Z 

United States 

Environmental Protection 

Agency 

Preliminary 2016 Effluent

Guidelines Program Plan
 

June 2016 
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U.S. Environmental Protection Agency
 

Office of Water (4303T)
 

1200 Pennsylvania Avenue, NW
 

Washington, DC 20460
 

EPA-821-R-16-001
 
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TABLE OF CONTENTS
 

Table of Contents 

Page 

1.	 EXECUTIVE SUMMARY ....................................................................................................1-1
 

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

2.1	 The Clean Water Act and the Effluent Guidelines Program................................2-1
 

2.2	 Effluent Guidelines Review and Planning Process..............................................2-3
 

2.2.1	 Annual Review Process ...........................................................................2-4
 

2.2.2	 Effluent Guidelines Program Plans........................................................2-10
 

2.3	 Effluent Limitations Guidelines and Pretreatment Standards Overview...........2-11
 

2.3.1 Best Practicable Control Technology Currently Available (BPT) 

— CWA Sections 301(b)(1)(A) and 304(b)(1)......................................2-12
 

2.3.2	 Best Conventional Pollution Control Technology (BCT) — CWA 

Sections 301(b)(2)(E) and 304(b)(4) .....................................................2-13
 

2.3.3	 Best Available Technology Economically Achievable (BAT) —
 

CWA Sections 301(b)(2)(A) and 304(b)(2)...........................................2-13
 

2.3.4	 New Source Performance Standards (NSPS) — CWA Section 306 .....2-13
 

2.3.5	 Pretreatment Standards for Existing Sources (PSES) — CWA 

Section 307(b)........................................................................................2-13
 

2.3.6	 Pretreatment Standards for New Sources (PSNS) — CWA Section
 

307(c) .....................................................................................................2-14
 

3.	 2015 EFFLUENT GUIDELINES PLANNING PROCESS AND METHODOLOGY ....................3-1
 

3.1	 Summary of the 2015 Annual Review Methodology ..........................................3-1
 

3.1.1	 Toxicity Rankings Analysis (TRA) .........................................................3-1
 

3.1.2	 Preliminary Category Reviews................................................................3-2
 

3.1.3	 Review of Additional Industrial Categories and Pollutants.....................3-3
 

3.2	 Discharges Excluded from EPA’s 2015 Annual Review ....................................3-3
 

3.2.1	 Categories for Which EPA Has Recently Promulgated or Revised
 

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

3.2.2	 Discharges Not Categorizable..................................................................3-4
 

3.3	 Data Quality Assurance and Limitations.............................................................3-5
 

3.3.1	 DMR and TRI Data..................................................................................3-5
 

3.3.2	 Other Data Sources Supporting EPA’s 2015 Annual Review.................3-8
 

4.	 RESULTS OF THE 2015 ANNUAL REVIEW........................................................................4-1
 

4.1	 Findings from EPA’s 2015 TRA and Preliminary Category Reviews................4-1
 

4.2	 Findings from EPA’s Review of Additional Industrial Categories and 

Pollutants............................................................................................................4-13
 

5.	 INDUSTRIES FOR WHICH EPA IS CURRENTLY UNDERTAKING AN ELG
 

RULEMAKING ..................................................................................................................5-1
 

5.1	 EPA’s Current Schedule for ELG Actions ..........................................................5-1
 

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Table of Contents 

TABLE OF CONTENTS (Continued) 

Page 

6.	 ONGOING EPA STUDIES OF INDUSTRIAL DISCHARGES .................................................6-1
 

6.1	 Continued Detailed Study of the Petroleum Refining Category (40 CFR
 

Part 419)...............................................................................................................6-1
 

6.2	 Continued Detailed Study of CWT Category (40 CFR Part 437) .......................6-1
 

6.3	 Continued Preliminary Study of the Metal Finishing Category (40 CFR
 

Part 433)...............................................................................................................6-2
 

7.	 OTHER ONGOING EPA REVIEWS ...................................................................................7-1
 

8.	 OTHER INITIATIVES ........................................................................................................8-1
 

9.	 PRELIMINARY 2016 PLAN DECISIONS AND ACTIONS .....................................................9-1
 

10.	 SUMMARY TABLE OF FINDINGS FOR EXISTING GUIDELINE CATEGORIES FROM
 

THE 2015 ANNUAL REVIEW...........................................................................................10-1
 

11.	 SOLICITATIONS FOR PUBLIC COMMENT AND INPUT....................................................11-1
 

12.	 REFERENCES FOR THE PRELIMINARY 2016 PLAN........................................................12-1
 

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List of Tables and Figures 

LIST OF TABLES 

Page 

Table 3-1. Point Source Categories That Have Undergone Recent Rulemaking ........................ 3-4
 

Table 3-2. TRI and DMR Data Utility and Limitations............................................................... 3-6
 

Table 4-1. Final 2015 Combined Point Source Category Rankings............................................ 4-2
 

Table 10-1. Summary of Findings from EPA’s 2015 Annual Review of Existing
 

Industrial Categories............................................................................................... 10-1
 

LIST OF FIGURES 

Page 

Figure 2-1. Odd-Year Annual Review of Existing ELGs............................................................ 2-7
 

Figure 2-2. Odd-Year Identification of Possible New ELGs....................................................... 2-8
 

Figure 2-3. Even-Year Annual Review of Existing ELGs and Identification of
 

Possible New ELGs .................................................................................................. 2-9
 

Figure 2-4. Further Review of Industrial Categories Identified During Annual Reviews......... 2-10
 

Figure 2-5. Regulations of Direct and Indirect Wastewater Discharges ................................... 2-12
 

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1—Executive Summary 

1. EXECUTIVE SUMMARY 

This Preliminary 2016 Effluent Guidelines Program Plan (Preliminary 2016 Plan), 

prepared pursuant to Clean Water Act (CWA) section 304(m), 33 U.S.C. § 1314(m), identifies 

any new or existing industrial categories selected for effluent guidelines rulemakings and 

provides a schedule for such rulemakings. It also discusses the results of EPA’s annual review of 

effluent limitations guidelines and pretreatment standards (ELGs), consistent with CWA sections 

301(d), 304(b), 304(g), and 304(m) (2015 Annual Review), and it includes EPA’s evaluation of 

indirect discharge categories that do not have categorical pretreatment standards for the purpose 

of identifying potential new categories for which pretreatment standards under CWA section 

307(b) might be warranted. 

At this time, EPA has concluded that no additional industries warrant new or revised 

effluent guidelines. Therefore, EPA is not identifying any existing effluent guidelines for 

possible revision, nor is EPA identifying any new industries for an effluent guidelines 

rulemaking, aside from those currently undergoing a rulemaking.1 EPA is also not identifying 

the development of any new or revised pretreatment standards at this time, beyond those that are 

currently under development.2 

EPA plans to continue its review and/or study of several industrial categories and 

pollutant groups to determine if new or revised effluent guidelines are warranted, as announced 

in the Final 2014 Plan Effluent Guidelines Program Plan (Final 2014 Plan) (U.S. EPA, 2015a). 

These industrial categories consist of Petroleum Refining, Centralized Waste Treatment (CWT), 

Metal Finishing, Pesticide Chemicals, Engineered Nanomaterials Manufacturing and 

Formulating (ENMs), and Oil and Gas Extraction in Cook Inlet, Alaska. In addition, as 

announced in the Final 2014 Plan, EPA plans to continue to collect industrial wastewater 

treatment technology performance data for its Industrial Wastewater Treatment Technology 

(IWTT) Database, for use in future annual reviews. EPA also identified several additional 

categories for further review based on the findings from its 2015 Annual Review, as discussed 

below. 

This Preliminary 2016 Plan and its conclusions are primarily supported by EPA’s 2015 

Annual Effluent Guidelines Review Report (2015 Annual Review Report) (U.S. EPA, 2016a) 

which builds on prior annual reviews to identify certain pollutants in wastewater discharges in 

industrial categories which may not be adequately regulated by current ELGs. The 2015 Annual 

Review Report provides and explains the detailed data, analyses and other information EPA used 

in the 2015 Annual Review of industrial wastewater discharges, and is a part of the record for 

this Preliminary Plan. Annual Review Reports for prior years are part of the Annual Review 

record and can be found at EPA's Effluent Guidelines Plan webpage. 

EPA typically conducts a toxicity rankings analysis (TRA) of industrial categories in odd 

years and provides results in corresponding annual review reports. For the 2015 Annual Review 

EPA’s TRA included those subject to existing ELGs and those not currently regulated by ELGs. 

1 Effluent limitations guidelines and standards (ELGs) for the Canned and Preserved Seafood Category covering the 

Alaskan seafood processing subcategories are currently undergoing a rulemaking. 2 Pretreatment standards for the Dental Category and the Oil and Gas Extraction Category, specifically relating to 

the discharge of pollutants from unconventional oil and gas extraction facilities, are currently under development. 

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1—Executive Summary 

EPA then prioritized for further review those categories whose pollutant discharges may pose the 

greatest hazards to human health or the environment. From these 2015 TRA and preliminary 

category reviews, EPA identified three point source categories that warrant further review: Iron 

and Steel Manufacturing (40 CFR Part 420), Organic Chemicals, Plastics, and Synthetic Fibers 

(OCPSF) (40 CFR Part 414), and Pulp, Paper and Paperboard (40 CFR Part 430). EPA plans to 

continue its review of discharges from these categories during the 2016 annual review period, 

and report findings for these three categories in its Final 2016 Effluent Guidelines Program Plan 

(Final 2016 Plan). 

In addition, as part of the 2015 Annual Review, EPA began reviewing in more detail 

three point source categories that were prioritized for further review based on public comments. 

These categories are Battery Manufacturing (40 CFR Part 461), Electrical and Electronic 

Components Manufacturing (40 CFR Part 469), specifically, Subpart B Electronic Crystals, and 

Rubber Manufacturing (40 CFR Part 428), Subpart A (Tire and Inner Tube Plants Subcategory). 

EPA initiated these reviews to address comments received from stakeholders regarding 

new types of batteries that have been developed, and advances in electrical and electronics 

components manufacturing, since the current ELGs were developed. EPA initiated review of 

rubber manufacturing to determine whether 2-Mercaptobenothiazole (MBT), a chemical 

compound used in tire manufacturing, was being discharged. 

EPA determined that additional review of Rubber Manufacturing related to the discharge 

of MBT from tire manufacturing is not warranted at this time because MBT’s release into the 

environment is not due to industrial wastewater discharges but is primarily from the wear of tires 

on pavement, which is not under the purview of the ELG program. EPA plans to continue 

reviewing Battery Manufacturing and Electrical and Electronic Components manufacturing 

during the 2016 Annual Review. 

During the 30-day public comment period for this Plan, EPA is soliciting public comment 

and data and information on several industrial wastewater discharge topics. See Section 11 of 

this Plan for a discussion of those topics for which EPA is soliciting comments. See the Federal 

Register Notice of Availability for this Plan for instructions on how, and where, to submit 

comments and information. 

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2—Background 

2. BACKGROUND 

This section explains how the Effluent Guidelines Program fits into EPA’s National 

Water Program, describes the general and legal background of the Effluent Guidelines Program, 

and summarizes EPA’s process for making effluent guidelines revision and development 

decisions (i.e., effluent guidelines planning). 

2.1 The Clean Water Act and the Effluent Guidelines Program 

The CWA is based on the principle of cooperative federalism, with distinct roles for both 

EPA and the states, in which the goal is to restore and maintain the chemical, physical, and 

biological integrity of the nation’s waters. To that end, the Act is generally focused on two types 

of controls: (1) water quality-based controls, based on water quality standards, and (2) 

technology-based controls, based on ELGs. 

The CWA gives states the primary responsibility for establishing, reviewing, and revising 

water quality standards. Water quality standards consist of designated uses for each water body 

(e.g., fishing, swimming, supporting aquatic life), criteria that protect the designated uses 

(numeric pollutant concentration limits and narrative criteria such as “no objectionable sediment 

deposits”), and an antidegradation policy. EPA develops recommended national criteria for many 

pollutants, pursuant to CWA section 304(a), 33 U.S.C. § 1314(a), which states may adopt or 

modify, as appropriate, to reflect local conditions. However, any modifications made by states to 

the criteria must be approved by EPA before they can take effect in a state’s water quality 

standards under the Clean Water Act. 

EPA is responsible for developing technology-based ELGs, based on best available 

technologies, for controlling industrial wastewater discharges. ELGs apply to pollutant 

discharges from industrial facilities directly to surface water (direct discharges) and to publicly 

owned treatment works (POTWs) (indirect discharges). For sources discharging directly to 

surface waters, permitting authorities—states authorized to administer the National Pollutant 

Discharge Elimination System (NPDES) permit program, and EPA in the few states that are not 

authorized— must incorporate EPA-promulgated limitations and standards into discharge 

permits, where applicable (U.S. EPA, 2010). For sources discharging indirectly to POTWs, EPA, 

a State, or an approved municipal “control authority” will typically issue a permit or control 

mechanism containing the appropriate effluent limitations and/or local limits in order to obligate 

a facility to be in compliance with the applicable standards and reporting requirements. 

While technology-based ELGs in discharge permits are sometimes as stringent as, or 

more stringent than necessary to meet water quality standards, the effluent guidelines program is 

not specifically designed to ensure that regulated discharges meet the water quality standards of 

the receiving water body. For this reason, the CWA also requires authorized states to establish 

water quality-based effluent limitations where necessary to meet water quality standards. Water 

quality-based limits may require industrial facilities to meet requirements that are more stringent 

than those in a national effluent guideline regulation. In the overall context of the CWA, ELGs 

must be viewed as one tool in the broader set of tools and authorities Congress provided to EPA 

and the states to restore and maintain the quality of the nation’s waters. 

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2—Background 

The 1972 amendments to the Federal Water Pollution Control Act (which then became 

known as the Clean Water Act) marked a distinct change in Congress’s efforts “to restore and 

maintain the chemical, physical, and biological integrity of the Nation’s waters” (see CWA 

section 101(a), 33 U.S. C. 1251(a)). Before 1972, the law focused principally on water quality 

standards. This approach was challenging, however, because of the difficulty in determining 

whether a specific discharger or combination of dischargers was responsible for decreasing the 

water quality in a receiving stream. 

The CWA directed EPA to promulgate ELGs that reflect pollutant reductions achievable 

by categories or subcategories of industrial point sources through the implementation of 

available treatment and prevention technologies. The ELGs are based on specific technologies 

(including process 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)). Unlike other CWA tools, 

ELGs are national in scope and establish pollution control obligations for all facilities that 

discharge wastewater within an industrial category or subcategory. In establishing these controls 

under the direction of the statute, EPA assesses, for example: (1) the performance and 

availability of the pollution control technologies or pollution prevention practices for an 

industrial category or subcategory; (2) the economic achievability of those technologies, which 

can include consideration of the affordability of achieving the reduction in pollutant discharge; 

(3) the cost of achieving effluent reductions; (4) non-water quality environmental impacts 

(including energy requirements); and (5) such other factors as the EPA Administrator deems 

appropriate. 

In passing the CWA, Congress viewed the creation of a single national pollution control 

requirement for each industrial category, based on the “best” technology the industry can afford, 

as a way to reduce the potential creation of “pollution havens” and to set the nation’s sight on 

eliminating pollutant discharge to U.S. waters. Consequently, EPA’s goal in establishing national 

ELGs is to ensure that industrial facilities with similar characteristics, regardless of their location 

or the nature of their receiving water, or POTW into which they discharge, will, at a minimum, 

meet similar effluent guidelines or pretreatment standards representing the performance of the 

“best” pollution control technologies or pollution prevention practices. 

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 are a critical element of the nation’s clean water program and reduce the 

discharge of pollutants that have serious environmental impacts, including pollutants that: 

•	 Kill or impair fish and other aquatic organisms. 

•	 Cause human health problems through the consumption of contaminated water, fish, 

or shellfish. 

•	 Degrade aquatic ecosystems. 

EPA has promulgated effluent guidelines for 58 industrial categories (see Table 10-1, 

below); descriptions of all 58 industrial categories are available at EPA’s Industrial Effluent 

Guidelines webpage. These regulations apply to between 35,000 and 45,000 facilities that 

discharge directly to the nation’s waters, as well as another 12,000 facilities that discharge to 

POTWs (i.e., indirect dischargers). Based on estimates of pollutant reductions from each separate 

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2—Background 

guideline, EPA has estimated that the regulations, cumulatively, have prevented the discharge of 

over 700 billion pounds of toxic pollutants annually. 

2.2 Effluent Guidelines Review and Planning Process 

In addition to establishing new regulations, the CWA requires EPA to review existing 

effluent guidelines annually. EPA reviews all point source categories subject to existing effluent 

guidelines and pretreatment standards to identify potential candidates for revision, consistent 

with CWA sections 304(b), 301(d), 304(m)(1)(A) and 304(g). EPA also reviews industries 

consisting of direct-discharging facilities not currently subject to effluent guidelines to identify 

potential candidates for effluent guidelines rulemakings, pursuant to CWA section 304(m)(1)(B). 

Finally, EPA reviews industries consisting entirely or almost entirely of indirect-discharging 

facilities that are not currently subject to pretreatment standards, to identify potential candidates 

for pretreatment standards development under CWA section 307(b). 

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

•	 Restore and maintain the chemical, physical, and biological integrity of the nation’s 

waters. 

•	 Provide transparent decision making and involve stakeholders early and often during 

the planning process. 

EPA uses four major factors to prioritize existing effluent guidelines and pretreatment 

standards for possible revision. These factors were developed in EPA’s draft National Strategy 

(U.S. EPA, 2002). 

The first factor EPA considers is a combination of the amount and type of pollutants in an 

industrial category’s discharge and the relative hazard posed by that discharge. This factor 

enables EPA to prioritize rulemakings that could produce the greatest environmental and health 

benefits. 

The second factor EPA considers is the performance and cost of applicable and 

demonstrated wastewater treatment technologies, process changes, and pollution prevention 

alternatives that could effectively reduce pollutant concentrations in the industrial category’s 

wastewater. 

The third factor EPA considers is the affordability 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 industry indicates that it would not be 

affordable to implement expensive and stringent new requirements, EPA might conclude that a 

less stringent or less expensive approach to reduce pollutant loadings would better satisfy 

applicable statutory requirements. EPA might also conclude that a wastewater treatment 

technology, process change, or pollution prevention measure was not economically achievable 

for a particular industry. 

The fourth factor EPA considers is the opportunity to eliminate inefficiencies or 

impediments to pollution prevention or technological innovation, or opportunities to promote 

innovative approaches. This factor might also prompt EPA, during annual reviews, to decide 

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2—Background 

against revising an existing set of effluent guidelines or pretreatment standards if the pollutant 

source is already efficiently and effectively controlled by other regulatory or non-regulatory 

programs. 

2.2.1 Annual Review Process 

EPA’s annual review process includes an odd-and even-year annual review cycle, to 

address cohesively and comprehensively the factors laid out in EPA’s draft National Strategy. In 

the odd-year reviews, EPA screens industrial dischargers through a toxicity rankings analysis 

(TRA) that identifies and ranks those categories whose reported pollutant discharges pose a 

substantial hazard to human health and the environment (See Figure 2-1 and Figure 2-2). EPA 

assesses the relative hazard of these discharges by applying toxic weighting factors (TWFs) to 

the annual pollutant discharges reported on discharge monitoring reports (DMRs); and to the 

Toxics Release Inventory (TRI) for a category to calculate the total discharge of toxic pollutants 

as toxic-weighted pound equivalents (TWPE) for a category. EPA then ranks the industrial 

categories based on total TWPE discharged. 

In the even years, EPA reviews additional hazard data sources and conducts alternate 

analyses to enhance the identification of industrial categories for which new or revised ELGs 

may be appropriate (beyond those that traditionally rank high in the TRA). This is consistent 

with the Government Accountability Office (GAO) recommendation that EPA’s annual review 

approach include additional industrial hazard data sources to augment its screening-level review 

of discharges from industrial categories.

3 Furthermore, EPA recognizes the value in considering, 

in the screening phase, the availability of treatment technologies, process changes, or pollution 

prevention practices that can reduce the identified hazards. Specifically, in the even-year 

reviews, EPA targets new data sources that will provide information not previously captured as 

part of the TRA, including, but not limited to, the following: 

•	 Industrial process changes. 

•	 Emerging contaminants of concern. 

•	 Advances in treatment technologies and pollution prevention practices. 

•	 Availability of new, more sensitive analytical methods. 

•	 Other hazard data and information not captured in the TRA and/or suggested by 

stakeholders or by public comments. 

Figure 2-3 illustrates the even-year review process. See Section 3 of this Preliminary 

2016 Effluent Guidelines Program Plan (Preliminary 2016 Plan), for details on the methodology 

used specifically for EPA’s 2015 Annual Review. 

EPA also conducts a more detailed preliminary category review of those industrial 

discharge categories that (1) rank highest in terms of TWPE (i.e., pose the greatest hazard to 

human health and the environment) in the TRA, (2) are identified as warranting further review 

during the even-year analyses, or (3) are otherwise brought to its attention through stakeholder or 

3 GAO’s recommendations for the review of additional hazard data sources were published in GAO’s September 

2012 report Water Pollution: EPA Has Improved Its Review of Effluent Guidelines But Could Benefit from More 

Information on Treatment Technologies. 

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2—Background 

public comments. If EPA determines that further review is appropriate for an industrial category, 

EPA may complete a preliminary or detailed study of the point source category (see Section 

2.2.1.1 and Section 2.2.1.2, respectively), which may eventually lead to a new or revised 

guideline. 

2.2.1.1 Preliminary Category Reviews 

EPA may conduct a preliminary category review for industrial categories (1) identified in 

the TRA as having the highest hazard potential, (2) identified as a priority by any of the evenyear review analyses, or (3) otherwise brought to EPA’s attention through stakeholder or public 

comments. EPA is particularly likely to conduct a preliminary category review if it lacks 

sufficient data to determine whether regulatory action would be appropriate (as illustrated in 

Figure 2-4). EPA may complete preliminary category reviews as part of the annual review cycle, 

depending on the industrial categories warranting review at that time or may extend the review 

into the next cycle. In its preliminary category reviews, EPA may examine the following: (1) 

wastewater characteristics and pollutant sources, (2) the pollutants driving the toxic-weighted 

pollutant discharges, (3) availability of pollution prevention 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 toxicity ranking results 

or pollutant discharges identified as a priority from other sources and fill in data gaps. Next, EPA 

considers the factors that may be contributing to these discharges. These include, for example, 

whether the discharges are primarily driven by a few facilities or are more widespread within a 

category. These assessments provide an additional level of quality assurance for the reported 

pollutant discharges and number of facilities that represent the majority of toxic-weighted 

pollutant discharge. EPA may also review readily available technologies and approaches for 

reducing the discharges. 

During a preliminary category review, EPA may consult data sources including, but not 

limited to the following: (1) the U.S. Economic Census, (2) TRI and DMR data, (3) trade 

associations and reporting facilities that can verify reported releases and facility categorizations, 

(4) regulatory authorities (states and EPA regions) that can clarify how category facilities are 

permitted, (5) NPDES permits and their supporting fact sheets, (6) EPA effluent guidelines 

technical development documents, (7) relevant EPA preliminary data summaries or study 

reports, and (8) technical literature on pollutant sources and control technologies. If a 

preliminary category review reveals that the reports of toxic discharges are correct and are likely 

to be the result of the production practices widely used throughout the category, or technology 

approaches may exist for further controlling the pollutants, EPA may decide to conduct a 

preliminary or detailed study prior to initiating a rulemaking. 

2.2.1.2 Preliminary and Detailed Studies 

After conducting the preliminary category reviews (depicted in Figure 2-4), EPA may 

then conduct a study, at different levels of detail, of an industrial category. Typically, EPA has 

conducted two types of studies; preliminary studies and detailed studies. A preliminary study is 

usually more introductory in its level of information collection and evaluation than a detailed 

study. Both types of studies usually profile an industry category, gather information about its 

wastewater discharges, collect information about availability and cost of treatment and pollution 

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2—Background 

prevention technologies, assess the financial status of the facilities in the category, and 

investigate other factors to determine if it would be appropriate to identify the category for 

possible effluent guidelines revision. During preliminary or detailed studies, EPA also typically 

examines the factors and data sources listed above for preliminary category reviews. However, 

during a detailed study, EPA’s examination of a point source category and available pollution 

prevention and treatment options is generally more rigorous than the analyses conducted during a 

preliminary category review or preliminary study, and may include primary data collection 

activities, such as industry questionnaires and wastewater sampling and analysis, to fill data 

gaps. In many cases, the information and data gathered for a study comprises the basis of the 

rulemaking. However, in other instances, the additional data and information gathered may 

indicate that a new or revised guideline is not warranted. Regardless of the outcome, EPA 

describes for the public and other stakeholders its decisions to conduct studies, or to develop 

rulemakings, in the Effluent Guidelines Program Plan.4 When a rulemaking is determined 

appropriate, schedules are also described in the Plan. 

4 While EPA describes such decisions in its plans, EPA may elect to describe them first on its website or through a 

venue other than the plan. 

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2—Background 

* If EPA is aware of new segment growth within such a category or new concerns are identified, EPA may do 

further review. 

Figure 2-1. Odd-Year Annual Review of Existing ELGs 

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2—Background 

* Significant concentrations may include levels above minimum levels from 40 CFR Part 136 or other EPAapproved methods, levels above treatable levels, or levels of concern to human health and toxicity. 

Figure 2-2. Odd-Year Identification of Possible New ELGs 

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2—Background 

* Significant concentrations may include levels above minimum levels from 40 CFR Part 136 or other EPAapproved methods, levels above treatable levels, or levels of concern to human health and toxicity. 

Figure 2-3. Even-Year Annual Review of Existing ELGs and Identification of 

Possible New ELGs 

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2—Background 

Figure 2-4. Further Review of Industrial Categories Identified During Annual Reviews 

2.2.2 Effluent Guidelines Program Plans 

CWA section 304(m)(1)(A) requires 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 ELGs that EPA has promulgated under that section. 

EPA’s 2015 Annual Effluent Guidelines Review Report (2015 Annual Review Report) presents 

the results of its ELG reviews (U.S. EPA, 2016a). The 2015 Annual Review Report provides 

and explains the detailed data, analyses and other information EPA used in the 2015 annual 

review of industrial wastewater discharges, and is a part of the record for this Preliminary Plan. 

Under the even- and odd-year annual review approach described above in Section 2.2.1, 

EPA coordinates its annual reviews of existing ELGs under section 304(b) with its publication of 

Preliminary and Final Plans, under CWA section 304(m). As a result, Final Plans typically 

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2—Background 

present the compilation of the odd- and even-year reviews and any public comments received on 

the Preliminary Plan. EPA may initiate, continue, or complete preliminary category reviews or 

in-depth studies during the odd- or even-year reviews. Additionally, EPA may publish the 

conclusions from these studies as part of the Preliminary or Final Plan, based on when during the 

planning cycle the study or review is completed. 

EPA coordinates its annual reviews under section 304(b) with publication of Plans under 

section 304(m) for several reasons. First, the annual reviews are inextricably linked to the 

planning effort because each review year’s results can inform the content of the Preliminary and 

Final Plans (e.g., by identifying candidates for ELG revision, or by identifying point source 

categories for which EPA has never promulgated ELGs). Second, even though it is not required 

to do so under either section 304(b) or section 304(m), EPA serves the public interest by 

periodically describing the annual review results (including the review process). Doing so while 

simultaneously publishing the Preliminary and Final Plans makes both processes more 

transparent. Third, by requiring EPA to review existing ELGs each year, EPA understands 

Congress to have intended for each successive review to build on the results of earlier reviews. 

2.3 Effluent Limitations Guidelines and Pretreatment Standards Overview 

The effluent guidelines program is one component of the Nation’s clean water program, 

established by the 1972 Clean Water Act and subsequent amendments. The effluent guidelines 

program is authorized under CWA sections 301, 304, 306, and 307, 33 U.S.C. §§ 1311, 1314, 

1316, 1317. In summary, the CWA directs EPA to promulgate categorical regulations through 

the following six levels of control: 

1. Best practicable control technology currently available (BPT). 

2. Best conventional control technology (BCT). 

3. Best available technology economically achievable (BAT). 

4. New source performance standards (NSPS). 

5. Pretreatment standards for existing sources (PSES). 

6. Pretreatment standards for new sources (PSNS). 

For point sources that discharge pollutants directly into surface waters (direct 

dischargers), the effluent limitations and standards promulgated by EPA are implemented 

through NPDES permits (see CWA sections 301(a), 301(b), 402; 33 U.S.C. §§ 1311(a), 1311(b), 

1342). For point sources that discharge to POTWs (indirect dischargers), EPA promulgates 

pretreatment standards that apply directly to those sources and are enforced by POTWs and by 

state and federal authorities. See CWA sections 307(b), 307(c); 33 U.S.C. § 1317(b), 1317(c). 

Figure 2-5 illustrates the relationship between the regulation of direct and indirect dischargers. 

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2—Background 

Figure 2-5. Regulations of Direct and Indirect Wastewater Discharges 

2.3.1	 Best Practicable Control Technology Currently Available (BPT) — CWA Sections 

301(b)(1)(A) and 304(b)(1) 

EPA develops effluent limitations based on BPT for conventional, toxic, and 

nonconventional pollutants. CWA section 304(a)(4) designates the following as conventional 

pollutants: biochemical oxygen demand (BOD5), total suspended solids, fecal coliform, pH, and 

any additional pollutants defined by the Administrator as conventional. The Administrator 

designated oil and grease as an additional conventional pollutant on July 30, 1979 (see 44 FR 

44501). EPA has identified 65 pollutants and classes of pollutants as toxic, among 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 pollutants are considered to be nonconventional. 

In specifying BPT, EPA looks at numerous factors. EPA first considers the total cost of 

applying the control technology in relation to the effluent reduction benefits. It also considers the 

age of the equipment and facilities, the processes employed and any required process changes, 

engineering aspects of the control technologies, non-water-quality environmental impacts 

(including energy requirements), and such other factors the EPA Administrator deems 

appropriate (see CWA section 304(b)(1)(B)). Traditionally, EPA establishes BPT effluent 

limitations by averaging the best performances of facilities of various ages, sizes, processes, or 

other common characteristics within the industry. Where existing performance is uniformly 

inadequate, BPT may reflect higher levels of control than currently in place in an industrial 

category, if EPA determines that the technology can be applied practically. 

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2—Background 

2.3.2	 Best Conventional Pollution 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 for 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 after considering a two-part, “cost-reasonableness” test. EPA 

explained its methodology for the development of BCT limitations in 1986 (see 51 FR 24974; 

July 9, 1986). 

2.3.3	 Best Available Technology Economically Achievable (BAT) — CWA Sections 

301(b)(2)(A) and 304(b)(2) 

For toxic pollutants and nonconventional pollutants, EPA promulgates effluent 

limitations guidelines which require application of the BAT (see CWA sections 301(b)(2)(A) and 

304(b)(2)(B)). 

The CWA factors relating to the assessment of best available technology economically 

achievable shall take into account the age of equipment and facilities involved, the process 

employed, the engineering aspects of the application of various types of control techniques, 

process changes, the cost of achieving such effluent reduction, non-water quality environmental 

impact (including energy requirements), and such other factors as the Administrator deems 

appropriate (see CWA section 304(b)(2)(B)). 

In addition to end-of-pipe wastewater treatment, BAT limitations may be based on 

effluent reductions attainable through changes in a facility’s processes and operations. Where 

existing performance is uniformly inadequate, BAT may reflect a higher level of performance 

than is currently being achieved within a particular subcategory, based on technology transferred 

from a different subcategory or category. BAT may be based upon process changes or internal 

controls, even when these technologies are not common industry practice. 

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

NSPS reflect effluent reductions based on the best available demonstrated control 

technology. New sources have the opportunity to install the best and most efficient production 

processes and wastewater treatment technologies. As a result, NSPS should represent the most 

stringent controls attainable through the application of the best available demonstrated control 

technology for all pollutants (i.e., conventional, nonconventional, and priority pollutants). In 

establishing NSPS, EPA considers the cost of achieving the effluent reduction and any non-water 

quality environmental impacts and energy requirements (see CWA section 306(b)(1)(B)). 

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

PSES apply to indirect dischargers and are designed to prevent the discharge of pollutants 

that pass through, interfere with, or are otherwise incompatible with the operation of POTWs, 

including wastewater conveyance and sludge disposal. Pretreatment standards are technologybased and are analogous to BAT effluent limitations guidelines (see CWA section 301(b)(1)(A)). 

2-13
 
 

 

2—Background 

The General Pretreatment Regulations, which set forth the framework for implementing 

national pretreatment standards, are found at 40 CFR Part 403. 

2.3.6 Pretreatment Standards for New Sources (PSNS) — CWA Section 307(c) 

Like PSES, PSNS apply to indirect dischargers and are designed to prevent the 

discharges of pollutants that pass through, interfere with, or are otherwise incompatible with the 

operation of POTWs. PSNS are to be issued at the same time as NSPS (see CWA section 

307(c)). New indirect dischargers have the opportunity to incorporate the best available 

demonstrated technologies in their plants. EPA considers the same factors in promulgating PSNS 

as it does in promulgating NSPS. 

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3—2015 Effluent Guidelines Planning Process and Methodology 

3. 2015 EFFLUENT GUIDELINES PLANNING PROCESS AND METHODOLOGY 

This section summarizes the process EPA used in its 2015 Annual Review to identify 

industrial categories for potential development of new or revised ELGs, as well as the data 

sources and limitations used to complete this review. This process consists of the following: 

•	 Performing a TRA to identify and rank categories with pollutant discharges that may 

pose a substantial hazard to human health and the environment. 

•	 Conducting preliminary category reviews for the industrial categories with the 

highest hazard potential identified from the TRA; and 

•	 Reviewing additional industrial categories and chemicals brought to EPA’s attention 

through stakeholder comments and input, to evaluate recent changes within the 

industries as well as potential pollutant releases to the environment through industrial 

wastewater discharge that may not be adequately regulated by current effluent 

guidelines. 

3.1 Summary of the 2015 Annual Review Methodology 

This section briefly summarizes EPA’s 2015 Annual Review methodology for the TRA, 

preliminary category reviews, and the review of additional industrial categories and pollutants. 

For more information and details on EPA’s 2015 Annual Review methodology and analyses, see 

EPA’s 2015 Annual Effluent Guidelines Review Report (2015 Annual Review Report) (U.S. 

EPA, 2016a). 

3.1.1 Toxicity Rankings Analysis (TRA) 

For the 2015 Annual Review, EPA performed a TRA of all industrial categories to: (1) 

evaluate reported discharges from categories subject to existing ELGs, as well as potential new 

categories, and (2) prioritize for further review those categories discharging high levels of toxic 

pollutants relative to other categories. See Section 2.0 of the 2015 Annual Review Report for 

more details on the TRA methodology and data sources (U.S. EPA, 2016a). 

As a first step in the TRA, EPA downloaded 2013 industrial rankings data from the DMR 

Pollutant Loading Tool (DMR Loading Tool).5 The DMR Loading Tool generates industrial 

rankings using TRI data and DMR data from the Integrated Compliance Information System for 

the National Pollutant Discharge Elimination System (ICIS-NPDES), in accordance with EPA’s 

odd-year annual review methodology. EPA’s odd-year annual review methodology was 

previously described in the Technical Support Document for the Annual Review of Existing 

Effluent Guidelines and Identification of Potential New Point Source Categories (2009 

Screening-Level Analysis (SLA) Report) (U.S. EPA, 2009a), and is outlined below: 

1.	 TRI and DMR data do not identify the ELGs applicable to a particular facility. 

However, TRI includes information on a facility’s North American Industry 

5 See the DMR Pollutant Loading Tool page which presents the top industrial dischargers of toxic pollutants. EPA 

used this section of the DMR Pollutant Loading Tool to inform its 2015 TRA. The tool is maintained by EPA’s 

Office of Enforcement and Compliance Assurance, Office of Compliance. 

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3—2015 Effluent Guidelines Planning Process and Methodology 

Classification System (NAICS) code, while DMR data include information on a 

facility’s Standard Industrial Classification (SIC) code. Thus, as a first step, the DMR 

Loading Tool relates each facility’s SIC and NAICS code to an industrial category.6 

2.	 Next, the DMR Loading Tool uses the data reported in TRI and DMR for a specific 

year to calculate the pounds of pollutant discharged from facilities to U.S. waters. The 

tool performs these calculations for toxic, nonconventional, and conventional 

pollutants. For indirect dischargers, the tool adjusts the facility discharges to account 

for removals that occur at the POTW. 

3.	 The DMR Loading Tool then applies TWFs7 to the annual pollutant discharges to 

calculate the total discharge of toxic pollutants as TWPE for each facility. 

4.	 Lastly, the DMR Loading Tool sums the TWPE for each facility in an industrial 

category to calculate a total TWPE per category for that year. The tool calculates two 

TWPE estimates for each industrial category: (1) an estimate based on data in TRI 

and (2) an estimate based on DMR data. EPA adds these two estimates together to 

generate a single TWPE value for each industrial category. EPA then ranks the 

categories according to their total TWPE discharged. EPA takes this approach 

because it found that combining the TWPE estimates from TRI and DMR data into a 

single TWPE number highlights those industries with the most toxic pollution.8 

After downloading DMR and TRI industrial rankings data, EPA performed a quality 

review of the data (see Section 3.3 of this Preliminary 2016 Plan for further details on the data 

sources and EPA’s data quality review). From this review, EPA identified and made corrections 

to the 2013 DMR and TRI data, as appropriate (see Appendix D of the 2015 Annual Review 

Report for a complete list of data corrections (U.S EPA, 2016a)). EPA downloaded the corrected 

data into a set of static databases and summed the DMR and TRI TWPE for all facilities in each 

industrial category. EPA then re-ranked the industrial categories based on the corrected total 

TWPE to generate the final 2015 point source category rankings. As discussed below, EPA used 

the final point source category rankings to prioritize industrial categories for further preliminary 

category review. Section 4.1 of this Preliminary 2016 Plan presents the findings of EPA’s 2015 

TRA. 

3.1.2 Preliminary Category Reviews 

Based on the final 2015 combined point source category rankings generated from the 

TRA, EPA prioritized for further review those industrial categories whose pollutant discharges 

potentially pose the greatest hazards to human health or the environment because of their 

toxicity. To identify these industrial categories, EPA calculated the industrial categories 

cumulative percent of the total TWPE. EPA identified and focused its preliminary category 

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

the 2009 SLA Report (U.S. EPA, 2009a). 7 For more information on TWFs, see Toxic Weighting Factors Methodology (U.S. EPA, 2012b). 8 Different pollutants may dominate the TRI and DMR TWPE 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 toxic discharge data in both TRI and DMR. Although this 

approach could theoretically lead to double-counting, EPA’s review of the data indicates that, because the two 

databases tend to focus on different pollutants, double-counting is minimal and does not affect the order of the topranked industrial categories. 

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3—2015 Effluent Guidelines Planning Process and Methodology 

reviews on the 18 industrial categories that collectively discharge over 95 percent of the total 

TWPE. EPA performed the preliminary category reviews in accordance with Section 2.2.1.1 of 

this 2016 Preliminary Plan. 

EPA documented the quality of the data supporting its preliminary review of these 

industrial categories, analyzed how the data could be used to characterize the industrial 

wastewater discharges, and prioritized the findings for further review. See Section 3.3 of this 

Preliminary 2016 Plan for more information on data usability and quality of the data sources 

supporting the preliminary category reviews. Section 4.1 of this Plan presents the findings from 

EPA’s preliminary category reviews. 

3.1.3 Review of Additional Industrial Categories and Pollutants 

As part of the 2015 Annual Review, EPA also initiated a review of two additional point 

source categories that were not identified as categories warranting further review in the 2015 

TRA: Battery Manufacturing (40 CFR Part 461) and Electrical and Electronic Components (40 

CFR Part 469), specifically Subpart B Electronic Crystals. In addition, EPA reviewed in more 

detail MBT, a chemical compound used in tire manufacturing. Tire manufacturing is covered 

under the Rubber Manufacturing Point Source Category (40 CFR Part 428), Subpart A (Tire and 

Inner Tube Plants Subcategory)). 

EPA initiated these reviews to address comments received from the public and other 

stakeholders regarding recent changes in these industries and the potential for new pollutant 

releases to the environment through their wastewater discharges. As part of these reviews, EPA 

revisited the existing ELGs and supporting development documents, examined recent changes to 

the industries, including new processes and technologies that may be generating new pollutants 

of concern, or industrial wastewater discharge sources not previously considered, and reviewed 

readily available data on current discharges. 

EPA documented the quality of the data supporting its review of these industrial 

categories, analyzed how the data could be used to characterize the industrial wastewater 

discharges, and prioritized the findings for further review. See Section 3.3 of this Preliminary 

2016 Plan for more information on the usability and quality of the data sources supporting these 

additional reviews. Section 4.2 of this report presents the findings from EPA’s review of these 

additional industrial categories and pollutants. 

3.2 Discharges Excluded from EPA’s 2015 Annual Review 

Consistent with its previous annual reviews, EPA eliminated the following from further 

consideration during its 2015 Annual Review: 

•	 Discharges from industrial categories for which EPA has recently promulgated or 

revised ELGs (within the past seven years). 

•	 Discharges from facilities that require a NPDES permit, but do not fall under an 

existing or new point source category or subcategory (e.g., Superfund sites). 

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3—2015 Effluent Guidelines Planning Process and Methodology 

3.2.1 Categories for Which EPA Has Recently Promulgated or Revised ELGs 

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

industrial categories for which ELGs were recently established or revised but are not yet fully 

implemented. In general, EPA removes an industrial point source category from further 

consideration during a review cycle if EPA established or revised the category’s ELGs within 

seven years of the annual reviews. This seven-year period allows time for the ELGs to be 

incorporated into NPDES permits. Table 3-1 lists the categories EPA excluded from the 2015 

Annual Review due to this seven-year period. 

Table 3-1. Point Source Categories That Have Undergone Recent Rulemaking 

40 CFR Part Point Source Category Date of Rulemaking 

450 Construction and Development March 6, 2014 

449 Airport Deicing May 16, 2012 

423 Steam Electric Power Generating September 30, 2015 

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

reviews industrial categories or subcategories that are subjects of an ongoing rulemaking 

process. These include the Canned and Preserved Seafood Category (covering the Alaskan 

seafood processing subcategories), dental practices (specifically, relating to the discharge of 

mercury found in dental amalgam), and the Oil and Gas Extraction Category, specifically 

relating to the discharge of pollutants from unconventional oil and gas extraction facilities. See 

Section 5 of this Preliminary 2016 Plan for details on the rulemaking status of these categories. 

Industrial categories or subcategories for which EPA had recently considered developing 

or revising ELGs were not reviewed by EPA in its final 2015 point source category rankings and 

TRA. This is because EPA thoroughly reviewed these categories separately from the annual 

review process. This includes a subcategory of facilities that produce chlorine and chlorinated 

hydrocarbons (CCH) that fall within either the Organic Chemicals, Pesticides, and Synthetic 

Fibers (40 CFR Part 414) or the Inorganic Chemicals Manufacturing (40 CFR Part 415) point 

source categories. This review was limited to only those facilities producing CCH and did not 

include the remainder of the OCPSF or Inorganic Chemicals categories. Similarly, EPA did not 

review coalbed methane extraction in the Oil and Gas Extraction Category (40 CFR Part 435). 

See Section 5 of EPA’s Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans 

(U.S. EPA, 2014) for details on EPA’s determinations related to these categories. 

3.2.2 Discharges Not Categorizable 

EPA identified some discharges that cannot be categorized into existing or new point 

source categories or subcategories. As part of the 2011 Annual Review, EPA reviewed high 

TWPE discharges from a Superfund site (Auchterlonie, 2009; U.S. EPA, 2012a). Direct 

discharges from Superfund sites, whether made on site or off site, are subject to NPDES 

permitting requirements (U.S. EPA, 1988a, 1988b). For the reasons discussed below, EPA 

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

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

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3—2015 Effluent Guidelines Planning Process and Methodology 

EPA determined that discharges from Superfund sites are too varied to be categorized 

into a single point source category. In particular, they vary by: 

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

•	 Treatment technologies (e.g., air stripping, granular activated carbon, 

chemical/ultraviolet oxidation, aerobic biological reactors, chemical precipitation). 

•	 Types of facilities causing groundwater contamination (e.g., wood treatment 

facilities, metal finishing and electroplating facilities, drum recycling facilities, 

mines, mineral processing facilities, radium processing facilities). 

•	 In addition, the duration and volume of Superfund site direct discharges vary 

significantly due to differences in aquifer characteristics and in the magnitude, fate, 

and transport of contaminants in aquifers and vadose zones. 

Currently, permit writers for Superfund sites determine technology-based effluent limits 

using their best professional judgment. The permit must also call for more stringent effluent 

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

site-specific, best professional judgment approach is workable and flexible within the context of 

a Superfund cleanup (U.S. EPA, 2012a). 

3.3 Data Quality Assurance and Limitations 

This section discusses the data sources supporting the 2015 Annual Review and their 

limitations. EPA’s methodology for the 2015 Annual Review involved several components, as 

discussed in Section 3.1, including the TRA, preliminary category reviews, and review of 

additional industrial categories and pollutants. As in previous annual reviews, EPA continued to 

rely on TRI and DMR data, downloaded from the DMR Loading Tool, during the 2015 Annual 

Review. EPA also used the following data source categories to support its 2015 Annual Review: 

•	 Conference proceedings, peer-reviewed journals, other academic literature. 

•	 State and local government information provided in telephone calls and email 

correspondence. 

•	 Federal, state, and local government publications. 

•	 Data and information obtained from industry and trade associations. 

•	 Other (non-industry) publications. 

3.3.1 DMR and TRI Data 

Previously, in its 2009 SLA Report, EPA explained its use of DMR and TRI data (U.S. 

EPA, 2009a).9 This report provides details of the methods used to process thousands of data 

records and generate national estimates of industrial effluent discharges. Section 2.1 of the 2015 

9 The 2009 SLA Report describes the odd-year annual review methodology and EPA’s use of DMR and TRI data. 

This report is separate from the Technical Support Document for the Preliminary 2010 Effluent Guidelines Program 

Plan (U.S. EPA, 2009b). 

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3—2015 Effluent Guidelines Planning Process and Methodology 

Annual Review Report describes in detail EPA’s quality evaluation of the 2013 DMR and TRI 

data (used to support the 2015 Annual Review) and the data’s limitations (U.S. EPA, 2016a). 

In general, EPA uses DMR data to evaluate direct discharges of pollutants to waters of 

the U.S. that are regulated by a permit in which monitoring is required. More than 250,000 

industrial facilities and 17,000 wastewater treatment plants have NPDES individual permits or 

general permits10 for wastewater discharges to U.S. waters. Facilities must report compliance 

with NPDES permit requirements via DMRs. DMR data can include pollutant concentrations 

and/or quantities, flow, and identification of permit violations. Thus, DMR data provide readily 

available and relevant information on industrial pollutant discharges to surface waters (i.e., direct 

discharges). 

In comparison, EPA generally uses TRI data to evaluate indirect discharges of pollutants 

to POTWs, as well as the direct discharge of pollutants to waters of the U.S. that are not 

regulated via NPDES permits. TRI requires facilities that meet operating thresholds to report onsite releases of certain listed toxic chemicals to receiving streams and POTWs, as well as other 

media (e.g., air, land, underground wells, etc.). In addition, the list of chemicals reported to TRI 

can be broader than the chemicals for which facilities have NPDES permit limitations or 

monitoring requirements, and therefore reported on DMRs. Thus, TRI data provide 

supplementary information to DMR data regarding potential additional pollutants that may be 

discharged by an industrial category. However, as discussed below, TRI data are somewhat 

limited in utility due to TRI reporting requirements, including requirements that allow facilities 

to report releases that are based on estimates and not actual sampling data. Table 3-2 describes 

the utility and limitations of the DMR and TRI data. 

Table 3-2. TRI and DMR Data Utility and Limitations 

TRI DMR 

Utility of Data 

National scope. National scope. 

Includes releases to POTWs, not just direct 

dischargers to surface waters. 

Discharge reports are based on effluent chemical analysis 

and metered flows. 

Includes releases of many toxic chemicals, not just 

those on the facility permit. 

Includes discharge data from facilities classified by SIC 

code. 

Includes discharge data from facilities classified by 

manufacturing NAICS codes, as well as by other 

industrial categories. 

Limitations of Data 

Small establishments and those that do not meet 

reporting requirements are not included in the 

database. 

Data systems contain data only for pollutants in the 

facility permit. 

10 An NPDES individual permit is written to reflect site-specific conditions of a single discharger based on 

information submitted by that discharger in a permit application. An individual permit is unique to that discharger. 

NPDES general permits are written to cover multiple dischargers with similar operations and types of discharges, 

based on the permit writer’s professional knowledge of those types of activities and discharges (U.S. EPA, 2010). 

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3—2015 Effluent Guidelines Planning Process and Methodology 

Table 3-2. TRI and DMR Data Utility and Limitations 

TRI DMR 

Some reported releases are based on estimates (due to 

TRI reporting guidance); some facilities may 

overestimate or underestimate releases. 

Limited discharge data on minorb discharges. 

Certain chemicals are reported as a class, not as 

individual compoundsa This can cause inaccurate 

estimates of the toxicity of chemical releases. 

Data systems do not include data characterizing indirect 

discharges from industrial facilities to POTWs. 

Facilities are identified by NAICS codes, not point 

source category. 

Facilities do not always report duration of discharges, 

which may result in overestimates of toxic releases based 

on the assumption that discharges are continuous. 

TRI only requires facilities to report certain 

chemicals; therefore, all pollutants discharged from a 

facility may not be captured. 

Some data systems do not identify the type of wastewater 

discharged, which may include stormwater or noncontact cooling water; pipe identification is not always 

clear. 

Facilities are identified by SIC codes, not point source 

category. 

Data may contain errors from manual data entry. 

Facilities do not always report average concentrations or 

quantities, which results in overestimates if only 

maximum values are reported. 

a Chemicals reported as a class include polycyclic aromatic compounds, dioxin and dioxin-like compounds, and 

metal compounds. b	 EPA developed a major/minor classification system for industrial and municipal wastewater discharges. The 

distinction was initially made to help EPA and states set priorities for permit issuance and reissuance. Facilities 

with minor discharges must report compliance with NPDES permit limits via monthly DMRs submitted to the 

permitting authority; however, EPA does not require the permitting authority to enter data in the Permit 

Compliance System and Integrated Compliance Information System-NPDES databases (U.S. EPA, 2010). 

EPA performed a quality review of the DMR and TRI data downloaded from the DMR 

Loading Tool to assess the data’s completeness, comparability, accuracy, and reasonableness, in 

accordance with the Environmental Engineering Support for Clean Water Regulations 

Programmatic Quality Assurance Project Plan (PQAPP) (ERG, 2013). See section 2.2 of the 

2015 Annual Review Report for a detailed discussion of the quality review of the DMR and TRI 

data. 

The 2013 DMR data reported from ICIS-NPDES do not include data from New Jersey. In 

2006, states began transitioning their DMR reporting from the Permit Compliance System (PCS) 

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

territories/tribes had completely migrated to ICIS-NPDES, except New Jersey; thus, New Jersey 

has not supplied EPA with required data about its CWA discharge program (U.S. EPA, 2015b). 

During the course of its quality review of the 2013 TRI data, EPA found that hydrogen 

sulfide water releases accounted for approximately 40 percent of the total 2013 TRI TWPE. 

Hydrogen sulfide has not historically been included or evaluated as part of EPA’s previous 

annual reviews, but is now included due to recent changes in TRI reporting requirements. EPA 

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3—2015 Effluent Guidelines Planning Process and Methodology 

further investigated the hydrogen sulfide releases reported to TRI and determined that the data 

for indirect releases are overestimated based on the estimation techniques used. EPA adjusted the 

indirect releases of hydrogen sulfide reported to TRI to account for these POTW removals. See 

Section 2.2.2.1 of the 2015 Annual Review Report for further details (U.S. EPA, 2016a). 

Additionally, during EPA’s quality review of 2013 DMR and TRI data, EPA made 

appropriate corrections to errors found in the data (e.g., unit errors, transcription errors, missing 

below detection limit indicators). For a detailed summary of all corrections made to the 2013 

DMR and TRI data in support of the 2015 Annual Review, see Sections 2.2.1 and 2.2.2, 

respectively, in EPA’s 2015 Annual Review Report (U.S. EPA, 2016a). 

3.3.2 Other Data Sources Supporting EPA’s 2015 Annual Review 

For its 2015 Annual Review, EPA also used other data to support analyses of the 

potential environmental impact of industrial discharges. EPA obtained these data from 

government and other peer reviewed publications, through direct email or telephone 

correspondence with industry and state and local governments, and through online sources, 

including company websites. EPA considered the accuracy, reliability, and representativeness of 

data sources to assess their usability for the 2015 Annual Review, as described below and in 

Section 4.3.1 of the PQAPP (ERG, 2013). EPA also referred to Table 4-2 in the PQAPP to 

determine if the sources provided information that was sufficiently accurate and reliable to use in 

the 2015 Annual Review (ERG, 2013). 

Accuracy. EPA assumed that the data and information contained in and supporting 

government publications, selected conference proceedings, peer-reviewed journal articles, and 

other academic literature are sufficiently accurate to support the general and/or facility-specific 

characterization of industries, process operations, and waste streams. EPA also considered 

industry and other non-industry information, including direct industry correspondence, company 

websites, and online news articles. The data and information reported by these sources is 

potentially less accurate than those in government publications or peer-reviewed literature, but 

provided useful information for qualitative characterization and understanding of industries, 

process operations, and waste streams. 

Reliability. Using the following criteria, EPA also evaluated the reliability of collected 

existing data for use in qualitative analyses: 

•	 The scientific work is clearly written, so that all assumptions and methodologies can 

be identified. 

•	 The variability and uncertainty (quantitative and qualitative) in the information or in 

the procedures, measures, methods, or models, are evaluated and characterized. 

•	 The assumptions and methods are consistently applied throughout the analysis, as 

reported in the source. 

•	 Waste streams, parameters, units, and detection limits (when appropriate) are clearly 

characterized. 

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3—2015 Effluent Guidelines Planning Process and Methodology 

•	 The governmental or facility contact is reputable and has knowledge of the industry, 

facility, process operation, or waste streams of interest. 

EPA considered data sources that met these criteria sufficiently reliable to support its 

characterization and understanding of industries, process operations, and waste streams. 

Representativeness. EPA evaluated existing data and information for use in qualitative 

analyses based on whether the data provide a national perspective and are relevant to and 

representative of the industry to which the data are applied, using the following criteria: 

•	 Relevance. The data source is relevant to the industry or pollutant group of interest 

(e.g., the industry description or SIC and NAICS codes provided in the data source, 

when available, match the industry). 

•	 National Applicability. The data can be applied broadly to provide a national 

perspective relative to the industry or pollutant group of interest (e.g., the data are 

characteristic of the industry or pollutant group). 

EPA considered data sources that met these criteria sufficiently representative to support 

the characterization of industries, process operations, and waste streams. During the course of its 

preliminary category reviews, EPA obtained certain facility-specific data from correspondence 

with state and local regulators and/or industry representatives and determined that the data were 

not representative of the industry (e.g., the pollutant discharge was associated with a process 

unique to an individual facility). In such instances, EPA determined that the information was 

useful for understanding and characterizing wastewater discharges or process operations from 

specific facilities, which furthered its understanding of the wastewater discharges and operations 

for the industry. 

For more information on the quality assurance activities supporting the 2015 Annual 

Review, including a summary of EPA’s data quality and utility evaluation for these additional 

data sources, see Appendix A of the 2015 Annual Review Report (U.S EPA, 2016a). 

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4—Results of the 2015 Annual Review 

4. RESULTS OF THE 2015 ANNUAL REVIEW 

This section presents a summary of the findings from EPA’s 2015 Annual Review, 

specifically the TRA, preliminary category reviews, and the review of additional industrial 

categories and pollutants. 

4.1 Findings from EPA’s 2015 TRA and Preliminary Category Reviews 

In its 2015 Annual Review, consistent with the odd-year review methodology, EPA 

conducted a TRA to identify, rank, and prioritize for further review categories with pollutant 

discharges that may pose a substantial hazard to human health and the environment, relative to 

other categories. From the TRA, EPA developed the final 2015 combined point source category 

rankings, presented in Table 4-1 below, accounting for all corrections and updates to the data 

discussed in Section 3.3.1, and removal of any categories and discharges, as discussed in Section 

3.2. 

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5

10

15

20

25

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4—Results of the 2015 Annual Review 

Table 4-1. Final 2015 Combined Point Source Category Rankings 

PSC 

Code PSC Description TRI TWPE DMR TWPE Total TWPE 

Cumulative Percentage 

of Total TWPE Rank 

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

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

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

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

414 Organic Chemicals, Plastics and Synthetic Fibersa 333,000 301,000 634,000 67.0% 

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

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

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

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

445 Landfills 235 166,000 166,000 84.2% 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

4-2
 
 

 

 

4—Results of the 2015 Annual Review 

Table 4-1. Final 2015 Combined Point Source Category Rankings 

PSC 

Code PSC Description TRI TWPE DMR TWPE Total TWPE 

Cumulative Percentage 

of Total TWPE Rank 

407 

Canned and Preserved Fruits and Vegetables 

Processing 5,340 660 6,000 99.6% 35 

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

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

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

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

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

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

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

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

467 Aluminum Forming 857 657 1,510 99.9% 44 

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

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

461 Battery Manufacturing 934 227 1,160 100.0% 47 

426 Glass Manufacturing 522 133 655 100.0% 48 

NA Independent and Stand Alone Labs 0 542 542 100.0% 49 

460 Hospitals 0 536 536 100.0% 50 

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

446 Paint Formulating 94.8 0.437 95.3 100.0% 52 

454 Gum and Wood Chemicals Manufacturing 26.4 62.4 88.8 100.0% 53 

465 Coil Coating 79.1 0.0925 79.2 100.0% 54 

NA Food Service Establishments 0 35.5 35.5 100.0% 55 

447 Ink Formulating 19.6 0.0103 19.7 100.0% 56 

466 Porcelain Enameling 7.82 0 7.82 100.0% 57 

NA Tobacco Products 5.32 0.167 5.48 100.0% 58 

412 Concentrated Animal Feeding Operations 0 1.49 1.49 100.0% 59 

427 Asbestos Manufacturing 0 0.589 0.589 100.0% 60 

NA Industrial Laundries 0 0 0 100.0% 61 

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

Sources: DMRLTOutput2013_v1 and TRILTOutput2013_v1.
 

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

NA: Not applicable.
 a The Organic Chemicals, Pesticides, and Synthetic Fibers and Inorganic Chemicals Manufacturing point source categories do not include discharges from 

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

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4—Results of the 2015 Annual Review 

Based on its TRA, EPA prioritized for further review those industrial categories whose 

pollutant discharge toxicities potentially pose the greatest hazards to human health or the 

environment. To identify these industrial categories, EPA calculated each industrial category’s 

percent of the total TWPE. As shown in Table 4-1, EPA identified and focused its preliminary 

category reviews on the 18 industrial categories that collectively discharge over 95 percent of the 

total TWPE. EPA excluded Petroleum Refining (40 CFR Part 419) and Metal Finishing (40 CFR 

Part 433) from further preliminary category review because it is currently conducting detailed 

and preliminary studies of these categories, respectively, as announced in the Final 2014 Effluent 

Guidelines Program Plan (Final 2014 Plan) (U.S. EPA, 2015a). 

Based on further review of the remaining 16 categories, EPA determined that five 

categories did not warrant a detailed preliminary review as part of the 2015 Annual Review. For 

these five categories, many of which have been reviewed in detail in prior annual reviews, EPA 

found that one facility accounts for the majority of the category TWPE. From data available for 

the 2015 Annual Review, EPA determined that the discharges from the top facility are the result 

of an easily identifiable error, do not represent the category, or recommends the facility for 

facility-specific permitting action. These industrial categories include: 

•	 Drinking Water Treatment (potential new category) 

•	 Fertilizer Manufacturing (40 CFR Part 418) 

•	 Inorganic Chemicals Manufacturing (40 CFR Part 415) 

•	 Miscellaneous Foods and Beverages (potential new category) 

•	 Oil and Gas Extraction (40 CFR Part 435)11 

For each of the remaining 11 categories (of the top 18 that collectively discharge over 95 

percent of the total TWPE), EPA completed a preliminary category review to evaluate whether 

the category warrants further review for possible effluent guidelines development or revision. 

Below is the summary of findings from EPA’s 2015 preliminary category reviews. From these 

reviews, EPA identified three categories that warrant further review and eight categories that do 

not warrant further review. The three categories that warrant further review are: Iron and Steel 

Manufacturing (40 CFR Part 420), Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR 

Part 414), and Pulp, Paper, and Paperboard (40 CFR Part 430). 

•	 Carbon Black Manufacturing (40 CFR Part 458). EPA determined that the 

estimated toxicity of the Carbon Black Category discharges resulted primarily from 

polycyclic aromatic compounds (PACs) releases reported to TRI. EPA identified two 

facilities that account for 99 percent of the PAC TWPE for the Carbon Black 

Category. After applying a data change for one facility, the 2013 Carbon Black 

Category TWPE decreased from 63,800 to 38,500. This change would drop the 

category outside the top 95 percent of TWPE that EPA prioritized for preliminary 

review as part of the 2015 Annual Review. Therefore, EPA has determined that the 

11 EPA recently reviewed coal bed methane facilities. Additionally, EPA is currently engaged in a rulemaking 

process for unconventional oil and gas extraction facilities. Therefore, coal bed methane and unconventional oil and 

gas extraction facilities were not further reviewed in EPA’s review of the Oil and Gas Extraction Category in the 

2015 Annual Review. 

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4—Results of the 2015 Annual Review 

discharges do not warrant further review of the Carbon Black Manufacturing 

Category. 

•	 Grain Mills (40 CFR Part 406). EPA determined that the estimated toxicity of the 

Grain Mills Category discharges resulted primarily from hydrogen sulfide releases 

reported to TRI. One facility contributed over 98 percent of the category’s 2013 TRI 

hydrogen sulfide releases. The facility contact indicated that the release may be 

attributed to anaerobic wastewater treatment at the facility, and not to the 

manufacturing process. Because the majority of the hydrogen sulfide releases are 

attributed to one facility, EPA determined that they are not representative of the 

category, and therefore, the data do not warrant further review of the Grain Mills 

Category. 

•	 Iron and Steel Manufacturing (40 CFR Part 420). EPA determined that the 

estimated toxicity of the Iron and Steel Manufacturing Category discharges resulted 

primarily from polychlorinated biphenyls (PCBs), cyanide, fluoride, and lead 

reported on DMRs, and nitrate compound, lead and lead compound, manganese and 

manganese compound and copper and copper compound releases reported to TRI. 

From its preliminary category review of the Iron and Steel Manufacturing Category, 

EPA determined the following: 

—	 PCBs. One facility accounts for 100 percent of the DMR PCB discharges. The 

facility is working to determine the source of PCB discharges, but believes the 

discharges are from historical production activities on the site. Additionally, 

the facility’s PCB discharges have decreased in recent years. For these 

reasons, EPA does not consider the facility’s PCB discharges to be 

representative of discharges across the category. 

—	 Cyanide. Two facilities account for 76 percent of the DMR cyanide 

discharges. EPA identified a data correction for one facility, however, some 

discharges still exceed the facility’s permit limits; therefore, the facility may 

require facility-specific compliance assistance to address the cyanide 

discharges. The second facility has discharges below permit limits. Because 

the majority of cyanide discharges result from two facilities, they are not 

representative of discharges across the category. 

—	 Fluoride. Four facilities account for 94 percent of DMR fluoride discharges. 

For two of the top fluoride discharging facilities, EPA concluded that the 

fluoride concentrations are generally below those achievable by current 

technologies. One facility received a revised permit in 2014 that includes 

fluoride limits for an additional outfall; therefore, EPA expects fluoride 

discharges will decrease on future DMRs for this facility. The remaining 

facility has discharges above permit limits; therefore, facility-specific 

compliance assistance may be appropriate to address fluoride discharges from 

this facility. 

—	 Lead. EPA identified and corrected a data error for one facility that accounted 

for 19 percent of the TRI lead and lead compound releases. The correction 

decreased the facility’s lead and lead compound TRI TWPE from 4,360 to 

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4—Results of the 2015 Annual Review 

1,100. After the facility correction, EPA determined that all facilities with lead 

discharges in the 2013 DMR and TRI databases contributed less than 2,300 

TWPE each. However, 133 facilities reported releases of lead and lead 

compounds to TRI and 33 facilities reported lead discharges on DMRs in 

2013. Therefore, EPA determined that further investigation of this pollutant is 

appropriate to evaluate if the discharges are adequately controlled by the 

existing ELGs. 

—	 Nitrate. The individual facility TWPE associated with nitrate appears to be 

relatively low (less than 3,200); however, 56 facilities reported releases of 

nitrate to TRI in 2013. Nitrate is not a regulated pollutant under the Iron and 

Steel Manufacturing ELGs. Because 56 facilities report releases of nitrate to 

TRI in 2013 and nitrate is not a regulated pollutant, EPA determined that 

further investigation of this pollutant is appropriate to evaluate if the 

discharges are adequately controlled by the existing ELGs. 

—	 Manganese and Copper. Manganese and manganese compounds, and copper 

and copper compounds, not regulated by the Iron and Steel Manufacturing 

Category ELGs, contribute a small amount of TWPE relative to the other top 

pollutants (less than 6,000 TWPE each). However, because 114 and 79 

facilities reported manganese and manganese compound and copper and 

copper compound releases, respectively, to TRI in 2013, EPA determined that 

further investigation is appropriate to evaluate if the discharges are adequately 

controlled by the existing ELGs. 

In summary, from its preliminary category review, EPA determined that further 

review is appropriate for the Iron and Steel Manufacturing Category, specifically 

related to discharges of four pollutants: manganese and manganese compounds, 

copper and copper compounds, lead and lead compounds and nitrate compounds. 

•	 Landfills (40 CFR Part 445). EPA determined that the estimated toxicity of the 

Landfills Category discharges resulted primarily from cadmium, selenium, and iron 

reported on DMRs. From its preliminary category review of the Landfills Category, 

EPA determined the following: 

—	 Cadmium. One facility accounts for more than 99 percent of the 2013 DMR 

cadmium discharges. The large discharge was attributed to a single sampling 

event that was performed after a leachate tank flood, and was not 

representative of typical operating conditions at the facility. For this reason, 

EPA does not consider these discharges to be representative of the Landfills 

Category and they do not warrant further review. 

—	 Selenium. One facility accounts for more than 99 percent of the 2013 DMR 

selenium discharges. EPA identified and corrected a data entry error for the 

facility’s selenium concentrations, decreasing the facility’s selenium TWPE 

from 40,600 to 40.4. Therefore, this pollutant does not warrant further review. 

—	 Iron. Two facilities accounted for over 85 percent of the iron discharges in the 

2013 DMR data. EPA identified and corrected a data entry error for one 

facility’s iron discharges, decreasing the facility’s iron TWPE from 9,620 to 

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4—Results of the 2015 Annual Review 

0.015. EPA determined that facility-specific compliance assistance may be 

appropriate to address iron discharges from the other top facility. 

In summary, for the Landfills Category, EPA determined that the data do not support 

further review. 

•	 Meat and Poultry Products (40 CFR Part 432). EPA determined that the estimated 

toxicity of the Meat and Poultry Products Category discharges resulted primarily 

from nitrate compounds and hydrogen sulfide releases reported to TRI. From its 

preliminary category review of the Meat and Poultry Products Category, EPA 

determined the following: 

—	 Nitrate. Fifteen facilities accounted for the majority of TRI nitrate compound 

releases. EPA previously reviewed many of these in recent annual reviews. 

For the 2015 Annual Review EPA focused its review on five facilities whose 

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

permits include current total nitrogen ELGs. A fourth permit is currently 

under revision and is expected to include total nitrogen limitations specified in 

the ELGs. EPA determined that facility-specific permitting action may be 

appropriate to address nitrate compound releases from the fifth facility. While 

nitrate is regulated by the existing ELGs, if this category continues to rank 

high in future reviews primarily due to nitrate compound releases, EPA may 

evaluate whether technologies are available to reduce these discharges further. 

—	 Hydrogen Sulfide. Four facilities accounted for the majority of the hydrogen 

sulfide discharges. All four facilities reported direct releases of hydrogen 

sulfide to TRI. Three of the four facilities estimated their hydrogen sulfide 

releases by using soluble sulfide sampling data collected at the facilities. EPA 

determined that the other facility used published emission factors to estimate 

hydrogen sulfide releases. EPA is uncertain as to how representative the data 

are of actual releases; therefore, as new data become available, EPA may 

continue to review them to determine whether they potentially represent a 

category-wide issue. 

In summary, EPA did not identify the Meat and Poultry Category for further review 

at this time but may do so in the future for nitrate and hydrogen sulfide as additional 

data become available. 

•	 Mineral Mining and Processing (40 CFR Part 436). EPA determined that the 

estimated toxicity of the Mineral Mining and Processing Category discharges 

resulted primarily from chloride, aluminum, and fluoride discharges reported on 

DMRs. From its preliminary category review of the Mineral Mining and Processing 

Category, EPA determined the following: 

—	 Chloride and Aluminum. Two facilities account for 96 percent of the 2013 

DMR chloride discharges. At one of the facilities, the chloride discharges can 

be attributed to large salt piles the facility has on site, but is in the process of 

removing. This facility also accounts for 95 percent of the 2013 DMR 

aluminum discharges. EPA expects the discharges from this facility to 

4-7
 
 

 

 

 

 

 

 

 

 

 

 

 

 

4—Results of the 2015 Annual Review 

decrease in future years. The second top facility with chloride discharges has 

net limitations for chloride because they withdraw from and discharge to the 

same saline body of water. Additionally, its chloride discharges have been 

consistent from 2004 through 2013. EPA does not consider the discharges 

from this facility to be representative of the Mineral Mining and Processing 

Category. 

—	 Fluoride. One facility accounts for 69 percent of the 2013 DMR fluoride 

discharges. The facility’s discharges have increased from 2011 to 2014. 

Therefore, facility-specific permitting action may be appropriate to address 

fluoride discharges. 

In summary, for the Mineral Mining Category, EPA determined that the discharges 

are primarily attributed to single facilities and that no further review is warranted. 

•	 Nonferrous Metals Manufacturing (NFMM) (40 CFR Part 421). EPA determined 

that the estimated toxicity of the NFMM Category discharges resulted primarily from 

cadmium and fluoride reported on DMRs. From its preliminary category review of 

the NFMM Category, EPA determined the following: 

—	 Cadmium. One facility accounts for over 99 percent of the 2013 DMR 

cadmium discharges. The facility’s 2013 cadmium discharges are above 

permit benchmark values for three of their four stormwater outfalls. Facilityspecific compliance assistance to address the cadmium discharges from this 

facility may be warranted. 

—	 Fluoride. Two facilities account for 87 percent of the 2013 DMR fluoride 

discharges. One of the facilities closed in 2014. The other facility, (discussed 

for cadmium discharges above), has 2013 fluoride discharges that vary by 

three orders of magnitude, depending on the month. The facility currently has 

reporting requirements for fluoride, but no specific limits. Facility-specific 

compliance assistance to address fluoride discharges from this facility may be 

warranted. 

In summary, for the NFMM Category, EPA determined that the discharges are 

primarily attributed to one or two facilities and no further review is warranted.
 

•	 Ore Mining and Dressing (40 CFR Part 440). EPA determined that the estimated 

toxicity of the Ore Mining Category discharges resulted primarily from copper, 

selenium, radium-226, and arsenic reported on DMRs; and lead and lead compound 

and silver and silver compound releases reported to TRI. From its preliminary 

category review of the Ore Mining and Dressing Category, EPA determined the 

following: 

—	 Copper. Two facilities account for 76 percent of the 2013 copper discharges. 

One facility’s discharges resulted from contamination at the sample port on 

the discharge pipe and the facility plans to change the sampling location to 

avoid contamination; therefore, EPA expects copper discharges from this 

facility to decrease in future years. The other facility is closed and discharges 

are from tailings runoff, which fluctuate with yearly rainfall. EPA determined 

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4—Results of the 2015 Annual Review 

that these copper discharges are not representative of the Ore Mining and 

Dressing Category. 

—	 Selenium. One facility accounts for 89 percent of the selenium discharges. 

The facility’s permit was reissued in 2012 and included a schedule of 

compliance for selenium discharges. The facility plans to implement new on 

site treatment technologies to meet revised permit limits for selenium by 

2017; therefore, EPA expects decreases in selenium discharges from this 

facility on future DMRs. 

—	 Radium-226. One facility accounts for over 99 percent of the radium-226 

discharges. The 2013 radium-226 DMR discharge resulted from one measured 

concentration from an outfall where the facility discharges process water from 

the mine’s waste dump. The facility confirmed the 2013 discharge resulted 

from a major flood at the site; the facility has had no other radium-226 

discharges from 2011 through 2014, indicating that the 2013 discharge was an 

outlier. Therefore, the radium-226 discharges are not representative of typical 

discharges from this facility or from the Ore Mining Category. 

—	 Arsenic. One facility accounts for 69 percent and 66 percent of the DMR and 

TRI arsenic discharges, respectively. The facility is a large, integrated copper 

mining facility; the 2013 DMR arsenic discharges are below the NPDES 

monthly average and daily maximum permit limits. The facility’s high arsenic 

TWPE likely results from the relatively high level of industrial activity at the 

site. Therefore, EPA does not consider the facility’s arsenic discharges to be 

representative of facility discharges across the category. 

—	 Lead. Three mines account for 91 percent of the TRI lead and lead compound 

releases. All three mines are covered under a consent decree; therefore, EPA 

expects discharges to decrease in future years. 

—	 Silver. Two facilities account for over 99 percent of the 2013 silver and silver 

compound releases. Both facilities are part of a large, integrated copper 

mining facility that bases its reported TRI releases on conservative estimates 

not confirmed with sampling data. Therefore, EPA cannot assess how 

representative they are of actual silver and silver compound releases from the 

facility. 

In summary, for the top pollutants identified from the 2015 Annual Review, EPA 

determined that the discharges are primarily attributed to one or two facilities, the 

discharges are anomalies, or are not representative of the Ore Mining and Dressing 

Category. Therefore, EPA determined no further review of this category is warranted. 

•	 Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) (40 CFR Part 414). 

EPA determined that the estimated toxicity of the OCPSF Category discharges 

resulted primarily from PACs, total residual chlorine, hexachlorobenzene, and dioxin 

reported on DMRs, and PACs, dioxin and dioxin-like compound, carbon disulfide, 

and nitrate compound releases reported to TRI. From its preliminary category review 

of the OCPSF Category, EPA determined the following: 

4-9
 
 

 

 

 

 

4—Results of the 2015 Annual Review 

—	 PACs. Two facilities account for 94 percent of the 2013 DMR benzo[a]pyrene 

and benzo[k]fluoranthene discharges (both are PACs). Additionally, two 

facilities account for 96 percent of the 2013 TRI PACs releases. EPA 

determined DMR benzo[a]pyrene and benzo[k]fluoranthene discharges were 

originally reported in error and should have been reported as below detection. 

Correcting these data decreased the OCPSF Category benzo[a]pyrene TWPE 

from 59,800 to 3,230, and the benzo[k]fluoranthene TWPE from 18,200 to 

971. The top facility reporting TRI PACs releases is meeting its PACs permit 

limits, which form the basis of its reported TRI releases, and its permit is 

being updated to add increasingly stringent limits. EPA also expects the TRI 

PACs releases from the second top facility to decrease in future years, as the 

facility refines its estimation method for reporting PACs releases. For these 

reasons, EPA has determined that PACs releases for the OCPSF Category do 

not represent a hazard priority at this time. 

—	 Total Residual Chlorine. Total residual chlorine is not a regulated pollutant 

under the OCPSF ELGs. Ninety-seven facilities submitted DMRs with total 

residual chlorine discharges in 2013; four facilities account for over 60 

percent of those discharges. EPA reviewed the DMR data submitted by the 

top four facilities and found that all four met their permit limits in 2013; 

however, three of the facilities had minimum chlorine permit limits. EPA did 

not conduct a facility-level review of the total residual chlorine discharges for 

the remaining 93 facilities because no facility individually contributed more 

than 5,000 TWPE. However, due to the number of facilities with total residual 

chlorine discharges in the 2013 DMR database, and an indication that three of 

the top four facilities reporting total residual chlorine discharges have 

minimum total residual chlorine limits in their permits, EPA determined that 

further investigation of this pollutant is appropriate to determine whether 

control technologies are available to further reduce these discharges. 

—	 Hexachlorobenzene. Two facilities account for 93 percent of the 2013 DMR 

hexachlorobenzene discharges. EPA determined that hexachlorobenzene 

discharges from one facility will likely continue to decrease due to the 

implementation of more stringent permit limits. The other facility’s 

hexachlorobenzene discharges are below its current permit limits. As a result, 

EPA determined that hexachlorobenzene discharges for the OCPSF Category 

do not represent a hazard priority at this time. 

—	 Dioxin. One facility accounts for over 99 percent of the 2013 DMR 2, 3, 7, 8­

tetrachlorodibenzo-p-dioxin (TCDD) discharges. Two facilities account for 

over 93 percent of the 2013 TRI dioxin and dioxin-like compound releases. 

Two of the top DMR and TRI dioxin discharging facilities indicated that the 

dioxin discharges are associated with historical processes on site. EPA 

identified a data correction for the remaining top discharging facility, which, 

once applied, decreased the OCPSF category dioxin and dioxin-like 

compound TRI TWPE from 69,700 to 22,500. As a result, EPA has 

determined that dioxin discharges for the OCPSF Category do not represent a 

hazard priority at this time. 

4-10
 
 

4—Results of the 2015 Annual Review 

—	 Carbon Disulfide. Three cellulose products manufacturing facilities account 

for 97 percent of the 2013 TRI carbon disulfide releases for the OCPSF 

Category. EPA reviewed the releases from one of the top three facilities and 

determined that the carbon disulfide discharges are likely overestimated 

because of the high probability that the pollutant volatilizes over the long 

distance between the sampling point and final discharge point. EPA 

determined that the carbon disulfide releases do not represent a category-wide 

issue. 

—	 Nitrate. One hundred twenty-one facilities reported releases of nitrate 

compounds to TRI in 2013; two facilities account for 38 percent of those 

releases. EPA confirmed that both facilities base their nitrate compound TRI 

releases on monitoring data. One facility’s nitrate compound releases have 

remained similar from 2010 through 2013, while the other facility’s nitrate 

compound releases have decreased from 2010 through 2013. EPA did not 

conduct a facility-level review of the remaining 119 facilities with reported 

TRI nitrate compound releases in 2013, as the majority contribute less than 

1,000 TWPE each. However, 121 facilities reported releases of nitrate 

compounds to TRI. Therefore. EPA determined it is appropriate to evaluate 

whether control technologies are available to reduce nitrate discharges further. 

In summary, from its preliminary category review, EPA determined that further 

review is appropriate for the OCPSF Category, specifically related to discharges of 

two pollutants: total residual chlorine and nitrate compounds. 

•	 Pulp, Paper, and Paperboard (40 CFR Part 430). EPA determined that the 

estimated toxicity of the Pulp, Paper, and Paperboard (Pulp and Paper) Category 

discharges resulted primarily from releases reported to TRI of the following 

pollutants: hydrogen sulfide, dioxin and dioxin-like compounds, manganese and 

manganese-like compounds, lead and lead compounds, and mercury and mercury 

compounds. From its preliminary category review of the Pulp and Paper Category, 

EPA determined the following: 

—	 Hydrogen Sulfide. Seven facilities account for 80 percent of the hydrogen 

sulfide releases, with the top facility accounting for 27 percent of the releases. 

The top facility confirmed the 2013 TRI hydrogen sulfide release data, but 

stated that wastewater treatment system improvements such as dredging 

treatment basins of accumulated solids to increase the available aeration zone, 

led to decreased hydrogen sulfide discharges in 2014. EPA contacted industry 

trade associations regarding the reported releases of hydrogen sulfide as well, 

and determined that pulp and paper mills may calculate their hydrogen sulfide 

releases to TRI using total sulfide, rather than dissolved sulfide 

concentrations. Industry trade associations suggest this may result in an 

overestimate. One trade association has developed a new sampling system that 

may allow measurement of dissolved sulfides, and believes the new sampling 

system may mitigate the overestimation of hydrogen sulfide releases in TRI. 

Due to the number of facilities with hydrogen sulfide releases in the TRI 

database (97 facilities) and possible overestimation of hydrogen sulfide 

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4—Results of the 2015 Annual Review 

releases in TRI data due to the current sampling convention, EPA determined 

that it may be appropriate to continue to monitor releases of this pollutant to 

determine whether they potentially represent a category-wide issue warranting 

further evaluation. 

—	 Dioxin. The majority of dioxin and dioxin-like compound releases result from 

five facilities. Data from three of the facilities required data changes. 

Correcting the data decreased the dioxin and dioxin-like compound TWPE for 

the Pulp and Paper Category from 1,090,000 to 158,000. EPA determined the 

remaining two facilities either had discharges below the method minimum 

levels or decreasing discharges in recent years. As a result, EPA determined 

that discharges of dioxin and dioxin like compounds do not warrant further 

review at this time. 

—	 Manganese. In 2013,112 facilities reported releases of manganese and 

manganese compounds with none contributing more than five percent of the 

2013 manganese and manganese compound TRI TWPE for the Pulp and 

Paper Category. Further, it has been nearly 10 years since EPA conducted the 

Pulp and Paper Detailed Study in which it evaluated manganese and 

manganese compound concentrations compared to treatable levels. For these 

reasons, EPA determined that further investigation of this pollutant is 

appropriate to determine whether concentrations are present in facility effluent 

at levels that warrant further treatment. 

—	 Lead and Mercury. Lead and lead compounds and mercury and mercury 

compounds, not regulated by the Pulp and Paper Category ELGs, represent a 

small percentage (3.4 percent combined) of the 2013 TRI TWPE for the Pulp 

and Paper Category. However, because 172 and 84 facilities reported lead and 

lead compound and mercury and mercury compound releases, respectively, to 

TRI in 2013, EPA determined that further investigation is appropriate to 

determine if concentrations are present in facility effluent at a level that may 

warrant further treatment. 

In summary, from its preliminary category review, EPA determined that further 

review is appropriate for the Pulp and Paper Category, specifically related to 

discharges of four pollutants: lead and lead compounds, hydrogen sulfide, mercury 

and mercury compounds and manganese and manganese compounds. 

•	 Textile Mills (40 CFR Part 410). EPA determined that the estimated toxicity of the 

Textile Mills Category discharges resulted primarily from toxaphene and sulfide 

reported on DMRs. From its preliminary category review of the Textile Mills 

Category, EPA determined the following: 

—	 Toxaphene. One facility accounts for 100 percent of the 2013 DMR 

toxaphene discharges. The facility experienced matrix interferences with 

analyzing samples in 2013, resulting in false positive results; therefore, the 

facility’s toxaphene discharges do not represent discharges from the Textiles 

Category. 

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4—Results of the 2015 Annual Review 

—	 Sulfide. One facility accounts for over 70 percent of the 2013 DMR sulfide 

discharges. All 2013 sulfide discharges are below the facility’s permit limits 

and the facility is performing daily monitoring; therefore, further review of 

sulfide discharges is not warranted at this time. 

In summary, for the Textiles Category, EPA determined the discharges do not support 

the need for further review. 

4.2	 Findings from EPA’s Review of Additional Industrial Categories and Pollutants 

EPA also initiated a review of three additional point source categories that were 

identified as potential concerns based on public comments: Battery Manufacturing (40 CFR Part 

461) and Electrical and Electronic Components (40 CFR Part 469), specifically Subpart B 

Electronic Crystals. EPA also reviewed in more detail MBT, a chemical compound used in tire 

manufacturing, which is an industry covered under Subpart A Tire and Inner Tube Plants 

Subcategory of the Rubber Manufacturing (40 CFR Part 428) ELGs. The findings from these 

reviews are summarized below. 

•	 Battery Manufacturing (40 CFR Part 461). Battery technologies have greatly 

changed since the promulgation of the Battery Manufacturing ELGs in 1984, with the 

advent of rechargeable batteries, including lithium ion, vanadium redox and other 

types of batteries. The 1984 ELGs apply to discharges from battery manufacturing 

facilities if the battery type they manufacture is listed as one of six manufacturing 

subcategories. Each subcategory is based on the type of metal used to manufacture 

the battery anodes. Given the different types of anode materials used, the existing 

ELGs may not cover discharges from the manufacture of the newer types of batteries. 

Currently, 25 battery manufacturing facilities have active NPDES permits for 

wastewater discharges and it appears the battery manufacturing industry in the U.S. is 

growing. Tesla Motors is currently building a very large battery manufacturing plant 

in Nevada, which will manufacture lithium ion batteries. It is estimated, when at full 

capacity, this plant will manufacture 95 percent of the world’s rechargeable batteries. 

Given these factors, EPA has determined that further review of the Battery 

Manufacturing industry is appropriate to fully understand the state of the industry, the 

new battery technologies, the applicability of the existing ELGs, and the potential for 

new pollutants in the industry’s wastewater discharges. 

•	 Electrical and Electronic Components (40 CFR Part 469). Sapphire crystals are 

used in an increasing number of electronic devices. Stakeholders recently raised 

questions regarding the applicability of the Electrical and Electronic Components 

ELGs (E&EC ELGs) to the manufacture of sapphire crystals. Further, stakeholders 

identified new pollutants, specifically the use of nanomaterials in the manufacturing 

of electronics, which EPA did not consider during the development of the E&EC 

ELGs. 

Subpart B of the E&EC ELGs applies to discharges resulting from the manufacture of 

electronic crystals. While the definition of “electronic crystals” does not specify 

sapphire crystals, EPA determined that growing sapphire crystals and producing 

4-13
 
 

 

 

 

 

 

 

 

4—Results of the 2015 Annual Review 

sapphire crystal wafers meet the definition of manufacture of electronic crystals, as 

the crystals are used in the manufacture of electronic devices because of their unique 

structural and electronic properties. Therefore, 40 CFR Part 469 Subpart B covers 

wastewater discharges generated from growing sapphire crystals and producing 

sapphire crystal wafers. 

EPA’s review identified that sapphire crystal wafer production usually generates 

wastewater in the form of slurries and acids. The chemicals used in the preparation of 

sapphire wafers have not been thoroughly studied, so available information is limited. 

As a result, EPA has not yet determined the pollutants of concern or current 

wastewater management practices, though it has confirmed that nanodiamonds are 

used in sapphire crystal polishing slurries. EPA also identified a number of facilities 

in the U.S. that are likely manufacturing sapphire crystals and wafers. As a result of 

the investigation into sapphire crystal manufacturing, EPA determined continued 

review of the E&EC ELGs is appropriate. 

•	 2-Mercaptobenzothiazole (MBT). MBT is an organic vulcanization accelerator 

used in the manufacture of rubber tires. Subpart A, Tire and Inner Tube Plants, of the 

Rubber Manufacturing ELGs (40 CFR Part 428), covers discharges from tire 

manufacturing. EPA did not identify any DMR or TRI discharges of MBT from tire 

manufacturers. Further, EPA’s review of MBT indicates that concerns and research 

regarding its release into the environment have centered on dust from the abrasion 

and wear of tires, which is not under the purview of the ELG program. For these 

reasons, EPA is not pursuing further review of the discharge of MBT as an effluent 

guidelines issue at this time. 

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5—Industries for Which EPA is Currently Undertaking an ELG Rulemaking 

5. INDUSTRIES FOR WHICH EPA IS CURRENTLY UNDERTAKING AN ELG RULEMAKING 

EPA is currently undertaking a rulemaking for the Canned and Preserved Seafood 

Category (covering the Alaskan seafood processing subcategories), dental practices (specifically, 

relating to the discharge of mercury found in dental amalgam to POTWs), and for the Oil and 

Gas Extraction Category (specifically related to the discharge of pollutants in wastewaters from 

unconventional oil and gas extraction facilities to POTWs). This section presents updates and 

EPA’s current schedule for these actions. EPA is not soliciting comment on these ongoing 

rulemakings or schedules as part of this Preliminary 2016 Effluent Guidelines Program Plan. 

EPA is developing an amendment to the ELGs for the Canned and Preserved Seafood 

Category — Alaskan Seafood Subcategories (40 CFR Part 408). This action was initiated in 

1980 in response to two petitions submitted by the Alaska seafood processing industry. Since 

that time, EPA has taken a number of actions to respond to the petitions, including publishing a 

proposed rule in 1981, sending data and information requests (in the form of a questionnaire) to 

nine corporations in 2010, and issuing a Notice of Data Availability (NODA) on November 7, 

2013. For further information, see EPA’s Alaskan Seafood Processing Effluent Guidelines 

webpage. 

EPA is currently engaged in a rulemaking related to pretreatment requirements for 

discharges of mercury from dental practices. Based on information submitted in prior annual 

reviews (2004, 2006, and 2008), commenters raised concerns about mercury discharges from 

dental practices and urged EPA to consider establishing effluent guidelines and pretreatment 

standards for such discharges. EPA announced the rulemaking concerning mercury discharges 

from dental practices in the Final 2010 Plan. Subsequently, EPA published a proposed rule on 

October 22, 2014 (79 FR 63,256), and held public hearings on November 10, 2014. The public 

comment period ended on February 20, 2015. 

EPA recently signed a rule which will revise the ELGs for the Oil and Gas Extraction 

Point Source Category by adding pretreatment standards for existing and new onshore 

unconventional oil and gas extraction facilities. This rule will fill a gap in existing federal 

wastewater regulations to ensure that the current practice of not sending wastewater discharges 

from this sector to POTWs continues into the future. Direct discharge requirements are not being 

revised. 

5.1 EPA’s Current Schedule for ELG Actions 

Pretreatment Standards for the Dental Category: 

- Proposed Rule October 22, 2014 

- Final Rule December 2016 

Pretreatment Standards for Unconventional Oil and Gas Extraction: 

- Proposed Rule April 7, 2015 

- Final Rule June 2016 

5-1
 
 

 

5—Industries for Which EPA is Currently Undertaking an ELG Rulemaking 

Canned and Preserved Seafood Category covering the Alaskan Seafood 

Processing Subcategories: 

- Notice of Data Availability November 7, 2013 

- Final Rule Spring 2017 

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6—Ongoing EPA Studies of Industrial Discharges 

6. ONGOING EPA STUDIES OF INDUSTRIAL DISCHARGES 

As discussed in the Final 2014 Effluent Guidelines Program Plan (Final 2014 Plan), EPA 

continued studies of the Centralized Waste Treatment (CWT) Category (40 CFR Part 437), 

Petroleum Refining Category (40 CFR Part 419), and Metal Finishing Category (40 CFR Part 

433) (U.S. EPA, 2015a). 

6.1 Continued Detailed Study of the Petroleum Refining Category (40 CFR Part 419) 

In the Final 2012 and Preliminary 2014 Plan, EPA announced its initiation of a detailed 

study of petroleum refineries (40 CFR Part 419) (U.S. EPA, 2014). EPA continues work on this 

study to determine if changes to the existing ELGs or pretreatment standards are appropriate for 

this industry. In particular, the detailed study is investigating the effects of heavier crudes and 

new wet air pollution control on wastewater discharges. Also, the detailed study is investigating 

pollution prevention or wastewater treatment methods available to reduce pollutants present in 

petroleum wastewater. 

The following sources of information were reviewed as part of the detailed study: 

•	 Updated profile information from a variety of public sources (e.g. crude types 

processed, wet air pollution control types used and economic information) 

•	 Recent DMR and TRI discharges 

•	 NPDES Permit information 

•	 Information from site visits to petroleum refineries 

•	 Information from industry, other EPA programs, EPA regions and states and 

literature sources 

After analyzing the information collected from the sources listed above, EPA has 

determined that a targeted information collection request to the industry and wastewater 

sampling data is appropriate to determine if changes to the existing ELGs or pretreatment 

standards are warranted. EPA plans to send a targeted information request, including a request 

for self-sampling data, to 9 or fewer companies. EPA will also continue to collect detailed 

information from NPDES permits, industry, EPA regions, states and literature sources as part of 

the detailed study. 

6.2 Continued Detailed Study of CWT Category (40 CFR Part 437) 

EPA has gathered information about CWT facilities across the country and identified 

those facilities that currently accept or have in the past accepted oil and gas extraction 

wastewaters. A memorandum is included in the record that identifies these facilities (ERG, 

2015). In addition to compiling information on facilities that accept oil and gas extraction 

wastewaters, EPA collected information on wastewater characteristics, wastewater treatment 

technology effectiveness and costs, environmental impacts of discharges, and economic aspects 

of the industry. EPA also conducted site visits at a number of facilities to collect additional, sitespecific information and is planning a targeted information collection request as well. 

6-1
 
 

 

 

6—Ongoing EPA Studies of Industrial Discharges 

6.3 Continued Preliminary Study of the Metal Finishing Category (40 CFR Part 433) 

In the Final 2014 Plan, EPA announced its initiation of a preliminary study of the Metal 

Finishing Category (40 CFR Part 433) to determine if revisions to the ELGs are warranted (U.S. 

EPA, 2015). As part of this study, EPA is evaluating facilities that make up the metal finishing 

industry (including electroplating), their size, and the major markets they serve; the types of 

metal finishing operations and alternative chemistries used that may potentially introduce new 

pollutants that are not currently regulated; new sources of metal finishing wastewater that 

contribute to the overall wastewater characteristics, such as wet air pollution controls or new 

operations in metal finishing; and advanced technologies that facilities employ for the treatment 

and subsequent recycle or discharge of metal finishing wastewater. The study is initially focusing 

on examining existing information that EPA collected or will collect through literature reviews, 

technical conferences, and discussions with industry experts and stakeholders. EPA also plans to 

conduct site visits at metal finishing facilities, analyze current available discharge data, and 

review information collected on the industry during the Metal Products and Machinery (MP&M) 

Rulemaking development. This information will help EPA answer the key study questions 

described in the Preliminary Study of the Metal Finishing Category: 2015 Status Report (U.S. 

EPA, 2016b). The report also describes EPA’s current study findings and next steps for 

continuing the preliminary study. 

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7—Other Ongoing EPA Reviews 

7. OTHER ONGOING EPA REVIEWS 

As presented in the Final 2014 Plan, EPA also continued its review of relevant literature 

to document the performance of new and improved industrial wastewater treatment technologies 

for inclusion in its IWTT Database, to be used in future annual reviews. Additionally, EPA 

continued its review of engineered nanomaterials in industrial wastewater. However, EPA did 

not report on these reviews in its 2015 Annual Effluent Guidelines Review Report (2015 Annual 

Review Report), as the evaluations are ongoing and EPA reported on these efforts in the Final 

2014 Plan. EPA plans to provide an update on these reviews as part of its 2016 Annual Review 

Report, or as new information becomes available. 

EPA continued its evaluation of several pesticide active ingredients (PAIs), identified 

through EPA’s review of analytical methods, for which the discharge from manufacturing is not 

currently regulated under the Pesticide Chemicals Manufacturing, Formulating, and Packaging 

ELGs (40 CFR Part 455). EPA will continue its evaluation of PAIs during future annual reviews 

as additional data and information become available. 

EPA is also continuing its review of the exemption from zero discharge requirements that 

exist in Subpart D of 40 CFR Part 435 for oil and gas extraction facilities operating in Cook 

Inlet, Alaska. The Agency expects to have this evaluation completed in the near future, and to 

announce a decision soon thereafter. 

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8—Other Initiatives 

8. OTHER INITIATIVES 

Innovation and technology have played key roles in improving the strength of the U.S. 

economy while at the same time vastly improving public health and the environment. The U.S. 

leads the way in the environmental technology arena that has become a worldwide market of 

over $800 billion. The environmental technology sector employs about 1.7 million Americans. 

For an advanced economy such as the U.S., innovation is a wellspring of economic 

growth and a powerful tool for addressing our most pressing challenges as a nation – such as 

enabling more Americans to lead longer, healthier lives, and accelerating the transition to a lowcarbon economy. In fact, from 1948-2012 over half of the total increase in U.S. productivity 

growth, a key driver of economic growth, came from innovation and technological change. 

That’s why President Obama issued the nation’s first-ever innovation strategy in 2009, 

updated it in 2011, and issued in October 2015 a final update entitled “A Strategy for American 

Innovation,” prepared by the National Economic Council and Office of Science and Technology 

Policy.12 

In addition to the current activities enumerated in the President’s Strategy, important new 

opportunities are described for action to be developed in 2015 and beyond, and include the 

following new horizon, applicable to the effluent guidelines program: 

“Designing Smart Regulation to Support Emerging Technologies 

Even the innovation process is changing. Key trends include the drastic reduction in 

costs to launch and scale technology; the lack of regulatory pathways for the testing 

and pilot phases of emerging technologies; the reduced role of incumbent, regulated 

intermediaries; and the shift away from technologies that can be regulated in 

accordance with stable categories to technologies that enable and require more fluid 

approaches. As the innovation process evolves, the Federal Government needs to 

develop new regulatory approaches for both new and existing regulations that

protect important public values like health and safety while fostering innovation. 

Smart regulation can also use cutting-edge technologies to reduce regulatory

burden, aid in regulatory analysis, and better solicit public engagement in the

regulatory process.” 

EPA aims to be a catalyst to promote and support technology innovation to restore, 

protect and ensure the sustainability of our water resources. In July 2015, the Agency released, 

“Promoting Innovation for a Sustainable Water Future: A Progress Report” to highlight the 

advances made in ten key market areas identified in “Promoting Technology Innovation for 

Clean and Safe Water.”13 

As a part of this Preliminary 2016 ELG Plan, EPA solicits public and stakeholder 

comments and input on ideas, approaches and information on how to design smart regulations to 

support and promote emerging and innovative technologies for industrial wastewater 

management. 

12 See the National Economic Council and Office of Science and Technology Policy’s A Strategy for American 

Innovation. 13 See EPA’s Promoting Innovation for a Sustainable Water Future webpage. 

8-1
 
 

 

 

 

 

 

 

 

 

 

 

 

 

9—Preliminary 2016 Plan Decisions and Actions 

9. PRELIMINARY 2016 PLAN DECISIONS AND ACTIONS 

This section summarizes EPA’s decisions and actions resulting from its 2015 Annual 

Review and from other ongoing studies and investigations of industrial wastewater discharges. 

EPA invites public comment on these decisions and actions. 

Based on the status of ongoing studies and findings from EPA’s 2015 Annual Review, 

EPA is not identifying any existing effluent guidelines for possible revision, nor is EPA 

identifying any industries for new effluent guidelines, aside from those currently undergoing 

rulemakings. EPA is also not identifying any industrial categories for detailed studies beyond 

those identified previously. 

However, EPA is conducting further preliminary review of the following industry 

categories: 

•	 Iron and Steel Manufacturing (40 CFR Part 420). From its preliminary category 

review of the Iron and Steel Manufacturing Category, EPA identified that further 

review is appropriate, specifically related to discharges of four pollutants: manganese 

and manganese compounds, copper and copper compounds, lead and lead 

compounds, and nitrate compounds. Of these pollutants, the Iron and Steel 

Manufacturing ELGs currently regulate only lead. 

Specifically, EPA plans to evaluate and understand the basis for estimates of reported 

releases to TRI, and to review available facility-specific concentration data for 

discharges of these pollutants. EPA plans to contact a subset of facilities and 

permitting authorities to determine what specific process operations may be 

generating the pollutants and how the discharges are currently treated. Additionally, 

EPA plans to review available treatment technologies for these pollutants to 

determine the level to which the technologies can treat the pollutants compared to the 

concentrations facilities are currently discharging. 

• Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) (40 CFR Part 414). 

From its preliminary category review of the OCPSF Category, EPA identified that 

further review is appropriate specifically related to discharges of two pollutants: total 

residual chlorine and nitrate compounds. The OCPSF ELGs do not currently regulate 

these pollutants. 

Specifically, EPA plans to review facility-specific concentration data for nitrate and 

total residual chlorine discharges, where available. EPA plans to evaluate and 

understand the basis for estimate of releases reported to TRI and contact specific 

facilities to determine what process operations may be generating the pollutants and 

how the discharges are currently treated. For total residual chlorine discharges, EPA 

also plans to further evaluate the prevalent minimum limits for total residual chlorine 

in facility permits, and to compare the discharges to total residual chlorine limits 

established for POTWs. Additionally, EPA plans to review treatment technologies for 

these pollutants to determine the level to which the technologies can treat the 

pollutants compared to the concentrations facilities are currently discharging. 

9-1
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

9—Preliminary 2016 Plan Decisions and Actions 

•	 Pulp, Paper, and Paperboard (40 CFR Part 430). From its preliminary category 

review of the Pulp and Paper Category, EPA identified that further review is 

appropriate, specifically related to discharges of four pollutants: lead and lead 

compounds, mercury and mercury compounds, hydrogen sulfide, and manganese and 

manganese compounds. The Pulp and Paper ELGs do not currently regulate any of 

these pollutants. 

Specifically, EPA plans to review facility-specific concentration data for discharges 

of lead and lead compounds, mercury and mercury compounds, and manganese and 

manganese compounds, where available. Additionally, EPA plans to further evaluate 

and understand the basis for estimates of releases reported to TRI; discuss discharges 

of these pollutants with industry trade associations; and review treatment technologies 

for these pollutants to determine the level to which the technologies can treat the 

pollutants. 

For hydrogen sulfide, EPA has determined that industry trade associations are 

actively evaluating discharges from pulp and paper mills and are working on refining 

methods to improve the accuracy of sampling techniques that will improve the quality 

of data reported to TRI in the future. EPA plans to continue to work with industry to 

understand potential releases of hydrogen sulfide, and will continue to monitor 

releases as new data become available. 

•	 Battery Manufacturing (40 CFR Part 461). Given public comments and the lack of 

information at this time, EPA determined that further review of the new battery 

technologies is appropriate to better understand the scope and potential for new 

discharges from battery manufacturing in the U.S. EPA also plans to assess the 

applicability of existing Battery Manufacturing ELGs relative to the new battery 

manufacturing technologies to ensure that if wastewater discharges are occurring 

from these new types of manufacturing, they are adequately covered by the ELGs. 

Specifically, EPA plans to review company and industry association websites, the 

U.S. Economic Census, and business and finance publications to determine the 

current scope of the battery manufacturing industry in the U.S. and the types of 

batteries currently manufactured or planned. EPA also plans to review NPDES permit 

documentation and industrial user agreements to assess how the ELGs are currently 

applied. Additionally, EPA plans to compare pollutants reported as discharged in 

DMR and TRI to those regulated in the ELGs to determine how advances in battery 

manufacturing may impact the types and concentrations of pollutants in resulting 

wastewater. 

•	 Electrical and Electronic Components (E&EC) (40 CFR Part 469). From its 

review of additional industrial categories and pollutants, EPA determined that 

additional review of the E&EC ELGs is appropriate to better understand recent 

technology advancements within the industry that impact production processes and 

wastewater generation and characteristics. For this review, EPA plans to expand its 

evaluation to cover the entire E&EC Category. One specific aspect of this evaluation 

will include whether the manufacture of new types of electronic crystals, including 

sapphire crystals, may introduce pollutants in wastewater discharges that were not 

9-2
 
 

 

9—Preliminary 2016 Plan Decisions and Actions 

considered when the ELGs were originally promulgated. EPA also plans to 

investigate recent advancements in other aspects of electrical and electronic 

components manufacturing, including the manufacture of semiconductors. In 

addition, EPA plans to evaluate treatment technologies that target and remove any 

new pollutants of concern identified. 

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10—Summary Table of Findings for Existing Guideline Categories from the 2015 Annual Review 

10.	 SUMMARY TABLE OF FINDINGS FOR EXISTING GUIDELINE CATEGORIES FROM THE 

2015 ANNUAL REVIEW 

Table 10-1 summarizes the findings from EPA’s 2015 Annual Reviews of existing point 

source categories. EPA uses the following codes to describe its findings and potential next steps 

for each industrial category: 

1.	 Effluent guidelines or pretreatment standards for this industrial category were 

recently promulgated or revised through an effluent guidelines rulemaking, or a 

rulemaking is currently underway. Or, EPA recently completed a preliminary study or 

a detailed study, and no further action is warranted at this time. 

2.	 Revising the national effluent guidelines or pretreatment standards is not the best tool 

to control toxic and non-conventional pollutant discharges because most discharges 

result from one or a few facilities in this industrial category. EPA will consider 

assisting permitting authorities to identify pollution control and pollution prevention 

technologies for the development of technology-based effluent limitations during the 

development of individual permits. 

3.	 Not identified as a priority based on data available at this time because (1) the 

category was not among those that cumulatively account for 95 percent of discharges, 

measured in TWPE, in the 2015 Annual Review; (2) EPA did not determine during 

the 2015 preliminary category review that revisions to the national effluent guidelines 

or pretreatment standards are warranted, or (3) EPA did not identify, during the 

review of additional industrial categories and pollutants, that revisions to the national 

effluent guidelines or pretreatment standards are warranted. 

4.	 EPA intends to start, or continue to conduct, preliminary category reviews of the 

pollutant discharges from this category. 

5.	 EPA intends to start or continue either a preliminary or detailed category study of this 

industry in its 2016 Annual Review to determine whether the category should 

undergo effluent guidelines rulemaking. 

6.	 EPA is identifying this industry for a potential revision of an existing effluent 

guideline. 

Table 10-1. Summary of Findings from EPA’s 2015 Annual Review of Existing Industrial 

Categories 

No. Industry Category (listed alphabetically) 40 CFR Part Findings 

1 Airport Deicing 449 (1) 

2 Aluminum Forming 467 (3) 

3 Asbestos Manufacturing 427 (3) 

4 Battery Manufacturing 461 (4) 

5 Canned and Preserved Fruits and Vegetable Processing 407 (3) 

6 Canned and Preserved Seafood Processinga 408 (1) and (3) 

7 Carbon Black Manufacturing 458 (3) 

10-1
 
10—Summary Table of Findings for Existing Guideline Categories from the 2015 Annual Review 

Table 10-1. Summary of Findings from EPA’s 2015 Annual Review of Existing Industrial
 

Categories
 

No. Industry Category (listed alphabetically) 40 CFR Part Findings 

8 Cement Manufacturing 411 (3) 

9 Centralized Waste Treatment 437 (5) 

10 Coal Mining 434 (3) 

11 Coil Coating 465 (3) 

12 Concentrated Animal Feeding Operations (CAFO) 412 (3) 

13 Concentrated Aquatic Animal Production 451 (3) 

14 Construction and Development 450 (1) 

15 Copper Forming 468 (3) 

16 Dairy Products Processing 405 (3) 

17 Electrical and Electronic Components 469 (4) 

18 Electroplating 413 (5) 

19 Explosives Manufacturing 457 (3) 

20 Ferroalloy Manufacturing 424 (3) 

21 Fertilizer Manufacturing 418 (3) 

22 Glass Manufacturing 426 (3) 

23 Grain Mills 406 (2) 

24 Gum and Wood Chemicals 454 (3) 

25 Hospitals 460 (3) 

26 Ink Formulating 447 (3) 

27 Inorganic Chemicalsb 415 (1) and (3) 

28 Iron and Steel Manufacturing 420 (4) 

29 Landfills 445 (3) 

30 Leather Tanning and Finishing 425 (3) 

31 Meat and Poultry Products 432 (3) 

32 Metal Finishing 433 (5) 

33 Metal Molding and Casting 464 (3) 

34 Metal Products and Machinery 438 (3) 

35 Mineral Mining and Processing 436 (2) 

36 Nonferrous Metals Forming and Metal Powders 471 (3) 

37 Nonferrous Metals Manufacturing 421 (2) 

38 Oil and Gas Extractionc 435 (1) and (3) 

39 Ore Mining and Dressing 440 (3) 

40 Organic Chemicals, Plastics, and Synthetic Fibersd 414 (1) and (4) 

41 Paint Formulating 446 (3) 

42 Paving and Roofing Materials (Tars and Asphalt) 443 (3) 

43 Pesticide Chemicals 455 (4) 

44 Petroleum Refining 419 (5) 

45 Pharmaceutical Manufacturing 439 (3) 

10-2
 
 

 

 

 

c 

10—Summary Table of Findings for Existing Guideline Categories from the 2015 Annual Review 

Table 10-1. Summary of Findings from EPA’s 2015 Annual Review of Existing Industrial
 

Categories
 

No. Industry Category (listed alphabetically) 40 CFR Part Findings 

46 Phosphate Manufacturing 422 (3) 

47 Photographic 459 (3) 

48 Plastic Molding and Forming 463 (3) 

49 Porcelain Enameling 466 (3) 

50 Pulp, Paper, and Paperboard 430 (4) 

51 Rubber Manufacturing 428 (3) 

52 Soaps and Detergents Manufacturing 417 (3) 

53 Steam Electric Power Generating 423 (1) 

54 Sugar Processing 409 (3) 

55 Textile Mills 410 (3) 

56 Timber Products Processing 429 (3) 

57 Transportation Equipment Cleaning 442 (3) 

58 Waste Combustors 444 (3) 

a Code (1) refers to the current effluent guidelines rulemaking, which includes Alaskan Seafood Processing 

facilities. Code (3) indicates that the remainder of the facilities in this category do not represent a hazard 

priority at this time. b	 Code (1) refers to the recent effluent guidelines rulemaking, and subsequent delisting for the CCH 

manufacturing sector, which includes facilities currently regulated by the OCPSF and Inorganic Chemicals 

effluent guidelines. Code (3) indicates that the remainder of the facilities in this category do not represent a 

hazard priority at this time. 

Code (1) refers to the ongoing effluent guidelines rulemaking for unconventional oil and gas extraction facilities 

and EPA’s review of the coalbed methane extraction sector of the industry. Code (3) refers to category 

discharges of the oil and gas extraction industry, excluding coalbed methane and unconventional oil and gas 

extraction facilities that do not represent a hazard priority at this time. d	 Code (1) refers to the recent effluent guidelines rulemaking, and subsequent delisting for the CCH 

manufacturing sector, which includes facilities currently regulated by the OCPSF and Inorganic Chemicals 

effluent guidelines. Code (4) indicates that further review may be appropriate for the remainder of the facilities 

in this category. 

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11—Solicitations for Public Comment and Input 

11. SOLICITATIONS FOR PUBLIC COMMENT AND INPUT 

During the 30-day public comment period for this Plan, EPA is soliciting public comment 

and data and information on the following subjects (see Federal Register Notice): 

•	 The data sources and methodologies used in the 2015 Annual Review. EPA solicits 

comments on the evaluation factors, criteria, and data sources used in conducting its 

2015 Annual Review and in developing the Preliminary 2016 Plan. EPA also 

solicits comment on other data sources it might use in its annual reviews and biennial 

planning process. 

•	 The data and information regarding the discharge and treatment of pollutants from 

Iron and Steel Manufacturing; Organic Chemicals, Plastics, and Synthetic Fibers; 

Pulp, Paper, and Paperboard; Battery Manufacturing; and Electrical and Electronic 

Components Manufacturing. EPA solicits data and information regarding the 

discharge and treatment of pollutants identified in the Preliminary 2016 Plan from 

these industrial processes, as well as any other information relevant to EPA’s review. 

•	 The information EPA compiled to date in the Centralized Waste Treatment (CWT) 

study. EPA gathered information about CWT facilities across the country and 

identified those facilities that currently accept or have in the past accepted oil and 

gas extraction wastewaters. EPA included a memorandum in the record that 

identifies these facilities (ERG, 2015). EPA requests comment on the accuracy and 

completeness of the information contained in this memorandum, as well as any other 

information relevant to EPA’s study of CWT facilities. 

•	 New data and information on known transfers of wastewater originating from 

conventional oil and gas extraction facilities to Publicly Owned Treatment Works 

(POTWs). EPA solicits data and information for the first time on known transfers of 

wastewater originating from conventional oil and gas extraction facilities to POTWs. 

In particular, EPA seeks information on the extent to which this practice is occurring, 

including the identification of conventional oil and gas facilities which discharge to 

POTWs. EPA also requests information on wastewater volumes transferred to 

POTWs as well as information on the pollutants in these wastewater (type, 

concentration, etc.) and any other known characteristics of the pollutants. 

•	 New information on the quantity, composition and purpose of well treatment and 

workover fluids in produced water discharges authorized under 40 CFR Part 435, 

Subpart E (Agricultural and Wildlife Water Use Subcategory). EPA solicits 

information for the first time on the quantity, composition and purpose of well 

treatment and workover fluids in produced water discharges authorized under 40 

CFR Part 435, Subpart E (Agricultural and Wildlife Water Use Subcategory) which, 

if good enough quality, can be used for wildlife or livestock watering or other 

agricultural uses, and actually put to such use during periods of discharge. EPA 

solicits information on both conventional and unconventional oil and gas extraction. 

For this solicitation, “Well treatment fluids” means any fluid used to restore or 

improve productivity by chemically or physically altering hydrocarbon-bearing strata 

after a well has been drilled. “Workover fluids” means salt solutions, weighted 

11-1
 
11—Solicitations for Public Comment and Input 

brines, polymers, or other specialty additives used in a producing well to allow for 

maintenance, repair or abandonment procedures. 

•	 Ideas, approaches and information on how to design smart regulations to support 

emerging technologies as described in A Strategy for American Innovation, prepared 

by the National Economic Council and Office of Science and Technology Policy. 

October 2015. 

11-2
 
 

12—References for the Preliminary 2016 Plan 

12. REFERENCES FOR THE PRELIMINARY 2016 PLAN 

1.	 Auchterlonie, Steve. 2009. Telephone Communication between Steve Auchterlonie, 

Front St. Remedial Action, and Chris Krejci, Eastern Research Group, Inc., Re: 

Verification of Magnitude and Basis of Estimate for Dioxin and Dioxin-like Compounds 

Discharges in PCS. (March 13). EPA-HQ-OW-2008-0517-0076. 

2.	 ERG. 2013. Eastern Research Group, Inc. Environmental Engineering Support for Clean 

Water Regulations Programmatic Quality Assurance Project Plan (PQAPP). Chantilly, 

VA. (May). EPA-HQ-OW-2010-0824-0229. 

3.	 ERG. 2015. Eastern Research Group, Inc. Memorandum: Centralized Waste Treatment 

Facility List. Chantilly, VA. (September). EPA-HQ-OW-2015-0665. DCN 08312. 

4.	 U.S. EPA. 1988a. CERCLA Compliance with Other Laws Manual: Interim Final. 

OSWER Publication 9234.1-01. Washington, D.C. (August). Available online at: 

http://nepis.epa.gov/Exe/ZyPDF.cgi/10001VMG.PDF?Dockey=10001VMG.PDF. EPA540-G-89-006. 

5.	 U.S. EPA. 1988b. Guidance on Remedial Actions for Contaminated Ground Water at 

Superfund Sites. OSWER Directive 9283.1-2. (December). Available online at: 

http://nepis.epa.gov/Exe/ZyPDF.cgi/2000A58O.PDF?Dockey=2000A58O.PDF. EPA540-G-88-003. 

6.	 U.S. EPA. 2002. A Strategy for National Clean Water Industrial Regulations: Effluent 

Limitations Guidelines, Pretreatment Standards, and New Source Performance 

Standards. Washington, D.C. (November). EPA-821-R-02-025. EPA-HQ-OW-2003­

0074-0215. 

7.	 U.S. EPA. 2009a. Technical Support Document for the Annual Review of Existing 

Effluent Guidelines and Identification of Potential New Point Source Categories. 

Washington, D.C. (October). EPA-821-R-09-007. EPA-HQ-OW-2008-0517-0515. 

8.	 U.S. EPA. 2009b. Technical Support Document for the Preliminary 2010 Effluent 

Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQOW-2008-0517-0514. 

9.	 U.S. EPA. 2010. U.S. EPA NPDES Permit Writers’ Manual. Washington, D.C. 

(September). EPA-833-K-10-001. Available online at:
 

http://www3.epa.gov/npdes/pubs/pwm_2010.pdf.
 

10. U.S. EPA. 2012a. The 2011 Annual Effluent Guidelines Review Report. Washington, 

D.C. (December). EPA-821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

11. U.S. EPA. 2012b. Toxic Weighting Factors Methodology. Washington, D.C. (March). 

EPA-820-R-12-005. EPA-HQ-OW-2010-0824-0004. 

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12—References for the Preliminary 2016 Plan 

12. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans. 

Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170-0002. 

13. U.S. EPA. 2015a. Final 2014 Effluent Guidelines Program Plan. Washington, D.C. 

(July). EPA-821-R-15-001. EPA-HQ-OW-2014-0170-0210. 

14. U.S. EPA. 2015b. Known Data Problems. Enforcement and Compliance History Online. 

Washington, D.C. (August). Available online at: https://echo.epa.gov/resources/echodata/known-data-problems. EPA-HQ-OW-2015-0665. DCN 08236. 

15. U.S. EPA. 2016a. The 2015 Annual Effluent Guidelines Review Report. Washington, 

D.C. (June). 821-R-16-002. EPA-HQ-OW-2015-0665. DCN 08209. 

16. U.S. EPA. 2016b. Preliminary Study of the Metal Finishing Category: 2015 Status 

Report. Washington, D.C. (June). EPA-821-R-16-004. EPA-HQ-OW-2015-0665. DCN 

MF00001. 

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