Z 

United States

Environmental Protection

Agency

Final 2014 Effluent

Guidelines Program Plan

July 2015
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U.S. Environmental Protection Agency

Office of Water (4303T)

1200 Pennsylvania Avenue, NW

Washington, DC 20460

EPA-821-R-15-002
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Table of Contents

iv

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

2.3 Effluent Limitations Guidelines and Pretreatment Standards Overview.......................2-10

2.3.1 Best Practicable Control Technology Currently Available (BPT) —

CWA Sections 301(b)(1)(A) and 304(b)(1)......................................................2-11

2.3.2 Best Conventional Pollution Control Technology (BCT) — CWA 

Sections 301(b)(2)(E) and 304(b)(4) ................................................................2-12

2.3.3 Best Available Technology Economically Achievable (BAT) — CWA 

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

2.3.4 New Source Performance Standards (NSPS) — CWA Section 306 ................2-12

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

307(b)................................................................................................................2-12

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

307(c)................................................................................................................2-13

3. 2014 EFFLUENT GUIDELINES PLANNING PROCESS AND METHODOLOGY ....................3-1

3.1 Summary of the 2014 Annual Review Methodology ......................................................3-1

3.1.1 Public Comments on the Preliminary 2014 Plan and Stakeholder Input............3-1

3.1.2 Continued Review of Selected Industrial Categories .........................................3-1

3.1.3 New Data Sources and Additional Supporting Analyses....................................3-3

3.2 Categories Excluded from EPA’s 2014 Annual Review .................................................3-4

3.2.1 Categories for Which EPA Has Recently Promulgated or Revised ELGs.........3-4

3.2.2 Discharges Not Categorizable ............................................................................3-5

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

3.3.1 Data Sources Supporting New or Continued Analyses ......................................3-6

3.3.2 DMR and TRI Data.............................................................................................3-7

4. RESULTS OF THE 2014 ANNUAL REVIEW........................................................................4-1

4.1 Findings from Public Comments and Stakeholder Input.................................................4-1

4.2 Findings from Continued Review of Select Industrial Categories...................................4-4

4.3 Findings from New Data Sources and Additional Supporting Analyses.........................4-5

5. FINAL 2014 PLAN DECISIONS AND ACTIONS ..................................................................5-1

5.1 Industries Previously Identified for Further Review for Which EPA is Taking 

No Action.........................................................................................................................5-1
Table of Contents

TABLE OF CONTENTS (Continued)

Page

v

5.2 Industries for Which EPA is Currently Undertaking an ELG Rulemaking .....................5-2

5.2.1 EPA’s Current Schedule for ELG Actions.........................................................5-2

5.3 Industries for Which EPA Is Currently Conducting Further Study.................................5-3

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

Part 419)..............................................................................................................5-3

5.3.2 Continued Detailed Study of CWT Category (40 CFR Part 437).......................5-4

5.3.3 Continued Evaluation of Cook Inlet, Alaska Oil and Gas Requirements...........5-4

5.3.4 Actions from the 2014 Annual Review ..............................................................5-5

6. SUMMARY TABLE OF FINDINGS FOR EXISTING GUIDELINE CATEGORIES FROM 

THE 2014 ANNUAL REVIEW ............................................................................................6-1

7. REFERENCES FOR THE FINAL 2014 PLAN ......................................................................7-1
Table of Contents

vi

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

Table 6-1. Summary of Findings from EPA’s 2014 Annual Review of Existing 

Industrial Categories.............................................................................................................6-1

LIST OF FIGURES

Page

Figure 2-1. Odd-Year Annual Review of Existing ELGs..........................................................................2-6

Figure 2-2. Odd-Year Identification of Possible New ELGs.....................................................................2-7

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

New ELGs.............................................................................................................................2-8

Figure 2-4. Further Review of Industrial Categories Identified During Annual Reviews.........................2-9

Figure 2-5. Regulations of Direct and Indirect Wastewater Discharges..................................................2-11
Section 1—Executive Summary

1-1 

1. EXECUTIVE SUMMARY

This Final 2014 Effluent Guidelines Program Plan (Final 2014 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 2014 Annual Review of effluent 

guidelines and pretreatment standards, consistent with CWA sections 301(d), 304(b), 304(g), and 

304(m), 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. 

Based on the 2014 Annual Review and public comment, EPA has concluded that no 

additional industries warrant new or revised effluent guidelines at this time. Therefore, EPA is 

not identifying any existing effluent guidelines for revision, nor is EPA identifying any new 

industries for an effluent guidelines rulemaking, aside from those currently undergoing a 

rulemaking (revised effluent limitations guidelines and standards (ELGs) for the Steam Electric 

Power Generating Category and for the Canned and Preserved Seafood Category covering the 

Alaskan seafood processing subcategories). 

EPA is also not identifying the development of any new or revised pretreatment standards 

at this time, excluding those that are currently under development (pretreatment standards for the 

Dental Category and the Unconventional Oil and Gas Extraction Category). 

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

or pollutant groups to determine if new or revised effluent guidelines are warranted. These 

industrial categories include Petroleum Refining, Centralized Waste Treatment (CWTs), Metal 

Finishing, Pesticide Chemicals, Engineered Nanomaterials Manufacturing and Formulating 

(ENMs), and Oil and Gas Extraction in Cook Inlet, Alaska. 

The Final 2014 Plan and its conclusions are supported by EPA’s 2014 Annual Effluent 

Guidelines Review Report (2014 Annual Review Report) (U.S. EPA, 2015), which builds on 

prior reviews and uses new hazard data sources and additional supporting analyses to identify 

new pollutants of concern and wastewater discharges in industrial categories not currently 

regulated by ELGs. Annual Review Reports for prior years are a part of the Annual Review 

record and can be found at http://water.epa.gov/lawsregs/lawsguidance/cwa/304m/index.cfm. 

During the 2014 Annual Review, EPA followed up on several proposed actions identified 

in the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (Final 2012 and 

Preliminary 2014 Plans) (U.S. EPA, 2014a). Specifically, EPA continued the following reviews: 

(1) preliminary review of the Metal Finishing Point Source Category; (2) targeted review of 

pesticide active ingredients (PAIs), for which the discharge from manufacturing is not currently 

regulated under the Pesticide Chemicals ELGs; and (3) review of brick and structural clay 

products manufacturing. EPA also initiated an investigation of the manufacture and processing 

of ENMs as a potential new source of industrial wastewater discharges. Additionally, EPA 

continued its collection of industrial wastewater treatment technology performance data for the 

Industrial Wastewater Treatment Technology (IWTT) Database.
Section 1—Executive Summary

1-2 

From the 2014 Annual Review, EPA determined that continued reviews are warranted for 

two regulated point source categories: Metal Finishing and Pesticide Chemicals Manufacturing. 

The manufacture and processing of ENMs also warrant further review. Specifically, EPA 

determined the following: 

• EPA’s continued preliminary review of the Metal Finishing Category identified 

several topics that warrant further investigation. These include: (1) potential new, 

unregulated pollutants of concern that are being used more commonly in metal 

finishing processes; (2) the prevalence of potential pollutants of concern 

associated with wastewater generated from the use of wet air pollution control 

devices at metal finishing operations; (3) the availability and use of advanced 

wastewater treatment technologies; and (4) the prevalence of zero discharge 

practices in the industry. As a result, EPA plans to continue this review through a 

preliminary study of the Metal Finishing Category. 

• EPA plans to continue its targeted review of PAIs for which the discharge from 

manufacturing is not currently regulated under the Pesticide Chemicals ELGs. 

EPA will use production information reported under Section 7 of the Federal 

Insecticide, Fungicide, and Rodenticide Act (FIFRA), as well as facility National 

Pollutant Discharge Elimination System (NPDES) permit applications, fact 

sheets, and permits for the PAI-producing facilities, to determine which PAIs are 

produced in the U.S. and are present in industrial wastewater discharges from 

pesticide chemicals manufacturing.

• Research and information to date suggest that industrial wastewater discharges 

may contain ENMs, which may have impacts on human health and the 

environment. From its initial review, EPA identified four main areas of research 

appropriate to better assess the potential presence and impact of ENMs in 

industrial wastewater: (1) development of standard methods and sampling 

techniques to detect and characterize ENMs in industrial wastewater; (2) 

evaluation of the toxic impacts of ENMs in industrial wastewater, taking into 

consideration their relevant forms and concentrations; (3) identification of the 

universe of facilities, production values, and waste associated with the 

manufacturing and processing of ENMs; and (4) evaluation and characterization 

of the fate, transformation, and treatment of ENMs in industrial wastewaters. EPA 

plans to continue to monitor ongoing research in these areas in future annual 

reviews and collect any new information on the discharge of ENMs as it becomes 

available. 

EPA determined that further review of brick and structural clay products manufacturing 

is not warranted at this time because wet scrubber use (which EPA identified as a potential new 

source of industrial wastewater discharge from this industry) is limited to a very few facilities. 

See Section 4.2 of this Plan as well as Section 5.3 of the 2014 Annual Review Report (U.S. EPA, 

2015), for more details regarding EPA’s findings related to this industry.

As part of the 2014 Annual Review, EPA also summarized the information captured to 

date in its IWTT Database, including treatment system and performance data from 98 research 

articles that cover 35 industrial categories, 142 pollutant parameters, and 53 individual types of 
Section 1—Executive Summary

1-3 

treatment technologies. EPA plans to continue adding industrial wastewater treatment 

technology data into IWTT for use in future annual reviews. EPA will use this database to 

identify whether specific industrial categories warrant further review for new or revised ELGs, 

based on the range of available treatment technology performance.

As announced in the Preliminary 2014 Plan, EPA has also begun a study of the 

Centralized Waste Treatment (CWT) industry. The study evaluates facilities that accept oil and 

gas extraction wastewaters to determine if the existing ELGs are adequately controlling 

pollutants found in the wastewaters. EPA has collected existing data and plans to visit sites, 

conduct monitoring, and gather additional data in the coming year. 

Also announced in the Preliminary 2014 Plan, EPA has begun a study of the Petroleum 

Refining industry. The study will determine if changes that the industry has experienced since 

the ELGs were last revised, including the use of heavier crude and wet air pollution controls, 

make updates to the existing ELGs, including pretreatment standards, appropriate. The study will 

also investigate whether pollution prevention or wastewater treatment methods are available to 

reduce pollutants present in the industrial wastewater. As part of the study, EPA plans to collect 

updated industry profile data, recent discharge data, and NPDES permit information. EPA also 

plans to conduct site visits and will collect additional information from industry, EPA regions, 

states, and literature sources.

EPA also considered public comments and information submitted by stakeholders in 

response to a solicitation for comments on the Preliminary 2014 Effluent Guidelines Program 

Plan (Preliminary 2014 Plan), published together with the Final 2012 Plan in the Federal 

Register on September 16, 2014 (79 FR 55472). These Plans can be found at 

http://www.gpo.gov/fdsys/pkg/FR-2014-09-16/html/2014-22062.htm. 

A total of 12 comment letters were received on the Preliminary 2014 Plan. The majority 

of the public comments either supported or did not support studies relating to the CWT Category, 

the Petroleum Refining Category, and the Metal Finishing Category, which EPA announced in 

the Preliminary 2014 Plan. Two commenters expressed support for EPA’s continued 

investigation into the presence and impact of ENMs in industrial wastewater. See Section 4 for a 

more detailed summary of the public comments received on the Preliminary 2014 Plan. 

Additionally, a table of the comments, including commenter name, commenter organization, and 

a short summary of the comment can be found in the 2014 Annual Review Report (U.S. EPA, 

2015). 
Section 2—Background

2-1 

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 Clean Water Act (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 effluent limitations guidelines and 

standards (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, for example, “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.

EPA is responsible for developing technology-based ELGs, based on currently 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). Categorical pretreatment standards are directly 

enforceable. 

While technology-based effluent limitations and standards 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 the discharges from each 

facility meet the water quality standards of its 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. 

The 1972 amendments to the CWA 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 CWA focused principally on water 
Section 2—Background

2-2 

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 1972 CWA directed EPA to promulgate effluent limitations guidelines and standards 

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 pollutionprevention practices for an industrial category or subcategory as a whole; (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 set the nation’s sights 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, will, at a minimum, meet similar effluent limitations and 

standards representing the performance of the “best” pollution control technologies or pollution 

prevention practices. ELGs provide the opportunity to promote pollution prevention and water 

conservation. This may be particularly important in controlling persistent, bioaccumulative, and 

toxic pollutants discharged in concentrations below analytic detection levels. 

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 contaminated water, fish, or shellfish; and

• Degrade aquatic ecosystems. 

EPA has promulgated effluent guidelines for 58 industrial categories (see Table 6-1

below; all 58 industrial categories are described at

http://water.epa.gov/scitech/wastetech/guide/history.cfm). 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. Based on estimates of pollutant reductions from each 

separate guideline, EPA has estimated that the regulations, cumulatively, have prevented the 

discharge of approximately 700 billion pounds of toxic pollutants annually. 
Section 2—Background

2-3 

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 sections 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; and

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

during the planning process. 

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

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

described at http://water.epa.gov/scitech/wastetech/guide/strategy/fs.cfm. 

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

category’s discharge and the relative hazard posed by that discharge. Using this factor enables 

EPA to prioritize rulemakings to achieve significant environmental and health benefits. 

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

demonstrated wastewater treatment technologies, process changes, or pollution prevention 

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

wastewater and, consequently, reduce the hazard posed by these pollutant discharges to human 

health or the environment. 

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 a less 

stringent, less expensive approach to reduce pollutant loadings would better satisfy applicable 

statutory requirements.

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

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

innovative approaches such as water-quality trading, including within-plant trading. This factor 

might also prompt EPA, during annual reviews, to decide against revising an existing set of 

effluent guidelines or pretreatment standards where the pollutant source is already efficiently and 

effectively controlled by other regulatory or non-regulatory programs.
Section 2—Background

2-4 

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 ranking 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). For the 

TRA, EPA relies on discharge monitoring report (DMR) and Toxics Release Inventory (TRI) 

data to rank industrial discharge categories by toxic-weighted pound equivalents (TWPE) 

released. 

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’s (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.1 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 its even-year reviews, 

EPA is targeting new data sources that will provide information on other considerations 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; and

• Other hazard data and information not captured through 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 Final 2014 

Effluent Guidelines Program Plan (Final 2014 Plan), for details on the methodology used 

specifically for EPA’s 2014 Annual Review. 

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

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

to human health and the environment) in the TRA, or are identified as warranting further review 

during the even-year analyses. 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. 

 

1 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, available online at http://www.gao.gov/assets/650/647992.pdf. 
Section 2—Background

2-5 

2.2.1.1 Preliminary Category Reviews

For the industrial categories with the highest hazard potential identified in the TRA, or 

identified as a priority from any of the even-year review analyses, EPA may conduct a 

preliminary category review, particularly 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. In its preliminary category reviews, EPA typically 

examines 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 and fill in data gaps. Next, EPA considers the factors that may be 

contributing to these discharges. These include, for example, changes in the production practices, 

costs, and performance of applicable and demonstrated technologies, or pollution prevention 

alternatives that can effectively reduce the pollutants in the point source category’s wastewater. 

These assessments provide an additional level of quality assurance on the reported pollutant 

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

discharge.

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 categorization, 

(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, not 

geographically isolated, and likely to be the result of the production practices in use broadly 

throughout the category, EPA may decide to conduct a preliminary or detailed study prior to 

initiating a rulemaking. In many cases, the information and data gathered for a study forms the 

basis of information used for the rulemaking. However, in some instances, EPA may decide not 

to move forward with a rulemaking following a study, if the data and information gathered 

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

announces to the public and other stakeholders decisions to conduct studies, or to develop 

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

appropriate, schedules are also announced in the Plan. 

2.2.1.2 Preliminary and Detailed Studies

After conducting the preliminary category reviews, as shown in Figure 2-4, EPA may

then conduct either a preliminary or detailed study of an industrial category. Typically, these 

studies profile an industry category, gather information about the hazards posed by its 

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

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 typically 

examines the factors and data sources listed above for preliminary category reviews. However, 
Section 2—Background

2-6 

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 analysis conducted during a 

preliminary category review or study, and may include primary data collection activities (such as 

industry questionnaires and wastewater sampling and analysis) to fill data gaps.

* 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

Begin odd-year review

of existing ELGs

Identify 

applicable SIC 

and NAICS 

codes for each 

point source 

category

Preliminary results of Toxicity Rankings Analysis

= Combined TRIReleases and DMRLoads

database rankings (Factor 1)

DMR & TRI

database 

tools

Stakeholder 

recommendations 

and comments

Are ELG revisions 

currently 

underway?

Have 

ELGs been 

developed or revised 

within the past 7 

years?

Are 

non-representative 

facilities responsible for 

overall category

TWPE?

When ranked 

by TWPE, does category 

contribute to top 95% of 

cumulative TWPE of all 

categories?

Are there 

identified implementation

and efficiency 

issues (Factor 4)?

Not a priority

category, no 

further

review at this time

Not a priority

category, no further

review at this time* 

Not a priority 

category,

but may recommend 

permitting support

for individual facilities

Further review

(see Figure 2-4)

Possible outcomes

-Further review

-BPJ support

-Identify for 

possible

revision of existing 

ELGs

-No action

Stakeholder recommendations and comments

Not a priority category,

no further review at this time

No

No

No

No

No

Yes

Yes

Yes

Yes

Yes

Evaluation of treatment technology performance data
Section 2—Background

2-7 

* Significant concentrations include levels above minimum levels from 40 CFR Part 136 or other EPA-approved 

methods, levels above treatability levels, or at levels of concern to human health and toxicity.

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

Stakeholder recommendations

and comments

Begin industry

identification

TRA databases

No identification or

further review necessary

Identify SIC/NAICS codes

with discharges not subject

to existing ELGs

Is the SIC/NAICS code 

appropriately considered a 

potential new subcategory

of an existing ELG?

Is the possible new

category all or nearly all

indirect dischargers?

Include in annual review 

of

existing category

(see Figure 2-1)

Are pollutants

potentially present at

significant 

concentrations?*

No identification or

further review 

necessary

Do 

discharges interfere

with or otherwise pass

through POTW

operations?

Further review

(see Figure 2-4)

Identify other tools

(e.g. permit-based

support or guidance)

Are ELGs the 

appropriate tool?

No

No

No

Yes No No

Yes

Yes Yes

Yes
Section 2—Background

2-8 

* Significant concentrations include levels above minimum levels from 40 CFR Part 136 or other EPA-approved 

methods, levels above treatability levels, or at levels of concern to human health and toxicity.

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

New ELGs

Begin even-year review

of hazard data sources and 

treatment technology 

performance data

Identify industries with 

pollutant

discharges not previously 

reviewed

Determine if an 

existing industry point source

category is applicable

to discharges

Stakeholder

recommendations

and comments

Continued review from 

odd-year (as necessary)

Collect additional data from

industry groups, published

reports from EPA, and peerreviewed publications

Are pollutants

potentially present at

significant

concentrations?*

Not a priority

category, no 

further

review at this time

Further review

(see Figure 2-4)

Do ELGs 

appropriately

regulate all pollutant

discharges identified?

Not a priority

category, no further

review at this time

No

No

No

Yes

Yes

Yes
Section 2—Background

2-9 

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

Category identified for further 

review (see Figures 2-1, 2-2, and 2-3)

Further Review

- Preliminary category 

review

- Preliminary or detailed 

study

(continue collecting data 

covering all four factors)

Are discharges

adequately controlled

by existing ELGs?

No further review at this time

Are ELGs potentially 

the appropriate tool?

Identify for possible 

promulgation or revision 

of ELGs

Identify other tools (e. g., 

permit-based support or guidance)

Not enough

information

Stakeholder 

input

Yes

No

Yes

No

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 effluent limitations guidelines that EPA has promulgated 

under that section. EPA’s 2014 Annual Effluent Guidelines Review Report (2014 Annual Review 

Report) presents the results of its effluent limitations guidelines reviews (U.S. EPA, 2015). 

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

EPA works to coordinate its annual reviews of existing effluent guidelines under section 304(b) 

with its publication of Preliminary and Final Plans under CWA section 304(m). As a result, Final 

Plans 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, depending upon when it 
Section 2—Background

2-10 

identifies a category warranting further review. 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 may inform the content of the Preliminary and 

Final Plans (e.g., by identifying candidates for effluent limitations guidelines revision, or by 

identifying point source categories for which EPA has never promulgated effluent limitations 

guidelines). Second, even though it is not required to do so under either section 304(b) or section 

304(m), EPA believes it can serve the public interest by periodically describing the annual 

reviews (including the review process used) and review results to the public. Doing so while 

simultaneously publishing the Preliminary and Final Plans makes both processes more 

transparent. Third, by requiring EPA to review existing effluent limitations guidelines each year, 

Congress appears to have intended for each successive review to build upon 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 available technology economically achievable (BAT).

3. Best conventional control technology (BCT).

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 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 sources that discharge to POTWs (indirect dischargers), EPA promulgates pretreatment 

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

authorities. See CWA sections 307(b), (c); 33 U.S.C. § 1317(b), (c). Figure 2-5 illustrates the 

relationship between the regulation of direct and indirect dischargers. 
Section 2—Background

2-11 

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 pollutants, of which 

126 specific substances have been designated priority toxic pollutants. See Appendix A to Part 

423, reprinted after 40 CFR Part 423.17. All other pollutants are considered to be 

nonconventional. 

In specifying BPT, EPA looks at a number of 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. 

NSPS

• Conventional Pollutants

• Nonconventional Pollutants

• Priority Pollutants (Toxics)

BPT

• Conventional Pollutants

• Nonconventional Pollutants

• Priority Pollutants (Toxics)

BCT

• Conventional Pollutants

BAT

• Nonconventional Pollutants

• Priority Pollutants (Toxics)

New 

Sources

Existing 

Sources

Direct Dischargers

PSNS

• Nonconventional Pollutants

• Priority Pollutants (Toxics)

PSES

• Nonconventional Pollutants

• Priority Pollutants (Toxics)

Indirect Dischargers
Section 2—Background

2-12 

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 guidelines 

based on BAT. See CWA sections 301(b)(2)(A), (C), (D), and (F). The factors considered in 

assessing BAT include the cost of achieving BAT effluent reductions, the age of equipment and 

facilities involved, the process employed, potential process changes, non-water-quality 

environmental impacts (including energy requirements), and such other factors the EPA 

Administrator deems appropriate. See CWA section 304(b)(2)(B). The technology must also be 

economically achievable. See CWA section 301(b)(2)(A). 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 nonwater-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).

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

national pretreatment standards, are found at 40 CFR Part 403. 
Section 2—Background

2-13 

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.
Section 3—2014 Effluent Guidelines Planning Process and Methodology

3-1 

3. 2014 EFFLUENT GUIDELINES PLANNING PROCESS AND METHODOLOGY

This section summarizes the process EPA used in its 2014 Annual Review to identify 

industrial categories for potential development of new or revised effluent limitations guidelines 

and standards (ELGs), as well as the data sources and limitations used to complete this review. 

This process consists of the following: 

• Considering public comments on the Preliminary 2014 Effluent Guidelines 

Program Plan (Preliminary 2014 Plan) and other stakeholder input. 

• Continuing to review (e.g., collecting additional data, contacting permit writers, 

evaluating available treatment technology information) specific industrial 

categories that EPA identified as warranting additional review in the Final 2012 

and Preliminary 2014 Effluent Guidelines Program Plans (Final 2012 and 

Preliminary 2014 Plans). 

• Identifying and evaluating new data sources and conducting additional supporting 

analyses to do the following:

— Identify new wastewater discharges or pollutants not previously regulated; 

and 

— Identify wastewater discharges that industry can more effectively treat or 

eliminate.

3.1 Summary of the 2014 Annual Review Methodology 

This section briefly summarizes EPA’s 2014 Annual Review methodology. For more 

information and details on EPA’s 2014 Annual Review methodology and analyses, see Part II 

(Sections 3 through 6) of EPA’s 2014 Annual Effluent Guidelines Review Report (2014 Annual 

Review Report) (U.S EPA, 2015). 

3.1.1 Public Comments on the Preliminary 2014 Plan and Stakeholder Input 

For the 2014 Annual Review, EPA considered public comments and stakeholder input 

received on the Preliminary 2014 Plan. See Section 4.1 for a summary of the public comments 

and stakeholder input received. For a detailed listing of the organizations that provided public 

comment and stakeholder input, see DCN 08110. 

3.1.2 Continued Review of Selected Industrial Categories

EPA continued to evaluate industrial categories that it identified as warranting further 

review in the Final 2012 and Preliminary 2014 Plans. These included two regulated industrial 

categories, Metal Finishing (40 CFR Part 433) and Pesticide Chemicals (40 CFR Part 455), and 

one potential new source of industrial wastewater discharge (brick and structural clay products 

manufacturing) (U.S. EPA, 2014a).

EPA documented the quality and usability of the data supporting its continued review of 

these industrial categories and evaluated how the data could be used to improve the 
Section 3—2014 Effluent Guidelines Planning Process and Methodology

3-2 

characterization of industrial wastewater discharges. EPA collected and reviewed data to identify 

the universe of facilities with known or potential discharges, the concentration and quantity of 

pollutants, and the wastewater treatment available for new industries. EPA then prioritized the 

findings for further review.

3.1.2.1 Continued Review of the Metal Finishing Category (40 CFR Part 433) 

As part of the 2012 Annual Review, EPA determined that transfers from metal finishing 

wastewater to publicly-owned treatment works (POTW) sludge may be contributing to higher 

POTW sludge concentrations of metals, particularly chromium, nickel, and zinc. In addition, in a 

recent letter to EPA and in its public comments on the Preliminary 2012 Plan, the Association of 

Clean Water Administrators (ACWA) urged EPA to revise the regulations or issue new guidance 

to address advancements in process and treatment technology for metal finishing and metal 

finishing wastewater. ACWA also urged EPA to update the interpretation of the applicability of 

the Metal Finishing regulations in light of current industrial practices (ACWA, 2013; U.S. EPA, 

2014b). Furthermore, in the 2013 Annual Review, the Metal Finishing Category ranked high in 

terms of toxic-weighted pound equivalents (TWPE) in EPA’s toxicity ranking analysis (TRA). 

To understand whether the Metal Finishing Category’s current ELGs may warrant 

revisions, EPA reviewed the scope of the existing ELGs, examined the current industry profile, 

and gathered data on wastewater treatment technologies in the 2014 Annual Review. EPA also 

contacted regional EPA pretreatment coordinators to further discuss metal finishing operations 

and potential applicability issues with the Metal Finishing ELGs. See Section 5.1 of the 2014 

Annual Review Report for details on the specific methodologies and analyses EPA employed for 

its continued review of the Metal Finishing Category (U.S. EPA, 2015). 

3.1.2.2 Targeted Review of Pesticide Active Ingredients (PAIs) Without Pesticide 

Chemicals Manufacturing Effluent Limits (40 CFR Part 455) 

As part of the 2012 Annual Review, EPA reviewed analytical methods that it recently 

developed or revised to facilitate its identification of unregulated pollutants in industrial 

wastewater discharge. By examining these methods, EPA identified 30 PAIs that are now 

measured by existing analytical methods under 40 CFR Part 136, but that do not currently have 

effluent limits under Subparts A and B in the Pesticide Chemicals ELGs (40 CFR Part 455) (U.S. 

EPA, 2014c). For the 2014 Annual Review, EPA began evaluating data sources that would 

provide information on the production of the 30 PAIs of interest to identify and prioritize for 

further review any that are manufactured in the U.S. These sources included pesticide 

registration status under Section 3 of the Federal Insecticide, Fungicide, and Rodenticide Act 

(FIFRA) and production information reported under Section 7 of FIFRA. See Section 5.2 of the 

2014 Annual Review Report for details on the specific methodologies and analyses EPA 

employed for its targeted review of PAIs for which the discharge from manufacturing is not 

regulated under the Pesticide Chemicals ELGs (U.S. EPA, 2015). 

3.1.2.3 Continued Review of Brick and Structural Clay Products Manufacturing

In its 2012 Annual Review, EPA identified brick and structural clay products 

manufacturing as an industry not currently regulated by ELGs that may generate industrial 

wastewater discharges due to federal air pollution control requirements. To understand if 
Section 3—2014 Effluent Guidelines Planning Process and Methodology

3-3 

wastewater discharges are being generated as a result of the implementation of the air 

regulations, as part of its 2014 Annual Review, EPA reviewed the current National Emission 

Standards for Hazardous Air Pollutants (NESHAP) for the industry to assess more about the 

potential impacts on the industry, specifically regarding the installation of wet air pollution 

controls. See Section 5.3 of the 2014 Annual Review Report for details on the specific 

methodologies and analyses EPA employed for its continued review of brick and structural clay 

products manufacturing (U.S. EPA, 2015). 

3.1.3 New Data Sources and Additional Supporting Analyses 

For the 2014 Annual Review, EPA also initiated a review of engineered nanomaterials

(ENMs), an emerging pollutant group of concern, and continued its review of industrial 

wastewater treatment technology performance data in order to populate the Industrial 

Wastewater Treatment Technology (IWTT) Database. EPA’s goals in focusing on these specific 

analyses were to identify new wastewater discharges or pollutants not previously regulated, and 

to identify wastewater discharges that can be eliminated or treated more effectively.

EPA documented the quality of the data supporting these reviews, evaluated how the data 

could be used to improve the characterization of industrial wastewater discharges (such as 

detection or monitoring of new pollutants, wastewater treatment available for specific industries, 

as well as current treatability levels), and prioritized the findings for further review.

3.1.3.1 Review of Engineered Nanomaterials (ENMs) in Industrial Wastewater 

In the 2014 Annual Review, EPA began evaluating ENMs as a potential emerging 

industrial wastewater pollutant category of concern. This was in response to public comments 

received on the Final 2010 Effluent Guidelines Program Plan (76 FR 66286) regarding the 

manufacture, use, and environmental release of nanosilver, as well as recent research and interest 

about ENMs impacts on human health and the environment. EPA reviewed current literature and 

communicated with leading researchers and government stakeholders about the fate, transport, 

and effects of ENMs on the environment and human health, and about the presence and 

discharge of ENMs in industrial wastewater. EPA focused its review on three classes of ENMs: 

silver, titanium dioxide, and carbon-based nanomaterials, which are estimated to be produced in 

the largest volumes. Further research has more fully classified their impact on human health and 

the environment relative to the impacts of other types of ENMs (for which there is little 

information). EPA assessed currently available information and identified outstanding data gaps 

related to characterizing and quantifying the presence and impact of ENMs in industrial 

wastewater discharges. See Section 6.1 of the 2014 Annual Review Report for details on the 

specific methodologies and analyses EPA employed for its review of ENMs in industrial 

wastewater (U.S. EPA, 2015). 

3.1.3.2 Review of Industrial Wastewater Treatment Technologies

EPA continued reviewing technical papers and research articles that document the 

performance of new and improved industrial wastewater treatment technologies. EPA is working 

to capture the performance data and treatment information in a searchable database. Such a 

database would facilitate screening of industrial categories for new or revised ELGs based on the 

availability and effectiveness of technologies in removing pollutants of concern from specific 
Section 3—2014 Effluent Guidelines Planning Process and Methodology

3-4 

industrial wastewater discharges. As part of the 2014 Annual Review, EPA described its 

industrial wastewater treatment technology data collection methodology; data quality assurance 

and control protocol; and database design, development, and storage. EPA also summarized the 

industrial wastewater treatment technology information collected to date. See Section 6.2 of the 

2014 Annual Review Report for details on the specific methodologies and analyses EPA 

employed for its review of industrial wastewater treatment technologies (U.S. EPA, 2015). 

3.2 Categories Excluded from EPA’s 2014 Annual Review 

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

consideration during its 2014 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 National Pollutant Discharge Elimination 

System (NPDES) permit, but do not fall under an existing or new point source 

category or subcategory (e.g., Superfund sites); and 

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

3.2.1 Categories for Which EPA Has Recently Promulgated or Revised ELGs

In its 2014 Annual Review, EPA excluded point source categories for which ELGs were 

recently established or revised but are not yet fully implemented. Point source categories that 

were recently reviewed in a rulemaking context, but for which EPA decided to withdraw the 

proposal or select the “no action” option, were also excluded. In general, EPA removed an 

industrial point source category from further consideration during a review cycle if EPA 

established, revised, or reviewed the category’s ELGs within seven years prior to 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 2014 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

December 1, 2009

Revised March 6, 2014

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

449 Airport Deicing May 16, 2012

As part of its 2014 Annual Review, EPA also did not consider industrial categories for 

which it is currently engaged in a rulemaking process. These include the Steam Electric Power 

Generating Category, 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 unconventional extraction in the Oil and Gas Extraction 
Section 3—2014 Effluent Guidelines Planning Process and Methodology

3-5 

Category. See Section 5.2 of this Final 2014 Plan for details on the rulemaking status for these 

categories.

3.2.2 Discharges Not Categorizable 

In its 2011 Annual Review, EPA identified discharges that are not categorizable into 

existing or new point source categories or subcategories (U.S. EPA, 2012a). In particular, EPA 

reviewed high TWPE discharges from a Superfund site (Auchterlonie, 2009). 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 in the Preliminary 2012 Plan 

(78 FR 48159), EPA determined that these discharges do not fall into a single point source 

category and continued to exclude these discharges in its 2014 Annual Review. 

3.3 Data Quality Assurance and Limitations 

EPA’s methodology for the 2014 Annual Review involved several components, as 

discussed in Section 3.1, including continued review of selected industrial categories, an 

evaluation of new data sources and additional supporting analyses, and an assessment of public 

comments and other stakeholder input. 

EPA used the following sources to characterize wastewater discharges during the 2014 

Annual Review: 

• Data and information from academic researchers (non-published); 

• Conference proceedings, peer-reviewed journals, industry-specific organization 

literature;

• EPA, state, and local government information provided in telephone calls, and 

email correspondence;

• Federal, state, and local government publications; 

• Data and information obtained from industry; 

• Data and information obtained from trade associations; 

• Information obtained from the National Nanotechnology Initiative; 

• Other stakeholder data and information; and 

• U.S. Economic Census data. 

In addition, as in previous annual reviews, EPA continued to use Toxics Release 

Inventory (TRI) and discharge monitoring report (DMR) data, downloaded from the DMR 

Pollutant Loading Tool during the 2014 Annual Review. This section discusses these data 

sources and their limitations.
Section 3—2014 Effluent Guidelines Planning Process and Methodology

3-6 

3.3.1 Data Sources Supporting New or Continued Analyses 

For its 2014 Annual Review, EPA used existing data to support analyses of the potential 

environmental impact of industrial discharges. EPA obtained the existing data from publications 

and databases available from other EPA offices, directly from industry and regulators, and 

through online sources. EPA considered the accuracy, reliability, and representativeness of data 

sources to assess their usability for the 2014 Annual Review, as described below and in Section 

4.3.1 of the Environmental Engineering Support for Clean Water Regulations Programmatic 

Quality Assurance Project Plan (PQAPP) (ERG, 2013). EPA also referenced Table 4-2 in the 

PQAPP to determine if the sources provided information that was sufficiently accurate and 

reliable to use in the 2014 Annual Review. 

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

sources were sufficiently accurate to support the characterization of industry waste streams and

the performance of specified treatment technologies. These sources included state and federal 

reports, selected conference proceedings, peer-reviewed journal articles, and information 

obtained directly from federal, state, or local government organizations. EPA also considered

data and information from certain non-peer-reviewed industry publications to assist in 

qualitatively characterizing specific industrial discharges. 

Reliability. Using the following factors, 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 methodologies are consistently applied throughout the 

analysis, as reported in the source; and

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

clearly characterized.

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

characterization of industry waste streams and the performance of specified treatment 

technologies. 

Representativeness. EPA evaluated existing data for use in qualitative analyses based on 

whether the data provide a national perspective and are relevant to and representative of the 

industry or pollutant group to which the data are applied using the following factors: 

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

interest (e.g. the industry description or Standard Industrial Classification (SIC) 

and North American Industry Classification System (NAICS) codes provided in 

the data source, when available, match the industry or pollutant group of interest, 
Section 3—2014 Effluent Guidelines Planning Process and Methodology

3-7 

the wastewater treatment technology is appropriate for the waste stream(s) 

generated at the facility).

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

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

characteristic of the industry or pollutant group as a whole? Can the treatment 

technology generally be used to treat wastewater(s) from the industry?).

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

the characterization of industry waste streams and the performance of specified treatment 

technologies. 

For more information on the quality assurance activities supporting the 2014 Annual 

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

sources, see Appendix B of the 2014 Annual Review Report (U.S EPA, 2015). 

3.3.2 DMR and TRI Data 

EPA has previously explained its use of DMR and TRI data in the Technical Support 

Document for the Annual Review of Existing Effluent Guidelines and Identification of Potential 

New Point Source Categories (2009 Screening-Level Analysis (SLA) Report) (U.S. EPA, 2009). 

The 2009 SLA Report provides the detailed methodology used to process thousands of data 

records and generate national estimates of industrial effluent discharges.

In general, EPA uses DMR data to understand discharges of pollutants that are regulated 

by an ELG or for which NPDES permits require monitoring. More than 190,000 industrial 

facilities and 17,000 wastewater treatment plants have NPDES individual or general permits2 for 

wastewater discharges to waters of the U.S. Facilities must report compliance with NPDES 

permit limits via DMRs. DMR data can include pollutant concentration and/or quantity, flow, 

and identification of permit violations. Thus DMR data provide readily available and relevant 

information on industrial pollutant discharges to surface waters, e.g., direct discharges. 

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

pollutants to POTWs as well as the discharge of pollutants that are not regulated via NPDES 

permits. TRI requires facilities that meet operating thresholds, to report on-site releases of certain 

listed toxic chemicals to receiving streams and POTWs, as well as other media (e.g., air, land, 

underground wells, and several other categories). 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 provides 

supplementary information to DMR data regarding potential additional unregulated 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. 

 

2 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, 2007).
Section 3—2014 Effluent Guidelines Planning Process and Methodology

3-8 

For its analyses EPA typically relies on outputs from the DMR Pollutant Loading Tool,3

which categorizes pollutant discharges using the SIC and NAICS codes and calculates pollutant 

loadings using DMR and TRI discharge data. In its analyses, EPA multiplies a mass loading of a 

pollutant in pounds per year (as reported in the DMR Pollutant Loading Tool) by a pollutantspecific toxic weighting factor (TWF) to derive a toxic-weighted pound equivalent (TWPE)

loading. For more information on TWFs, see EPA’s Toxic Weighting Factors Methodology 

(U.S. EPA, 2012b). EPA also classifies each facility reporting discharges into a particular 

industrial point source category based on the applicable SIC or NAICS codes for that facility. 

TRI includes information on a facility’s NAICS code, while DMR data include information on a 

facility’s SIC code. EPA then sums the TWPE for each facility classified in a point source 

category to calculate a total TWPE per category for a given year. 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 any 

SIC code.

Includes discharge data from facilities classified by 

manufacturing NAICS codes and some 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. 

Some releases are based on estimates due to TRI 

reporting guidance; some facilities may over- or 

under-estimate releases.

Limited discharge data on minorb discharges.

Certain chemicals are reported as a class, not as 

individual compounds.

a 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 overestimate 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.

 

3 The DMR Pollutant Loading Tool is at http://cfpub.epa.gov/dmr/. The tool is maintained by EPA’s Office of 

Enforcement and Compliance Assurance, Office of Compliance. 
Section 3—2014 Effluent Guidelines Planning Process and Methodology

3-9 

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

TRI DMR

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 an overestimation 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).

The DMR and TRI data EPA used have been evaluated and corrected during previous 

Toxicity Ranking Analyses (TRAs) reported for calendar years 2000, 2002, 2004, and 2006–

2013. For a detailed list of all corrections made to the 2011 DMR and TRI data, see Section 3.3.1 

and 3.3.2, respectively, in EPA’s 2013 Annual Review Report (U.S. EPA, 2014d).
Section 4—Results of the 2014 Annual Review

4-1 

4. RESULTS OF THE 2014 ANNUAL REVIEW

For the 2014 Annual Review, EPA evaluated public comments and stakeholder input 

received on the Preliminary 2014 Effluent Guidelines Program Plan (Preliminary 2014 Plan) 

and continued its review of specific industrial categories that EPA identified as warranting 

additional review in the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans 

(Final 2012 and Preliminary 2014 Plans). Furthermore, EPA identified new data sources and 

conducted additional supporting analyses. 

4.1 Findings from Public Comments and Stakeholder Input

EPA’s annual review process considers information provided by the public and 

stakeholders regarding new or revised effluent limitations guidelines and pretreatment standards. 

This section presents a summary of the comments received on the Preliminary 2014 Plan. A 

more detailed summary table of the comments can be found in the 2014 Annual Effluent 

Guidelines Review Report (2014 Annual Review Report) (U.S. EPA, 2015). 

EPA published its Preliminary 2014 Plan together with the Final 2012 Plan and provided 

a 60-day public comment period on the Preliminary 2014 Plan starting on September 16, 2014 

(see 79 FR 55472). The Docket supporting this Final 2014 Effluent Guidelines Program Plan 

(Final 2014 Plan) includes a complete set of the comments submitted, as well as the Agency’s 

responses (see DCN 08110).

EPA received public comments on the Preliminary 2014 Plan from 18 organizations; one 

consultant to pretreatment programs for local governments, one organization representing states, 

nine organizations representing industry, and seven environmental organizations.4 The public 

comments addressed the following topics: 

• Centralized waste treatment (CWTs) (5 comments); 

• Petroleum refining (4 comments); 

• Metal finishing (3 comments); 

• Nanomaterials (3 comments); 

• Oil and gas pretreatment standards and ongoing rulemaking for oil and gas 

extraction for unconventional oil and gas facilities (2 comments); and

• Other (2 comments). 

EPA received five comments on its proposed CWTs detailed study from one consultant 

to local government pretreatment programs, two industry representatives, and several 

environmental organizations. The consultant to local government pretreatment programs 

commented that EPA should review and clearly define the applicability of CWT effluent 

limitations guidelines and standards (40 CFR Part 437) as they relate to accepting oil and natural 

 

4 Seven environmental organizations submitted one combined public comment on the Preliminary 2014 Plan. One of 

the environmental organizations also submitted a separate public comment on the Preliminary 2014 Plan.
Section 4—Results of the 2014 Annual Review

4-2 

gas produced wastewater. One industry representative questioned the intent and basis for the 

CWTs detailed study, stating there is a lack of definition for what qualifies as a CWT, a lack of a 

reasonable basis for initiating the study, and potential overlap with the Oil and Gas Extraction 

ELGs for shale gas facilities that direct their wastewater to CWTs. The other industry 

representative commented that revising the CWT ELG may not be necessary to address 

discharges of oil and gas extraction wastewater (to CWTs, POTWs, or surface water) and that 

any new regulations and/or guidelines for CWT facilities could be aided by direct meetings 

between EPA, industry experts in the field, and the operators of CWT facilities. The 

environmental organizations supported EPA’s decision to undertake a detailed study of CWTs 

that accept oil and gas wastewaters and requested the study be expedited, stating that (1) the 

CWT ELGs are out of date in light of the developments in the oil and gas extraction industry; (2) 

CWTs may not have treatment in place for pollutants in oil and gas wastewaters; (3) oil and gas 

wastewaters may have potential impacts on drinking water sources; and (4) pretreatment 

standards under development for discharges to POTWs from onshore unconventional oil and gas 

extraction could result in more discharges to CWTs. One environmental organization also 

provided recommendations for resources and information in support of the CWT detailed study. 

For the Petroleum Refining Category (40 CFR Part 419), EPA received three comments 

from industry representatives questioning the quality and appropriateness of data used as the 

basis for initiating the study. Industry representatives also questioned EPA’s objective for 

examining feedstock metals. One industry representative questioned the basis for EPA’s 

investigation of polynuclear aromatic hydrocarbons. EPA also received a comment from the 

consultant to local government pretreatment programs supporting the detailed study and 

suggesting that EPA specifically evaluate common problem pollutants, including benzene and 

sulfides. In addition, the commenter indicated that EPA should evaluate groundwater pump-andtreat operations to clearly define regulated, unregulated, and dilute waste streams.

EPA received comments on its proposal to continue review of the Metal Finishing 

Category (40 CFR Part 433) from the consultant to local government pretreatment programs, one 

industry representative, and an organization representing states. The consultant to the local 

government pretreatment programs did not support reopening the regulation because it could 

make the regulation vulnerable to weakening by special interest groups. The industry 

representative did not support further review of the Metal Finishing Category, stating that EPA 

recently reviewed the industry as part of the Metal Products and Machinery ELGs rulemaking 

and determined that revised guidelines were not necessary. Further, the industry representative 

commented that the industry is not using new processes or treatment technologies that would 

suggest the need to revise the applicable Metal Finishing ELGs, and POTWs have the ability to 

impose stricter limits to address specific concerns. The organization representing states

supported further review of the Metal Finishing Category, stating that the industry has changed 

significantly since the existing regulations were developed. These changes include updated 

chemical formulas and processes, new pollutants of concern, new treatment technologies, and a 

broader scope for the metal finishing universe. The organization representing states also 

commented that clarification is needed regarding classification of a facility as an existing or new 

source, that there are inconsistencies in categorical determinations across the country for certain 

metal finishing applications (etching vs cleaning, coating vs adsorption, phosphate coating vs 

cleaning), and that EPA should consider adopting a sunset provision for the Electroplating ELGs 

(40 CFR Part 413) to require eventual compliance with the Metal Finishing ELGs (40 CFR Part 

433). 
Section 4—Results of the 2014 Annual Review

4-3 

For nanomaterials, the consultant to local government pretreatment programs and one 

industry representative supported EPA’s effort to characterize nanomaterials in industrial 

wastewater discharges. Specifically, the industry representative urged EPA to recognize the 

diversity of nanomaterials and their applications across multiple industries in its future reports; 

coordinate closely with EPA’s New Chemicals Program to understand nanomaterial releases in 

water; consider work on the fate and transport of nanomaterials completed or currently 

underway; and recognize the potential for nanotechnology to provide new and improved tools for 

wastewater treatment. One wastewater treatment products manufacturer also commented that he 

is currently testing a coagulant/flocculent/filter aid that has shown success at settling nanoparticles, E. coli, phosphorus and other particulates.

The group of seven environmental groups commented that ongoing revisions to 

pretreatment standards for discharges to POTWs need to reflect changes in onshore oil and gas 

exploration, stimulation, and extraction. One environmental organization commented that the oil 

and gas ELG rulemaking for the unconventional oil and gas facilities should be finalized as soon 

as possible, and provided recommendations for resources and information in support of the 

rulemaking. 

The organization representing states supported EPA’s new even-year review 

methodology, used in the 2012 Annual Review, as well as inclusion of the current status of ELGs 

under development in the Final 2012 Plan. This commenter also suggested improvements to the 

ELG review and planning processes, including an increase in EPA staff allocated to work on 

ELGs and pretreatment standards, and publication of Annual Review Reports earlier in the 

planning process, as well as more timely publication of future ELG Plans. 

The consultant to local government pretreatment programs commented that EPA should 

add biodiesel manufacturing to the list of industrial sectors to evaluate.

Lastly, EPA received three unsolicited comments on final decisions announced in the 

Final 2012 Plan. EPA did not solicit public comment on the contents of the Final 2012 Plan since 

public comments were solicited on the actions and decisions when they were proposed in the 

Preliminary 2012 Plan on August 7, 2013. Regardless, one industry commenter indicated support 

for EPA’s decision in the Final 2012 Plan to delist coalbed methane as a new subcategory under 

the Oil and Gas Extraction Category (40 CFR Part 435), and an environmental organization 

indicated they did not support EPA’s decision to delist coalbed methane. The third unsolicited 

comment by an industry organization indicated support for EPA’s final decision in the Final 

2012 Plan not to further review Pulp and Paper industry discharges. 

In general, the public comments submitted on the Preliminary 2014 Plan did not result in 

any new direction or determinations with respect to the proposed actions announced in the 

Preliminary 2014 Plan, or EPA’s final decisions and actions indicated in this Final 2014 Plan. 

EPA did, however, receive useful information and input from the public review that will help 

inform ongoing studies, in particular Petroleum Refining, Metal Finishing, and CWTs. EPA’s 

responses to the specific comments can be found in EPA’s comment response document (DCN 

08110).
Section 4—Results of the 2014 Annual Review

4-4 

4.2 Findings from Continued Review of Select Industrial Categories

For the 2014 Annual Review, EPA continued to evaluate two regulated industrial 

categories and one potential new source of industrial wastewater discharge, all of which EPA 

had identified in the Final 2012 and Preliminary 2014 Plans as warranting further review: Metal 

Finishing (40 CFR Part 433), Pesticide Chemicals (40 CFR Part 455), and brick and structural 

clay products manufacturing (unregulated) (U.S. EPA, 2014a). Below are the findings from these 

2014 continued category reviews.

• Continued Review of the Metal Finishing Category (40 CFR Part 433). EPA’s 

continued review of the Metal Finishing Category in 2014 indicates that the 

industry has not experienced significant growth in the last 30 years. However, 

research suggests that the industry is consolidating into larger companies that tend 

to compete better with the expanding global market; this consolidation may have 

slightly reduced the size of the U.S. metal finishing industry. Further, the industry 

is exploring the use of new chemicals that improve surface finishing quality 

and/or eliminate the use of toxic chemicals. These alternatives may be changing 

the characteristics of metal finishing wastewater. In addition, at least some portion 

of the industry is employing more advanced wastewater treatment technologies, 

including reuse, although a majority of the industry continues to meet the effluent 

limitations guidelines and standards (ELGs) using the more common treatment 

technologies that formed the basis of best available technology economically 

achievable as defined in the ELGs. 

EPA’s continued preliminary review of the Metal Finishing Category identified 

several topics that warrant further review, including the following: 

— Potential new pollutants of concern not currently regulated that are 

increasingly used in metal finishing processes. 

— Prevalence of potential pollutants of concern associated with wastewater 

generated from the use of wet air pollution control devices to control air 

emissions from metal finishing operations. 

— The application of advanced wastewater treatment technologies and the 

prevalence of zero discharge practices in the industry. 

• Targeted Review of Pesticide Active Ingredients (PAIs) without Pesticide 

Chemicals Manufacturing Effluent Limits (40 CFR Part 455). EPA reviewed the 

30 PAIs that are now measured by analytical methods listed in 40 CFR Part 136, 

but discharges of which from manufacturers are not currently regulated under the 

Pesticide Chemicals ELGs. The review identified only seven that are currently 

registered or under registration review in accordance with Section 3 of the Federal 

Insecticide, Fungicide, and Rodenticide Act. The remaining 23 PAIs of interest 

have either never been registered or have had their registrations canceled. 

However, registration status may not be an indicator of whether the PAI is 

manufactured in the U.S. (and potentially present in industrial wastewater 

discharge), because unregistered pesticides may still be manufactured in the U.S. 
Section 4—Results of the 2014 Annual Review

4-5 

for export. Though EPA was not able to prioritize a subset of the PAIs for further 

review at this time, EPA did identify follow-up questions and sources of 

information that will indicate which of the 30 PAIs of interest are produced in the 

U.S. and are thus potentially present in wastewater discharges. These sources of 

information include the Pesticide Registration Information System (PRISM), 

Section Seven Tracking System (SSTS) production data, permit applications, fact 

sheets, and facility permits for producers of the PAIs in the U.S. 

• Continued Review of Brick and Structural Clay Products Manufacturing. As part 

of EPA’s 2012 Annual Review, EPA identified brick and structural clay products 

manufacturing as an industry not currently regulated by ELGs that may generate 

industrial wastewater discharges due to federal air pollution control requirements. 

During its 2014 Annual Review, EPA determined that wet scrubbers are not a 

common air pollution control method within the industry. Additionally, EPA 

determined that only two of the 345 brick manufacturing facilities, two of the 24 

clay ceramics facilities, and three of 127 ceramic tile facilities in the U.S. 

currently have wet scrubbers installed. The findings suggest that the use of wet 

scrubbers to control air pollution is limited in this industry and not expected to 

increase. 

4.3 Findings from New Data Sources and Additional Supporting Analyses

EPA initiated a review of a group of emerging pollutants of concern and continued its 

review of industrial wastewater treatment technology performance data as part of the 2014 

Annual Review (U.S. EPA, 2015). Below are the findings from these reviews. 

• Review of Engineered Nanomaterials (ENMs) in Industrial Wastewater. EPA 

reviewed current literature and scientific research and communicated with 

researchers and government stakeholders regarding ENMs. As a result, EPA

determined the following: 

— Some manufacturing and processing methods likely generate wastewater, 

but the quantity generated and waste management practices are not 

documented. 

— Toxicity hazards from ENMs have been demonstrated in the laboratory, 

but the environmental and human health risks are largely unknown. 

— Fate of and exposure to industrial wastewater releases of ENMs to the 

environment have not been studied. 

— The small size, unique properties, and complexity of ENMs present a 

challenge for environmental monitoring, risk assessment, and regulation. 

— Methods for detecting and characterizing nanomaterials in complex media, 

like industrial wastewater, are under development.
Section 4—Results of the 2014 Annual Review

4-6 

— EPA has not approved any standardized methods for sampling, detecting, 

or quantifying of nanomaterials in aqueous media. 

— Research has shown that common treatment technologies employed at 

municipal wastewater treatment plants can remove nanomaterials from the 

wastewater, but that these may then accumulate in the sludge. 

EPA’s review also identified four main areas of further research appropriate to 

better assess the potential presence and impact of ENMs in industrial wastewater:

— Development of standard methods and sampling techniques to detect and 

characterize nanomaterials in industrial wastewater.

— Evaluation of ENM toxicity impacts and potential occurrence in industrial 

wastewater, taking into consideration relevant forms and concentrations of 

ENMs.

— Identification of the universe of ENM facilities, their production values, 

and the waste generated and disposed of during the manufacturing and 

processing of ENMs.

— Evaluation and characterization of the fate, transformation, and treatment 

of ENMs in industrial wastewaters. 

The National Nanotechnology Initiative (NNI), a collaborative, interagency U.S. 

government research and development initiative, provides a framework for 

individual and cooperative nanotechnology-related activities for 20 federal 

department and agency units, including EPA. Ongoing research coordinated by 

NNI agencies and academic research centers (e.g., research by several offices 

within EPA, the National Science Foundation, the National Institute of Standards 

and Technology, the National Institute of Occupational Safety and Health, the 

Occupational Safety and Health Administration, and others) may serve to address 

these research needs and facilitate understanding of the potential for wastewater 

discharges from the manufacture and processing of ENMs, as well as potential 

human health and environmental impacts. 

• Review of Industrial Wastewater Treatment Technologies. From EPA’s continued 

review of technical papers and research articles that document the performance of 

new and improved industrial wastewater treatment technologies, EPA has

identified and captured treatment information from 163 articles in the Industrial 

Wastewater Treatment Technology (IWTT) Database as of September 2014. Of 

the 163 articles, 98 provide both treatment system information and performance 

data (i.e., pollutant removal efficiencies). The 98 articles with performance data 

represent 35 industrial categories; however, most of the literature reviews 

conducted to date have focused on the petroleum refining and metal finishing 

industries. IWTT documents the removal efficiencies of 142 parameters, 

including many metals, chemical oxygen demand, total suspended solids, and 

total dissolved solids. Though performance data are captured for pilot- and full-
Section 4—Results of the 2014 Annual Review

4-7 

scale treatment systems as a whole, 53 individual treatment technologies (which 

constitute the various treatment systems) are currently included in IWTT, with 

chemical precipitation, membrane bioreactors, and clarification described in the 

greatest number of articles.
Section 5—Final 2014 Plan Decisions and Actions

5-1 

5. FINAL 2014 PLAN DECISIONS AND ACTIONS

As proposed in the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans 

(Final 2012 and Preliminary 2014 Plans), EPA initiated studies of the Centralized Waste 

Treatment (CWT) Category (40 CFR Part 437) and Petroleum Refining Category (40 CFR Part 

419) (U.S. EPA, 2014a). As part of the 2014 Annual Review, EPA also continued several other 

activities, including its preliminary review of the Metal Finishing Category (40 CFR Part 433); 

collection of data for the Industrial Wastewater Treatment Technology (IWTT) Database; review 

of the brick and structural clay manufacturing industry (for which air regulations may result in an 

unregulated wastewater discharge); and 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 effluent limitations guidelines and standards (ELGs) (40 CFR Part 

455). In addition, EPA began investigating the environmental toxicity and industrial wastewater 

discharge of engineered nanomaterials (ENMs). This section presents EPA’s decisions on actions 

proposed in the Final 2012 and Preliminary 2014 Plans. 

As part of the Final 2012 and Preliminary 2104 Plans, EPA also proposed to continue 

reviewing specific Chemical Action Plan chemicals and industrial categories identified in the 

Toxics Release Inventory (TRI) Sectors Expansion rule; however, EPA did not focus on these 

actions during the 2014 Annual Review. EPA plans to focus on these actions during future 

annual reviews as additional data and information become available.

Based on the 2012, 2013, and 2014 Annual Reviews and public comments, EPA has 

concluded that no new industrial wastewater discharges present concerns that warrant new or 

revised effluent guidelines at this time. Therefore, EPA is not identifying any existing effluent 

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

from those currently undergoing rulemakings. EPA is also not identifying the development of 

any new or revised pretreatment standards at this time, excluding those that are currently under 

development. 

5.1 Industries Previously Identified for Further Review for Which EPA is Taking 

No Action

In the Final 2012 and Preliminary 2014 Plan, EPA announced its continued review of 

industries for which air regulations may result in unregulated wastewater discharge (U.S. EPA, 

2014a). As part of that review, EPA further evaluated brick and structural clay products 

manufacturing. The findings suggest that the use of wet scrubbers to control air pollution is 

limited in this industry; therefore, EPA determined that brick and structural clay products 

manufacturing is not now generating a potential new source of industrial wastewater discharge 

that warrants regulation. Based on these findings from the 2014 Annual Review, EPA has 

concluded that no further review of discharges from brick and structural clay products 

manufacturing is warranted and is taking no further action related to this category at this time

(U.S. EPA, 2015). 
Section 5—Final 2014 Plan Decisions and Actions

5-2 

5.2 Industries for Which EPA is Currently Undertaking an ELG Rulemaking

EPA is currently undertaking a rulemaking that would revise ELGs for the Steam Electric

Power Generating Point Source Category (40 CFR 423). Because the Steam Electric rulemaking 

is underway, EPA excluded these facilities’ discharges from analyses conducted for the 2014 

Annual Review. 

EPA is also 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. Currently, EPA is reviewing public comments received on the 

NODA, and an effluent guideline revision for this subcategory is expected to be final sometime 

in late 2015. For further information see: 

http://water.epa.gov/scitech/wastetech/guide/seafood/alaskan.cfm. 

EPA is currently engaged in a rulemaking to develop potential 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 also indicated in its Final 2010 ELG Plan (76 FR 66286) that it was initiating two 

separate rulemakings to potentially revise ELGs for the Oil and Gas Extraction Point Source 

Category (40 CFR Part 435) to address discharges from coalbed methane and shale gas 

extraction. EPA announced that it was delisting the coalbed methane extraction industry from the 

effluent guidelines plan in the Final 2012 Plan (U.S. EPA, 2014a). EPA recently proposed a 

rulemaking on April 7, 2015 (80 FR 18557), which will revise the ELGs for the Oil and Gas 

Extraction Point Source Category, adding a subcategory for pretreatment standards for 

unconventional oil and gas extraction to address wastewaters, including, but not limited to, shale 

gas, shale oil, tight gas, and tight oil extraction. This proposed rule would 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. 

5.2.1 EPA’s Current Schedule for ELG Actions

Steam Electric Power Generation:

 - Proposed Rule June 7, 2013 

 - Final Action September 30, 2015 
Section 5—Final 2014 Plan Decisions and Actions

5-3 

Pretreatment Standards for the Dental Category:

 - Proposed Rule October 22, 2014 

 - Final Rule June 2016 

Pretreatment Standards for Unconventional Oil and Gas Extraction: 

 - Proposed Rule April 7, 2015 

Canned and Preserved Seafood Category covering the Alaskan Seafood 

Processing Subcategories:

- Notice of Data Availability November 7, 2013 

 - Final Rule Early 2016 

5.3 Industries for Which EPA Is Currently Conducting Further Study

Based on the findings from EPA’s 2014 Annual Review and status of ongoing studies, 

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

to determine if new or revised effluent guidelines are warranted, as discussed in the subsections 

below. 

5.3.1 Continued Detailed Study of the Petroleum Refining Category (40 CFR Part 419) 

In the Final 2012 and Preliminary 2014 Plan, EPA announced it was planning to initiate a 

detailed study of petroleum refineries (40 CFR Part 419) (U.S. EPA, 2014a). EPA has initiated 

that study to determine if changes to the existing ELGs or pretreatment standards are appropriate 

for this industry. In reviewing DMRs from petroleum refineries, EPA has observed an increase in 

discharges of metal pollutants that are not regulated by the existing regulations and identified 

some dioxin compound discharges. In particular, the detailed study will investigate the effects of 

heavier crudes and new wet air pollution controls on wastewater discharges. The detailed study 

will also investigate pollution prevention or wastewater-treatment methods available to reduce 

pollutants present in petroleum refining wastewater.

The following information will initially be collected for the industry:

• Updated profile information obtained 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; 

• National Pollutant Discharge Elimination System (NPDES) Permit information; 

• Information from site visits to petroleum refineries; and

• Information from industry, other EPA programs, EPA regions, states, and 

literature sources. 
Section 5—Final 2014 Plan Decisions and Actions

5-4 

After analyzing the information collected from the sources listed above, EPA will 

determine whether an information collection request to the industry and wastewater sampling are 

appropriate. 

5.3.2 Continued Detailed Study of CWT Category (40 CFR Part 437) 

In the Final 2012 and Preliminary 2014 Plan, EPA announced it was planning to initiate a 

detailed study of the CWT industry (40 CFR Part 437) for facilities accepting oil and gas 

extraction wastewaters (U.S. EPA, 2014a). EPA has initiated that study to determine if revisions 

to the ELGs are warranted. The current regulations do not include limitations for pollutants 

commonly found in these wastewaters, such as total dissolved solids, barium, bromide, radium, 

and strontium. The study is intended to be comprehensive and will cover all oil and gas 

wastewater, including both conventional and unconventional oil and gas extraction. As part of 

this study, EPA plans to evaluate the following: 

• The extent of facilities accepting oil and gas extraction wastewaters; 

• The technologies used to treat these wastewaters, their performance, and costs; 

• Financial characteristics of the industry; 

• Environmental impacts of these wastewater discharges to waters in the U.S.; and

• Current practices for management of treatment residuals. 

To date, EPA has been conducting site visits at CWT facilities across the country and 

collecting existing information and data to characterize the industry. In the coming year, EPA 

plans to continue conducting site visits and sampling wastewater and treatment residuals at 

facilities to evaluate the pollutants present, their concentrations, and the performance of 

treatment technologies.

5.3.3 Continued Evaluation of Cook Inlet, Alaska Oil and Gas Requirements

EPA received comments during public review of the Preliminary 2012 ELG Plan 

questioning the appropriateness of the limits established for Cook Inlet, Alaska in the Coastal

Subcategory of the Oil and Gas Extraction Point Source Category (40 CFR Part 435, Subpart 

D). In 1996, EPA decided not to require zero discharge of drill cuttings, produced water, and 

other drilling wastes for oil and gas extraction operators in Cook Inlet. EPA determined that 

onsite injection and other zero discharge options did not represent BAT in Cook Inlet. Currently, 

Cook Inlet discharge requirements are the same as those that apply to dischargers in the Offshore 

Subcategory. 

According to commenters, the limits that apply in Cook Inlet allow contamination of the 

Inlet, which poses significant concerns because the inlet is a source of commercial, recreational, 

and subsistence harvesting of fish, shellfish, and other marine species. As a result of the public 

comments, EPA is evaluating the current implementation of the effluent guidelines, including the 

availability and economic achievability of injection wells that could achieve zero discharge for 

produced water, drilling muds and cuttings from all wells and exploration in the Inlet. EPA is 

examining data provided from EPA Region 10, Alaska Department of Environmental 

Conservation, and the Alaska Oil and Gas Conservation Commission to evaluate injection 

capacity and/or other barriers that may exist in Cook Inlet to managing wastewater to achieve 

zero discharge. 
Section 5—Final 2014 Plan Decisions and Actions

5-5 

5.3.4 Actions from the 2014 Annual Review 

EPA plans to continue its evaluation of the following categories and pollutant groups of 

interest based on results from the 2014 Annual Review: 

• Preliminary Study of the Metal Finishing Category (40 CFR Part 433). EPA will

continue its review through a preliminary study of the Metal Finishing Category

to help determine whether revisions to the existing Metal Finishing ELGs are 

warranted. The study will focus on the following: 

— Potential new pollutants of concern not currently regulated that are 

increasingly used in metal finishing processes; 

— Prevalence of potential pollutants of concern associated with wastewater 

generated from the use of wet air pollution controls at metal finishing 

operations; and

— The application of advanced wastewater treatment technologies and the 

prevalence of zero discharge practices in the industry. 

• Targeted Review of PAIs Without Pesticide Chemicals Manufacturing Effluent 

Limits (40 CFR Part 455). EPA plans to continue its targeted review of PAIs for 

which the discharge from manufacturing is not regulated under the Pesticide 

Chemicals ELGs. Specifically, EPA plans to conduct a comprehensive review of 

production data compiled in the Pesticide Registration Information System 

(PRISM), Section Seven Tracking System (SSTS) database, maintained under the 

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). EPA will focus on 

the 23 PAIs of interest that are not currently registered (never registered or with 

canceled registrations). After identifying specific PAIs that are produced in the 

U.S., EPA plans to further review plant process and permit information for the 

facilities that produce the PAIs to identify whether they are present in wastewater 

discharges from pesticide chemicals manufacturing. 

• Continued Review of ENMs in Industrial Wastewater. EPA plans to continue to 

monitor ongoing research on ENMs in future annual reviews and will collect any 

new information as it becomes available, particularly related to the following data 

gaps:

— Development of standard methods and sampling techniques to detect and 

characterize nanomaterials in industrial wastewater;

— Evaluation of ENM toxicity impacts and potential occurrence in industrial 

wastewater, taking into consideration relevant forms and concentrations of 

ENMs;

— Identification of the universe of facilities, their production values, and the 

nature of the waste generated and disposed by manufacturing and 

processing of ENMs; and 
Section 5—Final 2014 Plan Decisions and Actions

5-6 

— Evaluation and characterization of the fate, transformation, and treatment 

of ENMs in industrial wastewaters. 

• Continued Review of Industrial Wastewater Treatment Technologies. EPA plans 

to continue to collect industrial wastewater treatment technology data for IWTT

for use in future annual reviews. EPA expects to use this database to identify 

whether specific industrial categories warrant further review for new or revised 

ELGs, based on the range of available treatment technology performance. 
Section 6—Summary Table of Findings for Existing Guideline Categories from the 2014 Annual Review

6-1 

6. SUMMARY TABLE OF FINDINGS FOR EXISTING GUIDELINE CATEGORIES FROM 

THE 2014 ANNUAL REVIEW

Table 6-1 summarizes the findings from EPA’s 2014 Annual Review 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 in identifying pollution-control and 

pollution-prevention technologies for the development of technology-based 

effluent limitations during the development of individual permits.

3. Not identified as a priority based on data available at this time because EPA did 

not identify during the 2014 Annual Review that revisions to the national effluent 

guidelines or pretreatment standards are warranted.

4. EPA intends to start, or continue to conduct, a preliminary category review of the 

pollutant discharges from this category.

5. EPA intends to start or continue either a preliminary or detailed study of this 

industry to determine whether to identify the category for effluent guidelines 

rulemaking. 

6. EPA is identifying this industry for a potential revision of an existing effluent 

guideline. 

Table 6-1. Summary of Findings from EPA’s 2014 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 (3)

5 Canned and Preserved Fruits and Vegetable Processing 407 (3)

6 Canned and Preserved Seafood Processing 408 (3)

7 Carbon Black Manufacturing 458 (3)

8 Cement Manufacturing 411 (3)

9 Centralized Waste Treatment 437 (5)
Section 6—Summary Table of Findings for Existing Guideline Categories from the 2014 Annual Review

6-2 

Table 6-1. Summary of Findings from EPA’s 2014 Annual Review of Existing 

Industrial Categories

No. Industry Category (Listed Alphabetically) 40 CFR Part Findings

10 Coal Mining 434 (3)

11 Coil Coating 465 (3)

12 Concentrated Animal Feeding Operations (CAFO) 412 (1)

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 (3)

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 (3)

24 Gum and Wood Chemicals 454 (3)

25 Hospitals 460 (1)

26 Ink Formulating 447 (3)

27 Inorganic Chemicalsa 415 (1) and (3)

28 Iron and Steel Manufacturing 420 (3)

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 (3)

36 Nonferrous Metals Forming and Metal Powders 471 (3)

37 Nonferrous Metals Manufacturing 421 (2)

38 Oil and Gas Extractionb 435 (1) and (3)

39 Ore Mining and Dressing 440 (2)

40 Organic Chemicals, Plastics, and Synthetic Fibersa 414 (1), (2), and (3)

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)
Section 6—Summary Table of Findings for Existing Guideline Categories from the 2014 Annual Review

6-3 

Table 6-1. Summary of Findings from EPA’s 2014 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 (3)

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 (2)

56 Timber Products Processing 429 (3)

57 Transportation Equipment Cleaning 442 (3)

58 Waste Combustors 444 (3)

a Codes (1) and (3) are used for this category. The first code, (1), refers to the recent effluent guidelines rulemaking, 

and subsequent delisting for the Chlorinated and Chlorinated Hydrocarbons (CCH) manufacturing sector, which 

includes facilities currently regulated by the Organic Chemicals, Plastics, and Synthetic Fibers and Inorganic

Chemicals effluent guidelines. The second code, (3), indicates that the remainder of the facilities in these two 

categories does not represent a hazard priority at this time.

b Codes (1) and (3) are used for this category. The first code, (1), refers to the ongoing effluent guidelines 

rulemaking for shale gas extraction and EPA’s review of the coalbed methane extraction sector of the industry. The 

second code, (3), refers to category discharges of the oil and gas extraction industry, excluding coalbed methane and 

shale gas extraction, that do not represent a hazard priority at this time. 
Section 7—References For the Final 2014 Plan

7-1 

7. REFERENCES FOR THE FINAL 2014 PLAN

1. ACWA. 2013. Public Comment Submitted by the Association of Clean Water

Administrators on the Preliminary 2012 Effluent Guidelines Program Plan. Re: Docket

ID No. EPA-HQ-OW-2010-0824/Preliminary 2012 Effluent Guidelines Program Plan

and 2011 Annual Effluent Guidelines Review Report. (October 7). EPA-HQ-OW-2010-

0824-0218-A2.

2. Auchterlonie, Steve. 2009. Notes from 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.

3. 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.

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:

www.epa.gov/superfund/resources/remedy/pdf/540g-89006-s.pdf. EPA-540-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://www.epa.gov/superfund/policy/remedy/pdfs/540g-88003-s.pdf. EPA-540-G-88-

003. 

6. U.S. EPA. 2009. Technical Support Document for the Annual Review of Existing

Effluent Guidelines and Identification of Potential New Point Source Categories.

Washington, D.C. (October). EPA-821-R-09-007. EPA-HQ-OW-2008-0517-0515.

7. U.S. EPA. 2010. U.S. EPA NPDES Permit Writers’ Manual. Washington, D.C.

(September). Available online at: http://water.epa.gov/polwaste/npdes/basics/NPDESPermit-Writers-Manual.cfm. EPA-833-K-10-001. EPA-HQ-OW-2010-0824-0236.

8. 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.

9. U.S. EPA. 2012b. Toxic Weighting Factors Methodology. Washington, D.C. (March).

EPA-HQ-OW-820-R-12-005. EPA-HQ-OW-2010-0824-0004.

10. U.S. EPA. 2014a. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.

Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170-

0002. 

11. U.S. EPA. 2014b. Response to Comments for the Preliminary 2012 Effluent Guidelines 

Program Plan. Washington D.C. (September). EPA-HQ-OW-2010-0824-0318. 
Section 7—References For the Final 2014 Plan

7-2 

12. U.S. EPA. 2014c. The 2012 Annual Effluent Guidelines Review Report. Washington 

D.C.(September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824-0320.

13. U.S. EPA. 2014d. The 2013 Annual Effluent Guidelines Review Report. Washington,

D.C. (September). EPA-821-R-14-003. EPA-HQ-OW-2014-0170-0077.

14. U.S. EPA. 2015. The 2014 Annual Effluent Guidelines Review Report. Washington, D.C.

(July). EPA-821-R-15-001. EPA-HQ-OW-2014-0170. DCN 08106.