# Technical Support Document for the 2010 Effluent Guidelines Program Plan

September 2011

EPA 820-R-10-021

### i CONTENTS

Page

P ART 

### I: I NTRODUCTION 

### ..................................................................................................................... I

1. B ACKGROUND 

### ................................................................................................................... 1-1

1.1 EPA’s Clean Water Act Program ........................................................................ 1-1

1.2 Background on the Effluent Guidelines Program ................................................ 1-1

1.3 What Are Effluent Limitation Guidelines and Pretreatment Standards? ............. 1-2

1.3.1 Best Practicable Control Technol ogy Currently Available (BPT) — CWA Sections 301(b)(1)( A) and 304(b)(1) ........................................ 1-3

1.3.2 Best Conventional Pollutant C ontrol Technology (BCT) — CWA Sections 301(b)(2)(E ) and 304(b)(4) ....................................................... 1-4

1.3.3 Best Available Technology Economically Achievable (BAT) — CWA Sections 301(b)(2)( A) and 304(b)(2) ............................................. 1-4

1.3.4 New Source Performance Standard s (NSPS) — CWA Section 306 ....... 1-4

1.3.5 Pretreatment Standards for Ex isting Sources (PSES) — CWA Section 307(b) .......................................................................................... 1-4

1.3.6 Pretreatment Standards for New Sources (PSNS) — CWA Section 307(c) ....................................................................................................... 1-5

1.4 Success of EPA’s Effluent Guidelines Program .................................................. 1-5

1.5 What Are EPA’s Effluent Guidelines Pl anning and Review Requirements? ...... 1-5

1.6 Background References ....................................................................................... 1-6

2. P UBLIC 

### C OMMENTS ON THE 

### F INAL 

### E FFLUENT 

### G UIDELINES 

### P ROGRAM 

### P LAN FOR


### 2008 AND 

### P RELIMINARY 

### 2010 E FFLUENT 

### G UIDELINES 

### P ROGRAM 

### P LAN 

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

3. T HE 

### E FFLUENT 

### G UIDELINES 

### P LANNING 

### P ROCESS 

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

3.1 Goals of the Effluent Guidel ines Planning Process ............................................. 3-1

3.2 Annual Review of Existing Effluent Guidelines and Pretreatment

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

3.2.1 Factors Considered in Review of Existing Effluent Guidelines and

Pretreatment Standards ............................................................................ 3-1

3.2.2 Overview: Review of Existing Point Source Categories ......................... 3-5

3.3 Identification of New Categories fo r Possible Effluent Guidelines Development ........................................................................................................ 3-7

3.3.1 Direct Discharges ..................................................................................... 3-8

3.3.2 Indirect Discharges .................................................................................. 3-8

3.4 Stakeholder Involvement and Schedule ............................................................... 3-8

3.5 The Effluent Guidelines Pla nning Process References ........................................ 3-9

4. M ETHODOLOGY



### , D ATA 

### S OURCES



### , AND 

### L IMITATIONS 

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

4.1 Data Sources and Limitations .............................................................................. 4-1

4.1.1 SIC Codes ................................................................................................ 4-2

4.1.2 NAICS Codes........................................................................................... 4-3

4.1.3 Toxic Weighting Factors.......................................................................... 4-4

4.1.4 Data from TRI .......................................................................................... 4-4

4.1.5 Data from PCS and ICIS-NPDES ............................................................ 4-7

### CONTENTS (Continued)

Page

ii 4.2 Methodology Correction Affecting Both Screening-Level Review

Databases ............................................................................................................. 4-9

4.2.1 Summary of DMRLoads2008 Database Methodology Changes ........... 4-10

4.2.2 Summary of TRIReleases2008 Databa se Methodology Changes ......... 4-13

4.3 Corrections to the DMRLoads2008 Database .................................................... 4-15

4.3.1 DMRLoads2008: Categorizati on of Discharges .................................... 4-15

4.3.2 DMRLoads2008: Internal Monitoring ................................................... 4-16

4.3.3 DMRLoads2008: Intermittent Discharges ............................................. 4-16

4.3.4 DMRLoads2008: Excluded Pollutant Parameters ................................. 4-17

4.3.5 DMRLoads2008: Pollutant Corrections ................................................ 4-17

4.3.6 DMRLoads2008: Data Quality Review ................................................. 4-17

4.3.7 DMRLoads2008: Facility Reviews........................................................ 4-20

4.4 Corrections to the TRIReleases2008 Database .................................................. 4-35

4.4.1 TRIReleases2008: Categorizati on of Discharges .................................. 4-35

4.4.2 TRIReleases2008: Pollutant Corrections ............................................... 4-36

4.4.3 TRIReleases2008: Data Quality Review ............................................... 4-37

4.4.4 TRIReleases2008: Facility Reviews ...................................................... 4-38

4.4.5 Trends in TRI Data ................................................................................ 4-43

4.5 TRIReleases2008 Rankings and DMRLoads2008 Rankings ............................. 4-43

4.6 Methodology, Data Sources, and Limitations References ................................. 4-43

PART II: RESULTS OF THE 2010 ANNUAL REVIEW OF INDUSTRIAL

CATEGORIES WITH EXISTING ELGS .......................................................................... II

5. 2010 A NNUAL 

### R EVIEW OF 

### E XISTING 

### E FFLUENT 

### L IMITATIONS 

### G UIDELINES AND


### S TANDARDS AND 

### R ANKING OF 

### P OINT 

### S OURCE 

### C ATEGORIES 

### ............................................ 5-1

5.1 Summary of the Results from the 2009 Annual Review ..................................... 5-1

5.2 Results of the 2010 Screen ing-Level Review ...................................................... 5-2

5.2.1 Categories for Which EPA is Currently Developing or Revising

ELGs ........................................................................................................ 5-2

5.2.2 Categories for Which EPA Recently Promulgated or Revised

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

5.2.3 Discharges Not Categorizable .................................................................. 5-3

5.2.4 Categories with One Facility Dominating the TWPE .............................. 5-4

5.2.5 Results of the 2010 Screen ing-Level Review .......................................... 5-4

5.3 Prioritization of Categories fo r the 2010 Annual Review ................................. 5-10

5.3.1 Detailed Study of Existing ELGs ........................................................... 5-12

5.3.2 Preliminary Category Reviews .............................................................. 5-12

5.4 2010 Annual Review References ....................................................................... 5-19

6. F ERTILIZER 

### M ANUFACTURING 

### (40 CFR P ART 

### 418) .......................................................... 6-1

6.1 Fertilizer Manufacturing Category Background .................................................. 6-1

6.1.1 Fertilizer Manufacturing Industry Profile ................................................ 6-1

6.1.2 40 CFR Part 418....................................................................................... 6-3

6.2 Fertilizer Manufacturing Category 2 010 Screening-Level Review ..................... 6-4

6.3 Fertilizer Manufacturing Categor y Pollutants of Concern ................................... 6-5

### CONTENTS (Continued)

Page

iii 6.4 Fertilizer Manufacturing Category Fl uoride Discharges in DMR ....................... 6-8

6.4.1 Top Facility Permit Compliance ............................................................ 6-10

6.4.2 Mosaic Fertilizers, LLC in Uncle Sam, LA ........................................... 6-11

6.4.3 IMC Phosphates in St. James, LA ......................................................... 6-12

6.5 Fertilizer Manufacturing Category Conclusions ................................................ 6-13

6.6 Fertilizer Manufacturing Category References .................................................. 6-14

7. I NORGANIC 

### C HEMICALS 

### M ANUFACTURING 

### (40 CFR P ART 

### 415) ....................................... 7-1

7.1 Inorganic Chemicals Category Background ........................................................ 7-1

7.1.1 Inorganic Chemicals Industry Profile ...................................................... 7-1

7.1.2 40 CFR Part 415....................................................................................... 7-5

7.2 Inorganic Chemicals Category Sc reening-Level Review .................................... 7-5

7.3 Inorganic Chemicals Category Po llutants of Concern ......................................... 7-6

7.4 Inorganic Chemicals Category Top F acility Dischargers in DMR ...................... 7-9

7.4.1 UOP LLC in Chickasaw, AL ................................................................... 7-9

7.4.2 AL State Docks Mud Lakes in Mobile, AL ........................................... 7-10

7.4.3 Elementis Chromium LP in Castle Hayne, NC ..................................... 7-11

7.4.4 Dow Chemical Pittsburg Plant in Pittsburg, OH ................................... 7-13

7.5 Inorganic Chemicals Category Conclusions ...................................................... 7-15

7.6 Inorganic Chemicals Category References ........................................................ 7-16

8. L ANDFILLS 

### (40 CFR P ART 

### 445) ........................................................................................ 8-1

8.1 Landfills Category Background ........................................................................... 8-1

8.1.1 Landfills Industry Profile ......................................................................... 8-1

8.1.2 40 CFR Part 445....................................................................................... 8-3

8.2 Landfills Category 2010 Screening-Level Review .............................................. 8-5

8.3 Landfills Pollutants of Concern ........................................................................... 8-5

8.4 Landfills Category Facility-Sp ecific DMR Review ............................................ 8-6

8.5 Landfills Category Iron Disc harges in DMR ....................................................... 8-9

8.6 Landfills Category Conclusions ......................................................................... 8-12

8.7 Landfills Category References ........................................................................... 8-13

9. M INERAL 

### M INING AND 

### P ROCESSING 

### (40 CFR P ART 

### 436) ................................................. 9-1

9.1 Mineral Mining Category Background ................................................................ 9-1

9.1.1 Mineral Mining Industry Profile .............................................................. 9-1

9.1.2 40 CFR Part 436....................................................................................... 9-7

9.2 Mineral Mining Category 2010 Scre ening-Level Review ................................... 9-8

9.3 Mineral Mining Category Pollu tants of Concern ................................................. 9-9

9.4 Mineral Mining Category Sulfid e Discharges in DMR ..................................... 9-12

9.5 Mineral Mining Category Fluorid e Discharges in DMR ................................... 9-14

9.5.1 Wastewater Sources of Fluoride ............................................................ 9-14

9.5.2 Top Facilities Discharging Fluoride ...................................................... 9-15

9.5.3 Fluoride Wastewater Treatment ............................................................. 9-20

9.6 Mineral Mining Category Ammonia as Nitrogen Discharges in DMR ............. 9-20

9.7 Mineral Mining Category Conclusions .............................................................. 9-21

9.8 Mineral Mining Category References ................................................................ 9-23

### CONTENTS (Continued)

Page

iv 10. O IL 

### & G AS 

### E XTRACTION 

### (40 CFR P ART 

### 435)................................................................. 10-1

10.1 Oil and Gas Category Background .................................................................... 10-1

10.1.1 Oil and Gas Industry Profile .................................................................. 10-1

10.1.2 40 CFR Part 435..................................................................................... 10-3

10.2 Oil and Gas Category 2010 Scr eening-Level Review ....................................... 10-4

10.3 Oil and Gas Pollutants of Concern..................................................................... 10-4

10.4 Oil and Gas Category Sulfide Discharges in DMR ........................................... 10-6

10.5 Oil and Gas Category Conclusions .................................................................... 10-7

10.6 Oil and Gas Category References ...................................................................... 10-8

11. O RE 

### M INING AND 

### D RESSING 

### (40 CFR P ART 

### 440) ........................................................... 11-1

11.1 Ore Mining and Dressing Ca tegory References ................................................ 11-2

12. O RGANIC 

### C HEMICALS



### , P LASTICS



### , AND 

### S YNTHETIC 

### F IBERS 

### (40 CFR P ART 

### 414) ............. 12-1

12.1 OCPSF Category Background ........................................................................... 12-1

12.1.1 OCPSF Industry Profile ......................................................................... 12-1

12.1.2 40 CFR Part 414..................................................................................... 12-7

12.2 OCPSF Category 2010 Screenin g-Level Review .............................................. 12-8

12.3 OCPSF Pollutants of Concern ........................................................................... 12-8

12.4 OCPSF Category Top Facility Dischargers in DMR ....................................... 12-11

12.4.1 Chevron Oronite Co. LLC in Belle Chasse, LA .................................. 12-11

12.4.2 MPM Silicones, LLC in Friendly, WV ................................................ 12-12

12.4.3 E I DuPont de Nemours & Co. in Washington, WV ........................... 12-14

12.5 OCPSF Category Chlorine Discharges in DMR .............................................. 12-15

12.5.1 Oxea Bay City Plant in Bay City, TX .................................................. 12-16

12.5.2 Channelview Complex Channelview, TX ........................................... 12-17

12.6 OCPSF Category Conclusions ......................................................................... 12-18

12.7 OCSPF Category References ........................................................................... 12-19

13. P LASTICS 

### M OLDING AND 

### F ORMING 

### (40 CFR P ART 

### 463)................................................. 13-1

13.1 PMF Category Background ............................................................................... 13-1

13.1.1 PMF Industry Profile ............................................................................. 13-1

13.1.2 40 CFR Part 463..................................................................................... 13-5

13.1.3 40 CFR Part 63 Subpart UUUU............................................................. 13-6

13.2 PMF Category 2010 Screening-Level Review .................................................. 13-6

13.3 PMF Pollutants of Concern ................................................................................ 13-7

13.4 PMF Category Chlorine Di scharges in DMR .................................................. 13-10

13.5 PMF Category Carbon Disulfide Discharges in DMR and TRI ...................... 13-11

13.5.1 Regenerated Cellulose Products .......................................................... 13-11

13.5.2 Regenerated Cellulose Facility Information ........................................ 13-12

13.5.3 Wastewater Sources of Carbon Disulfide ............................................ 13-16

13.5.4 Regenerated Cellulose Wast ewater Treatment .................................... 13-17

13.6 PMF Category Diethylhexyl Phthalate Discharges in DMR ........................... 13-17

13.7 PMF Category Conclusions ............................................................................. 13-18

13.8 PMF Category References ............................................................................... 13-19

### CONTENTS (Continued)

Page

v 14. T EXTILE 

### M ILLS 

### (40 CFR P ART 

### 410) ............................................................................... 14-1

14.1 Textiles Category Background .......................................................................... 14-1

14.1.1 Textiles Industry Profile ........................................................................ 14-1

14.1.2 40 CFR Part 414..................................................................................... 14-5

14.2 Textiles Category 2010 Screening-Level Review ............................................. 14-6

14.3 Textiles Pollutants of Concern ........................................................................... 14-7

14.4 Textiles Category Top Facility Dischargers in DMR ...................................... 14-10

14.4.1 Kawashima Textile USA, Inc. in Camden, SC .................................... 14-10

14.4.2 Kannapolis Water Treatment Pl ant in Kannapolis, NC ....................... 14-11

14.4.3 Mohawk Industries Oak River Plan t in Bennettsville, SC ................... 14-12

14.4.4 Mohawk Industries, Inc. in Lyerly, GA ............................................... 14-15

14.4.5 Deroyal Textiles in Camden, SC ......................................................... 14-15

14.5 Textiles Category Conclusions ........................................................................ 14-16

14.6 Textiles Category References .......................................................................... 14-17

15. W ASTE 

### C OMBUSTORS 

### (40 CFR P ART 

### 444) ..................................................................... 15-1

15.1 Waste Combustors Category Background ......................................................... 15-1

15.1.1 Waste Combustors Indu stry Profile ....................................................... 15-1

15.1.2 40 CFR Part 444..................................................................................... 15-3

15.2 Waste Combustors Category Screening Level Review ..................................... 15-3

15.3 Waste Combustors Category Pollutants of Concern .......................................... 15-4

15.4 Waste Combustors Hexachloroph ene Discharges in DMR ............................... 15-7

15.5 Waste Combustors Category Conclusions ......................................................... 15-7

15.6 Waste Combustors Category References ........................................................... 15-8

PART III: DETAILED STUDIES ................................................................................................. III

16. H EALTH 

### C ARE 

### I NDUSTRY AND 

### H OSPITALS 

### C ATEGORY 

### (40 CFR P ART 

### 460) ................... 16-1

16.1 Health Care Industry and Hospita ls Category References ................................. 16-2

17. O IL AND 

### G AS 

### E XTRACTION 

### (40 CFR P ART 

### 435) ............................................................. 17-1

17.1 Overview of Operations ..................................................................................... 17-1

17.2 Produced Water .................................................................................................. 17-1

17.2.1 Management of Produced Water ........................................................... 17-2

17.2.2 Treatment of Produced Waters .............................................................. 17-2

17.3 Summary of Outreach ........................................................................................ 17-2

17.4 Oil and Gas Extraction References .................................................................... 17-3

### vi LIST OF TABLES

Page

2-1 Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program Plans EPA Docket Number: EPA-HQ-OW-2008-0517 .................................................. 2-2

4-1 Nomenclature and Format of NAICS and SIC Codes ..................................................... 4-3

4-2 Number of Major and Minor Di schargers by State in DMR 2008 ................................ 4-11

4-3 Dioxin and Dioxin-Like Compounds Distribution Se lection Hierarchy for

TRIReleases2008 ............................................................................................................ 4-13

4-4 Number of Facilities As signed Each Dioxin Distributi on Hierarchy in TRI 2008 ........ 4-15

4-5 Summary of DMRLoads2008 Facility Review .............................................................. 4-21

4-6 Summary of TRIReleases2008 Facility Review ............................................................ 4-39

4-7 Number of Facilities with Data in TRI for Reporting Years 2002 Through 2008 ........ 4-43

5-1 Point Source Categories That Have Unde rgone a Recent Rulemaking or Review ......... 5-3

5-2 Point Source Categories with One Facil ity Dominating the TWPE Discharges ............. 5-6

5-3 Final TRIReleases2008 and DMRLoads2008 Combined Point Source Category Rankings ...................................................................................................................... .... 5-7

5-4 2010 Annual Review of Categories with Existing ELGs: Level of Review .................. 5-10

5-5 Previous Reviews for Categories with Preliminary Category Reviews for the 2010

Annual Review ............................................................................................................... 5 -19

6-1 Number of Fertilizer Ma nufacturing Facilities ................................................................ 6-2

6-2 Number of Fertilizer Ma nufacturing Facilities by Di scharge Classification in 2008

DMR Database ................................................................................................................. 6-3

6-3 Number of Fertilizer Manufacturing Facilities by Discharge Type in 2008 TRI

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

6-4 Subcategories in the Fertiliz er Manufacturing Category ................................................. 6-4

6-5 Fertilizer Manufacturing Category TRI and DMR Discharges for the 2006 through 2010 Screening-Level Reviews .......................................................................... 6-4

6-6 Fertilizer Manufacturing Category 2008 DM R TWPE by Discharge Classification ...... 6-5

6-7 Fertilizer Manufacturing Category Top TRI Pollutants ................................................... 6-6

### LIST OF TABLES (Continued)

Page

vii 6-8 Fertilizer Manufacturing Ca tegory Top DMR Pollutants ................................................ 6-7

6-9 Top Fluoride Discharg ing Facilities in 2007 and 2008 DMR Databases ........................ 6-9

6-10 Outfalls and Permit Information for Top Fluoride Dischargers .................................... 6-11

6-11 Mosaic Fertilizers 2008 Monthly Fluori de Discharge Data and 40 CFR Part 418 Monthly Average Limitations ........................................................................................ 6-12

6-12 IMC Phosphates 2008 Fluoride Discharges ................................................................... 6-13

6-13 IMC Phosphates Outfall 002 2008 Monthly Fluoride Discharge Data and 40 CFR Part 418 Monthly Average Limitations ......................................................................... 6-13

7-1 Number of Inorganic Chemical s Manufacturing F acilities ............................................. 7-3

7-2 Number of Inorganic Chemical Faciliti es by Facilities by Discharge Classification

in 2008 DMR Database .................................................................................................... 7-4

7-3 Number of Inorganic Chemicals F acilities by Discharge Type in 2008 TRI

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

7-4 Inorganic Chemicals Category TRI and DMR Discharges for the 2006 through 2010 Screening-Level Reviews ....................................................................................... 7-5

7-5 Inorganic Chemicals Category 2008 DMR TWPE by Discharge Classification ............ 7-6

7-6 Inorganic Chemicals Cate gory Top TRI Pollutants ......................................................... 7-7

7-7 Inorganic Chemicals Cate gory Top DMR Pollutants ...................................................... 7-8

7-8 Inorganic Chemicals Category Top Facility Dischargers in the 2008 DMR

Database ...................................................................................................................... ..... 7-9

7-9 UOP LLC 2008 Top Discharges .................................................................................... 7-10

7-10 UOP LLC Outfalls 003 and 004 2008 Monthly Aluminum Discharge Data ................ 7-10

7-11 AL State Docks Mud Lakes 2008 Merc ury and Aluminum Discharges ....................... 7-11

7-12 AL State Docks Mud Lakes Outfall 001 2008 Monthly Mercury Discharge Data ....... 7-11

7-13 Elementis Chromium LP Pl ant 2008 Top Discharges ................................................... 7-12

7-14 Elementis Chromium LP Outfa ll 001 2008 Monthly Mercury and Silver Discharge Data ............................................................................................................... 7-12

7-15 Dow Chemical Pittsburg Plant 2008 Top Discharges .................................................... 7-13

### LIST OF TABLES (Continued)

Page

viii 7-16 Dow Chemical Pittsburg Plant 2008 Monthly Copper Discharge Data ........................ 7-14

7-17 Dow Chemical Pittsburg Plan t’s 2008 Copper Discharges ........................................... 7-14

8-1 Number of Landfills ....................................................................................................... .. 8-2

8-2 Number of Landfills by Discharge Cl assification in 2008 DMR Database ..................... 8-2

8-3 Number of Landfills in the DMR Da tabase for Reporting Years 2004, 2007, and

2008........................................................................................................................... ....... 8-3

8-4 Number of Landfills by Discharg e Type in 2008 TRI Database ..................................... 8-3

8-5 Regulated Pollutants and Limits for th e Landfills Category (40 CFR Part 445) ............. 8-4

8-6 Landfills Category TRI and DMR Disc harges for the 2009 and 2010 ScreeningLevel Reviews ................................................................................................................. . 8-5

8-7 Landfills Category 2008 DMR TWPE by Discharge Classification ............................... 8-5

8-8 Landfills Category Top TR I Pollutants in 2008 ............................................................. 8-6

8-9 Landfills Category Top DMR Pollutants in 2008 ........................................................... 8-6

8-10 Data Errors Identified in the La ndfills Category in 2008 DMR Database ...................... 8-8

8-11 Corrected TWPE for Top Pollutant s in the Landfills Category in 2008 DMR

Database ...................................................................................................................... ..... 8-9

8-12 Iron Concentrations in the 2008 DMR Database Compared to Treatability

Concentrations ............................................................................................................... 8-11

9-1 Number of Mineral Mining Facilities .............................................................................. 9-2

9-2 Number of Mineral Mining Facilities .............................................................................. 9-4

9-3 Number of Mineral Mini ng Facilities by Type of Di scharger in TRI 2008 .................... 9-6

9-4 Applicability of Subcategories in the Mineral Mining Category ..................................... 9-7

9-5 Mineral Mining Category TRI and DMR Discharges for the 2010 and Previous Screening-Level Reviews ................................................................................................ 9-9

9-6 Mineral Mining Category 2008 DMR TWPE by Discharge Classification .................... 9-9

9-7 Mineral Mining Category Top TRI Pollutants............................................................... 9-10

9-8 Mineral Mining Category Top DMR Pollutants ............................................................ 9-11

### LIST OF TABLES (Continued)

Page

ix 9-9 Mineral Mining Category Top Sulfide Di scharging Facility in DMR 2008 ................. 9-12

9-10 US Silica Co. 2008 Monthly Sulfide and Flow Discharge Data .................................... 9-13

9-11 US Silica Co. 2009 and 2010 Monthly Sulfide and Flow Discharge Data .................... 9-13

9-12 Mineral Mining Category Top Fluoride Di scharging Facilities in DMR 2008 ............. 9-14

9-13 PCS Phosphates White Springs Outfall Descriptions and Fluoride Limits ................... 9-16

9-14 2008 Monthly Fluoride Concentrations and Limits for PCS Phosphates White Springs ....................................................................................................................... .... 9-16

9-15 Outfall 001 Monthly Fluoride Concentr ations and Limits for PCS Phosphates White Springs (Jasper) ................................................................................................... 9-18

9-16 2008 Monthly Fluoride Discharge Data and Limits for US Agri-Chemicals Corporation ................................................................................................................... . 9-19

9-17 Outfall 001 Monthly Fluoride Discha rge Data and Limits for Feldspar Corporation ................................................................................................................... . 9-20

9-18 Mineral Mining Category Top Ammonia as Nitrogen Discharging Facilities in

DMR 2008 ..................................................................................................................... 9-21

9-19 Glen-Gery Corporation’s 2008 Quarterl y Ammonia as N and Flow Discharge

Data .......................................................................................................................... ...... 9-21

10-1 Number of Oil and Gas Facilities .................................................................................. 10-2

10-2 Number of Oil and Gas Facilities by Discharge Type in DMR 2008 ............................ 10-2

10-3 Number of Oil and Gas Facilities in DMR Databases for Reporting Years 2004, 2007, and 2008 .............................................................................................................. 10-3

10-4 Subcategories in the Oil and Gas Category ................................................................... 10-3

10-5 Oil and Gas Category TRI and DMR Discharges for the 2006 through 2010 Screening-Level Reviews .............................................................................................. 10-4

10-6 Oil and Gas Category 2008 DMR TWPE by Discharge Classification ......................... 10-4

10-7 Oil and Gas Category Top DMR Pollutants .................................................................. 10-5

10-8 Oil and Gas Category Top Sulfide Di scharging Facilities in the 2008 DMR

Database ...................................................................................................................... ... 10-6

10-9 Marathon Oil Maverick Springs 2008 Sulfide Discharge Data ..................................... 10-7

### LIST OF TABLES (Continued)

Page

x 12-1 Number of OCPSF Facilities ......................................................................................... 12-3

12-2 Number of OCPSF Facilities by Discharge Classification in 2008 DMR Database ..... 12-5

12-3 Number of OCPSF Facilities by Type of Discharger in TRI 2008 ................................ 12-6

12-4 Applicability of Subcategor ies in the OCPSF Category ................................................ 12-7

12-5 OCPSF Category TRI and DMR Di scharges for the 2006 through 2010 Screening-Level Reviews .............................................................................................. 12-8

12-6 OCPSF Category 2008 DMR TWPE by Discharge Classification ............................... 12-8

12-7 O.CPSF Category Top TRI Pollutants ........................................................................... 12-9

12-8 OCPSF Category Top DMR Pollutants ....................................................................... 12-10

12-9 OCPSF Category Top Facility Discha rgers in the DMR 2008 Database .................... 12-11

12-10 Chevron Oronite 2008 Top Discharges ....................................................................... 12-12

12-11 Chevron Oronite Outfall 202 2008 Monthly Discharge Data ...................................... 12-12

12-12 MPM Silicones 2008 Top Discharges ......................................................................... 12-13

12-13 MPM Silicones Outfall 001 2008 Monthly Discharge Data ........................................ 12-13

12-14 E I DuPont de Nemours 2008 Top Discharges ............................................................ 12-14

12-15 E I DuPont de Nemours 2008 Mont hly PACs Discharge Data ................................... 12-15

12-16 OCSPF Category Top Chlorine Discharging Facilities in the 2008 DMR Database .. 12-15

12-17 Oxea Bay City 2008 Monthly Chlorine and Flow Discharge Data ............................. 12-16

12-18 Channelview Complex 2008 Monthly Chlo rine and Flow Discharge Data and

Maximum Chlorine Permit Limitations ....................................................................... 12-17

13-1 Number of PMF Facilities ............................................................................................. 13- 3

13-2 Number of PMF Facilities by Discharge Classification in 2008 DMR Database ......... 13-4

13-3 Number of PMF Facilities by Disc harge Type in 2008 TRI Database .......................... 13-5

13-4 PMF Category TRI and DMR Discharges for the 2006 through 2010 ScreeningLevel Reviews ................................................................................................................ 13-7

13-5 PMF Category 2008 DMR TWPE by Discharge Classification .................................... 13-7

### LIST OF TABLES (Continued)

Page

xi 13-6 PMF Category Top TRI Pollutants ................................................................................ 13-8

13-7 PMF Category Top DMR Pollutants ............................................................................. 13-9

13-8 PMF Category Chlorine Discharging Facilities in 2008 DMR Database .................... 13-10

13-9 Kinetico, Inc. 2008 Monthly Chlorine and Flow Discharge Data ............................... 13-11

13-10 Cellulose Manufacturers in the United States ............................................................. 13-13

13-11 2008 TRI and DMR Discharges for Cellulose Products Manufacturing Facilities ..... 13-14

13-12 Innovia Films 2008 Monthly Carbon Disulfide Discharge Data ................................. 13-15

13-13 Cellulose Products Facilities Wastewater Treatment .................................................. 13-17

13-14 PMF Category Diethylhexyl Phthalat e Discharging Facilities in 2008 DMR

Database ...................................................................................................................... . 13-17

13-15 Flexco Corp. 2008 Monthly Diethylhe xyl Phthalate Discharge Data ......................... 13-18

14-1 Number of Textiles Facilities ......................................................................................... 14 -3

14-2 Number of Textiles Fac ilities by Discharge Classificati on in 2008 DMR Database .... 14-4

14-3 Number Textiles Facilities by Disc harge Type in 2008 TRI Database ......................... 14-5

14-4 Applicability of Subcategorie s in the Textiles Category ............................................... 14-6

14-5 Textiles Category TRI and DM R Discharges for the 2006 through 2010 Screening-Level Reviews .............................................................................................. 14-7

14-6 Textiles Category 2008 DMR TWPE by Discharge Classification ............................... 14-7

14-7 Textiles Category Top TRI Pollutants ........................................................................... 14-8

14-8 Textiles Category Top DMR Pollutants ........................................................................ 14-9

14-9 Textiles Category Top Pollutant and Facility Dischargers in DMR 2008 ................... 14-10

14-10 Kawahima Textile 2008 Top Discha rges in the DMR Database ................................. 14-11

14-11 Kawashima Textile USA 2008 Monthly Me rcury and Flow Discharge Data ............. 14-11

14-12 Kannapolis WTP 2008 Top Discharg es in the DMR Database ................................... 14-12

14-13 Kannapolis WTP 2008 Monthly Al uminum Discharge Data ...................................... 14-12

### LIST OF TABLES (Continued)

Page

xii 14-14 Mohawk Industries Oak River Plant 2008 T op Discharges in the DMR Database ..... 14-13

14-15 Mohawk Industries Oak River Plant 2008 Monthly Toxaphene Discharge Data ....... 14-14

14-16 Mohawk Industries Oak River Plant 2009 and 2010 Monthly Toxaphene Discharge Data ............................................................................................................. 14 -14

14-17 Mohawk Industries 2008 Top Discha rges in the DMR Database ................................ 14-15

14-18 Mohawk Industries 2008 Monthl y Sulfide Discharge Data ........................................ 14-15

14-19 Deroyal Textiles 2008 Top Discharges in the DMR Database .................................... 14-16

14-20 Deroyal Textiles 2008 Monthly Aldrin Discharge Data .............................................. 14-16

15-1 Number of Facilities in Waste Combustors Category ................................................... 15-2

15-2 Number of Waste Combus tor Facilities by Type of Discharger in DMR 2008 ............ 15-2

15-3 Waste Combustor Facilities by Discharge Type in 2008 TRI Database ....................... 15-3

15-4 Applicability of Subcategories in the Waste Combustor Category ............................... 15-3

15-5 Waste Combustors Category TRI a nd DMR Discharges for the 2006 through 2010 Screening-Level Reviews ..................................................................................... 15-4

15-6 Waste Combustors Category 2008 DMR TW PE by Discharge Classification ............. 15-4

15-7 Waste Combustors Category Top TRI Pollutants .......................................................... 15-5

15-8 Waste Combustors Categor y Top DMR Pollutants ....................................................... 15-6

15-9 Clean Harbors Deer Park 2008 Monthly Hexachlorophene Discharge Data ................ 15-7

### xiii LIST OF FIGURES

Page

1-1 Regulations of Direct and Indi rect Wastewater Discharges ............................................ 1-3

3-1 Flow Chart of Annual Review of Existing ELGs ............................................................ 3-2

3-2 Flow Chart of Further Review of Existing ELGs ............................................................ 3-3

3-3 Flow Chart of Identifica tion of Possible New ELGs ....................................................... 3-4Part I – Introduction



# PART I: INTRODUCTIONSection 1 – Background



### 1-1 This document supports the Final 2010 Effluent Guidelines Program Plan. It presents the methodology used to perform the annual reviews of industrial discharges required by the Clean Water Act and the results of the reviews.

1. B ACKGROUND



### This section explains how th e Effluent Guidelines Program fits into EPA’s National Water Program, describes the general and legal background of the Effluent Guidelines Program, and describes EPA’s process for making effluent guidelines revision and development decisions (i.e., effluent guide lines planning).

1.1 EPA’s Clean Water Act Program

EPA’s Office of Water is responsible for de veloping the programs and tools authorized under the Clean Water Act (CWA), which enables EP A and the states to pr otect and restore the Nation’s waters. These programs and tools generally rely either on water quality-based controls, such as water quality standard s and water quality-based effluent limitations, or technology-based controls, such as effluent guidelines and technology-based effluent limitations.

The CWA gives states the primary responsibil ity for establishing, reviewing, and revising water quality standards. These st andards consist of designated uses for each water body (e.g., fishing, swimming, supporting aquatic lif e), numeric pollutant concentr ation limits (“criteria”) to protect those uses, and an an tidegradation policy. EPA develops national criteria for many pollutants, which states may adopt or modify as appropriate to reflect local conditions. In a parallel track to water quality standards, EPA also develops technology-based effluent limitation guidelines and standards (ELGs), based on curren t available technologies . These guidelines and standards are then incorporated into discharge permits as tech nology-based effluent limitations (U.S. EPA, 1996). While technology-based effluent limitations in discharge permits may be as stringent as or more stringent than water-quality-based effluent limits, the effluent guidelines program is not specifically designed to ensure that the discharge from each facility meets the water quality standards of its receiving water body. For this reason, the CWA also requires states to establish water-quality-based permit limitations, where necessary to attain and maintain water quality standards. These water-quality-based li mits may require industr ial facilities to meet requirements that are more stringent than thos e in a national effluent guideline regulation. EPA notes that the various components of water-qual ity-based permitting (water quality standards, water-quality-based effluent limits, and total ma ximum daily loads) are in different stages of development nationally and by state, which may re sult in different leve ls of protection across states. Therefore, national categorical efflue nt limitations and standards remain a critical component of EPA’s CWA Program. Consequently, in the overall c ontext of the CWA, effluent guidelines must be viewed as one tool in the broad arsenal of tools C ongress provided to EPA and the states to protect and restore the Nation’s water quality.

1.2 Background on the Effluent Guidelines Program

The 1972 CWA marked a distinct change in Co ngress’s efforts “to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.” See CWA § 101(a), 33 U.S.C. § 1251(a). Prior to 1972, the CWA relied on “water quality standards.” This approach was challenging, however, because it was very di fficult to prove that a specific discharger was responsible for decreasing the water quality of its receiving stream.Section 1 – Background



### 1-2 The 1972 CWA directed EPA to promulgate effl uent guidelines that reflect pollutant reductions that can be achieved by categories or subcategories of industrial point sources. The effluent guidelines are based on specific techno logies (including proce ss changes) that EPA identifies as meeting the statutorily prescribed level of control. See CWA sections 301(b)(2), 304(b), 306, 307(b), and 307(c). Unli ke other CWA tools, effluent guidelines are national in scope and establish pollution cont rol obligations for all facilitie s that discharge wastewater within an industrial category or subcategory. In establishing these controls, EPA assesses: (1) the performance and availability of the best pollu tion control technologies or pollution prevention practices for an industrial category or subcategor y as a whole; (2) the eco nomic achievability of those technologies, which can include considerati on of costs, effluent reduction benefits, and affordability of achieving the reduction in pollutant discharge; (3) non-water-quality environmental impacts (including energy requiremen ts); and (4) such other factors as the EPA Administrator deems appropriate.

Creating a single national pollution control requirement for each industrial category based on the best technology the industry could afford was seen by Congress as a way to reduce the potential creation of “polluti on havens” and to set the Nation’ s sights on attaining the highest possible level of water quality. Consequently, EPA’s goal in establis hing national effluent guidelines is to ensure that indus trial facilities with si milar characteristics, regardless of their location or the nature of their receiving wate r, will at a minimum meet similar effluent limitations representing the perfor mance of the best pollution c ontrol technologies or pollution prevention practices.

Unlike other CWA tools, effluent guidelines provide the opportunity to promote pollution prevention and water conservation. This may be pa rticularly important in controlling persistent, bioaccumulative, and toxic pollutants discharged in concentrations below analytic detection levels. Effluent guidelines also control pollutant discharges at the point of discharge from

industrial facilities a nd cover discharges directly to su rface water (direct discharges) and discharges to publicly owned treatment works (P OTWs) (indirect discharges). For industrial dischargers to POTWs, this can have the added benefit of preventing the untreated discharge of pollutants to groundwater from leaking sewer pipe s or to surface waters due to combined sewer

overflows.

1.3 What Are Effluent Limitation Guidelines and Pretreatment Standards?

The national clean water industrial regulatory program is authorized under sections 301, 304, 306, and 307 of the CWA.

The CWA directs EPA to promulgate ELG s through six levels of control:

1. Best practicable control technol ogy currently available (BPT);

2. Best available control technology economically achievable (BAT);

3. Best conventional contro l technology (BCT);

4. New source performance standards (NSPS);

5. Pretreatment standards for existing sources (PSES); and

6. Pretreatment standards for new sources (PSNS).

For point sources that discharge po llutants directly into the wate rs of the United States (direct dischargers), the limitations and standard s promulgated by EPA are implemented throughSection 1 – Background



### National Pollutant Discharge Elimination Syst em (NPDES) permits. See CWA sections 301(a), 301(b), and 402. For sources that discharge to PO TWs (indirect dischargers), EPA promulgates pretreatment standards that appl y directly to those sources and are enforced by POTWs and state

and federal authorities. See CW A sections 307(b) and (c). Figure 1-1 illustrates the relationship between the regulation of direct and indirect dischargers.

Figure 1-1. Regulations of Direct a nd Indirect Wastewater Discharges

1.3.1 Best Practicable Control Technology Cu rrently Available (BPT) — CWA Sections 301(b)(1)(A) and 304(b)(1)

EPA develops effluent limitations base d on BPT for conventional, toxic, and nonconventional pollutants. S ection 304(a)(4) designates th e following as conventional pollutants: biochemical oxygen demand (BOD 5 

### ), total suspended solids, fecal coliform, pH, and any additional pollutants defi ned by the Administrator as conventional. The Administrator designated oil and grease as an additional c onventional pollutant on July 30, 1979. See 44 FR 44501 (July 30, 1979). EPA has identified 65 polluta nts and classes of pollutants as toxic pollutants, of which 126 specific substances have been designated priority toxic pollutants. See Appendix A to Part 423, reprinted after 40 CFR Part 423.17. All other pollu tants are considered

to be nonconventional.

In specifying BPT, EPA looks at a number of factors. EPA firs t considers the total cost of applying the control technology in relation to the effluent reduc tion benefits. The Agency also considers the age of the equipment and facili ties, the processes employed and any required process changes, engineeri ng aspects of the control t echnologies, non-water-quality environmental impacts (including energy requir ements), and such other factors the EPA Administrator deems appropriate. See CWA secti on 304(b)(1)(B). Traditionally, EPA establishes BPT effluent limitations based on the average of th e best performances of facilities within the industry of various ages, sizes, processes, or other common characteri stics. Where existing

1-3Section 1 – Background



### 1-4 performance is uniformly inadequate, BPT may reflect higher levels of cont rol than currently in place in an industrial category if the Agency de termines that the technology can be applied practically.

1.3.2 Best Conventional Pollutant Control Technology (BCT) — CWA Sections 301(b)(2)(E) and 304(b)(4)

The 1977 amendments to the CWA required EPA to identify effluent reduction levels for conventional pollutants associated with BCT fo r discharges from existing industrial point

sources. In addition to the other factors specified in section 304( b)(4)(B), the CWA requires that

EPA establish BCT limitations afte r consideration of a two-part “cost-reasonableness” test. EPA explained its methodology for the developmen t of BCT limitations in 1986. See 51 FR 24974 (July 9, 1986).

1.3.3 Best Available Technology Economica lly Achievable (BAT) — CWA Sections 301(b)(2)(A) and 304(b)(2)

For toxic pollutants and nonconventional polluta nts, EPA promulgates effluent guidelines based on BAT. See CWA sections 301(b)(2)(C), (D), and (F). The f actors considered in assessing BAT include the cost of achieving BA T effluent reductions, the age of equipment and facilities involved, the process employed, pot ential process changes, non-water-quality environmental impacts (including energy requir ements), and such other factors the EPA Administrator deems appropriate. See CWA sec tion 304(b)(2)(B). The technology must also be economically achievable. See CWA section 301(b)(2 )(A). In addition to e nd-of-pipe wastewater treatment, BAT limitations may be based on efflue nt reductions attainable through changes in a facility’s processes and operations. Where exis ting performance is uniformly inadequate, BAT may reflect a higher level of performance than is currently being achieved within a particular subcategory based on technology tr ansferred from a different s ubcategory or category. BAT may be based upon process changes or internal c ontrols, even when thes e technologies are not common industry practice.

1.3.4 New Source Performance Standards (NSPS) — CWA Section 306

NSPS reflect effluent reducti ons that are achievable base d on the best available demonstrated control technology. New sources have the opportunity to instal l the best and most efficient production processes and wastewater treatment technologies. As a result, NSPS should represent the most stringent cont rols attainable through the application of the best available demonstrated control technology for all polluta nts (i.e., conventional, nonconventional, and priority pollutants). In establis hing NSPS, EPA is directed to take into consideration the cost of achieving the effluent reduction and any non-water-quality envi ronmental impacts and energy requirements.

1.3.5 Pretreatment Standards for Existing Sources (PSES) — CWA Section 307(b)

PSES apply to indirect dischargers and are desi gned to prevent the di scharge of pollutants that pass through, interfer e with, or are otherwise incompatib le with the operation of POTWs, including wastewater conveyan ce and sludge disposal. Pretreat ment standards are technologybased and are analogous to BAT ef fluent limitations guidelines.Section 1 – Background



### 1-5 The General Pretreatment Regulations, whic h set forth the framework for implementing national pretreatment standard s, are found at 40 CFR Part 403.

1.3.6 Pretreatment Standards for New So urces (PSNS) — CWA Section 307(c)

Like PSES, PSNS apply to indirect discha rgers and are designed to prevent the discharges of pollutants that pa ss through, interfere with, or are otherwise incompatible with the operation of POTWs. PSNS are to be issued at the same time as NSPS. Ne w indirect dischargers have the opportunity to incorporate into th eir plants the best available demonstrated technologies. The Agency considers the same f actors in promulgating PSNS as it considers in promulgating NSPS.

1.4 Success of EPA’s Effluent Guidelines Program

The Effluent Guidelines Program has helped reverse the water quality degradation that accompanied industrialization in this country. Permits developed using the technology-based industrial regulations ar e a critical element of the Nation’s clean water program and reduce the discharge of pollutants that have serious envi ronmental impacts, including pollutants that:

• 

### Kill or impair fish and other aquatic organisms;

• 

### Cause human health problems through contaminated water, fish, or shellfish; and

• 

### Degrade aquatic ecosystems.

EPA has issued effluent guidelines for 57 i ndustrial categories and these regulations apply to between 35,000 and 45,000 facilities that disc harge directly to the Nation’s waters, as well as another 12,000 facilities th at discharge to POTWs. These regulations have prevented the discharge of more than 700 billion pounds of toxic pollutants each year.

1.5 What Are EPA’s Effluent Guidelines Planning and Review Requirements?

In addition to establishing new regulati ons, the CWA also requires EPA to review existing effluent guidelines annuall y. EPA reviews all point source categories subject to existing effluent guidelines and pretreat ment standards to identify potential candidates for revision, as required by CWA sections 304(b), 301(d), 304(g), and 307(b). This document explains how EPA uses reported discharge data and other fact ors to conduct this review. EPA also reviews industries consisting of direct disc harging facilities not currently s ubject to effluent guidelines to identify potential candidates for effluent guidelines rulemakings, as required by CWA section 304(m)(1)(B). Finally, EPA reviews industries consis ting entirely or almost entirely of indirect discharging facilities that are not currently subject to pretreatment standards to identify potential candidates for pretreatment standards developm ent, as required by CW A sections 304(g) and 307(b).

CWA section 304(m)(1)(A) requi res EPA to publish an Effluent Guidelines Program Plan (Plan) every two years that establishes a schedule for the annual review and revision, in accordance with section 304(b), of the effluent gui delines that EPA has promulgated under that section. EPA’s Final 2010 Plan pr esents the results of the sec tion 304(b) reviews. The schedule

is as follows: EPA will coordinate its annual revi ew of existing effluent guidelines under section 304(b) with its publication of the preliminary and final Plans under CWA section 304(m). In other words, in odd numbered years, EPA intends to complete its annual review upon publicationSection 1 – Background



### 1-6 of the preliminary Plan that EPA must publ ish for public review and comment under CWA section 304(m)(2). In even numbered years, EPA intends to complete its annual review upon the publication of the final Plan. EPA’s 2010 annual review is the review cycle ending upon the publication of this Final 2010 Plan.

EPA is coordinating its annual reviews under section 304(b) with publication of Plans under section 304(m) for several re asons. First, the annual review is inextricably linked to the planning effort, because the results of each a nnual review can inform the content of the preliminary and final Plans (e.g

. , by identifying candidates for ELG revision for which EPA can schedule rulemaking in the Plan, or by identify ing point source categories for which EPA has not promulgated effluent guidelines). Second, even th ough not required to do so under either section 304(b) or section 304(m), EPA believes that th e public interest is se rved by periodically presenting to the public a description of each a nnual review (including th e review process used) and the results of the review. Doing so at th e same time EPA publishes preliminary and final Plans makes both processes more transparent. Third, by requiring EPA to review all existing effluent guidelines each year, Congress appears to have intended that each successive review would build upon the results of earlier reviews. Therefore, by describing the 2010 annual review along with the Final 2010 Plan, EPA hopes to gather and receive data and information that will inform its reviews for 2011 and the Preliminary 2012 Plan.

1.6 Background References

1. U.S. EPA. 1996. U.S. EPA NPDES Perm it Writers’ Manual . Washington, DC. (December). EPA-833-B-96-003. Available online at: http://cfpub.epa.gov/npdes/ writermanual.cfm?program_id=45.Section 2 – Public Comments



### 2-1 2. P UBLIC 

### C OMMENTS ON THE 

### F INAL 

### E FFLUENT 

### G UIDELINES 

### P ROGRAM 

### P LAN FOR 

### 2008

AND 

### P RELIMINARY 

### 2010 E FFLUENT 

### G UIDELINES 

### P ROGRAM 

### P LAN



### EPA published its Preliminary 2010 Effluent Gu idelines Program Plan (Preliminary 2010 Plan) on December 28, 2009 (74 FRN 68599) and reque sted comments on various aspects of its analyses, data, and information to inform its 2010 annual review and two detailed studies. The Agency received five comments on the Final 2008 Plan and 51 comments on the Preliminary

2010 Plan. Table 2-1 lists the commenters as well as a synopsis of the comments.Section 2 – Public Comments2-2Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program PlansEPA Docket Number: EPA-HQ-OW-2008-0517No.Commenter NameEPADocket No.Comment Summary1Deborah Goldberg (Earthjustice)0045General comments in favor of creating ELGs for a subcategory to Oil and Gas Extraction (40 CFRPart 435) for wastewater from oil and gas drilling,hydraulic fracturing to retrieve shale gas, andextraction for all oil and gas exploration, rather than focusing on coalbed methane (CBM)extraction. Recommends zero discharge of all related wastewater.2Lisa Widawsky (EnvironmentalIntegrity Project)0046General comments in favor of creating ELGs for toxic metals from coal combustion wastes at SteamElectric Power Generating plants (40 CFR Part 423). Recommends zero discharge from scrubberand ash transport systems as BAT because it has been achieved by sources in the industry.3Nancy Stewart and Margie Parsley(League of Women Voters ofTennessee)0047General comments in favor of revising Steam Electric Power Generating ELGs (40 CFR Part 423)and containment guidelines for coal-ash impoundments. Recommend including inspection andmonitoring for structural integrity, capping to prevent overflows, composite liners to preventseepage, monitoring for heavy metals and other pollutants in nearby surface waters, and phase-outof wet ash storage systems.4Abigail Dillen (Earthjustice)0048General comments in favor ofrevising the Steam Electric Power Generating ELGs (40 CFR Part423). Recommends eliminating all pollutant discharges from scrubber and ash handling systems andall discharge of leachate from land-based coal combustion waste disposal.5Doug Morris (American PetroleumInstitute)0049General comments to provide helpful regulatory and scientific background to EPA in response tocomments submitted by Earthjustice (EPA-HQ-OW-2008-0517-0045) regarding creating ELGs fora subcategory of Oil and Gas Extraction (40 CFR Part435) for wastewater from oil and gas drilling,hydraulic fracturing to retrieve shale gas, and extraction for all oil and gas exploration, rather thanfocusing on coalbed methane (CBM) extraction.6Russel F. Mankes(Albany Medical Center)0523Recommends considering the results of a two-year study funded by U.S. EPA Region 2 onpharmaceutical waste disposal for consideration ofbest practices, numeric data, and real-worldsolutions diverting pharmaceuticals from wastewater.7Edward Berbaum0524Opposes hydraulic fracturing to retrieveshale gas activities that may impact water quality due todrilling for natural gas in Dimock, PA.8Roger Graham0525Opposes the Chesapeake Appalachian Gas Company dumping wastewater related to hydraulicfracturing to retrieve shale gas inthe well near Keuka Lake in NY.9Jeff Bong0526Opposes the application of Chesapeake Appalachian Gas Company to store drilling wastewater inthe Finger Lakes Region of NYbecause of possible contamination of ground and surface waterresulting from hydraulic fracturing to retrieve shale gas.Section 2 – Public Comments2-3Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program PlansEPA Docket Number: EPA-HQ-OW-2008-0517No.Commenter NameEPADocket No.Comment Summary10Warren Cole0527Opposes storing wastewater from hydraulic fracturing to retrieve shale gas near the Keuka Lake inNY. Recommends requiring a 10-mile, or more, distance away from the Finger Lakes for storingwastewater.11Bill Hawley(Tompkins County Senior Citizens’Council Inc.)0528Supports programs that will make it easier and more accessible for the general public and smalllong-term care facilities toproperly dispose of unwanted pharmaceuticals.12Gail Connally0529Opposes storing toxic water from hydraulic fracturing to retrieve shale gas in Pulteney, NY nearKeuka Lake.13Keith and Annette Toaspern0530Recommends expanding the CBM Detailed Study to include all oil and gas exploration, stimulation,and extraction techniques, includinghydraulic fracturing, to retrieve shale gas in all formations.Specifically have concerns about storing wastewater near Keuka Lake in NY.14Eunice Alexander0531Recommends expanding the CBM Detailed Study to include hydraulic fracturing to retrieve shalegas.15Ed Gottlieb(Ithaca Area Wastewater TreatmentFacility)0532Supports changes that would allow health care facilities an alternative to flushing unusedpharmaceuticals.16Dennis Kucinich(Michigan Department of NaturalResources and Environment)0533Supports efforts todevelop proper disposal of unused pharmaceuticals. Recommends EPAreconsider and regulate dental mercury. Recommends EPA reexamine Metal Finishing (40 CFRPart 433) and Electroplating (40 CFR Part 413) ELGs because of new chemical formulas, pollutantsof concern, and treatment technologies.17Ken Harward(Association of Idaho Cities)0534Supports adopting best management practices for the proper disposal of unused pharmaceuticals.Recommends EPA regulate unused pharmaceuticals.18Bernard Handler0535Recommends EPA examine hydraulic fracturing to retrieve shale gas.19Mary Sweeny0536Recommends expanding the CBM Detailed Study to include hydraulic fracturing to retrieve shalegas in all formations, including Barnett and Marcellus Shales.20John Wagner(Wyoming Department ofEnvironmental Quality)0537Recommends that, if it proceeds with CBM ELGs EPA include CBM discharges in the Oil and GasExtraction Subpart E applicability (40 CFR Part 435).21Laurie Tenace(Florida Department ofEnvironmental Protection)0538General comments insupport of EPA’s unused pharmaceuticals detailed study and informationabout Florida Department of Environmental Protection guidelines for disposal of unusedpharmaceuticals.Section 2 – Public Comments2-4Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program PlansEPA Docket Number: EPA-HQ-OW-2008-0517No.Commenter NameEPADocket No.Comment Summary22Bob LeResche(Powder River Basin ResourceCouncil)0539Supports moving forward with the CBM ELGs along with including all oil and gas exploration,stimulation, and extraction techniques thatresult in surface or groundwater pollution.23V. Bruce Thompson(American Exploration andProduction Council)0540Opposes EPA’s CBM Detailed Study becoming an ELG and opposes expanding the scope of thedetailed study to include other oil and gas extraction activities.24Cynthia Finley(National Association of CleanWater Agencies)0541General comments insupport of EPA’s unused Pharmaceuticals Detailed Study.25Marcia English0542Recommends EPA examine hydraulic fracturing to retrieve shale gas, particularly in the MarcellusShale basin.26Justine Coffey, JD, LLM(American Societyof Health-SystemPharmacists)0543Recommends EPA reconsider using a survey to collect information on unused pharmaceuticalsmanagement. Provided additional information about unused pharmaceuticals management.27Becky Jayne(Illinois Environmental ProtectionAgency)0544Indicates the Quicksilver Caucus Dental Work Group will provide comments at a later date.28Jen Jackson(Bay Area Pollution PreventionGroup)0545Supports moving forward withan ELG for unused pharmaceuticals to limit disposal in the sanitarysewer.29Les and Sheryl Rosenbloom0546Oppose trucking toxic wastewater from hydraulic fracturing to retrieve Marcellus Shale gas inPennsylvania to store near Keuka Lake in NY.30Angie Burckhalter(Oklahoma Independent PetroleumAssociation)0547Opposes moving forward with ELGs for CBM and expanding the CBM Detailed Study to includeall oil and gas exploration, stimulation, and extraction.31S. J. Tatham0548Supports expanding the CBM Detailed Study to include all oil and gas exploration, stimulation, andextraction, including hydraulic fracturing to retrieve shale gas.32Lee Fuller(Independent Petroleum Associationof America)0549Opposes moving forward with ELGs for CBM.33Karen Bennett(National Mining Association)0550Opposes moving forward with a preliminary study of the Ore Mining and Dressing ELGs (40 CFRPart 440).Section 2 – Public Comments2-5Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program PlansEPA Docket Number: EPA-HQ-OW-2008-0517No.Commenter NameEPADocket No.Comment Summary34Charlie Burd(Independent Oil and GasAssociation of West Virginia, Inc.)0551Opposes expanding the CBM Detailed Study to include all oil and gas exploration and production.35Thomas Curtis(American Water WorksAssociation)Diane VanDe Hei (Association ofMetropolitan Water Agencies)0552General comments on the Effluent Guidelines Program Plan. Supports the CBM Detailed Study andreview of hydraulic fracturing to retrieve shale gas.36Elizabeth Tatham(Delaware River Basin Commission)0553Opposes the practice of hydraulic fracturing to retrieve shale gas because of risks to drinking wateraquifers from fracking fluid and discharges tosurface water. Supports designating special protectedareas as off limits to mining and other industrial use.37Jay Watson(King County)0554Provided information on best managementpractices (BMPs) for unused pharmaceuticals.38Kate Cain-Bell0555Opposes hydraulic fracturing to retrieve shale gas in Pennsylvania because of harm to human healthand the environment.39Winfield Tatham0556Opposes hydraulic fracturing to retrieve shale gas in Pennsylvania because of harm to human healthand the environment.40Barbara Bickford and CharlesSchuler(Wisconsin Department of NaturalResources)0557Support developing BMPs for unused pharmaceuticals to safeguard public health. Encouragestreamlining federal regulations to minimize generation of unused pharmaceuticals. Supportexpanding the EPA Pharmaceuticals Detailed Studyto include unused pharmaceutical disposal fromhomes and agriculture. Support expanding the EPA detailed study to quantify volumes ofpharmaceuticals excreted versus disposed as unused.41Mark Fix(Northern Plains Resource Council)0558Supports developing ELGs for both CBM and hydraulic fracturing to retrieve shale gas.42David Templet(Chesapeake Energy Corporation)0559Opposes developing ELGs for hydraulic fracturing to retrieve shale gas.43Jennifer Peterson(Environmental Integrity Project,Defenders of Wildlife, Earthjustice,and Sierra Club)0560Supports EPA’s selection of Steam Electric Power Generating for revised rulemaking but suggestsexpedited schedule for revisions.Section 2 – Public Comments2-6Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program PlansEPA Docket Number: EPA-HQ-OW-2008-0517No.Commenter NameEPADocket No.Comment Summary44Sarah Eckel(Citizens Campaign for theEnvironment)0561 and0565Supports developing ELGs for all oil and gas exploration, stimulation, and extraction techniques ina detailed study, including a study of environmental impacts. Requests EPA explore potential forcontamination surrounding underground injection disposal for the waste fluids from oil and gasexploration, stimulation, and extraction.45John Smillie(The Western Organization ofResource Councils)0562Supports developing ELGs for all oil and gas exploration, stimulation, and extraction techniques ina detailed study, including hydraulicfracturing to retrieve shale gas.46Cynthia Miles(Utility Water Act Group)0563Opposes revising the Steam Electric Power Generating Point Source Category (40 CFR Part 423).47Deborah Goldberg(Earthjustice)0564Supports developing ELGs for both CBM and hydraulic fracturing.48Scott Thomas(Fennemore Craig, P.C.)0566Opposes revising ELGs for the Ore Mining and Dressing Category (40 CFR Part 440).49B. Arrindell(Damascus Citizens forSustainability)0567Opposes the process of hydraulic fracturing to retrieve shale gas because of risks to drinking wateraquifers from fracking fluid and discharges to surface water.50Kathleen Sgamma(Independent Petroleum Associationof Mountain States)0568Opposes developing ELGs to regulate CBM produced water discharges.51Leroy Sprang(Northern Cheyenne Tribe)0569Opposes developing ELGs to regulate CBM-produced water discharges and to allow state specificregulation.52Erik Milito(American Petroleum Institute)0570Opposes developing ELGs to regulate CBM-produced water discharges.53Charlotte Smith(PharmEcology Services WasteManagement)0571Provides information onBMPs for unused pharmaceuticals handling and disposal.54Gayle Gray(Rx Rescue LLC)0572Provides information onBMPs for unused pharmaceuticals handling and disposal.55Mark McDermid (WisconsinDepartment of Natural Resources)0573Supports developing an ELG to regulate dental amalgam discharges from dentists’ offices.Section 3 – The Effluent Guidelines Planning Process



### 3-1 3

. T HE 

### E FFLUENT 

### G UIDELINES 

### P LANNING 

### P ROCESS



### This section provides a general overview of the process EPA used in 2010 to identify industrial categories for potential development of new or revise d effluent limitations guidelines and pretreatment standards (ELGs). This proce ss consisted of: (1) annu al review of existing ELGs to identify candidates for revision; (2) identification of new categories of direct dischargers for possible development of efflue nt guidelines; and (3) identification of new categories of indirect discharger s for possible development of pret reatment standards. Each of these components is illustrated in Figure 3-1 through Figure 3-3 and discussed below.

3 .1 Goals of the Effluent Guid elines Planning Process

In the effluent guidelines planning proce ss, EPA is guided by the following goals:

• 

### Re store and maintain the chemical, phys ical, and biological integrity of the Nation's waters; and

• 

### Prov ide transparent decision-making and involve stakeholders early and often during the planning process.

3.2 An nual Review of Existing Effluent Guidelines and Pret reatment Standards

This section describes the four factors used (Section 3.2.1 ) and how they are used (Section 3.2.2 ) in the annual review of existing effluent guidelines and pretreatment standards.

3.2.1 Fa ctors Considered in Review of Existin g Effluent Guidelines and Pretreatment

Standards

EPA uses four major factors in prioritizing existing effluent guideli nes or pretreatment standards for possible revision.

The first factor EPA considers is the amount and type of pollutants in an industrial category’s discharge and the relative hazard posed by that discharge. Using this factor enables the Agency to set priorities for rulemaking to achieve the greatest environmental and health benefits. EPA estimates the potential hazard of pollu tant discharges in te rms of toxic-weighted pound equivalents (TWPE), discus sed in detail in Section 4.1.3 . To assess the effectiveness of pollution control, EPA examines the removal of pollutants in terms of pounds and TWPE.

The second factor EPA considers is the pe rformance and cost of applicable and demonstrated wastewater treatment technologi es, process changes, or pollution prevention alternatives that could effectively reduce the concentrations of pollu tants in the industrial category’s wastewater and, conseq uently, reduce the hazard to human health or the environment associated with these pollutant discharges.Section 3 – The Effluent Guidelines Planning Process



### Figure 3-1. Flow Chart of Annua l Review of Existing ELGs

3-2Section 3 – The Effluent Guidelines Planning Process



### Figure 3-2. Flow Chart of Furt her Review of Existing ELGs

3-3Section 3 – The Effluent Guidelines Planning ProcessInclude in annual reviewof existing category (seeFigure 3-1)Identify SIC/NAICScodes withdischarges notsubject to existingELGsIs the SIC/NAICS codeappropriatelyconsidered a potentialnew subcategory of anexisting ELG ?Begin industryidentificationDodischarges interferewith or otherwise passthrough POTWoperations?*Is the possible newcategory all or nearly allindirect dischargers ?Aredischarges of toxicor nonconventionalpollutantstrivial?*Are ELGs potentiallythe appropriate tool ?No identification orfurther review necessaryIdentify other tools(e.g., permit-basedsupport or guidance)Identify for possiblenew effluent guidelinesor standardsNo identification orfurther review necessaryStakeholder recommendationsand commentsDMR& TRIdatabase toolsYesYesNoYesYesYesNoNoNoNo*Continue further review if not enough data.Figure 3-3. Flow Chart of Identification of Possible New ELGs3-4Section 3 – The Effluent Guidelines Planning Process



### 3-5 The third factor EPA considers is the affo rdability or economic achievability of the wastewater treatment technology, process change , or pollution prevention measures identified using the second factor. If the financial condition of the indus try indicates that it would be difficult to implement new requi rements, EPA might conclude that it would be more costeffective to develop less expensive approaches to reduce pollutant load ings that would better satisfy applicable statutory requirements.

The fourth factor EPA considers is an oppor tunity to eliminate inefficiencies or impediments to pollution prevention or techno logical innovation, or opp ortunities to promote innovative approaches such as water quality trading, including with in-plant trading. This factor might also prompt EPA, during an annual review, to decide agains t revising an existing set of effluent guidelines or pretreatment standards wher e the pollutant source is already efficiently and effectively controlled by other re gulatory or nonregulatory programs.

3.2.2 Ov erview: Review of Existing Point Source Categories

EPA has established ELGs to regulate wast ewater discharges from 57 point source categories and must annually review the ELGs for all of these categories. EPA first conducts a screening-level review of all cat egories subject to existing ELGs to prioritize the categories for further review. The Agency then conducts another review, either an in-depth “detailed study” or a somewhat less detailed “preliminary categor y review,” to identify existing categories for potential ELGs revision.

3.2 .2.1 Screening-Level Review

The screening-level review is the firs t step in EPA’s annual review. Section 4 provides details on the database methodology used in the sc reening-level review. EPA uses this step to prioritize categories for further review. In conduc ting the screening-level review, EPA considers the amount and toxicity of the pollutants in a cat egory’s discharge and the extent to which these pollutants may pose a hazard to human health or the environment (Factor 1).

EPA conducts its screening-level review usi ng data from the Toxics Release Inventory (TRI) and data from discharge monitoring repor ts (DMR) contained in the Permit Compliance System (PCS) and Integrated Compliance Inform ation System - National Pollutant Discharge Elimination System (ICIS-NPDES ). EPA combines the DMR data from both PCS and ICISNPDES in a database called DMRLoads . The Revised Quality Assuran ce Project Plan for the 2009 Annual Screening-Level Analysis of TR I, ICIS-NPDES, and PCS Industrial Category Discharge Data describes in detail the quality criteria EPA used to evaluate the TRI and DMR data (ERG, 2009). TRI and DMR data do not identif y the effluent guideline (s) applicable to a particular facility. However, TRI includes info rmation on a facility’s North American Industry Classification System (NAICS) code, while DM R data include inform ation on a facility’s

Standard Industrial Classification (SIC) code. Therefore, the first step in EPA’s screening-level

review is to relate each SIC and NAICS code to an industrial category. 1 

### The second step is to use the information reported in TRI and DMR, for a sp ecified year, to calculate the annual pollutant discharges in pounds, including toxi c, nonconventional, and conventio nal pollutants. For indirect

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

the 2009 Technical Support Document for the Annual Review of Existing Effluent Guidelines and Identification of Potential New Point Source Categories (U.S. EPA, 2009).Section 3 – The Effluent Guidelines Planning Process



### 3-6 dischargers, EPA adjusts the faci lity discharges to account for removals at the publicly owned treatment works (POTW). The third step is to apply toxic wei ghting factors (TWFs) 2 

### to the annual pollutant discharges to calculate the total discharg e of toxic and nonconventional pollutants (reported in units of TWPE). EPA then sums the TWPE for each facility in a category to calculate a total TWPE per category for that year. EPA calculates two TWPE estimates for each category: one based on data in TRI and one based on DMR data. EPA combines the estimated discharges of toxic and nonconventional pollutants calculated from TRI and DMR data to estimate a single TWPE value for each industrial category. EPA took this approach because it found that combining the TWPE estimates from TRI and DMR data into a single TWPE number offered a clearer perspective of the in dustries with the most toxic pollution. 3



### EPA then ranks point source categories accord ing to their total TWPE discharges. In identifying categories for further review, EPA pr ioritizes categories acco unting for 95 percent of

the cumulative TWPE from the co mbined databases (see Section 5.3 ). Illustrated in Figure 3-1

, EPA also excludes from further re view categories for which an e ffluent guidelines rulemaking is currently underway or for which effluent guideline s have been promulgated or revised within the past seven years. EPA chose seve n years because this is the typical length of time for the effects of effluent guidelines or pretreat ment standards to be fully reflect ed in pollutant loading data and TRI reports. EPA also considers th e number of facilities respons ible for the majority of the estimated toxic-weighted pollutant discharges as sociated with an indus trial activity. Where only a few facilities in a category account for the vast majority of toxic-weighted pollutant discharges, EPA typically does not prioritize the category for additional review. In this case, EPA believes that revising individual permits may be more effective in addre ssing the toxic-weighted pollutant discharges than a national effluent guidelines rulemaking because requirements can be better tailored to these few facilities and because individual permitting actions may take considerably less time than a national rulemaking.

3.2.2 .2 Further Review

Based on its screening-level revi ew of all point source catego ries, EPA prioritizes certain categories for further review to determine whethe r it would be appropriate for EPA to identify those categories in the final Plan for potential effluent guidelines revision. EPA typically conducts two types of further review: detailed studies and preliminary reviews. EPA selects categories for further review based on the scre ening-level review and/ or stakeholder input.

EPA’s detailed studies generally examine the following: (1) wastewater characteristics and pollutant sources; (2) the pollutants driving the toxic-wei ghted pollutant discharges; (3) availability of pollution preventi on and treatment; (4) the geographic distribution of facilities in the industry; (5) any pollutant discharge trends within the industry; and (6) any relevant economic factors. First, EPA attempts to verify the screening-level results and to fill in data gaps (Factor 1). Next, EPA consider s costs and performance of ap plicable and demonstrated

2 For more information on toxic weighting factors, see Toxic Weighting Factor Development in Support of CWA 304(m) Planning Process (U.S. EPA, 2006).

3 Different pollutants may dominate the TRI and DMR TW PE estimates for an industrial category due to the differences in pollutant reporting requirements between the TRI and DMR databases. The single TWPE number for each category highlights those industries with the most t oxic discharge data in both TRI and DMR. Although this approach could have theoretically led to double-counting, EPA's review of the data indi cates that because the three databases focus on different pollutants, double-counting was minimal and did not affect the order of the top ranked industrial categories.Section 3 – The Effluent Guidelines Planning Process



### 3-7 technologies, process changes, or pollution preven tion alternatives that ca n effectively reduce the pollutants in the point source category’s wastewater (Factor 2). Last, EPA considers the affordability or economic achievability of the technology, process change, or pollution prevention measure identified usin g the second factor (Factor 3).

Types of data sources that EPA may consu lt in conducting its deta iled studies include, but are not limited to: (1) U.S. Economic Census; (2) TRI and DMR data; (3) trade associations and reporting facilities to verify reported releases and facility categorization; (4) regulatory authorities (states and EPA regions) to understa nd how category facilities are permitted; (5) NPDES permits and their supporting fact sheet s; (6) EPA effluent guidelines technical development documents; (7) relevant EPA prelim inary data summaries or study reports; and (8) technical literature on pollutant sources and control technologies.

Preliminary reviews are similar to detailed studies and have the same purpose. During preliminary reviews, EPA generally examines the same factors and data sources listed above for detailed studies. However, in a preliminar y review, EPA’s examination of a point source category and available pollution prevention and tr eatment options is less rigorous than in its

detailed studies. While EPA collects and anal yzes hazard and technology performance and cost information on categories undergoing preliminary review, it assigns a higher priority to investigating categories unde rgoing detailed studies.

3.3 Id entification of New Categories for Po ssible Effluent Guidelines Development

Concurrent with its review of existing point source categories, EPA also reviews industries not currently subject to effluent gui delines to identify pot ential new point source categories. To identify possible new categories, EPA conducts a “crosswalk” analysis based on

data in DMR and TRI. Facilities with data in DMR and TRI are identified by a four-digit SIC code or six-digit NAICS code (Sections 4.1.1 and 4.1.2 provide more details on SIC and NAICS codes, respectively). EPA links each four-digit SIC code and six-digit NAICS code to an appropriate industrial categor y (i.e., “the crosswalk”). 4 

### This crosswalk identifies SIC codes and

NAICS codes that EPA associated with industries subject to an existing gu ideline. The crosswalk

also identifies SIC and NAICS codes not associated with an existing guidelin e. In addition to the crosswalk analysis, EPA relies on stakeholder comments to identi fy potential new point sources categories. Sections 4.1.4 and 4.1.5 discuss the utility and limitations of TRI and DMR data, respectively, in detail.

For each industry identified through the cro sswalk analysis or stakeholder comments,

EPA evaluates whether it could be identified as a potential new category in the plan or whether it is properly considered a potential new subcategory of an existing point source category. To determine this, EPA generally looks at whethe r the industry produces a similar product or performs a similar service as an existing category. If so, EPA ge nerally considers the industry to be a potential new subcategory of that categ ory. If, however, the industry is significantly different from existing categories in terms of products or servi ces provided, EPA considers the industry as a potential new st and-alone category subject to identification in the Plan.

4 For additional information on “the crosswalk,” see Section 4 of the 2009 Technical Support Document for the Annual Review of Existing Effluent Guidelines and Identification of Potential New Point Source Categories (U.S. EPA, 2009).Section 3 – The Effluent Guidelines Planning Process



### 3-8 3.3 .1 Direct Discharges

Because the Clean Water Act (CWA) has different requirements for potential new categories of direct and indirect dischargers, EPA examines new categories to determine if the category comprises mostly direct dischargers, mo stly indirect discharger s, or both direct and indirect dischargers. If a categor y consists largely of direct disc hargers, EPA evaluates the type of pollutants discharged by facilities in the category.

3.3 .2 Indirect Discharges

For potential new categories with primarily indirect dischargers, EPA evaluates the potential for the wastewater discharges to “i nterfere with, pass through, or [be] otherwise incompatible with” the operation of POTWs. See 33 U.S.C. § 1371( b)(1). Using available data, EPA reviews the types of pollutants in an industry’s wastewater. Then, EPA reviews the likelihood of those pollutants to pass through a POTW as meas ured by: (1) the total annual TWPE discharged by the indus trial sector; and (2) the av erage TWPE discharged among facilities that discharge to POTW s. EPA also assesses the interfer ence potential of the discharge. Finally, EPA considers whether the pollutant di scharges are already adequately controlled by general pretreatment standards a nd/or local pretreatment limits.

3. 4 Stakeholder Involvement and Schedule

EPA’s goal is to involve stakeholders ear ly and often during it s annual reviews of existing effluent guidelines and the developmen t of the biennial Plan. By doing so, EPA will likely maximize the data collected to inform its analyses and provide additional transparency and understanding of its effluent guidelines prio rities identified in the biennial Plan.

EPA’s annual reviews build on reviews from previous years, and reflect a lengthy

outreach effort to involve stakeholders in the review process. In performing its annual reviews, EPA considers all public comments, information, and data submitted to EPA as part of its outreach activities. EPA solicits public comment at the beginning of each annual review of effluent guidelines and on the pr eliminary biennial Plan. In eac h Federal Register Notice, EPA requests stakeholder comments on specific industries and discha rges as well as any general

comments.

EPA completes an annual review of industr ial discharges each y ear, upon publication of the Preliminary and Final Effluent Guidelines Program Plans. In odd-numbered years, EPA publishes its preliminary Plan for public review and comment as required under CWA section 304(m)(2). In even-numbered years, EPA publishes its final Plan that incorporates the comments received on the preliminary Plan.

EPA intends that these contemporaneous revi ews will provide meaningful insight into EPA’s effluent guidelines and pretreatment st andards program decision-making. Additionally, by providing notice for these and future reviews, EP A hopes to provide a consolidated source of information for the Agency’s current and future effluent guidelines and pretreatment standards program reviews.Section 3 – The Effluent Guidelines Planning Process



### 3-9 3. 5 The Effluent Guidelines Planning Process References

1. ERG. 2009. Revised Quality Assurance Project Plan for 2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and PC S Industrial Category Discharge Data. (September). EPA-HQ-OW-2008-0517-0507.

2. U.S. EPA. 2006. Toxic Weighting Factor Devel opment in Support of CWA 304(m) Planning Process . Washington, DC. (June). EPA-HQ-OW-2004-0032-1634.

3. U .S. EPA. 2009. Technical Support Document for the Annu al Review of Existing Effluent Guidelines and Identification of Po tential New Point Source Categories . EPA-821-R-09- 007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515.Section 4 – Methodology, Data Sources, and Limitations



### 4-1 4

. M ETHODOLOGY 

### , D ATA 

### S OURCES 

### , AND 

### L IMITATIONS



### As discussed in Section 1 , the Clean Water Act (CWA) requires EPA to conduct an annual review of existing effluent limitations gu idelines and pretreatment standards (ELGs). It also requires EPA to identify industrial categories without ap plicable ELGs. EPA’s methodology for the 2010 annual review and new point sour ce category identifica tion involves several components, as discussed in Section 3

.

First, EPA performs a screening-level review of all point source categories subject to existing ELGs to identify categories discharg ing high levels of t oxic and nonconventional pollutants relative to other categories. Second, EPA identifies priority categories as possible candidate ELGs for revision, as required by CWA sections 304(b), 301(d), 304(g), and 307(b). EPA then performs further review of the priority categories. Pa rt II of this report (Sections 5 through 15 ) discusses the findings of EPA’s 2010 annual review.

The next component of EPA’s review is to identify industria l categories without applicable ELGs. EPA reviews indirect discharging industries not currently subject to pretreatment standards to identify potential candi dates for pretreatment standards development, as required by CWA section 307( b). Next, EPA reviews direct discharging industries not currently subject to ELGs to identify potential candidates for ELG development, as required by section 304(m)(1)(B) of the CWA.

In performing the screening-level review of existing ELGs and identifying industrial categories without ELGs, EPA relies on discharg e monitoring report (DMR) data, contained in EPA’s Permit Compliance System (PCS) and the In tegrated Compliance Information System for the National Pollutant Discharge Elimination Sy stem (ICIS-NPDES), and the Toxics Release Inventory (TRI). This section discusses thes e databases, related data sources, and their

limitations.

EPA has developed two screening-level tools, the TRIReleases and DMRLoads databases, to facilitate analysis of TRI and PCS/ICIS-NPDES data. EPA pr eviously explained the creation of these screening-level analysis tools in the Technical Support Document for the Annual Review of Existing Effluent Guidelines and Identifica tion of Potential New Point Source Categories (2009 Screening-Level Analysis (SLA) Re port) (U.S. EPA, 2009). The 2009 SLA Report provides the detailed methodology used to process thousands of data records and generate

national estimates of industrial effluent discharges. This secti on does not revisit the details of creating the database tools. Instead, it lists the methodology corrections made to the DMRLoads

and TRIReleases databases as part of EPA’s 2010 annual re view. It also presents the preliminary category rankings from TRIReleases2008_v3 and DMRLoads2008_v2

.

4 .1 Data Sources and Limitations

This subsection provides general informa tion on the use of Standard Industrial Classification (SIC) and North Am erican Industry Classification System (NAICS) codes, toxic weighting factors (TWFs), TRI data, and DMR data. The following reports supplement this section and discuss EPA’s methodology for developi ng and using the two screening-level tools:

• 

### Tech nical Support Document for the Annual Review of Existing Effluent Guidelines and Identification of Po tential New Point Source Categories , (2009Section 4 – Methodology, Data Sources, and Limitations



### 4-2 SLA Report) (U.S. EPA, 2009). Document s the methodology and development of

the DMRLoads2008 and TRIReleases2008 databases, including (but not limited to) matching NAICS and SIC codes to poi nt source categories and using TWFs to estimate toxic-weighted pound equivalents (TWPE).

• 

### Draft Toxic Weighting Factor Devel opment in Support of the CWA 304(m) Planning Process (Draft TWF Development Docu ment), dated July 2005 (U.S. EPA, 2005). Explains how EPA developed the December 2004 TWFs.

• 

### Toxic Weighting Factor Development in Support of the CWA 304(m) Planning

Process (Final TWF Development Document ) (U.S. EPA, 2006b). Explains how EPA developed the April 2006 TWFs.

4

.1.1 SIC Codes

The SIC code system was developed to help with the collection, aggregation, presentation, and analysis of data from the U.S. economy (OMB, 1987). The different parts of the SIC code signify the following:

• 

### The f irst two digits repres ent the major industry group;

• 

### The third digit represents the industry group; and

• 

### The fourth digit repr esents the industry.

For example, major SIC code 26: Paper and Allied Products includes all pulp, paper, and paperboard manufacturing operation s. Within SIC code 26, the thre e-digit SIC codes are used to distinguish the type of facility: 263 for paperb oard mills, 265 for paperboard containers and boxes, etc. Within SIC code 265, the four-digit SIC codes are used to separate facilities by product type: 2652 for setup paperboard boxes, 2653 for corrugated and solid fiber boxes, etc.

The SIC system is used by many government ag encies, 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 establ ishment. PCS and ICIS-NPDES include one fourdigit SIC code, reflecting the principal activity causing the discharge at each facility.

Regulations for an individual point source category may apply to one SIC code, multiple SIC codes, or a portion of the facilities in an SI C code. Therefore, to use databases that identify facilities by SIC code, EPA linked each four-digit SIC code to an appropriate point source category, as summarized in the “SIC/Point Sour ce Category Crosswalk” table (Table A-1 in Appendix A).

There are some SIC codes for which EPA ha s not established national ELGs. Table A-2 in Appendix A lists the SIC codes for which fac ility discharge data are available in PCS and ICIS-NPDES, but for which EPA could not identi fy an applicable point source category. For a more detailed discussion, see Section 6 of the 2009 SLA Report (U.S. EPA, 2009).Section 4 – Methodology, Data Sources, and Limitations



### 4-3 4

.1.2 NAICS Codes

In 1997, the U.S. Census Bureau introduced th e NAICS code system, to better represent the economic structure of countries participati ng in the North American Free Trade Agreement and to respond to criticism about the SIC code system. Table 4-1 explains the nomenclature and

format of NAICS and SIC codes.

Table 4-1. Nomenclature and Format of NAICS and SIC Codes

NAICS SIC

2-digit Sector Letter Division

3-digit Subsector 2-digit Major Group

4-digit Industry Group 3-digit Industry Group

5-digit NAICS Industry 4-digit Industry

6-digit U.S. Industry N/A N/A



### For example, below are the SIC and NAICS code for the Folding Paperboard Box Manufacturing industry.

In the SIC code system the classification is less stratified:

• 

### 26: Paper and Allied Paper Products;

— 265: Paperboard containers and boxes;

• 2657: Folding Paperboard Boxes, Including Sanitary (except paperboard backs for blis ter or skin packages).

In the NAICS code system the classification is more stratified:

• 

### 32: Manufacturing;

— 322: Paper Manufacturing;

• 3222: C onverted Paper Product Manufacturing;

o 322212 : Folding Paperboard Box Manufacturing.

The NAICS system is used for industrial classification purposes at many government agencies, including EPA. As in the SIC system, each establishment is classified according to its primary economic activity, which is determined by its principal product or group of products. An establishment may have activities in more than one NAICS code.

Regulations for an individual point source category may apply to one NAICS code, multiple NAICS codes, or a portion of the facilities in an NAICS code. Therefore, to use databases that identify facilities by NAICS code (e.g., TRI), EPA linked each six-digit NAICS code to an appropriate point source category, as summarized in the “NAICS/Point Source Category Crosswalk” table (Table A-3 in Append ix A). This table was based on the SIC/Point Source Category Crosswalk table (Table A-1 in Appendix A) and the NAICS/SIC Code Crosswalk that EPA developed for past comparisons.

There are some NAICS codes for which EPA has not established national ELGs. Table A-4 in Appendix A lists the NAICS codes for which facility discharge data are available in TRI,Section 4 – Methodology, Data Sources, and Limitations



### 4-4 but for which EPA could not identify an applicab le point source category. For a more detailed discussion, see Section 6 of the 2009 SLA Report (U.S. EPA, 2009).

4.1.3 Toxic Weighting Factors

As part of the Effluent Guidelines Program, EPA developed a wide variety of tools and methodologies to evaluate effluent discharges. EP A’s Office of Water, E ngineering and Analysis Division (EAD) maintains a Toxics Database co mpiled from over 100 references for more than 1,900 pollutants. The Toxics Database includes a quatic life and human hea lth toxicity data, as well as physical and chemical prope rty data. Each pollutant in this database is identified by a unique Chemical Abstract Serv ice (CAS) number. EPA calculate s TWFs from these data to account for differences in toxicity across polluta nts and to provide the means to compare mass loadings of different pollutants. In its analys es, EPA multiplies a mass loading of a pollutant in pounds per year (lb/yr) by a polluta nt-specific weighting factor to derive a “toxic-equivalent” loading (lb-equivalent/yr). Througho ut this document, the toxic-equi valent is also referred to as TWPE. The Draft and Final TWF Development Do cuments discuss the use and development of TWFs in detail (U.S. EPA, 2005; U.S. EPA, 2006b).

EPA derives TWFs from chroni c aquatic life criteria (or to xic effect levels) and human health criteria (or toxic effect levels) established for the consum ption of fish. In the TWF method for assessing water-based effects, these aquatic life and human health toxicity levels are compared to a benchmark value that represents the toxicity level of a specified pollutant. EPA selected copper, a metal commonly detected a nd removed from industr ial effluent, as the benchmark pollutant. The Final TWF Developm ent Document contains details on how EPA developed its TWFs (U.S. EPA, 2006b). Table A- 5 in Appendix A lists the TWFs for those

chemicals in the DMRLoads2008 and TRIReleases2008 databases for which EPA has developed

TWFs.

4. 1.3.1 New Toxic Weighting Factors Develo ped During the 2010 Annual Review

During the 2010 annual review, EPA did not re vise any TWFs or develop TWFs for any chemicals that had not previously had TWFs.

4. 1.3.2 Calculation of TWPE

EPA weighted the annual pollutant discharges calculated from the TRIReleases (see

Section 4.1.4 ) and DMRLoads (see Sections 4.1.5 ) databases using EAD’s TWFs to calculate TWPE for each reported discharge. EPA su mmed the estimated TWPE discharged by each facility in a point source categ ory to understand the potential hazar d of the discharges from each category. The following subsections di scuss the calculation of TWPE.

4. 1.4 Data from TRI

TRI is the common name for Section 313 of the Emergency Planning and Community Right-to-Know Act. Each year, f acilities that meet certain thres holds must report their releases and other waste management activities for listed toxic chemicals. Facilities must report the quantities of toxic chemicals recycled, collected, and combusted for energy recovery, treated for destruction, or disposed of. A se parate report must be filed for each chemical that exceeds the reporting threshold. The TRI list of chemicals for reporting year 2008 includes more than 650Section 4 – Methodology, Data Sources, and Limitations



### 4-5 chemicals and chemical categories. For the 2010 screening-level review, EPA used data for reporting year 2008, because they were the most r ecent available at the time the review began.

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

1. NAICS Code Determination . The primary NAICS code determines if TRI reporting is required. The primary NAICS c ode is associated with the facility’s revenues, and may not relate to its po llutant discharges (73 FR 324666). Certain facilities in NAICS codes 11, 21, 22, 31 through 33, 42, 48 through 49, 51, 54, 56 and 81, and federal facilities are pote ntially subject to TRI reporting. EPA generally relies on facility claims rega rding the NAICS code identification.

2

. Number of Employees . Facilities must have 10 or more full-time employees or their equivalent. EPA defines a “full-tim e equivalent” as a person that works 2,000 hours in the reporting year (there are several excepti ons and special circumstances that are well defined in the TRI reporti ng instructions).

3

. Activity Thresholds . If the facility is in a covere d NAICS code and has 10 or more full-time employee equivalents, it must c onduct an activity threshold analysis for every chemical and chemical category on th e current TRI list. The facility must determine whether it manufactures, processes, or otherwise uses each chemical at or above the appropriate activity thres hold. Reporting thresholds are not based on

the amount of release. All TRI threshol ds are based on mass, not concentration. Different thresholds apply for persiste nt bioaccumulative toxic (PBT) chemicals than for non-PBT chemicals. Generally, non-PBT chemical threshold quantities are 25,000 pounds for manufacturing and processing activities and 10,000 pounds

for other use activities. All thresholds are determined per chemical over the calendar year. For example, dioxin and dioxin-like compounds are considered PBT chemicals. The TRI reporting guidance requires any facility that manufactures, processes, or otherwise uses 0.1 grams of dioxin and dioxin-like compounds to report it to TRI (U.S. EPA, 2000).

In TRI, facilities repo rt annual loads released to the environment of each toxic chemical or chemical category that meets reporting require ments. Facilities must report onsite releases or disposal to air, receiving str eams, land, underground wells, and several other categories. They must also report the amount of toxic chemicals in wastes transf erred to off-site locations, (e.g., POTWs, commercial waste disposal facilities).

For its screening-level reviews, EPA focu sed on the amount of chemicals facilities reported either discharging dire ctly to a receiving stream or transferring to a POTW. For facilities discharging directly to a stream, EPA took the annual loads directly from the reported TRI data for calendar year 2008. Fo r facilities transferri ng to POTWs, EPA first adjusted the TRI pollutant loads reported to account for pollutant removal that occurs at the POTWs prior to discharge to the receiving stream. Table A-6 in Appendix A lists the POTW removals used for all TRI chemicals reported as transferred to POTWs.Section 4 – Methodology, Data Sources, and Limitations



### 4-6 Facilities reporting to TRI ar e not required to sample a nd 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 require d to indicate, by a reporting code, the basi s of their release estimate. TRI’s reporting guidance is that, for mo st chemicals reasonably expected to be present but measured below the detection limit, facilities should use half the detection limit to estimate the mass released. However, for dioxins a nd dioxin-like compounds, nondetects should be

treated as zero.

TRI allows facilities to report releases as sp ecific numbers or as ranges, if appropriate. Specific estimates are encouraged if data are available to ensure th e accuracy; however, EPA

allows facilities to re port releases in the following ranges: 1 to 10 pounds, 11 to 499 pounds, and 500 to 999 pounds. For its screening-level reviews, EPA used the midpoint of each reported range to represent a facility ’s releases, as applicable.

4 .1.4.1 Utility of TRI Data

The data collected in TRI are particularly useful for ELG planning for the following

reasons:

• 

### TRI is national in scope, including data from all 50 states and U.S. territories/tribes;

• 

### TRI inc ludes releases to PO TWs, not just direct disc harges to surface water;

• 

### TRI includes discharge data from manufacturing NAICS codes and some other

industrial cate gories; and

• 

### TRI includes releases of many toxic chemical s, not just those in facility discharge permits.

4 .1.4.2 Limitations of TRI

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

• 

### Small establishments (less than 10 employ ees) 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.

• 

### Rele ase reports are, in part, based on estimates, not measurements, and, due to TRI guidance, may overstate releases, es pecially at facil ities with large

wastewater flows.

• 

### C ertain chemicals (polycyclic aromatic compounds (PACs) , dioxin and dioxinlike compounds, metal compounds) are reporte d as a class, not as individual compounds. Because the individual com pounds in most classes have widely varying toxic effects, the potential to xicity of chemical releases can be inaccurately estimated.Section 4 – Methodology, Data Sources, and Limitations



### 4-7 • 

### F acilities are identified by NAICS c ode, not point source category. For some NAICS codes, it may be difficult or impo ssible to identify the point source category that is the source of the toxic wastewater releases.

Despite these limitations, EPA determined that the data summarized in TRIReleases2008 were usable for the 2010 screening- level review and prioritization of the toxic-weighted pollutant loadings discharged by industrial categories.

4. 1.5 Data from PCS and ICIS-NPDES

EPA has used data reported to PCS as a part of its screening-leve l review of existing effluent guidelines since the 2003 annual re view (68 FRN 75515). Since 2002, EPA has been working to modernize PCS by creating a new da ta system called ICIS-NPDES. In 2006, some states began transitioning thei r DMR reporting from PCS to ICIS -NPDES. Currently 57 of the 71 states and territories/tribes have migrated to ICIS-NPDES. Therefore, for the 2010 annual review, EPA’s view of nationwide discharges wa s split between two sets of data. EPA created the 2008 DMR Loadings Tool to combine the two systems (PCS and ICIS -NPDES) and generate industrial category rankings for all U.S. states and territories/tribe s. EPA extracted the loads from the 2008 DMR Loadings Tool to create the DMRLoads2008 database. Both PCS and ICISNPDES automate entering, updating, and retrieving NPDES data and track permit issuance, permit limits, monitoring data, and other data pe rtaining to facilities regulated by the NPDES program under the CWA.

More than 65,000 industrial facilities and wast ewater treatment plants have permits for wastewater discharges to waters of the United States. To provide an initial framework for setting permitting priorities, EPA developed a major/mi nor classification system for industrial and municipal wastewater discharges. Major discharg es usually have the capability to impact receiving waters if not controll ed and, therefore, have received more regulatory attention than minor discharges. There are approximately 7,000 f acilities (including sewe rage systems) with major discharges and 15,000 facilities with minor discharges for which PCS and ICIS-NPDES have extensive records. Permitting authorities classify discharges as major based on an

assessment of six characteristics:

1. Toxic pollutant potential;

2. Discharge flow: stream flow ratio;

3. Conventional pollu tant loading;

4. Publi c health impact;

5

. Water quality factors; and

6

. Proximity to coastal waters.

Facilities with major discharges must re port compliance with NPDES permit limits via monthly DMRs submitted to the permitting au thority. The permitting authority enters the reported DMR data into PCS or ICIS-NPDES, in cluding pollutant conc entration and quantity

values and identification of a ny types of permit violations.

Minor discharges may, or may not, adversely impact receiving water if not controlled. Facilities with minor discharges must report compliance with NPDES permit limits via monthly DMRs submitted to the permitting authority; however, EPA does not require the permitting authority to enter data in th e PCS and ICIS-NPDES databases. For this reason, the PCS andSection 4 – Methodology, Data Sources, and Limitations



### 4-8 ICIS-NPDES databases include data only for a limited set of minor discharges (i.e., if the state or other permitting authority chooses to include these data).

Parameters in PCS and ICIS-NPDES include water quality parameters (such as pH and temperature), specific chemicals, conventional parameters (such as biochemical oxygen demand (BOD 5 

### ) and total suspended solids (TSS)), and fl ow rates. Although other pollutants may be discharged, PCS and ICIS-NPDES c ontain data only for the parameters identified in the facility’s NPDES permit. Facilities typically report monthl y average pounds per day discharged, but also report daily maxima and averag e pollutant concentrations.

For the 2010 annual review, EPA used data for reporting year 2008, to correspond to the

data obtained from TRI. For th e 2010 annual review, EPA correct ed certain aspects of the 2008 data (see Section 4.3 ). Using the DMR Loadings Tool, EPA calculated annual loads for the PCS

and ICIS-NPDES data and then combined th e calculated loads for each set of data. EPA

extracted the results of the a nnual loads calcula tions in the DMRLoads2008 database. Section 2 of the 2009 SLA Report provides details on the methodology and development of

DMRLoads2008 (U.S. EPA, 2009).

4 .1.5.1 Utility of PSC and ICIS-NPDES

The data collected in the PCS and ICIS-NPDES data systems are particularly useful for the ELG planning process for the following reasons:

• 

### PCS and ICIS-NPDES combined are nationa l in scope, including data from all 50

states and 21 U.S. territories/tribes.

• 

### Discha rge reports included in PCS and ICIS-NPDES are based on effluent chemical analysis and metered flows.

• 

### PCS and ICIS-NPDES include f acilities in all SIC codes.

• 

### PCS and ICIS-NPDES include data on conve ntional pollutants fo r most facilities and for the nutrients nitrogen and phosphorus for many facilities.

4 .1.5.2 Limitations of PCS and ICIS-NPDES

Limitations of the data collected in the PC S and ICIS-NPDES data systems include the following:

• 

### The data systems contain data only for po llutants a facility is required by permit to monitor; the facility is not required to monitor or report all pollutants actually discharged.

• 

### The data systems include limited di scharge monitoring data from minor dischargers.

• 

### The data systems do not include data ch aracterizing indirect discharges from

industrial faciliti es to POTWs.

• 

### Many of the pollutant parameters included in the data systems are reported as a group parameter and not as individua l compounds (e.g., “Total Kjeldahl Nitrogen,” “oil and grease”). Because the individual compounds in the groupSection 4 – Methodology, Data Sources, and Limitations



### 4-9 parameter may have widely varying toxi c effects, the potential toxicity of chemical releases can be inaccurately estimated.

• 

### In some cases, the data systems identify the type of wastewater (e.g., process wastewater, stormwater, noncontact cooli ng water) being discharged; however, most do not and, therefore, total flow ra tes reported to PCS and ICIS-NPDES may include stormwater and noncontact cooling water, as well as process wastewater.

• 

### Pipe identification is not al ways clear. For some facilities, internal monitoring points are labeled as outfalls, and PCS and ICIS-NPDES may double-count a facility’s discharge. In other cases, an outfall may be labeled as an internal monitoring point, and PCS and ICIS-N PDES may not account for all of a facility’s discharge.

• 

### Facilities are identified by SIC code, not point source category. For some SIC codes, it may be difficult or impossible to identify the point source category that is the source of the repor ted wastewater discharges 5



### .

• 

### PCS and ICIS-NPDES were designed as a permit compliance tracking system and do not contain production information.

• 

### PC S and ICIS-NPDES data may be entere d into the data systems manually, which leads to data-entry errors.

• 

### In PC S and ICIS-NPDES, data may be re ported as an average quantity, maximum quantity, average concentration, maxi mum concentration, and/or minimum concentration. For many facili ties and/or pollutants, average quantity values are not provided. In these cases, EPA is lim ited to estimating facility loads based on the maximum quantity. Section 3.2.3 of the 2009 SLA Report discusses the maximum quantity issue in detail (U.S. EPA, 2009).

• 

### PCS a nd ICIS-NPDES data on conventiona l pollutants and the nutrients nitrogen and phosphorus are not used because of data quality concerns.

Despite these limitations, EPA determined that the data summarized in DMRLoads2008 were usable for the 2010 screening-level review s and prioritizations of the toxic-weighted pollutant loadings discharged by industrial facilities. The combined PCS and ICIS-NPDES databases remain the only data source quantifyi ng the pounds of regulated pollutants discharged directly to surface waters of the United States.

4 .2 Methodology Correction Affecting Both Screening-Level Review Databases

The 2009 SLA Report provides detailed info rmation on the methodology EPA used to develop the screening-le vel review databases (U.S. EPA, 2009). For the 2010 annual review, EPA made changes to the methodology used to develop the 2008 DMR and TRI databases. These methodology changes included the processi ng of the PCS data, the addition of minor

5 ICIS-NPDES includes a data field for applicable ELGs; ho wever, it is not required and typically not populated.Section 4 – Methodology, Data Sources, and Limitations



### 4-10 discharges to the 2008 DMR database, and a change to the dioxin distribu tion hierarchy in the

2008 TRI database. This subsect ion summarizes the methodology changes made by EPA to the 2010 screening-level re view databases.

4

.2.1 Summary of DMRLoads2008 Database Methodology Changes

The two major changes made to the DMRLoads2008 database, discussed in the subsections below, include changes made to th e PCS data processing an d the addition of minor dischargers.

PCS Data Processing

For the 2010 annual review, EPA generate d the industrial category rankings in

DMRLoads2008 for all U.S. states and territories/trib es from two data sources, PCS and ICISNPDES. As part of the 2010 annual review, EPA es timates the pollutant load for each facility by multiplying flow and concentration where appropriat e. That is, no load is estimated for internal outfalls, and EPA does not estimate a load for cer tain pollutants, such as pH. During previous annual reviews, EPA used a separate database to process PCS data. This year, EPA incorporated the PCS data processing (i.e., calculation a load using flow and concentr ation where appropriate) as an additional subroutine in the DMR Loadings Tool. The data analysis methodology in the DMR Loadings Tool subroutine is consistent with the PCSLoadCalculator

.

Addition of Minor Dischargers

Facilities in the DMRLoads database are classified as ei ther major or minor dischargers based on EPA’s major/minor clas sification system for industria l and municipal wastewater discharges. As discussed in the Section 4.1.5 , major discharges usually have the capability to impact receiving waters if not controlled. Minor discharges may or may not adversely impact receiving water if not controlled. Therefore, EP A does not require permitting authorities to enter

DMR data for facilities with mi nor discharges into PCS and ICIS-NPDES. As a result, discharge data for minor discharges in PCS and ICIS-NPDES may be incomplete.

EPA previously reviewed discharges for only major discharging fac ilities because of the possible incomplete data for minor discharg ing facilities. For th e 2010 annual review, EPA determined that including minor discharges would provide a more thorough review by identifying industries that may consist mostly of minor facilities or have high pollutant discharges because of contributing minor facilities. To determine if minor discharges are appropriately represented, EPA co mpared the number of minor di schargers in the DMR database to the number of minor dischargers that report water discharges for each state, presented in Table

4-2

.Section 4 – Methodology, Data Sources, and Limitations



### 4-11 Table 4-2. Number of Major and Minor Dischargers by State in DMR 2008

State or Territory/Tribe Minors a Minors with Water Discharges b Percent of Minors with Water Discharges

Alaska 3,302 20 0.6%

Alabama 10,175 961 9.4%

Arkansas 3,857 374 9.7%

American Samoa 4 0 0.0%

Arizona 104 9 8.7%

California 2,142 1 0.0%

Colorado 3,122 63 2.0%

Connecticut 739 74 10.0%

District of Columbia 128 7 5.5%

Delaware 35 21 60.0%

Florida 244 137 56.1%

Georgia 1,984 148 7.5%

Gulf of Mexico 649 0 0.0%

Guam 62 0 0.0%

Hawaii 3,096 13 0.4%

Iowa 1,535 420 27.4%

Idaho 966 81 8.4%

Illinois 11,487 770 6.7%

Indiana 4,105 1,140 27.8%

Johnston Atoll 1 0 0.0%

Kansas 1,166 24 2.1%

Kentucky 1,731 1,304 75.3%

Louisiana 16,787 28 0.2%

Massachusetts 1,225 156 12.7%

Maryland 4,168 589 14.1%

Maine 270 106 39.3%

Michigan 463 197 42.5%

Minnesota 685 9 1.3%

Missouri 2,894 1,148 39.7%

Northern Mariana Islands 11 0 0.0%

Mississippi 1,507 997 66.2%

Montana 3,869 169 4.4%

North Carolina 1,083 648 59.8%

North Dakota 111 1 0.9%

Nebraska 1,167 210 18.0%

New Hampshire 310 23 7.4%

New Jersey 3,649 498 13.6%

New Mexico 1,594 44 2.8%

Navajo Nation 45 2 4.4%

Nevada 461 1 0.2%Section 4 – Methodology, Data Sources, and Limitations



### 4-12 Table 4-2. Number of Major and Minor Dischargers by State in DMR 2008

State or Territory/Tribe Minors a Minors with Water Discharges b Percent of Minors with Water Discharges

New York 6,869 805 11.7%

Ohio 3,044 1,465 48.1%

Oklahoma 1,294 149 11.5%

Oregon 324 4 1.2%

Pennsylvania 10,613 20 0.2%

Puerto Rico 701 117 16.7%

Rhode Island 687 70 10.2%

South Carolina 371 250 67.4%

South Dakota 674 55 8.2%

St. Regis Mohawk Tribe 2 0 0.0%

Tennessee 2,050 576 28.1%

Texas 10,030 802 8.0%

Utah 2,815 70 2.5%

Virginia 966 2 0.2%

Virgin Islands 148 23 15.5%

Vermont 147 0 0.0%

Washington 438 34 7.8%

Wisconsin 830 0 0.0%

West Virginia 818 42 5.1%

Wyoming 1,305 11 0.8%

Total 135,059 14,888 11.0%

Source: DMRLoads2008_v2

. a – All minor dischargers in the 2008 DMR database. b – All minor dischargers with discharge data in the 2008 DMR database.



### To consistently compare major and minor facility discharges in the database, EPA used the same database methodologies an d procedures in place for review ing major facility discharges

to correct and review the minor facility discharge data. For exam ple, EPA used the same flow methodology for both major and minor facilities to autocorrect flows between 1,000 and 5,000 MGD (see Section 4.3.6 ). Because the DMRLoads2008 database consists of 90 percent minor facilities, EPA calculated the 2008 category ranki ngs with and without minor facilities to determine the impact it had on the 2010 category rankings, shown in Table C-7, in Appendix C. The addition of the minor dischargers to the 2008 DMR data increased the total number of facilities reviewed from 2,036 to 16,924. Because of the inconsistent minor water discharging data, EPA reviewed states where the majority of minors reported water discharges (e.g., Kentucky, Mississippi, and South Ca rolina). However, some states did not include any water discharge data from minor facil ities (e.g., Vermont and Wisconsin).

The addition of minor dischargers also resu lted in point source categories that EPA has not previously reviewed to be included in the top 95 percent of the 2010 annual review, such as: Landfills (40 CFR Part 445), Oil & Gas Extracti on (excluding coalbed methane operations) (40 CFR Part 435), and Metal Molding and Casti ng (Foundries) (40 CFR Part 464). For the 2010Section 4 – Methodology, Data Sources, and Limitations



### 4-13 annual review, EPA reviewed both major and minor top discharging facil ities for industrial categories with high TWPE (see Section 4.3.7 ).

4.2 .2 Summary of TRIReleases2008 Da tabase Methodology Changes

In the TRI database certain chemicals (PACs, dioxin and dioxin-like compounds, metal compounds) are reported as a class, not as individual compounds. Because the individual compounds in most classes have widely varying t oxic effects, the potential toxicity of chemical releases can be inaccurately estimated. Howe ver, for dioxin and dioxin-like compounds, reporting facilities are given the opportunity to report facility-sp ecific dioxin distributions that EPA uses to better estimate the pollutant TWPE.

The dioxin and dioxin-like compounds class in cludes 17 individual congeners, each with its own TWF. Facilities report a single mass number for the dioxin and dioxin-like compounds but can report the mass of each congener in a separate field (referred to as the dioxin distribution). For previous TRI reporting years, a facility could report only one dioxin congener distribution, even if dioxins are released to more than one medi um. As part of previous annual reviews, EPA determined that the majority of facilities use the dioxin congener distribution for air releases rather than water discharges. Howeve r, EPA used the reported distribution as it was

the best available information on th e wastewater dioxi n distribution.

Starting in 2008, facilities could report release-specific distributions. For example, if a facility had three stream discharges (e.g., su rface water discharge, ai r release, and POTW transfer), it could report a di stribution for each stream. As part of the data processing, the TRI Program calculates a total surface water release distribution by combining each of the individual

stream release distributions. For direct discha rges of dioxin and dioxin-like compounds, EPA

used the total surface water rel ease distribution. For facilities that leave the all congener distribution fields blank, EPA has worked with some trade as sociations to identify the most accurate distribution based on the manufacturing pr ocess generating the wastewater. Therefore, EPA revised the congener distribution hierarchy in the TRIReleases2008 database, presented in

Table 4-3 , to reflect the change in the TR I distribution reporting requirements.

Table 4-3. Dioxin and Dioxin-Like Compound s Distribution Selection Hierarchy for

TRIReleases2008

2008 TRI Prior TRI Databases

1. Assign the distribution reported by the facility, stored in TRI’s Water_Congener_2008 table.

• Dire ct discharge distribution is from the column “53 Total Water Release” b

• Indirect discharge distribution is from the column “61 POTW Transfer

Amount” Same a

2. If there are any changes identified fr om facility-specific follow-up (e.g. discussions with facilities from prior year s), assign that previously identified distribution. This distribution overwrites distributions applied in Step 1. Same

If the facility does not have a congener di stribution applied in Steps 1 or 2, then:

3. For facilities in the Pulp and Paper Category c , assign the “Pulp Default”

distribution. Same

4. For facilities in the Timber Products Category d , assign the “Wood Preserving

Default” distribution. SameSection 4 – Methodology, Data Sources, and Limitations



### 4-14 Table 4-3. Dioxin and Dioxin-Like Compound s Distribution Selection Hierarchy for

TRIReleases2008

2008 TRI Prior TRI Databases

5. Use the NAICS average distribution. For facilities in the same category, start with the smaller subset of the NAICS code, and then if none of that subset reports a distribution, go to a larger set of NAICS codes. e Same

6. Assign the distribution reported by the facility for “52 Stack Air” stored in TRI’s Congener_2008 table f

. NA

7. Use the TWF for CAS number N150 (dioxin and dioxin-like compounds), which is congener 7, the median of the 17 TWFs for dioxin and dioxin-like compounds. Same

a – Previous TRI data included only one distribution for each facility. The TRI 2008 data includes separate

distributions for each release. b – EPA selected the “Total Water Release” distribution rather than using the distributions for each discharge to a receiving stream because the majority of facilities did not report distributions for each receiving stream discharge. c – Congener distribution is applied only to facilities reporting NAICS codes 322110, 322121, 322122, and 322130. Facilities reporting other NAICS codes that link to the Pu lp and Paper Category do not get the “Pulp Default” congener distribution. d – Congener distribution is applied only to fac ilities reporting NAICS codes 321114 and 113310. Facilities reporting other NAICS codes that link to the Timber Products Category do not get the “Wood Preserving Default” congener distribution. e – Step 5 Example for a Pulp and Paper Category facility. Facility A has a primary NAICS code 322291, reported dioxin, and left distribution blank. Steps 1 through 4 do not apply (therefore, no distribution has been applied using the hierarchy yet). Facilities B, C, and D primary NAICS codes 322291-2. Facility B reported a distribution (Step 1). Facilities C and D did not report one, and they did not get one assigned from Steps 1 through 4. In this hierarchy, first we calculate the NAICS average congener distributio n on both 322291 (no distribution available) and then 322291-2 (resulting in a distribution). Then we assign the 322291-2 results to Facilities A, C, and D. Second, we make another attempt to calculate the average distribution for NAICS 322291. We calculate the average distribution for NAICS 322291 and 322291-2. This will be assign ed to the facility reporting 322291 (Facility A).

f – EPA selected the “Stack Air” distri bution because facilities populated this field most frequently in the 2008 TRI

data. NA – Not applicable.



### In TRIReleases2008 , 121 facilities reported diox in and dioxin-like compounds. Table 4-4 presents the number of faciliti es that reported a dioxin distribu tion for their water releases and the number of facilities that were assigned a distribution from the hierarchy. As shown in Table

4-4 , approximately 34 percent of facilities reporting dioxin and dioxin-like compounds reported a specific water release distribution. For the rema ining facilities, EPA used the hierarchy to assign the dioxin distributions.Section 4 – Methodology, Data Sources, and Limitations



### 4-15 Table 4-4. Number of Facilities Assigned Each Dioxin Distribution Hierarchy in TRI

2008

Hierarchy

Number Abbreviated

Name Number of Facilities Assigned the

Distribution Percent of Total FacilitiesReporting Dioxin and DioxinLike Compounds

1 Reported Direct 36 29.7% Reported Indirect 5 4.1%

2 Manual 5 4.1%

3 Pulp & Paper 31 25.6%

4 Wood Preserving 9 7.4%

5 NAICS Average 11 9.1%

6 Stack Air 15 12.4%

7 N150 9 7.4%

Total 121 100%

Source: TRICalculations2008_v3

.



### 4 .3 Corrections to the DMRLoads2008 Database

EPA developed the DMRLoads2008 database as part of the 2010 annual review using the methodology explained in the 2009 SLA Report (U .S. EPA, 2009) with the methodology updates

described in Section 4.2.1

.

During previous screening-level analyses, EPA identified numerous facility-specific

corrections for PCS and ICIS-NDPES data reported for calendar years 2000, 2002, 2004, 2006,

and 2007. Several of these corrections similarl y apply to the 2008 DMR data. In addition, EPA reviewed the quality of the 2008 DMR data and facili ties with discharges that have the greatest impact on total category loads and category ranki ngs. Table B-2 in Appendix B of this report lists all corrections made to the 2008 DMR data in the DMR Loadings Tool.

4

.3.1 DMRLoads2008: Categorization of Discharges

This subsection describes database corrections to facility categorization and pollutant discharges in DMRLoads2008 . Section 4 of the 2009 SLA Report describes the SIC/Point Source Category Crosswalk development, which EPA uses to link between facility SIC codes and categories with existing ELGs (U.S. EPA, 2009). Because most point source categories are not defined by SIC code, the relations hip between SIC code and point source category is not a oneto-one correlation. A single SIC code may include facilities in more than one point source category, and associating an SIC code with onl y one category may be an oversimplification. Also, many facilities have operatio ns subject to more than one point source category. Further, facilities in some categories ca nnot be identified by SIC code (e.g., Centralized Waste Treatment facilities). Section 4 of the 2009 SLA Report descri bes the database changes, summarized below (U.S. EPA, 2009):

• 

### Facility-Level Point Source Category Assignment . For some SIC codes that include facilities subject to guidelines from more than one point source category, EPA was able to assign each facility to the category that best applied to the majority of its discharges. EPA reviewed information available about each facility to determine which point source category applied to the facility’s operations.Section 4 – Methodology, Data Sources, and Limitations



### 4-16 • 

### Poll utant-Level Point So urce Category Assignment . Many facilities have operations subject to more than one poi nt source category. For most of these facilities, EPA cannot divide the pollutan t discharges among the applicable point source categories. Two exceptions where EPA was able to assign wastewater discharges of certain chemicals to the a ppropriate point source category are listed

below:

— Organic Chemicals, Plastics, and Sy nthetic Fibers (OCPSF)/Pesticide Chemicals. EPA removed all pesticide discharges from the OCPSF Category and included them as discha rges from the Pesticide Chemicals Category.

— Metal Products and Machinery (MP&M) /Metal Finishing. EPA used the methodologies described in Section 4 of the 2009 SLA Report (U.S. EPA, 2009) to apportion pollutant loads between the MP&M and Metal Finishing Categories.

4

.3.2 DMRLoads2008: Internal Monitoring

This subsection describes database corrections to identify internal monitoring points in

DMRLoads2008 . As discussed in Sections 3.2.1.3 and 3.2.3.2 of the 2009 SLA Report (U.S. EPA, 2009), the 2008 DMR Loadings Tool calculate d loads only for monitoring locations that

are labeled as effluent. The e ffluent monitoring locations in the 2008 DMR Loadings Tool are:

• 

### MLOC 1 – Effluent net discharge;

• 

### MLOC 2 – Effluent gross discharge;

• 

### MLOC A – After disinfection;

• 

### MLOC B – Before disinfection; and

• 

### MLOC SC – See comments.

As a result, the DMR Loadings Tool excl udes discharges for internal monitoring locations such as intake water, influent to treatment, and intermediate points in the wastewater treatment system. However, during previous category reviews and de tailed studies, EPA

identified instances of double-c ounting that resulted from incl uding certain internal monitoring points in the loads database. For example, a facility monitors for Pollutant A at the effluent from its wastewater treatment system (internal Outfal l 101). Outfall 101 wastewat er is later combined with other plant discharges at final Outfall 001 and is discharged to a receiving stream. The facility also monitors for Pollutant A at fina l Outfall 001. Both outfalls are effluent monitoring points identified as MLOC 1 or MLOC 2; however , Outfall 101 is upstream of the final outfall. Calculating loads for Pollutant A at both the in ternal and final outfalls double-counting Pollutant A discharges. EPA identified instances where pollutant discharges are reported for multiple monitoring locations along the same discharge line and eliminated the discharges for the upstream monitoring locations. EPA made these corrections to the 2008 data in the DMR Loadings Tool. A complete list of these correc tions made in the DMR Loadings Tool can be found in Table B-2 of Appendix B of this report.

4.3.3 DMRLoads2008: Intermittent Discharges

This section describes database correcti ons made for intermittent discharges in

DMRLoads2008 . As described in Sections 3.2.1.3 and 3.2.3.2 of the 2009 SLA Report (U.S.Section 4 – Methodology, Data Sources, and Limitations



### 4-17 EPA, 2009), the DMR Loadings Tool assumes that all discharges in PCS and ICIS-NPDES are continuous (24 hours per day for all days in th e monitoring period). During previous annual reviews, EPA identified facility discharges that are intermittent and therefore are overestimated by the DMR Loadings Tool. EPA calculated annual loads for these discharges based on information obtained from the facility on the fr equency and duration of wastewater discharges.

EPA made these corrections in the 2 008 data in the DMR Loadings Tool.

4

.3.4 DMRLoads2008: Excluded Pollutant Parameters

This section describes database corrections made to exclude selected water quality parameters and flow from the annual load calcul ation in 2008 DMR Loadi ngs Tool. As described

in Sections 3.2.1.3 and 3.2.3.2 of the 2009 SLA Re port (U.S. EPA, 2009) , facilities report pollutant mass quantities, pollutant concentrations , and wastewater flow rates to PCS and ICISNPDES using a variety of units. EPA’s PCS CNVRT program and the ICIS-NPDES Convert Module convert the discharges into standard units of kilograms per day (kg/day) for mass quantities, milligrams per liter (mg/L) for concentrations, and millions of gallons per day (MGD) for flow rates. However, some parameters are re ported in units that ca nnot be converted into kg/day or mg/L (e.g., temperature, pH, fecal coli form, whole effluent toxicity). EPA excluded these parameters from the screening-level anal ysis. Table B-3 of Appe ndix B lists the excluded
parameters.

4

.3.5 DMRLoads2008: Pollutant Corrections

This section describes database changes ma de to discharges of specific pollutants reported to the DMR for EPA’s 2010 screening-level review in the 2008 DMR Loadings Tool.

During the reasonableness checks of the PCS CNVRT output, EPA identified unusually high mercury concentrations reported to PCS by facilities located in Ohio in the PCS CNVRT output. These facilities reported mercury disc harges using PRAM 50092 (Mercury Total Low Level). The PRAM 50092 concentrations in th e 2004 CNVRT output ranged from 0.2 to 673 mg/L from 0.001 to 380,000 mg/L in the 2008 CNVRT output. EPA contacted the Ohio Environmental Protection Agency (Ohio EPA) to determine the correct reporting units for PRAM 50092 (Stuhlfauth, 2007). An Ohio EPA representative explained that Ohio EPA started requiring low level mercury analyses in 2002. At that time, some facilities had limits in micrograms per liter ( μ g/L). Currently, all of the limits are in nanograms per liter (ng/L).

As a result of this contact, EPA conc luded that the units for the PRAM 50092 concentrations for the 2004 PCS data should be ng/L, not mg/L. The PRAM 50092

concentrations in the 2008 CN VRT output ranged from 0.001 to 380,000 mg/L with greater than 98 percent of these concentrations between 0.1 and 1,000 mg/L. Based on this distribution, EPA concluded that the error for the 2004 data pe rsisted in 2008. Therefore, EPA corrected the concentrations by dividing all concentrations fo r PRAM 50092 reported by facilities in Ohio in the DMR Pollutant Loadings Tool by one million.

4

.3.6 DMRLoads2008: Data Quality Review

EPA evaluated the quality of the PCS a nd ICIS-NPDES DMR data for use in

DMRLoads2008 as part of the 2010 screen ing-level review. This ev aluation considered data completeness, accuracy, reasonableness, and comparability. The Quality Assurance Project PlanSection 4 – Methodology, Data Sources, and Limitations



### 4-18 for the 2009 Annual Screening-Level Analysis of TRI and PCS Industrial Category Discharge

Data describe the quality objectives in more de tail (ERG, 2009). EPA conducted quality reviews for three stages of the development of DMRLoads2008 : 1) PCS CNVRT and ICIS-NPDES Convert Module outputs; 2) the 2008 DMR Loadings Tool output; and 3) DMRLoads2008 results. The following discussion provides an overvie w of the quality review steps for each stage:

• 

### PCS CNVRT and ICIS-NPDES Convert Module outputs . EPA conducted an initial quality review of the extracted PCS CNVRT and ICIS-NPDES DMR data to evaluate its completeness, reasonableness, and comparability. For completeness, EPA compared the number of major facilities and the universe of

SIC codes in the 2008 DMR data to the DMR data in 2007.

EPA reviewed the DMR data for reasona bleness to identify any data quality issues, such as misreported units that the PCS CNVRT and ICIS-NPDES Convert

Module did not correct. EPA identified seve ral wastewater flows that exceeded the reasonable range. EPA reviewed these flows and developed the flow

correction function for the PCS CNVR T and ICIS-NPDES Convert Module (described in Section 3.2.3 of the 2009 SLA Report (U.S. EPA, 2009)). This function is designed to identify data en try errors for flows greater than 1,000

MGD. The PCS CNVRT and ICIS-NPDES Convert Module corrects all flows exceeding 5,000 MGD and applies more conservative criteria to correct flows from 1,000 to 5,000 MGD. The PCS CNVR T and ICIS-NPDES Convert Module made the following corrections to the PCS and ICIS-NPDES wastewater flows:

— 559 corrections based on m onth-to-month variations;

— 379 corrections based on comparing flows to design flows; and

— 470 corrections based on assuming that flows exceeding 5,000 MGD are reported in units of GPD.

• 

### Load Calculator routines. EPA’s quality review for the Load Calculator routines included accuracy checks for database queries on the 2008 data in the DMR Loadings Tool. EPA reviewed the program ming code used to develop each query to verify the logic and ve rified that the number of records in the output table equaled the number of records in intermedia te queries to ensure that no data were missing and that there were no duplicate data. In addition, EPA performed hand calculations to verify the accuracy of th e Load Calculator module outputs during reviews of facility discharges for DMRLoads2008 results.

• 

### DMRLoads2008 results. EPA’s quality review of the DMRLoads2008 results included the following:

— Completeness checks . EPA compared counts of dischargers in

DMRLoads2008 to DMRLoads2007 to confirm the completeness of the database. There were 2,018 major disc harging facilities that reported a

load to DMRLoads2007 and 2,036 major discharging facilities that reported a load to DMRLoads2008 . There were 14,888 minor discharging facilities that reported a load to DMRLoads2008 ; however, EPA did not include minor discharges in previ ous review. Therefore, EPA cannot

determine if DMRLoads2008 is complete.Section 4 – Methodology, Data Sources, and Limitations



### 4-19 — Accuracy of facility discharges . EPA reviewed the accu racy of facilities’ discharges that had the greatest impact on total category loads and category rankings to identify possibl e calculation errors. EPA reviewed monitoring period data in PCS a nd ICIS-NPDES, measurement data

available on EPA’s Envirofacts web page, and information from each facility’s NPDES permit and permit fact sheet. In some cases, EPA contacted facilities to verify the measurements in their DMR. Section

4.3.7 describes EPA’s review of facili ty discharges in more detail.

— Accuracy of category discharges . EPA reviewed the accuracy of category discharges by verifying that pollutant discharges in PCS and ICIS-NPDES were assigned to the appropriate point source category. EPA used engineering judgment to determine if the pollutant discharge was reasonably associated with the point source category. Section 4.3.1 discusses facility-level and pollu tant-level category assignments.

— Accuracy of database queries . EPA’s quality review for the development

of DMRLoads2008 included accuracy checks for database queries in DMRLoadsAnalysis2008 6 

### and DMRLoads2008 . Documentation of accuracy checks is provided in a QC table in each Microsoft AccessTM

database.

— Reasonableness of pollutant loads . EPA reviewed the DMR Loadings Tool’s 2008 output (i.e., th e calculated kg/year for each pollutant at each discharge pipe and monitoring locati on) for those pollutant discharges with the highest toxic-weighted lo ads (e.g., dioxins, polychlorinated biphenyls (PCBs), and mercury). To id entify possible erro rs in recording units of measure, EPA identified calculat ed discharges that were orders of magnitude higher than previous years’ discharges or discharges from other facilities within the same categ ory. EPA reviewed quantities or

concentrations and flows that the DM R Loadings Tool database used to calculate the annual discharge. EPA compared these measurements with

measurements available on EPA’s Envirofacts web page. If the measurements were similar, then EPA concluded that the output was acceptable. If the data did not match between the databases and Envirofacts, EPA corrected the data to match Envirofacts. When EPA was unsure what the correct data were, EPA contacted the facility or permitting authority for more information (see Section 4.3.7 ).

— Reasonableness of facility loads . EPA identified facility discharges with the highest TWPE. EPA identified faci lities for review whose pollutant discharges accounted for more than 95 percent of the TWPE for their point source category. EPA compared 2008 DMR data to other available

6 DMRLoadsAnaysis2008 is a database used to evaluate the impacts of calculation assumptions and corrects SIC

Code classifications fo r certain facilities and certain discharges (i.e., OCSPF and Pesticide discharges). See Section 3.2 of the 2009 SLA Report for further information (U.S. EPA, 2009).Section 4 – Methodology, Data Sources, and Limitations



### 4-20 information, such as information fr om EPA’s Envirofacts web page, and the facility’s NPDES permit and perm it fact sheet. If the data did not

match between the database and Enviro facts, EPA corrected the data to

match Envirofacts. When EPA was uns ure what the correct data were, EPA contacted the facility or perm itting authority for more information (see Section 4.3.7 ).

— Comparability . EPA compared DMRLoads2008 to DMRLoads2007 to identify pollutant discharges or wast ewater flows that differed more than the year-to-year variation of other chemicals and facilities. EPA used this comparison to determine if quantity, concentration, or flow corrections were needed for facility discharges with the highest TWPE. If the comparison was unavailable (e.g., th e pollutant was not previously reported) EPA contacted the facility or permitting authority (see Section

4.3.7 ).

4

.3.7 DMRLoads2008: Facility Reviews

EPA reviewed the accuracy of facility discha rges that had the greatest impact on total category loads and category rankings in DMRLoads2008 . EPA reviewed facilities with the highest toxic-weighted discharges of individual pollutant parameters. For the identified facilities, EPA used the following steps to review the accuracy of the loads calculated from PCS and ICISNPDES data:

1

. Reviewed database corrections for DMRLoads2007, PCSLoads2004

, PCSLoads2002, and PCSLoads2000 to determine whether corrections were made during previous reviews and evalua ted whether EPA should apply these corrections to the 2008 DMR discharges.

2. Rev iewed 2008 DMR data, hand-calculated a nnual pollutant loads, and compared the results to loads calculated by th e DMR Loading Tool and stored in

DMRLoads2008

.

3. Reviewed PCS and ICIS-NPDES pipe desc ription information available in PCS, EPA’s on-line Envirofacts data system, ICIS-NPDES supporti ng tables, or from the facility’s NPDES permit and permit fact sheet to identify monitored pollutant discharges that are:

— I ntermittent (e.g., tidal, seasonal, or occur after a storm event);

— I nternal monitoring locations from which wastewater is combined with

other waste streams and monitored again, resulting in double-counting loads; and

— Not representative of category disc harges (e.g., stormwater runoff from
nonprocess areas, noncontact cooling water, or wastewater related to operations in another point source category).

Table 4-5 presents EPA’s facility review and corrections made to the DMRLoads2008

database.Section 4 – Methodology, Data Sources, and Limitations4-21Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionMonongahela PowerCompanyWillow Island,WVSteam ElectricPower GeneratingChlorineOutfall 001 free chlorine Jul 2008concentration is 1,000 timeshigher than other monthlyconcentrations. Outfall 001 totalresidual chlorine Sept and Oct2008 concentrations were in mg/Lin the DMR Loadings Tool, whileEnvirofacts concentrations are inug/L.Revise Jul 2008 free chlorine andSept and Oct 2008 total residualchlorine concentrations bydividing by 1,000.Fulton CountyCommissionersOHSanitaryLowLevelMercuryOutfall 001 low level mercurySept 2008 concentration in theDMR Loadings Tool is 1,000,000times higher than theconcentrations reported inEnvirofacts.Revise Sept 2008 mercuryconcentration by dividing by1,000,000. Revise number ofreporting units and number ofdays to reflect annual reporting.General Electric – ErieErie, PAMetal FinishingMercuryOutfall 001 mercury 2008concentration in the DMRLoadings Tool is 1,000,000 timeshigher than the 2007 concentrationthat EPA corrected as a result offacility-provided information.Revise all mercuryconcentrations by dividing by1,000,000.Ohio Valley CoalCompanyWashington TWP,OHCoal MiningSeleniumOutfall 001 selenium Dec 2008concentration in the DMRLoadings Tool is 1,000,000 timeshigher than other monthlyconcentrations.Revise Dec 2008 seleniumconcentration by dividing by1,000,000. Revise number ofreporting units and number ofdays to reflect quarterlyreporting.Section 4 – Methodology, Data Sources, and Limitations4-22Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionTX Eastern TransGladevilleGladeville, TNElectric & GasPCBsOutfall 002 PCB Jan 2008concentration in the DMRLoadings Tool is 1,000 timeshigher than other monthlyconcentrations. Envirofacts unitsfor Jan 2008 areμg/L, not mg/L.Revise Jan 2008 PCBconcentration by dividing by1,000.Village of ElidaElida, OHNonclassifiableLow LevelMercuryOutfall 001 low level mercury Jun,Aug, and Sept 2008concentrations are in the DMRLoadings Tool as mg/L, while theconcentrations in Envirofacts arein ng/L.Revise Jun, Aug, and Sept 2008low level mercury concentrationsby dividing by 1,000,000. Revisenumber of reporting units andnumber of days to reflectquarterly reporting.Clemson UniversityWWTFClemson, SCEducationTotal MercuryOutfall 001 Mar, Jun, Sept 2008total mercury concentrations in theDMR Loadings Tool do not matchthe concentrations in Envirofacts.Revise total mercuryconcentration values. Revisenumber of reporting units andnumber of days to reflectquarterly reporting.Carbon Limestone LandfillOHLandfillsLow LevelMercuryOutfall 001 low level mercury Janand Dec 2008 concentrations arein the DMR Loadings Tool asmg/L, while concentrations inEnvirofacts are in ng/L.Revise Jan and Dec 2008mercury concentrations bydividing by 1,000,000.Tysons Foods, Inc.Carthage, MSMeat and PoultryProductsMercuryFacility contact identified that the2008 total recoverable mercuryconcentrations for outfall 001were reported as ng/L but were inthe DMR Loadings Tool as mg/L(Lovitt, 2010).Revise mercury concentration bydividing by 1,000,000. Revisemercury quantities to reflectconcentrations updates.Section 4 – Methodology, Data Sources, and Limitations4-23Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionAKZO Nobel FunctionalChemicalAxis, ALInorganicChemicalsTotal MercuryOutfall 006 Dec 2008 totalmercury concentration is 1,000times higher than otherconcentrations in the DMRLoadings Tool. Facility contactconfirmed that the Dec 2008 totalmercury concentration wasreported inμg/L, but was in theDMR Loadings Tool as mg/L(Williams, 2010).Revise Dec 2008 total mercuryconcentration by dividing by1,000.Arcelormittal Weirton,Inc.Weirton, WVIron andSteelCyanideOutfall003 Aug 2008 cyanideconcentration in the DMRLoadings Tool is 1,000 timeshigher than other monthlyconcentrations.Revise Aug 2008 cyanideconcentration by dividing by1,000.USEC PDGDPMcCracken, KYNonferrous MetalsManufacturingPCBsFacility contact verified the 2008PCB concentrations in the DMRLoadings Tool and indicated thatthe outfalls are for stormwaterrunoff. The PCBs are due tolegacy activity at the site, and thefacility treats all process water thatmay have PCBs using carbonadsorption (Travis, 2010).No action.Cargill Corn Milling(Progold)Wahpeton, NDGrain MillsChlorideOutfall 001 Jan 2008 chlorideconcentration is 10,000 timeshigher than other monthlyconcentrations in the DMRLoadings Tool. Also, Jan 2008average concentration reported is10,000 higher than the maximumconcentration.Revise Jan 2008 average chlorideconcentration by dividing by10,000.Marathon Oil – MaverickSpringsFremont County,WYOil & GasExtractionSulfur2008 sulfide concentrations arecomparable to 2007 and 2009concentrations.No action.Section 4 – Methodology, Data Sources, and Limitations4-24Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionSmithfield Packing Co IncTarHeel, NCMeat and PoultryProductsChlorineOutfall 001 Apr through Sept2008 chlorine concentrations arein the DMR Loadings Tool asmg/L, while the concentrations inEnvirofacts are in μg/L.Revise Apr through Sept 2008chlorine concentrations bydividing by 1,000.Clear Lakes TroutCompanyBuhl, IDConcentratedAquatic AnimalProductionCopperOutfall 001 Jan 2008 copperconcentration is 9 mg/L, but allother months are No DataIndicator (NODI) 9 in the DMRLoadings Tool. Facility contactverified that the copper Jan 2008concentration was a data entryerror (Bogaard, 2010).Delete Jan 2008 copperconcentration and change NODIcode to 9.Hercules, IncorporatedBrunswick, GAGum and WoodToxapheneFacility contact stated that theoutfall 001 2008 toxapheneconcentrations were reversed withthe total suspended solids (TSS)concentrations. Facility contactstated that the toxapheneconcentrations are all belowdetection limit (BDL) (Bernarack,2010).Reverse all toxapheneconcentrations and TSSconcentrations and add BDLindicators to all toxapheneconcentrations.Valley View LandfillTrimble County,KYLandfillsMercuryOutfall 001 Jun 2008 and outfall004 Mar 2008 mercuryconcentrations were highcompared to the otherconcentrations reported. Facilitycontact stated that theconcentrations for both outfallsshould be reported as nondetect.The contact also stated that theconcentration value should be0.0002, not 40 (Knarr, 2010).Revise outfall 001 Jun 2008 andoutfall 004 Mar 2008 mercuryconcentrations to 0.0002 mg/Land add BDL indicators tomercury concentrations.Section 4 – Methodology, Data Sources, and Limitations4-25Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionFormer Koppers FacilityKansas City, MOTimberTCDDFacility contact confirmed that alloutfall 004 and 005 2008 TCDDconcentrations were all nondetect(Rayna, 2010). Number of daysand number of reporting units didnot match reported concentrations.Add BDL indicators to all 2008TCDD concentrations foroutfalls 004 and 005. Revise thenumber of reporting units andnumber of days.EI DuPont De Nemours &CoWashington, WVOCPSFHexachlorobenzeneOutfall 002, 005, and 102 2008hexachlorobenzene concentrationsare reported as the sameconcentration for all months.Therefore, assumed that all theconcentrations should benondetect.Add BDL indicators to all 2008hexachlorobenzeneconcentrations for outfalls 002,005, and 102.Eastman Chemicals/SCOperationsSaint Matthews,SCOCPSFMercuryOutfall 001 Jan 2008 mercuryconcentrations has a leading (i.e.,prior to the decimal place) 4 in theDMR Loadings Tool, whileEnvirofacts has a leading 0.Revise Jan 2008 mercuryconcentration value to removethe leading 4.Galey & Lord/Society HillSociety Hill, SCTextile millsMercuryOutfall 001 2008 total mercuryconcentration has a leading (i.e.,prior to the decimal place) 4 in theDMR Loadings Tool, whileEnvirofacts has leading 0.Revise 2008 total mercuryconcentration value to removethe leading 4.Wyeth ResearchChazy, NYLabsMercuryOutfall 001 Jul 2008 mercuryquantity in the DMR LoadingsTool does not match the quantitycalculated using the concentrationand flow or data in Envirofacts.EPA used the concentration andflow to calculate the correctquantity.Revise Jul 2008 mercuryquantity.Section 4 – Methodology, Data Sources, and Limitations4-26Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionBridgeport Water PlantBridgeport, OHDrinking WaterManganeseOutfall 002 Feb, Apr, and Nov2008 manganese quantities in theDMR Loadings Tool do not matchquantities calculated using theconcentration and flow or the datareported in Envirofacts. EPA usedthe concentration and flow tocalculate the correct quantity.Revise hexachlorobenzenequantity to match data reportedin EnvirofactsKoppers Industries IncFollansbee, WVOCPSFHexachlorobenzeneOutfall 101 Feb 2008hexachlorobenzene quantities inthe DMR Loadings Tool do notmatch data reported inEnvirofacts.Revise hexachlorobenzenequantity.ASA EthanolBloomingburg, LLCOHOCSPFIron, FluorideOutfall 001 Mar and Apr 2008fluoride quantities are 1,000,000times higher than the calculatedquantities using the concentrationsand flows in the DMR LoadingsTool. Iron quantities for May andAug through Dec 2008 have aleading (i.e., prior to the decimalplace) 4 in the DMR LoadingsTool, while Envirofacts hasleading 0.Revise Mar and Apr 2008fluoride quantities by dividing by1,000,000. Revise May and Augthrough Dec 2008 iron quantitiesto remove the leading 4.Special Metals CorpNew Hartford, NYNonferrous metalsmanufacturingPCB-1254Outfall 001 PCB-1254 quantityare 1,000 times higher than whenthe quantity is calculated using theconcentration and flow in theDMR Loadings Tool. Allconcentrations were also reportedas non-detect in the DMRLoadings Tool.Revise PCB-1254 quantity tomatch quantity calculated usingconcentration and flow. Also,add BDL indicators to PCB-1254quantities.Section 4 – Methodology, Data Sources, and Limitations4-27Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionSmith’s Pleasant ValleyOHNonclassifiableChlorineOutfall 001 Jun, Aug, and Oct2008 flows are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are in GPD.Revise Jun, Aug, and Oct 2008flows for Outfall 001 by dividingby 1,000,000.Bulk Plant IncFlemingsbrg #39Fleming County,KYPetroleumRefiningBenzeneOutfall 001 flows for Mar, Jun,and Sept 2008 are extremely high(between 4,000 and 30,000MGD). Flows should be reportedas GPD, not MGD.Revise Mar, Jun, and Sept flowsfor Outfall 001 by dividing by1,000,000.Pelican GroveCampgroundOHHotels & OtherLodging PlacesChlorineOutfall 001 flows for 2008 are inthe DMR Loadings Tool as MGD,while flows in Envirofacts are inGPD.Revise flows for Outfall 001 bydividing by 1,000,000.SPARTA Water TreatmentPlantSparta, TNDrinking WaterTreatmentChlorineOutfall 001 flows for Jan throughJul 2008 are not consistent withother months, or the data reportedin Envirofacts for 2009.Revise Jan through Jul 2008flows for Outfall 001 by dividingby 1,000,000.CAPPS TavernOHFood ServiceEstablishmentsChlorineOutfall 001 flows for 2008,excluding Jan and Oct, are in theDMR Loadings Tool as MGD,while flows in Envirofacts are inGPD.Revise flows, excluding Jan andOct, for Outfall 001 by dividingby 1,000,000.Saint Ilija MacadonianChurchOHMembershipOrganizationsChlorineOutfall 001 flows for 2008 are inthe DMR Loadings Tool as MGD,while flows in Envirofacts are inGPD.Revise flows for Outfall 001 bydividing by 1,000,000.Contech U.S. LLCPierceton, INWholesale TradeDurable GoodsLeadOutfall 001 flow for Feb 2008 isreported in the DMR LoadingsTool as MGD, while other flowsin the DMR Loadings Tool arereported as GPD.Revise flow for Feb 2008 forOutfall 001 by dividing by1,000,000.Section 4 – Methodology, Data Sources, and Limitations4-28Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionNorbet Fun FamilyBowlingOHAmusement&RecreationServicesChlorineOutfall 001 flows for 2008,excluding Jan and Apr, are in theDMR Loadings Tool as MGD,while flows in Envirofacts are inGPD.Revise flows excluding Jan andApr, for Outfall 001 by dividingby 1,000,000.SAKAS, Inc.OHMetal FinishingChlorineOutfall 001 flows for 2008 are inthe DMR Loadings Tool as MGD,while flows in Envirofacts are inGPD.Revise flows for Outfall 001 bydividing by 1,000,000.Dowel Town-Liberty WTPLiberty, TNDrinking WaterTreatmentAluminumOutfall 001 flows for Jan, Mar,and May 2008 are 1,000,000 timeshigher than other reported flowsand the design flow.Revise flows for Outfall 001(Jan, Mar, May 2008) bydividing by 1,000,000.Speedway Super AmericaLLCOHAutomotiveDealers & ServiceStationsChlorineOutfall 001 flows for 2008,excluding Jul, are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are in GPD.Revise flows, excluding Jul, forOutfall 001 by dividing by1,000,000.Le-O-Na Falls MobileHome ParkOHReal EstateChlorineOutfall 001 flows for 2008,excluding Jul, are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are in GPD.Revise flows, excluding Jul, forOutfall 001 by dividing by1,000,000.MSAD #9Farmington, MEEducationChlorineOutfall 001 flows for 2008, exceptSept and Oct, are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are reportedas GPD.Revise flows, excluding Sept andOct, for Outfall 001 by dividingby 1,000,000.MSAD #52Turner, MEEducationChlorineOutfall 001 flows for 2008, exceptJun through Aug, are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are in GPD.Revise flows, except Jun throughAug, for Outfall 001 by dividingby 1,000,000.Section 4 – Methodology, Data Sources, and Limitations4-29Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionMEAD Depot LandfillOHWaste CombustorsManganeseOutfall 001 flows for Aug throughDec 2008 and Outfall 002 flowsfor Jan and Mar through Aug 2008are in the DMR Loadings Tool asMGD, while flows in Envirofactsare in GPD.Revise flows listed as MGD forOutfall 001 and Outfall 002 bydividing by 1,000,000.Charm Countryview Inn,Inc.OHFood ServiceChlorineOutfall 001 flows for Feb throughOct 2008 are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are in GPD.Revise flows for Feb through Oct2008 for Outfall 001 by dividingby 1,000,000.Korner KitchenOHFood ServiceChlorineOutfall 001 flows for Feb throughDec 2008 are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are in GPD.Revise flows for Feb throughDec 2008 for Outfall 001 bydividing by 1,000,000.EnvirosystemsIncorporatedHampton, NHIndependent andStand Alone LabsCadmiumOutfall 002 flows for Sept and Oct2008 (DRIDs A and B) were1,000,000 times higher than othermonths reported and the permitdesign flow is 400 GPD (U.S.EPA Region 1, 2006).Revise Sept and Oct 2008 flowsfor Outfall 002 by dividing by1,000,000.Bullitt Co LandfillBullitt County,KYLandfillsIronOutfall 001 flows for Jan, July,and October 2008 were 1,000,000times higher than other flowsreported. KY DEP PermitManager indicated that flows forJan, July, and October 2008 werereported as GPD, not MGD. Alsonoted that the facility was amunicipal waste landfill (Becker,2010).Revise flows for Jan, July, andOctober 2008 for Outfall 001 andchange SIC code to link to theLandfills Category only.Stevens Aviation, Inc.Vandalia, OHWholesale TradeNondurable GoodsLeadOutfall 001 flow for Aug 2008 isin the DMR Loadings Tool asMGD, while flow in Envirofacts isin GPD.Revise flow for Aug 2008 forOutfall 001 by dividing by1,000,000.Section 4 – Methodology, Data Sources, and Limitations4-30Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionReed Duplex Apt BLDGMadison County,KYReal EstateChlorineOutfall 001 flow for Sept 2008was high compared to other flows.KY DEP Permit Managerindicated permit design flow is0.001 MGD and that the facilityreported incorrect units (MGDinstead of GPD) (Becker, 2010).Revise flow for Sept 2008 forOutfall 001 by dividing by1,000,000.Deborah K. SchiemannOHSocial ServicesChlorineOutfall 001 flows for May throughOct 2008 are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are in GPD.Revise flows for May throughOct 2008 for Outfall 001 bydividing by 1,000,000.John W Black AquaticCenterOldham County,KYAmusement &RecreationServicesChlorineOutfall 001 flows for May throughSept 2008 are all reported in theLoadings Tool as MGD, butassumed were reported as GPDbecause of the nature of thefacility (aquatic center).Revise flows for May throughSept 2008 for Outfall 001 bydividing by 1,000,000.Sugar Grove Bible ChurchOHMembershipOrganizationsChlorineOutfall 001 flows for 2008 are inthe DMR Loadings Tool as MGD,while flows in Envirofacts are inGPD.Revise flows for Outfall 001 bydividing by 1,000,000.Wullenweber MotorsOHWholesale TradeDurable GoodsChlorineOutfall 001 flows for Jan throughMay, July, Aug, and Dec 2008 arein the DMR Loadings Tool asMGD, while flows in Envirofactsare in GPD.Revise flows for months listingflow units of MGD for Outfall001 by dividing by 1,000,000.Cognis CorporationOHOCPSFCopperOutfall 010 flows for Oct 2008and outfall 033 flows for May,Aug, Nov 2008 are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are in GPD.Revise MGD flows for Outfalls010 and 033 by dividing by1,000,000.Section 4 – Methodology, Data Sources, and Limitations4-31Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionHoliday Motel WWTFCleveland, TXHotels & OtherLodging PlacesChlorineOutfall 001 flows for Feb, Jun,and Oct 2008 are 1,000,000 timeshigher than flows reported for theother months.Revise flows for Feb, June, andOct for Outfall 001 by dividingby 1,000,000.A.P. Green Refractories ,Co.Oak Hill, OHMineral MiningChlorineOutfall 001 flows for 2008,excluding Feb, are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are reportedas GPD.Revise flows, excluding Feb, forOutfall 001 by dividing by1,000,000.Sebasco Harbor ResortLLCPhippsburg, MEHotelsChlorineOutfall 002 flows for May throughOct 2008 are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are GPD.Revise flows for May throughOct 2008 for Outfall 002 bydividing by 1,000,000.Newagen Seaside InnSouthport, MEHotelsChlorineOutfall 001 flows for Jun throughSept 2008 are in the DMRLoadings Tool as MGD, whileflows in Envirofacts are GPD(auto-corrected by the DMRLoadings Tool).Revise June, July, and Sept 2008flows for Outfall 001 by dividingby 1,000,000.US Dept of the InteriorWinter Harbor,MENational Security& InternationalAffairsChlorineOutfall 001 flows for May and Jun2008 are in the DMR LoadingsTool as MGD, while flows inEnvirofacts are in GPD.Revise flows for May and Jun2008for Outfall 001 by dividingby 1,000,000.Engineered Coil CompanyHigh Ridge, MOMetal FinishingCopperOutfall 002 flows for Nov 2008are in the DMR Loadings Tool asMGD, while flows in Envirofactsare in GPD.Revise flows for Nov 2008 forOutfall 002 by dividing by1,000,000.Section 4 – Methodology, Data Sources, and Limitations4-32Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionHarbison-WalkerRefractorVanalia, OHMineral Miningand ProcessingAluminumOutfall 001 flows for Mar, Jun,and Sept 2008, are not consistentwith other months or the designflow of 230 MGD. The facilitypermit stated that the flows arebased on precipitation; however,the units are suspected to beincorrect (State of Missouri,2005).Revise March, June, and Septflows for Outfall 001 by dividingby 1,000.Hamilton Water TreatmentPlantHamilton, ALDrinking WaterTreatmentAluminumOutfall 001 flows for 2008,excluding Feb, are 1,000 timeshigher than corrected flows from2007.Revise all flows for Outfall 001by dividing by 1,000.Cook’s Hams, Inc.Lincoln, NEMeat and PoultryProductsSulfurOutfall 001 flow for Jun 2008 is1,000 times higher than all othermonths, the maximum daily flowfor Jun 2008, and the permitdesign flow (0.069 MGD).Revise Jun 2008 flow for Outfall001 by dividing by 1,000.PRASA WTP MiraderoFilter PLTMayaguez, PRDrinking WaterTreatmentChlorineOutfall 001 flow for May 2008was 1,000 times higher than theflows reported for other months.Suspect units error during dataentry.Revise May 2008 flow forOutfall 001 by dividing by 1,000.PRASA WTP SergioCuevasTrujillo Alto, PRDrinking WaterTreatmentChlorineOutfall 001 flows for May andAug 2008 are 1,000 times higherthan other monthly flows.Revise May and Aug 2008 flowsfor Outfall 001 by dividing flowsby 1,000.National Copper andSmeltingHuntsville, ALCopper formingZincOutfall 002 flows for Jul throughNov 2008 were 1,000 times higherthan other reported monthly flows.Also, zinc concentrations reportedfor July through Sept 2008 forOutfall 002 were 1,000 timeshigher than other monthlyconcentrations.Revise flows for Jul through Nov2008 for Outfall 002 by dividingflows by 1,000. Reviseconcentrations for July throughSept 2008 for zinc by dividingconcentrations by 1,000.Section 4 – Methodology, Data Sources, and Limitations4-33Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionBayview Detention CTRWWTFLos Fresnos, TXJustice, PublicOrder, & SafetyChlorineOutfall 001 flows for 2008reported to the DMR LoadingsTool did not match the Envirofactsdata. TCEQ contact indicated thatthe facility is a POTW and theflow permit limit is 0.16 MGD.Revise flows for Outfall 001 bydividing flows by 1,000 andchange SIC code to link toPOTWs.KODAK ColoradoDivisionWindsor, COMetal FinishingSilverOutfall 006 flow is not consistentwith other flows reported for thefacility in 2008. Facility contactstated that theaverage flow forOutfall 006 is about 150 L/day(0.000039 MGD) (Peterson,2010).Replace flows for Outfall 006.Catskill State FishHatcheryLivingston Manor,NYConcentratedAquatic AnimalProductionFormaldehydeOutfall 001 flows for 2008 wereextremely high. NYSDEC contactverified that flows for all monthswere reported in GPM, not MGD,based on discussions with thefacility (Sansalone, 2010).Database Change: Revise flowsfor Outfall 002 by dividing by694.SEAPAC of Idaho, Inc.Hagerman, IDConcentratedAquatic AnimalProductionCopperOutfall 001 flows and outfall OSBflows for 2008 were reported withthe incorrect units (unknown) inthe DMR Loadings Tool whencompared to Envirofacts (cubicfeet per second (CFS) withdifferent values).Database Change: Revise flowsfor Outfalls 001 and OSB bydividing by 1.55.Upshur Property, Inc.Tallmansville,WVCoal MiningSeleniumOutfalls 001, 002, and 004 flowsare in the DMR Loadings Tool asMGD, while Envirofacts flows arein GPM. Outfall 402 flows are inthe DMR Loadings Tool as MGDwhile Envirofacts flows are inCFS.Database Change: Revise flowsfor Outfalls 001, 002, 004 fromGPM to MGD by dividing by694. Revise flows for Outfall 402from CFS to MGD by dividingby 1.55.Section 4 – Methodology, Data Sources, and Limitations4-34Table 4-5. Summary ofDMRLoads2008Facility ReviewFacilityLocationPoint SourceCategoryPollutant(s)in QuestionReview FindingsAction Taken/Database CorrectionUS Steel Corp – MonValley Works - EdgarThomsonBraddock, PAIron and SteelIronFacility contact identified that thefacility measures pollutantconcentrations in their stormwaterprior to commingling withnoncontact cooling water. EPAdeveloped a flow factor using the2004 data, to determine theamount of stormwater in the totaloutfall flow for more accurate loadestimates (Belack, 2007).Database Change: Revise flowsfor Outfalls 005, 006, 008, and009 by applying flow factor.Section 4 – Methodology, Data Sources, and Limitations



### 4-35 4 .4 Corrections to the TRIReleases2008 Database

EPA developed the TRIReleases2008 database as part of the 2010 annual review using the methodology explained in the 2009 SLA Report (U.S. EPA, 2009) with the methodology updates described in Section 4.2.2

.

During previous screening-level analyses, EPA identified numerous facility-specific corrections for TRI data reported for cal endar years 2002 through 2007. Several of these corrections similarly apply to the 2008 TRI data . In addition, EPA reviewed the quality of the 2008 TRI data for facilities with discharges that have the greatest impact on total category loads and category rankings. Table B-1 in Appendix B of th is report lists all co rrections made to the

2008 TRI data.

4.4 .1 TRIReleases2008: Categorization of Discharges

This section describes database corrections to categorization of facilities and pollutant discharges in TRIReleases2008 . Section 4 of the 2009 SLA Report describes the development of the NAICS/Point Source Categor y Crosswalk, which EPA uses to link between facility NAICS codes and categories with existing ELGs (U .S. EPA, 2009). Because most point source categories are not defined by NAI CS code, the relationship be tween NAICS code and point source category is not a one-to- one correlation. A single NAICS code may include facilities in more than one point source category, and asso ciating an NAICS code with only one category may be an oversimplification. Also, many facilitie s have operations subject to more than one point source category. Further, facilities in some categories report a variet y of NAICS codes that do not correlate directly to a point source category, precludin g identification by NAICS code (e.g., Centralized Waste Treatment facilities). Section 5 of the 2009 SLA Report describes the database changes, summarized below (U.S. EPA, 2009):

• 

### Facility-Level Point Source Category Assignment. For some NAICS codes that include facilities subject to guidelines from more than one point source category, EPA was able to assign each facility to the category that best applied to the majority of its discharges. EPA reviewed information available about each facility to determine which point source category applied to the facility’s operations.

• 

### Pollutant-Level Point Source Category Assignment. Many facilities have operations subject to more than one poi nt source category. For most of these facilities, EPA cannot divide the pollutan t discharges among the applicable point source categories. Below are two excep tions where EPA was able to assign wastewater discharges of certain chem icals to the appropriate point source
category:

— OCPS F/Pesticide Chemicals. EPA removed all pesticide discharges from the OCPSF Category and included them as discharges from the Pesticide Chemicals Category.

— MP&M/Metal Finishing. EPA used the methodologies described in Section 4 of the 2009 SLA Report to a pportion pollutant loads between the MP&M and Metal Finishing Categories.Section 4 – Methodology, Data Sources, and Limitations



### 4-36 • 

### Categories Not Identified by NAICS C ode (e.g., Centralized Waste Treatment, Waste Combustor, and Landfills)

. The NAICS/Point Source Category Crosswalk does not assign any NAICS codes to the Centralized Waste Treatment (CWT) Point Source Category (40 CFR Part 437), Waste Combustor Point Source Category (30 CFR Part 444), or Landfills Category (40 CFR Part 445). Furthermore, the applicability of these three regulations is not defined by NAICS

codes and no NAICS code properly describes the CWT, waste combustor, or landfill services. Currently, EPA assigns all facilities reporting NAICS code 562213 (Solid Waste Combustors and Inci nerators) as part of the Waste Combustor Category. The remaining f acilities, with NAICS codes 562211 (Hazardous Waste Treatment and Dis posal) and 562219 (Other Nonhazardous Waste Treatment and Disposal), are incl uded in all three ca tegories, which over estimates the category loads. During prev ious annual reviews, EPA has identified certain facilities that should be catego rized as a CWT, waste combustor, or landfill. EPA assigned these facilities to the correct industrial category. As

facilities continue to be re viewed due to high TWPE, EPA classifies them into the correct industrial category based on facility operations.

4

.4.2 TRIReleases2008: Pollutant Corrections

This section describes databa se corrections made to disc harges of specific pollutants reported to the TRI for EPA’s 2010 screening-level review in the TRIReleases2008 database.

• 

### Metal Compounds. For TRI reporting, facilities may be required to report discharges of a metal (e.g., zinc) an d its compounds (e.g., zinc compounds) on a single reporting form. Because the release quantity for the metal compound reporting is based on the mass of the pare nt metal, EPA uses the parent metal TWF to calculate TWPE for the metal and metal compound discharges. For ranking purposes, EPA combined the TWPE s for the metal a nd metal compounds (i.e., TWPE reported for “zinc and zinc compounds”). For more details on this correction, see Section 3.4.4 of the 2009 SLA Report (U.S. EPA, 2009).

• 

### Sodium Nitrite. For TRI reporting, sodium nitrite re lease quantities are reported as

the mass of the sodium nitrite. Sodium n itrite is an ionic salt that will fully

dissociate into nitrite and sodium ions in aqueous solutions. In addition, the nitrite

ions are unstable in water and will oxidize to nitrate. Therefore, EPA converted the pounds of TRI-reported sodium nitrite discharges to pounds of nitrogen in the discharge and used the TWF for “nitrate as N” (0.0032) to calculate TWPE for sodium nitrite. In addition, EPA also used the POTW removal for nitrate to

account for the removal of sodium nitrite in POTWs.

• 

### Phosphorus (Yellow or White). Yellow and white phosphorus, both allotropes of elemental phosphorus, are hazardous chemical s that spontaneously ignite in air. During the 2006 screening-le vel review, EPA determined that facilities were incorrectly reporting discharges of to tal phosphorus (i.e., the phosphorus portion of phosphorus-containing compounds) as phosphorus (yellow or white) (U.S. EPA, 2006a). Therefore, EPA deleted all phosphorus (yellow or white) discharges reported to TRI for the 2010 screening-level review.Section 4 – Methodology, Data Sources, and Limitations



### 4-37 4.4.3 TRIReleases2008: Data Quality Review

EPA evaluated the quality of TRI data for use in the 2010 screening-level review and prioritization of loadings of toxic and nonc onventional pollutants discharged by industrial categories based on completeness, accurac y, reasonableness, and comparability. The Quality Assurance Project Plan for the 2009 Annual Screen ing-Level Analysis of TRI, ICIS-NPDES, and PCS Industrial Category Discharge Data describes the quality objectiv es in more detail (ERG, 2009). The following discussion provides an overview of the quality review steps:

• 

### Completeness Checks. EPA compared counts of facilities in TRIReleases2008 to
TRIReleases2007

, TRIReleases2005

, TRIReleases2004

, TRIReleases2003

, TRIReleases2002, and TRIReleases2000 to describe the completeness of the database. The comparison showed that for 72 percent of the point source categories or NAICS code groupings, the number of facilities reporting wastewater discharges changed by le ss than 25 percent from 2007 to 2008. EPA

also determined that most NAICS codes exhibiting a large per centage change did so because only a few facilities in th ese NAIC codes reported discharges (e.g., a change from one facility to three facilities is equivalent to a 200 per cent increase).

• 

### Accuracy of Facility Discharges. EPA reviewed the accuracy of facilities’ discharges that had the greatest impact on total category loads and category rankings. EPA identified facilities for review whose pollutant discharges accounted for more than 95 percent of th e TWPE for their point source category. EPA compared 2008 TRI data to other av ailable information, such as PCS and ICIS-NPDES, information from EPA’s E nvirofacts web page, the facilities’ NPDES permits and permit fact sheets, a nd discussion with facility contacts.

• 

### Accuracy of Category Discharges. EPA reviewed the accuracy of category discharges by verifying that pollutant discharges in TRI were assigned to the appropriate point source cat egory. EPA used engineering judgment to determine if pollutant discharges were reasonably a ssociated with the poi nt source category.

• 

### Accu racy of Database Queries. EPA’s quality review fo r the development of

TRIReleases2008 included accuracy checks for database queries in

TRICalculations2008 7 

### and TRIReleases2008 . Documentation of accuracy checks is provided in a QC table in each Microsoft AccessTM database.

• 

### Comparability. EPA compared TRIReleases2008 to TRIRelease2007

, TRIReleases2005

, TRIReleases2004

, TRIReleases2003, TRIReleases2002, and

TRIReleases2000 to identify pollutant discharges that differ more than the yearto-year variation of other chemicals and facilities. From the comparison, EPA determined that 42 percent of the pollutants discharged in both 2008 and 2007 had a change of less than 50 pe rcent in the quantity discharged. EPA also determined that most of the pollutants with a large percentage change reflected initial discharges of small quantities. In add ition, most of these pollutant discharges

resulted in small TWPEs.

7 TRICalculations2008 is a database EPA created to analyze raw TRI data. See Section 2.4 of the 2009 SLA Report for more detailed information (U.S. EPA, 2009).Section 4 – Methodology, Data Sources, and Limitations



### 4-38 4

.4.4 TRIReleases2008: Facility Reviews

Table 4-6 presents EPA’s TRI facility revi ew and corrections made to the

TRIReleases2008 database. EPA reviewed the accuracy of calculated discharges from facilities with discharges that have the greatest impact on total category loads and category rankings. EPA used the following criteria to select facilities for review:

• 

### Facilities with the highest toxic-weighted discharges of all faci lities reporting to TRI for reporting year 2008;

• 

### Facilities with the highest toxic-weighted discharges of individual chemicals that contribute the majority of the toxic-wei ghted discharges for all categories; and

• 

### Facilities with the highest toxic-weig hted discharges from categories that contribute the majority of the toxic-wei ghted discharges for all categories.

For the identified facilities, EPA used the following steps to review the accuracy of the

loads calculated from TRI data.

1. Rev iew database corrections for TRIReleases2007, TRIReleases2005

, TRIReleases2004

, TRIReleases2003

, TRIReleases2002 , and TRIReleases2000 to
determine whether corrections were made during previous reviews and evaluate

whether these corrections should be applied to TRIReleases2008

.

2

. Review discharges reported to TRI fo r other reporting years (i.e., 2000, 2002, 2003, 2004, 2005, and 2007) and compare to di scharges reported to TRI for reporting year 2008.

3

. Review 2008 DMR data in PCS and ICIS-NPD ES, if available, to hand-calculate annual pollutant loads and compare to di scharges reported to TRI for reporting year 2008.

4

. Contact the facility to ve rify whether the pollutant discharges are reported correctly.Section 4 – Methodology, Data Sources, and Limitations4-39Table 4-6. Summary ofTRIReleases2008Facility ReviewFacility NameFacility LocationPoint SourceCategoryPollutant(s) inQuestionReview FindingsActions Taken/DatabaseCorrectionCarolina Pole LelandLeland, NCTimberDioxin CompoundsFacility did not recognize thedioxin distribution numberingchange for the 2008 reportingyear. Facility contact stated thatthe reported grams of dioxin arebased on monitoring data – somecongeners were detected in 2008but all were BDL in 2009. Facilityprovided sampling data thatindicated that the dioxindistribution was based on the TRI2007 distribution numbering(House, 2010).Revise dioxin distribution.Clean Harbors Deer Park,LPLa Porte, TXWasteCombustorsBenzideneReviewed benzidine DMR data inthe DMR Loadings Tool anddetermined that all 2008discharges were 0 mg/L.Revise benzidine load to zero.DuPont Chambers WorksDeepwater, NJOCPSFHexachlorobenzene,PACsFacility contact indicated thathexachlorobenzene loads werecalculated using half the detectionlimit. Facility contact confirmedthat hexachlorobenzene and PACswere never detected at the facility(Northey, 2007).Revise hexachlorobenzene andPACs loads to zero.DuPont Chemicals – StarkeFacilityStarke, FLOre MiningDioxin CompoundsFacility did not recognize thedioxin distribution numberingchange for the 2008 reportingyear. Facility contact confirmedthat the dioxin distribution wasincorrect. Facility providedfacility-specific distribution(Wood, 2010).Revise dioxin distribution.Section 4 – Methodology, Data Sources, and Limitations4-40Table 4-6. Summary ofTRIReleases2008Facility ReviewFacility NameFacility LocationPoint SourceCategoryPollutant(s) inQuestionReview FindingsActions Taken/DatabaseCorrectionDuPont Delisle PlantPass Christian,MSInorganicChemicalsDioxin CompoundsFacility did not recognize thedioxin distribution numberingchange for the 2008 reportingyear. Facility contact confirmedthat the dioxin distribution wasincorrect. Facility providedfacility-specific distribution(Wood, 2010).Revise dioxin distribution.DuPont Edge MoorEdgemoor, DEInorganicChemicalsDioxin CompoundsFacility did not recognize thedioxin distribution numberingchange for the 2008 reportingyear. Facility contact confirmedthat the dioxin distribution wasincorrect. Facility providedfacility-specific distribution(Wood, 2010).Revise dioxin distribution.DuPont Johnsonville PlantNew Johnsonville,TNInorganicChemicalsDioxin CompoundsFacility did not recognize thedioxin distribution numberingchange for the 2008 reportingyear. Facility contact confirmedthat the dioxin distribution wasincorrect. Facility providedfacility-specific distribution(Wood, 2010).Revise dioxin distribution.ExxonMobil ChemicalBaton Rouge ChemicalPlantBaton Rouge, LAOCPSFPACsFacility contact confirmed that thepounds released were based onhalf the detection limit and thatPACs were never detected at thefacility (Fellows, 2003).Revise PACs load to zero.ExxonMobil Oil CorpJoliet RefineryChannahon, ILPetroleumRefiningHexachlorobenzeneFacility contact confirmed that thepounds released were based onhalf the detection limit. Contactdid not recall any previous yearswhere hexachlorobenzene wasdetected (Noga, 2010).Revise hexachlorobenzene loadto zero.Section 4 – Methodology, Data Sources, and Limitations4-41Table 4-6. Summary ofTRIReleases2008Facility ReviewFacility NameFacility LocationPoint SourceCategoryPollutant(s) inQuestionReview FindingsActions Taken/DatabaseCorrectionFormosa PlasticsCorporation LouisianaBaton Rouge, LACCHDioxin CompoundsFacility did not recognize thedioxin distribution numberingchange for the 2008 reportingyear. Dioxin distribution reportedin 2008 is similar to 2003distribution (using previousreporting years’ numberingscheme).Revise dioxin distribution.Formosa PlasticsCorporation TexasPoint Comfort,TXCCHDioxin CompoundsFacility did not recognize thedioxin distribution numberingchange for the 2008 reportingyear. Dioxin distribution reportedin 2008 is similar to 2003distribution (using previousreporting years’ numberingscheme).Revise dioxin distribution.Graftech InternationalHoldings, Inc.Columbia, TNCarbon BlackManufacturingPACsFacility contact provided PACssampling data. Facility reviewedthe monitoring data anddetermined they overestimated thePAC discharges (1091.23pounds). Facility contact said theyshould have reported dischargesas 246 pounds of PACs. Themonitoring results also provided adistribution for the PACcompounds to create a facilityspecific TWF (Aslinger, 2010).Revise PAC annual load (LBY)from 1,091 to 246. CalculateTWPE using facility-specificTWF.H. Kramer & Co.Chicago, ILNonferrousMetalsManufacturingPhosphorous(Yellow or White)Elemental phosphorus is not likelyto be discharged by facilities, andis likely reported incorrectly.Revise phosphorus (yellow orwhite) load to zero.Section 4 – Methodology, Data Sources, and Limitations4-42Table 4-6. Summary ofTRIReleases2008Facility ReviewFacility NameFacility LocationPoint SourceCategoryPollutant(s) inQuestionReview FindingsActions Taken/DatabaseCorrectionJohn Morrell & Co.Sioux Falls, SDMeat andPoultryMercuryFacility contact confirmed thatmercury discharges are estimatedbased on metals testing performedfor the city discharge. Contactstated that all mercury sampleswere BDL (Draveland, 2010).Revise mercury load to zero.Lima Refining Co.Lima, OHPetroleumRefiningPhosphorous(Yellow or White)Elemental phosphorus is not likelyto be discharged by facilities andis likely reported incorrectly.Revise phosphorus (yellow orwhite) load to zero.Louisiana Pigment Co L.P.Westlake, LAInorganicChemicalsDioxin CompoundsFacility did not provide a watercongener distribution for 2008.Use facility provided distributionfrom 2007 (Kashyap, 2009).Revise dioxin distribution.Occidental Chemical CorpColumbia, TNInorganicChemicalsPhosphorous(Yellow or White)Elemental phosphorus is not likelyto be discharged by facilities, andis likely reported incorrectly.Revise phosphorus (yellow orwhite) load to zero.PCS Nitrogen Fertilizer LPAugusta, GAFertilizerManufacturingDioxin CompoundsFacility did not recognize thedioxin distribution numberingchange for the 2008 reportingyear. Dioxin distribution reportedin 2008 is similar to 2005distribution (using previousreporting years’ numberingscheme).Revise dioxin distribution.U.S. Army Pine BluffArsenalPine Bluff, ARNationalSecurity &InternationalAffairsPhosphorous(Yellow or White)Elemental phosphorus is not likelyto be discharged by facilities andis likely reported incorrectly.Revise phosphorus (yellow orwhite) load to zero.Section 4 – Methodology, Data Sources, and Limitations



### 4-43 4.4.5 Trends in TRI Data

EPA has identified a consistent decrease ever y year since 2002 in the total number of facilities reporting to TRI. EPA also identified a consistent decrease in the number of facilities reporting discharges to TRI from 2002 to 2007. Ho wever, the number of facilities reporting discharges to TRI increased from 2007 to 2008. Table 4-7 illustrates the trends since 2002.

Table 4-7. Number of Facilities with Data in TRI for Reporting Years 2002 Through 2008

Reporting Year Number of Facilities Reporting to

TRI Number of Facilities Reporting Discharges to TRI

2002 24,379 8,291

2003 23,811 8,051

2004 23,675 7,930

2005 23,461 7,837

2006 22,880 7,506

2007 21,965 6,572

2008 21,694 6,891

Source: TRIReleases2002 ; TRIReleases2003 ; TRIReleases2004 ; TRIReleases2005 ; TRIReleases2006 ; TRIReleases2007 ; and TRIReleases2008

.



### EP A does not have sufficient information to de termine the cause of the decrease in the number of facilities reporti ng to TRI over the past seven ye ars. The aggregate number of

establishments 8 

### reported to the U.S. Economic Census increased from 2002 to 2007. No changes in reporting requirements occurred that can be at tributed to the decrease. EPA will continue to monitor this change in the future.

4.5 TRIReleases2008 Rankings and DMRLoads2008 Rankings

Af ter incorporating the cha nges discussed in Sections 4.3 and 4.4 , EPA generated the

final versions of the TRIReleases and DMRLoads databases used for the 2010 screening-level

review: TRIReleases2008_v3 and DMRLoads2008_v2 . Tables C-1 and C-2 in Appendix C present the category rankings by TWPE from the TRIReleases2008_v3 and DMRLoads2008_v2 databases, respectively. The category rankings presen ted in these tables reflect all the corrections made during the 2010 screening-level reviews. Ta bles C-3 and C-4 in Appendix C present the six-digit NAICS code rankings by TWPE from TRIReleases2008_v3 and the four-digit SIC code rankings by TWPE from DMRLoads2008_v2 , respectively. Tables C-5 and C-6 in Appendix C present the chemical rankings by TWPE from TRIReleases2008_v3 and DMRLoads2008_v2

, respectively.

4.6 Me thodology, Data Sources, and Limitations References

1. Aslinger, Julia. 2010. Notes from E-mail Comm unication between Julia Aslinger, Center for Toxicology, and Environmental Health, LLC and Elizabeth Sabol, Eastern Research

8 EPA reviewed only 3-digit NAICS code industry groups th at were eligible for TRI reporting. Refer to Chapter 2 of the 2009 SLA Report (EPA, 2009) for more detail.Section 4 – Methodology, Data Sources, and Limitations



### 4-44 Group, Inc. “RE: PAC Discharge Summ ary.” (March 22). EPA-HQ-OW-2008-0517

DCN 07253.

2. Becker, Jory. 2010. Notes from Telephone Conversation between Jory Becker, KY DEP, and Jessica Wolford, Eastern Research Group, Inc. “RE: Review of DMR data and Permits for Bullitt County Landfill (KY0091651) and Reed Duplex Apt. Bldg. (KY0095036).” (February 22). EPA-HQ-OW-2008-0517 DCN 07254.

3. Belack, Dan. 2007. Notes from E-mail Comm unication between Dan Belack, US Steel, and Jan Matuszko, U.S. EPA. “RE: 2004 PC S Discharges.” (May 7). EPA-HQ-OW2006-0771-0480.

4. Bernarack, Christopher. 2010. Notes from E- mail Communication between Christopher Bernarack, GA DEQ, and William Sw ietlik, U.S. EPA. “RE: Resolution of Hercules, Inc. Toxaphene Outlier.” (April 25). EPA-HQ-OW-2008-0517 DCN 07255.

5. Bogaard, Dirk. 2010. Notes from Telephone C onversation between Dirk Bogaard, Clear Lakes Trout Company, and Eli zabeth Sabol, Eastern Resear ch Group, Inc. “RE: Copper concentration reported to DMR in 2008.” (April 22). EPA-HQ-OW-2008-0517 DCN

07256.

6. Draveland, Steve. 2010. Notes from Telephone Conversation between Steve Draveland, John Morrell & Co. and Elizabeth Sabol, East ern Research Group, Inc. “RE: Basis ofMercury and Mercury Compound load reported to TRI in 2008.” (February 12). EPAHQ-OW-2008-0517 DCN 07257.

7. ERG. 2009. Eastern Research Group, Inc. Revise d Quality Assurance Project Plan for the 2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and PCS Industrial Category Discharge Data. Chantilly, VA. (September). EPA-HQ-OW-2008-0517-0507.

8. Fellows, Dave. 2003. Notes from Telephone Co nversation between Dave Fellows, Exxon Mobile, and Eastern Research Group, Inc. “RE: Toxic Release Inventory Inquiry.” (August 12). EPA-HQ-OW-2003-0074 DCN 00336.

9. House, Jane. 2010. Notes from Telephone Conversation between Jane House, Carolina Pole – Leland, and Elizabeth Sabol, East ern Research Group, Inc. “RE: Dioxin Distribution and Dioxin load reported to TRI in 2008.” (March 15). EPA-HQ-OW-2008-

0517 DCN 07258.

10. Kashyap, Vikram. 2009. Notes from E-mail Communication between Vikram Kashyap, Louisiana Pigment Co., and Eleanor Coddi ng, Eastern Research Group, Inc. “RE: Response to EPA Questions on 2007 TRI Dioxi n Water Releases – Louisiana Pigment Company.” (May 8). EPA-HQ-OW-2008-0517-0094.

11. Knarr, Bill. 2010. Notes from E-mail Comm unication between Bill Knarr, Kenvirons, Inc., and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Valley View Landfill - Mercury Discharges DMR 2008.” (Mar ch 23). EPA-HQ-OW-2008-0517 DCN 07259.Section 4 – Methodology, Data Sources, and Limitations



### 4-45 12. Lovitt, Faith. 2010. Notes from Telephone Conversation between Faith Lovitt, Tyson Foods, Inc., and Elizabeth Sabol, Easter n Research Group, Inc. “RE: Mercury concentration reported to DMR in 2008.” (February 19). EPA-HQ-OW-2008-0517 DCN

07260.

13. Noga, Jeff. 2010. Notes from Telephone C onversation between Jeff Noga, ExxonMobil Oil Corp., and Jessica Wolford, Eastern Re search Group, Inc. RE: Joilet Refinery’s hexachlorobenze discharges in 2008. (February 15). EPA-HQ-OW-2008-0517 DCN

07303.

14. Northey, Scott. 2007. Notes from Telephone Conversation between Scott Norhtey, DuPont Chambers Works, and Chris Krej ci, Eastern Research Group, Inc. “RE: Hexachlorobenzene discharges reported by DuPont Chambers Works.” (December 12). EPA-HQ-OW-2006-0771-1171.

15. OMB. 1987. Office of Management and Budget. Standard Industrial Classification

Manual . Washington, DC. (Unknown). EPA-HQ-OW-2008-0517.

16. Peterson, Eric. 2010. Notes from Telephone Conversation between Eric Peterson, Kodak Colorado Division, and Elizabeth Sabol, East ern Research Group, Inc. “RE: Silver concentration reported to DMR in 2008.” (February 16). EPA-HQ-OW-2008-0517 DCN

07261.

17. Rayna, Dave. 2010. Notes from Telephone Conve rsation between Dave Rayna, Former Koppers, and Elizabeth Sabol, Eastern Resear ch Group, Inc. “RE: TC DD concentrations reported to DMR in 2008.” (March 17). EPA-HQ-OW-2008-0517 DCN 07262.

18. Sansalone, John. 2010. Notes from Telephone Conversation between John Sansalone, DEC Region 3 Office, and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Flows reported to DMR in 2008.” (March 17). EPA-HQ-OW-2008-0517 DCN 07263.

19. State of Missouri. 2005. Department of Na tural Resources Water Discharge Permit NPDES MO0000710 – Harbison Walker Refractories Company – Vandalia Plant. Vandalia, MO. (May 27). EPA-HQ-OW-2008-0517 DCN 07264.

20. Stuhlfauth, Gary. 2007. Notes from Telephone Conversation between Gary Stuhlfauth, Ohio USEPA, and TJ Finseth, Eastern Res earch Group, Inc. “RE: Low level mercury discharge requirements on NPDES permits in Ohio.” (January 22). EPA-HQ-OW-2006-

0771-0487.

21. Travis, Chris. 2010. Notes from Telephone C onversation between Chris Travis, USEC PDGDP, and Elizabeth Sabol, Eastern Resear ch Group, Inc. “RE: PCB concentrations reported to DMR in 2008.” (March 17). EPA-HQ-OW-2008-0517 DCN 07265.

22. U.S. EPA Region 1. 2006. NPDES Fact Shee t: EnviroSystems Inc. – Hampton, New Hampshire. (April 11). EPA-HQ-OW-2008-0517-0075.Section 4 – Methodology, Data Sources, and Limitations



### 4-46 23. U.S. EPA. 2000. EPCRA Section 313 Guidance for Re porting Toxic Chemicals Within the Dioxins and Dioxin-Like Compounds Category . EPA-745-B-00-021. Washington, DC. (December). EPA-HQ-OW-2003-0074-1150.

24. U.S. EPA. 2005. Draft Toxic Weighting Factor Development in Support of CWA 304(m) Planning Process . Washington, DC. June. EPA-HQ-OW-2004-0032-0857.

25. U.S. EPA. 2006b. Toxic Weighting Factor Devel opment in Support of CWA 304(m) Planning Process . Washington, DC. (June). EPA-HQ-OW-2004-0032-1634.

26. U.S. EPA. 2006a. Technical Support Document for the 2006 Effluent Guidelines Program Plan. EPA-821-R-06-018. Washington, DC . (December). EPA-HQ-OW-2004-

0032-2782.

27. U.S. EPA. 2009. Technical Support Document for the Annu al Review of Existing Effluent Guidelines and Identification of Po tential New Point Source Categories . EPA-821-R-09- 007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515.

28. Williams, Sylvia. 2010. Notes from E-mail Communication between Sylvia Williams, Akzo Noble, and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Nobel - DMR 2008 Mercury Discharges.” (March 22). EPA-HQ-OW- 2008-0517 DCN 07266.

29. Wood, Ken. 2010. Notes from E-mail Communica tion between Ken Wood, DuPont, and Ellie Codding, Eastern Research Group, Inc. “RE: Request for Clarification of 2008 TRI Data for EPA’s Annual Review.” (A pril 21). EPA-HQ-OW-2008-0517 DCN 07267.Part II – Results of the 2010 Annual Review



### II 

# PART II: RESULTS OF THE 2010 ANNUAL REVIEW OF

INDUSTRIAL CATEGORIES WITH EXISTING ELGSSection 5 – 2010 Annual Review



### 5-1 5. 2010 A NNUAL 

### R EVIEW OF 

### E XISTING 

### E FFLUENT 

### L IMITATIONS 

### G UIDELINES AND


### S TANDARDS AND 

### R ANKING OF 

### P OINT 

### S OURCE 

### C ATEGORIES



### For the 2010 annual review, EPA co nducted the followi ng activities:

• 

### Up dated the reviews from previous year s (i.e., revised the 2009 annual review results with new or corrected data);

• 

### Pe rformed new researches (i.e., contacted industry to verify discharges, conducted literature searches, and collected additio nal data from site visits and state permitting agencies); and

• 

### Solicited information from stakeholde rs through comment response and other stakeholder outreach (e.g., meetings with industry trade groups).

Thi s section presents the results of th e 2009 annual review, the results of the 2010 screening-level review, and the prioritization of categor ies for the 2010 annual review.

5.1 Summary of the Results from the 2009 Annual Review

EP A published its annual review of existing e ffluent limitation guide lines and standards (ELGs) as part of the Preliminary 2010 Plan on October 30, 2009 (74 FR 68599). In the 2009 annual review, EPA identified 10 point source cat egories that represented the bulk of the estimated toxic discharges (as measured by to xic-weighted pound equivalents (TWPE)) from existing industrial point source categories. EPA ranked each point source category by the amount of toxic pollutants in its disc harges (as measured by TWPE) and identified the Steam Electric Power Generating (Steam Electric) Point Source Category (Categor y) (40 CFR Part 423) as the category with the highest TWPE (accounting for mo re than 72 percent of the total TWPE). EPA identified the following seven additional categories with pote ntially high TWPE discharge estimates (accounting for almost 24 percent of existing point source category TWPE):

• 

### Pulp, Paper and Paperboard (40 CFR Part 430);

• 

### Fertilizer Manufacturing (40 CFR Part 418);

• 

### Organic Chemicals, Plastics and S ynthetic Fibers (40 CFR Part 414);

• 

### Pe troleum Refining (40 CFR Part 419);

• 

### Inorganic Chemicals Manufacturing (40 CFR Part 415);

• 

### Nonferrous Metals Manufact uring (40 CFR Part 421); and

• 

### Ore Mining and Dressing (40 CFR Part 440).

EPA concluded its detailed study of the Steam Electric Category and decided to pursue an effluent guidelines rulemaking for the category. For the seven categories listed above, EPA conducted preliminary category reviews based on the results of the 2009 sc reening-level review

and stakeholder comments. EPA determined that it would continue the preliminary category review for the Ore Mining and Dressing Category as part of the 2010 annual review to collect additional information on pollutant discharges and potential treatment technology options. For the remaining six categories, EPA determined that these categories were not a hazard priority

based on data available for the 2009 annual review.

EPA also conducted detailed studies of the Oil and Gas Extraction Category (40 CFR Part 435), to assess whether to revise the limits to include Coalbed Methane Extraction as a new subcategory, and the Health Care Industry (i ncluding Hospitals (40 CFR Part 460)) during theSection 5 – 2010 Annual Review



### 5-2 2009 annual review that were conducted as a result of public comments. EPA decided to

continue these two detailed studies as part of the 2010 annual review.

I n view of the annual nature of its reviews of existing ELGs, EPA believes that each

annual review can and should influence succeedi ng annual reviews (e.g., by indicating data gaps, identifying new pollutants or pollution reducti on technologies, or otherwise highlighting industrial categories for more deta iled scrutiny in subsequent year s). EPA used the findings, data,

and comments on the 2009 annual review to inform its 2010 annual review. The 2009 review built on the previous reviews by continuing to use the screening methodology and incorporating some refinements in assigning discharges to categories. EPA made similar refinements to assigning discharges to categor ies for the 2010 annual review.

5.2 Results of the 2010 Screening-Level Review

F or the 2010 screening-level review, EPA used the combined results of the
TRIReleases2008_v3 and the DMRLoads2008_v2 databases, discussed in Section 4.5 of this document. When combining the results of thes e databases, EPA eliminated from further consideration the results for the following:

• 

### Discharges from industrial categories fo r which EPA is currently developing or revising ELGs;

• 

### Discharges from point source categories for which EPA has recently promulgated or revised ELGs;

• 

### Discharges from facilities that do not fall into an existing or new point source category or subcategory; and

• 

### Discharges from facilities determined not to be representative of their category.

Sec tions 5.2.1 through 5.2.4 discuss the rationale for these decisions. The final combined database rankings represent the results of the 2010 screening-level review and are presented in

Section 5.2.5

.

5.2.1 Categories for Which EPA is Currently Developing or Revising ELGs

EPA is currently considering revisions to ELGs for Organic Chemicals, Pesticides, and Synthetic Fibers (OCPSF) (40 CFR 414) and th e Inorganic Chemicals Manufacturing (40 CFR 415) Point Source Categories for facilities that produce chlorine and chlorinated hydrocarbons (CCH). Because the CCH rulemaking is underway, EPA excluded discharges from these

facilities from further consider ation under the current planning cy cle. EPA subtracted the TWPE loads from facilities that produce chlorine or chlorinated hydrocarbons from the OCPSF and Inorganic Chemicals Manufacturing Point Source Ca tegory loads. Because facilities that produce chlorine and chlorinated hydrocarbons are only a subset of the OCPSF and Inorganic Chemicals Manufacturing Categories, EPA included loads for al l other facilities in these two categories in the prioritization of cate gories for further review.

EPA is also currently consider ing revisions to ELGs for th e Steam Electric (40 CFR 423) Point Source Category. Because the Steam El ectric rulemaking is underway, EPA excluded discharges from these facilities from further consideration und er the current planning cycle.Section 5 – 2010 Annual Review



### 5-3 E PA is also currently consider ing revisions to ELGs for th e following industries: airport deicing and drinking water treatme nt. However, the TWPE associated with these categories is low and does not affect the prioritization of categories.

5.2.2 Categories for Which EPA Recently Promulgated or Revised ELGs

For the 2010 annual review and development of category rankings, EPA excluded point source categories for which ELGs were recentl y established or revi sed but not yet fully implemented, or were recently reviewed in a ru lemaking context but EPA decided to withdraw the proposal or select the “no act ion” option. In general, EPA re moved an industrial point source category from further consider ation during a review cycle if EPA established, revised, or reviewed the category’s ELGs with in seven years prior to the a nnual review. This seven-year period allows time for the ELGs to be incorporated into National Pollutant Discharge Elimination System (NPDES) permits. Table 5-1 lists the categories EPA excluded from the 2009 and 2010 reviews due to this seven year period.

Removing a point source category from furthe r consideration in th e development of the rankings does not mean that EPA eliminates th e category from annual review. In cases where EPA is aware of the growth of a new segment w ithin such category or where new concerns are identified for previously unevaluated pollutant s discharged by facilitie s in the category, EPA would apply closer scrutiny to th e discharges from the category in deciding whether to consider it further during the current revi ew cycle. For example, EPA c onducted the detailed study of the Coal Mining Category (40 CFR Part 434) base d on comments received on the 2006 Preliminary Plan, although the Coal Mining EL Gs were revised in January 2002.

Table 5-1. Point Source Categories That H ave Undergone a Recent Rulemaking or

Review

40 CFR Part Point Source Category Date of Rulemaking

450 Construction and Development December 1, 2009

122 and 412 Concentrated Animal Feeding Operations (CAFOs) November 20, 2008

451 Concentrated Aquatic Animal Production (or Aquaculture) August 23, 2004

432 Meat and Poultry Products September 8, 2004

413, 433, and 438 Metal Products and Machinery (including Metal Finishing and Electroplating) May 13, 2003

420 Iron and Steel Manufacturing October 17, 2002



### 5.2.3 Discharges Not Categorizable

EPA identified discharges that are not categor izable into existing or new point source categories or subcategories. In particular, EPA reviewed high TWPE discharges from a Superfund site (Auchterlonie, 2009). 9 

### Direct discharges from S uperfund sites, whether made onsite or offsite, are subject to NPDES perm itting requirements (U.S. EPA, 1988a; U.S. EPA, 1988b). For the reasons discussed below EPA determ ined that these discharges do not represent a point source category and excluded these TWPE from the point source category rankings.

9 The Comprehensive Environmental Response, Compensa tion, and Liability Act (CERCLA), commonly known as Superfund, was enacted by Congress on December 11, 1980.Section 5 – 2010 Annual Review



### 5-4 E PA identified that discharges from Superfund si tes are too varied to be categorized into a point source category. In particul ar, these discharges vary by:

• 

### Contaminants (e.g., metals, pesticides, dioxin);

• 

### Trea tment technologies (e.g., air st ripping, granular activated carbon, chemical/ultraviolet oxidation, aerobi c biological reactors, chemical precipitation); and

• 

### Types of facilities causing groundwater contamination (e.g., wood treatment facilities, metal finishing and electroplati ng facilities, drum r ecycling facilities, mine sites, mineral processing facil ities, radium processing facilities).

Moreo ver, the duration and volume of these dire ct discharges vary significantly due to differences in aquifer characteristics and the ma gnitude, fate, and transport of contaminants in aquifers and vadose zones. Currently at Supe rfund sites, permit writers determine technologybased effluent limits using their best professi onal judgment (BPJ). EPA selects the remedial technology and derives numerical e ffluent discharge limits. The permit must also contain more stringent effluent limitations when required to co mply with state water quality standards. EPA finds that the current site-specific BPJ approach is workable and flexible within the context of a Superfund cleanup.

5.2.4 Categories with One Facility Dominating the TWPE

EPA id entified point source categories with significant TWPE where only one facility was responsible for more than 95 percent of th e TWPE reported to be discharged even though it was not the only facility reporting discharges for the category (see Table 5-2 ). EPA identified six

facilities that dominated the TW PE in the category to which they belonged. EPA investigated these facilities to determine if their discharges were representative of th e category. If they were not, EPA subtracted the facility ’s TWPE from the total categor y TWPE and recalculated the category’s ranking. EPA performed this analysis se parately for each of the databases. Based on EPA’s knowledge of these industries and the revi ew of the pollutant discharges for these facilities, EPA determined that all of the pollutant di scharges are represen tative of the industry and therefore, EPA did not remove the discharges from the category.

5.2.5 Results of the 2010 Screening-Level Review

A fter adjusting the category TWPE totals and rankings as described in Sections 5.2.1 through 5.2.4 , EPA consolidated the 2008 discharge monitoring report (DMR) and Toxics Release Inventory (TRI) rankings into one set using the following steps:

• 

### EPA combined the two lists of point s ource categories by adding each category’s

DMRLoads2008 TWPE and TRIReleases2008 TWPE 10



### .

• 

### EPA then ranked the point s ource categories based on total DMRLoads2008 and

TRIReleases2008 TWPE.

10 EPA notes that this may result in “double-counting” of ch emical discharges a facility reported to both PCS/ICISNPDES and TRI, and “single-counting” of chemicals reported in only one of the databases. Further, the combined databases do not count chemicals that may be discharg ed but are not reported to PCS/ICIS-NPDES or TRI.Section 5 – 2010 Annual Review



### 5-5 Table 5-3 presents the combined DMRLoads2008 and TRIReleases2008 rankings. These are the final category rankings accounting for all corrections made to the databases during the 2010 screening-level review and removal of any categories and discharges as discussed in

Sections 5.2.1 through 5.2.4

.Section 5 – 2010 Annual Review5-6Table 5-2. Point Source Categories with One Facility Dominating the TWPE DischargesPoint Source CategoryFacility with Over95% of CategoryTWPEFacilityLocationDataSourcePollutant DrivingTWPEFacilityTWPEPercentage ofTotalCategoryTWPEActionMiscellaneous Food andBeverages (Potential NewCategory)Bacardi CorpCatano, PRDMR 2008Sulfur188,00097.4%Did not remove loadfrom category TWPE.Independent and Stand AloneLabs (Potential NewCategory)Battelle MemorialInstituteColumbus,OHDMR 2008Chloride186,00099.1%Did not remove loadfrom category TWPE.Ferroalloy Manufacturing(Part 424)Eramet Marietta, Inc.Marietta,OHTRI 2008Manganese andManganeseCompounds12,50096.9%Did not remove loadfrom category TWPE.Tobacco Products (PotentialNew Category)Philip Morris USAPark 500 SiteChester, VATRI 2008Chlorine1,77098.7%Did not remove loadfrom category TWPE.Coil Coating (Part 465)Latasde AluminioReynoldsGuayama,PRDMR 2008Sulfur47695.1%Did not remove loadfrom category TWPE.Ink Formulation (Part 447)Superior Printing Ink,Co, Inc.Marlboro,MADMR 2008Chlorine24.699.6%Did not remove loadfrom category TWPE.Source:DMRLoads2008_v2andTRIReleases2008_v3.Section 5 – 2010 Annual Review5-7Table 5-3. FinalTRIReleases2008andDMRLoads2008Combined Point Source Category Rankings40 CFRPartPoint Source CategoryTRIReleases2008TWPEDMRLoads2008TWPETotal TWPECumulativePercentage of TotalTWPERank430Pulp, Paper And Paperboard523,000510,0001,030,00012.8%1419Petroleum Refining410,000618,0001,030,00025.6%2421Nonferrous Metals Manufacturing38,700955,000994,00037.9%3418Fertilizer Manufacturing8,120818,000826,00048.2%4414Organic Chemicals, Plastics And Synthetic Fibers137,000512,000649,00056.2%5440Ore Mining And Dressing109,000339,000448,00061.8%6415Inorganic Chemicals Manufacturing71,300228,000299,00065.5%7444Waste Combustors8,830245,000254,00068.7%8410Textile Mills2,750247,000250,00071.8%9463Plastics Molding And Forming74,700174,000249,00074.9%10NAMiscellaneous Foods And Beverages5,210193,000198,00077.3%11445Landfills781191,000192,00079.7%12411Cement Manufacturing529189,000190,00082.1%13435Oil & Gas ExtractionNA189,000189,00084.4%14NAIndependent And Stand Alone Labs49.9186,000186,00086.7%15455Pesticide Chemicals35,500114,000150,00088.6%16464Metal Molding And Casting (Foundries)5,040122,000127,00090.2%17NAFood Service EstablishmentsNA119,000119,00091.6%18436Mineral Mining And Processing3,390100,000103,00092.9%19428Rubber Manufacturing7,18073,70080,90093.9%20434Coal Mining1,28076,40077,70094.9%21429Timber Products Processing27,30031,50058,80095.6%22439Pharmaceutical Manufacturing6,89049,10056,00096.3%23467Aluminum Forming5,83033,70039,50096.8%24471Nonferrous Metals Forming And Metal Powders20,90015,00035,90097.3%25409Sugar Processing20535,30035,50097.7%26437Centralized Waste Treatment6,85025,50032,40098.1%27Section 5 – 2010 Annual Review5-8Table 5-3. FinalTRIReleases2008andDMRLoads2008Combined Point Source Category Rankings40 CFRPartPoint Source CategoryTRIReleases2008TWPEDMRLoads2008TWPETotal TWPECumulativePercentage of TotalTWPERank458Carbon Black Manufacturing27,60033527,90098.5%28422Phosphate Manufacturing65717,20017,90098.7%29469Electrical And Electronic Components3,58012,30015,90098.9%30460HospitalNA15,70015,70099.1%31424Ferroalloy Manufacturing12,9002,56015,50099.3%32457Explosives Manufacturing43.210,40010,40099.4%33406Grain Mills5,6004,3009,90099.5%34468Copper Forming4,7802,4707,25099.6%35425Leather Tanning And Finishing6,99017.57,01099.7%36407Canned And Preserved Fruits And VegetablesProcessing4,8105195,33099.8%37405Dairy Products Processing3,7501,4505,20099.8%38461BatteryManufacturing1,5806222,20099.8%39442Transportation Equipment CleaningNA1,8401,84099.9%40NATobacco Products1,79011.31,80099.9%41443Paving And Roofing Materials (Tars And Asphalt)9277511,68099.9%42426Glass Manufacturing4739171,39099.9%43408Canned And Preserved Seafood Processing1089321,04099.9%44417Soap And Detergent Manufacturing77679.9856100.0%45NAPrinting And Publishing141671812100.0%46465Coil Coating191501692100.0%47446Paint Formulating55118.3569100.0%48454Gum And Wood Chemicals Manufacturing69.5218288100.0%49447Ink Formulating35.424.860.2100.0%50466Porcelain Enameling18.57.4325.9100.0%51427Asbestos ManufacturingNA1.421.42100.0%52NAIndustrial LaundriesNA0.3210.321100.0%53Section 5 – 2010 Annual Review5-9Table 5-3. FinalTRIReleases2008andDMRLoads2008Combined Point Source Category Rankings40 CFRPartPoint Source CategoryTRIReleases2008TWPEDMRLoads2008TWPETotal TWPECumulativePercentage of TotalTWPERank459PhotographicNA0.03280.0328100.0%54NAPhoto ProcessingNA0.03280.0328100.0%55Total1,590,0006,460,0008,050,000Source:TRIReleases2008_v3andDMRLoads2008_v2.NA – Not applicable.Section 5 – 2010 Annual Review



### 5-10 5.3 Prioritization of Categories for the 2010 Annual Review

Based on its screening-level review, EPA was ab le to prioritize for further review (i.e., a detailed study or preliminary category review ) those industrial cate gories whose pollutant discharges potentially pose the greatest hazards to human health or the environment because of their toxicity (i.e., categories that collectively discharge over 95 percent of the total TWPE). EPA also considered efficiency and implementation issues raised by stakeholders in identifying candidates for further review. By using this multilayered screening approach, the Agencyconcentrated its resources on those point source categories with the highest estimates of toxicweighted pollutant discharges (based on best avai lable data), while assigning a lower priority to categories that the Agency believes are not good candidates for ELGs revision at this time.

Table 5-4 lists the point source categories with existing ELGs, the level of review EPA performed as part of the 2010 annual review, an d how each category was identified for further review, if applicable.

Table 5-4. 2010 Annual Review of Categories with Existing ELGs: Level of Review

40 CFR

Part Point Source Category Level of Review Source of

Identification for

Further Review

405 Dairy Products Processing Screening-Level Review NA a

406 Grain Mills Manufacturing Screening-Level Review NA a

407 Fruits and Vegetable Processing Screening-Level Review NA a

408 Canned and Preserved Seafood Screening-Level Review NA a

409 Sugar Processing Screening-Level Review NA a

410 Textile Mills Preliminary Review TWPE

411 Cement Manufacturing Preliminary Review TWPE

412 Concentrated Animal Feeding Operations Screening-Level Review NA a

413 Electroplating Screening-Level Review NA a

414 Organic Chemicals, Plastics and Synt hetic Fibers Preliminary Review TWPE

415 Inorganic Chemicals Pr eliminary Review TWPE

417 Soaps and Detergents Manufacturing Screening-Level Review NA a

418 Fertilizer Manufacturing Preliminary Review TWPE

419 Petroleum Refining Preliminary Review TWPE

420 Iron and Steel Manufacturing Screening-Level Review NA a

421 Nonferrous Metals Manufact uring Preliminary Review TWPE

422 Phosphate Manufacturing Screening-Level Review NA a

423 Steam Electric Power Generation Screening-Level Review NA a

424 Ferroalloy Manufacturing Screening-Level Review NA a

425 Leather Tanning and Finishing Screening-Level Review NA a

426 Glass Manufacturing Screening-Level Review NA a

427 Asbestos Manufacturing Screening-Level Review NA a

428 Rubber Manufacturing Preliminary Review TWPE

429 Timber Products Processing Screening-Level Review NA a

430 Pulp, Paper and Paperboard Preliminary Review TWPESection 5 – 2010 Annual Review



### 5-11 Table 5-4. 2010 Annual Review of Categories with Existing ELGs: Level of Review

40 CFR

Part Point Source Category Level of Review Source of

Identification for

Further Review

432 Meat and Poultry Products Screening-Level Review NA a

433 Metal Finishing Screening-Level Review NA a

434 Coal Mining Preliminary Review TWPE

435 Oil and Gas Extraction Detailed Study of Coalbed Methane Operations Comments

Preliminary Review of Remaining Operations TWPE

436 Mineral Mining and Processing Preliminary Review TWPE

437 Centralized Waste Treaters Screening-Level Review NA a

438 Metal Products and Machinery Screening-Level Review NA a

439 Pharmaceutical Manufacturi ng Screening-Level Review NA a

440 Ore Mining and Dressing Preliminary Review TWPE

442 Transportation Equipment Cleaning Screening-Level Review NA a

443 Paving and Roofing Materials (Tars and Asphalt) Screening-Level Review NA a

444 Waste Combustors (Commercial Incinerators Combusting Hazardous Waste) Preliminary Review TWPE

445 Landfills Preliminary Review TWPE

446 Paint Formulating Screening-Level Review NA a

447 Ink Formulating Screening-Level Review NA a

450 Construction and Development Industry Screening-Level Review NA a

451 Aquatic Animal Production Industry Screening-Level Review NA a

454 Gum and Wood Chemicals Screening-Level Review NA a

455 Pesticide Chemicals Manufacturing Preliminary Review TWPE

457 Explosives Screening-Level Review NA a

458 Carbon Black Manufacturing Screening-Level Review NA a

459 Photographic Screening-Level Review NA a

460 Hospital Detailed Study (of Health Care Industry) Comments

461 Battery Manufacturing Screening-Level Review NA a

463 Plastic Molding and Forming Preliminary Review TWPE

464 Metal Molding and Casting (Foundries) Preliminary Review TWPE

465 Coil Coating Screening-Level Review NA a

466 Porcelain Enameling Screening-Level Review NA a

467 Aluminum Forming Screening-Level Review NA a

468 Copper Forming Screening-Level Review NA a

469 Electrical and Electronic Components Screening-Level Review NA a

471 Nonferrous Metals Forming and Meta l Powders Screening-Level Review NA a

NA Food Service Establishments Preliminary Review TWPE

NA Miscellaneous Food and Beverages Preliminary Review TWPE

NA Independent and Stand Alone Labs Preliminary Review TWPESection 5 – 2010 Annual Review



### 5-12 a – For categories with only a screening- level review, the source of identifica tion is not applicable, as EPA conducts a screening-level review of all categor ies subject to existing effluent guidelines. The “source of identification” is only applicable for those industries selected for further review. NA – Not applicable.



### 5.3.1 Detailed Study of Existing ELGs

EPA performed detailed studies on two point source categories as pa rt of its 2010 annual

review based on the results of its 2008 and 2009 annual reviews. Because EPA data collection was not finished in 2009, EPA continued detailed studies of the Oil and Gas Extraction Category (40 CFR Part 435) to assess whethe r to revise the limits to include coalbed methane extraction as a new subcategory, and the Health Care Industr y (includes Hospitals (40 CFR Part 460)). EPA did not identify additional categories for deta iled study as part of the 2010 annual review.

EPA’s detailed studies generally examine the following: (1) wastewater characteristics and pollutant sources; (2) the pollutants driving the toxic-wei ghted pollutant discharges; (3) availability of pollution preventi on and treatment; (4) the geographic distribution of facilities in the industry; (5) any pollutant discharge trends within the industry; and (6) any relevant economic factors. First, EPA attempts to verify the screening-level result s and fill in data gaps. Next, EPA considers costs and performance of applicable and demonstr ated control technology, process change, or pollution prev ention alternatives that can e ffectively reduce the pollutants remaining in the industrial category's wastewat er. Last, EPA considers the affordability or economic achievability of the technology, proces s change, or pollution prevention measures

identified above.

Types of data sources that EPA may consu lt in conducting its deta iled studies include, but are not limited to: (1) the U.S. Economic Cens us; (2) TRI, Permit Compliance System (PCS), and the Integrated Information System – Nati onal Pollutant Discharge Elimination System (ICIS-NDPES) data; (3) trade associations and repor ting facilities to verify reported releases and facility categorization; (4) re gulatory authorities (states a nd EPA regions) to understand how category facilities are permitted; (5) National Po llutant Discharge Elimination System (NPDES) permits and their supporting fact sheets; (6) EPA effluent gui delines technical development documents; (7) relevant EPA preliminary data summaries or study report s; and (8) technical literature on pollutant sources and control technologies.

For more information about the Oil and Gas Extraction Detailed Study (coalbed methane industry) and the Health Care Industry Detailed Study, see Sections 16.2 and 16.1 of this report, respectively.

5.3.2 Preliminary Category Reviews

Preliminary category reviews are similar to detailed studies and have the same purpose. During preliminary reviews, EPA generally examin es the same items listed above for detailed studies. However, EPA’s preliminary review of a category and available pollution prevention and treatment options is less rigorous than its detailed studies. While EP A collects and analyzes hazard and technology-based information on ca tegories undergoing preliminary review, it assigns a higher priority to investiga ting categories undergoing detailed studies.

As shown in Table 5-4 , EPA identified for preliminary review 21 industrial categories that cumulatively discharge more than 95 percent of the combined DMRLoads2008 andSection 5 – 2010 Annual Review



### 5-13 TRIReleases2008 total TWPE. Three of the 21 industrial categories identified for preliminary review are potential new categories. Based on information from the 2010 and previous annual reviews, EPA concluded that the following 13 i ndustrial categories did not require a detailed section in this report. For thes e 13 categories, EPA determined that the conclusions were the same as made during previous annual reviews or the majority of the TWPE was due to data errors (e.g., incorrect units) 11 

### . These industrial categories, and the reasons for excluding them from further preliminary review, are listed below. EPA is assigning all of these categories with a lower priority for revision (i.e ., the category is marked with “( 3)” in the “Findings” column in Table V-1 in the 2010 Final Plan FR notice).

Cement Manufacturing (40 CFR Part 411)

For th e Cement Manufacturing Category, the DMRLoads2008_v2 database accounts for the majority of the combined estimated TWPE . EPA identified one facility, Lafarge North America’s Alpena Plant in Alpena, MI, that accounts for approximately 89 percent of the 2008 DMR TWPE for the Cement Manufacturing Category. EPA determined that the mercury quantities are incorrect because they do not match the load calculated using the mercury

concentrations and flows. Corr ecting these errors reduces the facility’s 2008 DMR TWPE from 169,000 to 759 and reduces the Cement Manufacturing Category’s combined 2008 DMR and TRI TWPE from 190,000 to 21,100 (ERG, 2010). The cat egory is no longer a priority for the

2010 annual review.

Petroleum Refining (40 CFR Part 419)

T he Petroleum Refining Category total TWPE is approximately 60 percent from the 2008 DMR database and 40 percent from the 2008 TRI database. The top pollutant in the 2008 DMR database is sulfide, while the top pollutants in the 2008 TRI database are dioxin and dioxin-like compounds and polycyclic aromatic compounds (PAC s). Discharges of these four pollutants from petroleum refineries have been reviewed in previous an nual reviews, and EPA concluded the following:

• 

### Sulfide : As part of the 2004 detailed st udy of the Petroleum Refining Category, EPA determined that petroleum refi neries are achieving final effluent concentrations less than existing limits in 40 CFR Part 419 and refineries are treating sulfide to concentra tions at or near treatabl e levels (U.S. EPA, 2006b).

• 

### Dioxin and dioxin- like compounds : EPA determined that dioxin and dioxin-like compounds are produced during catalytic reforming and catalyst regeneration operations at petroleum refineries. Most facilities reporting dioxin and dioxin-like compounds in TRI never detected dioxin and dioxin-like compounds in their process wastewater effluent. Of the 232 refineries in TRI 2007 that report nonzero TWPE, nine reported discharges of dioxin and dioxin-like compounds. Of the nine refineries report ing dioxin and dioxin-like compound discharges in 2007, only five of these refineries reported dioxin discharges based on analytical

11 EPA generated a corrected version of the 2008 DMR database: DMRLoads2008_v3, which is available via http://www.regulations.gov, EPA-HQ -OW-2008-0517 DCN 07317. This ve rsion includes all corrections

documented in this TSD.Section 5 – 2010 Annual Review



### 5-14 measurements (see Table 11-5 in the Technical Support Document for the Preliminary 2010 Effluent Guidelines Program Plan (U.S. EPA, 2009)).

• 

### PACs : EPA determined that petroleum refi neries report PAC discharges to TRI that are either based on half the detection limit multiplied by the flow or using

emission factors. EPA determined that there is little evidence that PACs are being discharged to surface waters in concen trations above the detection limit (U.S. EPA, 2009).

EPA determined that the 2008 petroleum refinery discharges were consistent with previous years’ discharges. As a result, EPA will rely on the conclusions from previous annual reviews: the discharges from this category do not represent a priority hazard at this time. The category is no longer a priority for the 2010 annual review.

Nonferrous Metals Manufacturing (40 CFR Part 421)

For the Nonferrous Metals Manufacturing Category, the DMRLoads2008_v2 database accounts for the majority of the combined estimated TWPE. The top facility, USEC PDGDP in McCracken County, KY, accounts for almost 60 percent of the category’s 2008 DMR TWPE. EPA contacted the facility to di scuss discharges of polychlorinat ed biphenyls (PCBs) as part of

the 2010 annual review. The facili ty contact verified that EPA’s database was properly characterizing the PCB discharge and indicated that the PCBs are from stormwater due to legacy activity at the site. The facility contact also i ndicated that USEC PDGDP treats all process water that may contain PCBs using carbon adsorption (Travis, 2010). EPA determined that the PCB discharges are not from nonferrous metals manuf acturing processes and, therefore, should be excluded from the category’s TWPE. Therefore, EPA determined that the 2008 nonferrous metals manufacturing discharges are consistent with the previous year’s discharges. As a result, EPA will rely on the conclusions from previous annual reviews: the discharges from this category do not represent a priority hazard at this time. See Section 8.0 of the 2009 TSD for additional information (U.S. EP A, 2009). The category is no l onger a priority for the 2010

annual review.

Rubbe r Manufacturing (40 CFR Part 428)

For the Rubber Manufacturing Category, the DMRLoads2008_v2 database accounts for the majority of the combined estimated TW PE. EPA identified the following two facilities accounting for approximately 79 percent of th e 2008 DMR TWPE for th e Rubber Manufacturing Category:

• 

### Durakon Industries, Inc. in Lapeer, MI: EPA determined that the January and December 2008 mercury quantities are inco rrect because they do not match the load calculated using the mercury concentrations and flows. Correcting these data reduces the facility’s 2008 DMR TWPE from 34,900 to 0.11 (ERG, 2010).

• 

### Kraton Polymers, US, LLC in Belpre, OH: EPA determined that the January through December 2008 arsenic quantities are incorrect because they do not match the load calculated using the arseni c concentrations and flows. Correcting these data reduces the facility’s 2008 DMR TWPE from 23,200 to 2,900 (ERG, 2010).Section 5 – 2010 Annual Review



### 5-15 After reviewing the data, EPA determined that the discharges from the facilities above were incorrect. Correcting these errors reduces the Rubber Manufacturing Category combined 2008 DMR and TRI TWPE from 80,900 to 25,700 (ERG, 2010) . The category is no longer a priority

for the 2010 annual review.

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

T he Pulp, Paper, and Paperboard (Pulp and Paper) Category total TWPE is approximately 50 percent from the 2008 DMR database and 50 percent from the 2008 TRI database. The top pollutants in the 2008 DMR database are 2,3,7,8 -tetrachlorodibenzo- p-dioxin (2,3,7,8-TCDD) and sulfide, while the top po llutants in the 2008 TRI database are manganese and manganese compounds, lead and lead compounds, and dioxin and dioxin-like compounds. Discharges of dioxin and dioxin-like compounds, including 2,3, 7,8-TCDD, and manganese and manganese compounds from pulp and paper facilities have b een reviewed in previous annual reviews:

• 

### 2,3,7,8-TCDD (DMR) and Dioxin and Di oxin-Like Compounds (TRI) : EPA determined that the 2,3,7,8-TCDD DMR data were not detected in bleach plant effluent or final mill effluent (U.S. EPA, 2006a). Additionally, EPA determined that the majority of the underlying data used to estimate releases of dioxin and dioxin-like compounds reported to TRI were pollutant concentr ations below the Method 1613B minimum level. Therefore, there is substantial uncertainty about the magnitude of these reported discharges . TRI-reported discharges of dioxin and dioxin-like compounds for the Pulp a nd Paper Category are most likely significantly overestimated and thus do not accurately reflect current industry discharges (U.S. EPA, 2009).

• 

### Manganese and Manganese Compounds : As part of the Pulp and Paper Detailed Study performed in the 2006 a nnual review, EPA determined that the manganese concentrations were too low to treat using end-of-pipe treatment technologies for large plant flows (U.S. EPA, 2006a). Although EPA has not reviewed new discharge concentration data , it has no new data to suggest that manganese concentrations are above th e treatable levels (U.S. EPA, 2009).

E PA has not reviewed discharges of sulfid e and lead and lead compounds from pulp and paper facilities as part of previous annual re views. EPA’s findings as part of the 2010 annual

review for sulfide and lead a nd lead compound discharges are:

• 

### Sulfide : Approximately 23 percent of th e 2008 DMR TWPE for the Pulp and Paper Category is from sulfide discharges. There are two facilities with sulfide discharges in the 2008 DMR database: Smur fit-Stone Container in Florence, SC and Domtar Johnsonburg in Johnsonburg, PA. The 2008 sulfide discharges for Smurfit-Stone Container ranged from be low the detection limit (0.1 mg/L to 1.0 mg/L) to 1.7 mg/L. The Lockwood-Post’s Directory of Pulp and Paper Mills

indicates that Smurfit-Stone Container has a 1,600 acre settling basin. Sulfides may result from an anaerobic portion of th e settling basin. EPA determined that

the sulfide concentration for Domt ar Johnsonburg was reported below the detection limit, while the sulfide quantity was reported above the detection limit.Section 5 – 2010 Annual Review



### 5-16 Therefore, sulfide discharges from Domtar Johnsonburg are likely below the detection limit, resulting in a 16,000 TWPE reduction in the Pulp and Paper Category’s sulfide TWPE. EPA will continue to monitor the sulfide discharges to determine if they are properly controlled.

• 

### Lead and Lead Compounds : Approximately 13 per cent (63,800 TWPE) of the 2008 TRI TWPE for the Pulp and Paper Catego ry is from discharges of lead and lead compounds. There are 185 pulp and paper facilities in the 2008 TRI database reporting discharges of lead and lead co mpounds. The top facility with discharges of lead and lead compounds is Kimberly Clark in Everett, WA that accounts for approximately 9.6 percent of the Pulp and Paper Category’s lead and lead compound discharges; therefor e, there are no outlier pu lp and paper facilities discharging lead and lead compounds. The majority of the lead and lead compounds are based on monitoring data (54 discharges) or published emission factors (46 discharges). Because there are no outlier facilities, EPA determined

that the lead and lead compound discharges are like ly accurate. EPA suspects high TWPE from the high volume of lead and lead compound dischargers in the Pulp and Paper Category. EPA will con tinue to monitor the lead and lead compound discharges to determine if they are properly controlled.

EPA determined that the 2008 pulp and pape r discharges of dioxin and dioxin-like compounds and manganese and manganese compounds were consistent with previous years’ discharges. EPA will continue to monitor the Pu lp and Paper Category’s sulfide and lead and lead compound discharges to determine if they ar e properly controlled. As a result, EPA will rely on the conclusions from previous annual reviews: the discharges from this category do not represent a priority hazard at this time. The category is no longer a priority for the 2010 annual

review.

Coal Mining (40 CFR Part 434)

For the Coal Mining Category, the DMRLoads2008_v2 database accounts for the majority of the combined estimated TWPE. Th e top pollutants in the 2008 DMR database are manganese and iron. Discharges of these pollutants fr om coal mines were reviewed as part of the Coal Mining Detailed Study during the 2007 a nd 2008 annual reviews. EPA determined that

based on its review of available data, revisions to the pollutant limitations in the Coal Mining ELGs were not warranted (U.S. EPA, 2008).

Pesticide Chemicals (40 CFR Part 455)

For the Pesticide Chemicals (Pesticides) Category, the DMRLoads2008_v2 database accounts for the majority of the combined estimated TWPE. EPA identified one facility, Bayer CropSciences in Institute, WV , that accounted for approximately 83 percent of the 2008 DMR TWPE for the Pesticides Category. EPA determined that the majority of the of the facility’s estimated load results from total carbaryl. EPA c ontacted Bayer CropSciences to verify the total carbaryl quantities and c oncentrations and flow. Bayer CropSci ences indicated that all of the total carbaryl quantities and con centrations for outfall 005 were reported below the detection limit, while all but one total carbaryl con centration for outfall 301 was reported below the detection limit (Smith, 2010). Using the facility-provided quantitie s and concentrations reducesSection 5 – 2010 Annual Review



### 5-17 Bayer CropSciences 2008 DMR TWPE from 94,300 to 532 and reduces the Pesticides Category’s total TWPE from 114,000 to 20,000 (ERG, 2010). The category is no longer a priority for the 2010 annual review.

Metal Molding and Casting (40 CFR Part 464)

For the Metal Molding a nd Casting Category, the DMRLoads2008_v2 database accounts for the majority of the combined estimated TW PE. EPA identified one facility, Eagle-Picher Industries in Sidney, OH, that accounted for approximately 61 percent of the 2008 DMR TWPE for the Metal Molding and Casting Category. EP A determined that the outfall 001 flows for September, October, and December 2008 were in correctly entered as million gallons per day (MGD) instead of gallons per day (GPD). Corr ecting these errors re duces the facility’s 2008 DMR TWPE from 74,700 to 32 and reduces the Metal Molding and Casting Category’s total TWPE from 127,000 to 52,300 (ERG, 2010). The categ ory is no longer a priority for the 2010

annual review.

Miscellaneous Food and Bever ages (Potential New Category)

For the Miscellaneous Foods and Be verages Potential New Category, the
DMRLoads2008_v2 database accounts for the majority of the combined estimated TWPE. EPA identified one facility, Bacardi Corp. in Cata no, PR, that accounted for approximately 97 percent of the 2008 DMR TWPE for the Miscellaneous Food and Beverages Potential New Category. EPA reviewed this facility’s discharges in pr eparing the 2006 Final Pl an as well (U.S. EPA, 2006b).

EPA contacted EPA Region 2 to discuss the B acardi discharges and determined that the facility’s sulfide discharges were unique to the facility. According to Region 2 staff, the Bacardi

effluent wastewater charact eristics include high levels of biochemical oxygen demand – approximately 15,000 milligrams per liter (mg/L), bacteria, and solids, which complicate its treatment. As a result, Region 2 worked with the facility to determine treatable levels. The wastewater discharge commingles with adjacent wa stewater treatment discharges from PRASA’s Puerto Nuevo and Bayamon wastewater treatment plants (WWTPs). The wa stewater discharges immediately dilute the discharge from the Bacardi plant. As a result, Region 2 concluded that certain pollutants, such as sulfide, can be disc harged at high concentrations and will be diluted prior to reaching surf ace water (O’Brien, 2010). EPA based the water quality based limitations for this facility on the final Water Quality Cert ificate issued by the Puer to Rico Environmental Quality Board (U.S. EPA Region 2, 2007). The resulting permit limit for sulfide is 108 mg/L at the outfall. The sulfide limit at the edge of th e mixing zone, after commingling with the WWTPs is 2 μg/L (U.S. EPA Region 2, 2008). Because one facility accounted for the vast majority of the TWPE, EPA determined that ELGs for the potent ial new category are not warranted. Therefore, the category is no longer a prio rity for the 2010 annual review.

Food Service Establishments (Potential New Category)

For the Food Service Establishments Potential New Category, the DMRLoads2008_v2

database accounts for all of the total TWPE (food service estab lishments do not report to TRI). EPA identified one facility, Gionino’s Pizza in OH, that accounted for approximately 75 percent of the 2008 DMR TWPE for the Food Service Establishments Potential New Category. EPA

determined that the outfall 001 flows for January through December 2008 were incorrectlySection 5 – 2010 Annual Review



### 5-18 entered as MGD instead of GPD. Correcting these errors reduces the facility’s 2008 DMR TWPE from 90,700 to 3.7 and reduces the Food Service Establishments Potential New Category’s combined 2008 DMR and TRI TW PE from 198,000 to 34,000 (ERG, 2010). The category is no longer a priority for the 2010 annual review.

Independent and Stand Alone La bs (Potential New Category)

For the Independent and Stand Alone Labs Potential New Category, the
DMRLoads2008_v2 database accounts for the majority of the combined estimated TWPE. EPA identified one facility, Battelle Memorial In stitute in Columbus, OH, that accounted for approximately 99 percent of th e 2008 DMR TWPE for the Independent and Stand Alone Labs Potential New Category. EPA determined that the outfall 002 flows for January through August and October through December 2008 were incorrectly entered as MGD instead of GPD. Correcting these errors reduces the facility’s 2008 DMR TWPE from 184,000 to 1.2 and reduces the Independent and Stand Alone Labs Potent ial New Category’s combined 2008 DMR and TRI TWPE from 186,000 to 1,810 (ERG, 2010). The catego ry is no longer a priority for the 2010

annual review.

The preliminary reviews for the remaining ei ght categories involved more than discharge data errors and, therefore, each have sections in this report. The eight preliminary reviews identified are listed below, along with a referenc e to where they are discussed in this report:

• 

### Fertilizer Manufacturing Category (Section 6 );

• 

### Inorganic Chemicals Manufacturing Category (Section 7 );

• 

### Landfills Category (Section 8 );

• 

### Mineral Mining and Processing Category (Section 9 );

• 

### Oil and Gas Extraction Cate gory (Excluding CBM) (Section 10 );

• 

### Ore Mining and Dressing Category (Section 11 );

• 

### Organic Chemicals, Plastics, and Synthetic Fibers Category (Section 12 );

• 

### Plastics Molding and Forming Category (Section 13 );

• 

### Textile Mills Category (Section 14 ); and

• 

### Waste Combustors Category (Section 15 ).

EPA recently conducted detailed studies or pr eliminary reviews of many of the categories

listed above. Table 5-5 lists these categories and the leve l of review performed for EPA’s 2007 through 2010 annual reviews. For each of these categories, EPA’s annual review builds on previous reviews. For the preliminary category re views and detailed studies discussed in this document, EPA primarily looked at the pollutants reported in 2008 and their contribution to their category’s TWPE.Section 5 – 2010 Annual Review



### 5-19 Table 5-5. Previous Reviews for Categories wi th Preliminary Category Reviews for the

2010 Annual Review

40 CFR

Part Point Source Category Level of Review for

2007/2008 Level of Review for

2009/2010

410 Textile Mills Screening-Level Review a Preliminary Category Review

414 Organic Chemicals, Plastics, and Synthetic Fibers Preliminary Category Review Preliminary Category Review

415 Inorganic Chemicals Manufacturing Screening-Level Review a Preliminary Category Review

418 Fertilizer Manufacturi ng Screening-Level Review a Preliminary Category Review

435 Oil and Gas Extraction, excluding Coalbed Methane operations NA Preliminary Category Review

436 Mineral Mining and Processing NA Preliminary Category Review

440 Ore Mining and Dressing Preliminary Category Review Preliminary Category Review

444 Waste Combustors Preliminary Category Review Preliminary Category Review

445 Landfills NA Preliminary Category Review

463 Plastics Molding and Forming Screening-Level Review a Preliminary Category Review

a

– EPA conducted a preliminary category review as part of the 2007 annual review, but not as part of the 2008

annual review.

N A – Not applicable.



### 5 .4 2010 Annual Review References

1. Auchterlonie, Steve. 2009. Notes from Telephone Conversation between Steve Auchterlonie, Front St. Remedi al Action, and Chris Krejci, Ea stern Research Group, Inc. “RE: Verification of magnitude and basis of estimate for dioxin and dioxin-like compounds discharges in PCS.” (March 13). EPA-HQ-OW-2008-0517-0076.

2. ERG. 2010. Eastern Research Group, Inc. Prelim inary Category Review – Facility Data Review and Revised Calculations. (September). EPA-HQ-OW-2008-0517 DCN 07304.

3. O’Brien, Karen. 2010. EPA Region 2. Notes from Telephone Conversation between Karen O’Brien, EPA Region 2, a nd Eleanor Codding, Eastern Research Group, Inc. “RE: Sulfide discharges from Bacardi Corporat ion in Puerto Rico.” (August). EPA-HQ-OW2008-0517 DCN 07305.

4. Smith, Gordon. 2010. Telephone and E-mail co mmunication with Gordon Smith, Bayer CropSciences, and Lauren Wingo, Easter n Research Group, Inc. “Re: Bayer CropSciences’ 2008 DMR Pesticide Discharg es.” (September 14). EPA-HQ-OW-2008-

0517 DCN 07268.

5. Travis, Chris. 2010. Notes from Telephone C onversation between Chris Travis, USEC PDGDP, and Elizabeth Sabol, Eastern Resear ch Group, Inc. “RE: PCB concentrations reported to DMR in 2008.” (March 17). EPA-HQ-OW-2008-0517 DCN 07265.

6. U.S. EPA Region 2. 2007. National Pollutant Di scharge Elimination System Fact Sheet – PR0000591 – Bacardi Corporation – Cataño, Puerto Rico. (December 12). EPA-HQOW-2008-0517 DCN 07269.Section 5 – 2010 Annual Review



### 5-20 7. U.S. EPA Region 2. 2008. National Pollutant Discharge Elimination System Permit – PR0000591 – Bacardi Corporation – Cataño, Pu erto Rico. (July 1). EPA-HQ-OW-2008-

0517 DCN 07270.

8. U.S. EPA. 1988a. CERCLA Compliance with Other Laws Manual: Interim Final. EPA540-G-89-006. OSWER Publication 9234.1-01. Wa shington, DC. (August). Available online at: www.epa.gov/superfund/res ources/remedy/pdf/540g-89006-s.pdf.

9. U.S. EPA. 1988b. Guidance on Remedial Ac tions for Contaminated Ground Water at Superfund Sites. OSWER Directiv e 9283.1-2. EPA-540-G-88-003. (December). Available online at: www.epa.gov/superf und/resources/remedy/pdf/540g-89006-s.pdf.

10. U.S. EPA. 2006a. Final Report: Pulp, Paper, and Paperboard Detailed Study . EPA-821- R-06-016. Washington, DC. (Novemb er). EPA-HQ-OW-2004-0032-2249.

11. U.S. EPA. 2006b. Technical Support Document for the 2006 Effluent Guidelines Program Plan . EPA-821R-06-018. (December). EPA-HQ-OW-2004-0032-2782.

12. U.S. EPA. 2008. Coal Mining Detailed Study . EPA-821-R-08-012. Washington, DC. (August). EPA-HQ-OW-2006-0771-1695.

1 3. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent Guidelines Program Plan . EPA-821-R-09-006. Washingt on, DC. (October). EPA-HQOW-2008-0517-0515.Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-1 6. F ERTILIZER 

### M ANUFACTURING 

### (40 CFR P ART 

### 418)

EP A selected the Fertilizer Manufacturing Category for preliminary review because it continues to rank high, in terms of toxic-weighted pound equivale nt (TWPE), in point source category rankings (see Table 5-3 for the point source category rankings). The Final 2006 Plan summarizes the results of EPA’s previous revi ew of this industry in 2004 and 2005 (71 FR 76644). EPA also reviewed discharges from the Fe rtilizer Manufacturing Category as part of the 2009 annual review (74 FR 68599). This secti on summarizes the results of the 2010 annual

review associated with the Fe rtilizer Manufacturing Category. EPA focused on discharges of fluoride from two facilities because of their high TWPE relative to the other facilities in the Fertilizer Manufacturing Category.

6.1 Fertilizer Manufacturing Category Background

Th is subsection provides the background on the Fertilizer Manufacturing Category including a brief profile of th e fertilizer manufacturing indus try and background on 40 CFR Part

418.

6. 1.1 Fertilizer Manufacturing Industry Profile

Th e fertilizer manufacturing industry incl udes facilities that produce phosphorus- and nitrogen-based fertilizers (U.S . EPA, 2006). EPA considered the following three North American Industrial Classification System (N AICS) codes as part of the Fe rtilizer Manufacturing Category:

• 

### 325311: Nitrogenous Fertilizer Manufacturing;

• 

### 325312: Phosphatic Fertilizer Manufacturing; and

• 

### 325314: Fertilizer (Mixing Only) Manufacturing.

Because the Permit Compliance System (PCS ) and Integrated Compliance Information System – National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the sources of the discharg e monitoring report (DMR) data used to develop DMRLoads2008 , report facilities by Standard Industrial Classification (SIC) code, and the U.S. Economic Census and Toxics Release Inventory (TRI) report data by North American Industry Classification System (NAICS) code, EPA reclassi fied the 2008 DMR data by th e equivalent NAICS code. Table 6-1

lists the number of facilities from the U.S. Ec onomic Census and the screening-level databases for the three NAICS codes with operations in the Fertilizer Manufacturing Category, including the corresponding SIC codes for reference. The U. S. Economic Census includes more facilities than the screening-level database s because of many possible factor s including: facilities may not meet TRI-reporting thresholds, facilities may di scharge to a publicly owned treatment works (POTW), and some facilities in the U.S. Economic Census are dist ributors or sales facilities, not

manufacturers.Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-2 Table 6-1. Number of Fertilizer Manufacturing Facilities

NAICS Code Corresponding SIC Code Number of Facilities

2002 U.S.

Economic

Census 2008 DMR

Database a 2008 TRI

Database b

325311: Nitrogenous Fertilizer Manufacturing 2873: Nitrogenous

Fertilizers 144 63 42

325312: Phosphatic Fertilizer Manufacturing 2874FER: Phosphatic

Fertilizers c 45 2 d 17 e

325314: Fertilizer (Mixing Only) Manufacturing 2875: Fertilizer (Mixing Only) Manufacturing 534 54 57

Total 723 119 116

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2 ; and TRIReleases2008_v3

. a – Includes both major and minor dischargers. Also, DMR data is reported by SIC code; therefore EPA used an NAICS to SIC crosswalk for comparison purposes. b – Facilities reporting releases to any media. c – Wastewater generated by facilities in SIC code 2874 can be regulated under multiple categories. Most facilities in SIC code 2874 are grouped under the Phosphate Manufacturing Category (40 CFR Part 422). EPA reviewed available information about pollutant loads and manufacturing operations for facilities repor ting this SIC code. In its crosswalk, EPA assigned the extension “FER” to the end of the SIC codes for facilities that most likely fall under the applicability of 40 CFR Part 418, Fe rtilizer Manufacturing (U.S. EPA, 2006). d – Includes facilities that EPA determined were subject to the Fertilizer Manufacturing Effluent Limitations Guidelines and Pretreatment Standards (ELGs) as part of the 2006 annual review reporting SIC code 2874: Phosphatic Fertilizers (U.S. EPA, 2006).

e – EPA identified an error in the TRIReleases2008_v3 database, and pollutant loads for facilities with NAICS code 325312 are currently associat ed with the Phosphate Manufacturing Category (40 CFR Part 422) rather than the Fertilizer Manufacturing Category. The 2008 TRI TWPE for these facilities is only 657 TWPE (compared with the Fertilizer Manufacturing Category total of 826,000 TW PE). Therefore, the TWPE associated with facilities reporting NAICS code does not affect the category ranki ng. EPA will correct the error in future annual reviews.



### Table 6-2 shows whether permitting authorities desi gnated direct discharging facilities in the Fertilizer Manufacturing Category as minor or major dischargers (see Section 4.1.5 ). EPA included data for minor dischargers in the 2010 annual review, as part of DMRLoads2008_v2 (for previous annual reviews, EPA included only major dischargers). EPA does not require permitting authorities to submit DMR data for minor dischargers; however, many states do provide complete DMR data for them. From the 2010 annual review, EPA observed many data entry or other errors for minor dischargers in ad dition to those previously identified for major dischargers, as discussed in Section 4.3

. Table 6-2 shows that approximate ly 81 percent of the Fertilizer Manufacturing Category dischargers in the 2008 DMR database are minor dischargers. However, as shown in Table 6-6 , the TWPE from the minor discha rgers is negligible compared to the facilities with the greatest TWPE in this category (i.e., major dischargers).Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-3 Table 6-2. Number of Fertilizer Manufacturing Fa cilities by Discharge Classification in

2008 DMR Database

NAICS Code a Number of Facilities in 2008 DMR Database

Major Dischargers Minor Dischargers All Dischargers

325311: Nitrogenous Fertilizer Manufacturing 21 42 63

325312: Phosphatic Fertili zer Manufacturing 2 0 2

325314: Fertilizer (Mixing Only) Manufacturing 0 54 54

Total 23 96 b 119

Source: DMRLoads2008_v2

. a – DMR data is reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison

purposes. b – The DMR data in PCS and ICIS-NPDES do not include discharge data for all minor dischargers. For the facilities in the Fertilizer Manufacturing Category, 32 of the 96 minor dischargers have DMR data.



### Table 6-3 presents the type of disc harges reported by facilitie s in the 2008 TRI database. The majority of fertilizer manufacturing facilitie s reporting to TRI reported direct discharges to

surface waters.

Table 6-3. Number of Fertilizer Manufacturing Facilities by Discharge Type in 2008 TRI

Database

NAICS Code Number of Facilities in 2008 TRI Database

Direct Dischargers Only Indirect Dischargers Only Both Indirect

and Direct Dischargers No Water Discharges

325311: Nitrogenous Fertilizer Manufacturing 23 2 2 15

325312: Phosphatic Fertilizer Manufacturing 8 1 1 7

325314: Fertilizer (Mixing Only) Manufacturing 11 3 1 42

Total 42 6 4 64

Source: TRIReleases2008_v3

.



### 6.1.2 40 CFR Part 418

EPA first promulgated ELGs for the Ferti lizer Manufacturing Category (40 CFR Part 418) on April 8, 1974 (39 FR 12836) for the Basic Fertilizer Chemicals Segment and on January 14, 1975 (40 FR 2652) for the Formulated Fertil izer Chemicals Segment. The Fertilizer Manufacturing ELGs are applicable to proce ss wastewater and contaminated nonprocess wastewater discharged from the specific subcategories listed in Table 6-4 . The seven subcategories are based on the type of fertilizer produced.Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-4 Table 6-4. Subcategories in the Fertilizer Manufacturing Category

Subpart Title Description

A Phosphate Subcategory a Manufacture of sulfuric acid by sulfur burning, wet-process

p hosphoric acid, normal superphosphate, triple superphosphate, and ammonium phosphate.

B Ammonia Subcategory Manufacture of ammonia.

C Urea Subcategory Manufacture of urea.

D Ammonium Nitrate Subcategory Manufacture of ammonium nitrate.

E Nitric Acid Subcategory Production of nitr ic acid in concentrations up to 68 percent.

F Ammonium Sulfate Production Subcategory Production of ammonium sulfate by the synthetic process and by coke oven by-product recovery.

G Mixed Blend Fertilizer Production Subcategory Production of mixed b and blend c fertilizer.

Source: Fertilizer Manufacturing Point Source Category - 40 CFR Part 418 and Preliminary Review of Prioritized Categories of Industrial Dischargers (U.S. EPA, 2005). a – The applicability of Subpart A excludes certain wet-process phosphoric acid processes from best practicable control technology (BPT) and best available technology economically achievable (BAT) limitations. The exclusion applies to processes that were under construction either on or before April 8, 1974, at plants located in the state of

Louisiana.

b – Mixed fertilizer means “a mixture of wet and/or dry straight fertilizer material, mixed fertilizer materials, fillers and additives prepared through chemical reaction to a given formulation.” c – Blend fertilizer means “a mixture of dry, straight and mixed fertilizer materials.”



### 6.2 Fertilizer Manufacturing Category 2010 Screening-Level Review

Table 6-5 compares the screening-level review results for the Fertilizer Manufacturing Category from the 2006 through 2010 annual reviews. The combined TWPE from discharges in the DMR and TRI databases decreased from discharge years 2002 to 2008. The estimated 2008

DMR TWPE dominates the estimated 2008 cat egory TWPE, composing approximately 99 percent of the combined 2008 DMR and TRI TW PE, similar to previous years of data.

Table 6-5. Fertilizer Manufacturing Catego ry TRI and DMR Discharges for the 2006 through 2010 Screening-Level Reviews

Year of Discharge Year of Review Fertilizer Manufacturing Category

TRI TWPE DMR TWPE a Total TWPE

2002 2006 9,100 1,370,000 1,380,000

2004 2007 10,800 1,170,000 1,180,000

2005 2008 7,300 NA NA

2007 2009 4,460 1,095,000 1,100,000

2008 2010 8,120 818,000 826,000

Source: TRIReleases2002_v4 ; PCSLoads2002_v4 ; TRIReleases2004_v3 ; PCSLoads2004_v3 ; TRIReleases2005_v2 ; TRIReleases2007_v2 ; DMRLoads2007_v4 ; TRIReleases2008_v3 ; and DMRLoads2008_v2

. a – DMR data from 2002 through 2007 includes only major dischargers. 2008 DMR data includes both minor and major dischargers. NA – Not applicable. EPA did not evaluate DMR data for 2005.Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-5 Table 6-6 presents the 2008 DMR TWPE by f acility discharge classification. EPA excluded minor dischargers from previous annual reviews, but included them in the 2010 annual review. The majority (98 percent) of the TW PE in the 2008 DMR database results from major dischargers.

Table 6-6. Fertilizer Manufacturing Category 2008 DMR TWPE by Discharge

Classification

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers

2008 16,300 802,000

So urce: DMRLoads2008_v2

. a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous

annual reviews.



### 6.3 Fertilizer Manufacturing Category Pollutants of Concern

Table 6-7 lists the five pollutants with the highe st TRI TWPE based on results from the 2010, 2009, and 2007 annual reviews ( TRIReleases2008_v3

, TRIReleases2007_v2 , and
TRIReleases2004_ v3 , respectively). Table 6-8 lists the five pollutants with the highest TWPE based on results from the 2010, 2009, and 2007 annual reviews ( DMRLoads2008_v2, DMRLoads2007_v3 , and PCSLoads2004_v4 , respectively).Section 6 – Fertilizer Manufacturing (40 CFR Part 418)6-6Table 6-7. Fertilizer Manufacturing Category Top TRI PollutantsPollutant2004 TRI Dataa2007 TRI Dataa2008 TRI DataaRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPENitrate Compounds1313,5601192,2501273,650Polycyclic Aromatic Compounds311,570Pollutant not reported in the top five2007 TRI reported pollutants.211,170Chlorine581,2102565334772Mercury and Mercury CompoundsPollutant not reported in the top five2004 TRI reported pollutants.3264844710Copper and Copper Compounds4131,24054228510517Zinc and Zinc CompoundsPollutant not reported in the top five2004 TRI reported pollutants.45240Pollutants not reported in the top five2008 TRI reported pollutants.Dioxin and Dioxin-LikeCompounds211,960Pollutant not reported in the top five2007 TRI reported pollutants.Fertilizer ManufacturingCategory TotalNA47b10,850NA29b4,460cNA42b8,120cSource:TRIReleases2004_v3;TRIReleases2007_v2; andTRIReleases2008_v3.a – Discharges include transfers to POTWs and account for POTW removals.b – Number of facilities reporting TWPE greater than zero.c – EPA identified an error in theTRIReleases2007_v2andTRIReleases2008_v3databases, and pollutant loads associated with facilities reporting NAICS code325312 are currently associated with the Phosphate Manufacturing Category (40 CFR Part 422) rather than the Fertilizer Manufacturing Category. EPA willcorrect the error in future years of the TRI database. The TWPEfor these facilities is less than 10 percent of the total TWPEfor both years (242 TWPE for 2007and 657 TWPE for 2008).NA – Not applicable.Section 6 – Fertilizer Manufacturing (40 CFR Part 418)6-7Table 6-8. Fertilizer Manufacturing Category Top DMR PollutantsPollutant2004 DMR Dataa2007 DMR Dataa2008 DMR DatabRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPEFluoride141,120,000131,055,00013778,000Ammonia as Nitrogen4194,5204162,40022716,000Aluminum2116,7003110,6003113,300Cadmium3216,6002225,400416,7102,4-Dichlorophenoxyacetic AcidPollutant not reported in the top five2004 DMR reported pollutants.Pollutant not reported in the top five2007 DMR reported pollutants.511,750Nitrogen, nitrate total (as N)5124,080511782Pollutant not reported in the top five2008 DMR reported pollutants.Fertilizer ManufacturingCategory TotalNA22c1,170,000NA19c1,100,000NA36c818,000Source:PCSLoads2004_v4;DMRLoads2007_v3; andDMRLoads2008_v2.a – 2004 and 2007 DMR data includes only major dischargers.b – 2008 DMR data include major and minor dischargers.c – Number of facilities reportinga TWPE of greater than zero.NA – Not applicable.Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-8 The Fertilizer Manufacturing Category TWPE in the 2008 TRI database is significantly

lower than the TWPE in the 2008 DMR database . Therefore, EPA focused the preliminary category review on the DMR-reported pollutants that account for the majority of the category

TWPE.

Fluoride is the top DMR-reported polluta nt in 2004, 2007, and 2008, contributing more than 95 percent of the total ca tegory TWPE. EPA’s preliminary re view focused on discharges of fluoride and the review results are presente d in the following subsections. EPA did not investigate the other top pollutant s as part of the 2010 annual review because the other pollutants represent a small percentage (6 percent) of the combined 2008 DMR and TRI TWPE for the Fertilizer Manufacturing Category.

6.4 Fertilizer Manufacturing Category Fluoride Discharges in DMR

The 2010 annual review of the Fertilizer Manufacturing Category focused on fluoride discharges in the 2008 DMR database. Table 6-9 presents the facilities th at account for all of the fluoride discharges in the 2008 and 2007 DMR databa ses. The decrease in fluoride TWPE from 2007 to 2008 likely results from decreased flow in 2008, as flow fluctuates with rain events.

The majority (91 percent) of the fluoride discharges in 2008 were from Mosaic Fertilizers, LLC in Uncle Sam, LA. The other two facilities, IMC Phosphates in St. James, LA and Mississippi Phosphates Corp in Pascagoul a, MS account for the remaining 9 percent. Fluoride is generated in the ma nufacture of wet-process phosphor ic acid that is used in phosphatic fertilizer manufacturi ng (U.S. EPA, 1974). See the Technical Support Document for the 2006 Effluent Guidelines Program Plan (U.S. EPA, 2006) for descri ptions of the wet-process phosphoric acid process (Section 8.5.1), wastewater sources of fluoride (Section 8.5.2), and wastewater treatment of fluoride (Section 8.5.3). The subsections below provide information on the facilities that discharge the highest amounts of fluoride.Section 6 – Fertilizer Manufacturing (40 CFR Part 418)6-9Table 6-9. Top Fluoride Discharging Facilities in 2007 and 2008 DMR DatabasesFacility NameFacility Location20072008aPounds ofFluorideDischargedFluoride TWPEPercentage ofFertilizerManufacturingCategory’s 2007DMR FluorideTWPEPounds ofFluorideDischargedFluorideTWPEPercentage ofFertilizerManufacturingCategory’s 2008DMR FluorideTWPEMosaic Fertilizer, LLCUncle Sam, LA27,300,000957,00091%23,500,000705,00091%IMC Phosphates Co.St James, LA2,140,00075,9007%2,000,00059,9008%Mississippi Phosphates Corp.Pascagoula, MS665,00023,3002%452,00013,6001%Total30,200,0001,055,000100%25,900,000778,000100%Source:DMRLoads2007_v3andDMRLoads2008_v2.a – Major and minor dischargers.Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-10 6.4 .1 Top Facility Permit Compliance

Bo th of the top facilities in the Fertilizer Manufacturing Cate gory are phosphate fertilizer manufacturers. Phosphate ferti lizer manufacturers ar e subject to 40 CFR Part 418 Subpart A – Phosphate Subcategory. Subpart A BAT include s limits on flow-based surge capacity and pollutant discharge concentrations. The flow-based requirements are:

• 

### Ze ro discharge of wastewater except fr om the gypsum storage and disposal area;

• 

### Maintenance of a surge cap acity for a 10-year, 24-hour storm event (BPT) or a 25-year, 24-hour storm event (BAT) in the gypsum storage and disposal area;

• 

### If stored wastewater reaches 50 percent of the required surge capacity, the facility

is allowed to discharge treated wastewater;

• 

### If stored wastewater exceeds 50 percent of the required surge capacity, the facility

is required to treat and discharge wastewater; and

• 

### During discharge events, facilities ar e required to meet limitations for phosphorous, fluoride (25 mg/L monthly av erage and 75 mg/L daily maximum), total suspended solids, and pH (U.S. EPA, 1974).

Facilities minimize the volume of wa stewater discharged by impounding and recirculating all direct contact process wast ewater, including stormwat er runoff from active gypsum storage and disposal areas. This recirc ulation leads to an accumulation of fluoride, phosphorous, and radium in the wastewater w ith concentrations in excess of 8,500 mg/L fluoride, 5,000 mg/L phosphorous, and 60 pCi/L ra dium 226. Additionally, the wastewater is typically very acidic with a pH of between one and two. Several facilities report that they have not treated or discharged wastewater for several year s. For the 1974 rulemaking, EPA determined that most facilities would discharg e continuously between tw o and four months of the year due to excess wastewater in th e impoundment from rainfall (U.S. EPA, 1974).

The applicability of Subpart A excludes certain wet-process phosphoric acid processes from BPT, BAT, and BCT limitations that were under construction either on or before April 8, 1974, at plants located in the state of Louisiana. As a result, the Mosaic Fertilizers facility in Uncle Sam, LA and IMC Phosphates facility in St. James, LA are excluded from Subpart A. Permit writers limit discharges fr om these facilities using best professional judgment (BPJ) (see 52 FR 28428, July 29, 1987). Table 6-10 presents the outfall descriptions and the permit limits and findings for both facilities. Fo r some portion of the discharges from the Mosaic Fertilizers’ Uncle Sam and IMC Phosphates’ St. James fac ilities, BPJ permits incorporate Subpart A requirements.Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-11 Table 6-10. Outfalls and Permit Information for Top Fluoride Dischargers

Name Outfall with

Fluoride Discharges Fluoride Permit

Limits Permit Findings

Mosaic Fertilizers LLC – Uncle Sam,

LA 001: Once-through cooling water, scrubber water,

nonprocess wastewater, fertilizer

area stormwater, inactive gypsum storage area, and active gypsum
storage area L imits for outfall 001 excluding

inactive and active
gypsum storage area discharges:

1 65,000 lb/day monthly average

2 22,800 lb/day daily

maximum a • Ackn owledges exemption of flow requirements;

• Po rtion of gypsum storage and disposal are designated inactive;

• Stormwater from in active storage and disposal area discharged without treatment; Fundamentally Different Factor (FDF) granted to exempt facility from recycling process wastewater by installing fluoride scrubber;

• Gypsum storage area must meet BAT requirements;

• Optional discharge of treated wastewater below 50% surge capacity;

• Required discharge of treated wastewater

above 50% stor age capacity.

IMC Phosphates – St. James, LA 001 : Active gypsum
storage area, process
wastewater,
stormwater,

nonprocess wastewater, and noncontact cooling

water 25 mg /L monthly

average 7 5 mg/L daily

maximum • No acknowledgement of exemption of flow requirements;

• No discharge of process wastewater;

• Gypsum storage area must meet BAT requirements;

• Optional discharge of treated wastewater below 50% surge capacity;

• Required discharge of treated wastewater

above 50% stor age capacity. 002: Inactive
gypsum storage area Monitor and report fluoride discharges

Source: Facility Permits (LDEQ, 20 03; LDEQ, 2004a; and LDEQ, 2004b). a – Mass-based fluoride limitations are based on fluoride removal efficiency of the scrubber.



### 6.4.2 Mosaic Fertilizers, LLC in Uncle Sam, LA

Table 6-11 presents the monthly discharge data for Mosaic Fertilizers’ Uncle Sam facility, compared to the mass-based fluoride permit limit. Table 6-11 also includes a calculated monthly average concentration for the facility and the 40 CFR Pa rt 418 concentration-based limit (25 mg/L). EPA calculated the monthly average concentration using the average quantity and flow data in the DMR Loadings Tool.Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-12 Table 6-11. Mosaic Fertilizers 2008 Monthly Fl uoride Discharge Data and 40 CFR Part 418 Monthly Average Limitations

Outfall Monitoring

Period Date Average

Fluoride Quantity from

DMR data

(lb/day) Monthly Average

Fluoride Permit

Limit (lb/day) Calculated

Fluoride

Concentration (mg/L) a 40 CFR Part 418 Monthly Average

Fluoride Limit (mg/L) b

001 31-Jan-08 62,872 165,000 143 25

001 29-Feb-08 74,246 165,000 153 25

001 31-Mar-08 77,855 165,000 156 25

001 30-Apr-08 126,387 165,000 193 25

001 31-May-08 88,278 165,000 139 25

001 30-Jun-08 4,899 165,000 7.26 25

001 31-Jul-08 94,499 165,000 141 25

001 31-Aug-08 102,640 165,000 142 25

001 30-Sep-08 18,978 165,000 72.6 25

001 31-Oct-08 70,030 165,000 117 25

001 30-Nov-08 49,890 165,000 88.6 25

001 31-Dec-08 787 165,000 3.53 25

Source: DMR Loadings Tool and Facility Permit (LDEQ, 2003).

a– Concentration was calculated using the monthly quantity (lb/day) and flow (million gallons per day). b – The 40 CFR Part 418 Subpart A limit for fluoride discharges is 25 mg/L when the facilities are discharging.



### The 2008 DMR database includes over 23 millions pounds of fluoride discharged by Mosaic Fertilizers’ Uncle Sam facility. The facility permit has a maximum fluoride permit limit of 165,000 lb/day, set by permit writers using BPJ. The facility is not exceeding the mass-based permit limit; however, the limit is exceedingly high compared to the effluent guidelines that apply to other facilities in th e subcategory. Additionally, the fl uoride concentrations from this outfall range from 3.3 mg/L to 193 mg/L, the major ity of which are greate r than the treatable concentrations reported in the Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Basic Fert ilizer Chemicals Segment of the Fertilizer Manufacturing Point Source Category (1974 Development Document) (U.S. EPA, 1974).

6.4.3 IMC Phosphates in St. James, LA

Table 6-12 presents the 2008 fluoride discharges for IMC Phosphates’ two outfalls. From the facility permit, outfall 001 is the outfall for the active gypsum storage area, process
wastewater, stormwater, nonprocess wast ewater, and noncontact cooling water. Discharges from outfall 001 must meet the 40 CFR Part 418 Subpa rt A fluoride limits (LDEQ, 2004a; LDEQ, 2004b); IMC Phosphates met these limits in 2008. Outfall 002 is the outf all for the inactive gypsum storage area. The permit only requires reporting of fluoride discharges from outfall 002 (i.e., no numerical limit). EPA focused the addi tional review of IMC Phosphates’ fluoride discharges on outfall 002 because the discharges from this outfall contain the majority of the facility’s fluoride TWPE and it does not have the 40 CFR Part 418 Subpart A fluoride limit.Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-13 Table 6-12. IMC Phosphates 2008 Fluoride Discharges

Outfall Fluoride Permit Limits (mg/L) Average Fluoride Concentration (mg/L) Pounds of Fluoride Discharged (lb/yr) Fluoride TWPE

001 25 mg/L monthly average 75 mg/L daily maximum 2.13 49,700 1,490

002 Report only 382 1,950,000 58,400

Source: DMRLoads2008_v2 and Facility Permits (LDEQ, 2004a and LDEQ, 2004b).



### Table 6-13 presents the monthly discharge data for IMC Phosphates outfall 002, compared to the fluoride permit limit and the 40 CFR Part 418 Subpart A concentration-based fluoride limit (25 mg/L).

Table 6-13. IMC Phosphates Outfall 002 2008 Mo nthly Fluoride Discharge Data and 40 CFR Part 418 Monthly Average Limitations

Outfall Monitoring

Period Date Average Fluoride

Concentration (mg/L) 40 CFR Part 418 Monthly Average Fluoride Limit (mg/L) Facility Permit Monthly Average Fluoride Limit (mg/L)

002 31-Jan-08 523 25 Report Only (No Limit)

002 29-Feb-08 454 25 Report Only (No Limit)

002 31-Mar-08 555 25 Report Only (No Limit)

002 30-Apr-08 NA 25 Report Only (No Limit)

002 31-May-08 718 25 Report Only (No Limit)

002 30-Jun-08 365 25 Report Only (No Limit)

002 31-Jul-08 383 25 Report Only (No Limit)

002 31-Aug-08 360 25 Report Only (No Limit)

002 30-Sep-08 297 25 Report Only (No Limit)

002 31-Oct-08 449 25 Report Only (No Limit)

002 30-Nov-08 279 25 Report Only (No Limit)

002 31-Dec-08 234 25 Report Only (No Limit)

S ource: DMR Loadings Tool. NA – Not available. The DMR Loadings Tool does not have a fluoride concentration fo r IMC Phosphates for April

2008.



### The 2008 DMR database includes close to 2 millions pounds of fluoride discharged by IMC Phosphates for outfall 002. The facility perm it does not limit discharges of fluoride from outfall 002; however, the concentrations are exc eeding the effluent guidelines (25 mg/L) that apply to other outfalls at the facility and at ot her facilities within the subcategory. Additionally,

the fluoride concentrations from this outfall ra nge from 234 mg/L to 718 mg/L, all of which are greater than the treatable c oncentrations reported in the 1974 Development Document (U.S. EPA, 1974).

6 .5 Fertilizer Manufacturing Category Conclusions

The estimated toxicity of the Fertilizer Manuf acturing Category discharges results mainly from the fluoride discharges of two plants (accounting for 95 percent of the category’s 2008Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-14 DMR TWPE). Data collected for the 2010 annua l review demonstrated that wastewater discharge characteristics for this category are consistent with discha rges from prior years. As in prior years, EPA makes th e following conclusions:

• 

### The fluoride discharges we re verified in the 2008 DMR database for Mosaic Fertilizers’ Uncle Sam facility and IM C Phosphates’ St. James facility, both phosphate fertilizer manufactur ers in Louisiana. These f acilities are exempt from 40 CFR Part 418 Subpart A, and the permits are based on BPJ and include fluoride limits or reporting only requiremen ts. EPA concludes that these facilities do not represent the category as a whole because they are exempt from Part 418 (see 52 FR 28428, July 29, 1987). However, fluoride is discharged at

concentrations above the treatable concentrations reported in the 1974 Development Document (U.S. EPA, 1974).

• 

### The total 2008 TWPE excluding the fluoride discharges from Mosaic Fertilizers’ Uncle Sam and IMC Phosphates’ St. James facilities is 61,100 TWPE.

E PA prioritizes point source categories with existing regulations for potential revision based on the greatest estimated toxicity to human health and the environment, measured as TWPE. Based on the above conclusions, EPA is assi gning this category with a lower priority for revision (i.e., this category is marked with “(3)” in the “Findings” column in Table V-1 in the Federal Register notice that presents the 2010 annual review of existing ELGs).

6.6 Fertilizer Manufacturing Category References

1

. LDEQ. 2003. Louisiana Department of Envir onmental Quality. Office of Environmental Services Water Discharge Permit and F act Sheet NPDES LA0004847 – IMC PhosphatesCompany Uncle Sam Plant, Uncle Sam, LA. Baton Rouge, LA. (June 16). EPA-HQ-OW2004-0032-1773.

2

. LDEQ. 2004a. Louisiana Department of Envi ronmental Quality. Water Discharge Permit for NPDES LA0029769 – IMC Phosphates Compa ny, Faustina Plant, St. James, LA. Baton Rouge, LA. EPA-HQ-OW-2004-0032-1134.

3

. LDEQ. 2004b. Louisiana Department of Envi ronmental Quality. Water Discharge Permit Fact Sheet for NPDES LA0029769 – IMC Phosphates Company, Faustina Plant, St. James, LA. Baton Rouge, LA. EPA-HQ-OW-2004-0032-1134.

4

. U.S. Census. 2002. U.S. Economic Census. Available online at: http://www.census.gov/econ/census02.

5

. U.S. EPA. 1974. Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Basic Fertilizer Chemicals Segment of the Fertilizer Manufacturing Point Source Category . EPA-440/1-75/042-a. Washington, DC. (March).Section 6 – Fertilizer Manufacturing (40 CFR Part 418)



### 6-15 6. U.S. EPA. 2005. Preliminary 2005 Review of Prior itized Categories of Industrial Dischargers . EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-

0053.

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

Plan . EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-1 7. I NORGANIC 

### C HEMICALS 

### M ANUFACTURING 

### (40 CFR P ART 

### 415)

EPA id entified the Inorganic Chemicals Ma nufacturing (Inorganic Chemicals) Point Source Category (40 CFR Part 415) for preliminar y review because it continues to rank high, in terms of toxic-weighted pound e quivalent (TWPE), in point source category rankings (see Table

5-3 for the point source category rankings). This industry was reviewed previously in each of EPA’s Preliminary and Final Effluent Guidelin es Program Plans from 2004 to 2009, except for 2008 (U.S. EPA, 2004; U.S. EPA, 2005; U.S. EP A, 2006; U.S. EPA, 2007; U.S. EPA, 2009).

This section summarizes the resu lts of the 2010 annual review a ssociated with the Inorganic Chemicals Category. EPA focused on discharges of metals because of their high TWPE relative to the rest of the Inorganic Chemicals Category.

This section describes the results of EP A’s 2010 preliminary category review of the Inorganic Chemicals Category. EPA is currently reviewing discharges from the Chlor-Alkali Subcategory as part of the Chlorine and Chlo rinated Hydrocarbons (CCH) Effluent Limitations Guidelines and Standards (ELGs) rulemaking. Be cause a rulemaking for this segment of the Inorganic Chemicals Category is underway, EPA ex cluded discharges from these facilities from further consideration in this review (s ee Table V-1, 73 FR 53218, September 15, 2008).

7.1 Inorganic Chemicals Category Background

T his subsection provides background on the Inorganic Chemicals Category including a brief profile of the inorganic chemical s industry and background on 40 CFR Part 415.

7

.1.1 Inorganic Chemicals Industry Profile

The inorganic chemicals manufacturing indus try includes a broad class of facilities encompassing the manufacture of substances th at do not include carbon a nd its derivatives as their principal elements. EPA considered th e following seven North American Industry Classification System (NAICS) codes as part of the Inorganic Ch emicals Category:

• 

### 3 25120: Industrial Gases;

• 

### 3 25131: Inorganic Pigments;

• 

### 3 25181: Alkalies and Chlorine;

• 

### 325188: All Other Basic Inorgani c Chemical Manufacturing;

• 

### 325998INORG: All Other Miscellaneous Ch emical Product and Preparation;

• 

### 331311: Alumina Refining; and

• 

### 3 25510INORG: Paint and Coating Manufacturing.

Wa stewater generated by facilities in NAICS codes 325998 and 325510 may be regulated under multiple point source categories. For exam ple, most facilities in NAICS 325510 are grouped under Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category (40 CFR Part 414). EPA reviewed available informa tion about pollutant loads and manufacturing operations for facilities reporting these NAICS codes. In its crosswalk, EPA assigned the extension “INORG” to the end of the NAICS codes of facilities that most likely fall under the applicability of the Inorganic Chemicals Point Source Category (40 CFR Part 415).

Th is list of Standard Industrial Classificat ion (SIC) codes includes facilities that EPA determined are potential new subcategories to th e Inorganic Chemicals Ca tegory. As part of theSection 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-2 2004 annual review, EPA reviewed industries with SIC codes not clearly subject to existing ELGs. EPA concluded that the proc esses, operations, wastewaters, and pollutants of facilities in the following SIC codes are similar to those of the Inorganic Chemicals Category (U.S. EPA, 2004): 12

• 

### 2812: Alkalies and Chlorine;

• 

### 2813: Industrial Gases;

• 

### 2816: Inorganic Pigments; and

• 

### 2 819: Industrial Inorganic Chemicals.

As par t of the 2009 annual review, EPA reclassified these SIC codes as equivalent NAICS codes

for use with the U.S. Economic Census and T oxics Release Inventory (TRI) data that are reported by NAICS code. However, there is not a direct relationship between one SIC and one NAICS codes. As a result, EPA included the fo llowing NAICS codes in the 2010 annual review of the Inorganic Chemicals Category because they contain facilities w ith operations that are

similar to the SIC codes above:

• 

### 325120: Industrial Gases;

• 

### 325131: Inorganic Pigments;

• 

### 325181: Alkalies and Chlorine;

• 

### 325188: All Other Basic Inorgani c Chemical Manufacturing;

• 

### 331311: Alumina Refining; and

• 

### 325510INORG: Paint and Coating Manufacturing.

Because Permit Compliance System (PCS) and Integrated Compliance Information System – National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the sources of the discharg e monitoring report (DMR) data used to develop DMRLoads2008 , report facilities by SIC codes, and the U.S. Economic Census and TRI report data by NAICS code,

EPA reclassified the 2008 DMR data by the equivalent NAICS code. Table 7-1 lists the number

of facilities from the U.S. Economic Census a nd the screening-level databases for the seven NAICS codes with operations in the Inorganic Chemicals Category the corresponding SIC codes

are included for reference. The U.S. Economic Census includes more facilities than the screening-level databases because of many possi ble factors including not meeting TRI-reporting thresholds, discharging to a publicly owned tr eatment works (POTW), and because some of

those in the U.S. Economic Cens us are distributors or sales facilities, not manufacturers.

12 The tables in this section include discharge information from facilities reporting these SIC codes and the corresponding NAICS codes; however, these facilities contribute negligible amounts of TWPE. Consistent with the conclusions drawn during the 2004 detailed study (U.S. EPA, 2004) and 2006 review (U.S. EPA, 2006), EPA found that large numbers of these facilities discharge no wastew ater and only a small number of facilities discharge TWPE greater than zero.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-3 Table 7-1. Number of Inorganic Chem icals Manufacturing Facilities

NAICS Code Corresponding

SIC Code Number of Facilities

2002 U.S.

Economic

Census 2008 DMR

Database a 2008 TRI

Database b

325120: Industrial Gas Manufacturing

2813: Industrial

Gases 2816: Inorganic Pigments

2819: Industrial Inorganic Chemicals, NEC 572 440 70

325131: Inorganic Dye and Pigment Manufacturing 81 41

325188: All Other Basic Inorganic Chemical Manufacturing 631 276

325510INORG: Paint and Coating Manufacturing NA 2

325998INORG: All Other Miscellaneous Chemical Product and Preparation NA 12

331311: Alumina Refining 10 6

325181: Alkalies and Chlorine Manufacturing 2812: Alkalies

and Chlorine 41 12 6

Total >1,335 452 413

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads20008_v2 ; and TRIReleases2008_v3

. a – Includes both major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an NAICS to SIC crosswalk for comparison purposes. b – Releases to any media. NA – Not applicable. These facility-specific NAICS codes do not correspond to NAICS codes in the 2002 U.S.

Economic Census.

NEC – Not elsewhere classified.



### Table 7-2 shows whether permitting authorities desi gnated direct discharging facilities in the Inorganic Chemicals Category as mi nor or major dischargers (see Section 4.1.5 ). EPA included data for minor dischargers for the firs t time in the 2010 annual review, as part of
DMRLoads2008_v2 database. EPA does not require permitting authorities to submit DMR data for minor dischargers; however, many states do provide complete DMR data for minor dischargers. From the 2010 annual review, EPA ob served many data entry or other errors for minor dischargers in addition to those previously id entified for major discha rgers, as discussed in

Section 4.3

. Table 7-2 shows that approximately 86 percent of the Inorganic Chemicals Category dischargers in the 2008 DMR data base are minor dischargers.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-4 Table 7-2. Number of Inorganic Chemical Fa cilities by Facilities by Discharge

Classification in 2008 DMR Database

NAICS Code Number of Facilities in 2008 DMR Database

Major Dischargers Minor Dischargers All Dischargers

325120: Industrial Gas Manufacturing

60 380 440 325131: Inorganic Dye and Pigment Manufacturing

325188: All Other Basic Inorganic Chemical Manufacturing

325510INORG: Paint and Coating Manufacturing

325998INORG: All Other Miscellaneous Chemical Product and Preparation

331311: Alumina Refining

325181: Alkalis and Chlorine Manufacturing 0 12 12

Total 60 392 452

Source: DMRLoads2008_v2

.



### Table 7-3 presents the type of disc harges reported by facilitie s in the 2008 TRI database. The majority of inorganic chemicals facilities reporting to TRI do not re port water discharges, but those that do are almost evenly split between direct dischargers and indirect dischargers.

Table 7-3. Number of Inorganic Chemicals Fa cilities by Discharge Type in 2008 TRI

Database

NAICS Code Number of Facilities in TRI 2008 Database

Direct Dischargers Only Indirect Dischargers Only Both Indirect

and Direct No Water Discharges

325120: Industrial Gas Manufacturing 4 6 0 60

325131: Inorganic Dye and Pigment Manufacturing 14 9 4 14

325181: Alkalis and Chlorine Manufacturing 0 2 0 4

325188: All Other Basic Inorganic Chemical Manufacturing 40 44 24 168

325510INORG: Paint and Coating Manufacturing 1 0 1 0

325998INORG: All Other

Miscellaneous Chemical Product

and Preparation 2 8 0 2

331311: Alumina Refining 2 1 0 3

Total 63 70 29 2 51

S ource: TRIReleases2008_v3

.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-5 7.1.2 40 CFR Part 415

Wastewater discharges for th e inorganic chemicals manufact uring industry are regulated under 40 CFR Part 415: Inorganic Chemicals Manufacturing Point Source Category. This category consists of 67 subcategories define d by the type of inorganic chemical product

manufactured. In addition to best practicable control tec hnology (BPT), best available technology economically achievable (BAT), best conventional pollutant control technology (BCT), and new source performance standard s (NSPS), the category includes pretreatment standards for existing sources (PSES) and pret reatment standards fo r new sources (PSNS) limitations for at least one subcategory. Table 5-6 in the 2004 Effluent Guidelines Program Plan contains details on the pollutants regulated by each subpart (U.S. EPA, 2004). The effluent guidelines for the Inorganic Chemicals Category were first promulgated in 1974 and revised in 1975, 1976, 1982, and 1986.

7.2 Inorganic Chemicals Category Screening-Level Review

Table 7-4 compares the screening-level results for the Inorganic Chemicals Category from the 2006 through 2010 annual reviews that re presented multiple years of data from the

DMR and TRI databases. The combined DMR and TRI TWPE increased slightly from discharge years 2002 to 2004, but decreased from discharge year 2007 to 2008.

Table 7-4. Inorganic Chemicals Category TRI and DMR Discharges for the 2006 through 2010 Screening-Level Reviews

Year of Discharge Year of Review Inorganic Chemicals Category

TRI TWPE DMR TWPE a Total TWPE

2002 2006 186,000 107,000 293,000

2004 2007 123,000 316,000 439,000

2005 2008 92,100 NA NA

2007 2009 54,700 394,000 449,000

2008 2010 71,300 228,000 299,000

Source: TRIReleases2002_v4 ; PCSLoads2002_v4 ; TRIReleases2004_v3 ; PCSLoads2004_v3 ; TRIReleases2005_v2 ; TRIReleases2007_v2 ; DMRLoads2007_v4 ; TRIReleases2008_v3 ; and DMRLoads2008_v2

. a – DMR data from 2002 through 2007 only includes major dischargers. 2008 DMR data includes both minor and major dischargers. NA – Not applicable. EPA did not evaluate DMR data for 2005.



### Table 7-5 presents the 2008 DMR TWPE by f acility discharge classification. EPA excluded minor dischargers from previous annual reviews, but included them in the 2010 annual review. The majority (61 percent) of the TW PE in the 2008 DMR database is from major dischargers.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-6 Table 7-5. Inorganic Chemicals Category 2008 DMR TWPE by Discharge Classification

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers

2008 89,000 139,000

Source: DMRLoads2008_v2

. a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous

annual reviews.



### 7.3 Inorganic Chemicals Category Pollutants of Concern

Table 7-6 compares the five pollutants with th e highest TRI TWPE based on results from the 2010, 2009, and 2007 annual reviews ( TRIReleases2008_v3

, TRIReleases2007_v2 , and
TRIReleases2004_ v3 ). Table 7-7 lists the five pollutants with the highest TWPE based on results from the 2010, 2009, and 2007 annual reviews ( DMRLoads2008_v2, DMRLoads2007_v3 , and
PCSLoads2004_v4 ).Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)7-7Table 7-6. Inorganic Chemicals Category Top TRI PollutantsPollutant2004 TRI Dataa2007 TRI Dataa2008 TRI DataaRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPEManganese and ManganeseCompounds12967,40012214,60012638,200Mercury and Mercury Compounds3134,3903126,5002106,680Arsenic and Arsenic CompoundsPollutants not reported in the top five2004 TRI reported pollutants.435,480356,100Nitrate Compounds4483,9705413,5704495,340Polychlorinated biphenyls (PCBs)Pollutants not reported in the top five2004 TRI reported pollutants.Pollutants not reported in the top five2007 TRI reported pollutants.523,570Dioxin and Dioxin LikeCompounds2525,0002511,600Pollutants not reported in the top five2008 TRI reported pollutants.Hexachlorobenzene543,600Pollutants not reported in the top five2007 TRI reported pollutants.Inorganic Chemicals CategoryTotalNA191b123,000NA142b54,700NA161b71,300Source:TRIReleases2004_v3,TRIReleases2007_v2; andTRIReleases2008_v3.a – Discharges include transfers to POTWs and account for POTW removals.b – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)7-8Table 7-7. Inorganic Chemicals Category Top DMR PollutantsPollutant2004 DMR Dataa2007 DMR Dataa2008 DMR DatabRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPEAluminumPollutants not reported in the top fiveDMR 2004 reported pollutants.Pollutants not reported in the top fiveDMR 2007 reported pollutants.11755,900Mercury21446,500Copper52729,8005232,05034036,900Sulfide1287,900Pollutants not reported in the top fiveDMR 2007 reported pollutants.419,960SilverPollutants not reported in the top fiveDMR 2004 reported pollutants.559,000Polychlorinated biphenyls(PCBs)11363,000Pollutants not reported in the top fiveDMR 2008 reported pollutants.Chlorine31040,5002910,500FluoridePollutants not reported in the top fiveDMR 2004 reported pollutants.374,590Heptachlor412,140Iron4829,900Pollutants not reported in the top fiveDMR 2007 reported pollutants.Lead21452,400Inorganic Chemicals CategoryTotalNA58c316,000NA51c394,000NA139c228,000Source:PCSLoads2004_v4;DMRLoads2007_v3; andDMRLoads2008_v2.a – 2004 and 2007 DMR data only include major dischargers.b – 2008 DMR data includes major and minor dischargers.c – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-9 The Inorganic Chemicals Category TWPE in the 2008 TRI database is significantly lower than the 2008 DMR TWPE. Therefore, EPA focused the additional review on the DMR-reported pollutants that account for the ma jority of the category TWPE.

EPA’s additional review for the 2008 DMR databa se metals discharges is presented in the following sections. During the review of meta ls discharges, EPA discovered that the majority of the top pollutants were discharged by the sa me four facilities in the 2008 DMR database.

Table 7-8 presents the top pollutants discharged in the Inorganic Chemicals Category and the corresponding top facility discharger.

Table 7-8. Inorganic Chemicals Category To p Facility Dischargers in the 2008 DMR

Database

Top Pollutant Facility Name Pounds of

Pollutant Discharged Pollutant

TWPE Total Facility

TWPE Other Top

Pollutants Discharged

Aluminum UOP LLC 875,000 52,500 58,200 None a

Mercury AL State Docks – Mud

Lakes 221 25,900 28,400 Aluminum

Elementis Chromium LP

Castle 94.4 11,100 24,000 Silver

Copper Dow Chemical, Pittsburg Plant 48,100 30,300 33,900 N one a

S ource: DMRLoads2008_v2

. a – These facilities do not have discharges of other top five pollutants with significant discharges (TWPE great than 1,000).



### 7.4 Inorganic Chemicals Category Top Facility Dischargers in DMR

This subsection provides further detail on th e top four facility dischargers in the Inorganic Chemicals Category responsible for th e majority of the aluminum, mercury, copper,

and silver TWPE. As a result of EPA’s review of discharges from th e top facilities in the Inorganic Chemicals Category, the overall category 2008 DMR TWPE decreased by 121,900

TWPE.

7.4.1 UOP LLC in Chickasaw, AL

Table 7-9 presents the discharges in the 2008 DM R database for UOP LLC. The majority of the facility TWPE (approximately 90 percent) is from aluminum. Aluminum discharges from UOP LLC account for 23 percent of the DMR TWPE for the Inorganic Chemicals Category.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-10 Table 7-9. UOP LLC 2008 Top Discharges

Pollutant Total Pounds Total TWPE Percentage of Facility

Total TWPE

Aluminum 875,000 52,500 90.2%

Iron 783,000 4,380 7.5%

Zinc 20,000 800 1.4%

Chloride 9,230,000 225 0.4%

Nickel 1,590 159 0.3%

Total 191,000,000 58,200 100%

Source: DMRLoads2008_v2

.



### The majority of the aluminum discharges for UOP LLC are from outfalls 003 and 004. The facility’s permit indicates that outfalls 003 and 004 are “sto rm water runoff from nonprocess

areas associated with molecular sieve adsorben ts and catalysts manufacture.” The permit does include monitoring only requirements for al uminum for outfalls 003 and 004 (ADEM, 2002).

Table 7-10 presents the aluminum discharge data for outfalls 003 and 004 in the DMR Loadings Tool for 2008. EPA contacted UOP LLC to verify the aluminum concentrations and flows. UOP LLC verified the aluminum values and units, bu t indicated that the fl ows for outfall 003 and 004 had the wrong units (Frain, 2010). Table 7-10 also includes the facili ty-provided flows. Using the facility-provided flows for outfalls 003 and 004, UOP LLC’s aluminum discharges decrease by 46,200 TWPE, while the facil ity’s TWPE decreases from 58,200 TWPE to 7,110 TWPE.

Table 7-10. UOP LLC Outfalls 003 and 004 2008 Monthly Aluminum Discharge Data

Outfall Monitoring Period

Date Maximum

Concentration (mg/L) DMR Loadings Tool Flow (MGD) Facility-Provided Flow (MGD)

003 30-Jun-08 10 31.86 3.186

003 31-Dec-08 0.1 20.33 2.033

004 30-Jun-08 9 25.52 2.552

004 31-Dec-08 1.025 1 6.29 1.629
Source: DMR Loadings Tool and Facility Contact (Frain, 2010).



### 7.4.2 AL State Docks Mud Lakes in Mobile, AL

Table 7-11 presents the discharges in the 2008 DMR database for AL State Docks Mud Lakes. The majority of the facility TWPE (appr oximately 91 percent) is from mercury. Mercury discharges from AL State Docks Mud Lakes al so account for almost 11 percent of the DMR TWPE for the Inorganic Chemicals Category.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-11 Table 7-11. AL State Docks Mud Lakes 2008 Mercury and Aluminum Discharges

Pollutant Total Pounds Total TWPE Percentage of Facility

Total TWPE

Mercury 221 25,900 91.2%

Aluminum 41,600 2,500 8.8%

Total 9,470,000 28,400 100%

Source: DMRLoads2008_v2

.



### AL State Docks Mud Lakes is a dock that serves as a transfer station for bulk cargo that is exported and imported. The dock site was a form er aluminum ore tailing lakes operated by the Aluminum Company of America (ALCOA). These lakes are currently used to accumulate and treat aluminum ore tailings leachate prior to discharge to the Mobile River (ADEM, 2006). The facility contact indicated that it is not an industrial manufacturing site (Wright, 2010).

All of the mercury discharges for AL State Docks Mud Lakes are from outfall 001. Outfall 001 is stormwater and groundwater from the aluminum tailings leachate collection system (ADEM, 2006). Table 7-12 presents the mercury discharg e data for outfall 001 in the DMR Loadings Tool for 2008. EPA contacted AL State Docks Mud Lakes and the Alabama Department of Environmental Management (ADE M) to verify the mercury quantities. ADEM confirmed the mercury discharges (Brown, 2010).

EPA determined that the discharges from this facility do not meet the applicability of the Inorganic Chemicals Category. Because this facil ity’s discharges are from aluminum ore mining, EPA believes this facility’s discharges are appl icable to the Nonferrous Metals Manufacturing (40 CFR Part 421). However, because the facility no longer operates as an aluminum ore mine and processing facility, EPA believes the discharg es should be permitted using best professional judgment.

Table 7-12. AL State Docks Mud Lakes Ou tfall 001 2008 Monthly Mercury Discharge

Data

Outfall Monitoring Period Date Average Quantity (kg/day)

001 31-Mar-08 NR

001 30-Jun-08 0.000635

001 30-Sept-08 0.776

001 31-Dec-08 0 .313
Source: DMR Loadings Tool. NR – Not reported.



### 7.4.3 Elementis Chromium LP in Castle Hayne, NC

Table 7-13 presents the discharges in the 2008 DMR database for Elementis Chromium LP. The majority of the facility TWPE (approxima tely 79 percent) is from mercury and silver. Mercury and silver discharges from Elementis Ch romium LP also account for 8 percent of the DMR TWPE for the Inorganic Chemicals Category.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-12 Table 7-13. Elementis Chromium LP Plant 2008 Top Discharges

Pollutant Total Pounds Total TWPE Percentage of Facility

Total TWPE

Mercury 94.4 11,100 46.3%

Silver 471 7,760 32.3%

Selenium 2,360 2,640 11.0%

Lead 942 2,110 8.8%

Chloride 7,980,000 194 0.8%

Total 8,010,000 24,000 100%

Source: DMRLoads2008_v2

.



### All of the mercury discharges for Elementis Chromium LP are from outfall 001. Table

7-14 presents the mercury discharge data for outfall 001 in the DMR Loadings Tool for 2008. EPA contacted Elementis Chromium LP to verify the mercury and silver concentrations and

flows. Elementis Chromium LP verified the flow s, but indicated that the mercury and silver concentrations were incorrect. The facility cont act also indicated that mercury and silver are reported quarterly rather than monthly (Coury, 2010). Table 7-14 also includes the facilityprovided concentrations. Using th e facility-provided concentrati ons, Elementis Chromium LP’s mercury discharges decrease by 18,800 TWPE, while the facility’s TWPE decreases from 24,000 TWPE to 5,190 TWPE.

Table 7-14. Elementis Chromium LP Ou tfall 001 2008 Monthly Mercury and Silver Discharge Data

Outfall Monitoring

Period Date NODI Code a Average

Concentration (mg/L) FacilityProvided

Concentration (mg/L) Average Flow (MGD)

Mercury

001 31-Jan-08 8 NR 0.659129

001 29-Feb-08 0.0003 0.0003 0.668433

001 31-Mar-08 8 NR 0.6071

001 30-Apr-08 8 NR 0.614742

001 31-May-08 0.2 0.0002 0.707

001 30-Jun-08 8 NR 0.589548

001 31-Jul-08 8 NR 0.582452

001 31-Aug-08 0 <0.0002 0.58029

001 30-Sept-08 8 NR 0.595933

001 31-Oct-08 8 NR 0.557667

001 30-Nov-08 0 <0.0002 0.606935

001 31-Dec-08 8 NR 0.691677Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-13 Table 7-14. Elementis Chromium LP Ou tfall 001 2008 Monthly Mercury and Silver Discharge Data

Outfall Monitoring

Period Date NODI Code a Average

Concentration (mg/L) FacilityProvided

Concentration (mg/L) Average Flow (MGD)

Silver

001 31-Jan-08 8 NR 0.659129

001 29-Feb-08 0 <0.001 0.668433

001 31-Mar-08 8 NR 0.6071

001 30-Apr-08 8 NR 0.614742

001 31-May-08 1 <0.001 0.707

001 30-Jun-08 8 NR 0.589548

001 31-Jul-08 8 NR 0.582452

001 31-Aug-08 0 <0.001 0.58029

001 30-Sept-08 8 NR 0.595933

001 31-Oct-08 8 NR 0.557667

001 30-Nov-08 0 <0.005 0.606935

001 31-Dec-08 8 NR 0.691677
Source: DMR Loadings Tool and Facility Contact (Coury, 2010). a – NODI Code 8 is a reporting code for “Other.” NR – Not reported. The facility contact indicated that me rcury and silver were reported quarterly rather than monthly.



### 7.4.4 Dow Chemical Pittsburg Plant in Pittsburg, OH

Table 7-15 presents the discharges in the 2008 DMR database for Dow Chemical Pittsburg Plant. The majority of the facility TWPE (approximately 89 percent) is from copper. Copper discharges from Dow Chemical Pittsbu rg Plant account for 13 percent of the DMR TWPE for the Inorganic Chemicals Category.

Table 7-15. Dow Chemical Pitts burg Plant 2008 Top Discharges

Pollutant Total Pounds Total TWPE Percentage of Facility

Total TWPE

Copper 48,100 30,300 89.3%

Nickel 28,100 2,810 8.3%

Mercury 7.11 833 2.4%

Total 2,060,000 33,900 100%

Source: DMRLoads2008_v2

.



### The majority of the copper discharges for Do w Chemical Pittsburg Plant are from outfalls 001, 004, 005, and 006. Table 7-16 presents the copper discharge data for outfalls 001, 004, 005, and 006 in the DMR Loadings Tool for 2008. The f acility’s copper discharges are in the DMR Loadings Tool as a quantity (i.e., as kilogram per day (kg/day)). EPA also calculated the monthly average quantity discharge using the average concentration and flow data in the 2008 DMRSection 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-14 Loadings Tool. EPA determined that the reporte d quantities in the DMR Loadings Tool were incorrect. The discharge quantities calculated using the flow and concentrations are at least 3 orders of magnitude less. Table 7-16 also presents the calculated monitoring period quantities.

Table 7-17 presents the revised estimated pounds a nd TWPE for copper from the Dow Chemical Pittsburg Plant. Using the calculated quantitie s, Dow Chemical Pittsburg Plant’s copper discharges decrease by 23,600 TW PE, while the facility’s TWPE decreases from 33,900 TWPE to 10,300 TWPE.

Table 7-16. Dow Chemical Pittsburg Pl ant 2008 Monthly Copper Discharge Data

Outfall Monitoring

Period Date NODI

Code a Average Quantity (kg/day) Average

Concentration (mg/L) Average Flow (MGD) Calculated Quantity (kg/day)

001 31-Jan-08 6.4 0.0064 0.09 0.0021

001 29-Feb-08 2.9 0.0029 0.14 0.0015

001 31-Mar-08 6.1 0.0061 0.2 0.0046

001 30-Apr-08 2.4 0.0024 1.51 0.0137

001 31-May-08 8.7 0.0087 0.18 0.0059

001 30-Jun-08 5.4 0.0054 0.18 0.0036

004 31-Jan-08 15 0.015 2.92 0.1655

004 29-Feb-08 11 0.011 0.36 0.0151

004 31-Mar-08 C

004 30-Apr-08 C

004 31-May-08 C

004 30-Jun-08 C

005 30-Jun-08 7.6 0.0076 97.2 2.79

006 30-Jun-08 43 0.043 64.3 10.46
Source: DMR Loadings Tool. a – NODI Code C means no discharge occurred for that monitoring period.



### Table 7-17. Dow Chemical Pittsbur g Plant’s 2008 Copper Discharges

Outfall Old Copper

Total Pounds Old Copper

TWPE Revised Copper

Total Pounds Revised Copper

TWPE Reduction in

TWPE

001 4,290 2,700 4.21 2.7 2,700

004 3,400 2,150 24.5 15.4 2,130

005 6,070 3,820 2,230 1,410 2,420

006 34,300 21,600 8,350 5,260 16,400

Total 48,000 30,300 1 0,600 6,690 2 3,600

S ource: DMRLoads2008_v2 and Inorganic Chemicals Category (40 CFR Part 415) Facility Review Calculations (ERG, 2010).Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-15 7.5 Inorganic Chemicals Category Conclusions

T he estimated toxicity of the Inorganic Chem icals Category discha rges resulted from discharges of metals. Data collected for the 2010 annual review demonstrated that wastewater discharge characteristics for this category are consistent with discha rges from prior years. As in prior years, EPA makes th e following conclusions:

• 

### There were flow units errors for discharges from the UOP LLC facility in Chickasaw, AL. These discharges account ed for the majority of the Inorganic Chemicals Category aluminum TWPE in the 2008 DMR database. Correcting the

flow units decreases the 2008 facility TWPE by 51,100 TWPE.

• 

### AL State Docks Mud Lakes facility in M obile, AL was incorrectly classified in the Inorganic Chemicals Category. This f acility should be classified in the Nonferrous Metals Manufacturing Cate gory (40 CFR Part 421). Excluding this facility from the Inorganic Chemical s Category decreases the category’s 2008 TWPE by 28,400 TWPE. EPA also determined that best professional judgment (BPJ) permitting was most appropriate for this facility’s discharges.

• 

### The mercury and silver concentrations fo r Elementis Chromium LP’s facility in Castle Hayne, NC had unit errors an d were missing below detection limit indicators. Correcting the concentrati ons decreases the 2008 facility TWPE by 18,800 TWPE.

• 

### The r eported copper quantities for Dow Chem ical Pittsburg Plant’s facility in Pittsburg, CA were significantly higher than the quantities calculated using the reported concentrations and flows in 2008 DMR Loadings Tool. Using the calculated quantities decreases the 2008 facility TWPE by 23,600 TWPE.

• 

### Correcting the database errors identifi ed during the 2010 annual review decreases the 2008 Inorganic Chemicals Categor y TWPE from 299,000 TWPE to 177,000 TWPE. The Inorganic Chemicals Category continues to rank high because a high number of facilities (approximately 450) in the industry have data in the screening-level databases. 13 

### EPA will continue to monitor the Inorganic Chemicals Category discharges to determ ine if they are properly controlled.

EPA prioritizes point source categories with existing regulations for potential revision based on the greatest estimated toxicity to human health and the environment, measured as TWPE. Based on the above conclusions, EPA is assi gning this category with a lower priority for revision (i.e., this category is marked with “(3)” in the “Findings” column in Table V-1 in the Federal Register notice that presents the 2010 annual review of existing ELGs).

13 For the Inorganic Chemicals Manu facturing Point Source Category, TRIReleases2008 contains data from 413 facilities, and DMRLoads2008 contains data from 452 facilities.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-16 7.6 Inorganic Chemicals Category References

1. ADEM. 2002. Alabama Department of Envir onmental Management. National Pollutant Discharge Elimination System Permit NPDES – AL0002666 – for UOP LLC Mobile Plant. Montgomery, AL. (Decembe r 23). EPA-HQ-OW-2008-0517 DCN 07271.

2. ADEM. 2006. Alabama Department of Envir onmental Management. National Pollutant Discharge Elimination System Permit NP DES – AL0002976 – for Alabama State Port Authority Mud Lakes. Mobile, AL. (O ctober 24). EPA-HQ-OW -2008-0517 DCN 07272.

3. Brown, Donald. 2010. Telephone and E-mail communication with Donald Brown, Alabama Department of Environmental Ma nagement, and Elizabeth Sabol, Eastern Research Group, Inc. “Re: Mercury Discharg es Reported to DMR in 2008 for AL State Docks – Mud Lakes.” (August 31) . EPA-HQ-OW-2008-0517 DCN 07306.

4. Coury, Sean. 2010. Telephone conversation with Sean Coury, Elementis Chromium, and Elizabeth Sabol, Eastern Research Group, Inc. “Re: Mercury and Silver Discharges Reported to DMR in 2008.” (June 29). EPA-HQ-OW-2008-0517 DCN 07273.

5. ERG. 2010. Eastern Research Group, Inc. Inor ganic Chemicals Category (40 CFR Part 415) Facility Review Calculations. (July 2). EPA-HQ-OW-2008-0517 DCN 07274.

6. Frain, Rick. 2010. Telephone conversation wi th Rick Frain, UOP LLC and Elizabeth Sabol, Eastern Research Group, Inc. “Re: Aluminum Discharges Reported to DMR in 2008.” (June 29). EPA- HQ-OW-2008-0517 DCN 07275.

7. U.S. Census. 2002. U.S. Economic Census. Available online at: http://www.census.gov/econ/census02.

8. U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program

Plan . EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346 through 1352.

9. U.S. EPA. 2005. Preliminary 2005 Review of Prior itized Categories of Industrial Dischargers . EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-

0016.

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

Plan . EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.

11. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent Guidelines Program Plan . EPA-821-R-07-007. Washingt on, DC. (October). EPA-HQOW-2006-0771-0819.

12

. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent Guidelines Program Plan . EPA-821-R-09-006. Washingt on, DC. (October). EPA-HQOW-2008-0517-0515.Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415)



### 7-17 13

. Wright, Cliff. 2010. Telephone and E-mail comm unication with Cliff Wright, AL State Docks – Mud Lakes and Elizabeth Sabol, Ea stern Research Group, Inc. “Re: Mercury Discharges Reported to DMR in 2008.” (June 29). EPA-HQ-OW-2008-0517 DCN

07276.Section 8 – Landfills (40 CFR Part 445)



### 8-1 8. L ANDFILLS 

### (40 CFR P ART 

### 445)

EP A selected the Landfills Category (40 CFR Part 445) for preliminary review because it ranks high, in terms of toxic-weighted pound e quivalent (TWPE), in point source category rankings (see Table 5-3 for the point source category rankings). EPA has not previously reviewed the Landfills Category. This section su mmarizes the results of the 2010 annual review associated with the Landfills Category. EPA focused on metal discharges, because of their high TWPE compared to other pollutants in the category.

8. 1 Landfills Category Background

Th is subsection provides background on the Land fills Category including a brief profile of the landfills industry a nd background on 40 CFR Part 445.

8. 1.1 Landfills Industry Profile

The landfills industry includes facilities th at are operate waste (hazardous and nonhazardous) treatment or disposal facilities or pe rform the collecting and/or hauling of waste materials within a local area, combined with the operation of waste treatment or disposal

facilities. The landfills can either be commerci al or municipal. EPA considered the following four North American Industry Classification System (NAICS) codes as part of the Landfills Category:

• 

### 562211: Hazardous Waste Treatment and Disposal;

• 

### 562212: Solid Waste Landfill;

• 

### 562219: Other Nonhazardous Waste Tr eatment and Disposal; and

• 

### LNDFLL: Landfills.

Wastewater generated by facilities in the NAICS codes 562211, 562212, and 562219 may be regulated under the Landfills Category, Cent ralized Waste Treatment (CWT) Category (40 CFR Part 437), and the Waste Co mbustor Category (40 CFR Part 444). EPA reviewed available information about pollutant loads and operations for facilities reporting these NAICS codes. EPA was able to assign the “LNDFLL” NAICS code fo r facilities that most likely fall under the applicability of Part 445, Landfills Effluent Li mitation Guidelines and Standards (ELGs). EPA

was not able to determine which point source category applied to the other facilities in NAICS codes 562211, 562212, and 562219. The discharges from these facilities that were not assigned

the “LNDFLL” NAICS code are counted in all three point source ca tegories in the 2008 discharge monitoring report (D MR) and Toxics Release In ventory (TRI) databases.

Because Permit Compliance System (PCS) and Integrated Compliance Information System – National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the sources of the DMR data used to develop DMRLoads2008 , report facilities by Standard

Industrial Classification (SIC) codes, and the U.S. Economic Census and TRI report data by NAICS code, EPA reclassified the 2008 DM R data by the equivalent NAICS code. Table 8-1

lists the number of facilities from the U.S. Ec onomic Census and the screening-level databases for the seven NAICS codes with operations in the Inorganic Chemicals Category the corresponding SIC codes are included for referen ce. The U.S. Economic Census includes more facilities than the screening-level databases be cause of many possible factors including not meeting TRI-reporting thresholds, discharging to a publicly owned treatment works (POTW),Section 8 – Landfills (40 CFR Part 445)



### 8-2 and because some of those in the U.S. Economic Census are distributors or sales facilities, not

manufacturers.

Table 8-1. Number of Landfills

NAICS Code Corresponding

SIC Code Number of Facilities

2002 U.S.

Economic Census 2008 DMR

Database a 2008 TRI

Database b

562211: Hazardous Waste Treatment and Disposal 4953: Refuse Systems;

4953L: Refuse Systems (Landfills) 701 1,295 53

562212: Solid Waste Landfill 1,507 1

562219: Other Nonhazardous Waste Treatment and Disposal 199 5

LNDFLL: Landfills NA 8

Total >2,407 1,295 67

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2 ; and TRIReleases2008_v3

.a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore EPA used an NAICS-to-SICcode crosswalk for comparison purposes. b – Releases to any media. NA – Not applicable.



### Table 8-2 shows whether permitting authorities designated direct discharges as minor or major (see Section 4.1.5 ) for facilities in the Landfills Category. EPA included data for minor discharges for the first time in the 2010 annual review, as part of DMRLoads2008_v2 database. EPA does not require permitting authorities to submit DMR data for minor dischargers; however, many states do provide complete DMR data for th em. From this year’s review, EPA observed many data entry or other errors for minor discha rgers in addition to those previously identified for major dischargers, as discussed in Section 4.3

. Table 6-2 shows that approximately 99 percent of the Landfills Category dischargers in the 2008 DMR database are minor dischargers.

Table 8-2. Number of Landfills by Discharg e Classification in 2008 DMR Database

NAICS Code a Number of Facilities in 2008 DMR Database

Major Dischargers Minor Dischargers All Dischargers

562211: Hazardous Waste Treatment and Disposal 11 1,284 1,295

562212: Solid Waste Landfill

562219: Other Nonhazardous Waste Treatment and Disposal

LNDFLL: Landfills

Total 11 1,284 1,295

Source: DMRLoads2008_v2

. a – DMR data is reported by SIC code; therefore EPA used an NAICS to SIC crosswalk for comparison purposes.



### Table 8-3 presents the number of landfills included in the DMR databases and whether discharge data (e.g., pollutant con centrations, flow rates, etc.) we re included for reporting years 2004, 2007, and 2008. The table shows a large increase in the number of landfills with dischargeSection 8 – Landfills (40 CFR Part 445)



### 8-3 data from 2004 and 2007 to 2008 in the DMR databa se, due to the addition of minors. However, there are still almost 70 percent of landfills w ithout discharge data in the 2008 DMR database.

Table 8-3. Number of Landfills in the DMR Database for Reporting Years 2004, 2007,

and 2008

Discharge Status 2004 a 2007 a 2008 a With Water Discharge Data b 18 8 383 Without Water Discharge

Data c 287 1,070 912

Total 305 1,078 1,295

Source: PCSLoads2004_v3; DMRLoads2007_v4 ; and DMRLoads2008_v2

. a – Major and minor dischargers.

b – Includes facilities with DMR data in the DMR databases. c – Includes facilities with NPDES permits without DMR data in the DMR databases.



### Table 8-4 presents the type of disc harges reported by facilitie s in the 2008 TRI database. The majority of landfills reporting to TRI do not report water discharges. However, there is an

even distribution of direct and indirect discha rgers for those that do re port water discharges.

Table 8-4. Number of Landfills by Discharge Type in 2008 TRI Database

NAICS Code Number of Facilities in 2008 TRI Database

Direct Dischargers Only Indirect Dischargers Only Both Indirect

and Direct Dischargers No Water Discharges

562211: Hazardous Waste Treatment and Disposal 4 4 1 44

562212: Solid Waste Landfill 0 0 1 0

562219: Other Nonhazardous Waste Treatment and Disposal 2 0 0 3

LNDFLL: Landfills 1 3 2 2

Total 7 7 4 49

So urce: TRIReleases2008_v3

.



### 8.1 .2 40 CFR Part 445

EPA promulgated ELGs for the Landfills Category (40 CFR Part 445) on January 19, 2000 (65 FRN 3007). The Landfills ELGs are applicable to wastewater discharges to surface

water 14 

### from landfill units, excluding wastewater discharges from the following units:

• 

### La nd application or land treatment units;

• 

### S urface impoundments;

• 

### Un derground injection wells;

• 

### Wast e piles;

• 

### Salt dome formations;

14 40 CFR Part 445 does not set limits for disc harges to POTWs (i.e., indirect dischargers).Section 8 – Landfills (40 CFR Part 445)



### 8-4 • 

### Salt bed formations;

• 

### Underground mines/caves;

• 

### Wastewater generated offsite;

• 

### Discharges of contaminated ground water or wastewater from recovery pumping wells;

• 

### Landfills operated in conjunction with othe r industrial or commercial operations when the landfill receives facility generated wastes; and

• 

### Landfills in conjunction CWTs.

There are two subcategories in the Landfills Category: Resource Conservation and Recovery Act (RCRA) Subtitle C Hazardous Waste (Subpart A) and RCRA Subtitle D Nonhazardous Waste (Subpart B). RCRA Subtitle C Hazardous Waste landfills are authorized by RCRA to accept hazardous waste (see 40 CFR Part 421) . These landfills are required to maintain a leachate collection and removal system during th e active and postclosure period of the landfill (U.S. EPA, 2000). RCRA Subtitle D NonHazardous Waste landfills can receive municipal refuse, ash, sludge, construction and demolition de bris, and nonhazardous industrial waste. Prior to 1980 when RCRA was enacted, the older Subtitle D landfills may have received waste that was later classified as hazardous (U.S. EPA, 2000). Table 8-5 presents the regulated pollutants and limits for direct dischargers in the tw o subparts. For RCRA Subtitle C hazardous waste landfills, EPA developed the limits based on a treatment system consisting of equalization, chemical precipitation, biological treatment, a nd multimedia filtration. For RCRA Subtitle D nonhazardous waste landfills, EPA developed the limits based on a treatment system consisting of equalization, biological treatment, a nd multimedia filtration (U.S. EPA, 2000).

Table 8-5. Regulated Pollutants and Limits fo r the Landfills Category (40 CFR Part 445)

Regulated

Pollutant RCRA Subtitle C Hazardous Waste Landfill BAT (Subpart A) RCRA Subtitle D Nonhazardous Waste Landfill BAT (Subpart B)

Daily Maximum (mg/L) Monthly Average (mg/L) Daily Maximum (mg/L) Monthly Average (mg/L)

BOD 5 220 56 140 37

TSS 88 27 88 27

Ammonia (as N) 10 4.9 10 4.9

α -Terpineol 0.042 0.019 0.033 0.016

Aniline 0.024 0.015 NA NA

Benzoic acid 0.119 0.073 0.12 0.071

Naphthalene 0.059 0.022 NA NA

p -Cresol 0.024 0.015 0.025 0.014

Phenol 0.048 0.029 0.026 0.015

Pyridine 0.072 0.025 NA NA

Arsenic 1.1 0.54 NA NA

Chromium 1.1 0.46 NA NA

Zinc 0.535 0.296 0.2 0.11

pH W ithin the range 6 to 9 Within the range 6 to 9

Source: 40 CFR Part 445. NA – Not applicable. Subpart B – RCRA Subtitle D No nhazardous Waste Landfill does not regulate these pollutants.Section 8 – Landfills (40 CFR Part 445)



### 8-5 8.2 Landfills Category 2010 Screening-Level Review

Table 8-6 compares the screening-level results for the Landfills Category from the 2009 and 2010 annual reviews that represented the 2007 and 2008 DMR and TRI databases, respectively. The combined DMR and TRI TWPE increased from discharge years 2007 to 2008. The 2008 DMR TWPE accounts for approximately 99 percent of the total 2008 category TWPE, similar to the previous year.

Table 8-6. Landfills Category TRI and DMR Discharges for the 2009 and 2010 ScreeningLevel Reviews

Year of Discharge Year of Review Landfills Category

TRI TWPE b DMR TWPE a Total TWPE

2007 2009 83 15,300 15,400

2008 2010 781 191,000 192,000

Source: TRIReleases2008_v3 and DMRLoads2008_v2

. Note: EPA did not previously review th e Landfills Category; therefore, the 2007 discharge data is only shown for comparison to 2008. a – DMR data from 2007 include only major dischargers. DMR 2008 data include both minor and major dischargers. b – Discharges include transfers to POTWs and account for POTW removals.



### Table 8-7 presents the 2008 DMR TWPE by f acility discharge classification. EPA excluded minor dischargers from previous annual reviews, but included them in the 2010 annual review. The majority (99 percent) of the TW PE in the 2008 DMR database results from minor dischargers.

Table 8-7. Landfills Category 2008 DMR TW PE by Discharge Classification

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers

2008 190,000 1 ,260

Source: DMRLoads2008_v2

. a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous

annual reviews.



### 8.3 Landfills Pollutants of Concern

Table 8-8 lists the five pollutants with the highest TWPE in TRIReleases2008_v3 , while

Table 8-9 lists the five pollutants with the highest TWPE in DMRLoads2008_v2

.Section 8 – Landfills (40 CFR Part 445)



### 8-6 Table 8-8. Landfills Category Top TRI Pollutants in 2008 a

Pollutant Rank Number of Facilities Reporting Pollutant TWPE

Copper and Copper Compounds 1 5 127

Tetrachloroethylene 2 3 55

Arsenic and Arsenic Compounds 3 1 37

Lead and Lead Compounds 4 4 36

Cadmium and Cadmium Compounds 5 2 14

Landfills Category Total NA 18 b 781

Source: TRIReleases2008_v3

. a – Discharges include transfers to POTWs and account for POTW removals. b – Number of facilities reporting TWPE greater than zero.



### Table 8-9. Landfills Category Top DMR Pollutants in 2008 a

Pollutant Rank Number of Facilities Reporting Pollutant TWPE

Vanadium 1 11 45,400

Iron 2 146 31,300

Manganese 3 55 15,700

Arsenic 4 47 15,100

Calcium 5 18 10,900

Landfills Category Total NA 232 b 191,000

Source: DMRLoads2008_v2

. a – 20 08 DMR data includes major and minor dischargers. b – Number of facilities reporting TWPE greater than zero.



### The Landfills Category TWPE in the 2008 TRI da tabase is significantly lower than the 2008 DMR TWPE. Therefore, EPA focused the a dditional review of the Landfills Category on the DMR-reported pollu tants that account for the ma jority of the category TWPE.

The top four DMR-reported pollutants in 2008 are metals. Of the top four metals, the Landfill ELG regulates only arsenic from hazardous waste landfills (Subpart A). The remaining top metals are not regulated by the Landfill ELG. EP A’s additional review of the top metals is presented in the following section.

8.4 Landfills Category Facility-Specific DMR Review

During the 2010 annual review of the Landf ills Category, EPA identified several data entry or conversion errors in the underlying DMR data used to develop the 2008 DMR database. These errors inaccurately increased the top polluta nts TWPE. All of the errors identified during the facility review were for mi nor dischargers, which compose the majority of facilities reporting discharges in the Landfills Category. Table 8-10 presents the data entry errors identified by EPA along with the corrected facility TWPE. EPA also identified one facility, American Electric Power in Ohio, that was incorrectly categorized in the Landfills Category. EPA determined that this facility only receives waste from Ameri can Electric Power’s flue gas desulfurization, gypsum, fly and bottom ash, and purge stream solid s (Ohio EPA, 2009). Therefore, this facilitySection 8 – Landfills (40 CFR Part 445)



### 8-7 should be included in Steam Electric Power Gene rating Category (40 CFR Pa rt 423) rather than Part 445 because Part 445 excludes “landfills ope rated in conjunction with other industrial or commercial operations when the landfill only re ceives waste generated by the industrial or commercial operation directly associated w ith the landfill” (see 40 CFR Part 445.1(e)).

Table 8-11 presents the revised top pollutant TWPE using the corrected data. Note: these

corrections are not included in DMRLoads2008_v2 . EPA will incorporate these corrections into

future versions of the 2008 DMR database.Section 8 – Landfills (40 CFR Part 445)8-8Table 8-10. Data Errors Identified in the Landfills Category in 2008 DMR DatabaseFacility NameFacilityLocationMajor orMinorFacilityPollutants withIdentifiedErrorsOriginalPollutantTWPEOriginal FacilityTotal TWPEError(s) IdentifiedCorrectedFacilityTWPEPercentReductionof FacilityTWPESpringfieldSanitaryLandfillWillard,MOMinorVanadium45,10046,600Facility contact confirmed vanadiumconcentrations were all reported in μg/l,not mg/L. Facility contact alsoconfirmed six discharges that weremissing the nondetect indicator(i.e. “<”). (Gatlin, 2010)1,56097%AdvantageMetalsRecyclingKansasCity, MOMinorAlla20,30020,300Facility contact confirmed a data entryerror (i.e., incorrectvalue and decimallocation) for the cadmium concentrationfor September 2008. Facility contact alsoidentified data entry errors (i.e., incorrectdecimal location) for all the flows foroutfalls 001and 003. (Palmer, 2010)24099%Onyx MapleHill LandfillMacon, MOMinorMagnesium,Manganese,Fluoride20,100b20,300Facility contact confirmed magnesium,manganese, and fluoride concentrationswere all reported in μg/L, not mg/L, foroutfalls 001 and 004. (Tipton, 2010)17599%AshtabulaRiverOHMinorArsenic13,10016,700Review of on-line Envirofacts15confirmed incorrectvalues for arsenicquantities.3,66078%Sources: Facility contacts (Gatlin, 2010; Palmer, 2010; and Tipton, 2010).a – EPA identified a flow-unit error that affectedall pollutants for outfalls 001, 002, and 003.b – Pollutant TWPE is the sum of magnesium, manganese, and fluoride TWPE for outfalls 001 and 004.15EPA uses the data in Envirofacts as a source while reviewing the DMR Loadings Tool data because Envirofacts continually accepts and updates correctionssubmitted by facilities and states. The DMR Loadings Tool is not continuously updated; therefore, loads may be estimated with erroneous data.Section 8 – Landfills (40 CFR Part 445)



### 8-9 Table 8-11. Corrected TWPE for Top Pollutants in the Landfills Category in 2008 DMR

Database

Pollutant 2008 DMR TWPE Corrected 2008 DMR TWPE

Vanadium 45,400 300

Iron 31,300 29,900
Manganese 15,700 4,240

Arsenic 15,100 2,060

Calcium 10,900 100 a

L andfills Category Total 191,000 97,000 a – The majority, approximately 99 percent, of the calcium discharges in the Landfills Category was from American Electric Power Landfills, which EPA determined was incorr ectly classified as the Landfills Category (Ohio EPA, 2010).



### After the errors identified in Table 8-10 were corrected, EPA determined that vanadium, manganese, arsenic, and calcium were no longer pollutants of concern. Therefore, EPA did not include these pollutants in any further review of the Landfills Category. EPA identified that iron is consistently reported as discharged and is a top pollutant that is not regulated by the Landfill ELGs. EPA’s review of iron is pres ented in the following subsection.

8.5 Landfills Category Iron Discharges in DMR

As part of the 2010 annual review of the Landfills Category, EPA reviewed iron discharges in the 2008 DMR database. Iron is not regulated by the Landfill ELGs. The Development Document for Final Effluent Limitations Guidelines and Standards for the Landfills Point Source Category (January 2000) indicates that “E PA excluded pollutants that are naturally occurring compounds in so il or ground water at landfill facilities or pollutants that are used as treatment chemicals in this industry...” This included iron, along with other pollutants (U.S. EPA, 2000).

EPA compared the iron concentrations from la ndfill discharges to treatable levels typical of chemical precipitation and biolog ical treatment. In order to co mpare the iron concentrations to treatment level, EPA determined that th ere were 3,404 iron concentrations in 2008 DMR Loadings Tool for facilities in the Landfills Category. EPA removed 0 mg/L concentrations and concentrations reported below th e detection limit (BDL) for all reporting periods, resulting in 1,286 iron concentrations for the analysis. Because facilities report multiple concentrations for each monitoring period, EPA prioritized the selecti on of the average concentration and then the maximum (ERG, 2010).

Then, EPA compared the iron concentrati ons to the EPA Method 200.7 method detection limit (MDL) for iron to determine if the concentra tions were at detectab le levels. EPA excluded the 58 iron concentrations (approximately 2 percen t) that were below MDL. EPA calculated the resulting median, average, and maximum of th e remaining iron concentrations. EPA analyzed the median concentration rather than the average or maximum because of suspected data entry errors that would skew the average an d maximum iron concentrations (ERG, 2010).

EPA then compared the median iron concentr ation to available chemical precipitation and biological treatability data. EPA chose th ese specific wastewater treatment technologiesSection 8 – Landfills (40 CFR Part 445)



### 8-10 because they were the technologies used to de termine the best available technology (BAT) basis used to develop limits for the RCRA Subtit le C Hazardous Waste Landfills. EPA used treatability data for chemical precipitation a nd biological treatment al ready established during previous annual reviews 16 

### (U.S. EPA, 2009).

Table 8-12 presents the median iron concentrat ion compared to the EPA Method 200.7 MDL and compared to treatability concentrations for chemical precipitation and biological

treatment. Table 8-12 shows that the median iron concentrat ion in landfill disc harges is below the maximum concentrations achievable by ch emical precipitation a nd biological treatment.

16 As part of the Steam Electric Powe r Generating Point Source Category Detailed Study, EPA collected treatability data for chemical precipitation and biological treatment sy stems. Iron was included in the treatability data (U.S. EPA, 2009).Section 8 – Landfills (40 CFR Part 445)8-11Table 8-12. Iron Concentrations in the 2008 DMR Database Compared to Treatability ConcentrationsPollutantNumber ofFacilitiesReportingPollutantaEPA 200.7 MDL(mg/L)ChemicalPrecipitationTreatmentConcentrationRange (mg/L)BiologicalTreatmentConcentrationRange (mg/L)MedianConcentration(mg/L)Percent ofConcentrationsabove ChemicalPrecipitationRangePercent ofConcentrationsabove BiologicalTreatmentRangeIron1460.030.019 – 6ND (0.0022) – 231.2111%2%Source: DMR Loadings Tool;Method 200.7 Determination of Metals and Trace Elements in Water and Wastesby Inductively Couple Plasma-Atomic EmissionSpectrometry(U.S. EPA, 1994); and2009Steam Electric Power Generating Point Source Category: Final Detailed Study Report(U.S. EPA, 2009).a – Number of facilities reporting iron concentrations after EPA excluded outfalls with all nondetect concentrations and concentrations reported as 0 mg/L.MDL – Method detection limit.ND –Nondetect. Detection limit indicated in ( ).Section 8 – Landfills (40 CFR Part 445)



### 8-12 The median iron concentration for all outfalls is less than the bi ological treatment or chemical precipitation treatability concentra tions. Approximately 89 percent of the iron concentrations are below the chemical precipitat ion treatability (below 6 mg/L) and 98 percent are below the biological treatment treatabi lity (below 23 mg/L). The remaining iron concentrations above the chemical precipitati on treatment range are reported by a total of 24 facilities, seven of which are also above the biological treatment range.

EPA determined that approximately 80 percent of the facilities reporting iron

concentrations above treatable le vels are located in Missouri and Kentucky. Because the majority of the landfills are minor discharges and EPA has not previously revi ewed their data, EPA believes that there may be data quality issu es (e.g., incorrect un its) with the high iron concentrations. Additionally, the majority of the facilities have iron concentrations below treatable levels. Therefore, EPA does not believe that revising the Landfill ELGs to include iron limits is appropriate.

8 .6 Landfills Category Conclusions

T he estimated toxicity of the Landfills Category discharges results mainly from the discharges of metals. During th e 2010 annual review, EPA identifie d many data entry errors in the Landfill Category DMR data, because they ar e predominately minor discharges. Based on corrected discharge data, further review at this time is unnecessary. Therefore, EPA concludes the following:

• 

### Database errors were identified for vanadium, manganese, arsenic, and iron. Additionally, one fac ility, American Electric Power, was incorrectly categorized in the Landfills Category when it should be included in the Steam Electric Power Generating Category (40 CFR Part 423). Ma king these corrections decreases the Landfills Category TWPE by over 49 percent, from 191,000 TWPE to 97,000

TWPE.

• 

### Eighty-nine percent of iron concentrati ons in the 2008 DMR database are within treatability concentration ranges. Twen ty-one of the 24 facilities with iron concentrations in the 2008 DMR database that exceed treatability concentrations are located in Missouri and Kentucky. Iron is not regulated by the Landfill ELGs. There are possible quality issues with th e iron concentration data in the Landfills Category. EPA will continue monitoring iron concentrations from landfills as part of future annual reviews. Based on these data, EPA cannot conclude that an effluent guideline revision is necessary at this time; howev er, EPA will collect

additional data for considerati on during the 2011 annual review.

EPA prioritizes point source categories with existing regulations for potential revision based on the greatest estimated toxicity to human health and the environment, measured as TWPE. Based on the above conclusions, EPA is assi gning this category with a lower priority for revision (i.e., this category is marked with “(5)” in the “Findings” column in Table V-1 in the Federal Register notice that presents the 2010 an nual review of existing effluent guidelines and pretreatment standards).Section 8 – Landfills (40 CFR Part 445)



### 8-13 8 .7 Landfills Category References

1. ERG. 2010 Eastern Research Group, Inc. Me morandum to William Swietlik, U.S. EPA EPA, from Jessica Wolford and Elizabeth Sabol, Eastern Research Group, Inc. RE: Methodology for Analyzing Landfill Iron Concentrations in the 2008 DMR Loadings Tool. (October). EP A-HQ-OW-2008-0517 DCN 07277.

2. Gatlin, Jacquelin. 2010. E-mail communication between Jacquelin Gatlin, Missouri Department of Natural Resources, and El eanor Codding, Eastern Research Group, Inc. “RE: OR 15133 DMRs for Springfield Sa nitary Landfill.” (June 24). EPA-HQ-OW2008-0517 DCN 07278.

3. Ohio EPA. 2009. Ohio Environmental Protec tion Agency. Authorization to Discharge

under National Pollutant Disc harge Elimination System Permit OH0076627 – Columbus Southern Power Company, Conesville, OH. Ohio EPA Location. (December). EPA-HQOW-2008-0517 DCN 07279.

4. Palmer, Adria. 2010. E-mail communicat ion between Adria Palmer, Missouri Department of Natural Resources, and El eanor Codding, Eastern Research Group, Inc. “Confirming DMR Data for Advantage Metals Recycling Facility (MO0115801).” (June 28). EPA-HQ-OW-2008-0517 DCN 07280.

5. Tipton, Lantz. 2010. E-mail communication be tween Lantz Tipton, Missouri Department of Natural Resources, and Elizabeth Sa bol, Eastern Research Group, Inc. “DMRs Clarification Needed for Onyx Maple H ill Landfill.” (June 30). EPA-HQ-OW-2008-0517

DCN 07281.

6. U .S. EPA. 1994. Method 200.7 Determination of Meta ls and Trace Elements in Water and Wastes by Inductively Couple Plasma -Atomic Emission Spectrometry Revision 4.4

. Washington, DC. (Unknown). Available online at: http://www.epa.gov/waterscien ce/methods/method/files/200_7.pdf.

7. U.S. EPA. 2000. Development Document for Final Effluent Limitations Guidelines and Standards for the Landfills Point Source Category . EPA-821-R-99-019. Washington, DC. (January). Available online at: http://www.epa.gov/waterscience/guide/landfills/final/index.html.

8. U.S. EPA. 2009. Steam Electric Power Generating Point Source Category: Final Detailed Study Report . EPA-821-R-008. Washington, DC . (October). EPA-HQ-OW2008-0517-0413.Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-1 9. M INERAL 

### M INING AND 

### P ROCESSING 

### (40 CFR P ART 

### 436)

EP A selected the Mineral Mining and Pro cessing (Mineral Mining) Category for preliminary review because it continues to rank high, in terms of toxic-weighted pound equivalent (TWPE), in point source category rankings (see Table 5-3 for the point source category rankings). This indus try was reviewed previously in EPA’s Final 2004 Effluent Guidelines Program Plans (U.S. EPA, 2004). Th is section summarizes the 2010 annual review associated with the Mineral Mining Category. EPA focused on discharges of sulfide, fluoride, and ammonia as nitrogen, because of their high TW PE relative to other pollutants in the Mineral Mining Category.

9. 1 Mineral Mining Category Background

Th is subsection provides the background on the Mineral Mining Category including a brief industry profile of the mineral mining and processing industry and background on 40 CFR

Part 436.

9. 1.1 Mineral Mining Industry Profile

Th e Mineral Mining Category includes facilities that mine and process non-metallic minerals and discharge wastewat er. EPA considered the follow ing 28 North American Industry Classification System (NAICS) codes as part of the Mineral Mining Category:

• 

### 2 12311: Dimension Stone Mining and Quarrying;

• 

### 2 12312: Crushed and Broken Limest one Mining and Quarrying;

• 

### 2 12313: Crushed and Broken Gran ite Mining and Quarrying;

• 

### 2 12319: Other Crushed and Broken St one Mining and Quarrying;

• 

### 21 2321: Construction Sand and Gravel Mining;

• 

### 2123 22: Industrial Sand Mining;

• 

### 212324: Kaolin and Ball Clay Mining;

• 

### 212325: Clay and Ceramic and Re fractory Minerals Mining;

• 

### 212391: Potash, Soda, and Borate Mineral Mining;

• 

### 212392: Phosphate Rock Mining;

• 

### 212393: Other Chemical and Fertilizer Mineral Mining;

• 

### 212399: All Other Nonmetal lic Mineral Mining;

• 

### 213115: Support Activities for Nonmetal lic Minerals (except Fuels);

• 

### 327111: Vitreous China Plumbing Fixture and China and Earthenware Bathroom Accessories Manufacturing;

• 

### 327112: Vitreous China, Fine Earthe nware, and Other Pottery Product Manufacturing;

• 

### 327113: Porcelain Electrical Supply Manufacturing;

• 

### 327121: Brick and Structural Clay Tile Manufacturing;

• 

### 327122: Ceramic Wall and Floor Tile Manufacturing;

• 

### 327123: Other Structural Clay Product Manufacturing;

• 

### 327124: Clay Refractory Manufacturing;

• 

### 327125: Nonclay Refractory Manufacturing;

• 

### 327410: Lime Manufacturing;

• 

### 327420: Gypsum Product Manufacturing;

• 

### 327910: Abrasive Product Manufacturing;Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-2 • 

### 327992: Ground or Treated Mineral and Earth Manufacturing;

• 

### 327999: All Other Miscellaneous Nonmetal lic Mineral Product Manufacturing;

• 

### 339999MIN: All Other Miscella neous Manufacturing; and

• 

### 423320: Brick, Stone, and Related Constructi on Material Mercha nt Wholesalers.

Wastewater generated by facilities in NAICS codes 339999 can be regulated under multiple categories. EPA reviewed availabl e information about pollutant loads and manufacturing operations for fac ilities reporting this NAICS codes. EPA assigned the extension

“MIN” to the end of the NAICS codes of facilities that likely primarily generate wastewater regulated by the Mineral Mini ng Effluent Limitation Guidelines and Standards (ELGs). For example, most facilities in NAICS code 339999 are grouped under the Metal Finishing ELGs.

Because the Permit Compliance System (PCS) and the Integrated Compliance Information System – National Pollutant Discharge Elimination System (ICIS-NPDES), the sources of the discharge mon itoring report (DMR) data used to develop DMRLoads2008, report facilities by Standard Industrial Classification (SIC) code, and the U.S. Economic Census and Toxics Release Inventory (TRI) report data by NAICS code, EP A reclassified the 2008 DMR by the equivalent NAICS code. Table 9-1 lists the number of facilities from the U.S. Economic Census and the screening-level databases for the 21 NAICS codes with operations in the Mineral Mining Category, the corresponding SIC codes are in cluded for reference. The U.S. Economic

Census includes more facilities than the scr eening-level databases be cause of many possible factors including: facilities may not meet TRI-repor ting thresholds, facilities may discharge to a publicly owned treatment works (POTW), and some facilities in the U.S. Economic Census are

distributors or sales faci lities, not manufacturers.

Table 9-1. Number of Mineral Mining Facilities

NAICS Code SIC Code Number of Facilities

2002 U.S.

Economic

Census 2008

DMR a 2008

TRI b

212311: Dimension Stone Mining and Quarrying 1411: Dimension Stone 179 48

212312: Crushed and Broken Limestone Mining and Quarrying 1422: Crushed and Broken Limestone 1,523 881 3

212313: Crushed and Broken Granite Mining and Quarrying 1423: Crushed and Broken Granite 322 91 4Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-3 Table 9-1. Number of Mineral Mining Facilities

NAICS Code SIC Code Number of Facilities

2002 U.S.

Economic

Census 2008

DMR a 2008

TRI b

212319: Other Crushed and Broken Stone Mining and Quarrying 1429: Crushed and Broken Stone, NEC, 1455: Kaolin and Ball Clay, 1459: Clay, Ceramic, and Refractory Minerals, NEC,

1479: Chemical and Fertilizer Mineral Mining, NEC,

1499: Miscellaneous Nonmetallic Minerals, Except Fuels (except

bituminous limestone and bituminous sandstone), 3295: Minerals and Earths, Ground or Otherwise Treated (grinding, washing, separating, etc. of kaolin and ball clay). 1,214

696 4

212324: Kaolin and Ball Clay Mining 35 2

212325: Clay and Ceramic and Refractory Minerals Mining 123 3

212393: Other Chemical and Fertilizer Mineral Mining 47 1

212399: All Other Nonmetallic Mineral Mining 246 21

327992: Ground or Treated Mineral and Earth Manufacturing 292 43

212321: Construction Sand and Gravel Mining 1442: Construction Sand and Gravel 2,612 1288 6

212322: Industrial Sand Mining 1446: Industrial Sand 141 56

212391: Potash, Soda, and Borate Mineral Mining 1474: Potash, Soda, and Borate Minerals 24 1

212392: Phosphate Rock Mining 1475: Phosphate Rock 15 38

213115: Support Activities for Nonmetallic Minerals (except Fuels) 1481: Nonmetallic Minerals Services, Except Fuels (except geophysical surveying and mapping and site preparation and related construction activities performed on a contract or fee basis) 284 10 1

327111: Vitreous China Plumbing

Fixture and China and Earthenware

Bathroom Accessories Manufacturing 3261: Vitreous China Plumbing Fixtures and China and Earthenware Fittings and

Bathroom Accessories 50 15 5

327112: Vitreous China, Fine Earthenware, and Other Pottery Product Manufacturing 3262:Vitreous China Table and Kitchen Articles, 3263: Fine Earthenware (Whiteware) Table and Kitchen Articles, 3269: Pottery Products, NEC 760 18 8

327113: Porcelain Electrical Supply Manufacturing 3264: Porcelain Electrical Supplies 138 13 5

327121: Brick and Structural Clay Tile Manufacturing 3251: Brick and Structural Clay Tile (except slumped brick) 200 43 96

327122: Ceramic Wall and Floor Tile Manufacturing 3253: Ceramic Wall and Floor Tile 203 8 17

327123: Other Structural Clay Product Manufacturing 3259: Structural Clay Products, NEC 50 7 5

327124: Clay Refractory Manufacturing 3255: Clay Refractories 134 43 12Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-4 Table 9-1. Number of Mineral Mining Facilities

NAICS Code SIC Code Number of Facilities

2002 U.S.

Economic

Census 2008

DMR a 2008

TRI b

327125: Nonclay Refractory Manufacturing 3297: Nonclay Refractories 106 17 19

327410: Lime Manufacturing 3274: Lime 77 35 48

327420: Gypsum Product Manufacturing

3275: Gypsum Products, 3291: Abrasive Products (steel wool with or without soap), 3299: Nonmetallic Mineral Products, NEC (moldings, ornamental and architectural plaster work, and gypsum statuary) 308

64 85

327910: Abrasive Product Manufacturing 363 28

327999: All Other Miscellaneous

Nonmetallic Mineral Product Manufacturing 454 45

339999MIN: All Other Miscellaneous Manufacturing 5,332 1

423320: Brick, Stone, and Related

Construction Material Merchant

Wholesalers 5032: Brick, Stone, and Related Construction Materials (merchant wholesalers except construction materials sold via retail method) 3,592 49 2

Total 18,824 3,421 464

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); TRIReleases2008_v3 ; and DMRLoads2008_v2

. a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an NAICS to SIC crosswalk for comparison purposes. b – Releases to any media. NA – Not applicable.



### Table 9-2 shows how permitting authorities designated direct discharging facilities in the Mineral Mining Category as minor or major (see Section 4.1.5 ). EPA included data for minor dischargers for the first time in the 2010 annual review, as part of DMRLoads2008_v2 . EPA does not require permitting authorities to submit DMR data for minor dischargers; however, many states do provide complete DMR data for them . From the 2010 annual review, EPA observed many data entry or other errors for minor discha rgers in addition to those previously identified for major dischargers, as discussed in Section 4.3

. Table 9-2 shows that approximately 99 percent of the Mineral Mining Category disc hargers in the 2008 DMR database are minor dischargers.

Table 9-2. Number of Mineral Mining Facilities

NAICS Code a Number of Facilities in DMR 2008

Majors Dischargers Minor Dischargers All Dischargers

212311: Dimension Stone Mining and Quarrying 0 48 48

212312: Crushed and Broken Limestone Mining and Quarrying 7 874 881

212313: Crushed and Broken Granite Mining and Quarrying 0 91 91Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-5 Table 9-2. Number of Mineral Mining Facilities

NAICS Code a Number of Facilities in DMR 2008

Majors Dischargers Minor Dischargers All Dischargers

212319: Other Crushed and Broken Stone Mining and Quarrying

6 690 696 212324: Kaolin and Ball Clay Mining

212325: Clay and Ceramic and Refractory Minerals Mining

212393: Other Chemical and Fertilizer Mineral Mining

212399: All Other Nonmetallic Mineral Mining

327992: Ground or Treated Mineral and Earth Manufacturing

212321: Construction Sand and Gravel Mining 3 1,285 1,288

212322: Industrial Sand Mining 0 56 56

212391: Potash, Soda, and Borate Mineral Mining 0 1 1

212392: Phosphate Rock Mining 15 23 38

213115: Support Activities for Nonmetallic Minerals (except Fuels) 2 8 10

327111: Vitreous China Plumbing Fixture and China and Earthenware Bathroom Accessories Manufacturing 0 15 15

327112: Vitreous China, Fine Earthenware, and Other Pottery Product Manufacturing 0 18 18

327113: Porcelain Electrical Supply Manufacturing 0 13 13

327121: Brick and Structural Clay Tile Manufacturing 1 42 43

327122: Ceramic Wall and Floor Tile Manufacturing 0 8 8

327123: Other Structural Clay Product Manufacturing 0 7 7

327124: Clay Refractory Manufacturing 0 43 43

327125: Nonclay Refractory Manufacturing 1 16 17

327410: Lime Manufacturing 2 33 35

327420: Gypsum Product Manufacturing

0 64 64 327910: Abrasive Product Manufacturing

327999: All Other Miscellaneous Nonmetallic Mineral Product Manufacturing

339999MIN: All Other Miscellaneous Manufacturing

423320: Brick, Stone, and Related Construction Material

Merchant Wholesalers 0 49 49

Total 37 3,384 b 3,421

Source: DMRLoads2008_v2

. a – DMR data is reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison

purposes. b – The DMR data in PCS and ICIS-NPDES does not include discharge data for all minor dischargers. For the facilities in the Mineral Mining Category, 1,109 of the 3,384 minor dischargers have DMR data.Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-6 Table 9-3 presents the type of disc harges reported by facilitie s in the 2008 TRI database. The majority of mineral mining facilities reporting to TRI do not report water discharges, but those that do mostly repo rted discharging directly.

Table 9-3. Number of Mineral Mining Facili ties by Type of Discharger in TRI 2008

NAICS Code Number of Facilities in TRI 2008

Direct Dischargers Only Indirect Dischargers Only Both

Indirect and

Direct No Water Discharges

212311: Dimension Stone Mining and Quarrying 0 0 0 0

212312: Crushed and Broken Limestone Mining and Quarrying 1 0 0 2

212313: Crushed and Broken Granite Mining and Quarrying 1 1 0 2

212319: Other Crushed and Broken Stone Mining and Quarrying 1 0 0 3

212324: Kaolin and Ball Clay Mining 1 0 0 1

212325: Clay and Ceramic and Refractory Minerals Mining 0 0 0 3

212393: Other Chemical and Fertilizer Mineral Mining 0 0 0 1

212399: All Other Nonmetallic Mineral Mining 1 0 0 20

327992: Ground or Treated Mineral and Earth Manufacturing 5 2 0 36

212321: Construction Sand and Gravel Mining 5 0 0 1

212322: Industrial Sand Mining 0 0 0 0

212391: Potash, Soda, and Borate Mineral Mining 0 0 0 0

212392: Phosphate Rock Mining 0 0 0 0

213115: Support Activities for Nonmetallic Minerals (except Fuels) 0 0 0 1

327111: Vitreous China Plumbing Fixture and China

and Earthenware Bathroom Accessories Manufacturing 3 0 0 2

327112: Vitreous China, Fine Earthenware, and Other Pottery Product Manufacturing 1 1 1 5

327113: Porcelain Electrical Supply Manufacturing 0 1 0 4

327121: Brick and Structural Clay Tile Manufacturing 2 1 1 92

327122: Ceramic Wall and Floor Tile Manufacturing 1 4 0 12

327123: Other Structural Clay Product Manufacturing 1 1 0 3

327124: Clay Refractory Manufacturing 2 0 0 10

327125: Nonclay Refractory Manufacturing 1 6 1 11

327410: Lime Manufacturing 5 0 0 43

327420: Gypsum Product Manufacturing 31 0 0 54

327910: Abrasive Product Manufacturing 0 4 0 24

327999: All Other Miscellaneous Nonmetallic Mineral Product Manufacturing 2 5 0 38Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-7 Table 9-3. Number of Mineral Mining Facili ties by Type of Discharger in TRI 2008

NAICS Code Number of Facilities in TRI 2008

Direct Dischargers Only Indirect Dischargers Only Both

Indirect and

Direct No Water Discharges

339999MIN: All Other Miscellaneous Manufacturing 0 0 0 1

423320: Brick, Stone, and Related Construction

Material Merchant Wholesalers 0 0 0 2

Total 6 4 26 3 371

Source: TRIReleases2008_v3

.



### 9.1.2 40 CFR Part 436

There are 38 subcategories for the Mineral Mining ELGs. EPA first promulgated ELGs for the Mineral Mining Category (40 CFR Pa rt 436) on October 16, 1975 (40 FR 48657) for selected subparts. EPA proposed regulations on June 10, 1976 for additional subparts, of which only Subparts B, C, D, and R were promulgate d on July 1979. National amendments were made to the ELGs on December 28, 1979. 17 of the subpa rts in 40 CFR Part 436 are reserved. The majority of the remaining subcategories have no discharge requirements or best practical control technology (BPT) limitations. Table 9-4 lists the 38 subcategories and applicability.

Table 9-4. Applicability of Subcategor ies in the Mineral Mining Category

Subpart Subcategory Title Subcategory Applicability

A Dimension Stone Reserved

B Crushed Stone Crushed and broken stone and riprap, including calcite in conjunction with the processing of limestone or dolomite

C Construction Sand and Gravel Sand and gravel for construction or fill uses, excluding on-board processing of dredged sand and gravel that is covered by 33 CFR

Part 230

D Industrial Sand Sand and gravel for uses other than construction fill including, but not limited to, glassmaking, molding, abrasives, filtration, refractories, and refractory bonding

E Gypsum Gypsum

F Asphaltic Mineral Bituminous limestone, o il-impregnated diatomite and olsonite not primarily as an energy source

G Asbestos and Wollastonite Asbestos and wollastonite

H Lightweight Aggregates Reserved

I Mica and Sericite Reserved

J Barite Barite

K Fluorspar Fluorspar

L Salines from Brine Lakes Salines from brine lakes

M Borax Borate minerals, excluding borax obtained from brine lakes that is covered by 40 CFR Part 436 Subpart L

N Potash Potash, excluding potash obtained from brine lakes that is covered by 40 CFR Part 436 Subpart LSection 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-8 Table 9-4. Applicability of Subcategor ies in the Mineral Mining Category

Subpart Subcategory Title Subcategory Applicability

O Sodium Sulfate Sodium sulfate, excluding sodium sulfate obtained from brine lakes that is covered by 40 CFR Part 436 Subpart L

P Trona Reserved

Q Rock Salt Reserved

R Phosphate Rock Phosphate bearing rock, ore or earth for the phosphate content

S Frasch Sulfur Sulfur on shore and in ma rshes and estuaries by the Frasch process, excluding sulfur refining operations that are not performed at the mining and collection site

T Mineral Pigments Reserved

U Lithium Reserved

V Bentonite Bentonite

W Magnesite Magnesite

X Diatomite Diatomite

Y Jade Jade

Z Novaculite Novaculite

AA Fire Clay Reserved

AB Attapulgite and

Montmorillonite Reserved

AC Kyanite Reserved

AD Shale and Common Clay Reserved

AE Aplite Reserved

AF Tripoli Tripoli

AG Kaolin Reserved

AH Ball Clay Reserved

AI Feldspar Reserved

AJ Talc, Steatite, Soapstone and Pyrophyllite Reserved

AK Garnet Reserved

AL Graphite Graphite

Source: Mineral Mining and Processing Point Source Category – 40 CFR 436

.



### 9.2 Mineral Mining Category 2010 Screening-Level Review

Table 9-5 compares the screening-level results for the Mineral Mining Category from the 2006 through 2010 annual reviews. The combin ed DMR and TRI TWPE decreased from discharge years 2004 to 2007, but increased from discharge y ears 2007 to 2008. The discharge year 2008 DMR TWPE accounts for approximately 97 percent of the combined 2008 DMR and

TRI TWPE.Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-9 Table 9-5. Mineral Mining Category TRI and DMR Discharges for the 2010 and Previous Screening-Level Reviews

Year of Discharge Year of Review Mineral Mining Category

TRI TWPE DMR TWPE a Total TWPE

2002 2006 2,840 50,500 53,340

2004 2007 5,390 49,300 54,700

2005 2008 6,260 NA NA

2007 2009 2,420 26,700 29,100

2008 2010 3,390 100,000 103,000

Source: TRIReleases2002_v4 ; PCSLoads2002_v4 ; TRIReleases2004_v3 ; PCSLoads2004_v3 ; TRIReleases2005_v2 ; TRIReleases2007_v2 ; DMRLoads2007_v4 ; TRIReleases2008_v3 ; and DMRLoads2008_v2

. a – DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and major dischargers. NA – Not applicable. EPA did not evaluate DMR data for 2005.



### Table 9-6 presents the 2008 DMR TWPE by f acility discharge classification. EPA excluded minor dischargers from previous annual reviews, but included them in the 2010 annual review. The majority (69 percent) of the TW PE in the 2008 DMR database results from major dischargers.

Table 9-6. Mineral Mining Category 2008 DM R TWPE by Discharge Classification

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers

2 008 30,800 69,300

Source: DMRLoads2008_v2

. a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous

annual reviews.



### 9.3 Mineral Mining Category Pollutants of Concern

Table 9-7 compares the five pollutants with the highest TWPE based on the results from the 2010, 2009, and 2007 annual reviews ( TRIReleases2008_v3

, TRIReleases2007_v2 , and
TRIReleases2004_ v3 , respectively). Table 9-8 lists the five pollutants with the highest DMR TWPE based on the results from the 2010, 2009, and 2007 annual reviews ( DMRLoads2008_v2, DMRLoads2007_v3 , and PCSLoads2004_v4 , respectively).Section 9 – Mineral Mining and Processing (40 CFR Part 436)9-10Table 9-7. Mineral Mining Category Top TRI PollutantsPollutant2004 TRI Databasea2007 TRI Databasea2008 TRI DatabaseaRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPENitrateCompounds361,050151,300162,080Copper and Copper CompoundsPollutants not reported in the top fiveTRI 2004 reported pollutants.Pollutants not reported in the top fiveTRI 2007 reported pollutants.24435Mercury and mercury Compounds24387316249Manganese and ManganeseCompounds51126548239410151Lead and Lead Compounds1511,270323371553144AmmoniaPollutants not reported in the top fiveTRI 2004 reported pollutants.5360Pollutants not reported in the top fiveTRI 2008 reported pollutants.Nickel and Nickel Compounds271,060Pollutants not reported in the top fiveTRI 2007 reported pollutants.Chromium and ChromiumCompounds413806Mineral Mining Category TotalNA101b6,260NA60b2,420NA92b3,390Source:TRIReleases2004_v3;TRIReleases2007_v2; andTRIReleases2008_v3.a – Discharges include transfers to POTWs and account for POTW removals.b – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 9 – Mineral Mining and Processing (40 CFR Part 436)9-11Table 9-8. Mineral Mining Category Top DMR PollutantsPollutant2004 DMR Databasea2007 DMR Databasea2008 DMR DatabasebRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPESulfidePollutant not reported in the top five DMR2004 reported pollutants.Pollutant not reported in the top five DMR2007 reported pollutants.1535,900Fluoride11441,80011418,70022028,200Ammonia as NitrogenPollutant not reported in the top five DMR2004 reported pollutants.Pollutant not reported in the top five DMR2007 reported pollutants.32811,100Chloride431,510565724276,690Lead321,560312,7605125,940Cadmium211,940223,060Pollutant not reported in the top five DMR2008 reported pollutants.Zinc5348241710Mineral Mining CategoryTotalNA23c49,300NA28c26,700NA120c100,000Source:PCSLoads2004_v4;DMRLoads2007_v3; andDMRLoads2008_v2.a – 2004 and 2007 DMR data only include major dischargers.b– 2008 DMR data includes major and minor dischargers.c – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-12 The Mineral Mining Category TWPE in the 2008 TRI database is significantly lower than the 2008 DMR TWPE. Therefore, EPA focu sed the preliminary category review on the DMR-reported pollutants that account for the majority of the category TWPE.

EPA’s additional review for the 2008 DMR da tabase pollutants of concern, sulfide, fluoride, and ammonia as nitrogen, is presen ted in the following subsections. EPA did not investigate the other top pollutant s as part of the 2010 annual review because they account for a small percentage (27 percent) of the 2008 Mi neral Mining Category combined DMR and TRI

TWPE.

Of the pollutants of concern for the Mine ral Mining Category, Part 436 only regulates fluoride in Subpart D – Industrial Sand Subcat egory. EPA’s 2010 annual review of the Mineral Mining Category determined that the majority of fluoride discharges are from facilities covered by the Phosphate Rock Subcategory (Subpart R) . The Phosphate Rock Subcategory does not regulate fluoride.

9.4 Mineral Mining Category Sul fide Discharges in DMR

As part of the 2010 annual review of the Mi neral Mining Category, EPA reviewed sulfide discharges in the 2008 DMR database. Approxi mately 36 percent of the 2008 DMR TWPE is from sulfide discharges. Table 9-9 presents the sulfide discharges from mineral mining facilities

in the 2008 DMR database. US Silica Co. in Rockwood, MI, accounts for 87 percent of the sulfide discharges in the DM R 2008 database for the Mineral Mining Category. This subsection provides information on US S ilica’s sulfide discharges.

Table 9-9. Mineral Mining Category Top Sulfide Discharging Facility in DMR 2008

Facility Name Pounds of Sulfide Discharged Sulfide TWPE Percentage of Mineral Mining Category Sulfide

DMR 2008 TWPE

US Silica Co. 11,200 31,200 87%

Stoneco Inc. 1,150 3,210 9%

US Gypsum Co. 415 1,160 3%

Stoneco Inc. – Maybee 57 159 <1%

Stoneco Inc. - Denniston 40 113 <1%

Total 12,800 35,900 100%

Source: DMRLoads2008_v2

.



### US Silica discharges sulfide from outfall 002. Table 9-10 presents US Silica’s 2008 monthly sulfide discharge data in the DMR Lo adings Tool for outfall 002. The facility permit

states that outfall 002 is for sand and limestone mine dewatering water and process wastewater. The facility permit requires the facility to re port dissolved sulfide c oncentrations monthly (MDEQ, 2005).Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-13 EPA reviewed DMR data from Envirofacts 17 

### for 2008 – 2010. The 2008 sulfide and flow data from the DMR Loadings Tool corresponds to the Envirofacts, and EPA identified no corrections for data in the DMR Loadings Tool . EPA did find that US Silica only detected sulfide during one month from January 2008 through March 2010. Table 9-11 presents US

Silica’s available 2009 and 2010 sulf ide discharge data from Envirofacts. Given that these discharges occurred only once in almost three year s, EPA finds that the sulfide discharges from this facility do not represent a consistent discharge for all sili ca mineral mines. EPA also does not believe the US Silica sulfide discharges warrant a revision to the Mineral Mining ELGs. For an individual facility, permit wr iters can apply best profession al judgment to determine the appropriate control of discharges.

Table 9-10. US Silica Co. 2008 Monthly Sulfide and Flow Discharge Data

Outfall Monitoring Period

Date DMR Loadings Tool Maximum Sulfide Concentration (mg/L) DMR Loadings Tool Average Flow (MGD)

002 31-Jan-08 2.20 13.06

002 31-Mar-08 0 13.69

002 30-Apr-08 0 13.38

002 31-Aug-08 0 13.05

002 30-Sep-08 0 12.81

002 31-Oct-08 0 12.61

002 30-Nov-08 0 12.23

002 31-Dec-08 0 11.98

Source: DMR Loadings Tool.



### Table 9-11. US Silica Co. 2009 and 2010 Monthl y Sulfide and Flow Discharge Data

Outfall Monitoring Period

Date Envirofacts Sulfide Concentration (mg/L) Envirofacts Flow (MGD)

002 30-Apr-09 0 11.45

002 30-Jun-09 0 11.3

002 31-Aug-09 0 11.68

002 30-Sept-09 0 11.1

002 31-Oct-09 0 11.8

002 30-Nov-09 0 11.4

002 31-Dec-09 0 12.3

002 31-Jan-10 0 11.7

002 28-Feb-10 0 11.9

002 31-Mar-10 0 11.9

Source: Envirofacts.

17 EPA uses the data in Envirofacts as a source while re viewing the DMR Loadings Tool data because Envirofacts continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not continuously updated; therefore, loads may be estimated with erroneous data.Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-14 9.5 Mineral Mining Category Fluoride Discharges in DMR

As part of the 2010 annual review of th e Mineral Mining Category, EPA reviewed fluoride discharges in the 2008 DMR database . Approximately 28 percent of the 2008 DMR TWPE is from fluoride discharges. Table 9-12 presents the fluoride discharges from mineral mining facilities in the 2008 DMR database.

The majority (74 percent) of fluoride di scharges in 2008 were from four fluoride discharging facilities: PCS Phosphates White Springs, PCS Phosphates White Springs (Jasper), US Agri-Chemicals, and Feldspar Corp. These fluoride discharges re sult from mineral mining processes that are regu lated by Subparts R – Phosphate Rock and AI – Feldspar. Neither Subpart R nor Subpart AI sets limits for fluoride (Subpa rt AI is reserved). This subsection provides information on the fluoride discharges from th e top four fluoride di scharging facilities.

Table 9-12. Mineral Mining Category Top Fl uoride Discharging Facilities in DMR 2008

Facility Name Location Pounds of

Fluoride Discharged Fluoride TWPE Percentage of Mineral Mining Category

Fluoride DMR

2008 TWPE

PCS Phosphates White Springs White Springs, FL 334,000 10,000 35.6%

PCS Phosphates White Springs (Jasper) Jasper, FL 173,000 5,200 18.4%

US Agri-Chemicals – Ft Meade Fort Meade, FL 111,000 3,320 11.8%

Feldspar Corp Spruce Pine Fac Spruce Pine, NC 72,300 2,170 7.7%

Mosaic Fertilizer, LLC – Ft Gr White Springs, FL 50,500 1,510 5.4%

Mosaic Fertilizer LLC - Four Polk County, FL 42,200 1,270 4.5%

Remaining Mineral Mining Fluoride Dischargers a NA 156,000 4,690 16.7%

Total 9 40,000 28,200 100%

S ource: DMRLoads2008_v2

. a – There are 14 remaining mineral mining facilities that have fluoride discharges in DMRLoads2008_v2 that account for 16.7 percent of the Mineral Mining Category’s 2008 fluoride TWPE. NA – Not applicable.



### 9.5.1 Wastewater Sources of Fluoride

The majority of the fluoride discharges fo r the Mineral Mining and Processing Category are from phosphate mines in Florida and feldsp ar mines in North Carolina. EPA previously compiled information on this category, disc ussed in the 1976 Development Document for

Interim Final Effluent Limitations Guidelines and Standards of Performance – Mineral Mining and Processing Industry (Miner al Mining Development Document). For the 2010 Final Plan, EPA compared current information to data fr om the Mineral Mining Development Document.

Phosphate mines are located in four major producing areas: Florida, North Carolina, Tennessee, and western states. The phosphate ro ck is not a pure compound, but a fluorapitite mineral containing impurities of fluoride, iron, aluminum, silica, and uranium. In Florida, phosphate rock washing operations produce large quantities of slurry, very fine clay, andSection 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-15 phosphate minerals called slime. This slime is sent to settling ponds th at cover large surface areas. Wastewater is generated from stormwater runoff from the slime storage and disposal area (U.S. EPA, 1976). Some of the Florida phosphate mines also appear to manufacture phosphatic fertilizer on site, which also generates fluoride-containing wast ewater. See the Section 8.5.2 of the Technical Support Document for the 2006 Effl uent Guidelines Program Plan (U.S. EPA, 2006) for potential wastewater sources fr om the phosphate fertilizer operations.

The feldspar mines in North Carolina use hydrofluoric acid fl otation to separate the byproducts, which can include mica, quartz, and sa nd, from the feldspar (U.S. EPA, 1976). The feldspar processing uses significan t quantities of water with litt le recycle because of possible build-up of soluble organics and fluoride ions. Fac ilities can also use sulfur ic acid, sulfonic acid, frothers, amines and oils as the flotation ag ent. The Mineral Mining Development Document

shows that treated effluent fl uoride concentrations in 1976 range d from 1.3 mg/L to 34 mg/L. The hydrofluoric acid flotation generates fl uoride-containing wast ewater, which can be minimized using a flotation circuit and/or part ial recycle of the fluoride, as well as lime treatment. The Mineral Mining Development Docu ment studied the performance of single stage chemical precipitation: lime addition with mixing followed by settling ponds. The 1976 data showed that single-stage chemical precipitation could achieve efflue nt fluoride concentrations of less than 10 mg/L through segreg ation and separate treatment of fluoride-containing streams (U.S. EPA, 1976).

9.5.2 Top Facilities Discharging Fluoride

The majority (75 percent) of fluoride discha rges in 2008 were from the top four fluoride discharging facilities: PCS Phosphates White Springs, PCS Phosphates White Springs (Jasper), US Agri-Chemicals, and Feldspar Corp. Fluor ide is generated in the open-pit mining of phosphate rock and the production of feldspar in the Phosphate Rock and Feldspar Subcategories of the Mineral Mining Category, respectively. This subsection provides information on each facility’s fluoride discharges from the 2008 DM R Loadings Tool and their corresponding permit limits, if available.

PCS Phosphates White Springs in White Springs, FL

PCS Phosphates White Springs generates wastewater from: open-pit mining of phosphate rock, beneficiation of the roc k, manufacture of sulfuric acid and phosphoric acid, production of fertilizer components and anim al-feed supplements, and stormw ater runoff. The facility’s treatment system includes pH adjustment and ch emical precipitation, when required, using lime; settling and sedimentation; and adsorption/abso rption on mining waste clay particles in clay settling areas (FL DEP, 2003a).

PCS Phosphates White Springs discharg es fluoride from outfalls 001, 122, and 128. Outfall 001 is a surface water monitoring location. Table 9-13 describes outfall descriptions, fluoride limits, and the basis of the fluoride limits.Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-16 Table 9-13. PCS Phosphates White Springs Ou tfall Descriptions and Fluoride Limits

Outfall Outfall Description Fluoride Limits

Daily

Maximum

(mg/L) Monthly Average (mg/L) Limit Basis a

001 Swift Creek surface water monitoring

location 10.0 Report Only FL DEP water quality criteria for Class III predominately

fresh surface water

122 Treated process wastewater, CNPW, stormwater, and treated sanita ry wastewater 75.0 25.0 Fertilizer Manufacturing

ELGs

128 Treated process wastewater, CNPW, stormwater, treated sanitary wastewater, and discharges above mid-point of the surge capacity from the calcium sulfate stormwater pile runoff system 75.0 25.0 Fertilizer Manufacturing

ELGs

Source: Facility Permit (FL DEP, 2003a). a – The facility’s permit and fact sheet do not state the basis for the fluoride limit. However, the limits set correspond to FL water quality criteria for Class III pre dominately fresh surface water. The permit limits may also be based on permit writer best professional judgment.



### Table 9-14 presents the monthly discharge data for the PCS Phosphates White Springs facility for outfalls 001 and 122, which account for the majority of the fluoride discharges. As

shown in Table 9-14 , the fluoride concentrations in the 2008 DMR data are below permit limitations. Outfall 001 represents a surface wate r monitoring location; therefore, EPA will exclude these discharges from future screening- level databases. This exclusion would reduce the facility’s fluoride discharges from 10,000 TWPE to 2,340 TWPE. Additionally, the fluoride

concentrations at outfall 001 are less than the Florida Department of Environmental Protection’s (FL DEP’s) water quality standa rd, showing that PCS Phosphat es White Springs’ fluoride discharges are not expected to impact the quality of the receiving stream.

Table 9-14. 2008 Monthly Fluoride Concentratio ns and Limits for PCS Phosphates White Springs

Monitoring

Period Date DMR Loadings Tool Daily Maximum

Fluoride Concentration (mg/L) DMR Loadings Tool Monthly Average

Fluoride Concentration (mg/L) Daily Maximum

Fluoride Permit Limit (mg/L) Monthly Average

Fluoride Permit Limit (mg/L)

Outfall 001 – Surface Water Monitoring

31-Jan-08 2.62 2.34 10 Report

29-Feb-08 2.03 1.92 10 Report

31-Mar-08 1.83 1.73 10 Report

30-Apr-08 2.18 1.97 10 Report

31-May-08 2.26 2.19 10 Report

30-Jun-08 2.33 2.23 10 Report

31-Jul-08 2.55 2.39 10 Report

31-Aug-08 2.26 2.13 10 Report

30-Sep-08 2.59 2.44 10 Report

31-Oct-08 2.52 2.45 10 ReportSection 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-17 Table 9-14. 2008 Monthly Fluoride Concentratio ns and Limits for PCS Phosphates White Springs

Monitoring

Period Date DMR Loadings Tool Daily Maximum

Fluoride Concentration (mg/L) DMR Loadings Tool Monthly Average

Fluoride Concentration (mg/L) Daily Maximum

Fluoride Permit Limit (mg/L) Monthly Average

Fluoride Permit Limit (mg/L)

30-Nov-08 2.7 2.60 10 Report

31-Dec-08 2.45 2.34 10 Report

Outfall 122 - Treated Process Wastewater, CNPW , Stormwater, and Treate d Sanitary Wastewater

31-Jan-08 10.19 5.06 75 25

29-Feb-08 4.1 4.10 75 25

31-Mar-08 6.43 5.07 75 25

30-Apr-08 4.38 4.02 75 25

31-May-08 5.92 4.92 75 25

30-Jun-08 5.55 4.70 75 25

31-Jul-08 5.17 4.82 75 25

31-Aug-08 5.5 4.78 75 25

30-Sep-08 3.98 3.26 75 25

31-Oct-08 5.36 4.27 75 25

30-Nov-08 4.77 3.93 75 25

31-Dec-08 3.15 1.81 75 25

Source: DMR Loadings Tool and Facility Permit (FL DEP, 2003a).



### PCS Phosphates White Springs (Jasper) in Jasper, FL

PCS Phosphates White Springs (Jasper) gene rates wastewater from: open-pit mining of phosphate rock, beneficiation of the rock, and stormwater from the Suwannee River Chemical Complex and Mine. The facility’s treatment sy stem includes pH adjustment and chemical precipitation, when required, using lime; settling and sedimentation; and adsorption/absorption on mining waste clay particles in clay settling areas (FL DEP, 2003b).

PCS Phosphates White Springs (Jasper) discharges most of its fluoride from outfall 001, with minor discharges from outfalls 1A2, 1H8, and 202. Outfall 001 represents a surface water monitoring location in Swift Creek, the receiv ing stream for outfalls 1A2, 1H8, and other outfalls. Outfall 202 is process wastewater from the mining and beneficiation of phosphate rock, CNPW, stormwater, mine dewatering, and treated sanitary wastewater.

Table 9-15 presents the monthly discharge data for the PCS Phosphates White Springs (Jasper) facility for outfall 001 (i n-stream monitoring location), co mpared to the fluoride permit

limits. As shown in Table 9-15 , the fluoride concentrations in the 2008 DMR data are below permit limitations. Outfall 001 represents a surf ace water monitoring location; therefore, EPA will exclude these discharges from future screening-level databases. This exclusion would reduce the facility’s fluoride discharges from 5,200 TWPE to 720 TWPE. Additionally, the fluoride

concentrations at outfall 001 ar e less than the FL DEP’s water quality standard, showing that PCS Phosphates White Springs (Jasper)’s fluoride discharges are not expected to impact the quality of the receiving stream.Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-18 Table 9-15. Outfall 001 Monthly Fluoride Concen trations and Limits for PCS Phosphates White Springs (Jasper)

Monitoring Period

Date DMR Loadings Tool Daily Maximum

Fluoride

Concentration (mg/L) DMR Loadings Tool Monthly Average

Fluoride

Concentration (mg/L) Daily Maximum

Fluoride Permit Limit (mg/L) a Monthly Average

Fluoride Permit Limit (mg/L) a

31-Jan-08 2.62 2.34 10 Report Only

29-Feb-08 2.03 1.92 10 Report Only

31-Mar-08 0.3 1.73 10 Report Only

30-Apr-08 2.18 1.97 10 Report Only

31-May-08 2.26 2.19 10 Report Only

30-Jun-08 2.33 2.23 10 Report Only

31-Jul-08 2.55 2.39 10 Report Only

31-Aug-08 2.26 2.13 10 Report Only

30-Sep-08 2.59 2.44 10 Report Only

31-Oct-08 2.52 2.45 10 Report Only

30-Nov-08 2.71 2.60 10 Report Only

31-Dec-08 2.45 2.34 10 Report Only

Source: 2008 DMR Loadings Tool and Facility Permit (FL DEP, 2003b). a – EPA suspects these fluoride limits are based on FL DE P water quality criteria for Class III predominately fresh

surface water.



### US Agri-Chemicals Corporation in Fort Meade, FL

US Agri-Chemicals Corporation manufactur es sulfuric acid, phosphoric acid, monoammonium phosphate, di-ammonium phosphate, and fluosilicic acid. US Agri-Chemicals also has a lined phosphogypsum stack and an un- lined process water cooling pond with a recirculation system. The facility is worki ng with the state to close the un-lined pond. The facility’s 2004 NPDES permit also allows the facility to construct an additional lined phosphogypsum stack. The facility treats wastewat er from both ponds through a two-stage lime treatment and spray aeration process prior to discharge (FL DEP, 2004).

Table 9-16 presents the monthly fluoride discha rge data for US Agri-Chemicals for outfall 004, compared to the fluoride permit limits. As shown in Table 9-16 , the fluoride

concentrations in the 2008 DMR data are be low permit limitations. Additionally, based on the permit and fact sheet, EPA believes that the facil ity’s operations fall within the applicability of the Fertilizer Manufacturing ELGs (40 CFR Pa rt 418) and/or Phosphate Manufacturing ELGs (40 CFR Part 422) rather than the Mineral Mini ng ELGs (40 CFR Part 436) because the facility does not have any mining operations. Therefore, discharges from this facility should be excluded

from the 2010 annual review of the Mineral Mi ning Category, reducing the category’s TWPE by 3,530 TWPE. As part of future annual reviews, EP A will continue its review of this facility’s discharges and reassign this faci lity to the correct category.Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-19 Table 9-16. 2008 Monthly Fluoride Discharge Da ta and Limits for US Agri-Chemicals Corporation

Outfall Monitoring Period

Date Maximum Fluoride

Concentration from DMR Data (mg/L) Daily Maximum

Fluoride Permit

Limit (mg/L) Monthly Average

Fluoride Permit

Limit (mg/L)

004 31-Jan-08 7.15 10 Report

004 29-Feb-08 5.50 10 Report

004 31-Mar-08 3.07 10 Report

004 30-Apr-08 3.23 10 Report

004 31-May-08 2.96 10 Report

004 30-Jun-08 3.60 10 Report

004 31-Jul-08 4.44 10 Report

004 31-Aug-08 4.01 10 Report

004 30-Sep-08 4.50 10 Report

004 31-Oct-08 5.53 10 Report

004 30-Nov-08 5.10 10 Report

004 31-Dec-08 3.86 10 Report

Source: DMR Loadings Tool and Facility Permit (FL DEP, 2004).



### Feldspar Corporation in Spruce Pine, NC

The Feldspar Corporation is an industrial minerals processing facility. The facility produces feldspar, quartz, and mica. Outfall 001 di scharges treated proces s wastewater to the North Toe River. The facility’s treatment system includes clarifiers, poly mer feed system, lime for pH adjustment, vacuum filters, and an Emic o clarifier/thickener to outfall 001 (NC DWQ, 2006).

The facility discharges fluoride from outfall 001. Table 9-17 presents the monthly fluoride discharge data for Feldspar. The fluorid e permit limits for the facility were 225 lb/day monthly average and 448 lb/day daily maximum when the facility was treating discharges from Unimum Corporation’s Crystal Operation. However, once Unimum began directly discharging, Feldspar’s fluoride limits were revised to 174 lb/day monthly average and 348 lb/day daily maximum (NC DWQ, 2006). It is unclear which limits applied in 2008. As shown in Table 9-17

, the facility did not meet fluoride permit limits for at least part of 2008. The monthly average fluoride quantities discharged are above the orig inal permit limit for January and February 2008 and above the revised permit limit for all of 2008. The daily maximum fluoride quantities are similarly above the original and revised daily maximum fluoride limits for 2008. This facility appears to be exceeding its mass-based permit fluoride limit.Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-20 Table 9-17. Outfall 001 Monthly Fluoride Di scharge Data and Limits for Feldspar Corporation

Monitoring

Period Date DMR Loadings Tool Daily Maximum Fluoride Quantity (lb/day) DMR Loadings Tool Monthly Average Fluoride Quantity (lb/day)

31-Jan-08 539 221.6

29-Feb-08 623.9 237.9

31-Mar-08 443.7 222.1

30-Apr-08 433.5 211.2

31-May-08 366.9 167.2

30-Jun-08 426.4 217.0

31-Jul-08 376.6 181.4

31-Aug-08 430.4 216.5

30-Sep-08 407.2 186.2

31-Oct-08 445.9 220.1

30-Nov-08 381.5 1 58.3

3 1-Dec-08 385.3 139.7

Source: DMR Loadings Tool.



### 9.5.3 Fluoride Wastewater Treatment

EPA determined that the top fluoride discharging facilities have two-stage chemical precipitation with lime treatment sy stems. This process is similar to that at phosphatic fertilizer manufacturing facilities, which achieve fluoride concentrations of 15 mg/L or less (U.S. EPA, 1974). Current technologies are achieving fluoride concentrations at least as effective, sometimes achieving 2 mg/L effluent fluoride. The chemi cal precipitation has improved by using calcium chloride (CaCl 2 

### ) rather than lime, while solids sepa ration has improved by using polymers and membrane filters (WC&E, 2006; Ionics, Unknown; GCIP, 2002).

9.6 Mineral Mining Category Ammonia as Nitrogen Discharges in DMR

As part of the 2010 annual review of th e Mineral Mining Category, EPA reviewed ammonia as nitrogen (ammonia as N) discharg es in the 2008 DMR database. Approximately 11 percent of the 2008 DMR TWPE is from discharges of ammonia as N. Table 9-18 presents the ammonia as N discharges from mineral mining facilities in the 2008 DM R database. Glen-Gery Corporation in Tully Township, OH, accounts for 99 percent of the ammonia as N discharges in the DMR 2008 database for the Mineral Mining Ca tegory. This subsection provides information on Glen-Gery’s ammonia as N discharges.Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-21 Table 9-18. Mineral Mining Category Top Ammoni a as Nitrogen Discharging Facilities in

DMR 2008

Facility Name Location Pounds of

Ammonia as N

Discharged Ammonia as N

TWPE Percentage of Mineral Mining Category

Ammonia as N

DMR 2008

TWPE

Glen-Gery Corporation Tully Township, OH 9,900,000 11,000 99

Remaining Mineral Mining Ammonia as N Dischargers a NA 24,400 27.2 1.3%

Total 10,030,000 11,100 100%

Source: DMRLoads2008_v2

. a – There are 35 remaining mineral mining facilities that have ammonia as N discharges in DMRLoads2008_v2 that account for approximately 1.3 percent of the Minera l Mining Category’s 2008 ammonia as N TWPE. NA – Not applicable.



### Glen-Gery discharges ammonia as N through outfall 002. Table 9-19 presents GlenGery’s 2008 quarterly ammonia as N and flow di scharge data in the DMR Loadings Tool for outfall 002. EPA compared the concen tration and flow data from the DMR Loadings Tool to the

data in Envirofacts and determined that there is a unit of measurement error for the outfall 002 flows. The flows in the DMR Loadings Tool were 1,000,000 times higher than the data in Envirofacts, also presented in Table 9-19 . Using the outfall 002 flow s from Envirofacts, GlenGery’s ammonia as N discharges are 6.31 pounds and 0.004 TWPE for 2008, reducing the facility’s total TWPE by 99 percent. This reduction in TWPE decreases the Mineral Mining Category’s 2008 DMR TWPE by 11,000 TWPE, and am monia as N would no longer be a top pollutant of concern.

Table 9-19. Glen-Gery Corporation’s 2008 Quar terly Ammonia as N and Flow Discharge

Data

Outfall Monitoring Period

Date DMR Loadings Tool

Maximum Sulfide Concentration (mg/L) DMR Loadings Tool Average Flow (MGD) Envirofacts Flow (MGD)

002 31-Mar-08 6.88 500 0.005

002 30-Jun-08 0.03 500 0.005

002 31-Aug-08 0.19 500 0.005

0 02 31-Dec-08 1 8.6 500 0 .005

S ource: DMR Loadings Tool and Envirofacts.



### 9.7 Mi neral Mining Category Conclusions

Based on available data, the estimated t oxicity of the Mineral Mining Category discharges in the screening-level databases re sult from sulfide, fluoride, and ammonia as N discharges. Data collected for the 2010 annual re view demonstrated that wastewater discharge characteristics for this category are consistent with discharges from prior years. As in prior years, EPA makes the following conclusions:Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-22 • 

### Th e 2008 sulfide discharge from U.S. Silic a was restricted to a single month, and the facility has not reported any sulf ide discharges since January 1, 2008. EPA does not consider this pollutant a concern at this time, but will review the discharges for sulfide as part of future annual reviews.

• 

### The fluoride discharges in the Minera l Mining Category are from phosphate and feldspar mining facilities regulated by Subpart R – Phosphate Rock and Subpart AI – Feldspar (reserved), respectively. Th ese facilities are also located in areas with naturally occurring fluoride com pounds in the ore, Florida and North

Carolina.

• 

### Th e fluoride discharges from phosphate mines were misrepresented in the screening level databases:

— Th e majority of the fluoride disc harges from PCS Phosphates White Springs and PCS Phosphates White Sp rings (Jasper) represented surface water monitoring stations, not proces s wastewater outfalls. Excluding the fluoride discharges from these ou tfalls reduces the Mineral Mining Category’s fluoride TWPE by 8,010 TWPE. In addition, fluoride

concentrations measured at these surface water outfalls were below the FL DEP water quality criteria for Class I II predominately fresh surface water.

— The US Agri-Chemicals’ operations do not meet the applicability of the Mineral Mining Category. The facility’s operations meet the applicability of the Fertilizer Manufacturing and/or Phosphate Manufacturing Categories. EPA will review the facili ty’s discharges in future annual reviews and will reassign this f acility to the correct category.

As a re sult, EPA will collect additional data on fluoride discharges from mineral mining facilities for consideration during the 2011 annual review.

• 

### Feld spar Corporation appears to be exceeding its mass based fluoride permit limits. Subpart AI – Feldspar of the Mi neral Mining Category does not currently regulate fluoride discharges. Permit lim it exceedances do not warrant the need for further regulation but rather better facility compliance. EPA will continue to monitor fluoride discharges from Feldspar Corporation.

• 

### Data base errors were identified for discha rges of ammonia as N. After correcting these errors, the Mineral Mining Categor y TWPE from ammonia as N decreased by 99 percent, from 11,100 TWPE to 100 TWPE and does not represent a hazard priority.

Bas ed on the above conclusions, EPA is assigni ng this category with a lower priority for revision (i.e., this category is marked with “(5)” in the “Findings” column in Table V-1 in the Federal Register notice that presents the 2009 an nual review of existing effluent guidelines and pretreatment standards).Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-23 9.8 Mineral Mining Category References

1. F L DEP. 2003a. Florida Department of Environmental Protection. National Pollution Discharge System Permit NPDES – FL0036226 – PCS Phosphates White Springs. White Springs, FL. (May 27). EPA-HQ-OW-2004-0032-1169.

2

. FL DEP. 2003b. Florida Department of E nvironmental Protection. National Pollution Discharge System Permit NPDES – FL0000665 – PCS Phosphates White Springs (Jasper). Jasper, FL. (May 27). EPA-HQ-OW-2008-0517 DCN 07283.

3

. FL DEP. 2004. Florida Department of E nvironmental Protection. National Pollution Discharge System Permit NPDES – FL0001902 – U. S. Agri-Chemicals Corporation. Fort Meade, FL. (January 26). EPA-HQ-OW-2008-0517 DCN 07285.

4

. GCIP. 2002. General Chemical Industrial Products. Chapter 14 – Wastewater and Water Treatment. Available online at: http://www.genchem.com/calcium/NCh14.html. Date accessed: July 27, 2006. EPA-HQ-OW-2004-0032-2606.



### 5

. MDEQ. 2005. Michigan Depart of Environm ental Quality. National Pollution Discharge Elimination System Permit NPDES – MI000136 8 – U.S. Silica. Rockwood, MI. (October 1). EPA-HQ-OW-2008-0517 DCN 07287.

6

. Ionics. Unknown. “The EnChem® Process for Fluoride Removal.” Wastewater

Treatment for the Microelectroni cs Industry. Available online at: http://www.iconics.com/pdf/TS4752EUS.pdf. Date accessed: July 27, 2006. EPA-HQOW-2004-0032-2605.

7

. NC DWQ. 2006. North Carolina Division of Water Quality. National Pollution Discharge Elimination System Permit NPDES – NC00003 53 – Feldspar Corporation. Spruce Pine, NC. (August 31). EPA-HQ-OW-2008-0517 DCN 07289.

8

. U.S. Census. 2002. U.S. Economic Census. Available online at: http://www.census.gov/econ/census02.

9. U .S. EPA. 1974. Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Basic Fertilizer Chemicals Segment of the Fertilizer Manufacturing Point Source Category . EPA-440/1-75/042-a. Washington, DC. (March).

10

. U.S. EPA. 1976. Development Document for Interim Final Effluent Limitations Guidelines and Standards of Performan ce for the Mineral Mining and Processing Industry . EPA-440-1-76-059-a. Washington, DC. (June).

11. U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program

Plan . EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346 through 1352.Section 9 – Mineral Mining and Processing (40 CFR Part 436)



### 9-24 12. U.S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program

Plan . EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.

13. WC&E. 2006. Wastech Controls & Engineerin g, Inc. Fluoride Wastewater Treatment (FWT) (HF Neutralization or Fluor ide Reduction. Available online at: http://www.wastechengineering.com/papers/h f.htm. Date accessed: July 27. EPA-HQOW-2004-0032-2604.Section 10 – Oil & Gas Extraction (40 CFR Part 435)



### 10-1 10. O IL 

### & G AS 

### E XTRACTION 

### (40 CFR P ART 

### 435)

EPA selected the Oil and Gas Extraction (Oil and Gas) Category for preliminary review because it ranks high, in terms of TWPE, in point source category rankings (see Table 5-3 for the point source category rankings). This section summarizes the results of the 2010 annual review associated with the Oil and Gas Category. EPA fo cused on discharges of sulfide from one oil extraction facility, because of its high toxic-weighted pound equiva lent (TWPE) relative to the

other facilities in the Oil and Gas Category. EPA also reviewed stakeholder comments regarding hydraulic fracturing to retrieve shale gas (see Table 2-1). The Final 2006 Plan summarizes the results of EPA’s previous review of this i ndustry, specifically the coalbed methane (CBM) sector, in 2004 and 2005 (71 FR 76644). See Sec tion 16.2 of this document for information on EPA’s detailed study of the CBM sector.

10.1 Oil and Gas Category Background

This subsection provides the background on the Oil and Gas Category including a brief profile of the oil and gas industr y and background on 40 CFR Part 435.

10.1.1 Oil and Gas Industry Profile

The oil and gas industry include s facilities that explore, dr ill, and produce oil or gas, along with the support operations. The explor ation process consists of mapping, aerial photography, special surveys to find underground c onditions favorable to oil or gas deposits, and exploratory drilling. The drilling pro cess includes drilling to reach oil or gas reservoirs or to gain knowledge of geologic formations. The production includes separating the fluid fractions (e.g., gas from liquid, oil from water), treating the wa stes, and further processing to improve the separations (U.S. EPA, 1976). EPA considered the following two North American Industry Classification System (NAICS) codes as part of the Oil and Gas Category.

• 

### 211111: Crude Petroleum and Na tural Gas Extraction; and

• 

### 213112: Support Activities for Oil Gas Operations.

Because the Permit Compliance System (PCS ) and Integrated Compliance Information System – National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the sources of the discharg e monitoring report (DMR) data used to develop DMRLoads2008 , report facilities by Standard Industrial Classification (SIC) code, and the U.S. Economic Census and Toxics Release Inventory (TR I) report data by NAICS code, EPA reclassified the 2008 DMR data by the equivalent NAICS code. Table 10-1 lists the number of facilities from the U.S. Census and the screening-level databases for th e two NAICS codes with operations in the Oil and Gas Category, including the corresponding SI C codes for reference. Because the only facility listed in the 2008 TRI database for the Oil and Gas Category does not report water discharges, the remaining sections for this cat egory review will focus on the data in the 2008

DMR database. The U.S. Economic Census include s more facilities than the screening-level databases because of many possible factors in cluding: facilities may not meet TRI-reporting thresholds, facilities may discharge to a pub licly owned treatment works (POTW), and some

facilities in the U.S. Economic Census are distri butors or sales faciliti es, not manufacturers.Section 10 – Oil & Gas Extraction (40 CFR Part 435)



### 10-2 Table 10-1. Number of Oil and Gas Facilities

NAICS Code Corresponding SIC

Code Number of Facilities

2002 U.S.

Economic Census 2008 DMR

Database a 2008 TRI

Database b

211111 Crude Petroleum

and Natural Gas Extraction 1311: Crude Petroleum

and Natural Gas 7,227 2,899 0

213112 Support Activities for Oil and Gas Operations 1381: Drilling Oil and Gas Wells;

1382: Oil and Gas Field Exploration;

1389: Oil and Field Services, NEC; 4925: Mixed, Manufactured, or Liquid Gas Production 6,367 407 1 c

Total >13,594 3,306 1

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2 ; and TRIReleases2008_v3

.a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore EPA used an NAICS-to-SICcode crosswalk for comparison purposes. b – Releases to any media. c – Note this facility did not report water discharges in 2008.



### Table 6-2 shows whether permitting authorities designated direct discharges as minor or major (see Section 4.1.5 ) for facilities in the Oil and Gas Category. EPA included data for minor discharges for the first time in the 2010 annual review, as part of DMRLoads2008_v2 database. EPA does not require permitting authorities to submit DMR data for minor discharges; however, many states do provide complete DMR data for th em. From this year’s review, EPA observed many data entry or other errors for minor discharg es in addition to those previously identified for major discharges, as discussed in Section 4.3

. Table 10-2 shows that more than 99 percent of the Oil and Gas Category dischargers in the 2008 DMR database are minor dischargers. Table 10-3

shows the number of facilities with and w ithout discharge data in the 2004, 2007, and 2008

DMR databases.

Table 10-2. Number of Oil and Gas Facilities by Discharge Type in DMR 2008

NAICS Code a Number of Facilities in 2008 DMR Database

Major Dischargers Major Dischargers Major Dischargers

211111 Crude Petroleum and Natural Gas

Extraction 8 2,891 2,899

213112 Support Activities for Oil and Gas Operations 1 406 407

Total 9 3,297 3,306

Source: DMRLoads2008_v2

. a – DMR data is reported by SIC code; therefore EPA used an NAICS to SIC crosswalk for comparison purposes.Section 10 – Oil & Gas Extraction (40 CFR Part 435)



### 10-3 Table 10-3. Number of Oil and Gas Facilities in DMR Databases for Reporting Years 2004, 2007, and 2008 a

Discharge Status 2004 2007 2008

With Water Discharge Data b 3 5 135

Without Water Discharge

Data c 291 1,569 3,171

Total 294 1, 574 3,306

Source: PCSLoads2004_v3 ; DMRLoads2007_v4 ; and DMRLoads2008_v2

. a – Major and minor dischargers.

b – Includes facilities with DMR data in the DMR databases. c – Includes facilities with NPDES permits without DMR data in the DMR databases.



### 10.1.2 40 CFR Part 435

EPA first promulgated effluent limitation guide lines and standards (ELGs) for the Oil and Gas Category (40 CFR Part 435) on April 13, 1979 (40 FR 22069). Best available technology (BAT) , best current technology (BCT), and new source performance standards (NSPS) limitations were promulgated on March 4, 1993 (58 FR 12454) for Subpart A: Offshore Subcategory and on December 16, 1996 (61 FR 66086) for Subpart D: Coastal Subcategory.

Table 10-4 lists the existing subcateg ories for the Oil and Gas Ca tegory and describes their applicability. Subpart B is reserved.

Table 10-4. Subcategories in the Oil and Gas Category

Subpart Title Description

A Offshore Applicable to facilities engaged in field exploration, drilling, well production, and well

treatment that are located in waters that are offshore. Offshore is defined as seaward of the inner boundary of the territorial seas.

C Onshore Applicable to facilities engaged in field exploration, drilling, well completion, and well

treatment that are located on shore. Onshore is defined as landward of the inner boundary of the territorial seas.

D Coastal Applicable to facilities engaged in field exploration, drilling, well production, and well

treatment that are located in coastal waters. Coastal is defined as landward of the inner boundary of the territorial seas or landward of the inner boundary of the territorial seas and bounded on the inland side by the line defined by the inner boundary of the

territorial seas.

E Agricultural

and Wildlife

Water Use Applicable to onshore facilities engaged in field exploration, drilling, well completion,

and well treatment that are located in the Un ited States west of the 98th meridian for which the produced water has a use in agriculture or wildlife propagation when discharged to navigable waters.

F Stripper a Ap plicable to onshore facilities engaged in production and well treatment that produce 10 barrels per well per calendar day or less of crude oil and are operating at the maximum feasible rate of production.

G General

Provisions a Prevents oil and gas facilities applicable to 40 CFR Part 435 Subparts A through F from circumventing the ELGs by moving effluent discharges from one subcategory to another for disposal under less stringent requirements.

Source: Development Document for Interim Final Effluent Limitations Guid elines and Proposed New Source Performance Standards for the Oil and Gas Extraction Point Source Category (U.S. EPA, 1976). a – No pollutants are regulated in Subparts F or G.Section 10 – Oil & Gas Extraction (40 CFR Part 435)



### 10-4 10.2 Oil and Gas Category 2010 Screening-Level Review

Table 10-5 compares the screening-level database results for the Oil and Gas Category from the 2006 through 2010 annual reviews. Th e combined DMR and TRI TWPE increased from discharge years 2007 to 2008. The estimated 2008 DMR TWPE dominates the estimated 2008 category TWPE because no fac ilities reported water discharg es to TRI in 2008, similar to

2007.

Table 10-5. Oil and Gas Category TRI and DMR Discharges for the 2006 through 2010 Screening-Level Reviews

Year of Discharge Year of Review Oil and Gas Category

TRI TWPE DMR TWPE a Total TWPE

2002 2006 700 1.18 701

2004 2007 596 17.8 614

2005 2008 802 NA NA

2007 2009 NR 255 255

2008 2010 NR 189,000 189,000

Source: TRIReleases2002_v4 ; PCSLoads2002_v4 ; TRIReleases2004_v3 ; PCSLoads2004_v3 ; TRIReleases2005_v2 ; TRIReleases2007_v2 ; DMRLoads2007_v4 ; TRIReleases2008_v3 ; and DMRLoads2008_v2

. a – DMR data from 2002 through 2007 include only major dischargers. DMR 2008 data include both minor and major dischargers. NA – Not applicable. EPA did not evaluate DMR data for 2005. NR – Not Reported. No facilities reported water discharges to TRI for reporting years 2007 and 2008.



### Table 10-6 presents the 2008 DMR TWPE by f acility discharge classification. EPA excluded minor dischargers from previous annual reviews, but included them in the 2010 annual review. The majority (over 99 pe rcent) of the TWPE in the 2008 DMR database results from minor dischargers.

Table 10-6. Oil and Gas Category 2008 DMR TWPE by Discharge Classification

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers

2008 189,000 36.1

Source: DMRLoads2008_v2

. a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous

annual reviews.



### 10.3 Oil and Gas Pollutants of Concern

Table 10-7 lists the five pollutants with the hi ghest TWPE in DMR data from reporting years 2008, 2007, and 2004 ( DMRLoads2008_v2

, DMRLoads2007_v3 , and PCSLoads2004_v4 ). EPA is not presenting the top pollutants for th e TRI databases because no facilities reported water discharges to TRI in 2007 or 2008.Section 10 – Oil & Gas Extraction (40 CFR Part 435)10-5Table 10-7. Oil and Gas Category Top DMR PollutantsPollutant2004 DMR Databasea2007 DMR Databasea2008 DMR DatabasebRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPESulfidePollutants not reported in the top five 2004DMR reported pollutants.Pollutants not reported in the top five2007 DMR reported pollutants.13170,000Aluminum227,550Chloride3127,340Fluoride422,250Cyanide52871Arsenic1186.2Pollutants not reported in the top five2008 DMR reported pollutants.Lead410.0732460.8Copper510.0693349.0SilverPollutant not reported in the top five 2004DMR reported pollutants.4131.7Chlorine1111.25124.6Zinc214.91Pollutants not reported in the top five2007 DMR reported pollutants.Sulfide311.61Oil and Gas CategoryTotalNA2c17.8NA5c256NA52c189,000Source:PCSLoads2004_v4;DMRLoads2007_v3; andDMRLoads2008_v2.a – 2004 and 2007 DMR data include only major dischargers.b – 2008 DMR data include major and minor dischargers.c – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 10 – Oil & Gas Extraction (40 CFR Part 435)



### 10-6 Sulfide is the top DMR-reported pollutant in 2008, contributing approximately 90 percent of the total category TWPE for 2008. EPA’s additi onal review for sulfide is presented in the following subsection. EPA did not investigate the ot her top pollutants as part of the 2010 annual review because the remaining TWPE is such a sm all percentage (10 percen t) of the 2008 Oil and Gas Category combined DMR and TRI TWPE.

10.4 Oil and Gas Category Sulfide Discharges in DMR

The 2010 annual review of the Oil and Gas Cate gory focused on sulfide discharges in the

2008 DMR database. Table 10-8 presents the three facilities that report sulfide discharges in the 2008 DMR database. The majority (99 percent) of the sulfide discharges in 2008 were from Marathon Oil Maverick Springs in Fremont Coun ty, WY. EPA did not review discharges from

the other two facilities because they account for only 1 percen t of the remaining 2008 Oil and Gas Category’s sulfide TWPE.

Sulfide may be generated during the stripp ing process to remove hydrogen sulfide (H 2 

### S), which can be naturally occurring in small amounts in crude petroleum. These trace amounts can make the petroleum extremely toxic and corrosive, which is referred to as “sour crude”. The sour crude must be “sweetened” to protect personnel, mitigate corrosion, and meet sale specifications (Manning and Thompson, 1995).

Removing the H 2 

### S is usually achieved by stripping with cold or hot natural gas. Because

the H 2 

### S is volatile, the compound accompanies the va por in a gas-oil separation. Due to the extremely toxic characteristics of H 2 

### S, the resulting overhead gas cannot be vented. Therefore, water is usually used to strip the gas of H 2 

### S. This process will produce sour water. In water, H 2 

### S

can form a weak acid made of two ions HS – 

### and S 2- 

### (Manning and Thompson, 1995). This stripping process could result in the discharge of sulf ide from this facility.

Table 10-8. Oil and Gas Category Top Sulfide Discharging Facilities in the 2008 DMR

Database

Facility Name Facility Location 2008

Pounds of Sulfide Discharged Sulfide

TWPE Percentage of Oil and Gas Category Sulfide

2008 DMR TWPE

Marathon Oil Maverick Springs Fremont County,

WY 60,600 169,800 99%

Soap Creek Oil Field St. Xavier, MT 107 300 < 1%

Petro Gas Liquids Processing Corpus Chrisi, TX 5.79 16 < 1%

Total 60,700 170,000 100%

Source: DMRLoads2008_v2

.



### Marathon Oil Maverick Springs

The Marathon Oil Maverick Spri ngs facility, located in Fr emont County, WY, is a crudeoil refiner. The facility is w ithin the exterior boundaries of the Wind River Indian Reservation. The facility fact sheet indicates that the limits were devel oped based on Subparts C and E of the Oil and Gas Category (WDEQ, 2007b). Table 10-9 presents the sulfide concentration data for Marathon Oil Maverick Springs.Section 10 – Oil & Gas Extraction (40 CFR Part 435)



### 10-7 Table 10-9. Marathon Oil Maverick Spr ings 2008 Sulfide Discharge Data

Outfall Monitoring Period

Date NODI Code a Maximum Concentration (mg/L) Flow (MGD)

001 30-June-07 C NR

001 31-Dec-07 9.76 1.645

001 30-June-08 C 1.633

001 31-Dec-08 24 1.645

001 30-June-09 25 1.598

001 31-Dec-09 8 1.5 76

Not e: The 2007 and 2009 discharge data are from EPA’s Envirofacts. NR – Flow not reported a – No discharge occurred for the monitoring period



### ERG contacted Marathon Oil Maverick Springs to verify the sulfide discharges for 2008. Marathon Oil Maverick Springs confirmed the 2008 sulfide concentrations and flows for outfall 001, a stormwater discharge from the facility. Marathon Oil Maverick Sp rings also confirmed that the permit does not specify a limit for sulfide (Taylor, 2010).

According to the 2007 Statement of Basis, the Marathon Oil Maverick Springs’ permit authorizes the discharge of treated wastewater at the oil producti on facility. Produced oil, water, and gas are separated in tanks by gravity, heat , and emulsion breaking chemicals. Water is discharged through settling ponds where the re maining oil is removed by floatation and skimming prior to discharge to a tributary to Five Mile Creek. The di scharge provides wildlife and stock watering opportunities. In addition, aq uatic communities have developed in this ephemeral drainage, which are dependent upon the flow of this produced water (WDEQ, 2007a).

The e ffluent guidelines and the facility perm it do not list sulfide as a regulated pollutant. However, the permit includes effluent monitoring requirements for sulfide. Sulfide is required to be monitored semi-annually.

10.5 Oil and Gas Category Conclusions

The est imated toxicity of the Oil and Gas Category discharges results mainly from the sulfide discharges of one oil extraction plant (acc ounting for 99 percent of the category’s 2008 TWPE). EPA does not believe that Marathon Oil’s sulfide discharges are representative of the Oil and Category. Without Marathon Oil’s sulfide disc harges, the Oil and Gas TWPE is not a concern. Therefore, EPA concludes the following:

• 

### The sulfide discharges in the 2008 DMR database for Marathon Oil Maverick Springs were verified and do not appear to be erroneous. This facility’s sulfide discharges are not consistent with sulfide discharges from other facilities in the category. As a result, Marathon Oil’s sulfid e discharges are best controlled by its individual permit.

EPA prioritizes point source categories with existing regulations for potential revision based on the greatest estimated toxicity to human health and the environment, measured as TWPE. Based on the above conclusions, EPA is assi gning this category with a lower priority for revision (i.e., this category is marked with “(2)” in the “Findings” column in Table V-1 in the Federal Register notice that presents the 2010 annual review of existing ELGs).Section 10 – Oil & Gas Extraction (40 CFR Part 435)



### 10-8 1 0.6 Oil and Gas Category References

1. Manning, Francis and Thompson, Richard 1995. Oilfield Processing of Petroleum: Crude

Oil . Penn Well Publishing Compa ny. EPA-HQ-OW- 2008-0517 DCN 07310.

2. Taylor, Linda. 2010. Telephone c onversation with Linda Taylor , Marathon Oil Maverick Springs, and Elizabeth Sabol, Eastern Research Group, Inc. “Sulfide Discharges Reported to DMR in 2008.” (June 3) . EPA-HQ-OW-2008-0517 DCN 07307.

3. WD EQ. 2007a. Wyoming Department of E nvironmental Quality. State of Wyoming National Pollutant Discharge Elimin ation System Permit NPDES WY0000779 – Marathon Oil Maverick Springs. Frem ont County, WY. (November) EPA-HQ-OW2008-0517 DCN 07291.

4. WDEQ. 2007b. Wyoming Department of Envi ronmental Quality. State of Wyoming National Pollutant Discharge Eliminati on System Statement of Basis NPDES WY0000779 – Marathon Oil Maverick Spri ngs. Fremont County, WY. (June) EPA-HQOW-2008-0517 DCN 07292.

5. U.S. Census. 2002. U.S. Economic Census. Available online at: http://www.census.gov/econ/census02.

6. U.S. EPA. 1976. Development Document for Interim Final Effluent Limitations Guidelines and Proposed New Source Perf ormance Standards for the Oil and Gas Extraction Point Source Category . EPA-440/1-76-055-a. Washington, DC. (September).

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

Plan . EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.Section 11 – Ore Mining and Dressing (40 CFR Part 440)



### 11-1 11. O RE 

### M INING AND 

### D RESSING 

### (40 CFR P ART 

### 440)

As di scussed in the 2008 Final Plan, EPA conducted a preliminary study of facilities covered under 40 CFR Part 440, the Ore Mining and Dressing (Ore Mining) Category to examine why toxic-weighted pollutant discharg es by the ore mining industry ranked relatively high compared to other industries in the 2002 through 2008 annual reviews. The purpose of the study was to identify, collect, and review readily available existi ng data and information on toxic pollutants in wastewater discharges to determin e whether additional analysis or revision of 40 CFR Part 440 might be warranted to better control toxic discharges.

T he preliminary study focused on active ore mines covered under 40 CFR Part 440 Subpart J: Copper, Lead, Zinc, Gold, Silver , and Molybdenum Ores. These types of mines comprise approximately 76 percent (263 ore mine s) of the approximately 345 ore mines in the

United States. Inactive ore mines were not includ ed as they are not covered by the effluent guidelines.

Appr oximately 294 ore mines currently have National Pollutant Di scharge Elimination System (NPDES) wastewater discharge permits. There is a difference between the total number of ore mines and the number with NPDES permit s because not all ore mines have wastewater discharges. The approximately 1,870 placer mine s, covered under 40 CFR Part 440 Subpart M, were not examined in this study because they employ mining practices an d wastewater streams that are fundamentally different from mines covered under the other subparts of 40 CFR Part

440.

The preliminary study examined information pe rtaining to the two t ypes of wastewater discharged by ore mines: process wastewater (including mine drainage) and stormwater. Process

wastewater is covered under 40 CFR Part 440. St ormwater is not cove red under 40 CFR Part 440 unless it is commingled with process wastewater prior to di scharge to a su rface waterbody.

The study was limited by incomplete national- level process wastewat er discharge data, and the lack of any nationally re presentative stormwater data fo r the ore mines of interest. EPA did review available ore mine-sp ecific process wastewater discha rge information, available Total Maximum Daily Load (TMDL) reports, information for ore mine site stor mwater discharges, and

an industrial wastewater trea tment technology, known as high de nsity sludge recycling, which was identified during the course of the study.

Ba sed on EPA’s review of toxic pollutant da ta, EPA found that in 2007, the most recent year for which quality-checked data are available, approximately only two percent of ore mining facilities were responsible for approximately 90 pe rcent of toxic weighted discharges by the ore mining industry for toxic pollutants.

Given that only a small percentage of activ e ore mines account for th e majority of toxic weighted discharges, this can best be addressed through permitting, compliance, and enforcement activities for the specific ore mining sources, rather than by re vision of 40 CFR Part

440.

Wh ile the available toxic pollutant data doe s not suggest that EP A revisit the ELGs for ore mining and dressing (40 CFR Pa rt 440) at this time, the Agency currently remains concerned about many other types of mining-related wate r quality impairments. EPA has a number ofSection 11 – Ore Mining and Dressing (40 CFR Part 440)



### 11-2 activities that address discharges of polluta nts from mines including: guidance on protective levels of conductivity for aquatic life in streams affected by mine discharges; plans to revise the water quality criteria for selenium; increased a ttention on compliance with, and enforcement of, individual permit limits; improved permitting guidan ce; and more stringent discharge monitoring requirements in permits.

The Ore Mining Preliminary Study Report (U.S. EPA, 2010) is being issued concurrent with the publication of the final 2010 Plan.

11 .1 Ore Mining and Dressing Category References

1. U.S. EPA. 2010. Ore Mining and Dressing Preliminary Study Report . EPA-821-R-08- 012. Washington, DC. (December). EPA-HQ-OW-2008-0517 DCN 07369.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-1 12

. O RGANIC 

### C HEMICALS 

### , P LASTICS 

### , AND 

### S YNTHETIC 

### F IBERS 

### (40 CFR P ART 

### 414)

EP A selected the Organic Chemicals, Plasti cs, and Synthetic Fibe rs (OCPSF) Category for preliminary review because it continues to rank high, in terms of toxic-weighted pound equivalent (TWPE), in point s ource category rankings (see Ta ble 5-3 for the point source category rankings). This industr y was reviewed previously in each of EPA’s Preliminary and Final Effluent Guidelines Program Plans from 2004 to 2009 (U.S. EPA, 2004; U.S. EPA, 2005a; U.S. EPA, 2006; U.S. EPA, 2007; U.S. EPA, 2008, U.S. EPA, 2009). This section summarizes

the results of the 2010 annual review associat ed with the OCPSF Category. EPA focused on discharges of hexachlorobenzen e, metals, chlorine, and polycyc lic aromatic compounds (PACs), because of their high TWPE relative to other pollutants in the OCPSF Category.

EP A is currently reviewing discharges fr om the Chlorinated Hydrocarbon Manufacturing Segment of the OCPSF Category as part of the Chlorine and Chlorinated Hydrocarbons (CCH) effluent guidelines rulemaking. Because a rulema king for this segment of the OCPSF Category is underway, EPA excluded discharges from these faci lities from further consideration in this review (see Table V-1, 70 FR 61335, October 30, 2007).

12. 1 OCPSF Category Background

This subsection provides the background on the OCPSF Category including a brief profile of the OCPSF industry a nd background on 40 CFR Part 414.

12 .1.1 OCPSF Industry Profile

The OCPSF industry includes many chemical indus tries producing a wide variety of end products, such as polypropylene, vinyl chloride and polyvinyl chloride (PVC), chlorinated solvents, rubber precursors, styrofoam additiv es, and polyester. Some OCPSF facilities are extremely complex and produce hundreds of chemical s, while others are simpler, producing one or two end products. EPA considered the following 22 North American Industry Classification System (NAICS) codes as part of the OCPSF Category:

• 

### 311 999OCPSF: All Other Miscella neous Food Manufacturing;

• 

### 32419 9OCPSF: All Other Petroleum and Coal Products Manufacturing;

• 

### 325110: Petrochemical Manufacturing;

• 

### 325120OCPSF: Industrial Gas Manufacturing;

• 

### 325132: Synthetic Organic Dye a nd Pigment Manufacturing;

• 

### 325188OCPSF: All Other Basic Inorganic Chemical Manufacturing;

• 

### 325192: Cyclic Crude and Inte rmediate Manufacturing;

• 

### 325193: Ethyl Alcohol Manufacturing;

• 

### 325199: All Other Basic Organi c Chemical Manufacturing;

• 

### 325211: Plastics Material a nd Resin Manufacturing;

• 

### 325221: Cellulosic Organi c Fiber Manufacturing;

• 

### 325222: Noncellulosic Organi c Fiber Manufacturing;

• 

### 325510OCPSF: Paint and Coating Manufacturing;

• 

### 325520: Adhesive Manufacturing;

• 

### 325611OCPSF: Soap and Other Detergent Manufacturing;

• 

### 325612: Polish and Other Sani tation Good Manufacturing;

• 

### 325620: Toilet Preparation Manufacturing;Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-2 • 

### 325998: All Other Miscellaneous Ch emical Product and Preparation Manufacturing;

• 

### 326199OCPSF: All Other Plastics Product Manufacturing;

• 

### 339999OCPSF: All Other Miscel laneous Manufacturing;

• 

### 424690: Other Chemical and Allied Products Merchant Wholesalers; and

• 

### 562920: Materials Reco very Facilities.

W astewater generated by fac ilities in NAICS codes 311999, 324199, 325120, 325188, 325510, 325611, 326199, 339999 may be regulated under multiple categories. For example, most facilities in NAICS code 324199 are gr ouped under the Petroleum Refining Effluent Limitation Guidelines and Standards (ELGs). EPA reviewed available information about pollutant loads and manufacturing operations fo r facilities reporting these NAICS codes. EPA assigned the extension “OCPSF” to the end of the NAICS codes of facilities that most likely fall under the applicability of the OCPSF ELGs (40 CFR Part 414).

This list of Standard Industrial Classificat ion (SIC) codes includes facilities that EPA determined are potential new subcategories of the OCPSF Category. As part of the 2004 annual review, EPA reviewed industrie s with SIC codes not clearly subject to existing ELGs. EPA concluded that the processes, ope rations, wastewaters, and pollutant s of facilities in the eight SIC

codes are similar to those of the OCPSF Category (U.S. EPA, 2004): 18

• 

### 2821: Plastics Materials, Synthetic and Resins, and Nonvulcanizable Elastomers;

• 

### 2824: Manmade Organic Fibe rs, Except Cellulosic;

• 

### 2842: Specialty Cleaning, Polishing, and Sanitation Preparations;

• 

### 2844: Perfumes, Cosmetics, and Other Toilet Preparations (except toothpaste, gel, and dentifrice powders);

• 

### 2869: Industrial Organic Chemicals, NE C (cyclopropane, diethylcyclohexane, naphthalene sulfonic acid);

• 

### 2891: Adhesives and Sealants;

• 

### 2899: Chemicals and Chemical Prep arations, NEC (table salt); and

• 

### 5169: Chemicals and Allied Products , NEC (merchant wholesalers).

A s part of the 2009 annual review, EPA reclassified these SIC codes as equivalent NAICS codes

for use with the U.S. Economic Census and T oxics Release Inventory (TRI) data that are reported by NAICS code (U.S. EPA, 2009). However, there is not a direct relationship between one SIC and one NAICS code. As a result, EP A included the following NAICS codes in the

2010 annual review of the OCPSF Ca tegory because they contain facilities with ope rations that

are similar to the SIC codes above:

• 

### 311999OCPSF: All Other Miscella neous Food Manufacturing;

• 

### 325188OCPSF: All Other Basic Inorganic Chemical Manufacturing;

• 

### 325199: All Other Basic Organi c Chemical Manufacturing;

• 

### 325222: Noncellulosic Organi c Fiber Manufacturing;

18 The tables in this section include discharge information from facilities reporting these SIC codes and the corresponding NAICS codes; however, these facilities contribute negligible amounts of TWPE. Consistent with the conclusions drawn during the 2004 detailed study (U.S. EPA, 2004) and 2006 review (U.S. EPA, 2006), EPA found that large numbers of these facilities discharge no wastew ater and only a small number of facilities discharge TWPE greater than zero.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-3 • 

### 325510OCPSF: Paint and Coating Manufacturing;

• 

### 325520: Adhesive Manufacturing;

• 

### 325611OCPSF: Soap and Other Detergent Manufacturing;

• 

### 325620: Toilet Preparation Manufacturing;

• 

### 325998: All Other Miscellaneous Ch emical Product and Preparation Manufacturing;

• 

### 326199OCPSF: All Other Plastics Product Manufacturing;

• 

### 339999OCPSF: All Other Miscella neous Manufacturing; and

• 

### 424690: Other Chemical and Allied Products Merchant Wholesalers.

Because the Permit Compliance System (PCS ) and Integrated Compliance Information System – National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the sources of the discharg e monitoring report (DMR) data used to develop DMRLoads2008 , report facilities by SIC code and the U.S. Economic Ce nsus and TRI report data by NAICS code, EPA

reclassified the 2008 DMR data by the equivalent NAICS code. Table 12-1 lists the number of

facilities from the U.S. Economic Census and th e screening-level databases for the 22 NAICS codes with operations in the OCPSF Category the corresponding SIC codes are included for

reference. The U.S. Economic Census includes more facilities than the screening-level databases because of many possible factors including: f acilities may not meet TRI-reporting thresholds, facilities may discharge to a public ly owned treatment works (POTW) , and some facilities in the

U.S. Economic Census are distributors or sales facilities, not manufacturers.

Table 12-1. Number of OCPSF Facilities

NAICS Code SIC Code Number of Facilities

2002 U.S.

Economic

Census 2008 DMR

Database a 2008 TRI

Database b

311999OCPSF: All Other Miscellaneous Food Manufacturing 2821:Plastics Materials, Synthetic and Resins,

and Nonvulcanizable

Elastomers 2824:Manmade Organic Fibers, Except

Cellulosic 2842: Specialty Cleaning, Polishing,

and Sanitation Preparations 2844: Perfumes, Cosmetics, and Other Toilet Preparations (toothpaste, gel, and dentifrice powders) 2865: Cyclic Organic

Crudes and

Intermediates and Organic Dyes and Pigments (except aromatics and organic NA

929 2

324199OCPSF: All Other Petroleum and Coal Products Manufacturing NA 1

325110: Petrochemical Manufacturing 56 67

325120OCPSF: Industrial Gas Manufacturing NA 2

325132: Synthetic Organic Dye and Pigment Manufacturing 123 32

325188OCPSF: All Other Basic Inorganic Chemical Manufacturing NA 1

325192: Cyclic Crude and Intermediate Manufacturing 37 20

325193: Ethyl Alcohol Manufacturing 72 153

325199: All Other Basic Organic Chemical Manufacturing 685 379

325211: Plastics Material and Resin Manufacturing 690 348

325222: Noncellulosic Organic Fiber Manufacturing 95 25Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-4 Table 12-1. Number of OCPSF Facilities

NAICS Code SIC Code Number of Facilities

2002 U.S.

Economic

Census 2008 DMR

Database a 2008 TRI

Database b

325510OCPSF: Paint and Coating Manufacturing dyes and pigments)

2869: Industrial Organic Chemicals, NEC (fluorocarbon gases);

891: Adhesives and

Sealants

2899: Chemicals and Chemical Preparations, NEC (table salt) NA 7

325520: Adhesive Manufacturing 595 151

325611OCPSF: Soap and Other Detergent Manufacturing NA 12

325612: Polish and Other Sanitation Good Manufacturing 604 84

325620: Toilet Preparation Manufacturing 867 26

325998: All Other Miscellaneous Chemical Product and Preparation Manufacturing 1,188 311

326199OCPSF: All Other Plastics Product Manufacturing NA 3

339999OCPSF: All Other Miscellaneous Manufacturing NA 2

562920: Materials Recovery Facilities 947 32

424690: Other Chemical and Allied Products

Merchant Wholesalers 5169: Chemicals and Allied Products, NEC (merchant wholesalers) 11,158 94 443

325221: Cellulosic Organic Fiber Manufacturing 2823: Cellulosic

Manmade Fibers 8 4 4

Total > 17,125 1,027 2,105
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); TRIReleases2007_v2 ; and DMRLoads2007_v2

. a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an NAICS to SIC crosswalk for comparison purposes. b – Releases to any media. NA – Not applicable.



### Table 9-2 shows whether permitting authorities designated direct dischargers as minor or major (see Section 4.1.5 ) for facilities in the OCSPF Category. EPA included data for minor dischargers for the first time in the 2010 annual review, as part of DMRLoads2008_v2 database. EPA does not require permitting authorities to submit DMR data for minor dischargers; however, many states do provide complete DMR data for th em. From this year’s review, EPA observed many data entry or other errors for minor discha rgers in addition to those previously identified for major dischargers, as discussed in Section 4.3

. Table 12-2 shows that approximately 78 percent of the OCPSF Category dischargers in the 2008 DMR database ar e minor dischargers.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-5 Table 12-2. Number of OCPSF Facilities by Discharge Classification in 2008 DMR

Database

NAICS Code a Number of Facilities in 2008 DMR

Major Dischargers Minor Dischargers All Dischargers

311999OCPSF All Other Miscellaneous Food Manufacturing

219 710 929 324199OCPSF All Other Petroleum and Coal Products Manufacturing

325110 Petrochemical Manufacturing

325120OCPSF Industrial Gas Manufacturing

325132 Synthetic Organic Dye and Pigment Manufacturing

325188OCPSF All Other Basic Inorganic Chemical Manufacturing

325192 Cyclic Crude and Intermediate Manufacturing

325193 Ethyl Alcohol Manufacturing

325199 All Other Basic Orga nic Chemical Manufacturing

325211 Plastics Material and Resin Manufacturing

325222 Noncellulosic Organic Fiber Manufacturing

325510OCPSF Paint and Coating Manufacturing

325520 Adhesive Manufacturing

325611OCPSF Soap and Other Detergent Manufacturing

325612 Polish and Other Sanitation Good Manufacturing

325620 Toilet Preparation Manufacturing

325998 All Other Miscellaneous Chemical Product and Preparation Manufacturing

326199OCPSF All Other Plastics Product Manufacturing

339999OCPSF All Other Miscellaneous Manufacturing

562920 Materials Recovery Facilities

424690 Other Chemical and Allied Products Merchant

Wholesalers 2 92 94

325221 Cellulosic Organic Fiber Manufacturing 2 2 4

Total 223 804 1,027

Source: DMRLoads2008_v2

. a – DMR data is reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison

purposes.



### Table 12-3 presents the type of discharges reporte d by facilities in the 2008 TRI database. The majority of OCPSF facilities reporting to TR I do not report water disc harges, but those that do mostly reported discharging indirectly.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-6 Table 12-3. Number of OCPSF Facilities by Type of Discharger in TRI 2008

NAICS Code Number of Facilities in TRI 2008 Database

Direct Dischargers Only Indirect Dischargers Only Both Indirect

and Direct No Water Discharges

311999OCPSF: All Other Miscellaneous Food Manufacturing 0 2 0 0

324199OCPSF: All Other Petroleum and Coal

Products Manufacturing 0 0 1 0

325110: Petrochemical Manufacturing 30 15 1 21

325120OCPSF: Industrial Gas Manufacturing 1 0 0 1

325132: Synthetic Organic Dye and Pigment Manufacturing 3 18 0 11

325188OCPSF: All Other Basic Inorganic

Chemical Manufacturing 0 1 0 0

325192: Cyclic Crude and Intermediate Manufacturing 9 4 2 5

325193: Ethyl Alcohol Manufacturing 4 6 1 142

325199: All Other Basic Organic Chemical Manufacturing 73 126 17 163

325211: Plastics Material and Resin Manufacturing 61 80 23 184

325222: Noncellulosic Organic Fiber Manufacturing 6 9 0 10

325510OCPSF: Paint and Coating Manufacturing 0 6 1 0

325520: Adhesive Manufacturing 4 20 0 127

325611OCPSF: Soap and Other Detergent Manufacturing 0 11 0 1

325612: Polish and Other Sanitation Good Manufacturing 1 20 0 63

325620: Toilet Preparation Manufacturing 0 14 1 11

325998: All Other Miscellaneous Chemical Product and Preparation Manufacturing 14 48 6 243

326199OCPSF: All Other Plastics Product Manufacturing 0 2 1 0

339999OCPSF: All Other Miscellaneous Manufacturing 0 0 1 1

562920: Materials Recovery Facilities 0 1 0 31

424690: Other Chemical and Allied Products

Merchant Wholesalers 6 27 0 410

325221: Cellulosic Organic Fiber Manufacturing 2 0 0 2

Total 2 14 4 10 5 5 1,426

Source: TRIReleases2008_v3

.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-7 12.1.2 40 CFR Part 414

EPA first promulgated ELGs for th e OCPSF Category (40 CFR Part 414) on November 5, 1987 (52 FR 42568). This category consis ts of seven subcate gories that apply to the manufacture of products a nd product groups, as shown in Table 12-4 with corresponding SIC codes and applicability. Subparts B through H have limitations for biochemical oxygen demand (BOD 5 

### ), total suspended solids (TSS), and pH. The regulation also include s limitations and/or pretreatment standards for certain toxic pollutants in three additional subparts:

• 

### Subpart I — Direct Discharge Point Sour ces That Use End-of-Pipe Biological Treatment;

• 

### Subpart J — Direct Discharge Point S ources That Do Not Use End-of-Pipe Biological Treatment; and

• 

### Subpart K — Indirect Discharge Point Sources.

Table 12-4. Applicability of Subcat egories in the OCPSF Category

Subpart Subcategory Title Corresponding SIC Code(s) a Subcategory Applicability

B Rayon Fibers 2823: Cellulosic Manmade Fibers Cellulosic manmade fiber (Rayon) manufactured by the Viscose process.

C Other Fibers 2824: Synthetic Organic Fibers, Except Cellulosic All other synthetic fibers (except Rayon) including, but not limited to, products listed in Section 414.30.

D Thermoplastic Resins 28213: Thermoplastic Resins Any plastic product classified as a thermoplastic resin including, but not limited to, products listed in Section

414.40.

E Thermosetting Resins 28214: Thermosetting Resins Any plastic product classified as a thermosetting resin including, but not limited to, products listed in Section

414.50.

F Commodity Organic

Chemicals 2865: Cyclic Crudes and Intermediates, Dyes and Organic Pigments 2869: Industrial Organic Chemicals, NEC Commodity organic chemicals and commodity organic chemical groups including, but not limited to, products

listed in Section 414.60.

G Bulk Organic

Chemicals 2865: Cyclic Crudes and Intermediates, Dyes and Organic Pigments 2869: Industrial Organic Chemicals, NEC Bulk organic chemicals and bulk organic chemical groups including, but not limited to, products listed in

Section 414.70.

H S pecialty Organic

Chemicals 2865: Cyclic Crudes and Intermediates, Dyes and Organic Pigments 2869: Industrial Organic Chemicals, NEC All other organic chemicals and organic chemical groups including, but not limited to, products listed in the OCPSF Development Document (Vol. II, Appendix II-A, Table VII).

Source: Product and Product Group Discharges Subject to Effluent Limitations and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category — 40 CFR 414 , Table 2-2 (U.S. EPA, 2005b). a – During the 2009 annual review EPA developed a cros swalk between SIC codes and NAICS codes. Because there is not a direct match EPA did not report NAICS codes.

NEC – Not elsewhere classified.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-8 12.2 OCPSF Category 2010 Screening-Level Review

Table 12-5 compares the screening-level databa se results for the OCPSF Category from the 2006 through 2010 annual reviews. The combined DMR and TRI TWPE increased from discharge years 2002 to 2004, but decreased from discharge years 2004 to 2008. The 2008 DMR TWPE accounts for approximately 79 percent of the combined 2008 DMR and TRI TWPE, while TRI discharges dominated pr evious years’ combined TWPE.

Table 12-5. OCPSF Category TRI and DMR Discharges for the 2006 through 2010 Screening-Level Reviews

Year of Discharge Year of Review OCPSF Category

TRI TWPE DMR TWPE a Total TWPE

2002 2006 349,000 398,000 747,000

2004 2007 957,000 608,000 1,570,000

2005 2008 759,000 NA NA

2007 2009 575,000 309,000 884,000

2008 2010 137,000 512,000 649,000

Source: TRIReleases2002_v4 ; PCSLoads2002_v4 ; TRIReleases2004_v3 ; PCSLoads2004_v3 ; TRIReleases2005_v2 ; TRIReleases2007_v2 ; DMRLoads2007_v4 ; TRIReleases2008_v3 ; and DMRLoads2008_v2

. a – DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and major dischargers. NA – Not applicable. EPA did not evaluate DMR data for 2005.



### Table 12-6 presents the 2008 DMR TWPE by f acility discharge classification. EPA excluded minor dischargers from previous annual reviews, but included them in the 2010 annual review. The majority (96 percent) of the TW PE in the 2008 DMR database results from major dischargers.

Table 12-6. OCPSF Category 2008 DMR TWPE by Discharge Classification

Year of Discharge a TWPE from Minor Dischargers T WPE from Major Dischargers

2008 19,100 493,000

Source: DMRLoads2008_v2

. a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous

annual reviews.



### 12.3 OCPSF Pollutants of Concern

Table 12-7 compares the five chemicals with the highest TWPE in the 2008, 2007, and 2004 TRI databases ( TRIReleases2008_v3

, TRIReleases2007_v2 , and TRIReleases2004_ v3 ).

Table 12-8 lists the five pollutants with the highest TWPE in the 2008, 2007, and 2004 DMR databases ( DMRLoads2008_v2, DMRLoads2007_v3 , and PCSLoads2004_v4 ).Section 12 – Organic Chemicals, Plastics,and Synthetic Fibers (40 CFR Part 414)12-9Table 12-7. O.CPSF Category Top TRI PollutantsPollutant2004 TRI Dataa2007 TRI Dataa2008 TRI DataaRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPENitrate Compounds513016,200Pollutant not reported in the top five 2007TRI reported pollutants.111115,000Lead and Lead CompoundsPollutants not reported in the top five2004 TRI reported pollutants.55516,50025012,600Copper and CopperCompoundsPollutants not reported in the top five2007 TRI reported pollutants.34410,400Manganese and ManganeseCompounds42610,200Hydroquinone4617,1003418,5005510,030Dioxin and Dioxin LikeCompounds18693,00014398,000Pollutants not reported in the top five 2008TRI reported pollutants.Chlorine31522,90021327,500PACsPollutant not reported in the top five2004 TRI reported pollutants.4718,200Hexachlorobenzene2484,500Pollutant not reported in the top five 2007TRI reported pollutants.OCPSF Category TotalNA744b95,700NA594b57,500NA672b137,000Source:TRIReleases2004_v3;TRIReleases2007_v2; andTRIReleases2008_v3.a – Discharges include transfers to POTWs and account for POTW removals.b – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 12 – Organic Chemicals, Plastics,and Synthetic Fibers (40 CFR Part 414)12-10Table 12-8. OCPSF Category Top DMR PollutantsPollutant2004 DMR Dataa2007 DMR Dataa2008 DMR DatabRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPEHexachlorobenzene213123,00011362,700111124,000Chlorine44638,20024645,600210477,800NickelPollutants not reported in the top five 2004DMR reported pollutants.45823,00036859,500CopperPollutant not reported in the top five 2007DMR reported pollutants.413342,100Fluoride51228,20031335,50051628,900TinPollutant not reported in the top five 2004DMR reported pollutants.5317,500Pollutants not reported in the top five 2008DMR reported pollutants.Aluminum120209,000Pollutant not reported in the top five 2007DMR reported pollutants.Benzidine3163,800OCPSF CategoryTotalNA202c608,000NA194c309,000NA357c512,000Source:PCSLoads2004_v4;DMRLoads2007_v3; andDMRLoads2008_v2.a – 2004 and 2007 DMR data include only major dischargers.b – 2008 DMR data includes major and minor dischargers.c – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-11 The OCPSF 2008 TRI TWPE accounts for 21 percen t of the total category TWPE, while the 2008 DMR TWPE accounts for 79 percent. Theref ore, EPA focused the additional review on the DMR-reported pollu tants that account for the ma jority of the category TWPE.

EPA’s additional review for the 2008 DM R database pollutants of concern, hexachlorobenze, chlorine, and metals (nicke l and copper), is presen ted in the following

subsections. EPA also revi ewed discharges of PACs 19 

### as part of the 2010 annual review, even though they are not one of the t op five pollutants for DMR in 2008. PACs discharges have been continually monitored by EPA as part of prev ious annual reviews. During the review of top pollutants, EPA discovered that the majority of th e top pollutants were discharged from the same

three facilities in the 2008 DMR database. Table 12-9 presents the facility dischargers and corresponding top DMR pollutants discharged in the OCSPF Category.

Table 12-9. OCPSF Category Top Facility Dischargers in the DMR 2008 Database

Top Pollutant Facility Name Pounds of

Pollutant Discharged Pollutant

TWPE Total Facility

TWPE Other Top

Pollutants Discharged

Hexachlorobenzene Chevron Oronite Co. 43.8 85,300 95,600 PACs

Nickel MPM Silicones, LLC 571,000 57,100

102,000 Hexachlorobenzene,

PACs Copper MPM Silicones, LLC 36,600 23,100

Benzo(a)pyrene a E I DuPont De Nemours 196 1 9,700 44,900 Other PACs

Source: DMRLoads2007_v3 and DMRLoads2008_v2

. a – Benzo(a)pyrene is included in the gr oup of pollutants referred to as PACs.



### 12.4 OCPSF Category Top Facility Dischargers in DMR

The majority of the top pollutants for the OCSPF Category in the 2008 DMR database are discharged from the top three facility discha rgers. This subsection provides further detail on the top three facility discharg ers in the OCSPF Category responsi ble for the majority of the hexachlorobenzene, PACs, and metals TWPE. As a result of EPA’s review of discharges from the top facilities in the OCPSF Category, th e overall category 2008 DMR TWPE decreased by 239,000 TWPE.

12.4.1 Chevron Oronite Co. LLC in Belle Chasse, LA 20



### Table 12-10 presents the top five discharges in the 2008 DMR database for Chevron Oronite Co. LLC. The majority of the facility TWPE (approximately 89 percent) is from hexachlorobenzene. Hexachlorobenzene discharg es from Chevron Oronite also account for almost 17 percent of the total OCPSF Category TWPE in the 2008 DMR database. The other top

19 PACs include the following pollutants: benzo(a)anthracene, chrysene, benzo(a) pyrene, benzo(b)fluoranthene, benzo(j)fluoranthene, benzo(k)fluoranthene, fluorant hene, benzo(r,s,t)pentaphene, dibenz(a,h)acridine, dibenz(a,j)acridine, dibenzo(a,h)anthracene, dibenzo(a,e)fluoranthene, dibenzo(a,e)pyrene, dibenzo(a,h)pyrene, dibenzo(a,l)pyrene, 7H-dibenzo(c,g)car bozole, 7,12-dimethylbenz(a)anthracene, indeno(1,2,3-cd)pyrene, 3-methylcholanthrene, 5-methylchrysene, and 1-nitropyrene.

20 Chevron Oronite Co. LLC in Belle Chasse, LA has two NPIDs: LA0005738 and LAG670106. This section discusses the discharges associated with the NPID LA0005738. Discharges from LAG670106 are not included in the DMR Loadings Tool.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-12 pollutants (all PACs) are benzo(a)pyrene, chrysene, benzo(a)anthracene, and benzo(b)fluoranthene.

Table 12-10. Chevron Oronite 2008 Top Discharges

Pollutant Total Pounds Total TWPE Percentage of Facility

Total TWPE

Hexachlorobenzene 43.8 85,300 89%

Benzo(a)pyrene 43.8 4,410 4.6%

Chrysene 43.8 1,360 1.4%

Benzo(a)anthracene 43.8 1,340 1.4%

Benzo(b)fluoranthene 43.8 1,340 1.4%

Total 362,000 95,600 100%

Source: DMRLoads2008_v2

.



### All of the pollutant discharges fo r Chevron Oronite are from outfall 202. Table 12-11 presents the discharge data in the DMR Loadings Tool for 2008. EPA contacted Chevron Oronite to verify the hexachlorobenzene and PACs quantities. Chevron Oron ite indicated that the hexachlorobenzene, benzo(a)pyrene, chrysene, benzo(a)anthracene, and benzo(b)fluoranthene

concentrations were measured below the det ection limit (BDL). Further, Chevron Oronite provided discharge monitoring data that show ed all PAC concentrations in the 2008 DMR database were reported as nondetect (Sampey, 2010).

Chevron Oronite indicated that they use half the detection lim it to calculate the quantities when the pollutants are measured BDL (Sampey, 2010). Therefore, all of the quantities in the

2008 DMR database were BDL and the loads and TWPE should be zero. This correction leads to the facility’s to tal TWPE decreased from 95,600 TWPE to 40 TWPE, a reduction of over 99
percent.

Table 12-11. Chevron Oronite Outfall 202 2008 Monthly Discharge Data

Outfall Pollutant Monitoring

Period Date DMR Loadings Tool Quantity (kg/day) FacilityProvided Quantity (kg/day) Flow (MGD)

202 Hexachlorobenzene 31-Dec-08 0.0544 <0.0544 1.132

202 Benzo(a)pyrene 31-Dec-08 0.0544 <0.0544 1.132

202 Chrysene 31-Dec-08 0.0544 <0.0544 1.132

202 Benzo(a)anthracene 31-D ec-08 0.0544 <0.0544 1.132

2 02 Benzo(b)fluoranthene 31-Dec-08 0.0544 <0.0544 1.132
Source: DMR Loadings Tool and Facility Contact (Sampey, 2010).



### 12.4.2 MPM Silicones, LLC in Friendly, WV

Table 12-12 presents the top pollutant discharg es in the 2008 DMR database for MPM Silicones, LLC. The majority of the TWPE results from discharge of nickel and copper.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-13 Hexachlorobenzene and benzo(a)pyrene are the 3 rd 

### and 4 th 

### ranking pollutants, by TWPE, for the facility in the 2008 DMR database.

Table 12-12. MPM Silicones 2008 Top Discharges

Pollutant Total Pounds TWPE Percentage of Facility

TWPE

Nickel 571,000 57,100 56%

Copper 36,600 23,100 23%

Hexachlorobenzene 10 19,000 19%

Benzo(a)pyrene 12 1,190 1.2%

Total 10,400,000 102,000 100%

Source: DMRLoads2008_v2

.



### All of MPM Silicones’ top pollutant discharges are from outfall 001. Table 12-13 presents the discharge data in the DMR Load ings Tool for 2008. EPA contacted MPM Silicones to verify the values and units for the nickel , copper, hexachlorobenzene, and benzo(a)pyrene concentrations. MPM Silicones’ facility contact verified that the pollutant concentrations reported were either incorrect or missing the BDL indicators (i.e., “<”), and all concentrations should have been reported as μg/L, not mg/L . The facility contact also indicated that benzo(a)pyrene should have been reported annually ; therefore, there shou ld only be one reported

concentration for December 2008. Table 12-13 also shows the facility -provided concentrations (Martin, 2010).

Table 12-13. MPM Silicones Outfall 001 2008 Monthly Discharge Data

Outfall Monitoring Period

Date DMR Loadings Tool Average Concentration (mg/L) Facility-Corrected Average Concentration (mg/L) Average Flow (MGD)

Nickel

001 31-Mar-08 22 0.022 5.71

001 30-Jun-08 11

- a 5.4

001 30-Sept-08 21 0.021 5.32

001 31-Dec-08 83 0.083 5.43

Copper

001 31-Mar-08 3 < 0.006 5.71

001 30-Jun-08 <0.5

- a 5.4

001 30-Sept-08 <5 < 0.01 5.32

001 31-Dec-08 3 < 0.006 5.43

Hexachlorobenzene

001 31-Mar-08 0.000395 < 0.00079 5.71

001 30-Jun-08 0.000435 < 0.00075 5.4

001 30-Sept-08 0.000435 < 0.00075 5.32

001 31-Dec-08 0.00121 < 0.00024 5.43Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-14 Table 12-13. MPM Silicones Outfall 001 2008 Monthly Discharge Data

Outfall Monitoring Period

Date DMR Loadings Tool Average Concentration (mg/L) Facility-Corrected Average Concentration (mg/L) Average Flow (MGD)

Benzo(a)pyrene

001 30-Sept-08 0.00095 NR b 5.32

001 31-Oct-08 0.000705 NR b 5.39

001 31-Dec-08 NR < 0.00141 b 5.43
Source: DMR Loadings Tool and Facility Contact (Martin, 2010). a – Concentration not reported due to sampling error.

b – The facility contact indicated that the benzo(a)pyrene concentration was be report ed only once in December 2008, not September or October 2008. NR – Concentration not reported.



### Using the facility-provided concentrati ons, EPA calculated the revised load and corresponding TWPE for the top pollutants. The facility’s co pper, hexachlorobenzene, and benzo(a)pyrene loads were zeroed because all of the concentrations were measured below the

detection limit. MPM Silicones’ nickel disc harges decrease from 57,100 TWPE 39 TWPE, while the facility’s to tal TWPE decreased from 102,000 TWPE to 1,620 TWPE, a reduction of over 98
percent.

12.4.3 E I DuPont de Nemours & Co. in Washington, WV

Table 12-14 presents the top discharges for E I DuPont de Nemours & Co. in the 2008 DMR database. The majority of the facility TWPE (approximately 41 percent) is from benzo(a)pyrene. The other top pollutants repo rted are chrysene, benzo(a)anthracene, and benzo(k)fluoranthene, all PACs.

Table 12-14. E I DuPont de Nemours 2008 Top Discharges

Pollutant Total Pounds TWPE Percentage of Facility

TWPE

Benzo(a)pyrene 196 19,700 44%

Chrysene 196 6,070 14%

Benzo(a)anthracene 196 6,000 13%

Benzo(k)fluoranthene 196 6,000 13%

Total 7,250,000 44,900 100%

Source: DMRLoads2008_v2

.



### All of the PACs discharges are from outfalls 002 and 005. Table 12-15 presents the discharge data in the DMR Loadings Tool for 2008. EPA contacted the West Virginia Department of Environmental Pr otection (WV DEP) to verify th e PACs concentrations. The WV DEP provided the DMRs and indicated that the a ll PACs discharges were below the detection limit in 2008 (Simmons, 2010). Theref ore, the facility’s PACs load s and TWPE were set to zero. E I DuPont de Nemours’ TWPE decreased from 44,500 TWPE to 1,550 TWPE, a total reduction of 96 percent.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-15 Table 12-15. E I DuPont de Nemours 2008 Monthly PACs Discharge Data

Outfall Pollutant Monitoring

Period Date DMR Loadings

Tool

Concentration (mg/L) WV DEPProvided

Concentration (mg/L) Flow (MGD)

005 Benzo(a)pyrene 31-Jul-08 0.0013 < 0.0013 52.1

002 Benzo(a)pyrene 31-Jul-08 0.0013 < 0.0013 11.7

005 Chrysene 31-Jul-08 0.0013 < 0.0013 52.1

005 Benzo(a)anthracene 31 -Jul-08 0.0013 < 0.0013 52.1

0 05 Benzo(k)fluoranthene 31-Jul-08 0.0013 < 0.0013 52.1
Source: DMR Loadings Tool and Facility Contact (Simmons, 2010).



### 12.5 OCPSF Category Chlorine Discharges in DMR

As part of the 2010 annual review of th e OCSPF Category, EPA reviewed chlorine discharges in the 2008 DMR database. Approxi mately 15 percent of the OCPSF Category 3009 DMR TWPE results from chlorine discharges. Table 12-16 presents the facilities in the 2008 DMR database that discharge chlorine. Two facilit ies, Oxea Bay City Plant in Bay City, TX, and Channel View Complex in Channelview, TX, account for approximately 62 percent of the discharges in the 2008 DMR database. This subsect ion provides information on Oxea Bay City’s and Channelview’s chlorine discharges.

Table 12-16. OCSPF Category Top Chlorine Discharging Facilities in the 2008 DMR

Database

Facility Name Major/Minor Discharger Pounds of Chlorine Discharged Chlorine TWPE Percentage of OCSPF Category

Chlorine DMR 2008

TWPE

Oxea Bay City Plant Major 52,500 26,300 34%

Channel View Complex Major 43,600 21,800 28%

Pasadena Plastics Complex Major 12,900 6,450 8%

Exxon Mobil Chemical Co. Major 7,600 3,800 5%

Cytec Industries, Inc. Major 6,500 3,250 4%

Remaining OCPSF Chlorine Dischargers a 32,400 16,200 21%

Total 156,000 77,800 100%

Source: DMRLoads2008_v2

. a – There are 99 remaining OCPSF facilities with chlorine discharges in DMRLoads2008_v2 that account for about 21 percent of the OCPSF Category’s 2008 chlorine TWPE in the DMR database.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-16 12.5.1 Oxea Bay City Plant in Bay City, TX

All of Oxea Bay City’s chlorine discharges are from outfall 001. Table 12-17 presents Oxea Bay City’s 2008 chlorine discharge data from DMR Loadings Tool for outfall 001. EPA confirmed these discharges with information from Envirofacts 21



### .

Table 12-17. Oxea Bay City 2008 Monthly Ch lorine and Flow Discharge Data

Monitoring Period Date DMR Loadings Tool Chlorine Concentration (mg/L) DMR Loadings Tool Flow (MGD)

31-Jan-08 45 1.004

29-Feb-08 37.5 0.817

31-Mar-08 16.3 1.052

30-Apr-08 5.9 0.873

31-May-08 37.5 0.581

30-Jun-08 1.6 0.586

31-Jul-08 0.1 0.669

31-Aug-08 85 0.736

30-Sep-08 3 0.839

31-Oct-08 0.1 0.733

30-Nov-08 12 0.711

3 1-Dec-08 15 0.799
Source: DMR Loadings Tool.



### Oxea Bay City Plant discharges treated domestic wastewater and treated process

wastewater from the neutral effluent treatment system, a nd treated utility wastewater, stormwater, groundwater recovered during site ex cavations, stormwater from the old dewatering area and from landfill cells, groundwater from the bailing of monitor wells, groundwater from recovery wells, and hydrostatic test disc harge water via outfall 001 (TCEQ, 2009).

EPA contacted Oxea Bay City Plant to confirm the chlorine discharges from outfall 001. The facility contact verified th e chlorine concentrations and in dicated that the location where

chlorine is monitored is different than the lo cation of the final outfall, where flow rate is measured. The chlorine is measured at a nearby sewage treatment facility, Honeyhoe. Oxea Bay

indicated that effluent from H oneyhoe commingles with proce ss wastewater in equalization tanks. The facility contact believed that a majo rity of the chlorine wa s removed by microbes in the equalization tanks. From the e qualization tanks, flow is directed to the facility’s cooling pond and is re-circulated. The facility contact stated that the flow from the equalization tank is typically re-circulated through th e cooling pond; however, the facility permit allows for effluent from the equalization tanks to be rerouted a nd discharged to outfall 001, if necessary. The facility contact also indicated th at in 2008 the plant had issues with the analyz er that controls the chlorine feed, which they though may account for th e higher chlorine concentrations (Martinez, 2010).

21 EPA uses the data in Envirofacts as a source while re viewing the DMR Loadings Tool data because Envirofacts continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not continuously updated; therefore, loads may be estimated with erroneous data.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-17 Based on information from the facility cont act, EPA believes that the DMR Loadings Tool is overestimating the chlorine discharges for Oxea Bay City Plant. The DMR Loadings Tool is using the chlorine that is measured at the effluent from Honeyhoe and the flow that is measured after the equalization tanks to calcula te the chlorine load. EPA will continue to monitor the chlorine discharges from this facility.

12.5.2 Channelview Complex Channelview, TX

All of Channelview’s chlorine discharges are from outfall 001. Table 12-18 presents Channelview’s 2008 chlorine discharge data from the DMR Loadings Tool and Envirofacts for outfall 001. EPA compared data from the DMR Load ings Tool, Envirofact s, and the facility permit and found that the concen tration reported in the 2008 DM R database is the maximum

concentration.

Table 12-18. Channelview Complex 2008 Monthly Chlorine and Flow Discharge Data and

Maximum Chlorine Permit Limitations

Monitoring Period

Date DMR Loadings

Tool Chlorine

Concentration (mg/L) EPA Envirofacts

Minimum Chlorine

Concentration (mg/L) EPA Envirofacts

Maximum Chlorine

Concentration (mg/L) Facility Maximum

Chlorine Permit

Limit (mg/L)

31-Jan-08 NR 1.03 3.88 4

29-Feb-08 3.89 1.17 3.89 4

31-Mar-08 NR 1 31 4

30-Apr-08 NR 1.2 3.9 4

31-May-08 NR 1.43 3.9 4

30-Jun-08 NR 1 3.98 4

31-Jul-08 NR 1.12 3.93 4

31-Aug-08 NR NR NR 4

30-Sep-08 NR 1.24 3.94 4

31-Oct-08 NR NR NR 4

30-Nov-08 NR 1.2 NR 4

31-Dec-08 NR 1 .2 NR 4

Sour ce: DMR Loadings Tool; Envirofacts; and TPDES Permit for Channelview TX0003531 (TCEQ, 2004). NR – Not reported.



### Outfall 001 at Channelview Complex discharges treated organic chem ical manufacturing process wastewater, auto shop wastewater, laboratory wastewater, cooling tower blowdown, sanitary wastewater, loading area and pro cess area washdown, tank farm wastewater, heat exchanger blasting slab waste, steam blow down, demineralization regeneration blowdown, methanol neutralization sump wastewater, and pr ocess area stormwater runoff. The facility is required to treat domestic sewage (both primary a nd secondary) and chlorina te it sufficiently to maintain at least 1.0 mg/L and at most 4.0 mg/L residual chlorine afte r at least 20 minutes contact time (based on peak flow) prior to mixing with any other waters. The domestic sewage is required to be monitored five times per week, by grab sample. From the facility permit, all effluent monitoring samples, including flow rate, are taken where all effluents are commingled together prior to discharge. The f acility is required to take the ch lorine sample at the exit of the septic chlorinator prior to commingli ng with other wastewaters (TCEQ, 2004).Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-18 EPA c ontacted Channelview Complex to confir m the chlorine concentrations and flows for 2008. The facility contact stated that all of chlorine concentrations and flows were correct. The facility contact stated that the unusually high chlorine concentra tion measured during the March 2008 sampling episode was a result of a septic chlorinator ma lfunction. The facility contact also confirmed that the septic chlorinato r, where chlorine is measured, is well upstream

of where flow is measured and that no flow is measured at the septic chlorinator (Miller, 2010). Therefore, EPA believes that the DMR Loadings T ool is overestimating the chlorine discharges

for 2008. EPA will continue to monitor the chlorine concentrations from this facility, but does

not believe the estimated chlorine load accurate ly represents this facility’s discharge.

12.6 OCPSF Category Conclusions

The est imated toxicity of the OCSPF Categor y discharges result from hexachlorobenze, metals, chlorine, and PACs discharges. Data co llected for the 2010 annual review demonstrated that wastewater discharge characteristics for this category are consistent with discharges from prior years. As in prior years, EPA makes the following conclusions:

• 

### There were missing BDL indicators for hexachlorobenzene and PACs discharges from the Chevron Oronite facility in Be lle Chasse, LA. These discharges were actually reported as nondetect, zeroing thei r load and TWPE. Correcting this error

decreases the 2008 facili ty TWPE to 40 TWPE.

• 

### There were missing BDL indicators and a units error for th e nickel, copper, hexachlorobenzene, and PAC discharges reported by MPM Silicones in Friendly, WV. Correcting these erro rs decreases the 2008 fac ility TWPE to 1,620 TWPE.

• 

### There were missing BDL i ndicators for the PAC discharges reported by EI DuPont de Nemours in Washington, WV. These discharges were actually reported nondetect, zeroing their load and TWPE. Correcting this error decreases the 2008 facility TWPE to 1,550 TWPE.

• 

### The chlorine TWPE resulted from fl ow measurement location errors: two facilities measure chlorine at a sepa rate location than flow. The flow

measurements occur after th e wastewater containing ch lorine commingles with

wastewater without chlorine . Therefore, the chlorine load does not accurately reflect the facility’s discharge. EPA will correct this error in the screening-level databases in future years of review and continue monitoring the chlorine discharges from OCSPF facilities.

• 

### Correcting the database errors identifi ed during the 2010 annual review decreases the 2008 OCPSF Category TWPE from 649,000 TWPE to 410,000 TWPE. The OCSPF Category continues to rank high due to the high number of facilities (over 2,000) in the industry. EPA will continue to monitor the OCSPF Category discharges to determine if they are properly controlled.

EPA prioritizes point source categories with existing regulations for potential revision based on the greatest estimated toxicity to human health and the environment, measured as TWPE. Based on the above conclusions, EPA is assi gning this category with a lower priority forSection 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-19 revision (i.e., this category is marked with “(3)” in the “Findings” column in Table V-1 in the Federal Register notice that presents the 2010 annual review of existing ELGs).

12.7 OCSPF Category References

1. Martin, Jason. 2010. Notes from Telephone C onversation between Jason Martin, MPM Silicones, LLC, and Elizabeth Sabol, Easter n Research Group, Inc. “RE: Discharges Reported to DMR in 2008.” (June 29). EPA-HQ-OW-2008-0517 DCN 07293.

2. Martinez, Sylvia. 2010. Notes from Telephone Conversation between Sylvia Martinez, Oxea Bay City Plant, and Lauren Wingo, Ea stern Research Group, Inc. “RE: Oxea Bay City Plant’s 2008 Chlorine and Flow Data in DMR Data.” (August 27). EPA-HQ-OW2008-0517 DCN 07294.

3. Miller, Tommy. 2010. Notes from Telephone Conversation between Tommy Miller, Lyondell Bassel, and Lauren Wingo, Eastern Re search Group, Inc. “RE: Channel View’s

2008 Chlorine and Flow Data in DM R.” (August 30). EPA-HQ-OW-2008-0517 DCN

07295.

4. Sampey, Troy. 2010. E-mail Communication be tween Troy Sampey, Chevron Oronite Co., and Elizabeth Sabol, Eastern Research Group, Inc. “RE: DMRs Clarification Needed

for Chevron Oronite - Oak Point Plan t.” (July 13). EPA-HQ-OW-2008-0517 DCN

07296.

5. Simmons, Linda. 2010. Notes from Telephone Conversation between Linda Simmons, West Virginia Department of Environmen tal Protection, and Eli zabeth Sabol, Eastern Research Group, Inc. “RE: PAC Discharges Reported to DMR in 2008.” (July 13). EPAHQ-OW-2008-0517 DCN 07297.

6. TCEQ. 2004. Texas Commission on Environmen tal Quality. Water Discharge Permit for

NPDES TX0003531 – Channelvie w Complex, Channelview, TX. EPA-HQ-OW-2008-

0517 DCN 07298.

7. TCEQ. 2009. Texas Commission on Environmen tal Quality. Notice of Application and Preliminary Decision for Water Quality TPDES Permit Amendment for Industrial

Wastewater for NPDES TX 0006017 – Oxea Bay City Plant, Bay City, TX. EPA-HQOW-2008-0517 DCN 07299.

8. U.S. Census. 2002. U.S. Economic Census. Available online at: http://www.census.gov/econ/census02.

9. U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program

Plan . EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346 through 1352.

10. U.S. EPA. 2005a. Preliminary 2005 Review of Prioritized Categories of Industrial Dischargers . EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-

0016.Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)



### 12-20 11. U.S. EPA. 2005b. Product and Product Group Discharges Su bject to Effluent Limitations and Standards for the Organic Chemicals, Pl astics, and Synthetic Fibers Point Source Category. Washington, DC. (April). EPA-HQ-OW-2004-032-2568.

12

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

Plan . EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.

13

. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent Guidelines Program Plan . EPA-821-R-07-007. Washingt on, DC. (October). EPA-HQOW-2006-0771-0819.

14

. U.S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program

Plan . EPA-821-R-08-015 Washington, DC. (August). EPA-HQ-OW-2006-0771-1701.

15

. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent Guidelines Program Plan . EPA-821-R-09-006. Washingt on, DC. (October). EPA-HQOW-2008-0517-0515.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-1 13. P LASTICS 

### M OLDING AND 

### F ORMING 

### (40 CFR P ART 

### 463)

EPA selected the Plastics Molding and Forming (PMF) Category 

### for preliminary review because it continues to rank high, in terms of toxic-weighted pound equivalent (TWPE), in point source category rankings (see Table 5-3 for the point source category rankings). The Final 2006 Plan summarizes the results of EPA’s previous reviews of this indus try in 2005 and 2006 (71 FR 76644). This section summarizes the results of the 2010 annual review associated with the PMF Category. EPA focused on discharges of carbon disulfide from four cellulose products manufacturers, because of their high TWPE relative to the rest of the PMF Category.

13. 1 PMF Category Background

Thi s subsection provides background on the PMF Category including a brief profile of the PMF industry, background on 40 CFR Part 463,and background on 40 CFR Part 63 Subpart UUUU, the Cellulose Products National Emi ssion Standards for Hazardous Air Pollutants (NESHAP).

13. 1.1 PMF Industry Profile

The p lastics molding and forming industry in cludes facilities th at are engaged in blending, molding, forming, or othe r types of processing of plasti c materials. These processes commonly include extrusion, coating and la minating, thermoforming, calendaring, casting, foaming, cleaning, and finishing (U.S. EPA, 1984). EPA considered the following 13 North American Industry Classification System ( NAICS) codes part of the PMF Category:

• 

### 32599 1: Custom Compounding of Purchased Resins;

• 

### 326113: Unlaminated Plastics Film and Sh eet (except Packagi ng) Manufacturing;

• 

### 326121: Unlaminated Plastics Pr ofile Shape Manufacturing;

• 

### 326122: Plastics Pipe and Pipe Fitting Manufacturing;

• 

### 326130: Laminated Plastics Plate, Sheet (except Packaging), and Shape Manufacturing;

• 

### 326140: Polystyrene Foam Product Manufacturing;

• 

### 326150: Urethane and Other Foam Product (except Polystyrene) Manufacturing;

• 

### 326160: Plastics Bottle Manufacturing;

• 

### 326191: Plastics Plumbing Fixture Manufacturing;

• 

### 326199: All Other Plastics Product Manufacturing;

• 

### 332813PMF: Electroplating, Plating, Po lishing, Anodizing and Coloring;

• 

### 335921: Fiber Optic Cabl e Manufacturing; and

• 

### 339999PMF: All Other Misce llaneous Manufacturing.

Wastewater generated by facilities in NAICS codes 332813 and 339999 can be regulated under multiple categories. EPA reviewed availa ble information about pollutant loads and manufacturing operations for f acilities reporting these NAICS c odes. In its crosswalk, EPA assigned the extension “PMF” to the end of the NAI CS codes for facilities that most likely fall under the applicability of 40 CFR Part 463, PMF. Most facilities in NAICS 332813 are grouped under the Electroplating Category, while most f acilities in NAICS 339999 are grouped under the Metal Finishing Category.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-2 Because the Permit Compliance System (PCS ) and Integrated Compliance Information System - National Pollutant Discharge Elimination System (ICIS-NPDES), the sources of the discharge monitoring report (D MR) data used to develop DMRLoads2008 , report facilities by Standard Industrial Classification (SIC) code, an d the U.S. Economic Census and Toxics Release Inventory (TRI) report data by NAICS code, EPA reclassified the 2008 DMR by the equivalent

NAICS code. Table 13-1 lists the number of facilities from the U.S. Economic Census and the screening-level databases for the twelve NAICS codes with operations in the PMF Category, the corresponding SIC codes are included for referen ce. The U.S. Economic Census includes more facilities than the screening-level databases becaus e of many possible factor s including: facilities may not meet TRI-reporting thresh olds, facilities may discharge to a publicly owned treatment works (POTW), and some facilities in the U.S. Economic Census are distributors or sales facilities, not manufacturers.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-3 Table 13-1. Number of PMF Facilities

NAICS Code Corresponding SIC

Code Number of Facilities

2002 U.S.

Economic

Census 2008 DMR

Database a 2008 TRI

Database b

325991: Custom Compounding of

Purchased Resins 3087: Custom Compounding of

Purchased Plastics

Resins 749 31 179

326113: Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing 3081: Unsupported

Plastics Film and Sheet 881 162 80

326121: Unlaminated Plastics Profile Shape Manufacturing

3082: Unsupported Plastics Profile Shapes; 3084: Plastics Pipe; and 3089: Plastics Products,

NEC 670

219 47

326122: Plastics Pipe and Pipe Fitting Manufacturing 441 48

326199: All Other Plastics Product Manufacturing 7,892 442

332813PMF: Electroplating, Plating, Polishing, Anodizing and Coloring NA 4

339999PMF: All Other Miscellaneous Manufacturing NA 1

326130: Laminated Plastics Plate, Sheet (except Packaging), and Shape Manufacturing 3083: Laminated Plastics Plate, Sheet, and Profile Shapes 293 9 66

326140: Polystyrene Foam Product Manufacturing

3086: Plastics Foam

Products 552

39 26

326150: Urethane and Other Foam Product (except Polystyrene) Manufacturing 627 212

326160: Plastics Bottle Manufacturing 3085: Plastics Bottles 404 32 3

326191: Plastics Plumbing Fixture Manufacturing 3088: Plastics Plumbing

Fixtures 544 6 129

335921: Fiber Optic Cable Manufacturing NA c 96 NA c 4

Total >13,149 498 1,241
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2 ; and TRIReleases2008_v3

. a – Includes both major and minor dischargers. Also, DMR data is reported by SIC code; therefore EPA used an NAICS to SIC crosswalk for comparison purposes. b – Facilities reporting releases to any media.

c – There is not an SIC code that links to the NAICS code 335921 with facilities that have discharges meeting the applicability of the PMF Category. NA – Not applicable.

NEC – Not elsewhere classified.



### Table 13-2 shows whether permitting authorities designated direct discharging facilities in the PMF Category as minor or major dischargers (see Section 4.1.5 ). EPA included data for minor dischargers for the first time in the 2010 annual review, as part of DMRLoads2008_v2

. EPA does not require permitting authorities to submit DMR data for minor dischargers; however, many states do provide complete DMR data for th em. From this year’s review, EPA observed many data entry or other errors for minor discha rgers in addition to those previously identifiedSection 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-4 for major dischargers, as discussed in Section 4.3. Table 13-2 shows that approximately 99 percent of the PMF Category dischargers in the 2008 DMR database are minor dischargers.

Table 13-2. Number of PMF Facilities by Di scharge Classification in 2008 DMR Database

NAICS Code a Number of Facilities in 2008 DMR Database

Majors Dischargers Minors Dischargers Total

325991: Custom Compounding of Purchased Resins 0 31 31

326113: Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing 3 159 162

326121: Unlaminated Plastics Profile Shape Manufacturing

3 216 219 326122: Plastics Pipe and Pipe Fitting Manufacturing

326199: All Other Plastics Product Manufacturing

332813PMF: Electroplating, Plating, Polishing, Anodizing and Coloring

339999PMF: All Other Miscellaneous Manufacturing

326130: Laminated Plastics Plate, Sheet (except Packaging), and Shape Manufacturing 1 8 9

326140: Polystyrene Foam Product Manufacturing

0 39 39 326150: Urethane and Other Foam Product (except Polystyrene) Manufacturing

326160: Plastics Bottle Manufacturing 0 32 32

326191: Plastics Plumbing Fixture Manufacturing 0 6 6

335921: Fiber Optic Cable Manufacturing NA NA NA

Total 7 491 b 498

Source: DMRLoads2008_v2

. a – DMR data are reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison

purposes. b – The DMR data in PCS and ICIS-NPDES does not include discharge data for all minor dischargers. For the facilities in the PMF Category, 99 of the 491 minor dischargers have DMR data. NA – Not applicable. There is not an SIC code that li nks to the NAICS code 335921 with facilities that have discharges meeting the applicability of the PMF Category.



### Table 13-3 presents the type of discharges reporte d by facilities in the 2008 TRI database. The majority of PMF facilities reporting to TR I do not report water discha rges, but those that do mostly reported indirect discharges to POTWs.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-5 Table 13-3. Number of PMF Facilities by Discharge Type in 2008 TRI Database

NAICS Code Number of Facilities in 2008 TRI Database

Direct Dischargers Only Indirect Dischargers Only Both Indirect

and Direct Dischargers No Water Discharges

325991 Custom Compounding of Purchased Resins 13 27 8 131

326113 Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing 7 18 3 52

326121 Unlaminated Plastics Profile Shape Manufacturing 1 6 0 40

326122 Plastics Pipe and Pipe Fitting Manufacturing 0 1 0 47

326130 Laminated Plastics Plate, Sheet (except Packaging), and Shape Manufacturing 1 4 1 60

326140 Polystyrene Foam Product Manufacturing 2 2 0 22

326150 Urethane and Other Foam Product (except Polystyrene) Manufacturing 1 1 0 210

326160 Plastics Bottle Manufacturing 0 0 0 3

326191 Plastics Plumbing Fixture Manufacturing 2 0 0 127

326199 All Other Plastics Product Manufacturing 3 12 2 425

332813PMF Electroplating, Plating, Polishing, Anodizing and Coloring 0 4 0 0

335921: Fiber Optic Cable Manufacturing 2 0 1 1

339999PMF All Other Miscellaneous Manufacturing 0 1 0 0

Total 32 76 1 5 1,118

Source: TRIReleases2008_v3

.



### 13.1.2 40 CFR Part 463

EPA first promulgated effluent limitation guid elines and standards (ELGs) for the PMF Category (40 CFR Part 463) on December 17, 1984 (49 FR 49040). There are three subcategories, all of which have best pr acticable control tech nology (BPT), new source performance standards (NSPS), pretreatment standards for existing sources (PSES), and pretreatment standards for new sources (PSN S) limitations. See Section 11.B of the Preliminary 2005 Review of Prioritized Categor ies of Industrial Dischargers (U.S. EPA, 2005a) for additional details on the subpart applicability and discharg e limitations and standards.

The remainder of this section focuses on cellu lose manufacturing f acilities because their discharges remain the top concern for the PM F Category for the 2010 annual review, as they

were for the 2005 and 2006 annual reviews.

EPA determined in the 2005 and 2006 annual reviews that cellulose film and sponge manufacturers were dischargi ng large quantities of carbon disulfide (U.S. EPA, 2005a; U.S. EPA, 2006). The carbon disulfide discharges from the manufacture of cellulose product are not covered by Part 463 (the PMF Cate gory). The product is made of re generated cellulose using the viscose process, and Part 463 specifically ex cludes products manufactured from regeneratedSection 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-6 cellulose, as well as the molding and forming of regenerated cellulose (U.S . EPA, 1984). Further,

the Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Plastics Molding and Forming Point Source Category states that 40 CFR Part 414, Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Po int Source Category, covers only the manufacture of rayon, a regenerated cellul ose fiber, and excludes the manufacture of cellulose film, sponge, and meat casings (U.S. EPA, 1987; U.S. EPA, 2005b). Thus, wastewater discharges from the manufactur e of several cellulose products, including film, sponge, and meat casings, are not covered by any existing categ orical ELGs or pretreatment standards. Additionally, neither PMF nor OCPSF regulate disc harges of carbon disulfide, the pollutant of concern for the cellulose products manufacturers identified in the annua l reviews of the PMF Category.

13.1.3 40 CFR Part 63 Subpart UUUU

On June 11, 2002, a NESHAP for Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU) was promulgated (67 FR 4005 5). The Cellulose Products Manufacturing NESHAP regulated the Miscellaneous Viscose Processes and Cellulose Ethers Production Categories. The Miscellaneous Viscose Process category include s cellulose food casings, rayon, cellulosic sponge, and cellophane manufacturing facilities. The NE SHAP established emissions limits for hazardous air pollutants (HAPs), such as carbon disulfide, carbonyl sulfide, ethylene oxide, methanol, methyl chloride, propylene oxide, and toluene. As a result, additional air pollution control may be transferri ng more carbon disulf ide to the water via scrubbers. For more

information on the Cellulose Products Manuf acturing NESHAP see Section 15.1.3 of the Technical Support Document for the 2006 Effluent Guidelines Program Plan (2006 Technical Support Document) (U.S. EPA, 2006).

13.2 PMF Category 2010 Screening-Level Review

Table 13-4 compares the screening-level resu lts for the PMF Category from the 2006 through 2010 annual reviews. The combined TW PE from discharges in the DMR and TRI databases decreased from discharge years 2002 to 2007, but increased from discharge years 2007

to 2008. Both the 2008 DMR TWPE and 2008 TRI TW PE increased significantly from the previous year. The increase in DMR TWPE is due to the addition of minor dischargers as part of

the 2010 annual review and data entr y errors for chlorine and diet hylhexyl phthalate discharges (see Sections 13.4 and 13.6 ). The 2008 DMR TWPE accounts for approximately 70 percent of the total category TWPE.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-7 Table 13-4. PMF Category TRI and DMR Discharges for the 2006 through 2010 Screening-Level Reviews

Year of Discharge Year of Review PMF Category

TRI TWPE DMR TWPE a Total TWPE

2002 2006 118,000 20,800 139,000

2004 2007 72,700 10,800 83,400

2005 2008 22,300 NA NA

2007 2009 8,780 12,400 21,200

2008 2010 74,700 174,000 249,000

Source: TRIReleases2002_v4 ; PCSLoads2002_v4 ; TRIReleases2004_v3 ; PCSLoads2004_v3 ; TRIReleases2005_v2 ; TRIReleases2007_v2 ; DMRLoads2007_v4 ; TRIReleases2008_v3 ; and DMRLoads2008_v2

. a – DMR data from 2002 through 2007 includes only major discharges. 2008 DMR data includes both minor and major dischargers. NA – Not applicable. EPA did not evaluate DMR data for 2005.



### Table 13-5 presents the 2008 DMR TWPE by f acility discharge classification. EPA excluded minor dischargers from previous annual reviews, but included them in the 2010 annual review. The majority (70 percent) of the TW PE in the 2008 DMR database is from minor dischargers.

Table 13-5. PMF Category 2008 DMR TWPE by Discharge Classification

Year of Discharge a TWPE from Minor Dischargers T WPE from Major Dischargers

2008 121,000 52,900

Source: DMRLoads2008_v2

. a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous

annual reviews.



### 13.3 PMF Pollutants of Concern

Table 13-6 lists the five pollutants with the highe st TRI TWPE based on results from the 2010, 2009, and 2007 annual reviews ( TRIReleases2008_v3

, TRIReleases2007_v2 , and
TRIReleases2004_ v3 , respectively). Table 13-7 lists the five pollutant s with the highest DMR TWPE based on results from the 2010, 2009, and 2007 annual reviews ( DMRLoads2008_v2, DMRLoads2007_v3 , and PCSLoads2004_v4 , respectively).Section 13 – Plastics Molding and Forming (40 CFR Part 463)13-8Table 13-6. PMF Category Top TRI PollutantsPollutant2004 TRI Databasea2007 TRI Databasea2008 TRI DatabaseaRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPECarbonDisulfide1565,400136,9501473,100Nitrate Compounds411354310360211302Lead and Lead Compounds556350246660337275ButyraldehydePollutants not reported in the top five2004 TRI reported pollutants.4231042188Diethylhexyl Phthalate5812158157Dioxin and Dioxin-likeCompounds215,410Pollutants not reported in the top five2007 TRI reported pollutants.Pollutants not reported in the top five2008 TRI reported pollutants.Formaldehyde34389PMF Category TotalNA154b76,700NA121b8,780NA123b74,700Source:TRIReleases2004_v3,TRIReleases2007_v2; andTRIReleases2008_v3.a – Discharges include transfers to POTWs and account for POTW removals.b – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 13 – Plastics Molding and Forming (40 CFR Part 463)13-9Table 13-7. PMF Category Top DMR PollutantsPollutant2004 DMR Databasea2007 DMR Databasea2008 DMR DatabaseaRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPEChlorinePollutant not reported in the top five2004 DMR reported pollutants.Pollutant not reported in the top five2007 DMR reported pollutants.11379,600Carbon Disulfide119,7801111,8002152,000Diethylhexyl PhthalatePollutant not reported in the top five2004 DMR reported pollutants.Pollutant not reported in the top five2007 DMR reported pollutants.3240,200Copper23187421144121,120Sulfate311852117552175Ammonia as NitrogenPollutants not reported in the top five2004 DMR reported pollutants.34121Pollutants not reported in the top five2008 DMR reported pollutants.Cadmium5246Nitrogen, Ammonia45182Pollutants not reported in the top five2007 DMR reported pollutants.Nitrogen, Nitrate (Total As N)51106PMF Category TotalNA7c10,800NA6c12,400NA35c174,000Source: PCSLoads2004_v4; DMRLoads2007_v3; and DMRLoads2008_v2.a – 2004 and 2007 DMR data include only major dischargers.b – 2008 DMR data includes major and minor dischargers.c – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-10 The PMF Category combined TWPE is dom inated by carbon disulfide discharges, accounting for approximately 61 percent of the combined TWPE. Therefore, EPA focused the preliminary category review on carbon disulfide discharges from TRI and DMR along with the other top DMR-reported pollutant s that account for the majo rity of the category TWPE.

Chlorine is the top DMR-reported polluta nt in 2008, followed by carbon disulfide and diethylhexyl phthalate. EPA’s additional review for chlorine, diethylhexyl phthalate, and carbon disulfide, the pollutants of c oncern, is presented in the following subsections. EPA did not investigate the other top pollutant s as part of the 2010 annual review because they account for a small percentage (1 percent) of the 2 008 PMF Category combined DMR and TRI TWPE.

13.4 PMF Category Chlorine Discharges in DMR

As part of the 2010 annual review of th e PMF Category, EPA reviewed chlorine discharges in the 2008 DMR database. Approxi mately 46 percent of the 2008 DMR TWPE is from chlorine discharges. Table 13-8 presents the chlorine discharges from PMF facilities in the 2008 DMR database. Kinetico Inc., in Newberry, OH, accounts for 99 percent of the chlorine discharges in the 2008 DMR database for the PMF Category. This subsection provides information on Kinetico’s chlorine discharges.

Table 13-8. PMF Category Chlorine Discharging Facilities in 2008 DMR Database

Facility Name Pounds of Chlorine Discharged Chlorine TWPE Percentage of PMF Category’s 2008

DMR Chlorine

TWPE

Kinetico, Inc. 159,000 79,500 99%

Remaining PMF Chlorine Dischargers a 200 100 1%

Total 159,000 79,600 100%

Source: DMRLoads2008_v2

. a – There are 25 remaining PMF facilities that have chlorine discharges in DMRLoads2008_v2 that account for about 1 percent of the PMF Category’s 2008 chlorine TWPE.



### Kinetico discharges chlorine from outfalls 001 and 003. The majority of the chlorine discharges from Kinetico are from outfall 003 (99.9 percent). Table 13-9 presents Kinetico’s 2008 monthly discharge data in the DMR Load ings Tool for outfall 003. EPA compared the

concentration and flow data from the DMR Lo adings Tool to the data in Envirofacts 22 

### and

determined that there is a unit of measurement error for the outfall 003 flows. The flows in the DMR Loadings Tool were 1,000,000 times higher than the data in Envirofact s, also presented in

Table 13-9 . Using the outfall 003 flows from Envirof acts, Kinetico’s chlorine discharges are 0.159 pounds and 0.079 TWPE for 2008, reducing the faci lity’s total TWPE by 99 percent. This

reduction in TWPE decreases the PM F Category’s 2008 DMR TWPE by 79,500 TWPE.

22 EPA uses the data in Envirofacts as a source while re viewing the DMR Loadings Tool data because Envirofacts continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not continuously updated; therefore, loads may be estimated with erroneous data.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-11 Table 13-9. Kinetico, Inc. 2008 Monthly Ch lorine and Flow Discharge Data

Outfall Monitoring

Period Date NODI

Code a DMR Loadings Tool

Maximum Chlorine Concentration (mg/L) DMR Loadings Tool Flow (MGD) EPA Envirofacts Flow (MGD)

003 31-May-08 Q 377 0.000378

003 30-Jun-08 Q 297 0.000297

003 31-Jul-08 Q 305 0.000304

003 31-Aug-08 Q 289 0.000289

003 30-Sep-08 0.1 529 0.000529

0 03 31-Oct-08 Q 391 0.000391
Source: DMR Loadings Tool and Envirofacts. a – NODI Code Q means that the concentration is not quantifiable.



### 13.5 PMF Category Carbon Disulfide Discharges in DMR and TRI

The 2010 annual review of the PMF Category fo cused on carbon disulf ide discharges in the 2008 DMR and TRI databases. Carbon disulfide discharges accounted for 50 percent of the combined 2008 DMR and TRI TWPE for the PMF Category. This subsection provides

information on the manufacture of regenerated cellulose products because this industry segment is responsible for the PMF Cate gory carbon disulfide discharges. This subsection also includes information on the top carbon disulfide facilities in the 2008 DMR and TRI databases, including

wastewater sources and treatment.

13.5.1 Regenerated Cellulose Products

As part of the 2005 annual review, EPA determ ined that the carbon disulfide discharges

come from facilities that ma nufacture regenerated cellulose products, such as cellophane, cellulosic sponge, and meat ca sings (U.S. EPA, 2005a). Fo r the 2006 annual review, EPA reviewed a study of the cellulose products manufacturing facilities that was written in support of

the Cellulose Products Manufactur ing NESHAP. The information gathered during the study is

summarized in the memorandum Industry Profile of Cellulose Products Manufacturing Facilities

in the U.S. (Schmidtke, 2000). The findings regarding the regenerated ce llulose industry from the

2006 annual review are summarized below. S ee Section 15.5.1 in the 2006 Technical Support Document (U.S. EPA, 2006) for additional details.

The viscose process is used to manufactur e cellulose film, sponge, meat casings, and rayon. In the viscose process, shee ts of dissolving-grade cellulose pulp are saturate d with caustic

to convert the cellulose into alka li cellulose. The alkali cellulose is pressed to remove the excess

caustic and is shredded to increase the surface area for easier processing. After shredding, the

alkali cellulose resembles “white crumbs.” The alkali cellulose partially oxidizes and degrades by aging in ambient air. Gaseous carbon disulfide is mixed with th e aged alkali cellulose in a vessel to form sodium cellulose xanthate, rese mbling “yellow crumbs.” The sodium cellulose xanthate is dissolved in aqueous caustic so lution, creating the viscos e solution. The viscose solution is ripened, filtered, degassed, and extrud ed and then sulphuric acid is added to the viscose solution to form rege nerated cellulose (Schmidtke , 2000). The manufacture of rayon, cellophane, and meat casings differ in the type of extrusion dye and the post-regeneration processing, which includes at least washing and bleaching.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-12 The manufacture of cellulosic sponge differs slightly. The sheets of dissolving-grade pulp

are converted into alkali cellulo se, followed by xanthation into s odium cellulose xanthate using carbon disulfide, and formation of the viscose so lution. The viscose solution is then mixed with sodium sulphate crystals, other fibers, and dyes. The mixture is poured into a mold or extruded under high temperature to melt the sodium sulphate crystals, leaving the por es characteristic of sponges. The remaining processing of the ce llulose sponges includes bleaching, washing, cutting, and possibly packaging. Some facilities that manufacture sponges do not make viscose

and thus do not use carbon disulfid e. Instead they purchase blocks of hardened viscose that they dissolve to form the softened viscose for processing (Schmidtke, 2000).

13.5.2 Regenerated Cellulose Facility Information

EPA identified cellulose products manufacturer s in the United States using the TRI and DMR databases and data from a study of th e cellulose products manufacturing industry conducted by EPA’s Office of Air Quality Pl anning and Standards (OAQPS) during their development of NESHAP regulations (Schmidtke, 2000). Table 13-10 lists the six U.S. cellulose products manufacturers identified in the PMF Category. There may be additional cellulose manufacturing facilities in the United Stat es not included in th e available sources.

In addition, rayon manufacturers are not discus sed in this section. Their manufacturing process is identical to other cellulose manufacturi ng processes, but they form fibers instead of sheets, tubes, or sponges. However, these manuf acturers are regulated under Part 414: OCPSF. OCPSF does not regulate carbon disulfide discharges.

Four of the six facilities reported wastewater discharges of carbon disulfide to TRI in 2008, and one of the 2008 TRI facilities also has discharges of carbon di sulfide in the 2008 DMR database. Although all six regenera ted cellulose facilities have National Pollutant Discharge Elimination System (NPDES) perm it IDs, there are data for only three of them in the 2008 DMR

database. Table 13-11 presents the total pollutant discharges for the regenerated cellulose facilities in the 2008 TRI and DMR databases, alo ng with the discharges of carbon disulfide.

Table 13-11 excludes the 3M Corporation facilities in Elyria, OH and Prairie du Chien, WI

because these facilities do not have data for 2008 in PCS or ICIS-NPDES and TRI.

EPA reviewed additional information on two of the facilities repor ting carbon disulfide discharges in 2008, Innovia Films in Tecumse h, KS and Viskase in Loudoun, TN. Specific information regarding these facilities is presented in the following subsections.Section 13 – Plastics Molding and Forming (40 CFR Part 463)13-13Table 13-10. Cellulose Manufacturers in the United StatesaTRI ID(NPDES ID)Facility NameFacility LocationProduct TypeDischargeTypePermit Notes66542FLXLN6000S(KS0003204)Innovia Films Inc.Tecumseh, KSCellophaneDirectCarbon disulfide monitoring required afteractivated sludge basin because it inhibits thebiological process at concentrations above 35mg/L. Facility must notify regulators if carbondisulfide exceeds 17.5 mg/L.61832TPKNC915NM(ILR000333)Viscofan USA Inc.Danville, ILMeat CasingsIndirectFacility only has a general storm water permit; thefacility discharges process wastewater indirectly.37774VSKSCEASTL(TN0001457)ViskaseCorporationLoudon, TNMeat CasingsIndirectbPermit limits are based on state regulations andtreatability.72370VSKSCRT198(AR0036544)ViskaseCorporationOsceola, ARMeat CasingsDirectFacility is a minor discharge facility.14150GNRLM305SA(NYR00D034)3M CorporationTonawanda, NYCellulosic SpongesIndirectFacility does not have DMR data because itdischarges indirectly. No permit available.44035NYLNG1301L(NA)3M CorporationElyria, OHCellulosic SpongesUnknownDoes not report discharges to PCS or ICISNPDES. Does not report wastewater discharges toTRI. No permit available.53821MCMPN217NO(NA)3M CorporationPrairie du Chien,WICellulosic SpongesIndirectDoes not report discharges to PCS or ICISNPDES. Does not report wastewater discharges toTRI after 2001. No permit available.38402SPNTXSANTA(TN0001571)Spontex Inc.Columbia, TNCellulosic SpongesDirectPermit writer used OCPSF Subpart D –Thermoplastic Resins BPT limitations for NPDESpermit. The permit writer did not apply BATlimitations because the facility produced less than 5million pounds of product per year.Source: Company Websites (Devro, Unknown; Innovia Films, 2004; Spontex, 2004; Viskase, 2002);TRIReleases2002_4;TRIReleases2003_2; Facility NPDESPermits (TDEC, 2002; IEPA, 2003; KDHE, 2005; ADEQ, 2000; TDEC, 2005); andIndustry Profile of the Cellulose Products Manufacturing Facilities in theU.S.(Schmidtke, 2000).a–Rayon is included in cellulose manufacturers; however, these facilities are not presented in this table. Wastewater dischargesfrom rayon manufacturing arecovered under the OCPSF Category (40 CFR Part 414).b – EPA believes the facility is an indirect discharger becausethe facility reports POTW transfers and not surface water releases to TRI. DMR does not containdata for this facility, although they have a NPDES permit thatexpired in December 2006. EPA believes they began discharging only to a POTW sometime after1991.NA – Not applicable.Section 13 – Plastics Molding and Forming (40 CFR Part 463)13-14Table 13-11. 2008 TRI and DMR Discharges for Cellulose Products Manufacturing FacilitiesFacility Name2008 TRI2008 DMRTotal PoundsDischargedaTotal TWPECarbonDisulfidePoundsDischargedaCarbonDisulfideTWPETotal PoundsDischargedTotal TWPECarbonDisulfidePoundsDischargedCarbonDisulfideTWPEInnovia Films Inc.Tecumseh, KS38,30055,60019,90055,60084,400,00052,20018,60052,000Viscofan USA Inc.Danville, IL6,89010,8003,81010,800NANANANAViskase CorporationLoudon, TN1,9905,5401,9205,380NANANANAViskase CorporationOsceola, AR14,8001,3304701,320241,000122NRNR3M CorporationTonawanda, NY7682,150NRNRNANANANASpontex Inc.Columbia, TN219613NRNR40,90014.4NRNRSource:TRIReleases2008_v3andDMRLoads2008_v2.a – Discharges include transfers to POTWs and account for POTW removals (i.e., the amount shown assumes that the POTW removed some of the pollutant).NA – Not applicable. These facilities are indirect dischargers.NR – Not reported.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-15 13.5.2.1 Innovia Films in Tecumseh, KS

EPA reviewed the carbon disulfide discharg es from Innovia Films in Tecumseh, KS as part of the 2010 annual review because this facili ty has the largest discharge of carbon disulfide in the 2008 TRI and DMR databases. The pounds of carbon disulfide repor ted in 2008 TRI is close to the annual pounds discharged cal culated in 2008 DMR database. Innovia Films

estimated their carbon disulfide releases based on periodic monitoring data. EPA believes that

Innovia Films used their carbon disulfide DMR data to report to TRI. Therefore, EPA reviewed the 2008 DMR carbon disulfide discharges from I nnovia Films only as part of the 2010 annual

review.

During the 2006 annual review, EPA reviewed carbon disulfide discharges for Innovia Films. EPA contacted Innovia Films, because it wa s the only facility reporting discharges of carbon disulfide for the PMF Category in the 2002 DMR database. The facility provided

corrections to the effluent carbon disulfide c oncentrations, and EPA corrected the estimated pounds of pollutant discharged. The facility contact indicated that the carbon disulf ide discharges reported resulted from wet scrubbing of the gaseous by-products (Martin, 2006).

Table 13-12 presents the carbon disulfide discharge data in the DMR Loadings Tool for 2008 along with the facility-corrected carbon disu lfide data from 2006, for comparison purposes.

The carbon disulfide concentratio ns and discharge flows for 2008 are similar to the corrected 2006 data. Therefore, EPA determined that the data are likely accurate , and Innovia Films is likely discharging more than 18,000 pounds of carbon disulfide from Outfall 001 annually.

Table 13-12. Innovia Films 2008 Monthly Carbon Disulfide Discharge Data

Outfall Monitoring

Period Date 2006 FacilityProvided Carbon

Disulfide

Concentration (mg/L) 2008 DMR Loadings Tool

Carbon Disulfide

Concentration (mg/L) 2006 FacilityProvided Flow (MGD) 2008 DMR Loadings Tool Flow (MGD)

001 31-Jan-08 2.39 2.03 1.94 1.90

001 29-Feb-08 3.41 4.98 2.03 1.98

001 31-Mar-08 0.362 9.48 2.02 2.08

001 31-May-08 0.072 0.747 2.06 1.78

001 30-Jun-08 0.019 0.557 2.08 1.96

001 31-Jul-08 0.005 0.368 1.87 1.68

001 31-Aug-08 0.022 0.75 1.74 1.91

001 30-Sep-08 0.028 5.76 1.96 2.01

001 31-Oct-08 0.095 0 1.93 1.79

001 30-Nov-08 0.609 8.34 2.03 1.71

001 31-Dec-08 2.39 2.15 1.94 1.80
Source: DMR Loading Tool and Facility Contact (Martin, 2006).Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-16 13.5.2.2 Viskase Corporation in Loudoun, TN

The Viskase facility in Loudoun, TN manufact ures cellulose casings and discharges water to the adjacent POTW. The facility consistently reports releases of approximately 100,000 pounds of carbon disulfide to the POTW (based on TRI data from 2005 through 2008).

As part of its reviews, EPA contacted the f acility and the POTW receiving the facility’s wastewater in 2009. The facility contact indicated that they estimate their discharges of carbon disulfide for TRI using sampling data that is collected every two or three years. The POTW

contact indicated that in additi on to Viskase sampling at the point where the discharge leaves the facility, the POTW samples for carbon disulfide when the discharge enters the POTW facility from a pipe connecting the two adjacent propertie s. The combined data show that the facility releases close to 100,000 pounds of carbon disulfide to the POTW, but the POTW receives less than 3,000 pounds from the discharge pipe. This d ecrease in pollutant load suggests the possible volatilization of 97,000 pounds of carbon disulfide within th e discharge pipe, but warrants further investigation (Birkholtz, 2009 ; Glarrow, 2009; U.S. EPA, 2009).

The data in TRIReleases2008_v3 are consistent with the information collected from the facility and POTW. As a result, no corre ctions were made to the 2008 TRI data.

13.5.3 Wastewater Sources of Carbon Disulfide

At cellulose products manufactur ing facilities, the main wast ewater sources of carbon

disulfide include railcar unl oading, carbon disulfide storag e, and air pollution control (Schmidtke, 2000).

Carbon disulfide gas is delivered to most cellulose products facilities by railcar. Unloading the railcar requires filling it with water or nitrogen to displace the carbon disulfide into the storage tank. Facilities using water di splacement generate carbon -disulfide-saturated wastewater during railcar unloading, which is sent to the faci lity’s wastewater treatment system. Facilities using nitrogen disp lacement do not produce the carbon- disulfide-satura ted wastewater during railcar unloading. EPA determ ined that Spontex Inc. was th e only facility of the eight

listed in Table 13-10 that uses water to displace carbon disulfide during unloading as of 2000 (Schmidtke, 2000).

Carbon disulfide storage tanks are typically submerged under water in a concrete-lined pool. This allows any carbon disulfide leaks to collect in the bottom of the pool to avoid atmospheric releases. In addition to the underwater storage, the ta nks have a water or nitrogen padding system to fill the head space in the tank and further prevent contact with oxygen. The padding is in direct contact w ith the carbon disulfide, creating wastewater saturated with carbon disulfide if a water padding syst em is used. The water padding in the storage tank is displaced into the water pool when the storage tanks are filled. Displaced water in the pool and water padding is sent to the wastewater treatment sy stem. As of 2000, EPA determined that, of the

facilities listed in Table 13-10 , only Viscofan USA Inc, 3M Corporation Tonawanda, and Spontex Inc. use a water pa dding system (Schmidtke, 2000).

Gaseous by-products in the regeneration of cellulose, including hydrogen sulfide and carbon disulfide, are off-gassed from the process e quipment. Pollutants in the vented gas can be removed via a wet gas scrubber, which uses an aqueous solution to remove the air pollutants.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-17 The wet scrubber removal efficiency for carbon di sulfide is low but the scrubber effluent may contain some carbon disulfide (Schmidtke, 2000). Discharges reported by Innovia Films Inc. are due to wet scrubbing of the ga seous by-products (Martin, 2006).

13.5.4 Regenerated Cellulose Wastewater Treatment

Table 13-13 summarizes the wastewater treatm ent known to be used by cellulose products manufacturing facilities.

Table 13-13. Cellulose Products Fa cilities Wastewater Treatment

Product Number of

Facilities Pretreatment Used by Indirect Dischargers Treatment Used by Direct Dischargers

Cellophane 1 NA Neutralizati on, settling, equalization, second neutralization, aeration, and

clarification.

Food Casings 3 Neutralization, potential filtration and settling.

Achieved carbon disulfide (CS 2 ) concentrations of 5- 20 parts per million (ppm). Neut ralization using lime, equalization,

and clarification.

Cellulosic Sponges 4 Neutralization and

oxidization Equalization, aeration, and clarification.

Source: Industry Profile of the Cellulose Products Manufacturing Facilities in the U.S. (Schmidtke, 2000). NA – Not applicable.



### 13.6 PMF Category Diethylhexyl Phthalate Discharges in DMR

As part of the 2010 annual review of th e PMF Category, EPA reviewed diethylhexyl phthalate discharges in the 2008 DMR database . Approximately 30 percent of the 2008 DMR TWPE results from diethylhexyl phthalate discharges. Table 13-14 presents the facilities in 2008 DMR that discharge diethylhexyl phthalate. On e facility, Flexco Corp. in Tuscumbia, AL, accounts for over 99 percent of the discharges in the 2008 DMR. This subsection provides information on Flexco’s diethy lhexyl phthalate discharges.

Table 13-14. PMF Category Diethylhexyl Phth alate Discharging Facilities in 2008 DMR

Database

Facility Name Major/Minor Facility Discharger Pounds of Diethyhexyl

Phthalate Discharged Diethyhexyl

Phthalate TWPE Percentage of PMF Category Diethyhexyl

Phthalate TWPE

Flexco Corp. Minor 969,000 40,200 >99%

DuPont Teijin Films Major 9.7 2.3 <1%

Total 969,000 40,200 100%

Source: DMRLoads2008_v2

.



### All of Flexco’s diethylhexyl phthala te discharges are from outfall 003. Table 13-15 presents Flexco’s 2008 diethylhexyl phthalate discharge data from the DMR Loadings Tool.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-18 EPA contacted Flexco to verify the 2008 diethylhexyl phthalate discharges in the DMR Loadings Tool. The facility contact conf irmed that the November 2009 sample concentration was below detection and should have been reported as NODI Code B (below the detection limit) (Blazer, 2010). Because all of the facility diethylhexyl phthalate concentra tions were below detection, the facility’s revised diethylhexyl pht halate load and TWPE are zero, reducing the facility’s total TWPE by 100 percent. This reduction in TWPE decreases the PMF Category’s 2008 DMR TWPE by 40,200 TWPE.

Table 13-15. Flexco Corp. 2008 Monthly Diet hylhexyl Phthalate Discharge Data

Outfall Monitoring Period

Date NODI Code a Diethylhexyl Phthalate

Maximum Concentration (mg/L) Average Flow (MGD)

003 31-Jan-08 B 0.173

003 29-Feb-08 B 0.173

003 31-Mar-08 B 0.173

003 31-May-08 B 0.173

003 30-Jun-08 B 0.173

003 31-Jul-08 B 0.258

003 31-Aug-08 B 0.305

003 30-Sep-08 B 0.283

003 31-Oct-08 B 0.283

003 30-Nov-08 109 0.475

003 31-D ec-08 B 0.493

Source: DMR Loadings Tool.

a – Below the detection limit.



### 13.7 PMF Category Conclusions

The est imated toxicity of the PMF Category discharges result mainly from the carbon disulfide discharges of regenerated cellulose facilities (accounting for 50 percent of the category’s 2008 combined DMR and TRI TWPE). Data collected for the 2010 annual review demonstrated that wastewater discharge character istics for this category are consistent with discharges from prior years. As in prio r years, EPA makes the following conclusions:

• 

### Database errors for discharges of chlori ne were identified. After correcting these errors, the PMF Category total chlorine TWPE decreased by 99 percent, from 79,600 to 100 TWPE.

• 

### Datab ase errors for discharges of diet hylhexyl phthalate were identified. After correcting these errors, the PMF Category total diethylhexyl phthalate pounds and TWPE decreased to zero (a decrease of 100 percent).

• 

### Carbon disulfide discharges from cellulo se manufacturers were identified as a possible concern. Carbon disulfide disc harges are not regulated by the PMF ELGs. The OCPSF Category does not regu late carbon disulfide for rayon manufacturers. Therefore, carbon disu lfide discharges from cellulose manufacturers are not regul ated under any ELGs.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-19 • 

### Fro m available data, 50 percent of regene rated cellulose manu facturers (excluding rayon fiber facilities) discharge directly to surface waters; 50 pe rcent discharge to

POTWs.

• 

### Many regenerated cellulose facilities do not have permit limits for carbon disulfide but are required to monitor for it. The facilities that monitor carbon disulfide are reporting discharges at measurable concentrations, above the

detection limit.

• 

### Based on the 2010 annual review, EPA intends to conduct an expanded preliminary category review of carbon di sulfide discharges as part of the 2011/2012 planning cycle.

E PA prioritizes point source categories with existing regulations for potential revision based on the greatest estimated toxicity to human health and the environment, measured as TWPE. Based on the above conclusions, EPA is assi gning this category with a lower priority for revision (i.e., this category is marked with “(5)” in the “Findings” column in Table V-1 in the Federal Register notice that presents the 2009 annual review of existing ELGs).

13.8 PMF Category References

1

. ADEQ. 2000. Arkansas Depart ment of Environmental Quality. National Pollution Discharge Elimination System Permit Application NPDES – AR0036544 – Viskase Corporation, Osceola, AR. Little Rock, AR. (December, 31). EPA-HQ-OW-2004-0032-

1205.

2

. Birkholtz, Dave. 2009. Telephone conversation with Dave Bi rkholtz of City of Loudoun, TN POTW and Eleanor Codding of Eastern Research Group, Inc. “Carbon Disulfide Discharges Reported to TRI by Viskase F acility in Loudoun, TN.” (March 12). EPA-HQOW-2008-0517 DCN 07300.

3

. Blazer, Don. 2010. E-mail communication with Don Blazer of Flexco Corp. in Tuscumbia, AL and Elizabeth Sabol of Ea stern Research Group, Inc. “Flexco Corp. DMR Clarification.” (July 8). EPA-HQ-OW-2008-0517 DCN 07301.

4. De vro. Unknown. Product Availability. Available online at: http://www.devro.plc.uk/products/index.ht m. Date accessed: June 22, 2005. EPA-HQOW-2004-0032-0259.

5. Glarrow, Patrick. 2009. Telephone communication with Patrick Glarrow of Viskase in Loudoun, TN and Eleanor Codding of Eastern Research Group, Inc. “Carbon Disulfide Discharges Reported to TRI by Viskase F acility in Loudoun, TN.” (March 10). EPA-HQOW-2008-0517-0074.

6. IEPA. 2003. Illinois Environmental Protecti on Agency Division of Water Pollution

Control. General NPDES Permit for Storm Wa ter Discharges from Industrial Activities. Springfield, IL. EPA-HQ-OW-2004-0032-1209.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-20 7. Innovia Films. 2004. Company Profile. Available online at: http://www.innoviafilms.com/corporate/profile.htm. Date accessed: June 22, 2005. EPAHQ-OW-2004-0032-0261.

8. KDHE. 2005. Kansas Department of Health a nd Environment. Kansas Water Pollution

Control Permit and Authorization to Discharge Under NPDES KS0003204 – Innovia Films, Tecumseh, KS. Topeka, KS. (December 5). EPA-HQ-OW-2004-0032-1210.

9. Martin, Tony. 2006. Telephone conversation with Tony Martin of Innovia Films Inc. and

Jessica Wolford of Eastern Research Gr oup, Inc. “Discussion of Carbon Disulfide Discharges for Innovia Films Inc. (K S0003204).” (April 27). EPA-HQ-OW-2004-0032-

2324.

10

. Schmidtke, Karen and Thomas Holloway. 2000. Industry Profile of the Cellulose Products Manufacturing Facilities in the U .S. Prepared for U.S. EPA National Emissions Standards for Hazardous Air Pollutants: Cellulose Products Manufacturing . Cary, NC. (April 11). EPA-HQ-OAR-2003-0193-0004.

11

. Spontex. 2004. MAPA Spontex, Inc. Wi ping Products. Available online at: http://www.spontexusa.com/products.cfm?PRTID=1. Date accessed: June 22, 2005. EPA-HQ-OW-2004-0032-0269.

12

. TDEC. 2002. Tennessee Department of E nvironment and Conservation. State of Tennessee National Pollutant Discharge El imination System Permit NPDES TN0001457 – Viskase Corporation, Loudon, TN. Nas hville, TN. EPA-HQ-OW-2004-0032-1207.

13

. TDEC. 2005. Tennessee Department of E nvironment and Conservation. State of Tennessee National Pollutant Discharge Elimination System Permit NPDES Permit TN0001571 – Spontex Inc., Columbia, TN. Nashville, TN. 2005. EPA-HQ-OW-2004-

0032-1208.

14. U.S. Census. 2002. U.S. Economic Census. Available online at: http://www.census.gov/econ/census02.

15. U.S. EPA. 1984. Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Plas tics Molding and Forming Point Source Category . EPA 440/1-84/069. Washington, DC. (December).

16. U.S. EPA. 1987. Development Document for Effluent Limitations Guidelines and Standards for the Organic Chemical, Plas tics, and Synthetic Fibers Point Source Category - Final . EPA 4401-87-009. Washi ngton, DC. (October).

17. U.S. EPA. 2005a. Preliminary Review of Prioriti zed Categories of Industrial Discharger s. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-

0053.Section 13 – Plastics Molding and Forming (40 CFR Part 463)



### 13-21 18. U.S. EPA. 2005b. Product and Product Group Discharges Su bject to Effluent Limitations and Standards for the Organic Chemicals, Pl astics, and Synthetic Fibers Point Source Category - 40 CFR 414 . Washington, DC. EP A-HQ-OW-2004-0032-0941.

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

Plan . EPA-821-R-06-018. Washington, DC . (December). EPA-HQ-OW-2004-0032-

2782.

20. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent Guidelines Program Plan . EPA-821-R-09-006. Washingt on, DC. (October). EPA-HQOW-2008-0517-0515.

21. Viskase. 2002. Viskase Companies, Inc. Visk ase Casing Solutions Worldwide. Available online at: http://www.viskase.com/. Date accessed: June 22, 2005. EPA-HQ-OW-2004-

0032-0264.Section 14 – Textile Mills (40 CFR Part 410)



### 14-1 14. T EXTILE 

### M ILLS 

### (40 CFR P ART 

### 410)

EPA selected the Textile Mills (Textiles) Category for preliminary review because it continues to rank high, in terms of toxic-weighted pound equivale nt (TWPE), in point source category rankings (see Table 5-3 for the point source category rankings). This industry was reviewed previously in EPA’s Preliminary and Final 2006 Efflue nt Guidelines Program Plans and the Preliminary 2008 Effluent Guidelines Pr ogram Plan (U.S. EPA, 2005; U.S. EPA, 2006; U.S. EPA, 2007). This section summarizes the 2010 annual review associated with the Textiles Category. EPA focused on discharges of mercur y, aluminum, toxaphene, sulfide, and aldrin, because of their high TWPE relative to ot her pollutants in the Textiles Category.

14. 1 Textiles Category Background

This subsection provides background on the Textiles Category incl uding a brief industry profile of the textiles industry and background on 40 CFR Part 410.

1 4.1.1 Textiles Industry Profile

T he Textiles Category includes facilities that manufacture and process textile materials, such as carpets, broad woven fabrics, and kn itwear. It also includes facilities using wet processes, such as scouring, dyeing, finishing, printing, and coating, wh ich discharge contact wastewater. EPA considered the following 21 No rth American Industry Classification System (NAICS) codes as part of the Textiles Category:

• 

### 313111: Yarn Spinning Mills;

• 

### 313112: Yarn Texturizing, Throwing, and Twisting Mills;

• 

### 313113: Thread Mills;

• 

### 313210: Broadwoven Fabric Mills;

• 

### 313221: Narrow Fabric Mills;

• 

### 313230: Nonwoven Fabric Mills;

• 

### 313241: Weft Knit Fabric Mills;

• 

### 313249: Other Knit Fabric and Lace Mills;

• 

### 313311: Broadwoven Fabric Finishing Mills;

• 

### 313312: Textile and Fabric Finishing (except Broadwoven Fabric) Mills;

• 

### 313320: Fabric Coating Mills;

• 

### 314110: Carpet and Rug Mills;

• 

### 314992: Tire Cord and Tire Fabric Mills;

• 

### 314999: All Other Miscellaneou s Textile Product Mills;

• 

### 315111: Sheer Hosiery Mills;

• 

### 315119: Other Hosiery and Sock Mills;

• 

### 315191: Outerwear Knitting Mills;

• 

### 315192: Underwear and Night wear Knitting Mills;

• 

### 315992: Glove and Mitten Manufacturing.

• 

### 315999: Other Apparel Accessories and Other Apparel Manufacturing; and

• 

### 336360: Motor Vehicle Seating and Interior Trim Manufacturing.

This list of Standard Industrial Classificat ion (SIC) codes includes facilities that EPA determined are potential new subcategories to th e Textiles Category. As part of the 2004 annual review, EPA reviewed industrie s with SIC codes not clearly subject to existing effluentSection 14 – Textile Mills (40 CFR Part 410)



### 14-2 limitation guidelines and standards (ELGs). EP A concluded that the processes, operations, wastewaters, and pollutants of facilities in the following SIC codes are similar to those of the Textiles Category (U.S. EPA, 2004): 23

• 

### 2322: Men’s and Boys’ Underwear and Nightwear ;

• 

### 2396: Automotive Trimmings, Apparel Findings, and Related Products ; and

• 

### 2399: Fabricated Textile Products , Not Elsewhere Classified

.

As part of the 2009 annual review, EPA reclassified these SIC codes as equivalent NAICS codes

for use with the U.S. Economic Census and T oxics Release Inventory (TRI) data that are reported by NAICS code. However, there is not a direct relationship between one SIC and one NAICS code. As a result, EPA included the following NAICS codes in the 2010 annual review of the Textiles Category because they contain facil ities with operations that are similar to the SIC

codes above:

• 

### 314999: All Other Miscellaneous Textile Product Mills; and

• 

### 336360: Motor Vehicle Seating and Interior Trim Manufacturing.

Because the Permit Compliance System (PCS ) and Integrated Compliance Information System - National Pollutant Discharge Elimination System (ICIS-NPDES), the sources of the discharge monitoring report (D MR) data used to develop DMRLoads2008 , report facilities by SIC code, and the U.S. Economic Census and TRI report data by NAICS c ode, EPA reclassified the 2008 DMR by the equivalent NAICS code. Table 14-1 lists the number of facilities from the U.S. Economic Census and the screening-le vel databases for the 21 NAICS codes with operations in the Textiles Category, the corresponding SIC codes are included for reference. The

U.S. Economic Census includes mo re facilities than the screen ing-level databases because of many possible factors including: facilities may not meet TRI-reporting thresholds, facilities may discharge to a publicly owned treatment works (POTW), and some facilities in the U.S.

Economic Census are distributors or sales facilities, not manufacturers.

23 The tables in this section include discharge information from facilities reporting these SIC codes and the corresponding NAICS codes; however, these facilities contribute negligible amounts of TWPE. Consistent with the conclusions drawn during the 2004 annual review (U.S. EPA, 2004) and the 2006 review (U.S. EPA, 2006), EPA found that large numbers of these facilities discharge no wastewater and only a small number of facilities discharge TWPE greater than zero.Section 14 – Textile Mills (40 CFR Part 410)



### 14-3 Table 14-1. Number of Textiles Facilities

NAICS Code Corresponding SIC Code Number of Facilities

2002 U.S.

Economic

Census 2008

DMR

Database a 2008

TRI

Database b

313111: Yarn Spinning Mills
2211: Broadwoven Fabric Mills, Cotton; 2221: Broadwoven Fabric Mills, Manmade Fiber and Silk; 2231: Broadwoven Fabric Mills, Wool;

2241: Narrow Fabric and Other Smallware Mills: Cotton, Wool, Silk, and Manmade Fiber;2251: Women’s Full-Length and KneeLength Hosiery, Except Socks; 2252: Hosiery, NEC; 2253: Knit Outerwear Mills; 2254: Knit Underwear and Nightwear Mills; 2257: Weft Knit Fabric Mills; 2258: Lace and Warp Knit Fabric Mills; 2259: Knitting Mills, NEC

2261: Finishers of Broadwoven Fabrics of Cotton;

2262: Finishers of Broadwoven Fabrics of Manmade Fiber and Silk; 2269: Finishers of Textiles, NEC; 2281: Yarn Spinning Mills; 2284: Thread Mills; 2295: Coated Fabrics, Not Rubberized; 2297: Nonwoven Fabrics; 2299: Textile Goods, NEC 351

214 3

313113: Thread Mills 87 4

313210: Broadwoven Fabric

Mills 762 14

313221: Narrow Fabric Mills 236 2

313230: Nonwoven Fabric Mills 264 10

313312: Textile and Fabric Finishing (except Broadwoven Fabric) Mills 365 16

313241: Weft Knit Fabric Mills 180 2

313249: Other Knit Fabric and

Lace Mills 182 1

313311: Broadwoven Fabric Finishing Mills 1,006 20

313320: Fabric Coating Mills 219 53

315111: Sheer Hosiery Mills 101 0

315119: Other Hosiery and Sock

Mills 308 0

315191: Outerwear Knitting

Mills 398 0

315192: Underwear and Nightwear Knitting Mills 36 0

315999: Other Apparel Accessories and Other Apparel Manufacturing 991 1

313112: Yarn Texturizing, Throwing, and Twisting Mills 2282: Yarn Texturizing, Throwing, Twisting and Winding Mills 142 3 0

314110: Carpet and Rug Mills 2273: Carpets and Rugs 405 13 30

314992: Tire Cord and Tire

Fabric Mills 2296: Tire Cord and Fabrics 25 5 14

314999: All Other Miscellaneous

Textile Product Mills 2298: Cordage and Twine; 2399: Fabricated Textile Products,

NEC 2,312 8 8

336360: Motor Vehicle Seating and Interior Trim Manufacturing 2396: Automotive Trimmings, Apparel Findings, and Related Products 387 5 33

315992: Glove and Mitten Manufacturing NA 96 0 1

Total 8,853 248 212

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); TRIReleases2008_v3 ; and DMRLoads2008_v2

.a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an NAICS-to-SICcode crosswalk for comparison purposes. b – Releases to any media. NA – Not applicable.Section 14 – Textile Mills (40 CFR Part 410)



### 14-4 Table 14-2 shows whether permitting authorities designated direct dischargers as minor or major (see Section 4.1.5 ) for facilities in the Textiles Category. EPA included data for minor dischargers for the first time in the 2010 annual review, as part of DMRLoads2008_v2 database. EPA does not require permitting authorities to submit DMR data for minor dischargers; however, many states do provide complete DMR data for th em. From this year’s review, EPA observed many data entry or other errors for minor discha rgers in addition to those previously identified for major dischargers, as discussed in Section 4.3

. Table 14-2 shows that approximately 79 percent of the Textiles Category dischargers in the 2008 DMR database are minor dischargers.

Table 14-2. Number of Textiles Facilities by Discharge Classification in 2008 DMR

Database

NAICS Code a Number of Facilities in 2008 DMR

Database

Major Dischargers Major Dischargers Major Dischargers

313111: Yarn Spinning Mills

47 167 214 313113: Thread Mills

313210: Broadwoven Fabric Mills

313221: Narrow Fabric Mills

313230: Nonwoven Fabric Mills

313312: Textile and Fabric Finishing (except Broadwoven Fabric)

Mills

313241: Weft Knit Fabric Mills

313249: Other Knit Fabric and Lace Mills

313311: Broadwoven Fabric Finishing Mills

313320: Fabric Coating Mills

315111: Sheer Hosiery Mills

315119: Other Hosiery and Sock Mills

315191: Outerwear Knitting Mills

315192: Underwear and Nightwear Knitting Mills

315999: Other Apparel Accessories and Other Apparel Manufacturing

313112: Yarn Texturizing, Throwing, and Twisting Mills 0 3 3

314110: Carpet and Rug Mills 4 9 13

314992: Tire Cord and Tire Fabric Mills 0 5 5

314999: All Other Miscellaneous Textile Product Mills 0 8 8

336360: Motor Vehicle Seating and Interior Trim Manufacturing 0 5 5

Total 51 197 248

Source: DMRLoads2008_v2

. a – DMR data are reported by SIC code; therefore EPA used an NAICS to SIC crosswalk for comparison purposes.



### Table 14-3 presents the type of discharges reporte d by facilities in the 2008 TRI database. The majority of textile facilities reporting to TRI do not report water di scharges, but those that do mostly reported discharging indirectly.Section 14 – Textile Mills (40 CFR Part 410)



### 14-5 Table 14-3. Number Textiles Facilities by Discharge Type in 2008 TRI Database

NAICS Code Number of Facilities in 2008 TRI Database

Direct Dischargers Only Direct Dischargers Only Direct Dischargers Only Direct Dischargers Only

313111: Yarn Spinning Mills 0 0 0 3

313113: Thread Mills 0 2 0 2

313210: Broadwoven Fabric Mills 0 2 1 11

313221: Narrow Fabric Mills 0 1 0 1

313230: Nonwoven Fabric Mills 0 3 1 6

313312: Textile and Fabric Finishing (except Broadwoven Fabric) Mills 1 9 1 5

313241: Weft Knit Fabric Mills 0 1 0 1

313249: Other Knit Fabric and Lace Mills 0 0 0 1

313311: Broadwoven Fabric Finishing Mills 3 6 0 11

313320: Fabric Coating Mills 0 7 1 45

315111: Sheer Hosiery Mills 0 0 0 0

315119: Other Hosiery and Sock Mills 0 0 0 0

315191: Outerwear Knitting Mills 0 0 0 0

315192: Underwear and Nightwear Knitting Mills 0 0 0 0

315999: Other Apparel Accessories and Other Apparel Manufacturing 0 1 0 0

313112: Yarn Texturizing, Throwing, and Twisting

Mills 0 0 0 0

314110: Carpet and Rug Mills 0 10 0 20

314992: Tire Cord and Tire Fabric Mills 1 5 3 5

314999: All Other Miscellaneous Textile Product

Mills 0 1 0 7

336360: Motor Vehicle Seating and Interior Trim Manufacturing 0 2 0 31

315992: Glove and Mitten Manufacturing 0 1 0 0

Total 5 51 7 149

Source: TRIReleases2008_v3

.



### 14.1.2 40 CFR Part 414

EPA first promulgated ELGs for the Textiles Category (40 CFR Part 410) on September 2, 1982 (47 FR 38819). There are nine subcategories, all of which have best practicable control technology (BPT), best available technology econo mically achievable (BAT), and new source performance standards (NSPS) limitations. Some s ubcategories also have pretreatment standards for existing sources (PSES), a nd pretreatment standards for new sources (PSNS) limitations.

Table 9-4 lists the nine subcategories and applicability. Table 14-4 in the Technical Support Document for the 2006 Effluent Guidelines Program Plan lists the regulated pollutants for the subcategories (U.S. EPA, 2006).Section 14 – Textile Mills (40 CFR Part 410)



### 14-6 Table 14-4. Applicability of Subcat egories in the Textiles Category

Subpart Subcategory Title Subcategory Applicability

A Wool Scouring Wool scouring, topmaking, and general cleaning of raw wool

B Wool Finishing Wool finishers, includ ing carbonizing, fulling, dyeing, bleaching, rinsing, fireproofing, and other such similar processes

C Low Water Use Processing Yarn manufacture, yarn texturizing, unfinished fabric manufacture, fabric coating, fabric laminating , tire cord and fabric dipping, and carpet tufting and carpet backing

D Woven Fabrics Finishing Woven fabric finishers, which may include any or all of the following unit operations: desizing, bleaching, mercerizing, dyeing, printing, resin treatment, water proofing, flame proofing, soil repellency application and a special finish application

E Knit Fabric Finishing Knit fabric finishers, which may include any or all of the following unit operations: bleaching, mercerizing, dyeing, printing, resin treatment, water proofing, flame proofing, soil repellency application and a special finish application

F Carpet Finishing Carpet mills, which may include any or all of the following unit operations: bleaching, scouring, carbonizing, fulling, dyeing, printing, resin treatment, waterproofing, flameproofing, soil repellency, looping, and backing with foamed and unfoamed latex and jute

G Stock & Yarn Finishing Stock or yarn dyeing or finishing, which may include any or all of the following unit operations and processes: cleaning, scouring, bleaching, mercerizing, dyeing and special finishing

H Nonwoven Manufacturi ng Facilities that primarily manufacture nonwoven textile products of wool, cotton, or synthetics, singly or as blends, by mechanical, thermal, and/or adhesive bonding procedures

I Felted Fabric Processing Facilities that pr imarily manufacture nonwoven products by employing fulling and felting operations as a means of achieving fiber bonding

Source: Textile Mills Point Source Category – 40 CFR 41 0; Development Document for Effluent Limitations Guidelines and Standards for the Textile Mills Point Source Category (U.S. EPA, 1979).



### 14.2 Textiles Category 2010 Screening-Level Review

Table 14-5 compares the screening-le vel database results for th e Textiles Category from the 2006 through 2010 annual reviews that represented multiple years of data from the DMR and TRI databases. The combined DMR and TRI TWPE decreased from discharge years 2004 to 2007, but increased from discharge years 2007 to 2008. The discharge year 2008 DMR TWPE accounts for approximately 42 percent of the combined 2008 DMR and TRI TWPE, similar to previous years.Section 14 – Textile Mills (40 CFR Part 410)



### 14-7 Table 14-5. Textiles Category TRI and DM R Discharges for the 2006 through 2010 Screening-Level Reviews

Year of Discharge Year of Review Textiles Category

TRI TWPE DMR TWPE a Total TWPE

2002 2006 3,710 123,000 127,000

2004 2007 3,040 123,000 126,000

2005 2008 3,040 NA NA

2007 2009 2,390 79,900 82,300

2008 2010 2,750 247,000 250,000

Source: TRIReleases2002_v4 ; PCSLoads2002_v4 ; TRIReleases2004_v3 ; PCSLoads2004_v3 ; TRIReleases2005_v2 ; TRIReleases2007_v2 ; DMRLoads2007_v4 ; TRIReleases2008_v3 ; and DMRLoads2008_v2

. a – DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and major dischargers. NA – Not applicable. EPA did not evaluate DMR data for 2005.



### Table 14-6 presents the 2008 DMR TWPE by f acility discharge classification. EPA excluded minor dischargers from previous annual reviews, but included them in the 2010 annual review. The majority (72 percent) of the TW PE in the 2008 DMR database results from major dischargers.

Table 14-6. Textiles Category 2008 DMR TW PE by Discharge Classification

Year of Discharge a T WPE from Minor Dischargers TWPE from Major Dischargers

2008 68,200 179,000

Source: DMRLoads2008_v2

. a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous

annual reviews.



### 14.3 Textiles Pollutants of Concern

Table 14-7 compares the five chemicals with the highest TWPE in the 2008, 2007, and 2004 TRI databases ( TRIReleases2008_v3

, TRIReleases2007_v2 , and TRIReleases2004_ v3 ).

Table 14-8 lists the five pollutants with the highest TWPE in the 2008, 2007, and 2004 DMR databases ( DMRLoads2008_v2, DMRLoads2007_v3 , and PCSLoads2004_v4 ).Section 14 – Textile Mills (40 CFR Part 410)14-8Table 14-7. Textiles Category Top TRI PollutantsPollutant2004a2007a2008aRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPEAmmoniaPollutants not reported in the top five2004 TRI reported pollutants.19970191,330Lead and Lead CompoundsPollutant not reported in the top five2007 TRI reported pollutants.28272Copper and Copper Compounds1128432951137192Chlorine Dioxide216393120441173Nitrate Compounds352684616456157Di(2-ethylhexyl) phthalatePollutant not reported in the top five2004 TRI reported pollutants.51106Pollutants not reported in the top five2008 TRI reported pollutants.Antimony and AntimonyCompounds418192Pollutants not reported in the top five2007 TRI reported pollutants.Zinc and Zinc Compounds513173Textiles Category TotalNA83b3,040NA61b2,390NA58b2,750Source:TRIReleases2004_v3;TRIReleases2007_v2; andTRIReleases2008_v3.a – Discharges include transfers to POTWs and account for POTW removals.b – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 14 – Textile Mills (40 CFR Part 410)14-9Table 14-8. Textiles Category Top DMR PollutantsPollutant2004a2007a2008bRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPEMercuryPollutants not reported in the top five 2004DMR reported pollutants.4329613135,000AluminumPollutants not reported in the top five 2007DMR reported pollutants.2334,300Toxaphene3132,800Sulfide135117,00042530,100AldrinPollutant not reported in the top five 2004DMR reported pollutants.1176,400519,500Chlorine2183,4402161,680Pollutants not reported in the top five 2008DMR reported pollutants.Copper3241,270318583ChromiumPollutant not reported in the top five 2004DMR reported pollutants.53184Chloride414340Pollutant not reported in the top five 2007DMR reported pollutants.Nitrogen, Kjeldahl Total (asN)55209Textiles Category TotalNA62c123,000NA46c79,900NA77c247,000Source:PCSLoads2004_v4;DMRLoads2007_v3; andDMRLoads2008_v2.a – 2004 and 2007 DMR data include only major dischargers.b – 2008 DMR data includes major and minor dischargers.c – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 14 – Textile Mills (40 CFR Part 410)



### 14-10 The majority of the Textiles Category total TWPE (over 98 percent) is based on discharges in the 2008 DMR database. Therefore, EPA focused the preliminary category review on the DMR-reported pollutants that account for the majority of the category TWPE.

EPA’s additional review for the 2008 DMR da tabase pollutants of concern, mercury, aluminum, toxaphene, sulfide, and aldrin, is presented in the followi ng sections. During the review of top pollutants, EPA di scovered that the majority of th e top pollutants were discharged

from the same three facili ties in the 2008 DMR database. Table 14-9 presents the top discharging facilities and top pollutants in the Textiles Cate gory. The following subsections provide details

on EPA’s review of the 2008 DMR database discharges.

Table 14-9. Textiles Category Top Pollutant and Facility Dischargers in DMR 2008

Top Pollutant Facility Name Pounds of

Pollutant Discharged Pollutant

TWPE Total Facility

TWPE

Mercury Kawashima Textile USA, Inc. 1,151 135,000 135,000

Aluminum Kannapolis Water Treatment

Plant 571,000 34,300 35,000

Toxaphene Mohawk Industries/ Oak River

Plant 1.09 33,100 32,800

Sulfide Mohawk Industries, Inc. 5,060 1 4,200 14,200

Aldrin Deroyal Textiles 0.853 9,500 9,510

Source: DMRLoads2008_v2

.



### 14.4 Textiles Category Top Facility Dischargers in DMR

This subsection provides further detail on the t op five facility discha rgers in the Textiles Category responsible for the majority of the me rcury, aluminum, toxaphene, sulfide and aldrin

TWPE. As a result of EPA’s identification of data errors, of discharges from the top facilities in the Textiles Category, the ove rall category 2008 DMR TWPE d ecreased by over 170,000 TWPE from 250,000 TWPE to 78,500 TWPE.

14.4.1 Kawashima Textile USA, Inc. in Camden, SC

Table 14-10 presents the discharges in the 2008 DMR database for Kawashima Textile USA, Inc. The majority of the facility TWPE (approximately 100 percent) is from mercury. Mercury discharges from Kawashima Textile also account for approximately 54 percent of the DMR TWPE for the Textiles Category.Section 14 – Textile Mills (40 CFR Part 410)



### 14-11 Table 14-10. Kawahima Textile 2008 Top Discharges in the DMR Database

Pollutant Total Pounds Total TWPE Percent of Facility Total

TWPE

Mercury 1,150 135,000 100%

Iron 106 0.59 0%

Ammonia 255 0.28 0%

Manganese 3.06 0.21 0%

Phosphorous 0.77 0.00 0%

Total 1,510 135,000 100%

Source: DMRLoads2008_v2

.



### All of the pollutant discharges for Ka washima Textile USA are from outfall 002. Table

14-11 presents the discharge data in the DMR Lo adings Tool for 2008, along with the data from

EPA’s Envirofacts 24 

### . EPA determined that January, June, July, and August 2008 mercury concentrations had data errors. Using the corr ected concentrations, EPA calculated the revised load and corresponding TWPE for mercury. The f acility’s mercury discharges decrease from 135,000 TWPE to 0.9 TWPE, while th e facility’s tota l TWPE decreased from 135,000 TWPE to 2 TWPE, a reduction of almost 100 percent.

Table 14-11. Kawashima Textile USA 2008 Monthl y Mercury and Flow Discharge Data

Outfall Pollutant Monitoring

Period Date a DMR Loadings Tool Average Concentration (mg/L) Envirofacts Average Concentration (mg/L) Average Flow (MGD)

002 Mercury 31-Jan-08 4.0000188 0.0000188 0.2997

002 Mercury 29-Feb-08 0.000012 0.000012 0.2793

002 Mercury 31-Mar-08 0.000013 0.000013 0.2173

002 Mercury 30-Apr-08 0.000011 0.000011 0.1954

002 Mercury 31-May-08 0.00011 0.00011 0.2563

002 Mercury 30-Jun-08 4.0000042 0.0000042 0.2751

002 Mercury 31-Jul-08 4.0000048 0.0000048 0.2548

002 Mercury 31-Aug-08 4.0000061 0.0000061 0.2915
Source: DMR Loadings Tool and Envirofacts. a – The DMR Loadings Tool and Envirofacts do not have mercury concentrations for Kawashima Textile USA for September, October, Nove mber, and December 2008.



### 14.4.2 Kannapolis Water Treatment Plant in Kannapolis, NC

Table 14-12 presents the discharges in the 2008 DMR database for Kannapolis Water Treatment Plant (WTP). The majority of the facility TWPE (almost 98 percent) is from discharges of aluminum. Alum inum discharges from Kannapolis WTP also account for approximately 14 percent of the DMR TWPE for the Inorganic Chemicals Category.

24 EPA uses the data in Envirofacts as a source while re viewing the DMR Loadings Tool data because Envirofacts continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not continuously updated; therefore, loads may be estimated with erroneous data.Section 14 – Textile Mills (40 CFR Part 410)



### 14-12 Table 14-12. Kannapolis WTP 2008 Top Discharges in the DMR Database

Pollutant Total Pounds TWPE Percent of Facility

TWPE

Aluminum 571,000 34,300 97.90%

Iron 109,000 611 1.75%

Manganese 1,740 122 0.35%

Calcium 6,270 0.18 0.00%

Magnesium 70.6 0.06 0.00%

Total 688,000 35,000 100%

Source: DMRLoads2008_v2

.



### All of Kannapolis WTP’s aluminum discharges are from outfall 001. Table 14-13 presents the aluminum discharge data in the DMR Loadings Tool for 2008, along with the data

from EPA’s Envirofacts. EPA determined that aluminum concentrations for January through November 2008 were in the DMR Loadings Tool as mg/L, but in Envirofacts as μ g/L. Using the corrected concentrations, EPA calculated th e revised load and corresponding TWPE for aluminum. The facility’s alum inum discharges decrease fr om 34,300 TWPE to 36 TWPE, while the facility’s to tal TWPE decreases from 34,900 TWPE to 769 TWPE, a reduction of almost 100
percent.

Table 14-13. Kannapolis WTP 2008 Mont hly Aluminum Discharge Data

Outfall Pollutant Monitoring

Period Date DMR Loadings Tool Average Concentration (mg/L) Envirofacts Average

Concentration

( μ g/L) (mg/L)

001 Aluminum 31-Jan-08 659.8 659.8 0.6598

001 Aluminum 29-Feb-08 911.25 911.25 0.91125

001 Aluminum 31-Mar-08 887.5 887.5 0.8875

001 Aluminum 30-Apr-08 537 537 0.537

001 Aluminum 31-May-08 411.75 411.75 0.41175

001 Aluminum 30-Jun-08 657.25 657.25 0.65725

001 Aluminum 31-Jul-08 608.4 608.4 0.6084

001 Aluminum 31-Aug-08 626.25 626.25 0.62625

001 Aluminum 30-Sep-08 1,339 1,339 1.339

001 Aluminum 31-Oct-08 491.6 491.6 0.4916

001 Aluminum 30-Nov-08 440 440 0 .440

001 Aluminum 31-Dec-08 0.333 333 0.33
Source: DMR Loadings Tool and Envirofacts.



### 14.4.3 Mohawk Industries Oak River Plant in Bennettsville, SC

Table 14-14 presents the discharges for Mohawk Industries Oak River Plant in the 2008 DMR database. The majority of the TWPE is from toxaphene (approximately 99 percent). Toxaphene discharges from Moha wk Industries Oak River Plant al so account for approximately 13 percent of the DMR TWPE for the Textiles Category.Section 14 – Textile Mills (40 CFR Part 410)



### 14-13 Table 14-14. Mohawk Industries Oak River Plant 2008 Top Discharges in the DMR

Database

Pollutant Total Pounds TWPE Percent of Facility TWPE

Toxaphene 1.09 32,800 99.2%

Sulfur 92.1 258 0.78%

Chlorine 28.1 14.0 0.04%

Ammonia 72.0 0.08 0.00%

Chromium 0.88 0.06 0.00%

Total 194 33,100 100%

Source: DMRLoads2008_v2

.



### Mohawk Industries Oak River Plant reports toxaphene discharges from outfall 001. Table

14-15 presents the discharge data in the DM R Loadings Tool for 2008. EPA contacted the facility to confirm the 2008 t oxaphene discharges. Mohawk Indus tries Oak River Plant stated

that the concentrations were correct and that the December 2008 toxaphene concentration was <0.0005 mg/L. Mohawk Industries Oak River Plant also indicated that the chemical is not used as a raw material or in any other chemicals at the facility (Wood, 2010). The South Carolina Department of Health and Environmental Control (SC DHEC) requires Mohawk to monitor for toxaphene because recent water quality data found it at detectable concen trations. The facility must monitor toxaphene to determine if a limit is necessary (Vickers, 2010).

EPA evaluated available 2009 and 2010 toxaphene data from Envirofacts, presented in

Table 14-16 , and determined that all concentrations we re reported below detection limit (BDL). SC DHEC is monitoring toxaphene discharges , and all 2009 and 2010 discharges are BDL, and EPA will continue reviewing the discharge data for this facility.Section 14 – Textile Mills (40 CFR Part 410)



### 14-14 Table 14-15. Mohawk Industries Oak River Plant 2008 Monthly Toxaphene Discharge

Data

Outfall Pollutant Monitoring

Period Date DMR Loadings

Tool

Concentration (mg/L) Facility-Provided

Concentration (mg/L) Average Flow (MGD)

001 Toxaphene 31-Jan-08 < 0.0005 < 0.0005 0.093487

001 Toxaphene 29-Feb-08 < 0.0005 < 0.0005 0.108851

001 Toxaphene 31-Mar-08 < 0.0025 < 0.0025 0.070074

001 Toxaphene 30-Apr-08 0.0025 0.0025 0.09694

001 Toxaphene 31-May-08 0.0005 0.0005 0.073806

001 Toxaphene 30-Jun-08 < 0.0005 < 0.0005 0.08753

001 Toxaphene 31-Jul-08 < 0.0005 < 0.0005 0.131065

001 Toxaphene 31-Aug-08 < 0.0005 < 0.0005 0.164852

001 Toxaphene 30-Sep-08 < 0.05 < 0.05 0.158837

001 Toxaphene 31-Oct-08 < 0.0005 < 0.0005 0.1335

001 Toxaphene 30-Nov-08 < 0.0005 < 0.0005 NR

001 Toxaphene 31-Dec-08 NR < 0.0005 NR
Source: DMR Loadings Tool and Facility Contact (Wood, 2010). NR – Not reported.



### Table 14-16. Mohawk Industries Oak River Plant 2009 and 2010 Monthly Toxaphene Discharge Data

Outfall Pollutant Monitoring Period Date Envirofacts Concentration (mg/L)

001 Toxaphene 31-Jan-09 < 0.00055

001 Toxaphene 29-Feb-09 < 0.0005

001 Toxaphene 31-Mar-09 < 0.0005

001 Toxaphene 30-Apr-09 < 0.0001

001 Toxaphene 31-May-09 < 0.00055

001 Toxaphene 30-Jun-09 < 0.00055

001 Toxaphene 31-Jul-09 < 0.0005

001 Toxaphene 31-Aug-09 < 0.0003

001 Toxaphene 30-Sep-09 < 0.0005

001 Toxaphene 31-Oct-09 < 0.0005

001 Toxaphene 30-Nov-09 < 0.0005

001 Toxaphene 31-Dec-09 < 0.0005

001 Toxaphene 31-Jan-10 < 0.0005

001 Toxaphene 29-Feb-10 < 0.0005

001 Toxaphene 31-Mar-10 < 0.0005

001 Toxaphene 30-Apr-10 < 0.005

0 01 Toxaphene 31-May-10 < 0.0005

001 Toxaphene 30-Jun-10 < 0.00055

Source: EnvirofactsSection 14 – Textile Mills (40 CFR Part 410)



### 14-15 14.4.4 Mohawk Industries, Inc. in Lyerly, GA

Table 14-17 presents the discharges for Mohawk Industries in the 2008 DMR database.

Almost all of the TWPE is from sulfide. Su lfide discharges from Mohawk Industries also account for approximately 6 percent of th e DMR TWPE for the Textiles Category.

Table 14-17. Mohawk Industries 2008 Top Discharges in the DMR Database

Pollutant Total Pounds TWPE Percent of Facility TWPE

Sulfide 5,100 14,200 99.98%

Chromium 40.4 2.83 0.02%

Total 5,140 14,200 100%

Source: DMRLoads2008_v2

.



### All of Mohawk Industries sulfide discharges are from outfalls 0A1. Table 14-18 presents the discharge data in the DMR Loadings Tool an d the back-calculated concentrations associated with each sulfide quantity. EPA cal culated the sulfide concentrations using the average quantity and flow provided in the 2008 DMR Loadings Tool. EPA contacted the facility to verify the sulfide quantities in the 2008 DM R database. Mohawk Industries confirmed that the sulfide quantities were correct and that the permit lim it for sulfide is 11 kg/day (Wood, 2010). Mohawk Industries stated that sulfide pr esent in the wastewater may be from boiler treatment chemicals

and wastewater treatment chemicals used to tr eat intake water for hardness (Wood, 2010). The sulfide quantities are below permit limits, therefore, the facility’s sulfide discharges are not a

concern for the 2010 annual review.

Table 14-18. Mohawk Industries 2008 Monthly Sulfide Discharge Data

Outfall Pollutant Monitoring Period

Date DMR Loadings Tool Average Quantity (kg/day) Calculated Sulfide

Concentrations (mg/L) Average Flow (MGD)

0A1 Sulfide 31-Jan-08 6.08 1.2 1.323

0A1 Sulfide 30-Apr-08 8.31 1.3 1.659

0A1 Sulfide 31-Jul-08 7.61 1.9 1 .025

0A1 Sulfide 31-Oct-08 2.83 1.1 0.723
Source: DMR Loadings Tool and Facility Contact (Wood, 2010).



### 14.4.5 Deroyal Textiles in Camden, SC

Table 14-19 presents the discharges for Deroya l Textiles in the 2008 DMR database.

Almost all of the TWPE is from aldrin. Aldrin discharges from Deroyal Textiles also account for approximately 4 percent of the DMR TWPE for the Textiles Category.Section 14 – Textile Mills (40 CFR Part 410)



### 14-16 Table 14-19. Deroyal Textiles 2008 Top Discharges in the DMR Database

Pollutant Total Pounds TWPE Percent of Facility TWPE

Aldrin 0.85 9,500 99.9%

Sulfur 2.05 5.74 0.06%

Hydrogen sulfide 0.45 1.27 0.01%

Chromium 3.93 0.28 0.00%

Ammonia 140 0.16 0.00%

Total 147 9,500 100%

Source: DMRLoads2008_v2

.



### All of the aldrin discharges are from outfall 001. Table 14-20 presents the discharge data in the DMR Loadings Tool for 2008. EPA contacted Deroyal Textiles to verify the aldrin concentrations. Deroyal Textiles indicated that the facility made a c onversion error with the

March 2008 DMR data and the aldrin concentration was reported in μ g/L instead of mg/L although the units were reported as mg/L (G ettys, 2010). Using th e facility-provided concentrations, EPA calculated the revised lo ad and corresponding TWPE for aldrin. The facility’s aldrin discharges decrease from 9,500 TWPE to 353 TWPE, while the facility’s total TWPE decreases from 9,510 TWPE to 361 TWPE, a reduction of over 96 percent.

Table 14-20. Deroyal Textiles 2008 Monthly Aldrin Discharge Data

Outfall Pollutant Monitoring Period

Date DMR Loadings Tool Average

Concentration (mg/L) Facility-Provided Average

Concentration (mg/L) Average Flow (MGD)

001 Aldrin 31-Jan-08 0 0 0.08

001 Aldrin 29-Feb-08 0 0 0.102

001 Aldrin 31-Mar-08 0.034 0.000034 0.088

001 Aldrin 30-Apr-08 0.00023 0.00023 0.087

001 Aldrin 31-May-08 0.000011 0.000011 0.07

001 Aldrin 30-Jun-08 0.000116 0.000116 0.073

001 Aldrin 31-Jul-08 NR NR 0.065

001 Aldrin 31-Aug-08 0 0 0.061

001 Aldrin 30-Sep-08 0 0 0.038

001 Aldrin 31-Oct-08 0 0 0.037

001 Aldrin 30-Nov-08 0 0 0.017

001 Aldrin 31-Dec-08 0.00 0019 0.000019 0.02 6

Sour ce: DMR Loadings Tool and Facility Contact (Gettys, 2010). NR – Not reported. The aldrin data for July 2008 includes the NODI code E – analysis not conducted.



### 14.5 Textiles Category Conclusions

The est imated toxicity of the Textile Mills Category discharges result from mercury, aluminum, toxaphene, sulfide, and aldrin discha rges. Data collected for the 2010 annual reviewSection 14 – Textile Mills (40 CFR Part 410)



### 14-17 demonstrated that wastewater discharge character istics for this category are consistent with discharges from prior years. As in prio r years, EPA makes the following conclusions:

• 

### There were data errors in the mercury concentrations for Kawashima Textile USA. Correcting this error decreases the 2008 facility TWPE to 2 TWPE.

• 

### There was a units error for the aluminum concentrations for Kannapolis WTP. Correcting this error decreases the 2008 facility TWPE to 769 TWPE.

• 

### The screening-level data for toxaphene discharges from Mohawk Industries Oak

River Plant are accurate. Th e facility does not use t oxaphene and is unable to identify the source of the pesticide. SC DHEC requires the facility to continue monitoring for toxaphene, and EPA will con tinue reviewing toxaphene discharges from this facility as part of future reviews.

• 

### Sulfide discharges from Mohawk Industries in Lyerly, GA are below the permit limit. EPA will continue monitoring sulfide discharges from this facility as part of

future reviews.

• 

### There was a units error for the March 2008 aldrin concentration for Deroyal Textiles. Correcting this error decreases the 2008 f acility TWPE to 361 TWPE.

• 

### Correcting the database errors identifi ed during the 2010 annual review decreases the 2008 Textile Mills Category TWPE from 250,000 TWPE to 78,500 TWPE.

EPA will continue to monitor the Textile Mills Category discharges to determine if they are properly controlled.

EPA prioritizes point source categories with existing regulations for potential revision based on the greatest estimated toxicity to human health and the environment, measured as TWPE. Based on the above conclusions, EPA is assi gning this category with a lower priority for revision (i.e., this category is marked with “(3)” in the “Findings” column in Table V-1 in the Federal Register notice that presents the 2010 annual review of existing ELGs).

1 4.6 Textiles Category References

1. Gettys, John. 2010. E-mail Communication w ith John Gettys, Deroyal Textiles, and Lauren Wingo, Eastern Research Group, Inc. “RE: DMRs Clarification Needed for Deroyal Textiles - SC0002518.” (Septe mber 7). EPA-HQ-OW-2008-0517 DCN 07302.

2. U.S. Census. 2002. U.S. Economic Census. Available online at: http://www.census.gov/econ/census02.

3

. U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program

Plan . EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346 through 1352.Section 14 – Textile Mills (40 CFR Part 410)



### 14-18 4. U.S. EPA. 2005. Preliminary 2005 Review of Prior itized Categories of Industrial Dischargers . EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-

0016.

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

Plan . EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.

6. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent Guidelines Program Plan . EPA-821-R-07-007. Washingt on, DC. (October). EPA-HQOW-2006-0771-0819.

7. Vickers, Melinda. 2010. Telephone communicat ion with Melinda Vickers, South Carolina Department of Health and Envir onmental Control (SC DH EC), and Elizabeth Sabol, Eastern Research Group, Inc. “Re: DMR Clarificatio n for Toxaphene Discharges

from Mohawk Industries Oak River Plan t.” (September 23). EPA-HQ-OW-2008-0517

DCN 07308.

8. Wood, Denise. 2010. Telephone and E-mail comm unication with Denise Wood, Mohawk Industries, and Elizabeth Sabol and Lauren Wingo, Eastern Research Group, Inc. “Re:

DMR Clarification Needed for Mohawk Indus tries Oak River Plant and Lyerly Plant.” (September 2). EPA-HQ-OW-2008-0517 DCN 07309.Section 15 – Waste Combus tors (40 CFR Part 444)



### 15-1 15. W ASTE 

### C OMBUSTORS 

### (40 CFR P ART 

### 444)

EPA selected the Waste Combustors Category (40 CFR Part 444) for preliminary review because it ranked high, in terms of toxic-weight ed pound equivalent (TWPE) (see Table 5-3 for the point source category rankings ). The Final 2008 Plan summar izes the results of EPA’s previous review of this industry in 2008 (72 FR 61335). This section summarizes the results of

the 2010 annual review associated with the Waste Combustors Category. EPA focused on discharges of hexachlorophene, because of its high TWPE relati ve to the rest of the Waste Combustors Category.

15.1 Waste Combustors Category Background

This subsection provides background on the Waste Combustors Category including a brief profile of the waste combustors industry and background on 40 CFR Part 444.

15.1.1 Waste Combustors Industry Profile

The waste combustors industry includes faciliti es that recover energy from or dispose of wastes (both hazardous and nonhazardous) by incine ration (U.S. EPA, 2008). EPA considered the following four North American Industry Classi fication System (NAICS) codes as part of the Waste Combustors Category:

• 

### 562211: Hazardous Waste Treatment and Disposal;

• 

### 562213: Solid Waste Combustors and Incinerators;

• 

### 562219: Other Nonhazardous Waste Tr eatment and Disposal; and

• 

### WC: Waste Combustors.

Wastewater generated by facilities in NAICS codes 562211, 562213, and 562219 may be regulated under the Centralized Waste Treatme nt (CWT) (40 CFR Part 437), Landfills (40 CFR Part 445) (see Section 8 ), and/or Waste Combustors Categories. EPA reviewed available information about pollutant load and manufact uring operations for f acilities reporting these NAICS codes. In its crosswalk, EPA assigned th e “WC” NAICS code for facilities that most likely fall under the applicability of 40 CFR Part 444, Waste Combustors.

Because the Permit Compliance System (PCS ) and Integrated Compliance Information System - National Pollutant Discharge Elimination System (ICIS-NPDES), the sources of the discharge monitoring report (D MR) data used to develop DMRLoads2008 , report facilities by Standard Industrial Classification (SIC) code, an d the U.S. Economic Census and Toxics Release Inventory (TRI) report data by NAICS code, EPA reclassified the 2008 DMR by the equivalent

NAICS code. Table 15-1 lists the number of facilities from the U.S. Economic Census and the screening-level databases for th e four NAICS codes with operati ons in the Waste Combustors Category; the corresponding SIC c odes are included for reference. The U.S. Economic Census

includes more facilities than the screening-level databases be cause of many possible factors including: facilities may not m eet TRI-reporting thresholds, facil ities may discharge to a publicly owned treatment works (POTW), and some faci lities in the U.S. Economic Census are

distributors or sales faci lities, not manufacturers.Section 15 – Waste Combus tors (40 CFR Part 444)



### 15-2 Table 15-1. Number of Facilities in Waste Combustors Category

NAICS Code Corresponding

SIC Code Number of Facilities

2002 U.S.

Economic Census 2008 DMR

Database a 2008 TRI

Database b

562211: Hazardous Waste Treatment and Disposal 4953: Refuse Systems

4953WC c : Refuse

Systems (Waste

Combustors) 701 1,217 53

562213: Solid Waste

Combustors and Incinerators 120 1

562219: Other Nonhazardous Waste Treatment and Disposal 199 5

WC: Waste Combustors NA 6

Total >1,020 1,217 65

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2 ; and TRIReleases2008_v3

.a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore EPA used an NAICS-to-SICcode crosswalk for comparison purposes. b – Facilities reporting releases to any media. c – Wastewater generated by facilities in SIC code 4953 may be regulated under the CWT, Landfills, and Waste Combustors Categories. In its crosswalk, EPA assigned the extension “WC” to the end of the SIC code for facilities that most likely fall under the applicability of the Waste Combustors Effluent Limitation Guidelines and Standards (ELGs). NA – Not applicable. These facility-specific NAICS codes a ssigned as part of the annual review do not correspond

to NAICS codes in the 2002 U.S. Economic Census.



### Table 15-2 shows whether permitting authorities designated direct discharging facilities in the Waste Combustors Category as mi nor or major dischargers (see Section 4.1.5 ). EPA included data for minor dischargers for the firs t time in the 2010 annual review, as part of
DMRLoads2008_v2 . EPA does not require permitting author ities to submit DMR data for minor dischargers; however, many states do provide complete DMR data for minor dischargers. From the 2010 annual review, EPA observed many data entr y or other errors for minor dischargers in addition to those previously identified for major discharger s, as discussed in Section 4.3

. Table

15-2 shows that approximately 99 percent of the Waste Combustor Category dischargers in the

2008 DMR database are minor dischargers.

Table 15-2. Number of Waste Combustor Facilities by Type of Discharger in DMR 2008

Majors Dischargers Minors Dischargers Total

8 1,210 a 1,217

Source: DMRLoads2008_v2

. a – The DMR data in PCS and ICIS-NPDES does not include discharge data for all minor dischargers. For the facilities in the Waste Combustor Category, 301 of the 1,210 minor dischargers have DMR data. Note: Includes waste combustors reported in both SIC codes 4953 and 4953WC.



### Table 15-3 presents the type of discharges reporte d by facilities in the 2008 TRI database. The majority of waste combustor facilities repo rting to TRI do not report water discharges, but those that do mostly reported direct discharges to surface waters.Section 15 – Waste Combus tors (40 CFR Part 444)



### 15-3 Table 15-3. Waste Combustor Facilities by Discharge Type in 2008 TRI Database

NAICS Code Number of Facilities in 2008 TRI Database

Direct Dischargers Only Indirect Dischargers Only Both

Indirect and

Direct No Water Discharges

562211: Hazardous Waste Treatme nt and Disposal 4 4 1 44

562213: Solid Waste Combustors and Incinerators 1 0 0 0

562219: Other Nonhazardous Waste Treatment and Disposal 2 0 0 3

WC: Waste Combustors 4 0 0 2

Total 11 4 1 49

Source: TRIReleases2008_v3

.



### 15.1.2 40 CFR Part 444

EPA first promulgated ELGs for the Waste Combustors Category (40 CFR Part 444) on January 27, 2000 (65 FR 4381). The Waste Combusto rs ELGs apply to wastewater discharges from hazardous waste combustors, except cement kilns, regulated as “incinerators” or “boilers

and industrial furnaces” under the Resource Conservation and Recovery Act (RCRA). The rule applies solely to commercial facilities (i.e., facil ities that accept wastes from off-site for fee or remuneration). At the time of promulgation, EPA estimated that the rule would apply to eight facilities (U.S. EPA, 2000). Table 15-4 lists the pollutants regulated by Part 444.

Table 15-4. Applicability of Subcategor ies in the Waste Combustor Category

Subpart Name Subpart Applicability Regulated Pollutants

A: Commercial

Hazardous Waste

Combustor (C WHC) The discharge of wastewater from a CHWC facility including any thermal unit, except a cement kiln, if the

thermal unit burns RCRA ha zardous wastes received

from off-site for a fee or other remuneration in the following circumstances. The thermal unit is a

commercial hazardous waste co mbustor if the off-site wastes are generated at a facility not under the same corporate structure or subject to the same ownership as

the thermal unit. TSS, pH, Arsenic, Cadmium, Chromium, Copper, Lead, Mercury, Silver, Titanium, and

Zinc

Source: 40 CFR Part 444; Development Document for Final Effluent Limitations Guidelines and Standards for
Commercial Hazardous Waste Combustors (U.S. EPA, 2000).



### 15.2 Waste Combustors Category Screening Level Review

Table 15-5 shows the screening-level results fo r the Waste Combustors Category from the 2005, 2007, and 2008 TRI and DMR databases. The Waste Combustors Category was excluded from annual reviews prior to 2008 because EPA promulgated the ELGs on January 27, 2000. The TRI TWPE increased from discharge y ear 2007 to 2008, but decreased from discharge year 2005 to 2008. The DMR TWPE in creased by two orders of magnitude from discharge year 2007 to 2008, mainly because of discharges from one facility, discussed below.Section 15 – Waste Combus tors (40 CFR Part 444)



### 15-4 Table 15-5. Waste Combustors Category TRI and DMR Discharges for the 2006 through 2010 Screening-Level Reviews

Year of Discharge Year of Review Waste Combustors Category

TRI TWPE DMR TWPE a Total TWPE

2005 2008 52,300 NA NA

2007 2009 114 3,220 3,260

2008 2010 8,830 245,000 254,000

Source: TRIReleases2002_v4 ; PCSLoads2002_v4 ; TRIReleases2004_v3 ; PCSLoads2004_v3 ; TRIReleases2005_v2 ; TRIReleases2007_v2 ; DMRLoads2007_v4 ; TRIReleases2008_v3 ; and DMRLoads2008_v2

. a – DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and major dischargers. NA – Not applicable. EPA did not evaluate DMR data for 2005.



### Table 15-6 presents the 2008 DMR TWPE by f acility discharge classification. EPA excluded minor dischargers from previous annual reviews, but included them in the 2010 annual review. The majority (70 percent) of the TW PE in the 2008 DMR database is from major dischargers.

Table 15-6. Waste Combustors Category 2008 DMR TWPE by Discharge Classification

Yea r of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers

2008 69,900 176,000

Source: DMRLoads2008_v2

. a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous

annual reviews.



### 15.3 Waste Combustors Category Pollutants of Concern

Table 15-7 lists the five pollutants with the highe st TRI TWPE based on results from the 2010, 2009, and 2007 annual reviews ( TRIReleases2008_v3

, TRIReleases2007_v2 , and
TRIReleases2004_ v3 , respectively). Table 15-8 lists the five pollutant s with the highest DMR TWPE based on results from the 2010, 2009, and 2007 annual reviews ( DMRLoads2008_v2, DMRLoads2007_v3 , and PCSLoads2004_v4 , respectively). As noted in Section 15.2 , the DMR TWPE increase from discharge year 2007 to 2008 is mainly because of discharges from one facility.Section 15 – Waste Combustors (40 CFR Part 444)15-5Table 15-7. Waste Combustors Category Top TRI PollutantsPollutant2004 TRI Databasea2007 TRI Databasea2008 TRI DatabaseaRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPECadmium and CadmiumCompounds423,1901213.8132,550AldrinPollutants not reported in the top five2004 TRI reported pollutants.Pollutants not reported in the top five 2007TRI reported pollutants.212,230Heptachlor311,710Chlordane41797Silver and Silver Compounds522,30052379Nitrate CompoundsPollutants not reported in the top five2004 TRI reported pollutants.228.35Pollutants not reported in the top five2008 TRI reported pollutants.Ethylene Glycol315.23Lead and Lead Compounds424.34Formaldehyde513.5Benzidine11188,000Pollutants not reported in the top five 2007TRI reported pollutants.Toxaphene2134,500Hexachlorobenzene3111,900Waste Combustors CategoryTotalNA11b243,000NA22b114NA16b8,830Source:TRIReleases2004_v3;TRIReleases2007_v2; andTRIReleases2008_v3.a – Discharges include transfers to POTWs and account for POTW removals.b – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 15 – Waste Combustors (40 CFR Part 444)15-6Table 15-8. Waste Combustors Category Top DMR PollutantsPollutant2004 DMR Databasea2007 DMR Databasea2008 DMR Databas)bRankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPERankNumber ofFacilitiesReportingPollutantTWPEHexachlorophenePollutants not reported in the top five 2004DMR reported pollutants.Pollutant not reported in the top five 2007DMR reported pollutants.11172,000Arsenic2181522614,900CalciumPollutants not reported in the top five 2007DMR reported pollutants.3510,900Copper4448,750Sulfate5506,370Cadmium121,290Pollutants not reported in the top five 2008DMR reported pollutants.Mercury32717Selenium42177Lead5382Sulfide121,380Pollutants not reported in the top five DMR2007 reported pollutants.Boron211,360PCB-126031814PCB-124831814PCB-124231814Waste CombustorsCategory TotalNA17c9,087NA4c3,220NA164c245,000Source:PCSLoads2004_v4;DMRLoads2007_v3; andDMRLoads2008_v2.a – 2004 and 2007 DMR data include only major dischargers.b – 2008 DMR data includes major and minor dischargers.c – Number of facilities reporting TWPE greater than zero.NA – Not applicable.Section 15 – Waste Combus tors (40 CFR Part 444)



### 15-7 The Waste Combustors Category combined TWPE is dominated by hexachlorophene discharges, accounting for approximately 68 per cent of the combined TWPE. Additionally, the Waste Combustors Category TWPE in the 2008 TRI database is significantly lower than the 2008 DMR TWPE. Therefore, EPA focused the preliminary category review on hexachlorophene discharges in the 2008 DMR database.

15.4 Waste Combustors Hexachlorophene Discharges in DMR

As part of the 2010 annual review of the Waste Combustors Category, EPA reviewed hexachlorophene discharges in the 2008 DMR database. Approximately 70 percent of the 2008 DMR TWPE results from hexachlorophene discha rges. Only one facility, Clean Harbors Deer Park, reported hexachlorophene discharges.

Clean Harbors Deer Park discharges hexachlorophene from outfall 001. Table 15-9 presents Clean Harbors Deer Pa rk’s quarterly hexachlorophene discharge data from the DMR Loadings Tool. EPA contacted the facility to ve rify the hexachlorophene quantities and flows for outfall 001. The facility contact indi cated that the quantities were re ported as lb/day rather than kg/day. Additionally, the facility contact indicate d that the reported quantities were based on nondetect hexachlorophene concentrations. The quantities were report ed without the below detection limit (BDL) indicator (i.e., “<” sign) because their permit requires them to use the detection limit to calculate the quantity if the concentrations ar e nondetect (Honohan, 2010).

Table 15-9 also presents the facility -provided quantities, converte d to kg/day. Using the revised quantities, Clean Harbors Deer Park’s hexach lorophene discharges are 0 TWPE, reducing the Waste Combustors Category 2008 DMR TWPE by approximately 72 percent, from 245,000 to 73,000 TWPE.

Table 15-9. Clean Harbors Deer Park 2008 Mo nthly Hexachlorophene Discharge Data

Outfall Monitoring Period Date DMR Loadings Tool Average Quantity (kg/day) Facility-Provided Average Quantity (kg/day)

001 31-Jan-08 0.128 <0.058

001 30-Apr-08 0.120 <0.054

001 31-Jul-08 0 .132 <0.060

001 3 1-Oct-08 0.101 <0.046

Source : DMR Loadings Tool; and Facility Contact (Honohan, 2010).



### 15.5 Waste Combustors Category Conclusions

The estimated toxicity of the Waste Combusto rs Category discharges results mainly from the hexachlorophene discharges of one plant (accounting for 72 percent of the category’s 2008 DMR TWPE). The remaining estimated toxicity results mainly from metals discharges. Data

collected for the 2010 annual review demonstrated that wastewater discharge characteristics for this category are consistent with discharges from prior years. As in prior years, EPA makes the following conclusions:

• 

### Bas ed on contacts with Clean Harbors D eer Park, in 2008, the facility did not detect hexachlorophene (i.e., all concentr ations were below th e detection limit).Section 15 – Waste Combus tors (40 CFR Part 444)



### 15-8 EPA then set the hexachlorophene load and TWPE to zero. Correcting this error

decreases the Waste Combustors Cate gory combined 2008 DMR and TRI TWPE to 81,800 TWPE.

• 

### EPA will collect data on metals and pesticides discharges from waste combustors for consideration during the 2011 annual revi ew because the estimated toxicity is primarily from these groups of chemicals.

• 

### EPA will continue monitoring discharges from waste combustors as part of future

annual reviews.

EPA prioritizes point source categories with existing regulations for potential revision based on the greatest estimated toxicity to human health and the environment, measured as TWPE. Based on the above conclusion, EPA is assi gning this category with a lower priority for revision (i.e., this category is marked with “(5)” in the “Findings” column in Table V-1 in the Federal Register notice that presents the 2010 an nual review of existing effluent guidelines and pretreatment standards).

15.6 Waste Combustors Category References

1. Honohan, Kevin, Craig. 2010. E-mail communi cation between Kevin Honohan, Clean Harbors Deer Park, and Eleanor Coddi ng, Eastern Research Group, Inc. “DMRs

Clarification Needed for TX0005941.” (July 8). EPA-HQ- OW-2008-0517 DCN 07282.

2

. U.S. Census. 2002. U.S. Economic Census. Available online at: http://www.census.gov/econ/census02.

3

. U.S. EPA. 2000. Development Document for Final Effluent Limitations Guidelines and Standards for Commercial Hazardous Waste Combustors . EPA-821-R-99-020. Washington, DC. (January). Available online at: http://epa.gov/guide/chwc/ final/technical.html.

4. U.S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program

Plan . EPA-821-R-08-015. Washington, DC. (August). EPA-HQ-OW-2006-0771-1701.Part III – Detailed Studies



### III 

# PART III: DETAILED STUDIESSection 16 – Health Care Industry and Hospitals Category (40 CFR Part 460)



### 16-1 16. H EALTH 

### C ARE 

### I NDUSTRY AND 

### H OSPITALS 

### C ATEGORY 

### (40 CFR P ART 

### 460)

Ph armaceutical chemicals have been detected in our nation's waterways, leading to concerns that these compounds may affect a quatic life and possible human health through drinking water sources. As a result of public comments on the 2006 Final 2006 Plan, EPA initiated a study of unused pharmaceutical disposal pr actices at health care facilities. The focus of this study was on disposal to water via se wers. EPA studied medical facilities; including, hospitals, hospices, long-term care facilities, health car e clinics, physician offices, and veterinary facilities. A standard disposal practice at many health care facilities is to flush unused pharmaceuticals down the toilet or drain.

Un used pharmaceuticals include leftover medicat ion that is expired, not dispensed, and/or partially used, and residues from delivery devices. During the study, EPA conducted intensive

outreach to over 700 stakeholders and evaluated a range of manage ment practices to reduce the generation of unused pharmaceuticals and their disposal down the drain. Based on the information collected through the outreach, EP A has drafted a guidance document, “Best Management Practices for Unused Pharmaceuticals at Health Care Facilities” (U.S. EPA, 2010). The guidance document was made available fo r a 60 day public review and comment as announced in a Federal Register Notice, publ ished on September 8, 2010 (75 FR 54627). The draft guidance document was posted on the Agency’s website.

In summary, the guidance recommends the following practices to prevent or minimize the amount of pharmaceuticals being disposed in water:

• 

### Conduct an inventory of pharmaceuticals and pharmaceutical waste to quantify

the amount of medication the facility is disposing of;

• 

### Reduce pharmaceutical waste by reviewing purchasing practices, use limited dose or unit dose dispensing, replace pharm aceutical samples with vouchers, and perform on-going inventory c ontrol and stock rotation;

• 

### R euse or donate unused pharmaceuticals when possible; return unused pharmaceuticals to the pharmacy; send unused pharmaceuticals to a reverse distributor for credit and proper disposal in accordance with th e facility’s state environmental regulations; prope rly identify and manage hazardous pharmaceutical wastes in accordance with federal and state regulations; use EPA recommended practices to dispose of non- hazardous pharmaceutic al waste at the facility;

• 

### Segregate waste for disposal to ensure regulations are met; and

• 

### T rain staff in proper disposal methods.

EPA received 89 comments on the proposed guidance on November 8, 2010 and is reviewing suggested changes to the document and working with re levant Federal Agencies to ensure any incorporated comments are consistent with other Federal la ws and policies. EPA plans to issue the study report and final guidan ce in 2011 and will notify st akeholders directly and by means of its website at: http://water.epa.gov/scitech/waste tech/guide/unusedpharms_index.cfm

.Section 16 – Health Care Industry and Hospitals Category (40 CFR Part 460)



### 16-2 16.1 Health Care Industry and Ho spitals Category References

1. U.S. EPA. 2010. Draft Guidance Document: Best M anagement Practices for Unused

Pharmaceuticals at Health Care Facilities . EPA-821-R-10-006. Washington, DC. (August 26). Available online at: http://water.epa.gov/scitech/wastete ch/guide/upload/unuseddraft.pdf.Section 17 – Oil and Gas Extraction (40 CFR Part 435)



### 17-1 17. O IL AND 

### G AS 

### E XTRACTION 

### (40 CFR P ART 

### 435)

A s a result of prior 304(m) planning, EPA initiated a detailed study of the coalbed methane industry and its wastewater discharges . Coalbed methane extraction is considered a subcategory of the Oil and Gas Extraction (Oil and Gas) Categor y, although it is not currently subject to the ELGs promulgated for this category. Since 2006, the coalbed methane industry has expanded. In addition, EPA recei ved comments in 2005, 2008, and again during the 2010 review from citizens and environmental advocacy groups requesting development of a regulation for

coalbed methane extraction as well as for shale gas extraction, another subcategory of the Oil and Gas Category. Unlike coalbed methane extr action, however, shale gas extraction is now subject to the Oil and Gas ELG s, although there are currentl y no applicable categorical pretreatment standards for shale gas extraction.

C oalbed methane-produced water discharges can impact receiving surface waters and soils. Saline discharges from coal bed methane operations can adve rsely affect aquatic life. The large volume of water discha rged can also cause stream bank erosion and salt deposition, creating hardpan soil. Long-term impacts include sodium buil dup, reduction of plant diversity, mobilization of salts and other elements, a nd alteration of surface and subsurface hydrology.

1 7.1 Overview of Operations

Methane gas is naturally created during the ge ologic process of converting plant material to coal (coalification). To extract the methane, coalbed methane operators drill wells into coal seams and pump out ground water. Removing the gr ound water from the formation is necessary to produce coalbed methane, as the water remova l reduces the pressure and allows the methane to release from the coal to produce flowing natu ral gas. In 2008, 252 coalbed methane operators managed approximately 55,500 coalbed methane wells in the U.S. in 13 distinct regions, called

basins.

17.2 Produced Water

The ground water that has been pumped out of the well, called "p roduced water," like most ground water found deep below the surface of the earth, has high salinity and can include pollutants such as chloride, sodium, sulfate, bicarbonate, fluoride, iron, barium, magnesium, ammonia, and arsenic. To quantify the amount of pollutants in coalbed methane produced waters, EPA relied on measuring total dissolved solids and electrical conductivity, which are bulk parameters for quantifying the total am ount of dissolved solids in a wastewater.

A single coalbed methane well can discharge t housands of gallons of produced water per day, and may discharge produced water for anywhere from 5 to 15 years. Coalbed methane wells have a distinctive production hist ory characterized by: an early stage when large amounts of water are produced to reduce reservoir pressure whic h in turn encourages release of gas; a stable stage when quantities of produced gas increase as the quantities of produ ced water decrease; and a late stage when the amount of gas produced declines and water production remains low.

T he quantity and quality of produced water varies from basin to basin, within a particular basin, from coal seam to coal seam, and ove r the lifetime of a coalbed methane well. For example, coalbed methane produced water volumes range from 1,000 gallons per day (gpd) per well in the San Juan Basin to 17,000 gpd per well in the Powder River Basin.Section 17 – Oil and Gas Extraction (40 CFR Part 435)



### 17-2 17.2.1 Management of Produced Water

C oalbed methane operators need to dispose of thousands of gallons of produced water per day for each coalbed methane well. Operators can employ a range of options for treatment and management of this wastewater.

Preliminary estimates based on survey data pr edict that approximately 47 billion gallons of produced water are pumped annually from co al seams across the country. Approximately 45 percent of those produced waters ar e directly discharged to waters of the U.S., for a total national discharge of 22 billion gallons per year.

Surface water discharge is most prevalent in three U.S. coalbed methane basins:

• 

### The Black Warrior Basin in Alabama and Mississippi (11 percent of total coalbed methane surface discharges);

• 

### The Powder River Basin in Wyoming and Montana (72 percent of total coalbed methane surface discharges); and

• 

### The Raton Basin in Colorado and New Me xico (11 percent of total coalbed methane surface discharges).

Many of these discharges are largely untreated. Surf ace discharge occurs rarel y, if at all, in the other major commercial basins.

In the other commercial basins in the U.S, coalbed methane operators are, for the most part, able to prevent dischargi ng their produced water by discharg ing the water to land (where there may be other impacts to the soil or vegeta tion), re-injecting the prod uced water back into the ground, or using the water in one of many beneficial use options (e.g., stock watering, irrigation).

17.2.2 Treatment of Produced Waters

Available technology options for adequately removing pollutants from produced water include ion exchange and reverse osmosis.

17.3 Summary of Outreach

In 2007, EPA conducted several site visits to coalbed methane basins throughout the country and gathered information on potential treatment technologies for coalbed methaneproduced water discharges. EPA also conducted wi despread outreach with stakeholders, both in the industry and from the communities adjacent to coalbed methane basins. EPA conducted more

than 30 site visits to locations in 6 coalbed methane basins and met with over 300 different stakeholders. EPA also conducted 13 meetings an d teleconferences with over 150 stakeholders.

In addition to the extensive information co llection through site visits and outreach, EPA acknowledged that an informed decision about rulemaking would require even more detailed information. EPA developed an industry questionn aire, solicited public comment twice, and in 2009 obtained OMB approval under the Paperwork Reduction Act, to conduct a mandatory survey directed at operators of coalbed methan e projects which consist of a single well or a group of wells operated by the same company. The questionnaire colle cted technical and economic data in a two-part survey, a screen er and a detailed survey, on the operations andSection 17 – Oil and Gas Extraction (40 CFR Part 435)



### 17-3 operators of coalbed methane projects. Questi onnaire responses arrive d in early 2010 and the data was used by EPA to create national estimat es of pollutant discharges across the country from the coalbed methane industry and to de velop an economic prof ile of the industry.

In response to the Preliminary 2010 Plan, EPA received 32 comments on coalbed methane extraction. Comments from industry s ources did not support rulemaking for coalbed methane, suggesting an effluent guideline was not appropriate due to the variability of produced water quality, quantity and available management techniques across th e country. Additionally, industry stated that the current regulatory framework of site-specific BPJ permits was adequately addressing pollutant discharges from produced water discharges.

The final detailed study report for coalbed meth ane is being issued concurrent with the Final 2010 Plan (U.S. EPA, 2010).

Coalbed methane production represents about 8 percent of natural ga s production in this country, and coalbed methane extraction is expect ed to continue for decades. Of the 22 billion gallons of water discharged to surface water each year some has high total dissolved solids. The detailed study also found that th ere are readily availa ble technologies to treat this produced water. As a result of the information gathered in the detailed study, EPA has decided to initiate rulemaking for coalbed methane extraction, a curre ntly unregulated subcat egory of the Oil and Gas Category.

17.4 Oil and Gas Extraction References

1. U.S. EPA. 2010. Coalbed Methane Extraction: Detailed Study Report . EPA-821-R-10- 022. Washington, DC. EPA- HQ-OW-2008-0517 DCN 09999.