United States

Environmental Protection Agency



# The 2015 Annual Effluent Guidelines Review Report

June 2016THIS PAGE INTENTIONALLY LEFT BLANK

# U.S. Environmental Protection Agency Office of Water (4303T) 1200 Pennsylvania Avenue, NW Washington, DC 20460

EPA

- 82 1-R- 16

- 002THIS PAGE INTENTIONALLY LEFT BLANKTable of Contents

TABLE OF CONTENTS

Page

1. I NTRODUCTION TO EPA’ S 2015 A NNUAL R EVIEW

........................................................ 1-1

1.1 Intr oduction References

....................................................................................... 1-2

2. EPA’ S 2015 T OXICITY R ANKINGS A NALYSIS (TRA)

.................................................... 2-1

2.1 Data Sources and Limitations

.............................................................................. 2-1

2.1.1 SIC Codes

............................................................................................... 2-2

2.1.2 NAICS Codes

......................................................................................... 2-3

2.1.3 Toxic Weighting Factors

........................................................................ 2-4

2.1.4 Data from ICIS

- NPDES

......................................................................... 2-4

2.1.5 Data from TRI

......................................................................................... 2-7

2.2 Data Quality Review

............................................................................................ 2-9

2.2.1 Data Quality Review and Corrections to the 2013 DMR Data

............ 2-10

2.2.2 Data Quality Review and Corrections to the 2013 TRI Data

............... 2-16

2.3 Generation of the Final 2015 Point Source Category Rankings

........................ 2-23

2.3.1 Categories for Which EPA Has Recently Promulgated or

Revised ELGs

....................................................................................... 2-24

2.3.2 Discharges Not Categorizable

.............................................................. 2-25

2.4 Results of the 2015 Toxicity Rankings Analysis

............................................... 2-25

2.5 References for EPA’s Toxicity Rankings Analysis

........................................... 2-28

3. EPA’ S 2015 P RELIMINARY C ATEGORY R EVIEWS

......................................................... 3-1

3.1 Prioritization of Categories for Preliminary Category Review

............................ 3-1

3.1.1 Drinking Water Treatment (potential new category)

.............................. 3-2

3.1.2 Fertilizer Manufacturing (40 CFR Part 418)

.......................................... 3-2

3.1.3 Inorganic Chemicals Manufacturing (40 CFR Part 415)

........................ 3-2

3.1.4 Miscellaneous Foods and Beverages (poten tial new category)

.............. 3-3

3.1.5 Oil and Gas Extraction (40 CFR Part 435)

............................................. 3-3

3.1.6 References for the Prioritization of Categories for Preliminary Category Review

.................................................................................... 3-4

3.2 Carbon Black Manufacturing (40 CFR Part 458)

................................................ 3-5

3.2.1 Carbon Black Category 2015 Toxicity Rankings Analysis

.................... 3-5

3.2.2 Carbon Black Category Pollutants of Concern

....................................... 3-6

3.2.3 Carbon Black PAC Discharges in TRI

................................................... 3-6

3.2.4 Carbon Black Category Findings

............................................................ 3-8

3.2.5 Carbon Black Category References

........................................................ 3-9

3.3 Grain Mills (40 CFR Part 406)

.......................................................................... 3-11

3.3.1 Grain Mills Category 2015 Toxicity Rankings Analysis

..................... 3-11

3.3.2 Grain Mills Category Pollutants of Concern

........................................ 3-12

3.3.3 Hydrogen Sulfide Background

............................................................. 3-12

3.3.4 Grain Mills Category Hydrogen Sulfide Releases in TRI

.................... 3-13

3.3.5 Grain Mills Category Findings

............................................................. 3-14

3.3.6 Grain Mills Category References

......................................................... 3-14

iv3.4 Iron and Steel Manufacturing (40 CFR Part 420)

.............................................. 3-16

3.4.1 Iron and Steel Manufacturing Category 2015 Toxicity Rankings Analysis

................................................................................ 3-16

3.4.2 Iron and Steel Manufacturing Category Pollutants of Concern

............ 3-17

3.4.3 Ir on and Steel Manufacturing PCBs Discharges in DMR

.................... 3-19

3.4.4 Iron and Steel Manufacturing Cyanide Discharges in DMR

................ 3-20

3.4.5 Iron and Steel Manufacturing Fluoride Discharges in DMR

................ 3-24

3.4.6 Iron and Steel Manufacturing Lead and Lead Compound Discharges in DMR and TRI

................................................................ 3-30

3.4.7 Iron and Steel Manufacturing Nitrate Compound Releases in

TRI

........................................................................................................ 3-31

3.4.8 Iron and Steel Manufacturing Category Findings

................................ 3-32

3.4.9 Iron and Steel Manufacturing Category References

............................. 3-33

3.5 Landfills (40 CFR Part 445)

.............................................................................. 3-36

3.5.1 Landfills Category 2015 Toxicity Rankings Analysis

.......................... 3-36

3.5.2 Landfills Category Pollutants of Concern

............................................ 3-37

3.5.3 Landfills Category Cadmium Discharges in DMR

.............................. 3-37

3.5.4 Landfills Category Selenium Discharges in DMR

............................... 3-38

3.5.5 Landfills Category Iron Discharges in DMR

........................................ 3-40

3.5.6 Landfills Category Findings

................................................................. 3-42

3.5.7 Landfills Category References

............................................................. 3-42

3.6 Meat and Poultry Products (40 CFR Part 432)

.................................................. 3-45

3.6.1 Meat and Poultry Category 2015 Toxicity Rankings Analysis

............ 3-45

3.6.2 Meat and Poultry Category Pollutants of Concern

............................... 3-46

3.6.3 Meat and Poultry Category Nitrate Compound Releases in

TRI

........................................................................................................ 3-46

3.6.4 Meat and Poultry Category Hydrogen Sulfide Releases in TRI

........... 3-54

3.6.5 Meat and Poultry Category Findings

.................................................... 3-56

3.6.6 Meat and Poultry Category References

................................................ 3-57

3.7 Mineral Mining and Processing (40 CFR Part 436)

.......................................... 3-59

3.7.1 Mineral Mining Category 2015 Toxicity Rankings Analysis

............... 3-59

3.7.2 Mineral Mining Category Pollutants of Concern

................................. 3-60

3.7.3 Mineral Mining Category Chloride and Aluminum Discharges in DMR

.............................................................................. 3-60

3.7.4 Mineral Mining Category Fluoride Discharges in DMR

...................... 3-63

3.7.5 Mineral Mining Category Findings

...................................................... 3-65

3.7.6 Mineral Mining Category References

.................................................. 3-66

3.8 Nonferrous Metals Manufacturing (40 CFR Part 421)

...................................... 3-67

3.8.1 NFMM Category 2015 Toxicity Rankings Analysis

............................ 3-67

3.8.2 NFMM Category Pollutants of Concern

............................................... 3-68

3.8.3 NFMM Cadmium and Fluoride Discharges in DMR

........................... 3-68

3.8.4 NFMM Category Findings

................................................................... 3-72

3.8.5 NFMM Category References

................................................................ 3-72 Table of Contents

TABLE OF CONTENTS (Continued)

Page

vTable of Contents

TABLE OF CONTENTS (Continued)

Page

3.9 Ore Mining and Dressing (40 CFR Part 440)

.................................................... 3-74

3.9.1 Ore Mining Category 2015 Toxicity Rankings Analysis

..................... 3-74

3.9.2 Ore Mining Category Pollutants of Concern

........................................ 3-75

3.9.3 Ore Mining Copper Discharges in DMR and TRI

................................ 3-77

3.9.4 Ore Mining S elenium Discharges in DMR

.......................................... 3-79

3.9.5 Ore Mining Radium

- 226 Discharges in DMR

...................................... 3-80

3.9.6 Ore Mining Arsenic Discharges in DMR and TRI

............................... 3-80

3.9.7 Ore Mining Lead and Lead Compound Discharges in TRI

.................. 3-83

3.9.8 Ore Mining Silver and Silver Compoun d Discharges in TRI

............... 3-84

3.9.9 Ore Mining Category Findings

............................................................. 3-85

3.9.10 Ore Mining and Dressing Category References

................................... 3-86

3.10 Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)

............. 3-89

3.10.1 OCPSF Category 2015 Toxicity Rankings Analysis

............................ 3-89

3.10.2 OCPSF Category Po llutants of Concern

............................................... 3-90

3.10.3 OCPSF Category PACs Discharges in DMR and TRI

......................... 3-92

3.10.4 OCPSF Category Total Residual Chlorine Discharges in

DMR

..................................................................................................... 3-95

3.10.5 OCPSF Category Hexachlorobe nzene Discharges in DMR

................. 3-96

3.10.6 OCPSF Category Dioxin Discharges in DMR and TRI

....................... 3-98

3.10.7 OCPSF Category Carbon Disulfide Releases in TRI

......................... 3-101

3.10.8 OCPSF Category Nitrate Compounds Releases in TRI

..................... 3-103

3.10.9 OCPSF Category Findings

................................................................. 3-105

3.10.10 OCPSF Category References

.............................................................. 3-107

3.11 Pulp, Paper, and Paperboard (40 CFR Part 430)

............................................. 3-111

3.11.1 Pulp and Paper Category 2015 Toxicity Rankings Analysis

.............. 3-111

3.11.2 Pulp and Paper Category Pollutants of Concern

................................. 3-112

3.11.3 Pulp and Paper Category Hydrogen Sulfide Releases in TRI

............ 3-113

3.11.4 Pulp and Paper Category Dioxin and Dioxin Compound

Releases in TRI

................................................................................... 3-116

3.11.5 Pulp and Paper Category Manganese and Manganese Compound Releases in TRI

................................................................ 3-119

3.11.6 Pulp and Paper Category Findings

..................................................... 3-120

3.11.7 Pulp and Paper Category References

.................................................. 3-121

3.12 Textile Mills (40 CFR Part 410)

...................................................................... 3-123

3.12.1 Textiles Category 2015 Toxicity Rankings Analysis

......................... 3-123

3.12.2 Textiles Category Pollutants of Concern

............................................ 3-123

3.12.3 Textiles Toxaphene Discharges in DMR

............................................ 3-124

3.12.4 Textiles Sulfide Discharges in DMR

.................................................. 3-126

3.12.5 Textiles Category Findings

................................................................. 3-127

3.12.6 Textiles Category References

............................................................. 3-127

viTABLE OF CONTENTS (Continued) Table of Contents

Page

4. EPA’ S 2015 R EVIEW OF A DDITIONAL I NDUSTRIAL C ATEGORIES AND
P OLLUTANTS

.......................................................................................................................... 4-1

4.1 Battery Manufacturing (40 CFR Part 461)

.......................................................... 4-1

4.1.1 Overview of Battery Manufacturing, the ELGs, and Current U.S. Manufacturing

................................................................................ 4-2

4.1.2 Overview of Rechargeable Batteries

...................................................... 4-4

4.1.3 Summary of Findings from EPA’s Review of Battery Manufacturing

......................................................................................... 4-7

4.1.4 References for Battery Manufacturing

................................................... 4-8

4.2 Electrical and Electronic Components (40 CFR Part 469)

................................ 4-12

4.2.1 Overview of the Electrical and Electronic Components ELGs in Relation to Sapphire Crystal Manufacturing

.................................... 4-12

4.2.2 Overview of Sapphire Crystals Manufacturing and

Wastewater Generation

......................................................................... 4-12

4.2.3 Summary of Findings from E PA’s Review of the Electrical and Electronic Components ELGs in Relation to Sapphire Crystal Manufacturing

.......................................................................... 4-16

4.2.4 References f or Electrical and Electronic Components

......................... 4-17

4.3 2- Mercaptobenzothiazole (MBT)

...................................................................... 4-19

4.3.1 Overview of Existing ELGs Related to MBT and Rubber Manufacturing

....................................................................................... 4-19

4.3.2 Overview of MBT

................................................................................. 4-19

4.3.3 Summary of Findings from EPA’s Review of MBT

............................ 4-21

4.3.4 References for MBT

............................................................................. 4-21

vi iList of Tables

LIST OF TABLES Page

Table 2 -1.Nomenclature and Format of NAICS and SIC Codes

................................................. 2-3

Table 2

- 2. Results of 2013 DMR Data Completeness Check

.................................................... 2-10

Table 2 -3. Summary of 2013 DMR Facility Data Quality Review

........................................... 2-12

Table 2

- 4. Results of the 2013 TRI Data Completeness Check

................................................ 2-16

Table 2 -5. Summary of 2013 TRI Facility Data Quality Review

.............................................. 2-18

Table 2 -6. Top 2013 TRI Point Source Categories with Reported Hydrogen Sulfide

Water Releases

........................................................................................................ 2-20

Table 2 -7. Summary of 2013 TRI Hydrogen Sulfide Water Releases by Release Type

........... 2-21

Table 2 -8. Point Source Categories That Have Undergone Recent Rulemaking

...................... 2-24

Table 2 -9. Final 2015 C ombined Point Source Category Rankings

.......................................... 2-26

Table 3 -1. Carbon Black Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

............................................................................ 3-5

Table 3 -2. Carbon Black Category Top TRI Pollutants

.............................................................. 3-6

Table 3 -3. Top Facilities Reporting 2013 TRI PAC Releases

..................................................... 3-7

Table 3

- 4. GrafTech PAC TRI Releases for 2008 – 2013

........................................................... 3-8

Table 3 -5. Cabot PAC TRI Releases for 2007 – 2013

................................................................. 3-8

Table 3-6. Grain Mills Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

......................................................................................... 3-11

Table 3

- 7. Grain Mills Category Top TRI Pollutants

................................................................ 3-12

Table 3 -8. Top Facilities Reporting 2013 TRI Hydrogen Sulfide Releases

.............................. 3-13

Table 3 -9. Iron and Steel Manufacturing Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

....................................................... 3-17

Table 3 -10. Iron and Steel Manufacturing Category Top DMR Pollutants

............................... 3-18

Table 3 -11. Iron and Steel Manufacturing Category Top TRI Pollutants

................................. 3-19

Table 3-12. U.S. Steel Fairless Hills Works’ PCB Discharges for 2011-2014

......................... 3-20

Table 3 -13. Top 2013 DMR Cyanide Discharging Facilities

.................................................... 3-21

Table 3 -14. Mountain State Carbon 2008 and 2013 Permit Limits

........................................... 3-21

Table 3 -15. Mountain State Carbon’s 2013 DMR CNWAD Discharges

.................................. 3-22

Table 3 -16. Mountain State Carbon’s 2013 DMR Total Cyanide Discharges

.......................... 3-23

v iiiLIST OF TABLES (Continued) List of Tables

Page

Table 3 -17. U.S. Steel Clairton Plant’s 2002, 2012, and 2015 Cyanide Permit Limits for

Outfall 183

.............................................................................................................. 3-23

Table 3 -18. U.S. Steel Clairton Plant’s 2013 DMR Cyanide Discharges for Outfall 183

......... 3-24

Table 3 -19. Top 2013 DMR Fluoride Discharging Facilities

.................................................... 3-25

Table 3 -20. U.S. Steel Gary Works’ 2013 DMR Fluoride Discharges...................................... 3-26

Table 3 -21. U.S. Steel Gary Works’ Fluoride Discharges for 2011 – 2014

.............................. 3-26

Table 3 -22. ArcelorMittal Weirton LLC’s 2013 DMR Fluoride Discharges

............................ 3-27

Table 3 -23. ArcelorMittal Weirton LLC’s Fluoride Discharges for 2011 – 2014

..................... 3-28

Table 3 -24. U.S. Steel Granite City Works’ 2013 DMR Fluoride Discharges for Outfall

001

.......................................................................................................................... 3-28

Table 3-25. U.S. Steel Granite City Works’ Fluoride Discharges for 2011 – 2014

.................. 3-29

Table 3 -26. ArcelorMittal Burns Harbor 2013 DMR Fluo ride Discharges for Outfall 002

...... 3-29

Table 3 -27. ArcelorMittal Burns Harbor Fluoride Discharges for 2011 – 2014

....................... 3-29

Table 3 -28. Top Facilities Reporting 2013 TRI Lead and Lead Compound Releases

.............. 3-30

Table 3 -29. Top Facilities Reporting 2013 TRI Nitrate Compound Releases

........................... 3-31

Table 3 -30. AK Steel Rockport Works’ TRI- Reported Nitrate Compound Releases for

2008 – 2013

............................................................................................................ 3-32

Ta ble 3-31. Landfills Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

......................................................................................... 3-36

Table 3

- 32. Landfill s Category Top DMR Pollutants

............................................................... 3-37

Table 3 -33. Top 2013 DMR Cadmium Discharging Facilities

.................................................. 3-38

Table 3 -34. Henderson City Landfill’s 2013 DMR Quarterly Cadmium Discharges

............... 3-38

Table 3 -35. Top 2013 DMR Selenium Discharging Facilities

.................................................. 3-39

Table 3

- 36. SCGENCO/Williams Ash Disposal Facility’s 2013 DMR Original and Corrected Selenium Discharges from Outfall 001

.................................................. 3-39

Table 3 -37. Top 2013 DMR Iron Discharging Facilities

........................................................... 3-40

Table 3 -38. Bluegrass Containment LLC’s 2013 DMR Original and Corrected Iron Discharges from Outfall 001

.................................................................................. 3-41

Table 3 -39. Bavarian Trucking’s 2013 DMR Iron Discharges from Outfall 001

..................... 3-42

ixLIST OF TABLES (Continued) List of Tables

Page

Table 3

- 40. Meat and Poultry Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

.......................................................................... 3-45

Table 3 -41. Meat and Poultry C ategory Top TRI Pollutants

..................................................... 3-46

Table 3 -42. Top Facilities Reporting 2013 TRI Nitrate Compound Releases

........................... 3-48

Table 3 -43. BAT Treatment for the Meat and Poultry Subcategories

....................................... 3-49

Table 3 -44. John Morrell’s Sioux Falls Facility’s 2013 DMR Discharges for Ammonia as N, Outfall 001

..................................................................................................... 3-51

Table 3 -45. Findings for Select 2013 TRI Nitrate Compound Dischargers

.............................. 3-53

Table 3 -46. Top Facilities Reporting 2013 TRI Hydrogen Sulfide Releases

............................ 3-54

Table 3

- 47. Wastewater Treatment Steps at Various Tyson Fresh Meats, Inc. Facilities

......... 3-55

Table 3 -48. Mineral Mining Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

.......................................................................... 3-59

Table 3 -49. Mineral Mining Category Top DMR Pollutants

.................................................... 3-60

Table 3 -50. Top 2013 DMR Chloride Discharging Facilities

................................................... 3-61

Table 3 -51. Top 2013 DMR Aluminum Discharging Facilities

................................................ 3-61

Table 3

- 52. SES Assets, LLC Chloride and Aluminum Discharges for 2011 – 2014

............... 3-62

Table 3 -53. Cedar Lake Plant’s Historical and 2013 DMR Monthly Chloride Disc harges

...... 3-63

Table 3 -54. Top 2013 DMR Fluoride Discharging Facilities

.................................................... 3-64

Table 3 -55. PCS Phosphate White Spring’s 2013 DMR Monthly Average Fluoride Discharges

............................................................................................................... 3-64

Table 3 -56. PCS Phosphate White Spring’s Fluoride Discharges for 2011 – 2014

.................. 3-65

Table 3

- 57. NFMM Category TRI and DMR Facility Counts and Discharges Reported for 2009, 2011, and 2013

........................................................................................ 3-67

Table 3 -58. 2013 NFMM Category Top DMR Pollutants

......................................................... 3-68

Table 3 -59. Top 2013 DMR Cadmium Discharging Facilities

.................................................. 3-69

Table 3 -60. Top 2013 DMR Fluoride Discharging Facilities

.................................................... 3-69

Table 3 -61. Nyrstar’s 2013 DMR Monthly Cadmium Discharges

............................................ 3-70

Table 3 -62. Nyrstar’s 2013 DMR Monthly Fluoride Discharges for Outfall 001

..................... 3-71

Table 3 -63. Nyrstar DMR Cadmium and Fluoride Discharges for 2010 – 2014

...................... 3-71

xList of Tables

LIST OF TABLES (Continued)

Page

Table 3 -64. Horsehead DMR Fluoride Discharges for 2010 – 2014

......................................... 3-72

Table 3 -65. Ore Mining Category TRI and DMR Facility Counts an d Discharges Reported in 2009, 2011, and 2013

.......................................................................... 3-75

Table 3 -66. Ore Mining Category Top DMR Pollutants

........................................................... 3-76

Table 3 -67. Ore Mining Category Top TRI Pollutants

.............................................................. 3-77

Table 3 -68. Top 2013 DMR Copper Discharging Facilities

...................................................... 3-78

Table 3

- 69. Northshore Mining’s DMR Co pper Discharges from 2010 – 2014

....................... 3-78

Table 3 -70. Top 2013 DMR Selenium Discharging Facilities

.................................................. 3-79

Table 3 -71. Top 2013 DMR Radium-226 Discharging Facilities

............................................. 3-80

Table 3 -72. Top 2013 DMR Arsenic Discharging Facilities

..................................................... 3-81

Table 3 -73. Top Facilities Reporting 2013 TRI Arsenic and Arsenic Compound Releases

..... 3-81

Table 3 -74. Kennecott Utah’s DMR and TRI Arsenic Discharges from 2007 – 2014

.............. 3-81

Table 3 -75. Kennecott Utah’s 2013 DMR Arsenic Discharges

................................................. 3-82

Table 3 -76. Top Facilities Reporting 2013 TRI Lead and Lead Compound Releases

.............. 3-83

Table 3 -77. TRI Lead and Lead Compound Releases from 2009 – 2013

................................. 3-84

Table 3 -78. Top Facilities Reporting 2013 TRI Silver and Silver Compound Releases

........... 3-84

Table 3 -79. OCPSF Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

.............................................................................................. 3-90

Table 3 -80. OCPSF Category Top DMR Pollutants

.................................................................. 3-91

Table 3 -81. OCPSF Category Top TRI Pollutants

.................................................................... 3-92

Table 3 -82. Top 2013 DMR PACs Discharging Facilities

........................................................ 3-93

Table 3 -83. Top Facilities Reporting 2013 TRI PACs Releases

............................................... 3-93

Table 3

- 84. Sasol’s 2013 DMR PACs Discharges

.................................................................... 3-94

Table 3 -85. ExxonMobil’s PACs TRI Releases, 2009 – 2013

.................................................. 3-95

Table 3 -86. Top 2013 DMR Total Residual Chlorine Discharging Facilities

........................... 3-96

Table 3 -87. Top 2013 D MR Hexachlorobenzene Discharging Facilities

.................................. 3-97

Table 3 -88. Sasol’s 2013 DMR Hexachlorobenzene Discharges

.............................................. 3-97

Table 3

- 89. Sasol’s Hexachlorobenzene DMR Discharges, 2010 – 2014

................................. 3-98

xiList of Tables

LIST OF TABLES (Continued)

Page

Table 3 -90. 2013 DMR Hexachlorobenzene Discharges for Nalco Company

.......................... 3-98

Table 3 -91. Top 2013 DMR TCDD Discharging Facilities

...................................................... 3-99

Table 3 -92. Top Facilities Reporting 2013 TRI Dioxin and Dioxin-like Compound

Releases

.................................................................................................................. 3-99

Table 3 -93. Dow Chemical Company TRI Dioxin and Dioxin-like Compound Releases,

2008 – 2013

.......................................................................................................... 3-100

Table 3 -94. Sasol’s Dioxin and Dioxin-like Compound TRI Releases, 2009 – 2013

............. 3-101

Table 3 -95. Top Facilities Reporting 2013 TRI Carbon Disulfide Releases

........................... 3-101

Table 3 -96. Viskase Corporation Carbon Disulfide TRI Indirect Releases, 2007 – 2013

....... 3-102

Table 3-97. Innovia Films Inc. Carbon Disulfide DMR and TRI Releases, 2007 – 2013

....... 3-103

Table 3 -98. Viscofan USA, Inc. Carbon Disulfide TRI Indirect Releases, 2007 – 2013

........ 3-103

Table 3 -99. Top Facilities Reporting 2013 TRI Nitrate Compound Releases

......................... 3-104

Table 3 -100. DSM Chemicals NA, Inc. Nitrate Compound TRI Releases, 2010 – 2013

....... 3-104

Table 3 -101. DuPont Chambers Works Nitrate Compounds TRI Releases, 2010 – 2013

...... 3-105

Table 3 -102. Pulp and Paper Category TRI and DMR Facility Counts and Discharges Reported for 2009, 2011, and 2013

...................................................................... 3-112

Table 3 -103. Pulp and Paper Category Top TRI Pollutants

.................................................... 3-113

Table 3 -104. Top Facilities Reporting 2013 TRI Hydrogen Sulfide Releases

........................ 3-114

Table 3 -105. Top Facilities Reporting 2013 TRI Dioxin and Dioxin-Like Compounds

Releases

................................................................................................................ 3-116

Table 3 -106. Domtar Paper Dioxin and Dioxin-Like Compound Releases for 2009 – 2013

.. 3-117

Table 3 -107. Boise White Paper LLC Dioxin and Dioxin-Like Compound Concentrations

.. 3-117

Table 3 -108. Rayonier Dioxin and Dioxin-Like Compound Releases for 2009, 2011,

2013

...................................................................................................................... 3-118

Table 3 -109. Resolute Dioxin and Dioxin-Like Compound Releases for 2009, 2011, 2013

.. 3-119

Table 3 -110. 2002

– 2013 M anganese and Manganese Compound Releases in TRI

................ 3-120

Table 3 -111. Textiles Category TRI and DMR Facility Counts and Discharges Reported

in 2009, 2011, and 2013

....................................................................................... 3-123

Table 3 -112. 2013 Textiles Category Top DMR Pollutants

.................................................... 3-124

xiiList of Tables

LIST OF TABLES (Continued)

Page

Table 3 -113. Mohawk Industries’ 2013 DMR Monthly Toxaphene Discharges Reported

for Outfall 001

...................................................................................................... 3-125

Table 3 -114. Mohawk Industries 2013 DMR Notes for Toxaphene Discharges

.................... 3-125

Table 3 -115. Top 2013 DMR Sulfide Discharging Facilities

.................................................. 3-126

Table 3 -116. King America’s 2013 DMR Monthly Sulfide Discharges Reported for

Outfall 001

............................................................................................................ 3-126

Table 4

- 1. Current Rechargeable Batteries and Common Uses

.................................................. 4-3

Table 4

- 2. Rechargeable Battery Types used in Hybrid and Electric Vehicles

........................... 4-7

Table 4 -3. Properties of MBT

.................................................................................................... 4-20

Table 4

- 4. Facilities Reporting MBT Releases to TRI in 2013

................................................. 4-21

xiiiList of Figures

LIST OF FIGURES Page

Figure 4-1. Simplified Battery Diagram (adapted from Northwestern University, 2014)

........... 4-3

Figure 4-2. Simplified Schematic of a Redox Flow Battery (Salkind et al., 2003)

..................... 4-5

Figure 4- 3. Basic Manufacturing Processes for Electronic Crystals (U.S. EPA, 1983)

............ 4-15

xiv1— Introduction to EPA’s 2015 Annual Review

1. I NTRODUCTION TO EPA’ S 2015 A NNUAL R EVIEW

Effluent limitations guidelines and standards (ELGs) are an essential element of the nation’s clean water program, which was established by the 1972 amendments to the Federal Water Pollution Control Act (which then became known as the Clean Water Act (CWA)). ELGs are technology- based regulations used to control industrial wastewater discharges. EPA issues ELGs for new and existing sources that discharge directly to surface waters, as well as those that discharge to publicly owned treatment works (POTWs ) (indirect dischargers ). ELGs are applied

in discharge permits as limit s to the pollutants that facilities may discharge. To date, EPA has established ELGs to regulate wastewater discharges from 58 point source categories. This regulatory program substantially reduces industrial waste water pollution and continues to be a critical aspect of the effort to clean the nation ’ s waters.

In addition to developing new ELGs, the CWA requires EPA to revise existing ELGs when appropriate. Over the years, EPA has revised EL Gs in response to developments such as advances in treatment technology and changes in industry processes. To continue its efforts to reduce industrial wastewater pollution and fulfill CWA requirements, EPA conducts an annual review and effluent guidelines planning process. The annual review and planning process has three main objectives: (1) to review existing ELGs to identify candidates for revision, (2) to identify new categories of direct dischargers for possible development of ELGs , and (3) to identify new categories of indirect dischargers for possible development of pretreatment

standards.

This report documents EPA’s methodology and findings from its 2015 Annual Review. The 2015 Annual Review consisted of three components:

• Conducting a toxicity ranki ng analysis (TRA) using data from discharge monitoring reports (DMRs) contained in the Integrated Compliance Information System for the National Pollutant Discharge Elimination System (ICIS -NPDES), and the Toxics Release Inventory (TRI). The TRA identifies and prioritizes for further review those industrial categories whose pollutant discharges pose the greatest hazard to human

health and the environment relative to other categories. EPA evaluates the relative hazard of these discharges by applying toxic we ighting factors (TWFs) to the annualpollutant discharges to calculate the total discharge of toxic pollutants as toxicweighted pound equivalents (TWPE). See Section 2 of this report for details of the

TRA.

• Conducting preliminary category reviews for the industrial categories with the highest hazard potential (in terms of TWPE) identified from the TRA. EPA uses the preliminary category reviews to further evaluate and identify categories that may warrant additional review and study or possible effluent guidelines and standards revision or development. See Section 3 of this report for details on the individual preliminary category reviews.

• Reviewing additional industrial categories and pollutants brought to EPA’s attention through public and stakeholder comments and input, to evaluate recent changes within the industries as well as potential new pollutant releases to the environment through industrial wastewater discharge that may not be adequately regulated by

1-11— Introduction to EPA’s 2015 Annual Review

current ELGs . See Section 4 of this report for details on EPA’s review of additional industrial categories and pollutants.

The 2015 Annual Review supports EPA’s Office of Water’s Preliminary 2016 Effluent Guidelines Program Plan (Preliminary 2016 Plan) (U.S. EPA, 2016 ). The Prelim inary 2016 Plan, pursuant to Section 304(m) of the CWA, provides background on the CWA and ELG planning process, summarizes the results of the 2015 Annual Review, and details EPA’s proposed actions and follow-up. The Preliminary 2016 Plan also identifies any industrial categories newly selected for effluent guidelines rulemaking, and provides a schedule for such rulemaking.

1.1 Introduction References

1. U.S. EPA. 2015. Final 2014 Effluent Guidelines Program Plan . Washington, D.C. (July). EPA-821-R-15-001. EPA- HQ

- OW -2014-0170-0210.

2. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan . Washington,

D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN 08208.

1-22— EPA’s 2015 Tox icity Rankings Analysis (TRA)

2. EPA’ S 2015 T OX ICITY R ANKINGS A NALYSIS (TRA)

Consistent with its odd year review methodology, 1 EPA perform ed a TRA of all industrial categories, including those subject to existing effluent limitations guidelines and

standards ( ELGs ) and those not currently regulated b y ELGs

, to identify and prioritize for further review categories whose pollutant discharge s may pose the greatest hazards to human health or

the environment relative to other categories

.

As a first step in the TRA, EPA downloaded 2013 industrial rankings data from the “Top Industrial Dischargers of Toxic Pollutants” are a of the DMR Pollutant Loading Tool (the Loading Tool) 2 . EPA used 2013 data to form the basis for the TRA because they represented the most recent and complete set of industrial wastewater discharge data available at the time of the

2015 Annual Review. Section 2.1 describes the industrial rankings data sources and their

limitations in detail.

Next, EPA performed a quality review of the data, as discussed in Section 2.2, in order to identify and correct data errors and understand potential outliers. As described in Section 2.3, EPA imported the corrected data into a set of static databases to create the final 2015 point source category rankings. Section 2.4 presents the final 2015 point source category rankings, which EPA used to prioritize categories for further preliminary review. Section 3 of this report presents the methodology for, and findings from, EPA’s preliminary category reviews.

2.1 Data Sources and Limitations

The Loading Tool estimates the load of pollutants discharged from specific facilities using a combination of discharge monitoring report (DMR) data, from the Integrated

C ompliance Information System for the National Pollutant Discharge Elimination System ( ICIS

NPDES ), and Toxics Release Inventory ( TRI ) data

. 3 TRI and DMR data do not identify the effluent guideline(s) applicable to a particular facility. However, TRI clas sifies facilities by North American Industry Classification System (NAICS) code, while ICIS

- NPDES classifies facilities by Standard Industrial Classification (SIC) code s. Thus, the Loading Tool relate s each SIC and NAICS code to an industrial category. 4 It also assigns a relative toxic weight ing factor (TWF) to the estimated loads from each facility to calculate the total discharge of toxic pollutants as toxic weighted pound equivalents (TWPE). 5

The Loading Tool then sums the TWPE for each facility in an industrial category to calculate a total TWPE per category and ranks the categories according to their total TWPE discharge d. The Loading Tool’s industrial rankings are calculated using the same methodology

1 EPA’s odd year review methodology is further discussed in the Preliminary 2016 Effluent Guidelines Program

Plan (Preliminary 2016 Plan) (U.S. EPA , 2016).

2 See the DMR Pollutant Loading Tool , which presents the top industrial dischargers of toxic pollutan ts. EPA used this section of the DMR Pollutant Loading Tool to inform its 2015 TRA.

3 Consistent with the methodology presented in the Technical Support Document for the Annual Review of Existing Effluent Guidelines and Identification of Potent ial New Poin t Source Categories (2009 Screening

- Level Analysis (SLA) Report (U.S. EPA, 2009).

4 For more information on how EPA related each SIC and NAICS code to an industrial category, see Section 5.0 of

the 2009 SLA Report ( U.S. EPA, 2009 ).

5 See a full overview o f the DMR Pollutant Loading Tool

.

2-12— EPA’s 2015 Tox icity Rankings Analysis (TRA)

presented in the 2009 Screening Level Analysis (S LA ) Report (U.S. EPA, 2009), except for one change to the selection of DMR measurement data from ICIS

- NPDES

. 6 The calculations specific to the Loading Tool are documented in the Technical Users Background Document for the Discharge Monitoring Report ( DMR) Pollutant Loading Tool (U.S. EPA, 2012a ).

This section provides general information on the use and limitations of the data sources the Loading Tool uses to generate the industrial rankings. These data sources include:

• SIC codes

• N AICS codes

• TWFs

• DMR data from ICIS

- NDPES

• TRI data

2.1.1 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 firs t two digits represent the major industry group.

• The third digit represents the industry group.

• The fourth digit represents the industry.

For example, major SIC code 26 (Paper and Allied Products) includes all pulp, paper, and paperboard manufacturing ope rations. 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.

Although developed to track economic data, the SIC system is used by many government agencies, including EPA, to promote data comparability. In the SIC system, ea ch 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.

ICIS -NPDES includes one four-digit SIC code, reflecting the principal activity causing the discharge at each facility.

EPA does not define the applicability of its ELGs by SIC code, but by industry and process desc riptions. For this reason, regulations for an individual point source category may apply to one SIC code, multiple SIC codes, or a portion of the facilities in a SIC code. Therefore,

to use data that identify facilities by SIC code, E PA mapped each four-digit SIC code to an appropriate point source category, as summarized in the “SIC/Point Source Category Crosswalk”

6 The Loading Tool incorporates one change to the selection of DMR measurement data from ICIS

- NPDES,

described in Section 3.1 of the 2013 Annual Effluent Guidelines Review Report , which deviates from the methodology described in the 2009 SLA Report (U.S. EPA, 2014a).

2-22— EPA’s 2015 Tox icity Rankings Analysis (TRA)

table (Table C -1 in Appendix C). The Loading Tool applies this crosswalk to generate the industrial rankings.

EPA has not established national ELGs for all SIC codes. Table C -2 in Appendix C lists the SIC codes for which facility discharge data are available in ICIS -NPDES, but for which EPA could not identify an applicable point source category. For a more detailed discussio n, see Section 6 of the 2009 SLA Report (U.S. EPA, 2009).

2.1.2 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 remedy deficiencies of the SIC code system. The nomenclature and forma t of NAICS and SIC codes are presented in Table 2-1.

Table 2-1. Nomenclature and Format of NAICS and SIC Codes

NAICS SIC

2

- digit Sector Letter Di vision

3

- digit Subsector 2

- digit Major g roup
4

- digit Industry g roup 3

- digit Industry g roup
5

- digit NAICS i ndustry 4

- digit Industry

6

- digit U.S.

- specific i ndustry N/A N/A

For example, below are the SIC and NAICS codes for the folding paperboard box manufacturing industry.

In the SIC code system, the classification is less stratified:

• D: Manufacturing;

− 26: Paper and Allied Paper Products;

o 265: Paperboard Containers and B oxes ;

 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;

 32221: Paperboard Container 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 activi ty, which is determined by its principal product or group of products. An establishment may have activities in more than one NAICS code.

2-32— EPA’s 2015 Tox icity Rankings Analysis (TRA)

EPA does not define the applicability of its ELGs by NAICS code, but by industry and process descriptions. For this reason, regulations for an individual point source category may apply to one NA IC S code, several NA IC S codes, or a portion of the facilities in one NAI CS code. Therefore, to use data that identify facilities by NAI CS code, EPA mapped each six

- digit

NAICS code to an appropriate point source category, as summarized in the “NAICS/Point Source Category Crosswalk” table ( Table C -3 in Appendix C ). The Loading Tool applies this crosswalk to generate the industrial rankings.

There are some NA ICS codes for which EPA has not established national ELGs. Table C-4 in Appendix C lists the NAICS codes for which faci lity discharge data are available in TRI, but for which EPA could not identify an applicable point source category. For a more detailed

d iscussion, see Section 6 of the 2009 SLA Report (U.S. EPA, 2009).

2.1.3 Toxic Weighting Factors

As part of the Effluent Guidelines Program, EPA developed a wide variety of tools and methods to evaluate effluent discharges. Among these tools is a Toxics Databas e 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 uses the

Toxics Database to calculate a pollutant- specific TWF that accounts for differences in toxicity across pollutants and allows comparison of mass loadings of different pollutants. The Loading

Tool uses TWFs to calculate a “toxic

- equivalent s” loading (in pounds- equivalent s per year). The Loading Tool multiplies a mass loading of a pollutant in pounds per year by the TWF to derive a

TWPE

. The Toxic Weighting Factors Methodology memorandum discuss es the use and development of TWFs in detail (U.S. EPA, 2012c).

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 chose copper, a metal commonly detected and removed from industrial effluent, as the benchmark pollutant (U.S. EPA, 2012c ). During the 2015 Annual Review, EPA did not revise any TWFs or develop TWFs for chemicals that had not previously had them. 7

2.1.4 Data from ICIS- NPDES

EPA has used DMR data reported to EPA’s Permit Compliance System ( PCS ) as a part of its TRA of existing effluent guidelines since the 2003 Annual Review (68 FRN 75515). Since 2002, EPA has been modernizing PCS by creating a new data system

, ICIS

- NPDES. ICIS

NPDES automate s entering, updating, and retrieving NPDES data, and t rack s permit issuance, permit limits, monitoring data, and other data pertaining to facilities regulated by the NPDES program under the CWA . In 2006, states began transitioning their DMR reporting from PCS to

ICIS

- NPDES . The transition was completed in 2012. By 2012, all states and U.S.

territories/tribes h ave completely migrated to ICIS

- NPDES , except New Jersey; thus, New

7 See documentation maintained within the DMR Loading Tool , for a list of chemicals and their associated TWFs developed by EPA to date.

2-42— EPA’s 2015 Tox icity Rankings Analysis (TRA)

Jersey has not supplied EPA with required data about its CWA discharge program (U.S. EPA, 2015a). Therefore, the 2013 DMR data do not in clude data from New Jersey. See Section 2.1.4.2

for more information on this limitation.

More than 250,000 industrial facilities and 17,000 wastewater treatment plants have NPDES individual or general permits 8 for wastewater discharges to waters of the U.S . 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. Permitting authorities classify discharges as major by assessing the follo wing six characteristics (U.S. EPA, 2010):

• Toxic pollutant potential

• Discharge flow: stream flow ratio

• Conventional pollutant loading

• Public health impact

• Water quality factors

• Proximity to coastal waters

Facilities that are major discharge r s must report compliance with NPDES permit requirements via monthly DMRs submitted to the permitting authority. The permitting authority enters the reported DMR data into ICIS -NPDES, including pollutant concentrations and quantit ies, and identifies any permit violations. During the 2015 Annual Review, EPA identified approximately 6,0 00 facilities (including sewerage systems) classified as major dischargers with

DMR data in 2013.

Minor discharger s may or may not adversely impact receiving water if not controlled.

Facilities that are minor discharger s must report compliance with NPDES permit requirements via monthly DMRs submitted to the permitting authority; however, EPA does not require the permitting authority to enter data in the ICIS

- NPDES database. For this reason, the ICIS- NPDES

database includes discharge data only for a limited set of minor discharge rs. During the 2015 Annual Review, EPA identified approximately 23,000 facilities (including sewerage systems)

classified as minor dischargers with DMR da ta in 2013.

Parameters in ICIS

- NPDES include water quality parameters (such as pH and temperature), specific chemicals, conventional parameters (such as biochemical oxygen demandand total suspended solids), and flow rates. Although other pollutants may be discharged, ICISNPDES contain s data only for the parameters identified in the facility’s NPDES permit. Facilities typically report monthly average concentrations or quantities per day discharged, but may report daily, quarterly, or yearly pollutant measurements, depending on monitoring requirements stated in their permit.

A NPDES individual permit is written to reflect site

- specific conditions of a single discharger based on information submitted by that discharger in a permit application. An individual permit is unique to that discharger. NPDES general permits are written to cover multiple dischargers with similar operations and types of discharges based on the permit writer’s professional knowledge of those types of activities and discharges (U.S. EPA, 2010).

2-5 82— EPA’s 2015 Tox icity Rankings Analysis (TRA)

2.1.4.1 Utility of ICIS

- NPDES Data

The data collected in the ICIS

- NPDES data system are particularly useful for the ELG planning process for the following reasons:

• ICIS

- NPDES is national in scope, including data from 49 states and 21 U.S.

territories/tribes.

• Discharge reports included in ICIS

- NPDES are based on effluent chemical analysis

and metered flows using known analytical methods.

• ICIS -NPDES includes discharge data for faci lities in any SIC code.

2.1.4.2 Limitations of ICIS

- NPDES Data

Limitations of the data collected in the ICIS -NPDES data system include the following:

• Because New Jersey has not supplied EPA with required discharge monitoring data about its CWA discharge program, the 2013 DMR data do not include discharge monitoring data from this state (U.S. EPA, 2015a). For reference, in 2011, New Jersey accounted for approximately 94,000 TWPE out of a total of 8,930,000 TWPE, with discharges primarily from the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) (40 CFR Part 414) and Petroleum Refining (40 CFR Part 419) point source categories.

• The data system contain s 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.

• Data from minor discharges are not comprehensive.

• The data system does not include data characterizing discharges from industrial

facilities to publicly owned treatment works ( POTWs ).

• In some cases, the data system does not identif y the type of wastewater (e.g., process
wastewater, stormwater, noncontact cooling water) being discharged ; therefore, total flow rates reported 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 external outfalls, and ICIS -NPDES may double- count a facility’s discharge. In other cases, an outfall may be labeled as an internal monitoring point,

and ICIS- NPDES may not include all of a facility’s discharge.

• Facilities may not always report the duration of discharge in their DMRs; pollutant loadings are calculated using continuous discharge assumptions (365 days per year), which may overestimate some toxic releases.

2-62— EPA’s 2015 Tox icity Rankings Analysis (TRA)

• Facilities are identified by SIC code, not point source category. For some SIC codes, it may be difficult or impossible to identify the correct point source category associated with the reported wastewater discharges

. 9

• ICIS

- NPDES w as designed as a permit compliance tracking system and does not contain production information that would benefit the review of discharges compared to production- based limitations.

• ICIS -NPDES data may be entered into the data systems manually, which leads to data

entry errors.

• In ICIS -NPDES data may be reported as an average quantity, maximum quantity, average concentration, maximum concentration, and/or minimum concentration. For many facilities and pollutants, average quantity values are not provided. In th ese cases, EPA estimates 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).

Despite these limitations, EPA determined that th e ICIS

- NPDES data summarized in the Loading Tool were usable for the 2015 TRA and prioritization of the toxic- weighted pollutant loadings discharged by industrial facilities. The ICIS- NPDES database remain s the only data source quantifying regulated pollutants discharged directly to surface waters of the U.S

.

2.1.5 Data from TRI

Section 313 of the Emergency Planning and Community Right- to

- Know Act requires

facilities meet ing specified thresholds to report their annual releases and other waste management activities for listed toxic chemicals to the TRI . Facilities must report the quantities of toxic chemicals recycled, collected, combusted for energy recovery, treated for destruction, or otherwise disposed of. Fac ilities must complete a separate report for each chemical manufactured, processed, or used in excess of the reporting threshold. For the 2015 TRA, EPA used TRI data for reporting year 2013 because they were the most recent data available when the review began.

A facility must meet three criteria to be required to submit a TRI report for a given reporting year:

1. NAICS Code Determination . The facility’s primary six

- digit 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 ( 71 FR 32464). The TRI

covered industries include six -digit NAICS codes under the following NAICS subsectors or industry groups (U.S. EPA, 2015b) :

− 212, Mining

− 221, Utilities

− 31–33, Manufacturing

9 ICIS

- NPD ES includes a data field for applicable ELGs; however, completion of this field is not required and it is typically not populated.

2-72— EPA’s 2015 Tox icity Rankings Analysis (TRA)

− All other miscellaneous manufacturing (includes 1119, 1131, 2111, 4883, 5417, 8114)

− 424, Merchant Wholesalers, Non-durable Goods

− 425, Wholesale Electronic Markets and Agent Brokers

− 511, 512, 519, Publishing

− 562, Hazardous waste

− Federal fa cilities

2. Number of E mployees . Facilities must have 10 or more full-time employees or their equivalent (i.e., a total of 20,000 hours or greater worked in a year) . EPA defines a

“full

- time e mployee ” as 2,000 hours per year of full- time equivalent employment (there are several exceptions and special circumstances that are well defined in the TRI reporting instructions) (40 CFR Part 372.3).

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. It must determine whether it manufactures, proc esses, 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, bioaccum ulative , 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, mercury compounds are considered PBT chemicals. The TRI reporting guidance requires any facility that manufactures, processes, or otherwise uses 10 grams or more of mercury 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 offsite locations, (e.g., POTWs, commercial waste disposal facilities).

Facilities reporting to TRI are not required to sample and analyze waste stream s 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 c ode, 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, TRI guidance indicates that for dioxins and dioxin- like compounds,

non- detects should be treated as zero.

TRI allow s facilities to report releases as specific numbers or as ranges, if appropriate. Specific estimates are encouraged if data are available t o ensure the ir accuracy; however, TRI allows facilities to report releases in the following ranges: 1 to 10 pounds, 11 to 499 pounds, and

2-82— EPA’s 2015 Tox icity Rankings Analysis (TRA)

500 to 999 pounds. If a facility reports a range for a direct or indirect discharge, TRI uses the

mid dle of the range for the TRI output (U.S. EPA, 2013a).

2.1.5.1 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

.

• TRI includes releases of many toxic chemicals, not just those in facility discharge permits.

2.1.5.2 Limitations of TRI Data

For purposes of ELG planning, limitations of the data collected in TRI include the following:

• Small establishments (fewer 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 . Due to TRI guidance, they may overstate releases, especially at facilities with large wastewater

flows.

• Certain chemical s ( e.g., polycyclic aromatic compounds ( PACs ), dioxin and dioxinlike compounds) are reported as a class, not as individual compounds. Because the individual compounds in most classes vary widely in their toxic effects, the potential toxicity of chemical r eleases 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

associated with the source of the toxic wastewater releases.

• TRI only requires facilities to report certain chemicals; therefore, all pollutants discharged from a facility may not be captured.

Despite these limitations, EPA determined that the TRI data presented in the Loading

Tool were usable for the 201 5 T RA and prioritization of the toxic- weighted pollutant loadings discharged by industrial categories.

2.2 Data Quality Review

EPA evaluated the quality of the 2013 DMR and TRI data from the Loading Tool. This evaluation considered data completeness, comparability, accuracy, and reasonableness. The

2-92— EPA’s 2015 Tox icity Rankings Analysis (TRA)

Environmental Engineering Support for Clean Water Regulations Programmatic Quality Assurance Project Plan (PQAPP) describes the quality objectives in more detail (ER G, 2013).

2.2.1 Data Quality Review and Corrections to the 2013 DMR Data

To evaluate completeness, comparability , accuracy, and reasonableness of the 2013 DMR data, EPA performed the following checks:

Completeness

. To evaluate the data’s completeness, EPA com pared counts of facilities reporting 2011 and 2013 DMR data in the Loading Tool, as shown in Table 2-2.

As mentioned in Section 2.1.4.2, New Jersey has not converted to the current DMR reporting system (ICIS

- NPDES) , and thus has not supplied EPA with required data about its

CWA discharge program for the reporting year 2013 (U.S. EPA, 2015a). As a result, the 2013 DMR data are not complete. However, because the numbers of major and minor facilities reporting DMR data are otherwise similar between 2011 and 2013, EPA determined that the 2013 DMR dataset contained in the Loading Tool was usable for the 2015 Annual Review.

Table 2-2. Results of 2013 DMR Data Completeness Check

Number of Major Industrial Dischargers Number of Minor Industrial Dischargers

D MR 2011 DMR 2013 DMR 2011 DMR 2013
1,908 1,938 14,530 16,420

Sources: DMRLTOutput2013_v1 and DMRLTOutput2011_v1.

Comparability . EPA compared the 2011 and 2013 DMR data from the Loading Tool 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 appropriate for facility discharges with the highest TWPE. If the comparison was unavailable (e.g., if the pollutant had not been previously reported), EPA contacted the facility or permitting authority

.

Accuracy and reasonableness. To evaluate the accuracy and reasonableness of the 2013 DMR data, EPA reviewed the facility and pollutant discharges that had the greatest impact on total category loads and industrial rankings in the Loading Tool , based on toxic-weighted pounds discharged . For each identified facilit y, EPA used the following steps to review the accuracy and

reasonableness of the loads calculated from ICIS

- NPDES data:

1. Re viewed database corrections from previous TRAs to determine whether corrections made during previous reviews should apply to the 2013 DMR discharges.

2. Reviewed 2013 DMR facility SIC code information (including the facility’s NPDES permit and permit fact sheet) to determine if the facility was assigned to the point source category that best applied to the majority of its discharges, or identified pollutant- level point source category assignments where facilities have operations subject to more than one point source category.

3. Reviewed the Loading Tool’s 2013 DMR facility loading calculations, then compared Loading Tool data to data available in EPA’s online Envirofacts data system, or from the facility’s NPDES permit and permit fact sheet to verify the data. EPA then

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calculated annual pollutant loads and compared the results to the 201 3 Loading Tool output data to verify the accuracy of the calculated facility loads.

4. Reviewed ICIS

- NPDES pipe description s available in E PA’s online Envirofacts data system, ICIS -NPDES supporting tables, or t he facility’s NPDES permit and permit fact sheet to identify monitored pollutant discharges that are:

− In termittent (e.g., t idal, seasonal, or occurring after a storm).

− Internal monitoring locations from which wastewater is combined with other waste streams and monitored again, resulting in double-counting loads.

− Not representative of category discharges (e. g., stormwater runof f from

nonprocess areas, non contact cooling water, or wastewater related to operations in another point source category).

5. Reviewed ICIS

- NPDES output data for pollutants that should be excluded from the 2013 DMR load calculation because they are in units th at cannot be converted to quantities (e.g., kilograms per day (kg/d)) or concentrations (e.g., milligrams per liter (mg/L)). 10

6. Contacted the state permitting authority or facility to determine if the data were reported and transcribed correctly.

7. Used the Error Report functionality built into the Enforcement and Compliance History Online (ECHO) website 11 to report identified DMR data errors to the data stewards for evaluation and correction, to ensure that the underlying DMR data pulled

into ICIS

- NPDES a re updated.

Table 2-3 summarizes EPA’s initial quality review of the 2013 DMR data. Table D -1 in Appendix D lists a ll of the specific corrections EPA made to the 2013 DMR data as a result of its data quality review, prior to generating the final 2015 point source category rankings. Note that

EPA conducted f urther quality reviews of the 2013 DMR data, and made additiona l data

corrections

, as part of the more detailed preliminary category reviews ( presented in Section 3) of this report.

10 Table A-5 in Appendix A in the Technical Users Background Document for the Discharge Monitoring Report (DMR) Pollutant Load ing Tool lists pollutants excluded from the Loading Tool (U.S. EPA, 2012a). Examples include: temperature, pH, fecal coliform, and whole effluent toxicity.

11 See EPA’s Enforcement Compliance History Online

.

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Table 2-3. Summary of 2013 DMR Facility Data Quality Review

Facility Location Point Source Category Pollutant(s) in Question Review Findings Action Taken/Database

Correction Equity Group

Eufaula Div

LLC Eufaula, AL Meat and Poultry

Products Cadmium, Copper, Nickel, Zinc Facility confirmed a concentration error for metals as part of the 2013 Annual Review;

concentrations are three orders of magnitude larger than actual values (U.S. EPA, 2014a). December 2013 concentrations for cadmium, copper, nickel, and zinc are three orders of magnitude larger than other months. Divide December 2013 cadmium, copper, nickel, and zinc concentrations by
1,000.

Nubay Mining,

LLC Galatia, IL Coal Mining Flow EPA identified a unit error for 2011 flow values as part of the 2013 Annual Review.

Flow values we re three orders of magnitude larger than actual values (U.S. EPA, 2014a).

March 2013 flow value for outfall 009 is

also three orders of magnitude larger than

other months. Divide March 2013 flow value by 1,000.

PRASA WTP

Sabana Grande Sabana Grande,

PR Drinking Water

Treatment Flow EPA corrected an outlier flow value for February 2011 for outfall 001 as part of the 2013 Annual Review by dividing by 10,000

to match other months (U.S. EPA, 2014 a ).

December 2013 flow value for outfall 001 is two orders of magnitude higher than other

mon ths. Divide December 2013 flow value by 100.

US Steel Mon Valley Works

– Edgar

Thomson Plant Braddock, PA Iron and Steel Manufacturing Flow EPA originally identified a flow correction as part of the 2007 Annual Review (U.S. EPA, 2007); EPA again incorporated the flow correction for the facility as part of the 2013 Annual Review ( U.S. EPA, 2014 a).

The 2013 flow values reviewed for the 2015 Annual Review do not reflect the facility

flow correction. Incorporated facility flow

correction and revised 2 013 loads for all pollutants.

Celanese LTD Bay City Plant Bay City, TX Organic Chemicals, Plastics, and Synthetic Fibers Total Residual Chlorine Facility misidentified outfall 001 in DMR data; the outfall is an internal outfall. EPA

marked this outfall as an internal outfall as part of the 2013 Annual Review (U.S. EPA,

2014 a). Marked outfall 001 as an

internal outfall.

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Table 2-3. Summary of 2013 DMR Facility Data Quality Review

Facility Location Point Source Category Pollutant(s) in Question Review Findings Action Taken/Database

Correction

Aventis Institute, WV Organic PCBs The facility confirmed 2011 PCB s Add BDL indicator to 2013 Cropscience Chemicals, concentrations were missing a below PCB s discharges.

USA Plastics, and Synthetic Fibers detection limit (BDL) indicator as part of the 2013 Annual Review (U.S. EPA, 2014a). EPA determined 2013 PCB s concentrations were also missing the BDL

indicator. Ed Arey & Buckhannon, Timber Flow Facility reported incorrect units for the 2009 Divided 2013 flow values

Son s, Inc. WV Products Processing and 2011 flow values, making the flow values 1,000,000 times larger than previous years (U.S. EPA, 2014a). 2013 flow values are also 1,000,000 larger than previous

years. by 1,000,000 to match order of magnitude of previous

years.

Evergreen Recycling and Disposal Northwood, OH Unassigned Waste Facility Nickel Facility reported incorrect units for the 2013

nickel concentrations. Divided 2013 nickel concentrations by
1,000,000 ,000

. Koppers, Inc. Gainesville, FL Timber

Products Processing 2,3,7,8

- TCDD State contact confirmed the 2013 DMR TCDD data for outfall 001 (Akhavein, 2014). EPA also confirmed the facility is a Superfund Site by the CERCLIS number. Facility re

- assigned to PSC

code 999

– Superfund Sites.

Resolute FP

US Inc. a Calhoun, TN Pulp, Paper and Paperboard Mercury Facility con tact provided corrected 2013 mercury concentrations (Schwartz and Wiegand, 2014). Revised 2013 mercury

concentrations.

Black Oak

Landfill Hartvil le, MO Landfills Silver, Selenium State contact confirmed that 2013 DMR

silver and selenium concentrations are in units of μg/L, not mg/L (Sappington, 2014). Divided 2013 silver and selenium concentrations by
1,000.

Graftech Anmoore, WV Metal Finishing Arsenic, Aluminum Facility c ontact provided revised 2013 Revised 2013 arsenic

International arsenic concentrations for outfall 026 and concentrations for outfall Holdings Inc. flow values for outfalls 026, 036, 037, and 038 (Williams, 2014). 026 and flow values for outfalls 026, 036, 037, and

038. BASF Corp Wyandotte, MI Organic Mercury The March 2013 mercury concentration is Divide the March 2013 Chemicals, Plastics, and Synthetic Fibers six orders of magnitude higher than the other reported concentrations for outfall

002. concentration by 1,000,000.

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Table 2-3. Summary of 2013 DMR Facility Data Quality Review

Facility Location Point Source Category Pollutant(s) in Question Review Findings Action Taken/Database

Correction

Decker Coal

Co. Decker, MT Coal Mining Arsenic State contact confirmed that the December

2013 arsenic concentration for outfall 002 is

non

- detect (Self, 2014). Zeroed December 2013

arsenic concentration f or outfall 002.

Aluminum Co.

of America

Badin Badin, NC NFMM Cyanide State contact confirmed that 2013 cyanide concentrations are in units of μg/L, not mg/L (Allocco, 2014). Divided 2013 cyanide concentrations by 1,000.

Mosaic Donaldsonville, Fertilizer Fluoride, Cadmium, Facility is a phosphate fertilizer No data corrections . The Phosphates LA Manufacturing Aluminum manufacturer, which is subject to 40 CFR facility does not represent

Co. Faustina Part 418, Subpart A, Phosphate the Fertilizer Manufacturing

Plant Subcategory. However, because the facility is located in Louisiana, EPA determined it is exempt from Subpart A and permit limits are based on facility

- specific permitting

. Category because it is exempt from 40 CFR Part

418.

Honeywell Hopewell, VA Organic Hexachlorobenzene Facility contact confirmed that 2013 Zeroed 2013

International Chemicals, hexachlorobenzene discharges are below hexachlorobenzene

Inc. Plastics, and Synthetic Fibers detection (Parker, 2013). discharges.

DuPont Washington, Organic Hexachlorobenzene Confirmed with DMR data provided by the Zeroed 2013 Washington WV Chemicals, West Virginia Department of hexachlorobenzene

Works Plastics, and Synthetic Fibers Environmental Protection that the hexachlorobenzene discharges are below

detecti on. discharges.

Ergon West Virginia Newell, WV Petroleum Refining Sulfide Facility contact provided a revised July 2013 sulfide concentration (Stanton, 2015). Revised July 2013 sulfide

concentration. Shenango Inc. Pittsburgh, PA Iron and Steel Manufacturing Benzo(a)pyrene August 2013 benzo(a)pyrene quantity is three orders of magnitude larger than other months and previous years data. Divided August 2013 benzo(a)pyrene quantity by
1,000. Feldspar

Monticello

Plant Monticello, GA Mineral Mining and Processing Flow November 2013 flow value is five orders of magnitude larger than other months. Divided November 2013 flow by 100,000.

United Park City Mines

Co. Park City, UT Ore Mining and Dressing Mercury State contact confirmed that 2013 mercury concentrations are in units of ng/L, not mg/L (Thiele, 2015). Divided October 2013 mercury concentration by
1,000,000.

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Table 2-3. Summary of 2013 DMR Facility Data Quality Review

Facility Location Point Source Category Pollutant(s) in Question Review Findings Action Taken/Database

Correction Clearon Corp South Charleston, WV Inorganic

Chemicals Manufacturing Flow March and May 2013 flow values are three orders of magnitude larger than other

months in 2013 and previous year s’ data. Divide March and May 2013 flow values by 1,000.

Clean Harbors Baton Rouge

LLC Baton Rouge,

LA Centralized

Waste

Treatment Hexachlorocyclohexane Confirmed hexachlorocyclohexane discharges are below detection with DMR

data from Louisiana (LA DEQ, 2015)

. Zeroed 2013 hexachlorocyclohexane discharges.

Henderson City Landfill Henderson, KY Landfills No data corrections. Facility contact confirmed the outlier

cadmium concentration in March 2013 for outfall 001; the facility had a leachate tank flood on the sampling date for this outfall. Therefore, the sample was not a representative sample for the outfall (Anderson, 2015). No data corrections.

US Ecology

Texas Inc. Robstown, TX Centralized

Waste

Treatment Flow Facility contact confirmed the outlier flow value in September 2013 for outfall 004; the facility had a large rainfall event in September 2013 and the facility’s flow

meter was faulty. Therefore, the sample was not a representative sample for the outfall (Camarena, 2015).

a This facility is referred to as Abibow US Inc. in previous annual review reports. In 2012, Abibow US Inc. became Resolute FP US Inc. (Resolute, 2012)

.

2-152— EPA’s 2015 Tox icity Rankings Analysis (TRA)

2.2.2 Data Quality Review and Corrections to the 2013 TRI Data

To evaluate completeness, comparability, accuracy, and reasonableness of the 2013 TRI data, EPA performed the following checks:

Completeness. To evaluate the data’s completeness, EPA compared counts of facilities reporting 2011 and 2013 TRI data in the Loading Tool, as shown in Table 2-4. Because the number of facilities reporting is similar be tween 2011 and 2013, EPA determined that the 2013 TRI dataset contained in the Loading Tool was useable for the 2015 Annual Review.

Table 2-4. Results of the 2013 TRI Data Completeness Check

Total Number of Facilities Reporting to TRI Number of Facilities Reporting Discharges Greater

than Zero to TRI

TRI 2011 TRI 2013 TRI 2011 TRI 2013

18,391 19,601 6,855 6,936

Sources: TRILTOutput2013_v1 and TRILTOutput2011_v1

.

Comparability. EPA compared the 2013 TRI data from the Loading Tool to 2011 TRI data from the Loading Tool to identify annual pollutant loadings that differed more than the

year

- to

- year variation of other chemicals and facilities. EPA used this comparison to determine if

corrections were appropri ate for facility discharges with the highest TWPE. If the comparison was unavailable (e.g., the pollutant was not previously reported), EPA contacted the facility

.

Accuracy and reasonableness. EPA reviewed facility and pollutant releases that had the greatest impact on total category loads and rankings in terms of TWPE released . For the identified facilities, EPA used the following steps:

1. Revi ewed database corrections from previous TRAs to determine whether corrections made during previous reviews should apply to the 2013 TRI releases.

2. Reviewed releases reported to TRI for other reporting years (i.e., 2000, 2002, 2003, 2004, 2005, 2007, 2008, 2009, and 2011) and compared them to releases reported to TRI for reporting year 2013 to identify trends in the disc harges.

3. Reviewed 2013 TRI NAICS code information to determine if the facility was assigned to the point source category that best applied to the majority of its discharges, or identified pollutant- level point source category assignments where

facilities ha ve operations subject to more than one point source category.

4. Reviewed 2013 DMR data, if available, and hand-calculated annual pollutant loads to

compare to releases reported to TRI for reporting year 2013.

5. Verified that the Loading Tool excluded pollutant s that should not have an associated pollutant load (e.g., yellow or white phosphorus). See Section 3.4.2 in EPA’s 2011 Annual Effluent Guidelines Review Report (U.S. EPA, 2012b).

6. Contact ed the facility to verify whether the pollutant releases are reported correctly.

Through the accuracy review, EPA identified that hydrogen sulfide water releases accounted for approximately 40 percent of the total 2013 TRI TWPE (U.S. EPA , 2015c;

2-162— EPA’s 2015 Tox icity Rankings Analysis (TRA)

TRILTOutput2013_v0 ). EPA further evaluated the quality of the hydrogen sulfide data, as hydrogen sulfide is a relatively new pollutant reported to TRI that EPA has not previously considered in its annual reviews and because the data constitutes a large percentage of the TWPE reported to TRI in 2013. EPA evaluated data so urces and contacted facilities, summarized in

Table 2-5 . EPA determined that the data for indirect releases are overestimated based on the estimation techniques used

. As a result, EPA identified and adjusted the indirect releases of hydrogen sulfide reported to TRI to account for POTW removals ( U.S. EPA , 2015c ). See Section

2.2.2.1 for more details on EPA’s investigation and adjustment of the 2013 hydrogen sulfide data reported to TRI.

Table 2-5 summarizes EPA’s quality review of the 2013 TRI data. Table D -2 in Appendix D of this report lists all of the specific corrections EPA made to the 2013 TRI data as a result of its data quality review, prior to generating the f inal 2015 point source category rankings. Note that EPA conducted further quality review of the 2013 TRI data and identified additional data corrections as part of the more detailed preliminary category reviews presented in Section 3 of this report.

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Table 2-5. Summary of 2013 TRI Facility Data Quality Re view

Facility Location Point Source Category Chemical(s) in Questions Review Findings Action

Taken/Database

Correction International Paper Georgetown, SC Pulp, Paper, and Paperboard Dioxin and dioxin

like compounds Facility contact confirmed that the TCDD value reported to the 2013 TRI was not detected (Schwartz & Wiegand, 2014). Zeroed dioxin and

dioxin

- like compound

releases.

ExxonMobil

Chemical Baton Rouge Chemical

Plant Baton Rouge,

LA Organic Chemicals, Plastics, and Synthetic Fibers PACs As part of the 2013 Annual Review, facility

contact confirmed the 2011 TRI PAC releases were estimated from monthly sampling results that were non

- detect; therefore, 2011 releases were zeroed (U.S. EPA, 2014a). 2013 rele ases are similar to

2011. Zeroed 2013 PAC

releases.

Mountain State

Carbon Follansbee, WV Iron and Steel Manufacturing PACs Facility contact confirmed an error in their 2013 PAC release reported to TRI and provided corrected data (Smith, 2015). Revised PAC release.

USS Gary Works Gary, IN Iron and Steel Manufacturing Lead and lead compounds Facility contact confirmed an error in their 2013 lead and lead compound release reported to TRI and provided corrected data (Armentrout, 2014). Revised lead and le ad compound release.

Valero Refining Memphis, TN Petroleum Refining Hydrogen Sulfide Facility contact confirmed the 2013 hydrogen sulfide release and stated that the release was calculated based on monthly sampling results (Brewer, 2014). No data corrections.

Tesoro Refining Salt Lake City,

UT Petroleum Refining Hydrogen Sulfide Facility contact confirmed that the 2013 hydrogen sulfide release was calculated based on sampling results (Ibarra, 2014). No data corrections.

Smithfield Farmland Corp Denison, IA Meat and Poultry

Products Hydrogen Sulfide Facility contact confirmed that the 2013 hydrogen sulfide release was calculated based on sampling results (Murphy, 2014). No data corrections.

Smithfield Farmland Corp Clinton, NC Meat and Poultry

Products Hydrogen Sulfide Facility contact confirmed that the 2013 hydrogen sulfide release was calculated based on sampling results (Murphy, 2014). No data corrections.

Smithfield Farmland Corp Smithfield, VA Meat and Poultry

Products Hydrogen Sulfide Fa cility contact confirmed that the 2013 hydrogen sulfide release was calculated based on sampling results (Murphy, 2014). No data corrections.

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Table 2-5. Summary of 2013 TRI Facility Data Quality Re view

Facility Location Point Source Category Chemical(s) in Questions Review Findings Action

Taken/Database

Correction Tyson Fresh Meats

Inc. Logansport, IN Meat and Poultry

Products Hydrogen Sulfide Facility contact confirmed the 2013 hydrogen sulfide release and stated that the release was calculated based on sampling results (Dirks, 2015) No data corrections.

JR Simplot Co Grand Forks, ND Canned and

Preserved Fruits and Vegetable Processing Hydrogen Sulfide Facility contact conf irmed the 2013 hydrogen sulfide release and stated that the release was calculated based on sampling results (Prigge, 2014). No data corrections.

SAPPI Cloquet

LLC Cloquet, MN Pulp, Paper, and Paperboard Hydrogen Sulfide Facility contact confirmed an error in 2013 hydrogen sulfide releases and provided corrected data (Schwartz & Wiegand, 2014). Revised hydrogen

sulfide release.

Rocktenn CP LLC Hopewell, VA Pulp, Paper, and Paperboard Hydrogen Sulfide Facility contact confirmed the 2013 hydrogen sulfide release and stated that the release was based on factors provided by the trade association (Schwartz & Wiegand, 2014). No data corrections.

2-192— EPA’s 2015 Tox icity Rankings Analysis (TRA)

2.2.2.1 Updates to the 2013 TRI Hydrogen Sulfide Data

During its review of the 2013 TRI d ata, E PA noted that hydrogen sulfide water releases accounted for approximately 40 percent of the total 2013 TRI T WPE (U.S. EPA , 2015c; TRILTOutput2013_v0 ). Hydrogen sulfide has not historically been included or evaluated as part of EPA’s previous annual reviews, but is now included due to recent changes in TRI reporting requirements.

Hydrogen sulfide was added to the TRI list of toxic chemicals in a final rule published on December 1, 1993. On August 22, 1994, EPA issued an Administrative Stay of the reporting requirements for hydrogen sulfide to evaluate issues brought to the Agency's attention after promulgation of the final rule. These issues concerned the human health effect basis for the listing and the Agency's use of exposure analyses in TRI listing decisions. Although the final rule listing hydrogen sulfide under section 313 of the Emergency Planning and Community Right- to

- Know Act (EPCRA ) remained in force, the stay deferred the reporting requirements for hydrogen sulfide while EPA completed its further evaluation (76 FR 64022).

From its further evaluation of the environmental toxicity of hydrogen sulfide, EPA

determined that available data indicate th at water with concentrations of more than 2.0 ug/L undissociated hydrogen sulfide would constitute a long- term hazard to aquatic organisms despite its fate under certain environmental conditions (76 FR 64022). As a result, on October 17, 2011,

EPA announce d it was lifting the Administrative Stay of the reporting requirements for hydrogen sulfide under Section 313 of EPCRA (76 FR 64022). Facilities were required to report environmental releases of hydrogen sulfide to TRI beginning with the reporting year 2012, including releases to water.

EPA’s review of the hydrogen sulfide data reported to TRI for the 2015 Annual Review identified five industrial point source categories where hydrogen sulfide contributed a substantial portion of the category TWPE. Table 2-6 lists these point source categories and the percentage of their total category TWPE attributed to hydrogen sulfide. Table 2-7 summar izes the reported 2013 TRI hydrogen sulfide releases by release type (i.e., direct and indirect releases) ( U.S. EPA, 2015c).

Table 2-6. T op 2013 TRI Point Source Categories with Reported Hydrogen Sulfide

Water Releases

Point Source Category Total TWPE H 2 S TWPE Percentage of Total Category TWPE

Attributed to H 2 S

430

– Pulp, Paper and Paperboard 4,280,000 2,140,000 50%

419

– Petroleum Refining 580,000 191,000 33%

406

– Grain Mills 276,000 274,000 99%

432

– Meat and Poultry Products 213,000 169,000 79%

407

– Canned and Preserved Fruits and Vegetables Processing 68,700 64,200 93%

Total TRI TWPE for Top Categories with Reported Hydrogen Sulfide Releases 5,420,000 2,840,000 52%

Total TRI TWPE 7,1 6 0,000 2,870 ,000 40%

Source: TRILTOutput2013_v0

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Table 2-7. Summary of 2013 TRI Hydrogen Sulfide Water Releases by Release Type

Type of Release Number of Facilities Reporting H 2 S Releases Pounds of Reported H 2 S

Releases H 2 S TWPE

Direct 146 513,000 1,440 ,000

Indirect 26 511,000 1,43 0 ,000

Total H 2 S Releases 172 1,024,000 2,870 ,000

Total TRI TWPE 7,1 6 0,000

Source: TRILTOutput2013_v0

As shown in Table 2-6, hydrogen sulfide releases from five point source categories account for 99 percent of the hydrogen sulfide TRI TWPE and 40 percent of the total TRI

TWPE. Table 2-7 shows that the total reported quantity of hydrogen sulfide released (in pounds) is equally distributed between direct and indirect releasing facili ties. The data also indicate that a higher number of direct discharging facilities (146) reported releasing hydrogen sulfide as compared to indirect discharging facilities (26).

EPA further evaluated the quality of the hydrogen sulfide data, as hydrogen s ulfide is a relatively new pollutant reported to TRI that EPA has not previously considered in its annual reviews, and because the data account for a large percentage of the TWPE reported to TRI in 2013. As a first step in assessing the quality of the hydrogen sulfide data and its utility for the 2015 Annual Review, EPA evaluated whether the reported releases for indirect discharging facilities take into account any treatment and removal that is likely to occur at the receiving

POTW. As discussed in Section 3.4 of Technical Users Background Document for the Discharge Monitoring Report (DMR) Pollutant Loading Tool (U.S. EPA, 2012a), the Loading Tool adjusts, if possible, the TRI pollutant releases reported by indirect discharging facilities to account for pollutants remov ed at POTWs prior to release to receiving waters . Table C-1 in Appendix C of

the Technical Users Background Document for the DMR Pollutant Loading Tool lists the POTW

removals used for the TRI chemicals reported as transferred to POTWs (U.S. EPA, 2012a ). The adjusted releases are incorporated into the TRI industrial rankings data presented in the “Top Industrial Dischargers of Toxic Pollutants” are a of the Loading Tool.

EPA did not identify a removal specific to hydrogen sulfide in Table C-1 in Appendix C

of the Technical Users Background Document for the DMR Pollutant Loading Tool ; therefore, it determined that the 2013 TRI hydrogen sulfide data reported for indirect releasing facilities do not account for treatment occurring at POTWs.

Becau se hydrogen sulfide in water readily oxidizes to sulfates and is biologically

oxidized to elemental sulfur under low to neutral pH and well-aerated conditions (U.S. EPA, 1986, WHO, 2003), hydrogen sulfide removal rates at POTWs are likely to be substantial, which would greatly reduce the amounts of hydrogen sulfide ultimate ly released to receiving waters. Therefore, EPA determined it was necessary to identify a removal efficiency that it could apply

to the indirectly release d hydrogen sulfide data reported in TRI, to account for hydrogen sulfide

remov ed at POTW s.

EPA reviewed data sources historically used to develop POTW removals to establish a POTW removal rate for hydrogen sulfide. These data sources include:

2-212— EPA’s 2015 Tox icity Rankings Analysis (TRA)

• EPA’s National Risk Management Research Labor atory (NRMRL) Treatability Database (U.S. EPA, 2004).

• POTW data incorporated into recent ELGs.

• POTW removals incorporated into EPA’s Office of Pollution Prevention and Toxics (OPPT) Risk Screening Environmental Indicators (RSEI) model. (Note: EPA relies on the RSEI model for POTW removals only in the absence of actual performance data).

EPA has not made recent updates to the NRMRL Treatability Database, nor has EPA promulgated any more recent ELGs that regulate the release of hydrogen sulfide; therefore, t hese data sources did not provide any new information regarding POTW removals of hydrogen

sulfide.

The RSEI model primarily relies on POTW removals obtained from the NRMRL Treatability Database, but also relies on Syracuse Research Corporation’s (SRC’s) Sewage Treatment Plant Fugacity Model (STPWIN) for those chemicals not in the NRMRL Treatability Database (U.S. EPA, 2013b). EPA did not identify any recent updates to the NRMRL Treatability Database; therefore, EPA focused its investigation on POTW removal rates for hydrogen sulfide that may be available in the STPWIN model.

EPA downloaded the latest version of SRC’s STPWIN model (U.S. EPA, 2013b), which is integrated into EPA’s Estimation Program Interface (EPI) Suite 12 (EPI Suite Version 4.11 (November 2012)). The EPI Suite is a suite of physical/chemical property and environmental fate estimation programs developed by the EPA’s OPPT and SRC. The STPWIN model in particular predicts the removal of chemical s by typical ac tivated sludge- based sewage treatment plan ts

. The Hydrogen Sulfide Releases Reported to the Toxics Release Inventory (TRI) in 2013 memorandum discusses the details of the STPWIN model ( U.S. EPA, 2015c ).

To estimate a hydrogen sulfide POTW removal, EPA ente red the chemical properties for hydrogen sulfide into the STPWIN and used the default option for the degradation half- life of hydrogen sulfide, which provides a conservative removal rate. The resulting POTW removal for hydrogen sulfide calculated by the STPWIN model is 98.64 percent.

To gather additional data on POTW removals of hydrogen sulfide and confirm the POTW removal rate calculated by the STWPIN model, EPA contacted Lafayette Wastewater Treatment Plant, in Lafayette, IN, a POTW that receives wastewa ters from industrial facilities reporting releases of hydrogen sulfide to TRI. EPA also contacted the City of Tolleson Wastewater Treatment Plant, in Tolleson, AZ, which reported hydrogen sulfide discharges on its

DMR.

The Lafayette Wastewater Treatment Pl ant did not have any treatment data for hydrogen sulfide and was not concerned about hydrogen sulfide loads received from industrial facilities (Beeler, 2014). The City of Tolleson Wastewater Treatment Plant provided 2013 and 2014 hydrogen sulfide treatment data: raw influent hydrogen sulfide concentrations range from 0.23 –

0.742 mg/L, and the treated effluent concentrations are 0.01 mg/L or less (Tyler, 2014). These

12 See the EPI Suite

– Estimation Program Interface for more information and to download the model.

2-222— EPA’s 2015 Tox icity Rankings Analysis (TRA)

data indicate a hydrogen sulfide percent removal at the POTW ranging from 95.7 to 98.7 per cent. This suggests that EPA can reasonably apply the estimated removal rate of 98.64 percent obtained from the STPWIN model to adjust the indirect releases of hydrogen sulfide reported to

TRI.

Thus, EPA applied a POTW removal rate of 98.64 percent to the hydrogen sulfide release data reported to TRI in 2013 and used the adjusted releases in the development of the final 2015 point source category rankings. Table B -1 in Appendix B lists the facilities with indirect hydrogen sulfide releases adjusted to accou nt for POTW removals. Incorporating the POTW

removal rate for the hydrogen sulfide releases reduces the total 2013 hydrogen sulfide TRI
TWPE to 19,500.

EPA evaluated the data quality associated with direct releases of hydrogen sulfide reported to TRI in 2 013 as part of its preliminary reviews, specifically for the Grain Mills, Meat and Poultry Products, and Pulp, Paper, and Paperboard point source categories (see Sections 3.3,
3.6, and 3.11 of this report , respectively).

2.3 Generation of the Final 2015 Point Source Category Rankings

EPA incorporated the corrected data, discussed in Sections 2.2.1 and 2.2.2, into a set of databases, DMRLTOutput2013_v1 and TRILTOutput2013_v1

, designed to preserve the integrity of the data and subsequent analyses supporting the 2015 Annual Review. These databases are static, while the Loading Tool is based on a dynamic dataset that can change over time. (For example, evolving reporting requirements may affect the population of facilities reporting to

ICIS

- NPDES and facilities may report data corrections as they are identified ). Tables E -1 and E2 in Appendix E present the TRI and DMR point source category rankings by TWPE from the TRIOutput2013_v1 and DMRLTOutput2013_v1 databases, respectively. Additiona lly, Tables E

- 3

and E-4 in Appendix E present the six -digit NAICS code rankings by TWPE from TRIOutput2013_v1 and the four-digit SIC code rankings by TWPE from DMRLTOutput2013_v1 , respecti vely. Tables E

- 5 and E -6 in Appendix E present the chemical rankings by TWPE from TRIOutput2013_v1 and DMRLTOutput2013_v1 , respectively.

To generate the final combined 2015 point source category rankings, EPA consolidated the 2013 DMR and TRI point source category rankings into one dataset using the following

steps:

• EPA combined the two lists of point source categories by adding each category’s DMRLTOutput2013-_v1 TWPE and TRILTOutput2013-_v1 TWPE. 13

• EPA ranked the point source categories based on the total DMRLTOutput2013-_v1

and TRILTOutput2013- _v1 TWPE.

In addition, EPA eliminated from further consideration the results for the following:

13 Combining DMR and TRI loads may result in “double

- counting” of chemi cal discharges if a facility reported to

both ICIS

- NPDES and TRI, and “single

- counting” of chemicals reported in only one of the data sources. Further, the combined TWPE do not count chemicals that may be discharged but are not reported to ICIS

- NPDES or TR I.

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• Discharges from industrial categories for which EPA promulgated or revised ELGs within the past seven years

. See Section 2.3.1 for details on these categories.

• Discharges from facilities that require a NPDES permit but do not fall into an existing or new point source category or subcategory (e.g., Superfund sites). See Section 2.3.2

for details on these facilities.

The final combined 2015 point source category rankings represent the results of the 2015 TRA and are presented in Section 2.4

.

2.3.1 Categories for Which EPA Has Recently Promulgated or Revised ELGs

In its 2015 TRA and subsequent preliminary category reviews, EPA did not consider

industrial c ategories for which ELGs were recently established or revised but are not yet fully implemented. In general, EPA removes an industrial point source category from further consideration during a review cycle if EPA established or revised the category’s ELGs within seven years of the a nnual r eviews. This seven -year period allows time for the ELGs to be incorporated into NPDES permits. Table 2-8 lists the categories EPA excluded from the 2015 Annual Review due to this seven-year period.

Table 2-8. Point Source Categories That Have Under gone Recent Rulemaking

40 CFR Part Point Source Category Date of Rulemaking

450 Construction and Development December 1, 2009 Revised March 6, 2014

449 Airport Deicing May 16, 2012

423 Steam Electric Power Generating September 30, 2015

In addition, EPA did not consider in its 2015 TRA and subsequent preliminary category reviews industrial categories or subcategories that are subjects of an ongoing rulemaking process. These include the Canned and Preserved Seafood Category (covering the A laskan seafood processing subcategories ) , dental p ractices (specifically, relating to the discharge of mercury found in dental amalgam), and the Oil and Gas Extraction Category, specifically relating to the discharge of pollutants from unconventional oil and gas extraction facilities. See Section 5 of the Preliminary 2016 Plan (U.S. EPA, 2016) for details on the rulemaking status of these categories.

Industrial categories or subcategories for which EPA had recently considered developing or revising ELGs were not reviewed by EPA in its final 2015 point source category rankings and TRA. This is because EPA thoroughly reviewed these categories separately from the annual review process. This includes a subcategory of facilities that produce chlorine and chlorinated hydrocarbons (CCH) that fall into the Organic Chemicals, Pesticides, and Synthetic Fibers (40 CFR Part 414) and Inorganic Chemicals Manufacturing (40 CFR Part 415) point source categories. Similarly, EPA did not review coalbed methane extraction in the Oil and Gas Extraction Category (40 CFR Part 435). See Section 5 of EPA’s Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014) for details on EPA’s determinations related to these categories.

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2.3.2 Discharges Not Categorizable

EPA identified some discharges that are not categorizable into existing or new point source categories or subcategories. As part of the 2011 Annual Review, EPA reviewed high TWPE discharges from a Superfund site (Auchterlonie, 2009; U.S. EPA, 2012). Direct discharges from Superfund sites, whether made on site or off site, are subject to NPDES permitting requirements (U.S. EPA, 1988a, 1988b). For the reasons discussed below

, EPA

continued to determine that these discharges cannot be categorized into a single point source

category

, and excluded these TWPE from the final 2015 point source category rankings.

EPA determined that discharges from Super fund sites are too varied to be categorized into a single point source category. In particular, they vary by:

• Contaminants (e.g., metals, pesticides, dioxin).

• Treatment technologies (e.g., air stripping, granular activated carbon, chemical/ultraviolet oxidation, aerobic biological reactors, chemical precipitation)

.

• Types of facilities causing groundwater contamination (e.g., wood treatment facilities, metal finishing and electroplating facilities, drum recycling facilities, mines, mineral processing facilities, radium processing facilities).

• In addition, the duration and volume of Superfund site direct discharges vary significantly due to differences in aquifer characteristics and in the magnitude, fate, and transport of contaminants through aquifers and vadose zones.

Currently, permit writers for Superfund sites determine technology- based effluent limits using their best professional judgment. The permit must also call for more stringent effluent

limitations , if necessary, to comply with state water quality standards. EPA finds that the current

site -specific, best professional judgment approach is workable and flexible within the context of a Superfund cleanup (U.S. EPA, 2012).

2.4 Results of the 2015 Toxicity Rankings Analysis

Table 2-9 presen ts the final 2015 combined point source category rankings that support

EPA’s 2015 TRA and Annual Review. The data in the table take into account all corrections and updates discussed in Sections 2.2.1 and 2.2.2. Table 2-9 also reflects the removal of any categories and discharges , as discussed in Section 2.3. As described in Section 3, EPA used these rankings to prioritize categories for further preliminary review.

2-255

10

15

20

25

30 2— EPA’s 2015 Tox icity Rankings Analysis (TRA)

Table 2-9 . Final 2015 Combined Point Source Category Rankings

PSC

Code PSC Description TRI TWPE DMR TWPE Total TWPE Cumulative Percentage

of Total TWPE Rank

430 Pulp, Paper a nd Paperboard 2,190,000 321,000 2,510,000 30.1% 1

NA Drinking W ater T reatment 0 892,000 892,000 40.8% 2

415 Inorganic Chemicals Manufacturing a 794,000 94,200 888,000 51.4% 3

419 Petroleum Refining 419,000 242,000 661,000 59.4% 4

414 Organic Chemicals, Plastics a nd Synthetic Fibers a 333,000 301,000 634,000 67.0%

418 Fertilizer Manufacturing 8,500 568,000 577,000 73.9% 6

420 Iron a nd Steel Manufacturing 84,600 188,000 273,000 77.2% 7

421 Nonferrous Metals Manufacturing 34,300 187,000 221,000 79.8% 8

406 Grain Mills 179,000 22,300 201,000 82.2% 9

445 Landfills 235 166,000 166,000 84.2%

435 Oil and Gas Extraction 0 163,000 163,000 86.2% 11

436 Mineral Mining a nd Processing 4,710 139,000 144,000 87.9% 12

440 Ore Mining a nd Dressing 82,700 57,700 140,000 89.6% 13

433 Metal Finishing 46,900 73,500 120,000 91.0% 14

NA Miscellaneous Foods a nd Beverages 5,030 105,000 110,000 92.3%

410 Textile Mills 2,210 89,500 91,700 93.4% 16

432 Meat a nd Poultry Products 81,500 8,220 89,700 94.5% 17

458 Carbon Black Manufacturing 63,800 0.0998 63,800 95.3% 18

437 Centralized Waste Treatment 2,720 59,700 62,400 96.0% 19

NA Unassigned Waste Facility 13,000 34,000 47,000 96.6%

434 Coal Mining 386 40,200 40,600 97.1% 21

409 Sugar Processing 406 32,500 32,900 97.5% 22

422 Phosphate Manufacturing 2,340 23,900 26,200 97.8% 23

429 Timber Products Processing 22,500 2,980 25,500 98.1% 24

455 Pesticide Chemicals 19,000 3,760 22,700 98.4%

438 Metal Products a nd Machinery 17,400 2,010 19,400 98.6% 26

471 Nonferrous Metals Forming a nd Metal Powders 12,300 1,070 13,400 98.8% 27

424 Ferroalloy Manufacturing 12,100 283 12,400 98.9% 28

428 Rubber Manufacturing 7,410 4,120 11,500 99.0% 29

439 Pharmaceutical Manufacturing 2,670 6,500 9,170 99.2%

468 Copper Forming 5,840 2,440 8,280 99.3% 31

463 Plastics Molding a nd Forming 1,830 6,030 7,860 99.4% 32

464 Metal Molding a nd Casting (Foundries) 3,460 3,890 7,350 99.4% 33

444 Waste Combustors 88.8 7,210 7,300 99.5% 34

2-262— EPA’s 2015 Tox icity Rankings Analysis (TRA)

Table 2-9 . Final 2015 Combined Point Source Category Rankings

PSC

Code PSC Description TRI TWPE DMR TWPE Total TWPE Cumulative Percentage

of Total TWPE Rank

407 Canned a nd Preserved Fruits a nd Vegetables Processing 5,340 660 6,000 99.6% 35

411 Cement Manufacturing 381 5,600 5,980 99.7% 36

405 Dairy Products Processing 4,270 481 4,750 99.7% 37

413 Electroplating 4,620 0 4,620 99.8% 38

469 Electrical a nd Electronic Components 3,030 171 3,200 99.8% 39

NA Printing and Publishing 27.6 2,110 2,140 99.8% 40

425 Leather Tanning a nd Finishing 1,400 506 1,910 99.9% 41

451 Concentrated Aquatic Animal Production 0 1,530 1,530 99.9% 42

457 Explosives Manufacturing 1,130 386 1,520 99.9% 43

467 Aluminum Forming 857 657 1,510 99.9% 44

417 Soap a nd Detergent Manufacturing 1,260 148 1,410 99.9% 45

442 Transportation Equipment Cleaning 71.7 1,270 1,340 100.0% 46

461 Battery Manufacturing 934 227 1,160 100.0% 47

426 Glass Manufacturing 522 133 655 100.0% 48

NA Independent a nd Stand Alone Labs 0 542 542 100.0% 49

460 Hospital s 0 536 536 100.0% 50

443 Paving a nd Roofing Materials (Tars a nd Asphalt) 190 93.6 283 100.0% 51

446 Paint Formulating 94.8 0.437 95.3 100.0% 52

454 Gum a nd Wood Chemicals Manufacturing 26.4 62.4 88.8 100.0% 53

465 Coil Coating 79.1 0.0925 79.2 100.0% 54

NA Food Service Establishments 0 35.5 35.5 100.0% 55

447 Ink Formulating 19.6 0.0103 19.7 100.0% 56

466 Porcelain Enameling 7.82 0 7.82 100.0% 57

NA Tobacco Products 5.32 0.167 5.48 100.0% 58

412 Concentrated Animal Feeding Operations 0 1.49 1.49 100.0% 59

427 Asbestos Manufacturing 0 0.589 0.589 100.0% 60

NA Industrial Laundries 0 0 0 100.0% 61

Total 4,480,000 3,860,000 8,340,000

Sources: DMRLTOutput2013 _v1 and TRILTOutput2013 _v1

. Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable.

a The Organic Chemicals, Pesticides, and Synthetic Fibers and Inorganic Chemicals Manufacturing point source categories do not include d ischarges from facilities that produce chlorine and chlorinated hydrocarbons because EPA recently reviewed this category separately from the annual review process.

2-272— EPA’s 2015 Tox icity Rankings Analysis (TRA)

2.5 References for EPA’s Toxicity Rankings Analysis

1. Akhavein, Keisha. 2014. Telephone and Email Communic ation between Keisha Akhavein, Florida Department of Environmental Protection

, and Kimberly Bartell, Eastern Research Group, Inc. , Re: 2013 DMR TCDD Discharges for Koppers Inc. (November 7). EPA

- HQ

- OW -2015-0665 . DCN 08213.

2. Allocco, Marcia. 2014. Telephone and Email Communication between Marcia Allocco, North Carolina Department of Environmental and Natural Resources and Kimberly Bartell

, Eastern Research Group, Inc. , Re: 2013 DMR Cyanide Discharges for ALCOA in Badin, NC . (November 14). EPA

- HQ

- OW -2015-0665.

DCN 08214.

3. Anderson, Jason. 2015. Telephone and Email Communication between Jason Anderson, SMR Environmental Services, and Kimberly Bartell, Eastern Resea rch Group, Inc., Re: 2013 DMR Cadmium Discharges for Henderson City Landfill. (February 12 ). EPA

- HQ

- OW -2015-0665. DCN 08215.

4. Armentrout, Krista. 2014. Telephone and Email Communication between Krista

Armentrout , US Steel, and Kimberly Bartell, Eastern Research Group, Inc., Re:

2013 TRI Water Releases . ( December 12 ). EPA

- HQ

- OW -2015-0665 . DCN 08216.

5. Auchterlonie, Steve. 2009. Telephone Conversation between Steve Auchterlonie, Front St. Remedial Action, and Chris Krejci, Eastern Research Group, Inc., Re : Verification of magnitude and basis of estimate for dioxin and dioxin- like compounds discharges in PCS. (March 13). EPA- HQ

- OW -2008-0517-0076.

6. Beeler, Brian. 2014. Telephone and Email Communication between Brian Beeler, Lafayette WWTP, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 Hydrogen Sulfide Discharges at POTWs. (December 19). EPA -HQ- OW -2015­

0665. DCN 08217.

7. Brewer, Steve. 2014. Telephone and Email Communication between Steve Brewer, Valero Refining Co., and Kimberly Bartell, Eastern Research Group, Inc. , Re: 2013 TRI Hydrogen Sulfide Discharges for Valero Refining in Memphis, TN. (D ecember 22). EPA

- HQ

- OW -2015-0665. DCN 08218.

8. Camarena, Celina. 2015. Telephone and Email Communication between Celina Camarena, U.S. Ecology Texas Inc., and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Discharges for U.S. Ecology Texas Inc., Robstown,

TX. (February 18). EPA

- HQ

- OW -2015-0665. DCN 08219.

9. Dirks, Kim. 2014. Telephone and Email Communication between Kim Dirks, Tyson Fresh Meats, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 TRI Hydrogen Sulfide Discharges for Tyson Fresh Meats in Hillsdale, IL. (December 22). EPA

- HQ

- OW -2015-0665. DCN 08220.

2-282— EPA’s 2015 Tox icity Rankings Analysis (TRA)

10. ERG. 2013. Eastern Research Group, Inc. Environmental Engineering Support for Clean Water Regulations Programmatic Quality Assurance Project Plan (PQAPP). Chantilly, VA . (May). EPA- HQ

- OW -2010-0824-0229.

11. Ibarra, Sergio. 2014. Telephone and Email Communication between Sergio Ibarra, Tesoro Refining, and Kimberly Bartell, Eastern Research Group, Inc. , Re: 2013 TRI Hydrogen Sulfide Discharges for Tesoro Refining in Salt Lake City, UT. (Decemb er 22). EPA

- HQ

- OW -2015-0665. DCN 08221.

12. LA DEQ. 2015. Louisiana Department of Environmental Quality. Document

Search

. EPA

- HQ

- OW -2015-0665. DCN 08233.

13. Murphy, Susan. 2014. Telephone and Email Communication between Susan Murphy, Smithfield Farmland Corp., and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 TRI Hydrogen Sulfide Discharges for Smithfield Farmland Corp in Denison, IA. (December 22). EPA

- HQ

- OW -2015-0665. DCN 08222.

14. OMB. 1987. Office of Management and Budget. Standard Industrial Classification Manual. Washington, D.C. (Unknown). EPA- HQ

- OW -2008-0517.

15. Parker, Andrew. 2013. Telephone and Email Communication b etween Andrew Parker, Honeywell International Inc., and Kimber ly Bartell, Eastern Research Group, Inc., Re: 2011 DMR Discharges for Honeywell International. (December

13 ). EPA

- HQ

- OW -2014-0170-0031.

16. Prigge, John. 2014. Telephone and Email Communication between John Prigge , JR Simplot, and Kimberly Bartell, Eastern Re search Group, Inc., Re: 2013 TRI Hydrogen Sulfide Discharges for JR Simplot in Grand Forks, ND. (December 22).

EPA

- HQ

- OW -2015-0665. DCN 08223.

17. Resolute FP . 2012. Resolute Forest Products. Legal Entity Name Changes. (May 23). EPA

- HQ

- OW -2015-0665. DCN 08200.

18. Sappington, Amanda. 2014. Telephone and Email Communication between Amanda Sappington, Missouri Department of Natural Resources, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Silver/Selenium Discharges for Black Oak Landfill. (November 14). EPA

- HQ

- OW -2015-0665. DCN 08224.

19. Schwartz, Jerry, and Paul Wiegand. 2014. Telephone and Email Communication between Jerry Schwartz, American Forest and Paper Association, Paul Wiegand,

National Council for Air and Stream Improvement, and Kimberly Bart ell, Eastern Research Group, Inc., Re: 2013 DMR and TRI Pulp and Paper Discharges. ( December ). EPA

- HQ

- OW -2015-0665. DCN 08201.

20. Self, Gina. 2014. Telephone and Email Communication between Gina Self,

Montana Department of Environmental Quality

, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Arsenic Discharges for Decker Coal Co. (November 14). EPA

- HQ

- OW -2015-0665. DCN 08225.

2-292— EPA’s 2015 Tox icity Rankings Analysis (TRA)

21. Smith, Patrick. 2014. Telephone and Email Communication between Patrick Smith, Mountain State Carbon, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 TRI PAC Discharges for Mountain State Carbon. ( December 23 ). EPA

- HQ

OW -2015-0665. DCN 08226.

22. Stanton, Neil. 2015. Telephone and Email Communication between Neil Stanton, Ergon West Virginia and Ki mberly Bartell, Eastern Research Group, Inc. Re: 2013 DMR Sulfide Discharges

. (February 27). EPA

- HQ

- OW -2015-0665. DCN 08227.

23. Thiele, Rhonda. 2015. Telephone and Email Communication between Rhonda Thiele, Utah Department of Environmental Quality and Kimber ly Bartell, Eastern Research Group, Inc. Re: 2013 DMR Discharges for United Park City Mines Co., Park City, UT. (February 13). EPA

- HQ

- OW -2015-0665. DCN 08228.

24. Tyler, David. 2014. Telephone and Email Communication between David Tyler, Tolleson WWTP, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 Hydrogen Sulfide Discharges at POTWs. (December 19). EPA

- HQ

- OW -2015­

0665. DCN 08229.

25. U.S. EPA. 1986. Quality Criteria for Water . Washington, D.C. (M ay ). EPA

- HQ

OW -2004-0032-2619.

26. U.S. EPA. 1988a. CERCLA Compliance with Other Laws Manual: Interim Final. OSWER Publication 9234.1-01. Washington, D.C. (August). Available online at: http://nepis.epa.gov/Exe/ZyPDF.cgi/10001VMG.PDF?Dockey=10001VMG.PDF

. EPA -540-G-89-006.

27. U.S. EPA. 1988b. Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites. OSWER Directive 9283.1- 2. (December). Available online at: http://nepis.epa.gov/Exe/ZyPDF.cgi/2000A58O.PDF?Dockey=2000A58O.PDF

. EPA -540-G-88-003.

28. 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, D.C. (December). EPA

- HQ

- OW -2003-0074-1150.

29. U.S. EPA. 2004. Office of Research and Development. NRMRL Treatability Data
Base, Version 5.0 (EPA 600/C-93/003a). Cincinnati, OH. (February). EPA

- HQ

OW -2015-0665. DCN 08230.

30. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent Guidelines Program Plan . EPA -821-R-07-007. Washington, D.C. (October). EPAHQ

- OW -2006-0771-0819.

31. 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, D.C. (October). EPA- HQ

- OW -2008-0517-0515.

2-302— EPA’s 2015 Tox icity Rankings Analysis (TRA)

32. U.S. EPA. 2010. U.S. EPA NPDES Permit Writers’ Manual. Washington, D.C. (September). EPA -833-K-10-001. EPA

- HQ

- OW -2010-0824-0236.

33. U.S. EPA. 2011. Preliminary Study of Carbon Disulfide Discharges from Cellulose Products Manufacturers . Washington, D.C. (December). EPA -821-R-11-009. EPA

HQ

- OW -2015-0665. DCN 08182.

34. U.S. EPA. 2012a. Technical Users Background Document for the Discharge Monitoring Report (DMR) Pollutant Loading Tool. EPA

- HQ

- OW -2014-0170-0058.

35. U.S. EPA. 2012b. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. (December). EPA-821-R-12-001. EPA- HQ

- OW -2010-0824­

0195.

36. U.S. EPA. 20 12c. Toxic Weighting Factor s Methodology. Washington, D.C. ( March ). EPA -820-R-12-005. EPA

- HQ

- OW -2010-0824-0004.

37. U.S. EPA. 2013a. Toxics Release Inventory Basic Plus Data File Format

Documentation v12 . Washington, D.C. (July 11). EPA- HQ

- OW -2014-0170-0063.

38. U.S. EPA. 2013b. EPA’s Risk -Screening Environmental Indicators (RSEI) Methodology . Washington, D.C. (July). EPA

- HQ

- OW -2015-0665. DCN 08231.

39. U.S. EPA. 2014a. The 2013 Annual Effluent Guidelines Review Report. Washington, D.C. (September). EPA-821-R-14-003. EPA

- HQ

- OW -2014-0170­

0077.

40. U.S. EPA. 2014b. Final 2012 and Preliminary 2014 Effluent Guidelines Program

Plans. Washington, D.C. (September). EPA-820-R-14-001 . EPA

- HQ

- OW -2014­

0170-0002.

41. U.S. EPA. 2015a. Known Data Problems . Enforcement and Compliance History Online. Washington, D.C. (August). EPA

- HQ

- OW -2015-0665. DCN 08236.

42. U.S. EPA. 2015b. Is My Facility’s Six -Digit NAICS Code a TRI- Covered Industry? Toxics Release Inventory Program. Washington, D.C. (February 3). EPA

- HQ -OW2015-0665. DCN 08237.

43. U.S. EPA. 2015c. Memorandum from William Swietlik, U.S. EPA, to Public Docket for the Preliminary 2016 Effluent Guidelines Program Plan, EPA Docket

Number EPA

- HQ

- OW -2015-0665. Re: Hydrogen Sulfide Releases Reported to the Toxics Release Inventory (TRI) in 2013. (October 29). EPA

- HQ

- OW -2015-0665.

DCN 08211.

44. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan. Washington

D.C. (June). EPA-821-R-16-001. EPA

- HQ

- OW -2015-0665. DCN 08208.

45. WHO, 2003. World Health Organization. Hydrogen Sulfide in Drinking- water

. EPA

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2-312— EPA’s 2015 Tox icity Rankings Analysis (TRA)

46. Williams, Bill. 2014. Telephone and Email Communication between Bill Williams, Graftech International and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Arsenic Discharges. (December 17). EPA- HQ

- OW -2015-0665. DCN

08232.

2-323— EPA’s 2015 Preliminary Category Reviews

3.1

— Prioritization of Categories for Preliminary Category Review

3. EPA’ S 2015 P RELIMINARY C ATEGORY R EVIEWS

Based on its toxicity rankings analysis (TRA) described in Section 2 , EPA was able to prioritize for further review those industrial categories whose pollutant discharges potentially pose the greatest hazards to human health or the environment because of their toxicity. To identify these industrial categories, EPA calculated each industrial category’s percent of the total toxic-weighted pound equivalents (TWPE). As shown in Table 2-9, EPA identified and focused its preliminary category reviews on the 18 industrial categories that collectively discharge over 95 percent of the total TWPE.

EPA documented the quality of the data supporting its preliminary review of these

industr ial categories , analyzed how the data could be used to characterize the industrial wastewater discharges, and prioritized the findings for further review. See Appendix A of this report for more information on data usability and quality of the data sources supporting these

reviews

.

3.1 Prioritization of Categories for Preliminary Category Review

EPA excluded Petroleum Refining (40 CFR Part 419) and Metal Finishing (40 CFR Part 433) from further preliminary category review because it is currently conducting ongo ing detailed and preliminary studies of these categories, respectively, as announced in the Final 2014 Effluent Guidelines Program Plan (U.S. EPA, 2015).

Based on its knowledge of the annual review process; data from the Integrated Compliance Information System for the National Pollutant Discharge Elimination System (ICIS

NPDES) , and the Toxics Release Inventory (TRI); and historical data changes, EPA determined that five of the remaining 16 categories did not warrant a detailed preliminary category review as part of the 2015 Annual Review. For these five categories, many of which have been reviewed in detail in prior annual reviews , EPA found that one facility accounts for the majority of the category TWPE. From data available for the 2015 Annual Review, E PA determined that the discharges from that facility either are the result of an easily identifiable error or do not represent the category. These industrial categories, and the reasons for excluding them from further preliminary review, are briefly discus sed in Sections 3.1.1 through 3.1.5, below.

For each of the remaining 11 categories ( of the top 18 that collectively discharge over 95 percent of the total TWPE ), EPA did not initially identify obvious data entry errors and/or determined that the TWPE was attributed to multiple pollutants and facilities. Therefore, EPA completed a preliminary review for these categories to determine whether the discharges warrant further review and study and/or possible revisions to the effluent limitations guidelines and standards. The findings from EPA’s preliminary category reviews ar e discussed in the following subsections of this report. The 11 industrial categories identified for detailed preliminary category reviews are listed below and discussed in Sections 3.2 through 3.12:

• Carbon Black Manufacturing (40 CFR Part 458)

• Grain Mills (40 CFR Part 406)

• Iron and Steel Manufacturing (40 CFR Part 420)

• Land fills (40 CFR Part 445)

3-13— EPA’s 2015 Preliminary Category Reviews

3.1

— Prioritization of Categories for Preliminary Category Review

• Meat and Poultry Products (40 CFR Part 432)

• Mineral Mining and Processing (40 CFR Part 436)

• Nonferrous Metals Manufacturing (40 CFR Part 421)

• Ore Mining and Dressing (40 CFR Part 440)

• Organic Chemicals, Plastics, and Synthetic Fiber s (40 CFR Part 414)

• Pulp, Paper, and Paperboard (40 CFR Part 430)

• Textile Mills (40 CFR Part 410)

3.1.1 Drinking Water Treatment (potential new category)

The Drinking Water Treatment (DWT) Category total TWPE is composed entirely of 2013 discharge monitoring report (DMR) discharges. The 2013 DMR top pollutant is total residual chlorine. EPA identified one facility, Wyndham Sugar Bay Resort in St. Thomas, VI, which accounts for over 80 percent of the 2013 DMR total residual chlorine TWPE for the DWT Category. As part of the 2015 Annual Review, EPA Region 2 confirmed Wyndham Sugar Bay Resort’s total residual chlorine discharges. The 2013 DMR total residual chlorine data is above the facility’s permit limits. Additionally, the facility has submitted intermittent total residual chlorine DMR discharge data from 2010 through 2013. The EPA Region 2 contact stated that data from all facilities in the Virgin Islands is historically incomplete (Louis, 2015). EPA determined that the data do not support the need to review further the DWT Category.

3.1.2 Fertilizer Manufacturing (40 CFR Part 418)

The Fertilizer Manufacturing Category total TWPE is composed almost entirely of DMR discharges , and the top 2013 DMR pollutant is fluoride. EPA identified one facility, Mosaic

Fertilize r LLC, in Uncle Sam, LA, which accounts for 89 percent of the 2013 DMR fluoride TWPE for the Fertilizer Manufacturing Category. Mosaic Fertilizer LLC is a phosphate fertilizer manufacturer. Phosphate fertilizer manufacturers are subject to 40 CFR Part 418 Subpart A, “Phosphate Subcategory.” The facility was r eviewed as part of the 2010, 2011, and 2013 Annual Reviews. During those reviews, EPA determined that, in accordance with 40 CFR Part 418, the facility is exempt from Subpart A and that permit limits ar e based on facility

- specific permitting (U.S. EPA 2011, 2012, 2014). Further, fluoride discharges for the facility have de creased from discharge years 2011 to 2013 (534,000 TWPE in 2011, 490,000 TWPE in 201 3). Therefore, EPA

makes a similar finding as previous annual reviews: Mosaic Fertilizer LLC does not represent the Fertilizer Category because it is exempt from 40 CFR Part 418 (see 52 FR 28428, July 29, 1987). EPA determined that the data do not support the need to review further the Fertilizer Manufacturing Category.

3.1.3 Inorganic Chemicals Manufacturing (40 CFR Part 415)

For the Inorganic Chemicals Manufacturing (Inorganic Chemicals) Category, the 2013 TRI TWPE accounts for 89 percent of the combined DMR and TRI TWPE. As a result, EPA focused on 2013 TRI data. The top 2013 TRI pollutant is cadmium and cadmium compounds. EPA determined that one facility, PCS Nitrogen Fertilizer LP, in Geismar, LA, accounts for over 99 percent of the 2013 TRI cadmium and cadmium compounds TWPE for the Inorganic

Che micals Category. As part of the 2015 Annual Review, EPA contacted the facility. The facility contact confirmed the 2013 TRI cadmium and cadmium compound releases and stated

3-23— EPA’s 2015 Preliminary Category Reviews

3.1

— Prioritization of Categories for Preliminary Category Review

that the source of the metals in the wastewater was from the raw materials used in the phosphoric acid production processes, which contain low levels of naturally occurring metals. For one of three outfalls, the facility estimates cadmium and cadmium compound releases using monthly concentrations multiplied by the annual flow. This outfa ll comprises the majority of the TRI cadmium and cadmium compound releases reported to TRI and consists of inactive storage pile runoff and excess stormwater runoff. For the other two outfalls, the facility bases estimations on

historical concentrations mu ltiplied by the annual flow. All three of the outfalls used in determining the cadmium and cadmium compound releases to TRI are internal outfalls (Hopper, 2014). The facility has a NPDES permit, with cadmium monitoring only requirements for one of

the inte rnal outfalls only. Since the cadmium and cadmium compound releases from PCS Nitrogen Fertilizer are from internal outfalls, they are not accounted for in the facility’s DMR loadings. The facility is in the process of obtaining a revised permit. EPA determined that the data do not represent the Inorganic Chemicals Category.

3.1.4 Miscellaneous Foods and Beverages (potential new category)

The Miscellaneous Foods and Beverages Category total TWPE is composed almost entirely of DMR discharges and the top 2013 DMR pollutant is sulfide. EPA identified one facility, Bacardi Corporation, in Catano, PR, which accounts for over 97 percent of the 2013 DMR sulfide TWPE for the Miscellaneous Foods and Beverages Category. EPA previously reviewed sulfide discharges from Bacardi Corporation as part of the 2010 Annual Review. At that time, EPA determined that the facility’s sulfide discharges were unique t o the facility and certain pollutants, such as sulfide, are discharged below permit limits and combined with waste streams from adjacent wastewater treatment plants prior to reaching surface water (U.S. EPA, 2011). As part of the 2015 Annual Review, EPA Region 2 confirmed Bacardi Corporation’s 2013 DMR sulfide discharges. The EPA Region 2 contact also stated that the facility’s wastewater treatment and permit limits have not changed in recent years and the sulfide

concentrations result from molasses used to make rum (Lantner, 2015). The 2013 DMR sulfide discharges meet the facility’s permit limits. For these reasons, EPA determined that the sulfide discharges from Bacardi Corporation are unique to the facility and do not represent the

Miscellaneous Foods and Beverages Category.

3.1.5 Oil and Gas Extraction (40 CFR Part 435)

For the Oil and Gas Extraction (Oil and Gas) Category, the 2013 DMR TWPE accounts for 100 percent of the combined DMR and TRI TWPE. As a result, EPA focused on 2013 DMR data. The top 2013 DMR pollutant is sulfide, accounting for over 93 percent of the total DMR TWPE for the Oil and Gas Category. EPA determined that one facility, Maverick Spring, in Cody, WY, accounts for over 99 percent of the 2013 DMR sulfide TWPE. EPA determined that

this f acility is a conventional oil and gas extraction facility, and therefore, further reviewed the facility as part of the 2015 Annual Review. 14 The facility discharges sulfide from outfall 001; the facility’s NPDES permit includes monitoring only requiremen ts for sulfide from outfall 001

. As part of the 2015 Annual Review, Region 8 confirmed Maverick Spring’s 2013 DMR sulfide

14 EPA recently reviewed coal bed methane facilities separately from the annual review process. Additionally, EPA is currently engaged in a rulemaking process for unconventional oil and gas extraction facilities. Therefore, coal

bed methane and unconvent ional oil and gas extraction facilities were not further reviewed in EPA’s review of the Oil and Gas Extraction Category.

3-33— EPA’s 2015 Preliminary Category Reviews

3.1

— Prioritization of Categories for Preliminary Category Review

discharges and indicated that the facility’s permit is currently under revision (Lozano, 2014). Additionally, Maverick Spring’s sulfide discharges have increased from 2011 to 2013. EPA determined that the data do not support the need to further review the Oil and Gas Extraction Category.

3.1.6 References for the Prioritization of Categories for Preliminary Category Review

1. Hopper, Cecil. 2014. Telephone and Email Communication between Cecil Hopper, PCS Nitrogen Fertilizer LP, and Eva Knoth, Eastern Research Group, Inc., Re: 2013 TRI Surface Water Releases. (December 12). EPA

- HQ

- OW -2015­

0665 . DCN 08238.

2. Lantner, Murray. 2015. Telephone and Em ail Communication between Murray Lantner, EPA Region 2, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Discharges for Bacardi Corp . (February 13). EPA

- HQ

- OW -2015­

0665. DCN 08239.

3. Louis, Nestor. 2015. Telephone and Email Communication between Nestor Louis, EPA Region 2, and Kimberly Bartell, Eastern Research Group, Inc.

, Re: 2013 DMR Discharges for Wyndham Sugar Bay Resort . (February 13). EPA

- HQ

- OW

2015-0665. DCN 08240.

4. Lozano, VelRey. 2014. Telephone and Email Communication between VelRey Lozano, EPA Region 8, and Kimberly Bartell, Eastern Research Group, Inc.

, Re: 2013 DMR Sulfide Discharges for Maverick Spring in Cody WY. (December 18).

EPA

- HQ

- OW -2015-0665. DCN 08241.

5. 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

2008-0517-0618.

6. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. (December). EPA 821-R-12-001. EPA- HQ

- OW -2010-0824­

0195.

7. U.S. EPA. 2014. The 2013 Annual Effluent Guidelines Review Report. Washington, D.C. ( September ). EPA 82 1-R-14- 003 . EPA

- HQ

- OW -2014-0170­

0077.

8. U.S. EPA. 2015. Final 2014 Effluent Guidelines Program Plan . Washington,

D.C. (July). EPA -821-R-15-001. EPA- HQ

- OW -2014-0170-0210.

3-43— EPA’s 2015 Preliminary Category Reviews

3.2

— Carbon Black M anufacturing (40 CFR P art 4 58 )

3.2 Carbon Black M anufacturing (40 CFR P art 458 )

EPA identified the Carbon Black Manufacturing (Carbon Black) Category for preliminary review because it ranks high, in terms of toxic-weighted pound equivalents (TWPE), in the final 2015 combined point source category rankings. EPA has not completed a prel iminary category review of the Carbon Black Category as part of recent annual reviews because it has not historically been a category that collectively contributed to the top 95 percent of the total TWPE in the point source category rankings. However, EPA has reviewed and made data corrections for facility

- specific discharges as part of previous toxicity rankings analyses (TRA). This section summarizes the results of the 2015 Annual Review. EPA focused its 2015 review on discharges of polycyclic aromatic compounds (PACs) because of their high TWPE relative to the other pollutants discharged by facilities in the Carbon Black Category.

3.2.1 Carbon Black Category 2015 Toxicity Rankings Analysis

Table 3-1 compares the TRA data for the Carbon Black Cat egory from the 2011, 2013, and 2015 Annual Reviews. EPA did not conduct the TRA in 2012 or 2014, but instead reviewed additional data sources as part of the even -year annual revie w, as described in Section 2.2.1 of EPA’s Preliminary 2016 Plan (U.S. EPA, 2016). As discussed in this section, during the 2015 Annual Review, EPA identified a data correction that affected the 2013 Toxic Release Inventory (TRI) data and TWPE. The bottom row of Table 3-1 shows the corrected data resulting from this

review.

Table 3-1. Carbon Black Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

Year of Discharge Year of

Review Carbon Black Category Facility Counts a Carbon Black Category TWPE

Total TRI

Facilities Total DMR Major

Facilities Total DMR

Minor

Facilities TRI TWPE b DMR

TWPE c Total TWPE

2009 2011 5 0 3 62,300 65.9 62,400

2011 2013 4 0 1 27,900 0.2 27,900

63,800 d 63,800 d

2013 2015 3 0 1 38,500 e 0.1 38,500 e

Sources: DMRLoads2009_v2 (for 2009 DMR) ; TRIReleases2009_v2 (for 2009 TRI); DMRLTOutput2011_v1 (for

2011 DMR); TRILTOutput2011_v1 (for 2011 TRI); DMRLTOutput2013_v1 (for 2013 DMR); TRILTOutput2011_v3 (for 201 3 TRI).

Note: EPA did not evaluate 2010 or 2012 DMR and TRI dat a. Note: TWPE values are rounded to three significant figures. Sums of individual values may not equal the total presented, due to rounding.

a Number of facilities with TWPE greater than zero.

b Releases include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for

POTW removals.

Includes DMR data from b oth major and minor dischargers

. d 2013 data prior to corrections made during the 2015 Annual Review.

e 2013 data after corrections were made during the 2015 Annual Review.

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As shown in Table 3-1, the TWPE for TRI decreased from 2009 to 2011 and then increased from 2011 to 2013, even while the number of facilities reporting has dropped. The increase in TRI TWPE is primarily due to releases from facilities described in t he sections

below.

3.2.2 Carbon Black Category Pollutants of Concern

EPA’s 2015 review of the Carbon Black Category focused on 2013 TRI releases because the TRI data dominate the category’s combined TWPE. Table 3-2 shows the five pollutants with the highest contribution to the 2013 TRI TWPE. Table 3-2 also presents the 2013 TRI TWPE after EPA corrected errors identified in this preliminary category review (discussed in the sections below). As a point of comparison, Ta ble 3-2 shows the 2011 TRI facility count and TWPE for these top five pollutants, based on the 2013 Annual Review (U.S. EPA, 2014).

PACs contribute more than 99 percent of the original 2013 TRI TWPE for the Carbon Black Category (prior to corrections discussed below). Section 3.2.3 presents EPA’s investigations of reported releases of this top pollutant. EPA did not investigate the other pollutants as part of the 2015 Annual Review because they represent a small percentage (approximately 0.01 percent) of the 2013 TRI TWPE for the Carbon Black Category.

Table 3-2. Carbon Black Category Top TRI Pollutants

Pollutant a 2013 TRI Data 2011 TRI Data

Number of Facilities Reporting Pollutant b Original

TWPE Corrected

TWPE Number of Facilities Reporting Pollutant b TWPE

PACs 3 63,800 38,500 3 27,900

Anthracene 1 4.57 4.57 1 2.79

Phenanthrene 1 0.522 0.522 1 0.319

Lead and Lead Compounds 2 0.259 0.259 3 0.517

Mercury and M ercury C ompounds 1 0.012 0.012 1 0.012

Carbon Black Category Total c 3 63,800 38,500 4 27,900

Sources: TRILTOutput2011_v1 (for 2011 TRI TWPE); TRILTOutput2013_v1 (for 2013 TRI TWPE) Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable.

a Anthracene, phenanthrene, lead and lead compounds, and mercury and mercury compounds combined

contribute less than 0.01 percent of the original 2013 category TRI TWPE. Therefore, EPA did not review any of these releases as part of the 2015 Annual Review.

b Number of facilities with TWPE greater than zero.

c The Carbon Black Category has water releases for on ly five pollutants in the 2013 TRI.

3.2.3 Carbon Black PAC Discharges in TRI

EPA’s investigation of the PAC releases revealed that two facilities, GrafTech International Holdings, Inc. in Columbia, TN, and Cabot Corporation Canal Plant in Franklin,

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LA 15 , account for 99 percent of the 2013 TRI PAC releases (shown in Table 3-3 ). Only three facilities have 2013 TRI PAC releases; the other is Cabot Corporation in Ville Pla tte, LA, which EPA did not investigate as part of the 2015 Annual Review because it contributes only 0.03 percent of the PAC TWPE in the Carbon Black Category.

Table 3-3. Top Facilities Reporting 2013 TRI PAC Releases

Facility Name Facility

Location Pounds of

Pollutant

Released Pollutant

TWPE Percent of Category TWPE

GrafTech International Holdings, Inc. Columbia, TN 394 39,700 62.1%

Cabot Corporation Canal Plant Franklin, LA 240 24,100 37.8%

Cabot Corporation Ville Platte Plant Ville Platte, LA 0.16 16.1 0.03%

Total 634 63,800 100%

Source: TRILTOutput2013_v1 Note: Sums of individual values may not equal the total presented, due to rounding.

Graf Tech International Holdings, Inc.

GrafTech International Holdings (GrafTech) in Columbia, TN, manufactures advanced graphite materials and refractory products. As part of its TRA data review and outlier correction

process supporting the 2010, 2011, and 2013 Annual Reviews, EPA reviewed PAC releases from GrafTech. The corrections to the outlier data for this facility has historically dropped the category TWPE out of the top 95 percent (U.S. EPA, 2011, 2012, 2014). As discussed in the 2010 Annual Review Report, EPA contacted the facility to confirm PA C releases. The facility contact confirmed the PAC releases, provided sampling data, and explained that the facility estimates the release using the flow and the concentration of PACs in the total suspended solids (TSS) present in the wastewater (U.S. EPA, 2011).

In TRI, facilities report PAC releases as a class, not individual compounds. EPA estimates TWPE for PACs using the toxic weighting factor (TWF) for benzo(a)pyrene (100.66), the highest TWF associated with a PAC. Because the TWF for benzo(a)pyrene is higher than that for any other PAC, this represents a worst- case scenario. For PAC releases that are not composed completely of benzo(a)pyrene, this method overestimates the relative toxicity of the releases. Based on the monitoring data provided by the facility in 2010, EPA identified the specific PACs discharged and calculated a facility

- specifi c TWF (Aslinger, 2010). As part of the TRA supporting the 2010, 2011, and 2013 Annual Reviews, EPA revised GrafTech’s PAC releases to reflect their facility -spe cific TWF. Table 3-4 presents the original and corrected and TWPE used to support those annual reviews (U.S. EPA, 2011, 2012, 2014).

EPA contacted GrafTech as part o f the 2015 Annual Review to confirm their 2013 discharges. The facility contact confirmed the 2013 PAC release and explained that the facility continues to estimate their PAC load by using the flow and process knowledge of the

concentration of PACs in the TSS present in the wastewater. The facility contact also stated that

15 D ata sources list Cabot Corporation Canal Plant ( TRI ID: 70583CBTCRSTATE , NPDES ID: LA000182 ) in

either Franklin, LA or Centerville, LA. The cities are next to each other. The 2015 Annual Review Report lists the city as Franklin, LA because the company website lists the facility address at this location.

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there was an increase in production from 2012 to 2013 (Philpot, 2015). Because the facility continues to calculate the PAC discharge using the same methods and monitoring data, EPA

revise d the 2013 releases to reflect the facility

- specific TWF. Incorporating the facility

- specific TWF decreases the 2013 PAC TWPE from 39,700 to 14,300.

Table 3-4 . GrafTech PAC TRI Releases for 2008 – 2013

Year of Discharge Original PAC Pounds Discharged Original PAC TWPE Corrected PAC TWPE

2008 1,090 110,000 8,950

2009 446 44,900 16,2 00

2011 371 37,3 00 13,500

2013 394 39,700 14,300

Source: U.S. EPA, 2011, U.S. EPA, 2012, U.S. EPA 2014, DMR Pollutant Loading Tool.

Cabot Corporation Canal Plant

Cabot Corporation Canal Plant (Cabot) in Franklin, LA, manufactures specialty chemicals and performance materials. As part of the 2015 Annual Review, EPA contacted the facility about its PAC releases. The facil ity contact explained that the facility estimates the PAC release based off the concentration of polycyclic aromatic hydrocarbons (PAHs) in the feedstock oil (removing anthracene and phenanthrene, which are not PACs) and the amount of wastewater

used for t he process. The facility adds in an estimate of solids based on process knowledge to reach a total amount of PACs discharged for the year (Longon, 2015). Although the facility uses process knowledge to determine the concentration of PACs in the feedstock o il, there is a potential for overestimation. Table 3-5 presents Cabot’s PAC discharge data for the years 2007 through 2013. As shown, the discharges have fluctuated since 2007, with spikes in 2010 and 2013. The facility contact stated that an increase in production led to the increased discharges.

Table 3-5. Cabot PAC TRI Releases for 2007 – 2013

Year of Discharge Pounds of PACs Released PAC TWPE

2007 178 17,900

2008 168 16,900

2009 149 14,900

2010 233 23,500

2011 142 14,300

2012 147 14,800

2013 240 24,100

Source: DMR Loading Tool

3.2.4 Carbon Black Category Findings

The estimated toxicity of the Carbon Black Category discharges resulted primarily from PAC releases reported to TRI. From the 2015 Annual Review, EPA found:

• One facility, GrafTech International Holdings, Inc., in Columbia, TN, contributed 62 percent of the category’s 2013 TRI PAC releases. EPA contacted the facility as part of the 2015 Annual Review; the facility confirmed the releases and estimation

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method. EPA revised the 2013 releases to reflect a facility

- specific TWF to account for toxicity of specific the PACs discharged, which reduced the fa cility’s TRI PAC TWPE from 39,700 to 14,300.

• One facility, Cabot Corporation Canal Plant, in Franklin, LA, contributed 38 percent of the category’s 2013 TRI PAC releases. EPA contacted the facility as part of the 2015 Annual Review; the facility confirmed the release and explained that increases in p roduction led to increased releases, however, the facility also indicated that the estimation methodology may overestimate PAC discharges.

• EPA identified that only two facilities accounted for 99 percent of the PAC TWPE for the Carbon Black Category. Afte r applying a facility

- specific TWF for GrafTech the 2013 Carbon Black Category TWPE decreased from 63,800 to 38,500. This change would drop the category outside the top 95 percent that EPA prioritized for preliminary review as part of the 2015 Annual Revie w.

3.2.5 Carbon Black Category 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 -2008-0517-0745.

2. ERG. 2015. Preliminary Category Review – Facility Data Review and Revised Calculations for Point Source Category – 458 – Carbon Black Manufacturing. (September). EPA

- HQ

- OW -2015-0665. DCN 08122.

3. Longon, Scott. 2015. Telephone Communication between Scott Longon, Cabot Corporation Canal Plant, and Kara Edquist, Eastern Research Group, Inc., Re: 2013 TRI PAC Discharges for Cabot Corporation’s Canal Plant, Franklin, LA. (April 14). EPA

- HQ

- OW -2015-0665. DCN 08123.

4. Philpot, Beverley . 2015. Telephone Communication between Beverley Philpot, Graftech International Holdings, Inc., and Kara Edquist, Eastern Research Group, Inc., Re: 2013 TRI PAC Discharges for Graftech International Holdings, Inc., Columbia, TN. (April 14). EPA- HQ

- OW -2015-0665. DCN 08124.

5. 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

2008-0517-0618.

6. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. (December). EPA 821-R-12-001. EPA- HQ

- OW -2010-0824­

0195.

7. U.S. EPA. 2014. The 2013 Annual Effluent Guidelines Review Report

. Washington, D.C. (September). EPA-821-R-14-003. EPA- HQ

- OW -2014-0170­

0077.

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— Carbon Black M anufacturing (40 CFR P art 4 58 )

8. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan. Washington, D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN

08208.

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3.3

— Grain Mills (40 CFR Part 406 )

3.3 Grain Mills (40 CFR Part 406)

EPA identifie d the Grain Mills Category for preliminary review because it ranks high, in

terms of toxic -weighted pound equivalents (TWPE), in the final 2015 combined point source category rankings. EPA has not completed a preliminary category review of the Grain Mills Category as part of recent annual reviews because it has not historically been a category that collectively contributed to t he top 95 percent of the total TWPE in the point source category rankings. This section summarizes the results of the 2015 Annual Review. Hydrogen sulfide was added as a Toxic Release Inventory (TRI) reporting requirement in 2012. As a result, in 2013, hydrogen sulfide contributed a substantial amount of TWPE for the category. Therefore, for the 2015 Annual Review, EPA focused its review on discharges of hydrogen sulfide because of the high TWPE rela tive to the other pollutants discharged by facilities in t he Grain Mills Category.

3.3.1 Grain Mills Category 2015 Toxicity Rankings Analysis

Table 3-6 compares the toxicity rankings analys es (TRA) data for the Grain Mills Category from the 2011, 2013, and 2015 Annual Reviews. EPA did not conduct the TRA in 2012 or 2014, but instead reviewed additional data sources as part of the even-year annual

review

, as d escribed in Section 2.2.1 of EPA’s Preliminary 2016 Plan (U.S. EPA, 2016). During the 2015 Annual Review, EPA did not identify any data corrections to the 2013 Discharge Monitoring Report (DMR) and TRI discharge data for the Grain Mills Category

.

Table 3-6 . Grain Mills Categ ory TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

Year of Discharge Year of

Review Grain Mills Category Facility Counts a Grain Mills Category TWPE

Total TRI

Facilities Total DMR Major

Facilities Total DMR

Minor

Facilities TRI

TWPE b DMR TWPE c Total

TWPE

2009 2011 32 10 13 6,190 2,900 9,090

2011 2013 23 7 18 10,500 2, 8 10 13,300

2013 2015 31 5 15 179,000 22,300 201,000

Sources: TRIReleases2009_v2 ; DMRLoads2009_v2 (for 2009 TRI and DMR); TRILTOutput2011_v1 ; DMRLTOutput2011_v1 (for 2011 TRI and DMR ); TRILTOutput2013_v1 ; DMRLTOutput2013_v1 (for 2013 TRI and DMR).

Note: EPA did not evaluate 2010 or 2012 DMR and TRI data

. Note: TWPE values are rounded to three significant figures. Sums of individual values may not equal the total presented, due to rounding.

a Number of facilities with TWPE greater than zero.

b Releases include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for

POTW removals. The 2013 TRI TWPE also includes TWPE associated with reported releases of hydrogen sulfide. Facilities began reporting releases of hydrogen sulfide to TRI in 2012.

Includes DMR discharges from both major and minor dischargers

.

As shown in Table 3-6, the total TWPE increased slightly from 2009 to 2011 and substantially from 20 11 to 2013 . This substantial increase was driven by releases of hydrogen

sulfide reported to TRI, discussed in the sections below. T he number of facilities reporting to

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— Grain Mills (40 CFR Part 406 )

TRI decreased from 2009 to 2011, but rose again in 2013. The total number of DMR facilities, both major and minor, declined slightly from 2009 to 2013.

3.3.2 Grain Mills Category Pollutants of Concern

E PA’s 2015 review of the Grain Mills Category focused on the 2013 TRI releases because the TRI data dominate the category’s combined TWPE. EPA did not focus on 2013 DMR discharges, however, the increase in DMR TWPE from 2011 to 2013 is attributed to an outlier flow during August 2013 from one facility, which was subsequently corrected in the source data after EPA finalized the 2015 combined point source category rankings. Table 3-7 shows the five pollutants with the highest contribution to the 2013 TRI TWPE. As a point of comparison, Table 3-7 also shows the 2011 TRI facility count and TWPE for these top pollutants, based on the 2013 Annual Review (U.S. EPA, 2014). Hydrogen sulfide contributes over 98 percent of the total 2013 TRI TWPE. Because hydrogen sulfide was added as a TRI reporting requirement in 2012, no hydrogen sulfide releases were reported in 2011. EPA’s investigations of reported releases of hydrogen sulfide are presented in Sections 3.3.3 and 3.3.4. EPA did not investigate the other pollutants as part of the 2015 Annual Review, because they represent a small percentage (less than 2 percent) of the 2013 TRI TWPE for the Grain Mills Category.

Table 3-7. Grain Mills Category Top TRI Pollutants

Pollutant a 2013 TRI Data 2011 TRI Data

Number of Facilities Reporting Pollutant b TWPE Number of Facilities Reporting Pollutant b TWPE

Hydrogen Sulfide 7 177,000 NA c NA c

Nitrate Compounds 13 1,100 11 1

, 640

Ammonia 8 416 8 391

Ethylene Glycol 3 141 2 331

Lead and Lead Compounds 3 14 1 4 473

Top Pollutant Total NA 179,000 NA 2,840

Grain Mills Category Total 31 179,000 23 10,500

Sources: TRILTOutput2011 _v1; TRILTOutput2013_v1

. Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable.

a Nitrate compounds, ammonia, ethylene glycol, and lead and lead compounds releases c ombined contribute less than 2 percent of the 2013 category TRI TWPE. Therefore, EPA did not review any of these releases as part of

the 2015 Annual Review.

b Number of fac ilities with TWPE greater than zero.

c Hydrogen s ulfide was added as a TRI reporting requirement in 2012 it was not a TRI

- listed chemical in 2011.

3.3.3 Hydrogen Sulfide Background

As described in Section 2.2.2.1 of this report

, facilities were required to report releases of hydrogen s ulfide to TRI beginning in 2012. EPA did not perform a TRA in 2014; therefore, EPA is reviewing TRI reported hydrogen sulfide water releases for the first time as part of the 2015 Annual Review. Hydrogen sulfide is a biologically active compound that is found primarily as an

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— Grain Mills (40 CFR Part 406 )

anaerobic degradation product of both organic sulfur compounds and inorganic sulfates. Sulfides

ar e constituents of many industrial wastes such as those from farming, food processors, tanneries, paper mills, chemical plants, and gas works. The anaerobic decomposition of sewage, sludge beds, algae, and other naturally deposited organic material is a maj or source of hydrogen sulfide (U.S. EPA, 1986). Discharges from these and other activities can release hydrogen sulfide to receiving waters (ATSDR, 2014).

Hydrogen sulfide is a soluble, colorless, highly poisonous, gaseous compound having the characteristic odor of rotten eggs. When soluble sulfides are added to water

, they react with hydrogen ions to form the hydrosulfide ion (HS - ) and hydrogen sulfide (H 2 S) , the proportion of each depending on pH. The toxicity of sulfides derives primarily from hydrogen sulfide rather than from the hydrosulfide or sulfide ions. At pH 9 , approximately 99 percent of the sulfide is in

the form of HS - ; at pH 7 the sulfide is equally divided between HS - and H 2 S; and at pH 5 about 99 percent of the sulfide is pr esent in the form of H 2 S (U.S. EPA, 1986). In well aerated water, hydrogen sulfide is readily oxidized to sulfates and biologically oxidized to elemental sulfur.

Under anaerobic conditions, microbial reduction of sulfate to sulfide can occur (WHO, 2003).

3.3.4 Grain Mills Category Hydrogen Sulfide Releases in TRI

EPA’s investigation of the hydrogen sulfide data revealed that one facility, Cargill, Inc., Wet Corn Milling in Wahpeton, ND, accounts for over 98 percent of the hydrogen sulfide

releases reported to TRI in 2013 (shown in Table 3-8 ). EPA did not investigate the remaining

facilities reporting releases of hydrogen sulfide as part of the 2015 Annual R eview.

Table 3-8. Top Faci lities Reporting 2013 TRI Hydrogen Sulfide Releases

Facility Name Facility

Location Pounds of

Pollutant

Released Pollutant

TWPE Percent of Category TWPE

Cargill, Inc., Wet Corn Milling Wahpeton, ND 62,500 175,000 98.8 %

All other hydrogen sulfide releases in the Grain Mills Category a 776 2,170 1.2%

Total 63,200 177,000 100%

Source: TRILTOutput2013_v1

. Note: Sums of individual values may not equal the total presented, due to rounding.

a Six additional facilities reported hydrogen sulfide releases in the 2013 TRI

.

Cargill, Inc., Wet Corn Milling in Wahpeton, ND, manufactures high fructose corn syrup. EPA contacted the facility as part of the 2015 Annual Review. The facility operates a wastewater treatment plant on site, which includes aerobic and anaerobic treatment steps, and discharges effluent from the wastewater treatment plant directly to the Red River. The hydrogen sulfide releases are produced by the anaerobic wastewater treatment at the facility, not directly by the manufacturing process (R azink, 2014). Sulfur compounds are not regulated pollutants in the

Grain Mills effluent limitations guidelines and standards (ELGs) (40 CFR Part 406).

To estimate their 2013 TRI hydrogen sulfide release, the facility, over two weeks, took four direct sampl es of wastewater from their treatment plant’s external outfall and measured the dissolved sulfide concentration in the samples. According to the facility, measurement of

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— Grain Mills (40 CFR Part 406 )

dissolved sulfide concentration in water may be a high bias estimate of hydrogen sulfide concentration. The average concentration from these four samples was multiplied by the average daily flow to estimate the pounds discharged per day, and then multiplied by the number of days wastewater was discharged in 2013 to estimate the annual pounds discharged (Razink, 2014). The facility reported similar direct releases of hydrogen sulfide to TRI in 2012 (184,000 TWPE) and 2013 (DMR Pollutant Loading Tool).

3.3.5 Grain Mills Category Findings

The estimated toxicity of the Grain Mills Category discharges resulted primarily from hydrogen sulfide releases reported to TRI. From the 2015 Annual Review, EPA found:

• One facility, Cargill, Inc., Wet Corn Milling in Wahpeton, ND, contributes over 98 percent of the category’s 2013 TRI hydrogen sulfide releases. The facility has a NPDES permit for its wastewater treatment plant and is a direct discharger.

− The reported di rect release to TRI was estimated based on the average dissolved sulfide concentration from four samples taken over two week s, and may reflects high bias releases of hydrogen sulfide from the facility.

− The release may be attributed to anaerobic wastewater treatment at the facility, and not to the manufacturing process.

• Because the majority of the hydrogen sulfide releases are attributed to one facility,

EPA does not consider them to be representative of the Grain Mills C ategory

.

3.3.6 Grain Mills Category Ref erences

1. ATSDR. 2014. U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry. Draft Toxicological Profile for Hydrogen Sulfide and Carbonyl Sulfide . Atlanta, GA. (October). EPA

- HQ

- OW -2015-0665.

DCN 08125.

2. ERG. 2015. E astern Research Group, Inc. Preliminary Category Review

– Facility Data Review for Point Source Category – 406 – Grain Mills. Chantilly, VA. (September). EPA

- HQ

- OW -2015-0665. DCN 08126.

3. Razink, Jonathan. 2014. Telephone and Email Communication Between Jonathan Razink, Cargill, Inc., and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 TRI Hydrogen Sulfide Releases. (December 22). EPA

- HQ

- OW -2015-0665.

DCN 08127.

4. U.S. EPA. 1986. Qua lity Criteria for Water . Washington, D.C. (M ay ). EPA

- HQ

OW -2004-0032-2619.

5. U.S. EPA. 2014. The 2013 Annual Effluent Guidelines Review Report

. Washington, D.C. (September). EPA-821-R-14-003. EPA- HQ

- OW -2014-0170­

0077.

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— Grain Mills (40 CFR Part 406 )

6. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan. Washington, D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN

08208.

7. WHO. 2003. World Health Organization. Hydrogen Sulfide in Drinking- water

. EPA

- HQ

- OW -2015-0665. DCN 08128.

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3.4

— Iron and Steel Manufacturing (40 CFR Par t 420)

3.4 Iron and Steel Manufacturing (40 CFR Par t 420)

EPA identified the Iron and Steel Manufacturing Category for preliminary review

because it rank s high again , in terms of toxic-weighted pound equivalents (TWPE), in the final 2015 combined point source category rankings. Previously, EPA reviewed discharges from this category as part of the 2011 and 2013 Annual Reviews in which it also ranked high (U.S. EPA, 2012; U.S. EPA, 2014). This section summarizes the results of the 2015 Annual Review. EPA focused its 2015 review on discharges of polychlorinated biphenyls (PCBs), cyanide, fluoride, nitrate compounds, and lead and lead compounds due to their high TWPE relative to the other pollutants discharged by facilities in the Iron and Steel Manufacturing Category. Cyanide and fluoride, reviewed as part of the 2013 Annual Review, continue to be top pollutants of concern. For the 2015 Annual Review, available discharge data also showed significant contributions of PCBs, nitrate compounds, and lead and lead compounds. For further background on the Iron and Steel Manufacturing Category, including an industry profile , see The 2011 Annual Effluent Guidelines Review Report (U.S. EPA, 2012).

3.4.1 Iron and Steel Manufacturing Category 2015 Toxicity Rankings Analysis

Table 3-9 compares the toxicity rankings analyses (TRA ) data for the Iron and Steel Manufacturing Category from the 2011, 2013, and 2015 Annual Reviews. EPA did not conduct the TRA in 2012 or 2014, but i nstead reviewed additional data sources as part of the even

- year annual review, as described in Section 2.2.1 of EPA’s Preliminary 2016 Plan (U.S. EPA, 2016). As discussed in this section, during the 2015 Annual Review, EPA identified data corrections that affected the 2013 Discharge Monitoring Report (DMR) and Toxic Release Inventory (TRI)

data and TWPE. The bottom row of Table 3-9 shows the corrected data resulting fr om this

review.

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— Iron and Steel Manufacturing (40 CFR Par t 420)

Table 3-9 . Iron and Steel Manufacturing Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

Year of Discharge Year of

Review Iron and Steel Manufacturing Category Facility Counts a Iron and Steel Manufacturing Category

TWPE

Total TRI

Facilities Total DMR Major

Facilities Total DMR

Minor

Facilities TRI TWPE b DMR

TWPE c Total TWPE

2009 2011 227 73 49 96,200 108,000 d 20 5 ,000 d

2011 2013 222 76 45 82,900 214,000 e 297,000 e

2013 2015 215 51 29 84,600 f 188,000 f 273,000 f

82,600 g 182,000 g 264 ,000 g

Sources: 2013 Annual Review Report (for 2009 and 2011 DMR and TRI Data) (U.S. EPA, 2014); DMRLTOutput2013_v1 (for 2013 DMR); TRILTOutput2013_v1 (for 2013 TRI).

Note: EPA did not evaluate 2010 or 2012 DMR and TRI data. Note: TWPE values are rounded to three significant figures. Sums of individual values may not equal the total presented, due to rounding.

a Number of facilities with TWPE greater than zero.

b Releases include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for

POTW removals.

c Includes DMR data from both major and minor dischargers.

d 2009 data after corrections were made during the 2011 Annual Review.

e 2011 data after corrections were made during the 2013 Annual Review.

f 2013 data prior to corrections made during the 2015 Annual Review.

g 2013 data after corrections were made during the 2015 Annual Review.

As shown in Table 3-9 , the number of TRI facilities with pollutant releases and TRI

TWPE decreased from 20 09 to 2013. The number of permitted facilities with DMR data also decreased from 2009 to 2013. This suggests that the number of U.S. iron and steel facilities may be declining. However, during the same timeframe, t he DMR TWPE increased substantially from 2009 to 2011, then decreased from 2011 to 2013.

3.4.2 Iron and Steel Manufacturing Category Pollutants of Concern

EPA’s 2015 review of the Iron and Steel Manufacturing Category focused on the 2013 DMR and TRI discharges because both contribute to the category’s combined TWPE. Table 3-10 shows the five pollutants with the highest contribution to the 2013 DMR TWPE. Table 3-10 also presents the 2013 DMR TWPE after EPA corrected errors identified in th is preliminary category review (discussed in the sections below). As a point of comparison, Table 3-10 also shows the 2011 DMR facility count and TWPE for these top five pollutants, based on the 2013 Annual Review (U.S. EPA, 2014). PCBs, cyanide, and fluoride contribute over 70 percent of the original 2013 DMR TWPE for the Iron and Steel Manufacturing Category (prior to corrections discussed below). Additionally, EPA i nvestigated DMR discharges of lead because it is a top TRI pollutant. Of these top pollutants, only cyanide and lead are regulated pollutants in the Iron and Steel Category effluent limitations guidelines and standards (ELGs) (40 CFR Part 420). Sections

3.4.3 through 3.4.6 present EPA’s investigation of DMR d ischarges of PCBs, cyanide, fluoride,

and DMR and TRI- reported discharges of lead . EPA did not investigate total residual chlorine as

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— Iron and Steel Manufacturing (40 CFR Par t 420)

part of the 2015 Annu al Review because it represents a small percentage (7 percent) of the 2013 DMR TWPE for the Iron and Steel Manufacturing Category.

Table 3-11 shows the five pollutan ts with the highest contribution to the 2013 TRI

TWPE. Table 3-11 also presents the 2013 TRI TWPE after EPA corrected errors identified in this prelimi nary category review (discussed in the sections below). As a point of comparison,

Table 3-11 also shows the 2011 TRI facility count and TWPE for these top five pollutants, based on the 2013 Annual Review (U.S. EPA, 2014). Nitrate compounds and lead and lead compounds contribute over 56 percent of the original 2013 TRI TWPE for the Iron and Steel Manufacturing Category (prior to corrections discussed bel ow) . Sections 3.4.6 and 3.4.7 present E PA’s investigation of reported TRI releases of lead and lead compounds and nitrate compounds . EPA

did not conduct a facility -level investigation of polycyclic aromatic compounds, manganese and manganese compounds, and copper and copper compounds, as part of the 2015 Annual Review because they contribute a small amount of TWPE relative to the other top pollutants in the Iron and Steel Manufacturing Category. However, many facilities report manganese and manganese compound and copper and copper compound releases to TRI, as shown in Table 3-11.

Table 3-10 . Iron and Steel Manufacturing Category Top DMR Pollutants

Pollutant b 2013 DMR Data a 2011 DMR Data a

Number of Facilities Reporting

Pollutant c Original

TWPE Corrected

TWPE Number of Facilities Reporting

Pollutant c TWPE d

PCBs 1 76,700 76,700 1 73,200

Cyanide 13 29,200 22,700 26 34,100

Fluoride 10 26,500 26,500 17 34,200

Total Residual Chlorine 20 13,700 13,700 29 28,600

Lead 33 8,760 8,760 63 12,600

Top Pollutant Total NA 155,000 148,000 NA 110,000

Iron and Steel Manufacturing Category Total 80 188,000 182,000 121 214,000

Sources: DMRLTOutput2013_v1 (for 2013 TWPE); DMRLTOutput2011_v1 (for 2011 facility counts); 2013 Annual Review Report (for 2011 TWPE) (U.S. EPA, 2014)

. Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable

a Includes DMR data from both major and minor dischargers.

b Total residual chlorine discharges contribute 7 percent of the original 2013 category DMR TWPE. Therefore,

EPA did not review total residual chlorine discharges as part of the 2015 Annual Review.

c Number of facilities with TWPE greater than zero.

d 2011 data after corrections were made during the 2013 Annual Review.

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Table 3-11 . Iron and Steel Manufacturing Category Top TRI Pollutants

Pollutant a 2013 TRI Data 2011 TRI Data

Number of Facilities Reporting

Pollutant b Original

TWPE Corrected

TWPE Number of Facilities Reporting

Pollutant b TWPE

Nitrate Compounds 56 25,400 25,400 55 24,600

Lead and Lead Compounds 133 22,700 20,600 c 135 24,300

Polycyclic Aromatic Compounds 5 6,910 6,910 4 11,400

Manganese and Manganese Compounds 114 5,680 5,680 117 6,250

Copper and Copper Compounds 79 4,990 4,990 78 4,270

Top Pollutant Total NA 65,700 63,600 NA 70,800

Iron and Steel Manufacturing Category Total 215 84,600 82,600 222 82,900

Sources: TRILTOutput2011_v1 (for 2011 TRI TWPE); TRILTOutput2013_v1 (for 2013 TRI TWPE) Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable.

a Polycyclic aromatic compounds, manganese and manganese compounds, and copper and copper compounds

each contribute less than 9 percent of the original 2013 category TRI TWPE. T herefore, EPA did not review polycyclic aromatic compound, manganese and manganese compound, or copper and copper compound releases as part of the 2015 Annual Review.

b Number of facilities with TWPE greater than zero.

c EPA identified two facilities with revisions to their 2013 TRI lead and lead compound releases. Section 3.4.6

discusses the correction from Charter Steel Cleveland. EPA also received corrected data from ArcelorMittal Burns Harbor LLC in Burns Harbor, IN (Bley, 2015). EPA revised the 2013 TRI lead and lead compound TWPE to incorporate the corrected data from these facilities.

3.4.3 Iron and Steel Manufacturing PCBs Discharges in DMR

EPA’s investigatio n of the PCB discharges revealed that one facility, U.S. Steel Fairless Hills Works, in Fairless Hills, PA, accounts for 100 percent of the 2013 DMR PCB discharges. In 2013, the facility reported 2.25 pounds of PCBs discharged, corresponding to 76,700 TWPE ( DMRLTOutput2013_v1) . EPA did not review 2011 PCB discharges from this facility as part of its 2013 Annual Review because the facility submitted 2011 PCB DMR data after EPA compiled

the DMRLTOutput2011_v1 database supporting the 2013 Annual Review.

As pa rt of the 2015 Annual Review, EPA contacted U.S. Steel about the Fairless Hills facility. The facility began operation in 1952 and was a fully integrated steel mill. The facility included two blast furnaces, nine open- hearth furnaces, two coke batteries, a n 80-inch hot stripmill, rolling mills, a sheet and tin department, hot dip galvanizing line, a pipe mill, and a deepwater vessel slip. The entire facility was located on nearly 4,000 acres along the Delaware River. At the time of construction and operat ion of the facility, PCBs were common in electrical equipment at the facility (Lasko, 2015).

In August 1991, the company closed and systematically demolished the pipe mill and the hot side of the plant, which included iron making, steel making, cokemaking, and hot rolling productions. In 1998, the remaining cold finishing operations, excluding the hot dip galvanizing

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— Iron and Steel Manufacturing (40 CFR Par t 420)

line, were permanently idled. The company has substantially redeveloped the site but several buildings remain in the sheet and tin area (Lask o, 2015).

Table 3-12 presents U.S. Steel Fairless Hills Works’ PCB discharges for 2011 through 2014. As shown, the PCB discharges have remained consistent from 2011 through 2013, and

decreased in 2014. U.S. Steel does not know the source of the PCBs detected in discharges from the Fairless Hills Works’ facility; however, they have confirmed that the PCBs are not associated with the remaining hot dip galvanizing line. Therefore, the facility has attributed the disc harges to historical production activities at the site (Lasko, 2015).

Table 3-12. U.S. Steel Fairless Hills Works’ PCB Discharges for 2011-2014

Year PCB TWPE

2011 73,200

2012 69,800

2013 76,700

2014 25,800

Source: DMRLTOutput2013_v1; DMR Loading Pollutant Tool (Loading Tool)

.

In 2003, EPA Regions 2 and 3 adopted a Total Maximum Daily Load (TMDL) for PCBs for Zones 2, 3, 4, and 5 of the tidal Delaware River. This change required U.S. Steel to perform PCB analyses on wastewater discharges using EPA Method 1668A. This wastewater sampling and analysis has narrowed the location of the potential sources of PCB discharges to the lower segment of the facility, near outfall 002. U.S. Steel is currently working with the Delaware River Basin Commission (DRBC) to investigate further this segment of the canal to determine the source of the PCB discharges (Lasko, 2015). The facility’s PCB discharges have decreased from 2013 to 2014, as shown in Table 3- 12 , and the PCB discharges are associated with historical production activities, not current operations. Additionally, the company is working with DRBC

to determine the source of the PCB discharges.

3.4.4 Iron and Steel Manufacturing Cyanide Discharges in DMR

EPA’s investigation of the cyanide discharges revealed that two facilities, Mountain State Carbon, LLC 16 , in Follansbee, WV, and U.S. Steel Clairton Plant, Clairton, PA, account for 76 percent of the 2013 cyanide discharges (shown in Table 3-13 ). EPA reviewed cyanide discharges from both of these facilities as part of the 2011 and 2013 Annual Reviews (U.S. EPA, 2012, U.S. EPA, 2014). EPA did not investigate the remaining 11 facilities discharging cyanide as part of

the 2015 Annual Review.

16 This facility is named Severstal Wheeling, Inc. in the DMR database ( DMRLTOutpu t201 3 _v1 ). However, the facility’s permit lists the permittee as Mountain State Carbon, LLC.

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Table 3-13. Top 2013 DMR Cyanide Discharging Facilities

Facility Name Facility Location Pounds of Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

Mountain State Carbon, LLC Follansbee, WV 10,900 12,100 41.4%

U.S. Steel Clairton Plant Clairton, PA 9,050 10,000 34.4%

All other cyanide dischargers in the Iron and Steel Manufacturing Category a 6,390 7,090 24.2%

Total 26,300 29,200 100%

Source: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a Eleven additional facilities submitted cyanide discharges in the 2013 DMR data.

Both of the top two facilities are cokemaking plants, i.e., they produce carbon- coke from coal for use in steelmaking. Cokemaking operations generate wastewater containing cyanide during the byproduct recovery process. For further information on cokemaking plants in the U.S., see Section 9.4 of the 2011 Annual Review Report (U.S. EPA, 2012).

During the 2002 Iron and Steel rulemaking, EPA established production- based limits for cyanide based on the performance of best available technology (BAT) for the cokemaking subcategory (40 CFR Part 420 Subpart A). The BAT production- based limits are based on a long- term average ( LTA ) of 2.965 mg/L, and a variability factor of 1.49 (U.S. EPA, 2002, Appendices D and E).

Mountain State Carbon

Mountain State Carbon, LLC, in Follansbee, WV, discharges cyanide from two outfalls. EPA reviewed cyanide discharges from this facility as part of the 2011 and 2013 Annual Reviews. As part of the 2015 Annual Review, EPA contacted the facility and learned they received a revised permi t, becoming effective on October 1, 2013. The new permit changed the naming of the outfalls; outfall 205 was renamed outfall 006 and outfall 005 was renamed outfall

004. Mountain State Carbon has discharges and separate permit limits for total cyanide and weak acid dissociable cyanide (CNWAD). 17 Table 3-14 presents the 2008 and 2013 permit limits for Mountain State Carbon for total cyanide and CNWAD (Smith, 2015).

Table 3-14. Mountain State Carbon 2008 and 2013 Permit Limits

Outfall Number Total Cyanide Monthly Average

Permit Limit Total Cyanide Daily Maximum

Permit Limit CNWAD Monthly Average Permit

Limit CNWAD Daily

Maximum Permit

Limit

2008 Permit Limits

005 None None 0.0114 mg/L 0.0284 mg/L

17 Because a permit may require a facility to measure a pollutant in more than one way, such as discharges of total cyanide a nd CNWAD , EPA groups the DMR data using a hierarchy to determine which parameter best represents the total pollutant discharges. This avoids double counting of discharges. For this reason, EPA grouped total cyanide and CNWAD discharges under DMR cyanide discharges . See Section 3.2.3.2 of 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) for more information on pollutant groupin gs in DMR (U.S. EPA, 2009)

.

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Table 3-14. Mountain State Carbon 2008 and 2013 Permit Limits

Outfall Number Total Cyanide Monthly Average

Permit Limit Total Cyanide Daily Maximum

Permit Limit CNWAD Monthly Average Permit

Limit CNWAD Daily

Maximum Permit

Limit

205 24.5 lb/day (11.1 kg/day) 34.9 lb/day (15.8 kg/day) None None

2013 Permit Limits

004 (previously 005) Report Only Report Only Report Only Report Only

006 (previously 205) 25.6 lb/day (11.6 kg/day) or 4.39 mg/L 36.6 lb/day (16.6 kg/day) or 9.31 mg/L 0.067 mg/L 0.12 mg/L

Source: WVDEP, 2008a; WVDEP, 2013 b

The change in outfall designations mid-way through 2013 caused the Loading Tool to calculate facility discharge loads inaccurately. The Loading Tool calculates pollutant loadings from DMR data submitted by the facility. For months when a facility reports no flow and concentration data, the Loading Tool calculates estimated monthly discha rges. 18 In this instance, the Loading Tool interpreted the new outfall numbers as representing two new outfalls, and assigned both “new” outfalls estimated monthly discharges (for months that had data missing), while continuing to apply estimated discharges to the old outfall numbers. As a result, cyanide discharges from this facility were, at first, substantially overestimated. EPA corrected this error, resulting in a decrease of the facility’s cyanide TWPE from 12,100 to 5,570.

Ta ble 3-15 presents Mountain State Carbon’s 2013 DMR CNWAD discharges and NPDES monthly a verage permit limit for outfall 004 (previously outfall 005). Table 3-16 presents Mountain State Carbon’s 2013 DMR total cyanide discharges and NPDES monthly average permit limit for outfall 006 (previously outfall 205) . As shown in Table 3-15, the

CNWAD d ischarges for outfall 004 (previously outfall 005) are below permit limits . However,

as shown in Table 3-16 , t he Ma y 2013 quantity from outfall 006 (previously outfall 205) and the November 2013 concentration from outfall 006 exceed the facility permit limits.

Table 3-15 . Mountain State Carbo n’s 2013 DMR CNWAD Discharges

Outfall Date Reported Monthly Average Flow (MGD) Reported Monthly Average Concentration (mg/L) NPDES Monthly Average

Permit Limit

005 31

- Jan

- 13 7.58 0.0021 0.0114 mg/L

005 28

- Feb

- 13 6.52 0.0021 0.0114 mg/L

005 31

- Mar

- 13 13.5 0.0026 0.0114 mg/L

005 30

- Apr

- 13 14.3 0.0016 0.0114 mg/L

005 31

- May

- 13 13.5 0.0026 0.0114 mg/L

005 30

- Jun

- 13 12.6 0.0009 0.0114 mg/L

005 31

- Jul

- 13 9.39 0.0029 0.0114 mg/L

18 For example, Mountain State Carbon’s 2013 permit renamed outfall 205 as 006; the two numbers represent the same outfall. Mountain State Carbon submitted nine months of concentration and flow data for outfall 205, and

three mon ths of concentration and flow data for the same outfall after its number was changed from 205 to 006. For outfall 205, the DMR Loading Tool calculated the total load for the year and estimated discharges for the three “missing” months. For outfall 006, the DMR Loading Tool calculated the total load for the year and estimated discharges for nine “missing months.”

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Table 3-15 . Mountain State Carbo n’s 2013 DMR CNWAD Discharges

Outfall Date Reported Monthly Average Flow (MGD) Reported Monthly Average Concentration (mg/L) NPDES Monthly Average

Permit Limit

005 31

- Aug

- 13 8.68 0.0020 0.0114 mg/L

005 30

- Sep

- 13 10.0 0.0021 0.0114 mg/L

004 a 31

- Dec

- 13 13.2 0.013 Report Only

Sources: DMRLTOutput2013_v1 ; Smith, 2015; WV DEP, 2008a ; WV DEP, 2013 b

a The revised permit changed the monitoring requirement for this outfall from monthly to quarterly, therefore, after September 2013, the facility only submitted CNWAD discharges for the outfall in December 2013.

Table 3-16. Mountain State Carbon’s 2013 DMR Total Cyanide Discharges

Outfall Date Reported Monthly Average Flow (MGD) Reported Monthly Average

Concentration (mg/L) Reported Monthly Average Quantity (lb/d) NPDES Monthly Average Permit Limit

205 31

- Jan

- 13 0.57 NR 9.68 24.5 lb/d

205 28

- Feb

- 13 0.6 NR 9.19 24.5 lb/d

205 31

- Mar

- 13 0.58 NR 8.29 24.5 lb/d

205 30

- Apr

- 13 0.59 NR 12.0 24.5 lb/d

205 31

- May

- 13 0.5 NR 27.8 a 24.5 lb/d

205 30

- Jun

- 13 0.69 NR 14.0 24.5 lb/d

205 31

- Jul

- 13 0.73 NR 8.29 24.5 lb/d

205 31

- Aug

- 13 0.65 NR 11.0 24.5 lb/d

205 30

- Sep

- 13 0.7 NR 8.90 24.5 lb/d

006 31

- Oct

- 13 0.578 3.4 NR 4.39 mg/L

006 30

- Nov

- 13 0.606 4.5 a NR 4.39 mg/L

006 31

- Dec

- 13 0.6 2.1 NR 4.39 mg/L

Sources: DMRLTOutput2013_v1 ; Smith, 2015; WVDEP, 2008a; WV DEP, 2013 b NR: Not Reported

a Cyanide concentration or quantity exceeds monthly average permit limit.

U.S. Steel Clairton Plant

U.S. Steel Clairton Plant discharges cyanide in cokemaking wastewater from outfall 183. EPA reviewed this facility’s cyanide discharges as part of the 2011 and 2013 Annual Reviews. As part of the 2015 Annual Review, EPA contacted U.S. Steel to discuss the Clairton Plant’s cyanide discharges. The facility received a revised permit in May 2012 that included revised cyanide permit limits. The facility appealed the revised cyanide permit limits and settled with the Pennsylvania Department of Environmental Prote ction (PA DEP) with a consent order in January 2014. PA DEP reissued the permit, which became effective in February 2015 (Lasko, 2015). Table 3-17 presents the facili ty’s 2002, 2012, and 2015 cyanide permit limits for outfall

183.

Table 3-17. U.S. Steel Clairton Plant’s 2002, 2012, and 2015 Cyanide Permit Limits

for Outfall 183

Permit Cyanide Monthly Average Permit

Limit (mg/L) Cyanide Monthly Average Permit

Limit (lb/day) Cyanide Daily

Maximum Permit

Limit (mg/L) Cyanide Daily

Maximum Permit

Limit (lb/day)

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Table 3-17. U.S. Steel Clairton Plant’s 2002, 2012, and 2015 Cyanide Permit Limits

for Outfall 183

2002 Permit Limits 5.5 118 10 216

2012 Permit Limits 4.41 90.5 6.30 129

2015 Permit Limits 5.5 94 10 134

Source: PA DEP, 2002, PA DEP, 2012, PA DEP, 2015

PA DEP extended the 2002 cyanide permit limits for outfall 183 until the revised 2012 permit became effective. However, because the facility appealed the cyanide permit limits in the revised 2012 permit, th e facility had to meet the 2002 cyanide permit limits in 2013. Table 3-18 presents U.S. Steel’s 2013 monthly cyanide and flow discharge data for outfall 183. EPA calculated the cyanide concentrations using the reported quantity and average monthly flows. As shown, the facility’s discharge concentrations do not exceed the 2002, 2012, or 2015 permit limits and are below the LTA for cyanide calculated for the 2002 rulemaking (2.965 mg/L). The facility’s high cyanide TWPE is likely the result of the large amount of industrial activity at the site. This facility has historically been the top coke producer in the U.S. (U.S. EPA, 2002).

Table 3-18. U.S. Steel Clairton Plant’s 2013 DMR Cyanide Discharges for Outfall 183

Date Reported Monthly Average Flow (MGD) Reported Monthly Average Quantity (kg/d) Calculated Monthly Average Concentration (mg/L)

31

- Jan

- 13 2.4 7.27 0.800

28

- Feb

- 13 2.49 9.18 0.974

31

- Mar

- 13 2.34 14.2 1.60

30

- Apr

- 13 2.43 16.7 1.82

31

- May

- 13 2.38 9.38 1.04

30

- Jun

- 13 2.41 7.66 0.84 0

31

- Jul

- 13 2.59 10.1 1.03

31

- Aug

- 13 2.44 20.3 2.20

30

- Sep

- 13 2.4 11.3 1.24

31

- Oct

- 13 2.37 10.3 1.15

30

- Nov

- 13 2.45 10.2 1.10

31

- Dec

- 13 2.48 7.61 0.811

Sources: DMRLTOutput2013_v1

3.4.5 Iron and Steel Manufacturing Fluoride Discharges in DMR

EPA’s investigation of the fluoride discharges revealed that four facilities, account for 94 percent of the reported 2013 fluoride discharges (shown in Table 3-19). EPA did not investigate the remaining six facilities discharging fluoride as part of the 2015 Annual R eview.

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— Iron and Steel Manufacturing (40 CFR Par t 420)

Table 3-19. Top 2013 DMR Fluoride Discharging Facilities

Facility Name Facility

Loca tion Pounds of Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

U.S. Steel Gary Works a Gary, IN 324,000 9,730 36.7%

ArcelorMittal Weirton LLC b Weirton, WV 240,000 7,190 27.1%

U.S. Steel Granite City Works Granite City, IL 154,000 4,620 17.4%

ArcelorMittal Burns Harbor LLC Burns Harbor, IN 114,000 3,410 12.9%

All other fluoride dischargers in the Iron and Steel Manufacturing Category c 53,100 1,590 6.00%

Total 885,000 26,500 100%

Source: DMRLTOutput2013_v1.

Note: Sums of individual values may not equal the total presented, due to rounding.

a This facility is named USS Gary Works in the DMR database ( DMRLTOutput2013_v1 ) and in the 2013 Annual Review Report (U.S. EPA, 2014). However, the facility’s permit lists the permittee as U.S. Steel Gary Works.

b This facility is named Mittal Steel USA Weirton Inc. in the DMR database ( DMRLTOutput2013_v1 ) and Weirton Steel Corporati on in the 2013 Annual Review Report (U.S. EPA, 2014) . However, the facility’s permit lists the permittee as ArcelorMittal Weirton LLC.

Six additional facilities submitted fluoride discharges in the 2013 DMR data

.

The Iron and Steel Manufacturing Categor y ELGs do not include discharge limits for

fluoride . During previous annual reviews, EPA researched treatment technologies that were capable of removing fluoride (not specific to iron and steel wastewater discharges ) and found they achiev e effluent fluorid e concentrations between 2 mg/L and 15 mg/L (WC&E, 2006; Ionics, n.d.; GCIP, 2002). EPA used these effluent fluoride concentrations as benchmarks for initial comparison of fluoride discharges from iron and steel manufacturing facilities.

U.S. Steel Gary Wo rks

U.S. Steel Gary Works in Gary, IN, discharges fluoride in to the Grand Calumet River from outfalls 005, 028, and 030 (ID EM , 2014). EPA previously reviewed fluoride discharges from this facility as part of the 2013 Annual Review. Outfall 005 discharges c ooling water and condensate from many operations along with stormwater runoff. Outfalls 028 and 030 are discharges from lagoons that collect continuous caster non

- contact cooling water, cooling tower blowdown, stormwater runoff, steam condensate, and slab spray cooling water. The facility’s permit requires monitoring fluoride in discharges from outfalls 005, 028, and 030, but does not include fluoride limits (ID EM , 2014).

Table 3-20 presents U.S. Steel Gary Works ’ fluoride discharge data for 2013. EPA calculated the fluoride concentrations using the quantity and average monthly flows. The fluoride concentrations range from 0.306 mg/L to 4.01 mg/L. Table 3-21 also presents the facility’s fluoride discharges for 2011 through 2014. As shown, discharges were nearly unchanged from 2011 to 2012, but decreased steadily from 2012 to 2014. Similar to the 2013 Annual Review, EPA found th at fluoride concentrations for U.S. Steel Gary Works fall at the low end of the range of concentrations achievable by current technologies described above.

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Table 3-20. U.S. Steel Gary Works’ 2013 DMR Fluoride Discharges

Outfall Date Reported Monthly Average Flow (MGD) Reported Monthly Average Quantity (kg/d) Calculated Monthly Average Concentration (mg/L)

005 31

- Jan

- 13 38.8 84.3 0.574

005 28

- Feb

- 13 41.4 77.1 0.492

005 31

- Mar

- 13 41.7 86.6 0.549

005 30

- Apr

- 13 42.6 86.1 0.534

005 31

- May

- 13 41.4 66.6 0.425

005 30

- Jun

- 13 44.7 68.4 0.404

005 31

- Jul

- 13 45.3 72.1 0.421

005 31

- Aug

- 13 47.5 71.2 0.396

005 30

- Sep

- 13 47.7 62.1 0.344

005 31

- Oct

- 13 43.7 67.1 0.406

005 30

- Nov

- 13 46.2 53.5 0.306

005 31

- Dec

- 13 52.4 62.5 0.315

028 31

- Jan

- 13 8.6 105 3.23

028 28

- Feb

- 13 7.2 86.6 3.18

028 31

- Mar

- 13 7.1 86.1 3.20

028 30

- Apr

- 13 7.1 74.3 2.76

028 31

- May

- 13 8.4 87.5 2.75

028 30

- Jun

- 13 8.1 105 3.42

028 31

- Jul

- 13 8.2 109 3.51

028 31

- Aug

- 13 8.6 103 3.16

028 30

- Sep

- 13 9.2 119 3.42

028 31

- Oct

- 13 7.6 82.9 2.88

028 30

- Nov

- 13 8.4 92.1 2.90

028 31

- Dec

- 13 7.9 120 4.01

030 31

- Jan

- 13 20.5 249 3.21

030 28

- Feb

- 13 20.2 251 3.28

030 31

- Mar

- 13 18.6 234 3.33

030 30

- Apr

- 13 18.7 205 2.90

030 31

- May

- 13 20.9 224 2.83

030 30

- Jun

- 13 18.7 228 3.23

030 31

- Jul

- 13 19.0 265 3.69

030 31

- Aug

- 13 19.4 245 3.34

030 30

- Sep

- 13 19.4 257 3.51

030 31

- Oct

- 13 14.1 163 3.06

030 30

- Nov

- 13 17.4 224 3.40

030 31

- Dec

- 13 18 264 3.87

Source: DMRLTOutput2013_v1

Table 3-21. U.S. Steel Gary Works’ Fluoride Discharges for 2011 – 2014

Year Pounds of Fluoride Discharged Fluoride TWPE

2011 339,000 10,200

2012 346,000 10,400

2013 324,000 9,730

2014 293,000 8,800

Source: DMRLTOutput2013_v1; DMR Loading Tool.

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ArcelorMittal Weirton LLC

ArcelorMittal Weirton LLC in Weirton, WV, discharges fluoride from outfalls 003 and 004 into the Ohio River and Harmon Creek, respectively. The facility discharges cooling water,

stormwater r unoff, and process waste water from outfall 003 , and untreated stormwater through outfall 004. EPA previously reviewed fluoride discharges from this facility as part of the 2013

Annual Review. The facility’s 2008 permit calls for monitoring of fluoride disc harges from outfall 003, but does not include fluoride limits. The fluoride permit limit for outfall 004 is 1.4 mg/L monthly average and 2.2 mg/L daily maximum (WVDEP, 2008b).

Table 3-22 presents the facility’s fluoride discharge data for 2013. As described above, EPA determined that current wastewater technologies (not specific to iron and steel) are achieving effluent fluoride concentrations between 2 mg/L and 15 mg/L. EPA determined th at 2013 fluoride concentrations from outfall 004, shown in Table 3-22 are below the facility’s permit limit and below concentrations achievable by current technologies. However, the fluoride concentrations from outfall 003 are substantially higher than outfall 004, by an order of magnitude. Table 3-23 presents the fa cility’s fluoride discharges for 2011 through 2014. As shown, discharges have remained consistent from 2011 through 2013, and have decreased from

2013 to 2014.

The facility received a revised permit, effective May 2014. This permit includes fluoride

limits for outfall 003 of 4.3 mg/L monthly average and 5.9 mg/L daily maximum, effective May 1, 2017, based on water quality standards (WVDEP, 2014; WVDEP, 2013a ). As the facility comes into compliance with the new permit limits , EPA expects that fluoride discharges from

ArcelorMittal Weirton LLC will decrease in future DMRs.

Table 3-22. ArcelorMittal Weirton LLC’s 2013 DMR Fluoride Discharges

Outfall Date Reported Monthly Average Flow (MGD) Reported Monthly Averag e Concentration (mg/L)

003 31

- Jan

- 13 10.3 8.05

003 31

- Mar

- 13 10.9 6.38

003 30

- Jun

- 13 11.7 9.1

003 31

- Dec

- 13 7.3 7.51

004 31

- Jan

- 13 0.77 0.27

004 28

- Feb

- 13 0.82 0.25

004 31

- Mar

- 13 0.66 0.28

004 30

- Apr

- 13 1.28 0.3

004 31

- May

- 13 0.6 0.3

004 30

- Jun

- 13 0.7 0.3

004 31

- Jul

- 13 1.6 0.3

004 31

- Aug

- 13 0.6 0.4

004 30

- Sep

- 13 0.7 0.4

004 31

- Oct

- 13 0.7 0.4

004 30

- Nov

- 13 0.7 0.4

004 31

- Dec

- 13 0.8 0.4

Source: DMRLTOutput2013_v1

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Table 3-23. ArcelorMittal Weirton LLC’s Fluoride Discharges for 2011 – 2014

Year Pounds of Fluoride Discharged Fluoride TWPE

2011 331,000 9,940

2012 357,000 10,700

2013 240,000 7,190

2014 216,000 6,490

Source: DMRLTOutput2013_v1; DMR Loading Tool.

U.S. Steel Granite City Works

U.S. Steel Granite City Works, in Granite City, IL, discharges fluoride from outfall 001 to Horseshoe Lake. Discharges consist of wastewater from numerous sources, including the blast furnace, the hot strip mill, the galvanizing lines, continuous casters, maintenance shops, laboratories, the coke plant, the cold mill, and the continuous pickler. Discharges also contain landfill leachates, sanitary, stormwater runoff, and boiler blowdown. EPA has not previously reviewed fluoride discharges from this facility. The facility received a revised permit, effective June 1, 2015. The fluoride limits were not revised, but continue to include a 4 mg/L (834 lb/day) daily maximum limit for fluoride from outfall 001, with no monthly average fluoride limits (ILEPA, 2015).

Table 3-24 presents the facility’s fluoride discharge data for 2013. EPA calculated the fluoride concentrations using the reported quantit ies and average monthly flows. The fluoride concentrations range from 2.17 mg/L to 4.49 mg/L. EPA determined that fluoride conce ntrations for U.S. Steel Granite City Works are generally below those achievable by current technologies,

described above. However, the June and July 2013 monthly average fluoride concentrations exceed the daily maximum permit limit. Table 3-25 presents the facility’s fluoride discharges for 2011 through 2014. As shown, discharge levels decreased from 2011 to 2014.

Table 3-24. U.S. Steel Granite City Works’ 2013 DMR Fluoride Discharges for Outfall 001

Date Reported Monthly Average Flow (MGD) Reported Monthly Average Quantity (kg/d) Calculated Monthly Average Concentration (mg/L)

31

- Jan

- 13 12.4 174 3.72

28

- Feb

- 13 15.4 175 3.00

31

- Mar

- 13 16.4 190 3.06

30

- Apr

- 13 16.1 186 3.05

31

- May

- 13 15.2 175 3.04

30

- Jun

- 13 14.7 250 4.49 a

31

- Jul

- 13 14.5 244 4.46 a

31

- Aug

- 13 17.1 198 3.06

30

- Sep

- 13 16.9 175 2.74

31

- Oct

- 13 19.2 161 2.22

30

- Nov

- 13 18.0 220 3.24

31

- Dec

- 13 17.9 147 2.17

3-283— EPA’s 2015 Preliminary Category Reviews

3.4

— Iron and Steel Manufacturing (40 CFR Par t 420)

Source: DMRLTOutput2013_v1

.

a Fluoride concentration exceeds daily maximum permit limit.

Table 3-25. U.S. Steel Granite City Works’ Fluoride Discharges for 2011 – 2014

Year Pounds of Fluoride Discharged Fluoride TWPE

2011 163,000 4,880

2012 158,000 4,750

2013 154,000 4,620

2014 141,000 4,240

Source: DMRLTOutput2013_v1; DMR Loading Tool.

ArcelorMittal Burns Harbor LLC

ArcelorMittal Burns Harbor LLC, in Burns Harbor, IN, discharges fluoride from outfall

002. EPA has not previously reviewed fluoride discharges from this facility. Table 3- 26 presents the facility’s fluor ide discharge data for 2013. EPA calculated the fluoride concentrations using the quantity and average monthly flows. As shown, the fluoride concentrations range from 0.070 mg/L to 0.194 mg/L. EPA determined that fluoride concentrations for ArcelorMittal Burns Harbor are generally below those achievable by current technologies, described above. Additionally, Table 3-27 presents the facility’s fluoride discharges for 2011 through 2014. As shown, discharges increased from 2011 to 2012, but by 2014 had fallen back to below 2011

levels

.

Table 3-26. ArcelorMittal Burns Harbor 2013 DMR Fluoride Discharges for Outfall 002

Date Reported Monthly Average Flow (MGD) Reported Monthly Average Quantity (kg/d) Calculated Monthly Average Concentration (mg/L)

31

- Jan

- 13 255 141 0.146

28

- Feb

- 13 257 164 0.169

31

- Mar

- 13 255 166 0.172

30

- Apr

- 13 233 165 0.187

31

- May

- 13 194 51.7 0.070

30

- Jun

- 13 209 137 0.173

31

- Jul

- 13 241 122 0.134

31

- Aug

- 13 251 134 0.141

30

- Sep

- 13 260 148 0.150

31

- Oct

- 13 268 197 0.194

30

- Nov

- 13 225 155 0.182

31

- Dec

- 13 197 119 0.160

Source: DMRLTOutput2013_v1

Table 3-27. ArcelorMittal Burns Harbor Fluoride Discharges for 2011 – 2014

Year Pounds of Fluoride Discharged Fluoride TWPE

2011 84,700 2,540

2012 124,000 3,710

2013 114,000 3,410

2014 81,700 2,450

Source: DMRLTOutput2013_v1; DM R Loading Tool.

3-293— EPA’s 2015 Preliminary Category Reviews

3.4

— Iron and Steel Manufacturing (40 CFR Par t 420)

3.4.6 Iron and Steel Manufacturing Lead and Lead Compound Discharges in DMR and

TRI

EPA has not previously reviewed lead discharges from Iron and Steel Manufacturing facilities. Lead is a regulated pollutant in the Iron and Steel Manufacturing ELG, with limitations for seven of the thirteen subcategories. 19

EPA’s review of the lead DMR data revealed that 33 facilities account for 8,760 TWPE, with no facility contributing more than 2,300 TWPE. EPA’s investigation of TRI

- reported lead and lead compound data revealed that 133 facilities account for 22,700 TWPE. EPA identified one facility, Charter Steel Cleveland, in Cuyahoga Heights, OH, that accounts for 4,360 TWPE (19 percent of the 2013 TRI lead and lead compound releases) (shown in Table 3-28 ). EPA further reviewed lead discharges for Charter Steel, as discussed below. EPA did not conduct facility

- specific investigat ions of the 33 facilities with DMR lead discharges or the remaining

132 facilities reporting TR I releases of lead and lead compounds as part of the 2015 Annual

Review because no facility contributes more than 2,300 TWPE.

Table 3-28. Top Facilities Reporting 2013 TRI Lead and Lead Compound Releases

Facility Name Facility Location Pounds of

Pollutant

Release d Pollutant

TWPE Percent of Category TWPE

Charter Steel Cleveland Cuyahoga Heights, OH 1,950 4,360 19.2%

All other lead and lead compound release s in the Iron and Steel Manufacturing Category a 8,170 18,300 80.8 %

Total 10,100 22,700 100%

Source: TRI LTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 132 additional facilities reported lead and lead compound releases in the 2013 TRI.

Charter Steel Cleveland in Cuyahoga Heights, OH, reported both indirect and direct

release s of lead and lead compounds to TRI . As part of the 2015 Annual Review, EPA contacted the facility to discuss their lead and lead compound TRI releases

. A stormwater permit regulates

the facility’s stormwate r releases to the Cuyahoga River. The facility does not have an individual NPDES permit. In addition to the direct stormwater release, t he facility has two onsite pretreatment plants that discharge to the Northeast Ohio Regional Sewer District. The facility

estimates indirect lead and lead compound releases by sampling at each pretreatment plant (Lawniczak, 2015).

The facility contact also explained that while calculating the amount of lead and lead compound releases transferred, they incorrectly converted from milligrams of lead to pounds of lead, resulting in an overestimate of the pounds reported to TRI for 2013. Correcting for this error decreases the facility’s lead and lead compounds TRI TWPE from 4,360 to 1,090.

19 Subpart B, Sintering Subcategory, Subpart C, Ironmaking Subcategory, Subpart D, Steelmaking Subcategory, Subpart E, Vacuum Degassing Subcategory , Subpart F, Continuous Casting Subcategory, Subpart I, Acid Pickling Subcategory, and Subpart J, Cold Forming Subcategory include limitations for lead.

3-303— EPA’s 2015 Preliminary Category Reviews

3.4

— Iron and Steel Manufacturing (40 CFR Par t 420)

The individual facility TWPE associated with lead discharges across the Iron and Steel Manufacturing Category appears to be relatively low (less than 2,300); however, a large number

of facilities reported lead discharges on DMR s and lead and lead compou nd releases to TRI in

2013.

3.4.7 Iron and Steel Manufacturing Nitrate Compound Release s in TRI

EPA has not previously reviewed nitrate compound discharges from Iron and Steel Manufacturing facilities. Nitrate compounds are not regulated pollutants in the Ir on and Steel Manufacturing Category ELG; however, three subparts have ammonia as N limitations

. 20

EPA’s investigation of the nitrate compound data revealed that one facility , AK Steel Corporation, in Rockport, IN, accounts for 47 percent of the 2013 nitrate releases (shown in

Table 3-29 ). EPA did not investigate the remaining 5 5 facilities reporting releases of nitrate as part of the 2015 Annual R eview because no individual facility contributes more than 3,200

TWPE.

Table 3-29. Top Facilities Reporting 2013 TRI Nitrate Compound Releases

Facility Name Facility

Location Po unds of Pollutant

Released Pollutant

TWPE Percent of Category

TWPE

AK Steel Corporation, Rockport Works Rockport, IN 15,900,00 0 11,900 4 6.6 %

All other nitrate

- releasing facilities in the Iron and Steel Manufacturing Category a 18,200,000 13,600 53.4 %

Total 34,100,000 25,400 100%

Source: TRI LTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 5 5 additional facilities reported nitrate compound releases in the 2013 TRI

.

AK Steel Corporation Rockport Works, in Rockport, IN, is an integrated steel mill, manufacturing iron and steel products and coke and cokemaking byproducts. The facility releases directly to the Grand Calumet River and Lake Michigan. The facility has repor t-only requirements for ammonia as N in their NPDES permit, but does not have nitrate compound reporting requirements (IDEM, 2011). As part of the 2015 Annual Review, EPA contacted AK Steel to discuss the Rockport facility nitrate compound releases reported to TRI.

The AK Steel contac t stated that nitrate compound releases are calculated the same at

each AK Steel facility. Each facility obtains a weekly composite outfall sample and analyzes it for nitrate as nitrogen. The facility averages the weekly concentrations for each month, multiplies by the average daily flow and the number of days in the month, and converts to pounds. This determines the pounds per month of nitrate as nitrogen released at the outfall. To calculate the amount of nitrate compou nds as required for TRI reporting, t he facility then converts the pounds per month of nitrate as nitrogen to pounds of nitrate as nitrate compounds,

20 Subpart A, Cokemaking Subcategory, Subpart B, Sintering Subcategory, and Subpart C, Ironmaking

Subca tegory, include limitations for Ammonia as N.

3-313— EPA’s 2015 Preliminary Category Reviews

3.4

— Iron and Steel Manufacturing (40 CFR Par t 420)

by multiplying by the molecular weight ratio of nitrate to nitrogen. 21 This step determines the pounds of nitrate compounds released per month. The facility totals each month to obtain the annual total nitrate compounds release d (Miracle, 2015). Table 3-30 present s the nitrate compound release s for 2008 through 2013 for AK Steel Rockport Works. As shown, releases decreased from 2010 to 2012, then increased again in 2013. The facility’s nitrate compound releases are the same order of magnitude as the other 55 facilities with nitrate compound releases combined, as shown in Table 3-29.

Table 3

- 30 . AK Steel Rockport Works’ TRI

- Reported Nitrate Compound Releases for

2008

– 2013

Year Pounds of Nitrate Released Nitrate TWPE

2008 17,300,000 12,900

2009 12,100,000 9,050

2010 23,500,000 17,600

2011 18,400,000 13,700

2012 14,400,000 10,800

2013 15,900,000 11,900

Source: TRI LTOutput2013_v1; DMR Loading Tool.

In general, the individual facility TWPE associated with nitrate discharges across the Iron and Steel Manufacturing Category appears to be relatively low (less than 3,200); however, a large number of facilities reported nitrate compound releases to TRI in 2013.

3.4.8 Iron and Steel Manufacturing Category Findings

The estimated toxicity of the Iron and Steel Manufacturing Category discharges resulted primarily from PCBs, cyanide, fluoride, and lead discharges reported on DMR s, and nitrate compound, lead and lead compound, manganese and manganese compound, and copper and copper compound releases reported to TRI. From the 2015 Annual Review, EPA found:

• PCBs

. One facility, U.S. Steel Fairless Hills Works, in Fairless Hills, PA, accounts for 100 percent of the DMR PCB discharges. The facility is working with the Delaware River Basin Commission ( DRBC ) to determine the source of the PCB discharges, but believes th e discharges are from historical production activities on the site. The facility’s PCB discharges have also decreased from 2013 to 2014. For these reasons, EPA does not consider the facility’s PCB discharges to be representative of discharges across the ca tegory.

• Cyanide

. Two facilities, Mountain State Carbon, in Follansbee, WV, and U.S. Steel Clairton Plant, in Clairton, PA, account for 76 percent of the DMR cyanide discharges. EPA reviewed the cyanide discharges and found:

− EPA identified an error in Mountain State Carbon’s cyanide discharges. Correcting this error decreases the facility’s cyanide TWPE from 12,100 to 5,570. However, two months of cyanide discharges from one outfall at Mountain State Carbon exceed the facility’s permit limits.

21 Molecular weight ratio is 4.43: the molecular weight of nitrate is 62; the molecular weight of nitrogen is 14.

3-323— EPA’s 2015 Preliminary Category Reviews

3.4

— Iron and Steel Manufacturing (40 CFR Par t 420)

− U.S. Stee l Clairton Plant’s cyanide discharges are below permit limits and the LTA for cyanide calculated for the 2002 rulemaking. The facility’s high cyanide TWPE is likely the result of the large amount of industrial activity at the facility,

as it has historical ly been the top coke producer in the U.S.

− Because t he majority of cyanide discharges from the Iron and Steel Manufacturing Category are attributed to two facilities

, EPA does not consider

them to be representative of the Iron and Steel Category

.

• Fluoride

. Four facilities account for 94 percent of DMR fluoride discharges. EPA determined that current wastewater technologies (not specific to iron and steel) are achieving effluent concentrations between 2 mg/L and 15 mg/L. For two of the top fluoride discharging facilities, EPA concluded that the fluoride concentrations are generally below those achi evable by current technologies. One facility, ArcelorMittal Weirton LLC in Weirton, WV, received a revised permit in 2014 that includes

fluoride limits for outfall s 003 and 004. Therefore, EPA expects that fluoride discharges will decrease on future DMRs for this facility. The remaining facility, U.S. Steel Granite City Works, has discharges above permit limits.

• Lead

. One facility, Charter Steel Cleveland, in Cuyahoga Heights, OH, accounts for 19 percent of the TRI lead and lead compound releases. The facility identified a data error in the indirect releases reported to TRI. Correcting this error, decreases the facility’s lead and lead compound TWPE from 4,360 to 1,100. After the correction for Charter Steel Cleveland, EPA determined that all facilities with lead discharges in the 2013 DMR and TRI databases contributed less than 2,300 TWPE each. However, EPA notes that a large number of facilities reported lead and l ead compounds to TRI and lead discharges on DMRs in 2013 (133 and 33 facilities, respectively).

• Nitrate

. One facility, AK Steel Corporation Rockport Works, in Rockport, IN, accounts for 47 percent of the TRI nitrate compound releases and bases its load

re ported to TRI on sampling data. The individual facility TWPE associated with nitrate discharges across the remainder of the Iron and Steel Manufacturing Category appears to be relatively low (less than 3,200); however, EPA notes that a large

number of faci lities (56 facilities) reported nitrate releases to TRI in 2013.

• Manganese and Copper

. EPA did not further investigate manganese and manganese compounds and copper and copper compounds as part of the 2015 Annual Review because they contribute a small amount of TWPE relative to the other top pollutants (less than 6,000 TWPE each). However, E PA notes that a large number of facilities reported manganese and manganese compound and copper and copper compound releases to TRI in 2013 (114 and 79 facilities, respectively) and these pollutants are not regulated by the Iron and Steel Manufacturing ELGs.

3.4.9 Iron and Steel Manufacturing Category References

1. Bley, Doug. 2015. Telephone Communication Between Doug Bley, ArcelorMittal Burns Harbor LLC, and William Swietlik, U.S. EPA, Re: 2013 TRI Lead Discharges. (June 30)

. EPA

- HQ

- OW -2015-0665. DCN 08129.

3-333— EPA’s 2015 Preliminary Category Reviews

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— Iron and Steel Manufacturing (40 CFR Par t 420)

2. ERG . 2015. Preliminary Category Review – Facility Data Review for Point Source Category – 420 –Iron and Steel Manufacturing. ( September ). EPA

- HQ

OW -2015-0665. DCN 08130.

3. GCIP. 2002. General Chemical Industrial Products. Chapter 14 – Wastewater and

Water Treat ment. EPA- HQ

- OW -2004-0032-2606.

4. IDEM. 2011. Indiana Department of Environmental Management. NPDES Permit: AK Steel Rockport Works, Rockport, IN (IN0059650). (July 1). EPA

- HQ

OW -2015-0665. DCN 08131.

5. ID EM. 2014. Indiana Department of Environmental Management. Amended NPDES Permit: U.S. Steel Gary Works, Gary, IN (IN0000281). (March 21). EPA

HQ

- OW -2015-0665. DCN 08132.

6. ILEPA. 2015. Illinois Environmental Protection Agency. NPDES Permit: U.S. Steel Granite City Works, Granite City, IL (IL0000329). (May 22). EPA

- HQ

- OW

2015-0665. DCN 08133.

7. Ionics. n.d. The EnChem® Process for Fluoride Removal. Wastewater Treatment for the Microelectronics Industry . EPA

- HQ

- OW -2004-0032-2605.

8. Lasko , Brian. 2015. Telephone and Email Communication Between Brian Lasko,

U.S. Steel, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR and TRI Discharges for U.S. Steel Facilities. (May 27)

. EPA

- HQ

- OW -2015-0665.

DCN 08134.

9. Lawniczak, Jay. 2015. Telephone and Email Communication Between Jay Lawniczak, Charter Steel Cleveland, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 TRI Lead and Lead Compound Discharges for Charter Steel. (June 1)

. EPA

- HQ

- OW -2015-0665. DCN 08135.

10. Miracle, Dave. 2015. Telephone and Email Communication Between Dave Miracle, AK Steel, and Ki mberly Bartell, Eastern Research Group, Inc., Re: 2013 TRI Nitrate Discharges. (May 21)

. EPA

- HQ

- OW -2015-0665. DCN 08136.

11. PADEP. 2002. Pennsylvania Department of Environmental Protection. NPDES Permit: U.S. Steel Clairton Works, Clairton, PA (PA0004472). (F ebruary 1 ).

EPA

- HQ

- OW -2015-0665. DCN 08137.

12. PADEP. 2012. Pennsylvania Department of Environmental Protection. NPDES Permit: U.S. Steel Clairton Works, Clairton, PA (PA0004472). (May 1). EPAHQ

- OW -2015-0665. DCN 08138.

13. PADEP. 2015. Pennsylvania Department o f Environmental Protection. NPDES Permit: U.S. Steel Clairton Works, Clairton, PA (PA0004472). (February 1).

EPA

- HQ

- OW -2015-0665. DCN 08139.

14. Smith, Patrick. 2015. Telephone and Email Communication Between Patrick Smith, Mountain State Carbon, and Kimberly Bartell, Eastern Research Group,

3-343— EPA’s 2015 Preliminary Category Reviews

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— Iron and Steel Manufacturing (40 CFR Par t 420)

Inc., Re: 2013 DMR Cyanide Discharges. (May 13). EPA

- HQ

- OW -2015-0665.

DCN 08140.

15. U.S. EPA. 2002. Development Document for Final Effluent Limitations Guidelines and Standards for the Iron and Steel Manufacturing Point Source Category . Washington, D. C. EPA -821-R-02-004. EPA- HQ

- OW -2010-0824-0119.

16. 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, D.C. (October). EPA- HQ

- OW -2008-0517­

0515.

17. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. (December). EPA 821-R-12-001. EPA- HQ

- OW -2010-0824­

0195.

18. U.S. EPA. 2014. The 2013 Annual Effluent Guidelines Review Report

. Washington, D.C. (September). EPA-821-R-14-003. EPA- HQ

- OW -2014-0170­

0077.

19. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan. Washington, D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN

08208.

20. WC&E. 2006. Wastech Controls & Engineeri ng, Inc. Fluoride Wastewater Treatment (FWT) HF Neutralization or Fluoride Reduction. EPA

- HQ

- OW -2004­

0032-2604.

21. WVDEP. 2008a. West Virginia Department of Environmental Protection. NPDES Permit: Mountain State Carbon, Follansbee, WV (WV0004499). (January 15).

EPA

- HQ

- OW -2010-0824-0067.

22. WVDEP. 2008b. West Virginia Department of Environmental Protection. NPDES Permit: Arcelormittal Weirton Inc. (Weirton Steel Corporation), Weirton, WV (WV0003336). (July 28). EPA- HQ

- OW -2014-0170-0019.

23. WVDEP . 2013 a. West Virginia Department of Environmental Protection. NPDES

Fact Sheet Addendum: Arcelormittal Weirton Inc. (Weirton Steel Corporation), Weirton, WV (WV0003336) . EPA

- HQ

- OW -2015-0665. DCN 08310.

24. WVDEP . 2013b. West Virginia Department of Environmental Protection. NPD ES Permit: Mountain State Carbon, Follansbee, WV (WV0004499). (August 29).

EPA

- HQ

- OW -2015-0665. DCN 08141.

25. WVDEP . 2014. West Virginia Department of Environmental Protection. NPDES Permit: Arcelormittal Weirton Inc. (Weirton Steel Corporation), Weirton, WV (WV0003336). ( March 18 ). EPA

- HQ

- OW -2015-0665. DCN 08142.

3-353— EPA’s 2015 Preliminary Category Reviews

3.5

— Landfills (40 CFR Part 445)

3.5 Landfills (40 CFR Part 445)

EPA identified the Landfills C ategory for preliminary review because it ranks high again

, in terms of toxic-weighted pound equivalents (TWPE), in the final 2015 combined point source category rankings. Previously, EPA reviewed discharges from this category as part of the 2010 and 2011 Annual Reviews in which it also ranked high (U.S. EPA, 2011, 2012). This section

summarizes the results of the 2015 Annual Review. EPA focused its 2015 review on discharges

of cadmium

, selenium , and iron because of their high TWPE rel ative to the other pollutants discharged by facilities in the Lan d fills Category. Of these three pollutants, only iron was reviewed in the 2010 and 2011 Annual Reviews. For the 2015 Annual Review, available discharge data also showed significant contributions of cadmium and selenium.

3.5.1 Landfills Category 2015 Toxicity Rankings Analysis

Table 3-31 compares the toxicity ranking analyses ( TRA ) data for the Landfills Categor y from the 2011, 2013, and 2015 Annual Reviews. EPA did not conduct the TRA in 2012 or 2014, but instead reviewed additional data sources as part of the even

- year annual review

, as described in Section 2.2.1 of EPA’s Preliminary 2016 Plan (U.S. EPA, 2016). As discussed in this section, during the 2015 Annual Review, EPA identified data corrections that affected the 2013 Discharge Monitoring Report (DMR) data and TWPE. The bottom row of Table 3- 31 shows the corrected data resulting from this review.

Table 3-31. Landfills Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

Year of Discharge Year of

Review Landfills Category Facility Counts a Landfills Category TWPE

Total TRI

Facilities Total DMR Major

Facilities Total DMR

Minor

Facilities TRI

TWPE b DMR TWPE c Total

TWPE

2009 2011 19 7 194 2,750 29, 70 0 d 32,400 d

2011 2013 1 5 190 42,900 e 19,300 62,100

166,000 f 166,000 f

2013 2015 4 4 175 235 116 ,000 g 116 ,000 g

Sources: TRIReleases2009_v2

, DMRLoads2009_v2 , and 2011 Annual Review Report (for 2009 DMR data ) (U.S. EPA, 2012 ); DMRLTOutput2011_v1 (for 2011 DMR); TRILTOutput2011_v1 (for 2011 TRI); DMRLTOutput2013_v1 (for 2013 DMR); TRILTOutput2013_v 1 (for 2013 TRI)

Note: EPA did not evaluate 2010 or 2012 DMR and TRI data Note: TWPE values are rounded to three significant figures. Sums of individual values may not equal the total presented, due to rounding.

a Number of facilities with TWPE greater than zero.

b Releases include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for

POTW removals. Includes DMR data from both major and minor dischargers

. d 2009 data after corrections were made during the 2011 Annual Review.

e The majority of the 2011 TRI TWPE was attributed to one facility, Clean Harbors Deer Park LLC in La Porte,

TX. This facility was reassigned to the Unassigned Waste Facili ty Category.

f 2013 data prior to corrections made during the 2015 Annual Review.

g 2013 data after corrections were made during the 2015 Annual Review.

3-36 c3— EPA’s 2015 Preliminary Category Reviews

3.5

— Landfills (40 CFR Part 445)

As shown in Table 3-31 , the total TWPE increased from 2009 to 2013, while the number

of Toxic Release Inventory ( TRI ) facilities and DMR facilities decreased from 2009 to 2013.

3.5.2 Landfills Category Pollutants of C oncern

EPA’s 2015 review of the Landfills Category focused on the 2013 DMR discharges

because the DMR data dominate the category’s combined TWPE. Table 3-32 shows the five pollutants with the highest contribution to the 2013 DMR TWPE. Table 3-32 also presents the 2013 DMR TWPE after EPA corrected two errors identified in this preliminary category review (discussed in the sections below). As a point of comparison, Table 3-32 shows the 2011 DMR facility count and TWPE for these top pollutants, based on the 2013 Annual Review (U.S. EPA,

2014 ).

Cadmium , selenium, and iron contribute more than 88 percent of the original 2013 DMR

TWPE for the Landfills Category (prior to corrections discussed below). Cadmium , selenium,

and iron are not regulated in the Landfills Category effluent limitations guidelines and standards (ELGs) (40 CFR Part 445). EPA’s investigations of reported discharges of the top t hree pollutants are presented in Sections 3.5.3, 3.5.4, and 3.5.5. EPA did not investigate the other pollutants, including arsenic and silver , as part of the 2015 Annual Review, because they represent a small percentage ( 6 percent) of the 2013 DMR TWPE for the Landfills Category.

Table 3-32. Landfills Category Top DMR Pollutants

Pollutant b 2013 DMR Data a 2011 DMR Data a

Number of Facilities Reporting

Pollutant c Original

TWPE Corrected

TWPE Number of Facilities Reporting

Pollutant c TWPE

Cadmium 25 91,700 91,700 28 1,370

Selenium 23 40,800 195 23 249

Iron 138 14,500 4,910 136 5,05 0

Arsenic 37 8,010 8,010 32 1,370

Silver 9 2,270 2,270 8 1,590

Top Pollutant

Total NA 157,000 1 0 7,000 NA 9

, 6 3 0

Landfills Category Total 179 166,000 1 1 6,000 195 19,300

Sources: DMRLTOutput2013_v1 (for 2013 TWPE); DMRLTOutput2011_v1 (for 2011 TWPE) Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable.

a Includes DMR data from both major and minor dischargers.

b Arsenic and silver discharges combined contribute 6 percent of the original 2013 category DMR TWPE. Therefore, EPA did not review arsenic or silver discharges as part of the 2015 Annual Review.

c Number of facilities with TWPE greater than zero.

3.5.3 Landfills Category Cadmium Discharges in DMR

EPA’s investigation of the cadmium discharges revealed that one facility, Henderson City Landfill in Henderson, KY , accounts for over 99 percent of the 2013 DMR cadmium discharges

3-373— EPA’s 2015 Preliminary Category Reviews

3.5

— Landfills (40 CFR Part 445)

(shown in Table 3-33 ). EPA did not investigate the remaining facilities discharging cadmium as

part o f the 2015 Annual R eview.

Table 3-33. Top 2013 DMR Cadmium Discharging Facilities

Facility Name Facility

Location Pounds of

Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

Henderson City Landfill Henderson, KY 3,940 91,100 99.3

All other cadmium dischargers in the Landfills Category a 26.4 610 0.7

Total 3,970 91,700 100%

Source: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 24 additional facilities submitted cadmium discharges in the 2013 DMR data.

Henderson City Landfill in Henderson, KY, discharges cadmium through two outfalls and reports quarterly cadmium concentrations, shown in Table 3-34. As shown in Table 3-34, March 2013 discharges from outfall 001 are significantly greater than other discharges. As part of the 2015 Annual Review, EPA contacted the facility about their cadmium discharges. The facility contact confirmed the 2013 cadmium discharges and explained that the March 2013

concentration is an outlier. The facility experienced a l arge rainstorm event during this month,

which caused a leachat e tank flood on the same day sampling was conducted at the outfall. The March 2013 sample was not representative of typical operation conditions at the facility (Williams, 2015). EPA reviewed 2014 cadmium discharges and confirmed the total cadmium

TWPE to be 0.8.

Table 3-34 . Henderson City Landfill’s 2013 DMR Quarterly Cadmium Discharges

Outfall Date Monthly Average Flow (MGD) Monthly Average Cadmium Concentration (mg/L)

001 31

- Mar

- 13 0.100 52.50

001 30

- Jun

- 13 0.014 0.001

001 30

- Sep

- 13 No Discharge

001 31

- Dec

- 13 0.006 0.00005

002 31

- Mar

- 13 0.036 0.001

002 30

- Jun

- 13 0.021 0.001

002 30

- Sep

- 13 0.001 0.001

002 31

- Dec

- 13 0.005 0.001

Source: DMRLTOutput2013_v1.

3.5.4 Landfills Category Selenium Discharges in DMR

EPA’s investigation of the selenium discharges revealed that one facility, South Carolina Generating Company (SCGENCO) / Williams Ash Disposal Facility in Moncks Corne r, SC, accounts for over 99 percent of the 2013 DMR selenium discharges (shown in Table 3-35 ). EPA did not investigate the remaining facilities discharging selenium as part of the 2015 Annual

R eview.

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— Landfills (40 CFR Part 445)

Table 3-35. Top 2013 DMR Selenium Discharging Facilities

Facility Name Facility Location Pounds of Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

SCGENCO/Williams Ash Disposal Facility Moncks Corner,

SC 36,300 40,600 99.5

All other selenium dischargers in the Landfills Category a 175 195 0.5

Total 36,500 40,800 100%

Source: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 22 additional facilities submitted selenium discharges in the 2013 DMR data.

SCGENCO/Williams Ash Disposal Facility is a landfill for the disposal of coal ash and

gypsum from SCGENCO/Williams Station in Goose Creek, SC (SH DHEC, 2013a). SCGENCO discharges selenium from one outfall, which contains ash landfill runoff, ash landfill leachate, and truck wash water (SC DHEC, 2013b). As part of the 2015 Annual Review, EPA contacted the South Carolina Department of Health and Environmental Control (SC DHEC) to confirm the facility’s selenium discharges. SC DHEC indicated that the facility’s 2013 selenium concentrations were rep orted in units of micrograms per liter (μg/L) instead of milligrams per liter (mg/L) (Rippy, 2015). Table 3-36 presents the original and corrected concentrations, and average flow rates from the facility. After correcting the concentrations, the facility’s selenium TWPE decreases from 40,600 to 40.4.

Table 3-36 . SCGENCO/Williams Ash Disposal Facility’s 2013 DMR Original a nd Corrected Selenium Discharges from Outfall 001

Date Monthly Average Flow (MGD) Original Monthly Average

Selenium Concentration (mg/L) Corrected Monthly Average

Selenium Concentration (mg/L)

31

- Jan

- 13 0.27 6.1 0.0061

29

- Feb

- 13 1.21 15.8 0.0158

31

- Mar

- 13 0.33 16.4 0.0164

30

- Apr

- 13 0.16 21.1 0.0211

31

- May

- 13 0.45 22.9 0.0229

30

- Jun

- 13 No Discharge

31

- Jul

- 13 1.17 25.6 0.0256

31

- Aug

- 13 1.29 28.4 0.0284

30

- Sep

- 13 No Discharge

Source: DMRLTOutput2013_v1.

SC DHEC also provided the facility’s NPDES permit and permit rationale. SCGENCO/Williams Ash Disposal Facility’s NPDES permit ( SC0046175 ), effective March 4, 2009 to September 30, 2013, required monthly monitoring and reporting for selenium (SC DHEC, 2009a, 2009b). When the permit was reissued in 2013 (effective October 1, 2013), neither monitoring requirements nor permit limits were placed on selenium because SC DHEC determined that the selenium discharges showed no reasonable potential to cause or contribute to a water quality violation (SC DHEC, 2013a, 2013b). For this reason, selenium discharges were only reported through September 2013, as shown in Table 3- 36

.

3-393— EPA’s 2015 Preliminary Category Reviews

3.5

— Landfills (40 CFR Part 445)

Additionally, after reviewing SCGENCO/Will iams Ash Disposal Facility’s NPDES permit, EPA determined that the landfill operates and receives waste directly from the

SCGENCO Williams Station coal -fired power plant. The Landfills ELGs do not apply to discharges of landfill wastewater from landfills operated in conjunction with other industrial or commercial operations when the landfill only receives wastes generated by the industrial or commercial operation directly associated with the landfill (40 CFR Part 445). For this reason,

EPA determined that SCGENCO should instead be classified under the Steam Electric Power Generating Category (40 CFR Part 423).

3.5.5 Landfills Category Iron Discharges in DMR

EPA’s investigation of iron discharges revealed that two facilities

, Bluegrass Containment LLC, in Hart ford , KY , and Bavarian Trucking, in Walton, KY, account for over 85 percent of the 2013 DMR iron discharges (shown in Table 3-37). EPA did not investigate the

remaini ng facilities discharging iron as part of the 2015 Annual R eview.

Table 3-37. Top 2013 DMR Iron Discharging Facilities

Facility Name Facility

Location Pounds of Pollutant Discharged Pollutant

TWPE Percent of Category

TWPE

Bluegrass Containment LLC Hartford, KY 1,720,000 9,620 66.2

Bavarian Trucking Walton, KY 501,000 2,810 19.3

All other iron dischargers in the Landfills Category a 375,000 2,100 14.5

Total 2,590,000 14,500 100%

Source: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 136 additional facilities submitted iron discharges in the 2013 DMR data.

Bluegrass Containment LLC

Bluegrass Containment LLC discharges iron from one outfall and reports monthly iron concentrations, shown in Table 3-38 for 2013. As shown in Table 3-38, the February 2013 iron concentration reported from outfall 001 was far greater than other months’ concentrations. As part of the 2015 Annual Review, EPA contacted the Kentucky Department for Environmental Protection, which confirmed the February 2013 iron concentration (Milburn, 2015). EPA also contacted the laboratory that submitted the DMR on behalf of Bluegrass Containment LLC. The laboratory contact indicated that the February 2013 iron concentration was measured in μg/L and incorrectly converted to m g/L on the DMR by multiplying by 1,000 instead of dividing by 1,000. The correct iron concentration is 0.525 mg/L (Gish, 2015). Table 3-38 presents the original and

c orrected concentrations, and average flow rates from the facility. Correcting the concentrations, decreases the facility’s iron TWPE from 9,620 to 0.015, reducing the Landfills Category iron TWPE from 14,500 to 4,910, as shown in Tabl e 3-32.

3-403— EPA’s 2015 Preliminary Category Reviews

3.5

— Landfills (40 CFR Part 445)

Table 3-38. Bluegrass Containment LLC’s 2013 DMR Original and Corrected Iron Discharges from Outfall 001

Date Monthly Average

Flow (MGD) Original Monthly Average Iron Concentration (mg/L) Corrected Monthly Average Iron Concentration (mg/L)

31

- Jan

- 13 0.36 1.07 1.07

29

- Feb

- 13 0.014 525,000 0.525

31

- Mar

- 13 0.108 0.66 0.66

30

- Apr

- 13 0.004 0.14 0.14

31

- May

- 13 0.072 0.27 0.27

30

- Jun

- 13 0.57 0.24 0.24

31

- Jul

- 13 0.014 0.101 0.101

31

- Aug

- 13 0.001 0.15 0.15

30

- Sep

- 13 0.005 0.15 0.15

31

- Oct

- 13 0.00001 0.36 0.36

30

- Nov

- 13 0.001 0.36 0.36

31

- Dec

- 13 0.004 0.15 0.15

Source: DMRLTOutput2013_v1.

Bavarian Trucking

Bavarian Trucking discharges iron from one outfall and reports daily maximum and monthly average iron concentrations, shown in Table 3-39 . The facility has a daily max imum

iron limit of 4 mg/L. As shown in Table 3-39 , the iron concentrations exceed the permit limit during several months in 2013 . The facility’s Clean Water Act compliance status was classified as Category I 22 during 2013 due to several effluent violations of permit limits for iron and other pollutants.

22 S everity of violations is calculated according to the Clean Water Act regulations, which have specific criteria specifying the duration, severity, and type of violations that rise to the level of Significant Noncompliance (SNC). SNC can occur at major facilities. The calculation of "Category I" violations is equivalent to the SNC calculations, but because the violations occur at smaller dischargers (non

- major), EPA does not classi fy the

violations as SNC.

3-413— EPA’s 2015 Preliminary Category Reviews

3.5

— Landfills (40 CFR Part 445)

Table 3-39. Bavarian Trucking’s 2013 DMR Iron Discharges from Outfall 001

Date Monthly Average Flow (MGD) Daily Maximum/Monthly Average Iron Concentration (mg/L) a

31

- Jan

- 13 0.160 13.4

29

- Feb

- 13 0.209 87.2

31

- Mar

- 13 No Discharge

30

- Apr

- 13 0.170 9.11

31

- May

- 13 0.084 35.7

30

- Jun

- 13 467 3.61

31

- Jul

- 13 No Discharge

31

- Aug

- 13 0.320 852

30

- Sep

- 13 No Discharge

31

- Oct

- 13 0.039 3.12

30

- Nov

- 13 0.029 0.326

31

- Dec

- 13 0.380 17.7

Source: D MRLTOutput2013_v1; US EPA, 2015.

a The facility reported the same concentration values for daily maximum and monthly average for each monitoring period in 2013

.

3.5.6 Landfills Category Findings

The estimated toxicity of the Landfills Category discharges resulted primarily from

cadmium , selenium, and iron discharges reported on DMRs. From the 2015 Annual Review,

EPA found:

• Cadmium. One facility, Henderson City Landfill in Henderson, KY, accounts for more than 99 percent of the 2013 DMR cadmium discharges . The large discharge can be attributed to a single sampling event that was performed after a leachat e tank flood and was not representative of typical operating conditions at the facility. For this

reason
, EPA does not consider these discharges to be representative of the Landfills Category.

• Selenium. One facility, SCGENCO/Williams Ash Disposal Facility , in Mon cks Corner, SC, accounts for more than 99 percent of the 2013 DMR selenium discharges . SC DHEC confirmed that the selenium concentrations were reported in units of μg/L instead of mg/L. Incorporating this correction decreases the facility’s

selenium TWPE f rom 40,600 to 40.4.

• Iron. Two facilities, Bluegrass Containment in Hartford, KY, and Bavarian Trucking in Walton, KY, account for over 85 percent of the iron discharges in the 2013 DMR

data. EPA identified an error in the concentration data for iron for B luegrass Containment. With this error corrected, the facility’s iron TWPE decreases from 9,620 to 0.015, reducing the Landfills Category iron TWPE from 14,500 to 4,910. Bavarian Trucking exceeded its permit limit for iron during 2013.

3.5.7 Landfills Categor y References

1. ERG. 2015. Preliminary Category Review

– Facility Data Review for Point Source Category – 445 – Landfills . (September). EPA

- HQ

- OW -2015-0665. DCN

08143.

3-423— EPA’s 2015 Preliminary Category Reviews

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— Landfills (40 CFR Part 445)

2. Gish, Beverly. 2015. Telephone and Email Communication Between Beverly Gish, SMR Laboratories, Inc., and Eva Knoth, Eastern Research Group, Inc., Re:

2013 DMR Iron Discharges from Bluegrass Containment LLC . (May 21). EPA

HQ

- OW -2015-0665. DCN 08144.

3. Milburn, Jerry. 2015. Telephone and Email Communication Between Jerry Milburn, Kentucky Department for Environmental Protection, and Eva Knoth, Eastern Research Group, Inc., Re: 2013 DMR Iron Discharges from Bluegrass

Containment LLC . (May 21). EPA

- HQ

- OW -2015-0665. DCN 08145.

4. Rippy, Crystal. 2015. Telephone and Email Communication Between Crystal Rippy, South Carolina Department of Health and Environmental Compliance, and Eva Knoth, Eastern Research Group, Inc., Re: 2013 DMR Selenium Discharges from SCGENCO /A.M. Williams Ash Disposal Facility . (April 30). EPA

- HQ

- OW

2015-0665. DCN 08146.

5. SC DHEC. 2009a. South Carolina Department of Health and Environmental Compliance

. NPDES Permit Fact Sheet and Rationale: South Carolina Generating Company (SCGENCO) A.M. Will iams Station -Highway 52 Ash Disposal Facility (SC0046175). (February 27). EPA

- HQ

- OW -2015-0665. DCN

08147.

6. SC DHEC. 2009b. South Carolina Department of Health and Environmental Compliance

. NPDES Permit: South Carolina Generating Company (SCGENCO)

A.M. Willi ams Station-Highway 52 Ash Disposa l Facility (SC0046175) . (March 4). EPA

- HQ

- OW -2015-0665. DCN 08148.

7. SC DHEC. 2013a. South Carolina Department of Health and Environmental Compliance

. NPDES Permit: South Carolina Generating Company (SCGENCO)

A.M. Williams Station -Highway 52 Ash Disposal Facility (SC0046175) . (August

30 ). EPA

- HQ

- OW -2015-0665. DCN 08149.

8. SC DHEC. 2013b. South Carolina Department of Health and Environmental Compliance

. NPDES Permit Fact Sheet and Rationale: South Carolina Generating Company (SCGENCO ) A.M. Williams Station -Highway 52 Ash Disposal Facility (SC0046175) . (August 29 ). EPA

- HQ

- OW -2015-0665. DCN

08150.

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

2008-0517-0618.

10. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. (December). EPA 821-R-12-001. EPA- HQ -OW-2010-0824­

0195.

11. U.S. EPA. 2014. The 2013 Annual Effluent Guidelines Review Report

. Washington, D.C. (September). EPA-821-R-14-003. EPA- HQ

- OW -2014-0170­

0077.

3-433— EPA’s 2015 Preliminary Category Reviews

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— Landfills (40 CFR Part 445)

12. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan. Washington, D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN

08208.

13. Williams, Brian. 2015. Telephone and Email Communication Bet ween Brian Williams, Henderson City Landfill, Henderson, KY, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Cadmium Discharges . (February 12). EPA

- HQ

- OW -2015-0665. DCN 08151.

3-443— EPA’s 2015 Preliminary Category Reviews

3.6

—

Meat and Poultry Products (40 CFR Part 432 )

3.6 Meat and Poultry Products (40 CFR Part 432)

EPA identified the Meat and Poultry Products (Meat and Poultry) Category for preliminary review because it ranks high again, in terms of toxic-weighted pound equivalents (TWPE), in the final 2015 combined point source category rankings. Previously, EPA reviewed discharges from this categ ory as part of the 2011 to 2013 Annual Reviews in which it also ranked high (U.S. EPA, 2012, 2014a, 2014b ). This section summarizes the results of the 2015 Annual Review. EPA focused its 2015 review on discharges of nitrate compounds and hydrogen sulfide because of their high TWPE relative to other pollutants discharged by facilities in the Meat and Poultry Category. Nitrate, reviewed as part of the 2011 and 2012 Annual Reviews, continues to be a top pollutant of concern. Hydrogen sulfide was added as a Toxic Release Inventory (TRI) reporting requirement in 2012. As a result, in 2013, hydrogen sulfide contributed a substantial amount of TWPE for the category. Therefore, for the 2015 Annual Review, available discharge data also showed significant contributions of hydrogen sulfide to the Meat and Poultry Category TWPE.

3.6.1 Meat and Poultry Category 2015 Toxicity Rankings Analysis

Table 3-40 compares the toxicity rankings analyses (TRA) data for the Meat and Poultry Category from the 2011, 2013, and 2015 Annual Reviews. EPA did not conduct the TRA in 2012 or 2014, but instead reviewed additional data sources as part of the even-year annual review, as described in Section 2.2.1 of EPA’s Preliminary 2016 Plan (U.S. EPA, 2016). During the 2015 Annual Review, EPA did not identify a ny data corrections to the 2013 discharge monitoring report (DMR) or TRI data for the Meat and Poultry Category.

Table 3-40. Meat and Poultry Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

Year of Discharge Year of

Review Meat and Poultry Category Facility Counts a Meat and Poultry Category TWPE

Total TRI

Facilities Total DMR Major

Facilities Total DMR

Minor

Facilities TRI

TWPE b DMR TWPE c Total

TWPE

2009 2011 173 38 88 53,800 17,200 71,000

2011 2013 156 32 99 39,100 13,700 d 52,800 d

2013 2015 179 29 4 6 81,500 8,220 89,700

Sources: TRIReleases2009_v2

, DMR Loads2009_v2 , and 2011 Annual Review Report (for 2009 DMR and TRI data ) (U.S. EPA, 2012 ); DMR LTOutput2011_v1 (for 2011 DMR ); TRILTOutput2011_v1 (for 2011 TRI) ;
DMR LTOutput2013_v1 (for 2013 DMR ); TRILTOutput2013_v 1 (for 2013 TRI)

. Note: EPA did not evaluate 2010 or 2012 DMR and TRI data

. Note: TWPE values are rounded to three significant figures. Sums of individua l values may not equal the total presented, due to rounding.

a Number of facilities with TWPE greater than zero.

b Releases include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for

POTW removals. The 2013 TRI TWPE also includes TWPE associated with reported releases of hydrogen sulfide. Facilities began reporting releases of hydrogen sulfide to TRI in 2012.

Includes DMR data from both major and minor dischargers

. d 2011 data after corrections were made during the 2013 Annual Review.

3-45 c3— EPA’s 2015 Preliminary Category Reviews

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—

Meat and Poultry Products (40 CFR Part 432 )

As shown in Table 3-40 , the tota l number of facilities reporting releases to TRI, and their respective TWPE, decreased from 2009 to 2011, but increased in 2013. During that same time period, the total number of fac ilities reporting discharges on DMRs and their respective TWPE decreased. The increase in TRI TWPE in 2013 is primarily due to releases from the facilities

described in the sections below.

3.6.2 Meat and Poultry Category Pollutants of Concern

EPA’s 2015 revi ew of the Meat and Poultry Category focused on the 2013 TRI releases

because the TRI data dominate the category’s combined TWPE

. Table 3-41 shows the five pollutants with the highest contribution to the 2013 TRI TWPE. As a point of comparison, Table 3-41 also shows the 2011 TRI facility count and TWPE for these top five pollutants, based on the 2013 Annual Review (U.S. EPA, 2014b ). Nitrate compounds and hydrogen sulfide contribute more than 98 percent of the total 2013 TRI TWPE. Because hydrogen sulfide was added as a TRI reporting requirement in 2012, no hydrogen sulfide releases were reported in 2011. EPA’s investigations of reported releases of the top two pollutants are presented in Sections 3.6.3 and

3.6.4. EPA did not investigate the other pollutants, including ammonia, sodium nitrite, and mercury and mercury compounds, as part of the 2015 Annual Review, because they represent a small percentage (less than 2 percent) of the 2013 TRI TWPE for the Me at and Poultry Category.

Table 3-41. Meat and Poultry Category Top TRI Pollutants

Pollutant a 2013 TRI Data 2011 TRI Data

Number of Facilities Reporting Pollutant b TWPE Number of Facilities Reporting Pollutant b TWPE

Nitrate Compounds 117 42,300 105 38,000

Hydrogen Sulfide 11 37,700 NA c NA c

Ammonia 118 797 114 876

Sodium Nitrite 11 455 5 16.8

Mercury and Mercury Compounds 1 155 1 170

Top Pollutant Total NA 81,500 NA 39,100

Meat and Poultry Category

Total 179 81,500 156 39,100

Sources: TRI LTOutput2013_v1 (for 2013 TWPE); TRI LTOutput2011_v1 (for 2011 TWPE). Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable.

a Ammonia, sodium nitrite, and mercury and mercury compounds releases combined contribute less than 2 percent of the 2013 category TRI TWPE. Therefore, EPA did not review any of these releases as part of the

2015 Annual Review.

b Number of facilities with TWPE greater than zero.

c Hydr ogen s ulfide was added as a TRI reporting requirement in 2012; it was not a TRI

- listed chemical in 2011.

3.6.3 Meat and Poultry Category Nitrate Compound Releases in TRI

EPA’s investigation of the nitrate compound releases revealed that 15 facilities account for approximately 59 percent of the 2013 TRI nitrate compound releases (as shown in Table 3­

42 ) . EPA did not investigate the remaining facilities discharging nitrate compounds as part of the

3-463— EPA’s 2015 Preliminary Category Reviews

3.6

—

Meat and Poultry Products (40 CFR Part 432 )

2015 Annual Review. EPA reviewed nitrate compound releases from the Meat and Poultry Category in detail as part of the 2011 and 2012 Annual Reviews. 23 Therefore, Table 3-42 also presents the 2009 TRI nitrate compound TWPE for comparison purposes.

23 EPA reviewed 2009 DMR and TRI data as part of the 2011 and 2012 Annual Reviews.

3-473— EPA’s 2015 Preliminary Category Reviews

3.6

—

Meat and Poultry Products (40 CFR Part 432 )

Table 3-42. Top Facilities Reporting 2013 TRI Nitrate Compound Releases

Facility Name 2013 TRI Data 2009 TRI Data a

Location Subcategory Nitrate Compound

Pounds Released Nitrate Compound

TWPE Percent of Nitrate Compound Category TWPE Nitrate Compound

TWPE

Cargill Meat Solutions Corp

. Schuyler , NE B 4,770,000 3,560 8.42% 2,870

Cargill Meat Solutions Corp

. Ottumwa , IA Undetermined 3,090,000 2,310 5.45% 686 b

John Morrell & Co

. Sioux Falls , SD Undetermined 2,870,000 2,150 5.07% 17.2 b

Pilgrim's Pride Corp Mt

. Pleasant Complex Mount Pleasant , TX K 2,590,000 1,930 4.56% 1,040

Cargill Meat Solutions Corp

. Beardstown , IL B 2,540,000 1,900 4.49% 2,730

T yson Fresh Meats Inc.

– Joslin, IL Hillsdale , IL B 2,530,000 1,890 4.46% 3,320

Lewiston Processing Plant Lewiston Woodville , NC L 2,050,000 1,530 3.61% 2,440

Tyson Fresh Meats Inc

. Lexington , NE B 1,890,000 1,410 3.34% 3,730

Tyson Fresh Meats Inc

. Columbus Junction , IA B 1,880,000 1,400 3.32% 1,210

Smithfield Packing Co

., Inc

., Tar Heel

Div

. Tar Heel , NC B 1,840,000 1,370 3.24% 2,800

Tyson Farms Inc.

– Carthage, MS Processing Plant Carthage , MS K 1,720,000 1,280 3.03% 251 b

Accomac Processing Plant Accomac , VA K 1,520,000 1,130 2.68% 1,550

JBS Plainwell Plainwell , MI B 1,330,000 997 2.35% 1,300

Cargill Meat Solutions Corp

. Fort Morgan , CO Undetermined 1,290,000 966 2.28% 761 b

Tyson Farms Inc

. - Blountsville Processing Plant Blountsville , AL L 1,290,000 964 2.28% 1,110

Remaining Facilities Reporting Nitrate Compounds Releases c 23,500,000 17,500 41.4 % 23,500

Total 56,700,000 42,300 100% 46,900

Source: TRIReleases2009_v2 ( for 2009 TRI)

, TRI LTOutput2013_v1 (for 2013 TRI); 2011 Annual Review Report (for 2009 TRI data and Subcategories ) (U.S. EPA,

2012 ); and 2012 Annual Review Report (for Subcategories) (U.S. EPA, 2014a). Note: EPA determined subcategories by reviewing available permits.

a EPA reviewed 2009 nitrate compound releases as part of the 2011 and 2012 Annual Reviews. Therefore, 2009 data is pr esented for comparison purposes.

b The facility was not reviewed as part of the 2011 or 2012 Annual Reviews.

102 additional facilities reported nitrate compound releases in the 2013 TRI database, wh ich account for approximately 41 percent of the cate gory’s nitrate compounds 2 013 TRI TWPE.

3-48 c3— EPA’s 2015 Preliminary Category Reviews

3.6

—

Meat and Poultry Products (40 CFR Part 432 )

EPA has identified s everal forms of nitrogen as pollutants of concern in meat and p oultry processing wastewaters: total Kjeldahl nitrogen (TKN), ammonia nit rogen, and nitrite plus

nitrate -nitrogen. Because protein is a major component of both meat and blood, meat and poultry

wastewaters can cont ain high concentrations of nitrogen. 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).

Nitrite and nitrate -nitrogen a re 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 is nitrification. Biological treatment is often required, at

l east 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).

40 CFR Part 432 regulates wastewater discharges from Meat and Poultry processing plants in 12 subcategories of products and product groups. EPA last updated effluent limitations guidelines and standards (ELGs) for the Meat and Poultry Category on September 8, 2004 (69 FR 54476). In addition to best practicable control technology (BPT) limitations, 40 CFR Part 432 includes limitations based on the best available technology economically achievable (BAT) and new source performance standards (NSPS). 40 CFR Part 432 regulates conventional pollutants (BOD, fecal coliform, oil and grease, and TSS) for all subparts. Excluding Subpart E (Small Processors), all subparts include ammonia as nitrogen (N) and total nitrogen limitations for BAT

, at plants exceeding a threshold pounds of annual live weight kill (LWK) (40 CFR Part 432) (U.S. EPA, 2014a). BAT treatment varies based on subcategory. Table 3-43 lists the BAT options for the Meat and Poultry subcategories. The Meat and Poultry Category ELGs do not regulate

nitrate.

Table 3-43 . BAT Treatment for the Meat and Poultry Subcategories

Subcategory Treatment Unit Processes

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: U.S . EPA, 2002.

Thirteen meat and poultry facilities reporting releases of nitrate compounds to TRI were reviewed as part of the 2011 and 2012 Annual Reviews. EPA determined that the majority of these facilities are in compliance with the ELGs for total nitrogen

, or are currently awaiting revised permits that will include total nitrogen permit limitations . As a result, EPA assigned the Meat and Poultry Category a lower priority for revision (U.S. EPA, 2014a). As part of the 2015

3-493— EPA’s 2015 Preliminary Category Reviews

3.6

—

Meat and Poultry Products (40 CFR Part 432 )

Annual Review, EPA determined all facilities reviewed as part of the 2011 and 2012 Annual Reviews also reported nitrate releases to TRI in 2013; however, only eleven are included in the top fifteen facilities listed in Table 3-42.

As part of the 2015 Annual Review, EPA reviewed the 2013 and 2009 TRI nitrate releases for the top 15 facilities listed in Table 3-42 . Many of these facilities reported a decrease in nitrate compound releases to TRI from 2009 to 2013. EPA specifically reviewed the five facilities with the greatest increase in nitrate TWPE from 2009 to 2013 (three of which were reviewed pre viously). Therefore, EPA has focused on the following facilities for the 2015

Annual Review:

• Cargill Meat Solutions Corporation, Schuyler, NE

• Cargil l Me at Solutions Corporation, Ottumwa, IA

• John Morrell & Co., Sioux Falls, SD

• Pilgrim’s Pr ide Corporation, Mount Pleasant, TX

• Tyson Farm, Inc., Carthage, MS

Cargill Meat Solutions Corp. (Schuyler, NE)

Cargill Meat Solutions Corporation ’s facility in Schuyler, NE, is a complex beef slaughterhouse, covered by 40 CFR Part 432, Subcategory B, with a production of approximately 6,500,000 pounds per day in LWK. EPA previously reviewed this facility as part of the 2011 and 2012 Annual Review Reports (U.S. EPA, 2012, 2014a). The facility’s nitrate compound releases account for approximately 8 percent of the 2013 TRI nitrate compounds TWPE. 24 Treated process wastewater is discharged via outfalls 001 and 003 to surface water and agricultural land application sites, respectively. Process wastewater discharged to outfall 001 is treated with a dissolved air flotation unit, anaerobic lagoon cells, a four- chambered sequential batch reactor (an activated sludge plant), a chlorine contact basin, and dechlorination. Discharges of nutrient- rich water from outfall 003 (treated process wastewater and non

- contact cooling water) are used on agricultural land ( the facility does not have an outfall 002) (NE DEQ, 2009 ).

The facility permit, issued October 2009, includes seasonal limits for ammonia as N for

outfalls 001 and 003 , which are lower than the effluent limitations specified in 40 CFR Part 432. The per mit does not include limits for total nitrogen. The permit writer for Cargill Meat Solutions Corp. stated that the ammonia as N limit s were more stringent than the water quality

criteria and are based on waste load allocations (Ewol dt, 2012). Th e ammonia as N permit limit s are (NE DEQ, 2009):

• Winter: 4.0 mg/L monthly average, 8.0 mg/L daily maximum (equal to BAT limitations).

• Spring: 2.58 mg/L monthly average, 5.17 mg/L daily maximum.

• Summer: 1.89 mg/L monthly average, 3.79 mg/L daily maximum.

24 Cargill Meat Solutions in Schuyler, NE, accounted for 6 percen t of the 2009 TRI nitrate compound TWPE (U.S. EPA, 2012).

3-503— EPA’s 2015 Preliminary Category Reviews

3.6

—

Meat and Poultry Products (40 CFR Part 432 )

Cargill Meat Solutions Corp. (Ottumwa, IA)

Cargill Meat Solutions, Corp. (Cargill Ottumwa) in Ottumwa, IA, is a hog slaughterhouse. Treated process wastewater is discharged via outfall 001 to the Des Moines

River. The treatment for process wastewater discharge d through outfall 001 consists of grit removal, settling, chlorination, and an oxidation ditch. Non -contact cooling water from refrigeration and processing equipment is discharged via outfall 002. Wastewater from the facility’s third outfal l, outfall 801, is a combined waste stream from outfalls 001 and 002 (IA DNR, 2009).

The facility permit, issued May 2009, includes total nitrogen permit limits of 134 mg/L monthly average and 194 mg/L daily maximum. The permit includes ammonia as N limits of 4.0 mg/L monthly average and 8.0 mg/L daily maximum. These limits are based on 40 CFR Part 432 (IA DNR, 2009).

John Morrell & Co mpany (Sioux Falls, SD)

As part of the 2015 Annual Review, EPA contacted the South Dakota Department of

Environment and Na tural Resources (SD DENR). The state confirmed that the John Morrell & Company facility in Sioux Falls , SD, is currently operating under an administratively continued permit which expired March 31, 2005. According to this permit, the facility discharges tr eated process wastewater via outfall 001 (SD DENR, 2000b).

The facility’s 2000 permit does not include total nitrogen limits. The permit includes the following ammonia as N permit limits, which are based on a total maximum daily load based on the background water quality of the Big Sioux River near Sioux Falls, the surface water quality

standard for un -ionized ammonia (0.04 mg/L), and best professional judgment. The 30-day average ammonia limits are based on their allocation of the allowable waste load (SD DENR, 2000a; SD DENR, 2000b):

• Spring (April – May): 70 lb/day monthly average, 123 lb/day daily maximum.

• Summer (June – August): 58 lb/day monthly average, 102 lb/day daily maximum.

• Fall (September – October): 75 lb/day monthly average, 131 lb/day daily m aximum.

• Winter (November

– March): 163 lb/day monthly average, 285 lb/day daily

maximum.

Table 3-44 presents the John Morrell Sioux Falls facility’s ammonia as N 2013 DMR average daily concentration and wastewater flow data for outfall 001. EPA calculated the average quantities using the reported concentrations and wastewater flows, and compared them to the seasonal permit limits for ammonia as N. As shown, the 2013 amm onia as N discharges are below the allowable period load based on the permit limits.

Table 3-44. John Morrell’s Sioux Falls Facility’s 2013 DMR Discharges for Ammonia as N, Outfall 001

Monitoring

Period End

Date Wastewater Flow (MGD) Av erage Daily

Concentration (mg/L) Calculated Average Quantity (lb/day) NPDES Monthly Average Permit Limit (lb/day )

31

- Jan

- 13 2.17 1.13 20.5 163

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Table 3-44. John Morrell’s Sioux Falls Facility’s 2013 DMR Discharges for Ammonia as N, Outfall 001

Monitoring

Period End

Date Wastewater Flow (MGD) Av erage Daily

Concentration (mg/L) Calculated Average Quantity (lb/day) NPDES Monthly Average Permit Limit (lb/day )

28

- Feb

- 13 2.19 1.05 19.2 163

31

- Mar

- 13 2.14 0.91 16.3 163

30

- Apr

- 13 2.16 0.94 16.9 70

31

- May

- 13 2.17 0.86 15.6 70

30

- Jun

- 13 2.29 0.88 16.8 58

31

- Jul

- 13 2.14 0.72 12.9 58

31

- Aug

- 13 2.33 0.67 13.0 58

30

- Sep

- 13 2.26 0.72 13.6 75

31

- Oct

- 13 2.03 0.80 13.6 75

30

- Nov

- 13 2.14 0.77 13.8 163

31

- Dec

- 13 2.02 1.12 18.9 163

Source: DMR Loading Tool; SD DENR, 2000b for permit limits Note: Rounding of calculated limits may mean actual monitoring period loads vary slightly.

Pilgrim’s Pride Corp. (Mount Pleasant, TX)

Pilgrim’s Pride Corp – Mt Pleasant Complex, in Mount Pleasant, TX, is a poultry first processing plant covered by 40 CFR Part 432, Subcategory K. EPA previously reviewed this facility as part of the 2011 and 2012 Annual Review Reports (U.S. EPA, 2012 and 2014a). The facility’s permit, which was recently under a major ame ndment change since the 2012 Annual Review, includes limit s for total nitrogen and seasonal limits for ammonia as N. According to the facility permit, the facility discharges treated process wastewater via outfall 001. The process wastewater is treated by primary and secondary screening for solids removal, flow equalization, dissolved air flotation with chemical addition, biotower treatment, two activated sludge aeration basins, two final clarifiers, sand filtration, chlorination, and dechlorination (TCEQ, 2015).

The total nitrogen permit limit s are based on 40 CFR Part 432 and are 103 mg/L monthly average, 147 mg/L daily maximum. The ammonia as N permit limits are based on water quality

criteria and equal to 40 CFR Part 432. They are (TCEQ, 2015 ):

• Winter: 4.0 mg/L monthly average, 8 .0 mg/L daily maximum.

• Summer: 1.0 mg/L monthly average, 2.0 mg/L daily maximum.

Tyson Farms, Inc. (Carthage, MS)

Tyson Farms, Inc., Carthage Processing Plant in Carthage, MS, is a poultry first processor covered by 40 CFR Part 432, Subcategory K. The facility discharges treated process and sanitary wastewater, as well as non -contact cooling water, from outfall 001 into Cobbs Creek via Pickens Branch (MDEQ, 201 0a). The facility’s treatment process includes screen s , anaerobic lagoons, activated sludge, sedimentation, disinfection, and dechlorination (MDEQ, 2010b).

The total nitrogen permit limits are based on 40 CFR Part 432 and are 103 mg/L monthly average, 147 mg/L daily maximum. The ammonia as N permit limits are not seasonally based and are 2.0 mg/L monthly average, 3.0 mg/L daily maximum (MDEQ, 2010a).

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Nitrate Compounds Discharge Summary

EPA has determined the following for the top 2013 TRI nitrate compound dischargers:

• The total TRI nitrate compound TWPE decreased from 2009 to 2013; however, for seven of the top fifteen facilities the TRI nitrate compound TWPE increased during this period. Further five of the top seven facilities reported an increase of 20 percent or more, as shown in Table 3-42. As Table 3-45 shows, three of the fiv e facility permits further reviewed as part of the 2015 Annual Review are in compliance with 40 CFR Part 432 total nitrogen limitations. One permit is currently under revision and is expected to include total nitrogen limits. EPA determined that one facili ty (Cargill Meat Solutions, in Schuyler, NE), while likely captured in the applicability of 40 CFR Part 432, Subcategory B, does not include total nitrogen limits (the ELGs specify total nitrogen limits). The ammonia as N limits included in this facility’s permit are more stringent than 40 CFR Part 432 for ammonia.

Table 3-45. Findings for Select 2013 TRI Nitrate Compound Dischargers

Facility

Name State Subpart Date

Permit

Issued 40 CFR Part

432 Total Nitrogen Max Daily (mg/L) 40 CFR Part 432 Total Nitrogen Max Monthly Average (mg/L) EPA Findings Cargill

Meat

Solutions NE B October

2009 NA NA Permit limits are more stringent than 40 CFR Part 432 for ammonia; however, permit does not include total nitrogen limits. Cargill

Meat

Solutions IA ND May 2009 194 134 Permit limits based on 40 CFR Part 432 total nitrogen

and ammonia limitations.

John

Morrell &

Co. SD ND April 2000 NA NA Facility is operating under an administratively continued permit, which is currently under revision. ELGs were not incorporated into existing permit since it was issued prior to the

effective date of the ELG. Pilgrim’s

Pride Corp. TX K June 2015 147 103 Total nitrogen permit limits

based on 40 CFR Part 432

limitations. Ammonia permit limits based on water quality criteria equal to 40

CFR Part 432 limitations. Tyson’s
Farm, Inc. MS K December

2010 147 103 Permit limits based on 40 CFR Part 432 total nitrogen

limitations.

Sources: IA DNR, 2009; NE DEQ, 2009; SD DEQ, 2000b; TCEQ, 2015; and MDEQ, 2010a.

N A = Not applicable

ND = Not determined

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3.6.4 Meat and Poultry Category Hydrogen Sulfide Releases in TRI

EPA’s investigation of the hydrogen sulfide releases revealed that four facilities account for 93 percent of the 2013 TRI hydrogen sulfide releases (shown in Table 3-46 ). EPA did not investigate the remaining facilities discharging hydrogen sulfide as part of the 2015 Annual

R eview.

Table 3-46. Top Facilities Reporting 2013 TRI Hydrogen Sulfide Releases

Facility Name Facility Location Pounds of Pollutant

Released Pollutant

TWPE Percent of Category TWPE

Tyson Fresh Meats , Inc. Hillsdale, IL 5,320 14,900 39.5%

Tyson Fresh Meats

, Inc. Lexington, NE 3,350 9,380 24.9%

Tyson Fresh Meats

, Inc. Columbus Junction, IA 2,220 6,220 16.5%

John Morrell & Co

. Sioux Falls, SD 1,600 4,490 11.9%

All other hydrogen s ulfide releases in the Meat and Poultry Category a 986 2,760 7.3 %

Total 13,500 37,700 100%

So urce: TRI LTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a Seven additional facilities reported hydrogen sulfide releases in the 2013 TRI

.

Hydrogen sulfide discharges from meat and poultry facilities result from the anaerobic treatment of process wastewater. Anaerobic treatment is advantageous for treating wastewater from meat and poultry facilities because it requires low lev els of energy to digest the high concentration of organic solid fractions of animal by-products from slaughterhouse facilities. Anaerobic lagoons are a common form of wastewater treatment. The degradation of the organic material typically emits methane and carbon dioxide; ammonium and hydrogen sulfide are also produced in trace amounts. The pH of the wastewater determines the composition of air emissions; for example, a pH lower than 6 produces more hydrogen sulfide and carbon dioxide emissions. Covering th e lagoons improves heat retention, though a layer of scum typically forms on the lagoon surface, even if uncovered, which also reduces heat loss and emissions of malodorous compounds, such as hydrogen sulfide (U.S. EPA, 2002). The Meat and Poultry

ELGs do not include limitations and standards for hydrogen sulfide.

Aerobic treatment of process wastewater can also result in hydrogen sulfide emissions. Facultative lagoons combine aerobic and anaerobic degradation, providing an aerobic upper layer and an anaerobic bottom layer, which digests the settleable solids in the wastewater. Though sulfides are created within the anaerobic layer, these emissions are typically oxidized before releasing into the atmosphere (U.S. EPA, 2002).

As discussed in Section 2.2.2.1 and Section 3.3 of this report, EPA annou nced that it was lifting the 1994 Administrative Stay of the reporting requirements for hydrogen sulfide on October 17, 2011 (76 FR 64022). Facilities were required to report environmental releases of hydrogen sulfide to TRI beginning with the reporting ye ar 2012, including releases to water. EPA did not perform a TRA in 2014; therefore, EPA is reviewing hydrogen sulfide discharges

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for the first time as part of the 2015 Annual Review. EPA is focusing on hydrogen sulfide releases reported by direct discharge rs in the 2013 TRI.

As part of the 2015 Annual Review, EPA contacted the four facilities presented in Table 3-46 to determine how they are calculating hydrogen sulfide releases. Because only two parent companies own the four facilities in Table 3-46 , EPA summarized the findings by parent company in the following sub- sections.

Tyson Fresh Meats, Inc.

The facilities located in Hillsdale, IL, Lexington, NE, and Columbus Junction, IA, are all direct dischargers and employ different wastewater treatment techniques, as summarized in

Table 3-47. The Hillsdale and Lexington facilities are complex beef slaughterhouses (IL EPA, 2011; NE DEQ, 2010). The facility in Columbus Junction is a complex hog slaughterhouse (Heeb, 2015). The company contact stated that hydrogen sulfide concentrations are generally similar between facilities (Dirks, 2014).

Table 3-47 . Wastewater Treatment Steps at Various Tyson Fresh Meats, Inc. Facilities

Wastewater Treatment Steps Hillsdale, IL Columbus Junction, IA Lexington, NE

Anaerobic lagoon (covered) X X

Anaerobic lagoon (uncovered) X

Biogas handling X X

Anoxic process X X

Aeration process X X X

Secondary clarification X X X

Chlorination X X X

Dechlorination X X X

Discharge to stream X X X

Source: Dirks, 201 4.

The three facilities have similar procedures for estimating their hydrogen sulfide releases. The facilities use limited samples of soluble sulfide and pH, in addition to known proportions of hydrogen sulfide and hydrosulfide ion in dissolved sulfide (assum ing a neutral solution), to convert this sulfide concentration into hydrogen sulfide. The amount of hydrogen sulfide, in pounds, is estimated using a conversion based on the wastewater flow and calculated hydrogen sulfide concentration. The TRI reported releases are not a result of direct sampling of hydrogen sulfide at any of the three facilities (Dirks, 2014).

In an effort to further understand the reported releases of hydrogen sulfide to TRI, EPA reviewed available DMR data for the Hillsdale and Lexingt on facilities, however, neither facility’s permit limits or requires monitoring for hydrogen sulfide . The Columbus Junction facility permit is still under review due to a Use Attainability Analysis (UAA) concerning the receiving stream, therefore, the faci lity only has TRI data available (Heeb, 2015).

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John Morrell & Co.

John Morrell & Company’s facility in Sioux Falls, SD , reported direct releases of hydrogen sulfide to TRI in 2013 based on published emission factors (i.e., basis of estimate code E1). As part of the 2015 Annual Review, EPA contacted the facility and confirmed that the TRI hydrogen sulfide releases are estimated from treatment processes at the facility based on calculations using collection efficiencies and emission factors developed at the facility (Schulz, 2014). Therefore, the TRI reported releases are not a result of direct sampling. EPA reviewed available DMR data for this facility and determined that the facility’s discharge permit does not limit or require monitoring of hydrogen sulfide.

Hydrogen Sulfide Discharge Summary

Based on company contacts, EPA determined that three facilities estimated their hydrogen sulfide releases reported to TRI based on soluble sulfide sampling data. The company

contact for these facilities stated that this approach likely accurately represent s potential releases to surface waters as reported to TRI. A fourth facility reviewed used emission factors to estimate their reported hydrogen sulfide releases. These four facilities account for 93 percent of the hydrogen sulfide releases reported to TRI in 2013.

3.6.5 Meat and Poultry Category Findings

The estimated toxicity of the Meat and Poultry Category discharges resulted primarily from nitrate compound and hydrogen sulfide releases reported to TRI . From the 2015 Annual Review, EPA found:

• Nitrate. Fifteen meat and poultry facilities account for the majority of TRI nitrate compound releases. EPA previously reviewed many of these in recent annual reviews. For the 2015 Annual Review, EPA focused its review on five fa cilities whose nitrate compound TWPE increased from 2009 to 2013. Three of these f acility permits are in complian ce with current total nitrogen ELGs. One permit is currently under revision and is expected to include total nitrogen limitations specified in the ELGs. EPA determined that one facility is likely captured in the applicability of 40 CFR Part 432, Subcategory B; however, the permit does not include total nitrogen limitations. The ammonia as N limitations included in this facility’s permit are more stringent than local water quality criteria

.

• Hydrogen Sulfide. Four facilities accounted for the majority of the hydrogen sulfide

releases

. All four facilities reported direct releases of hydrogen sulfide to TRI. Three of the four facilities are estimating their hydrogen sulfide releases by using soluble sulfide sampling data collected at the facilities. A company contact for three of the

facilities believes that the direct releases of hydrogen sulfide they report to TRI

accuratel y represent potential relea ses to receiving waters. EPA determined that the other facility is using published emission factors, and not direct wastewater sampling, to estimate hydrogen sulfide releases. EPA is uncertain as to how representative the

data are of actual releases

.

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3.6.6 Me at and Poultry Category References

1. Dirks, Kim & Christopher Logue. 2014. Telephone and Email Communication between Kim Dirks, Tyson Fresh Meats, Inc., Christopher Logue, Tyson Fresh Meats, Inc., and Kimberly Bartell, Eastern Research Group, Inc., Re: TRI

C larification for Hydrogen Sulfide Discharges. (December 22 ). EPA

- HQ

- OW

2015-0665. DCN 08152.

2. ERG. 2015. Preliminary Category Review – Facility Data Review for Point Source Category – 432 – Meat and Poultry. (September). EPA

- HQ

- OW -2015­

0665. DCN 08153.

3. Ewoldt, Cay. 2012. Telephone and Email Communication Between Cay Ewoldt, NPDES Permits and Compliance Unit, NE DEQ, and Kimberly Landick, Eastern Research Group, Inc., Re: Meat and Poultry Facility Nitrogen Discharges. (January 25). EPA- HQ

- OW -2010-0824-0250.

4. Heeb, Wendy. 2015. Telephone Communication Between Wendy Heeb, Iowa Department of Natural Resources, and Kara Edquist, Eastern Research Group, Inc., Re: Obtaining Tyson Fresh Meats, Columbus Junction, IA permit. (June 8).

EPA

- HQ

- OW -2015-0665. DCN 08154.

5. IL EPA. 2011. Illinois Environmental Protection Agency. Public Notice of Facility Permit for NPDES Permit: Tyson F resh Meats, Inc., Hillsdale, IL (IL0003913). (June 3). EPA- HQ -OW2010-0824-0248.

6. IA DNR. 2009. Iowa Department of Natu ral Resources. NPDES Pe rmit: Cargill Meat Solutions Corporation, Ottumwa, IA (IA0060569). (May 6). EPA

- HQ

- OW

2015-0665. DCN 08155.

7. MDEQ. 2010a. Mississippi Department of Environmental Quality. NPDES Permit: Tyson Food, Inc., Carthage, MS (MS0026140). (December 6). EPA

- HQ

OW -2015-0665. DCN 08157.

8. MDEQ. 2010b. Mississippi Department of Environmental Quality. Permit Rationale for Reissuance for NPDES Permit: Tyson Foods, Inc., Carthage, MS (MS0026140). (September 29). EPA

- HQ

- OW -2015-0665. DCN 08156.

9. NE DEQ. 2009. Nebraska Departmen t of Environmental Quality. NPDES Permit and Fact Sheet: Cargill Meat Solutions Corp., Schuyler, NE (NE0000795). (October 1) . EPA

- HQ

- OW -2010-0824-0242.

10. NE DEQ. 2010. Nebraska Department of Environmental Quality. NPDES Permit and Fact Sheet: Tyson Fresh Me ats, Inc., Lexington, NE (NE0123501). (October 1) . EPA

- HQ

- OW -2010-0824-0241.

11. Schulz, Charles. 2014. Telephone Communication between Charles Schulz, John Morrell & Co., and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 TRI

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Hydrogen Sulfide Discharges for John Morrell & Co. (December 22). EPA

- HQ

OW -2015-0665. DCN 08158.

12. SD DENR. 2000a. South Dakota Department of Environment and Natural Resources. NPDES Permit: John Morell and Company, Sioux Falls, SD (SD0000078). (April 1). EPA

- HQ

- OW -2015-0665. DCN 08159.

13. SD DENR. 2000b. South Dakota Department of Environment and Natural Resources. Addendum for NPDES Permit: John Morell and Company, Sioux Falls, SD (SD0000078). (July 5). EPA

- HQ

- OW -2015-0665. DCN 08160.

14. TCEQ. 2015. Texas Commission on Environmental Quality. Notice of Application and Preliminary Decision for Water Quality TPDES Permit Amendment for Industrial Wastewater for NPDES Permit: Pilgrim’s Pride Corp., Mount Pleasant, TX (TX0062936). (June). EPA

- HQ

- OW -2015-0665. DCN

08161.

15. U .S. EPA . 2002. De velopment 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. EPA

- HQ

OW -2010-0824-0233.

16. U.S. EPA. 2012. The 2011 Annual Effl uent Guidelines Review Report. Washington, D.C. (December). EPA 821-R-12-001. EPA- HQ -OW-2010-0824­

0195.

17. U.S. EPA. 2014a. The 2012 Annual Effluent Guidelines Review Report

. Washington, D.C. (September). EPA-821-R-14-004. EPA- HQ

- OW -2010-0824­

0320.

18. U.S. EPA. 2014b. The 2013 Annual Effluent Guidelines Review Report

. Washington, D.C. (September). EPA-821-R-14-003. EPA- HQ

- OW -2014-0170­

0077.

19. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan. Washington, D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN

08208.

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Mineral Mining and Processing (40 CFR Part 436 )

3.7 Mineral Mining and Processing (40 CFR Part 436)

EPA identified the Mineral Mining and Processing (Mineral Mining) Category for preliminary review because it ranks high again, in terms of toxic-weighted pound equivalents (TWPE), in the final 2015 combined point source category rankings. Previously, EPA reviewed discharges from this category as part of the 2004, 2010, and 2011 Annual Reviews in which it also ranked high (U.S. EPA, 2004, 2011, 2012). This section summarizes the results of the 2015 Annual Review. EPA focused its 2015 review on discharges of chloride, aluminum, and fluoride because of their high TWPE relative to the other pollutants discharged by facilities in the Mineral Mining Category. Fluoride, reviewed as part of the 2010 and 2011 Annual Reviews, continued to be a top pollutant of concern. For the 2015 Annual Review, available discharge data also showed significant contributions of chloride and aluminum.

3.7.1 Mineral Mining Category 2015 Toxicity Rankings Analysis

Table 3-48 compares the toxicity rankings analyses (TRA) data for the Mineral Mining Category from the 2011, 2013, and 2015 Annual Reviews. EPA did not conduct the TRA in 2012 or 2014, but instead revie wed additional data sources as part of the even -year annual review, as described in Section 2.2.1 of EPA’s Preliminary 2016 Plan (U.S. EPA, 2016 ). During the 2015 Annual Review, EPA did not identify any data corrections to the 2013 Discharge Monitoring Rep ort (DMR) and Toxic Release Inventory (TRI) discharge data for the Mineral Mining Category.

Table 3-48. Mineral Mining Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

Year of Discharge Year of

Review Mineral Mining Category Facility Counts a Mineral Mining Category TWPE

Total TRI

Facilities Total DMR Major

Facilities Total DMR

Minor

Facilities TRI

TWPE b DMR TWPE c Total

TWPE

2009 2011 9 1 26 113 5,430 44,700 d 50,100 d

2011 2013 82 20 127 2,950 31,200 34,100

2013 2015 81 9 76 4,710 139,000 144,000

Sources: TRIReleases2009 _v2, DMRLoads2009_v2 , and 2011 Annual Review Report (for 2009 DMR and TRI data) (U.S. EPA, 2012); DMRLTOutput2011_v1 (for 2011 DMR); TRILTOutput2011_v1 (for 2011 TRI); DMRLTOutput2013_v1 (for 2013 DMR); TRILTOutput2013_v1 (for 2013 TRI)

Note: EPA did not evaluate 2010 or 2012 DMR and TRI data

. Note: TWPE values are rounded to three significant figures. Sums of individual values may not equal the total presented, due to rounding.

a Number of facilities with TWPE greater than zero.

b Releases include direct releases to surface waters and transfers to POTWs. Transfers to POTWs account for

POTW removals.

Includes DMR data from both major and minor dischargers.

d 2009 data after corrections were made during the 2011 Annual Review.

As shown in Table 3-48 , the DMR and total TWPE decreas ed from 2009 to 2011 and increased significantly from 2011 to 2013. The number of TRI facilities decreased from 2009 to 2013, while the total number of DMR facilities increased slightly from 2009 to 2011 but then

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decreased substantially from 2011 to 2013. The increase in TWPE from 2011 to 2013 is primarily due to discharges from the facilities described in the sections below. The decrease in the number of facilities from 2011 to 2013 is due to decreases in minor facilities in two states, Colorado and Ohio (DMR Loading Tool).

3.7.2 Mineral Mining Category Pollutants of Concern

EPA’s 2015 review of the Mineral Mining Category focused on the 2013 DMR discharges because the DMR data dominate the category’s combined TWPE. Table 3-49 shows the five pollutants with the highest contribution to the 2013 DMR TWPE. As a point of comparison, Table 3-49 shows the 2011 DMR facility count and TWPE for these top five pollutants, based on the 2013 Annual Review (U.S. EPA, 2014).

Chloride, aluminum, and fluoride contribute more than 81 percent of the total 2013 DMR TWPE. Of these top pollutants, only fluoride is a regulated pollutant in the Mineral Mining Category effluent limitations guidelines and standards (ELGs) (40 CFR Part 436). EPA’s investigations of reported discharges of the top three po llutants are presented in Sections 3.7.3 and 3.7.4. EPA did not investigate the other pollutants, including iron and cyanide, as part of the 2015 Annual Review, because they represent a small percentage (11 percent) of the 2013 DMR TWPE for the Mineral Mining Category.

Table 3-49. Mineral Mining Category Top DMR Pollutants

Pollutant b 2013 DMR Data a 2011 DMR Data a

Number of Facilities Reporting Pollutant c T WPE Number of Facilities Reporting Pollutant c TWPE

Chloride 21 45,900 25 8,990

Aluminum 12 45,200 15 3,080

Fluoride 13 21,700 14 11,500

Iron 1 7 8,150 36 580

Cyanide 4 7,670 6 523

Top Pollutant Total NA 129,000 NA 24,700

Mineral Mining Category Total 8 5 139,000 147 31,200

Sources: DMRLTOutput2013_v1 (for 2013 TWPE); DMRLTOutput2011_v1 (for 2011 TWPE)

. NA: Not applicable.

a Includes DMR data from both major and minor dischargers

. b Iron and cyanide discharges combined contribute 11 percent of the 2013 category DMR TWPE. Therefore, EPA did not review iron or cyanide discharges as part of the 2015 Annual Review.

c Number of facilities with TWPE greater than zero.

3.7.3 Mineral Mining Category Chloride and Aluminum Discharges in DMR

EPA’s investigation of chloride discharges revealed that two facilities, SES Assets LLC (formerly Lambert Dock) in Belmont, WV, and Cedar Lake Plant in Seagraves, TX, account for 96 percent of the 2013 DMR chloride discharges (shown in Table 3-50). In addition, EPA’s investigation of the aluminum discha rges revealed that SES Assets LLC in Belmont, WV, also accounts for 95 percent of the 2013 DMR aluminum discharges (shown in Table 3-51 ). Because

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SES Assets accounts f or the majority of both the chloride and aluminum discharges, these discharges are reviewed together in this section. EPA did not investigate the remaining facilities discharging chloride or aluminum as part of the 2015 Annual Review.

Table 3-50. Top 2013 DMR Chloride Discharging Facilities

Facility Name Facility

Location Pounds of

Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

SES Assets LLC (formerly Lambert Dock) Belmont, WV 1,380,000,000 33,600 73%

Cedar Lake Plant Seagraves, TX 429,000,000 10,400 23%

All other chloride dischargers in the Mineral Mining Category a 75,900,000 1,850 4%

Total 1,880,000,000 45,900 100%

Source: DMRLTOutput201 3 _v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 19 additional facilities submitted chloride discharges in the 2013 DMR data

.

Table 3-51. Top 2013 DMR Aluminum Discharging Facilities

Facility Name Facility

Location Pounds of

Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

SES Assets LLC (formerly Lambert Dock) Belmont, WV 717,000 43,000 95%

All other aluminum dischargers in the Mineral Mining Category a 36,100 2,160 5%

Total 753,000 45,200 100%

Source: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 11 additional facilities submitted aluminum discharges in the 2013 DMR data

.

SES Assets, LLC (Chloride and Aluminum Discharges)

SES Assets LLC (formerly Lambert Dock), in Belmont, WV, discharges chloride and aluminum through three outfalls. SES is a sand and gravel hauling facility that has large salt piles on site. As part of the 2015 Annual Review, EPA contacted the facility abou t their chloride and aluminum discharges. The facility contact confirmed the 2013 chloride and aluminum discharges and explained that the discharges are from surface runoff from the large contaminated salt piles

that SES Assets inherited from Lambert Truck ing in 2010. The salt is stored onsite and sold to the West Virginia Department of Transportation for winter road use. The piles have been onsite

since the 1970s and are located near outfall 002 and 003. Table 3-52 presents the 2011 through 2014 DMR chloride and aluminum discharges for SES Assets, LLC. After SES Assets acquired the facility in 2010, stricter reporting was enforced (Goble, 2014). Previously, before the acquisition, the facility did not submit consistent DMR data.

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Table 3-52 . SES Assets, L L C Chloride and Aluminum Discharges for 2011 – 2014

Year of Discharge Chloride TWPE Aluminum TWPE

2011 636 2,810

2012 44,200 20,600

2013 33,600 43,000

2014 2,500 1,390
Source: DMR Loading Tool

The facility contact indicated that over the last two years the company has implemented remediation efforts on site, such as salt storage pad berm repair and repair of outfalls 002 and 003 (Goble, 2014). This is reflected in the decreased chloride and aluminum TWPE from 2013 to 2014, shown in Table 3-52. However, the facility contact stated that the company is selling their remaining salt piles and does not plan to store salt on site in the future (Goble, 2014). EPA expects the discharges fr om this facility to decrease in future years.

Cedar Lake Plant (Chloride Discharges)

Cedar Lake Plant, owned by Cooper Natural Resources Inc., in Seagraves, TX, discharges chloride through two outfalls, 001 and 003. The facility produces anhydrous sodium sulfate from brine extracted from Cedar Lake, a saline lake. Spent brine is returned to the lake via outfall 001, along with plant floor wash water, condensate from evaporation processes, and stormwater. Wastewater from pump house floor washdown, booster pump noncontact cooling water, stormwater, and occasional brine tank overflow are all discharged through outfall 002. EPA did not review DMR data from outfall 002 as part of this review because the outfall does not have chloride discharges. Cooling tower blowdown from the evaporation pond, intermittent brine tank overflow, stormwater runoff, culvert wash water, and tank washdown are discharged through outfall 003. Because the facility withdraws and discharges to Cedar Lake, 40 CFR 436.122(b) allows net limitations to be applied (TCEQ, 2009). Therefore, there are no reportable limits for TDS, chloride, or sulfate; rather the wastewater discharge may not fall below the quality of the water withdrawn (TCEQ, 2009).

Chloride is not a regulated pollutant in the Mi neral Mining Category ELGs . Historical discharge data to support the no reportable limits in Cedar Lake’s permit are provided in the Statement of Basis/Technical Summary for the facility (TCEQ, 2009). The facility’s permit expired on December 1, 2014 and an updated permit and Statement of Basis/Technical Summary have been drafted (TCEQ, 2015). Table 3-53 presents the average monthly flow and chloride discharges for all three outfalls from 2004 through 2009 and 2009 through 2014 as presented in the Statement of Basis/Technical Summary documents (TCEQ, 2009 and TCEQ, 2015). EPA compared these discharges to the 2013 DMR average monthly discharges for outfalls 001 and

002 in Table 3-53 to show that they are consistent with those presented in the Statement of Basis/Technical Summary documents from TCEQ.

3-623— EPA’s 2015 Preliminary Category Reviews

3.7

—

Mineral Mining and Processing (40 CFR Part 436 )

Table 3-53. Cedar Lake Plant’s Historical and 2013 DMR Monthly Chloride Discharges

Outfall 001 Outfall 002 Outfall 003

Flow (MGD) Chlor ide

Concentration (mg/L) Flow (MGD) Chlor ide

Concentration (mg/L) Flow (MGD) Chlor ide

Concentration (mg/L)

Average Monthly Discharge , 2004

– 2009

20 04

- 2009 Average of Daily Avg a 1.06 92,968 0.026 26,822 0.027 52,316

2004

- 2009 Maximum of Daily Max b 1.58 116,886 0.28 95,497 0.06 97,746

Average Monthly Effluent, 2009

– 2014

2009

- 2014 Average of Daily Avg a 1.259 93,769
No discharge reported 0.148 66,857

2009

- 2014 Maximum of Daily Max b 1.575 166,000 1.305 211,000

Average Daily Discharge , 2013 DMR Data

31

- Jan

- 13 1.305 104,225

No discharge reported 0.012 68,450

28

- Feb

- 13 1.305 95,050 0.012 78,300

31

- Mar

- 13 1.305 98,400 0.011 87,900

30

- Apr

- 13 1.305 89,160 0.1 70,367

31

- May

- 13 1.305 104,950 0.015 77,250

30

- Jun

- 13 1.27 91,950 0.022 44,800

31

- Jul

- 13 1.305 127,400 0.007 30,850

31

- Aug

- 13 1.305 104,175 0.013 54,275

30

- Sep

- 13 1.305 120,175 0.012 93,067

31

- Oct

- 13 1.305 109,733 0.012 57,233

30

- Nov

- 13 1.305 128,800 0.005 130,000

31

- Dec

- 13 1.305 110,750 0 0

Source: TCEQ, 2009; TCEQ, 2015; DMRLTOutput2013_v1.

a Average of Daily Avg values are the average of all daily average values for the reporting period.

b Maximum of Daily Max values are the individual maximum values for the reporting period.

Table 3-53 shows that the 2013 DMR discharges are similar in magnitude to discharges used to determine the no reportable limit in the facility’s permit. Additionally, as noted above, the facility withdraws and discharges to Cedar La ke allowing net limitations to be applied.

3.7.4 Mineral Mining Category Fluoride Discharges in DMR

EPA’s investigation of the fluoride discharges revealed that PCS Phosphate White Springs, in White Springs, FL, accounts for 69 percent of the 2013 DMR fluori de discharges (shown in Table 3-54 ). EPA did not investigate the remaining 12 facilities discharging fluoride as part of the 2015 Annual R eview.

3-633— EPA’s 2015 Preliminary Category Reviews

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—

Mineral Mining and Processing (40 CFR Part 436 )

Table 3-54. Top 2013 DMR Fluoride Discharging Facilities

Facility Name Facility Location Pounds of Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

PCS Phosphate White Springs White Springs, FL 496,000 14,900 69%

All other fluoride dischargers in the Mineral Mining Category a 226,000 6,770 31%

Total 722,000 21,700 100%

So urce: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 12 additional facilities submit ted fluoride discharges in the 2013 DMR data

.

PCS Phosphate White Springs generates wastewater from open -pit mining of phosphate rock, beneficiation of the rock, manufacture of sulfuric acid and phosphoric acid, production of fertilizer components and ani mal

- feed supplements, and stormwater runoff. The facility’s treatment system includes pH adjustment and chemical precipitation using lime; settling and sedimentation; and adsorption/absorption on mining waste clay particles in clay settling areas (FL DEP, 2013).

PCS Phosphate White Springs discharges fluoride from outfalls 001, 002, 003, and 004.

All four outfalls have a monthly average reporting requirement for fluoride and a daily maximum permit limit of 10 mg/L (FL DEP, 2013). Tabl e 3-55 presents the average monthly flows and fluoride discharge concentrations for three outfalls in 2013; the facility reported no discharges from outfall 003 in 2013. There are multiple internal outfalls that feed into 001, so the facility samples at a point in Swift Creek where 001 discharges. None of the fluoride concentrations,

shown in Table 3-55, exceed the daily maximum permit limit. As part of the 2015 Annual

Review , EPA contacted the Florida Department of Environmental Protection (FL DEP), which confirmed the facility’s 2013 fluoride discharges (FL DEP, 2015).

Table 3-55 . PCS Phosphate White Spring’s 2013 DMR Monthly A verage Fluoride Discharges

Date Outfall 001 Outfall 002 Outfall 00 4

Flow (MGD) Fluoride

Concentration (mg/L) Flow (MGD) Fluoride

Concentration (mg/L) Flow (MGD) Fluoride

Concentration (mg/L)

31

- Jan

- 13 25 .0 2.3 1.1 0.6 0.9 0.7

28

- Feb

- 13 30.4 1.6 1 .0 1.2 3.3 0.6

31

- Mar

- 13 59.4 1.9 1 .0 3 .0 2.9 0.8

30

- Apr

- 13 65.7 2.1 1 .0 3.9 4.5 0.9

31

- May

- 13 53.3 2.9 1.4 5 .0 6 .0 1.1

30

- Jun

- 13 99.9 2.5 0.9 5.6 5.5 0.9

31

- Jul

- 13 144 2.3 0.8 9 .0 18.9 0.9

31

- Aug

- 13 90.9 2.7 0.8 3.2 5.2 0.9

30

- Sep

- 13 72.4 2.5 0.8 1.9 1.5 0.7

31

- Oct

- 13 33.8 2.9 0.0 0 .0 0.9 0.7

3-643— EPA’s 2015 Preliminary Category Reviews

3.7

—

Mineral Mining and Processing (40 CFR Part 436 )

Table 3-55 . PCS Phosphate White Spring’s 2013 DMR Monthly A verage Fluoride Discharges

Date Outfall 001 Outfall 002 Outfall 00 4

Flow (MGD) Fluoride

Concentration (mg/L) Flow (MGD) Fluoride

Concentration (mg/L) Flow (MGD) Fluoride

Concentration (mg/L)

30

- Nov

- 13 25.4 3 .0 0.0 0 .0 1.8 1 .0

31

- Dec

- 13 52.2 3.2 0.8 1.1 4.2 1.1

Source: DMRLTOutput2013_v1

Table 3-56 presents PCS Phosphate White Spring’s total fluoride discharges from 2011 through 2014. As shown, discharges have increased from 2011 to 2014, almost doubling between

2013 and 2014.

Table 3-56 . PCS Phosphate White Spring’s Fluoride Discharges for 2011 – 2014

Year of Discharge Fluoride TWPE

2011 5,570

2012 12,100

2013 14,900

2014 27,200
Source: DMR Loading Tool

3.7.5 Mineral Mining Category Findings

The estimated toxicity of the Mineral Mining Category discharges resulted primarily from chloride, aluminum, and fluoride discharges reported on DMRs. From the 2015 Annual Review, EPA found:

• Chloride and Aluminum. SES Assets, (formerly Lambert Doc k) in Belmont, WV, and Cedar Lake Plant, in Seagraves, TX, account for 96 percent of the 2013 DMR chloride discharges. SES Assets also accounts for 95 percent of the 2013 DMR aluminum discharges.

− SES Assets’ chloride and aluminum discharges can be attributed to the large salt piles the facility has on site. SES Assets has implemented remediation efforts, is selling its remaining salt piles, and does not plan to store salt on site in the future. For this reason, EPA does not consider these discharges to be representative of the Mineral Mining Category.

− Cedar Lake Plant has net limitations because they withdraw from and discharge to the same saline body of water. Additionally, chloride concentrations have been consistent from 2004 through 2013. For the se reasons, EPA does not consider these discharges to be representative of the Mineral Mining Category.

• Fluoride. One facility, PCS Phosphate White Springs in White Springs, FL, contributed 69 percent of the 2013 DMR fluoride discharges. The facility’s discharges have increased from 2011 to 2014.

3-653— EPA’s 2015 Preliminary Category Reviews

3.7

—

Mineral Mining and Processing (40 CFR Part 436 )

3.7.6 Mineral Mining Category References

1. ERG. 2015. Preliminary Category Review – Facility Data Review for Point Source Category – 436 – Mineral Mining and Processing . ( September). EPA

- HQ

OW -2015-0665. DCN 08162.

2. FL DEP. 2013. Florida Department of Environmental Protection. NPDES Permit: PCS Phosphates White Springs, White Springs, FL (FL0000655). (March 18).

EPA

- HQ

- OW -2015-0665. DCN 08163.

3. FL DEP. 2015. Telephone and Email Communication Between Tom Kallemeyn,

Flor ida Department of Environmental Protection, and Kara Edquist, Eastern Research Group, Inc., Re: 2013 DMR Fluoride Discharges. (May 6 ). EPA

- HQ

OW -2015-0665. DCN 08164.

4. Goble, Billey. 2014. Telephone and Email Communication Between Billey Goble, SES Services , and Diane Perkins, Cirrus Associates, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Aluminum, Chloride Discharges. (December 18). EPA

- HQ

- OW -2015-0665. DCN 08165.

5. TCEQ. 2009. Texas Commission on Environmental Quality. NPDES Permit

State ment of Basis/Technical Summary: Cooper Natural Resources, Cedar Lake Plant, Seagraves, TX (TX0112038). (December 19). EPA

- HQ

- OW -2015-0665.

DCN 08166.

6. TCEQ. 2015. Texas Commission on Environmental Quality. NPDES Permit Statement of Basis/Technical Summary: Cooper Natural Resources, Cedar Lake Plant, Seagraves, TX (TX0112038). (March 31). EPA

- HQ

- OW -2015-0665. DCN

08167.

7. 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.

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

2008-0517-0618.

9. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Re view Report. Washington, D.C. (December). EPA 821-R-12-001. EPA- HQ

- OW -2010-0824­

0195.

10. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program

Plans . Washington, D.C. (September). EPA-820-R-14-001. EPA- HQ

- OW -2014­

0170-0002.

11. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan. Washington, D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN

08208.

3-663— EPA’s 2015 Preliminary Category Reviews

3.8

— Nonferrous Metals Manufacturing (40 CFR Part 421 )

3.8 Nonferrous Metals Manufacturing (40 CFR Part 421 )

EPA identified the Nonferrous Metals Manufacturing (NFMM) Category for preliminary review because it ranks high again, in terms of toxic-weighted pound equivalents (TWPE), in the final 2015 combined point source category rankings. Previously, EPA reviewed discharges from this category as part of the 2004, 2006, 2007, 2009, 2011, and 2013 Annual Reviews in which it also ranked high (U.S. EPA, 2004, 2006, 2007, 2009, 2012, 2014 ). This section summarizes the results of the 2015 Annual Review. EPA focused its 2015 review on discharges of cadmium and fluoride because of their high TWPE relative to the other pollutants discharged by facilities in the NFMM Category. Cadmium, reviewed as part of the 2013 Annual Review, continues to be a top pollutant of concern. For the 2015 Annual Review, available discharge data also showed significant contributions of fluoride.

3.8.1 NFMM Category 2015 Toxicity Rankings Analysis

Table 3-57 compa res the toxicity rankings analyses (TRA) data for the NFMM Category from the 2011, 2013, and 2015 Annual Reviews. EPA did not conduct the TRA in 2012 or 2014, but instead reviewed additional data sources as part of the even

- year annual review, as described in Section 2.2.1 of EPA’s Preliminary 2016 Plan (U.S. EPA, 2016). During the 2015 Annual Review, EPA did not identify any data corrections to the 2013 Discharge Monitoring Report (DMR) and Toxic Release Inventory (TRI) discharge data for the NFMM Category

.

Table 3-57. NFMM C ategory TRI and DMR Facility Counts and Discharges Reported for 2009, 2011, and 2013

Year of Discharge Year of

Review NFMM Category Facility Counts a NFMM Category TWPE

Total TRI

Facilities Total DMR Major

Facilities Total DMR

Minor

Facilities TRI

TWPE b DMR TWPE c Total

TWPE

2009 2011 121 29 19 40,500 160,00 0 d 201,000 d

2011 2013 119 28 23 42,900 330,000 e 373,000 e

2013 2015 108 18 11 34,300 187,000 221,000

Sources: 201 3 Annual Review Report (for 2009 and 2011 DMR and TRI data ) (U.S. EPA, 2014 ); DMRLTOutput2013_v1 (for 2013 DMR); TRILTOutput2013_v1 (for 2013 TRI)

Note: EPA did not evaluate 2010 or 2012 DMR and TRI data

. Note: TWPE values are rounded to three significant f igures. Sums of individual values may not equal the total presented, due to rounding.

a Number of facilities with TWPE greater than zero.

b Releases include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for

POTW removals.

Includes DMR data from both major and minor dischargers.

d 2009 data after corrections were made during the 2011 Annual Review.

e 2011 data after corrections were made during the 2013 Annual Review.

As shown in Table 3-57, the total TWPE increased from 2009 to 2011 and decreased

from 2011 to 2013. Ad ditionally, the number of TRI facilities decreased from 2009 to 2013, while the total number of DMR facilities increased from 2009 to 2011, then decreased significantly from 2011 to 2013.

3-67 c3— EPA’s 2015 Preliminary Category Reviews

3.8

— Nonferrous Metals Manufacturing (40 CFR Part 421 )

3.8.2 NFMM Category Pollutants of Concern

EPA’s 2015 review of the NFMM Category focused on the 2013 DMR discharges

because the DMR data dominate the category’s combined TWPE. Table 3-58 shows the five pollutants with the highest contribution to the 2013 DMR TWPE. As a point of comparison,

Table 3-58 shows the 2011 DMR facility count and TWPE for these top five pollutants, based on the 2013 Annual Review (U.S. EPA, 2014).

Cadmium and fluoride contribute more than 78 percent of the total 2013 DMR TWPE. Cadmium and fluoride are regulated in the NFMM Category effluent limit ations guidelines and standards (ELGs) (40 CFR Part 421). EPA’s investigations of repo rted discharges of these poll utants are presented in Section 3.8.3. EPA did not investigate the other pollutants, including zinc, lead, and aluminum, as part of the 2015 Annual Review, because they represent a small percentage (13 percent) of the 2013 DMR TWPE for the NFMM Category.

Table 3-58. 2013 NFMM Category Top DMR Pollutants

Pollutant b 2013 DMR Data a 2011 DMR Data a

Number of Facilities Reporting Pollutant c TWPE Number of Facilities Reporting Pollutant c TWPE d

Cadmium 4 104,000 9 114,000

Fluoride 15 41,100 18 18,100

Zinc 17 8,990 29 9,910

Lead 11 8,420 20 19,400

Aluminum 16 7,680 22 12,400

Top Pollutant Total NA 170,000 NA 174,000

NFMM Category Total 29 187,000 51 330,000

Sources: DMRLTOutput2013_v1 (for 2013 TWPE); DMRLTOutput2011_v1 (for 2011 TWPE) Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable.

a Includes DMR data from both major and minor dischargers.

b Zinc, lead, and aluminum discharges combined contribute 13 percent of the 2013 category DMR TWPE. Therefore, EPA did not review zinc, lead, or aluminum discharges as part of the 2015 Annual Review.

c Number of facilities with TWPE greater than zero.

d 2011 data after corrections were made during the 2013 Annual Review.

3.8.3 NFMM Cadmium and Fl uoride Discharges in DMR

EPA’s investigation of the cadmium discharges revealed that one facility, Nyrstar Clarksville, Inc. (Nyrstar), in Clarksville, TN, accounts for over 99 percent of the 2013 DMR cadmium discharges (shown in Tabl e 3-59). In addition, EPA’s investigation of the fluoride discharges revealed that two facilities, Nyrstar, in Clarksville, TN, and Horsehead Corp. in Monaca, PA, account for 87 percent of the 2013 DMR fluoride discharges (shown in Table 3­ 60) . Because Nyrstar accounts for the majority of both the cadmium and fluoride discharges, these discharges are reviewed together in this section. EPA did not investigate the remaining

fa cilities discharging cadmium or fluoride as part of the 2015 Annual Review.

3-683— EPA’s 2015 Preliminary Category Reviews

3.8

— Nonferrous Metals Manufacturing (40 CFR Part 421 )

Table 3-59. Top 2013 DMR Cadmium Discharging Facilities

Facility Name Facility

Location Pounds of

Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

Nyrstar Clarksville, Inc. Clarksville, TN 4,480 103,000 99.4%

All other cadmium dischargers in the NFMM Category a 28.6 661 0.6%

Total 4,510 104,000 100%

Source: DMRLTOutput201 3 _v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a Three additional facilities submitted cadmium discharges in the 2013 DMR data

.

Table 3-60. Top 2013 DMR Fluoride Discharging Facilities

Facility Name Facility

Location Pounds of

Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

Nyrstar Clarksville, Inc. Clarksville, TN 691,000 20,700 50%

Horsehead Corp. Monaca, PA 508,000 15,200 37%

All other fluoride dischargers in the NFMM Category a 175,000 5,240 13%

Total 1,370,000 41,200 100%

Source: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 13 additional facilities submitted fluoride discharges in the 2013 DMR data

.

Nyrstar Clarksville, Inc. (Cadmium and Fluoride Discharges)

Nyrstar in Clarksville, TN, produces zinc metal from beneficiation of zinc concentrate ore by a hydrometallurgical process. As secondary products, this facility also produces cadmium metal, sulfuric acid, and metallurgical ly valuable byproducts (TN DEC, 2005). EPA reviewed the facility’s cadmium discharges as part of the 2011 and 2013 Annual Reviews (U.S. EPA, 2012, 2014). Nyrstar discharges cadmium from outfalls 001, SW3, SW4, and SW5, and fluoride

from outfall 001. Outfal l 001 discharges treated process wastewater, sanitary wastewater, stormwater, and cooling water (TN DEC, 2011). Outfalls SW3, SW4, and SW5 discharge stormwater runoff from the main production area, materials handling areas, and ancillary facility

areas, re spectively (Crocker, 2013).

Nyrstar was issued a new permit, which took effect January 2012. The permit set a monthly average cadmium limit of 2.28 pounds per day (lb/day) (1.03 kilograms per day (kg/day)), a daily maximum cadmium limit of 5.29 lb/day (2.4 kg/day), and a fluoride limit of report only for outfall 001. Additionally, the permit set a daily maximum cadmium benchmark

3-693— EPA’s 2015 Preliminary Category Reviews

3.8

— Nonferrous Metals Manufacturing (40 CFR Part 421 )

concentration 25 of 0.0159 milligrams per liter (mg/L) for outfalls SW3, SW4, and SW5, with a quarterly monitoring requirement (TN DEC, 2011).

Table 3-61 presents Nyrstar’s 2013 cadmium concentrations, along with the average daily flow per month for the four outfalls. As shown in Table 3-61, 2013 cadmium loads for outfall 001 are below the facility’s permit limits. However, 2013 cadmium discharges for outfalls SW3, SW4, and SW5 exceed the daily maximum benchmark concentration set in the facility permit.

Table 3-61. Nyrstar’s 2013 DMR Monthly Cadmium Discharges

Outfall Date Flow (MGD) Quantity (kg/day) Concentration (mg/L) NPDES M onthly Average Permit Limit a

001 31

- Jan

- 13 0.610 0.503 NR 1.03 kg/day

001 28

- Feb

- 13 0.660 0.370 NR 1.03 kg/day

001 31

- Mar

- 13 0.605 0.610 NR 1.03 kg/day

001 30

- Apr

- 13 0.680 0.660 NR 1.03 kg/day

001 31

- May

- 13 0.720 0.707 NR 1.03 kg/day

001 30

- Jun

- 13 0.590 0.340 NR 1.03 kg/day

001 31

- Jul

- 13 0.630 0.260 NR 1.03 kg/day

001 31

- Aug

- 13 0.830 0.770 NR 1.03 kg/day

001 30

- Sep

- 13 0.690 0.270 NR 1.03 kg/day

001 31

- Oct

- 13 0.710 0.410 NR 1.03 kg/day

001 30

- Nov

- 13 0.590 0.370 NR 1.03 kg/day

001 31

- Dec

- 13 0.750 0.707 NR 1.03 kg/day

SW3 31

- Mar

- 13 0.130 NR 8.00 b 0.0159 mg/L

SW3 30

- Jun

- 13 0.260 NR 2.46 b 0.0159 mg/L

SW3 30

- Sept

- 13 0.710 NR 3.71 b 0.0159 mg/L

SW3 31

- Dec

- 13 0.120 NR 4.27 b 0.0159 mg/L

SW4 31

- Mar

- 13 0.099 NR 0.110 b 0.0159 mg/L

SW4 30

- Jun

- 13 0.140 NR 0.025 b 0.0159 mg/L

SW4 30

- Sept

- 13 0.380 NR 0.280 b 0.0159 mg/L

SW4 31

- Dec

- 13 0.098 NR 0.220 b 0.0159 mg/L

SW5 31

- Mar

- 13 0.850 NR 0.025 b 0.0159 mg/L

SW5 30

- Jun

- 13 1.30 NR 0.025 b 0.0159 mg/L

SW5 30

- Sept

- 13 3.31 NR 0.050 b 0.0159 mg/L

SW5 31

- Dec

- 13 0.850 NR 0.025 b 0.0159 mg/L

Sources : DMRLTOutput2013_v1 ; TN DEC, 2011 NR: Not Reported

a EPA converted the facility’s cadmium permit limits for outfall 001 to kg/day to match the units of the reported mass discharge loads; the permit lists the limit in lb/day. Additionally, the 0.01 59 mg/L value, shown as the NPDES monthly average permit limit for outfalls SW3, SW4, and SW5, are benchmark concentrations, not

effluent limitations.

b Cadmium concentration exceeds daily maximum benchmark concentration.

Table 3-62 presents Nyrstar’s 2013 fluoride concentrations, along with the average daily flow per month for outfall 001. Because the facility reported fluoride quantities in kg/day for

25 Benchmark/cutoff values are not effluent limitations. Outfalls SW3, SW4, and SW5 discharge stormwater runoff; therefore, benchmark/cutoff concentrations are listed in the facility’s permit to eval uate the effectiveness of their stormwater best management practices (BMPs). If the facility discharge exceeds the benchmark concentration, the facility is required to complete investigations to determine the reason(s) the higher value(s) occurred and

make BMP improvements, as needed, for the relevant parameter (TN DEC, 2011).

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3.8

— Nonferrous Metals Manufacturing (40 CFR Part 421 )

outfall 001, EPA calculated the fluoride concentrations using the pollutant load discharged and the average monthly flow. The facility has a once-per-month monitoring requirement for fluoride in their permit for outfall 001; the permit does not include fluoride effluent limits (TN DEC, 2011). As shown in Table 3-62, the fluoride concentrations vary by three orders of magnitude depending on the month for outfall 001. As part of the 2015 Annual Review, EPA contacted Nyrstar about the fluoride discharges. The facility contact confirmed the reported 2013 flow rates and concentrations and explained that a fluoride sample is taken once- per -month which may not be indicative of the entire month and would only be valid for the 24- hour period that the composite sample was collected. Other parameters reported for outfall 001 are averages of multiple samples throughout the month (Crocker, 2014).

Table 3-62. Nyrstar’s 2013 DMR Monthly Fluoride Discharges for Outfall 001

Date Reported Flow (MGD) Reported Quantity (kg/day) Calculated Concentration (mg/L)

31

- Jan

- 13 0.610 24.9 10.8

28

- Feb

- 13 0.660 29.1 11.6

31

- Mar

- 13 0.605 43.7 19.1

30

- Apr

- 13 0.680 66.8 26.0

31

- May

- 13 0.720 698 256

30

- Jun

- 13 0.590 5.19 2.32

31

- Jul

- 13 0.630 97.1 40.7

31

- Aug

- 13 0.830 62.2 19.8

30

- Sep

- 13 0.690 431 165

31

- Oct

- 13 0.710 2,720 1,010

30

- Nov

- 13 0.590 13.1 5.87

31

- Dec

- 13 0.750 5,940 2,090

Source: DMRLTOutput2013_v1

Table 3-63 presents Nyrstar’s cadmium and fluoride DMR discharges for 2010 through 2014. EPA reviewed 2014 cadmium and fluoride discharges and confirmed that the discharges are not increasing ; however, 2013 cadmium discharges exceed permit benchmark values for three of the four stormwater outfalls and 2013 fluoride concentrations vary by three orders of magnitude depending on the month.

Tabl e 3-63. Nyrstar DMR Cadmium and Fluoride Discharges for 2010 – 2014

Year Cadmium TWPE Fluoride TWPE a

2010 99,700 NR

2011 112,000 NR

2012 166,000 783

2013 103,000 20,700

2014 103,000 6,700

Source: DMRLTOutput2013_v1 ; DMR Loading Tool. Note: TWPE values are rounded to three significant figures. NR: Not Reported

a Nyrstar was issued a new permit in 2012 that added the requirement for fluoride monitoring of outfall 001. Prior to 2012, the facility did not monitor fluoride discharges.

3-713— EPA’s 2015 Preliminary Category Reviews

3.8

— Nonferrous Metals Manufacturing (40 CFR Part 421 )

Horsehead Corporation (Fluoride Discharges)

Horsehead Corporation owned and operated a zinc smelter and ancillary units to prod uce zinc metal, zinc oxide, zinc dust, zinc sulfate, and sulfuric acid, in Monaca, PA. The facility was a zinc smelter that is subject to 40 CFR Part 421 Subpart H (Primary Zinc Subcategory). Subpart H does not regulate fluoride discharges. EPA previously reviewed the facility’s fluoride discharges as part of the 2011 Annual Review; the facility contact confirmed the 2009 fluoride discharges and EPA recommended facility

- specific permitting support to address the facility’s fluoride discharges (U.S. EPA, 2012).

According to the facility’s website, as of April 30, 2014, the operations in Monaca, PA were shut down. In May 2014, the facility started production of zinc metal at a new Mooresboro, NC location (Horsehead Corporation, 2014). 26 Table 3-64 presents Horsehead’s Monaca, PA fluoride discharges for 2010 through 2014. As shown, discharges significantly decreased in 2014, when the facility closed at the end of April.

Table 3-64 . Horsehead DMR Fluoride Discharges for 2010 – 2014

Year Fluoride TWPE

2010 15,600

2011 11,600

2012 13,000

2013 15,200

2014 2,300

Source: DMRLTOutput2013_v1 ; DMR Loading Tool.

3.8.4 NFMM Category Findings

The estimated toxicity of the NFMM Category discharges resulted primarily from cadmium and fluoride discharges reported on DMRs. From the 2015 Annual Review, EPA

found:

• One facility, Nyrstar Clarksville, Inc., in Clarksville, TN, account ed for over 99 percent of the 2013 DMR cadmium discharges and 50 percent of the 2013 DMR fluoride discharges. The facility’s 2013 cadmium discharges are above permit benchmark values for three of the four stormwater outfalls. The facility’s 2013 fluoride discharges vary by three orders of magnitude, depending on the month. The facility currently has reporting requirements for fluoride, but no specific limits.

• Horsehead Corporation in Monaca, PA, contributed 37 percent of the 2013 DMR fluoride discharges (note that Nyrstar Clarksville, Inc., discussed above, contributes 50 percent of the 2013 DMR fluoride discharges; the two facilities together account for 87 percent of the fluoride discharges). The facility closed in 2014.

3.8.5 NFMM Category References

1. Crock er, William. 2013. Telephone and Email Communication Between William Crocker, Nyrstar, and Julia Kolberg, Eastern Research Group, Inc., Re: 2011

26 No 2014 DMR data were submitted for the new facility in Mooresboro, NC.

3-723— EPA’s 2015 Preliminary Category Reviews

3.8

— Nonferrous Metals Manufacturing (40 CFR Part 421 )

DMR Cadmium and Lead Discharges. (December 11). EPA

- HQ

- OW -2014-0170­

0024.

2. Crocker, William. 2014. Telephone an d Email Communication Between William Crocker, Nyrstar, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Fluoride Discharges. (December 11 ). EPA

- HQ

- OW -2015-0665. DCN

08168.

3. ERG. 2015. Preliminary Category Review – Facility Data Review for Point Source Category – 421 – NFMM. (September). EPA

- HQ

- OW -2015-0665. DCN

08169.

4. Horsehead Corporation. 2014. Horsehead Corporation End Operations at Monaca, PA Facility. (May 5). EPA

- HQ

- OW -2015-0665. DCN 08170.

5. TN DEC. 2005. Tennessee Department of Environment and Conservation. NPDES Permit Fact Sheet: Nyrstar Clarksville, Inc., Clarksville, Tennessee

. (May 31). EPA- HQ

- OW -2010-0824-0042.

6. TN DEC. 2011. Tennessee Department of Environment and Conservation. NPDES Permit: Nyrstar Clarksville, Inc., Clarksville, Tennessee . (November 30).

EPA

- HQ

- OW -2014-0170-0025.

7. 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.

8. 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.

9. 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.

10. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent

Gui delines Program Plan . Washington, D.C. (October). EPA-821-R-09-006.

EPA

- HQ

- OW -2008-0517-0514.

11. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. (December). EPA 821-R-12-001. EPA- HQ

- OW -2010-0824­

0195.

12. U.S. EPA. 2014. The 2 013 Annual Effluent Guidelines Review Report

. Washington, D.C. (September). EPA-821-R-14-003. EPA- HQ

- OW -2014-0170­

0077.

13. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan. Washington, D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN

08208.

3-733— EPA’s 2015 Preliminary Category Reviews

3.9

— Ore Mining and Dressing (40 CFR P art 4 40 )

3.9 Ore Mining and Dressing (40 CFR Part 440 )

EPA identified the Ore Mining and Dressing (Ore Mining) Category for preliminary

review because it rank s high again , in terms of toxic-weighted pound equival ent s (TWPE), in the final 2015 combined point source category rankings. Previously, EPA reviewed discharges from this category as part of the 2009, 2010, 2011, and 2013 Annual Reviews in which it also ranked high (U.S. EPA, 2009, 2011a, 2012, 2014). In addition, EPA conducted a preliminary study of this category as part of the 2009 and 2010 Annual Reviews (U.S. EPA, 2011b). From the preliminary study, EPA found that a small percentage of active mines account for the majority of toxic weighted discharges; th erefore, discharge issues are best addressed through permitting, compliance, and enforcement activities rather than revision of 40 CFR Part 440 (U.S. EPA, 2011b).

This section summarizes the results of the 2015 Annual Review. EPA focused its 2015

review o n discharges of copper, selenium, radium-226, arsenic, lead and lead compounds, and silver and silver compounds because of their high TWPE relative to other pollutants discharged by facilities in the Ore Mining Category. Copper and arsenic, reviewed as part of the 2013 Annual Review, continue to be top pollutants of concern. For the 2015 Annual Review, available discharge data also showed significant contributions of selenium, radium-226, lead and lead compounds, and silver and silver compounds.

3.9.1 Ore Mining Category 2015 Toxicity Rankings Analysis

Table 3-65 compares the toxicity rankings analyses (TRA) data for the Ore Mining

Cat egory from the 2011, 2013, and 2015 Annual Reviews. EPA did not conduct the TRA in 2012 or 2014, but instead reviewed additional data sources as part of the even-year annual review, as described in Section 2.2.1 of EPA’s Preliminary 2016 Plan (U.S. EPA, 2016). During the 2015 Annual Review, EPA did not identify any data corrections to the 2013 Discharge Monitoring Report (DMR) and Toxic Release Inventory (TRI) discharge data for the Ore Mining Category.

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3.9

— Ore Mining and Dressing (40 CFR P art 4 40 )

Table 3-65. Ore Mining Category TRI a nd DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

Year of Discharge Year of

Review Ore Mining Category Facility Counts a Ore Mining Category TWPE

Total TRI

Facilities Total DMR Major

Facilities Total DMR

Minor

Facilities TRI TWPE b DMR

TWPE c Total TWPE

2009 2011 34 45 31 68,900 139,000 208,000

2011 2013 33 53 37 72,900 d 110,000 183,000 d

2013 2015 32 33 20 82,700 57,700 140,000

Sources: TRIReleases2009_v2

, DMR Loads2009_v2 , and 2011 Annual Review Report (for 2009 DMR and TRI data ) (U.S. EPA, 2012 ); DMR LTOutput2011_v1

, TRILTOutput2011_v1

, and 2013 Annual Review Report (for 2011 DMR and TRI data) (U.S. EPA, 2014); DMR LTOutput2013_v1 (for 2013 DMR ); TRILTOutput2013_v 1 (for 2013 TRI)

. Note: EPA did not evaluate 2010 or 2012 DMR and TRI dat a.

Note: TWPE values are rounded to three significant figures. Sums of individual values may not equal the total presented, due to rounding.

a Number of facilities with TWPE greater than zero.

b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account

for POTW removals.

c Includes DMR data from both major and minor dischargers

. d 2011 DMR data after corrections were made during the 2013 Annual Revi ew.

As shown in Table 3-65 , the number of TRI facilities with pollutant releases has decreased slightly, while the TRI TWPE has increased from 2009 to 2013. The numbe r of DMR facilities with pollutant discharges increased from 2009 to 2011 then decreased substantially from 2011 to 2013, while the DMR TWPE decreased from 2009 to 2013. The total number of permitted facilities (not just those that reported discharges grea ter than zero) also decreased from 2011 to 2013 (DMR Pollutant Loading Tool), suggesting that the number of U .S. ore mines may be declining.

3.9.2 Ore Mining Category Pollutants of Concern

EPA’s 2015 review of the Ore Mining Category focused on the 2013 DMR and TRI discharges because both contribute to the category’s combined TWPE. Table 3-66 shows the f ive pollutants with the highest contribution to the 2013 DMR TWPE. As a point of comparison,

Table 3-66 also shows the 2011 DMR facility count and TWPE for these top five pollutants, based on the 2013 Annual Review (U.S. EPA, 2014). Copper, selenium, radium-226, and arsenic contribute 67 percent of the total 2013 DMR TWPE. The Ore Mining effluent limitations guidelines and standards (ELGs) regulate copper, radium-226, and arsenic, but do not include

limitations for selenium. Sections 3.9.3 through 3.9.6 present EPA’s investigation of these top DMR pollutants. EPA did not investigate molybdenum as part of the 2015 Annual Review because it represents a small percentage (9 percent) of the 2013 DMR TWPE for the Ore Mining Category.

Table 3-67 shows the five pollutants with the highest contribution to the 2013 TRI TWPE. As a point of comparison, Table 3-67 also shows the 2011 TRI facility count and TWPE for these top five pollutants, based on the 2013 Annual Review (U.S. EPA, 2014). EPA investigated lead and lead compounds and silver and silver compounds because they cont ribute

3-75c 3— EPA’s 2015 Preliminary Category Reviews

3.9

— Ore Mining and Dressing (40 CFR P art 4 40 )

over 71 percent of the total 2013 TRI TWPE. Additionally, EPA investigated TRI discharges of arsenic and arsenic compounds and copper and copper compounds because they are top DMR pollutants. Sections 3.9.3 and 3.9.6 through 3.9.8 present EPA’s investigation of reported releases of the top TRI pollutants. EPA did not investigate vanadium and vanadium compounds as part of the 2015 Annual Review because they represent a small percentage (less than 8 percent) of the 2013 TRI TWPE for the Ore Mining Category.

Table 3-66. Or e Mining Category Top DMR Pollutants

Pollutant b 2013 DMR Data a 2011 DMR Data a

Number of Facilities Reporting Pollutant c TWPE Number of Facilities Reporting Pollutant c TWPE

Copper 30 14,100 49 6,940

Selenium 13 9,140 15 2,060

Radium

- 226 4 8,050 0 0

Arsenic 14 7,470 19 11,800

Molybdenum 4 5,250 4 5,700

Top Pollutant Total NA 44,000 NA 26,500

Ore Mining Category Total 53 57,700 90 110,000

Sources: DMRLTOutput2013_v1 (for 2013 TWPE); DMRLTOutput2011_v1 (for 2011 facility counts ) Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable.

a Includes DMR data from both major and minor dischargers.

b Molybdenum discharges contribute 9 percent of the 2013 category DMR TWPE. Therefore, EPA did not review molybdenum discharges as part of the 2015 Annual Review.

Number of facilities with TWPE greater than zero.

3-763— EPA’s 2015 Preliminary Category Reviews

3.9

— Ore Mining and Dressing (40 CFR P art 4 40 )

Table 3-67. Ore Mining Category Top TRI Pollutants

Pollutant a 2013 TRI Data 2011 TRI Data

Number of Facilities Reporting Pollutant b TWPE Number of Facilities Reporting Pollutant b TWPE c

Lead and Lead Compounds 25 42,700 25 33,600

Silver and Silver Compounds 3 16,500 3 16,500

Vanadium and Vanadium Compounds 4 5,920 4 4,530

Arsenic and Arsenic Compounds 5 4,640 6 3,820

Copper and Copper Compounds 17 3,110 17 3,280

Top Pollutant Total NA 72,900 NA 61,700

Ore Mining Category Total 32 82,700 33 72,900

Sources: TRILTOutput2011_v1 (for 2011 TRI TWPE); TRILTOutput2013_v1 (for 2013 TRI TWPE)

Note: Sums of individual values may not equal the total presented, due to rounding.

N A: Not applicable.

a Vanadium and vanadium compound releases contribute less than 8 percent of the 2013 category TRI TWPE. Therefore, EPA did not review vanadium and vanadium compound releases as part of the 2015 Annual Review.

b Number of facilities with TWPE greater than zero.

c 2011 data after corrections were made during the 2013 Annual Review.

3.9.3 Ore Mining Copper Discharges in DMR and TRI

EPA’s investigation of the copper and copper compound discharges in TRI revealed that 17 facilities account for 3,110 TWPE, with no facility contributing more than 200 TWPE, on average. Because each facility contributes less than 200 TWPE on average, EPA d id not review copper and copper compound releases reported to TRI for individual facilities.

In contrast to TRI, EPA’s investigation of the DMR copper discharges revealed that two facilities, Northshore Mining – Silver Bay, in Silver Bay, MN, and Copper Range Company’s White Pine Mine, in White Pine, MI, account for 76 percent of the 2013 DMR copper discharges (shown in Table 3-68). EPA did not investigate the remaining facilities discharging copper as part of the 2015 Annual R eview.

3-773— EPA’s 2015 Preliminary Category Reviews

3.9

— Ore Mining and Dressing (40 CFR P art 4 40 )

Table 3-68. Top 2013 DMR Copper Discharging Facilities

Facility Name Facility Location Pounds of Polluta nt Discharged Pollutant

TWPE Percent of Category TWPE

Northshore Mining

– Silver Bay Silver Bay, MN 11,500 7,260 51.7%

Copper Range Company White Pine

Mine White Pine, MI 5,420 3,420 24.3%

All other copper dischargers in the Ore Mining Category a 5,360 3,380 24.0%

Total 22,300 14,100 100%

Source: DMRLTOutput201 3 _v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 28 additional facilities submitted copper discharges in the 2013 DMR data

.

Northshore Mining

– Silver Bay

Northshore Mining in Silver Bay, MN, is a taconite 27 mine with a processing facility and power plant onsite. The facility discharges copper from one outfall. As part of the 2015 Annual Review, EPA contacted the mine about the copper discharges. The f acility contact confirmed the 2013 DMR copper discharges and stated that the facility monitors copper discharges yearly from a non-contact cooling water discharge from the onsite power plant, in accordance with the facility’s NPDES permit. The facility doe s not have a permit limit for copper (Hayden, 2015). The Iron Ore Subcategory, Subpart A, of the Ore Mining ELGs does not include limitations for

copper.

Table 3-69 presents Northshore Mining’s copper discharges from 2010 through 2014. As shown, discharges increased from 2012 to 2013, but decreased from 2013 to 2014. The facility has historically collected samples from a sample port on the discharge pipe. In June and J uly 2015, the facility collected samples from the sample port on the discharge pipe, inside the diffuser box at the outlet to the lake, and from the lake. It was determined that sample contamination is occurring from the sample port on the discharge pipe, resulting in elevated copper discharges. The facility contact stated that starting with the 2015 reporting year; the facility will collect samples from inside the diffuser box at the outlet to the lake and submit the results on their DMRs (Hayden, 2015). T herefore, EPA expects copper discharges from this facility to decrease in future years.

Table 3-69 . Northshore Mining’s DMR Copper Discharges from 2010 – 2014

Year Pounds TWPE

2010 8,250 5,200

2011 4,740 2,980

2012 6,110 3,850

2013 11,500 7,260

2014 4,170 2,630

Source: DMRLTOutput201 3_v1; DMR Loading Tool.

27 Taconite is a low

- grade iron ore.

3-783— EPA’s 2015 Preliminary Category Reviews

3.9

— Ore Mining and Dressing (40 CFR P art 4 40 )

Copper Range Company’s White Pine Mine

Copper Range Company’s White Pine Mine, in White Pine, MI, was an active copper mine from 1952 to 1995 (Michelson, 2014). As part of the 2015 Annual Review, EPA contacted the Michigan Department of Environmental Quality (MI DEQ) regarding the mine’s copper discharges. The MI DEQ contact stated that the White Pine Mine is closed and the discharges are from tailings runoff. The mine has an active NPDES permit, with monitoring -only requirements for copper (MI DEQ, 2010). The MI DEQ contact also stated that sto rmwater runoff typically drives the copper discharges for the mine, resulting in higher copper discharges with higher precipitation (Conroy, 2015). The Copper, Lead, Zinc, Gold, Silver, and Molybdenum Ores Subcategory, Subpart J, of the Ore Mining ELGs includes concentration limitations for copper of

0.15 mg/L monthly average and 0.30 mg/L daily maximum. EPA compared the 2013 copper concentrations from the White Pine Mine to the Subpart J copper ELGs and found that all concentrations are below the monthly average and daily maximum limitations.

3.9.4 Ore Mining Selenium Discharges in DMR

EPA’s investigation of the selenium discharges revealed that one facility, Tilden Mine in Ishpeming, MI, accounts for 89 percent of the 2013 selenium discharges (shown in Table 3-70). The remaining facilities account for a combined TWPE of 965, therefore, EPA did not investigate the remaining facilities discharging selenium as part of the 2015 Annual R eview.

Table 3-70. Top 2013 DMR Selenium Discharging Facilities

Facility Name Facility Location Pounds of Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

Tilden Mine a Ishpeming, MI 7,300 8,170 89.4%

All other selenium dischargers in the Ore Mining Category b 862 965 10.6%

Total 8,160 9,140 100%

Source: DMRLTOutput201 3 _v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a This facility is named Cliffs District Lab in the DMR database ( DMRLTOutput2013_v1 ). However, the facility’s permit lists the permittee as Tilden Min e.

b 12 additional facilities submitted selenium discharges in the 2013 DMR data

.

Tilden Mine is a hematite 28 mine. The Iron Ore Subcategory, Subpart A, of the Ore Mining ELGs does not include limitations for selenium. As part of the 2015 Annual Review, EPA contacted the company to discuss their selenium discharges. Tilden Mine has a large tailings pond and sends the water through clarifiers before it is discharged. The facility permit was reissued in 2012 and included a schedule of compliance for selenium discharges. The facility completed a feasibility study of treatment options in August 2013, and is currently performing pilot studies for selected selenium treatment systems. The facility plans to implement a treatment system and meet permit limits 29 for selenium by November 2017 (Ketzenberger,

28 Hematite is the mineral form of iron (III) oxide.

29 The 2012 facility permit lists total selenium permit limits of 1.1 lb/day and 5.1 μg/L monthly average for outfall 002, effective November 1, 2017.

3-793— EPA’s 2015 Preliminary Category Reviews

3.9

— Ore Mining and Dressing (40 CFR P art 4 40 )

2015). EPA expects decreases in selenium discharges from this facility on future DMRs because of new limits on their permit and because new on site treatment technologies are to be installed at this facility.

3.9.5 Ore Mining Radium

- 226 Discharges in DMR

EPA’s investigation of the radium- 226 discharges revealed that one fac ility, JD -7 and JD9 Mines in Naturita, CO, accounts for over 99 percent of the 2013 radium-226 discharges (shown

in Table 3- 71 ). EPA did not investigate the remaining facilities discharging radium-226 as part

of the 2015 Annual R eview.

Table 3-71. Top 2013 DMR Radium-226 Discharging Facilities

Facility Name Facility

Location Pounds of Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

JD

- 7 and JD

- 9 Mines Naturita, CO 0.00194 8,040 99.9%

All other radium

- 226 dischargers in the Ore Mining Category a 0.00000120 4.94 0.06%

Total 0.00195 8,050 100%

Source: DMRLTOutput201 3 _v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a Three additional facilities submitted radium

- 226 discharges in the 2013 DMR data

.

JD -7 and JD-9 mines, owned by the Cotter Corporation, are uranium and vanadium mines. The Uranium, Radium, and Vanadium Ores Subcategory, Subpart C, of the Ore Mining

ELGs includes concentration limitations for total Radium -226 10 mg/L monthly average and 30 mg/L daily maximum. The mines have not been actively operating since 1980. However, Cotter Corporation keeps the mines on active standby status, ready to resume productio n ( CDPHE

, 2011).

The 2013 radium-226 DMR discharge resulted from one measured concentration from

outfall 001B at the JD- 7 mine in September 2013. The facility discharges process water from the

mine’s waste dump through outfall 001B. As part of the 2015 Annual Review, EPA contacted the Colorado Department of Public Health and Environment (CDPHE) to discuss the mine’s radium-226 discharges. The CDPHE contact confirmed the radium-226 discharge and contacted

th e facility directly to determine the reason behind the September 2013 discharge. The facility contact stated that a major flooding event in September 2013 caused the radium-226 discharge (Morgan, 2015). The facility has had no other radium-226 discharges from 2011 through 2014, indicating that the September 2013 discharge was an outlier.

3.9.6 Ore Mining Arsenic Discharges in DMR and TRI

EPA’s investigation of the arsenic discharges in DMR and TRI revealed that one facility, Kennecott Utah Copper Smelter and Refinery (Kennecott Utah) in Magna, UT, accounts for 69 percent and 66 percent of the DMR and TRI arsenic discharges, respectively (shown in Table 3­

72 and Table 3-73). The remaining facilities account for a combined TWPE of 1,290 in DMR and 1,560 in TRI, therefore, EPA did not investigate the remaining facilities discharging arseni c in DMR or TRI as part of the 2015 Annual Review.

3-803— EPA’s 2015 Preliminary Category Reviews

3.9

— Ore Mining and Dressing (40 CFR P art 4 40 )

Table 3-72. Top 2013 DMR Arsenic Discharging Facilities

Facility Name Facility Location Pounds of Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

Kennecott Utah Copper Smelter & Refinery Magna, UT 1,290 5,200 69.6%

All other arsenic dischargers in the Ore Mining Category a 561 2,270 30.4%

Total 1,850 7,470 100%

Source: DMRLTOutput201 3 _v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 13 additional facilities submitted arsenic discharges in the 2013 DMR data

.

Table 3-73. Top Facilities Reporting 2013 TRI Arsenic and Arsenic Compound Releases

Facility Name Facility Location Pounds of Pollutant

Released Pollutant

TWPE Percent of Category TWPE

Kennecott Utah Copper Smelter & Refinery Magna, UT 762 3,080 66.4%

All other arsenic dischargers in the Ore Mining Category a 386 1,560 33.6%

Total 1,150 4,640 100%

Source: TRILTOutput2013_v1

. Note: Sums of individual values may not equal the total presented, due to rounding.

a Four additional facilities reported arsenic and arsenic compound releases in the 2013 TRI

.

Kennecott Utah, owned by Rio Tinto, is a large, integrated facility that includes an open pit copper mine, a concentrator, a power plant, a smelter, a refinery, a reverse osmosis plant, a tailings pond, and a sewage treatment plant. All active facilities are west of Salt Lake City, UT. The concentrator typically processes approximately 170,000 tons of ore per day from the Bingham Canyon Mine (UT DEQ, 2009).

The facility discharges arsenic from six outfalls. Table 3-74 presents Kennecott Utah’s DMR and TRI arsenic discharges from 2007 through 2014. As shown, both DMR and TRI arsenic discharges have remained consistent over this time period. Table 3-75 presents Kennecott Utah’s 2013 DMR arsenic discharges and NPDES permit limits. 30 As shown, all 2013 DMR arsenic discharges are below the NPDES monthly average and daily maximum permit limits. The facility’s high arsenic TWPE likely results from the relatively high level of industrial activity at

the site.

Table 3-74 . Kennecott Utah’s DMR and TRI Arsenic Discharges from 2007 – 2014

Year DMR TWPE TRI TWPE

2007 3,170 1,170

30 The facility’s permit limits are based on the Ore Mining ELGs (40 CFR Part 440), Nonferrous Metals Manufacturing ELGs (40 C FR Part 421), Utah Secondary Treatment Standards, and Utah Water Quality Standards (UT DEQ, 2009).

3-813— EPA’s 2015 Preliminary Category Reviews

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— Ore Mining and Dressing (40 CFR P art 4 40 )

Table 3-74 . Kennecott Utah’s DMR and TRI Arsenic Discharges from 2007 – 2014

Year DMR TWPE TRI TWPE

2008 5,460 1,210

2009 5,730 2,890

2010 5,370 1,230

2011 5,470 2,260

2012 4,230 1,210

2013 5,200 3,080

2014 3,790 NA

Source: DMRLTOutput201 3_v1; TRILTOutput2013_v1; DMR Loading Tool.

NA: Not available

.

Table 3-75 . Kennecott Utah’s 2013 DMR Arsenic Discharges

Outfall Date Reported Monthly Average Data NPDES Permit Limits

Flow (MGD) Quantity (kg/day) Concentration ( mg/L ) Monthly Average Daily Maximum

004 31

- Mar

- 13 7.6 NR 0.015 Monitoring Only Monitoring Only

004 30

- Jun

- 13 0 NR 0 Monitoring Only Monitoring Only

004 30

- Sep

- 13 4.6 NR 0.053 Monitoring Only Monitoring Only

004 31

- Dec

- 13 5.12 NR 0.03 Monitoring Only Monitoring Only

008 31

- Mar

- 13 0 NR 0 0.25 mg/L 0.50 mg/L

008 30

- Jun

- 13 0.08 NR 0.068 0.25 mg/L 0.50 mg/L

008 30

- Sep

- 13 0 NR 0 0.25 mg/L 0.50 mg/L

008 31

- Dec

- 13 0 NR 0 0.25 mg/L 0.50 mg/L

010 31

- Mar

- 13 0.05 NR 0.008 Monitoring Only 0.10 mg/L

010 30

- Jun

- 13 0.04 NR 0.011 Monitoring Only 0.10 mg/L

010 30

- Sep

- 13 0.05 NR 0.007 Monitoring Only 0.10 mg/L

010 31

- Dec

- 13 0.07 NR 0.008 Monitoring Only 0.10 mg/L

012 31

- Jan

- 13 13.2 NR <0.005 0.25 mg/L 0.50 mg/L

012 28

- Feb

- 13 15 NR 0.012 0.25 mg/L 0.50 mg/L

012 31

- Mar

- 13 21.5 NR 0.018 0.25 mg/L 0.50 mg/L

012 30

- Apr

- 13 19.5 NR 0.076 0.25 mg/L 0.50 mg/L

012 31

- May

- 13 13.6 NR 0.043 0.25 mg/L 0.50 mg/L

012 30

- Jun

- 13 0 NR 0 0.25 mg/L 0.50 mg/L

012 31

- Jul

- 13 0 NR 0 0.25 mg/L 0.50 mg/L

012 31

- Aug

- 13 0 NR 0 0.25 mg/L 0.50 mg/L

012 30

- Sep

- 13 0 NR 0 0.25 mg/L 0.50 mg/L

012 31

- Oct

- 13 20.1 NR 0.014 0.25 mg/L 0.50 mg/L

012 30

- Nov

- 13 14 NR 0.032 0.25 mg/L 0.50 mg/L

012 31

- Dec

- 13 0 NR 0 0.25 mg/L 0.50 mg/L

104 31

- Jan

- 13 0.28 <0.0027 NR 5.08 kg/day 12.4 kg/day

104 28

- Feb

- 13 0.34 0.0077 NR 5.08 kg/day 12.4 kg/day

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— Ore Mining and Dressing (40 CFR P art 4 40 )

104 31

- Mar

- 13 0.31 0.0108 NR 5.08 kg/day 12.4 kg/day

104 30

- Apr

- 13 0.29 0.34 NR 5.08 kg/day 12.4 kg/day

104 31

- May

- 13 0.32 0.052 NR 5.08 kg/day 12.4 kg/day

104 30

- Jun

- 13 0 0 NR 5.08 kg/day 12.4 kg/day

104 31

- Jul

- 13 0 0 NR 5.08 kg/day 12.4 kg/day

104 31

- Aug

- 13 0 0 NR 5.08 kg/day 12.4 kg/day

104 30

- Sep

- 13 0.3 0.013 NR 5.08 kg/day 12.4 kg/day

104 31

- Oct

- 13 0.34 0.016 NR 5.08 kg/day 12.4 kg/day

104 30

- Nov

- 13 0.29 0.027 NR 5.08 kg/day 12.4 kg/day

104 31

- Dec

- 13 0.25 0.011 NR 5.08 kg/day 12.4 kg/day

SW4 30

- Jun

- 13 0.0000099 NR 0.053 Monitoring Only Monitoring Only

SW4 31

- Dec

- 13 0.000099 NR 0.006 Monitoring Only Monitoring Only

Source: DMRLTOutput2013_v1 ; UT DEQ, 2009

3.9.7 Ore Mining Lead and Lead Compound Discharges in TRI

EPA’s investigation of lead and lead compound discharges revealed that three facilities account for 91 percent of the lead and lead compound discharges reported in to TRI in 2013 (shown in Table 3-76). The remaining facilities account for a combined TWPE of 3,500, therefore, EPA did not investigate the remaining facilities discharg ing lead and lead compounds as part of the 2015 Annual R eview.

Table 3-76. Top Facilities Reporting 2013 TRI Lead and Lead Compound Releases

Facility Name Facility Location Pounds of Pollutant

Released Pollutant

TWPE Percent of Category TWPE

Fletcher Mine Centerville, MO 8,250 18,500 43.3%

Buick Mine Boss, MO 6,870 15,400 36.0%

Brushy Creek Mine Boss, MO 2,390 5,360 12.5%

All other lead and lead compound dischargers in the Ore Mining Category a 1,560 3,500 8.20%

Total 19,100 42,700 100%

Source: TRILTOutput2013_v1 Note: Sums of individual values may not equal the total presented, due to rounding.

a 22 additional facilities reported lead and lead compound releases in the 2013 TRI

.

Fletcher Mine, in Centerville, MO, and Buick Mine and Brushy Creek Mine in Boss, MO, are owned by Doe Run Resources Corporation, a lead mining company headquartered in St. Louis, MO, with facilities in southeast Missouri. Doe Run owns and operates several mining and milling facilities, as well as primary and secondary lead smelters. Ore from the mines at the Doe Run facilities is crushed, milled, and processed; lead concentrate is transported from the mills to the primary and secondary lead smelters for sme lting and refining. Doe Run Resources Corporation agreed to a consent decree on October 8, 2010 with the U.S. Department of Justice, EPA, and the Missouri Department of Natural Resources (MO DNR), to spend approximately $65 million to correct violations of several environmental laws at 10 of its lead mining, milling,

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— Ore Mining and Dressing (40 CFR P art 4 40 )

and smelting facilities in southeast Missouri. These 10 facilities include Fletcher Mine, Buick Mine, and Brushy Creek Mine (U.S. EPA, 2010).

As part of the 2015 Annual Review, EPA contacted MO DNR about lead and lead compound releases from these mines. The MO DNR contact stated that the mines are active and there is an administrative stay on enforcement activities for the sites due to the consent decree (Sappington, 2014). Table 3-77 presents the lead and lead compound TRI releases for Fletcher Mine, Buick Mine, and Brushy Creek Mine. As shown, lead and lead compound TRI releases

have increased for all min es from 2009 to 2013. However, due to the consent decree, EPA expects lead discharges to decrease from Doe Run facilities over the next several years.

Table 3-77. TRI Lead and Lead Compound Releases from 2009 – 2013

Year Fletcher Mine TWPE Buick Mine TWPE Brushy Creek Mine TWPE

2009 9,230 11,300 4,120

2010 7,700 10,200 2,710

2011 11,700 11,900 5,970

2012 10,500 12,800 3,480

2013 18,500 15,400 5,360

Source: TRILTOutput2013_v1; DMR Loading Tool.

3.9.8 Ore Mining Silver and Silver Compound Discharges in TRI

EPA’s investigation of the silver and silver compound discharges revealed that two facilities, Kennecott Utah Copper Smelter & Refinery, in Magna, UT and Kennecott Utah Copper Mine, in Bingham Canyon, UT, account for over 99 percent of the 2013 silver and silver compound discharges (shown in Table 3-78). EPA did not inve stigate the remaining facility discharging silver and silver compounds as part of the 2015 Annual R eview.

Table 3-78. Top Facilities Reporting 2013 TRI Silver and Silver Compound Releases

Facility Name Facility Location Pounds of

Pollutant

Released Pollutant

TWPE Percent of Category

TWPE

Kennecott Utah Copper Smelter & Refinery Magna, UT 500 8,240 49.9%

Kennecott Utah Copper Mine Bingham Canyon, UT 500 8,240 49.9%

Freeport

- McMoran Miami Inc. Claypool, AZ 0.6 9.88 0.06%

Total 1,000 16,500 100%

Source: TRILTOutput2013_v1 Note: Sums of individual values may not equal the total presented, due to rounding.

Rio Tinto owns both the Kennecott Utah Copper Smelter and Refinery, in Magna, UT, and Kennecott Utah Copper Mine, in Bingham Canyon, UT. Section 3.9.6 discusses ars enic discharges from the Magna, UT location, which is a large, integrated copper mining facility. Both facilities reported 500 pounds of silver and silver compounds discharged to TRI from 2007 through 2013.

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— Ore Mining and Dressing (40 CFR P art 4 40 )

As part of the 2015 Annual Review, EPA contacted Rio Tinto to confirm the TRI silver and silver compound releases for both Kennecott facilities. According to the contact, the company bases the TRI silver and silver compound release on plant knowledge that silver releases are at least an order of magnitude less than copper releases, and on historical plant data for silver concentrations in the tailings pond. The facility uses a conservative maximum estimate of 1,000 pounds of silver released to water, divided equally between the copper smelter and

refiner y in Magna, UT, and the mine in Bingham Canyon, UT (Nannini, 2014). The facility does not have silver discharges in the 2013 DMR data.

3.9.9 Ore Mining Category Findings

The estimated toxicity of the Ore Mining Category discharges resulted primarily from copper, selenium, radium-226, and arsenic discharges reported on DMRs, and lead and lead compound and silver and silver compound releases reported to TRI. From the 2015 Annual Review, EPA found:

• Copper

. Two facilities, Northshore Mining, in Silver Bay, MN, and White Pine Mine, in White Pine, MI, account for 76 percent of the 2013 copper discharges. The Northshore Mining facility contact confirmed that copper discharges result from contamination at the sample port on the discharge pipe. Starting with the 2015

r eporting year, the facility will collect samples from inside the diffuser box at the outlet to the lake. Therefore, EPA expects copper discharges from this facility to decrease in future years. The White Pine Mine is closed and discharges are from tailings runoff, which typically fluctuate with yearly rainfall. EPA does not consider these copper discharges to be representative of the Ore Mining Category.

• Selenium

. One facility, Tilden Mine in Ishpeming, MI, accounts for 89 percent of the 2013 selenium discharges. The facility permit was reissued in 2012 and included a schedule of compliance for selenium discharges. The facility plans to implement new on site treatment technologies to meet revised permit limits for selenium by 2017; therefore, EPA expects decreases in selenium discharges from this facility on future

DMRs.

• Radium-226

. One facility, JD -7 and JD-9 mines in Naturita, CO, accounts for over 99 percent of the 2013 radium-226 discharges. The 2013 radium- 226 discharges resulted

from one measured conc entration from an outfall where the facility discharges process water from the mine’s waste dump. The facility confirmed the 2013 discharge resulted from a major flooding event at the site in September 2013; the facility has had no other radium-226 discharges from 2011 through 2014, indicating that the 2013 discharge was an outlier. For this reason, EPA does not consider radium -226 discharges from the JD -7 and JD-9 mines to be representative of typical discharges from this facility or from the Ore Mining Ca tegory.

• Arsenic

. One facility, Kennecott Utah Copper Smelter and Refinery in Magna, UT, accounts for 69 percent and 66 percent of the DMR and TRI arsenic discharges, respectively. The facility is a large, integrated copper mining facility. The facility’s 2013 DMR arsenic discharges are below the NPDES monthly average and daily maximum permit limits. The facility’s h igh arsenic TWPE likely results from the

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3.9

— Ore Mining and Dressing (40 CFR P art 4 40 )

relatively high level of industrial activity at the site. Therefore, EPA does not consider the facility’s arsenic discharges to be representative of discharges across the Ore Mining Category.

• Lead

. Three mines, Fletcher Mine, in Centerville, MO, and Buick Mine and Brushy Creek Mine, in Boss, MO, account for 91 percent of the TRI lead and lead compound releases; Doe Run Resources Corporation owns all three mines. Doe Run agreed to a consent decree on October 8, 2010 to correct violations of several environmental laws at many of its facilities, including Fletcher Mine, Buick Mine, and Brushy Creek Mine. Therefore, EPA expects lead discharges from Doe Run facilities to decrease in

the future.

• Silver

. Two facilities, Ken necott Utah Copper Smelter and Refinery, Magna, UT, and Kennecott Utah Copper Mine in Bingham Canyon, UT, account for over 99 percent of the 2013 silver and silver compound releases. Rio Tinto owns both facilities, which are part of a large, integrated cop per mining facility. The facility confirmed the 2013 TRI silver and silver compound releases and stated that the releases are based on estimates from historical plant data for silver concentrations. Because the facility bases its reported TRI releases on conservative estimates not confirmed with sampling data, EPA cannot asses how representative they are of actual silver and silver compound releases from the facility.

3.9.10 Ore Mining and Dressing Category References

1. CDPHE. 2011. Colorado Department of Public Health and Environment. NPDES Permit and Fact Sheet: Cotter Corporation

– JD -7 and JD- 9 Mines, Naturita, CO (CO0036251). (June 1). EPA

- HQ

- OW -2015-0665. DCN 08186.

2. Conroy, Randy. 2015. Telephone and Email Communication Between Randy Conroy, Michigan Departm ent of Environmental Quality, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Copper Discharges for Copper Range Co. (June 10). EPA

- HQ

- OW -2015-0665. DCN 08187.

3. ERG. 2015. Preliminary Category Review – Facility Data Review for Point Source Category – 440 – Ore Mining and Dressing. ( September ). EPA

- HQ

- OW

2015-0665. DCN 08188.

4. Hayden, Andrea. 2015. Telephone and Email Communication Between Andrea Hayden, Cliffs Natural Resources, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Copper Discharges for Northshore Mining. (June 9). EPA

HQ

- OW -2015-0665. DCN 08189.

5. Ketzenberger, Brent. 2015. Telephone and Email Communication Between Brent Ketzenberger, Cliffs Natural Resources, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Selenium Discharges for Tilden Mine, Ishpeming, MI. (June 9). EPA

- HQ

- OW -2015-0665. DCN 08190.

6. Michelson, Daniel. 2014. Michigan Technological University. Copper Range Company Records, MS-080. (June 25). EPA

- HQ

- OW -2015-0665. DCN 08191.

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— Ore Mining and Dressing (40 CFR P art 4 40 )

7. MI DEQ. 2010. Michigan Department of Environmental Quality. NPDES Permit for Copper Range Company, White Pine, MI (MI0006114). (November 1). EPA

HQ

- OW -2015-0665. DCN 08192.

8. Morgan, Kelly. 2015. Telephone and Email Communication Between Kelly Morgan, Colorado Department of Public Health & Environment, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Radium-226 Discharges for

JD -7 and JD-9 Mines. (June 9). EPA

- HQ

- OW -2015-0665. DCN 08193.

9. Nannini, Tom. 2014. Telephone and Email Communication Between Tom

Nan nini, Rio Tinto Kennecott, and Eva Knoth, Eastern Research Group, Inc., Re: 2013 TRI Water Releases for Kennecott Utah Copper. (December 16). EPA

- HQ

OW -2015-0665. DCN 08194.

10. Sappington, Amanda. 2014. Telephone and Email Communication Between Amanda Sappington, Missouri Department of Natural Resources, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 TRI Lead Discharges for Fletcher Mine and Buick Mine. (December 23). EPA

- HQ

- OW -2015-0665. DCN 08195.

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 -2008-0517-0514.

12. U.S. EPA. 2010. Doe Run Resources Corporation Settlement. (October 8). EPA

HQ

- OW -2015-0665. DCN 08196.

13. U.S. EPA. 2011a. Technica l Support Document for the 2010 Effluent Guidelines Program Plan . Washington, D.C. (October). EPA 820-R-10-021. EPA- HQ

- OW

2008-0517-0618.

14. U.S. EPA. 2011b. Ore Mining and Dressing Preliminary Study Report

. Washington, D.C. (December). EPA-821-R-08-012. EPA

- HQ

- OW -2008-0517­

0712.

15. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. (December). EPA 821-R-12-001. EPA- HQ

- OW -2010-0824­

0195.

16. U.S. EPA. 2014. The 2013 Annual Effluent Guidelines Review Report

. Washington, D.C. (Sept ember). EPA -821-R-14-003. EPA- HQ

- OW -2014-0170­

0077.

17. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan. Washington, D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN

08208.

18. UT DEQ. 2009. Utah Department of Environmental Quality. NPDES Permit for Kennecott Utah Copper LLC, Magna, UT (UT0000051). (November 12). EPA

HQ

- OW -2015-0665. DCN 08197.

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

3.10 Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

EPA identi fied the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Category for preliminary review because it ranks high again , in terms of toxic

- weighted pound equivalent s (TWPE), in the final 2015 combined point source category rankings. Previously, EPA reviewed discharges from this category as part of the 2004 through 2011, and 2013 Annual Reviews in which it also ranked high (U.S. EPA, 2004, 2005a, 2005b, 2006, 2007, 2008, 2009, 2011a, 2012, 2014). In addition, EPA conducted a preliminary study of carbon disulfide discharges from cellulose products manufacturers in 2011 (U.S. EPA, 2011b) and reviewed discharges from the chlorinated hydrocarbon manufacturing segment of the OCPSF Category as part of the Chlorine and Chlorinated Hydrocarbons (CCH) effluent guidelines rulemaking. 31

This section summarizes the results of the 2015 Annual Review. EPA focused its 2015

review on discharges of polycyclic aromatic compounds (PACs)

, total residual chorine, hexachlorobenzene, dioxin and dioxin-like compounds, carbon disulfide , and nitrate compounds

because of their high TWPE relative to the other pollutants discharged by facilities in the OCPSF Category. Total residual chlorine and hexachlorobenzene, reviewed as part of the 2013 Annual Review, continue to contribute large proportions of the total category TWPE. For the 2015 Annual Review, available discharge data also showed significant contributions of PACs, dioxin and dioxin-like compounds, carbon disulfide, and nitrate compounds.

3.10.1 OCPSF Category 2015 Toxicity Rankings Analysis

Table 3-79 compares the toxicity rankings analyse s (TRA) data for the OCPSF Category from the 2011, 2013, and 2015 Annual Reviews. EPA did not conduct the TRA in 2012 or 2014,

but instead reviewed additional data sources as part of the even

- year annual review, as described in Section 2.2.1 of EPA’s Preliminary 2016 Plan (U.S. EPA, 2016). As discussed in this section, during the 2015 Annual Review, EPA identified data corrections that affected the 2013

Di scharge Monitoring Report (DMR) and Toxic Release Inventory (TRI) data and TWPE. The

bottom row of Table 3- 79 shows the corrected data resulting from this review.

31 Based on the information collected during the rulemaking, EPA proposed to delist the CCH manufacturing industry and discontinue the rulemaking in 2012.

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

Tabl e 3-79. OCPSF Category TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

Year of Discharge Year of

Review OCPSF Category Facility Counts a OCPSF Category TWPE

Total TRI

Facilities Total DMR Major

Facilities Total DMR

Minor

Facilities TRI

TWPE b DMR TWPE c Total

TWPE

2009 2011 671 169 150 146,000 491,000 d 637,000 d

2011 2013 631 165 180 148,000 658,000 e 806,000 e

333,000 f 301,000 f 634,000 f

2013 2015 651 136 144 286,000 g 224,000 g 510,000 g

Sources: 201 3 Annual Review Report (for 2009 and 20 11 DMR and TRI data) (U.S. EPA, 2014) ; DMRLTOutput2013_v1 (for 2013 DMR); TRILTOutput2013_v1 (for 2013 TRI)

. Note: EPA did not evaluate 2010 or 2012 DMR and TRI dat a.
Note: TWPE values are rounded to three significant figures. Sums of individual values may not equal the total presented, due to rounding.

a Number of facilities with TWPE greater than zero.

b Releases include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for

POTW removals.

c Includes DMR data from both major and minor dischargers

. d 2009 DMR data after corrections were made during the 2011 Annual Review.

e 2011 DMR data after corrections were made during the 2013 Annual Review.

f 2013 DMR data prior to corrections made during the 2015 Annual Review.

g 2013 DMR data after corrections were made during the 2015 Annual Review.

As shown in Table 3-79 , the total TWPE increased from 2009 to 2011 then decreased from 2011 to 2013, mainly due to a decrease in DMR discharges. However, TRI releases

increased , driven by a substantial rise in repo rted releases of carbon disulfide ( discussed in Section 3.10.7, below). Additionally, the number of facilities reporting discharges on DMRs

decreased from 2009 to 2013.

3.10.2 OCPSF Category Pollutants of Concern

EPA’s 2015 review of the OCPSF Category focused on the 2013 DMR and TRI discharges because both contribute to the category’s combined TWPE. Table 3-80 shows the five pollutants with the highest contribution to the 2013 DMR TWPE. As a point of comparison,

Table 3-80 also shows the 2011 DMR facility count and TWPE for these top pollutants , based on the 2013 Annual Review (U.S. EPA, 2014 ). The top five pollutants contribute more than 60 percent of the original 2013 DMR TWPE for the OCPSF Category (prior to corrections discussed below)

. The OCPSF effluent limitations guidelines and standards (ELGs) currently regulate benzo[a]pyrene, hexachlorobenzene, and benzo[k]fluoranthene, but not total residual chlorine or 2,3,7,8- tetrachlorodibenzo -p-dioxin. EPA’s inves tigations of reported discharges of these pollutants are summarized in Sections 3.10.3 to 3.10.6.

Table 3-81 shows the five pollutants with the highest contribution to the 2013 TRI

TWPE. As a point of comparison, Table 3-81 also shows the 2011 TRI facility count and TWPE for these top pollutants, based on the 2013 Annual Review (U.S. EPA, 2014 ). Carbon disulfide, dioxin and dioxin-like compounds, PACs, and nitrate compounds contribute 77 percent of the

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

original 2013 TRI TWPE for the OCPSF Category (prior to corrections discussed below) . EPA’s investigations of reported discharges of these pollutants are summarized in Sections 3.10.3, and

3.10.6 through 3.10.8. EPA did not investigate hydroquinone as part of the 2015 Annual Review

because it represent s a small percentage (less than 4 percent ) of the 2013 TRI TWPE for the

OCPSF Category.

Table 3-80. OCPSF Category Top DMR Pollutants

Pollutant 2013 DMR Data a 2011 DMR Data a

Number of Facilities Reporting Pollutant c Original

TWPE Corrected

TWPE Number of Facilities Reporting Pollutant b TWPE

Benzo[a]pyrene 12 59,800 3,230 11 37,200

Total Residual Chlorine 97 49,200 49,200 110 59,500

Hexachlorobenzene 10 28,800 28,800 11 61,800

2,3,7,8

­ Tetrachlorodibenzo -pdioxin 2 25,200 25,200 1 1,000

Benzo[k]fluoranthene 9 18,200 971 10 10,200

Top Pollutant Total NA 181,000 107,000 NA 179,000

OCPSF Category Total 280 301,000 224,000 345 658,000

Sources: DMRLTOutput2013_v1 (for 2013 data); DMRLTOutput2011_v1 (for 2011 data)

. Note: Sums of individual values may not equal the total presented due to rounding. NA: Not applicable.

a Includes DMR data from both major and minor dischargers.

b Number of facilities with TWPE greater than zero.

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Table 3-81. OCPSF Category Top TRI Pollutants

Pollutant a 2013 TRI Data 2011 TRI Data

Number of Facilities Reporting

Pollutant b Original

TWPE Corrected

TWPE Number of Facilities Reporting

Pollutant b TWPE

Carbon Disulfide 10 157,000 157,000 8 5,310

Dioxin and D ioxin

- like

C ompounds 3 69,700 22,500 4 25,000

Polycyclic Aromatic Compounds 9 16,300 16,300 8 7,530

Nitrate Compounds 121 13,200 13,200 104 14,200

Hydroquinone 5 10,300 10,300 5 8

, 790

Top Pollutant Total NA 267,000 220 ,000 NA 60,800

OCPSF Category

Total 651 333,000 286,000 631 148,000

Sources: TRILTOutput2011 _v1; TRILTOutput2013_v1

. Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable.

a Hydroquinone releases contribute 3 .1 percent of the original 2013 category TRI TWPE. Therefore, EPA did not review hydroquinone releases as part of the 2015 Annual Review.

b Number of facilities with TWPE greater than zero.

3.10.3 OCPSF Category PACs Discharges in DMR and TRI

EPA re viewed 2013 DMR and TRI PACs discharges from OCPSF facilities for the 2015

Annual Review. EPA’s investigation of the 2013 DMR PACs data revealed that two facilities, Honeywell International, Inc. (Honeywell), in Hopewell, VA, and E. I. DuPont de Nemours in Washington, WV, account for 94 percent of the 2013 DMR PACs discharges, which con sist of benzo[a]pyrene and benzo[k]fluoranthene 32 discharges (shown in Table 3- 82 ). EPA did not investigate the remaining facilities discharging benzo[a]pyrene, benz o[k]fluoranthene or other PACs as part of the 2015 Annual Review.

32 Benzo[a]pyrene and benzo[k]fluoranthene are PACs. Facilities submit DMR data for individual PACs. In TRI, facilities report PACs as a chemical category.

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Table 3-82. Top 2013 DMR PACs Discharging Facilities

Facility Name Facility

Location Benzo[a]pyrene Benzo[k]fluoranthene

Pounds Discharged TWPE Percent of Category

TWPE Pounds Discharged TWPE Percent of Category

TWPE

Honeywell International

, Inc. Hopewell Plant Hopewell,

VA 322 32,400 54% 322 9,870 54%

E

. I

. DuPont de Nemours

- Washington Works Washington,

WV 240 24,200 40% 240 7,360 40%

All ot her pollutant dischargers in the OCPSF Category a 32.1 3,230 6% 31.7 971 6%

Total 594 59,800 100% 594 18,200 100%

Source: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a Ten additional f acilities submitted b enzo[a]pyrene discharges in the 2013 DMR data. Seven additional facilities submitted benzo[k]fluoranthene discharges in the 2013 DMR data.

EPA’s investigation of the 2013 TRI PACs releases revealed that two facilities, Sas ol

North America Inc

. Lake Charles Chemical Complex (Sasol), in Westlake, LA and ExxonMobil

Chemical Co . Baytown Olefins Plant (ExxonMobil), in Baytown, TX, account for 96 percent of

the 2013 TRI PACs releases (as shown in Table 3-83 below). EPA did not investigate the remaining facilities releasing PACs as part of the 2015 Annual Review.

Table 3-83. Top Facilities Reporting 2013 TRI PACs Releases

Facility Name Facility

Location Pounds of

Pollutant

Released Pollutant

TWPE Percent of Category TWPE

Sasol N orth America, Inc. Lake Charles Chemical Complex Westlake, LA 123 12,300 76%

ExxonMobil Chemical C o. Baytown

Olefins Plant Baytown, TX 33 3,320 20%

All other PACs releases in the OCPSF Category a 6.54 658 4%

Total 162 16,300 100%

Source: TRILTOutput2013_v1

. Note: Sums of individual values may not equal the total presented, due to rounding.

a Seven additional facilities reported PACs releases in the 2013 TRI

.

Honeywell International Inc. Hopewell Plant

The Honeywell International Hopewell, VA plant discharges benzo[a]pyrene and benzo[k]fluoranthene from outfall 101, which discharges contact cooling water from two barometric condensers (VA DEQ, 2008). After EPA downloaded the 2013 DMR data from the DMR Loading Tool for the 2015 Annual Review, the facility subsequently updated their DMR data to add a below-detection-limit code to their reports of benzo[a]pyrene and benzo[k]fluoranthene, indicating that loads for these pollutants should be zero. Therefore, EPA zeroed the benzo[a]pyrene and benzo[k]fluoranthene discharges for the facility, which decreased

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

the OCPSF benzo[a]pyrene TWPE from 59,800 to 27,400, and benzo[k]fluoranthene TWPE from 18,200 to 8,330. These corrections are reflected in Table 3-80.

E. I. DuPont de Nemours - Washington Works

E. I. DuPont de Nemours – Washing ton Works, in Washington, WV, discharges benzo[a]pyrene and benzo[k]fluoranthene from outfalls 002, 005, and 105. As part of the 2015 Annual Review, EPA verified the 2013 DMR data with the West Virginia Department of Environmental Protection (WV DEP). The facility’s DMRs (from WV DEP) indicated that all benzo[a]pyrene and benzo[k]fluoranthene discharges were below the detection limit in 2013. Therefore, EPA zeroed the facility’s benzo[a]pyrene and benzo[k]fluoranthene discharges, further decreasing the OCPSF benzo[a]pyrene TWPE to 3,230 and the benzo[k]fluoranthene

TWPE to 971. These corrections are reflected in Table 3-80.

Sasol N orth A merica Inc. Lake Charles Chemica l Complex

Sasol is an organic chemical manufacturing plant in Westlake, LA. EPA previously reviewed this facility as part of the 2011 and 2013 Annual Reviews. Sasol discharges process wastewater, stormwater, sanitary wastewater, and miscellaneous utility w astewaters through eight outfalls. The facility’s 2009 NPDES permit includes limits for 5 PACs compounds 33 (LA DEQ, 2009a). Because Sasol plans to approximately triple the company’s chemical production capacity from 2015 to 2018 (Sasol, 2015), a revised permit was issued for the facility in 2014. The revised permit includes four phases of pollutant limits, including PACs, as construction progresses at the site. 34 The pollutant limits are more stringent for each phase of construction, requiring the facil ity to meet the most stringent limits in 2018, when expansion is scheduled to be completed (LA DEQ, 2014).

As part of the 2015 Annual Review, EPA contacted the facility. The contact stated that Sasol’s TRI PACs releases are based on the samples taken for their NPDES permit and that increases in the load released are due to an increase in flow from increased pro duction and rainfall (Shaw, 2014). EPA reviewed 2013 DMR PACs discharges for Sasol, shown in Table 3­ 84, and determined that all discharges are below the 2009 permit limits. Even though the facility plans to increase production capacity in future years, the facility’s PACs discharges may decrease due to the more stringent limits included in the facility’s r evised permit.

Table 3-84. Sasol’s 2013 DMR PACs Discharges

PACs Outfall Date Flow (MGD) Reported Quantity (kg/day) Calculated Quantity (lb/day) 2009 NPDES Monthly Average Permit Limit (lb/day) Benzo(a)anthracene 001 31

- Mar

- 13 2.11 0 0 0.164

001 30

- Jun

- 13 2.77 0.041 0.090 0.164

001 30

- Sep

- 13 2.57 0 0 0.164

001 31

- Dec

- 13 2.34 0 0 0.164 Benzo(a)pyrene 001 31

- Mar

- 13 2.11 0 0 0.164

001 30

- Jun

- 13 2.77 0.041 0.090 0.164

33 Benzo(a)anthracene, benzo(a)pyrene, benzo(k)fluoranthene, benzo(b)fluoranthene, and dibenzo(a,h)anthr acene.

34 The monthly average permit limits during the four phases of construction for benzo(a)anthracene and benzo(a)pyrene are each: phase 1

– 0.164 lb/day, phase 2

– 0.0578 lb/day, phase 3

– 0.0289 lb/day, phase 4

– 0.0211 lb/day (LA DEQ, 2014).

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Table 3-84. Sasol’s 2013 DMR PACs Discharges

PACs Outfall Date Flow (MGD) Reported Quantity (kg/day) Calculated Quantity (lb/day) 2009 NPDES Monthly Average Permit Limit (lb/day)

001 30

- Sep

- 13 2.57 0 0 0.164

001 31

- Dec

- 13 2.34 0 0 0.164

Source: DMRLTOutput2013_v1 , LA DEQ, 2009 a

.

ExxonMobil Chemical Co. Baytown Olefins Plant

EPA has not reviewed TRI PACs releases from ExxonMobil in Baytown, TX, as part of recent annual reviews. As part of the 2015 Annual Review, EPA contacted the facility to discuss PACs releases. The facility contact confirmed the reported 2013 TRI PACs releases and stated

that the releases were calculated based on a measured flow from their stormwater outfall multiplied by half the detection limit of three PACs 35 that may be present in the wastewater. The facility contact stated that the PACs releases were calculated to provide a conservative estimate; however, the facility reevaluated this approach and determined that there was no reason to conclude PACs are released at this outfall, because the site’s stormwater has no contact with process areas. Beginning with the 2014 reporting year, the facility plans to report zero PACs wastewater releases to TRI (Brewer, 2015).

Table 3-85 presents the TRI PACs releases from 2009 through 2013. The facility contact confirmed the variation in PACs releases from 2009 through 2013 was due to variation in flo w. The facility’s NPDES permit does not require monitoring of PACs; therefore, the facility does not submit PAC discharges on their DMRs (Brewer, 2015). Based on the information provided by the facility contact, EPA expects a decrease in PACs releases repo rted to TRI from this facility.

Table 3-85 . ExxonMobil’s PACs TRI Releases , 2009 – 2013

Year Pounds of PAC Released PACs TWPE

2009 50 5,000

2010 56 5,640

2011 19 1,910

2012 54 5,440

2013 33 3,320

Source: DMRLTOutput2013_v1; DMR Loading Tool.

3.10.4 OCPSF Category Total Residual Chlorine Discharges in DMR

Ninety

- seven facilities submitted DMRs with total residual chlorine discharges in 2013. EPA previously reviewed total residual chlorine discharges fr om OCPSF facilities as part of the 2010 and 2013 Annual Reviews. As part of the 2010 review, EPA determined that a flow measurement error from one facility resulted in an elevated TWPE; as part of the 2013 review, EPA determined that discharges from the to p facility were from an internal outfall, not an external outfall. For these reasons, as part of the 2010 and 2013 Annual Reviews, EPA determined that further review of total residual chlorine discharges was not warranted. Total

35 Benzo(a)anthracene, benzo(a)pyrene, and chrysene.

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

residual c hlorine is not re gulated under the OCPSF ELGs. As shown in Table 3-80 , t he DMR discharges of total residual chlorine decreased by over 10,000 TWPE (over 17 percent) from 2011 to 2013, and the number of facilities with discharges also decreased

.

EPA’s investigation of the total residual chlorine discharges revealed that four facilities, Equistar Chemicals, in Channelview, TX; Bayer MaterialScience, in New Martinsville, WV ; INEOS USA Green Lake Plant, in Port Lavaca, TX ; and Goodyear Tire and Rubber Co., in
Beaumont, TX ; account for over 60 percent of the 2013 DMR total residual chlorine discharges (as shown in Table 3-86 , below). EPA reviewed the DMR data submitted by these four facilities and did not identify any outliers or potential errors. All facilities met permit requirements in 2013: Bayer MaterialScience has monitoring requirements, while the other three facilities met minimum total residual chlorine permit limits.

EPA did not conduct a facility- level review of the remaining 93 facilities discharging total residual chlorine as part of the 2015 Annual Review, as none of the remaining 93 individual facilities accounted for more than 5,000 TWPE ; however, a large number of facilities reported total residual chlorine discharges on DMR s in 2013 and the data suggest that three of the top four

facilities have minimum total residual ch lor ine limits in their permits.

Table 3-86. Top 2013 DMR Total Residual Chlorine Discharging Facilities

Facility Name Facility Location Pounds of

Pollutant Discharged Pollutant

TWPE P ercent of Category TWPE

Equistar Chemicals Channelview, TX 18,900 9,440 19%

Bayer MaterialScience New Martinsville, WV 18,000 9,000 18%

INEOS USA Green Lake Plant Port Lavaca, TX 12,200 6,110 12%

Goodyear Tire & Rubber Co. Beaumont, TX 10,300 5,160 11%

All other total residual chlorine dischargers in the OCPSF Category a 39,000 19,500 40%

Total 98,400 49,200 100%

Source: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a 93 additional facilities submitted total residual chlorine discharges in the 2013 DMR data.

3.10.5 OCPSF Category Hexachlorobenzene Discharges in DMR

EPA’s investigation of the hexachlorobenzene discharges revealed that two facilities, Sasol, in Westlake, LA, and Nalco Company, in Garyville, LA, account for 93 percent of the 2013 TRI hexachlorobenzene discharges (as shown in Table 3-87 below). EPA did not investigate the remaining facilities discharging hexa chlorobenzene as part of the 2015 Annual

Review.

3-963— EPA’s 2015 Preliminary Category Reviews

3.10

— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

Table 3-87. Top 2013 DMR Hexachlorobenzene Discharging Facilities

Facility Name Facility

Location Pounds of

Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

Sasol NA

, Inc.

, Lake Charles Chemical Complex Westlake, LA 8.28 16,100 56%

Nalco Company Garyville, LA 5.48 10,700 37%

All other hexachlorobenzene dischargers in the OCPSF Category a 1.04 2,020 7%

Total 14.8 28,800 100%

Source: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a Eight additional facilities submitted hexachlorobenzene discharges in the 2013 DMR data.

Sasol N orth America, Inc. Lake Charles Chemical Complex

As discussed in Section 3.10.3, Sasol is an organic chemical manufacturing plant in Westlake, LA. Sasol discharges hexachlorobenzene from outfall 001, which is a continuous discharge of process wastewater, process area stormwater, and miscellaneous utility

wastewaters. 36 The facility’s 2009 NPDES permit includes limits for hexachlorobenzene of

0.005 lb/day monthly average and 0.012 lb/day daily maximum for outfall 001 (LA DEQ, 2009a). EPA reviewed 2013 DMR hexachlorobenzene discharges for Sasol (shown in Table 3­ 88) and determined that the June 2013 hexachlorobenzene discharge from outfall 001 is above the 2009 hexachlorobenzene permit limit for outfall 001. However, as shown in Table 3-89, Sasol’s DMR hexachlorobenzene discharges from 2010 through 2014 have decreased. Additionally, Sasol’s revised 2014 permit includes four phases of hexachlorobenzene limits, which are increasingly more stringent as construction progresses at the site through 2018 37 (LA DEQ, 2014). Even though the facility plans to increase production capacity in future years, the facility’s hexachlorobenzene discharges may decrease due to the more stringent limits included in the facility’s revised permit.

Table 3-88. Sasol’s 2013 DMR Hexachlorobenzene Discharges

Outfall Date Flow (MGD) Reported Quantity (kg/day) Calculated Quantity (lb/day) 2009 NPDES Monthly Average Permit Limit (lb/day)

001 31

- Mar

- 13 2.11 0 0 0.005

001 30

- Jun

- 13 2.77 0.041 0.09 0.005

36 Process wastewater, process area stormwater, and miscellaneous utility wastewaters are from the Normal Paraffin Unit, Ethoxylate Unit, Alcohol Unit, Alumina Unit, Linear Alkyl Benzene Unit, Ethylene Unit, Steam Plant, Georgia Gulf Lake Charles Vinyl Chloride Monomer Plant, and Activated Sludge Unit. Other wastewaters discharged through outfall 001 include sanitary wastewater, groundwater, holding ponds/basins stormwater, zeolite regeneration wastewater, bo iler blowdown, sulfide caustic, lime settler wastewater, caustic wash quench settler blowdown, benzene contaminated water and steam condensate, and alcohol quench wastewater (LA DEQ, 2009a).

37 The monthly average permit limits during the four phases of con struction for hexachlorobenzene are: phase 1

– 0.0049 lb/day, phase 2

– 0.0017 lb/day, phase 3

– 0.0009 lb/day, phase 4

– 0.00006 lb/day. The daily maximum permit limits during the four phases of construction for hexachlorobenzene: phase 1

– 0.012 lb/day, phase 2

– 0.0041 lb/day, phase 3

– 0.0021 lb/day, phase 4

– 0.0015 lb/day (LA DEQ, 2014).

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

Table 3-88. Sasol’s 2013 DMR Hexachlorobenzene Discharges

Outfall Date Flow (MGD) Reported Quantity (kg/day) Calculated Quantity (lb/day) 2009 NPDES Monthly Average Permit Limit (lb/day)

001 30

- Sep

- 13 2.57 0 0 0.005

001 31

- Dec

- 13 2.34 0 0 0.005

Source: DMRLTOutput2013_v1 , LA DEQ, 2009 a

.

Table 3-89 . Sasol’s Hexachlorobenzene DMR Discharges, 2010 – 2014

Year Pounds of Hexachlorobenzene Discharged Hexachlorobenzene TWPE

2010 28.3 55,200

2011 20.4 39,900

2012 25.8 50,400

2013 8.28 16,100

2014 8.27 16,100

Source: DMRLTOutput2013_v1; DMR Loading Tool.

Nalco Co mpany

Nalco Company discharges hexachlorobenzene from outfall 001. The outfall has a continuous discharge of treated process wastewater 38 (LA DEQ, 2009b). EPA previously reviewed hexachlorobenzene discharges from this facility as part of the 2011 Annual Review and determined that the reported daily maximum and monthly average concentrations do not exceed the hexachlorobenzene limits in the facility’s permit (U.S. EPA, 2012). The facility’s permit requires that the quantity of hexachlorobenzene discharged be reported annually (LA DEQ, 2009b). Table 3-90 presents Nalco’s 2013 DMR hexachlorobenzene discharges and associated permit limits. As shown, the reported daily maximum and monthly average quantities do not

exceed the hexachlorobenzene limits in the facility’s permit.

Table 3-90. 2013 DMR Hexachlorobenzene Discharges for Nalco Company

2013 DMR Data Permit Limits Flow (MGD) Quantity (kg/day) Pounds (lb/day) Calculated Quantity (kg/day) Daily Maximum 0.41 0.0068 0.1 0.0454 Monthly Average 0.41 0.0068 0.05 0.0227
Source: LADEQ, 2009 b

, DMRLTOutput2013_v1.

3.10.6 OCPSF Category Dioxin Discharges in DMR and TRI

EPA reviewed 2013 DMR and TRI data on dioxin and dioxin-like compounds from OCPSF facilities for the 2015 Annual Review. EPA’s investigation of the 2013 DMR dioxin data

revealed that one facility , A.K.A. Solutia Nitro Site (Solutia), in Nitro, WV, accounts for over 99

38 Treated process wastewater results from the following areas: acrylamide manufacturing, emulsion polymerization, general purpose reactors and blenders, Kathon TM /glutar aldehyde blends, storage and cleaning, Evonik polymer, and the lab. Process area stormwater, utility wastewaters from cooling tower blowdown, boiler blowdown, and water demineralizer, coagulants and cleaners wastewater, and treated sanitary wastewater are also discharged through outfall 001 (LA DEQ, 2009b).

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

percent of the 2013 DMR 2,3,7,8-tetrachlorodibenzo-p-dioxin (T CDD ) 39 discharges (as shown in

Table 3-91 ).

Table 3-91. Top 2013 DMR TCDD Discharging Facilities

Facility Name Facility

Location Pounds of Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

A.K.A. Solutia Nitro Site Nitro, WV 0.0000359 25,200 99.9%

The Dow Chemical Company Midland, MI 3.50 x 10
- 9 2.46 0.01%

Total 0.0000359 25,200 100%

Source: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

EPA’s investigation of the 2013 TRI dioxin and dioxin- like compounds releases revealed that two facilities, Sasol, in Westlake, LA, and Dow Chemical, in Midland, MI, account for 93 percent of the 2013 TRI dioxin and dioxin- like compound releases (as shown in Table 3-92 below). EPA did not investigate the remaining facility, Shell Chemical, in Deer Park, TX, releasing dioxin and dioxin- like compounds as part of the 2015 Annual Review.

Table 3-92. Top Facilities Reporting 2013 TRI Dioxin and Dioxin- like Compound Releases

Facility Name Facility

Location Pounds of

Pollutant

Released Pollutant

TWPE Percent of Category TWPE

Sasol NA

, Inc. Lake Charles Chemical Complex Westlake, LA 0.00107 53,700 77%

The Dow Chemical Co mpany Midland, MI 0.00408 11,100 16%

Shell Chemical Deer Park, TX 0.00170 4,870 7%

Total 0.00685 69,700 100%

Source: TRILTOutput2013_v1

. Note: Sums of individual values may not equal the total presented, due to rounding.

A.K.A. Solutia Nitro Site

Solutia’s Nitro Site is an active remedial construction site. The TCDD discharges at the site are a result of byproducts crea ted by the production of the herbicide 2, 4, 5­ trichlorophenoxyacetic acid at the site from 1948 to 1969. As part of the 2015 Annual Review,

EPA contacted Solutia about the facility’s TCDD discharges

. The facility contact stated that they are implementing remediation activities under a RCRA corrective action permit, which includes capping and covering areas with TCDD-affected soils, and pumping and treating groundwater from the affected area on site. Remediation activities were scheduled to be completed in summer 2015 (House, 2014). The facility’s DMR TCDD TWPE decreased from 25,200 in 2013 to 4,950 in 2014. The facility contact stated that TCDD discharges are expected to cease with the completion of the remediation activities (House, 2014). Because the faci lity is implementing

39 TCDD is a dioxin compound. Facilities can submit DMR data for individual dioxin compounds. In TRI, facilities report dioxin compounds as the group of dioxin and dioxin

- like compounds.

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

remediation activities, EPA expects the TCDD discharges to continue to decrease on future

DMRs.

The Dow Chemical Co mpany

Dow Chemical in Midland, MI, is a large chemical manufacturing facility and discharges dioxin and dioxin-like compounds from outfall 031. The facility is a top TRI discharger of dioxin and dioxin-like compounds in the OCPSF Category (as shown in Table 3-92).

EPA previously reviewed TRI dioxin and dioxin-like compound discharges from Dow Chemical as part of the 2009 Annual Review and determined that such discharges mos tly resulted from historical processes. As part of the 2015 Annual Review, EPA contacted the facility to discuss its dioxin and dioxin-like compound discharges. The facility contact confirmed

the 2013 TRI dioxin and dioxin- like compound discharges and stat ed that they were calculated

from measured concentrations from bi- weekly wastewater composite samples using EPA Method 1613B (non- detect concentrations were treated as zero). The facility contact indicated that discharges are from historical processes and waste management units that are no longer in operation at the site (Kennett, 2015). Although TRI releases are based on sampling data, they are significantly higher than discharges submitted on the facility’s DMRs. Table 3-93 presents TRI dioxin and dioxin-like compound discharges for Dow Chemical from 2008 through 2013. As shown, discharges ranged from 6,740 to 13,200 TWPE over those 6 years.

Table 3-93. Dow Chemical Company TRI Dioxin and Dioxin- like Compound Releases,

2008 – 2013

Year Dioxin and Dioxin

- like Compound TWPE

2008 11,300

2009 6,740

2010 13,200

2011 9,500

2012 8,890

2013 11,100

Source: TRILTOutput2013_ v1, DMR Loading Tool.

Sasol N orth America Inc. Lake Charles Chemical Complex

EPA has previously reviewed TRI dioxin and dioxin-like compound releases from Sasol as part of the 2011 and 2013 Annual Reviews. As part of these reviews, the fac ility contact stated that the dioxin and dioxin-like compound distribution is based on an average of 12 different samples at the facility, and all non

- detect results are equal to one half of the method detection

limit. EPA revised the 2009 and 2011 dioxin loads based on the dioxin and dioxin- like compound distribution provided by the facility by zeroing the non-detect results (U.S. EPA, 2012 and 2014). As part of the 2015 Annual Review, the facility contact confirmed that the method of determining the TRI d ioxin and dioxin-like compound release at the facility had not changed (Shaw, 2014). Therefore, EPA corrected the 2013 dioxin load similar to previous years by zeroing the non

- detect results. Table 3-94 presents original and corrected pounds of dioxin and dioxin-like compound releases from 2009 through 2013. Incorporating this correction decreases the TRI dioxin and dioxin-like compound TWPE for the OCPSF category from 69,700 to 22,500, as shown in Table 3-81.

3-1003— EPA’s 2015 Preliminary Category Reviews

3.10

— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

Table 3-94. Sasol’s Dioxin and Dioxin- like Compo und TRI Releases, 2009 – 2013

Year Original Pounds Discharged Corrected Pounds Discharged

2009 0.000890 0.0006

2010 0.000898 0.000898 a

2011 0.000912 0.0006

2012 0.000943 0.00094 3 a

2013 0.00107 0.0007

Source: DMR Loading Tool; U.S. EPA, 2012, U.S. EPA 2014

a EPA did not review 2010 or 2012 dioxin and dioxin

- like compound discharges for this facility ; therefore, discharges were not corrected

.

3.10.7 OCPSF Category Carbon Disulfide Releases in TRI

EPA’s investigation of carbon disulfide releases revealed that three facilities, Viskase Corp ., in Loudon, TN, Innovia Films, Inc., in Tecumseh, KS, and Viscofan USA , Inc., in Danville, IL, account for 97 percent of the 2013 TRI carbon disulfide releases ( as shown in Table

3-95 ) . EPA did not investigate the remaining facilities releasing carbon disulfide as part of the

2015 Annual Review.

Table 3-95. Top Facilities Reporting 2013 TRI Carbon Disulfide Releases

Facility Name Facility

Location Pounds of

Pollutant

Released Pollutant

TWPE Percent of Category TWPE

Viskase Corp oration Loudon, TN 35,400 99,000 63%

Innovia Films

, Inc

. Tecumseh, KS 10,500 29,300 19%

Viscofan USA

, Inc. Danville, IL 8,800 24,600 16%

All other carbon disulfide releases in the OCPSF Category a 1,550 4,340 3%

Total 56,200 157,000 100%

Source: TRILTOutput2013_v1

. Note: Sums of individual values may not equal the total presented, due to rounding.

a Seven additional facilities reported carbon disulfide releases in the 2013 TRI

.

Viskase Corporation

The Viskase Corporation in Loudon, TN, is a food casings manufacturer, one of two facilities operated by Viskase Corporation, the world’s largest producer of small -sized food casings (U.S. EPA, 2011b). Viskase Corporation’s reported indirect releases of carbon disulfide account for 63 percent of the 2013 TRI OCPSF carbon disulfide TWPE. As shown in Table 3-96 below, releases reported in 2012 and 2013 are substantially g reater than releases reported from 2008 through 2011.

EPA reviewed 2006 through 2009 indirect releases from Viskase Corporation in 2011 as part of its Preliminary Study of Carbon Disulfide Discharges from Cellulose Products Manufacturers (U.S. EPA, 2011b). Specifically, EPA contacted Viskase Corporation and the local pretreatment coordinator to confirm the carbon disulfide releases. At the time, EPA determined that the majority of the carbon disulfide concentrations measured at the POTW influent did not exceed the industrial user permit limit for carbon disulfide of 5 mg/L. More

3-1013— EPA’s 2015 Preliminary Category Reviews

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

importantly, the concentrations reviewed were prior to treatment through the receiving POTW. EPA determined that the carbon disulfide concentrations in the POTW effluent following treatment are likely below levels of detection, and are likely no concern to human health and aquatic life. See Section 5.2 of EPA’s P reliminary Study of Carbon D ischarge D ischarges from

C ellulose Products Manufacturers for more information (U.S. EPA, 2011b).

Similar to its 2007 through 2011 releases, the facility reported that the 2012 and 2013 releases are based on periodic or random monitoring data or measurements. As part of the 2015 Annual Review, EPA made several attempts to contact Viskase Corporation to confirm the findings from its 2011 preliminary study and understand why the carbon disulfide releases increased by an order of magnitude from 2011 to 2012, and then nearly doubled in 2013, but the facility did not respond to the requests (Yoder, 2014). Based on conclusions from the 2011 preliminary study, EPA determined that the carbon disulfide discharges volatilize and likely do not pass through to the POTW effluent.

Table 3-96. Viskase Corporation Carbon Disulfide TRI Indirect Releases, 2007 – 2013

Year Total Indirect Pounds Total Indirect TWPE

2007 428 1,200

2008 1,920 5,380

2009 2,080 5,8 20

2010 2,080 5,8 20

2011 1,920 5,3 80

2012 19, 000 53,3 00

2013 35, 400 99,00 0

Source: TRILTOutput2013_v1; DMR Loading Tool.

Innovia Films

, Inc.

Innovia Films, Inc., in Tecumseh, KS, manufactures cellophane u sed primarily in food packaging. Innovia reported direct releases of carbon disulfide accounting for 19 percent of the

2013 TRI OCPSF carbon disulfide TWPE. Reported TRI releases from the facility peaked in 2009, decreased in 2010, and were relatively consistent between 2010 and 2013 (as shown in

Table 3-97). The facility reported that 2007 through 2013 TRI release estimates are based on periodic or random monitoring data or measurements. The facility also has a NPDES permit ( KS0003204) and reports carbon disulfide releases on DMRs. Table 3-97 shows a comparison of the TRI and DMR discharge data for 2007 through 2013. As shown in the table, TRI releases have remained fairly consistent from 2010 through 2013, while DMR discharges have significantly decreased. Therefore, EPA is unsure of the representativeness of the facility’s carbon disulfide releases reported to TRI.

EPA reviewed the facility’s NPDES permit as part of the Preliminary Study of Carbon Disulfide Dis charges from Cellulose Products Manufacturers (U.S. EPA, 2011b). From this review, EPA determined that the facility recovers volatilized carbon disulfide, a valuable feedstock, using steam. Some carbon disulfide is captured in the steam condensate and is transferred to the wastewater treatment system. At this facility , the sampling point is more than one mile away from the wastewater treatment system ’s final discharge point. As a result, during the study EPA determined that the concentration of carbon disulfide entering the surface water is likely lower than sampled because of this distance and volatilization (U.S. EPA, 2011b). The

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

TRI releases have declined slightly since the 2011 preliminary study, while the DMR discharges have decreased substantially since the 2011 preliminary study, and the actual concentration of

carbon disulfide entering the surface water is likely lower than measured by sampling (because

of the distance between sampling and outfall, and volatilization).

Table 3-97. Innovia Films Inc. Carbon Disulfide DMR and TRI Releases, 2007 – 2013

Year Total TRI Pounds DMR Pounds

2007 5,44 0 No data a vailable

2008 19, 900 12,9 00

2009 26, 500 28, 200

2010 10, 500 10,2 00

2011 1 4,000 7,1 30

2012 11,0 00 2,3 80

2013 10, 500 973

Source: TRILTOutput2013_v1; DMRLTOutput2013_v1; DMR Loading Tool.

Viscofan USA

, Inc.

Viscofan USA, Inc., in Danville, IL, manufactures food casings. The facility reported

indirect releases of carbon disulfide accounting for 16 percent of the 2013 TRI OCPSF carbon

disulfide TWPE. Table 3-98 presents the facility’s carbon disulfide TRI releases from 2007 through 2013. The fac ility reported that their TRI release estimates are based on periodic or random monitoring data or measurements, but has not responded to EPA’s requests for confirmation and details (Webster, 2014). The facility has an active NPDES permit, but does not

mon itor for carbon disulfide. T he reported releases of carbon disulfide from Viscofan USA are to

POTWs. Similar to the findings discussed for Viskase above, EPA determined that the carbon disulfide discharges volatilize and likely do not pass through to the P OTW effluent

.

Table 3-98 . Viscofan USA, Inc. Carbon Disulfide TRI Indirect Releases, 2007 – 2013

Year Total Indirect Pounds Total Indirect TWPE

2007 1

, 600 4

, 480

2008 3

, 840 10 ,800

2009 2

, 240 6

, 27 0

2010 9

, 280 26,000

2011 7

, 8 80 22 ,100

2012 9

, 920 27 ,800

2013 8

, 800 24

, 6 00

Source: TRILTOutput2013_v1; DMR Loading Tool.

3.10.8 OCPSF Category Nitrate Compounds Releases in TRI

EPA’s investigation of the nitrate compounds releases revealed that two facilities, DSM Chemicals NA, Inc., in Augusta, GA, and DuPont Chambers Works, in Deepwater, NJ, together account for 38 percent of the 2013 TRI nitrate compounds releases (as shown in Tab le 3-99 below). EPA did not conduct facility- level reviews for any of the remaining 119 facilities releasing nitrate compounds in TRI as part of the 2015 Annual Review because none of them contributes more than 1,000 TWPE to the total nitrate TRI TWPE for the OCPSF Category.

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

Table 3-99. Top Facilities Reporting 2013 TRI Nitrate Compound Releases

Facility Name Facility

Location Pounds of

Pollutant

Released Pollutant

TWPE Percent of Category TWPE

DSM Chemicals NA, Inc. August a , GA 4,390,000 3,280 25%

DuPont Chambers Works Deepwater, N J 2,320,000 1,730 13%

All other nitrate compound releases in the OCPSF Category a 11,000,000 8,220 62%

Total 17,700,000 13,200 100%

Source: TRILTOutput2013_v1

. Note: Sums of individual values may not equal the total presented, due to rounding.

a 119 additional facilities reported nitrate compound releases in the 2013 TRI

.

DSM Chemicals NA, Inc.

DSM Chemicals NA, Inc. produces caprolactum, a monomer used to make nylon fibers. As part of the 2015 Annual Review, EPA contacted DSM Chemicals NA about its 2013 TRI nitrate compounds releases (Connell, 2015)

. Most of the nitrate releases are generated a t the facility’s on

- site wastewater treatment plant. Oxidation of organic raw materials during production of caprolactum forms ammonia and nitrites. These nitrogen compounds are then oxidized to nitrate compounds by nitrification in the wastewater treatmen t plant.

The facility estimated the TRI releases based on monitoring data. The facility samples wastewater three times a week from the wastewater treatment plant effluent and calculates a monthly average nitrate concentration. The facility multiplies the monthly nitrate average concentration by the average monthly flow to determine the annual pounds of nitrate compounds released (Connell, 2015). As shown in Table 3- 100 , the facility’s nitrate compound TRI releases have been fairly similar from 2010 through 2013.

Table 3-100. DSM Chemicals NA, Inc. Nitrate Compound TRI Releases, 2010 – 2013

Year Pounds of Nitrate Compounds

Released Nitrate TWPE

2010 4,510,000 3,370

2011 5,220,000 3,900

2012 4,080,000 3,050

2013 4,390,000 3,280

Source: TRILTOutput2013_v1; DMR Loading Tool.

DuPont Chambers Works

DuPont Chambers Works manufactures hundreds of intermediate products for automotive, consumer, and agricultural uses at five diffe rent units at its Deepwater, NJ site (Young, 2014), and releases nitrate compounds directly to surface waters. As part of the 2015 Annual Review, EPA contacted DuPont Chambers Works about its 2013 TRI nitrate compounds

releases (Northey, 2015). The facility estimated nitrate releases based on mass balance calculations. The facility samples the final effluent for nitrate compounds weekly, using EPA method 300.0. The facility subtracts the source water nitrate concentration from the effluent

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

concentration to get the net concentration contributed by its industrial activity. Nitrate was detected in all 2013 samples (Northey, 2015).

As shown in Table 3-101, the facility’s nitrate compounds releases in 2012 and 2013 are about half of the levels reported in 2007 through 2011. According to the facility contact, the decrease in releases was due to process changes on site, resulting in decreased nitrogen loading to the facility’s wastewater treatment plant (Northey, 2015).

Table 3-101 . DuPont Chambers Works Nitrate Compounds TRI Releases, 2010 – 2013

Year Pounds of Nitrate Compounds

Released Nitrate TWPE

2007 4,110,000 3,070

2008 5,310,000 3,970

2009 3,210,000 6,430

2010 4,400,000 3,290

2011 4,260,000 3,180

2012 2,460,000 1,840

2013 2, 320,000 1,730

Source: TRILTOutput2013_v1; DMR Loading Tool.

The individual facility TWPE associated with nitrate discharges across the OCPSF Category appears to be relatively low (less than 3,300); however, a large number of facilities reported nitrate compound release to TRI in 2013.

3.10.9 OCPSF Category Finding s

The estimated toxicity of the OCPSF Category discharges resulted primarily from PACs, total residual chlorine, hexachlorobenzene, and dioxin discharges reported on DMRs, and PACs,

dioxin and dioxin- like compound, carbon disulfide, and nitrate compound releases reported to TRI. From the 2015 Annual Review, EPA found:

• PACs

. Two facilities, Honeywell, in Hopewell, VA, and E. I. DuPont de Nemours, in Washington, WV, account for 94 percent of the 2013 DMR benzo[a]pyrene and benzo[k]fluoranthene discharges. Additionally, two facilities, Sasol, in Westlake, LA, and ExxonMobil, in Baytown, TX, account for 96 percent of the 2013 TRI PACs releases. The results of EPA’s review of PACs discharges were:

− EPA confirmed that the DMR benzo[a]pyrene and benzo[k]fluoranthene discharges for Honeywell and E. I. DuPont de Nemours were below detection and should be corrected to zero. Incorporating this correction decreases the OCPSF benzo[a]pyrene TWPE from 59,800 to 3,230, and the benzo[k]fluoranthene TWPE from 18,200 to 971.

− Sasol, in Westlake, LA, is a top facility for 2013 TRI PACs releases. The facility has a NPDES permit, which sets limits for the discharge of five PACs. The TRI data were based on monitoring data for the facility’s NPDE S permit. The facility is currently meeting its PACs permit limits. In addition, the facility plans to expand from 2015 through 2018, and their revised 2014 NPDES permit has four

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

phases of increasingly stringent pollutant limits that the facility must meet as construction progresses.

− A facility contact at ExxonMobil, in Baytown, TX, confirmed the ir 2013 TRI PACs release and stated that the facility based its calculations on conservative

estimat es of PACs concentrations and that it is not likely that PACs a re actually present. As a result, the facility plans to report zero PACs wastewater releases to TRI in future years. Based on the information provided by the facility contact, EPA expects a decrease in PACs releases reported to TRI from this facility.

− For the reasons identified above, EPA has determined that PACs releases for the OCPSF Category do not represent a hazard priority at this time.

• Total Residual Chlorine

. Total residual chlorine is not a regulated pollutant under the OCPSF ELGs. Ninety -seven fa cilities submitted DMRs with total residual chlorine discharges in 2013; four facilities account for over 60 percent of those discharges. EPA reviewed the DMR data submitted by the top four facilities and found that all four met their permit limits in 2013 . In addition, EPA found that three of the facilities had minimum chlorine permit limits. EPA did not conduct a facility

- level review of the total residual chlorine discharges for the remaining 93 facilities because no facility individually contributed more than 5,000 TWPE. However, EPA notes that large number of facilities (97 facilities) reported total residual chlorine discharges on
DMR s in 2013 and three of the top four facilities reporting total residual chlorine discharges have minimum total residual chlorine limits in their permits

.

• Hexachlorobenzene

. Two facilities, Sasol, in Westlake, LA, and Nalco Company, in Garyville, LA, account for 93 percent of the 2013 DMR hexachlorobenzene discharges. EPA determined that hexachlorobenzene discharges from Sas ol will likely continue to decrease due to the implementation of more stringent permit limits. Nalco Company’s hexachlorobenzene discharges are also below its current permit limits. As a result, EPA determined that hexachlorobenzene discharges for the OCPSF Category do not represent a hazard priority at this time.

• Dioxin

. One facility, Solutia, in Nitro, WV, accounts for over 99 percent of the 2013 DMR TCDD discharges. Two facilities, Sasol, in Westlake, LA, and Dow Chemical, in Midland, MI, account for 93 percent of the 2013 TRI dioxin and dioxin- like compound releases. EPA reviewed the dioxin discharges and found the following:

− The facility contact at Solutia stated that the facility is implementing remediation activities under a RCRA permit, which include s capping and covering areas with

TCDD -affected soils, and pumping and treating groundwater from the affected area on site. TCDD discharges at the site have decreased from 2013 to 2014; the facility expects that the TCDD discharges will cease with the comp letion of remediation activities, scheduled for summer 2015.

− EPA identified a data correction for the TRI dioxin and dioxin-like compound releases from Sasol, decreasing the OCPSF category dioxin and dioxin- like compound TRI TWPE from 69,700 to 22,500.

− Th e facility contact at Dow Chemical confirmed the 2013 TRI dioxin and dioxinlike compound release data, and stated that the dioxin and dioxin-like compound

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

releases are from historical processes and waste management units that are no longer in operation at the site.

− For the reasons identified above, EPA has determined that dioxin discharges for the OCPSF Category do not represent a hazard priority at this time.

• Carbon Disulfide

. Three cellulose products manufacturing facilities, Viskase Corporation, in Loudon, TN, Innovia Films Inc., in Tecumseh, KS, and Viscofan USA Inc., in Danville, IL, account for 97 percent of the 2013 TRI carbon disulfide releases. EPA reviewed the carbon disulfide releases and found the following:

− EPA reviewed indirect carbon disulf ide releases from Viskase Corporation in 2011, as part of the Preliminary Study of Carbon Disulfide Discharges from Cellulose Products Manufacturers . Consistent with previous findings, EPA determined that the carbon disulfide discharges likely do not pass through to the

POTW effluent.

− EPA reviewed Innovia Films, Inc.’s NPDES permit in 2011, as part of the Preliminary Study of Carbon Disulfide Discharges from Cellulose Products Manufacturers . At the time, EPA determined that the concentration of carbon

disul fide entering the surface water is likely lower than sampled because of additional volatilization over the long distance between the sampling point and the wastewater treatment system final discharge point. TRI carbon disulfide discharges at the facility h ave remained stable from 2010 to 2013, and DMR discharges have decreased substantially from 2010 to 2013; therefore, EPA has

continued to find that 2013 TRI discharges are likely lower than sampled.

− As was the case for Viskase, the reported releases of ca rbon disulfide from Viscofan USA, Inc., are to POTWs. EPA determined that the carbon disulfide discharges likely do not pass through to the POTW effluent.

− Only ten facilities reported TRI carbon disulfide releases in 2013 and three constituted 97 percent of the releases (two of these discharge indirectly to POTWs). EPA does not consider the carbon disulfide releases to be representative

of the OCPSF category

.

• Nitrate

. One hundred twenty- one facilities reported releases of nitrate compounds to TRI in 2013; two facilities, DSM Chemicals NA, Inc., in Augusta, GA, and DuPont Chambers Works, in Deepwater, NJ, account for 38 percent of those releases. EPA confirmed that both facilities base their nitrate compound T RI releases on monitoring data. DSM Chemical’s TRI nitrate releases have remained fairly similar from 2010 through 2013, while DuPont Chambers Works’ TRI nitrate compound releases have decreased from 2010 through 2013. EPA did not conduct a facility- level review of the remaining 119 facilities with reported TRI nitrate compound releases in 2013, as the majority contribute less than 1,000 TWPE each. However, EPA notes that a large number of facilities ( 121 facilities ) reported nitrate compound releases to TRI in

2013.

3.10.10 OCPSF Category References

1. Brewer, Kevin. 2015. Telephone and Email Communication Between Kevin Brewer, ExxonMobil Chemical Co., and Eva Knoth, Eastern Research Group,

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3.10

— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

Inc., Re: 2013 TRI PACs Releases from ExxonMobil Chemical Co. in Baytown,

TX. ( May 7 ). EPA

- HQ

- OW -2015-0665. DCN 08171.

2. Connell, Elizabeth. 2015. Telephone and Email Communication Between

Elizabeth Connell, DSM Chemicals NA, Inc. , and Eva Knoth, Eastern Research Group, Inc., Re: 2013 TRI Nitrate Releases from DSM Chemicals NA, Inc., Augusta, GA . ( May 7 ). EPA

- HQ

- OW -2015-0665. DCN 08172.

3. ERG. 2015. Preliminary Category Review – Facility Data Review for Point Source Category – 414 – Organic Chemicals, Plastics, and Synthetic Fibers. ( September ). EPA

- HQ

- OW -2015-0665. DCN 08173.

4. House, Michael. 2014. Telephone and Email Communication Between Michael House, A.K.A Solutia, and Kimberly Bartell, Eastern Research Group, Inc., Re:

2013 DMR 2,3,7,8

- TCDD Discharges for A.K.A Solutia Nitro Site . (December 18). EPA

- HQ

- OW -2015-0665. DCN 08174.

5. Kennett, Shari. 2015. Telephone and Email Communication Between Shari Kennett, Dow Chemical, and Eva Knoth, Eastern Research Group, Inc., Re: 2013 TRI Dioxin Releases from Dow Chemical Co., Midland, MI. (May 8). EPA

- HQ

OW -2015-0665. DCN 08175.

6. LA DEQ. 2009a. Louisiana De partment of Environmental Quality. NPDES Permit: Sasol North America, Westlake, LA (LA0003336). (November 13). EPA

HQ

- OW -2015-0665. DCN 08176.

7. LA DEQ. 2009b. Louisiana Department of Environmental Quality. NPDES Permit: Nalco Company, Garyville, LA (LA0038890). (March 10). EPA

- HQ

- OW

2015-0665. DCN 08177.

8. LA DEQ. 2014. Louisiana Department of Environmental Quality. NPDES Permit: Sasol North America, Westlake, LA (LA0003336)

. (April 29). EPA

- HQ

- OW

2015-0665. DCN 08178.

9. Northey, Scott. 2015. Telephone a nd Email Communication Between Scott Northey, DuPont Chambers Works, and Eva Knoth, Eastern Research Group,
Inc., Re: 2013 TRI Nitrate Releases from DuP ont Chamber Works, Deepwater,

NJ . ( May 7 ). EPA

- HQ

- OW -2015-0665. DCN 08179.

10. Sasol. 2015. Sasol North Amer ican Operations. Lake Charles Chemical Complex

and R&D. EPA

- HQ

- OW -2015-0665. DCN 08180.

11. Shaw, Scott. 2014. Telephone and Email Communication Between Scott Shaw, Sasol North America, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Dioxin Discharges for Sasol . (December 23). EPA

- HQ

- OW -2015­

0665. DCN 08181.

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12. 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.

13. U.S. EPA. 2005a. Preliminary 2005 Review of Prioritized Categories of Industrial Dischargers . Washington, D.C. (August). EPA- 821 -B-05-004. EPAHQ

- OW -2004-0032-0016.

14. U.S. EPA. 2005b. Product and Product Group Discharges Subject to Effluent

Limitations and St andards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category . Washington, D.C. (April). EPA- HQ

- OW -2004­

0032-2568.

15. U.S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program Plan . Washington, D.C. (Decembe r). EPA -821-R-06-018. E PA

- HQ

OW -2004-0032-2782.

16. 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.

17. 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.

18. 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 -2008-0517-0514.

19. U.S. EPA. 2011a. Technical Support Document for the 2010 Effluent Guidelines Program Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA- HQ

- OW

2008-0517-0618.

20. U.S. EPA. 2011b. Preliminary Study of Carbon Di sulfide Discharges from Cellulose Products Manufacturers . Washington, D.C. (December). EPA -821-R11-009. EPA

- HQ

- OW -2015-0665. DCN 08182.

21. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. (December). EPA 821-R-12-001. EPA- HQ

- OW -2010-0824­

0195.

22. U.S. EPA. 2014. The 2013 Annual Effluent Guidelines Review Report. Washington, D.C. ( September ). EPA 821-R-14- 003 . EPA

- HQ

- OW -2014-0170­

0077.

23. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan

. Washington, D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN

08208.

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— Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414 )

24. VA DEQ. 2008. Virginia Department of Environmental Quality. NPDES Permit: Honeywell International, Inc., Hopewell, VA. (September 30). EPA- HQ

- OW

2014-0170-0033.

25. Webster, Jack. 2014. Telephone Communication Between Jack Webster, Viscofan USA, Inc., and Elizabeth Gentile, Eastern Research Group, Inc., Re: 2013 TRI

Carbon Disulfide Discharges from Viscofan USA, Inc

. (December). EPA

- HQ

OW -2015-0665. DCN 08183.

26. Yoder, Michael. 2014. Telephone and Email Communication Between Michael Yoder, Viskase Corporation, and Elizabeth Gentile, Eastern Research Group, Inc.,

Re: 2013 TRI Carbon Disulfide Discharges from Viskase Corp

. (December).

EPA

- HQ

- OW -2015-0665. DCN 08184.

27. Young, Alex. 2014. New DuPont Chambers Works plant manager ready to take on big change . South Jersey Times. (December). EPA

- HQ

- OW -2015-0665. DCN

08185.

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3.11

— Pulp, Paper, and Paperboard (40 CFR Part 430)

3.11 Pulp, Paper, and Paperboard (40 CFR Part 430)

EPA identified the Pulp, Paper, and Paperboard (Pulp and Paper) Category for preliminary review because it rank s high again , in terms of toxic-weighted pound equivalents (TWPE), in the final 2015 combined point source category rankings. Previously, EPA reviewed discharges from this category as part of the Preliminary and Final Effluent Guidelines Program Plans in 2004–2013 in which it also ranked high (U.S. EPA, 2004, 2006a, 2007, 2008, 2009a, 2011, 2012, 2014a, and 2014b). During its 2006 Effluent Guidelines Program Plan development, EPA also conducted a detailed study of this industry (U.S. EPA, 2006b).

This section summarizes the results of the 201 5 Annual Review. EPA focused its 2015 review on discharges of hydrogen sulfide, dioxin and dioxin-like compounds, and manganese and manganese compounds because of their high TWPE relat ive to other pollutants discharged by facilities in the Pulp and Paper Category. Dioxin and dioxin-like compounds and manganese and manganese compounds, reviewed as part of the 2013 Annual Review, continue to be top pollutants of concern. Hydrogen sulfide was added as a Toxic Release Inventory (TRI) reporting requirement in 2012. As a result, in 2013, hydrogen sulfide contributed a substantial amount of TWPE for the category. Therefore, for the 2015 Annual Review, available discharge data showed substantial contributions of hydrogen sulfide to the Pulp and Paper Category TWPE.

3.11.1 Pulp and Paper Category 2015 Toxicity Rankings Analysis

Table 3-102 compar es the toxicity r ankings analyse s (TRA) data for the Pulp and Paper Category from the 2011, 2013, and 2015 Annual Reviews. EPA did not conduct the TRA in 2012 or 2014, but instead reviewed additional data sources as part of the even-year annual review, as described in Section 2.2.1 of EPA’s Preliminary 2016 Plan (U.S. EPA, 2016). As discussed in this section, during the 2015 Annual Review, EPA identified a data correction that

affected the 2013 TRI data and TWPE. The bottom row of Table 3-102 shows both the original data and the corrected data resulting from this review.

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— Pulp, Paper, and Paperboard (40 CFR Part 430)

Table 3-102 . Pulp and Paper Category TRI and DMR Facility Count s and Discharges Reported for 2009, 2011, and 2013

Year of Discharge Year of

Review Pulp and Paper Category Facility Counts a Pulp and Paper Category TWPE

Total of TRI

Facilities Total DMR Major Facilities Total DMR

Minor Facilities TRI

TWPE b DMR

TWPE c Total

2009 2011 250 137 20 1,080,000 260,000 d 1,340,000

2011 2013 219 130 24 651,000 576,000 e 1,230,000

2,750,000 f 3,070,000 f

2013 2015 226 110 16 1,820,000 g 321,000 2,140,000 g

Sources : 201 3 Annual Review Report (for 2009 and 2011 DMR and TRI Data) (U.S. EPA, 2014 ); DMRLTOutput2013 _v1 (for 201 3 DMR); TRILTOutput2013_v1 (for 201 3 TRI).

Note: EPA did not evaluate 2010 or 2012 DMR and TRI data Note: TWPE values are rounded to three significant figures. Sums of individual values may not equal the t otal presented, due to rounding.

a Number of facilities with TWPE greater than zero.

b Releases include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for POTW removals. The 2013 TRI TWPE also includes TWPE associated with reported releases of hydrogen sulfide. Facilities began reporting releases of hy drogen sulfide to TRI in 2012.

c Includes DMR data from both major and minor dischargers

. d 2009 data after corrections were made during the 2011 Annual Review.

e 2011 data after corrections were made during the 2013 Annual Review.

f 2013 data prior to corrections made during the 2015 Annual Review.

g 2013 data after corrections were made during the 2015 Annual Review.

As shown in Table 3-102, the TRI TWPE decre ased from 2009 to 2011, then increased substantially from 2011 to 2013 while the number of facilities reporting releases to TRI

decreased from 2009 to 2013. The total number of facilities submitting discharge monitoring reports ( DMR s) decreased from 20 09 to 2013, the DMR TWPE increased from 2009 to 2011 and

decreased from 2011 to 2013 . The increase in TRI TWPE from 2011 to 2013 can be at tributed to new requirements for reporting hydrogen sulfide releases, discussed in the sections below.

3.11.2 Pulp and Paper Category Pollutants of Concern

EPA’s 2015 review of the Pulp and Paper Category focused on the 2013 TRI releases

because the TRI data dominate the category’s combined TWPE. Table 3-103 shows the five pollutants with the highest contribution to the 2013 TRI TWPE. Table 3-103 also presents the 2013 TRI TWPE after EPA corrected an error identified in this preliminary category review (discussed in the sections below). As a point of comparison, Table 3-103 also shows the 2011 TRI facility count and TWPE for these top five pollutants, based on the 2013 Annual Review (U.S. EPA, 2014). Because hydrogen sulfide was added as a TRI reporting requirement in 2012, no hydrogen sulfide releases were reported in 2011.

Hydrogen sulfide, dioxin and dioxin-like compounds, and manganese and manganese compounds contribute over 92 percent of the original 2013 TRI TWPE for the Pulp and Paper Category (prior to corrections discussed below). Sections 3.11.3 through 3.11.5 present EPA’s investigation of reported TRI releases of t he top three pollutants . EPA did not conduct a facilitylevel investigation of lead and lead compounds and mercury and mercury compounds, as part of the 2015 Annual Review, because they account for less than 4 percent of the total TRI TWPE.

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— Pulp, Paper, and Paperboard (40 CFR Part 430)

However, many facilities report lead and lead compound and mercury and mercury compound releases to TRI and individually their TWPE is over 45,000, as shown in Table 3-103.

Table 3-103. Pulp and Paper Category Top TRI Pollutants

Pollutant a 2013 TRI Data 2011 TRI Data

Number of Facilities Reporting Pollutant b Original

TWPE Corrected

TWPE Number of Facilities Reporting Pollutant b TWPE

Hydrogen Sulfide 98 1,190,000 1,190,000 NA c NA c

Dioxin and Dioxin

- Like Compounds 42 1,090,000 158,000 38 238,000

Manganese and Manganese Compounds 112 318,000 318,000 104 266,000

Lead and Lead Compounds 172 47,700 47,700 157 48,000

Mercury and Mercury Compounds 84 46,500 46,500 81 52,700

Top Pollutant Total NA 2,690,000 1,760,000 NA 605,000

Pulp and Paper Category

Total 226 2,750,000 1,820,000 219 651,000

Sources: TRILTOutput2011_v1; TRILTOutput2013_v1 Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable.

a Lead and lead compound and mercury and mercury compound releases c ombined contribute less than 5 percent
of the original 2013 category TRI TWPE. Therefore, EPA did not review releases of either pollutant as part of

the 2015 Annual Review.

b Number of facilities with TWPE greater than zero.

c Hydrogen s ulfide was added as a TRI reporting requirement in 2012; it was not a TRI

- listed chemical in 2011.

3.11.3 Pulp and Paper Category Hydrogen Sulfide Releases in TRI

EPA’s investigation of the hydrogen sulfide data revealed that seven facilities account for 80 percent of the hydrogen sulfide releases reported to TRI in 2013 (shown in Table 3-104 ). EPA investigated the top facility, which accounts for more than a quarter of the total hydrogen sulfide releases and double the releases reported by any of the other top reporting facilities. EPA did not review in further detail the hydrogen sulfide releases for the remaining 97 pulp and paper mills as part of the 2015 Annual Review, but instead focused on understanding t he presence, fate, and concentrations of hydrogen sulfide in pulp and paper mill effluents.

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3.11

— Pulp, Paper, and Paperboard (40 CFR Part 430)

Table 3-104. Top Facilities Reporting 2013 TRI Hydrogen Sulfi de Releases

Facility Name Facility Location Pounds of

Pollutant

Released Pollutant

TWPE Percent of Category TWPE

Georgia

- Pacific, Monticello Monticello, MS 115 ,000 32 3,000 27.2%

Rocktenn Stevenson, AL 50 ,600 14 2,000 11.9%

Alabama River Cellulose LLC Perdue Hill, AL 45

, 800 128 ,000 10.8%

Brunswick Cellulose, Inc. Brunswick, GA 45

, 3 00 12 7,000 10.7%

Rayonier Performance Fibers Jesup Mill Jesup, GA 34

, 6 00 9 7,000 8.2%

Georgia

- Pacific, Cedar Springs LLC Cedar Springs, GA 34 ,000 95 ,300 8.0%

Georgia

- Pacific, Toledo LLC Toledo, OR 16,100 45,100 3.8%

All other hydrogen sulfide dischargers in the Pulp and Paper Category a 82,100 230,000 19.4%

Total 424,000 1,190,000 100%

Source: TRILTOutput2013_v1

Note: Sums of individual values may not equal the total presented, due to rounding.

a 91 additional facilities reported hydrogen sulfide release s in the 2013 TRI

.

As part of the 2015 Annual Review, EPA contacted the American Forest and Paper Association (AF&PA) and the National Council for Air and Stream Improvement (NCASI). AF&PA is the national trade association of the forest, pulp, paper, paperboard, and wood products industry. NCASI is a nonprofit research institute funded by the North American forest products industry, including pulp and paper facilities. AF&PA and NCASI provided information on the presence, fate, and concentrations of hydrogen sulfide in pulp and paper mill effluents. Hydrogen sulfide, one of several forms of reduced sulfur, can occur in pulp and paper mill wastewater primarily from two processes: 1) the use and recovery of sulfur -containing pulping liquors; and 2) biological reduction of sulfate or other oxidized sulfur species in wastewater collection or treatment systems. Because most wastewater treatment systems in the forest products industry use aerobic biological treatment, AF&PA and NCASI suggested that high concentrations of hydrogen sulfide do not occur at pulp and paper mills that properly treat their wastewater. However, according to AF&PA and NCASI, it is possible for trace levels of hydrogen sulfide to be present in some treated effluents. Available data from four pulp mills using aerobic treatment showed hydrogen sul fide removal rates greater than 98 percent, mostly due to oxidation in the wastewater treatment system (Wiegand, 2015).

NCASI collected wastewater samples at 25 pulp and paper mills in the U.S. and Canada

for total sulfide concentrations and published the results in 2012 in an NCASI Technical Bulletin (NCASI, 2012; Wiegand 2015). The mills were not a random sample, but were chosen because they had experienced odor-related issues in which sulfide may have been a factor. Therefore, the

data represent mills w ith potentially higher concentrations of sulfide in their wastewater than are likely to be found in the category as a whole. The samples were analyzed using NCASI Method

RSC -02.02 , which uses direct aqueous injection gas chromatography with a pulsed flame photometric detector . This method measures the concentration of total sulfide in the sample that is volatile at pH 2.5. The data showed that biologically treated final effluent concentrations of total sulfide ranged from non-detect to 0.29 mg/L, with an average concentration of 0.10 mg/L.

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— Pulp, Paper, and Paperboard (40 CFR Part 430)

Six of the 25 mills sampled had non- detect total sulfide concentrations in their effluent (Wiegand, 2015).

NCASI indicated that measuring low concentrations of hydrogen sulfide is challenging due to its absorptive, adsorptive, photo reactive, volatile, biologically active, and oxidative properties. The hydrogen sulfide data collected for the 25 pulp and paper mills discussed above were based on measurements of total sulfide, as hydrogen sulfide is difficult to measure due to dependencies on pH, temperature, ionic strength, and organic and inorganic complexes. NCASI noted that hydrogen sulfide concentrations in treated mill effluents will be less than total sulfide concentrations, in part due to the likely presence of metal and organic sulfide complexes disassociated during the analytical procedure. In addition, pulp and paper mills typically operate biological treatment plants at a neutral pH of 7, higher than the 2.5 pH at which volatile sulfide s are measured by the method described above. Due to these factors, NCASI has suggested that the hydrogen sulfide releases identified in its 2012 report of treated mil l effluents may be an overestimate. NCASI also indicated that mills are likely using simi lar methods to estimate their TRI releases, resulting in estimates reported to TRI that are potentially overestimated ( NCASI, 2012; Wiegand, 2015).

In 2015, NCASI developed a new sampling system that may allow measurement of

dissolved sulfides in water sam ples (i.e., sulfide forms passing through a 0.7 μm filter), rather than total sulfides. Because the hydrogen sulfide in effluents is dissolved, accurately measuring dissolved sulfides is more likely to produce a close approximation of actual hydrogen sulfide concentrations than measuring total sulfide. AF&PA and NCASI believe that the new sampling system will mitigate overestimate s of hydrogen sulfide concentrations in TRI data (Wiegand, 2015).

As part of the 2015 Annual Review, and to follow up on the specific hydrogen sulfide release data reported to TRI in 2013, AF&PA and NCASI also contacted the Georgia- Pacific mill in Monticello, MS, to discuss their hydrogen sulfide releases. This mill reported the largest releases of hydrogen sulfide in 2013, accounting for more than a quarter of the total hydrogen sulfide releases reported to TRI in 2013 and double the releases reported by any of the other top reporting facilities. The mill confirmed their 2013 TRI hydrogen sulfide release, and stated that

this value was based on a direct total sulfide concentration measurement of the treated effluent at the facility. Since 2013, the facility has improved their wastewater treatment system by dredging treatment basins of accumulated solids to increase the available aeration zone, and releases decreased to 32,000 pounds (89,900 TWPE) per year in 2014 (Schwartz and Wiegand, 2014). This value is consistent with the hydrogen sulfide releases reported by the other top reporting

facilities. EPA did not review in further detai l the hydrogen sulfide releases for the remaining 97 pulp and paper mills, which account for 73 percent of the 2013 TRI hydrogen sulfide releases.

In summary, as discussed above, in 2013, pulp and paper mills may have calculated their hydrogen sulfide releases to TRI using a total sulfide concentration and, according to AF&PA and NCASI, this results in an overestimate. EPA has determined these industry trade associations are actively evaluating discharges from pulp and paper mills and are working on refining methods to improve the accuracy of sampling techniques that will enhance the quality of data reported to TRI in the future.

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— Pulp, Paper, and Paperboard (40 CFR Part 430)

3.11.4 Pulp and Paper Category Dioxin and Dioxin Compound Releases in TRI

EPA’s investigation of the dioxin and dioxin compound data revealed that five facilities account for 93 percent of the dioxin and dioxin-like compound releases reported to TRI in 2013 (shown in Table 3-105). EPA did not inves tigate the remaining facilities reporting releases of dioxin and dioxin-like compounds as part of the 2015 Annual Review.

Table 3-105. Top Facilities Reporting 2013 TRI Dioxin and Dioxin- Like Compounds

Releases

Facility Name Facility

Location Pounds of Pollutant

Released Pollutant

TWPE Percent of Category

TWPE

International Paper Pine Hill Mill Pine Hill, AL 0.00758 683,000 62.8%

Domtar Paper Co. Bennettsville, SC 0.00194 226,000 20.7%

Boise White Paper LLC Wallula, WA 0.000274 52,800 4.8%

Rayonier Performance Fibers

LLC Fernandina Beach, FL 0.00270 31,100 2.9%

Resolute FP US Inc.

– Calhoun Operations Calhoun, TN 0.00133 21,900 2.0%

All other dioxin and dioxin

- like compound dischargers in the Pulp and Paper Category a 0.103 74,100 6.8%

Total 0.117 1,090,000 100%

Source: TRILTOutput2013_v1

. Note: Sums of individual values may not equal the total presented, due to rounding.

a 37 additional facilities reported dioxin and dioxin

- like releases in the 2013 TRI

.

Int ernational Paper

International Paper’s Pine Hill, AL, facility is a containerboard mill. EPA has not previously reviewed dioxin and dioxin-like compound releases from this facility. As part of the 2015 Annual Review, EPA contacted AF&PA and NCASI about this facility’s dioxin and dioxin-like compound releases. AF&PA and NCASI confirmed that the facility inadvertently reported an incorrect dioxin distribution (Schwartz and Wiegand, 2014). Correcting the distribution decreases the facility’s dioxin and dioxin-like compound TWPE from 683,000 to

480.

Domtar Paper

As part of the 2011 and 2013 Annual Reviews, EPA reviewed the TRI dioxin and dioxinlike compound releases from Domtar Paper, in Bennettsville, SC, and determined that the number of pounds reported as released was based on one half of the detection limit and that dioxin was not actually detected at the mill. As described in Section 3.2.2.2 in EPA’s Technical Support Document for the Annual Review of Existing Effluent Guidelines and Iden tification of Potential New Point Source Categories (2009 Screening- Level Analysis (SLA) Report), EPA zeros the load for the purpose of its screening-level toxicity rankings analysis when all concentrations of a specific pollutant are reported as non

- detec ted values for all monitoringperiods (U.S. EPA, 2009b). Therefore, EPA zeroed the 2009 and 2011 TRI dioxin and dioxinlike compound releases for Domtar Paper (U.S. EPA, 2012 and 2014b). Table 3-106 presents

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— Pulp, Paper, and Paperboard (40 CFR Part 430)

Domtar Paper’s dioxin and dioxin-like compound TRI releases for 2009 through 2013. As shown, the 2013 release is similar to previous years. Therefore, without re- contacting the mill, EPA concluded that the 2013 reported dioxin and dioxin- like compound release was based on non-detected values. As in previously years, EPA zeroed Domtar Paper’s 2013 dioxin and

dioxin- like compound release.

Table 3-106. Domtar Paper Dioxin and Dioxin-Like Compound Releases for 2009 – 2013

Year Pounds of Dioxin and Dioxin

Like Compounds Released Dioxin and Dioxin

- Like Compound

TWPE

2009 0.002 225,000

2010 0.00195 232,000

2011 0.00196 228,000

2012 0.00195 232,000

2013 0.00194 226,000

Source: TRI LTOutput2013_v1 ; DMR Loading Tool.

Boise White Paper LLC

EPA previously reviewed discharges from Boise White Paper LLC, in Wallula, WA, as part of the 2011, 2012, and 2013 Annual Reviews. As part of the 2011 and 2012 Annual Reviews, EPA reviewed 2009 TRI data and determined that the mill calculated dioxin releas es using actual dioxin test results. EPA also determined that the facility detected concentrations of 2,3,7,8-TCDF above the Method 1613B Minimum Level (ML); however, the concentrations of

all other detected congeners were below the method MLs. Since EPA d oes not know the laboratory specific MLs, it is possible that the results are below the laboratory’s MLs and may

not be accurate.

As part of the 2015 Annual Review, EPA contacted AF&PA and NCASI about Boise White Paper LLC’s TRI dioxin and dioxin- like com pound releases. The facility contact provided 2012 through 2014 effluent sampling data, shown in Table 3-107 (Schwartz and Wiegand, 2014). As shown, the detected concentrations are all below the corresponding method MLs. As noted above, s ince EPA does not know the laboratory specific MLs, it is possible that the results are below the laboratory’s MLs and may not be accurate.

The facility contact also stated that the company instituted new reporting conventions in 2012. The changes to reporting conventions included using one half of the sample- specific detection limit when values were not detected. In previous reporting years, all non- detect values were reported as zero (Schwartz and Wiegand, 2014).

Table 3-107. Boise White Paper LLC Dioxin and Dioxin- Like Compound Concentrations

Dioxin Congener

Number Dioxin Congener Method 1613B ML (pg/L) 2012 (pg/L) 2013 (pg/L) 2014 (pg/L)

1 2,3,7,8

- TCDD 10 ND ND ND

2 1,2,3,7,8

- PeCDD 50 ND ND ND

3 1,2,3,4,7,8

- HxCDD 50 ND ND ND

4 1,2,3,6,7,8

- HxCDD 50 ND ND ND

5 1,2,3,7,8,9

- HxCDD 50 ND ND ND

6 1,2,3,4,6,7,8

- HpCDD 50 14.5 ND ND

7 1,2,3,4,6,7,8,9

- OCDD 100 95.6 20.8 97.2

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— Pulp, Paper, and Paperboard (40 CFR Part 430)

Table 3-107. Boise White Paper LLC Dioxin and Dioxin- Like Compound Concentrations

Dioxin Congener

Number Dioxin Congener Method 1613B ML (pg/L) 2012 (pg/L) 2013 (pg/L) 2014 (pg/L)

8 2,3,7,8

- TCDF 10 9.3 0 ND 7.03

9 1,2,3,7,8

- PeCDF 50 3.24 ND ND

10 2,3,4,7,8

- PeCDF 50 5.48 ND ND

11 1,2,3,4,7,8

- HxCDF 50 ND ND ND

12 1,2,3,6,7,8

- HxCDF 50 3.15 ND ND

13 1,2,3,7,8,9

- HxCDF 50 ND ND ND

14 2,3,4,6,7,8

- HxCDF 50 ND ND ND

15 1,2,3,4,6,7,8

- HpCDF 50 ND ND ND

16 1,2,3,4,7,8,9

- HpCDF 50 ND ND ND

17 1,2,3,4,6,7,8,9

- OCDF 100 ND ND ND

Total 131 20.8 104
Sources: Schwartz & Wiegand, 2014

ND: Non

- detect results.

Rayonier Performance Fibers

EPA reviewed TRI dioxin and dioxin- like compound discharges from Rayonier Performance Fibers (Rayonier) in Fernandina Beach, FL, as part of the 2011, 2012, and 2013 Annual Reviews. From these earlier reviews, EPA confirmed that the mill bases its reported

dioxin and dioxin- like compound discharg es on quarterly measurements (U.S. EPA, 2012). Rayonier reported that they detected seven dioxin congeners in their effluent wastewater in

2009 40 and five in 2011 41 . In both years, two congeners were detected above EPA’s Method 1613 MLs; however, EPA c oncluded that the concentrations were low and that the discharges did not warrant further review (U.S. EPA, 2014a, 2014b).

Similar to previous years, Rayonier reported that they detected seven dioxin congeners in

their effluent wastewater in 2015 42

. Table 3-108 presents Rayonier’s dioxin and dioxin- like compound TRI releases for 2009, 2011, and 2013. As shown, quantities of these congeners and

the TWPE ha ve decreased from 2009 to 2013.

Table 3-108. Rayonier Dioxin and Dioxin-Like Compound Releases for 2009, 2011, 2013

Year Pounds of Dioxin and Dioxin

Like Compounds Released Dioxin and Dioxin

- Like Compound

TWP E

2009 0.011 37,800

2011 0.016 38,900

2013 0.0026 31,100

Source: TRI LTOutput2013_v1 ; DMR Pollutant Loading Tool.

40 Rayonier detected concentrations of 1,2,3,7,8,9

- HxCDD; 1,2,3,4,6,7,8

- HpCDD; 1,2,3,4,6,7,8,9

- OCDD; 2,3,7,8

­ TCDF; 2,3,4,7,8

- PeCDF; 1,2,3,4,6,7,8

- HpCDF; and 1,2,3,4,6,7,8,9

- OCDF in 2009. See Section 5.3.2 in the 2012 Annual Review Report (U.S.EPA, 2014a).

41 Rayonier d etected concentrations of 1,2,3,4,6,7,8

- HpCDD; 1,2,3,4,6,7,8,9

- OCDD; 2,3,7,8

- TCDF; 1,2,3,4,6,7,8

­ HpCDF; and 1,2,3,4,6,7,8,9

- OCDF in 2011 (U.S. EPA, 2014b).

42 Rayonier detected concentrations of 1,2,3,7,8

- PeCDD; 1,2,3,4,6,7,8

- HpCDD; 1,2,3,4,6,7,8,9

- OCDD; 2, 3,7,8

­ TCDF; 1,2,3,4,7,8

- HxCDF; 1,2,3,4,6,7,8

- HpCDF; and 1,2,3,4,6,7,8,9

- OCDF in 2013.

3-1183— EPA’s 2015 Preliminary Category Reviews

3.11

— Pulp, Paper, and Paperboard (40 CFR Part 430)

Resolute FP US Inc. – Calhoun Operations

EPA reviewed TRI dioxin and dioxin-like compound discharges from Resolute FP US Inc. (Resolute) 43 in Calhoun, TN, as part of the 2011 and 2013 Annual Reviews. As part of these earlier reviews, EPA confirmed that all dioxin congeners were non-detect and zeroed the TRI dioxin and dioxin-like compound releases for the facility. Table 3-109 presents the facility’s dioxin and dioxin-like compound TRI releases for 2009, 2011, and 2013. Since the 2013 dioxin and dioxin-like compound discharges are similar to previous years, EPA similarly zeroed them. Zeroing dioxin and dioxin-like compound discharges from Resolute further decreases the Pulp and Paper dioxin and dioxin-like compound TRI TWPE to 158,000, as shown in Table 3-103.

Table 3-109. Resolute Dioxin and Dioxin-Like Compound Releases for 2009, 2011, 2013

Year Pounds of Dioxin and Dioxin

Like Compounds Released Dioxin and Dioxin

- Like Compound

TWPE

2009 0.0015 24,900

2011 0.0016 27,300

2013 0.0013 21,900

Source: TRI LTOutput2013_v1 ; DMR Loading Tool.

3.11.5 Pulp and Paper Category Manganese and Manganese Compound Releases in TRI

Manganese and manganese compound discharges account for 14.5 percent of the total 2013 TRI TWPE. Manganese is not a regulated pollutant in the Pulp and Paper effluent limitations guidelines and standards (ELGs). In 2013, 112 facilities reported discharges of manganese and manganese compounds to TRI.

EPA reviewed manganese and manganese compound discharges in detail as part of the 2006 Pulp and Paper Detailed Study. At that time, EPA concluded that manganese and manganese compound discharges in this categor y are below treatable levels (U.S. EPA, 2006b). More recently, EPA reviewed the TRI manganese and manganese compound discharges for the Pulp and Paper Category as part of the 2011 and 2013 Annual Reviews. During these reviews, EPA compared annual releases reported to TRI to data reviewed as part of the 2006 Pulp and Paper Detailed Study and determined that the releases remained relatively consistent. Therefore, EPA confirmed that its previous conclusion from the 2006 detailed study still applies. As part of the 2011 and 2013 Annual Reviews, however, EPA did not further evaluate manganese concentration data (U.S. EPA, 2012, 2014b).

As part of the 2015 Annual Review, EPA reviewed manganese and manganese compound discharges in TRI from 2002 to 2013 (see Table 3-110). As shown, the discharges are fairly consistent from 2002 to 2013. However, EPA notes that nearly 50 percent of the facilities (112 out of 226 facilities) repor ting releases to TRI reported releases of manganese and manganese compounds in 2013 (none contributed more than five percent of the manganese and manganese compound TRI TWPE for the Pulp and Paper Category). EPA has not evaluated manganese concentration data compared to treatable levels since the 2006 detailed study

.

43 This facility is referred to as Abibow US Inc. in previous annual review reports. In 2012, Abibow US Inc. became Resolute FP US Inc. (Resolute, 2012).

3-1193— EPA’s 2015 Preliminary Category Reviews

3.11

— Pulp, Paper, and Paperboard (40 CFR Part 430)

Table 3-110. 2002

– 2013 Manganese and Manganese Compound Releases in TRI

Discharge Year Review Year TRI Data

Number of Dischargers Total TWPE

2002 2006 112 304,000

2004 2007 117 316,000

2007 2009 79 231,000

2008 2010 117 308,000

2009 2011 115 298,000

2011 2013 104 266,000

2013 2015 112 31 8,000

Sources: TRIReleases2002; PCSLoads2002; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2007_v2;
DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3; TRIReleases2009_v2; DMRLoads2009_v2; DMRLTOutput2011_v1; TRILTOutput2011_v1; DMRLTOutput2013_v1; TRILTOutput2013_v1

.

3.11.6 Pulp and Paper Category Findings

The estimated toxicity of the Pulp and Paper Category discharges resulted primarily from hydrogen sulfide, dioxin and dioxin-like compound, and manganese and manganese- like compound releases reported to TRI. From the 2015 Annual Review, EPA found:

• Hydrogen Sulfide. Seven facilities account for 80 percent of the TRI hydrogen

sulfide releases, with one facility, Georgia -Pacific, in Monticello, MS, accounting for 27 percent of the releases. The Georgia -Pacific facility confirmed the 2013 TRI hydrogen sulfide release data, but stated that wastewater treatment system improvements have led to decreased hydrogen sulfide discharges in 2014.

EPA identified 97 mills with hydrogen sulfide releases reported to TRI in 2013. Discussions with industry trade associations, AF&PA and NCASI, suggest that pulp and paper mills may calculate their hydroge n sulfide releases to TRI using total sulfide concentrations, which may result in an overestimate. Further, NCASI has developed a new sampling system that may allow measurement of dissolved sulfides, which AF&PA and NCASI believe may lessen the overestimat e of hydrogen sulfide

releases in TRI.

• Dioxin. The majority of dioxin and dioxin-like compound releases from the Pulp and Paper Category result from five facilities. Three of the facilities had data changes, resulting in the dioxin and dioxin-like compound TWPE for the Pulp and Paper Category to decrease from 1,090,000 to 158,000. This decreases the 2013 Pulp and Paper Category TWPE from 3,070,000 to 2,140,000. EPA determined the remaining two facilities either had discharges below the method MLs or decrea sing discharges in recent years.

• Manganese. In 2013, 112 facilities reported releases of manganese and manganese compounds with none contributing more than five percent of the 2013 manganese and manganese compound TRI TWPE for the Pulp and Paper Category. Though the releases have been fairly consistent from 2002 to 2013, it has been nearly 10 years

3-1203— EPA’s 2015 Preliminary Category Reviews

3.11

— Pulp, Paper, and Paperboard (40 CFR Part 430)

since EPA conducted the Pulp and Paper Detailed Study in which it evaluated manganese and manganese compound concentrations compared to treatable levels

.

• Lead and Mercury . EPA did not further investigate lead and lead compounds and mercury and mercury compounds as part of the 2015 Annual Review; however, EPA notes that a large number of facilities reported lead and lead compound and mercury and mercury compound releases (172 and 84 facilities, respectively ), to TRI in 2013.

These pollutants are not regulated by the Pulp and Paper Category ELGs.

3.11.7 Pulp and Paper Category References

1. ADEM. 2012. Alabama Department of Environmental Management. NPDES

Permit for International Paper Company

– Pine Hill Containerboard Mill, Pine Hill, AL (AL0002674). (August 1). EPA

- HQ

- OW -2015-0665. DCN 08198.

2. ERG. 2015 . Preliminary Category Review

– Facility Data Review and Revised Calculations for Point Source Category 430 – Pulp and Paper. ( September ). EPA

HQ

- OW -2015-0665. DCN 08199.

3. Resolute FP. 2012. Resolute Forest Products. Legal Entity Name Changes . (May 23). EPA

- HQ

- OW -2015-0665. DCN 08200.

4. Schwartz, Jerry, and Paul Wiegand. 2014.Telephone and Email Communication Between Jerry Schwartz, American Forest and Paper Association , Paul Wiegand, National Council for Air and Stream Improvement, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013DMR and TRI Pulp and Paper Dischargers. ( Decembe r). EPA

- HQ

- OW -2015-0665. DCN 08201.

5. 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.

6. U.S. EPA. 2006a. Technical Support Document for the 2006 Effluent Guidelines

Pr ogram Plan . Washington, D.C. (December). EPA-821-R-06-018. EPA- HQ

OW -2004-0032-2782.

7. 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.

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. 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.

3-1213— EPA’s 2015 Preliminary Category Reviews

3.11

— Pulp, Paper, and Paperboard (40 CFR Part 430)

10. 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 -2008-0517-0514.

11. U.S. EPA. 2009b. Technical Support Document for the Annual Review of Existing Effluent Guidelines and Identification of Potential New Point Source Categories

. EPA821 -R-09-007. Washington, D.C. (October). EPA- HQ

- OW -2008-0517-0515.

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

2008-0517-0618.

13. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. (December). EPA 821-R-12-001. EPA- HQ

- OW -2010-0824­

0195.

14. U.S. EPA. 2014a. The 2012 Annual Effluent Guidelines Review Report

. Washington, D.C. (September). EPA -821-R-14-004. EPA

- HQ

- OW -2010-0824­

0320.

15. U.S. EPA. 2014b. The 2013 Annual Effluent Guidelines Review Report

. Washington, D.C. (September). EPA-821-R-14-003. EPA- HQ

- OW -2014-0170­

0077.

16. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan. Washington, D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN

08208.

17. Wiegand, Paul. 2015. National Council for Air and Stream Improvement. A Summary of Information Regarding the Presence, Fate, and Concentrations of Reduced Sulfur in Pulp and Paper Mill Treated Effluents. (January). EPA

- HQ

OW -2015-0665. DCN 08202.

3-1223— EPA’s 2015 Preliminary Category Reviews

3.12

— Textile Mills (40 CFR Part 410)

3.12 Textile Mills (40 CFR Part 410)

EPA identified the Textile Mills (Textiles) Category for preliminary review because it ranks high again, in terms of toxic-weighted pound equivalents (TWPE), in the final 2015 combined point source category rankings. Previously, EPA reviewed discharges from this category as part of the 2005, 2006, 2007, 2010, and 2011 Annual Reviews in which it also ranked high (U.S. EPA, 2005, 2006, 2007, 2011, 2012). This section summari zes the results of the 2015 Annual Review. EPA focused its 2015 review on discharges of toxaphene and sulfide because of their high TWPE relative to the other pollutants discharged by facilities in the Textiles Category.

3.12.1 Textiles Category 2015 Toxicity Rankings Analysis

Table 3-111 compares the toxicity rankings analyses (TRA) data for the Textiles Category from the 2011, 2013, and 2015 Annual Reviews. EPA did not conduct the TRA in 2012 or 2014, but instead reviewed additional data sources as part of the even-year annual review, as described in Section 2.2.1 of EPA’s Preliminary 2016 Plan (U.S. EPA, 2016). During the 2015 Annual Review, EPA did not identify any data corrections to the 2013 Discharge Monitoring Report (DMR) and Toxic Release Inventory (TRI) discharge data for the Tex tiles Category.

Table 3-111. Textiles C ategory TRI and DMR Facility Counts and Discharges Reported in 2009, 2011, and 2013

Year of Discharge Year of

Review Textiles Category Facility Counts a Textiles Category TWPE

Total TRI

Facilities Total DMR Major

Facilities Total DMR

Minor

Facilities TRI

TWPE b DMR TWPE c Total

TWPE

2009 2011 54 35 21 1,910 37,200 39,100

2011 2013 41 27 25 1,070 22,300 23,400

2013 2015 43 29 21 2,210 89,500 91,700

Sources: TRIReleases2009_v2

, DMRLoads2009_v2 , and 2011 Annual Review Report (for 2009 DMR data ) (U.S. EPA, 2012 ); DMRLTOutput2011_v1 (for 2011 DMR); TRILTOutput2011_v1 (for 2011 TRI); DMRLTOutput2013_v1 (for 2013 DMR); TRILTOutput2013_v 1 (for 2013 TRI)

Note: EPA di d not evaluate 2010 or 2012 DMR and TRI data Note: TWPE values are rounded to three significant figures. Sums of individual values may not equal the total presented, due to rounding.

a Number of facilities with TWPE greater than zero.

b Releases include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for

POTW removals.

c Includes DMR d ata from both major and minor dischargers.

As shown in Table 3-111 , the total TWPE increased significantly in 2013, while the number of TRI and major and minor DMR facilities decreased slightly from 2009 to 2013.

3.12.2 Textiles Category Pollutants of Concern

E PA’s 2015 review of the Textiles Category focused on the 2013 DMR discharges

because the DMR data dominate the category’s combined TWPE. Table 3-112 shows the five

3-1233— EPA’s 2015 Preliminary Category Reviews

3.12

— Textile Mills (40 CFR Part 410)

po llutants w ith the highest contribution to the 2013 DMR TWPE. As a point of comparison,

Table 3-112 shows the 2011 DMR facility count and TWPE for these top five pollutants, based on the 2013 Annual Review (U.S. EPA, 2014).

Toxaphene and sulfide contribute more than 95 percent of the total 2013 DMR TWPE

. Of these top pollutants, only sulfide is a regulated pollutant in the Textiles Category effluent limitation guidelines and standards (ELGs) (40 CFR Part 410). EPA’s investigations of reported discharges of the top two pollutants are presente d in Section s 3.12.3 and 3.12.4. EPA did not investigate the other pollutants, including copper, zinc, and total residual chlorine, as part of the 2015 Annual Review, because they represent a small percentage (4 percent) of the 2013 DMR TWPE for the Textiles Category.

Table 3-112. 2013 Textiles Category Top DMR Pollutants

Pollutant b 2013 DMR Data a 2011 DMR Data a

Number of Facilities Reporting Pollutant c TWPE Number of Facilities Reporting Pollutant c TWPE

Toxaphene 1 48,000 0 0

Sulfide 9 37,600 13 19,200

Copper 13 2,280 9 67 .1

Zinc 9 1,330 8 13 .1

Total Residual Chlorine 11 110 17 1,170

Top Pollutant Total NA 89,300 NA 20,400

Textiles Category Total 50 89,500 52 22,300

Sources: DMRLTOutput2013_v1 (for 2013 TWPE); DMRLTOutput2011_v1 (for 2011 TWPE) Note: Sums of individual values may not equal the total presented, due to rounding. NA: Not applicable.

a Includes DMR data from both major and minor dischargers

. b Copper, zinc, and total residual chlorine discharges combined contribute 4 percent of the 2013 category DMR

TWPE. Therefore, EPA did not review copper, zinc, or total residual chlorine discharges as part of the 2015

Annual Review.

c Number of facilities with TWPE greater than zero.

3.12.3 Textiles Toxaphene Discharges in DMR

EPA’s investigation of the toxaphene discharges revealed that one facility, Mohawk Industries Inc. Oak River Facility (Mohawk Industries), in Bennettsville, SC, accounts for 100 percent of the 2013 DMR toxaphene discharges. In 2013, the facility reported 1.59 pounds of toxaphene discharged, corresponding to 48,000 TWPE ( DMRLTOutput2013_v1)

.

Mohawk Industries in Bennettsville, SC, discharges toxaphene from one outfall and submits monthly toxaphene concentrations, presented in Table 3-113 . The facility’s permit includes a monthly average toxaphene limit of 0.79 micrograms per liter (μg/L), equal to 0.00079 milligrams per liter (mg/L), and a daily maximum toxaphene limit of 17.8 μg/L (0.0178 mg/L) for outfall 001 (Ri ppy, 2015). EPA reviewed this facility’s toxaphene discharges as part of the 2010 Annual Review. The facility contact confirmed that toxaphene is not used as a raw material or in any other chemicals at the facility. However, detectable concentrations have been

3-1243— EPA’s 2015 Preliminary Category Reviews

3.12

— Textile Mills (40 CFR Part 410)

found in water quality data. Therefore, the South Carolina Department of Health and Environmental Control (SC DHEC) included limitations for toxaphene in the facility’s permit (U.S. EPA, 2011). As shown in Table 3-113, the concentrations for June, July, November, and December 2013 are above the facility’s monthly average permit limit.

Table 3-113 . Mohawk Industries’ 2013 DMR Monthly Toxaphene Discharges Reported for Outfall 001

Date Monthly Average Flow (MGD) Monthly Average Concentration (mg/L) NPDES M onthly Average

Permit Limit (mg/L)

31

- Jan

- 13 0.190 0.00025 0.00079

28

- Feb

- 13 0.106 0.00025 0.00079

31

- Mar

- 13 0.160 0.000025 0.00079

30

- Apr

- 13 0.240 0.00025 0.00079

31

- May

- 13 0.250 0.00025 0.00079

30

- Jun

- 13 0.230 0.01 a 0.00079

31

- Jul

- 13 0.096 0.007 a 0.00079

31

- Aug

- 13 0.130 0.00025 0.00079

30

- Sep

- 13 0.140 0.00012 0.00079

31

- Oct

- 13 0.075 0.00025 0.00079

30

- Nov

- 13 0.077 0.0012 a 0.00079

31

- Dec

- 13 0.110 0.025 a 0.00079

Source: DMRLTOutput2013_v1

.

a Toxaphene concentration exceeds monthly average permit limit.

As part of the 2015 Annual Review, EPA contacted the SC DHEC to confirm the facility’s 2013 toxaphene discharges. The state contact confirmed the discharges and stated that the higher concentrations for four months in 2013 were due to matrix interferences when analyzing the water samples (Rippy, 2015). The facility provided detailed notes discussing the issues on the monthly DMRs, shown in Table 3-114.

Table 3-114 . Mohawk Industries 2013 DMR Notes for Toxaphene Discharges

Date Facility DMR Notes

30

- Jun

- 13 “The detection limit for toxaphene could not be achieved due to matrix interference caused by dyes. Two samples for June 2013 were analyzed attempting to achieve 0.5 micrograms per liter (μg/L). Both of the samples exhibited chromatographic co

- elution, which is defined as multiple compounds having retention times that are the same or similar. Dilution was

necessary to v erify toxaphene was not present at the level reported, in which two co

- eluting dye compounds were not present.”

31

- Jul

- 13 “Toxaphene is not used anywhere on the Oak River site, nor is it used in any process. There apparently is an interference in the testing leading to a false positive. The facility is currently changing to another lab certified in South Carolina that will al so parallel test.”

30

- Nov

- 13 “Two samples were analyzed for toxaphene and the lowest detection limit achieved on both samples was 2.5 μg/L. A dilution was required for both samples to eliminate matrix

interference from non

- target background and resulted in an elevated reporting limit of 2.5 μg/L. The lab exhausted everything allowed in the EPA Method 8081B procedure and were unable to achieve a reading below our limit of 0.79 μg/L.”

31

- Dec

- 13 “PQL for toxaphene was found to be less than 0.025 mg/L using EPA Method 8081B. The sample was diluted due to matrix interferences that impaired the ability to make an accurate analytical determination. The detection limit was elevated in order to reflect the necessary

dilution.”

Source: Rippy, 2015

3-1253— EPA’s 2015 Preliminary Category Reviews

3.12

— Textile Mills (40 CFR Part 410)

EPA reviewed 2 014 toxaphene DMR discharges and confirmed the toxaphene TWPE has decreased to 3,860.

3.12.4 Textiles Sulfide Discharges in DMR

EPA’s investigation of the sulfide discharges revealed that one facility, King America Finishing Inc., (King America) in Sylvania, GA, accounts for over 70 percent of the 2013 DMR sulfide discharges (shown in Table 3-115 ). EPA did not investigate the eight remaining facilities discharging sulfide as part of the 2015 Annual R eview.

Table 3-115. Top 2013 DMR Sulfide Discharging Facilities

Facility Name Facility

Location Pounds of

Pollutant Discharged Pollutant

TWPE Percent of Category TWPE

King America Finishing Inc. Sylvania, GA 9,510 26,600 70.9%

All other sulfide dischargers in the Textiles Category a 3,910 10,900 29.1%

Total 13,400 37,600 100%

Source: DMRLTOutput2013_v1. Note: Sums of individual values may not equal the total presented, due to rounding.

a Eight additional facilities submitted sulfide discharges in the 2013 DMR data

.

King America in Sylvania, GA, produces cotton and poly/cotton woven fabrics. The facility discharges sulfide from outfall 001. The facility was issued a new permit in December 2013. The previous permit included a monthly average sulfide limit of 31 pounds per day (lb/day) (14.1 kilograms per day (kg/day)) and a daily maximum sulfide limit of 62 lb/day (28.1 kg/day) for outfall 001 (Beranek, 2015). The new permit includes a monthly average sulfide limit of 24 lb/day (10.9 kg/day) and a daily maximum sulfide limit of 48 lb/day (21.8 kg/day) fo r outfall 001 (GA EPD, 2013).

Table 3-116 presents King America’s 2013 sulfide discharges, along with average monthly flow for outfall 001. As shown in Table 3-116, 2013 sulfide discharges are below the

fa cility’s previous and new permit limits.

Table 3-116. King America’s 2013 DMR Monthly Sulfide Discharges Reported for Outfall 001

Date Monthly Average Flow (MGD) Monthly Average Quantity (kg/day) NPDES M onthly Average

Permit Limit (kg/day) a

31

- Jan

- 13 1.28 5.44 14.1

28

- Feb

- 13 1.38 5.89 14.1

31

- Mar

- 13 1.40 5.45 14.1

30

- Apr

- 13 1.41 5.89 14.1

31

- May

- 13 1.20 4.98 14.1

30

- Jun

- 13 1.48 5.60 14.1

3-1263— EPA’s 2015 Preliminary Category Reviews

3.12

— Textile Mills (40 CFR Part 410)

Table 3-116. King America’s 2013 DMR Monthly Sulfide Discharges Reported for Outfall 001

Date Monthly Average Flow (MGD) Monthly Average Quantity (kg/day) NPDES M onthly Average

Permit Limit (kg/day) a

31

- Jul

- 13 1.61 7.44 14.1

31

- Aug

- 13 1.72 6.50 14.1

30

- Sep

- 13 1.73 6.59 14.1

31

- Oct

- 13 1.57 6.08 14.1

30

- Nov

- 13 1.59 6.84 14.1

31

- Dec

- 13 1.44 5.65 10.9

Source: DMRLTOutput2013_v1 ; Beranek, 2015, GA EPD, 2013.

a The permit limit listed for January to November 2013 is from the facility’s previous permit, which expired in November 2013. The permit limit listed for December 2013 is from the facility’s new permit, issued in

December 2013.

As part of the 2015 Annual Review, EPA contacted the facility to discuss their sulfide discharges. The facility contact confirmed the 2013 discharges and stated that the facility monitors for sulfide on a daily basis. The majority of the daily samples are non- detect and the facility uses the detection limit for these samples to calculate monthly average loads. Because the monthly average values submitted on the DMR are averages of the daily samples collected throughout the month and non- detect samples are assumed to be at the detecti on limit, the overall monthly average load is always equivalent to or greater than the detection limit for sulfide (Hutcheson, 2015)

. Sulfide discharges are below permit limits for outfall 001 and the facility is performing daily monitoring; therefore

.

3.12.5 Textiles Category Findings

The estimated toxicity of the Textiles Category discharges resulted primarily from toxaphene and sulfide discharges reported on DMRs. From the 2015 Annual Review, EPA

found:

• Toxaphene. One facility, Mohawk Industries, Inc. Oak River Facility, in Bennettsville, SC, contributed 100 percent of the 2013 DMR toxaphene discharges. The facility experienced matrix interferences with analyzing samples in 2013, resulting in false positive results; therefore, EPA does not consider Mohawk Industries’ reported toxaphene discharges to be representative of discharges across the Textiles Category.

• Sulfide. King America Finishing, Inc., in Sylvania, GA, contributed over 70 percent of the 2013 DMR sulfide discharges. All 2013 sulfide discharges are below the facility’s permit limits and the facility is performing daily monitoring

.

3.12.6 Textiles Category References

1. Beranek, Christopher. 2015. Telephone and Email Communication Between Christopher Beranek, Geo rgia Environmental Protection Division, and Kimberly

3-1273— EPA’s 2015 Preliminary Category Reviews

3.12

— Textile Mills (40 CFR Part 410)

Bartell, Eastern Research Group, Inc., Re: 2013 DMR Sulfide Discharges for King America Finishing. (May 11). EPA

- HQ

- OW -2015-0665. DCN 08203.

2. ERG. 2015. Preliminary Category Review – Facility Data Review for Point Source Category 410 – Textiles. (September). EPA

- HQ

- OW -2015-0665. DCN

08204.

3. GA EPD. 2013. Georgia Department of Natural Resources, Environmental

Protection Division. NPDES Permit: King America Finishing, Inc. (GA0003280). (November 19). EPA

- HQ -OW-2015-0665. DCN 08205.

4. Hutcheson, Matthew. 2015. Telephone and Email Communication Between Matthew Hutcheson, King America Finishing, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2013 DMR Sulfide Discharges. (May 13). EPA

- HQ

OW -2015-0665. DCN 08206.

5. Rippy, Crystal. 2015. Telephone and Email Communication Between Crystal Rippy, South Carolina Department of Health and Environmental Compliance, and Kara Edquist, Eastern Research Group, Inc., Re: 2013 DMR Discharges for Mohawk Industries. (February 13). EPA

- HQ

- OW -2015-0665. DCN 08207.

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

2004-0032-0016.

7. U.S. EPA. 2006. Technical Support Document for the 20 06 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. 2011. Technical Support Document for the 2010 Effluent Guidelines Program Plan . Washington, D.C. (October). EPA 820-R-10-021. EPA- HQ

- OW

2008-0517-0618.

10. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Repor t. Washington, D.C. (December). EPA 821-R-12-001. EPA- HQ

- OW -2010-0824­

0195.

11. U.S. EPA. 2014. The 2013 Annual Effluent Guidelines Review Report

. Washington, D.C. (September). EPA-821-R-14-003. EPA- HQ

- OW -2014-0170­

0077.

12. U.S. EPA. 2016. Preliminary 2016 Effluent Guidelines Program Plan. Washington, D.C. (June). EPA-821-R-16-001. EPA- HQ

- OW -2015-0665. DCN

08208.

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4. EPA’ S 2015 R EVIEW OF A DDITIONAL I NDUSTRIAL C ATEGORIES AND P OLLUTANTS

For the 2015 Annual Review EPA also initiated a review of two additional point source categories that were not identified as categories warranting further review in the 2015 TRA; Battery Manufacturing (40 CFR Part 461) and Electrical and Electronic Components (40 CFR Part 469), specifically Subpart B Electronic Crystals. In addition, EPA reviewed in more detail 2-Mercaptobenothiazole (MBT), a chemical compound used in tire manufacturing . Tire manufacturing is covered under the Rubber Manufacturing Point Source Category (40 CFR Part 428), Sub part A ( Tire and Inner Tube Plants Subcategory ).

EPA initiated these reviews to address comments received from stakeholders regarding recent changes to these industries as well as potential new pollutant releases to the environment through industrial wast ewater discharge. As part of these reviews, EPA reviewed the existing

ELGs and supporting development documents, examined recent changes to the industries, including new processes and technologies that may be generating new pollutants of concern, or

source s of industrial wastewater discharge not previously considered, and reviewed readily available data on current discharges

.

EPA documented the quality of the data supporting its review of these industrial categories , analyzed how the data could be used to characterize the industrial wastewater discharges, and prioritized the findings for further review

. See Appendix A of this report for more information on data usability and quality of the data sources supporting these reviews.

Sections 4.1, 4.2, and 4.3 of this report provide details of each of these reviews.

4.1 Battery Manufacturing (40 CFR Part 461)

Stakeholders raised concerns about potential wastewater discharges from new battery technologies, notably in comments submitted in response to EPA’s Final 2010 Effluent Guidelines Program Plan (76 FR 66286; U.S. EPA, 2013). Concerns centered on the recent advent of vanadium redox batteries, as well as the increased production of lithium ion batteries (including electric v ehicle batteries). As part of the 2015 Annual Review, EPA performed the following research to evaluate whether further review of the Battery Manufacturing Category is

warranted:

• Reviewed the Battery Manufacturing Point Source Category Effluent Limitations Guidelines and Standards (ELGs).

• Collected information about the current status of U.S. battery manufacturing.

• Evaluated the applicability of the existing ELGs to more recent production practices, reviewed readily available information on wastewater genera ted from these more recent production practices

.

The Battery Manufacturing ELGs (40 CFR Part 461) were promulgated in 1984. The ELGs set limits for subcategories based on the anode material: cadmium, calcium, lead, leclanché, 44 lithium, magnesium, and z inc. EPA’s review indicates that battery technologies have

44 Leclanch é is a type of zinc anode battery containing acid chloride electrolytes.

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greatly advanced since the promulgation of the Battery Manufacturing ELGs and that wastewater discharges from the manufacture of some of the new battery technologies may not be covered.
However, EP A identified little information on the manufacturing processes for these battery technologies and how they might generate wastewater. In addition, EPA identified only limited information about the extent of U.S. manufacturing of batteries that use advanced and emerging battery technologies.

The following sections provide an overview of the Battery Manufacturing ELGs applicable to current U.S. battery manufacturing, specifically consideration of two new battery technologies: vanadium redox batteries and lit hium ion batteries (including electric vehicle batteries).

4.1.1 Overview of Battery Manufacturing, the ELGs, and Current U.S. Manufacturing

Battery manufacturing encompasses the production of modular electric power sources that contain part or all of their fuel within the unit and that generate electric power directly by a chemical reaction (U.S. EPA, 1984a). There are three major components o f a battery cell (see Figure 4-1 ):

• Anode (negative electrode)

• Cathode (positive electrode)

• Electrolyte

The electrolyte separates the anode from the cathode and causes a chemical reaction that generates electrons at the anode, resulting in an electrical difference between the anode and cathode. When the electrical circuit is closed, such as when connecting the battery to a light bulb,

electrons flow from the anode to t he cathode and the battery discharges (indicated by arrows in Figure 4-1 ). Rechargeable batteries may be repeatedly discharged and recharged. During charging, electro ns flow in reverse, from the cathode to the anode, to restore the battery to its original state ( Northwestern University, 2014).

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Figure 4-1. Simplified Battery Diagram ( adapted from Northwestern University , 2014).

The Battery Manufacturing ELGs (40 CFR Part 461) are subcategorized by anode material. At the time of the rulemaking, data showed that battery cells with common process operations frequently use the same anode material, and that facilities manufac turing batteries with a common anode material generated wastewater bearing the same major pollutants (U.S. EPA, 1984a). The ELGs include seven subcategories: cadmium, calcium, lead, leclanché, lithium, magnesium, and zinc. Limitations are production normalized by the weight of the anode material, cathode material, or the entire battery cell, depending on the subcategory and

wastewater stream.

In the mid -1980s, after the Battery Manufacturing ELGs were promulgated, rechargeable batteries, including lithium i on batteries, emerged in the market (Salkind et al., 2003). Current rechargeable battery types and their common uses are listed in Table 4-1. The existing ELGs do not cover wastewater discharges from the manufacture of some types of rechargeable batteries (e.g., nickel metal hydride) because the anode materials are not accounted f or under any of the specific subcategories. In addition, rechargeable batteries are generally classified by the ions flowing between the anode and cathode, so different anode materials may be used for the same kind of battery, which would change the applic ability of the ELGs even within the same rechargeable battery type. Two kinds of rechargeable batteries, lithium ion and vanadium redox, were recently brought to EPA’s attention by stakeholders, and are further discussed below, in

Section 4.1.2.

Table 4-1 . Current Rechargeable Batteries and Common Uses

Rechargeable Battery Technology Common Uses

Lithium Ion Consumer electronic devices, portable electronics, electric and hybrid vehicles

Lithium M anganese O xide Consumer electronic devices

Nickel

- Metal Hydride (NiMH) Electric and hybrid vehicles

Nickel

- Hydrogen (NiH 2 ) Satellites and spacecraft

Vanadium Redox (Flow) Energy storage (electric grid and remote communities)

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Table 4-1 . Current Rechargeable Batteries and Common Uses

Rechargeable Battery Technology Common Uses

Nickel

- Cadmium (NiCd) Largely phased out and replaced by NiMH and other technologies

Sources: American Vanadium, 2014; Clyde Space, 2014; Energizer, 2010; Maxell, 2012; Vacuum Products Canada, Inc., 2013.

In 1984, as part of the development of the Battery Manufacturing ELGs, EPA collected information from 254 U.S. battery manufacturing facilities. At the time, 21 facilities reported having direct discharges to surface waters, 149 reported discharges to POTWs, and 84 reported zero discharges (U.S. EPA, 1984a, 1984b). From its 2015 Annual Review, EPA identified 25 active NPDES permits for battery manufacturing facilities in EPA ’s Integrated Compliance Information System – National Pollutant Discharge Elimination System (ICIS

- NPDES) 45

database , but only one battery manufacturing facility report ed DMR discharges greater than zero in 2013 ( DMRLTOutput2013_v1 ). Fifty

- eight facilities reported water releases greater than zero to TRI in 2013, 23 of wh ich reported direc t releases ( TRILTOutput2013_v1 ). Current discharge data continue to suggest that a substantial portion of battery manufacturers discharge wastewater to POTWs. The data also suggest that there are more facilities reporting releases from ba ttery manufacturing, as indicated in TRI, than are currently reporting discharges on DMRs. It should be noted, however, that the DMR and TRI data sets may not include information about all battery manufacturing facilities due to limitations of the reportin g requirements. For example, some facilities classified as minor dischargers may not be captured in the DMR data. Additionally, TRI does not include data from small establishments that do not meet reporting thresholds. Further, the reported releases in TRI may be an overestimate, as TRI reporting requirements allow facilities to base release reports on estimates, not actual measurements . For more information on the limitations of the DMR and TRI datasets, see Section 2.1

.

4.1.2 Overview of Rechargeable Batteries

Commercial and consumer uses of rechargeable batteries became widespread in the mid

1980s, after the Battery Manufacturing ELGs were promulgated. Further, with advances in hybrid and electric vehicles, the automobile industry increasingly uses rechargeable batteries. The following subsections provide a summary of the comments EPA received regarding vanadium redox, lithium ion, and other electric and hybrid vehicle batteries, in particular, as well as the information EPA has collected to date about rechargea ble batteries.

Vanadium Redox Batteries

At a National Association of Clean Water Agencies (NACWA) National Pretreatment and Pollution Prevention Workshop in 2014, attendees raised concerns about the potential growth in manufacturing of vanadium redox batt eries and the implications for wastewater management. The discussion indicated that vanadium redox batteries are currently fabricated in research and development laboratories and that all wastewater resulting from their production is

hauled off site as hazardous waste. There was further speculation that, as production of vanadium

redox batteries becomes more widely commercialized and the volume of wastewater generated

45 Queried from EPA’s Enforcement and Compliance History Online (ECHO) Water Facility search.

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increases, these facilities may begin sending wastewater to POTWs or applying for discharg e permits, as haul ing and treating larger volumes of wastewater off site becomes too expensive.

Vanadium redox or vanadium flow batteries are being developed to function as sources of energy during power outages and for use in remote areas and developing countries. These

batteries are rechargeable and generate electricity by pump ing liquid electrolytes containing vanadium ions through electrochemical cells separated by ion selective membranes (Figure 4-2) (Salkind et al., 2003). Unlike traditional batteries, flow batteries are not closed systems. This allows for potential replacement of depleted electrolyte and may result in a reduc ed rate of degradation of the anode and cathode materials (St. John, 2014). Flow batteries contain a liquid electrolyte; therefore, handling may be a concern for disposal or waste management.

Figure 4-2. Simplified Sc hematic of a Redox Flow Battery (Salkind et al., 2003)

Because of the anode material they employ (often graphite), vanadium redox batteries

may n ot be covered under the current Battery Manufacturing ELGs ( 40 CFR Part 461). However, EPA’s investigation did not identify information that vanadium redox batteries are commercially manufactured in the U.S., nor did EPA find information about vanadium redox battery manufacturing process es . Available information suggests that vanadium redox battery manufacturing in the U.S. remains limited to the research and development phase at this time

, which is consistent with the stakeholder comments (American Vanadium, 2014).

EPA identified one company in Canada, American Vanadium, which distributes German

made vanadium redox batteries in North America for electric grid energy storage. EPA searched the 2012 and 2013 Canadian National Pollutant Release Inventory (NPRI) , Canada's legislated, publicly accessible inventory of pollutant releases to air, water and land, and reviewed disposals and transfers for recycling by the company name and by industry. EPA did not find any reported

wastewater releases in the Canadian NPRI (Environment Canada, 2014). American Vanadium has an operations center in Nevada; however, sear ches of the DMR Pollutant Loading Tool by company name and location did not indicate that the facility had a NPDES permit or reported to

TRI.

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Lithium Ion Batteries

T he Association of Clean Water Administrators (ACWA) commented on EPA’s Final

2010 Effluent Guidelines Program Plan , recommending that EPA modify the battery manufacturing category to explicit ly exclude lithium ion batteries from the lithium battery subpart (U.S. EPA, 2013). No further detail was provided in the comment.

Lithium ion batteries are a type of rechargeable battery in which the lithium ions move from the anode to the cathode during discharge and from the cathode to the anode during recharge. Lithium ion battery technologies are rapidly advancing, and there are many battery types and configurations using a variety of materials for the anode, cathode, and electrolyte. In these batteries, lithium is often part of the electrolyte, which can be a solid or liquid medium (Salkind et al., 2003), and is not necessarily the anode material. Graphite or hard carbon is often used as the anode material, but lithium and lithium alloys are also used. Lithium ion batteries using silicon as the anode material are also being developed (Patterson, 2009).

The L ithium Subcategory (Subpart E) of the Battery Ma nufacturing ELGs sets limits for wastewater pollutants in lithium anode battery manufacturing discharges (40 CFR Part 461.50). The battery cells reported to be manufactured at the time of the rulemaking did not use an aqueous or liquid electrolyte. EPA noted in the 1984 Development Document for Effluent Limitations Guidelines and Standards for the Battery Manufacturing Point Source Category that there are few process wastewater sources associated with lithium anode battery manufacturing (U.S. EPA, 1984a).

Subpart E includes standards for n ew s ources ( New Source Performance Standards and Pretreatment Standards for New Sources) covering four operations: lead iodide cathodes , iron disulfide cathodes, miscellaneous wastewater streams , and air scrubbers. Miscellaneous wastewater stream sources include ancillary operations, such as cell testing, scrap disposal, cell washing, and floor and equipment washing (U.S. EPA, 1984a). The standards explicitly prohibit discharges of wastewater pollutants from any batt ery manufacturing operations not listed.

Based on the applicability of Subpart E, wastewater discharges from manufacturing of lithium ion batteries using lithium as the anode material are subject to the limits for

miscellaneous wastewater streams. This subpart, however, does not cover manufacturing of lithium ion batteries using a non- lithium anode material.

EPA identified one U.S. manufacturer of lithium ion batteries, EnerDel, Inc. (Indianapolis, IN). 46 The company does not hold NPDES permits for any of its facilities. EPA did not find further information about the extent of current U.S. lithium ion battery manufacturing or the waste streams generated during manufacture.

In April 2015, Tesla Motors announced it would begin production of the Powerwall, a rechargeable lithium -ion battery designed to store energy at individual residences for load shifting, backup power, and self -consumption of solar power generation, for delivery beginning in the late summer of 2015 (Tesla Motors, 2015a). EPA was not able to identify the anode type, based on available information. The battery is available in 7kWh and 10kWh capacities. Initial,

46 ECHO Facility Search by facility name.

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small -scale production will occur at Tesla’s Fremont, CA factory, and in 2016, production will move to Tesla’s factory in Nevada, which is currently under construction (Bomey, 2015). Tesla does not hold a NPDES permit for its Fremont, CA facility.

Electric Vehicle Battery Manufacturing

EPA received a public comment on its Final 2010 Effluent Guidelines Program Plan expressing concern abo ut potential environmental effects if electric vehicle battery manufacturing facilities were to be built in California (U.S. EPA, 2013).

Table 4-2 below summariz es th e types of batteries used in several hybrid and electric

vehicle models ; h owever, none of these batteries are currently manufactured in the U.S. Lithium ion battery technology is used in a majority of the current electric and hybrid vehicles in the U.S.

ma rket.

Table 4-2 . Rechargeable Battery Types used in Hybrid and Electric Vehicles

Car Company Model Electric Battery

Chevrolet Volt Electric Vehicle Lithium Ion Spark Electric Vehicle Lithium Ion

Honda Fit Electric Vehicle Lithium Ion Accord Hybrid Lithium Ion Insight Hybrid Nickel

- Metal Hydride Civic Hybrid 2011

– 2015 Lithium Ion Civic Hybrid 2001

– 2010 Nickel

- Metal Hydride

CR

- Z Hybrid Lithium Ion FCX Clarity Fuel Cell Electric Vehicle Lithium Ion

Tesla S Electric Vehicle Lithium Ion

Toyota Prius Hybrids Nickel

- Metal Hydride Prius Plug

- In Hybrid Lithium Ion Camry Hybrid Nickel

- Metal Hydride Avalon Hybrid Nickel

- Metal Hydride Highlander Hybrid Nickel

- Metal Hydride

Scion iQ Electric Vehicle Lithium Ion

Source s : General Motors, 2014a, 2014b; American Honda Motor Company, Inc., 2013a, 2013b, 2014, 2015a, 2015b, 2015c, 2015d; Tesla Motors, 2015c; Toyota, 2012, 2015a, 2015b, 2015c, 2015d, 2015e, 2015f, 2015g.

Tesla Motor s currently purchases lithium ion batteries for its electric vehicles from Panasonic. Tesla and Panasonic began building a large

- scale battery manufacturing facility in

Nevada in 201 4. The plant is expected to be completed in 2017 and is planned to produce 35

GWh of cells and 50 GWh of packs per year by 2020, an amount which would exceed all of the

current lithium ion battery production worldwide (Ramsey, 2014; Tesla Motors, 2015b ).

4.1.3 Summary of Findings from EPA’s Review of Battery Manufacturing

EPA’s research i ndicates that battery technologies have greatly changed since the promulgation of the Battery Manufacturing ELGs in 1984, with the advent of rechargeable batteries, including lithium ion and vanadium redox batteries. The 1984 ELGs apply to discharges from battery manufacturing facilities if the battery type they manufacture is listed as one of six manufacturing subcategories. Each subcategory is based on the type of metal used to

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manufacture the battery anodes. It is unclear at this time whether the existin g ELGs cover discharges from the manufacture of newer types of batteries because the anode materials are not covered by any of the specific ELG subcategories. In addition, rechargeable batteries are generally classified by the ions flowing between the anode and cathode, so different anode materials may be used for the same kind of battery and whether the current ELGs address discharges for this type of manufacturing is also questionable

.

However, despite the advances in technologies, battery manufacturing in the U.S. appears to have declined since the 1980s. EPA identified 58 battery manufacturing facilities that reported water releases greater than zero to TRI in 2013, 23 of which reported direct releases ( TRILTOutput2013_v1 ). EPA identified 25 NPDES permi ts for battery manufacturing facilities currently designated as active ( ICIS

- NPDES ), but only one battery manufacturing facility reporting DMR discharges greater than zero in 2013 ( DMRLTOutput2013_v1 ).

EPA identified at least one facility, a Tesla Motors plant being built in Nevada, which will be manufacturing lithium ion batteries on a large scale. In addition, stakeholders have expressed concern over potential growth in manufacturing of vanadium redox and electric vehicle batteries and its implications for wastewater management.

While the battery manufacturing industry and battery technologies are advancing, EPA has not yet identified information regarding the generation of new wastewater discharges from the manufacture of these new battery technologies. However, stakeholders expressed concerns about a resurgence of battery manufacturing in the U.S., particularly related to vanadium redox

and electric vehicle batteries. EPA has found it does not fully understand the state of the battery manufacturing industry, new battery technologies, the applicability of the existing ELGs, and the potential for new pollutants in the industry’s wastewater discharges. Specifically, EPA’s data gaps include:

• Potential future growth of the industry as reliance on electrical s torage systems

grows.

• What production processes during the manufacture of lithium ion, vanadium redox, and electric vehicle batteries generate wastewater.

• How the wastewater is managed.

• What pollutants are present in any discharges of industrial wastewater.

• Whether current U.S. battery manufacturers have changed, or plan to change, the types of batteries they produce.

• Whether there are other new battery manufacturing facilities being built in the U.S. and the types of batteries they will be producing.

4.1.4 References for Battery Manufacturing

1. American Honda Motor Company, Inc. 2013a. The 2014 Accord Plug-In. Accessed: June 11, 2015. EPA

- HQ

- OW -2015-0665. DCN 08242.

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2. American Honda Motor Company, Inc. 2013b. 2014 Fit EV. Accessed: June 11,

2015. EPA

- HQ

- OW -2015-0665. DCN 08243.

3. American Honda Motor Company, Inc. 2014. CR-Z 2015. Accessed: June 11,

2015. EPA

- HQ

- OW -2015-0665. DCN 08244.

4. American Honda Motor Company, Inc. 2015a. Accord 2015. Accessed: June 11,

2015. EPA

- HQ

- OW -2015-0665. DCN 08245.

5. Ame rican Honda Motor Company, Inc. 2015b. Civic 2015. Accessed: June 11,

2015. EPA

- HQ

- OW -2015-0665. DCN 08246.

6. American Honda Motor Company, Inc. 2015c. FCX Clarity Specifications. Accessed: June 11, 2015. EPA

- HQ

- OW -2015-0665. DCN 08247.

7. American Honda Motor Company, Inc. 2015d. 2014 Insight Specifications. Accessed: August 12, 2015. EPA

- HQ

- OW -2015-0665. DCN 08248.

8. American Vanadium. 2014. Vanadium Flow Batteries. Accessed: September 10,

2014. EPA

- HQ

- OW -2015-0665. DCN 08249.

9. Bomey, N. 2015. Tesla CEO Elon Musk reveals Powerwall home battery. Detroit

Free Press (May 1). EPA

- HQ

- OW -2015-0665. DCN 08250.

10. Clyde Space. 2014. Secondary Batteries. Accessed: September 10, 2014. EPA

HQ

- OW -2015-0665. DCN 08251.

11. Energizer. 2010. Nickel Metal Hydride (NiMH) Handbook and App lication

Manual. EPA

- HQ

- OW -2015-0665. DCN 08252.

12. Environment Canada. 2014. National Pollutant Release Inventory (NPRI) Online

Data Search. Accessed: September 10, 2014. EPA

- HQ

- OW -2015-0665. DCN

08253.

13. General Motors. 2014a. Spark EV 2015. Accessed: June 11 , 2015

. EPA

- HQ

- OW

2015-0665. DCN 08254.

14. General Motors. 2014b. Volt 2015. Accessed: June 11, 2015. EPA

- HQ

- OW

2015-0665. DCN 08255.

15. Maxell. 2012. Rechargeable Batteries Product Index. Accessed: September 10,

2014. EPA

- HQ

- OW -2015-0665. DCN 08256.

16. Northwestern University. 2014. Northwestern University Department of Electrical Engineering and Computer Science , Qualitative Reasoning Group. How do

batteries work? Accessed: September 11, 2014. EPA

- HQ

- OW -2015-0665. DCN

08257.

17. Patterson, Mary L. 2009. Ano de Materials for Lithium Ion Batteries. Powerpoint Presentation for the Indiana University Battery Workshop. (November). EPA

HQ

- OW -2015-0665. DCN 08258.

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18. Ramsey, M. 2014. Tesla confirms Nevada to g et b attery f actory

. Wall Street

Journal (September 4). EPA -HQ- OW -2015-0665. DCN 08259.

19. Salkind, A. J., Klein, M., Bullock, K. R., Pierson, J. R., and Gifford, P. R. 2003. Batteries, Other Secondary Cells . Kirk -Othmer Encyclopedia of Chemical Technology. John Wiley & Sons, Inc. (December)

. EPA

- HQ

- OW -2015-0665.

DCN 08260.

20. St. John, J. 2014. The German-American Vanadium Flow Battery Connection. Greentech Media. (February 24). EPA

- HQ

- OW -2015-0665. DCN 08261.

21. Tesla Motors. 2015a. Tesla Energy. Accessed: May 19, 2015. EPA

- HQ

- OW

2015-0665. DCN 08262.

22. Tesla Motors. 2015b. Tesla Gigafactory. Accessed: May 19, 2015. EPA

- HQ

- OW

2015-0665. DCN 08263.

23. Tesla Motors. 2015c. Model S Specifications. Accessed: August 11, 2015 . EPA

HQ

- OW -2015-0665. DCN 08264.

24. Toyota. 2012. 2013 Scion iQ EV . Accessed: Septemb er 9, 2014. EPA

- HQ

- OW

2015-0665. DCN 08265.

25. Toyota. 2015a. Avalon 2015. Accessed June 11, 2015. EPA

- HQ

- OW -2015-0665.

DCN 08266.

26. Toyota. 2015b. Camry 2015. Accessed June 11, 2015. EPA

- HQ

- OW -2015-0665.

DCN 8267.

27. Toyota. 2015c. Highlander 2015. Accessed June 11, 2015. EPA

- HQ

- OW -2015­

0665. DCN 08268.

28. Toyota. 2015d. Prius 2015. Accessed June 11, 2015. EPA

- HQ

- OW -2015-0665.

DCN 08269.

29. Toyota. 2015e. Prius c 2015. Accessed June 11, 2015. EPA

- HQ

- OW -2015-0665.

DCN 08270.

30. Toyota. 2015f. 2015 Prius Plug-In Hybrid. Accessed June 11, 2015. EPA

- HQ

OW -2015-0665. DCN 08271.

31. Toyota. 2015g. Prius v 2015. Accessed June 11, 2015. EPA

- HQ

- OW -2015-0665.

DCN 08272.

32. U.S. EPA . 1984a. Development Document for Effluent Limitations Guidelines and Standards for the Battery Manufacturing Point Source Category, Volume I. Washington, D.C. (September). EPA 440/1-84- 067

. EPA

- HQ

- OW -2015-0665.

DCN 08273.

33. U.S. EPA . 1984b. Development Document for Effluent Limitations Guidelines and Standards for the Battery Manufacturing Point Source Category, Volume II.

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Washington, D.C. (September). EPA 440/1-84- 067

. EPA

- HQ

- OW -2015-0665.

DCN 08274.

34. U.S. EPA. 2013. Response to Comments for the Final 2010 Effluent Guidelines Program Plan. Washington, D.C. (May). EPA- HQ -OW-2010-0824-0196.

35. Vacuum Products Canada, Inc. 2013. Lithium Ion Battery Manufacturing. Accessed: September 10, 2014. EPA- HQ

- OW -2015-0665. DCN 08275.

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4.2 Electrical and Electronic Components (40 CFR Part 469)

At a National Association of Clean Water Agencies (NAC WA) National Pretreatment and Pollution Prevention Workshop in 2014, stakeholders raised concerns regarding the applicability of the Electrical and Electronic Components Effluent Limitations Guidelines and Standards (E&EC ELGs) (40 CFR Part 469) to the man ufacture of sapphire crystals. Sapphire crystals are used in an increasing number of electronic devices

. Further, stakeholders expressed concern related to new pollutants of concern, specifically the use of nanomaterials in the manufacturing of electronics that EPA did not consider during the development of the E&EC ELGs. As a result, as part of the 2015 Annual Review, EPA began reviewing the E&EC ELGs, primarily as they relate to sapphire crystal manufacturing, to determine whether recent changes within the E&EC industry are resulting in new wastewater discharges or pollutants of concern

.

4.2.1 Overview of the Electrical and Electronic Components ELGs in Relation to Sapphire Crystal Manufacturing

In 1983, EPA promulgated the E&EC ELGs, which regulate pollutant discharges from four subcategories: semiconductors, electronic crystals, cathode ray tubes, and luminescent materials. Subpart B specifically covers discharges resulting from the manufacture of electronic crystals. Subpart B defines electronic crystals as “crystals or crystalline material which because of their unique structural and electronic properties are used in electronic devices. Examples of these crystals are crystals comprised of quartz, ceramic, silicon, gallium ar senide, and idium

arsenide.” In addition, manufacture of electronic crystals is defined in this subpart as “the growing of crystals and/or the production of crystal wafers for use in the manufacture of

electronic devices.” While the definition of electroni c crystals does not specifically mention sapphire crystals, sapphire crystals that are grown and made into wafers are used in the manufacture of electronic devices and thus meet the definition of electronic crystals. Therefore, 40 CFR Part 469 Subpart B is applicable to wastewater discharges generated from growing sapphire crystals and producing sapphire crystal wafers. Subpart B includes concentration- based effluent limitations for total toxic organics (TTO), arsenic, fluoride, total suspended solids (TSS)

, and pH for both new and existing direct and indirect dischargers.

In developing the ELGs, EPA identified four main types of electronic crystals: piezoelectric crystals (primarily quartz), lithium niobate, liquid crystals, and semiconducting crystals (pri marily silicon, gallium arsenide, and gallium phosphate) (U.S. EPA, 1983). At the time, EPA identified only one sapphire crystal manufacturing facility.

4.2.2 Overview of Sapphire Crystals Manufacturing and Wastewater Generation

Sapphire, the common name of the mineral corundum, is an aluminum oxide (α

- Al 2 O 3 )

gemstone that is widely used in industrial applications due to its physical properties ( Dinh

, 2011). After diamonds and silicon carbide, sapphire is one of the hardest ma terials; it is chemically inert a nd transmits light effectively ( PR Hoffman, 2013). These properties make sapphire crystals a commonly used substrate in light- emitting diodes ( LEDs ) and in solar cells, hard drives, lasers , and other optic al application s.

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Sapphire Crystal Growth

While sapp hire crystals have been produced for over a century (Harris, 2004), they were not widely used for electronics until the mid-1980s, when industry began using them as

substrates in silicon -on-sapphire microprocessors (Peregrine Semiconductor Corporation, 2012).

Due to the increased demand for sapphire crystals for smartphones, LEDs, and other electronic devices and components, sapphire crystal manufacturing has grown dramatically in recent years (Wray, 2011). The industry manufactures synthetic sapphire crystals for industrial applications by a variety of me thods, depending on the end product desired. While methods vary, they all begin with molten aluminum oxide (Al 2 O 3 ) that is formed into a large synthetic sapphire crystal

, called a boule (ClearlySapphire.com, 2014).

The generally recognized methods of sapphire crystal formation are described below . All of the methods are commonly used for sapphire crystal production, except the Edge-Defined

Film -Fed Growth (EFG) method, which does not produce crystals of high optical quality. The sapphire crystal growth processes do not generate wastewater; however, they may produce non

contact cooling water.

• Czochralski Method . In the Czochralski method, aluminum oxide is melted in a crucible and a sapphire seed crystal is dipped into it, rotated, and pulled out of the melt, promoting crystal growth (Harris, 2004). The growth process takes weeks, and the resulting crystal is used in lasers, transparent electronics, high temperature process windows, and optical applicatio ns (ClearlySapphire.com, 2014).

• EFG Method . In the EFG method, after alumin um oxide is melted in a crucible it moves up a molybdenum die, used to shape the crystal, at the bottom of the crucible by capillary attraction. A seed crystal is dipped into the melt on top of the die and the seed is pulled out, promoting crystal formation (Harris , 2004). The crystals created using this method are typically used in applications that do not require high quality crystals . (ClearlySapphire.com, 2014 ).

• Gradient Solidifi cation

. In gradient solidification, a hemispheric crucible with a sapphire seed in the bottom is filled with alumina. A temperature gradient is created in a vacuum and the seed crystal is partially melted. The slow cooling of the alumina promotes sapphire crystallization (Harris, 2004).

• Heat Exchanger Method . The heat exchanger method begins with a sapphire seed crystal placed in a crucible. The crucible is then filled with pure alumina crackle. The crackle is melted, while partially melting the seed crystal. The seed is cooled slowly and the resulting crystal is of high quality (ClearlySapphire.com, 2014; Harris, 2004).

• Kyropoulos Method . The Kyropoulos method begins with melting high- purity

alumin um oxide powder in a crucible. A seed crystal forms at the bottom and is drawn out under a highly controlled thermal gradient. The resulting boules are highly pure and can be used for electronics and optics (ClearlySapphire.com, 2014 ).

• Verneuil F lame -fusion C rystal G rowth Method

. The Verneuil method , developed in 1902, was the first method developed for industrial sap phire production. It uses powdered alumin um oxide (Al 2 O 3 ) and chromium oxide ( Cr 2 O 3 ). The powders are nearly melted and dropped onto an alumina pedestal. The seed crystal that forms is

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— Electrical and Electronic Components (40 CFR Part 469)

removed from the melt and rotated (Harris , 2004). The resulting crystal s have internal striations, so they have limited use ( ClearlySapphire.com, 2014 ).

Sapphire Crystal Wafer Production

Production of sapphire crystal wafers for electronic applications begins with a sapphire boule that can be over one hundred kilograms. The boule is sliced into wafers at a defined angle that depends on the end-use . The wafers are then lapped, ground, polished, and cleaned with a wet chemical cleaner ( PR Hoffman, 2013 ). These polished wafers are used for electronic displays, semiconductors, LEDs, and lenses whose performance can be altered by surface

features ( Dinh , 2011).

The processes used in the manufacture of sapphire crystal wafers are generally the same as in the manufacture of silicon crystal wafers, from the formation of a crystalline boule, to the slicing, lapping, grinding, polishing, and cleaning. Figure 4-3 outlines the silicon wafer production process . As indicated in the diagram, several of the wafer production processes can generate wastewater in the form of slurries and acids. Because silicon is not as hard as sapphire, the chemicals and slurries used in these processes may be different. However, th e chemicals used in the preparation of sapphire wafers have not been studied as thoroughly as silicon wafers, so available information is limited (Kirby, 2008).

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Figure 4-3. Basic M anufacturing P rocesses for Electronic Crystals ( U.S. EPA , 1983)

Lapping, grinding, and polishing of sapphire crystals often require liquid media and an abrasive (Ng and Dumm, 2012). Wafer lapping typically uses an abrasive liquid slurry mixture with lapping plates to grind off any irregularities left after slicing , and results in a smooth, unpolished surface ( Dinh , 2011). Wafer grinding may also use liquid slurries, but is more typically used for the coarse removal of material. Slurries used in these methods can be oil - or

water -based and could result in wastewater production.

Sapphire wafer polishing involves any of several processes, including: mechanical polishing, wet chemical-mechanical polishing, dry chemical-mechanical polishing, colloidal silica polishing, and contactless chemical mechanical polishing. Chemical mechanical polishing is frequently used on sapphire crystals and uses chemical slurries for corrosion and abrasives (often alumina) for mechanical fric tion ( Zhang, et al., 2010; Dinh , 2011 ). Other slurries used for the final steps of sapphire crystal production include alpha-alumina- based, scale silica

- based

, polycrystalline diamond, nanodiamond, and colloidal silica slurries ( Grish, 2011).

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Sapphire etc hing commonly uses sulfuric and phosphoric acids (Kirby, 2008), and patterning of sapphire uses strong acids (Chang, et al., 2013).

Liquid- based slurries and chemicals used in the final processing of sapphire crystal wafers may result in chemical waste dis charges. EPA reported that in the 1980s, semiconductor production used 166 million gallons of water per day, which is treated prior to discharge. Sapphire is now commonly used as a substrate for semiconductors, but the current state of wastewater discharge s from sapphire crystal wafer production is not clear. More recent data indicate that chemical and mechanical processing of electronic wafers in general (i.e., not just sapphire wafers) can produce six liters of slurry waste per individual wafer (Belongia, 1999).

Sapphire Crystal Manufacturing in the U.S.

EPA identified several companies that manufacture, process, and finish sapphire crystals in the U.S. These companies include Saint -Gobain Crystals, Rubicon Technology, and GT Advanced Technologies (GTAT, 2013; Saint-Gobain, 2009; Sterling, 2011). 47

4.2.3 Summary of Findings from EPA’s Review of the Electrical and Electronic Components ELGs in Relation to Sapphire Crystal Manufacturing

Sapphire crystals are used in an increasing number of electronic devices, and stakeholders have recently raised concerns regarding the applicability of E&EC ELGs and new pollutants discharged from sapphire crystal manufacturing. EPA’s review of the E&EC ELGs determined that Subpart B - Electronic Crystals covers wastewater disc harges generated from growing sapphire crystals and producing sapphire crystal wafers. While the ELGs do not specify sapphire crystals, they are a crystal or crystalline material used in the manufacture of electronic devices because of their unique structural and electronic properties, and therefore meet the applicability of that Subpart.

• Preliminary research indicates that sapphire crystal wafer production usually generates wastewater in the form of slurries and acids. The chemicals used in the preparation of sapphire wafers have not been thoroughly studied, so available information is limited. As a result, EPA has not yet determined the pollutants of concern or current wastewater management practices. Further, public comments expressed concern about pollutants that EPA did not consider during the development of the existing E&EC ELGs, specifically, nanomaterials. EPA confirmed that nanodiamonds are used in sapphire crystal polishing slurries. In addition, EPA

identified a number of facilities in the U.S. th at are likely manufacturing sapphire crystals and wafers. To date, EPA’s review has not definitively determined whether the manufacture of sapphire crystals and wafers result s in the discharge of pollutants not covered by 40 CFR Part 469. EPA has found it does not fully understand the state

of the E&EC industry in the U.S., including advances in technology and manufacturing processes , and potential new pollutants of concern present in wastewater discharge. Specifically, EPA’s data gaps include: What additio nal pollutants of concern may be present in discharges from sapphire crystal manufacturing that are not regulated by the existing ELGs.

47 This list is not exhaustive; it includes facilities that were easily identified through internet research.

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• How permitting authorities are currently addressing discharges from facilities that manufacture sapphire crystals.

• What manufacturing processes generate wastewater, and how the wastewater is treated, reused, and/or discharge d.

• How many facilities in the U.S. are manufacturing sapphire crystals and what is the volume of production.

4.2.4 References for Electrical and Electronic Components

1. Belongia, B. M., Sun, Y., Vaygents, J. C., Raghavan, S., and O’Sullivan, J. 1999. Treatment of CMP Waste Streams. Arizona Board of Regents for the University

of Arizona. EPA

- HQ

- OW -2015-0665. DCN 08292.

2. Chang, C-M., Shiao, M-H., Chiang, D., Yang, C-T., Huang, M-J., and Hsueh, WJ. 2013. Submicron-Size Patterning on the Sapphire Substrate Prepared by Nanosphere Lithography and Nanoimprint Lithography Techniques. Met. Mater.

Int. 19(4): 869-874. EPA

- HQ

- OW -2015-0665. DCN 08293.

3. ClearlySapphire.com. 2014. Growth. EPA

- HQ

- OW -2015-0665. DCN 08294.

4. Dinh, H. 2011. Polishing of Sapphire Substrates

. EPA

- HQ

- OW -2015-0665. DCN

08295.

5. GRISH. 2011. Beijing Grish Hitech Co., Ltd. Sapphire Wafer Lapping. EPA

- HQ

OW -2015-0665. DCN 08296.

6. GT Advan ced Technologies. 2013. Worldwide Locations. EPA

- HQ

- OW -2015­

0665. DCN 08297.

7. Harris, D.C. 2004. A Century of Sapphire Crystal Growth. Proceedings of the 10th DoD Electromagnetic Windows Symposium. Norfolk, Virginia. ( May ).

EPA

- HQ

- OW -2015-0665. DCN 08298.

8. Kirby, K.W. 2008. Processing of Sapphire Surfaces for Semiconductor Device Applications. Master of Science Thesis, Pennsylvania State University Graduate School College of Engineering. EPA

- HQ

- OW -2015-0665. DCN 08299.

9. Leavitt, P. 2014. Apple factory in Mesa ramps up sapphire production. EPA

- HQ

OW -2015-0665. DCN 08300.

10. Ng, K-Y., and Dumm, T. 2012. Advancements in Lapping and Polishing with

Diamond Slurries. CS M ANTECH Conference, April 23-26 2012, Boston,

Massachusetts. EPA

- HQ

- OW -2015-0665. DCN 08301.

11. Peregrine Semiconductor Corporation. 2012. Driving the RF SOI Revolution.

EPA

- HQ

- OW -2015-0665. DCN 08302.

12. PR Hoffman. 2013. PR Hoffman Machine Products. Sapphire Wafer Processing.

EPA

- HQ

- OW -2015-0665. DCN 08303.

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13. Saint -Gobain. 2009. Saint-Gobain Crystals Achieves ISO 9001 Certification.

EPA

- HQ

- OW -2015-0665. DCN 08304.

14. Sterling, J. 2011. Rubicon Technology: a h igh tech start

- up successfully practices strategic focus

. EPA

- HQ

- OW -2015-0665. DCN 08305.

15. U.S. EPA. 1983. Development Document for the Electrical and Electronic Components Point Source Category: Phase I. Washington, D.C. (April). EPA

HQ

- OW -2015-0665. DCN 08306.

16. Zhang, Z., Liu, W., Song, Z., and Hu, X. 2010. Two

- Step Chemical Mechanical Polishing of Sapphire Substrate. Journal of the Electrochemical Society. 157 (6):

H688-H691. EPA

- HQ

- OW -2015-0665. DCN 08307.

17. Wray, P. 2011. Sapphire crystal makers’ business on upswing. EPA

- HQ

- OW

2015-0665. DCN 08308.

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— 2- Mercaptoben z othiazole (MBT)

4.3 2- Mercaptoben z othiazole (MBT)

EPA received a public comment on its Preliminary 2012 Effluent Guidelines Program

Plan from the Association of Clean Water Administrators (ACWA) concerning the

environmental release of 2-m ercaptoben zothiazole (MBT) . The comment cited research indicating that t he chemical is highly toxic to aquatic life, slow to biodegrade, and, because it is released as tires wear, is pervasive in the environment. The comment expressed concern that this

chemical is not codified in 40 CFR Part 401.15 48 as a toxic pollutant. Th e commenter also asserts that the chemical is not captured by the TRI database, although EPA notes that this is not accurate (U.S. EPA, 2014). 49

In its response to the comment, EPA noted that the effluent guidelines program under the Clean Water Act focuses on the discharge of pollutants from industrial wastewater sources, and

that it is not necessarily the best program for addressing the environmental release of MBT from automobile tires wearing down from use on roads. Other efforts, such as pollution prevention and product substitution, under statutes such as the Toxic Substances Control Act (TSCA), may be

more appropriate to address the potential issues associated with MBT (U.S. EPA, 2014). However, as a direct fol low -up to the comment, EPA looked into this chemical as part of the 2015 Annual Review, focusing specifically on its use in tire manufacturing, and any associated potential discharge s. MBT is used in other industries, such as sodium and zinc salts of MBT,

which are active ingredients in fungicides, microbiocides, and bacteriostats (U.S. EPA, 1994).
However, these uses were outside of the scope of this review.

4.3.1 Overview of Existing ELGs Related to MBT and Rubber M anufacturing

The Rubber Manufacturing ELGs (40 CFR Part 428), specifically Subpart A, Tire and Inner Tube Plants, cover discharges from tire manufacturing. This subpart includes discharge limitations for TSS, oil and grease, and pH, but does not include limitations on toxic pollutants. EPA promul gated the Rubber Manufacturing ELGs in 1974 and has not significantly updated

them since 1975.

4.3.2 Overview of MBT

The following subsections discuss MBT’s chemical properties, use, and environmental

release.

MBT Properties

MBT is a beige or light yellow po wder that is insoluble in water. Table 4-3 below presents MBT’s properties

.

48 Provides a list of toxic pollutants designated pursuant to section 307(a)(1) of the Clean Water Act . Part 401 provides general provisions, such as definitions and test procedures that apply to additional regulations that implement the Clean Water Act.

49 EPA notes that MBT was added to the TRI list of chemicals in 1995 (U.S. EPA, 2015).

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Table 4-3 . Properties of MBT

Property Data Chemical Structure b

Molecular Formula C 7 H 5 NS 2 Molecular Weight 167.25

Melting Point 177

- 181 ̊C

Density 1.42 g/cm 3

Flash Point 243 ̊C

Water Solubility <0.1 g/100 mL at 19 ̊C 0.032 g/100 mL a

CAS Database Reference 149

- 30

- 4

Source: Chemical Book, 2014 , unless otherwise specified.

a Source for a lternative water solubility value : ChemicalLand21.com, 2015

. b Source: Sigma

- Aldrich, 2015.

MBT’s Use in Tires

Vulcanization is the process by which plastic rubber is converted into the elastic or ha rd rubber state. The process is brought about by the linking of macro- molecules at reactive sites (U.S. EPA, 1974). Vulcanization improves the mechanical properties of rubber (Rodgers , et al., 2004). In the early 1900s, researchers discovered accelerators that help control the vulcanization process and the number and type of sulfur crosslinks that form. Aniline was the first organic compound used to accelerate the reaction of sulfur with natural rubber. Since then, the industry has developed less toxic aniline derivatives that possess increased acceleration activity. MBT, one such compound, is prepared by heating aniline, carbon disulfide, and sulfur in an autoclave at elevated temperature and pressure. MBT is currently the highest volume organic accelerator used to manufacture rubber tires (Ohm, 2000). However, the use of accelerators in the U.S. has been declining due to longer-lasting tires and reduced number of U.S. manufacturers (Ohm, 2000).

MBT’s Release to the Environment

An emission scenario, published by the Organization for Economic Co-operation and Development (OECD) in 2004, evaluated the sources, use patterns, and release pathways of rubber industry chemical additives to support estimates of environmental releases (OECD, 2004). OECD specifically examined scenarios for formulation and processing emissions to wastewater, formulation and processing emissions to air and soil, and the private use of rubber products by tire abrasion, including emission to surface water and soil. Tire abrasion was the

onl y scenario that resulted in the release of MBT.

EPA’s review of available discharge data identified five facilities that reported releases of MBT to TRI in 2013, as shown in Table 4-4 below. None of these facilities are tire manufacturers, though this data set may be limited, as only facilities that manufacture and process more than 25,000 pounds, or otherwise use more than 10,000 pounds of a listed chemical in a given year, report releases to TRI ( see Section 2.1 of this report for a discussion of the limitations of TRI data) . Further, each of the reported releases of MBT from other types of rubber manufacturing are less than five pounds per year.

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EPA identified 12 tire manufacturers (by SIC Code 3011) in the U.S. reporting DMR discharges greater than zero in 2013 ( DMRLTOutput2013_v1 ). None of these facilities reported discharges of MBT . However, MBT is not a regulated pollutant in the Rubber Manufactu ring ELGs; therefore, facilities are unlikely to report MBT discharges unless their permit contains specific limitations or monitoring requirements.

Table 4-4 . Facilitie s Reporting MBT Releases to TRI in 2013

Point Source

Category NAICS Code and Description Facility Name and

Location Facility Description Pounds

MBT Organic chemicals, plastics and synthetic

fibers (OCPSF) (40 CFR Part 414) 325199

- All Other Basic Organic

Chemical Manufacturing Emerald Performance Materials LLC, Henry,

IL Produces and markets specialty chemicals for use in aerospace, food, beverages, cosmetics, toothpaste, household products, paint, tires, automobiles, and sports gear, etc. (Emerald Performance Materials, 2006) 5,480

325998

- All Other Dober Group, Hazelton

, Produces liquids for Dober 180

Miscellaneous PA Chemical’s Cooling Systems

Chemical Product and Division and GreenFloc Preparation Division (Dober, 2015)

. Manufacturing

Rubber Manufacturing (40 CFR Part 428) 326299

- All Other

Rubber Product Manufacturing International Automotive Components, Canton,

OH Produces and supplies

automotive interior components (IAC, 2015)

. 5

Gold Key Processing Inc., Middlefield, OH Develops and produces black

and non

- black rubber compounds (GoldKey, 2015)

. 2.6

326291

- Rubber Cooper Standard Produces sealing and trim 1

Product Automotive

, Inc., systems, fuel and brake Manufacturing for Auburn, IN delivery systems, and anti

Mechanical Use vibration control products for

the automotive industry (CooperStandard, 2015)

. Source: TRILTOutput2013_v1

Note: V alues are rounded to three significant figures.

4.3.3 Summary of Findings from EPA’s Review of MBT

Though tire manufacturers use MBT as a vulcanization accelerator, EPA’s review of 2013 DMR and TRI data did not identify any discharges of MBT from tire manufacturers, although there may be releases from other industries, including OCPSF and rubber manufacturing in general. In addition, concerns regarding MBT’s release to the environment have centered on dust from the abrasion and wear of tires, which is not under the purview of the effluent guidelines program.

4.3.4 References for MBT

1. Chemical Book. 2014. 2-Mercaptobenzothiaole. Accessed September 18, 2014.

EPA

- HQ

- OW -2015-0665. DCN 08278.

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2. ChemicalLand21.com. 2015. 2-M ercaptobenzothiazole. Accessed June 11, 2015.

EPA

- HQ

- OW -2015-0665. DCN 08279.

3. CooperStandard. 2015. CooperStandard Products and Innovations. EPA

- HQ

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2015-0665. DCN 08280.

4. Dober. 2015. History. EPA

- HQ

- OW -2015-0665. DCN 08281.

5. Emerald Performance Materials. 2006. Emerald Performance Materials Home.

EPA

- HQ

- OW -2015-0665. DCN 08282.

6. GoldKey. 2015. GoldKey Processing, Inc. Mixing Technology. EPA

- HQ

- OW

2015-0665. DCN 08283.

7. IAC. 2015. About International Automotive Components. EPA

- HQ

- OW -2015­

0665. DCN 08284.

8. OECD. 2004. Organisation for Economic Co- Operation and Development. Emission Scenario Document on Additives in Rubber Industry. Series on Emission Scenario Documents No. 6. (June). EPA

- HQ

- OW -2015-0665. DCN

08285.

9. Ohm, R. F. 2000. Rubber Chemicals. Kirk- Othmer Encyclopedia of Chemical Technology. EPA

- HQ

- OW -2015-0665. DCN 08286.

10. Rodgers, B., Waddell, W. H., Solis, S. and Klingensmith, W. 2004. Rubber Compounding. Kirk-Othmer Encyclopedia of Chemical Technology. EPA

- HQ

OW -2015-0665. DCN 08287.

11. Sigma -Aldrich. 2015. M3302 - 2- Mercaptobenzothiazole. Accessed June 11,

2015. EPA- HQ

- OW -2015-0665. DCN 08288.

12. U.S. EPA. 1974. Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Tire and Synthetic Segment of the Rubber Processing Point Source Category. Washington D.C. (February). EPA

440/0-174-013. EPA

- HQ

- OW -2015-0665. DCN 08289.

13. U.S. EPA. 1994. R.E.D. FACTS: Sodium and Zinc Salts of 2­ Mercaptobenzothiazole. EPA 738 -F-94-024. Washington D.C. ( September ). EPA

HQ

- OW -2015-0665. DCN 08290.

14. U.S. EPA. 2014. Response to Comments for the Preliminary 2012 Effluent Guidelines Program Plan . Washington, D.C. (September). EPA- HQ

- OW -2010­

0824-0318.

15. U.S. EPA. 2015. Changes To The TRI List Of Toxic Chemicals. Washington, D.C.

EPA

- HQ

- OW -2015-0665. DCN 08291.

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