United States 

Environmental Protection 

Agency 

The 2015 Annual Effluent
 

Guidelines Review Report
 

June 2016 
THIS PAGE INTENTIONALLY LEFT BLANK
 
 

U.S. Environmental Protection Agency
 

Office of Water (4303T)
 

1200 Pennsylvania Avenue, NW
 

Washington, DC 20460
 

EPA-821-R-16-002
 
THIS PAGE INTENTIONALLY LEFT BLANK
 
 

 

 

 

 

 

 

Table of Contents 

TABLE OF CONTENTS
 

Page 

1. INTRODUCTION TO EPA’S 2015 ANNUAL REVIEW ........................................................1-1
 

1.1 Introduction References.......................................................................................1-2
 

2. EPA’S 2015 TOXICITY RANKINGS ANALYSIS (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 PRELIMINARY CATEGORY REVIEWS .........................................................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 (potential 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
 

iv 
 

3.4 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	 Iron 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 

v 
Table 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 Selenium 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 Compound 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 Pollutants 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 Hexachlorobenzene 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
 

vi 
 

TABLE OF CONTENTS (Continued) 

Table of Contents 

Page 

4. EPA’S 2015 REVIEW OF ADDITIONAL INDUSTRIAL CATEGORIES AND 

POLLUTANTS..........................................................................................................................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 EPA’s Review of the Electrical 

and Electronic Components ELGs in Relation to Sapphire
 

Crystal Manufacturing..........................................................................4-16
 

4.2.4	 References for 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
 

vii 
List 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 Combined 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
 

viii 
 

LIST 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 Fluoride 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
 

Table 3-31. Landfills Category TRI and DMR Facility Counts and Discharges Reported 

in 2009, 2011, and 2013 ......................................................................................... 3-36
 

Table 3-32. Landfills 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
 

ix 
 

 

 

 

 

 

 

 

LIST 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 Category 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 Discharges ...... 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
 

x 
 

 

 

 

 

 

 

 

 

 

List 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 and 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 Copper 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 DMR 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
 

xi 
 

 

 

 

 

 

 

 

 

 

 

 

List 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 Manganese 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
 

xii 
 

 

 

List 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
 

xiii 
 

 

 

List 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
 

xiv 
 

 

 

 

 

 

 

 

 

1—Introduction to EPA’s 2015 Annual Review 

1. INTRODUCTION TO EPA’S 2015 ANNUAL REVIEW 

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 limits to the pollutants that facilities may discharge. To date, EPA has 

established ELGs to regulate wastewater discharges from 58 point source categories. This 

regulatory program substantially reduces industrial wastewater pollution and continues to be a 

critical aspect of the effort to clean the nation’s waters. 

In addition to developing new ELGs, the CWA requires EPA to revise existing ELGs 

when appropriate. Over the years, EPA has revised ELGs in response to developments such as 

advances in treatment technology and changes in industry processes. To continue its efforts to 

reduce industrial wastewater pollution and fulfill CWA requirements, EPA conducts an annual 

review and effluent guidelines planning process. The annual review and planning process has 

three main objectives: (1) to review existing ELGs to identify candidates for revision, (2) to 

identify new categories of direct dischargers for possible development of 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 ranking 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 weighting factors (TWFs) to the annual 

pollutant 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 

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1—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 Preliminary 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. 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

2. EPA’S 2015 TOXICITY RANKINGS ANALYSIS (TRA) 

Consistent with its odd year review methodology, 1 EPA performed a TRA of all 

industrial categories, including those subject to existing effluent limitations guidelines and 

standards (ELGs) and those not currently regulated by ELGs, to identify and prioritize for further 

review categories whose pollutant discharges 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” area 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 

Compliance Information System for the National Pollutant Discharge Elimination System (ICISNPDES), 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 classifies facilities by 

North American Industry Classification System (NAICS) code, while ICIS-NPDES classifies 

facilities by Standard Industrial Classification (SIC) codes. Thus, the Loading Tool relates each 

SIC and NAICS code to an industrial category.4 It also assigns a relative toxic weighting 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 

discharged. 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 pollutants. 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 Potential New Point 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 of the DMR Pollutant Loading Tool. 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

presented in the 2009 Screening Level Analysis (SLA) 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 

• NAICS 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 first 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 operations. Within SIC code 26, the three-digit SIC codes are used to 

distinguish the type of facility: 263 for paperboard mills, 265 for paperboard containers and 

boxes, etc. Within SIC code 265, the four-digit SIC codes are used to separate facilities by 

product type: 2652 for setup paperboard boxes, 2653 for corrugated and solid fiber boxes, etc. 

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, each establishment 

is classified according to its primary economic activity, which is determined by its principal 

product or group of products. An establishment may have activities in more than one SIC code. 

Some data collection organizations track only the primary SIC code for each establishment. 

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 descriptions. 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, EPA 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). 

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2—EPA’s 2015 Toxicity 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 discussion, 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 format 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 Division 

3-digit Subsector 2-digit Major group 

4-digit Industry group 3-digit Industry group 

5-digit NAICS industry 4-digit Industry 

6-digit U.S.-specific industry 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 Boxes; 

 2657: Folding Paperboard Boxes, Including Sanitary (except paperboard 

backs for blister or skin packages). 

In the NAICS code system the classification is more stratified: 

•	 32: Manufacturing;
 

− 322: Paper Manufacturing;
 

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 activity, which is determined by its principal product or group of products. An 

establishment may have activities in more than one NAICS code. 

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2—EPA’s 2015 Toxicity 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 NAICS code, several NAICS codes, or a portion of the facilities in one NAICS 

code. Therefore, to use data that identify facilities by NAICS 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 NAICS codes for which EPA has not established national ELGs. Table 

C-4 in Appendix C lists the NAICS codes for which facility discharge data are available in TRI, 

but for which EPA could not identify an applicable point source category. For a more detailed 

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

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 Database compiled from 

over 100 references for more than 1,900 pollutants. The Toxics Database includes aquatic life 

and human health toxicity data, as well as physical and chemical property data. Each pollutant in 

this database is identified by a unique Chemical Abstract Service (CAS) number. EPA 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-equivalents” loading (in pounds-equivalents 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 discusses 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. ICISNPDES automates entering, updating, and retrieving NPDES data, and tracks 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 have 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. 

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2—EPA’s 2015 Toxicity 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 include 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 following 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 dischargers 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 

quantities, and identifies any permit violations. During the 2015 Annual Review, EPA identified 

approximately 6,000 facilities (including sewerage systems) classified as major dischargers with 

DMR data in 2013. 

Minor dischargers may or may not adversely impact receiving water if not controlled. 

Facilities that are minor dischargers 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 dischargers. During the 2015 

Annual Review, EPA identified approximately 23,000 facilities (including sewerage systems) 

classified as minor dischargers with DMR data in 2013. 

Parameters in ICIS-NPDES include water quality parameters (such as pH and 

temperature), specific chemicals, conventional parameters (such as biochemical oxygen demand 

and total suspended solids), and flow rates. Although other pollutants may be discharged, ICISNPDES contains 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). 

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2—EPA’s 2015 Toxicity 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 facilities 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 contains 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 identify 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. 

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2—EPA’s 2015 Toxicity 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 was 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 these 

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 the 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 remains 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 meeting 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. Facilities 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 TRIcovered 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-NPDES includes a data field for applicable ELGs; however, completion of this field is not required and it is 

typically not populated. 

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2—EPA’s 2015 Toxicity 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 facilities 

2.	 Number of Employees. 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 employee” 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, processes, or otherwise uses each chemical at or above the 

appropriate activity threshold. Reporting thresholds are not based on the amount of 

release. All TRI thresholds are based on mass, not concentration. Different thresholds 

apply for persistent, bioaccumulative, toxic (PBT) chemicals than for non-PBT 

chemicals. Generally, non-PBT chemical threshold quantities are 25,000 pounds for 

manufacturing and processing activities and 10,000 pounds for other use activities. 

All thresholds are determined per chemical over the calendar year. For example, 

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 streams to 

determine the quantities of toxic chemicals released. They may estimate releases based on mass 

balance calculations, published emission factors, site-specific emission factors, or other 

approaches. Facilities are required to indicate, by a reporting code, the basis of their release 

estimate. TRI’s reporting guidance is that, for most chemicals reasonably expected to be present, 

but measured below the detection limit, facilities should use half the detection limit to estimate 

the mass released. However, TRI guidance indicates that for dioxins and dioxin-like compounds, 

non-detects should be treated as zero. 

TRI allows facilities to report releases as specific numbers or as ranges, if appropriate. 

Specific estimates are encouraged if data are available to ensure their accuracy; however, TRI 

allows facilities to report releases in the following ranges: 1 to 10 pounds, 11 to 499 pounds, and 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

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

middle 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 chemicals (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 releases can be inaccurately estimated. 

•	 Facilities are identified by NAICS code, not point source category. For some NAICS 

codes, it may be difficult or impossible to identify the point source category 

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 2015 TRA 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 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

Environmental Engineering Support for Clean Water Regulations Programmatic Quality 

Assurance Project Plan (PQAPP) describes the quality objectives in more detail (ERG, 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 compared 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 

DMR 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 facility, EPA used the following steps to review the accuracy and 

reasonableness of the loads calculated from ICIS-NPDES data: 

1.	 Reviewed 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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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

calculated annual pollutant loads and compared the results to the 2013 Loading Tool 

output data to verify the accuracy of the calculated facility loads. 

4.	 Reviewed ICIS-NPDES pipe descriptions available in EPA’s online Envirofacts data 

system, ICIS-NPDES supporting tables, or the facility’s NPDES permit and permit 

fact sheet to identify monitored pollutant discharges that are: 

− Intermittent (e.g., tidal, 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 runoff from 

nonprocess areas, noncontact 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 that 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) website11 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 are updated. 

Table 2-3 summarizes EPA’s initial quality review of the 2013 DMR data. Table D-1 in 

Appendix D lists all 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 further quality reviews of the 2013 DMR data, and made additional 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 Loading 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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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

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 were 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, 2014a). 

December 2013 flow value for outfall 001 is 

two orders of magnitude higher than other 

months. 

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, 2014a). 

The 2013 flow values reviewed for the 2015 

Annual Review do not reflect the facility 

flow correction. 

Incorporated facility flow 

correction and revised 2013 

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, 

2014a). 

Marked outfall 001 as an 

internal outfall. 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

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 PCBs Add BDL indicator to 2013 

Cropscience Chemicals, concentrations were missing a below PCBs discharges. 

USA Plastics, and 

Synthetic Fibers 

detection limit (BDL) indicator as part of 

the 2013 Annual Review (U.S. EPA, 

2014a). EPA determined 2013 PCBs 

concentrations were also missing the BDL 

indicator. 

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

Sons, 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 contact provided corrected 2013 

mercury concentrations (Schwartz and 

Wiegand, 2014). 

Revised 2013 mercury 

concentrations. 

Black Oak 

Landfill 

Hartville, 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 contact 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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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

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 for 

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 

detection. 

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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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

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 years’ 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). 

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2—EPA’s 2015 Toxicity 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 between 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 appropriate 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.	 Reviewed 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 discharges. 

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 have 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 pollutants 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.	 Contacted 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; 

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2—EPA’s 2015 Toxicity 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 sources 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 final 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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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

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

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 dioxinlike 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 releases 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 lead 

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 Facility contact confirmed that the 2013 

hydrogen sulfide release was calculated 

based on sampling results (Murphy, 2014). 

No data corrections. 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

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

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 confirmed 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. 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

2.2.2.1 Updates to the 2013 TRI Hydrogen Sulfide Data 

During its review of the 2013 TRI data, EPA noted that hydrogen sulfide water releases 

accounted for approximately 40 percent of the total 2013 TRI TWPE (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 that 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 announced 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 summarizes the reported 

2013 TRI hydrogen sulfide releases by release type (i.e., direct and indirect releases) (U.S. EPA, 

2015c). 

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

Water Releases
 

Point Source Category Total TWPE H2S TWPE 

Percentage of Total 

Category TWPE 

Attributed to H2S 

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 7,160,000 2,870,000 40% 

Source: TRILTOutput2013_v0 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

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

Type of Release 

Number of Facilities 

Reporting H2S Releases 

Pounds of Reported H2S 

Releases H2S TWPE 

Direct 146 513,000 1,440,000 

Indirect 26 511,000 1,430,000 

Total H2S Releases 172 1,024,000 2,870,000 

Total TRI TWPE 7,160,000 

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 facilities. 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 sulfide 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 removed 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” area 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. 

Because 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 ultimately released to receiving waters. 

Therefore, EPA determined it was necessary to identify a removal efficiency that it could apply 

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

removed at POTWs. 

EPA reviewed data sources historically used to develop POTW removals to establish a 

POTW removal rate for hydrogen sulfide. These data sources include: 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

•	 EPA’s National Risk Management Research Laboratory (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, these 

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) Suite12 (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 chemicals by typical activated sludge-based sewage treatment plants. 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 entered 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 wastewaters 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 Plant 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. 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

data indicate a hydrogen sulfide percent removal at the POTW ranging from 95.7 to 98.7 percent. 

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 account 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 2013 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. Additionally, 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, respectively. 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 chemical 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 TRI. 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

•	 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 categories 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 annual reviews. 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 Undergone 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 Alaskan 

seafood processing subcategories), dental practices (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—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

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 Superfund 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 presents 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. 

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2—EPA’s 2015 Toxicity 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 and Paperboard 2,190,000 321,000 2,510,000 30.1% 1 

NA Drinking Water Treatment 0 892,000 892,000 40.8% 2 

415 Inorganic Chemicals Manufacturinga 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 and Synthetic Fibersa 333,000 301,000 634,000 67.0% 

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

420 Iron and 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 and Processing 4,710 139,000 144,000 87.9% 12 

440 Ore Mining and 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 and Beverages 5,030 105,000 110,000 92.3% 

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

432 Meat and 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 and Machinery 17,400 2,010 19,400 98.6% 26 

471 Nonferrous Metals Forming and 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 and Forming 1,830 6,030 7,860 99.4% 32 

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

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

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2—EPA’s 2015 Toxicity 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 and Preserved Fruits and 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 and 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 and 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 and 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 and Stand Alone Labs 0 542 542 100.0% 49 

460 Hospitals 0 536 536 100.0% 50 

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

446 Paint Formulating 94.8 0.437 95.3 100.0% 52 

454 Gum and 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 discharges from 

facilities that produce chlorine and chlorinated hydrocarbons because EPA recently reviewed this category separately from the annual review process. 

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2—EPA’s 2015 Toxicity Rankings Analysis (TRA) 

2.5 References for EPA’s Toxicity Rankings Analysis 

1.	 Akhavein, Keisha. 2014. Telephone and Email Communication 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 Research 

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. (December 

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. 

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2—EPA’s 2015 Toxicity 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. 

(December 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 between Andrew 

Parker, Honeywell International Inc., and Kimberly 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 Research 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 Bartell, 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. 

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2—EPA’s 2015 Toxicity 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-HQOW-2015-0665. DCN 08226. 

22.	 Stanton, Neil. 2015. Telephone and Email Communication between Neil Stanton, 

Ergon West Virginia and Kimberly 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 Kimberly 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. (May). EPA-HQOW-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-HQOW-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. 

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2—EPA’s 2015 Toxicity 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. EPAHQ-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. 2012c. Toxic Weighting Factors 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-HQ-OW-2015-0665. DCN 08128. 

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2—EPA’s 2015 Toxicity 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. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.1—Prioritization of Categories for Preliminary Category Review 

3. EPA’S 2015 PRELIMINARY CATEGORY REVIEWS 

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 

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. 

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 ongoing 

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 (ICISNPDES), 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, EPA 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 discussed 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 are 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) 

• Landfills (40 CFR Part 445) 

3-1
 
 

 

 

 

 

 

 

 

 

 

3—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 Fibers (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 

Fertilizer 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 reviewed 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 are based on facility-specific permitting 

(U.S. EPA 2011, 2012, 2014). Further, fluoride discharges for the facility have decreased from 

discharge years 2011 to 2013 (534,000 TWPE in 2011, 490,000 TWPE in 2013). 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 

Chemicals 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 

3-2
 
 

 

 

 

 

 

 

 

 

3—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 outfall 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 multiplied 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 internal 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 to 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 facility 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 requirements 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 unconventional oil and gas extraction facilities were not further reviewed in EPA’s review of 

the Oil and Gas Extraction Category. 

3-3
 
 

 

 

 

 

3—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 Email 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-OW2015-0665. 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-OW2008-0517-0618. 

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. 

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. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.2—Carbon Black Manufacturing (40 CFR Part 458) 

3.2 Carbon Black Manufacturing (40 CFR Part 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 preliminary 

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 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 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 Countsa Carbon Black Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilities TRI TWPEb 

DMR 

TWPEc Total TWPE 

2009 2011 5 0 3 62,300 65.9 62,400 

2011 2013 4 0 1 27,900 0.2 27,900 

63,800d 63,800d 

2013 2015 3 0 1 38,500e 0.1 38,500e 

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 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 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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3—EPA’s 2015 Preliminary Category Reviews 

3.2—Carbon Black Manufacturing (40 CFR Part 458) 

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 the 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, Table 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 

Pollutanta 

2013 TRI Data 2011 TRI Data 

Number of Facilities 

Reporting Pollutantb 

Original 

TWPE 

Corrected 

TWPE 

Number of Facilities 

Reporting Pollutantb 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 Mercury 

Compounds 

1 0.012 0.012 1 0.012 

Carbon Black 

Category Totalc 

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 only 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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3—EPA’s 2015 Preliminary Category Reviews 

3.2—Carbon Black Manufacturing (40 CFR Part 458) 

LA15, 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 Platte, 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.
 

GrafTech 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 PAC 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-specific 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-specific 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 of 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 Data 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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3—EPA’s 2015 Preliminary Category Reviews 

3.2—Carbon Black Manufacturing (40 CFR Part 458) 

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 

revised 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 16,200 

2011 371 37,300 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 facility 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 the 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 oil, 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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3—EPA’s 2015 Preliminary Category Reviews 

3.2—Carbon Black Manufacturing (40 CFR Part 458) 

method. EPA revised the 2013 releases to reflect a facility-specific TWF to account 

for toxicity of specific the PACs discharged, which reduced the facility’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 production 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. After 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 Review. 

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). EPAHQ-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-OW2008-0517-0618. 

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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3—EPA’s 2015 Preliminary Category Reviews 

3.2—Carbon Black Manufacturing (40 CFR Part 458) 

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—EPA’s 2015 Preliminary Category Reviews 

3.3—Grain Mills (40 CFR Part 406) 

3.3 Grain Mills (40 CFR Part 406) 

EPA identified 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 the 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 relative to the other pollutants discharged by facilities in the Grain Mills Category. 

3.3.1 Grain Mills Category 2015 Toxicity Rankings Analysis 

Table 3-6 compares the toxicity rankings analyses (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 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 TRI discharge data for the Grain Mills Category. 

Table 3-6. Grain Mills Category TRI and DMR Facility Counts and Discharges Reported 

in 2009, 2011, and 2013 

Year of 

Discharge 

Year of 

Review 

Grain Mills Category Facility Countsa Grain Mills Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilities 

TRI 

TWPEb DMR TWPEc 

Total 

TWPE 

2009 2011 32 10 13 6,190 2,900 9,090 

2011 2013 23 7 18 10,500 2,810 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 2011 to 2013. This substantial increase was driven by releases of hydrogen 

sulfide reported to TRI, discussed in the sections below. The number of facilities reporting to 

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3—EPA’s 2015 Preliminary Category Reviews 

3.3—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 

EPA’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 

Pollutanta 

2013 TRI Data 2011 TRI Data 

Number of Facilities 

Reporting Pollutantb TWPE 

Number of Facilities 

Reporting Pollutantb TWPE 

Hydrogen Sulfide 7 177,000 NAc NAc 

Nitrate Compounds 13 1,100 11 1,640 

Ammonia 8 416 8 391 

Ethylene Glycol 3 141 2 331 

Lead and Lead Compounds 3 141 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 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 Hydrogen sulfide 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 sulfide 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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3—EPA’s 2015 Preliminary Category Reviews 

3.3—Grain Mills (40 CFR Part 406) 

anaerobic degradation product of both organic sulfur compounds and inorganic sulfates. Sulfides 

are 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 major 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 (H2S), 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 H2S; and at pH 5 about 

99 percent of the sulfide is present in the form of H2S (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 Review. 

Table 3-8. Top Facilities 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 

Categorya 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 (Razink, 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 samples 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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3.3—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 direct release to TRI was estimated based on the average dissolved 

sulfide concentration from four samples taken over two weeks, 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 Category. 

3.3.6 Grain Mills Category References 

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. Eastern 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. Quality Criteria for Water. Washington, D.C. (May). EPA-HQOW-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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3.3—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—EPA’s 2015 Preliminary Category Reviews 

3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

3.4 Iron and Steel Manufacturing (40 CFR Part 420) 

EPA identified the Iron and Steel Manufacturing 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 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 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) and Toxic Release Inventory (TRI) 

data and TWPE. The bottom row of Table 3-9 shows the corrected data resulting from this 

review. 

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3.4—Iron and Steel Manufacturing (40 CFR Part 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 Countsa 

Iron and Steel Manufacturing Category 

TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilities TRI TWPEb 

DMR 

TWPEc Total TWPE 

2009 2011 227 73 49 96,200 108,000d 205,000d 

2011 2013 222 76 45 82,900 214,000e 297,000e 

2013 2015 215 51 29 84,600f 188,000f 273,000f 

82,600g 182,000g 264,000g 

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 2009 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, the 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 this 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 investigated 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 discharges of PCBs, cyanide, fluoride, 

and DMR and TRI-reported discharges of lead. EPA did not investigate total residual chlorine as 

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part of the 2015 Annual 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 pollutants 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 preliminary 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 below). Sections 3.4.6 and 3.4.7 present EPA’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 

Pollutantb 

2013 DMR Dataa 2011 DMR Dataa 

Number of 

Facilities Reporting 

Pollutantc 

Original 

TWPE 

Corrected 

TWPE 

Number of 

Facilities Reporting 

Pollutantc TWPEd 

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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3—EPA’s 2015 Preliminary Category Reviews 

3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

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

Pollutanta 

2013 TRI Data 2011 TRI Data 

Number of 

Facilities Reporting 

Pollutantb 

Original 

TWPE 

Corrected 

TWPE 

Number of 

Facilities Reporting 

Pollutantb TWPE 

Nitrate Compounds 56 25,400 25,400 55 24,600 

Lead and Lead Compounds 133 22,700 20,600c 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. Therefore, 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 investigation 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 part 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, an 80-inch hot strip 

mill, 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 operation 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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3—EPA’s 2015 Preliminary Category Reviews 

3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

line, were permanently idled. The company has substantially redeveloped the site but several 

buildings remain in the sheet and tin area (Lasko, 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 discharges 

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, LLC16, 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 (DMRLTOutput2013_v1). However, the 

facility’s permit lists the permittee as Mountain State Carbon, LLC. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

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 Categorya 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 permit, 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 and 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 groupings in DMR 

(U.S. EPA, 2009). 

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3—EPA’s 2015 Preliminary Category Reviews 

3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

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, 2013b 

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 discharges. 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. 

Table 3-15 presents Mountain State Carbon’s 2013 DMR CNWAD discharges and 

NPDES monthly average 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 discharges for outfall 004 (previously outfall 005) are below permit limits. However, 

as shown in Table 3-16, the May 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 Carbon’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 months 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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3—EPA’s 2015 Preliminary Category Reviews 

3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

Table 3-15. Mountain State Carbon’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 

004a 31-Dec-13 13.2 0.013 Report Only 

Sources: DMRLTOutput2013_v1; Smith, 2015; WVDEP, 2008a; WVDEP, 2013b 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 27.8a 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 4.5a 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; WVDEP, 2013b 

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 Protection (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 facility’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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3—EPA’s 2015 Preliminary Category Reviews 

3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

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, the 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 0.840 

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 Review. 

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c 

3—EPA’s 2015 Preliminary Category Reviews 

3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

Table 3-19. Top 2013 DMR Fluoride Discharging Facilities 

Facility Name 

Facility 

Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Percent of 

Category TWPE 

U.S. Steel Gary Worksa Gary, IN 324,000 9,730 36.7% 

ArcelorMittal Weirton LLCb 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 Categoryc 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 Corporation 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 Category 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 achieve effluent fluoride 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 Works 

U.S. Steel Gary Works in Gary, IN, discharges fluoride into the Grand Calumet River 

from outfalls 005, 028, and 030 (IDEM, 2014). EPA previously reviewed fluoride discharges 

from this facility as part of the 2013 Annual Review. Outfall 005 discharges cooling 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 (IDEM, 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 that 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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3—EPA’s 2015 Preliminary Category Reviews 

3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

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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3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

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 runoff, and process wastewater 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 discharges 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 that 

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 facility’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 Average 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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3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

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 quantities and average monthly flows. The fluoride 

concentrations range from 2.17 mg/L to 4.49 mg/L. EPA determined that fluoride concentrations 

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 4.49a 

31-Jul-13 14.5 244 4.46a 

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 

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3.4—Iron and Steel Manufacturing (40 CFR Part 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 fluoride 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; DMR Loading Tool. 

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3.4—Iron and Steel Manufacturing (40 CFR Part 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 investigations of the 33 facilities with DMR lead discharges or the remaining 

132 facilities reporting TRI 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 

Released 

Pollutant 

TWPE 

Percent of 

Category TWPE 

Charter Steel Cleveland Cuyahoga Heights, OH 1,950 4,360 19.2% 

All other lead and lead compound releases in the Iron and 

Steel Manufacturing Categorya 8,170 18,300 80.8% 

Total 10,100 22,700 100% 

Source: TRILTOutput2013_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 

releases 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 stormwater releases to the Cuyahoga River. The facility does not have an individual 

NPDES permit. In addition to the direct stormwater release, the 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. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.4—Iron and Steel Manufacturing (40 CFR Part 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 DMRs and lead and lead compound releases to TRI in 

2013. 

3.4.7 Iron and Steel Manufacturing Nitrate Compound Releases in TRI 

EPA has not previously reviewed nitrate compound discharges from Iron and Steel 

Manufacturing facilities. Nitrate compounds are not regulated pollutants in the Iron 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 55 facilities reporting releases of nitrate as 

part of the 2015 Annual Review 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 

Pounds of Pollutant 

Released 

Pollutant 

TWPE 

Percent of 

Category 

TWPE 

AK Steel Corporation, Rockport Works Rockport, IN 15,900,000 11,900 46.6% 

All other nitrate-releasing facilities in the Iron and Steel 

Manufacturing Categorya 18,200,000 13,600 53.4% 

Total 34,100,000 25,400 100% 

Source: TRILTOutput2013_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a 55 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 report-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 contact 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 compounds as required for TRI reporting, the 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 

Subcategory, include limitations for Ammonia as N. 

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3.4—Iron and Steel Manufacturing (40 CFR Part 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 released (Miracle, 2015). Table 3-30 presents the nitrate 

compound releases 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: TRILTOutput2013_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 DMRs, 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 the 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 category. 

•	 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. 

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3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

−	 U.S. Steel 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 historically been the top coke producer in the U.S. 

−	 Because the 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 achievable by current technologies. One facility, ArcelorMittal 

Weirton LLC in Weirton, WV, received a revised permit in 2014 that includes 

fluoride limits for outfalls 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 lead 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 

reported 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 facilities (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, EPA 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. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.4—Iron and Steel Manufacturing (40 CFR Part 420) 

2.	 ERG. 2015. Preliminary Category Review – Facility Data Review for Point 

Source Category – 420 –Iron and Steel Manufacturing. (September). EPA-HQOW-2015-0665. DCN 08130. 

3.	 GCIP. 2002. General Chemical Industrial Products. Chapter 14 – Wastewater and 

Water Treatment. 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-HQOW-2015-0665. DCN 08131. 

5.	 IDEM. 2014. Indiana Department of Environmental Management. Amended 

NPDES Permit: U.S. Steel Gary Works, Gary, IN (IN0000281). (March 21). EPAHQ-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-OW2015-0665. 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 Kimberly 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). (February 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 of 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, 

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3.4—Iron and Steel Manufacturing (40 CFR Part 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 & Engineering, 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. 2013a. 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. NPDES 

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. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.5—Landfills (40 CFR Part 445) 

3.5 Landfills (40 CFR Part 445) 

EPA identified the Landfills 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 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 relative to the other pollutants 

discharged by facilities in the Landfills 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 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 

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 Countsa Landfills Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilities 

TRI 

TWPEb DMR TWPEc 

Total 

TWPE 

2009 2011 19 7 194 2,750 29,700d 32,400d 

2011 2013 1 5 190 42,900e 19,300 62,100 

166,000f 166,000f 

2013 2015 4 4 175 235 116,000g 116,000g 

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_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. 

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 Facility 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. 

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3—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 Concern 

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 three 

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 

Pollutantb 

2013 DMR Dataa 2011 DMR Dataa 

Number of 

Facilities Reporting 

Pollutantc 

Original 

TWPE 

Corrected 

TWPE 

Number of 

Facilities Reporting 

Pollutantc TWPE 

Cadmium 25 91,700 91,700 28 1,370 

Selenium 23 40,800 195 23 249 

Iron 138 14,500 4,910 136 5,050 

Arsenic 37 8,010 8,010 32 1,370 

Silver 9 2,270 2,270 8 1,590 

Top Pollutant 

Total NA 157,000 107,000 NA 9,630 

Landfills 

Category Total 179 166,000 116,000 195 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 

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3—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 of the 2015 Annual Review. 

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 Categorya 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 large rainstorm event during this month, 

which caused a leachate 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 Corner, 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 

Review. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.5—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 Categorya 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 reported 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 and
 

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. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.5—Landfills (40 CFR Part 445) 

Additionally, after reviewing SCGENCO/Williams 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 Hartford, 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 

remaining facilities discharging iron as part of the 2015 Annual Review. 

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 Categorya 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 mg/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 

corrected 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 Table 3-32. 

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3—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 maximum 

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	 Severity 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 classify the 

violations as SNC. 

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3—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: DMRLTOutput2013_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 leachate 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 Moncks 

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 from 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 Bluegrass 

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 Category References 

1.	 ERG. 2015. Preliminary Category Review – Facility Data Review for Point 

Source Category – 445 – Landfills. (September). EPA-HQ-OW-2015-0665. DCN 

08143. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.5—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). EPAHQ-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-OW2015-0665. 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. Williams 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. Williams Station-Highway 52 Ash Disposal 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-OW2008-0517-0618. 

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. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.5—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 Between 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. 

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3—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 category 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 any 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 Countsa Meat and Poultry Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilities 

TRI 

TWPEb DMR TWPEc 

Total 

TWPE 

2009 2011 173 38 88 53,800 17,200 71,000 

2011 2013 156 32 99 39,100 13,700d 52,800d 

2013 2015 179 29 46 81,500 8,220 89,700 

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 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. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.6—Meat and Poultry Products (40 CFR Part 432) 

As shown in Table 3-40, the total 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 facilities 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 review 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 Meat and Poultry Category. 

Table 3-41. Meat and Poultry Category Top TRI Pollutants 

Pollutanta 

2013 TRI Data 2011 TRI Data 

Number of Facilities 

Reporting Pollutantb TWPE 

Number of Facilities 

Reporting Pollutantb TWPE 

Nitrate Compounds 117 42,300 105 38,000 

Hydrogen Sulfide 11 37,700 NAc NAc 

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: TRILTOutput2013_v1 (for 2013 TWPE); TRILTOutput2011_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 Hydrogen sulfide 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 

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3—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. 

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3—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 Dataa 

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% 686b 

John Morrell & Co. Sioux Falls, SD Undetermined 2,870,000 2,150 5.07% 17.2b 

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 

Tyson 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% 251b 

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% 761b 

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), TRILTOutput2013_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 presented 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, which account for approximately 41 percent of the category’s nitrate
 

compounds 2013 TRI TWPE.
 

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3—EPA’s 2015 Preliminary Category Reviews 

3.6—Meat and Poultry Products (40 CFR Part 432) 

EPA has identified several forms of nitrogen as pollutants of concern in meat and poultry 

processing wastewaters: total Kjeldahl nitrogen (TKN), ammonia nitrogen, and nitrite plus 

nitrate-nitrogen. Because protein is a major component of both meat and blood, meat and poultry 

wastewaters can contain 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 are 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 

least seasonally, to satisfy effluent limitations for the discharge of ammonia nitrogen to surface 

waters. Many NPDES permits are written with seasonal limits for ammonia because the lower 

pH and temperature of the receiving waters during winter reduce the toxicity of ammonia by 

converting it to ammonium (U.S. EPA, 2002). 

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 

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3—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 previously). Therefore, EPA has focused on the following facilities for the 2015 

Annual Review: 

•	 Cargill Meat Solutions Corporation, Schuyler, NE 

•	 Cargill Meat Solutions Corporation, Ottumwa, IA 

•	 John Morrell & Co., Sioux Falls, SD 

•	 Pilgrim’s Pride 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 permit does not include limits for total nitrogen. The permit writer for Cargill Meat 

Solutions Corp. stated that the ammonia as N limits were more stringent than the water quality 

criteria and are based on waste load allocations (Ewoldt, 2012). The ammonia as N permit limits 

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 percent of the 2009 TRI nitrate compound TWPE (U.S. 

EPA, 2012). 

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3—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 discharged 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 outfall, 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 & Company (Sioux Falls, SD) 

As part of the 2015 Annual Review, EPA contacted the South Dakota Department of 

Environment and Natural 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 treated 

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 maximum. 

•	 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 ammonia 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) 

Average 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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3—EPA’s 2015 Preliminary Category Reviews 

3.6—Meat and Poultry Products (40 CFR Part 432) 

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) 

Average 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 amendment change since the 2012 Annual 

Review, includes limits 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 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 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, 2010a). The facility’s treatment process includes screens, 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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3—EPA’s 2015 Preliminary Category Reviews 

3.6—Meat and Poultry Products (40 CFR Part 432) 

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 five 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 facility (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. 

NA = Not applicable 

ND = Not determined 

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3—EPA’s 2015 Preliminary Category Reviews 

3.6—Meat and Poultry Products (40 CFR Part 432) 

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 

Review. 

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 sulfide releases in the Meat and 

Poultry Categorya 986 2,760 7.3% 

Total 13,500 37,700 100% 

Source: TRILTOutput2013_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 levels 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 the 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 announced 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 year 2012, including releases to water. 

EPA did not perform a TRA in 2014; therefore, EPA is reviewing hydrogen sulfide discharges 

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3—EPA’s 2015 Preliminary Category Reviews 

3.6—Meat and Poultry Products (40 CFR Part 432) 

for the first time as part of the 2015 Annual Review. EPA is focusing on hydrogen sulfide 

releases reported by direct dischargers 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, 2014. 

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 (assuming 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 Lexington 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 facility only has TRI data available (Heeb, 2015). 

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3—EPA’s 2015 Preliminary Category Reviews 

3.6—Meat and Poultry Products (40 CFR Part 432) 

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 represents 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 facilities 

whose nitrate compound TWPE increased from 2009 to 2013. Three of these facility 

permits are in compliance 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 

accurately represent potential releases 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—EPA’s 2015 Preliminary Category Reviews 

3.6—Meat and Poultry Products (40 CFR Part 432) 

3.6.6 Meat 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 

Clarification for Hydrogen Sulfide Discharges. (December 22). EPA-HQ-OW2015-0665. 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 Fresh Meats, Inc., Hillsdale, IL 

(IL0003913). (June 3). EPA-HQ-OW2010-0824-0248. 

6.	 IA DNR. 2009. Iowa Department of Natural Resources. NPDES Permit: Cargill 

Meat Solutions Corporation, Ottumwa, IA (IA0060569). (May 6). EPA-HQ-OW2015-0665. DCN 08155. 

7.	 MDEQ. 2010a. Mississippi Department of Environmental Quality. NPDES 

Permit: Tyson Food, Inc., Carthage, MS (MS0026140). (December 6). EPA-HQOW-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 Department 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 Meats, 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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3—EPA’s 2015 Preliminary Category Reviews 

3.6—Meat and Poultry Products (40 CFR Part 432) 

Hydrogen Sulfide Discharges for John Morrell & Co. (December 22). EPA-HQOW-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. Development Document for the Proposed Effluent Limitations 

Guidelines and Standards for the Meat and Poultry Products Industry Point 

Source Category. Washington, D.C. (January). EPA-821-B-01-007. EPA-HQOW-2010-0824-0233. 

16.	 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. 

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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3—EPA’s 2015 Preliminary Category Reviews 

3.7—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 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 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 Countsa Mineral Mining Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilities 

TRI 

TWPEb DMR TWPEc 

Total 

TWPE 

2009 2011 91 26 113 5,430 44,700d 50,100d 

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 decreased 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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3—EPA’s 2015 Preliminary Category Reviews 

3.7—Mineral Mining and Processing (40 CFR Part 436) 

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 pollutants 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 

Pollutantb 

2013 DMR Dataa 2011 DMR Dataa 

Number of Facilities 

Reporting Pollutantc TWPE 

Number of Facilities 

Reporting Pollutantc TWPE 

Chloride 21 45,900 25 8,990 

Aluminum 12 45,200 15 3,080 

Fluoride 13 21,700 14 11,500 

Iron 17 8,150 36 580 

Cyanide 4 7,670 6 523 

Top Pollutant Total NA 129,000 NA 24,700 

Mineral Mining 

Category Total 85 139,000 147 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 discharges 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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3—EPA’s 2015 Preliminary Category Reviews 

3.7—Mineral Mining and Processing (40 CFR Part 436) 

SES Assets accounts for 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 

Categorya 75,900,000 1,850 4% 

Total 1,880,000,000 45,900 100% 

Source: DMRLTOutput2013_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 

Categorya 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 about 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 Trucking 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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3—EPA’s 2015 Preliminary Category Reviews 

3.7—Mineral Mining and Processing (40 CFR Part 436) 

Table 3-52. SES Assets, LLC 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 from 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 Mineral 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. 

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3—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) 

Chloride 

Concentration 

(mg/L) 

Flow 

(MGD) 

Chloride 

Concentration 

(mg/L) 

Flow 

(MGD) 

Chloride 

Concentration 

(mg/L) 

Average Monthly Discharge, 2004 – 2009 

2004-2009 Average of 

Daily Avga 1.06 92,968 0.026 26,822 0.027 52,316 

2004-2009 Maximum of 

Daily Maxb 1.58 116,886 0.28 95,497 0.06 97,746 

Average Monthly Effluent, 2009 – 2014 

2009-2014 Average of 

Daily Avga 1.259 93,769 

No discharge reported 

0.148 66,857 

2009-2014 Maximum of 

Daily Maxb 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 Lake 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 fluoride discharges 

(shown in Table 3-54). EPA did not investigate the remaining 12 facilities discharging fluoride 

as part of the 2015 Annual Review. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.7—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 

Categorya 226,000 6,770 31% 

Total 722,000 21,700 100% 

Source: DMRLTOutput2013_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a 12 additional facilities submitted 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 animal-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). Table 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 Average Fluoride 

Discharges
 

Date 

Outfall 001 Outfall 002 Outfall 004 

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 

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3—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 Average Fluoride 

Discharges
 

Date 

Outfall 001 Outfall 002 Outfall 004 

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 Dock) 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 these 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. 

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3—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-HQOW-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, 

Florida Department of Environmental Protection, and Kara Edquist, Eastern 

Research Group, Inc., Re: 2013 DMR Fluoride Discharges. (May 6). EPA-HQOW-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 

Statement 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-OW2003-0074-1346 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-OW2008-0517-0618. 

9.	 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. 

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. 

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3—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 compares 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 Category TRI and DMR Facility Counts and Discharges Reported for 

2009, 2011, and 2013 

Year of 

Discharge 

Year of 

Review 

NFMM Category Facility Countsa NFMM Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilities 

TRI 

TWPEb DMR TWPEc 

Total 

TWPE 

2009 2011 121 29 19 40,500 160,000d 201,000d 

2011 2013 119 28 23 42,900 330,000e 373,000e 

2013 2015 108 18 11 34,300 187,000 221,000 

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. 

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. Additionally, 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. 

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3—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 limitations guidelines and 

standards (ELGs) (40 CFR Part 421). EPA’s investigations of reported discharges of these 

pollutants 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 

Pollutantb 

2013 DMR Dataa 2011 DMR Dataa 

Number of Facilities 

Reporting Pollutantc TWPE 

Number of Facilities 

Reporting Pollutantc TWPEd 

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 Fluoride 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 Table 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 

facilities discharging cadmium or fluoride as part of the 2015 Annual Review. 

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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 Categorya 28.6 661 0.6% 

Total 4,510 104,000 100% 

Source: DMRLTOutput2013_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 Categorya 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 metallurgically 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. Outfall 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, respectively (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 

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3.8—Nonferrous Metals Manufacturing (40 CFR Part 421) 

concentration25 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 Monthly 

Average Permit Limita 

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 8.00b 0.0159 mg/L 

SW3 30-Jun-13 0.260 NR 2.46b 0.0159 mg/L 

SW3 30-Sept-13 0.710 NR 3.71b 0.0159 mg/L 

SW3 31-Dec-13 0.120 NR 4.27b 0.0159 mg/L 

SW4 31-Mar-13 0.099 NR 0.110b 0.0159 mg/L 

SW4 30-Jun-13 0.140 NR 0.025b 0.0159 mg/L 

SW4 30-Sept-13 0.380 NR 0.280b 0.0159 mg/L 

SW4 31-Dec-13 0.098 NR 0.220b 0.0159 mg/L 

SW5 31-Mar-13 0.850 NR 0.025b 0.0159 mg/L 

SW5 30-Jun-13 1.30 NR 0.025b 0.0159 mg/L 

SW5 30-Sept-13 3.31 NR 0.050b 0.0159 mg/L 

SW5 31-Dec-13 0.850 NR 0.025b 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 0.0159 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 evaluate 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. 

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

Year Cadmium TWPE Fluoride TWPEa 

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. 

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3—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 produce 

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, accounted 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.	 Crocker, 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. 

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3—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 and 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-OW2003-0074-1346 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-HQOW-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 

Guidelines 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 2013 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. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.9—Ore Mining and Dressing (40 CFR Part 440) 

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 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 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; therefore, 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 on 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 

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 Ore Mining 

Category. 

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3.9—Ore Mining and Dressing (40 CFR Part 440) 

Table 3-65. Ore Mining Category TRI and DMR Facility Counts and Discharges
 

Reported in 2009, 2011, and 2013
 

Year of 

Discharge 

Year of 

Review 

Ore Mining Category Facility Countsa Ore Mining Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilities TRI TWPEb 

DMR 

TWPEc Total TWPE 

2009 2011 34 45 31 68,900 139,000 208,000 

2011 2013 33 53 37 72,900d 110,000 183,000d 

2013 2015 32 33 20 82,700 57,700 140,000 

Sources: TRIReleases2009_v2, DMRLoads2009_v2, and 2011 Annual Review Report (for 2009 DMR and TRI data) 

(U.S. EPA, 2012); DMRLTOutput2011_v1, TRILTOutput2011_v1, and 2013 Annual Review Report (for 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 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 Review. 

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 number 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 greater 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 five 

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 contribute 

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3—EPA’s 2015 Preliminary Category Reviews 

3.9—Ore Mining and Dressing (40 CFR Part 440) 

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. Ore Mining Category Top DMR Pollutants 

Pollutantb 

2013 DMR Dataa 2011 DMR Dataa 

Number of Facilities 

Reporting Pollutantc TWPE 

Number of Facilities 

Reporting Pollutantc 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. 

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3.9—Ore Mining and Dressing (40 CFR Part 440) 

Table 3-67. Ore Mining Category Top TRI Pollutants 

Pollutanta 

2013 TRI Data 2011 TRI Data 

Number of Facilities 

Reporting Pollutantb TWPE 

Number of Facilities 

Reporting Pollutantb TWPEc 

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.
 

NA: 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 did 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 Review. 

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3—EPA’s 2015 Preliminary Category Reviews 

3.9—Ore Mining and Dressing (40 CFR Part 440) 

Table 3-68. Top 2013 DMR Copper Discharging Facilities 

Facility Name Facility Location 

Pounds of Pollutant 

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 Categorya 5,360 3,380 24.0% 

Total 22,300 14,100 100% 

Source: DMRLTOutput2013_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 taconite27 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 facility 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 does 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 July 

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). Therefore, 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: DMRLTOutput2013_v1; DMR Loading Tool. 

27 Taconite is a low-grade iron ore. 

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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 stormwater 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 Review. 

Table 3-70. Top 2013 DMR Selenium Discharging Facilities 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Percent of 

Category TWPE 

Tilden Minea Ishpeming, MI 7,300 8,170 89.4% 

All other selenium dischargers in the Ore 

Mining Categoryb 862 965 10.6% 

Total 8,160 9,140 100% 

Source: DMRLTOutput2013_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 Mine. 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. 

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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 facility, 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 Review. 

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 Categorya 0.00000120 4.94 0.06% 

Total 0.00195 8,050 100% 

Source: DMRLTOutput2013_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 production (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 

the 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 arsenic 

in DMR or TRI as part of the 2015 Annual Review. 

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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 

Categorya 561 2,270 30.4% 

Total 1,850 7,470 100% 

Source: DMRLTOutput2013_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 Categorya 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 CFR Part 421), Utah Secondary Treatment Standards, and Utah Water Quality 

Standards (UT DEQ, 2009). 

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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: DMRLTOutput2013_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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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 discharging lead and lead compounds 

as part of the 2015 Annual Review. 

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 Categorya 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 smelting 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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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 mines 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 investigate the remaining facility 

discharging silver and silver compounds as part of the 2015 Annual Review. 

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 arsenic 

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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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 

refinery 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 

reporting 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 concentration 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 Category. 

•	 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 high arsenic TWPE likely results from the 

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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, Kennecott 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 copper 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 Department 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-OW2015-0665. 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). EPAHQ-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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7.	 MI DEQ. 2010. Michigan Department of Environmental Quality. NPDES Permit 

for Copper Range Company, White Pine, MI (MI0006114). (November 1). EPAHQ-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 

Nannini, Rio Tinto Kennecott, and Eva Knoth, Eastern Research Group, Inc., Re: 

2013 TRI Water Releases for Kennecott Utah Copper. (December 16). EPA-HQOW-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). EPAHQ-OW-2015-0665. DCN 08196. 

13.	 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-OW2008-0517-0618. 

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. (September). 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). EPAHQ-OW-2015-0665. DCN 08197. 

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

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

EPA identified the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) 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 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 analyses (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 

Discharge 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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Table 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 Countsa OCPSF Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilities 

TRI 

TWPEb DMR TWPEc 

Total 

TWPE 

2009 2011 671 169 150 146,000 491,000d 637,000d 

2011 2013 631 165 180 148,000 658,000e 806,000e 

333,000f 301,000f 634,000f 

2013 2015 651 136 144 286,000g 224,000g 510,000g 

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 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 reported 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 investigations 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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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 represents 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 Dataa 2011 DMR Dataa 

Number of Facilities 

Reporting Pollutantc 

Original 

TWPE 

Corrected 

TWPE 

Number of Facilities 

Reporting Pollutantb 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 

Pollutanta 

2013 TRI Data 2011 TRI Data 

Number of 

Facilities Reporting 

Pollutantb 

Original 

TWPE 

Corrected 

TWPE 

Number of 

Facilities Reporting 

Pollutantb TWPE 

Carbon Disulfide 10 157,000 157,000 8 5,310 

Dioxin and Dioxin-like 

Compounds 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 reviewed 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 consist of 

benzo[a]pyrene and benzo[k]fluoranthene32 discharges (shown in Table 3-82). EPA did not 

investigate the remaining facilities discharging benzo[a]pyrene, benzo[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 other pollutant dischargers in the 

OCPSF Categorya 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 facilities submitted benzo[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, Sasol 

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 North America, Inc. Lake Charles 

Chemical Complex Westlake, LA 123 12,300 76% 

ExxonMobil Chemical Co. Baytown 

Olefins Plant Baytown, TX 33 3,320 20% 

All other PACs releases in the OCPSF Categorya 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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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 – Washington 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 North America Inc. Lake Charles Chemical 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 wastewaters 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 facility 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 production 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 revised 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)anthracene. 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, 2009a. 

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 flow. 

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 reported 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 from 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 top 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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residual chlorine is not regulated under the OCPSF ELGs. As shown in Table 3-80, the 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 DMRs in 2013 and the data suggest that three of the top four 

facilities have minimum total residual chlorine 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 

Percent 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 

Categorya 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 hexachlorobenzene as part of the 2015 Annual 

Review. 

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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 Categorya 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 North 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 201837 (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, boiler 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 construction 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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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, 2009a. 

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 Company 

Nalco Company discharges hexachlorobenzene from outfall 001. The outfall has a 

continuous discharge of treated process wastewater38 (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, 2009b, 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, KathonTM/glutaraldehyde 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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percent of the 2013 DMR 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)

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 Company 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 created 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 facility 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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remediation activities, EPA expects the TCDD discharges to continue to decrease on future 

DMRs. 

The Dow Chemical Company 

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 mostly 

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 stated 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 North 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 facility 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 dioxin 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. 

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

Year Original Pounds Discharged Corrected Pounds Discharged 

2009 0.000890 0.0006 

2010 0.000898 0.000898a 

2011 0.000912 0.0006 

2012 0.000943 0.000943a 

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 Corporation 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 Categorya 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 greater 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 

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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 Preliminary Study of Carbon Discharge Discharges from 

Cellulose 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 5,820 

2010 2,080 5,820 

2011 1,920 5,380 

2012 19,000 53,300 

2013 35,400 99,000 

Source: TRILTOutput2013_v1; DMR Loading Tool. 

Innovia Films, Inc. 

Innovia Films, Inc., in Tecumseh, KS, manufactures cellophane used 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 Discharges 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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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 5,440 No data available 

2008 19,900 12,900 

2009 26,500 28,200 

2010 10,500 10,200 

2011 14,000 7,130 

2012 11,000 2,380 

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 facility 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 

monitor for carbon disulfide. The 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 POTW 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 6,270 

2010 9,280 26,000 

2011 7,880 22,100 

2012 9,920 27,800 

2013 8,800 24,600 

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 Table 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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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. Augusta, GA 4,390,000 3,280 25% 

DuPont Chambers Works Deepwater, NJ 2,320,000 1,730 13% 

All other nitrate compound releases in the OCPSF Categorya 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 at 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 treatment 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 different 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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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 Findings 

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 NPDES 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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phases of increasingly stringent pollutant limits that the facility must meet as 

construction progresses. 

−	 A facility contact at ExxonMobil, in Baytown, TX, confirmed their 2013 TRI 

PACs release and stated that the facility based its calculations on conservative 

estimates of PACs concentrations and that it is not likely that PACs are 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 facilities 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 

DMRs 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 Sasol 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 includes 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 completion 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. 

−	 The 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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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 disulfide 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 

disulfide 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 have 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 carbon 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 TRI 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-HQOW-2015-0665. DCN 08175. 

6.	 LA DEQ. 2009a. Louisiana Department of Environmental Quality. NPDES 

Permit: Sasol North America, Westlake, LA (LA0003336). (November 13). EPAHQ-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-OW2015-0665. DCN 08177. 

8.	 LA DEQ. 2014. Louisiana Department of Environmental Quality. NPDES Permit: 

Sasol North America, Westlake, LA (LA0003336). (April 29). EPA-HQ-OW2015-0665. DCN 08178. 

9.	 Northey, Scott. 2015. Telephone and Email Communication Between Scott 

Northey, DuPont Chambers Works, and Eva Knoth, Eastern Research Group, 

Inc., Re: 2013 TRI Nitrate Releases from DuPont Chamber Works, Deepwater, 

NJ. (May 7). EPA-HQ-OW-2015-0665. DCN 08179. 

10.	 Sasol. 2015. Sasol North American 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-OW2003-0074-1346 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 Standards 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. (December). EPA-821-R-06-018. EPA-HQOW-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-OW2006-0771-1701. 

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-OW2008-0517-0618. 

20.	 U.S. EPA. 2011b. Preliminary Study of Carbon Disulfide 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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24.	 VA DEQ. 2008. Virginia Department of Environmental Quality. NPDES Permit: 

Honeywell International, Inc., Hopewell, VA. (September 30). EPA-HQ-OW2014-0170-0033. 

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-HQOW-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—EPA’s 2015 Preliminary Category Reviews 

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 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 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 2015 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 relative 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 compares the toxicity rankings analyses (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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3.11—Pulp, Paper, and Paperboard (40 CFR Part 430) 

Table 3-102. Pulp and Paper Category TRI and DMR Facility Counts and Discharges 

Reported for 2009, 2011, and 2013
 

Year of 

Discharge 

Year of 

Review 

Pulp and Paper Category Facility Countsa Pulp and Paper Category TWPE 

Total of TRI 

Facilities 

Total DMR 

Major Facilities 

Total DMR 

Minor Facilities 

TRI 

TWPEb 

DMR 

TWPEc Total 

2009 2011 250 137 20 1,080,000 260,000d 1,340,000 

2011 2013 219 130 24 651,000 576,000e 1,230,000 

2,750,000 f 3,070,000 f 

2013 2015 226 110 16 1,820,000g 321,000 2,140,000g 

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. 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. 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 decreased 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 (DMRs) decreased from 2009 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 attributed 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 the 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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3.11—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 

Pollutanta 

2013 TRI Data 2011 TRI Data 

Number of Facilities 

Reporting Pollutantb 

Original 

TWPE 

Corrected 

TWPE 

Number of Facilities 

Reporting Pollutantb TWPE 

Hydrogen Sulfide 98 1,190,000 1,190,000 NAc NAc 

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 combined 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 sulfide 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 the presence, fate, and 

concentrations of hydrogen sulfide in pulp and paper mill effluents. 

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3—EPA’s 2015 Preliminary Category Reviews 

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

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

Facility Name Facility Location 

Pounds of 

Pollutant 

Released 

Pollutant 

TWPE 

Percent of 

Category TWPE 

Georgia-Pacific, Monticello Monticello, MS 115,000 323,000 27.2% 

Rocktenn Stevenson, AL 50,600 142,000 11.9% 

Alabama River Cellulose LLC Perdue Hill, AL 45,800 128,000 10.8% 

Brunswick Cellulose, Inc. Brunswick, GA 45,300 127,000 10.7% 

Rayonier Performance Fibers Jesup Mill Jesup, GA 34,600 97,000 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 

Categorya 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 releases 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 sulfide 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 with 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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3.11—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 sulfides 

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 mill effluents may be an 

overestimate. NCASI also indicated that mills are likely using similar 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 samples (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 overestimates 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 detail 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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3—EPA’s 2015 Preliminary Category Reviews 

3.11—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 investigate 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 Categorya 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.
 

International 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 Identification 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-detected values for all monitoring 

periods (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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3—EPA’s 2015 Preliminary Category Reviews 

3.11—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 DioxinLike 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: TRILTOutput2013_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 releases 

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 does 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 compound 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, since 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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3.11—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 9.30 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 discharges on quarterly measurements (U.S. EPA, 2012). 

Rayonier reported that they detected seven dioxin congeners in their effluent wastewater in 

200940 and five in 201141. In both years, two congeners were detected above EPA’s Method 

1613 MLs; however, EPA concluded 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 201542. 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 have decreased from 2009 to 2013. 

Table 3-108. Rayonier Dioxin and Dioxin-Like Compound Releases for 2009, 2011, 2013 

Year 

Pounds of Dioxin and DioxinLike Compounds Released Dioxin and Dioxin-Like Compound 

TWPE 

2009 0.011 37,800 

2011 0.016 38,900 

2013 0.0026 31,100 

Source: TRILTOutput2013_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 detected 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. 

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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 DioxinLike Compounds Released Dioxin and Dioxin-Like Compound 

TWPE 

2009 0.0015 24,900 

2011 0.0016 27,300 

2013 0.0013 21,900 

Source: TRILTOutput2013_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 category 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) reporting 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). 

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3—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 112 318,000 

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 hydrogen 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 overestimate 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 decreasing 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 

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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). EPAHQ-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. 

(December). 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-OW2003-0074-1346 through 1352. 

6.	 U.S. EPA. 2006a. Technical Support Document for the 2006 Effluent Guidelines 

Program Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQOW-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-OW2006-0771-1701. 

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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-OW2008-0517-0618. 

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-HQOW-2015-0665. DCN 08202. 

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3—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 summarizes 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 Textiles 

Category. 

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

in 2009, 2011, and 2013 

Year of 

Discharge 

Year of 

Review 

Textiles Category Facility Countsa Textiles Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilities 

TRI 

TWPEb DMR TWPEc 

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_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. 

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 

EPA’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 

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3—EPA’s 2015 Preliminary Category Reviews 

3.12—Textile Mills (40 CFR Part 410) 

pollutants with 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 presented in Sections 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 

Pollutantb 

2013 DMR Dataa 2011 DMR Dataa 

Number of Facilities 

Reporting Pollutantc TWPE 

Number of Facilities 

Reporting Pollutantc 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 (Rippy, 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 

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3—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 Monthly 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 0.01a 0.00079 

31-Jul-13 0.096 0.007a 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 0.0012a 0.00079 

31-Dec-13 0.110 0.025a 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 verify 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 also 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 

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3—EPA’s 2015 Preliminary Category Reviews 

3.12—Textile Mills (40 CFR Part 410) 

EPA reviewed 2014 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 Review. 

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 Categorya 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) for 

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 

facility’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 Monthly 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 

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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 Monthly 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 detection 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, Georgia Environmental Protection Division, and Kimberly 

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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-HQOW-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-OW2004-0032-0016. 

7.	 U.S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines 

Program Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQOW-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-OW2008-0517-0618. 

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. 

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 Review of Additional Industrial Categories and Pollutants 

4.1—Battery Manufacturing (40 CFR Part 461) 

4. EPA’S 2015 REVIEW OF ADDITIONAL INDUSTRIAL CATEGORIES AND POLLUTANTS 

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), Subpart 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 wastewater 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 

sources 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 vehicle 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 generated 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 zinc. EPA’s review indicates that battery technologies have 

44 Leclanché is a type of zinc anode battery containing acid chloride electrolytes. 

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4—EPA’s 2015 Review of Additional Industrial Categories and Pollutants 

4.1—Battery Manufacturing (40 CFR Part 461) 

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, EPA 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 lithium 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 of 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 the cathode and the battery discharges (indicated by arrows in 

Figure 4-1). Rechargeable batteries may be repeatedly discharged and recharged. During 

charging, electrons flow in reverse, from the cathode to the anode, to restore the battery to its 

original state (Northwestern University, 2014). 

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4—EPA’s 2015 Review of Additional Industrial Categories and Pollutants 

4.1—Battery Manufacturing (40 CFR Part 461) 

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 manufacturing 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 ion 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 for 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 applicability 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 Manganese Oxide Consumer electronic devices 

Nickel-Metal Hydride (NiMH) Electric and hybrid vehicles 

Nickel-Hydrogen (NiH2) 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 reported DMR discharges greater than zero 

in 2013 (DMRLTOutput2013_v1). Fifty-eight facilities reported water releases greater than zero 

to TRI in 2013, 23 of which reported direct 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 battery 

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 reporting 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 mid1980s, 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 rechargeable 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 batteries 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 discharge 

permits, as hauling 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 pumping 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 reduced 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 Schematic of a Redox Flow Battery (Salkind et al., 2003) 

Because of the anode material they employ (often graphite), vanadium redox batteries 

may not 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 processes. 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 Germanmade 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, searches 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 

The 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 explicitly 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 Lithium Subcategory (Subpart E) of the Battery Manufacturing 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 new sources (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 battery 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 about potential environmental effects if electric vehicle battery 

manufacturing facilities were to be built in California (U.S. EPA, 2013). 

Table 4-2 below summarizes the types of batteries used in several hybrid and electric 

vehicle models; however, 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. 

market. 

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 

Sources: 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 Motors 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 2014. 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 indicates 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 existing 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 permits 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 storage 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.	 American 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. EPAHQ-OW-2015-0665. DCN 08251. 

11.	 Energizer. 2010. Nickel Metal Hydride (NiMH) Handbook and Application 

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-OW2015-0665. DCN 08254. 

14.	 General Motors. 2014b. Volt 2015. Accessed: June 11, 2015. EPA-HQ-OW2015-0665. 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. Anode Materials for Lithium Ion Batteries. Powerpoint 

Presentation for the Indiana University Battery Workshop. (November). EPAHQ-OW-2015-0665. DCN 08258. 

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18.	 Ramsey, M. 2014. Tesla confirms Nevada to get battery factory. 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-OW2015-0665. DCN 08262. 

22.	 Tesla Motors. 2015b. Tesla Gigafactory. Accessed: May 19, 2015. EPA-HQ-OW2015-0665. DCN 08263. 

23.	 Tesla Motors. 2015c. Model S Specifications. Accessed: August 11, 2015. EPAHQ-OW-2015-0665. DCN 08264. 

24.	 Toyota. 2012. 2013 Scion iQ EV. Accessed: September 9, 2014. EPA-HQ-OW2015-0665. 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-HQOW-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 (NACWA) 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 manufacture 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 arsenide, 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 electronic 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 (primarily 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-Al2O3) 

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 materials; it is 

chemically inert and 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 optical applications. 

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Sapphire Crystal Growth 

While sapphire 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 methods, depending on the end product desired. While methods vary, they all 

begin with molten aluminum oxide (Al2O3) 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 noncontact 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 applications (ClearlySapphire.com, 2014). 

•	 EFG Method. In the EFG method, after aluminum 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 Solidification. 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 

aluminum 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 Flame-fusion Crystal Growth Method. The Verneuil method, developed in 

1902, was the first method developed for industrial sapphire production. It uses 

powdered aluminum oxide (Al2O3) and chromium oxide (Cr2O3). The powders are 

nearly melted and dropped onto an alumina pedestal. The seed crystal that forms is 

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removed from the melt and rotated (Harris, 2004). The resulting crystals 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, the 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 Manufacturing Processes 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 friction (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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4.2—Electrical and Electronic Components (40 CFR Part 469) 

Sapphire etching 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 discharges. 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 discharges 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 discharges 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. that are likely manufacturing sapphire 

crystals and wafers. To date, EPA’s review has not definitively determined whether 

the manufacture of sapphire crystals and wafers results 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 additional 

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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4—EPA’s 2015 Review of Additional Industrial Categories and Pollutants 

4.2—Electrical and Electronic Components (40 CFR Part 469) 

•	 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 discharged. 

•	 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-HQOW-2015-0665. DCN 08296. 

6.	 GT Advanced 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-HQOW-2015-0665. DCN 08300. 

10.	 Ng, K-Y., and Dumm, T. 2012. Advancements in Lapping and Polishing with 

Diamond Slurries. CS MANTECH 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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4—EPA’s 2015 Review of Additional Industrial Categories and Pollutants 

4.2—Electrical and Electronic Components (40 CFR Part 469) 

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 high 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). EPAHQ-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-OW2015-0665. DCN 08308. 

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4—EPA’s 2015 Review of Additional Industrial Categories and Pollutants 

4.3—2-Mercaptobenzothiazole (MBT) 

4.3 2-Mercaptobenzothiazole (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-mercaptobenzothiazole (MBT). The comment cited research 

indicating that the 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 401.1548 as a toxic pollutant. The 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 follow-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 discharges. 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 Manufacturing 

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 promulgated 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 powder 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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4—EPA’s 2015 Review of Additional Industrial Categories and Pollutants 

4.3—2-Mercaptobenzothiazole (MBT) 

Table 4-3. Properties of MBT 

Property Data Chemical Structureb 

Molecular Formula C7H5NS2 

Molecular Weight 167.25 

Melting Point 177-181 ̊C 

Density 1.42 g/cm3 

Flash Point 243 ̊C 

Water Solubility <0.1 g/100 mL at 19 ̊C 

0.032 g/100 mLa 

CAS Database Reference 149-30-4 

Source: Chemical Book, 2014, unless otherwise specified.
 a Source for alternative 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 hard 

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 

only 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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4—EPA’s 2015 Review of Additional Industrial Categories and Pollutants 

4.3—2-Mercaptobenzothiazole (MBT) 

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 Manufacturing 

ELGs; therefore, facilities are unlikely to report MBT discharges unless their permit contains 

specific limitations or monitoring requirements. 

Table 4-4. Facilities 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 antiMechanical Use vibration control products for 

the automotive industry 

(CooperStandard, 2015). 

Source: TRILTOutput2013_v1
 

Note: Values 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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4.3—2-Mercaptobenzothiazole (MBT) 

2.	 ChemicalLand21.com. 2015. 2-Mercaptobenzothiazole. Accessed June 11, 2015. 

EPA-HQ-OW-2015-0665. DCN 08279. 

3.	 CooperStandard. 2015. CooperStandard Products and Innovations. EPA-HQ-OW2015-0665. 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-OW2015-0665. 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-HQOW-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). EPAHQ-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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