## MEMORANDUM

TO: Melissa Weitz, EPA

FROM: Amie Aguiar and Deb Bartram, ERG

DATE: 10 August 2008

SUBJECT: Planned Revisions of the I ndustrial Wastewater Inventory Emission Estimates for the 1990-2007 Inventory

As directed by EPA, ERG will be incorporating a number of previ ously proposed revisions to the industrial wastewater inventory emission estimates. This memorandum presents a summary of the planned improvements.

I E STIMATING 

### P ETROLEUM 

### R EFINING 

### W ASTEWATER 

### T REATMENT 

### E MISSIONS



### As outlined in the memorandum from 30 July 2008 on petroleum refining coverage in the Inventory, ERG recommends including the petroleum refining industry in th e wastewater sector. The previous memorandum explicitly outlines the methods and calculations for estimating CH 4 

### and CO 2 

### emissions from wastewater treatment systems.

II R EFINING 

### C ALCULATION 

### M ETHOD TO 

### I NCLUDE 

### BOD/COD R EMOVAL 

### P RIOR TO 

### A NAEROBIC 

### T REATMENT



### With the exception of pulp and paper wastewater treatment, the inventory method currently does not explicitly account for BOD or COD removals th at may occur prior to the anaerobic treatment of the wastewater. The 2006 IPCC Guidelines suggest s that the removal of organics as sludge be addressed as shown in the following equation:

CH 4 

### Emissions = 

# 



i iiii 

### REFSTOW ) [(

Where:

CH 4 

### Emissions = CH4 emissions in inventory year, kg CH4/yr TOW i 

### = total organically degradable material in wastewater from industry i in inventory year, kg COD/yr i = industrial sector S i 

### = organic component remove d as sludge in inventory year, kg COD/yr EF i 

### = emission factor for industry i, kg CH4/kg COD for treatment/discharge pathway or system(s) used in inventory year R i 

### = amount of CH4 recovere d in inventory year, kg CH4/yr

### Memorandum 10 August 2008 Page 2

Therefore, ERG investigated the appropriatene ss of including a factor for the Inventory’s industry categories to account for BOD/COD that is removed through primary treatment and therefore does not contribute to methane emi ssions. Table 1 presents a summary of the suggested actions for the 1990-2007 U.S. Inventory.

Pulp and Paper

As described in ERG’s memorandum entitl ed “Recommended Improvements to EPA’s Wastewater Inventory for Industrial Wastewater,” dated July 2, 2007, ERG previously estimated the percent of BOD that would be removed in pr imary treatment at a pulp mill. In the United States, primary treatment is focused on solids removal, equalization, ne utralization, and color reduction (EPA, 1993). The vast majority of pulp a nd paper mills with on-site treatment systems use mechanical clarifiers to remove suspended solids from the wastewater. ERG estimated that approximately 42 percent of the BOD in pulp and paper wastewater passes on to secondary treatment, which consists of activated sludge , aerated stabilization basins, or non-aerated stabilization basins.

Meat and Poultry

For meat and poultry plants, primary wastewater treatment is commonly used prior to the onsite anaerobic lagoon. Raw wastewater from slaughterhouses can include suspended matter that is insoluble, is slowly biodegradable, and account s for 40 to 50 percent of the raw wastewater COD. Most facilities use screening, oil and grease removal, dissolved air flotation, and flow equalization. However, the BOD/COD value used in the Inventory repres ents the amount of BOD/COD entering the anaerobic lagoon following prim ary treatment . Therefore, it is not necessary to add a specific f actor for this industry to acc ount for BOD/COD removals during primary treatment.

Fruits and Vegetables

For fruits and vegetables proces sing plants, screening is used at almost all canning plants, while gravity sedimentation is used at all types of plants. Gravity sedi mentation is a primary treatment operation to reduce suspended solids and BOD, w ith the sludge being pumped to sludge handling or digestion facilities. The efficiency of the primary settling step to reduce BOD is dependent on the specific type of waste (e.g., tomato and tree fr uit lye peel wastewater vs. root crop vegetable wastewater). Based on data colle cted by EPA (EPA, October 1975), BOD is typically reduced by 17 to 30 percent. Therefore, ERG suggests in cluding a BOD removal rate of 23 percent.

Ethanol Production

As described in ERG’s memorandum entitled “Assessment of Greenhouse Gas Emissions from Wastewater Treatment of U.S. Ethanol Produc tion Wastewaters,” dated October 19, 2006, the COD loading used in the inventory represents the amount of BOD/COD e xpected to enter the

### Memorandum 10 August 2008 Page 3

anaerobic treatment systems. Therefore, it is not necessary to add a sp ecific factor for this industry to account for BOD/COD re movals during primary treatment.

Petroleum Refining

Petroleum refineries utilize oil/water separato rs as a primary treatment operation. ERG was unable at this time to determine specific removal rates for BOD/COD by these primary treatment operations. However, we believe th ere is no significant removal.

Table 1. Primary Treatment and Percent BOD Removal by Industry

Industry Primary Treatment Presence % BOD Removal in Primary Treatment

Pulp and Paper Yes 58% Meat and Poultry Yes No Factor Needed (BOD represents what is entering anaerobic lagoon) Fruits and Vegetables Yes 23% Ethanol Production No No Factor Needed (BOD represents what is entering anaerobic treatment) Petroleum Refining Yes No significant BOD removal expected



### III E STIMATING 

### P ERCENT 

### I NDUSTRIAL 

### W ASTEWATER 

### T REATED 

### O N 

### S ITE AND 

### N UMBER OF 

### T REATMENT 

### S YSTEMS



### In ERG’s memorandum entitled “E stimation of Onsite Treatment at Industrial Facilities and Review of Wastewater Charact erization Data,” dated 15 Apr il 2008, ERG reviewed the number of treatment systems and the percent of wastewat er treated onsite. Usi ng this industry-specific information, ERG will revise the inventory calcul ations to present the estimation of percent wastewater treated anaerobically (%TA) for each industry. We will present a general calculation for each industry that defines the percent of plants in the industry that treat wastewater on site, the percent of plants that have a primary treat ment step prior to biological treatment, and the percent of plants that treat wastewater anaerobically. ERG will estimate the %TA for both primary treatment and secondary treatment. For plants that have primary treatment in place, ERG will incorporate an estimate of COD that is removed prior to wastewater treatment in the anaerobic treatment units.

In general, ERG recommends the industry e quations be revised to show the following calculations for the percent of wast ewater treated anaerobically (%TA):

%TA p 

### = %Plants o 

### * %WW a,p 

### * %COD p 

### %TA s 

### = [%Plants a 

### * %WW a,s 

### * %COD s 

### ] + [%Plants t 

### * %WW a,t 

### * %COD s 

### ]

### Memorandum 10 August 2008 Page 4

Where:

%TA p 

### = percent of industry wastewater treated anaerobically in primary treatment %Plants o 

### = percent of plants with onsite treatment %WW a,p 

### = percent of wastewater treated anaerobically in primary treatment %COD p 

### = percent of COD entering primary treatment %TA s 

### = percent of industry wastewater tr eated anaerobically in secondary

treatment %Plants a 

### = percent of plants with anaerobic secondary treatment %Plants t 

### = percent of plants with other secondary treatment %WW a,s 

### = percent of wastewater treated anaerobically in anaerobic secondary

treatment %WW a,t 

### = percent of wastewater treated anaero bically in other secondary treatment %COD s 

### = percent of COD enteri ng secondary treatment

Pulp and Paper

Based on information from the 2002 U.S. Economi c Census, there are 561 pulp and paper mills in the United States. According to EPA’s da ta from 1993, there were a total of 565 pulp and paper mills. Of these, 338 mills (60%) have onsite treatment with primary treatment and 166 mills (approximately 30%) have basins for secondary wastewater treatment (either aerated or nonaerated). About 85% of these basins are anaerobic (or 25% of plants have anaerobic basins on site).

Meat and Poultry

According to the 2002 U.S. Economic Census there are 3,973 meat and poultry processing facilities in the United States, of which 3,437 are red meat facilities and 536 are poultry plants. EPA conducted a survey in 2001 to collect info rmation on the industry based on calendar year 2000. From that information, EPA estimates that 71% of facilities disc harge wastewater, of which 94% are indirect discharger s (facilities that di scharge to a publicly owned treatment works (POTW)) and 6% are direct dischargers. Overa ll, EPA estimates that 67% of meat processing facilities discharge indirectly and 75% of poultry operations disc harge indirectly. Although it is likely that most of the indirect dischargers em ploy some pretreatment such as screening and dissolved air floatation, anaerobic pretreatment would be unusual.

The remaining facilities either do not discharge (“zero discharger ”) or they discharge their wastewater directly. A ll direct dischargers utilize anaerobic treatment; however, there is limited information on zero dischargers. Although it is like ly that some small zer o discharge facilities use contract haulers for wastewat er disposal, it seems reasonable to assume that zero discharge generally means disposal by land application preceded by anaerobic pretreatment given the lack of available information.

### Memorandum 10 August 2008 Page 5

Therefore, we estimate all meat and poultry proce ssing facilities conduct some sort of treatment on site. Approximately 33% of meat wastewat er and 25% of poultry wa stewater is treated anaerobically on site.

Fruits and Vegetables

According to the 2002 U.S. Economic Census for Manufacturing, there are 1,746 fruit and vegetable preserving and specialty plants. Of all fruit facilities, 52% discharge to POTWs, 11.6% directly discharge to surface waters, and 36.6% land apply thei r wastewater. At vegetable facilities, 48% of wastewater is discharged to POTWs, 11% is directly discharged to surface waters, and 41% is land applied. So for fruit a nd vegetable facilities together, roughly 50% is discharged to POTWs (873 facilities), 11% is di rectly discharged (192 facilities), and 39% is land applied (681 facil ities; Martin 2006).

It is reasonable to assume that, depending on the product, approximately 50% of all direct discharge is pretreated in anaerobic lagoons. F acilities discharging to POTWs or land applying their wastewater are unlikely to have any an aerobic pretreatment, so it is likely that approximately 96 facilities treat their wastew ater anaerobically on site (Martin 2006). The current Inventory states that 5% of wastewater is treated anaer obically on site, which translates to about 87 facilities, which is cl ose to the values calculated above.

Ethanol Production

In the United States, there are currently 139 et hanol biorefineries with 61 under construction (RFA, 2008). From the Inventory, 23% of these re fineries are wet milling facilities and 77% are dry milling facilities (about 32 and 107, respectively). As described in ERG’s memorandum entitled “Assessment of Greenhouse Gas Emissions from Wastewater Treatment of U.S. Ethanol Production Wastewaters,” dated October 19, 2006, 33.3% of wastewater is treated anaerobically at wet milling facilities. This can be translated to about 11 facilities that treat wastewater anaerobically on site. At dry milling facilities, 75% of wastewater is treated anaerobically on site (in either biomethanators or other anaerobic systems). Biomet hanators account for 50%, and other anaerobic treatment counts for 25%. 1 

### In total, roughly 80 dry milling facilities treat wastewater anaerobically, with 53 treating their wastewater with biomethanators.

Summary of Industry Values

Based on the previous discussions , ERG recommends using the valu es presented in Table 2 in the revised Inventory calculations.

1 These percentages for dry milling operations have been updated since the October 19, 2006 memorandum to account for additional industry c ontacts made in January 2007.

### Memorandum 10 August 2008 Page 6

Table 2. Variables Needed to Calculate P ercent Treated Anaerobically by Industry

Industry

Variable Pulp and Paper Meat Processing Poultry Processing Fruit/ Vegetable Processing Ethanol Production – Wet Mill Ethanol Production – Dry Mill Petroleum Refining

%TA p 0 0 0 0 0 0 0 %TA s 10.5 33 25 5.5 33.3 75 100 %Plants o 60 100 100 11 100 100 100 %Plants a 25 33 25 5.5 33.3 75 100 %Plants t 35 67 75 5.5 66.7 25 0 %WW a,p 0 0 0 0 0 0 0 %WW a,s 100 100 100 100 100 100 100 %WW a,t 0 0 0 0 0 0 0 %COD p 100 100 100 100 100 100 100 %COD s 42 100 100 100 100 100 100



### IV U PDATING 

### E THANOL 

### P RODUCTION 

### W ASTEWATER 

### E MISSIONS 

### C ALCULATIONS



### ERG will be confirming ethanol calculations using EPA ethanol plant site visit data from KarrieJo Robinson-Shell from EPA Region 4. ERG is curre ntly awaiting receipt of these data and plans to confirm or improve the following variables: th e volume of water generated per unit of ethanol production, types of treatment units used and da ta on BOD or COD in wastewater prior to

treatment.

V I NCLUSION OF 

### O THER 

### I NDUSTRIAL 

### W ASTEWATER 

### S OURCES



### The methodology to estimate emissions for industr ial wastewater currently accounts for pulp and paper, meat and poultry proces sing, fruits and vegetables pr ocessing, and ethanol production wastewater treatment. Based on direction fr om the EPA TOPO for the 1990-2007 Inventory, ERG will also add petroleum refining wastewater treatment. To support EPA in determining whether other industrial sources should be incl uded in the wastewater inventory, ERG used available data sets from EPA’s Permit Complia nce System (PCS) to investigate/rank other industries based on the amount of BOD, COD, and total nitrogen reported to be discharged.

For industries that report discharging large quan tities of BOD and COD, ERG then investigated whether these facilities are like ly to treat their wastewater on site with anaerobic biological treatment, indicating a likelihood of methane gene ration from treatment. For industries that report discharging large quantities of total nitroge n, ERG investigated whether these facilities are likely to treat their wastewater on site with ni trification/denitrifica tion biological systems, indicating a likelihood of nitrous oxi de generation from treatment. Th ese facilities are likely to also produce nitrous oxide from their discharged effluent.

### Memorandum 10 August 2008 Page 7

Background Information on EPA’s Permit Compliance System

PCS is a computerized information manageme nt system maintained by EPA’s Office of Enforcement and Compliance Assurance (OECA). It was created to track permit, compliance, and enforcement status of facilities regulat ed by the NPDES program under the CWA. Among other things, PCS houses discharge data for these facilities. 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 pe rmitting priorities, EPA developed a major/minor classification system for industr ial and municipal wa stewater discharges. Major discharges almost always have the capability to impact r eceiving waters if not c ontrolled and, therefore, have received more regulatory attention than minor discharges. There are approximately 6,400 facilities (including POTWs) with major discha rges for which PCS has extensive records. Permitting authorities classify discharges as majo r 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 Discharge Monitoring Reports (DMRs) submi tted to the permitting authority. The permitting authority enters the reported DMR data into PC S, including pollutant c oncentration and quantity values and identification of any types of perm it violations. Minor disc harges may, or may not, adversely impact receiving water if not controll ed. Therefore, EPA does not require DMRs for facilities with minor discharges. For this reas on, the PCS database includes data only for a limited set of minor dischargers when the states choose to in clude these data.

Parameters in PCS include water quality parame ters (such as pH and temperature), specific chemicals, conventional parameters (such as B OD5 and total suspended solids [TSS]), and flow rates. Although other pollutants ma y be discharged, PCS contains only data for the parameters identified in the facility’s NPDES permit. Fac ilities typically report monthly average pounds per day discharged, but also re port daily maxima and averag e pollutant concentrations.

The PCS database contains approximately 50 di fferent parameters that may be reported for nitrogen compounds. Total n itrogen is the sum of organic nitroge n, ammonia, nitrite, and nitrate. Total inorganic nitrogen is the sum of ammonia, nitrite, and nitrate. Total Kjeldahl Nitrogen (TKN) is the sum of organic nitrogen and ammoni a. Unionized ammonia is a subset of total ammonia. Because different nitrogen compounds re ported by one facility may overlap with each other, ERG developed the followi ng hierarchy for calculating the total nitrogen load to avoid double counting nitrogen:

### Memorandum 10 August 2008 Page 8

1. Use PCS PRAM 00600 (“Nitrogen, Total (as N)), if reported, to repr esent total nitrogen. 2. If PCS PRAM 00600 is not reported, use the sum of TKN, nitrite, and nitrate. 3. If neither of the first two rules apply, use the sum of organi c nitrogen, ammonia, nitrite, nitrate. 4. Where applicable, use TRI data to fill in for missing PCS parameters in the total nitrogen calculation. 5. If no nitrogen compounds are reported to PCS, use the sum of ammonia, sodium nitrite, and nitrate compounds reported to TRI.

Loads of compounds that are not reported as nitr ogen, such as sodium nitrite, nitrate compounds, or ammonia, were converted to pounds of nitrogen using the following equation:

Lbs Nitrogen = Lbs Compound * (Molecular Weight (MW) Nitrogen / MW Compound)

ERG, in support of EPA Office of Water’s Effluent Guidelines Pr ogram Plan, used the PCS data for reporting year 2004 to estimate annual pollu tant loads by industry category. ERG used a calculation tool called the PCSLoa dCalculator to calculate these annual loads. The output from this tool is housed in a database called PCSLoads2004 . More details on the methodology and development PCSLoads2004 can be found in EPA’s 2008 Preliminary Plan TSD (EPA, 2007).

Industry Rankings

ERG used the industry rankings of BOD, COD, and total nitrogen discharges from PCSLoads2004 to determine the top five industries for each pollutant parameter. The full lists of industry rankings can be found in Attachments 1 through 3. Table 3 presents a summary of the industries with the highest loads for each of thes e parameters. It’s important to note that a majority of plants are required to monitor and report BOD discharges; a smaller percentage are required to report COD and/or nitrogen loadings. However, the organic chemicals, plastics, and synthetic fibers (OCPSF) industry is listed as one of the top five industries discharging all three pollutant parameters for 2004. Therefore, ERG fu rther investigated this industry for possible inclusion in the U.S. Greenhouse Gas Inventory.

### Memorandum 10 August 2008 Page 9

Table 3. Top Industries Reporting Discharges of BOD, COD, and Total Nitrogen in 2004

Reported BOD Discharges Reported COD Discharges Reported Nitrogen Discharges

Industry Total Annual Load Industry Total Annual Load Industry Total Annual Load Organic chemicals, plastics and synthetic fibers 1,415,153,620 Pulp, paper and paperboard 147,340,464 Organic chemicals, plastics and synthetic fibers 14,709,505

Chlorine and chlorinated hydrocarbons 662,227,060 Petroleum refining 134,104,025 Steam electric power generation 12,517,688

Pulp, paper and paperboard 242,941,593 Textile mills 30,591,292 Meat and Poultry Products 9,175,593

Canned and preserved seafood processing 51,815,923 Organic chemicals, plastics and synthetic fibers 25,678,477 Pulp, paper and paperboard 9,124,065

Steam electric

power generating 51,520,861 Miscellaneous Foods and Beverages 16,984,927 Fertilizer manufacturing 6,166,094



### Preliminary Investigatio n of the OCPSF Industry

The OCPSF category includes many chemical indus tries producing hundreds of end products, such as polypropylene, vinyl chloride and PV C, chlorinated solvents, rubber precursors, styrofoam additives, and polyester (to name a few). Some OCPSF fac ilities are extremely complex and produce hundreds of chemicals, wher e others are simpler, producing only one or

two. This category includes facilities in the following SIC codes:

• 2821: Plastic Materials, Synthetic Re sins, and Nonvulcanizable Elastomers; • 2823: Cellulosic and Other Man-Made Fibers; • 2824: Synthetic Organic Fi bers, Except Cellulose; • 2865: Cyclic Crudes and Intermediates, and Organic Dyes and Pigments; • 2869: Industrial Organic Chemicals, Not Elsewhere Classified (NEC); • 2842: Specialty Cleaning, Polishing, and Sanitation Preparations; • 2844: Perfumes, Cosmetics, a nd Other Toilet Preparations; • 2891: Adhesives and Sealants; • 2899: Chemicals and Chemical Preparations, NEC; and • 5169: Chemicals and Allied Products.

Based on 2002 Economic Census data, there are more than 60,000 facilities within this industry, of which approximately 500 facilities with NP DES permits to discharge wastewater, and classified as either major or minor dischargers, report to PCS. (EPA, 2007)

EPA’s Office of Water conducted a detailed survey of the industry in 1987, and received facilityspecific data from 940 OCPSF plants. Based on 1987 data, the average flow rate for direct

### Memorandum 10 August 2008 Page 10

dischargers was 1.31 million gallons per day (M GD), and for indirect dischargers was 0.25 MGD. Table 4 illustrates the typical raw (prior to treatment) BOD and COD concentrations of wastewater at direct an d indirect dischargers. In addition, EPA collected information on the type of onsite treatment conducted at OCPSF facilities. Table 5 summarizes the treatment information gathered. From this, it is clear that a very small percentage (1.3%) of facilities operated anaerobic treatment systems. In addi tion, no plants were iden tified at that time as operating nitrification/de nitrification systems.

Table 4. Raw Pollutant Concentrations in Wastewater Generated by OCPSF Facilities

Source: EPA, 1987 Raw Pollutant Concentrations (1987) Pollutant Direct Dischargers (mg/L) Indirect Dischargers (mg/L)

BOD 5 1,088 1,784

COD 2,908 4,571



### Table 5. Secondary Treatment Systems Reported by OCPSF Facilities

Secondary Treatment Technology Percent of Facilities Reporting 1 Activated Sludge Treatment (e.g., activated sludge, oxidation ditch, pure oxygen activated sludge) 16.3

Aerated Lagoon 9.5 Aerobic Lagoon 2.6 Anaerobic Lagoon 1.3 Trickling Filters 1.3 Rotating Biological Contactors 0.8 Other 21.4 Source: EPA, 1987 (Table VII-16)

1 Percent of operations does not add to 100% because some facilities did not re port having secondary treatment, and some facilities reported having more than one type of secondary treatment.



### Because the information collected by the Offi ce of Water was dated, ERG accessed more recent data on treatment technologies reported in EP A’s Toxic Release Inventory (TRI) by OCPSF facilities. Table 6 presents the number of facil ities that reported usi ng particular wastewater treatment processes in 2000. Unfortunately, fa cilities only reported a general category of biological treatment, and not the spec ific type of treatment in place. However, it would be very unusual for a facility to move from aerobic biological treatment to anaerobic biological treatment. Therefore, ERG believes the 1987 data represents a maximum percent of operations with anaerobic treatment, and th erefore is not a likely industr y category for significant methane emissions. On the other hand, it is unclear whethe r this industry would ha ve significant nitrous oxide emissions. Although virtua lly no facilities reported using nitrification/denitrification systems in 1987, there has been incr easing interest in nitr ogen discharges in the U.S. since that time. It is likely there has been an increase in the use of technologies to control such discharges from this industry. More resear ch is needed to determine wh at type of nitrogen reduction

### Memorandum 10 August 2008 Page 11

technologies are in place, and to determine what level of nitrous oxide emissions may be likely from such systems.

Table 6. Type of Wastewater Treatment Proce sses Reported to TRI by OCPSF Facilities

Number of Facilities Reporting Use

Wastewater Treatment Process Direct 1 (213 facilities) Indirect 1 (176 facilities) Biological Treatment 207 60 Settling/Clarification 136 59 Equalization 120 65

Neutralization 101 90

Filtration 75 34 Stripping (air and steam) 50 54 Chemical precipitation 42 31 Adsorption 32 33 Source: TRI, 2000



### Other Preliminary Industry Investigations

ERG conducted a cursory review of industrial treatment data fo r other industries discharging significant loads of BOD, COD, and total nitrogen.

Chlorine and Chlorinated Hydrocarbon Manufacturing . The chlorine and chlorinated hydrocarbon manufacturing industry was recently id entified by EPA’s Office of Water, and includes manufacturers of ethylen e dichloride (EDC), vinyl ch loride monomer (VCM), and polyvinyl chloride (PVC), as well as chlor-alkali operations. EPA is evaluating whether chlorine produced by operations other than chlor-alkali w ill also be included. EPA’s Office of Water is currently collecting wastewater treatment data fr om these facilities; therefore, ERG recommends holding on any decision to include this industr y until these data are available for review (expected Summer 2009).

Steam Electric Power Generation . The steam electric industry includes electric utilities that combust coal, natural gas, and/or oil to generate electricity fo r distribution in commerce. Steam electric operations are classifi ed in the following SIC codes:

• 4911 Electrical Services: Establ ishments engaged in the generation, transmission and/or distribution of electri c energy for sale; and • 4931 Electric and Other Services Combined : Establishments primarily engaged in providing electric services in co mbination with other services, with electric services as the major part though less than 95 percent of the total.

While the steam electric industry was identified as a top nitrogen and BOD discharger, it is unlikely that their wastewater treatment pr ocesses would emit si gnificant amounts of CH 4 

### and

### Memorandum 10 August 2008 Page 12

NO x 

### . Steam electric facilities primarily use se ttling ponds for treatment. Although these ponds are not aerated, they contain large quantities of lime and ash, and also receive large volume contributions from cooling water systems. It is unlikely these ponds would emit any significant quantities of methane or nitrous oxide.

Textile Mills . The textiles industry in cludes facilities that manuf acture 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, wh ich discharge contact wastewater. These facilities ar e classified under SIC major group 22: Textile Mill Products.

The textiles industry generates wastewater w ith a wide range of flow and pollutant characteristics. Table 7 presents median historic al values of BOD and COD in wastewater from different subcategories with in the textiles industry.

Table 7. Historical COD and BOD Median Values in Untreated Textile Wastewater

Subcategory BOD (mg/L) COD (mg/L) Wool Scouring 1830 6900 Wool Finishing 150 650 Low Water Use Processing 120-380 180-1060 Woven Fabric Finishing 300-405 900-1240 Knit Fabric Finishing 205-325 765-1300 Carpet Finishing 440 1190 Stock & Yam Finishing 190 685 Nonwoven Manufacturing 175 2360 Felted Fabric Processing 205 555



### Based on data from the EPA Office of Water’s 1982 Development Document for Effluent Limitation Guidelines and Standards for Textile Mills, 18% of direct dischargers provide no wastewater treatment, 19% provide only prelim inary treatment (e.g., screening, sedimentation); 56% provide biological treatm ent by lagoons, biological filtration, or activated sludge; and only 7% provide advanced treatment like membrane processes and chemical coagulation/precipitation.

Facilities that indirectly discha rge their wastewater to POTWs may also treat wastewater on site. From the 1982 data, 58% of indi rect dischargers discharge wit hout treatment, 35% have only preliminary treatment, 7% have biological trea tment, and 0.2% have advanced treatment. The majority of zero discharge mills have no treatment.

ERG recommends that this industry be reviewed further to determine the potential extent of methane emissions.

Fertilizer Manufacturing. The fertilizer manufacturing indust ry includes facili ties that produce phosphorus- and nitrogen-based fertilizers. Facilitie s subject to this category typically report

### Memorandum 10 August 2008 Page 13

under SIC codes 2873: Nitrogenous Fertilizers, 2874: Phospha tic Fertilizers, and 2875: Fertilizers, Mixing Only. Based on 2002 Economic Ce nsus data, there are 143 facilities in the nitrogenous fertilizers SIC code. There are anot her 542 facilities in th e fertilizers mixing SIC code. (U.S. EPA, 2006)

The fertilizer manufacturing industry was one of the top nitrogen discharging industries. There are a number of subcategories that may release various forms of nitrogen in their wastewater, including ammonia, urea, ammonium nitrat e, nitric acid, and a mmonium sulfate.

Fertilizer manufacturing plants generate from 2 to 5 gallons of wastewat er per ton of product. Ammonia plants utilize more water compared to other fertilizer pl ants. Effluent wastewater from nitrogenous fertilizer treatment commonly c ontains ammonia nitrogen, nitrate and organic nitrogen. Common waste water treatment systems include raw water filtra tion and clarification, water softening and water deio nization (EPA 1974, EPA 1975).

Although virtually no facilities re ported using biological treatment systems in the 1970s, there has been increasing interest in nitr ogen discharges in the U.S. sin ce that time. It is likely there has been an increase in the use of technologies to control such discharg es from this industry. More research is needed to de termine what type of nitrogen re duction technologies are in place, and to determine what level of nitrous oxide emissions may be likely from such systems. ERG recommends that this industry be reviewed further to determine the potential extent of nitrous oxide emissions.

Canned and Preserved Seafood Processing. ERG was only able to perform a very cursory review of this category. Within the ca nned and preserved seafood processing category wastewater characteristics vary widely. Even within one section of the category, salmon canning, production varies from <1 t on to 5 tons per hour, BOD 5 

### ranges from 500 to 4,300 mg/L, COD ranges from 1,000 to 7,500 mg/L, and wastewater fl ow ranges from <1 to 22 liters per second. Frequently, wastewater from seaf ood processing plants is return ed to the ocean, and sometimes screens are used to remove solids that are th en landfilled. Other plants may discharge their wastewater to POTWs for treatment. Anywhere fr om 20-100% of plants di rectly discharge their wastewater (EPA 1975). ERG is stil l researching the types of trea tment systems that may be in use by this industry.

VI R EFERENCES



### U.S. Census, 2002. U.S. Economic Census. Available online at: http://www.census.gov/econ/census02.

U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent Guidelines Program Plan . EPA-821-R-07-007. United States Envir onmental Protection Agency, Office of Water, Washington, D.C., October.

### Memorandum 10 August 2008 Page 14

U.S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program Plan. EPA-821-R-06-018. United States Environmenta l Protection Agency, Office of Water, Washington, D.C. December.

U.S. EPA. 1993. Development Document for the Proposed Effluent Limitations Guidelines and Standards for the Pulp, Paper and Paperboard Point Source Category . EPA-821-R-93-019. United States Environmental Protection Agency, Office of Water, Washington, D.C., October.

U.S. EPA. 1987. Development Document for Effluent Limitations Guidelines and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category . EPA-440-1-87- 009. United States Environmental Protection Ag ency, Office of Water, Washington, D.C. October.

U.S. EPA. 1975. Economic Analysis of Interim Final Effluent Guidelines Seafood Processing Industry . United States Environmental Protection Agency, Office of Planning and Evaluation, Washington, D.C., February.

U.S. EPA. 1975. Development Document for Interim Final Effluent Guidelines and Proposed New Source Performance Standards for the Fish Meal, Salmon, Bottom Fish, Sardine, Herring, Clam, Oyster, Scallop and Abalone Segment of the Canned and Preserved Seafood Processing Point Source Category . United States Environmental Prot ection Agency, Office of Water and Hazardous Materials, Wash ington, D.C., January.

U.S. EPA. 1975. Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Formulated Fert ilizer Chemicals Section of the Fertilizer Manufacturing Point Source Category . United States Environmental Protection Agency, Office of Water and Hazardous Material s, Washington, D.C., January.

U.S. EPA. 1975. Development Document for Interim Final and Proposed Effluent Limitations Guidelines and New Source Performance Standard s for the Fruits, Vegetables, and Specialties Segment of the Canned and Preserved Fruits and Vegetables Point Source Category . United States Environmental Protection Agency, O ffice of Water. EPA-440/1-75-046, Washington, D.C., October.

U.S. EPA. 1974. Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Basic Fertiliz er Chemicals Section of the Fertilizer Manufacturing Point Source Category . United States Environmental Protection Agency, Office of Air and Water Programs, Washington, D.C., March.

### Memorandum 10 August 2008 Page 15

Attachment 1 Ranking of BOD Discharg es by Industry (2004)

Industrial Point Source Category Number of Major Dischargers Reporting for BOD5 Total Category Load % Total Organic chemicals, plastics and synthetic fibers 193 1,415,153,620 56.67 Chlorine and chlorinated hydrocarbons 27 662,227,060 26.52 Pulp, paper and paperboard 208 242,941,593 9.73 Canned and preserved seafood processing 5 51,815,923 2.08 Steam electric power generating 142 51,520,861 2.06 Dairy products processing 4 19,443,232 0.78 Miscellaneous Foods and Beverages 9 14,991,126 0.60

Lumber & Wood Products 1 7,014,048 0.28 Petroleum refining 97 6,659,440 0.27 Sugar processing 18 4,067,733 0.16 Meat and Poultry Products 41 3,133,954 0.13

Grain mills 11 2,411,731 0.097

Textile mills 62 2,163,290 0.087 Iron and steel manufacturing 30 1,912,757 0.077 Timber products processing 8 1,539,141 0.062 National Security & International Affairs 29 1,444,580 0.058

Pharmaceutical manufacturin g 21 1,420,91 0 0.057 Inorganic chemicals manufacturing 34 1,114,484 0.045 Metal Products and Machinery 34 984,578 0.039 Drinking Water Treatment 10 575,678 0.023

Waste combustors 13 516,549 0.021

Landfills 13 516,549 0.021 Nonferrous metals manufacturing 12 429,958 0.017

Centralized Waste Treatment 4 389,943 0.016 Canned and preserved fruits and vegetables processing 11 343,293 0.014 Rubber Manufacturing 15 340,134 0.014

Pesticide chemicals 12 277,477 0.011 Fertilizer manufacturing 11 241,874 0.0097 Gum and wood chemicals manufacturing 2 219,132 0.0088 Plastics molding and forming 6 134,295 0.0054 Copper forming 3 112,082 0.0045 Electroplating 8 106,763 0.0043

Educational Services 4 98,785 0.0040 Justice, Public Order, & Safety 8 78,311 0.0031 Aluminum forming 3 76,579 0.0031

### Memorandum 10 August 2008 Page 16

Industrial Point Source Category Number of Major Dischargers Reporting for BOD5 Total Category Load % Total Electrical and electronic comp onents 3 74,848 0.0030 Printing & Publishing 1 69,552 0.0028 Paving and roofing materials (tars and asphalt) 3 62,550 0.0025 Phosphate manufacturing 1 59,281 0.0024 Leather tanning and finishing 4 51,018 0.0020 Metal Finishing 11 49,365 0.0020 Explosives manufacturing 3 45,091 0.0018 Airport Deicing 3 42,972 0.0017 Heavy Construction, Except Building 1 21,752 0.0009 Cement manufacturing 3 20,818 0.0008

Tobacco Products 1 14,996 0.0006 Ore mining and dressing 5 14,623 0.0006 Soap and detergent manufacturing 3 14,276 0.0006 Glass manufacturing 2 13,980 0.0006 Metal molding and casting (foundries) 3 9,148 0.0004 Nonferrous metals forming and metal powders 2 6,258 0.0003 Executive, Legislative, & General 2 6,133 0.0002 Trucking & Warehousing 4 5,158 0.0002

Real Estate 1 4,554 0.0002 Environmental Quality & Housing 2 4,533 0.0002 Construction and Development 1 2,882 0.0001 Independent and Stand Alone Labs 5 2,865 0.0001

Food & Kindred Products 1 1,887 0.0001 Mineral Mining and Processing 2 672 0.0000 Hospital 2 477 0.0000 Photographic 1 239 0.0000 Photo Processing 1 239 0.0000 Coal mining 2 117 0.0000

Oil & Gas Extraction 1 21 0.0000 Sanitary Services 1 - 0.0000

Total 1,184 2,497,017,771 Source: EPA 2007.

### Memorandum 10 August 2008 Page 17

Attachment 2 Ranking of COD Discharg es by Industry (2004)

Industrial Point Source Category Number of Major Dischargers Reporting for COD Total Category Load % Total Pulp, paper and paperboard 21 147,340,464 36.55 Petroleum refining 72 134,104,025 33.26

Textile mills 54 30,591,292 7.59 Organic chemicals, plastics and synthetic fibers 66 25,678,477 6.37 Miscellaneous Foods and Beverages 2 16,984,927 4.21 Pharmaceutical manufacturing 19 10,967,257 2.72

Waste combustors 7 5,199,026 1.29

Landfills 7 5,199,026 1.29 Timber products processing 2 3,501,512 0.87 Rubber Manufacturing 13 2,907,437 0.72

Centralized Waste Treatment 1 2,457,270 0.61 Metal Finishing 16 2,138,798 0.53 Sugar processing 3 2,098,166 0.52 Chlorine and chlorinated hydrocarbons 6 1,926,622 0.48 Fertilizer manufacturing 4 1,680,869 0.42 National Security & International Affairs 7 1,525,098 0.38 Inorganic chemicals manufacturing 9 1,478,835 0.37 Steam electric power generating 21 1,435,618 0.36 Iron and steel manufacturing 19 1,327,076 0.33

Pesticide chemicals 7 1,028,601 0.26 Electrical and electronic comp onents 2 778,629 0.19 Metal molding and casting (foundries) 3 721,490 0.18 Explosives manufacturing 2 528,840 0.13 Gum and wood chemicals manufacturing 1 405,105 0.10 Printing & Publishing 1 348,919 0.09 Plastics molding and forming 2 249,406 0.06 Meat and Poultry Products 2 145,237 0.04 Aluminum forming 1 123,685 0.03 Nonferrous metals manufacturing 2 96,711 0.02

Wholesale Trade- Durable Goods 1 74,880 0.02 Battery manufacturing 1 61,471 0.02 Construction and Development 1 16,860 0.00

Wholesale Trade- Nondurable Goods 1 15,268 0.00 Ore mining and dressing 2 13,835 0.00 Trucking & Warehousing 3 6,730 0.00

### Memorandum 10 August 2008 Page 18

Industrial Point Source Category Number of Major Dischargers Reporting for COD Total Category Load % Total Nonferrous metals forming and metal powders 2 2,957 0.00

Grain mills 1 1,489 0.00 Mineral Mining and Processing 1 1,322 0.00 Independent and Stand Alone Labs 1 960 0.00 Copper forming 1 - - Airport Deicing 1 - -

Total 388 403,164,193 Source: EPA 2007.

### Memorandum 10 August 2008 Page 19

Attachment 3 Ranking of Total Nitrogen Di scharges by Industry (2004)

Industrial Point Source Category # Major Dischargers Total Nitrogen Load % of Total Organic chemicals, plastics and synthetic fibers 126 14,709,505 19.0% Steam electric power generation 83 12,517,688 16.2% Meat and Poultry Products 41 9,175,593 11.9% Pulp, paper and paperboard 72 9,124,065 11.8% Fertilizer manufacturing 19 6,166,094 8.0% Iron and steel manufacturing 38 4,309,891 5.6% Mineral Mining and Processing 15 3,150,156 4.1% Petroleum refining 90 3,111,534 4.0% Phosphate manufacturing 14 2,367,978 3.1% Pharmaceutical manufacturing 13 1,723,253 2.2% Inorganic chemicals 34 1,707,683 2.2% Miscellaneous Foods and Beverages 5 1,666,878 2.2% Nonferrous metals manufacturing 16 1,202,297 1.6% Metal Finishing 40 1,017,733 1.3% Explosives 4 879,369 1.1% Ferroalloy manufacturing 1 794,187 1.0% National Security & International Affairs 22 565,390 0.7% Sugar processing 11 434,486 0.6%

Textile mills 38 377,188 0.5% Pesticide chemicals manufacturing 12 232,486 0.3% Plastic molding and forming 5 197,834 0.3% Nonferrous metals forming and metal powders 6 189,260 0.2% Drinking Water Treatment 7 158,653 0.2% Ore mining and dressing 10 140,918 0.2% Grain mills manufacturing 7 137,515 0.2% Fruits and vegetable processing 9 131,016 0.2% Vinyl Chloride and Chlor-Alkali 13 110,645 0.1% Timber products processing 5 108,060 0.1% Canned and preserved seafood 2 91,040 0.1% Rubber Manufacturing 9 87,898 0.1%

Landfills 11 68,828 0.1% Waste combustors (commercial incinerators combusting hazardous waste) 11 68,828 0.1% Airport Deicing 2 57,547 0.1% Heavy Construction, Except Building 1 56,055 0.1% Electrical and electronic components 3 54,741 0.1% Electroplating 11 49,334 0.1%

Educational Services 4 43,964 0.1%

Tobacco Products 1 41,668 0.1%

Centralized Waste Treaters 3 39,950 0.1%

### Memorandum 10 August 2008 Page 20

Industrial Point Source Category # Major Dischargers Total Nitrogen Load % of Total Justice, Public Order, & Safety 7 37,460 0.0%

Lumber & Wood Products 1 36,187 0.0% Paving and roofing materials (tars and asphalt) 2 33,980 0.0% Metal molding and casting (foundries) 3 25,328 0.0% Independent and Stand Alone Labs 5 21,529 0.0% Executive, Legislative, & General 2 16,621 0.0% Dairy products processing 2 15,945 0.0%

Gum and wood chemicals 1 13,842 0.0% Leather tanning and finishing 3 11,628 0.0% Aluminum forming 4 9,483 0.0% Glass manufacturing 1 7,772 0.0% Battery manufacturing 1 2,972 0.0% Hospital 2 2,593 0.0% Environmental Quality & Housing 1 2,099 0.0%

Food & Kindred Products 1 1,507 0.0%

Real Estate 1 768 0.0% Engineering & Management Services 1 435 0.0% Administration of Economic Programs 1 411 0.0% Trucking & Warehousing 2 318 0.0%

Amusement & Recreation Services 1 274 0.0% Copper forming 1 147 0.0% Cement manufacturing 1 82 0.0% Coal mining 1 4 0.0% Photographic 1 3 0.0% Photo Processing 1 3 0.0%

Total 77,308,597 Source: EPA 2007.