Technical Support Document for the 2010 

Effluent Guidelines Program Plan 

October 2011 

EPA 820-R-10-021
 

i

CONTENTS 

Page 

PART I: INTRODUCTION ..................................................................................................................... I

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

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

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

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

1.3.1 Best Practicable Control Technology Currently Available (BPT) 

— CWA Sections 301(b)(1)(A) and 304(b)(1) ........................................ 1-3

1.3.2 Best Conventional Pollutant Control Technology (BCT) — CWA 

Sections 301(b)(2)(E) and 304(b)(4) ....................................................... 1-4

1.3.3 Best Available Technology Economically Achievable (BAT) — 

CWA Sections 301(b)(2)(A) and 304(b)(2) ............................................. 1-4

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

1.3.5 Pretreatment Standards for Existing Sources (PSES) — CWA 

Section 307(b) .......................................................................................... 1-4

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

307(c) ....................................................................................................... 1-5

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

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

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

2. PUBLIC COMMENTS ON THE FINAL EFFLUENT GUIDELINES PROGRAM PLAN FOR 

2008 AND PRELIMINARY 2010 EFFLUENT GUIDELINES PROGRAM PLAN .......................... 2-1

3. THE EFFLUENT GUIDELINES PLANNING PROCESS ............................................................. 3-1

3.1 Goals of the Effluent Guidelines Planning Process ............................................. 3-1

3.2 Annual Review of Existing Effluent Guidelines and Pretreatment 

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

3.2.1 Factors Considered in Review of Existing Effluent Guidelines and 

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

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

3.3 Identification of New Categories for Possible Effluent Guidelines 

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

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

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

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

3.5 The Effluent Guidelines Planning Process References ........................................ 3-9

4. METHODOLOGY, DATA SOURCES, AND LIMITATIONS ....................................................... 4-1

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

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

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

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

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

4.1.5 Data from PCS and ICIS-NPDES ............................................................ 4-7
CONTENTS (Continued) 

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ii

4.2 Methodology Correction Affecting Both Screening-Level Review 

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

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

4.2.2 Summary of TRIReleases2008 Database Methodology Changes ......... 4-13

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

4.3.1 DMRLoads2008: Categorization of Discharges .................................... 4-15

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

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

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

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

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

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

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

4.4.1 TRIReleases2008: Categorization of Discharges .................................. 4-35

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

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

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

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

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

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

PART II: RESULTS OF THE 2010 ANNUAL REVIEW OF INDUSTRIAL

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

5. 2010 ANNUAL REVIEW OF EXISTING EFFLUENT LIMITATIONS GUIDELINES AND 

STANDARDS AND RANKING OF POINT SOURCE CATEGORIES ............................................ 5-1

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

5.2 Results of the 2010 Screening-Level Review ...................................................... 5-2

5.2.1 Categories for Which EPA is Currently Developing or Revising 

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

5.2.2 Categories for Which EPA Recently Promulgated or Revised 

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

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

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

5.2.5 Results of the 2010 Screening-Level Review .......................................... 5-4

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

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

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

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

6. FERTILIZER MANUFACTURING (40 CFR PART 418) .......................................................... 6-1

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

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

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

6.2 Fertilizer Manufacturing Category 2010 Screening-Level Review ..................... 6-4

6.3 Fertilizer Manufacturing Category Pollutants of Concern ................................... 6-5
CONTENTS (Continued) 

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6.4 Fertilizer Manufacturing Category Fluoride Discharges in DMR ....................... 6-8

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

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

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

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

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

7. INORGANIC CHEMICALS MANUFACTURING (40 CFR PART 415) ....................................... 7-1

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

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

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

7.2 Inorganic Chemicals Category Screening-Level Review .................................... 7-5

7.3 Inorganic Chemicals Category Pollutants of Concern ......................................... 7-6

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

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

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

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

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

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

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

8. LANDFILLS (40 CFR PART 445) ........................................................................................ 8-1

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

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

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

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

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

8.4 Landfills Category Facility-Specific DMR Review ............................................ 8-6

8.5 Landfills Category Iron Discharges in DMR ....................................................... 8-9

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

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

9. MINERAL MINING AND PROCESSING (40 CFR PART 436) ................................................. 9-1

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

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

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

9.2 Mineral Mining Category 2010 Screening-Level Review ................................... 9-8

9.3 Mineral Mining Category Pollutants of Concern ................................................. 9-9

9.4 Mineral Mining Category Sulfide Discharges in DMR ..................................... 9-12

9.5 Mineral Mining Category Fluoride Discharges in DMR ................................... 9-14

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

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

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

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

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

9.8 Mineral Mining Category References ................................................................ 9-23
CONTENTS (Continued) 

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iv

10. OIL & GAS EXTRACTION (40 CFR PART 435)................................................................. 10-1

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

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

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

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

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

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

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

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

11. ORE MINING AND DRESSING (40 CFR PART 440) ........................................................... 11-1

11.1 Ore Mining and Dressing Category References ................................................ 11-2

12. ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC FIBERS (40 CFR PART 414) ............. 12-1

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

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

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

12.2 OCPSF Category 2010 Screening-Level Review .............................................. 12-8

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

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

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

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

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

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

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

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

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

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

13. PLASTICS MOLDING AND FORMING (40 CFR PART 463)................................................. 13-1

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

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

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

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

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

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

13.4 PMF Category Chlorine Discharges in DMR .................................................. 13-10

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

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

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

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

13.5.4 Regenerated Cellulose Wastewater Treatment .................................... 13-17

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

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

13.8 PMF Category References ............................................................................... 13-19
CONTENTS (Continued) 

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14. TEXTILE MILLS (40 CFR PART 410) ............................................................................... 14-1

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

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

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

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

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

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

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

14.4.2 Kannapolis Water Treatment Plant in Kannapolis, NC ....................... 14-11

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

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

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

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

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

15. WASTE COMBUSTORS (40 CFR PART 444) ..................................................................... 15-1

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

15.1.1 Waste Combustors Industry Profile ....................................................... 15-1

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

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

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

15.4 Waste Combustors Hexachlorophene Discharges in DMR ............................... 15-7

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

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

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

16. HEALTH CARE INDUSTRY AND HOSPITALS CATEGORY (40 CFR PART 460) ................... 16-1

16.1 Health Care Industry and Hospitals Category References ................................. 16-2

17. OIL AND GAS EXTRACTION (40 CFR PART 435) ............................................................. 17-1

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

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

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

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

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

17.4 Oil and Gas Extraction References .................................................................... 17-3
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LIST OF TABLES 

Page 

2-1 Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program 

Plans EPA Docket Number: EPA-HQ-OW-2008-0517 .................................................. 2-2

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

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

4-3 Dioxin and Dioxin-Like Compounds Distribution Selection Hierarchy for 

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

4-4 Number of Facilities Assigned Each Dioxin Distribution Hierarchy in TRI 2008 ........ 4-15

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

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

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

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

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

5-3 Final TRIReleases2008 and DMRLoads2008 Combined Point Source Category 

Rankings .......................................................................................................................... 5-7

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

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

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

6-1 Number of Fertilizer Manufacturing Facilities ................................................................ 6-2

6-2 Number of Fertilizer Manufacturing Facilities by Discharge Classification in 2008 

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

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

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

6-4 Subcategories in the Fertilizer Manufacturing Category ................................................. 6-4

6-5 Fertilizer Manufacturing Category TRI and DMR Discharges for the 2006 

through 2010 Screening-Level Reviews .......................................................................... 6-4

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

6-7 Fertilizer Manufacturing Category Top TRI Pollutants ................................................... 6-6
LIST OF TABLES (Continued) 

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vii

6-8 Fertilizer Manufacturing Category Top DMR Pollutants ................................................ 6-7

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

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

6-11 Mosaic Fertilizers 2008 Monthly Fluoride Discharge Data and 40 CFR Part 418 

Monthly Average Limitations ........................................................................................ 6-12

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

6-13 IMC Phosphates Outfall 002 2008 Monthly Fluoride Discharge Data and 40 CFR 

Part 418 Monthly Average Limitations ......................................................................... 6-13

7-1 Number of Inorganic Chemicals Manufacturing Facilities ............................................. 7-3

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

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

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

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

7-4 Inorganic Chemicals Category TRI and DMR Discharges for the 2006 through 

2010 Screening-Level Reviews ....................................................................................... 7-5

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

7-6 Inorganic Chemicals Category Top TRI Pollutants ......................................................... 7-7

7-7 Inorganic Chemicals Category Top DMR Pollutants ...................................................... 7-8

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

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

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

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

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

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

7-13 Elementis Chromium LP Plant 2008 Top Discharges ................................................... 7-12

7-14 Elementis Chromium LP Outfall 001 2008 Monthly Mercury and Silver 

Discharge Data ............................................................................................................... 7-12

7-15 Dow Chemical Pittsburg Plant 2008 Top Discharges .................................................... 7-13
LIST OF TABLES (Continued) 

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

7-17 Dow Chemical Pittsburg Plant’s 2008 Copper Discharges ........................................... 7-14

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

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

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

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

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

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

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

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

8-8 Landfills Category Top TRI Pollutants in 2008 ............................................................. 8-6

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

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

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

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

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

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

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

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

9-3 Number of Mineral Mining Facilities by Type of Discharger in TRI 2008 .................... 9-6

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

9-5 Mineral Mining Category TRI and DMR Discharges for the 2010 and Previous 

Screening-Level Reviews ................................................................................................ 9-9

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

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

9-8 Mineral Mining Category Top DMR Pollutants ............................................................ 9-11
LIST OF TABLES (Continued) 

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9-9 Mineral Mining Category Top Sulfide Discharging Facility in DMR 2008 ................. 9-12

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

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

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

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

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

Springs ........................................................................................................................... 9-16

9-15 Outfall 001 Monthly Fluoride Concentrations and Limits for PCS Phosphates 

White Springs (Jasper) ................................................................................................... 9-18

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

Corporation .................................................................................................................... 9-19

9-17 Outfall 001 Monthly Fluoride Discharge Data and Limits for Feldspar 

Corporation .................................................................................................................... 9-20

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

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

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

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

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

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

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

2007, and 2008 .............................................................................................................. 10-3

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

10-5 Oil and Gas Category TRI and DMR Discharges for the 2006 through 2010 

Screening-Level Reviews .............................................................................................. 10-4

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

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

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

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

10-9 Marathon Oil Maverick Springs 2008 Sulfide Discharge Data ..................................... 10-7
LIST OF TABLES (Continued) 

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

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

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

12-4 Applicability of Subcategories in the OCPSF Category ................................................ 12-7

12-5 OCPSF Category TRI and DMR Discharges for the 2006 through 2010 

Screening-Level Reviews .............................................................................................. 12-8

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

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

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

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

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

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

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

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

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

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

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

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

12-18 Channelview Complex 2008 Monthly Chlorine and Flow Discharge Data and 

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

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

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

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

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

13-5 PMF Category 2008 DMR TWPE by Discharge Classification .................................... 13-7
LIST OF TABLES (Continued) 

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

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

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

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

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

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

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

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

13-14 PMF Category Diethylhexyl Phthalate Discharging Facilities in 2008 DMR 

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

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

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

14-2 Number of Textiles Facilities by Discharge Classification in 2008 DMR Database .... 14-4

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

14-4 Applicability of Subcategories in the Textiles Category ............................................... 14-6

14-5 Textiles Category TRI and DMR Discharges for the 2006 through 2010 

Screening-Level Reviews .............................................................................................. 14-7

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

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

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

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

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

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

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

14-13 Kannapolis WTP 2008 Monthly Aluminum Discharge Data ...................................... 14-12
LIST OF TABLES (Continued) 

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14-14 Mohawk Industries Oak River Plant 2008 Top Discharges in the DMR Database ..... 14-13

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

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

Discharge Data ............................................................................................................. 14-14

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

14-18 Mohawk Industries 2008 Monthly Sulfide Discharge Data ........................................ 14-15

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

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

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

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

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

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

15-5 Waste Combustors Category TRI and DMR Discharges for the 2006 through 

2010 Screening-Level Reviews ..................................................................................... 15-4

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

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

15-8 Waste Combustors Category Top DMR Pollutants ....................................................... 15-6

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

LIST OF FIGURES 

Page 

1-1 Regulations of Direct and Indirect Wastewater Discharges ............................................ 1-3

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

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

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

PART I: INTRODUCTION 
Section 1 – Background 

1-1 

This document supports the Final 2010 Effluent Guidelines Program Plan. It presents the 

methodology used to perform the annual reviews of industrial discharges required by the Clean 

Water Act and the results of the reviews. 

1. 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 describes EPA’s process for making effluent guidelines revision and development decisions 

(i.e., effluent guidelines planning). 

1.1 EPA’s Clean Water Act Program

EPA’s Office of Water is responsible for developing the programs and tools authorized 

under the Clean Water Act (CWA), which enables EPA and the states to protect and restore the 

Nation’s waters. These programs and tools generally rely either on water quality-based controls, 

such as water quality standards and water quality-based effluent limitations, or technology-based 

controls, such as effluent guidelines and technology-based effluent limitations. 

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

water quality standards. These standards consist of designated uses for each water body (e.g., 

fishing, swimming, supporting aquatic life), numeric pollutant concentration limits (“criteria”) to 

protect those uses, and an antidegradation policy. EPA develops national criteria for many 

pollutants, which states may adopt or modify as appropriate to reflect local conditions. In a 

parallel track to water quality standards, EPA also develops technology-based effluent limitation 

guidelines and standards (ELGs), based on current available technologies. These guidelines and 

standards are then incorporated into discharge permits as technology-based effluent limitations 

(U.S. EPA, 1996). While technology-based effluent limitations in discharge permits may be as 

stringent as or more stringent than water-quality-based effluent limits, the effluent guidelines 

program is not specifically designed to ensure that the discharge from each facility meets the 

water quality standards of its receiving water body. For this reason, the CWA also requires states 

to establish water-quality-based permit limitations, where necessary to attain and maintain water 

quality standards. These water-quality-based limits may require industrial facilities to meet 

requirements that are more stringent than those in a national effluent guideline regulation. EPA 

notes that the various components of water-quality-based permitting (water quality standards, 

water-quality-based effluent limits, and total maximum daily loads) are in different stages of 

development nationally and by state, which may result in different levels of protection across 

states. Therefore, national categorical effluent limitations and standards remain a critical 

component of EPA’s CWA Program. Consequently, in the overall context of the CWA, effluent 

guidelines must be viewed as one tool in the broad arsenal of tools Congress provided to EPA 

and the states to protect and restore the Nation’s water quality. 

1.2 Background on the Effluent Guidelines Program 

The 1972 CWA marked a distinct change in Congress’s efforts “to restore and maintain 

the chemical, physical, and biological integrity of the Nation’s waters.” See CWA § 101(a), 33 

U.S.C. § 1251(a). Prior to 1972, the CWA relied on “water quality standards.” This approach 

was challenging, however, because it was very difficult to prove that a specific discharger was 

responsible for decreasing the water quality of its receiving stream. 
Section 1 – Background 

1-2 

The 1972 CWA directed EPA to promulgate effluent guidelines that reflect pollutant 

reductions that can be achieved by categories or subcategories of industrial point sources. The 

effluent guidelines 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, effluent guidelines 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, EPA assesses: (1) the 

performance and availability of the best pollution control technologies or pollution prevention 

practices for an industrial category or subcategory as a whole; (2) the economic achievability of 

those technologies, which can include consideration of costs, effluent reduction benefits, and 

affordability of achieving the reduction in pollutant discharge; (3) non-water-quality 

environmental impacts (including energy requirements); and (4) such other factors as the EPA 

Administrator deems appropriate. 

Creating a single national pollution control requirement for each industrial category 

based on the best technology the industry could afford was seen by Congress as a way to reduce 

the potential creation of “pollution havens” and to set the Nation’s sights on attaining the highest 

possible level of water quality. Consequently, EPA’s goal in establishing national effluent 

guidelines 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 representing the performance of the best pollution control technologies or pollution 

prevention practices. 

Unlike other CWA tools, effluent guidelines 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. Effluent guidelines also control pollutant discharges at the point of discharge from 

industrial facilities and cover discharges directly to surface water (direct discharges) and 

discharges to publicly owned treatment works (POTWs) (indirect discharges). For industrial 

dischargers to POTWs, this can have the added benefit of preventing the untreated discharge of 

pollutants to groundwater from leaking sewer pipes or to surface waters due to combined sewer 

overflows. 

1.3 What Are Effluent Limitation Guidelines and Pretreatment Standards?

The national clean water industrial regulatory program is authorized under sections 301, 

304, 306, and 307 of the CWA. 

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

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

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

3. Best conventional control technology (BCT); 

4. New source performance standards (NSPS); 

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

6. Pretreatment standards for new sources (PSNS). 

For point sources that discharge pollutants directly into the waters of the United States (direct 

dischargers), the limitations and standards promulgated by EPA are implemented through 
Section 1 – Background 

National Pollutant Discharge Elimination System (NPDES) permits. See CWA sections 301(a), 

301(b), and 402. 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) and (c). Figure 1-1 illustrates the relationship 

between the regulation of direct and indirect dischargers. 

Figure 1-1. Regulations of Direct and Indirect Wastewater Discharges 

1.3.1 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. 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 (July 30, 1979). 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. The Agency 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 based on the average of the best performances of facilities within the 

industry of various ages, sizes, processes, or other common characteristics. Where existing 

1-3 
Section 1 – Background 

1-4 

performance is uniformly inadequate, BPT may reflect higher levels of control than currently in 

place in an industrial category if the Agency determines that the technology can be applied 

practically. 

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

and 304(b)(4) 

The 1977 amendments to the CWA required EPA to identify effluent reduction levels for 

conventional pollutants associated with BCT 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 consideration of 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). 

1.3.3 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)(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. 

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

NSPS reflect effluent reductions that are achievable 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 is directed to take into consideration the cost of 

achieving the effluent reduction and any non-water-quality environmental impacts and energy 

requirements. 

1.3.5 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. 
Section 1 – Background 

1-5 

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

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

1.3.6 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. New indirect dischargers 

have the opportunity to incorporate into their plants the best available demonstrated 

technologies. The Agency considers the same factors in promulgating PSNS as it considers in 

promulgating NSPS. 

1.4 Success of EPA’s Effluent Guidelines Program

The Effluent Guidelines Program has helped reverse the water quality degradation that 

accompanied industrialization in this country. Permits developed using the technology-based 

industrial regulations 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 issued effluent guidelines for 57 industrial categories and 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. These regulations have prevented the 

discharge of more than 700 billion pounds of toxic pollutants each year. 

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

In addition to establishing new regulations, the CWA also 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, as 

required by CWA sections 304(b), 301(d), 304(g), and 307(b). This document explains how EPA 

uses reported discharge data and other factors to conduct this review. EPA also reviews 

industries consisting of direct discharging facilities not currently subject to effluent guidelines to 

identify potential candidates for effluent guidelines rulemakings, as required by 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, as required by CWA sections 304(g) and 

307(b). 

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 guidelines that EPA has promulgated under that 

section. EPA’s Final 2010 Plan presents the results of the section 304(b) reviews. The schedule 

is as follows: EPA will coordinate its annual review of existing effluent guidelines under section 

304(b) with its publication of the preliminary and final Plans under CWA section 304(m). In 

other words, in odd numbered years, EPA intends to complete its annual review upon publication 
Section 1 – Background 

1-6 

of the preliminary Plan that EPA must publish for public review and comment under CWA 

section 304(m)(2). In even numbered years, EPA intends to complete its annual review upon the 

publication of the final Plan. EPA’s 2010 annual review is the review cycle ending upon the 

publication of this Final 2010 Plan. 

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

under section 304(m) for several reasons. First, the annual review is inextricably linked to the 

planning effort, because the results of each annual review can inform the content of the 

preliminary and final Plans (e.g., by identifying candidates for ELG revision for which EPA can 

schedule rulemaking in the Plan, or by identifying point source categories for which EPA has not 

promulgated effluent guidelines). Second, even though not required to do so under either section 

304(b) or section 304(m), EPA believes that the public interest is served by periodically 

presenting to the public a description of each annual review (including the review process used) 

and the results of the review. Doing so at the same time EPA publishes preliminary and final 

Plans makes both processes more transparent. Third, by requiring EPA to review all existing 

effluent guidelines each year, Congress appears to have intended that each successive review 

would build upon the results of earlier reviews. Therefore, by describing the 2010 annual review 

along with the Final 2010 Plan, EPA hopes to gather and receive data and information that will 

inform its reviews for 2011 and the Preliminary 2012 Plan. 

1.6 Background References

1. U.S. EPA. 1996. U.S. EPA NPDES Permit Writers’ Manual. Washington, DC. 

(December). EPA-833-B-96-003. Available online at: http://cfpub.epa.gov/npdes/

writermanual.cfm?program_id=45. 
Section 2 – Public Comments 

2-1 

2. PUBLIC COMMENTS ON THE FINAL EFFLUENT GUIDELINES PROGRAM PLAN FOR 2008

AND PRELIMINARY 2010 EFFLUENT GUIDELINES PROGRAM PLAN

EPA published its Preliminary 2010 Effluent Guidelines Program Plan (Preliminary 2010 

Plan) on December 28, 2009 (74 FRN 68599) and requested comments on various aspects of its 

analyses, data, and information to inform its 2010 annual review and two detailed studies. The 

Agency received five comments on the Final 2008 Plan and 51 comments on the Preliminary 

2010 Plan. Table 2-1 lists the commenters as well as a synopsis of the comments.
Sect

2-2 

Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program 

EPA Docket Number: EPA-HQ-OW-2008-0517 

No. Commenter Name 

EPA 

Docket No. Comment Summary 

1 Deborah Goldberg (Earthjustice) 0045 General comments in favor of creating ELGs for a subcategory to Oil and 

Part 435) for wastewater from oil and gas drilling, hydraulic fracturing to rextraction for all oil and gas exploration, rather than focusing on coalbed mextraction. Recommends zero discharge of all related wastewater. 

2 Lisa Widawsky (Environmental 

Integrity Project) 

0046 General comments in favor of creating ELGs for toxic metals from coal co

Electric Power Generating plants (40 CFR Part 423). Recommends zero diand ash transport systems as BAT because it has been achieved by sources 

3 Nancy Stewart and Margie Parsley 

(League of Women Voters of Tennessee) 

0047 General comments in favor of revising Steam Electric Power Generating E

and containment guidelines for coal-ash impoundments. Recommend inclu

monitoring for structural integrity, capping to prevent overflows, compositseepage, monitoring for heavy metals and other pollutants in nearby surfacof wet ash storage systems. 

4 Abigail Dillen (Earthjustice) 0048 General comments in favor of revising the Steam Electric Power Generatin

423). Recommends eliminating all pollutant discharges from scrubber and all discharge of leachate from land-based coal combustion waste disposal. 

5 Doug Morris (American Petroleum 

Institute) 

0049 General comments to provide helpful regulatory and scientific background 

comments submitted by Earthjustice (EPA-HQ-OW-2008-0517-0045) regaa subcategory of Oil and Gas Extraction (40 CFR Part 435) for wastewater hydraulic fracturing to retrieve shale gas, and extraction for all oil and gas focusing on coalbed methane (CBM) extraction. 

6 Russel F. Mankes 

(Albany Medical Center) 

0523 Recommends considering the results of a two-year study funded by U.S. E

pharmaceutical waste disposal for consideration of best practices, numeric solutions diverting pharmaceuticals from wastewater. 

7 Edward Berbaum 0524 Opposes hydraulic fracturing to retrieve shale gas activities that may impac

drilling for natural gas in Dimock, PA. 

8 Roger Graham 0525 Opposes the Chesapeake Appalachian Gas Company dumping wastewater 

fracturing to retrieve shale gas in the well near Keuka Lake in NY. 

9 Jeff Bong 0526 Opposes the application of Chesapeake Appalachian Gas Company to stor

the Finger Lakes Region of NY because of possible contamination of grouresulting from hydraulic fracturing to retrieve shale gas. 
Sect

2-3 

Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program 

EPA Docket Number: EPA-HQ-OW-2008-0517 

No. Commenter Name 

EPA 

Docket No. Comment Summary 

10 Warren Cole 0527 Opposes storing wastewater from hydraulic fracturing to retrieve shale gas 

NY. Recommends requiring a 10-mile, or more, distance away from the Fiwastewater. 

11 Bill Hawley 

(Tompkins County Senior Citizens’ Council Inc.) 

0528 Supports programs that will make it easier and more accessible for the gen

long-term care facilities to properly dispose of unwanted pharmaceuticals. 

12 Gail Connally 0529 Opposes storing toxic water from hydraulic fracturing to retrieve shale gas 

Keuka Lake. 

13 Keith and Annette Toaspern 0530 Recommends expanding the CBM Detailed Study to include all oil and gas 

and extraction techniques, including hydraulic fracturing, to retrieve shale Specifically have concerns about storing wastewater near Keuka Lake in N

14 Eunice Alexander 0531 Recommends expanding the CBM Detailed Study to include hydraulic frac

gas. 

15 Ed Gottlieb 

(Ithaca Area Wastewater Treatment Facility) 

0532 Supports changes that would allow health care facilities an alternative to fl

pharmaceuticals. 

16 Dennis Kucinich 

(Michigan Department of Natural Resources and Environment) 

0533 Supports efforts to develop proper disposal of unused pharmaceuticals. Re

reconsider and regulate dental mercury. Recommends EPA reexamine Met

Part 433) and Electroplating (40 CFR Part 413) ELGs because of new chemof concern, and treatment technologies. 

17 Ken Harward 

(Association of Idaho Cities) 

0534 Supports adopting best management practices for the proper disposal of un

Recommends EPA regulate unused pharmaceuticals. 

18 Bernard Handler 0535 Recommends EPA examine hydraulic fracturing to retrieve shale gas. 19 Mary Sweeny 0536 Recommends expanding the CBM Detailed Study to include hydraulic frac

gas in all formations, including Barnett and Marcellus Shales. 

20 John Wagner 

(Wyoming Department of Environmental Quality) 

0537 Recommends that, if it proceeds with CBM ELGs EPA include CBM disch

Extraction Subpart E applicability (40 CFR Part 435). 

21 Laurie Tenace 

(Florida Department of Environmental Protection) 

0538 General comments in support of EPA’s unused pharmaceuticals detailed st

about Florida Department of Environmental Protection guidelines for dispopharmaceuticals. 
Sect

2-4 

Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program 

EPA Docket Number: EPA-HQ-OW-2008-0517 

No. Commenter Name 

EPA 

Docket No. Comment Summary 

22 Bob LeResche 

(Powder River Basin Resource Council) 

0539 Supports moving forward with the CBM ELGs along with including all oil 

stimulation, and extraction techniques that result in surface or groundwater 

23 V. Bruce Thompson 

(American Exploration and Production Council) 

0540 Opposes EPA’s CBM Detailed Study becoming an ELG and opposes expa

detailed study to include other oil and gas extraction activities. 

24 Cynthia Finley 

(National Association of Clean Water Agencies) 

0541 General comments in support of EPA’s unused Pharmaceuticals Detailed S

25 Marcia English 0542 Recommends EPA examine hydraulic fracturing to retrieve shale gas, parti

Shale basin. 

26 Justine Coffey, JD, LLM 

(American Society of Health-System Pharmacists) 

0543 Recommends EPA reconsider using a survey to collect information on unu

management. Provided additional information about unused pharmaceutica

27 Becky Jayne 

(Illinois Environmental Protection Agency) 

0544 Indicates the Quicksilver Caucus Dental Work Group will provide commen

28 Jen Jackson 

(Bay Area Pollution Prevention Group) 

0545 Supports moving forward with an ELG for unused pharmaceuticals to limi

sewer. 

29 Les and Sheryl Rosenbloom 0546 Oppose trucking toxic wastewater from hydraulic fracturing to retrieve Ma

Pennsylvania to store near Keuka Lake in NY. 

30 Angie Burckhalter 

(Oklahoma Independent Petroleum Association) 

0547 Opposes moving forward with ELGs for CBM and expanding the CBM De

all oil and gas exploration, stimulation, and extraction. 

31 S. J. Tatham 0548 Supports expanding the CBM Detailed Study to include all oil and gas exp

extraction, including hydraulic fracturing to retrieve shale gas. 

32 Lee Fuller 

(Independent Petroleum Association of America) 

0549 Opposes moving forward with ELGs for CBM. 

33 Karen Bennett 

(National Mining Association) 

0550 Opposes moving forward with a preliminary study of the Ore Mining and D

Part 440). 
Sect

2-5 

Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program 

EPA Docket Number: EPA-HQ-OW-2008-0517 

No. Commenter Name 

EPA 

Docket No. Comment Summary 

34 Charlie Burd 

(Independent Oil and Gas Association of West Virginia, Inc.) 

0551 Opposes expanding the CBM Detailed Study to include all oil and gas exp

35 Thomas Curtis 

(American Water Works Association) Diane VanDe Hei (Association of Metropolitan Water Agencies) 

0552 General comments on the Effluent Guidelines Program Plan. Supports the 

review of hydraulic fracturing to retrieve shale gas. 

36 Elizabeth Tatham 

(Delaware River Basin Commission)

0553 Opposes the practice of hydraulic fracturing to retrieve shale gas because o

aquifers from fracking fluid and discharges to surface water. Supports desiareas as off limits to mining and other industrial use. 

37 Jay Watson 

(King County) 

0554 Provided information on best management practices (BMPs) for unused ph

38 Kate Cain-Bell 0555 Opposes hydraulic fracturing to retrieve shale gas in Pennsylvania because 

and the environment. 

39 Winfield Tatham 0556 Opposes hydraulic fracturing to retrieve shale gas in Pennsylvania because 

and the environment. 

40 Barbara Bickford and Charles 

Schuler (Wisconsin Department of Natural Resources) 

0557 Support developing BMPs for unused pharmaceuticals to safeguard public 

streamlining federal regulations to minimize generation of unused pharmacexpanding the EPA Pharmaceuticals Detailed Study to include unused pha

homes and agriculture. Support expanding the EPA detailed study to quantpharmaceuticals excreted versus disposed as unused. 

41 Mark Fix 

(Northern Plains Resource Council) 

0558 Supports developing ELGs for both CBM and hydraulic fracturing to retrie

42 David Templet 

(Chesapeake Energy Corporation) 

0559 Opposes developing ELGs for hydraulic fracturing to retrieve shale gas. 

43 Jennifer Peterson 

(Environmental Integrity Project, Defenders of Wildlife, Earthjustice, and Sierra Club) 

0560 Supports EPA’s selection of Steam Electric Power Generating for revised r

expedited schedule for revisions. 
Sect

2-6 

Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program 

EPA Docket Number: EPA-HQ-OW-2008-0517 

No. Commenter Name 

EPA 

Docket No. Comment Summary 

44 Sarah Eckel 

(Citizens Campaign for the Environment) 

0561 and 

0565 

Supports developing ELGs for all oil and gas exploration, stimulation, and a detailed study, including a study of environmental impacts. Requests EPA contamination surrounding underground injection disposal for the waste fluexploration, stimulation, and extraction. 

45 John Smillie 

(The Western Organization of Resource Councils) 

0562 Supports developing ELGs for all oil and gas exploration, stimulation, and 

a detailed study, including hydraulic fracturing to retrieve shale gas. 

46 Cynthia Miles 

(Utility Water Act Group) 

0563 Opposes revising the Steam Electric Power Generating Point Source Categ

47 Deborah Goldberg 

(Earthjustice) 

0564 Supports developing ELGs for both CBM and hydraulic fracturing. 

48 Scott Thomas 

(Fennemore Craig, P.C.) 

0566 Opposes revising ELGs for the Ore Mining and Dressing Category (40 CF

49 B. Arrindell 

(Damascus Citizens for Sustainability) 

0567 Opposes the process of hydraulic fracturing to retrieve shale gas because o

aquifers from fracking fluid and discharges to surface water. 

50 Kathleen Sgamma 

(Independent Petroleum Association of Mountain States) 

0568 Opposes developing ELGs to regulate CBM produced water discharges. 

51 Leroy Sprang 

(Northern Cheyenne Tribe) 

0569 Opposes developing ELGs to regulate CBM-produced water discharges an

regulation. 

52 Erik Milito 

(American Petroleum Institute) 

0570 Opposes developing ELGs to regulate CBM-produced water discharges. 

53 Charlotte Smith 

(PharmEcology Services Waste Management) 

0571 Provides information on BMPs for unused pharmaceuticals handling and d

54 Gayle Gray 

(Rx Rescue LLC) 

0572 Provides information on BMPs for unused pharmaceuticals handling and d

55 Mark McDermid (Wisconsin 

Department of Natural Resources) 

0573 Supports developing an ELG to regulate dental amalgam discharges from d
Section 3 – The Effluent Guidelines Planning Process 

3-1 

3. THE EFFLUENT GUIDELINES PLANNING PROCESS

This section provides a general overview of the process EPA used in 2010 to identify 

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

and pretreatment standards (ELGs). This process consisted of: (1) annual review of existing 

ELGs to identify candidates for revision; (2) identification of new categories of direct 

dischargers for possible development of effluent guidelines; and (3) identification of new 

categories of indirect dischargers for possible development of pretreatment standards. Each of 

these components is illustrated in Figure 3-1 through Figure 3-3 and discussed below. 

3.1 Goals of the Effluent Guidelines Planning Process

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. 

3.2 Annual Review of Existing Effluent Guidelines and Pretreatment Standards

This section describes the four factors used (Section 3.2.1) and how they are used 

(Section 3.2.2) in the annual review of existing effluent guidelines and pretreatment standards. 

3.2.1 Factors Considered in Review of Existing Effluent Guidelines and Pretreatment 

Standards 

EPA uses four major factors in prioritizing existing effluent guidelines or pretreatment 

standards for possible revision. 

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

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

the Agency to set priorities for rulemaking to achieve the greatest environmental and health 

benefits. EPA estimates the potential hazard of pollutant discharges in terms of toxic-weighted 

pound equivalents (TWPE), discussed in detail in Section 4.1.3. To assess the effectiveness of 

pollution control, EPA examines the removal of pollutants in terms of pounds and TWPE. 

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

demonstrated wastewater treatment technologies, process changes, or pollution prevention 

alternatives that could effectively reduce the concentrations of pollutants in the industrial 

category’s wastewater and, consequently, reduce the hazard to human health or the environment 

associated with these pollutant discharges. 
Section 3 – The Effluent Guidelines Planning Process 

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

3-2 
Section 3 – The Effluent Guidelines Planning Process 

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

3-3 
Section 3 – The Effluent Gu

Include in annual review 

of existing category (see 

Figure 3-1)

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 ?

Begin industry 

identification

Do 

discharges interfere

with or otherwise pass

through POTW 

operations?*

Is the possible new

category all or nearly all

indirect dischargers ?

Are 

discharges of toxic 

or nonconventional 

pollutants

trivial?*

Are ELGs potentially 

the appropriate tool ?

No identification or

further review necessary

Identify other tools

(e.g., permit-based 

support or guidance )

Identify for possible

new effluent guidelines 

or standards

Stakeholder recommendations 

and comments

DMR & TRI 

database tools

Yes

Yes

No

Yes

Yes

Yes

No

No

No

No

*Continue further review if not enough data.

Figure 3-3. Flow Chart of Identification of Possible New ELGs 

3-4 
Section 3 – The Effluent Guidelines Planning Process 

3-5 

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 be 

difficult to implement new requirements, EPA might conclude that it would be more costeffective to develop less expensive approaches to reduce pollutant loadings that 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 an annual review, 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 nonregulatory programs. 

3.2.2 Overview: Review of Existing Point Source Categories 

EPA has established ELGs to regulate wastewater discharges from 57 point source 

categories and must annually review the ELGs for all of these categories. EPA first conducts a 

screening-level review of all categories subject to existing ELGs to prioritize the categories for 

further review. The Agency then conducts another review, either an in-depth “detailed study” or 

a somewhat less detailed “preliminary category review,” to identify existing categories for 

potential ELGs revision. 

3.2.2.1 Screening-Level Review 

The screening-level review is the first step in EPA’s annual review. Section 4 provides 

details on the database methodology used in the screening-level review. EPA uses this step to 

prioritize categories for further review. In conducting the screening-level review, EPA considers 

the amount and toxicity of the pollutants in a category’s discharge and the extent to which these 

pollutants may pose a hazard to human health or the environment (Factor 1). 

EPA conducts its screening-level review using data from the Toxics Release Inventory 

(TRI) and data from discharge monitoring reports (DMR) contained in the Permit Compliance 

System (PCS) and Integrated Compliance Information System - National Pollutant Discharge 

Elimination System (ICIS-NPDES). EPA combines the DMR data from both PCS and ICISNPDES in a database called DMRLoads. The Revised Quality Assurance Project Plan for the 

2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and PCS Industrial Category 

Discharge Data describes in detail the quality criteria EPA used to evaluate the TRI and DMR 

data (ERG, 2009). TRI and DMR data do not identify the effluent guideline(s) applicable to a 

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

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

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

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

 The second step is to use 

the information reported in TRI and DMR, for a specified year, to calculate the annual pollutant 

discharges in pounds, including toxic, nonconventional, and conventional pollutants. For indirect 

 

1

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

the 2009 Technical Support Document for the Annual Review of Existing Effluent Guidelines and Identification of 

Potential New Point Source Categories (U.S. EPA, 2009). 
Section 3 – The Effluent Guidelines Planning Process 

3-6 

dischargers, EPA adjusts the facility discharges to account for removals at the publicly owned 

treatment works (POTW). The third step is to apply toxic weighting factors (TWFs)2

 to the 

annual pollutant discharges to calculate the total discharge of toxic and nonconventional 

pollutants (reported in units of TWPE). EPA then sums the TWPE for each facility in a category 

to calculate a total TWPE per category for that year. EPA calculates two TWPE estimates for 

each category: one based on data in TRI and one based on DMR data. EPA combines the 

estimated discharges of toxic and nonconventional pollutants calculated from TRI and DMR data 

to estimate a single TWPE value for each industrial category. EPA took this approach because it 

found that combining the TWPE estimates from TRI and DMR data into a single TWPE number 

offered a clearer perspective of the industries with the most toxic pollution.3

EPA then ranks point source categories according to their total TWPE discharges. In 

identifying categories for further review, EPA prioritizes categories accounting for 95 percent of 

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

EPA also excludes from further review categories for which an effluent guidelines rulemaking is 

currently underway or for which effluent guidelines have been promulgated or revised within the 

past seven years. EPA chose seven years because this is the typical length of time for the effects 

of effluent guidelines or pretreatment standards to be fully reflected in pollutant loading data and 

TRI reports. EPA also considers the number of facilities responsible for the majority of the 

estimated toxic-weighted pollutant discharges associated with an industrial activity. Where only 

a few facilities in a category account for the vast majority of toxic-weighted pollutant discharges, 

EPA typically does not prioritize the category for additional review. In this case, EPA believes 

that revising individual permits may be more effective in addressing the toxic-weighted pollutant 

discharges than a national effluent guidelines rulemaking because requirements can be better 

tailored to these few facilities and because individual permitting actions may take considerably 

less time than a national rulemaking. 

3.2.2.2 Further Review 

Based on its screening-level review of all point source categories, EPA prioritizes certain 

categories for further review to determine whether it would be appropriate for EPA to identify 

those categories in the final Plan for potential effluent guidelines revision. EPA typically 

conducts two types of further review: detailed studies and preliminary reviews. EPA selects 

categories for further review based on the screening-level review and/or stakeholder input. 

EPA’s detailed studies generally examine the following: (1) wastewater characteristics 

and pollutant sources; (2) the pollutants driving the toxic-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 screening-level results and to fill in data gaps 

(Factor 1). Next, EPA considers costs and performance of applicable and demonstrated 

 

2

 For more information on toxic weighting factors, see Toxic Weighting Factor Development in Support of CWA 

304(m) Planning Process (U.S. EPA, 2006). 3

 Different pollutants may dominate the TRI and DMR TWPE estimates for an industrial category due to the 

differences in pollutant reporting requirements between the TRI and DMR databases. The single TWPE number for 

each category highlights those industries with the most toxic discharge data in both TRI and DMR. Although this 

approach could have theoretically led to double-counting, EPA's review of the data indicates that because the three 

databases focus on different pollutants, double-counting was minimal and did not affect the order of the top ranked 

industrial categories. 
Section 3 – The Effluent Guidelines Planning Process 

3-7 

technologies, process changes, or pollution prevention alternatives that can effectively reduce the 

pollutants in the point source category’s wastewater (Factor 2). Last, EPA considers the 

affordability or economic achievability of the technology, process change, or pollution 

prevention measure identified using the second factor (Factor 3). 

Types of data sources that EPA may consult in conducting its detailed studies include, 

but are not limited to: (1) U.S. Economic Census; (2) TRI and DMR data; (3) trade associations 

and reporting facilities to verify reported releases and facility categorization; (4) regulatory 

authorities (states and EPA regions) to understand 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. 

Preliminary reviews are similar to detailed studies and have the same purpose. During 

preliminary reviews, EPA generally examines the same factors and data sources listed above for 

detailed studies. However, in a preliminary review, EPA’s examination of a point source 

category and available pollution prevention and treatment options is less rigorous than in its 

detailed studies. While EPA collects and analyzes hazard and technology performance and cost 

information on categories undergoing preliminary review, it assigns a higher priority to 

investigating categories undergoing detailed studies. 

3.3 Identification of New Categories for Possible Effluent Guidelines Development

Concurrent with its review of existing point source categories, EPA also reviews 

industries not currently subject to effluent guidelines to identify potential new point source 

categories. To identify possible new categories, EPA conducts a “crosswalk” analysis based on 

data in DMR and TRI. Facilities with data in DMR and TRI are identified by a four-digit SIC 

code or six-digit NAICS code (Sections 4.1.1 and 4.1.2 provide more details on SIC and NAICS 

codes, respectively). EPA links each four-digit SIC code and six-digit NAICS code to an 

appropriate industrial category (i.e., “the crosswalk”).4

 This crosswalk identifies SIC codes and 

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

also identifies SIC and NAICS codes not associated with an existing guideline. In addition to the 

crosswalk analysis, EPA relies on stakeholder comments to identify potential new point sources 

categories. Sections 4.1.4 and 4.1.5 discuss the utility and limitations of TRI and DMR data, 

respectively, in detail. 

For each industry identified through the crosswalk analysis or stakeholder comments, 

EPA evaluates whether it could be identified as a potential new category in the plan or whether it 

is properly considered a potential new subcategory of an existing point source category. To 

determine this, EPA generally looks at whether the industry produces a similar product or 

performs a similar service as an existing category. If so, EPA generally considers the industry to 

be a potential new subcategory of that category. If, however, the industry is significantly 

different from existing categories in terms of products or services provided, EPA considers the 

industry as a potential new stand-alone category subject to identification in the Plan. 

 

4

 For additional information on “the crosswalk,” see Section 4 of the 2009 Technical Support Document for the 

Annual Review of Existing Effluent Guidelines and Identification of Potential New Point Source Categories (U.S. 

EPA, 2009). 
Section 3 – The Effluent Guidelines Planning Process 

3-8 

3.3.1 Direct Discharges 

Because the Clean Water Act (CWA) has different requirements for potential new 

categories of direct and indirect dischargers, EPA examines new categories to determine if the 

category comprises mostly direct dischargers, mostly indirect dischargers, or both direct and 

indirect dischargers. If a category consists largely of direct dischargers, EPA evaluates the type 

of pollutants discharged by facilities in the category. 

3.3.2 Indirect Discharges 

For potential new categories with primarily indirect dischargers, EPA evaluates the 

potential for the wastewater discharges to “interfere with, pass through, or [be] otherwise 

incompatible with” the operation of POTWs. See 33 U.S.C. § 1371(b)(1). Using available data, 

EPA reviews the types of pollutants in an industry’s wastewater. Then, EPA reviews the 

likelihood of those pollutants to pass through a POTW as measured by: (1) the total annual 

TWPE discharged by the industrial sector; and (2) the average TWPE discharged among 

facilities that discharge to POTWs. EPA also assesses the interference potential of the discharge. 

Finally, EPA considers whether the pollutant discharges are already adequately controlled by 

general pretreatment standards and/or local pretreatment limits. 

3.4 Stakeholder Involvement and Schedule

EPA’s goal is to involve stakeholders early and often during its annual reviews of 

existing effluent guidelines and the development of the biennial Plan. By doing so, EPA will 

likely maximize the data collected to inform its analyses and provide additional transparency and 

understanding of its effluent guidelines priorities identified in the biennial Plan. 

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

outreach effort to involve stakeholders in the review process. In performing its annual reviews, 

EPA considers all public comments, information, and data submitted to EPA as part of its 

outreach activities. EPA solicits public comment at the beginning of each annual review of 

effluent guidelines and on the preliminary biennial Plan. In each Federal Register Notice, EPA 

requests stakeholder comments on specific industries and discharges as well as any general 

comments. 

EPA completes an annual review of industrial discharges each year, upon publication of 

the Preliminary and Final Effluent Guidelines Program Plans. In odd-numbered years, EPA 

publishes its preliminary Plan for public review and comment as required under CWA section 

304(m)(2). In even-numbered years, EPA publishes its final Plan that incorporates the comments 

received on the preliminary Plan. 

EPA intends that these contemporaneous reviews will provide meaningful insight into 

EPA’s effluent guidelines and pretreatment standards program decision-making. Additionally, by 

providing notice for these and future reviews, EPA hopes to provide a consolidated source of 

information for the Agency’s current and future effluent guidelines and pretreatment standards 

program reviews. 
Section 3 – The Effluent Guidelines Planning Process 

3-9 

3.5 The Effluent Guidelines Planning Process References

1. ERG. 2009. Revised Quality Assurance Project Plan for 2009 Annual Screening-Level 

Analysis of TRI, ICIS-NPDES, and PCS Industrial Category Discharge Data.

(September). EPA-HQ-OW-2008-0517-0507. 

2. U.S. EPA. 2006. Toxic Weighting Factor Development in Support of CWA 304(m) 

Planning Process. Washington, DC. (June). EPA-HQ-OW-2004-0032-1634. 

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

Guidelines and Identification of Potential New Point Source Categories. EPA-821-R-09-

007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515. 
Section 4 – Methodology, Data Sources, and Limitations 

4-1

4. METHODOLOGY, DATA SOURCES, AND LIMITATIONS

As discussed in Section 1, the Clean Water Act (CWA) requires EPA to conduct an 

annual review of existing effluent limitations guidelines and pretreatment standards (ELGs). It 

also requires EPA to identify industrial categories without applicable ELGs. EPA’s methodology 

for the 2010 annual review and new point source category identification involves several 

components, as discussed in Section 3. 

First, EPA performs a screening-level review of all point source categories subject to 

existing ELGs to identify categories discharging high levels of toxic and nonconventional 

pollutants relative to other categories. Second, EPA identifies priority categories as possible 

candidate ELGs for revision, as required by CWA sections 304(b), 301(d), 304(g), and 307(b). 

EPA then performs further review of the priority categories. Part II of this report (Sections 5

through 15) discusses the findings of EPA’s 2010 annual review. 

The next component of EPA’s review is to identify industrial categories without 

applicable ELGs. EPA reviews indirect discharging industries not currently subject to 

pretreatment standards to identify potential candidates for pretreatment standards development, 

as required by CWA section 307(b). Next, EPA reviews direct discharging industries not 

currently subject to ELGs to identify potential candidates for ELG development, as required by 

section 304(m)(1)(B) of the CWA. 

In performing the screening-level review of existing ELGs and identifying industrial 

categories without ELGs, EPA relies on discharge monitoring report (DMR) data, contained in 

EPA’s Permit Compliance System (PCS) and the Integrated Compliance Information System for 

the National Pollutant Discharge Elimination System (ICIS-NPDES), and the Toxics Release 

Inventory (TRI). This section discusses these databases, related data sources, and their 

limitations. 

EPA has developed two screening-level tools, the TRIReleases and DMRLoads databases, 

to facilitate analysis of TRI and PCS/ICIS-NPDES data. EPA previously explained the creation 

of these screening-level analysis tools 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. This section does not revisit the details of 

creating the database tools. Instead, it lists the methodology corrections made to the DMRLoads

and TRIReleases databases as part of EPA’s 2010 annual review. It also presents the preliminary 

category rankings from TRIReleases2008_v3 and DMRLoads2008_v2. 

4.1 Data Sources and Limitations

This subsection provides general information on the use of Standard Industrial 

Classification (SIC) and North American Industry Classification System (NAICS) codes, toxic 

weighting factors (TWFs), TRI data, and DMR data. The following reports supplement this 

section and discuss EPA’s methodology for developing and using the two screening-level tools: 

• Technical Support Document for the Annual Review of Existing Effluent 

Guidelines and Identification of Potential New Point Source Categories, (2009 
Section 4 – Methodology, Data Sources, and Limitations 

4-2

SLA Report) (U.S. EPA, 2009). Documents the methodology and development of 

the DMRLoads2008 and TRIReleases2008 databases, including (but not limited 

to) matching NAICS and SIC codes to point source categories and using TWFs to 

estimate toxic-weighted pound equivalents (TWPE).

• Draft Toxic Weighting Factor Development in Support of the CWA 304(m) 

Planning Process (Draft TWF Development Document), dated July 2005 (U.S. 

EPA, 2005). Explains how EPA developed the December 2004 TWFs. 

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

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

EPA developed the April 2006 TWFs. 

4.1.1 SIC Codes 

The SIC code system was developed to help with the collection, aggregation, 

presentation, and analysis of data from the U.S. economy (OMB, 1987). The different parts of 

the SIC code signify the following: 

• The first two digits represent the major industry group; 

• The third digit represents the industry group; and 

• The fourth digit represents the industry. 

For example, major SIC code 26: Paper and Allied Products includes all pulp, paper, and 

paperboard manufacturing operations. Within SIC code 26, the three-digit SIC codes are used to 

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

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

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

The SIC system is used by many government agencies, including EPA, to promote data 

comparability. In the SIC system, each establishment is classified according to its primary 

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

establishment may have activities in more than one SIC code. Some data collection organizations 

track only the primary SIC code for each establishment. PCS and ICIS-NPDES include one fourdigit SIC code, reflecting the principal activity causing the discharge at each facility. 

Regulations for an individual point source category may apply to one SIC code, multiple 

SIC codes, or a portion of the facilities in an SIC code. Therefore, to use databases that identify 

facilities by SIC code, EPA linked each four-digit SIC code to an appropriate point source 

category, as summarized in the “SIC/Point Source Category Crosswalk” table (Table A-1 in 

Appendix A). 

There are some SIC codes for which EPA has not established national ELGs. Table A-2 

in Appendix A lists the SIC codes for which facility discharge data are available in PCS and 

ICIS-NPDES, but for which EPA could not identify an applicable point source category. For a 

more detailed discussion, see Section 6 of the 2009 SLA Report (U.S. EPA, 2009). 
Section 4 – Methodology, Data Sources, and Limitations 

4-3

4.1.2 NAICS Codes 

In 1997, the U.S. Census Bureau introduced the NAICS code system, to better represent 

the economic structure of countries participating in the North American Free Trade Agreement 

and to respond to criticism about the SIC code system. Table 4-1 explains the nomenclature and 

format of NAICS and SIC codes. 

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

NAICS SIC 

2-digit Sector Letter Division 

3-digit Subsector 2-digit Major Group 

4-digit Industry Group 3-digit Industry Group 

5-digit NAICS Industry 4-digit Industry 

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

For example, below are the SIC and NAICS code for the Folding Paperboard Box 

Manufacturing industry. 

In the SIC code system the classification is less stratified: 

• 26: Paper and Allied Paper Products; 

— 265: Paperboard containers and boxes; 

• 2657: Folding Paperboard Boxes, Including Sanitary (except 

paperboard backs for blister or skin packages). 

In the NAICS code system the classification is more stratified: 

• 32: Manufacturing; 

— 322: Paper Manufacturing; 

• 3222: Converted Paper Product Manufacturing; 

o 322212: Folding Paperboard Box Manufacturing. 

The NAICS system is used for industrial classification purposes at many government 

agencies, including EPA. As in the SIC system, each establishment is classified according to its 

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

establishment may have activities in more than one NAICS code. 

Regulations for an individual point source category may apply to one NAICS code, 

multiple NAICS codes, or a portion of the facilities in an NAICS code. Therefore, to use 

databases that identify facilities by NAICS code (e.g., TRI), EPA linked each six-digit NAICS 

code to an appropriate point source category, as summarized in the “NAICS/Point Source 

Category Crosswalk” table (Table A-3 in Appendix A). This table was based on the SIC/Point 

Source Category Crosswalk table (Table A-1 in Appendix A) and the NAICS/SIC Code 

Crosswalk that EPA developed for past comparisons. 

There are some NAICS codes for which EPA has not established national ELGs. Table 

A-4 in Appendix A lists the NAICS codes for which facility discharge data are available in TRI, 
Section 4 – Methodology, Data Sources, and Limitations 

4-4

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

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

4.1.3 Toxic Weighting Factors 

As part of the Effluent Guidelines Program, EPA developed a wide variety of tools and 

methodologies to evaluate effluent discharges. EPA’s Office of Water, Engineering and Analysis 

Division (EAD) maintains a Toxics Database compiled from over 100 references for more than 

1,900 pollutants. The Toxics Database includes aquatic life and human health toxicity data, as 

well as physical and chemical property data. Each pollutant in this database is identified by a 

unique Chemical Abstract Service (CAS) number. EPA calculates TWFs from these data to 

account for differences in toxicity across pollutants and to provide the means to compare mass 

loadings of different pollutants. In its analyses, EPA multiplies a mass loading of a pollutant in 

pounds per year (lb/yr) by a pollutant-specific weighting factor to derive a “toxic-equivalent” 

loading (lb-equivalent/yr). Throughout this document, the toxic-equivalent is also referred to as 

TWPE. The Draft and Final TWF Development Documents discuss the use and development of 

TWFs in detail (U.S. EPA, 2005; U.S. EPA, 2006b). 

EPA derives TWFs from chronic aquatic life criteria (or toxic effect levels) and human 

health criteria (or toxic effect levels) established for the consumption of fish. In the TWF method 

for assessing water-based effects, these aquatic life and human health toxicity levels are 

compared to a benchmark value that represents the toxicity level of a specified pollutant. EPA 

selected copper, a metal commonly detected and removed from industrial effluent, as the 

benchmark pollutant. The Final TWF Development Document contains details on how EPA 

developed its TWFs (U.S. EPA, 2006b). Table A-5 in Appendix A lists the TWFs for those 

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

TWFs. 

4.1.3.1 New Toxic Weighting Factors Developed During the 2010 Annual Review 

During the 2010 annual review, EPA did not revise any TWFs or develop TWFs for any 

chemicals that had not previously had TWFs. 

4.1.3.2 Calculation of TWPE 

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

Section 4.1.4) and DMRLoads (see Sections 4.1.5) databases using EAD’s TWFs to calculate 

TWPE for each reported discharge. EPA summed the estimated TWPE discharged by each 

facility in a point source category to understand the potential hazard of the discharges from each 

category. The following subsections discuss the calculation of TWPE. 

4.1.4 Data from TRI 

TRI is the common name for Section 313 of the Emergency Planning and Community 

Right-to-Know Act. Each year, facilities that meet certain thresholds must report their releases 

and other waste management activities for listed toxic chemicals. Facilities must report the 

quantities of toxic chemicals recycled, collected, and combusted for energy recovery, treated for 

destruction, or disposed of. A separate report must be filed for each chemical that exceeds the 

reporting threshold. The TRI list of chemicals for reporting year 2008 includes more than 650 
Section 4 – Methodology, Data Sources, and Limitations 

4-5

chemicals and chemical categories. For the 2010 screening-level review, EPA used data for 

reporting year 2008, because they were the most recent available at the time the review began. 

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

a given reporting year: 

1. NAICS Code Determination. The primary NAICS code determines if TRI 

reporting is required. The primary NAICS code is associated with the facility’s 

revenues, and may not relate to its pollutant discharges (73 FR 324666). Certain 

facilities in NAICS codes 11, 21, 22, 31 through 33, 42, 48 through 49, 51, 54, 56 

and 81, and federal facilities are potentially subject to TRI reporting. EPA 

generally relies on facility claims regarding the NAICS code identification. 

2. Number of Employees. Facilities must have 10 or more full-time employees or 

their equivalent. EPA defines a “full-time equivalent” as a person that works 

2,000 hours in the reporting year (there are several exceptions and special 

circumstances that are well defined in the TRI reporting instructions). 

3. Activity Thresholds. If the facility is in a covered NAICS code and has 10 or more 

full-time employee equivalents, it must conduct an activity threshold analysis for 

every chemical and chemical category on the current TRI list. The facility must 

determine whether it manufactures, processes, or otherwise uses each chemical at 

or above the appropriate activity threshold. Reporting thresholds are not based on 

the amount of release. All TRI thresholds are based on mass, not concentration. 

Different thresholds apply for persistent bioaccumulative toxic (PBT) chemicals 

than for non-PBT chemicals. Generally, non-PBT chemical threshold quantities 

are 25,000 pounds for manufacturing and processing activities and 10,000 pounds 

for other use activities. All thresholds are determined per chemical over the 

calendar year. For example, dioxin and dioxin-like compounds are considered 

PBT chemicals. The TRI reporting guidance requires any facility that 

manufactures, processes, or otherwise uses 0.1 grams of dioxin and dioxin-like 

compounds to report it to TRI (U.S. EPA, 2000). 

In TRI, facilities report annual loads released to the environment of each toxic chemical 

or chemical category that meets reporting requirements. Facilities must report onsite releases or 

disposal to air, receiving streams, land, underground wells, and several other categories. They 

must also report the amount of toxic chemicals in wastes transferred to off-site locations, (e.g., 

POTWs, commercial waste disposal facilities). 

For its screening-level reviews, EPA focused on the amount of chemicals facilities 

reported either discharging directly to a receiving stream or transferring to a POTW. For 

facilities discharging directly to a stream, EPA took the annual loads directly from the reported 

TRI data for calendar year 2008. For facilities transferring to POTWs, EPA first adjusted the TRI 

pollutant loads reported to account for pollutant removal that occurs at the POTWs prior to 

discharge to the receiving stream. Table A-6 in Appendix A lists the POTW removals used for 

all TRI chemicals reported as transferred to POTWs. 
Section 4 – Methodology, Data Sources, and Limitations 

4-6

Facilities reporting to TRI are not required to sample and analyze waste streams to 

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

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

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

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

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

the mass released. However, for dioxins and dioxin-like compounds, nondetects should be 

treated as zero. 

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

Specific estimates are encouraged if data are available to ensure the accuracy; however, EPA 

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

500 to 999 pounds. For its screening-level reviews, EPA used the midpoint of each reported 

range to represent a facility’s releases, as applicable. 

4.1.4.1 Utility of TRI Data 

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

reasons: 

• TRI is national in scope, including data from all 50 states and U.S. 

territories/tribes; 

• TRI includes releases to POTWs, not just direct discharges to surface water; 

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

industrial categories; and 

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

permits. 

4.1.4.2 Limitations of TRI 

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

following: 

• Small establishments (less than 10 employees) are not required to report, nor are 

facilities that do not meet the reporting thresholds. Thus, facilities reporting to 

TRI may be a subset of an industry. 

• Release reports are, in part, based on estimates, not measurements, and, due to 

TRI guidance, may overstate releases, especially at facilities with large 

wastewater flows. 

• Certain chemicals (polycyclic aromatic compounds (PACs), dioxin and dioxinlike compounds, metal compounds) are reported as a class, not as individual 

compounds. Because the individual compounds in most classes have widely 

varying toxic effects, the potential toxicity of chemical releases can be 

inaccurately estimated. 
Section 4 – Methodology, Data Sources, and Limitations 

4-7

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

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

category that is the source of the toxic wastewater releases. 

Despite these limitations, EPA determined that the data summarized in TRIReleases2008 

were usable for the 2010 screening-level review and prioritization of the toxic-weighted pollutant 

loadings discharged by industrial categories. 

4.1.5 Data from PCS and ICIS-NPDES 

EPA has used data reported to PCS as a part of its screening-level review of existing 

effluent guidelines since the 2003 annual review (68 FRN 75515). Since 2002, EPA has been 

working to modernize PCS by creating a new data system called ICIS-NPDES. In 2006, some 

states began transitioning their DMR reporting from PCS to ICIS-NPDES. Currently 57 of the 71 

states and territories/tribes have migrated to ICIS-NPDES. Therefore, for the 2010 annual 

review, EPA’s view of nationwide discharges was split between two sets of data. EPA created 

the 2008 DMR Loadings Tool to combine the two systems (PCS and ICIS-NPDES) and generate 

industrial category rankings for all U.S. states and territories/tribes. EPA extracted the loads from 

the 2008 DMR Loadings Tool to create the DMRLoads2008 database. Both PCS and ICISNPDES automate entering, updating, and retrieving NPDES data and track permit issuance, 

permit limits, monitoring data, and other data pertaining to facilities regulated by the NPDES 

program under the CWA. 

More than 65,000 industrial facilities and wastewater treatment plants have permits for 

wastewater discharges to waters of the United States. To provide an initial framework for setting 

permitting priorities, EPA developed a major/minor classification system for industrial and 

municipal wastewater discharges. Major discharges usually have the capability to impact 

receiving waters if not controlled and, therefore, have received more regulatory attention than 

minor discharges. There are approximately 7,000 facilities (including sewerage systems) with 

major discharges and 15,000 facilities with minor discharges for which PCS and ICIS-NPDES 

have extensive records. Permitting authorities classify discharges as major based on an 

assessment of six characteristics: 

1. Toxic pollutant potential; 

2. Discharge flow: stream flow ratio; 

3. Conventional pollutant loading; 

4. Public health impact; 

5. Water quality factors; and 

6. Proximity to coastal waters. 

Facilities with major discharges must report compliance with NPDES permit limits via 

monthly DMRs submitted to the permitting authority. The permitting authority enters the 

reported DMR data into PCS or ICIS-NPDES, including pollutant concentration and quantity 

values and identification of any types of permit violations. 

Minor discharges may, or may not, adversely impact receiving water if not controlled. 

Facilities with minor discharges must report compliance with NPDES permit limits via monthly 

DMRs submitted to the permitting authority; however, EPA does not require the permitting 

authority to enter data in the PCS and ICIS-NPDES databases. For this reason, the PCS and 
Section 4 – Methodology, Data Sources, and Limitations 

4-8

ICIS-NPDES databases include data only for a limited set of minor discharges (i.e., if the state or 

other permitting authority chooses to include these data). 

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

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

(BOD5) and total suspended solids (TSS)), and flow rates. Although other pollutants may be 

discharged, PCS and ICIS-NPDES contain data only for the parameters identified in the facility’s 

NPDES permit. Facilities typically report monthly average pounds per day discharged, but also 

report daily maxima and average pollutant concentrations. 

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

data obtained from TRI. For the 2010 annual review, EPA corrected certain aspects of the 2008 

data (see Section 4.3). Using the DMR Loadings Tool, EPA calculated annual loads for the PCS 

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

extracted the results of the annual loads calculations in the DMRLoads2008 database. Section 2 

of the 2009 SLA Report provides details on the methodology and development of 

DMRLoads2008 (U.S. EPA, 2009). 

4.1.5.1 Utility of PSC and ICIS-NPDES 

The data collected in the PCS and ICIS-NPDES data systems are particularly useful for 

the ELG planning process for the following reasons: 

• PCS and ICIS-NPDES combined are national in scope, including data from all 50 

states and 21 U.S. territories/tribes. 

• Discharge reports included in PCS and ICIS-NPDES are based on effluent 

chemical analysis and metered flows. 

• PCS and ICIS-NPDES include facilities in all SIC codes. 

• PCS and ICIS-NPDES include data on conventional pollutants for most facilities 

and for the nutrients nitrogen and phosphorus for many facilities. 

4.1.5.2 Limitations of PCS and ICIS-NPDES 

Limitations of the data collected in the PCS and ICIS-NPDES data systems include the 

following: 

• The data systems contain data only for pollutants a facility is required by permit 

to monitor; the facility is not required to monitor or report all pollutants actually 

discharged. 

• The data systems include limited discharge monitoring data from minor 

dischargers. 

• The data systems do not include data characterizing indirect discharges from 

industrial facilities to POTWs. 

• Many of the pollutant parameters included in the data systems are reported as a 

group parameter and not as individual compounds (e.g., “Total Kjeldahl 

Nitrogen,” “oil and grease”). Because the individual compounds in the group 
Section 4 – Methodology, Data Sources, and Limitations 

4-9

parameter may have widely varying toxic effects, the potential toxicity of 

chemical releases can be inaccurately estimated. 

• In some cases, the data systems identify the type of wastewater (e.g., process 

wastewater, stormwater, noncontact cooling water) being discharged; however, 

most do not and, therefore, total flow rates reported to PCS and ICIS-NPDES may 

include stormwater and noncontact cooling water, as well as process wastewater. 

• Pipe identification is not always clear. For some facilities, internal monitoring 

points are labeled as outfalls, and PCS and ICIS-NPDES may double-count a 

facility’s discharge. In other cases, an outfall may be labeled as an internal 

monitoring point, and PCS and ICIS-NPDES may not account for all of a 

facility’s discharge. 

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

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

is the source of the reported wastewater discharges5. 

• PCS and ICIS-NPDES were designed as a permit compliance tracking system and 

do not contain production information. 

• PCS and ICIS-NPDES data may be entered into the data systems manually, which 

leads to data-entry errors. 

• In PCS and ICIS-NPDES, data may be reported as an average quantity, maximum 

quantity, average concentration, maximum concentration, and/or minimum 

concentration. For many facilities and/or pollutants, average quantity values are 

not provided. In these cases, EPA is limited to estimating facility loads based on 

the maximum quantity. Section 3.2.3 of the 2009 SLA Report discusses the 

maximum quantity issue in detail (U.S. EPA, 2009). 

• PCS and ICIS-NPDES data on conventional pollutants and the nutrients nitrogen 

and phosphorus are not used because of data quality concerns. 

Despite these limitations, EPA determined that the data summarized in DMRLoads2008 

were usable for the 2010 screening-level reviews and prioritizations of the toxic-weighted 

pollutant loadings discharged by industrial facilities. The combined PCS and ICIS-NPDES 

databases remain the only data source quantifying the pounds of regulated pollutants discharged 

directly to surface waters of the United States. 

4.2 Methodology Correction Affecting Both Screening-Level Review Databases

The 2009 SLA Report provides detailed information on the methodology EPA used to 

develop the screening-level review databases (U.S. EPA, 2009). For the 2010 annual review, 

EPA made changes to the methodology used to develop the 2008 DMR and TRI databases. 

These methodology changes included the processing of the PCS data, the addition of minor 

 

5

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

4-10

discharges to the 2008 DMR database, and a change to the dioxin distribution hierarchy in the 

2008 TRI database. This subsection summarizes the methodology changes made by EPA to the 

2010 screening-level review databases. 

4.2.1 Summary of DMRLoads2008 Database Methodology Changes 

The two major changes made to the DMRLoads2008 database, discussed in the 

subsections below, include changes made to the PCS data processing and the addition of minor 

dischargers. 

PCS Data Processing 

For the 2010 annual review, EPA generated the industrial category rankings in 

DMRLoads2008 for all U.S. states and territories/tribes from two data sources, PCS and ICISNPDES. As part of the 2010 annual review, EPA estimates the pollutant load for each facility by 

multiplying flow and concentration where appropriate. That is, no load is estimated for internal 

outfalls, and EPA does not estimate a load for certain pollutants, such as pH. During previous 

annual reviews, EPA used a separate database to process PCS data. This year, EPA incorporated 

the PCS data processing (i.e., calculation a load using flow and concentration where appropriate) 

as an additional subroutine in the DMR Loadings Tool. The data analysis methodology in the 

DMR Loadings Tool subroutine is consistent with the PCSLoadCalculator. 

Addition of Minor Dischargers 

Facilities in the DMRLoads database are classified as either major or minor dischargers 

based on EPA’s major/minor classification system for industrial and municipal wastewater 

discharges. As discussed in the Section 4.1.5, major discharges usually have the capability to 

impact receiving waters if not controlled. Minor discharges may or may not adversely impact 

receiving water if not controlled. Therefore, EPA does not require permitting authorities to enter 

DMR data for facilities with minor discharges into PCS and ICIS-NPDES. As a result, discharge 

data for minor discharges in PCS and ICIS-NPDES may be incomplete. 

EPA previously reviewed discharges for only major discharging facilities because of the 

possible incomplete data for minor discharging facilities. For the 2010 annual review, EPA 

determined that including minor discharges would provide a more thorough review by 

identifying industries that may consist mostly of minor facilities or have high pollutant 

discharges because of contributing minor facilities. To determine if minor discharges are 

appropriately represented, EPA compared the number of minor dischargers in the DMR database 

to the number of minor dischargers that report water discharges for each state, presented in Table 

4-2. 
Section 4 – Methodology, Data Sources, and Limitations 

4-11

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

State or Territory/Tribe Minors a

Minors with Water 

Discharges b

Percent of Minors with 

Water Discharges 

Alaska 3,302 20 0.6% 

Alabama 10,175 961 9.4% 

Arkansas 3,857 374 9.7% 

American Samoa 4 0 0.0% 

Arizona 104 9 8.7% 

California 2,142 1 0.0% 

Colorado 3,122 63 2.0% 

Connecticut 739 74 10.0% 

District of Columbia 128 7 5.5% 

Delaware 35 21 60.0% 

Florida 244 137 56.1% 

Georgia 1,984 148 7.5% 

Gulf of Mexico 649 0 0.0% 

Guam 62 0 0.0% 

Hawaii 3,096 13 0.4% 

Iowa 1,535 420 27.4% 

Idaho 966 81 8.4% 

Illinois 11,487 770 6.7% 

Indiana 4,105 1,140 27.8% 

Johnston Atoll 1 0 0.0% 

Kansas 1,166 24 2.1% 

Kentucky 1,731 1,304 75.3% 

Louisiana 16,787 28 0.2% 

Massachusetts 1,225 156 12.7% 

Maryland 4,168 589 14.1% 

Maine 270 106 39.3% 

Michigan 463 197 42.5% 

Minnesota 685 9 1.3% 

Missouri 2,894 1,148 39.7% 

Northern Mariana Islands 11 0 0.0% 

Mississippi 1,507 997 66.2% 

Montana 3,869 169 4.4% 

North Carolina 1,083 648 59.8% 

North Dakota 111 1 0.9% 

Nebraska 1,167 210 18.0% 

New Hampshire 310 23 7.4% 

New Jersey 3,649 498 13.6% 

New Mexico 1,594 44 2.8% 

Navajo Nation 45 2 4.4% 

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

4-12

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

State or Territory/Tribe Minors a

Minors with Water 

Discharges b

Percent of Minors with 

Water Discharges 

New York 6,869 805 11.7% 

Ohio 3,044 1,465 48.1% 

Oklahoma 1,294 149 11.5% 

Oregon 324 4 1.2% 

Pennsylvania 10,613 20 0.2% 

Puerto Rico 701 117 16.7% 

Rhode Island 687 70 10.2% 

South Carolina 371 250 67.4% 

South Dakota 674 55 8.2% 

St. Regis Mohawk Tribe 2 0 0.0% 

Tennessee 2,050 576 28.1% 

Texas 10,030 802 8.0% 

Utah 2,815 70 2.5% 

Virginia 966 2 0.2% 

Virgin Islands 148 23 15.5% 

Vermont 147 0 0.0% 

Washington 438 34 7.8% 

Wisconsin 830 0 0.0% 

West Virginia 818 42 5.1% 

Wyoming 1,305 11 0.8% 

Total 135,059 14,888 11.0% 

Source: DMRLoads2008_v2. 

a – All minor dischargers in the 2008 DMR database. 

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

To consistently compare major and minor facility discharges in the database, EPA used 

the same database methodologies and procedures in place for reviewing major facility discharges 

to correct and review the minor facility discharge data. For example, EPA used the same flow 

methodology for both major and minor facilities to autocorrect flows between 1,000 and 5,000 

MGD (see Section 4.3.6). Because the DMRLoads2008 database consists of 90 percent minor 

facilities, EPA calculated the 2008 category rankings with and without minor facilities to 

determine the impact it had on the 2010 category rankings, shown in Table C-7, in Appendix C. 

The addition of the minor dischargers to the 2008 DMR data increased the total number of 

facilities reviewed from 2,036 to 16,924. Because of the inconsistent minor water discharging 

data, EPA reviewed states where the majority of minors reported water discharges (e.g., 

Kentucky, Mississippi, and South Carolina). However, some states did not include any water 

discharge data from minor facilities (e.g., Vermont and Wisconsin). 

The addition of minor dischargers also resulted in point source categories that EPA has 

not previously reviewed to be included in the top 95 percent of the 2010 annual review, such as: 

Landfills (40 CFR Part 445), Oil & Gas Extraction (excluding coalbed methane operations) (40 

CFR Part 435), and Metal Molding and Casting (Foundries) (40 CFR Part 464). For the 2010 
Section 4 – Methodology, Data Sources, and Limitations 

4-13

annual review, EPA reviewed both major and minor top discharging facilities for industrial 

categories with high TWPE (see Section 4.3.7). 

4.2.2 Summary of TRIReleases2008 Database Methodology Changes 

In the TRI database certain chemicals (PACs, dioxin and dioxin-like compounds, metal 

compounds) are reported as a class, not as individual compounds. Because the individual 

compounds in most classes have widely varying toxic effects, the potential toxicity of chemical 

releases can be inaccurately estimated. However, for dioxin and dioxin-like compounds, 

reporting facilities are given the opportunity to report facility-specific dioxin distributions that 

EPA uses to better estimate the pollutant TWPE. 

The dioxin and dioxin-like compounds class includes 17 individual congeners, each with 

its own TWF. Facilities report a single mass number for the dioxin and dioxin-like compounds 

but can report the mass of each congener in a separate field (referred to as the dioxin 

distribution). For previous TRI reporting years, a facility could report only one dioxin congener 

distribution, even if dioxins are released to more than one medium. As part of previous annual 

reviews, EPA determined that the majority of facilities use the dioxin congener distribution for 

air releases rather than water discharges. However, EPA used the reported distribution as it was 

the best available information on the wastewater dioxin distribution. 

Starting in 2008, facilities could report release-specific distributions. For example, if a 

facility had three stream discharges (e.g., surface water discharge, air release, and POTW 

transfer), it could report a distribution for each stream. As part of the data processing, the TRI 

Program calculates a total surface water release distribution by combining each of the individual 

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

used the total surface water release distribution. For facilities that leave the all congener 

distribution fields blank, EPA has worked with some trade associations to identify the most 

accurate distribution based on the manufacturing process generating the wastewater. Therefore, 

EPA revised the congener distribution hierarchy in the TRIReleases2008 database, presented in 

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

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

TRIReleases2008

2008 TRI Prior TRI Databases 

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

Water_Congener_2008 table. 

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

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

Amount” 

Same a

2. If there are any changes identified from facility-specific follow-up (e.g. 

discussions with facilities from prior years), assign that previously identified 

distribution. This distribution overwrites distributions applied in Step 1. 

Same 

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

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

distribution. 

Same 

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

Default” distribution. 

Same 
Section 4 – Methodology, Data Sources, and Limitations 

4-14

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

TRIReleases2008

2008 TRI Prior TRI Databases 

5. Use the NAICS average distribution. For facilities in the same category, start with 

the smaller subset of the NAICS code, and then if none of that subset reports a 

distribution, go to a larger set of NAICS codes. e

Same 

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

Congener_2008 table f

. 

NA 

7. Use the TWF for CAS number N150 (dioxin and dioxin-like compounds), which 

is congener 7, the median of the 17 TWFs for dioxin and dioxin-like compounds. 

Same 

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

distributions for each release. 

b – EPA selected the “Total Water Release” distribution rather than using the distributions for each discharge to a 

receiving stream because the majority of facilities did not report distributions for each receiving stream discharge. 

c – Congener distribution is applied only to facilities reporting NAICS codes 322110, 322121, 322122, and 322130. 

Facilities reporting other NAICS codes that link to the Pulp and Paper Category do not get the “Pulp Default” 

congener distribution. 

d – Congener distribution is applied only to facilities reporting NAICS codes 321114 and 113310. Facilities 

reporting other NAICS codes that link to the Timber Products Category do not get the “Wood Preserving Default” 

congener distribution. 

e – Step 5 Example for a Pulp and Paper Category facility. Facility A has a primary NAICS code 322291, reported 

dioxin, and left distribution blank. Steps 1 through 4 do not apply (therefore, no distribution has been applied using 

the hierarchy yet). Facilities B, C, and D primary NAICS codes 322291-2. Facility B reported a distribution (Step 1). 

Facilities C and D did not report one, and they did not get one assigned from Steps 1 through 4. In this hierarchy, 

first we calculate the NAICS average congener distribution on both 322291 (no distribution available) and then 

322291-2 (resulting in a distribution). Then we assign the 322291-2 results to Facilities A, C, and D. Second, we 

make another attempt to calculate the average distribution for NAICS 322291. We calculate the average distribution 

for NAICS 322291 and 322291-2. This will be assigned to the facility reporting 322291 (Facility A). 

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

data. 

NA – Not applicable. 

In TRIReleases2008, 121 facilities reported dioxin and dioxin-like compounds. Table 4-4

presents the number of facilities that reported a dioxin distribution for their water releases and 

the number of facilities that were assigned a distribution from the hierarchy. As shown in Table 

4-4, approximately 34 percent of facilities reporting dioxin and dioxin-like compounds reported 

a specific water release distribution. For the remaining facilities, EPA used the hierarchy to 

assign the dioxin distributions. 
Section 4 – Methodology, Data Sources, and Limitations 

4-15

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

2008

Hierarchy 

Number 

Abbreviated 

Name 

Number of Facilities Assigned the 

Distribution 

Percent of Total Facilities 

Reporting Dioxin and DioxinLike Compounds 

1 

Reported Direct 36 29.7% 

Reported Indirect 5 4.1% 

2 Manual 5 4.1% 

3 Pulp & Paper 31 25.6% 

4 Wood Preserving 9 7.4% 

5 NAICS Average 11 9.1% 

6 Stack Air 15 12.4% 

7 N150 9 7.4% 

Total 121 100% 

Source: TRICalculations2008_v3. 

4.3 Corrections to the DMRLoads2008 Database

EPA developed the DMRLoads2008 database as part of the 2010 annual review using the 

methodology explained in the 2009 SLA Report (U.S. EPA, 2009) with the methodology updates 

described in Section 4.2.1. 

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

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

and 2007. Several of these corrections similarly apply to the 2008 DMR data. In addition, EPA 

reviewed the quality of the 2008 DMR data and facilities with discharges that have the greatest 

impact on total category loads and category rankings. Table B-2 in Appendix B of this report 

lists all corrections made to the 2008 DMR data in the DMR Loadings Tool.

4.3.1 DMRLoads2008: Categorization of Discharges 

This subsection describes database corrections to facility categorization and pollutant 

discharges in DMRLoads2008. Section 4 of the 2009 SLA Report describes the SIC/Point Source 

Category Crosswalk development, which EPA uses to link between facility SIC codes and 

categories with existing ELGs (U.S. EPA, 2009). Because most point source categories are not 

defined by SIC code, the relationship between SIC code and point source category is not a oneto-one correlation. A single SIC code may include facilities in more than one point source 

category, and associating an SIC code with only one category may be an oversimplification. 

Also, many facilities have operations subject to more than one point source category. Further, 

facilities in some categories cannot be identified by SIC code (e.g., Centralized Waste Treatment 

facilities). Section 4 of the 2009 SLA Report describes the database changes, summarized below 

(U.S. EPA, 2009): 

• Facility-Level Point Source Category Assignment. For some SIC codes that 

include facilities subject to guidelines from more than one point source category, 

EPA was able to assign each facility to the category that best applied to the 

majority of its discharges. EPA reviewed information available about each facility 

to determine which point source category applied to the facility’s operations. 
Section 4 – Methodology, Data Sources, and Limitations 

4-16

• Pollutant-Level Point Source Category Assignment. Many facilities have 

operations subject to more than one point source category. For most of these 

facilities, EPA cannot divide the pollutant discharges among the applicable point 

source categories. Two exceptions where EPA was able to assign wastewater 

discharges of certain chemicals to the appropriate point source category are listed 

below: 

— Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF)/Pesticide 

Chemicals. EPA removed all pesticide discharges from the OCPSF 

Category and included them as discharges from the Pesticide Chemicals 

Category. 

— Metal Products and Machinery (MP&M)/Metal Finishing. EPA used the 

methodologies described in Section 4 of the 2009 SLA Report (U.S. EPA, 

2009) to apportion pollutant loads between the MP&M and Metal 

Finishing Categories. 

4.3.2 DMRLoads2008: Internal Monitoring 

This subsection describes database corrections to identify internal monitoring points in 

DMRLoads2008. As discussed in Sections 3.2.1.3 and 3.2.3.2 of the 2009 SLA Report (U.S. 

EPA, 2009), the 2008 DMR Loadings Tool calculated loads only for monitoring locations that 

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

• MLOC 1 – Effluent net discharge; 

• MLOC 2 – Effluent gross discharge; 

• MLOC A – After disinfection; 

• MLOC B – Before disinfection; and 

• MLOC SC – See comments. 

As a result, the DMR Loadings Tool excludes discharges for internal monitoring 

locations such as intake water, influent to treatment, and intermediate points in the wastewater 

treatment system. However, during previous category reviews and detailed studies, EPA 

identified instances of double-counting that resulted from including certain internal monitoring 

points in the loads database. For example, a facility monitors for Pollutant A at the effluent from 

its wastewater treatment system (internal Outfall 101). Outfall 101 wastewater is later combined 

with other plant discharges at final Outfall 001 and is discharged to a receiving stream. The 

facility also monitors for Pollutant A at final Outfall 001. Both outfalls are effluent monitoring 

points identified as MLOC 1 or MLOC 2; however, Outfall 101 is upstream of the final outfall. 

Calculating loads for Pollutant A at both the internal and final outfalls double-counting Pollutant 

A discharges. EPA identified instances where pollutant discharges are reported for multiple 

monitoring locations along the same discharge line and eliminated the discharges for the 

upstream monitoring locations. EPA made these corrections to the 2008 data in the DMR 

Loadings Tool. A complete list of these corrections made in the DMR Loadings Tool can be 

found in Table B-2 of Appendix B of this report. 

4.3.3 DMRLoads2008: Intermittent Discharges 

This section describes database corrections made for intermittent discharges in 

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

4-17

EPA, 2009), the DMR Loadings Tool assumes that all discharges in PCS and ICIS-NPDES are 

continuous (24 hours per day for all days in the monitoring period). During previous annual 

reviews, EPA identified facility discharges that are intermittent and therefore are overestimated 

by the DMR Loadings Tool. EPA calculated annual loads for these discharges based on 

information obtained from the facility on the frequency and duration of wastewater discharges. 

EPA made these corrections in the 2008 data in the DMR Loadings Tool. 

4.3.4 DMRLoads2008: Excluded Pollutant Parameters 

This section describes database corrections made to exclude selected water quality 

parameters and flow from the annual load calculation in 2008 DMR Loadings Tool. As described 

in Sections 3.2.1.3 and 3.2.3.2 of the 2009 SLA Report (U.S. EPA, 2009), facilities report 

pollutant mass quantities, pollutant concentrations, and wastewater flow rates to PCS and ICISNPDES using a variety of units. EPA’s PCS CNVRT program and the ICIS-NPDES Convert 

Module convert the discharges into standard units of kilograms per day (kg/day) for mass 

quantities, milligrams per liter (mg/L) for concentrations, and millions of gallons per day (MGD) 

for flow rates. However, some parameters are reported in units that cannot be converted into 

kg/day or mg/L (e.g., temperature, pH, fecal coliform, whole effluent toxicity). EPA excluded 

these parameters from the screening-level analysis. Table B-3 of Appendix B lists the excluded 

parameters. 

4.3.5 DMRLoads2008: Pollutant Corrections 

This section describes database changes made to discharges of specific pollutants 

reported to the DMR for EPA’s 2010 screening-level review in the 2008 DMR Loadings Tool. 

During the reasonableness checks of the PCS CNVRT output, EPA identified unusually 

high mercury concentrations reported to PCS by facilities located in Ohio in the PCS CNVRT 

output. These facilities reported mercury discharges using PRAM 50092 (Mercury Total Low 

Level). The PRAM 50092 concentrations in the 2004 CNVRT output ranged from 0.2 to 673 

mg/L from 0.001 to 380,000 mg/L in the 2008 CNVRT output. EPA contacted the Ohio 

Environmental Protection Agency (Ohio EPA) to determine the correct reporting units for 

PRAM 50092 (Stuhlfauth, 2007). An Ohio EPA representative explained that Ohio EPA started 

requiring low level mercury analyses in 2002. At that time, some facilities had limits in 

micrograms per liter (μg/L). Currently, all of the limits are in nanograms per liter (ng/L). 

As a result of this contact, EPA concluded that the units for the PRAM 50092 

concentrations for the 2004 PCS data should be ng/L, not mg/L. The PRAM 50092 

concentrations in the 2008 CNVRT output ranged from 0.001 to 380,000 mg/L with greater than 

98 percent of these concentrations between 0.1 and 1,000 mg/L. Based on this distribution, EPA 

concluded that the error for the 2004 data persisted in 2008. Therefore, EPA corrected the 

concentrations by dividing all concentrations for PRAM 50092 reported by facilities in Ohio in 

the DMR Pollutant Loadings Tool by one million. 

4.3.6 DMRLoads2008: Data Quality Review 

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

DMRLoads2008 as part of the 2010 screening-level review. This evaluation considered data 

completeness, accuracy, reasonableness, and comparability. The Quality Assurance Project Plan 
Section 4 – Methodology, Data Sources, and Limitations 

4-18

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

Data describe the quality objectives in more detail (ERG, 2009). EPA conducted quality reviews 

for three stages of the development of DMRLoads2008: 1) PCS CNVRT and ICIS-NPDES 

Convert Module outputs; 2) the 2008 DMR Loadings Tool output; and 3) DMRLoads2008

results. The following discussion provides an overview of the quality review steps for each stage: 

• PCS CNVRT and ICIS-NPDES Convert Module outputs. EPA conducted an 

initial quality review of the extracted PCS CNVRT and ICIS-NPDES DMR data 

to evaluate its completeness, reasonableness, and comparability. For 

completeness, EPA compared the number of major facilities and the universe of 

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

EPA reviewed the DMR data for reasonableness to identify any data quality 

issues, such as misreported units that the PCS CNVRT and ICIS-NPDES Convert 

Module did not correct. EPA identified several wastewater flows that exceeded 

the reasonable range. EPA reviewed these flows and developed the flow 

correction function for the PCS CNVRT and ICIS-NPDES Convert Module 

(described in Section 3.2.3 of the 2009 SLA Report (U.S. EPA, 2009)). This 

function is designed to identify data entry errors for flows greater than 1,000 

MGD. The PCS CNVRT and ICIS-NPDES Convert Module corrects all flows 

exceeding 5,000 MGD and applies more conservative criteria to correct flows 

from 1,000 to 5,000 MGD. The PCS CNVRT and ICIS-NPDES Convert Module 

made the following corrections to the PCS and ICIS-NPDES wastewater flows: 

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

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

— 470 corrections based on assuming that flows exceeding 5,000 MGD are 

reported in units of GPD. 

• Load Calculator routines. EPA’s quality review for the Load Calculator routines 

included accuracy checks for database queries on the 2008 data in the DMR 

Loadings Tool. EPA reviewed the programming code used to develop each query 

to verify the logic and verified that the number of records in the output table 

equaled the number of records in intermediate queries to ensure that no data were 

missing and that there were no duplicate data. In addition, EPA performed hand 

calculations to verify the accuracy of the Load Calculator module outputs during 

reviews of facility discharges for DMRLoads2008 results. 

• DMRLoads2008 results. EPA’s quality review of the DMRLoads2008 results 

included the following: 

— Completeness checks. EPA compared counts of dischargers in 

DMRLoads2008 to DMRLoads2007 to confirm the completeness of the 

database. There were 2,018 major discharging facilities that reported a 

load to DMRLoads2007 and 2,036 major discharging facilities that 

reported a load to DMRLoads2008. There were 14,888 minor discharging 

facilities that reported a load to DMRLoads2008; however, EPA did not 

include minor discharges in previous review. Therefore, EPA cannot 

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

4-19

— Accuracy of facility discharges. EPA reviewed the accuracy of facilities’ 

discharges that had the greatest impact on total category loads and 

category rankings to identify possible calculation errors. EPA reviewed 

monitoring period data in PCS and ICIS-NPDES, measurement data 

available on EPA’s Envirofacts web page, and information from each 

facility’s NPDES permit and permit fact sheet. In some cases, EPA 

contacted facilities to verify the measurements in their DMR. Section 

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

— Accuracy of category discharges. EPA reviewed the accuracy of category 

discharges by verifying that pollutant discharges in PCS and ICIS-NPDES 

were assigned to the appropriate point source category. EPA used 

engineering judgment to determine if the pollutant discharge was 

reasonably associated with the point source category. Section 4.3.1

discusses facility-level and pollutant-level category assignments. 

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

of DMRLoads2008 included accuracy checks for database queries in 

DMRLoadsAnalysis20086

 and DMRLoads2008. Documentation of 

accuracy checks is provided in a QC table in each Microsoft AccessTM 

database. 

— Reasonableness of pollutant loads. EPA reviewed the DMR Loadings 

Tool’s 2008 output (i.e., the calculated kg/year for each pollutant at each 

discharge pipe and monitoring location) for those pollutant discharges 

with the highest toxic-weighted loads (e.g., dioxins, polychlorinated 

biphenyls (PCBs), and mercury). To identify possible errors in recording 

units of measure, EPA identified calculated discharges that were orders of 

magnitude higher than previous years’ discharges or discharges from other 

facilities within the same category. EPA reviewed quantities or 

concentrations and flows that the DMR Loadings Tool database used to 

calculate the annual discharge. EPA compared these measurements with 

measurements available on EPA’s Envirofacts web page. If the 

measurements were similar, then EPA concluded that the output was 

acceptable. If the data did not match between the databases and 

Envirofacts, EPA corrected the data to match Envirofacts. When EPA was 

unsure what the correct data were, EPA contacted the facility or permitting 

authority for more information (see Section 4.3.7). 

— Reasonableness of facility loads. EPA identified facility discharges with 

the highest TWPE. EPA identified facilities for review whose pollutant 

discharges accounted for more than 95 percent of the TWPE for their point 

source category. EPA compared 2008 DMR data to other available 

 

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

Code classifications for certain facilities and certain discharges (i.e., OCSPF and Pesticide discharges). See Section 

3.2 of the 2009 SLA Report for further information (U.S. EPA, 2009). 
Section 4 – Methodology, Data Sources, and Limitations 

4-20

information, such as information from EPA’s Envirofacts web page, and 

the facility’s NPDES permit and permit fact sheet. If the data did not 

match between the database and Envirofacts, EPA corrected the data to 

match Envirofacts. When EPA was unsure what the correct data were, 

EPA contacted the facility or permitting authority for more information 

(see Section 4.3.7). 

— Comparability. EPA compared DMRLoads2008 to DMRLoads2007 to 

identify pollutant discharges or wastewater flows that differed more than 

the year-to-year variation of other chemicals and facilities. EPA used this 

comparison to determine if quantity, concentration, or flow corrections 

were needed for facility discharges with the highest TWPE. If the 

comparison was unavailable (e.g., the pollutant was not previously 

reported) EPA contacted the facility or permitting authority (see Section 

4.3.7). 

4.3.7 DMRLoads2008: Facility Reviews 

EPA reviewed the accuracy of facility discharges that had the greatest impact on total 

category loads and category rankings in DMRLoads2008. EPA reviewed facilities with the 

highest toxic-weighted discharges of individual pollutant parameters. For the identified facilities, 

EPA used the following steps to review the accuracy of the loads calculated from PCS and ICISNPDES data: 

1. Reviewed database corrections for DMRLoads2007, PCSLoads2004, 

PCSLoads2002, and PCSLoads2000 to determine whether corrections were made 

during previous reviews and evaluated whether EPA should apply these 

corrections to the 2008 DMR discharges. 

2. Reviewed 2008 DMR data, hand-calculated annual pollutant loads, and compared 

the results to loads calculated by the DMR Loading Tool and stored in 

DMRLoads2008. 

3. Reviewed PCS and ICIS-NPDES pipe description information available in PCS, 

EPA’s on-line Envirofacts data system, ICIS-NPDES supporting tables, or from 

the facility’s NPDES permit and permit fact sheet to identify monitored pollutant 

discharges that are: 

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

— Internal monitoring locations from which wastewater is combined with 

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

loads; and 

— Not representative of category discharges (e.g., stormwater runoff from 

nonprocess areas, noncontact cooling water, or wastewater related to 

operations in another point source category). 

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

database. 
Section 4 – Methodology, Data 

4-21 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

Monongahela Power Company 

Willow Island, WV 

Steam Electric Power Generating 

Chlorine Outfall 001 free chlorine Jul 2008 

concentration is 1,000 times higher than other monthly concentrations. Outfall 001 total residual chlorine Sept and Oct 2008 concentrations were in mg/L in the DMR Loadings Tool, while Envirofacts concentrations are in ug/L. 

Revise Sept anchlorine dividing 

Fulton County Commissioners 

OH Sanitary Low Level 

Mercury 

Outfall 001 low level mercury Sept 2008 concentration in the DMR Loadings Tool is 1,000,000 times higher than the concentrations reported in Envirofacts. 

Revise concent1,000,0reportindays to 

General Electric – Erie Erie, PA Metal Finishing Mercury Outfall 001 mercury 2008 

concentration in the DMR Loadings Tool is 1,000,000 times higher than the 2007 concentration that EPA corrected as a result of facility-provided information. 

Revise concent1,000,0

Ohio Valley Coal Company 

Washington TWP, OH 

Coal Mining Selenium Outfall 001 selenium Dec 2008 

concentration in the DMR Loadings Tool is 1,000,000 times higher than other monthly concentrations. 

Revise concent1,000,0reportindays to reportin
Section 4 – Methodology, Data 

4-22 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

TX Eastern TransGladeville Gladeville, TN Electric & Gas PCBs Outfall 002 PCB Jan 2008 concentration in the DMR 

Loadings Tool is 1,000 times higher than other monthly concentrations. Envirofacts units for Jan 2008 are μg/L, not mg/L. 

Revise concent1,000. 

Village of Elida Elida, OH Nonclassifiable Low Level 

Mercury 

Outfall 001 low level mercury Jun, Aug, and Sept 2008 concentrations are in the DMR Loadings Tool as mg/L, while the concentrations in Envirofacts are in ng/L. 

Revise low levby dividnumber number quarterl

Clemson University WWTF 

Clemson, SC Education Total Mercury Outfall 001 Mar, Jun, Sept 2008 

total mercury concentrations in the DMR Loadings Tool do not match the concentrations in Envirofacts. 

Revise concentnumber number quarterl

Carbon Limestone Landfill OH Landfills Low Level 

Mercury 

Outfall 001 low level mercury Jan and Dec 2008 concentrations are in the DMR Loadings Tool as mg/L, while concentrations in Envirofacts are in ng/L. 

Revise mercury dividing 

Tysons Foods, Inc. Carthage, MS Meat and Poultry 

Products 

Mercury Facility contact identified that the 

2008 total recoverable mercury concentrations for outfall 001 were reported as ng/L but were in the DMR Loadings Tool as mg/L (Lovitt, 2010). 

Revise dividing mercury concent
Section 4 – Methodology, Data 

4-23 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

AKZO Nobel Functional Chemical 

Axis, AL Inorganic 

Chemicals 

Total Mercury Outfall 006 Dec 2008 total 

mercury concentration is 1,000 times higher than other concentrations in the DMR Loadings Tool. Facility contact confirmed that the Dec 2008 total mercury concentration was reported in μg/L, but was in the DMR Loadings Tool as mg/L (Williams, 2010). 

Revise concent1,000. 

Arcelormittal Weirton, Inc. 

Weirton, WV Iron and Steel Cyanide Outfall 003 Aug 2008 cyanide 

concentration in the DMR Loadings Tool is 1,000 times higher than other monthly concentrations. 

Revise concent1,000. 

USEC PDGDP McCracken, KY Nonferrous Metals 

Manufacturing 

PCBs Facility contact verified the 2008 

PCB concentrations in the DMR Loadings Tool and indicated that the outfalls are for stormwater runoff. The PCBs are due to legacy activity at the site, and the facility treats all process water that may have PCBs using carbon adsorption (Travis, 2010). 

No actio

Cargill Corn Milling (Progold)

Wahpeton, ND Grain Mills Chloride Outfall 001 Jan 2008 chloride 

concentration is 10,000 times higher than other monthly concentrations in the DMR Loadings Tool. Also, Jan 2008 average concentration reported is 10,000 higher than the maximum concentration. 

Revise concent10,000. 

Marathon Oil – Maverick Springs 

Fremont County, WY 

Oil & Gas Extraction 

Sulfur 2008 sulfide concentrations are 

comparable to 2007 and 2009 concentrations. 

No actio
Section 4 – Methodology, Data 

4-24 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

Smithfield Packing Co Inc Tar Heel, NC Meat and Poultry 

Products 

Chlorine Outfall 001 Apr through Sept 

2008 chlorine concentrations are in the DMR Loadings Tool as mg/L, while the concentrations in Envirofacts are in μg/L. 

Revise chlorine dividing 

Clear Lakes Trout Company 

Buhl, ID Concentrated 

Aquatic Animal Production 

Copper Outfall 001 Jan 2008 copper 

concentration is 9 mg/L, but all other months are No Data Indicator (NODI) 9 in the DMR Loadings Tool. Facility contact verified that the copper Jan 2008 concentration was a data entry error (Bogaard, 2010). 

Delete Jconcentcode to 

Hercules, Incorporated Brunswick, GA Gum and Wood Toxaphene Facility contact stated that the 

outfall 001 2008 toxaphene concentrations were reversed with the total suspended solids (TSS) concentrations. Facility contact stated that the toxaphene concentrations are all below detection limit (BDL) (Bernarack, 2010). 

Reverse concentconcentindicatoconcent

Valley View Landfill Trimble County, 

KY 

Landfills Mercury Outfall 001 Jun 2008 and outfall 

004 Mar 2008 mercury concentrations were high compared to the other concentrations reported. Facility contact stated that the concentrations for both outfalls should be reported as nondetect. The contact also stated that the concentration value should be 0.0002, not 40 (Knarr, 2010). 

Revise outfall 0concentand add mercury 
Section 4 – Methodology, Data 

4-25 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

Former Koppers Facility Kansas City, MO Timber TCDD Facility contact confirmed that all 

outfall 004 and 005 2008 TCDD concentrations were all nondetect (Rayna, 2010). Number of days and number of reporting units did not match reported concentrations. 

Add BDTCDD outfalls number number 

EI DuPont De Nemours & Co 

Washington, WV OCPSF Hexachlorobenzene Outfall 002, 005, and 102 2008 hexachlorobenzene concentrations 

are reported as the same concentration for all months. Therefore, assumed that all the concentrations should be nondetect. 

Add BDhexachlconcent005, an

Eastman Chemicals/SC Operations 

Saint Matthews, SC 

OCPSF Mercury Outfall 001 Jan 2008 mercury 

concentrations has a leading (i.e., prior to the decimal place) 4 in the DMR Loadings Tool, while Envirofacts has a leading 0. 

Revise concentthe lead

Galey & Lord/Society Hill Society Hill, SC Textile mills Mercury Outfall 001 2008 total mercury 

concentration has a leading (i.e., prior to the decimal place) 4 in the DMR Loadings Tool, while Envirofacts has leading 0. 

Revise concentthe lead

Wyeth Research Chazy, NY Labs Mercury Outfall 001 Jul 2008 mercury 

quantity in the DMR Loadings Tool does not match the quantity calculated using the concentration and flow or data in Envirofacts. EPA used the concentration and flow to calculate the correct quantity. 

Revise quantity
Section 4 – Methodology, Data 

4-26 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

Bridgeport Water Plant Bridgeport, OH Drinking Water Manganese Outfall 002 Feb, Apr, and Nov 

2008 manganese quantities in the DMR Loadings Tool do not match quantities calculated using the concentration and flow or the data reported in Envirofacts. EPA used the concentration and flow to calculate the correct quantity. 

Revise quantity in Envir

Koppers Industries Inc Follansbee, WV OCPSF Hexachlorobenzene Outfall 101 Feb 2008 hexachlorobenzene quantities in 

the DMR Loadings Tool do not match data reported in Envirofacts. 

Revise quantity

ASA Ethanol Bloomingburg, LLC 

OH OCSPF Iron, Fluoride Outfall 001 Mar and Apr 2008 

fluoride quantities are 1,000,000 times higher than the calculated quantities using the concentrations and flows in the DMR Loadings Tool. Iron quantities for May and Aug through Dec 2008 have a leading (i.e., prior to the decimal place) 4 in the DMR Loadings Tool, while Envirofacts has leading 0. 

Revise fluoride 1,000,0through to remo

Special Metals Corp New Hartford, NY Nonferrous metals 

manufacturing 

PCB-1254 Outfall 001 PCB-1254 quantity 

are 1,000 times higher than when the quantity is calculated using the concentration and flow in the DMR Loadings Tool. All concentrations were also reported as non-detect in the DMR Loadings Tool. 

Revise match qconcentadd BDquantiti
Section 4 – Methodology, Data 

4-27 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

Smith’s Pleasant Valley OH Nonclassifiable Chlorine Outfall 001 Jun, Aug, and Oct 

2008 flows are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise flows foby 1,00

Bulk Plant Inc Flemingsbrg #39 

Fleming County, KY 

Petroleum Refining 

Benzene Outfall 001 flows for Mar, Jun, 

and Sept 2008 are extremely high (between 4,000 and 30,000 MGD). Flows should be reported as GPD, not MGD. 

Revise for Outf1,000,0

Pelican Grove Campground 

OH Hotels & Other 

Lodging Places 

Chlorine Outfall 001 flows for 2008 are in 

the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise dividing 

SPARTA Water Treatment Plant 

Sparta, TN Drinking Water 

Treatment 

Chlorine Outfall 001 flows for Jan through 

Jul 2008 are not consistent with other months, or the data reported in Envirofacts for 2009. 

Revise flows foby 1,00

CAPPS Tavern OH Food Service 

Establishments 

Chlorine Outfall 001 flows for 2008, 

excluding Jan and Oct, are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise Oct, for by 1,00

Saint Ilija Macadonian Church 

OH Membership 

Organizations 

Chlorine Outfall 001 flows for 2008 are in 

the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise dividing 

Contech U.S. LLC Pierceton, IN Wholesale TradeDurable Goods Lead Outfall 001 flow for Feb 2008 is reported in the DMR Loadings 

Tool as MGD, while other flows in the DMR Loadings Tool are reported as GPD. 

Revise Outfall 1,000,0
Section 4 – Methodology, Data 

4-28 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

Norbet Fun Family Bowling 

OH Amusement & 

Recreation Services 

Chlorine Outfall 001 flows for 2008, 

excluding Jan and Apr, are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise Apr, for by 1,00

SAKAS, Inc. OH Metal Finishing Chlorine Outfall 001 flows for 2008 are in 

the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise dividing 

Dowel Town-Liberty WTP Liberty, TN Drinking Water 

Treatment 

Aluminum Outfall 001 flows for Jan, Mar, 

and May 2008 are 1,000,000 times higher than other reported flows and the design flow. 

Revise (Jan, Mdividing 

Speedway Super America LLC 

OH Automotive 

Dealers & Service Stations 

Chlorine Outfall 001 flows for 2008, 

excluding Jul, are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise Outfall 1,000,0

Le-O-Na Falls Mobile Home Park 

OH Real Estate Chlorine Outfall 001 flows for 2008, 

excluding Jul, are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise Outfall 1,000,0

MSAD #9 Farmington, ME Education Chlorine Outfall 001 flows for 2008, except 

Sept and Oct, are in the DMR Loadings Tool as MGD, while flows in Envirofacts are reported as GPD. 

Revise Oct, for by 1,00

MSAD #52 Turner, ME Education Chlorine Outfall 001 flows for 2008, except 

Jun through Aug, are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise Aug, foby 1,00
Section 4 – Methodology, Data 

4-29 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

MEAD Depot Landfill OH Waste Combustors Manganese Outfall 001 flows for Aug through 

Dec 2008 and Outfall 002 flows for Jan and Mar through Aug 2008 are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise Outfall dividing 

Charm Countryview Inn, Inc. 

OH Food Service Chlorine Outfall 001 flows for Feb through 

Oct 2008 are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise 2008 foby 1,00

Korner Kitchen OH Food Service Chlorine Outfall 001 flows for Feb through 

Dec 2008 are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise Dec 200dividing 

Envirosystems Incorporated 

Hampton, NH Independent and 

Stand Alone Labs 

Cadmium Outfall 002 flows for Sept and Oct 

2008 (DRIDs A and B) were 1,000,000 times higher than other months reported and the permit design flow is 400 GPD (U.S. EPA Region 1, 2006). 

Revise for Outf1,000,0

Bullitt Co Landfill Bullitt County, 

KY 

Landfills Iron Outfall 001 flows for Jan, July, 

and October 2008 were 1,000,000 times higher than other flows reported. KY DEP Permit Manager indicated that flows for Jan, July, and October 2008 were reported as GPD, not MGD. Also noted that the facility was a municipal waste landfill (Becker, 2010). 

Revise October change Landfil

Stevens Aviation, Inc. Vandalia, OH Wholesale TradeNondurable Goods Lead Outfall 001 flow for Aug 2008 is in the DMR Loadings Tool as 

MGD, while flow in Envirofacts is in GPD. 

Revise Outfall 1,000,0
Section 4 – Methodology, Data 

4-30 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

Reed Duplex Apt BLDG Madison County, 

KY 

Real Estate Chlorine Outfall 001 flow for Sept 2008 

was high compared to other flows. KY DEP Permit Manager indicated permit design flow is 0.001 MGD and that the facility reported incorrect units (MGD instead of GPD) (Becker, 2010). 

Revise Outfall 1,000,0

Deborah K. Schiemann OH Social Services Chlorine Outfall 001 flows for May through 

Oct 2008 are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise Oct 200dividing 

John W Black Aquatic Center 

Oldham County, KY 

Amusement & Recreation Services 

Chlorine Outfall 001 flows for May through 

Sept 2008 are all reported in the Loadings Tool as MGD, but assumed were reported as GPD because of the nature of the facility (aquatic center). 

Revise Sept 20dividing 

Sugar Grove Bible Church OH Membership 

Organizations 

Chlorine Outfall 001 flows for 2008 are in 

the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise dividing 

Wullenweber Motors OH Wholesale TradeDurable Goods Chlorine Outfall 001 flows for Jan through May, July, Aug, and Dec 2008 are 

in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise flow un001 by 

Cognis Corporation OH OCPSF Copper Outfall 010 flows for Oct 2008 

and outfall 033 flows for May, Aug, Nov 2008 are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise 010 and 1,000,0
Section 4 – Methodology, Data 

4-31 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

Holiday Motel WWTF Cleveland, TX Hotels & Other 

Lodging Places 

Chlorine Outfall 001 flows for Feb, Jun, 

and Oct 2008 are 1,000,000 times higher than flows reported for the other months. 

Revise Oct for by 1,00

A.P. Green Refractories , Co. 

Oak Hill, OH Mineral Mining Chlorine Outfall 001 flows for 2008, 

excluding Feb, are in the DMR Loadings Tool as MGD, while flows in Envirofacts are reported as GPD. 

Revise Outfall 1,000,0

Sebasco Harbor Resort LLC 

Phippsburg, ME Hotels Chlorine Outfall 002 flows for May through 

Oct 2008 are in the DMR Loadings Tool as MGD, while flows in Envirofacts are GPD. 

Revise Oct 200dividing 

Newagen Seaside Inn Southport, ME Hotels Chlorine Outfall 001 flows for Jun through 

Sept 2008 are in the DMR Loadings Tool as MGD, while flows in Envirofacts are GPD (auto-corrected by the DMR Loadings Tool). 

Revise flows foby 1,00

US Dept of the Interior Winter Harbor, 

ME 

National Security & International Affairs 

Chlorine Outfall 001 flows for May and Jun 

2008 are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise 2008for by 1,00

Engineered Coil Company High Ridge, MO Metal Finishing Copper Outfall 002 flows for Nov 2008 

are in the DMR Loadings Tool as MGD, while flows in Envirofacts are in GPD. 

Revise Outfall 1,000,0
Section 4 – Methodology, Data 

4-32 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

Harbison-Walker Refractor 

Vanalia, OH Mineral Mining 

and Processing 

Aluminum Outfall 001 flows for Mar, Jun, 

and Sept 2008, are not consistent with other months or the design flow of 230 MGD. The facility permit stated that the flows are based on precipitation; however, the units are suspected to be incorrect (State of Missouri, 2005). 

Revise flows foby 1,00

Hamilton Water Treatment Plant 

Hamilton, AL Drinking Water 

Treatment 

Aluminum Outfall 001 flows for 2008, 

excluding Feb, are 1,000 times higher than corrected flows from 2007. 

Revise by divid

Cook’s Hams, Inc. Lincoln, NE Meat and Poultry 

Products 

Sulfur Outfall 001 flow for Jun 2008 is 

1,000 times higher than all other months, the maximum daily flow for Jun 2008, and the permit design flow (0.069 MGD). 

Revise 001 by 

PRASA WTP Miradero Filter PLT 

Mayaguez, PR Drinking Water 

Treatment 

Chlorine Outfall 001 flow for May 2008 

was 1,000 times higher than the flows reported for other months. Suspect units error during data entry. 

Revise Outfall 

PRASA WTP Sergio Cuevas 

Trujillo Alto, PR Drinking Water 

Treatment 

Chlorine Outfall 001 flows for May and 

Aug 2008 are 1,000 times higher than other monthly flows. 

Revise for Outfby 1,00

National Copper and Smelting 

Huntsville, AL Copper forming Zinc Outfall 002 flows for Jul through 

Nov 2008 were 1,000 times higher than other reported monthly flows. Also, zinc concentrations reported for July through Sept 2008 for Outfall 002 were 1,000 times higher than other monthly concentrations. 

Revise 2008 foflows bconcentSept 20concent
Section 4 – Methodology, Data 

4-33 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

Bayview Detention CTR WWTF 

Los Fresnos, TX Justice, Public 

Order, & Safety 

Chlorine Outfall 001 flows for 2008 

reported to the DMR Loadings Tool did not match the Envirofacts data. TCEQ contact indicated that the facility is a POTW and the flow permit limit is 0.16 MGD. 

Revise dividing change POTWs

KODAK Colorado Division 

Windsor, CO Metal Finishing Silver Outfall 006 flow is not consistent 

with other flows reported for the facility in 2008. Facility contact stated that the average flow for Outfall 006 is about 150 L/day (0.000039 MGD) (Peterson, 2010). 

Replace 

Catskill State Fish Hatchery 

Livingston Manor, NY 

Concentrated Aquatic Animal Production 

Formaldehyde Outfall 001 flows for 2008 were 

extremely high. NYSDEC contact verified that flows for all months were reported in GPM, not MGD, based on discussions with the facility (Sansalone, 2010). 

Databasfor Outf694. 

SEAPAC of Idaho, Inc. Hagerman, ID Concentrated 

Aquatic Animal Production 

Copper Outfall 001 flows and outfall OSB 

flows for 2008 were reported with the incorrect units (unknown) in the DMR Loadings Tool when compared to Envirofacts (cubic feet per second (CFS) with different values). 

Databasfor Outfdividing 

Upshur Property, Inc. Tallmansville, 

WV 

Coal Mining Selenium Outfalls 001, 002, and 004 flows 

are in the DMR Loadings Tool as MGD, while Envirofacts flows are in GPM. Outfall 402 flows are in the DMR Loadings Tool as MGD while Envirofacts flows are in CFS. 

Databasfor OutfGPM to 694. Refrom CFby 1.55
Section 4 – Methodology, Data 

4-34 

Table 4-5. Summary of DMRLoads2008 Facility Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

D

US Steel Corp – Mon Valley Works - Edgar Thomson 

Braddock, PA Iron and Steel Iron Facility contact identified that the 

facility measures pollutant concentrations in their stormwater prior to commingling with noncontact cooling water. EPA developed a flow factor using the 2004 data, to determine the amount of stormwater in the total outfall flow for more accurate load estimates (Belack, 2007). 

Databasfor Outf009 by 
Section 4 – Methodology, Data Sources, and Limitations 

4-35

4.4 Corrections to the TRIReleases2008 Database

EPA developed the TRIReleases2008 database as part of the 2010 annual review using 

the methodology explained in the 2009 SLA Report (U.S. EPA, 2009) with the methodology 

updates described in Section 4.2.2. 

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

corrections for TRI data reported for calendar years 2002 through 2007. Several of these 

corrections similarly apply to the 2008 TRI data. In addition, EPA reviewed the quality of the 

2008 TRI data for facilities with discharges that have the greatest impact on total category loads 

and category rankings. Table B-1 in Appendix B of this report lists all corrections made to the 

2008 TRI data. 

4.4.1 TRIReleases2008: Categorization of Discharges 

This section describes database corrections to categorization of facilities and pollutant 

discharges in TRIReleases2008. Section 4 of the 2009 SLA Report describes the development of 

the NAICS/Point Source Category Crosswalk, which EPA uses to link between facility NAICS 

codes and categories with existing ELGs (U.S. EPA, 2009). Because most point source 

categories are not defined by NAICS code, the relationship between NAICS code and point 

source category is not a one-to-one correlation. A single NAICS code may include facilities in 

more than one point source category, and associating an NAICS code with only one category 

may be an oversimplification. Also, many facilities have operations subject to more than one 

point source category. Further, facilities in some categories report a variety of NAICS codes that 

do not correlate directly to a point source category, precluding identification by NAICS code 

(e.g., Centralized Waste Treatment facilities). Section 5 of the 2009 SLA Report describes the 

database changes, summarized below (U.S. EPA, 2009): 

• Facility-Level Point Source Category Assignment. For some NAICS codes that 

include facilities subject to guidelines from more than one point source category, 

EPA was able to assign each facility to the category that best applied to the 

majority of its discharges. EPA reviewed information available about each facility 

to determine which point source category applied to the facility’s operations. 

• Pollutant-Level Point Source Category Assignment. Many facilities have 

operations subject to more than one point source category. For most of these 

facilities, EPA cannot divide the pollutant discharges among the applicable point 

source categories. Below are two exceptions where EPA was able to assign 

wastewater discharges of certain chemicals to the appropriate point source 

category: 

— OCPSF/Pesticide Chemicals. EPA removed all pesticide discharges from 

the OCPSF Category and included them as discharges from the Pesticide 

Chemicals Category. 

— MP&M/Metal Finishing. EPA used the methodologies described in 

Section 4 of the 2009 SLA Report to apportion pollutant loads between the 

MP&M and Metal Finishing Categories. 
Section 4 – Methodology, Data Sources, and Limitations 

4-36

• Categories Not Identified by NAICS Code (e.g., Centralized Waste Treatment, 

Waste Combustor, and Landfills). The NAICS/Point Source Category Crosswalk 

does not assign any NAICS codes to the Centralized Waste Treatment (CWT) 

Point Source Category (40 CFR Part 437), Waste Combustor Point Source 

Category (30 CFR Part 444), or Landfills Category (40 CFR Part 445). 

Furthermore, the applicability of these three regulations is not defined by NAICS 

codes and no NAICS code properly describes the CWT, waste combustor, or 

landfill services. Currently, EPA assigns all facilities reporting NAICS code 

562213 (Solid Waste Combustors and Incinerators) as part of the Waste 

Combustor Category. The remaining facilities, with NAICS codes 562211 

(Hazardous Waste Treatment and Disposal) and 562219 (Other Nonhazardous 

Waste Treatment and Disposal), are included in all three categories, which over 

estimates the category loads. During previous annual reviews, EPA has identified 

certain facilities that should be categorized as a CWT, waste combustor, or 

landfill. EPA assigned these facilities to the correct industrial category. As 

facilities continue to be reviewed due to high TWPE, EPA classifies them into the 

correct industrial category based on facility operations. 

4.4.2 TRIReleases2008: Pollutant Corrections 

This section describes database corrections made to discharges of specific pollutants 

reported to the TRI for EPA’s 2010 screening-level review in the TRIReleases2008 database. 

• Metal Compounds. For TRI reporting, facilities may be required to report 

discharges of a metal (e.g., zinc) and its compounds (e.g., zinc compounds) on a 

single reporting form. Because the release quantity for the metal compound 

reporting is based on the mass of the parent metal, EPA uses the parent metal 

TWF to calculate TWPE for the metal and metal compound discharges. For 

ranking purposes, EPA combined the TWPEs for the metal and metal compounds 

(i.e., TWPE reported for “zinc and zinc compounds”). For more details on this 

correction, see Section 3.4.4 of the 2009 SLA Report (U.S. EPA, 2009). 

• Sodium Nitrite. For TRI reporting, sodium nitrite release quantities are reported as 

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

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

ions are unstable in water and will oxidize to nitrate. Therefore, EPA converted 

the pounds of TRI-reported sodium nitrite discharges to pounds of nitrogen in the 

discharge and used the TWF for “nitrate as N” (0.0032) to calculate TWPE for 

sodium nitrite. In addition, EPA also used the POTW removal for nitrate to 

account for the removal of sodium nitrite in POTWs. 

• Phosphorus (Yellow or White). Yellow and white phosphorus, both allotropes of 

elemental phosphorus, are hazardous chemicals that spontaneously ignite in air. 

During the 2006 screening-level review, EPA determined that facilities were 

incorrectly reporting discharges of total phosphorus (i.e., the phosphorus portion 

of phosphorus-containing compounds) as phosphorus (yellow or white) (U.S. 

EPA, 2006a). Therefore, EPA deleted all phosphorus (yellow or white) discharges 

reported to TRI for the 2010 screening-level review. 
Section 4 – Methodology, Data Sources, and Limitations 

4-37

4.4.3 TRIReleases2008: Data Quality Review 

EPA evaluated the quality of TRI data for use in the 2010 screening-level review and 

prioritization of loadings of toxic and nonconventional pollutants discharged by industrial 

categories based on completeness, accuracy, reasonableness, and comparability. The Quality 

Assurance Project Plan for the 2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and 

PCS Industrial Category Discharge Data describes the quality objectives in more detail (ERG, 

2009). The following discussion provides an overview of the quality review steps: 

• Completeness Checks. EPA compared counts of facilities in TRIReleases2008 to 

TRIReleases2007, TRIReleases2005, TRIReleases2004, TRIReleases2003,

TRIReleases2002, and TRIReleases2000 to describe the completeness of the 

database. The comparison showed that for 72 percent of the point source 

categories or NAICS code groupings, the number of facilities reporting 

wastewater discharges changed by less than 25 percent from 2007 to 2008. EPA 

also determined that most NAICS codes exhibiting a large percentage change did 

so because only a few facilities in these NAIC codes reported discharges (e.g., a 

change from one facility to three facilities is equivalent to a 200 percent increase). 

• Accuracy of Facility Discharges. EPA reviewed the accuracy of facilities’ 

discharges that had the greatest impact on total category loads and category 

rankings. EPA identified facilities for review whose pollutant discharges 

accounted for more than 95 percent of the TWPE for their point source category. 

EPA compared 2008 TRI data to other available information, such as PCS and 

ICIS-NPDES, information from EPA’s Envirofacts web page, the facilities’ 

NPDES permits and permit fact sheets, and discussion with facility contacts. 

• Accuracy of Category Discharges. EPA reviewed the accuracy of category 

discharges by verifying that pollutant discharges in TRI were assigned to the 

appropriate point source category. EPA used engineering judgment to determine 

if pollutant discharges were reasonably associated with the point source category. 

• Accuracy of Database Queries. EPA’s quality review for the development of 

TRIReleases2008 included accuracy checks for database queries in 

TRICalculations20087

 and TRIReleases2008. Documentation of accuracy checks 

is provided in a QC table in each Microsoft AccessTM database. 

• Comparability. EPA compared TRIReleases2008 to TRIRelease2007, 

TRIReleases2005, TRIReleases2004, TRIReleases2003, TRIReleases2002, and 

TRIReleases2000 to identify pollutant discharges that differ more than the yearto-year variation of other chemicals and facilities. From the comparison, EPA 

determined that 42 percent of the pollutants discharged in both 2008 and 2007 had 

a change of less than 50 percent in the quantity discharged. EPA also determined 

that most of the pollutants with a large percentage change reflected initial 

discharges of small quantities. In addition, most of these pollutant discharges 

resulted in small TWPEs. 

 

7 TRICalculations2008 is a database EPA created to analyze raw TRI data. See Section 2.4 of the 2009 SLA Report 

for more detailed information (U.S. EPA, 2009). 
Section 4 – Methodology, Data Sources, and Limitations 

4-38

4.4.4 TRIReleases2008: Facility Reviews 

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

TRIReleases2008 database. EPA reviewed the accuracy of calculated discharges from facilities 

with discharges that have the greatest impact on total category loads and category rankings. EPA 

used the following criteria to select facilities for review: 

• Facilities with the highest toxic-weighted discharges of all facilities reporting to 

TRI for reporting year 2008; 

• Facilities with the highest toxic-weighted discharges of individual chemicals that 

contribute the majority of the toxic-weighted discharges for all categories; and 

• Facilities with the highest toxic-weighted discharges from categories that 

contribute the majority of the toxic-weighted discharges for all categories. 

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

loads calculated from TRI data. 

1. Review database corrections for TRIReleases2007, TRIReleases2005, 

TRIReleases2004, TRIReleases2003, TRIReleases2002, and TRIReleases2000 to 

determine whether corrections were made during previous reviews and evaluate 

whether these corrections should be applied to TRIReleases2008. 

2. Review discharges reported to TRI for other reporting years (i.e., 2000, 2002, 

2003, 2004, 2005, and 2007) and compare to discharges reported to TRI for 

reporting year 2008. 

3. Review 2008 DMR data in PCS and ICIS-NPDES, if available, to hand-calculate 

annual pollutant loads and compare to discharges reported to TRI for reporting 

year 2008. 

4. Contact the facility to verify whether the pollutant discharges are reported 

correctly. 
Section 4 – Methodology, Data 

4-39

Table 4-6. Summary of TRIReleases2008 Facility Review 

Facility Name Facility Location

Point Source 

Category 

Pollutant(s) in 

Question Review Findings 

Act

Carolina Pole Leland Leland, NC Timber Dioxin Compounds Facility did not recognize the 

dioxin distribution numbering change for the 2008 reporting year. Facility contact stated that the reported grams of dioxin are based on monitoring data – some congeners were detected in 2008 but all were BDL in 2009. Facility provided sampling data that indicated that the dioxin distribution was based on the TRI 2007 distribution numbering (House, 2010). 

Revise d

Clean Harbors Deer Park, LP 

La Porte, TX Waste 

Combustors 

Benzidene Reviewed benzidine DMR data in 

the DMR Loadings Tool and determined that all 2008 discharges were 0 mg/L. 

Revise b

DuPont Chambers Works Deepwater, NJ OCPSF Hexachlorobenzene, 

PACs 

Facility contact indicated that hexachlorobenzene loads were calculated using half the detection limit. Facility contact confirmed that hexachlorobenzene and PACs were never detected at the facility (Northey, 2007). 

Revise hPACs lo

DuPont Chemicals – Starke Facility 

Starke, FL Ore Mining Dioxin Compounds Facility did not recognize the 

dioxin distribution numbering change for the 2008 reporting year. Facility contact confirmed that the dioxin distribution was incorrect. Facility provided facility-specific distribution (Wood, 2010). 

Revise 
Section 4 – Methodology, Data 

4-40

Table 4-6. Summary of TRIReleases2008 Facility Review 

Facility Name Facility Location

Point Source 

Category 

Pollutant(s) in 

Question Review Findings 

Act

DuPont Delisle Plant Pass Christian, 

MS 

Inorganic Chemicals 

Dioxin Compounds Facility did not recognize the 

dioxin distribution numbering change for the 2008 reporting year. Facility contact confirmed that the dioxin distribution was incorrect. Facility provided facility-specific distribution (Wood, 2010). 

Revise 

DuPont Edge Moor Edgemoor, DE Inorganic 

Chemicals 

Dioxin Compounds Facility did not recognize the 

dioxin distribution numbering change for the 2008 reporting year. Facility contact confirmed that the dioxin distribution was incorrect. Facility provided facility-specific distribution (Wood, 2010). 

Revise d

DuPont Johnsonville Plant New Johnsonville, 

TN 

Inorganic Chemicals 

Dioxin Compounds Facility did not recognize the 

dioxin distribution numbering change for the 2008 reporting year. Facility contact confirmed that the dioxin distribution was incorrect. Facility provided facility-specific distribution (Wood, 2010). 

Revise d

ExxonMobil Chemical Baton Rouge Chemical Plant 

Baton Rouge, LA OCPSF PACs Facility contact confirmed that the 

pounds released were based on half the detection limit and that PACs were never detected at the facility (Fellows, 2003). 

Revise P

ExxonMobil Oil Corp Joliet Refinery 

Channahon, IL Petroleum 

Refining 

Hexachlorobenzene Facility contact confirmed that the 

pounds released were based on half the detection limit. Contact did not recall any previous years where hexachlorobenzene was detected (Noga, 2010). 

Revise hto zero. 
Section 4 – Methodology, Data 

4-41

Table 4-6. Summary of TRIReleases2008 Facility Review 

Facility Name Facility Location

Point Source 

Category 

Pollutant(s) in 

Question Review Findings 

Act

Formosa Plastics Corporation Louisiana 

Baton Rouge, LA CCH Dioxin Compounds Facility did not recognize the 

dioxin distribution numbering change for the 2008 reporting year. Dioxin distribution reported in 2008 is similar to 2003 distribution (using previous reporting years’ numbering scheme). 

Revise 

Formosa Plastics Corporation Texas 

Point Comfort, TX 

CCH Dioxin Compounds Facility did not recognize the 

dioxin distribution numbering change for the 2008 reporting year. Dioxin distribution reported in 2008 is similar to 2003 distribution (using previous reporting years’ numbering scheme). 

Revise 

Graftech International Holdings, Inc. 

Columbia, TN Carbon Black 

Manufacturing 

PACs Facility contact provided PACs 

sampling data. Facility reviewed the monitoring data and determined they overestimated the PAC discharges (1091.23 pounds). Facility contact said they should have reported discharges as 246 pounds of PACs. The monitoring results also provided a distribution for the PAC compounds to create a facilityspecific TWF (Aslinger, 2010). 

Revise Pfrom 1,0TWPE uTWF. 

H. Kramer & Co. Chicago, IL Nonferrous 

Metals Manufacturing 

Phosphorous (Yellow or White) 

Elemental phosphorus is not likely to be discharged by facilities, and is likely reported incorrectly. 

Revise pwhite) l
Section 4 – Methodology, Data 

4-42

Table 4-6. Summary of TRIReleases2008 Facility Review 

Facility Name Facility Location

Point Source 

Category 

Pollutant(s) in 

Question Review Findings 

Act

John Morrell & Co. Sioux Falls, SD Meat and 

Poultry 

Mercury Facility contact confirmed that 

mercury discharges are estimated based on metals testing performed for the city discharge. Contact stated that all mercury samples were BDL (Draveland, 2010). 

Revise m

Lima Refining Co. Lima, OH Petroleum 

Refining 

Phosphorous (Yellow or White) 

Elemental phosphorus is not likely to be discharged by facilities and is likely reported incorrectly. 

Revise pwhite) l

Louisiana Pigment Co L.P. Westlake, LA Inorganic 

Chemicals 

Dioxin Compounds Facility did not provide a water 

congener distribution for 2008. Use facility provided distribution from 2007 (Kashyap, 2009). 

Revise d

Occidental Chemical Corp Columbia, TN Inorganic 

Chemicals 

Phosphorous (Yellow or White) 

Elemental phosphorus is not likely to be discharged by facilities, and is likely reported incorrectly. 

Revise pwhite) l

PCS Nitrogen Fertilizer LP Augusta, GA Fertilizer 

Manufacturing 

Dioxin Compounds Facility did not recognize the 

dioxin distribution numbering change for the 2008 reporting year. Dioxin distribution reported in 2008 is similar to 2005 distribution (using previous reporting years’ numbering scheme). 

Revise d

U.S. Army Pine Bluff Arsenal 

Pine Bluff, AR National 

Security & International Affairs 

Phosphorous (Yellow or White) 

Elemental phosphorus is not likely to be discharged by facilities and is likely reported incorrectly. 

Revise pwhite) l
Section 4 – Methodology, Data Sources, and Limitations 

4-43

4.4.5 Trends in TRI Data 

EPA has identified a consistent decrease every year since 2002 in the total number of 

facilities reporting to TRI. EPA also identified a consistent decrease in the number of facilities 

reporting discharges to TRI from 2002 to 2007. However, the number of facilities reporting 

discharges to TRI increased from 2007 to 2008. Table 4-7 illustrates the trends since 2002. 

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

Reporting Year 

Number of Facilities Reporting to 

TRI 

Number of Facilities Reporting 

Discharges to TRI 

2002 24,379 8,291 

2003 23,811 8,051 

2004 23,675 7,930 

2005 23,461 7,837 

2006 22,880 7,506 

2007 21,965 6,572 

2008 21,694 6,891 

Source: TRIReleases2002; TRIReleases2003; TRIReleases2004; TRIReleases2005; TRIReleases2006; 

TRIReleases2007; and TRIReleases2008. 

EPA does not have sufficient information to determine the cause of the decrease in the 

number of facilities reporting to TRI over the past seven years. The aggregate number of 

establishments8 reported to the U.S. Economic Census increased from 2002 to 2007. No changes 

in reporting requirements occurred that can be attributed to the decrease. EPA will continue to 

monitor this change in the future. 

4.5 TRIReleases2008 Rankings and DMRLoads2008 Rankings

After incorporating the changes discussed in Sections 4.3 and 4.4, EPA generated the 

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

review: TRIReleases2008_v3 and DMRLoads2008_v2. Tables C-1 and C-2 in Appendix C 

present the category rankings by TWPE from the TRIReleases2008_v3 and DMRLoads2008_v2

databases, respectively. The category rankings presented in these tables reflect all the corrections 

made during the 2010 screening-level reviews. Tables C-3 and C-4 in Appendix C present the 

six-digit NAICS code rankings by TWPE from TRIReleases2008_v3 and the four-digit SIC code 

rankings by TWPE from DMRLoads2008_v2, respectively. Tables C-5 and C-6 in Appendix C 

present the chemical rankings by TWPE from TRIReleases2008_v3 and DMRLoads2008_v2, 

respectively.

4.6 Methodology, Data Sources, and Limitations References

1. Aslinger, Julia. 2010. Notes from E-mail Communication between Julia Aslinger, Center 

for Toxicology, and Environmental Health, LLC and Elizabeth Sabol, Eastern Research 

 

8

 EPA reviewed only 3-digit NAICS code industry groups that were eligible for TRI reporting. Refer to Chapter 2 of 

the 2009 SLA Report (EPA, 2009) for more detail. 
Section 4 – Methodology, Data Sources, and Limitations 

4-44

Group, Inc. “RE: PAC Discharge Summary.” (March 22). EPA-HQ-OW-2008-0517 

DCN 07253. 

2. Becker, Jory. 2010. Notes from Telephone Conversation between Jory Becker, KY DEP, 

and Jessica Wolford, Eastern Research Group, Inc. “RE: Review of DMR data and 

Permits for Bullitt County Landfill (KY0091651) and Reed Duplex Apt. Bldg. 

(KY0095036).” (February 22). EPA-HQ-OW-2008-0517 DCN 07254. 

3. Belack, Dan. 2007. Notes from E-mail Communication between Dan Belack, US Steel, 

and Jan Matuszko, U.S. EPA. “RE: 2004 PCS Discharges.” (May 7). EPA-HQ-OW2006-0771-0480. 

4. Bernarack, Christopher. 2010. Notes from E-mail Communication between Christopher 

Bernarack, GA DEQ, and William Swietlik, U.S. EPA. “RE: Resolution of Hercules, Inc. 

Toxaphene Outlier.” (April 25). EPA-HQ-OW-2008-0517 DCN 07255. 

5. Bogaard, Dirk. 2010. Notes from Telephone Conversation between Dirk Bogaard, Clear 

Lakes Trout Company, and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Copper 

concentration reported to DMR in 2008.” (April 22). EPA-HQ-OW-2008-0517 DCN 

07256. 

6. Draveland, Steve. 2010. Notes from Telephone Conversation between Steve Draveland, 

John Morrell & Co. and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Basis of 

Mercury and Mercury Compound load reported to TRI in 2008.” (February 12). EPAHQ-OW-2008-0517 DCN 07257. 

7. ERG. 2009. Eastern Research Group, Inc. Revised Quality Assurance Project Plan for the 

2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and PCS Industrial 

Category Discharge Data. Chantilly, VA. (September). EPA-HQ-OW-2008-0517-0507. 

8. Fellows, Dave. 2003. Notes from Telephone Conversation between Dave Fellows, Exxon 

Mobile, and Eastern Research Group, Inc. “RE: Toxic Release Inventory Inquiry.” 

(August 12). EPA-HQ-OW-2003-0074 DCN 00336. 

9. House, Jane. 2010. Notes from Telephone Conversation between Jane House, Carolina 

Pole – Leland, and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Dioxin 

Distribution and Dioxin load reported to TRI in 2008.” (March 15). EPA-HQ-OW-2008-

0517 DCN 07258. 

10. Kashyap, Vikram. 2009. Notes from E-mail Communication between Vikram Kashyap, 

Louisiana Pigment Co., and Eleanor Codding, Eastern Research Group, Inc. “RE: 

Response to EPA Questions on 2007 TRI Dioxin Water Releases – Louisiana Pigment 

Company.” (May 8). EPA-HQ-OW-2008-0517-0094. 

11. Knarr, Bill. 2010. Notes from E-mail Communication between Bill Knarr, Kenvirons, 

Inc., and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Valley View Landfill - 

Mercury Discharges DMR 2008.” (March 23). EPA-HQ-OW-2008-0517 DCN 07259. 
Section 4 – Methodology, Data Sources, and Limitations 

4-45

12. Lovitt, Faith. 2010. Notes from Telephone Conversation between Faith Lovitt, Tyson 

Foods, Inc., and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Mercury 

concentration reported to DMR in 2008.” (February 19). EPA-HQ-OW-2008-0517 DCN 

07260. 

13. Noga, Jeff. 2010. Notes from Telephone Conversation between Jeff Noga, ExxonMobil 

Oil Corp., and Jessica Wolford, Eastern Research Group, Inc. RE: Joilet Refinery’s 

hexachlorobenze discharges in 2008. (February 15). EPA-HQ-OW-2008-0517 DCN 

07303. 

14. Northey, Scott. 2007. Notes from Telephone Conversation between Scott Norhtey, 

DuPont Chambers Works, and Chris Krejci, Eastern Research Group, Inc. “RE: 

Hexachlorobenzene discharges reported by DuPont Chambers Works.” (December 12). 

EPA-HQ-OW-2006-0771-1171. 

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

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

16. Peterson, Eric. 2010. Notes from Telephone Conversation between Eric Peterson, Kodak 

Colorado Division, and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Silver 

concentration reported to DMR in 2008.” (February 16). EPA-HQ-OW-2008-0517 DCN 

07261. 

17. Rayna, Dave. 2010. Notes from Telephone Conversation between Dave Rayna, Former 

Koppers, and Elizabeth Sabol, Eastern Research Group, Inc. “RE: TCDD concentrations 

reported to DMR in 2008.” (March 17). EPA-HQ-OW-2008-0517 DCN 07262. 

18. Sansalone, John. 2010. Notes from Telephone Conversation between John Sansalone, 

DEC Region 3 Office, and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Flows 

reported to DMR in 2008.” (March 17). EPA-HQ-OW-2008-0517 DCN 07263. 

19. State of Missouri. 2005. Department of Natural Resources Water Discharge Permit 

NPDES MO0000710 – Harbison Walker Refractories Company – Vandalia Plant. 

Vandalia, MO. (May 27). EPA-HQ-OW-2008-0517 DCN 07264. 

20. Stuhlfauth, Gary. 2007. Notes from Telephone Conversation between Gary Stuhlfauth, 

Ohio USEPA, and TJ Finseth, Eastern Research Group, Inc. “RE: Low level mercury 

discharge requirements on NPDES permits in Ohio.” (January 22). EPA-HQ-OW-2006-

0771-0487. 

21. Travis, Chris. 2010. Notes from Telephone Conversation between Chris Travis, USEC 

PDGDP, and Elizabeth Sabol, Eastern Research Group, Inc. “RE: PCB concentrations 

reported to DMR in 2008.” (March 17). EPA-HQ-OW-2008-0517 DCN 07265. 

22. U.S. EPA Region 1. 2006. NPDES Fact Sheet: EnviroSystems Inc. – Hampton, New 

Hampshire. (April 11). EPA-HQ-OW-2008-0517-0075. 
Section 4 – Methodology, Data Sources, and Limitations 

4-46

23. U.S. EPA. 2000. EPCRA Section 313 Guidance for Reporting Toxic Chemicals Within 

the Dioxins and Dioxin-Like Compounds Category. EPA-745-B-00-021. Washington, 

DC. (December). EPA-HQ-OW-2003-0074-1150. 

24. U.S. EPA. 2005. Draft Toxic Weighting Factor Development in Support of CWA 304(m) 

Planning Process. Washington, DC. June. EPA-HQ-OW-2004-0032-0857. 

25. U.S. EPA. 2006b. Toxic Weighting Factor Development in Support of CWA 304(m) 

Planning Process. Washington, DC. (June). EPA-HQ-OW-2004-0032-1634. 

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

Program Plan. EPA-821-R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-

0032-2782. 

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

Guidelines and Identification of Potential New Point Source Categories. EPA-821-R-09-

007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515. 

28. Williams, Sylvia. 2010. Notes from E-mail Communication between Sylvia Williams, 

Akzo Noble, and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Nobel - DMR 2008 

Mercury Discharges.” (March 22). EPA-HQ-OW-2008-0517 DCN 07266. 

29. Wood, Ken. 2010. Notes from E-mail Communication between Ken Wood, DuPont, and 

Ellie Codding, Eastern Research Group, Inc. “RE: Request for Clarification of 2008 TRI 

Data for EPA’s Annual Review.” (April 21). EPA-HQ-OW-2008-0517 DCN 07267. 
Part II – Results of the 2010 Annual Review 

II

PART II: RESULTS OF THE 2010 ANNUAL REVIEW OF 

INDUSTRIAL CATEGORIES WITH EXISTING ELGS
Section 5 – 2010 Annual Review 

5-1

5. 2010 ANNUAL REVIEW OF EXISTING EFFLUENT LIMITATIONS GUIDELINES AND 

STANDARDS AND RANKING OF POINT SOURCE CATEGORIES

For the 2010 annual review, EPA conducted the following activities: 

• Updated the reviews from previous years (i.e., revised the 2009 annual review 

results with new or corrected data); 

• Performed new researches (i.e., contacted industry to verify discharges, conducted 

literature searches, and collected additional data from site visits and state 

permitting agencies); and 

• Solicited information from stakeholders through comment response and other 

stakeholder outreach (e.g., meetings with industry trade groups). 

This section presents the results of the 2009 annual review, the results of the 2010 

screening-level review, and the prioritization of categories for the 2010 annual review. 

5.1 Summary of the Results from the 2009 Annual Review

EPA published its annual review of existing effluent limitation guidelines and standards 

(ELGs) as part of the Preliminary 2010 Plan on October 30, 2009 (74 FR 68599). In the 2009 

annual review, EPA identified 10 point source categories that represented the bulk of the 

estimated toxic discharges (as measured by toxic-weighted pound equivalents (TWPE)) from 

existing industrial point source categories. EPA ranked each point source category by the amount 

of toxic pollutants in its discharges (as measured by TWPE) and identified the Steam Electric 

Power Generating (Steam Electric) Point Source Category (Category) (40 CFR Part 423) as the 

category with the highest TWPE (accounting for more than 72 percent of the total TWPE). EPA 

identified the following seven additional categories with potentially high TWPE discharge 

estimates (accounting for almost 24 percent of existing point source category TWPE): 

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

• Fertilizer Manufacturing (40 CFR Part 418); 

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

• Petroleum Refining (40 CFR Part 419); 

• Inorganic Chemicals Manufacturing (40 CFR Part 415); 

• Nonferrous Metals Manufacturing (40 CFR Part 421); and 

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

EPA concluded its detailed study of the Steam Electric Category and decided to pursue an 

effluent guidelines rulemaking for the category. For the seven categories listed above, EPA 

conducted preliminary category reviews based on the results of the 2009 screening-level review 

and stakeholder comments. EPA determined that it would continue the preliminary category 

review for the Ore Mining and Dressing Category as part of the 2010 annual review to collect 

additional information on pollutant discharges and potential treatment technology options. For 

the remaining six categories, EPA determined that these categories were not a hazard priority 

based on data available for the 2009 annual review. 

EPA also conducted detailed studies of the Oil and Gas Extraction Category (40 CFR 

Part 435), to assess whether to revise the limits to include Coalbed Methane Extraction as a new 

subcategory, and the Health Care Industry (including Hospitals (40 CFR Part 460)) during the 
Section 5 – 2010 Annual Review 

5-2

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

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

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

annual review can and should influence succeeding annual reviews (e.g., by indicating data gaps, 

identifying new pollutants or pollution reduction technologies, or otherwise highlighting 

industrial categories for more detailed scrutiny in subsequent years). EPA used the findings, data, 

and comments on the 2009 annual review to inform its 2010 annual review. The 2009 review 

built on the previous reviews by continuing to use the screening methodology and incorporating 

some refinements in assigning discharges to categories. EPA made similar refinements to 

assigning discharges to categories for the 2010 annual review. 

5.2 Results of the 2010 Screening-Level Review

For the 2010 screening-level review, EPA used the combined results of the 

TRIReleases2008_v3 and the DMRLoads2008_v2 databases, discussed in Section 4.5 of this 

document. When combining the results of these databases, EPA eliminated from further 

consideration the results for the following: 

• Discharges from industrial categories for which EPA is currently developing or 

revising ELGs; 

• Discharges from point source categories for which EPA has recently promulgated 

or revised ELGs; 

• Discharges from facilities that do not fall into an existing or new point source 

category or subcategory; and 

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

Sections 5.2.1 through 5.2.4 discuss the rationale for these decisions. The final combined 

database rankings represent the results of the 2010 screening-level review and are presented in 

Section 5.2.5. 

5.2.1 Categories for Which EPA is Currently Developing or Revising ELGs 

EPA is currently considering revisions to ELGs for Organic Chemicals, Pesticides, and 

Synthetic Fibers (OCPSF) (40 CFR 414) and the Inorganic Chemicals Manufacturing (40 CFR 

415) Point Source Categories for facilities that produce chlorine and chlorinated hydrocarbons 

(CCH). Because the CCH rulemaking is underway, EPA excluded discharges from these 

facilities from further consideration under the current planning cycle. EPA subtracted the TWPE 

loads from facilities that produce chlorine or chlorinated hydrocarbons from the OCPSF and 

Inorganic Chemicals Manufacturing Point Source Category loads. Because facilities that produce 

chlorine and chlorinated hydrocarbons are only a subset of the OCPSF and Inorganic Chemicals 

Manufacturing Categories, EPA included loads for all other facilities in these two categories in 

the prioritization of categories for further review. 

EPA is also currently considering revisions to ELGs for the Steam Electric (40 CFR 423) 

Point Source Category. Because the Steam Electric rulemaking is underway, EPA excluded 

discharges from these facilities from further consideration under the current planning cycle. 
Section 5 – 2010 Annual Review 

5-3

EPA is also currently considering revisions to ELGs for the following industries: airport 

deicing and drinking water treatment. However, the TWPE associated with these categories is 

low and does not affect the prioritization of categories. 

5.2.2 Categories for Which EPA Recently Promulgated or Revised ELGs 

For the 2010 annual review and development of category rankings, EPA excluded point 

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

implemented, or were recently reviewed in a rulemaking context but EPA decided to withdraw 

the proposal or select the “no action” option. 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 review. This seven-year 

period allows time for the ELGs to be incorporated into National Pollutant Discharge 

Elimination System (NPDES) permits. Table 5-1 lists the categories EPA excluded from the 

2009 and 2010 reviews due to this seven year period. 

Removing a point source category from further consideration in the development of the 

rankings does not mean that EPA eliminates the category from annual review. In cases where 

EPA is aware of the growth of a new segment within such category or where new concerns are 

identified for previously unevaluated pollutants discharged by facilities in the category, EPA 

would apply closer scrutiny to the discharges from the category in deciding whether to consider 

it further during the current review cycle. For example, EPA conducted the detailed study of the 

Coal Mining Category (40 CFR Part 434) based on comments received on the 2006 Preliminary 

Plan, although the Coal Mining ELGs were revised in January 2002. 

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

Review 

40 CFR Part Point Source Category Date of Rulemaking

450 Construction and Development December 1, 2009 

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

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

432 Meat and Poultry Products September 8, 2004 

413, 433, and 438 Metal Products and Machinery 

(including Metal Finishing and Electroplating) 

May 13, 2003 

420 Iron and Steel Manufacturing October 17, 2002 

5.2.3 Discharges Not Categorizable 

EPA identified discharges that are not categorizable into existing or new point source 

categories or subcategories. In particular, EPA reviewed high TWPE discharges from a 

Superfund site (Auchterlonie, 2009).9

 Direct discharges from Superfund sites, whether made 

onsite or offsite, are subject to NPDES permitting requirements (U.S. EPA, 1988a; U.S. EPA, 

1988b). For the reasons discussed below EPA determined that these discharges do not represent 

a point source category and excluded these TWPE from the point source category rankings. 

 

9

 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as 

Superfund, was enacted by Congress on December 11, 1980. 
Section 5 – 2010 Annual Review 

5-4

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

a point source category. In particular, these discharges vary by: 

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

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

chemical/ultraviolet oxidation, aerobic biological reactors, chemical 

precipitation); and 

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

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

mine sites, mineral processing facilities, radium processing facilities). 

Moreover, the duration and volume of these direct discharges vary significantly due to 

differences in aquifer characteristics and the magnitude, fate, and transport of contaminants in 

aquifers and vadose zones. Currently at Superfund sites, permit writers determine technologybased effluent limits using their best professional judgment (BPJ). EPA selects the remedial 

technology and derives numerical effluent discharge limits. The permit must also contain more 

stringent effluent limitations when required to comply with state water quality standards. EPA 

finds that the current site-specific BPJ approach is workable and flexible within the context of a 

Superfund cleanup. 

5.2.4 Categories with One Facility Dominating the TWPE 

EPA identified point source categories with significant TWPE where only one facility 

was responsible for more than 95 percent of the TWPE reported to be discharged even though it 

was not the only facility reporting discharges for the category (see Table 5-2). EPA identified six 

facilities that dominated the TWPE in the category to which they belonged. EPA investigated 

these facilities to determine if their discharges were representative of the category. If they were 

not, EPA subtracted the facility’s TWPE from the total category TWPE and recalculated the 

category’s ranking. EPA performed this analysis separately for each of the databases. Based on 

EPA’s knowledge of these industries and the review of the pollutant discharges for these 

facilities, EPA determined that all of the pollutant discharges are representative of the industry 

and therefore, EPA did not remove the discharges from the category. 

5.2.5 Results of the 2010 Screening-Level Review 

After adjusting the category TWPE totals and rankings as described in Sections 5.2.1

through 5.2.4, EPA consolidated the 2008 discharge monitoring report (DMR) and Toxics 

Release Inventory (TRI) rankings into one set using the following steps: 

• EPA combined the two lists of point source categories by adding each category’s 

DMRLoads2008 TWPE and TRIReleases2008 TWPE10. 

• EPA then ranked the point source categories based on total DMRLoads2008 and 

TRIReleases2008 TWPE. 

 

10 EPA notes that this may result in “double-counting” of chemical discharges a facility reported to both PCS/ICISNPDES and TRI, and “single-counting” of chemicals reported in only one of the databases. Further, the combined 

databases do not count chemicals that may be discharged but are not reported to PCS/ICIS-NPDES or TRI. 
Section 5 – 2010 Annual Review 

5-5

Table 5-3 presents the combined DMRLoads2008 and TRIReleases2008 rankings. These 

are the final category rankings accounting for all corrections made to the databases during the 

2010 screening-level review and removal of any categories and discharges as discussed in 

Sections 5.2.1 through 5.2.4. 
Section 

5-6

Table 5-2. Point Source Categories with One Facility Dominating the TWPE Discharge

Point Source Category 

Facility with Over 

95% of Category 

TWPE 

Facility 

Location 

Data 

Source 

Pollutant Driving 

TWPE 

Facility 

TWPE 

Percentage o

Total 

Category 

TWPE 

Miscellaneous Food and Beverages (Potential New Category) 

Bacardi Corp Catano, PR DMR 2008 Sulfur 188,000 97.4% 

Independent and Stand Alone Labs (Potential New Category) 

Battelle Memorial Institute 

Columbus, OH 

DMR 2008 Chloride 186,000 99.1% 

Ferroalloy Manufacturing (Part 424) 

Eramet Marietta, Inc. Marietta, 

OH 

TRI 2008 Manganese and 

Manganese Compounds 

12,500 96.9% 

Tobacco Products (Potential New Category) 

Philip Morris USA Park 500 Site 

Chester, VA TRI 2008 Chlorine 1,770 98.7% 

Coil Coating (Part 465) Latasde Aluminio 

Reynolds 

Guayama, PR 

DMR 2008 Sulfur 476 95.1% 

Ink Formulation (Part 447) Superior Printing Ink, 

Co, Inc. 

Marlboro, MA 

DMR 2008 Chlorine 24.6 99.6% 

Source: DMRLoads2008_v2 and TRIReleases2008_v3. 
Section 

5-7

Table 5-3. Final TRIReleases2008 and DMRLoads2008 Combined Point Source Category Ra

40 CFR 

Part Point Source Category 

TRIReleases2008

TWPE 

DMRLoads2008

TWPE Total TWPE 

C

Perce

430 Pulp, Paper And Paperboard 523,000 510,000 1,030,000 419 Petroleum Refining 410,000 618,000 1,030,000 421 Nonferrous Metals Manufacturing 38,700 955,000 994,000 418 Fertilizer Manufacturing 8,120 818,000 826,000 414 Organic Chemicals, Plastics And Synthetic Fibers 137,000 512,000 649,000 440 Ore Mining And Dressing 109,000 339,000 448,000 415 Inorganic Chemicals Manufacturing 71,300 228,000 299,000 444 Waste Combustors 8,830 245,000 254,000 410 Textile Mills 2,750 247,000 250,000 463 Plastics Molding And Forming 74,700 174,000 249,000 

NA Miscellaneous Foods And Beverages 5,210 193,000 198,000 

445 Landfills 781 191,000 192,000 411 Cement Manufacturing 529 189,000 190,000 435 Oil & Gas Extraction NA 189,000 189,000 

NA Independent And Stand Alone Labs 49.9 186,000 186,000 

455 Pesticide Chemicals 35,500 114,000 150,000 464 Metal Molding And Casting (Foundries) 5,040 122,000 127,000 

NA Food Service Establishments NA 119,000 119,000 

436 Mineral Mining And Processing 3,390 100,000 103,000 428 Rubber Manufacturing 7,180 73,700 80,900 434 Coal Mining 1,280 76,400 77,700 429 Timber Products Processing 27,300 31,500 58,800 439 Pharmaceutical Manufacturing 6,890 49,100 56,000 467 Aluminum Forming 5,830 33,700 39,500 471 Nonferrous Metals Forming And Metal Powders 20,900 15,000 35,900 409 Sugar Processing 205 35,300 35,500 437 Centralized Waste Treatment 6,850 25,500 32,400 
Section 

5-8

Table 5-3. Final TRIReleases2008 and DMRLoads2008 Combined Point Source Category Ra

40 CFR 

Part Point Source Category 

TRIReleases2008

TWPE 

DMRLoads2008

TWPE Total TWPE 

C

Perce

458 Carbon Black Manufacturing 27,600 335 27,900 422 Phosphate Manufacturing 657 17,200 17,900 469 Electrical And Electronic Components 3,580 12,300 15,900 460 Hospital NA 15,700 15,700 424 Ferroalloy Manufacturing 12,900 2,560 15,500 457 Explosives Manufacturing 43.2 10,400 10,400 406 Grain Mills 5,600 4,300 9,900 468 Copper Forming 4,780 2,470 7,250 425 Leather Tanning And Finishing 6,990 17.5 7,010 407 

Canned And Preserved Fruits And Vegetables Processing 4,810 519 5,330 

405 Dairy Products Processing 3,750 1,450 5,200 461 Battery Manufacturing 1,580 622 2,200 442 Transportation Equipment Cleaning NA 1,840 1,840 

NA Tobacco Products 1,790 11.3 1,800 

443 Paving And Roofing Materials (Tars And Asphalt) 927 751 1,680 426 Glass Manufacturing 473 917 1,390 408 Canned And Preserved Seafood Processing 108 932 1,040 417 Soap And Detergent Manufacturing 776 79.9 856 

NA Printing And Publishing 141 671 812 

465 Coil Coating 191 501 692 446 Paint Formulating 551 18.3 569 454 Gum And Wood Chemicals Manufacturing 69.5 218 288 447 Ink Formulating 35.4 24.8 60.2 466 Porcelain Enameling 18.5 7.43 25.9 427 Asbestos Manufacturing NA 1.42 1.42 

NA Industrial Laundries NA 0.321 0.321 
Section 

5-9

Table 5-3. Final TRIReleases2008 and DMRLoads2008 Combined Point Source Category Ra

40 CFR 

Part Point Source Category 

TRIReleases2008

TWPE 

DMRLoads2008

TWPE Total TWPE 

C

Perce

459 Photographic NA 0.0328 0.0328 

NA Photo Processing NA 0.0328 0.0328 

Total 1,590,000 6,460,000 8,050,000 

Source: TRIReleases2008_v3 and DMRLoads2008_v2. 

NA – Not applicable.
Section 5 – 2010 Annual Review 

5-10

5.3 Prioritization of Categories for the 2010 Annual Review

Based on its screening-level review, EPA was able to prioritize for further review (i.e., a 

detailed study or preliminary category review) those industrial categories whose pollutant 

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

their toxicity (i.e., categories that collectively discharge over 95 percent of the total TWPE). EPA 

also considered efficiency and implementation issues raised by stakeholders in identifying 

candidates for further review. By using this multilayered screening approach, the Agency 

concentrated its resources on those point source categories with the highest estimates of toxicweighted pollutant discharges (based on best available data), while assigning a lower priority to 

categories that the Agency believes are not good candidates for ELGs revision at this time. 

Table 5-4 lists the point source categories with existing ELGs, the level of review EPA 

performed as part of the 2010 annual review, and how each category was identified for further 

review, if applicable. 

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

40 CFR 

Part Point Source Category Level of Review 

Source of 

Identification for 

Further Review 

405 Dairy Products Processing Screening-Level Review NA a

406 Grain Mills Manufacturing Screening-Level Review NA a

407 Fruits and Vegetable Processing Screening-Level Review NA a

408 Canned and Preserved Seafood Screening-Level Review NA a

409 Sugar Processing Screening-Level Review NA a

410 Textile Mills Preliminary Review TWPE 

411 Cement Manufacturing Preliminary Review TWPE 

412 Concentrated Animal Feeding Operations Screening-Level Review NA a

413 Electroplating Screening-Level Review NA a

414 Organic Chemicals, Plastics and Synthetic Fibers Preliminary Review TWPE 

415 Inorganic Chemicals Preliminary Review TWPE 

417 Soaps and Detergents Manufacturing Screening-Level Review NA a

418 Fertilizer Manufacturing Preliminary Review TWPE 

419 Petroleum Refining Preliminary Review TWPE 

420 Iron and Steel Manufacturing Screening-Level Review NA a

421 Nonferrous Metals Manufacturing Preliminary Review TWPE 

422 Phosphate Manufacturing Screening-Level Review NA a

423 Steam Electric Power Generation Screening-Level Review NA a

424 Ferroalloy Manufacturing Screening-Level Review NA a

425 Leather Tanning and Finishing Screening-Level Review NA a

426 Glass Manufacturing Screening-Level Review NA a

427 Asbestos Manufacturing Screening-Level Review NA a

428 Rubber Manufacturing Preliminary Review TWPE 

429 Timber Products Processing Screening-Level Review NA a

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

5-11

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

40 CFR 

Part Point Source Category Level of Review 

Source of 

Identification for 

Further Review 

432 Meat and Poultry Products Screening-Level Review NA a

433 Metal Finishing Screening-Level Review NA a

434 Coal Mining Preliminary Review TWPE 

435 Oil and Gas Extraction Detailed Study of Coalbed 

Methane Operations 

Comments 

Preliminary Review of 

Remaining Operations 

TWPE 

436 Mineral Mining and Processing Preliminary Review TWPE 

437 Centralized Waste Treaters Screening-Level Review NA a

438 Metal Products and Machinery Screening-Level Review NA a

439 Pharmaceutical Manufacturing Screening-Level Review NA a

440 Ore Mining and Dressing Preliminary Review TWPE 

442 Transportation Equipment Cleaning Screening-Level Review NA a

443 Paving and Roofing Materials (Tars and Asphalt) Screening-Level Review NA a

444 Waste Combustors (Commercial Incinerators 

Combusting Hazardous Waste) 

Preliminary Review TWPE 

445 Landfills Preliminary Review TWPE 

446 Paint Formulating Screening-Level Review NA a

447 Ink Formulating Screening-Level Review NA a

450 Construction and Development Industry Screening-Level Review NA a

451 Aquatic Animal Production Industry Screening-Level Review NA a

454 Gum and Wood Chemicals Screening-Level Review NA a

455 Pesticide Chemicals Manufacturing Preliminary Review TWPE 

457 Explosives Screening-Level Review NA a

458 Carbon Black Manufacturing Screening-Level Review NA a

459 Photographic Screening-Level Review NA a

460 Hospital Detailed Study (of Health 

Care Industry) 

Comments 

461 Battery Manufacturing Screening-Level Review NA a

463 Plastic Molding and Forming Preliminary Review TWPE 

464 Metal Molding and Casting (Foundries) Preliminary Review TWPE 

465 Coil Coating Screening-Level Review NA a

466 Porcelain Enameling Screening-Level Review NA a

467 Aluminum Forming Screening-Level Review NA a

468 Copper Forming Screening-Level Review NA a

469 Electrical and Electronic Components Screening-Level Review NA a

471 Nonferrous Metals Forming and Metal Powders Screening-Level Review NA a

NA Food Service Establishments Preliminary Review TWPE 

NA Miscellaneous Food and Beverages Preliminary Review TWPE 

NA Independent and Stand Alone Labs Preliminary Review TWPE 
Section 5 – 2010 Annual Review 

5-12

a – For categories with only a screening-level review, the source of identification is not applicable, as EPA conducts 

a screening-level review of all categories subject to existing effluent guidelines. The “source of identification” is 

only applicable for those industries selected for further review. 

NA – Not applicable. 

5.3.1 Detailed Study of Existing ELGs 

EPA performed detailed studies on two point source categories as part of its 2010 annual 

review based on the results of its 2008 and 2009 annual reviews. Because EPA data collection 

was not finished in 2009, EPA continued detailed studies of the Oil and Gas Extraction Category 

(40 CFR Part 435) to assess whether to revise the limits to include coalbed methane extraction as 

a new subcategory, and the Health Care Industry (includes Hospitals (40 CFR Part 460)). EPA 

did not identify additional categories for detailed study as part of the 2010 annual review. 

EPA’s detailed studies generally examine the following: (1) wastewater characteristics 

and pollutant sources; (2) the pollutants driving the toxic-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 screening-level results and fill in data gaps. 

Next, EPA considers costs and performance of applicable and demonstrated control technology, 

process change, or pollution prevention alternatives that can effectively reduce the pollutants 

remaining in the industrial category's wastewater. Last, EPA considers the affordability or 

economic achievability of the technology, process change, or pollution prevention measures 

identified above. 

Types of data sources that EPA may consult in conducting its detailed studies include, 

but are not limited to: (1) the U.S. Economic Census; (2) TRI, Permit Compliance System (PCS), 

and the Integrated Information System – National Pollutant Discharge Elimination System 

(ICIS-NDPES) data; (3) trade associations and reporting facilities to verify reported releases and 

facility categorization; (4) regulatory authorities (states and EPA regions) to understand how 

category facilities are permitted; (5) National Pollutant Discharge Elimination System (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. 

For more information about the Oil and Gas Extraction Detailed Study (coalbed methane 

industry) and the Health Care Industry Detailed Study, see Sections 16.2 and 16.1 of this report, 

respectively. 

5.3.2 Preliminary Category Reviews 

Preliminary category reviews are similar to detailed studies and have the same purpose. 

During preliminary reviews, EPA generally examines the same items listed above for detailed 

studies. However, EPA’s preliminary review of a category and available pollution prevention 

and treatment options is less rigorous than its detailed studies. While EPA collects and analyzes 

hazard and technology-based information on categories undergoing preliminary review, it 

assigns a higher priority to investigating categories undergoing detailed studies. 

As shown in Table 5-4, EPA identified for preliminary review 21 industrial categories 

that cumulatively discharge more than 95 percent of the combined DMRLoads2008 and 
Section 5 – 2010 Annual Review 

5-13

TRIReleases2008 total TWPE. Three of the 21 industrial categories identified for preliminary 

review are potential new categories. Based on information from the 2010 and previous annual 

reviews, EPA concluded that the following 13 industrial categories did not require a detailed 

section in this report. For these 13 categories, EPA determined that the conclusions were the 

same as made during previous annual reviews or the majority of the TWPE was due to data 

errors (e.g., incorrect units)11. These industrial categories, and the reasons for excluding them 

from further preliminary review, are listed below. EPA is assigning all of these categories with a 

lower priority for revision (i.e., the category is marked with “(3)” in the “Findings” column in 

Table V-1 in the 2010 Final Plan FR notice). 

Cement Manufacturing (40 CFR Part 411) 

For the Cement Manufacturing Category, the DMRLoads2008_v2 database accounts for 

the majority of the combined estimated TWPE. EPA identified one facility, Lafarge North 

America’s Alpena Plant in Alpena, MI, that accounts for approximately 89 percent of the 2008 

DMR TWPE for the Cement Manufacturing Category. EPA determined that the mercury 

quantities are incorrect because they do not match the load calculated using the mercury 

concentrations and flows. Correcting these errors reduces the facility’s 2008 DMR TWPE from 

169,000 to 759 and reduces the Cement Manufacturing Category’s combined 2008 DMR and 

TRI TWPE from 190,000 to 21,100 (ERG, 2010). The category is no longer a priority for the 

2010 annual review. 

Petroleum Refining (40 CFR Part 419) 

The Petroleum Refining Category total TWPE is approximately 60 percent from the 2008 

DMR database and 40 percent from the 2008 TRI database. The top pollutant in the 2008 DMR 

database is sulfide, while the top pollutants in the 2008 TRI database are dioxin and dioxin-like 

compounds and polycyclic aromatic compounds (PACs). Discharges of these four pollutants 

from petroleum refineries have been reviewed in previous annual reviews, and EPA concluded 

the following: 

• Sulfide: As part of the 2004 detailed study of the Petroleum Refining Category, 

EPA determined that petroleum refineries are achieving final effluent 

concentrations less than existing limits in 40 CFR Part 419 and refineries are 

treating sulfide to concentrations at or near treatable levels (U.S. EPA, 2006b). 

• Dioxin and dioxin-like compounds: EPA determined that dioxin and dioxin-like 

compounds are produced during catalytic reforming and catalyst regeneration 

operations at petroleum refineries. Most facilities reporting dioxin and dioxin-like 

compounds in TRI never detected dioxin and dioxin-like compounds in their 

process wastewater effluent. Of the 232 refineries in TRI 2007 that report nonzero TWPE, nine reported discharges of dioxin and dioxin-like compounds. Of 

the nine refineries reporting dioxin and dioxin-like compound discharges in 2007, 

only five of these refineries reported dioxin discharges based on analytical 

 

11 EPA generated a corrected version of the 2008 DMR database: DMRLoads2008_v3, which is available via 

http://www.regulations.gov, EPA-HQ-OW-2008-0517 DCN 07317. This version includes all corrections 

documented in this TSD. 
Section 5 – 2010 Annual Review 

5-14

measurements (see Table 11-5 in the Technical Support Document for the 

Preliminary 2010 Effluent Guidelines Program Plan (U.S. EPA, 2009)). 

• PACs: EPA determined that petroleum refineries report PAC discharges to TRI 

that are either based on half the detection limit multiplied by the flow or using 

emission factors. EPA determined that there is little evidence that PACs are being 

discharged to surface waters in concentrations above the detection limit (U.S. 

EPA, 2009). 

EPA determined that the 2008 petroleum refinery discharges were consistent with previous 

years’ discharges. As a result, EPA will rely on the conclusions from previous annual reviews: 

the discharges from this category do not represent a priority hazard at this time. The category is 

no longer a priority for the 2010 annual review. 

Nonferrous Metals Manufacturing (40 CFR Part 421) 

For the Nonferrous Metals Manufacturing Category, the DMRLoads2008_v2 database 

accounts for the majority of the combined estimated TWPE. The top facility, USEC PDGDP in 

McCracken County, KY, accounts for almost 60 percent of the category’s 2008 DMR TWPE. 

EPA contacted the facility to discuss discharges of polychlorinated biphenyls (PCBs) as part of 

the 2010 annual review. The facility contact verified that EPA’s database was properly 

characterizing the PCB discharge and indicated that the PCBs are from stormwater due to legacy 

activity at the site. The facility contact also indicated that USEC PDGDP treats all process water 

that may contain PCBs using carbon adsorption (Travis, 2010). EPA determined that the PCB 

discharges are not from nonferrous metals manufacturing processes and, therefore, should be 

excluded from the category’s TWPE. Therefore, EPA determined that the 2008 nonferrous 

metals manufacturing discharges are consistent with the previous year’s discharges. As a result, 

EPA will rely on the conclusions from previous annual reviews: the discharges from this 

category do not represent a priority hazard at this time. See Section 8.0 of the 2009 TSD for 

additional information (U.S. EPA, 2009). The category is no longer a priority for the 2010 

annual review. 

Rubber Manufacturing (40 CFR Part 428) 

For the Rubber Manufacturing Category, the DMRLoads2008_v2 database accounts for 

the majority of the combined estimated TWPE. EPA identified the following two facilities 

accounting for approximately 79 percent of the 2008 DMR TWPE for the Rubber Manufacturing 

Category: 

• Durakon Industries, Inc. in Lapeer, MI: EPA determined that the January and 

December 2008 mercury quantities are incorrect because they do not match the 

load calculated using the mercury concentrations and flows. Correcting these data 

reduces the facility’s 2008 DMR TWPE from 34,900 to 0.11 (ERG, 2010). 

• Kraton Polymers, US, LLC in Belpre, OH: EPA determined that the January 

through December 2008 arsenic quantities are incorrect because they do not 

match the load calculated using the arsenic concentrations and flows. Correcting 

these data reduces the facility’s 2008 DMR TWPE from 23,200 to 2,900 (ERG, 

2010). 
Section 5 – 2010 Annual Review 

5-15

After reviewing the data, EPA determined that the discharges from the facilities above were 

incorrect. Correcting these errors reduces the Rubber Manufacturing Category combined 2008 

DMR and TRI TWPE from 80,900 to 25,700 (ERG, 2010). The category is no longer a priority 

for the 2010 annual review. 

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

The Pulp, Paper, and Paperboard (Pulp and Paper) Category total TWPE is approximately 

50 percent from the 2008 DMR database and 50 percent from the 2008 TRI database. The top 

pollutants in the 2008 DMR database are 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) 

and sulfide, while the top pollutants in the 2008 TRI database are manganese and manganese 

compounds, lead and lead compounds, and dioxin and dioxin-like compounds. Discharges of 

dioxin and dioxin-like compounds, including 2,3,7,8-TCDD, and manganese and manganese 

compounds from pulp and paper facilities have been reviewed in previous annual reviews: 

• 2,3,7,8-TCDD (DMR) and Dioxin and Dioxin-Like Compounds (TRI): EPA 

determined that the 2,3,7,8-TCDD DMR data were not detected in bleach plant 

effluent or final mill effluent (U.S. EPA, 2006a). Additionally, EPA determined 

that the majority of the underlying data used to estimate releases of dioxin and 

dioxin-like compounds reported to TRI were pollutant concentrations below the 

Method 1613B minimum level. Therefore, there is substantial uncertainty about 

the magnitude of these reported discharges. TRI-reported discharges of dioxin and 

dioxin-like compounds for the Pulp and Paper Category are most likely 

significantly overestimated and thus do not accurately reflect current industry 

discharges (U.S. EPA, 2009).

• Manganese and Manganese Compounds: As part of the Pulp and Paper 

Detailed Study performed in the 2006 annual review, EPA determined that the 

manganese concentrations were too low to treat using end-of-pipe treatment 

technologies for large plant flows (U.S. EPA, 2006a). Although EPA has not 

reviewed new discharge concentration data, it has no new data to suggest that 

manganese concentrations are above the treatable levels (U.S. EPA, 2009). 

EPA has not reviewed discharges of sulfide and lead and lead compounds from pulp and 

paper facilities as part of previous annual reviews. EPA’s findings as part of the 2010 annual 

review for sulfide and lead and lead compound discharges are: 

• Sulfide: Approximately 23 percent of the 2008 DMR TWPE for the Pulp and 

Paper Category is from sulfide discharges. There are two facilities with sulfide 

discharges in the 2008 DMR database: Smurfit-Stone Container in Florence, SC 

and Domtar Johnsonburg in Johnsonburg, PA. The 2008 sulfide discharges for 

Smurfit-Stone Container ranged from below the detection limit (0.1 mg/L to 1.0 

mg/L) to 1.7 mg/L. The Lockwood-Post’s Directory of Pulp and Paper Mills 

indicates that Smurfit-Stone Container has a 1,600 acre settling basin. Sulfides 

may result from an anaerobic portion of the settling basin. EPA determined that 

the sulfide concentration for Domtar Johnsonburg was reported below the 

detection limit, while the sulfide quantity was reported above the detection limit. 
Section 5 – 2010 Annual Review 

5-16

Therefore, sulfide discharges from Domtar Johnsonburg are likely below the 

detection limit, resulting in a 16,000 TWPE reduction in the Pulp and Paper 

Category’s sulfide TWPE. EPA will continue to monitor the sulfide discharges to 

determine if they are properly controlled. 

• Lead and Lead Compounds: Approximately 13 percent (63,800 TWPE) of the 

2008 TRI TWPE for the Pulp and Paper Category is from discharges of lead and 

lead compounds. There are 185 pulp and paper facilities in the 2008 TRI database 

reporting discharges of lead and lead compounds. The top facility with discharges 

of lead and lead compounds is Kimberly Clark in Everett, WA that accounts for 

approximately 9.6 percent of the Pulp and Paper Category’s lead and lead 

compound discharges; therefore, there are no outlier pulp and paper facilities 

discharging lead and lead compounds. The majority of the lead and lead 

compounds are based on monitoring data (54 discharges) or published emission 

factors (46 discharges). Because there are no outlier facilities, EPA determined 

that the lead and lead compound discharges are likely accurate. EPA suspects 

high TWPE from the high volume of lead and lead compound dischargers in the 

Pulp and Paper Category. EPA will continue to monitor the lead and lead 

compound discharges to determine if they are properly controlled. 

EPA determined that the 2008 pulp and paper discharges of dioxin and dioxin-like 

compounds and manganese and manganese compounds were consistent with previous years’ 

discharges. EPA will continue to monitor the Pulp and Paper Category’s sulfide and lead and 

lead compound discharges to determine if they are properly controlled. As a result, EPA will rely 

on the conclusions from previous annual reviews: the discharges from this category do not 

represent a priority hazard at this time. The category is no longer a priority for the 2010 annual 

review. 

Coal Mining (40 CFR Part 434) 

For the Coal Mining Category, the DMRLoads2008_v2 database accounts for the 

majority of the combined estimated TWPE. The top pollutants in the 2008 DMR database are 

manganese and iron. Discharges of these pollutants from coal mines were reviewed as part of the 

Coal Mining Detailed Study during the 2007 and 2008 annual reviews. EPA determined that 

based on its review of available data, revisions to the pollutant limitations in the Coal Mining 

ELGs were not warranted (U.S. EPA, 2008). 

Pesticide Chemicals (40 CFR Part 455) 

For the Pesticide Chemicals (Pesticides) Category, the DMRLoads2008_v2 database 

accounts for the majority of the combined estimated TWPE. EPA identified one facility, Bayer 

CropSciences in Institute, WV, that accounted for approximately 83 percent of the 2008 DMR 

TWPE for the Pesticides Category. EPA determined that the majority of the of the facility’s 

estimated load results from total carbaryl. EPA contacted Bayer CropSciences to verify the total 

carbaryl quantities and concentrations and flow. Bayer CropSciences indicated that all of the 

total carbaryl quantities and concentrations for outfall 005 were reported below the detection 

limit, while all but one total carbaryl concentration for outfall 301 was reported below the 

detection limit (Smith, 2010). Using the facility-provided quantities and concentrations reduces 
Section 5 – 2010 Annual Review 

5-17

Bayer CropSciences 2008 DMR TWPE from 94,300 to 532 and reduces the Pesticides 

Category’s total TWPE from 114,000 to 20,000 (ERG, 2010). The category is no longer a 

priority for the 2010 annual review. 

Metal Molding and Casting (40 CFR Part 464) 

For the Metal Molding and Casting Category, the DMRLoads2008_v2 database accounts 

for the majority of the combined estimated TWPE. EPA identified one facility, Eagle-Picher 

Industries in Sidney, OH, that accounted for approximately 61 percent of the 2008 DMR TWPE 

for the Metal Molding and Casting Category. EPA determined that the outfall 001 flows for 

September, October, and December 2008 were incorrectly entered as million gallons per day 

(MGD) instead of gallons per day (GPD). Correcting these errors reduces the facility’s 2008 

DMR TWPE from 74,700 to 32 and reduces the Metal Molding and Casting Category’s total 

TWPE from 127,000 to 52,300 (ERG, 2010). The category is no longer a priority for the 2010 

annual review. 

Miscellaneous Food and Beverages (Potential New Category) 

For the Miscellaneous Foods and Beverages Potential New Category, the 

DMRLoads2008_v2 database accounts for the majority of the combined estimated TWPE. EPA 

identified one facility, Bacardi Corp. in Catano, PR, that accounted for approximately 97 percent 

of the 2008 DMR TWPE for the Miscellaneous Food and Beverages Potential New Category. 

EPA reviewed this facility’s discharges in preparing the 2006 Final Plan as well (U.S. EPA, 

2006b). 

EPA contacted EPA Region 2 to discuss the Bacardi discharges and determined that the 

facility’s sulfide discharges were unique to the facility. According to Region 2 staff, the Bacardi 

effluent wastewater characteristics include high levels of biochemical oxygen demand – 

approximately 15,000 milligrams per liter (mg/L), bacteria, and solids, which complicate its 

treatment. As a result, Region 2 worked with the facility to determine treatable levels. The 

wastewater discharge commingles with adjacent wastewater treatment discharges from PRASA’s 

Puerto Nuevo and Bayamon wastewater treatment plants (WWTPs). The wastewater discharges 

immediately dilute the discharge from the Bacardi plant. As a result, Region 2 concluded that 

certain pollutants, such as sulfide, can be discharged at high concentrations and will be diluted 

prior to reaching surface water (O’Brien, 2010). EPA based the water quality based limitations 

for this facility on the final Water Quality Certificate issued by the Puerto Rico Environmental 

Quality Board (U.S. EPA Region 2, 2007). The resulting permit limit for sulfide is 108 mg/L at 

the outfall. The sulfide limit at the edge of the mixing zone, after commingling with the WWTPs 

is 2 μg/L (U.S. EPA Region 2, 2008). Because one facility accounted for the vast majority of the 

TWPE, EPA determined that ELGs for the potential new category are not warranted. Therefore, 

the category is no longer a priority for the 2010 annual review. 

Food Service Establishments (Potential New Category) 

For the Food Service Establishments Potential New Category, the DMRLoads2008_v2

database accounts for all of the total TWPE (food service establishments do not report to TRI). 

EPA identified one facility, Gionino’s Pizza in OH, that accounted for approximately 75 percent 

of the 2008 DMR TWPE for the Food Service Establishments Potential New Category. EPA 

determined that the outfall 001 flows for January through December 2008 were incorrectly 
Section 5 – 2010 Annual Review 

5-18

entered as MGD instead of GPD. Correcting these errors reduces the facility’s 2008 DMR 

TWPE from 90,700 to 3.7 and reduces the Food Service Establishments Potential New 

Category’s combined 2008 DMR and TRI TWPE from 198,000 to 34,000 (ERG, 2010). The 

category is no longer a priority for the 2010 annual review. 

Independent and Stand Alone Labs (Potential New Category) 

For the Independent and Stand Alone Labs Potential New Category, the 

DMRLoads2008_v2 database accounts for the majority of the combined estimated TWPE. EPA 

identified one facility, Battelle Memorial Institute in Columbus, OH, that accounted for 

approximately 99 percent of the 2008 DMR TWPE for the Independent and Stand Alone Labs 

Potential New Category. EPA determined that the outfall 002 flows for January through August 

and October through December 2008 were incorrectly entered as MGD instead of GPD. 

Correcting these errors reduces the facility’s 2008 DMR TWPE from 184,000 to 1.2 and reduces 

the Independent and Stand Alone Labs Potential New Category’s combined 2008 DMR and TRI 

TWPE from 186,000 to 1,810 (ERG, 2010). The category is no longer a priority for the 2010 

annual review. 

The preliminary reviews for the remaining eight categories involved more than discharge 

data errors and, therefore, each have sections in this report. The eight preliminary reviews 

identified are listed below, along with a reference to where they are discussed in this report: 

• Fertilizer Manufacturing Category (Section 6); 

• Inorganic Chemicals Manufacturing Category (Section 7); 

• Landfills Category (Section 8); 

• Mineral Mining and Processing Category (Section 9); 

• Oil and Gas Extraction Category (Excluding CBM) (Section 10); 

• Ore Mining and Dressing Category (Section 11); 

• Organic Chemicals, Plastics, and Synthetic Fibers Category (Section 12); 

• Plastics Molding and Forming Category (Section 13); 

• Textile Mills Category (Section 14); and 

• Waste Combustors Category (Section 15). 

EPA recently conducted detailed studies or preliminary reviews of many of the categories 

listed above. Table 5-5 lists these categories and the level of review performed for EPA’s 2007 

through 2010 annual reviews. For each of these categories, EPA’s annual review builds on 

previous reviews. For the preliminary category reviews and detailed studies discussed in this 

document, EPA primarily looked at the pollutants reported in 2008 and their contribution to their 

category’s TWPE. 
Section 5 – 2010 Annual Review 

5-19

Table 5-5. Previous Reviews for Categories with Preliminary Category Reviews for the 

2010 Annual Review 

40 CFR 

Part Point Source Category 

Level of Review for 

2007/2008 

Level of Review for 

2009/2010 

410 Textile Mills Screening-Level Review a Preliminary Category Review 

414 Organic Chemicals, Plastics, and 

Synthetic Fibers 

Preliminary Category Review Preliminary Category Review 

415 Inorganic Chemicals Manufacturing Screening-Level Review a Preliminary Category Review

418 Fertilizer Manufacturing Screening-Level Review a Preliminary Category Review

435 Oil and Gas Extraction, excluding 

Coalbed Methane operations 

NA Preliminary Category Review 

436 Mineral Mining and Processing NA Preliminary Category Review 

440 Ore Mining and Dressing Preliminary Category Review Preliminary Category Review 

444 Waste Combustors Preliminary Category Review Preliminary Category Review

445 Landfills NA Preliminary Category Review 

463 Plastics Molding and Forming Screening-Level Review a Preliminary Category Review 

a – EPA conducted a preliminary category review as part of the 2007 annual review, but not as part of the 2008 

annual review. 

NA – Not applicable. 

5.4 2010 Annual Review References 

1. Auchterlonie, Steve. 2009. Notes from Telephone Conversation between Steve 

Auchterlonie, Front St. Remedial Action, and Chris Krejci, Eastern Research Group, Inc. 

“RE: Verification of magnitude and basis of estimate for dioxin and dioxin-like 

compounds discharges in PCS.” (March 13). EPA-HQ-OW-2008-0517-0076. 

2. ERG. 2010. Eastern Research Group, Inc. Preliminary Category Review – Facility Data 

Review and Revised Calculations. (September). EPA-HQ-OW-2008-0517 DCN 07304. 

3. O’Brien, Karen. 2010. EPA Region 2. Notes from Telephone Conversation between 

Karen O’Brien, EPA Region 2, and Eleanor Codding, Eastern Research Group, Inc. “RE: 

Sulfide discharges from Bacardi Corporation in Puerto Rico.” (August). EPA-HQ-OW2008-0517 DCN 07305. 

4. Smith, Gordon. 2010. Telephone and E-mail communication with Gordon Smith, Bayer 

CropSciences, and Lauren Wingo, Eastern Research Group, Inc. “Re: Bayer 

CropSciences’ 2008 DMR Pesticide Discharges.” (September 14). EPA-HQ-OW-2008-

0517 DCN 07268. 

5. Travis, Chris. 2010. Notes from Telephone Conversation between Chris Travis, USEC 

PDGDP, and Elizabeth Sabol, Eastern Research Group, Inc. “RE: PCB concentrations 

reported to DMR in 2008.” (March 17). EPA-HQ-OW-2008-0517 DCN 07265. 

6. U.S. EPA Region 2. 2007. National Pollutant Discharge Elimination System Fact Sheet – 

PR0000591 – Bacardi Corporation – Cataño, Puerto Rico. (December 12). EPA-HQOW-2008-0517 DCN 07269. 
Section 5 – 2010 Annual Review 

5-20

7. U.S. EPA Region 2. 2008. National Pollutant Discharge Elimination System Permit – 

PR0000591 – Bacardi Corporation – Cataño, Puerto Rico. (July 1). EPA-HQ-OW-2008-

0517 DCN 07270. 

8. U.S. EPA. 1988a. CERCLA Compliance with Other Laws Manual: Interim Final. EPA540-G-89-006. OSWER Publication 9234.1-01. Washington, DC. (August). Available 

online at: www.epa.gov/superfund/resources/remedy/pdf/540g-89006-s.pdf. 

9. U.S. EPA. 1988b. Guidance on Remedial Actions for Contaminated Ground Water at 

Superfund Sites. OSWER Directive 9283.1-2. EPA-540-G-88-003. (December). 

Available online at: www.epa.gov/superfund/resources/remedy/pdf/540g-89006-s.pdf. 

10. U.S. EPA. 2006a. Final Report: Pulp, Paper, and Paperboard Detailed Study. EPA-821-

R-06-016. Washington, DC. (November). EPA-HQ-OW-2004-0032-2249. 

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

Program Plan. EPA-821R-06-018. (December). EPA-HQ-OW-2004-0032-2782. 

12. U.S. EPA. 2008. Coal Mining Detailed Study. EPA-821-R-08-012. Washington, DC. 

(August). EPA-HQ-OW-2006-0771-1695. 

13. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent 

Guidelines Program Plan. EPA-821-R-09-006. Washington, DC. (October). EPA-HQOW-2008-0517-0515. 
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-1

6. FERTILIZER MANUFACTURING (40 CFR PART 418) 

EPA selected the Fertilizer Manufacturing Category for preliminary review because it 

continues to rank high, in terms of toxic-weighted pound equivalent (TWPE), in point source 

category rankings (see Table 5-3 for the point source category rankings). The Final 2006 Plan 

summarizes the results of EPA’s previous review of this industry in 2004 and 2005 (71 FR 

76644). EPA also reviewed discharges from the Fertilizer Manufacturing Category as part of the 

2009 annual review (74 FR 68599). This section summarizes the results of the 2010 annual 

review associated with the Fertilizer Manufacturing Category. EPA focused on discharges of 

fluoride from two facilities because of their high TWPE relative to the other facilities in the 

Fertilizer Manufacturing Category. 

6.1 Fertilizer Manufacturing Category Background

This subsection provides the background on the Fertilizer Manufacturing Category 

including a brief profile of the fertilizer manufacturing industry and background on 40 CFR Part 

418. 

6.1.1 Fertilizer Manufacturing Industry Profile 

The fertilizer manufacturing industry includes facilities that produce phosphorus- and 

nitrogen-based fertilizers (U.S. EPA, 2006). EPA considered the following three North American 

Industrial Classification System (NAICS) codes as part of the Fertilizer Manufacturing Category: 

• 325311: Nitrogenous Fertilizer Manufacturing; 

• 325312: Phosphatic Fertilizer Manufacturing; and 

• 325314: Fertilizer (Mixing Only) Manufacturing. 

Because the Permit Compliance System (PCS) and Integrated Compliance Information 

System – National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the 

sources of the discharge monitoring report (DMR) data used to develop DMRLoads2008, report 

facilities by Standard Industrial Classification (SIC) code, and the U.S. Economic Census and 

Toxics Release Inventory (TRI) report data by North American Industry Classification System 

(NAICS) code, EPA reclassified the 2008 DMR data by the equivalent NAICS code. Table 6-1

lists the number of facilities from the U.S. Economic Census and the screening-level databases 

for the three NAICS codes with operations in the Fertilizer Manufacturing Category, including 

the corresponding SIC codes for reference. The U.S. Economic Census includes more facilities 

than the screening-level databases because of many possible factors including: facilities may not 

meet TRI-reporting thresholds, facilities may discharge to a publicly owned treatment works 

(POTW), and some facilities in the U.S. Economic Census are distributors or sales facilities, not 

manufacturers. 
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-2

Table 6-1. Number of Fertilizer Manufacturing Facilities 

NAICS Code Corresponding SIC Code 

Number of Facilities

2002 U.S. 

Economic 

Census 

2008 DMR 

Database a

2008 TRI 

Database b

325311: Nitrogenous 

Fertilizer Manufacturing 

2873: Nitrogenous 

Fertilizers 

144 63 42 

325312: Phosphatic 

Fertilizer Manufacturing 

2874FER: Phosphatic 

Fertilizers c

45 2 d 17 e

325314: Fertilizer (Mixing 

Only) Manufacturing 

2875: Fertilizer (Mixing 

Only) Manufacturing 

534 54 57 

Total 723 119 116 

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2; and TRIReleases2008_v3. 

a – Includes both major and minor dischargers. Also, DMR data is reported by SIC code; therefore EPA used an 

NAICS to SIC crosswalk for comparison purposes. 

b – Facilities reporting releases to any media. 

c – Wastewater generated by facilities in SIC code 2874 can be regulated under multiple categories. Most facilities 

in SIC code 2874 are grouped under the Phosphate Manufacturing Category (40 CFR Part 422). EPA reviewed 

available information about pollutant loads and manufacturing operations for facilities reporting this SIC code. In its 

crosswalk, EPA assigned the extension “FER” to the end of the SIC codes for facilities that most likely fall under 

the applicability of 40 CFR Part 418, Fertilizer Manufacturing (U.S. EPA, 2006). 

d – Includes facilities that EPA determined were subject to the Fertilizer Manufacturing Effluent Limitations 

Guidelines and Pretreatment Standards (ELGs) as part of the 2006 annual review reporting SIC code 2874: 

Phosphatic Fertilizers (U.S. EPA, 2006). 

e – EPA identified an error in the TRIReleases2008_v3 database, and pollutant loads for facilities with NAICS code 

325312 are currently associated with the Phosphate Manufacturing Category (40 CFR Part 422) rather than the 

Fertilizer Manufacturing Category. The 2008 TRI TWPE for these facilities is only 657 TWPE (compared with the 

Fertilizer Manufacturing Category total of 826,000 TWPE). Therefore, the TWPE associated with facilities 

reporting NAICS code does not affect the category ranking. EPA will correct the error in future annual reviews. 

Table 6-2 shows whether permitting authorities designated direct discharging facilities in 

the Fertilizer Manufacturing Category as minor or major dischargers (see Section 4.1.5). EPA 

included data for minor dischargers in the 2010 annual review, as part of DMRLoads2008_v2

(for previous annual reviews, EPA included only major dischargers). EPA does not require 

permitting authorities to submit DMR data for minor dischargers; however, many states do 

provide complete DMR data for them. From the 2010 annual review, EPA observed many data 

entry or other errors for minor dischargers in addition to those previously identified for major 

dischargers, as discussed in Section 4.3. Table 6-2 shows that approximately 81 percent of the 

Fertilizer Manufacturing Category dischargers in the 2008 DMR database are minor dischargers. 

However, as shown in Table 6-6, the TWPE from the minor dischargers is negligible compared 

to the facilities with the greatest TWPE in this category (i.e., major dischargers). 
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-3

Table 6-2. Number of Fertilizer Manufacturing Facilities by Discharge Classification in 

2008 DMR Database 

NAICS Code a 

Number of Facilities in 2008 DMR Database 

Major Dischargers Minor Dischargers All Dischargers 

325311: Nitrogenous Fertilizer Manufacturing 21 42 63 

325312: Phosphatic Fertilizer Manufacturing 2 0 2 

325314: Fertilizer (Mixing Only) Manufacturing 0 54 54 

Total 23 96 b 119 

Source: DMRLoads2008_v2. 

a – DMR data is reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison 

purposes. 

b – The DMR data in PCS and ICIS-NPDES do not include discharge data for all minor dischargers. For the 

facilities in the Fertilizer Manufacturing Category, 32 of the 96 minor dischargers have DMR data. 

Table 6-3 presents the type of discharges reported by facilities in the 2008 TRI database. 

The majority of fertilizer manufacturing facilities reporting to TRI reported direct discharges to 

surface waters. 

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

Database 

NAICS Code 

Number of Facilities in 2008 TRI Database 

Direct 

Dischargers 

Only 

Indirect 

Dischargers 

Only 

Both Indirect 

and Direct 

Dischargers 

No Water 

Discharges 

325311: Nitrogenous Fertilizer Manufacturing 23 2 2 15 

325312: Phosphatic Fertilizer Manufacturing 8 1 1 7 

325314: Fertilizer (Mixing Only) Manufacturing 11 3 1 42 

Total 42 6 4 64 

Source: TRIReleases2008_v3.

6.1.2 40 CFR Part 418 

EPA first promulgated ELGs for the Fertilizer Manufacturing Category (40 CFR Part 

418) on April 8, 1974 (39 FR 12836) for the Basic Fertilizer Chemicals Segment and on January 

14, 1975 (40 FR 2652) for the Formulated Fertilizer Chemicals Segment. The Fertilizer 

Manufacturing ELGs are applicable to process wastewater and contaminated nonprocess 

wastewater discharged from the specific subcategories listed in Table 6-4. The seven 

subcategories are based on the type of fertilizer produced. 
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-4

Table 6-4. Subcategories in the Fertilizer Manufacturing Category 

Subpart Title Description 

A Phosphate Subcategory a Manufacture of sulfuric acid by sulfur burning, wet-process 

phosphoric acid, normal superphosphate, triple superphosphate, 

and ammonium phosphate.

B Ammonia Subcategory Manufacture of ammonia. 

C Urea Subcategory Manufacture of urea. 

D Ammonium Nitrate Subcategory Manufacture of ammonium nitrate. 

E Nitric Acid Subcategory Production of nitric acid in concentrations up to 68 percent. 

F Ammonium Sulfate Production 

Subcategory 

Production of ammonium sulfate by the synthetic process and 

by coke oven by-product recovery. 

G Mixed Blend Fertilizer Production 

Subcategory 

Production of mixed b and blend c fertilizer. 

Source: Fertilizer Manufacturing Point Source Category - 40 CFR Part 418 and Preliminary Review of Prioritized 

Categories of Industrial Dischargers (U.S. EPA, 2005). 

a – The applicability of Subpart A excludes certain wet-process phosphoric acid processes from best practicable 

control technology (BPT) and best available technology economically achievable (BAT) limitations. The exclusion 

applies to processes that were under construction either on or before April 8, 1974, at plants located in the state of 

Louisiana. 

b – Mixed fertilizer means “a mixture of wet and/or dry straight fertilizer material, mixed fertilizer materials, fillers 

and additives prepared through chemical reaction to a given formulation.” 

c – Blend fertilizer means “a mixture of dry, straight and mixed fertilizer materials.” 

6.2 Fertilizer Manufacturing Category 2010 Screening-Level Review

Table 6-5 compares the screening-level review results for the Fertilizer Manufacturing 

Category from the 2006 through 2010 annual reviews. The combined TWPE from discharges in 

the DMR and TRI databases decreased from discharge years 2002 to 2008. The estimated 2008 

DMR TWPE dominates the estimated 2008 category TWPE, composing approximately 99 

percent of the combined 2008 DMR and TRI TWPE, similar to previous years of data. 

Table 6-5. Fertilizer Manufacturing Category TRI and DMR Discharges for the 2006 

through 2010 Screening-Level Reviews 

Year of Discharge Year of Review 

Fertilizer Manufacturing Category 

TRI TWPE DMR TWPE a Total TWPE 

2002 2006 9,100 1,370,000 1,380,000 

2004 2007 10,800 1,170,000 1,180,000 

2005 2008 7,300 NA NA 

2007 2009 4,460 1,095,000 1,100,000 

2008 2010 8,120 818,000 826,000 

Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; 

TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; and DMRLoads2008_v2. 

a – DMR data from 2002 through 2007 includes only major dischargers. 2008 DMR data includes both minor and 

major dischargers. 

NA – Not applicable. EPA did not evaluate DMR data for 2005. 
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-5

Table 6-6 presents the 2008 DMR TWPE by facility discharge classification. EPA 

excluded minor dischargers from previous annual reviews, but included them in the 2010 annual 

review. The majority (98 percent) of the TWPE in the 2008 DMR database results from major 

dischargers. 

Table 6-6. Fertilizer Manufacturing Category 2008 DMR TWPE by Discharge 

Classification 

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers 

2008 16,300 802,000 

Source: DMRLoads2008_v2. 

a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous 

annual reviews. 

6.3 Fertilizer Manufacturing Category Pollutants of Concern

Table 6-7 lists the five pollutants with the highest TRI TWPE based on results from the 

2010, 2009, and 2007 annual reviews (TRIReleases2008_v3, TRIReleases2007_v2, and 

TRIReleases2004_ v3, respectively). Table 6-8 lists the five pollutants with the highest TWPE 

based on results from the 2010, 2009, and 2007 annual reviews (DMRLoads2008_v2, 

DMRLoads2007_v3, and PCSLoads2004_v4, respectively). 
Section 6 – Fertilizer Manufac

6-6

Table 6-7. Fertilizer Manufacturing Category Top TRI Pollutants 

Pollutant 

2004 TRI Data a 2007 TRI Data a 20

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Nitrate Compounds 1 31 3,560 1 19 2,250 1 Polycyclic Aromatic Compounds 3 1 1,570 

Pollutant not reported in the top five 

2007 TRI reported pollutants. 2 

Chlorine 5 8 1,210 2 5 653 3 Mercury and Mercury Compounds 

Pollutant not reported in the top five 

2004 TRI reported pollutants. 3 2 648 4 

Copper and Copper Compounds 4 13 1,240 5 4 228 5 Zinc and Zinc Compounds 

Pollutant not reported in the top five 

2004 TRI reported pollutants. 4 5 240 Pollutants no

Dioxin and Dioxin-Like 2008 TRCompounds 2 1 1,960 

Pollutant not reported in the top five 

2007 TRI reported pollutants. 

Fertilizer Manufacturing Category Total NA 47 b 10,850 NA 29 b 4,460 c NA 

Source: TRIReleases2004_v3; TRIReleases2007_v2; and TRIReleases2008_v3. 

a – Discharges include transfers to POTWs and account for POTW removals. b – Number of facilities reporting TWPE greater than zero. c – EPA identified an error in the TRIReleases2007_v2 and TRIReleases2008_v3 databases, and pollutant loads associated with facilitie

325312 are currently associated with the Phosphate Manufacturing Category (40 CFR Part 422) rather than the Fertilizer Manufacturing 

correct the error in future years of the TRI database. The TWPE for these facilities is less than 10 percent of the total TWPE for both ye

and 657 TWPE for 2008). NA – Not applicable.
Section 6 – Fertilizer Manufac

6-7

Table 6-8. Fertilizer Manufacturing Category Top DMR Pollutants 

Pollutant 

2004 DMR Data a 2007 DMR Data a 200

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Fluoride 1 4 1,120,000 1 3 1,055,000 1 Ammonia as Nitrogen 4 19 4,520 4 16 2,400 2 Aluminum 2 1 16,700 3 1 10,600 3 Cadmium 3 2 16,600 2 2 25,400 4 2,4-Dichlorophenoxyacetic Acid 

Pollutant not reported in the top five 

2004 DMR reported pollutants. 

Pollutant not reported in the top five 

2007 DMR reported pollutants.

5 

Nitrogen, nitrate total (as N) 

5 12 4,080 5 11 782 Pollutant no

2008 DM

Fertilizer Manufacturing Category Total 

NA 22 c 1,170,000 NA 19 c 1,100,000 NA 

Source: PCSLoads2004_v4; DMRLoads2007_v3; and DMRLoads2008_v2. 

a – 2004 and 2007 DMR data includes only major dischargers. b – 2008 DMR data include major and minor dischargers. c – Number of facilities reporting a TWPE of greater than zero. NA – Not applicable.
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-8

The Fertilizer Manufacturing Category TWPE in the 2008 TRI database is significantly 

lower than the TWPE in the 2008 DMR database. Therefore, EPA focused the preliminary 

category review on the DMR-reported pollutants that account for the majority of the category 

TWPE. 

Fluoride is the top DMR-reported pollutant in 2004, 2007, and 2008, contributing more 

than 95 percent of the total category TWPE. EPA’s preliminary review focused on discharges of 

fluoride and the review results are presented in the following subsections. EPA did not 

investigate the other top pollutants as part of the 2010 annual review because the other pollutants 

represent a small percentage (6 percent) of the combined 2008 DMR and TRI TWPE for the 

Fertilizer Manufacturing Category. 

6.4 Fertilizer Manufacturing Category Fluoride Discharges in DMR

The 2010 annual review of the Fertilizer Manufacturing Category focused on fluoride 

discharges in the 2008 DMR database. Table 6-9 presents the facilities that account for all of the 

fluoride discharges in the 2008 and 2007 DMR databases. The decrease in fluoride TWPE from 

2007 to 2008 likely results from decreased flow in 2008, as flow fluctuates with rain events. 

The majority (91 percent) of the fluoride discharges in 2008 were from Mosaic 

Fertilizers, LLC in Uncle Sam, LA. The other two facilities, IMC Phosphates in St. James, LA 

and Mississippi Phosphates Corp in Pascagoula, MS account for the remaining 9 percent. 

Fluoride is generated in the manufacture of wet-process phosphoric acid that is used in 

phosphatic fertilizer manufacturing (U.S. EPA, 1974). See the Technical Support Document for 

the 2006 Effluent Guidelines Program Plan (U.S. EPA, 2006) for descriptions of the wet-process 

phosphoric acid process (Section 8.5.1), wastewater sources of fluoride (Section 8.5.2), and 

wastewater treatment of fluoride (Section 8.5.3). The subsections below provide information on 

the facilities that discharge the highest amounts of fluoride. 
Section 6 – Fertilizer Manufac

6-9

Table 6-9. Top Fluoride Discharging Facilities in 2007 and 2008 DMR Databases 

Facility Name Facility Location 

2007 2

Pounds of 

Fluoride 

Discharged Fluoride TWPE 

Percentage of 

Fertilizer 

Manufacturing

Category’s 2007 

DMR Fluoride 

TWPE 

Pounds of 

Fluoride 

Discharged 

Fluo

TW

Mosaic Fertilizer, LLC Uncle Sam, LA 27,300,000 957,000 91% 23,500,000 705IMC Phosphates Co. St James, LA 2,140,000 75,900 7% 2,000,000 59,Mississippi Phosphates Corp. Pascagoula, MS 665,000 23,300 2% 452,000 13,Total 30,200,000 1,055,000 100% 25,900,000 778

Source: DMRLoads2007_v3 and DMRLoads2008_v2. a – Major and minor dischargers. 
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-10

6.4.1 Top Facility Permit Compliance 

Both of the top facilities in the Fertilizer Manufacturing Category are phosphate fertilizer 

manufacturers. Phosphate fertilizer manufacturers are subject to 40 CFR Part 418 Subpart A – 

Phosphate Subcategory. Subpart A BAT includes limits on flow-based surge capacity and 

pollutant discharge concentrations. The flow-based requirements are: 

• Zero discharge of wastewater except from the gypsum storage and disposal area; 

• Maintenance of a surge capacity for a 10-year, 24-hour storm event (BPT) or a 

25-year, 24-hour storm event (BAT) in the gypsum storage and disposal area; 

• If stored wastewater reaches 50 percent of the required surge capacity, the facility 

is allowed to discharge treated wastewater; 

• If stored wastewater exceeds 50 percent of the required surge capacity, the facility 

is required to treat and discharge wastewater; and 

• During discharge events, facilities are required to meet limitations for 

phosphorous, fluoride (25 mg/L monthly average and 75 mg/L daily maximum), 

total suspended solids, and pH (U.S. EPA, 1974). 

Facilities minimize the volume of wastewater discharged by impounding and 

recirculating all direct contact process wastewater, including stormwater runoff from active 

gypsum storage and disposal areas. This recirculation leads to an accumulation of fluoride, 

phosphorous, and radium in the wastewater with concentrations in excess of 8,500 mg/L 

fluoride, 5,000 mg/L phosphorous, and 60 pCi/L radium 226. Additionally, the wastewater is 

typically very acidic with a pH of between one and two. Several facilities report that they have 

not treated or discharged wastewater for several years. For the 1974 rulemaking, EPA 

determined that most facilities would discharge continuously between two and four months of 

the year due to excess wastewater in the impoundment from rainfall (U.S. EPA, 1974). 

The applicability of Subpart A excludes certain wet-process phosphoric acid processes 

from BPT, BAT, and BCT limitations that were under construction either on or before April 8, 

1974, at plants located in the state of Louisiana. As a result, the Mosaic Fertilizers facility in 

Uncle Sam, LA and IMC Phosphates facility in St. James, LA are excluded from Subpart A. 

Permit writers limit discharges from these facilities using best professional judgment (BPJ) (see 

52 FR 28428, July 29, 1987). Table 6-10 presents the outfall descriptions and the permit limits 

and findings for both facilities. For some portion of the discharges from the Mosaic Fertilizers’ 

Uncle Sam and IMC Phosphates’ St. James facilities, BPJ permits incorporate Subpart A 

requirements. 
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-11

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

Name 

Outfall with 

Fluoride 

Discharges 

Fluoride Permit 

Limits Permit Findings 

Mosaic Fertilizers 

LLC – Uncle Sam, 

LA

001: Once-through 

cooling water, 

scrubber water, 

nonprocess 

wastewater, fertilizer 

area stormwater, 

inactive gypsum 

storage area, and 

active gypsum 

storage area 

Limits for outfall 

001 excluding 

inactive and active 

gypsum storage area 

discharges: 

165,000 lb/day 

monthly average 

222,800 lb/day daily 

maximum a

• Acknowledges exemption of flow 

requirements; 

• Portion of gypsum storage and disposal are 

designated inactive; 

• Stormwater from inactive storage and 

disposal area discharged without treatment; 

Fundamentally Different Factor (FDF) 

granted to exempt facility from recycling 

process wastewater by installing fluoride 

scrubber; 

• Gypsum storage area must meet BAT 

requirements; 

• Optional discharge of treated wastewater 

below 50% surge capacity; 

• Required discharge of treated wastewater 

above 50% storage capacity. 

IMC Phosphates – 

St. James, LA 

001: Active gypsum 

storage area, process 

wastewater, 

stormwater, 

nonprocess 

wastewater, and 

noncontact cooling 

water 

25 mg/L monthly 

average 

75 mg/L daily 

maximum 

• No acknowledgement of exemption of flow 

requirements; 

• No discharge of process wastewater; 

• Gypsum storage area must meet BAT 

requirements; 

• Optional discharge of treated wastewater 

below 50% surge capacity; 

• Required discharge of treated wastewater 

above 50% storage capacity. 002: Inactive 

gypsum storage area 

Monitor and report 

fluoride discharges 

Source: Facility Permits (LDEQ, 2003; LDEQ, 2004a; and LDEQ, 2004b). 

a – Mass-based fluoride limitations are based on fluoride removal efficiency of the scrubber. 

6.4.2 Mosaic Fertilizers, LLC in Uncle Sam, LA 

Table 6-11 presents the monthly discharge data for Mosaic Fertilizers’ Uncle Sam 

facility, compared to the mass-based fluoride permit limit. Table 6-11 also includes a calculated 

monthly average concentration for the facility and the 40 CFR Part 418 concentration-based limit 

(25 mg/L). EPA calculated the monthly average concentration using the average quantity and 

flow data in the DMR Loadings Tool. 
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-12

Table 6-11. Mosaic Fertilizers 2008 Monthly Fluoride Discharge Data and 40 CFR Part 

418 Monthly Average Limitations 

Outfall 

Monitoring 

Period Date 

Average 

Fluoride 

Quantity from 

DMR data 

(lb/day) 

Monthly 

Average 

Fluoride Permit 

Limit (lb/day) 

Calculated 

Fluoride 

Concentration 

(mg/L) a

40 CFR Part 418 

Monthly 

Average 

Fluoride Limit 

(mg/L) b

001 31-Jan-08 62,872 165,000 143 25 

001 29-Feb-08 74,246 165,000 153 25 

001 31-Mar-08 77,855 165,000 156 25 

001 30-Apr-08 126,387 165,000 193 25 

001 31-May-08 88,278 165,000 139 25 

001 30-Jun-08 4,899 165,000 7.26 25 

001 31-Jul-08 94,499 165,000 141 25 

001 31-Aug-08 102,640 165,000 142 25 

001 30-Sep-08 18,978 165,000 72.6 25 

001 31-Oct-08 70,030 165,000 117 25 

001 30-Nov-08 49,890 165,000 88.6 25 

001 31-Dec-08 787 165,000 3.53 25 

Source: DMR Loadings Tool and Facility Permit (LDEQ, 2003). 

a – Concentration was calculated using the monthly quantity (lb/day) and flow (million gallons per day). 

b – The 40 CFR Part 418 Subpart A limit for fluoride discharges is 25 mg/L when the facilities are discharging. 

The 2008 DMR database includes over 23 millions pounds of fluoride discharged by 

Mosaic Fertilizers’ Uncle Sam facility. The facility permit has a maximum fluoride permit limit 

of 165,000 lb/day, set by permit writers using BPJ. The facility is not exceeding the mass-based 

permit limit; however, the limit is exceedingly high compared to the effluent guidelines that 

apply to other facilities in the subcategory. Additionally, the fluoride concentrations from this 

outfall range from 3.3 mg/L to 193 mg/L, the majority of which are greater than the treatable 

concentrations reported in the Development Document for Effluent Limitations Guidelines and 

New Source Performance Standards for the Basic Fertilizer Chemicals Segment of the Fertilizer 

Manufacturing Point Source Category (1974 Development Document) (U.S. EPA, 1974). 

6.4.3 IMC Phosphates in St. James, LA 

Table 6-12 presents the 2008 fluoride discharges for IMC Phosphates’ two outfalls. From 

the facility permit, outfall 001 is the outfall for the active gypsum storage area, process 

wastewater, stormwater, nonprocess wastewater, and noncontact cooling water. Discharges from

outfall 001 must meet the 40 CFR Part 418 Subpart A fluoride limits (LDEQ, 2004a; LDEQ, 

2004b); IMC Phosphates met these limits in 2008. Outfall 002 is the outfall for the inactive 

gypsum storage area. The permit only requires reporting of fluoride discharges from outfall 002 

(i.e., no numerical limit). EPA focused the additional review of IMC Phosphates’ fluoride 

discharges on outfall 002 because the discharges from this outfall contain the majority of the 

facility’s fluoride TWPE and it does not have the 40 CFR Part 418 Subpart A fluoride limit. 
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-13

Table 6-12. IMC Phosphates 2008 Fluoride Discharges 

Outfall 

Fluoride Permit Limits 

(mg/L) 

Average Fluoride 

Concentration (mg/L)

Pounds of Fluoride 

Discharged (lb/yr) Fluoride TWPE 

001 25 mg/L monthly average 

75 mg/L daily maximum 

2.13 49,700 1,490 

002 Report only 382 1,950,000 58,400 

Source: DMRLoads2008_v2 and Facility Permits (LDEQ, 2004a and LDEQ, 2004b). 

Table 6-13 presents the monthly discharge data for IMC Phosphates outfall 002, 

compared to the fluoride permit limit and the 40 CFR Part 418 Subpart A concentration-based 

fluoride limit (25 mg/L). 

Table 6-13. IMC Phosphates Outfall 002 2008 Monthly Fluoride Discharge Data and 40 

CFR Part 418 Monthly Average Limitations

Outfall 

Monitoring 

Period Date 

Average Fluoride 

Concentration 

(mg/L) 

40 CFR Part 418 

Monthly Average 

Fluoride Limit (mg/L) 

Facility Permit Monthly Average 

Fluoride Limit (mg/L) 

002 31-Jan-08 523 25 Report Only (No Limit) 

002 29-Feb-08 454 25 Report Only (No Limit) 

002 31-Mar-08 555 25 Report Only (No Limit) 

002 30-Apr-08 NA 25 Report Only (No Limit) 

002 31-May-08 718 25 Report Only (No Limit) 

002 30-Jun-08 365 25 Report Only (No Limit) 

002 31-Jul-08 383 25 Report Only (No Limit) 

002 31-Aug-08 360 25 Report Only (No Limit) 

002 30-Sep-08 297 25 Report Only (No Limit) 

002 31-Oct-08 449 25 Report Only (No Limit) 

002 30-Nov-08 279 25 Report Only (No Limit) 

002 31-Dec-08 234 25 Report Only (No Limit) 

Source: DMR Loadings Tool. 

NA – Not available. The DMR Loadings Tool does not have a fluoride concentration for IMC Phosphates for April 

2008. 

The 2008 DMR database includes close to 2 millions pounds of fluoride discharged by 

IMC Phosphates for outfall 002. The facility permit does not limit discharges of fluoride from 

outfall 002; however, the concentrations are exceeding the effluent guidelines (25 mg/L) that 

apply to other outfalls at the facility and at other facilities within the subcategory. Additionally, 

the fluoride concentrations from this outfall range from 234 mg/L to 718 mg/L, all of which are 

greater than the treatable concentrations reported in the 1974 Development Document (U.S. 

EPA, 1974). 

6.5 Fertilizer Manufacturing Category Conclusions

The estimated toxicity of the Fertilizer Manufacturing Category discharges results mainly 

from the fluoride discharges of two plants (accounting for 95 percent of the category’s 2008 
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-14

DMR TWPE). Data collected for the 2010 annual review demonstrated that wastewater 

discharge characteristics for this category are consistent with discharges from prior years. As in 

prior years, EPA makes the following conclusions: 

• The fluoride discharges were verified in the 2008 DMR database for Mosaic 

Fertilizers’ Uncle Sam facility and IMC Phosphates’ St. James facility, both 

phosphate fertilizer manufacturers in Louisiana. These facilities are exempt from 

40 CFR Part 418 Subpart A, and the permits are based on BPJ and include 

fluoride limits or reporting only requirements. EPA concludes that these facilities 

do not represent the category as a whole because they are exempt from Part 418 

(see 52 FR 28428, July 29, 1987). However, fluoride is discharged at 

concentrations above the treatable concentrations reported in the 1974 

Development Document (U.S. EPA, 1974). 

• The total 2008 TWPE excluding the fluoride discharges from Mosaic Fertilizers’ 

Uncle Sam and IMC Phosphates’ St. James facilities is 61,100 TWPE. 

EPA prioritizes point source categories with existing regulations for potential revision 

based on the greatest estimated toxicity to human health and the environment, measured as 

TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for 

revision (i.e., this category is marked with “(3)” in the “Findings” column in Table V-1 in the 

Federal Register notice that presents the 2010 annual review of existing ELGs). 

6.6 Fertilizer Manufacturing Category References

1. LDEQ. 2003. Louisiana Department of Environmental Quality. Office of Environmental 

Services Water Discharge Permit and Fact Sheet NPDES LA0004847 – IMC Phosphates 

Company Uncle Sam Plant, Uncle Sam, LA. Baton Rouge, LA. (June 16). EPA-HQ-OW2004-0032-1773. 

2. LDEQ. 2004a. Louisiana Department of Environmental Quality. Water Discharge Permit 

for NPDES LA0029769 – IMC Phosphates Company, Faustina Plant, St. James, LA. 

Baton Rouge, LA. EPA-HQ-OW-2004-0032-1134. 

3. LDEQ. 2004b. Louisiana Department of Environmental Quality. Water Discharge Permit 

Fact Sheet for NPDES LA0029769 – IMC Phosphates Company, Faustina Plant, St. 

James, LA. Baton Rouge, LA. EPA-HQ-OW-2004-0032-1134. 

4. U.S. Census. 2002. U.S. Economic Census. Available online at: 

http://www.census.gov/econ/census02. 

5. U.S. EPA. 1974. Development Document for Effluent Limitations Guidelines and New 

Source Performance Standards for the Basic Fertilizer Chemicals Segment of the 

Fertilizer Manufacturing Point Source Category. EPA-440/1-75/042-a. Washington, DC. 

(March). 
Section 6 – Fertilizer Manufacturing (40 CFR Part 418) 

6-15

6. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial 

Dischargers. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-

0053. 

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

Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-1

7. INORGANIC CHEMICALS MANUFACTURING (40 CFR PART 415)

EPA identified the Inorganic Chemicals Manufacturing (Inorganic Chemicals) Point 

Source Category (40 CFR Part 415) for preliminary review because it continues to rank high, in 

terms of toxic-weighted pound equivalent (TWPE), in point source category rankings (see Table 

5-3 for the point source category rankings). This industry was reviewed previously in each of 

EPA’s Preliminary and Final Effluent Guidelines Program Plans from 2004 to 2009, except for 

2008 (U.S. EPA, 2004; U.S. EPA, 2005; U.S. EPA, 2006; U.S. EPA, 2007; U.S. EPA, 2009). 

This section summarizes the results of the 2010 annual review associated with the Inorganic 

Chemicals Category. EPA focused on discharges of metals because of their high TWPE relative 

to the rest of the Inorganic Chemicals Category. 

This section describes the results of EPA’s 2010 preliminary category review of the 

Inorganic Chemicals Category. EPA is currently reviewing discharges from the Chlor-Alkali 

Subcategory as part of the Chlorine and Chlorinated Hydrocarbons (CCH) Effluent Limitations 

Guidelines and Standards (ELGs) rulemaking. Because a rulemaking for this segment of the 

Inorganic Chemicals Category is underway, EPA excluded discharges from these facilities from 

further consideration in this review (see Table V-1, 73 FR 53218, September 15, 2008). 

7.1 Inorganic Chemicals Category Background

This subsection provides background on the Inorganic Chemicals Category including a 

brief profile of the inorganic chemicals industry and background on 40 CFR Part 415. 

7.1.1 Inorganic Chemicals Industry Profile 

The inorganic chemicals manufacturing industry includes a broad class of facilities 

encompassing the manufacture of substances that do not include carbon and its derivatives as 

their principal elements. EPA considered the following seven North American Industry 

Classification System (NAICS) codes as part of the Inorganic Chemicals Category: 

• 325120: Industrial Gases; 

• 325131: Inorganic Pigments; 

• 325181: Alkalies and Chlorine; 

• 325188: All Other Basic Inorganic Chemical Manufacturing; 

• 325998INORG: All Other Miscellaneous Chemical Product and Preparation; 

• 331311: Alumina Refining; and 

• 325510INORG: Paint and Coating Manufacturing. 

Wastewater generated by facilities in NAICS codes 325998 and 325510 may be regulated 

under multiple point source categories. For example, most facilities in NAICS 325510 are 

grouped under Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category (40 

CFR Part 414). EPA reviewed available information about pollutant loads and manufacturing 

operations for facilities reporting these NAICS codes. In its crosswalk, EPA assigned the 

extension “INORG” to the end of the NAICS codes of facilities that most likely fall under the 

applicability of the Inorganic Chemicals Point Source Category (40 CFR Part 415). 

This list of Standard Industrial Classification (SIC) codes includes facilities that EPA 

determined are potential new subcategories to the Inorganic Chemicals Category. As part of the 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-2

2004 annual review, EPA reviewed industries with SIC codes not clearly subject to existing 

ELGs. EPA concluded that the processes, operations, wastewaters, and pollutants of facilities in 

the following SIC codes are similar to those of the Inorganic Chemicals Category (U.S. EPA, 

2004):12

• 2812: Alkalies and Chlorine; 

• 2813: Industrial Gases; 

• 2816: Inorganic Pigments; and 

• 2819: Industrial Inorganic Chemicals. 

As part of the 2009 annual review, EPA reclassified these SIC codes as equivalent NAICS codes 

for use with the U.S. Economic Census and Toxics Release Inventory (TRI) data that are 

reported by NAICS code. However, there is not a direct relationship between one SIC and one 

NAICS codes. As a result, EPA included the following NAICS codes in the 2010 annual review 

of the Inorganic Chemicals Category because they contain facilities with operations that are 

similar to the SIC codes above: 

• 325120: Industrial Gases; 

• 325131: Inorganic Pigments; 

• 325181: Alkalies and Chlorine; 

• 325188: All Other Basic Inorganic Chemical Manufacturing; 

• 331311: Alumina Refining; and 

• 325510INORG: Paint and Coating Manufacturing. 

Because Permit Compliance System (PCS) and Integrated Compliance Information 

System – National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the 

sources of the discharge monitoring report (DMR) data used to develop DMRLoads2008, report 

facilities by SIC codes, and the U.S. Economic Census and TRI report data by NAICS code, 

EPA reclassified the 2008 DMR data by the equivalent NAICS code. Table 7-1 lists the number 

of facilities from the U.S. Economic Census and the screening-level databases for the seven 

NAICS codes with operations in the Inorganic Chemicals Category the corresponding SIC codes 

are included for reference. The U.S. Economic Census includes more facilities than the 

screening-level databases because of many possible factors including not meeting TRI-reporting 

thresholds, discharging to a publicly owned treatment works (POTW), and because some of 

those in the U.S. Economic Census are distributors or sales facilities, not manufacturers. 

 

12 The tables in this section include discharge information from facilities reporting these SIC codes and the 

corresponding NAICS codes; however, these facilities contribute negligible amounts of TWPE. Consistent with the 

conclusions drawn during the 2004 detailed study (U.S. EPA, 2004) and 2006 review (U.S. EPA, 2006), EPA found 

that large numbers of these facilities discharge no wastewater and only a small number of facilities discharge TWPE 

greater than zero. 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-3

Table 7-1. Number of Inorganic Chemicals Manufacturing Facilities 

NAICS Code 

Corresponding 

SIC Code 

Number of Facilities 

2002 U.S. 

Economic 

Census 

2008 DMR 

Database a

2008 TRI 

Database b

325120: Industrial Gas Manufacturing 

2813: Industrial 

Gases 

2816: Inorganic 

Pigments 

2819: Industrial 

Inorganic 

Chemicals, NEC 

572 440 70 

325131: Inorganic Dye and Pigment 

Manufacturing 

81 41 

325188: All Other Basic Inorganic 

Chemical Manufacturing 

631 276 

325510INORG: Paint and Coating 

Manufacturing 

NA 2 

325998INORG: All Other Miscellaneous 

Chemical Product and Preparation 

NA 12 

331311: Alumina Refining 10 6 

325181: Alkalies and Chlorine 

Manufacturing 

2812: Alkalies 

and Chlorine 

41 12 6 

Total >1,335 452 413 

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads20008_v2; and TRIReleases2008_v3. 

a – Includes both major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an 

NAICS to SIC crosswalk for comparison purposes. 

b – Releases to any media. 

NA – Not applicable. These facility-specific NAICS codes do not correspond to NAICS codes in the 2002 U.S. 

Economic Census. 

NEC – Not elsewhere classified. 

Table 7-2 shows whether permitting authorities designated direct discharging facilities in 

the Inorganic Chemicals Category as minor or major dischargers (see Section 4.1.5). EPA 

included data for minor dischargers for the first time in the 2010 annual review, as part of 

DMRLoads2008_v2 database. EPA does not require permitting authorities to submit DMR data 

for minor dischargers; however, many states do provide complete DMR data for minor 

dischargers. From the 2010 annual review, EPA observed many data entry or other errors for 

minor dischargers in addition to those previously identified for major dischargers, as discussed in 

Section 4.3. Table 7-2 shows that approximately 86 percent of the Inorganic Chemicals Category 

dischargers in the 2008 DMR database are minor dischargers. 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-4

Table 7-2. Number of Inorganic Chemical Facilities by Facilities by Discharge 

Classification in 2008 DMR Database 

NAICS Code 

Number of Facilities in 2008 DMR Database 

Major 

Dischargers 

Minor 

Dischargers 

All 

Dischargers 

325120: Industrial Gas Manufacturing 

60 380 440 

325131: Inorganic Dye and Pigment Manufacturing 

325188: All Other Basic Inorganic Chemical 

Manufacturing 

325510INORG: Paint and Coating Manufacturing 

325998INORG: All Other Miscellaneous Chemical 

Product and Preparation 

331311: Alumina Refining 

325181: Alkalis and Chlorine Manufacturing 0 12 12 

Total 60 392 452 

Source: DMRLoads2008_v2. 

Table 7-3 presents the type of discharges reported by facilities in the 2008 TRI database. 

The majority of inorganic chemicals facilities reporting to TRI do not report water discharges, 

but those that do are almost evenly split between direct dischargers and indirect dischargers. 

Table 7-3. Number of Inorganic Chemicals Facilities by Discharge Type in 2008 TRI 

Database 

NAICS Code 

Number of Facilities in TRI 2008 Database 

Direct 

Dischargers 

Only 

Indirect 

Dischargers 

Only 

Both Indirect 

and Direct 

No Water 

Discharges 

325120: Industrial Gas 

Manufacturing 4 6 0 60 

325131: Inorganic Dye and Pigment 

Manufacturing 14 9 4 14 

325181: Alkalis and Chlorine 

Manufacturing 0 2 0 4 

325188: All Other Basic Inorganic 

Chemical Manufacturing 40 44 24 168 

325510INORG: Paint and Coating 

Manufacturing 1 0 1 0 

325998INORG: All Other 

Miscellaneous Chemical Product 

and Preparation 2 8 0 2 

331311: Alumina Refining 2 1 0 3 

Total 63 70 29 251 

Source: TRIReleases2008_v3. 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-5

7.1.2 40 CFR Part 415 

Wastewater discharges for the inorganic chemicals manufacturing industry are regulated 

under 40 CFR Part 415: Inorganic Chemicals Manufacturing Point Source Category. This 

category consists of 67 subcategories defined by the type of inorganic chemical product 

manufactured. In addition to best practicable control technology (BPT), best available 

technology economically achievable (BAT), best conventional pollutant control technology 

(BCT), and new source performance standards (NSPS), the category includes pretreatment 

standards for existing sources (PSES) and pretreatment standards for new sources (PSNS) 

limitations for at least one subcategory. Table 5-6 in the 2004 Effluent Guidelines Program Plan 

contains details on the pollutants regulated by each subpart (U.S. EPA, 2004). The effluent 

guidelines for the Inorganic Chemicals Category were first promulgated in 1974 and revised in 

1975, 1976, 1982, and 1986. 

7.2 Inorganic Chemicals Category Screening-Level Review

Table 7-4 compares the screening-level results for the Inorganic Chemicals Category 

from the 2006 through 2010 annual reviews that represented multiple years of data from the 

DMR and TRI databases. The combined DMR and TRI TWPE increased slightly from discharge 

years 2002 to 2004, but decreased from discharge year 2007 to 2008.

Table 7-4. Inorganic Chemicals Category TRI and DMR Discharges for the 2006 through 

2010 Screening-Level Reviews 

Year of Discharge Year of Review 

Inorganic Chemicals Category 

TRI TWPE DMR TWPE a Total TWPE 

2002 2006 186,000 107,000 293,000 

2004 2007 123,000 316,000 439,000 

2005 2008 92,100 NA NA 

2007 2009 54,700 394,000 449,000 

2008 2010 71,300 228,000 299,000 

Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; 

TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; and DMRLoads2008_v2. 

a – DMR data from 2002 through 2007 only includes major dischargers. 2008 DMR data includes both minor and 

major dischargers. 

NA – Not applicable. EPA did not evaluate DMR data for 2005. 

Table 7-5 presents the 2008 DMR TWPE by facility discharge classification. EPA 

excluded minor dischargers from previous annual reviews, but included them in the 2010 annual 

review. The majority (61 percent) of the TWPE in the 2008 DMR database is from major 

dischargers. 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-6

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

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers 

2008 89,000 139,000 

Source: DMRLoads2008_v2. 

a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous 

annual reviews. 

7.3 Inorganic Chemicals Category Pollutants of Concern

Table 7-6 compares the five pollutants with the highest TRI TWPE based on results from 

the 2010, 2009, and 2007 annual reviews (TRIReleases2008_v3, TRIReleases2007_v2, and 

TRIReleases2004_ v3). Table 7-7 lists the five pollutants with the highest TWPE based on results 

from the 2010, 2009, and 2007 annual reviews (DMRLoads2008_v2, DMRLoads2007_v3, and 

PCSLoads2004_v4). 
Section 7 – Inorganic Chemicals Manufac

7-7

Table 7-6. Inorganic Chemicals Category Top TRI Pollutants 

Pollutant 

2004 TRI Data a 2007 TRI Data a 20

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Manganese and Manganese Compounds 

1 29 67,400 1 22 14,600 1 

Mercury and Mercury Compounds 3 13 4,390 3 12 6,500 2 Arsenic and Arsenic Compounds Pollutants not reported in the top five 

2004 TRI reported pollutants. 

4 3 5,480 3 

Nitrate Compounds 4 48 3,970 5 41 3,570 4 Polychlorinated biphenyls (PCBs) Pollutants not reported in the top five 

2004 TRI reported pollutants. 

Pollutants not reported in the top five 

2007 TRI reported pollutants. 

5 

Dioxin and Dioxin Like Compounds 

2 5 25,000 2 5 11,600 

Pollutants no

Hexachlorobenzene 5 4 3,600 Pollutants not reported in the top five 2008 TR

2007 TRI reported pollutants. 

Inorganic Chemicals Category Total 

NA 191 b 123,000 NA 142 b 54,700 NA 

Source: TRIReleases2004_v3, TRIReleases2007_v2; and TRIReleases2008_v3. 

a – Discharges include transfers to POTWs and account for POTW removals. b – Number of facilities reporting TWPE greater than zero. NA – Not applicable. 
Section 7 – Inorganic Chemicals Manufac

7-8

Table 7-7. Inorganic Chemicals Category Top DMR Pollutants 

Pollutant 

2004 DMR Data a 2007 DMR Data a 200

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Aluminum Pollutants not reported in the top five 

DMR 2004 reported pollutants. 

Pollutants not reported in the top five 

DMR 2007 reported pollutants. 

1 

Mercury 2 Copper 5 27 29,800 5 23 2,050 3 Sulfide 1 2 87,900 Pollutants not reported in the top five 

DMR 2007 reported pollutants. 

4 

Silver 

Pollutants not reported in the top five 

DMR 2004 reported pollutants. 

5 

Polychlorinated biphenyls (PCBs) 

1 1 363,000 

Pollutants no

DMR 200

Chlorine 3 10 40,500 2 9 10,500 Fluoride Pollutants not reported in the top five 

DMR 2004 reported pollutants. 

3 7 4,590 

Heptachlor 4 1 2,140 Iron 4 8 29,900 Pollutants not reported in the top five Lead 2 14 52,400 DMR 2007 reported pollutants. Inorganic Chemicals Category Total 

NA 58 c 316,000 NA 51 c 394,000 NA 

Source: PCSLoads2004_v4; DMRLoads2007_v3; and DMRLoads2008_v2. 

a – 2004 and 2007 DMR data only include major dischargers. b – 2008 DMR data includes major and minor dischargers. c – Number of facilities reporting TWPE greater than zero. NA – Not applicable.
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-9

The Inorganic Chemicals Category TWPE in the 2008 TRI database is significantly lower 

than the 2008 DMR TWPE. Therefore, EPA focused the additional review on the DMR-reported 

pollutants that account for the majority of the category TWPE. 

EPA’s additional review for the 2008 DMR database metals discharges is presented in 

the following sections. During the review of metals discharges, EPA discovered that the majority 

of the top pollutants were discharged by the same four facilities in the 2008 DMR database. 

Table 7-8 presents the top pollutants discharged in the Inorganic Chemicals Category and the 

corresponding top facility discharger. 

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

Database 

Top Pollutant Facility Name 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Total 

Facility 

TWPE 

Other Top 

Pollutants 

Discharged 

Aluminum UOP LLC 875,000 52,500 58,200 None a

Mercury 

AL State Docks – Mud 

Lakes 221 25,900 28,400 Aluminum 

Elementis Chromium LP 

Castle 94.4 11,100 24,000 Silver 

Copper 

Dow Chemical, 

Pittsburg Plant 48,100 30,300 33,900 None a

Source: DMRLoads2008_v2. 

a – These facilities do not have discharges of other top five pollutants with significant discharges (TWPE great than 

1,000). 

7.4 Inorganic Chemicals Category Top Facility Dischargers in DMR

This subsection provides further detail on the top four facility dischargers in the 

Inorganic Chemicals Category responsible for the majority of the aluminum, mercury, copper, 

and silver TWPE. As a result of EPA’s review of discharges from the top facilities in the 

Inorganic Chemicals Category, the overall category 2008 DMR TWPE decreased by 121,900 

TWPE. 

7.4.1 UOP LLC in Chickasaw, AL 

Table 7-9 presents the discharges in the 2008 DMR database for UOP LLC. The majority 

of the facility TWPE (approximately 90 percent) is from aluminum. Aluminum discharges from 

UOP LLC account for 23 percent of the DMR TWPE for the Inorganic Chemicals Category. 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-10

Table 7-9. UOP LLC 2008 Top Discharges 

Pollutant Total Pounds Total TWPE 

Percentage of Facility 

Total TWPE 

Aluminum 875,000 52,500 90.2% 

Iron 783,000 4,380 7.5% 

Zinc 20,000 800 1.4% 

Chloride 9,230,000 225 0.4% 

Nickel 1,590 159 0.3% 

Total 191,000,000 58,200 100% 

Source: DMRLoads2008_v2. 

The majority of the aluminum discharges for UOP LLC are from outfalls 003 and 004. 

The facility’s permit indicates that outfalls 003 and 004 are “storm water runoff from nonprocess 

areas associated with molecular sieve adsorbents and catalysts manufacture.” The permit does 

include monitoring only requirements for aluminum for outfalls 003 and 004 (ADEM, 2002). 

Table 7-10 presents the aluminum discharge data for outfalls 003 and 004 in the DMR Loadings 

Tool for 2008. EPA contacted UOP LLC to verify the aluminum concentrations and flows. UOP 

LLC verified the aluminum values and units, but indicated that the flows for outfall 003 and 004 

had the wrong units (Frain, 2010). Table 7-10 also includes the facility-provided flows. Using 

the facility-provided flows for outfalls 003 and 004, UOP LLC’s aluminum discharges decrease 

by 46,200 TWPE, while the facility’s TWPE decreases from 58,200 TWPE to 7,110 TWPE. 

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

Outfall 

Monitoring Period 

Date 

Maximum 

Concentration 

(mg/L) 

DMR Loadings Tool 

Flow (MGD) 

Facility-Provided 

Flow (MGD) 

003 30-Jun-08 10 31.86 3.186 

003 31-Dec-08 0.1 20.33 2.033 

004 30-Jun-08 9 25.52 2.552 

004 31-Dec-08 1.025 16.29 1.629 

Source: DMR Loadings Tool and Facility Contact (Frain, 2010). 

7.4.2 AL State Docks Mud Lakes in Mobile, AL 

Table 7-11 presents the discharges in the 2008 DMR database for AL State Docks Mud 

Lakes. The majority of the facility TWPE (approximately 91 percent) is from mercury. Mercury 

discharges from AL State Docks Mud Lakes also account for almost 11 percent of the DMR 

TWPE for the Inorganic Chemicals Category. 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-11

Table 7-11. AL State Docks Mud Lakes 2008 Mercury and Aluminum Discharges 

Pollutant Total Pounds Total TWPE 

Percentage of Facility 

Total TWPE 

Mercury 221 25,900 91.2% 

Aluminum 41,600 2,500 8.8% 

Total 9,470,000 28,400 100% 

Source: DMRLoads2008_v2. 

AL State Docks Mud Lakes is a dock that serves as a transfer station for bulk cargo that 

is exported and imported. The dock site was a former aluminum ore tailing lakes operated by the 

Aluminum Company of America (ALCOA). These lakes are currently used to accumulate and 

treat aluminum ore tailings leachate prior to discharge to the Mobile River (ADEM, 2006). The 

facility contact indicated that it is not an industrial manufacturing site (Wright, 2010). 

All of the mercury discharges for AL State Docks Mud Lakes are from outfall 001. 

Outfall 001 is stormwater and groundwater from the aluminum tailings leachate collection 

system (ADEM, 2006). Table 7-12 presents the mercury discharge data for outfall 001 in the 

DMR Loadings Tool for 2008. EPA contacted AL State Docks Mud Lakes and the Alabama 

Department of Environmental Management (ADEM) to verify the mercury quantities. ADEM 

confirmed the mercury discharges (Brown, 2010). 

EPA determined that the discharges from this facility do not meet the applicability of the 

Inorganic Chemicals Category. Because this facility’s discharges are from aluminum ore mining, 

EPA believes this facility’s discharges are applicable to the Nonferrous Metals Manufacturing 

(40 CFR Part 421). However, because the facility no longer operates as an aluminum ore mine 

and processing facility, EPA believes the discharges should be permitted using best professional 

judgment. 

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

Data 

Outfall Monitoring Period Date Average Quantity (kg/day) 

001 31-Mar-08 NR 

001 30-Jun-08 0.000635 

001 30-Sept-08 0.776 

001 31-Dec-08 0.313 

Source: DMR Loadings Tool. 

NR – Not reported. 

7.4.3 Elementis Chromium LP in Castle Hayne, NC 

Table 7-13 presents the discharges in the 2008 DMR database for Elementis Chromium 

LP. The majority of the facility TWPE (approximately 79 percent) is from mercury and silver. 

Mercury and silver discharges from Elementis Chromium LP also account for 8 percent of the 

DMR TWPE for the Inorganic Chemicals Category. 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-12

Table 7-13. Elementis Chromium LP Plant 2008 Top Discharges 

Pollutant Total Pounds Total TWPE 

Percentage of Facility 

Total TWPE 

Mercury 94.4 11,100 46.3% 

Silver 471 7,760 32.3% 

Selenium 2,360 2,640 11.0% 

Lead 942 2,110 8.8% 

Chloride 7,980,000 194 0.8% 

Total 8,010,000 24,000 100% 

Source: DMRLoads2008_v2. 

All of the mercury discharges for Elementis Chromium LP are from outfall 001. Table 

7-14 presents the mercury discharge data for outfall 001 in the DMR Loadings Tool for 2008. 

EPA contacted Elementis Chromium LP to verify the mercury and silver concentrations and 

flows. Elementis Chromium LP verified the flows, but indicated that the mercury and silver 

concentrations were incorrect. The facility contact also indicated that mercury and silver are 

reported quarterly rather than monthly (Coury, 2010). Table 7-14 also includes the facilityprovided concentrations. Using the facility-provided concentrations, Elementis Chromium LP’s 

mercury discharges decrease by 18,800 TWPE, while the facility’s TWPE decreases from 24,000 

TWPE to 5,190 TWPE. 

Table 7-14. Elementis Chromium LP Outfall 001 2008 Monthly Mercury and Silver 

Discharge Data 

Outfall 

Monitoring 

Period Date NODI Code a 

Average 

Concentration 

(mg/L) 

FacilityProvided 

Concentration 

(mg/L) 

Average Flow 

(MGD) 

Mercury 

001 31-Jan-08 8 NR 0.659129 

001 29-Feb-08 0.0003 0.0003 0.668433 

001 31-Mar-08 8 NR 0.6071 

001 30-Apr-08 8 NR 0.614742 

001 31-May-08 0.2 0.0002 0.707 

001 30-Jun-08 8 NR 0.589548 

001 31-Jul-08 8 NR 0.582452 

001 31-Aug-08 0 <0.0002 0.58029 

001 30-Sept-08 8 NR 0.595933 

001 31-Oct-08 8 NR 0.557667 

001 30-Nov-08 0 <0.0002 0.606935 

001 31-Dec-08 8 NR 0.691677 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-13

Table 7-14. Elementis Chromium LP Outfall 001 2008 Monthly Mercury and Silver 

Discharge Data 

Outfall 

Monitoring 

Period Date NODI Code a 

Average 

Concentration 

(mg/L) 

FacilityProvided 

Concentration 

(mg/L) 

Average Flow 

(MGD) 

Silver 

001 31-Jan-08 8 NR 0.659129 

001 29-Feb-08 0 <0.001 0.668433 

001 31-Mar-08 8 NR 0.6071 

001 30-Apr-08 8 NR 0.614742 

001 31-May-08 1 <0.001 0.707 

001 30-Jun-08 8 NR 0.589548 

001 31-Jul-08 8 NR 0.582452 

001 31-Aug-08 0 <0.001 0.58029 

001 30-Sept-08 8 NR 0.595933 

001 31-Oct-08 8 NR 0.557667 

001 30-Nov-08 0 <0.005 0.606935 

001 31-Dec-08 8 NR 0.691677 

Source: DMR Loadings Tool and Facility Contact (Coury, 2010). 

a – NODI Code 8 is a reporting code for “Other.” 

NR – Not reported. The facility contact indicated that mercury and silver were reported quarterly rather than 

monthly. 

7.4.4 Dow Chemical Pittsburg Plant in Pittsburg, OH 

Table 7-15 presents the discharges in the 2008 DMR database for Dow Chemical 

Pittsburg Plant. The majority of the facility TWPE (approximately 89 percent) is from copper. 

Copper discharges from Dow Chemical Pittsburg Plant account for 13 percent of the DMR 

TWPE for the Inorganic Chemicals Category. 

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

Pollutant Total Pounds Total TWPE 

Percentage of Facility 

Total TWPE 

Copper 48,100 30,300 89.3% 

Nickel 28,100 2,810 8.3% 

Mercury 7.11 833 2.4% 

Total 2,060,000 33,900 100% 

Source: DMRLoads2008_v2. 

The majority of the copper discharges for Dow Chemical Pittsburg Plant are from outfalls 

001, 004, 005, and 006. Table 7-16 presents the copper discharge data for outfalls 001, 004, 005, 

and 006 in the DMR Loadings Tool for 2008. The facility’s copper discharges are in the DMR 

Loadings Tool as a quantity (i.e., as kilogram per day (kg/day)). EPA also calculated the monthly 

average quantity discharge using the average concentration and flow data in the 2008 DMR 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-14

Loadings Tool. EPA determined that the reported quantities in the DMR Loadings Tool were 

incorrect. The discharge quantities calculated using the flow and concentrations are at least 3 

orders of magnitude less. Table 7-16 also presents the calculated monitoring period quantities. 

Table 7-17 presents the revised estimated pounds and TWPE for copper from the Dow Chemical 

Pittsburg Plant. Using the calculated quantities, Dow Chemical Pittsburg Plant’s copper 

discharges decrease by 23,600 TWPE, while the facility’s TWPE decreases from 33,900 TWPE 

to 10,300 TWPE. 

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

Outfall 

Monitoring 

Period Date 

NODI 

Code a

Average 

Quantity 

(kg/day) 

Average 

Concentration 

(mg/L) 

Average Flow 

(MGD) 

Calculated 

Quantity 

(kg/day) 

001 31-Jan-08 6.4 0.0064 0.09 0.0021 

001 29-Feb-08 2.9 0.0029 0.14 0.0015 

001 31-Mar-08 6.1 0.0061 0.2 0.0046 

001 30-Apr-08 2.4 0.0024 1.51 0.0137 

001 31-May-08 8.7 0.0087 0.18 0.0059 

001 30-Jun-08 5.4 0.0054 0.18 0.0036 

004 31-Jan-08 15 0.015 2.92 0.1655 

004 29-Feb-08 11 0.011 0.36 0.0151 

004 31-Mar-08 C 

004 30-Apr-08 C 

004 31-May-08 C 

004 30-Jun-08 C 

005 30-Jun-08 7.6 0.0076 97.2 2.79 

006 30-Jun-08 43 0.043 64.3 10.46 

Source: DMR Loadings Tool. 

a – NODI Code C means no discharge occurred for that monitoring period. 

Table 7-17. Dow Chemical Pittsburg Plant’s 2008 Copper Discharges 

Outfall 

Old Copper 

Total Pounds 

Old Copper 

TWPE 

Revised Copper 

Total Pounds 

Revised Copper 

TWPE 

Reduction in 

TWPE 

001 4,290 2,700 4.21 2.7 2,700 

004 3,400 2,150 24.5 15.4 2,130 

005 6,070 3,820 2,230 1,410 2,420 

006 34,300 21,600 8,350 5,260 16,400 

Total 48,000 30,300 10,600 6,690 23,600 

Source: DMRLoads2008_v2 and Inorganic Chemicals Category (40 CFR Part 415) Facility Review Calculations 

(ERG, 2010). 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-15

7.5 Inorganic Chemicals Category Conclusions

The estimated toxicity of the Inorganic Chemicals Category discharges resulted from 

discharges of metals. Data collected for the 2010 annual review demonstrated that wastewater 

discharge characteristics for this category are consistent with discharges from prior years. As in 

prior years, EPA makes the following conclusions: 

• There were flow units errors for discharges from the UOP LLC facility in 

Chickasaw, AL. These discharges accounted for the majority of the Inorganic 

Chemicals Category aluminum TWPE in the 2008 DMR database. Correcting the 

flow units decreases the 2008 facility TWPE by 51,100 TWPE. 

• AL State Docks Mud Lakes facility in Mobile, AL was incorrectly classified in 

the Inorganic Chemicals Category. This facility should be classified in the 

Nonferrous Metals Manufacturing Category (40 CFR Part 421). Excluding this 

facility from the Inorganic Chemicals Category decreases the category’s 2008 

TWPE by 28,400 TWPE. EPA also determined that best professional judgment 

(BPJ) permitting was most appropriate for this facility’s discharges. 

• The mercury and silver concentrations for Elementis Chromium LP’s facility in 

Castle Hayne, NC had unit errors and were missing below detection limit 

indicators. Correcting the concentrations decreases the 2008 facility TWPE by 

18,800 TWPE. 

• The reported copper quantities for Dow Chemical Pittsburg Plant’s facility in 

Pittsburg, CA were significantly higher than the quantities calculated using the 

reported concentrations and flows in 2008 DMR Loadings Tool. Using the 

calculated quantities decreases the 2008 facility TWPE by 23,600 TWPE. 

• Correcting the database errors identified during the 2010 annual review decreases 

the 2008 Inorganic Chemicals Category TWPE from 299,000 TWPE to 177,000 

TWPE. The Inorganic Chemicals Category continues to rank high because a high 

number of facilities (approximately 450) in the industry have data in the 

screening-level databases.13 EPA will continue to monitor the Inorganic 

Chemicals Category discharges to determine if they are properly controlled. 

EPA prioritizes point source categories with existing regulations for potential revision 

based on the greatest estimated toxicity to human health and the environment, measured as 

TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for 

revision (i.e., this category is marked with “(3)” in the “Findings” column in Table V-1 in the 

Federal Register notice that presents the 2010 annual review of existing ELGs). 

 

13 For the Inorganic Chemicals Manufacturing Point Source Category, TRIReleases2008 contains data from 413 

facilities, and DMRLoads2008 contains data from 452 facilities. 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-16

7.6 Inorganic Chemicals Category References

1. ADEM. 2002. Alabama Department of Environmental Management. National Pollutant 

Discharge Elimination System Permit NPDES – AL0002666 – for UOP LLC Mobile 

Plant. Montgomery, AL. (December 23). EPA-HQ-OW-2008-0517 DCN 07271. 

2. ADEM. 2006. Alabama Department of Environmental Management. National Pollutant 

Discharge Elimination System Permit NPDES – AL0002976 – for Alabama State Port 

Authority Mud Lakes. Mobile, AL. (October 24). EPA-HQ-OW-2008-0517 DCN 07272. 

3. Brown, Donald. 2010. Telephone and E-mail communication with Donald Brown, 

Alabama Department of Environmental Management, and Elizabeth Sabol, Eastern 

Research Group, Inc. “Re: Mercury Discharges Reported to DMR in 2008 for AL State 

Docks – Mud Lakes.” (August 31). EPA-HQ-OW-2008-0517 DCN 07306. 

4. Coury, Sean. 2010. Telephone conversation with Sean Coury, Elementis Chromium, and 

Elizabeth Sabol, Eastern Research Group, Inc. “Re: Mercury and Silver Discharges 

Reported to DMR in 2008.” (June 29). EPA-HQ-OW-2008-0517 DCN 07273. 

5. ERG. 2010. Eastern Research Group, Inc. Inorganic Chemicals Category (40 CFR Part 

415) Facility Review Calculations. (July 2). EPA-HQ-OW-2008-0517 DCN 07274. 

6. Frain, Rick. 2010. Telephone conversation with Rick Frain, UOP LLC and Elizabeth 

Sabol, Eastern Research Group, Inc. “Re: Aluminum Discharges Reported to DMR in 

2008.” (June 29). EPA-HQ-OW-2008-0517 DCN 07275. 

7. U.S. Census. 2002. U.S. Economic Census. Available online at: 

http://www.census.gov/econ/census02. 

8. U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program 

Plan. EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346 

through 1352. 

9. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial 

Dischargers. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-

0016. 

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

Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782. 

11. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent 

Guidelines Program Plan. EPA-821-R-07-007. Washington, DC. (October). EPA-HQOW-2006-0771-0819. 

12. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent 

Guidelines Program Plan. EPA-821-R-09-006. Washington, DC. (October). EPA-HQOW-2008-0517-0515. 
Section 7 – Inorganic Chemicals Manufacturing (40 CFR Part 415) 

7-17

13. Wright, Cliff. 2010. Telephone and E-mail communication with Cliff Wright, AL State 

Docks – Mud Lakes and Elizabeth Sabol, Eastern Research Group, Inc. “Re: Mercury 

Discharges Reported to DMR in 2008.” (June 29). EPA-HQ-OW-2008-0517 DCN 

07276.
Section 8 – Landfills (40 CFR Part 445) 

8-1

8. LANDFILLS (40 CFR PART 445) 

EPA selected the Landfills Category (40 CFR Part 445) for preliminary review because it 

ranks high, in terms of toxic-weighted pound equivalent (TWPE), in point source category 

rankings (see Table 5-3 for the point source category rankings). EPA has not previously 

reviewed the Landfills Category. This section summarizes the results of the 2010 annual review 

associated with the Landfills Category. EPA focused on metal discharges, because of their high 

TWPE compared to other pollutants in the category. 

8.1 Landfills Category Background

This subsection provides background on the Landfills Category including a brief profile 

of the landfills industry and background on 40 CFR Part 445. 

8.1.1 Landfills Industry Profile 

The landfills industry includes facilities that are operate waste (hazardous and nonhazardous) treatment or disposal facilities or perform the collecting and/or hauling of waste 

materials within a local area, combined with the operation of waste treatment or disposal 

facilities. The landfills can either be commercial or municipal. EPA considered the following 

four North American Industry Classification System (NAICS) codes as part of the Landfills 

Category: 

• 562211: Hazardous Waste Treatment and Disposal; 

• 562212: Solid Waste Landfill; 

• 562219: Other Nonhazardous Waste Treatment and Disposal; and 

• LNDFLL: Landfills. 

Wastewater generated by facilities in the NAICS codes 562211, 562212, and 562219 may 

be regulated under the Landfills Category, Centralized Waste Treatment (CWT) Category (40 

CFR Part 437), and the Waste Combustor Category (40 CFR Part 444). EPA reviewed available 

information about pollutant loads and operations for facilities reporting these NAICS codes. EPA 

was able to assign the “LNDFLL” NAICS code for facilities that most likely fall under the 

applicability of Part 445, Landfills Effluent Limitation Guidelines and Standards (ELGs). EPA 

was not able to determine which point source category applied to the other facilities in NAICS 

codes 562211, 562212, and 562219. The discharges from these facilities that were not assigned 

the “LNDFLL” NAICS code are counted in all three point source categories in the 2008 

discharge monitoring report (DMR) and Toxics Release Inventory (TRI) databases. 

Because Permit Compliance System (PCS) and Integrated Compliance Information 

System – National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the 

sources of the DMR data used to develop DMRLoads2008, report facilities by Standard 

Industrial Classification (SIC) codes, and the U.S. Economic Census and TRI report data by 

NAICS code, EPA reclassified the 2008 DMR data by the equivalent NAICS code. Table 8-1

lists the number of facilities from the U.S. Economic Census and the screening-level databases 

for the seven NAICS codes with operations in the Inorganic Chemicals Category the 

corresponding SIC codes are included for reference. The U.S. Economic Census includes more 

facilities than the screening-level databases because of many possible factors including not 

meeting TRI-reporting thresholds, discharging to a publicly owned treatment works (POTW), 
Section 8 – Landfills (40 CFR Part 445) 

8-2

and because some of those in the U.S. Economic Census are distributors or sales facilities, not 

manufacturers. 

Table 8-1. Number of Landfills 

NAICS Code 

Corresponding 

SIC Code 

Number of Facilities

2002 U.S. 

Economic Census

2008 DMR 

Database a

2008 TRI 

Database b

562211: Hazardous Waste 

Treatment and Disposal 

4953: Refuse 

Systems; 

4953L: Refuse 

Systems 

(Landfills) 

701 1,295 53 

562212: Solid Waste Landfill 1,507 1 

562219: Other Nonhazardous 

Waste Treatment and Disposal 

199 5 

LNDFLL: Landfills NA 8 

Total >2,407 1,295 67 

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2; and TRIReleases2008_v3. 

a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore EPA used an NAICS-to-SICcode crosswalk for comparison purposes. 

b – Releases to any media. 

NA – Not applicable. 

Table 8-2 shows whether permitting authorities designated direct discharges as minor or 

major (see Section 4.1.5) for facilities in the Landfills Category. EPA included data for minor 

discharges for the first time in the 2010 annual review, as part of DMRLoads2008_v2 database. 

EPA does not require permitting authorities to submit DMR data for minor dischargers; however, 

many states do provide complete DMR data for them. From this year’s review, EPA observed 

many data entry or other errors for minor dischargers in addition to those previously identified 

for major dischargers, as discussed in Section 4.3. Table 6-2 shows that approximately 99 

percent of the Landfills Category dischargers in the 2008 DMR database are minor dischargers. 

Table 8-2. Number of Landfills by Discharge Classification in 2008 DMR Database 

NAICS Code a 

Number of Facilities in 2008 DMR Database 

Major Dischargers Minor Dischargers All Dischargers 

562211: Hazardous Waste Treatment and 

Disposal 

11 1,284 1,295 

562212: Solid Waste Landfill 

562219: Other Nonhazardous Waste Treatment 

and Disposal 

LNDFLL: Landfills 

Total 11 1,284 1,295 

Source: DMRLoads2008_v2. 

a – DMR data is reported by SIC code; therefore EPA used an NAICS to SIC crosswalk for comparison purposes. 

Table 8-3 presents the number of landfills included in the DMR databases and whether 

discharge data (e.g., pollutant concentrations, flow rates, etc.) were included for reporting years 

2004, 2007, and 2008. The table shows a large increase in the number of landfills with discharge 
Section 8 – Landfills (40 CFR Part 445) 

8-3

data from 2004 and 2007 to 2008 in the DMR database, due to the addition of minors. However, 

there are still almost 70 percent of landfills without discharge data in the 2008 DMR database. 

Table 8-3. Number of Landfills in the DMR Database for Reporting Years 2004, 2007, 

and 2008 

Discharge Status 2004 a 2007 a 2008 a

With Water Discharge Data b 18 8 383 

Without Water Discharge 

Data c 287 1,070 912 

Total 305 1,078 1,295 

Source: PCSLoads2004_v3; DMRLoads2007_v4; and DMRLoads2008_v2. 

a – Major and minor dischargers. 

b – Includes facilities with DMR data in the DMR databases. 

c – Includes facilities with NPDES permits without DMR data in the DMR databases. 

Table 8-4 presents the type of discharges reported by facilities in the 2008 TRI database. 

The majority of landfills reporting to TRI do not report water discharges. However, there is an 

even distribution of direct and indirect dischargers for those that do report water discharges. 

Table 8-4. Number of Landfills by Discharge Type in 2008 TRI Database 

NAICS Code 

Number of Facilities in 2008 TRI Database 

Direct 

Dischargers 

Only 

Indirect 

Dischargers 

Only 

Both Indirect 

and Direct 

Dischargers 

No Water 

Discharges 

562211: Hazardous Waste Treatment and 

Disposal 

4 4 1 44 

562212: Solid Waste Landfill 0 0 1 0 

562219: Other Nonhazardous Waste Treatment 

and Disposal 

2 0 0 3 

LNDFLL: Landfills 1 3 2 2 

Total 7 7 4 49 

Source: TRIReleases2008_v3.

8.1.2 40 CFR Part 445 

EPA promulgated ELGs for the Landfills Category (40 CFR Part 445) on January 19, 

2000 (65 FRN 3007). The Landfills ELGs are applicable to wastewater discharges to surface 

water14 from landfill units, excluding wastewater discharges from the following units: 

• Land application or land treatment units; 

• Surface impoundments; 

• Underground injection wells; 

• Waste piles; 

• Salt dome formations; 

 

14 40 CFR Part 445 does not set limits for discharges to POTWs (i.e., indirect dischargers). 
Section 8 – Landfills (40 CFR Part 445) 

8-4

• Salt bed formations; 

• Underground mines/caves; 

• Wastewater generated offsite; 

• Discharges of contaminated ground water or wastewater from recovery pumping 

wells; 

• Landfills operated in conjunction with other industrial or commercial operations 

when the landfill receives facility generated wastes; and 

• Landfills in conjunction CWTs. 

There are two subcategories in the Landfills Category: Resource Conservation and 

Recovery Act (RCRA) Subtitle C Hazardous Waste (Subpart A) and RCRA Subtitle D 

Nonhazardous Waste (Subpart B). RCRA Subtitle C Hazardous Waste landfills are authorized by 

RCRA to accept hazardous waste (see 40 CFR Part 421). These landfills are required to maintain 

a leachate collection and removal system during the active and postclosure period of the landfill 

(U.S. EPA, 2000). RCRA Subtitle D NonHazardous Waste landfills can receive municipal 

refuse, ash, sludge, construction and demolition debris, and nonhazardous industrial waste. Prior 

to 1980 when RCRA was enacted, the older Subtitle D landfills may have received waste that 

was later classified as hazardous (U.S. EPA, 2000). Table 8-5 presents the regulated pollutants 

and limits for direct dischargers in the two subparts. For RCRA Subtitle C hazardous waste 

landfills, EPA developed the limits based on a treatment system consisting of equalization, 

chemical precipitation, biological treatment, and multimedia filtration. For RCRA Subtitle D 

nonhazardous waste landfills, EPA developed the limits based on a treatment system consisting 

of equalization, biological treatment, and multimedia filtration (U.S. EPA, 2000). 

Table 8-5. Regulated Pollutants and Limits for the Landfills Category (40 CFR Part 445) 

Regulated 

Pollutant 

RCRA Subtitle C Hazardous Waste 

Landfill BAT (Subpart A) 

RCRA Subtitle D Nonhazardous Waste 

Landfill BAT (Subpart B) 

Daily Maximum 

(mg/L) 

Monthly Average

(mg/L) 

Daily Maximum 

(mg/L) 

Monthly Average

(mg/L) 

BOD5 220 56 140 37 

TSS 88 27 88 27 

Ammonia (as N) 10 4.9 10 4.9 

α-Terpineol 0.042 0.019 0.033 0.016 

Aniline 0.024 0.015 NA NA 

Benzoic acid 0.119 0.073 0.12 0.071 

Naphthalene 0.059 0.022 NA NA 

p -Cresol 0.024 0.015 0.025 0.014 

Phenol 0.048 0.029 0.026 0.015 

Pyridine 0.072 0.025 NA NA 

Arsenic 1.1 0.54 NA NA 

Chromium 1.1 0.46 NA NA 

Zinc 0.535 0.296 0.2 0.11 

pH Within the range 6 to 9 Within the range 6 to 9 

Source: 40 CFR Part 445. 

NA – Not applicable. Subpart B – RCRA Subtitle D Nonhazardous Waste Landfill does not regulate these 

pollutants. 
Section 8 – Landfills (40 CFR Part 445) 

8-5

8.2 Landfills Category 2010 Screening-Level Review

Table 8-6 compares the screening-level results for the Landfills Category from the 2009 

and 2010 annual reviews that represented the 2007 and 2008 DMR and TRI databases, 

respectively. The combined DMR and TRI TWPE increased from discharge years 2007 to 2008. 

The 2008 DMR TWPE accounts for approximately 99 percent of the total 2008 category TWPE, 

similar to the previous year. 

Table 8-6. Landfills Category TRI and DMR Discharges for the 2009 and 2010 ScreeningLevel Reviews 

Year of Discharge Year of Review 

Landfills Category 

TRI TWPE b DMR TWPE a Total TWPE 

2007 2009 83 15,300 15,400 

2008 2010 781 191,000 192,000 

Source: TRIReleases2008_v3 and DMRLoads2008_v2. 

Note: EPA did not previously review the Landfills Category; therefore, the 2007 discharge data is only shown for 

comparison to 2008. 

a – DMR data from 2007 include only major dischargers. DMR 2008 data include both minor and major 

dischargers. 

b – Discharges include transfers to POTWs and account for POTW removals. 

Table 8-7 presents the 2008 DMR TWPE by facility discharge classification. EPA 

excluded minor dischargers from previous annual reviews, but included them in the 2010 annual 

review. The majority (99 percent) of the TWPE in the 2008 DMR database results from minor 

dischargers. 

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

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers 

2008 190,000 1,260 

Source: DMRLoads2008_v2. 

a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous 

annual reviews. 

8.3 Landfills Pollutants of Concern

Table 8-8 lists the five pollutants with the highest TWPE in TRIReleases2008_v3, while 

Table 8-9 lists the five pollutants with the highest TWPE in DMRLoads2008_v2. 
Section 8 – Landfills (40 CFR Part 445) 

8-6

Table 8-8. Landfills Category Top TRI Pollutants in 2008 a 

Pollutant Rank 

Number of Facilities 

Reporting Pollutant TWPE 

Copper and Copper Compounds 1 5 127 

Tetrachloroethylene 2 3 55 

Arsenic and Arsenic Compounds 3 1 37 

Lead and Lead Compounds 4 4 36 

Cadmium and Cadmium Compounds 5 2 14 

Landfills Category Total NA 18 b 781

Source: TRIReleases2008_v3. 

a – Discharges include transfers to POTWs and account for POTW removals. 

b – Number of facilities reporting TWPE greater than zero. 

Table 8-9. Landfills Category Top DMR Pollutants in 2008 a 

Pollutant Rank 

Number of Facilities 

Reporting Pollutant TWPE 

Vanadium 1 11 45,400 

Iron 2 146 31,300 

Manganese 3 55 15,700 

Arsenic 4 47 15,100 

Calcium 5 18 10,900 

Landfills Category Total NA 232 b 191,000 

Source: DMRLoads2008_v2. 

a – 2008 DMR data includes major and minor dischargers. 

b – Number of facilities reporting TWPE greater than zero. 

The Landfills Category TWPE in the 2008 TRI database is significantly lower than the 

2008 DMR TWPE. Therefore, EPA focused the additional review of the Landfills Category on 

the DMR-reported pollutants that account for the majority of the category TWPE. 

The top four DMR-reported pollutants in 2008 are metals. Of the top four metals, the 

Landfill ELG regulates only arsenic from hazardous waste landfills (Subpart A). The remaining 

top metals are not regulated by the Landfill ELG. EPA’s additional review of the top metals is 

presented in the following section. 

8.4 Landfills Category Facility-Specific DMR Review

During the 2010 annual review of the Landfills Category, EPA identified several data 

entry or conversion errors in the underlying DMR data used to develop the 2008 DMR database. 

These errors inaccurately increased the top pollutants TWPE. All of the errors identified during 

the facility review were for minor dischargers, which compose the majority of facilities reporting 

discharges in the Landfills Category. Table 8-10 presents the data entry errors identified by EPA 

along with the corrected facility TWPE. EPA also identified one facility, American Electric 

Power in Ohio, that was incorrectly categorized in the Landfills Category. EPA determined that 

this facility only receives waste from American Electric Power’s flue gas desulfurization, 

gypsum, fly and bottom ash, and purge stream solids (Ohio EPA, 2009). Therefore, this facility 
Section 8 – Landfills (40 CFR Part 445) 

8-7

should be included in Steam Electric Power Generating Category (40 CFR Part 423) rather than 

Part 445 because Part 445 excludes “landfills operated in conjunction with other industrial or 

commercial operations when the landfill only receives waste generated by the industrial or 

commercial operation directly associated with the landfill” (see 40 CFR Part 445.1(e)). 

Table 8-11 presents the revised top pollutant TWPE using the corrected data. Note: these 

corrections are not included in DMRLoads2008_v2. EPA will incorporate these corrections into 

future versions of the 2008 DMR database. 
Section 8 – La

8-8

Table 8-10. Data Errors Identified in the Landfills Category in 2008 DMR Database 

Facility Name 

Facility 

Location 

Major or 

Minor 

Facility 

Pollutants with 

Identified 

Errors 

Original 

Pollutant 

TWPE 

Original Facility 

Total TWPE Error(s) Identified 

Springfield Sanitary Landfill 

Willard, 

MO 

Minor Vanadium 45,100 46,600 Facility contact confirmed vanadium 

concentrations were all reported in μg/l, not mg/L. Facility contact also confirmed six discharges that were missing the nondetect indicator (i.e. “<”). (Gatlin, 2010) 

Advantage Metals Recycling 

Kansas 

City, MO 

Minor All a 20,300 20,300 Facility contact confirmed a data entry 

error (i.e., incorrect value and decimal location) for the cadmium concentration for September 2008. Facility contact also identified data entry errors (i.e., incorrect decimal location) for all the flows for outfalls 001and 003. (Palmer, 2010) 

Onyx Maple Hill Landfill 

Macon, MO Minor Magnesium, 

Manganese, 

Fluoride 

20,100 b 20,300 Facility contact confirmed magnesium, 

manganese, and fluoride concentrations were all reported in μg/L, not mg/L, for outfalls 001 and 004. (Tipton, 2010) 

Ashtabula River 

OH Minor Arsenic 13,100 16,700 Review of on-line Envirofacts15

confirmed incorrect values for arsenic quantities. 

Sources: Facility contacts (Gatlin, 2010; Palmer, 2010; and Tipton, 2010). a – EPA identified a flow-unit error that affected all pollutants for outfalls 001, 002, and 003. b – Pollutant TWPE is the sum of magnesium, manganese, and fluoride TWPE for outfalls 001 and 004. 15 EPA uses the data in Envirofacts as a source while reviewing the DMR Loadings Tool data because Envirofacts continually accepts a

submitted by facilities and states. The DMR Loadings Tool is not continuously updated; therefore, loads may be estimated with erroneo
Section 8 – Landfills (40 CFR Part 445) 

8-9

Table 8-11. Corrected TWPE for Top Pollutants in the Landfills Category in 2008 DMR 

Database 

Pollutant 2008 DMR TWPE Corrected 2008 DMR TWPE 

Vanadium 45,400 300 

Iron 31,300 29,900 

Manganese 15,700 4,240 

Arsenic 15,100 2,060 

Calcium 10,900 100 a 

Landfills Category Total 191,000 97,000 

a – The majority, approximately 99 percent, of the calcium discharges in the Landfills Category was from American 

Electric Power Landfills, which EPA determined was incorrectly classified as the Landfills Category (Ohio EPA, 

2010). 

After the errors identified in Table 8-10 were corrected, EPA determined that vanadium, 

manganese, arsenic, and calcium were no longer pollutants of concern. Therefore, EPA did not 

include these pollutants in any further review of the Landfills Category. EPA identified that iron 

is consistently reported as discharged and is a top pollutant that is not regulated by the Landfill 

ELGs. EPA’s review of iron is presented in the following subsection. 

8.5 Landfills Category Iron Discharges in DMR

As part of the 2010 annual review of the Landfills Category, EPA reviewed iron 

discharges in the 2008 DMR database. Iron is not regulated by the Landfill ELGs. The 

Development Document for Final Effluent Limitations Guidelines and Standards for the 

Landfills Point Source Category (January 2000) indicates that “EPA excluded pollutants that are 

naturally occurring compounds in soil or ground water at landfill facilities or pollutants that are 

used as treatment chemicals in this industry...” This included iron, along with other pollutants 

(U.S. EPA, 2000). 

EPA compared the iron concentrations from landfill discharges to treatable levels typical 

of chemical precipitation and biological treatment. In order to compare the iron concentrations to 

treatment level, EPA determined that there were 3,404 iron concentrations in 2008 DMR 

Loadings Tool for facilities in the Landfills Category. EPA removed 0 mg/L concentrations and 

concentrations reported below the detection limit (BDL) for all reporting periods, resulting in 

1,286 iron concentrations for the analysis. Because facilities report multiple concentrations for 

each monitoring period, EPA prioritized the selection of the average concentration and then the 

maximum (ERG, 2010). 

Then, EPA compared the iron concentrations to the EPA Method 200.7 method detection 

limit (MDL) for iron to determine if the concentrations were at detectable levels. EPA excluded 

the 58 iron concentrations (approximately 2 percent) that were below MDL. EPA calculated the 

resulting median, average, and maximum of the remaining iron concentrations. EPA analyzed 

the median concentration rather than the average or maximum because of suspected data entry 

errors that would skew the average and maximum iron concentrations (ERG, 2010). 

EPA then compared the median iron concentration to available chemical precipitation 

and biological treatability data. EPA chose these specific wastewater treatment technologies 
Section 8 – Landfills (40 CFR Part 445) 

8-10

because they were the technologies used to determine the best available technology (BAT) basis 

used to develop limits for the RCRA Subtitle C Hazardous Waste Landfills. EPA used 

treatability data for chemical precipitation and biological treatment already established during 

previous annual reviews16 (U.S. EPA, 2009). 

 

Table 8-12 presents the median iron concentration compared to the EPA Method 200.7 

MDL and compared to treatability concentrations for chemical precipitation and biological 

treatment. Table 8-12 shows that the median iron concentration in landfill discharges is below 

the maximum concentrations achievable by chemical precipitation and biological treatment.

16 As part of the Steam Electric Power Generating Point Source Category Detailed Study, EPA collected treatability 

data for chemical precipitation and biological treatment systems. Iron was included in the treatability data (U.S. 

EPA, 2009). 
Section 8 – La

8-11

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

Pollutant 

Number of 

Facilities 

Reporting 

Pollutant a 

EPA 200.7 MDL 

(mg/L) 

Chemical 

Precipitation 

Treatment 

Concentration 

Range (mg/L) 

Biological 

Treatment 

Concentration 

Range (mg/L) 

Median 

Concentration 

(mg/L) 

Percent 

Concentra

above Che

Precipita

Range 

Iron 146 0.03 0.019 – 6 ND (0.0022) – 23 1.21 11% 

Source: DMR Loadings Tool; Method 200.7 Determination of Metals and Trace Elements in Water and Wastes by Inductively Couple P

Spectrometry (U.S. EPA, 1994); and 2009 Steam Electric Power Generating Point Source Category: Final Detailed Study Report (U.S

a – Number of facilities reporting iron concentrations after EPA excluded outfalls with all nondetect concentrations and concentrations MDL – Method detection limit. ND –Nondetect. Detection limit indicated in ( ). 
Section 8 – Landfills (40 CFR Part 445) 

8-12

The median iron concentration for all outfalls is less than the biological treatment or 

chemical precipitation treatability concentrations. Approximately 89 percent of the iron 

concentrations are below the chemical precipitation treatability (below 6 mg/L) and 98 percent 

are below the biological treatment treatability (below 23 mg/L). The remaining iron 

concentrations above the chemical precipitation treatment range are reported by a total of 24 

facilities, seven of which are also above the biological treatment range. 

EPA determined that approximately 80 percent of the facilities reporting iron 

concentrations above treatable levels are located in Missouri and Kentucky. Because the majority 

of the landfills are minor discharges and EPA has not previously reviewed their data, EPA 

believes that there may be data quality issues (e.g., incorrect units) with the high iron 

concentrations. Additionally, the majority of the facilities have iron concentrations below 

treatable levels. Therefore, EPA does not believe that revising the Landfill ELGs to include iron 

limits is appropriate. 

8.6 Landfills Category Conclusions

The estimated toxicity of the Landfills Category discharges results mainly from the 

discharges of metals. During the 2010 annual review, EPA identified many data entry errors in 

the Landfill Category DMR data, because they are predominately minor discharges. Based on 

corrected discharge data, further review at this time is unnecessary. Therefore, EPA concludes 

the following: 

• Database errors were identified for vanadium, manganese, arsenic, and iron. 

Additionally, one facility, American Electric Power, was incorrectly categorized 

in the Landfills Category when it should be included in the Steam Electric Power 

Generating Category (40 CFR Part 423). Making these corrections decreases the 

Landfills Category TWPE by over 49 percent, from 191,000 TWPE to 97,000 

TWPE. 

• Eighty-nine percent of iron concentrations in the 2008 DMR database are within 

treatability concentration ranges. Twenty-one of the 24 facilities with iron 

concentrations in the 2008 DMR database that exceed treatability concentrations 

are located in Missouri and Kentucky. Iron is not regulated by the Landfill ELGs. 

There are possible quality issues with the iron concentration data in the Landfills 

Category. EPA will continue monitoring iron concentrations from landfills as part 

of future annual reviews. Based on these data, EPA cannot conclude that an 

effluent guideline revision is necessary at this time; however, EPA will collect 

additional data for consideration during the 2011 annual review. 

EPA prioritizes point source categories with existing regulations for potential revision 

based on the greatest estimated toxicity to human health and the environment, measured as 

TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for 

revision (i.e., this category is marked with “(5)” in the “Findings” column in Table V-1 in the 

Federal Register notice that presents the 2010 annual review of existing effluent guidelines and 

pretreatment standards). 
Section 8 – Landfills (40 CFR Part 445) 

8-13

8.7 Landfills Category References

1. ERG. 2010 Eastern Research Group, Inc. Memorandum to William Swietlik, U.S. EPA 

EPA, from Jessica Wolford and Elizabeth Sabol, Eastern Research Group, Inc. RE: 

Methodology for Analyzing Landfill Iron Concentrations in the 2008 DMR Loadings 

Tool. (October). EPA-HQ-OW-2008-0517 DCN 07277. 

2. Gatlin, Jacquelin. 2010. E-mail communication between Jacquelin Gatlin, Missouri 

Department of Natural Resources, and Eleanor Codding, Eastern Research Group, Inc. 

“RE: OR 15133 DMRs for Springfield Sanitary Landfill.” (June 24). EPA-HQ-OW2008-0517 DCN 07278. 

3. Ohio EPA. 2009. Ohio Environmental Protection Agency. Authorization to Discharge 

under National Pollutant Discharge Elimination System Permit OH0076627 – Columbus 

Southern Power Company, Conesville, OH. Ohio EPA Location. (December). EPA-HQOW-2008-0517 DCN 07279. 

4. Palmer, Adria. 2010. E-mail communication between Adria Palmer, Missouri 

Department of Natural Resources, and Eleanor Codding, Eastern Research Group, Inc. 

“Confirming DMR Data for Advantage Metals Recycling Facility (MO0115801).” (June 

28). EPA-HQ-OW-2008-0517 DCN 07280. 

5. Tipton, Lantz. 2010. E-mail communication between Lantz Tipton, Missouri Department 

of Natural Resources, and Elizabeth Sabol, Eastern Research Group, Inc. “DMRs 

Clarification Needed for Onyx Maple Hill Landfill.” (June 30). EPA-HQ-OW-2008-0517 

DCN 07281. 

6. U.S. EPA. 1994. Method 200.7 Determination of Metals and Trace Elements in Water 

and Wastes by Inductively Couple Plasma-Atomic Emission Spectrometry Revision 4.4. 

Washington, DC. (Unknown). Available online at: 

http://www.epa.gov/waterscience/methods/method/files/200_7.pdf. 

7. U.S. EPA. 2000. Development Document for Final Effluent Limitations Guidelines and 

Standards for the Landfills Point Source Category. EPA-821-R-99-019. Washington, 

DC. (January). Available online at: 

http://www.epa.gov/waterscience/guide/landfills/final/index.html. 

8. U.S. EPA. 2009. Steam Electric Power Generating Point Source Category: Final 

Detailed Study Report. EPA-821-R-008. Washington, DC. (October). EPA-HQ-OW2008-0517-0413. 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-1

9. MINERAL MINING AND PROCESSING (40 CFR PART 436) 

EPA selected the Mineral Mining and Processing (Mineral Mining) Category for 

preliminary review because it continues to rank high, in terms of toxic-weighted pound 

equivalent (TWPE), in point source category rankings (see Table 5-3 for the point source 

category rankings). This industry was reviewed previously in EPA’s Final 2004 Effluent 

Guidelines Program Plans (U.S. EPA, 2004). This section summarizes the 2010 annual review 

associated with the Mineral Mining Category. EPA focused on discharges of sulfide, fluoride, 

and ammonia as nitrogen, because of their high TWPE relative to other pollutants in the Mineral 

Mining Category. 

9.1 Mineral Mining Category Background

This subsection provides the background on the Mineral Mining Category including a 

brief industry profile of the mineral mining and processing industry and background on 40 CFR 

Part 436. 

9.1.1 Mineral Mining Industry Profile 

The Mineral Mining Category includes facilities that mine and process non-metallic 

minerals and discharge wastewater. EPA considered the following 28 North American Industry 

Classification System (NAICS) codes as part of the Mineral Mining Category: 

• 212311: Dimension Stone Mining and Quarrying; 

• 212312: Crushed and Broken Limestone Mining and Quarrying; 

• 212313: Crushed and Broken Granite Mining and Quarrying; 

• 212319: Other Crushed and Broken Stone Mining and Quarrying; 

• 212321: Construction Sand and Gravel Mining; 

• 212322: Industrial Sand Mining; 

• 212324: Kaolin and Ball Clay Mining; 

• 212325: Clay and Ceramic and Refractory Minerals Mining; 

• 212391: Potash, Soda, and Borate Mineral Mining; 

• 212392: Phosphate Rock Mining; 

• 212393: Other Chemical and Fertilizer Mineral Mining; 

• 212399: All Other Nonmetallic Mineral Mining; 

• 213115: Support Activities for Nonmetallic Minerals (except Fuels); 

• 327111: Vitreous China Plumbing Fixture and China and Earthenware Bathroom 

Accessories Manufacturing; 

• 327112: Vitreous China, Fine Earthenware, and Other Pottery Product 

Manufacturing; 

• 327113: Porcelain Electrical Supply Manufacturing; 

• 327121: Brick and Structural Clay Tile Manufacturing; 

• 327122: Ceramic Wall and Floor Tile Manufacturing; 

• 327123: Other Structural Clay Product Manufacturing; 

• 327124: Clay Refractory Manufacturing; 

• 327125: Nonclay Refractory Manufacturing; 

• 327410: Lime Manufacturing; 

• 327420: Gypsum Product Manufacturing; 

• 327910: Abrasive Product Manufacturing; 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-2

• 327992: Ground or Treated Mineral and Earth Manufacturing; 

• 327999: All Other Miscellaneous Nonmetallic Mineral Product Manufacturing; 

• 339999MIN: All Other Miscellaneous Manufacturing; and 

• 423320: Brick, Stone, and Related Construction Material Merchant Wholesalers. 

Wastewater generated by facilities in NAICS codes 339999 can be regulated under 

multiple categories. EPA reviewed available information about pollutant loads and 

manufacturing operations for facilities reporting this NAICS codes. EPA assigned the extension 

“MIN” to the end of the NAICS codes of facilities that likely primarily generate wastewater 

regulated by the Mineral Mining Effluent Limitation Guidelines and Standards (ELGs). For 

example, most facilities in NAICS code 339999 are grouped under the Metal Finishing ELGs. 

Because the Permit Compliance System (PCS) and the Integrated Compliance 

Information System – National Pollutant Discharge Elimination System (ICIS-NPDES), the 

sources of the discharge monitoring report (DMR) data used to develop DMRLoads2008, report 

facilities by Standard Industrial Classification (SIC) code, and the U.S. Economic Census and 

Toxics Release Inventory (TRI) report data by NAICS code, EPA reclassified the 2008 DMR by 

the equivalent NAICS code. Table 9-1 lists the number of facilities from the U.S. Economic 

Census and the screening-level databases for the 21 NAICS codes with operations in the Mineral 

Mining Category, the corresponding SIC codes are included for reference. The U.S. Economic 

Census includes more facilities than the screening-level databases because of many possible 

factors including: facilities may not meet TRI-reporting thresholds, facilities may discharge to a 

publicly owned treatment works (POTW), and some facilities in the U.S. Economic Census are 

distributors or sales facilities, not manufacturers. 

Table 9-1. Number of Mineral Mining Facilities 

NAICS Code SIC Code 

Number of Facilities 

2002 U.S. 

Economic

Census 

2008 

DMR a

2008 

TRI b

212311: Dimension Stone Mining 

and Quarrying 

1411: Dimension Stone 179 48 

212312: Crushed and Broken 

Limestone Mining and Quarrying 

1422: Crushed and Broken Limestone 1,523 881 3 

212313: Crushed and Broken 

Granite Mining and Quarrying 

1423: Crushed and Broken Granite 322 91 4 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-3

Table 9-1. Number of Mineral Mining Facilities 

NAICS Code SIC Code 

Number of Facilities 

2002 U.S. 

Economic

Census 

2008 

DMR a

2008 

TRI b

212319: Other Crushed and Broken 

Stone Mining and Quarrying 1429: Crushed and Broken Stone, NEC, 

1455: Kaolin and Ball Clay, 

1459: Clay, Ceramic, and Refractory 

Minerals, NEC, 

1479: Chemical and Fertilizer Mineral 

Mining, NEC, 

1499: Miscellaneous Nonmetallic 

Minerals, Except Fuels (except 

bituminous limestone and bituminous 

sandstone), 

3295: Minerals and Earths, Ground or 

Otherwise Treated (grinding, washing, 

separating, etc. of kaolin and ball clay). 

1,214 

696 

4 

212324: Kaolin and Ball Clay 

Mining 35 2 

212325: Clay and Ceramic and 

Refractory Minerals Mining 123 3 

212393: Other Chemical and 

Fertilizer Mineral Mining 47 1 

212399: All Other Nonmetallic 

Mineral Mining 246 21 

327992: Ground or Treated Mineral 

and Earth Manufacturing 292 43 

212321: Construction Sand and 

Gravel Mining 

1442: Construction Sand and Gravel 2,612 1288 6 

212322: Industrial Sand Mining 1446: Industrial Sand 141 56 

212391: Potash, Soda, and Borate 

Mineral Mining 

1474: Potash, Soda, and Borate Minerals 24 1 

212392: Phosphate Rock Mining 1475: Phosphate Rock 15 38 

213115: Support Activities for 

Nonmetallic Minerals (except Fuels) 

1481: Nonmetallic Minerals Services, 

Except Fuels (except geophysical 

surveying and mapping and site 

preparation and related construction 

activities performed on a contract or fee 

basis) 

284 10 1 

327111: Vitreous China Plumbing 

Fixture and China and Earthenware 

Bathroom Accessories 

Manufacturing 

3261: Vitreous China Plumbing Fixtures 

and China and Earthenware Fittings and 

Bathroom Accessories 50 15 5 

327112: Vitreous China, Fine 

Earthenware, and Other Pottery 

Product Manufacturing 

3262:Vitreous China Table and Kitchen 

Articles, 

3263: Fine Earthenware (Whiteware) 

Table and Kitchen Articles, 

3269: Pottery Products, NEC 

760 18 8 

327113: Porcelain Electrical Supply 

Manufacturing 

3264: Porcelain Electrical Supplies 138 13 5 

327121: Brick and Structural Clay 

Tile Manufacturing 

3251: Brick and Structural Clay Tile 

(except slumped brick) 200 43 96 

327122: Ceramic Wall and Floor 

Tile Manufacturing 

3253: Ceramic Wall and Floor Tile 203 8 17 

327123: Other Structural Clay 

Product Manufacturing 

3259: Structural Clay Products, NEC 50 7 5 

327124: Clay Refractory 

Manufacturing 

3255: Clay Refractories 134 43 12 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-4

Table 9-1. Number of Mineral Mining Facilities 

NAICS Code SIC Code 

Number of Facilities 

2002 U.S. 

Economic

Census 

2008 

DMR a

2008 

TRI b

327125: Nonclay Refractory 

Manufacturing 

3297: Nonclay Refractories 106 17 19 

327410: Lime Manufacturing 3274: Lime 77 35 48 

327420: Gypsum Product 

Manufacturing 

3275: Gypsum Products, 

3291: Abrasive Products (steel wool 

with or without soap), 

3299: Nonmetallic Mineral Products, 

NEC (moldings, ornamental and 

architectural plaster work, and gypsum 

statuary) 

308 

64 

85 

327910: Abrasive Product 

Manufacturing 363 28 

327999: All Other Miscellaneous 

Nonmetallic Mineral Product 

Manufacturing 

454 45 

339999MIN: All Other 

Miscellaneous Manufacturing 5,332 1 

423320: Brick, Stone, and Related 

Construction Material Merchant 

Wholesalers 

5032: Brick, Stone, and Related 

Construction Materials (merchant 

wholesalers except construction 

materials sold via retail method) 

3,592 49 2 

Total 18,824 3,421 464 

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); TRIReleases2008_v3; and DMRLoads2008_v2. 

a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an NAICS to SIC 

crosswalk for comparison purposes. 

b – Releases to any media. 

NA – Not applicable. 

Table 9-2 shows how permitting authorities designated direct discharging facilities in the 

Mineral Mining Category as minor or major (see Section 4.1.5). EPA included data for minor 

dischargers for the first time in the 2010 annual review, as part of DMRLoads2008_v2. EPA does 

not require permitting authorities to submit DMR data for minor dischargers; however, many 

states do provide complete DMR data for them. From the 2010 annual review, EPA observed 

many data entry or other errors for minor dischargers in addition to those previously identified 

for major dischargers, as discussed in Section 4.3. Table 9-2 shows that approximately 99 

percent of the Mineral Mining Category dischargers in the 2008 DMR database are minor 

dischargers. 

Table 9-2. Number of Mineral Mining Facilities 

NAICS Code a

Number of Facilities in DMR 2008 

Majors 

Dischargers 

Minor 

Dischargers All Dischargers

212311: Dimension Stone Mining and Quarrying 0 48 48 

212312: Crushed and Broken Limestone Mining and 

Quarrying 7 874 881 

212313: Crushed and Broken Granite Mining and 

Quarrying 0 91 91 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-5

Table 9-2. Number of Mineral Mining Facilities 

NAICS Code a

Number of Facilities in DMR 2008 

Majors 

Dischargers 

Minor 

Dischargers All Dischargers

212319: Other Crushed and Broken Stone Mining and 

Quarrying 

6 690 696 

212324: Kaolin and Ball Clay Mining 

212325: Clay and Ceramic and Refractory Minerals 

Mining 

212393: Other Chemical and Fertilizer Mineral Mining 

212399: All Other Nonmetallic Mineral Mining 

327992: Ground or Treated Mineral and Earth 

Manufacturing 

212321: Construction Sand and Gravel Mining 3 1,285 1,288 

212322: Industrial Sand Mining 0 56 56 

212391: Potash, Soda, and Borate Mineral Mining 0 1 1 

212392: Phosphate Rock Mining 15 23 38 

213115: Support Activities for Nonmetallic Minerals 

(except Fuels) 2 8 10 

327111: Vitreous China Plumbing Fixture and China and 

Earthenware Bathroom Accessories Manufacturing 0 15 15 

327112: Vitreous China, Fine Earthenware, and Other 

Pottery Product Manufacturing 0 18 18 

327113: Porcelain Electrical Supply Manufacturing 0 13 13 

327121: Brick and Structural Clay Tile Manufacturing 1 42 43 

327122: Ceramic Wall and Floor Tile Manufacturing 0 8 8 

327123: Other Structural Clay Product Manufacturing 0 7 7 

327124: Clay Refractory Manufacturing 0 43 43 

327125: Nonclay Refractory Manufacturing 1 16 17 

327410: Lime Manufacturing 2 33 35 

327420: Gypsum Product Manufacturing 

0 64 64 

327910: Abrasive Product Manufacturing 

327999: All Other Miscellaneous Nonmetallic Mineral 

Product Manufacturing 

339999MIN: All Other Miscellaneous Manufacturing 

423320: Brick, Stone, and Related Construction Material 

Merchant Wholesalers 0 49 49 

Total 37 3,384 b 3,421 

Source: DMRLoads2008_v2. 

a – DMR data is reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison 

purposes. 

b – The DMR data in PCS and ICIS-NPDES does not include discharge data for all minor dischargers. For the 

facilities in the Mineral Mining Category, 1,109 of the 3,384 minor dischargers have DMR data. 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-6

Table 9-3 presents the type of discharges reported by facilities in the 2008 TRI database. 

The majority of mineral mining facilities reporting to TRI do not report water discharges, but 

those that do mostly reported discharging directly. 

Table 9-3. Number of Mineral Mining Facilities by Type of Discharger in TRI 2008 

NAICS Code 

Number of Facilities in TRI 2008 

Direct 

Dischargers 

Only 

Indirect 

Dischargers 

Only 

Both 

Indirect and 

Direct 

No Water 

Discharges 

212311: Dimension Stone Mining and Quarrying 0 0 0 0 

212312: Crushed and Broken Limestone Mining and 

Quarrying 1 0 0 2 

212313: Crushed and Broken Granite Mining and 

Quarrying 1 1 0 2 

212319: Other Crushed and Broken Stone Mining and 

Quarrying 1 0 0 3 

212324: Kaolin and Ball Clay Mining 1 0 0 1 

212325: Clay and Ceramic and Refractory Minerals 

Mining 0 0 0 3 

212393: Other Chemical and Fertilizer Mineral 

Mining 0 0 0 1 

212399: All Other Nonmetallic Mineral Mining 1 0 0 20 

327992: Ground or Treated Mineral and Earth 

Manufacturing 5 2 0 36 

212321: Construction Sand and Gravel Mining 5 0 0 1 

212322: Industrial Sand Mining 0 0 0 0 

212391: Potash, Soda, and Borate Mineral Mining 0 0 0 0 

212392: Phosphate Rock Mining 0 0 0 0 

213115: Support Activities for Nonmetallic Minerals 

(except Fuels) 0 0 0 1 

327111: Vitreous China Plumbing Fixture and China 

and Earthenware Bathroom Accessories 

Manufacturing 

3 0 0 2 

327112: Vitreous China, Fine Earthenware, and Other 

Pottery Product Manufacturing 1 1 1 5 

327113: Porcelain Electrical Supply Manufacturing 0 1 0 4 

327121: Brick and Structural Clay Tile Manufacturing 2 1 1 92 

327122: Ceramic Wall and Floor Tile Manufacturing 1 4 0 12 

327123: Other Structural Clay Product Manufacturing 1 1 0 3 

327124: Clay Refractory Manufacturing 2 0 0 10 

327125: Nonclay Refractory Manufacturing 1 6 1 11 

327410: Lime Manufacturing 5 0 0 43 

327420: Gypsum Product Manufacturing 31 0 0 54 

327910: Abrasive Product Manufacturing 0 4 0 24 

327999: All Other Miscellaneous Nonmetallic 

Mineral Product Manufacturing 2 5 0 38 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-7

Table 9-3. Number of Mineral Mining Facilities by Type of Discharger in TRI 2008 

NAICS Code 

Number of Facilities in TRI 2008 

Direct 

Dischargers 

Only 

Indirect 

Dischargers 

Only 

Both 

Indirect and 

Direct 

No Water 

Discharges 

339999MIN: All Other Miscellaneous Manufacturing 0 0 0 1 

423320: Brick, Stone, and Related Construction 

Material Merchant Wholesalers 0 0 0 2 

Total 64 26 3 371 

Source: TRIReleases2008_v3. 

9.1.2 40 CFR Part 436 

There are 38 subcategories for the Mineral Mining ELGs. EPA first promulgated ELGs 

for the Mineral Mining Category (40 CFR Part 436) on October 16, 1975 (40 FR 48657) for 

selected subparts. EPA proposed regulations on June 10, 1976 for additional subparts, of which 

only Subparts B, C, D, and R were promulgated on July 1979. National amendments were made 

to the ELGs on December 28, 1979. 17 of the subparts in 40 CFR Part 436 are reserved. The 

majority of the remaining subcategories have no discharge requirements or best practical control 

technology (BPT) limitations. Table 9-4 lists the 38 subcategories and applicability. 

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

Subpart Subcategory Title Subcategory Applicability 

A Dimension Stone Reserved 

B Crushed Stone Crushed and broken stone and riprap, including calcite in 

conjunction with the processing of limestone or dolomite 

C Construction Sand and Gravel Sand and gravel for construction or fill uses, excluding on-board 

processing of dredged sand and gravel that is covered by 33 CFR 

Part 230 

D Industrial Sand Sand and gravel for uses other than construction fill including, but 

not limited to, glassmaking, molding, abrasives, filtration, 

refractories, and refractory bonding 

E Gypsum Gypsum 

F Asphaltic Mineral Bituminous limestone, oil-impregnated diatomite and olsonite not 

primarily as an energy source 

G Asbestos and Wollastonite Asbestos and wollastonite 

H Lightweight Aggregates Reserved 

I Mica and Sericite Reserved 

J Barite Barite 

K Fluorspar Fluorspar 

L Salines from Brine Lakes Salines from brine lakes 

M Borax Borate minerals, excluding borax obtained from brine lakes that is 

covered by 40 CFR Part 436 Subpart L 

N Potash Potash, excluding potash obtained from brine lakes that is covered 

by 40 CFR Part 436 Subpart L 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-8

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

Subpart Subcategory Title Subcategory Applicability 

O Sodium Sulfate Sodium sulfate, excluding sodium sulfate obtained from brine lakes 

that is covered by 40 CFR Part 436 Subpart L 

P Trona Reserved 

Q Rock Salt Reserved 

R Phosphate Rock Phosphate bearing rock, ore or earth for the phosphate content 

S Frasch Sulfur Sulfur on shore and in marshes and estuaries by the Frasch process, 

excluding sulfur refining operations that are not performed at the 

mining and collection site 

T Mineral Pigments Reserved 

U Lithium Reserved 

V Bentonite Bentonite 

W Magnesite Magnesite 

X Diatomite Diatomite 

Y Jade Jade 

Z Novaculite Novaculite 

AA Fire Clay Reserved 

AB Attapulgite and 

Montmorillonite 

Reserved 

AC Kyanite Reserved 

AD Shale and Common Clay Reserved 

AE Aplite Reserved 

AF Tripoli Tripoli 

AG Kaolin Reserved 

AH Ball Clay Reserved 

AI Feldspar Reserved 

AJ Talc, Steatite, Soapstone and 

Pyrophyllite 

Reserved 

AK Garnet Reserved 

AL Graphite Graphite 

Source: Mineral Mining and Processing Point Source Category – 40 CFR 436. 

9.2 Mineral Mining Category 2010 Screening-Level Review

Table 9-5 compares the screening-level results for the Mineral Mining Category from the 

2006 through 2010 annual reviews. The combined DMR and TRI TWPE decreased from 

discharge years 2004 to 2007, but increased from discharge years 2007 to 2008. The discharge 

year 2008 DMR TWPE accounts for approximately 97 percent of the combined 2008 DMR and 

TRI TWPE. 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-9

Table 9-5. Mineral Mining Category TRI and DMR Discharges for the 2010 and Previous 

Screening-Level Reviews 

Year of Discharge Year of Review 

Mineral Mining Category 

TRI TWPE DMR TWPE a Total TWPE 

2002 2006 2,840 50,500 53,340 

2004 2007 5,390 49,300 54,700 

2005 2008 6,260 NA NA 

2007 2009 2,420 26,700 29,100 

2008 2010 3,390 100,000 103,000 

Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; 

TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; and DMRLoads2008_v2. 

a – DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and 

major dischargers. 

NA – Not applicable. EPA did not evaluate DMR data for 2005. 

Table 9-6 presents the 2008 DMR TWPE by facility discharge classification. EPA 

excluded minor dischargers from previous annual reviews, but included them in the 2010 annual 

review. The majority (69 percent) of the TWPE in the 2008 DMR database results from major 

dischargers. 

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

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers 

2008 30,800 69,300 

Source: DMRLoads2008_v2. 

a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous 

annual reviews. 

9.3 Mineral Mining Category Pollutants of Concern

Table 9-7 compares the five pollutants with the highest TWPE based on the results from 

the 2010, 2009, and 2007 annual reviews (TRIReleases2008_v3, TRIReleases2007_v2, and 

TRIReleases2004_ v3, respectively). Table 9-8 lists the five pollutants with the highest DMR 

TWPE based on the results from the 2010, 2009, and 2007 annual reviews (DMRLoads2008_v2, 

DMRLoads2007_v3, and PCSLoads2004_v4, respectively). 
Section 9 – Mineral Mining and Proc

9-10

Table 9-7. Mineral Mining Category Top TRI Pollutants 

Pollutant 

2004 TRI Database a 2007 TRI Database a 2008 

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Nitrate Compounds 3 6 1,050 1 5 1,300 1 Copper and Copper Compounds Pollutants not reported in the top five 

TRI 2004 reported pollutants. 

Pollutants not reported in the top five 

TRI 2007 reported pollutants. 2 

Mercury and mercury Compounds 2 4 387 3 Manganese and Manganese Compounds 5 11 265 4 8 239 4 Lead and Lead Compounds 1 51 1,270 3 23 371 5 Ammonia Pollutants not reported in the top five 

TRI 2004 reported pollutants. 5 3 60 

Pollutants no

TRI 2008 

Nickel and Nickel Compounds 2 7 1,060 Pollutants not reported in the top five 

TRI 2007 reported pollutants. Chromium and Chromium Compounds 4 13 806 

Mineral Mining Category Total NA 101 b 6,260 NA 60 b 2,420 NA 

Source: TRIReleases2004_v3; TRIReleases2007_v2; and TRIReleases2008_v3. 

a – Discharges include transfers to POTWs and account for POTW removals. b – Number of facilities reporting TWPE greater than zero. NA – Not applicable. 
Section 9 – Mineral Mining and Proc

9-11

Table 9-8. Mineral Mining Category Top DMR Pollutants 

Pollutant 

2004 DMR Database a 2007 DMR Database a 2008 D

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

N

R

Sulfide 

Pollutant not reported in the top five DMR 

2004 reported pollutants. 

Pollutant not reported in the top five DMR 

2007 reported pollutants. 1 

Fluoride 1 14 41,800 1 14 18,700 2 Ammonia as Nitrogen 

Pollutant not reported in the top five DMR 

2004 reported pollutants. 

Pollutant not reported in the top five DMR 

2007 reported pollutants. 3 

Chloride 4 3 1,510 5 6 572 4 Lead 3 2 1,560 3 1 2,760 5 Cadmium 2 1 1,940 2 2 3,060 Pollutant not repZinc 5 3 482 4 1 710 2008 reMineral Mining Category Total NA 23 c 49,300 NA 28 c 26,700 NA 

Source: PCSLoads2004_v4; DMRLoads2007_v3; and DMRLoads2008_v2. 

a – 2004 and 2007 DMR data only include major dischargers. b – 2008 DMR data includes major and minor dischargers. c – Number of facilities reporting TWPE greater than zero. NA – Not applicable.
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-12

The Mineral Mining Category TWPE in the 2008 TRI database is significantly lower 

than the 2008 DMR TWPE. Therefore, EPA focused the preliminary category review on the 

DMR-reported pollutants that account for the majority of the category TWPE. 

EPA’s additional review for the 2008 DMR database pollutants of concern, sulfide, 

fluoride, and ammonia as nitrogen, is presented in the following subsections. EPA did not 

investigate the other top pollutants as part of the 2010 annual review because they account for a 

small percentage (27 percent) of the 2008 Mineral Mining Category combined DMR and TRI 

TWPE. 

Of the pollutants of concern for the Mineral Mining Category, Part 436 only regulates 

fluoride in Subpart D – Industrial Sand Subcategory. EPA’s 2010 annual review of the Mineral 

Mining Category determined that the majority of fluoride discharges are from facilities covered 

by the Phosphate Rock Subcategory (Subpart R). The Phosphate Rock Subcategory does not 

regulate fluoride. 

9.4 Mineral Mining Category Sulfide Discharges in DMR

As part of the 2010 annual review of the Mineral Mining Category, EPA reviewed sulfide 

discharges in the 2008 DMR database. Approximately 36 percent of the 2008 DMR TWPE is 

from sulfide discharges. Table 9-9 presents the sulfide discharges from mineral mining facilities 

in the 2008 DMR database. US Silica Co. in Rockwood, MI, accounts for 87 percent of the 

sulfide discharges in the DMR 2008 database for the Mineral Mining Category. This subsection 

provides information on US Silica’s sulfide discharges. 

Table 9-9. Mineral Mining Category Top Sulfide Discharging Facility in DMR 2008 

Facility Name 

Pounds of Sulfide 

Discharged Sulfide TWPE 

Percentage of 

Mineral Mining 

Category Sulfide 

DMR 2008 TWPE 

US Silica Co. 11,200 31,200 87% 

Stoneco Inc. 1,150 3,210 9% 

US Gypsum Co. 415 1,160 3% 

Stoneco Inc. – Maybee 57 159 <1% 

Stoneco Inc. - Denniston 40 113 <1% 

Total 12,800 35,900 100% 

Source: DMRLoads2008_v2. 

US Silica discharges sulfide from outfall 002. Table 9-10 presents US Silica’s 2008 

monthly sulfide discharge data in the DMR Loadings Tool for outfall 002. The facility permit 

states that outfall 002 is for sand and limestone mine dewatering water and process wastewater. 

The facility permit requires the facility to report dissolved sulfide concentrations monthly 

(MDEQ, 2005). 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-13

EPA reviewed DMR data from Envirofacts17 for 2008 – 2010. The 2008 sulfide and flow 

data from the DMR Loadings Tool corresponds to the Envirofacts, and EPA identified no 

corrections for data in the DMR Loadings Tool. EPA did find that US Silica only detected 

sulfide during one month from January 2008 through March 2010. Table 9-11 presents US 

Silica’s available 2009 and 2010 sulfide discharge data from Envirofacts. Given that these 

discharges occurred only once in almost three years, EPA finds that the sulfide discharges from 

this facility do not represent a consistent discharge for all silica mineral mines. EPA also does 

not believe the US Silica sulfide discharges warrant a revision to the Mineral Mining ELGs. For 

an individual facility, permit writers can apply best professional judgment to determine the 

appropriate control of discharges. 

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

Outfall 

Monitoring Period 

Date 

DMR Loadings Tool Maximum 

Sulfide Concentration (mg/L) 

DMR Loadings Tool Average 

Flow (MGD) 

002 31-Jan-08 2.20 13.06 

002 31-Mar-08 0 13.69 

002 30-Apr-08 0 13.38 

002 31-Aug-08 0 13.05 

002 30-Sep-08 0 12.81 

002 31-Oct-08 0 12.61 

002 30-Nov-08 0 12.23 

002 31-Dec-08 0 11.98 

Source: DMR Loadings Tool. 

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

Outfall 

Monitoring Period 

Date 

Envirofacts Sulfide Concentration 

(mg/L) Envirofacts Flow (MGD) 

002 30-Apr-09 0 11.45 

002 30-Jun-09 0 11.3 

002 31-Aug-09 0 11.68 

002 30-Sept-09 0 11.1 

002 31-Oct-09 0 11.8 

002 30-Nov-09 0 11.4 

002 31-Dec-09 0 12.3 

002 31-Jan-10 0 11.7 

002 28-Feb-10 0 11.9 

002 31-Mar-10 0 11.9 

Source: Envirofacts. 

 

17 EPA uses the data in Envirofacts as a source while reviewing the DMR Loadings Tool data because Envirofacts 

continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not 

continuously updated; therefore, loads may be estimated with erroneous data. 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-14

9.5 Mineral Mining Category Fluoride Discharges in DMR

As part of the 2010 annual review of the Mineral Mining Category, EPA reviewed 

fluoride discharges in the 2008 DMR database. Approximately 28 percent of the 2008 DMR 

TWPE is from fluoride discharges. Table 9-12 presents the fluoride discharges from mineral 

mining facilities in the 2008 DMR database. 

The majority (74 percent) of fluoride discharges in 2008 were from four fluoride 

discharging facilities: PCS Phosphates White Springs, PCS Phosphates White Springs (Jasper), 

US Agri-Chemicals, and Feldspar Corp. These fluoride discharges result from mineral mining 

processes that are regulated by Subparts R – Phosphate Rock and AI – Feldspar. Neither Subpart 

R nor Subpart AI sets limits for fluoride (Subpart AI is reserved). This subsection provides 

information on the fluoride discharges from the top four fluoride discharging facilities. 

Table 9-12. Mineral Mining Category Top Fluoride Discharging Facilities in DMR 2008

Facility Name Location 

Pounds of 

Fluoride 

Discharged Fluoride TWPE 

Percentage of 

Mineral Mining 

Category 

Fluoride DMR 

2008 TWPE 

PCS Phosphates White Springs White Springs, FL 334,000 10,000 35.6% 

PCS Phosphates White Springs 

(Jasper) Jasper, FL 173,000 5,200 18.4% 

US Agri-Chemicals – Ft Meade Fort Meade, FL 111,000 3,320 11.8% 

Feldspar Corp Spruce Pine Fac Spruce Pine, NC 72,300 2,170 7.7% 

Mosaic Fertilizer, LLC – Ft Gr White Springs, FL 50,500 1,510 5.4% 

Mosaic Fertilizer LLC - Four Polk County, FL 42,200 1,270 4.5% 

Remaining Mineral Mining 

Fluoride Dischargers a NA 156,000 4,690 16.7% 

Total 940,000 28,200 100% 

Source: DMRLoads2008_v2. 

a – There are 14 remaining mineral mining facilities that have fluoride discharges in DMRLoads2008_v2 that 

account for 16.7 percent of the Mineral Mining Category’s 2008 fluoride TWPE. 

NA – Not applicable. 

9.5.1 Wastewater Sources of Fluoride 

The majority of the fluoride discharges for the Mineral Mining and Processing Category 

are from phosphate mines in Florida and feldspar mines in North Carolina. EPA previously 

compiled information on this category, discussed in the 1976 Development Document for 

Interim Final Effluent Limitations Guidelines and Standards of Performance – Mineral Mining 

and Processing Industry (Mineral Mining Development Document). For the 2010 Final Plan, 

EPA compared current information to data from the Mineral Mining Development Document. 

Phosphate mines are located in four major producing areas: Florida, North Carolina, 

Tennessee, and western states. The phosphate rock is not a pure compound, but a fluorapitite 

mineral containing impurities of fluoride, iron, aluminum, silica, and uranium. In Florida, 

phosphate rock washing operations produce large quantities of slurry, very fine clay, and 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-15

phosphate minerals called slime. This slime is sent to settling ponds that cover large surface 

areas. Wastewater is generated from stormwater runoff from the slime storage and disposal area 

(U.S. EPA, 1976). Some of the Florida phosphate mines also appear to manufacture phosphatic 

fertilizer on site, which also generates fluoride-containing wastewater. See the Section 8.5.2 of 

the Technical Support Document for the 2006 Effluent Guidelines Program Plan (U.S. EPA, 

2006) for potential wastewater sources from the phosphate fertilizer operations. 

The feldspar mines in North Carolina use hydrofluoric acid flotation to separate the byproducts, which can include mica, quartz, and sand, from the feldspar (U.S. EPA, 1976). The 

feldspar processing uses significant quantities of water with little recycle because of possible 

build-up of soluble organics and fluoride ions. Facilities can also use sulfuric acid, sulfonic acid, 

frothers, amines and oils as the flotation agent. The Mineral Mining Development Document 

shows that treated effluent fluoride concentrations in 1976 ranged from 1.3 mg/L to 34 mg/L. 

The hydrofluoric acid flotation generates fluoride-containing wastewater, which can be 

minimized using a flotation circuit and/or partial recycle of the fluoride, as well as lime 

treatment. The Mineral Mining Development Document studied the performance of single stage 

chemical precipitation: lime addition with mixing followed by settling ponds. The 1976 data 

showed that single-stage chemical precipitation could achieve effluent fluoride concentrations of 

less than 10 mg/L through segregation and separate treatment of fluoride-containing streams 

(U.S. EPA, 1976). 

9.5.2 Top Facilities Discharging Fluoride 

The majority (75 percent) of fluoride discharges in 2008 were from the top four fluoride 

discharging facilities: PCS Phosphates White Springs, PCS Phosphates White Springs (Jasper), 

US Agri-Chemicals, and Feldspar Corp. Fluoride is generated in the open-pit mining of 

phosphate rock and the production of feldspar in the Phosphate Rock and Feldspar Subcategories 

of the Mineral Mining Category, respectively. This subsection provides information on each 

facility’s fluoride discharges from the 2008 DMR Loadings Tool and their corresponding permit 

limits, if available. 

PCS Phosphates White Springs in White Springs, FL 

PCS Phosphates White Springs generates wastewater from: open-pit mining of phosphate 

rock, beneficiation of the rock, manufacture of sulfuric acid and phosphoric acid, production of 

fertilizer components and animal-feed supplements, and stormwater runoff. The facility’s 

treatment system includes pH adjustment and chemical precipitation, when required, using lime; 

settling and sedimentation; and adsorption/absorption on mining waste clay particles in clay 

settling areas (FL DEP, 2003a). 

PCS Phosphates White Springs discharges fluoride from outfalls 001, 122, and 128. 

Outfall 001 is a surface water monitoring location. Table 9-13 describes outfall descriptions, 

fluoride limits, and the basis of the fluoride limits. 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-16

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

Outfall Outfall Description 

Fluoride Limits 

Daily 

Maximum 

(mg/L) 

Monthly 

Average 

(mg/L) Limit Basis a

001 

Swift Creek surface water monitoring 

location 10.0 

Report 

Only 

FL DEP water quality criteria 

for Class III predominately 

fresh surface water 

122 

Treated process wastewater, CNPW, 

stormwater, and treated sanitary wastewater 75.0 25.0 

Fertilizer Manufacturing 

ELGs 

128 

Treated process wastewater, CNPW, 

stormwater, treated sanitary wastewater, and 

discharges above mid-point of the surge 

capacity from the calcium sulfate stormwater 

pile runoff system 75.0 25.0 

Fertilizer Manufacturing 

ELGs 

Source: Facility Permit (FL DEP, 2003a). 

a – The facility’s permit and fact sheet do not state the basis for the fluoride limit. However, the limits set 

correspond to FL water quality criteria for Class III predominately fresh surface water. The permit limits may also 

be based on permit writer best professional judgment. 

Table 9-14 presents the monthly discharge data for the PCS Phosphates White Springs 

facility for outfalls 001 and 122, which account for the majority of the fluoride discharges. As 

shown in Table 9-14, the fluoride concentrations in the 2008 DMR data are below permit 

limitations. Outfall 001 represents a surface water monitoring location; therefore, EPA will 

exclude these discharges from future screening-level databases. This exclusion would reduce the 

facility’s fluoride discharges from 10,000 TWPE to 2,340 TWPE. Additionally, the fluoride 

concentrations at outfall 001 are less than the Florida Department of Environmental Protection’s 

(FL DEP’s) water quality standard, showing that PCS Phosphates White Springs’ fluoride 

discharges are not expected to impact the quality of the receiving stream. 

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

Springs 

Monitoring 

Period Date 

DMR Loadings Tool 

Daily Maximum 

Fluoride 

Concentration (mg/L) 

DMR Loadings Tool 

Monthly Average 

Fluoride 

Concentration (mg/L)

Daily Maximum 

Fluoride Permit Limit 

(mg/L) 

Monthly Average 

Fluoride Permit Limit 

(mg/L) 

Outfall 001 – Surface Water Monitoring 

31-Jan-08 2.62 2.34 10 Report 

29-Feb-08 2.03 1.92 10 Report

31-Mar-08 1.83 1.73 10 Report

30-Apr-08 2.18 1.97 10 Report

31-May-08 2.26 2.19 10 Report

30-Jun-08 2.33 2.23 10 Report

31-Jul-08 2.55 2.39 10 Report

31-Aug-08 2.26 2.13 10 Report

30-Sep-08 2.59 2.44 10 Report

31-Oct-08 2.52 2.45 10 Report
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-17

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

Springs 

Monitoring 

Period Date 

DMR Loadings Tool 

Daily Maximum 

Fluoride 

Concentration (mg/L) 

DMR Loadings Tool 

Monthly Average 

Fluoride 

Concentration (mg/L)

Daily Maximum 

Fluoride Permit Limit 

(mg/L) 

Monthly Average 

Fluoride Permit Limit 

(mg/L) 

30-Nov-08 2.7 2.60 10 Report

31-Dec-08 2.45 2.34 10 Report

Outfall 122 - Treated Process Wastewater, CNPW, Stormwater, and Treated Sanitary Wastewater 

31-Jan-08 10.19 5.06 75 25 

29-Feb-08 4.1 4.10 75 25

31-Mar-08 6.43 5.07 75 25

30-Apr-08 4.38 4.02 75 25

31-May-08 5.92 4.92 75 25

30-Jun-08 5.55 4.70 75 25

31-Jul-08 5.17 4.82 75 25

31-Aug-08 5.5 4.78 75 25

30-Sep-08 3.98 3.26 75 25

31-Oct-08 5.36 4.27 75 25

30-Nov-08 4.77 3.93 75 25

31-Dec-08 3.15 1.81 75 25

Source: DMR Loadings Tool and Facility Permit (FL DEP, 2003a). 

PCS Phosphates White Springs (Jasper) in Jasper, FL 

PCS Phosphates White Springs (Jasper) generates wastewater from: open-pit mining of 

phosphate rock, beneficiation of the rock, and stormwater from the Suwannee River Chemical 

Complex and Mine. The facility’s treatment system includes pH adjustment and chemical 

precipitation, when required, using lime; settling and sedimentation; and adsorption/absorption 

on mining waste clay particles in clay settling areas (FL DEP, 2003b). 

PCS Phosphates White Springs (Jasper) discharges most of its fluoride from outfall 001, 

with minor discharges from outfalls 1A2, 1H8, and 202. Outfall 001 represents a surface water 

monitoring location in Swift Creek, the receiving stream for outfalls 1A2, 1H8, and other 

outfalls. Outfall 202 is process wastewater from the mining and beneficiation of phosphate rock, 

CNPW, stormwater, mine dewatering, and treated sanitary wastewater. 

Table 9-15 presents the monthly discharge data for the PCS Phosphates White Springs 

(Jasper) facility for outfall 001 (in-stream monitoring location), compared to the fluoride permit 

limits. As shown in Table 9-15, the fluoride concentrations in the 2008 DMR data are below 

permit limitations. Outfall 001 represents a surface water monitoring location; therefore, EPA 

will exclude these discharges from future screening-level databases. This exclusion would reduce 

the facility’s fluoride discharges from 5,200 TWPE to 720 TWPE. Additionally, the fluoride 

concentrations at outfall 001 are less than the FL DEP’s water quality standard, showing that 

PCS Phosphates White Springs (Jasper)’s fluoride discharges are not expected to impact the 

quality of the receiving stream. 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-18

Table 9-15. Outfall 001 Monthly Fluoride Concentrations and Limits for PCS Phosphates 

White Springs (Jasper) 

Monitoring Period 

Date 

DMR Loadings Tool 

Daily Maximum 

Fluoride 

Concentration 

(mg/L) 

DMR Loadings Tool 

Monthly Average 

Fluoride 

Concentration 

(mg/L) 

Daily Maximum 

Fluoride Permit 

Limit (mg/L) a 

Monthly Average 

Fluoride Permit 

Limit (mg/L) a 

31-Jan-08 2.62 2.34 10 Report Only 

29-Feb-08 2.03 1.92 10 Report Only

31-Mar-08 0.3 1.73 10 Report Only

30-Apr-08 2.18 1.97 10 Report Only

31-May-08 2.26 2.19 10 Report Only

30-Jun-08 2.33 2.23 10 Report Only

31-Jul-08 2.55 2.39 10 Report Only

31-Aug-08 2.26 2.13 10 Report Only

30-Sep-08 2.59 2.44 10 Report Only

31-Oct-08 2.52 2.45 10 Report Only

30-Nov-08 2.71 2.60 10 Report Only

31-Dec-08 2.45 2.34 10 Report Only

Source: 2008 DMR Loadings Tool and Facility Permit (FL DEP, 2003b). 

a – EPA suspects these fluoride limits are based on FL DEP water quality criteria for Class III predominately fresh 

surface water. 

US Agri-Chemicals Corporation in Fort Meade, FL 

US Agri-Chemicals Corporation manufactures sulfuric acid, phosphoric acid, monoammonium phosphate, di-ammonium phosphate, and fluosilicic acid. US Agri-Chemicals also 

has a lined phosphogypsum stack and an un-lined process water cooling pond with a 

recirculation system. The facility is working with the state to close the un-lined pond. The 

facility’s 2004 NPDES permit also allows the facility to construct an additional lined 

phosphogypsum stack. The facility treats wastewater from both ponds through a two-stage lime 

treatment and spray aeration process prior to discharge (FL DEP, 2004). 

Table 9-16 presents the monthly fluoride discharge data for US Agri-Chemicals for 

outfall 004, compared to the fluoride permit limits. As shown in Table 9-16, the fluoride 

concentrations in the 2008 DMR data are below permit limitations. Additionally, based on the 

permit and fact sheet, EPA believes that the facility’s operations fall within the applicability of 

the Fertilizer Manufacturing ELGs (40 CFR Part 418) and/or Phosphate Manufacturing ELGs 

(40 CFR Part 422) rather than the Mineral Mining ELGs (40 CFR Part 436) because the facility 

does not have any mining operations. Therefore, discharges from this facility should be excluded 

from the 2010 annual review of the Mineral Mining Category, reducing the category’s TWPE by 

3,530 TWPE. As part of future annual reviews, EPA will continue its review of this facility’s 

discharges and reassign this facility to the correct category. 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-19

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

Corporation 

Outfall 

Monitoring Period 

Date 

Maximum Fluoride 

Concentration from 

DMR Data (mg/L) 

Daily Maximum 

Fluoride Permit 

Limit (mg/L) 

Monthly Average 

Fluoride Permit 

Limit (mg/L) 

004 31-Jan-08 7.15 10 Report 

004 29-Feb-08 5.50 10 Report

004 31-Mar-08 3.07 10 Report

004 30-Apr-08 3.23 10 Report

004 31-May-08 2.96 10 Report

004 30-Jun-08 3.60 10 Report

004 31-Jul-08 4.44 10 Report

004 31-Aug-08 4.01 10 Report

004 30-Sep-08 4.50 10 Report

004 31-Oct-08 5.53 10 Report

004 30-Nov-08 5.10 10 Report

004 31-Dec-08 3.86 10 Report

Source: DMR Loadings Tool and Facility Permit (FL DEP, 2004). 

Feldspar Corporation in Spruce Pine, NC 

The Feldspar Corporation is an industrial minerals processing facility. The facility 

produces feldspar, quartz, and mica. Outfall 001 discharges treated process wastewater to the 

North Toe River. The facility’s treatment system includes clarifiers, polymer feed system, lime 

for pH adjustment, vacuum filters, and an Emico clarifier/thickener to outfall 001 (NC DWQ, 

2006). 

The facility discharges fluoride from outfall 001. Table 9-17 presents the monthly 

fluoride discharge data for Feldspar. The fluoride permit limits for the facility were 225 lb/day 

monthly average and 448 lb/day daily maximum when the facility was treating discharges from 

Unimum Corporation’s Crystal Operation. However, once Unimum began directly discharging, 

Feldspar’s fluoride limits were revised to 174 lb/day monthly average and 348 lb/day daily 

maximum (NC DWQ, 2006). It is unclear which limits applied in 2008. As shown in Table 9-17, 

the facility did not meet fluoride permit limits for at least part of 2008. The monthly average 

fluoride quantities discharged are above the original permit limit for January and February 2008 

and above the revised permit limit for all of 2008. The daily maximum fluoride quantities are 

similarly above the original and revised daily maximum fluoride limits for 2008. This facility 

appears to be exceeding its mass-based permit fluoride limit. 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-20

Table 9-17. Outfall 001 Monthly Fluoride Discharge Data and Limits for Feldspar 

Corporation 

Monitoring 

Period Date 

DMR Loadings Tool Daily Maximum 

Fluoride Quantity (lb/day) 

DMR Loadings Tool Monthly Average 

Fluoride Quantity (lb/day) 

31-Jan-08 539 221.6 

29-Feb-08 623.9 237.9 

31-Mar-08 443.7 222.1 

30-Apr-08 433.5 211.2 

31-May-08 366.9 167.2 

30-Jun-08 426.4 217.0 

31-Jul-08 376.6 181.4 

31-Aug-08 430.4 216.5 

30-Sep-08 407.2 186.2 

31-Oct-08 445.9 220.1 

30-Nov-08 381.5 158.3 

31-Dec-08 385.3 139.7 

Source: DMR Loadings Tool. 

9.5.3 Fluoride Wastewater Treatment 

EPA determined that the top fluoride discharging facilities have two-stage chemical 

precipitation with lime treatment systems. This process is similar to that at phosphatic fertilizer 

manufacturing facilities, which achieve fluoride concentrations of 15 mg/L or less (U.S. EPA, 

1974). Current technologies are achieving fluoride concentrations at least as effective, sometimes 

achieving 2 mg/L effluent fluoride. The chemical precipitation has improved by using calcium 

chloride (CaCl2) rather than lime, while solids separation has improved by using polymers and 

membrane filters (WC&E, 2006; Ionics, Unknown; GCIP, 2002). 

9.6 Mineral Mining Category Ammonia as Nitrogen Discharges in DMR

As part of the 2010 annual review of the Mineral Mining Category, EPA reviewed 

ammonia as nitrogen (ammonia as N) discharges in the 2008 DMR database. Approximately 11 

percent of the 2008 DMR TWPE is from discharges of ammonia as N. Table 9-18 presents the 

ammonia as N discharges from mineral mining facilities in the 2008 DMR database. Glen-Gery 

Corporation in Tully Township, OH, accounts for 99 percent of the ammonia as N discharges in 

the DMR 2008 database for the Mineral Mining Category. This subsection provides information 

on Glen-Gery’s ammonia as N discharges. 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-21

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

DMR 2008 

Facility Name Location 

Pounds of 

Ammonia as N 

Discharged 

Ammonia as N 

TWPE 

Percentage of 

Mineral Mining 

Category 

Ammonia as N 

DMR 2008 

TWPE 

Glen-Gery Corporation Tully Township, OH 9,900,000 11,000 99 

Remaining Mineral Mining 

Ammonia as N Dischargers a NA 24,400 27.2 1.3% 

Total 10,030,000 11,100 100% 

Source: DMRLoads2008_v2. 

a – There are 35 remaining mineral mining facilities that have ammonia as N discharges in DMRLoads2008_v2 that 

account for approximately 1.3 percent of the Mineral Mining Category’s 2008 ammonia as N TWPE. 

NA – Not applicable. 

Glen-Gery discharges ammonia as N through outfall 002. Table 9-19 presents GlenGery’s 2008 quarterly ammonia as N and flow discharge data in the DMR Loadings Tool for 

outfall 002. EPA compared the concentration and flow data from the DMR Loadings Tool to the 

data in Envirofacts and determined that there is a unit of measurement error for the outfall 002 

flows. The flows in the DMR Loadings Tool were 1,000,000 times higher than the data in 

Envirofacts, also presented in Table 9-19. Using the outfall 002 flows from Envirofacts, GlenGery’s ammonia as N discharges are 6.31 pounds and 0.004 TWPE for 2008, reducing the 

facility’s total TWPE by 99 percent. This reduction in TWPE decreases the Mineral Mining 

Category’s 2008 DMR TWPE by 11,000 TWPE, and ammonia as N would no longer be a top 

pollutant of concern. 

Table 9-19. Glen-Gery Corporation’s 2008 Quarterly Ammonia as N and Flow Discharge 

Data 

Outfall 

Monitoring Period 

Date 

DMR Loadings Tool 

Maximum Sulfide 

Concentration (mg/L) 

DMR Loadings Tool 

Average Flow (MGD) 

Envirofacts Flow 

(MGD) 

002 31-Mar-08 6.88 500 0.005 

002 30-Jun-08 0.03 500 0.005

002 31-Aug-08 0.19 500 0.005

002 31-Dec-08 18.6 500 0.005

Source: DMR Loadings Tool and Envirofacts. 

9.7 Mineral Mining Category Conclusions

Based on available data, the estimated toxicity of the Mineral Mining Category 

discharges in the screening-level databases result from sulfide, fluoride, and ammonia as N 

discharges. Data collected for the 2010 annual review demonstrated that wastewater discharge 

characteristics for this category are consistent with discharges from prior years. As in prior years, 

EPA makes the following conclusions: 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-22

• The 2008 sulfide discharge from U.S. Silica was restricted to a single month, and 

the facility has not reported any sulfide discharges since January 1, 2008. EPA 

does not consider this pollutant a concern at this time, but will review the 

discharges for sulfide as part of future annual reviews. 

• The fluoride discharges in the Mineral Mining Category are from phosphate and 

feldspar mining facilities regulated by Subpart R – Phosphate Rock and Subpart 

AI – Feldspar (reserved), respectively. These facilities are also located in areas 

with naturally occurring fluoride compounds in the ore, Florida and North 

Carolina. 

• The fluoride discharges from phosphate mines were misrepresented in the 

screening level databases: 

— The majority of the fluoride discharges from PCS Phosphates White 

Springs and PCS Phosphates White Springs (Jasper) represented surface 

water monitoring stations, not process wastewater outfalls. Excluding the 

fluoride discharges from these outfalls reduces the Mineral Mining 

Category’s fluoride TWPE by 8,010 TWPE. In addition, fluoride 

concentrations measured at these surface water outfalls were below the FL 

DEP water quality criteria for Class III predominately fresh surface water. 

— The US Agri-Chemicals’ operations do not meet the applicability of the 

Mineral Mining Category. The facility’s operations meet the applicability 

of the Fertilizer Manufacturing and/or Phosphate Manufacturing 

Categories. EPA will review the facility’s discharges in future annual 

reviews and will reassign this facility to the correct category. 

 As a result, EPA will collect additional data on fluoride discharges from mineral 

mining facilities for consideration during the 2011 annual review. 

• Feldspar Corporation appears to be exceeding its mass based fluoride permit 

limits. Subpart AI – Feldspar of the Mineral Mining Category does not currently 

regulate fluoride discharges. Permit limit exceedances do not warrant the need for 

further regulation but rather better facility compliance. EPA will continue to 

monitor fluoride discharges from Feldspar Corporation. 

• Database errors were identified for discharges of ammonia as N. After correcting 

these errors, the Mineral Mining Category TWPE from ammonia as N decreased 

by 99 percent, from 11,100 TWPE to 100 TWPE and does not represent a hazard 

priority. 

Based on the above conclusions, EPA is assigning this category with a lower priority for 

revision (i.e., this category is marked with “(5)” in the “Findings” column in Table V-1 in the 

Federal Register notice that presents the 2009 annual review of existing effluent guidelines and 

pretreatment standards). 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-23

9.8 Mineral Mining Category References

1. FL DEP. 2003a. Florida Department of Environmental Protection. National Pollution 

Discharge System Permit NPDES – FL0036226 – PCS Phosphates White Springs. White 

Springs, FL. (May 27). EPA-HQ-OW-2004-0032-1169. 

2. FL DEP. 2003b. Florida Department of Environmental Protection. National Pollution 

Discharge System Permit NPDES – FL0000665 – PCS Phosphates White Springs 

(Jasper). Jasper, FL. (May 27). EPA-HQ-OW-2008-0517 DCN 07283. 

3. FL DEP. 2004. Florida Department of Environmental Protection. National Pollution 

Discharge System Permit NPDES – FL0001902 – U.S. Agri-Chemicals Corporation. Fort 

Meade, FL. (January 26). EPA-HQ-OW-2008-0517 DCN 07285. 

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

Treatment. Available online at: http://www.genchem.com/calcium/NCh14.html. Date 

accessed: July 27, 2006. EPA-HQ-OW-2004-0032-2606. 

5. MDEQ. 2005. Michigan Depart of Environmental Quality. National Pollution Discharge 

Elimination System Permit NPDES – MI0001368 – U.S. Silica. Rockwood, MI. (October 

1). EPA-HQ-OW-2008-0517 DCN 07287. 

6. Ionics. Unknown. “The EnChem® Process for Fluoride Removal.” Wastewater 

Treatment for the Microelectronics Industry. Available online at: 

http://www.iconics.com/pdf/TS4752EUS.pdf. Date accessed: July 27, 2006. EPA-HQOW-2004-0032-2605. 

7. NC DWQ. 2006. North Carolina Division of Water Quality. National Pollution Discharge 

Elimination System Permit NPDES – NC0000353 – Feldspar Corporation. Spruce Pine, 

NC. (August 31). EPA-HQ-OW-2008-0517 DCN 07289. 

8. U.S. Census. 2002. U.S. Economic Census. Available online at: 

http://www.census.gov/econ/census02. 

9. U.S. EPA. 1974. Development Document for Effluent Limitations Guidelines and New 

Source Performance Standards for the Basic Fertilizer Chemicals Segment of the 

Fertilizer Manufacturing Point Source Category. EPA-440/1-75/042-a. Washington, DC. 

(March). 

10. U.S. EPA. 1976. Development Document for Interim Final Effluent Limitations 

Guidelines and Standards of Performance for the Mineral Mining and Processing 

Industry. EPA-440-1-76-059-a. Washington, DC. (June). 

11. U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program 

Plan. EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346 

through 1352. 
Section 9 – Mineral Mining and Processing (40 CFR Part 436) 

9-24

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

Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782. 

13. WC&E. 2006. Wastech Controls & Engineering, Inc. Fluoride Wastewater Treatment 

(FWT) (HF Neutralization or Fluoride Reduction. Available online at: 

http://www.wastechengineering.com/papers/hf.htm. Date accessed: July 27. EPA-HQOW-2004-0032-2604. 
Section 10 – Oil & Gas Extraction (40 CFR Part 435) 

10-1

10. OIL & GAS EXTRACTION (40 CFR PART 435) 

EPA selected the Oil and Gas Extraction (Oil and Gas) Category for preliminary review 

because it ranks high, in terms of TWPE, in point source category rankings (see Table 5-3 for the 

point source category rankings). This section summarizes the results of the 2010 annual review 

associated with the Oil and Gas Category. EPA focused on discharges of sulfide from one oil 

extraction facility, because of its high toxic-weighted pound equivalent (TWPE) relative to the 

other facilities in the Oil and Gas Category. EPA also reviewed stakeholder comments regarding 

hydraulic fracturing to retrieve shale gas (see Table 2-1). The Final 2006 Plan summarizes the 

results of EPA’s previous review of this industry, specifically the coalbed methane (CBM) 

sector, in 2004 and 2005 (71 FR 76644). See Section 16.2 of this document for information on 

EPA’s detailed study of the CBM sector. 

10.1 Oil and Gas Category Background

This subsection provides the background on the Oil and Gas Category including a brief 

profile of the oil and gas industry and background on 40 CFR Part 435. 

10.1.1 Oil and Gas Industry Profile 

The oil and gas industry includes facilities that explore, drill, and produce oil or gas, 

along with the support operations. The exploration process consists of mapping, aerial 

photography, special surveys to find underground conditions favorable to oil or gas deposits, and 

exploratory drilling. The drilling process includes drilling to reach oil or gas reservoirs or to gain 

knowledge of geologic formations. The production includes separating the fluid fractions (e.g., 

gas from liquid, oil from water), treating the wastes, and further processing to improve the 

separations (U.S. EPA, 1976). EPA considered the following two North American Industry 

Classification System (NAICS) codes as part of the Oil and Gas Category. 

• 211111: Crude Petroleum and Natural Gas Extraction; and 

• 213112: Support Activities for Oil Gas Operations. 

Because the Permit Compliance System (PCS) and Integrated Compliance Information 

System – National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the 

sources of the discharge monitoring report (DMR) data used to develop DMRLoads2008, report 

facilities by Standard Industrial Classification (SIC) code, and the U.S. Economic Census and 

Toxics Release Inventory (TRI) report data by NAICS code, EPA reclassified the 2008 DMR 

data by the equivalent NAICS code. Table 10-1 lists the number of facilities from the U.S. 

Census and the screening-level databases for the two NAICS codes with operations in the Oil 

and Gas Category, including the corresponding SIC codes for reference. Because the only 

facility listed in the 2008 TRI database for the Oil and Gas Category does not report water 

discharges, the remaining sections for this category review will focus on the data in the 2008 

DMR database. The U.S. Economic Census includes more facilities than the screening-level 

databases because of many possible factors including: facilities may not meet TRI-reporting 

thresholds, facilities may discharge to a publicly owned treatment works (POTW), and some 

facilities in the U.S. Economic Census are distributors or sales facilities, not manufacturers. 
Section 10 – Oil & Gas Extraction (40 CFR Part 435) 

10-2

Table 10-1. Number of Oil and Gas Facilities 

NAICS Code 

Corresponding SIC 

Code 

Number of Facilities

2002 U.S. 

Economic Census

2008 DMR 

Database a

2008 TRI 

Database b

211111 Crude Petroleum 

and Natural Gas Extraction

1311: Crude Petroleum 

and Natural Gas 7,227 2,899 0 

213112 Support Activities 

for Oil and Gas Operations 

1381: Drilling Oil and 

Gas Wells; 

1382: Oil and Gas Field 

Exploration; 

1389: Oil and Field 

Services, NEC; 

4925: Mixed, 

Manufactured, or 

Liquid Gas Production 6,367 407 1 c 

Total >13,594 3,306 1 

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2; and TRIReleases2008_v3. 

a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore EPA used an NAICS-to-SICcode crosswalk for comparison purposes. 

b – Releases to any media. 

c – Note this facility did not report water discharges in 2008. 

Table 6-2 shows whether permitting authorities designated direct discharges as minor or 

major (see Section 4.1.5) for facilities in the Oil and Gas Category. EPA included data for minor 

discharges for the first time in the 2010 annual review, as part of DMRLoads2008_v2 database. 

EPA does not require permitting authorities to submit DMR data for minor discharges; however, 

many states do provide complete DMR data for them. From this year’s review, EPA observed 

many data entry or other errors for minor discharges in addition to those previously identified for 

major discharges, as discussed in Section 4.3. Table 10-2 shows that more than 99 percent of the 

Oil and Gas Category dischargers in the 2008 DMR database are minor dischargers. Table 10-3

shows the number of facilities with and without discharge data in the 2004, 2007, and 2008 

DMR databases. 

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

NAICS Code a 

Number of Facilities in 2008 DMR Database 

Major Dischargers Major Dischargers Major Dischargers

211111 Crude Petroleum and Natural Gas 

Extraction 

8 2,891 2,899 

213112 Support Activities for Oil and Gas 

Operations 

1 406 407 

Total 9 3,297 3,306 

Source: DMRLoads2008_v2. 

a – DMR data is reported by SIC code; therefore EPA used an NAICS to SIC crosswalk for comparison purposes. 
Section 10 – Oil & Gas Extraction (40 CFR Part 435) 

10-3

Table 10-3. Number of Oil and Gas Facilities in DMR Databases for Reporting Years 

2004, 2007, and 2008 a 

Discharge Status 2004 2007 2008 

With Water Discharge Data b 3 5 135 

Without Water Discharge 

Data c 291 1,569 3,171 

Total 294 1,574 3,306 

Source: PCSLoads2004_v3; DMRLoads2007_v4; and DMRLoads2008_v2. 

a – Major and minor dischargers. 

b – Includes facilities with DMR data in the DMR databases. 

c – Includes facilities with NPDES permits without DMR data in the DMR databases. 

10.1.2 40 CFR Part 435 

EPA first promulgated effluent limitation guidelines and standards (ELGs) for the Oil and 

Gas Category (40 CFR Part 435) on April 13, 1979 (40 FR 22069). Best available technology 

(BAT) , best current technology (BCT), and new source performance standards (NSPS) 

limitations were promulgated on March 4, 1993 (58 FR 12454) for Subpart A: Offshore 

Subcategory and on December 16, 1996 (61 FR 66086) for Subpart D: Coastal Subcategory. 

Table 10-4 lists the existing subcategories for the Oil and Gas Category and describes their 

applicability. Subpart B is reserved. 

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

Subpart Title Description 

A Offshore Applicable to facilities engaged in field exploration, drilling, well production, and well 

treatment that are located in waters that are offshore. Offshore is defined as seaward of 

the inner boundary of the territorial seas. 

C Onshore Applicable to facilities engaged in field exploration, drilling, well completion, and well 

treatment that are located onshore. Onshore is defined as landward of the inner 

boundary of the territorial seas. 

D Coastal Applicable to facilities engaged in field exploration, drilling, well production, and well 

treatment that are located in coastal waters. Coastal is defined as landward of the inner 

boundary of the territorial seas or landward of the inner boundary of the territorial seas 

and bounded on the inland side by the line defined by the inner boundary of the 

territorial seas. 

E Agricultural 

and Wildlife 

Water Use 

Applicable to onshore facilities engaged in field exploration, drilling, well completion, 

and well treatment that are located in the United States west of the 98th meridian for 

which the produced water has a use in agriculture or wildlife propagation when 

discharged to navigable waters. 

F Stripper a Applicable to onshore facilities engaged in production and well treatment that produce 

10 barrels per well per calendar day or less of crude oil and are operating at the 

maximum feasible rate of production. 

G General 

Provisions a

Prevents oil and gas facilities applicable to 40 CFR Part 435 Subparts A through F from 

circumventing the ELGs by moving effluent discharges from one subcategory to 

another for disposal under less stringent requirements. 

Source: Development Document for Interim Final Effluent Limitations Guidelines and Proposed New Source 

Performance Standards for the Oil and Gas Extraction Point Source Category (U.S. EPA, 1976). 

a – No pollutants are regulated in Subparts F or G. 
Section 10 – Oil & Gas Extraction (40 CFR Part 435) 

10-4

10.2 Oil and Gas Category 2010 Screening-Level Review

Table 10-5 compares the screening-level database results for the Oil and Gas Category 

from the 2006 through 2010 annual reviews. The combined DMR and TRI TWPE increased 

from discharge years 2007 to 2008. The estimated 2008 DMR TWPE dominates the estimated 

2008 category TWPE because no facilities reported water discharges to TRI in 2008, similar to 

2007. 

Table 10-5. Oil and Gas Category TRI and DMR Discharges for the 2006 through 2010 

Screening-Level Reviews 

Year of Discharge Year of Review 

Oil and Gas Category 

TRI TWPE DMR TWPE a Total TWPE 

2002 2006 700 1.18 701 

2004 2007 596 17.8 614 

2005 2008 802 NA NA 

2007 2009 NR 255 255 

2008 2010 NR 189,000 189,000 

Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; 

TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; and DMRLoads2008_v2. 

a – DMR data from 2002 through 2007 include only major dischargers. DMR 2008 data include both minor and 

major dischargers. 

NA – Not applicable. EPA did not evaluate DMR data for 2005. 

NR – Not Reported. No facilities reported water discharges to TRI for reporting years 2007 and 2008. 

Table 10-6 presents the 2008 DMR TWPE by facility discharge classification. EPA 

excluded minor dischargers from previous annual reviews, but included them in the 2010 annual 

review. The majority (over 99 percent) of the TWPE in the 2008 DMR database results from 

minor dischargers. 

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

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers 

2008 189,000 36.1 

Source: DMRLoads2008_v2. 

a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous 

annual reviews. 

10.3 Oil and Gas Pollutants of Concern

Table 10-7 lists the five pollutants with the highest TWPE in DMR data from reporting 

years 2008, 2007, and 2004 (DMRLoads2008_v2, DMRLoads2007_v3, and PCSLoads2004_v4). 

EPA is not presenting the top pollutants for the TRI databases because no facilities reported 

water discharges to TRI in 2007 or 2008. 
Section 10 – Oil & Gas Extr

10-5

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

Pollutant 

2004 DMR Database a 2007 DMR Database a 2008 D

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

N

R

P

Sulfide 

Pollutants not reported in the top five 2004 

DMR reported pollutants. 

Pollutants not reported in the top five 

2007 DMR reported pollutants. 

1 

Aluminum 2 Chloride 3 Fluoride 4 Cyanide 5 Arsenic 1 1 86.2 

Pollutants not 

2008 DMR 

Lead 4 1 0.073 2 4 60.8 Copper 5 1 0.069 3 3 49.0 Silver 

Pollutant not reported in the top five 2004 

DMR reported pollutants. 4 1 31.7 

Chlorine 1 1 11.2 5 1 24.6 Zinc 2 1 4.91 Pollutants not reported in the top five Sulfide 3 1 1.61 2007 DMR reported pollutants. Oil and Gas Category Total NA 2 c 17.8 NA 5 c 256 NA 

Source: PCSLoads2004_v4; DMRLoads2007_v3; and DMRLoads2008_v2. 

a – 2004 and 2007 DMR data include only major dischargers. b – 2008 DMR data include major and minor dischargers. c – Number of facilities reporting TWPE greater than zero. NA – Not applicable.
Section 10 – Oil & Gas Extraction (40 CFR Part 435) 

10-6

Sulfide is the top DMR-reported pollutant in 2008, contributing approximately 90 percent 

of the total category TWPE for 2008. EPA’s additional review for sulfide is presented in the 

following subsection. EPA did not investigate the other top pollutants as part of the 2010 annual 

review because the remaining TWPE is such a small percentage (10 percent) of the 2008 Oil and 

Gas Category combined DMR and TRI TWPE. 

10.4 Oil and Gas Category Sulfide Discharges in DMR

The 2010 annual review of the Oil and Gas Category focused on sulfide discharges in the 

2008 DMR database. Table 10-8 presents the three facilities that report sulfide discharges in the 

2008 DMR database. The majority (99 percent) of the sulfide discharges in 2008 were from 

Marathon Oil Maverick Springs in Fremont County, WY. EPA did not review discharges from 

the other two facilities because they account for only 1 percent of the remaining 2008 Oil and 

Gas Category’s sulfide TWPE. 

Sulfide may be generated during the stripping process to remove hydrogen sulfide (H2S), 

which can be naturally occurring in small amounts in crude petroleum. These trace amounts can 

make the petroleum extremely toxic and corrosive, which is referred to as “sour crude”. The sour 

crude must be “sweetened” to protect personnel, mitigate corrosion, and meet sale specifications 

(Manning and Thompson, 1995). 

Removing the H2S is usually achieved by stripping with cold or hot natural gas. Because 

the H2S is volatile, the compound accompanies the vapor in a gas-oil separation. Due to the 

extremely toxic characteristics of H2S, the resulting overhead gas cannot be vented. Therefore, 

water is usually used to strip the gas of H2S. This process will produce sour water. In water, H2S 

can form a weak acid made of two ions HS– and S2- (Manning and Thompson, 1995). This 

stripping process could result in the discharge of sulfide from this facility. 

Table 10-8. Oil and Gas Category Top Sulfide Discharging Facilities in the 2008 DMR 

Database 

Facility Name Facility Location 

2008 

Pounds of Sulfide 

Discharged 

Sulfide 

TWPE 

Percentage of Oil and 

Gas Category Sulfide 

2008 DMR TWPE 

Marathon Oil Maverick 

Springs 

Fremont County, 

WY 60,600 169,800 99% 

Soap Creek Oil Field St. Xavier, MT 107 300 < 1% 

Petro Gas Liquids Processing Corpus Chrisi, TX 5.79 16 < 1% 

Total 60,700 170,000 100% 

Source: DMRLoads2008_v2. 

Marathon Oil Maverick Springs 

The Marathon Oil Maverick Springs facility, located in Fremont County, WY, is a crudeoil refiner. The facility is within the exterior boundaries of the Wind River Indian Reservation. 

The facility fact sheet indicates that the limits were developed based on Subparts C and E of the 

Oil and Gas Category (WDEQ, 2007b). Table 10-9 presents the sulfide concentration data for 

Marathon Oil Maverick Springs. 
Section 10 – Oil & Gas Extraction (40 CFR Part 435) 

10-7

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

Outfall 

Monitoring Period 

Date NODI Code a

Maximum 

Concentration (mg/L) Flow (MGD) 

001 30-June-07 C NR 

001 31-Dec-07 9.76 1.645 

001 30-June-08 C 1.633 

001 31-Dec-08 24 1.645 

001 30-June-09 25 1.598 

001 31-Dec-09 8 1.576 

Note: The 2007 and 2009 discharge data are from EPA’s Envirofacts. 

NR – Flow not reported 

a – No discharge occurred for the monitoring period 

ERG contacted Marathon Oil Maverick Springs to verify the sulfide discharges for 2008. 

Marathon Oil Maverick Springs confirmed the 2008 sulfide concentrations and flows for outfall 

001, a stormwater discharge from the facility. Marathon Oil Maverick Springs also confirmed 

that the permit does not specify a limit for sulfide (Taylor, 2010). 

According to the 2007 Statement of Basis, the Marathon Oil Maverick Springs’ permit 

authorizes the discharge of treated wastewater at the oil production facility. Produced oil, water, 

and gas are separated in tanks by gravity, heat, and emulsion breaking chemicals. Water is 

discharged through settling ponds where the remaining oil is removed by floatation and 

skimming prior to discharge to a tributary to Five Mile Creek. The discharge provides wildlife 

and stock watering opportunities. In addition, aquatic communities have developed in this 

ephemeral drainage, which are dependent upon the flow of this produced water (WDEQ, 2007a). 

The effluent guidelines and the facility permit do not list sulfide as a regulated pollutant. 

However, the permit includes effluent monitoring requirements for sulfide. Sulfide is required to 

be monitored semi-annually. 

10.5 Oil and Gas Category Conclusions

The estimated toxicity of the Oil and Gas Category discharges results mainly from the 

sulfide discharges of one oil extraction plant (accounting for 99 percent of the category’s 2008 

TWPE). EPA does not believe that Marathon Oil’s sulfide discharges are representative of the 

Oil and Category. Without Marathon Oil’s sulfide discharges, the Oil and Gas TWPE is not a 

concern. Therefore, EPA concludes the following: 

• The sulfide discharges in the 2008 DMR database for Marathon Oil Maverick 

Springs were verified and do not appear to be erroneous. This facility’s sulfide 

discharges are not consistent with sulfide discharges from other facilities in the 

category. As a result, Marathon Oil’s sulfide discharges are best controlled by its 

individual permit. 

EPA prioritizes point source categories with existing regulations for potential revision 

based on the greatest estimated toxicity to human health and the environment, measured as 

TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for 

revision (i.e., this category is marked with “(2)” in the “Findings” column in Table V-1 in the 

Federal Register notice that presents the 2010 annual review of existing ELGs). 
Section 10 – Oil & Gas Extraction (40 CFR Part 435) 

10-8

10.6 Oil and Gas Category References

1. Manning, Francis and Thompson, Richard 1995. Oilfield Processing of Petroleum: Crude 

Oil. Penn Well Publishing Company. EPA-HQ-OW-2008-0517 DCN 07310. 

2. Taylor, Linda. 2010. Telephone conversation with Linda Taylor, Marathon Oil Maverick 

Springs, and Elizabeth Sabol, Eastern Research Group, Inc. “Sulfide Discharges Reported 

to DMR in 2008.” (June 3). EPA-HQ-OW-2008-0517 DCN 07307. 

3. WDEQ. 2007a. Wyoming Department of Environmental Quality. State of Wyoming 

National Pollutant Discharge Elimination System Permit NPDES WY0000779 – 

Marathon Oil Maverick Springs. Fremont County, WY. (November) EPA-HQ-OW2008-0517 DCN 07291. 

4. WDEQ. 2007b. Wyoming Department of Environmental Quality. State of Wyoming 

National Pollutant Discharge Elimination System Statement of Basis NPDES 

WY0000779 – Marathon Oil Maverick Springs. Fremont County, WY. (June) EPA-HQOW-2008-0517 DCN 07292. 

5. U.S. Census. 2002. U.S. Economic Census. Available online at: 

http://www.census.gov/econ/census02. 

6. U.S. EPA. 1976. Development Document for Interim Final Effluent Limitations 

Guidelines and Proposed New Source Performance Standards for the Oil and Gas 

Extraction Point Source Category. EPA-440/1-76-055-a. Washington, DC. (September). 

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

Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782. 
Section 11 – Ore Mining and Dressing (40 CFR Part 440) 

11-1

11. ORE MINING AND DRESSING (40 CFR PART 440) 

As discussed in the 2008 Final Plan, EPA conducted a preliminary study of facilities 

covered under 40 CFR Part 440, the Ore Mining and Dressing (Ore Mining) Category to 

examine why toxic-weighted pollutant discharges by the ore mining industry ranked relatively 

high compared to other industries in the 2002 through 2008 annual reviews. The purpose of the 

study was to identify, collect, and review readily available existing data and information on toxic

pollutants in wastewater discharges to determine whether additional analysis or revision of 40 

CFR Part 440 might be warranted to better control toxic discharges. 

The preliminary study focused on active ore mines covered under 40 CFR Part 440 

Subpart J: Copper, Lead, Zinc, Gold, Silver, and Molybdenum Ores. These types of mines 

comprise approximately 76 percent (263 ore mines) of the approximately 345 ore mines in the 

United States. Inactive ore mines were not included as they are not covered by the effluent 

guidelines. 

Approximately 294 ore mines currently have National Pollutant Discharge Elimination 

System (NPDES) wastewater discharge permits. There is a difference between the total number 

of ore mines and the number with NPDES permits because not all ore mines have wastewater 

discharges. The approximately 1,870 placer mines, covered under 40 CFR Part 440 Subpart M, 

were not examined in this study because they employ mining practices and wastewater streams 

that are fundamentally different from mines covered under the other subparts of 40 CFR Part 

440. 

The preliminary study examined information pertaining to the two types of wastewater 

discharged by ore mines: process wastewater (including mine drainage) and stormwater. Process 

wastewater is covered under 40 CFR Part 440. Stormwater is not covered under 40 CFR Part 440 

unless it is commingled with process wastewater prior to discharge to a surface waterbody. 

The study was limited by incomplete national-level process wastewater discharge data, 

and the lack of any nationally representative stormwater data for the ore mines of interest. EPA 

did review available ore mine-specific process wastewater discharge information, available Total 

Maximum Daily Load (TMDL) reports, information for ore mine site stormwater discharges, and 

an industrial wastewater treatment technology, known as high density sludge recycling, which 

was identified during the course of the study. 

Based on EPA’s review of toxic pollutant data, EPA found that in 2007, the most recent 

year for which quality-checked data are available, approximately only two percent of ore mining 

facilities were responsible for approximately 90 percent of toxic weighted discharges by the ore 

mining industry for toxic pollutants.

Given that only a small percentage of active ore mines account for the majority of toxic 

weighted discharges, this can best be addressed through permitting, compliance, and 

enforcement activities for the specific ore mining sources, rather than by revision of 40 CFR Part 

440. 

While the available toxic pollutant data does not suggest that EPA revisit the ELGs for 

ore mining and dressing (40 CFR Part 440) at this time, the Agency currently remains concerned 

about many other types of mining-related water quality impairments. EPA has a number of 
Section 11 – Ore Mining and Dressing (40 CFR Part 440) 

11-2

activities that address discharges of pollutants from mines including: guidance on protective 

levels of conductivity for aquatic life in streams affected by mine discharges; plans to revise the 

water quality criteria for selenium; increased attention on compliance with, and enforcement of, 

individual permit limits; improved permitting guidance; and more stringent discharge monitoring 

requirements in permits. 

The Ore Mining Preliminary Study Report (U.S. EPA, 2010) is being issued concurrent 

with the publication of the final 2010 Plan. 

11.1 Ore Mining and Dressing Category References

1. U.S. EPA. 2010. Ore Mining and Dressing Preliminary Study Report. EPA-821-R-08-

012. Washington, DC. (December). EPA-HQ-OW-2008-0517 DCN 07369.
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-1

12. ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC FIBERS (40 CFR PART 414) 

EPA selected the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Category 

for preliminary review because it continues to rank high, in terms of toxic-weighted pound 

equivalent (TWPE), in point source category rankings (see Table 5-3 for the point source 

category rankings). This industry was reviewed previously in each of EPA’s Preliminary and 

Final Effluent Guidelines Program Plans from 2004 to 2009 (U.S. EPA, 2004; U.S. EPA, 2005a; 

U.S. EPA, 2006; U.S. EPA, 2007; U.S. EPA, 2008, U.S. EPA, 2009). This section summarizes 

the results of the 2010 annual review associated with the OCPSF Category. EPA focused on 

discharges of hexachlorobenzene, metals, chlorine, and polycyclic aromatic compounds (PACs), 

because of their high TWPE relative to other pollutants in the OCPSF Category. 

EPA is currently reviewing discharges from the Chlorinated Hydrocarbon Manufacturing 

Segment of the OCPSF Category as part of the Chlorine and Chlorinated Hydrocarbons (CCH) 

effluent guidelines rulemaking. Because a rulemaking for this segment of the OCPSF Category is 

underway, EPA excluded discharges from these facilities from further consideration in this 

review (see Table V-1, 70 FR 61335, October 30, 2007). 

12.1 OCPSF Category Background

This subsection provides the background on the OCPSF Category including a brief 

profile of the OCPSF industry and background on 40 CFR Part 414. 

12.1.1 OCPSF Industry Profile 

The OCPSF industry includes many chemical industries producing a wide variety of end 

products, such as polypropylene, vinyl chloride and polyvinyl chloride (PVC), chlorinated 

solvents, rubber precursors, styrofoam additives, and polyester. Some OCPSF facilities are 

extremely complex and produce hundreds of chemicals, while others are simpler, producing one 

or two end products. EPA considered the following 22 North American Industry Classification 

System (NAICS) codes as part of the OCPSF Category: 

• 311999OCPSF: All Other Miscellaneous Food Manufacturing; 

• 324199OCPSF: All Other Petroleum and Coal Products Manufacturing; 

• 325110: Petrochemical Manufacturing; 

• 325120OCPSF: Industrial Gas Manufacturing; 

• 325132: Synthetic Organic Dye and Pigment Manufacturing; 

• 325188OCPSF: All Other Basic Inorganic Chemical Manufacturing; 

• 325192: Cyclic Crude and Intermediate Manufacturing; 

• 325193: Ethyl Alcohol Manufacturing; 

• 325199: All Other Basic Organic Chemical Manufacturing; 

• 325211: Plastics Material and Resin Manufacturing; 

• 325221: Cellulosic Organic Fiber Manufacturing; 

• 325222: Noncellulosic Organic Fiber Manufacturing; 

• 325510OCPSF: Paint and Coating Manufacturing; 

• 325520: Adhesive Manufacturing; 

• 325611OCPSF: Soap and Other Detergent Manufacturing; 

• 325612: Polish and Other Sanitation Good Manufacturing; 

• 325620: Toilet Preparation Manufacturing; 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-2

• 325998: All Other Miscellaneous Chemical Product and Preparation 

Manufacturing; 

• 326199OCPSF: All Other Plastics Product Manufacturing; 

• 339999OCPSF: All Other Miscellaneous Manufacturing; 

• 424690: Other Chemical and Allied Products Merchant Wholesalers; and 

• 562920: Materials Recovery Facilities. 

Wastewater generated by facilities in NAICS codes 311999, 324199, 325120, 325188, 

325510, 325611, 326199, 339999 may be regulated under multiple categories. For example, 

most facilities in NAICS code 324199 are grouped under the Petroleum Refining Effluent 

Limitation Guidelines and Standards (ELGs). EPA reviewed available information about 

pollutant loads and manufacturing operations for facilities reporting these NAICS codes. EPA 

assigned the extension “OCPSF” to the end of the NAICS codes of facilities that most likely fall 

under the applicability of the OCPSF ELGs (40 CFR Part 414). 

This list of Standard Industrial Classification (SIC) codes includes facilities that EPA 

determined are potential new subcategories of the OCPSF Category. As part of the 2004 annual 

review, EPA reviewed industries with SIC codes not clearly subject to existing ELGs. EPA 

concluded that the processes, operations, wastewaters, and pollutants of facilities in the eight SIC 

codes are similar to those of the OCPSF Category (U.S. EPA, 2004):18

• 2821: Plastics Materials, Synthetic and Resins, and Nonvulcanizable Elastomers; 

• 2824: Manmade Organic Fibers, Except Cellulosic; 

• 2842: Specialty Cleaning, Polishing, and Sanitation Preparations; 

• 2844: Perfumes, Cosmetics, and Other Toilet Preparations (except toothpaste, gel, 

and dentifrice powders); 

• 2869: Industrial Organic Chemicals, NEC (cyclopropane, diethylcyclohexane, 

naphthalene sulfonic acid); 

• 2891: Adhesives and Sealants; 

• 2899: Chemicals and Chemical Preparations, NEC (table salt); and 

• 5169: Chemicals and Allied Products, NEC (merchant wholesalers). 

As part of the 2009 annual review, EPA reclassified these SIC codes as equivalent NAICS codes 

for use with the U.S. Economic Census and Toxics Release Inventory (TRI) data that are 

reported by NAICS code (U.S. EPA, 2009). However, there is not a direct relationship between 

one SIC and one NAICS code. As a result, EPA included the following NAICS codes in the 

2010 annual review of the OCPSF Category because they contain facilities with operations that 

are similar to the SIC codes above: 

• 311999OCPSF: All Other Miscellaneous Food Manufacturing; 

• 325188OCPSF: All Other Basic Inorganic Chemical Manufacturing; 

• 325199: All Other Basic Organic Chemical Manufacturing; 

• 325222: Noncellulosic Organic Fiber Manufacturing; 

 

18 The tables in this section include discharge information from facilities reporting these SIC codes and the 

corresponding NAICS codes; however, these facilities contribute negligible amounts of TWPE. Consistent with the 

conclusions drawn during the 2004 detailed study (U.S. EPA, 2004) and 2006 review (U.S. EPA, 2006), EPA found 

that large numbers of these facilities discharge no wastewater and only a small number of facilities discharge TWPE 

greater than zero. 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-3

• 325510OCPSF: Paint and Coating Manufacturing; 

• 325520: Adhesive Manufacturing; 

• 325611OCPSF: Soap and Other Detergent Manufacturing; 

• 325620: Toilet Preparation Manufacturing; 

• 325998: All Other Miscellaneous Chemical Product and Preparation 

Manufacturing; 

• 326199OCPSF: All Other Plastics Product Manufacturing; 

• 339999OCPSF: All Other Miscellaneous Manufacturing; and 

• 424690: Other Chemical and Allied Products Merchant Wholesalers. 

Because the Permit Compliance System (PCS) and Integrated Compliance Information 

System – National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the 

sources of the discharge monitoring report (DMR) data used to develop DMRLoads2008, report 

facilities by SIC code and the U.S. Economic Census and TRI report data by NAICS code, EPA 

reclassified the 2008 DMR data by the equivalent NAICS code. Table 12-1 lists the number of 

facilities from the U.S. Economic Census and the screening-level databases for the 22 NAICS 

codes with operations in the OCPSF Category the corresponding SIC codes are included for 

reference. The U.S. Economic Census includes more facilities than the screening-level databases 

because of many possible factors including: facilities may not meet TRI-reporting thresholds, 

facilities may discharge to a publicly owned treatment works (POTW), and some facilities in the 

U.S. Economic Census are distributors or sales facilities, not manufacturers. 

Table 12-1. Number of OCPSF Facilities 

NAICS Code SIC Code 

Number of Facilities 

2002 U.S. 

Economic 

Census 

2008 DMR 

Database a

2008 TRI 

Database b

311999OCPSF: All Other Miscellaneous Food 

Manufacturing 

2821:Plastics Materials, 

Synthetic and Resins, 

and Nonvulcanizable 

Elastomers 

2824:Manmade Organic 

Fibers, Except 

Cellulosic 

2842: Specialty 

Cleaning, Polishing, 

and Sanitation 

Preparations 

2844: Perfumes, 

Cosmetics, and Other 

Toilet Preparations 

(toothpaste, gel, and 

dentifrice powders) 

2865: Cyclic Organic 

Crudes and 

Intermediates and 

Organic Dyes and 

Pigments (except 

aromatics and organic 

NA 

929 

2 

324199OCPSF: All Other Petroleum and Coal 

Products Manufacturing NA 1 

325110: Petrochemical Manufacturing 56 67 

325120OCPSF: Industrial Gas Manufacturing NA 2 

325132: Synthetic Organic Dye and Pigment 

Manufacturing 123 32 

325188OCPSF: All Other Basic Inorganic 

Chemical Manufacturing NA 1 

325192: Cyclic Crude and Intermediate 

Manufacturing 37 20 

325193: Ethyl Alcohol Manufacturing 72 153 

325199: All Other Basic Organic Chemical 

Manufacturing 685 379 

325211: Plastics Material and Resin 

Manufacturing 690 348 

325222: Noncellulosic Organic Fiber 

Manufacturing 95 25 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-4

Table 12-1. Number of OCPSF Facilities 

NAICS Code SIC Code 

Number of Facilities 

2002 U.S. 

Economic 

Census 

2008 DMR 

Database a

2008 TRI 

Database b

325510OCPSF: Paint and Coating 

Manufacturing 

dyes and pigments) 

2869: Industrial 

Organic Chemicals, 

NEC (fluorocarbon 

gases); 

891: Adhesives and 

Sealants 

2899: Chemicals and 

Chemical Preparations, 

NEC (table salt) 

NA 7 

325520: Adhesive Manufacturing 595 151 

325611OCPSF: Soap and Other Detergent 

Manufacturing NA 12 

325612: Polish and Other Sanitation Good 

Manufacturing 604 84 

325620: Toilet Preparation Manufacturing 867 26 

325998: All Other Miscellaneous Chemical 

Product and Preparation Manufacturing 1,188 311 

326199OCPSF: All Other Plastics Product 

Manufacturing NA 3 

339999OCPSF: All Other Miscellaneous 

Manufacturing NA 2 

562920: Materials Recovery Facilities 947 32 

424690: Other Chemical and Allied Products 

Merchant Wholesalers 

5169: Chemicals and 

Allied Products, NEC 

(merchant wholesalers) 11,158 94 443 

325221: Cellulosic Organic Fiber Manufacturing

2823: Cellulosic 

Manmade Fibers 8 4 4 

Total > 17,125 1,027 2,105 

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); TRIReleases2007_v2; and DMRLoads2007_v2. 

a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an NAICS to SIC 

crosswalk for comparison purposes. 

b – Releases to any media. 

NA – Not applicable. 

Table 9-2 shows whether permitting authorities designated direct dischargers as minor or 

major (see Section 4.1.5) for facilities in the OCSPF Category. EPA included data for minor 

dischargers for the first time in the 2010 annual review, as part of DMRLoads2008_v2 database. 

EPA does not require permitting authorities to submit DMR data for minor dischargers; however, 

many states do provide complete DMR data for them. From this year’s review, EPA observed 

many data entry or other errors for minor dischargers in addition to those previously identified 

for major dischargers, as discussed in Section 4.3. Table 12-2 shows that approximately 78 

percent of the OCPSF Category dischargers in the 2008 DMR database are minor dischargers. 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-5

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

Database 

NAICS Code a

Number of Facilities in 2008 DMR 

Major 

Dischargers 

Minor 

Dischargers 

All 

Dischargers 

311999OCPSF All Other Miscellaneous Food Manufacturing 

219 710 929 

324199OCPSF All Other Petroleum and Coal Products 

Manufacturing 

325110 Petrochemical Manufacturing 

325120OCPSF Industrial Gas Manufacturing 

325132 Synthetic Organic Dye and Pigment Manufacturing 

325188OCPSF All Other Basic Inorganic Chemical 

Manufacturing 

325192 Cyclic Crude and Intermediate Manufacturing 

325193 Ethyl Alcohol Manufacturing 

325199 All Other Basic Organic Chemical Manufacturing 

325211 Plastics Material and Resin Manufacturing 

325222 Noncellulosic Organic Fiber Manufacturing 

325510OCPSF Paint and Coating Manufacturing 

325520 Adhesive Manufacturing 

325611OCPSF Soap and Other Detergent Manufacturing 

325612 Polish and Other Sanitation Good Manufacturing 

325620 Toilet Preparation Manufacturing 

325998 All Other Miscellaneous Chemical Product and 

Preparation Manufacturing 

326199OCPSF All Other Plastics Product Manufacturing 

339999OCPSF All Other Miscellaneous Manufacturing 

562920 Materials Recovery Facilities 

424690 Other Chemical and Allied Products Merchant 

Wholesalers 2 92 94 

325221 Cellulosic Organic Fiber Manufacturing 2 2 4 

Total 223 804 1,027 

Source: DMRLoads2008_v2. 

a – DMR data is reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison 

purposes. 

Table 12-3 presents the type of discharges reported by facilities in the 2008 TRI database. 

The majority of OCPSF facilities reporting to TRI do not report water discharges, but those that 

do mostly reported discharging indirectly. 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-6

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

 NAICS Code 

Number of Facilities in TRI 2008 Database 

Direct 

Dischargers 

Only 

Indirect 

Dischargers 

Only 

Both Indirect 

and Direct 

No Water 

Discharges 

311999OCPSF: All Other Miscellaneous Food 

Manufacturing 0 2 0 0 

324199OCPSF: All Other Petroleum and Coal 

Products Manufacturing 0 0 1 0 

325110: Petrochemical Manufacturing 30 15 1 21 

325120OCPSF: Industrial Gas Manufacturing 1 0 0 1 

325132: Synthetic Organic Dye and Pigment 

Manufacturing 3 18 0 11 

325188OCPSF: All Other Basic Inorganic 

Chemical Manufacturing 0 1 0 0 

325192: Cyclic Crude and Intermediate 

Manufacturing 9 4 2 5 

325193: Ethyl Alcohol Manufacturing 4 6 1 142 

325199: All Other Basic Organic Chemical 

Manufacturing 73 126 17 163 

325211: Plastics Material and Resin 

Manufacturing 61 80 23 184 

325222: Noncellulosic Organic Fiber 

Manufacturing 6 9 0 10 

325510OCPSF: Paint and Coating Manufacturing 0 6 1 0 

325520: Adhesive Manufacturing 4 20 0 127 

325611OCPSF: Soap and Other Detergent 

Manufacturing 0 11 0 1 

325612: Polish and Other Sanitation Good 

Manufacturing 1 20 0 63 

325620: Toilet Preparation Manufacturing 0 14 1 11 

325998: All Other Miscellaneous Chemical 

Product and Preparation Manufacturing 14 48 6 243 

326199OCPSF: All Other Plastics Product 

Manufacturing 0 2 1 0 

339999OCPSF: All Other Miscellaneous 

Manufacturing 0 0 1 1 

562920: Materials Recovery Facilities 0 1 0 31 

424690: Other Chemical and Allied Products 

Merchant Wholesalers 6 27 0 410 

325221: Cellulosic Organic Fiber Manufacturing 2 0 0 2 

Total 214 410 55 1,426 

Source: TRIReleases2008_v3. 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-7

12.1.2 40 CFR Part 414 

EPA first promulgated ELGs for the OCPSF Category (40 CFR Part 414) on 

November 5, 1987 (52 FR 42568). This category consists of seven subcategories that apply to 

the manufacture of products and product groups, as shown in Table 12-4 with corresponding SIC 

codes and applicability. Subparts B through H have limitations for biochemical oxygen demand 

(BOD5), total suspended solids (TSS), and pH. The regulation also includes limitations and/or 

pretreatment standards for certain toxic pollutants in three additional subparts: 

• Subpart I — Direct Discharge Point Sources That Use End-of-Pipe Biological 

Treatment; 

• Subpart J — Direct Discharge Point Sources That Do Not Use End-of-Pipe 

Biological Treatment; and 

• Subpart K — Indirect Discharge Point Sources. 

Table 12-4. Applicability of Subcategories in the OCPSF Category 

Subpart Subcategory Title Corresponding SIC Code(s) a Subcategory Applicability 

B Rayon Fibers 2823: Cellulosic Manmade Fibers Cellulosic manmade fiber (Rayon) 

manufactured by the Viscose process.

C Other Fibers 2824: Synthetic Organic Fibers, 

Except Cellulosic 

All other synthetic fibers (except 

Rayon) including, but not limited to, 

products listed in Section 414.30. 

D Thermoplastic Resins 28213: Thermoplastic Resins Any plastic product classified as a 

thermoplastic resin including, but not 

limited to, products listed in Section 

414.40. 

E Thermosetting Resins 28214: Thermosetting Resins Any plastic product classified as a 

thermosetting resin including, but not 

limited to, products listed in Section 

414.50. 

F Commodity Organic 

Chemicals 

2865: Cyclic Crudes and 

Intermediates, Dyes and Organic 

Pigments 

2869: Industrial Organic 

Chemicals, NEC 

Commodity organic chemicals and 

commodity organic chemical groups 

including, but not limited to, products 

listed in Section 414.60. 

G Bulk Organic 

Chemicals 

2865: Cyclic Crudes and 

Intermediates, Dyes and Organic 

Pigments 

2869: Industrial Organic 

Chemicals, NEC 

Bulk organic chemicals and bulk 

organic chemical groups including, 

but not limited to, products listed in 

Section 414.70. 

H Specialty Organic 

Chemicals 

2865: Cyclic Crudes and 

Intermediates, Dyes and Organic 

Pigments 

2869: Industrial Organic 

Chemicals, NEC 

All other organic chemicals and 

organic chemical groups including, 

but not limited to, products listed in 

the OCPSF Development Document 

(Vol. II, Appendix II-A, Table VII). 

Source: Product and Product Group Discharges Subject to Effluent Limitations and Standards for the Organic 

Chemicals, Plastics, and Synthetic Fibers Point Source Category — 40 CFR 414, Table 2-2 (U.S. EPA, 2005b). 

a – During the 2009 annual review EPA developed a crosswalk between SIC codes and NAICS codes. Because there 

is not a direct match EPA did not report NAICS codes. 

NEC – Not elsewhere classified. 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-8

12.2 OCPSF Category 2010 Screening-Level Review

Table 12-5 compares the screening-level database results for the OCPSF Category from 

the 2006 through 2010 annual reviews. The combined DMR and TRI TWPE increased from 

discharge years 2002 to 2004, but decreased from discharge years 2004 to 2008. The 2008 DMR 

TWPE accounts for approximately 79 percent of the combined 2008 DMR and TRI TWPE, 

while TRI discharges dominated previous years’ combined TWPE. 

Table 12-5. OCPSF Category TRI and DMR Discharges for the 2006 through 2010 

Screening-Level Reviews 

Year of Discharge Year of Review 

OCPSF Category 

TRI TWPE DMR TWPE a Total TWPE 

2002 2006 349,000 398,000 747,000 

2004 2007 957,000 608,000 1,570,000 

2005 2008 759,000 NA NA 

2007 2009 575,000 309,000 884,000 

2008 2010 137,000 512,000 649,000 

Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; 

TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; and DMRLoads2008_v2. 

a – DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and 

major dischargers. 

NA – Not applicable. EPA did not evaluate DMR data for 2005. 

Table 12-6 presents the 2008 DMR TWPE by facility discharge classification. EPA 

excluded minor dischargers from previous annual reviews, but included them in the 2010 annual 

review. The majority (96 percent) of the TWPE in the 2008 DMR database results from major 

dischargers. 

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

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers 

2008 19,100 493,000 

Source: DMRLoads2008_v2. 

a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous 

annual reviews. 

12.3 OCPSF Pollutants of Concern

Table 12-7 compares the five chemicals with the highest TWPE in the 2008, 2007, and 

2004 TRI databases (TRIReleases2008_v3, TRIReleases2007_v2, and TRIReleases2004_ v3). 

Table 12-8 lists the five pollutants with the highest TWPE in the 2008, 2007, and 2004 DMR 

databases (DMRLoads2008_v2, DMRLoads2007_v3, and PCSLoads2004_v4).
Section 12 – Organic Chemicals, Plastics, and Synthetic F

12-9

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

Pollutant 

2004 TRI Data a 2007 TRI Data a 2008 

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Nu

F

R

P

Nitrate Compounds 5 130 16,200 

Pollutant not reported in the top five 2007 

TRI reported pollutants. 1 

Lead and Lead Compounds 

Pollutants not reported in the top five 

2004 TRI reported pollutants. 

5 55 16,500 2 

Copper and Copper Compounds Pollutants not reported in the top five 

2007 TRI reported pollutants. 

3 

Manganese and Manganese Compounds 4 Hydroquinone 4 6 17,100 3 4 18,500 5 Dioxin and Dioxin Like Compounds 1 8 693,000 1 4 398,000 

Pollutants not repo

TRI repo

Chlorine 3 15 22,900 2 13 27,500 PACs 

Pollutant not reported in the top five 

2004 TRI reported pollutants. 4 7 18,200 

Hexachlorobenzene 2 4 84,500 

Pollutant not reported in the top five 2007 

TRI reported pollutants. 

OCPSF Category Total NA 744 b 95,700 NA 594 b 57,500 NA 

Source: TRIReleases2004_v3; TRIReleases2007_v2; and TRIReleases2008_v3. 

a – Discharges include transfers to POTWs and account for POTW removals. b – Number of facilities reporting TWPE greater than zero. NA – Not applicable. 
Section 12 – Organic Chemicals, Plastics, and Synthetic F

12-10

Table 12-8. OCPSF Category Top DMR Pollutants 

Pollutant 

2004 DMR Data a 2007 DMR Data a 2008 D

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Nu

F

Re

Po

Hexachlorobenzene 2 13 123,000 1 13 62,700 1 Chlorine 4 46 38,200 2 46 45,600 2 Nickel 

Pollutants not reported in the top five 2004 

DMR reported pollutants. 

4 58 23,000 3 

Copper 

Pollutant not reported in the top five 2007 

DMR reported pollutants. 4 

Fluoride 5 12 28,200 3 13 35,500 5 Tin 

Pollutant not reported in the top five 2004 

DMR reported pollutants. 5 3 17,500 Pollutants not repo

Aluminum 1 20 209,000 Pollutant not reported in the top five 2007 DMR repBenzidine 3 1 63,800 DMR reported pollutants. OCPSF Category Total NA 202 c 608,000 NA 194 c 309,000 NA 

Source: PCSLoads2004_v4; DMRLoads2007_v3; and DMRLoads2008_v2. 

a – 2004 and 2007 DMR data include only major dischargers. b – 2008 DMR data includes major and minor dischargers. c – Number of facilities reporting TWPE greater than zero. NA – Not applicable.
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-11

The OCPSF 2008 TRI TWPE accounts for 21 percent of the total category TWPE, while 

the 2008 DMR TWPE accounts for 79 percent. Therefore, EPA focused the additional review on 

the DMR-reported pollutants that account for the majority of the category TWPE. 

EPA’s additional review for the 2008 DMR database pollutants of concern, 

hexachlorobenze, chlorine, and metals (nickel and copper), is presented in the following 

subsections. EPA also reviewed discharges of PACs19 as part of the 2010 annual review, even 

though they are not one of the top five pollutants for DMR in 2008. PACs discharges have been 

continually monitored by EPA as part of previous annual reviews. During the review of top 

pollutants, EPA discovered that the majority of the top pollutants were discharged from the same 

three facilities in the 2008 DMR database. Table 12-9 presents the facility dischargers and 

corresponding top DMR pollutants discharged in the OCSPF Category. 

Table 12-9. OCPSF Category Top Facility Dischargers in the DMR 2008 Database 

Top Pollutant Facility Name 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Total 

Facility 

TWPE 

Other Top 

Pollutants 

Discharged 

Hexachlorobenzene Chevron Oronite Co. 43.8 85,300 95,600 PACs 

Nickel MPM Silicones, LLC 571,000 57,100

102,000 

Hexachlorobenzene, 

PACs 

Copper MPM Silicones, LLC 36,600 23,100

Benzo(a)pyrene a E I DuPont De Nemours 196 19,700 44,900 Other PACs 

Source: DMRLoads2007_v3 and DMRLoads2008_v2. 

a – Benzo(a)pyrene is included in the group of pollutants referred to as PACs. 

12.4 OCPSF Category Top Facility Dischargers in DMR

The majority of the top pollutants for the OCSPF Category in the 2008 DMR database 

are discharged from the top three facility dischargers. This subsection provides further detail on 

the top three facility dischargers in the OCSPF Category responsible for the majority of the 

hexachlorobenzene, PACs, and metals TWPE. As a result of EPA’s review of discharges from 

the top facilities in the OCPSF Category, the overall category 2008 DMR TWPE decreased by 

239,000 TWPE. 

12.4.1 Chevron Oronite Co. LLC in Belle Chasse, LA20

Table 12-10 presents the top five discharges in the 2008 DMR database for Chevron 

Oronite Co. LLC. The majority of the facility TWPE (approximately 89 percent) is from 

hexachlorobenzene. Hexachlorobenzene discharges from Chevron Oronite also account for 

almost 17 percent of the total OCPSF Category TWPE in the 2008 DMR database. The other top 

 

19 PACs include the following pollutants: benzo(a)anthracene, chrysene, benzo(a) pyrene, benzo(b)fluoranthene, 

benzo(j)fluoranthene, benzo(k)fluoranthene, fluoranthene, benzo(r,s,t)pentaphene, dibenz(a,h)acridine, 

dibenz(a,j)acridine, dibenzo(a,h)anthracene, dibenzo(a,e)fluoranthene, dibenzo(a,e)pyrene, dibenzo(a,h)pyrene, 

dibenzo(a,l)pyrene, 7H-dibenzo(c,g)carbozole, 7,12-dimethylbenz(a)anthracene, 

indeno(1,2,3-cd)pyrene, 3-methylcholanthrene, 5-methylchrysene, and 1-nitropyrene. 

20 Chevron Oronite Co. LLC in Belle Chasse, LA has two NPIDs: LA0005738 and LAG670106. This section 

discusses the discharges associated with the NPID LA0005738. Discharges from LAG670106 are not included in 

the DMR Loadings Tool. 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-12

pollutants (all PACs) are benzo(a)pyrene, chrysene, benzo(a)anthracene, and 

benzo(b)fluoranthene. 

Table 12-10. Chevron Oronite 2008 Top Discharges 

Pollutant Total Pounds Total TWPE 

Percentage of Facility 

Total TWPE 

Hexachlorobenzene 43.8 85,300 89% 

Benzo(a)pyrene 43.8 4,410 4.6% 

Chrysene 43.8 1,360 1.4% 

Benzo(a)anthracene 43.8 1,340 1.4% 

Benzo(b)fluoranthene 43.8 1,340 1.4% 

Total 362,000 95,600 100% 

Source: DMRLoads2008_v2. 

All of the pollutant discharges for Chevron Oronite are from outfall 202. Table 12-11

presents the discharge data in the DMR Loadings Tool for 2008. EPA contacted Chevron 

Oronite to verify the hexachlorobenzene and PACs quantities. Chevron Oronite indicated that the 

hexachlorobenzene, benzo(a)pyrene, chrysene, benzo(a)anthracene, and benzo(b)fluoranthene 

concentrations were measured below the detection limit (BDL). Further, Chevron Oronite 

provided discharge monitoring data that showed all PAC concentrations in the 2008 DMR 

database were reported as nondetect (Sampey, 2010). 

Chevron Oronite indicated that they use half the detection limit to calculate the quantities 

when the pollutants are measured BDL (Sampey, 2010). Therefore, all of the quantities in the 

2008 DMR database were BDL and the loads and TWPE should be zero. This correction leads to 

the facility’s total TWPE decreased from 95,600 TWPE to 40 TWPE, a reduction of over 99 

percent. 

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

Outfall Pollutant 

Monitoring 

Period Date 

DMR Loadings 

Tool Quantity 

(kg/day) 

FacilityProvided 

Quantity 

(kg/day) Flow (MGD) 

202 Hexachlorobenzene 31-Dec-08 0.0544 <0.0544 1.132 

202 Benzo(a)pyrene 31-Dec-08 0.0544 <0.0544 1.132 

202 Chrysene 31-Dec-08 0.0544 <0.0544 1.132 

202 Benzo(a)anthracene 31-Dec-08 0.0544 <0.0544 1.132 

202 Benzo(b)fluoranthene 31-Dec-08 0.0544 <0.0544 1.132 

Source: DMR Loadings Tool and Facility Contact (Sampey, 2010). 

12.4.2 MPM Silicones, LLC in Friendly, WV 

Table 12-12 presents the top pollutant discharges in the 2008 DMR database for MPM 

Silicones, LLC. The majority of the TWPE results from discharge of nickel and copper. 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-13

Hexachlorobenzene and benzo(a)pyrene are the 3rd and 4th ranking pollutants, by TWPE, for the 

facility in the 2008 DMR database. 

Table 12-12. MPM Silicones 2008 Top Discharges 

Pollutant Total Pounds TWPE 

Percentage of Facility 

TWPE 

Nickel 571,000 57,100 56% 

Copper 36,600 23,100 23% 

Hexachlorobenzene 10 19,000 19% 

Benzo(a)pyrene 12 1,190 1.2% 

Total 10,400,000 102,000 100% 

Source: DMRLoads2008_v2. 

All of MPM Silicones’ top pollutant discharges are from outfall 001. Table 12-13

presents the discharge data in the DMR Loadings Tool for 2008. EPA contacted MPM Silicones 

to verify the values and units for the nickel, copper, hexachlorobenzene, and benzo(a)pyrene 

concentrations. MPM Silicones’ facility contact verified that the pollutant concentrations 

reported were either incorrect or missing the BDL indicators (i.e., “<”), and all concentrations 

should have been reported as μg/L, not mg/L. The facility contact also indicated that 

benzo(a)pyrene should have been reported annually; therefore, there should only be one reported 

concentration for December 2008. Table 12-13 also shows the facility-provided concentrations 

(Martin, 2010). 

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

Outfall 

Monitoring Period 

Date 

DMR Loadings Tool 

Average Concentration 

(mg/L) 

Facility-Corrected 

Average 

Concentration (mg/L) Average Flow (MGD)

Nickel 

001 31-Mar-08 22 0.022 5.71 

001 30-Jun-08 11 - a 5.4 

001 30-Sept-08 21 0.021 5.32 

001 31-Dec-08 83 0.083 5.43 

Copper 

001 31-Mar-08 3 < 0.006 5.71 

001 30-Jun-08 <0.5 - a 5.4 

001 30-Sept-08 <5 < 0.01 5.32 

001 31-Dec-08 3 < 0.006 5.43 

Hexachlorobenzene 

001 31-Mar-08 0.000395 < 0.00079 5.71 

001 30-Jun-08 0.000435 < 0.00075 5.4 

001 30-Sept-08 0.000435 < 0.00075 5.32 

001 31-Dec-08 0.00121 < 0.00024 5.43 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-14

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

Outfall 

Monitoring Period 

Date 

DMR Loadings Tool 

Average Concentration 

(mg/L) 

Facility-Corrected 

Average 

Concentration (mg/L) Average Flow (MGD)

Benzo(a)pyrene 

001 30-Sept-08 0.00095 NR b 5.32 

001 31-Oct-08 0.000705 NR b 5.39 

001 31-Dec-08 NR < 0.00141 b 5.43 

Source: DMR Loadings Tool and Facility Contact (Martin, 2010). 

a – Concentration not reported due to sampling error. 

b – The facility contact indicated that the benzo(a)pyrene concentration was be reported only once in December 

2008, not September or October 2008. 

NR – Concentration not reported. 

Using the facility-provided concentrations, EPA calculated the revised load and 

corresponding TWPE for the top pollutants. The facility’s copper, hexachlorobenzene, and 

benzo(a)pyrene loads were zeroed because all of the concentrations were measured below the 

detection limit. MPM Silicones’ nickel discharges decrease from 57,100 TWPE 39 TWPE, while 

the facility’s total TWPE decreased from 102,000 TWPE to 1,620 TWPE, a reduction of over 98 

percent. 

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

Table 12-14 presents the top discharges for E I DuPont de Nemours & Co. in the 2008 

DMR database. The majority of the facility TWPE (approximately 41 percent) is from 

benzo(a)pyrene. The other top pollutants reported are chrysene, benzo(a)anthracene, and 

benzo(k)fluoranthene, all PACs. 

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

Pollutant Total Pounds TWPE 

Percentage of Facility 

TWPE 

Benzo(a)pyrene 196 19,700 44% 

Chrysene 196 6,070 14% 

Benzo(a)anthracene 196 6,000 13% 

Benzo(k)fluoranthene 196 6,000 13% 

Total 7,250,000 44,900 100% 

Source: DMRLoads2008_v2. 

All of the PACs discharges are from outfalls 002 and 005. Table 12-15 presents the 

discharge data in the DMR Loadings Tool for 2008. EPA contacted the West Virginia 

Department of Environmental Protection (WV DEP) to verify the PACs concentrations. The WV 

DEP provided the DMRs and indicated that the all PACs discharges were below the detection 

limit in 2008 (Simmons, 2010). Therefore, the facility’s PACs loads and TWPE were set to zero. 

E I DuPont de Nemours’ TWPE decreased from 44,500 TWPE to 1,550 TWPE, a total reduction 

of 96 percent. 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-15

Table 12-15. E I DuPont de Nemours 2008 Monthly PACs Discharge Data 

Outfall Pollutant 

Monitoring 

Period Date 

DMR Loadings 

Tool 

Concentration 

(mg/L) 

WV DEPProvided 

Concentration 

(mg/L) Flow (MGD) 

005 Benzo(a)pyrene 31-Jul-08 0.0013 < 0.0013 52.1 

002 Benzo(a)pyrene 31-Jul-08 0.0013 < 0.0013 11.7 

005 Chrysene 31-Jul-08 0.0013 < 0.0013 52.1

005 Benzo(a)anthracene 31-Jul-08 0.0013 < 0.0013 52.1

005 Benzo(k)fluoranthene 31-Jul-08 0.0013 < 0.0013 52.1

Source: DMR Loadings Tool and Facility Contact (Simmons, 2010). 

12.5 OCPSF Category Chlorine Discharges in DMR

As part of the 2010 annual review of the OCSPF Category, EPA reviewed chlorine 

discharges in the 2008 DMR database. Approximately 15 percent of the OCPSF Category 3009 

DMR TWPE results from chlorine discharges. Table 12-16 presents the facilities in the 2008 

DMR database that discharge chlorine. Two facilities, Oxea Bay City Plant in Bay City, TX, and 

Channel View Complex in Channelview, TX, account for approximately 62 percent of the 

discharges in the 2008 DMR database. This subsection provides information on Oxea Bay City’s 

and Channelview’s chlorine discharges. 

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

Database 

Facility Name 

Major/Minor 

Discharger 

Pounds of Chlorine 

Discharged Chlorine TWPE 

Percentage of 

OCSPF Category 

Chlorine DMR 2008 

TWPE 

Oxea Bay City Plant Major 52,500 26,300 34% 

Channel View Complex Major 43,600 21,800 28% 

Pasadena Plastics Complex Major 12,900 6,450 8% 

Exxon Mobil Chemical Co. Major 7,600 3,800 5% 

Cytec Industries, Inc. Major 6,500 3,250 4% 

Remaining OCPSF Chlorine Dischargers a 32,400 16,200 21% 

Total 156,000 77,800 100% 

Source: DMRLoads2008_v2. 

a – There are 99 remaining OCPSF facilities with chlorine discharges in DMRLoads2008_v2 that account for about 

21 percent of the OCPSF Category’s 2008 chlorine TWPE in the DMR database. 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-16

12.5.1 Oxea Bay City Plant in Bay City, TX 

All of Oxea Bay City’s chlorine discharges are from outfall 001. Table 12-17 presents 

Oxea Bay City’s 2008 chlorine discharge data from DMR Loadings Tool for outfall 001. EPA 

confirmed these discharges with information from Envirofacts21. 

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

Monitoring Period Date 

DMR Loadings Tool Chlorine 

Concentration (mg/L) DMR Loadings Tool Flow (MGD)

31-Jan-08 45 1.004 

29-Feb-08 37.5 0.817

31-Mar-08 16.3 1.052

30-Apr-08 5.9 0.873

31-May-08 37.5 0.581

30-Jun-08 1.6 0.586

31-Jul-08 0.1 0.669

31-Aug-08 85 0.736

30-Sep-08 3 0.839

31-Oct-08 0.1 0.733

30-Nov-08 12 0.711

31-Dec-08 15 0.799

Source: DMR Loadings Tool. 

Oxea Bay City Plant discharges treated domestic wastewater and treated process 

wastewater from the neutral effluent treatment system, and treated utility wastewater, 

stormwater, groundwater recovered during site excavations, stormwater from the old dewatering 

area and from landfill cells, groundwater from the bailing of monitor wells, groundwater from 

recovery wells, and hydrostatic test discharge water via outfall 001 (TCEQ, 2009). 

EPA contacted Oxea Bay City Plant to confirm the chlorine discharges from outfall 001. 

The facility contact verified the chlorine concentrations and indicated that the location where 

chlorine is monitored is different than the location of the final outfall, where flow rate is 

measured. The chlorine is measured at a nearby sewage treatment facility, Honeyhoe. Oxea Bay 

indicated that effluent from Honeyhoe commingles with process wastewater in equalization 

tanks. The facility contact believed that a majority of the chlorine was removed by microbes in 

the equalization tanks. From the equalization tanks, flow is directed to the facility’s cooling pond 

and is re-circulated. The facility contact stated that the flow from the equalization tank is 

typically re-circulated through the cooling pond; however, the facility permit allows for effluent 

from the equalization tanks to be rerouted and discharged to outfall 001, if necessary. The 

facility contact also indicated that in 2008 the plant had issues with the analyzer that controls the 

chlorine feed, which they though may account for the higher chlorine concentrations (Martinez, 

2010). 

 

21 EPA uses the data in Envirofacts as a source while reviewing the DMR Loadings Tool data because Envirofacts 

continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not 

continuously updated; therefore, loads may be estimated with erroneous data.
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-17

Based on information from the facility contact, EPA believes that the DMR Loadings 

Tool is overestimating the chlorine discharges for Oxea Bay City Plant. The DMR Loadings 

Tool is using the chlorine that is measured at the effluent from Honeyhoe and the flow that is 

measured after the equalization tanks to calculate the chlorine load. EPA will continue to 

monitor the chlorine discharges from this facility. 

12.5.2 Channelview Complex Channelview, TX 

All of Channelview’s chlorine discharges are from outfall 001. Table 12-18 presents 

Channelview’s 2008 chlorine discharge data from the DMR Loadings Tool and Envirofacts for 

outfall 001. EPA compared data from the DMR Loadings Tool, Envirofacts, and the facility 

permit and found that the concentration reported in the 2008 DMR database is the maximum 

concentration. 

Table 12-18. Channelview Complex 2008 Monthly Chlorine and Flow Discharge Data and 

Maximum Chlorine Permit Limitations 

Monitoring Period 

Date 

DMR Loadings 

Tool Chlorine 

Concentration 

(mg/L)

EPA Envirofacts 

Minimum Chlorine 

Concentration 

(mg/L) 

EPA Envirofacts 

Maximum Chlorine 

Concentration 

(mg/L) 

Facility Maximum 

Chlorine Permit 

Limit (mg/L) 

31-Jan-08 NR 1.03 3.88 4 

29-Feb-08 3.89 1.17 3.89 4 

31-Mar-08 NR 1 31 4 

30-Apr-08 NR 1.2 3.9 4 

31-May-08 NR 1.43 3.9 4 

30-Jun-08 NR 1 3.98 4 

31-Jul-08 NR 1.12 3.93 4 

31-Aug-08 NR NR NR 4 

30-Sep-08 NR 1.24 3.94 4 

31-Oct-08 NR NR NR 4 

30-Nov-08 NR 1.2 NR 4 

31-Dec-08 NR 1.2 NR 4

Source: DMR Loadings Tool; Envirofacts; and TPDES Permit for Channelview TX0003531 (TCEQ, 2004). 

NR – Not reported. 

Outfall 001 at Channelview Complex discharges treated organic chemical manufacturing 

process wastewater, auto shop wastewater, laboratory wastewater, cooling tower blowdown, 

sanitary wastewater, loading area and process area washdown, tank farm wastewater, heat 

exchanger blasting slab waste, steam blowdown, demineralization regeneration blowdown, 

methanol neutralization sump wastewater, and process area stormwater runoff. The facility is 

required to treat domestic sewage (both primary and secondary) and chlorinate it sufficiently to 

maintain at least 1.0 mg/L and at most 4.0 mg/L residual chlorine after at least 20 minutes 

contact time (based on peak flow) prior to mixing with any other waters. The domestic sewage is 

required to be monitored five times per week, by grab sample. From the facility permit, all 

effluent monitoring samples, including flow rate, are taken where all effluents are commingled 

together prior to discharge. The facility is required to take the chlorine sample at the exit of the 

septic chlorinator prior to commingling with other wastewaters (TCEQ, 2004). 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-18

EPA contacted Channelview Complex to confirm the chlorine concentrations and flows 

for 2008. The facility contact stated that all of chlorine concentrations and flows were correct. 

The facility contact stated that the unusually high chlorine concentration measured during the 

March 2008 sampling episode was a result of a septic chlorinator malfunction. The facility 

contact also confirmed that the septic chlorinator, where chlorine is measured, is well upstream 

of where flow is measured and that no flow is measured at the septic chlorinator (Miller, 2010). 

Therefore, EPA believes that the DMR Loadings Tool is overestimating the chlorine discharges 

for 2008. EPA will continue to monitor the chlorine concentrations from this facility, but does 

not believe the estimated chlorine load accurately represents this facility’s discharge. 

12.6 OCPSF Category Conclusions

The estimated toxicity of the OCSPF Category discharges result from hexachlorobenze, 

metals, chlorine, and PACs discharges. Data collected for the 2010 annual review demonstrated 

that wastewater discharge characteristics for this category are consistent with discharges from 

prior years. As in prior years, EPA makes the following conclusions: 

• There were missing BDL indicators for hexachlorobenzene and PACs discharges 

from the Chevron Oronite facility in Belle Chasse, LA. These discharges were 

actually reported as nondetect, zeroing their load and TWPE. Correcting this error 

decreases the 2008 facility TWPE to 40 TWPE. 

• There were missing BDL indicators and a units error for the nickel, copper, 

hexachlorobenzene, and PAC discharges reported by MPM Silicones in Friendly, 

WV. Correcting these errors decreases the 2008 facility TWPE to 1,620 TWPE. 

• There were missing BDL indicators for the PAC discharges reported by EI 

DuPont de Nemours in Washington, WV. These discharges were actually reported 

nondetect, zeroing their load and TWPE. Correcting this error decreases the 2008 

facility TWPE to 1,550 TWPE. 

• The chlorine TWPE resulted from flow measurement location errors: two 

facilities measure chlorine at a separate location than flow. The flow 

measurements occur after the wastewater containing chlorine commingles with 

wastewater without chlorine. Therefore, the chlorine load does not accurately 

reflect the facility’s discharge. EPA will correct this error in the screening-level 

databases in future years of review and continue monitoring the chlorine 

discharges from OCSPF facilities. 

• Correcting the database errors identified during the 2010 annual review decreases 

the 2008 OCPSF Category TWPE from 649,000 TWPE to 410,000 TWPE. The 

OCSPF Category continues to rank high due to the high number of facilities (over 

2,000) in the industry. EPA will continue to monitor the OCSPF Category 

discharges to determine if they are properly controlled. 

EPA prioritizes point source categories with existing regulations for potential revision 

based on the greatest estimated toxicity to human health and the environment, measured as 

TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-19

revision (i.e., this category is marked with “(3)” in the “Findings” column in Table V-1 in the 

Federal Register notice that presents the 2010 annual review of existing ELGs). 

12.7 OCSPF Category References

1. Martin, Jason. 2010. Notes from Telephone Conversation between Jason Martin, MPM 

Silicones, LLC, and Elizabeth Sabol, Eastern Research Group, Inc. “RE: Discharges 

Reported to DMR in 2008.” (June 29). EPA-HQ-OW-2008-0517 DCN 07293. 

2. Martinez, Sylvia. 2010. Notes from Telephone Conversation between Sylvia Martinez, 

Oxea Bay City Plant, and Lauren Wingo, Eastern Research Group, Inc. “RE: Oxea Bay 

City Plant’s 2008 Chlorine and Flow Data in DMR Data.” (August 27). EPA-HQ-OW2008-0517 DCN 07294. 

3. Miller, Tommy. 2010. Notes from Telephone Conversation between Tommy Miller, 

Lyondell Bassel, and Lauren Wingo, Eastern Research Group, Inc. “RE: Channel View’s 

2008 Chlorine and Flow Data in DMR.” (August 30). EPA-HQ-OW-2008-0517 DCN 

07295. 

4. Sampey, Troy. 2010. E-mail Communication between Troy Sampey, Chevron Oronite 

Co., and Elizabeth Sabol, Eastern Research Group, Inc. “RE: DMRs Clarification Needed 

for Chevron Oronite - Oak Point Plant.” (July 13). EPA-HQ-OW-2008-0517 DCN 

07296. 

5. Simmons, Linda. 2010. Notes from Telephone Conversation between Linda Simmons, 

West Virginia Department of Environmental Protection, and Elizabeth Sabol, Eastern 

Research Group, Inc. “RE: PAC Discharges Reported to DMR in 2008.” (July 13). EPAHQ-OW-2008-0517 DCN 07297. 

6. TCEQ. 2004. Texas Commission on Environmental Quality. Water Discharge Permit for 

NPDES TX0003531 – Channelview Complex, Channelview, TX. EPA-HQ-OW-2008-

0517 DCN 07298. 

7. TCEQ. 2009. Texas Commission on Environmental Quality. Notice of Application and 

Preliminary Decision for Water Quality TPDES Permit Amendment for Industrial 

Wastewater for NPDES TX0006017 – Oxea Bay City Plant, Bay City, TX. EPA-HQOW-2008-0517 DCN 07299. 

8. U.S. Census. 2002. U.S. Economic Census. Available online at: 

http://www.census.gov/econ/census02. 

9. U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program 

Plan. EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346 

through 1352. 

10. U.S. EPA. 2005a. Preliminary 2005 Review of Prioritized Categories of Industrial 

Dischargers. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-

0016. 
Section 12 – Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

12-20

11. U.S. EPA. 2005b. Product and Product Group Discharges Subject to Effluent Limitations 

and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source 

Category. Washington, DC. (April). EPA-HQ-OW-2004-032-2568. 

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

Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782. 

13. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent 

Guidelines Program Plan. EPA-821-R-07-007. Washington, DC. (October). EPA-HQOW-2006-0771-0819. 

14. U.S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program 

Plan. EPA-821-R-08-015 Washington, DC. (August). EPA-HQ-OW-2006-0771-1701. 

15. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent 

Guidelines Program Plan. EPA-821-R-09-006. Washington, DC. (October). EPA-HQOW-2008-0517-0515. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-1

13. PLASTICS MOLDING AND FORMING (40 CFR PART 463) 

EPA selected the Plastics Molding and Forming (PMF) Category for preliminary review 

because it continues to rank high, in terms of toxic-weighted pound equivalent (TWPE), in point 

source category rankings (see Table 5-3 for the point source category rankings). The Final 2006 

Plan summarizes the results of EPA’s previous reviews of this industry in 2005 and 2006 (71 FR 

76644). This section summarizes the results of the 2010 annual review associated with the PMF 

Category. EPA focused on discharges of carbon disulfide from four cellulose products 

manufacturers, because of their high TWPE relative to the rest of the PMF Category. 

13.1 PMF Category Background

This subsection provides background on the PMF Category including a brief profile of 

the PMF industry, background on 40 CFR Part 463,and background on 40 CFR Part 63 Subpart 

UUUU, the Cellulose Products National Emission Standards for Hazardous Air Pollutants 

(NESHAP). 

13.1.1 PMF Industry Profile 

The plastics molding and forming industry includes facilities that are engaged in 

blending, molding, forming, or other types of processing of plastic materials. These processes 

commonly include extrusion, coating and laminating, thermoforming, calendaring, casting, 

foaming, cleaning, and finishing (U.S. EPA, 1984). EPA considered the following 13 North 

American Industry Classification System (NAICS) codes part of the PMF Category: 

• 325991: Custom Compounding of Purchased Resins; 

• 326113: Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing; 

• 326121: Unlaminated Plastics Profile Shape Manufacturing; 

• 326122: Plastics Pipe and Pipe Fitting Manufacturing; 

• 326130: Laminated Plastics Plate, Sheet (except Packaging), and Shape 

Manufacturing; 

• 326140: Polystyrene Foam Product Manufacturing; 

• 326150: Urethane and Other Foam Product (except Polystyrene) Manufacturing; 

• 326160: Plastics Bottle Manufacturing; 

• 326191: Plastics Plumbing Fixture Manufacturing; 

• 326199: All Other Plastics Product Manufacturing; 

• 332813PMF: Electroplating, Plating, Polishing, Anodizing and Coloring; 

• 335921: Fiber Optic Cable Manufacturing; and 

• 339999PMF: All Other Miscellaneous Manufacturing. 

Wastewater generated by facilities in NAICS codes 332813 and 339999 can be regulated 

under multiple categories. EPA reviewed available information about pollutant loads and 

manufacturing operations for facilities reporting these NAICS codes. In its crosswalk, EPA 

assigned the extension “PMF” to the end of the NAICS codes for facilities that most likely fall 

under the applicability of 40 CFR Part 463, PMF. Most facilities in NAICS 332813 are grouped 

under the Electroplating Category, while most facilities in NAICS 339999 are grouped under the 

Metal Finishing Category. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-2

Because the Permit Compliance System (PCS) and Integrated Compliance Information 

System - National Pollutant Discharge Elimination System (ICIS-NPDES), the sources of the 

discharge monitoring report (DMR) data used to develop DMRLoads2008, report facilities by 

Standard Industrial Classification (SIC) code, and the U.S. Economic Census and Toxics Release 

Inventory (TRI) report data by NAICS code, EPA reclassified the 2008 DMR by the equivalent 

NAICS code. Table 13-1 lists the number of facilities from the U.S. Economic Census and the 

screening-level databases for the twelve NAICS codes with operations in the PMF Category, the 

corresponding SIC codes are included for reference. The U.S. Economic Census includes more 

facilities than the screening-level databases because of many possible factors including: facilities 

may not meet TRI-reporting thresholds, facilities may discharge to a publicly owned treatment 

works (POTW), and some facilities in the U.S. Economic Census are distributors or sales 

facilities, not manufacturers. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-3

Table 13-1. Number of PMF Facilities 

NAICS Code 

Corresponding SIC 

Code

Number of Facilities 

2002 U.S. 

Economic 

Census 

2008 DMR 

Database a

2008 TRI 

Database b

325991: Custom Compounding of 

Purchased Resins 

3087: Custom 

Compounding of 

Purchased Plastics 

Resins 749 31 179 

326113: Unlaminated Plastics Film and 

Sheet (except Packaging) Manufacturing 

3081: Unsupported 

Plastics Film and Sheet 881 162 80 

326121: Unlaminated Plastics Profile 

Shape Manufacturing 

3082: Unsupported 

Plastics Profile Shapes; 

3084: Plastics Pipe; and 

3089: Plastics Products, 

NEC 

670 

219 

47 

326122: Plastics Pipe and Pipe Fitting 

Manufacturing 441 48 

326199: All Other Plastics Product 

Manufacturing 7,892 442 

332813PMF: Electroplating, Plating, 

Polishing, Anodizing and Coloring NA 4 

339999PMF: All Other Miscellaneous 

Manufacturing NA 1 

326130: Laminated Plastics Plate, Sheet 

(except Packaging), and Shape 

Manufacturing 

3083: Laminated Plastics 

Plate, Sheet, and Profile 

Shapes 293 9 66 

326140: Polystyrene Foam Product 

Manufacturing 

3086: Plastics Foam 

Products 

552 

39 

26 

326150: Urethane and Other Foam Product 

(except Polystyrene) Manufacturing 627 212 

326160: Plastics Bottle Manufacturing 3085: Plastics Bottles 404 32 3 

326191: Plastics Plumbing Fixture 

Manufacturing 

3088: Plastics Plumbing 

Fixtures 544 6 129 

335921: Fiber Optic Cable Manufacturing NA c 96 NA c 4 

Total >13,149 498 1,241 

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2; and TRIReleases2008_v3. 

a – Includes both major and minor dischargers. Also, DMR data is reported by SIC code; therefore EPA used an 

NAICS to SIC crosswalk for comparison purposes. 

b – Facilities reporting releases to any media. 

c – There is not an SIC code that links to the NAICS code 335921 with facilities that have discharges meeting the 

applicability of the PMF Category. 

NA – Not applicable. 

NEC – Not elsewhere classified. 

Table 13-2 shows whether permitting authorities designated direct discharging facilities 

in the PMF Category as minor or major dischargers (see Section 4.1.5). EPA included data for 

minor dischargers for the first time in the 2010 annual review, as part of DMRLoads2008_v2. 

EPA does not require permitting authorities to submit DMR data for minor dischargers; however, 

many states do provide complete DMR data for them. From this year’s review, EPA observed 

many data entry or other errors for minor dischargers in addition to those previously identified 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-4

for major dischargers, as discussed in Section 4.3. Table 13-2 shows that approximately 99 

percent of the PMF Category dischargers in the 2008 DMR database are minor dischargers. 

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

NAICS Code a

Number of Facilities in 2008 DMR Database 

Majors 

Dischargers 

Minors 

Dischargers Total 

325991: Custom Compounding of Purchased Resins 0 31 31 

326113: Unlaminated Plastics Film and Sheet (except 

Packaging) Manufacturing 3 159 162 

326121: Unlaminated Plastics Profile Shape 

Manufacturing 

3 216 219 

326122: Plastics Pipe and Pipe Fitting Manufacturing 

326199: All Other Plastics Product Manufacturing 

332813PMF: Electroplating, Plating, Polishing, 

Anodizing and Coloring 

339999PMF: All Other Miscellaneous Manufacturing 

326130: Laminated Plastics Plate, Sheet (except 

Packaging), and Shape Manufacturing 1 8 9 

326140: Polystyrene Foam Product Manufacturing 

0 39 39 

326150: Urethane and Other Foam Product (except 

Polystyrene) Manufacturing 

326160: Plastics Bottle Manufacturing 0 32 32 

326191: Plastics Plumbing Fixture Manufacturing 0 6 6 

335921: Fiber Optic Cable Manufacturing NA NA NA 

Total 7 491 b 498 

Source: DMRLoads2008_v2. 

a – DMR data are reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison 

purposes. 

b – The DMR data in PCS and ICIS-NPDES does not include discharge data for all minor dischargers. For the 

facilities in the PMF Category, 99 of the 491 minor dischargers have DMR data. 

NA – Not applicable. There is not an SIC code that links to the NAICS code 335921 with facilities that have 

discharges meeting the applicability of the PMF Category. 

Table 13-3 presents the type of discharges reported by facilities in the 2008 TRI database. 

The majority of PMF facilities reporting to TRI do not report water discharges, but those that do 

mostly reported indirect discharges to POTWs. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-5

Table 13-3. Number of PMF Facilities by Discharge Type in 2008 TRI Database 

NAICS Code 

Number of Facilities in 2008 TRI Database 

Direct 

Dischargers 

Only 

Indirect 

Dischargers 

Only 

Both Indirect 

and Direct 

Dischargers 

No Water 

Discharges 

325991 Custom Compounding of Purchased Resins 13 27 8 131 

326113 Unlaminated Plastics Film and Sheet 

(except Packaging) Manufacturing 7 18 3 52 

326121 Unlaminated Plastics Profile Shape 

Manufacturing 1 6 0 40 

326122 Plastics Pipe and Pipe Fitting 

Manufacturing 0 1 0 47 

326130 Laminated Plastics Plate, Sheet (except 

Packaging), and Shape Manufacturing 1 4 1 60 

326140 Polystyrene Foam Product Manufacturing 2 2 0 22 

326150 Urethane and Other Foam Product (except 

Polystyrene) Manufacturing 1 1 0 210 

326160 Plastics Bottle Manufacturing 0 0 0 3 

326191 Plastics Plumbing Fixture Manufacturing 2 0 0 127 

326199 All Other Plastics Product Manufacturing 3 12 2 425 

332813PMF Electroplating, Plating, Polishing, 

Anodizing and Coloring 0 4 0 0 

335921: Fiber Optic Cable Manufacturing 2 0 1 1 

339999PMF All Other Miscellaneous 

Manufacturing 0 1 0 0 

Total 32 76 15 1,118 

Source: TRIReleases2008_v3.

13.1.2 40 CFR Part 463 

EPA first promulgated effluent limitation guidelines and standards (ELGs) for the PMF 

Category (40 CFR Part 463) on December 17, 1984 (49 FR 49040). There are three 

subcategories, all of which have best practicable control technology (BPT), new source 

performance standards (NSPS), pretreatment standards for existing sources (PSES), and 

pretreatment standards for new sources (PSNS) limitations. See Section 11.B of the Preliminary 

2005 Review of Prioritized Categories of Industrial Dischargers (U.S. EPA, 2005a) for 

additional details on the subpart applicability and discharge limitations and standards. 

The remainder of this section focuses on cellulose manufacturing facilities because their 

discharges remain the top concern for the PMF Category for the 2010 annual review, as they 

were for the 2005 and 2006 annual reviews. 

EPA determined in the 2005 and 2006 annual reviews that cellulose film and sponge 

manufacturers were discharging large quantities of carbon disulfide (U.S. EPA, 2005a; U.S. 

EPA, 2006). The carbon disulfide discharges from the manufacture of cellulose product are not 

covered by Part 463 (the PMF Category). The product is made of regenerated cellulose using the 

viscose process, and Part 463 specifically excludes products manufactured from regenerated 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-6

cellulose, as well as the molding and forming of regenerated cellulose (U.S. EPA, 1984). Further, 

the Development Document for Effluent Limitations Guidelines and New Source Performance 

Standards for the Plastics Molding and Forming Point Source Category states that 40 CFR Part 

414, Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Point Source Category, covers 

only the manufacture of rayon, a regenerated cellulose fiber, and excludes the manufacture of 

cellulose film, sponge, and meat casings (U.S. EPA, 1987; U.S. EPA, 2005b). Thus, wastewater 

discharges from the manufacture of several cellulose products, including film, sponge, and meat 

casings, are not covered by any existing categorical ELGs or pretreatment standards. 

Additionally, neither PMF nor OCPSF regulate discharges of carbon disulfide, the pollutant of 

concern for the cellulose products manufacturers identified in the annual reviews of the PMF 

Category. 

13.1.3 40 CFR Part 63 Subpart UUUU 

On June 11, 2002, a NESHAP for Cellulose Products Manufacturing (40 CFR Part 63, 

Subpart UUUU) was promulgated (67 FR 40055). The Cellulose Products Manufacturing 

NESHAP regulated the Miscellaneous Viscose Processes and Cellulose Ethers Production 

Categories. The Miscellaneous Viscose Process category includes cellulose food casings, rayon, 

cellulosic sponge, and cellophane manufacturing facilities. The NESHAP established emissions 

limits for hazardous air pollutants (HAPs), such as carbon disulfide, carbonyl sulfide, ethylene 

oxide, methanol, methyl chloride, propylene oxide, and toluene. As a result, additional air 

pollution control may be transferring more carbon disulfide to the water via scrubbers. For more 

information on the Cellulose Products Manufacturing NESHAP see Section 15.1.3 of the 

Technical Support Document for the 2006 Effluent Guidelines Program Plan (2006 Technical 

Support Document) (U.S. EPA, 2006). 

13.2 PMF Category 2010 Screening-Level Review

Table 13-4 compares the screening-level results for the PMF Category from the 2006 

through 2010 annual reviews. The combined TWPE from discharges in the DMR and TRI 

databases decreased from discharge years 2002 to 2007, but increased from discharge years 2007 

to 2008. Both the 2008 DMR TWPE and 2008 TRI TWPE increased significantly from the 

previous year. The increase in DMR TWPE is due to the addition of minor dischargers as part of 

the 2010 annual review and data entry errors for chlorine and diethylhexyl phthalate discharges 

(see Sections 13.4 and 13.6). The 2008 DMR TWPE accounts for approximately 70 percent of 

the total category TWPE. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-7

Table 13-4. PMF Category TRI and DMR Discharges for the 2006 through 2010 

Screening-Level Reviews 

Year of Discharge Year of Review 

PMF Category 

TRI TWPE DMR TWPE a Total TWPE 

2002 2006 118,000 20,800 139,000 

2004 2007 72,700 10,800 83,400 

2005 2008 22,300 NA NA 

2007 2009 8,780 12,400 21,200 

2008 2010 74,700 174,000 249,000 

Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; 

TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; and DMRLoads2008_v2. 

a – DMR data from 2002 through 2007 includes only major discharges. 2008 DMR data includes both minor and 

major dischargers. 

NA – Not applicable. EPA did not evaluate DMR data for 2005. 

Table 13-5 presents the 2008 DMR TWPE by facility discharge classification. EPA 

excluded minor dischargers from previous annual reviews, but included them in the 2010 annual 

review. The majority (70 percent) of the TWPE in the 2008 DMR database is from minor 

dischargers. 

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

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers 

2008 121,000 52,900 

Source: DMRLoads2008_v2. 

a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous 

annual reviews. 

13.3 PMF Pollutants of Concern

Table 13-6 lists the five pollutants with the highest TRI TWPE based on results from the 

2010, 2009, and 2007 annual reviews (TRIReleases2008_v3, TRIReleases2007_v2, and 

TRIReleases2004_ v3, respectively). Table 13-7 lists the five pollutants with the highest DMR 

TWPE based on results from the 2010, 2009, and 2007 annual reviews (DMRLoads2008_v2, 

DMRLoads2007_v3, and PCSLoads2004_v4, respectively). 
Section 13 – Plastics Molding and Fo

13-8

Table 13-6. PMF Category Top TRI Pollutants 

Pollutant 

2004 TRI Database a 2007 TRI Database a 2008 

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

N

R

Carbon Disulfide 1 5 65,400 1 3 6,950 1 Nitrate Compounds 4 11 354 3 10 360 2 Lead and Lead Compounds 5 56 350 2 46 660 3 Butyraldehyde Pollutants not reported in the top five 

2004 TRI reported pollutants. 

4 2 310 4 

Diethylhexyl Phthalate 5 8 121 5 Dioxin and Dioxin-like Compounds 2 1 5,410 Pollutants not reported in the top five 2007 TRI reported pollutants. Pollutants no

2008 TRI 

Formaldehyde 3 4 389 PMF Category Total NA 154 b 76,700 NA 121 b 8,780 NA 

Source: TRIReleases2004_v3, TRIReleases2007_v2; and TRIReleases2008_v3. 

a – Discharges include transfers to POTWs and account for POTW removals. b – Number of facilities reporting TWPE greater than zero. NA – Not applicable. 
Section 13 – Plastics Molding and Fo

13-9

Table 13-7. PMF Category Top DMR Pollutants 

Pollutant 

2004 DMR Database a 2007 DMR Database a 2008 D

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Chlorine 

Pollutant not reported in the top five 

2004 DMR reported pollutants. 

Pollutant not reported in the top five 

2007 DMR reported pollutants. 1 

Carbon Disulfide 1 1 9,780 1 1 11,800 2 Diethylhexyl Phthalate 

Pollutant not reported in the top five 

2004 DMR reported pollutants. 

Pollutant not reported in the top five 

2007 DMR reported pollutants. 3 

Copper 2 3 187 4 2 114 4 Sulfate 3 1 185 2 1 175 5 Ammonia as Nitrogen Pollutants not reported in the top five 

2004 DMR reported pollutants. 

3 4 121 

Pollutants no

2008 DMR 

Cadmium 5 2 46 Nitrogen, Ammonia 4 5 182 Pollutants not reported in the top five Nitrogen, Nitrate (Total As N) 5 1 106 2007 DMR reported pollutants. PMF Category Total NA 7 c 10,800 NA 6 c 12,400 NA 

Source: PCSLoads2004_v4; DMRLoads2007_v3; and DMRLoads2008_v2. a – 2004 and 2007 DMR data include only major dischargers. b – 2008 DMR data includes major and minor dischargers. c – Number of facilities reporting TWPE greater than zero. NA – Not applicable.
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-10

The PMF Category combined TWPE is dominated by carbon disulfide discharges, 

accounting for approximately 61 percent of the combined TWPE. Therefore, EPA focused the 

preliminary category review on carbon disulfide discharges from TRI and DMR along with the 

other top DMR-reported pollutants that account for the majority of the category TWPE. 

Chlorine is the top DMR-reported pollutant in 2008, followed by carbon disulfide and 

diethylhexyl phthalate. EPA’s additional review for chlorine, diethylhexyl phthalate, and carbon 

disulfide, the pollutants of concern, is presented in the following subsections. EPA did not 

investigate the other top pollutants as part of the 2010 annual review because they account for a 

small percentage (1 percent) of the 2008 PMF Category combined DMR and TRI TWPE. 

13.4 PMF Category Chlorine Discharges in DMR

As part of the 2010 annual review of the PMF Category, EPA reviewed chlorine 

discharges in the 2008 DMR database. Approximately 46 percent of the 2008 DMR TWPE is 

from chlorine discharges. Table 13-8 presents the chlorine discharges from PMF facilities in the 

2008 DMR database. Kinetico Inc., in Newberry, OH, accounts for 99 percent of the chlorine 

discharges in the 2008 DMR database for the PMF Category. This subsection provides 

information on Kinetico’s chlorine discharges. 

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

Facility Name 

Pounds of Chlorine 

Discharged Chlorine TWPE 

Percentage of PMF 

Category’s 2008 

DMR Chlorine 

TWPE 

Kinetico, Inc. 159,000 79,500 99% 

Remaining PMF Chlorine Dischargers a 200 100 1% 

Total 159,000 79,600 100% 

Source: DMRLoads2008_v2. 

a – There are 25 remaining PMF facilities that have chlorine discharges in DMRLoads2008_v2 that account for 

about 1 percent of the PMF Category’s 2008 chlorine TWPE. 

Kinetico discharges chlorine from outfalls 001 and 003. The majority of the chlorine 

discharges from Kinetico are from outfall 003 (99.9 percent). Table 13-9 presents Kinetico’s 

2008 monthly discharge data in the DMR Loadings Tool for outfall 003. EPA compared the 

concentration and flow data from the DMR Loadings Tool to the data in Envirofacts22 and 

determined that there is a unit of measurement error for the outfall 003 flows. The flows in the 

DMR Loadings Tool were 1,000,000 times higher than the data in Envirofacts, also presented in 

Table 13-9. Using the outfall 003 flows from Envirofacts, Kinetico’s chlorine discharges are 

0.159 pounds and 0.079 TWPE for 2008, reducing the facility’s total TWPE by 99 percent. This 

reduction in TWPE decreases the PMF Category’s 2008 DMR TWPE by 79,500 TWPE. 

 

22 EPA uses the data in Envirofacts as a source while reviewing the DMR Loadings Tool data because Envirofacts 

continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not 

continuously updated; therefore, loads may be estimated with erroneous data. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-11

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

Outfall 

Monitoring 

Period Date 

NODI 

Code a 

DMR Loadings Tool 

Maximum Chlorine 

Concentration (mg/L) 

DMR Loadings Tool 

Flow (MGD) 

EPA Envirofacts Flow 

(MGD) 

003 31-May-08 Q 377 0.000378 

003 30-Jun-08 Q 297 0.000297 

003 31-Jul-08 Q 305 0.000304 

003 31-Aug-08 Q 289 0.000289 

003 30-Sep-08 0.1 529 0.000529 

003 31-Oct-08 Q 391 0.000391 

Source: DMR Loadings Tool and Envirofacts. 

a – NODI Code Q means that the concentration is not quantifiable. 

13.5 PMF Category Carbon Disulfide Discharges in DMR and TRI

The 2010 annual review of the PMF Category focused on carbon disulfide discharges in 

the 2008 DMR and TRI databases. Carbon disulfide discharges accounted for 50 percent of the 

combined 2008 DMR and TRI TWPE for the PMF Category. This subsection provides 

information on the manufacture of regenerated cellulose products because this industry segment 

is responsible for the PMF Category carbon disulfide discharges. This subsection also includes 

information on the top carbon disulfide facilities in the 2008 DMR and TRI databases, including 

wastewater sources and treatment. 

13.5.1 Regenerated Cellulose Products 

As part of the 2005 annual review, EPA determined that the carbon disulfide discharges 

come from facilities that manufacture regenerated cellulose products, such as cellophane, 

cellulosic sponge, and meat casings (U.S. EPA, 2005a). For the 2006 annual review, EPA 

reviewed a study of the cellulose products manufacturing facilities that was written in support of 

the Cellulose Products Manufacturing NESHAP. The information gathered during the study is 

summarized in the memorandum Industry Profile of Cellulose Products Manufacturing Facilities 

in the U.S. (Schmidtke, 2000). The findings regarding the regenerated cellulose industry from the 

2006 annual review are summarized below. See Section 15.5.1 in the 2006 Technical Support 

Document (U.S. EPA, 2006) for additional details. 

The viscose process is used to manufacture cellulose film, sponge, meat casings, and 

rayon. In the viscose process, sheets of dissolving-grade cellulose pulp are saturated with caustic 

to convert the cellulose into alkali cellulose. The alkali cellulose is pressed to remove the excess 

caustic and is shredded to increase the surface area for easier processing. After shredding, the 

alkali cellulose resembles “white crumbs.” The alkali cellulose partially oxidizes and degrades 

by aging in ambient air. Gaseous carbon disulfide is mixed with the aged alkali cellulose in a 

vessel to form sodium cellulose xanthate, resembling “yellow crumbs.” The sodium cellulose 

xanthate is dissolved in aqueous caustic solution, creating the viscose solution. The viscose 

solution is ripened, filtered, degassed, and extruded and then sulphuric acid is added to the 

viscose solution to form regenerated cellulose (Schmidtke, 2000). The manufacture of rayon, 

cellophane, and meat casings differ in the type of extrusion dye and the post-regeneration 

processing, which includes at least washing and bleaching. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-12

The manufacture of cellulosic sponge differs slightly. The sheets of dissolving-grade pulp 

are converted into alkali cellulose, followed by xanthation into sodium cellulose xanthate using 

carbon disulfide, and formation of the viscose solution. The viscose solution is then mixed with 

sodium sulphate crystals, other fibers, and dyes. The mixture is poured into a mold or extruded 

under high temperature to melt the sodium sulphate crystals, leaving the pores characteristic of 

sponges. The remaining processing of the cellulose sponges includes bleaching, washing, 

cutting, and possibly packaging. Some facilities that manufacture sponges do not make viscose 

and thus do not use carbon disulfide. Instead they purchase blocks of hardened viscose that they 

dissolve to form the softened viscose for processing (Schmidtke, 2000). 

13.5.2 Regenerated Cellulose Facility Information 

EPA identified cellulose products manufacturers in the United States using the TRI and 

DMR databases and data from a study of the cellulose products manufacturing industry 

conducted by EPA’s Office of Air Quality Planning and Standards (OAQPS) during their 

development of NESHAP regulations (Schmidtke, 2000). Table 13-10 lists the six U.S. cellulose 

products manufacturers identified in the PMF Category. There may be additional cellulose 

manufacturing facilities in the United States not included in the available sources. 

In addition, rayon manufacturers are not discussed in this section. Their manufacturing 

process is identical to other cellulose manufacturing processes, but they form fibers instead of 

sheets, tubes, or sponges. However, these manufacturers are regulated under Part 414: OCPSF. 

OCPSF does not regulate carbon disulfide discharges. 

Four of the six facilities reported wastewater discharges of carbon disulfide to TRI in 

2008, and one of the 2008 TRI facilities also has discharges of carbon disulfide in the 2008 DMR 

database. Although all six regenerated cellulose facilities have National Pollutant Discharge 

Elimination System (NPDES) permit IDs, there are data for only three of them in the 2008 DMR 

database. Table 13-11 presents the total pollutant discharges for the regenerated cellulose 

facilities in the 2008 TRI and DMR databases, along with the discharges of carbon disulfide. 

Table 13-11 excludes the 3M Corporation facilities in Elyria, OH and Prairie du Chien, WI 

because these facilities do not have data for 2008 in PCS or ICIS-NPDES and TRI. 

EPA reviewed additional information on two of the facilities reporting carbon disulfide 

discharges in 2008, Innovia Films in Tecumseh, KS and Viskase in Loudoun, TN. Specific 

information regarding these facilities is presented in the following subsections.
Section 13 – Plastics Molding and Fo

13-13

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

TRI ID 

(NPDES ID) Facility Name Facility Location Product Type 

Discharge 

Type Perm

66542FLXLN6000S (KS0003204) 

Innovia Films Inc. Tecumseh, KS Cellophane Direct Carbon disulfide monitori

activated sludge basin becbiological process at concmg/L. Facility must notify disulfide exceeds 17.5 mg

61832TPKNC915NM (ILR000333) 

Viscofan USA Inc. Danville, IL Meat Casings Indirect Facility only has a genera

facility discharges proces

37774VSKSCEASTL (TN0001457) 

Viskase Corporation 

Loudon, TN Meat Casings Indirect b Permit limits are based on 

treatability. 

72370VSKSCRT198 (AR0036544) 

Viskase Corporation 

Osceola, AR Meat Casings Direct Facility is a minor dischar

14150GNRLM305SA (NYR00D034) 

3M Corporation Tonawanda, NY Cellulosic Sponges Indirect Facility does not have DM

discharges indirectly. No 

44035NYLNG1301L (NA) 

3M Corporation Elyria, OH Cellulosic Sponges Unknown Does not report discharge

NPDES. Does not report wTRI. No permit available. 

53821MCMPN217NO (NA) 

3M Corporation Prairie du Chien, 

WI 

Cellulosic Sponges Indirect Does not report discharge

NPDES. Does not report wTRI after 2001. No permi

38402SPNTXSANTA (TN0001571) 

Spontex Inc. Columbia, TN Cellulosic Sponges Direct Permit writer used OCPSF 

Thermoplastic Resins BPpermit. The permit writer limitations because the famillion pounds of product 

Source: Company Websites (Devro, Unknown; Innovia Films, 2004; Spontex, 2004; Viskase, 2002); TRIReleases2002_4; TRIReleasesPermits (TDEC, 2002; IEPA, 2003; KDHE, 2005; ADEQ, 2000; TDEC, 2005); and Industry Profile of the Cellulose Products ManufacU.S. (Schmidtke, 2000). a – Rayon is included in cellulose manufacturers; however, these facilities are not presented in this table. Wastewater discharges from rcovered under the OCPSF Category (40 CFR Part 414). b – EPA believes the facility is an indirect discharger because the facility reports POTW transfers and not surface water releases to TRIdata for this facility, although they have a NPDES permit that expired in December 2006. EPA believes they began discharging only to 

1991. NA – Not applicable. 
Section 13 – Plastics Molding and Fo

13-14

Table 13-11. 2008 TRI and DMR Discharges for Cellulose Products Manufacturing Facil

Facility Name 

2008 TRI 2008 DMR 

Total Pounds 

Discharged a Total TWPE 

Carbon 

Disulfide 

Pounds 

Discharged a

Carbon 

Disulfide 

TWPE 

Total Pounds 

Discharged Total TWPE 

Ca

Disu

Pou

Disch

Innovia Films Inc. Tecumseh, KS 

38,300 55,600 19,900 55,600 84,400,000 52,200 18

Viscofan USA Inc. Danville, IL 

6,890 10,800 3,810 10,800 NA NA N

Viskase Corporation Loudon, TN 

1,990 5,540 1,920 5,380 NA NA N

Viskase Corporation Osceola, AR 

14,800 1,330 470 1,320 241,000 122 N

3M Corporation Tonawanda, NY 

768 2,150 NR NR NA NA N

Spontex Inc. Columbia, TN 

219 613 NR NR 40,900 14.4 N

Source: TRIReleases2008_v3 and DMRLoads2008_v2. 

a – Discharges include transfers to POTWs and account for POTW removals (i.e., the amount shown assumes that the POTW removed 

NA – Not applicable. These facilities are indirect dischargers. NR – Not reported.
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-15

13.5.2.1 Innovia Films in Tecumseh, KS 

EPA reviewed the carbon disulfide discharges from Innovia Films in Tecumseh, KS as 

part of the 2010 annual review because this facility has the largest discharge of carbon disulfide 

in the 2008 TRI and DMR databases. The pounds of carbon disulfide reported in 2008 TRI is 

close to the annual pounds discharged calculated in 2008 DMR database. Innovia Films 

estimated their carbon disulfide releases based on periodic monitoring data. EPA believes that 

Innovia Films used their carbon disulfide DMR data to report to TRI. Therefore, EPA reviewed 

the 2008 DMR carbon disulfide discharges from Innovia Films only as part of the 2010 annual 

review. 

During the 2006 annual review, EPA reviewed carbon disulfide discharges for Innovia 

Films. EPA contacted Innovia Films, because it was the only facility reporting discharges of 

carbon disulfide for the PMF Category in the 2002 DMR database. The facility provided 

corrections to the effluent carbon disulfide concentrations, and EPA corrected the estimated 

pounds of pollutant discharged. The facility contact indicated that the carbon disulfide discharges 

reported resulted from wet scrubbing of the gaseous by-products (Martin, 2006). 

Table 13-12 presents the carbon disulfide discharge data in the DMR Loadings Tool for 

2008 along with the facility-corrected carbon disulfide data from 2006, for comparison purposes. 

The carbon disulfide concentrations and discharge flows for 2008 are similar to the corrected 

2006 data. Therefore, EPA determined that the data are likely accurate, and Innovia Films is 

likely discharging more than 18,000 pounds of carbon disulfide from Outfall 001 annually. 

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

Outfall 

Monitoring 

Period Date 

2006 FacilityProvided Carbon 

Disulfide 

Concentration 

(mg/L) 

2008 DMR 

Loadings Tool 

Carbon Disulfide 

Concentration 

(mg/L) 

2006 FacilityProvided Flow 

(MGD) 

2008 DMR 

Loadings Tool 

Flow (MGD) 

001 31-Jan-08 2.39 2.03 1.94 1.90 

001 29-Feb-08 3.41 4.98 2.03 1.98 

001 31-Mar-08 0.362 9.48 2.02 2.08 

001 31-May-08 0.072 0.747 2.06 1.78 

001 30-Jun-08 0.019 0.557 2.08 1.96 

001 31-Jul-08 0.005 0.368 1.87 1.68 

001 31-Aug-08 0.022 0.75 1.74 1.91 

001 30-Sep-08 0.028 5.76 1.96 2.01 

001 31-Oct-08 0.095 0 1.93 1.79 

001 30-Nov-08 0.609 8.34 2.03 1.71 

001 31-Dec-08 2.39 2.15 1.94 1.80 

Source: DMR Loading Tool and Facility Contact (Martin, 2006).
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-16

13.5.2.2 Viskase Corporation in Loudoun, TN 

The Viskase facility in Loudoun, TN manufactures cellulose casings and discharges 

water to the adjacent POTW. The facility consistently reports releases of approximately 100,000 

pounds of carbon disulfide to the POTW (based on TRI data from 2005 through 2008). 

As part of its reviews, EPA contacted the facility and the POTW receiving the facility’s 

wastewater in 2009. The facility contact indicated that they estimate their discharges of carbon 

disulfide for TRI using sampling data that is collected every two or three years. The POTW 

contact indicated that in addition to Viskase sampling at the point where the discharge leaves the 

facility, the POTW samples for carbon disulfide when the discharge enters the POTW facility 

from a pipe connecting the two adjacent properties. The combined data show that the facility 

releases close to 100,000 pounds of carbon disulfide to the POTW, but the POTW receives less 

than 3,000 pounds from the discharge pipe. This decrease in pollutant load suggests the possible 

volatilization of 97,000 pounds of carbon disulfide within the discharge pipe, but warrants 

further investigation (Birkholtz, 2009; Glarrow, 2009; U.S. EPA, 2009).

The data in TRIReleases2008_v3 are consistent with the information collected from the 

facility and POTW. As a result, no corrections were made to the 2008 TRI data. 

13.5.3 Wastewater Sources of Carbon Disulfide 

At cellulose products manufacturing facilities, the main wastewater sources of carbon 

disulfide include railcar unloading, carbon disulfide storage, and air pollution control 

(Schmidtke, 2000). 

Carbon disulfide gas is delivered to most cellulose products facilities by railcar. 

Unloading the railcar requires filling it with water or nitrogen to displace the carbon disulfide 

into the storage tank. Facilities using water displacement generate carbon-disulfide-saturated 

wastewater during railcar unloading, which is sent to the facility’s wastewater treatment system. 

Facilities using nitrogen displacement do not produce the carbon-disulfide-saturated wastewater 

during railcar unloading. EPA determined that Spontex Inc. was the only facility of the eight 

listed in Table 13-10 that uses water to displace carbon disulfide during unloading as of 2000 

(Schmidtke, 2000). 

Carbon disulfide storage tanks are typically submerged under water in a concrete-lined 

pool. This allows any carbon disulfide leaks to collect in the bottom of the pool to avoid 

atmospheric releases. In addition to the underwater storage, the tanks have a water or nitrogen 

padding system to fill the headspace in the tank and further prevent contact with oxygen. The 

padding is in direct contact with the carbon disulfide, creating wastewater saturated with carbon 

disulfide if a water padding system is used. The water padding in the storage tank is displaced 

into the water pool when the storage tanks are filled. Displaced water in the pool and water 

padding is sent to the wastewater treatment system. As of 2000, EPA determined that, of the 

facilities listed in Table 13-10, only Viscofan USA Inc, 3M Corporation Tonawanda, and 

Spontex Inc. use a water padding system (Schmidtke, 2000). 

Gaseous by-products in the regeneration of cellulose, including hydrogen sulfide and 

carbon disulfide, are off-gassed from the process equipment. Pollutants in the vented gas can be 

removed via a wet gas scrubber, which uses an aqueous solution to remove the air pollutants. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-17

The wet scrubber removal efficiency for carbon disulfide is low but the scrubber effluent may 

contain some carbon disulfide (Schmidtke, 2000). Discharges reported by Innovia Films Inc. are 

due to wet scrubbing of the gaseous by-products (Martin, 2006). 

13.5.4 Regenerated Cellulose Wastewater Treatment 

Table 13-13 summarizes the wastewater treatment known to be used by cellulose 

products manufacturing facilities. 

Table 13-13. Cellulose Products Facilities Wastewater Treatment 

Product 

Number of 

Facilities 

Pretreatment Used by 

Indirect Dischargers 

Treatment Used by Direct 

Dischargers 

Cellophane 1 NA Neutralization, settling, equalization, 

second neutralization, aeration, and 

clarification. 

Food Casings 3 Neutralization, potential 

filtration and settling. 

Achieved carbon disulfide 

(CS2) concentrations of 5-

20 parts per million (ppm). 

Neutralization using lime, equalization, 

and clarification. 

Cellulosic 

Sponges 

4 Neutralization and 

oxidization 

Equalization, aeration, and clarification.

Source: Industry Profile of the Cellulose Products Manufacturing Facilities in the U.S. (Schmidtke, 2000). 

NA – Not applicable. 

13.6 PMF Category Diethylhexyl Phthalate Discharges in DMR

As part of the 2010 annual review of the PMF Category, EPA reviewed diethylhexyl 

phthalate discharges in the 2008 DMR database. Approximately 30 percent of the 2008 DMR 

TWPE results from diethylhexyl phthalate discharges. Table 13-14 presents the facilities in 2008 

DMR that discharge diethylhexyl phthalate. One facility, Flexco Corp. in Tuscumbia, AL, 

accounts for over 99 percent of the discharges in the 2008 DMR. This subsection provides 

information on Flexco’s diethylhexyl phthalate discharges. 

Table 13-14. PMF Category Diethylhexyl Phthalate Discharging Facilities in 2008 DMR 

Database 

Facility Name 

Major/Minor 

Facility Discharger 

Pounds of 

Diethyhexyl 

Phthalate 

Discharged 

Diethyhexyl 

Phthalate TWPE 

Percentage of PMF 

Category 

Diethyhexyl 

Phthalate TWPE 

Flexco Corp. Minor 969,000 40,200 >99% 

DuPont Teijin Films Major 9.7 2.3 <1% 

Total 969,000 40,200 100% 

Source: DMRLoads2008_v2. 

All of Flexco’s diethylhexyl phthalate discharges are from outfall 003. Table 13-15

presents Flexco’s 2008 diethylhexyl phthalate discharge data from the DMR Loadings Tool. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-18

EPA contacted Flexco to verify the 2008 diethylhexyl phthalate discharges in the DMR Loadings 

Tool. The facility contact confirmed that the November 2009 sample concentration was below 

detection and should have been reported as NODI Code B (below the detection limit) (Blazer, 

2010). Because all of the facility diethylhexyl phthalate concentrations were below detection, the 

facility’s revised diethylhexyl phthalate load and TWPE are zero, reducing the facility’s total 

TWPE by 100 percent. This reduction in TWPE decreases the PMF Category’s 2008 DMR 

TWPE by 40,200 TWPE. 

Table 13-15. Flexco Corp. 2008 Monthly Diethylhexyl Phthalate Discharge Data 

Outfall 

Monitoring Period 

Date NODI Code a 

Diethylhexyl Phthalate 

Maximum Concentration 

(mg/L) 

Average Flow 

(MGD) 

003 31-Jan-08 B 0.173 

003 29-Feb-08 B 0.173 

003 31-Mar-08 B 0.173 

003 31-May-08 B 0.173 

003 30-Jun-08 B 0.173 

003 31-Jul-08 B 0.258 

003 31-Aug-08 B 0.305 

003 30-Sep-08 B 0.283 

003 31-Oct-08 B 0.283 

003 30-Nov-08 109 0.475 

003 31-Dec-08 B 0.493 

Source: DMR Loadings Tool. 

a – Below the detection limit. 

13.7 PMF Category Conclusions

The estimated toxicity of the PMF Category discharges result mainly from the carbon 

disulfide discharges of regenerated cellulose facilities (accounting for 50 percent of the 

category’s 2008 combined DMR and TRI TWPE). Data collected for the 2010 annual review 

demonstrated that wastewater discharge characteristics for this category are consistent with 

discharges from prior years. As in prior years, EPA makes the following conclusions: 

• Database errors for discharges of chlorine were identified. After correcting these 

errors, the PMF Category total chlorine TWPE decreased by 99 percent, from 

79,600 to 100 TWPE. 

• Database errors for discharges of diethylhexyl phthalate were identified. After 

correcting these errors, the PMF Category total diethylhexyl phthalate pounds and 

TWPE decreased to zero (a decrease of 100 percent). 

• Carbon disulfide discharges from cellulose manufacturers were identified as a 

possible concern. Carbon disulfide discharges are not regulated by the PMF 

ELGs. The OCPSF Category does not regulate carbon disulfide for rayon 

manufacturers. Therefore, carbon disulfide discharges from cellulose 

manufacturers are not regulated under any ELGs. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-19

• From available data, 50 percent of regenerated cellulose manufacturers (excluding 

rayon fiber facilities) discharge directly to surface waters; 50 percent discharge to 

POTWs. 

• Many regenerated cellulose facilities do not have permit limits for carbon 

disulfide but are required to monitor for it. The facilities that monitor carbon 

disulfide are reporting discharges at measurable concentrations, above the 

detection limit. 

• Based on the 2010 annual review, EPA intends to conduct an expanded 

preliminary category review of carbon disulfide discharges as part of the 

2011/2012 planning cycle. 

EPA prioritizes point source categories with existing regulations for potential revision 

based on the greatest estimated toxicity to human health and the environment, measured as 

TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for 

revision (i.e., this category is marked with “(5)” in the “Findings” column in Table V-1 in the 

Federal Register notice that presents the 2009 annual review of existing ELGs). 

13.8 PMF Category References

1. ADEQ. 2000. Arkansas Department of Environmental Quality. National Pollution 

Discharge Elimination System Permit Application NPDES – AR0036544 – Viskase 

Corporation, Osceola, AR. Little Rock, AR. (December, 31). EPA-HQ-OW-2004-0032-

1205. 

2. Birkholtz, Dave. 2009. Telephone conversation with Dave Birkholtz of City of Loudoun, 

TN POTW and Eleanor Codding of Eastern Research Group, Inc. “Carbon Disulfide 

Discharges Reported to TRI by Viskase Facility in Loudoun, TN.” (March 12). EPA-HQOW-2008-0517 DCN 07300. 

3. Blazer, Don. 2010. E-mail communication with Don Blazer of Flexco Corp. in 

Tuscumbia, AL and Elizabeth Sabol of Eastern Research Group, Inc. “Flexco Corp. 

DMR Clarification.” (July 8). EPA-HQ-OW-2008-0517 DCN 07301. 

4. Devro. Unknown. Product Availability. Available online at: 

http://www.devro.plc.uk/products/index.htm. Date accessed: June 22, 2005. EPA-HQOW-2004-0032-0259. 

5. Glarrow, Patrick. 2009. Telephone communication with Patrick Glarrow of Viskase in 

Loudoun, TN and Eleanor Codding of Eastern Research Group, Inc. “Carbon Disulfide 

Discharges Reported to TRI by Viskase Facility in Loudoun, TN.” (March 10). EPA-HQOW-2008-0517-0074. 

6. IEPA. 2003. Illinois Environmental Protection Agency Division of Water Pollution 

Control. General NPDES Permit for Storm Water Discharges from Industrial Activities. 

Springfield, IL. EPA-HQ-OW-2004-0032-1209. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-20

7. Innovia Films. 2004. Company Profile. Available online at: 

http://www.innoviafilms.com/corporate/profile.htm. Date accessed: June 22, 2005. EPAHQ-OW-2004-0032-0261. 

8. KDHE. 2005. Kansas Department of Health and Environment. Kansas Water Pollution 

Control Permit and Authorization to Discharge Under NPDES KS0003204 – Innovia 

Films, Tecumseh, KS. Topeka, KS. (December 5). EPA-HQ-OW-2004-0032-1210. 

9. Martin, Tony. 2006. Telephone conversation with Tony Martin of Innovia Films Inc. and 

Jessica Wolford of Eastern Research Group, Inc. “Discussion of Carbon Disulfide 

Discharges for Innovia Films Inc. (KS0003204).” (April 27). EPA-HQ-OW-2004-0032-

2324. 

10. Schmidtke, Karen and Thomas Holloway. 2000. Industry Profile of the Cellulose 

Products Manufacturing Facilities in the U.S. Prepared for U.S. EPA National Emissions 

Standards for Hazardous Air Pollutants: Cellulose Products Manufacturing. Cary, NC. 

(April 11). EPA-HQ-OAR-2003-0193-0004. 

11. Spontex. 2004. MAPA Spontex, Inc. Wiping Products. Available online at: 

http://www.spontexusa.com/products.cfm?PRTID=1. Date accessed: June 22, 2005. 

EPA-HQ-OW-2004-0032-0269. 

12. TDEC. 2002. Tennessee Department of Environment and Conservation. State of 

Tennessee National Pollutant Discharge Elimination System Permit NPDES TN0001457 

– Viskase Corporation, Loudon, TN. Nashville, TN. EPA-HQ-OW-2004-0032-1207. 

13. TDEC. 2005. Tennessee Department of Environment and Conservation. State of 

Tennessee National Pollutant Discharge Elimination System Permit NPDES Permit 

TN0001571 – Spontex Inc., Columbia, TN. Nashville, TN. 2005. EPA-HQ-OW-2004-

0032-1208. 

14. U.S. Census. 2002. U.S. Economic Census. Available online at: 

http://www.census.gov/econ/census02. 

15. U.S. EPA. 1984. Development Document for Effluent Limitations Guidelines and New 

Source Performance Standards for the Plastics Molding and Forming Point Source 

Category. EPA 440/1-84/069. Washington, DC. (December). 

16. U.S. EPA. 1987. Development Document for Effluent Limitations Guidelines and 

Standards for the Organic Chemical, Plastics, and Synthetic Fibers Point Source 

Category - Final. EPA 4401-87-009. Washington, DC. (October). 

17. U.S. EPA. 2005a. Preliminary Review of Prioritized Categories of Industrial 

Dischargers. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-

0053. 
Section 13 – Plastics Molding and Forming (40 CFR Part 463) 

13-21

18. U.S. EPA. 2005b. Product and Product Group Discharges Subject to Effluent Limitations 

and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source 

Category - 40 CFR 414. Washington, DC. EPA-HQ-OW-2004-0032-0941. 

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

Plan. EPA-821-R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-

2782. 

20. U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent 

Guidelines Program Plan. EPA-821-R-09-006. Washington, DC. (October). EPA-HQOW-2008-0517-0515. 

21. Viskase. 2002. Viskase Companies, Inc. Viskase Casing Solutions Worldwide. Available 

online at: http://www.viskase.com/. Date accessed: June 22, 2005. EPA-HQ-OW-2004-

0032-0264. 
Section 14 – Textile Mills (40 CFR Part 410) 

14-1

14. TEXTILE MILLS (40 CFR PART 410) 

EPA selected the Textile Mills (Textiles) Category for preliminary review because it 

continues to rank high, in terms of toxic-weighted pound equivalent (TWPE), in point source 

category rankings (see Table 5-3 for the point source category rankings). This industry was 

reviewed previously in EPA’s Preliminary and Final 2006 Effluent Guidelines Program Plans 

and the Preliminary 2008 Effluent Guidelines Program Plan (U.S. EPA, 2005; U.S. EPA, 2006; 

U.S. EPA, 2007). This section summarizes the 2010 annual review associated with the Textiles 

Category. EPA focused on discharges of mercury, aluminum, toxaphene, sulfide, and aldrin, 

because of their high TWPE relative to other pollutants in the Textiles Category. 

14.1 Textiles Category Background

 This subsection provides background on the Textiles Category including a brief industry 

profile of the textiles industry and background on 40 CFR Part 410. 

14.1.1 Textiles Industry Profile 

The Textiles Category includes facilities that manufacture and process textile materials, 

such as carpets, broad woven fabrics, and knitwear. It also includes facilities using wet 

processes, such as scouring, dyeing, finishing, printing, and coating, which discharge contact 

wastewater. EPA considered the following 21 North American Industry Classification System 

(NAICS) codes as part of the Textiles Category: 

• 313111: Yarn Spinning Mills; 

• 313112: Yarn Texturizing, Throwing, and Twisting Mills; 

• 313113: Thread Mills; 

• 313210: Broadwoven Fabric Mills; 

• 313221: Narrow Fabric Mills; 

• 313230: Nonwoven Fabric Mills; 

• 313241: Weft Knit Fabric Mills; 

• 313249: Other Knit Fabric and Lace Mills; 

• 313311: Broadwoven Fabric Finishing Mills; 

• 313312: Textile and Fabric Finishing (except Broadwoven Fabric) Mills; 

• 313320: Fabric Coating Mills; 

• 314110: Carpet and Rug Mills; 

• 314992: Tire Cord and Tire Fabric Mills; 

• 314999: All Other Miscellaneous Textile Product Mills; 

• 315111: Sheer Hosiery Mills; 

• 315119: Other Hosiery and Sock Mills; 

• 315191: Outerwear Knitting Mills; 

• 315192: Underwear and Nightwear Knitting Mills; 

• 315992: Glove and Mitten Manufacturing. 

• 315999: Other Apparel Accessories and Other Apparel Manufacturing; and 

• 336360: Motor Vehicle Seating and Interior Trim Manufacturing. 

This list of Standard Industrial Classification (SIC) codes includes facilities that EPA 

determined are potential new subcategories to the Textiles Category. As part of the 2004 annual 

review, EPA reviewed industries with SIC codes not clearly subject to existing effluent 
Section 14 – Textile Mills (40 CFR Part 410) 

14-2

limitation guidelines and standards (ELGs). EPA concluded that the processes, operations, 

wastewaters, and pollutants of facilities in the following SIC codes are similar to those of the 

Textiles Category (U.S. EPA, 2004):23

• 2322: Men’s and Boys’ Underwear and Nightwear; 

• 2396: Automotive Trimmings, Apparel Findings, and Related Products; and 

• 2399: Fabricated Textile Products, Not Elsewhere Classified. 

As part of the 2009 annual review, EPA reclassified these SIC codes as equivalent NAICS codes 

for use with the U.S. Economic Census and Toxics Release Inventory (TRI) data that are 

reported by NAICS code. However, there is not a direct relationship between one SIC and one 

NAICS code. As a result, EPA included the following NAICS codes in the 2010 annual review 

of the Textiles Category because they contain facilities with operations that are similar to the SIC 

codes above: 

• 314999: All Other Miscellaneous Textile Product Mills; and 

• 336360: Motor Vehicle Seating and Interior Trim Manufacturing. 

Because the Permit Compliance System (PCS) and Integrated Compliance Information 

System - National Pollutant Discharge Elimination System (ICIS-NPDES), the sources of the 

discharge monitoring report (DMR) data used to develop DMRLoads2008, report facilities by 

SIC code, and the U.S. Economic Census and TRI report data by NAICS code, EPA reclassified 

the 2008 DMR by the equivalent NAICS code. Table 14-1 lists the number of facilities from the 

U.S. Economic Census and the screening-level databases for the 21 NAICS codes with 

operations in the Textiles Category, the corresponding SIC codes are included for reference. The 

U.S. Economic Census includes more facilities than the screening-level databases because of 

many possible factors including: facilities may not meet TRI-reporting thresholds, facilities may 

discharge to a publicly owned treatment works (POTW), and some facilities in the U.S. 

Economic Census are distributors or sales facilities, not manufacturers. 

 

23 The tables in this section include discharge information from facilities reporting these SIC codes and the 

corresponding NAICS codes; however, these facilities contribute negligible amounts of TWPE. Consistent with the 

conclusions drawn during the 2004 annual review (U.S. EPA, 2004) and the 2006 review (U.S. EPA, 2006), EPA 

found that large numbers of these facilities discharge no wastewater and only a small number of facilities discharge 

TWPE greater than zero. 
Section 14 – Textile Mills (40 CFR Part 410) 

14-3

Table 14-1. Number of Textiles Facilities 

NAICS Code Corresponding SIC Code 

Number of Facilities 

2002 U.S. 

Economic 

Census 

2008 

DMR 

Database a

2008 

TRI 

Database b

313111: Yarn Spinning Mills 

2211: Broadwoven Fabric Mills, 

Cotton; 

2221: Broadwoven Fabric Mills, 

Manmade Fiber and Silk; 

2231: Broadwoven Fabric Mills, Wool;

2241: Narrow Fabric and Other 

Smallware Mills: Cotton, Wool, Silk, 

and Manmade Fiber; 

2251: Women’s Full-Length and KneeLength Hosiery, Except Socks; 

2252: Hosiery, NEC; 

2253: Knit Outerwear Mills; 

2254: Knit Underwear and Nightwear 

Mills; 

2257: Weft Knit Fabric Mills; 

2258: Lace and Warp Knit Fabric 

Mills; 

2259: Knitting Mills, NEC 

2261: Finishers of Broadwoven Fabrics 

of Cotton; 

2262: Finishers of Broadwoven Fabrics 

of Manmade Fiber and Silk; 

2269: Finishers of Textiles, NEC; 

2281: Yarn Spinning Mills; 

2284: Thread Mills; 

2295: Coated Fabrics, Not Rubberized;

2297: Nonwoven Fabrics; 

2299: Textile Goods, NEC 

351 

214 

3 

313113: Thread Mills 87 4 

313210: Broadwoven Fabric 

Mills 762 14 

313221: Narrow Fabric Mills 236 2 

313230: Nonwoven Fabric Mills 264 10 

313312: Textile and Fabric 

Finishing (except Broadwoven 

Fabric) Mills 365 16 

313241: Weft Knit Fabric Mills 180 2 

313249: Other Knit Fabric and 

Lace Mills 182 1 

313311: Broadwoven Fabric 

Finishing Mills 1,006 20 

313320: Fabric Coating Mills 219 53 

315111: Sheer Hosiery Mills 101 0 

315119: Other Hosiery and Sock 

Mills 308 0 

315191: Outerwear Knitting 

Mills 398 0 

315192: Underwear and 

Nightwear Knitting Mills 36 0 

315999: Other Apparel 

Accessories and Other Apparel 

Manufacturing 991 1 

313112: Yarn Texturizing, 

Throwing, and Twisting Mills 

2282: Yarn Texturizing, Throwing, 

Twisting and Winding Mills 142 3 0 

314110: Carpet and Rug Mills 2273: Carpets and Rugs 405 13 30 

314992: Tire Cord and Tire 

Fabric Mills 2296: Tire Cord and Fabrics 25 5 14 

314999: All Other Miscellaneous 

Textile Product Mills 

2298: Cordage and Twine; 

2399: Fabricated Textile Products, 

NEC 2,312 8 8 

336360: Motor Vehicle Seating 

and Interior Trim Manufacturing 

2396: Automotive Trimmings, Apparel 

Findings, and Related Products 387 5 33 

315992: Glove and Mitten 

Manufacturing NA 96 0 1 

Total 8,853 248 212 

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); TRIReleases2008_v3; and DMRLoads2008_v2. 

a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an NAICS-to-SICcode crosswalk for comparison purposes. 

b – Releases to any media. 

NA – Not applicable. 
Section 14 – Textile Mills (40 CFR Part 410) 

14-4

Table 14-2 shows whether permitting authorities designated direct dischargers as minor 

or major (see Section 4.1.5) for facilities in the Textiles Category. EPA included data for minor 

dischargers for the first time in the 2010 annual review, as part of DMRLoads2008_v2 database. 

EPA does not require permitting authorities to submit DMR data for minor dischargers; however, 

many states do provide complete DMR data for them. From this year’s review, EPA observed 

many data entry or other errors for minor dischargers in addition to those previously identified 

for major dischargers, as discussed in Section 4.3. Table 14-2 shows that approximately 79 

percent of the Textiles Category dischargers in the 2008 DMR database are minor dischargers. 

Table 14-2. Number of Textiles Facilities by Discharge Classification in 2008 DMR 

Database 

NAICS Code a 

Number of Facilities in 2008 DMR 

Database 

Major 

Dischargers

Major 

Dischargers 

Major 

Dischargers

313111: Yarn Spinning Mills 

47 167 214 

313113: Thread Mills 

313210: Broadwoven Fabric Mills 

313221: Narrow Fabric Mills 

313230: Nonwoven Fabric Mills 

313312: Textile and Fabric Finishing (except Broadwoven Fabric) 

Mills 

313241: Weft Knit Fabric Mills 

313249: Other Knit Fabric and Lace Mills 

313311: Broadwoven Fabric Finishing Mills 

313320: Fabric Coating Mills 

315111: Sheer Hosiery Mills 

315119: Other Hosiery and Sock Mills 

315191: Outerwear Knitting Mills 

315192: Underwear and Nightwear Knitting Mills 

315999: Other Apparel Accessories and Other Apparel Manufacturing 

313112: Yarn Texturizing, Throwing, and Twisting Mills 0 3 3 

314110: Carpet and Rug Mills 4 9 13 

314992: Tire Cord and Tire Fabric Mills 0 5 5 

314999: All Other Miscellaneous Textile Product Mills 0 8 8 

336360: Motor Vehicle Seating and Interior Trim Manufacturing 0 5 5 

Total 51 197 248 

Source: DMRLoads2008_v2. 

a – DMR data are reported by SIC code; therefore EPA used an NAICS to SIC crosswalk for comparison purposes. 

Table 14-3 presents the type of discharges reported by facilities in the 2008 TRI database. 

The majority of textile facilities reporting to TRI do not report water discharges, but those that 

do mostly reported discharging indirectly. 
Section 14 – Textile Mills (40 CFR Part 410) 

14-5

Table 14-3. Number Textiles Facilities by Discharge Type in 2008 TRI Database 

NAICS Code 

Number of Facilities in 2008 TRI Database 

Direct 

Dischargers 

Only 

Direct 

Dischargers 

Only 

Direct 

Dischargers 

Only 

Direct 

Dischargers 

Only 

313111: Yarn Spinning Mills 0 0 0 3 

313113: Thread Mills 0 2 0 2 

313210: Broadwoven Fabric Mills 0 2 1 11 

313221: Narrow Fabric Mills 0 1 0 1 

313230: Nonwoven Fabric Mills 0 3 1 6 

313312: Textile and Fabric Finishing (except 

Broadwoven Fabric) Mills 1 9 1 5 

313241: Weft Knit Fabric Mills 0 1 0 1 

313249: Other Knit Fabric and Lace Mills 0 0 0 1 

313311: Broadwoven Fabric Finishing Mills 3 6 0 11 

313320: Fabric Coating Mills 0 7 1 45 

315111: Sheer Hosiery Mills 0 0 0 0 

315119: Other Hosiery and Sock Mills 0 0 0 0 

315191: Outerwear Knitting Mills 0 0 0 0 

315192: Underwear and Nightwear Knitting Mills 0 0 0 0 

315999: Other Apparel Accessories and Other 

Apparel Manufacturing 0 1 0 0 

313112: Yarn Texturizing, Throwing, and Twisting 

Mills 0 0 0 0 

314110: Carpet and Rug Mills 0 10 0 20 

314992: Tire Cord and Tire Fabric Mills 1 5 3 5 

314999: All Other Miscellaneous Textile Product 

Mills 0 1 0 7 

336360: Motor Vehicle Seating and Interior Trim 

Manufacturing 0 2 0 31 

315992: Glove and Mitten Manufacturing 0 1 0 0

Total 5 51 7 149 

Source: TRIReleases2008_v3. 

14.1.2 40 CFR Part 414 

EPA first promulgated ELGs for the Textiles Category (40 CFR Part 410) on September 

2, 1982 (47 FR 38819). There are nine subcategories, all of which have best practicable control 

technology (BPT), best available technology economically achievable (BAT), and new source 

performance standards (NSPS) limitations. Some subcategories also have pretreatment standards 

for existing sources (PSES), and pretreatment standards for new sources (PSNS) limitations. 

Table 9-4 lists the nine subcategories and applicability. Table 14-4 in the Technical Support 

Document for the 2006 Effluent Guidelines Program Plan lists the regulated pollutants for the 

subcategories (U.S. EPA, 2006). 
Section 14 – Textile Mills (40 CFR Part 410) 

14-6

Table 14-4. Applicability of Subcategories in the Textiles Category 

Subpart Subcategory Title Subcategory Applicability 

A Wool Scouring Wool scouring, topmaking, and general cleaning of raw wool 

B Wool Finishing Wool finishers, including carbonizing, fulling, dyeing, bleaching, 

rinsing, fireproofing, and other such similar processes 

C Low Water Use Processing Yarn manufacture, yarn texturizing, unfinished fabric manufacture, 

fabric coating, fabric laminating, tire cord and fabric dipping, and 

carpet tufting and carpet backing 

D Woven Fabrics Finishing Woven fabric finishers, which may include any or all of the 

following unit operations: desizing, bleaching, mercerizing, dyeing, 

printing, resin treatment, water proofing, flame proofing, soil 

repellency application and a special finish application 

E Knit Fabric Finishing Knit fabric finishers, which may include any or all of the following 

unit operations: bleaching, mercerizing, dyeing, printing, resin 

treatment, water proofing, flame proofing, soil repellency 

application and a special finish application 

F Carpet Finishing Carpet mills, which may include any or all of the following unit 

operations: bleaching, scouring, carbonizing, fulling, dyeing, 

printing, resin treatment, waterproofing, flameproofing, soil 

repellency, looping, and backing with foamed and unfoamed latex 

and jute 

G Stock & Yarn Finishing Stock or yarn dyeing or finishing, which may include any or all of 

the following unit operations and processes: cleaning, scouring, 

bleaching, mercerizing, dyeing and special finishing 

H Nonwoven Manufacturing Facilities that primarily manufacture nonwoven textile products of 

wool, cotton, or synthetics, singly or as blends, by mechanical, 

thermal, and/or adhesive bonding procedures 

I Felted Fabric Processing Facilities that primarily manufacture nonwoven products by 

employing fulling and felting operations as a means of achieving 

fiber bonding 

Source: Textile Mills Point Source Category – 40 CFR 410; Development Document for Effluent Limitations 

Guidelines and Standards for the Textile Mills Point Source Category (U.S. EPA, 1979). 

14.2 Textiles Category 2010 Screening-Level Review

Table 14-5 compares the screening-level database results for the Textiles Category from 

the 2006 through 2010 annual reviews that represented multiple years of data from the DMR and 

TRI databases. The combined DMR and TRI TWPE decreased from discharge years 2004 to 

2007, but increased from discharge years 2007 to 2008. The discharge year 2008 DMR TWPE 

accounts for approximately 42 percent of the combined 2008 DMR and TRI TWPE, similar to 

previous years. 
Section 14 – Textile Mills (40 CFR Part 410) 

14-7

Table 14-5. Textiles Category TRI and DMR Discharges for the 2006 through 2010 

Screening-Level Reviews 

Year of Discharge Year of Review 

Textiles Category 

TRI TWPE DMR TWPE a Total TWPE 

2002 2006 3,710 123,000 127,000 

2004 2007 3,040 123,000 126,000 

2005 2008 3,040 NA NA 

2007 2009 2,390 79,900 82,300 

2008 2010 2,750 247,000 250,000 

Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; 

TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; and DMRLoads2008_v2. 

a – DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and 

major dischargers. 

NA – Not applicable. EPA did not evaluate DMR data for 2005. 

Table 14-6 presents the 2008 DMR TWPE by facility discharge classification. EPA 

excluded minor dischargers from previous annual reviews, but included them in the 2010 annual 

review. The majority (72 percent) of the TWPE in the 2008 DMR database results from major 

dischargers. 

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

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers 

2008 68,200 179,000 

Source: DMRLoads2008_v2. 

a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous 

annual reviews. 

14.3 Textiles Pollutants of Concern

Table 14-7 compares the five chemicals with the highest TWPE in the 2008, 2007, and 

2004 TRI databases (TRIReleases2008_v3, TRIReleases2007_v2, and TRIReleases2004_ v3). 

Table 14-8 lists the five pollutants with the highest TWPE in the 2008, 2007, and 2004 DMR 

databases (DMRLoads2008_v2, DMRLoads2007_v3, and PCSLoads2004_v4). 
Section 14 – Textile 

14-8

Table 14-7. Textiles Category Top TRI Pollutants 

Pollutant 

2004 a 2007 a 

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Ammonia 

Pollutants not reported in the top five 

2004 TRI reported pollutants. 

1 9 970 1 

Lead and Lead Compounds 

Pollutant not reported in the top five 

2007 TRI reported pollutants. 2 

Copper and Copper Compounds 1 12 843 2 9 511 3 Chlorine Dioxide 2 1 639 3 1 204 4 Nitrate Compounds 3 5 268 4 6 164 5 Di(2-ethylhexyl) phthalate 

Pollutant not reported in the top five 

2004 TRI reported pollutants. 5 1 106 

Pollutants no

2008 TR

Antimony and Antimony Compounds 4 18 192 Pollutants not reported in the top five 2007 TRI reported pollutants. Zinc and Zinc Compounds 5 13 173 Textiles Category Total NA 83 b 3,040 NA 61 b 2,390 NA 

Source: TRIReleases2004_v3; TRIReleases2007_v2; and TRIReleases2008_v3. 

a – Discharges include transfers to POTWs and account for POTW removals. b – Number of facilities reporting TWPE greater than zero. NA – Not applicable. 
Section 14 – Textile 

14-9

Table 14-8. Textiles Category Top DMR Pollutants 

Pollutant 

2004 a 2007 a 

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

N

R

Mercury 

Pollutants not reported in the top five 2004 

DMR reported pollutants. 

4 3 296 1 

Aluminum 

Pollutants not reported in the top five 2007 

DMR reported pollutants. 

2 

Toxaphene 3 Sulfide 1 35 117,000 4 Aldrin 

Pollutant not reported in the top five 2004 

DMR reported pollutants. 1 1 76,400 5 

Chlorine 2 18 3,440 2 16 1,680 

Pollutants not re

DMR re

Copper 3 24 1,270 3 18 583 Chromium 

Pollutant not reported in the top five 2004 

DMR reported pollutants. 5 3 184 

Chloride 4 14 340 

Pollutant not reported in the top five 2007 

DMR reported pollutants. Nitrogen, Kjeldahl Total (as N) 5 5 209 

Textiles Category Total NA 62 c 123,000 NA 46 c 79,900 NA 

Source: PCSLoads2004_v4; DMRLoads2007_v3; and DMRLoads2008_v2. 

a – 2004 and 2007 DMR data include only major dischargers. b – 2008 DMR data includes major and minor dischargers. c – Number of facilities reporting TWPE greater than zero. NA – Not applicable.
Section 14 – Textile Mills (40 CFR Part 410) 

14-10

The majority of the Textiles Category total TWPE (over 98 percent) is based on 

discharges in the 2008 DMR database. Therefore, EPA focused the preliminary category review 

on the DMR-reported pollutants that account for the majority of the category TWPE. 

EPA’s additional review for the 2008 DMR database pollutants of concern, mercury, 

aluminum, toxaphene, sulfide, and aldrin, is presented in the following sections. During the 

review of top pollutants, EPA discovered that the majority of the top pollutants were discharged 

from the same three facilities in the 2008 DMR database. Table 14-9 presents the top discharging 

facilities and top pollutants in the Textiles Category. The following subsections provide details 

on EPA’s review of the 2008 DMR database discharges. 

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

Top Pollutant Facility Name 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Total 

Facility 

TWPE 

Mercury Kawashima Textile USA, Inc. 1,151 135,000 135,000 

Aluminum 

Kannapolis Water Treatment 

Plant 571,000 34,300 35,000 

Toxaphene 

Mohawk Industries/ Oak River 

Plant 1.09 33,100 32,800 

Sulfide Mohawk Industries, Inc. 5,060 14,200 14,200 

Aldrin Deroyal Textiles 0.853 9,500 9,510 

Source: DMRLoads2008_v2. 

14.4 Textiles Category Top Facility Dischargers in DMR

This subsection provides further detail on the top five facility dischargers in the Textiles 

Category responsible for the majority of the mercury, aluminum, toxaphene, sulfide and aldrin 

TWPE. As a result of EPA’s identification of data errors, of discharges from the top facilities in 

the Textiles Category, the overall category 2008 DMR TWPE decreased by over 170,000 TWPE 

from 250,000 TWPE to 78,500 TWPE. 

14.4.1 Kawashima Textile USA, Inc. in Camden, SC 

Table 14-10 presents the discharges in the 2008 DMR database for Kawashima Textile 

USA, Inc. The majority of the facility TWPE (approximately 100 percent) is from mercury. 

Mercury discharges from Kawashima Textile also account for approximately 54 percent of the 

DMR TWPE for the Textiles Category. 
Section 14 – Textile Mills (40 CFR Part 410) 

14-11

Table 14-10. Kawahima Textile 2008 Top Discharges in the DMR Database 

Pollutant Total Pounds Total TWPE 

Percent of Facility Total 

TWPE 

Mercury 1,150 135,000 100% 

Iron 106 0.59 0% 

Ammonia 255 0.28 0% 

Manganese 3.06 0.21 0% 

Phosphorous 0.77 0.00 0% 

Total 1,510 135,000 100% 

Source: DMRLoads2008_v2. 

All of the pollutant discharges for Kawashima Textile USA are from outfall 002. Table 

14-11 presents the discharge data in the DMR Loadings Tool for 2008, along with the data from 

EPA’s Envirofacts24. EPA determined that January, June, July, and August 2008 mercury 

concentrations had data errors. Using the corrected concentrations, EPA calculated the revised 

load and corresponding TWPE for mercury. The facility’s mercury discharges decrease from 

135,000 TWPE to 0.9 TWPE, while the facility’s total TWPE decreased from 135,000 TWPE to 

2 TWPE, a reduction of almost 100 percent. 

Table 14-11. Kawashima Textile USA 2008 Monthly Mercury and Flow Discharge Data 

Outfall Pollutant 

Monitoring 

Period Date a 

DMR Loadings Tool 

Average 

Concentration (mg/L)

Envirofacts Average 

Concentration (mg/L) Average Flow (MGD)

002 Mercury 31-Jan-08 4.0000188 0.0000188 0.2997 

002 Mercury 29-Feb-08 0.000012 0.000012 0.2793 

002 Mercury 31-Mar-08 0.000013 0.000013 0.2173 

002 Mercury 30-Apr-08 0.000011 0.000011 0.1954 

002 Mercury 31-May-08 0.00011 0.00011 0.2563 

002 Mercury 30-Jun-08 4.0000042 0.0000042 0.2751 

002 Mercury 31-Jul-08 4.0000048 0.0000048 0.2548 

002 Mercury 31-Aug-08 4.0000061 0.0000061 0.2915 

Source: DMR Loadings Tool and Envirofacts. 

a – The DMR Loadings Tool and Envirofacts do not have mercury concentrations for Kawashima Textile USA for 

September, October, November, and December 2008. 

14.4.2 Kannapolis Water Treatment Plant in Kannapolis, NC 

Table 14-12 presents the discharges in the 2008 DMR database for Kannapolis Water 

Treatment Plant (WTP). The majority of the facility TWPE (almost 98 percent) is from 

discharges of aluminum. Aluminum discharges from Kannapolis WTP also account for 

approximately 14 percent of the DMR TWPE for the Inorganic Chemicals Category. 

 

24 EPA uses the data in Envirofacts as a source while reviewing the DMR Loadings Tool data because Envirofacts 

continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not 

continuously updated; therefore, loads may be estimated with erroneous data. 
Section 14 – Textile Mills (40 CFR Part 410) 

14-12

Table 14-12. Kannapolis WTP 2008 Top Discharges in the DMR Database 

Pollutant Total Pounds TWPE 

Percent of Facility 

TWPE 

Aluminum 571,000 34,300 97.90% 

Iron 109,000 611 1.75% 

Manganese 1,740 122 0.35% 

Calcium 6,270 0.18 0.00% 

Magnesium 70.6 0.06 0.00% 

Total 688,000 35,000 100% 

Source: DMRLoads2008_v2. 

All of Kannapolis WTP’s aluminum discharges are from outfall 001. Table 14-13

presents the aluminum discharge data in the DMR Loadings Tool for 2008, along with the data 

from EPA’s Envirofacts. EPA determined that aluminum concentrations for January through 

November 2008 were in the DMR Loadings Tool as mg/L, but in Envirofacts as μg/L. Using the 

corrected concentrations, EPA calculated the revised load and corresponding TWPE for 

aluminum. The facility’s aluminum discharges decrease from 34,300 TWPE to 36 TWPE, while 

the facility’s total TWPE decreases from 34,900 TWPE to 769 TWPE, a reduction of almost 100 

percent. 

Table 14-13. Kannapolis WTP 2008 Monthly Aluminum Discharge Data 

Outfall Pollutant 

Monitoring 

Period Date 

DMR Loadings Tool Average 

Concentration (mg/L) 

Envirofacts Average 

Concentration 

(μg/L) (mg/L) 

001 Aluminum 31-Jan-08 659.8 659.8 0.6598 

001 Aluminum 29-Feb-08 911.25 911.25 0.91125 

001 Aluminum 31-Mar-08 887.5 887.5 0.8875 

001 Aluminum 30-Apr-08 537 537 0.537 

001 Aluminum 31-May-08 411.75 411.75 0.41175 

001 Aluminum 30-Jun-08 657.25 657.25 0.65725 

001 Aluminum 31-Jul-08 608.4 608.4 0.6084 

001 Aluminum 31-Aug-08 626.25 626.25 0.62625 

001 Aluminum 30-Sep-08 1,339 1,339 1.339 

001 Aluminum 31-Oct-08 491.6 491.6 0.4916 

001 Aluminum 30-Nov-08 440 440 0.440 

001 Aluminum 31-Dec-08 0.333 333 0.33 

Source: DMR Loadings Tool and Envirofacts. 

14.4.3 Mohawk Industries Oak River Plant in Bennettsville, SC 

Table 14-14 presents the discharges for Mohawk Industries Oak River Plant in the 2008 

DMR database. The majority of the TWPE is from toxaphene (approximately 99 percent). 

Toxaphene discharges from Mohawk Industries Oak River Plant also account for approximately 

13 percent of the DMR TWPE for the Textiles Category. 
Section 14 – Textile Mills (40 CFR Part 410) 

14-13

Table 14-14. Mohawk Industries Oak River Plant 2008 Top Discharges in the DMR 

Database 

Pollutant Total Pounds TWPE Percent of Facility TWPE

Toxaphene 1.09 32,800 99.2% 

Sulfur 92.1 258 0.78% 

Chlorine 28.1 14.0 0.04% 

Ammonia 72.0 0.08 0.00% 

Chromium 0.88 0.06 0.00% 

Total 194 33,100 100% 

Source: DMRLoads2008_v2. 

Mohawk Industries Oak River Plant reports toxaphene discharges from outfall 001. Table 

14-15 presents the discharge data in the DMR Loadings Tool for 2008. EPA contacted the 

facility to confirm the 2008 toxaphene discharges. Mohawk Industries Oak River Plant stated 

that the concentrations were correct and that the December 2008 toxaphene concentration was 

<0.0005 mg/L. Mohawk Industries Oak River Plant also indicated that the chemical is not used 

as a raw material or in any other chemicals at the facility (Wood, 2010). The South Carolina 

Department of Health and Environmental Control (SC DHEC) requires Mohawk to monitor for 

toxaphene because recent water quality data found it at detectable concentrations. The facility 

must monitor toxaphene to determine if a limit is necessary (Vickers, 2010). 

EPA evaluated available 2009 and 2010 toxaphene data from Envirofacts, presented in 

Table 14-16, and determined that all concentrations were reported below detection limit (BDL). 

SC DHEC is monitoring toxaphene discharges, and all 2009 and 2010 discharges are BDL, and 

EPA will continue reviewing the discharge data for this facility. 
Section 14 – Textile Mills (40 CFR Part 410) 

14-14

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

Data 

Outfall Pollutant 

Monitoring 

Period Date 

DMR Loadings 

Tool 

Concentration 

(mg/L) 

Facility-Provided 

Concentration 

(mg/L) 

Average Flow 

(MGD) 

001 Toxaphene 31-Jan-08 < 0.0005 < 0.0005 0.093487 

001 Toxaphene 29-Feb-08 < 0.0005 < 0.0005 0.108851 

001 Toxaphene 31-Mar-08 < 0.0025 < 0.0025 0.070074 

001 Toxaphene 30-Apr-08 0.0025 0.0025 0.09694 

001 Toxaphene 31-May-08 0.0005 0.0005 0.073806 

001 Toxaphene 30-Jun-08 < 0.0005 < 0.0005 0.08753 

001 Toxaphene 31-Jul-08 < 0.0005 < 0.0005 0.131065 

001 Toxaphene 31-Aug-08 < 0.0005 < 0.0005 0.164852 

001 Toxaphene 30-Sep-08 < 0.05 < 0.05 0.158837 

001 Toxaphene 31-Oct-08 < 0.0005 < 0.0005 0.1335 

001 Toxaphene 30-Nov-08 < 0.0005 < 0.0005 NR 

001 Toxaphene 31-Dec-08 NR < 0.0005 NR 

Source: DMR Loadings Tool and Facility Contact (Wood, 2010). 

NR – Not reported. 

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

Discharge Data 

Outfall Pollutant Monitoring Period Date 

Envirofacts 

Concentration (mg/L) 

001 Toxaphene 31-Jan-09 < 0.00055 

001 Toxaphene 29-Feb-09 < 0.0005 

001 Toxaphene 31-Mar-09 < 0.0005 

001 Toxaphene 30-Apr-09 < 0.0001 

001 Toxaphene 31-May-09 < 0.00055 

001 Toxaphene 30-Jun-09 < 0.00055 

001 Toxaphene 31-Jul-09 < 0.0005 

001 Toxaphene 31-Aug-09 < 0.0003 

001 Toxaphene 30-Sep-09 < 0.0005 

001 Toxaphene 31-Oct-09 < 0.0005 

001 Toxaphene 30-Nov-09 < 0.0005 

001 Toxaphene 31-Dec-09 < 0.0005 

001 Toxaphene 31-Jan-10 < 0.0005 

001 Toxaphene 29-Feb-10 < 0.0005 

001 Toxaphene 31-Mar-10 < 0.0005 

001 Toxaphene 30-Apr-10 < 0.005 

001 Toxaphene 31-May-10 < 0.0005 

001 Toxaphene 30-Jun-10 < 0.00055 

Source: Envirofacts 
Section 14 – Textile Mills (40 CFR Part 410) 

14-15

14.4.4 Mohawk Industries, Inc. in Lyerly, GA 

Table 14-17 presents the discharges for Mohawk Industries in the 2008 DMR database. 

Almost all of the TWPE is from sulfide. Sulfide discharges from Mohawk Industries also 

account for approximately 6 percent of the DMR TWPE for the Textiles Category. 

Table 14-17. Mohawk Industries 2008 Top Discharges in the DMR Database 

Pollutant Total Pounds TWPE Percent of Facility TWPE

Sulfide 5,100 14,200 99.98% 

Chromium 40.4 2.83 0.02% 

Total 5,140 14,200 100% 

Source: DMRLoads2008_v2. 

All of Mohawk Industries sulfide discharges are from outfalls 0A1. Table 14-18 presents 

the discharge data in the DMR Loadings Tool and the back-calculated concentrations associated 

with each sulfide quantity. EPA calculated the sulfide concentrations using the average quantity 

and flow provided in the 2008 DMR Loadings Tool. EPA contacted the facility to verify the 

sulfide quantities in the 2008 DMR database. Mohawk Industries confirmed that the sulfide 

quantities were correct and that the permit limit for sulfide is 11 kg/day (Wood, 2010). Mohawk 

Industries stated that sulfide present in the wastewater may be from boiler treatment chemicals 

and wastewater treatment chemicals used to treat intake water for hardness (Wood, 2010). The 

sulfide quantities are below permit limits, therefore, the facility’s sulfide discharges are not a 

concern for the 2010 annual review. 

Table 14-18. Mohawk Industries 2008 Monthly Sulfide Discharge Data 

Outfall Pollutant 

Monitoring Period 

Date 

DMR Loadings 

Tool Average 

Quantity (kg/day) 

Calculated Sulfide 

Concentrations 

(mg/L) 

Average Flow 

(MGD) 

0A1 Sulfide 31-Jan-08 6.08 1.2 1.323 

0A1 Sulfide 30-Apr-08 8.31 1.3 1.659 

0A1 Sulfide 31-Jul-08 7.61 1.9 1.025 

0A1 Sulfide 31-Oct-08 2.83 1.1 0.723 

Source: DMR Loadings Tool and Facility Contact (Wood, 2010). 

14.4.5 Deroyal Textiles in Camden, SC 

Table 14-19 presents the discharges for Deroyal Textiles in the 2008 DMR database. 

Almost all of the TWPE is from aldrin. Aldrin discharges from Deroyal Textiles also account for 

approximately 4 percent of the DMR TWPE for the Textiles Category. 
Section 14 – Textile Mills (40 CFR Part 410) 

14-16

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

Pollutant Total Pounds TWPE Percent of Facility TWPE

Aldrin 0.85 9,500 99.9% 

Sulfur 2.05 5.74 0.06% 

Hydrogen sulfide 0.45 1.27 0.01% 

Chromium 3.93 0.28 0.00% 

Ammonia 140 0.16 0.00% 

Total 147 9,500 100% 

Source: DMRLoads2008_v2. 

All of the aldrin discharges are from outfall 001. Table 14-20 presents the discharge data 

in the DMR Loadings Tool for 2008. EPA contacted Deroyal Textiles to verify the aldrin 

concentrations. Deroyal Textiles indicated that the facility made a conversion error with the 

March 2008 DMR data and the aldrin concentration was reported in μg/L instead of mg/L 

although the units were reported as mg/L (Gettys, 2010). Using the facility-provided 

concentrations, EPA calculated the revised load and corresponding TWPE for aldrin. The 

facility’s aldrin discharges decrease from 9,500 TWPE to 353 TWPE, while the facility’s total 

TWPE decreases from 9,510 TWPE to 361 TWPE, a reduction of over 96 percent. 

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

Outfall Pollutant 

Monitoring Period 

Date 

DMR Loadings 

Tool Average 

Concentration 

(mg/L) 

Facility-Provided 

Average 

Concentration 

(mg/L) 

Average Flow 

(MGD) 

001 Aldrin 31-Jan-08 0 0 0.08 

001 Aldrin 29-Feb-08 0 0 0.102 

001 Aldrin 31-Mar-08 0.034 0.000034 0.088 

001 Aldrin 30-Apr-08 0.00023 0.00023 0.087 

001 Aldrin 31-May-08 0.000011 0.000011 0.07 

001 Aldrin 30-Jun-08 0.000116 0.000116 0.073 

001 Aldrin 31-Jul-08 NR NR 0.065 

001 Aldrin 31-Aug-08 0 0 0.061 

001 Aldrin 30-Sep-08 0 0 0.038 

001 Aldrin 31-Oct-08 0 0 0.037 

001 Aldrin 30-Nov-08 0 0 0.017 

001 Aldrin 31-Dec-08 0.000019 0.000019 0.026 

Source: DMR Loadings Tool and Facility Contact (Gettys, 2010). 

NR – Not reported. The aldrin data for July 2008 includes the NODI code E – analysis not conducted. 

14.5 Textiles Category Conclusions

The estimated toxicity of the Textile Mills Category discharges result from mercury, 

aluminum, toxaphene, sulfide, and aldrin discharges. Data collected for the 2010 annual review 
Section 14 – Textile Mills (40 CFR Part 410) 

14-17

demonstrated that wastewater discharge characteristics for this category are consistent with 

discharges from prior years. As in prior years, EPA makes the following conclusions: 

• There were data errors in the mercury concentrations for Kawashima Textile 

USA. Correcting this error decreases the 2008 facility TWPE to 2 TWPE. 

• There was a units error for the aluminum concentrations for Kannapolis WTP. 

Correcting this error decreases the 2008 facility TWPE to 769 TWPE. 

• The screening-level data for toxaphene discharges from Mohawk Industries Oak 

River Plant are accurate. The facility does not use toxaphene and is unable to 

identify the source of the pesticide. SC DHEC requires the facility to continue 

monitoring for toxaphene, and EPA will continue reviewing toxaphene discharges 

from this facility as part of future reviews. 

• Sulfide discharges from Mohawk Industries in Lyerly, GA are below the permit 

limit. EPA will continue monitoring sulfide discharges from this facility as part of 

future reviews. 

• There was a units error for the March 2008 aldrin concentration for Deroyal 

Textiles. Correcting this error decreases the 2008 facility TWPE to 361 TWPE. 

• Correcting the database errors identified during the 2010 annual review decreases 

the 2008 Textile Mills Category TWPE from 250,000 TWPE to 78,500 TWPE. 

EPA will continue to monitor the Textile Mills Category discharges to determine 

if they are properly controlled. 

EPA prioritizes point source categories with existing regulations for potential revision 

based on the greatest estimated toxicity to human health and the environment, measured as 

TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for 

revision (i.e., this category is marked with “(3)” in the “Findings” column in Table V-1 in the 

Federal Register notice that presents the 2010 annual review of existing ELGs). 

14.6 Textiles Category References

1. Gettys, John. 2010. E-mail Communication with John Gettys, Deroyal Textiles, and 

Lauren Wingo, Eastern Research Group, Inc. “RE: DMRs Clarification Needed for 

Deroyal Textiles - SC0002518.” (September 7). EPA-HQ-OW-2008-0517 DCN 07302. 

2. U.S. Census. 2002. U.S. Economic Census. Available online at: 

http://www.census.gov/econ/census02. 

3. U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program 

Plan. EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346 

through 1352. 
Section 14 – Textile Mills (40 CFR Part 410) 

14-18

4. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial 

Dischargers. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-

0016. 

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

Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782. 

6. U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent 

Guidelines Program Plan. EPA-821-R-07-007. Washington, DC. (October). EPA-HQOW-2006-0771-0819. 

7. Vickers, Melinda. 2010. Telephone communication with Melinda Vickers, South 

Carolina Department of Health and Environmental Control (SC DHEC), and Elizabeth 

Sabol, Eastern Research Group, Inc. “Re: DMR Clarification for Toxaphene Discharges 

from Mohawk Industries Oak River Plant.” (September 23). EPA-HQ-OW-2008-0517 

DCN 07308. 

8. Wood, Denise. 2010. Telephone and E-mail communication with Denise Wood, Mohawk 

Industries, and Elizabeth Sabol and Lauren Wingo, Eastern Research Group, Inc. “Re: 

DMR Clarification Needed for Mohawk Industries Oak River Plant and Lyerly Plant.” 

(September 2). EPA-HQ-OW-2008-0517 DCN 07309. 
Section 15 – Waste Combustors (40 CFR Part 444) 

15-1

15. WASTE COMBUSTORS (40 CFR PART 444) 

EPA selected the Waste Combustors Category (40 CFR Part 444) for preliminary review 

because it ranked high, in terms of toxic-weighted pound equivalent (TWPE) (see Table 5-3 for 

the point source category rankings). The Final 2008 Plan summarizes the results of EPA’s 

previous review of this industry in 2008 (72 FR 61335). This section summarizes the results of 

the 2010 annual review associated with the Waste Combustors Category. EPA focused on 

discharges of hexachlorophene, because of its high TWPE relative to the rest of the Waste 

Combustors Category. 

15.1 Waste Combustors Category Background 

This subsection provides background on the Waste Combustors Category including a 

brief profile of the waste combustors industry and background on 40 CFR Part 444. 

15.1.1 Waste Combustors Industry Profile 

The waste combustors industry includes facilities that recover energy from or dispose of 

wastes (both hazardous and nonhazardous) by incineration (U.S. EPA, 2008). EPA considered 

the following four North American Industry Classification System (NAICS) codes as part of the 

Waste Combustors Category: 

• 562211: Hazardous Waste Treatment and Disposal; 

• 562213: Solid Waste Combustors and Incinerators; 

• 562219: Other Nonhazardous Waste Treatment and Disposal; and 

• WC: Waste Combustors. 

Wastewater generated by facilities in NAICS codes 562211, 562213, and 562219 may be 

regulated under the Centralized Waste Treatment (CWT) (40 CFR Part 437), Landfills (40 CFR 

Part 445) (see Section 8), and/or Waste Combustors Categories. EPA reviewed available 

information about pollutant load and manufacturing operations for facilities reporting these 

NAICS codes. In its crosswalk, EPA assigned the “WC” NAICS code for facilities that most 

likely fall under the applicability of 40 CFR Part 444, Waste Combustors. 

Because the Permit Compliance System (PCS) and Integrated Compliance Information 

System - National Pollutant Discharge Elimination System (ICIS-NPDES), the sources of the 

discharge monitoring report (DMR) data used to develop DMRLoads2008, report facilities by 

Standard Industrial Classification (SIC) code, and the U.S. Economic Census and Toxics Release 

Inventory (TRI) report data by NAICS code, EPA reclassified the 2008 DMR by the equivalent 

NAICS code. Table 15-1 lists the number of facilities from the U.S. Economic Census and the 

screening-level databases for the four NAICS codes with operations in the Waste Combustors 

Category; the corresponding SIC codes are included for reference. The U.S. Economic Census 

includes more facilities than the screening-level databases because of many possible factors 

including: facilities may not meet TRI-reporting thresholds, facilities may discharge to a publicly 

owned treatment works (POTW), and some facilities in the U.S. Economic Census are 

distributors or sales facilities, not manufacturers. 
Section 15 – Waste Combustors (40 CFR Part 444) 

15-2

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

NAICS Code 

Corresponding 

SIC Code 

Number of Facilities 

2002 U.S. 

Economic Census

2008 DMR 

Database a

2008 TRI 

Database b

562211: Hazardous Waste 

Treatment and Disposal 

4953: Refuse 

Systems 

4953WC c

: Refuse 

Systems (Waste 

Combustors) 

701 1,217 53 

562213: Solid Waste 

Combustors and Incinerators 

120 1 

562219: Other Nonhazardous 

Waste Treatment and Disposal 

199 5 

WC: Waste Combustors NA 6 

Total >1,020 1,217 65 

Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2; and TRIReleases2008_v3. 

a – Major and minor dischargers. Also, DMR data are reported by SIC code; therefore EPA used an NAICS-to-SICcode crosswalk for comparison purposes. 

b – Facilities reporting releases to any media. 

c – Wastewater generated by facilities in SIC code 4953 may be regulated under the CWT, Landfills, and Waste 

Combustors Categories. In its crosswalk, EPA assigned the extension “WC” to the end of the SIC code for facilities 

that most likely fall under the applicability of the Waste Combustors Effluent Limitation Guidelines and Standards 

(ELGs). 

NA – Not applicable. These facility-specific NAICS codes assigned as part of the annual review do not correspond 

to NAICS codes in the 2002 U.S. Economic Census.

Table 15-2 shows whether permitting authorities designated direct discharging facilities 

in the Waste Combustors Category as minor or major dischargers (see Section 4.1.5). EPA 

included data for minor dischargers for the first time in the 2010 annual review, as part of 

DMRLoads2008_v2. EPA does not require permitting authorities to submit DMR data for minor 

dischargers; however, many states do provide complete DMR data for minor dischargers. From 

the 2010 annual review, EPA observed many data entry or other errors for minor dischargers in 

addition to those previously identified for major dischargers, as discussed in Section 4.3. Table 

15-2 shows that approximately 99 percent of the Waste Combustor Category dischargers in the 

2008 DMR database are minor dischargers. 

Table 15-2. Number of Waste Combustor Facilities by Type of Discharger in DMR 2008 

Majors Dischargers Minors Dischargers Total 

8 1,210 a 1,217 

Source: DMRLoads2008_v2. 

a – The DMR data in PCS and ICIS-NPDES does not include discharge data for all minor dischargers. For the 

facilities in the Waste Combustor Category, 301 of the 1,210 minor dischargers have DMR data. 

Note: Includes waste combustors reported in both SIC codes 4953 and 4953WC. 

Table 15-3 presents the type of discharges reported by facilities in the 2008 TRI database. 

The majority of waste combustor facilities reporting to TRI do not report water discharges, but 

those that do mostly reported direct discharges to surface waters. 
Section 15 – Waste Combustors (40 CFR Part 444) 

15-3

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

NAICS Code 

Number of Facilities in 2008 TRI Database 

Direct 

Dischargers 

Only 

Indirect 

Dischargers 

Only 

Both 

Indirect and 

Direct 

No Water 

Discharges 

562211: Hazardous Waste Treatment and Disposal 4 4 1 44 

562213: Solid Waste Combustors and Incinerators 1 0 0 0 

562219: Other Nonhazardous Waste Treatment and 

Disposal 2 0 0 3 

WC: Waste Combustors 4 0 0 2 

Total 11 4 1 49 

Source: TRIReleases2008_v3. 

15.1.2 40 CFR Part 444 

EPA first promulgated ELGs for the Waste Combustors Category (40 CFR Part 444) on 

January 27, 2000 (65 FR 4381). The Waste Combustors ELGs apply to wastewater discharges 

from hazardous waste combustors, except cement kilns, regulated as “incinerators” or “boilers 

and industrial furnaces” under the Resource Conservation and Recovery Act (RCRA). The rule 

applies solely to commercial facilities (i.e., facilities that accept wastes from off-site for fee or 

remuneration). At the time of promulgation, EPA estimated that the rule would apply to eight 

facilities (U.S. EPA, 2000). Table 15-4 lists the pollutants regulated by Part 444. 

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

Subpart Name Subpart Applicability Regulated Pollutants 

A: Commercial 

Hazardous Waste 

Combustor 

(CWHC) 

The discharge of wastewater from a CHWC facility 

including any thermal unit, except a cement kiln, if the 

thermal unit burns RCRA hazardous wastes received 

from off-site for a fee or other remuneration in the 

following circumstances. The thermal unit is a 

commercial hazardous waste combustor if the off-site 

wastes are generated at a facility not under the same 

corporate structure or subject to the same ownership as 

the thermal unit. 

TSS, pH, Arsenic, Cadmium, 

Chromium, Copper, Lead, 

Mercury, Silver, Titanium, and 

Zinc 

Source: 40 CFR Part 444; Development Document for Final Effluent Limitations Guidelines and Standards for 

Commercial Hazardous Waste Combustors (U.S. EPA, 2000). 

15.2 Waste Combustors Category Screening Level Review

Table 15-5 shows the screening-level results for the Waste Combustors Category from 

the 2005, 2007, and 2008 TRI and DMR databases. The Waste Combustors Category was 

excluded from annual reviews prior to 2008 because EPA promulgated the ELGs on January 27, 

2000. The TRI TWPE increased from discharge year 2007 to 2008, but decreased from discharge 

year 2005 to 2008. The DMR TWPE increased by two orders of magnitude from discharge year 

2007 to 2008, mainly because of discharges from one facility, discussed below. 
Section 15 – Waste Combustors (40 CFR Part 444) 

15-4

Table 15-5. Waste Combustors Category TRI and DMR Discharges for the 2006 through 

2010 Screening-Level Reviews 

Year of Discharge Year of Review 

Waste Combustors Category 

TRI TWPE DMR TWPE a Total TWPE 

2005 2008 52,300 NA NA 

2007 2009 114 3,220 3,260 

2008 2010 8,830 245,000 254,000 

Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; 

TRIReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; and DMRLoads2008_v2. 

a – DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and 

major dischargers. 

NA – Not applicable. EPA did not evaluate DMR data for 2005.

Table 15-6 presents the 2008 DMR TWPE by facility discharge classification. EPA 

excluded minor dischargers from previous annual reviews, but included them in the 2010 annual 

review. The majority (70 percent) of the TWPE in the 2008 DMR database is from major 

dischargers. 

Table 15-6. Waste Combustors Category 2008 DMR TWPE by Discharge Classification 

Year of Discharge a TWPE from Minor Dischargers TWPE from Major Dischargers 

2008 69,900 176,000 

Source: DMRLoads2008_v2. 

a – Data for previous years of discharge are not included because EPA excluded minor dischargers from previous 

annual reviews. 

15.3 Waste Combustors Category Pollutants of Concern

Table 15-7 lists the five pollutants with the highest TRI TWPE based on results from the 

2010, 2009, and 2007 annual reviews (TRIReleases2008_v3, TRIReleases2007_v2, and 

TRIReleases2004_ v3, respectively). Table 15-8 lists the five pollutants with the highest DMR 

TWPE based on results from the 2010, 2009, and 2007 annual reviews (DMRLoads2008_v2, 

DMRLoads2007_v3, and PCSLoads2004_v4, respectively). As noted in Section 15.2, the DMR 

TWPE increase from discharge year 2007 to 2008 is mainly because of discharges from one 

facility. 
Section 15 – Waste Comb

15-5

Table 15-7. Waste Combustors Category Top TRI Pollutants 

Pollutant 

2004 TRI Database a 2007 TRI Database a 2008 

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

N

Cadmium and Cadmium Compounds 

4 2 3,190 1 2 13.8 1 

Aldrin 

Pollutants not reported in the top five 

2004 TRI reported pollutants. Pollutants not reported in the top five 2007 TRI reported pollutants. 

2 

Heptachlor 3 Chlordane 4 Silver and Silver Compounds 5 2 2,300 5 Nitrate Compounds 

Pollutants not reported in the top five 

2004 TRI reported pollutants. 

2 2 8.35 

Pollutants no

2008 TR

Ethylene Glycol 3 1 5.23 Lead and Lead Compounds 4 2 4.34 Formaldehyde 5 1 3.5 Benzidine 1 1 188,000 

Pollutants not reported in the top five 2007 

TRI reported pollutants. Toxaphene 2 1 34,500 

Hexachlorobenzene 3 1 11,900 Waste Combustors Category Total 

NA 11 b 243,000 NA 22 b 114 NA 

Source: TRIReleases2004_v3; TRIReleases2007_v2; and TRIReleases2008_v3. 

a – Discharges include transfers to POTWs and account for POTW removals. b – Number of facilities reporting TWPE greater than zero. NA – Not applicable. 
Section 15 – Waste Comb

15-6

Table 15-8. Waste Combustors Category Top DMR Pollutants

Pollutant 

2004 DMR Database a 2007 DMR Database a 2008 DM

Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Number of 

Facilities 

Reporting 

Pollutant TWPE Rank 

Nu

F

R

P

Hexachlorophene 

Pollutants not reported in the top five 2004 

DMR reported pollutants. 

Pollutant not reported in the top five 2007 

DMR reported pollutants. 

1 

Arsenic 2 1 815 2 Calcium 

Pollutants not reported in the top five 2007 

DMR reported pollutants. 

3 

Copper 4 Sulfate 5 Cadmium 1 2 1,290 

Pollutants not rep

DMR rep

Mercury 3 2 717 Selenium 4 2 177 Lead 5 3 82 Sulfide 1 2 1,380 

Pollutants not reported in the top five DMR 

2007 reported pollutants. 

Boron 2 1 1,360 PCB-1260 3 1 814 PCB-1248 3 1 814 PCB-1242 3 1 814 Waste Combustors Category Total 

NA 17 c 9,087 NA 4 c 3,220 NA 

Source: PCSLoads2004_v4; DMRLoads2007_v3; and DMRLoads2008_v2. 

a – 2004 and 2007 DMR data include only major dischargers. b – 2008 DMR data includes major and minor dischargers. c – Number of facilities reporting TWPE greater than zero. NA – Not applicable.
Section 15 – Waste Combustors (40 CFR Part 444) 

15-7

The Waste Combustors Category combined TWPE is dominated by hexachlorophene 

discharges, accounting for approximately 68 percent of the combined TWPE. Additionally, the 

Waste Combustors Category TWPE in the 2008 TRI database is significantly lower than the 

2008 DMR TWPE. Therefore, EPA focused the preliminary category review on 

hexachlorophene discharges in the 2008 DMR database. 

15.4 Waste Combustors Hexachlorophene Discharges in DMR

As part of the 2010 annual review of the Waste Combustors Category, EPA reviewed 

hexachlorophene discharges in the 2008 DMR database. Approximately 70 percent of the 2008 

DMR TWPE results from hexachlorophene discharges. Only one facility, Clean Harbors Deer 

Park, reported hexachlorophene discharges. 

Clean Harbors Deer Park discharges hexachlorophene from outfall 001. Table 15-9

presents Clean Harbors Deer Park’s quarterly hexachlorophene discharge data from the DMR 

Loadings Tool. EPA contacted the facility to verify the hexachlorophene quantities and flows for 

outfall 001. The facility contact indicated that the quantities were reported as lb/day rather than 

kg/day. Additionally, the facility contact indicated that the reported quantities were based on 

nondetect hexachlorophene concentrations. The quantities were reported without the below 

detection limit (BDL) indicator (i.e., “<” sign) because their permit requires them to use the 

detection limit to calculate the quantity if the concentrations are nondetect (Honohan, 2010). 

Table 15-9 also presents the facility-provided quantities, converted to kg/day. Using the revised 

quantities, Clean Harbors Deer Park’s hexachlorophene discharges are 0 TWPE, reducing the 

Waste Combustors Category 2008 DMR TWPE by approximately 72 percent, from 245,000 to 

73,000 TWPE. 

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

Outfall Monitoring Period Date 

DMR Loadings Tool 

Average Quantity 

(kg/day) 

Facility-Provided 

Average Quantity 

(kg/day) 

001 31-Jan-08 0.128 <0.058 

001 30-Apr-08 0.120 <0.054 

001 31-Jul-08 0.132 <0.060 

001 31-Oct-08 0.101 <0.046 

Source: DMR Loadings Tool; and Facility Contact (Honohan, 2010). 

15.5 Waste Combustors Category Conclusions

The estimated toxicity of the Waste Combustors Category discharges results mainly from 

the hexachlorophene discharges of one plant (accounting for 72 percent of the category’s 2008 

DMR TWPE). The remaining estimated toxicity results mainly from metals discharges. Data 

collected for the 2010 annual review demonstrated that wastewater discharge characteristics for 

this category are consistent with discharges from prior years. As in prior years, EPA makes the 

following conclusions: 

• Based on contacts with Clean Harbors Deer Park, in 2008, the facility did not 

detect hexachlorophene (i.e., all concentrations were below the detection limit). 
Section 15 – Waste Combustors (40 CFR Part 444) 

15-8

EPA then set the hexachlorophene load and TWPE to zero. Correcting this error 

decreases the Waste Combustors Category combined 2008 DMR and TRI TWPE 

to 81,800 TWPE. 

• EPA will collect data on metals and pesticides discharges from waste combustors 

for consideration during the 2011 annual review because the estimated toxicity is 

primarily from these groups of chemicals. 

• EPA will continue monitoring discharges from waste combustors as part of future 

annual reviews. 

EPA prioritizes point source categories with existing regulations for potential revision 

based on the greatest estimated toxicity to human health and the environment, measured as 

TWPE. Based on the above conclusion, EPA is assigning this category with a lower priority for 

revision (i.e., this category is marked with “(5)” in the “Findings” column in Table V-1 in the 

Federal Register notice that presents the 2010 annual review of existing effluent guidelines and 

pretreatment standards). 

15.6 Waste Combustors Category References

1. Honohan, Kevin, Craig. 2010. E-mail communication between Kevin Honohan, Clean 

Harbors Deer Park, and Eleanor Codding, Eastern Research Group, Inc. “DMRs 

Clarification Needed for TX0005941.” (July 8). EPA-HQ-OW-2008-0517 DCN 07282. 

2. U.S. Census. 2002. U.S. Economic Census. Available online at: 

http://www.census.gov/econ/census02. 

3. U.S. EPA. 2000. Development Document for Final Effluent Limitations Guidelines and 

Standards for Commercial Hazardous Waste Combustors. EPA-821-R-99-020. 

Washington, DC. (January). Available online at: 

http://epa.gov/guide/chwc/final/technical.html. 

4. U.S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program 

Plan. EPA-821-R-08-015. Washington, DC. (August). EPA-HQ-OW-2006-0771-1701. 
Part III – Detailed Studies 

III 

PART III: DETAILED STUDIES
Section 16 – Health Care Industry and Hospitals Category (40 CFR Part 460) 

16-1 

16. HEALTH CARE INDUSTRY AND HOSPITALS CATEGORY (40 CFR PART 460) 

Pharmaceutical chemicals have been detected in our nation's waterways, leading to 

concerns that these compounds may affect aquatic life and possible human health through 

drinking water sources. As a result of public comments on the 2006 Final 2006 Plan, EPA 

initiated a study of unused pharmaceutical disposal practices at health care facilities. The focus 

of this study was on disposal to water via sewers. EPA studied medical facilities; including, 

hospitals, hospices, long-term care facilities, health care clinics, physician offices, and veterinary 

facilities. A standard disposal practice at many health care facilities is to flush unused 

pharmaceuticals down the toilet or drain. 

Unused pharmaceuticals include leftover medication that is expired, not dispensed, and/or 

partially used, and residues from delivery devices. During the study, EPA conducted intensive 

outreach to over 700 stakeholders and evaluated a range of management practices to reduce the 

generation of unused pharmaceuticals and their disposal down the drain. Based on the 

information collected through the outreach, EPA has drafted a guidance document, “Best 

Management Practices for Unused Pharmaceuticals at Health Care Facilities” (U.S. EPA, 2010). 

The guidance document was made available for a 60 day public review and comment as 

announced in a Federal Register Notice, published on September 8, 2010 (75 FR 54627). The 

draft guidance document was posted on the Agency’s website. 

In summary, the guidance recommends the following practices to prevent or minimize 

the amount of pharmaceuticals being disposed in water: 

• Conduct an inventory of pharmaceuticals and pharmaceutical waste to quantify 

the amount of medication the facility is disposing of; 

• Reduce pharmaceutical waste by reviewing purchasing practices, use limited dose 

or unit dose dispensing, replace pharmaceutical samples with vouchers, and 

perform on-going inventory control and stock rotation; 

• Reuse or donate unused pharmaceuticals when possible; return unused 

pharmaceuticals to the pharmacy; send unused pharmaceuticals to a reverse 

distributor for credit and proper disposal in accordance with the facility’s state 

environmental regulations; properly identify and manage hazardous 

pharmaceutical wastes in accordance with federal and state regulations; use EPA 

recommended practices to dispose of non-hazardous pharmaceutical waste at the 

facility; 

• Segregate waste for disposal to ensure regulations are met; and 

• Train staff in proper disposal methods. 

EPA received 89 comments on the proposed guidance on November 8, 2010 and is 

reviewing suggested changes to the document and working with relevant Federal Agencies to 

ensure any incorporated comments are consistent with other Federal laws and policies. EPA 

plans to issue the study report and final guidance in 2011 and will notify stakeholders directly 

and by means of its website at: 

http://water.epa.gov/scitech/wastetech/guide/unusedpharms_index.cfm. 
Section 16 – Health Care Industry and Hospitals Category (40 CFR Part 460) 

16-2 

16.1 Health Care Industry and Hospitals Category References

1. U.S. EPA. 2010. Draft Guidance Document: Best Management Practices for Unused 

Pharmaceuticals at Health Care Facilities. EPA-821-R-10-006. Washington, DC. 

(August 26). Available online at: 

http://water.epa.gov/scitech/wastetech/guide/upload/unuseddraft.pdf.
Section 17 – Oil and Gas Extraction (40 CFR Part 435) 

17-1 

17. OIL AND GAS EXTRACTION (40 CFR PART 435) 

As a result of prior 304(m) planning, EPA initiated a detailed study of the coalbed 

methane industry and its wastewater discharges. Coalbed methane extraction is considered a 

subcategory of the Oil and Gas Extraction (Oil and Gas) Category, although it is not currently 

subject to the ELGs promulgated for this category. Since 2006, the coalbed methane industry has 

expanded. In addition, EPA received comments in 2005, 2008, and again during the 2010 review 

from citizens and environmental advocacy groups requesting development of a regulation for 

coalbed methane extraction as well as for shale gas extraction, another subcategory of the Oil 

and Gas Category. Unlike coalbed methane extraction, however, shale gas extraction is now 

subject to the Oil and Gas ELGs, although there are currently no applicable categorical 

pretreatment standards for shale gas extraction. 

Coalbed methane-produced water discharges can impact receiving surface waters and 

soils. Saline discharges from coalbed methane operations can adversely affect aquatic life. The 

large volume of water discharged can also cause stream bank erosion and salt deposition, 

creating hardpan soil. Long-term impacts include sodium buildup, reduction of plant diversity, 

mobilization of salts and other elements, and alteration of surface and subsurface hydrology. 

17.1 Overview of Operations

Methane gas is naturally created during the geologic process of converting plant material 

to coal (coalification). To extract the methane, coalbed methane operators drill wells into coal 

seams and pump out ground water. Removing the ground water from the formation is necessary 

to produce coalbed methane, as the water removal reduces the pressure and allows the methane 

to release from the coal to produce flowing natural gas. In 2008, 252 coalbed methane operators 

managed approximately 55,500 coalbed methane wells in the U.S. in 13 distinct regions, called 

basins. 

17.2 Produced Water

The ground water that has been pumped out of the well, called "produced water," like 

most ground water found deep below the surface of the earth, has high salinity and can include 

pollutants such as chloride, sodium, sulfate, bicarbonate, fluoride, iron, barium, magnesium, 

ammonia, and arsenic. To quantify the amount of pollutants in coalbed methane produced 

waters, EPA relied on measuring total dissolved solids and electrical conductivity, which are 

bulk parameters for quantifying the total amount of dissolved solids in a wastewater. 

A single coalbed methane well can discharge thousands of gallons of produced water per 

day, and may discharge produced water for anywhere from 5 to 15 years. Coalbed methane wells 

have a distinctive production history characterized by: an early stage when large amounts of 

water are produced to reduce reservoir pressure which in turn encourages release of gas; a stable 

stage when quantities of produced gas increase as the quantities of produced water decrease; and 

a late stage when the amount of gas produced declines and water production remains low. 

The quantity and quality of produced water varies from basin to basin, within a particular 

basin, from coal seam to coal seam, and over the lifetime of a coalbed methane well. For 

example, coalbed methane produced water volumes range from 1,000 gallons per day (gpd) per 

well in the San Juan Basin to 17,000 gpd per well in the Powder River Basin. 
Section 17 – Oil and Gas Extraction (40 CFR Part 435) 

17-2 

17.2.1 Management of Produced Water 

Coalbed methane operators need to dispose of thousands of gallons of produced water per 

day for each coalbed methane well. Operators can employ a range of options for treatment and 

management of this wastewater. 

Preliminary estimates based on survey data predict that approximately 47 billion gallons 

of produced water are pumped annually from coal seams across the country. Approximately 45 

percent of those produced waters are directly discharged to waters of the U.S., for a total national 

discharge of 22 billion gallons per year. 

Surface water discharge is most prevalent in three U.S. coalbed methane basins: 

• The Black Warrior Basin in Alabama and Mississippi (11 percent of total coalbed 

methane surface discharges); 

• The Powder River Basin in Wyoming and Montana (72 percent of total coalbed 

methane surface discharges); and 

• The Raton Basin in Colorado and New Mexico (11 percent of total coalbed 

methane surface discharges). 

Many of these discharges are largely untreated. Surface discharge occurs rarely, if at all, in the 

other major commercial basins. 

 In the other commercial basins in the U.S, coalbed methane operators are, for the most 

part, able to prevent discharging their produced water by discharging the water to land (where 

there may be other impacts to the soil or vegetation), re-injecting the produced water back into 

the ground, or using the water in one of many beneficial use options (e.g., stock watering, 

irrigation). 

17.2.2 Treatment of Produced Waters 

Available technology options for adequately removing pollutants from produced water 

include ion exchange and reverse osmosis. 

17.3 Summary of Outreach

In 2007, EPA conducted several site visits to coalbed methane basins throughout the 

country and gathered information on potential treatment technologies for coalbed methaneproduced water discharges. EPA also conducted widespread outreach with stakeholders, both in 

the industry and from the communities adjacent to coalbed methane basins. EPA conducted more 

than 30 site visits to locations in 6 coalbed methane basins and met with over 300 different 

stakeholders. EPA also conducted 13 meetings and teleconferences with over 150 stakeholders. 

In addition to the extensive information collection through site visits and outreach, EPA 

acknowledged that an informed decision about rulemaking would require even more detailed 

information. EPA developed an industry questionnaire, solicited public comment twice, and in 

2009 obtained OMB approval under the Paperwork Reduction Act, to conduct a mandatory 

survey directed at operators of coalbed methane projects which consist of a single well or a 

group of wells operated by the same company. The questionnaire collected technical and 

economic data in a two-part survey, a screener and a detailed survey, on the operations and 
Section 17 – Oil and Gas Extraction (40 CFR Part 435) 

17-3 

operators of coalbed methane projects. Questionnaire responses arrived in early 2010 and the 

data was used by EPA to create national estimates of pollutant discharges across the country 

from the coalbed methane industry and to develop an economic profile of the industry. 

In response to the Preliminary 2010 Plan, EPA received 32 comments on coalbed 

methane extraction. Comments from industry sources did not support rulemaking for coalbed 

methane, suggesting an effluent guideline was not appropriate due to the variability of produced 

water quality, quantity and available management techniques across the country. Additionally, 

industry stated that the current regulatory framework of site-specific BPJ permits was adequately 

addressing pollutant discharges from produced water discharges. 

The final detailed study report for coalbed methane is being issued concurrent with the 

Final 2010 Plan (U.S. EPA, 2010). 

Coalbed methane production represents about 8 percent of natural gas production in this 

country, and coalbed methane extraction is expected to continue for decades. Of the 22 billion 

gallons of water discharged to surface water each year some has high total dissolved solids. The 

detailed study also found that there are readily available technologies to treat this produced 

water. As a result of the information gathered in the detailed study, EPA has decided to initiate 

rulemaking for coalbed methane extraction, a currently unregulated subcategory of the Oil and 

Gas Category. 

17.4 Oil and Gas Extraction References

1. U.S. EPA. 2010. Coalbed Methane Extraction: Detailed Study Report. EPA-821-R-10-

022. Washington, DC. EPA-HQ-OW-2008-0517 DCN 09999.