 2009 carbaryl
concentrations and quantities
for outfall 005.
Berwin Business
Center
Festus, MO
Real Estate
Chlorine
Outfall 001 Oct, Nov, and Dec 2009
flows are 1,000,000 times higher than
other monthly flows.
Revised Oct, Nov, and Dec
2009 for outfall 001 flow by
dividing by 1,000,000.
Bridal Cave
Devlpmnt WWTF
Camdenton,
MO
Miscellaneous Retail
Chlorine
Outfall 001 2009 flows are 1,000,000
times higher than flows reported in 2008.
Revise 2009 flow for outfall
001 by dividing by 1,000,000.
Brunswick Cellulose,
Inc.
Brunswick,
GA
Pulp & Paper
2,3,7,8-TCDD
Facility contact confirmed that the 2009
TCDD concentration for outfall 001 was
below the detection limit. (Schwartz,
2011a).
Revise Jun 2009 TCDD
concentration for outfall 001
by adding a BDL indicator.
Bulk Plant Inc
Flemingsbrg #39
Fleming
County, KY
Petroleum Refining
Benzene
Facility contact identified 2009 flow as
GPD, not MGD, for Outfall 001. Facility
contact verified maximum flow values
and indicated that the average flow values
should be the same as the maximum
(Becker, 2011).
Revise 2009 flow for outfall
001 by dividing the maximum
flows by 1,000,000 and
making the average and
maximum flow values the
same.
Bulk Plant Inc
Grayson #266
Carter
County, KY
Petroleum Refining
Benzene
Facility contact identified 2009 flow as
GPD, not MGD, for Outfall 001. Facility
contact verified maximum flow values
and indicated that the average flow values
should be the same as the maximum
(Becker, 2011).
Revise 2009 flow for outfall
001 by dividing the maximum
flows by 1,000,000 and
making the average and
maximum flow values the
same.
Butler County
Landfill
Poplar Bluff,
MO
Landfills
Lead
Facility contact identified that the 2009
lead concentrations for Outfall 001 and
002 should be reported as ug/L, not mg/L
(Cozad, 2011).
Revise 2009 lead
concentrations for outfalls 001
and 002 by dividing by 1,000.
3-17
-------
Section 3—Methodology, Data Sources, and Limitations
Table 3-2. Summary of DMRLoads2009 Facility Review
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C&H Sugar
Crockett, CA
Sugar Processing
Methylmercury
Outfall 001 and 002 Oct 2009
methylmercury concentrations are
100,000 time higher than other monthly
concentrations.
Revise Oct 2009
methylmercury concentrations
for outfall 001 by dividing by
100,000.
Cascade Pacific Pulp
Halsey, OR
Pulp & Paper
2,3,7,8-TCDD
Facility contact identified that all 2009
TCDD quantities for outfall OOlare below
the detection limit (Schwartz, 201 la).
Revise 2009 TCDD quantities
for outfall 001 by adding BDL
indicators.
Charlotte Walters
Sweetwater,
AL
Automotive Dealers
& Service Stations
Lead
Outfall 001 2009 flows are greater than
2,000 MGD; however, the facility is a
minor discharger. Flows are 1,000,000
times higher than expected from a minor
discharger.
Revise 2009 flows for outfall
001 by dividing by 1,000,000.
Citizens Gas & Coke
Utility
Indianapolis,
IN
Oil & Gas
Benzo(a)pyrene
Dec 2009 benzo(a)pyrene concentrations
for outfalls 009, 013, 014, 017, and 019
are 1,000 times higher than all other
concentrations. Remaining 2009
concentrations of the correct magnitude
also are reported below the detection
limit.
Revise Dec 2009
benzo(a)pyrene concentrations
for the specified outfalls by
dividing by 1,000 and adding
a BDL indicators.
Claiborne Mill
Claiborne,
AL
Pulp & Paper
2,3,7,8-TCDD
Outfall 001 Jun 2009 TCDD
concentration reported in Envirofacts is
the same value as the Dec 2009
concentration; however, it is missing the
BDL indicator.
Revise June 2009 TCDD
concentration for outfall 001
by adding a BDL indicator.
Clean Harbors Baton
Rouge, LLC
Baton Rouge,
LA
CWT
Benzidine
Facility contact identified that the Dec
2009 benzidine concentration for outfall
001 is below the dectection limit (Clark,
2011).
Revise Dec 2009 benzidine
concentration for outfall 001
by adding a BDL indicator.
3-18
-------
Section 3—Methodology, Data Sources, and Limitations
Table 3-2. Summary of DMRLoads2009 Facility Review
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Crossett Harbor Port
Crossett, AR
Hotels & Other
Lodging
Mercury
Outfall 001 Sept 2009 mercury quantity
is 1,000,000 times higher than other
monthly quantities and Dec 2009 mercury
quantity is 1,000 times higher than all
other monthly quantities.
Revise Sept 2009 mercury
quantity by dividing by
1,000,000 and Dec 2009
mercury quantity by dividing
by 1,000.
Dana Transport Inc.
Nitro, WV
Trucking &
Warehousing
Mercury
Outfall 001 2009 mercury quantities in
the DMR Loadings Tool do not match the
quantity calculated using the
concentration and flow data in
Envirofacts. EPA used the concentration
and flow to calculate the correct quantity.
Revise 2009 mercury
quantities for outfall 001.
Doe Run, Fletcher
Mine/Ml
Viburnum,
MO
Ore Mining
Lead
Outfall 001 Nov and Dec 2009 lead
concentrations are 1,000 times higher
than other monthly concentrations.
Revise Nov and Dec 2009
lead concentrations for outfall
001 by dividing by 1,000.
Expo Water Park, Inc.
Tulsa, OK
Amusement &
Recreation Services
Chlorine
Outfall 001 2009 flows are greater than
2,000 MGD; however, the facility is a
minor discharger.
Revise 2009 flows for outfall
001 by dividing by 1,000,000.
Fisheries
Development
Corporation
Hagerman,
ID
CAAP
Copper
Facility contact identified that copper
concentrations should be zero for 2009
(Bogaard, 2011).
Revise 2009 copper
concentrations.
Freeman United Coal-
Industry
Industry, IL
Coal Mining
Manganese
Outfall 019 2009 flows are 1,000 times
higher than flow data in previous years.
Revise 2009 flow for outfall
019 by dividing by 1,000.
Holiday Motel
WWTF
Cleveland,
TX
Hotels & Other
Lodging
Chlorine
Outfall 001 Feb 2009 flow is 1,000,000
times higher than other months of data.
Revise Feb 2009 flow for
outfall 001 by dividing by
1,000,000.
Insulfoam
Mead, NE
Plastics Molding And
Forming
Chlorine
Outfall 001 2009 flows are 1,000,000
times higher than previous years of data.
Revise all 2009 flow values
for outfall 001 by dividing by
1,000,000.
Lost Canyon Lakes
Steedman,
MO
Hotels & Other
Lodging
Chlorine
Outfall 002 Jun 2009 flow is 100 times
higher than other months of data and Aug
and Nov 2009 flows are 1,000,000 times
higher than other months of data.
Revise Jun 2009 flow by
dividing by 100 and revise
Aug and Nov 2009 flow by
dividing by 1,000,000.
3-19
-------
Section 3—Methodology, Data Sources, and Limitations
Table 3-2. Summary of DMRLoads2009 Facility Review
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Maplesville Lumber
Mill
Maplesville,
AL
Timber Products
Processing
Iron
Outfall 008 Dec 2009 flow is 1,000 times
higher than other months of data.
Revise Dec 2009 flow for
outfall 008 by dividing by
1,000.
Marion Co Sanitary
Landfill
Marion
County, KY
Landfills
Iron
Outfall 001 and 002 2009 flows are 5,500
to 16,500 MGD; however, facility is a
minor discharger.
Revise 2009 flows for outfalls
001 and 002 by dividing by
1,000,000.
Matthews High
School
OH
Educational Services
Ammonia as N
Outfall 001 Feb, Mar, and Apr 2009
ammonia quantities and flows are
1,000,000 times higher than other months
of data.
Revise Feb, Mar, and Apr
2009 ammonia quantities and
flows for outfall 001 by
dividing by 1,000,000.
Monterey Coal
Company-Mine 2
Albers, IL
Coal Mining
Manganese
Outfall 001 2009 flows are in Envirofacts
as MGD. The 2010 flows in Envirofacts
are the same order magnitude but in
GPM.
Revise 2009 flows for outfall
001.
Mountain State
Carbon, LLC
Follansbee,
WV
Iron and Steel
Manufacturing
Aluminum
Outfall 005 2009 aluminum
concentrations, Jan through Jun, are
1,000 times higher than the remaining
2009 concentrations and more recent
(2010 data).
Revise Jan to Jun 2009
aluminum concentrations for
outfall 005 by dividing by
1,000.
Mueller Company
Albertville,
AL
Metal Molding and
Casting
Chlorine
Facility contact identified that the June
2009 chlorine concentration for outfall
015 should be 1.35 mg/L, not 135 mg/L
(Warren, 2011a).
Revise Jun 2009 chlorine
concentration.
Palm Coast WTP #3 -
Membrane C
FL
Drinking Water
Hydrogen
sulfide
Florida DEP verified the concentrations
and units (LB/1000 GA) for 2009
hydrogen sulfide data for outfall 001.
Facility contact also provided the
conversion calculation between mg/L and
LB/1000 GA (Sedano, 2011).
Revise 2009 hydrogen sulfide
concentrations for outfall 001.
Rayonier
Performance Fibers
Jesup, GA
Pulp & Paper
2,3,7,8-TCDD
Facility contact identified that the Mar
2009 TCDD concentration for outfall
0A0 is below the detection limit
(Schwartz, 2011a).
Revise Mar 2009 TCDD
concentration for outfall 0A0
by adding BDL indicator.
3-20
-------
Section 3—Methodology, Data Sources, and Limitations
Table 3-2. Summary of DMRLoads2009 Facility Review
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SC Dept
Corr/Wateree River
Sumter, SC
Justice, Public Order,
& Safety
Mercury
Facility contact identified that the 2009
mercury concentration units for outfall
001 should be ng/L not mg/L
(Stoudemire, 2011).
Revise 2009 mercury
concentrations for outfall 001
by dividing by 1,000,000.
Seapac of Idaho Inc
Hagerman,
ID
CAAP
Copper
Facility contact identified that the copper
concentrations are ug/L not mg/L for
outfall 001 (VanTassel, 2011).
Revise 2009 copper
concentrations by dividing by
1,000.
Smurfit-Stone
Container
Florence, SC
Pulp & Paper
Sulfur
Facility contact verified the 2009 sulfide
concentrations and flows for outfall 001.
The sulfide discharges are due to the kraft
pulping process (O'Shaughnessy, 2011).
No action.
Solutia Inc
Anniston, AL
OCPSF
PCB-1242
Facility contact verified the 2009 PCB
concentrations and flows for outfall 012
(Warren, 2011b).
No action.
Special Metals Corp
New
Hartford, NY
Nonferrous Metals
Manufacturing
PCB-1254,
PCB-1248,
PCB-1241
Outfall 001 2009 PCB concentrations are
below the detection limit, but quantities
do not have BDL indicator. Jan to Jun
2009 PCB quantities are also 1,000 times
higher than others.
Revise 2009 PCB quantities
for outfall 001 by adding BDL
indicators where
concentrations are reported
below the detection limit and
dividing Jan to June 2009
PCB quantities by 1,000.
Sunny Acres II LLC
High Ridge,
MO
Real Estate
Chlorine
Outfall 001 2009 flows are 1,000,000
times higher than previous years of data.
Revise 2009 flows for outfall
001 by dividing by 1,000,000.
The Horny Toad
Lake Ozark,
MO
Food Services
Chlorine
Outfall 001 2009 flows are 1,000,000
times higher than previous years of data.
Revise 2009 flows for outfall
001 by dividing by 1,000,000.
Tiger Sunbelt
Industries
Atmore, AL
Inorganic Chemicals
Sulfur
Outfall 001 Dec 2009 average sulfur
concentration does not have a BDL
indicator, but is the same value as the
maximum concentration that has a BDL
indicator.
Revise Dec 2009 average
sulfur concentration for outfall
001 by adding a BDL
indicator.
3-21
-------
Section 3—Methodology, Data Sources, and Limitations
Table 3-2. Summary of DMRLoads2009 Facility Review
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White mountain
Apache Tribe
Greer, AZ
Hotels & Other
Lodging
Chlorine
Outfall 001 flows are greater than 350
MGD; however, facility is a minor
discharger.
Revise June 2009 flow by
dividing by 100,000, Oct 2009
flow by dividing by 100, Dec
2009 flow by dividing by
1,000.
Windsong MHP
WWTF
Gravois
Mills, MO
Real Estate
Chlorine
Outfall 001 2009 flows are 1,000,000
times higher than previous years of data.
Revise 2009 flows for outfall
001 by dividing by 1,000,000.
3-22
-------
Section 3—Methodology, Data Sources, and Limitations
3.4 Corrections to the TRIReleases2009 Database
EPA developed the TRIReleases2009 database as part of the 2011 Annual Reviews using
the methodology explained in the 2009 SLA Report (U.S. EPA, 2009) with the methodology
updates described in Section 4.2.2 in the 2010 TSD (U.S. EPA, 2011).
During previous toxicity rankings analyses, EPA identified numerous facility-specific
corrections for TRI data reported for calendar years 2002 through 2008. Several of these
corrections similarly apply to the 2009 TRI data. In addition, EPA reviewed the quality of the
2009 TRI data for facilities with discharges that have the greatest impact on total category loads
and category rankings. Table B-l in Appendix B of this report lists all corrections made to the
2009 TRI data.
3.4.1 TRIReleases2009: Categorization of Discharges
This section describes database corrections to categorization of facilities and pollutant
discharges in TRIReleases2009. Section 4 of the 2009 SLA Report describes the development of
the NAICS/Point Source Category Crosswalk, which EPA uses to link between facility NAICS
codes and categories with existing ELGs (U.S. EPA, 2009). Because most point source
categories are not defined by NAICS code, the relationship between NAICS code and point
source category is not a one-to-one correlation. A single NAICS code may include facilities in
more than one point source category, and associating an NAICS code with only one category
may be an oversimplification. Also, many facilities have operations subject to more than one
point source category. Further, facilities in some categories report a variety of NAICS codes that
do not correlate directly to a point source category, precluding identification by NAICS code
(e.g., Centralized Waste Treatment facilities). Section 5 of the 2009 SLA Report describes the
database changes, summarized below (U.S. EPA, 2009):
• Facility-Level Point Source Category Assignment. For some NAICS codes that
include facilities subject to guidelines from more than one point source category,
EPA was able to assign each facility to the category that best applied to the
majority of its discharges. EPA reviewed information available about each facility
to determine which point source category applied to the facility's operations.
• Pollutant-Level Point Source Category Assignment. Many facilities have
operations subject to more than one point source category. For most of these
facilities, EPA cannot divide the pollutant discharges among the applicable point
source categories. Below are two exceptions where EPA was able to assign
wastewater discharges of certain chemicals to the appropriate point source
category:
— OCPSF/Pesticide Chemicals. EPA removed all pesticide discharges from
the OCPSF Category and included them as discharges from the Pesticide
Chemicals Category.
— MP&M/Metal Finishing. EPA used the methodologies described in
Section 4 of the 2009 SLA Report to apportion pollutant loads between the
MP&M and Metal Finishing Categories.
3-23
-------
Section 3—Methodology, Data Sources, and Limitations
• Categories Not Identified by NAICS Code (e.g., Centralized Waste Treatment,
Waste Combustor, and Landfills). The NAICS/Point Source Category Crosswalk
does not assign any NAICS codes to the Centralized Waste Treatment (CWT)
Point Source Category (40 CFR Part 437), Waste Combustor Point Source
Category (30 CFR Part 444), or Landfills Category (40 CFR Part 445).
Furthermore, the applicability of these three regulations is not defined by NAICS
codes and no NAICS code properly describes the CWT, waste combustor, or
landfill services. Currently, EPA assigns all facilities reporting NAICS code
562213 (Solid Waste Combustors and Incinerators) as part of the Waste
Combustor Category. The remaining facilities, with NAICS codes 562211
(Hazardous Waste Treatment and Disposal) and 562219 (Other Nonhazardous
Waste Treatment and Disposal), are included in all three categories, which over
estimates the category loads. During previous annual reviews, EPA has identified
certain facilities that should be categorized as a CWT, waste combustor, or
landfill. EPA assigned these facilities to the correct industrial category. As
facilities continue to be reviewed due to high TWPE, EPA classifies them into the
correct industrial category based on facility operations.
3.4.2 TRIReleases2009: Pollutant Corrections
This section describes database corrections made to discharges of specific pollutants
reported to the TRI for EPA's 2011 toxicity rankings analysis in the TRIReleases2009 database.
• Metal Compounds. For TRI reporting, facilities may be required to report
discharges of a metal (e.g., zinc) and its compounds (e.g., zinc compounds) on a
single reporting form. Because the release quantity for the metal compound
reporting is based on the mass of the parent metal, EPA uses the parent metal
TWF to calculate TWPE for the metal and metal compound discharges. For
ranking purposes, EPA combined the TWPEs for the metal and metal compounds
(i.e., TWPE reported for "zinc and zinc compounds"). For more details on this
correction, see Section 3.4.4 of the 2009 SLA Report (U.S. EPA, 2009).
• Sodium Nitrite. For TRI reporting, sodium nitrite release quantities are reported as
the mass of the sodium nitrite. Sodium nitrite is an ionic salt that will fully
dissociate into nitrite and sodium ions in aqueous solutions. In addition, the nitrite
ions are unstable in water and will oxidize to nitrate. Therefore, EPA converted
the pounds of TRI-reported sodium nitrite discharges to pounds of nitrogen in the
discharge and used the TWF for "nitrate as N" (0.0032) to calculate TWPE for
sodium nitrite. In addition, EPA also used the POTW removal for nitrate to
account for the removal of sodium nitrite in POTWs.
• Phosphorus (Yellow or White). Yellow and white phosphorus, both allotropes of
elemental phosphorus, are hazardous chemicals that spontaneously ignite in air.
During the 2006 toxicity rankings analysis, EPA determined that facilities were
incorrectly reporting discharges of total phosphorus (i.e., the phosphorus portion
of phosphorus-containing compounds) as phosphorus (yellow or white) (U.S.
EPA, 2006a). Therefore, EPA deleted all phosphorus (yellow or white) discharges
reported to TRI for the 2011 toxicity rankings analysis.
3-24
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Section 3—Methodology, Data Sources, and Limitations
3.4.3 TRIReleases2009: Data Quality Review
EPA evaluated the quality of TRI data for use in the 2011 toxicity rankings analysis and
prioritization of loadings of toxic and nonconventional pollutants discharged by industrial
categories based on completeness, accuracy, reasonableness, and comparability. The Quality
Assurance Project Plan for the 2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and
PCS Industrial Category Discharge Data describes the quality objectives in more detail (ERG,
2009). The following discussion provides an overview of the quality review steps:
• Completeness Checks. EPA compared counts of facilities in TRIReleases2009 to
TRIReleases2008, TRIReleases2007, TRIReleases2005, TRIReleases2004,
TRIReleases2003, TRIReleases2020, and TRIReleases2000 to describe the
completeness of the database. The comparison showed that for 86 percent of the
NAICS code groupings, the number of facilities reporting wastewater discharges
changed by less than 25 percent from 2008 to 2009. EPA also determined that
most NAICS codes exhibiting a large percentage change did so because only a
few facilities in these NAIC codes reported discharges (e.g., a change from one
facility to three facilities is equivalent to a 200 percent increase).
• Accuracy of Facility Discharges. EPA reviewed the accuracy of facilities'
discharges that had the greatest impact on total category loads and category
rankings. EPA identified facilities for review whose pollutant discharges
accounted for more than 95 percent of the TWPE for their point source category.
EPA compared 2009 TRI data to other available information, such as PCS and
ICIS-NPDES, information from EPA's Envirofacts web page, the facilities'
NPDES permits and permit fact sheets, and discussion with facility contacts.
• Accuracy of Category Discharges. EPA reviewed the accuracy of category
discharges by verifying that pollutant discharges in TRI were assigned to the
appropriate point source category. EPA used engineering judgment to determine
if pollutant discharges were reasonably associated with the point source category.
• Accuracy of Database Queries. EPA's quality review for the development of
TRIReleases2009 included accuracy checks for database queries in
TRICalculations20093 and TRIReleases2009. Documentation of accuracy checks
is provided in a QC table in each Microsoft Access™ database.
• Comparability. EPA compared TRIReleases2009 to TRIReleases2008,
TRIReleases2007, TRIReleases2005, TRIReleases2004, TRIReleases2003,
TRIReleases2020, and TRIReleases2000 to identify pollutant discharges that
differ more than the year-to-year variation of other chemicals and facilities. From
the comparison, EPA determined that 63 percent of the pollutants discharged in
both 2009 and 2008 had a change of less than 50 percent in the quantity
discharged. EPA also determined that most of the pollutants with a large
3 TRICalculations2009 is a database EPA created to analyze raw TRI data. See Section 2.4 of the 2009 SLA Report
for more detailed information (U.S. EPA, 2009).
3-25
-------
Section 3—Methodology, Data Sources, and Limitations
percentage change reflected initial discharges of small quantities. In addition,
most of these pollutant discharges resulted in small TWPEs.
3.4.4 TRIReleases2009: Facility Reviews
Table 3-3 presents EPA's TRI facility review and corrections made to the
TRIReleases2009 database. EPA reviewed the accuracy of calculated discharges from facilities
with discharges that have the greatest impact on total category loads and category rankings. EPA
used the following criteria to select facilities for review:
• Facilities with the highest toxic-weighted discharges of all facilities reporting to
TRI for reporting year 2009;
• Facilities with the highest toxic-weighted discharges of individual chemicals that
contribute the majority of the toxic-weighted discharges for all categories; and
• Facilities with the highest toxic-weighted discharges from categories that
contribute the majority of the toxic-weighted discharges for all categories.
For the identified facilities, EPA used the following steps to review the accuracy of the
loads calculated from TRI data.
1. Review database corrections for TRIReleases200S, TRIReleases2007,
TRIReleases2005, TRIReleases2004, TRIReleases2003, TRIReleases2002, and
TRIReleases2000 to determine whether corrections were made during previous
reviews and evaluate whether these corrections should be applied to
TRIReleases2009.
2. Review discharges reported to TRI for other reporting years (i.e., 2000, 2002,
2003, 2004, 2005, 2007 and 2008) and compare to discharges reported to TRI for
reporting year 2009.
3. Review 2009 DMR data in PCS and ICIS-NPDES, if available, to hand-calculate
annual pollutant loads and compare to discharges reported to TRI for reporting
year 2009.
4. Contact the facility to verify whether the pollutant discharges are reported
correctly.
3-26
-------
Section 3—Methodology, Data Sources, and Limitations
Table 3-3. Summary of TRIReleases2009 Facility Review
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Cahaba Pressure
Treated Forest
Products Inc
Brierfield, AL
Timber Products
Processing
Dioxin Compounds
Facility did not provide a
water congener distribution
in 2009.
Revise dioxin distribution
based on the reported water
discharges for all 17
congeners.
International Paper
Pensacola Mill
Cantonment, FL
Pulp, Paper, and
Paperboard
Dioxin Compounds
Facility did not recognize the
dioxin distribution
numbering change for the
2008 reporting period.
Dioxin distribution reported
in 2009 is similar to 2008
(using reporting years'
numbering scheme).
Revise dioxin distribution.
Sasol North America
Inc Lake Charles
Chemical Complex
Westlake, LA
OCPSF
Dioxin Compounds
Facility contact provided
dioxin compound sampling
data. Facility contact stated
that distribution and load
were calculated using half
the detection limit for values
that were non-detect (Hayes,
2011).
Revise dioxin load (LBY)
from 0.0009 to 0.0006, and
revise the dioxin distribution.
Suncor Energy
Commerce City
Refinery
Commerce City, CO
Petroleum Refining
Dioxin Compounds
Facility contact provided
dioxin compound sampling
data. Facility contact stated
that distribution was
calculated using half the
detection limit for values
that were non-detect
(Congram, 2011).
Revise dioxin distribution.
Charter Steel
Risingsun
Risingsun, OH
Iron and Steel
Zinc and Zinc
Compounds
Facility contact provided
zinc sampling data and the
average 2009 flow for the
direct and indirect outfalls.
EPA identified a conversion
error in the calculations
(Bukach, 2011).
Revise zinc load (LBY) from
4,570 to 4.57 for the direct
discharge and 2,100,759 to
2,100 for the indirect
discharge.
3-27
-------
Section 3—Methodology, Data Sources, and Limitations
Table 3-3. Summary of TRIReleases2009 Facility Review
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Carbon, LLC
Follansbee, WV
Iron and Steel
PACs
Facility contact provided
PACs sampling data. The
monitoring results provide a
distribution for the PAC
compounds to create a
facility-specific TWF
(Smith, 2011).
Revise PACs annual load
(LBY) from 360 to 185.
Calculate TWPE using
facility-specific TWF.
Dupont Chambers
Works
Deepwater, NJ
OCPSF
PACs and PCBs
EPA compared the 2009
PACs load with 2009 DMR
data to determine which
PAC compounds were being
discharged from the facility.
The 2009 DMR data
confirmed that only one
PAC was detected. Facility
contact also stated that only
one PCB (PCB-1242) was
detected in sampling data
(Northey, 2011).
Change PACs load (LBY)
from 136 to 63.83 and PCBs
load (LBY) from 0.7 to 0.18.
Calculate TWPE using
facility-specific TWF.
Graftech International
Holdings Inc.
Columbia, TN
Carbon Black
Manufacturing
PACs
Facility contact provided
PACs sampling data during
the 2010 Annual Reviews.
The monitoring results
provide a distribution for the
PAC compounds to create a
facility-specific TWF
(Aslinger, 2010).
Calculate TWPE using
facility-specific TWF.
Abitibibowater Inc.
Coosa Pines
Operations
Coosa Pines, AL
Pulp, Paper, and
Paperboard
Dioxin Compounds
Facility contact confirmed
that the pounds released
were based on half the
detection limit and that
dioxin was not detected at
the facility (Schwartz,
2011b).
Revise dioxin load to zero.
3-28
-------
Section 3—Methodology, Data Sources, and Limitations
Table 3-3. Summary of TRIReleases2009 Facility Review
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Bennettsville, SC
Pulp, Paper, and
Paperboard
Dioxin Compounds
Facility contact confirmed
that the pounds released
were based on half the
detection limit and that
dioxin was not detected at
the facility (Schwartz,
2011b)
Revise dioxin load to zero.
Longview Fibre
Paper & Packaging
Inc.
Longview, WA
Pulp, Paper, and
Paperboard
Dioxin Compounds
Facility contact confirmed
that the pounds released
were based on half the
detection limit and that
dioxin was not detected at
the facility (Schwartz,
2011b)
Revise dioxin load to zero.
WeylchemUS Inc.
Elgin, SC
Pesticide
Chemicals
Heptachlor
EPA compared the 2009
heptachlor discharges with
2009 DMR data to determine
that all 2009 heptachlor
concentrations were non-
detect.
Revise heptachlor load to
zero.
ExxonMobil Oil Corp
Joliet Refinery
Channahon, IL
Petroleum Refining
Hexachlorobenzene
Facility contact confirmed
that the pounds released
were based on half the
detection limit during the
2010 Annual Reviews
(Noga, 2010).
Revise hexchlorobenzene
load to zero.
John Morrell & Co.
Sioux Falls, SD
Meat and Poultry
Mercury and Mercury
Compounds
Facility contact confirmed
that the pounds released
were based on half the
detection limit during the
2010 Annual Reviews.
Facility contact confirmed
that all data were non-detect
(Draveland, 2010).
Revise mercury load to zero.
3-29
-------
Section 3—Methodology, Data Sources, and Limitations
Table 3-3. Summary of TRIReleases2009 Facility Review
l";icili(\ Niiim-
l-';icilil\ Locution
Point Source
Csili'Sion
I'olluliiiiKs) in
(JiicMiun
Uc\ ic\\ limlinus
Actions I'iikcn/Diiliihiisc
(oiicclion
ExxonMobil
Chemical Baton
Rouge Chemical
Plant
Baton Rouge, LA
OCPSF
PACs
Facility contact confirmed
that the pounds released
were based on half the
detection limit (Graham,
2011).
Revise PACs load to zero.
H. Kramer & Co.
Chicago, IL
Nonferrous Metals
Manufacturing
Phosphorus (Yellow
or White)
Elemental phosphorus is not
likely to be discharged by
facilities, and is likely
reported incorrectly.
Revise phosphorus (yellow or
white) load to zero.
Lima Refining Co.
Lima, OH
Petroleum Refining
Phosphorus (Yellow
or White)
Elemental phosphorus is not
likely to be discharged by
facilities, and is likely
reported incorrectly.
Revise phosphorus (yellow or
white) load to zero.
U.S. Army Pine Bluff
Arsenal
Pine Bluff, AR
National Security
& International
Affairs
Phosphorus (Yellow
or White)
Elemental phosphorus is not
likely to be discharged by
facilities, and is likely
reported incorrectly.
Revise phosphorus (yellow or
white) load to zero.
3-30
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Section 3—Methodology, Data Sources, and Limitations
3.4.5 Trends in TRI Data
EPA has identified a consistent decrease every year since 2002 in the total number of
facilities reporting to TRI. EPA also identified a consistent decrease in the number of facilities
reporting discharges to TRI from 2002 to 2007. However, the number of facilities reporting
discharges to TRI increased from 2007 to 2009. Table 3-4 illustrates the trends since 2002.
Table 3-4. Number of Facilities with Data in TRI for Reporting Years 2002 Through 2009
Reporting Year
Number of Facilities Reporting to
TRI
Number of Faeilities Reporting
Discharges to TRI
2002
24,379
8,291
2003
23,811
8,051
2004
23,675
7,930
2005
23,461
7,837
2006
22,880
7,506
2007
21,965
6,572
2008
21,694
6,891
2009
20,797
7,012
Source: TRIReleases2002; TRIReleases2003; TRIReleases2004; TRIReleases2005; TRIReleases2006;
TRIReleases2007; TRIReleases2008; and TRIReleases2009.
EPA does not have sufficient information to determine the cause of the decrease in the
number of facilities reporting to TRI over the past eight years. The aggregate number of
establishments4 reported to the U.S. Economic Census increased from 2002 to 2007. No changes
in reporting requirements occurred that can be attributed to the decrease. EPA will continue to
monitor this change in the future.
3.5 TRIReleases2009 Rankings and DMRLoads2009 Rankings
After incorporating the changes discussed in Sections 3.3 and 3.4, EPA generated the
final versions of the TRIReleases and DMRLoads databases used for the 2011 toxicity rankings
analysis: TRIReleases2009_v2 and l)MRLoads2009 v2. Tables C-l and C-2 in Appendix C
present the category rankings by TWPE from the TRIReleases2009_v2 and DMRLoads2009 v2
databases, respectively. The category rankings presented in these tables reflect all the corrections
made during the 2011 toxicity rankings analyses. Tables C-3 and C-4 in Appendix C present the
six-digit NAICS code rankings by TWPE from TRIReleases2009 v2 and the four-digit SIC code
rankings by TWPE from DMRLoads2009 v2, respectively. Tables C-5 and C-6 in Appendix C
present the chemical rankings by TWPE from TRIReleases2009 v2 and DMRLoads2009_v2,
respectively. For a summary of the final rankings and the findings of the 2011 Annual Reviews,
see Section 4 of the Preliminary 2012 Plan (U.S. EPA, 2013).
Also, in Table 8-1 of the Preliminary 2012 Plan, EPA summarizes its conclusions from
the annual reviews about each of the 57 point source categories discharges (U.S. EPA, 2013).
EPA uses the following codes to describe the results for each industrial category:
4 EPA reviewed only 3-digit NAICS code industry groups that were eligible for TRI reporting. Refer to Chapter 2 of
the 2009 SLA Report (EPA, 2009) for more detail.
3-31
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Section 3—Methodology, Data Sources, and Limitations
1. Effluent guidelines or pretreatment standards for this industrial category were
recently revised through an effluent guidelines rulemaking, or a rulemaking is
currently underway. Or, EPA recently completed a preliminary study or a
detailed study, and no further action is necessary at this time.
2. Revising the national effluent guidelines or pretreatment standards is not the best
tool for this industrial category because most of the toxic and non-conventional
pollutant discharges result from one or a few facilities in this industrial category.
EPA will consider assisting permitting authorities in identifying pollution control
and pollution prevention technologies for the development of technology-based
effluent limitations during the development of individual permits.
3. Not identified as a priority based on data available at this time (e.g., not among
industries that cumulatively compose 95% of discharges as measured in units of
TWPE).
4. EPA intends to start or continue a detailed study of this industry in its 2012
Annual Reviews to determine whether to identify the category for effluent
guidelines rulemaking.
5. EPA is continuing to assess pollutant discharges using screening-level data
because incomplete data are currently available to determine whether to conduct a
detailed study or identify the category for possible revision. Additional quality
review on the pollutant discharges, applicable facilities, and potential wastewater
treatment options needs to be reviewed prior to conducting a detailed study.
6. EPA is identifying this industry for a revision of an existing effluent guideline.
3.6 Methodology, Data Sources, and Limitations References
1. Aslinger, Julia. 2010. Notes from E-mail Communication between Julia Aslinger, Center
for Toxicology, and Environmental Health, LLC and Elizabeth Sabol, Eastern Research
Group, Inc. "RE: PAC Discharge Summary." (March 22). EPA-HQ-OW-2008-0517
DCN 07253.
2. Becker, Jory, 2011. Telephone and E-mail Communication between Jory Becker, KY
Department of Environmental Protection, and Kimberly Landick, Eastern Research
Group, Inc. "RE: 2009 DMR Flow and Units for Bulk Plant Flemingsburg and Grayson."
(February 24). EPA-HA-OW-2010-0824 DCN 07694.
3. Bogaard, Dirk. 2011. Notes from Telephone Conversation between Dirk Bogaard, Water
Quality Division of the Idaho Trout Company, and Kimberly Landick, Eastern Research
Group, Inc. "RE: 2009 DMR Copper Concentrations" (February 24). EPA-HA-OW-
2010-0824 DCN 07695.
4. Bukach, Tammy. 2011. Notes from Telephone and E-mail Communication between
Tammy Bukach, Charter Steel Rising Sun, and Kimberly Landick, Eastern Research
Group, Inc. "RE: 2009 TRI Zinc and Zinc Compounds Discharges." (January 21). EPA-
HA-OW-2010-0824 DCN 07696.
3-32
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Section 3—Methodology, Data Sources, and Limitations
5. Carruth, Darren. 2011. Notes from Telephone Conversation between Darren Carruth,
Barton Lexa Water Association, and Kimberly Landick, Eastern Research Group, Inc.
"RE: 2009 DMR Flow Values and Units." (January 21). EPA-HA-OW-2010-0824 DCN
07697.
6. Clark, Billy, 2011. Notes from Telephone Conversation between Billy Clark, Clean
Harbors Baton Rouge, and Kimberly Landick, Eastern Research Group, Inc. "RE: 2009
DMR Benzidine Discharges" (February 24). EPA-HA-OW-2010-0824 DCN 07698.
7. Congram, Tony. 2011. Notes from Telephone and E-mail Communication between Tony
Congram, Suncor Energy, and Elizabeth Sabol, Eastern Research Group, Inc. "RE: 2009
TRI Dioxin Releases and Distribution." (January 10). EPA-HA-OW-2010-0824 DCN
07699.
8. Cozad, Marietta. 2011. Notes from Telephone Communication Between Marietta Cozad,
MDNR, and Kimberly Landick and Elizabeth Sabol, Eastern Research Group, Inc., Re:
2009 DMR Lead Discharges for Butler County Landfill." (February 23). EPA-HQ-OW-
2010-0824. DCN 07531.
9. Draveland, Steve. 2010. Notes from Telephone Conversation between Steve Draveland,
John Morrell & Co. and Elizabeth Sabol, Eastern Research Group, Inc. "RE: Basis of
Mercury and Mercury Compound load reported to TRI in 2008." (February 12). EPA-
HQ-OW-2008-0517 DCN 07257.
10. ERG. 2009. Eastern Research Group, Inc. Revised Quality Assurance Project Plan for the
2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and PCS Industrial
Category Discharge Data. Chantilly, VA. (September). EPA-HQ-OW-2008-0517-0507.
11. Graham, George, 2011. Notes from Telephone and E-mail Communicatoin between
George Graham, Exxon Mobile Baton Rouge, and Elizabeth Sabol, Eastern Research
Group, Inc. "Re: 2009 TRIPAC Discharges." (January 10). EPA-HQ-OW-2010-0824
DCN 07693
12. Hayes, Michael. 2011. Telephone and E-mail Communication with Michael Hayes, Sasol
North America, Inc. and Kimberly Landick, Eastern Research Group, Inc. "RE: 2009 TRI
Dioxin Discharges." (January 28). EPA-HA-OW-2010-0824 DCN 07700.
13. O'Shaughnessy, Niall. 2011. Email Communication with Neil O'Shaughnessy,
RockTenn, and Elizabeth Sabol, Eastern Research Group, Inc. "Request for 2009 DMR
Data Clarification." (June 13). EPA-HQ-OW-2010-0824 DCN 07701.
14. Noga, Jeff. 2010. Notes from Telephone Conversation between Jeff Noga, ExxonMobil
Oil Corp., and Jessica Wolford, Eastern Research Group, Inc. RE: Joilet Refinery's
hexachlorobenze discharges in 2008. (February 15). EPA-HQ-OW-2008-0517 DCN
07303.
15. Northey, Scott. 2011. E-mail Communication with Scott Northey, Dupont Chambers
Works, and Elizabeth Sabol, Eastern Research Group, Inc. "RE: 2009 TRI Dupont PCB
Discharges." (February 28). EPA-HQ-OW-2010-0824 DCN 07702.
3-33
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Section 3—Methodology, Data Sources, and Limitations
16. Schwartz, Jerry, 201 la. E-mail Communication with Jerry Schwartz, AF&PA, and
William Swietlik, U.S. EPA, and Elizabeth Sabol, Eastern Research Group, Inc. "RE:
Request for 2009 DMR Data Clarification for Pulp and Paper Mills." (March 8). EPA-
HQ-OW-2010-0824 DCN 07703.
17. Schwartz, Jerry, 201 lb. E-mail Communication with Jerry Schwartz, AF&PA, and
William Swietlik, U.S. EPA, and Elizabeth Sabol, Eastern Research Group, Inc. "RE:
Request for 2009 TRI Data Clarification for Pulp and Paper Mills." (March 8). EPA-HQ-
OW-2010-0824 DCN 07686.
18. Sedano, Monica. 2011. Telephone and E-mail Communication with Monica Sedano,
Florida Department of Environmental Protection (FL DEP), and Elizabeth Sabol, Eastern
Research Group, Inc. "RE: Hydrogen Sulfide, Unionized Concentrations in DMR 2009."
(February 24). EPA-HQ-OW-2010-0824 DCN 07687.
19. Smith, Gordon. 2010. Telephone and E-mail Communication with Gordon Smith, Bayer
CropSciences, and Lauren Wingo, Eastern Research Group, Inc. "RE: Bayer
CropSciences' 2008 DMR Pesticide Discharges." (September 14). EPA-HQ-OW-2008-
0517 DCN 07268.
20. Smith, Patrick, 2011. Notes from Telephone and E-mail Communication with Patrick
Smith, Mountain State Carbon, and Kimberly Landick, Eastern Research Group, Inc.
"RE: 2009 TRIPAC Discharges". (January 21). EPA-HA-OW-2010-0824 DCN 07688.
21. Stoudemire, Dale. 2011. Notes from Telephone Conversation between Dale Stoudemire,
Bureau of Water, South Carolina DEHC, and Kimberly Landick, Eastern Research
Group, Inc. "RE: 2009 DMR Mercury Discharges." (February 24). EPA-HQ-OW-2010-
0824 DCN 07689.
22. Stuhlfauth, Gary. 2007. Notes from Telephone Conversation between Gary Stuhlfauth,
Ohio USEPA, and TJ Finseth, Eastern Research Group, Inc. "RE: Low level mercury
discharge requirements on NPDES permits in Ohio." (January 22). EPA-HQ-OW-2006-
0771-0487.
23. U.S. EPA. 2000. EPCRA Section 313 Guidance for Reporting Toxic Chemicals Within
the Dioxins and Dioxin-Like Compounds Category. EPA-745-B-00-021. Washington,
DC. (December). EPA-HQ-OW-2003-0074-1150.
24. U.S. EPA. 2005. Draft Toxic Weighting Factor Development in Support of CWA 304(m)
Planning Process. Washington, DC. June. EPA-HQ-OW-2004-0032-0857.
25. U.S. EPA. 2006a. Technical Support Document for the 2006 Effluent Guidelines
Program Plan. EPA-821-R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-
0032-2782.
26. U.S. EPA. 2006b. Toxic Weighting Factor Development in Support of CWA 304(m)
Planning Process. Washington, DC. (June). EPA-HQ-OW-2004-0032-1634.
3-34
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Section 3—Methodology, Data Sources, and Limitations
27. U.S. EPA. 2009. Technical Support Document for the Annual Review of Existing
Effluent Guidelines and Identification of Potential New Point Source Categories. EPA-
821-R-09-007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515.
28. U.S. EPA. 2010. U.S. EPA NPDES Permit Writers' Manual. Washington, DC.
(September). EPA-833-K-10-001. Available online at:
http ://cfpub. epa.gov/npdes/writermanual. cfm? program_id=45.
29. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA 820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
30. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
31. VanTassel, Tom. 2011. Notes from Telephone Conversation between Tom VanTassel,
Water Quality Division of the Idaho Department of Environmental Quality, and Kimberly
Landick, Eastern Research Group, Inc. "RE: 2009 DMR Copper Concentrations"
(February 24). EPA-HA-OW-2010-0824 DCN 07690.
32. Warren, Lee. 201 la. Notes from Telephone Conversation between Lee Warren, Water
Division of the Alabama Department of Environmental Management, and Kimberly
Landick, Eastern Research Group, Inc. "RE: 2009 DMR Chlorine Discharges at Mueller
Company" (February 24). EPA-HA-OW-2010-0824 DCN 07691.
33. Warren, Lee. 201 lb. Notes from Telephone and E-mail Communication between Lee
Warren, Water Division of the Alabama Department of Environmental Management, and
Kimberly Landick, Eastern Research Group, Inc. "RE: 2009 DMR Chlorine Discharges
at Solutia, Inc." (February 24). EPA-HA-OW-2010-0824 DCN 07692.
3-35
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Section 4—Aluminum Forming (40 CFR Part 467)
4. Aluminum Forming (40 CFR Part 467)
EPA selected the Aluminum Forming Category for preliminary review because it ranks
high, in terms of toxic-weighted pound equivalent (TWPE), in the point source category
rankings. This section summarizes the results of the 2011 Annual Reviews associated with the
Aluminum Forming Category, which focused on discharges of lead from one facility, because of
its high TWPE relative to the other facilities in the Aluminum Forming Category.
4.1 Aluminum Forming Category 2011 Toxicity Rankings Analysis
Table 4-1 compares the toxicity rankings analysis results for the Aluminum Forming
Category from the 2006 through 2011 Annual Reviews. The combined TWPE from discharges in
the discharge monitoring report (DMR) and Toxics Release Inventory (TRI) databases decreased
from discharge years 2002 to 2007 and increased slightly from 2007 to 2009. The estimated 2009
DMR TWPE accounts for approximately 85 percent of the combined 2009 DMR and TRI
TWPE, similar to previous years of data.
Table 4-1. Aluminum Forming Category TRI and DMR Discharges for the 2006 Through
2011 Toxicity Rankings Analyses
Year of Discharge
Year of Review
Aluminum Forming Category
TRI TWPE"
DMR TWPEb
Total TWPE
2002
2006
940,000°
61,500
l,000,000c
2004
2007
3,320
27,600
309,000
2005
2008
3,260
NA
NA
2007
2009
2,710
12,200
14,900
2008
2010
5,830
32,800
38,700
2009
2011
5,920
33,800
39,700
Sources: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 include only major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
0 In the 2006 Annual Reviews, EPA excluded the TWPE for TRI-reported discharges of PCBs from Kaiser
Aluminum & Chemical Corporation in Spokane, WA, because a) the estimated release reported to TRI
appeared to be an error, b) PCBs are no longer in commerce and therefore not regulated by ELGs, and c) the
PCB discharges did not represent the category as a whole. Removing the TRI TWPE, reduced the TRI TWPE
from 940,000 to 5,238 TWPE. As a result, the Aluminum Forming Category ranked 22nd, outside the categories
EPA prioritized for review. See the 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of Potential New Categories for
Effluent Limitations Guidelines and Standards (U.S. EPA, 2005).
NA: Not applicable. EPA did not evaluate DMR data for 2005.
4.2 Aluminum Forming Category Pollutants of Concern
EPA's review of the Aluminum Forming Category focused on the 2009 DMR discharges
because the 2009 DMR data dominate the category's combined TWPE. Table 4-2 lists the five
pollutants with the highest TWPE based on results from the 2011 and 2010 Annual Reviews
(DMRLoads2009_v2 and DMRLoads2008 v3, respectively).
4-1
-------
Section 4—Aluminum Forming (40 CFR Part 467)
Table 4-2. Aluminum Forming Category Top DMR Pollutants
Pollutant
2008 DMR Data"
2009 DMR Data'1
Rank
Number of Facilities
Reporting Pollutant
TWPE
Rank
Number of Facilities
Reporting Pollutant
TWPE
Lead
1
6
28,800
1
7
24,800
Cyanide
4
8
173
2
8
6,080
Aluminum
2
17
1,950
3
17
1,490
Fluoride
3
4
1,430
4
4
1,090
Zinc
Pollutant not reported in the top five 2008 DMR-
reported pollutants.
5
20
124
Polychlorinated biphenyls (PCBs)
5
1
93
Pollutant not reported in the top five 2009 DMR-
reported pollutants.
Aluminum Forming Category Total
NA
23b
32,800
NA
23b
33,800
Source: DMRLoads2008_v3 and DMRLoads2009_v2.
" DMR data include major and minor dischargers.
b Number of facilities reporting a TWPE of greater than zero.
NA: Not applicable.
4-2
-------
Section 4—Aluminum Forming (40 CFR Part 467)
Lead is the top DMR-reported pollutant in 2008 and 2009 contributing more than 73
percent of the 2009 DMR category TWPE. EPA did not investigate the other top pollutants as
part of the 2011 Annual Reviews because they represent less than 27 percent of the 2009 DMR
TWPE for the Aluminum Forming Category.
4.3 Aluminum Forming Category Lead Discharges in DMR
Table 4-3 presents the facilities that account for the lead discharges in the 2009 and 2008
DMR databases. The majority (98 percent) of the lead discharges in the 2009 DMR database
were from Alcan Rolled Products in Ravenswood, WV. The other five facilities account for the
remaining two percent. Accordingly, EPA's review of the lead discharges in DMR focused on
Alcan Rolled Products.
4-3
-------
Section 4—Aluminum Forming (40 CFR Part 467)
Table 4-3. Top Lead Discharging Facilities in 2008 and 2009 DMR Databases
Facility Name
Facility Location
2008"
2009"
Pounds of
Lead
Discharged
Lead TWPE
Percentage of
Aluminum
Forming
Category's 2008
DMR Lead
TWPE
Pounds of
Lead
Discharged
Lead
TWPE
Percentage of
Aluminum
Forming
Category's 2009
DMR Lead
TWPE
Alcan Rolled Products
Ravenswood, WV
12,800
28,700
>99%
10,800
24,300
98%
Remaining facilities reporting
lead discharges'3
NA
51
114
<1%
238
533
2%
Total
12,900
28,800
100%
11,100
24,800
100%
Source: DMRLoads2008_v3 and DMRLoads2009_v2.
" Major and minor dischargers.
b There are five remaining facilities that have lead discharges in the 2009 DMR database, which account for 2 percent of the category's lead DMR TWPE.
4-4
-------
Section 4—Aluminum Forming (40 CFR Part 467)
As part of the 2011 Annual Reviews, EPA contacted the West Virginia Department of
Environmental Protection (WV DEP) about the lead discharges from Alcan Rolled Products.
WV DEP stated that all lead measurements for 2009 found levels below detection. WV DEP
accordingly reported 5 micrograms per liter (|ig/L) in their DMRs, half of lead's minimum
detection limit of 10 |ig/L (Clevenger, 2011).5 Based on this data, EPA determined that all the
lead concentrations were below detectable levels in 2009. As described in Section 3, EPA zeroes
the load when all concentrations of a specific pollutant are BDL for the year. By zeroing the lead
discharge for Alcan Rolled Products, the total DMR TWPE decreases from 33,800 to 9,530.
4.4 Aluminum Forming Category Conclusions
The estimated toxicity of the Aluminum Forming Category discharges results mainly
from the lead discharges of one facility (accounting for 61 percent of the category's 2009
combined TWPE). Using data collected for the 2011 Annual Reviews, EPA concludes the
following:
• One facility, Alcan Rolled Products, accounted for 98 percent of the 2009 DMR
lead TWPE. WV DEP indicated the facility did not detect lead but reported the
concentration as half the detection limit without the BDL indicators. Because all
the lead concentrations were non-detect, EPA zeroed the load and TWPE in the
DMRLoads2009 database.
• Correcting the BDL indicators for lead decreases the 2009 DMR TWPE to 9,530,
making the category's 2009 combined TWPE 15,500. This change would drop the
category outside the top 95 percent that EPA prioritized for preliminary review as
part of the 2011 Annual Reviews.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
4.5 Aluminum Forming Category References
1. Clevenger, Renee. 2011. Notes From Telephone Communication Between Renee
Clevenger, West Virginia Department of Environmental Protection (WVDEP), and
Kimberly Landick, Eastern Research Group, Inc., Re: 2009 DMR Lead Discharges. (May
5). EPA-HQ-OW-2010-0824. DCN 07561.
2. U.S. EPA. 1994. Method 200.7 Determination of Metals and Trace Elements in Water
and Wastes by Inductively Coupled Plasma-Atomic Emissions Spectrometry. Revision
4.4. (Cincinnati, OH). Available online at:
5 WV DEP indicated that the minimum detection limit was 10 milligrams per liter (Clevenger, 2011). EPA believes
WV DEP meant 10 |ig/L because the facility's permit requires lead reported in |ig/L (WV DEP, 2002) and the
method detection limit for EPA Method 200.7 is 10 |ig/L (U.S. EPA, 1994).
4-5
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Section 4—Aluminum Forming (40 CFR Part 467)
http://water.epa.gov/scitech/methods/cwa/bioindicators/upload/2007_07_10_methods_me
thod_200_7.pdf. EPA-HQ-OW-2010-0824. DCN 07562.
3. U.S. EPA. 2005. 2005 Annual Screening-Level Analysis: Supporting the Annual Review
of Existing Limitations Guidelines and Standards and Identification of Potential New
Categories for Effluent Limitations Guidelines and Standards. (Washington, D.C).
(August). EPA-821 -B-05-003. EPA-HQ-OW-2004-0032-0901.
4. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
5. WV DEP. 2002. West Virginia Department of Environmental Protection. NPDES Permit:
Pechiney Rolled Products, LLC, Ravenswood, WV. (December 30). EPA-HQ-OW-2010-
0824. DCN 07563.
4-6
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Section 5—Centralized Waste Treatment (40 CFR Part 437)
5. Centralized Waste Treatment (40 CFR Part 437)
EPA selected the Centralized Waste Treatment (CWT) Category for preliminary review
because it ranks high, in terms of toxic-weighted pound equivalent (TWPE), in the point source
category rankings. EPA previously reviewed discharges from the CWT Category as part of the
2007 and 2008 Annual Reviews (U.S. EPA, 2007, 2008). This section summarizes the results of
the 2011 Annual Reviews associated with the CWT Category, which focused on discharges of
hexachlorobenzene from one facility, because of its high TWPE relative to the other facilities in
the CWT Category.
5.1 CWT Category 2011 Toxicity Rankings Analysis
Table 5-1 compares the toxicity rankings analysis results for the CWT Category from the
2006 through 2011 Annual Reviews. The combined TWPE from discharges in the discharge
monitoring report (DMR) and Toxics Release Inventory (TRI) databases decreased from
discharge years 2004 to 2008 and increased from 2008 to 2009. The estimated 2009 DMR
TWPE accounts for approximately 79 percent of the combined 2009 DMR and TRI TWPE,
similar to recent years of data.
Table 5-1. CWT Category TRI and DMR Discharges for the
2006 Through 2011 Toxicity Rankings Analyses
Year of Discharge
Year of Review
CWT Category
TRI TWPE"
DMR TWPEb
Total TWPE
2002
2006
38,100
3,420
41,500
2004
2007
7,460,000
8,730
7,470,000
2005
2008
4,280,000
NA
NA
2007
2009
3,790
30,900
34,700
2008
2010
6,850
20,300
27,200
2009
2011
10,500
40,500
51,000
Sources: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 include only major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
5.2 CWT Category Pollutants of Concern
EPA's review of the CWT Category focused on the 2009 DMR discharges because the
2009 DMR data dominate the category's combined TWPE. Table 5-2 lists the five pollutants
with the highest TWPE based on results from the 2011 and 2010 Annual Reviews
(DMRLoads2009 v2 and DMRLoads2008 v3, respectively).
Hexachlorobenzene is the top DMR pollutant in 2009, contributing to more than 78
percent of the 2009 DMR category TWPE. EPA did not investigate the other top pollutants as
part of the 2011 Annual Reviews because they represent less than 22 percent of the combined
2009 DMR and TRI TWPE for the CWT Category.
5-1
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Section 5—Centralized Waste Treatment (40 CFR Part 437)
Table 5-2. CWT Category Top DMR Pollutants
Pollutant
2008 DMR Data3
2009 DMR Data"
Rank
Number of
Facilities Reporting
Pollutant
TWPE
Rank
Number of
Facilities Reporting
Pollutant
TWPE
Hexachlorobenzene
Pollutant not reported in the top five 2008 DMR-reported
pollutants.
1
1
31,400
Sulfur
2
2
3,960
2
2
3,360
Benzo(a)pyrene
Pollutants not reported in the top five 2008 DMR-reported
pollutants.
3
1
1,590
PCB-1242
4
1
535
Chrysene
5
1
501
Chlordane
1
1
7,540
Pollutants not reported in the top five 2009 DMR-reported
pollutants.
Cyanide
3
7
1,660
Silver
4
3
1,270
Acrylonitrile
5
2
1,100
CWT Category Total
NA
9b
20,300
NA
9b
40,500
Sources: DAdRLoads2008jv3 and DATRLoads2009_v2.
a DMR data include major and minor dischargers.
b Number of facilities reporting a TWPE of greater than zero.
NA: Not applicable.
5-2
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Section 5—Centralized Waste Treatment (40 CFR Part 437)
5.3 CWT Category Hexachlorobenzene Discharges in DMR
Clean Harbors Baton Rouge, LLC (Clean Harbors), in Baton Rouge, LA, accounts for all
of the CWT Category's hexachlorobenzene discharges in the 2009 DMR database. Clean
Harbors reports hexachlorobenzene discharges as a quantity (i.e., pounds per day), which is
calculated using the measured concentration and flow. Table 5-3 presents Clean Harbors'
monthly hexachlorobenzene quantities for 2007 through 2010. All monthly values are below the
detection limit except for December 2009.
As part of the 2011 Annual Reviews, EPA contacted the facility about the December
2009 hexachlorobenzene quantity. The facility contact stated that they had measured
hexachlorobenzene at levels below detection, but a laboratory dilution factor error had caused the
detection limit to be 400 micrograms per liter (|ig/L), 40 times the usual value. Because the value
could thus have been anywhere between 0 and 399 |ig/L, the facility reported the
hexachlorobenzene quantity using the highest possible concentration (399 |ig/L) and explained
the laboratory's error in its cover letter with the DMR data (Clark, 2011). The facility contact
also stated that besides December 2009, hexachlorobenzene was always measured at levels
below detection (Clark, 2011), as shown in Table 5-3.
As a result, EPA determined that it was appropriate to modify the DMRLoads2009
database by adding the below detection limit (BDL) indicator to the December 2009
hexachlorobenzene discharge, which zeros the facility's 2009 hexachlorobenzene TWPE and
decreases the CWT Category's 2009 combined TWPE to 19,600.
Table 5-3. 2007-2010 Monthly Hexachlorobenzene Discharges for Clean Harbors Baton
Rouge as Reported in Discharge Monitoring Reports
Monlli
Qu;inlil> (lhs/d;i\)
2007
200S
2009
2010'
January
<0.051
<0.051
<0.051
<0.101
February
<0.05
<0.051
<0.05
< 0.026
March
<0.05
<0.05
<0.039
0
April
<0.051
<0.05
< 0.048
0
May
<0.051
<0.05
<0.051
0
June
<0.05
< 0.025
< 0.026
<0.02
August
<0.05
< 0.025
No discharge
0
July
<0.05
< 0.025
<0.05
0
September
<0.05
No discharge
< 0.049
0
October
<0.05
< 0.027
< 0.027
<0.02
November
No discharge
<0.05
< 0.026
0
December
<0.05
No discharge
0.317
No discharge
Sources: Envirofacts; DMRLoads2007_v4; DMRLoads2008_v3; and DMRLoads2009_v2.
" 2010 data were pulled from Envirofacts.
5-3
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Section 5—Centralized Waste Treatment (40 CFR Part 437)
5.4 CWT Category Conclusions
The estimated toxicity of the CWT Category discharges results mainly from the
hexachlorobenzene discharges of one facility (accounting for 62 percent of the category's 2009
combined TWPE). Using data collected for the 2011 Annual Reviews, EPA concludes the
following:
• The hexachlorobenzene discharges are from one facility, Clean Harbors Baton
Rouge, LLC. The facility measured its December 2009 concentration at levels
below detection but reported the quantity without the BDL indicator because a
laboratory error caused the detection limit to be 400 |ig/L (Clark, 2011). For
toxicity rankings analysis database purposes, EPA determined that the BDL
indicator should be added to the concentration, which zeros the
hexachlorobenzene discharges.
• Correcting the BDL indicator for hexachlorobenzene decreases the 2009 DMR
TWPE to 9,100, making the category's 2009 combined TWPE 19,600. This
change would drop the category outside the top 95 percent that EPA prioritized
for preliminary review as part of the 2011 Annual Reviews.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
5.5 CWT Category References
1. Clark, Billy. 2011. Notes From Telephone Communication with Billy Clark, Clean
Harbors Baton Rouge, LLC, and Kimberly Landick, Eastern Research Group, Inc., Re:
2009 DMR Hexachlorobenzene Discharges. (May 5). EPA-HQ-OW-2010-0824. DCN
07565.
2. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA 821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
3. U. S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA 821-R-08-015. EPA-HQ-OW-2006-0771-1701.
4. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
5-4
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Section 6—Coal Mining (40 CFR Part 434)
6. Coal Mining (40 CFR Part 434)
EPA identified the Coal Mining Category for preliminary review because it continues to
rank high, in terms of toxic-weighted pound equivalent (TWPE), in point source category
rankings. This industry was reviewed previously in EPA's Preliminary and Final Effluent
Guidelines Program Plans from 2004 to 2006 (U.S. EPA, 2004, 2005, 2006). EPA also
conducted a detailed study of the Coal Mining Category during the 2007 and 2008 Annual
Reviews (U.S. EPA, 2008). This section summarizes the results of the 2011 Annual Reviews
associated with the Coal Mining Category. EPA focused on discharges of manganese and iron
because of their high TWPE relative to the rest of the Coal Mining Category.
6.1 Coal Mining Category Toxicity Rankings Analysis
Table 6-1 compares the toxicity rankings analysis results for the Coal Mining Category
from 2006 through 2011. The combined TWPE from discharges in the discharge monitoring
report (DMR) and Toxics Release Inventory (TRI) databases increased using 2008 data because
the 2002 through 2007 DMR databases excluded minor dischargers. The DMR and TRI database
TWPE decreased from discharge year 2008 to 2009.
Table 6-1. Coal Mining Category TRI and DMR Discharges for the
2006 Through 2011 Toxicity Rankings Analyses
Year of Discharge
Year of Review
Coal Mining Category
TRI TWPE1'
DMR TWPEb
Total TWPE
2002
2006
3,120
1,910
5,030
2004
2007
1,190
2,490
3,680
2005
2008
745
NA
NA
2007
2009
493
2,290
2,780
2008
2010
1,280
76,400
77,700
2009
2011
1,010
65,800
66,800
Sources: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v2;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 only include major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
It is important to note that discharges for the majority of coal mines are not included in
the TRI or DMR databases. There are over 1,000 active coal mines in the U.S. (U.S. EPA, 2008).
TRI contains data for facilities in certain SIC codes, including those for coal mining (1221, 1222,
and 1231). However, only coal mines with at least 10 full-time employees or their equivalent,
and that manufacture, use, or otherwise process certain chemicals at or above an activity
threshold report to TRI (U.S. EPA, 2009). The 2008 Coal Mining Detailed Study found that only
21 coal mines had data in TRI (U.S. EPA, 2008). For DMR data, many states classify discharges
from coal mines as "minor dischargers" and, as a result, do not enter DMR data into EPA's ICIS-
NPDES or PCS systems. EPA's 2008 Detailed Study for the Coal Mining Point Source Category
6-1
-------
Section 6—Coal Mining (40 CFR Part 434)
found that less than one-fourth of the coal mines were represented in the EPA's DMR storage
system (U.S. EPA, 2008).
6.2 Coal Mining Manufacturing Category Pollutants of Concern
EPA's review of the Coal Mining Category focused on the 2009 DMR discharges
because the 2009 DMR data dominate the category's combined TWPE. Table 6-2 lists the five
pollutants with the highest TWPE based on results from the 2011 and 2010 Annual Reviews
(DMRLoads2009 v2 and DMRLoads2008 v3, respectively).
Manganese and iron are the top two DMR pollutants in 2009, contributing more than 77
percent of the total category TWPE. Manganese and iron were also the top pollutants in the 2008
DMR database and were reviewed as part of the Coal Mining Detailed Study during the 2007
and 2008 Annual Reviews (U.S. EPA, 2008). EPA did not investigate the other top pollutants as
part of the 2011 Annual Reviews because they represent a small percentage (less than 23
percent) of the 2009 DMR TWPE for the Coal Mining Category.
Table 6-2. Coal Mining Manufacturing Category Top DMR Pollutants
Pollutant
2008 DM R Data1'
2009 DMR Data1'
Rank
Number of
Faeilities
Reporting
Pollutant
TWPE
Rank
Number of
Faeilities
Reporting
Pollutant
TWPE
Manganese
1
46
80,900
1
57
36,000
Iron
2
133
11,900
2
151
14,600
Mercury
Pollutant not reported in the top five 2009
DMR-reported pollutants.
3
4
6,190
Sulfate
4
36
8,550
4
52
3,630
Chloride
3
33
8,810
5
48
3,360
Magnesium
5
2
1,130
Pollutant not reported in the top five 2009
DMR-reported pollutants.
Coal Mining
Category Total
NA
137b
112,000
NA
166b
65,800
Sources: DMRLoads2008jv3 and DMRLoads2009_v2.
a DMR data include major and minor dischargers.
b Number of facilities reporting a TWPE of greater than zero.
NA: Not applicable.
6.3 Coal Mining Category Iron and Manganese Discharges in DMR
Table 6-3 presents the Coal Mining Effluent Limitations Guidelines (ELGs) limits for
manganese and iron for the Acid or Ferruginous Mine Drainage subcategory (Subcategory C).
See Section 4 of the Coal Mining Detailed Study for additional details on the Coal Mining ELGs
(U.S. EPA, 2008).
6-2
-------
Section 6—Coal Mining (40 CFR Part 434)
Table 6-3. Coal Mining ELGs Subpart C Manganese and Iron Limits
Manganese Limits
Iron Limits
Dailv Maximum
Monthly Average
Dailv Maximum
Monthly Average
Subpart C
(mg/L)
(mg/L)
(mg/L)
(mg/L)
BPT/BAT
4
2
7
3.5
NSPS
4
2
6
3
Source: Coal Mining Point Source Category BPT, BAT, BCT Limitations and New Source Performance
Standards—40 CFR Part 434.
BAT: Best available technology economical achievable.
BPT: Best practicable control technology.
NSPS: New source performance standards.
Table 6-4 presents the facilities that account for the manganese and iron compound
discharges in the 2009 DMR database. Forty-six percent of the manganese and iron discharges
are from the top facility, Freeman United Coal-Industry. The next two facilities, Freeman United
Coal-Crown 2 and Freeman United Coal-Crown 3, account for 28 percent of the manganese and
iron discharges. EPA did not investigate the remaining facilities discharging manganese and/or
iron as part of the 2011 Annual Reviews.
Table 6-4. Top Manganese and Iron Discharging Facilities in the 2009 DMR Database
Facility Name
Facility
Location
Pounds of
Manganese and
Iron Discharged
Manganese and
Iron TWPE
Percentage of Coal Mining
Category's 2009
DMR Manganese and
Iron TWPE
Freeman United Coal-
Industry
Industry, IL
1,570,000
23,100
46%
Freeman United Coal-
Crown 2
Virden, IL
212,000
10,500
21%
Freeman United Coal-
Crown 3
Farmersville, IL
93,800
3,400
7%
Remaining Facilities Reporting Manganese or
Iron Discharges3
1,250,000
13,600
27%
Total
3,120,000
50,600
100%
Source: DMRLoads2009_v2.
a There are 205 remaining facilities that have manganese and/or iron discharges in the 2009 DMR database,
which account for 27 percent of the category's manganese and iron DMR TWPE.
Freeman United Coal-Industry
Freeman United Coal-Industry in Industry, IL, is the top manganese and iron discharging
facility. Freeman United Coal-Industry discharges manganese and iron from 12 outfalls. In
reviewing the facility's 2009 flows, EPA noted that eight of the outfalls had listed flows in 2009
that were 1,000 times greater than in other years. Because previous year's data show a consistent
difference in the order of magnitude, EPA assumed that a units error caused the increase in flow.
Assuming this to be an error, EPA corrected those eight outfalls' flows to be on the same order
of magnitude as the other four outfalls' flow. Table 6-5 presents the original and corrected flows,
along with the original and corrected iron and manganese TWPE. Using the corrected flows, the
6-3
-------
Section 6—Coal Mining (40 CFR Part 434)
facility's iron and manganese TWPE decreases to 270 and its overall total TWPE decreases from
24,400 to 1,510.
Table 6-5. Freeman United Coal-Industry 2009 Original DMR
and Corrected Flow Discharges
Outfall
Original Flow
(MGD)
Corrected
Flow (MGD)
TWPE
Original
Iron
Corrected
Iron
Original
Manganese
Corrected
Manganese
002
67.9
0.0679
685
1.03
9,130
13.8
003
8.61
0.00861
88.1
0.105
611
0.738
009
0.148
NC
2.05
NC
49
NC
018
0.035
NC
0.431
NC
36.1
NC
019
0.062
NC
0
NC
157
NC
24W
0.0283
NC
0.426
NC
8.31
NC
026
15.3
0.0153
326
0.391
5,640
6.80
029
8.1
0.0081
162
0.195
NA
NA
030
69.9
0.0699
312
0.375
NA
NA
031
30.4
0.0304
5,140
5.14
NA
NA
032
4
0.004
86.3
0.086
NA
NA
033
15.3
0.0153
723
2.17
NA
NA
Total TWPE
7,520
12.4
15,600
272
Sources: DMRLoads2009_v2 and coal mining supporting calculations (ERG, 2011).
NA: Not applicable. Facility did not report manganese discharges for these outfalls.
NC: No change. EPA did not correct the flow for this outfall because the order of magnitude matched flows from
previous years.
In addition to the flow corrections, EPA identified that some of Freeman United Coal-
Industry's manganese and iron discharges were above their proposed permit limits, which are
equivalent to or more stringent than the ELGs. The proposed limits are from an October 2010
public notice on the facility's NPDES permits (IL EPA, 2010) and may not reflect the limits in
place in 2009.
Table 6-6 presents the ranges of manganese and iron concentrations, the proposed permit
limits, and the percent of concentrations that are above the proposed permit limits for each
outfall. For manganese, approximately 64 percent of the monthly average concentrations and 72
percent of the daily maximum concentrations are above the proposed permit limits. For iron,
approximately 8 percent of the monthly average concentrations and 2 percent of the daily
maximum concentrations were above the proposed permit limits. As shown in Table 6-6,
Freeman United Coal-Industry's manganese and iron discharges exceed the proposed permit
limits. Additionally, the ranges of manganese and iron concentrations exceed the ELG limits
listed for the subcategory in Table 6-3, which are less stringent than the proposed permit limits
below. Permit exceedances do not warrant the need for further regulation but rather better
facility-specific compliance support.
6-4
-------
Section 6—Coal Mining (40 CFR Part 434)
Table 6-6. Freeman United Coal-Industry's 2009 Manganese and Iron Concentrations
Outfall
Monthly Average Concentrations (mg/L)
Daily Maximum Concentrations (mg/L)
Range
Proposed
Permit
Limits"
Percentage Above
Proposed Permit
Limits
Range
Proposed
Permit
Limits"
Percentage Above
Proposed Permit
Limits
Manganese Discharges
002
0.248-1.76
1
38%
0.248-1.81
1
38%
003
0.102-1.04
1
10%
0.13-1.64
1
20%
009
0.266-2.69
1
67%
0.648-3.26
1
92%
018
1.33-13.6
1
100%
1.96-14.1
1
100%
019
0.49-59
1
83%
0.49-61
1
92%
024W
0.411-3.53
1
58%
0.479-3.53
1
58%
026
0.284-4.71
1
80%
0.54-8.6
1
90%
Manganese
Discharges
for All
Outfalls
0.102-59
64%
0.13-61
72%
Iron Discharges
003b
0.07-1.8
3.5
0%
0.09-3.33
7
0%
009b
0.137-5.79
3.5
7%
0.18-5.79
7
0%
018b
0.219-2.48
3.5
0%
0.3-3.69
7
0%
019b
1.5-1.5
3.5
0%
1.5-1.5
7
0%
024W
0.091-4.82
3
7%
0.321-4.82
6
0%
026
0.198-3.33
3
10%
0.24-5.86
6
0%
029
0.376-2.36
3
0%
0.557-3.74
6
0%
030
0.093-1.26
3
0%
0.099-3.21
6
0%
031
2.31-11.9
3
67%
4.33-15.4
6
33%
032
0.381-1.57
3
0%
0.628-3.99
6
0%
033
8.13-8.13
3
100%
12.8-12.8
6
100%
Iron
Discharges
for All
Outfalls
0.07-11.85
8%
0.09-15.4
2%
Source: DMRLoads2009_v2.
a The proposed permit limits are listed in the public notice for their future permit (IL EPA, 2010).
b These outfalls are permitted using the 40 CFR Part 434 Subpart C BAT limits because discharges began before
July 27, 1987 (IL EPA, 2010).
Freeman United Coal-Crown 2
Freeman United Coal-Crown 2 in Virden, IL, is the second top manganese and iron
discharging facility. Freeman United Coal-Crown 2 discharges manganese and iron from outfall
001. As part of the 2011 Annual Reviews, EPA contacted the facility about their 2009 flows and
received corrected data from the facility contact. Table 6-7 presents the original and corrected
flows, along with the original and corrected iron and manganese TWPE. Using the corrected
flows, the facility's iron and manganese TWPE decreases to 836. This will decrease the facility's
overall total TWPE from 12,100 to 961.
6-5
-------
Section 6—Coal Mining (40 CFR Part 434)
Table 6-7. Freeman United Coal-Crown 2 2009 Original DMR and Corrected Flow
Discharges
Outfall
Original Flow
(MGD)
Corrected
Flow (MGD)
TWPE
Original
Iron
Corrected
Iron
Original
Manganese
Corrected
Manganese
Crown 2
001
82.5
2.38
381
30.2
10,100
805
Sources: DMRLoads2009_v2; facility contact (Austin, 2011); and coal mining supporting calculations (ERG, 2011).
Freeman United Coal-Crown 3
Freeman United Coal-Crown 3 in Industry, IL, is the third top manganese and iron
discharging facility. Freeman United Coal-Crown 3 discharges manganese and iron from two
outfalls, 001 and 002. As part of the 2011 Annual Reviews, EPA contacted the facility about
their 2009 flows and received corrected data from the facility contact. Table 6-8 presents the
original and corrected flows, along with the original and corrected iron and manganese TWPE.
Using the corrected flows, the facility's iron and manganese TWPE decreases to 6.37. This will
decrease the facility's overall total TWPE from 6,230 to 11.8.
Table 6-8. Freeman United Coal - Crown 3 2009 Original DMR and
Corrected Flow Discharges
Outfall
Original Flow
(MGD)
Corrected
Flow (MGD)
TWPE
Original
Iron
Corrected
Iron
Original
Manganese
Corrected
Manganese
Crown 3
001
0.166
116
208
0.385
2,350
5.81
002
0.042
29.5
67.6
0.175
NA
NA
Total TWPE
276
0.559
2,350
5.81
Sources: DA4RLoads2009_v2; facility contact (Austin, 2011); and coal mining supporting calculations (ERG, 2011).
NA: Not applicable. Facility did not report manganese discharges for these outfalls.
6.4 Coal Mining Pollutants Not Currently Regulated by Part 434
Some states and stakeholders have identified concerns with pollutants beyond those
regulated in Part 434. For example, West Virginia regulates aluminum, selenium, and TDS in
coal mining drainage based on state water quality criteria. The 2008 Coal Mining Detailed Study
identified data on pollutants of concern not regulated by Part 434, including aluminum,
cadmium, selenium, and total dissolved solids/conductivity (U.S. EPA, 2008).
6.5 Coal Mining Category Conclusions
The estimated toxicity of the Coal Mining Category discharges resulted from manganese
and manganese compounds and iron and iron compounds. Data collected for the 2011 Annual
Reviews demonstrate that wastewater discharge characteristics for this category are consistent
with discharges from prior years. Using data collected for the 2011 Annual Reviews, EPA
concludes the following:
6-6
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Section 6—Coal Mining (40 CFR Part 434)
• One facility, Freeman United Coal-Industry, accounts for 46 percent of the
category's manganese and iron 2009 DMR discharges. EPA determined that some
of the facility's outfalls had listed flows that were 1,000 times greater in 2009
than in other years. Correcting the flows results in a reduction in the facility's
TWPE from 24,400 to 1,510. Additionally, more than 64 percent of the
manganese discharges and 2 percent of the iron discharges exceed the facility's
proposed permit limits, which are equivalent to or more stringent than the ELGs.
Permit limit exceedances do not warrant the need for further regulation but rather
better facility-specific compliance support. As new data become available, EPA
will review the manganese and iron discharges from Freeman United Coal-
Industry to determine if the same conclusion applies.
• Freeman United Coal-Crown 2 and Freeman United Coal-Crown 3 account for
21 percent and 7 percent of the category's manganese and iron 2009 DMR
discharges, respectively. EPA determined that there was an error in the flows for
both facilities, which the facility contact corrected. Correcting the flows for both
facilities results in a reduction in the TWPE from 12,100 to 961 for Freeman
United Coal-Crown 2 and 6,230 to 11.8 for Freeman United Coal-Crown 3.
• Correcting the database errors identified during the 2011 Annual Reviews
decreases the 2009 Coal Mining Category TWPE from 66,800 to 26,600. This
change would drop the category outside the top 95 percent that EPA prioritized
for preliminary review as part of the 2011 Annual Reviews.
• Based solely on the 2011 toxicity ranking analysis, the Coal Mining category
would be ranked a lower priority for revision. However, the Coal Mining
Category (Part 434) is under represented in the databases EPA uses in the toxicity
ranking analysis. Furthermore, Part 434 currently only regulates pH, total
suspended solids, iron, and manganese; while coal mine drainage also contains
elevated levels of aluminum, selenium, and total dissolved solids.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
6.6 Coal Mining Category References
1. Austin, Thomas. 2011. Telephone and Email Communication with Thomas Austin,
Freeman United Coal, and Elizabeth Sabol, Eastern Research Group, Inc., Re: 2009
DMR Flow Discharges. (June 30). EPA-HQ-OW-2010-0824. DCN 07580.
2. ERG. 2011. Eastern Research Group, Inc. Coal Mining Supporting Calculations. (July).
EPA-HQ-OW-2010-0824. DCN 07581.
3. IL EPA. 2010. Illinois Environmental Protection Agency. NPDESPermit: Springfield
Coal Company, Industry, IL. (October 13). EPA-HQ-OW-2010-0824. DCN 07582.
6-7
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Section 6—Coal Mining (40 CFR Part 434)
4. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. EPA-821 -R-04-014. Washington, D.C. (August). EPA-HQ-OW-2003-0074-1346
through 1352.
5. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. EPA-821-B-05-004. Washington, D.C. (August). EPA-HQ-OW-2004-
0032-0016.
6. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. EP A-821 -R-06-018. Washington, D.C. (December). EPA-HQ-OW-2004-0032-
2782.
7. U.S. EPA. 2008. Coal Mining Detailed Study. EPA-821-R-08-012. Washington, D.C.
(August). EPA-HQ-OW-2006-0771-1695.
8. U.S. EPA. 2009. Technical Support Document for the Annual Review of Existing
Effluent Guidelines and Identification of Potential New Point Source Categories. EPA-
821-R-09-007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515.
9. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
6-8
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Section 7—Fertilizer Manufacturing (40 CFR Part 418)
7. Fertilizer Manufacturing (40 CFR Part 418)
EPA selected the Fertilizer Manufacturing Category for preliminary review because it
continues to rank high, in terms of toxic-weighted pound equivalent (TWPE), in the point source
category rankings. EPA has reviewed facility discharges from this category in past years of
review (2004-2009) (U.S. EPA, 2004, 2005, 2006, 2007, 2008, 2009). The Final 2010 Plan
summarizes the results of EPA's review of this industry in 2010 (U.S. EPA, 2011). This section
summarizes the results of the 2011 Annual Reviews, which focused on discharges of fluoride
from two facilities due to their high TWPE relative to the other facilities in the Fertilizer
Manufacturing Category.
7.1 Fertilizer Manufacturing Category 2011 Toxicity Rankings Analysis
Table 7-1 compares the toxicity rankings analysis results for the Fertilizer Manufacturing
Category from the 2006 through 2011 Annual Reviews. The combined TWPE from discharges in
the discharge monitoring report (DMR) and Toxics Release Inventory (TRI) databases decreased
from discharge years 2002 to 2008 and increased slightly from 2008 to 2009. The estimated 2009
DMR TWPE accounts for approximately 99 percent of the combined 2009 DMR and TRI
TWPE, similar to previous years of data.
Table 7-1. Fertilizer Manufacturing Category TRI and DMR Discharges for the 2006
Through 2011 Toxicity Rankings Analyses
Year of Discharge
Year of Review
Fertilizer Manufacturing Category
TRI TWPE1'
DMRTWPEb
Total TWPE
2002
2006
9,100
1,370,000
1,380,000
2004
2007
10,800
1,170,000
1,180,000
2005
2008
7,300
NA
NA
2007
2009
4,460
1,095,000
1,100,000
2008
2010
8,120
818,000
826,000
2009
2011
9,550
902,000
912,000
Sources: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 include only major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
NA - Not applicable. EPA did not evaluate DMR data for 2005.
7.2 Fertilizer Manufacturing Category Pollutants of Concern
EPA's review of the Fertilizer Manufacturing Category focused on the 2009 DMR
discharges because the 2009 DMR data dominates the category's combined TWPE. Table 7-2
lists the five pollutants with the highest TWPE based on results from the 2011 and 2010 Annual
Reviews (DMRLoads2009_v2 and DMRLoads2008 v3, respectively).
7-1
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Section 7—Fertilizer Manufacturing (40 CFR Part 418)
Table 7-2. Fertilizer Manufacturing Category Top DMR Pollutants
Pollutant
2008 DMR Data"
2009 DMR Data'1
Rank
Number of Facilities
Reporting Pollutant
TWPE
Rank
Number of Facilities
Reporting Pollutant
TWPE
Fluoride
1
3
778,000
1
3
875,000
Aluminum
3
1
13,300
2
1
16,700
Cadmium
4
1
6,710
3
2
6,580
Ammonia as nitrogen
2
27
16,000
4
24
1,700
Nitrogen
Pollutant not reported in the top five 2009 DMR-
reported pollutants.
5
13
605
2,4-dichlorophenoxyacetic acid
5
1
1,750
Pollutant not reported in the top five 2009 DMR-
reported pollutants.
Fertilizer Manufacturing Category Total
NA
36b
818,000
NA
31b
902,000
Sources: DMRLoads2008jy3', and DA4RLoads2009_v2.
" DMR data include major and minor dischargers.
b Number of facilities reporting a TWPE of greater than zero.
NA - Not applicable.
7-2
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Section 7—Fertilizer Manufacturing (40 CFR Part 418)
Fluoride is the top DMR-reported pollutant in 2008 and 2009, contributing more than 99
percent of the total category TWPE. Fluoride was also the primary reason for the review using
2004 and 2007 DMR data (U.S. EPA, 2007; U.S. EPA, 2009). EPA did not investigate the other
top pollutants as part of the 2010 or 2011 Annual Reviews because the other pollutants represent
a small percentage (less than one percent) of the combined 2009 DMR and TRI TWPE for the
Fertilizer Manufacturing Category.
7.3 Fertilizer Manufacturing Category Fluoride Discharges in DMR
Table 7-3 presents three facilities that account for all of the fluoride discharges in the
2009 and 2008 DMR databases. The majority (99 percent) of the fluoride discharges in 2009
were from Mosaic Fertilizers, LLC, in Uncle Sam, LA, and IMC Phosphates in St. James, LA.
The other facility, Mississippi Phosphates Corporation in Pascagoula, MS, accounts for the
remaining one percent. These facilities generate wastewater-containing fluoride while
manufacturing wet-process phosphoric acid, which is used in phosphatic fertilizer manufacturing
(U.S. EPA, 1974). See the Technical Support Document for the 2006 Effluent Guidelines
Program Plan (U.S. EPA, 2006) for descriptions of the wet-process phosphoric acid process
(Section 8.5.1), wastewater sources of fluoride (Section 8.5.2), and wastewater treatment of
fluoride (Section 8.5.3).
7-3
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Section 7—Fertilizer Manufacturing (40 CFR Part 418)
Table 7-3. Top Fluoride-Discharging Facilities in 2008 and 2009 DMR Databases
Facility Name
Facility Location
2008"
2009"
Pounds of
Fluoride
Discharged
Fluoride TWPE
Percentage of
Fertilizer
Manufacturing
Category's 2008
DMR Fluoride
TWPE
Pounds of
Fluoride
Discharged
Fluoride
TWPE
Percentage of
Fertilizer
Manufacturing
Category's 2009
DMR Fluoride
TWPE
Mosaic Fertilizer, LLC
Uncle Sam, LA
23,500,000
705,000
91%
27,200,000
816,000
93%
IMC Phosphates Co.
St James, LA
2,000,000
59,900
8%
1,500,000
46,400
5%
Mississippi Phosphates Corp.
Pascagoula, MS
452,000
13,600
1%
414,000
12,400
1%
Total
25,900,000
778,000
100%
29,200,000
875,000
100%
Sources: DMRLoads2008_v3 and DMRLoads2009_v2.
a Major and minor dischargers.
7-4
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Section 7—Fertilizer Manufacturing (40 CFR Part 418)
Both of the top facilities in the Fertilizer Manufacturing Category are phosphate fertilizer
manufacturers. Phosphate fertilizer manufacturers are subject to 40 CFR Part 418 Subpart A,
"Phosphate Subcategory." Subpart A BAT includes limits on flow-based surge capacity and
pollutant discharge concentrations. The flow-based requirements (U.S. EPA, 1974) are:
• Zero discharge of wastewater except from the gypsum storage and disposal area.
• Maintenance of a surge capacity for a 10-year, 24-hour storm event (BPT) or a
25-year, 24-hour storm event (BAT) in the gypsum storage and disposal area.
• If stored wastewater reaches 50 percent of the required surge capacity, the facility
is allowed to discharge treated wastewater.
• If stored wastewater exceeds 50 percent of the required surge capacity, the facility
is required to treat and discharge wastewater.
• During discharge events, the facility is required to meet limitations for
phosphorus, fluoride (25 milligrams per liter monthly average and 75 milligrams
per liter daily maximum), total suspended solids, and pH.
The applicability of Subpart A excludes certain wet-process phosphoric acid processes
from BPT, BAT, and BCT limitations that were under construction either on or before April 8,
1974, at plants located in the state of Louisiana. As a result, the Mosaic Fertilizers facility in
Uncle Sam (previously owned by IMC Phosphates) and the IMC Phosphates facility in St. James
are excluded from Subpart A. Permit writers limit discharges from these facilities using facility-
specific permitting support (see 52 FR 28428, July 29, 1987). See the Technical Support
Document for the 2006 Effluent Guidelines Program Plan (Section 8.5.4) for information on
how discharges from these facilities are permitted (U.S. EPA, 2006).
7.4 Fertilizer Manufacturing Category Conclusions
The estimated toxicity of the Fertilizer Manufacturing Category discharges results mainly
from the fluoride discharges of two facilities (accounting for 95 percent of the category's 2009
combined TWPE), which are excluded from the Subpart A applicability. Data collected for the
2011 Annual Reviews demonstrated that wastewater discharge characteristics for this category
are consistent with discharges from prior years. Using data collected for the 2011 Annual
Reviews, EPA concludes the following:
• The two facilities that accounted for 99 percent of the fluoride discharges, Mosaic
Fertilizers' Uncle Sam facility and IMC Phosphates' St. James facility, are
exempt from 40 CFR Part 418 Subpart A. The permit limits are based on facility-
specific permitting support (U.S. EPA, 2011). These facilities do not represent the
category as a whole because they are exempt from Part 418 (see 52 FR 28428,
July 29, 1987).
• The total 2009 TWPE excluding the fluoride discharges from these two facilities
is 16,300. This change would drop the category outside the top 95 percent that
EPA prioritized for preliminary review as part of the 2011 Annual Reviews.
7-5
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Section 7—Fertilizer Manufacturing (40 CFR Part 418)
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
7.5 Fertilizer Manufacturing Category References
1. U.S. EPA. 1974. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Basic Fertilizer Chemicals Segment of the
Fertilizer Manufacturing Point Source Category. Washington, D.C. (March). EPA-440-1-
75-042-a.
2. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA 821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
3. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004-
0032-0053.
4. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
5. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
6. U. S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-08-015. EPA-HQ-OW-2006-0771-1701.
7. U. S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, DC. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-0517-0515.
8. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA 820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
9. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
7-6
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Section 8—Inorganic Chemicals Manufacturing (40 CFR Part 415)
8. Inorganic Chemicals Manufacturing (40 CFR Part 415)
EPA selected the Inorganic Chemicals Manufacturing (Inorganic Chemicals) Category
for preliminary review because it continues to rank high, in terms of toxic-weighted pound
equivalent (TWPE), in the point source category rankings. The Final 2010 Plan (U.S. EPA,
2011) summarizes the results of EPA's 2010 review of this industry. EPA also reviewed
discharges from the Inorganic Chemicals Category as part of the 2004 through 2009 Annual
Reviews, except for 2008 (U.S. EPA, 2004a, 2005, 2006, 2007, 2009). This section summarizes
the results of the 2011 Annual Reviews associated with the Inorganic Chemicals Category. EPA
focused on discharges of manganese and manganese compounds and dioxin and dioxin-like
compounds because of their high TWPE relative to the rest of the Inorganic Chemicals Category.
EPA has reviewed discharges from the Chlor-Alkali Subcategory as part of the Chlorine
and Chlorinated Hydrocarbons effluent guidelines rulemaking. Because a rulemaking for this
segment of the Inorganic Chemicals Category began in 2005, and given EPA's findings on the
industry, EPA excluded discharges from these facilities from a further toxicity ranking analysis
in this year's review (see Table V-l, 76 FR 66286, October 26, 2011).
8.1 Inorganic Chemicals Category Toxicity Rankings Analysis
Table 8-1 compares the toxicity rankings analysis results for the Inorganic Chemicals
Category from the 2006 through 2011 Annual Reviews. The combined TWPE from discharges in
the discharge monitoring report (DMR) and Toxics Release Inventory (TRI) databases increased
from discharge years 2002 to 2004, and decreased from discharge year 2007 to 2009.
Table 8-1. Inorganic Chemicals Category TRI and DMR Discharges for the 2006 Through
2011 Toxicity Rankings Analyses
Year of Discharge
Year of Review
Inorganic Chemicals Category
TRI TWPE'1
DMR TWPEb
Total TWPE
2002
2006
186,000
107,000
293,000
2004
2007
123,000
316,000
439,000
2005
2008
92,100
NA
NA
2007
2009
54,700
394,000
449,000
2008
2010
71,300
228,000
299,000
2009
2011
72,500
51,300
124,000
Sources: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v2;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 only include major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
8.2 Inorganic Chemicals Category Pollutants of Concern
EPA's review of the Inorganic Chemicals Category focused on the 2009 TRI discharges
because the 2009 TRI data account for 58 percent of the category's combined TWPE. Table 8-2
8-1
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Section 8—Inorganic Chemicals Manufacturing (40 CFR Part 415)
lists the five pollutants with the highest TRI TWPE based on results from the 2011 and 2010
Annual Reviews (TRIReleases2009 v2 and TRIReleases2008 v3, respectively).
The top two pollutants in the TRI database, manganese and manganese compounds and
dioxin and dioxin-like compounds, account for approximately 68 percent of the category's 2009
TRI TWPE. These two pollutants have consistently accounted for the majority of the Inorganic
Chemicals Category TWPE:
• Manganese and manganese compounds have been the top TRI-reported pollutant
in the 2004, 2008, and 2009 rankings databases (U.S. EPA, 2011).
• Dioxin and dioxin-like compounds are the second top TRI-reported pollutant in
the 2009 rankings database and were also the top TRI-reported pollutant in 2002
(U.S. EPA, 2006).
EPA did not investigate the other top pollutants as part of the 2011 Annual Reviews
because the other pollutants represent less than 32 percent of the category's 2009 TRI TWPE.
8-2
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Section 8—Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 8-2. Inorganic Chemicals Category Top TRI Pollutants
2008 TRI Data"
2009 TRI Data"
Pollutant
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Manganese and manganese compounds
1
26
38,200
1
24
35,800
Dioxin and dioxin-like compounds
Pollutants not reported in the top five 2008 TRI-
reported pollutants.
2
7
13,800
Arsenic and arsenic compounds
3
5
6,100
3
6
6,140
Nitrate compounds
4
49
5,340
4
49
3,910
Mercury and mercury compounds
2
10
6,680
5
11
3,510
Polychlorinated biphenyls (PCBs)
5
2
3,570
Pollutants not reported in the top five 2009 TRI-
reported pollutants.
Inorganic Chemicals Category Total
NA
161b
71,300
NA
153b
72,500
Sources: TRIReleases2007_v2 and TRIReleases2008_v3.
" Discharges include transfers to POTWs and account for POTW removals.
b Number of facilities reporting TWPE greater than zero.
NA: Not applicable.
8-3
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Section 8—Inorganic Chemicals Manufacturing (40 CFR Part 415)
8.3 Inorganic Chemicals Category Manganese and Manganese Compound Discharges
in TRI
Table 8-3 presents the facilities that account for the manganese and manganese
compound discharges in the 2009 TRI database. Two plants are responsible for 65 percent of
these discharges: Tronox Pigments, Inc. (Tronox Pigments), and Tronox LLC.
Tronox Pigments and Tronox LLC both manufacture titanium dioxide (Blackmon, 2011;
Freeze, 2011). Previous annual reviews have identified titanium dioxide manufacturers as
facilities with high manganese and manganese compound discharges. EPA focused its additional
review for the 2011 Annual Reviews on discharges from Tronox Pigments and Tronox LLC.
Table 8-3. Manganese and Manganese Compound Discharging Facilities in the Inorganic
Chemicals Category in the 2009 TRI Database
Facility Name
Facility Location
Pollutant
TWPE
Facility Percent of Manganese
and Manganese Compounds
Category TWPE
Tronox Pigments, Inc.
Savannah, GA
11,700
33%
Tronox LLC
Hamilton, MS
11,600
32%
Millennium Inorganic Chemicals Inc.
Hawkins Point Plant
Baltimore, MD
6,880
19%
DuPont Edgemoor
Edgemoor, DE
2,440
7%
Remaining facilities reporting manganese
and manganese compound discharges3
NA
3,220
9%
Total
NA
35,800
100%
Source: TRIReleases2009_v2.
" There are 20 remaining facilities that have manganese and manganese compound discharges in the 2009 TRI
database, which account for 9 percent of the category's manganese and manganese compound TRI TWPE.
NA: Not applicable.
8.3.1 Tronox Pigments, Inc.
Tronox Pigments in Savannah, GA, is the top manganese and manganese compound
discharging facility. As part of the 2011 Annual Reviews, EPA contacted the facility and
confirmed the manganese discharges were not reporting errors. However, Tronox representatives
stated that manganese discharges resulted from their titanium dioxide manufacturing, which was
shutdown in August 2009 (Blackmon, 2011). The facility continues to operate its sulfuric acid
plant (Blackmon, 2011; Tronox, 2007). As shown in Table 8-4, Tronox Pigments' manganese
and manganese compound TWPE decreased from 2007 to 2009. Tronox Pigments did not report
manganese and manganese compound discharges in 2010, confirming that the manganese-
generating operation has been shutdown.
Tronox Pigments also filed bankruptcy in 2009. The facility is in litigation with
Anadarko Petroleum Corporation, causing many of its operations to be shutdown. Given the
shutdown of the operation that generates manganese and ongoing litigation, the facility's
operations and discharges are not likely representative of other facilities in the category (U.S.
EPA, 2010).
8-4
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Section 8—Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 8-4. Manganese and Manganese Compound Discharges for Tronox Pigments, Inc.
Year of Discharge
Manganese and Manganese
Compound Discharge (lbs)
Manganese and Manganese
Compounds TW.PE
2005
466,000
32,800
2006
257,000
18,100
2007
282,000
19,900
2008
230,000
16,100
2009
167,000
11,700
2010
NR
NR
Sources: TRIReleases2005_v2; TRIReleases2006_vl; TRIReleases2008_v2; TRIReleases2009_v2; and Envirofacts.
NR - Not reported.
8.3.2 Tronox LLC
Tronox LLC in Hamilton, MS, is the second top manganese and manganese compound
discharging facility in the 2009 TRI database, with 165,000 pounds discharged. EPA contacted
the facility as part of the 2011 Annual Reviews and confirmed that the toxicity rankings
databases accurately quantify the manganese discharges. Tronox LLC stated that the manganese
discharges were higher than usual in 2009 due to unusually high stormwater runoff entering their
settling ponds, which Tronox LLC considered a process upset and not representative of normal
operating conditions (Freeze, 2011).
The facility contact also provided manganese discharge data for 2008 through 2010 and
confirmed that its titanium dioxide plant generates manganese-containing wastewater (Freeze,
2011). Table 8-5 presents the manganese discharges the facility provided, along with those listed
in the TRI database for the same period. The data confirm the site's information that the 2009
discharge is greater than in 2008 and 2010 because of the process upset. EPA concludes that the
increased manganese and manganese compound discharges for 2009 were a result of a process
upset and are not likely representative of other facilities in the category.
Table 8-5. Manganese and Manganese Compound Discharges for Tronox LLC
Year of Discharge
Facility Provided Manganese
and Manganese Compound
Discharge (lb)"
Manganese and Manganese Compound
Discharges in TRI Database
Discharge (lb)
TWPE
2008
90,400
89,400
6,300
2009
165,000
165,000
11,600
2010
124,000
124,000
8,730
Source: Facility contact (Freeze, 2011).
a Discharges are from outfalls 101 and 201. Outfall 101 carries cooling water and stormwater runoff; outfall 201
carries process water, sanitary water, and stormwater runoff from process areas.
8.4 Inorganic Chemicals Category Dioxin and Dioxin-Like Compound Discharges in
TRI
The second top pollutant in the 2009 TRI database is dioxin and dioxin-like compounds.
Table 8-6 presents the facilities that account for the dioxin and dioxin-like compound discharges
8-5
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Section 8—Inorganic Chemicals Manufacturing (40 CFR Part 415)
in the 2009 TRI database. Eighty-six percent of these discharges are from one facility, DuPont
Edgemoor.
Table 8-6. Dioxin and Dioxin-Like Compound Discharging Facilities
in the 2009 TRI Database
Facility Name
Facility
Location
Pollutant
TWPE
Facility Percent of Dioxin and
Dioxin-Like Compounds
Category TWPE
DuPont Edgemoor
Edgemoor, DE
11,800
86%
Remaining facilities reporting dioxin and
dioxin-like compound discharges3
NA
1,970
14%
Total
NA
13,800
100%
Source: TRIReleases2009_v2.
" There are six remaining facilities that have dioxin and dioxin-like compound discharges in the 2009 TRI
database, which account for 14 percent of the category's dioxin and dioxin-like compounds TRI TWPE.
NA: Not applicable.
Dioxin and dioxin-like compounds form during the chloride-ilmenite titanium dioxide
manufacturing process (U.S. EPA, 2006). The DuPont Edgemoor facility manufactures titanium
dioxide using the chloride-ilmenite process and indicated that discharges of dioxin and dioxin-
like compounds had decreased since the facility installed a "PBT Unit" in 2001 to remove
additional solids. Table 8-7 presents the dioxin and dioxin-like compound discharges for DuPont
Edgemoor for discharge years 2002 to 2009.
Table 8-7. Dioxin and Dioxin-Like Compound Discharges for DuPont Edgemoor
Year of Discharge
Dioxin and Dixon-Likc
Compound Discharge
(grams)
Dioxin and Dioxin-Like
Compounds TWF"
Dioxin and Dixon-Likc
Compounds TWPE
2002
13.6
2,021
60.5
2003
0.708
132,994
208
2004
0.283
250,244
156
2005
0.135
132,994
40
2006
0.48
288,398
305
2007
4.89
207,568
2,240
2008
0.57
37,219
46.8
2009
2.82
1,904,247
11,800
Sources: TRIReleases2002_v4; TRIReleases2003_v2; TRIReleases2004_v3; TRIReleases2005_v02;
TRIReleases2007_v2; TRIReleases2008_v3; and TRIReleases2009_v2.
a The dioxin and dioxin-like compounds class includes 17 individual congeners, each with its own toxic
weighting factor (TWF). Facilities can report the mass of each congener in a separate field (referred to as the
dioxin distribution). EPA uses the dioxin distribution to calculate a facility-specific TWF and TWPE. Because
the dioxin TWF is based on the congeners reported yearly by the facility, it is possible to have similar amounts
of dioxin and drastically different TWFs due to differences in the congener distribution.
EPA investigated whether the 2009 dioxin release estimate was based on measurements
of dioxin that are below detection limits. Often, to follow TRI guidance, facilities estimate their
8-6
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Section 8—Inorganic Chemicals Manufacturing (40 CFR Part 415)
releases using half the detection limit of a congener that was never detected. For EPA's toxicity
rankings analysis purposes, this can lead to an overestimation of TWPE.
EPA has monitored dioxin and dioxin-like compound discharges from DuPont Edgemoor
since 2006. EPA contacted the facility as part of the 2006 Annual Reviews to determine the
accuracy of the reported dioxin and dioxin-like compound discharges in the 2003 TRI (Wood,
2006); the facility had indeed used half the detection limit to estimate the load for TRI reporting
(U.S. EPA, 2006). Section 9.5 of the Technical Support Document for the 2006 Effluent
Guidelines Program Plan (U.S. EPA, 2006) presents EPA's findings from the 2006 Annual
Reviews.
To determine if the facility's reported 2009 dioxin load was based on non-detect values,
EPA compared the results to DuPont Edgemoor's 2003 results. Table 8-8 presents DuPont
Edgemoor's 2003 sampling results, extrapolated 2009 sampling results, and the EPA Method
1613B minimum level (U.S. EPA, 2004b). EPA used the facility's reported 2009 congener
distribution and the permit limit flow to extrapolate 2009 concentrations, also presented in Table
8-8. DuPont Edgemoor estimated its facility load based on monitoring data, as reported to the
2009 TRI; therefore, the estimated concentrations in Table 8-8 represent valid estimates of
DuPont's measurements.
As shown in Table 8-8, DuPont Edgemoor only detected one of the congeners above the
EPA Method 1613B minimum level in 2003: 1,2,3,4,6,7,8,9-OCDF. Based on the estimated
2009 concentrations, only two of the calculated 2009 concentrations are above the EPA Method
1613B minimum level: 1,2,3,4,6,7,8-HpCDF and 1,2,3,4,6,7,8,9-OCDD. Both of these
congeners are considered less toxic than most dioxin and dioxin-like congeners and are assigned
low TWF values. Table 8-8 shows that the amount of dioxin and dioxin-like concentrations used
for the 2009 TRI estimate are likely similar to the 2003 sampling results. That is, most likely
only one or two congeners were detected. When recalculated using only those congeners likely
detected, the load discharged decreases from 2.82 grams to 1.92 grams and the associated TWPE
decreases from 11,800 to 193. As with the 2003 discharges, the facility's discharges of dioxin
and dioxin-like compounds are likely below the EPA Method 1613B minimum level.
Further, DuPont Edgemoor's NPDES permit regulates the discharge of dioxins and
furans by both quantity and concentration permit limits for dioxin and dioxin-like compounds:
2.2 x 10"10 pounds per day toxic equivalency (TEQ)6 and 5.1 x 10"9 micrograms per liter TEQ
(DNREC, 2007a). The dioxin and dioxin-like compound permit limits are based on Delaware's
Surface Water Quality Standards (DNREC, 2007b). The permit further requires that DuPont
Edgemoor prepare a pollutant minimization plan for dioxin and dioxin-like compounds that will
locate pollutant sources and review process modifications, materials substitutions, treatment
technologies, best management practices, and/or facility procedures to identify options to reduce
discharges (DNREC, 2007a).
As in previous years, EPA concludes that additional study and analysis of dioxin and
dioxin-like discharges from DuPont Edgemoor is not necessary. DuPont Edgemoor has not
detected most congeners of dioxin and dioxin-like compounds, and the facility has likely never
6 TEQs are calculated values that allow for a comparison of the toxicity of different combinations of dioxin and
dioxin-like compounds using a toxic equivalent factor. This factor is the ratio of the toxicity of one of the
compounds to the toxicity of the two most toxic compounds, 2,3,7,8-TCDD and 1,2,3,7,8-PeCDD.
8-7
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Section 8—Inorganic Chemicals Manufacturing (40 CFR Part 415)
detected concentrations above the EPA Method 1613B minimum level. Further, the facility's
NPDES permit requires them to continue to develop better treatment of dioxin and dioxin-like
compounds, and the discharge is already controlled. Finally, DuPont Edgemoor is one of the few
remaining U.S. facilities that manufactures titanium dioxide. Its dioxin discharges do not
represent discharges across the category as a whole.
Table 8-8. 2009 Concentrations of Dioxin and Dioxin-Like Compounds in Effluent
Samples (pg/L) From DuPont Edgemoor and EPA Method 1613B Minimum Levels
1613B ML
2003"
2009b
Congener
TWF
(Pg/L)
(Pg/L)
(Pg/L)
Flow (MGY)C
1,898
Polychlorinated dibenzo-p-furans (CDFs)
2,3,7,8-TCDF
43,819,553.68
10
ND
ND
1,2,3,7,8-PeCDF
7,632,640
50
ND
ND
2,3,4,7,8-PeCDF
557,312,000
50
ND
ND
1,2,3,4,7,8-HxCDF
5,760,000
50
2.675
24.8
1,2,3,6,7,8-HxCDF
14,109,440
50
ND
40
2,3,4,6,7,8-HxCDF
51,204,160
50
ND
0.445
1,2,3,7,8,9-HxCDF
47,308,800
50
ND
ND
1,2,3,4,6,7,8-HpCDF
85,760
50
18.27
132d
1,2,3,4,7,8,9-HpCDF
3,033,984
50
ND
0.682
1,2,3,4,6,7,8,9-OCDF
2,020.96
100
101.24d
52
Polychlorinated dibenzo-p-dioxins (CDDs)
2,3,7,8-TCDD
703,584,000
10
ND
ND
1,2,3,7,8-PeCDD
692,928,000
50
ND
ND
1,2,3,4,7,8-HxCDD
23,498,240
50
ND
ND
1,2,3,6,7,8-HxCDD
9,556,480
50
ND
ND
1,2,3,7,8,9-HxCDD
10,595,840
50
ND
0.0835
1,2,3,4,6,7,8-HpCDD
411,136
50
ND
6.32
1,2,3,4,6,7,8,9-OCDD
6,585.6
100
7.335
136d
Sources: TRIReleases2009_v2; Technical Support Document for the 2006 Effluent Guidelines Program Plan (U.S.
EPA, 2006); facility contact (Wood, 2006); facility permit (DNREC, 2007a); and Method 1613: Tetra- Through
Octa-Chlorinated Dioxins and Furans by Isotope DilutionHRGC/HRMS (U.S. EPA, 2004b).
a Concentrations discharged from outfall 001, effluent from the wastewater treatment system (DNREC, 2007a).
b Concentrations calculated using the facility's reported congener distribution in 2009 and the permit limit flow.
0 Facility permit flow for outfall 001.
d Concentrations greater than Method 1613B ML.
ML: Minimum level established for EPA Method 1613B (U.S. EPA, 2004b).
ND: No data.
8.5 Inorganic Chemicals Category Conclusions
The estimated toxicity of the Inorganic Chemicals Category discharges resulted from
manganese and manganese compounds and dioxin and dioxin-like compounds. Data collected
for the 2011 Annual Reviews demonstrated that wastewater discharge characteristics for this
-------
Section 8—Inorganic Chemicals Manufacturing (40 CFR Part 415)
category are consistent with discharges from prior years. Using data collected for the 2011
Annual Reviews, EPA concludes the following:
• Two facilities, Tronox Pigments, Inc. (Savannah, GA) and Tronox LLC
(Hamilton, MS), account for 65 percent of the category's 2009 TRI discharges of
manganese and manganese compounds. Both facilities are titanium dioxide
manufacturers and confirmed that the 2011 toxicity rankings databases accurately
estimate their manganese and manganese compound discharges (Blackmon, 2011;
Freeze, 2011). However, for both facilities, the 2009 discharge is not
representative of typical discharges from titanium dioxide manufacturing:
— Tronox Pigments shut down its titanium dioxide process in August 2009;
the facility expects this will result in a reduction in manganese and
manganese compound discharges.
— Tronox LLC's high 2009 manganese discharges resulted from process
upsets.
These facilities' discharges are not likely representative of other facilities in the
category. For this reason, EPA is not identifying these discharges as a priority
hazard at this time.
• DuPont Edgemoor accounts for 86 percent of the category's 2009 TRI discharges
of dioxin and dioxin-like compounds. The facility manufactures titanium dioxide
using the chloride-ilmenite process, which produces dioxin and dioxin-like
compounds. Using the facility's reported 2009 congener distribution and the
permit limit flow, EPA determined only two of the congeners were above the
EPA Method 1613B minimum level: 1,2,3,4,6,7,8-HpCDF and 1,2,3,4,6,7,8,9-
OCDD. These two congeners have low toxicity compared to other congeners, and
therefore are assigned low TWFs. DuPont Edgemoor has not detected most
congeners of dioxin and dioxin-like compounds, and the facility has likely never
detected concentrations above the EPA Method 1613B minimum level. DuPont
Edgemoor's permit also includes dioxin and dioxin-like compound limits and
requirements to develop a pollutant minimization plan, controlling the discharge.
As found in previous years, additional study and analysis of dioxin discharges in
the Inorganic Chemicals Category is not warranted at this time.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
8.6 Inorganic Chemicals Category References
1. Blackmon, Joseph. 2011. Telephone and Email Communication Between Joseph
Blackmon, Tronox Pigments, Inc., and Kimberly Landick, Eastern Research Group, Inc.,
8-9
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Section 8—Inorganic Chemicals Manufacturing (40 CFR Part 415)
Re: Request for 2009 TRI Data Clarification. (January 28). EPA-HQ-OW-2010-0824
DCN 07583.
2. DNREC. 2007a. Delaware Department of Natural Resources and Environmental Control.
NPDES Permit for E.I. DuPont de Nemours & Company, Edgemoor, DE. (January 1).
EPA-HQ-OW-2010-0824 DCN 07584.
3. DNREC. 2007b. Delaware Department of Natural Resources and Environmental Control.
NPDES Permit Fact Sheet: E.I. DuPont de Nemours & Company, Edgemoor, DE.
(January 1). EPA-HQ-OW-2010-0824 DCN 07585.
4. Freeze, Terry. 2011. Telephone and Email communication Between Terry Freeze, Tronox
LLC, and Kimberly Landick, Eastern Research Group, Inc., Re: Request for 2009 TRI
Data Clarification. (January 28). EPA-HQ-OW-2010-0824 DCN 07586.
5. Tronox. 2007. Tronox Incorporated. Savannah, Georgia, U.S. Available online at:
http://www.tronox.com/about/operations/savannah.htm. EPA-HQ-OW-2010-0824 DCN
07587.
6. U.S. EPA. 2004a. Technical Support Document for the 2004 Effluent Guidelines
Program Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-
0074-1346 through 1352.
7. U.S. EPA. 2004b. Method 1613: Tetra- Through Octa-Chlorinated Dioxins and Furans by
Isotope Dilution HRGC/HRMS. Washington, D.C. (October). EPA-HQ-OW-2004-0032-
2653.
8. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004-
0032-0053.
9. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
10. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
11. U. S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-0517-0515.
12. U.S. EPA. 2010. Tronox Incorporated Bankruptcy Settlement. (November 24). Available
online at:
http://www.epa.gov/compliance/resources/cases/cleanup/cercla/tronox/index.html. Date
accessed: June 2011. EPA-HQ-OW-2010-0824 DCN 07588.
8-10
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Section 8—Inorganic Chemicals Manufacturing (40 CFR Part 415)
13. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
14. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
15. Wood, Kenneth. 2006. E-mail Correspondence Between Kenneth Wood, Du Pont, and
Eleanor Ku Codding, Eastern Research Group, Inc. Re: Responses to Remaining
Questions from your Email of February 2nd for DeLisle and EdgeMoor Facilities.
(February 13). EPA-HQ-OW-2004-0032-2347.
8-11
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
9. Iron and Steel Manufacturing (40 CFR Part 420)
EPA selected the Iron and Steel Manufacturing Category for preliminary review because
it ranks high, in terms of toxic-weighted pound equivalent (TWPE), in the point source category
rankings. This section summarizes the results of the 2011 Annual Reviews, which focused on
discharges of cyanide, chlorine, chromium, fluoride, and aluminum due to their high TWPE
relative to the other pollutants in the Iron and Steel Manufacturing Category.
9.1 Iron and Steel Manufacturing Category Background
This subsection provides the background on the Iron and Steel Manufacturing Category,
including a brief profile of the iron and steel manufacturing industry and background on 40 CFR
Part 420.
9.1.1 Iron and Steel Manufacturing Industry Profile
The iron and steel manufacturing industry includes facilities whose production operations
discharge and introduce pollutants into surface water as well as publicly owned treatment works
(POTWs).
EPA considered the following seven industrial categories as part of the Iron and Steel
Manufacturing Category, encompassing seven North American Industry Classification System
(NAICS) codes and four Standard Industrial Classification (SIC) codes:
• NAICS 331111: Iron and Steel Mills (including Cokemaking Facilities)
• NAICS 331210: Iron and Steel Pipe and Tube Manufacturing
• NAICS 331221: Rolled Steel Shape Manufacturing (Blast Furnace, Steel Works,
and Rolling Mills)
• NAICS 331222: Steel Wire Drawing and Steel Nails
• The steelmaking facilities within the following NAICS Codes:
— NAICS 332618: Other Fabricated Wire Product Manufacturing
— NAICS 332112: Nonferrous Forging (Blast Furnace, Steel Works, and
Rolling Mills)
— NAICS 332813: Electroplating, Plating, Polishing, Anodizing, and
Coloring (Cold Rolled Steel)
The PCS and ICIS-NPDES systems report facilities by SIC code and the U.S. Economic
Census, and Toxics Release Inventory (TRI) report data by NAICS code. Because of this
discrepancy, EPA reclassified the 2009 discharge monitoring report (DMR) data by the
equivalent NAICS code. Table 9-1 lists the number of facilities from the U.S. Economic Census
and the toxicity rankings databases for the seven industrial categories with operations in the Iron
and Steel Manufacturing Category. The U.S. Economic Census includes more facilities than the
DMR toxicity rankings database: facilities may not meet TRI-reporting thresholds, facilities may
9-1
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
discharge to a POTW, and some facilities in the U.S. Economic Census are distributors or sales
facilities, not manufacturers.
Table 9-1. Number of Iron and Steel Manufacturing Facilities
2007 U.S. Economic Census
2009 DMRa
2009 TRIb
Total
Minor
Major
Total
Indirect
Direct
Both
4,949
161
76
85
228
52
125
51
Sources: U.S. Economic Census (2007); TRIReleases2009jv2; and DAdRLoads2009_v2.
a Minor facility discharges may or may not adversely impact receiving water if not controlled.
Major facility discharges have the capability to impact receiving waters if not controlled.
b Indirect facilities discharge to POTWs.
Direct facilities discharge directly to surface water.
9.1.2 40 CFR Part 420
EPA first promulgated effluent limitations guidelines (ELGs) for the Iron and Steel
Manufacturing Category (40 CFR Part 420) in May 1982 (47 FR 23258) and last amended them
in April 2002 (67 FR 64215). This category consists of 13 subcategories that apply to the
manufacture of products and product groups, as shown in Table 9-2 with corresponding
applicability.
9-2
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
Table 9-2. Applicability and Regulated Pollutants for the Iron and Steel Manufacturing Category
Regulated Pollutants
Subpart
Subcategory
Title
Subcategory Applicability
Ammonia as N
=
2
a
3
o
N
§
«
Chromium
Cyanide
Lead
Naphthalene
Nickel
Oil and Grease
n
o.
Phenols (4AAP)
Tetrachloroethylene
Total Residual
Chlorine
Total Suspended
Solids
Zinc
2, 3, 7, 8- TCDF
A
Cokemaking
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
byproduct and other cokemaking operations.
X
X
X
X
X
X
X
X
B
Sintering
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
sintering operations conducted by heating iron-
bearing wastes together with fine iron ore,
limestone, and coke fines in an ignition furnace
to produce an agglomerate for charging to the
blast furnace.
X
X
X
X
X
X
X
X
X
X
C
Ironmaking
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
ironmaking operations in which iron ore is
reduced to molten iron in a blast furnace.
X
X
X
X
X
X
X
X
X
D
Steelmaking
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
steelmaking operations conducted in basic
oxygen and electric arc furnaces.
X
X
X
X
E
Vacuum
Degassing
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
vacuum degassing operations conducted by
applying a vacuum to molten steel.
X
X
X
X
F
Continuous
Casting
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
continuous casting of molten steel into
intermediate or semi-finished steel products
through water cooled molds.
X
X
X
X
X
9-3
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
Table 9-2. Applicability and Regulated Pollutants for the Iron and Steel Manufacturing Category
Regulated Pollutants
Subpart
Subcategory
Title
Subcategory Applicability
Ammonia as N
=
2
a
3
o
N
g
CO
Chromium
Cyanide
Lead
Naphthalene
Nickel
Oil and Grease
n
o.
Phenols (4AAP)
Tetrachloroethylene
Total Residual
Chlorine
Total Suspended
Solids
Zinc
2, 3, 7, 8- TCDF
G
Hot Forming
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from hot
forming operations conducted in primary,
section, flat, and pipe and tube mills.
X
X
X
H
Salt Bath
Descaling
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
oxidizing and reducing salt bath descaling
operations.
X
X
X
X
X
I
Acid
Pickling
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
sulfuric acid, hydrochloric acid, or combination
acid pickling operations.
X
X
X
X
X
X
X
J
Cold
Forming
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
cold rolling and cold working pipe and tube
operations in which unheated steel is passed
through rolls or otherwise processed.
X
X
X
X
X
X
X
X
X
K
Alkaline
Cleaning
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
operations in which steel and steel products are
immersed in alkaline cleaning baths to remove
mineral and animal fats or oils from the steel,
and those rinsing operations which follow
immersion.
X
X
X
L
Hot Coating
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
operations in which steel is coated with zinc,
terne metal, or other metals by the hot dip
process, and associated rinsing operations.
X
X
X
X
X
X
9-4
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
Table 9-2. Applicability and Regulated Pollutants for the Iron and Steel Manufacturing Category
Regulated Pollutants
Subpart
Subcategory
Title
Subcategory Applicability
Ammonia as N
=
2
a
3
o
N
g
CO
Chromium
Cyanide
Lead
Naphthalene
Nickel
Oil and Grease
n
o.
Phenols (4AAP)
Tetrachloroethylene
Total Residual
Chlorine
Total Suspended
Solids
Zinc
2, 3, 7, 8- TCDF
M
Other
Operations
Discharges to waters of the U.S. and the
introduction of pollutants into a POTW from
production of direct-reduced iron and from
briquetting and forging operations.
X
X
X
9-5
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
9.2 Iron and Steel Manufacturing Category 2011 Toxicity Rankings Analysis
Table 9-3 compares the toxicity rankings analysis results for the Iron and Steel
Manufacturing Category from the 2009 through 2011 Annual Reviews. The combined DMR and
TRITWPE has decreased from discharge years 2008 to 2009. The estimated 2009 DMR TWPE
accounts for approximately 58 percent of the combined 2009 DMR and TRI TWPE.
Table 9-3. Iron and Steel Manufacturing Category TRI and DMR Discharges for the 2009
Through 2011 Toxicity Rankings Analyses
Year of Discharge
Year of Review
Iron and Steel Manufacturing Category
TRI TWPE'1
DMR TWPEb
Total TWPE
2007
2009
104,000
730,000
834,000
2008
2010
111,000
616,000
727,000
2009
2011
96,200
134,000
230,000
Sources: TRI Releases 2007 v2, DATRLoads2007_v4, TRIReleases2008_v3, DMRLoads2008_v3;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2007 include only major dischargers. DMR 2008 data include both minor and major
dischargers.
9.3 Iron and Steel Manufacturing Category Pollutants of Concern
EPA's review of the Iron and Steel Manufacturing Category focused on the 2009 DMR
discharges because the 2009 DMR data dominate the category's combined TWPE. Table 9-4
lists the five pollutants with the highest TWPE based on results from the 2011 Annual Reviews
(DMRLoads2009 v2). The top five DMR-reported pollutants in 2009 contribute more than 61
percent of the total category TWPE.
Table 9-4. Iron and Steel Manufacturing Category Top DMR Pollutants
Pollutant
2009 DMR Data'1
Rank
Number of Facilities
Reporting Pollutant
TWPE
Cyanide
1
24
27,400
Chlorine
2
29
17,200
Chromium
3
35
16,000
Fluoride
4
10
11,500
Aluminum
5
16
9,660
Iron and Steel Manufacturing
Category Total
NA
122b
134,000
Source: DMRLoads2009_v2.
a DMR data include major and minor dischargers.
b Number of facilities reporting a TWPE of greater than zero.
EPA's additional review for the 2009 DMR database pollutants of concern, cyanide,
chlorine, chromium, fluoride, and aluminum, is presented in the following subsections. EPA did
9-6
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
not investigate the other top pollutants as part of the 2011 Annual Reviews because they account
for a minority (39 percent) of the 2009 Iron and Steel Manufacturing Category DMR TWPE.
9.4 Iron and Steel Manufacturing Category Cyanide Discharges in DMR
Cyanide discharges in the 2009 DMR database account for 21 percent of the total DMR
TWPE. Table 9-5 presents the cyanide dischargers in the 2009 DMR database. Discharges of
cyanide from two facilities account for over 56 percent of the category's cyanide DMR TWPE.
As a result, EPA focused its review of cyanide discharges on the top two facilities.
Table 9-5. Iron and Steel Manufacturing Category Cyanide
Dischargers in the 2009 DMR Database
Facility Name
Location
Cyanide Pounds
Discharged
Cyanide TWPE
Facility Percent
of Cyanide
Category TWPE
US Steel Corp.-Clairton Works
Clairton, PA
9,100
10,100
37%
Mountain State Carbon, LLC
Follansbee, WV
4,770
5,290
19%
Remaining facilities reporting cyanide discharges3
10,800
12,000
44%
Total
24,700
27,400
100%
Source: DMRLoads2009_v2.
" There are 18 remaining facilities that have cyanide discharges in the 2009 DMR database, which account for 44
percent of the category's cyanide DMR TWPE.
Both of the top two facilities are cokemaking plants: plants that produce carbon-coke
from coal for steelmaking. Cokemaking operations generate wastewater containing cyanide as
part of the byproduct recovery process. Currently, there are 19 cokemaking plants in the United
States. Table 9-6 lists U.S. coke plants operating in 2011, their locations, and their range of
cyanide concentrations in 2009. As shown, Mountain State Carbon has the highest cyanide
concentration range.
Table 9-6. Operating U.S. Coke Plants as of September 1, 2011
State
Facility Name
City
Facility Range of 2009
Cyanide Concentrations
(mg/L)
Alabama
ABC Coke (Drummond Company, Inc.)
Tarrant
0.282-4.62
Walter Coke
Birmingham
0.012-1.01
Illinois
U.S. Steel
Granite City
0.005(ND)-0.03
Gateway Energy & Coke Company
Granite City
NR
Indiana
Indiana Harbor Coke Company
East Chicago
0.003(ND)-0.024
ArcelorMittal
Burns Harbor
0.002(ND)-0.004
U.S. Steel
Gary
NR
Michigan
DTE Energy Services
Ecorse
NR
New York
Tonawanda Coke Corp.
Tonawanda
NR
Ohio
AK Steel Corp.
Middletown
NR
Middletown Coke Co.
Middletown
NR
ArcelorMittal
Warren
NR
SunCoke Co.
Haverhill
NR
9-7
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
Table 9-6. Operating U.S. Coke Plants as of September 1, 2011
State
Facility Name
City
Facility Range of 2009
Cyanide Concentrations
(mg/L)
Pennsylvania
Erie Coke Corp.
Erie
NR
ArcelorMittal
Monessen
NR
DTE Energy Services
Pittsburgh
1-2
U.S. Steel
Clairton
0.789-2.64
Virginia
Jewell Coke and Coal
Vansant
NR
West Virginia
Mountain State Carbon
Follansbee
0.62-6.2
Sources: ACCCI (2011), DMR Loadings Tool.
NR: Not reported.
9.4.1 U.S. Steel Corporation-Clairton Works
U.S. Steel Corporation-Clairton Works (U.S. Steel) in Clairton, PA, discharges cyanide
from its outfall 183 in wastewater from cokemaking. Table 9-7 presents U.S. Steel's 2009
monthly cyanide and flow discharge data in the DMR Loadings Tool for outfall 183. The
outfall's cyanide limits as stated in the facility permit are 5.5 milligrams per liter (mg/L) or 53.5
kilograms per day (kg/day) (PADEP, 2006). As shown in Table 9-7, the facility's discharge data
n
do not exceed permit limits and are below treatable levels. Their relatively high cyanide TWPE
results from their large flow, as they historically have been the top coke producer in the U.S.
(U.S. EPA, 2002).
Table 9-7. U.S. Steel's Outfall 183 2009 Monthly Cyanide and Flow Discharge Data
Monitoring Period
Date
DMR Loadings Tool
Average Cyanide
Discharge (kg/day)
DMR Loadings Tool
Average Flow (MGD)
DMR Loadings Tool Average
Cyanide Concentrations
(mg/L)
31-Jan-09
13.85
2.53
1.457
28-Feb-09
13.68
2.56
1.406
31-Mar-09
12.09
2.49
1.288
30-Apr-09
10.58
2.17
1.255
31-May-09
6.48
2
0.855
30-Jun-09
6.32
2.04
0.789
31-Jul-09
8.89
2.21
1.079
31-Aug-09
9.39
2.16
1.167
30-Sep-09
7.41
2.25
0.871
31-Oct-09
11.24
2.16
1.35
30-Nov-09
11.78
2.37
1.46
31-Dec-09
23.95
2.38
2.643
Source: DMR Loadings Tool.
7 For the most recent 2002 effluent guideline revision, EPA established production-based limits based on long-term
average (LTA) for best available technology economically achievable (BAT) for cyanide at 2.965 mg/L, and a
variability factor of 1.49. The Clairton cyanide concentrations are less than this estimated treatability concentration.
9-8
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
9.4.2 Mountain State Carbon, LLC
Mountain State Carbon, LLC, in Follansbee, WV, discharges cyanide from its outfall
205. Mountain State Carbon discharges treated process wastewater, ground water, and
stormwater from the biological treatment plant through this outfall. Table 9-8 presents Mountain
State Carbon's 2009 monthly cyanide and flow discharge data in the DMR Loadings Tool for
outfall 205. A missing decimal point in the May 2009 concentration was identified and corrected.
The facility's permit states that the cyanide limit for outfall 205 is 11.1 kg/day (WVDEP, 2008).
As shown in Table 9-8, the November 2009 quantity exceeds the mass-based facility permit
limit.
Table 9-8. Mountain State Carbon's Outfall 205 2009 Monthly
Cyanide and Flow Discharge Data
Monitoring Period
Date
DMR Loadings Tool
Average Cyanide
Discharge (kg/dav)
DMR Loadings Tool
Average Flow (MGD)
DMR Loadings Tool Average
Cyanide Concentrations
(mg/L)
31-Jan-09
7.07
0.736
2.5
28-Feb-09
6.26
0.713
2.3
31-Mar-09
5.53
0.743
1.9
30-Apr-09
6.08
0.693
2.4
31-May-09
5.44
0.683
2.2
30-Jun-09
5.26
0.0667
2.1
31-Jul-09
4.35
0.696
1.7
31-Aug-09
3.13
0.664
1.2
30-Sep-09
1.91
0.662
0.76
31-Oct-09
1.65
0.69
0.62
30-Nov-09
18.41
0.761
6.2
31-Dec-09
6.30
0.801
2.3
Source: DMR Loadings Tool.
For the most recent 2002 effluent guideline revision, EPA established production-based
limits based on long-term average (LTA) for best available technology economically achievable
(BAT) for cyanide at 2.965 mg/L. As shown in Table 9-8, Mountain State Carbon's cyanide
discharges exceed the treatable level of cyanide for one month. EPA concludes that this one
outlier month resulted in a significant amount of TWPE.
EPA further reviewed discharge data for this facility to see how often they exceeded their
permit limits and found that the facility was not in compliance during eleven months in 2010.
However, the compliance issues appear to be resolved in 2011. Therefore, EPA will continue to
review this facility's cyanide discharges in future years of review, but these discharges are not
representative of typical cokemaking facility discharges.
9.5 Iron and Steel Manufacturing Category Chlorine Discharges in DMR
Chlorine discharges in the 2009 DMR database account for 13 percent of the total DMR
TWPE. Table 9-9 presents the chlorine dischargers in the 2009 DMR database. Discharges of
9-9
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
chlorine from one facility account for over 51 percent of the category's chlorine DMR TWPE.
EPA focused its review of chlorine discharges on this top facility.
Table 9-9. Iron and Steel Manufacturing Category Chlorine
Dischargers in the 2009 DMR Database
Facility Name
Location
Chlorine
Pounds
Discharged
Chlorine TWPE
Facility Percent
of Chlorine
Category TWPE
ISG Sparrows Point, Inc.
Sparrows Point, MD
17,400
8,690
51%
Remaining facilities reporting chlorine discharges3
17,000
8,500
49%
Total
34,400
17,200
100%
Source: DMRLoads2009_v2.
a There are 28 remaining facilities that have chlorine discharges in the 2009 DMR database, which account for 49
percent of the category's chlorine DMR TWPE.
9.5.1 ISG Sparrows Point, Inc.
ISG Sparrows Point, Inc., in Sparrows Point, MD, discharges chlorine from its outfall
001. ISG Sparrows Point discharges primarily noncontact cooling water used for condenser
cooling at Pennwood Power Station through this outfall. Table 9-10 presents ISG Sparrows
Point's 2009 monthly chlorine and flow discharge data in the DMR Loadings Tool for outfall
001. As shown in Table 9-10 all of the facility's 2009 chlorine discharges are below the permit
limit of 0.2 mg/L.
Table 9-10. ISG Sparrows Point's Outfall 001 2009 Monthly
Chlorine Discharge and Flow Data
Monitoring Period
Date
DMR Loadings Tool
Chlorine
Concentration (mg/L)
Facility Permit-Enforceable
Compliance Level Limit—
Daily Maximum (mg/L)
DMR Loadings Tool
Average Flow (MGD)
31-Jan-09
0.1
0.2
7
28-Feb-09
0
0.2
78
31-Mar-09
0
0.2
188
30-Apr-09
0.04
0.2
145
31-May-09
0
0.2
143
30-Jun-09
0
0.2
159
31-Jul-09
0
0.2
204
31-Aug-09
0.1
0.2
223
30-Sep-09
0.1
0.2
176
31-Oct-09
0
0.2
171
30-Nov-09
0.09
0.2
158
31-Dec-09
0
0.2
204
Sources: DMR Loadings Tool and facility permit (MDE, 2001).
As part of the 2011 Annual Reviews, EPA contacted the facility about its 2009 chlorine
concentrations and flows from outfall 001. The facility contact confirmed that all 2009 chlorine
9-10
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
concentrations were below the permit limit and that the facility had never had a permitting issue
with chlorine. The facility contact also stated that the flows are large for outfall 001 because it
carries water from the non-contact cooling system for power generation for the onsite power
plant (Becker, 2011).
EPA identified an error in how DMRLoads vO2 estimated the facility's discharges. The
DMR database automatically calculates the load based on 24 hours a day of discharge. Because
the flow from outfall 001 is non-contact cooling water from a power station, the facility is only
allowed to discharge chlorine two hours per day. Therefore, the DMR database overestimated the
chlorine load for this facility. With two hours of discharge per day instead of 24, ISG Sparrow's
Chlorine TWPE decreases from 8,690 to 1,320.
9.6 Iron and Steel Manufacturing Category Chromium Discharges in DMR
Chromium discharges in the 2009 DMR database account for 12 percent of the total
DMR TWPE. Table 9-11 presents the chromium dischargers in the 2009 DMR database.
Discharges of chromium from one facility account for over 98 percent of the category's
chromium DMR TWPE. Accordingly, EPA focused its review of chromium discharges on that
facility.
Table 9-11. Iron and Steel Manufacturing Category Chromium
Dischargers in the 2009 DMR Database
Facility Name
Location
Chromium
Pounds
Discharged
Chromium
TWPE
Facility Percent
of Chromium
Category TWPE
Arcelormittal Weirton Inc.
Weirton, WV
223,000
15,600
98%
Remaining facilities reporting chromium discharges3
4,520
316
2%
Total
228,000
16,000
100%
Source: DMRLoads2009_v2.
a There are 34 remaining facilities that have chromium discharges in the 2009 DMR database, which account for
2 percent of the category's chromium DMR TWPE.
9.6.1 Arcelormittal Weirton Inc.
Arcelormittal Weirton Inc. in Weirton, WV, discharges chromium from three outfalls:
003, 004, and 203. Outfall 203 is an internal outfall to outfall 003, through which Arcelormittal
Weirton discharges cooling water, stormwater runoff and process water. Table 9-12 presents
chromium discharge data for outfalls 003, 004, and 203 for 2009. As part of the 2011 Annual
Reviews, EPA contacted the facility to confirm these discharges; the facility contact confirmed
the discharges as listed in the table (Minda, 2011). The facility's permit does not set limits for
chromium outfall 203, though it does require monitoring. For outfall 003, the permit limits daily
maximum discharge to 2.05 mg/L and monthly average discharge to 0.81 mg/L. Outfall 003 does
not exceed these limits.
The facility contact also confirmed that outfall 203 is an internal outfall to outfall 003,
with water from the former undergoing additional treatment for chromium to meet the latter's
discharge limits (Minda, 2011). Therefore, discharges from outfall 203 should be removed from
9-11
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
the database as double-counts, since they are also part of the discharges from outfall 003. With
this correction, Arcelormittal Weirton's TWPE includes discharges from outfall 003 and 004 and
decreases to 147.
Table 9-12. Arcelormittal Weirton's 2009 Chromium Discharge and Flow Data
Outfall
DMR Loadings Tool
Average Chromium
Concentration (mg/L)
DMR Loadings
Tool Average Flow
(MGD)
Total Outfall
Chromium Pounds
Discharged
Total Outfall
Chromium TWPE
003
0.143
8.07
2,080
145
004
0.00375
2.98
24.4
1.70
203
107
1.03
221,000 a
15,500
Source: DMR Loadings Tool.
a Outfall 203 is an internal outfall. Outfall 203 undergoes additional treatment for chromium prior to discharging
to Outfall 003 due to permit limitations (Minda, 2011).
9.7 Iron and Steel Manufacturing Category Fluoride Discharges in DMR
Fluoride discharges in the 2009 DMR database account for 9 percent of the total DMR
TWPE. Table 9-13 presents the fluoride dischargers in the 2009 DMR database. Discharges of
fluoride from one facility account for 51 percent of the category's fluoride DMR TWPE.
Accordingly, EPA focused its review of fluoride discharges on this top facility.
Table 9-13. Iron and Steel Manufacturing Category Fluoride
Dischargers in the 2009 DMR Database
Facility Name
Location
Fluoride
Pounds
Discharged
Fluoride TWPE
Facility Percent
of Fluoride
Category TWPE
Arcelormittal Weirton Inc.
Weirton, WV
194,000
5,810
51%
Remaining facilities reporting fluoride discharges3
189,000
5,660
49%
Total
382,000
11,500
100%
Source: DMRLoads2009_v2.
a There are nine remaining facilities that have fluoride discharges in the 2009 DMR database, which account for
49 percent of the category's fluoride DMR TWPE.
9.7.1 Arcelormittal Weirton Inc.
Arcelormittal Weirton Inc. in Weirton, WV, discharges fluoride from its outfall 003.
Arcelormittal Weirton discharges cooling water, storm water runoff, and process water through
outfall 003. The facility's permit requires monitoring of fluoride discharges from outfall 003 but
does not set fluoride limits (Minda, 2011). The Iron and Steel Manufacturing Category ELG does
not regulate fluoride.
Table 9-14 presents the facility's fluoride discharge data for 2009. The concentrations
ranged from 5.6 mg/L to 14.8 mg/L. EPA determined that current technologies are achieving
effluent fluoride concentrations between 2 mg/L and 15 mg/L (WC&E, 2006; Ionics, n.d.; GCIP,
2002).
9-12
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
Table 9-14. Arcelormittal Weirton's Outfall 003 2009 Monthly
Fluoride Discharge and Flow Data
Monitoring Period Date
DMR Loadings Tool Fluoride
Concentration (mg/L)
DMR Loadings Tool Average Flow
(MGD)
31-Mar-09
10.3
6.62
30-Jun-09
13.1
10.2
30-Sep-09
14.8
10.3
31-Dec-09
5.6
5.8
Source: DMR Loadings Tool.
9.8 Iron and Steel Manufacturing Category Aluminum Discharges in DMR
Aluminum discharges in the 2009 DMR database account for 7 percent of the total DMR
TWPE. Table 9-15 presents the aluminum dischargers in the 2009 DMR database. Discharges of
aluminum from three facilities account for over 64 percent of the category's aluminum DMR
TWPE. Accordingly, EPA focused its review of aluminum discharges on these facilities. All
three discharge storm water; for two of them, EPA determined that the storm water contacts either
process areas, scrap storage, or finished product.
Table 9-15. Iron and Steel Manufacturing Category Aluminum
Dischargers in the 2009 DMR Database
Facility Name
Location
Aluminum
Pounds
Discharged
Aluminum
TWPE
Facility Percent
of Aluminum
Category TWPE
Ipsco Tubulars (KY) Inc. Wilder
Campbell County, KY
44,600
2,680
28%
Nucor Steel Tuscaloosa Inc.
Tuscaloosa, AL
32,600
1,960
20%
Nucor Steel Decatur, LLC
Decatur, AL
26,300
1,580
16%
Remaining facilities reporting aluminum discharges3
57,400
3,440
36%
Total
161,000
9,660
100%
Source: DMRLoads2009_v2.
a There are 13 remaining facilities that have aluminum discharges in the 2009 DMR database, which account for
36 percent of the category's aluminum DMR TWPE.
9.8.1 Ipsco Tubulars (KY) Inc. Wilder
Ipsco Tubulars Inc. in Campbell County, KY, discharges aluminum from its outfall 003,
which carries untreated stormwater runoff. Table 9-16 presents Ipsco Tubulars' 2009 monthly
aluminum and flow discharge data in the DMR Loadings Tool for outfall 003. As shown in the
table, the concentration for February 2009 is two orders of magnitude larger than the
concentrations for other months.
9-13
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
Table 9-16. Ipsco Tubulars's Outfall 003 2009 Monthly Aluminum
Discharge and Flow Data
.Monitoring Period Date
DMR Loadings Tool Aluminum
Concentration (mg/L)
DMR Loadings Tool Average Flow
(MGD)
31-Jan-09
5.51
0.73
28-Feb-09
182
0.73
31-Mar-09
8.25
0.34
30-Apr-09
3.84
0.34
31-May-09
13.5
0.34
30-Jun-09
5.87
0.34
31-Jul-09
2.36
0.34
31-Aug-09
1.45
0.34
30-Sep-09
5.78
0.34
31-Oct-09
1.4
0.73
30-Nov-09
2.32
0.34
31-Dec-09
3.04
0.34
Source: DMR Loadings Tool.
As part of the 2011 Annual Reviews, EPA contacted the facility about its 2009 aluminum
concentrations and flows from outfall 003. The facility contact (McDaniel, 2011) confirmed that
the data were correct, and also stated that an incident affected outfall 003 during February 2009,
causing high concentrations of oil and grease. The incident affected all parameters in the samples
taken on February 11, 2009, but by re-sampling on February 27, 2009, the oil and grease value
(along with the rest of the parameters) was within permit limits. This month was an anomaly in
the data for this outfall; the facility has experienced nothing similar since February 2009. The
incident's cause was never identified.
As shown in Table 9-16, in 2009 the facility's mean effluent aluminum concentration was
19.6 mg/L for outfall 003 (untreated stormwater). In the 2002 rulemaking, EPA established
production-based limitations for aluminum for steelmaking, based on two-stage metals
precipitation as BAT, which achieved an LTA of 0.229 mg/L for aluminum. The facility's mean
discharge concentration, 19.6 mg/L, is higher than this treatable level. Even excluding the
February 2009 outlier in Table 9-16, the resulting mean concentration, 4.85 mg/L, is still higher
than this treatable level. For these reasons, EPA is considering facility-specific permitting and
compliance support to address this facility's untreated stormwater discharge.
9.8.2 Nucor Steel Tuscaloosa Inc.
Nucor Steel in Tuscaaloosa, AL, discharges aluminum from its outfall 001. Outfall 001
discharges "non-contact cooling water from melting, casting, rolling, and electrical substation
operations and storm water associated with employee parking areas, semi-finished and finished
product storage, and steel mill operations" (ADEM, 2007a). Table 9-17 presents Nucor Steel
Tuscaloosa's 2009 aluminum and flow discharge data in the DMR Loadings Tool for outfall 001.
9-14
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
Table 9-17. Nucor Steel's Outfall 001 Tuscaloosa 2009 Aluminum
Discharge and Flow Data
Monitoring Period Date
DMR Loadings Tool Aluminum
Concentration (mg/L)
DMR Loadings Tool Average
Flow (MGD)
31-Mar-09
24
0.67
30-Jun-09
16
0.42
30-Sep-09
13
0.9
31-Dec-09
15
0.95
Source: DMR Loadings Tool.
As part of the 2011 Annual Reviews, EPA contacted the facility about its 2009 aluminum
concentrations and flows from outfall 001. The facility contact confirmed the concentrations and
flows shown in Table 9-17. The facility contact also stated that outfall 001 has a higher flow than
other outfalls because it is the facility's primary NPDES outfall. Outfall 001 handles all of the
non-contact cooling water and stormwater for the facility and previously discharged directly to a
stream. Following the most recent permit change, the water from outfall 001 now discharges to a
primary settling pond and then to a main tributary that leads to the river (Smith and Larmore,
2011).
In the 2002 rulemaking, EPA identified that BAT for the steelmaking subcategory, two-
stage metals precipitation, could consistently achieve an LTA of 0.229 mg/L for aluminum, with
a variability factor of 0.053. The 2009 aluminum concentrations from outfall 001 are higher than
treatable levels (i.e., the waste stream could be treated and aluminum could be discharged at a
much lower concentration). EPA is considering facility-specific permitting support to address
aluminum discharges from the Nucor Steel Tuscaloosa facility. Also, the discharges for outfall
001 result in part from stormwater and non-contact cooling water, which are not regulated by
Part 420 but rather Part 122.
9.8.3 Nucor Steel Decatur LLC
Nucor Steel in Decatur, AL, discharges chromium from outfall 002. Outfall 002
discharges "storm water runoff from the Scrap Yard, North and South Scrap Bays, and Slag
Yards associated with the manufacture of hot rolled steel" (ADEM, 2007b). Table 9-18 presents
Nucor Steel, Decatur's 2009 aluminum and flow discharge data in the DMR Loadings Tool for
outfall 002.
Table 9-18. Nucor Steel Decatur's Outfall 002 2009 Monthly Aluminum
Discharge and Flow Data
Monitoring Period Date
DMR Loadings Tool Aluminum
Concentration (mg/L)
DMR Loadings Tool Average Flow
(MGD)
30-Jun-09
2.92
4.03
31-Dec-09
2.37
1.05
Source: DMR Loadings Tool.
9-15
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
As part of the 2011 Annual Reviews, EPA contacted the facility about its 2009 aluminum
concentrations and flows from outfall 002. The facility contact confirmed these concentrations
and flows, shown in Table 9-18. The facility contact also stated that outfall 002 discharges to one
of the ponds where stormwater from the east part of the plant along with some non-contact
cooling water blowdown is collected. There is no treatment except for a pH adjustment once the
water is discharged into the collection pond. The facility contact stated that the flows are high for
outfall 002 because it is the primary stormwater outfall for the facility (Denton, 2011).
As shown in Table 9-18, in 2009 the facility's mean effluent aluminum concentration was
2.64 mg/L for outfall 002 (untreated stormwater). In the 2002 rulemaking, EPA promulgated
production-based limitations for aluminum for wastewater from steelmaking. These limits were
based on two-stage metals precipitation as BAT, which achieved an LTA of 0.229 mg/L for
aluminum, with a variability factor of 0.053. The facility's discharge concentration is higher than
this treatable level. EPA is considering facility-specific permitting support to address aluminum
discharges from the Nucor Steel Decatur facility.
9.9 Iron and Steel Manufacturing Category Conclusions
Based on available data, the estimated toxicity of the Iron and Steel Manufacturing
Category discharges in the toxicity rankings databases result from cyanide, chlorine, chromium,
fluoride, and aluminum discharges. Data collected for the 2011 Annual Reviews demonstrated
that wastewater discharge characteristics for this category are consistent with discharges from
prior years. Using data collected for the 2011 Annual Reviews, EPA concludes the following:
• Two facilities, US Steel Corporation-Clairton Works, and Mountain State
Carbon, LLC, contribute the majority of the DMR database cyanide discharges
for the Iron and Steel Manufacturing Category. US Steel Corporation's cyanide
discharges do not exceed the permit limitations and likely have a high load
because of their flow. US Steel Corporation's high flow is expected as it has
historically been a top coke producer in the United States. Mount State Carbon's
2009 November cyanide quantity exceeds its mass-based permit limitation. EPA
further determined that the facility was not in compliance during eleven months in
2010. However, the compliance issues appeared to be resolved in 2011.
Therefore, EPA will continue to review this facility's cyanide discharges in future
years, but notes that these discharges are not representative of typical cokemaking
facility discharges.
• The chlorine discharges are reported by one facility, ISG Sparrows Point, Inc.
Due to an overestimation in the DMR database, ISG Sparrows Point's chlorine
TWPE was corrected from 8,690 to 1,320. EPA concludes that the chlorine
discharge does not represent a hazard priority.
• Database errors were also identified for discharges of chromium. After correcting
these errors, the Iron and Steel Manufacturing Category TWPE from chromium
decreased from 16,000 to 463 and does not represent a hazard priority.
• One facility, Arcelormittal Weirton Inc., accounted for 51 percent of the 2009
DMR fluoride TWPE. The concentrations ranged from 5.6 mg/L to 14.8 mg/L.
9-16
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
EPA determined that current technologies are achieving effluent fluoride
concentrations between 2 mg/L and 15 mg/L. Therefore, EPA does not consider
these discharges a hazard priority at this time.
• Three facilities, Ipsco Tubulars Inc., Nucor Steel Tuscaloosa Inc., and Nucor Steel
Decatur LLC, contribute the majority of the aluminum discharges for the Iron and
Steel Manufacturing Category. The aluminum discharges for all three facilities
result from stormwater, and all effluent aluminum concentrations exceed treatable
levels. EPA is considering facility-specific permitting support to be the most
appropriate to control these facilities' fluoride discharges.
• Correcting the database errors identified during the 2011 Annual Reviews
decreases the 2009 Iron and Steel Manufacturing Category TWPE from 230,000
to 207,000. As new data becomes available, EPA will continue to review the Iron
and Steel Category discharges to determine if they are properly controlled.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
9.10 Iron and Steel Manufacturing Category References
1. ACCCI. 2011. American Coke and Coal Chemicals Institute. Operating U.S. & Canadian
Coke Plants. (September 1). EPA-HQ-OW-2010-0824. DCN 07589.
2. ADEM. 2007a. Alabama Department of Environmental Management. Draft NPDES
Permit: Nucor Steel Tuscaloosa Inc., Tuscaloosa, AL. (October 10). EPA-HQ-OW-2010-
0824. DCN 07590.
3. ADEM. 2007b. Alabama Department of Environmental Management. Draft NPDES
Permit: Nucor Steel Decatur LLC, Decatur, AL. (September 12). EPA-HQ-OW-2010-
0824. DCN 07591.
4. Becker, Russ. 2011. Notes From Telephone Communication Between Russ Becker, ISG
Sparrows Point, Inc., and Kimberly Landick, Eastern Research Group, Inc., Re: 2009
DMR Chlorine Concentration and Flow Discharges. (August 1). EPA-HQ-OW-2010-
0824. DCN 07592.
5. Denton, Wayne. 2011. Notes From Telephone Communication Between Wayne Denton,
Nucor Steel Decatur, and Kimberly Landick, Eastern Research Group, Inc., Re: 2009
DMR Aluminum Concentration and Flow Discharges. (August 2). EPA-HQ-OW-2010-
0824. DCN 07593.
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Section 9—Iron and Steel Manufacturing (40 CFR Part 420)
6. GCIP. 2002. General Chemical Industrial Products. Chapter 14 - Wastewater and Water
Treatment. Available online at: http://www.genchem.com/calcium/NChl4.html. DCN
03761.
7. Ionics, n.d. "The EnChem® Process for Fluoride Removal." Wastewater Treatment for
the Microelectronics Industry. Available online at:
http://www.iconics.com/pdf/TS4752EUS.pdf. DCN 03760.
8. McDaniel, Jennifer. 2011. Telephone and Email communication Between Jennifer
McDaniel, IPSCO Tubulars, Inc., and Kimberly Landick, Eastern Research Group, Inc.,
Re: DMR Clarification Needed for IPSCO Tubulars. (August 2). EPA-HQ-OW-2010-
0824. DCN 07594.
9. MDE. 2001. Maryland Department of the Environment. NPDES Permit: ISG Sparrows
Point, Inc., Sparrows Point, MD. (March 1). EPA-HQ-OW-2010-0824. DCN 07595.
10. Minda, Dave. 2011. Notes From Telephone Communication Between Dave Minda,
Arcelormittal Weirton, and Kimberly Landick, Eastern Research Group, Inc., Re: 2009
DMR Chromium Discharges. (September 13). EPA-HQ-OW-2010-0824. DCN 07597.
11. PADEP. 2006. Commonwealth of Pennsylvania Department of Environmental
Protection, Water Management Program. NPDES Permit: U.S. Steel Corporation-
Clairton Works, Clairton, PA. (December 27). EPA-HQ-OW-2010-0824. DCN 07598.
12. Smith, Tyler, and Eric Larmore. 2011. Notes From Telephone Communication Between
Tyler Smith and Eric Larmore, Nucor Steel-Tuscaloosa, and Kimberly Landick, Eastern
Research Group, Inc., Re: 2009 DMR Aluminum Concentration and Flow Discharges.
(August 2). EPA-HQ-OW-2010-0824. DCN 07600.
13. U.S. EPA. 2002. Development Document for Final Effluent Limitations Guidelines and
Standards for the Iron and Steel Manufacturing Point Source Category. Washington, DC.
EPA-821 -R-02-004. EPA-HQ-OW-2010-0824. DCN 07720.
14. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
15. WC&E. 2006. Wastech Controls & Engineering, Inc. Fluoride Wastewater Treatment
(FWT) (HF Neutralization or Fluoride Reduction. Available online at:
http://www.wastechengineering.com/papers/hf.htm. DCN 03759.
16. WVDEP. 2008. West Virginia Department of Environmental Protection. NPDES Permit:
Mountain State Carbon, Follansbee, IV V. (January 15). EPA-HQ-OW-2010-0824. DCN
07601.
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Section 10—Landfills (40 CFR Part 445)
10. Landfills (40 CFR Part 445)
EPA selected the Landfills Category for preliminary review because it continues to rank
high, in terms of toxic-weighted pound equivalent (TWPE), in the point source category
rankings. The Final 2010 Plan summarizes the results of EPA's previous review of this industry
in 2010 (U.S. EPA, 2011). This section summarizes the results of the 2011 Annual Reviews,
which focused on discharges of fluoride, boron, and metals, including copper, manganese, and
iron, due to their high TWPE relative to the other pollutants in the Landfills Category and the
findings from the 2010 Annual Reviews.
10.1 Landfills Category 2011 Toxicity Rankings Analysis
Table 10-1 compares the toxicity rankings analysis results for the Landfills Category
from the 2009 through 2011 Annual Reviews. The combined TWPE from discharges in the
discharge monitoring report (DMR) and Toxics Release Inventory (TRI) databases increased
from discharge years 2007 to 2009. The estimated 2009 DMR TWPE accounts for approximately
99 percent of the combined 2009 DMR and TRI TWPE, similar to previous years of data.
Table 10-1. Landfills Category TRI and DMR Discharges for the 2009 Through 2011
Toxicity Rankings Analyses
Year of Discharge
Year of Review
Landfills Category
TRI TWPE1'
DMRTWPEb
Total TWPE
2007
2009
83
15,300
15,400
2008
2010
781
191,000
192,000
2009
2011
2,750
219,000
222,000
Sources: TRI Releases 2007 v2, DMRLoads2007_v4, TRIReleases2008_v3, DA4RLoads2008_v3;
TRIReleases2009jv2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2007 include only major dischargers. DMR 2008 data include both minor and major
dischargers.
10.2 Landfills Category Pollutants of Concern
EPA's review of the Landfills Category focused on the 2009 DMR discharges because
the 2009 DMR data dominate the category's combined TWPE. Table 10-2 lists the five
pollutants with the highest TWPE based on results from the 2011 and 2010 Annual Reviews
(DMRLoads2009 v2 and DMRLoads2008 v3, respectively).
The top five DMR-reported pollutants in 2009 contribute more than 87 percent of the
total category TWPE. EPA determined that three facilities account for the majority of the top
five DMR-reported pollutants. EPA also continued its review of iron, the fifth top DMR-reported
pollutant, as a continuation of the findings from the 2010 Annual Reviews (U.S. EPA, 2011).
10-1
-------
Section 10—Landfills (40 CFR Part 445)
Table 10-2. Landfills Category Top DMR Pollutants
Pollutant
2008 DMR Data1'
2009 DM R Data'1
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Copper
Pollutants not reported in the top five 2008
DMR-reported pollutants.
1
57
73,100
Fluoride
2
25
52,900
Boron
3
29
47,000
Manganese
3
55
15,700
4
48
18,200
Iron
2
146
31,300
5
122
7,420
Vanadium
1
11
45,400
Pollutants not reported in the top five 2009
DMR-reported pollutants.
Arsenic
4
47
15,100
Calcium
5
18
10,900
Landfills Category
Total
NA
232b
191,000
NA
201b
219,000
Sources: DA4RLoads2008jv3 and DALRLoads2009_v2.
a DMR data include major and minor dischargers.
b Number of facilities reporting a TWPE of greater than zero.
NA: Not applicable.
10.3 Landfills Category Top Dischargers in DMR
Table 10-3 presents the top three facilities discharging the pollutants of concern for the
Landfills Category in the 2009 DMR database: Butler County Landfill in Poplar Bluff, MO;
Tunnel Hill Reclamation in New Lexington, OH; and BFI Backridge Sanitary Landfill in La
Grange, MO. The majority (86 percent) of the top pollutant discharges in 2009 were from these
three facilities, and this section accordingly focuses on them.
Table 10-3. Top Facilities Discharging Pollutants of Concern in the 2009 DMR Database
Facility
Location
Top Pollutants
Discharged
Combined Top
Pollutant DMR
Pounds
Discharged
Combined Top
Pollutant DMR
TWPE
Butler County Landfill
Poplar Bluff, MO
Copper,
Fluoride, Boron
7,340,000
169,000
Tunnel Hill Reclamation
New Lexington, OH
Manganese
225,000
15,700
BFI, Backridge Sanitary
Landfill
La Grange, MO
Iron
782,000
4,380
Total
207,000,000
219,000
Source: DMRLoads2009 v2.
10.3.1 Butler County Landfill
Table 10-4 presents the discharges in the 2009 DMR database for Butler County Landfill.
Approximately 97 percent of the facility's TWPE is from copper, fluoride, and boron discharges.
10-2
-------
Section 10—Landfills (40 CFR Part 445)
Table 10-4. Butler County Landfill 2009 Top Discharges in the DMR Database
Polliilanl
Toial Pounds
1 Olill TW PI
Perccnl of l ;icili(> Toial
twpi:
Copper
115,000
72,500
41.0%
Fluoride
1,690,000
50,700
29.1%
Boron
5,530,000
46,100
26.5%
Remaining pollutants3
2,410,000
4,690
2.8%
Total
9,750,000
174,000
100%
Source: DMRLoads2009_v2.
" Remaining pollutants discharged by Butler County Landfill include sulfate, chlorides, total suspended solids,
nickel, biological oxygen demand (BOD), manganese, antimony, barium, and lead.
The copper, fluoride, and boron discharges for Butler County Landfill are from outfalls
001 and 002. Table 10-5 presents the discharge data in the DMR Loadings Tool for 2009. EPA
contacted the Missouri Department of Natural Resources (MO DNR) to confirm the 2009 copper
discharges. MO DNR indicated that the September 2009 copper concentration for outfall 001
was 21 micrograms per liter (|ig/L), not 21 milligrams per liter (mg/L) (Cozad, 2011). Because
fluoride and boron concentrations from the DMR Loadings Tool were similar in order of
magnitude to the original copper concentration, EPA converted the concentrations from mg/L to
|ig/L. Using the corrected concentrations, the facility's TWPE decreased from 174,000 to 4,765,
a reduction of over 97 percent.
Table 10-5. Butler County Landfill 2009 Monthly Top Pollutant Discharge Data
Oiid'all
Polliilanl
Monitoring Period
Dale
DMR Loadings Tool
( oniTiilralion img/l.)
( orivclcd
( onccnlralion img/l.)
001
Copper
30-Sep-09
21
0.021
002
Fluoride
30-Sep-09
370
0.37
001
Boron
30-Sep-09
700
0.7
002
Boron
30-Sep-09
370
0.37
Sources: DMR Loadings Tool and MO DNR contact (Cozad, 2011).
10.3.2 Tunnel Hill Reclamation
Table 10-6 presents the discharges in the 2009 DMR database for Tunnel Hill
Reclamation. All of the facility TWPE is from manganese discharges.
Table 10-6. Tunnel Hill Reclamation 2009 Top Discharges in the DMR Database
Polliilanl
lolal Pounds
1 tilal TW PI.
Pcrmil of l-'acilil> l olal
TWPI'.
Manganese
225,000
15,700
100%
Total suspended solids
2,910
0
0%
Total
228,000
15,700
100%
Source: DMRLoads2009 v2.
10-3
-------
Section 10—Landfills (40 CFR Part 445)
All of the manganese discharges for Tunnel Hill Reclamation are from outfall 001. Table
10-7 presents the 2009 discharge data from the DMR Loadings Tool for outfall 001. The DMR
Loadings Tool uses the facility quantities for August through December 2009 to calculate the
facility's annual manganese load. Because the DMR Loadings Tool prioritizes the quantity value
for the calculation, the quantities reported as "NR" were not included in the load calculation.
However, the facility also reported the flow and monthly manganese concentration data in the
2009 DMR data, even for reporting periods January through July, where the quantity not
reported. EPA hand calculated the monthly quantities using the reported manganese
concentrations and flow, also presented in Table 10-7. The calculated quantities are at least three
orders of magnitude less than the quantities in the DMR Loadings Tool. EPA determined that the
monthly quantities used to calculate the load in the DMR Loadings Tool are incorrect. After
correcting the monthly quantities, Tunnel Hill Reclamation's manganese discharges decrease
from 15,700 to 10.9 TWPE, a reduction of over 99 percent.
Table 10-7. Tunnel Hill Reclamation 2009 Monthly Manganese Discharges for Outfall 001
Monitoring Period
l);ik'
DMR Loadings Tool Dala
l-'.PA ( alenlaled
Oii;inlil> 1 (kii/d;i\)
A\eraiie Qu;ni(i(>
Reported (kii/din)
A\eraiie
Coneenlralion
Reported img/l.)
A\eraiie I'low
Reported (M(.D)
31-Jan-09
NR
1.7325
0.0607
0.398
28-Feb-09
NR
1.33
0.1274
0.641
31-Mar-09
NR
0.248
0.0635
0.060
30-Apr-09
NR
0.5575
0.0926
0.195
31-May-09
NR
0.6375
0.0729
0.176
30-Jun-09
NR
0.346
0.0618
0.081
31-Jul-09
NR
0.616
0.0638
0.149
31-Aug-09
545
0.545
0.0519
0.107
30-Sep-09
315
0.315
0.0569
0.068
31-Oct-09
1,594
1.594
0.0654
0.395
30-Nov-09
654.3
0.654
0.02270
0.056
31-Dec-09
213.5
0.214
0.0306
0.025
Sources: DMR Loadings Tool and Envirofacts.
" EPA calculated the quantity using the average concentration and average flow.
10.3.3 BFI Backridge Sanitary Landfill
Table 10-8 presents the discharges in the 2009 DMR database for BFI Backridge Sanitary
Landfill. The majority of the facility's TWPE (over 99 percent) is from iron.
Table 10-8. BFI Backridge Sanitary Landfill 2009 Discharges in the DMR Database
Polliilanl
Toial Pounds
i oiid t\\ pi:
Percent of l-'aeilil> Toial
iwpi:
Iron
782,000
4,380
>99%
Lead
1.32
2.96
<1%
Remaining pollutants3
156,440
0
0%
Total
938,700
4,380
100%
Source: DMRLoads2009_v2.
" Remaining pollutants discharged by BFI Backridge Sanitary Landfill include total dissolved solids, chlorides,
sulfates, and BOD.
10-4
-------
Section 10—Landfills (40 CFR Part 445)
The iron discharges for BFI Backridge Sanitary Landfill are from outfalls 001 and 002.
Table 10-9 presents the 2009 iron discharge data in the DMR Loadings Tool and Envirofacts for
outfalls 001 and 002. EPA compared the data from the DMR Loadings Tool to Envirofacts and
concluded that a data entry error in September 2009 had resulted in iron concentrations 1,000
times higher than March 2009 concentrations. Using the corrected concentrations, BFI Backridge
Sanitary Landfill's discharges decreased from 4,380 to 6.9 TWPE, a reduction of over 99
percent.
Table 10-9. BFI Backridge Sanitary Landfill 2009 Monthly Iron Discharges
DMR l.oiidin^s Tool
A\er;iiie
Convck'd A\emtio
Monitoring Period
( oniTiilmlion
l-'n\ iroliicls A\ci'iiiic
( oiKTiilr;ilion
oiitniii
Diilo
(inii/l.)
( onci-nlr;ilion (inii/l.)
(inii/l.)
001
31-Mar-09
0.86
0.86
0.86
001
30-Sep-09
950
NR
0.95
002
31-Mar-09
1.8
1.8
1.8
002
30-Sep-09
6300
NR
6.3
Sources: DMR Loadings Tool and Envirofacts.
NR: Not reported. Concentrations were not in Envirofacts.
10.4 Landfills Category Iron Discharges in DMR
As part of the 2010 reviews of the Landfills Category, EPA compared iron discharges in
the 2008 DMR database to treatable levels typical of chemical precipitation and biological
treatment. See Section 8.5 of the Technical Support Document for the 2010 Effluent Guidelines
Program Plan for additional information on the methodology used to review the iron
concentration data, or the memorandum titled "Methodology for Analyzing Landfill Iron
Concentrations in the 2008 DMR Loadings Tool" (U.S. EPA, 2011; ERG, 2010).
For the 2010 Annual Reviews, EPA determined that 89 percent of iron concentrations in
the 2008 DMR database were within treatability concentration ranges (ERG, 2010). Because
EPA was concerned about the quality of data, EPA concluded that additional review was
necessary and solicited comments as part of the 2010 Final Plan. See 76 FR 66286 (October 26,
2011).
For the 2011 Annual Reviews, EPA used the same methodology to review iron
concentration data for the Landfills Category. EPA determined that there were 3,232 iron
concentrations in the DMR Loadings Tool for 2009 for facilities in the Landfills Category. EPA
removed 0 mg/L or blank concentrations and concentrations reported below the detection limit
for all reporting periods, resulting in 1,593 iron concentrations for the 2011 analysis. Because
facilities report multiple concentrations for each monitoring period, EPA prioritized the selection
of the average concentration and then the maximum (ERG, 2010).
Then, EPA compared the iron concentrations to the EPA Method 200.7 method detection
limit (MDL) for iron to determine if the concentrations were at detectable levels. EPA excluded
the 66 iron concentrations (approximately 4 percent) that were below the MDL. EPA calculated
the resulting median, average, and maximum of the remaining iron concentrations. EPA
10-5
-------
Section 10—Landfills (40 CFR Part 445)
analyzed the median concentration rather than the average or maximum because of suspected
data entry errors that would skew the average and maximum iron concentrations (ERG, 2010).
EPA then compared the median iron concentration to available chemical precipitation
and biological treatability data. EPA chose these specific wastewater treatment technologies
because they were the technologies used to determine the best available technology basis used to
develop limits for the RCRA Subtitle C Hazardous Waste Landfills. EPA used treatability data
for chemical precipitation and biological treatment already established during previous annual
reviews8 (U.S. EPA, 2009).
Table 10-10 presents the 2008 and 2009 median iron concentrations compared to the
EPA Method 200.7 MDL and treatability concentrations for chemical precipitation and
biological treatment. Similar to the 2010 findings, Table 10-10 shows that the median
concentration in landfill discharges is below the maximum concentrations achievable by
chemical precipitation and biological treatment.
8 As part of the Steam Electric Power Generating Point Source Category Detailed Study, EPA collected treatability
data for chemical precipitation and biological treatment systems. Iron was included in the treatability data (U.S.
EPA, 2009).
10-6
-------
Section 10—Landfills (40 CFR Part 445)
Table 10-10. Iron Concentrations in the 2008 and 2009 DMR Database Compared to Treatability Concentrations
Discharge Year
Number of
Faeilities
Reporting
Pollutant"
Median
Concentration
(mg/L)
EPA 200.7 MDL
(mg/L)
Chemical
Precipitation
T rcatmcnt
Concentration
Range (mg/L)
Biological
Treatment
Concentration
Range (mg/L)
Percent of
Concentrations
Above Chemical
Precipitation
Range
Percent of
Concentrations
Above Biological
Treatment
Range
2008
146
1.21
0.03
0.019-6
ND (0.0022)-23
11%
2%
2009b
122
0.85
8%
1.5%
Sources: DMR Loadings Tool; Method 200.7 Determination of Metals and Trace Elements in Water and Wastes by Inductively Couple Plasma-Atomic Emission
Spectrometry (U.S. EPA, 1994); and 2009 Steam Electric Power Generating Point Source Category: Final Detailed Study Report (U.S. EPA, 2009).
a Number of facilities reporting iron concentrations after EPA excluded outfalls with all non-detect concentrations and concentrations reported as 0 mg/L.
b EPA used the corrected iron concentration for BFI Backridge Sanitary Landfill in the 2009 iron median concentration.
MDL: Method detection limit.
ND: Non-detect. Detection limit indicated in parentheses.
10-7
-------
Section 10—Landfills (40 CFR Part 445)
The 2009 median iron concentration for all outfalls is less than the biological treatment or
chemical precipitation treatability concentrations and less than the 2008 median iron
concentration for all outfalls. Approximately 92 percent of the iron concentrations are below the
chemical precipitation treatability (below 6 mg/L) and 98.5 percent are below the biological
treatment treatability (below 23 mg/L). The remaining iron concentrations above the chemical
precipitation treatment range are reported by a total of 37 facilities, four of which are also above
the biological treatment range. EPA determined that approximately 75 percent of the facilities
reporting iron concentrations above treatable levels are located in Missouri and Kentucky.
10.5 Landfills Category Conclusions
The estimated toxicity of the Landfills Category discharges results mainly from the
discharges of metals. During the 2010 Annual Reviews, EPA identified many data entry errors in
the Landfills Category DMR data, because they are predominately minor discharges. Based on
corrected discharge data, further review at this time is unnecessary. Therefore, EPA concludes
the following:
• Database errors were identified for copper, fluoride, boron, manganese, and iron.
Making these corrections decreases the Landfills Category TWPE by over 85
percent, from 221,000 to 32,400. With this reduction, the Landfills Category
would rank 23rd, which is outside the top 95 percent that EPA prioritized for
preliminary review as part of the 2011 Annual Reviews.
• Ninety-two percent of iron concentrations in the 2009 DMR database are within
treatability concentration ranges.
• Because the majority of 2009 DMR iron concentrations are within the treatability
concentration ranges and approximately 85 percent of the TWPE was a result of
database errors, EPA will continue to review the Landfills category iron
discharges in future years.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
10.6 Landfills Category References
1. ERG. 2010. Eastern Research Group, Inc. Memorandum to William Swietlik, U.S. EPA,
From Jessica Wolford and Elizabeth Sabol, Eastern Research Group, Inc., Re:
Methodology for Analyzing Landfill Iron Concentrations in the 2008 DMR Loadings
Tool. (October). EPA-HQ-OW-2008-0517 DCN 07277.
2. Cozad, Marietta. 2011. Notes From Telephone Communication Between Marietta Cozad,
MDNR, and Kimberly Landick and Elizabeth Sabol, Eastern Research Group, Inc., Re:
10-8
-------
Section 10—Landfills (40 CFR Part 445)
2009 DMR Lead Discharges for Butler County Landfill." (February 23). EPA-HQ-OW-
2010-0824. DCN 07531.
3. U.S. EPA. 1994. Method 200.7 Determination of Metals and Trace Elements in Water
and Wastes by Inductively Couple Plasma-Atomic Emission Spectrometry Revision 4.4.
Washington, DC. (Unknown). Available online at:
http://www.epa.gov/waterscience/methods/method/files/200_7.pdf.
4. U.S. EPA. 2009. Steam Electric Power Generating Point Source Category: Final
Detailed Study Report. EPA-821-R-008. Washington, DC. (October). EPA-HQ-OW-
2008-0517-0413.
5. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA-820R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
6. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
10-9
-------
Section 11—Meat and Poultry Products (40 CFR Part 432)
11. Meat and Poultry Products (40 CFR Part 432)
EPA selected the Meat and Poultry Products (Meat and Poultry) Category for preliminary
review because it ranks high, in terms of toxic-weighted pound equivalent (TWPE), in the point
source category rankings. This section summarizes the results of the 2011 Annual Reviews
associated with the Meat and Poultry Category. EPA focused on discharges of nitrate compounds
because of their high TWPE relative to the other pollutants in the Meat and Poultry Category.
11.1 Meat and Poultry Category Background
This subsection provides the background on the Meat and Poultry Category including a
brief profile of the Meat and Poultry industry and background on 40 CFR Part 432.
11.1.1 Meat and Poultry Industry Profile
The meat and poultry industry includes facilities engaged in the slaughtering, dressing
and packing of meat and poultry products for human consumption and/or animal food and feeds.
Meat and poultry products for human consumption include meat and poultry from cattle, hogs,
sheep, chickens, turkeys, ducks and other fowl as well as sausages, luncheon meats and cured,
smoked or canned or other prepared meat and poultry products from purchased carcasses and
other materials. Meat and poultry products for animal food and feeds include animal oils, meat
meal and facilities that render grease and tallow from animal fat, bones and meat scraps (40 CFR
§432.1) EPA considered the following eight industrial categories as part of the Meat and Poultry
Products Category:
• Other Animal Food Manufacturing (Meat and Poultry Products)
• Animal (except Poultry) Slaughtering
• Meat Processed from Carcasses
• Rendering and Meat Byproduct Processing
• Poultry Processing
• All Other Miscellaneous Food Manufacturing (Meat and Poultry Products)
• Broilers and Other Meat Type Chicken Production
• Dog and Cat Food Manufacturing
Because the sources of the discharge monitoring report (DMR) data used to develop
DMRLoads2009 report facilities by Standard Industrial Classification (SIC) code and the U.S.
Economic Census and Toxics Report Inventory (TRI) report data by North American Industry
Classification System (NAICS) code, EPA reclassified the 2009 DMR data by the equivalent
NAICS code. See Section 4.2.1.2 of the 2009 SLA Report for additional details (U.S. EPA,
2009). Table 11-1 lists the number of facilities from the 2007 U.S. Economic Census and the
toxicity rankings databases for the eight industrial categories with operations in the Meat and
11-1
-------
Section 11—Meat and Poultry Products (40 CFR Part 432)
Poultry Category. The U.S. Economic Census includes more facilities than the toxicity rankings
databases for many reasons: facilities may not meet TRI-reporting thresholds, facilities may
discharge to a publicly owned treatment works (POTW), and some facilities in the U.S.
Economic Census are distributors or sales facilities, not manufacturers.
Table 11-1 also includes the number of meat and poultry facilities by major or minor
discharge status in the 2009 DMR database. As described in Section 2.1.5, permitting authorities
classify discharges as major or minor based on the potential impact of the discharge (U.S. EPA,
2011). In general, major discharges are expected to impact receiving waters if not controlled;
minor discharges may, or may not, adversely impact receiving waters if not controlled. Also as
described in 2.1.5, the PCS and ICIS-NPDES databases include data only for a limited set of
minor discharges (i.e., if the state or other permitting authority chooses to include these data).
Table 11-1 shows that approximately 78 percent of the Meat and Poultry Category discharges in
the 2009 DMR database are minor discharges. Table 11-1 also presents the type of discharges
reported by facilities in the 2009 TRI database. The majority of the meat and poultry facilities
reporting to TRI reported direct discharges to surface waters.
Table 11-1. Number of Meat and Poultry Facilities
2009 DMR
2009 TRI
2007 U.S.
Economic
Census
Total
Minor
Major
Total
Indirect
Dischargers
Only
Direct
Dischargers
Only
Both
Indirect
and Direct
Dischargers
6,357
189
147
42
173
64
92
17
Source: U.S. Economic Census (2007); TRIReleases2009jv2; andDMRLoads2009_v2.
11.1.2 40 CFR Part 432
EPA most recently updated effluent limitations guidelines (ELGs) for the Meat and
Poultry Category (40 CFR Part 432) on September 8, 2004 (69 FR 54476). This category
consists of 12 subcategories that apply to the manufacture of products and product groups, as
shown in Table 11-2 with corresponding applicability, regulated pollutants, and limitations. In
addition to best practicable control technology (BPT), best available technology economically
achievable (BAT), and new source performance standards (NSPS) are also included in 40 CFR
Part 432. Table 11-2 presents the BAT-based ELG limits for the Meat and Poultry Category.
11-2
-------
Section 11—Meat and Poultry Products (40 CFR Part 432)
Table 11-2. Applicability, Regulated Pollutants, and BAT ELG Limits
for the Meat and Poultry Category
Siihpiirl
Siil)c;iU'}ion
1 ilk-
Suhcsilcgon A|)|)lic;il)ilil\
Ammuni;i :is V
Toliil Ni(ro»oir'
M;i\
l);iil\
(iiiii/l.)
M;i\
Mnnlhl\
A\er;iiie
(inii/l.)
M;i\ l).iil\
M;i\
\lon(hl\
(nili/l.)
A
Simple
Slaughterhouses
Process w a^lew aler dis>cliarge;>
resulting from production of meat
carcasses by simple
slaughterhouses.
8.0
4.0
194
134
Bb
Complex
Slaughterhouses
Process wastewater discharges
resulting from production of meat
carcasses by complex
slaughterhouses.
8.0
4.0
194
134
Cb
Low-processing
Packinghouses
Process wastewater discharges
resulting from production of meat
carcasses by low-processing
packinghouses.
8.0
4.0
194
134
Db
High-processing
Packinghouses
Process wastewater discharges
resulting from production of meat
carcasses by high-processing
packinghouses.
8.0
4.0
194
134
E°
Small Processors
Process wastewater discharges
resulting from production of
finished meat products (i.e.: fresh
meat cuts, smoked products,
canned products, hams, sausages,
and luncheon meats) by a small
processor.
NA
NA
NA
NA
Fd
Meat Cutters
Process wastewater discharges
resulting from production of fresh
meat cuts (i.e.: steaks, roasts, and
chops) by a meat cutter.
8.0
4.0
194
134
Gd
Sausage and
Luncheon Meats
Processors
Process wastewater discharges
resulting from production of fresh
meat cuts, sausage, bologna, and
other luncheon meats by a
sausage and luncheon meat
processor.
8.0
4.0
194
134
Hd
Ham Processors
Process wastewater discharges
resulting from production of
hams by a ham processor.
8.0
4.0
194
134
Id
Canned Meats
Processors
Process wastewater discharges
resulting from production of
canned meats by a canned meats
processor.
8.0
4.0
194
134
11-3
-------
Section 11—Meat and Poultry Products (40 CFR Part 432)
Table 11-2. Applicability, Regulated Pollutants, and BAT ELG Limits
for the Meat and Poultry Category
Ammuni;i :is V
Toliil Ni(ro»oir'
Siihpiirl
SiihciiU'jion
1 ilk-
Suhcsilcgon A|)|)lic;il)ilil\
M;i\
l);iil\
(iiiii/l.)
M;i\
Mnnlhl\
A\er;iiie
(inii/l.)
M;i\ l).iil\
M;i\
\lon(hl\
(nili/l.)
J
Reiiderei'b
Proccbb w ablew alcr dibcliargcb
resulting from production of meat
meal, dried animal by-product
residues (tankage), animal oils,
grease and tallow, and hide
curing, by a renderer.
0.14
(pounds
per 1000
lbs (g/kg)
of raw
material)
0.0"
(pounds
per 1000
lbs (g/kg)
of raw
material);
194
134
Ke
Poultry First
Processing
Process wastewater discharges
resulting from slaughtering of
poultry, further processing of
poultry and rendering of material
derived from slaughtered poultry.
8.0
4.0
147
103
Lf
Poultry Further
Processing
Process wastewater discharges
resulting from further processing
of poultry.
8.0
4.0
147
103
Source: 40 CFR §432
a Units are mg/L unless otherwise noted.
b Any existing point source subject to this subpart that slaughters more than 50 million pounds per year (in units
live weight kill (LWK)) must achieve the applicable total Nitrogen and Ammonia as N BAT based limits.
0 The Small Processors Subcategory does not have BAT based limits; however, it does have BPT and NSPS
based limits for BOD5, fecal coliform, oil and gas, and TSS.
d The total Nitrogen BAT based limit only applies to facilities with more than 50 million pounds per year of final
product. The Ammonia as N BAT based limit applies to all facilities.
e Any existing point source subject to this subpart that slaughters more than 100 million pounds per year (in units
LWK) must achieve the applicable total Nitrogen and Ammonia as N BAT based limits.
f Any existing point source subject to this subpart that slaughters more than 7 million pounds per year (in units
LWK) must achieve the applicable total Nitrogen and Ammonia as N BAT based limits.
NA: Not applicable.
11.2 Meat and Poultry Category 2011 Toxicity Rankings Analysis
Table 11-3 compares the toxicity rankings analysis results for the Meat and Poultry
Products Category from the 2009 through 2011 Annual Reviews. The combined DMR and TRI
TWPE decreased from discharge years 2007 to 2009. The estimated 2009 TRI TWPE accounts
for approximately 76 percent of the combined 2009 DMR and TRI TWPE.
11-4
-------
Section 11—Meat and Poultry Products (40 CFR Part 432)
Table 11-3. Meat and Poultry Category TRI and DMR Discharges for the
2009 Through 2011 Toxicity Rankings Analyses
Year of Discharge
Year of Review
Meat and Poultry Category
TRI TWPE"
DMR TWPEb
Total TWPE
2007c
2009
35,900
536,000
572,000
2008c
2010
61,600
15,700
77,300
2009
2011
53,800
17,200
71,000
Sources: TRI Releases 2007 v2, DMRLoads2007_v4, TRlReleases2008_v3, DA4RLoads2008_v3;
TRIReleases2009_v2; and DMRLoads2009jv2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2007 include only major dischargers. DMR 2008 data include both minor and major
dischargers.
0 EPA did not review discharges from the Meat and Poultry Category as part of the 2009 and 2010 Annual
Reviews because the category ELGs were promulgated in 2004. In general, EPA does not review discharge data
for an industrial point source category if EPA established, revised, or reviewed the category's ELGs within
seven years of the annual review.
11.3 Meat and Poultry Category Pollutants of Concern
EPA's review of the Meat and Poultry Category focused on the 2009 TRI discharges
because the 2009 TRI data dominate the category's combined TWPE. Table 11-4 lists the five
pollutants with the highest TWPE based on results from the 2011 Annual Reviews
(TRIReleases2009 v2). The top TRI-reported pollutant in 2009, nitrate, contributes more than 87
percent of the category's 2009 TRI TWPE. As a result, EPA's additional review for the 2011
Annual Reviews focused on nitrate. EPA did not investigate the other top pollutants as part of
the 2011 Annual Reviews because they account for only 13 percent of the 2009 Meat and Poultry
Category TRI TWPE; however, EPA did review DMR data to aid in the review of the 2009 TRI
nitrate discharges.
Table 11-4. Meat and Poultry Category Top TRI Pollutants
Pollutant
2009 TRI Data"
Rank
Number of Facilities
Reporting Pollutant
TWPE
Nitrate compounds'3
1
116
46,900
Chlorine
2
4
2,840
Lead and lead compounds
3
1
1,590
Mercury and mercury compounds
4
1
1,480
Ammonia
5
126
853
Meat and Poultry Category Total
NA
173c
53,800
Source: TRlReleases2009_v2.
" Discharges include transfers to POTWs and account for POTW removals.
b The TRI list of chemicals within water-dissociable nitrate compounds category and guidance for reporting
includes 49 pollutants. A full list of TRI pollutants included in the "Nitrate Compounds" category is available
online at: http://www.epa.gov/tri/guide_docs/pdf/2000/nitrates2000.pdf.
0 Number of facilities reporting a TWPE of greater than zero.
11-5
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Section 11—Meat and Poultry Products (40 CFR Part 432)
11.4 Meat and Poultry Category Nitrate Compound Discharges in TRI
Nitrate compound discharges from meat and poultry facilities in the 2009 TRI database
account for 87 percent of the category's 2009 TRI TWPE. Table 11-5 presents the facilities that
account for the nitrate compound discharges in the 2009 TRI database.
11-6
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Section 11—Meat and Poultry Products (40 CFR Part 432)
Table 11-5. Meat and Poultry Category Nitrate Compounds Dischargers in the 2009 TRI Database
Facility Name
Location
Subcategory
Nitrate
Compound
Pounds Released
Nitrate Compound TWPE
Facility Percent of
Nitrate
Compound
Category TWPE
Tyson Fresh Meats, Inc.
Lexington, NE
B
4,990,000
3,730
7.94 %
Tyson Fresh Meats, Inc., JoslinIL
Hillsdale, IL
B
4,450,000
3,320
7.08 %
Cargill Meat Solutions Corp.
Schuyler, NE
B
3,850,000
2,870
6.12%
Smithfield Packing, Co., Inc. Tar Heel Div
Tar Heel, NC
Undetermined
3,750,000
2,800
5.96 %
Cargill Meat Solutions Corp.
Beardstown, IL
Undetermined
3,650,000
2,730
5.81 %
Lewiston Processing Plant
Lewiston
Woodville, NC
Undetermined
3,260,000
2,440
5.19%
Accomac Processing Plant
Accomac, VA
Undetermined
2,080,000
1,550
3.3 %
Farmland Foods, Inc.
Crete, NE
B
1,780,000
1,330
2.84 %
JBS Plainwell
Plainwell, MI
Undetermined
1,750,000
1,300
2.78 %
Cargill Meat Solutions Corp.
Wyalusing, PA
B
1,670,000
1,250
2.66 %
Tyson Fresh Meats, Inc.
Columbus Junction,
IA
Undetermined
1,620,000
1,210
2.58 %
Tyson Foods, Inc., Blountsville Processing Plant
Blountsville, AL
Undetermined
1,490,000
1,110
2.37 %
Pilgrim's Pride, Corp., Mt. Pleasant Complex
Mount Pleasant, TX
Undetermined
1,390,000
1,040
2.22 %
Remaining facilities reporting nitrate compounds discharges3
27,100,000
20,300
43.2 %
Total
62,900,000
46,900
100 %
Source: TRIReleases2009 v2.
a There are 103 remaining facilities that have nitrate compounds discharges in the 2009 TRI database, which account for approximately 43 percent of the
category's nitrate compounds 2009 TRI TWPE.
11-7
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Section 11—Meat and Poultry Products (40 CFR Part 432)
Several forms of nitrogen are pollutants of concern in the meat and poultry processing
wastewaters: total Kjeldahl nitrogen (TKN), ammonia nitrogen, and nitrite plus nitrate nitrogen.
Because protein is the principal component of meat and blood, meat and poultry wastewaters can
contain relatively high concentrations of nitrogen. Nitrite and nitrate nitrogen compounds are
usually present in process wastewater at concentrations less than 1 mg/L prior to biological
treatment. Nitrite and nitrate concentrations can be higher than the reported 1 mg/L if nitrite and
nitrate salts are used for curing meat or poultry (U.S. EPA, 2002).
Nitrite and nitrate nitrogen is rarely present before aerobic biological treatment due to the
lack of oxygen necessary for microbially mediated nitrification. Therefore, the principal source
of nitrite and nitrate nitrogen following treatment is nitrification. Biological treatment is often
required, at least seasonally, to satisfy effluent limitations for the discharge of ammonia nitrogen
to surface waters. Many NPDES permits are written with seasonal limits for ammonia because
the lower pH and temperature of the receiving waters during winter reduce the toxicity of
ammonia by converting it to ammonium (U.S. EPA, 2002).
The principal concern about oxidized nitrogen in the wastewater is its role in
eutrophication. An additional concern is its potential for increasing ambient surface water nitrate
nitrogen concentrations above the national maximum contaminant level (MCL) of 10 mg/L in
source waters used for public drinking water supplies (U.S. EPA, 2002).
The biological removal of nitrogen from wastewaters is a two-step process beginning
with nitrification followed by denitrification. Under anaerobic conditions, ammonia is oxidized
to nitrite, which is oxidized to nitrate in the process of nitrification. Following the anaerobic
conditions, nitrite and nitrate are reduced microbially by denitrification, producing nitrogen gas
as the principal end product (U.S. EPA, 2002). Table 11-6 lists the BAT options for the meat and
poultry subcategories.
Table 11-6. BAT Treatment Basis for the Meat and Poultry Subcategories
Subcategory
Treatment Unit Processes (Pollutants Removed)
A-D
Dissolved air flotation, lagoon, nitrification, denitrification, and disinfection
E
NA (no BAT limits)
F-I
Dissolved air flotation, lagoon, nitrification, denitrification, and disinfection
K
Dissolved air flotation, nitrification, denitrification, and disinfection
L
Dissolved air flotation, lagoon, nitrification, denitrification, and disinfection
J
Dissolved air flotation, nitrification, denitrification, and disinfection
Source: Development Document for the Proposed Effluent Limitations Guidelines and Standards for the Meat and
Poultry Products Industry Point Source Category (U.S. EPA, 2002).
EPA determined that five out of the top 13 nitrate compound discharging facilities are
complex slaughterhouses regulated by Subpart B of the Meat and Poultry ELGs. Subpart B
(Complex Slaughterhouses) applies to discharges of process wastewater associated with the
production of meat carcasses, in whole or in part, by complex slaughterhouses. Process
wastewater includes water from animal holding areas at these facilities. By definition, a complex
slaughterhouse is a slaughterhouse that provides extensive processing of the by-products of meat
slaughtering (40 CFR §432.20 and §432.21). The BAT treatment basis for Subpart B is dissolved
air flotation, lagoons, nitrification, denitrification, and disinfection (U.S. EPA, 2002). This
subsection provides information on each facility's operations and nitrate compounds discharges
in the 2009 TRI database.
11-8
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Section 11—Meat and Poultry Products (40 CFR Part 432)
11.4.1 Tyson Fresh Meats, Inc.
Tyson Fresh Meats, Inc. (Tyson Lexington), in Lexington, NE is a complex beef cattle
slaughterhouse (NDEQ, 2004a). The facility's nitrate compound discharges account for
approximately 8 percent of the 2009 TRI nitrate compound TWPE. The facility permit
recognizes wastewater discharges from two outfalls, 001 and 002. Outfall 001 discharges treated
process wastewater from the slaughter of beef cattle. The process wastewater is treated by a
dissolved air flotation system, two anaerobic lagoon cells, a plant with two activated sludge
basins, chlorination, dechlorination, and storage ponds for off specification wastewaters. Outfall
002 is an emergency bypass, to be used only when outfall 001 is unavailable for discharge. No
discharge is allowable without prior written authorization. The facility permit does not limit
nitrate discharges from outfall 001 or 002; however, it does seasonally limit ammonia (NDEQ,
2004a).
11.4.2 Tyson Fresh Meats, Inc.
Tyson Fresh Meats, Inc. (Tyson Joslin), in Hillsdale, IL is a complex slaughterhouse.
Wastewater at the facility is generated from slaughtering, process and rendering, boilers, yard
washing, hides cleaning/curing, tannery, tannery mean house and other facility operations (IL
EPA, 2004). The facility's nitrate compound discharges account for approximately 7 percent of
the 2009 TRI nitrate compounds TWPE. The plant operations result in an average discharge of
3.17 MGD of treated process wastewater, boiler blowdown, sanitary waste, miscellaneous waste,
stormwater and cooling water discharges from outfall 001. The facility permit does not limit
nitrate discharges from outfall 001; however, it does seasonally limit ammonia (IL EPA, 2004).
The facility reports 988,000 pounds of nitrate discharged from outfall 001 in the 2009
DMR database. As shown in Table 11-5, the facility reports 4,450,000 pounds of nitrate
compounds in the 2009 TRI database, a difference of 3,460,000 pounds. Because of the
difference between the 2009 DMR and 2009 TRI data, the facility is likely overestimating the
amount of nitrate compounds reported to the 2009 TRI database. It is common for facilities to
include non-industrial pollutant loads, such as loads from stormwater, based on TRI reporting
guidance. Additionally, facilities often estimate TRI pollutant loadings based on inventory,
production, and emission factors, not actual sampling data as in the DMR database.
11.4.3 Cargill Meat Solutions Corporation
Cargill Meat Solutions Corporation's facility (Cargill Schuyler) in Schuyler, NE is a
complex beef slaughterhouse and meat processing plant (NDEQ, 2004b). The facility's nitrate
compound discharges account for approximately 6 percent of the 2009 TRI nitrate compounds
TWPE. The facility permit recognizes wastewater discharges from outfalls 001, 002, and 003.
Outfall 001 discharges treated process wastewater from the beef slaughterhouse. The treatment at
the plant includes a dissolved air flotation unit, anaerobic lagoon cells, a four-chambered
sequence batch reactor (an activated sludge plant), a chlorine contact basin, and dechlorination.
Outfall 002 discharges non-contact cooling water from ammonia condensers for meat coolers.
Outfall 003 is a land application of treated effluent discharge to various agricultural sites. The
source of the water is the treated process wastewater stored in the wet storage lagoon cell. The
facility permit does not limit nitrate discharges for outfalls 001, 002, or 003; however, it does
seasonally limit ammonia (NDEQ, 2004b).
11-9
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Section 11—Meat and Poultry Products (40 CFR Part 432)
11.4.4 Farmland Foods, Inc.
Farmland Foods, Inc. (Farmland Foods) in Crete, NE is a complex swine slaughterhouse
that slaughters hogs and processes them into fresh pork products as well as smoked meat
products. All byproducts are cooked down in the rendering process and the non-condensable
vapors are discharged through an air scrubbing system of a water curtain vortex. The majority of
process water originates from floor drains throughout the plant (i.e., drains from the kill floor,
cut floor, and cleanup area) (NDEQ, 2005). The facility's nitrate compounds discharge account
for approximately 2.8 percent of the 2009 TRI nitrate compound TWPE. The facility permit
recognizes wastewater discharges from outfalls 001 and 002 (NDEQ, 2005).
Outfall 001 discharges wastewater from the cut floor, kill floor, as well as cleanup
wastewater, sanitary water, and non-contact cooling water. Wastewater treatment at the facility
includes screening, dissolved air flotation, two anaerobic lagoons, an anoxic tank, three aeration
basins, two final clarifiers (activated sludge), a chlorine contact basin and dechlorination, and a
sludge holding lagoon. Outfall 002 discharges single-pass, non-contact cooling water. The
facility permit does not limit nitrate discharges from outfalls 001 or 002; however, it does limit
ammonia (NDEQ, 2005).
11.4.5 Cargill Meat Solutions Corporation
Cargill Meat Solutions Corporation's facility (Cargill Wyalusing) in Wyalusing, PA is a
complex slaughterhouse that butchers and packages beef meat products (PA DEP, 2004). The
facility's nitrate compounds discharges account for approximately 2.6 percent of the 2009 TRI
nitrate compound TWPE. The facility permit recognizes wastewater discharges from outfall 001.
Outfall 001 discharges wastewater from the complex slaughterhouse process, the air scrubber,
boiler blowdown, and sewage waters. Wastewater treatment at the facility includes screening,
anaerobic lagoons, aeration, clarification, chlorination, dechlorination, sludge thickening, and
sludge land application. The facility does not limit nitrate discharges from outfall 001; however,
it does seasonally limit ammonia (PA DEP, 2004).
11.5 Nitrate Concentrations in the 2009 DMR Database
EPA reviewed the 2009 DMR nitrate as nitrogen pollutant discharges to determine the
order of magnitude of the nitrate concentration discharges for meat and poultry facilities. EPA
reviewed the nitrate concentrations from the 17 meat and poultry facilities that have 2009 DMR
data, nine of which also report to the 2009 TRI database.
EPA compared the nitrate concentrations to the ambient surface water national MCL of
10 mg/L in source waters used for public drinking water supplies (U.S. EPA, 2002). In order to
compare the nitrate concentrations, EPA determined that there were 286 nitrate concentrations in
the 2009 DMR Loadings Tool. No nitrate concentrations were reported below the detection limit;
therefore, EPA used all 286 concentrations for the analysis. Because facilities report multiple
concentrations for each monitoring period, EPA prioritized the selection of the average
concentration, then the maximum, and finally the minimum concentration. For facilities that
reported nitrate quantity values, EPA back-calculated the concentrations using the quantity and
the average monthly flow. Table 11-7 presents the minimum, maximum, and median nitrate
concentration values evaluated in the 2009 DMR Loadings Tool.
11-10
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Section 11—Meat and Poultry Products (40 CFR Part 432)
Table 11-7. Minimum, Maximum, and Median Nitrate Concentrations in the 2009 DMR
Loadings Tool
Minimum Nitrate Concentration
(mg/L)
Maximum Nitrate Concentration
(mg/L)
Median Nitrate Concentration
(mg/L)
0
147
15.6
Source: DMR Loadings Tool.
Figure 11-1 presents the nitrate concentrations reported in the 2009 DMR Loadings Tool
compared to the national MCL of 10 mg/L. As the figure shows, about 60 percent of the nitrate
concentrations in the 2009 DMR Loading Tool are greater than the national MCL.
~ Nitrate Concentration
Nitrate MCL
Percent of Concentrations Greater than, Equal to, or Less than the Nitrate MCL
Figure 11-1. Meat and Poultry Nitrate Concentration Probability Plot
11.6 Meat and Poultry Category Conclusions
The majority of the estimated toxicity of the Meat and Poultry Category discharges
results from nitrate compound discharges. Data collected for the 2011 Annual Reviews led EPA
to conclude that, for the facilities that report nitrate discharges, the median nitrate concentration
was 15.6 mg/L. EPA believes some facilities have not received updated permits reflective of
effluent guidelines (Part 432). As a result, EPA will continue to review nitrate compound
discharges from meat and poultry facilities during its 2012 Annual Reviews.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
11-11
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Section 11—Meat and Poultry Products (40 CFR Part 432)
revision (i.e., this category is marked with "(5)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
11.7 Meat and Poultry Category References
1. IL EPA, 2004. Illinois Environmental Protection Agency Division of Water Pollution
Control. Facility Permit for NPDES IL0003913 - Tyson Fresh Meats, Inc., Joslin, IL.
(March 25). EPA-HQ-OW-2010-0824 DCN 07519.
2. NDEQ, 2004a. Nebraska Department of Environmental Quality. Fact Sheet for NPDES
NE0123501 - Tyson Fresh Meats, Inc., Lexington, NE. (January 4). EPA-HQ-OW-2010-
0824 DCN 07520.
3. NDEQ, 2004b. Nebraska Department of Environmental Quality. Facility Permit for
NPDES NE0000795 - Cargill Meats Solutions Corporation, Schuyler, NE. (August 30).
EPA-HQ-OW-2010-0824 DCN 07521.
4. NDEQ, 2005. Nebraska Department of Environmental Quality. Facility Permit for
NPDES NE0032191 - Farmland Foods, Inc., Crete, NE. (March 1). EPA-HQ-OW-2010-
0824 DCN 07522.
5. PA DEP, 2004. Pennsylvania Department of Environmental Protection. Facility Permit
for NPDES PA0111759 - Cargill Meat Solutions Corporation, Wyalusing, PA (March
31). EPA-HQ-OW-2010-0824 DCN 07523.
6. U.S. Economic Census. 2007. 2007 Economic Census. Available online at:
http://www.census.gov/econ/census07.
7. U.S. EPA, 2002. Development Document for the Proposed Effluent Limitations
Guidelines and Standards for the Meat and Poultry Products Industry Point Source
Category. Washington, D.C. (January). EPA-821-B-01-007.
8. U.S. EPA. 2009. Technical Support Document for the Annual Review of Existing
Effluent Guidelines and Identification of Potential New Point Source Categories.
Washington, D.C. (October). EPA-821-R-09-007.
9. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
10. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
11-12
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Section 12—Metal Finishing (40 CFR Part 433)
12. Metal Finishing (40 CFR Part 433)
EPA selected the Metal Finishing Category for preliminary review because it ranks high,
in terms of toxic-weighted pound equivalents (TWPE), in the point source category rankings.
This section summarizes the results of the 2011 Annual Reviews associated with the Metal
Finishing Category. EPA focused on discharges of silver, polychlorinated biphenyls (PCBs), and
cyanide, because of their high TWPE relative to the other pollutants in the Metal Finishing
Category.
12.1 Metal Finishing Category Background
This subsection provides the background on the Metal Finishing Category, including a
brief profile of the metal finishing industry and background on 40 CFR Part 433.
12.1.1 Metal Finishing Industry Profile
The Metal Finishing Category includes plants that engage in changing the surface of an
object to improve its appearance and/or durability. It also includes direct discharging plants that
engage in processes related to electroplating, which is the production of a thin surface coating of
one metal on another by electrodeposition (U.S. EPA, 1983). The Metal Finishing Category
includes 200 North American Industry Classification System (NAICS) codes (corresponding to
178 Standard Industrial Classification, or SIC, codes).
The sources of the discharge monitoring report (DMR) data used to develop
DMRLoads2009 report facilities by SIC code; the U.S. Economic Census and Toxics Release
Inventory (TRI) report data by NAICS code. Accordingly, EPA reclassified the 2009 DMR data
by the equivalent NAICS code. See Section 4.2.1.2 of the 2009 SLA Report for additional details
(U.S. EPA, 2009). Table 12-1 lists the number of facilities from the 2007 U.S. Economic Census
and the toxicity rankings databases for the 200 industrial categories with operations in the Metal
Finishing Category. The U.S. Economic Census includes more facilities than the toxicity
rankings databases for many reasons: facilities may not meet TRI-reporting thresholds, facilities
may discharge to a publicly owned treatment works (POTW), and some facilities in the U.S.
Economic Census are distributors or sales facilities, not manufacturers.
Table 12-1. Number of Metal Finishing Facilities
2007 U.S.
Economic Census
2009 DMR
2009 TRI
Total
Minor
Major
Total
Indirect
Dischargers
Only
Direct
Dischargers
Only
Both Indirect
and Direct
Dischargers
166,356
858
749
109
1,970
1,382
323
265
Sources: U.S. Economic Census (2007), TRIReleases2009jv2, and DMRLoads2009_v2.
Table 12-1 also includes the number of metal finishing facilities by major or minor
discharge status in the 2009 DMR database. As described in Section 2.1.5, permitting authorities
classify discharges as major or minor based on the potential impact of the discharge. In general,
major discharges are expected to impact receiving waters if not controlled; minor discharges may
or may not. Also as described in Section 2.1.5, the PCS and ICIS-NPDES databases include data
for a limited set of minor discharges (i.e., only those for which the state or other permitting
12-1
-------
Section 12—Metal Finishing (40 CFR Part 433)
authority chooses to include these data). Table 12-1 shows that approximately 82 percent of the
Metal Finishing Category discharges in the 2009 DMR database are minor discharges. Table
12-1 also presents the type of discharges reported by facilities in the 2009 TRI database. The
majority of the metal finishing facilities reporting to TRI reported indirect discharges to surface
waters.
12.1.2 40 CFR Part 433
EPA first promulgated effluent limitations guidelines (ELGs) for the Metal Finishing
Category (40 CFR Part 433) on September 15, 1983 (48 FR 41409). This category consists of
one subcategory (Subpart A, "Metal Finishing Subcategory") that applies to the manufacture of
products and product groups, as shown in Table 12-2 with corresponding applicability, regulated
pollutants, and limitations. In addition to best practicable control technology (BPT), best
available technology economically achievable (BAT), and new source performance standards
(NSPS), the category includes pretreatment standards for existing sources (PSES) and
pretreatment standards for new sources (PSNS) limitations.
Table 12-2. Applicability, Regulated Pollutants, and ELG Limits
for the Metal Finishing Category
Siihpiirl
A|)|)liciil)ilil>
Pnlliiliinl
HAT/PS r.s
l);iil\ M:i\
(Monlhl\
A\er;iiii') (nig/I.)
NSPS/PSNS l);iil\
M:i\ (Mnn(hl\
A\er;i;ii') img/l.)
Subpart A -
Metal
Finishing
Subcategory
The provisions of this subpart apply to
discharges from the following six metal
finishing operations on any basis material:
Electroplating, Electroless Plating,
Anodizing, Coating (chromating,
phosphating, and coloring), Chemical
Etching and Milling, and Printed Circuit
Board Manufacture. a'b,c
Silver
0.43 (0.24)
0.43 (0.24)
Copper
3.38 (2.07)
3.38 (2.07)
Lead
0.69 (0.43)
0.69 (0.43)
Cyanide
1.20 (0.65)
1.20 (0.65)
Cadmium
0.69 (0.26)
0.11 (0.07)
Chromium
2.77 (1.71)
2.77(1.71)
Nickel
3.98 (2.38)
3.98 (2.38)
Zinc
2.61 (1.48)
2.61 (1.48)
For industrial facilities with cyanide
treatment, and upon agreement between a
source subject to those limits and the
pollution control authority, the following
amenable cyanide limit may apply in place
of the total cyanide limit.
Cyanide
amenable to
alkaline
chlorination
0.86 (0.32)
0.86 (0.32)
Source: 40 CFR §433.10.
a If any of those six operations are present, then this part applies to discharges from those operations and also to
discharges from any of the following 40 process operations: cleaning, machining, grinding, polishing, tumbling,
burnishing, impact deformation, pressure deformation, shearing, heat treating, thermal cutting, welding, brazing,
soldering, flame spraying, sand blasting, other abrasive jet machining, electric discharge machining,
electrochemical machining, electron beam machining, laser beam machining, plasma arc machining, ultrasonic
machining, sintering, laminating, hot dip coating, sputtering, vapor plating, thermal infusion, salt bath descaling,
solvent degreasing, paint stripping, painting, electrostatic painting, electropainting, vacuum metalizing, assembly,
calibration, testing, and mechanical plating.
b In some cases, effluent limitations and standards for industrial categories may be effective and applicable to
wastewater discharges from the metal finishing operations listed above. In such cases these part 433 limits shall
not apply and the applicable industrial category regulations shall apply.
0 This part does not apply to (1) metallic platemaking and gravure cylinder preparation conducted within or for
printing and publishing facilities or (2) existing indirect discharging job shops and independent printed circuit
board manufacturers which are covered by 40 CFR part 413.)
12-2
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Section 12—Metal Finishing (40 CFR Part 433)
12.2 Metal Finishing Category 2011 Toxicity Rankings Analysis
Table 12-3 compares the toxicity rankings analysis results for the Metal Finishing
Category from the 2009 through 2011 Annual Reviews. The combined DMR and TRI TWPE
decreased from discharge years 2007 to 2009. The estimated 2009 DMR TWPE accounts for
approximately 69 percent of the combined 2009 DMR and TRI TWPE.
Table 12-3. Metal Finishing Category TRI and DMR Discharges for the 2009 Through
2011 Toxicity Rankings Analyses
Year of Discharge
Year of Review
Metal. Finishing Category
TRI TWPE'1
DMR TWPEb
Total TWPE
2007°
2009
62,000
3,360,000
3,422,000
2008°
2010
74,400
463,000
537,400
2009
2011
86,100
197,000
283,100
Sources: TRI Releases 2007 v2, DMRLoads2007_v4, TRlReleases2008_v3, DAiRLoads2008_v3;
TRlReleases2009jv2', and DMRLoads2009_v2.
" Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2007 include only major dischargers. DMR 2008 data include both minor and major
dischargers.
0 EPA did not review discharges from the Metal Finishing Category as part of the 2009 and 2010 Annual
Reviews because the category had recently undergone review and therefore could include data entry errors.
12.3 Metal Finishing Category Pollutants of Concern
EPA's review of the Metal Finishing Category focused on the 2009 DMR discharges
because the 2009 DMR data dominate the category's combined TWPE. Table 12-4 lists the five
pollutants with the highest TWPE based on results from the 2011 Annual Reviews
(DMRLoads2009_v2). The top three DMR-reported pollutants in 2009 contribute more than 76
percent of the category's 2009 DMR TWPE. As a result, EPA's review, presented in the
following subsections, focused on the top three DMR database pollutants of concern: silver,
cyanide, and PCB-1248. EPA did not investigate the other top pollutants as part of the 2011
Annual Reviews because they account for a minority (45 percent) of the 2009 Metal Finishing
Category DMR TWPE.
Table 12-4. Metal Finishing Category Top DMR Pollutants
Pollutant
2009 DMR Data'1
Rank
Number of Facilities
Reporting Pollutant
TWPE
Silver
1
56
44,800
Cyanide
2
114
39,400
PCB-1248
3
2
24,200
Lead
4
123
17,300
Cadmium
5
65
16,900
Metal Finishing Category Total
NA
360b
142,600
Source: DMRLoads2009_v2.
a DMR data include major and minor dischargers.
b Number of facilities reporting a TWPE of greater than zero.
12-3
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Section 12—Metal Finishing (40 CFR Part 433)
12.4 Metal Finishing Category Silver Discharges in DMR
Silver discharges from metal finishing facilities in the 2009 DMR database account for
23 percent of the category's 2009 DMR TWPE. Table 12-5 presents the facilities that account for
the silver discharges in the 2009 DMR database. Discharges of silver from one facility, Eastman
Kodak Company's Kodak Park Facility, account for over 91 percent of the category's silver
DMR TWPE. Accordingly, EPA focused on this top facility.
Table 12-5. Metal Finishing Category Silver Dischargers in the 2009 DMR Database
Facility Name
Location
Silver Pounds
Discharged
Silver TWPE
Facility Percent
of Silver
Category TWPE
Eastman Kodak Company, Kodak
Park Facility
Rochester, NY
2,490
41,100
91.6%
Remaining Facilities Reporting Silver Discharges3
227
3,750
8.4%
Total
2,720
44,800
100%
Source: DMRLoads2009_v2.
a There are 55 remaining facilities that have silver discharges in the 2009 DMR database, which account for 8
percent of the category's silver DMR TWPE.
Eastman Kodak Park in Rochester, NY discharges silver via Outfall 001. Outfall 001
includes discharges of process wastewater (including water from associated activities) and
stormwater to the Genesee River. Table 12-6 presents Eastman Kodak Park's 2009 monthly silver
and flow discharge data in the DMR Loadings Tool for outfall 001. Table 12-6 also presents the
back-calculated silver concentrations, calculated using the 2009 silver quantity and flow values.
Table 12-6. Eastman Kodak Park 2009 Monthly Silver and Flow
Discharge Data for Outfall 001
Monitoring Period Date
DMR Loadings Tool
Monthly Average Silver
Discharge (kg/day)
DMR Loadings Tool
Average Flow (MGD)
Back-Calculated
Concentrations
(mg/L)
31-Jan-09
2.45
17
0.04
28-Feb-09
1.45
18
0.02
31-Mar-09
5.90
17
0.09
30-Apr-09
7.26
17
0.11
31-May-09
4.04
16
0.07
30-Jun-09
4.54
15
0.08
31-Jul-09
1.90
15
0.03
31-Aug-09
1.72
18
0.03
30-Sep-09
1.09
14
0.02
31-Oct-09
2.59
14
0.05
30-Nov-09
2.95
15
0.05
31-Dec-09
1.27
16
0.02
Source: DMR Loadings Tool.
12-4
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Section 12—Metal Finishing (40 CFR Part 433)
Eastman Kodak Park's permit limits silver discharge to 15.8 kg/day as a monthly average
and 27.2 kg/day as a daily maximum (NY DEC, 2009). The Metal Finishing ELG silver limits
are 0.24 mg/L monthly average and 0.43 mg/L daily maximum. The BAT treatment technology
options used to develop the ELG basis for the concentration based silver limit are chemical
precipitation and clarification at the final effluent (U.S. EPA, 1983). As shown in Table 12-6, the
2009 silver quantities do not exceed the mass-based permit limitations or concentration-based
ELG limitations for silver. As part of the 2011 Annual Reviews, EPA also contacted the facility
to confirm their 2009 flow data for outfall 001. Eastman Kodak Part confirmed that EPA was
estimating the silver load with the correct flow for 2009 (Bishopp, 2011). Therefore, EPA
determined that the silver discharges are likely accurate. As new data become available, EPA
will continue to review flow and silver discharges for this facility.
12.5 Metal Finishing Category Cyanide Discharges in DMR
Cyanide discharges from metal finishing facilities in the 2009 DMR database account for
20 percent of the category's DMR TWPE. Table 12-7 presents the cyanide dischargers in the
2009 DMR database. Discharges of cyanide from one facility, Eastman Kodak Company's
Windsor Facility (Eastman Windsor), account for 98 percent of the category's cyanide DMR
TWPE. Accordingly, EPA focused its review of cyanide discharges on this top facility.
Table 12-7. Metal Finishing Category Cyanide Dischargers in the 2009 DMR Database
Facility Name
Location
Cyanide Pounds
Discharged
Cyanide TWPE
Facility Percent
of Cyanide
Category TWPE
Eastman Kodak Company, Windsor
Facility
Windsor, CO
34,600
38,400
98%
Remaining Facilities Reporting Cyanide Discharges3
844
937
2%
Total
35,500
39,400
100%
Source: DMRLoads2009_v2.
a There are 113 remaining facilities that have cyanide discharges in the 2009 DMR database, which account for
28 percent of the category's cyanide DMR TWPE.
Eastman Windsor in Windsor, CO discharges cyanide from outfall 001. Table 12-8
presents Eastman Windsor's 2008 and 2009 monthly cyanide and flow discharge data in the DMR
Loadings Tool and Envirofacts for outfall 001. The reported monthly average cyanide
concentrations for 2009 were 1,000 times higher than 2008 concentrations. Due to the difference
in the order of magnitude of the cyanide concentrations from 2008 to 2009, EPA determined that
a unit of measurement error had occurred for all monitoring periods in 2009. Using corrected
cyanide concentration data, Eastman Windsor's cyanide discharges decrease to 37 pounds and 41
TWPE for 2009, reducing the facility's total TWPE by over 99 percent. This reduction in TWPE
decreases the Metal Finishing Category's 2009 DMR TWPE by 38,392 TWPE, making cyanide
no longer be a top pollutant of concern.
12-5
-------
Section 12—Metal Finishing (40 CFR Part 433)
Table 12-8. Eastman Kodak Windsor 2008 and 2009 Monthly Cyanide and Flow
Discharge Data for Outfall 001
Monitoring Period Date
DMR Loadings Tool Monthly
Average Cyanide Concentration
(mg/L)
Envirofacts Average Flow (MGD)
31-Jan-08
0
1.08
29-Feb-08
0
0.92
31-Mar-08
0.011
0.72
30-Apr-08
0.02
0.86
31-May-08
0.028
0.94
30-Jun-08
0
1.2
31-Jul-08
<0.01
1.25
31-Aug-08
<0.01
1.43
30-Sep-08
0.016
1.23
31-Oct-08
<0.01
1.15
30-Nov-08
<0.01
1.15
31-Dec-08
0.023
0.88
31-Jan-09
32
1.02
28-Feb-09
27
0.89
31-Mar-09
21.5
0.73
30-Apr-09
<10
0.89
31-May-09
6
0.96
30-Jun-09
5.5
0.89
31-Jul-09
< 10
1.12
31-Aug-09
6.5
1.2
30-Sep-09
7.5
1.01
31-Oct-09
9.5
0.87
30-Nov-09
11.5
0.84
31-Dec-09
9.5
1.12
Sources: DMR Loadings Tool and Envirofacts.
12.6 Metal Finishing Category PCB-1248 Discharges in DMR
PCB-1248 discharges in the 2009 DMR database account for 12 percent of the total DMR
TWPE. Table 12-9 presents the two metal finishing PCB-1248 dischargers in the 2009 DMR
database. Discharges of PCB-1248 from General Motors Powertrain's Tonawanda Engine Plant
account for over 95 percent of the category's PCB-1248 DMR TWPE.
Table 12-9. Metal Finishing Category PCB-1248 Dischargers in the 2009 DMR Database
Facility Name
Location
PCB-1248
Pounds
Discharged
PCB-1248
TWPE
Facility Percent
of PCB-1248
Category TWPE
General Motors Powertrain -
Tonawanda Engine Plant
Buffalo, NY
2.53
23,100
95%
12-6
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Section 12—Metal Finishing (40 CFR Part 433)
Table 12-9. Metal Finishing Category PCB-1248 Dischargers in the 2009 DMR Database
Facility Name
Location
PCB-1248
Pounds
Discharged
PCB-1248
TWPE
Facility Percent
of PCB-1248
Category TWPE
General Motors Powertrain - Massena
Plant
Massena, NY
0.12
1,100
5%
Total
2.65
24,200
100%
Source: DMRLoads2009 v2.
12.6.1 General Motors Powertrain, Tonawanda Engine Plant
The General Motors Powertrain (GM) Tonawanda Engine Plant in Buffalo, NY
discharges PCB-1248 from outfall 001. Outfall 001 comprises non-contact cooling water,
remediation system discharge, garage sump flow, and stormwater. The GM Tonawanda plant
began operating in the 1950s. It consisted of three major operations: the engine plant, the forge
facility, and the foundry complex. GM Tonawanda still operates an expanded engine plant today,
but it sold the forge facility in 1994 and shut down the foundry complex in 1984. The foundry
complex and accompanying buildings (wastewater treatment facilities) were demolished between
1996 and 1998. PCBs at the GM Tonawanda facility were historically used in the foundry and
forge facilities. The remediation system discharge at this facility includes the removal of sand
and concrete contaminated with PCBs. The demolition plan for the foundry complex included
collection, treatment, and discharge of PCB-contaminated wastewaters that had been in contact
with the foundry sand and concrete; handling and disposal of foundry sand; characterization and
handling of PCB-contaminated concrete; and completion of the project by filling the basement
with flowable fill (NY DEC, 2003b).
Table 12-10 presents GM Tonawanda's 2009 monthly PCB-1248 concentrations and
flow discharge data in the DMR Loadings Tool for outfall 001, with the permit-enforceable
compliance level. GM Tonawanda's 2009 PCB-1248 concentrations do not exceed the facility
permit-enforceable compliance level. The 2009 flow for outfall 001 is also in compliance with
the facility permit limits of 13.5 MGD monthly average and 25 MGD daily maximum. EPA
determined that the data are likely accurate, and GM Tonawanda is likely discharging
approximately 2.5 pounds of PCB-1248 from outfall 001 annually. However, the outfall contains
remediation system discharge, which is not related to the manufacturing process but rather to
cleanup of sand and concrete contaminated with PCBs from a foundry complex previously
operated onsite.
Table 12-10. GM Tonawanda Outfall 001 2009 Monthly PCB-1248
Discharge and Flow Data
Monitoring Period Date
DMR Loadings Tool
PCB-1248 Concentration
(lig/L)
Facility Pcrmit-
Enfo rccablc Co m pi iancc
Level Limit (|xg/L)
DMR Loadings Tool
Average Flow (MGD)
31-Jan-09
0.095
0.3
2.84
28-Feb-09
0
0.3
7.10
31-Mar-09
0
0.3
5.34
30-Apr-09
0
0.3
5.84
12-7
-------
Section 12—Metal Finishing (40 CFR Part 433)
Table 12-10. GM Tonawanda Outfall 001 2009 Monthly PCB-1248
Discharge and Flow Data
Monitoring Period Date
DMR Loadings Tool
PCB-1248 Concentration
(Jig/L)
Facility Pcrmit-
Ent'orccable Compliance
Level Limit (fig/L)
DMR Loadings Tool
Average Flow (MGD)
31-May-09
0
0.3
5.14
30-Jun-09
0
0.3
4.05
31-Jul-09
0
0.3
8.09
31-Aug-09
0.19
0.3
9.16
30-Sep-09
0.098
0.3
8.73
31-Oct-09
0.09
0.3
9.43
30-Nov-09
0
0.3
7.84
31-Dec-09
0
0.3
7.68
Sources: DMR Loadings Tool and Facility Fact Permit (NY DEC, 2003a).
12.6.2 General Motors Powertrain — Massena Plant
General Motors Powertrain Massena Plant (GM Massena) in Massena, NY discharges
PCB-1248 from three outfalls: 001, 003, and 005. Outfall 001 discharges process wastewater
from aluminum casting production and sanitary wastewater, while outfalls 003 and 005
discharge noncontact cooling water, storm water, and storm water treatment discharge (NY DEC,
2010). The GM Massena plant was originally built in 1958 to produce aluminum cylinder heads.
The plants used PCBs from 1959 to 1974 as a component of the hydraulic fluids in its die casting
process. Since 1974, the GM Massena plant has continued manufacturing engine blocks without
using the die casting process. In the early 1960s, a reclamation system was installed to recover
used hydraulic fluid. PCB sludges were periodically landfilled in onsite areas (U.S. EPA Region
2, 2010). Stormwater and ground water from these landfills continues to be discharged but is not
part of active manufacturing processes. Therefore, the PCB discharges are legacy discharges and
the facility is no longer using or manufacturing PCBs onsite (U.S. EPA Region 2, 2010).
Table 12-11 presents GM Massena's 2009 monthly PCB-1248 concentrations and flow
discharge data in the DMR Loadings Tool with the permit-enforceable compliance level. GM
Massena's 2009 PCB-1248 average monthly concentrations for outfalls 001 and 003 were above
the facility permit enforceable compliance level in July 2009, while outfall 005 PCB-1248 2009
concentrations were below the limit for all of 2009. EPA calculated the associated TWPE with
these exceedances using the monthly average concentrations and the daily maximum permit
limit. EPA determined that the amount of TWPE associated with the July 2009 exceedances is
approximately 200 TWPE. This facility appears to be exceeding its concentration-based permit
PCB-1248 concentration for outfalls 001 and 003 for the July reporting period in 2009.
12-8
-------
Section 12—Metal Finishing (40 CFR Part 433)
Table 12-11 GM Massena 2009 Monthly PCB-1248 Discharge and Flow Data
Monitoring
Period Date
DMR Loadings Tool PCB-
1248 Average Monthly
Concentration (jig/L)
Facility Permit-
Enforceable Compliance
Level Limit (jig/L)
DMR Loadings Tool Average
Flow (MGD)
Outfall 001
31-Jan-09
0
0.3
0.138
28-Feb-09
0.1
0.3
0.147
31-Mar-09
0.1
0.3
0.166
30-Apr-09
0.019
0.3
0.145
31-May-09
0
0.3
0.074
30-Jun-09
0
0.3
0.142
31-Jul-09
0.56
0.3
0.102
31-Aug-09
NODIC
0.3
NODIC
30-Sep-09
<0.051
0.3
0.185
31-Oct-09
<0.05
0.3
0.082
30-Nov-09
<0.05
0.3
0.105
31-Dec-09
NODIC
0.3
NODIC
Outfall 003
31-Jan-09
0
0.3
0.084
28-Feb-09
0.3
0.3
0.212
31-Mar-09
0
0.3
0.190
30-Apr-09
0.06
0.3
0.158
31-May-09
0.07
0.3
0.192
30-Jun-09
0.13
0.3
0.092
31-Jul-09
0.79
0.3
0.202
31-Aug-09
NODIC
0.3
NODIC
30-Sep-09
<0.051
0.3
0.434
31-Oct-09
<0.05
0.3
0.266
30-Nov-09
<0.05
0.3
0.230
31-Dec-09
<0.05
0.3
0.376
12-9
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Section 12—Metal Finishing (40 CFR Part 433)
Table 12-11 GM Massena 2009 Monthly PCB-1248 Discharge and Flow Data
Monitoring
Period Date
DMR Loadings Tool PCB-
1248 Average Monthly
Concentration (jig/L)
Facility Permit-
Enforceable Compliance
Level Limit (jig/L)
DMR Loadings Tool Average
Flow (MGD)
Outfall 005
31-Jan-09
0
0.3
0.040
28-Feb-09
0
0.3
0.038
31-Mar-09
0
0.3
0.254
30-Apr-09
0
0.3
0.144
31-May-09
0
0.3
0.029
30-Jun-09
NODIC
0.3
NODIC
31-Jul-09
0.1
0.3
0.332
31-Aug-09
0.09
0.3
0.365
30-Sep-09
NODIC
0.3
NODIC
31-Oct-09
<0.05
0.3
0.301
30-Nov-09
NODIC
0.3
NODIC
31-Dec-09
<0.05
0.3
0.294
Sources: DMR Loadings Tool and Facility Fact Permit (NY DEC, 2010).
NODI C: The facility did not report a concentration or flow because no discharge occurred for the monitoring
period.
12.7 Metal Finishing Category Conclusions
The estimated toxicity of the Metal Finishing Category discharges resulted from silver,
cyanide, and PCB-1248 discharges. Using data collected for the 2011 Annual Reviews, EPA
concludes the following:
• Eastman Kodak Park's 2009 silver quantities and concentrations did not exceed
mass-based permit limits or the concentration-based ELG limits for the Metal
Finishing Category. Therefore, EPA determined that the silver discharges are
likely accurate. As future data becomes available, EPA will continue to review
flow and silver discharges for this facility.
• There are database errors for discharges of cyanide from Eastman Windsor. With
these errors corrected, the Metal Finishing Category's cyanide TWPE decreases
by over 97 percent, from 39,370 TWPE to 978 TWPE.
• GM Tonawanda and GM Massena facilities are discharging PCBs. The PCB
discharges result from remediation systems and landfills, not metal manufacturing
processes. The GM Tonawanda facility is not exceeding its concentration-based
permit limits for PCB-1248. However, the GM Massena facility is exceeding the
concentration-based permit PCB-1248 limit, specifically during the reporting
period for July 2009. Permit limit exceedances do not warrant the need for further
regulation, but they do call for better facility compliance. EPA will continue to
review PCB discharges from the GM facilities.
12-10
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Section 12—Metal Finishing (40 CFR Part 433)
• The amount of TWPE corresponding to the July 2009 exceedances for the GM
Massena facility is 220 TWPE. In addition, the PCB discharges are not related to
manufacturing processes regulated by the Metal Finishing. Therefore, these
discharges do not indicate a need to consider revision of existing ELGs.
• Correcting the database errors identified during the 2011 Annual Reviews
decreases the 2009 Metal Finishing Category TWPE from 196,502 TWPE to
158,110 TWPE. The Metal Finishing Category continues to rank high due to the
high number of facilities (over 1,900) in the industry. EPA will continue to review
the Metal Finishing Category discharges to determine if they are properly
controlled.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
12.8 Metal Finishing Category References
1. Bishopp, Mary Lee. 2011. Telephone and Email Communications Between Mary Lee
Bishopp, Eastman Kodak, and Elizabeth Sabol, Eastern Research Group, Inc., Re:
Eastman Kodak Flows—2009. (August 3). EPA-HQ-OW-2010-0824. DCN 07534.
2. NY DEC. 2003a. New York State Department of Environmental Conservation. NPDES
Permit: General Motors Powertrain—Tonawanda Engine Plant, Buffalo, NY. EPA-HQ-
OW-2010-0824. DCN 07535.
3. NY DEC. 2003b. New York State Department of Environmental Conservation. 2003.
GM Powertrain—Report. (March 27). EPA-HQ-OW-2010-0824. DCN 07536.
4. NY DEC. 2009. New York State Department of Environmental Conservation. NPDES
Permit: Eastman Kodak Company, Rochester, NY. EPA-HQ-OW-2010-0824. DCN
07537.
5. NY DEC. 2010. New York State Department of Environmental Conservation. NPDES
Permit: General Motors Powertrain—Massena Plant, Massena, NY. EPA-HQ-OW-2010-
0824. DCN 07538.
6. U.S. Economic Census. 2007. Available online at: http://www.census.gov/econ/census07.
7. U.S. EPA. 1983. Development Document for Effluent Limitations Guidelines New
Source Performance Standards for the Metal Finishing Point Source Category.
Washington, D.C. (June). EPA-440-1-83-091.
8. U.S. EPA. 2009. Technical Development Document for the Annual Review of Existing
Guidelines and Identification of Potential New Point Source Categories. Washington,
D.C. (October). EPA-HQ-OW-2008-0517-0515.
12-11
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Section 12—Metal Finishing (40 CFR Part 433)
9. U.S. EPA Region 2. 2010. General Motors (Central Foundry Division). New York
(October 5). EPA-HQ-OW-2010-0824. DCN 07541.
10. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
12-12
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
13. Mineral Mining and Processing (40 CFR Part 436)
EPA selected the Mineral Mining and Processing (Mineral Mining) Category for
preliminary review because it continues to rank high, in terms of toxic-weighted pound
equivalent (TWPE), in the point source category rankings. This industry was reviewed
previously in EPA's Final 2004 and 2010 Effluent Guidelines Program Plans (U.S. EPA, 2004,
2011). This section summarizes the results of the 2011 Annual Reviews, which focused on
discharges of cadmium, fluoride, and chlorine, due to their high TWPE relative to the other
pollutants in the Mineral Mining Category and the 2010 Annual Reviews findings.
13.1 Mineral Mining Category 2011 Toxicity Rankings Analysis
Table 13-1 compares the toxicity rankings analysis results for the Mineral Mining
Category from the 2006 through 2011 Annual Reviews. The combined discharge monitoring
report (DMR) and Toxics Release Inventory (TRI) TWPE decreased from discharge years 2004
to 2007, increased from discharge years 2007 to 2008, and decreased again from 2008 to 2009.
The estimated 2009 DMR TWPE accounts for over 93 percent of the combined 2009 DMR and
TRI TWPE, similar to previous years of data.
Table 13-1. Mineral Mining Category TRI and DMR Discharges for the
2006 Through 2011 Toxicity Rankings Analyses
Year of Discharge
Year of Review
Mineral Mining Category
TRI TWPE"
DMR TWPEb
Total TWPE
2002
2006
2,840
50,500
53,300
2004
2007
5,390
49,300
54,700
2005
2008
6,260
NA
NA
2007
2009
2,420
26,700
29,100
2008
2010
3,390
100,000
103,000
2009
2011
5,430
80,100
85,500
Sources: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v2;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2007 include only major dischargers. DMR 2008 and 2009 data include both minor and major
dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
13.2 Mineral Mining Category Pollutants of Concern
EPA's review of the Mineral Mining Category focused on the 2009 DMR discharges
because the 2009 DMR data dominate the category's combined TWPE. Table 13-2 lists the five
pollutants with the highest TWPE based on results from the 2011 and 2010 Annual Reviews
(DMRLoads2009_v2 and DMRLoads2008 v3, respectively). The top five DMR-reported
pollutants in 2009 contribute more than 87 percent of the total category TWPE.
13-1
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
Table 13-2. Mineral Mining Category Top DMR Pollutants
Pollutant
2008 DMR Data3
2009 DMR Data"
Rank
Number of Facilities
Reporting Pollutant
TWPE
Rank
Number of Facilities
Reporting Pollutant
TWPE
Cadmium
Pollutants not reported in the top five 2008 DMR-reported
pollutants.
1
6
17,600
Fluoride
2
20
28,200
2
22
15,800
Chlorine
Pollutants not reported in the top five 2008 DMR-reported
pollutants.
3
13
15,000
Lead
5
12
5,940
4
12
13,200
Chloride
4
27
6,690
5
23
8,310
Sulfide
1
5
35,900
Pollutants not reported in the top five 2009 DMR-reported
pollutants.
Ammonia as N
3
28
11,100
Mineral Mining Category
Total
NA
120b
100,000
NA 139b
80,100
Sources: DMRLoads2008jv2 and DMRLoads2009_v2.
a DMR data include major and minor dischargers.
b Number of facilities reporting a TWPE of greater than zero.
NA: Not applicable.
13-2
-------
Section 13—Mineral Mining and Processing (40 CFR Part 436)
EPA's additional review of the Mineral Mining Category's 2009 DMR database
pollutants of concern focused on cadmium, fluoride, and chlorine, presented in the following
subsections. EPA continued its review of fluoride based on findings from the 2010 Annual
Reviews. EPA did not investigate the other top pollutants as part of the 2011 Annual Reviews
because they account for a small percentage (27 percent) of the 2009 DMR TWPE for the
Mineral Mining Category.
Of the pollutants of concern for the Mineral Mining Category, 40 CFR Part 436 only
regulates fluoride in the Industrial Sand Subcategory (Subpart D). The majority of fluoride
discharges in this category are from facilities covered by the Phosphate Rock Subcategory
(Subpart R), which does not regulate fluoride (U.S. EPA, 2011).
13.3 Mineral Mining Category Cadmium Discharges in DMR
Cadmium discharges in the 2009 DMR database account for 22 percent of the total DMR
TWPETable 13-3 presents the cadmium dischargers in the 2009 DMR database. Discharges of
cadmium from two facilities, Butala Sand and Gravel and Doe Run Buick Mine/Mill, account for
over 99 percent of the category's cadmium DMR TWPE. Accordingly, EPA focused its review
of cadmium discharges on these top two facilities.
Table 13-3. Mineral Mining Category Cadmium Dischargers in the 2009 DMR Database
Facility Name
Location
Cadmium
Pounds
Discharged
Cadmium
TWPE
Facility Percent
of Cadmium
Category TWPE
Butala Sand and Gravel
Salida, CO
466
10,800
61%
Doe Run Buick Mine/Mill3
Viburnum, MO
291
6,720
38%
Remaining facilities reporting cadmium discharges'5
4.1
93
< 1%
Total
762
17,600
100%
Source: DMRLoads2009 v2.
a Due to an EPA enforcement settlement, Doe Run is required to lower cadmium discharges at all Doe Run
facilities in Missouri (including the Buick Mine/Mill). Because the settlement includes Doe Run's cadmium
discharges, EPA will not review the facility's discharges as part of the 2011 Annual Reviews (U.S. EPA, 2010).
b There are four remaining facilities that have cadmium discharges in the 2009 DMR database, which account for
0.5 percent of the category's cadmium DMR TWPE.
13.3.1 Butala Sand and Gravel
Butala Sand and Gravel (Butala) in Salida, CO discharges cadmium from outfall 002.
Table 13-4 presents Butala's 2009 quarterly cadmium and flow discharge data in the DMR Loadings
Tool for outfall 002. After reviewing the flow data from the DMR Loadings Tool, EPA determined
that the December 2009 flow is 1,000 times higher than the flow in preceding periods. Using a
corrected value of 0.434 million gallons per day (MGD) for the December 2009 outfall 002 flow,
Butala's cadmium discharges are 0.92 pounds and 21.27 TWPE for 2009, reducing the facility's total
TWPE by over 99 percent. This reduction decreases the Mineral Mining Category's 2009 DMR
TWPE by 11,000, making cadmium no longer be a top pollutant of concern.
13-3
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
Table 13-4. Butala 2009 Monthly Cadmium and Flow Discharge Data for Outfall 002
Monitoring Period Date
DMR Loadings Tool
Average Cadmium
Concentration (mg/L)
DMR Loadings Tool
Average Flow (MGD)
Corrected Average
Flow (MGD)
31-Mar-09
NODIC
NODIC
NODIC
30-Jun-09
0.0011
0.15
0.15
30-Sep-09
< 0.00062
0.439
0.439
31-Dec-09
0.0014
434
0.434
Source: DMR Loadings Tool.
NODI C: The facility did not report a concentration or flow because no discharge occurred for the monitoring
period.
13.4 Mineral Mining Category Fluoride Discharges in DMR
Fluoride discharges in the 2009 DMR database account for 20 percent of the total DMR
TWPE. Table 13-5 presents the fluoride dischargers in the 2009 DMR database. EPA focused its
review of fluoride discharges on the top five facilities, which account for over 71 percent of the
category's fluoride 2009 DMR TWPE.
Table 13-5. Mineral Mining Category Fluoride Dischargers in the 2009 DMR Database
Facility Name
Location
Fluoride
Pounds
Discharged
Fluoride
TWPE
Facility Percent
of Fluoride
Category TWPE
Mosaic Fertilizer, LLC, Ft. Green
Mine Complex
Fort Green, FL
130,000
3,900
25%
US Agri-Chemicals, Ft. Meade
Fort Meade, FL
125,000
3,760
24%
Mosaic Fertilizer, LLC, Four Corners
Mine
Polk County, FL
48,200
1,450
9%
Feldspar Corp. Spruce Pine Facility
Spruce Pine, NC
37,000
1,110
7%
South Fort Meade Mine
Nichols, FL
36,900
1,110
7%
Remaining facilities reporting fluoride discharges3
149,000
4,470
28%
Total
526,000
15,800
100%
Source: DMRLoads2009_v2.
a There are 17 remaining facilities that have fluoride discharges in the 2009 DMR database, which account for 28
percent of the category's cadmium DMR TWPE.
The majority of the fluoride discharges for the Mineral Mining Category come from
phosphate mines in Florida and feldspar mines in North Carolina. These fluoride discharges
result from mineral mining processes that are regulated by Subparts R (Phosphate Rock) and AI
(Feldspar). Neither Subpart R nor Subpart AI sets limits for fluoride (Subpart AI is reserved).
EPA previously compiled information on this category from the 1976 Development Document
for Interim Final Effluent Limitations Guidelines and Standards of Performance—Mineral
Mining and Processing Industry. A summary of EPA's review is found in Section 9.5.1 of the
2010 Technical Support Document (U.S. EPA, 2011).
The top five fluoride discharging facilities account for the majority (71 percent) of
fluoride discharges in 2009. This subsection provides information on each facility's fluoride
13-4
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
discharges from the 2009 DMR Loadings Tool and their corresponding permit limits, if
available.
13.4.1 US Agri-Chemicals Corporation
US Agri-Chemicals Corporation (US Agri-Chemicals) in Fort Meade, FL manufactures
sulfuric acid, phosphoric acid, mono-ammonium phosphate, di-ammonium phosphate, and
fluosilicic acid. US Agri-Chemicals also has a lined phosphogypsum stack and an unlined
process water cooling pond with a recirculation system. As of 2004, the facility was working
with the state to close the unlined pond. The facility's 2004 NPDES permit also allows the
facility to construct an additional lined phosphogypsum stack. The facility treats wastewater
from both ponds through a two-stage lime treatment and spray aeration process before discharge
(FL DEP, 2004).
Based on the facility's permit and fact sheet, EPA believes that the facility's operations
fall within the applicability of the Fertilizer Manufacturing Effluent Limitations Guidelines, or
ELGs (40 CFR Part 418) rather than the Mineral Mining ELGs (40 CFR Part 436) because the
facility does not have any mining operations. Therefore, discharges from this facility should be
excluded from the 2011 Annual Reviews of the Mineral Mining Category, reducing the
category's TWPE by 3,760.
13.4.2 Feldspar Corporation Spruce Pine Facility
The Feldspar Corporation (Feldspar) in Spruce Pine, NC is an industrial minerals
processing facility. The facility produces feldspar, quartz, and mica. Outfall 001 discharges
treated process wastewater to the North Toe River. The facility's treatment system includes
clarifiers, a polymer feed system, lime for pH adjustment, vacuum filters, and an Emico
clarifier/thickener to outfall 001 (NCDENR, 2006).
The facility discharges fluoride from outfall 001. Previously, the facility treated
discharges from Unimin Corporation's Crystal Operation, and the fluoride permit limits for the
facility were 102 kilograms per day (kg/day) monthly average and 203 kg/day daily maximum.
However, once Unimin began directly discharging, Feldspar's fluoride limits were revised to
78.9 kg/day monthly average and 157 kg/day daily maximum (NCDENR, 2006). The North
Carolina Division of Water Quality permit writer for this facility confirmed that Unimin
Corporation did not start directly discharging to the North Toe River until 2010 (Nowell, 2011);
therefore, the higher limits applied to the 2009 fluoride discharges. As presented in Table 13-6,
the 2009 average monthly quantities for outfall 001 did not exceed the monthly or maximum
mass-based permit limitation. The facility also has a monthly average flow permit limit of 3.5
MGD for outfall 001. As presented in Table 13-6, the 2009 monthly average flows do not exceed
3.5 MGD.
EPA back-calculated the average and maximum 2009 fluoride concentrations, presented
in Table 13-6, using the quantity and flow. The average and maximum calculated concentrations
exceed the freshwater aquatic life water quality standard of 1.8 milligrams per liter, or mg/L
(U.S. EPA, 2007). However, the facility's permit writer stated that the North Toe River's total
fluoride allocation had been calculated using the water quality standard and the river's lowest
seven-day average flow that occurs (on average) once every 10 years. The permit writer then
divided the total fluoride allocation between the five feldspar mines along the North Toe River
13-5
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
based on facility design capacity to determine the mass-based permit limits. The permit writer
also stated that the North Carolina Division of Water Quality monitors fluoride concentrations
using ambient monitoring stations to confirm that fluoride levels in the North Toe River are
below 1.8 mg/L. The permit writer confirmed that the fluoride levels did not exceed 1.8 mg/L.
Because the 2009 average fluoride quantities are below the permit limit, EPA determined
that the fluoride discharges and flows are likely accurate, and the Feldspar Corporation in Spruce
Pine, NC is likely discharging more than 37,000 pounds of fluoride annually. These feldspar
mine fluoride discharges are geographically isolated to North Carolina, and permit writers have
enacted permit limits to ensure that fluoride levels do not exceed the water-quality-based permit
limits. As a result, these discharges are being controlled and do not indicate the need for a
national ELG. EPA will continue to review fluoride discharges from feldspar mines in North
Carolina.
Table 13-6. Feldspar 2009 Monthly Fluoride and Flow Discharge Data for Outfall 002
Monitoring
Period Date
DMR Loadings
Tool Average
2009 Fluoride
Quantity
(kg/day)
DMR Loadings
Tool Maximum
2009 Fluoride
Quantity
(kg/day)
Back-Calculated
Average
Fluoride
Concentration
(mg/L)
Back-Calculated
Maximum
Fluoride
Concentration
(mg/L)
DMR Loadings
Tool Average
2009 Flow
(MGD)
31-Jan-09
35.7
194
4.10
22.3
2.3
28-Feb-09
50.9
140
5.87
16.2
2.29
31-Mar-09
33.7
101
4.95
14.9
1.80
30-Apr-09
34.9
125
5.71
20.5
1.61
31-May-09
26.9
92.5
4.64
16.0
1.53
30-Jun-09
59.1
123
8.78
18.3
1.78
31-Jul-09
31.9
156
5.22
25.6
1.61
31-Aug-09
59.7
125
7.79
16.3
2.02
30-Sep-09
64.8
155
7.75
18.5
2.21
31-Oct-09
55.5
124
6.48
14.4
2.26
30-Nov-09
49.9
167
5.93
19.9
2.22
31-Dec-09
50.3
112
5.65
12.6
2.35
Source: DMR Loadings Tool.
13.5 Florida Fluoride Dischargers
Three of the top five fluoride dischargers are phosphate mines in Florida. The fluoride
permit limits for all the Florida discharges is 10.0 mg/L. The fluoride permit limits of 10 mg/L
are based on Table 62-302.230, "Surface Water Quality Criteria," in the Florida Administrative
Code (FL DEP, 2000, 2003 a, 2003b). The Florida Department of Environmental Protection (FL
DEP) Mining and Minerals Phosphate Management contact stated that the usual fluoride
concentration from the phosphate mines in Florida is approximately 3 mg/L; therefore, there has
been no action to revise the state's fluoride water quality criteria or research new treatment
technologies for fluoride discharges. The FL DEP contact also stated that it is difficult to
estimate the actual discharge area of these mines because the acreage and outfalls change
constantly with mining operations (Champion, 2011). A summary of each top fluoride discharger
in Florida is provided below.
13-6
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
13.5.1 Mosaic Fertilizer, LLC, Fort Green Mine Complex
The Mosaic Fertilizer, LLC, Fort Green and Payne Creek Mines (Fort Green Mine
Complex) in Fort Green, FL discharges fluoride from six outfalls: 001, 002, 003, 004, 005, and
006. The Fort Green Mine Complex operations include phosphate mining and beneficiation
facilities, phosphatic clay settling areas, sand tailings disposal areas, and a mine water
recirculation system. The mine water recirculation system discharges treated excess process
wastewater, stormwater runoff, and reclaimed wastewater from the outfalls listed above. At this
facility, phosphate ore is strip-mined by dragline, then slurried in a pit with high-pressure water
cannons and pumped to the beneficiation plant, where the fine clays and sands are separated
from the product phosphate rock. This separation is achieved by washing, screening, and double
flotation. The separated clays are pumped to waste clay settling areas. Sand tailings are pumped
as slurry to mined areas for use as reclamation fill. Decanted water from the clay settling areas is
returned to the beneficiation plant and discharged as necessary (FL DEP, 2003a).
The facility's wastewater treatment facilities include settling basins where mine
dewatering and process-generated wastewater from the phosphate mining and beneficiation
(offsite) operations and stormwater runoff are sent. The discharge consists of clarified water
from the water recirculation system. All process wastewater to be discharged first passes through
active settling areas, where contaminants are retained with the settled clays (FL DEP, 2003a).
Table 13-7 presents the 2009 quarterly fluoride and flow discharge data from the DMR
Loadings Tool, along with the daily maximum fluoride permit limit and the average design flow
reported in the facility permit fact sheet (FL DEP, 2003a). The 2009 daily maximum fluoride
concentrations did not exceed the daily maximum permit limitation of 10 mg/L. The flows
reported for each outfall vary compared to the facility permit fact sheet flows; however,
discharges are dependent on the rainfall contributions to the system in excess of the available
storage capacity and the inflow of ground water into mining cuts (FL DEP, 2003a).
Because the quarterly fluoride concentrations do not exceed permit limits, EPA
determined that the fluoride discharges and flows are likely accurate, and the Fort Green Mine
Complex is likely discharging more than 128,000 pounds of fluoride annually.
Table 13-7. Fort Green Mine Complex 2009 Fluoride and Flow Discharge Data
Outfall
Monitoring
Period Date
DMR Loadings Tool
Daily Maximum
Fluoride
Concentration (mg/L)
Daily Maximum
Fluoride Permit
Limit (mg/L)
DMR Loadings
Tool Monthly
Flow (MGD)
Facility Fact Sheet
Average Flow
(MGD)
001
31-Mar-09
NODIC
10.0
NODIC
0.207
001
30-Jun-09
NODIC
10.0
NODIC
001
30-Sept-09
0.98
10.0
NODIC
001
31-Dec-09
NODIC
10.0
NODIC
002
31-Mar-09
NODIC
10.0
NODIC
4.273
002
30-Jun-09
1.69
10.0
9.19
002
30-Sept-09
1.12
10.0
25.6
002
31-Dec-09
0.76
10.0
12.17
003
31-Mar-09
NODIC
10.0
NODIC
0
003
30-Jun-09
1
10.0
31.38
13-7
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
Table 13-7. Fort Green Mine Complex 2009 Fluoride and Flow Discharge Data
Outfall
Monitoring
Period Date
DMR Loadings Tool
Daily Maximum
Fluoride
Concentration (mg/L)
Daily Maximum
Fluoride Permit
Limit (mg/L)
DMR Loadings
Tool Monthly
Flow (MGD)
Facility Fact Sheet
Average Flow
(MGD)
003
30-Sept-09
NODIC
10.0
NODIC
003
31-Dec-09
NODIC
10.0
NODIC
004
31-Mar-09
0.67
10.0
NODIC
0
004
30-Jun-09
0.62
10.0
25.43
004
30-Sept-09
0.69
10.0
35.3
004
31-Dec-09
0.78
10.0
37.67
005
31-Mar-09
1.27
10.0
NODIC
24.89
005
30-Jun-09
1.26
10.0
10.01
005
30-Sept-09
1.18
10.0
49
005
31-Dec-09
0.97
10.0
18.85
006
31-Mar-09
1.02
10.0
NODIC
0
006
30-Jun-09
NODIC
10.0
NODIC
006
30-Sept-09
0.73
10.0
1.02
006
31-Dec-09
0.66
10.0
0.96
Sources: DMR Loadings Tool and facility permit fact sheet (FL DEP, 2003a).
NODI C: The facility did not report a concentration or flow because no discharge occurred for the monitoring
period.
13.5.2 Mosaic Fertilizer, LLC, Four Corners Mine
The Mosaic Fertilizer, LLC Four Corners Mine (Four Corners Mine) in Polk County, FL
discharges fluoride from outfalls 001 and 002. The Four Corners Mine operations include
phosphate mining and beneficiation facilities, phosphatic clay settling areas, sand tailings
disposal areas, and a mine water recirculation system. The mine water recirculation system
discharges treated excess process wastewater, non-process wastewater, groundwater seepage,
and stormwater runoff from the outfalls listed above. Facility activities include the mining of
phosphate ore. The mined ore is slurried into a pit and then pumped to the beneficiation plant,
where the fine clays and sands are separated from the phosphate rock by washing, screening, and
double flotation. The generated wet phosphate rock is transferred to another location for further
processing. The separated clays are pumped to waste clay settling areas. Sand tailings are
pumped as a slurry to mined areas for use as reclamation fill. Decanted waters from the clay
settling areas, ground waters from mine pits, and stormwater runoff are returned to the
beneficiation plant for reuse, and excess water is discharged as necessary (FL DEP, 2003b).
The facility's wastewater treatment facilities include settling basins where mine
dewatering and process generated wastewater from the phosphate mining and beneficiation
operations and stormwater runoff are sent. The discharge consists of clarified water from the
water recirculation system. All process wastewater to be discharged first passes through active
settling areas, where contaminants are retained with the settled clays (FL DEP, 2003b).
Table 13-8 presents the 2009 monthly discharge data for fluoride and flow from the DMR
Loadings Tool. Table 13-8 also presents the daily maximum fluoride permit limit (FL DEP,
2003a). The DMR Loadings Tool 2009 monthly average fluoride concentrations data for these
outfalls did not exceed the daily maximum permit limitation of 10 mg/L.
13-8
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
Table 13-8. Four Corners Mine 2009 Fluoride and Flow Discharge Data
Outfall
Monitoring Period Date
DMR Loadings Tool
Daily Maximum
Fluoride Coneentration
(mg/L)
Daily Maximum
Fluoride Permit Limit
(mg/L)
DMR Loadings Tool
Monthly Flow
(MGD)
001
31-Jan-09
NODI 9
10.0
NODIC
001
28-Feb-09
NODI 9
10.0
NODIC
001
31-Mar-09
NODI 9
10.0
NODIC
001
30-Apr-09
NODI 9
10.0
NODIC
001
31-May-09
NODI 9
10.0
18.4
001
30-Jun-09
1.5
10.0
60.5
001
31-Jul-09
NODI 9
10.0
55.5
001
31-Aug-09
NODI 9
10.0
52
001
30-Sep-09
2
10.0
50.8
001
31-Oct-09
NODI 9
10.0
1.52
001
30-Nov-09
NODIC
10.0
NODIC
001
31-Dec-09
NODIC
10.0
NODIC
002
31-Jan-09
NODI 9
10.0
NODIC
002
28-Feb-09
NODI 9
10.0
NODIC
002
31-Mar-09
NODI 9
10.0
NODIC
002
30-Apr-09
NODI 9
10.0
NODIC
002
31-May-09
NODI 9
10.0
13
002
30-Jun-09
1.6
10.0
43
002
31-Jul-09
NODI 9
10.0
30
002
31-Aug-09
NODI 9
10.0
4.7
002
30-Sep-09
1.8
10.0
11.6
002
31-Oct-09
NODIC
10.0
NODIC
002
30-Nov-09
NODIC
10.0
NODIC
002
31-Dec-09
2.2
10.0
30
Sources: DMR Loadings Tool and facility permit fact sheet (FL DEP, 2003b).
NODI C: The facility did not report a concentration or flow because no discharge occurred for the monitoring
period.
NODI 9: The facility did not report a concentration because of conditional monitoring.
Table 13-9 presents the average annualized flow from each of the outfalls 001 and 002
during 2009. The total flow through these outfalls is higher than the discharges described by the
facility in the 2003 permit fact sheet (total flow in 2002); however, discharges are dependent on
the rainfall contributions to the system in excess of the available storage capacity and the inflow
of ground water into mining cuts (FL DEP, 2003b).
Because the quarterly fluoride concentrations do not exceed permit limits, EPA
determined that the fluoride discharges and flows are likely accurate, and the Four Corners Mine
is likely discharging more than 48,000 pounds of fluoride annually from outfalls 001 and 002
combined.
13-9
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
Table 13-9. Four Corners Mine 2009 Flow Discharge Data
Outfall
DMR Loadings Tool Average Flow
(MG/year)
Permit Faet Sheet Flow in 2002 (IMG/vear)
001
14,522
3,185
002
8,048
1,183
Sources: DMR Loadings Tool and facility permit fact sheet (FL DEP, 2003b).
13.5.3 South Fort Meade Mine
South Fort Meade Mine in Nichols, FL discharges wastewater and stormwater from its
outfall 001. South Fort Meade Mine operations include phosphate mining and beneficiation
facilities, phosphatic clay settling areas, sand tailings disposal areas, and a mine water
recirculation system. Facility activities include the mining and washing of phosphate ore. The
mined ore is slurried into a pit and pumped to the beneficiation plant where the fine clays and
sand are separated from the phosphate rock by washing, screening, and double flotation. The
generated wet phosphate rock is transported to another location for further processing. The
separated clays are pumped to settling areas. Sand tailings are pumped as a slurry to mined areas
for use as reclamation fill or are stored above grade for later use in reclamation. Decanted waters
from the clay settling areas, ground waters from mine pits, and stormwater runoff are returned to
the beneficiation plant for reuse, and excess water is discharged as necessary (FL DEP, 2000).
Table 13-10 presents the quarterly 2009 average fluoride concentration and flow data for
outfall 001 in the DMR Loadings Tool. South Fort Meade Mine did not exceed the daily
maximum permit limitation of 10.0 mg/L. The facility does not have a limitation on total flow.
Table 13-10 below presents the DMR Loadings Tool 2009 monthly average total flow data for
outfall 001.
Because the quarterly fluoride concentrations do not exceed permit limits, EPA
determined that the fluoride discharges and flows are likely accurate, and the South Fort Meade
Mine is likely discharging more than 36,000 pounds of fluoride annually from outfall 001.
Table 13-10. South Fort Meade Mine 2009 Monthly Fluoride and Flow
Discharge Data for Outfall 001
Monitoring Period Date
DMR Loadings Tool Maximum
Fluoride Concentration (mg/L)
DMR Loadings Tool Average Flow
(MGD)
31-Mar-09
NODIC
NODIC
30-Jun-09
1.9
1.23
30-Sep-09
1.25
22.63
31-Dec-09
1.57
12.59
Source: DMR Loadings Tool.
NODI C: The facility did not report a concentration or flow because no discharge occurred for the monitoring
period.
13.5.4 Fluoride Wastewater Treatment
EPA determined that the top fluoride discharging facilities have two-stage chemical
precipitation with lime treatment systems. This process is similar to that at phosphatic fertilizer
13-10
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
manufacturing facilities, which achieve fluoride concentrations of 15 mg/L or less (U.S. EPA,
1974). Current technologies are achieving fluoride concentrations at least as effective, sometimes
achieving 2 mg/L effluent fluoride. Using calcium chloride rather than lime has improved
chemical precipitation, while using polymers and membrane filters has improved solids
separation (WC&E, 2006; Ionics, n.d.; GCIP, 2002).
13.6 Mineral Mining Category Chlorine Discharges in DMR
Chlorine discharges in the 2009 DMR database account for 19 percent of the total DMR
TWPE. Table 13-11 lists the facilities discharging chlorine in the 2009 DMR database.
Discharges of chlorine from one facility, Carmeuse Lime and Stone, Inc., account for over 94
percent of the category's chlorine DMR TWPE. As a result, EPA focused its review of cadmium
discharges on that facility.
Table 13-11. Mineral Mining Category Chlorine Dischargers in the 2009 DMR Database
Facility Name
Location
Chlorine
Pounds
Discharged
Chlorine TWPE
Facility Percent
of Chlorine
Category TWPE
Carmeuse Lime & Stone, Inc.
Butler, KY
28,400
14,200
94%
Remaining facilities reporting Chlorine discharges3
1,670
836
6%
Total
30,000
15,000
100%
Source: DMRLoads2009_v2.
a - There are 12 remaining facilities that have chlorine discharges in the 2009 DMR database, which account for 6
percent of the category's cadmium DMR TWPE.
Carmeuse Lime and Stone, Inc. (Carmeuse) in Butler, KY discharges chlorine from
outfall 015. Table 13-12 presents Carmeuse's 2009 monthly chlorine and flow discharge data in
the DMR Loadings Tool for outfall 015. In reviewing the flow data from the DMR Loadings
Tool, EPA found a unit of measurement error for the February 2009 flow, the reported flow for
this month was 1,000 times higher than for other months in 2009, as presented in Table 13-12.
Using a corrected value of 0.0011 MGD for the February 2009 outfall 015 flow, Carmeuse's
chlorine discharges are 81 pounds and 40.42 TWPE for 2009, reducing the facility's total TWPE
by over 99 percent. This reduction in TWPE decreases the Mineral Mining Category's 2009
DMR TWPE to 40.42, making chlorine no longer a top pollutant of concern.
Table 13-12. Carmeuse 2009 Monthly Chlorine and Flow Discharge Data for Outfall 015
Monitoring Period Date
DMR Loadings Tool
Maximum Chlorine
Concentration (mg/L)
DMR Loadings Tool
Average Flow (MGD)
Corrected Average
Flow (MGD)
31-Jan-09
0.7
0.004
0.004
28-Feb-09
11
11
0.0011
31-Mar-09
5.5
0.0029
0.0029
31-Jul-09
1.1
0.0031
0.0031
30-Sep-09
0.7
0.0029
0.0029
31-Oct-09
0.5
0.0058
0.0058
30-Nov-09
75.5
0.0035
0.0035
13-11
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
Table 13-12. Carmeuse 2009 Monthly Chlorine and Flow Discharge Data for Outfall 015
Monitoring Period Date
DMR Loadings Tool
Maximum Chlorine
Concentration (mg/L)
DMR Loadings Tool
Average Flow (MGD)
Corrected Average
Flow (MGD)
31-Dec-09
4.86
0.004
0.004
Source: DMR Loadings Tool.
13.7 Mineral Mining Category Conclusions
Based on available data, the estimated toxicity of the Mineral Mining Category
discharges in the toxicity rankings databases result from cadmium, fluoride, and chlorine
discharges. Data collected for the 2011 Annual Reviews demonstrated that wastewater discharge
characteristics for this category are consistent with discharges from prior years. As in prior years,
EPA concludes the following:
• The fluoride discharges in the Mineral Mining Category result from phosphate
and feldspar mining facilities regulated by Subpart R (Phosphate Rock) and
Subpart AI (Feldspar; reserved), respectively. These facilities are also located in
areas with naturally occurring fluoride compounds in the ore: Florida and North
Carolina. Subparts R and AI do not regulate fluoride; however, permit limits are
derived from state water quality standards.
• Feldspar Corporation likely discharged over 37,000 pounds of fluoride into the
North Toe River in 2009; however, the discharge did not exceed mass-based
permit limitations. Subpart AI (Feldspar) of the Mineral Mining Category does
not currently regulate fluoride discharges. The North Carolina Division of Water
Quality developed the fluoride permit limits using the state water quality standard.
The Division monitors the North Toe River's in-stream fluoride concentration to
ensure it does not exceed the water quality standard (Nowell, 2011). Because
these feldspar mine fluoride discharges are geographically isolated to North
Carolina and do not exceed water-quality-based permit limits, EPA will continue
to review fluoride discharges from Feldspar Corporation as new data become
available.
• The fluoride discharges from US Agri-Chemicals' operations were
misrepresented in the toxicity rankings databases. The Mineral Mining Category
is not applicable to these operations; rather, they fall within the Fertilizer
Manufacturing Category (40 CFR Part 418). EPA will reassign this facility to the
correct category and will review its discharges in future annual reviews under the
Fertilizer Manufacturing Category.
• The three remaining Florida mines reviewed, Mosaic Fertilizer's Fort Green Mine
Complex and Four Corners Mine and South Fort Meade Mine, have fluoride
concentrations that do not exceed water-quality-based permit limitations (10
mg/L) or treatable concentrations (15 mg/L) using two-stage chemical
precipitation with lime treatment systems. The FL DEP permit contact stated that
fluoride discharges from these phosphate mines do not approach the state water
13-12
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
quality standard and are therefore not a concern for permit writers (Champion,
2011).
• EPA identified database errors for discharges of cadmium and chlorine. After
correcting these errors, the Mineral Mining Category TWPE from cadmium
decreased by over 60 percent, from 17,600 to 6,740, and does not represent a
hazard priority. The TWPE from chlorine decreased by over 90 percent, from
15,000 to 876, and therefore does not represent a hazard priority.
• Correcting the database errors identified during the 2011 Annual Reviews
decreases the 2009 Mineral Mining Category TWPE from 80,100 to 55,200.
Excluding discharges from facilities that are not considered part of the 2011
Annual Reviews of the Mineral Mining Category, the TWPE decreases to 44,700.
EPA will continue to review the Mineral Mining Category discharges to
determine if they are properly controlled.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
13.8 Mineral Mining Category References
1. Champion, Jacquelyn. 2011. Notes From Telephone Communications Between Jacquelyn
Champion, FL DEP, and Elizabeth Sabol, Eastern Research Group, Inc., Re: Fluoride
Discharges from Phosphate Mines in Florida. (August 26). EPA-HQ-OW-2010-0824.
DCN 07542.
2. FL DEP. 2000. Florida Department of Environmental Protection. NPDES Permit:
FL0037958—Car gill Fertilizer, Inc. South Fort Meade Mine, Fort Meade, FL. EPA-HQ-
OW-2010-0824. DCN 07553.
3. FL DEP. 2003a. Florida Department of Environmental Protection. NPDES Permit Fact
Sheet: FL0027600—Mosaic Fertilizer, LLC, Bradley, FL. EPA-HQ-OW-2010-0824.
DCN 07543.
4. FL DEP. 2003b. Florida Department of Environmental Protection. NPDES Permit Fact
Sheet: FL0036412—Mosaic Fertilizer, LLC, Bradley Junction, FL. EPA-HQ-OW-2010-
0824. DCN 07544.
5. FL DEP. 2004. Florida Department of Environmental Protection. NPDES Permit: US
Agri-Chemicals Corporation, Fort Meade, Florida. EPA-HQ-OW-2010-0824. DCN
07545.
6. GCIP. 2002. General Chemical Industrial Products. Chapter 14: Wastewater and Water
Treatment. Available online at: http://www.genchem.com/calcium/NChl4.html. Date
accessed: July 27, 2006. DCN 03761.
13-13
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Section 13—Mineral Mining and Processing (40 CFR Part 436)
7. Ionics, n.d. "The EnChem® Process for Fluoride Removal." Wastewater Treatment for
the Microelectronics Industry. Available online at:
http://www.iconics.com/pdf/TS4752EUS.pdf. Date accessed: July 27, 2006. EPA-HQ-
OW-2004-0032-2605.
8. NCDENR. 2006. North Carolina Department of Environment and Natural Resources,
Division of Water Quality. NPDES Permit Fact Sheet: NC0000353—Feldspar
Corporation, Spruce Pine, NC. EPA-HQ-OW-2010-0824. DCN 07548.
9. Nowell, Jacquelyn. 2011. Notes From Telephone Communications Between Jacquelyn
Nowell, NCDENR, and Elizabeth Sabol, Eastern Research Group, Inc., Re: Fluoride
Discharges from Feldspar Corporation in North Carolina. (August 24). EPA-HQ-OW-
2010-0824. DCN 07550.
10. U.S. EPA. 1974. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Basic Fertilizer Chemicals Segment of the
Fertilizer Manufacturing Point Source Category. EPA-440/l-75/042-a. Washington, DC.
(March).
11. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
12. U.S. EPA. 2007. Numeric Criteria for Standard, Metal, and Priority Pollutants Applicable
to Specific Designated Uses of the State. (August). EPA-HQ-OW-2010-0824. DCN
07551.
13. U.S. EPA. 2010. Civil Enforcement: Doe Run Resources Corporation Settlement.
Washington, D.C. (October 8). EPA-HQ-OW-2010-0824. DCN 07552.
14. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
15. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
16. WC&E. 2006. Wastech Controls & Engineering, Inc. Fluoride Wastewater Treatment
(FWT) (HF Neutralization or Fluoride Reduction. Available online at:
http://www.wastechengineering.com/papers/hf.htm. Date accessed: July 27. EPA-HQ-
OW-2004-0032-2604.
13-14
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
14. Nonferrous Metals Manufacturing (40 CFR Part 421)
EPA selected the Nonferrous Metals Manufacturing (NFMM) Category (40 CFR Part 421)
for preliminary review because it continues to rank high, in terms of toxic-weighted pound equivalent
(TWPE), in point source category rankings. EPA reviewed discharges from the NFMM Category as
part of the 2004, 2006, 2007, and 2009 reviews (U.S. EPA, 2004, 2006, 2007, 2009). This section
summarizes the results of the 2011 Annual Reviews associated with the NFMM Category. EPA
focused on discharges of mercury, fluoride, lead, cadmium, and molybdenum, because of their high
TWPE relative to other pollutants in the NFMM Category. For further background on the NFMM
Category, see the Technical Support Document for the 2009 Effluent Guidelines Program Plan (U.S.
EPA, 2009).
14.1 NFMM Category 2011 Toxicity Rankings Analysis
Table 14-1 compares the toxicity rankings database results for the NFMM Category from
the 2006 through 2011 Annual Reviews. The combined TWPE from discharges in the discharge
monitoring report (DMR) and Toxics Release Inventory (TRI) databases increased from
discharge year 2002 to 2008 and decreased from 2008 to 2009. The 2009 DMR TWPE accounts
for approximately 81 percent of the combined 2009 DMR and TRI TWPE category, which is
consistent with previous years.
Table 14-1. NFMM Category TRI and DMR Discharges for 2006 Through 2011 Toxicity
Rankings Analyses
Year of
Discharge
Year of
Review
NFMM Category
TRI TWPE"
DMR TWPEb
Total TWPE
2002
2006
51,800
397,000
449,000
2004
2007
52,600
321,000
374,000
2005
2008
41,800
NA
NA
2007
2009
38,900
343,000
382,000
2008
2010
38,700
463,000
503,000
2009
2011
40,500
174,000
215,000
Sources: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v2;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 include only major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
14.2 NFMM Category Pollutants of Concern
EPA's review of the NFMM Category focused on the 2009 DMR discharges because the
2009 DMR data account for 81 percent of the category's combined TWPE. Table 14-2 lists the
five pollutants with the highest DMR TWPE based on results from the 2011 and 2010 Annual
Reviews (DMRLoads2009 v2 and DMRLoads2008 v2, respectively). The top five DMR-
reported pollutants in 2009 contribute more than 70 percent of the category's DMR TWPE.
EPA's additional review of the NFMM Category's 2009 DMR database pollutants of concern
focused on all top five pollutants, presented in the following subsections.
14-1
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
Table 14-2. 2009 NFMM Category Top DMR Pollutants
Pollutant
2008 DMR Database"
2009 DMR Database"
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Mercury
4
6
34,500
1
4
29,100
Fluoride
5
17
26,100
2
17
24,700
Lead
1
26
183,000
3
20
24,300
Cadmium
3
15
53,400
4
11
22,900
Molybdenum
Pollutants not reported in the top five
2008 DMR-reported pollutants.
5
3
22,000
Polychlorinated biphenyls
(PCBs)
2
2
93,400
Pollutants not reported in the top five
2009 DMR-reported pollutants.
NFMM Category Total
NA
51b
463,000
NA
48b
174,000
Sources: DMRLoads2008_v3 and DMRLoads2009_v2.
a DMR data include major and minor dischargers.
b Number of facilities reporting a TWPE of greater than zero.
NA: Not applicable.
14.3 NFMM Category Mercury Discharges in DMR
Mercury discharges from NFMM facilities in the 2009 DMR database account for over
16 percent of the category's 2009 DMR TWPE. Table 14-3 presents the facilities with mercury
discharges in the 2009 DMR database. Discharges of mercury from one facility, Alabama State
Docks Mud Lakes (AL State Docks), account for over 99 percent of the category's mercury
DMR TWPE. As a result, EPA focused its review of mercury discharges on that facility.
Table 14-3. NFMM Category Top Mercury Discharging Facilities
in the 2009 DMR Database
Facility Name
Facility Location
Total Pounds
Pollutant
TWPE
Percent of Category's
DMR Mercury TWPE
AL State Docks - Mud Lakes
Mobile, AL
249
29,100
> 99%
Remaining facilities reporting mercury3
0.23
26.7
< 1%
Total
249
29,100
100%
Source: DMRLoads2009_v2.
a There are three remaining facilities that have mercury discharges in the 2009 DMR database, which account for
less than 1 percent of the category's mercury DMR TWPE.
EPA reviewed the mercury discharges from AL State Docks as part of the 2010 Annual
Reviews (see Section 7.4.2 of the Technical Support Document for the 2010 Effluent Guidelines
Program Plan for more information on the facility) (U.S. EPA, 2011). EPA determined that the
facility's discharges result from former aluminum ore tailings lakes, not from current
manufacturing. AL State Dock's 2009 mercury discharges are comparable to the facility's 2008
14-2
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
discharges, which EPA verified as part of the 2010 Annual Reviews. Because the facility no
longer operates as an aluminum ore mine and processing facility, its discharges do not warrant
the need for revision of national effluent guidelines for this category. For these reasons, EPA is
considering facility-specific permitting compliance to address this facility's mercury discharges.
14.4 NFMM Category Fluoride Discharges in DMR
Fluoride discharges from NFMM facilities in the 2009 DMR database account for
approximately 14 percent of the category's DMR TWPE. Table 14-4 presents the facilities with
fluoride discharges in the 2009 DMR database. Discharges of fluoride from one plant, Horsehead
Corporation, account for 80 percent of the category's fluoride DMR TWPE. As a result, EPA
focused its review of fluoride discharges on the top facility.
Table 14-4. NFMM Category Top Fluoride Discharging Facility in the 2009 DMR
Database
Facility Name
Facility Location
Total Pounds
Pollutant
TWPE
Percent of Category's
DMR Mercury
TWPE
Horsehead Corporation
Monaca, PA
656,000
19,700
80%
Remaining Facilities Reporting Fluoride a
166,000
4,990
20%
Total
823,000
24,700
100%
Source: DMRLoads2009_v2.
a There are 16 remaining facilities that have fluoride discharges in the 2009 DMR database, which account for 20
percent of the category's fluoride DMR TWPE.
Horsehead Corporation in Monaca, PA owns and operates a zinc smelter and ancillary
units to produce zinc metal, zinc oxide, zinc dust, zinc sulfate, and sulfuric acid. Horsehead
Corporation is a zinc smelter that is subject to 40 CFR Part 421 Subpart H (Primary Zinc
Subcategory). Subpart H does not regulate fluoride discharges. From the 2009 DMR data,
Horsehead Corporation is the only zinc smelter that reports fluoride discharges.
The facility discharges process wastewater through outfall 101 and noncontact cooling
water through outfall 102 (PA DEP, 2001). The facility discharges the resulting commingled
wastewater through outfall 001 to the Ohio River (PA DEP, 2001). The average flow for outfall
101 is 0.75 MGD, approximately 15 percent of the design flow through outfall 001 (5.1 MGD).
The permit only requires monitoring for fluoride at the internal outfall 101. It does not set
numerical limits and does not require monitoring of fluoride at outfall 001. Due to high levels of
fluoride reported in the facility's 2000 permit application, the Pennsylvania Department of
Environmental Protection required the facility to develop a pollution reduction report and
monitor for fluoride.
As part of the 2011 Annual Reviews, EPA contacted Horsehead to confirm the fluoride
discharges. The facility contact stated that the fluoride discharges at outfall 101 were accurate.
The facility contact also stated that the primary sources of fluoride in the wastewater result from
the crude zinc oxide (CZO) and calcined CZO processes. Both sources are responsible for
approximately the same amount of fluoride in the process. The CZO enters the process through
the CZO clarifier system. In the process, some fluoride may dissolve in the clarifier overflow,
which is sent to the facility's wastewater treatment plant. The CZO filter cake is then processed
14-3
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
in the sinter plant with calcine. The sinter plant generates sinter and a fume byproduct. The sinter
is sent to the furnace plant, where the majority of the fluoride exits the process via discard slag.
The plant also generates an aqueous waste stream, which is sent to the zinc sulfide clarifier
system. Similar to the CZO clarifier system, some fluoride dissolves and is sent to the
wastewater treatment plant via the clarifier overflow. The wastewater treatment includes
clarification, designed to eliminate heavy metals. However, the clarifier does not remove fluoride
due to the solubility of fluoride at the clarifier's operational pH range. Therefore, the discharge
from outfall 101 contains fluoride (Swisher, 2011).
To estimate the fluoride load at the final effluent, EPA calculated the fluoride
concentrations at the final effluent, outfall 001, using the 2009 DMR Loadings Tool fluoride
concentration and flow data (0.75 MGD monthly average) for outfall 101 and the design flow
(5.1 MGD) presented in the facility fact sheet for outfall 001 (PA DEP, 2001). Table 14-5
presents the 2009 DMR monthly fluoride and flow discharge data and the calculated fluoride
concentrations at outfall 001 for Horsehead Corporation.
Treatment technologies available for fluoride discharges include two-stage chemical
precipitation with lime treatment systems, a process similar to fluoride treatment at phosphatic
fertilizer manufacturing facilities. This treatment process can achieve fluoride concentrations of
15 mg/L or less (U.S. EPA, 1974). Current technologies are achieving fluoride concentrations at
least as effective, sometimes achieving 2 mg/L effluent fluoride. The chemical precipitation has
improved with the use of calcium chloride rather than lime, while polymers and membrane filters
have improved solids separation (WC&E, 2006; Ionics, n.d.; GCIP, 2002).
The fluoride concentrations reported at outfall 101 exceed treatable levels by an order of
magnitude. Even following a 1:7 dilution, all calculated fluoride concentrations at outfall 001
exceed treatable levels, except for the calculated effluent concentration for December 2009. The
state has identified the fluoride discharge as requiring a pollutant reduction plan but did not
require a numerical effluent limit for fluoride. Therefore, EPA is considering facility-specific
permitting support to address this facility's fluoride discharges.
Table 14-5. 2009 Monthly Fluoride and Flow Discharge Data for Horsehead Corporation
Monitoring Period
Date
DMR Loadings Tool
Monthly Average Fluoride
Concentration at Outfall
101 (mg/L)
DMR Loadings Tool
Monthly Average Flow for
Outfall 101 (MGD)
Calculated Monthly
Average Concentration at
Outfall 001 (mg/L)
31-Jan-09
229
1.312
58.9
28-Feb-09
261
1.071
54.8
31-Mar-09
364
0.883
63.0
30-Apr-09
332
0.78
50.8
31-May-09
139
0.815
22.2
30-Jun-09
134
0.817
21.5
31-Jul-09
398
0.768
59.9
31-Aug-09
448
0.704
61.8
30-Sep-09
213
0.787
32.9
31-Oct-09
231
0.668
30.3
30-Nov-09
391
0.535
41.0
14-4
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
Table 14-5. 2009 Monthly Fluoride and Flow Discharge Data for Horsehead Corporation
.Monitoring Period
Date
DMR Loadings Tool
Monthly Average Fluoride
Concentration at Outfall
101 (mg/L)
DMR Loadings Tool
Monthly Average Flow for
Outfall 1.01. (MGD)
Calculated Monthly
Average Concentration at
Outfall 001 (mg/L)
31-Dec-09
178
0.285
9.9
Source: DMR Loadings Tool.
14.5 NFMM Category Lead Discharges in DMR
Lead discharges from NFMM facilities in the 2009 DMR database account for
approximately 14 percent of the category's DMR TWPE. Table 14-6 presents the facilities with
lead discharges in the 2009 DMR database. Discharges of lead from one facility, Buick
Resources Recycling in Bixby, MO, account for 87 percent of the category's lead DMR TWPE.
Accordingly, EPA focused its review on Buick Resource Recycling.
Table 14-6. NFMM Category Top Lead Discharging Facility in the 2009 DMR Database
Facility Name
Facility Location
Total Pounds
Pollutant
TWPE
Percent of Category's
DMR Mercury
TWPE
Buick Resource Recycling
Bixby, MO
9,470
21,200
87%
Remaining facilities reporting lead3
1,360
3,050
13%
Total
10,800
24,300
100%
Source: DMRLoads2009_v2.
a There are 19 remaining facilities that have lead discharges in the 2009 DMR database, which account for 13
percent of the category's lead DMR TWPE.
Buick Resource Recycling, owned by the Doe Run Company, is a secondary lead
smelting plant that recycles lead-acid batteries and other lead-bearing hazardous and non-
hazardous wastes. The wastes are recycled to recover the lead, other trace metals, sulfuric acid,
and polyethylene plastic (Doe Run, 2004). Buick Resource Recycling discharges wastewater
from three outfalls, and the permit requires lead monitoring at all three. Outfall 001 discharges
industrial process wastewater, process stormwater, and primary treated sanitary water. Outfalls
002 and 003 discharge stormwater runoff and settling basin and storm emergency overflow.
Part 421, Subpart M, Secondary Lead Manufacturing, sets limits for lead, as well as other
pollutants (e.g., 0.189 milligrams per kilogram (mg/kg) of lead as the BAT daily maximum for
battery cracking). The facility's permit sets lead limits for outfall 001 at 0.47 kg/day monthly
average and 1.17 kg/day (0.19 mg/L) daily maximum (MO DNR, 2003). The permit also states
that discharges from outfalls 002 and 003 are not authorized unless the combined flows of
outfalls 001, 002, and 003 meet the limitations of outfall 001 (MO DNR, 2003).
Table 14-7 presents Buick Resource Recycling's 2009 DMR monthly lead concentration
data for outfalls 001, 002, and 003. EPA back calculated the maximum lead concentrations from
the lead quantities and flow for outfalls 002 and 003. Using this methodology, EPA determined
that all of the daily maximum lead quantities and back-calculated concentrations for outfalls 002
and 003 exceed the daily maximum permit limitation. EPA's Office of Civil Enforcement is
14-5
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
working with this facility to resolve compliance issues and Doe Run is required to lower lead
discharges at all facilities in Missouri (including the Buick Resource Recycling facility) due to
an EPA enforcement settlement. Because of the settlement, EPA considers this facility's
discharges as not representative of the whole category, and that the facility's discharges are
being controlled through EPA's compliance process (U.S. EPA, 2010).
Table 14-7. 2009 Monthly Lead and Flow Discharge Data for Buick Resource Recycling
Monitoring Date
DMR Loadings Tool
Maximum Lead Quantity
(kg/day)
Back-Calculated Maximum
Lead Concentration (mg/L)
DMR Loadings Tool
Monthly Maximum Flow
(MGD)
Outfall 001a
31-Jan-09
0.023
0.015
0.388
28-Feb-09
0.161
0.111
0.382
31-Mar-09
0.000
0.000
0.362
30-Apr-09
0.152
0.077
0.52
31-May-09
0.053
0.023
0.599
30-Jun-09
0.372
0.174
0.565
31-Jul-09
0.007
0.005
0.376
31-Aug-09
0.043
0.036
0.314
30-Sep-09
0.052
0.028
0.497
31-Oct-09
0.075
0.030
0.658
30-Nov-09
0.218
0.100
0.575
31-Dec-09
0.204
0.149
0.363
Outfall 002
31-Jan-09
NODIC
NODIC
NODIC
28-Feb-09
NODIC
NODIC
NODIC
31-Mar-09
NODIC
NODIC
NODIC
30-Apr-09
NODIC
NODIC
NODIC
31-May-09
NODIC
NODIC
NODIC
30-Jun-09
0.211
0.30
0.185
31-Jul-09
NODIC
NODIC
NODIC
31-Aug-09
NODIC
NODIC
NODIC
30-Sep-09
NODIC
NODIC
NODIC
31-Oct-09
59.5
23.1
0.68
30-Nov-09
32.1
29.7
0.28
31-Dec-09
NODIC
NODIC
NODIC
Outfall 003
31-Jan-09
NODIC
NODIC
NODIC
28-Feb-09
1.68
0.602
0.74
31-Mar-09
NODIC
NODIC
NODIC
30-Apr-09
2.73
2.41
0.3
31-May-09
NODIC
NODIC
NODIC
30-Jun-09
25.1
8.06
0.82
31-Jul-09
NODIC
NODIC
NODIC
14-6
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
Table 14-7. 2009 Monthly Lead and Flow Discharge Data for Buick Resource Recycling
Monitoring Date
DMR Loadings Tool
Maximum Lead Quantity
(kg/day)
Back-Calculated Maximum
Lead Concentration (mg/L)
DMR Loadings Tool
Monthly Maximum Flow
(MGD)
31-Aug-09
NODIC
NODIC
NODIC
30-Sep-09
NODIC
NODIC
NODIC
31-Oct-09
38.5
2.118
4.81
30-Nov-09
3.99
3.71
0.28
31-Dec-09
NODIC
NODIC
NODIC
Sources: DMR Loadings Tool and facility-provided information (Lanzafame, 2011).
" The quantities, concentrations, and flow presented for outfall 001 are for the monthly average values.
NODI C: The facility did not report a concentration or flow because no discharge occurred for the monitoring
period.
14.6 NFMM Category Cadmium Discharges in DMR
Cadmium discharges from NFMM facilities in the 2009 DMR database account for
approximately 13 percent of the category's DMR TWPE. Table 14-8 presents facilities with
cadmium discharges in the 2009 DMR database. EPA focused its review of cadmium discharges
on the top three facilities, which account for 89 percent of the category's cadmium 2009 DMR
TWPE. However, two of the top three cadmium dischargers, both Doe Run facilities in Missouri,
are currently under compliance and enforcement actions with U.S. EPA's Office of Civil
Enforcement. Due to the enforcement settlement, the Doe Run Herculaneum facility is required
to shut down by December 21, 2013, and the Doe Run Glover Smelter discharges are being
reviewed for compliance (U.S. EPA, 2010). As a result, EPA refocused its review of cadmium
discharges on the third facility, Nyrstar Clarksville.
14-7
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
Table 14-8. NFMM Category Top Cadmium Discharging Facilities
in the 2009 DMR Database
Facility Name
Facility Location
Total Pounds
Pollutant
TWPE
Percent of Category's
Total DMR
Cadmium TWPE
Nyrstar Clarksville, Inc.
Clarksville, TN
385
8,910
39%
Doe Run, Glover Smelter3, b
Annapolis, MO
307
7,090
31%
Doe Run, Herculaneum
Smelterb
Herculaneum, MO
190
4,390
19%
Remaining facilities reporting cadmiumb
108
2,490
11%
Total
990
22,900
100%
Source: DMRLoads2009 v2.
a On December 1, 2003, operations at the Doe Run Glover Smelter, a lead smelter, were placed on "care and
maintenance" status. While on care and maintenance, the facility and equipment were kept operationally ready
and maintained all permits (Doe Run, 2004).
b Due to an EPA enforcement settlement, the Doe Run Herculaneum facility has not operated for several years
and will be completely shut down by December 21, 2013. The results of the settlement also required Doe Run
to lower cadmium discharges at all its facilities in Missouri (including Glover Smelter). Because the cadmium
discharges are already being reviewed as part of the settlement, EPA will not review the facility discharges as
part of the 2011 Annual Reviews (U.S. EPA, 2010).
0 There are 8 remaining facilities that have cadmium discharges in the 2009 DMR database, which account for
11 percent of the category's cadmium DMR TWPE.
14.6.1 Nyrstar Clarksville, Inc.
Nyrstar Clarksville, Inc., in Clarksville, TN (Nyrstar) produces zinc metal from
beneficiation of zinc concentrate ore by a hydrometallurgical process. As secondary products,
this facility also co-produces cadmium metal, sulfuric acid, and metallurgically valuable
byproducts (TN DEC, 2005). Nyrstar discharges cadmium from its outfall 001, which discharges
treated process wastewater, sanitary wastewater, and cooling water (TN DEC, 2006).
Part 421, Subpart H, Primary Zinc Manufacturing, sets limits for cadmium (e.g., 0.334
mg/kg lead as the BAT daily maximum for the zinc reduction furnace wet air pollution control).
The facility's permit limits cadmium to a monthly average of 0.798 kg/day and a daily maximum
of 1.99 kg/day (TN DEC, 2006). The facility fact sheet included the corresponding
concentrations for these limits: 0.317 mg/L monthly average and 0.793 mg/L daily maximum
(TN DEC, 2005). The NFMM ELG limits cadmium discharges in plant wastewater to 0.494
mg/kg of cadmium produced as a monthly average and 1.23 mg/kg of cadmium produced as a
daily maximum.
Treatment technologies available for cadmium discharges include two-stage chemical
precipitation with lime addition or two-stage chemical precipitation with settling and filtering, a
process similar to cadmium treatment at centralized waste treaters and/or metal finishing
manufacturing facilities. These treatment processes can achieve cadmium concentrations of 0.13
mg/L or 0.044 mg/L, respectively (ERG, 2006).
Table 14-9 presents Nyrstar's 2009 monthly average cadmium quantity and flow data
from the DMR Loadings Tool for outfall 001. Table 14-9 also includes EPA's back-calculated
monthly cadmium concentrations, derived using the monthly average quantity and flow. The
14-8
-------
Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
June 2009 monthly average quantity exceeds the facility permit limit and is above the fact
sheet's cadmium concentration basis. EPA also determined that the back-calculated
concentrations are above treatable levels. Based on these findings, these discharges do not
indicate the need for revision of national effluent guidelines, but rather facility-specific
permitting and compliance assistance.
Table 14-9. 2009 Monthly Cadmium and Flow Discharge Data for Nyrstar's Outfall 001
Monitoring
Date
DMR Loadings Tool
Average Monthly
Cadmium Quantity
(kg/day)
DMR Loadings Tool
Maximum Monthly
Cadmium Quantity
(kg/day)
Back-Calculated
Ave rage C ad mi u m
Concentration (mg/L)
DMR Loadings Tool
Average Flow (MGD)
31-Jan-09
0.358
0.372
0.19
0.51
28-Feb-09
0.367
0.603
0.17
0.56
31-Mar-09
0.467
0.667
0.21
0.58
30-Apr-09
0.390
0.449
0.17
0.61
31-May-09
0.476
0.508
0.18
0.72
30-Jun-09
0.807
0.821
0.39
0.55
31-Jul-09
0.372
0.404
0.16
0.63
31-Aug-09
0.426
0.444
0.19
0.60
30-Sep-09
0.558
0.567
0.21
0.69
31-Oct-09
0.472
0.508
0.19
0.66
30-Nov-09
0.512
0.825
0.21
0.63
31-Dec-09
0.540
0.571
0.20
0.73
Source: DMR Loadings Tool.
14.7 NFMM Category Molybdenum Discharges in DMR
Molybdenum discharges from NFMM facilities in the 2009 DMR database account for
approximately 12 percent of the category's DMR TWPE. Table 14-10 presents the facilities with
molybdenum discharges in the 2009 DMR database. Discharges of molybdenum from one
facility, GulfChem & Metallurgical Corporation in Freeport TX, account for over 99 percent of
the category's molybdenum DMR TWPE. Accordingly, EPA focused its review on GulfChem.
Table 14-10. NFMM Category Top Molybdenum Discharging Facility
in the 2009 DMR Databases
Facility Name
Facility Location
Total Pounds
Pollutant
TWPE
Percent of Category's
DMR Mercury
TWPE
GulfChem & Metallurgical Corp
Freeport, TX
110,000
22,000
> 99%
Remaining facilities reporting molybdenum3
74.6
14.9
<1%
Total
110,000
22,000
100%
Source: DMRLoads2009 v2.
There are two remaining facilities that have molybdenum discharges in the 2009 DMR database, which account
for less than 1 percent of the category's molybdenum DMR TWPE.
14-9
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
GulfChem operates a plant that recovers metals (molybdenum and vanadium) from spent
refinery hydro-desulfurizing catalysts. The plant discharges molybdenum from its outfalls 001
and 002. Outfall 001 discharges process wastewater, cooling water, domestic sewage, and
stormwater runoff from the facility.
Part 421, Subpart T, sets limits for molybdenum from many secondary molybdenum
processes (e.g., 0.000 mg/kg for molybdenum drying wet air pollution control). However,
molybdenum limits for several subcategories for Part 421, Subpart T, are reserved for both BPT
and BAT:
• Leach tailings
• Molybdenum filtrate solvent extraction raffinate
• Pure grade molybdenum
The facility's permit limits molybdenum for outfall 001 at 36.7 kg/day monthly average
and 82 kg/day daily maximum. Outfall 002 is a stormwater outfall with a daily maximum
molybdenum permit limit of 30 mg/L (TCEQ, 2003).
Table 14-11 presents the 2009 monthly molybdenum discharges for GulfChem from the
2009 DMR database. EPA compared the data from the DMR Loadings Tool to the publically
available data in Envirofacts. EPA determined that the April 2009 concentration for outfall 002
was a data entry error, given previous months of data available in Envirofacts. Using a corrected
value of 19.3 mg/L for that concentration, GulfChem's 2009 molybdenum discharges are 39,600
pounds and 7,920 TWPE, reducing the facility's total TWPE by over 51 percent. This reduction
decreases the NFMM Category's 2009 DMR TWPE by 14,100, making molybdenum no longer
a top pollutant of concern.
EPA also compared the data to the facility's permit limits and determined that the outfall
001 January, April, July, August, and December 2009 molybdenum quantities exceed the mass-
based permit limits. As a result, EPA recommends facility-specific permitting and compliance
assistance to control molybdenum discharges from the GulfChem facility.
Table 14-11. 2009 Monthly Molybdenum Data for GulfChem's Outfalls 001 and 002
Monitoring
Period Date
DMR Loadings Tool
Average Molybdenum
Quantities (kg/dav)"
DMR Loadings Tool
Average Molybdenum
Concentrations (mg/L)b
Corrected DMR Loadings
Tool Average Molybdenum
Concentrations (mg/L)
Outfall 001
31-Jan-09
58.2
61.5
NA
28-Feb-09
18.7
16.5
NA
31-Mar-09
13.2
11.9
NA
30-Apr-09
70.1
51.6
NA
31-May-09
17.9
15.4
NA
30-Jun-09
31.5
24.4
NA
31-July-09
47.7
37.6
NA
31-Aug-09
107.9
94.7
NA
30-Sep-09
23.2
23.1
NA
14-10
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
Table 14-11. 2009 Monthly Molybdenum Data for GulfChem's Outfalls 001 and 002
Monitoring
Period Date
DMR Loadings Tool
Average Molybdenum
Quantities (kg/dav)"
DMR Loadings Tool
Average Molybdenum
Concentrations (mg/L)b
Corrected DMR Loadings
Tool Average Molybdenum
Concentrations (mg/L)
31-Oct-09
72.7
75.1
NA
30-Nov-09
12.8
12.9
NA
31-Dec-09
44.6
45.7
NA
Outfall 002
31-Jan-09
NODIC
NODIC
NA
28-Feb-09
NODIC
NODIC
NA
31-Mar-09
7.15
7
NA
30-Apr-09
1,512
1,930
19.3
31-May-09
3.87
16.5
NA
30-Jun-09
NODIC
NODIC
NA
31-July-09
NODIC
NODIC
NA
31-Aug-09
NODIC
NODIC
NA
30-Sep-09
NODIC
NODIC
NA
31-Oct-09
21
16.6
NA
30-Nov-09
32.6
23.3
NA
31-Dec-09
46.6
20.8
NA
Source: DMRLoads2009_v2.
a EPA calculated the average monthly quantity for outfall 002 using the average concentration (mg/L) and the
flow (MGD) because the facility did not report a quantity value.
b EPA calculated the average monthly concentration for outfall 001 using the average quantity (kg/day) and the
flow (MGD) because the facility did not report a concentration value.
NODI C: The facility did not report a concentration or flow because no discharge occurred for the monitoring
period.
14.8 NFMM Category Conclusions
Based on available data, the estimated toxicity of the NFMM Category discharges in the
toxicity rankings databases results from mercury, fluoride, lead, cadmium, and molybdenum
discharges. Data collected for the 2011 Annual Reviews demonstrated that wastewater discharge
characteristics for this category are consistent with discharges from prior years. As in prior years,
EPA concludes the following:
• The mercury discharges from the NFMM Category result from one facility, AL
State Docks. EPA determined that this facility's mercury discharges are legacy
discharges from previous aluminum ore mining and processing operations that
have since been shut down. EPA believes that these discharges do not indicate the
need for revision of national effluent guidelines and is considering facility-
specific permitting compliance to address this facility's mercury discharges.
• The fluoride discharges from the NFMM Category result from one facility,
Horsehead Corporation. The facility contact confirmed the 2009 fluoride
discharges from outfall 101. EPA determined that this facility is reporting fluoride
14-11
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
discharges from an internal monitoring point, prior to commingling with another
outfall at the final effluent. However, EPA's calculated concentrations at the final
effluent are still higher than treatable levels achieved by two-stage chemical
precipitation with a lime treatment system. The facility contact also confirmed
that the wastewater treatment does not specifically target fluoride. EPA is
considering facility-specific permitting support to address this facility's fluoride
discharges. EPA will continue to review fluoride discharges from Horsehead
Corporation.
• The lead discharges result from one facility: Buick Resource Recycling, which
exceeded its maximum mass-based lead permit limits for all reporting periods in
2009 for stormwater outfalls 002 and 003. U.S. EPA's Office of Civil
Enforcement already identified compliance and operation problems with the Doe
Run facility and is already addressing the lead discharges.
• The cadmium discharges from the NFMM Category results from three facilities,
Nyrstar Clarksville, Inc., and two Doe Run lead smelters (Glover and
Herculaneum). EPA's Office of Civil Enforcement already identified compliance
and operation problems with the two Doe Run facilities and is already addressing
these facilities' discharges. Nyrstar exceeded its monthly average permit limits for
one month in 2009, and the back-calculated cadmium concentrations are above
treatable levels. The existing regulations already set limits for cadmium;
therefore, EPA recommends facility-specific permitting to control cadmium
discharges at this facility.
• The molybdenum discharges from the NFMM Category come from one facility,
GulfChem & Metallurgical Corporation. EPA identified a database error for this
facility. With it corrected, the NFMM Category's molybdenum TWPE decreased
by 64 percent, from 22,000 to 7,900; this means it is no longer a hazard priority.
However, the molybdenum discharges for this facility also exceed the monthly
average mass-based permit limit for five months in 2009. Therefore, EPA
recommends facility-specific permitting and compliance assistance for this
facility.
• Correcting the database errors identified during the 2011 Annual Reviews
decreases the 2009 NFMM Category TWPE from 215,000 to 200,900. Excluding
discharges from facilities that are closed or imminently closing, the TWPE
decreases to 168,200. As new data become available, EPA will continue to review
discharges from the NFMM Category to determine if the discharges are properly
controlled.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(2)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
14-12
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
14.9 NFMM Category References
1. Doe Run. 2004. Recycling. Available online at:
http://www.doemn.com/WHATWEDO/RECYCLING/tabid/74/language/en-
US/Default.aspx. Date accessed: August 11, 2011. EPA-HQ-OW-2010-0824. DCN
07568.
2. ERG. 2006. Eastern Research Group, Inc. Combined Metals Database. EPA-HQ-OW-
2010-0824. DCN 07569.
3. GCIP. 2002. General Chemical Industrial Products. Chapter 14: Wastewater and Water
Treatment. Available online at: http://www.genchem.com/calcium/NChl4.html. Date
accessed: July 27, 2006. DCN 03761.
4. Ionics, n.d. The EnChem® Process for Fluoride Removal. Wastewater Treatment for the
Microelectronics Industry. Available online at:
http://www.iconics.com/pdf/TS4752EUS.pdf. Date accessed: July 27, 2006. DCN 03760.
5. Lanzafame, Jim. 2011. Letter Correspondence Between James Lanzafame, Doe Run
Resource Recycling Division, and Elizabeth Sabol, Eastern Research Group, Inc., Re:
Request for Historical DMRs. (August 17). EPA-HQ-OW-2010-0824. DCN 07577.
6. MO DNR. 2003. Missouri Department of Natural Resources. NPDES Permit: Doe Run
BuickResource Recycling, Boss, Missouri. (November 1). EPA-HQ-OW-2010-0824.
DCN 07547.
7. PA DEP. 2001. Commonwealth of Pennsylvania Department of Environmental
Protection. NPDES Permit: Horsehead Corporation, Monaca, Pennsylvania. (August 2).
EPA-HQ-OW-2010-0824. DCN 07572.
8. Swisher, David. 2011. Telephone and Email Correspondence Between David Swisher,
Horsehead Corporation, and Elizabeth Sabol, Eastern Research Group, Inc., Re: 2009
DMR Fluoride Discharges. (August 24). EPA-HQ-OW-2010-0824. DCN 07578.
9. TCEQ. 2003. Texas Commission on Environmental Quality. NPDES Permit: Gulf
Chemical & Metallurgical Corporation, Freeport, Texas. (April 23). EPA-HQ-OW-
2010-0824. DCN 07575.
10. TN DEC. 2005. Tennessee Department of Environment and Conservation. NPDES
Permit Fact Sheet: Nyrstar Clarksville, Inc., Clarksville, Tennessee. (May 31). EPA-HQ-
OW-2010-0824. DCN 07573.
11. TN DEC. 2006. Tennessee Department of Environment and Conservation. NPDES
Permit: Nyrstar Clarksville, Inc, Clarksville, Tennessee. (June 1). EPA-HQ-OW-2010-
0824. DCN 07574.
12. U.S. EPA. 1974. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Basic Fertilizer Chemicals Segment of the
14-13
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Section 14—Nonferrous Metals Manufacturing (40 CFR Part 421)
Fertilizer Manufacturing Point Source Category. Washington, D.C. (March). EPA-440-1-
75-042-a.
13. U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
14. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
15. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
16. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-0517-0515.
17. U.S. EPA. 2010. Civil Enforcement: Doe Run Resources Corporation Settlement.
Washington, D.C. (October 8). EPA-HQ-OW-2010-0824. DCN 07576.
18. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
19. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
20. WC&E. 2006. Wastech Controls & Engineering, Inc. Fluoride Wastewater Treatment
(FWT): Also Known as HF Neutralization or Fluoride Reduction. Available online at:
http://www.wastechengineering.com/papers/hf.htm. Date accessed: July 27. DCN 03759.
14-14
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Section 15—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
15. Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
EPA selected the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Category
for preliminary review because it continues to rank high, in terms of toxic-weighted pound
equivalent (TWPE), in point source category rankings. EPA reviewed discharges from the
OCPSF Category as part of the 2004 through 2010 reviews (U.S. EPA, 2004, 2005a, 2005b,
2006, 2007, 2008, 2009, 2011). This section summarizes the results of the 2011 Annual Reviews
associated with the OCPSF Category. EPA focused on discharges of PCB-1242 and
hexachlorobenzene because of their high TWPE relative to other pollutants in the OCPSF
Category. For further background of the OCPSF Category, see the Technical Support Document
for the 2010 Effluent Guidelines Program Plan (U.S. EPA, 2011).
EPA recently reviewed discharges from the chlorinated hydrocarbon manufacturing
segment of the OCPSF Category as part of the Chlorine and Chlorinated Hydrocarbons effluent
guidelines rulemaking. EPA is proposing to delist chlorinated hydrocarbon manufacturing from
the effluent guidelines plan and discontinue the rulemaking. Given this, these facilities were
excluded from further consideration in this toxicity ranking analysis (see Table 8-1, in the
Preliminary 2012 Plan (U.S. EPA, 2013)).
15.1 OCPSF Category 2011 Toxicity Rankings Analysis
Table 15-1 compares the toxicity rankings analysis results for the OCPSF Category from
the 2006 through 2011 Annual Reviews. The 2009 discharge monitoring report (DMR) TWPE
accounts for approximately 79 percent of the combined 2009 DMR and Toxics Release
Inventory (TRI) TWPE, while TRI discharges dominated previous years' combined TWPE.
Table 15-1. OCPSF Category TRI and DMR Discharges for the 2006 Through 2011
Toxicity Rankings Analysis
Year of Discharge
Year of Review
OCPSF Category
TRI TWPE1'
DMR TWPEb
Total TWPE
2002
2006
349,000
398,000
747,000
2004
2007
957,000
608,000
1,570,000
2005
2008
759,000
NA
NA
2007
2009
575,000
309,000
884,000
2008
2010
137,000
512,000
649,000
2009
2011
146,000
541,000
687,000
Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v2;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 include only major dischargers. DMR 2008 and 2009 data include both
minor and major dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
15.2 OCPSF Pollutants of Concern
EPA's review of the OCPSF Category focused on the 2009 DMR discharges because the
2009 DMR data dominate the category's combined TWPE. Table 15-2 compares the five.
15-1
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Section 15—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Table 15-2. OCPSF Category Top DMR Pollutants
Pollutant
2008 DMR Data3
2009 DMR Data"
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
PCB-1242
Pollutants not reported in the top five 2008 DMR-reported
pollutants.
1
1
240,000
Hexachlorobenzene
1
11
124,000
2
9
131,000
Chlorine
2
104
77,800
3
95
75.800
Tin
Pollutants not reported in the top five 2008 DMR-reported
pollutants.
4
3
16,400
Fluoride
5
11
11,000
Nickel
3
68
59,500
Pollutants not reported in the top five 2009 DMR-reported
pollutants.
Copper
4
133
42,100
Fluoride
5
16
28,900
OCPSF Category Total
NA
357b
512,000
NA
319b
541,000
Sources: DMRLoads2008jv2 and DMRLoads2009_v2.
a DMR data include major and minor dischargers.
b Number of facilities reporting TWPE greater than zero.
NA: Not applicable.
15-2
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Section 15—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
pollutants with the highest TWPE in the 2009 and 2008 DMR databases (DMRLoads2009_v2
and DMRLoads2008_v2, respectively).
PCB-1242 and hexachlorobenzene compose the majority (approximately 70 percent) of
the 2009 DMR TWPE for the OCSPF Category. The PCB-1242 discharges in the 2009 DMR
database are from only one facility, Solutia, Inc., in Anniston, AL. PCBs are no longer
manufactured in the United States and are used in a limited number of products. Therefore, PCB
discharges are typically legacy issues and require facility-specific permitting support (40 CFR
Part 761.50). EPA is not prioritizing the PCB discharges for review as part of the 2011 Annual
Reviews because the discharges are from only one facility and PCBs are typically legacy issues.
15.3 OCPSF Category Hexachlorobenzene Dischargers in DMR
EPA's 2011 Annual Reviews of the OCPSF Category focused on hexachlorobenzene
discharges. Hexachlorobenzene discharges in the 2009 DMR database account for 24 percent of
the total DMR TWPE. Table 15-3 presents the hexachlorobenzene dischargers in the 2009 DMR
database. Discharges of hexachlorobenzene from three facilities account for over 90 percent of
the category's hexachlorobenzene DMR TWPE. As a result, EPA focused its review of
hexachlorobenzene discharges on the top three facilities.
Table 15-3. OCPSF Category Hexachlorobenzene Dischargers in the 2009 DMR Database
Facility Name
Hexachlorobenzene
Pounds Discharged
Hexachlorobenzene
TWPE
Facility Percent of
Hexachlorobenzene
Category TWPE
Daikin America Inc.
29.2
56,900
44%
Chevron Oronite Co., LLC, Oak Point Plant
25.6
49,800
38%
Nalco Company
6.21
12,100
9%
Remaining facilities reporting
hexachlorobenzene discharges3
6.26
12,100
9%
Total
100%
Source: DMRLoads2009_v2.
" There are three remaining facilities that have hexachlorobenzene discharges in the 2009 DMR database, which
account for 3 percent of the category's hexachlorobenzene DMR TWPE.
15.3.1 Daikin American, Inc.
Daikin American in Decatur, AL, discharges hexachlorobenzene from one outfall, outfall
001, which carries treated process wastewater from a fluorocarbon production facility (ADEM,
2003a). Table 15-4 presents the 2009 DMR hexachlorobenzene concentrations compared to the
facility's permit and limit from Subpart J of the OCPSF effluent limitations guidelines, or
ELGs.9 The facility's permit requires that hexachlorobenzene be reported annually as a quantity.
EPA calculated the 2009 concentrations using the quantities and flow from the 2009 DMR
database. EPA calculated the 2009 permit limit concentrations using the permit limit quantities
and the flows from the facility's permit fact sheet (ADEM, 2003b). The facility's fact sheet also
states that the hexachlorobenzene permit limits are based on the human health criteria. Therefore,
9 See Section 12.1.2 of the Technical Support Document for the 2010 Effluent Guidelines Program Plan (U.S. EPA,
2011) for details on the OCPSF ELGs.
15-3
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Section 15—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Table 15-4. 2009 DMR Hexachlorobenzene Discharges for Daikin American, Inc.
2009 DMR Database Data
Permit Limits and Fact Sheet Data
ELG Limits
(mg/L)
Quantity
(kg/day)
Flow (MGD)
Calculated
Concentration (m^/L)
Quantity
(kg/day)
Flow (MGD)a
Calculated
Concentration (m^/L)
Daily maximum
0.0363
1.07
0.00896
0.0862
0.79
0.0288
0.794
Monthly average
0.0363
1.07
0.00896
0.0544
0.79
0.0182
0.196
Sources: Facility permit and fact sheet (ADEM, 2003a, 2003b) and DMRLoads2009_v2.
a Flow is reported only in the facility permit; this value is based on the facility's permit fact sheet.
15-4
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Section 15—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
the permit limits are based on facility-specific permitting support rather than the OCPSF ELGs
(ADEM, 2003b). As shown in Table 15-4, the calculated daily maximum and monthly average
concentrations do not exceed the OCPSF ELG hexachlorobenzene limits or the facility-specific
permit limits based on the water quality criteria for human health.
15.3.2 Chevron Oronite Co., LLC, Oak Point Plant
Chevron Oronite, Oak Point Plant, in Belle Chasse, LA, discharges hexachlorobenzene
from outfall 202. This continuous, internal discharge consists of treated process wastewater and
process area stormwater (LADEQ, 2009a). Table 15-5 presents the 2008 and 2009
hexachlorobenzene data for Chevron Oronite.
Table 15-5. 2008 and 2009 Hexachlorobenzene Discharge Data for Chevron
Oronite Outfall 202
Monitoring Period
DMR Loadings Tool Quantity (kg/day)
Flow (MGD)
31-Dec-08
0.0544
1.132
31-Dec-09
0.0317
2.527
Source: DMR Loadings Tool.
EPA contacted Chevron Oronite about the 2008 DMR discharges of hexachlorobenzene
as part of the 2010 Annual Reviews. Chevron Oronite indicated that all of the 2008
hexachlorobenzene quantities had been measured below the detection limit; they had therefore
used half of the detection limit to calculate the reported quantities (Sampey, 2010). Accordingly,
EPA determined that all of the quantities in the 2008 DMR database were based on non-detect
sample results and the loads and, for annual review purposes, TWPE should be zero (U.S. EPA,
2011). As shown in Table 15-5, the 2009 hexachlorobenzene quantities are less than the 2008
quantities. The 2009 DMR data are consistent with 2008; EPA concludes that for annual review
purposes, the TWPE should be zero. With this error corrected the facility's total TWPE
decreases from 55,800 to 6,000, a reduction of over 89 percent.
15.3.3 Nalco Company
Nalco Company discharges hexachlorobenzene from outfall 001, a continuous discharge
of treated process wastewater (LADEQ, 2009b). Table 15-6 presents the 2009 DMR
hexachlorobenzene concentrations compared to the facility's permit and limit from Subpart H of
the OCPSF ELGs.10 The facility's permit requires that hexachlorobenzene be reported annually
as a quantity. EPA calculated the 2009 concentrations using the quantities and flow from the
2009 DMR database. EPA calculated the 2009 permit limit concentrations using the permit limit
quantities and the estimated flow from the facility's permit. As shown in Table 15-6, the reported
daily maximum and monthly average concentrations do not exceed the hexachlorobenzene limits
in the facility's permit or the OCPSF ELGs.
10 See Section 12.1.2 of the Technical Support Document for the 2010 Effluent Guidelines Program Plan (U.S. EPA,
2011) for details on the OCPSF ELGs.
15-5
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Section 15—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Table 15-6. 2009 DMR Hexachlorobenzene Discharges for Nalco Company
2009 DMR Database Data
Permit Limits and Fact Sheet Data
ELG Limits
(mg/L)
Quantity
(kg/day)
Flow (MGD)
Calculated
Concentration (m^/L)
Quantity
(kg/day)
Flow (MGD)a
Calculated
Concentration (m^/L)
Daily maximum
0.0077
0.503
0.00405
0.0454
0.514
0.0233
0.028
Monthly average
0.0077
0.503
0.00405
0.0227
0.514
0.0117
0.015
Source: Facility Permits (LADEQ, 2009b) and DMRLoads_2009_v2.
" Flow is reported only in the facility permit; this value is based on the facility's permit fact sheet.
15-6
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Section 15—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
15.4 OCPSF Category Conclusions
The estimated toxicity of the OCSPF Category discharges results from PCB-1242 and
hexachlorobenzene discharges. Data collected for the 2011 Annual Reviews demonstrated that
wastewater discharge characteristics for this category are consistent with discharges from prior
years. Using data collected for the 2011 Annual Reviews, EPA concludes the following:
• The PCB-1242 discharges are reported by one facility, Solutia, Inc., in Anniston,
Alabama. PCBs are no longer manufactured in the United States, so PCB
discharges are typically legacy issues (40 CFR Part 761.50). EPA determined that
the PCB discharges are not representative of the category because they come from
only one facility and are typically legacy issues. Therefore, the PCB discharges
should be controlled using facility-specific permitting support. EPA excluded the
facility's discharges from further review.
• Three facilities, Daikin American, Inc., Chevron Oronite, and Nalco Company,
contribute the majority of the hexachlorobenzene discharges for the OCPSF
Category.
• Chevron Oronite indicated that the 2008 hexachlorobenzene quantities were based
on non-detect sampling results. The facility's 2009 hexachlorobenzene quantities
are on the same order of magnitude as the 2008 values; therefore, EPA suspects
that the 2009 quantities are also based on non-detect sampling results.
Accordingly, EPA determined that Chevron Oronite's 2009 hexachlorobenzene
load and TWPE should be zero. Correcting this error decreases the facility's 2009
TWPE from 55,800 to 6,000.
• The hexachlorobenzene discharges from Daikin American, Inc., and Nalco
Company are below the ELGs and the facilities' permit limits. Although
hexachlorobenzene is present, the discharge concentrations are an order of
magnitude below the ELGs. As new data become available, EPA will review
hexachlorobenzene discharges from the OCPSF Category to determine if the same
conclusions apply.
• Correcting the database errors identified during the 2011 Annual Reviews
decreases the 2009 OCPSF Category TWPE from 687,000 to 397,000. The
OCSPF Category continues to rank high due to the high number of facilities (over
2,000) in the industry. As new data becomes available, EPA will continue to
review the OCSPF Category discharges to determine if they are properly
controlled.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
15-7
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Section 15—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
15.5 OCSPF Category References
1. ADEM. 2003a. Alabama Department of Environmental Management. NPDES Permit:
Daikin America, Inc., Decatur, AL. EPA-HQ-OW-2010-0824. DCN 07608.
2. ADEM. 2003b. Alabama Department of Environmental Management. NPDES Permit
Fact Sheet: Daikin America, Inc., Decatur, AL. EPA-HQ-OW-2010-0824. DCN 07609.
3. LADEQ. 2009a. Louisiana Department of Environmental Quality, Environmental
Services. NPDES Permit: Chevron Oronite Company, LLC, Oak Point Plant, Belle
Chasse, LA. EPA-HQ-OW-2010-0824. DCN 07610.
4. LADEQ. 2009b. Louisiana Department of Environmental Quality, Environmental
Services. NPDES Permit: Nalco Company, Garyville Facility, Garyville, LA. EPA-HQ-
OW-2010-0824. DCN 07611.
5. Sampey, Troy. 2010. E-mail Communication Between Troy Sampey, Chevron Oronite
Co., and Elizabeth Sabol, Eastern Research Group, Inc., Re: DMRs Clarification Needed
for Chevron Oronite—Oak Point Plant. (July 13). EPA-HQ-OW-2010-0824. DCN
07296.
6. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
7. U.S. EPA. 2005a. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004-
0032-0016.
8. U.S. EPA. 2005b. Product and Product Group Discharges Subject to Effluent Limitations
and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source
Category. Washington, D.C. (April). EPA-HQ-OW-2004-032-2568.
9. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
10. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
11. U. S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-08-015. EPA-HQ-OW-2006-0771-1701.
12. U. S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-0517-0515.
15-8
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Section 15—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
13. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
14. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
15-9
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Section 16—Oil & Gas Extraction (40 CFR Part 435)
16. Oil & Gas Extraction (40 CFR Part 435)
EPA selected the Oil and Gas Extraction (Oil and Gas) Category for preliminary review
because it ranks high, in terms of toxic-weighted pound equivalent (TWPE), in point source
category rankings. The Final 2010 Plan summarizes the results of EPA's previous review of this
industry in 2010 (U.S. EPA, 2011). EPA also reviewed discharges from this industry,
specifically the coalbed methane (CBM) sector, in 2004 and 2005 (71 FR 76644, December 21,
2006). See Section 16.2 of the Final 2010 Plan for information on EPA's detailed study of the
CBM sector (U.S. EPA, 2011). As a result of this detailed study, EPA announced in the Final
2010 Plan its intent to review discharges from the CBM segment of the Oil and Gas Category as
part of the CBM effluent guidelines rulemaking. Also announced in the Final 2010 ELG
Program Plan, EPA initiated a rulemaking for shale gas extraction, another subcategory of the
Oil and Gas Category, which includes ELGs for direct discharge but not pretreatment standards.
For more information on shale gas extraction, see the Final 2010 Plan (76 FR 66286).
At this time, however, EPA is proposing to delist from rulemaking in the effluent
guidelines plan the CBM extraction subcategory (see Section 4.1.1 of the Preliminary 2012 Plan
for more details). EPA plans to continue to address shale gas extraction under its proposed
rulemaking titled "ELG Revisions to Address Discharges from Unconventional Oil and Gas
Extraction".
Because rulemakings for the CBM and shale gas extraction segments of the Oil and Gas
Category were, or are, currently under consideration, EPA excluded discharges from these
facilities from further consideration in this review (see Table V-l, 76 FR 66286, October 26,
2011).
This section summarizes the results of the 2011 Annual Reviews associated with the Oil
and Gas Category. EPA focused on discharges of sulfide from one facility, because of its high
TWPE relative to the other facilities in the Oil and Gas Category.
16.1 Oil and Gas Category 2011 Toxicity Rankings Analysis
Table 16-1 compares the toxicity rankings analysis results for the Oil and Gas Category
from the 2006 through 2011 Annual Reviews. The combined discharge monitoring report
(DMR) and Toxics Release Inventory (TRI) TWPE increased from discharge years 2007 to
2009. Since 2007, the combined TWPE is based only on DMR data because no facilities reported
water discharges to TRI for 2007 through 2009. EPA's review of the Oil and Gas Category
focused on the 2009 DMR discharges because no facilities reported water discharges to TRI in
2009.
Table 16-1. Oil and Gas Category TRI and DMR Discharges for the 2006 Through 2011
Toxicity Rankings Analysis
Year of Discharge
Year of Review
Oil and Gas Category
TRI TWPE"
DMRTWPEb
Total TWPE
2002
2006
700
1.18
701
2004
2007
596
17.8
614
2005
2008
802
NA
NA
16-1
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Section 16—Oil & Gas Extraction (40 CFR Part 435)
Table 16-1. Oil and Gas Category TRI and DMR Discharges for the 2006 Through 2011
Toxicity Rankings Analysis
Year of Discharge
Year of Review
Oil and Gas Category
TRI TWPE"
DMRTWPEb
Total TWPE
2007
2009
NR
255
255
2008
2010
NR
189,000
189,000
2009
2011
NR
238,000
238,000
Sources: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 include only major dischargers. DMR 2008 and 2009 data include both
minor and major dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
NR: Not reported. No facilities reported water discharges to TRI for reporting years 2007 through 2009.
16.2 Oil and Gas Category Pollutants of Concern
Table 16-2 lists the five pollutants with the highest TWPE in DMR data from reporting
years 2009 and 2008 (DMRLoads2009_v2 and DMRLoads2008 v3, respectively). Sulfide is the
top DMR pollutant in 2009, contributing approximately 94 percent of the total category TWPE
for 2009. EPA did not investigate the other top pollutants as part of the 2011 Annual Reviews
because the remaining TWPE is only six percent of the 2009 combined TWPE for the Oil and
Gas Category.
16-2
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Section 16—Oil & Gas Extraction (40 CFR Part 435)
Table 16-2. Oil and Gas Category Top DMR Pollutants
Pollutant
2008 DMR Database1'
2009 DMR Database'1
Rank
Number of
Faeilities Reporting
Pollutant
TWPE
Rank
Number of
Facilities Reporting
Pollutant
TWPE
Sulfide
1
3
170,000
1
3
224,000
Chloride
3
12
7,340
2
20
10,700
Fluoride
4
2
2,250
3
3
1,900
Arsenic
Pollutant not reported in the top five 2008 DMR-reported
pollutants.
4
1
367
Aluminum
2
2
7,550
5
3
242
Cyanide
5
2
871
Pollutant not reported in the top five 2009 DMR-reported
pollutants.
Oil and Gas Category Total
NA
52b
189,000
NA
63b
238,000
Sources: DMRLoads2008_v3 and DMRLoads2009_v2.
a 2008 and 2009 DMR data include major and minor dischargers.
b Number of facilities reporting TWPE greater than zero.
16-3
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Section 16—Oil & Gas Extraction (40 CFR Part 435)
16.3 Oil and Gas Category Sulfide Discharges in DMR
Table 16-3 presents the three facilities that have sulfide discharges in the 2008 and 2009
DMR databases. The majority (99 percent) of the sulfide TWPE results from discharges from
Marathon Oil Maverick Springs in Fremont County, WY. EPA did not review sulfide discharges
from the other facilities because they account for only one percent of the Oil and Gas Category's
sulfide TWPE.
16-4
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Section 16—Oil & Gas Extraction (40 CFR Part 435)
Table 16-3. Oil and Gas Category Top Sulfide Discharging Facilities in the 2008 and 2009 DMR Databases
Facility Name
Facility Location
2008
2009
Pounds of
Sulfide
Discharged
Sulfide
TWPE
Percentage of Oil and
Gas Category Sulfide
2009 DMR TWPE
Pounds of
Sulfide
Discharged
Sulfide
TWPE
Percentage of Oil and
Gas Category Sulfide
2009 DMR TWPE
Marathon Oil Maverick
Springs
Fremont County, WY
60,600
169,800
99%
79,700
223,200
99%
Soap Creek Oil Field
St. Xavier, MT
107
300
<1%
130
400
<1%
Petro Gas Liquids
Processing
Corpus Christi, TX
5.79
16
<1%
4
12
<1%
Total
60,700
170,000
100%
79,800
224,000
100%
Sources: DMRLoads2008 v2 and DMRLoads2009 v2.
16-5
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Section 16—Oil & Gas Extraction (40 CFR Part 435)
The Marathon Oil Maverick Springs facility is an oil production facility, located within
the exterior boundaries of the Wind River Indian Reservation. The facility's permit fact sheet
indicates that the Wyoming Department of Environmental Conservation (WDEQ) developed the
permit limits based on Subparts C ("Onshore Subcategory") and E ("Agricultural and Wildlife
Water Use Subcategory" of the Oil and Gas Category (WDEQ, 2007). See Section 10.1.2 of the
Technical Support Document for the 2010 Effluent Guidelines Program Plan for a complete
review of the Oil and Gas Category ELGs (U.S. EPA, 2011). The ELGs and the facility's permit
do not set numerical limits for sulfide; however, the permit requires semi-annual effluent
monitoring requirements for sulfide. Table 16-4 presents the sulfide concentration data for
Marathon Oil Maverick Springs for 2007 through 2009.
Table 16-4. Marathon Oil Maverick Springs's Outfall 001 2007 Through 2009
Sulfide Discharge Data
Monitoring Period Date
Maximum Concentration (mg/L)
Flow (MGD)
31-Dec-07
9.76
1.645
31-Dec-08
24
1.645
30-June-09
25
1.598
31-Dec-09
8
1.576
Source: EPA's Envirofacts and DMR Loadings Tool.
EPA contacted Marathon Oil Maverick Springs to verify the 2008 sulfide discharges as
part of the 2010 Annual Reviews. The facility confirmed the 2008 sulfide concentrations and
flows for outfall 001, a stormwater discharge (Taylor, 2010). EPA also contacted the Wyoming
Department of Environmental Quality (WDEQ), the permitting authority, to determine the
impact of sulfide concentrations on the receiving stream. The permitting authority confirmed that
there were no issues with the sulfide concentrations affecting the receiving stream (WDEQ,
2007). The WDEQ contact further established that water discharges from crude refiners vary
with geographic location, implying that the Maverick Spring discharge differs from refiners in
other basins.
As a result, EPA concluded that the state is aware of Marathon Oil Maverick Springs'
sulfide discharges, and that their sulfide wastewater discharges are unique. That is, the
magnitude of their sulfide discharges does not mean that discharges from other facilities in the
category would contain such sulfide levels. Because the 2009 sulfide discharges and flow are of
the same order of magnitude, as shown in Table 16-4, EPA did not contact the facility to verify
the 2009 data. EPA continues to conclude that the facility's sulfide discharges are best controlled
by facility-specific permitting support. For more information on the 2008 sulfide discharges from
Marathon Oil Maverick Springs, see Section 10.4 of the Technical Support Document for the
2010 Effluent Guidelines Program Plan (U.S. EPA, 2011).
16.4 Oil and Gas Category Conclusions
The estimated toxicity of the Oil and Gas Category discharges results mainly from the
sulfide discharges of Marathon Oil Maverick Springs (accounting for 99 percent of the
category's 2009 TWPE). EPA does not believe that these sulfide discharges are representative of
the Oil and Gas Category. Data collected for the 2011 Annual Reviews demonstrated that
16-6
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Section 16—Oil & Gas Extraction (40 CFR Part 435)
wastewater discharge characteristics for this category are consistent with discharges from prior
years. Using data collected for the 2011 Annual Reviews, EPA concludes the following:
• EPA contacted Marathon Oil Maverick Springs in 2010 because of their sulfide
discharges. Marathon Oil Maverick Springs confirmed the 2008 sulfide
concentrations and flows. The 2009 sulfide discharges and flows are the same
order of magnitude as the 2008 data. Therefore, EPA believes that the 2009
discharge estimates are valid but do not represent the category as a whole.
Marathon Oil's sulfide discharges are best controlled by facility-specific
permitting support.
• The total 2009 TWPE excluding the sulfide discharges from Marathon Oil
Maverick Springs is 14,800. This change would drop the category outside the top
95 percent that EPA prioritized for preliminary review as part of the 2011 Annual
Reviews.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
16.5 Oil and Gas Category References
1. Taylor, Linda. 2010. Notes From Telephone Conversation Between Linda Taylor,
Marathon Oil Maverick Springs, and Elizabeth Sabol, Eastern Research Group, Inc., Re:
Sulfide Discharges Reported to DMR in 2008. (June 3). EPA-HQ-OW-2008-0517 DCN
07307.
2. WDEQ. 2007. Wyoming Department of Environmental Quality. State of Wyoming
National Pollutant Discharge Elimination System Statement of Basis NPDES
WY0000779—Marathon Oil Maverick Springs. Fremont County, WY. (June) EPA-HQ-
OW-2008-0517 DCN 07292.
3. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
4. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA 820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
5. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
16-7
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Section 17—Ore Mining and Dressing (40 CFR Part 440)
17. Ore Mining and Dressing (40 CFR Part 440)
EPA selected the Ore Mining and Dressing (Ore Mining) Category for preliminary
review because it ranks high, in terms of toxic-weighted pound equivalent (TWPE), in point
source category rankings. EPA conducted a preliminary study of this category as part of the 2009
and 2010 Annual Reviews (U.S. EPA, 2009, 2011). EPA also reviewed discharges from the Ore
Mining Category as part of the 2004 through 2008 Annual Reviews (U.S. EPA, 2004, 2005,
2006, 2007, 2008). This section summarizes the results of the 2011 Annual Reviews associated
with the Ore Mining and Dressing Category.
17.1 Ore Mining and Dressing Category 2011 Toxicity Rankings Analysis
Table 17-1 compares the toxicity rankings database results for the Ore Mining Category
from the 2006 through 2011 reviews. Both the Toxics Release Inventory (TRI) and discharge
monitoring report (DMR) TWPE decreased from 2008 to 2009. The estimated 2009 DMR
TWPE accounts for 67 percent of the combined 2009 DMR and TRI TWPE category, similar to
previous years. EPA's review of the Ore Mining Category focused on the 2009 DMR discharges
because the 2009 DMR data account for 67 percent of the 2009 combined category TWPE.
Table 17-1. Ore Mining Category TRI and DMR Discharges for 2002 Through 2009
Year of
Discharge
Year of
Review
Ore Mining Category
TRI TWPE'1
DMR TWPEb
Total TWPE
2002
2006
77,600
410,000
488,000
2004
2007
88,000
581,000
669,000
2005
2008
76,700
NA
NA
2007
2009
39,400
184,000
223,000
2008
2010
109,000
339,000
448,000
2009
2011
68,900
139,000
208,000
Sources: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2; PCSLoads2004_v4;
TRIReleases2004_v3; TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v3;
TRIReleases2009_v2; and DMRLoads2009_v2.
" Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 include only major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
17.2 Ore Mining and Dressing Category Top Facilities in DMR
In EPA's preliminary study of the Ore Mining Category, conducted during the 2009 and
2010 Annual Reviews, EPA determined that approximately two percent of ore mining facilities
in the 2007 DMR database have DMR data; see Table 2-2 in the Ore Mining and Dressing
Preliminary Study Report (U.S. EPA, 2011). Table 17-2 presents counts of the 2009 ore mining
facilities in the DMR database. There are 80 ore mining facilities with DMR data in the 2009
DMR database, which accounts for less than four percent of all the facilities in the database.
17-1
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Section 17—Ore Mining and Dressing (40 CFR Part 440)
Table 17-2. Summary of 2009 Ore Mining Facilities With Data in the DMR Database
ELG
Subpart
SIC Code and Description
Facilities by Type of Discharger
Number of
Facilities With
DMR Data
Major
Minor
All
A
1011: Iron Ores
5
26
31
6
J
1021: Copper Ores
11
19
30
6
J
1031: Lead/Zinc Ores
24
17
41
21
J,M
1041: Gold Ores
13
2,028
2,041
24
J
1044: Silver Ores
2
29
31
4
J
1061: Ferroalloy Ores (Except Vanadium)
5
7
12
5
NA
1081: Metal Mining Services
0
4
4
1
C
1094: Uranium, Radium, Vanadium Ores
7
28
35
5
Others3
1099: Metal Ores, NEC
4
23
27
8
Total
71
2,181
2,252
80
Source: DMRLoads2009_v2.
a The other subparts include B, D, E, F, G, H, I, and K.
NEC: Not elsewhere classified.
In addition to the findings mentioned above, EPA analyzed specific pollutant discharges
and determined that only a small percentage of active mines account for the majority of
category's TWPE (U.S. EPA, 2011). Table 17-3 shows the top 14 mines in the 2009 DMR
database and their corresponding 2009 TRI discharges. EPA's review showed that the majority
of the top 14 mines were reviewed in the Ore Mining Preliminary Study. For a listing of the top
mines in the preliminary study, see Table 6-1 in the Ore Mining and Dressing Preliminary Study
Report (U.S. EPA, 2011). In addition, EPA's review showed that the majority of the pollutants
and loads were the same as those reviewed in the Ore Mining Preliminary Study.
Because the discharge data from these mines was consistent with the data from the
Preliminary Study, EPA draws a similar conclusion. As shown in Table 17-3, these 14 top mines
represent less than one percent of the total number of ore mining facilities (from Table 17-2) and
almost 80 percent of the category's 2009 combined TWPE. They differ in location and mine
type, showing no trend toward a particular type of mine. Given that a small percentage of active
mines account for the majority of category's TWPE, as in the 2010 preliminary study findings,
EPA determined that high TWPE discharges are best addressed through facility-specific
permitting, compliance, and enforcement support rather than by a revision of 40 CFR Part 440
(U.S. EPA, 2009).
17-2
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Section 17—Ore Mining and Dressing (40 CFR Part 440)
Table 17-3. Top Facility Discharges in the 2009 DMR and TRI Databases"
Facility Name
Facility Location
Mine Type1*
TWPE
Total Percentage of
Ore Mining and
Dressing Category's
2009 TWPE '
Facility
Total DMR
TWPE
Facility
Total TRI
TWPE
Facility
Total
TWPE
Teck-Pogo Inc.
Delta Junction, AK
Gold ores
33,000
NR
33,000
15.9%
Climax Mine
Climax, CO
Ferroalloy ores
(except
vanadium)
28,500
NR
28,500
13.7%
Kennecott Copper Co.
Magna, UT
Copper ores
19,800
15,600
35,400
17.0%
Doe Run, Viburnum Mine #35
Viburnum, MO
Lead/zinc ores
12,400
NR
12,400
6.0%
Doe Run, Fletcher Mine/Ml
Viburnum, MO
Lead/zinc ores
11,300
9,610
20,910
10.1%
Doe Run, Viburnum Div
Viburnum, MO
Lead/zinc ores
7,370
NR
7,370
3.5%
Doe Run, Brushy Cr Mine/M
Viburnum, MO
Lead/zinc ores
4,780
4,560
9,340
4.5%
Balmat Mines & Mill
Gouverneur, NY
Lead/zinc ores
4,530
709
5,240
2.5%
Mammoth, Sutro, Keystone Et A1
Redding, CA
Copper ores
2,150
NR
2,150
1.0%
Alcoa Arkansas Remediation
Bauxite, AR
Metal ores, NEC
1,960
NR
1,960
0.9%
Homestake Mining Company
Lead, SD
Gold ores
1,720
NR
1,720
0.8%
Northshore Mining/Silver Bay
Silver Bay, MN
Iron ores
1,700
NR
1,700
0.8%
Anschutz—Madison Mine
Fredericktown, MO
Lead/zinc ores
1,510
NR
1,510
0.7%
Doe Run, West Fork Unit
Bunker, MO
Lead/zinc ores
1,330
NR
1,330
0.6%
Remaining facilities with Ore Mining Category
discharges0
NA
NA
7,110
38,400
45,500
21.9%
Total
NA
139,000
68,900
208,000
100%
Source: DMRLoads2009_v2 and TRIReleases2009_v2.
" The 2009 DMR data includes both major and minor dischargers.
b Mine type was based on the SIC code the facility reported.
0 There are 62 remaining facilities with ore mining discharges that account for approximately 22 percent of the category's 2009 combined TWPE.
NA: Not applicable.
NR: Not reported. Facility does not have discharges in TRI.
NEC: Not elsewhere classified.
17-3
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Section 17—Ore Mining and Dressing (40 CFR Part 440)
17.3 Ore Mining and Dressing Category Conclusions
The estimated toxicity of the Ore Mining Category discharges results mainly from less
than 1 percent of ore mines (accounting for almost 79 percent of the category's 2009 combined
TWPE). Data collected for the 2011 Annual Reviews demonstrated that wastewater discharge
characteristics for this category are consistent with discharges from the 2010 preliminary study.
Using data collected for the 2011 Annual Reviews, EPA concludes the following:
• Over 78 percent of the category's 2009 combined category TWPE is from
discharges from 14 facilities. These facilities are varied in location and mine type.
• EPA determined that these facilities are best managed through facility-specific
permitting, compliance, and enforcement support.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(2)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
17.4 Ore Mining and Dressing Category References
1. U. S. EPA. 2004 Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA 821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
2. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004-
0032-0053.
3. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
4. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA 821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
5. U.S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA 821-R-08-015. EPA-HQ-OW-2006-0771-1701.
6. U. S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-0517-0515.
7. U.S. EPA. 2011. Ore Mining and Dressing Preliminary Study Report. W ashington, D.C.
(December). EPA-821-R-08-012. EPA-HQ-OW-2008-0517 DCN 07369.
17-4
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Section 17—Ore Mining and Dressing (40 CFR Part 440)
8. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA 820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
9. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
17-5
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Section 18—Pesticide Chemicals (40 CFR Part 455)
18. Pesticide Chemicals (40 CFR Part 455)
EPA selected the Pesticide Chemicals Category for preliminary review because it
continues to rank high, in terms of toxic-weighted pound equivalent (TWPE), in the point source
category rankings. EPA reviewed discharges from the Pesticide Chemicals Category as part of
the 2005, 2006, and 2007 Annual Reviews (U.S. EPA, 2005, 2006, 2007). This section
summarizes the results of the 2011 Annual Reviews associated with the Pesticide Chemicals
Category. EPA focused on discharges of polychlorinated biphenyls (PCBs) from one facility due
to its high TWPE relative to the other facilities in the Pesticide Chemicals Category.
18.1 Pesticide Chemicals Category 2011 Toxicity Rankings Analysis
Table 18-1 compares the toxicity rankings analysis results for the Pesticide Chemicals
Category from the 2006 through 2011 Annual Reviews. The combined TWPE from discharges in
the discharge monitoring report (DMR) and Toxics Release Inventory (TRI) databases decreased
from discharge years 2002 to 2009. The estimated 2009 TRI TWPE accounts for approximately
78 percent of the combined 2009 DMR and TRI TWPE, as in the 2002 and 2004 discharge years.
Table 18-1. Pesticide Chemicals Category TRI and DMR Discharges for the 2006
Through 2011 Toxicity Rankings Analysis
Year of Discharge
Year of Review
Pesticide Chemicals Category
TRI TWPE1'
DMRTWPEb
Total TWPE
2002
2006
554,000
50,300
605,000
2004
2007
518,000
102,000
621,000
2005
2008
31,400
NA
NA
2007
2009
24,700
180,000
205,000
2008
2010
35,500
81,500
117,000
2009
2011
35,700
10,000
45,700
Sources: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3;
TRIReleases2009_v2; and DMRLoads2009_v2.
" Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 include only major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
18.2 Pesticide Chemicals Category Pollutants of Concern
EPA's review of the Pesticide Chemicals Category focused on the 2009 TRI discharges
because the 2009 TRI data dominate the category's combined TWPE. Table 18-2 lists the five
pollutants with the highest TWPE based on results from the 2011 and 2010 Annual Reviews
(TRIReleases2009_v2 and TRIReleases2008v3, respectively).
PCB is the top TRI-reported pollutant in 2009, contributing more than 36 percent of the
2009 TRI category TWPE. EPA did not investigate the other top pollutants as part of the 2011
Annual Reviews.
18-1
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Section 18—Pesticide Chemicals (40 CFR Part 455)
Table 18-2. Pesticide Chemicals Category Top TRI Pollutants
2008 TRI Data
2009 TRI Data
Pollutant
Rank
Number of Facilities
Reporting Pollutant
TWPE
Rank
Number of Facilities
Reporting Pollutant
TWPE
PCBs
Pollutant not reported in the top five 2008 TRI-
reported pollutants.
1
1
13,000
Dichlorvos
2
1
6,930
2
1
6,930
Diazinon
4
4
3,110
3
2
3,330
Carbaryl
5
5
2,800
4
2
2,800
Dioxin and dioxin-like compounds
Pollutant not reported in the top five 2008-TRI
reported pollutants.
5
1
1,440
Bifenthrin
1
2
12,700
Pollutant not reported in the top five 2009 TRI-
Dinitrobutyl phenol
3
3
3,370
reported pollutants.
Pesticide Chemicals Category Total
NA
73a
35,500
NA
62a
35,700
Sources: TRIReleases2008_v3 and TRIReleases2009jv2.
a Number of facilities reporting a TWPE of greater than zero.
NA: Not applicable.
18-2
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Section 18—Pesticide Chemicals (40 CFR Part 455)
18.3 Pesticide Chemicals Category PCB Discharges in TRI
GB Biosciences Corp. in Houston, TX, manufactures chlorophenol in a process that
creates PCBs as a byproduct (King, 2011). The facility accounts for all of the Pesticide
Chemicals Category's PCB discharges in the 2009 TRI database. Table 18-3 presents GB
Biosciences' PCB discharges for 2003 through 2010; note that the 2009 discharges are three
orders of magnitude larger than previous years' discharges.
Table 18-3. 2003-2010 GB Biosciences Corp. TRI PCB Discharges
Ye.ir
loliil PC 15 Pounds Kokusod
l oliil P( IJ T\\ IT.
2003
0.0004
13.6
2004
0.001
34.0
2005
0.0004
13.6
2006
0.0006
20.4
2007
0.0008
27.2
2008
0.0008
27.2
2009
0.382
13,000
2010a
0.000765
26.0
Sources: Envirofacts; TRIReleases2002_v4; TRIReleases2004_v3; TRIReleases2005_v2; TRIReleases2007_v2;
TRIReleases2008_v3; and TRIReleases2009_v2.
" 2010 data were pulled from Envirofacts.
As part of the 2011 Annual Reviews, EPA contacted GB Biosciences about its PCB
discharge in the 2009 TRI. The facility contact identified a reporting error: the 0.382 pounds
reported to TRI should have been reported as 0.382 grams.
In addition, the facility had estimated its PCB discharges in 2009 TRI using results from
sampling by the University of Houston, done as part of the Texas Commission on Environmental
Quality's (TCEQ's) PCB total maximum daily load (TMDL) development for the Houston Ship
Channel and Upper Galveston Bay.11 All of the facility's 2009 PCB sample concentrations were
below detection limits, which is consistent with its previous and 2010 results. (The facility has
detected PCBs in its sludge, which it disposes of offsite.) However, the University of Houston
measured 0.71 nanograms per liter (ng/L) of PCBs in a sample of the facility's wastewater. The
facility used the 0.71 ng/L result and the 2009 flow rate to calculate its 2009 TRI PCB
discharges. The facility contact suspected that the University of Houston's PCBs results differ
from the facility's because of method variations (King, 2011).
As a result, EPA determined that the reported 2009 TRI discharge from GB Biosciences
overestimates the actual discharge. The facility used the sampling result from the TMDL study
and did not factor in the non-detect values measured throughout the year. Because all of the
11 TCEQ began developing the TMDL for PCBs as a result of seafood consumption advisories for various species of
fish, issued by the Texas Department of State Health Services after PCBs were detected in the fish tissue beginning
in 2001 (HGAC, 2011; TCEQ, 2010). TCEQ analyzed effluent samples from 20 different sampling sites in 2009
around the Houston Ship Channel and Galveston Bay areas. GB Biosciences was the only pesticide manufacturing
facility sampled (Parsons, 2009). TCEQ reported the effluent PCB concentration from GB Biosciences to be
between 0.136 and 0.300 ng/L. Other facilities included in the TMDL development sampling had effluent PCB
concentrations between 0.136 and 3.214 ng/L (Parsons, 2010).
18-3
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Section 18—Pesticide Chemicals (40 CFR Part 455)
facility's 2009 data are non-detect, EPA is zeroing the PCB TWPE for GB Biosciences.
Additionally, the TMDL study will ensure that any actual PCB discharges are controlled
sufficiently. Correcting this discharge will result in the total category TWPE decreasing from
45,700 to 32,700.
18.4 Pesticide Chemicals Category Conclusions
The estimated toxicity of the Pesticide Chemicals Category discharges results mainly
from the PCB discharges of one facility (accounting for 28 percent of the category's 2009
combined TWPE). Using data collected for the 2011 Annual Reviews, EPA concludes the
following:
One facility, GB Biosciences, accounts for all of the 2009 TRI PCB discharges. The
facility reported the TRI PCB discharges in grams instead of pounds. Additionally, the facility
used a sample collected by the University of Houston as part of the TCEQ TMDL study to
calculate its 2009 PCB discharges as reported to TRI. However, the facility has a long history of
testing for PCBs and finding concentrations below levels of detection (King, 2011). EPA
determined that the 2009 TRI discharge for GB Biosciences overestimates the actual discharge
and zeroed the facility's PCB discharges for toxicity ranking purposes.
The total 2009 category TWPE after correcting the units and amount of the PCB
discharge from GB Biosciences is 32,700. This change would drop the category outside the top
95 percent that EPA prioritized for preliminary review as part of the 2011 Annual Reviews.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
18.5 Pesticide Chemicals Category References
1. HGAC. 2011. Houston-Galveston Area Council. Houston Ship Channel and Upper
Galveston Bay: TMDL Project for Dioxin and Polychlorinated Biphenyls (PCBs) in Fish
Tissue. (April 14). EPA-HQ-OW-2010-0824. DCN 07612.
2. King, Stephanie. 2011. Telephone Communication Between Stephanie King, GB
Biosciences, and Kimberly Landick, Eastern Research Group, Inc., Re: 2009 TRI PCB
Discharges. (May 10). EPA-HQ-OW-2010-0824. DCN 07613.
3. Parsons. 2009. Total Maximum Daily Loadfor PCBs in the Houston Ship Channel.
University of Houston. (July 14). EPA-HQ-OW-2010-0824. DCN 07614.
4. Parsons. 2010. Total Maximum Daily Load for PCBs in the Houston Ship Channel +
Survey and Snapshot of PCBs and Dioxin in the Houston Ship Channel and Galveston
Bay System. University of Houston. (June 23). EPA-HQ-OW-2010-0824. DCN 07615.
18-4
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Section 18—Pesticide Chemicals (40 CFR Part 455)
5. TCEQ. 2010. Texas Commission on Environmental Quality, Total Maximum Daily Load
Program. Improving Water Quality in the Houston Ship Channel and Galveston Bay,
Thirteen TMDLs for PCBs. (March). EPA-HQ-OW-2010-0824. DCN 07616.
6. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004-
0032-0053.
7. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
8. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
9. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
18-5
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Section 19—Petroleum Refining (40 CFR Part 419)
19. Petroleum Refining (40 CFR Part 419)
EPA selected the Petroleum Refining Category for preliminary review because it ranks
high, in terms of toxic-weighted pound equivalent (TWPE), in the point source category
rankings. EPA reviewed discharges from the Petroleum Refining Category as part of the 2004-
2009 Annual Reviews (U.S. EPA, 2004, 2005, 2006, 2007, 2008, 2009). EPA also conducted a
detailed study of this industry in support of the 2004 Final Effluent Guidelines Program Plan
(U.S. EPA, 2004). This section describes the results of EPA's 2011 preliminary category review
of the Petroleum Refining Category. The review focused on discharges of dioxin and dioxin-like
compounds and polycyclic aromatic compounds (PACs) from the Toxics Release Inventory
(TRI) and sulfide, chlorine, and metals discharges from discharge monitoring reports (DMR),
because of their high TWPE relative to other pollutants in the Petroleum Refining Category.
19.1 Petroleum Refining Category 2011 Toxicity Rankings Analysis
Table 19-1 compares the toxicity rankings analysis results for the Petroleum Refining
Category from the 2007 through 2011 Annual Reviews. The combined TWPE from discharges in
the DMR and TRI databases decreased from discharge years 2004 to 2007, increased from 2007
to 2008, and then decreased from 2008 to 2009. The estimated 2009 TRI TWPE accounts for
approximately 60 percent of the combined 2009 DMR and TRI TWPE.
Table 19-1. Petroleum Refining Category TRI and DMR Discharges for 2007
Through 2011 Toxicity Rankings Analysis
Year of Discharge
Year of Review
Petroleum Refining Category
TRI TWPE"
DMR TWPEb
Total TWPE
2004
2007
669,000
819,000
1,490,000
2005
2008
628,000
NA
NA
2007
2009
172,000
403,000
575,000
2008
2010
410,000
680,000
1,090,000
2009
2011
436,000
295,000
731,000
Sources: TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; TRIReleases2007_v2;
DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3; TRIReleases2009_v2; and
DMRLoads2009 v2.
a Discharges include transfers to publicly owned treatment works (POTWs) and account for POTW removals.
b DMR data from 2004 through 2007 include only major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
19.2 Petroleum Refining Category Pollutants of Concern
EPA's review of the Petroleum Refining Category focused on the 2009 TRI and DMR
discharges because the category's combined TWPE is not dominated by either the 2009 TRI or
DMR data. Table 19-2 lists the five pollutants with the highest TWPE in TRIReleases2008 v3
and TRIReleases2009 v2. Table 19-3 lists the five pollutants with the highest TWPE in
DMRLoads2007 v3 and DMRLoads2009 v2. The top TRI pollutant, dioxin and dioxin-like
compounds, contributes more than 72 percent of the total TRI TWPE. The top DMR pollutants,
sulfide and chlorine, contribute more than 61 percent of the total DMR TWPE.
19-1
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Section 19—Petroleum Refining (40 CFR Part 419)
Table 19-2. Petroleum Refining Category Top TRI Pollutants
Pollutant
2008"
2009"
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Dioxin and dioxin-like compounds
1
20
300,000
1
19
315,000
Polycyclic aromatic compounds
2
62
33,700
2
63
35,000
Mercury and mercury compounds
3
62
18,800
3
68
22,600
Lead and lead compounds
5
107
11,300
4
113
16,700
Nitrate compounds
4
65
18,200
5
66
14,600
Petroleum Refining Category Total
NA
298b
410,000
NA
280b
436,000
Sources: TRIReleases2008_v3 and TRIReleases2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b Number of facilities reporting TWPE greater than zero.
Table 19-3. Petroleum Refining Category Top DMR Pollutants
Pollutant
2008
2009
Rank
Number of Facilities
Reporting Pollutant
TWPE
Rank
Number of Facilities
Reporting Pollutant
TWPE
Sulfide
1
77
203,000
1
73
136,000
Chlorine
3
22
132,000
2
23
45,700
Chloride
4
15
39,000
3
14
16,800
Aluminum
Pollutants not reported in the top five 2008
DMR-reported pollutants.
4
12
14,200
Selenium
5
23
12,200
Benzene
2
86
150,000
Pollutants not reported in the top five 2009
DMR-reported pollutants.
Toluene
5
55
31,900
Petroleum Refining
Category Total
NA
248"
680,000
NA
249"
295,000
Sources: DMRLoads2008_v3 and DMRLoads2009_v2.
" Number of facilities reporting TWPE greater than zero.
NA: Not applicable.
The following subsections discuss EPA's additional review for the 2009 TRI and DMR
database pollutants of concern: dioxin and dioxin-like compounds, sulfide, chlorine, and metals.
EPA also reviewed the TRI PAC discharges and confirmed that there is little evidence that PACs
are being discharged to surface waters in concentrations above the detection limit, previously
concluded during the 2004 Annual Reviews (U.S. EPA, 2004). EPA did not investigate the other
top pollutants as part of the 2011 Annual Reviews.
19.3 Petroleum Refining Category Dioxin and Dioxin-Like Compound Discharges in TRI
Dioxin and dioxin-like compounds contribute 72 percent of the total 2009 TRI TWPE
and increased by approximately 15,000 TWPE from reporting years 2008 to 2009. EPA
previously determined that refineries produce dioxin and dioxin-like compounds during catalytic
reforming and catalyst regeneration operations (U.S. EPA, 2004). Table 19-4 summarizes the
19-2
-------
Section 19—Petroleum Refining (40 CFR Part 419)
number of facilities and total TWPE for discharge years 2004 through 2009 and demonstrates the
large increase in estimated TWPE. Table 19-15, at the end of this section, presents the petroleum
refineries that reported dioxin and dioxin-like compound discharges to TRI in 2009 and shows
that the majority of this increase results from a single facility.
Table 19-5 summarizes the 2009 basis of estimates reported by the 19 refineries
discharging dioxin in 2009 by type of estimate. Of the 19 refineries reporting dioxin and dioxin-
like compound discharges to TRI in 2009, only nine of these refineries reported dioxin
discharges based on analytical measurements, the other refineries never measured for dioxin and
dioxin-like compounds.
Table 19-4. Summary of Dioxin and Dioxin-Like Compound Discharges, 2004-2009
Year of Discharge
21MW
200X
2IHP
2005
2004
Number of facilities
19
20
9
15
17
Total TWPE
315,000
300,000
94,500
516,000
559,000
Sources: TRIReleases2004_v3; TRIReleases2005_v2; TRIReleases2007_v2; TRIReleases2008_v3; and
TRIReleases2009 v2.
Table 19-5. Basis of Estimate Summary for 2009 Dioxin and
Dioxin-Like Compound Discharges
ISiisis of I.N(iin;ik'
Ml or \12
<
i:i oi-1.2
()
Number of facilities
9
2
3
5
Source: TRIReleases2009jv2.
Ml: continuous monitoring data or measurements
M2: periodic or random monitoring data or measurements
C: mass balance calculations, such as calculation of the amount of the toxic chemical in streams entering and
leaving process equipment
El: published emission factors
E2: site-specific emission factors
O: other approaches, such as engineering calculations
Hovensa LLC in Christiansted, VI, accounts for 65 percent of the category's dioxin and
dioxin-like compound discharges in TRIReleases2009v03. As part of the 2011 Annual Reviews,
EPA contacted the facility about its dioxin and dioxin-like compound discharges. The facility
contact stated that the dioxin discharges are estimated using literature values associated with
dioxin formation from reformer catalyst regeneration. The facility indicated that the increase in
dioxin discharges from 2008 to 2009, shown in Table 19-15, was due to the number of times the
facility regenerated the reformer catalyst, once in 2008 compared to three times in 2009. The
facility contact stated that the number of regenerations required in a given year could vary
between zero and three, depending on different operating factors (Vernon, 2011). The facility
used the dioxin distributions given in the Dioxins and Refineries: Analysis in the San Francisco
Bay Area report (CBE, 2000) to estimate the dioxin load and distribution, presented in Table
19-6. The source of these dioxin distributions is the 1996 EPA Preliminary Data Summary for
the Petroleum Refining Category.
19-3
-------
Section 19—Petroleum Refining (40 CFR Part 419)
Table 19-6. Bay Area Refineries Reformer Water Results"
Dioxin Convenor
T\\ 1
( hc\ roil
( onccnlralion
(pii/l.)
Richmond
Disl rihu lion
Iosco
( OIKTIIII'illioil
(pii/l.)
A\on
Disl rihu lion
Iosco
( onccnlralion
ipfi/l.)
iorico1'
Disl rihu 1 icin
2,3,7,8- TCDD
703,584,000
170
0.206
BD
0
22
0.289
1,2,3,7,8-PeCDD
692,928,000
730
0.886
BD
0
85
1.12
1,2,3,4,7,8-HxCDD
23,498,240
740
0.898
8,700
0.39
90
1.18
1,2,3,6,7,8-HxCDD
9,556,480
920
1.12
15,700
0.703
90
1.18
1,2,3,7,8,9-HxCDD
10,595,840
440
0.534
16,900
0.757
190
2.5
1,2,3,4,6,7,8-HpCDD
411,136
2,640
3.2
55,900
2.5
890
11.7
OCDD
6,586
1,170
1.42
68,400
3.06
1,400
18.4
2,3,7,8-TCDF
43,819,554
3,350
4.07
5,300
0.237
150
1.97
1,2,3,7,8-PeCDF
7,632,640
9,150
11.1
44,000
1.97
120
1.58
2,3,4,7,8-PeCDF
557,312,000
4,600
5.58
111,500
4.99
180
2.37
1,2,3,4,7,8-HxCDF
5,760,000
14,700
17.8
128,500
5.76
340
4.47
1,2,3,6,7,8-HxCDF
14,109,440
5,800
7.04
131,000
5.87
240
3.15
2,3,4,6,7,8-HxCDF
47,308,800
1,320
1.6
25,000
1.12
190
2.5
1,2,3,7,8,9-HxCDF
51,204,160
1,700
2.06
177,000
7.93
230
3.02
1,2,3,4,6,7,8-HpCDF
85,760
17,200
20.9
599,000
26.8
970
12.8
1,2,3,4,7,8,9-HpCDF
3,033,984
7,500
9.1
566,000
25.4
520
6.84
OCDF
2,021
10,250
12.4
279,500
12.5
1,900
25
Total TWF
45,900,000
34,900,000
28,300,000
Source: Dioxins and Refineries report (CBE, 2000).
a Dioxin sampling occurred on wastewater directly exiting the reformer catalyst regenerators.
b Tosco Rodeo is now ConocoPhillips Rodeo.
BD: Below detection.
19-4
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Section 19—Petroleum Refining (40 CFR Part 419)
As new data becomes available, EPA will review dioxin discharges for the Petroleum
Refining Category to determine if the same conclusions apply.
19.4 Petroleum Refining Category PAC Discharges in TRI
PACs discharges contribute 8 percent of the total 2009 TRI TWPE and increased by
approximately 1,300 TWPE from reporting years 2008 to 2009. Table 19-16, presented at the
end of this section, lists the petroleum refineries that reported PACs to TRI in 2009. Exxon
Mobil Oil Corp.'s Joliet Refinery in Channahon, IL, contributed 26 percent of the PAC
discharges for TRI 2009. Table 19-7 presents the total PAC discharges from years 2004 through
2009, which have remained consistent.
Table 19-7. Total TRI PACs Discharges for Years 2004-2009
200')
201 IS
200"7
2005
2004
TWPE
35,000
33,700
31,000
34,300
26,100
Sources: TRIReleases2004_v3; TRIReleases2005_v2; TRIReleases2007_v2; TRIReleases2008_v3; and
TRIReleases2009_v2.
EPA examined PAC discharges from petroleum refineries extensively for its previous
detailed and preliminary category reviews. From these previous studies, EPA concluded that the
petroleum refinery PAC discharges reported to TRI are either (1) based on half the detection
limit multiplied by the flow or (2) estimated using emission factors.
Therefore, there is little evidence that PACs are being discharged to surface waters in
concentrations above the detection limit (U.S. EPA, 2004). As shown in Table 19-7, the TWPE
is consistent from discharge year 2004 to 2009 and, therefore, EPA's previous conclusions from
the detailed study are still accurate.
19.5 Petroleum Refining Category Sulfide Discharges in DMR
Sulfide discharges in the 2009 DMR database account for 46 percent of the category's
total DMR TWPE. Table 19-8 presents the top sulfide dischargers in the 2009 DMR database.
The majority (54 percent) of the sulfide discharges are from four facilities; EPA focused the
further review of the category's sulfide discharges on these facilities.
Table 19-8. Petroleum Refining Category Sulfide Dischargers in the 2009 DMR Database
Facility Name
Location
Sulfide Pounds
Discharged
Sulfide TWPE
Facility Percent of
Sulfide Category
TWPE
Beaumont Refinery
Beaumont, TX
15,900
44,400
32%
Texas City Refinery
Texas City, TX
4,270
12,000
9%
Exxon Company USA
Baton Rouge
Baton Rouge, LA
3,710
10,400
8%
19-5
-------
Section 19—Petroleum Refining (40 CFR Part 419)
Table 19-8. Petroleum Refining Category Sulfide Dischargers in the 2009 DMR Database
Facility Name
Location
Sulfide Pounds
Discharged
Sulfide TWPE
Facility Percent of
Sulfide Category
TWPE
Citgo Petroleum
Corporation
Lake Charles, LA
2,490
6,980
5%
Remaining facilities reporting sulfide discharges3
22,300
62,600
46%
Total
48,700
136,000
100%
Source: DMRLoads2009_v2.
a There are 69 remaining facilities that have sulfide discharges in the 2009 DMR database, which account for 46
percent of the category's sulfide DMR TWPE.
2 2
Sulfide is an anion of sulfur in its lowest oxidation state of minus 2 (S "). The dianion S "
exists only in strongly alkaline aqueous solutions. Such solutions can form by dissolution of H2S
or alkali metals such as lithium sulfide, sodium sulfide, and potassium sulfide in the presence of
excess hydroxide ions. The ion S2 is exceptionally basic, with an acid dissociation constant
(pKa) greater than 14. Sulfide does not exist in appreciable concentrations even in highly alkaline
water. Instead, sulfide combines with protons to form HS , which is variously called H2S ion. At
still lower pH values (<7), HS converts to H2S, as shown by the equation below. At a pH of 5,
nearly 100 percent of sulfide is present as H2S.
H2S O HS" + H+ and HS" O S" + H+ (Eq. 19-1)
Sulfides are moderately strong reducing agents. They react with oxygen in the air in
elevated temperatures to form higher-valence sulfur salts, such as sulfates and sulfur dioxide.
Aqueous solutions of transition metals cations react with sulfides to precipitate solid metal
sulfide salts. The metal sulfide salts typically have very low solubility in water.
Sulfides are constituents of many industrial wastes such as those from tanneries, paper
mills, chemical plants, and gas works (U.S. EPA, 1986). Sulfides discharged to neutral receiving
waters can be reduced to hydrogen disulfide (H2S), an extremely toxic, odiferous, and corrosive
gas. Minute concentrations (2 micrograms per liter) of H2S impart an objectionable odor and
taste to water, making it unfit for municipal consumption (U.S. EPA, 1974).
The Petroleum Refining Category effluent limitations guideline (ELG) does set limits for
sulfide; however, they are production based limits. Therefore, EPA did not compare the ELG
production based limits to the concentration and quantity discharges from the top sulfide
discharging facilities. Sources of sulfide in the Petroleum Refining Category include crude
desalting, crude distillation, and cracking processes (U.S. EPA, 1982).
19.5.1 Sulfide Wastewater Treatment
The following discusses various treatment options for sulfide in industrial wastewaters.
Although the options presented below have the ability to remove sulfide from wastewater, the
actual effluent concentrations attainable are a function of treatment system design, which is
beyond the scope of this section (Briggs, 2011). In addition to wastewater treatment, substituting
sulfur dyes in the dyeing processes is another way textile mills can reduce sulfide discharges
(U.S. EPA, 1982).
19-6
-------
Section 19—Petroleum Refining (40 CFR Part 419)
19.5.2 Biological Treatment
Biological treatment, the treatment basis for the BAT limits, treats industrial effluent
streams by either aerobic or anaerobic processes (U.S. EPA, 1974). It involves bacteria that
stabilize wastes by decomposing them to form harmless inorganic solids (Durai and
Rajasimman, 2011).
EPA identified two recent studies on industrial waste with high sulfide concentrations:
• The first study (Camper and Bott, 2006) investigated a viscose rayon plant, where
one- and two- stage biological treatment was used for influent with high levels of
reduced sulfur compounds (i.e., sulfide) and organic contaminants. The study
showed that about 99 percent of the influent sulfide can be biologically oxidized
to sulfate. This resulted in effluent sulfide concentrations less than 2.5 mg/L.
• The second study (Durai and Rajasimman, 2011) concerned a tannery. It showed
that pretreatment for aerobic units and post-treatment for anaerobic units,
including oxidation of sulfide by air using activated carbon as a catalyst,
eliminates sulfide in the wastewater effluent.
19.5.3 Aeration and Air Stripping
Aeration is a common method for removal of dissolved gasses such as H2S. Aeration
processes are, generally, used in two types of water applications: air stripping, the process in
which gas is removed from water, and aeration, the process in which air or oxygen is transferred
to water. Henry's Law describes the tendency of a constituent to transfer from the liquid to the
gas phase at equilibrium. The Henry's Law constant is the ratio of the equilibrium concentration
of a particular contaminant in air to its concentration in water. Thus, a higher Henry's Law
constant indicates a greater tendency of species to volatilize. Compounds with Henry's Law
constants above 10 atmospheres per mole fraction are readily air strippable. Because the Henry's
Law constant for sulfide ion is very low, it is not published; however, the Henry's Law constant
for H2S is 468 at 20°C, which indicates that sulfide must first be converted to H2S by the addition
of acid to pH 5 or below. High temperature and turbulence promotes gas transfer by reducing
thickness of film at air-water interface. The efficiency of aeration depends almost entirely on the
amount of surface contact between the air and water. Method of aeration can be classified into
four general categories: waterfall, bubble, mechanical, and pressure aeration (Briggs, 2011).
The effectiveness of aeration for removing sulfide depends upon the aeration method
selected, the pH of the water (which dictates the applicable Henry's law constant), design factors
such as air to water ratio, flow and loading rate, available area of mass transfer, temperature, and
algae production. The major drawback to aeration is that H2S is not destroyed, but is instead
transferred to an air emission (Briggs, 2011).
19.5.4 Hydrogen Peroxide Oxidation
Hydrogen peroxide (H2O2) controls sulfide by oxidation to either elemental sulfur or
sulfate ion depending on the pH of the wastewater. Hydrogen peroxide oxidation of sulfide has
been demonstrated at both industrial facilities and municipal wastewater treatment plants. At
neutral or slightly acid pH conditions, the product of sulfide oxidation is predominately
19-7
-------
Section 19—Petroleum Refining (40 CFR Part 419)
elemental sulfur, which appears as a yellow colloid (if H2O2 is underdosed) or a white colloid
(with complete oxidation). Colloidal elemental sulfur can be removed from the wastewater
following H2O2 oxidation by flocculation with an anionic polymer and filtration. The reaction
below shows the oxidation of H2S to elemental sulfur under neutral or slightly acid conditions
(Briggs, 2011).
H2S + H202 ^ So + H20 (Eq. 19-2)
It is not unusual for system efficiencies to approach 100 percent, particularly when the
concentrations of other oxidizable substances (e.g., thiosulfate) are low, and when the reaction is
accelerated by a catalyst such as ferric iron. In the presence of enough ferric iron, 99 percent of
H2S can be removed from wastewater (Briggs, 2011). Under alkaline conditions (pH > 9.2),
sulfide is converted to sulfate by H2O2 as shown by the reaction below.
S2" + 4H202 ¦=> S042" + 4H20 H20 (Eq. 19-3)
It is not unusual for system efficiencies to approach 100 percent, provided that the H2O2
is added in a controlled fashion and the reaction medium is thoroughly mixed. This is due to the
faster reaction brought about by the increased reactivity of H2O2 at alkaline pH. Consequently, as
the pH increases above 9 or 10, there is generally little benefit to catalyzing the reaction. At a pH
9, sulfide can be oxidized to sulfate in 15 minutes. Since sulfate is very soluble in water, no
additional wastewater processing (e.g., filtration) is required following peroxide oxidation
(Briggs, 2011).
Table 19-9 presents discharge data for the top four facilities discharging sulfide and their
permit limits. The majority of discharges for all four facilities are below or near treatable levels
(Briggs, 2011). EPA determined that sulfide discharges do not represent a hazard priority at this
time.
Table 19-9. Top Sulfide Discharging Facilities
Reported
Reported
Permit
( oneenlmlion
Ou;iiilil> Riiniic
l-'low
Limits
l";ieili(\ \;ime
l.oeiilion
OiiHiill
Kiinuo (inii/l.)
(kii/d;i\)
(MCI))
(lhs/d;i\)
Beaumont Refinery
Beaumont, TX
001
0.02-4.8
NR
11-14
NA
Texas City Refinery
Texas City, TX
001
0-0.05
0-2.93
0-15.44
NA
005
0-0.05
0-3.73
0-19.96
006
0.04-0.10
1.82-3.73
9.79-15.44
NA
Exxon Company
USA
Baton Rouge,
LA
001
0.044-0.257
2.27-13.2
13.5-14.1
NA
Citgo Petroleum
Lake Charles,
001
0.00624-0.0208
0.10-0.30
1.09-1.92
17.6
Corporation
LA
003
0.0262-0.268
3.0-19.0
8.49-11.5
21.8
Source: DMR Loadings Tool.
NR: Not reported.
NA: Not applicable.
19.6 Petroleum Refining Category Chlorine Discharges in DMR
Chlorine discharges in the 2009 DMR database account for 15 percent of the category's
total DMR TWPE. Table 19-10 presents the chlorine discharges in the 2009 DMR database.
Discharges of chlorine from one facility, Premcor DCR, account for 75 percent of the category's
19-8
-------
Section 19—Petroleum Refining (40 CFR Part 419)
chlorine DMR TWPE. Accordingly, EPA focused its review of chlorine discharges on that
facility.
Table 19-10. Petroleum Refining Category Chlorine Dischargers
in the 2009 DMR Database
Facility Name
Location
Chlorine
Pounds
Discharged
Chlorine TWPE
Facility Percent
of Chlorine
Category TWPE
Premcor DCR
Delaware City, DE
68,700
34,400
75%
Remaining facilities reporting chlorine discharges3
22,700
11,400
25%
Total
91,500
45,700
100%
Source: DMRLoads2009_v2.
a There are 22 remaining facilities that have chlorine discharges in the 2009 DMR database, which account for 25
percent of the category's chlorine DMR TWPE.
Premcor DCR in Delaware City, DE, discharges chlorine from its outfall 001. Premcor's
refinery shut down at the end of 2009 (Valero, 2009). On June 1, 2010, PBF Energy acquired the
refinery and it started back up in May 2011 (Seba, 2011). Table 19-11 presents Premcor's 2009
monthly chlorine and flow discharge data from the DMR Loadings Tool. As Table 19-11 shows,
three concentrations are above the detection limit; however, the concentration values reported are
the same as in months that are below the detection limit (BDL). As a result, EPA suspects that
the BDL indicators are missing from these 2009 concentrations. With a BDL indicator added for
January, February, and April 2009 discharges, the facility's chlorine TWPE decreases to zero.
Table 19-11. Premcor's Outfall 001 2009 Monthly Chlorine and Flow Discharge Data
Monitoring Period Date
DMR Loadings Tool Average
Chlorine Discharge (mg/L)
DMR Loadings Tool Average
Flow (MGD)
31-Jan-09
0.1
298
28-Feb-09
0.2
299
31-Mar-09
<0.1
241
30-Apr-09
0.1
177
31-May-09
<0.1
356
30-Jun-09
<0.1
409
31-Jul-09
<0.2
419
31-Aug-09
<0.1
403
30-Sep-09
<0.1
391
31-Oct-09
<0.1
316
30-Nov-09
<0.1
270
31-Dec-09
<0.1
106
Source: DMR Loadings Tool.
19.7 Petroleum Refining Category Metals Discharges in DMR
Petroleum refinery wastewater contains a number of metals. The major source of metals
in refinery wastewater is crude petroleum. Pipe corrosion, catalyst additives, other refinery raw
19-9
-------
Section 19—Petroleum Refining (40 CFR Part 419)
materials, cooling water biocide, and supply water also contribute metals to refinery wastewater
(U.S. EPA, 2004).
Table 19-12 presents the DMR metals discharges from discharge years 2000 to 2009.
During the 2004 Annual Reviews, EPA concluded that 10 metals are most commonly found in
discharges from petroleum refineries (U.S. EPA, 2004). Table 19-13 lists these metals, along
with the number of facilities reporting each metal in 2009 and the total 2009 pollutant TWPE.
Table 19-14 presents the top 98 percent of facilities that are discharging metals with the metals
they discharged. The Petroleum Refining Category ELG does set limits for chromium; however,
they are production based limits. Therefore, EPA did not compare the ELG production based
limits to the concentration and quantity discharges from the top chromium discharging facilities.
Table 19-12. DMR Metal Discharges, 2000-2009
2009
2008
2007
2004
2000
Total Metals TWPE
66,300
56,300
134,000
63,700
33,500
Sources: PCSLoads2000; PCSLoads2004_v3; DMRLoads2007_v4; DMRLoads2008_v3; and DMRLoads2009_v2.
Table 19-13. 2009 Petroleum Refinery Metals DMR Discharges
Metal
2000
2009
Number of
Facilities
Reporting
Metals®
Number of Facilities
Reporting Non-Zero
TWPE
Total
Metal
TWPE
Number of
Facilities
Reporting
Metals3
Number of Facilities
Reporting Non-Zero
TWPE
Total
Metal
TWPE
Aluminum
7
6
7,830
17
12
14,200
Arsenic
18
10
5,770
46
13
4,560
Chromium
99
61
553
124
54
178
Copper
26
18
712
87
46
4,650
Lead
28
11
1,575
167
47
8,620
Mercury
16
7
1,910
59
21
7,950
Nickel
17
13
480
57
22
448
Selenium
23
18
9,040
52
23
12,200
Vanadium
3
3
1,120
2
2
11,800
Zinc
39
32
1,110
96
54
1,680
Total
104
77
30,100
253
117
66, 300
Source: PCSLoads2000_v3 and DMR Loadings Tool.
a This number includes all facilities reporting metal concentrations.
19-10
-------
Section 19—Petroleum Refining (40 CFR Part 419)
Table 19-14. 2009 Top Petroleum Refineries Discharging Metals in DMR
Facility Name
Location
Total Metal
TWPE
Aluminum
Arsenic
Chromium
•-
a.
o
U
Lead
Mercury
Nickel
Selenium
Vanadium
Zinc
Trainer Oil Refinery
Trainer, PA
15,100
X
X
X
X
X
BP Products Whiting Refinery
Whiting, IN
13,800
X
X
X
X
X
Suncor Energy (USA) Inc.
Commerce City,
CO
7,510
X
X
X
X
X
X
X
X
Sunoco, Inc.
Philadelphia, PA
4,690
X
X
X
Flint Hills Resources LP
Pine Bend, MN
3,780
X
X
El Segundo Refinery
El Segundo, CA
3,470
X
X
X
X
X
X
X
Motiva Enterprises, LLC
Norco, LA
2,430
X
Phillips 66 Company, Sweeny
Old Ocean, TX
2,290
X
X
X
Tosco Refinery
Rodeo, CA
1,990
X
X
X
X
X
X
X
X
Ergon-West Virginia Inc.
Newell, WV
1,770
X
X
X
X
Delek Refining, LTD.
Tyler, TX
1,280
X
X
Catlettsburg Refining LLC
Boyd County, KY
1,100
X
X
X
X
ConocoPhillips Company-
Lake Charles
Westlake, LA
901
X
X
X
X
Martinez Refinery
Martinez, CA
792
X
X
X
X
X
Valero Memphis Refinery
Memphis, TN
755
X
X
X
Borger Refinery
Borger, TX
488
X
X
X
The Premcor Refining Group
Port Arthur, TX
443
X
X
Lion Oil Co
El Dorado, AR
392
X
X
X
X
Source: DMR Loadings Tool.
EPA does not have enough information to determine if the metals discharges present a
hazard. EPA intends to collect information on the concentrations of metals in the discharges and
to compare these to treatability concentrations in the 2012 planning year.
19.8 Petroleum Refining Category Conclusions
EPA's estimate of the toxicity of Petroleum Refining Category discharges is largely due
to the TRI-reported discharges of dioxin and dioxin-like compounds and PACs and DMR-
reported discharges of sulfides, chlorine, and metals. Using data collected for the 2011 Annual
Reviews, EPA concluded the following:
• EPA previously determined that refineries form dioxin and dioxin-like
compounds during catalytic reforming and catalyst regeneration operations. One
facility, Hovensa, accounts for 65 percent of the category's dioxin and dioxin-like
compound discharges in TRI2009. The increase in discharge of dioxin and
dioxin-like compounds from this facility was due to an increase in the number of
catalyst regenerations. To complete its review, EPA requires additional
information on other refinery dioxin discharge. EPA will continue to review the
19-11
-------
Section 19—Petroleum Refining (40 CFR Part 419)
remaining dioxin and dioxin-like compound discharges during its 2012 Annual
Reviews.
• PAC discharges have remained consistent from 2004 to 2009, so EPA's
conclusions from the detailed study still apply. As a result, EPA does not consider
these PAC discharges from the Petroleum Refining Category a hazard priority at
this time.
• Four facilities account for 54 percent of the DMR sulfide discharges for the
Petroleum Refining Category. The majority of discharges for all four facilities are
below or near treatable levels. EPA does not consider these sulfide discharges
from the Petroleum Refining Category a hazard priority at this time.
• One facility, Premcor, accounts for 75 percent of the DMR chlorine discharges for
the Petroleum Refining Category. EPA suspects missing BDL indicators in the
data. With this error corrected, the facility TWPE decreases to zero.
• Petroleum refinery wastewater contains a number of metal pollutants. To
complete its review, EPA requires additional information to evaluate the
discharge hazards associated with metals and will continue reviewing the
discharges during its 2012 Annual Reviews.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(5)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
19.9 Petroleum Refining Category References
1. Briggs, Mark. 2011. Sulfide Treatment Technologies Memorandum. Eastern Research
Group. (July 15). EPA-HQ-OW-2010-0824 DCN 07617.
2. Camper, Ian, and Charles Bott. 2006. Improvement of an Industrial Wastewater
Treatment System at a Former Viscose Rayon Plant—Resulting From Two-State
Biological Leachate Treatability Testing. Water Environment Foundation. EPA-HQ-OW-
2010-0824. DCN 07505.
3. CBE. 2000. Communities for a Better Environment. Dioxins and Refineries: Analysis in
the San Francisco Bay Area. Report No. 2000-2. (August). EPA-HQ-OW-2010-0824
DCN 07618.
4. Durai, G, and M Rajasimman. 2011. Biological Treatment of Tannery Wastewater—A
Review. Journal of Environmental Science and Technology. Volume 4 (1): 1-17.
(January 17). EPA-HQ-OW-2010-0824 DCN 07506.
5. Seba, Erwin. 2011. UPDATE 1-PBF Restarts Delaware City Crude Unit—Sources.
Reuters. (June 23). Available online at:
19-12
-------
Section 19—Petroleum Refining (40 CFR Part 419)
http://www.reuters.com/article/2011/06/23/refinery-operations-pbf-delawarecity-
idUSWEN466320110623?feedType=RSS. EPA-HQ-OW-2010-0824 DCN 07619.
6. U.S. EPA. 1974. Development Document for Effluent Guidelines and New Source
Performance Standards for the Textile Mills Point Source Category. Washington, D.C.
(June). EPA-440-1 -79-022b.
7. U.S. EPA. 1982. Development Document for Effluent Limitations Guidelines and
Standards for the Petroleum Refining Point Source Category. Washington, D.C.
(October). EPA-821-R-04-014.
8. U.S. EPA. 1986. Quality Criteria for Water 1986. Washington, D.C. (May). EPA-440-5-
86-0010.
9. U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352
10. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004-0032-
0053.
11. U.S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
12. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
13. U.S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-08-015. EPA-HQ-OW-2006-0771-1701.
14. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-0517-0515.
15. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
16. Valero. 2009. Valero Marketing and Supply Company. Valero to Permanently Close
Delaware City Refinery to Strengthen Financial Position. (November 20). Available
online at: http://www.valero.eom/NewsRoom/Pages/PR_20091120_0.aspx. EPA-HQ-
OW-2010-0824 DCN 07620.
17. Vernon, Kent. 2011. Telephone and Email Communication Between Kent Vernon,
Hovensa, and Elizabeth Sabol, Eastern Research Group, Inc., Re: Request for 2009 TRI
Data Clarification. (January 10). EPA-HQ-OW-2010-0824 DCN 07621.
19-13
-------
Section 19—Petroleum Refining (40 CFR Part 419)
Table 19-15. Dioxin and Dioxin-Like Discharges From Petroleum Refineries Reported to TRI in 2004-2009
Facility Name
Locution
( ,'ommcnts
2009
2008
2007
2005
2004
Grams
Released
TWPK
liusis of
Kstimate
(Irams
Released
TWPK
Uasis of
Kstimate
Grams
Released
TWPK
Uasis of
Kstimatc
Grams
Released
TWPK
Basis of
Kstimate
Grams
Released
TWPK
Uasis of
Kstimate
Hovensa, LLC
Christiansted,
VI
No DMR data;
TWPE is driving
force for 08-09
change in
discharge
1.65
205,07
3
O
0.55
12,848
O
NR
NR
NR
2.2
180,44
2
E
1.7
148,653
C
Chevron
Products Co.
Richmond
Refinery
Richmond,
CA
DMR TWPE is
zero; grams is
driving force for
08-09 change in
discharge
0.25
20,621
M2
0.65
84,423
M2
0.32
33,397
M2
0.94
121,52
1
M
1.35
141,106
O
Valero Refining
Co, Oklahoma
Valero
Ardmore
Refinery
Ardmore, OK
No DMR data;
new to report in
2009
0.18053
16,463
C
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Conoco Phillips
Co, Billings
Refinery
Billings, MT
No DMR data;
TWPE is driving
force for 08-09
change in
discharge
0.08
16,169
M2
0.091
3,125
M2
NR
NR
NR
NR
NR
NR
NR
NR
NR
Chevron
Products Co.
Div of Chevron
USA Inc.
El Segundo,
CA
DMR TWPE is
zero; grams is
driving force for
08-09 change in
discharge
0.599
13,283
M2
0.8912
81,266
M2
0
0
M2
0.158
16,221
M
0.2
20,533
M
Marathon
Ashland
Petroleum
LLC, Illinois
Refining Div
Robinson, IL
No DMR data;
grams is driving
force for 08-09
change in
discharge
0.0404
12,622
M2
0.0405
28,571
O
0.04
1,094
O
0.0404
3,314
O
0.04
3,604
O
Chevron
Products Co.
Salt Lake City
Refinery
Salt Lake
City, UT
No DMR data;
new to report in
2009
0.097
12,611
El
NR
NR
NR
0.02
541
M2
NR
NR
NR
NR
NR
NR
Shell Oil Co,
Deer Park
Refining LP
Deer Park,
TX
No DMR data;
TWPE is driving
force for 08-09
change in
discharge
0.1003
8,532
M2
0.1303
3,044
M2
0.14
13,306
M2
0.114
10,850
M
0.16
15,477
M
19-14
-------
Section 19—Petroleum Refining (40 CFR Part 419)
Table 19-15. Dioxin and Dioxin-Like Discharges From Petroleum Refineries Reported to TRI in 2004-2009
Facility Name
Locution
( ,'ommcnts
2009
2008
2007
2005
2004
Grams
Released
TWPK
liusis of
Kstimate
(Irams
Released
TWPK
Uasis of
Kstimate
Grams
Released
TWPK
Uasis of
Kstimatc
Grams
Released
TWPK
Basis of
Kstimate
Grams
Released
TWPK
Uasis of
Kstimate
Chevron
Products Co.,
Pascagoula
Refinery
Pascagoula,
MS
No DMR data;
grams is driving
force for 08-09
change in
discharge
0.07265
3,595
O
0.03709
4,592
O
NR
NR
NR
0.099
4,234
O
0.12
5,217
O
Tesoro
Refining &
Marketing Co
Anacortes,
WA
No DMR data;
grams is driving
force for 08-09
change in
discharge
0.41
2.905
M2
0.519
12,124
O
NR
NR
NR
1.94
55,248
M
1.95
54,406
M
Conoco
Phillips, San
Francisco
Refinery
Rodeo, CA
DMR TWPE is
zero; grams is
driving force for
08-09 change in
discharge
0.062320
5
2,276
C
0.16818
15,610
c
NR
NR
NR
NR
NR
NR
NR
NR
NR
BP Products
North America
Inc, Toledo
Refinery
Oregon, OF!
DMR TWPE is
zero; grams is
driving force for
08-09 change in
discharge
0.481
785
M2
0.264
6,167
o
0.29
41,963
O
0.331
47,084
O
0.34
47,795
M
Citgo
Petroleum Corp
Westlake, LA
No DMR data;
TWPE is driving
force for 08-09
change in
discharge
0.00128
126
El
0.00257
60
El
0.002
69
O
0.00256
210
E
0.0026
231
E
Conoco
Phillips, Santa
Maria Facility
Refinery
Arroyo
Grande, CA
No DMR data;
grams is driving
force for 08-09
change in
discharge
0.0675
26
M2
0.0133
311
M2
NR
NR
NR
NR
NR
NR
NR
NR
NR
BP Products
North
American
Whiting
Whiting, IN
No DMR data;
grams is driving
force for 08-09
change in
discharge
0.000015
8
O
0.000013
12
O
NR
NR
NR
NR
NR
NR
0.000011
1.8
O
Premcor
Refining
Group, Inc.
Delaware
City, DE
No DMR data;
new to report in
2009
0.000036
3
4
O
NR
NR
NR
0.0001
3.13
O
0.000097
2
O
0.022
559
O
19-15
-------
Section 19—Petroleum Refining (40 CFR Part 419)
Table 19-15. Dioxin and Dioxin-Like Discharges From Petroleum Refineries Reported to TRI in 2004-2009
Facility Name
Locution
( ,'ommcnts
2009
2008
2007
2005
2004
Grams
Released
TWPK
liusis of
Kstimate
Grains
Released
TWPK
Uasis of
Kstimate
Grams
Released
TWPK
Uasis of
Kstimate
Grams
Released
TWPK
Basis of
Kstimate
Grams
Released
TWPK
Uasis of
Kstimate
Suncor Energy
Commerce City
Refinery
Commerce
City, CO
No DMR data;
grams is driving
force for 08-09
change in
discharge
0.35
4
El
0.35
8,176
El
NR
NR
NR
0.111
9,104
M
0.037
3,333
M
Conoco
Phillips,
Ferndale
Refinery
Ferndale,
WA
No DMR data;
grams is driving
force for 08-09
change in
discharge
0.2251
3
M2
0.2284
25,883
M2
NR
NR
NR
NR
NR
NR
NR
NR
NR
Martin
Operating Ptnr
LP
Smackover,
AR
No DMR data;
grams is driving
force for 08-09
change in
discharge
0.0005
0.1
O
0.00005
1
O
NR
NR
NR
NR
NR
NR
NR
NR
NR
Sources: TRIReleases2009_v2; TRIReleases2008_v3; TRIReleases2007_v2; TRIReleases2005_v2; and TRIReleases2004_v3.
NR: Not reported.
For indirect discharges, the mass shown is the mass transferred to the POTW that is ultimately discharged to surface waters, accounting for an estimated
83% removal of dioxin and dioxin-like compounds by the POTW.
Refineries reported basis of estimate in TRI as: M (monitoring data/measurements); M2 (periodic monitoring data/measurements); C (mass balance
calculations); E (published emission factors); and O (other approaches, such as engineering calculations).
19-16
-------
Section 19—Petroleum Refining (40 CFR Part 419)
Table 19-16. PAC Discharges from Petroleum Refineries Reported to TRI in 2004-2009
l iicilitv \;imt
Locution
2009
2008
2007
2005
2004
Pounds
Released
TWPK
Uasis of
l.stimiitc
Pounds
Released
TWPK
Uasis of
l.stimiitc
Pounds
Released
TWPK
Uasis of
Kstimate
Pounds
Released
TWPK
Basis of
l.stimiitc
Pounds
Released
TWPK
Uasis of
l.stimiitc
Exxon Mobil Oil Corp Joliet
Refinery
Channahon, IL
358
9,099
M2
337
8,566
M2
NR
NR
NR
NR
NR
NR
NR
NR
NR
Chevron Products Co-Hawaii
Refinery
Kapolei, HI
264.1
6,713
M2
250
6,354
M2
260
6,608
M2
270
6,862.6
M
270
6,863
M
Flint Hills Resources LP-West
Plant
Corpus Christi,
TX
103.1
2,620
M2
4.8
122
M2
5.4
137
M2
10.6
269.4
M
16
412
M
Chevron Products Co.
Pascagoula Refinery
Pascagoula,
MS
85.9
2,183
O
88.8
2,257
O
NR
NR
NR
126.1
3,205.1
O
115
2,923
O
Conoco Phillips Co-Bayway
Refinery
Linden, NJ
75.3
1,914
O
13.8
351
O
5.6
142
O
NR
NR
NR
NR
NR
NR
BP Products North America
Inc., Toledo Refinery
Oregon, OH
68
1,728
M2
78
1,983
M2
NR
NR
NR
NR
NR
NR
NR
NR
NR
Marathon Petroleum Co. LLC,
Saint Paul Park Refinery
Saint Paul Park
MN
49
1,245
C
51
1,296
C
NR
NR
NR
95.7
2,431.1
M
24
616
M
PDV Midwest Refining LLC,
Lemont Refinery
Lemont, IL
37.91
964
M2
38.58
981
O
35.96
914
O
32.1
814.9
M
NR
NR
NR
ConocoPhillips Co-Alliance
Refinery
Belle Chasse,
LA
32.3329
822
M2
NR
NR
NR
43.3
1,103
O
43.8
1114.3
M
49
1,233
M
Marathon Petroleum Co, LLC
Texas City, TX
30.2
768
M2
31.4
798
M2
31.5
801
M2
34.6
879.4
M
29
742
M
Lake Charles Carbon Co.
Lake Charles,
LA
28.2
717
O
12.7
323
O
NR
NR
NR
7.2
183
M
NR
NR
NR
Chevron Products Co, Div of
Chevron USA Inc.
El Segundo,
CA
27
686
M2
34.2
869
M2
81.5
2,011
M2
137.4
3,492.3
M
113
2,882
M
Flint Hills Resources LP-East
Plant
Corpus Christi,
TX
26.2
666
M2
0.6
15
M2
NR
NR
NR
0.5
12.7
M
0.6
15
M
Motiva Enterprises, LLC
Port Arthur,
TX
25
635
O
22
559
O
NR
NR
NR
NR
NR
NR
NR
NR
NR
Marathon Ashland Petroleum
LLC, Illinois Refining Div
Robinson, IL
24
610
O
24.5
623
O
24.7
628
O
24
610
O
28
712
O
Lyondell-Citgo Refining LP
Houston, TX
20.71
526
M2
62.59
1,591
M2
13.57
345
M2
3
76.3
M
0
0
M
Valero Refining Co, Louisiana
Krotz Springs,
LA
20.5
521
M2
20.7
526
M2
22.4
569
M2
23
584.6
O
22
567
O
ConocoPhillips Co, Wood
River Refinery
Roxana, IL
13
330
O
10
254
O
9
229
O
11
279.6
O
11
280
O
19-17
-------
Section 19—Petroleum Refining (40 CFR Part 419)
Table 19-16. PAC Discharges from Petroleum Refineries Reported to TRI in 2004-2009
l iicilitv \;imt
Locution
2009
2008
2007
2005
2004
Pounds
Released
TWPK
Uasis of
l.stimiitc
Pounds
Released
TWPK
Uasis of
l.stimiitc
Pounds
Released
TWPK
Uasis of
Kstimate
Pounds
Released
TWPK
Basis of
l.stimiitc
Pounds
Released
TWPK
Uasis of
l.stimiitc
Wynne wood Refining Co.
Wynnewood,
OK
13
330
M2
12
305
M2
NR
NR
NR
NR
NR
NR
10
254
O
Valero Refining New Orleans
LLC
New Sarpy, LA
7.4138
188
O
7.767
197
O
7
178
O
9
228.8
O
9
229
O
ConocoPhillips Co., Lake
Charles Refinery
Westlake, LA
5.88
149
O
39.4
1,001
O
NR
NR
NR
41
1,042.1
O
43
1,093
o
Exxon Mobil Corp, Everett
Terminal
Everett, MA
5.2
132
o
5.5
140
o
NR
NR
NR
NR
NR
NR
NR
NR
NR
Premcor Refining Group Inc.
Delaware City,
DE
5
127
o
5
127
o
4
102
O
3.4
86.4
O
4
102
O
Tesoro Alaska-Kenai Refinery
Kenai, AK
5
127
o
5
127
o
5
127
O
19
482.9
O
18.9
480
o
Marathon Petroleum Corp
Garyville
Garyville, LA
5
127
M2
5
127
M2
5
127
c
5
127.1
c
5
127
c
ConocoPhillips San Francisco
Refinery
Rodeo, CA
4
102
M2
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Chevron Products Co,
Richmond Refinery
Richmond, CA
3.7
94
M2
18
458
M2
16
407
M2
19
482.9
M
19.3
491
M
ConocoPhillips Co, Santa
Maria Refinery
Arroyo Grande,
CA
3.7
94
E2
3
76
E2
3
76
E2
2
50.8
O
2
51
O
BP Products North America
Whiting
Whiting, IN
3.5
89
O
1.4
36
O
2.5
63.5
O
3.6
91.5
o
1
25
o
Premcor Hartford Distribution
Center
Hartford, IL
2.7
69
Ml
1.2
31
Ml
0.8
20.3
Ml
NR
NR
NR
NR
NR
NR
Exxon Mobil Refining &
Supply Baton Rouge Refinery
Baton Rouge,
LA
2
51
O
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Suncor Energy Commerce City
Refinery
Commerce
City, CO
2
51
O
2
51
O
NR
NR
NR
19
482.9
O
28
712
O
Tesoro Refining & Marketing
Co.
Anacortes, WA
1
25
o
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Koppers Inc. Monessen Coke
Plant
Monessen, PA
1
25
o
4.7
119
O
2.9
74
O
3.2
322
O
NR
NR
NR
Shell Oil Products US Puget
Sound Refinery
Anacortes, WA
1
25
El
0.9
23
El
1
25.4
El
1
25.4
O
1
25
O
Global Cos LLC, South
Portland Terminal
South Portland,
ME
0.874
22
M2
0.08
2
M2
NR
NR
NR
1.3
33.04
M
NR
NR
NR
19-18
-------
Section 19—Petroleum Refining (40 CFR Part 419)
Table 19-16. PAC Discharges from Petroleum Refineries Reported to TRI in 2004-2009
l iicilitv \;imt
Locution
2009
2008
2007
2005
2004
Pounds
Released
TWPK
Uasis of
l.stimiitc
Pounds
Released
TWPK
Uasis of
l.stimiitc
Pounds
Released
TWPK
Uasis of
Kstimate
Pounds
Released
TWPK
Basis of
l.stimiitc
Pounds
Released
TWPK
Uasis of
l.stimiitc
Tesoro Refining and Marketing
Co.
Martinez, CA
0.7
18
M2
0.8
20
M2
0.6
15.2
M2
0.6
15.3
M
0.5
12
M
Triram Connecticut, LLC
Portland, CT
0.59
15
O
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Chevron Products Co, Salt
Lake City Refinery
Salt Lake City,
UT
0.56
14
M2
0.53
13
M2
61
1,550
M2
60
1,525
M
59
1,500
M
National Co-op Refinery Assoc.
McPherson, KS
0.4
10
M2
1
25
M2
2.4
61
M2
NR
NR
NR
NR
NR
NR
Martin Product Sales, LLC
Beaumont, TX
0.26
7
M2
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Global South Terminal, LLC
Revere, MA
0.25
6
O
0.3
8
O
NR
NR
NR
NR
NR
NR
NR
NR
NR
Sprague Searsport Terminal
Searsport, ME
0.22336
6
C
0.643
16
C
NR
NR
NR
35.5
902
C
NR
NR
NR
Flint Hills Resources LP,
McFarland Terminal
McFarland, WI
0.21
5
o
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
ConocoPhillips Co. Trainer
Refinery
Trainer, PA
0.2
5
o
NR
NR
NR
0.3
7.62
O
0.1
3.6
O
0.2
5
O
Valero Refining, Texas LP,
Corpus Christi West Plant
Corpus Christi,
TX
0.15
4
o
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Sprague River Road Terminal
Newington, NH
0.10837
3
c
0.0944
2
C
NR
NR
NR
0.115
2.9
C
NR
NR
NR
Global Revco Terminal, LLC
Revere, MA
0.105
3
o
0.42
11
O
NR
NR
NR
NR
NR
NR
NR
NR
NR
Sprague, South Portland
South Portland,
ME
0.10361
3
c
0.13
3
c
NR
NR
NR
0.147
3.72
C
NR
NR
NR
Chevron Products Co.
Perth Amboy,
NJ
0.1
3
o
0.2
5
o
NR
NR
NR
0.6
15.3
O
0.9
23
O
Conoco Phillips Co. Pipeline,
Pasadena Terminal
Pasadena, TX
0.1
3
o
0.171
4
o
NR
NR
NR
NR
NR
NR
NR
NR
NR
BP West Coast Products LLC
Carson
Carson, CA
0.1
3
M2
NR
NR
NR
NR
NR
NR
0.1
2.5
M
NR
NR
NR
Sprague, Quincy
Quincy, MA
0.0885
2
E2
0.1457
4
E2
NR
NR
NR
1.575
40.02
O
NR
NR
NR
Exxon Mobil Oil Corp, Des
Plaines Terminal
Arlington
Fleights, IL
0.05
1
o
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Exxon Mobil Oil Corp, East
Providence Terminal
East
Providence, RI
0.04
1
o
1.5
38
O
NR
NR
NR
1.6
40.67
O
NR
NR
NR
Sprague, Providence
Providence, RI
0.01155
0
c
0.2804
7
C
NR
NR
NR
5.81
148
C
NR
NR
NR
Conoco Phillips Co, Gulf Coast
Lubes Plant
Sulphur, LA
0.01
0
o
0.0045
0
o
NR
NR
NR
0
0
o
NR
NR
NR
19-19
-------
Section 19—Petroleum Refining (40 CFR Part 419)
Table 19-16. PAC Discharges from Petroleum Refineries Reported to TRI in 2004-2009
l iicilitv \;imt
Locution
2009
2008
2007
2005
2004
Pounds
Rclcnscd
TWPK
Uilsis of
l.stimiitc
Pounds
Rclcnscd
TWPK
Unsis of
l.stimiitc
Pounds
Released
TWPK
Unsis of
Kstimntc
Pounds
Rclcnscd
TWPK
Basis of
l.stimiitc
Pounds
Rclcnscd
TWPK
Uilsis of
l.stimiitc
Premcor West Memphis
Terminal
West Memphis,
AR
0.0038
0
C
0.0039
0
C
0.0029
0.074
C
NR
NR
NR
NR
NR
NR
Metro Terminals Corp
Brooklyn, NY
0.003
0
O
0.003
0
O
NR
NR
NR
0.008
0.203
O
NR
NR
NR
Indirect
Marathon Petroleum Co LLC
Michigan Refining Div
Detroit, MI
100.7
188
M2
8.7584
223
M2
8.97
228
M2
94
175.8
M
98
184
M
Western Refining Co El Paso
Refinery
El Paso, TX
48
90
O
4.4896
114
O
0.44
11.2
O
54
101
O
51
95
O
Safety-Kleen Systems, Inc.
Buffalo Oil Recovery Factory
Buffalo, NY
3.68
7
M2
0.2944
7
M2
0.66
17
M2
1.2
2.24
M
NR
NR
NR
Sunoco, Inc (R&M)
Philadelphia Refinery
Philadelphia,
PA
3
6
M2
0.2208
6
M2
0.07
1.87
M2
NR
NR
NR
NR
NR
NR
Sources: TRIReleases2009_v2; TRIReleases2008_v3; TRIReleases2007_v2; TRIReleases2005_v2; and TRIReleases2004_v3.
NR: not reported.
Refineries reported basis of estimate in TRI as: M (monitoring data/measurements); Ml (constant monitory data/measurements); M2 (periodic monitoring
data/measurements); C (mass balance calculations);
E (published emission factors); El (published emission factors); E2 (site-specific emission factors); and O (other approaches, such as engineering
calculations).
19-20
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
20. Pulp, Paper, and Paperboard (40 CFR Part 430)
EPA identified the Pulp, Paper, and Paperboard (Pulp and Paper) Category (40 CFR Part
430) for preliminary review because it continues to rank high, in terms of toxic-weighted pound
equivalent (TWPE), in point source category rankings. EPA previously reviewed discharges
from pulp and paper facilities as part of the Preliminary and Final Effluent Guidelines Program
Plans in 2004-2010 (U.S. EPA, 2004, 2006a, 2007, 2008, 2009a, 2011). During its 2006 Final
Effluent Guidelines Program Plan reviews, EPA also conducted a detailed study of this industry
(U.S. EPA, 2006b). This section summarizes the results of the 2011 Annual Reviews associated
with the Pulp and Paper Category. The review focused on discharges of dioxin and dioxin-like
compounds and manganese and manganese-like compounds from the Toxics Release Inventory
(TRI), and sulfide and aluminum discharges from discharge monitoring reports (DMR), because
of their high TWPE relative to other pollutants in the Pulp and Paper Category.
20.1 Pulp and Paper Toxicity Rankings Analysis
Table 20-1 compares the toxicity rankings analysis results for the Pulp and Paper
Category from the 2007 through 2011 Annual Reviews. The combined TWPE from discharges in
the DMR and TRI databases increased from 2008 to 2009. The estimated 2009 TRI TWPE
accounts for approximately 77 percent of the combined 2009 category TWPE.
Table 20-1. Pulp and Paper Category TRI and DMR Discharges for 2007 Through 2011
Toxicity Rankings Analysis
Year of Discharge
Year of Review
Pulp and Paper Manufacturing Category
TRI TWPE'1
DMR TWPEb
Total
2004
2007
669,000
165,000
833,000
2007
2009
460,000°
2,730,000
3,190,000d
2008
2010
523,000
348,000
871,000
2009
2011
956,000
287,000
1,240,000
Sources: TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; TRIReleases2007_v2;
DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3; TRIReleases2009_v2; and
DMRLoads2009 v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2004 through 2007 include only major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
0 Includes discharges from facilities reporting NAICS code 326112. These discharges should be associated with
the Plastics Molding and Forming Category (40 CFR Part 463). EPA has corrected future versions of the
database to reflect this change.
d During the 2009 Annual Reviews, EPA contacted facilities to verify the concentrations of dioxin and dioxin-
like compounds in PCS and ICIS-NPDES and found that for all facilities contacted, there were either unit errors
(e.g., measurements reported in ng/L but in the database as mg/L) or missing non-detect indicators. After
corrections, the new 2009 category total TWPE was 712,000.
20.2 Pulp and Paper Category Pollutants of Concern
EPA's review of the Pulp and Paper Category focused on the 2009 TRI and DMR
discharges because both contribute to the category's combined TWPE. Table 20-2 lists the five
pollutants with the highest TWPE in TRIReleases2008 v3 and TRIReleases2009_v2. Table 20-3
lists the five pollutants with the highest TWPE in DMRLoads2007 v3 and DMRLoads2009 v2.
20-1
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
The top TRI pollutants, dioxin and dioxin-like compounds and manganese and manganese
compounds, contribute more than 83 percent of the total TRI TWPE. The top DMR pollutants,
sulfide and aluminum, contribute more than 73 percent of the total DMR TWPE.
Table 20-2. Pulp and Paper Category Top TRI Pollutants
2008a
2009a
Pollutant
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Dioxin and dioxin-like compounds
3
49
36,500
1
51
494,000
Manganese and manganese compounds
1
117
308,000
2
115
298,000
Lead and lead compounds
2
185
63,800
3
181
61,100
Mercury and mercury compounds
Pollutant not reported in the top
five 2008 TRI-reported pollutants.
4
87
16,300
Polycyclic aromatic compounds
5
34
19,300
5
27
15,900
Zinc and zinc compounds
4
90
21,200
Pollutant not reported in the top five
2009 TRI-reported pollutants.
Pulp and Paper Category Total
NA
250b
523,000
NA
250b
956,000
Sources: TRIReleases2008_v3 and TRIReleases2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
Table 20-3. Pulp and Paper Category Top DMR Pollutants
Pollutant
2008
2009
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Sulfide
2
2
116,000
1
3
147,000
Aluminum
3
26
68,800
2
32
63,100
2,3,7,8-tetrachlorodibenzo-p-dioxin
1
5
118,000
3
3
26,100
Chlorine
4
33
16,800
4
34
17,900
Mercury
Pollutant not reported in the top
five 2008 DMR-reported pollutants.
5
16
10,100
Iron
5
14
5,970
Pollutant not reported in the top five
2009 DMR-reported pollutants.
Pulp and Paper Category Total
NA
158a
348,000
NA
157a
287,000
Sources: DMRLoads2008_v3 and DMRLoads2009_v2.
a Number of facilities reporting TWPE greater than zero.
NA: Not applicable.
EPA's additional review for the Pulp and Paper Category focused on the 2009 TRI and
DMR database pollutants of concern, dioxin and dioxin-like compounds, manganese and
20-2
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
manganese compounds, sulfide, and aluminum, presented in the following subsections. EPA did
not investigate the other top pollutants as part of the 2011 Annual Reviews.
20.3 Pulp and Paper Category Dioxin and Dioxin-like Compound Discharges in TRI
Dioxin and dioxin-like compounds contribute 52 percent of the total 2009 TRI TWPE
and increased by nearly 14 times from reporting years 2008 and 2009. Table 20-4 summarizes
the number of facilities and total TWPE for discharge years 2004 through 2009. Table 20-16,
presented at the end of this section, lists the pulp and paper mills that reported dioxin and dioxin-
like compound discharges to TRI in 2009. Table 20-4 demonstrates the large increase in
estimated TWPE. Table 20-16 shows that the majority of this increase results from a single
facility.
Table 20-5 summarizes the 2009 basis of estimates reported by the 51 paper mills
discharging dioxin in 2009 by type of estimate. Of the 51 pulp and paper mills reporting dioxin
and dioxin-like compound discharges in 2009, only 15 reported discharges based on analytical
measurements, the majority never measured for dioxin and dioxin-like compounds.
To determine why dioxin and dioxin-like compound discharge estimates had significantly
increased from 2008 to 2009, EPA followed the revised methodology from the 2006 Pulp, Paper,
and Paperboard Detailed Study (U.S. EPA, 2006b). The revised methodology was used to
estimate the TWPE of reported releases of dioxin and dioxin-like compounds. EPA used the
actual distribution of wastewater effluent measurement data provided by individual mills. If such
data were not available, EPA used the dioxin congener distribution of the mill discharges used to
develop the National Council for Air and Stream Improvement (NCASI) SARA Handbook
emission factor.
Table 20-4. Summary of Dioxin and Dioxin-Like Compound Discharges, 2004-2009
Year of Discharge
21MW
2IHIS
2IHP
2005
2004
Number of facilities
51
49
42
56
64
Total TWPE
494,000
36,500
86,400
147,000
178,000
Sources: TRIReleases2004_v3; TRIReleases2005_v2; TRIReleases2007_v2; TRIReleases2008_v3; and
TRIReleases2009 v2.
20-3
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 20-5. Basis of Estimate Summary for 2009 Dioxin and
Dioxin-Like Compound Discharges
ISiisis of I.N(iin;ik'
Ml or \12
<
i:i oi-1:2
()
Number of facilities3
15
7
23
8
Source: TRIReleases2009 v2.
a There are a total of 51 pulp and paper mills that report dioxin discharges to the 2009 TRI database. The counts
above include basis of estimates for plants that have both indirect and direct discharges, which may account for
double counting of facilities.
Ml: Continuous monitoring data or measurements
M2: Periodic or random monitoring data or measurements
C: Mass balance calculations, such as calculation of the amount of the toxic chemical in streams entering and
leaving process equipment
El: Published emission factors
E2: Site-specific emission factors
O: Other approaches, such as engineering calculations
The following sections discuss the top dioxin and dioxin-like compound discharger,
Simpson Tacoma Kraft Co., LLC (Simpson Tacoma), in Tacoma, WA, and the remaining dioxin
and dioxin-like compound dischargers. Simpson Tacoma accounts for 46 percent of the
category's 2009 TRI dioxin and dioxin-like compound discharges and therefore is presented
separately.
20.3.1 Simpson Tacoma Kraft Co., LLC
Table 20-6 presents dioxin and dioxin-like compound discharges for Simpson Tacoma
from 2005 through 2009. As shown in Table 20-6, the TWPE increased by more than 228,000
from 2008 to 2009. As part of the 2011 Annual Reviews, EPA contacted the American Forest
and Paper Association (AF&PA) about the 2009 TRI dioxin discharges. AF&PA is the national
trade association of the forest, pulp, paper, paperboard, and wood products industry. AF&PA
stated that the congener distributions for reporting years 2005 through 2007 were based only on
sampling of two dioxin congeners (2,3,7,8-tetrachlorodibenzo-p-dioxin and 2,3,7,8-
tetrachlorodibenzofuran). In recent years, the facility has performed full congener testing, which
resulted in detections of other congeners (Schwartz, 2011). The full congener testing was fully
incorporated into the TRI database in 2009, which is demonstrated by the increase in TWPE.
Table 20-7 presents the facility-specific dioxin and dioxin-like congener distribution for 2008
and 2009.
Table 20-6. Dioxin and Dioxin-Like Compound Discharges in TRI
for Simpson Tacoma, 2005-2009
Dioxin C ompounds
200')
21 MIS
2007
200(»
2005
Pounds released
0.005
0.004
0.0002
0.0002
0.0003
TWPE
229,000
243
207
218
276
Sources: TRIReleases 2005 v02; TRIReleases 2006 vOl; TRIReleases 2007 v2; TRIReleases2008_v3; and
TRIReleases2009_v2, AF&PA Contact (Schwartz, 2011).
20-4
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 20-7. Facility-Specific Dioxin and Dioxin-Like Congener Distribution
200X
200')
Congener
Disl rihu lion
Disl ri hut ion
Nil in her
( hemienl Name
T\\ 1
r:--;.)
1
Tetrachlorodibenzo-p-dioxin, 2,3,7,8-
703,584,000
0
0
2
Pentachlorodibenzo-p-dioxin, 1,2,3,7,8-
692,928,000
0
0
3
Hexachlorodibenzo-p-dioxin, 1,2,3,4,7,8-
23,498,240
0
3.20
4
Hexachlorodibenzo-p-dioxin, 1,2,3,6,7,8-
9,556,480
0
5.31
5
Hexachlorodibenzo-p-dioxin, 1,2,3,7,8,9-
10,595,840
0
4.22
6
Heptachlorodibenzo-p-dioxin, 1,2,3,4,6,7,8-
411,136
14.7
20.22
7
Octachlorodibenzo-p-dioxin
6,586
85.3
40.23
8
Tetrachlorodibenzofuran, 2,3,7,8-
43,819,554
0
1.25
9
Pentachlorodibenzofuran, 1,2,3,7,8-
7,632,640
0
3.69
10
Pentachlorodibenzofuran, 2,3,4,7,8-
557,312,000
0
7.34
11
Hexachlorodibenzofuran, 1,2,3,4,7,8-
5,760,000
0
2.57
12
Hexachlorodibenzofuran, 1,2,3,6,7,8-
14,109,440
0
3.11
13
Hexachlorodibenzofuran, 1,2,3,7,8,9-
47,308,800
0
0
14
Hexachlorodibenzofuran, 2,3,4,6,7,8-
51,204,160
0
4.14
15
Heptachlorodibenzofuran, 1,2,3,4,6,7,8-
85,760
0
0
16
Heptachlorodibenzofuran, 1,2,3,4,7,8,9-
3,033,984
0
0
17
Octachlorodibenzofuran
2,021
0
4.73
Total TWF
66,100
46,200,000
Source: AF&PA contact (Schwartz, 2011).
20.3.2 Remaining Dioxin and Dioxin-Like Discharging Facilities
The next 19 facilities account for 52 percent of the dioxin and dioxin-like compound TRI
TWPE. As part of the 2011 Annual Reviews, EPA contacted AF&PA and NCASI about the
dioxin and dioxin-like discharges from 19 pulp and paper mills. NCASI is a nonprofit research
institute funded by North American forest products industry, including pulp and paper facilities.
Many of the companies that fund NCASI are also members of AF&PA. This information request
resulted in the findings presented in Table 20-8. Four facilities provided revisions to their dioxin
and dioxin-like compound discharges, which EPA will incorporate into future versions of the
TRIReleases2009_v2 database:
• Boise White Paper in Wallula, WA, documented revisions to its original TRI data.
The revisions has ceased to report a "quantity treated on-site" due to a previously
incorrect assumption, is using actual dioxin test results instead of published
emission factors for effluent and primary sludge, and has corrected a formula for
calculating the emissions from the recovery boilers that caused the value to be off
by a factor of 10. The facility also documented using half the detection limit for
BDL results. Since the BDL results were non-detect, a "<" should have been
incorporated into the database instead of using half the limit (Wiegand, 2011).
EPA incorporated these changes and estimates 2.30 grams and 156,000 TWPE of
dioxin and dioxin-like compounds discharged in 2009 for Boise White Paper.
• The Georgia-Pacific Naheola Mill in Pennington, AL, documented an error in its
original TRI data: the grams released to water and the grams released to land were
transposed (Wiegand, 2011). After correcting this error, EPA estimates 3.6 grams
20-5
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
and 10,800 TWPE of dioxin and dioxin-like compounds discharged in 2009 for
Georgia-Pacific.
• Clearwater Paper Corp. in Arkansas City, AR, documented an error in the
reported octachlorodibenzo-p-dioxin discharges—an incorrect conversion from
picograms to grams (Wiegand, 2011). After the correction, EPA estimates 1.83
grams and 3,240 TWPE of dioxin and dioxin-like compounds discharged in 2009
for Clearwater Paper Corp.
• Abitibowater Calhoun Operations in Calhoun, TN, documented that all dioxin
congeners were non-detect and missing the "<" in the database (Wiegand, 2011).
After the correction, EPA estimates zero pounds and zero TWPE of dioxin and
dioxin-like compounds discharged in 2009 for Abitibowater Calhoun Operations.
20-6
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 20-8. Information on Top Pulp and Paper Category 2009 TRI Dioxin and Dioxin-Like Compound Dischargers
Niimc
l.ociilioii
(.nuns ol
Dioxin
Dischiiriicd
T\\ IT.
Diilii \crific;i(ion
Dischiii'^o ( iilciiliilion
Mclhoriologt
ISk';ichinu Process
Description
Boise White
Paper, LLC
Wallula,
WA
Revised: 2.30
Original: 0.21
Revised: 156,000
Original: 13,800
Provided data showing
reporting errors; therefore
EPA revised database
Based on effluent sampling,
using half the detection limit
for BDL results
No change since the Pulp and
Paper Detailed Study
Kimberly-
Clark
Everett, WA
0.419
55,300
Confirmed data
Based on mass balances
using historical congener
data, using half the detection
limit for BDL results
No change since the Pulp and
Paper Detailed Study
S.D. Warren
Co.
Skowhegan,
ME
0.184
37,900
Confirmed data
Based on May 2002 final
effluent sampling data using
0 for BDL results, corrected
for the annual flow
No change since the Pulp and
Paper Detailed Study
Rayonier
Performance
Fibers
Fernandina
Beach, FL
5.20
37,800
Confirmed data
Based on quarterly
measurements, using 0 for
BDL results
No change since the Pulp and
Paper Detailed Study; uses
hypochlorite periodically as a
viscosity modifier in the
bleaching process
Clearwater
Paper Corp.
Lewiston,
ID
0.4
15,500
Confirmed data
Based on effluent sampling,
using half the detection limit
for BDL results
No change since the Pulp and
Paper Detailed Study
Georgia-
Pacific,
Naheola Mill
Pennington,
AL
Revised: 3.6
Original: 2
Revised: 10,800
Original: 8,490
Provided data showing
reporting errors; therefore
EPA revised database
Based onNCASI release
factors
No change since the Pulp and
Paper Detailed Study; portion
of post-converting tissue
broke receives hypochlorite
treatment
International
Paper
Franklin,
VA
2.14
10,400
Confirmed data
Based onNCASI release
factors, using 0 for BDL
results
Switched from ozone to
chlorine dioxide for
bleaching in 2006
Georgia-
Pacific
Crossett, AR
5.09
8,990
Confirmed data
Based onNCASI release
factors
No change since the Pulp and
Paper Detailed Study
20-7
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 20-8. Information on Top Pulp and Paper Category 2009 TRI Dioxin and Dioxin-Like Compound Dischargers
Niimc
I.ociilioii
(.nuns ol
Dioxin
Dischiiriicd
T\\ IT.
Diilii \crific;i(ion
Dischiii'^o ( iilciiliilion
Mclhoriologt
ISk';ichinu Process
Description
Nippon Paper
Industries
Port
Angeles,
WA
0.035
8,370
Confirmed data
Based on 2006 final effluent
sampling, using half the
detection limit for BDL
results
No change since the Pulp and
Paper Detailed Study
Evergreen
Packaging
Pine Bluff,
AR
3.21
5,690
Confirmed data
Based onNCASI release
factors, using 0 for BDL
results
No change since the Pulp and
Paper Detailed Study
Procter &
Gamble Paper
Products
Mehoopany,
PA
0.02
4,520
Confirmed data
Based on dioxin congener
tool calculations, using 0 for
BDL results
No change since the Pulp and
Paper Detailed Study
Boise White
Paper
Jackson, MS
2.28
4,030
Confirmed data
Based on effluent sampling
for TCDD and NCASI
release factors, using 0 for
BDL results
No change since the Pulp and
Paper Detailed Study
Rock-Tenn
Mill Co.
Demopolis,
AL
2.17
3,840
Confirmed data
Based on effluent sampling
for TCDD and NCASI
release factors, using 0 for
BDL results
No change since the Pulp and
Paper Detailed Study
International
Paper
Riegelwood,
NC
0.07
3,510
Confirmed data
Based on 2000 final effluent
sampling, using 0 for BDL
results
No change since the Pulp and
Paper Detailed Study
Clearwater
Paper Corp.
Arkansas
City, AR
Revised: 1.83
Original: 0.456
Revised: 3,240
Original: 3,220
Provided data showing
reporting errors; therefore
EPA revised database
Based on effluent sampling
for TCDD and TCDF and
NCASI release factors, using
0 for BDL results
No change since the Pulp and
Paper Detailed Study
Weyerhauser
Vanceboro,
NC
1.36
2,720
Confirmed data
Based on effluent sampling
for OCDD and NCASI
release factors, using 0 for
BDL results
No change since the Pulp and
Paper Detailed Study
Georgia-
Pacific Corp.
Palatka, FL
1.40
2,480
Confirmed data
Based onNCASI release
factors, using 0 for BDL
results
Replaced the brown stock
washers and installed an
oxygen delignification
system
20-8
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 20-8. Information on Top Pulp and Paper Category 2009 TRI Dioxin and Dioxin-Like Compound Dischargers
Niimc
l.ociiliun
(.nuns ol
Dioxin
Dischiiriicd
T\\ IT.
Diilii \crific;i(ion
Dischiii'^o ( iilciiliilion
Mclhoriologt
ISk';ichinu Process
Description
Domtar Paper
Co.
Plymouth,
NC
3.48
2,370
Confirmed data
Based on effluent sampling
for TCDD and TCDF and
NCASI release factors, using
0 for BDL results
No change since the Pulp and
Paper Detailed Study
Abitibowater
Calhoun
Operations
Calhoun, TN
Revised: 0
Original: 0.685
Revised: 0
Original: 24,900
Provided data showing all
congeners were BDL;
therefore EPA revised
database
Based on October 2000
sampling and annual flow,
using 0 for BDL results
No change since the Pulp and
Paper Detailed Study
Sources: NCASI contact (Wiegand, 2011); TRlReleases2009_v2.
20-9
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
As part of the 2006 Pulp and Paper Detailed Study, EPA determined that the vast
majority of data underlying the estimated releases of dioxin and dioxin-like compounds reported
to TRI (both NCASI data and facility-specific data) are based on pollutant concentrations below
the Method 1613B minimum levels. Therefore, the TRI-reported discharges of dioxin and
dioxin-like compounds for this category do not accurately reflect current industry discharges
(U.S. EPA, 2006b).
As part of the 2011 Annual Reviews, EPA collected data on bleach plant changes
because the bleaching process generates dioxin and dioxin-like compounds. Paper companies can
significantly reduce their dioxin generation by switching from elemental chlorination (using
chlorine gas) to using elemental-chlorine free bleaching by using chlorine dioxide. Table 20-8
lists bleach plant changes provided by NCASI. Of the facilities contacted, none changed their
bleaching processes in ways expected to significantly reduce dioxin generation, such as
switching to elemental chlorine free bleaching (e.g., chlorine dioxide). One plant changed from
ozone to chlorine dioxide; however, NCASI data show no significant change in dioxin
generation would result (NCASI, 2005). Based on these data, EPA concludes that there have not
been recent significant bleaching process changes in the pulp and paper industry.
As shown in Table 20-8, the pulp and paper industry continues to use NCASI release
factors or facility-specific sampling data to calculate dioxin and dioxin-like compound
discharges in the pulp and paper industry. EPA gathered some facility-specific data and was in
contact with AF&PA and NCASI to confirm the facility-specific data for all of the facilities
listed in Table 20-8. Upon completion of the 2011 Annual Reviews, EPA collected all data
necessary to determine if the conclusions reached in the 2006 Pulp and Paper Detailed Study are
still applicable from AF&PA, NCASI, and specific pulp mills (U.S. EPA, 2006b). EPA will
review the data and conclude its review of dioxin discharges in its 2012 Annual Reviews.
20.4 Pulp and Paper Category Manganese and Manganese Compound Discharges in TRI
Manganese and manganese compound discharges in the 2009 TRI database account for
31 percent of the total TRI TWPE. Each facility accounts for less than 5 percent of the TWPE;
no outliers exist in the TRI database.
As part of the Pulp and Paper Detailed Study, EPA determined the manganese and
manganese compounds are present in the intake water and may be contaminants in process
chemicals. Table 20-9 shows the manganese and manganese compound discharges in the TRI
and DMR databases from 2002 to 2009. EPA examined reported manganese and manganese
compound discharges from pulp and paper facilities during the Pulp and Paper Detailed Study
for the 2006 Plan and its previous preliminary studies. EPA obtained discharge data in Form 2C
of NPDES permit applications for 40 mills. EPA concluded that typical metal discharges from
pulp and paper mills were at concentrations too low to treat using end-of-pipe treatment
technologies for large plant flow rates (U.S. EPA, 2006b). Although EPA has not reviewed new
discharge concentration data, it has no new data to suggest that manganese concentrations are
above the treatable levels. As shown in Table 20-9, the TWPE is consistent from discharge year
2002 to 2009 and, therefore, EPA's previous conclusions from the detailed study are still
accurate: manganese and manganese compound discharges in the pulp and paper category are
below treatable levels.
20-10
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 20-9. 2002-2009 Manganese and Manganese Compound
Discharges in TRI and DMR
TRI Diilii
DMR Diilii
Number of
1 (Hill T\\ PI
Number of
1 (Hill l \\ PI
Discharge Year
Ue\ ic'w Year
Dischargers
Dischargers
2002
2006
112
304,000
4
287
2004
2007
117
316,000
5
5,190
2007
2009
79
231,000
5
3,210
2008
2010
117
308,000
3
3,040
2009
2011
115
298,000
3
2,960
Sources: TRIReleases2002; PCSLoads2002; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2007_v2;
DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3; TRIReleases2009_v2; and
DMRLoads2009_v2.
20.5 Pulp and Paper Category Sulfide Discharges in DMR
Table 20-10 presents the top sulfide dischargers in the 2009 DMR database. The majority
(92 percent) of the sulfide discharges were from one facility, Smurfit-Stone Container in
Florence, SC. EPA focused the sulfide discharges review on this facility.
Table 20-10. Pulp and Paper Category Top Sulfide Discharging Facilities
in the 2009 DMR Database
Facility Name
Facility Location
Pounds of Sulfide
Discharged
Sulfide TWPE
Percentage of
Pulp and Paper
Category 2009
DMR Sulfide
TWPE
Smurfit-Stone Container
Florence, SC
48,400
135,000
92%
Remaining facilities reporting sulfide discharges3
4,040
11,300
8%
Total
52,400
147,000
100%
Source: DMRLoads2009_v2.
" There are two remaining facilities that have sulfide discharges in the 2009 DMR database, which account for 8
percent of the category's sulfide DMR TWPE.
20.5.1 Sulfide Formation and Treatment Options
Sulfides are constituents of many industrial wastes such as those from tanneries, paper
mills, chemical plants, and gas works (U.S. EPA, 1986). Sulfides discharged to neutral receiving
waters can be reduced to hydrogen disulfide (H2S), an extremely toxic, odiferous, and corrosive
gas. Minute concentrations (2 micrograms per liter) of H2S impart an objectionable odor and
taste to water, making it unfit for municipal consumption (U.S. EPA, 1974).
2 2
Sulfide is an anion of sulfur in its lowest oxidation state of minus 2 (S "). The dianion S "
exists only in strongly alkaline aqueous solutions. Such solutions can form by dissolution of H2S
or alkali metals such as lithium sulfide, sodium sulfide, and potassium sulfide in the presence of
excess hydroxide ions. The ion S2 is exceptionally basic, with an acid dissociation constant
(pKa) greater than 14. Sulfide does not exist in appreciable concentrations even in highly alkaline
water. Instead, sulfide combines with protons to form HS , which is variously called H2S ion. At
20-11
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
still lower pH values (<7), HS converts to H2S, as shown by the equation below. At a pH of 5,
nearly 100 percent of sulfide is present as H2S.
H2S O HS" + H+ and HS" O S" + H+ (Eq. 20-1)
Sulfides are moderately strong reducing agents. They react with oxygen in the air in
elevated temperatures to form higher-valence sulfur salts, such as sulfates and sulfur dioxide.
Aqueous solutions of transition metals cations react with sulfides to precipitate solid metal
sulfide salts. The metal sulfide salts typically have very low solubility in water.
Table 20-11 presents available sulfide treatment options in the pulp and paper industry
(see Section 18.5 for more details). Although these treatment options can remove sulfide from
wastewater, the actual effluent concentrations attainable are a function of treatment system
design (Briggs, 2011).
Table 20-11. Sulfide Wastewater Treatment Options
Tcchnoloi^ Niiino
1 iviil:il)ilil>
CoiK'ciili'iilions
IK'scriplion
Biological treatment
Up to 99 percent
sulfide removal
Treats industrial effluent streams by either aerobic or anaerobic
processes. The treatment involves bacteria decomposing waste to
form harmless inorganic solids. Studies show that approximately 99
percent of the influent sulfide concentration can be biologically
oxidized to sulfate.
Aeration and air stripping
Up to 100
percent sulfide
removal
Aeration involves removal of dissolved gasses such as H2S from
water, and is generally used in two types of water applications: air
stripping and aeration. The effectiveness of aeration for removing
sulfide depends on the aeration method selected, the pH of the
water, design factors, flow and loading rate, available area of mass
transfer, temperature, and algae production. The major drawback to
aeration is that H2S is not destroyed but converted to an air
emission.
Hydrogen peroxide
oxidation
Up to 100
percent sulfide
removal
This process controls sulfide by oxidation to either elemental sulfur
or sulfate ion by hydrogen peroxide (H202) addition, depending on
the pH of the wastewater. It can approach 100% efficiency if H202
is added in a controlled fashion and the reaction medium is
thoroughly mixed. No additional wastewater processing is required
following peroxide oxidation because sulfate is very soluble in
water.
Sources: ERG sulfide treatment technologies memo (Briggs, 2011); "Biological Treatment of Tannery Wastewater"
article (Durai and Rajasimman, 2010).
20.5.2 Smurfit-Stone Container
Sulfide discharges from Smurfit-Stone, in Florence, SC, account for approximately 47
percent of the DMR TWPE for the Pulp and Paper Category. All of Smurfit-Stone's sulfide
discharges are from outfall 001. Table 20-12 presents the sulfide discharge concentrations in the
DMR Loadings Tool. The facility's permit includes monitoring and reporting requirements for
sulfide, but there are no sulfide numeric limits in the permit (O'Shaughnessy, 2011). The Pulp
and Paper Category effluent limitations guideline does not regulate sulfide.
20-12
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
As part of the 2011 Annual Reviews, EPA contacted AF&PA about Smurfit-Stone's
sulfide discharges. The contact stated that the facility's kraft pulping process uses sodium-based
alkaline pulping solution (liquor). This solution consists of sodium sulfide and sodium hydroxide
in 10 percent solution. This is the primary source of sulfides in the wastewater. The wastewater
is treated in the mill's wastewater treatment ponds before being discharged, but the facility does
not have any specific treatment technologies in place for sulfide treatment (O'Shaughnessy,
2011).
Although the 2009 sulfide concentrations are not regulated by the facility's permit, the
concentrations are below or near treatable levels (Briggs, 2011). EPA concludes that sulfide
discharges do not represent a hazard priority at this time.
Table 20-12. Smurfit-Stone Container's Outfall 001 2009 Monthly Sulfide Discharge Data
Monitoring Period Date
DMR Loadings Tool Sulfide
Concentrations (mg/L)
Average Flow (MGD)
31-Jan-09
<1
14.9
28-Feb-09
4
16.8
31-Mar-09
<1
8.3
30-Apr-09
1.1
14.1
31-May-09
0.79
20.8
30-Jun-09
1.2
13.2
31-Jul-09
1.9
17.5
31-Aug-09
1.34
11.1
30-Sep-09
<0.38
12.6
31-Oct-09
0.72
14
30-Nov-09
0.51
11.6
31-Dec-09
<0.38
8.6
Source: DMR Loadings Tool.
20.6 Pulp and Paper Category Aluminum Discharges in DMR
Aluminum discharges from pulp and paper mills in the 2009 DMR database account for
22 percent of the total DMR TWPE. Table 20-13 presents the category's aluminum dischargers
in the 2009 database. The following sections discuss the top aluminum discharger, International
Paper-Texarkana, in Texarkana, TX, (International Paper), and the remaining aluminum
discharges in DMRLoads2009_v2. International Paper accounts for 57 percent of the category's
2009 DMR aluminum discharges and therefore is discussed separately.
Table 20-13. Pulp and Paper Category Aluminum Dischargers in the 2009 DMR Database
Facility Name
Location
Aluminum Pounds
Discharged
Aluminum TWPE
Facility Percent
of Aluminum
Category TWPE
International Paper-Texarkana
Texarkana, TX
600,000
36,000
57%
Remaining facilities reporting aluminum discharges3
452,000
27,130
43%
Total
1,050,000
63,100
100%
Source: DMRLoads2009_v2.
a There are 31 remaining facilities that have aluminum discharges in the 2009 TRI database, which account for 43
percent of the category's aluminum DMR TWPE.
20-13
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
20.6.1 International Paper
EPA investigated the load estimation for International Paper to eliminate any errors. All
of International Paper's aluminum discharges are reported at outfall 001. Table 20-14 presents
the 2009 outfall 001 aluminum concentrations and average flows from the DMR Loadings Tool.
The DMR Loadings Tool estimates discharges using available concentration and flow data for
each month. For months of missing data, the DMR Loading Tool estimates the load based on
other months' data. Facilities can differentiate months of zero discharge with a "no discharge,"
or NODI, code. When facilities do not report discharges, the Loading Tool first determines if no
discharge, or NODI, was reported. When a NODI code is omitted, the DMR Loading Tool
estimates the discharge for the missing month(s). See Section 3 of the EPA's 2009 SLA report
for more information on NODI codes (U.S. EPA, 2009b). Table 20-14 shows that the facility did
not report data or NODI codes for April through December 2009, causing the DMR Loadings
tool to overestimate the discharge. After the correction, the facility's aluminum TWPE decreases
from 36,000 to 9,000.
Table 20-14. International Paper's Outfall 001 2009 Monthly Aluminum Discharge Data
.Monitoring Period Date
DMR Loadings Tool Aluminum
Concentrations (mg/L)
Average Flow (MGD)
31-Jan-09
NODIC
NODIC
28-Feb-09
NODIC
NODIC
31-Mar-09
3.57
162.5
30-Apr-09
NR
NODIC
31-May-09
NR
NODIC
30-Jun-09
NR
NODIC
31-Jul-09
NR
NODIC
31-Aug-09
NR
NODIC
30-Sep-09
NR
NODIC
31-Oct-09
NR
NODIC
30-Nov-09
NR
NODIC
31-Dec-09
NR
NODIC
Source: DMR Loadings Tool.
NR: Not reported.
NODI C: The facility did not report a concentration or flow because no discharge occurred for the monitoring
period.
20.6.2 Remaining Aluminum Dischargers
The remaining 31 pulp and paper facilities account for 43 percent of the 2009 aluminum
DMR TWPE for the Pulp and Paper Category. Table 20-15 presents the median aluminum
concentration from the 2002 and 2009 DMR data for pulp and paper mills. The 2006 Pulp and
Paper Category Detailed Study used the 2002 data (U.S. EPA, 2006b).
As part of the Pulp and Paper Detailed Study, EPA determined that aluminum
compounds are present in the intake water and may be contaminants in process chemicals. EPA
also determined that aluminum concentrations are below treatable levels for end-of-pipe
treatment technologies suitable for large effluent flows (U.S. EPA, 2006b). As shown in Table
20-15, the aluminum median effluent concentration has decreased since 2002. Therefore, EPA's
20-14
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
previous conclusions from the detailed study are still accurate: aluminum discharges in pulp and
paper effluent are below treatable levels.
Table 20-15. Median Concentration of Aluminum in Pulp and
Paper Mill Effluent (jig/L)
Method Minimum l.c\cl (uii/l.)
PC S 2002 Mcdiiin (Mill ( ouni)
(iiii/l.l
DMR 200') Modiiin (Mill ( ouni)
(iili/l.l
50
1,147 (8)
290 (31)
Sources: PCSLoads2002 and DMRLoads2009 v2.
20.7 Pulp and Paper Category Conclusions
The estimated toxicity of the Pulp and Paper Category discharges results mainly from
TRI-reported discharges of dioxin and dioxin-like compounds and manganese and manganese
compounds and DMR-reported discharges of sulfide and aluminum. Using data collected for the
2011 Annual Reviews, EPA concludes the following:
• Dioxin and dioxin-like compounds contribute 52 percent of the total 2009 TRI
TWPE and increased by more than 14 times from reporting years 2008 to 2009.
One facility, Simpson Tacoma, accounts for 46 percent of the dioxin and dioxin-
like discharges. A change in congener testing caused the increase in TWPE for
this facility. The majority of the remaining facilities with dioxin and dioxin-like
compounds discharges base their calculations on NCASI release factors or
facility-specific sampling data. In EPA's 2006 Pulp and Paper Detailed Study,
data showed that the estimated releases of dioxin and dioxin-like compounds
reported to TRI are based on pollutant concentrations below the Method 1613B
minimum levels. Concentrations below the minimum level may not be accurate,
and the measurements may not accurately reflect industry discharges. EPA
collected data from AF&PA, NCASI, and specific pulp mills (U.S. EPA, 2006b).
EPA will review the data and conclude its review of dioxin discharges in its 2012
Annual Reviews.
• Each facility discharging manganese and manganese compounds accounts for less
than 5 percent of the manganese and manganese compound discharges to TRI; no
outliers exist in the TRI database. EPA's 2006 Pulp and Paper Detailed Study
concluded that metals concentrations in pulp and paper mill discharges were
below treatable levels. The 2009 TRI data are consistent with the 2006 data;
therefore EPA concludes that concentrations in pulp and paper wastewater are
below treatable levels.
• Sulfide discharges contribute 52 percent of the total DMR TWPE. One facility,
Smurfit-Stone in Florence, SC, accounts for 92 percent of the sulfide DMR
TWPE. The sulfide concentrations for Smurfit-Stone are below or near treatable
levels and therefore do not represent a hazard priority at this time.
• Aluminum discharges contribute 22 percent of the total DMR TWPE. One
facility, International Paper in Texarkana, TX, accounts for 57 percent of the
aluminum DMR TWPE. After correcting an error, the TWPE for this facility
20-15
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
decreases from 36,000 to 9,000. The total 2009 TWPE for the Pulp and Paper
Category decreases from 1,240,000 to 1,213,000. The remaining facilities account
for 43 percent of the aluminum DMR TWPE. EPA found that aluminum is not a
pollutant of concern because it is detected at concentrations below treatable levels
with end-of-pipe treatment technologies suitable for large effluent flows.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(5)" in the "Findings" column in Table 8-1 in the
Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA,
2013).
20.8 Pulp and Paper Category References
1. Briggs, Mark. 2011. Sulfide Treatment Technologies Memorandum. Eastern Research
Group. (July 15). EPA-HQ-OW-2010-0824 DCN 07616.
2. Durai, G., and M. Rajasimman. 2011. Biological Treatment of Tannery Wastewater—A
Review. Journal of Environmental Science and Technology. Volume 4 (1): 1-17. (January
17). EPA-HQ-OW-2010-0824 DCN 07506.
3. NCASI. 2005. Handbook of Chemical - Specific Information for SARA Section 303
Form R Reporting. EPA-HQ-OW-2004-0032-0500.
4. O'Shaughnessy, Niall. 2011. Email Correspondence Between Niall O'Shaughnessy,
Smurfit-Stone, and Elizabeth Sabol, Eastern Research Group, Inc., Re: Request for 2009
DMR Data Clarification. (June). EPA-HQ-OW-2010-0824 DCN 07645.
5. Schwartz, Jerry. 2011. Email Correspondence Between Jerry Schwarz, American Forest
and Paper Association, and Elizabeth Sabol, Eastern Research Group, Inc., Re:
Clarification of Dioxin Data. (February). EPA-HQ-OW-2010-0824 DCN 07646.
6. U.S. EPA. 1974. Development Document for Effluent Guidelines and New Source
Standards for the Textile Mills Point Source Category. Washington, D.C. (June). EPA-
440-l-79-022b.
7. U.S. EPA. 1986. Quality Criteria for Water 1986. Washington, D.C. (May). EPA-440-5-
86-0010.
8. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
9. U.S. EPA. 2006a. Technical Support Document for the 2006 Effluent Guidelines
Program Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-
0032-2782.
20-16
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
10. U.S. EPA. 2006b. Final Report: Pulp, Paper, and Paperboard Detailed Study.
Washington, D.C. (December). EPA-821-R-06-016. EPA-HQ-OW-2004-0032-2249.
11. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
12. U. S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-08-015. EPA-HQ-OW-2006-0771-1701.
13. U.S. EPA. 2009a. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-0517-0515
14. U.S. EPA. 2009b. Technical Support Document for the Annual Review of Existing
Effluent Guidelines and Identification of Potential New Point Source Categories. EPA-
821-R-09-007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515
15. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA 820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
16. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
17. Wiegand, Paul. 2011. Email Correspondence Between Paul Wiegand, National Council
for Air and Stream Improvement, and Elizabeth Sabol, Eastern Research Group, Inc., Re:
Pulp and Paper TRI Questions. (August). EPA-HQ-OW-2010-0824 DCN 07647.
20-17
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 20-16. Dioxin and Dioxin-Like Discharges From Pulp and Paper Category Reported to TRI in 2004-2009
TRI II)
l iicility N;imt
Locution
2009
2008
2007
2005
2004
Grains
Rclcnscd
TWTK
Uilsis of
Kstiinntc
Gi'ii ins
Rcleiiscd
TWTK
Unsis of
Kstiinntc
Grains
Rclcnscd
TWTK
Unsis of
Kstiinntc
Grains
Rclcnscd
TWl'K
Unsis of
Kstiinntc
Grains
Rcleiiscd
TWTK
linsis of
Kstiinntc
98421-
SMPSN-
80 IPO
Simpson Tacoma
Kraft Co.
Tacoma, WA
2.243
228,696
M2
NR
NR
NR
0.12
208
El
0.154
277
E
0.135
242
E
98201-
SCTTP-
2600F
Kimberly-Clark
Worldwide
Everett, WV
0.419
55,269
C
0.487
874
C
NR
NR
NR
1.33
2,380
C
2.7
4,846
C
04976-
SDWRR-
RFD3U
S.D. Warren Co.
Skowhegan,
ME
0.184
37,877
E2
0.187
335
E2
0.15
269
E2
0.168
302
O
0.17
305
O
32034-
TTRYN-
FOOTO
Rayonier
Performance
Fibers, LLC
Fernandina
Beach, FL
5.197
37,842
Ml
0.66
1,184
Ml
NR
NR
NR
0.56
1,000
M
1
1,794
M
37309-
BWTRS-
ROUTE
Abitibowater
Calhoun
Operations
Calhoun, TN
0.6854
24,888
El
0.6875
1,234
El
0.73
1,319
El
0.87
1,560
M
0.94
1,690
M
83501-
PTLTC-
805MI
Clearwater Paper
Corp, Idaho Pulp
& Paperboard
Lewiston, ID
0.4
15,465
M2
0.4
718
M2
0.44
789
M2
0.441
792
E
4.18
7,501
E
99363-
BSCSC-
POBOX
Boise White Paper
LLC
Wallula, WA
0.20886
13,745
O
0.205513
369
O
5.58
10,014
O
0.083
149
O
0.83
1,496
O
23851-
NNCMP-
HIGHW
International
Paper-Franklin
Mill
Franklin, VA
2.1364
10,440
El
1.3677
2,454
El
NR
NR
NR
NR
NR
NR
2.28
4,086
E
71635-
GRGPC-
PAPER
Georgia-Pacific
Crossett Ops.
Crossett, AR
5.0851
8,993
El
5.327
77
El
5.6
10,043
El
4.87
8,740
E
5.49
9,850
E
36916-
JMSRV-
ROUTE
Georgia-Pacific
Consumer
Products LP
Pennington,
AL
2
8,488
El
3.44
50
El
3.2
5,742
El
3.6
6,460
M
3.3
5,921
M
98362-
DSHWM-
MARIN
Nippon Paper
Industries USA
Co. Ltd.
Port Angeles,
WA
0.034969
8,367
M2
0.03689
66
M2
NR
NR
NR
0.92
1,650
M
1.82
3,266
M
71611-
NTRNT-
FAIRF
Evergreen
Packaging
Pine Bluff,
AR
3.2139
5,684
O
3.3431
49
O
3.4
6,101
O
3.7
6,640
O
3.6
6,459
O
18629-
PRCTR-
ROUTE
Procter & Gamble
Paper Products Co
Mehoopany,
PA
0.020003
4,517
El
0.018
32
El
0.02
29
El
0.087
156
E
0.012
22
C
20-18
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 20-16. Dioxin and Dioxin-Like Discharges From Pulp and Paper Category Reported to TRI in 2004-2009
TRI II)
lncilitv N;imt
Locution
2009
2008
2007
2005
2004
Grains
Rcleiiscd
TWTK
Uilsis of
l.stimiitc
Gi'ii ins
Rcleiiscd
TWTK
linsis of
l.stimiitc
Grains
Rcleiiscd
TWTK
Uilsis of
l.stimiitc
Grains
Rcleiiscd
TWl'K
Uilsis of
l.stimiitc
Grains
Rcleiiscd
TWTK
Uiisis of
l.stimiitc
36545-
BSCSC-
307WE
Boise White Paper
LLC
Jackson, AL
2.2812
4,032
El
2.3119
34
El
2.21
3,965
El
2.1
3,770
E
2.1
3,768
E
36732-
GLFST-
HIGHW
Rock-Tenn Mill
Co LLC
Demopolis,
AL
2.1694
3,838
El
1.9993
29
El
1.84
3,301
El
0.292
524
E
0.32
575
E
28456-
FDRLP-
RIEGE
International
Paper Riegelwood
Mill
Riegelwood,
NC
0.0663
3,507
El
0.0304881
55
El
0.0304
54
El
0.0304
55
E
0.0305
55
E
71654-
PTLTC-
HIGHW
Clearwater Paper
Corp, Arkansas
City
Arkansas
City, AR
0.456
3,222
O
0.984
1,766
O
NR
NR
NR
0.204
365
O
0.97
1,737
O
28560-
WYRHS-
STREE
Weyerhaeuser
Vanceboro,
NC
1.35604
2,715
El
1.657323
24
El
1.71
3,069
El
1.7
3,050
E
1.74
3,119
E
32078-
GRGPC-
STATE
Georgia - Pacific
Corp, Palatka
Palatka, FL
1.4041
2,483
El
1.4
20
El
NR
NR
NR
NR
NR
NR
NR
NR
NR
27962-
WYRHS-
TROWB
Domtar Paper Co
Plymouth Mill
Plymouth,
NC
3.4794
2,373
El
4.2028
7,541
El
4.33
7,777
El
0.989
1,770
E
0.91
1,638
E
75504-
NTRNT-
POBOX
International
Paper Texarkana
Mill
Queen City,
TX
1.552
1,752
M2
1.302
19
M2
2.68
4,809
M2
0.68
1,220
M
3.87
6,944
M
32533-
CHMPN-
375MU
International
Paper Pensacola
Mill
Cantonment,
FL
2.309
1,568
El
0.88
1,579
El
NR
NR
NR
0.8
1,440
E
0.93
1,669
E
37662-
MDPPR-
POBOX
Weyerhaeuser Co
Kingsport Paper
Mill
Kingsport,
TN
0.83272
1,473
El
0.8617
1,546
O
NR
NR
NR
3.45
6,190
M
3.4
6,101
M
32347-
BCKYC-
ROUTE
Buckeye Florida
Lp
Perry, FL
0.123152
1,141
M2
1.221887
18
M2
NR
NR
NR
1.32
2,380
M
1.3
2,330
M
63702-
PRCTR-
POBOX
Procter & Gamble
Paper Products Co
Jackson, MO
0.005099
802
O
0.0051
0
O
0.004
8.8
O
0.0042
8
O
0.0051
9.2
O
20-19
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 20-16. Dioxin and Dioxin-Like Discharges From Pulp and Paper Category Reported to TRI in 2004-2009
TRI II)
lncilitv N;i mt
Locution
2009
2008
2007
2005
2004
Grains
Rcleiiscd
TWTK
Uilsis of
l.stimiitc
Gi'ii ins
Rcleiiscd
TWTK
Unsis of
l.stimiitc
Grains
Rcleiiscd
TWTK
Uilsis of
l.stimiitc
Grains
Rcleiiscd
TWl'K
Uilsis of
l.stimiitc
Grains
Rcleiiscd
TWTK
Unsis of
l.stimiitc
31521-
BRNSW-
14W9T
Brunswick
Cellulose Inc
Brunswick,
GA
0.2271
309
El
0.218
391
El
0.19
341
El
0.186
335
E
0.19
335
E
29442-
NTRNT-
KAMIN
International
Paper Georgetown
Mill
Georgetown,
SC
0.6383
214
C
0.683
1,225
C
NR
NR
NR
0.753
1,350
C
0.75
1,351
C
31545-
TTRYN-
SAVAN
Rayonier
Performance
Fibers, Jesup Mill
Jesup, GA
0.00023
191
O
0.0003
1
O
NR
NR
NR
NR
NR
NR
NR
NR
NR
70634-
BSSTH-
USHIG
Boise Packaging
& Newsprint LLC
Deridder, LA
0.0893
156
El
0.1455
261
El
0.12
215
El
0.19
341
E
0.22
395
E
3676W-
NTRNT-
76HIG
International
Paper, Pine Hill
Mill
Pine Hill, AL
3.0065
116
El
3.02814
44
E2
NR
NR
NR
NR
NR
NR
NR
NR
NR
49829-
MDPBL-
COUNT
Escanaba Paper
Co.
Escanaba, MI
0.890943
85
M2
5.612
81
M2
NR
NR
NR
NR
NR
NR
NR
NR
NR
54308-
THPRC-
501EA
Procter & Gamble
Paper Products Co
Green Bay,
WI
0.000300
83
C
0.0006
0
C
0.0008
1
C
0.0003
1
C
0.0005
0.9
C
17362-
PHGLT-
228SO
P. H. Glatfelter
Co Spring Grove
Mill
Spring
Grove, PA
1.0633
70
El
1.105
1,983
El
1.02
1,830
El
0.946
1,700
E
0.9
1.616
E
12883-
NTRNT-
SHORE
International
Paper
Ticonderoga,
NY
0.4166
62
M2
0.4223
758
M2
0.44
790
M2
0.46
826
E
0.46
834
E
36426-
CNTNR-
HIGHW
Smurfit-Stone
Container
Enterprises Inc
Brewton, AL
3.0053
44
M2
3.0053
44
M2
NR
NR
NR
NR
NR
NR
2.5
4,486
E
18653-
PPTLB-
MAINS
Cascades Tissue
Group PA Inc,
Ransom Mill
Ransom, PA
0.0179
32
C
0.0153
27
C
0.0179
32
C
NR
NR
NR
NR
NR
NR
29704-
BWTRC-
5300C
Bowater Coated &
Specialty Papers
Div
Catawba, SC
2.161
31
M2
1.9695
29
C
NR
NR
NR
NR
NR
NR
NR
NR
NR
31407-
STNCN-
1BONN
Weyerhaeuser
Port Wentworth
Port
Wentworth,
GA
1.273
18
El
1.3648
2,449
El
0.61
1,094
El
0.679
1,220
E
0.69
1,239
E
20-20
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 20-16. Dioxin and Dioxin-Like Discharges From Pulp and Paper Category Reported to TRI in 2004-2009
TRI II)
l iicility N;imt
Locution
2009
2008
2007
2005
2004
Grains
Rcleiiscd
TWTK
Uilsis of
Kstiinntc
Gi'ii ins
Rcleiiscd
TWTK
Uasis of
Kstiinntc
Grains
Rcleiiscd
TWTK
liiisis of
Kstiinntc
Grains
Rcleiiscd
TWl'K
liiisis of
Kstiinntc
Grains
Rcleiiscd
TWTK
linsis of
Kstimiitc
29044-
NNCMP-
ROUTE
International
Paper
Eastover, SC
0.119
2
M2
0.1077
193
M2
NR
NR
NR
0.183
328
O
0.16
282
O
54474-
WYRHS-
200GR
Weyerhaeuser
Rothschild,
WI
0.063972
1
M2
0.0633
114
M2
NR
NR
NR
0.042
75
M
0.048
86
M
98607-
JMSRV-
NE4TH
Fort James Camas
LLC
Camas, WA
0.0025
0.2311
El
0.0034
6
M2
NR
NR
NR
NR
NR
NR
NR
NR
NR
70791-
GRGPC-
ZACHA
Georgia-Pacific
Consumer
Products LLC
Zachary, LA
0.00163
0.0237
M2
10
2,337
El
2.77
4,974
El
2.77
4,970
E
2.77
4,974
E
31068-
BCKYC-
OLDST
Weyerhaeuser Co
Oglethorpe,
GA
0.0011
0.0160
O
0.001
2
O
0.001
1.79
O
0.001
2
O
0.0005
0.9
O
Indirect
07407-
MRCLP-
1MARK
Marcal Paper
Mills Inc.
Elm wood
Park, NJ
0.379098
1,273
M2
0.1699
2.468
M2
0.16
1,315
M2
0.02499
45
M
0.00799
14
M
29681-
WRGRC-
803NO
Sealed Air Corp,
Cryovac Div.
Simpsonville,
SC
0.011185
989
O
NR
NR
NR
0.0187
1,654
O
NR
NR
NR
NR
NR
NR
32401-
STNCN-
1EVER
Smurfit-Stone
Container Corp
Panama City,
FL
0.074799
256
El
NR
NR
NR
0.082
146
El
0.0782
140
E
0.078
140
E
54308-
THPRC-
501EA
Procter & Gamble
Paper Products Co
Green Bay,
WI
0.000850
234
C
NR
NR
NR
0.00081
0.997
C
0.00034
1
C
0.00051
0.9
C
31702-
THPRC-
USROU
Procter & Gamble
Paper Pro Ducts
Co
Albany, GA
0.000663
111
O
NR
NR
NR
0.001
109
O
0.001989
4
O
0.0036
6.4
O
55744-
BLNDN-
115SW
Upm Blandin
Paper Co
Grand
Rapids, MN
2.19
59.33
E2
2.379
175.7
E2
2.11
3,782
El
2.261
4,060
M
2
3,599
M
93030-
PRCTR-
800NO
Procter & Gamble
Paper Products Co
Oxnard, CA
0.000134
20.27
C
NR
NR
NR
0.00016
0.45
C
0.000021
4
0
C
0.0034
6.1
C
23860-
STNHP-
910IN
Smurfit-Stone
Container Corp
Hopewell,
VA
0.000045
1.239
C
NR
NR
NR
0.221
397
C
0.21
378
O
NR
NR
NR
20-21
-------
Section 20—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 20-16. Dioxin and Dioxin-Like Discharges From Pulp and Paper Category Reported to TRI in 2004-2009
TRI II)
lncilitv N;imt
Locution
2009
2008
2007
2005
2004
Grains
Rcleiiscd
TWTK
Uilsis of
l.stimiitc
Gi'ii ins
Rcleiiscd
TWTK
Unsis of
l.stimiitc
Grains
Rcleiiscd
TWTK
Uilsis of
l.stimiitc
Grains
Rcleiiscd
TWl'K
Uilsis of
l.stimiitc
Grains
Rcleiiscd
TWTI.
Unsis of
l.stimiitc
55720-
PTLTC-
NORTH
Sappi Cloquet
LLC
Cloquet, MN
0.04131
0.5998
M2
NR
NR
NR
0.04
78
M2
0.04811
86
E
0.044
78
E
63702-
PRCTR-
POBOX
Proctor & Gamble
Paper Products Co
Jackson, MO
0.000000
238
0.027
El
NR
NR
NR
0.00392
9
O
NR
NR
NR
NR
NR
NR
Sources: TRIReleases2009_v2; TRIReleases2008_v3; TRIReleases2007_v2; TRIReleases2005_v2; and TRIReleases2004_v3.
NR: Not reported.
For indirect discharges, the mass shown is the mass transferred to the POTW that is ultimately discharged to surface waters, accounting for an estimated 83
percent removal of dioxin and dioxin-like compounds by the POTW.
The TWPEs in this table were calculated using the 2006 TWFs (the 2006 dioxin and dioxin-like compound TWFs did not change from the August or
December 2004 TWFs).
Refineries reported basis of estimate in TRI as: M (monitoring data/measurements), M2 (periodic monitoring data/measurements), C (mass balance
calculations), E (published emission factors), and O (other approaches, such as engineering calculation).
20-22
-------
Section 21—Timber Products Processing (40 CFR Part 429)
21. Timber Products Processing (40 CFR Part 429)
EPA selected the Timber Products Processing (Timber Products) Category for
preliminary review because it ranks high, in terms of toxic-weighted pound equivalents (TWPE),
in the point source category rankings. EPA reviewed discharges from the Timber Products
Category as part of the 2004 Annual Reviews (U.S. EPA, 2004). This section summarizes the
results of the 2011 Annual Reviews associated with the Timber Products Category. EPA focused
on discharges of copper from discharge monitoring reports (DMR) and dioxin and dioxin-like
compounds from the Toxics Release Inventory (TRI) because of their high TWPE relative to the
other pollutants in the Timber Products Category.
21.1 Timber Products Category 2011 Toxicity Rankings Analysis
Table 21-1 compares the toxicity rankings analysis review results for the Timber
Products Category from the 2006 through 2011 Annual Reviews. The combined TWPE from
discharges in the DMR and TRI databases increased from discharge year 2002 to 2008 and
decreased from 2008 to 2009. The 2009 DMR TWPE accounts for approximately 75 percent of
the combined 2009 DMR and TRI TWPE.
Table 21-1. Timber Products Category TRI and DMR Discharges for the 2006 Through
2011 Toxicity Rankings Analysis
Year of Discharge
Year of Review
Timber Products Category
TRI TWPE"
DMRTWPEb
Total TWPE
2002
2006
48,000
1,100
49,100
2004
2007
63,900
443
64,300
2005
2008
51,500
NA
NA
2007
2009
16,300
51,600
67,900
2008
2010
27,300
295,000
322,000
2009
2011
29,700
91,200
121,000
Sources: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 include only major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
21.2 Timber Products Category Pollutants of Concern
Table 21-2 lists the top five pollutants with the highest TWPE in the 2009 and 2008
DMR databases, based on results from the 2011 and 2010 Annual Reviews (DMRLoads2009 v2
and DMRLoads2008 v3, respectively). Copper is the top DMR-reported pollutant in 2009,
contributing more than 87 percent of the 2009 DMR TWPE. EPA did not investigate the other
top DMR pollutants as part of the 2011 Annual Reviews because they represent less than 13
percent of the 2009 DMR TWPE for the Timber Products Category.
21-1
-------
Section 21—Timber Products Processing (40 CFR Part 429)
Table 21-2. Timber Products Category Top DMR Pollutants
Pollutant
2008 DMR Data3
2009 DMR Data"
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Copper
1
24
267,000
1
16
79,700
Iron
Pollutant not reported in the top five 2009
DMR reported pollutants.
2
4
7,930
Manganese
3
2
886
Ammonia as N
4
17
768
Magnesium
5
4
371
Arsenic
2
13
9,670
Pollutant not reported in the top five 2009
DMR reported pollutants.
p-Chloro-m-cresol
3
2
2,970
Benzo(a)pyrene
4
4
2,930
Pentachlorophenol
5
7
2,590
Timber Processing
Category Total
NA
66 b
295,000
NA
55 b
91,200
Sources: DMRLoads2008_v3 and DMRLoads2009_v2.
a DMR data include major and minor dischargers.
b Number of facilities reporting a TWPE of greater than zero.
NA: Not applicable.
Table 21-3 lists the five pollutants with the highest TWPE in the 2009 and 2008 TRI
databases (TRIReleases2009 v2 and TRIReleases2008 v3, respectively). Dioxin and dioxin-like
compounds are the top TRI-reported pollutant in 2009, contributing more than 72 percent of the
2009 TRI TWPE. EPA did not investigate the other top TRI pollutants as part of the 2011
Annual Reviews because they represent less than 28 percent of the 2009 TRI TWPE for the
Timber Products Category.
Table 21-3. Timber Products Category Top TRI Chemicals
Pollutant
2008 TRI Data"
2009 TRI Data"
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Dioxin and dioxin-like
Compounds
1
19
17,000
1
20
21,500
Arsenic and arsenic-like
Compounds
2
18
4,810
2
18
2,830
Polycyclic aromatic
compounds
Pollutants not reported in the top five 2009
TRI-reported pollutants.
3
33
1,410
Creosote
3
9
2,350
4
3
1,020
Copper and copper
compounds
4
31
1,240
5
24
1,000
Pentachlorophenol
5
15
705
Pollutants not reported in the top five
2008 TRI-reported pollutants.
21-2
-------
Section 21—Timber Products Processing (40 CFR Part 429)
Table 21-3. Timber Products Category Top TRI Chemicals
Pollutant
2008 TRI Data'1
2009 TRI Data1'
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Timber Processing
Category Total
NA
122b
27,300
NA
101b
29,700
Sources: TRIReleases2009jv2 and TRIReleases2008_v3.
a Discharges include transfers to POTWs and account for POTW removals.
b Number of facilities reporting TWPE greater than zero.
NA: Not applicable.
21.3 Timber Products Category Copper Discharges in DMR
Table 21-4 presents the top facilities with copper discharges in the 2009 DMR database.
EPA focused its review of copper discharges on the Ed Arey & Sons, Inc., facility in
Buckhannon, WV. The facility accounts for more than 99 percent of the copper discharges in the
2009 DMR data. The remaining 15 timber products facilities with copper discharges account for
less than 1 percent of the total Timber Products 2009 DMR copper TWPE.
Table 21-4. Top Copper Discharging Facilities in the 2009 DMR Database
Facility Name
Pounds of
Copper
Discharged
Copper
TWPE
Percentage of Timber
Products Category's 2009
DMR Copper TWPE
Ed Arey & Sons Inc.
126,000
79,400
>99%
All other copper dischargers in the Timber
Products Category3
561
353
<1%
Total
127,000
79,800
100%
Source: DMRLoads2009_v2.
a There are 15 remaining facilities that have copper dischargers in the 2009 DMR database, which account for
less than 1 percent of the category's copper DMR TWPE.
Ed Arey discharges copper through three outfalls, 001, 002, and 003. Table 21-5 presents
Ed Arey's copper concentration and flow discharge data from the 2009 DMR database. EPA
compared the 2009 DMR concentration and flow data to 2008 and 2009 flow data from
Envirofacts. The 2008 October flows in Envirofacts show an error with the unit of measurement
for the flows at all of the facility's outfalls; the flows in the 2009 DMR database were 1,000,000
times higher than 2008 flow data values in Envirofacts. Using the corrected flows, Ed Arey's
copper discharges are 0.1 pounds and 0.06 TWPE for 2009, reducing the facility's total TWPE
by 99 percent. This reduction in TWPE decreases the Timber Products Category's 2009 DMR
TWPE by 79,400.
21-3
-------
Section 21—Timber Products Processing (40 CFR Part 429)
Table 21-5. Ed Arey's 2009 DMR Copper and Flow Discharge Data
Outfall
Monitoring Period
Date
Maximum
Concentration (mjj/L)
DMR Loadings
Tool Flow (MGD)
Corrected Flow
(MGD)
001
30-Apr-2009
0.25
235
0.000235
001
31-0ct-2009
0.01
160
0.00016
002
30-Apr-2009
0.02
215
0.000215
002
31-0ct-2009
0.02
140
0.00014
003
30-Apr-2009
0.02
245
0.000245
003
31-0ct-2009
0.06
180
0.00018
Sources: EPA's Envirofacts and DMR Loadings Tool.
21.4 Timber Products Category Dioxin and Dioxin-Like Compounds Discharges in TRI
As part of the 2011 Annual Reviews, EPA contacted the trade association for timber
products facilities, the Treated Wood Council, and the trade association for pentachlorophenol
manufacturers, the Pentachlorophenol Task Force (PTF), to confirm the dioxin discharges and
distributions reported in the 2009 TRI database. EPA had previously contacted the Treated Wood
Council to collect information on dioxin and dioxin-like compound discharges as part of the
2004 Annual Reviews; in 2004, the Treated Wood Council identified the source of the dioxin
and dioxin-like discharges as the pentachlorophenol used in the wood preservation process (U.S.
EPA, 2004). The PTF confirmed that the top reporting facilities are still using pentachlorophenol
in their processes. The PTF reported that some facilities have dioxin and dioxin-like compound
discharges due to groundwater remediation activities; however, the majority of the reported
releases are associated with stormwater runoff from the finished-products storage yards
(Wilkinson, 2011).
The PTF also provided information on all 20 Timber Products dioxin and dioxin-like
compound discharging facilities. Table 21-6 presents the timber products facilities with dioxin
and dioxin-like compound discharges in the 2009 TRI database and the resulting changes made
to the pounds and TWPE as a result of the PTF information (Wilkinson, 2011).
The Treated Wood Council provides TRI industry reporting guidance, including a
congener distribution, to the timber facilities to properly estimate dioxin and dioxin-like
compound discharges from their facility. These estimates are based on pentachlorophenol
composition, which as a result of manufacturing can include dioxin and dioxin-like compounds.
The Treated Wood Council indicated that the TRI reporting guidance was updated based on 2008
pentachlorophenol composition data. Facilities then estimate or measure effluent
pentachlorophenol and use the congener distribution from the pentachlorophenol sampling to
calculate the dioxin and dioxin-like compound discharges. The PTF recognizes that this may be a
conservative approach given that the water solubility for pentachlorophenol is many orders of
magnitude higher than the water solubility of dioxin and dioxin-like compounds (Wilkinson,
2011).
21-4
-------
Section 21—Timber Products Processing (40 CFR Part 429)
Table 21-6. Dioxin and Dioxin-Like Compounds Discharging Facilities in the 2009 TRI Database
Facility Name
Location
Pounds of
Dioxin and
Dioxin-Like
Compounds
Released"
Dioxin and
Dioxin-Like
Compounds
TWPE
Revised Dioxin
and Dioxin-Like
Compounds
TWPE
Summary of Change from Pcntachlorophcnol
Task Force
Electric Mills Wood Preserving
LLC
Scooba, MS
0.130
8,230
1,530
Facility determined that an error had been made
during computation of releases. The stormwater
discharge from a 28-acre drainage area was
counted twice and there was a data entry error.
Amended 2009 TRI data show a release of 0.024
pounds. Accordingly, EPA revised the pounds
and TWPE.
Cahaba Pressure Treated Forest
Products Inc
Brierfield, AL
0.060
3,760
3,760
No change.
Huxford Pole & Timber Co Inc
Huxford, AL
0.037
2,320
2,320
No change.
Baldwin Pole Mississippi
Wiggins, MS
0.029
1,860
1,860
No change.
Koppers Inc
Grenada, MS
0.025
1,620
1,620
No change.
William C Meredith Co Inc
East Point, GA
0.022
1,400
1,400
No change.
Colfax Treating Co LLC
Pineville, LA
0.011
714
714
No change.
TR Miller Mill Co Inc
Brewton, AL
0.009
607
607
No change.
Koppers Inc
Florence, SC
0.011
553
553
No change.
Louisiana-Pacific Corp
Roaring River,
NC
0.00002
285
0
Facility's TRI-reported releases are based on a
one-time analysis for chlorinated dioxins/furans
required by the facility's NPDES permit. The
results were all below the detection limits and the
facility used half the detection limit to report
releases. Accordingly, EPA zeroed the dioxin
pounds and TWPE.
Baldwin Pole & Piling Co Inc
Bay Minette, AL
0.001
80.1
80.1
No change.
Mcfarland Cascade Pole & Lumber
Co
Tacoma, WA
0.0005
27.8
27.8
No change.
Mcfarland Cascade Pole & Lumber
Co
Eugene, OR
0.0004
24.9
0
Facility performed analyses for chlorinated
dioxins/furans in 2009, for which the all results
were non-detect. Accordingly, EPA zeroed the
dioxin pounds and TWPE.
21-5
-------
Section 21—Timber Products Processing (40 CFR Part 429)
Table 21-6. Dioxin and Dioxin-Like Compounds Discharging Facilities in the 2009 TRI Database
Facility Name
Location
Pounds of
Dioxin and
Dioxin-Like
Compounds
Released"
Dioxin and
Dioxin-Like
Compounds
TWPE
Revised Dioxin
and Dioxin-Like
Compounds
TWPE
Summary of Change from Pentachlorophenol
Task Force
Bell Lumber & Pole Co
New Brighton,
MN
0.0001
4.52
4.52
No change.
Brooks Manufacturing Co
Bellingham, WA
0.0001
3.82
3.82
No change.
Craftmaster Manufacturing Inc
Wysox, PA
0.0000002
3.45
3.45
No change.
J H Baxter & Co
Eugene, OR
0.00007
1.95
1.95
No change.
Oeser Co
Bellingham, WA
0.00005
1.54
1.54
No change.
Atlantic Wood Industries Inc
Vidalia, GA
0.00005
1.54
1.54
No change.
Permapost Products Inc
Hillsboro, OR
0.00001
0.16
0.16
No change.
Total
0.338
21,500
14,500
NA
Sources: TRIReleases2009jv2, the Pentachlorophenol Task Force letter (Wilkinson, 2011), 2011 Timber Data Review and Revised Calculations, (ERG, 2011).
a Discharges include transfers to POTWs and account for POTW removals.
NA: Not applicable.
21-6
-------
Section 21—Timber Products Processing (40 CFR Part 429)
21.5 Timber Products Category Conclusions
The estimated toxicity of the Timber Products Category discharges results mainly from
the copper discharges in DMR from one plant (accounting for 87 percent of the category's 2009
DMR TWPE) and dioxin and dioxin-like compound discharges in TRI (accounting for 72
percent of the category's 2009 TRI TWPE). EPA concludes the following:
• EPA identified database errors for the flows from Ed Arey & Sons, Inc. With
these errors corrected, the Timber Products Category's 2009 copper DMR TWPE
decreased by 99 percent, from 79,700 to 300.
• EPA contacted the Treated Wood Council and PTF to confirm discharges of
dioxin and dioxin-like compounds from timber products facilities. The PTF
identified reporting errors for three of these dischargers (Wilkinson, 2011). With
these errors corrected, the Timber Products Category's 2009 dioxin and dioxin-
like compounds TRI TWPE decreased by 32 percent, from 21,500 to 14,500.
• The PTF stated that the industry reporting guidance for dioxin and dioxin-like
compounds is based on the amount of pentachlorophenol measured or estimated
in the wastewater and the dioxin and dioxin-like compound distribution in the
pentachlorophenol. Additionally, all the wood preserving facilities are using the
industry TRI reporting guidance to estimate releases, the majority of which are
from stormwater runoff from finished-products storage yards (Wilkinson, 2011).
EPA does not recommend revising the Timber Products effluent limitations
guidelines (ELGs) because the dioxin and dioxin-like compound discharges are
dominated by stormwater, which the ELGs do not cover.
• The Timber Products Category's 2009 combined TWPE after incorporating
database corrections would be 34,600. This change would drop the category
outside the top 95 percent that EPA prioritized for preliminary review as part of
the 2011 Annual Reviews.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category a lower priority for
revision (i.e., it is marked with "(3)" in the "Findings" column in Table 8-1 in the Preliminary
2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S. EPA, 2013).
21.6 Timber Products Category References
1. ERG. 2011. Eastern Research Group, Inc. Preliminary Category Review—Facility Data
and Revised Calculations for Ed Arey & Sons, Inc. (April). EPA-HQ-OW-2010-0824.
DCN 07511.
2. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
21-7
-------
Section 21—Timber Products Processing (40 CFR Part 429)
3. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
4. Wilkinson, John. 2011. Letter Between John Wilkinson, Pentachlorophenol Task Force,
and Jessica Gray, Eastern Research Group, Inc., Re: Timber Products Sector 2009 TRI:
Chlorinated Dioxin/Furan Reporting. (July 22). EPA-HQ-OW-2010-0824. DCN 07512.
21-8
-------
Section 22—Textile Mills (40 CFR Part 410)
22. Textile Mills (40 CFR Part 410)
The Textile Mills (Textiles) Category continues to rank high, in terms of toxic-weighted
pound equivalents (TWPE), in the point source category rankings. This industry was reviewed
previously in EPA's Preliminary and Final 2006 Effluent Guidelines Program Plans and the
Preliminary 2008 Effluent Guidelines Program Plan (U.S. EPA, 2005, 2006, 2007). This section
summarizes the 2011 Annual Reviews associated with the Textiles Category. EPA focused on
discharges of sulfide because of its high TWPE relative to the other pollutants in the Textiles
Category.
22.1 Textiles Category 2011 Toxicity Rankings Analysis
Table 22-1 compares the toxicity rankings analysis results for the Textiles Category from
the 2006 through 2011 Annual Reviews. The combined TWPE from discharges in the discharge
monitoring reports (DMR) and Toxics Release Inventory (TRI) databases increased from
discharge years 2007 to 2008 and decreased from discharge years 2008 to 2009. The estimated
2009 DMR TWPE accounts for approximately 95 percent of the combined 2009 DMR and TRI
TWPE, similar to previous years.
Table 22-1. Textiles Category TRI and DMR Discharges for the 2006 Through 2011
Toxicity Rankings Analysis
Year of Discharge
Year of Review
Textiles Category
TRI TWPE"
DMR TWPEb
Total TWPE
2002
2006
3,710
123,000
127,000
2004
2007
3,040
123,000
126,000
2005
2008
3,040
NA
NA
2007
2009
2,390
79,900
82,300
2008
2010
2,750
247,000
250,000
2009
2011
1,910
37,200
39,100
Sources: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3;
TRIReleases2005_v2; TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v2;
TRIReleases2009_v2; and DMRLoads2009_v2.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2002 through 2007 include only major dischargers. 2008 and 2009 DMR data include both
minor and major dischargers.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
22.2 Textiles Category Pollutants of Concern
The Textiles Category review focused on the 2009 DMR discharges because the 2009
DMR data dominate the category's combined TWPE. Table 22-2 lists the five pollutants with the
highest TWPE based on results from the 2011 and 2010 DMR databases (DMRLoads2008 v2
and DMRLoads2009 v2, respectively). Sulfide is the top DMR pollutant in discharge year 2009,
contributing approximately 88 percent of the category's 2009 combined TWPE. Accordingly, the
rest of the Textiles Category review focuses on the sulfide discharges from the 2009 DMR
database.
22-1
-------
Section 22—Textile Mills (40 CFR Part 410)
Table 22-2. Textiles Category Top DMR Pollutants
Pollutant
2008a
2009"
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Sulfide
4
25
30,100
1
18
34,500
Hydrogen sulfide
Pollutant not reported in the top five 2008 DMR-reported
pollutants.
2
1
2,020
Chlorine
2
14
269
Copper
4
11
134
Ammonia as N
5
34
77.8
Mercury
1
3
135,000
Pollutant not reported in the top five 2009 DMR-reported
pollutants.
Aluminum
2
3
34,300
Toxaphene
3
1
32,800
Aldrin
5
1
9,500
Textiles Category Total
NA
77b
247,000
NA
56b
37,200
Sources: DMRLoads2008_v3 and DMRLoads2009_v2.
" DMR data include major and minor dischargers.
b Number of facilities reporting a TWPE of greater than zero.
NA: Not applicable.
22-2
-------
Section 22—Textile Mills (40 CFR Part 410)
22.3 Textiles Category Sulfide Discharges in DMR
Table 22-3 presents the top sulfide dischargers in the 2009 DMR database. The majority
(61 percent) of the sulfide discharges were from the top two discharging facilities, Mohawk
Industries, Inc., in Lyerly, GA and Gold Mills, Inc. in Pine Grove, PA. Accordingly, EPA
focused the Textiles Category review on these two facilities.
Table 22-3. Textiles Category Top Sulfide Discharging Facilities
in the 2009 DMR Database
Facility Name
Facility Location
Pounds of Sulfide
Discharged
Sulfide TWPE
Percentage of
Textiles Category
2009 DMR Sulfide
TWPE
Mohawk Industries, Inc.
Lyerly, GA
4,990
14,000
40.6%
Gold Mills, Inc.
Pine Grove, PA
2,490
6,980
20.2%
Remaining facilities reporting sulfide discharges in
the Textiles Category3
5,120
13,500
39.2%
Total
12,600
34,500
100%
Source: DMRLoads2009_v2.
a There are 15 remaining facilities that have sulfide discharges in the 2009 DMR database, which account for
approximately 40 percent of the category's sulfide DMR TWPE.
2 2
Sulfide is an anion of sulfur in its lowest oxidation state of minus 2 (S "). The dianion S "
exists only in strongly alkaline aqueous solutions. Such solutions can form by dissolution of H2S
or alkali metals such as lithium sulfide, sodium sulfide, and potassium sulfide in the presence of
excess hydroxide ions. The ion S2 is exceptionally basic with an acid dissociation constant (pKa)
greater than 14. Sulfide does not exist in appreciable concentrations even in highly alkaline
water. Instead, sulfide combines with protons to form HS , which is variously called H2S ion. At
still lower pH values (<7), HS converts to H2S, as shown by the equation below. At a pH of 5,
nearly 100 percent of sulfide is present as H2S.
H2S O HS" + H+ and HS" O S" + H+ (Eq. 22-1)
Sulfides are moderately strong reducing agents. They react with oxygen in the air in
elevated temperatures to form higher-valence sulfur salts, such as sulfates and sulfur dioxide.
Aqueous solutions of transition metals cations react with sulfides to precipitate solid metal
sulfide salts. The metal sulfide salts typically have very low solubility in water.
Organic sulfur and sulfides are in the wastewater of textile mills mainly from the dying
operation (U.S. EPA, 1974). In the 2009 DMR database, 17 facilities report sulfide discharges.
EPA evaluated the monthly sulfide concentrations for all those reported above the detection limit
and determined the average and median sulfide concentrations to be 1.36 and 0.35 mg/L,
respectively. The sulfide concentrations range from below the detection limit to 26 mg/L.
Sulfides discharged to neutral receiving waters can be reduced to hydrogen disulfide
(H2S), an extremely toxic, odiferous, and corrosive gas. Minute concentrations (2 |ig/L) of H2S
impart an objectionable odor and taste to water, making it unfit for municipal consumption (U.S.
EPA, 1974). The National Water Quality Criteria also determined that sulfide concentrations
22-3
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Section 22—Textile Mills (40 CFR Part 410)
greater than 2 |ig/L would constitute a long-term hazard for fish and other aquatic life (U.S.
EPA, 1986). Because of the proven toxicity of sulfides, sulfide was listed as a primary pollutant
for BPT in the Development Document for Effluent Guidelines and New Source Performance
Standards for the Textile Mills Point Source Category (1974 TDD).
Table 22-4 presents available sulfide treatment options in the textiles industry (see
Section 19.5 for more details). Although these treatment options can remove sulfide from
wastewater, the actual effluent concentrations attainable are a function of treatment system
design (Briggs, 2011).
Table 22-4. Sulfide Wastewater Treatment Options
Tcchnulu*^ N;mik'
1 iv:iliil)ilil>
('oiHTiilr;iliuiis
Description
Biological treatment
Up to 99 percent
sulfide removal
Treats industrial effluent streams by either aerobic or anaerobic
processes. The treatment involves bacteria decomposing waste to
form harmless inorganic solids. Studies show that approximately 99
percent of the influent sulfide concentration can be biologically
oxidized to sulfate.
Aeration and air stripping
Up to 100
percent sulfide
removal
Aeration involves removal of dissolved gasses such as H2S from
water, and is generally used in two types of water applications: air
stripping and aeration. The effectiveness of aeration for removing
sulfide depends on the aeration method selected, the pH of the
water, design factors, flow and loading rate, available area of mass
transfer, temperature, and algae production. The major drawback to
aeration is that H2S is not destroyed but converted to an air
emission.
Hydrogen peroxide
oxidation
Up to 100
percent sulfide
removal
This process controls sulfide by oxidation to either elemental sulfur
or sulfate ion by hydrogen peroxide (H202) addition, depending on
the pH of the wastewater. It can approach 100% efficiency if H202
is added in a controlled fashion and the reaction medium is
thoroughly mixed. No additional wastewater processing is required
following peroxide oxidation because sulfate is very soluble in
water.
Sources: ERG sulfide treatment technologies memo (Briggs, 2011); "Biological Treatment of Tannery Wastewater"
article (Durai and Rajasimman, 2010).
22.3.1 Mohawk Industries, Inc.
Sulfide discharges from Mohawk Industries, Inc., in Lyerly, GA account for
approximately 18 percent of the DMR TWPE for the Textiles Category. All of Mohawk
Industries' sulfide discharges are from its outfall 0A1. Table 22-5 presents the sulfide discharge
quantities from DMR data. From these reported quantities, EPA calculated the sulfide
concentrations for reporting years 2008 and 2009 using the average quantity and flow from the
DMR Loadings Tool. As part of the 2010 Annual Reviews, EPA contacted Mohawk Industries
and confirmed the 2008 sulfide quantities and that the permit limit for sulfide is 24.2 pounds per
day (lb/day). Mohawk Industries also stated that sulfide in the wastewater may come from boiler
treatment chemicals and wastewater treatment chemicals used to treat intake water for hardness
(Wood, 2010).
22-4
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Section 22—Textile Mills (40 CFR Part 410)
The Textiles Category, Subpart F (Carpet Finishing) does regulate sulfide; however, it is
a production-based limit of 0.08 pounds of sulfide per 1,000 pounds of product. Although the
2009 sulfide quantities are below the mass-based permit and calculated ELG limits, EPA's
calculated sulfide concentrations, which range from 1.17 mg/L to 1.44 mg/L, are greater than
treatability concentrations achieved by biological treatment, aeration and stripping, and hydrogen
peroxide oxidation (up to 100 percent sulfide removal). The back-calculated concentrations are
also greater than the Gold Book Water Quality Standards (2 |ig/L) for sulfides (H2S).
As part of the 2011 review, EPA contacted the facility permit writer with the Georgia
Environmental Protection Division to discuss sulfide discharges at the facility. The permit writer
stated that the permit limits are based on the ELG production-based limits because Georgia does
not have a water quality standard for sulfide. The permit writer stated that no further
investigation of sulfide discharges has been done at this time (Noell, 2011). Therefore, EPA is
considering facility-specific permitting support to address sulfide discharges at this facility.
22-5
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Section 22—Textile Mills (40 CFR Part 410)
Table 22-5. Mohawk Industries 2008 and 2009 Monthly Sulfide Discharge Data for Outfall 0A1
Pollutant
Monitoring
Period Date
2008
2009
DMR Loadings
Tool Average
Quantity
(lb/day)
Calculated
Sulfide
Concentrations
(mg/L)
Average Flow
(MGD)
DMR Loadings
Tool Average
Quantity
(lb/day)
Calculated
Sulfide
Concentrations
(mg/L)
Average Flow (MGD)
Sulfide
31-Jan
13.4
1.2
1.32
14.90
1.41
1.26
Sulfide
30-Apr
18.3
1.3
1.66
15.1
1.44
1.26
Sulfide
31-Jul
16.8
1.9
1.03
10.7
1.17
1.1
Sulfide
31-Oct
6.24
1.1
0.723
13.4
1.33
1.21
Source: DMR Loadings Tool (http://cfpub.epa.gov/dmr/).
22-6
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Section 22—Textile Mills (40 CFR Part 410)
22.3.2 Gold Mills, Inc.
Gold Mills, Inc., in Pine Grove, PA discharges sulfide from its outfall 001, which
receives wastewater from dyeing and finishing processes (PA DEP, 2004). Table 22-6 presents
the 2009 sulfide discharge data in the DMR Loadings Tool and the calculated concentrations.
EPA calculated the sulfide concentrations using the average quantity and flow provided in the
DMR Loadings Tool.
For outfall 001, the facility permit average monthly sulfide limit is 15.8 lbs/day and the
maximum daily limit is 31.6 lbs/day. The Textiles Category, Subpart E (Knit Fabric Finishing)
does regulate sulfide; however, it is a production-based limit of 0.2 pounds of sulfide per 1,000
pounds of product. The sulfide quantities are 45 percent lower than the permit limits and do not
exceed the calculated ELG mass-based limit; however, the calculated concentrations, which
range from 2.43 to 3.03 mg/L, are greater than treatability concentrations achieved by biological
treatment, aeration and stripping, and hydrogen peroxide oxidation (up to 100 percent sulfide
removal). The back-calculated concentrations are also greater than the Gold Book Water Quality
Standards (2 |ig/L) for sulfides (H2S).
As part of the 2011 review, EPA contacted the facility permit writer with the
Pennsylvania Department of Environmental Protection to discuss sulfide discharges at the
facility. The permit writer stated that the permit limits are based on the ELG production-based
limits because Pennsylvania does not have a water quality standard for sulfide. The permit writer
stated that sulfide discharges have not been investigated further at this time (Hastings, 2011).
Therefore, EPA is considering facility-specific permitting support to address sulfide discharges
at this facility.
Table 22-6. Gold Mills 2009 Monthly Sulfide Discharge Data
Outfall
Pollutant
.Monitoring Period
Date
DMR Loadings
Tool Average
Quantity (Ib/dav)
Caleulated Sulfide
Coneentrations
(mg/L)
Average Flow
(MGD)
001
Sulfide
31-Jan-09
7.82
3.03
0.309
001
Sulfide
28-Feb-09
8.85
2.95
0.359
001
Sulfide
31-Mar-09
7.81
2.84
0.329
001
Sulfide
30-Apr-09
6.75
2.72
0.297
001
Sulfide
31-May-09
6.74
2.96
0.273
001
Sulfide
30-Jun-09
6.74
2.92
0.277
001
Sulfide
31-Jul-09
6.41
2.86
0.269
001
Sulfide
31-Aug-09
6.58
2.81
0.281
001
Sulfide
30-Sep-09
6.75
2.55
0.317
001
Sulfide
31-Oct-09
6.50
2.43
0.32
001
Sulfide
30-Nov-09
5.80
2.77
0.251
001
Sulfide
31-Dec-09
5.40
2.55
0.254
Source: DMR Loadings Tool (http://cfpub.epa.gov/dmr/).
22-7
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Section 22—Textile Mills (40 CFR Part 410)
22.4 Textiles Category Conclusions
The estimated toxicity of the Textiles Category discharges result mainly from sulfide
discharges from two facilities. Data collected for the 2011 Annual Reviews demonstrated that
wastewater discharge characteristics for this category are consistent with discharges from prior
years. As in prior years, EPA concludes the following:
• Sulfides can be treated using biological treatment, aeration and stripping, and
hydrogen peroxide oxidation. Air stripping is an effective treatment, but the H2S
is discharged to the atmosphere. Hydrogen peroxide oxidation and biological
treatment are two efficient treatment technologies. Hydrogen peroxide oxidation
at pH levels above 9.2 produces sulfate, but the pH must be raised to achieve
treatment, then lowered to near neutral prior to surface discharge.
• Sulfide discharges from Mohawk Industries in Lyerly, GA and Gold Mills in Pine
Grove, PA are both below the permit limit production-based quantities; however,
the back-calculated concentrations for these facilities are higher than treatability
levels using biological treatment in combination with air oxidation (using
activated carbon) or hydrogen peroxide oxidation. These back-calculated
concentrations are also above recommended national water quality criteria levels.
• Sulfide discharges in the Carpet Finishing and Knit Fabric subcategories result
from the dyeing process. The Textiles 1974 TDD states that biological treatment
is sufficient to treat sulfides in wastewater. More recent studies suggest that
biological treatment in combination with air oxidation using activated carbon or
hydrogen peroxide oxidation can completely eliminate sulfide from effluent
wastewater. Because the facilities in this subcategory could reduce sulfide
discharges via additional treatment or the use of sulfide-free dyes, EPA is
considering facility-specific permitting support to control sulfide discharges.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, this category is similar to the EPA "lower priority for
revision" conclusion (i.e., this category is marked with "(2)" in the "Findings" column in Table
8-1 in the Preliminary 2012 Plan that presents the 2011 Annual Reviews of existing ELGs) (U.S.
EPA, 2013).
22.5 Textiles Category References
1. Briggs, Mark. 2011. Sulfide Treatment Technologies Memorandum. Eastern Research
Group. (July 15). EPA-HQ-OW-2010-0824. DCN 07616.
2. Durai, G, and M Rajasimman. 2011. Biological Treatment of Tannery Wastewater—A
Review. Journal of Environmental Science and Technology. Volume 4 (1): 1-17.
(January 17). EPA-HQ-OW-2010-0824. DCN 07506.
3. Hastings, Mary. 2011. Telephone and Email Communication Between Mary Hastings,
Pennsylvania Department of Environmental Protection, and Elizabeth Sabol, Eastern
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Section 22—Textile Mills (40 CFR Part 410)
Research Group, Inc., Re: 2009 DMR Sulfide Discharges. (September 6). EPA-HQ-OW-
2010-0824. DCN 07509.
4. Noell, Bill. 2011. Telephone Communication Between Bill Noel, Georgia Environmental
Protection Division, and Elizabeth Sabol, Eastern Research Group, Inc., Re: 2009 DMR
Sulfide Discharges. (September 19). EPA-HQ-OW-2010-0824. DCN 07510.
5. PA DEP. 2004. Pennsylvania Department of Environmental Protection. NPDES Permit:
Gold Mills, Inc., Pine Grove, PA. (August 30). EPA-HQ-OW-2010-0824. DCN 07507.
6. U.S. EPA. 1974. Development Document for Effluent Guidelines and New Source
Performance Standards for the Textile Mills Point Source Category. Washington, D.C.
(June). EPA-440-1-79.
7. U.S. EPA. 1982. Development Document for Effluent Guidelines and New Source
Performance Standards for the Textile Mills Point Source Category. Washington, D.C.
(September). EPA-440-l-79-022b.
8. U.S. EPA. 1986. Quality Criteria for Water 1986. Washington, D.C. (May). EPA-440-5-
86-0010.
9. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004-0032-
0016.
10. U.S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
11. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
12. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA 820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
13. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, DC.
(May). EPA-HQ-OW-2010-0824 DCN 07684.
14. Wood, Denise. 2010. Telephone and E-mail Communication Between Denise Wood,
Mohawk Industries, and Elizabeth Sabol and Lauren Wingo, Eastern Research Group,
Inc., Re: DMR Clarification Needed for Mohawk Industries Oak River Plant and Lyerly
Plant. (September 2). EPA-HQ-OW-2008-0517 DCN 07309.
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