Evaluation
of
RSEI
Model
Runs
Prepared
for:

U.
S.
Environmental
Protection
Agency
Engineering
and
Analysis
Division
Office
of
Water
1200
Pennsylvania
Avenue,
NW
Washington
DC
20460
Prepared
by:

Eastern
Research
Group,
Inc.
14555
Avion
Parkway
Suite
200
Chantilly,
VA
20151
August
6,
2003
Addendum
Added
December
12,
2003
EPA
Contract
No.
68­
C02­
095
Work
Assignment
0­
05
and
1­
05
ACKNOWLEDGMENTS
AND
DISCLAIMER
The
Agency
would
like
to
acknowledge
the
contributions
of
Carey
Johnston
and
Pat
Harrigan
of
EPA's
Office
of
Water
and
Steven
Hassur
of
EPA's
Office
of
Pollution
and
Prevention
and
Toxics
in
the
development
of
this
technical
document.
In
addition,
EPA
acknowledges
the
contribution
of
Eastern
Research
Group.

Neither
the
United
States
government
nor
any
of
its
employees,
contractors,
subcontractors,
or
other
employees
makes
any
warranty,
expressed
or
implied,
or
assumes
any
legal
liability
or
responsibility
for
any
third
party's
use
of,
or
the
results
of
such
use
of,
any
information,
apparatus,
product,
or
process
discussed
in
this
report,
or
represents
that
its
use
by
such
a
third
party
would
not
infringe
on
privately
owned
rights.
References
to
proprietary
technologies
are
not
intended
to
be
an
endorsement
by
the
Agency.

Questions
or
comments
regarding
this
technical
document
should
be
addressed
to:

Ms.
Lynn
Zipf
Biologist
Engineering
and
Analysis
Division
(
4303T)
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
(
202)
566
­
1429
zipf.
lynn@
epamail.
epa.
gov
i
RSEIreport_
121203.
wpd
TABLE
OF
CONTENTS
Page
EXECUTIVE
SUMMARY
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ES­
1
1.0
INTRODUCTION
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1­
1
2.0
OVERVIEW
OF
RSEI
MODEL
ANALYSIS
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2­
1
2.1
Overview
of
TRI
Reporting
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2­
2
2.2
Types
of
RSEI
Model
Output
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2­
4
2.3
Adaptations
to
Customize
RSEI
Output
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2­
6
2.4
Calculation
of
Risk­
Related
Results
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2­
7
2.4.1
Exposure
Pathways
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2­
8
2.4.2
Chemical
Toxicity
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2­
9
2.5
Completeness
of
RSEI
Analysis
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2­
11
3.0
RSEI
RANKINGS
BY
POINT
SOURCE
CATEGORY
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3­
1
3.1
Steam
Electric
Power
Generation
(
40
CFR
Part
423)
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3­
6
3.1.1
Industry
Description
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3­
6
3.1.2
Summary
of
RSEI
TRI
Data
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3­
8
3.2
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
(
40
CFR
Part
414)
.
3­
9
3.2.1
Industry
Description
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3­
9
3.2.2
Summary
of
RSEI
TRI
Data
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3­
12
3.3
Timber
Products
Processing
(
40
CFR
Part
429)
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3­
14
3.3.1
Industry
Description
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3­
14
3.3.2
Summary
of
RSEI
TRI
Data
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3­
16
3.4
Pulp,
Paper,
and
Paperboard
(
40
CFR
Part
430)
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3­
17
3.4.1
Industry
Description
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3­
18
3.4.2
Summary
of
RSEI
TRI
Data
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3­
19
3.5
SIC
Code
5171:
Petroleum
Bulk
Stations
and
Terminals
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3­
20
3.5.1
Industry
Description
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3­
20
3.5.2
Summary
of
RSEI
TRI
Data
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3­
22
3.6
Petroleum
Refining
(
40
CFR
Part
419)
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3­
23
3.6.1
Industry
Description
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3­
23
3.6.2
Summary
of
RSEI
TRI
Data
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3­
25
3.7
References
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3­
27
4.0
ITEMS
FOR
FURTHER
CONSIDERATION
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4­
1
TABLE
OF
CONTENTS
(
Continued)

ii
RSEIreport_
121203.
wpd
Attachment
A:
TRI
OVERVIEW
Attachment
B:
CALCULATION
OF
EAD
TWF
HAZARD
Attachment
C:
RELATION
OF
SIC
CODES
TO
POINT
SOURCE
CATEGORIES
Attachment
D:
POINT
SOURCE
CATEGORY
RANKINGS
BY
EAD
TWF
HAZARD
Addendum:
DATA
CORRECTIONS
AND
REVISED
RESULTS
iii
RSEIreport_
121203.
wpd
LIST
OF
TABLES
Page
3­
1
Ranking
of
Point
Source
Categories
That
Comprise
90%
of
EAD
TWF
Hazard
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.
3­
3
3­
2
Summary
Statistics
for
Point
Source
Categories
That
Comprise
90%
of
EAD
TWF
Hazard
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3­
5
3.1­
1
Summary
Statistics
for
the
Steam
Electric
Power
Generation
Point
Source
Category
(
40
CFR
Part
423)
.
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3­
8
3.1­
2
Chemical
Summary
Statistics
for
the
Steam
Electric
Power
Generation
Point
Source
Category
(
40
CFR
Part
423)
.
.
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.
3­
9
3.2­
1
Summary
Statistics
for
the
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
Point
Source
Category
(
40
CFR
Part
414)
.
.
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.
.
3­
12
3.2­
2
Chemical
Summary
Statistics
for
the
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
Point
Source
Category
(
40
CFR
Part
414)
.
.
.
.
.
.
.
.
.
.
3­
13
3.3­
1
Summary
Statistics
for
the
Timber
Products
Processing
Point
Source
Category
(
40
CFR
Part
429)
.
.
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.
3­
16
3.3­
2
Chemical
Summary
Statistics
for
the
Timber
Products
Processing
Point
Source
Category
(
40
CFR
Part
429)
.
.
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.
.
.
.
.
.
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.
.
3­
17
3.4­
1
Summary
Statistics
for
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
(
40
CFR
Part
430)
.
.
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.
3­
19
3.4­
2
Chemical
Summary
Statistics
for
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
(
40
CFR
Part
430)
.
.
.
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.
.
.
.
.
.
.
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.
.
3­
20
3.5­
1
Summary
Statistics
for
SIC
Code
5171:
Petroleum
Bulk
Stations
and
Terminals
.
.
.
.
.
.
.
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.
3­
22
3.5­
2
Chemical
Summary
Statistics
for
SIC
Code
5171:
Petroleum
Bulk
Stations
and
Terminals
.
.
.
.
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.
.
3­
23
3.6­
1
Summary
Statistics
for
the
Petroleum
Refining
Point
Source
Category
(
40
CFR
Part
419)
.
.
.
.
.
.
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.
3­
25
3.6­
2
Chemical
Summary
Statistics
for
the
Petroleum
Refining
Point
Source
Category
(
40
CFR
Part
419)
.
.
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3­
26
ES­
1
RSEIreport_
121203.
wpd
EXECUTIVE
SUMMARY
The
Clean
Water
Act
requires
EPA
to
periodically
revise
existing
effluent
limitations
guidelines
and
standards
(
ELGs),
and
promulgate
ELGs
for
new
point
source
categories
of
discharges.
EPA
published
a
draft
National
Strategy
that
sets
forth
a
planning
process
to
review
national
effluent
guidelines
and
set
priorities.
EPA
identified
four
major
factors,
derived
from
sections
301(
b)(
2)
and
304(
b)
of
the
CWA,
that
could
lead
EPA
to
conclude
that
a
revision
of
an
existing
effluent
guideline
or
a
promulgation
of
new
guideline
would
be
appropriate:
1)
the
extent
to
which
the
industry
category
is
discharging
pollutants
that
pose
a
risk
to
human
health
or
the
environment;
2)
the
identification
of
an
applicable
and
demonstrated
technology,
process
change,
or
pollution
prevention
approach
that
would
substantially
reduce
the
remaining
risk;
3)
the
cost,
performance,
and
affordability
of
the
technology,
process
change,
or
pollution
prevention
approach
that
would
substantially
reduce
that
risk;
and
4)
implementation
and
efficiency
considerations,
such
as
whether
revising
a
guideline
is
the
most
effective
approach
for
reducing
the
risk.
Factor
1
evaluates
the
extent
to
which
an
industry
category
is
discharging
pollutants
that
pose
an
impact
to
human
health
or
the
environment.
EPA
is
considering
the
use
of
several
data
sources
and
tools
available
to
evaluate
human
health
and
environmental
impacts.
One
of
these
tools
is
the
Risk
Screening
Environmental
Indicators
(
RSEI)
model,
developed
by
EPA's
Office
of
Pollution
Prevention
and
Toxics
(
OPPT).

The
RSEI
model
uses
Toxic
Release
Inventory
(
TRI)
data
to
estimate
chronic
human
toxicity
associated
with
long­
term
exposures
from
air
and
water
releases.
To
support
initial
screening
level
analyses
for
the
Strategy,
EPA's
Engineering
and
Analysis
Division
(
EAD)

conducted
a
review
of
the
RSEI
model
output
for
water
discharges
(
based
on
TRI
reported
releases
for
the
year
2000).
This
review
evaluated
the
completeness
of
the
RSEI
model
relative
to
the
goals
of
the
Strategy,
and
assessed
the
validity
of
the
ranked
lists
of
point
source
categories
and
SIC
codes
contributing
potential
risk.
EAD
also
performed
an
analysis
of
RSEI
output
customized
to
incorporate
EAD
toxic
weighting
factors
(
TWFs),
which
consider
both
human
health
and
aquatic
life
effects.
EAD
found
the
following
results:
ES­
2
RSEIreport_
121203.
wpd

Approximately
50
facilities
out
of
approximately
7,800
facilities
that
reported
direct
or
indirect
discharges
to
surface
water
in
the
2000
TRI
contribute
90
percent
of
both
the
RSEI
risk­
related
and
EAD
TWF
hazard
scores
for
the
entire
United
States.
(
The
specific
facilities
comprising
90
percent
of
the
two
results
differ.)


RSEI
risk­
related
and
EAD
TWF
hazard
scores
for
many
of
the
top
SIC
codes
and
point
source
categories
are
driven
by
discharges
from
a
few
or
only
one
facility.


Thirty­
four
out
of
400
SIC
codes
are
assigned
RSEI
risk­
related
results
of
zero;
9
of
the
400
SIC
codes
were
assigned
an
EAD
TWF
hazard
of
zero.


Eighty
of
the
329
TRI
list
chemicals
with
reported
direct
and
indirect
discharges
to
surface
water
in
the
2000
TRI
included
a
RSEI
risk­
related
score
of
zero
due
to
the
lack
of
chronic
human
health
toxicity
data
in
the
RSEI
model.
Fifty­
six
of
the
329
TRI
list
chemicals
received
an
EAD
hazard
score
of
zero
due
to
the
lack
of
EAD
TWFs.


Metals
and
metal
compounds
represent
approximately
78
percent
of
the
total
RSEI
risk­
related
results,
but
only
4
percent
of
the
TRI­
reported
pounds
discharged.
Two
TRI
compound
categories,
polycyclic
aromatic
compounds
(
PACs)
and
dioxin
and
dioxin­
like
compounds,
represent
approximately
93
percent
of
the
EAD
TWF
hazard
scores,
but
less
than
0.005
percent
of
the
total
TRI­
reported
pounds
discharged.

To
customize
RSEI
output
for
analyses
supporting
the
National
Strategy,
EAD
created
a
ranked
list
of
industries
(
using
EAD's
point
source
categories)
comprising
90
percent
of
the
EAD
TWF
hazard
scores.
The
six
categories
are:

EAD
TWF
Hazard
Score
Rank
Point
Source
Category
1
Steam
electric
power
generation
2
Organic
chemicals,
plastics,
and
synthetic
fibers
3
Timber
products
processing
4
Pulp,
paper,
and
paperboard
5
SIC
5171:
Petroleum
bulk
stations
and
terminals
6
Petroleum
refining
ES­
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EAD
also
identified
some
general
items
for
further
consideration,
which
reach
across
point
source
categories
and
SIC
codes.
Section
4.0
lists
details
of
the
general
and
point
source
category­
specific
items
that
EAD
identified,
including
validating
the
water­
related
RSEI
results,
investigating
whether
the
reported
PAC
and
dioxin
and
dioxin­
like
compound
releases
represent
a
reasonable
measure
of
actual
discharges,
and
conducting
site­
specific
second­
level
screening
and
evaluation
to
validate
RSEI
results.

Following
the
initial
screening­
level
review
of
PCS
data,
EAD
conducted
additional
data
quality
reviews
of
reported
pollutant
discharges
for
certain
top
ranking
industries
and
facilities.
These
reviews
identified
both
misreported
and
miscalculated
data,
including:

°
Adjustments
to
SIC
codes
associated
with
reported
discharges
(
affecting
the
point
source
category
or
industry
to
which
the
pollutant
loads
are
attributed);

°
Revisions
to
TWFs
used
for
certain
TRI
chemical
categories
(
e.
g.,
dioxin,
PACs)
to
better
reflect
the
specific
chemicals
discharged
by
a
specific
industry;

°
Adjustments
to
the
point
source
category/
SIC
crosswalk
to
eliminate
or
minimize
double
counting
of
pollutant
loads
between
industry
categories;
and
°
Facility­
and
pollutant­
specific
adjustments
to
reflect
misreported
or
miscalculated
pollutant
loadings.

An
addendum
detailing
these
data
corrections,
as
well
as
the
revised
pollutant
loads
by
point
source
category
and
industrial
grouping,
is
included
at
the
end
of
this
report.
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1.0
INTRODUCTION
The
Clean
Water
Act
requires
EPA
to
periodically
review
existing
effluent
guidelines,
pretreatment
standards,
and
new
source
performance
standards
and
to
revise
them
"
if
appropriate"
or,
in
the
case
of
new
source
performance
standards,
"
as
technology
and
alternatives
change."
In
addition,
the
Clean
Water
Act
requires
EPA
to
promulgate
effluent
guidelines
for
new
point
source
categories
of
discharges
under
certain
circumstances.
EPA
is
proposing
a
process
to
establish
priorities
for
the
Effluent
Guidelines
Program
that
is
predicated
on
selecting
opportunities
for
the
greatest
potential
risk
or
hazard
impact
reduction,
and
to
make
choices
in
consultation
with
the
public
and
regulated
communities
based
on
the
potential
to
cost­
effectively
reduce
levels
of
potential
impact
to
human
health
and
the
environment.

EPA
published
a
draft
National
Strategy
that
sets
forth
a
planning
process
to
review
national
effluent
guidelines
and
set
priorities.
EPA
identified
four
major
factors,
derived
from
sections
301(
b)(
2)
and
304(
b)
of
the
CWA,
that
could
lead
EPA
to
conclude
that
a
revision
of
an
existing
effluent
guideline
or
a
promulgation
of
new
guideline
would
be
appropriate:
1)
the
extent
to
which
the
industry
category
is
discharging
pollutants
that
pose
a
risk
to
human
health
or
the
environment;
2)
the
identification
of
an
applicable
and
demonstrated
technology,
process
change,
or
pollution
prevention
approach
that
would
substantially
reduce
the
remaining
risk;
3)

the
cost,
performance,
and
affordability
of
the
technology,
process
change,
or
pollution
prevention
approach
that
would
substantially
reduce
that
risk;
and
4)
implementation
and
efficiency
considerations,
such
as
whether
revising
a
guideline
is
the
most
effective
approach
for
reducing
the
risk.
The
Strategy
describes
how
EPA
intends
to
evaluate
readily
available
information
on
potential
risk
and
impacts
associated
with
point
source
discharges,
solicit
input
from
stakeholders,
gather
additional
information,
evaluate
whether
effluent
guidelines
are
the
most
efficient
approach
to
achieving
environmental
improvements,
and
present
results
to
the
public.

Factor
1
evaluates
the
extent
to
which
an
industrial
category
is
discharging
pollutants
that
pose
a
potential
impact
to
human
health
or
the
environment.
In
this
evaluation,

EPA
expects
to
consider
the
total
amount
of
pollutants
discharged
by
the
industrial
category,
the
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toxicity
of
that
discharge
to
both
human
health
and
the
environment,
the
fate
and
transport
of
those
pollutants,
and
the
number
of
potentially
exposed
individuals.
EPA
is
considering
the
use
of
several
data
sources
and
tools
available
to
evaluate
human
health
and
environmental
impacts,
as
discussed
in
the
report
entitled,
"
Factor
1
Analysis:
Human
Health
and
Environmental
Impacts,"

dated
December
2003.
One
of
these
data
sources
is
EPA's
TRI,
which
includes
estimates
of
pollutant
discharges
to
water.

The
RSEI
model,
developed
by
EPA's
Office
of
Pollution
Prevention
and
Toxics
(
OPPT),
is
a
tool
used
to
estimate
the
risk
associated
with
discharges
to
the
environment.
The
RSEI
model
uses
data
reported
in
the
TRI
to
estimate
chronic
human
toxicity
associated
with
long­
term
exposures
from
air
and
water
releases.
Since
publication
of
its
first
proposed
methodology
in
1991,
the
Risk­
Screening
Environmental
Indicators
(
RSEI;
earlier
known
as
the
TRI
Relative
Risk­
Based
Environmental
Indicators)
has
been
reviewed
by
risk
experts
including
experts
in
academia,
industry
trade
associations,
federal
and
state
government,
and
the
EPA
Science
Advisory
Board
(
SAB).
The
SAB
reviews
endorsed
the
RSEI
methodology
(
including
the
framework
of
the
water
release
model)
and
the
revised
toxicity
weighting
approach
for
screening
purposes.
Validation
of
the
air
release
model
was
conducted
by
Agency
staff.
EAD
also
evaluated
TRI
reported
discharges
output
from
the
RSEI
model
using
EAD
TWFs.
These
TWFs
incorporate
both
human
health
and
aquatic
life
effects.

This
report
discusses
initial
screening
level
analysis
of
RSEI
model
output
for
both
direct
and
indirect
water
discharges
reported
in
the
2000
TRI.
The
remainder
of
this
report
is
organized
in
the
following
sections:


Section
2.0
gives
an
overview
of
the
RSEI
model,
as
well
as
an
overview
of
TRI;


Section
3.0
presents
a
discussion
of
six
point
source
categories
from
the
RSEI
model
ranking;
and

Section
4.0
discusses
future
activities
under
consideration.
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Throughout
the
review
of
TRI
data,
EPA
identified
and
corrected
misreported
or
miscalculated
data.
A
summary
of
these
data
changes
can
be
found
in
the
addendum
to
this
report.
EPA
does
not
believe
that
all
errors
have
been
corrected
at
this
time.
Additional
corrections
will
be
added
to
the
addendum
as
they
occur.
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2.0
OVERVIEW
OF
RSEI
MODEL
ANALYSIS
EPA's
TRI
collects
data
for
612
chemicals
released
and
transferred
by
selected
facilities
in
the
United
States.
Some
of
these
chemicals
have
qualifiers
associated
with
them,
and
only
those
qualified
forms
of
the
chemical
are
reported
to
TRI
(
e.
g.,
aluminum
is
only
reportable
in
the
form
of
a
fume
or
dust).
It
is
important
to
note
that
conventional
pollutants
(
e.
g.,
total
suspended
solids,
biochemical
oxygen
demand,
pH,
and
oil
and
grease)
are
not
reported
to
TRI,

and
therefore
are
not
modeled.
In
2000,
facilities
reported
releases
of
527
chemicals
and
chemical
categories.
RSEI
contains
toxicity
data
on
426
of
these
chemicals
and
chemical
categories.

The
RSEI
model
allows
users
to
complete
screening­
level
analyses
of
facilities
and
chemicals
using
TRI
data.
One
way
facilities
are
identified
in
RSEI
is
by
primary
4­
digit
Standard
Industrial
Classification
(
SIC)
code.
The
RSEI
model
incorporates
the
following
information
into
the
model:


Amount
of
the
chemical
released
as
reported
from
TRI;


Location
of
the
chemical
release,
assumed
to
be
the
actual
facility
location
as
reported
from
TRI;


Proportional
toxicity
and
toxicity
weights
based
on
sources
such
as
the
Integrated
Risk
Information
System
(
IRIS);


Estimated
fate
and
transport
of
the
chemical
in
the
environment
once
released;


Pathway
of
release
based
on
the
TRI­
reported
medium
and
extent
of
human
exposure;


Number
of
people
exposed
through
fish
ingestion
based
on
1990
U.
S.
Census
data;
and

Number
of
people
exposed
based
on
drinking
water
populations
from
the
Safe
Drinking
Water
Information
System
(
SDWIS)
for
assessment
of
drinking
water
exposures.
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RSEIreport_
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These
components
are
combined
and
modeled
to
offer
a
quantitative
screeninglevel
risk­
related
perspective
for
relative
comparisons
of
chemical
releases.
The
model
also
allows
users
to
examine
results
from
a
hazard­
based
perspective
(
i.
e.,
where
TRI
releases
are
weighted
only
by
the
toxicity
of
the
chemical
released,
without
considering
the
potential
for
exposure
or
number
of
people
exposed),
as
well
as
view
results
from
a
pollutant
loadings
(
in
pounds)
perspective.
This
feature
allows
users
to
conduct
analyses
of
releases
and
transfers
of
chemicals
where
exposure
and
modeling
information
is
absent.

Section
2.1
presents
an
overview
of
TRI
and
how
data
are
reported
to
EPA.

Section
2.2
describes
types
of
RSEI
model
output,
and
Section
2.3
discusses
EPA's
adaptations
to
customize
RSEI
output
for
analyses
supporting
the
National
Strategy.
Section
2.4
discusses
the
way
RSEI
calculates
a
risk­
related
result,
including
discussions
of
exposure
pathways
modeled
and
chemical
toxicity
weights.
Finally,
Section
2.5
discusses
the
completeness
of
the
RSEI
analysis.

2.1
Overview
of
TRI
Reporting
TRI
is
the
common
name
for
Section
313
of
the
Emergency
Planning
and
Community
Right­
to­
Know
Act
(
EPCRA).
Each
year,
facilities
that
meet
certain
thresholds
(
such
as
number
of
employees)
must
report
their
releases
and
other
waste
management
activities
(
quantities
recycled,
collected,
and
combusted
for
energy
recovery,
treated
for
destruction,
or
disposed)
for
listed
toxic
chemicals.
A
separate
report
must
be
filed
for
each
chemical
that
exceeds
a
threshold.

There
are
three
criteria
that
a
facility
must
meet
to
be
required
to
submit
a
TRI
report
for
that
reporting
year.
The
criteria
are:

1)
SIC
Code
Determination:
Facilities
in
SIC
Codes
20
through
39,
seven
additional
SIC
codes
outside
this
range,
and
federal
facilities
must
evaluate
whether
additional
criteria
are
met
and
whether
reporting
is
required.
EPA
rarely
checks
or
refutes
facility
claims
regarding
the
SIC
code
identification.
The
primary
SIC
code,
which
is
based
on
the
facility's
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primary
activity
as
reported
by
the
submitter,
determines
TRI
reporting
and
has
been
used
as
the
basis
for
the
RSEI
analysis.

2)
Number
of
Employees:
Facilities
must
have
10
or
more
full­
time
employees
or
their
equivalent.
EPA
defines
a
"
full­
time
equivalent"
as
a
person
that
works
2,000
hours
in
the
reporting
year
(
there
are
several
exceptions
and
special
circumstances
that
are
well­
defined
in
the
TRI
reporting
instructions).

3)
Activity
Thresholds:
If
the
facility
is
in
a
covered
SIC
code
and
has
10
or
more
full­
time
employee
equivalents
it
must
conduct
an
activity
threshold
analysis
for
every
chemical
and
chemical
category
on
the
current
TRI
list.
The
facility
must
determine
whether
it
manufactures,
processes,
OR
otherwise
uses
each
chemical
at
or
above
the
appropriate
activity
threshold.
Reporting
thresholds
are
not
based
on
the
amount
of
release.
All
TRI
thresholds
are
based
on
mass,
not
concentration.
Different
thresholds
apply
for
persistent
bioaccumulative
toxic
(
PBT)
chemicals
than
for
non­
PBT
chemicals.

If
a
facility
does
not
manufacture,
process,
or
otherwise
use
any
EPCRA
Section
313
chemicals,
it
is
not
required
to
report
to
the
TRI.
This
may
account
for
the
number
of
facilities
known
to
be
part
of
an
SIC
code
in
the
1997
U.
S.
Economic
Census
but
not
included
in
the
RSEI
analysis.

EPA
identified
several
factors
associated
with
TRI
reporting
that
could
cause
confusion
when
analyzing
RSEI
results:


Range
Reporting:
TRI
provides
the
option
for
facilities
to
report
releases
as
specific
numbers
or
as
ranges,
if
appropriate.
Specific
estimates
are
encouraged
if
data
are
available
to
ensure
the
accuracy;
however,
EPA
allows
facilities
to
report
releases
in
the
following
ranges:
1
to
10
pounds,
11
to
499
pounds,
and
500
to
999
pounds.
Range
reporting
is
not
permitted
for
PBT
chemicals.
The
RSEI
model
uses
the
mid­
point
of
each
reported
range.


Detection
Limits:
Companies
are
required
to
use
their
judgement
and
report
the
most
accurate
information.
The
TRI
program
does
not
specify
the
use
(
or
non­
use)
of
detection
limits.
TRI
guidance
states
that
if
a
facility
reasonably
expects
a
chemical
to
be
present
in
waste
streams,
the
facility
should
assume
half
of
the
detection
limit
for
estimates.
If
the
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facility
does
not
reasonably
expect
the
chemical
to
be
present,
they
can
assume
a
concentration
of
zero.


The
De
Minimis
Exemption:
TRI
includes
an
exemption
such
that,
in
general,
chemicals
in
any
process
or
waste
stream
below
1
percent
(
by
mass)
for
non­
carcinogens
or
below
0.1
percent
for
carcinogens
(
as
defined
by
OSHA)
should
be
excluded
from
both
threshold
and
release
estimates.
The
de
minimis
exemption
is
not
applicable
to
the
manufacture
of
any
TRI
chemical
nor
to
PBT
chemicals.


Alternate
Certification
Statement
(
Form
A):
Starting
in
1997,
EPA
instituted
an
optional
second
type
of
TRI
Report,
commonly
called
the
Form
A.
With
implementation
of
Form
A,
facilities
may
now
certify
that
the
total
quantity
of
a
specific
chemical
released
and
managed
as
waste
is
less
than
500
pounds
without
quantifying
estimates
to
any
media.
A
significant
number
of
Form
A's
are
submitted
by
every
industry
each
year;
Form
A's
cannot
be
submitted
for
PBT
chemicals.
According
to
the
2000
Public
Data
Release
8,
456
Form
A's
were
filed.
Initial
analysis
of
RSEI
indicates
that,
because
no
release
quantity
can
be
assigned
to
any
media,
RSEI
ignores
all
Form
A
submissions.


Test
Data:
EPCRA
mandates
that
facilities
use
the
"
best
readily
available
information"
to
prepare
threshold
and
release
estimates
for
TRI
reporting.
It
does
not
require
the
facility
to
conduct
tests
on
the
chemicals.
However,
if
testing
has
been
conducted
for
any
other
purpose,
the
facility
is
required
to
consider
using
the
results
if
they
are
appropriate.

Further
information
on
TRI
reporting,
including
discussions
of
how
facilities
report
metals
and
metal
compounds,
how
TRI
data
change
over
time,
and
TRI
data
quality,
can
be
found
in
Attachment
A
to
this
report.
More
detailed
information
on
the
TRI
program
is
located
on
EPA's
TRI
homepage:
http://
www.
epa.
gov/
tri/.

2.2
Types
of
RSEI
Model
Output
Using
RSEI
model
results
generated
by
the
OPPT,
EAD
analyzed
RSEI
model
output
encompassing
a
subset
of
TRI
releases
and
transfers
of
chemicals
by
facilities
to
surface
waters
and
POTWs
for
the
year
2000.
Although
RSEI
can
model
both
air
and
water
releases,
this
model
cannot
currently
account
for
air
deposition
modeling
that
could
result
in
chemical
deposition
into
lakes,
streams,
and
watersheds
from
stack
air
emissions.
2­
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RSEIreport_
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RSEI
develops
four
rankings
from
the
TRI
data:
1)
RSEI
risk­
related
result,
2)

modeled
hazard,
3)
hazard,
and
4)
total
TRI
pounds.
EAD
developed
a
fifth
ranking:
EAD
TWF
hazard.
These
rankings
are
defined
as
follows:


Risk­
Related
Results
­
The
risk­
related
result
is
the
product
of
the
surrogate
dose
(
estimated
using
exposure
models),
the
chemical's
toxicity
weight,
and
the
exposed
population.
This
result
requires
all
necessary
modeling
parameters
to
be
present,
and
provides
the
most
comprehensive
ranking
available
by
the
model.
The
amount
of
chemical
released
is
the
modeled
amount
based
on
the
fate
and
transport
of
the
chemical
pounds
and
physical/
chemical
properties
of
the
chemical.


Modeled
Hazard
­
This
value
is
computed
by
multiplying
modeled
TRI
pounds
by
the
proportional
toxicity
weight
of
the
chemical
appropriate
for
the
exposure
pathway
selected
(
i.
e.,
inhalation
toxicity
weight
or
ingestion
toxicity
weight).
Modeled
TRI
pounds
are
those
in
which
all
of
the
required
input
parameters
required
to
calculate
a
risk­
related
result
are
present.
Modeled
TRI
pounds
do
not
necessarily
include
all
reported
discharges
to
surface
waters
or
POTWs
(
e.
g.,
pounds
may
be
excluded
because
other
required
parameters
are
not
available).


Hazard
­
This
value
is
calculated
for
TRI
chemicals
that
have
toxicity
weights
and
provides
a
perspective
regarding
the
chronic
human
health
hazard
of
these
releases.
The
hazard
score
is
calculated
by
multiplying
reported
TRI
pounds
by
the
toxicity
weight
of
the
chemical
associated
with
the
release
pathway
selected
(
i.
e.,
inhalation
toxicity
weight
or
oral
toxicity
weight).
The
model
uses
the
inhalation
toxicity
weight
when
calculating
the
hazard
score
for
air
releases.
For
TRI
on­
site
direct
water
releases
and
offsite
transfers
to
POTWs,
the
model
uses
the
oral
toxicity
weight
(
riskrelated
calculations
use
toxicity
weights
for
both
exposure
pathways
when
modeling
the
air
and
water
releases
from
POTWs).
For
unmodeled
releases,
RSEI
uses
the
highest
toxicity
weight
for
the
hazard
score.
For
this
analysis,
for
indirect
dischargers,
the
hazard
score
accounts
for
treatment
at
a
POTW.


Total
TRI
Pounds
­
This
amount
reflects
the
number
of
pounds
released
or
transferred
that
are
reported
to
the
TRI.
The
model
includes
pounds
discharged
to
surface
water
by
both
direct
and
indirect
discharges.
For
indirect
discharges,
the
reported
pounds
transferred
off
site
to
POTWs
are
adjusted
to
account
for
treatment
at
a
POTW.


EAD
Toxic­
Weighting
Factor
(
TWF)
Hazard
­
This
value
is
calculated
for
TRI
chemicals
that
have
EAD
TWFs,
as
developed
by
EAD's
Economic
&
Environmental
Assessment
Branch.
EAD
TWF
hazard
scores
2­
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RSEIreport_
121203.
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are
calculated
by
multiplying
total
TRI
pounds
(
described
above)
by
the
EAD
TWF
of
the
chemical.
For
more
details
on
how
EAD
TWFs
were
calculated,
see
Section
2.3.

2.3
Adaptations
to
Customize
RSEI
Output
In
the
thirty
years
since
Congress
passed
the
1972
Clean
Water
Act,
EPA
has
promulgated
effluent
guidelines
that
address
56
categories,
and
in
the
process
has
developed
a
variety
of
tools
and
methodologies
to
evaluate
effluent
discharges.
To
customize
RSEI
output
to
support
the
National
Strategy,
EAD
incorporated
the
following
factors
into
its
analyses:


EAD
TWFs
in
place
of
RSEI
toxic
weights;
and

Point
source
category
designations
by
facility
based
on
the
primary
SIC
code
(
retaining
the
4­
digit
SIC
code
for
those
facilities
not
included
in
existing
point
source
categories).

As
discussed
in
Section
2.4.2,
the
RSEI
model
considers
only
chronic
human
health
effects
in
assigning
chemical
toxicity.
In
contrast,
EAD
assigns
chemical
toxicity
based
on
both
aquatic
life
effects
and
human
health
effects.
EAD
maintains
a
Toxics
Data
Base
containing
aquatic
life
and
human
health
toxicity
data,
as
well
as
physical/
chemical
property
data,
for
more
than
1,900
pollutants
compiled
from
over
100
references.
Chemical­
specific
information
needed
to
generate
EAD
TWFs
include
aquatic
life
criteria
or
toxic
effect
data
for
native
aquatic
species,

human
health
reference
doses
(
RfDs),
and
cancer
potency
slope
factors
(
SFs).
In
developing
an
EAD
TWF,
a
value
for
aquatic
life
effects
and
a
value
for
human
health
effects
are
added.
The
calculation
is
performed
by
dividing
aquatic
life
and
human
health
criteria
(
or
toxic
effect
levels)

for
each
pollutant,
expressed
as
a
concentration
in
micrograms
per
liter
(
µ
g/
L),
into
the
former
copper
criterion
of
5.6
µ
g/
L:

TWF

5.6
AQ

5.6
HHOO
where:

TWF
=
toxic
weighting
factor
AQ
=
chronic
aquatic
life
value
(
µ
g/
L)
2­
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RSEIreport_
121203.
wpd
HHOO
=
human
health
(
ingesting
contaminated
organisms
only)
value
(
µ
g/
L).

For
more
details
on
how
EAD
determines
TWFs,
see
Toxic
and
Pollutant
Weighting
Factors
of
the
Final
Effluent
Limitations
Guidelines
and
Standards
for
Iron
and
Steel
Industry,
Final
Report
April
30,
2002.

The
TRI
list
includes
612
chemicals
and
compound
categories;
however,
reported
direct
or
indirect
discharges
to
surface
water
in
the
2000
TRI
included
a
total
of
329
TRI
list
chemicals
and
compound
categories.
EAD
TWFs
have
not
been
developed
for
56
of
these
chemicals,
resulting
in
an
EAD
TWF
hazard
score
of
zero
for
these
compounds.
For
more
details
on
how
EPA
correlated
EAD
TWFs
to
the
TRI
list
of
chemicals
and
compound
categories,
see
Attachment
B.
Note
that
two
compounds,
PACs
and
dioxin
and
dioxin­
like
compounds,

represent
less
than
0.005
percent
of
the
TRI­
reported
pounds
discharged
to
water,
but
approximately
93
percent
of
the
total
EAD
TWF
hazard
score
as
a
result
of
the
relatively
high
EAD
TWFs
for
these
compounds.
See
Section
3.0
for
further
discussion
of
this
issue.

To
analyze
RSEI
output
at
the
point
source
category
level,
EAD
related
SIC
codes
to
point
source
categories
for
existing
ELGs.
Facilities
are
required
to
report
a
primary
SIC
code
that
best
characterizes
the
activities
occurring
at
the
facility.
(
Facilities
may
report
up
to
five
more
additional
codes.)
For
this
analysis,
EPA
used
the
reported
primary
SIC
code.
EAD
aggregated
the
results
of
the
model
for
discharges
to
surface
waters
and
transfers
to
POTWs
and
ranked
the
results
by
point
source
category
and/
or
primary
SIC
code.
See
Section
3.0
for
further
information
regarding
the
classification
of
point
source
categories
and
compilation
of
RSEI
output
by
point
source
categories.

2.4
Calculation
of
Risk­
Related
Results
Version
2.1
of
the
RSEI
model
calculates
values
that
reflect,
for
modeled
TRI
releases
and
transfers,
chronic
human
health
risk­
related
impacts.
The
model
does
not
include
2­
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RSEIreport_
121203.
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acute
human
health
risks
or
risks
to
aquatic
life.
The
values
output
by
the
model
can
only
be
interpreted
as
relative
measures
and
are
only
meaningful
in
relationship
to
one
another.

The
model
uses
many
parameters,
all
of
which
must
be
present
in
order
to
calculate
a
risk­
related
result.
For
example,
facilities
are
assumed
to
discharge
to
the
nearest
receiving
stream
reach
(
i.
e.,
a
linear,
unbranched
section
of
a
water
body),
as
long
as
that
reach
is
within
six
kilometers
of
the
facility
or
the
actual
receiving
body
is
known;
otherwise,
the
discharge
is
not
modeled.
Note
that
stream
reach
data
are
not
available
for
Alaska,
Hawaii,
Puerto
Rico,

the
U.
S.
Virgin
Islands,
Guam,
American
Samoa,
and
the
Northern
Marianis
Islands;
therefore,
no
surface
water
releases
are
modeled
for
those
areas,
and
no
risk­
related
results
are
calculated.

2.4.1
Exposure
Pathways
The
RSEI
model
calculates
chronic
human
health
exposures
for
surface
water
releases
for
two
pathways:
drinking
contaminated
water
and
eating
non­
commercial
contaminated
fish.
RSEI
evaluates
the
exposure
pathway
by
assuming
that
facilities
discharge
chemicals
into
the
nearest
stream
reach,
unless
the
actual
receiving
body
is
known
(
in
which
case
RSEI
uses
the
reported
reach).
Chemical
concentrations
are
estimated
for
distances
up
to
200
kilometers
downstream
from
the
chemical
release
location.
For
more
details
on
how
RSEI
calculates
exposure,
see
the
document
DCN00233
in
Section
3.1.1
of
the
National
Strategy
docket.

RSEI
evaluates
fish
ingestion
based
on
a
county­
level
data
set
from
state
fish
and
wildlife
data
(
fishing
or
hunting/
fishing
licenses)
for
1996
(
or
1997
if
1996
was
not
available).

RSEI
matches
the
county­
level
data
in
conjunction
with
U.
S.
Economic
Census
data
to
estimate
the
number
of
people
by
age
and
gender
who
would
likely
ingest
fish.
The
model
estimates
the
chemical
concentration
in
fish
based
on
fate
and
transport
in
streams
to
which
chemicals
are
released.
Matching
all
these
data
together,
RSEI
estimates
the
human
exposure
resulting
from
fish
ingestion.

Estimates
of
the
population
served
by
each
drinking
water
intake
are
obtained
from
the
SDWIS.
The
model
uses
these
estimates
as
inputs
for
population
size
for
exposure
through
2­
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RSEIreport_
121203.
wpd
drinking
water.
Note
that
if
a
stream
reach
contains
no
drinking
water
intake,
the
exposed
population
is
set
to
zero
for
exposure
through
drinking
water
and
the
RSEI
risk­
related
result
is
zero.
However,
a
hazard­
related
result
may
still
be
calculated
based
on
the
pounds
of
chemical
discharged
and
the
chemical
toxicity.

For
indirect
discharges
(
transfers
to
POTWs),
RSEI
models
chemicals
entering
the
POTW
as
liquid
influent.
Depending
on
the
chemical's
physical
properties,
some
portion
of
the
influent
chemical
may
be
discharged
into
surface
water,
resulting
in
human
exposure
through
drinking
water
or
fish
ingestion.
Therefore,
the
model
considers
overall
removal
efficiencies
of
POTWs
and
resulting
discharges.
The
model
requires
input
on
all
of
the
following
parameters
to
model
exposure
from
chemical
transfers
to
POTWs:


Location
of
the
POTW
to
which
chemicals
are
discharged;


Location
of
the
stream
reach
to
which
the
POTW
discharges;


Overall
removal
efficiencies
of
POTWs
and
resulting
removal
rate
(
i.
e.,
contaminant­
specific
removal
rate);
and

Residuals
management
at
POTWs
(
i.
e.,
partitioning
within
the
POTW).

Methods
used
to
estimate
population
exposure
to
surface
water
effluent
discharges
from
POTWs
are
the
same
as
for
estimating
population
exposure
to
direct
surface
water
discharges,
as
previously
described.

2.4.2
Chemical
Toxicity
EPA
chose
a
method
of
assigning
toxicity
weights
to
chemicals
based
upon
easily
accessible
and
publicly
available
information,
and
uses
expert
EPA­
wide
judgments
to
the
greatest
extent
possible.
The
toxicity
weights
in
RSEI
are
based
upon
the
single,
most
sensitive
chronic
human
health
endpoint
(
i.
e.,
cancer
or
the
most
sensitive
noncancer
effect)
for
inhalation
or
ingestion
exposure,
and
do
not
reflect
severity
of
effects,
multiple
health
effects,
or
dermal
absorption.
Neither
acute
human
toxicity
nor
environmental
toxicity
are
modeled.
RSEI
reflects
2­
10
RSEIreport_
121203.
wpd
the
toxicities
of
chemicals
relative
to
one
another
using
a
continuous
system
of
numerical
weights.

Toxicity
weights
for
chemicals
increase
as
the
toxicological
potential
to
cause
chronic
human
health
effects
increases.

The
TRI
list
includes
30
chemical
compound
categories.
EPA's
methodology
for
assigning
toxicity
weights
to
these
categories
was
to
determine
a
representative
chemical
for
each
group
(
if
possible)
and
assign
the
toxicity
weight
of
that
representative
compound
to
the
entire
category.
Table
B­
1
of
Attachment
B
lists
the
30
TRI
chemical
compound
categories
and
the
representative
chemical
used
to
assign
RSEI
toxicity
weights.

RSEI
makes
two
significant
assumptions
regarding
the
toxicity
of
metals
and
metal
compounds.
These
assumptions
are
necessary
because
TRI
reporting
does
not
identify
the
valence
state
of
metals
or
metal
compounds,
and
because
the
chemical
identity
of
metal
compounds
released
to
the
environment
is
not
reported
(
only
the
quantity
of
the
parent
metal
contained
within
compounds).
The
first
assumption
RSEI
makes
is
that
metal
compounds
have
the
same
toxicity
weight
as
that
of
the
parent
metal,
even
though
the
chronic
human
toxicity
of
some
metal
compounds
may
be
higher
or
lower
than
the
parent
metal.
The
second,
conservative
assumption
is
that
the
entire
release
consists
of
the
valence
state
associated
with
the
highest
chronic
human
toxicity
(
e.
g.,
for
chromium,
Cr+
6
versus
Cr+
3).
Therefore,
RSEI
results
may
overestimate
the
potential
risk
for
metals,
and
may
overestimate
or
underestimate
the
potential
risk
for
metal
compounds.
For
more
information
on
metals
and
their
bioavailability,
see
the
February
24,
2003
memorandum
entitled
"
Evaluation
of
the
Appropriateness
of
Representative
Chemicals
for
Influential
Chemical
Groups"
from
Susan
Keane
and
Kristina
Watts,
Abt
Associates,
to
Lynn
Zipf,
EPA\
OW.
Note
that
metals
and
metal
compounds
represent
only
4
percent
of
the
TRIreported
pounds
discharged,
but
approximately
78
percent
of
the
total
RSEI
risk­
related
results,

likely
as
a
result
of
these
two
assumptions.

The
TRI
list
includes
612
chemicals
and
compound
categories.
One
hundred
eighty­
six
chemicals
reported
in
TRI
lack
chronic
human
health
toxicity
data,
including
dioxins
(
reported
by
172
facilities).
However,
discharges
for
many
of
these
chemicals
were
not
reported
to
TRI
(
reported
direct
or
indirect
discharges
to
surface
water
in
the
2000
TRI
included
a
total
of
2­
11
RSEIreport_
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wpd
329
TRI
list
chemicals
and
compound
categories).
Furthermore,
some
chemicals
have
only
inhalation
toxicity
data
and
not
ingestion
toxicity
data.
In
some
cases,
such
as
with
ammonia
(
reported
by
1,301
facilities),
RSEI
does
not
assign
risk
associated
with
surface
water
discharges
and
transfers
to
POTWs
because
there
is
evidence
that
using
inhalation
data
in
this
case
is
inappropriate.
As
a
result
of
these
factors,
80
of
the
329
TRI
list
chemicals
with
reported
direct
or
indirect
discharges
to
surface
water
in
the
2000
TRI
include
a
RSEI
risk­
related
score
of
zero.

2.5
Completeness
of
RSEI
Analysis
Sections
2.3
and
2.4.2
of
this
report
described
the
completeness
of
the
RSEI
analysis
at
the
pollutant
level.
This
section
describes
the
completeness
of
the
analysis
at
the
SIC
code
and
point
source
category
level.

There
are
a
total
of
400
SIC
codes
represented
by
all
facilities
with
reported
direct
or
indirect
discharges
to
surface
water
in
the
2000
TRI.
Because
all
input
parameters
required
to
calculate
RSEI
model
results
may
not
be
present,
EPA
analyzed
how
many
SIC
codes
were
evaluated
in
the
RSEI
model.
The
results
are
as
follows:


395
of
the
400
SIC
codes
have
RSEI
model
toxicity
data
for
at
least
one
chemical
that
is
discharged,
while
391
of
the
400
SIC
codes
have
EAD
TWF
hazard
data
for
at
least
one
chemical
that
is
discharged.


366
SIC
codes
were
assigned
a
risk­
related
result
that
was
greater
than
zero,
while
34
SIC
codes
were
assigned
a
risk­
related
result
of
zero.
[
Note
that
the
RSEI
model
can
assign
a
risk­
related
result
of
zero
for
different
reasons
(
e.
g.
lack
of
required
parameters
for
modeling,
or
an
exposed
population
of
zero)].


All
391
SIC
codes
with
EAD
TWF
hazard
score
for
at
least
one
chemical
were
assigned
a
total
EAD
TWF
hazard
score
greater
than
zero,
while
the
remaining
9
SIC
codes
were
assigned
an
EAD
TWF
hazard
score
of
zero.

RSEI
is
likely
to
underestimate
the
discharge
because
only
the
primary
SIC
is
used.

For
facilities
in
several
SIC
codes,
RSEI
would
be
underestimating
the
discharges
in
those
other
SIC
codes
and
overestimating
the
discharges
for
the
primary
SIC
codes.
3­
1
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3.0
RSEI
RANKINGS
BY
POINT
SOURCE
CATEGORY
RSEI
output
shows
7,814
facilities
reported
discharges
to
surface
waters
and
transfers
to
POTWs
during
the
year
2000.
Of
these
7,814
facilities,
6,074
were
assigned
a
riskrelated
result
greater
than
zero,
and
1,740
facilities
were
assigned
a
risk­
related
result
of
zero.
In
contrast,
7,625
of
the
7,814
facilities
were
assigned
an
EAD
TWF
hazard
score
greater
than
zero,

while
189
facilities
were
assigned
an
EAD
TWF
hazard
score
of
zero.
Analysis
also
shows
that
approximately
50
facilities
represent
90
percent
of
both
the
total
national
RSEI
risk­
related
result
and
the
EAD
TWF
hazard
score
(
the
specific
facilities
comprising
90
percent
of
the
two
results
differ).
Therefore,
less
than
one
percent
of
the
total
number
of
facilities
reporting
releases
and
transfers
account
for
90
percent
of
the
RSEI
model
results,
either
on
a
risk
basis
or
a
hazard
basis.

To
facilitate
analysis
of
the
RSEI
model
results
to
support
the
National
Strategy,

EAD
summed
SIC
code­
specific
RSEI
results
for
each
of
the
point
source
categories
with
existing
effluent
limitation
guidelines
and
standards.
Attachment
C
describes
the
methodology
EPA
used
to
assign
SIC
codes
to
point
source
categories,
as
well
as
tables
relating
point
source
categories
to
SIC
codes.
Some
SIC
codes
fall
in
more
than
one
point
source
category.
In
these
cases,
the
RSEI
model
results
are
either
distributed
among
applicable
point
source
categories
or
counted
in
each
point
source
category
in
which
they
are
regulated,
depending
on
the
specific
SIC
code
as
discussed
in
Attachment
C.
(
Double
counting
of
RSEI
model
results
for
certain
SIC
codes
accounts
for
approximately
8.5
percent
of
the
total
RSEI
risk­
related
result
and
1.5
percent
of
the
total
EAD
TWF
hazard
score.)
Some
SIC
codes
do
not
fall
within
any
of
the
existing
point
source
categories.
That
is,
no
existing
ELGs
apply
to
wastewater
discharges
from
these
industries.
For
these
SIC
codes,
RSEI
model
results
are
reported
and
reviewed
at
the
4­
digit
SIC
code
level.
EPA
may
consider
these
SIC
codes,
or
combinations
of
these
SIC
codes,
in
identifying
new
potential
point
source
categories
for
regulatory
action
or
other
initiatives.

Attachment
D
presents
the
RSEI
model
results
by
point
source
category
(
or
4­
digit
SIC
code
for
those
industries
not
included
in
existing
point
source
categories)
ranked
in
order
of
descending
EAD
TWF
hazard.
The
remainder
of
this
report
focuses
on
analysis
of
the
EAD
TWF
hazard
scores,
which
EPA
believes
best
supports
the
National
Strategy.
First,
as
discussed
in
3­
2
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Section
2.3,
the
EAD
TWF
hazard
analysis
is
more
closely
aligned
to
the
methodologies
EAD
uses
in
developing
effluent
limitations.
Second,
initial
review
identified
facilities
that
comprise
90
percent
of
the
RSEI
risk­
related
results.
EAD
further
investigated
the
facilities
for
which
the
data
or
model
appear
to
produce
discrepancies
that
would
affect
the
estimated
risk.
For
example,
the
Kimberly­
Clark
mill
in
Everett,
Washington
discharges
to
the
Everett
Harbor
(
Port
Gardner)

Puget
Sound,
yet
received
a
relatively
high
RSEI
risk­
related
score.
The
Puget
Sound
is
not
a
drinking
water
source,
and
RSEI
does
not
model
consumption
of
marine
species,
thus
EAD
would
expect
little
or
no
risk
associated
with
this
facility.
Third,
EPA
has
not
yet
completed
validating
the
water­
related
RSEI
fate
and
transport
calculations.
For
these
reason,
EPA
will
limit
the
consideration
of
RSEI
risk­
related
results
to
use
as
a
source
of
secondary
or
confirmation
information
for
other
analyses.

Table
3­
1
lists
the
six
point
source
categories
that
comprise
90
percent
of
the
EAD
TWF
hazard
score
for
the
United
States
and
the
corresponding
result
of
all
five
rankings
discussed
in
Section
2.2.
As
part
of
the
initial
screening
effort,
EAD
reviewed
the
top
six
point
source
categories
to
determine
and
comment
on
the
underlying
factors
that
drive
the
EAD
TWF
hazard
scores.
Sections
3.1
through
3.6
summarize
the
initial
analysis
for
each
of
the
six
top
point
source
categories.

Note
that
Table
3­
1
also
presents
the
number
of
facilities
that
comprise
90
percent
of
the
EAD
TWF
hazard
score
for
water
discharges
for
each
point
source
category
(
or
SIC
code).

This
information
provides
an
indication
of
the
extent
to
which
the
EAD
TWF
hazard
score
reasonably
represents
the
hazard
for
the
point
source
category
as
a
whole
rather
than
that
of
possibly
atypical
facility(
s).
For
example,
the
Steam
Electric
Power
Generation
point
source
category
is
ranked
first
using
the
EAD
TWF
hazard
score,
yet
greater
than
90
percent
of
the
EAD
TWF
hazard
score
for
this
point
source
category
is
attributed
to
only
one
facility.
In
contrast,
the
Pulp,
Paper,
and
Paperboard
point
source
category
is
ranked
fourth
using
the
EAD
TWF
hazard
score;
90
percent
of
the
EAD
TWF
hazard
score
for
this
point
source
category
is
attributed
to
50
facilities.
RSEIreport_
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wpd
3­
3
Table
3­
1
Ranking
of
Point
Source
Categories
That
Comprise
90%
of
EAD
TWF
Hazard
40
CFR
Part
Point
Source
Category/
SIC
Code
EAD
TWF
Hazard
Ranking
Risk­
Related
Results
Ranking
TRI
Pounds
Ranking
Hazard
Ranking
Modeled
Hazard
Ranking
Number
of
Facilities
Contributing
90%
of
EAD
TWF
Hazarda
423
Steam
Electric
Power
Generation
1
1
13
1
2
1
414
Organic
Chemicals,
Plastics
and
Synthetic
Fibers
2
6
2
2
1
4
429
Timber
Products
Processing
3
36
57
35
42
10
430
Pulp,
Paper,
and
Paperboard
4
12
4
8
10
50
N/
A
SIC
5171:
Petroleum
Bulk
Stations
and
Terminals
5
19
74
28
39
2
419
Petroleum
Refining
6
10
6
7
4
16
aThis
value
represents
the
number
of
facilities
whose
EAD
TWF
hazard
scores,
when
summed,
account
for
90%
of
the
hazard
for
that
point
source
category.
3­
4
RSEIreport_
121203.
wpd
Table
3­
2
provides
additional
relevant
statistics
for
the
top
six
point
source
categories,
such
as
the
total
number
of
facilities
that
comprise
the
point
source
category
(
as
reported
in
the
1997
U.
S.
Economic
Census),
the
total
number
of
facilities
reporting
to
TRI,
the
total
number
of
facilities
reporting
water
discharges
(
direct
or
indirect)
in
TRI,
and
the
number
of
facilities
that
are
assigned
a
EAD
TWF
hazard
score
associated
with
those
water
discharges.
This
table
provides
additional
insight
and
information
to
assist
in
determining
whether
that
result
is
characteristic
of
the
entire
category,
such
as
the
percentage
of
facilities
in
each
point
source
category
reported
water
discharges
and
contribute
to
the
EAD
TWF
hazard
score.
For
example,

for
Steam
Electric
Power
Generation,
only
638
of
6,212
facilities
(
10.3
percent)
in
the
1997
U.
S.

Census
submitted
TRI
reports
in
2000
(
see
Section
2.1
for
a
description
of
who
must
submit
a
TRI
report).
Of
the
638
Steam
Electric
Power
Generation
facilities
reported
to
TRI,
342
(
53.6
percent)
reported
water
discharges.

Finally,
as
discussed
in
Section
2.3,
two
compounds,
PACs
and
dioxin
and
dioxinlike
compounds,
represent
less
than
0.005
percent
of
the
TRI­
reported
pounds
discharged,
but
approximately
93
percent
of
the
total
EAD
TWF
hazard
score
as
a
result
of
the
relatively
high
EAD
TWFs
for
these
compounds.
Accordingly,
the
top
six
point
source
categories
are
comprised
of
one
or
more
individual
facilities
reporting
discharges
of
these
two
compounds.
Further
investigation
is
required
to
determine
whether
discharges
of
these
two
pollutants
are
isolated,

sitespecific
instances
or
representative
of
the
entire
category.
In
addition,
further
investigation
is
required
to
determine
whether
EAD
TWF
hazard
scores
for
these
compounds
provide
a
reasonable
measure
of
actual
discharges
or
are
instead
a
phenomenon
of
TRI
reporting
based
on
pollutant
detection
limits
and/
or
unrealistically
high
assumptions
regarding
the
presence
or
absence
of
pollutants
at
concentrations
less
than
the
detection
limit.
Further
investigation
is
also
required
to
evaluate
whether
the
selected
chemical
(
and
associated
EAD
TWF)
assigned
to
these
two
chemical
compound
categories
was
appropriate
on
an
industry­
specific
basis.
RSEIreport_
121203.
wpd
3­
5
Table
3­
2
Summary
Statistics
for
Point
Source
Categories
That
Comprise
90%
of
EAD
TWF
Hazard
EAD
TWF
Hazard
Rank
Point
Source
Category
b
Number
of
Facilities
Reporting
to
1997
U.
S.
Economic
Census
Facilities
Reporting
to
TRI
(
2000)
Facilities
Reporting
Water
Release
or
Transfer
in
TRI
(
2000)
a
Number
of
Water­

Discharging
Sites
Assigned
EAD
TWF
Hazard
Number
of
Facilities
Percentage
of
Facilities
Number
of
Facilities
Percentage
of
Facilities
1
Steam
Electric
Power
Generation
6,212
638
10.3
342
53.6
342
2
Organic
Chemicals,
Plastics
and
Synthetic
Fibers
1,570
996
63.4
576
57.8
574
3
Timber
Products
Processing
8,940
373
4.2
102
27.3
87
4
Pulp,
Paper,
and
Paperboard
512
328
64.1
232
70.7
230
5
SIC
5171:
Petroleum
Bulk
Stations
and
Terminals
9,104
502
5.5
167
33.3
167
6
Petroleum
Refining
242
183
75.6
136
74.3
136
aThe
number
of
facilities
reporting
a
direct
or
indirect
water
discharge
to
TRI.
This
number
excludes
facilities
with
no
releases,
facilities
with
only
air
and/
or
solids
releases,
or
facilities
that
are
not
required
to
report
due
to
small
size
or
not
exceeding
reporting
thresholds.

bSome
SIC
codes
were
included
in
multiple
point
source
categories.
See
Section
3.0
and
Attachment
C
for
further
information
regarding
EPA's
methodology
to
relate
SIC
codes
to
point
source
categories.
None
of
the
SIC
codes
included
in
the
RSEI
analyses
for
these
top
6
point
source
categories
overlap
with
any
other
point
source
categories.
3­
6
RSEIreport_
121203.
wpd
Section
4.0
presents
additional
items
for
further
consideration
related
to
the
point
source
category
analysis.
These
results
suggest
further
review
of
the
six
top
point
source
categories
and
their
underlying
RSEI
model
results
data
during
the
detailed
screening­
level
investigation
phase.

3.1
Steam
Electric
Power
Generation
(
40
CFR
Part
423)

This
subsection
discusses
the
RSEI
model
output
for
the
Steam
Electric
Power
Generation
point
source
category.
Section
3.1.1
briefly
describes
the
types
of
facilities
that
fall
within
this
point
source
category.
Section
3.1.2
summarizes
the
results
from
the
RSEI
TRI
data
and
discusses
the
top
SIC
codes,
facilities,
and
pollutants
that
contribute
to
the
EAD
TWF
hazard
score.

3.1.1
Industry
Description
The
Steam
Electric
Power
Generation
point
source
category
includes
establishments
primarily
engaged
in
the
generation
of
electric
energy
for
distribution
or
sale
which
results
primarily
from
a
process
utilizing
fossil­
type
fuel
(
coal,
oil,
or
gas)
or
nuclear
fuel
in
conjunction
with
a
thermal
cycle
employing
the
steam
water
system
as
the
thermodynamic
medium.
In
the
United
States,
approximately
half
of
all
electricity
is
generated
using
coal
as
the
energy
source.

Steam
electric
generation
is
by
far
the
Nation's
largest
industrial
water
user
with
approximately
30
to
40
times
the
water
use
of
the
Nation's
second
largest
industrial
water
user,

Chemicals
and
Allied
Products.
Steam
electric
units
require
large
amounts
of
cooling
water
for
steam
condensation
and
efficient
thermal
operation.
Power
plants
use
one
of
two
types
of
noncontact
cooling
water:
a
once­
through
system
or
a
recirculating
cooling
water
system.
The
majority
of
electric
utilities
use
recirculating
cooling
towers.
In
a
once­
through
cooling
water
system,
the
cooling
water
flow
rate
through
the
condenser
is
by
far
the
largest
process
water
flow,

normally
equating
to
about
98
percent
of
the
total
process
water
flow
for
the
entire
unit.
In
recirculating
systems,
cooling
tower
blowdown
(
a
percentage
of
the
recirculated
water
normally
3­
7
RSEIreport_
121203.
wpd
equating
to
30
to
60
percent
of
total
process
water
flow)
is
discharged
regularly
and
additional
fresh
makeup
water
is
treated
and
added
into
the
recirculating
system
to
relieve
the
buildup
of
solids.
Other
major
wastestreams
with
effluent
limitations
include
fly
ash
and
bottom
ash
handling
wastewaters,
coal
pile
runoff,
and
chemical
metals
cleaning
wastes.
The
wastewaters
from
nonchemical
metal
cleaning
wastes
do
not
have
effluent
limitations.
Facilities
also
generate
a
variety
of
low­
volume
wastes
(
e.
g.,
demineralizer
wastes,
boiler
blowdown,
wet
scrubber
pollution
control
systems).

Chemicals
of
concern
in
non­
contact
cooling
water
discharges
include
biocides,

organic
chemicals,
and
trace
metals
(
chromium
and
zinc)
from
biofouling
and
corrosion
control.

Oxidizing
biocides
such
as
chlorine
and
bromine
predominate
in
electric
utilities
because
of
cost,

environmental,
and
efficacy
issues.
At
facilities
with
once­
through
systems,
halogens
support
rapid
biocidal
action,
which
is
critical
to
providing
high
enough
treatment
levels
to
be
effective
while
also
complying
with
a
narrow
time
frame
for
treatment
(
e.
g.,
one
to
two
hours
per
day
as
required
by
NPDES
permits).
At
facilities
with
recirculating
systems,
cooling
tower
blowdown
containing
biocide
is
normally
sent
to
a
discharge
holding
pond,
where
free
available
chlorine
is
consumed
by
other
materials
or
"
deactivated"
based
on
retention
time.
Halogens
and
other
chemicals
(
e.
g.,
peracetic
acid
and
glutaraldehyde)
may
also
be
used
to
control
Zebra
Mussels
and
Asiatic
Clams.

The
1982
ELGs
for
this
point
source
category,
provided
at
40
CFR
423,
are
currently
being
applied
to
utility
steam
electric
facilities
(
discussed
above),
and
potentially
to
nonutility
steam
electric
generators
and
to
utility
and
nonutility
combined
generators.
Nonutility
steam
electric
generators
are
mainly
comprised
of
cogenerators
and
renewable
fuel
burners.

Cogenerators
are
facilities
that
primarily
produce
products
other
than
electricity
but
generate
some
or
all
of
their
own
electricity
requirements
by
operating
plants
producing
both
steam
and
power
(
i.
e.,
cogeneration
plants).
Renewable
fuel
burners
are
facilities
whose
processes
utilize
alternative
fuels
such
as
biomass,
municipal
solid
waste,
or
wood.
Combined
generators
are
facilities
that
use
a
type
of
non­
steam
electric
power
generation
process
comprised
of
a
gas
turbine
followed
by
a
heat
recovery
stream
generator.
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3.1.2
Summary
of
RSEI
TRI
Data
The
Steam
Electric
Power
Generation
Point
Source
Category
applies
to
facilities
in
SIC
Code
4911,
Electric
Services.
However,
within
this
SIC
code,
only
those
facilities
that
combust
coal
and/
or
oil
for
the
purpose
of
generating
electricity
for
distribution
in
commerce
are
required
to
report
to
TRI.
The
1997
U.
S.
Economic
Census
shows
6,212
establishments
engaged
in
operations
under
this
SIC
code.
Of
these,
342
facilities
reported
wastewater
discharges
in
the
TRI
database.
EAD
TWF
hazard
scores
were
assigned
to
all
342
facilities.
Table
3.1­
1
provides
statistics
related
to
the
Steam
Electric
Power
Generation
Point
Source
Category.
Table
3­
2
in
Section
3.1
presents
summary
statistics
for
the
top
six
point
source
categories.

Table
3.1­
1
Summary
Statistics
for
the
Steam
Electric
Power
Generation
Point
Source
Category
(
40
CFR
Part
423)

Rank
Point
Source
Category
Number
of
Facilities
Reporting
to
1997
U.
S.
Economic
Census
Facilities
Reporting
to
TRI
(
2000)
Facilities
Reporting
Water
Release
or
Transfer
in
TRI
(
2000)
a
Number
of
Water­
Discharging
Sites
Assigned
EAD
TWF
Hazard
Score
Number
of
Facilities
Percentage
of
Facilities
Number
of
Facilities
Percentage
of
Facilities
1
Steam
Electric
Power
Generation
6,212
638
10.3%
342
53.6%
342
In
the
2000
TRI
database,
41
chemicals
were
reported
as
being
discharged
to
water
by
facilities
in
this
point
source
category.
Of
these,
40
chemicals
were
assigned
EAD
TWF
hazard
scores.
Discharges
of
PACs,
reported
by
five
facilities,
account
for
97
percent
of
the
EAD
TWF
hazard
score
associated
with
this
category.
Table
3.1­
2
below
lists
the
chemicals
driving
the
EAD
TWF
hazard
score
for
the
Steam
Electric
Power
Generation
Point
Source
Category.
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Table
3.1­
2
Chemical
Summary
Statistics
for
the
Steam
Electric
Power
Generation
Point
Source
Category
(
40
CFR
Part
423)

Chemical
Number
of
Facilities
in
Category
Reporting
Discharge
to
Water
SIC
Codes
in
Category
Reporting
Discharge
to
Water
Percent
of
Category
EAD
TWF
Hazard
Score
Polycyclic
aromatic
compounds
5
4911
97%

The
high
EAD
TWF
hazard
score
associated
with
this
point
source
category
is
due
primarily
to
the
release
of
PACs
from
one
facility.
In
2000,
the
Pepco
Chalk
Point
Generating
Station
(
TRI
Facility
ID
20608CHLKP25100)
in
Aquasco,
Maryland
reported
a
release
to
surface
water
of
9,500
pounds
of
PACs.
This
release
accounts
for
96
percent
of
the
EAD
TWF
hazard
score
for
the
entire
point
source
category.
Further
investigation
of
this
facility's
operations
and
discharges,
as
compared
to
those
of
other
facilities,
is
necessary
to
determine
the
accuracy
of
this
facility's
EAD
TWF
hazard
score.

3.2
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
(
40
CFR
Part
414)

This
subsection
discusses
the
RSEI
model
output
for
the
Organic
Chemicals,

Plastics,
and
Synthetic
Fibers
(
OCPSF)
point
source
category.
Section
3.2.1
briefly
describes
the
types
of
facilities
that
fall
within
this
point
source
category.
Section
3.2.2
summarizes
the
results
from
the
RSEI
TRI
data
and
discusses
the
top
SIC
codes,
facilities,
and
pollutants
that
contribute
to
the
EAD
TWF
hazard
score.

3.2.1
Industry
Description
The
OCPSF
industry
converts
wood
and
fossil
fuel
products
into
intermediate
or
basic
finished
chemicals.
The
applicability
of
the
OCPSF
point
source
category
is
specifically
defined
as
comprised
of
facilities
in
the
following
SIC
codes:
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SIC
2821:
Plastics
materials,
synthetic
resins,
and
non­
vulcanizable
elastomers.
This
industry
produces
thermoplastic
and
thermoset
resins.
Commercially
important
thermoplastic
resins
include
poyethylene,
polyvinyl
chloride,
polypropylene,
and
polystyrene.
Leading
thermosets
in
sales
include
phenolic
resins,
urea
resins,
and
unsaturated
polyester
resins.

SIC
2823:
Cellulosic
manmade
fibers.
Products
from
this
industry
are
formed
by
the
conversion
of
cellulose
(
an
abundant,
naturally­
occurring
organic
compound)
into
a
soluble
derivative,
followed
by
reforming
as
filaments.
Commercially
important
cellulosic
fibers
include
rayon
and
cellulose
acetate.

SIC
2824:
Manmade
organic
fibers,
except
cellulosic.
This
industry
produces
synthetic
fibers
through
polymerization
and
subsequent
fiber
formation
of
synthetic
organic
chemicals
and
refined
petroleum
products.
Nylons,
polyesters,
polyolefins,
and
acrylics
are
some
important
products
of
the
noncellulosic
fiber
industry.

SIC
2865:
Cyclic
organic
crudes
and
intermediates,
and
organic
dyes
and
pigments.
Products
from
this
industry
are
processed
from
petroleum,
natural
gas,
and
coal.
Benzene,
toluene,
xylene,
and
naphthalene
are
a
few
of
the
important
products
produced
by
the
cyclic
crudes
and
intermediates
sector.
Facilities
in
this
sector
are
primarily
located
near
the
Gulf
of
Mexico
(
where
many
petroleum­
based
feedstocks
are
produced)
and
near
downstream
industrial
users
in
the
Northeast
and
Midwest.

SIC
2869:
Industrial
organic
chemicals,
not
elsewhere
classified.
This
is
the
largest
and
most
diverse
sector
of
the
industry.
Facilities
in
this
sector
are
also
primarily
located
near
the
Gulf
of
Mexico
and
in
the
Northeast
and
Midwest.
Important
products
of
this
industry
include:


Aliphatic
and
other
acyclic
organic
chemicals,
such
as
ethylene,
butylene,
and
butadiene;


Acetic,
chloroacetic,
adipic,
formic,
oxalic,
and
tartaric
acids
and
their
metallic
salts;


Chloral,
formaldehyde,
and
methylamine;


Solvents,
such
as
amyl,
butyl,
and
ethyl
alcohols;
methanol;
amyl,
butyl,
and
ethyl
acetates;
ethyl
ether,
ethylene
glycol
ether,
and
diethylene
glycol
ether;
acetone;
carbon
disulfide;
and
chlorinated
solvents,
such
as
carbon
tetrachloride,
perchloroethylene,
and
trichloroethylene;


Polyhydric
alcohols,
such
as
ethylene
glycol,
sorbitol,
pentaerythritol,
and
synthetic
glycerin;
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Synthetic
perfume
and
flavoring
materials,
such
as
coumarin,
methyl
salicylate,
saccharin,
citral,
citronellal,
synthetic
geraniol,
ionone,
terpineol,
and
synthetic
vanillin;


Rubber
processing
chemicals,
such
as
accelerators
and
antioxidants,
both
cyclic
and
acyclic;


Plasticizers,
both
cyclic
and
acyclic,
such
as
esters
of
phosphoric
acid,
phthalic
anhydride,
adipic
acid,
lauric
acid,
oleic
acid,
sebacic
acid,
and
stearic
acid;


Synthetic
tanning
agents,
such
as
naphthalene
sulfonic
acid
condensates;


Chemical
warfare
gases;
and

Esters,
amines,
etc.,
of
polyhydric
alcohols
and
fatty
and
other
acids.

These
industries
are
subject
to
the
requirements
of
the
EPA
Effluent
Guidelines
and
Standards
for
OCPSF,
40
CFR
Part
414,
established
in
1987
and
revised
in
1993.
This
effluent
guideline
separates
the
OCPSF
industry
into
eight
product
groups
and
sets
separate
conventional
pollutant
(
BOD
5,
TSS,
pH)
limitations
for
each
group.
In
addition,
the
regulation
establishes
separate
toxic
pollutant
ELGs
for:
direct
discharge
point
sources
that
use
end­
of­
pipe
biological
treatment;
direct
discharge
point
sources
that
do
not
use
end­
of­
pipe
biological
treatment;
and
indirect
discharge
point
sources.

As
a
result
of
the
wide
range
of
processes
used
and
products
produced,
a
variety
of
pollutants
are
found
in
the
wastewaters
of
the
organic
chemical
industry,
including
conventional
pollutants,
toxic
priority
pollutants,
and
nonconventional
pollutants.
Many
of
the
toxic
and
nonconventional
pollutants
found
in
the
wastewaters
of
this
industry
are
organic
compounds
produced
by
the
industry
for
sale,
while
others
are
by­
products
of
the
production
processes.
Since
there
is
generally
more
than
one
reaction
pathway
available
to
the
reactants
of
chemical
reactions,
undesirable
by­
products
are
often
produced
resulting
in
a
mixture
of
unreacted
raw
materials,
products,
and
by­
products.
The
processes
used
to
separate
the
desired
product
from
this
mixture
generate
additional
residues
with
little
or
no
commercial
value
and
that
end
up
in
process
wastewater,
air
emissions,
and
chemical
wastes.
The
combination
of
raw
materials
and
production
processes
used
at
a
facility
determine
the
characteristics
of
the
wastewater
generated.
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Potential
sources
of
pollutant
discharges
in
wastewater
include
equipment
and
product
washing,

lab
samples,
surplus
chemicals,
spent/
used
solvents,
waste
oils/
lubricants,
seal
flushes,
scrubber
blowdown,
cooling
water,
steam
jets,
vacuum
pumps,
and
leaks
and
spills.

3.2.2
Summary
of
RSEI
TRI
Data
The
1997
U.
S.
Economic
Census
shows
1,570
establishments
engaged
in
operations
under
one
of
the
six
SIC
codes
related
to
OCPSF.
Of
these,
576
facilities
reported
wastewater
discharges
in
the
TRI
database.
EAD
TWF
hazard
scores
were
assigned
to
574
of
these
576
facilities.
Table
3.2­
1
provides
statistics
related
to
the
OCPSF
Point
Source
Category.

Table
3­
2
in
Section
3.1
presents
summary
statistics
for
the
top
six
point
source
categories.

Table
3.2­
1
Summary
Statistics
for
the
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
Point
Source
Category
(
40
CFR
Part
414)

Rank
Point
Source
Category
Number
of
Facilities
Reporting
to
1997
U.
S.
Economic
Census
Facilities
Reporting
to
TRI
(
2000)
Facilities
Reporting
Water
Release
or
Transfer
in
TRI
(
2000)
a
Number
of
Water­
Discharging
Sites
Assigned
EAD
TWF
Hazard
Scores
Number
of
Facilities
Percentage
of
Facilities
Number
of
Facilities
Percentage
of
Facilities
2
Organic
chemicals,
plastics
and
synthetic
fibers
1,570
996
63.4%
576
57.8%
574
In
the
2000
TRI
database,
240
chemicals
were
reported
as
being
discharged
to
water
by
facilities
in
the
OCPSF
Point
Source
Category.
Of
these,
205
chemicals
were
assigned
EAD
TWF
hazard
scores.
Dioxin
and
dioxin­
like
compounds,
reported
by
16
facilities,
accounts
for
69
percent
of
the
EAD
TWF
hazard
scores
associated
with
this
category.
PACs,
reported
by
six
facilities,
accounts
for
27
percent
of
the
EAD
TWF
hazard.

The
OCPSF
industry
generates
wastewater
containing
organic
compounds,

nutrients,
metals,
and
cyanide.
Pollutants
of
concern
include
volatile
organic
compounds,
semi­
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volatile
organic
compounds,
alcohols,
PAHs,
nitrate
and
ammonia
nitrogen,
and
metals.
Metals
include
chromium,
cobalt,
copper,
lead,
nickel,
zinc,
and
total
cyanide.
Table
3.2­
2
below
lists
the
chemicals
driving
the
EAD
TWF
hazard
scores
for
OCPSF.

Table
3.2­
2
Chemical
Summary
Statistics
for
the
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
Point
Source
Category
(
40
CFR
Part
414)

Chemical
Number
of
Facilities
in
Category
Reporting
Discharge
to
Water
SIC
Codes
in
Category
Reporting
Discharge
to
Water
Percent
of
Category
EAD
TWF
Hazard
Score
Dioxin
and
dioxin­
like
compounds
16
2821,
2869
69%

Polycyclic
aromatic
compounds
6
2821,
2865,
2869
27%

SIC
Code
2869
(
Industrial
organic
chemicals,
not
elsewhere
classified
(
n.
e.
c.))

accounts
for
72
percent
of
the
EAD
TWF
hazard
score
for
the
OCPSF
Point
Source
Category.

This
is
due
primarily
to
the
releases
of
dioxin­
like
compounds
from
two
facilities.
The
Dow
Chemical
Co.
Louisiana
Division
facility
(
TRI
Facility
ID
70765THDWCHIGHW)
in
Plaquemine,

Louisiana
reported
a
release
to
surface
water
of
1.64
pounds
of
dioxin­
like
compounds.
The
Dow
Chemical
Co.
Freeport
facility
(
TRI
Facility
ID
77541THDWCBUILD)
in
Freeport,
Texas
reported
a
release
to
surface
water
of
1.24
pounds
of
dioxin­
like
compounds.
These
two
chemical
releases
account
for
61
percent
of
the
EAD
TWF
hazard
score
for
the
entire
point
source
category.
Further
investigation
of
these
facilities'
operations
and
discharges,
as
compared
to
those
of
other
facilities,
is
necessary
to
determine
the
accuracy
of
their
EAD
TWF
hazard
scores.

SIC
Code
2821
(
Plastics
materials,
synthetic
resins,
and
non­
vulcanizable
elastomers)
accounts
for
25
percent
of
the
EAD
TWF
hazard
score
for
the
OCPSF
Point
Source
Category.
This
is
due
primarily
to
the
release
of
PACs
from
one
facility.
The
Exxon
Chemical
Baton
Rouge
Chemical
Plant
(
TRI
Facility
ID
70805XXNCH4999S)
in
Baton
Rouge,
Louisiana
3­
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reported
a
release
to
surface
water
of
1,801
pounds
of
PACs.
This
chemical
release
accounts
for
24
percent
of
the
EAD
TWF
hazard
score
for
the
entire
point
source
category.

3.3
Timber
Products
Processing
(
40
CFR
Part
429)

This
subsection
discusses
the
RSEI
model
output
for
the
Timber
Products
Processing
point
source
category.
Section
3.3.1
briefly
describes
the
types
of
facilities
that
fall
within
this
point
source
category.
Section
3.3.2
summarizes
the
results
from
the
RSEI
TRI
data
and
discusses
the
top
SIC
codes,
facilities,
and
pollutants
that
contribute
to
the
EAD
TWF
hazard
score.

3.3.1
Industry
Description
The
timber
products
processing
point
source
category
includes
facilities
that
conduct
any
timber
products
processing
operations,
as
well
as
the
production
of
insulation
board
where
wood
is
a
major
raw
material.
Timber
products
processing
operations
covered
by
the
ELGs
include
barking,
veneer
manufacturing,
plywood
production,
hardboard
production,
wood
preserving,
wet
log
or
roundwood
storage,
log
washing,
sawing
and
planing,
finishing,
particle
board
manufacturing,
insulation
board
production,
and
furniture
and
fixture
production.
Listed
below
are
the
applicable
SIC
codes
included
in
the
RSEI
analysis
for
this
point
source
category:


2421
­
Sawmills
and
planing
mills,
general;


2435
­
Hardwood
veneer
and
plywood;


2436
­
Softwood
veneer
and
plywood;


2491
­
Wood
preserving;


2493
­
Reconstituted
wood
products;
and

2499
­
Wood
products,
n.
e.
c.

For
most
industry
subcategories,
applicable
effluent
limitations
specify
either
zero
discharge
or
include
only
the
conventional
pollutants
BOD
5,
TSS,
and/
or
pH.
However,
the
wood
preserving
subcategories
include
effluent
limitations
for
oil
and
grease,
COD,
and
the
toxic
pollutants
phenols,
copper,
chromium,
and/
or
arsenic.
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The
wood
preserving
process
consists
of
two
basic
processing
steps:
(
1)
reducing
the
moisture
content
of
the
wood
by
seasoning,
kiln
drying,
steaming,
or
other
processes,
and
(
2)

impregnating
the
wood
with
chemicals
to
impart
insecticidal,
fungicidal,
or
fire
resistant
properties
to
the
wood.
The
major
types
of
preservatives
used
in
wood
preserving
are
creosote,

pentachlorophenol
(
PCP),
and
various
formulations
of
water­
soluble
inorganic
chemicals,
the
most
common
of
which
are
the
salts
of
copper,
chromium,
and
arsenic
(
chromated
copper
arsenate
or
CCA).
Fire
retardants
are
formulations
of
salts,
the
principal
ones
being
borates,

phosphates,
and
ammonium
compounds.
Sources
of
process
wastewater
include
the
wood
drying
processes,
condensers
(
barometric­
and
surface­
type),
barometric
cooling
water,
and
coil
condensate.
Toxic
pollutants
in
wastewaters
from
plants
that
treat
with
organic
preservatives
are
principally
volatile
organic
solvents
such
as
benzene
and
toluene,
and
the
PACs
of
creosote,

including
anthracene,
pyrene,
and
phenanthrene,
that
are
contained
in
the
entrained
oils.
Phenol
and
phenol
derivatives
are
also
found
in
these
wastewaters.
PCP
is
found
in
wastewaters
from
plants
that
use
this
preservative,
and
the
heavy
metals
copper,
chromium,
and
arsenic
are
found
in
wastewaters
from
plants
that
use
CCA.

PCP
was
widely
used
as
a
pesticide
and
wood
preservative;
however,
since
1984,

the
purchase
and
use
of
PCP
has
been
restricted
to
certified
applicators.
It
is
no
longer
available
to
the
general
public,
but
is
still
used
industrially
as
a
wood
preservative
for
utility
poles,
railroad
ties,
and
wharf
pilings.
Creosote
is
commonly
used
to
treat
wood
in
building
fences,
bridges,
or
railroad
tracks,
or
installing
telephone
poles.

On
February
12,
2002,
EPA
announced
a
voluntary
decision
by
industry
to
move
consumer
use
of
treated
lumber
products
away
from
a
variety
of
pressure­
treated
wood
that
contains
arsenic
by
December
31,
2003,
in
favor
of
new
alternative
wood
preservatives.
This
transition
affects
virtually
all
residential
uses
of
wood
treated
with
CCA,
including
wood
used
in
play
structures,
decks,
picnic
tables,
landscaping
timbers,
residential
fencing,
patios
and
walkways/
boardwalks.
As
of
January
1,
2004,
EPA
will
not
allow
CCA
products
to
be
used
to
treat
wood
intended
for
any
of
these
residential
uses.
Although
the
Agency
has
not
concluded
that
there
is
unreasonable
risk
to
the
public
from
these
products,
it
has
been
determined
that
any
reduction
in
exposure
to
arsenic
is
desirable.
(
See
document:
Response
to
Requests
to
Cancel
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Certain
Chromated
Copper
Arsenate
(
CCA)
Wood
Preservative
Products
and
Amendments
to
Terminate
Certain
Uses
of
other
CCA
Products
,
Federal
Register:
April
9,
2003
(
Volume
68,

Number
68)

3.3.2
Summary
of
RSEI
TRI
Data
As
shown
in
Table
3.3­
1,
the
1997
U.
S.
Economic
Census
reports
8,940
facilities
engaged
in
the
production
of
timber
products
in
the
United
States.
Of
these,
102
facilities
reported
wastewater
discharges
in
the
2000
TRI
database,
of
which
87
facilities
were
assigned
EAD
TWF
hazard
scores.
Table
3­
2
in
Section
3.1
presents
summary
statistics
for
the
top
6
point
source
categories.

Table
3.3­
1
Summary
Statistics
for
the
Timber
Products
Processing
Point
Source
Category
(
40
CFR
Part
429)

EAD
TWF
Hazard
Rank
Point
Source
Category
Number
of
Facilities
Reporting
to
1997
U.
S.
Economic
Census
Facilities
Reporting
to
TRI
(
2000)
Facilities
Reporting
Water
Release
or
Transfer
in
TRI
(
2000)
a
Number
of
Water­
Discharging
Sites
Assigned
EAD
TWF
Hazard
Score
Number
of
Facilities
Percentage
of
Facilities
Number
of
Facilities
Percentag
e
of
Facilities
3
Timber
Products
Processing
8,940
373
4.2
102
27.3
87
aThe
number
of
facilities
reporting
a
direct
or
indirect
water
discharge
to
TRI.
This
number
excludes
facilities
with
no
releases,
facilities
with
only
air
and/
or
solids
releases,
or
facilities
that
are
not
required
to
report
due
to
small
size
or
not
exceeding
reporting
thresholds.

The
2000
TRI
database
reports
24
chemicals
discharged
in
this
industry.
Of
these,

only
1
chemical,
creosote,
was
not
assigned
an
EAD
TWF
hazard
score.
Dioxin
and
dioxin­
like
compounds,
reported
by
25
facilities,
accounts
for
nearly
97
percent
of
the
EAD
TWF
hazard
score
associated
with
this
category.
PACs,
reported
by
4
facilities,
accounts
for
approximately
3
percent
of
the
EAD
TWF
hazard
score.
Table
3.3­
2
summarizes
the
chemicals
that
comprise
the
majority
of
the
EAD
TWF
hazard.
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Table
3.3­
2
Chemical
Summary
Statistics
for
the
Timber
Products
Processing
Point
Source
Category
(
40
CFR
Part
429)

Chemical
Number
of
Facilities
in
Category
Reporting
Discharge
to
Water
SIC
Codes
in
Category
Reporting
Discharge
to
Water
Percent
of
Category
EAD
TWF
Hazard
Score
Dioxins
and
dioxin­
like
compounds
25
2491,
2499
96.6%

Polycyclic
aromatic
compounds
4
2491
3.2%

SIC
Code
2491
comprises
99.9
percent
of
the
total
EAD
TWF
hazard
score
for
the
timber
products
processing
point
source
category.
SIC
Code
2491
is
comprised
of
75
facilities,
of
which
10
facilities
comprise
greater
than
90
percent
of
the
EAD
TWF
hazard
score
for
both
this
SIC
code
and
the
entire
point
source
category.
The
single
facility
with
the
greatest
EAD
TWF
hazard
score,
Koppers
Inds.
Inc.,
Granada,
MS,
comprises
31.1
percent
of
the
total
EAD
TWF
hazard
score
for
the
entire
point
source
category.
The
facility
with
the
second
highest
EAD
TWF
hazard
score
for
the
category
is
Electric
Mills
Wood
Preserving,
Scooba,
MS,

comprising
13.2
percent
of
the
total
EAD
TWF
hazard
score.
Further
investigation
of
these
facilities'
operations
and
discharges,
as
compared
to
those
of
other
facilities,
is
necessary
to
determine
the
accuracy
of
their
EAD
TWF
hazard
scores.

3.4
Pulp,
Paper,
and
Paperboard
(
40
CFR
Part
430)

This
subsection
discusses
the
RSEI
model
output
for
the
Pulp,
Paper,
and
Paperboard
point
source
category.
Section
3.4.1
briefly
describes
the
types
of
facilities
that
fall
within
this
point
source
category.
Section
3.4.2
summarizes
the
results
from
the
RSEI
TRI
data
and
discusses
the
top
SIC
codes,
facilities,
and
pollutants
that
contribute
to
the
EAD
TWF
hazard
score.
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3.4.1
Industry
Description
Facilities
that
fall
in
the
pulp,
paper,
and
paperboard
point
source
category
manufacture
pulp,
paper,
and
paperboard
as
their
major
products
shipped.
These
facilities
include
market
pulp
mills
(
mills
that
manufacture
and
ship
pulp);
integrated
mills
(
mills
that
manufacture
both
pulp
and
paper
or
paperboard);
and
nonintegrated
mills
(
mills
that
manufacture
paper
or
paperboard
from
pulp
manufactured
by
other
mills
or
from
secondary
fiber).
Discharges
from
pulp,
paper,
and
paperboard
manufacturing
operations
are
covered
under
40
CFR
430,
updated
in
April
1998.
Listed
below
are
the
applicable
SIC
codes
included
in
the
RSEI
analysis
for
this
point
source
category:


2611
­
Pulp
mills
(
market
pulp
mills);


2621
­
Paper
mills
(
integrated
and
nonintegrated
paper
mills);
and

2631
­
Paperboard
mills
(
integrated
and
nonintegrated
paperboard
mills).

Pulp
manufacturing
operations
generate
wastewaters
with
high
concentrations
of
biochemical
oxygen
demand,
chemical
oxygen
demand,
color,
and
TSS.
Pulp
bleaching
operations
generate
wastewaters
containing
these
pollutants
and
also
toxic
chlorinated
pollutants.

The
toxic
chlorinated
pollutants
include
dioxin
and
dioxin­
like
compounds
(
including
furans),

chloroform,
and
chlorinated
phenolic
compounds.
Compliance
with
EPA's
BAT
effluent
limitations
guidelines
promulgated
in
April
1998
will
effectively
eliminate
the
discharge
of
these
toxic
chlorinated
pollutants.
These
guidelines
apply
to
about
100
facilities
in
the
pulp,
paper,
and
paperboard
manufacturing
industry.
Pulp
mills
treat
their
wastewater
with
biological
treatment,

either
the
activated
sludge
process,
aerated
stabilization
basins,
or
both.
Integrated
mills
will
also
generate
the
pollutants
listed
above
during
onsite
pulp
manufacturing,
but
will
also
generate
wastewaters
from
paper
or
paperboard
finishing
operations,
such
as
surface
treatments
(
e.
g.,

external
sizing
or
coating),
and
super
calendaring,
which
generate
the
conventional
pollutants
BOD
5
and
TSS.
Nonintegrated
mills
that
deink
secondary
fibers
(
deink
mills)
typically
do
not
bleach
their
pulp;
however,
those
that
do
bleach
secondary
fiber
with
hypochlorite
may
generate
wastewaters
containing
chloroform.
An
EPA
sampling
program
did
not
find
dioxins
in
deink
mill
discharges.
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3.4.2
Summary
of
RSEI
TRI
Data
As
shown
in
Table
3.4­
1,
the
1997
U.
S.
Economic
Census
reports
512
facilities
engaged
in
the
production
of
pulp,
paper,
and
paperboard
in
the
United
States.
Of
these,
232
facilities
reported
wastewater
discharges
in
the
2000
TRI
database,
of
which
230
facilities
were
assigned
EAD
TWF
hazard
scores.
Table
3­
2
in
Section
3.1
presents
summary
statistics
for
the
top
6
point
source
categories.

Table
3.4­
1
Summary
Statistics
for
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
(
40
CFR
Part
430)

EAD
TWF
Hazard
Rank
Point
Source
Category
Number
of
Facilities
Reporting
to
1997
U.
S.
Economic
Census
Facilities
Reporting
to
TRI
(
2000)
Facilities
Reporting
Water
Release
or
Transfer
in
TRI
(
2000)
a
Number
of
Water­
Discharging
Sites
Assigned
EAD
TWF
Hazard
Score
Number
of
Facilities
Percentage
of
Facilities
Number
of
Facilities
Percentag
e
of
Facilities
4
Pulp,
Paper,
and
Paperboard
512
328
64.1
232
70.7
230
aThe
number
of
facilities
reporting
a
direct
or
indirect
water
discharge
to
TRI.
This
number
excludes
facilities
with
no
releases,
facilities
with
only
air
and/
or
solids
releases,
or
facilities
that
are
not
required
to
report
due
to
small
size
or
not
exceeding
reporting
thresholds.

The
2000
TRI
database
reports
49
chemicals
discharged
in
this
industry.
Of
these,

only
2
chemicals,
C.
I.
Direct
Blue
218
and
sulfuric
acid,
were
not
assigned
an
EAD
TWF
hazard
score.
PACs,
reported
by
35
facilities,
account
for
approximately
53
percent
of
the
EAD
TWF
hazard
score
associated
with
this
category.
Dioxin
and
dioxin­
like
compounds,
reported
by
81
facilities,
account
for
approximately
39
percent
of
the
EAD
TWF
hazard
score.
Table
3.4­
2
summarizes
the
chemicals
that
comprise
the
majority
of
the
EAD
TWF
hazard.
3­
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Table
3.4­
2
Chemical
Summary
Statistics
for
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
(
40
CFR
Part
430)

Chemical
Number
of
Facilities
in
Category
Reporting
Discharge
to
Water
SIC
Codes
in
Category
Reporting
Discharge
to
Water
Percent
of
Category
EAD
TWF
Hazard
Polycyclic
aromatic
compounds
35
2611,
2621,
and
2631
52.9%

Dioxins
and
dioxin­
like
compounds
81
2611,
2621,
and
2631
39.1%

SIC
Code
2611
comprises
53.6
percent
of
the
total
EAD
TWF
hazard
score
for
the
pulp,
paper,
and
paperboard
point
source
category.
SIC
Code
2621
comprises
21.6
percent
of
the
hazard,
and
SIC
Code
2631
comprises
24.9
percent
of
the
hazard.
Fifty
of
the
232
facilities
that
reported
water
discharges
compose
greater
than
90
percent
of
the
EAD
TWF
hazard
score
for
the
entire
point
source
category.
The
single
facility
with
the
greatest
EAD
TWF
hazard
result,

Stone
Container
Corp,
Florence,
SC,
comprises
13.2
percent
of
the
total
EAD
TWF
hazard
for
the
entire
point
source
category.

3.5
SIC
Code
5171:
Petroleum
Bulk
Stations
and
Terminals
This
subsection
discusses
the
RSEI
model
output
for
the
Petroleum
Bulk
Stations
and
Terminals
(
PBST)
industry.
Section
3.5.1
briefly
describes
the
types
of
facilities
that
fall
within
this
SIC
code.
Section
3.5.2
summarizes
the
results
from
the
RSEI
TRI
data
and
discusses
the
top
facilities
and
pollutants
that
contribute
to
the
EAD
TWF
hazard
result.

3.5.1
Industry
Description
The
PBST
industry
comprises
establishments
primarily
engaged
in
the
wholesale
distribution
of
crude
petroleum
and
petroleum
products
from
bulk
liquid
storage
facilities.

Petroleum
products
handled
by
PBSTs
include
crude
oil,
gasoline,
aviation
gasoline,
jet
fuel
(
JP­

4),
diesel
fuel,
fuel
oil,
kerosene,
naphtha,
and
lubricating
oils.
As
specified
by
SIC
Code
5171,
3­
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the
bulk
liquid
storage
capacity
at
these
establishments
meets
or
exceeds
10,000
gallons.
This
industry
is
not
included
in
any
existing
point
source
category.

The
main
function
of
PBSTs
is
to
collect,
store,
and
distribute
product
within
the
petroleum
industry.
PBSTs
may
also
perform
the
following
processes:
tank
cleaning,
vehicle
and
equipment
washing
and
maintenance,
hydrostatic
testing,
product
heating,
and
blending
operations
(
i.
e.,
adding
additives
to
petroleum
products).
The
product
is
collected
from
refineries
or
preliminary
gathering
stations
and
terminals
by
pipeline,
water
transport,
or
rail
transport.

PBSTs
store
the
product
in
above
ground
storage
tanks
until
distribution
by
tank
trucks
to
service
stations
or
other
industrial
and
commercial
operations.

PBST
facilities
handle
several
different
types
of
wastewater,
including
stormwater,

tank
bottom
water,
washing
and
maintenance
wastewater,
hydrostatic
testing
wastewater,

wastewater
from
soil
and
groundwater
remediation,
and
wastewater
from
pollution
prevention
practices,
including
vapor
recovery
systems.
Stormwater
runs
over
the
facility
yard,
roofs,
and
drives;
seeps
into
floating
roof
product
tanks;
accumulates
in
concrete
or
soil
tank
basins
designed
to
collect
stormwater
and
contain
accidental
spills
or
contaminated
tank
bottom
water;
contacts
the
vehicle
loading/
unloading
area;
and
flows
into
vehicle
and
equipment
washing
and
maintenance
areas.
Tank
bottom
water
is
a
combination
of
stormwater
that
has
seeped
into
the
tank,
condensed
humidity
from
air
pumped
into
the
tank
during
product
removal,
condensed
humidity
from
tank
breathing
that
occurs
during
changes
in
weather
and
climate,
and
entrained
product
water
from
the
refineries.
Washing
and
maintenance
wastewater
(
including
washing
of
loading/
unloading
racks)
originates
as
fresh
water,
but
becomes
wastewater
after
contact
with
surfactants
and
other
cleaning
products.
Fresh
water
is
also
used
in
on­
site
lavatories
and
for
hydrostatic
testing.
If
a
site
has
contaminated
soil
or
groundwater,
practices
such
as
soil
washing
and
groundwater
pump
and
treat
generate
wastewater.
Finally,
pollution
control
devices
such
as
vapor
recovery
systems
may
generate
wastewater
while
removing
pollutants
from
other
media
(
e.
g.,
air).

PBST
wastewaters
generally
contain
oil
and
grease,
volatile
and
semivolatile
organic
compounds,
and
oxygenated
fuel
additives.
The
volume
of
wastewater
requiring
3­
22
RSEIreport_
121203.
wpd
treatment
prior
to
discharge
at
PBSTs
varies
depending
on
the
number
of
storage
tanks
at
the
facility,
annual
rainfall
amounts,
and
the
amount
of
contaminated
groundwater
(
if
any)
being
removed.

3.5.2
Summary
of
RSEI
TRI
Data
The
1997
U.
S.
Economic
Census
shows
9,104
establishments
engaged
in
operations
under
SIC
Code
5171.
Of
these,
167
facilities
reported
wastewater
discharges
in
the
TRI
database.
EAD
TWF
hazard
scores
were
assigned
to
all
167
facilities.
Table
3.5­
1
provides
statistics
related
to
the
PBST
industry.
Table
3­
2
in
Section
3.1
presents
summary
statistics
for
the
top
six
point
source
categories.

Table
3.5­
1
Summary
Statistics
for
SIC
Code
5171:
Petroleum
Bulk
Stations
and
Terminals
Rank
Point
Source
Category
Number
of
Facilities
Reporting
to
1997
U.
S.
Economic
Census
Facilities
Reporting
to
TRI
(
2000)
Facilities
Reporting
Water
Release
or
Transfer
in
TRI
(
2000)
a
Number
of
Water­
Discharging
Sites
Assigned
EAD
TWF
Hazard
Score
Number
of
Facilities
Percentage
of
Facilities
Number
of
Facilities
Percentage
of
Facilities
5
SIC
5171:
Petroleum
Bulk
Stations
and
Terminals
9,104
502
5.5%
167
33.3%
167
In
the
2000
TRI
database,
23
chemicals
were
reported
as
being
discharged
to
water
by
facilities
in
the
PBST
industry.
All
23
chemicals
were
assigned
EAD
TWF
hazard
scores.
Discharges
of
PACs,
reported
by
six
facilities,
account
for
99.99
percent
of
the
EAD
TWF
hazard
score
associated
with
this
category.

Table
3.5­
2
below
lists
the
chemicals
driving
the
EAD
TWF
hazard
score
for
the
PBST
industry.
3­
23
RSEIreport_
121203.
wpd
Table
3.5­
2
Chemical
Summary
Statistics
for
SIC
Code
5171:
Petroleum
Bulk
Stations
and
Terminals
Chemical
Number
of
Facilities
in
Category
Reporting
Discharge
to
Water
SIC
Codes
in
Category
Reporting
Discharge
to
Water
Percent
of
Category
EAD
TWF
Hazard
Polycyclic
aromatic
compounds
6
5171
99.991%

The
high
EAD
TWF
hazard
score
associated
with
this
industry
is
due
primarily
to
the
release
of
PACs
from
two
facilities.
In
2000,
the
Global
Revco
Terminal
facility
(
TRI
Facility
ID
01843BFGDRONEJA)
in
Revere,
Massachusetts
reported
a
release
to
surface
water
of
370
pounds
of
PACs.
This
release
accounts
for
53
percent
of
the
EAD
TWF
hazard
score
for
the
entire
industry.
The
Chelsea
Sandwich
facility
(
TRI
Facility
ID
02150CHLSS11BRO)
in
Chelsea,

Massachusetts
reported
a
release
to
surface
water
of
293
pounds
of
PACs.
This
release
accounts
for
42
percent
of
the
EAD
TWF
hazard
score
for
the
entire
industry.
Further
investigation
of
these
facilities'
operations
and
discharges,
as
compared
to
those
of
other
facilities,
is
necessary
to
determine
the
accuracy
of
their
EAD
TWF
hazard
scores.

3.6
Petroleum
Refining
(
40
CFR
Part
419)

This
subsection
discusses
the
RSEI
model
output
for
the
Petroleum
Refining
point
source
category.
Section
3.6.1
briefly
describes
the
types
of
facilities
that
fall
within
this
point
source
category.
Section
3.6.2
summarizes
the
results
from
the
RSEI
TRI
data
and
discusses
the
top
SIC
codes,
facilities,
and
pollutants
that
contribute
to
the
EAD
TWF
hazard
score.

3.6.1
Industry
Description
The
Petroleum
Refining
point
source
category
comprises
establishments
that
primarily
manufacture
fuels
(
motor
gasoline,
diesel
and
distillate
fuel
oil,
liquefied
petroleum
gas,

jet
fuel,
residual
fuel
oil,
and
kerosene),
finished
nonfuel
products
(
solvents,
lubricating
oils,
3­
24
RSEIreport_
121203.
wpd
greases,
petroleum
wax,
petroleum
jelly,
asphalt,
and
coke),
and
chemical
industry
feedstocks
(
naphtha,
methane,
ethane,
propane,
butane,
ethylene,
propylene,
butylenes,
butadiene,
benzene,

toluene,
and
xylene)
from
the
physical,
thermal,
and
chemical
separation
of
crude
oil
into
its
major
distillation
fractions
which
are
then
further
processed
through
a
series
of
separation
and
conversion
steps
into
finished
petroleum
products.
In
general,
the
major
petroleum
refinery
products
can
be
classified
into
one
of
four
groups,
based
on
physical
characteristics:

Low­
Boiling
Products.
These
products
include
compounds
that
are
gas
at
ambient
temperatures
and
pressures:
methane,
ethane,
propane,
butane,
and
corresponding
olefins.

Gasoline.
Gasolines
are
mixtures
of
hydrocarbons
having
typical
boiling
ranges
from
38
to
205

C.
Gasoline
components
include
light
straight­
run
gasoline
or
isomerate,

catalytic
reformate,
catalytically
cracked
gasoline,
hydrocracked
gasoline,
polymer
gasoline,

alkylate,
 
butane,
and
additives
such
as
methyl
tertiary
butyl
ether
(
MTBE),
ethyl
tertiary
butyl
ether
(
ETBE),
tertiary
amyl
methyl
either
(
TAME),
and
ethanol.

Distillate
Fuels.
Distillate
fuels
include
jet
or
turbine
fuels,
diesel
fuels,
and
heating
oils,
all
of
which
are
blended
from
a
variety
of
refinery
streams
to
meet
specifications.

Diesel
fuels
include
automotive
diesel
fuels
and
railroad
diesel
fuels.

Residual
Fuel
Oils.
Residual
fuel
oil
consists
of
the
heaviest
fractions
of
the
crude
oil,
which
is
generally
the
fractionating
tower
bottoms
from
vacuum
distillation.
Residual
fuel
oil
is
generally
considered
a
byproduct
of
petroleum
refineries.

Petroleum
refinery
processes
can
be
grouped
into
three
categories:
the
initial
crude
preparation
and
distillation
operations;
downstream
separation,
combination,
and
reshaping
operations;
and
supporting
operations
(
e.
g.,
wastewater
treatment,
sulfur
recovery,
and
heat
exchanger
cleaning).
Four
types
of
wastewater
are
produced:
surface
water
runoff,
cooling
water,
process
water,
and
sanitary
wastewater.
Surface
water
runoff
is
intermittent
and
contains
constituents
from
spills
to
the
surface,
leaks
in
equipment,
and
any
materials
that
may
have
3­
25
RSEIreport_
121203.
wpd
collected
in
drains.
Runoff
surface
water
also
includes
water
coming
from
crude
and
product
storage
tank
roof
drains.
Cooling
water
is
typically
does
not
come
into
direct
contact
with
process
oil
streams,
but
may
contain
chemical
additives
and
antifouling
biocides.
Process
wastewaters
are
generated
from
several
of
the
petroleum
refining
processes,
including
desalting
crude
oil,
steam
stripping
operations,
pump
gland
cooling,
product
refractionator
reflux
drum
drains,
and
boiler
blowdown.
Because
process
water
often
comes
into
direct
contact
with
oil,
it
is
usually
highly
contaminated.
Process
wastewater
generated
from
refineries
typically
contains
hydrogen
sulfide,
ammonia,
oil
and
grease,
suspended
solids,
chemical
oxygen
demand,

biochemical
oxygen
demand,
and
organic
chemicals.
Process
wastewater
from
desalting
operations
may
also
contain
low
levels
of
metals.

3.6.2
Summary
of
RSEI
TRI
Data
The
Petroleum
Refining
Point
Source
Category
applies
to
facilities
in
SIC
Code
2911,
Petroleum
Refining.
The
1997
U.
S.
Economic
Census
shows
242
establishments
engaged
in
operations
under
this
SIC
code.
Of
these,
136
facilities
reported
wastewater
discharges
in
the
TRI
database.
EAD
TWF
hazard
scores
were
assigned
to
all
136
facilities.
Table
3.6­
1
provides
statistics
related
to
the
Petroleum
Refining
Point
Source
Category.
Table
3­
2
in
Section
3.1
presents
summary
statistics
for
the
top
six
point
source
categories.

Table
3.6­
1
Summary
Statistics
for
the
Petroleum
Refining
Point
Source
Category
(
40
CFR
Part
419)

Rank
Point
Source
Category
Number
of
Facilities
Reporting
to
1997
U.
S.
Economic
Census
Facilities
Reporting
to
TRI
(
2000)
Facilities
Reporting
Water
Release
or
Transfer
in
TRI
(
2000)
a
Number
of
Water­
Discharging
Sites
Assigned
EAD
TWF
Hazard
Score
Number
of
Facilities
Percentage
of
Facilities
Number
of
Facilities
Percentage
of
Facilities
6
Petroleum
Refining
242
183
75.6%
136
74.3%
136
3­
26
RSEIreport_
121203.
wpd
In
the
2000
TRI
database,
82
chemicals
were
reported
as
being
discharged
to
water
by
facilities
in
this
point
source
category.
Of
these,
78
chemicals
were
assigned
EAD
TWF
hazard
scores.
Discharges
of
PACs,
reported
by
19
facilities,
account
for
88
percent
of
the
EAD
TWF
hazard
score
associated
with
this
category.
Discharges
of
dioxin
and
dioxin­
like
compounds,
reported
by
17
facilities,
account
for
seven
percent
of
the
EAD
TWF
hazard
score.

Dioxins
and
furans
are
generated
in
some
catalytic
reformers,
and
have
been
found
in
in­
plant
streams
at
the
part­
per­
thousand
level.
These
compounds
may
be
present
in
air
pollution
control
scrubber
wastewaters
from
catalyst
regeneration.

Table
3.6­
2
below
lists
the
chemicals
driving
th
EAD
TWF
hazard
for
the
Petroleum
Refining
Point
Source
Category.

Table
3.6­
2
Chemical
Summary
Statistics
for
the
Petroleum
Refining
Point
Source
Category
(
40
CFR
Part
419)

Chemical
Number
of
Facilities
in
Category
Reporting
Discharge
to
Water
SIC
Codes
in
Category
Reporting
Discharge
to
Water
Percent
of
Category
EAD
TWF
Hazard
Polycyclic
aromatic
compounds
19
2911
88%

Dioxin
and
dioxin­
like
compounds
17
2911
7%

Unlike
some
of
the
other
point
source
categories
evaluated,
the
petroleum
refining
industry
does
not
have
a
small
number
of
facilities
that
are
largely
responsible
for
the
category's
high
EAD
TWF
hazard
score.
Instead,
there
are
16
facilities
that
comprise
90
percent
of
the
category
EAD
TWF
hazard
score.
At
the
top
of
the
list
is
the
Lyondell­
Citgo
Refining
facility
(
TRI
Facility
ID
77017LYNDL12000)
in
Houston,
Texas,
which
reported
a
discharge
of
2,380
pounds
of
PACs
to
a
publicly­
owned
treatment
works
(
POTW);
following
POTW
removals,
the
discharge
to
surface
water
is
estimated
to
be
175
pounds.
This
discharge
accounts
for
33
percent
of
the
EAD
TWF
hazard
score
for
the
entire
point
source
category.
The
Valero
Refining
Texas
facility
(
TRI
Facility
ID
77592TXSCTLOOP1)
in
Texas
City,
Texas
reported
a
direct
discharge
of
64
pounds
of
PACs,
accounting
for
12
percent
of
the
EAD
TWF
hazard.
The
Tosco
San
3­
27
RSEIreport_
121203.
wpd
Francisco
refinery
(
TRI
Facility
ID
94572NCLSNOLDHI)
in
Rodeo,
California
reported
a
direct
discharge
of
57
pounds
of
PACs,
accounting
for
11
percent
of
the
EAD
TWF
hazard.

3.7
References
4.
U.
S.
EPA.
Preliminary
Data
Summary
for
the
Steam
Electric
Point
Source
Category.
Office
of
Water,
Engineering
and
Analysis
Division.
EPA
821­
Z­
96­
010.
April
1996.

5.
Email
With
Attached
Presentation
from
Carey
Johnston
with
EPA
to
Deborah
Bartram
with
ERG.
Answers
to
Questions
from
EPA
about
Cooling
Tower
Biocides.
May
29,
2003.

6.
U.
S.
EPA.
Profile
of
the
Organic
Chemicals
Industry.
Office
of
Compliance
Sector
Notebook.
EPA
310­
R­
95­
012.
September
1995.

7.
U.
S.
EPA.
Development
Document
for
Effluent
Limitations
Guideline
New
Source
Performance
Standards
for
the
Organic
Chemicals
and
the
Plastics
and
Synthetic
Fibers
Point
Source
Category.
Vol.
1.
Washington,
DC.
October
1987.

8.
Chemical
Manufacturer's
Association.
Designing
Pollution
Prevention
into
the
Process:
Research,
Development
and
Engineering,
Washington,
D.
C.
1993.

9.
U.
S.
EPA.
Development
Document
for
Effluent
Limitations
Guidelines
and
Standards
for
the
Timber
Products.
Section
I
­
Executive
Summary.
EPA
440/
1­
81/
023.
January
1981.

10.
U.
S.
EPA.
EPA
Newsroom:
Whitman
Announces
Transition
from
Consumer
Use
of
Treated
Wood
Containing
Arsenic.
February
12,
2002.

11.
U.
S.
EPA.
Pesticides:
Topical
&
Chemical
Fact
Sheets.
Manufacturers
to
Use
New
Wood
Preservatives,
Replacing
Most
Residential
Uses
of
CCA.
February
12,
2002.

12.
ATSDR
(
Agency
for
Toxic
Substances
and
Disease
Registry).
ToxFAQs
for
CREOSOTE.
CAS#­
Wood
Creosote
8021­
39­
4,
Coal
Tar
Creosote
8001­
58­
9,
Coal
Tar
8007­
45­
2.
September
2002.

13.
ATSDR
(
Agency
for
Toxic
Substances
and
Disease
Registry).
ToxFAQs
for
Pentachlorophenol.
CAS#­
87­
86­
5.
September
2001.

14.
U.
S.
EPA.
Profile
of
the
Lumber
and
Wood
Products
Industry.
EPA
Office
of
Compliance
Sector
Notebook
Project.
EPA
310­
R­
95­
006.
September
1995.
3­
28
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15.
U.
S.
EPA.
Proposed
Technical
Development
Document
for
the
Pulp,
Paper,
and
Paperboard
Category
Effluent
Limitations
Guidelines,
Pretreatment
Standards,
and
New
Source
Performance
Standards.
Office
of
Science
and
Technology,
Engineering
and
Analysis
Division.
October
29,
1993.

16.
U.
S.
EPA.
EPCRA
Section
313
Industry
Guidance,
Petroleum
Terminals
and
Bulk
Storage
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Office
of
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Prevention
and
Toxics
(
EPA
745­
B­
00­
002).
Washington,
DC.
February
2000.

17.
U.
S.
EPA.
AP­
42
­
Compilation
of
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Office
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Air
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and
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January
1995.

18.
American
Petroleum
Institute.
Impacts
of
Petroleum
Product
Marketing
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on
the
Aquatic
Environment.
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Publication
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April
1999.

19.
American
Petroleum
Institute.
Design,
Construction,
Operation,
Maintenance,
and
Inspection
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&
Tank
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API
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2610.
Washington,
DC,
July
1994.

20.
American
Petroleum
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Minimization,
Handling,
Treatment,
and
Disposal
of
Petroleum
Products
Terminal
Wastewaters.
Health
and
Environmental
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and
Manufacturing,
Distribution,
and
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Publication
Number
4602,
August
1994.

21.
ERG.
Draft
Profile
of
the
Petroleum
Bulk
Stations
and
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(
PBST)
Industry.
March
3,
2003.

22.
U.
S.
EPA.
Profile
of
the
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Office
of
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EPA/
310­
R­
95­
013.
September
1995.
4­
1
RSEIreport_
121203.
wpd
4.0
ITEMS
FOR
FURTHER
CONSIDERATION
This
section
discusses
items
that
EAD
intends
to
consider
during
a
more
detailed
review
phase
to
ensure
that
RSEI
outputs
are
correctly
interpreted
and
incorporated
into
the
National
Strategy.

Based
on
the
results
presented
in
Section
3.0,
EAD
believes,
for
some
point
source
categories,
the
EAD
TWF
hazard
score
analyses
identify
specific
facilities
that
contribute
hazard,

but
may
not
return
results
that
indicate
potential
hazard
representative
of
points
source
categories
as
a
whole.
To
better
correlate
results
with
the
National
Strategy,
EAD
may
consider
developing
revised
EAD
TWF
hazard
rankings
after
removing
facilities
that
drive
risk­
related
results
("
atypical"
facility
discharges,
such
as
those
pollutants
reported
by
only
one
facility,
or
pollutant
discharges
that
are
significantly
different
than
those
reported
by
other
facilities
in
the
SIC
code).

This
analysis
would
occur
as
a
component
of
EPA's
second­
level
screening
of
industries
for
further
investigation.

Further
investigation
is
required
to
determine
whether
EAD
TWF
hazard
results
for
PACs
and
dioxin
and
dioxin­
like
compounds,
which
represent
approximately
93
percent
of
the
total
EAD
TWF
hazard
score,
represent
a
reasonable
measure
of
actual
discharges
or
are
instead
a
phenomenon
of
TRI
reporting
based
on
pollutant
detection
limits
and/
or
unrealistically
high
assumptions
regarding
the
presence
or
absence
of
pollutants
at
concentrations
less
than
the
detection
limit.
EAD
will
also
further
evaluate
whether
the
representative
chemical
(
and
associated
EAD
TWF)
assigned
to
these
two
chemical
compound
categories
(
PACs,
dioxin
and
dioxin­
like
compounds)
was
appropriate
on
an
industry­
specific
basis.
(
See
Attachment
B
for
further
information
regarding
the
selection
of
EAD
TWFs
for
TRI
chemical
compound
categories.)
For
example,
use
of
the
EAD
TWF
for
benzo(
a)
pyrene
to
represent
PACs
may
be
appropriate
for
the
Iron
and
Steel
point
source
category,
which
is
known
to
generate
and
discharge
benzo(
a)
pyrene,
but
may
not
be
the
most
appropriate
compound
to
represent
PACs
for
other
point
source
categories.
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EPA
has
not
yet
completed
validating
the
water­
related
RSEI
calculations
and
results.
Most
RSEI
calculations
are
related
to
determination
of
risk­
related
scores,
which
are
not
the
focus
of
this
report;
however,
the
data
sources
(
2000
TRI)
and
some
calculations
also
relate
to
determination
of
EAD
TWF
hazard.
Specifically,
in
addition
to
the
facility­
specific
activities
discussed
in
Sections
4.2
through
4.7,
EAD
has
identified
the
following
model
validation
activities
that
it
may
consider:


Further
investigate
the
basis
for
the
chemical
removal
efficiencies
used
in
RSEI
for
discharges
to
POTWs.


Consider
developing
EAD
TWFs
for
the
remaining
56
chemicals
with
reported
direct
or
indirect
discharges
to
surface
water
in
the
2000
TRI,
prioritized
based
on
RSEI
risk­
related
results.


Validate
differences
in
reported
water
releases
(
pollutants
and
loadings)
for
sites
based
on
production
processes
and
capacities.


Validate
reported
water
releases
based
on
comparison
to
other
data
sources
such
as
EPA's
NPDES
permit
compliance
system.


Review
reported
primary
SIC
code
for
relevance
to
water
releases
(
see
further
discussion
below).

During
initial
review
of
the
RSEI
model
results,
EPA
identified
some
outlier
values.
In
investigating
these
cases,
EPA
determined
that
the
following
modification
were
appropriate
for
certain
SIC
code
assignments
(
six
facilities)
and
pollutants
(
1
facility)
as
listed
below:


Dow
Chemical
Co.,
Freeport,
TX
(
77541THDWCBUILD);
Dow
Chemical
Co,
Plaquemine,
LA
(
70765THDWCHIGHW);
and
PPG
Inds
Inc,
Lake
Charles,
LA
(
70669PPGNDCOLUM)
Primary
SIC
code
reported
for
TRI
for
these
three
facilities
was
2812
(
Alkalies
and
Chlorine);
however,
a
search
of
the
EPA
web
tool
OTIS
(
http://
www.
epa.
gov/
idea/
otis/
mm_
idea_
query.
html)
identified
SIC
code
2869
(
Industrial
organic
chemicals,
n.
e.
c.)
as
the
primary
SIC
code
for
the
facilities'
NPDES
permits.
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ExxonMobil
Chemical
Co
Olefins
Plant,
Baytown,
TX
(
77522XXNCH3525D)
Primary
SIC
code
reported
for
TRI
was
2822
(
Synthetic
rubber
(
vulcanizable
elastomers));
however,
a
search
of
OTIS
identified
SIC
code
2869
as
the
primary
SIC
code
for
the
facility's
NPDES
permit.


Exxon
Chemical,
Baton
Rouge,
LA
(
70805XXNCH4999S)
Primary
SIC
code
reported
for
TRI
was
2869;
however,
a
search
of
OTIS
identified
SIC
code
2821
(
Plastics
materials,
synthetic
resins,
and
non­
vulcanizable
elastomers)
as
the
primary
SIC
code
for
the
facility's
NPDES
permit.


Kimberly­
Clark
Tissue
Co,
Everett,
WA
(
98201SCTTP2600F)
Primary
SIC
code
reported
for
TRI
was
2611
(
Pulp
mills);
however,
EAD's
knowledge
of
this
facility
based
on
its
recent
investigation
of
this
industry
identified
SIC
code
2621
(
Paper
mills)
as
the
more
appropriate
primary
SIC
code.


Metallurgical
Products,
West
Chester,
PA
(
19381MTLLR810LI)
This
facility
reported
water
discharges
of
elemental
phosphorus.
Contact
with
facility
personnel
indicated
the
actual
discharge
was
phosphates
or
phosphoric
acid
and
not
elemental
phosphorus.

These
modifications
indicate
that
the
primary
SIC
code
reported
in
2000
TRI
may
not
be
the
most
appropriate
primary
SIC
code
for
water
discharges,
particularly
at
complex
facilities
with
multiple
processes.
EAD
expects
that
additional
modifications
to
TRI
reported
SIC
codes
and
pollutants
may
be
identified
during
second­
level
screening
investigation
of
the
top
point
source
categories.
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ATTACHMENT
A
TRI
OVERVIEW
The
purpose
of
this
section
is
to
provide
a
summary
of
the
Toxic
Release
Inventory
(
TRI),
specifically
focusing
on
how
the
data
are
reported.
This
summary
does
not
provide
all
details
about
the
TRI
program;
rather
it
is
intended
to
give
the
reader
a
basic
understanding
that
is
needed
perform
an
analysis
of
TRI
data
using
the
Risk
Screening
Environmental
Indicators
(
RSEI)
software
program,
specifically
for
comparative
risks
associated
with
releases
to
water.
More
detailed
information
can
be
found
at
EPA's
TRI
homepage:

http://
www.
epa.
gov/
tri/.

General
TRI
Background:

TRI
is
the
common
name
for
Section
313
of
the
Emergency
Planning
and
Community
Right­
to­
Know
Act
(
EPCRA).
Each
year,
facilities
that
meet
certain
thresholds
must
report
their
releases
and
other
waste
management
activities
(
quantities
recycled,
collected
and
combusted
for
energy
recovery,
treated
for
destruction,
or
disposed)
for
listed
toxic
chemicals.
A
separate
report
must
be
filed
for
each
chemical
that
exceeds
a
threshold.
The
TRI
list
of
chemicals
for
reporting
year
2000
(
the
most
recent
data
available)
includes
more
than
600
chemicals
and
chemical
categories.

TRI
reports
are
sent
to
EPA
by
July
1
of
each
year
for
information
pertaining
to
the
previous
calendar
year
(
for
example,
reports
due
on
July
1,
2003
will
include
releases
from
January
1,
2002
through
December
31,
2002).
EPA
collates
the
TRI
reports
and
performs
a
series
of
quality
assurance
checks
before
finalizing
the
TRI
database
(
typically
approximately
90,000
individual
reports
from
20,000
different
facilities
are
submitted
each
year).
Once
data
are
verified,
EPA's
RSEI
team
uses
the
data
to
compile
the
most
recent
RSEI
database.
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Who
Must
Report:

There
are
three
criteria
that
each
facility
must
consider
every
year.
If,
and
only
if,

a
facility
meets
all
three
criteria,
it
must
submit
a
TRI
report
for
that
reporting
year.
The
criteria
are:

1.
SIC
code
determination:
Facilities
in
Standard
Industrial
Classification
(
SIC)
primary
codes
20
through
39,
seven
additional
SIC
codes
outside
this
range,
and
federal
facilities
must
submit
a
TRI
report.
There
are
many
situations
where
a
facility
has
multiple
on­
site
establishments,
some
within
the
TRI
reporting
universe,
some
outside
the
universe.
In
these
situations,
the
primary
SIC
code,
which
is
based
on
the
facility's
primary
activity
as
reported
by
the
submitter,
determines
TRI
reporting.
The
RSEI
analyses
that
are
presented
throughout
this
document
have
been
filtered
to
only
assign
data
to
the
facility­
identified
primary
SIC
code.

2.
Number
of
Employees:
Facilities
must
have
10
or
more
full­
time
employees
or
their
equivalent.
EPA
defines
a
"
full­
time
equivalent"
as
a
person
that
works
2,000
hours
in
the
reporting
year.
Therefore,
this
criterion
is
met
if
the
facility
employs
any
number
of
workers
that
log
a
total
of
20,000
hours
in
the
reporting
year
(
there
are
several
exceptions
and
special
circumstances
that
are
well­
defined
in
the
TRI
reporting
instructions).

3.
Thresholds:
If
the
facility
is
in
a
covered
SIC
code
and
has
10
or
more
fulltime
employee
equivalents
it
must
conduct
an
activity
threshold
analysis
for
every
chemical
and
chemical
category
on
the
current
TRI
list.
The
facility
must
determine
whether
it
manufactures,
processes,
OR
otherwise
uses
each
chemical
at
or
above
the
appropriate
activity
threshold.
All
TRI
thresholds
are
based
on
mass,
not
concentration.
Also,
it
is
very
important
to
recognize
that
facilities
must
report
any
amount
released
to
any
media
regardless
of
thresholds.
Therefore,
many
facilities
submit
TRI
reports
that
show
zero
or
very
small
releases.

Essentially,
there
are
two
types
of
thresholds.
The
first
applies
to
"
non­
PBT
chemicals".
The
non­
PBT
threshold
determinations
for
the
three
activity
categories
are
mutually
exclusive.
That
is,
the
facility
must
conduct
a
separate
threshold
determination
for
each
activity
category
and
if
any
threshold
is
exceeded,
all
releases
must
be
reported.
The
non­
PBT
thresholds
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are
25,000
pounds
for
manufacturing;
25,000
pounds
for
processing;
and
10,000
pounds
for
other
use.

The
second
type
of
threshold
applies
to
PBT
chemicals.
One
primary
difference
in
TRI
reporting
for
PBTs
is
that
there
is
one
combined
threshold
for
all
three
activities
­

manufacturing,
processing,
and
other
use
are
NOT
mutually
exclusive.
Therefore,
the
facility
must
sum
the
amounts
associated
with
these
activities.
If
this
total
amount
meets
the
threshold
associated
with
the
specific
PBT
chemical,
a
TRI
Form
R
must
be
submitted.
The
reporting
thresholds
for
the
20
PBT
chemicals
are
either
10
pounds
or
100
pounds
(
or
0.1
grams
for
dioxins/
furans.

Changes
to
TRI
Reporting
Over
Time
Any
trend
analysis
using
TRI
data
in
general
or
RSEI
results
should
consider
the
primary
changes
that
have
occurred
over
the
past
several
years.
The
primary
changes
affecting
RSEI
analyses
are
briefly
presented
here:


Chemical
Expansion:
The
original
TRI
list
included
approximately
300
chemicals.
This
list
was
approximately
doubled
in
1995.
Additionally,
each
year
EPA
may
adjust
the
list
in
response
to
petitions
to
add
and
remove
specific
chemicals
(
typically
one
or
two
per
year).


Industry
Expansion:
The
original
industries
covered
in
TRI
only
included
those
in
the
manufacturing
sector
(
SIC
codes
20
through
39).
Federal
Facilities
were
included
via
an
executive
order
in
1994
(
regardless
of
associated
SIC
codes),
and
seven
additional
industries
were
added
in
1997.
The
seven
additional
industries
include:

 
SIC
codes
10
­
Metal
Mining
(
except
1011,
1081,
and
1094),

 
SIC
codes
12
­
Coal
Mining
(
except
1241),

 
SIC
codes
49
­
Electric,
Gas,
and
Sanitary
Services
(
limited
to
4911,
4931,
4939,
and
4953
and
limited
to
those
facilities
that
combust
coal
and/
or
oil
for
the
purpose
of
generating
electricity
for
distribution
in
commerce),
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SIC
code
5169
­
Chemical
and
Allied
Products,
n.
e.
c.,

 
SIC
code
5171
­
Petroleum
Terminals
and
Bulk
Stations,
and
 
SIC
code
7389
­
Business
Services,
n.
e.
c.


The
PBT
and
Lead
Rules:
Prior
to
reporting
year
2000,
the
three
activity
thresholds
for
all
TRI
chemicals
were
identical:
25,000
pounds
for
manufacturing;
25,0000
pounds
for
processing;
and
10,000
pounds
for
other
use.
However,
as
of
reporting
year
2000,
EPA
designated
18
chemicals
as
PBTs.
The
thresholds
for
PBTs
were
lowered
to
either
10
pounds
for
"
highly
persistent"
biocaccumulative,
toxic
chemicals
or
100
pounds
for
other
PBTs
(
dioxins/
furans
are
the
exception
where
the
threshold
is
0.1
grams).
Lead
and
lead
compounds
were
not
designated
as
PBTs
until
reporting
year
2001.

Metals
and
Metal
Compounds
TRI
and
RSEI
have
special
requirements
and
methods
of
analysis
for
metals.
The
factors
associated
with
TRI
reporting
for
metals
that
are
most
important
for
analysis
of
RSEI
results
are
presented
below.


TRI
Reporting
for
Metals
vs.
Metal
Compounds:
In
most
cases,
the
TRI
list
of
chemicals
includes
a
listing
for
the
elemental
metal
and
a
separate
listing
for
all
compounds
of
the
metal
(
e.
g.,
nickel
and
nickel
compounds).
In
general,
facilities
are
required
to
conduct
separate
threshold
analyses
and
then
submit
TRI
reports
for
the
parent
metal
and
the
metal
compound
or
one
combined
report
if
both
thresholds
are
met.


Metal
Compounds
­
Reporting
the
Mass
of
the
Elemental
Metal:
When
conducting
a
threshold
analysis
for
metal
compounds,
the
facility
must
estimate
and
sum
the
mass
of
all
compounds
manufactured,
processed,
or
otherwise
used.
However,
if
a
threshold
is
exceeded,
only
the
mass
of
the
elemental
metal
that
is
released
is
reported.
For
example,
if
a
facility
releases
100
pound
of
lead
oxide
(
PbO),
it
should
report
the
associated
mass
of
elemental
lead
(
93
pounds),
not
the
entire
100
pounds
of
lead
oxide.


Mercury
and
Lead:
Mercury
and
mercury
compounds
have
been
on
the
TRI
list
for
several
years.
However,
until
reporting
year
2000,
the
mercury
thresholds
were
those
for
non­
PBT
chemicals
(
25,000
pounds
or
10,000
pounds).
Therefore,
it
is
expected
that
many
facilities
may
have
reported
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these
chemicals
for
the
first
time
in
2000
when
the
threshold
dropped
to
10
pounds.
Any
trend
analysis
should
consider
this
fact.
Lead
and
lead
compounds
have
also
been
TRI
chemicals
for
several
years;
however,
they
were
not
considered
PBT
chemicals
until
reporting
year
2001.


Combustion
of
Fossil
Fuels:
All
fossil
fuels
contain
trace
amounts
of
most
TRI
metals
and/
or
metal
compounds.
Because
these
chemicals
are
present
in
low
concentrations
in
the
fuel,
it
requires
thousands
of
tons
of
coal,
oil,
wood,
and
even
natural
gas
to
meet
a
reporting
threshold.
Most
facilities
with
reasonably­
sized
combustion
units
easily
burn
enough
fuel
to
meet
a
threshold.
However,
while
virtually
every
electricity­
generating
power
plant
and
most
facilities
with
large
boilers
and
industrial
furnaces
(
BIFs)
report
for
nearly
every
TRI
metal,
many
smaller
facilities
will
not,
or
they
may
only
report
for
some
TRI
metals.


Aluminum,
Zinc,
and
Vanadium
Fume
and
Dust
Qualifier:
Historically,
TRI
has
designated
these
three
metals
with
a
"
fume
and
dust
qualifier".
Essentially,
this
qualifier
means
that
only
the
amount
of
these
metals
that
is
manufactured,
processed,
or
otherwise
used
as
a
fume
and/
or
dust
should
be
included
in
threshold
and
release
estimates.
Therefore,
facilities
may
exceed
a
threshold,
generate
significant
amounts
of
non­
dust
releases,
but
will
(
correctly)
not
report
these
releases.
Beginning
with
reporting
year
2000,
the
TRI
reporting
requirements
for
vanadium
were
modified
to
remove
the
fume
and
dust
qualifier.


Vanadium
Compounds:
Prior
to
reporting
year
2000,
vanadium
metal
was
a
TRI
chemical.
At
the
same
time
the
fume
and
dust
qualifier
was
removed
from
vanadium,
all
physical
forms
of
vanadium
compounds
were
added
to
the
TRI
list.

Other
Factors
Affecting
RSEI
Result
Analyses
There
are
several
factors
associated
with
TRI
reporting
that
could
cause
confusion
when
analyzing
RSEI
results.
The
primary
factors
that
have
been
that
could
affect
the
RSEI
results
are
discussed
below.


Range
Reporting:
TRI
provides
the
option
for
facilities
to
report
releases
as
specific
numbers
OR
as
ranges,
if
appropriate.
Specific
estimates
are
encouraged
if
data
are
available
to
ensure
the
accuracy;
however,
EPA
allows
facilities
to
report
releases
in
the
following
ranges:
1
to
10
pounds,
11
to
499
pounds,
or
500
to
999
pounds.
Range
reporting
is
not
permitted
for
PBT
chemicals.
The
RSEI
model
uses
the
mid­
point
of
each
range.
1TRI
2000
Executive
Summary.
http://
www.
epa.
gov/
tri.

A­
6
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Detection
Limits:
Companies
are
required
to
use
their
judgement
and
report
the
most
accurate
information.
The
TRI
program
does
not
specify
the
use
(
or
non­
use)
of
detection
limits.
TRI
guidance
states
that
if
a
facility
reasonably
expects
a
chemical
to
be
present
in
waste
streams,
the
facility
should
assume
half
of
the
detection
limit
for
estimates.
If
the
facility
does
not
reasonably
expect
the
chemical
to
be
present,
they
can
assume
a
concentration
of
zero.


The
De
Minimis
Exemption:
TRI
includes
an
exemption
such
that
in
general
chemicals
in
any
process
or
waste
stream
below
1%
(
by
mass)
for
non­
carcinogens
or
below
0.1%
for
carcinogens
(
as
defined
by
OSHA)
should
be
excluded
from
both
threshold
and
release
estimates.
The
de
minimis
exemption
is
not
applicable
to
the
manufacture
of
any
TRI
chemical
nor
to
PBT
chemicals.


Alternate
Certification
Statement
(
Form
A):
Starting
in
1997,
EPA
instituted
an
optional
second
type
of
TRI
Report,
commonly
called
the
Form
A.
With
implementation
of
Form
A,
facilities
may
now
certify
that
the
total
quantity
of
a
specific
chemical
released
and
managed
as
waste
is
less
than
500
pounds
without
quantifying
estimates
to
any
media.
A
significant
number
of
Form
A's
are
submitted
by
every
industry
each
year;
Form
A's
cannot
be
submitted
for
PBT
chemicals.
According
to
the
2000
Public
Data
Release
8,
456
Form
A's
were
filed.
Initial
analysis
of
RSEI
indicates
that,
because
no
release
quantity
can
be
assigned
to
any
media,
RSEI
ignores
all
Form
A
submissions.


Test
Data:
EPCRA
mandates
that
facilities
use
the
"
best
readily
available
information"
to
conduct
threshold
AND
release
estimates
for
TRI
reporting.
It
does
NOT
require
any
testing
to
be
conducted
in
any
circumstances.
However,
if
testing
has
been
conducted
for
any
other
purpose,
the
facility
is
required
to
consider
using
the
results
if
they
are
appropriate.

Data
Quality
EPA's
TRI
Division
has
always
been
concerned
with
the
quality
of
information
that
is
released
in
the
public
database.
Therefore,
an
overall
quality
assurance
program
has
been
instituted.
In
2000,
23,834
facilities
submitted
a
total
of
91,513
forms1.
While
the
majority
of
the
data
appear
to
provide
reasonable
pollutant
information,
EPA
acknowledges
that
significant
A­
7
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errors
associated
with
individual
estimates
do
exist.
The
primary
aspects
of
TRI's
data
quality
program
and
the
uncertainties
that
affect
RSEI
runs
are
briefly
presented
below.


Internal
Checks
of
Submitted
Reports:
EPA
headquarters
collects
all
reports,
either
electronic
submissions
or
manual
submissions,
and
conducts
a
series
of
internal
quality
control
checks
before
any
information
is
made
available
to
the
public.
All
data
for
every
report
is
entered
into
an
electronic
master
database.
Written
submissions
are
hand­
entered
by
two
clerical
personnel
and
cross­
checked
for
transcription
errors.
After
data
are
entered,
each
data
element
is
electronically
checked
to
identify
omissions
and
information
that
has
been
recorded
in
an
incorrect
field.
Potential
errors
are
identified
and
mailings
are
sent
to
submitters
requesting
verification
of
the
information.


Increaser/
Decreaser
Checks:
Facilities
that
show
significant
increases
or
decreases
from
one
year
to
the
next
are
identified
and
an
EPA
or
contractor
scientist
contacts
the
facilities
to
verify
the
estimates
in
question.


Reality
Checks:
In
addition
to
the
increaser/
decreaser
effort,
EPA
scientists
review
many
TRI
reports
and
conduct
a
reality
check,
focusing
on
anomalies
in
submitted
data.


Regional
QA/
QC
Efforts:
Individual
states
and
regions
also
conduct
quality
assurance
checks.
Many
regional
TRI
coordinators
work
closely
with
facilities
and
know
specific
issues
associated
with
individual
companies.
These
coordinators
often
review
individual
TRI
submissions
and
then
personally
contact
facilities
with
questions.


Revisions:
If
EPA
or
a
facility
identifies
any
errors,
a
revised
report
may
be
submitted.
Revisions
that
are
received
prior
to
the
data
freeze
are
incorporated
into
the
national
database
and
made
available
to
the
public
(
and
RSEI
programers)
with
the
yearly
Public
Data
Release.
Revisions
that
are
received
after
the
data
freeze
are
not
incorporated
until
the
following
reporting
year.


Site
Survey
Program:
EPA
conducted
site
visits
to
165
facilities
in
several
industry
sectors
to
assess
the
quality
of
facility
estimates.
EPA
observed
that
most
facility
estimates
were
within
10%
of
surveyor
estimates
based
on
site
surveyor's
assessments
of
information
that
was
"
readily
available".
There
were
also
many
circumstances
when
more
significant
errors
were
identified.
The
accuracy
varied
significantly
with
the
industry
sector
that
was
investigated.
No
surveys
have
been
conducted
since
1998.
A­
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It
is
important
to
note
that
the
site
survey
program
analysis
only
considered
the
"
best
readily
available
information".
When
no
test
data
or
emission
factors
were
available
the
uncertainty
in
actual
releases
is
expected
to
increase
significantly.
The
site
surveyors
did
not
conduct
additional
testing.


Sector
vs.
Facility
Accuracy:
The
accuracy
of
estimates
(
the
actual
pounds
released
to
specific
media)
does
not
necessarily
coincide
with
appropriate
reporting.
In
reality,
a
facility
may
correctly
report
for
TRI
and
in
good
faith
may
provide
the
best
estimate
of
releases
possible;
however,
the
uncertainty
in
the
estimate
may
be
extremely
high.
Results
from
TRI's
Site
Survey
Program
can
be
considered
to
show
that
a
microscopic
evaluation
of
individual
estimates
can
result
in
significant
uncertainties.
However,
survey
results
indicate
that
as
many
facilities
over­
report,
as
those
that
under­
report.
Therefore,
a
macroscopic
evaluation
of
entire
sectors
may
show
considerably
less
uncertainty
and
may
show
more
reasonable
results.
1EAD
Toxics
Database
developed
by
VERSAR,
version
developed
in
2001.

B­
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RSEIreport_
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ATTACHMENT
B
CALCULATION
OF
EAD
TWF
HAZARD
EAD
ranked
the
RSEI
results
using
EAD
TWFs
in
place
of
RSEI
toxic
weights.

This
value,
the
EAD
TWF
hazard,
is
calculated
for
TRI
chemicals
that
have
EAD
TWFs
developed
by
EAD's
Environmental
Assessment
Branch.
EAD
TWF
hazard
scores
are
calculated
by
multiplying
total
TRI
pounds
(
see
Section
2.2)
by
the
EAD
TWF
of
the
chemical.
For
indirect
discharges,
the
reported
pounds
transferred
off
site
to
POTWs
are
adjusted
to
account
for
treatment
at
a
POTW.

The
TRI
list
includes
612
chemicals
and
compound
categories.
Using
a
table
of
EAD
TWFs1,
EAD
was
able
to
identify
matching
entries
for
580
of
these
chemicals
and
assigned
EAD
TWFs
accordingly.
Of
the
329
TRI
chemicals
and
compound
categories
with
reported
direct
or
indirect
discharges
to
surface
waters,
EAD
TWFs
have
not
been
developed
for
55
of
these
chemicals.
See
Section
2.3
for
further
information
regarding
the
development
of
EAD
TWFs.

For
the
30
TRI
chemical
compound
categories,
EPA
could
not
use
CAS
Numbers
to
identify
matching
compounds
to
assign
EAD
TWFs.
Table
B­
1
lists
the
30
TRI
chemical
compound
categories
for
which
EAD
identified
representative
chemicals
using
means
other
than
CAS
Number,
and
provides
the
rationale
for
this
assignment.
This
table
provides
the
name
and
CAS
Number
of
the
TRI
chemical
compound
category,
the
chemical
used
as
the
basis
of
RSEI
toxicity
data,
the
name
and
CAS
number
of
the
chemical
used
to
select
an
EAD
TWF,
and
the
EAD
TWF
(
where
available).
B­
2
RSEIreport_
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Table
B­
1
Specific
Chemicals
and
Toxic
Weighting
Factors
Selected
to
Represent
TRI
Chemical
Compound
Categories
TRI
Category
Number
TRI
Chemical
Compound
Category
RSEI
Toxicity
Based
On
Representative
EAD
TWF
Chemical
EAD
TWF
Chemical
CAS
NO
EAD
TWF
Rationale
for
Assignment
N010
Antimony
compounds
Antimony
Antimony
7440­
36­
0
4.8
x
10­
3
1
N020
Arsenic
compounds
Arsenic
Arsenic
7440­
38­
2
3.47
1
N040
Barium
compounds
Barium
Barium
7440­
39­
3
2.0
x
10­
3
1
N050
Beryllium
compounds
Beryllium
Beryllium
7440­
41­
7
1.06
1
N078
Cadmium
compounds
Cadmium
Cadmium
7440­
43­
9
2.61
1
N084
Chlorophenols
Pentachlorophenol
Pentachlorophenol
87­
86­
5
0.44
2
N090
Chromium
compounds
Chromium
hexavalent
Chromium
hexavalent
18540­
29­
9
0.51
2
N096
Cobalt
compounds
Cobalt
Cobalt
7440­
48­
4
0.11
1
N100
Copper
compounds
Copper
Copper
7440­
50­
8
0.63
1
N106
Cyanide
compounds
Copper
cyanide
Copper
cyanide
544­
92­
3
2.6
x
10­
3
2
N120
Diisocyanates
None
(
no
toxicity
data
assigned)
None
(
no
EAD
TWF
chemical
identified)
101­
68­
8
Not
available
N150
Dioxin
and
dioxin­
like
compounds
None
(
no
toxicity
data
assigned)
Hexachlorodibenzofuran
1,2,3,6,7,8­
57117­
44­
9
6.7
x
106
3
N171
Ethylenebisdithiocar­
bamic
acid,
salts
and
esters
Metiram
Metiram
9006­
42­
2
8.7
x
10­
3
2
N230
Glycol
ethers
Methoxyethanol,
2­
Methoxyethanol,
2­
109­
86­
4
1.1
x
10­
4
2
N420
Lead
compounds
Lead
Lead
7439­
92­
1
2.24
1
N450
Manganese
compounds
Manganese
Manganese
7439­
96­
5
0.070
1
N458
Mercury
compounds
Mercury
Mercury
7439­
97­
6
117.08
1
N495
Nickel
compounds
Nickel
Nickel
7440­
02­
0
0.11
1
N503
Nicotine
and
salts
None
(
no
toxicity
data
assigned)
None
(
no
EAD
TWF
chemical
identified)
54­
11­
5
Not
available
N511
Nitrate
compounds
Nitrate
Nitrate
14797­
55­
8
6.2
x
10­
5
2
N575
Polybrominated
biphenyls
(
PBBs)
Polybrominated
biphenyls,
NOS
None
(
no
EAD
TWF
chemical
identified)
59536­
65­
1
Not
available
N583
Polychlorinated
alkanes
None
(
no
toxicity
data
assigned)
None
(
no
EAD
TWF
chemical
identified)
Not
available
Not
available
N590
Polycyclic
aromatic
compounds
Benzo(
a)
pyrene
Benzo(
a)
pyrene
50­
32­
8
4,283.56
2
N725
Selenium
compounds
Selenium
Selenium
7782­
49­
2
1.12
1
N740
Silver
compounds
Silver
Silver
7440­
22­
4
16.47
1
N746
Strychnine
and
salts
Strychnine
Strychnine
57­
24­
9
0.095
2
N760
Thallium
compounds
Thallium
Thallium
7440­
28­
0
1.00
2
N770
Vanadium
compounds
Vanadium
Vanadium
7440­
62­
2
0.62
1
N874
Warfarin
and
salts
Warfarin
Warfarin
81­
81­
2
1.86
2
Table
B­
1
(
Continued)

TRI
Category
Number
TRI
Chemical
Compound
Category
RSEI
Toxicity
Based
On
Representative
EAD
TWF
Chemical
EAD
TWF
Chemical
CAS
NO
EAD
TWF
Rationale
for
Assignment
B­
3
RSEIreport_
121203.
wpd
N982
Zinc
compounds
Zinc
Zinc
7440­
66­
6
0.047
1
Rationale
for
Assignment
1
­
With
the
exception
of
some
compound
categories
and
other
special
cases,
RSEI
assumes
that
metal
compounds
have
the
same
toxicity
weight
as
that
of
the
parent
metal.
Representative
EAD
TWF
chemicals
for
these
categories
were
identified
following
the
same
assumption.
2
­
RSEI
Technical
Appendix
A
(
2002).
3
­
Table
II,
Section
C
of
the
Toxic
Chemical
Release
Inventory
Reporting
Forms
and
Instructions
(
2002)
provided
a
list
of
the
17
chemicals
included
in
the
dioxins
category
for
TRI
reporting.
1,2,3,6,7,8­
Hexachlorodibenzofuran
has
the
median
EAD
TWF
of
these
17
chemicals
and
was
selected
as
the
representative
chemical.
1An
initial
table
(
NAIC_
codes.
wpd)
relating
point
source
category
to
SIC
and
NAICS
codes
was
developed
by
Hugh
Wise
of
EAD
and
used
as
the
basis
for
this
analysis.

C­
1
RSEIreport_
121203.
wpd
ATTACHMENT
C
RELATION
OF
SIC
CODES
TO
POINT
SOURCE
CATEGORIES
The
following
tables
relate
the
4­
digit
SIC
codes
to
existing
point
source
categories
that
may
regulate
discharges
from
those
industries.
Table
C­
1
lists
point
source
categories
and
their
corresponding
SIC
codes1.
Table
C­
2
lists
the
primary
SIC
codes
present
in
the
RSEI
model
(
based
on
2000
TRI
data)
that
are
not
currently
covered
by
a
point
source
category.

Some
SIC
codes
fall
in
more
than
one
point
source
category.
In
these
cases,
the
RSEI
model
results
are
either
distributed
among
applicable
point
source
categories
or
counted
in
each
point
source
category
in
which
they
are
regulated,
depending
on
the
specific
SIC
code.
The
majority
of
overlapping
SIC
codes
among
point
source
categories
occurs
between
the
Metal
Products
and
Machinery
(
MP&
M,
40
CFR
Part
438)
and
Metal
Finishing
(
40
CFR
Part
433)

point
source
categories.
EAD
determined
it
would
be
inappropriate
to
double
count
RSEI
model
results
for
these
point
source
categories
because
the
final
MP&
M
rule
at
§
438.1(
b)
specifically
excludes
both
metal­
bearing
wastewaters
and
wastewaters
subject
to
other
effluent
guidelines
(
e.
g.,
Metal
Finishing).
To
more
accurately
represent
the
applicability
of
these
two
point
source
categories
in
the
RSEI
analysis,
EAD
developed
a
methodology
to
distribute
the
RSEI
model
results
by
allocating
only
organic
chemical
releases
to
MP&
M
and
all
other
releases
to
Metal
Finishing.
Although
EAD
believes
this
simplified
methodology
reasonably
distributes
releases,

EPA
acknowledges
that
the
MP&
M
allocation
is
somewhat
overestimated
at
the
expense
of
the
Metal
Finishing
allocation
because
commingled
metal­
bearing
and
organic­
bearing
wastewaters
are
regulated
only
under
Metal
Finishing.

For
SIC
codes
that
overlap
point
source
categories
other
than
MP&
M
and
Metal
Finishing,
RSEI
model
results
are
counted
in
each
point
source
category
in
which
they
are
regulated.
Double
counting
of
RSEI
model
results
for
certain
SIC
codes
accounts
for
C­
2
RSEIreport_
121203.
wpd
approximately
8.5
percent
of
the
total
RSEI
risk­
related
result
and
1.5
percent
of
the
total
EAD
TWF
hazard
result.

Table
C­
1
Point
Source
Categories
and
Corresponding
SIC
Codes
Point
Source
Category
Relevant
SIC
codes
Aluminum
forming
3353,
3354,
3355,
3357,
3363,
3463
Asbestos
manufacturing
3292
Battery
manufacturing
3691,
3692
Builder's
paper
and
board
mills
40
CFR
431
has
been
deleted;
therefore,
this
point
source
category
no
longer
exists.

Canned
and
preserved
seafood
2091,
2092
Carbon
black
manufacturing
2895
Cement
manufacturing
3241
Centralized
waste
treatment
SIC
codes
are
not
an
appropriate
means
of
identification
for
this
point
source
category.

Coal
mining
1221,
1222,
1231,
1241a
Coil
coating
3411
Concentrated
animal
feeding
operationsb
0211,
0213,
0214,
0241,
0251,
0252,
0253,
0254,
0259,
0272
Copper
forming
3351,
3357,
3463
Dairy
products
processing
2021,
2022,
2023,
2024,
2026
Electrical
and
electronic
components
3671,
3674
Electroplating
3471
Explosives
2892
Ferroalloy
manufacturing
3313
Fertilizer
manufacturing
2873,
2874,
2875
Fruits
and
vegetable
processing
2033,
2034,
2035,
2037
Glass
manufacturing
3211,
3221,
3296
Grain
mills
manufacturing
2041,
2043,
2044,
2045,
2046,
2047
Gum
and
wood
chemicals
2861
Hospital
8062a,
8063,
8069a
Table
C­
1
(
Continued)

Point
Source
Category
Relevant
SIC
codes
C­
3
RSEIreport_
121203.
wpd
Ink
formulating
2893
Inorganic
chemicals
2812,
2813,
2816,
2819
Iron
and
steel
manufacturing
3312,
3315,
3316,
3317
Landfills
4953
Leather
tanning
and
finishing
3111
Meat
products
2011,
2013,
2077
Metal
finishing
2514,
2522,
2531,
2542,
2591,
2599,
2796,
3398,
Industry
Groups:
34,
35,
36,
37
and
38,
3911,
3914,
3915,
3931,
3944,
3949,
3951,
3953,
3961,
3965,
3993,
3995,
3999
Metal
molding
and
casting
(
foundries)
3321,
3322,
3324,
3325,
3364,
3365,
3366,
3369
Metal
products
and
machinery
2514,
2522,
2531,
2542,
2591,
2599,
2796,
3398,
Industry
Groups:
34,
35,
36,
37
and
38,
3911,
3914,
3915,
3931,
3944,
3949,
3951,
3953,
3961,
3965,
3993,
3995,
3999,
4011a,
4013a,
4111a,
4119a,
4121a,
4131a,
4141a,
4142a,
4173a,
4212a,
4213a,
4214a,
4215a,
4231a,
4412a,
4424a,
4432a,
4449a,
4481a,
4482a,
4489a,
4491a,
4492a,
4493a,
4499a,
4581a,
5013,
5511a,
5521a,
5561a,
5571a,
5599a,
7353a,
7359a,
7378a,
7379a,
7515a,
7532a,
7533a,
7537a,
7538a,
7539a,
7549a,
7623a,
7629a,
7631a,
7692a,
7699a
Mineral
mining
and
processing
1422a,
1423a,
1429a,
1442a,
1446a,
1455a,
1459a,
1474a,
1475a,
1479a,
1499a,
3275
Nonferrous
metals
forming
and
metal
powders
3356,
3357,
3363,
3399,
3463,
3482,
3483
Nonferrous
metals
manufacturing
2819,
3331,
3334,
3339,
3341
Oil
and
gas
extraction
1311
Ore
mining
and
dressing
1011a,
1021,
1031,
1041,
1044,
1061,
1094a,
1099
Organic
chemicals,
plastics,
and
synthetic
fibers
2821,
2823,
2824,
2865,
2869
Paint
formulating
2851
Paving
and
roofing
materials
(
tars
and
asphalt)
2951,
2952,
3996
Pesticide
chemicals
manufacturing,
formulation
and
packaging
2879
Petroleum
refining
2911
Pharmaceutical
manufacturing
2833,
2834
Phosphate
manufacturing
2819,
2874
Table
C­
1
(
Continued)

Point
Source
Category
Relevant
SIC
codes
C­
4
RSEIreport_
121203.
wpd
Photographicb
7221,
7335,
7384,
7819
Plastic
molding
and
forming
3081,
3082,
3083,
3084,
3085,
3086,
3087,
3088,
3089
Porcelain
enameling
3431,
3469,
3479,
3631,
3632,
3633,
3639
Pulp,
paper
and
paperboard
2611,
2621,
2631
Rubber
manufacturing
2822,
3011,
3021,
3052,
3053,
3061,
3069
Soaps
and
detergents
manufacturing
2841
Steam
electric
power
generation
4911
Sugar
processing
2061,
2062,
2063
Textile
mills
2211,
2221,
2231,
2241,
2251,
2252,
2253,
2254,
2257,
2258,
2259,
2261,
2262,
2269,
2273,
2281,
2282,
2284,
2295,
2296,
2297,
2298,
2299
Timber
products
processing
2421,
2435,
2436,
2491,
2493,
2499
Transportation
equipment
cleaningb
4491,
4499,
4741,
7699
Waste
combustors
(
commercial
incinerators
combusting
hazardous
waste)
4953
aNo
facilities
in
this
SIC
code
submitted
reports
to
the
2000
TRI.
bNo
facilities
in
the
SIC
codes
for
this
point
source
category
submitted
reports
to
the
2000
TRI.
C­
5
RSEIreport_
121203.
wpd
Table
C­
2
Reported
SIC
Codes
Not
Covered
by
a
Point
Source
Category
SIC
Code
SIC
Description
SIC
Code
SIC
Description
2032
Canned
specialties
2831
Nonexistent
SIC
code
2038
Frozen
specialties,
n.
e.
c.
2835
In
vitro
and
in
vivo
diagnostic
substances
2048
Prepared
feeds
and
feed
ingredients
for
animals
and
fowls,
except
dogs
and
cats
2836
Biological
products,
except
diagnostic
substances
2051
Bread
and
other
bakery
products,
except
cookies
and
crackers
2840
Soap,
detergents,
and
cleaning
preparations;
perfumes,
cosmetics,
and
other
toilet
preparations
2052
Cookies
and
crackers
2842
Specialty
cleaning,
polishing,
and
sanitation
preparations
2053
Frozen
bakery
products,
except
bread
2843
Surface
active
agents,
finishing
agents,
sulfonated
oils,
and
assistants
2064
Candy
and
other
confectionary
products
2844
Perfumes,
cosmetics,
and
other
toilet
preparations
2066
Chocolate
and
cocoa
products
2891
Adhesives
and
sealants
2074
Cottonseed
oil
mills
2899
Chemicals
and
chemical
preparations,
n.
e.
c.

2075
Soybean
oil
mills
2992
Lubricating
oils
and
greases
2076
Vegetable
oil
mills,
except
corn,
cottonseed,
and
soybean
2999
Products
of
petroleum
and
coal,
n.
e.
c.

2079
Shortening,
table
oils,
margarine,
and
other
edible
fats
and
oils,
n.
e.
c.
3050
Gaskets,
packing,
and
sealing
devices
and
rubber
and
plastics
hose
and
belting
2080
Beverages
3229
Pressed
and
blown
glass
and
glassware,
n.
e.
c.

2082
Malt
beverages
3231
Glass
products,
made
of
purchased
glass
2083
Malt
3251
Brick
and
structural
clay
tile
2085
Distilled
and
blended
liquors
3253
Ceramic
wall
and
floor
tile
2086
Bottled
and
canned
soft
drinks
and
carbonated
waters
3255
Clay
refractories
2087
Flavoring
extracts
and
flavoring
syrups,
n.
e.
c.
3259
Structural
clay
products,
n.
e.
c.

2096
Potato
chips,
corn
chips,
and
similar
snacks
3261
Vitreous
china
plumbing
fixtures
and
china
and
earthenware
fittings
and
bathroom
accessories
2097
Manufactured
ice
3262
Vitreous
china
table
and
kitchen
articles
2099
Food
preparations,
n.
e.
c.
3264
Porcelain
electrical
supplies
2111
Cigarettes
3269
Pottery
products,
n.
e.
c.

2131
Chewing
and
smoking
tobacco
and
snuff
3270
Concrete
gypsum
and
plaster
products
2141
Tobacco
stemming
and
redrying
3273
Ready
mixed
concrete
2322
Men's
and
boys'
underwear
and
nightware
3291
Abrasive
products
2396
Automotive
trimmings,
apparel
findings,
and
related
products
3295
Minerals
and
earths,
ground
or
otherwise
treated
2399
Fabricated
textile
products,
n.
e.
c.
3297
Nonclay
refractories
Table
C­
2
(
Continued)

SIC
Code
SIC
Description
SIC
Code
SIC
Description
C­
6
RSEIreport_
121203.
wpd
2411
Logging
3299
Nonmetallic
mineral
products,
n.
e.
c.

2431
Millwork
3490
Miscellaneous
fabricated
metal
products
2439
Structural
wood
members,
n.
e.
c.
3952
Lead
pencils,
crayons,
and
artists'
materials
2511
Wood
household
furniture,
except
upholstered
3991
Brooms
and
brushes
2512
Wood
household
furniture,
upholstered
4925
Mixed,
manufactured,
or
liquefied
petroleum
gas
production
and/
or
distribution
2517
Wood
television,
radio,
phonograph,
and
sewing
machine
cabinets
4931
Electric
and
other
services
combined
2521
Wood
office
furniture
4939
Combination
utilities,
n.
e.
c.

2541
Wood
office
and
store
fixtures,
partitions,
shelving,
and
lockers
5013
Motor
vehicle
supplies
and
new
parts
2649
Nonexistent
SIC
code
5093
Scrap
&
waste
materials
2653
Corrugated
and
solid
fiber
boxes
5142
Packaged
frozen
foods
2655
Fiber
cans,
tubes,
drums,
and
similar
products
5144
Poultry
and
poultry
products
2656
Sanitary
food
containers,
except
folding
5169
Chemicals
and
allied
products,
n.
e.
c.
(
wholesale
trade)

2657
Folding
paperboard
boxes,
including
sanitary
5171
Petroleum
bulk
stations
and
terminals
2661
Building
paper
and
building
board
mills
(
DISC.
1987
2493
or
2621)
5191
Farm
supplies
2671
Packaging
paper
and
plastics
film,
coated
and
laminated
6799
Investors,
n.
e.
c.

2672
Coated
and
laminated
paper,
n.
e.
c.
7389
Business
services,
n.
e.
c.

2674
Uncoated
paper
and
multiwall
bags
8731
Commercial
physical
and
biological
research
2676
Sanitary
paper
products
8733
Noncommercial
research
organizations
2679
Converted
paper
and
paperboard
products,
n.
e.
c.
8734
Commercial
testing
laboratory
2732
Book
printing
8741
Management
services
(
1987)

2752
Commercial
printing,
lithographic
8999
Services,
not
elsewhere
classified
2754
Commercial
printing,
gravure
9131
Executive
and
legislative
offices
combined
2759
Commercial
printing,
n.
e.
c.
9199
General
government,
n.
e.
c.

2771
Greeting
cards
9511
Air
and
water
resource
and
solid
waste
management
2782
Blankbooks,
looseleaf
binders
and
devices
9711
National
security
2800
Chemicals
and
allied
products
INVA
Invalid
SIC
code
2810
Industrial
inorganic
chemicals
n.
e.
c.
­
Not
elsewhere
classified.
aSome
sites
submitted
invalid
and
nonexistent
SIC
codes
to
the
2000
TRI.
The
SIC
codes
2649,
2831,
and
INVA
are
all
listed
in
RSEI.
D­
1
RSEIreport_
121203.
wpd
ATTACHMENT
D
POINT
SOURCE
CATEGORY
RANKINGS
BY
EAD
TWF
HAZARD
Table
D­
1
presents
all
point
source
categories
found
in
RSEI,
ranked
by
EAD
TWF
Hazard.
The
values
for
RSEI
Risk­
Related
Results,
TRI
Pounds,
RSEI
Hazard,
and
RSEI
Modeled
Hazard
are
also
presented.

Table
D­
1
Point
Source
Category
Rankings
by
EAD
TWF
Hazard
Point
Source
Category/
SIC
Code
EAD
TWF
Hazard
RSEI
Risk­
Related
Results
TRI
Pounds
RSEI
Hazard
RSEI
Modeled
Hazard
Steam
electric
power
generation
1
1
13
1
2
Organic
chemicals,
plastics
and
synthetic
fibers
2
6
2
2
1
Timber
products
processing
3
36
57
35
42
Pulp,
paper
and
paperboard
4
12
4
8
10
SIC
5171:
Petroleum
bulk
stations
and
terminals
5
19
74
28
39
Petroleum
refining
6
10
6
7
4
Iron
and
steel
manufacturing
7
3
1
4
5
Inorganic
chemicals
8
14
7
9
15
Nonferrous
metals
manufacturing
9
9
5
6
11
Landfillsa
10
26
41
22
23
Waste
combustors
(
commercial
incinerators
combusting
hazardous
waste)
a
10
26
41
22
23
Metal
Finishing
12
2
9
3
3
Phosphate
manufacturing
13
15
8
14
18
Rubber
Manufacturing
14
28
24
39
20
SIC
2899:
Chemicals
and
chemical
preparations,
n.
e.
c.
15
25
27
19
7
SIC
8733:
Noncommercial
research
organizations
16
44
118
56
71
Nonferrous
metals
forming
and
metal
powders
17
5
23
5
9
Plastic
molding
and
forming
18
29
25
27
25
Pharmaceutical
manufacturing
19
22
14
11
8
Ink
formulating
20
52
48
60
69
Porcelain
Enameling
21
37
28
38
21
SIC
7389:
Business
services,
n.
e.
c.
22
90
47
53
63
Textile
mills
23
18
31
15
13
Grain
mills
manufacturing
24
42
19
12
28
Table
D­
1
(
Continued)

Point
Source
Category/
SIC
Code
EAD
TWF
Hazard
RSEI
Risk­
Related
Results
TRI
Pounds
RSEI
Hazard
RSEI
Modeled
Hazard
D­
2
RSEIreport_
121203.
wpd
Fertilizer
manufacturing
25
20
11
30
31
Ore
mining
and
dressing
26
34
34
10
26
Metal
molding
and
casting
(
foundries)
27
21
44
18
17
Electroplating
28
4
17
25
14
SIC
9131:
Executive
and
legislative
offices
combined
29
95
61
67
83
Aluminum
forming
30
11
26
17
22
Copper
forming
31
13
49
21
29
Leather
tanning
and
finishing
32
40
36
34
38
Coal
mining
33
8
29
42
50
Ferroalloy
manufacturing
34
69
32
37
43
SIC
9511:
Air
and
water
resource
and
solid
waste
management
35
70
63
33
41
Fruits
and
vegetable
processing
36
76
10
47
58
Meat
Products
Processing
37
30
3
26
37
SIC
4925:
Mixed,
manufactured,
or
liquefied
petroleum
gas
production
and/
or
distribution
38
71
58
50
61
SIC
2411:
Logging
39
b
54
52
62
Pesticide
chemicals
manufacturing,
formulation
and
40
50
21
29
33
SIC
2075:
Soybean
oil
mills
41
49
22
58
64
Coil
coating
42
60
70
77
91
Cement
manufacturing
43
77
101
79
93
Electrical
and
electronic
components
44
16
12
16
16
Battery
manufacturing
45
17
52
20
30
SIC
2082:
Malt
beverages
46
62
16
51
44
SIC
2844:
Perfumes,
cosmetics,
and
other
toilet
preparations
47
35
72
62
45
SIC
2141:
Tobacco
stemming
and
redrying
48
b
30
72
88
Dairy
products
processing
49
64
15
36
6
SIC
2992:
Lubricating
oils
and
greases
50
55
40
66
52
SIC
9711:
National
security
51
43
39
31
36
SIC
4931:
Electric
and
other
services
combined
52
68
80
41
47
SIC
9199:
General
government,
n.
e.
c.
53
79
88
94
112
SIC
2099:
Food
preparations,
n.
e.
c.
54
63
38
75
60
SIC
2843:
Surface
active
agents,
finishing
agents,
sulfonated
oils,
and
assistants
55
38
51
24
12
Glass
manufacturing
56
57
56
71
82
SIC
3229:
Pressed
and
blown
glass
and
glassware,
n.
e.
c.
57
32
50
32
40
SIC
2842:
Specialty
cleaning,
polishing,
and
sanitation
preparations
58
39
71
48
34
SIC
2810:
Industrial
inorganic
chemicals
59
115
132
103
123
Table
D­
1
(
Continued)

Point
Source
Category/
SIC
Code
EAD
TWF
Hazard
RSEI
Risk­
Related
Results
TRI
Pounds
RSEI
Hazard
RSEI
Modeled
Hazard
D­
3
RSEIreport_
121203.
wpd
SIC
3295:
Minerals
and
earths,
ground
or
otherwise
treated
60
72
35
46
54
SIC
2048:
Prepared
feeds
and
feed
ingredients
for
animals
and
fowls,
except
dogs
and
cats
61
24
18
57
76
SIC
2655:
Fiber
cans,
tubes,
drums,
and
similar
products
62
48
75
91
107
Paint
formulating
63
23
60
43
32
Hospital
64
106
103
105
115
SIC
3269:
Pottery
products,
n.
e.
c.
65
33
107
65
72
SIC
8999:
Services,
not
elsewhere
classified
66
94
99
59
75
SIC
3291:
Abrasive
products
67
45
45
76
86
SIC
2676:
Sanitary
paper
products
68
b
152
b
b
SIC
3297:
Nonclay
refractories
69
81
91
81
98
Explosives
70
56
20
49
55
Soaps
and
detergents
manufacturing
71
41
68
55
35
SIC
3264:
Porcelain
electrical
supplies
72
31
94
70
81
SIC
2891:
Adhesives
and
sealants
73
67
69
61
68
Sugar
processing
74
61
33
78
97
SIC
5169:
Chemicals
and
allied
products,
n.
e.
c.
(
wholesale
trade)
75
75
90
82
65
SIC
2079:
Shortening,
table
oils,
margarine,
and
other
edible
fats
and
oils,
n.
e.
c.
77
66
67
96
70
SIC
8731:
Commercial
physical
and
biological
research
78
53
65
63
78
SIC
3299:
Nonmetallic
mineral
products,
n.
e.
c.
79
59
121
93
111
SIC
3231:
Glass
products,
made
of
purchased
glass
80
46
46
13
19
SIC
2754:
Commercial
printing,
gravure
81
51
100
74
80
SIC
4939:
Combination
utilities,
n.
e.
c.
82
100
120
125
121
SIC
2096:
Potato
chips,
corn
chips,
and
similar
snacks
83
b
37
40
95
SIC
2672:
Coated
and
laminated
paper,
n.
e.
c.
84
78
76
85
77
SIC
2831:
Nonexistent
SIC
code
85
104
59
45
48
SIC
2085:
Distilled
and
blended
liquors
86
130
53
89
104
SIC
3262:
Vitreous
china
table
and
kitchen
articles
87
74
122
73
87
SIC
3253:
Ceramic
wall
and
floor
tile
88
88
108
101
118
SIC
2396:
Automotive
trimmings,
apparel
findings,
and
related
products
89
117
97
102
122
Gum
and
wood
chemicals
90
83
66
54
56
SIC
2752:
Commercial
printing,
lithographic
91
47
85
69
51
Metal
Products
and
Machinery
92
89
78
68
85
SIC
2771:
Greeting
cards
93
82
96
87
94
SIC
2032:
Canned
specialties
94
102
77
111
49
SIC
3255:
Clay
refractories
95
86
114
120
134
Table
D­
1
(
Continued)

Point
Source
Category/
SIC
Code
EAD
TWF
Hazard
RSEI
Risk­
Related
Results
TRI
Pounds
RSEI
Hazard
RSEI
Modeled
Hazard
D­
4
RSEIreport_
121203.
wpd
SIC
2671:
Packaging
paper
and
plastics
film,
coated
and
laminated
96
107
83
95
110
SIC
2086:
Bottled
and
canned
soft
drinks
and
carbonated
waters
97
54
73
44
27
Paving
and
roofing
materials
(
tars
and
asphalt)
98
91
95
106
103
Canned
and
preserved
seafood
99
b
62
100
119
SIC
2076:
Vegetable
oil
mills,
except
corn,
cottonseed,
and
soybean
100
80
128
122
92
SIC
2111:
Cigarettes
101
98
43
130
130
SIC
2836:
Biological
products,
except
diagnostic
substances
102
7
79
84
84
SIC
2064:
Candy
and
other
confectionary
products
103
b
64
99
b
SIC
2053:
Frozen
bakery
products,
except
bread
104
113
86
123
113
SIC
2038:
Frozen
specialties,
n.
e.
c.
105
92
84
119
101
Oil
and
gas
extraction
106
85
111
92
109
Water
Supply
107
105
133
115
133
SIC
2782:
Blankbooks,
looseleaf
binders
and
devices
108
101
109
98
57
SIC
2087:
Flavoring
extracts
and
flavoring
syrups,
n.
e.
c.
109
73
81
64
46
SIC
2999:
Products
of
petroleum
and
coal,
n.
e.
c.
110
108
92
104
135
Asbestos
manufacturing
111
84
123
107
99
SIC
3261:
Vitreous
china
plumbing
fixtures
and
china
and
earthenware
fittings
and
bathroom
accessories
112
93
129
132
100
SIC
2083:
Malt
113
b
93
b
b
SIC
2431:
Millwork
114
118
142
118
125
SIC
2439:
Structural
wood
members,
n.
e.
c.
115
123
119
138
137
SIC
2322:
Men's
and
boys'
underwear
and
nightware
116
b
144
142
b
SIC
2512:
Wood
household
furniture,
upholstered
117
96
140
135
96
SIC
2679:
Converted
paper
and
paperboard
products,
n.
e.
c.
118
132
139
136
143
SIC
2097:
Manufactured
ice
119
b
110
b
b
SIC
3251:
Brick
and
structural
clay
tile
120
126
137
116
140
SIC
2835:
In
vitro
and
in
vivo
diagnostic
substances
121
109
55
83
66
SIC
2653:
Corrugated
and
solid
fiber
boxes
122
103
131
127
128
Invalid
SIC
code
123
58
150
128
128
SIC
8741:
MANAGEMENT
SERVICES
(
1987)
124
b
82
110
127
SIC
2051:
Bread
and
other
bakery
products,
except
cookies
and
crackers
125
b
89
124
105
SIC
2052:
Cookies
and
crackers
126
b
124
b
b
SIC
2066:
Chocolate
and
cocoa
products
127
b
87
121
53
SIC
2732:
Book
printing
128
65
112
86
74
SIC
3050:
Gaskets,
packing,
and
sealing
devices
and
rubber
and
plastics
hose
and
belting
129
120
144
144
142
Table
D­
1
(
Continued)

Point
Source
Category/
SIC
Code
EAD
TWF
Hazard
RSEI
Risk­
Related
Results
TRI
Pounds
RSEI
Hazard
RSEI
Modeled
Hazard
D­
5
RSEIreport_
121203.
wpd
SIC
2800:
Chemicals
and
allied
products
130
112
117
117
116
SIC
2511:
Wood
household
furniture,
except
upholstered
131
121
126
134
131
SIC
2840:
Soap,
detergents,
and
cleaning
preparations;
perfumes,
cosmetics,
and
other
toilet
preparations
132
122
104
80
59
SIC
3273:
Ready
mixed
concrete
133
111
102
133
139
SIC
2517:
Wood
television,
radio,
phonograph,
and
sewing
machine
cabinets
134
110
141
139
136
SIC
2074:
Cottonseed
oil
mills
135
97
148
143
106
SIC
2657:
Folding
paperboard
boxes,
including
sanitary
136
124
116
88
79
SIC
2521:
Wood
office
furniture
137
116
106
129
120
SIC
2649:
Nonexistent
SIC
code
138
114
105
126
117
SIC
3991:
Brooms
and
brushes
139
129
127
97
90
SIC
2399:
Fabricated
textile
products,
n.
e.
c.
140
99
147
109
114
SIC
3259:
Structural
clay
products,
n.
e.
c.
141
b
144
141
b
Mineral
Mining
and
Processing
142
b
135
108
126
SIC
2674:
Uncoated
paper
and
multiwall
bags
143
125
136
112
102
SIC
2656:
Sanitary
food
containers,
except
folding
144
127
138
114
108
SIC
5142:
PACKAGED
FROZEN
FOODS
145
b
149
b
b
SIC
2541:
Wood
office
and
store
fixtures,
partitions,
shelving,
and
lockers
146
119
143
131
124
SIC
2080:
Beverages
147
131
130
137
73
SIC
2759:
Commercial
printing,
n.
e.
c.
148
128
151
140
138
SIC
3270:
CONCRETE
GYPSUM
AND
PLASTER
PRODUCTS
b
b
b
b
67
SIC
5144:
POULTRY
AND
POULTRY
PRODUCTS
b
b
b
b
89
SIC
6799:
INVESTORS
NEC
b
b
b
b
141
Carbon
black
manufacturing
b
b
125
90
b
SIC
2131:
Chewing
and
smoking
tobacco
and
snuff
b
b
98
b
b
SIC
2661:
BUILDING
PAPER
AND
BUILDING
BOARD
MILLS
(
DISC.
1987
2493
OR
2621)
b
b
113
b
b
SIC
3952:
Lead
pencils,
crayons,
and
artists'
materials
b
b
134
b
b
aRSEI
model
output
for
these
two
point
source
categories
are
identical
because
both
categories
are
comprised
of
the
same
SIC
code,
4953
(
Refuse
systems).
bPoint
source
category/
SIC
code
assigned
a
RSEI
output
result
of
zero.
Addendum­
1
RSEIreport_
121203.
wpd
ADDENDUM
DATA
CORRECTIONS
AND
REVISED
RESULTS
This
addendum
describes
the
manual
data
modifications
that
were
made
to
the
TRI
and
RSEI
data.
Several
specific
manual
changes
were
made
as
analyses
progressed.
More
information
on
specific
data
corrections
may
be
found
in
the
project
file
in
the
individual
industry
sections.
The
types
of
changes
that
were
made
include:


Assignment
of
representative
toxicity
weighting
factor
to
chemical
categories;


Addition
of
EAD
POTW
removal
efficiencies
for
chemicals
where
RSEI
model
POTW
removal
efficiencies
were
not
available;


Adjustment
of
primary
SIC
code.
Note
that
this
error
was
corrected
in
release
of
version
2.1
of
the
RSEI
model
(
July
2003);


Facility­
specific
data
modifications
based
on
additional
information
obtained
from
a
facility
or
from
EPA's
Online
Tracking
Information
System
(
OTIS);
and

Point
Source
Category
Adjustments.

As
additional
data
corrections
are
made,
they
will
be
incorporated
into
future
versions
of
TRIReleases2000,
the
database
containing
the
TRI
data
and
RSEI
model
output
used
in
this
report.

Assignment
of
EAD
Toxic
Weighting
Factors
(
TWFs)

EAD
Toxic
Weighting
Factors
(
TWFs)
were
used
to
assign
toxicity
values
to
the
chemicals
represented
in
the
RSEI
model
output.
There
were
many
chemicals
present
in
RSEI
that
did
not
have
a
TWF
value
listed
in
the
EAD
table.
EPA
identified
several
chemicals
that
lacked
TWFs
and
were
significant
(
in
terms
of
pounds
reported
or
modeled
risk
score).
EPA
then
performed
a
review
of
recent
effluent
limitations
and
guidelines
to
determine
whether
any
TWFs
could
be
Addendum­
2
RSEIreport_
121203.
wpd
identified
for
these
significant
chemicals.
EPA
also
contacted
Versar,
a
contractor
that
assisted
in
developing
the
EAD
TWF
table,
for
clarification
regarding
one
chemical
that
appeared
to
have
its
TWF
incorrectly
assigned
to
another
chemical.

Changes:
a)
Nitrate
compounds
(
CASNo
N511):

 
Assigned
a
TWF
of
0.000062,
and
 
Based
on
a
Versar
memo
from
Kathy
Coon
to
Kathy
Zirbser
titled
"
Surrogate
TWF
for
Nitrates,"
dated
11/
30/
98,
which
was
used
as
the
basis
for
a
nitrate
TWF
in
the
development
of
the
Iron
&
Steel
ELG
b)
Benzo(
g,
h,
i)
perylene
(
CASNo
191242):

 
Assigned
a
TWF
of
0.3,
and
 
Based
on
the
TWF
used
in
the
development
of
the
Iron
&
Steel
ELG
c)
Chlorine
dioxide
(
CASNo
10049044)

 
Assigned
a
TWF
of
0.0000069,
and
 
Based
on
a
Versar
memo
from
Kathy
Coon
and
Jim
Buchert
to
Carey
Johnston
titled
"
TWF
for
Chlorine
Dioxide,"
dated
5/
8/
03.

POTW
Removal
Efficiencies
The
RSEI
model
contains
POTW
removal
data
for
each
chemical
in
order
to
estimate
the
amount
of
a
reported
chemical
that
is
discharged
to
surface
water
following
treatment
at
a
POTW.
There
were
eleven
chemicals
for
which
RSEI
did
not
have
any
POTW
removal
data.
EPA
performed
a
review
of
recent
effluent
limitations
and
guidelines
to
determine
whether
typical
POTW
removal
efficiencies
were
identified
for
any
of
these
eleven
chemicals.
Addendum­
3
RSEIreport_
121203.
wpd
Changes:
a)
Dioxin
and
dioxin­
like
compounds
(
CASNo
N150)

 
Assigned
a
removal
efficiency
of
83%,
and
 
Based
on
the
removals
of
2,3,7,8­
TCDF
(
CASNo
51207319),
1,2,3,4,6,7,8­
HPCDF
(
CASNo
67562394),
and
1,2,3,4,6,7,8­
HPCDD
(
CASNo
35822469)
that
were
used
in
the
development
of
the
Transportation
Equipment
Cleaning
and
Iron
&
Steel
ELGs.

b)
Nitrate
compounds
(
CASNo
N511):

 
Assigned
a
removal
efficiency
of
90%,
and
 
Based
on
the
removal
of
nitrate/
nitrite
that
was
used
in
the
development
of
the
Iron&
Steel
ELG.

Primary
SIC
Code
Determination
Primary
SIC
code
designations
in
the
RSEI
model
output
were
modified
for
all
facilities.
For
a
given
facility,
the
RSEI
model
outputs
all
SIC
codes
that
were
reported
to
TRI
by
that
facility
(
SICCode1,
SICCode2,
SICCode3,
etc.).
All
analyses
up
to
this
point
were
performed
under
the
assumption
that
the
SIC
code
listed
under
"
SICCode1"
was
the
primary
SIC
code
for
the
facility,

as
described
in
the
RSEI
documentation.
All
analyses,
therefore,
used
the
SICCode1
to
identify
the
representative
industry
for
a
facility.
During
a
technical
review
of
the
RSEI
model
output,
it
was
discovered
that
the
output
SIC
codes
were
sorted
in
ascending
numeric
order
for
each
facility
(
i.
e.,
a
facility
reporting
the
three
SIC
codes
2621,
2622,
and
2611
would
have
an
output
"
SICCode1"
of
2611).
Therefore,
the
SIC
code
listed
under
"
SICCode1"
for
a
given
facility
was
not
necessarily
the
primary
SIC
code,
as
was
the
assumption
in
the
analyses
to
that
point.

The
TRI
Public
Data
Release
(
www.
epa.
gov/
tri/
tridata/
tri00/
index.
htm)
for
2000
lists
all
SIC
codes
that
were
reported
to
TRI
by
a
given
facility
and
maintains
the
correct
designation
of
the
primary
SIC
code.
These
data
were
used
to
correct
the
SIC
codes
contained
in
the
RSEI
model
output.
Addendum­
4
RSEIreport_
121203.
wpd
Change:
All
facilities
in
the
RSEI
model
output
were
assigned
new
primary
SIC
codes,
based
on
the
2000
TRI
Public
Data
Release.
This
affected
approximately
700
of
the
7,814
water
dischargers
in
the
RSEI
model
output.

In
addition,
several
facilities
reported
more
than
one
primary
SIC
code
to
TRI.
For
this
analyses,

it
was
necessary
to
identify
a
single
primary
SIC
code
for
each
facility.
The
SIC
codes
listed
in
the
revised
RSEI
model
output,
which
represents
all
water
dischargers
that
reported
to
TRI,
were
subject
to
the
reviews
and
changes
listed
above,
and
were
therefore
believed
to
be
the
most
accurate
source
of
facility
SIC
codes
available.

Change:
EPA
determined
that
it
would
be
appropriate
to
use
the
revised
RSEI
model
output
to
update
the
primary
SIC
codes
listed
for
all
water
dischargers
in
the
TRI
Public
Release.
All
non­
dischargers
present
in
the
TRI
Public
Release
did
not
have
their
SIC
codes
changed,
and
several
of
these
facilities
still
have
multiple
"
primary"
SIC
codes.

Point
Source
Category
Adjustments
Nonferrous
Metals
Manufacturing
facilities
in
SIC
Code
2819
SIC
Code
2819
(
Industrial
inorganic
chemicals,
n.
e.
c.)
was
originally
categorized
under
both
the
Inorganic
Chemicals
Manufacturing
Point
Source
Category
(
PSC)
and
the
Nonferrous
Metals
Manufacturing
Point
Source
Category.
EPA
reviewed
the
facilities
in
this
SIC
code
to
determine
which
facilities
could
clearly
be
assigned
to
the
Nonferrous
Metals
Manufacturing
PSC
(
i.
e.,
only
a
portion
of
the
TRI
pounds
and
TWPE
from
SIC
Code
2819
would
be
allocated
to
that
category).
EPA
identified
four
TRI
facilities
in
SIC
Code
2819
that
most
likely
have
operations
regulated
by
the
Nonferrous
Metals
Manufacturing
PSC.

Changes:
EPA
assigned
a
placeholder
SIC
Code
of
2819N
to
the
following
four
TRI
facilities.
This
SIC
code
was
then
combined
into
the
Nonferrous
Metals
Manufacturing
PSC,
along
with
SIC
Codes
3331,
3333,
3339,
and
3341:

a)
ALCOA
World
Alumina
­
Fort
Meade,
FL
Facility
ID:
33841­
LMNMC­
HWY63
b)
ALCOA
World
Alumina
­
Point
Comfort,
TX
Facility
ID:
77978­
LMNMC­
STATE
Addendum­
5
RSEIreport_
121203.
wpd
c)
LCOA
World
Chemicals
­
Bauxite,
AR
Facility
ID:
72011­
LCRKN­
USHIG
d)
U.
S.
Enrichment
Corp.
Portsmouth
Gaseous
Diffusion
­
Piketon,
OH
Facility
ID:
45661­
NTDST­
3930U
Phosphate
Manufacturing
Facilities
in
SIC
Code
2819
SIC
Code
2819
(
Industrial
inorganic
chemicals,
n.
e.
c.)
was
originally
categorized
under
both
the
Inorganic
Chemicals
Manufacturing
PSC
and
the
Phosphate
Manufacturing
PSC.
EPA
reviewed
facilities
in
this
SIC
code
to
determine
which
facilities
could
clearly
be
assigned
to
the
Phosphate
Manufacturing
PSC
(
i.
e.,
only
a
portion
of
the
PCS
pounds
and
TWPE
from
SIC
Code
2819
would
be
allocated
to
that
category).
EPA
did
not
identify
any
PCS
facilities
in
SIC
Code
2819
that
would
have
operations
regulated
by
the
Phosphate
Manufacturing
PSC.
SIC
2819
was
removed
from
the
Phosphate
Manufacturing
PSC.
A
placeholder
SIC,
2819P,
was
created
in
the
Phosphate
Manufacturing
PSC
for
SIC
2819
facilities
that
may
be
identified
in
the
future
as
Phosphate
Manufacturing
facilities.

Fertilizer
Facilities
in
SIC
Code
2874
SIC
Code
2874
(
Phosphatic
fertilizers)
was
originally
categorized
under
both
the
Fertilizer
Manufacturing
PSC
and
the
Phosphate
Manufacturing
PSC.
EPA
reviewed
facilities
in
this
SIC
code
to
determine
which
facilities
could
clearly
be
assigned
to
the
Fertilizer
Manufacturing
PSC
(
i.
e.,
only
a
portion
of
the
PCS
pounds
and
TWPE
from
SIC
Code
2874
would
be
allocated
to
that
category).
EPA
did
not
identify
any
PCS
facilities
in
SIC
Code
2874
that
most
likely
have
operations
regulated
by
the
Fertilizer
Manufacturing
PSC.
SIC
2874
was
removed
from
the
Fertilizer
Manufacturing
PSC.
A
placeholder
SIC,
2874F,
was
created
in
the
Fertilizer
Manufacturing
PSC
for
SIC
2874
facilities
that
may
be
identified
in
the
future
as
Fertilizer
Manufacturing
facilities.
Addendum­
6
RSEIreport_
121203.
wpd
Facility­
Specific
Modifications
The
following
facility
specific
modifications
were
made
to
RSEI
model
output
data
based
on
2000
TRI
data.

Chemical
Release
Adjustments
1)
Metallurgical
Products
­
West
Chester,
PA
Facility
ID:
19381MTLLR810LI
Background:
The
RSEI
model
showed
286
lbs
of
phosphorus
(
yellow)
being
discharged,
resulting
in
a
risk
score
of
1,581,998.
The
facility
was
contacted
to
determine
whether
the
report
was
erroneous.
The
facility
indicated
that
they
have
no
water
discharges
other
than
perhaps
stormwater.
The
facility
also
indicated
that
the
reported
discharge
was
actually
phosphates
or
phosphoric
acid,
not
elemental
phosphorus.
Change:
Releases
of
phosphorus
(
yellow)
were
changed
to
zero
for
all
fields
(
lbs,
hazard,
risk)
because
of
the
uncertainty
of
this
reported
discharge.

2)
Ulbrich
Precision
Flat
Wire
­
Westminster,
SC
Facility
ID:
29693STLHDPOBOX
Background:
For
2000
TRI
reporting,
the
facility
reported
on
Form
R,
Section
6.1.
that
100,000
lbs
of
copper
were
transferred
to
a
POTW.
These
totals
for
copper
were
actually
transferred
to
a
metals
recovery
facility.
Change:
Copper
discharges
were
removed
from
the
database.

3)
Bridgeport
Insulated
Wire
Co.
­
Stratford,
CT
Facility
ID:
06497BRDGP514SU
Background:
For
2000
TRI
reporting,
the
facility
reported
on
Form
R,
Section
6.1
that
40,708
lbs
of
copper
were
transferred
to
a
POTW.
These
totals
for
copper
were
actually
transferred
to
a
metals
recovery
facility.
Change:
Copper
discharges
were
removed
from
the
database.
Addendum­
7
RSEIreport_
121203.
wpd
4)
Allied
Foods
L.
L.
­
Atlanta,
GA
Facility
ID:
30318LLDFD1450H
Background:
For
2000
TRI
reporting,
the
facility
reported
on
Form
R,
Section
6.1
that
352,261
lbs
of
copper
were
transferred
to
a
POTW.
These
totals
for
copper
were
actually
transferred
to
a
metals
recovery
facility.
Change:
Copper
discharges
were
removed
from
the
database.

5)
Oxy
Vinyl
L.
P
­
Deer
Park,
TX
Facility
ID:
77536CCDNT1000T
Background:
Chris
Burrel
of
Oxy
Vinyl
indicated
during
a
telephone
conversation
on
September
17,
2003
that
the
Deer
Park
facility
has
closed.
Neither
of
the
two
other
Oxy
Vinyl
plants
in
Texas
release
dioxins
to
surface
waters.
Change:
Releases
of
dioxins
for
the
Deer
Park
facility
were
removed
from
the
database.

6)
Norit
America
­
Marshall,
TX
Facility
ID:
75670MRCNNWESTE
Background:
Pollutant
loads
for
this
facility
are
reported
in
both
the
Inorganic
Chemicals
Manufacturing
industry
category
and
the
Phosphate
Manufacturing
industry
category.
The
facility
was
contacted
and
Curtis
Miles
of
Norit
America
confirmed
that
the
pollutant
loads
should
only
be
included
in
the
Inorganic
Chemicals
Manufacturing
category.
Change:
Pollutant
loads
were
reviewed
to
ensure
that
loads
were
only
associated
with
the
Inorganic
Chemicals
Manufacturing
category.

SIC
Code
Adjustments
1)
Conoco
Phillips
Refinery
­
Lake
Charles,
LA
Facility
ID:
70669CNCLKOLDSP
Background:
This
facility's
primary
SIC
was
incorrect
in
the
RSEI
model
output.
All
other
environmental
databases
(
as
presented
in
OTIS)
listed
the
primary
SIC
code
as
2911.
Change:
The
SIC
code
for
this
facility
was
changed
from
2893
to
2911.

2)
Dow
Chemical
Co.
­
Freeport,
TX
Facility
ID:
77541THDWCBUILD
Background:
The
primary
SIC
code
reported
to
TRI
was
2812
(
Alkalies
and
Chlorine);
however,
a
search
of
the
EPA
web
tool
OTIS
(
http://
www.
epa.
gov/
idea/
otis/
mm_
idea_
query.
html)
identified
SIC
code
2869
(
Industrial
organic
chemicals,
n.
e.
c.)
as
the
primary
SIC
code
for
the
facility's
NPDES
permits.
Change:
The
SIC
code
for
this
facility
was
changed
from
2812
to
2869.
Addendum­
8
RSEIreport_
121203.
wpd
3)
Dow
Chemical
Co.
­
Plaquemine,
LA
Facility
ID:
70765THDWCHIGHW
Background:
This
facility
has
multiple
SIC
codes
listed
as
being
the
primary
SIC
code
in
the
TRI
data.
A
search
of
the
EPA
web
tool
OTIS
identified
SIC
code
2869
(
Industrial
organic
chemicals,
n.
e.
c.)
as
the
primary
SIC
code
for
the
facility's
NPDES
permits.
Change:
The
SIC
code
for
this
facility
was
changed
from
2791/
2796/
2812
to
2869.

4)
Exxon
Chemical
Baton
Rouge
Chemical
Plant
­
Baton
Rouge,
LA
Facility
ID:
70805XXNCH4999S
Background:
The
primary
SIC
code
reported
to
TRI
was
2869;
however,
a
search
of
OTIS
identified
SIC
code
2821
(
Plastics
materials,
synthetic
resins,
and
non­
vulcanizable
elastomers)
as
the
primary
SIC
code
for
the
facility's
NPDES
permit.
Change:
The
SIC
code
for
this
facility
was
changed
from
2869
to
2821.

5)
Exxon
Mobil
Chemical
Co.
Baytown
Olefins
Plant
­
Baytown,
TX
Facility
ID:
77522XXNCH3525D
Background:
The
primary
SIC
code
reported
to
TRI
was
2822
(
Synthetic
rubber
(
vulcanizable
elastomers));
however,
a
search
of
OTIS
identified
SIC
code
2869
as
the
primary
SIC
code
for
the
facility's
NPDES
permit.
Change:
The
SIC
code
for
this
facility
was
changed
from
2822
to
2869.

6)
PPG
Industries,
Inc.
­
Lake
Charles,
LA
Facility
ID:
70669PPGNDCOLUM
Background:
The
primary
SIC
code
reported
to
TRI
was
2812
(
Alkalies
and
Chlorine);
however,
a
search
of
the
EPA
web
tool
OTIS
identified
SIC
code
2869
(
Industrial
organic
chemicals,
n.
e.
c.)
as
the
primary
SIC
code
for
the
facility's
NPDES
permits.
Change:
The
SIC
code
for
this
facility
was
changed
from
2812
to
2869.

Note:
There
are
two
other
facilities
that
were
reviewed
and
that
received
manual
SIC
code
changes.
This
was
performed
prior
to
the
SIC
code
update
using
the
TRI
Public
Release.
The
SIC
codes
assigned
to
these
facilities
by
the
TRI
data
were
the
same
as
the
SIC
codes
that
had
been
selected
during
the
facility
review.
Therefore,
there
was
no
need
to
perform
a
manual
change
for
these
facilities.

7)
Noveon,
Inc.
­
Lawrence,
MA
Facility
ID:
01843BFGDRONEJA
Background:
This
Facility
ID
was
associated
with
an
incorrect
name
and
SIC
code
in
the
RSEI
model
output.
Change:
The
facility
name
was
changed
from
Global
Revco
Terminal
L.
L.
C.
to
Noveon,
Inc.
and
the
SIC
code
was
changed
from
5171
to
2891.
Addendum­
9
RSEIreport_
121203.
wpd
8)
Kimberly­
Clark
Tissue
Co,
Everett,
WA
Facility
ID:
98201SCTTP2600F
Background:
The
primary
SIC
code
reported
to
TRI
was
2611
(
Pulp
mills);
however,
based
on
EPA's
recent
investigation
of
the
pulp
and
paper
industry,
the
primary
SIC
code
for
the
facility's
NPDES
permit
was
identified
as
2621.
Change:
The
SIC
code
for
this
facility
was
changed
from
2611
to
2621.

9)
All
SIC
codes
for
facilities
in
SIC
codes
2611,
2621,
and
2631
were
modified
to
represent
three
phases
of
regulation
of
the
pulp,
paper,
and
paperboard
industry:
Background:
Three
SIC
codes
are
used
to
classify
the
pulp
and
paper
industry,
according
to
the
primary
product
shipped:
2611­
Pulp
Mills,
2621­
Paper
Mills,
and
2631­
Paperboard
Mills.
Change:
The
list
of
facilities
within
these
SIC
codes
was
reviewed
to
properly
classify
the
facilities
into
the
appropriate
Pulp
and
Paper
Category
Phase.
The
facilities
listed
were
compared
to
a
list
of
facilities
that
are
covered
by
the
Phase
I
regulations,
and
to
a
list
of
facilities
covered
by
the
Phase
III
regulations.
Facilities
not
identified
as
Phase
I
or
Phase
III
were
classified
as
Phase
II.

SIC
placeholder
codes
were
created
to
represent
the
three
pulp
phases
at
each
of
the
three
SIC
codes:
2611­
1
2611­
2
2611­
3
2621­
1
2621­
2
2621­
3
2631­
1
2631­
2
2631­
3
Toxic
Weighted
Pound
Equivalent
(
TWPE)
Adjustments
1)
Pepco
Chalk
Point
Generating
Station
­
Aquasco,
MD
Facility
ID:
20608CHLKP25100
Background:
The
reported
PACs
category
discharge
was
an
isolated
event
(
i.
e.,
a
spill)
and
not
representative
of
typical
discharges
at
this
plant
or
of
this
industry
(
SIC
code
4911).
Change:
The
pounds
of
PACs
were
deleted.

2)
For
facilities
in
SIC
code
2812
or
2816
that
reported
dioxin
congener
distributions,
TWPE
adjustments
were
made
to
reflect
the
distribution
of
congeners
and
associated
TWFs.
The
percentage
distribution
of
dioxins
and
the
TWFs
of
specific
dioxin
congeners
were
used
to
calculate
a
facility­
specific
weighted
average
dioxin
TWF.
For
those
facilities
that
did
not
report
a
distribution,
the
median
TWF
value
was
used
to
estimate
the
TWPE.

3)
An
analysis
was
performed
to
determine
a
representative
TWPE
for
polycyclic
aromatic
compounds
(
PACs)
in
the
PBST
industry
category.
No
TWF
is
available
for
the
TRI
chemical
group
PACs.
However,
TWFs
are
available
for
8
of
the
21
individual
compounds
included
in
this
chemical
group.
In
addition,
discharge
loads
Addendum­
10
RSEIreport_
121203.
wpd
for
individual
PACs
were
reported
in
PCS
2000.
EPA
calculated
a
weighted
TWF
from
available
discharge
data
for
PACs
from
PCS.
This
value,
219.3411,
was
applied
to
the
pounds
of
PACs
releases
reported
in
TRI,
to
calculate
TWPE
for
facilities
within
the
PBST
industry
category.

Revised
Results
After
the
data
corrections
in
this
addendum
were
incorporated
into
TRIReleases2000,
the
TWPE
values
were
regenerated
for
each
point
source
category.
The
updated
rankings
are
presented
in
Tables
A­
1
and
A­
2.


Table
A­
1
presents
the
2000
TRI
TWPEs
and
rankings
for
point
source
categories
regulated
by
existing
effluent
guidelines;
and

Table
A­
2
presents
the
2000
TRI
TWPEs
and
rankings
for
industry
groupings
not
regulated
by
existing
effluent
guidelines.
Addendum­
11
RSEIreport_
121203.
wpd
Table
A­
1
Toxic­
Weighted
Pound
Equivalents
Discharges
by
Industries
Regulated
by
Existing
Effluent
Guidelines
40
CFR
Part
Point
Source
Category
TRI
Reported
Toxic­
Weighted
Pound
Equivalents
TRI
Reported
Step
1
Rankings
Step
6B
Rankings
405
Dairy
products
processing
5,829
37
27
406
Grain
mills
manufacturing
8,610
35
25
407
Canned
and
preserved
fruits
and
vegetable
processing
17,649
29
20
408
Canned
and
preserved
seafood
20
49
37
409
Sugar
processing
284
43
32
410
Textile
mills
84,754
19
12
411
Cement
manufacturing
10,827
33
23
412
Concentrated
animal
feeding
operations
(
CAFO)
N/
A
N/
C
N/
C
413
Electroplating
41,380
23
N/
C
414
Organic
chemicals,
plastics
and
synthetic
fibers
31,598,863
1
1
415
Inorganic
chemicals
manufacturing
630,218
12
7
417
Soaps
and
detergents
manufacturing
362
42
31
418
Fertilizer
manufacturing
61,273
20
13
419
Petroleum
refining
2,394,632
4
3
420
Iron
and
steel
manufacturing
1,685,493
6
N/
C
421
Nonferrous
metals
manufacturing
978,450
8
6
422
Phosphate
manufacturing
255
44
33
423
Steam
electric
power
generation
1,854,204
5
4
424
Ferroalloy
manufacturing
22,131
27
18
425
Leather
tanning
and
finishing
28,670
24
16
426
Glass
manufacturing
1,875
38
28
427
Asbestos
manufacturing
6
51
38
428
Rubber
manufacturing
166,343
14
8
429
Timber
products
processing
5,546,567
2
2
430
Pulp,
paper
and
paperboard
(
Phase
III)
319,244
13
N/
C
430
Pulp,
paper
and
paperboard
(
Phase
I)
3,575,766
3
N/
C
430
Pulp,
paper
and
paperboard
(
Phase
II)
1,336,418
7
5
432
Meat
products
processing
16,783
30
N/
C
433
Metal
finishing
842,890
11
N/
C
434
Coal
mining
22,472
26
N/
C
435
Oil
and
gas
extraction
8
50
N/
C
436
Mineral
mining
and
processing
0
52
39
Table
A­
1
(
Continued)

40
CFR
Part
Point
Source
Category
TRI
Reported
Toxic­
Weighted
Pound
Equivalents
TRI
Reported
Step
1
Rankings
Step
6B
Rankings
Addendum­
12
RSEIreport_
121203.
wpd
437
Centralized
waste
treatment
N/
A
N/
C
N/
C
438
Metal
products
and
machinery
45
47
N/
C
439
Pharmaceutical
manufacturing
105,119
17
N/
C
440
Ore
mining
and
dressing
52,627
21
14
442
Transportation
equipment
cleaning
N/
A
N/
C
N/
C
443
Paving
and
roofing
materials
(
tars
and
asphalt)
27
48
36
444
Waste
combustors
874,852
9
N/
C
445
Landfills
874,852
9
N/
C
446
Paint
formulating
916
39
29
447
Ink
formulating
51
45
34
450
Construction
and
development
N/
A
N/
C
N/
C
451
Aquatic
animal
production
industry
N/
A
N/
C
N/
C
454
Gum
and
wood
chemicals
50
46
35
455
Pesticide
chemicals
13,281
31
21
457
Explosives
381
41
30
458
Carbon
black
manufacturing
N/
A
N/
C
N/
C
459
Photographic
N/
A
N/
C
N/
C
460
Hospital
724
40
N/
C
461
Battery
manufacturing
8,047
36
26
463
Plastic
molding
and
forming
106,189
15
9
464
Metal
molding
and
casting
45,182
22
15
465
Coil
coating
11,764
32
22
466
Porcelain
enameling
92,174
18
11
467
Aluminum
forming
25,035
25
17
468
Copper
forming
22,071
28
19
469
Electrical
and
electronic
components
9,800
34
24
471
Nonferrous
metals
forming
and
metal
powders
105,540
16
10
Note:
"
N/
A"
means
not
available
and
"
N/
C"
means
not
calculated.
EPA
may
not
have
calculated
a
rank
due
to
lack
of
TRI
data
(
e.
g.,
coil
coating).
EPA
may
also
have
been
unable
to
identify
the
pollutant
loadings
for
the
various
subcategories
within
a
point
source
category.
This
is
important
when
trying
to
identify
subcategories
or
wastewater
discharges
from
industrial
operations
not
subject
to
any
exclusions
identified
in
Step
2.

Note:
The
TWPE
estimates
for
both
Waste
Combustors
(
Part
444)
and
Landfills
(
Part
445)
are
the
same
as
EPA
used
the
same
SIC
code
(
Refuse
Systems
(
4953))
to
estimate
loadings
for
both
categories.
EPA
will
refine
these
TWPE
estimates
for
the
final
record
by
using
the
facilities
identified
in
these
rulemaking
records.
Addendum­
13
RSEIreport_
121203.
wpd
Table
A­
2
Toxic­
Weighted
Pound
Equivalents
Discharges
by
Industries
Not
Regulated
by
Existing
Effluent
Guidelines
SIC
Code
Industrial
Sector
TRI
Reported
Toxic­
Weighted
Pound
Equivalents
TRI
Reported
Step
1
Rankings
Step
6B
Rankings
Two­
Digit
SIC
Code
Data
9
Fishing,
Hunting,
&
Trapping
N/
A
N/
C
N/
C
16
Heavy
Construction,
Except
Building
N/
A
N/
C
N/
C
20
Food
&
Kindred
Products
24,500
N/
C
N/
C
21
Tobacco
Products
6,131
N/
C
N/
C
23
Apparel
&
Other
Textile
Products
53
N/
C
N/
C
24
Lumber
&
Wood
Products
14,656
N/
C
N/
C
25
Furniture
&
Fixtures
2
N/
C
N/
C
26
Paper
&
Allied
Products
1,622
N/
C
N/
C
27
Printing
&
Publishing
280
N/
C
N/
C
28
Chemical
&
Allied
Products
164,662
N/
C
N/
C
29
Petroleum
&
Coal
Products
5,698
N/
C
N/
C
30
Rubber
and
miscellaneous
plastics
products
0
N/
C
N/
C
32
Stone,
Clay,
&
Glass
Products
5,561
N/
C
N/
C
34
Fabricated
metal
products
0
N/
C
N/
C
39
Misc.
Manuf.
Industries
0
N/
C
N/
C
40
Railroad
Transportation
N/
A
N/
C
N/
C
42
Trucking
&
Warehousing
N/
A
N/
C
N/
C
44
Water
Transportation
N/
A
N/
C
N/
C
46
Pipelines,
Except
Natural
Gas
N/
A
N/
C
N/
C
47
Transportation
Services
N/
A
N/
C
N/
C
49
Electric,
Gas,
&
Sanitary
Services
17,957
N/
C
N/
C
50
Wholesale
Trade­
Durable
Goods
287
N/
C
N/
C
51
Wholesale
Trade­
Nondurable
Goods
275
N/
C
N/
C
65
Real
Estate
N/
A
N/
C
N/
C
67
Holding
&
Other
Investment
Offices
0
N/
C
N/
C
73
Business
Services
88,810
N/
C
N/
C
82
Educational
Services
N/
A
N/
C
N/
C
87
Engineering
&
Management
Services
124,717
N/
C
N/
C
89
Services,
Not
Elsewhere
Classified
566
N/
C
N/
C
91
Executive,
Legislative,
&
General
36,734
N/
C
N/
C
92
Justice,
Public
Order,
&
Safety
N/
A
N/
C
N/
C
Table
A­
2
(
Continued)

SIC
Code
Industrial
Sector
TRI
Reported
Toxic­
Weighted
Pound
Equivalents
TRI
Reported
Step
1
Rankings
Step
6B
Rankings
Addendum­
14
RSEIreport_
121203.
wpd
95
Environmental
Quality
&
Housing
18,458
N/
C
N/
C
96
Administration
of
Economic
Programs
N/
A
N/
C
N/
C
97
National
Security
&
International
Affairs
3,647
N/
C
N/
C
99
Non
classifiable
Establishments
1
N/
C
N/
C
Industry
Sectors
Identified
by
Stakeholders
45
Airport
Industrial
Discharges
N/
A
N/
C
N/
C
273
Aquatic
Animal
Production
N/
A
N/
C
N/
C
15
Storm
Water
Discharges
from
Construction
and
Development
N/
A
N/
C
N/
C
8021
Dental
Facilities
N/
A
N/
C
N/
C
4941
Drinking
Water
Supply
and
Treatment
7
2
1
581
Food
Service
Establishments
N/
A
N/
C
N/
C
4959
Groundwater
Remediation
N/
A
N/
C
N/
C
8071
Independent
&
Stand
Alone
Laboratories
N/
A
N/
C
N/
C
7218
Industrial
Laundries
N/
A
N/
C
N/
C
4481
Ocean
Going
Vessels
N/
A
N/
C
N/
C
27
Printing
&
Publishing
280
1
N/
C
9223
Prisons
N/
A
N/
C
N/
C
N/
A
Municipal
Storm
Water
Runoff
N/
A
N/
C
N/
C
4952
Wastewater
Treatment
and
Sewerage
Systems
N/
A
N/
C
N/
C
Note:
"
N/
A"
means
not
available
and
"
N/
C"
means
not
calculated.
EPA
may
not
have
calculated
a
rank
due
to
lack
of
TRI
data
(
e.
g.,
tobacco
products).
