The 2013 Annual Effluent
 

Guidelines Review Report
 

September 2014 

Z

United States 

Environmental Protection 

Agency 
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U.S. Environmental Protection Agency
 

Office of Water (4303T)
 

1200 Pennsylvania Avenue, NW
 

Washington, DC 20460
 

EPA-821-R-14-003
 
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TABLE OF CONTENTS 

Page 

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

1. 2013 ANNUAL REVIEW EXECUTIVE SUMMARY..............................................................1-1
 

1.1	 References for 2013 Annual Review Executive Summary..................................1-4
 

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

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

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

2.2.1	 Effluent Guidelines Review and Prioritization Factors ...........................2-2
 

2.2.2	 Annual Review Process ...........................................................................2-3
 

2.2.3	 Effluent Guidelines Program Plans........................................................2-11
 

2.3	 References for Background................................................................................2-11
 

PART II: EPA’S 2013 ANNUAL REVIEW METHODOLOGY AND ANALYSES ......................... II
 

3. 2013 ANNUAL REVIEW DATA SOURCES, LIMITATIONS, AND QUALITY REVIEW..........3-1
 

3.1	 Methodology Change to the 2013 TRA...............................................................3-2
 

3.2	 Data Sources and Limitations ..............................................................................3-3
 

3.2.1	 SIC Codes ................................................................................................3-3
 

3.2.2	 NAICS Codes...........................................................................................3-3
 

3.2.3	 Toxic Weighting Factors..........................................................................3-5
 

3.2.4	 Data from PCS and ICIS-NPDES............................................................3-5
 

3.2.5	 Data from TRI..........................................................................................3-8
 

3.2.6	 TRI and DMR Comparative Analysis....................................................3-10
 

3.3	 2011 DMR and TRI Data Quality Review ........................................................3-10
 

3.3.1	 Data Quality Review and Corrections to the 2011 DMR Data..............3-11
 

3.3.2	 Data Quality Review and Corrections to the 2011 TRI Data ................3-18
 

3.4	 References for 2013 Annual Review Data Sources, Limitations, and
 

Quality Review ..................................................................................................3-24
 

4. FINAL 2013 ANNUAL REVIEW TOXICITY RANKING ANALYSIS METHODOLOGY
 

AND RESULTS.........................................................................................................................4-1
 

4.1	 Methodology for Generating the Final 2013 Point Source Category
 

Rankings ..............................................................................................................4-1
 

4.1.1	 Categories for Which EPA Has Recently Considered Developing
 

or Revising ELGs or Has Recently Promulgated or Revised ELGs........4-2
 

4.1.2	 Discharges Not Categorizable..................................................................4-2
 

4.2	 Results of the 2013 Toxicity Rankings Analysis.................................................4-3
 

4.3	 EPA’s Review of SIC Code Classifications for Previously Unclassified
 

Facilities...............................................................................................................4-7
 

4.4	 References for the Final 2013 Annual Review TRA Methodology and
 

Results..................................................................................................................4-7
 

5. EPA’S 2013 PRELIMINARY CATEGORY REVIEWS .........................................................5-1
 

5.1	 Prioritization of Categories for Preliminary Category Review............................5-1
 

iv 
TABLE OF CONTENTS (Continued) 

Page 

5.1.1	 Concentrated Aquatic Animal Production (40 CFR Part 451) ................5-2
 

5.1.2	 Meat and Poultry Products (40 CFR Part 432) ........................................5-2
 

5.1.3	 Oil and Gas Extraction (40 CFR Part 435) ..............................................5-2
 

5.1.4	 Ore Mining and Dressing (40 CFR Part 440) ..........................................5-2
 

5.1.5	 Pesticide Chemicals (40 CFR Part 455)...................................................5-3
 

5.1.6	 Fertilizer Manufacturing (40 CFR Part 418) ...........................................5-3
 

5.1.7	 Sugar Processing (40 CFR Part 409) .......................................................5-3
 

5.1.8	 References for the Prioritization for Categories for Preliminary
 

Category Review......................................................................................5-4
 

5.2	 Coal Mining (40 CFR Part 434)...........................................................................5-5
 

5.2.1	 Coal Mining Category Toxicity Rankings Analysis................................5-5
 

5.2.2	 Coal Mining Manufacturing Category Pollutants of Concern.................5-6
 

5.2.3	 Coal Mining Category Iron Discharges in DMR.....................................5-7
 

5.2.4	 Coal Mining Category Mercury Discharges in DMR..............................5-7
 

5.2.5	 Coal Mining Category Sulfate Discharges in DMR ................................5-8
 

5.2.6	 Coal Mining Category Manganese Discharges in DMR .........................5-9
 

5.2.7	 Coal Mining Category Findings.............................................................5-12
 

5.2.8	 References for Coal Mining Category ...................................................5-13
 

5.3	 Drinking Water Treatment (Potential New Category).......................................5-15
 

5.3.1	 DWT Industrial Category 2013 Toxicity Rankings Analysis................5-15
 

5.3.2	 DWT Industrial Category Pollutants of Concern...................................5-16
 

5.3.3	 DWT Industrial Category Total Residual Chlorine Discharges in
 

DMR ......................................................................................................5-17
 

5.3.4	 DWT Industrial Category Aluminum Discharges in DMR ...................5-19
 

5.3.5	 DWT Industrial Category Copper, Mercury, and Lead Discharges
 

in DMR ..................................................................................................5-21
 

5.3.6	 DWT Industrial Category Findings .......................................................5-23
 

5.3.7	 References for DWT Industrial Category..............................................5-24
 

5.4	 Inorganic Chemicals Manufacturing (40 CFR Part 415)...................................5-26
 

5.4.1	 Inorganic Chemicals Category 2013 Toxicity Rankings Analysis........5-26
 

5.4.2	 Inorganic Chemicals Category Pollutants of Concern...........................5-27
 

5.4.3	 Inorganic Chemicals Category Dioxin and Dioxin-Like Compound
 

Discharges in TRI ..................................................................................5-28
 

5.4.4	 Inorganic Chemicals Category Manganese and Manganese
 

Compound Discharges in TRI ...............................................................5-30
 

5.4.5	 Inorganic Chemicals Category Polychlorinated Biphenyl (PCB)
 

Compound Discharges in TRI ...............................................................5-31
 

5.4.6	 Inorganic Chemicals Category Findings................................................5-32
 

5.4.7	 References for Inorganic Chemicals Category ......................................5-33
 

5.5	 Iron and Steel Manufacturing (40 CFR Part 420)..............................................5-35
 

5.5.1	 Iron and Steel Manufacturing Category 2013 Toxicity Rankings
 

Analysis..................................................................................................5-35
 

5.5.2	 Iron and Steel Manufacturing Category Pollutants of Concern.............5-36
 

v 
TABLE OF CONTENTS (Continued) 

Page 

5.5.3	 Iron and Steel Manufacturing Category Fluoride Discharges in
 

DMR ......................................................................................................5-37
 

5.5.4	 Iron and Steel Manufacturing Category Aluminum Discharges in
 

DMR ......................................................................................................5-40
 

5.5.5	 Iron and Steel Manufacturing Category Cyanide Discharges in
 

DMR ......................................................................................................5-43
 

5.5.6	 Iron and Steel Manufacturing Category Total Residual Chlorine
 

Discharges in DMR................................................................................5-45
 

5.5.7	 Iron and Steel Manufacturing Category Findings..................................5-46
 

5.5.8	 References for Iron and Steel Manufacturing Category ........................5-48
 

5.6	 Metal Finishing (40 CFR Part 433) ...................................................................5-50
 

5.6.1 Summary of Metal Finishing ELGs.......................................................5-50
 

5.6.2 History of EPA Reviews of the Metal Finishing Category....................5-52
 

5.6.3 References for Metal Finishing Category..............................................5-56
 

5.7 Nonferrous Metals Manufacturing (40 CFR Part 421)......................................5-57
 

5.7.1 NFMM Category 2013 Toxicity Rankings Analysis.............................5-57
 

5.7.2 NFMM Category Pollutants of Concern................................................5-58
 

5.7.3 NFMM Category Cadmium Discharges in DMR..................................5-58
 

5.7.4 NFMM Category Copper Discharges in DMR......................................5-60
 

5.7.5 NFMM Category Mercury Discharges in DMR....................................5-61
 

5.7.6 NFMM Category PCB Discharges in DMR ..........................................5-62
 

5.7.7 NFMM Category Lead Discharges in DMR..........................................5-63
 

5.7.8 NFMM Category Findings.....................................................................5-65
 

5.7.9 References for NFMM Category ...........................................................5-66
 

5.8 Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414).............5-68
 

5.8.1 OCPSF Category 2013 Toxicity Rankings Analysis.............................5-68
 

5.8.2 OCPSF Category Pollutants of Concern................................................5-69
 

5.8.3 OCPSF Category Hexachlorobenzene Dischargers in DMR.................5-69
 

5.8.4 OCPSF Category Total Residual Chlorine Dischargers in DMR..........5-70
 

5.8.5 OCPSF Category PCB Dischargers in DMR.........................................5-71
 

5.8.6 OCPSF Category Findings.....................................................................5-72
 

5.8.7 References for OCPSF Category ...........................................................5-72
 

5.9 Petroleum Refining (40 CFR Part 419) .............................................................5-75
 

5.9.1 References for Petroleum Refining Category........................................5-79
 

5.10 Pulp, Paper, and Paperboard (40 CFR Part 430) ...............................................5-80
 

5.10.1 Pulp and Paper Category 2013 Toxicity Rankings Analysis.................5-80
 

5.10.2 Pulp and Paper Category Pollutants of Concern....................................5-81
 

5.10.3 Pulp and Paper Category Dioxin Discharges in DMR and TRI ............5-82
 

5.10.4 Pulp and Paper Category Sulfide Discharges in DMR ..........................5-85
 

5.10.5 Pulp and Paper Category Manganese and Manganese Compound
 

Discharges in TRI ..................................................................................5-87
 

5.10.6 Pulp and Paper Category Findings.........................................................5-88
 

5.10.7 References for Pulp and Paper Category ...............................................5-89
 

5.11	 Timber Products Processing (40 CFR Part 429)................................................5-91
 

vi 
TABLE OF CONTENTS (Continued) 

Page 

5.11.1 Timber Products Category 2013 Toxicity Rankings Analysis ..............5-91
 

5.11.2 Timber Products Category Pollutants of Concern .................................5-92
 

5.11.3 Timber Products Category Total Residual Chlorine Discharges in
 

DMR ......................................................................................................5-92
 

5.11.4 Timber Products Category Copper Discharges in DMR .......................5-94
 

5.11.5 Timber Products Category Arsenic Discharges in DMR.......................5-95
 

5.11.6 Timber Products Category Findings ......................................................5-96
 

5.11.7 References for Timber Products Category.............................................5-96
 

PART III: RESULTS OF EPA’S 2013 ANNUAL REVIEW.........................................................III
 

6. RESULTS OF THE 2013 ANNUAL REVIEW........................................................................6-1
 

vii 
LIST OF TABLES
 

Page 

Table 1-1. Point Source Categories Collectively Discharging Over 95% of the Total 

2013 Combined TWPE............................................................................................. 1-1
 

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

Table 3-2. Results of 2011 DMR Data Completeness Check.................................................... 3-11
 

Table 3-3. Summary of 2011 DMR Facility Data Quality Review ........................................... 3-13
 

Table 3-4. Number of Facilities with Data in TRI for Reporting Years 2002 Through
 

2011 ........................................................................................................................ 3-18
 

Table 3-5. Summary of 2011 TRI Facility Review ................................................................... 3-20
 

Table 4-1. Point Source Categories That Have Undergone Recent Rulemaking or Review....... 4-2
 

Table 4-2. Final 2013 Combined Point Source Category Rankings............................................ 4-4
 

Table 4-3. Summary of EPA’s Review of SIC Code Classifications for the Top
 

Previously Unclassified Facilities............................................................................. 4-8
 

Table 5-1. Coal Mining Category TRI and DMR Facility Counts and Discharges for the
 

2011 and 2013 Annual Reviews............................................................................... 5-5
 

Table 5-2. Coal Mining Category Top DMR Pollutants.............................................................. 5-6
 

Table 5-3. Top 2011 DMR Iron Discharging Mines ................................................................... 5-7
 

Table 5-4. Seneca Mine’s 2011 DMR Original and Corrected Iron Discharges ......................... 5-7
 

Table 5-5. Top 2011 DMR Mercury Discharging Mines ............................................................ 5-8
 

Table 5-6. Spartan Mine’s 2011 DMR Original and Corrected Mercury Discharges from
 

Outfall 001................................................................................................................ 5-8
 

Table 5-7. Top 2011 DMR Sulfate Discharging Mines............................................................... 5-9
 

Table 5-8. Peabody’s 2011 Original and Corrected Monthly Sulfate and
 

Flow Discharges from Outfall 003 ........................................................................... 5-9
 

Table 5-9. Top 2011 DMR Manganese Discharging Facilities ................................................. 5-10
 

Table 5-10. Nubay’s 2011 Original and Corrected Monthly Manganese and
 

Flow Discharges ..................................................................................................... 5-10
 

Table 5-11. Texas Westmoreland’s Yearly Manganese DMR Discharges ............................... 5-11
 

viii 
LIST OF TABLES (Continued) 

Page 

Table 5-12. Texas Westmoreland’s 2011 Monthly Manganese and Flow Discharge Data, 

NPDES Manganese Permit Limits, and Coal Mining ELGs Subpart C 

Manganese Limits................................................................................................... 5-12
 

Table 5-13. DWT Industrial Category TRI and DMR Facility Counts and Discharges for
 

the 2011 and 2013 Annual Reviews ....................................................................... 5-15
 

Table 5-14. DWT Industrial Category Top DMR Pollutants .................................................... 5-16
 

Table 5-15. DWT Industrial Category Count of Facilities for 2011 Top DMR Pollutants....... 5-16
 

Table 5-16. Top 2011 DMR Total Residual Chlorine Discharging Facilities........................... 5-17
 

Table 5-17. PRASA Vieja Ponce’s 2011 DMR Original and Corrected Flow and Total
 

Residual Chlorine Discharges for Outfall 001........................................................ 5-18
 

Table 5-18. PRASA Sabana Grande’s 2011 DMR Original and Corrected Flows for
 

Outfall 001.............................................................................................................. 5-18
 

Table 5-19. 2011 DMR Total Residual Chlorine Concentrations (mg/L)................................. 5-19
 

Table 5-20. Top 2011 DMR Aluminum Discharging Facilities................................................ 5-19
 

Table 5-21. Sanford Springs 2011 DMR Original and Corrected Flows for Outfall 001 ......... 5-20
 

Table 5-22. Dekalb 2011 DMR Original and Corrected Flows for Outfall 001........................ 5-20
 

Table 5-23. 2011 DMR Aluminum Concentrations (mg/L) ...................................................... 5-21
 

Table 5-24. 2011 DMR Copper and Lead Concentrations (mg/L)............................................ 5-22
 

Table 5-25. 2011 DMR Mercury Concentrations (mg/L).......................................................... 5-23
 

Table 5-26. Inorganic Chemicals Category TRI and DMR Facility Counts and
 

Discharges for the 2011 and 2013 Annual Reviews............................................... 5-26
 

Table 5-27. Inorganic Chemicals Category Top TRI Pollutants ............................................... 5-27
 

Table 5-28. Top 2011 TRI Dioxin and Dioxin Like Compound Discharging Facilities........... 5-28
 

Table 5-29. Millennium Plant I’s Yearly Dioxin and Dioxin-like Compound TRI
 

Discharges............................................................................................................... 5-29
 

Table 5-30. 2011 Concentrations of Dioxin and Dioxin-Like Compounds in Effluent
 

Samples (pg/L) from Millennium Plant I and EPA Method 1613B Minimum 

Levels...................................................................................................................... 5-29
 

Table 5-31. Top 2011 Manganese and Manganese Compound Discharging Facilities ............ 5-30
 

ix 
LIST OF TABLES (Continued) 

Page 

Table 5-32. Millennium Plant II’s Yearly Manganese and Manganese Compound 

TRI Discharges ....................................................................................................... 5-31
 

Table 5-33. Top 2011 PCB Discharging Facilities.................................................................... 5-31
 

Table 5-34. DuPont Johnsonville’s Yearly PCB TRI Discharges ............................................. 5-32
 

Table 5-35. Iron and Steel Category TRI and DMR Facility Counts and Discharges
 

for the 2011 and 2013 Annual Reviews ................................................................. 5-35
 

Table 5-36. Iron and Steel Manufacturing Category Top DMR Pollutants............................... 5-37
 

Table 5-37. Top 2011 DMR Fluoride Discharging Facilities.................................................... 5-37
 

Table 5-38. Arcelormittal’s 2011 DMR Original and Corrected Fluoride Discharges ............. 5-38
 

Table 5-39. USS Gary Works’ 2011 Monthly Fluoride Discharge and Flow Data................... 5-39
 

Table 5-40. Weirton Steel Corporation’s 2011 Monthly Fluoride Discharge and Flow
 

Data......................................................................................................................... 5-40
 

Table 5-41. Top 2011 DMR Aluminum Discharging Facilities................................................ 5-41
 

Table 5-42. Nucor Steel’s 2011 Monthly Aluminum Concentration and Flow Data................ 5-42
 

Table 5-43. Top 2011 DMR Cyanide Discharging Facilities.................................................... 5-43
 

Table 5-44. USS Clairton Plant Outfall 183 2011 Monthly Cyanide and
 

Flow Discharge Data .............................................................................................. 5-44
 

Table 5-45. Mountain State Carbon’s 2011 Monthly Cyanide and Flow Discharge Data ........ 5-45
 

Table 5-46. Top 2011 Total Residual Chlorine Discharging Facilities..................................... 5-46
 

Table 5-47. USS Clairton Plant’s 2011 Monthly Total Residual Chlorine and Flow
 

Discharge Data for Outfall 038............................................................................... 5-46
 

Table 5-48. Unit Operations Regulated by ELGs for the Metal Finishing Category ................ 5-51
 

Table 5-49. Applicability, Regulated Pollutants, and ELG Limits for the
 

Metal Finishing Category ....................................................................................... 5-51
 

Table 5-50. Maximum Monthly Average Effluent Limits of Part 413, Part 433, and
 

Proposed Part 438................................................................................................... 5-53
 

Table 5-51. Metal Finishing Category Top DMR Pollutants .................................................... 5-55
 

Table 5-52. Metal Finishing Category Top TRI Pollutants ....................................................... 5-55
 

x 
LIST OF TABLES (Continued)

Page 

Table 5-53. NFMM Category TRI and DMR Facility Counts and Discharges for the 

2011 and 2013 Annual Reviews............................................................................. 5-57
 

Table 5-54. 2011 NFMM Category Top DMR Pollutants......................................................... 5-58
 

Table 5-55. Top 2011 DMR Cadmium Discharging Facilities.................................................. 5-59
 

Table 5-56. Nyrstar’s 2011 DMR Monthly Cadmium Discharges............................................ 5-59
 

Table 5-57. Top 2011 DMR Copper Discharging Facilities...................................................... 5-60
 

Table 5-58. Alcoa’s 2011 DMR Original and Corrected Monthly Copper Discharges ............ 5-61
 

Table 5-59. Top 2011 DMR Mercury Discharging Facilities.................................................... 5-62
 

Table 5-60. Top 2011 DMR PCB Discharging Facilities.......................................................... 5-62
 

Table 5-61. U.S. Enrichment Corporation’s 2011 PCB Discharge and Flow Data................... 5-63
 

Table 5-62. Top 2011 DMR Lead Discharging Facilities ......................................................... 5-63
 

Table 5-63. Nyrstar’s 2011 DMR Monthly Lead Discharges.................................................... 5-64
 

Table 5-64. 2011, 2012, and 2013 Lead Discharges from Sanders Lead Company, Inc. ......... 5-65
 

Table 5-65. OCPSF Category TRI and DMR Facility Counts and Discharges for the
 

2011 and 2013 Annual Reviews............................................................................. 5-68
 

Table 5-66. OCPSF Category Top DMR Pollutants.................................................................. 5-69
 

Table 5-67. Top 2011 DMR Hexachlorobenzene Discharging Facilities.................................. 5-70
 

Table 5-68. Top 2011 DMR Total Residual Chlorine Discharging Facilities........................... 5-70
 

Table 5-69. 2011 DMR PCB Discharging Facility.................................................................... 5-71
 

Table 5-70. Petroleum Refining Category TRI and DMR Facility Counts and Discharges
 

for the 2011 and 2013 Annual Reviews ................................................................. 5-76
 

Table 5-71. Petroleum Refining Category Top DMR Pollutants .............................................. 5-76
 

Table 5-72. Petroleum Refining Category Top TRI Pollutants ................................................. 5-77
 

Table 5-73. Petroleum Refining Metals DMR Discharges........................................................ 5-77
 

Table 5-74. Pulp and Paper Category TRI and DMR Facility Counts and Discharges for
 

2011 and 2013 Annual Reviews............................................................................. 5-80
 

Table 5-75. Pulp and Paper Category Top DMR Pollutants...................................................... 5-81
 

xi 
LIST OF TABLES (Continued) 

Page 

Table 5-76. Pulp and Paper Category Top TRI Pollutants ........................................................ 5-82
 

Table 5-77. Top 2011 DMR TCDD Discharging Facilities ...................................................... 5-82
 

Table 5-78. Top 2011 TRI Dioxin and Dioxin-Like Compound Discharging Facilities........... 5-83
 

Table 5-79. 2011 and 2012 Concentrations of Dioxin and Dioxin-Like Compounds from
 

Simpson Tacoma (pg/L) and EPA Method 1613B Minimum Levels .................... 5-85
 

Table 5-80. Top 2011 DMR Sulfide Discharging Facilities...................................................... 5-86
 

Table 5-81. 2002–2011 Manganese and Manganese Compound Discharges in TRI and 

DMR ....................................................................................................................... 5-88
 

Table 5-82. Timber Products Category TRI and DMR Facility Counts and Discharges
 

for the 2011 and 2013 Annual Reviews ................................................................. 5-91
 

Table 5-83. Timber Products Category Top DMR Pollutants ................................................... 5-92
 

Table 5-84. Top 2011 DMR Total Residual Chlorine Discharging Facilities........................... 5-93
 

Table 5-85. Cahaba Timber’s 2011 DMR Total Residual Chlorine and
 

Flow Discharge Data .............................................................................................. 5-93
 

Table 5-86. Top 2011 DMR Copper Discharging Facilities...................................................... 5-94
 

Table 5-87. Ed Arey’s 2011 DMR Copper and Flow Discharge Data ...................................... 5-95
 

Table 5-88. Top 2011 DMR Arsenic Discharging Facilities..................................................... 5-95
 

Table 5-89. Free State Lumber’s 2011 DMR Original and Corrected Arsenic Discharges ...... 5-95
 

xii 
LIST OF FIGURES 

Page 

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

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

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

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

Figure 2-4. Further Review of Industrial Categories Identified During Odd- and
 

Even-Year Annual Reviews ................................................................................... 2-10
 

Figure 5-1. 2009–2013 Sulfide Concentrations for Smurfit-Stone Mill.................................... 5-87
 

xiii 
PART I: INTRODUCTION
 

I
 
Section 1—2013 Annual Review Executive Summary 

1. 2013 ANNUAL REVIEW EXECUTIVE SUMMARY 

Effluent limitations guidelines and standards (ELGs) are an essential element of the 

nation’s clean water program, which was established by the 1972 Clean Water Act (CWA). 

ELGs are technology-based regulations used to control industrial wastewater discharges. EPA 

issues ELGs for new and existing point source categories that discharge directly to surface 

waters, as well as those that discharge to publicly owned treatment works (POTWs). These ELGs 

are applied in permits to limit the pollutants that facilities may discharge. To date, EPA has 

established ELGs to regulate wastewater discharges from 58 point source categories. This 

regulatory program substantially reduces industrial water pollution and continues to be a critical 

aspect of the effort to clean the nation’s waters. 

In addition to developing new ELGs, the CWA requires EPA to revise existing ELGs 

when appropriate. Over the years, EPA has revised ELGs in response to developments such as 

advances in treatment technology and changes in industry processes. To continue its efforts to 

reduce industrial wastewater pollution and fulfill CWA requirements, EPA has established an 

annual review and effluent guidelines planning process with three main objectives: (1) review 

existing ELGs to identify candidates for revision, (2) identify new categories of direct 

dischargers for possible development of effluent guidelines, and (3) identify new categories of 

indirect dischargers for possible development of pretreatment standards. To achieve these 

objectives, EPA conducts a two-step review. First, EPA screens industrial discharges based on 

the relative hazard they pose to human health and the environment. Then, for those categories 

identified as a hazard priority, EPA conducts a more detailed evaluation to determine if the 

category is a candidate for new or revised ELGs. 

For the 2013 Annual Review, EPA conducted a toxicity rankings analysis (TRA) of all 

industrial categories, including those subject to existing ELGs and those not currently regulated 

by ELGs, to prioritize for further review those whose pollutant discharges may pose the greatest 

hazards to human health or the environment because of their toxicity. To identify these industrial 

categories, EPA calculated the industrial categories cumulative percent of the total toxicweighted pound equivalents (TWPE) discharged. As shown in Table 1-1, EPA identified and 

focused its review on the 17 industrial categories that collectively discharge over 95 percent of 

the total TWPE. 

Table 1-1. Point Source Categories Collectively Discharging Over 95% of the Total 

2013 Combined TWPE 

40 CFR 

Part Point Source Category Total TWPE 

Cumulative 

Percentage of 

Total TWPE Rank 

414 Organic Chemicals, Plastics, and Synthetic Fibers 1,690,000 13.1% 1 

430 Pulp, Paper, and Paperboard 1,690,000 26.3% 2 

419 Petroleum Refining 1,430,000 37.4% 3 

NA Drinking Water Treatment 1,390,000 48.2% 4 

440 Ore Mining and Dressing 1,340,000 58.6% 5 

420 Iron and Steel Manufacturing 1,250,000 68.4% 6 

418 Fertilizer Manufacturing 606,000 73.1% 7 

415 Inorganic Chemicals Manufacturing 469,000 76.7% 8 

1-1
 
Section 1—2013 Annual Review Executive Summary 

Table 1-1. Point Source Categories Collectively Discharging Over 95% of the Total 

2013 Combined TWPE 

40 CFR 

Part Point Source Category Total TWPE 

Cumulative 

Percentage of 

Total TWPE Rank 

421 Nonferrous Metals Manufacturing 426,000 80% 9 

455 Pesticide Chemicals 393,000 83.1% 10 

409 Sugar Processing 374,000 86% 11 

433 Metal Finishing 317,000 88.5% 12 

451 Concentrated Aquatic Animal Production 292,000 90.7% 13 

434 Coal Mining 189,000 92.2% 14 

432 Meat and Poultry Products 158,000 93.4% 15 

429 Timber Products Processing 131,000 94.5% 16 

435 Oil and Gas Extraction 106,000 95.3% 17 

Total 2013 Point Source Category Rankings 12,900,000 

Based on the annual review process, data sources, and historical data changes, EPA 

determined that seven of the 17 categories did not warrant a detailed preliminary category review 

as part of the 2013 Annual Review. For these seven categories, many of which have been 

reviewed in detail in prior annual reviews, EPA found that the majority of the TWPE for these 

categories resulted from an easily identifiable error (e.g., incorrect reporting units) associated 

with one or two facilities. For TWPE not associated with data entry errors, EPA did not identify 

any new information to alter the findings made during previous annual reviews (see Section 5.1 

for more information). These industrial categories include: 

 Concentrated Aquatic Animal Production (40 CFR Part 451); 

 Meat and Poultry Products (40 CFR Part 432); 

 Oil and Gas Extraction (40 CFR Part 435); 

 Ore Mining and Dressing (40 CFR Part 440); 

 Pesticide Chemicals (40 CFR Part 455); 

 Fertilizer Manufacturing (40 CFR Part 418); and 

 Sugar Processing (40 CFR Part 409). 

For the remaining 10 of the 17 industrial categories that collectively discharge over 95 

percent of the total TWPE, EPA did not initially identify obvious data entry errors and/or 

determined that the TWPE was attributed to multiple pollutants and facilities. Therefore, EPA 

completed detailed preliminary category reviews for the following categories (see Sections 5.2 

through 5.11 for more information): 

 Coal Mining (40 CFR Part 434); 

 Drinking Water Treatment (potential new category); 

 Inorganic Chemicals Manufacturing (40 CFR Part 415); 

 Iron and Steel Manufacturing (40 CFR Part 420); 

 Metal Finishing (40 CFR Part 433); 

1-2
 
Section 1—2013 Annual Review Executive Summary 

 Nonferrous Metals Manufacturing (40 CFR Part 421);
 

 Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414);
 

 Petroleum Refining (40 CFR Part 419);
 

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

 Timber Products Processing (40 CFR Part 429).
 

From the 10 detailed preliminary category reviews, EPA identified two for which further 

review and study is appropriate: Metal Finishing (40 CFR Part 433) and Petroleum Refining (40 

CFR Part 419). 

	 Metal Finishing (40 CFR Part 433). During the 2012 Annual Review, EPA’s 

review of the Targeted National Sewage Sludge Survey, combined with available 

indirect discharge data from TRI identified the Metal Finishing Point Source 

Category as potentially discharging high concentrations of metals, particularly 

chromium, nickel, and zinc, to POTWs. Additionally, this category ranked high, 

in terms of TWPE in the 2013 TRA. 

	 Petroleum Refining (40 CFR Part 419). During the 2011 Annual Review, EPA 

selected the Petroleum Refining Category (40 CFR Part 419) for a preliminary 

category review because it ranked high, in terms of TWPE (U.S. EPA, 2012). At 

that time, EPA found that the TWPE was largely due to Toxics Release Inventory 

reported discharges of dioxin and dioxin-like compounds, polycyclic aromatic 

compounds, and discharge monitoring report–reported discharges of sulfides, 

chlorine, and metals. EPA continued to review this category during the 2012 

Annual Review to verify facilities’ discharges and confirmed the 2011 Annual 

Review results (U.S. EPA, 2014a). EPA also reviewed new air pollution control 

regulations to identify whether the regulations could result in new wastewater 

streams. Additionally, this category ranked high, in terms of TWPE in the 2013 

TRA. 

For the remaining eight detailed preliminary category reviews, EPA determined that 

further category review was not warranted at this time for one, or more, of the following reasons: 

	 High category TWPE was a result of data entry errors at one or more facilities. 

After correcting these reporting errors, the category TWPE was significantly 

reduced and the category was removed from the top 95 percent of the toxicity 

rankings. 

	 High category TWPE was from one or two facilities that do not represent the 

category discharges as a whole and may be most appropriately controlled by 

facility-specific permitting action. 

	 High category TWPE was a result of discharges that are below facility-specific 

permit limitations or available treatment technology concentrations. 

This report details EPA’s methodology for its 2013 Annual Review and supports EPA 

Office of Water’s Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. 

1-3
 
Section 1—2013 Annual Review Executive Summary 

EPA, 2014b). The Plans, pursuant to Section 304(m) of the Clean Water Act (CWA),1 discuss 

the findings of the 2011, 2012, and 2013 Annual Reviews and detail EPA’s proposed actions and 

follow-up. The Plans also identify any new or existing industrial categories selected for effluent 

guidelines rulemaking and provide a schedule for such rulemaking. 

1.1	 References for 2013 Annual Review Executive Summary 

1.	 U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December). EPA-821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

2.	 U.S. EPA. 2014a. The 2012 Annual Effluent Guidelines Review Report. Washington, 

D.C. (September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824. DCN 07933. 

3.	 U.S. EPA. 2014b. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans. 

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

07756. 

1 Available at: http://water.epa.gov/lawsregs/lawsguidance/cwa/304m/. 

1-4
 
Section 2—Background 

2. BACKGROUND 

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

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

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

decisions (i.e., effluent guidelines planning), including details of its annual review process. 

2.1 The Clean Water Act and the Effluent Guidelines Program 

The Clean Water Act (CWA) is based on the principle of cooperative federalism, with 

distinct roles for both EPA and the states, in which the goal is to restore and maintain the 

chemical, physical, and biological integrity of the nation’s waters. To that end, the act is 

generally focused on two types of controls: (1) water-quality-based controls, based on water 

quality standards, and (2) technology-based controls, based on effluent limitations guidelines and 

standards (ELGs). 

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

revising water quality standards. Water quality standards consist of the following elements: (1) 

designating uses for each water body (e.g., fishing, swimming, supporting aquatic life), (2) 

establishing criteria that protect the designated uses (numeric pollutant concentration limits and 

narrative criteria, e.g., “no objectionable sediment deposits”), and (3) developing an antidegradation policy. EPA develops recommended national criteria for many pollutants, pursuant 

to CWA section 304(a), which the states may adopt or modify as appropriate to reflect local 

conditions. 

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

technologies for controlling industrial wastewater discharges. Permitting authorities (states 

authorized to administer the National Pollutant Discharge Elimination System (NPDES) permit 

program, and EPA in the few states that are not authorized) then must incorporate these 

guidelines and standards into discharge permits as technology-based effluent limitations, where 

applicable (U.S. EPA, 2010). 

While technology-based effluent limitations in discharge permits are sometimes as 

stringent as, or more stringent, than necessary to meet water quality standards, the effluent 

guidelines program is not specifically designed to ensure that the discharges from each facility 

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

requires authorized states to establish water-quality-based effluent limitations, where necessary 

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

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

In the overall context of the CWA, effluent guidelines must be viewed as one tool in the broader 

set of tools and authorities Congress provided to EPA and the states to restore and maintain the 

quality of the nation’s waters. 

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

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

the implementation of available treatment and prevention technologies. 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 

2-1
 
Section 2—Background 

307(c)). See Appendix A of this report for more information on the CWA and an explanation of 

the different levels of control for ELGs. 

Unlike other CWA tools, effluent guidelines are national in scope and establish pollutioncontrol obligations for all facilities within an industrial category or subcategory that discharge 

wastewater. In establishing these controls, under the direction of the statute, EPA assesses, for 

example, (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 the 

affordability of achieving the reduction in pollutant discharge; (3) the cost of achieving effluent 

reductions; (4) non-water-quality environmental impacts (including energy requirements); and 

(5) such other factors as the EPA Administrator deems appropriate. 

Congress saw creating a single national pollution-control requirement for each industrial 

category, based on the best technology the industry can afford, as a way to reduce the potential 

creation of “pollution havens” and to set the nation’s sight on eliminating the discharge of 

pollutants to waters of the US. 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. 

In addition to establishing technology-based effluent limits, 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. ELGs also control pollutant discharges from 

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

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

2.2 Effluent Guidelines Review and Planning Process 

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

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

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

with CWA sections 304(b), 301(d), and 304(g). EPA also reviews industries consisting of directdischarging facilities not currently subject to effluent guidelines to identify potential candidates 

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

reviews industries consisting entirely or almost entirely of indirect-discharging facilities that are 

not currently subject to pretreatment standards, to identify potential candidates for pretreatment 

standards development under CWA section 307(b). 

2.2.1 Effluent Guidelines Review and Prioritization Factors 

In its annual reviews, EPA considers four major factors for prioritizing existing effluent 

guidelines or pretreatment standards for possible revision, or identifying new industries of 

concern through alternate analyses. These factors were developed in EPA’s draft National 

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

2-2
 
Section 2—Background 

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. This enables the Agency to 

set priorities for its rulemaking that will achieve significant environmental and health benefits. 

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

demonstrated wastewater treatment technologies, process changes, or pollution prevention 

alternatives that could effectively reduce 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. 

The third factor EPA considers is the affordability or economic achievability of the 

wastewater treatment technology, process change, or pollution prevention measures identified 

using the second factor. If the financial condition of the industry indicates that it would not be 

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

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

statutory requirements. 

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

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

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

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

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

effectively controlled by other regulatory or non-regulatory programs. 

2.2.2 Annual Review Process 

EPA has instituted a two-step annual review process. In the odd-year reviews, EPA 

screens industrial dischargers through a toxicity ranking analysis (TRA) that identifies and ranks 

those categories whose pollutant discharges pose a substantial hazard to human health and the 

environment (the first draft National Strategy factor). For the TRA, EPA relies on discharge 

monitoring report (DMR) and Toxics Release Inventory (TRI) data to rank and prioritize for 

review industrial discharge categories based on toxic-weighted pound equivalents (TWPE) 

released. EPA relies on facility and state contacts, permits, and publicly available data sources to 

review top ranking industrial categories (see Section 2.2.2.1 for an overview of the odd-year 

annual review and Part II of this report for the specific methodology EPA used for the 2013 

TRA). 

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

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

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

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

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

of discharges from industrial categories.2 Furthermore, EPA recognizes the need to consider in 

the screening phase the availability of treatment technologies, process changes, or pollution2 GAO published its recommendations for the review of additional hazard data sources in its September 2012 report 

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

Treatment Technologies, available online at: http://www.gao.gov/assets/650/647992.pdf. 

2-3
 
Section 2—Background 

prevention practices that can reduce the identified hazards (the second and fourth draft National 

Strategy factors). See Section 2.2.2.2 for an overview of the even-year annual review. 

Using the TRA in the odd-year review in conjunction with additional analyses and hazard 

data in the even-year review, EPA is considering more cohesively and comprehensively the 

factors laid out in its draft National Strategy. This approach allows the Agency to prioritize 

existing effluent guidelines or pretreatment standards for possible revision or identify new 

industries of concern through alternate analyses. 

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

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

health and the environment) in the TRA or are identified as warranting further review during the 

even-year analyses. If EPA determines that further review is warranted for an industrial category, 

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

2.2.2.4), which may eventually lead to a new or revised guideline. 

2.2.2.1 Overview of the Toxicity Ranking Analysis and Odd-Year Annual Reviews 

In the odd-year annual reviews, EPA conducts a TRA using data from the TRI and data 

from DMRs contained in the Permit Compliance System (PCS) and the Integrated Compliance 

Information System for the National Pollutant Discharge Elimination System (ICIS-NPDES). 

Figure 2-1 details how EPA uses the TRA to identify existing ELGs that may warrant revision; 

Figure 2-2 addresses how EPA identifies new categories that may warrant regulation. 

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. Thus, the first step in EPA’s TRA is to relate each 

SIC and NAICS code to an industrial category.3 The second step is to use the information 

reported in TRI and DMR for a specific year to calculate the pounds of pollutant discharged to 

U.S. waters. These calculations are performed for toxic, nonconventional, and conventional 

pollutants. For indirect dischargers, EPA adjusts the facility discharges to account for removals 

at the POTW. The third step is to apply toxic weighting factors (TWFs)4 to the annual pollutant 

discharges to calculate the total discharge of toxic pollutants as TWPE for each facility. 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 estimate based on data in 

TRI and one estimate based on DMR data. EPA combines these two estimates to generate a 

single TWPE value for each industrial category. EPA takes this approach because it found that 

3 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). 4 For more information on TWFs, see Toxic Weighting Factor Development in Support of CWA 304(m) Planning 

Process (U.S. EPA, 2006). 

2-4
 
Section 2—Background 

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.5 

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

identify categories for further review, EPA prioritizes categories accounting for 95 percent of the 

cumulative TWPE from the combined DMR and TRI data. As illustrated in Figure 2-1, EPA 

typically 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.6 EPA also excludes categories in which only a few facilities account for a large 

majority of toxic-weighted pollutant discharges. EPA generally does not prioritize such a 

category for additional review, but suggests that individual permits may be more effective in 

addressing the toxic-weighted pollutant discharges than a national effluent guidelines 

rulemaking. For more information on the results of the 2013 Annual Review, see Section 6. 

As illustrated in Figure 2-2, EPA may also evaluate discharges in the odd-year TRA that 

are associated with SIC or NAICS codes that are not currently regulated or that may be a 

potential new subcategory of an existing ELG. EPA evaluates these discharges to determine if 

new ELGs are warranted for the new industrial category (or subcategory). Similarly, EPA can 

supplement this information with findings from new analyses conducted in the even-year annual 

review and review of treatment technology performance data to identify new industrial 

categories that may warrant ELGs (see Section 2.2.2.2). 

2.2.2.2 Overview of Even-Year Annual Reviews 

In the even-year annual reviews, EPA identifies additional hazard data and reviews 

treatment technologies to augment the TRA completed in each odd-year review. EPA prioritizes 

the review of these additional hazard data sources based on (1) the likelihood of identifying 

unregulated industrial discharges, (2) the utility of identifying new wastewater treatment 

technologies or pollution prevention alternatives, and (3) representativeness of the data for an 

industrial category. These new analyses take into account a broader set of hazard data and 

advancements in treatment technologies. In addition to the new hazard data sources, the evenyear reviews will include information from the public comments received on the Preliminary 

Plan and any continuing preliminary category reviews identified during the odd-year review, as 

illustrated in Figure 2-3. The specific methodologies and analyses of the 2012 Annual Review 

are described in more detail in Section 3 of the EPA’s Final 2012 Effluent Guidelines Program 

Plan and Preliminary 2014 Effluent Guidelines Program Plan (U.S. EPA, 2014). 

2.2.2.3 Preliminary Category Reviews 

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

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

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

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

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

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

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

6 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. 

2-5
 
Section 2—Background 

preliminary category review, particularly if it lacks sufficient data to determine whether 

regulatory action would be appropriate. EPA will complete preliminary category reviews as part 

of the odd- or even-year review cycle depending on the industrial categories warranting further 

review at that time. In its preliminary category reviews EPA typically examines the following: 

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

pollutant discharges, (3) availability of pollution prevention and treatment, (4) the geographic 

distribution of facilities in the industry, (5) any pollutant discharge trends within the industry, 

and (6) any relevant economic factors. In executing preliminary category reviews, EPA first 

attempts to verify the toxicity ranking results and fill in data gaps. These assessments provide an 

additional level of quality assurance on the reported pollutant discharges and number of facilities 

that represent the majority of toxic-weighted pollutant discharge. After the ranking results are 

verified, EPA next considers costs and performance of applicable and demonstrated 

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

pollutants in the point source category’s wastewater. Finally, and if appropriate based on the 

other findings, EPA considers the affordability or economic achievability of the technology, 

process change, or pollution prevention measure identified using the second factor. 

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

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

reporting facilities that can verify reported releases and facility categorization, (4) regulatory 

authorities (states and EPA regions) that can clarify how category facilities are permitted, (5) 

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

development documents, (7) relevant EPA preliminary data summaries or study reports, and (8) 

technical literature on pollutant sources and control technologies. 

2.2.2.4 Preliminary and Detailed Studies 

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

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

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

discharges, gather information about availability and cost of treatment and pollution prevention 

technologies, assess economic achievability, and investigate other factors in order to determine if 

it would be appropriate to identify the category for possible effluent guidelines revision. During 

preliminary or detailed studies, EPA typically examines the factors and data sources listed above 

for preliminary category reviews. However, during a detailed study, EPA’s examination of a 

point source category and available pollution prevention and treatment options is generally more 

rigorous than the analyses conducted during a preliminary category review or a preliminary 

study and may, if appropriate, include primary data collection activities (such as industry 

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

2-6
 
Section 2—Background 

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

2-7
 
Section 2—Background 

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

2-8
 
Section 2—Background 

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

Possible New ELGs
 

2-9
 
Section 2—Background 

Figure 2-4. Further Review of Industrial Categories Identified During Odd- and
 

Even-Year Annual Reviews
 

2-10
 
Section 2—Background 

2.2.3	 Effluent Guidelines Program Plans 

CWA section 304(m)(1)(A) requires EPA to publish an Effluent Guidelines Program 

Plan (Plan) every two years that establishes a schedule for the annual review and revision, in 

accordance with section 304(b), of the effluent guidelines that EPA has promulgated under that 

section. EPA publishes the results of the TRA and preliminary category reviews conducted 

during the odd-year review in a Preliminary Plan and takes public comment. In the even-year 

following publication of the Preliminary Plan, EPA identifies and evaluates additional data 

sources and hazard analyses to supplement the TRA. EPA then publishes a Final Plan in the 

even-year. The Final Plan presents the compilation of the odd- and even-year reviews and public 

comments received on the Preliminary Plan. EPA may initiate, continue, or complete preliminary 

category reviews, or in-depth studies during the odd- or even-year reviews, depending upon 

when it identifies a category warranting further review. Additionally, EPA may publish the 

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

planning cycle the study or review is completed. 

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

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

planning effort because the results of each year of review can inform the content of the 

Preliminary and Final Plans (e.g., by identifying candidates for effluent guidelines revision for 

which EPA can schedule rulemaking in the plans, or by identifying point source categories for 

which EPA has not promulgated effluent guidelines). Second, even though it is not required to 

do so under either section 304(b) or section 304(m), EPA believes it can serve the public interest 

by periodically describing to the public the annual reviews (including the review process used) 

and the results of the reviews. Doing so at the same time as publishing the 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 for each successive review to 

build on the results of earlier reviews. 

2.3	 References for Background 

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

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

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

Effluent Guidelines and Identification of Potential New Point Source Categories. EPA821-R-09-007. Washington, D.C. (October). EPA-HQ-OW-2008-0517-0515. 

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

(September). EPA-833-K-10-001. Available online at: 

http://cfpub.epa.gov/npdes/writermanual.cfm?program_id=45. 

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

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

07756. 

2-11
 
PART II: EPA’S 2013 ANNUAL REVIEW
 

METHODOLOGY AND ANALYSES
 

II
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

3. 2013 ANNUAL REVIEW DATA SOURCES, LIMITATIONS, AND QUALITY REVIEW 

The Clean Water Act (CWA) requires EPA to conduct an annual review of existing 

effluent limitations guidelines and standards (ELGs). It also requires EPA to identify industrial 

categories without applicable ELGs. This section summarizes the process EPA used in the 2013 

Annual Review to identify industrial categories for potential development of new or revised 

ELGs. This section also discusses the data sources used to complete this review and their 

limitations. 

Consistent with its odd year review methodology, EPA performed a toxicity ranking 

analysis (TRA) of all industrial categories, including those subject to existing ELGs and those 

not currently regulated by ELGs, to identify categories discharging high levels of toxic pollutants 

relative to other categories. In performing the TRA, EPA relied on discharge monitoring report 

(DMR) data, contained in EPA’s Permit Compliance System (PCS), the Integrated Compliance 

Information System for the National Pollutant Discharge Elimination System (ICIS-NPDES), 

and the Toxics Release Inventory (TRI). 

In previous years in which it conducted a TRA, EPA generated two databases to facilitate 

the analysis of DMR and TRI data: TRIReleases and DMRLoads. The creation of these databases 

is explained in the Technical Support Document for the Annual Review of Existing Effluent 

Guidelines and Identification of Potential New Point Source Categories (U.S. EPA, 2009), also 

known as the 2009 Screening-Level Analysis (SLA) Report. 

In 2010 EPA launched the DMR Pollutant Loading Tool (the Loading Tool), an online 

application that calculates pollutant loadings from permit and DMR data from PCS and ICISNPDES. The Loading Tool ranks discharges, industries, and watersheds based on pollutant mass 

and toxicity. It also includes wastewater pollutant discharge data from TRI.7 For the 2013 

Annual Review, instead of generating the industrial rankings using the TRIReleases and 

DMRLoads databases as it had in past reviews, EPA relied on the industrial rankings provided in 

the “Top Industrial Dischargers of Toxic Pollutants” area of the Loading Tool.8 The Loading 

Tool’s industrial rankings are calculated using the same methodology presented in the 2009 SLA 

Report (U.S. EPA, 2009), except for one change to the selection of DMR measurement data from 

PCS and ICIS-NPDES, described in Section 3.1. The calculations specific to the Loading Tool 

are documented in the Technical Users Background Document for the Discharge Monitoring 

Report (DMR) Pollutant Loading Tool (U.S. EPA, 2012a). The data sources, and associated 

limitations, used by the Loading Tool to calculate industrial rankings are discussed in Section 

3.2. 

As a first step, EPA downloaded the DMR and TRI industrial rankings data from the 

Loading Tool and performed a quality review of the data, as discussed in Section 3.3. EPA 

incorporated any corrections identified during this review into the Loading Tool. EPA then 

downloaded the corrected DMR and TRI data from the Loading Tool and used these data to 

generate the final point source category rankings (see Section 4.2) and identify industrial 

categories for further review (see Section 5). 

7 See a full overview of the DMR Pollutant Loading Tool here: http://cfpub.epa.gov/dmr/index.cfm.
 8 See the DMR Pollutant Loading Tool page, http://cfpub.epa.gov/dmr/everyday_searches.cfm, which presents the
 

top industrial dischargers of toxic pollutants. EPA used this section of the DMR Pollutant Loading Tool to inform its
 

2013 TRA.
 

3-1
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

This section of the report does not revisit the details of the Loading Tool calculations, but 

instead outlines the change in TRA methodology from previous annual reviews as well as the 

data sources, limitations, data quality review, and the Loading Tool output data for EPA’s 2013 

Annual Review. 

3.1 Methodology Change to the 2013 TRA 

The industrial rankings provided in the “Top Industrial Dischargers of Toxic Pollutants” 

area of the Loading Tool,9 used to inform the TRA for the 2013 Annual Review, are calculated 

using the same methodology presented in the 2009 SLA Report (U.S. EPA, 2009), except for one 

change to the selection of DMR measurement data from PCS and ICIS-NPDES, as discussed in 

this section. 

As described in Section 3.2 of the Technical Users Background Document for the 

Discharge Monitoring Report (DMR) Pollutant Loading Tool, the Loading Tool calculates DMR 

pollutant loadings using a quantity or concentration value, reported in the DMR data, and a 

wastewater flow. There are a total of two quantity and three concentration data fields that can be 

populated in the DMR data (i.e., five measurement value fields): 

 Quantity 1; 

 Quantity 2; 

 Concentration 1; 

 Concentration 2; and 

 Concentration 3. 

These five measurement fields can represent average or maximum quantity values or 

minimum, average, or maximum concentration values. EPA’s goal for calculating pollutant loads 

is to characterize the average pollutant loading; therefore, the Loading Tool selects the 

appropriate DMR measurement data field using a hierarchy that gives priority to the average 

values. 

In previous reviews, because the load calculation using the quantity value necessitated 

fewer variables in the calculation, EPA prioritized average quantities over average 

concentrations. However, the pollutant loading calculation methodology in the Loading Tool 

selects the same DMR measurement as the permit limit, which could be either concentration or 

quantity, to calculate the pollutant load and load over limit estimates. As a result, because EPA 

relied on the Loading Tool outputs for the 2013 Annual Review, the pollutant loadings are 

calculated by prioritizing measurements that are the same measurement as the permit limit 

(concentration or quantity). Even with this change to selecting measurement type, the Loading 

Tool still prioritizes average measurements over minimum and/or maximum measurements. See 

Section 3.2.2 of the Technical Users Background Document for the Discharge Monitoring 

Report (DMR) Pollutant Loading Tool for more specific information on the calculations (U.S. 

EPA, 2012a). 

9 See the DMR Pollutant Loading Tool page: http://cfpub.epa.gov/dmr/everyday_searches.cfm, which presents the 

top industrial dischargers of toxic pollutants. EPA used this section of the DMR Pollutant Loading Tool to inform its 

2013 TRA. 

3-2
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

3.2 Data Sources and Limitations 

This section provides general information on the use and limitations of Standard 

Industrial Classification (SIC) and North American Industry Classification System (NAICS) 

codes, toxic weighting factors (TWFs), TRI data, and DMR data to calculate the industrial 

category rankings in the Loading Tool. 

3.2.1 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. 

 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. 

Although developed to track economic data, 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 four-digit SIC code, reflecting the principal activity causing the 

discharge at each facility. 

EPA does not define the applicability of its ELGs by SIC code, but by industry and 

process descriptions. For this reason, 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 data that identify facilities by SIC code (e.g., PCS and ICIS-NPDES), EPA 

mapped each four-digit SIC code to an appropriate point source category, as summarized in the 

“SIC/Point Source Category Crosswalk” table (Table B-1 in Appendix B). 

EPA has not established national ELGs for all SIC codes. Table B-2 in Appendix B 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). 

3.2.2 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 

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

and to remedy deficiencies of the SIC code system. The nomenclature and format of NAICS and 

SIC codes are presented in Table 3-1. 

Table 3-1. 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 codes 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; 

o	 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; 

o 3222: Converted Paper Product Manufacturing; 

 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. 

EPA does not define the applicability of its ELGs by NAICS code, but by industry and 

process descriptions. For this reason, 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 data that identify facilities by NAICS code (e.g., TRI), EPA mapped each 

six-digit NAICS code to an appropriate point source category, as summarized in the 

“NAICS/Point Source Category Crosswalk” table (Table B-3 in Appendix B). This table was 

based on the SIC/Point Source Category Crosswalk table (Table B-1 in Appendix B) 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 

B-4 in Appendix B lists the NAICS codes for which facility discharge data are available in TRI, 

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

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). 

3.2.3 Toxic Weighting Factors 

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

methodologies to evaluate effluent discharges. Among these tools is 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 uses the Toxics Database to calculate a pollutant-specific TWF that accounts for differences 

in toxicity across pollutants and allows comparison of mass loadings of different pollutants. The 

TWFs are used in the Loading Tool to calculate a “toxic-equivalent” loading (in poundsequivalent per year). The Loading Tool multiplies a mass loading of a pollutant in pounds per 

year by the TWF to derive a toxicity weighted pound equivalent (TWPE). The Draft and Final 

TWF Development Documents discuss the use and development of TWFs in detail (U.S. EPA, 

2005, 2006). 

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 

chose 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, 2006). During the 2013 Annual Review, EPA did not revise any 

TWFs or develop TWFs for chemicals that had not previously had TWFs. Table B-5 in 

Appendix B lists the TWFs for those chemicals in the Loading Tool for which EPA has 

developed TWFs. 

3.2.4 Data from PCS and ICIS-NPDES 

EPA has used data reported to PCS as a part of its TRA of existing effluent guidelines 

since the 2003 Annual Reviews (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. At the time EPA downloaded the 

data from the Loading Tool, 56 of the 71 states and territories/tribes had completely migrated to 

ICIS-NPDES. Therefore, for the 2013 Annual Review, EPA’s view of nationwide discharges 

was split between two sets of data. The Loading Tool combines the two systems (PCS and ICISNPDES) and generates industrial category rankings for all U.S. states and territories/tribes. Both 

PCS and ICIS-NPDES 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 190,000 industrial facilities and 17,000 wastewater treatment plants have 

NPDES individual or general permits10 for wastewater discharges to waters of the U.S. To 

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

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

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

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. Permitting authorities classify 

discharges as major based on an assessment of six characteristics (U.S. EPA, 2010): 

	 Toxic pollutant potential; 

	 Discharge flow: stream flow ratio; 

	 Conventional pollutant loading; 

	 Public health impact; 

	 Water quality factors; and 

	 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. During the 2013 Annual Review, 

EPA identified approximately 6,200 facilities (including sewerage systems) with major 

discharges for which PCS and ICIS-NPDES have extensive records. 

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 

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). During the 2013 Annual Review, EPA 

identified approximated 25,000 facilities with minor discharges for which PCS and ICIS-NPDES 

have extensive records. 

Parameters in PCS and ICIS-NPDES include water quality parameters (such as pH and 

temperature), specific chemicals, conventional parameters (such as biochemical oxygen demand 

and total suspended solids), 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. 

3.2.4.1 Utility of PCS 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. 

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

based on the permit writer’s professional knowledge of those types of activities and discharges (U.S. EPA, 2007). 

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

	 Discharge reports included in PCS and ICIS-NPDES are based on effluent 

chemical analysis and metered flows using known analytical methods. 

	 PCS and ICIS-NPDES include discharge data for facilities in any SIC code. 

3.2.4.2 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. 

	 In some cases, the data systems identify the type of wastewater (e.g., process 

wastewater, stormwater, noncontact cooling water) being discharged. Many do 

not, though, so 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 do not always report the duration of discharge in their DMRs; therefore, 

some pollutant loadings are calculated using continuous discharge assumptions 

(365 days per year), which may overestimate the toxic releases. 

	 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 discharges.11 

	 PCS and ICIS-NPDES were designed as a permit compliance tracking system and 

do not contain production information that would benefit the review of discharges 

compared to production-based limitations. 

	 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 

11 ICIS-NPDES includes a data field for applicable ELGs; however, completion of this field is not required and it is 

typically not populated. 

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

the maximum quantity. Section 3.2.3 of the 2009 SLA Report discusses the 

maximum quantity issue in detail (U.S. EPA, 2009). 

Despite these limitations, EPA determined that the PCS and ICIS-NPDES data 

summarized in the Loading Tool were usable for the TRAs and prioritizations of the toxicweighted pollutant loadings discharged by industrial facilities. The combined PCS and ICISNPDES databases remain the only data source quantifying the pounds of regulated pollutants 

discharged directly to surface waters of the U.S. 

3.2.5	 Data from TRI 

Section 313 of the Emergency Planning and Community Right-to-Know Act requires 

facilities meeting specified thresholds to report their annual releases and other waste 

management activities for listed toxic chemicals to the TRI. Facilities must report the quantities 

of toxic chemicals recycled, collected, and combusted for energy recovery, treated for 

destruction, or otherwise disposed of. Facilities must complete a separate report for each 

chemical manufactured, processed, or used in excess of the reporting threshold. For the 2013 

TRA, EPA used TRI data for reporting year 2011 because they were the most recent available at 

the time the review began. 

A facility must meet three criteria to be required to submit a TRI report for a given 

reporting year: 

1.	 NAICS Code Determination. The facility’s 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 (71 FR 32464). 

The TRI-covered industries include: 

	 212, Mining; 

	 221, Utilities; 

	 31–33, Manufacturing; 

	 All other miscellaneous manufacturing (includes 1119, 1131, 2111, 4883, 

5417, 8114); 

	 424, Merchant Wholesalers, Non-durable Goods; 

	 425, Wholesale Electronic Markets and Agent Brokers; 

	 511, 512, 519, Publishing; 

	 562, Hazardous waste; and 

	 Federal facilities. 

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 who 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. It 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 

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

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, mercury compounds are considered PBT chemicals. 

The TRI reporting guidance requires any facility that manufactures, processes, or 

otherwise uses 10 grams or more of mercury 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 offsite locations, (e.g., 

publicly owned treatment works (POTWs), commercial waste disposal facilities). 

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, TRI guidance indicates that for dioxins and dioxin-like compounds, 

non-detects 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, TRI 

allows facilities to report releases in the following ranges: 1 to 10 pounds, 11 to 499 pounds, and 

500 to 999 pounds. If a facility reports a range for a direct or indirect discharge, TRI uses the 

middle of the range for the TRI output (U.S. EPA, 2013). 

3.2.5.1 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. 

	 TRI includes releases of many toxic chemicals, not just those in facility discharge 

permits. 

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

3.2.5.2 Limitations of TRI 

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

following: 

	 Small establishments (fewer 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. Due to TRI 

guidance, they may overstate releases, especially at facilities with large 

wastewater flows. 

	 Certain chemicals (e.g., polycyclic aromatic compounds (PACs), dioxin and 

dioxin-like 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. 

	 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. 

	 TRI only requires facilities to report certain chemicals; therefore, all pollutants 

discharged from a facility may not be captured. 

Despite these limitations, EPA determined that the TRI data presented in the Loading 

Tool were usable for the 2013 toxicity rankings analysis and prioritization of the toxic-weighted 

pollutant loadings discharged by industrial categories. 

3.2.6	 TRI and DMR Comparative Analysis 

To facilitate EPA’s understanding of the usefulness and limitations of the DMR and TRI 

data, the Loading Tool has a comparison feature that highlights the differences in discharges in 

DMR and TRI at the pollutant and facility level. For example, EPA can compare DMR and TRI 

data to identify the following for an industrial category: 

	 Overestimations in TRI pollutant loadings (identified by comparing reported TRI 

discharges and DMR discharges for the same facility/pollutant loading). 

	 Pollutants not currently regulated or permitted for discharge (identified by TRI 

pollutant loadings for facilities and pollutants that are absent from the DMR data). 

3.3	 2011 DMR and TRI Data Quality Review 

EPA evaluated the quality of the 2011 DMR and TRI data from the Loading Tool to 

identify any data corrections prior to generating the final 2013 point source category rankings 

(see Section 4.2) and further investigating industrial categories for possible effluent guidelines 

revisions (see Section 5). This evaluation considered data completeness, comparability, accuracy, 

and reasonableness. The Environmental Engineering Support for Clean Water Regulations 

Programmatic Quality Assurance Project Plan (PQAPP) describes the quality objectives in 

more detail (ERG, 2013). 

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

3.3.1	 Data Quality Review and Corrections to the 2011 DMR Data 

To evaluate completeness, comparability, accuracy, and reasonableness of the 2011 DMR 

data, EPA performed the following checks: 

Completeness. EPA compared counts of 2011 DMR reporting facilities in the Loading 

Tool to counts in DMRLoads2009 to confirm the completeness of the 2011 DMR data, as shown 

in Table 3-2. Because the numbers of major and minor facilities reporting DMR data are similar 

between 2009 and 2011, EPA determined that the 2011 DMR dataset contained in the Loading 

Tool was complete for the purpose of use in the 2013 Annual Review. 

Table 3-2. Results of 2011 DMR Data Completeness Check 

Number of Major Dischargers Number of Minor Dischargers 

DMR 2009 DMR 2011 DMR 2009 DMR 2011 

1,944 1,908 15,565 14,530 

Sources: DMRLTOutput2011_v1 and DMRLoads2009_v2. 

Comparability. EPA compared the 2011 DMR data from the Loading Tool to 

DMRLoads2009 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 appropriate 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. For a summary of the facilityspecific reviews, see Table 3-3. All of the data corrections identified as part of this review were 

incorporated into the Loading Tool before EPA calculated the final point source category 

rankings. 

Accuracy and Reasonableness. To evaluate the accuracy and reasonableness of the 2011 

DMR data, EPA reviewed the facility and pollutant discharges that had the greatest impact on 

total category loads and rankings in the 2011 DMR Loading Tool, based on toxic-weighted 

pounds discharged. For each identified facility, EPA used the following steps to review the 

accuracy and reasonableness of the loads calculated from PCS and ICIS-NPDES data: 

1.	 Reviewed database corrections from previous TRAs to determine whether 

corrections made during previous reviews should apply to the 2011 DMR 

discharges. 

2.	 Reviewed 2011 DMR facility SIC code information (including the facility’s 

NPDES permit and permit fact sheet) to determine if the facility was assigned to 

the point source category that best applied to the majority of its discharges, or 

identified pollutant-level point source category assignments where facilities have 

operations subject to more than one point source category. 

3.	 Reviewed the Loading Tool’s 2011 DMR facility loading calculations, compared 

Loading Tool data to data available in EPA’s online Envirofacts data system or 

from the facility’s NPDES permit and permit fact sheet, hand-calculated annual 

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

pollutant loads, and compared the results to the 2011 DMR Loading Tool output 

data to verify the accuracy of the calculated facility loads. 

4.	 Reviewed PCS and ICIS-NPDES pipe description information available in PCS, 

EPA’s online Envirofacts data system, ICIS-NPDES supporting tables, or the 

facility’s NPDES permit and permit fact sheet to identify monitored pollutant 

discharges that are: 

—	 Intermittent (e.g., tidal, seasonal, or occurring after a storm); 

—	 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). 

5.	 Reviewed PCS and ICIS-NPDES output data for pollutants that should be 

excluded from the 2011 DMR load calculation because they are in units that 

cannot be converted to quantities (e.g., kilograms per day) or concentrations (e.g., 

milligrams per liter).12 

6.	 Contacted the state permitting authority or facility to determine if the data were 

reported and transcribed correctly. 

Table 3-3 presents EPA’s facility review of the 2011 DMR data. In addition to this 

review, EPA reviewed historical data changes identified during previous TRAs to determine if 

they are still applicable to the 2011 DMR data. Table C-1 in Appendix C of this report lists all 

corrections EPA made to the 2011 DMR data before generating the Final 2013 Point Source 

Category Rankings. 

12 Table A-5 in Appendix A in the Technical Users Background Document for the Discharge Monitoring Report 

(DMR) Pollutant Loading Tool lists pollutants excluded from the Loading Tool (U.S. EPA, 2012a). Examples 

include: temperature, pH, fecal coliform, and whole effluent toxicity. 

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

Table 3-3. Summary of 2011 DMR Facility Data Quality Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

Action Taken/ 

Database Correction 

Elkem Metals 

Company 

Alloy, WV Ferroalloy 

Manufacturing 

Cadmium, lead, 

selenium, arsenic, 

chromium, nickel, 

vanadium, antimony, and 

aluminum 

July through November 2011 metal 

concentrations were six orders of 

magnitude higher than December 

concentrations for all outfalls. Facility 

contact confirmed that July through 

November concentrations needed to be 

divided by 1,000,000 (Wagner, 2013). 

Divided July through 

November metal 

concentrations by 

1,000,000. 

St. Louis Co. 

Water 

St. Louis, MO Drinking Water 

Treatment 

Iron, total residual 

chlorine 

All 2011 iron concentration values for 

outfalls 001, 002, and 003 range from 

11,300 to 322,000 mg/L. All 2011 total 

residual chlorine concentration values 

for outfalls 001 and 002 range from 840 

to 2,300 mg/L. The state contact 

confirmed that iron and total residual 

chlorine concentration values are in 

μg/L, not mg/L (Abernathy, 2013). 

Divided outfall 001, 002, 

and 003 iron 

concentrations by 1,000 

and divided outfall 001 and 

002 total residual chlorine 

concentrations by 1,000. 

Doe Run Company Viburnum, MO Ore Mining and 

Dressing 

Lead, cadmium, zinc, 

copper 

March through September 2011 lead, 

cadmium, zinc, and copper 

concentrations for outfalls 001, 002, and 

003 are 100 to 1,000 higher than 

December 2011 and all 2009 

concentrations. June and September 

2011 flows for outfall 002 are six orders 

of magnitude higher than March and 

December 2011 flows. 

Divided March through 

September 2011 lead, 

cadmium, zinc, and copper 

concentrations by 100 or 

1,000, as appropriate, for 

outfalls 001, 002, and 003. 

Divided outfall 002 June 

and September flows by 

1,000,000. 

Fletcher Mine/Mill Bunker, MO Ore Mining and 

Dressing 

Lead 2011 lead concentrations for outfall 001 

are high. State contact confirmed that 

2011 lead concentrations are in μg/L, 

not mg/L (Abernathy, 2013). 

Divided 2011 lead 

concentrations for outfall 

001 by 1,000. 

Armour Creek 

Landfill 

Nitro, WV Landfills/Waste 

Combustors 

2,3,7,8-TCDD State contact confirmed that 2011 

TCDD concentration for outfall 011 is 

non-detect (Mullins, 2013). 

Zeroed 2011 TCDD 

discharge for outfall 011. 

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

Table 3-3. Summary of 2011 DMR Facility Data Quality Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

Action Taken/ 

Database Correction 

Bullitt County 

Landfill 

Lebanon Junction, 

KY 

Landfills/Waste 

Combustors 

Flow February, March, June, July, November, 

and December 2011 flows for outfalls 

001 and 002 are 10,000 to 100,000 times 

higher than other months’ flows. EPA 

contacted the state during the 2010 

Annual Review and confirmed that large 

flows were reported as GPD, not MGD. 

Because the 2011 flows are off by the 

same order of magnitude, EPA assumes 

the same correction applies (Becker, 

2010). 

Divided February, March, 

June, July, November, and 

December 2011 flows for 

outfalls 001 and 002 by 

10,000 or 100,000, as 

appropriate. 

Brushy Creek 

Mine/Mill 

Bunker, MO Ore Mining and 

Dressing 

Lead, cadmium, zinc, 

copper 

2011 lead, cadmium, zinc, and copper 

concentrations for outfall 001 are high. 

State contact confirmed that 2011 lead, 

cadmium, zinc, and copper 

concentrations are in μg/L, not mg/L 

(Abernathy, 2013). 

Divided 2011 lead, 

cadmium, zinc, and copper 

concentrations for outfall 

001 by 1,000. 

Doe Run Co. West 

Fort Facility 

Bunker, MO Ore Mining and 

Dressing 

Lead, cadmium, zinc, 

copper 

April 2011 lead, cadmium, zinc, and 

copper concentrations for outfall 004 are 

high. State contact confirmed that April 

2011 lead, cadmium, zinc, and copper 

concentrations are in μg/L, not mg/L, for 

outfall 004 (Abernathy, 2013). 

Divided April 2011 lead, 

cadmium, zinc, and copper 

concentrations for outfall 

004 by 1,000. 

Alcoa Inc.—North 

Plant 

Alcoa, TN Aluminum Forming PCB, cyanide State contact confirmed that October 

2011 PCB discharge for outfall N06 is 

non-detect. State contact also confirmed 

that the April 2011 cyanide 

concentration for outfall SW1 should be 

0.01 mg/L, not 0.1 mg/L (Waits, 2013). 

Zeroed October 2011 PCB 

discharge for outfall N06. 

Corrected April 2011 

cyanide discharge to 0.01 

mg/L for outfall SW1. 

IMC Phosphates 

Company— 

Faustina 

Donaldsonville, 

LA 

Inorganic Chemicals Fluoride State contact identified that the June 

2011 fluoride quantity for outfall 002 

was incorrect as a result of a data entry 

error (Peterson, 2013). 

Revised June 2011 fluoride 

quantity for outfall 002 

from 739,000 kg/day to 

1,360 kg/day. 

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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

Table 3-3. Summary of 2011 DMR Facility Data Quality Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

Action Taken/ 

Database Correction 

Reverse Osmosis 

Treatment Facility 

Brighton, CO Drinking Water 

Treatment 

Sulfide The September 2011 sulfide 

concentration is five orders of 

magnitude higher than the other reported 

concentrations for outfall 011. 

Divided the September 

2011 concentration by 

100,000. 

Palm Coast WTP 

#3—Membrane C 

Palm Coast, FL Drinking Water 

Treatment 

Hydrogen sulfide Hydrogen sulfide concentration values 

range from 168 to 300 mg/L for outfall 

001. Facility was contacted as part of the 

2011 Annual Review and it was 

determined that the units for hydrogen 

sulfide were in LB/1000GA instead of 

mg/L (Sedano, 2011). 

Converted the hydrogen 

sulfide concentrations to 

mg/L from LB/1000GA 

(pounds per 1000 gallons 

of water) using 

conversions from the 2011 

Annual Review. 

Forest View MHP Wooster, OH Landfills/Waste 

Combustors 

Ammonia as N January through July 2011 ammonia as 

N concentrations for outfall 001 are four 

to seven orders of magnitude higher than 

permit limitations. 

Divided ammonia as N 

concentrations by 10,000 

or 10,000,000, as 

appropriate. 

Honeywell 

International 

Incorporated 

Baton Rouge, LA Inorganic Chemicals Hexachlorobenzene, 

PACs 

Facility contact confirmed that all 

hexochlorobenzene and polycyclic 

aromatic compounds (PACs) are 

measured below the minimum 

quantification level (MQL). The facility 

permit states that “if any individual 

analytical test result is less than the 

MQL listed in the permit, a value of zero 

may be used for that individual result for 

the DMR calculations and reporting 

requirements.” Previously, the facility 

reported concentrations below the MQL 

as zero. However, for the 2010 and 2011 

DMRs, the facility decided to take a 

more conservative approach in reporting 

and did not list zero for values below the 

MQL (Campesi, 2013). 

Revised 2011 

hexachlorobenzene and 

PACs discharges to be 0 

pounds per year. 

3-15
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

Table 3-3. Summary of 2011 DMR Facility Data Quality Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

Action Taken/ 

Database Correction 

Alcan Rolled Ravenswood, WV Aluminum Forming Lead EPA contacted the state as part of the Zeroed 2011 lead 

Products, LLC 2011 Annual Review and confirmed that 

all 2009 lead measurements were nondetect for outfall 002. Because the 2011 

lead concentration values for outfall 002 

are similar to 2009, EPA assumes the 

same correction applies (Clevenger, 

2011). 

discharges for outfall 002. 

Marion Co. 

Sanitary Landfill 

Lebanon, KY Landfills/Waste 

Combustors 

All pollutants June 2011 flow for outfalls 001 and 002 

is five orders of magnitude higher than 

the March 2011 flow. 

Divided June 2011 flow 

for outfalls 001 and 002 by 

100,000. 

U.S. DOE Paducah West Paducah, Inorganic Chemicals PCB State contact confirmed the 2011 PCB No change. 

Project—Paducah KY discharges for outfall 019 (Hokanson, 

Remediation 2013). 

Services, LLC 

Climax Climax, CO Ore Mining and All pollutants May through July 2011 flows for outfall No change. 

Molybdenum Dressing 001 are high. State contact confirmed 

Company the 2011 flows for outfall 001 (Morgan, 

2013). 

Arkema, Inc. Carrollton, KY Inorganic Chemicals Tin State contact confirmed the 2011 tin 

discharges for outfall 001 (Hokanson, 

2013). 

No change. 

Solutia, Inc. — Anniston, AL Inorganic Chemicals PCB-1242 During the 2011 Annual Review, EPA No change. 

Anniston Plant contacted the facility to confirm similar 

PCB-1242 concentrations and flows for 

outfall 012. The facility contact 

confirmed the data for outfall 012. The 

2011 DMR data for outfall 012 are 

similar in order of magnitude to 2009 

DMR data (Warren, 2011). 

Conservation 

Chemical 

Company 

Kansas City, MO Inorganic Chemicals PCB All 2011 PCB concentrations are below 

the permit limitations. 

No change. 

3-16
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

Table 3-3. Summary of 2011 DMR Facility Data Quality Review 

Facility Location 

Point Source 

Category 

Pollutant(s) 

in Question Review Findings 

Action Taken/ 

Database Correction 

Huber, J.M. 

Corporation 

Havre de Grace, 

MD 

Inorganic Chemicals Sodium sulfate All 2011 sodium sulfate quantities are 

below the permit limitations. 

No change. 

Kennecott 

CorporationSmelter & Refinery 

Magna, UT Ore Mining and 

Dressing 

Arsenic, cadmium, 

copper 

EPA reviewed arsenic, cadmium, 

copper, and flow values for all outfalls. 

No outlier data identified. 

No change. 

Pogo Mine Delta Junction, 

AK 

Ore Mining and 

Dressing 

Arsenic March 2011 arsenic concentration is 

three orders of magnitude higher than 

the other reported concentrations for 

outfall 011. 

Divided March 2011 

arsenic concentration by 

1,000 for outfall 001. 

Mobile Pulley and 

Machine Works 

Mobile, AL Ferroalloy 

Manufacturing 

All pollutants March 2011 flows for outfalls 001, 002, 

and 004 are three to four orders of 

magnitude higher than other months’ 

flows. 

Divided March 2011 flows 

for all outfalls 001, 002, 

and 004 by 1,000. 

Wise Alloys, 

LLC—Alloys Plant 

Muscle Shoals, 

AL 

Aluminum Forming Aluminum 2011 aluminum concentrations and flow 

rates for outfall 004 are high. State 

provided copies of the DMRs for outfall 

004 (Pinson, 2013). 

Updated 2011 aluminum 

concentrations and flow to 

match the state-provided 

DMRs for outfall 004. 

3-17
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

3.3.2 Data Quality Review and Corrections to the 2011 TRI Data 

To evaluate completeness, comparability, accuracy, and reasonableness of the 2011 TRI 

data, EPA performed the following checks: 

Completeness. EPA compared counts of 2011 TRI reporting facilities in the Loading 

Tool to counts in TRIReleases2009, TRIReleases2008, TRIReleases2007, TRIReleases2005, 

TRIReleases2004, TRIReleases2003, TRIReleases2002, and TRIReleases2000 to evaluate the 

completeness of the 2011 TRI data in the Loading Tool, as shown in Table 3-4. Additionally, 

EPA compared the counts of the number of facilities reporting 2011 TRI discharges, per NAICS 

code grouping, to the number of facilities reporting 2009 discharges. This comparison showed 

that for 72 percent of the NAICS code groupings, the number of facilities reporting wastewater 

discharges changed by less than 25 percent from 2009 to 2011. EPA also determined that most 

NAICS codes exhibiting a large percentage change did so because only a few facilities in these 

NAICS codes reported discharges (e.g., a change from one facility to three facilities is equivalent 

to a 200 percent increase). 

Because the number of facilities reporting is similar between 2009 and 2011, EPA 

determined that the 2011 TRI dataset contained in the Loading Tool was complete for the 

purpose of its use in the 2013 Annual Review. 

Table 3-4. Number of Facilities with Data in TRI for Reporting Years 2002 Through 2011 

Reporting Year 

Total 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 

2009 20,797 7,012 

2011 18,391 6,855 

Comparability. EPA compared the 2011 TRI data from the Loading Tool to 

TRIReleases2009 and previous years’ discharges to identify annual pollutant loadings that 

differed more than the year-to-year variation of other chemicals and facilities. EPA used this 

comparison to determine if corrections were appropriate for facility discharges with the highest 

TWPE. If the comparison was unavailable (e.g., the pollutant was not previously reported), EPA 

contacted the facility. For a summary of the facility-specific reviews, see Table 3-5. EPA 

incorporated all of the data corrections identified through this review into the Loading Tool 

before calculating the final point source category rankings. 

Accuracy and Reasonableness. EPA reviewed facility and pollutant discharges that had 

the greatest impact on total category loads and rankings in terms of TWPE discharged. For the 

identified facilities, EPA used the following steps: 

3-18
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

1.	 Reviewed database corrections from previous TRAs to determine whether 

corrections made during previous reviews should apply to the 2011 TRI 

discharges. 

2.	 Reviewed discharges reported to TRI for other reporting years (i.e., 2000, 2002, 

2003, 2004, 2005, 2007, 2008, and 2009) and compared them to discharges 

reported to TRI for reporting year 2011 to identify trends in the discharges. 

3.	 Reviewed 2011 TRI NAICS code information to determine if the facility was 

assigned to the point source category that best applied to the majority of its 

discharges, or identified pollutant-level point source category assignments where 

facilities have operations subject to more than one point source category. 

4.	 Reviewed 2011 DMR data, if available, and hand-calculated annual pollutant 

loads to compare to discharges reported to TRI for reporting year 2011. 

5.	 Verified that the Loading Tool excluded pollutants that should not have an 

associated pollutant load (e.g., yellow or white phosphorus). See Section 3.4.2 in 

EPA’s 2011 Annual Review Report (U.S. EPA, 2012b). 

6.	 Contacted the facility to verify whether the pollutant discharges are reported 

correctly. 

Table 3-5 presents EPA’s detailed facility review and corrections made to the 2011 TRI 

data. In addition to this review, EPA also reviewed historical data changes identified during 

previous TRAs to determine if they are still applicable to the 2011 TRI data. Table C-2 in 

Appendix C of this report lists all corrections EPA made to the 2011 TRI data before generating 

the Final 2013 Point Source Category Rankings. 

3-19
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

Table 3-5. Summary of 2011 TRI Facility Review 

Facility Location 

Point Source 

Category 

Chemical(s) in 

Question Review Findings 

Action Taken/ 

Database Correction 

S. D. Warren Co. Skowhegan, 

ME 

Pulp, Paper, and 

Paperboard 

Dioxin and dioxin-like 

compounds 

Facility contact provided corrected 2011 

dioxin distribution (Schwartz and Wiegand, 

2013). 

Revised dioxin 

distribution. 

Mountain State 

Carbon LLC 

Follansbee, 

WV 

Iron and Steel PACs During the 2011 Annual Review, EPA 

contacted the facility to confirm the PAC 

discharge. The facility contact provided 

PAC sampling data, which provide a 

distribution for the PAC compounds to 

create a facility-specific TWF (Smith, 

2011). The 2011 PAC load is similar in 

order of magnitude to the 2009 PAC load; 

therefore, EPA will apply the same change 

to the facility-specific TWF. 

Revised PACs annual load 

(lb/y) from 330 to 169. 

Calculated TWPE using 

facility-specific TWF. 

Carolina Pole 

Leland 

Leland, NC Timber Products 

Processing 

Dioxin and dioxin-like 

compounds 

Facility contact provided 2010 dioxin 

sampling data, which were used in 

combination with 2011 rainfall data to 

calculate the 2011 TRI load (Rouse, 2013). 

The facility-provided dioxin distribution 

does not match the 2011 TRI dioxin 

distribution. 

Revised dioxin distribution 

to match facility-provided 

sampling data. 

Domtar Paper Co. Bennettsville, 

SC 

Pulp, Paper, and 

Paperboard 

Dioxin and dioxin-like 

compounds 

Based on the non-detect results provided as 

part of the 2011 Annual Review, the dioxin 

data can be zeroed for 2011 (U.S. EPA, 

2012b). 

Zeroed dioxin load. 

Abibow US Inc. — 

Calhoun Operations 

Calhoun, TN Pulp, Paper, and 

Paperboard 

Dioxin and dioxin-like 

compounds 

Based on the non-detect results provided as 

part of the 2011 Annual Review, the dioxin 

data can be zeroed for 2011 (U.S. EPA, 

2012b). 

Zeroed dioxin load. 

3-20
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

Table 3-5. Summary of 2011 TRI Facility Review 

Facility Location 

Point Source 

Category 

Chemical(s) in 

Question Review Findings 

Action Taken/ 

Database Correction 

Graftech 

International 

Holdings Inc. 

Columbia, TN Carbon Black 

Manufacturing 

PACs During the 2010 Annual Review, EPA 

contacted the facility to confirm the PAC 

discharge. The facility contact provided 

PAC sampling data, which provide a 

distribution for the PAC compounds to 

create a facility-specific TWF (Aslinger, 

2010). The 2011 PAC load is similar in 

order of magnitude to the 2008 PAC load; 

therefore, EPA will apply the same change 

to the facility-specific TWF. 

Revised PACs annual load 

(lb/y) from 371 to 134. 

Calculated TWPE using 

the facility-specific TWF. 

St. Paul Park 

Refining Co., LLC 

Saint Paul 

Park, MN 

Petroleum Refining Dioxin and dioxin-like 

compounds 

Facility contact confirmed that an error was 

identified in their 2011 dioxin load 

calculations (Owen, 2013). 

Revised dioxin distribution 

and load. 

Columbian 

Chemicals Co. 

Centerville, 

LA 

Carbon Black 

Manufacturing 

PACs Facility confirmed all 2011 PAC discharges 

are non-detect (Reasoner, 2013). 

Zeroed PAC load. 

Sasol North 

America Inc. Lake 

Charles Chemical 

Complex 

Westlake, LA Organic Chemicals, 

Plastics, and Synthetic 

Fibers 

Dioxin and dioxin-like 

compounds 

Facility contact provided dioxin compound 

sampling data. Facility contact stated that 

distribution and load were calculated using 

half the detection limit for values that were 

non-detect (Hookanson, 2013). These data 

matched the dioxin data requested during 

the 2011 Annual Review. 

Revised dioxin load (lb/y) 

from 0.0009 to 0.0006, and 

revised the dioxin 

distribution. 

Exxonmobil 

Chemical Baton 

Rouge Chemical 

Plant 

Baton Rouge, 

LA 

Organic Chemicals, 

Plastics, and Synthetic 

Fibers 

PACs Facility contact confirmed 2011 TRI PAC 

discharges were estimated from monthly 

sampling results and that all results are nondetect (Labat, 2013). 

Zeroed PAC load. 

3-21
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

Table 3-5. Summary of 2011 TRI Facility Review 

Facility Location 

Point Source 

Category 

Chemical(s) in 

Question Review Findings 

Action Taken/ 

Database Correction 

Hovensa, LLC. Christiansted, 

VI 

Petroleum Refining Dioxin and dioxin-like 

compounds 

The facility was contacted as part of the 

2011 Annual Review. The contact stated 

that the dioxin discharges are estimated 

using literature values associated with 

dioxin formation from reformer catalyst 

regeneration (Vernon, 2011). Hovensa did 

not analyze its wastewater for dioxin or 

furans; therefore, EPA is not certain dioxins 

and furans are actually present in the 

wastewater at concentrations above the 

Method 1613B Minimum Level. As a 

result, EPA concluded that although 

Hovensa’s estimate of releases follows TRI 

program guidance, it may not represent 

actual wastewater discharges (U.S. EPA, 

2014). 

No action. 

Exxonmobil 

Refining & Supply 

Baton Rouge 

Refinery 

Baton Rouge, 

LA 

Petroleum Refining Mercury and mercury 

compounds 

The facility actually detected 0.022 ppm of 

mercury and mercury compounds because 

LDEQ published new lower MQLs for 

metals as part of the water quality standards 

(historically the mercury discharges were 

non-detect because LDEQ had higher 

MQLs (Labat, 2013). 

No action. 

Boise White Paper, 

LLC 

Wallula, WA Pulp, Paper, and 

Paperboard 

Dioxin and dioxin-like 

compounds 

The facility confirmed the 2011 dioxin 

distribution and total grams and stated that 

the same calculation process as previous 

years was used. The reason some congeners 

were detected in 2009 and not in 2011 was 

that in 2009 one-half the detection limit was 

used for the congeners that were reported by 

the testing lab as non-detect. Since 2009, 

these values have been reported as zero 

(Schwartz and Wiegand, 2013). No data 

corrections. 

No action. 

3-22
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

Table 3-5. Summary of 2011 TRI Facility Review 

Facility Location 

Point Source 

Category 

Chemical(s) in 

Question Review Findings 

Action Taken/ 

Database Correction 

Eastman Chemical Kingsport, TN Pesticide Chemicals Arsenic and arsenic The facility contact confirmed that the Mercury and arsenic 

Co., Tennessee compounds, mercury facility uses coal boilers and gasification discharges moved to a new 

Operations and mercury 

compounds, 

hydroquinone 

units onsite. The mercury and arsenic 

compounds are constituents in the coal and 

must be reported for TRI, however, 

sampling indicated that all mercury and 

arsenic discharges were non-detect. Per 

EPA direction, mercury and arsenic 

discharges will be removed to new 

subcategory under steam and the 

concentrations will be zeroed. The facility 

confirmed hydroquinone discharge and 

stated that the data are modeled based on 

influent manufacturing data. No data 

corrections to hydroquinone discharges 

(Smith, 2013). 

subcategory under steam; 

discharges zeroed. 

3-23
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

3.4	 References for 2013 Annual Review Data Sources, Limitations, and Quality Review 

1.	 Abernathy, Travis. 2013. Telephone Communication with Travis Abernathy, Missouri 

Department of Natural Resources, and Kimberly Bartell, Eastern Research Group, Inc., 

Re: 2011 DMR Concentration Values and Units for Fletcher Mine, Brushy Creek Mine, 

Doe Run Co. West Fork Facility, and St. Louis Co. Water. (January 4). EPA-HQ-OW2014-0170. DCN 07777. 

2.	 Aslinger, Julia. 2010. Email Communication between Julia Aslinger, Center for 

Toxicology, and Environmental Health, LLC and Elizabeth Sabol, Eastern Research 

Group, Inc. RE: PAC Discharge Summary. (March 22). EPA-HQ-OW-2008-0517. DCN 

07253. 

3.	 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. 

4.	 Campesi, Brad. 2013. Telephone and Email Communication with Brad Campesi, 

Honeywell International Incorporated, and Kimberly Bartell, Eastern Research Group, 

Inc., Re: 2011 DMR Concentration Values and Units. (February 5). EPA-HQ-OW-2014­

0170. DCN 07942. 

5.	 Clevenger, Renee. 2011. Telephone Communication Between Renee Clevenger, West 

Virginia Department of Environmental Protection (WVDEP), and Kimberly Landick, 

Eastern Research Group, Inc., Re: 2009 DMR Lead Discharges. (May 5). EPA-HQ-OW2010-0824. DCN 07561. 

6.	 ERG. 2013. Eastern Research Group, Inc. Environmental Engineering Support for Clean 

Water Regulations Programmatic Quality Assurance Project Plan (PQAPP). Chantilly, 

VA. (October). EPA-HQ-OW-2010-0824. DCN 07754. 

7.	 Hokanson, Shawn. 2013. Telephone and Email Communication with Shawn Hokanson, 

Kentucky Division of Water, and Elizabeth Sabol, Eastern Research Group, Inc., Re: 

2011 DMR Clarification Needed for Kentucky Facilities. (January 9). EPA-HQ-OW2014-0170. DCN 07943. 

8.	 Hookanson, Steve. 2013. Telephone and Email Communication with Steve Hookanson, 

Sasol North America, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 TRI 

Dioxin Discharges. (January 8). EPA-HQ-OW-2014-0170. DCN 07944. 

9.	 Labat, Stan. 2013. Telephone and Email Communication with Stan Labat, Exxonmobil, 

and Elizabeth Sabol, Eastern Research Group, Inc., Re: 2011 TRI Mercury and PACs 

Discharges. (January 22). EPA-HQ-OW-2014-0170. DCN 07956. 

10.	 Morgan, Kelly. 2013. Telephone Communication with Kelly Morgan, Colorado 

Department of Public Health and Environment, and Elizabeth Sabol, Eastern Research 

Group, Inc., Re: DMR Discharge Flows. (January 9). EPA-HQ-OW-2014-0170. DCN 

07945. 

3-24
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

11.	 Mullins, Gladys. 2013. Email Communication with Gladys Mullins, West Virginia 

Department of Environmental Protection, and Elizabeth Sabol, Eastern Research Group, 

Inc., Re: TCDD and Manganese DMR Discharges. (January 9). EPA-HQ-OW-2014­

0170. DCN 07955. 

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

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

13.	 Owen, Herbert. 2013. Telephone and Email Communication with Herbert Owen, St. Paul 

Park Refining Co., LLC, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 

TRI Dioxin Discharges. (January 7). EPA-HQ-OW-2014-0170. DCN 07946. 

14.	 Peterson, Kelly. 2013. Telephone and Email Communication with Kelly Peterson, 

Louisiana Department of Environmental Quality, and Kimberly Bartell, Eastern Research 

Group, Inc., Re: 2011 DMR Concentration Values and Units. (January 4). EPA-HQ-OW2014-0170. DCN 07947. 

15.	 Pinson, Theo. 2013. Telephone and Email Communication with Theo Pinson, Alabama 

Department of Environmental Management (ADEM), and Kimberly Bartell, Eastern 

Research Group, Inc., Re: 2011 DMR Concentration Values and Units for Wise Alloys 

LLC. (January 7). EPA-HQ-OW-2014-0170. DCN 07948. 

16.	 Reasoner, Michael. 2013. Telephone and Email Communication with Michael Reasoner, 

Columbian Chemicals Co., and Kim Wagoner, Eastern Research Group, Inc., Re: 2011 

TRI PAC Discharges. (January 17). EPA-HQ-OW-2014-0170. DCN 07949. 

17.	 Rouse, Mike. 2013. Telephone and Email Communication with Mike Rouse, Carolina 

Pole Leland, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 TRI Dioxin 

Discharges. (January 8). EPA-HQ-OW-2014-0170. DCN 07950. 

18.	 Schwartz, Jerry and Paul Wiegand. 2013. Telephone and Email Communication Between 

Jerry Schwartz, American Forest and Paper Association, Paul Wiegand, National 

Council for Air and Stream Improvement, and Kimberly Bartell, Eastern Research 

Group, Inc., Re: 2011 TRI Pulp and Paper Dioxin Dischargers. (March). EPA-HQ-OW2014-0170. DCN 07929. 

19.	 Sedano, Monica. 2011. Telephone and E-mail Communication with Monica Sedano, 

Florida Department of Environmental Protection (FL DEP), and Elizabeth Sabol, Eastern 

Research Group, Inc. Re: Hydrogen Sulfide, Unionized Concentrations in DMR 2009. 

(February 24). EPA-HQ-OW-2010-0824. DCN 07687. 

20.	 Smith, Patrick, 2011. Telephone and E-mail Communication with Patrick Smith, 

Mountain State Carbon, and Kimberly Landick, Eastern Research Group, Inc. “RE: 2009 

TRI PAC Discharges”. (January 21). EPA-HA-OW-2010-0824. DCN 07688. 

21.	 Smith, Fredna. 2013. Telephone and Email Communication with Fredna Smith, Eastman 

Chemical Co., Tennessee Operations, and Kim Wagoner, Eastern Research Group, Inc., 

Re: 2011 TRI Arsenic, Mercury, and Hydroquinone Discharges. (January 16). EPA-HQOW-2014-0170. DCN 07951. 

3-25
 
Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review 

22.	 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. 

23.	 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. 

24.	 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. 

25.	 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, D.C. (October). EPA-HQ-OW-2008-0517-0515. 

26.	 U.S. EPA. 2010. U.S. EPA NPDES Permit Writers’ Manual. Washington, DC. 

(September). EPA-833-K-10-001. Available online at: 

http://cfpub.epa.gov/npdes/writermanual.cfm?program_id=45. 

27.	 U.S. EPA. 2012a. Technical Users Background Document for the Discharge Monitoring 

Report (DMR) Pollutant Loading Tool. Available online at: 

http://cfpub.epa.gov/dmr/docs/Technical_Users_Background_Doc.pdf. EPA-HQ-OW2014-0170. DCN 07952. 

28.	 U.S. EPA. 2012b. The 2011 Annual Effluent Guidelines Review Report. Washington, 

D.C. (December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

29.	 U.S. EPA. 2013. Toxics Release Inventory Basic Plus Data File Format Documentation 

v12. Washington, D.C. (July 11). EPA-HQ-OW-2014-0170. DCN 07957. 

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

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

07756. 

31.	 Vernon, Kent. 2011. Telephone and Email Communication Between Kent Vernon, 

Hovensa, and Elizabeth Sabol, Eastern Research Group, Inc., Re: Request for 2009 TRI 

Data Clarification. (January 10). EPA-HQ-OW-2010-0824. DCN 07621. 

32.	 Wagner, Roger. 2013. Telephone Communication with Roger Wagner, Elkem Metals 

Company, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 DMR 

Concentration Values and Units. (March 7). EPA-HQ-OW-2014-0170.DCN 07954. 

33.	 Waits, Dana. 2013. Telephone Communication with Dana Waits, Tennessee Department 

of Environment and Conservation, and Kimberly Bartell, Eastern Research Group, Inc., 

Re: 2011 DMR Concentration Values and Units. (January 4). EPA-HQ-OW-2014-0170. 

DCN 07953. 

34.	 Warren, Lee. 2011. Telephone and E-mail Communication between Lee Warren, Water 

Division of the Alabama Department of Environmental Management, and Kimberly 

Landick, Eastern Research Group, Inc. RE: 2009 DMR Chlorine Discharges at Solutia, 

Inc. (February 24). EPA-HA-OW-2010-0824. DCN 07692. 

3-26
 
Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results 

4.	 FINAL 2013 ANNUAL REVIEW TOXICITY RANKING ANALYSIS METHODOLOGY AND 

RESULTS 

This section presents the methodology and results for the 2013 Toxicity Rankings 

Analysis (TRA) along with EPA’s review of facilities not reporting a Standard Industrial 

Classification (SIC) code in the 2011 discharge monitoring report (DMR) data. 

4.1	 Methodology for Generating the Final 2013 Point Source Category Rankings 

After incorporating the corrections discussed in Section 3.3, EPA downloaded the DMR 

and Toxics Release Inventory (TRI) data from the Loading Tool to a set of databases used for the 

2013 Annual Review: DMRLTOutput2011_v1 and TRILTOutput2011_v1. The databases are 

designed to preserve the integrity of the data and subsequent analyses supporting the 2013 

Annual Review: they are static, while the Loading Tool is based on a dynamic dataset that can 

change over time. (For example, evolving reporting requirements may affect the population of 

facilities reporting to the Permit Compliance System (PCS) or the Integrated Compliance 

Information System for the National Pollutant Discharge Elimination System (ICIS-NPDES) and 

facilities may report data corrections as they are identified.) EPA used the static data in the 

databases to generate the combined Final 2013 Point Source Category Rankings (see Section 4.2) 

and inform its preliminary category reviews (see Section 5). 

See Appendix D of this report for the DMR and TRI category rankings by toxic-weighted 

pound equivalents (TWPE). Specifically, Tables D-1 and D-2 in Appendix D present the 

category rankings by TWPE from the TRIOutput2011_v1 and DMRLTOutput2011_v1 databases, 

respectively. These tables reflect all the corrections described in Section 3.3. Tables D-3 and D-4 

in Appendix D present the six-digit North American Industry Classification System (NAICS) 

code rankings by TWPE from TRIOutput2011_v1 and the four-digit SIC code rankings by 

TWPE from DMRLTOutput2011_v1, respectively. Tables D-5 and D-6 in Appendix D present 

the chemical rankings by TWPE from TRIOutput2011_v1 and DMRLTOutput2011_v1, 

respectively. 

For the 2013 TRA, EPA consolidated the 2011 DMR and TRI point source category 

rankings into one dataset using the following steps: 

	 EPA combined the two lists of point source categories by adding each category’s 

DMRLTOutput2011_v1 TWPE and TRILTOutput2011_v1 TWPE.13 

	 EPA ranked the point source categories based on the total DMRLTOutput2011_v1 

and TRILTOutput2011_v1 TWPE. 

Additionally for the 2013 TRA, EPA eliminated from further consideration the results for 

the following: 

	 Discharges from industrial categories for which EPA recently considered 

developing or revising effluent limitations guidelines and standards (ELGs), or for 

13 Combining DMR and TRI loads may result in “double-counting” of chemical discharges if a facility reported to 

both PCS/ICIS-NPDES and TRI, and “single-counting” of chemicals reported in only one of the data sources. 

Further, the combined TWPE do not count chemicals that may be discharged but are not report to PSC/ICIS-NPDES 

or TRI. 

4-1
 
Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results 

which EPA has recently promulgated or revised ELGs (within the past seven 

years). 

	 Discharges from facilities that require a NPDES permit but do not fall into an 

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

Sections 4.1.1 and 4.1.2 discuss the rationale for these decisions. The final combined 

database rankings represent the results of the 2013 TRA and are presented in Section 4.2. 

4.1.1	 Categories for Which EPA Has Recently Considered Developing or Revising ELGs or 

Has Recently Promulgated or Revised ELGs 

EPA did not consider industrial categories for which it has recently considered 

developing or revising ELGs, because it has thoroughly reviewed these categories separately 

from the annual review process. These categories include the Organic Chemicals, Pesticides, and 

Synthetic Fibers (40 CFR 414) and Inorganic Chemicals Manufacturing (40 CFR 415) point 

source categories for facilities that produce chlorine and chlorinated hydrocarbons, as well as the 

coalbed methane extraction industry. See Section 5 of EPA’s Final 2012 and Preliminary 2014 

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

Similarly, EPA’s 2013 Annual Review excluded point source categories for which ELGs 

were recently established or revised but are not yet fully implemented, as well as categories that 

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

proposal or choose “no action.” In general, EPA removed an industrial point source category 

from further consideration during a review cycle if it had 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 NPDES permits. Table 4-1 lists the categories EPA 

excluded from the 2013 Annual Review due to this seven-year period. 

Table 4-1. Point Source Categories That Have Undergone 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 

449 Airport Deicing May 16, 2012 

EPA also did not consider industrial categories for which it is currently engaged in a 

rulemaking process. These include steam electric power generation, dental amalgam, and oil and 

gas extraction, specifically shale gas extraction. See Section 5.2 of the Final 2012 and 

Preliminary 2014 Plans (U.S. EPA, 2014) for details on the rulemaking status for these 

categories. 

4.1.2	 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). Direct discharges from Superfund sites, whether made 

onsite or offsite, are subject to NPDES permitting requirements (U.S. EPA, 1988a, 1988b). For 

4-2
 
Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results 

the reasons discussed below, EPA determined that these discharges do not fall into a single point 

source category and excluded these TWPE from the point source category rankings. 

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

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

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

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

chemical/ultraviolet oxidation, aerobic biological reactors, chemical 

precipitation). 

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

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

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. 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 best professional judgment approach is workable and flexible within the 

context of a Superfund cleanup. 

4.2	 Results of the 2013 Toxicity Rankings Analysis 

Table 4-2 presents the combined DMRLTOutput2011_v1 and TRILTOutput2011_v1 

rankings. These are the Final 2013 Point Source Category Rankings that support EPA’s 2013 

Annual Review, accounting for all corrections to the data discussed in Section 3.3 and removal 

of any categories and discharges discussed in Section 4.1. 

4-3
 
Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results 

Table 4-2. Final 2013 Combined Point Source Category Rankings 

40 CFR 

Part Point Source Category 

TRILTOutput2011_v1 

TWPE 

DMRLTOutput2011_v1 

TWPE Total TWPE 

Cumulative 

Percentage of 

Total TWPE Rank 

414 Organic Chemicals, Plastics, and Synthetic Fibers 148,000 1,540,000 1,690,000 13.1% 1 

430 Pulp, Paper, and Paperboard 651,000 1,030,000 1,690,000 26.3% 2 

419 Petroleum Refining 681,000 752,000 1,430,000 37.4% 3 

NA Drinking Water Treatment 1,640 1,380,000 1,390,000 48.2% 4 

440 Ore Mining and Dressing 1,230,000 110,000 1,340,000 58.6% 5 

420 Iron and Steel Manufacturing 82,900 1,170,000 1,250,000 68.4% 6 

418 Fertilizer Manufacturing 6,670 599,000 606,000 73.1% 7 

415 Inorganic Chemicals Manufacturing 327,000 142,000 469,000 76.7% 8 

421 Nonferrous Metals Manufacturing 42,900 383,000 426,000 80% 9 

455 Pesticide Chemicals 374,000 19,300 393,000 83.1% 10 

409 Sugar Processing 430 373,000 374,000 86% 11 

433 Metal Finishing 51,700 265,000 317,000 88.5% 12 

451 Concentrated Aquatic Animal Production NA 292,000 292,000 90.7% 13 

434 Coal Mining 564 189,000 189,000 92.2% 14 

432 Meat and Poultry Products 39,100 119,000 158,000 93.4% 15 

429 Timber Products Processing 32,300 98,600 131,000 94.5% 16 

435 Oil and Gas Extraction NA 106,000 106,000 95.3% 17 

463 Plastics Molding and Forming 69,200 26,700 95,900 96% 18 

NA Miscellaneous Foods and Beverages 4,900 57,400 62,300 96.5% 19 

445 Landfills 42,900 19,300 62,200 97% 20 

417 Soap and Detergent Manufacturing 2,370 47,100 49,500 97.4% 21 

424 Ferroalloy Manufacturing 8,990 27,300 36,300 97.7% 22 

436 Mineral Mining and Processing 2,950 31,200 34,100 97.9% 23 

458 Carbon Black Manufacturing 27,900 0.201 27,900 98.2% 24 

4-4
 
Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results 

Table 4-2. Final 2013 Combined Point Source Category Rankings 

40 CFR 

Part Point Source Category 

TRILTOutput2011_v1 

TWPE 

DMRLTOutput2011_v1 

TWPE Total TWPE 

Cumulative 

Percentage of 

Total TWPE Rank 

464 Metal Molding and Casting (Foundries) 9,670 16,300 26,000 98.4% 25 

410 Textile Mills 1,070 22,300 23,400 98.5% 26 

471 Nonferrous Metals Forming and Metal Powders 17,900 3,440 21,300 98.7% 27 

428 Rubber Manufacturing 10,200 7,320 17,500 98.8% 28 

438 Metal Products and Machinery 7,950 7,670 15,600 99% 29 

422 Phosphate Manufacturing 193 13,600 13,800 99.1% 30 

406 Grain Mills 10,500 2,810 13,300 99.2% 31 

457 Explosives Manufacturing 17.4 11,800 11,800 99.3% 32 

469 Electrical and Electronic Components 3,580 8,180 11,800 99.4% 33 

437 Centralized Waste Treatment 2,350 7,860 10,200 99.4% 34 

460 Hospital NA 9,420 9,420 99.5% 35 

468 Copper Forming 6,180 2,610 8,790 99.6% 36 

467 Aluminum Forming 1,300 6,960 8,270 99.6% 37 

439 Pharmaceutical Manufacturing 2,350 4,520 6,870 99.7% 38 

411 Cement Manufacturing 652 5,960 6,620 99.7% 39 

407 

Canned and Preserved Fruits and Vegetables 

Processing 

4,420 1,060 5,480 99.8% 40 

405 Dairy Products Processing 3,770 593 4,360 99.8% 41 

413 Electroplating 4,100 NA 4,100 99.9% 42 

466 Porcelain Enameling 27.8 2,730 2,760 99.9% 43 

444 Waste Combustors 88.2 2,650 2,740 99.9% 44 

NA Printing and Publishing 388 1,890 2,280 99.9% 45 

425 Leather Tanning and Finishing 1,900 8.2 1,910 99.9% 46 

426 Glass Manufacturing 246 1,560 1,800 99.9% 47 

442 Transportation Equipment Cleaning 0.013 1,700 1,700 100% 48 

4-5
 
Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results 

Table 4-2. Final 2013 Combined Point Source Category Rankings 

40 CFR 

Part Point Source Category 

TRILTOutput2011_v1 

TWPE 

DMRLTOutput2011_v1 

TWPE Total TWPE 

Cumulative 

Percentage of 

Total TWPE Rank 

443 Paving and Roofing Materials (Tars and Asphalt) 1,060 581 1,640 100% 49 

461 Battery Manufacturing 870 298 1,170 100% 50 

NA Independent and Stand Alone Labs 4.47 756 761 100% 51 

408 Canned and Preserved Seafood Processing 74.2 686 761 100% 52 

427 Asbestos Manufacturing NA 518 518 100% 53 

454 Gum and Wood Chemicals Manufacturing 33.6 360 394 100% 54 

465 Coil Coating 75 250 325 100% 55 

446 Paint Formulating 86.5 3.05 89.5 100% 56 

NA Food Service Establishments NA 45.6 45.6 100% 57 

NA Industrial Laundries NA 12.6 12.6 100% 58 

NA Tobacco Products 12.5 NA 12.5 100% 59 

447 Ink Formulating 3.61 2.22 5.84 100% 60 

NA Photo Processing NA 0.0628 0.0628 100% 61 

459 Photographic NA 0.0628 0.0628 100% 62 

Total 3,920,000 8,930,000 12,900,000 

Sources: DMRLTOutput2011_v1 and TRILTOutput2011_v1.
 

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

NA: Not applicable.
 

4-6
 
Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results 

4.3	 EPA’s Review of SIC Code Classifications for Previously Unclassified Facilities 

During the 2013 Annual Review, EPA identified 437 facilities that did not report an 

associated SIC code in the 2011 DMR data, corresponding to 6,200,000 TWPE. As a result, the 

TWPE from these facilities was not assigned to and considered as part of the discharge from the 

relevant industrial point source categories. For the 2013 Annual Review, EPA reviewed 10 

facilities that made up the top 99 percent of the TWPE associated with unclassified facilities to 

assign applicable SIC codes/point source categories. Table 4-3 presents EPA’s review of these 

top facilities. EPA plans to incorporate these SIC code changes and data corrections into future 

annual reviews. 

4.4	 References for the Final 2013 Annual Review TRA Methodology and Results 

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.	 Lopez, Victor. 2013. Telephone and Email Communication Between Victor Lopez, 

California Water Resources Control Board, and Kimberly Bartell, Eastern Research 

Group, Inc., Re: DMR Data and Permit Information for CA8000409. (July 12). EPA-HQOW-2014-0170. DCN 07958. 

3.	 Patridge, Michael. 2013. Telephone and Email Communication Between Michael 

Patridge, Illinois EPA, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 

DMR Data. (November 25). EPA-HQ-OW-2014-0170. DCN 07959. 

4.	 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. 

5.	 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. 

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

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

07756. 

4-7
 
Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results 

Table 4-3. Summary of EPA’s Review of SIC Code Classifications for the Top Previously Unclassified Facilities 

Facility Location TWPE 

Review Findings 

Action Taken/Database Correction 

Assigned 

SIC Code SIC Description 

Assigned 

PSC Code 

PSC 

Description 

Latham Water 

Treatment Plant 

Latham, IL 4,110,000 4951 Water Supply 501 Drinking 

Water 

Treatment 

EPA contacted Illinois EPA and determined that flow 

values and concentrations were incorrect for total 

residual chlorine and iron discharges (Patridge, 2013). 

Incorporating the corrections, the facility TWPE is 

reduced to 0.047. 

Gosnold Arms 

Inc. 

New Harbor, 

ME 

667,000 7011 Hotels and 

Motels 

NA NA High TWPE results from discharges of chlorine. EPA 

identified a flow error for outfall 001. Dividing the 

flows by 1,000,000 reduces the facility TWPE to 

0.667. 

North End 

Association 

Southport, 

ME 

517,000 8811 Private 

Household 

NA NA High TWPE results from discharges of chlorine. EPA 

identified a flow error for outfall 001. Dividing flows 

by 1,000,000 reduces the facility TWPE to 0.517. 

Regional Water 

Recycling Plant 

No. 5 

Chino, CA 323,000 4952 Sewerage System NA NA High TWPE results from discharges of copper and 

aluminum. The California Water Board confirmed 

that the units for copper and aluminum were incorrect 

and should be divided by 1,000 (Lopez, 2013). 

Incorporating this change the facility TWPE drops to 

2,000. 

East Capitol 

Island 

Partnership 

Southport, 

ME 

279,000 6541 Operators of 

Dwellings Other 

Than Apartments 

NA NA High TWPE due to discharges of chlorine. EPA 

identified a flow error for outfall 001. Dividing flows 

by 1,000,000 reduces the facility TWPE to 0.279. 

Jasper Wyman & 

Sons 

Cherryfield, 

ME 

138,000 2033 Canned, Frozen, 

and Preserved 

Fruits, and Food 

Specialties 

407 Canned and 

Preserved 

Fruits and 

Vegetables 

Processing 

High TWPE due to discharges of chlorine. EPA 

identified a flow error for outfall 001. Dividing flows 

by 1,000,000 reduces the facility TWPE to 0.138. 

Cullman Filter 

Plant 

Cullman, AL 41,800 4941 Water Supply 501 Drinking 

Water 

Treatment 

High TWPE due to discharges of aluminum and 

chlorine. EPA identified a flow error for outfall 001. 

Dividing flow values by 100 reduces the facility 

TWPE to 445. 

4-8
 
Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results 

Table 4-3. Summary of EPA’s Review of SIC Code Classifications for the Top Previously Unclassified Facilities 

Facility Location TWPE 

Review Findings 

Action Taken/Database Correction 

Assigned 

SIC Code SIC Description 

Assigned 

PSC Code 

PSC 

Description 

North Marshall 

Water Treatment 

Plant 

Grant, AL 38,400 4941 Water Supply 501 Drinking 

Water 

Treatment 

High TWPE due to discharges of aluminum and 

chlorine. EPA identified a flow error for outfall 001. 

Dividing the flow values by 100 reduces the facility 

TWPE to 413. 

Atlantic Blanket 

Company Inc. 

Northport, 

ME 

24,600 2392 House 

Furnishings, Exc 

Curtains 

NA NA High TWPE due to copper and chromium discharges. 

EPA identified a flow error for outfall 001. Dividing 

the flow values by 1,000,000 reduces the facility 

TWPE to 0.0248. 

St. Linden 

Terminal LLC 

Linden, NJ 15,000 5171 Petroleum Bulk 

Station and 

Terminal 

419 Petroleum 

Refining 

High TWPE due to copper and zinc discharges. EPA 

identified a flow error for outfall 001. Dividing the 

flow values by 1,000,000 reduces the facility TWPE 

to 0.123. 

4-9
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.1—Prioritization of Categories for Preliminary Category Review 

5. EPA’S 2013 PRELIMINARY CATEGORY REVIEWS 

Based on its toxicity rankings analysis, EPA was able to prioritize for further review (see 

Section 2.2.2) those industrial categories whose pollutant discharges potentially pose the greatest 

hazards to human health or the environment because of their toxicity. To identify these industrial 

categories, EPA calculated the industrial categories cumulative percent of the total toxicweighted pound equivalents (TWPE). As shown in Table 4-2, EPA identified and focused its 

review on the 17 industrial categories that collectively discharge over 95 percent of the total 

TWPE. 

5.1 Prioritization of Categories for Preliminary Category Review 

Based on its knowledge of the annual review process; data from the Permit Compliance 

System (PCS), the Integrated Compliance Information System for the National Pollutant 

Discharge Elimination System (ICIS-NPDES), and the Toxics Release Inventory (TRI); and 

historical data changes, EPA determined that seven of the 17 categories did not warrant a 

detailed preliminary category review as part of the 2013 Annual Review. For these seven 

categories, many of which have been reviewed in detail in prior annual reviews, EPA found that 

the majority of the TWPE resulted from an easily identifiable error (e.g., incorrect reporting 

units) associated with one or two facilities. For TWPE not associated with data entry errors, EPA 

did not identify any new information to alter the findings made during previous annual reviews. 

These industrial categories, and the reasons for excluding them from further preliminary review, 

are briefly discussed below. 

For the remaining 10 of the 17 industrial categories that collectively discharge over 95 

percent of the total TWPE, EPA did not initially identify obvious data entry errors and/or 

determined that the TWPE was attributed to multiple pollutants and facilities. Therefore, EPA 

completed a detailed preliminary review for these categories to identify whether data corrections 

were necessary or whether the discharges are more appropriately regulated by facility-specific 

permitting action, or may warrant revisions to effluent limitations guidelines and standards. The 

findings from EPA’s preliminary category reviews are discussed in the following subsections of 

this report. The 10 industrial categories identified for detailed preliminary category reviews are 

listed below and discussed in Sections 5.2 through 5.11: 

 Coal Mining (40 CFR Part 434); 

 Drinking Water Treatment (potential new category); 

 Inorganic Chemicals Manufacturing (40 CFR Part 415); 

 Iron and Steel Manufacturing (40 CFR Part 420); 

 Metal Finishing (40 CFR Part 433); 

 Nonferrous Metals Manufacturing (40 CFR Part 421); 

 Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414); 

 Petroleum Refining (40 CFR Part 419); 

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

 Timber Products Processing (40 CFR Part 429). 

5-1
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.1—Prioritization of Categories for Preliminary Category Review 

5.1.1 Concentrated Aquatic Animal Production (40 CFR Part 451) 

The Concentrated Aquatic Animal Production (CAAP) Category total TWPE is 

composed entirely of 2011 discharge monitoring report (DMR) discharges. The 2011 DMR top 

pollutant is copper. EPA identified one facility, Clear Springs Food Inc. in Buhl, ID, which 

accounts for over 99 percent of the 2011 DMR copper TWPE for the CAAP Category. As part of 

the 2013 Annual Review, EPA contacted the state of Idaho to confirm Clear Spring Foods Inc.’s 

copper discharges. The DMRs that the state provided confirmed that the copper concentrations 

were incorrect and that actual discharges did not occur (Gebhardt, 2013). Zeroing the copper 

discharges for the Clear Spring Foods Inc. facility reduces the CAAP Category’s 2011 copper 

TWPE from 289,000 to 2,740 and the total 2011 DMR TWPE from 292,000 to 5,130. The 

category is no longer a priority for the 2013 Annual Review. 

5.1.2 Meat and Poultry Products (40 CFR Part 432) 

For the Meat and Poultry Products (Meat and Poultry) Category, the 2011 DMR TWPE 

accounts for 75 percent of the combined DMR and TRI TWPE. As a result, EPA focused on 

2011 DMR data. The top 2011 DMR pollutant is lead. EPA identified one facility, Equity Group 

Eufaula Div LLC in Eufaula, AL, that accounts for over 99 percent of the 2011 DMR lead 

TWPE for the Meat and Poultry Category. As part of the 2013 Annual Review, EPA contacted 

this facility to confirm its lead discharges. The facility contact indicated that a reporting error had 

been made and all metal concentrations should be divided by 1,000 (Cline, 2013). Correcting this 

error reduces the Meat and Poultry Category’s total 2011 DMR TWPE from 119,000 to 13,700. 

The category is no longer a priority for the 2013 Annual Review. 

5.1.3 Oil and Gas Extraction (40 CFR Part 435) 

For the Oil and Gas Extraction (Oil and Gas) Category, the 2011 DMR TWPE accounts 

for 100 percent of the combined DMR and TRI TWPE. As a result, EPA focused on 2011 DMR 

data. EPA determined that four facilities account for 93 percent of the total 2011 DMR TWPE. 

EPA reviewed these facilities and determined that they are offshore facilities in the Gulf of 

Mexico, regulated by 40 CFR Part 435, Subpart A (Offshore Subcategory). Discharges from 

these facilities are subject to a general permit (GMG290000), issued by EPA Region 6. Through 

facility review, EPA determined that the top pollutants, mercury in barite, in dry weight, and 

cadmium in barite, also in dry weight, should be excluded from the 2011 DMR pollutant loading 

calculations because they are not associated with wastewater discharges. These pollutants are 

associated with solid barite stock used to generate drilling mud (40 CFR Part 435 §435.13) at 

these facilities. The facilities are required to test the solid barite stock to determine if they can 

discharge drilling fluids. Drilling fluids to which barite has been added (if such barite contains 

mercury in excess of 1.0 milligrams per kilogram dry weight, or cadmium in excess of 3.0 

milligrams per kilogram dry weight), have a zero discharge permit requirement. Removing these 

pollutant discharges reduced the Oil and Gas Category’s total 2011 DMR TWPE from 106,000 

to 8,130. The category is no longer a priority for the 2013 Annual Review. 

5.1.4 Ore Mining and Dressing (40 CFR Part 440) 

For the Ore Mining Category, the 2011 TRI TWPE accounts for 92 percent of the 

combined DMR and TRI TWPE. As a result, EPA focused on TRI data. The top pollutants in the 

2011 TRI database are arsenic and arsenic compounds and copper and copper compounds. One 

5-2
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.1—Prioritization of Categories for Preliminary Category Review 

facility, Jerritt Canyon Mine in Elko, NV, accounts for more than 99 percent of the arsenic and 

arsenic compound and copper and copper compound discharges in the 2011 TRI database. As 

part of the 2013 Annual Review, EPA contacted Jerritt Canyon Mine to confirm the arsenic and 

arsenic compound and copper and copper compound discharges. The facility contact indicated 

that a reporting error had been made: all the metal concentrations were supposed to be in parts 

per million but had not been divided by 1,000,000, so they were a factor of six higher than they 

should have been (Barta, 2013). Correcting this error reduces the Ore Mining Category’s 2011 

total TRI TWPE from 1,230,000 to 73,000. The category is no longer a priority for the 2013 

Annual Review. 

5.1.5 Pesticide Chemicals (40 CFR Part 455) 

For the Pesticide Chemicals Category, the 2011 TRI TWPE accounts for 95 percent of 

the combined DMR and TRI TWPE. As a result, EPA focused on TRI data. The top pollutants in 

the 2011 TRI database are toxaphene and chlordane. EPA identified one facility, Weylchem U.S. 

Inc. (Weylchem) in Elgin, SC, that accounts for 100 percent of the 2011 TRI toxaphene and 

chlordane TWPE for the Pesticide Chemicals Category. Weylchem’s heptachlor discharges were 

reviewed in the 2011 Annual Review Report. As part of the 2011 Annual Review, EPA 

compared Weylchem’s 2009 heptachlor TRI discharges to 2009 heptachlor DMR discharges and 

determined that 2009 heptachlor DMR discharges were non-detect. Therefore, EPA revised the 

heptachlor TRI load to zero (see Table 3-3 in the 2011 Annual Review Report, U.S. EPA, 2012). 

As part of the 2013 Annual Review, EPA followed similar steps for Weylchem’s toxaphene and 

chlordane discharges. EPA compared Weylchem’s 2011 toxaphene and chlordane TRI 

discharges to 2011 toxaphene and chlordane DMR discharges and determined that 2011 

toxaphene and chlordane DMR discharges were non-detect. Therefore, EPA revised the 

toxaphene and chlordane TRI load to zero. Incorporating these corrections decreases the 

Pesticide Chemicals Category’s 2011 TRI TWPE from 374,000 to 19,300. The category is no 

longer a priority for the 2013 Annual Review. 

5.1.6 Fertilizer Manufacturing (40 CFR Part 418) 

The Fertilizer Manufacturing Category total TWPE is composed almost entirely of DMR 

discharges and the top 2011 DMR pollutant is fluoride. EPA identified one facility, Mosaic 

Fertilizer LLC, in Uncle Sam, LA, which accounts for over 98 percent of the 2011 DMR fluoride 

TWPE for the Fertilizer Manufacturing Category. Mosaic Fertilizer LLC is a phosphate fertilizer 

manufacturer. Phosphate fertilizer manufacturers are subject to 40 CFR Part 418 Subpart A, 

“Phosphate Subcategory.” The facility was reviewed as part of the 2010 and 2011 Annual 

Reviews. During those reviews, EPA determined that, in accordance with 40 CFR Part 418, the 

facility is exempt from Subpart A and that permit limits are based on facility-specific permitting 

(U.S. EPA 2011, 2012). Further, fluoride discharges for the facility have decreased from 

discharge years 2009 to 2011 (816,000 TWPE in 2009, 534,000 TWPE in 2011). Therefore, EPA 

makes similar conclusions as previous annual reviews: Mosaic Fertilizer LLC does not represent 

the Fertilizer Category as a whole because it is exempt from Part 418 (see 52 FR 28428, July 29, 

1987). The category is no longer a priority for the 2013 Annual Review. 

5.1.7 Sugar Processing (40 CFR Part 409) 

The Sugar Processing Category total TWPE is composed entirely of DMR discharges and 

the top 2011 DMR pollutant is methylmercury. EPA identified one facility, C&H Sugar Co. Inc. 

5-3
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.1—Prioritization of Categories for Preliminary Category Review 

in Crockett, CA, that accounts for 100 percent of the 2011 DMR methylmercury TWPE for the 

Sugar Processing Category. As part of the 2013 Annual Review, EPA contacted the state of 

California to confirm C&H Sugar Co.’s methylmercury discharges. The state indicated that the 

methylmercury concentrations were incorrect; 2011 concentrations were measured in units of 

micrograms per liter, not milligrams per liter as listed on the DMRs (Vasquez, 2013). EPA found 

a similar error with this facility during the 2011 review of the Sugar Processing Category and 

came to similar conclusions (U.S. EPA, 2012). Correcting this error reduces the Sugar 

Processing Category’s 2011 methylmercury TWPE from 368,000 365 and the total 2011 DMR 

TWPE from 373,000 to 5,930. The category is no longer a priority for the 2013 Annual Review. 

5.1.8	 References for the Prioritization for Categories for Preliminary Category Review 

1.	 Barta, John. 2013. Telephone Communication with John Barta, Jerritt Canyon Mine, and 

Julia Kolberg, Eastern Research Group, Inc. “Re: 2011 TRI Discharges.” (December 11). 

EPA-HQ-OW-2014-0170. DCN 07962. 

2.	 Cline, Randy. 2013. Telephone and Email Communication with Randy Cline, Equity 

Group Eufaula Div LLC, and Kimberly Bartell, Eastern Research Group, Inc. “Re: 2011 

DMR Discharges.” (December 13). EPA-HQ-OW-2014-0170. DCN 07960. 

3.	 Gebhardt, Chris. 2013. Telephone and Email Communication with Chris Gebhardt, Idaho 

DEQ, and Julia Kolberg, Eastern Research Group, Inc. “Re: 2011 DMR Discharges.” 

(December 13). EPA-HQ-OW-2014-0170. DCN 07961. 

4.	 U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program 

Plan. Washington, D.C. (October). EPA 820-R-10-021. EPA-HQ-OW-2008-0517. DCN 

07320. 

5.	 U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

6.	 Vasquez, Gil. 2013. Telephone and Email Communication with Gil Vasquez, State Water 

Resources Control Board of California, and Julia Kolberg, Eastern Research Group, Inc. 

“Re: 2011 DMR Discharges for C&H Sugar Co.” (December 13). EPA-HQ-OW-2014­

0170. DCN 07963. 

5-4
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.2—Coal Mining (40 CFR Part 434) 

5.2 Coal Mining (40 CFR Part 434) 

EPA selected the Coal Mining Category for preliminary review because it continues to 

rank high, in terms of toxic-weighted pound equivalents (TWPE), in point source category 

rankings. EPA previously reviewed this industry in the Effluent Guidelines Program Plans from 

2004 to 2006 and in 2011 (U.S. EPA, 2004, 2005, 2006, 2012). EPA also conducted a detailed 

study of the Coal Mining Category during the 2007 and 2008 Annual Reviews (U.S. EPA, 2008). 

This section summarizes the results of the 2013 Annual Review pertaining to the Coal Mining 

Category. EPA focused on discharges of iron, mercury, sulfate, and manganese because of their 

high TWPE relative to other pollutants in the Coal Mining Category. Iron and manganese, 

reviewed as part of the 2011 Annual Review, continue to be top pollutants of concern. For the 

2013 Annual Review, available discharge data also showed significant contributions of mercury 

and sulfate to the Coal Mining Category TWPE. 

5.2.1 Coal Mining Category Toxicity Rankings Analysis 

Table 5-1 compares the toxicity rankings analysis (TRA) results for the Coal Mining 

Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in 2012, but 

instead reviewed additional data sources as part of the even-year annual review, as discussed in 

the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014). As 

discussed in this section, EPA’s review of the Coal Mining Category identified several data 

errors that affected the 2011 Discharge Monitoring Report (DMR) data and TWPE. The bottom 

row of Table 5-1 shows the corrected data resulting from this review. 

Table 5-1. Coal Mining Category TRI and DMR Facility Counts and Discharges for the 

2011 and 2013 Annual Reviews 

Year of 

Discharge 

Year of 

Review 

Coal Mining Category Facility Counts Coal Mining Category 

Total TRI 

Facilities 

Total DMR 

Major Facilities 

Total DMR 

Minor Facilitiesa 

TRI 

TWPEb 

DMR 

TWPEc 

Total 

TWPE 

2009d 2011 24 8 158 1,010 25,600 26,600 

2011 2013 

17 13 199 

564 189,000 190,000 

2011e 2013 564 55,900 56,500 

Source: 2011 Annual Review Report (for 2009d DMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_v1
 

(for 2011 DMR); TRILTOutput2011_v1 (for 2011 TRI).
 

Note: EPA did not evaluate DMR data for 2010.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
 b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
 

POTW removals.
 c DMR discharges from both minor and major facilities.
 d 2009 data after corrections made during the 2011 Annual Review.
 e 2011 data after corrections made during the 2013 Annual Review.
 

As shown in Table 5-1, the total TWPE (incorporating data corrections) increased from 

2009 to 2011. During that period, the number of major and minor DMR facilities increased, 

while the number of TRI facilities decreased. 

It is important to note that discharges for the majority of coal mines are not included in 

the TRI or DMR data. There are over 1,200 active coal mines in the U.S. (U.S. EIA, 2012). TRI 

contains data for facilities in certain SIC codes, including those for coal mining (1221, 1222, and 

5-5
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.2—Coal Mining (40 CFR Part 434) 

1231). However, only coal mines with at least 10 full-time employees or their equivalent, and 

that manufacture, use, or otherwise process certain chemicals at or above an activity threshold 

report to TRI (U.S. EPA, 2009). The 2008 Coal Mining Detailed Study found that only 21 coal 

mines had data in TRI (U.S. EPA, 2008); only 17 coal mines had data in the 2011 TRI database 

(TRILTOutput2011_v1). For DMR data, many states classify coal mines as “minor dischargers” 

and, as a result, do not enter DMR data into EPA’s ICIS-NPDES or PCS systems.14 EPA’s 2008 

Detailed Study for the Coal Mining Point Source Category found that fewer than one-fourth of 

the coal mines were represented in the EPA’s DMR storage system (U.S. EPA, 2008). 

5.2.2 Coal Mining Manufacturing Category Pollutants of Concern 

For its 2013 annual review, EPA’s review of the Coal Mining Category focused on the 

2011 DMR discharges because the 2011 DMR data dominate the category’s combined TWPE. 

Table 5-2compares the five pollutants with the highest contribution to the 2011 DMR TWPE. 

Table 5-2 also presents the 2011 DMR TWPE after EPA corrected errors identified in this 

preliminary category review (discussed in the sections below). In addition, as a point of 

comparison, Table 5-2 shows the 2009 DMR TWPE for these top five pollutants based on the 

results of (and corrections identified in) the 2011 Annual Review (U.S. EPA, 2012). 

Iron, mercury, sulfate, and manganese contribute approximately 92 percent of the total 

2011 DMR TWPE. EPA’s investigations of reported discharges of the top four pollutants are 

described in Sections 5.3 to 5.6. EPA did not investigate the other pollutants as part of the 2013 

Annual Review, including total residual chorine, because they represent approximately 8 percent 

of the 2011 DMR TWPE for the Coal Mining Category. 

Table 5-2. Coal Mining Category Top DMR Pollutants 

Pollutant 

2011 DMR Dataa 2009 DMR Dataa 

Number of Facilities 

Reporting Pollutant 

Original 

TWPE 

Corrected 

TWPE TWPE 

Iron 192 57,100 12,200 6,460 

Mercury 16 50,900 11,000 6,190 

Sulfate 68 42,500 880 1,960 

Manganese 96 22,900 16,500 8,240 

Total Residual Chlorine 10 4,260 4,260b 28.9 

Top Pollutants, Total NA 178,000 44,900 22,900 

Coal Mining Category, Total 212c 189,000 55,900 25,600 

Sources: DMRLTOutput2011_v1 (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE) 

(U.S. EPA, 2012)
 

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

NA: Not applicable.
 a DMR data include major and minor dischargers.
 b Total residual chlorine discharges contribute 2 percent of the 2011 category DMR TWPE. Therefore, EPA did not
 

review total residual chlorine discharges as part of the 2013 Annual Review.
 c Number of facilities reporting TWPE greater than zero.
 

14 The 2011 DMR database has data for 13 major and 205 minor coal mines (DMRLTOutput2011_v1). Because EPA 

does not ask the permitting authority to enter data for minor facilities into the DMR database, this is a small 

percentage of the over 1,000 active coal mines in the U.S. For further details on major and minor discharges in DMR 

data, see Section3.2.4 of this report. 

5-6
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.2—Coal Mining (40 CFR Part 434) 

5.2.3 Coal Mining Category Iron Discharges in DMR 

EPA’s investigation of the iron discharges revealed that Seneca Mine, in Hayden, CO, 

accounts for 79 percent of the 2011 DMR iron discharges (shown in Table 5-3). EPA did not 

investigate the remaining mines discharging iron. 

Table 5-3. Top 2011 DMR Iron Discharging Mines 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Seneca Mine (Seneca Coal Co.) Hayden, CO 8,020,000 44,900 79% 

All other iron dischargers in the Coal Mining Categorya 2,180,000 12,200 21% 

Total 10,200,000 57,100 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 191 other mines that have iron discharges in the 2011 DMR data.
 

Seneca Mine in Hayden, CO discharges iron from nine outfalls. The facility no longer 

operates as a mine, but monitoring of discharges continues as the surrounding areas undergo 

remediation (Cochran, 2013). As part of the 2013 Annual Review, EPA contacted the mine about 

their 2011 iron discharges. Seneca Mine provided corrected discharge concentrations after 

identifying a unit error for seven outfalls (Cochran, 2013). Table 5-4 presents Seneca Mine’s 

2011 original and corrected yearly average iron concentrations, along with the average flow 

values reported in the DMR Pollutant Loading Tool for the nine outfalls. Using these corrected 

values, Seneca Mine’s iron TWPE decreases from 44,900 to 46.5, reducing the Coal Mining 

Category’s iron TWPE from 57,100 to approximately 12,200, as shown in Table 5-2. 

Table 5-4. Seneca Mine’s 2011 DMR Original and Corrected Iron Discharges 

Outfall 

Original Average Flow 

(MGD) 

Original Average Iron 

Concentration (mg/L) 

Corrected Concentration 

(mg/L) 

005 0.245 643 0.643 

006 0.587 255 0.255 

008 0.357 0.170 0.170 

010 0.483 243 0.243 

011 0.069 251 0.251 

012 0.188 293 0.365 

013 0.021 0.233 0.233 

016 0.362 635 0.635 

017 1.08 580 0.578 

Source: DMRLTOutput2011_v1; Cochran, 2013. 

5.2.4 Coal Mining Category Mercury Discharges in DMR 

EPA’s investigation of the mercury discharges revealed that Spartan Mine in Sparta, IL 

accounts for 78 percent of the 2011 DMR mercury compound discharges (shown in Table 5-5). 

EPA did not investigate the remaining mines discharging mercury. 

5-7
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.2—Coal Mining (40 CFR Part 434) 

Table 5-5. Top 2011 DMR Mercury Discharging Mines 

Facility Name 

Facility 

Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Spartan Mine (Alpena Vision Resources) Sparta, IL 341 39,900 78% 

All other mercury dischargers in the Coal Mining Categorya 94 11,000 22% 

Total 435 50,900 100% 

Source: DMRLTOutput2011_v1.
 a There are 15 remaining mines that have mercury discharges in the 2011 DMR data.
 

Spartan Mine in Sparta, IL, is the top mercury discharging mine. The mine closed in 

1998; since closing, its activities are limited to reclamation. Spartan Mine discharges acid mine 

drainage from coal refuse piles. Discharges from Outfall 001 contain mercury and flow into a 

pond that serves as a tributary to Mary’s River (IL EPA, 2010). During the quarter when the 

pond is discharging, the mine collects and analyzes pollutant concentrations from a minimum of 

nine grab samples (IL EPA, 2010). As part of the 2013 Annual Review, EPA contacted the mine 

about their 2011 mercury concentrations and received corrected discharge concentrations. The 

facility contact indicated that the 2011 mercury concentrations were reported in units of 

micrograms per liter instead of nanograms per liter, as they were measured (Voshel, 2013). Table 

5-6 presents the original and corrected concentrations, and average flow rates from the mine. 

Using the corrected concentrations, the mine’s mercury TWPE decreases from 39,900 to 0.11, 

reducing the Coal Mining Category’s mercury TWPE from 50,900 to 11,000, as shown in Table 

5-2. 

Table 5-6. Spartan Mine’s 2011 DMR Original and Corrected Mercury Discharges 

from Outfall 001 

Monitoring Period Average Flow (MGD) 

Original Average Iron 

Concentration (mg/L) 

Corrected Concentration 

(mg/L) 

31-Jan-11 0.86 0.69 0.00000069 

31-May-11 0.86 0.58 0.00000058 

31-Dec-11 0.36 0.0000054 0.0000054 

Sources: DMRLTOutput2011_v1; Voshel, 2013. 

5.2.5 Coal Mining Category Sulfate Discharges in DMR 

EPA’s investigation of the sulfate discharges revealed that Peabody Midwest Mining, 

LLC (Peabody) in Ridge Farm, IL accounts for 98 percent of the 2011 DMR sulfate discharges 

(shown in Table 5-7). EPA did not investigate the remaining mines discharging sulfate. 

5-8
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.2—Coal Mining (40 CFR Part 434) 

Table 5-7. Top 2011 DMR Sulfate Discharging Mines 

Facility Name Facility Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Peabody Midwest Mining, LLC Ridge Farm, IL 7,440,000,000 41,700 98% 

All other sulfate dischargers in the Coal Mining Categorya 150,000,000 841 2% 

Total 7,590,000,000 42,500 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 67 remaining mines that have sulfate discharges in the 2011 DMR data.
 

Peabody in Ridge Farm, IL, discharges sulfate from outfall 003. In reviewing the 

concentration of the mine’s 2011 sulfate discharges, EPA noted that the March 2011 

concentration was 10,000 times greater than other months (see Table 5-8). As part of the 2013 

Annual Review, EPA requested Peabody’s 2011 DMR reports from the Illinois Environmental 

Protection Agency (IL EPA). The discharge and concentration information provided by the state 

listed a monthly minimum for March 2011 of 498 mg/L and a monthly maximum of 647 mg/L 

(IL EPA, 2013), which is consistent with the order of magnitude of the sulfate discharges 

reported for the other months. As a result, EPA assumed that the unusually high sulfate 

concentration was a unit reporting error, and corrected the value by dividing the March 2011 

sulfate concentration by 10,000. Table 5-8 presents Peabody’s 2011 original and corrected 

monthly sulfate concentrations along with the flow discharges for outfall 003. Using the 

corrected value of 586 mg/L for the March 2011 sulfate concentration, Peabody’s sulfate TWPE 

decreases from 41,700 to 39.1, reducing the Coal Mining Category’s sulfate TWPE from 42,500 

to 880, as shown in Table 5-2. 

Table 5-8. Peabody’s 2011 Original and Corrected Monthly Sulfate and
 

Flow Discharges from Outfall 003
 

Monitoring Period 

Datea 

Original Average Flow 

(MGD) 

Original Sulfate 

Concentration (mg/L) 

Corrected Sulfate 

Concentration (mg/L) 

31-Jan-11 4.92 677 677 

28-Feb-11 12.6 500 500 

31-Mar-11 4.91 5,856,667 586 

31-Apr-11 19.4 486 486 

31-May-11 4.73 292 292 

30-June-11 6.84 398 398 

31-Oct-11 0.38 789 789 

30-Nov-11 0.38 789 789 

31-Dec-11 1.37 969 969 

Source: DMRLTOutput2011_v1.
 a The mine reported no flow for July, August, and September 2011. Therefore, sulfate concentrations were not
 

reported for those months.
 

5.2.6 Coal Mining Category Manganese Discharges in DMR 

EPA’s investigation of the manganese discharges revealed that Nubay Mining LLC 

(Nubay Mining) in Galatia, IL, and Texas Westmoreland Coal Co. (Texas Westmoreland) in 

5-9
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.2—Coal Mining (40 CFR Part 434) 

Jewett, TX, account for 41 percent of the 2011 DMR sulfate discharges (shown in Table 5-7). 

EPA did not investigate the remaining mines discharging manganese. 

Table 5-9. Top 2011 DMR Manganese Discharging Facilities 

Facility Name Facility Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Nubay Mining LLC Galatia, IL 93,800 6,570 29% 

Texas Westmoreland Coal Co. Jewett, TX 40,700 2,850 12% 

All other manganese dischargers in the Coal Mining Categorya 193,000 13,500 59% 

Total 327,000 22,900 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 94 remaining mines that have manganese discharges in the 2011 DMR data.
 

Nubay Mining 

Nubay Mining in Galatia, IL, discharges manganese from outfalls 002, 005, and 009. In 

reviewing 2011 DMR manganese discharges from the mine, EPA noted that the September 2011 

average flow from outfall 002 and the April 2011 average flow from outfall 009 were 1,000 

times higher than other flows from these outfalls. As shown in Table 5-10, EPA concluded that 

these reported flows were in error and corrected the average flow from these outfalls. 

Incorporating the data correction, Nubay Mining’s manganese TWPE decreases from 6,570 to 

129, reducing the Coal Mining Category’s manganese TWPE from 22,900 to 16,500, as shown 

in Table 5-2. 

Table 5-10. Nubay’s 2011 Original and Corrected Monthly Manganese and 

Flow Discharges 

Outfall 

Monitoring 

Period Datea 

Original Average Flow 

(MGD) 

Corrected Average Flow 

(MGD) 

Original Manganese 

Concentration (mg/L) 

002 30-Apr-11 0.4 0.4 0.75 

002 31-May-11 1.72 1.72 0.75 

002 30-June-11 1.72 1.72 1.76 

002 30-Sep-11 1,730 1.73 0.19 

002 31-Dec-11 1.72 1.72 0.65 

005 31-Jan-11 3.45 3.45 .002 

005 28-Feb-11 1.72 1.72 .001 

005 31-Mar-11 1.72 1.72 0.21 

005 30-Sep-11 3.45 3.45 0.002 

005 31-Dec-11 3.45 3.45 0.19 

009 30-Apr-11 500 0.5 0.079 

009 31-May-11 0.3 0.3 0.074 

5-10
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.2—Coal Mining (40 CFR Part 434) 

Table 5-10. Nubay’s 2011 Original and Corrected Monthly Manganese and
 

Flow Discharges
 

Outfall 

Monitoring 

Period Datea 

Original Average Flow 

(MGD) 

Corrected Average Flow 

(MGD) 

Original Manganese 

Concentration (mg/L) 

009 30-Nov-11 0.3 0.3 0.002 

009 31-Dec-11 0.3 0.3 0.032 

Source: DMRLTOutput2011_v1.
 a The mine reported no flow for January, February, March, July, August, October and November 2011 from outfall
 

002; April, May, June, July, August, October and November from outfall 005; and January, February, March, June,
 

July, August, September, and October 2011 from outfall 009. Therefore, manganese concentrations were not
 

reported for those months.
 

Texas Westmoreland 

Texas Westmoreland in Jewett, TX, discharges manganese from outfalls 001, 003, and 

004. The mine is a surface mine for bituminous coal and lignite (Envirofacts). As shown in Table 

5-11, EPA did not identify any obvious reporting errors or data corrections; manganese 

discharges have remained consistent from 2007-2011. 

Table 5-11. Texas Westmoreland’s Yearly Manganese DMR Discharges 

Year of Discharge 

Total Manganese Pounds 

Discharged 

Total Manganese TWPE 

Discharged 

2007 34,300 2,400 

2008 48,300 3,380 

2009 21,200 1,480 

2010 31,700 2,220 

2011 40,700 2,850 

Source: DMRLTOutput2011_v1. 

According to ICIS-NPDES, Texas Westmoreland’s NPDES permit limits the 

concentration of manganese in the mine’s discharges to not more than 1 milligram per day 

monthly average and 2 milligrams per day daily maximum for all three outfalls (DMR Pollutant 

Loading Tool). Table 5-12 presents the mine’s reported 2011 manganese discharges. Table 5-12 

also presents the mine’s NPDES permit limits and the Coal Mining effluent limitations 

guidelines and standards (ELGs) limits for manganese for the Acid or Ferruginous Mine 

Drainage subcategory (Subcategory C). See Section 4 of the Coal Mining Detailed Study for 

additional details on the Coal Mining ELGs (U.S. EPA, 2008). As shown in Table 5-12, the 

mine’s reported 2011 manganese discharges do not exceed its permit limits or the Coal Mining 

ELGs. 

5-11
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.2—Coal Mining (40 CFR Part 434) 

Table 5-12. Texas Westmoreland’s 2011 Monthly Manganese and Flow Discharge Data,
 

NPDES Manganese Permit Limits, and Coal Mining ELGs Subpart C Manganese Limits
 

2011 Monthly Manganese and 

Flow Discharge Data 

NPDES Manganese 

Permit Limits 

Coal Mining ELGs 

Subpart C Manganese 

Limits 

Outfall 

Monitoring 

Period Date a 

Average 

Flow 

(MGD) 

Average 

Manganese 

Discharge 

(mg/L) 

Daily 

Maximum 

(mg/L) 

Monthly 

Average 

(mg/L) 

Daily 

Maximum 

(mg/L) 

Monthly 

Average 

(mg/L) 

001 31-Jan-11 34.8 0.96 2 1 4 2 

001 28-Feb-11 22.7 0.2 2 1 4 2 

001 31-Mar-11 28.4 0.71 2 1 4 2 

001 30-Apr-11 30.1 0.53 2 1 4 2 

001 31-May-11 31.8 0.64 2 1 4 2 

001 31-Jul-11 23.6 0.11 2 1 4 2 

001 30-Sep-11 40.7 0.44 2 1 4 2 

001 31-Dec-11 33.5 0.73 2 1 4 2 

003 31-Jan-11 14.1 0.06 2 1 4 2 

003 28-Feb-11 11 0.05 2 1 4 2 

003 31-Mar-11 2.9 0.14 2 1 4 2 

003 30-Apr-11 2.91 0.08 2 1 4 2 

003 31-May-11 2.9 0.79 2 1 4 2 

003 30-Jun-11 14.8 0.12 2 1 4 2 

003 31-Jul-11 0.84 0.16 2 1 4 2 

003 30-Sep-11 4.53 0.01 2 1 4 2 

003 31-Dec-11 34.7 0.02 2 1 4 2 

004 31-May-11 4.8 0.03 2 1 4 2 

Source: DMRLTOutput2011_v1; Coal Mining Point Source Category BPT, BAT, BCT Limitations and New Source
 

Performance Standards—40 CFR Part 434.
 

BAT: Best available technology economically achievable.
 

BPT: Best practicable control technology.
 

NSPS: New source performance standards.
 a The mine reported no flow for June, August, October and November 2011 from outfall 001; August, October and
 

November 2011 from outfall 003; and January, February, March, April, June, July, August, September, October,
 

November and December 2011 from outfall 004. Therefore, manganese concentrations were not reported for those
 

months.
 

5.2.7	 Coal Mining Category Findings 

The estimated toxicity of the Coal Mining Category discharges resulted from iron, 

mercury, sulfate, and manganese discharges. From the 2013 Annual Review, EPA has identified 

the following: 

	 One facility, Seneca Mine, contributes the majority of the iron discharges to the 

2011 DMR data. EPA identified a significant error in the concentration data for 

iron for six of the nine outfalls discharging iron. With these errors corrected, the 

mine’s iron TWPE decreases from 44,900 to 46.5, reducing the Coal Mining 

Category’s iron TWPE from 57,100 to 12,200. 

5-12
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.2—Coal Mining (40 CFR Part 434) 

	 One facility, Spartan Mine, contributes the majority of the mercury discharges to 

the 2011 DMR data. EPA identified an error in the concentrations reported for the 

mine, which the facility contact corrected. With this error corrected, the mine’s 

mercury TWPE decreases from 39,900 to 0.11, reducing the Coal Mining 

Category’s mercury TWPE from 50,900 to 11,000. 

	 One facility, Peabody Midwest Mining, LLC, contributes the majority of the 

sulfate discharges to the 2011 DMR data. EPA identified a significant error in the 

sulfate concentration reported in March 2011. With this error corrected, the 

mine’s TWPE decreased from 41,700 to 39.1, reducing the Coal Mining 

Category’s sulfate TWPE from 42,500 to 880. 

	 Two mines, Nubay Mining LLC and Texas Westmoreland Coal Co., contribute 

the majority of the manganese discharges in the 2011 DMR data. EPA confirmed 

manganese discharges for the Texas Westmoreland facility were below NPDES 

permit limits, as well as under the Coal Mining ELGs. EPA identified an error in 

the reported flow rates for Nubay Mining LLC. With this error corrected, the 

mine’s TWPE decreased from 6,570 to 129, reducing the Coal Mining Category’s 

manganese TWPE from 22,900 to 16,500. 

	 Correcting the reporting errors identified during the 2013 Annual Review 

decreases the 2011 Coal Mining Category TWPE from 190,000 to 56,500. This 

change would drop the category outside the top 95 percent that EPA prioritized 

for preliminary review as part of the 2013 Annual Review. 

5.2.8	 References for Coal Mining Category 

1.	 Cochran, John. 2013. Telephone Communication with John Cochran, Peabody 

Investment Corporation (Parent Company of Seneca Mine), and Julia Kolberg, Eastern 

Research Group, Inc. Re: 2011 DMR Iron Discharges. (December 19). EPA-HQ-OW2014-0170. DCN 07872. 

2.	 ERG. 2014. Preliminary Category Review – Facility Data Review and Revised 

Calculations for Point Source Category 434 – Coal Mining. (March). EPA-HQ-OW2014-0170. DCN 07884. 

3.	 IL EPA. 2010. Illinois Environmental Protection Agency. NPDES Permit: Alpena Vision 

Resources LLC, Spartan Mine, Sparta, IL. (February 1). EPA-HQ-OW-2014-0170. DCN 

07873. 

4.	 IL EPA. 2013. Illinois Environmental Protection Agency. DMR Data for IL0074802 – 

Peabody Midwest Mining LLC. Available online at: 

http://dataservices.epa.illinois.gov/dmrdata/dmrsearch.aspx. Accessed: December 9. 

EPA-HQ-OW-2014-0170. DCN 07874. 

5.	 U.S. EIA. 2012. United States Energy Information Administration. 2012 Historic Coal 

Production Data. Available online at: http://www.eia.gov/coal/data.cfm#production. 

Accessed: February 7, 2014. EPA-HQ-OW-2014-0170. DCN 07875. 

6.	 U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program 

Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346 

through 1352. 

5-13
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.2—Coal Mining (40 CFR Part 434) 

7.	 U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial 

Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004­

0032-0016. 

8.	 U.S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program 

Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032­

2782. 

9.	 U.S. EPA. 2008. Coal Mining Detailed Study. EPA-821-R-08-012. Washington, D.C. 

(August). EPA-HQ-OW-2006-0771-1695. 

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

Effluent Guidelines and Identification of Potential New Point Source Categories. EPA821-R-09-007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515. 

11.	 U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

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

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

07756. 

13.	 Voshel, Anne. 2013. Telephone Communication with Anne Voshel, Alpena Vision 

Resources – Spartan Mine, and Julia Kolberg, Eastern Research Group, Inc. Re: 2011 

DMR Mercury Discharges. (December 31). EPA-HQ-OW-2014-0170. DCN 07876. 

5-14
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.3—Drinking Water Treatment (Potential New Category) 

5.3 Drinking Water Treatment (Potential New Category) 

EPA selected the Drinking Water Treatment (DWT) industrial category for preliminary 

review because it continues to rank high, in terms of toxic-weighted pound equivalents (TWPE), 

in the point source category rankings. The DWT industrial category is not currently regulated by 

national effluent limitations guidelines and standards (ELGs); however, EPA reviewed these 

discharges to determine if a new regulatory category is appropriate for controlling wastewater 

discharges. 

EPA reviewed discharges from the DWT industrial category as part of the 2004 Annual 

Review, because at that time DWT ranked high in terms of TWPE relative to the other categories 

and was identified as a potential category of concern by public commenters (U.S. EPA, 2004). In 

2011, EPA published the results of the industrial category review, which included a literature 

review, site visits, and a survey of the DWT industry. A summary of the information collected as 

part of the review can be found in EPA’s Drinking Water Treatment Plant Residuals 

Management Technical Report: Summary of Residuals Generation, Treatment, and Disposal at 

Large Community Wastewater Systems (the 2011 DWT Report) report (U.S. EPA, 2011). As 

stated in the 2011 DWT Report, EPA determined that NPDES permits (individual and general) 

best control discharges from these facilities. 

This section summarizes the results of the 2013 Annual Review pertaining to the DWT 

industrial category. EPA focused on discharges of total residual chlorine and metals, which were 

also the focus of prior reviews, because of their high TWPE relative to the other pollutants 

discharged by establishments in this industrial category. 

5.3.1 DWT Industrial Category 2013 Toxicity Rankings Analysis 

Table 5-13 compares the toxicity rankings analysis (TRA) results for the DWT Category 

from the 2011 and 2013 Annual Reviews. As discussed in this section, EPA’s review of the 

DWT Category identified data errors that affect the 2011 DMR data and TWPE. The bottom row 

of Table 5-13 shows the corrected data resulting from this review. 

Table 5-13. DWT Industrial Category TRI and DMR Facility Counts and Discharges for 

the 2011 and 2013 Annual Reviews 

Year of 

Discharge 

Year of 

Review 

DWT Category Facility Counts DWT Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilitiesa 

TRI 

TWPEb 

DMR 

TWPEc 

Total 

TWPE 

2009 2011 3 7 854 132 408,000 408,000 

2011 2013 

2 18 1,005 1,640 1,380,000 1,390,000 

2011d 2013 1,640 974,000 976,000 

Sources: DMRLTOutput2011_v1 (for 2011 DMR), TRILTOuptut2011_v1 (for 2011 TRI), DMRLoads2009_v2 (for
 

2009 DMR), and TRIReleases2009_v2 (for 2009 TRI).
 

Note: EPA did not evaluate DMR data for 2010.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
 b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
 

POTW removals.
 c DMR discharges from both minor and major facilities.
 d 2011 data after corrections made during the 2013 Annual Review.
 

5-15
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.3—Drinking Water Treatment (Potential New Category) 

5.3.2 DWT Industrial Category Pollutants of Concern 

EPA’s 2013 Annual Review of the DWT industrial category focused on 2011 DMR 

discharges because the 2011 DMR data account for the majority of the industrial category’s 

combined TWPE (over 99 percent). Table 5-14 lists the five pollutants with the highest 

contribution to the 2011 DMR TWPE. Table 5-14 also presents the 2011 DMR TWPE after EPA 

corrected errors identified in this preliminary category review (discussed in the sections below). 

As a point of comparison, Table 5-14 provides the 2009 DMR TWPE for these top five 

pollutants. Consistent with the 2011 industry review of DWT facilities, for the 2013 Annual 

Review, EPA identified that total residual chlorine, aluminum, and copper contributed the 

highest amount of TWPE to DWT discharges. However, as shown in Table 5-14, the 2011 DMR 

TWPE for the DWT industrial category (after corrections identified during this annual review) 

has more than doubled since 2009. 

Table 5-14. DWT Industrial Category Top DMR Pollutants 

Pollutant 

2011 DMR Dataa 2009 DMR Dataa 

Number of Facilities 

Reporting Pollutant 

Original 

TWPE 

Corrected 

TWPE TWPE 

Total Residual Chlorine 644 416,000 181,000 131,000 

Aluminum 250 346,000 171,000 214,000 

Copper 137 127,000 127,000 12,300 

Mercury 52 113,000 113,000 159 

Lead 98 110,000 110,000 1,640 

Top Pollutant Total NA 1,110,000 701,000 359,000 

DWT Category Total 1,023a 1,380,000 974,000 408,000 

Sources: DMRLTOutput2011_v1 and DMRLoads2009_v2.
 

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

NA: Not applicable.
 a DMR data include major and minor dischargers.
 b Number of facilities reporting TWPE greater than zero.
 

As shown in Table 5-15, increases in total residual chlorine, copper, mercury, and lead 

are driving the increase in the category’s TWPE. Table 5-15 also shows that the total number of 

facilities reporting DMR discharges for the top five pollutants has increased by more than 60 

percent for copper, mercury, and lead from 2009 to 2011. 

Table 5-15. DWT Industrial Category Count of Facilities for 2011 Top DMR Pollutants 

Pollutant 

Number of Facilities Reporting 

Pollutant in 2009 DMR Data 

Number of Facilities Reporting 

Pollutant in 2011 DMR Data 

Total Facility 

Count Percent 

Major Minor Total Major Minor Total Increase 

Total Residual Chlorine 5 542 547 10 634 644 18% 

Aluminum 1 233 234 2 248 250 7% 

Copper 5 79 84 12 125 137 63% 

Mercury 1 30 31 6 46 52 68% 

Lead 2 57 59 7 91 98 66% 

Source: DMRLTOutput2011_v1 and DMRLoads2009_v2. 

5-16
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.3—Drinking Water Treatment (Potential New Category) 

For the 2013 Annual Review of the DWT industrial category, EPA investigated all top 

five DMR pollutants for the category. However, because of the large number of facilities in the 

DWT industrial category, EPA only reviewed the top facilities reporting total residual chlorine 

and aluminum discharges to verify reported data and identify anomalous data points that might 

need correction. The results of EPA’s 2013 Annual Review are presented in sections 5.3.3 

through 5.3.5. 

5.3.3 DWT Industrial Category Total Residual Chlorine Discharges in DMR 

EPA identified 644 drinking water treatment facilities with 2011 DMR total residual 

chlorine discharges. Two facilities, PRASA WTP PTA Vieja Ponce and PRASA WTP Sabana 

Grande, account for 58 percent of the 2011 DMR total residual chlorine discharges (shown in 

Table 5-16). EPA did not investigate the remaining facilities discharging total residual chlorine 

as part of the 2013 Annual Review. 

Table 5-16. Top 2011 DMR Total Residual Chlorine Discharging Facilities 

Facility Name Facility Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

PRASA WTP PTA Vieja Ponce Ponce, PR 397,000 199,000 48% 

PRASA WTP Sabana Grande Sabana Grande, PR 80,700 40,400 10% 

Remaining Facilities Reporting Total Residual Chlorine 

Dischargesa 353,000 177,000 42% 

Total 831,000 416,000 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 642 remaining facilities that have total residual chlorine discharges in the 2011 DMR data.
 

PRASA WTP PTA Vieja Ponce 

PRASA WTP PTA Vieja Ponce (PRASA Vieja Ponce) in Ponce, Puerto Rico, discharges 

total residual chlorine from outfall 001. In reviewing the facility’s 2011 DMR total residual 

chlorine data, EPA noted that the October 2011 flow and total residual chlorine concentration 

were at least one order of magnitude higher than the other 2011 flows and concentrations. As 

shown in Table 5-17, EPA determined that the reported October 2011 flow and concentration 

were in error and corrected these values. These corrections decreased the facility’s total residual 

chlorine TWPE from 199,000 to 3,700. This change reduced the 2011 DMR total residual 

chlorine TWPE by 195,000. Additionally, the facility has a total residual chlorine permit limit of 

0.5 mg/L (DMR Pollutant Loading Tool). PRASA Vieja Ponce exceeded its permit limit nine 

months out of the year. Therefore, facility-specific permitting action may be appropriate to 

address total residual chlorine discharges from PRASA Vieja Ponce. 

5-17
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.3—Drinking Water Treatment (Potential New Category) 

Table 5-17. PRASA Vieja Ponce’s 2011 DMR Original and Corrected Flow and Total
 

Residual Chlorine Discharges for Outfall 001
 

Monitoring Period 

Date 

Original Average 

Flow (MGD) 

Corrected 

Average Flow 

(MGD) 

Original Average Total 

Residual Chlorine 

Concentration (mg/L) 

Corrected Average 

Total Residual 

Chlorine 

Concentration (mg/L) 

31-Jan-2011 0.34 0.34 0.57 0.57 

28-Feb-2011 0.41 0.41 1.31 1.31 

31-Mar-2011 0.52 0.52 2.1 2.1 

30-Apr-2011 0.26 0.26 4.1 4.1 

31-May-2011 1.48 1.48 4.8 4.8 

30-Jun-2011 0.75 0.75 1.87 1.87 

31-Jul-2011 1.33 1.33 0.46 0.46 

31-Aug-2011 0.89 0.89 0.73 0.73 

30-Sep-2011 0.52 0.52 0.49 0.49 

31-Oct-2011 53.6 5.36 28.4 2.84 

30-Nov-2011 0.73 0.73 0.51 0.51 

31-Dec-2011 0.61 0.61 0.46 0.46 

Source: DMRLTOutput2011_v1. 

PRASA WTP Sabana Grande 

PRASA WTP PTA Vieja Ponce (PRASA Sabana Grande) in Sabana Grande, Puerto 

Rico, discharges total residual chlorine from outfall 001. In reviewing the facility’s 2011 DMR 

total residual chlorine data, EPA noted that the reported February 2011 flow was at least three 

orders of magnitude higher than the other 2011 flows. As shown in Table 5-18, EPA determined 

that the reported February 2011 flow was in error and corrected the flow. This correction 

decreased the facility’s total residual chlorine TWPE from 40,400 to 52.6. This change reduced 

the 2011 DMR total residual chlorine TWPE by 40,300. 

Table 5-18. PRASA Sabana Grande’s 2011 DMR Original and Corrected Flows for
 

Outfall 001
 

Monitoring Period Date Original Average Flow (MGD) Corrected Average Flow (MGD) 

31-Jan-2011 0.079 0.079 

28-Feb-2011 500 0.05 

31-Mar-2011 0.105 0.105 

30-Apr-2011 0.107 0.107 

31-May-2011 0.064 0.064 

30-Jun-2011 0.057 0.057 

31-Jul-2011 0.091 0.091 

31-Aug-2011 0.11 0.11 

30-Sep-2011 0.032 0.032 

31-Oct-2011 0.084 0.084 

30-Nov-2011 0.202 0.202 

31-Dec-2011 0.17 0.17 

Source: DMRLTOutput2011_v1. 

5-18
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.3—Drinking Water Treatment (Potential New Category) 

Further Review of 2011 DMR Total Residual Chlorine Discharges 

Additionally, EPA reviewed the information on total residual chlorine discharges 

collected as part of the 2011 review of the DWT industrial category. As shown in Table 4-3 of 

EPA’s 2011 DWT Report (U.S. EPA, 2011), EPA reviewed general and individual NPDES 

permits for total residual chlorine permit limitations from 21 states. During the 2011 review of 

the DWT industrial category, EPA determined that the majority of the permits reviewed 

contained monthly average total residual chlorine permit limitations ranging from 0.01 mg/L to 

1.0 mg/L. 

For the 2013 Annual Review, EPA identified the minimum, maximum, and median 2011 

DMR total residual chlorine facility average concentrations and compared those values to the 

maximum monthly average permit limitation identified in EPA’s 2011 DWT Report (1.0 mg/L). 

As shown in Table 5-19, the median of the facility average DMR total residual chlorine 

concentrations for 2011 is well below the maximum monthly average permit limitation identified 

in the 2011 DWT Report. Further, 93 percent of the facilities reporting total residual chlorine 

have average concentrations below the maximum monthly average permit limitation identified in 

the 2011 DWT Report. 

Table 5-19. 2011 DMR Total Residual Chlorine Concentrations (mg/L) 

Maximum 

Monthly 

Average Permit 

Limitation 

(mg/L) 

Minimum 

Reported 2011 

Average 

Concentration 

(mg/L) 

Maximum 

Reported 2011 

Average 

Concentration 

(mg/L) 

Median 

Reported 2011 

Average 

Concentration 

(mg/L) 

Total Number of 

Facilities 

Discharging 

Total Residual 

Chlorine 

Count (Percent) of 

Facilities over 

Maximum 

Monthly Average 

Permit Limitation 

1.0 0.00001 102,000 0.06 644 42 (7%) 

Sources: 2011 DWT Report (U.S. EPA, 2011) and DMRLTOutput2011_v1. 

5.3.4 DWT Industrial Category Aluminum Discharges in DMR 

EPA identified 250 drinking water treatment facilities with 2011 DMR aluminum 

discharges. EPA’s investigation of the aluminum discharges revealed that two facilities, Sanford 

Springs WTP and Dekalb Jackson WTP, account for 51 percent of the 2011 DMR aluminum 

discharges (shown in Table 5-20). EPA did not investigate the remaining facilities’ aluminum 

discharges as part of the 2013 Annual Review. 

Table 5-20. Top 2011 DMR Aluminum Discharging Facilities 

Facility Name Facility Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent 

of Category 

TWPE 

Sanford Springs WTP Piedmont, AL 1,930,000 116,000 34% 

Dekalb Jackson WTP Flat Rock, AL 984,000 59,100 17% 

Remaining Facilities Reporting Aluminum Dischargesa 2,840,000 171,000 49% 

Total 5,760,000 346,000 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 248 remaining facilities that have aluminum discharges in the 2011 DMR data.
 

5-19
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.3—Drinking Water Treatment (Potential New Category) 

Sanford Springs WTP 

Sanford Springs WTP (Sanford Springs) in Piedmont, AL, discharges aluminum from 

outfall 001. EPA contacted the facility to confirm its aluminum discharges. The facility contact 

stated that the 2011 flow values, presented in Table 5-21, should be in units of gallons per 

minute, not million gallons per day. The facility contact explained that outfall 001 is a 

backwash/flush outfall for the facility and only discharges for ten minutes per day; therefore, the 

flow rate is low (Ransom, 2013). This correction decreased the facility’s aluminum TWPE from 

116,000 to 1.16. 

Table 5-21. Sanford Springs 2011 DMR Original and Corrected Flows for Outfall 001 

Monitoring Period Date Original Average Flow (MGD) Corrected Average Flow (MGD) 

31-Jan-2011 1,076 0.011 

28-Feb-2011 865 0.009 

31-Mar-2011 870 0.009 

30-Apr-2011 1,029 0.010 

31-May-2011 1,231 0.012 

30-Jun-2011 1,540 0.015 

31-Jul-2011 1,443 0.014 

31-Aug-2011 1,441 0.014 

30-Sep-2011 1,220 0.012 

31-Oct-2011 1,163 0.012 

30-Nov-2011 991 0.010 

31-Dec-2011 901 0.009 

Source: DMRLTOutput2011_v1. 

Dekalb Jackson WTP 

Dekalb Jackson WTP (Dekalb) in Flat Rock, AL, discharges aluminum from outfall 001. 

As part of the 2013 Annual Review, EPA contacted the facility to confirm its aluminum 

discharges. The facility contact stated that the 2011 flow values, presented in Table 5-22, were 

incorrect and should be divided by 1,000 (Rose, 2013). This correction decreased the facility’s 

aluminum TWPE from 59,100 to 59.1. 

Table 5-22. Dekalb 2011 DMR Original and Corrected Flows for Outfall 001 

Monitoring Period Date Original Average Flow (MGD) Corrected Average Flow (MGD) 

31-Jan-2011 159 0.159 

28-Feb-2011 155 0.155 

31-Mar-2011 146 0.146 

30-Apr-2011 142 0.142 

31-May-2011 151 0.151 

30-Jun-2011 181 0.181 

31-Jul-2011 168 0.168 

31-Aug-2011 158 0.158 

5-20
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.3—Drinking Water Treatment (Potential New Category) 

Table 5-22. Dekalb 2011 DMR Original and Corrected Flows for Outfall 001 

Monitoring Period Date Original Average Flow (MGD) Corrected Average Flow (MGD) 

30-Sep-2011 142 0.142 

31-Oct-2011 145 0.145 

30-Nov-2011 147 0.147 

31-Dec-2011 156 0.156 

Source: DMRLTOutput2011_v1. 

Further Review of 2011 DMR Aluminum Discharges 

Similar to total residual chlorine, EPA reviewed the information on aluminum discharges 

collected as part of the 2011 review of the DWT industrial category. As shown in Table 4-3 of 

EPA’s 2011 DWT Report (U.S. EPA, 2011), EPA reviewed general and individual NPDES 

permits for aluminum limitations from 21 states. During the DWT industrial category review, 

EPA determined that the majority of permits reviewed contained monthly average aluminum 

permit limitations ranging from 0.75 mg/L to 4 mg/L. 

For the 2013 Annual Review, EPA identified the minimum, maximum, and median 2011 

DMR aluminum facility average concentrations and compared those values to the maximum 

monthly average permit limitation identified in EPA’s 2011 DWT Report (4 mg/L). As shown in 

Table 5-23, the median of the facility average DMR aluminum concentrations for 2011 is well 

below the maximum monthly average permit limitation. Further, 95 percent of the facilities 

reporting aluminum have average concentrations below the maximum monthly average permit 

limitation identified in the 2011 DWT Report. 

Table 5-23. 2011 DMR Aluminum Concentrations (mg/L) 

Maximum 

Monthly 

Average Permit 

Limitation 

(mg/L) 

Minimum 

Reported 2011 

Average 

Concentration 

(mg/L) 

Maximum 

Reported 2011 

Average 

Concentration 

(mg/L) 

Median 

Reported 2011 

Average 

Concentration 

(mg/L) 

Total Number of 

Facilities 

Discharging 

Aluminum 

Count (Percent) of 

Facilities over 

Maximum 

Monthly Average 

Permit Limitation 

4 0.0016 1,680 0.25 250 12 (4.8%) 

Sources: 2011 DWT Report (U.S. EPA, 2011) and DMRLTOutput2011_v1. 

During the 2011 review of the category, EPA determined that discharges from some 

drinking water treatment plants include certain pollutants because they are present in the source 

water (concentrated when removed from drinking water) and/or are the result of chemical 

treatment (including the presence of chemical impurities and disinfection by-products). As 

shown in Table 8-2 in the 2011 DWT Report, aluminum is listed as a source water contaminant 

removed from drinking water and is present in treatment chemicals (U.S. EPA, 2011). 

5.3.5 DWT Industrial Category Copper, Mercury, and Lead Discharges in DMR 

For 2011 DMR copper, mercury, and lead discharges, EPA focused its review on 

comparing the reported 2011 DMR discharge data to the permit limitations summarized in 

5-21
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.3—Drinking Water Treatment (Potential New Category) 

EPA’s 2011 DWT Report to determine if the discharge concentrations, on average, are higher 

than the permit limitations. 

As with its review of total residual chlorine and aluminum, for the 2013 Annual Review 

EPA identified the minimum, maximum, and median 2011 DMR copper and lead facility 

average concentrations and compared those values to the maximum monthly average permit 

limitations listed in the 2011 DWT Report. As shown in Table 4-3 of EPA’s 2011 DWT Report 

(U.S. EPA, 2011), EPA’s review of general and individual NPDES permits identified seven 

states that include permit limitations for copper ranging from 0.0031 mg/L to 0.007 mg/L. 

Additionally, EPA identified four states that include permit limitations for lead ranging from 

0.003 mg/L to 0.0081 mg/L. 

As shown in Table 5-24, the median of the facility average DMR copper concentrations 

for 2011 is greater than the maximum monthly average permit limitation identified in the 2011 

DWT Report (0.007 mg/L). Additionally, EPA determined that only 26 percent of the facilities 

reporting copper have average concentrations below the maximum monthly average permit 

limitation. 

Table 5-24 also shows that the median of the facility average DMR lead concentrations 

for 2011 is less than the maximum monthly average permit limitation identified in the 2011 

DWT Report (0.0081 mg/L). For 2011 DMR lead discharges, EPA determined that 87 percent of 

facilities reported lead concentrations lower than the maximum monthly average permit 

limitation. 

Table 5-24. 2011 DMR Copper and Lead Concentrations (mg/L) 

Pollutant 

Maximum 

Monthly 

Average 

Permit 

Limitation 

(mg/L) 

Minimum 

Reported 2011 

Average 

Concentration 

(mg/L) 

Maximum 

Reported 2011 

Average 

Concentration 

(mg/L) 

Median 

Reported 2011 

Average 

Concentration 

(mg/L) 

Total Number 

of Facilities 

Discharging 

Pollutant 

Count (Percent) 

of Facilities over 

Maximum 

Monthly 

Average Permit 

Limitation 

Copper 0.007 0.000017 4.8 0.012 137 102 (74.5%) 

Lead 0.0081 0.00004 0.26 0.0015 98 13 (13.3%) 

Sources: 2011 DWT Report (U.S. EPA, 2011), and DMRLTOutput2011_v1. 

Mercury is not listed as a common regulated pollutant in Section 4.2 of the 2011 DWT 

Report. Therefore, for this analysis, EPA compared the DMR average mercury concentrations 

for 2011 presented in Table 5-25 to available wastewater treatment data for mercury. As an 

initial point of comparison, EPA compared the 2011 DMR average mercury concentrations to 

concentrations achieved by granular media filtration (GMF). This treatment technology was 

tested at a petroleum refinery to meet NPDES permit limitations. The study found that GMF 

could achieve effluent limitations ranging from 0.003 μg/L to 0.0167 μg/L (Pulliam et al., 2010). 

As shown in Table 5-25, 71 percent of the facilities reported mercury concentrations within that 

comparable treatability range. 

5-22
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.3—Drinking Water Treatment (Potential New Category) 

Table 5-25. 2011 DMR Mercury Concentrations (mg/L) 

Pollutant 

Maximum 

GMF 

Treatability 

Concentration 

(mg/L) 

Minimum 

Reported 

2011 Average 

Concentration 

(mg/L) 

Maximum 

Reported 

2011 Average 

Concentration 

(mg/L) 

Median 

Reported 2011 

Average 

Concentration 

(mg/L) 

Total Number 

of Facilities 

Discharging 

Mercury 

Count (Percent) 

of Facilities over 

Maximum GMF 

Treatability 

Concentration 

(Percent) 

Mercury 0.0000167 0.0000019 0.09 0.0000077 52 15 (28.8%) 

Sources: Pulliam et al., 2010 and DMRLTOutput2011_v1. 

During EPA’s 2013 Annual Review of the DWT industrial category, EPA identified at 

least 137 facilities reporting discharges of copper, mercury, and lead; however, only three 

facilities contribute a majority of the TWPE for these pollutants. Though EPA did not evaluate 

any of the facility discharges of these pollutants in detail, similar to the findings for total residual 

chlorine and aluminum, EPA expects that some of the TWPE may be a result of data entry errors 

coupled with the large number of facilities reporting discharges. 

During the 2013 Annual Review, EPA also reviewed the 2011 DWT Report to determine 

if copper, mercury, and lead are present in the source water or treatment chemicals at drinking 

water treatment plants. As shown in Table 8-2 in the 2011 DWT Report, all three pollutants are 

listed as source water contaminants removed from drinking water, and are present in treatment 

chemicals (U.S. EPA, 2011). 

5.3.6	 DWT Industrial Category Findings 

The estimated toxicity of the DWT industrial category discharges resulted from total 

residual chlorine and metals. From the 2013 Annual Review, EPA has identified the following: 

	 The DWT industrial category DMR TWPE doubled from 2009 to 2011; however, 

the top pollutants (total residual chlorine and metals) stayed the same. 

Additionally, the number of facilities reporting each of the top pollutants 

increased from 2009 to 2011. 

	 EPA reviewed the top four dischargers of total residual chlorine and aluminum 

(which contributed more than 50 percent of the TWPE for each of these 

pollutants) and determined the following: 

1.	 One facility, PRASA Vieja Ponce, had errors in their 2011 DMR flow and 

total residual chlorine concentration values. EPA also determined that 

PRASA Vieja Ponce is exceeding its permit limitations for total residual 

chlorine. Therefore, facility-specific permitting action may be appropriate 

to address total residual chlorine discharges from PRASA Vieja Ponce. 

2.	 Additionally, EPA determined that the remaining three facilities each had 

errors in their reported flows for the 2011 DMR data. EPA made 

corrections to the flow and concentration data, which resulted in a 

decrease of the DWT industrial category TWPE from 1,390,000 to 

976,000 TWPE. 

5-23
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.3—Drinking Water Treatment (Potential New Category) 

	 Additionally, EPA compared 2011 DMR average facility concentrations of total 

residual chlorine, aluminum, copper, and lead to monthly average permit 

limitations summarized in Section 4.2 of the 2011 DWT Report. Because mercury 

is not listed as a common regulated pollutant in Section 4.2 of the 2011 DWT 

Report, as an initial point of comparison, EPA compared the 2011 DMR 

concentrations to concentrations achieved by GMF (though not applied to 

drinking water treatment wastewater). EPA determined that the majority of 

concentrations reported for total residual chlorine, aluminum, mercury, and lead 

were below the maximum monthly average permit limitations or within the GMF 

mercury treatability range. However, EPA determined that the majority of copper 

concentrations exceeded the maximum monthly average permit limitation 

identified in the 2011 DWT Report. 

	 During the 2011 review of the category, EPA determined that discharges from 

some drinking water treatment plants include certain pollutants because they are 

present in the source water and from treatment chemicals. Source water and 

treatment chemical pollutants include aluminum, copper, mercury, and lead (see 

Table 8-2 in the 2011 DWT Report (U.S. EPA, 2011). Because of the different 

source water contributions and treatment chemicals at each plant (among other 

reasons), EPA determined that NPDES permits (general and individual) best 

control discharges from these facilities during the 2011 review of the category. 

	 Therefore, EPA does not consider the remaining top metals (aluminum, copper, 

lead, and mercury) as hazard priorities because the majority of the average facility 

concentrations are below the monthly average pollutant concentrations presented 

in the 2011 DWT Report. In addition, all of the pollutants were identified as 

potential source water contributions or treatment chemicals. EPA does not 

consider total residual chlorine discharges a hazard priority at this time because 

over 90 percent of the 2011 DMR average facility concentrations are below the 

maximum monthly average permit limitation. 

5.3.7	 References for DWT Industrial Category 

1.	 ERG. 2014. Preliminary Category Review – Facility Data Review and Revised 

Calculations for PSC 501 – Drinking Water Treatment. (March). EPA-HQ-OW-2014­

0170. DCN 07978. 

2.	 Pulliam, Greg et al. (2010). A Coordinated Approach to Achieving NPDES Permit 

Compliance for Mercury and Selenium in a Refinery Effluent. Paper presented at 

WEFTEC 2010, Water Environment Federation. New Orleans, LA. EPA-HQ-OW-2014­

0170. DCN 07973. 

3.	 Ransom, Tim. 2013. Telephone communication with Tim Ransom, Sanford Spring Water 

Treatment Plant, and Kimberly Bartell, Eastern Research Group, Inc. Re: 2011 DMR 

Discharges for Sanford Springs Water Treatment Plant. (December 13). EPA-HQ-OW2014-0170. DCN 07974. 

5-24
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.3—Drinking Water Treatment (Potential New Category) 

4.	 Rose, Chris. 2013. Telephone and email communication with Chris Rose, Dekalb 

Jackson Water Treatment Plant, and Kimberly Bartell, Eastern Research Group, Inc. Re: 

2011 DMR Discharges for Dekalb Jackson Water Treatment Plant. (December 13). EPAHQ-OW-2014-0170. DCN 07975. 

5.	 U.S. EPA. 2011. Drinking Water Treatment Plant Residuals Management Technical 

Report: Summary of Residuals Generation, Treatment, and Disposal at Large Community 

Wastewater Systems (EPA 820-R-11-003). Washington, D.C. (December). EPA-HQOW-2014-0170. DCN 07976. 

5-25
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415) 

5.4 Inorganic Chemicals Manufacturing (40 CFR Part 415) 

EPA selected the Inorganic Chemicals Manufacturing (Inorganic Chemicals) Category 

for preliminary review because it continues to rank high, in terms of toxic-weighted pound 

equivalents (TWPE), in the point source category rankings. EPA also reviewed discharges from 

the Inorganic Chemicals Category in each of its Annual Reviews from 2004 through 2011, 

(except for 2008) (U.S. EPA, 2004a, 2005, 2006, 2007, 2009, 2011, 2012). This section 

summarizes the results of the 2013 Annual Review pertaining to the Inorganic Chemicals 

Category. EPA focused on discharges of dioxin and dioxin-like compounds, manganese and 

manganese compounds, and polychlorinated biphenyls (PCBs) from the toxic release inventory 

(TRI) because of their high TWPE relative to the rest of the pollutants discharged by the 

Inorganic Chemicals Category. Dioxin and dioxin-like compounds and manganese and 

manganese compounds, reviewed as part of the 2011 Annual Review, continue to be top 

pollutants of concern. Discharge data available for the 2013 Annual Review also showed that 

PCBs contribute significantly to the Inorganic Chemicals Category TWPE. 

5.4.1 Inorganic Chemicals Category 2013 Toxicity Rankings Analysis 

Table 5-26 compares the toxicity rankings analysis (TRA) results for the Inorganic 

Chemicals Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in 

2012, but instead reviewed additional data sources as part of the even-year annual review, as 

discussed in the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 

2014). During the 2013 Annual Review, EPA did not identify any data corrections for the 

Inorganic Chemicals Category. 

Table 5-26. Inorganic Chemicals Category TRI and DMR Facility Counts and 

Discharges for the 2011 and 2013 Annual Reviews 

Year of 

Discharge 

Year of 

Review 

Inorganic Chemicals Category Facility 

Counts Inorganic Chemicals Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilitiesa TRI TWPEb 

DMR 

TWPEc Total TWPE 

2009d 2011 153 45 84 60,900 51,300 112,000 

2011 2013 153 62 96 327,000 142,000 469,000 

Sources: 2011 Annual Review Report (for 2009d DMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_v1
 

(for 2011 DMR); TRILTOutput2011_v1 (for 2011 TRI).
 

Note: EPA did not evaluate DMR data for 2010.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
 b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
 

POTW removals.
 c DMR discharges from both minor and major facilities.
 d 2009 data after corrections made during the 2011 Annual Review.
 

As shown in Table 5-26, the TWPE for both TRI and DMR increased from 2009 to 2011. 

During that period, the number of TRI facilities has remained constant; however, the number of 

facilities in DMR has increased by 23 percent. 

5-26
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415) 

5.4.2	 Inorganic Chemicals Category Pollutants of Concern 

For its 2013 Annual Review, EPA’s review of the Inorganic Chemicals Category focused 

on 2011 TRI discharges because the 2011 TRI data dominate the category’s combined TWPE. 

Table 5-14 compares the five pollutants with the highest contribution to the 2011 TRI TWPE. In 

addition, as a point of comparison, Table 5-14 shows the 2009 TRI TWPE for these top five 

pollutants, based on the results of (and corrections identified in) the 2011 Annual Review (U.S. 

EPA, 2012). During the 2013 Annual Review, EPA did not identify any data corrections for the 

Inorganic Chemicals Category. 

Dioxin and dioxin-like compounds, manganese and manganese compounds, and PCBs 

account for approximately 92 percent of the total 2011 TRI TWPE in this industrial category. 

Dioxin and dioxin-like compounds and manganese and manganese compounds have consistently 

accounted for the majority of the Inorganic Chemicals Category TWPE in EPA’s previous 

Annual Reviews: 

	 Dioxin and dioxin-like compounds are the top TRI-reported pollutant in 2011 and 

ranked second in 2009 for the Inorganic Chemicals Category (U.S. EPA, 2012). 

Dioxin and dioxin-like compounds were also the top TRI-reported pollutant in 

2002 (U.S. EPA, 2006). 

	 Manganese and manganese compounds ranked second among TRI-reported 

pollutants in 2011 and ranked first in 2004, 2008, and 2009 for the Inorganic 

Chemicals Category (U.S. EPA, 2011). 

EPA’s investigations of reported discharges of the top three pollutants are presented in 

Sections 5.3.3 to 5.4.5. EPA investigated neither nitrate compounds, nor mercury and mercury 

compounds in the 2013 Annual Review because they represent only approximately 8 percent of 

the 2011 TRI TWPE for this category. 

Table 5-27. Inorganic Chemicals Category Top TRI Pollutants 

Pollutant 

2011 TRI Data 2009 TRI Data 

Number of Facilities 

Reporting Pollutant TWPE TWPE 

Dioxin and Dioxin-Like Compounds 6 279,000 2,170 

Manganese and Manganese Compounds 21 14,100 35,800 

Polychlorinated Biphenyls (PCBs) 2 7,010 0a 

Nitrate Compounds 49 5,070b 3,910 

Mercury and Mercury Compounds 13 4,250b 3,510 

Top Pollutant Total NA 310,000 45,400 

Inorganic Chemicals Category Total 153c 327,000 60,900 

Sources: TRILTOutput2011_v1 (for 2011 TRI TWPE); 2011 Annual Review Report (for 2009 TRI TWPE) (U.S.
 

EPA, 2012).
 

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

NA: Not applicable.
 a No facilities reported discharges of PCBs to TRI in 2009. Therefore, EPA did not review these discharges.
 b Nitrate compounds and mercury and mercury compounds combined contribute 3 percent of the 2011 category TRI.
 

Therefore, EPA did not review nitrate compound or mercury and mercury compound discharges as part of the 2013
 

Annual Review.
 c Number of facilities reporting TWPE greater than zero.
 

5-27
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415) 

5.4.3 Inorganic Chemicals Category Dioxin and Dioxin-Like Compound Discharges in TRI 

EPA’s investigation of the dioxin and dioxin-like compound discharges revealed that 

Millennium Inorganic Chemicals, Inc., Plant I (Millennium Plant I), in Ashtabula, OH15 accounts 

for 98 percent of the 2011 TRI dioxin and dioxin-like compound discharges (shown in Table 

5-16). EPA did not investigate other facilities in this category discharging dioxin and dioxin-like 

compounds. 

Table 5-28. Top 2011 TRI Dioxin and Dioxin Like Compound Discharging Facilities 

Facility Name 

Facility 

Location 

Pounds of 

Pollutant 

Discharged b 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Millennium Inorganic Chemicals, Inc. Plant I Ashtabula, OH 0.00245 273,000 98% 

Remaining Facilities Reporting Dioxin and Dioxin-Like 

Compound Dischargesa 0.00581 6,110 2% 

Total 0.00826 279,000 100% 

Source: TRILTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 5 remaining facilities that have dioxin and dioxin-like compound discharges in the 2011 TRI data.
 b Dioxin TWPE values are calculated using a dioxin distribution submitted by the facility. Each dioxin congener
 

making up the dioxin distribution has a different TWF. As a result, though facilities may discharge a greater amount
 

of pounds of dioxin, the associated total pollutant TWPE may be less.
 

Millennium Plant I produces titanium dioxide using a chloride process (U.S. EPA, 2001). 

During this process, the facility converts rutile or high-grade ilmenite ore into titanium 

tetrachloride (TiCl4) in a fluidized bed chlorinator. The resulting TiCl4 is piped to an oxidizer as 

a vapor. In the oxidizer, purified TiCl4 vapor is converted to TiO2, or titanium dioxide (U.S. 

EPA, 2006). For further information on titanium dioxide manufacturing, see Section 9.6 in the 

Technical Support Document for the 2006 Effluent Guidelines Program Plan (U.S. EPA, 2006). 

EPA contacted the facility about their dioxin and dioxin-like compound discharges. The 

facility contact stated that the formation of dioxin compounds occurs within an extremely narrow 

temperature range immediately following the chlorination process (Schmude, 2014). The facility 

measures the dioxin compounds based on quarterly sampling at the final effluent. The facility 

contact stated that in 2011, the non-detect data were inadvertently reported using the minimum 

detection limit. For other reporting years, the facility has reported non-detect data as zero 

(Schmude, 2014). The facility provided the 2011 flow rate and the 2012 grams of dioxin 

discharged. Table 5-29 presents Millennium Plant I’s dioxin and dioxin-like compound 

discharges for discharge years 2007-2012. As shown, the discharge quantity for 2011 is 

significantly greater than other reporting years. 

15 The TRI ID for Millennium Inorganic Chemicals, Inc. Plant I in Ashtabula, OH, is 44004SCMCH2900M. This 

facility is not to be confused with the Millennium Inorganic Chemicals, Inc. Plant II, also in Ashtabula, OH, which 

is discussed in Section 5.3.5. 

5-28
 
- -

- -

Section 5—EPA’s 2013 Preliminary Category Reviews 

5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415) 

Table 5-29. Millennium Plant I’s Yearly Dioxin and Dioxin-like Compound TRI Discharges 

Year of Discharge 

Total Dioxin and Dioxin-like 

Compounds Grams Discharged 

Total Dioxin and Dioxin-like 

Compounds TWPE 

2007 0 0 

2008 0 0 

2009 0.03 0.76 

2010 0.16 2,396 

2011 1.09 273,040 

2012 0.14 NA 

Source: TRILTOutput2011_v1; Schmude, 2014.
 

NA: Not Applicable. The Facility contact provided the total grams of dioxin discharged for 2012 but did not provide
 

the dioxin congener distribution. Therefore, the dioxin TWPE for 2012 was not calculated.
 

Since Millennium Plant I reported its 2011 dioxin and dioxin-like compound discharges 

in error and did not provide a corrected 2011 quantity, EPA used the 2011 flow provided by the 

facility contact and the facility’s TRI reported 2011 congener distribution to calculate its dioxin 

and dioxin-like compound discharge concentrations. Table 5-30 presents Millennium Plant I’s 

calculated dioxin and dioxin-like compound discharges for 2011 and the EPA Method 1613B 

minimum levels (MLs) (U.S. EPA, 2004b). As shown, all 2011 dioxin and dioxin-like compound 

discharges are below EPA’s Method 1613B MLs. EPA has limited confidence in dioxin 

concentrations measured below the Method 1613B ML. Further, Millennium Plant I is one of the 

few remaining U.S. facilities that manufactures titanium dioxide. Its dioxin and dioxin-like 

compound discharges do not represent discharges across the category as a whole. 

Table 5-30. 2011 Concentrations of Dioxin and Dioxin-Like Compounds in Effluent 

Samples (pg/L) from Millennium Plant I and EPA Method 1613B Minimum Levels 

Congener TWF 1613B ML (pg/L) 

Calculated 2011 

Concentration (pg/L)a 

Flow (MGY)b 868 

Polychlorinated dibenzo p furans (CDFs) 

2,3,7,8-TCDF 43,819,553.68 10 4.8 

1,2,3,7,8-PeCDF 7,632,640 50 23.8 

2,3,4,7,8-PeCDF 557,312,000 50 24.0 

1,2,3,4,7,8-HxCDF 5,760,000 50 24.2 

1,2,3,6,7,8-HxCDF 14,109,440 50 24.4 

2,3,4,6,7,8-HxCDF 51,204,160 50 24.3 

1,2,3,7,8,9-HxCDF 47,308,800 50 24.0 

1,2,3,4,6,7,8-HpCDF 85,760 50 26.1 

1,2,3,4,7,8,9-HpCDF 3,033,984 50 24.3 

1,2,3,4,6,7,8,9-OCDF 2,020.96 100 6.8 

Polychlorinated dibenzo p dioxins (CDDs) 

2,3,7,8-TCDD 703,584,000 10 4.9 

1,2,3,7,8-PeCDD 692,928,000 50 23.8 

1,2,3,4,7,8-HxCDD 23,498,240 50 24.0 

5-29
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415) 

Table 5-30. 2011 Concentrations of Dioxin and Dioxin-Like Compounds in Effluent
 

Samples (pg/L) from Millennium Plant I and EPA Method 1613B Minimum Levels
 

Congener TWF 1613B ML (pg/L) 

Calculated 2011 

Concentration (pg/L)a 

1,2,3,6,7,8-HxCDD 9,556,480 50 24.1 

1,2,3,7,8,9-HxCDD 10,595,840 50 24.4 

1,2,3,4,6,7,8-HpCDD 411,136 50 24.5 

1,2,3,4,6,7,8,9-OCDD 6,585.6 100 6.5 

Source: TRILTOutput2011_v1, U.S. EPA, 2004b.
 

ML: Minimum level established for EPA Method 1613B (U.S. EPA, 2004b).
 a Concentrations calculated using the facility’s reported congener distribution and flow in 2011.
 b 2011 facility flow from facility contact (Schmude, 2014).
 

5.4.4	 Inorganic Chemicals Category Manganese and Manganese Compound Discharges in 

TRI 

EPA’s investigation of the manganese and manganese compound discharges revealed that 

Millennium Inorganic Chemicals, Inc. Plant II (Millennium Plant II), in Ashtabula, OH16 

accounts for 39 percent of the 2011 TRI manganese and manganese compound discharges 

(shown in Table 5-31). EPA did not investigate the remaining facilities discharging manganese 

and manganese compounds. 

Table 5-31. Top 2011 Manganese and Manganese Compound Discharging Facilities 

Facility Name 

Facility 

Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent 

of Category 

TWPE 

Millennium Inorganic Chemicals, Inc. Plant II Ashtabula, OH 79,000 5,530 39% 

Remaining Facilities Reporting Manganese and Manganese 

Compound Dischargesa 122,000 8,540 61% 

Total 201,000 14,100 100% 

Source: TRILTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 20 remaining facilities that have manganese and manganese compound discharges in the 2011 TRI data.
 

Similar to Millennium Plant I, discussed in Section 5.3.3, Millennium Plant II produces 

titanium dioxide using the chloride process (U.S. EPA, 2001). For further information on 

titanium dioxide manufacturing, see Section 9.6 in the Technical Support Document for the 2006 

Effluent Guidelines Program Plan (U.S. EPA, 2006). 

Table 5-32 presents Millennium Plant II’s manganese and manganese compound 

discharges for discharge years 2007-2012. As shown, the discharge quantity for 2011 is higher 

than other reporting years. EPA contacted the facility about their 2011 manganese and 

manganese compound discharges. The facility contact confirmed the 2011 discharge quantity 

16 The TRI ID for the Millennium Inorganic Chemicals, Inc. Plant II in Ashtabula, OH is 44004SCMCH2426M. 

This facility is not to be confused with the Millennium Inorganic Chemicals, Inc. Plant I also located in Ashtabula, 

OH, discussed in Section 5.4.3. 

5-30
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415) 

and stated that the reported TRI discharge is based on direct sampling of the final effluent. The 

facility contact also stated that the increase in the manganese and manganese compound 

discharge in 2011 was due to a slight increase in flow. The increase in flow was said to result 

from many factors, including process rate, process conditions, and volume of stormwater. The 

facility contact also provided 2012 discharge quantity for comparison, and the discharges have 

subsequently decreased in 2012 (Schmude, 2014). 

Millennium Plant II is one of the few remaining U.S. facilities that manufacture titanium 

dioxide. Its manganese and manganese compound discharges are not representative of facility 

discharges across the category as a whole. 

Table 5-32. Millennium Plant II’s Yearly Manganese and Manganese Compound
 

TRI Discharges
 

Year of Discharge 

Total Manganese and Manganese 

Compounds Pounds per Year Discharged 

Total Manganese and Manganese 

Compounds TWPE 

2007 36,000 2,520 

2008 55,000 3,850 

2009 23,000 1,610 

2010 38,000 2,660 

2011 79,000 5,530 

2012 53,500 3,740 

Source: TRILTOutput2011_v1; Schmude, 2014. 

5.4.5	 Inorganic Chemicals Category Polychlorinated Biphenyl (PCB) Compound Discharges 

in TRI 

EPA’s investigation of the PCB compound discharges revealed that DuPont Johnsonville 

Plant (DuPont Johnsonville), in New Johnsonville, TN, accounts for 97 percent of the 2011 TRI 

PCB compound discharges (shown in Table 5-33). EPA did not investigate DuPont Edgemoor in 

Edgemoor, DE, which accounts for the remaining 2 percent of the discharges. 

Table 5-33. Top 2011 PCB Discharging Facilities 

Facility Name Facility Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

DuPont Johnsonville Plant New Johnsonville, TN 0.2 6,810 97% 

DuPont Edgemoor Edgemoor, DE 0.00607 207 3% 

Total 0.206 7,010 100% 

Source: TRILTOutput2011_v1.
 

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

DuPont Johnsonville produces titanium dioxide using the chloride-ilmenite process (U.S. 

EPA, 2001). The chloride-ilmenite process is similar to the chloride process discussed in Section 

5.3.3. The primary difference between the two processes is that the chloride-ilmenite process 

allows the use of lower-quality ore and easier oxidation than the chloride process (U.S. EPA, 

5-31
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415) 

2006). For further information on titanium dioxide manufacturing, see Section 9.6 in the 

Technical Support Document for the 2006 Effluent Guidelines Program Plan (U.S. EPA, 2006). 

EPA contacted DuPont Johnsonville about their PCB discharges. The facility contact 

confirmed the discharges and stated that small amounts of fine solids in the wastewater discharge 

(resulting from the chlorination process) are the source of the PCB compounds (Martin, 2013). 

Table 5-34 presents the facility’s PCB discharge quantity for years 2007-2011. As shown in 

Table 5-34, the facility’s PCB discharges have doubled from 2010 to 2011. Therefore, facilityspecific permitting action may be appropriate to address PCB discharges from the DuPont 

Johnsonville facility. 

Table 5-34. DuPont Johnsonville’s Yearly PCB TRI Discharges 

Year of Discharge Total PCB Pounds Discharged Total PCB TWPE 

2007 0.1 3,400 

2008 0.1 3,400 

2009 0 0 

2010 0.1 3,400 

2011 0.2 6,810 

Source: TRILTOutput2011_v1. 

5.4.6	 Inorganic Chemicals Category Findings 

The estimated toxicity of the Inorganic Chemicals Category discharges resulted from TRI 

dioxin and dioxin-like compounds, manganese and manganese compounds, and PCB discharges. 

From the 2013 Annual Review, EPA has identified the following: 

	 One facility, Millennium Inorganic Chemicals, Inc. Plant I, contributes the 

majority of the category’s 2011 TRI dioxin and dioxin-like compound discharges. 

EPA determined that the facility inadvertently reported 2011 dioxin and dioxinlike compound discharges using the minimum detection limit, when historically 

they have reported non-detect data as zero. In evaluating the data as reported, the 

2011 concentrations for all congeners are below EPA’s Method 1613B ML. 

Therefore, further review of the facility’s dioxin and dioxin-like compound 

discharges is not warranted at this time. 

	 One facility, Millennium Inorganic Chemicals, Inc. Plant II, accounts for 39 

percent of the category’s 2011 TRI manganese and manganese compound 

discharges. EPA determined that the 2011 manganese and manganese compound 

TRI discharge for the facility is an anomaly due to an increase in flow at the 

facility during 2011. This determination is supported by a decrease in the 

discharge in 2012. Therefore, further review of the facility’s manganese and 

manganese compound discharges is not warranted at this time. 

	 One facility, DuPont Johnsonville Plant, accounts for the majority of the 

category’s 2011 TRI PCB discharges. EPA determined that the facility’s 2011 

PCB discharges were accurate and increased from previous years. Therefore, 

facility-specific permitting action may be appropriate to address PCB discharges 

from this facility. 

5-32
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415) 

	 For the Inorganic Chemicals Category, EPA determined the data do not support 

the need to review further the Inorganic Category as a whole. 

5.4.7	 References for Inorganic Chemicals Category 

1.	 ERG. 2014. Preliminary Category Review – Facility Data Review and Revised 

Calculations for Point Source Category 415 – Inorganic Chemicals. (March). EPA-HQOW-2014-0170. DCN 07888. 

2.	 Martin, Gregg. 2013. Telephone and Email Communication between Gregg Martin, 

DuPont Johnsonville Plant, and Kimberly Bartell, Eastern Research Group, Inc. Re: 2011 

TRI PCB Discharges. (January 8). EPA-HQ-OW-2014-0170. DCN 07886. 

3.	 Schmude, Robert. 2014. Telephone and Email Communication between Robert Schmude, 

Millennium Inorganic Chemicals, Inc., and Kimberly Bartell, Eastern Research Group, 

Inc. Re: 2011 TRI Dioxin and Manganese Discharges. (January 8). EPA-HQ-OW-2014­

0170. DCN 07885. 

4.	 U.S. EPA. 2001. Final Titanium Dioxide Listing Background Document for the Inorganic 

Chemical Listing Determination. Washington, D.C. (October). EPA-HQ-OW-2004-0032­

2419. DCN 03331. 

5.	 U.S. EPA. 2004a. Technical Support Document for the 2004 Effluent Guidelines 

Program Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003­

0074-1346 through 1352. 

6.	 U.S. EPA. 2004b. Method 1613B: Tetra- Through Octa-Chlorinated Dioxins and Furans 

by Isotope Dilution HRGC/HRMS. Washington, D.C. (October). EPA-HQ-OW-2004­

0032-2653. 

7.	 U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial 

Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004­

0032-0053. 

8.	 U.S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program 

Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032­

2782. 

9.	 U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent 

Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQOW-2006-0771-0819. 

10.	 U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent 

Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQOW-2008-0517-0515. 

11.	 U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program 

Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA-HQ-OW-2008-0517. DCN 

07320. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415) 

12.	 U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

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

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

07756. 

5-34
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

5.5 Iron and Steel Manufacturing (40 CFR Part 420) 

EPA selected the Iron and Steel Manufacturing Category for preliminary review because 

it ranks high, in terms of toxic-weighted pound equivalents (TWPE), in the point source category 

rankings. EPA previously reviewed discharges from the Iron and Steel Manufacturing Category 

as part of the 2011 Annual Review (U.S. EPA, 2012). This section summarizes the results of the 

2013 Annual Review, which focused on discharges of fluoride, aluminum, cyanide, and total 

residual chlorine, due to their high TWPE relative to the other pollutants in the Iron and Steel 

Manufacturing Category. These four pollutants, reviewed as part of the 2011 Annual Review, 

continue to be top pollutants of concern. For further background on the Iron and Steel 

Manufacturing Category, including an industry profile, see The 2011 Annual Effluent Guidelines 

Review Report (U.S. EPA, 2012). 

5.5.1 Iron and Steel Manufacturing Category 2013 Toxicity Rankings Analysis 

Table 5-35 compares the toxicity rankings analysis (TRA) results for the Iron and Steel 

Manufacturing Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the 

TRA in 2012, but instead reviewed additional data sources as part of the even-year annual 

review, as discussed in the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans 

(U.S. EPA, 2014). As discussed below, EPA’s review of the Iron and Steel Manufacturing 

Category identified several data errors that affect the 2011 DMR data and TWPE. The bottom 

row of Table 5-35 shows the corrected data resulting from this review. 

Table 5-35. Iron and Steel Category TRI and DMR Facility Counts and Discharges 

for the 2011 and 2013 Annual Reviews 

Year of 

Discharge 

Year of 

Review 

Iron and Steel Facility Counts Iron and Steel Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilitiesa 

TRI 

TWPEb 

DMR 

TWPEc 

Total 

TWPE 

2009d 2011 227 73 49 96,200 108,000 205,000 

2011 2013 

222 76 45 82,900 1,220,000 1,300,000 

2011e 2013 82,900 214,000 297,000 

Sources: 2011 Annual Review Report (for 2009d DMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_v1
 

(for 2011 DMR); TRILTOutput2011_v1 (for 2011 TRI).
 

Note: EPA did not evaluate DMR data for 2010.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
 b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
 

POTW removals.
 c DMR discharges from both minor and major facilities.
 d 2009 data after corrections made during the 2011 Annual Review.
 e 2011 data after corrections made during the 2013 Annual Review.
 

The DMR TWPE for the Iron and Steel industrial category increased from discharge year 

2009 to 2011 by approximately 98 percent (after data corrections were made to the 2011 DMR 

data). As shown in Table 5-35, there has not been a significant increase in the total number of 

facilities reporting DMR data. 

5-35
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

5.5.2 Iron and Steel Manufacturing Category Pollutants of Concern 

For its 2013 Annual Review, EPA’s review of the Iron and Steel Manufacturing Category 

focused on the 2011 DMR discharges because the 2011 DMR data account for 94 percent of the 

category’s combined TWPE. Table 5-36 compares the five pollutants with the highest 

contribution to the 2011 DMR TWPE. Table 5-36 also presents the 2011 DMR TWPE after EPA 

corrected errors identified in this preliminary category review (discussed in the sections below). 

In addition, as a point of comparison, Table 5-36 shows the 2009 DMR TWPE for these top five 

pollutants based on the results of (and corrections identified in) the 2011 Annual Review (U.S. 

EPA, 2012). 

During EPA’s review of the Iron and Steel Manufacturing Category, one facility (US 

Steel Mon Valley Works, Edgar Thomson Plant, in Braddock, PA) was identified as responsible 

for the majority of 2011 DMR TWPE in all top pollutant categories. The facility accounted for 

99 percent of iron discharges, 97 percent of zinc discharges, and 98 percent of manganese 

discharges. During EPA’s 2007 Annual Review, EPA identified an error in the 2004 DMR flow 

values. At that time, the facility contact indicated that the facility measures pollutant 

concentrations in their stormwater prior to commingling with noncontact cooling water (U.S. 

EPA, 2007), but the flow reported in the DMR was for the commingled stream. To reflect 

loading estimates accurately in the 2004 DMR data, EPA developed and applied a flow 

correction factor using the 2004 facility data to calculate the volume of stormwater in the total 

outfall flow (Belack, 2007). For the 2007 Annual Review and subsequent annual reviews, EPA 

used the corrected flow rate with the reported concentration to calculate the total mass load 

discharged from the facility. During the 2013 Annual Review, EPA determined that this 

correction should have been carried through for the 2011 DMR data. EPA subsequently made 

this data correction, which decreased the total Iron and Steel Category 2011 DMR TWPE from 

1,220,000 to 290,000, and removed iron, zinc, and manganese as top pollutants discharged from 

this category. 

Also during the course of EPA’s review of the Iron and Steel Manufacturing Category, 

one facility submitted data corrections to their DMRs (Republic Conduit Manufacturing in 

Louisville, KY), which subsequently affected the top pollutants for this category. Prior to this 

data correction, the facility was identified as responsible for more than 98 percent of DMR 

hexavalent chromium discharges. However, the facility underwent an audit in the spring of 2013 

and realized that their flow values had been submitted with the incorrect units on the facility’s 

2011 DMR (Gaylord, 2013). Incorporating this data correction further decreased the total Iron 

and Steel Category 2011 DMR TWPE from 290,000 to 246,000 and removed hexavalent 

chromium as a top pollutant. 

After the data corrections discussed above were incorporated into the 2011 DMR data for 

the Iron and Steel Manufacturing Category, the top five pollutants with the highest contribution 

to the 2011 DMR TWPE, presented in Table 5-36, were fluoride, aluminum, cyanide, total 

residual chlorine, and silver. These contribute more than 69 percent of the total 2011 DMR 

TWPE for this category. EPA’s investigations of reported discharges of the top four pollutants 

are presented in Sections 5.5.3 to 5.5.6. EPA did not investigate the other top pollutants as part of 

the 2013 Annual Review, including silver, because they account for 31 percent of the 2011 DMR 

TWPE for the Iron and Steel Manufacturing Category. As shown in Table 5-36, EPA’s 

5-36
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

investigations of the top four pollutants identified additional data corrections, which further 

affected the category’s TWPE. 

Table 5-36. Iron and Steel Manufacturing Category Top DMR Pollutants 

Pollutant 

2011 DMR Dataa 2009 DMR Dataa 

Number of Facilities 

Reporting Pollutant Original TWPE 

Corrected 

TWPE TWPE 

Fluoride 17 47,800 34,200 11,500 

Aluminum 18 37,500 18,400 9,660 

Cyanide 26 34,100 34,100 27,400 

Total Residual Chlorine 29 28,600 28,600 9,810 

Silver 4 15,900 15,900b 1,400 

Top Pollutants, Total NA 164,000 131,000 59,800 

Iron and Steel Manufacturing 

Category, Total 146c 246,000d 214,000 108,000 

Sources: DMRLTOutput2011_v1 (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE) 

(U.S. EPA, 2012).
 

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

NA: Not applicable.
 a DMR data include major and minor dischargers.
 b Silver discharges contribute 6 percent of the 2011 category TWPE. Therefore, EPA did not review silver
 

discharges as part of the 2013 Annual Review.
 c Number of facilities reporting TWPE greater than zero.
 d The Iron and Steel Category Total 2011 DMR TWPE value includes the corrections to the Edgar Thompson Plant
 

and Republic Conduit Manufacturing data, described above. These corrections decreased the TWPE from 1,220,000,
 

as presented in Table 5-35, to 246,000. EPA identified further corrections to the data, which are reflected in the
 

Corrected TWPE in this table.
 

5.5.3 Iron and Steel Manufacturing Category Fluoride Discharges in DMR 

EPA’s investigation of fluoride discharges in this category revealed that three facilities 

account for approximately 73 percent of the 2011 DMR fluoride discharges from iron and steel 

manufacturers (shown in Table 5-37). EPA did not investigate the remaining facilities 

discharging fluoride as part of the 2013 Annual Review. 

Table 5-37. Top 2011 DMR Fluoride Discharging Facilities 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Arcelormittal Indiana Harbor LLC East Chicago, IN 500,000 15,000 31% 

USS Gary Works Gary, IN 339,000 10,200 21% 

Weirton Steel Corporation Weirton, WV 331,000 9,940 21% 

Remaining Facilities Reporting Fluoride Dischargesa 422,000 12,700 27% 

Total 1,590,000 47,800 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are fourteen remaining facilities that have fluoride discharges in the 2011 DMR data.
 

5-37
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

Fluoride is not a regulated pollutant in the Iron and Steel Manufacturing Category 

effluent limitations guidelines and standards (ELGs). During previous annual reviews, EPA 

researched treatment technologies that were capable of removing fluoride (not specific to iron 

and steel wastewater discharges). From this review, EPA determined that current technologies 

are achieving effluent fluoride concentrations between 2 mg/L and 15 mg/L (WC&E, 2006; 

Ionics, n.d.; GCIP, 2002). EPA used these effluent fluoride concentrations as benchmarks for 

initial comparison of fluoride discharges from iron and steel manufacturing facilities. 

Arcelormittal Indiana Harbor LLC 

Arcelormittal Indiana Harbor LLC (Arcelormittal) in East Chicago, IN, discharges 

fluoride from outfalls 009, 010, and 011. In reviewing the facility’s 2011 DMR fluoride 

concentrations, EPA noted that the May 2011 fluoride concentration from Outfall 010 was 100 

times higher than the other concentrations from that outfall, and from the other outfalls. As 

shown in Table 5-17, EPA assumed that the reported concentration was in error and corrected the 

concentration from this outfall. This correction decreased the facility’s fluoride TWPE from 

15,000 to 1,440, reducing the Iron and Steel Category’s fluoride TWPE from 47,800 to 34,200, 

as shown in Table 5-36. Further, all of the 2011 DMR fluoride concentrations for Arcelormittal 

are below the comparable treatability levels achievable by current technologies. 

Table 5-38. Arcelormittal’s 2011 DMR Original and Corrected Fluoride Discharges 

Outfall 

Monitoring 

Period Date 

Original Average Flow 

(MGD) 

Original Average Fluoride 

Concentration (mg/L) 

Corrected 

Concentration (mg/L) 

009 31-Mar-2011 34.1 0.4 0.4 

009 31-May-2011 34.1 0.36 0.36 

009 30-Sep-2011 34.1 0.28 0.28 

010 31-Mar-2011 45.1 0.46 0.46 

010 31-May-2011 44.9 36 0.36 

010 30-Sep-2011 44.9 0.29 0.29 

011 31-Mar-2011 18.6 1.6 1.6 

011 31-May-2011 32.8 0.82 0.82 

011 30-Sep-2011 35.7 0.84 0.84 

Source: DMRLTOutput2011_v1. 

USS Gary Works 

USS Gary Works in Gary, IN, discharges fluoride from outfalls 005, 028 and 030 to the 

Grand Calumet River (IDNR, 2007). Outfall 005 discharges cooling water and condensate from 

many operations, along with stormwater runoff (IDNR, 2007). Outfalls 028 and 030 are 

discharges from lagoons containing continuous caster non-contact cooling water, cooling tower 

blowdown, stormwater runoff, steam condensate, plate mill scale pit, slab spray cooling water, 

and vacuum degasser overflow. The facility’s permit calls for monitoring of fluoride discharges 

from outfalls 005, 028, and 030, but does not include fluoride limits (IDNR, 2007). 

Table 5-39 presents the facility’s fluoride discharge data for 2011. EPA calculated the 

fluoride concentrations using the quantity and average monthly flows. The fluoride 

concentrations range from 0.417 mg/L to 3.77 mg/L. For its initial comparison of the discharges, 

5-38
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

EPA determined that fluoride concentrations for USS Gary Works are generally below those 

achievable by current technologies described above. 

Table 5-39. USS Gary Works’ 2011 Monthly Fluoride Discharge and Flow Data 

Outfall 

Monitoring 

Period Date Average Flow (MGD) 

Fluoride Quantity 

(kg/day) 

Calculated Fluoride 

Concentrations (mg/L) 

005 31-Jan-2011 51.1 82.1 0.424 

005 28-Feb-2011 49.7 113 0.601 

005 31-Mar-2011 46.9 82.5 0.465 

005 30-Apr-2011 51.6 100 0.512 

005 31-May-2011 43.5 82.5 0.501 

005 30-Jun-2011 46.3 92.9 0.531 

005 31-Jul-2011 48.3 94.3 0.516 

005 31-Aug-2011 54.3 85.7 0.417 

005 30-Sep-2011 47.7 78.4 0.434 

005 31-Oct-2011 45.9 82.9 0.477 

005 30-Nov-2011 42.1 83.4 0.523 

005 Dec-31-2011 46.3 90.7 0.518 

028 31-Jan-2011 7.2 79.3 2.91 

028 28-Feb-2011 6.7 74.0 2.92 

028 31-Mar-2011 7.6 84.3 2.93 

028 30-Apr-2011 7 79.8 3.01 

028 31-May-2011 6.7 80.2 3.16 

028 30-Jun-2011 6.48 72.6 2.96 

028 31-Jul-2011 5.4 77.1 3.77 

028 31-Aug-2011 5.8 74.8 3.41 

028 30-Sep-2011 5.6 69.8 3.29 

028 31-Oct-2011 7.5 97.5 3.43 

028 30-Nov-2011 6.7 73.9 2.91 

028 31-Dec-2011 9.5 126 3.50 

030 31-Jan-2011 19.4 210 2.86 

030 28-Feb-2011 21.3 268 3.32 

030 31-Mar-2011 22.8 240 2.79 

030 30-Apr-2011 22.2 237 2.83 

030 31-May-2011 21.1 240 3.01 

030 30-Jun-2011 19.5 228 3.09 

030 31-Jul-2011 17.5 244 3.69 

030 31-Aug-2011 19.6 253 3.41 

030 30-Sep-2011 19.0 266 3.70 

030 31-Oct-2011 21.5 285 3.50 

030 30-Nov-2011 21.4 254 3.13 

030 31-Dec-2011 20.7 279 3.57 

Source: DMRLTOutput2011_v1. 

5-39
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

Weirton Steel Corporation 

Weirton Steel Corporation in Weirton, WV, discharges fluoride from outfalls 003 and 

004 into the Ohio River and Harmon Creek, respectively (WVDEP, 2008a). The facility 

discharges cooling water, stormwater runoff, and process water from both outfalls. The facility’s 

permit calls for monitoring of fluoride discharges from outfall 003, but does not include fluoride 

limits (WVDEP, 2008a). The fluoride permit limit for outfall 004 is 1.4 mg/L on an average 

monthly basis and 2.2 mg/L daily maximum (WVDEP, 2008a). 

Table 5-40 presents the facility’s fluoride discharge data for 2011. As described above, 

EPA determined that current wastewater technologies (not specific to iron and steel) are 

achieving effluent fluoride concentrations between 2 mg/L and 15 mg/L. For its initial 

comparison, EPA determined that 2011 fluoride concentrations from outfall 004 are below the 

facility’s permit limit and below those achievable by current technologies, as shown in Table 

5-40. However, the fluoride concentrations from outfall 003 are significantly higher than outfall 

004, by an order of magnitude. Additionally, the September 2011 concentration exceeds the 

concentration range that can be achieved by current treatment technologies, described above. 

Therefore, facility-specific permitting action may be appropriate to address fluoride discharges 

from the Weirton Steel Corporation facility. 

Table 5-40. Weirton Steel Corporation’s 2011 Monthly Fluoride Discharge and Flow Data 

Outfall 

Monitoring Period 

Date 

Average Flow 

(MGD) 

Fluoride 

Concentration 

(mg/L) 

Facility Permit Limits 

Monthly Average 

(mg/L) 

Daily Maximum 

(mg/L) 

003 31-Mar-2011 7.86 8.00 Monitoring Only Monitoring Only 

003 30-Jun-2011 11.0 8.32 Monitoring Only Monitoring Only 

003 30-Sep-2011 10.8 22.0 Monitoring Only Monitoring Only 

003 31-Dec-2011 6.50 5.82 Monitoring Only Monitoring Only 

004 31-Jan-2011 2.49 0.190 1.4 2.2 

004 28-Feb-2011 2.38 0.260 1.4 2.2 

004 31-Mar-2011 3.14 0.230 1.4 2.2 

004 30-Apr-2011 3.37 0.320 1.4 2.2 

004 31-May-2011 3.39 0.240 1.4 2.2 

004 30-Jun-2011 2.47 0.507 1.4 2.2 

004 31-Jul-2011 1.23 0.730 1.4 2.2 

004 31-Aug-2011 1.04 0.430 1.4 2.2 

004 30-Sep-2011 0.790 0.480 1.4 2.2 

004 31-Oct-2011 0.580 0.530 1.4 2.2 

004 30-Nov-2011 1.30 0.360 1.4 2.2 

004 31-Dec-2011 1.14 0.370 1.4 2.2 

Source: DMRLTOutput2011_v1. 

5.5.4 Iron and Steel Manufacturing Category Aluminum Discharges in DMR 

EPA’s investigation of aluminum discharges revealed that one facility, Nucor Steel 

Decatur LLC (Nucor Steel) in Trinity, AL, accounts for 76 percent of the 2011 DMR aluminum 

5-40
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

discharges (shown in Table 5-41). EPA did not investigate the remaining facilities discharging 

aluminum as part of the 2013 Annual Review. 

Table 5-41. Top 2011 DMR Aluminum Discharging Facilities 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Nucor Steel Decatur LLC Trinity, AL 477,000 28,600 76% 

Remaining Facilities Reporting Aluminum Dischargesa 148,000 8,890 24% 

Total 625,000 37,500 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 17 remaining facilities that have aluminum discharges in the 2011 DMR data.
 

Nucor Steel discharges aluminum through ten outfalls. Outfall 002 discharges stormwater 

runoff from the scrap yard, north and south scrap bays, and slag yards associated with the 

manufacture of hot rolled steel and non-contact blowdown. Outfalls 003, 012, and 013 discharge 

stormwater runoff associated with the manufacture of hot rolled steel. Outfalls 004, 006, 008, 

and 010 discharge stormwater associated with transportation equipment parking and storage. 

Outfalls 007 and 011 discharge stormwater runoff, non-contact cooling water blowdown, reverse 

osmosis concentrate, softener backwash, and carbon filter backwash (Bullard, 2014). The facility 

permit calls for monitoring on a quarterly or semi-annual basis for aluminum discharges for all 

outfalls listed above (ADEM, 2008), but does not have aluminum limits. 

Table 5-42 presents Nucor’s original aluminum discharge data for 2011. As part of the 

2013 Annual Review, EPA contacted Nucor Steel to confirm the aluminum discharges. The 

facility contact confirmed the 2011 discharges and stated that the December 2011 aluminum 

concentration reading for outfall 011 of 775 mg/L was taken immediately following a major 

precipitation event. Therefore, it did not represent typical daily discharges during the 92 day 

monitoring period. The facility performed additional sampling on January 26, 2012, and 

provided EPA a revised value of 0.463 mg/L for aluminum at outfall 011 (Bullard, 2014). EPA 

recalculated the facility aluminum discharge using the revised value for outfall 011. This resulted 

in a reduction of the facility’s 2011 DMR aluminum TWPE from 28,600 to 9,530, reducing the 

Iron and Steel Category’s aluminum TWPE from 37,500 to 18,400. 

Aluminum is not a regulated pollutant in the Iron and Steel Manufacturing Category 

ELG. However, during the 2002 rulemaking EPA evaluated the treatment of aluminum in 

wastewater from steelmaking. At that time, EPA evaluated two-stage metals precipitation, which 

achieved a long-term average concentration (LTA) of aluminum of 0.229 mg/L (U.S. EPA, 2002, 

Appendix D). The facility’s discharge concentrations, presented in Table 5-42, are all higher than 

this achievable level. Therefore, facility-specific permitting action may be appropriate to address 

this facility’s aluminum discharges. 

5-41
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

Table 5-42. Nucor Steel’s 2011 Monthly Aluminum Concentration and Flow Data 

Outfall Monitoring Period Date Average Flow (MGD) 

Aluminum Concentration 

(mg/L) 

002 31-Mar-2011 1.33 1.59 

002 30-Jun-2011 6.61 4.99 

002 30-Sep-2011 8.35 5.65 

002 31-Dec-2011 1.27 0.804 

003 30-Jun-2011 0.810 0.22 

003 31-Dec-2011 0.780 28.4 

004 31-Mar-2011 0.057 14.3 

004 30-Jun-2011 0.120 24.3 

004 30-Sep-2011 0.150 12.4 

004 31-Dec-2011 0.060 21.5 

006 31-Mar-2011 0.075 23.1 

006 30-Jun-2011 0.180 0 

006 30-Sep-2011 0.230 7.68 

006 31-Dec-2011 0.091 10.4 

007 31-Mar-2011 0.026 0.690 

007 30-Jun-2011 0.052 1.49 

007 30-Sep-2011 0.066 2.47 

007 31-Dec-2011 0.025 0.810 

008 31-Mar-2011 0.028 5.16 

008 30-Jun-2011 0.056 3.68 

008 30-Sep-2011 0.071 11.7 

008 31-Dec-2011 0.027 9.78 

010 31-Mar-2011 0.015 14.8 

010 30-Jun-2011 0.030 12.2 

010 30-Sep-2011 0.039 4.06 

010 31-Dec-2011 0.015 4.27 

011 31-Mar-2011 0.260 1.33 

011 30-Jun-2011 0.670 3.58 

011 30-Sep-2011 0.840 3.14 

011 31-Dec-2011 0.530 775a 

012 30-Jun-2011 0.260 1.28 

012 31-Dec-2011 0.840 4.02 

013 30-Jun-2011 1.44 5.69 

013 31-Dec-2011 4.57 3.89 

Source: DMRLTOutput2011_v1; Bullard, 2014.
 a The facility contact stated that the December 2011 concentration reading for outfall 011 was taken immediately
 

following a major precipitation event. The facility performed additional sampling on January 26, 2012, and provided
 

a revised value of 0.463 mg/L.
 

5-42
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

5.5.5 Iron and Steel Manufacturing Category Cyanide Discharges in DMR 

EPA’s investigation of the cyanide discharges revealed that two facilities, USS Clairton 

Plant in Clairton, PA (USS Clairton Plant), and Mountain State Carbon Follansbee Plant in 

Follansbee, WV, account for 60 percent of the 2011 DMR cyanide discharges (shown in Table 

5-43). EPA did not investigate the remaining facilities discharging cyanide as part of the 2013 

Annual Review. 

Table 5-43. Top 2011 DMR Cyanide Discharging Facilities 

Facility Name Facility Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

USS Clairton Plant Clairton, PA 12,100 13,500 39% 

Mountain State Carbon Follansbee Plant Follansbee, WV 6,340 7,040 21% 

Remaining Facilities Reporting Cyanide Dischargesa 12,300 13,600 40% 

Total 30,700 34,100 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are twenty-four remaining facilities that have cyanide discharges in the 2011 DMR data.
 

Both of the top two facilities are cokemaking plants, i.e., they produce carbon-coke from 

coal for use in steelmaking. Cokemaking operations generate wastewater containing cyanide as 

part of the byproduct recovery process. For further information on cokemaking plants in the 

U.S., see section 9.4 of the 2011 Annual Review Report (U.S. EPA, 2012). 

During the 2002 Iron and Steel rulemaking, EPA established production-based limits for 

cyanide as best available technology (BAT) for the cokemaking subcategory (40 CFR Part 420 

Subpart A). The BAT production-based limits are based on an LTA of 2.965 mg/L, and a 

variability factor of 1.49 (U.S. EPA, 2002, Appendices D and E). 

USS Clairton Plant 

USS Clairton Plant discharges cyanide in cokemaking wastewater from outfall 183. This 

facility’s cyanide discharges were also reviewed as part of the 2011 Annual Review (U.S. EPA, 

2012). Table 5-44 presents U.S. Steel’s 2011 monthly cyanide and flow discharge data for outfall 

183. The cyanide permit limits for outfall 183 are 5.5 mg/L or 118 pounds per day (lbs/day) 

average monthly and 10 mg/L or 216 lbs/day daily maximum. The facility’s cyanide permit 

limits became effective in February 2002 and were extended to cover 2011 discharges (PA DEP, 

2006). 

As shown in Table 5-44, the facility’s discharge concentrations do not exceed permit 

limits and are below the LTA for cyanide calculated during the 2002 rulemaking. The facility’s 

high cyanide TWPE is likely the result of the large amount of industrial activity at the site. This 

facility has historically been the top coke producer in the U.S. (U.S. EPA, 2002). 

5-43
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

Table 5-44. USS Clairton Plant Outfall 183 2011 Monthly Cyanide and
 

Flow Discharge Data
 

Monitoring 

Period Date 

Average Cyanide 

Discharge 

(kg/day) 

Average Flow 

(MGD) 

Average Cyanide 

Concentrations 

(mg/L) 

Facility Permit Limits 

Monthly 

Average (mg/L) 

Daily Maximum 

(mg/L) 

31-Jan-11 9.36 2.21 1.12 5.5 10 

28-Feb-11 11.1 2.47 1.19 5.5 10 

31-Mar-11 12.2 2.48 1.30 5.5 10 

30-Apr-11 13.6 2.6 1.38 5.5 10 

31-May-11 16.3 2.46 1.75 5.5 10 

30-Jun-11 13.7 2.31 1.57 5.5 10 

31-Jul-11 12.3 2.43 1.34 5.5 10 

31-Aug-11 11.7 2.38 1.30 5.5 10 

30-Sep-11 8.94 2.26 1.05 5.5 10 

31-Oct-11 23.8 2.31 2.72 5.5 10 

30-Nov-11 24.1 2.47 2.58 5.5 10 

31-Dec-11 23.1 2.57 2.37 5.5 10 

Source: DMRLTOutput2011_v1; PA DEP, 2006. 

Mountain State Carbon Follansbee Plant 

Mountain State Carbon discharges cyanide from outfalls 005 and 205. Mountain State 

Carbon discharges sanitary water, cooling water, and process water from outfall 005, and treated 

process wastewater, ground water, and stormwater from the biological treatment plant through 

outfall 205. 

This facility’s cyanide discharges were also reviewed as part of the 2011 Annual Review 

(U.S. EPA, 2012). Table 5-45 presents Mountain State Carbon’s 2011 DMR monthly cyanide 

and flow discharge data for outfalls 005 and 205. The facility’s cyanide permit limits for outfall 

005 are 0.0114 mg/L monthly average and 0.0284 mg/L daily maximum. These permit 

limitations are well below the cyanide LTA calculated during the 2002 rulemaking (2.965 mg/L). 

The facility’s cyanide permit limits for outfall 205 are 24.5 lb/day (11.1 kg/day) monthly average 

and 34.9 lbs/day (15.8 kg/day) daily maximum (WVDEP, 2008b). As shown in Table 5-45, from 

February through June 2011, and again in December 2011, discharges of cyanide from outfall 

005 exceed the facility’s permit limits. However, these concentrations are not above the cyanide 

LTA calculated during the 2002 rulemaking. Additionally, the January 2011 and November 2011 

quantity from outfall 205 exceed the mass-based facility permit limit. Therefore, facility-specific 

permitting or compliance action may be appropriate to address cyanide discharges from 

Mountain State Carbon. 

5-44
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

Table 5-45. Mountain State Carbon’s 2011 Monthly Cyanide and Flow Discharge Data 

Outfall 

Monitoring 

Period Date 

Average 

Cyanide 

Discharge 

(kg/day) 

Average 

Flow 

(MGD) 

Average 

Cyanide 

Concentration 

(mg/L) 

Facility Permit Limits 

Facility 

Permit Limit 

Units 

Monthly 

Average 

Daily 

Maximum 

005 31-Jan-11 0.293 8.70 0.009 0.0114 0.0284 mg/L 

005 28-Feb-11 0.293 6.45 0.012a 0.0114 0.0284 mg/L 

005 31-Mar-11 0.423 6.58 0.017a 0.0114 0.0284 mg/L 

005 30-Apr-11 0.383 8.44 0.012a 0.0114 0.0284 mg/L 

005 31-May-11 0.646 12.2 0.014a 0.0114 0.0284 mg/L 

005 30-Jun-11 0.830 13.7 0.016a 0.0114 0.0284 mg/L 

005 31-Jul-11 0.256 14.1 0.005 0.0114 0.0284 mg/L 

005 31-Aug-11 0.505 14.2 0.009 0.0114 0.0284 mg/L 

005 30-Sep-11 0.378 14.7 0.007 0.0114 0.0284 mg/L 

005 31-Oct-11 0.509 13.3 0.010 0.0114 0.0284 mg/L 

005 30-Nov-11 0.398 13.8 0.008 0.0114 0.0284 mg/L 

005 31-Dec-11 2.70 10.5 0.068b 0.0114 0.0284 mg/L 

205 31-Jan-11 12.2a 0.82 3.93 11.1 15.8 kg/day 

205 28-Feb-11 4.17 0.87 1.27 11.1 15.8 kg/day 

205 31-Mar-11 10.4 0.84 3.27 11.1 15.8 kg/day 

205 30-Apr-11 3.58 0.72 1.31 11.1 15.8 kg/day 

205 31-May-11 7.88 0.71 2.93 11.1 15.8 kg/day 

205 30-Jun-11 3.40 0.71 1.27 11.1 15.8 kg/day 

205 31-Jul-11 9.07 0.69 3.47 11.1 15.8 kg/day 

205 31-Aug-11 6.62 0.74 2.36 11.1 15.8 kg/day 

205 30-Sep-11 6.25 0.76 2.17 11.1 15.8 kg/day 

205 31-Oct-11 4.98 0.69 1.91 11.1 15.8 kg/day 

205 30-Nov-11 12.2a 0.73 4.42 11.1 15.8 kg/day 

205 31-Dec-11 5.44 0.69 2.08 11.1 15.8 kg/day 

Source: DMRLTOutput2011_v1; WV DEP, 2008b.
 a Cyanide concentration or quantity exceeds monthly average permit limitation.
 b Cyanide concentration or quantity exceeds both monthly average and daily maximum permit limitations.
 

5.5.6 Iron and Steel Manufacturing Category Total Residual Chlorine Discharges in DMR 

EPA’s investigation of total residual chlorine discharges revealed that one facility, USS 

Clairton Plant in Clairton, PA, accounts for 49 percent of the 2011 DMR total residual chlorine 

discharges (shown in Table 5-46). EPA did not investigate the remaining facilities discharging 

chlorine as part of the 2013 Annual Review. 

5-45
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

Table 5-46. Top 2011 Total Residual Chlorine Discharging Facilities 

Facility Name Location 

Total Residual 

Chlorine 

Pounds 

Discharged 

Total 

Residual 

Chlorine 

TWPE 

Facility Percent of 

Total Residual 

Chlorine Category 

TWPE 

USS Clairton Plant Clairton, PA 28,000 14,000 49% 

Remaining Facilities Reporting Total Residual Chlorine 

Dischargesa 29,200 14,600 51% 

Total 57,200 28,600 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are twenty-eight remaining facilities that have total residual chlorine discharges in the 2011 DMR data.
 

The USS Clairton Plant is the top cokemaking facility in the U.S. and discharges total 

residual chlorine in cokemaking wastewater from outfall 038. Table 5-47 presents USS 

Clairton’s 2011 DMR monthly total residual chlorine and flow discharge for outfall 038. The 

chlorine permit limit for outfall 038 is 0.5 mg/L monthly average (PA DEP, 2006). As shown in 

Table 5-47, the facility’s discharges do not exceed permit limits. Similar to the facility’s cyanide 

discharges, discussed above, the high chlorine discharges are the result of the large amount of 

industrial activity at the facility. 

Table 5-47. USS Clairton Plant’s 2011 Monthly Total Residual Chlorine and 

Flow Discharge Data for Outfall 038 

Monitoring 

Period Date Average Flow (MGD) 

Average Total Residual 

Chlorine Concentrations (mg/L) 

Monthly Average 

Permit Limit (mg/L) 

31-Jan-11 36.8 0.11 0.5 

28-Feb-11 41.8 0.11 0.5 

31-Mar-11 39.0 0.05 0.5 

30-Apr-11 41.7 0.08 0.5 

31-May-11 62.0 0.05 0.5 

30-Jun-11 70.4 0.18 0.5 

31-Jul-11 63.2 0.47 0.5 

31-Aug-11 66.2 0.12 0.5 

30-Sep-11 71.5 0.09 0.5 

31-Oct-11 61.1 0.04 0.5 

30-Nov-11 50.7 0.45 0.5 

31-Dec-11 42.9 0.26 0.5 

Source: DMRLTOutput2011_v1. 

5.5.7 Iron and Steel Manufacturing Category Findings 

The estimated toxicity of the Iron and Steel Manufacturing Category discharges results 

from fluoride, aluminum, cyanide, and total residual chlorine discharges. From the 2013 Annual 

Review, EPA has identified the following: 

5-46
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

	 Three facilities, Arcelormittal Indiana Harbor LLC, USS Gary Works and 

Weirton Steel Corporation, account for 73 percent of the category’s fluoride 2011 

DMR discharges. EPA determined the following: 

—	 Arcelormittal Indiana Harbor LLC had an error in their 2011 DMR 

fluoride discharges. This correction decreased the facility’s fluoride 

TWPE from 15,000 to 1,320, reducing the Iron and Steel Category’s 

fluoride TWPE from 47,800 to 34,200. Fluoride discharges from outfalls 

009, 010, and 011 are below comparable concentrations achieved by 

current treatment technologies (not specific to iron and steel 

manufacturing). 

—	 The USS Gary Works 2011 DMR fluoride discharge data also do not 

exceed comparable concentrations achieved by current treatment 

technologies. 

—	 Weirton Steel Corporation’s permit calls for fluoride monitoring of two 

outfalls discharging fluoride; one outfall also has numeric limits. EPA 

found that discharge from the latter outfall, which has monitoring 

requirements only, may exceed the comparable concentration ranges 

achieved by current treatment technologies. Therefore, facility-specific 

permitting action may be appropriate to address fluoride discharges from 

the Weirton Steel Corporation facility. 

	 One facility, Nucor Steel Decatur LLC, contributes the majority of the aluminum 

discharges for the Iron and Steel Manufacturing Category. The facility confirmed 

the 2011 discharges, but noted that the reading from outfall 011 in December did 

not accurately represent the average discharge from the facility. Based on data resubmitted by Nucor Steel Decatur, EPA recalculated the 2011 aluminum loadings. 

This resulted in a reduction of the facility’s 2011 DMR aluminum TWPE from 

28,600 to 9,530, reducing the Iron and Steel Category’s aluminum TWPE from 

37,500 to 18,400. 

	 Two facilities, USS Clairton Plant and Mountain State Carbon, LLC, contribute 

the majority of the cyanide discharges for the Iron and Steel Manufacturing 

Category. EPA reviewed cyanide discharges and found: 

—	 The USS Clairton Plant 2011 DMR cyanide discharge data do not exceed 

permit limits and are below the cyanide LTA calculated during the 2002 

rulemaking. The facility’s high cyanide TWPE is likely the result of the 

large amount of industrial activity at the facility, as they historically have 

been the top coke producer in the U.S. 

—	 Several months of cyanide discharges from two different outfalls at 

Mountain State Carbon exceed the facility’s mass-based permit limit; 

therefore facility-specific permitting action may be appropriate to address 

cyanide discharges from this facility. 

	 One facility, USS Clairton Plant, is responsible for the majority of the total 

residual chlorine discharges. The facility’s discharge data do not exceed permit 

limits. Similar to cyanide discharges for USS Clairton Plant, the high chlorine 

5-47
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

discharges are likely the result of the large flows from the facility; it is the top 

cokemaking facility in the U.S. 

	 Correcting the database errors identified during the 2013 Annual Review 

decreases the 2011 Iron and Steel Category TWPE from 1,220,000 to 214,000 

TWPE. In addition, EPA identified several facilities for facility-specific 

permitting action. 

5.5.8	 References for Iron and Steel Manufacturing Category 

1.	 ADEM. 2008. Alabama Department of Environmental Management. Draft NPDES 

Permit: Nucor Steel Decatur LLC, Trinity, AL. (February 1). EPA-HQ-OW-2014-0170. 

DCN 07893. 

2.	 Belack, Dan. 2007. Notes from E-mail Communication Between Dan Belack, US Steel, 

and Jan Matuszko, U.S. EPA. Re: DMR Clarification Needed for U.S. Steel. (May 7). 

EPA-HQ-OW-2006-0771-0480. 

3.	 Bullard, Carey. 2014. Notes from Telephone and E-mail Communication Between Carey 

Bullard, Nucor Steel LLC, and Julia Kolberg, Eastern Research Group, Inc. Re: DMR 

Clarification Needed for Nucor Steel LLC. (January 23). EPA-HQ-OW-2014-0170. DCN 

07889. 

4.	 ERG. 2014. Preliminary Category Review – Facility Data Review and Revised 

Calculations for Point Source Category 420 – Iron and Steel. (March). EPA-HQ-OW2014-0170. DCN 07902. 

5.	 Gaylord, Bruce. 2013. Notes from E-mail Communication Between Bruce Gaylord, 

Republic Conduit, and Carey Johnston, U.S. EPA. Re: DMR Clarification Needed for 

Republic Conduit. (May 23). EPA-HQ-OW-2014-0170. DCN 07892. 

6.	 GCIP. 2002. General Chemical Industrial Products. Chapter 14 – Wastewater and Water 

Treatment. Available online at: http://www.genchem.com/calcium/NCh14.html. EPAHQ-OW-2004-0032-2606. 

7.	 IDNR. 2007. Indiana Department of Natural Resources. NPDES Permit Fact Sheet: USS 

Gary Works, Gary, IN. (August 1). EPA-HQ-OW-2014-0170. DCN 07890. 

8.	 Ionics. n.d. “The EnChem® Process for Fluoride Removal.” Wastewater Treatment for 

the Microelectronics Industry. Available online at: 

http://www.iconics.com/pdf/TS4752EUS.pdf. EPA-HQ-OW-2004-0032-2605. 

9.	 PA DEP. 2006. Commonwealth of Pennsylvania Department of Environmental 

Protection, Water Management Program. NPDES Permit: U.S. Steel Corporation– 

Clairton Works, Clairton, PA. (December 27). EPA-HQ-OW-2010-0824. DCN 07598. 

10.	 U.S. EPA. 2002. Development Document for Final Effluent Limitations Guidelines and 

Standards for the Iron and Steel Manufacturing Point Source Category. Washington, DC. 

EPA-821-R-02-004. EPA-HQ-OW-2010-0824. DCN 07720. 

5-48
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.5—Iron and Steel Manufacturing (40 CFR Part 420) 

11.	 U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent 

Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQOW-2006-0771-0819. 

12.	 U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

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

Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-1070. DCN 

07756. 

14.	 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. EPA-HQ-OW-2004-0032-2604. 

15.	 WVDEP. 2008a. West Virginia Department of Environmental Protection. NPDES 

Permit: Arcelormittal Weirton Inc. (Weirton Steel Corporation), Weirton, WV. (July 28). 

EPA-HQ-OW-2014-0170. DCN 07891. 

16.	 WVDEP. 2008b. West Virginia Department of Environmental Protection. NPDES 

Permit: Mountain State Carbon, Follansbee, WV. (January 15). EPA-HQ-OW-2010­

0824. DCN 07601. 

5-49
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.6—Metal Finishing (40 CFR Part 433) 

5.6 Metal Finishing (40 CFR Part 433) 

During the 2012 Annual Review, EPA’s review of the Targeted National Sewage Sludge 

Survey (TNSSS), combined with available indirect discharge data from the toxics release 

inventory (TRI), identified the Metal Finishing Category (40 CFR Part 433) as potentially 

discharging high concentrations of metals, particularly chromium, nickel, and zinc, to publicly 

owned treatment works (POTWs). These metals could transfer to sewage sludge and diminish its 

beneficial use. Further, the Metal Finishing Category ranked high, in terms of toxic-weighted 

pound equivalents (TWPE), in the 2013 toxicity rankings analysis (TRA). As a result, EPA is 

continuing a preliminary category review of this category to evaluate further the need to revise 

the existing effluent limitations guidelines and standards (ELGs). 

5.6.1 Summary of Metal Finishing ELGs 

In 1979, EPA promulgated pretreatment standards for existing sources (PSES) for the 

Electroplating Category (40 CFR Part 413). These standards covered only existing indirect 

dischargers. Subsequently, EPA built upon the 1979 electroplating regulations and promulgated 

ELGs for the Metal Finishing Category (40 CFR Part 433) on September 15, 1983 (48 FR 

41409). 

The Metal Finishing ELGs consist of one subcategory (Subpart A, “Metal Finishing 

Subcategory”), with limitations that apply to wastewater discharges from six metal finishing 

operations. The applicability is not defined by industry sector, but by the six core electroplating 

operations originally identified in Part 413, and 40 additional process operations (Table 5-48). In 

addition to best practicable control technology (BPT), best available technology economically 

achievable (BAT), and new source performance standards (NSPS), Part 433 includes PSES and 

pretreatment standards for new sources (PSNS) limitations. Table 5-49 lists the metal finishing 

(40 CFR Part 433) applicability, regulated pollutants, and limitations. Part 433 supersedes most 

of Part 413, with the exception of discharges from independent job shops and printed circuit 

board manufacturers. Another Categorical Pretreatment Standard may cover wastewater 

discharges from metal finishing operations, in which case, the specific standard will apply. The 

following regulations take precedence over Part 433: 

 Nonferrous Smelting and Refining (40 CFR Part 421); 

 Coil Coating (40 CFR Part 465); 

 Porcelain Enameling (40 CFR Part 466); 

 Battery Manufacturing (40 CFR Part 461); 

 Iron and Steel Manufacturing (40 CFR Part 420); 

 Metal Casting Foundries (40 CFR Part 464); 

 Aluminum Forming (40 CFR Part 467); 

 Copper Forming (40 CFR Part 468); 

 Plastic Molding and Forming (40 CFR Part 463); 

 Electrical and Electronic Components (40 CFR Part 469); and 

 Nonferrous Forming (40 CFR Part 471). 

5-50
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.6—Metal Finishing (40 CFR Part 433) 

Table 5-48. Unit Operations Regulated by ELGs for the Metal Finishing Category 

Six Core Electroplating Operations 

(Introduced in Part 413) 

40 Additional Metal Processing Operations 

(Introduced in Part 433) 

 Electroplating 

 Electroless Plating 

 Anodizing 

 Coating 

 Etching And Chemical Milling 

 Printed Circuit Board Manufacturing 

 Cleaning 

 Machining 

 Grinding 

 Polishing 

 Barrel Finishing 

 Burnishing 

 Impact Deformation 

 Pressure Deformation 

 Shearing 

 Heat Treating 

 Thermal Cutting 

 Welding 

 Brazing 

 Soldering 

 Flame Spraying 

 Sand Blasting 

 Abrasive Jet Machining 

 Electrical Discharge Machining 

 Electrochemical Machining 

 Electron Beam Machining 

 Laser Beam Machining 

 Plasma Arc Machining 

 Ultrasonic Machining 

 Sintering 

 Laminating 

 Hot Dip Coating 

 Sputtering 

 Vapor Plating 

 Thermal Infusion 

 Salt Bath Descaling 

 Solvent Degreasing 

 Paint Stripping 

 Painting 

 Electrostatic Painting 

 Electropainting 

 Vacuum Metalizing 

 Assembly 

 Calibration 

 Testing 

 Mechanical Plating 

Table 5-49. Applicability, Regulated Pollutants, and ELG Limits for the
 

Metal Finishing Category
 

Subpart Applicability Pollutant 

BAT/PSES 

Daily Max

(Monthly

Average) (mg/L) 

NSPS/PSNS Daily

Max (Monthly

Average) (mg/L) a 

Subpart A – 

Metal 

Finishing

Subcategory 

The provisions of this subpart apply to

discharges from the following six metal

finishing operations on any basis material:

Electroplating, Electroless Plating,

Anodizing, Coating (chromating,

phosphating, and coloring), Chemical

Etching and Milling, and Printed Circuit

Board Manufacture.a 

Silver 0.43 (0.24) 0.43 (0.24) 

Copper 3.38 (2.07) 3.38 (2.07) 

Lead 0.69 (0.43) 0.69 (0.43) 

Cyanide 1.20 (0.65) 1.20 (0.65) 

Cadmium 0.69 (0.26) 0.11 (0.07) 

Chromium 2.77 (1.71) 2.77 (1.71) 

Nickel 3.98 (2.38) 3.98 (2.38) 

Zinc 2.61 (1.48) 2.61 (1.48) 

For industrial facilities with cyanide

treatment, and upon agreement between a

source subject to those limits and the

pollution control authority, the following

amenable cyanide limit may apply in

place of the total cyanide limit. 

Cyanide

amenable to 

alkaline 

chlorination 

0.86 (0.32) 0.86 (0.32) 

Source: 40 CFR §433.10.
 a This part does not apply to (1) metallic platemaking and gravure cylinder preparation conducted within or for
 

printing and publishing facilities or (2) existing indirect discharging job shops and independent printed circuit board
 

manufacturers which are covered by 40 CFR part 413.
 

5-51
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.6—Metal Finishing (40 CFR Part 433) 

5.6.2 History of EPA Reviews of the Metal Finishing Category 

EPA first conducts a screening-level review of all categories subject to existing ELGs in 

its TRA. In 2009, EPA conducted a screening-level review of the Metal Finishing Category (U.S. 

EPA, 2009). In the 2011 Annual Review, EPA selected the Metal Finishing Category (40 CFR 

Part 433) for a preliminary category review because it ranked high in the point source category 

rankings, in terms of TWPE (U.S. EPA, 2012). EPA assigned this category lower priority for 

revision in the Preliminary 2012 Plan after correcting reported discharges from facilities 

contributing to the high TWPE (U.S. EPA, 2013). 

EPA did not complete a preliminary category review of the category during the 2012 

Annual Review. However, during the 2012 Annual Review, EPA identified additional data 

sources that suggest further review of this category (U.S. EPA, 2014). Further, the category 

continued to rank high in the point source category rankings in EPA’s 2013 Annual Review. 

EPA plans to conduct a more detailed preliminary category review of the Metal Finishing 

Category during the 2014 Annual Review for the following reasons: 

1.	 As part of the 2012 Annual Review (U.S. EPA, 2014), EPA reviewed the TNSSS 

conducted by EPA’s Office of Water (OW), which measured contaminant 

concentrations in sewage sludge from 74 POTWs. Although the TNSSS did not 

specifically identify the industrial wastewater discharged to the sampled POTWs, 

EPA used information from TRI to examine pollutants discharged to POTWs, and 

explored how those pollutants might interfere with beneficial use of sewage sludge. 

This review suggested further investigation of pollutants discharged to POTWs by the 

metal finishing industry, particularly metals, including chromium, nickel and zinc, 

which were above the POTW sludge limits. EPA did not identify for further review 

any new pollutants of concern or wastewater discharges from industrial categories not 

currently regulated by ELGs. 

Additionally, the Metal Finishing Category (40 CFR Part 433) has 52 facilities 

reporting discharges to TNSSS POTWs, more than any other category. When 

facilities with discharges covered by Electroplating (40 CFR Part 413) are added, the 

two point source categories comprise nearly 50 percent of the facilities reporting 

discharges to the 35 TNSSS POTWs, indicating that these two categories may be 

primary sources of metals discharged to POTWs. 

2.	 EPA received comments from regional EPA offices and State pretreatment 

coordinators regarding POTW treatability issues arising from wastewater discharges 

received from metal processing facilities. One such issue was that the limits for this 

category might be improperly applied to metals industries regulated by other ELGs 

that take precedence over 40 CFR Part 433. 

3.	 EPA received comments from the Association of Clean Water Administrators 

(ACWA) recommending that EPA revise regulations or issue new guidance regarding 

pretreatment standards for the metal finishing industry because new technologies used 

by the industry may introduce new pollutants of concern that are not currently 

addressed in POTW or NPDES permits (InsideEPA, 2013). Such new technologies 

may also not be covered under the 46 existing metal finishing operations. 

5-52
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.6—Metal Finishing (40 CFR Part 433) 

4.	 EPA evaluated the metal finishing industry (among other metals industries) during 

the development of the Metal Products and Machinery (MP&M) rule (40 CFR Part 

438), promulgated in 2003. As part of the rulemaking, EPA conducted sampling 

episodes at 84 sites between 1986 and 2001 to obtain data on the characteristics of 

wastewater and solid wastes, including sites with metal finishing operations. This 

sampling program revealed the impact of technological advances in treating 

wastewater since EPA promulgated Part 433 in 1983. Table 5-50 compares the 

maximum monthly average effluent limits established by the 1983 Metal Finishing 

ELGs with the limits observed for the metal finishing industry during the MP&M rule 

development (covered by four subcategories in 40 CFR Part 438). EPA proposed 

these limits in 2001, but they were not promulgated. 

5.	 As outlined in the 2012 Annual Review Report (U.S. EPA, 2012), EPA is collecting 

data on new treatment technologies used to treat metals in industrial wastewater and 

is evaluating newer treatment performance levels to supplant the limits established by 

the Metal Finishing ELGs in 1983. From a preliminary comparison, it appears that 

treatment technologies developed after 1983 can reduce metals in wastewater to 

significantly lower levels than technologies that were available when the 1983 ELGs 

were developed. 

Table 5-50. Maximum Monthly Average Effluent Limits of Part 413, Part 433, and 

Proposed Part 438 

Pollutant Unit 

40 CFR Part 413a 

40 CFR 

Part 433b 40 CFR Part 438c 

>10,000 

gpd 

<10,000 

gpd 

NSPS & 

PSNS PSES 

General 

Metals 

MF Job 

Shops 

Non-Cr 

Anodizing 

Printed 

Wiring 

Board 

TSS mg/L 18 31 31 31 

Oil and Grease mg/L 12 26 26 26 

TOC mg/L 50 59 67 

Total organics 

parameter mg/L 4.3 4.3 4.3 

Total Metals mg/L 5.0 

Aluminum mg/L 4.0 

Cadmium mg/L 0.5 0.5 0.07 0.26 0.09 0.09 

Chromium mg/L 2.5 1.71 1.71 0.14 0.55 0.14 

Copper mg/L 1.8 2.07 2.07 0.28 0.57 0.28 

Total Cyanide mg/L 0.23 0.65 0.65 0.13 0.13 0.13 

Amenable 

Cyanide mg/L 1.5 0.32 0.32 0.07 0.07 0.07 

Lead mg/L 0.3 0.3 0.43 0.43 0.03 0.09 0.03 

Manganese mg/L 0.09 0.10 0.09 0.64 

Molybdenum mg/L 0.49 0.49 

Nickel mg/L 1.8 2.38 2.38 0.31 0.64 0.31 0.14 

Silver mg/L 0.5 d 0.24 0.24 0.09 0.06 

5-53
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.6—Metal Finishing (40 CFR Part 433) 

Table 5-50. Maximum Monthly Average Effluent Limits of Part 413, Part 433, and
 

Proposed Part 438
 

Pollutant Unit 

40 CFR Part 413a 

40 CFR 

Part 433b 40 CFR Part 438c 

>10,000 

gpd 

<10,000 

gpd 

NSPS & 

PSNS PSES 

General 

Metals 

MF Job 

Shops 

Non-Cr 

Anodizing 

Printed 

Wiring 

Board 

Sulfide, Total mg/L 13 13 13 

Tin mg/L 0.67 1.4 0.14 

Zinc mg/L 1.8 1.48 1.48 0.22 0.17 0.22 0.22 

Sources: U.S. EPA, 1979; U.S. EPA, 1983; U.S. EPA 2000.
 

Gray highlighting indicates no limits were set for the pollutant.
 a EPA established discharge limits based on a wastewater production threshold of 10,000 gallons per day (gpd).
 b NSPS – New Source Performance Standards; PSNS – Pretreatment Standards for New Sources; PSES –
 

Pretreatment Standards for Existing Sources.
 c Part 438 developed proposed limits for 8 subcategories, of which 4 subcategories are relevant to the metal finishing
 

industry: General Metals, Metal Finishing (MF) Job Shops, Non-chromium (Non-Cr) Anodizing, and Printed Wiring
 

Board.
 d The silver pretreatment standard applies only to Subpart B, precious metals plating.
 

Although EPA has not revised the Part 433 ELGs since 1983, the Agency has reviewed 

annual discharge data as part of the 304m review process. Table 5-51 compares the top three 

pollutants with the highest contribution to the 2011 DMR TWPE (PCB-1248, copper, and 

cyanide) and shows the 2009 DMR TWPE for these top pollutants based on the results of the 

2011 Annual Review (U.S. EPA, 2012). The top three pollutants contribute 45 percent of the 

total 2011 DMR TWPE. 

Table 5-52 shows that the top three pollutants, copper and copper compounds, lead and 

lead compounds, and silver and silver compounds, contribute 69 percent of the total 2011 TRI 

TWPE. For comparison, the table shows the 2009 TRI TWPE for these top pollutants, based on 

the results of the 2011 Annual Review (U.S. EPA, 2012). 

EPA’s review of the TNSSS identified chromium, nickel, and zinc as the top pollutants of 

concern at POTWs, which are most likely contributed by metal finishing facilities. The top 

pollutants identified in the DMR and TRI data indicate additional pollutants that do not overlap 

with EPA’s review of the TNSSS data. Further review is warranted to understand more fully the 

pollutants of concern for the Metal Finishing Category. 

5-54
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.6—Metal Finishing (40 CFR Part 433) 

Table 5-51. Metal Finishing Category Top DMR Pollutants 

Pollutant 

2011 DMR Dataa 2009 DMR Dataa 

Number of Facilities 

Reporting Pollutant b TWPE TWPE 

PCB-1248 2 44,200 24,200 

Copper 243 40,200 9,400 

Cyanide 68 35,500 39,400 

Top Pollutant Total NA 120,000 73,000 

Metal Finishing Category Total 626 265,000 197,000 

Sources: DMRLoads2009_v2; DMRLTOutput2011_v1.
 

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

NA: Not applicable.
 a DMR data include major and minor dischargers.
 b Number of DMR facilities reporting TWPE greater than zero.
 

Table 5-52. Metal Finishing Category Top TRI Pollutants 

Pollutant 

2011 TRI Data 2009 TRI Data 

Number of Facilities 

Reporting Pollutant a TWPE TWPE 

Copper and Copper Compounds 1,540 13,600 12,900 

Lead and Lead Compounds 2,256 11,100 10,700 

Silver and Silver Compounds 27 10,800 41,700 

Top Pollutant Total NA 35,500 65,300 

Metal Finishing Category Total 1,785 51,700 86,100 

Sources: TRIReleases2009_v2; TRILTOutput2011_v1.
 

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

NA: Not applicable.
 a Number of facilities reporting TWPE greater than zero.
 

For the continuing preliminary review of the Metal Finishing Category, EPA plans to: 

	 Collect updated industry information on the number of facilities (including 

indirect dischargers and small businesses) and how metal finishing operations and 

processes currently employed by the industry compare to the operations and 

processes used in 1983. 

	 Review data collected during the development of the MP&M ELGs to profile the 

metal finishing industry, further evaluate the proposed limits for metal finishing 

operations, and to review the POTW survey results for additional metals 

concentration data from POTWs that receive wastewater from metal finishing 

operations. 

	 Continue to analyze trends in DMR and TRI data to identify pollutants of interest. 

	 Review data from other EPA and government programs or industry sources (e.g., 

regional EPA pretreatment programs, ACWA) to understand changes in 

technologies and identify potential new pollutants of concern. 

5-55
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.6—Metal Finishing (40 CFR Part 433) 

	 Review new information on treatment technology performance to determine 

which technologies, if any, can reduce pollutants in metal finishing wastewater to 

concentrations lower than the Part 433 ELGs. 

EPA will use the findings from the preliminary category review to identify: 

	 Additional data needs for this industry, including information on industry 

economics and potential environmental impacts of current discharges. 

	 Metal finishing operations that are not covered by the 46 existing unit operations. 

	 Pollutants present in metal finishing wastewater that may not be included in the 

ELGs and that may warrant further study. 

	 Alternative manufacturing operations or chemistries that reduce or eliminate 

pollutant discharges. 

	 Current best available treatment technologies for removing pollutants from metal 

finishing wastewater. 

5.6.3	 References for Metal Finishing Category 

1.	 Inside EPA. 2013. States Say 'Green' Metal Finishing Technology Requires New Effluent 

Limitations Guidelines Guide. InsideEPA.com. Doc ID: 2440462. (July 16). EPA-HQOW-2014-0170. DCN 07870. 

2.	 U.S. EPA. 1979. Development Document for Existing Source Pretreatment Standards for 

the Electroplating Point Source Category. Washington, D.C. (August). EPA-HQ-OW2014-0170. DCN 07871. 

3.	 U.S. EPA. 1983. Federal Register Notice: Electroplating and Metal Finishing Point 

Source Categories; Effluent Limitations Guidelines, Pretreatment Standards, and New 

Source Performance Standards. Washington, D.C., (July 15). EPA-HQ-OW-2014-0170. 

DCN 07868. 

4.	 U.S. EPA. 2000. Development Document for the Proposed Effluent Limitations 

Guidelines and Standards for the Metal Products & Machinery Point Source Category. 

Washington, D.C. (December). EPA-HQ-OW-2014-0170. DCN 07869. 

5.	 U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent 

Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQOW-2008-0517-0515. 

6.	 U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December) EPA-821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

7.	 U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, D.C. 

(May). EPA-HQ-OW-2010-0824. DCN 07684. 

8.	 U.S. EPA. 2014. The 2012 Annual Effluent Guidelines Review Report. Washington, D.C. 

(September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824. DCN 07933. 

5-56
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.7—Nonferrous Metals Manufacturing (40 CFR Part 421) 

5.7 Nonferrous Metals Manufacturing (40 CFR Part 421) 

EPA selected the Nonferrous Metals Manufacturing (NFMM) Category for preliminary 

review because it continues to rank high, in terms of toxic-weighted pound equivalents (TWPE), 

in the point source category rankings. EPA reviewed discharges from the NFMM Category as 

part of the 2004, 2006, 2007, 2009, and 2011 reviews (U.S. EPA, 2004, 2006, 2007, 2009, 2012). 

This section summarizes the results of the 2013 Annual Review associated with the NFMM 

Category. EPA focused on discharges of cadmium, copper, mercury, polychlorinated biphenyls 

(PCBs), and lead from discharge monitoring reports (DMR) because of their high TWPE relative 

to other pollutants in the NFMM Category. Cadmium, mercury, and lead, reviewed as part of the 

2011 Annual Review, continue to be top pollutants of concern. For the 2013 Annual Review, 

available discharge data also showed significant contributions of copper and PCBs to the NFMM 

Category TWPE. 

5.7.1 NFMM Category 2013 Toxicity Rankings Analysis 

Table 5-35 compares the toxicity rankings analysis (TRA) results for the NFMM 

Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in 2012, but 

instead reviewed additional data sources as part of the even-year annual review as discussed in 

the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014). As 

discussed below, EPA’s review of the NFMM Category identified a data error that affected the 

2011 DMR data and TWPE. The bottom row of Table 5-35 shows the corrected data resulting 

from this review. 

Table 5-53. NFMM Category TRI and DMR Facility Counts and Discharges for the 

2011 and 2013 Annual Reviews 

Year of 

Discharge 

Year of 

Review 

NFMM Category Facility Counts NFMM Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major Facilities 

Total DMR 

Minor Facilitiesa 

TRI 

TWPEb 

DMR 

TWPEc 

Total 

TWPE 

2009d 2011 121 29 19 40,500 160,000 201,000 

2011 2013 

119 28 23 42,900 383,000 426,000 

2011e 2013 42,900 330,000 373,000 

Sources: 2011 Annual Review Report (for 2009d DMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_v1
 

(for 2011 DMR); TRILTOutput2011_v1 (for 2011 TRI).
 

Note: EPA did not evaluate DMR data for 2010.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a DMR minor facilities are reporting facilities and contribute to the total DMR TWPE.
 b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
 

POTW removals.
 c DMR discharges from both minor and major facilities.
 d 2009 data after corrections made during the 2011 Annual Review.
 e 2011 data after corrections made during the 2013 Annual Review.
 

As shown in Table 5-35, the total TWPE (incorporating data corrections) has increased 

from 2009 to 2011. During that period, the number of TRI facilities and minor DMR facilities 

decreased, while the number of major DMR facilities increased. 

5-57
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.7—Nonferrous Metals Manufacturing (40 CFR Part 421) 

5.7.2 NFMM Category Pollutants of Concern 

For its 2013 Annual Review, EPA’s review of the NFMM Category focused on the 2011 

DMR discharges because the 2011 DMR data account for 90 percent of the category’s combined 

TWPE. Table 5-54 lists the five pollutants with the highest contribution to the 2011 DMR 

TWPE. Table 5-54 also presents the 2011 DMR TWPE after EPA corrected an error identified in 

this preliminary category review (discussed in the sections below). In addition, as a point of 

comparison, Table 5-54 shows the 2009 DMR TWPE for these top five pollutants based on the 

results of (and corrections identified in) the 2011 Annual Review (U.S. EPA, 2012). 

Cadmium, copper, mercury, PCBs, and lead contribute more than 82 percent of the total 

2011 category DMR TWPE. EPA’s investigations of reported discharges of the top five 

pollutants are presented in Section 5.7.3 to 5.7.7. EPA did not investigate the other pollutants as 

part of the 2013 Annual Review because they account only 18 percent of the 2011 DMR TWPE 

for the NFMM Category. 

Table 5-54. 2011 NFMM Category Top DMR Pollutants 

Pollutant 

2011 DMR Dataa 2009 DMR Dataa 

Number of Facilities 

Reporting Pollutant 

Original 

TWPE 

Corrected 

TWPE TWPE 

Cadmium 9 114,000 114,000 22,900 

Copper 22 60,300 7,380 754 

Mercury 6 59,200 59,200 29,100 

PCBs 2 59,100 59,100 4,140 

Lead 21 19,400 19,400 24,300 

Top Pollutants, Total NA 312,000 259,000 81,200 

NFMM Category, Total 55b 383,000 330,000 160,000 

Sources: DMRLTOutput2011_v1 (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE) 

(U.S. EPA, 2012).
 

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

NA: Not applicable.
 a DMR data include major and minor dischargers.
 b Number of facilities reporting TWPE greater than zero.
 

5.7.3 NFMM Category Cadmium Discharges in DMR 

EPA’s investigation of the cadmium discharges revealed that Nyrstar Clarksville Inc. 

(Nyrstar), in Clarksville, TN accounts for over 98 percent of the 2011 DMR cadmium compound 

discharges (shown in Table 5-55). EPA did not investigate the remaining facilities discharging 

cadmium. 

5-58
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.7—Nonferrous Metals Manufacturing (40 CFR Part 421) 

Table 5-55. Top 2011 DMR Cadmium Discharging Facilities 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Nyrstar Clarksville Inc. Clarksville, TN 4,850 112,000 98% 

Remaining Facilities Reporting Cadmiuma 98.4 2,270 2% 

Total 4,950 114,000 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are eight remaining facilities that have cadmium discharges in the 2011 DMR data.
 

Nyrstar produces zinc metal from beneficiation of zinc concentrate ore by a 

hydrometallurgical process. As secondary products, this facility also co-produces cadmium 

metal, sulfuric acid, and metallurgically valuable byproducts (TN DEC, 2005). Nyrstar 

discharges cadmium from outfalls 001, SW3, SW4, and SW5. Outfall 001 discharges treated 

process wastewater, sanitary wastewater, and cooling water (TN DEC, 2006). Outfalls SW3, 

SW4, and SW5 discharge stormwater runoff from the main production area, materials handling 

areas, and ancillary facility areas, respectively (Crocker, 2014). 

As part of the 2013 Annual Review, EPA contacted Nyrstar about the cadmium 

discharges; the facility contact confirmed the 2011 flow rates and concentrations. Table 5-56 

presents Nyrstar’s 2011 cadmium concentrations, along with the average monthly flow for the 

four outfalls. Because the facility reported a cadmium quantity in kilograms per day (kg/day) for 

outfall 001, EPA calculated the concentrations using the pollutant load discharged and the 

average monthly flow. The 2011 quantities discharged from outfall 001 range from 0.16 to 0.68 

kg/day. The facility’s permit limits cadmium for outfall 001 at 0.798 kg/day monthly average 

and 1.99 kg/day daily maximum. It does not limit cadmium discharges for outfalls SW3, SW4, 

and SW5 (TN DEC, 2006), but requires monitoring. As shown in Table 5-56, 2011 cadmium 

concentrations for outfall 001 are below the facility’s permit limits. 

Table 5-56. Nyrstar’s 2011 DMR Monthly Cadmium Discharges 

Outfall Date 

Quantity 

(kg/day) 

NPDES Monthly 

Average Permit 

Limit (kg/day) a Flow (MGD) 

Concentration 

(mg/L) 

001 31-Jan-11 0.470 0.798 0.590 0.210 

001 28-Feb-11 0.580 0.798 0.740 0.207 

001 31-Mar-11 0.440 0.798 0.804 0.145 

001 30-Apr-11 0.680 0.798 0.806 0.223 

001 31-May-11 0.560 0.798 0.820 0.180 

001 30-Jun-11 0.430 0.798 0.720 0.158 

001 31-Jul-11 0.204 0.798 0.170 0.317 

001 31-Aug-11 0.160 0.798 0.140 0.302 

001 30-Sep-11 0.410 0.798 0.690 0.157 

001 31-Oct-11 0.650 0.798 0.610 0.282 

001 30-Nov-11 0.290 0.798 0.605 0.127 

001 31-Dec-11 0.190 0.798 0.660 0.076 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.7—Nonferrous Metals Manufacturing (40 CFR Part 421) 

Table 5-56. Nyrstar’s 2011 DMR Monthly Cadmium Discharges 

Outfall Date 

Quantity 

(kg/day) 

NPDES Monthly 

Average Permit 

Limit (kg/day) a Flow (MGD) 

Concentration 

(mg/L) 

SW3 31-Mar-11 NR Monitoring only 0.320 0.510 

SW3 30-Jun-11 NR Monitoring only 0.083 0.330 

SW3 30-Sep-11 NR Monitoring only 0.940 2.05 

SW3 31-Dec-11 NR Monitoring only 0.640 1.90 

SW4 31-Mar-11 NR Monitoring only 0.204 0.290 

SW4 30-Jun-11 NR Monitoring only 0.039 0.980 

SW4 30-Sep-11 NR Monitoring only 0.490 1.57 

SW4 31-Dec-11 NR Monitoring only 0.430 0.025 

SW5 30-Jun-11 NR Monitoring only 1.77 0.025 

SW5 31-Dec-11 NR Monitoring only 4.28 0.180 

Sources: DMRLTOutput2011_v1; TN DEC, 2006.
 

NR: Not reported.
 a Indicates limits that were in effect when 2009 and 2011 discharge data were submitted.
 

Nyrstar was issued a new permit, which took effect January 2012. The revised permit set 

a daily maximum cadmium limit of 0.0159 milligrams per liter (mg/L) for outfalls SW3, SW4, 

and SW5, with a quarterly monitoring requirement (but no monthly average limit); it adjusted the 

limit for cadmium discharges from outfall 001 to 1.03 kg/day monthly average and 2.4 kg/day 

daily maximum. The cadmium limits for outfall 001 were revised based on additional site 

information, further insight on the facility’s operation/performance, and a revised best 

professional judgment determination (TN DEC, 2011). EPA anticipates that the facility’s new 

permit limits for the stormwater outfalls will result in a reduction in cadmium discharges and 

associated TWPE from this facility; therefore, further review of the NFMM Category’s cadmium 

discharges is not warranted at this time. 

5.7.4 NFMM Category Copper Discharges in DMR 

EPA’s investigation of the copper discharges revealed that Alcoa World Alumina LLC 

(Alcoa), in Point Comfort, TX accounts for over 88 percent of the 2011 DMR copper discharges 

(shown in Table 5-57). EPA did not investigate the remaining facilities discharging copper. 

Table 5-57. Top 2011 DMR Copper Discharging Facilities 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Alcoa World Alumina, LLC Point Comfort, TX 84,100 53,000 88% 

Remaining Facilities Reporting Coppera 11,700 7,370 12% 

Total 95,800 60,300 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 21 remaining facilities that have copper discharges in the 2011 DMR data.
 

Alcoa discharges copper from three outfalls. As part of the 2013 Annual Review, EPA 

compared discharge concentrations for all outfalls and identified a unit error for the June 2011 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.7—Nonferrous Metals Manufacturing (40 CFR Part 421) 

copper concentration for outfall 015. Table 5-58 presents Alcoa’s original and corrected average 

copper concentrations along with the average flow values for the three outfalls. With the 

corrected discharge concentrations incorporated, Alcoa’s copper TWPE decreases from 53,000 

to 7.19, reducing the NFMM Category’s copper TWPE from 60,300 to 7,380, as shown in Table 

5-54. 

Table 5-58. Alcoa’s 2011 DMR Original and Corrected Monthly Copper Discharges 

Outfall 

Monitoring Period 

Datea 

Average Flow 

(MGD) 

Original Copper 

Concentration (mg/L) 

Corrected Copper 

Concentration (mg/L) 

006 28-Feb-11 0.77 0.0039 0.0039 

006 30-Apr-11 0.018 0.0065 0.0065 

008 31-Jan-11 0.0017 0 0 

008 28-Feb-11 0.013 0.014 0.014 

008 31-Mar-11 0.0012 0.019 0.019 

008 31-May-11 0.0013 0 0 

008 30-Jun-11 0.0005 0.015 0.015 

008 31-Jul-11 0.0008 0.14 0.14 

008 30-Sep-11 0.001 0.074 0.074 

008 31-Oct-11 0.001 0.022 0.022 

008 30-Nov-11 0.000062 0.041 0.041 

008 31-Dec-11 0.00026 0.11 0.11 

015 31-Jan-11 0.15 0.0068 0.0068 

015 28-Feb-11 0.021 0 0 

015 31-May-11 0.016 0 0 

015 30-June-11 0.52 642 0.0642 

015 30-Sep-11 0.063 0.012 0.012 

015 31-Oct-11 0.072 0.094 0.094 

Source: DMRLTOutput2011_v1.
 a The facility reported no flow for January, March, May, June, July, August, September, October, November, or
 

December 2011 from Outfall 006; April or August 2011 from Outfall 008; or March, April, July, August,
 

November, or December 2011 from Outfall 115. Therefore, copper concentrations were not reported for those
 

months.
 

5.7.5 NFMM Category Mercury Discharges in DMR 

EPA’s investigation of the mercury discharges revealed that Alabama State Docks–Mud 

Lakes, (AL State Docks), in Mobile, AL accounts for over 99 percent of the 2011 DMR mercury 

discharges (shown in Table 5-59). EPA did not investigate the remaining facilities discharging 

mercury. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.7—Nonferrous Metals Manufacturing (40 CFR Part 421) 

Table 5-59. Top 2011 DMR Mercury Discharging Facilities 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Alabama State Docks–Mud Lakes Mobile, AL 499 58,500 99% 

Remaining Facilities Reporting Mercury Dischargesa 6.16 721 1% 

Total 505 59,200 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are five remaining facilities that have mercury discharges in the 2011 DMR data.
 

EPA reviewed the mercury discharges from AL State Docks as part of the 2010 and 2011 

Annual Review (U.S. EPA, 2011, 2012). As discussed in the 2010 Annual Review, AL State 

Docks is a dock that serves as a transfer station for bulk cargo that is exported and imported. The 

site contains former aluminum ore tailings lakes, now used to accumulate and treat aluminum ore 

tailings leachate before discharge to the Mobile River. The site is not an industrial manufacturing 

site (U.S. EPA, 2011). EPA determined that the facility’s discharges result from the aluminum 

ore tailings lakes, not current manufacturing. EPA verified the facility’s 2008 mercury 

discharges of 25,900 TWPE; the 2011 discharge data are similar in order of magnitude. Because 

the facility no longer operates as an aluminum ore mine and processing facility and the 

discharges are similar to those in previous years, facility-specific permitting action may be 

appropriate to address this facility’s mercury discharges. 

5.7.6 NFMM Category PCB Discharges in DMR 

EPA’s investigation of the PCB discharges revealed that U.S. Enrichment Corporation– 

Paducah Gaseous Diffusion Plant (U.S. Enrichment Corp.), in Paducah, KY accounts for 96 

percent of the 2011 DMR PCB discharges (shown in Table 5-60). Only two facilities have 2011 

DMR PCB discharges; the other was Alcoa Lafayette Operations, which EPA did not investigate 

as part of the 2013 Annual Review because it contributes only 4 percent of PCB TWPE in the 

NFMM Category. 

Table 5-60. Top 2011 DMR PCB Discharging Facilities 

Facility Name Facility Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent 

of Category 

TWPE 

U.S. Enrichment Corp. – Paducah Gaseous 

Diffusion Plant 

Paducah, KY 1.67 56,700 96% 

Alcoa Lafayette Operations Lafayette, IN 0.0686 2,330 4% 

Total 1.74 59,100 100% 

Source: DMRLTOutput2011_v1.
 

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

U.S. Enrichment Corp. is a large uranium enrichment facility currently owned by the U.S. 

Department of Energy. The facility opened in 1952, and its enrichment operations ceased in 

2013. The plant produced low-enriched-uranium fuel for commercial nuclear power plants in the 

U.S. and around the world (USEC, 2014). The site was listed on the National Priorities List as a 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.7—Nonferrous Metals Manufacturing (40 CFR Part 421) 

Superfund site in 1994. EPA has been working with federal and state partners to clean up the site 

since the late 1980s, and expects the process to take many more years (U.S. EPA, 2013). 

U.S Enrichment Corp. discharges PCBs from outfalls 002, 009, 010, 011, and 012. PCB 

discharges from outfalls 002, 010, 011, and 012 are generated from stormwater runoff and onsite 

uranium enrichment processes and are discharged to Little Bayou Creek. Discharges from outfall 

009 are generated from stormwater runoff combined with cooling water and are discharged to 

Big Bayou Creek. The facility permit does not set a limit for PCB discharges, but requires 

monitoring for the five outfalls (KY DEP, 1998). Table 5-61 presents the facility’s PCB 

discharge flow rates and concentrations for 2011. EPA contacted the Kentucky Department of 

Environmental Protection, which verified the facility’s PCB discharges. As shown, the PCB 

concentrations range from 0.00019 to 0.0014 mg/L. 

U.S. Enrichment Corp. shut down its uranium enrichment process in 2013, and EPA has 

been working to clean up the site for many years. Therefore, the facility’s PCB discharges are 

likely not representative of other facilities in the category, and EPA is not performing further 

review of PCB discharges from this facility at this time. 

Table 5-61. U.S. Enrichment Corporation’s 2011 PCB Discharge and Flow Data 

Outfall Monitoring Period Date Average Flow (MGD) PCB Concentration (mg/L) 

002 31-Mar-2011 2.60 0.0014 

009 30-Apr-2011 1.29 0.00019 

010 30-Apr -2011 0.680 0.00033 

011 28-Feb-2011 1.60 0.00029 

011 31-Mar -2011 0.760 0.00048 

011 31-Jul-2011 0.010 0.0002 

012 31-Mar -2011 2.60 0.00053 

Source: DMRLTOutput2011_v1. 

5.7.7 NFMM Category Lead Discharges in DMR 

EPA’s investigation of the lead discharges revealed that Nyrstar Clarksville Inc. 

(Nyrstar), Clarksville, TN and Sanders Lead Company, Troy, AL account for 93 percent of the 

2011 DMR lead discharges (shown in Table 5-62). EPA did not investigate the remaining 

facilities discharging lead. 

Table 5-62. Top 2011 DMR Lead Discharging Facilities 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Nyrstar Clarksville Inc. Clarksville, TN 5,400 12,100 62% 

Sanders Lead Company Inc. Troy, AL 2,690 6,020 31% 

Remaining Facilities Reporting Leada 568 1,270 7% 

Total 8,660 19,400 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a 18 remaining facilities reported lead discharges in the 2011 DMR data.
 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.7—Nonferrous Metals Manufacturing (40 CFR Part 421) 

Nyrstar Clarksville, Inc. 

Manufacturing and outfall information for Nyrstar is summarized in Section 5.7.3 as part 

of the cadmium discussion. Nyrstar discharges lead from outfalls SW3, SW4, and SW5 

(Crocker, 2014). Discharges from these outfalls are the result of stormwater runoff from the main 

production area, materials handling areas, and ancillary facility areas, respectively. As part of the 

2013 Annual Review, EPA contacted Nyrstar about the lead discharges from these outfalls; the 

facility contact confirmed the 2011 lead discharge flow rates and concentrations. Table 5-63 

presents Nyrstar’s 2011 lead concentrations along with the average monthly flow for the 

stormwater outfalls. 

Table 5-63. Nyrstar’s 2011 DMR Monthly Lead Discharges 

Outfall Date Concentration (mg/L) Flow (MGD) 

SW3 31-Mar-11 0.170 0.320 

SW3 30-Jun-11 0.050 0.083 

SW3 30-Sep-11 2.39 0.940 

SW3 31-Dec-11 0.350 0.640 

SW4 31-Mar-11 1.60 0.204 

SW4 30-Jun-11 3.54 0.039 

SW4 30-Sep-11 3.95 0.490 

SW4 31-Dec-11 0.050 0.430 

SW5 30-Jun-11 0.050 1.77 

SW5 31-Dec-11 0.220 4.28 

Source: DMRLTOutput2011_v1. 

At the time of discharge in 2011, the facility’s permit did not include lead discharge 

limits for outfalls SW3, SW4, and SW5 (TN DEC, 2006). In January 2012, a new permit took 

effect, setting a daily maximum of 0.156 mg/L for outfalls SW3, SW4, and SW5 with quarterly 

monitoring required (but no monthly average limit) (TN DEC, 2011). Lead discharges at this 

facility are now regulated by the updated permit limits. Because lead limits have been added to 

the most recent facility permit, EPA expects that lead discharges from the stormwater outfalls at 

this facility will decrease on future DMRs. 

Sanders Lead Company, Inc. 

Sanders Lead Company Inc. in Troy, AL, is a secondary lead smelting plant that recycles 

lead-acid batteries. The wastes are recycled to recover the lead (Rutherford, 2013). Sanders Lead 

Company discharges wastewater from two outfalls, 003 and 004. Outfall 003 discharges 

stormwater runoff from maintenance areas and roof drains from the lead smelting plant; outfall 

004 discharges stormwater runoff from non-process portions of the lead smelting operation 

(ADEM, 2008). 

As part of the 2013 Annual Review, EPA contacted the facility about their lead 

discharges. The facility contact provided 2012 and 2013 lead concentration information 

(Rutherford, 2013). Table 5-64 presents Sanders Lead Company’s 2011, 2012, and 2013 biannual lead concentration information for outfalls 003 and 004. As shown, 2012 and 2013 lead 

concentrations are lower than 2011 lead concentrations. 

5-64
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.7—Nonferrous Metals Manufacturing (40 CFR Part 421) 

Table 5-64. 2011, 2012, and 2013 Lead Discharges from Sanders Lead Company, Inc. 

Date Outfall Concentration (mg/L) Flow (MGD) 

30-Jun-11 003 0.019 1.69 

31-Dec-11 003 0.034 7.3 

30-Jun-12 003 0.0054 1.9 

31-Dec-12 003 0.012 5.9 

30-Jun-13 003 <0.002 3.3 

30-Jun-11 004 0.0089 10.7 

31-Dec-11 004 0.03 45.9 

30-Jun-12 004 0.0052 11.9 

31-Dec-12 004 0.009 37.7 

30-Jun-13 004 <0.002 20.1 

Source: DMRLTOutput2011_v1. 

The facility contact explained the decrease in lead concentrations was due to a number of 

improvements to the facility’s particulate and stormwater containment capabilities (Rutherford, 

2013): 

	 Performing operations indoors, self-enclosed, and under negative pressure. 

	 Construction of a new vehicle maintenance shop and machinery fabrication shop 

to eliminate the potential for tracking metal constituents. 

	 Sweeping of the internal roadway to remove dust, dirt and debris. 

	 Replacement of asphalt pavement with new concrete in major traffic roadways to 

ensure more effective sweeping. 

The facility’s permit requirement only requires that they report lead discharges. It does not 

establish a limit. Based on the decreasing lead concentrations, EPA does not consider lead 

discharges from this facility to be a priority for further review. 

5.7.8	 NFMM Category Findings 

The estimated toxicity of the NFMM Category discharges resulted from DMR cadmium, 

copper, mercury, PCBs, and lead discharges. From the 2013 Annual Review, EPA has identified 

the following: 

	 One facility, Nyrstar Clarksville Inc., contributes the majority of the cadmium 

discharges to the 2011 DMR data. This facility was issued a new permit in 2012 

to control cadmium discharges from its stormwater outfalls and further review 

from EPA is not warranted at this time. 

	 One facility, Alcoa World Alumina, contributes the majority of the copper 

discharges to the 2011 DMR data. In reviewing the facility discharge information, 

EPA found an error in the concentrations reported for the facility. Correcting the 

data resulted in a reduction in the NFMM Category’s copper TWPE from 60,300 

to 7,380. 

5-65
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.7—Nonferrous Metals Manufacturing (40 CFR Part 421) 

	 One facility, AL State Docks, contributes the majority of the mercury discharges 

to the 2011 DMR data. EPA reviewed these discharges as part of the 2010 and 

2011 Annual Reviews and determined that they result from former aluminum ore 

tailings lakes, not from current manufacturing. Because the facility no longer 

operates as an aluminum ore mine and processing facility and the discharges are 

similar to those in previous years, facility-specific permitting action may be 

appropriate to address this facility’s mercury discharges. 

	 One facility, the U.S. Enrichment Corporation–Paducah Gaseous Diffusion Plant, 

contributes the majority of the PCB discharges to the 2011 DMR data. This 

facility shut down its uranium enrichment process in 2013, and cleanup efforts 

have been active at the site since the late 1980s. For these reasons, EPA is not 

performing further review of PCB discharges from this facility at this time. 

	 Two facilities, Nyrstar Clarksville Inc. and Sanders Lead Company, contribute the 

majority of the lead discharges to the 2011 DMR data. Nyrstar was issued a new 

permit in 2012, and further review from EPA is not warranted at this time. EPA 

determined that new containment technology and better management practices at 

Sanders Lead Company facility have allowed steady reductions in the 

concentration of lead discharges. 

	 Correcting the reporting errors identified during the 2013 Annual Review 

decreases the 2011 NFMM Category TWPE from 426,000 to 373,000. The total 

TWPE, incorporating data corrections, increased from 201,000 in 2009 to 373,000 

in 2011, while the number of facilities reporting discharges stayed about the same. 

However, for the majority of the top pollutants, one or two facilities contribute a 

majority of the TWPE. EPA has determined that those facilities either warrant 

individual permitting action or have already received revised permit limits that 

will reduce wastewater discharges in the future. A category-wide discharge issue, 

warranting an effluent guidelines revision, is not apparent. 

5.7.9	 References for NFMM Category 

1.	 ADEM. 2008. Alabama Department of Environmental Management. NPDES Permit: 

Sanders Lead Co. Inc. (October 29). EPA-HQ-OW-2014-0170. DCN 07908. 

2.	 Crocker, William. 2013. Telephone and Email Communication Between William 

Crocker, Nyrstar, and Julia Kolberg, Eastern Research Group, Inc., Re: 2011 DMR 

Cadmium and Lead Discharges. (December 11). EPA-HQ-OW-2014-0170. DCN 07904. 

3.	 ERG. 2014. Preliminary Category Review – Facility Data Review and Revised 

Calculations for Point Source Category – 421 – NFMM. (March). EPA-HQ-OW-2014­

0170. DCN 07918. 

4.	 KY DEP. 1998. Kentucky Department of Environmental Protection. NPDES Permit: U.S. 

Enrichment Corporation–Paducah Gaseous Diffusion Plant. (March 13). EPA-HQ-OW2014-0170. DCN 07903. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.7—Nonferrous Metals Manufacturing (40 CFR Part 421) 

5.	 Rutherford, Chris. 2013. Telephone and Email Communication Between Chris 

Rutherford, Sanders Lead Company, Inc., and Julia Kolberg, Eastern Research Group, 

Inc., Re: 2011 DMR Lead Discharges. (December 20). EPA-HQ-OW-2014-0170. DCN 

07907. 

6.	 TN DEC. 2005. Tennessee Department of Environment and Conservation. NPDES 

Permit Fact Sheet: Nyrstar Clarksville, Inc., Clarksville, Tennessee. (May 31). EPA-HQOW-2010-0824. DCN 07573. 

7.	 TN DEC. 2006. Tennessee Department of Environment and Conservation. NPDES 

Permit: Nyrstar Clarksville, Inc, Clarksville, Tennessee. (June 1). EPA-HQ-OW-2010­

0824. DCN 07574. 

8.	 TN DEC. 2011. Tennessee Department of Environment and Conservation. NPDES 

Permit: Nyrstar Clarksville, Inc, Clarksville, Tennessee. (November 30). EPA-HQ-OW2014-0170. DCN 07906. 

9.	 U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program 

Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346 

through 1352. 

10.	 U.S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program 

Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032­

2782. 

11.	 U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent 

Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQOW-2006-0771-0819. 

12.	 U.S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent 

Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQOW-2008-0517-0515. 

13.	 U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program 

Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA-HQ-OW-2008-0517. DCN 

07320. 

14.	 U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December). EPA-820-R-10-021. EPA-HQ-OW-2008-0517. DCN 07685. 

15.	 U.S. EPA. 2013. Region 4: Superfund Site - U.S. DOE Gaseous Diffusion Plant. 

Available online at: http://www.epa.gov/region4/superfund/sites/fedfacs/pgasdifky.html. 

Date accessed: February 17, 2014. EPA-HQ-OW-2014-0170.DCN 07909. 

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

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

07756. 

17.	 USEC. 2014. Paducah Gaseous Diffusion Plant. Available online at: 

http://www.usec.com/gaseous-diffusion/paducah-gdp. Accessed February 17, 2014. EPAHQ-OW-2014-0170. DCN 07910. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

5.8 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 

equivalents (TWPE), in point source category rankings. EPA reviewed discharges from the 

OCPSF Category as part of the 2004 through 2011 reviews (U.S. EPA, 2004, 2005a, 2005b, 

2006, 2007, 2008, 2009a, 2011, 2012). This section summarizes the results of the 2013 Annual 

Review pertaining to the OCPSF Category. EPA focused on discharges of hexachlorobenzene, 

total residual chlorine, and polychlorinated biphenyls (PCBs) because of their high TWPE 

relative to other pollutants in the OCPSF Category. Hexachlorobenzene, reviewed as part of the 

2011 Annual Review, continues to be a top pollutant of concern. For the 2013 Annual Review, 

available discharge data also showed significant contributions of total residual chlorine and 

PCBs to the OCPSF Category TWPE. 

5.8.1 OCPSF Category 2013 Toxicity Rankings Analysis 

Table 5-65 compares the toxicity rankings analysis (TRA) results for the OCPSF 

Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in 2012, but 

instead reviewed additional data sources as part of the even-year annual review as discussed in 

the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014). As 

discussed in this section, EPA’s review of the OCPSF Category identified several data errors that 

affected the 2011 DMR data and TWPE. The bottom row of Table 5-65 shows the corrected data 

resulting from this review. 

Table 5-65. OCPSF Category TRI and DMR Facility Counts and Discharges for the 

2011 and 2013 Annual Reviews 

Year of 

Discharge 

Year of 

Review 

OCPSF Category Facility Counts OCPSF Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilitiesa 

TRI 

TWPEb 

DMR 

TWPEc 

Total 

TWPE 

2009d 2011 671 169 150 146,000 491,000 637,000 

2011 2013 

631 165 180 

148,000 1,540,000 1,690,000 

2011e 2013 148,000 658,000 806,000 

Sources: 2011 Annual Review Report (for 2009d DMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_v1
 

(for 2011 DMR); TRILTOutput2011_v1 (for 2011 TRI).
 

Note: EPA did not evaluate DMR data for 2010.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
 b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
 

POTW removals.
 c DMR discharges from both minor and major facilities.
 d 2009 data after corrections made during the 2011 Annual Review.
 e 2011 data after corrections made during the 2013 Annual Review.
 

As shown in Table 5-65, the total TWPE (incorporating data corrections) has increased 

from 2009 to 2011. During that period, the number of TRI and minor DMR facilities decreased, 

the number of major DMR facilities increased. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

5.8.2 OCPSF Category Pollutants of Concern 

For its 2013 Annual Review, EPA’s review of the OCPSF Category focused on the 2011 

DMR discharges because the 2011 DMR data dominate the category’s combined TWPE. Table 

5-66 compares the five pollutants with the highest contribution to the 2011 DMR TWPE. It also 

presents the 2011 DMR TWPE after EPA corrected errors identified in this preliminary category 

review (discussed in the sections below). In addition, as a point of comparison, Table 5-66 shows 

the 2009 DMR TWPE for these top five pollutants based on the results of (and corrections 

identified in) the 2011 Annual Review (U.S. EPA, 2012). 

Hexachlorobenzene, total residual chlorine, and PCBs contribute more than 65 percent of 

the total 2011 DMR TWPE. EPA’s investigations of reported discharges of the top three 

pollutants are presented in Sections 5.8.3 to 5.8.5. EPA did not investigate the other top 

pollutants as part of the 2013 Annual Review (i.e., mercury and lead), because they represent 

less than 35 percent of the 2011 DMR TWPE for the OCPSF Category. 

Table 5-66. OCPSF Category Top DMR Pollutants 

Pollutant 

2011 DMR Dataa 2009 DMR Dataa 

Number of Facilities 

Reporting Pollutant Original TWPE 

Corrected 

TWPE TWPE 

Hexachlorobenzene 11 689,000 61,800 81,300 

Total Residual Chlorine 110 169,000 59,500 75,800 

PCBs 1 147,000 0 0 

Lead 51 114,000 114,000b 2,550 

Mercury 34 110,000 110,000b 741 

Top Pollutant Total NA 1,230,000 345,000 160,000 

OCPSF Category Total 345c 1,540,000 658,000 491,000 

Sources: DMRLTOutput2011_v1 (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE) 

(U.S. EPA, 2012).
 

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

NA: Not applicable.
 a DMR data include major and minor dischargers.
 b Mercury and lead discharges combined contribute less than 15 percent of the 2011 category DMR TWPE.
 

Therefore, EPA did not review mercury or lead discharges as part of the 2013 Annual Review.
 c Number of facilities reporting TWPE greater than zero.
 

5.8.3 OCPSF Category Hexachlorobenzene Dischargers in DMR 

EPA’s investigation of hexachlorobenzene discharges revealed that Honeywell 

International Incorporated–Hopewell (Honeywell), in Hopewell, VA, accounts for more than 91 

percent of the 2011 DMR hexachlorobenzene discharges (shown in Table 5-67). EPA did not 

investigate the remaining facilities discharging hexachlorobenzene. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

Table 5-67. Top 2011 DMR Hexachlorobenzene Discharging Facilities 

Facility Name 

Facility 

Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Honeywell International Incorporated ­

Hopewell Hopewell, VA 322 627,000 91% 

Remaining Facilities Reporting Hexachlorobenzene 

Dischargesa 31.7 61,800 9% 

Total 354 689,000 100% 

Source: DMRLTOutput2011_v1.
 

Note: Values presented in the table are rounded to three significant figures. Sums of individual values may not equal
 

the total presented, due to rounding.
 a There are 10 remaining facilities that have hexachlorobenzene discharges in the 2011 DMR data.
 

Honeywell reported hexachlorobenzene discharges from outfall 101, which discharges 

contact cooling water from two barometric condensers (VA DEQ, 2008). As part of the 2013 

Annual Review, EPA contacted Honeywell about the facility’s hexachlorobenzene discharges. 

Honeywell stated that the hexachlorobenzene discharges were measured at levels below 

detection and confirmed that below-detection-limit (BDL) indicators were not properly marked 

on the DMR (Parker, 2013). As described in Section 3.2.2.2 in EPA’s 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), EPA zeros the 

load when all concentrations of a specific pollutant are BDL for all monitoring periods (U.S. 

EPA, 2009b). Therefore, EPA zeroed Honeywell’s hexachlorobenzene discharges, which 

decreases the corrected total hexachlorobenzene TWPE for the OCPSF category from 689,000 to 

61,800, as shown in Table 5-66. 

5.8.4 OCPSF Category Total Residual Chlorine Dischargers in DMR 

EPA’s investigation of the total residual chlorine discharges revealed that Celanese LTD– 

Bay City Plant (Celanese), in Bay City, TX, accounts for more than 65 percent of the 2011 DMR 

chlorine discharges (shown in Table 5-68). EPA did not investigate the remaining facilities 

discharging total residual chlorine. 

Table 5-68. Top 2011 DMR Total Residual Chlorine Discharging Facilities 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Celanese LTD –Bay City Plant Bay City, TX 218,000 109,000 65% 

Remaining Facilities Reporting Total Residual 

Chlorine Dischargesa 119,000 59,500 35% 

Total 337,000 169,000 100% 

Source: DMRLTOutput2011_v1. 

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

a There are 109 remaining facilities that have total residual chlorine discharges in the 2011 DMR data. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

Celanese17 discharges total residual chlorine from outfall 001. As part of the 2013 Annual 

Review, EPA contacted Celanese about its total residual chlorine discharges. The facility contact 

explained that process wastewater from the facility enters an internal domestic wastewater 

treatment plant and then is transferred to a permitted onsite neutral effluent treatment (NET) 

system via an internal outfall. Wastewater from the NET system is discharged via outfall 001 to 

the Colorado River. The contact explained that the facility’s permit has a minimum chlorine limit 

of 1 milligram per liter for the internal outfall between the internal wastewater treatment plant 

and the NET system. The facility adds chlorine in the internal domestic wastewater treatment 

plant and the chlorine level must meet the minimum limit upon entering the NET system. Outfall 

001 discharges treated domestic wastewater and treated process wastewater (commingled) from 

the facility (TCEQ, 2007). Outfall 001 does not have a chlorine limit; however, the facility is 

reporting the chlorine concentrations at the internal outfall as part of its DMRs. The facility is 

working to remove the internal outfall chlorine limit listing from the DMRs in its current permit 

renewal cycle to avoid further confusion (Gavranovic, 2013). 

Since the total residual chlorine discharges from Celanese are from an internal outfall 

rather than outfall 001, EPA removed the chlorine discharges from the DMR TWPE total for this 

facility. With this correction, the total residual chlorine TWPE for the OCPSF category decreases 

from 169,000 to 59,500, as shown in Table 5-66. 

5.8.5 OCPSF Category PCB Dischargers in DMR 

EPA’s investigation of PCB discharges revealed that Aventis Cropscience USA, in 

Institute, WV, accounts for 100 percent of the 2011 DMR PCB discharges (shown in Table 

5-69). There were no remaining facilities discharging PCBs. 

Table 5-69. 2011 DMR PCB Discharging Facility 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Aventis Cropscience USA Institute, WV 4.31 147,000 100% 

Source: DMRLTOutput2011_v1. 

Aventis reported PCB discharges from outfall 001. As part of the 2013 Annual Review, 

EPA contacted Aventis about the facility’s PCB discharges. Aventis stated that all PCB 

discharges for 2011 were measured at levels below detection and that proper BDL indicators 

were not marked on the DMR (Smith, 2014). As described in Section 3.2.2.2 in EPA’s 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), EPA 

zeros the load when all concentrations of a specific pollutant are BDL for all monitoring periods 

(U.S. EPA, 2009b). Therefore, EPA zeroed Aventis’ PCB discharges, which decreases the 

corrected total PCB TWPE from the OCPSF category from 147,000 to 0, as shown in Table 

5-66. 

17 The facility is also referred to as OXEA Corporation, because Celanese sold parts of the company to OXEA in 

2007. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

5.8.6	 OCPSF Category Findings 

The estimated toxicity of the OCPSF Category discharges resulted from DMR 

hexachlorobenzene, total residual chlorine, and PCB discharges. From the 2013 Annual Review, 

EPA has identified the following: 

	 One facility, Honeywell International Incorporated, contributes the majority of the 

reported hexachlorobenzene discharges to the 2011 DMR data. The facility 

contact confirmed that BDL indicators were not properly marked on the DMR. 

Because all hexachlorobenzene discharges were non-detect, EPA zeroed the 

hexachlorobenzene load and TWPE for Honeywell. With this error corrected, the 

hexachlorobenzene TWPE for the OCPSF category decreased from 689,000 to 

61,800. 

	 One facility, Celanese, contributes the majority of the total residual chlorine 

discharges to the 2011 DMR data. The facility contact confirmed that the total 

residual chlorine discharges on the 2011 DMRs are from an internal outfall, not 

an external outfall. Therefore, EPA removed the total residual chlorine discharges 

for Celanese from the TWPE total for this category. With this error corrected, the 

total residual chlorine TWPE for the OCPSF category decreased from 169,000 to 

59,500. 

	 The PCB discharges are reported by one facility, Aventis Cropscience USA. The 

facility contact confirmed that below detection limit indicators were not properly 

marked on the DMR. Because all PCB discharges were non-detect, EPA zeroed 

the PCB load and TWPE for Aventis Cropscience. With this error corrected, the 

PCB TWPE for the OCPSF category decreased from 147,000 to 0. 

	 EPA corrected errors for discharges reported by three facilities. Correcting the 

errors identified during the 2013 Annual Review decreases the 2011 OCPSF 

Category TWPE from 1,690,000 to 806,000. The total corrected TWPE has 

increased from 2009 to 2011, likely a result of an increase in the number of minor 

discharging facilities, and thus the total number of facilities, submitting DMR 

data from 2009 to 2011. In addition, the total TWPE continues to remain high, 

which EPA attributes to the large number of facilities in the OCPSF industry. 

5.8.7	 References for OCPSF Category 

1.	 ERG. 2014. Preliminary Category Review – Facility Data Review and Revised 

Calculations for Point Source Category 414 – OCPSF. (March). EPA-HQ-OW-2014­

0170. DCN 07926. 

2.	 Gavranovic, Gladys. 2013. Telephone and Email Communication Between Gladys 

Gavranovic, Celanese LTD, and Kimberly Bartell, Eastern Research Group, Inc., Re: 

2011 DMR Chlorine Discharges for Celanese LTD. (December 13). EPA-HQ-OW-2014­

0170. DCN 07922. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

3.	 Parker, Andrew. 2013. Telephone and Email Communication Between Andrew Parker, 

Honeywell International Inc., and Kimberly Bartell, Eastern Research Group, Inc., Re: 

2011 DMR Discharges for Honeywell International. (December 13). EPA-HQ-OW-2014­

0170. DCN 07919. 

4.	 Smith, Gordon. 2014. Telephone and Email Communication Between Gordon Smith, 

Aventis Cropscience, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 

DMR PCB Discharges. (January 15). EPA-HQ-OW-2014-0170. DCN 07920. 

5.	 TCEQ. 2007. Texas Commission on Environmental Quality. NPDES Permit: Oxea 

Corporation, Bay City, Texas. (March 26). EPA-HQ-OW-2014-0170. DCN 07923. 

6.	 U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program 

Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346 

through 1352. 

7.	 U.S. EPA. 2005a. Preliminary 2005 Review of Prioritized Categories of Industrial 

Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004­

0032-0016. 

8.	 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, D.C. (April). EPA-HQ-OW-2004-032-2568. 

9.	 U.S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program 

Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032­

2782. 

10.	 U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent 

Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQOW-2006-0771-0819. 

11.	 U.S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program 

Plan. Washington, D.C. (August). EPA-821-R-08-015. EPA-HQ-OW-2006-0771-1701. 

12.	 U.S. EPA. 2009a. Technical Support Document for the Preliminary 2010 Effluent 

Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQOW-2008-0517-0515. 

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

Effluent Guidelines and Identification of Potential New Point Source Categories. EPA821-R-09-007. Washington, D.C. (October). EPA-HQ-OW-2008-0517-0515. 

14.	 U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program 

Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA-HQ-OW-2008-0517 DCN 

07320. 

15.	 U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December). EPA-821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 

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

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

07756. 

17.	 VA DEQ. 2008. Virginia Department of Environmental Quality. NPDES Permit: 

Honeywell International, Inc., Hopewell, VA. (September 30). EPA-HQ-OW-2014-0170. 

DCN 07921. 

5-74
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.9—Petroleum Refining (40 CFR Part 419) 

5.9 Petroleum Refining (40 CFR Part 419) 

During the 2011 Annual Review, EPA selected the Petroleum Refining Category (40 

CFR Part 419) for a preliminary review because it ranked high, in terms of toxic-weighted pound 

equivalents (TWPE) (U.S. EPA, 2012). At that time, EPA found that the TWPE was largely due 

to Toxics Release Inventory (TRI) reported discharges of dioxin and dioxin-like compounds, 

polycyclic aromatic compounds (PACs), and discharge monitoring report (DMR) reported 

discharges of sulfides, chlorine, and metals. EPA continued to review this category during the 

2012 Annual Review to verify facilities’ discharges and confirmed the 2011 Annual Review 

results. EPA also reviewed new air pollution control regulations to identify whether the 

regulations could result in new wastewater streams. EPA now plans to conduct a more detailed 

study of this industry to further investigate the findings from the 2011 and 2012 Annual 

Reviews. 

The effluent limitations guidelines and standards (ELGs) for petroleum refining (40 CFR 

Part 419) were promulgated in 1982. EPA established Best Practicable Control Technology 

(BPT), Best Available Technology Economically Achievable (BAT), and New Source 

Performance Standards (NSPS) production-based mass limitations for the following pollutants: 

 Ammonia as nitrogen; 

 Biochemical oxygen demand; 

 Chemical oxygen demand (or total organic compounds for high-chloride 

effluents); 

 Hexavalent chromium; 

 Oil and grease; 

 pH; 

 Phenolic compounds; 

 Sulfide; 

 Total chromium; and 

 Total suspended solids. 

As shown in the list above, only one metal (chromium) is currently regulated. EPA has 

not revised the ELGs since 1982, but has subsequently reviewed annual discharge data from 

2004 to 2011. Table 5-1 compares the toxicity rankings analysis results for the Petroleum 

Refining Category from the 2011 and 2013 Annual Reviews. 

5-75
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.9—Petroleum Refining (40 CFR Part 419) 

Table 5-70. Petroleum Refining Category TRI and DMR Facility Counts and Discharges 

for the 2011 and 2013 Annual Reviews 

Year of 

Discharge 

Year of 

Review 

Petroleum Refining Category Facility 

Counts Petroleum Refining Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilitiesa TRI TWPEb 

DMR 

TWPEc Total TWPE 

2009 2011 280 96 153 436,000 260,000 697,000 

2011 2013 274 91 172 681,000 752,000 1,430,000 

Sources: 2011 Annual Review Report (for 2009 DMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_v1
 

(for 2011 DMR); TRILTOutput2011_v1 (for 2011 TRI).
 

Note: EPA did not evaluate DMR or TRI data for 2010.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
 b Discharges include direct discharges to surface waters and transfers to publicly owned treatment works (POTWs).
 

Transfers to POTWs account for POTW removals.
 c DMR discharges from both minor and major facilities.
 

Table 5-71 presents the top five pollutants with the highest contribution to the 2011 DMR 

TWPE and Table 5-72 presents the top five pollutants with the highest contribution to the 2011 

TRI TWPE. In addition, as a point of comparison, Table 5-71 and Table 5-72 show the 2009 

DMR and TRI TWPE, respectively, for the top five pollutants based on the results of (and 

corrections identified in) the 2011 Annual Review (U.S. EPA, 2012). As shown in the tables, 

organic compounds, such as dioxin and dioxin-like compounds and PACs, rank high in both the 

2011 DMR and TRI pollutants. Mercury and mercury compounds also rank high. EPA did not 

review the facility-specific discharges for this industry during the 2013 Annual Review because 

EPA plans to conduct a more detailed study of this industry in 2014. As a result, some of the 

TWPE may be attributed to data errors. 

Table 5-71. Petroleum Refining Category Top DMR Pollutants 

Pollutant 

2011 DMR Dataa 2009 DMR Dataa 

Number of Facilities 

Reporting Pollutant TWPE TWPE 

Indeno(1,2,3-cd)pyreneb 6 280,000 256 

2,3,7,8-tetrachlorodibenzo-p-dioxin 1 219,000 0.329 

Methylmercury 5 77,300 306 

Sulfide 63 62,400 136,000 

Total Residual Chlorine 21 37,200 11,300 

Top Pollutant Total NA 676,000 148,000 

Petroleum Refining Category Total 263c 752,000 261,000 

Sources: DMRLTOutput2011_v1 (for 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE) (U.S.
 

EPA, 2012).
 

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

NA: Not applicable.
 a DMR data include major and minor dischargers.
 b Indeno(1,2,3-cd)pyrene is a PAC.
 c Number of facilities reporting TWPE greater than zero.
 

5-76
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.9—Petroleum Refining (40 CFR Part 419) 

Table 5-72. Petroleum Refining Category Top TRI Pollutants 

Pollutant 

2011 TRI Data 2009 TRI Data 

Number of Facilities 

Reporting Pollutant TWPE TWPE 

Dioxin and Dioxin-Like Compounds 18 435,000 315,000 

Mercury And Mercury Compounds 69 118,000 22,600 

Pacs 68 42,700 35,000 

Hexachlorobenzene 1 23,400 0 

Nitrate Compounds 64 16,700 14,600 

Top Pollutant Total NA 636,000 387,000 

Petroleum Refining Category Total 274a 681,000 436,000 

Sources: TRILTOutput2011_v1 (for 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE) (U.S. EPA,
 

2012).
 

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

NA: Not applicable.
 a Number of facilities reporting TWPE greater than zero.
 

EPA conducted a detailed study of this industry as part of the 2004 Final Effluent 

Guidelines Program Plan reviews (U.S. EPA, 2004). However, the industry has since changed. 

Refineries are processing heavier feedstocks (e.g., Canadian crude, tar sands), which may be a 

source of the increased metals in the discharges. In addition, changes in air pollution control 

regulations may have increased the use of wet scrubbers to control air emissions. EPA revised 

NSPS for petroleum refineries in 2012 (40 CFR 60 Subparts J and Ja) and issued National 

Emission Standards for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming 

Units, and Sulfur Recovery Units on April 11, 2002 (amended February 9, 2005) (40 CFR 63 

Subpart UUU). These revised air regulations may be another reason why petroleum refinery 

discharges are showing higher levels of metals. EPA needs to study this further. 

As part of the 2011 and 2012 Petroleum Refining Annual Reviews, EPA (U.S. EPA, 

2012, 2014) found that: 

 The catalytic reforming process may form dioxin and dioxin-like compounds. 

 Discharges of metal pollutants are increasing. 

As shown in Table 5-73, the number of facilities reporting non-zero metals TWPE 

increased and the DMR metals discharges doubled from 2000 to 2009. 

Table 5-73. Petroleum Refining Metals DMR Discharges 

Year of Discharge 

Number of Facilities 

Reporting Metalsa 

Number of Facilities Reporting 

Non-Zero TWPEa Total Metal TWPE 

2000 104 77 30,100 

2009 253 117 66,300 

Sources: 2011 Annual Review Report, Tables 19-12 and 19-13 (U.S. EPA, 2012). 

a Includes all facilities reporting metals discharges. 

5-77
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.9—Petroleum Refining (40 CFR Part 419) 

In addition to the refinery-specific findings, EPA has been collecting data on new 

treatment technologies to evaluate if new technologies demonstrate better performance than 

technologies used as the basis for existing ELGs from 1982. 

In summary, EPA plans to conduct the study of this industry to determine if changes to 

the existing ELGs are needed because: 

 Recent changes to the industry may have resulted in new wastestreams or 

wastewater characteristics. 

 EPA has observed an increase in metals discharges. 

 EPA has observed an increase in the number of refineries reporting metals 

discharges. 

 Only one metal (chromium) was included in the current Petroleum Refining 

ELGs. 

As part of the preliminary study, EPA plans to: 

	 Collect updated industry profile information to identify refineries that: 

—	 Use catalytic reforming; 

—	 Process heavy crude; and 

—	 Installed new air pollution control equipment that generates wastewater. 

	 Continue to analyze trends in DMR and TRI data to identify pollutants of interest. 

	 Review data from other EPA and government programs, or industry sources (e.g., 

Office of Air and Radiation, Department of Energy’s Energy Information 

Administration, Oil and Gas Journal). 

	 Review information on new treatment technologies to determine if they can 

remove pollutants in petroleum wastewater to a better degree than the technology 

upon which the current ELG was based. 

EPA will use the study to identify: 

	 Additional data needs for this industry, including information on its economics 

and potential environmental impacts of current discharges. 

	 Pollutants in petroleum refining wastewater that may not be included in permits 

and may warrant further study. 

	 Treatment technologies that more effectively remove pollutants from petroleum 

wastewater. 

Pending the preliminary study’s findings, EPA may collect additional data through permit and 

permit application reviews, site visits, or other methods. 

5-78
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.9—Petroleum Refining (40 CFR Part 419) 

5.9.1	 References for Petroleum Refining Category 

1.	 U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program 

Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346 

through 1352. 

2.	 U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

3.	 U.S. EPA. 2014. The 2012 Annual Effluent Guidelines Review Report. Washington, D.C. 

(September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824. DCN 07756. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.10—Pulp, Paper, and Paperboard (40 CFR Part 430) 

5.10 Pulp, Paper, and Paperboard (40 CFR Part 430) 

EPA identified the Pulp, Paper, and Paperboard (Pulp and Paper) Category (40 CFR Part 

430) for preliminary review because it continues to rank high, in terms of toxic-weighted pound 

equivalents (TWPE), in point source category rankings. EPA previously reviewed discharges 

from pulp and paper facilities as part of the Preliminary and Final Effluent Guidelines Program 

Plans in 2004–2011 (U.S. EPA, 2004a, 2006a, 2007, 2008, 2009a, 2011, 2012). During its 2006 

Final Effluent Guidelines Program Plan reviews, EPA also conducted a detailed study of this 

industry (U.S. EPA, 2006b). This section summarizes the results of the 2013 Annual Review 

associated with the Pulp and Paper Category. 

The estimated toxicity of the Pulp and Paper Category discharges resulted from discharge 

monitoring report (DMR)–reported discharges of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) 

and sulfide, and Toxics Release Inventory (TRI)–reported discharges of dioxin and dioxin-like 

compounds and manganese and manganese compounds. Sulfide, dioxin and dioxin-like 

compounds, and manganese and manganese-like compounds, reviewed as part of the 2011 

Annual Review, continue to be top pollutants of concern. For the 2013 Annual Review, 2011 

DMR data also showed significant contributions of TCDD to the Pulp and Paper Category 

TWPE. 

5.10.1 Pulp and Paper Category 2013 Toxicity Rankings Analysis 

Table 5-74 compares the toxicity rankings analysis (TRA) results for the Pulp and Paper 

Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in 2012, but 

instead reviewed additional data sources as part of the even-year annual review as discussed in 

the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plan (U.S. EPA, 2014a). As 

discussed in this section, EPA’s review of the Pulp and Paper Category identified a data error 

that affected the 2011 DMR data and TWPE. The bottom row of Table 5-74 shows the corrected 

data resulting from this review. 

Table 5-74. Pulp and Paper Category TRI and DMR Facility Counts and Discharges for 

2011 and 2013 Annual Reviews 

Year of 

Discharge 

Year of 

Review 

Pulp and Paper Category Facility Counts Pulp and Paper Category TWPE 

Total of TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilitiesa TRI TWPEb 

DMR 

TWPEc Total 

2009d 2011 250 137 20 1,080,000 260,000 1,340,000 

2011 2013 219 130 24 651,000 1,020,000 1,670,000 

2011e 2013 651,000 576,000 1,230,000 

Sources: 2011 Annual Review Report (for 2009d DMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_v1
 

(for 2011 DMR); TRILTOutput2011_v1 (for 2011 TRI).
 

Note: EPA did not evaluate DMR data for 2010.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
 b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
 

POTW removals.
 c DMR discharges from both minor and major facilities.
 d 2009 data after corrections made during the 2011 Annual Review.
 e 2011 data after corrections made during the 2013 Annual Review.
 

5-80
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.10—Pulp, Paper, and Paperboard (40 CFR Part 430) 

As shown in Table 5-74, the number of facilities in TRI and the number of major DMR 

facilities decreased from 2009 to 2011, while the number of minor DMR facilities increased. 

During that period, the TRI TWPE has decreased, while the DMR TWPE has increased. 

5.10.2 Pulp and Paper Category Pollutants of Concern 

For its 2013 Annual Review, EPA’s review of the Pulp and Paper Category focused on 

the 2011 TRI and DMR discharges because both contribute to the category’s combined TWPE. 

Table 5-75 compares the five pollutants with the highest contribution to the 2011 DMR TWPE. 

For comparison, it also shows the 2009 DMR TWPE for these top five pollutants based on the 

results of (and corrections identified in) the 2011 Annual Review (U.S. EPA, 2012). Table 5-75 

also presents the 2011 DMR TWPE after EPA corrected an error identified in this preliminary 

category review (discussed in the sections below). TCDD and sulfide contribute more than 85 

percent of the total 2011 DMR TWPE. EPA’s investigations of the top two DMR pollutants are 

presented in Sections 5.10.3 and 5.10.4. EPA did not investigate the other top DMR pollutants as 

part of the 2013 Annual Review, including 2,3,7,8-tetrachlorodibenzofuran, aluminum, and 

mercury because they represent less than 11 percent of the total DMR TWPE for the Pulp and 

Paper Category. 

Table 5-75 compares the five pollutants with the highest contribution to the 2011 TRI 

TWPE. In addition, as a point of comparison, Table 5-3 shows the 2009 TRI TWPE for these 

top five pollutants based on the results of (and corrections identified in) the 2011 Annual Review 

(U.S. EPA, 2012). Manganese and manganese compounds and dioxin and dioxin-like 

compounds contribute more than 77 percent of the total 2011 TRI TWPE. EPA’s investigations 

of the top two TRI pollutants are presented in Sections 5.10.3 and 5.10.5. EPA did not 

investigate the other top TRI pollutants as part of the 2013 Annual Review, including mercury, 

lead, and polycyclic aromatic compounds (PACs) for TRI, because they represent less than 18 

percent of the total TRI TWPE for the Pulp and Paper Category. 

Table 5-75. Pulp and Paper Category Top DMR Pollutants 

Pollutant 

2011 DMR Dataa 2009 DMR Dataa 

Number of Facilities 

Reporting Pollutant 

Original 

TWPE 

Corrected 

TWPE TWPE 

TCDD 6 626,000 183,000 26,100 

Sulfide 2 241,000 241,000 147,000 

2,3,7,8-tetrachlorodibenzofuran 5 67,600 67,600b 1,260 

Aluminum 30 26,900 26,900b 36,100 

Mercury 25 20,300 20,300b 10,100 

Top Pollutant Total NA 982,000 539,000 221,000 

Pulp and Paper Category Total 147c 1,020,000 576,000 260,000 

Sources: DMRLTOutput2011_v1 (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE) 

(U.S. EPA, 2012).
 

NA: Not applicable.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a DMR data include major and minor dischargers.
 b 2,3,7,8-tetrachlorodibenzofuran, aluminum, and mercury discharges combined contribute less than 11 percent of
 

the 2011 category TWPE. Therefore, EPA did not review these discharges as part of the 2013 Annual Review.
 c Number of facilities reporting TWPE greater than zero.
 

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5.10—Pulp, Paper, and Paperboard (40 CFR Part 430) 

Table 5-76. Pulp and Paper Category Top TRI Pollutants 

Pollutant 

2011 TRI Data 2009 TRI Data 

Number of Facilities 

Reporting Pollutant 

Original 

TWPE 

Corrected 

TWPEa TWPE 

Manganese and manganese compounds 104 266,000 266,000 298,000 

Dioxin and dioxin-like compounds 38 238,000 238,000 613,000 

Mercury and mercury compounds 81 52,700 52,700b 16,300 

Lead and lead compounds 157 48,000 48,000b 61,100 

PACs 21 14,000 14,000b 15,900 

Top Pollutant Total NA 619,000 619,000 1,000,000 

Pulp and Paper Category Total 221c 651,000 651,000 1,080,000 

Sources: TRILTOutput2011_v1 (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 TRI TWPE) 

(U.S. EPA, 2012).
 

NA: Not applicable.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a EPA reviewed the 2011 TRI manganese and manganese compound and dioxin and dioxin-like compound
 

discharges but determined that no data corrections were needed. Therefore, the corrected TWPE for these pollutants
 

matches the original TWPE.

b Mercury, lead, and PAC discharges combined contribute less than 18 percent of the 2011 category TWPE.
 

Therefore, EPA did not review these discharges as part of the 2013 Annual Review.
 c Number of facilities reporting TWPE greater than zero.
 

5.10.3 Pulp and Paper Category Dioxin Discharges in DMR and TRI 

EPA reviewed 2011 DMR and TRI data on dioxin and dioxin-like compounds from pulp 

and paper mills for the 2013 Annual Review. EPA’s investigation of the 2011 DMR dioxin data 

revealed that one facility, Rayonier Performance Fibers (Rayonier), in Jesup, GA, accounts for 

71 percent of the 2011 DMR TCDD18 discharges (shown in Table 5-77). EPA did not investigate 

the remaining facilities discharging TCDD. 

Table 5-77. Top 2011 DMR TCDD Discharging Facilities 

Facility Name Facility Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Rayonier Performance Fibers Jesup, GA 0.000629 443,000 71% 

Remaining Facilities Reporting TCDD Dischargesa 0.00026 183,000 29% 

Total 0.000889 626,000 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are five remaining facilities that have TCDD discharges in the 2011 DMR data.
 

EPA’s investigation of the 2011 TRI dioxin and dioxin-like compounds discharges 

revealed that four facilities account for 74 percent of the dioxin and dioxin-like compound 

18 TCDD is a dioxin compound. Facilities can submit DMR data for individual dioxin compounds. In TRI, facilities 

report dioxin compounds as the group of dioxin and dioxin-like compounds. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.10—Pulp, Paper, and Paperboard (40 CFR Part 430) 

discharges (shown in Table 5-78). EPA did not investigate the remaining facilities discharging 

dioxin and dioxin-like compounds. 

Table 5-78. Top 2011 TRI Dioxin and Dioxin-Like Compound Discharging Facilities 

Facility Name Facility Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Kimberly-Clark Worldwide Everett, WA 0.00101 67,700 28% 

SD Warren Co. Skowhegan, ME 0.000366 42,200 18% 

Rayonier Performance Fibers LLC Fernandina Beach, FL 0.0162 38,900 16% 

Simpson Tacoma Kraft Co. LLC Tacoma, WA 0.00174 27,100 11% 

Remaining Facilities Reporting Dioxin and Dioxin-Like 

Compound Dischargesa 0.0766 61,800 26% 

Total 0.0959 238,000 100% 

Source: TRILTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 34 remaining facilities that have dioxin and dioxin-like compound discharges in the 2011 TRI data.
 

Rayonier Performance Fibers, Jesup, GA 

Rayonier in Jesup, GA, is the top 2011 DMR TCDD discharger. The facility discharges 

TCDD from outfall 0A0. As part of the 2013 Annual Review, EPA contacted Rayonier about the 

facility’s TCDD discharges. Rayonier stated that the TCDD discharges were measured at levels 

below the detection limit (BDL). Rayonier confirmed that the BDL indicators for the TCDD 

discharges were not properly marked on the 2011 DMR (Mooney, 2014). As described in 

Section 3.2.2.2 in EPA’s 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), EPA zeros the load when all concentrations of a specific pollutant are 

BDL for all monitoring periods (U.S. EPA, 2009b). Therefore, EPA zeroed Rayonier’s 

discharges, which decreases the 2011 DMR TCDD TWPE for the Pulp and Paper category from 

626,000 to 183,000, as shown in Table 5-75. 

Kimberly-Clark 

EPA reviewed the TRI dioxin and dioxin-like compound discharges from KimberlyClark in Everett, WA, as part of the 2011 and 2012 Annual Reviews. EPA determined that the 

mill calculated its dioxin and dioxin-like compound releases using mass balances using historical 

congener data, not actual discharge measurements. In addition, this mill shut down in April 2012 

(U.S. EPA, 2012, 2014b). For these reasons, Kimberly-Clark’s dioxin and dioxin-like compound 

discharges do not represent discharges across the Pulp and Paper Category. 

SD Warren Co. 

As part of the 2011 and 2012 Annual Reviews, EPA reviewed the TRI dioxin and dioxinlike compound discharges from SD Warren Co. From these earlier reviews, EPA determined that 

the mill calculated its dioxin and dioxin-like compound releases using May 2002 final effluent 

sampling data, corrected for the annual flow and the naturally occurring congeners contained in 

the mill’s receiving water, pulp wood, and kaolin clay (U.S. EPA, 2012). In 2009, EPA also 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.10—Pulp, Paper, and Paperboard (40 CFR Part 430) 

determined that the mill’s dioxin and dioxin-like compound discharges, measured in May 2002, 

were less than EPA’s Method 1613 Minimum Levels (MLs) (U.S. EPA, 2014b). EPA previously 

concluded that concentrations below the MLs may not be accurate, and the measurements may 

not accurately reflect industry discharges. 

During the 2013 Annual Review, to verify SD Warren Co.’s reported 2011 TRI dioxin 

and dioxin-like compound discharges, EPA contacted the American Forest and Paper 

Association (AF&PA) and NCASI. AF&PA is the national trade association of the forest, pulp, 

paper, paperboard, and wood products industry. NCASI is a nonprofit research institute funded 

by North American forest products industry, including pulp and paper facilities. AF&PA 

confirmed with the mill that the 2011 dioxin and dioxin-like compound discharges reported to 

TRI were correct and stated that the mill continues to follow the same TRI calculation 

methodology discussed in the 2011 and 2012 Annual Review Reports (Schwartz, 2013). EPA 

observed that the mill’s reported TRI dioxin and dioxin-like compound TWPEs were similar in 

magnitude in 2011 (42,200) and 2009 (37,900). For these reasons, EPA concluded that SD 

Warren Co.’s dioxin and dioxin-like compound discharges are not a hazard priority at this time. 

Rayonier Performance Fibers, Fernandina Beach, FL 

EPA reviewed TRI dioxin and dioxin-like compound discharges from Rayonier 

Performance Fibers (Rayonier) in Fernandina Beach, FL, as part of the 2011 and 2012 Annual 

Reviews. From these earlier reviews, EPA confirmed that the mill bases its reported dioxin and 

dioxin-like compound discharges on quarterly measurements (U.S. EPA, 2012). Rayonier 

reported that they detected seven dioxin congeners19 in their effluent wastewater in 2009. Two of 

these congeners, 1,2,3,4,6,7,8,9-OCDD and 2,3,7,8-TCDF, were detected above EPA’s Method 

1613 MLs; however, in its 2012 Annual Review, EPA concluded that the concentrations are low 

and that the discharges do not warrant further review (U.S. EPA, 2014b). 

Rayonier reported to TRI that it released five dioxin congeners in its wastewater 

discharges in 2011.20 As part of the 2013 Annual Review, EPA contacted AF&PA and NCASI 

about the mill’s 2011 dioxin and dioxin-like compound discharges. NCASI confirmed with the 

mill that the 2011 dioxin and dioxin-like compound discharges reported to TRI were correct and 

stated that the same calculation methodology is used (Schwartz, 2013). As in the 2009 data, in 

2011 Rayonier reported detecting two congeners,1,2,3,4,6,7,8,9-OCDD and 2,3,7,8-TCDF, 

above EPA’s Method 1613 MLs. Further, the 2011 TWPE (38,900) is similar in magnitude to the 

2009 TWPE (37,800). Therefore, EPA concluded that the dioxin and dioxin-like compound 

discharges from Rayonier are not a hazard priority at this time. 

Simpson Tacoma Kraft Co. LLC 

EPA reviewed TRI dioxin and dioxin-like compound discharges from Simpson Tacoma 

Kraft Co, LLC (Simpson Tacoma), in Tacoma, WA, as part of the 2011 and 2012 Annual 

Reviews. These earlier reviews demonstrated that Simpson Tacoma based its reported dioxin and 

19 Rayonier detected concentrations of 1,2,3,7,8,9-HxCDD; 1,2,3,4,6,7,8-HpCDD; 1,2,3,4,6,7,8,9-OCDD; 2,3,7,8­

TCDF; 2,3,4,7,8-PeCDF; 1,2,3,4,6,7,8-HpCDF; and 1,2,3,4,6,7,8,9-OCDF in 2009. See Section 5.3.2 in the 2012 

Annual Review Report (U.S.EPA, 2014b).

20 Rayonier detected concentrations of 1,2,3,4,6,7,8-HpCDD; 1,2,3,4,6,7,8,9-OCDD; 2,3,7,8-TCDF; 1,2,3,4,6,7,8­

HpCDF; and 1,2,3,4,6,7,8,9-OCDF in 2011. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.10—Pulp, Paper, and Paperboard (40 CFR Part 430) 

dioxin-like compound releases on full congener testing sampled annually and detected dioxin 

congeners in the effluent wastewater are below EPA’s Method 1613B ML (U.S. EPA, 2012, 

2014b). 

As part of the 2013 Annual Review, EPA contacted AF&PA and NCASI about the mill’s 

2011 dioxin and dioxin-like compound discharges. AF&PA confirmed with the mill that the 

2011 dioxin and dioxin-like compound discharges reported to TRI were correct and provided 

results of Simpson Tacoma’s analysis of 2011 and 2012 wastewater discharges (Schwartz, 2013). 

Table 5-79 presents the results of the 2011 and 2012 analyses provided by the mill. As shown, all 

measured concentrations are below EPA’s Method 1613B MLs. Therefore, EPA concludes that 

the dioxin and dioxin-like compound discharges from Simpson Tacoma do not warrant further 

review at this time. 

Table 5-79. 2011 and 2012 Concentrations of Dioxin and Dioxin-Like Compounds from
 

Simpson Tacoma (pg/L) and EPA Method 1613B Minimum Levels
 

Congener 1613B ML (pg/L) 

2011 Average 

Concentration (pg/L) 

2012 Average 

Concentration (pg/L) 

Polychlorinated dibenzo p furans (CDFs) 

2,3,7,8-TCDF 10 0.385 0a 

1,2,3,7,8-PeCDF 50 0.454 0.35 

2,3,4,7,8-PeCDF 50 0.5 0a 

1,2,3,4,7,8-HxCDF 50 0a 0.42 

1,2,3,6,7,8-HxCDF 50 0.347 0.42 

2,3,4,6,7,8-HxCDF 50 0.351 0a 

1,2,3,7,8,9-HxCDF 50 0a 0a 

1,2,3,4,6,7,8-HpCDF 50 0.92 1.01 

1,2,3,4,7,8,9-HpCDF 50 0a 0a 

1,2,3,4,6,7,8,9-OCDF 100 1.05 1.01 

Polychlorinated dibenzo p dioxins (CDDs) 

2,3,7,8-TCDD 10 0a 0a 

1,2,3,7,8-PeCDD 50 0.258 0.4 

1,2,3,4,7,8-HxCDD 50 0a 0a 

1,2,3,6,7,8-HxCDD 50 0.418 0.92 

1,2,3,7,8,9-HxCDD 50 0.175 0a 

1,2,3,4,6,7,8-HpCDD 50 4.01 14.0 

1,2,3,4,6,7,8,9-OCDD 100 23.7 39.8 

Source: Schwartz, 2013.
 

ML: Minimum level established for EPA Method 1613B (U.S. EPA, 2004b).
 a Simpson Tacoma did not include reporting limits for any congeners but stated that all zero values were BDL
 

(Schwartz, 2013).
 

5.10.4 Pulp and Paper Category Sulfide Discharges in DMR 

EPA’s investigation of the sulfide discharge revealed that one facility, Smurfit-Stone 

Container (Smurfit-Stone), in Florence, SC, accounts for 97 percent of the 2011 DMR sulfide 

discharges (shown in Table 5-80). Because the Smurfit-Stone mill dominated the reported 

discharges, EPA did not investigate the remaining facility discharging sulfide. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.10—Pulp, Paper, and Paperboard (40 CFR Part 430) 

Table 5-80. Top 2011 DMR Sulfide Discharging Facilities 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Smurfit-Stone Container Florence, SC 83,500 234,000 97% 

Domtar – Johnsonburg Mill Johnsonburg, PA 2,590 7,250 3% 

Total 86,100 241,000 100% 

Source: DMRLTOutput2011_v1.
 

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

Smurfit-Stone discharges sulfide from outfall 001. EPA reviewed the mill’s sulfide 

discharges as part of the 2011 Annual Review and contacted AF&PA about the sulfide 

discharges. The mill’s permit includes monitoring and reporting requirements for sulfide, but 

there are no numeric sulfide discharge limits. The Pulp and Paper Category effluent limitations 

guidelines and standards do not regulate sulfide (U.S. EPA, 2012). 

The mill’s kraft pulping process uses sodium-based alkaline pulping solution (liquor) 

which consists of sodium sulfide and sodium hydroxide in 10 percent solution. This is the 

primary source of sulfides in the wastewater. Smurfit-Stone’s permit states that sulfide 

discharges from the facility have a reasonable potential to exceed water quality criteria for 

aquatic life; therefore, monitoring and reporting requirements for sulfide were added to the 

permit (SCDHEC, 2006). EPA determined in the 2011 Annual Review that the mill’s sulfide 

concentrations range from <0.38 to 4 milligrams per liter and are below or near treatable levels. 

Therefore, the mill’s sulfide discharges did not warrant further review (U.S. EPA, 2012). 

As part of the 2013 Annual Review, EPA contacted AF&PA about Smurfit-Stone’s 2011 

DMR sulfide discharges. AF&PA confirmed with the mill that these discharges were correct and 

stated that sulfide measurements for January and February 2011 appear to be anomalies, which 

skew the average sulfide concentration for 2011. The mill reviewed its DMR sulfide data from 

2009 to 2013, determining that the January and February 2011 concentrations are anomalies and 

that the sulfide concentrations in the effluent are decreasing. Figure 5-1 presents the downward 

trend of sulfide concentrations for years 2009 to 2013.The mill contact also explained that no 

process changes have occurred that would affect the source of sulfide at the mill (Schwartz, 

2014a). For these reasons, EPA concluded that the sulfide discharges from Smurfit-Stone do not 

warrant further review at this time. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.10—Pulp, Paper, and Paperboard (40 CFR Part 430) 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

Concentration mg/L 

Date 

Source: Schwartz, 2014b.
 

Note: Non-detects are shown at half of non-detect value.
 

Figure 5-1. 2009–2013 Sulfide Concentrations for Smurfit-Stone Mill 

5.10.5 Pulp and Paper Category Manganese and Manganese Compound Discharges in TRI 

Manganese and manganese compound discharges account for 41 percent of the total 2011 

TRI TWPE. In 2011, 104 facilities reported discharges of manganese and manganese compounds 

to TRI; no facility accounts for more than 6 percent of the TWPE. EPA reviewed the TRI 

manganese and manganese compound discharges for the Pulp and Paper Category as part of the 

2011 Annual Review and confirmed its previous conclusions from the Pulp and Paper Detailed 

Study: manganese and manganese compound discharges in this category are below treatable 

levels (U.S. EPA, 2006b, 2012). 

Table 5-81 presents the manganese and manganese compound discharges in TRI and 

DMR from 2002 to 2011. As shown, 2011 manganese and manganese compound discharges are 

similar to those in previous years. Therefore, EPA continues to conclude that manganese and 

manganese compound discharges in the Pulp and Paper Category are below treatable levels. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.10—Pulp, Paper, and Paperboard (40 CFR Part 430) 

Table 5-81. 2002–2011 Manganese and Manganese Compound Discharges in TRI and
 

DMR
 

Discharge Year Review Year 

TRI Data DMR Data 

Number of 

Dischargers Total TWPE 

Number of 

Dischargers Total TWPE 

2002 2006 112 304,000 4 287 

2004 2007 117 316,000 5 5,190 

2007 2009 79 231,000 5 3,210 

2008 2010 117 308,000 3 3,040 

2009 2011 115 298,000 3 2,960 

2011 2013 104 266,000 5 522 

Sources: TRIReleases2002; PCSLoads2002; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2007_v2; 

DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3; TRIReleases2009_v2; DMRLoads2009_v2; 

DMRLTOutput2011_v1; TRILTOutput2011_v1. 

5.10.6 Pulp and Paper Category Findings 

The estimated toxicity of the Pulp and Paper Category discharges resulted from DMRreported discharges of dioxin (TCDD) and sulfide, and TRI-reported discharges of dioxin and 

dioxin-like compounds and manganese and manganese compounds. In the 2013 Annual Review, 

EPA has identified the following: 

	 One facility, Rayonier Performance Fibers in Jesup, GA, accounts for 71 percent 

of the category’s DMR TCDD discharges. The facility contact confirmed that 

BDL indicators were not properly marked on the DMR. Because all TCDD 

discharges were non-detect, EPA zeroed the TCDD load and TWPE for Rayonier, 

which decreased the 2011 TCDD Pulp and Paper Category TWPE from 626,000 

to 183,000. 

	 Four facilities account for 74 percent of the category’s TRI dioxin and dioxin-like 

compound discharges. EPA previously reviewed these facilities as part of the 

2011 and 2012 Annual Reviews. One of them, Kimberly-Clark in Everett, WA, 

shut down in 2012. For the other three facilities, EPA determined that 2011 dioxin 

and dioxin-like compound discharges are either below or near EPA Method 1613 

MLs and are similar to 2009 dioxin and dioxin-like compound discharges. 

Accordingly, dioxin and dioxin-like compound discharges do not warrant further 

review at this time. 

	 One facility, Smurfit-Stone in Florence, SC, accounts for 97 percent of the 

category’s DMR sulfide discharges. EPA determined that the January and 

February 2011 sulfide concentrations for Smurfit-Stone were anomalies and 

skewed the 2011 total sulfide discharge. The sulfide concentrations have since 

decreased over time. Therefore, further review of the facility’s sulfide discharges 

is not warranted at this time. 

	 In 2011, 104 facilities reported discharges of manganese and manganese 

compounds to TRI. No facility accounts for more than 6 percent of the TWPE. 

EPA’s 2011 Annual Review and 2006 Detailed Study determined that manganese 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.10—Pulp, Paper, and Paperboard (40 CFR Part 430) 

and manganese compound concentrations in pulp and paper mill discharges were 

below treatable levels, which is still true for the 2013 Annual Review. 

	 EPA corrected errors for discharges reported by one mill. This decreases the 2011 

Pulp and Paper Category TWPE from 1,670,000 to 1,230,000. EPA reviewed 

discharges reported by five other mills, but made no corrections. For these mills, 

EPA either determined that discharges were anomalies for the 2011 reporting year 

or are below method MLs or treatable levels and a category-wide discharge issue, 

warranting an effluent guidelines revision, is not apparent. 

5.10.7 References for Pulp and Paper Category 

1.	 ERG. 2014. Preliminary Category Review – Facility Data Review and Revised 

Calculations for Point Source Category 430 – Pulp and Paper. (March). EPA-HQ-OW2014-0170. DCN 07932. 

2.	 Mooney, Brian. 2014. Telephone and Email Communication Between Brian Mooney, 

Rayonier Performance Fibers, Jesup Mill, and Kimberly Bartell, Eastern Research Group, 

Inc., Re: 2011 DMR Clarification for TCDD Discharges. (January). EPA-HQ-OW-2014­

0170. DCN 07927. 

3.	 SCDHEC. 2006. South Carolina Department of Health and Environmental Control. 

NPDES Permit: Smurfit-Stone Container Enterprises, Inc., Florence, SC. (August 29). 

EPA-HQ-OW-2014-0170. DCN 07928. 

4.	 Schwartz, Jerry, and Paul Wiegand. 2013.Telephone and Email Communication Between 

Jerry Schwartz, American Forest and Paper Association, Paul Wiegand, National Council 

for Air and Stream Improvement, and Kimberly Bartell, Eastern Research Group, Inc., 

Re: 2011 TRI Pulp and Paper Dioxin Dischargers. (March). EPA-HQ-OW-2014-0170. 

DCN 07929. 

5.	 Schwartz, Jerry. 2014a. Email Communication Between Jerry Schwartz, American Forest 

and Paper Association, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 

DMR Sulfide Discharges. (February). EPA-HQ-OW-2014-0170. DCN 07930. 

6.	 Schwartz, Jerry. 2014b. Sulfide Data Chart for Smurfit-Stone Enterprises, Florence, SC – 

SC000876 from Jerry Schwartz, American Forest and Paper Association. (January). 

EPA-HQ-OW-2014-0170. DCN 07931. 

7.	 U.S. EPA. 2004a. Technical Support Document for the 2004 Effluent Guidelines 

Program Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003­

0074-1346 through 1352. 

8.	 U.S. EPA. 2004b. Method 1613B: Tetra- Through Octa-Chlorinated Dioxins and Furans 

by Isotope Dilution HRGC/HRMS. Washington, D.C. (October). EPA-HQ-OW-2004­

0032-2653. 

9.	 U.S. EPA. 2006a. Technical Support Document for the 2006 Effluent Guidelines 

Program Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004­

0032-2782. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.10—Pulp, Paper, and Paperboard (40 CFR Part 430) 

10.	 U.S. EPA. 2006b. Final Report: Pulp, Paper, and Paperboard Detailed Study. 

Washington, D.C. (December). EPA-821-R-06-016. EPA-HQ-OW-2004-0032-2249. 

11.	 U.S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent 

Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQOW-2006-0771-0819. 

12.	 U.S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program 

Plan. Washington, D.C. (August). EPA-821-R-08-015. EPA-HQ-OW-2006-0771-1701. 

13.	 U.S. EPA. 2009a. Technical Support Document for the Preliminary 2010 Effluent 

Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQOW-2008-0517-0515. 

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

Effluent Guidelines and Identification of Potential New Point Source Categories. EPA821-R-09-007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515. 

15.	 U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program 

Plan. Washington, D.C. (October). EPA 820-R-10-021. EPA-HQ-OW-2008-0517. DCN 

07320. 

16.	 U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

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

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

07756. 

18.	 U.S. EPA. 2014b. The 2012 Annual Effluent Guidelines Review Report. Washington, 

D.C. (September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824. DCN 07933. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.11—Timber Products Processing (40 CFR Part 429) 

5.11 Timber Products Processing (40 CFR Part 429) 

EPA selected the Timber Products Processing (Timber Products) Category for 

preliminary review because it ranks high, in terms of toxic-weighted pound equivalents (TWPE), 

in the point source category rankings. EPA reviewed discharges from the Timber Products 

Category as part of the 2004 and 2011 Annual Reviews (U.S. EPA, 2004, 2012). This section 

summarizes the results of the 2013 Annual Review associated with the Timber Products 

Category. EPA focused on discharges of chlorine, copper, and arsenic from discharge monitoring 

reports (DMR) because of their high TWPE relative to the other pollutants in the Timber 

Products Category. Copper, reviewed as part of the 2011 Annual Review, continues to be a top 

pollutant of concern. For the 2013 Annual Review, available discharge data also showed 

significant contributions of chlorine and arsenic to the Timber Products Category TWPE. 

5.11.1 Timber Products Category 2013 Toxicity Rankings Analysis 

Table 5-82 compares the toxicity rankings analysis (TRA) results for the Timber Products 

Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in 2012, but 

instead reviewed additional data sources as part of the even-year annual review as discussed in 

the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014). As 

discussed in this section, EPA’s review of the Timber Products Category identified several data 

errors that affected the 2011 DMR data and TWPE. The bottom row of Table 5-82 shows the 

corrected data resulting from this review. 

Table 5-82. Timber Products Category TRI and DMR Facility Counts and Discharges 

for the 2011 and 2013 Annual Reviews 

Year of 

Discharge 

Year of 

Review 

Timber Category Facility Counts Timber Category TWPE 

Total TRI 

Facilities 

Total DMR 

Major 

Facilities 

Total DMR 

Minor 

Facilitiesa 

TRI 

TWPEb 

DMR 

TWPEc 

Total 

TWPE 

2009d 2011 101 1 54 22,700 11,800 34,500 

2011 2013 

102 2 80 32,300 99,600 132,000 

2011e 2013 32,300 72,800 105,000 

Sources: 2011 Annual Review Report (for 2009d DMR and Toxics Release Inventory (TRI) TWPE) (U.S. EPA,
 

2012); DMRLTOutput2011_v1 (for 2011 DMR); TRILTOutput2011_v1 (for 2011 TRI).
 

Note: EPA did not evaluate DMR data for 2010.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
 b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
 

POTW removals.
 c DMR discharges from both minor and major facilities.
 d 2009 data after corrections made during the 2011 Annual Review.
 e 2011 data after corrections made during the 2013 Annual Review.
 

As shown in Table 5-82, the total TWPE (incorporating data corrections) increased from 

2009 to 2011. During that period, the number of TRI and major and minor DMR facilities 

increased. 

5-91
 
Section 5—EPA’s 2013 Preliminary Category Reviews 

5.11—Timber Products Processing (40 CFR Part 429) 

5.11.2 Timber Products Category Pollutants of Concern 

For its 2013 Annual Review, EPA’s review of the Timber Products Category focused on 

the 2011 DMR discharges because the 2011 DMR data dominate the category’s combined 

TWPE. Table 5-83 compares the five pollutants with the highest contribution to the 2011 DMR 

TWPE. It also presents the 2011 DMR TWPE after EPA corrected errors identified in this 

preliminary category review (discussed in the sections below). For comparison, it also shows the 

2009 DMR TWPE for these top five pollutants based on the results of (and corrections identified 

in) the 2011 Annual Review (U.S. EPA, 2012). 

Total residual chlorine, copper, and arsenic contribute more than 93 percent of the total 

2011 DMR TWPE. EPA’s investigations of reported discharges of the top three pollutants are 

presented in Sections 5.11.3 to 5.11.5. EPA did not investigate the other pollutants as part of the 

2013 Annual Review, including pentachlorophenol and iron, because they represent less than 7 

percent of the 2011 DMR TWPE for the Timber Products Category. 

Table 5-83. Timber Products Category Top DMR Pollutants 

Pollutant 

2011 DMR Dataa 2009 DMR Dataa 

Number of Facilities 

Reporting Pollutant 

Original 

TWPE 

Corrected 

TWPE TWPE 

Total residual chlorine 9 60,800 60,800 155 

Copper 39 16,500 2,150 300 

Arsenic 27 15,600 3,190 336 

Pentachlorophenol 10 2,190 2,190b 238 

Iron 9 1,100 1,100b 7,930 

Top Pollutant Total NA 96,200 69,400 8,960 

Timber Products Category Total 82c 99,600 72,800 11,800 

Sources: DMRLTOutput2011_v1 (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE) 

(U.S. EPA, 2012).
 

NA: Not applicable.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a DMR data include major and minor dischargers.
 b Pentachlorophenol and iron discharges combined contribute less than 3 percent of the 2011 category DMR TWPE.
 

Therefore, EPA did not review pentachlorophenol or iron discharges as part of the 2013 Annual Review.
 c Number of facilities reporting TWPE greater than zero.
 

5.11.3 Timber Products Category Total Residual Chlorine Discharges in DMR 

EPA’s investigation of the total residual chlorine discharges revealed that Cahaba Timber 

Co. (Cahaba Timber), in Brierfield, AL, accounts for greater than 99 percent of the 2011 DMR 

chlorine discharges (shown in Table 5-84). EPA did not investigate the remaining facilities 

discharging total residual chlorine. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.11—Timber Products Processing (40 CFR Part 429) 

Table 5-84. Top 2011 DMR Total Residual Chlorine Discharging Facilities 

Facility Name Facility Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Cahaba Timber Co. Brierfield, AL 121,000 60,600 >99% 

All Other Chlorine Dischargers in the Timber Products 

Categorya 274 137 <1% 

Total 122,000 60,800 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are eight remaining facilities that have total residual chlorine dischargers in the 2011 DMR data.
 

Cahaba Timber discharges total residual chlorine through five outfalls. The facility 

performs wood preserving operations, mainly for poles (e.g., telephone poles). As part of the 

2013 Annual Review, EPA contacted Cahaba Timber about its total residual chlorine discharges. 

The facility contact confirmed the 2011 discharges and explained that a permit change required 

the facility to start reporting total residual chlorine discharge data in its DMRs in 2011; the 

facility did not submit total residual chlorine DMR data before 2011 (Woodruff, 2013). Total 

residual chlorine is not a regulated pollutant in the Timber Products Category effluent limitations 

guidelines and standards. Additionally, the facility’s permit requires monitoring of total residual 

chlorine discharges from all outfalls, but does not include specific permit limitations for total 

residual chlorine (ADEM, 2011). 

The facility has no treatment processes in place for total residual chlorine. The facility 

contact explained that the facility uses three wood preservatives, one of which is 

pentachlorophenol. Minor chlorine discharges may be coming from contact stormwater due to 

the storage of poles treated with the pentachlorophenol preservative. All five outfalls are 

stormwater outfalls that co-mingle with discharges from the cooling tower and boiler blowdown. 

The facility contact stated that chlorine discharges may also be from the cooling tower/boiler 

blowdown discharges (Woodruff, 2013). 

Table 5-85 presents Cahaba Timber’s 2011 DMR total residual chlorine and flow 

discharge data. Because this facility is contributing more than 99 percent of the total 2011 DMR 

residual chlorine TWPE, EPA does not consider these discharges to be representative of the 

Timber Category. 

Table 5-85. Cahaba Timber’s 2011 DMR Total Residual Chlorine and
 

Flow Discharge Data
 

Outfall Monitoring Period Date Concentration (mg/L) Flow (MGD) 

001 30-Sep-2011 24.1 0.78 

001 31-Dec-2011 7.2 0.19 

002 30-Sep-2011 9.24 0.78 

002 31-Dec-2011 5.73 0.19 

003 30-Sep-2011 33 0.78 

003 31-Dec-2011 6.55 0.19 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.11—Timber Products Processing (40 CFR Part 429) 

Table 5-85. Cahaba Timber’s 2011 DMR Total Residual Chlorine and
 

Flow Discharge Data
 

Outfall Monitoring Period Date Concentration (mg/L) Flow (MGD) 

004 30-Sep-2011 18.4 0.78 

004 31-Dec-2011 7.19 0.19 

005 30-Sep-2011 8.89 0.78 

005 31-Dec-2011 3.8 0.19 

Source: DMRLTOutput2011_v1. 

5.11.4 Timber Products Category Copper Discharges in DMR 

EPA’s investigation of the copper discharges revealed that Ed Arey & Sons, Inc. (Ed 

Arey), in Buckhannon, WV, accounts for more than 87 percent of the 2011 DMR copper 

discharges (shown in Table 5-86). EPA did not investigate the remaining facilities discharging 

copper. 

Table 5-86. Top 2011 DMR Copper Discharging Facilities 

Facility Name Facility Location 

Pounds of Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Ed Arey & Sons Inc. Buckhannon, WV 22,800 14,300 87% 

All Other Copper Dischargers in the Timber Products 

Categorya 3,420 2,150 13% 

Total 26,200 16,500 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 38 remaining facilities that have copper dischargers in the 2011 DMR data.
 

Ed Arey discharges copper through three outfalls, 001, 002, and 003. Table 5-87 presents 

Ed Arey’s 2011 DMR copper concentration and flow discharge data. EPA previously reviewed 

copper discharges from Ed Arey as part of the 2011 Annual Review. During that review, EPA 

compared the 2009 DMR concentration and flow values to 2008 and 2009 flow values from 

Envirofacts and found that the 2009 DMR flow values were 1,000,000 times higher than the 

2008 flow values in Envirofacts. Therefore, EPA corrected the 2009 flow values. The 2011 flow 

data is also 1,000,000 times higher than the 2008 flow data values in Envirofacts; again, EPA 

corrected the 2011 values. Using the corrected flows, Ed Arey’s copper discharges decrease to 

0.0228 pounds and 0.0143 TWPE for 2011, reducing the facility’s total TWPE by over 99 

percent. This reduction in TWPE decreases the Timber Products Category’s 2011 DMR copper 

TWPE from 16,500 to 2,150, as shown in Table 5-83. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.11—Timber Products Processing (40 CFR Part 429) 

Table 5-87. Ed Arey’s 2011 DMR Copper and Flow Discharge Data 

Outfall 

Monitoring Period 

Date 

Maximum 

Concentration (mg/L) 

Original Flow 

(MGD) 

Corrected Flow 

(MGD) 

001 30-Apr-2011 0.017 235 0.000235 

001 31-Oct-2011 0.026 200 0.0002 

002 31-Oct-2011 0.0025 180 0.00018 

003 31-Oct-2011 0.015 160 0.00016 

Source: DMRLTOutput2011_v1. 

5.11.5 Timber Products Category Arsenic Discharges in DMR 

EPA’s investigation of the arsenic discharges revealed that Free State Lumber Inc., in 

Haleyville, AL, accounts for 80 percent of the 2011 DMR arsenic discharges (shown in Table 

5-88). EPA did not investigate the remaining facilities discharging arsenic as part of the 2013 

Annual Review. 

Table 5-88. Top 2011 DMR Arsenic Discharging Facilities 

Facility Name Facility Location 

Pounds of 

Pollutant 

Discharged 

Pollutant 

TWPE 

Facility Percent of 

Category TWPE 

Free State Lumber Co. Inc. Haleyville, AL 3,090 12,500 80% 

All other Arsenic Dischargers in the Timber Products 

Categorya 781 3,150 20% 

Total 3,870 15,600 100% 

Source: DMRLTOutput2011_v1.
 

Note: Sums of individual values may not equal the total presented, due to rounding.
 a There are 26 remaining facilities that have arsenic dischargers in the 2011 DMR data.
 

Free State Lumber discharges arsenic through two outfalls, 001 and 002. The arsenic 

concentrations for both outfalls are much higher in September and December 2011 than in March 

and June 2011. The facility permit requires monitoring for arsenic discharges from both outfalls; 

no permit limit is set (ADEM, 2009). As part of the 2013 Annual Review, EPA contacted Free 

State Lumber about its arsenic discharges. The facility contact stated that the September and 

December 2011 arsenic concentrations should be in units of micrograms per liter instead of 

milligrams per liter (Hubbard, 2013). Table 5-89 presents the original and corrected 

concentrations, along with average flow rates from the facility. Using the corrected 

concentrations, the facility’s arsenic TWPE decreases from 12,500 to 36.3, reducing the Timber 

Products Category’s arsenic TWPE from 15,600 to 3,190, as shown in Table 5-83. 

Table 5-89. Free State Lumber’s 2011 DMR Original and Corrected Arsenic Discharges 

Outfall Monitoring Period 

Average Flow 

(MGD) 

Original Average 

Arsenic Concentration 

(mg/L) 

Corrected Average 

Arsenic Concentration 

(mg/L) 

001 31-Mar-2011 0 0.005 0.005 

001 30-Jun-2011 0.46 0.005 0.005 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.11—Timber Products Processing (40 CFR Part 429) 

Table 5-89. Free State Lumber’s 2011 DMR Original and Corrected Arsenic Discharges 

Outfall Monitoring Period 

Average Flow 

(MGD) 

Original Average 

Arsenic Concentration 

(mg/L) 

Corrected Average 

Arsenic Concentration 

(mg/L) 

001 30-Sep-2011 0 1.72 0.00172 

001 31-Dec-2011 0.35 3.36 0.00336 

002 31-Mar-2011 0 0.005 0.005 

002 30-Jun-2011 1.1 0.005 0.005 

002 30-Sep-2011 0 1.9 0.0019 

002 31-Dec-2011 0.82 3.43 0.00343 

Sources: DMRLTOutput2011_v1; Hubbard, 2013. 

5.11.6 Timber Products Category Findings 

The estimated toxicity of the Timber Products Category discharges resulted from DMR 

total residual chlorine, copper, and arsenic discharges. From the 2013 Annual Review, EPA has 

identified the following: 

	 One facility, Cahaba Timber, contributes the majority of the total residual 

chlorine discharges to the 2011 DMR data. The facility only began reporting 

discharges of total residual chlorine in 2011 due to a permit change, but does not 

have a specific permit limit for total residual chlorine. As a result, the facility is 

contributing more than 99 percent of the total 2011 DMR total residual chlorine 

TWPE. Therefore, EPA does not consider these discharges to be representative of 

the Timber Products Category. 

	 One facility, Ed Arey & Sons, Inc., contributes 87 percent of the category’s 

copper DMR discharges. EPA identified errors in the flow values from the 

facility. With these errors corrected, the Timber Products Category’s 2011 copper 

DMR decreased from 16,500 to 2,150. 

	 One facility, Free State Lumber, contributes the majority of the arsenic discharges 

to the 2011 DMR data. EPA identified an error in the concentrations reported for 

the facility, which the facility contact corrected. This change decreases the 

facility’s arsenic TWPE from 12,500 to 36.4, reducing the Timber Products 

Category’s arsenic TWPE from 15,600 to 3,190. 

	 Correcting the errors mentioned above decreases the 2011 Timber Products 

Category TWPE from 132,000 to 105,000. For the remaining facility reviewed as 

part of the 2013 Annual Review, EPA determined that the discharges were not 

representative of the industry. 

5.11.7 References for Timber Products Category 

1.	 ADEM. 2009. Alabama Department of Environmental Management. NPDES Permit: 

Free State Lumber Company Inc., Haleyville, AL. (March 27). EPA-HQ-OW-2014-0170. 

DCN 07934. 

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Section 5—EPA’s 2013 Preliminary Category Reviews 

5.11—Timber Products Processing (40 CFR Part 429) 

2.	 ADEM. 2011. Alabama Department of Environmental Management. NPDES Permit: 

Cahaba Pressure Treated Forest Products Inc., Brierfield, AL. (June 2). EPA-HQ-OW2014-0170. DCN 07935. 

3.	 ERG. 2014. Preliminary Category Review – Facility Data Review and Revised 

Calculations for Point Source Category 429 – Timber Products Processing. (March). 

EPA-HQ-OW-2014-0170. DCN 07941. 

4.	 Hubbard, Tabitha. 2013. Telephone and Email Communication Between Tabitha 

Hubbard, Free State Lumber Co, Inc., William Swietlik, U.S. EPA, and Kimberly Bartell, 

Eastern Research Group, Inc. Re: 2011 DMR Clarification for Arsenic Discharges. 

(December 13). EPA-HQ-OW-2014-0170. DCN 07936. 

5.	 U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program 

Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346 

through 1352. 

6.	 U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

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

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

07756. 

8.	 Woodruff, Al, and Ken Layton. 2013. Telephone and Email Communication Between Al 

Woodruff, Cahaba Timber Co., Ken Layton, Layton Environmental Engineering LLC, 

and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 DMR Chlorine Discharges 

for Cahaba Timber Co. (December 13). EPA-HQ-OW-2014-0170. DCN 07937. 

5-97
 
PART III: RESULTS OF
 

EPA’S 2013 ANNUAL REVIEW
 

III
 
Section 6—Results of the 2013 Annual Review 

6.	 RESULTS OF THE 2013 ANNUAL REVIEW 

For the 2013 Annual Review, EPA evaluated the results of the toxicity rankings analysis 

(TRA) and the preliminary category reviews. Based on its TRA, EPA prioritized for further 

review 17 industrial categories whose pollutant discharges may pose the greatest hazards to 

human health or the environment because of their toxicity based on toxic-weighted pound 

equivalents (TWPE). 

During its review, EPA determined that seven of the 17 categories that cumulatively 

discharge 95 percent of the TWPE did not warrant a detailed preliminary category review. For 

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

found that the majority of the TWPE resulted from easily identifiable errors (e.g., incorrect 

reporting units) associated with one or two facilities. For TWPE not associated with data entry 

errors, EPA did not identify any new information to alter the conclusions made during previous 

annual reviews. These industrial categories include: 

 Concentrated Aquatic Animal Production (40 CFR Part 451);
 

 Meat and Poultry Products (40 CFR Part 432);
 

 Oil and Gas Extraction (40 CFR Part 435);
 

 Ore Mining and Dressing (40 CFR Part 440);
 

 Pesticide Chemicals (40 CFR Part 455);
 

 Fertilizer Manufacturing (40 CFR Part 418); and
 

 Sugar Processing (40 CFR Part 409).
 

For the remaining 10 of the 17 industrial categories that collectively discharge over 95 

percent of the total TWPE, EPA completed a detailed preliminary category reviews to evaluate 

whether the categories warrant further review. From these reviews, EPA identified only two 

categories that warrant further review: Metal Finishing (40 CFR 433) and Petroleum Refining 

(40 CFR 419). Below are the findings from EPA’s 2013 preliminary category reviews: 

	 Coal Mining (40 CFR Part 434). EPA identified and corrected data errors for 

2011 discharge monitoring report (DMR) discharges of iron, mercury, sulfate, and 

manganese (the top pollutants). Correcting these reporting errors removes the 

category from the top 95 percent in the point source category rankings. 

	 Drinking Water Treatment (potential new category). EPA reviewed total 

residual chlorine, aluminum, copper, mercury, and lead (the top pollutants) for the 

2013 Annual Review. EPA identified and corrected flow errors at four facilities 

accounting for the majority of the 2011 DMR total residual chorine and aluminum 

discharges. Further, EPA examined the findings from its 2011 review of the 

drinking water industrial, category which found that discharges from drinking 

water treatment plants are best addressed through National Pollutant Discharge 

Elimination System (NPDES) permits and that some pollutants are present in the 

wastewater from source water contributions or treatment chemicals. EPA 

compared the 2011 DMR top pollutants and concentrations to the findings from 

the 2011 review of the industrial category and determined that the same 

6-1
 
Section 6—Results of the 2013 Annual Review 

conclusions apply. Therefore, EPA did not identify this category for further 

review. 

	 Inorganic Chemicals Manufacturing (40 CFR Part 415). EPA reviewed dioxin 

and dioxin-like compounds, manganese and manganese compounds, and 

polychlorinated biphenyls (PCBs) (the top pollutants), which result from three 

titanium dioxide manufacturing plants, for the 2013 Annual Review. 

—	 One facility reported dioxin discharges that account for 98 percent of the 

2011 TRI dioxin category TWPE. EPA determined that the facility 

inadvertently reported 2011 dioxin and dioxin-like compound discharges 

using the minimum detection limit, when historically they have reported 

non-detect data as zero. Additionally, EPA determined that the 2011 

concentrations for all congeners are below EPA’s Method 1613B 

Minimum Level (ML). 

—	 One facility accounted for 39 percent of the 2011 TRI manganese category 

TWPE. EPA determined that the 2011 manganese and manganese 

compound TRI discharge for the facility is an anomaly due to an increase 

in flow at the facility during 2011, which is supported by a decrease in the 

discharge in 2012. 

—	 One facility accounted for 97 percent of the 2011 TRI PCB category 

TWPE. EPA determined that the facility’s 2011 PCB discharges were 

accurate and increased from previous years. Therefore, facility-specific 

permitting action may be appropriate to address PCB discharges from this 

facility. 

EPA has determined that further review of the Inorganic Category as a 

whole is not warranted at this time. 

	 Iron and Steel Manufacturing (40 CFR Part 420). EPA reviewed discharges of 

fluoride, aluminum, cyanide, and total residual chlorine (top pollutants) for the 

2013 Annual Review. EPA determined that: 

—	 Three facilities account for 73 percent of the 2011 DMR fluoride category 

TWPE. EPA identified and corrected a data error in one facility’s 2011 

DMR fluoride concentrations. EPA compared fluoride concentrations 

from all three facilities to concentrations achieved by current treatment 

technologies (although not specific to iron and steel manufacturing) and 

determined that all concentrations from two facilities were below treatable 

levels. EPA determined that fluoride concentrations from the third facility 

may exceed the concentration ranges achieved by current treatment 

technologies and that facility-specific permitting action may be 

appropriate to address fluoride discharges at this facility. 

—	 The majority (76 percent) of the 2011 DMR aluminum category TWPE 

was from one facility. EPA identified and corrected a data error for the 

facility’s aluminum concentration, which decreased the aluminum TWPE 

for the category. 

6-2
 
Section 6—Results of the 2013 Annual Review 

—	 Two facilities contribute the majority (60 percent) of the 2011 DMR 

cyanide category TWPE. For one facility, EPA determined that the 2011 

cyanide concentrations do not exceed permit limitations or the long-term 

average concentration calculated for the 2002 category rulemaking. EPA 

suspects that this facility’s TWPE is high due to the large amount of 

industrial activity at the facility, as it historically has been the top coke 

producer in the U.S. For the other facility, EPA found that several months 

of cyanide discharges from two different outfalls exceed the facility’s 

mass-based permit limits; therefore, facility-specific permitting action may 

be appropriate to address cyanide discharges at this facility. 

—	 One facility, historically the top coke producer in the U.S., accounts for 49 

percent of the 2011 DMR total residual chlorine discharges. EPA 

determined that the total residual chlorine concentrations for this plant are 

a result of the large amount of industrial activity at the facility and do not 

exceed permit limitations. 

EPA has determined that the data do not support the need to further review 

the Iron and Steel Category as a whole. 

	 Metal Finishing (40 CFR Part 433). During the 2012 Annual Review, EPA’s 

review of the Targeted National Sewage Sludge Survey, combined with available 

indirect discharge data from TRI, identified the Metal Finishing Point Source 

Category as potentially discharging high concentrations of metals, particularly 

chromium, nickel, and zinc, to publicly owned treatment works. Additionally, this 

category ranked high, in terms of TWPE, in the 2013 TRA. These findings 

indicate that further review of this category may be warranted. 

	 Nonferrous Metals Manufacturing (40 CFR Part 421). EPA reviewed 

discharges of cadmium, copper, mercury PCBs, and lead (the top pollutants) for 

the 2013 Annual Review. EPA determined that: 

—	 One facility accounts for 98 percent of the 2011 DMR cadmium category 

discharges. In 2012, the facility was issued a new permit to control 

cadmium discharges from its stormwater outfalls. EPA determined that 

further review of the facility’s discharges is not needed at this time. 

—	 One facility accounts for 88 percent of the 2011 DMR copper category 

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

facility’s copper concentrations, which decreased the copper TWPE for 

the category. 

—	 One facility contributes 99 percent of the 2011 DMR mercury category 

discharges. EPA previously reviewed these discharges as part of the 2010 

and 2011 Annual Reviews. EPA determined that the facility’s discharges 

result from former aluminum ore tailings lakes, not from current 

manufacturing. Because the facility no longer operates as an aluminum ore 

mine and processing facility and the discharges are similar to those in 

previous years, facility-specific permitting action may be appropriate to 

address this facility’s mercury discharges. 

6-3
 
Section 6—Results of the 2013 Annual Review 

—	 One facility accounts for 96 percent of the 2011 DMR PCB category 

discharges. EPA determined that this facility shut down its uranium 

enrichment process in 2013 and that cleanup efforts have been active at 

the site since the late 1980s. For these reasons, EPA is not performing 

further review of PCB discharges from this facility at this time. 

—	 Two facilities account for 93 percent of the 2011 DMR lead category 

discharges. One facility was issued a new permit in 2012, which contains 

new permit limitations for lead. The second facility is steadily reducing 

the concentrations of lead discharges by installing new contaminant 

technology and using better management practices. Therefore, EPA did 

not identify lead discharges for further review at this time. 

EPA has determined that the data do not support the need to further review 

the Nonferrous Metal Manufacturing Category as a whole. 

	 Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414). EPA 

reviewed discharges of hexachlorobenzene, total residual chlorine, and PCBs (the 

top pollutants) for the 2013 Annual Review. EPA identified that, for each of these 

pollutants, a majority of the discharges are attributed to a single facility whose 

reported discharges were in error. After correcting the data errors, EPA found that 

the TWPE has increased by 26.5 percent from 2009 to 2011. EPA expects that the 

high TWPE is a result of the increase in the number of minor facilities reporting 

discharges and the large number of facilities in the category. 

	 Petroleum Refining (40 CFR Part 419). During the 2011 Annual Review, EPA 

selected the Petroleum Refining Category (40 CFR Part 419) for a preliminary 

category review because it ranked high, in terms of TWPE (U.S. EPA, 2012). At 

that time, EPA found that the TWPE was largely due to TRI-reported discharges 

of dioxin and dioxin-like compounds, polycyclic aromatic compounds, and DMRreported discharges of sulfides, chlorine, and metals. EPA continued to review 

this category during the 2012 Annual Review to verify facilities’ discharges and 

confirmed the 2011 Annual Review results. EPA also reviewed new air pollution 

control regulations to identify whether the regulations could result in new 

wastewater streams. Additionally, this category ranked high, in terms of TWPE, 

in the 2013 TRA. These findings indicate that further study of this category may 

be warranted. 

	 Pulp, Paper, and Paperboard (40 CFR Part 430). EPA reviewed discharges of 

dioxin and dioxin-like compounds, manganese and manganese compounds, and 

sulfide (the top pollutants) for the 2013 Annual Review. EPA’s review identified 

the following: 

—	 One facility accounts for the majority (71 percent) of the 2011 DMR 

2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) category discharges. EPA 

identified and corrected a data entry error for the facility’s TCDD 

concentrations, which decreased the TCDD TWPE for this category. 

—	 Four facilities account for the majority (74 percent) of the 2011 TRI 

dioxin and dioxin-like compound discharges. EPA previously reviewed 

these four facilities as part of the 2011 and 2012 Annual Reviews. One of 

6-4
 
Section 6—Results of the 2013 Annual Review 

them shut down in 2012. For the other three, EPA determined that 2011 

dioxin and dioxin-like compound discharges are either below or near EPA 

Method 1613 MLs and are similar to 2009 dioxin and dioxin-like 

compound discharges. As a result, further review of dioxin and dioxin-like 

compound discharges from this category is not warranted at this time. 

—	 In 2011, 104 facilities reported discharges of manganese and manganese 

compounds to TRI. No facility accounts for more than 6 percent of the 

TWPE. EPA’s 2011 Annual Review and 2006 Detailed Study of the 

industry determined that metals concentrations in pulp and paper mill 

discharges were below treatable levels. EPA did not identify any new 

information to alter its previous findings. 

EPA has determined that the data do not support the need to further review 

the Pulp and Paper Category as a whole. 

	 Timber Products Processing (40 CFR Part 429). For this category, the top 

pollutants, in terms of TWPE, are total residual chorine, copper, and arsenic. 

EPA’s review identified the following: 

—	 One facility accounts for more than 99 percent of the 2011 DMR total 

residual chlorine category discharges. The facility only began reporting 

total residual chlorine discharges in 2011 and is not exceeding any permit 

limitations for total residual chlorine. As a result, EPA does not consider 

these discharges to be representative of the category; they do not warrant 

further review at this time. 

—	 One facility accounts for 87 percent of the 2011 DMR copper category 

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

facility’s copper concentrations. 

—	 One facility accounts for 80 percent of the 2011 DMR arsenic category 

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

facility’s arsenic concentrations, which decreased the arsenic TWPE for 

this category. 

EPA has determined that the data do not support the need to further review 

the Timber Category as a whole. 

6-5