1This
preliminary
Plan
was
signed
by
EPA's
Assistant
Administrator
for
Water
on
December
23,
2003.
It
is
expected
to
be
published
in
the
Federal
Register
on
December
31,
2003.

2See
"
Description
and
Results
of
EPA
Methodology
to
Synthesize
Screening
Level
Results
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005,"
DCN
548,
Section
3.0.

Page
1
of
4
Memorandum
From:
Carey
A.
Johnston,
P.
E.
USEPA/
OW/
OST
ph:
(
202)
566
1014
johnston.
carey@
epa.
gov
To:
Public
Record
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005
DCN
00706,
Section
2.2.3
EPA
Docket
Number
OW­
2003­
0074
(
www.
epa.
gov/
edockets/)

Date:
December
30,
2003
Re:
Factor
2
Screening
Level
Information
on
the
Plastics
Products
Manufacturing
Industry
Overview
Under
the
Clean
Water
Act
(
CWA),
EPA
establishes
technology­
based
national
regulations,
termed
"
effluent
guidelines,"
to
reduce
pollutant
discharges
from
industrial
facilities
to
waters
of
the
United
States.
Section
304(
m)
of
the
Clean
Water
Act
(
CWA)
requires
EPA
to
publish
an
Effluent
Guidelines
Program
Plan
every
two
years.
CWA
Section
304(
m)(
1)(
A)
also
requires
EPA
to
establish
a
schedule
for
the
annual
review
and
revision
of
all
existing
effluent
guidelines.
Additionally,
CWA
Section
304(
m)(
1)(
B)
requires
EPA
to
identify
categories
of
point
sources
discharging
toxic
or
non­
conventional
pollutants
for
which
EPA
has
not
published
effluent
guidelines.

The
preliminary
Effluent
Guidelines
Program
Plan
for
2004/
20051
described
the
four
factors
EPA
considered
during
its
screening­
level
analyses.
Factor
2
(
Technology
Advances
and
Process
Changes)
considers
applicable
and
demonstrated
technologies,
process
changes,
or
pollution
prevention
alternatives
that
can
effectively
reduce
the
pollutants
remaining
in
an
industry
category's
wastewater
and
thereby
substantially
reduce
any
identified
risk
to
human
health
or
the
environment
associated
with
those
pollutants.
This
memo
summarizes
the
Factor
2
screening
level
information
gathered
on
the
plastics
products
manufacturing
industry.
Sectors
of
this
industry
were
identified
in
EPA's
outreach
activities,
however,
this
industry
was
not
identified
for
further
data
collection
in
the
current
effluent
guidelines
planning
cycle.
2
Page
2
of
4
Plastics
Products
Manufacturing
Industry
The
plastics
products
manufacturing
industry
(
SIC
308)
is
continuing
to
grow
as
an
increasing
number
of
products
are
manufactured
from
plastics.
In
addition,
the
National
Sediment
Contaminant
Point
Source
Inventory
identified
the
Plastic
Materials
industrial
category
as
a
discharger
of
sediment
contaminants.
Plastics
products
manufacturing
is
currently
subject
to
the
Effluent
Limitation
Guideline
(
ELG)
for
the
Plastic
Molding
and
Forming
Point
Source
Category
(
40
CFR
463),
promulgated
in
1984
and
revised
in
1985.

Technology
Advances
Several
technological
advances
in
plastics
manufacturing
have
increased
the
use
of
plastics
in
the
construction
sector.
For
example,
Wood­
Plastic
Composite
(
WPC)
manufacturing
is
increasing.
A
better
understanding
of
wood,
equipment
advances,
and
additive
developments
has
made
WPC
manufacturing
more
effective
since
the
1990s.
Decking
materials
are
the
largest
and
fastest
growing
WPC
market,
driven,
in
part,
by
concerns
about
arsenic
leaching
from
pressure
treated
wood.
WPC
use
in
decks
is
projected
to
more
than
double,
reaching
a
20
percent
market
share
by
2005.
The
increased
use
of
WPC
will
increase
the
wastewater
produced
during
WPC
manufacturing.

The
use
of
Fiber­
Reinforced
Polymer
(
FRP)
composites
is
also
increasing.
FRP
is
a
very
durable
composite
which
can
be
used
to
resurface
roads.
A
project
started
in
2001
is
underway
to
resurface
bridges
with
FRP
throughout
Ohio,
using
hundreds
of
millions
of
pounds
of
FRP.
The
large
quantity
of
FRP
needed
for
construction
projects
might
create
an
increase
in
plastics
manufacturing,
increasing
the
volume
of
wastewater
generated.

Research
is
currently
being
performed
to
further
the
applicability
of
plastics
to
the
automotive
sector.
The
organic
chemistry
of
plastic
is
being
investigated
to
develop
polymers
that
can
be
used
in
chassis/
drivetrain
applications
and
the
structural
framework
of
vehicles.
Plastics
are
being
developed
that
will
provide
a
finished
exterior
similar
to
paint.
The
new
plastic
polymers
may
produce
unique
types
of
wastewater
discharges.

Plastics
demand
will
also
increase
in
the
electronic
sector.
Plastics
may
be
used
instead
of
silicon
as
a
substrate
for
organic
semiconductors,
which
are
used
in
electronic
price
tags,
photovoltaic
cells,
and
light
emitting
displays.
Although
plastic
semiconductors
are
not
capable
of
the
same
high
speed
conductivity
as
silicon
semiconductors,
plastic
is
less
expensive
and
easier
to
manufacture
than
silicon.
Plastic
semiconductors
are
an
alternative
in
products
where
high
powered
silicon
semiconductors
are
not
needed.
The
introduction
of
plastics
in
the
fast
growing
electronics
sector
is
expected
to
increase
plastics
production
and
the
wastewater
produced
during
plastics
production.
Page
3
of
4
Wastewater
Generation
and
Treatment
Regulated
pollutants
for
the
plastics
products
manufacturing
industry
include
the
conventional
pollutants
biochemical
oxygen
demand
(
BOD5),
oil
and
grease,
total
suspended
solids
(
TSS),
and
pH,
and
the
priority
pollutants
bis
(
2­
ethylhexyl)
phthalate,
di­
n­
butyl
phthalate,
and
dimethyl
phthalate.
EPA's
selected
technology
basis
for
the
1985
rule
to
control
conventional
pollutants
and
certain
toxic
pollutants,
such
as
phenol
and
zinc,
comprises
biological
treatment
and
settling
with
equalization
and
pH
adjustment.
At
that
time,
EPA
also
identified
activated
carbon
as
a
control
technology
for
the
phthalates,
but
reserved
limitations
for
both
direct
and
indirect
dischargers
due
to
the
lack
of
treatment
performance
data.
Phthalates
are
plasticizers
commonly
added
to
plastics
to
make
them
flexible.
If
flexibility
is
not
a
desired
product
attribute,
phthalates
are
not
used
and
are
not
present
in
process
wastewater.
All
other
nonconventional
pollutants
of
concern
identified
for
the
1985
rule
(
i.
e.,
chemical
oxygen
demand,
total
organic
carbon,
and
total
phenols)
are
controlled
by
regulation
of
other
regulated
pollutants,
and
all
other
priority
pollutants
were
either
not
present,
detected
in
only
a
small
number
of
samples
(
less
than
10
percent
of
samples),
or
not
present
at
treatable
concentrations.

Pollutants
with
the
potential
for
release
to
air
and
water
include
toxic
additive
chemicals
such
as
blowing
agents,
flame
retardants,
and
plasticizers,
as
well
as
conventional
pollutants.
However,
according
to
TRI
release
information
in
reporting
year
1999,
effluent
discharges
and
hazardous
waste
releases
are
dwarfed
by
air
emissions.
Preliminary
review
of
2000
PCS
data
for
SIC
308
identifies
a
wide
variety
of
pollutants
monitored,
including
nutrients,
cyanide,
metals,
volatile
and
semivolatile
organics
and
residual
chlorine.
Additional
review
and
analysis
of
the
data
is
required
to
determine
whether
these
additional
pollutants
of
concern
are
generated
by
plastics
products
manufacturing
or
by
other
processes
onsite,
such
as
chemicals
manufacturing.

Facilities
with
significant
cleaning
operations
require
treatment,
such
as
biological
treatment
and
settling,
to
remove
dissolved
and
suspended
pollutants
to
achieve
the
monthly
average
effluent
limitations
for
the
Cleaning
Water
Subcategory
of
22
mg/
L
for
BOD5,
17
mg/
L
for
oil
and
grease,
and
36
mg/
L
for
TSS.
Facilities
without
significant
cleaning
operations
(
e.
g.,
facilities
that
perform
only
contact
cooling
and
heating
and/
or
finishing)
can
achieve
the
effluent
limitations
using
gravity
settling
and
oil
skimming.
In
fact,
dissolved
organic
pollutant
concentrations
at
these
facilities
(
e.
g.,
BOD5
less
than
6
mg/
L)
may
be
inadequate
to
support
biological
activity.
Gravity
settling
and
oil
skimming
technologies
were
commonly
used
by
plastics
products
manufacturing
facilities
in
the
early
1980s
when
the
effluent
limitations
were
developed,
while
biological
treatment
and
activated
carbon
were
not.

Opportunities
for
improved
control
of
pollutants
of
concern
include
product
substitution
for
bis
(
2­
ethylhexyl)
phthalate
and
improved
end­
of­
pipe
treatment.
Bis
(
2­
ethylhexyl)
phthalate,
determined
by
the
U.
S.
Department
of
Health
and
Human
Services
as
reasonably
anticipated
to
be
a
human
carcinogen,
remains
a
common
plasticizer.
Concerns
regarding
exposure
to
bis
(
2­
ethylhexyl)
phthalate
have
resulted
in
its
reduction,
elimination,
or
substitution
in
the
manufacture
of
certain
products
such
as
pacifiers,
other
baby
products
and
toys,
and
plastic
wrap
Page
4
of
4
used
by
the
food
industry.
Possible
substitutes
include
linear
phthalates
and
other
plastomers.

Facilities
operating
biological
treatment
systems
likely
achieve
significant
removals
of
phthalates.
For
example,
the
Fate
of
Priority
Pollutants
in
Publicly
Owned
Treatment
Works
(
a.
k.
a.,
"
50
POTW
Study")
shows
an
activated
sludge
treatment
removal
rate
of
60
percent
for
bis
(
2­
ethylhexyl)
phthalate,
and
an
onsite
biological
treatment
system
acclimated
to
bis
(
2­
ethylhexyl)
phthalate
would
be
expected
to
achieve
similar
or
enhanced
removals
as
compared
to
a
POTW.
Activated
carbon
would
provide
additional
wastewater
polishing
to
remove
any
remaining
phthalates
and
other
pollutants
amenable
to
carbon
adsorption.

The
plastics
products
manufacturing
industry
was
also
identified
as
a
probable
point
source
contributor
of
sediment
pollutants
by
the
1997
National
Sediment
Containment
Point
Source
Inventory.
Several
treatment
technologies,
such
as
filtration
and
chemically­
assisted
clarification,
can
achieve
enhanced
solids
removals
beyond
those
achieved
by
gravity
settling.
For
example,
sand
filtration
and
multimedia
filtration
systems
typically
remove
small
amounts
of
suspended
solids
entrained
in
effluent
from
gravity
clarifiers.
Sand
and
multimedia
polishing
filters
usually
are
designed
to
remove
90
percent
or
greater
of
all
filterable
suspended
solids
20
microns
or
larger
at
a
maximum
influent
concentration
of
40
mg/
L.
