REVIEW
OF
THE
GROUP
II
AND
OTHER
INDUSTRIES
IDENTIFIED
BY
FACTOR
ONE
IN
THE
SCREENING
LEVEL
ANALYSIS
2004/
05
CWA
304(
m)
PLAN
December
15,
2003
Introduction
Section
304(
m)
of
the
Clean
Water
Act
(
CWA)
requires
EPA
to
establish
a
schedule
for
the
annual
review
of
existing
effluent
limitations
guidelines
and
for
the
revision
of
any
guidelines,
as
appropriate.
EPA
also
must
identify
categories
of
sources
that
discharge
toxic
or
nonconventional
pollutants
directly
to
surface
waters
for
which
effluent
limitations
guidelines
have
not
been
published
and
establish
a
schedule
for
promulgation
of
guidelines
for
those
pollutants.

EPA
recently
completed
a
screening
level
analysis
to
identify
industries
that
should
be
included
in
the
2004/
05
304(
m)
plan.
Based
on
the
results
of
that
analysis,
EPA
sorted
industries
into
groups
to
prioritize
further
review.
The
Agency
will
focus
its
resources
on
the
review
of
the
Group
I
industries
followed
by
the
Group
II
industries.
For
the
remaining
industries
identified
by
Factor
One
but
for
which
EPA
has
numerous
data
gaps,
EPA
will
continue
to
collect
and
analyze
information
as
time
and
resources
permit.
For
more
information
on
the
screening
level
analysis
and
prioritization
of
industries
for
further
review,
see
the
memorandum,
"
Description
and
Results
of
EPA
Methodology
to
Synthesize
Screening
Level
Results
for
the
CWA
304(
m)
Effluent
Guidelines
Program
Plan
for
2004/
2005,"
Docket
Section
3.0,
DCN
00548.

In
general,
EPA
will
analyze
data
in
the
Permit
Compliance
System
(
PCS)
and
Toxic
Release
Inventory
(
TRI)
databases
and
other
available
sources
to
develop
and
analyze
the
following
types
of
information
for
the
Group
II
industries:

°
Geographic
distribution
(
including
a
spreadsheet
with
facility
identification
information);
°
Raw
wastewater
pollutant
loads
and
concentration;
°
Wastewater
flow
rates;
°
Onsite
wastewater
treatment;
°
Discharge
status
(
direct,
indirect,
and
zero);
°
Discharge
wastewater
pollutant
loads
and
concentrations
(
include
by
discharge
status
and
by
facilities
representing
90
percent
of
the
total
industry
loads
in
pounds
and
pound­
equivalents);
°
Multimedia
environmental
releases;
and
°
Industry
trends.

This
document
discusses
the
plan
to
conduct
the
review
of
the
Group
II
and
Other
Industries
Identified
by
Factor
1.
It
identifies
the
Group
II
and
Other
Factor
One
industries,
lists
potential
sources
of
information,
identifies
queries
to
be
made
of
the
PCS
and
TRI
databases,
and
identifies
stakeholder
comments
that
will
be
investigated.
Review
Plan
December
15,
2003
Page
2
1For
more
information
on
the
PCSLoads2000
database
and
its
development,
please
see
Development
of
PCS
Loads
2000,
Docket
Section
2.1.2,
DCN
00620.
For
more
information
on
the
TRIReleases2000
database,
please
see
Evaluation
of
RSEI
Model
Runs,
Docket
Section
2.1.1,
DCN
00618.
Information
Sources
There
are
several
sources
of
information
that
may
be
used
during
the
review
of
the
Group
II
and
Other
Factor
One
industries.
They
include,
but
are
not
limited
to,
the
following:

°
Current
effluent
limitations
guidelines
and
standards;
°
Technical
development
documents;
°
Guidance
documents;
°
Other
Agency
program
data;
°
Other
literature;
°
1997
Economic
Census;
°
Permit
Compliance
System
(
PCS)
database;
°
Toxic
Release
Inventory
(
TRI)
database;
°
Online
Tracking
Information
System
(
OTIS)
containing
information
on
National
Pollutant
Elimination
System
(
NPDES)
permits
(
http://
www.
epa.
gov/
idea/
otis/
mm_
idea_
query.
html);
°
TRI
Form
R
Query
Form
containing
information
on
pollutant
releases
reported
on
the
Form
R
for
a
facility
(
http://
www.
epa.
gov/
enviro/
html/
tris/
reports/
tri_
formr_
qry.
html);
°
Information
from
EPA's
outreach
activities
for
the
2004/
05
304(
m)
plan,
including
comments
from
permit
writers.

For
the
purpose
of
the
review
of
the
Group
II
and
Other
Factor
One
industries,
the
"
PCSLoads2000"
database
(
based
on
calendar
year
2000
PCS
reported
discharges)
and
the
"
TRIReleases2000"
database
(
based
on
output
from
the
2000
TRI)
will
be
used1.
The
PCSLoads2000
database
contains
information
for
major
direct
dischargers,
including
the
pounds
of
a
pollutant
discharged
by
SIC
code
and
by
facility,
the
toxic
weighted
pound
equivalents
(
TWPE)
discharged
by
SIC
code
and
by
facility,
and
wastewater
flow
rates
by
facility.
The
TRIReleases2000
database
contains
information
on
both
direct
and
indirect
discharges
for
facilities
required
to
report
to
TRI.
This
database
includes
the
pounds
of
a
toxic
chemical
(
or
chemical
category)
released
to
surface
waters
or
to
publicly
owned
treatment
works
(
POTWs)
by
SIC
code
and
by
facility,
the
estimated
TWPE
of
such
releases
to
surface
waters
by
SIC
code
and
by
facility,
treatment
processes
used
by
SIC
code
and
by
facility,
and
the
pounds
of
pollutants
released
to
other
environmental
media
by
SIC
code
and
by
facility.
Review
Plan
December
15,
2003
Page
3
Group
II
and
Other
Factor
One
Industries
EPA
identified
several
industries
based
on
Factor
1
(
potential
hazard/
risk)
for
which
it
has
numerous
data
gaps.
These
industries
have
been
divided
into
two
groups,
based
on
the
reported
TWPE
discharged.

Review
of
the
Group
II
Industries
EPA
has
included
the
following
as
Group
II
industries:

°
Inorganic
Chemicals
Manufacturing
(
40
CFR
Part
415);
and
°
Nonferrous
Metals
Manufacturing
(
40
CFR
Part
421).

The
following
procedures
may
be
used
to
conduct
the
review
of
the
Group
II
industries:

12.
Review
the
existing
effluent
limitations
guidelines
and
standards
for
an
industry
to
determine
existing
pollutant
limits
and
other
requirements
(
e.
g.,
no
discharge).

13.
Review
the
technical
development
documents,
guidance
documents
for
the
existing
effluent
limitations
guidelines
and
standard,
and
other
literature.
Information
on
geographic
distribution
of
industry
facilities,
raw
and
effluent
wastewater
pollutant
loads,
discharge
status,
and
wastewater
treatment
processes
may
be
available
in
these
documents.

14.
Determine
the
number
of
facilities
by
SIC
code
for
an
industry
from
the
1997
Economic
Census.

15.
Determine
the
number
of
direct,
indirect,
and
zero
dischargers
for
an
industry
in
the
TRIReleases2000
database
by
SIC
code.

16.
Scale­
up
the
number
of
direct
and
indirect
dischargers
for
an
industry
in
the
TRIReleases2000
database
using
the
total
number
of
facilities
from
the1997
Economic
Census
by
SIC
code.

17.
Determine
the
number
of
major
and
minor
direct
dischargers
in
the
PCSLoads2000
database
by
SIC
code.

18.
Query
the
PCSLoads2000
and
the
TRIReleases2000
databases
for
the
following
information:

°
Total
pounds
of
pollutants
discharged/
released
by
facility;
Review
Plan
December
15,
2003
Page
4
°
Total
TWPE
of
pollutants
discharged/
released
by
facility;

°
Percentage
of
the
total
TWPE
discharged/
released
by
facility
for
the
facilities
in
the
databases;

°
Cumulative
percentage
of
the
total
TWPE
discharged/
released
by
facility
for
the
facilities
in
the
database;

°
Percentage
of
the
total
TWPE
by
pollutant;

°
Cumulative
percentage
of
the
total
TWPE
by
pollutant;

°
Wastewater
flow
rate
data
by
facility
(
PCS
database
only);

°
Types
of
treatment
processes
used
by
SIC
code
(
also
available
by
facility)
(
TRI
database
only);
and
°
Pollutants
and
amounts
of
pollutants
released
to
other
media
(
TRI
database
only).

8.
If
dioxin
is
one
of
the
pollutants
that
account
for
90
percent
of
the
total
TWPE,
verify
how
the
TWPE
were
calculated.
The
reporting
form
for
the
TRIReleases2000
database
(
i.
e.,
Form
R)
requires
that
the
percentage
of
each
of
17
congeners
be
reported.
Use
those
percentages,
the
total
pounds
(
or
grams)
reported
on
Form
R,
and
the
toxic
weighting
factor
(
TWF)
for
each
congener
to
calculate
the
TWPE
of
each
congener.
In
the
PCS
database,
calculate
the
TWPE
when
a
particular
congener
of
dioxin
is
reported
using
the
TWF
for
the
congener.
If
no
congener
is
identified,
use
the
TWF
for
2,3,7,8­
TCDD
to
calculate
the
TWPE
pounds.

9.
Identify
the
facilities
in
the
PCSLoads2000
and
TRIReleases2000
databases
that
discharge/
release
90
percent
of
the
TWPE
for
the
facilities
in
the
database.

10.
Identify
the
pollutants
in
the
PCSLoads2000
and
TRIReleases2000
databases
that
account
for
90
percent
of
the
TWPE,
as
well
as
the
facilities
that
discharge
these
pollutants.

11.
If
necessary,
search
OTIS
and
the
TRI
Form
R
to
obtain
additional
information
about
facilities
that
discharge/
release
the
largest
TWPE
of
a
pollutant
including
the
source
of
the
discharge.
Review
Plan
December
15,
2003
Page
5
12.
If
necessary,
contact
the
facilities
that
discharge/
release
the
largest
TWPE
of
a
pollutant
to
verify
the
information
in
the
PCSLoads2000
and
TRIReleases2000
databases
and
on
Form
R.
Adjust
or
correct
the
information
according
to
information
provided
by
the
facility
contact.

13.
Recalculate
PCS
and
TRI
pollutant
loads
if
reported
discharge
loads
are
adjusted,
and
estimate
scaled
loads
for
the
entire
industry.

14.
Determine
the
pounds
of
pollutants
released
to
media
other
than
surface
water
in
the
TRIReleases2000
database.

15.
Review
the
applicable
comments
from
EPA's
outreach
activities
for
the
2004/
05
304(
m)
plan
to
determine
the
issues
for
a
particular
industry.

16.
Analyze
the
above
information
and
document
the
analysis
and
the
results
of
the
analysis.

Many
of
the
steps
in
the
above
procedure
for
the
Group
II
industries
were
completed
during
EPA's
screening­
level
analysis.
Other
steps
that
may
be
completed
for
each
Group
II
industry
are
as
follows:

Inorganic
Chemicals
Manufacturing
°
Contact
the
three
inorganic
chemicals
manufacturing
facilities
that
discharge/
release
the
highest
TWPE
of
dioxin/
dioxin­
like
compounds
to
determine
the
source
of
the
dioxin
and
to
verify
the
dioxin
information
on
the
facility's
TRI
Form
R
(
Step
12).

°
Recalculate
the
TWPE
released
to
surface
waters
based
on
the
revised
data
(
Step
13).

°
Query
the
TRIReleases2000
database
for
the
pounds
of
pollutants
released
to
media
other
than
surface
water
(
Step
14).

°
Address
the
following
comments
from
the
public
comment
activities
(
Step
15):


Evaluate
the
changes
to
this
industry
since
the
current
effluent
limitations
guidelines
were
published
in
1982,
particularly
with
respect
to
the
chloralkali
and
nitrous
oxide
subcategories.


Evaluate
the
applicability
of
the
guidelines
for
the
potassium
manufacturing
subcategory
with
respect
to
the
definition
of
process
wastewater.
Review
Plan
December
15,
2003
Page
6

Reevaluate
the
no
discharge
requirement
in
the
current
effluent
limitations
guidelines.

°
Update
the
final
documentation
for
the
inorganic
chemicals
manufacturing
industry
to
include
the
above
information
(
Step
16).

Nonferrous
Metals
Manufacturing
°
Contact
the
facilities
that
discharge/
release
the
highest
TWPE
to
determine
the
source
of
the
pollutants
and
to
verify
the
information
in
the
PCS
and
TRI
databases
(
Step
12).

°
Complete
the
review
of
the
methodology
used
to
scale­
up
the
pollutant
loads
in
the
PCSLoads2000
and
TRIReleases2000
databases
to
the
entire
nonferrous
metals
manufacturing
industry
and
revise
the
industry­
wide
pollutant
loads
and
TWPE,
as
appropriate
(
Step
13).

°
Query
the
TRIReleases2000
database
for
the
pounds
of
pollutants
released
to
media
other
than
surface
water
(
Step
14).

°
Update
the
final
report
for
the
nonferrous
metals
manufacturing
industry
to
include
the
above
information
(
Step
16).

Review
of
the
Other
Factor
One
Industries
EPA
identified
seven
industries
based
on
Factor
1
(
potential
hazard/
risk)
for
which
it
has
numerous
data
gaps.
They
are:

°
Fertilizer
Manufacturing
(
40
CFR
Part
418);
°
Ore
Mining
and
Dressing
(
40
CFR
Part
440);
°
Phosphate
Manufacturing
(
40
CFR
Part
422);
°
Pulp,
Paper,
and
Paperboard
(
Phase
II)
(
40
CFR
Part
430);
°
Steam
Electric
Generation
(
40
CFR
Part
423);
°
Textile
Mills
(
40
CFR
Part
410);
°
Timber
Products
Processing
(
40
CFR
Part
429);
and
°
Oil
and
Gas
Extraction
(
Including
Coal
Bed
Methane
Extraction)
(
40
CFR
Part
435).

As
time
and
resources
allow,
EPA
will
analyze
these
industries
using
the
procedure
described
for
Group
II
industries.
Review
Plan
December
15,
2003
Page
7
The
following
specific
steps
have
been
identified
for
each
of
the
Group
III
industries:

Fertilizer
Manufacturing
Stakeholders
believe
the
current
effluent
limitations
guidelines
are
out­
of­
date
and
are
not
stringent
enough,
particularly
with
respect
to
discharges
of
ammonia.

In
particular,
EPA
plans
to
do
the
following:

°
Verify
the
pollutant
loads
and
TWPE
that
account
for
90
percent
of
the
total
pollutant
loads
and
total
TWPE
in
the
PCSLoads2000
and
TRIReleases2000
databases.

°
Attempt
to
determine
the
source
and
cause
of
the
TWPE
and
pounds
discharged
that
account
for
90
percent
of
the
total
pollutant
loads
and
total
TWPE
in
the
PCSLoads2000
and
TRIReleases2000
databases.

°
Review
discharge
permits
and
available
monitoring
data
for
the
top
dischargers.

°
Estimate
industry­
level
ammonia
loads
based
on
PCS
and
TRI
reported
releases.

°
Review
existing
guideline
and
development
document
in
light
of
findings
to
evaluate
whether
the
existing
guideline
is
insufficient
to
address
current
issues.

Ore
Mining
&
Dressing
The
following
comments
were
received
from
stakeholders:

°
The
current
effluent
limitations
guidelines
may
be
outdated
and
the
BAT
technology
basis
may
no
longer
be
appropriate.

°
The
current
effluent
limitations
guidelines
should
be
revised
to
address
discharges
from
waste
rock,
spent
ore,
and
leach
material.
Other
issues
that
need
to
be
addressed
include
closure/
financial
assurance
plans,
remediation,
and
a
definition
of
active
vs
inactive
mines.

°
The
recommendations
of
EPA's
National
Mining
Team,
which
include
water
budgets
and
closure
plans,
should
be
considered
when
revising
the
hard
rock
mining
effluent
limitations
guidelines.

°
The
decision
to
exclude
seepage
from
waste
dumps
from
the
40
CFR
Part
440
definition
of
"
mine
drainage"
should
be
reversed.
Review
Plan
December
15,
2003
Page
8
°
Discharges
from
waste
rock
and
overburden
piles
should
be
subject
to
the
effluent
limitations
guidelines
and
should
not
be
considered
industrial
storm
water,
which
is
not
subject
to
the
guidelines.
Pollutants
of
concern
in
the
discharges
include
arsenic,
copper,
mercury,
and
selenium.

In
particular,
EPA
plans
to
do
the
following:

°
Verify
the
pollutant
loads
and
TWPE
that
account
for
90
percent
of
the
total
pollutant
loads
and
total
TWPE
in
the
PCSLoads2000
and
TRIReleases2000
databases.

°
Estimate
the
loads
of
arsenic,
copper,
mercury,
and
selenium
reported
for
this
industry.

°
Attempt
to
obtain
MultiSector
General
Permit
(
MSGP)
monitoring
data
and
estimate
loads
of
metals
pollutants
in
these
discharges
controlled
by
these
permits.

Phosphate
Manufacturing
Stakeholders
requested
clarification
of
the
SIC
codes
for
facilities
in
this
category,
and
believe
EPA
should
make
an
assessment
of
the
toxic
pollutants
discharged
by
facilities
in
this
category
through
a
review
the
NPDES
permits
for
the
facilities.

In
specific,
EPA
plans
to
do
the
following:

°
Verify
the
pollutant
loads
and
TWPE
that
account
for
90
percent
of
the
total
pollutant
loads
and
total
TWPE
in
the
PCSLoads2000
and
TRIReleases2000
databases.

°
Attempt
to
determine
the
source
and
cause
of
the
TWPE
and
pounds
discharged
that
account
for
90
percent
of
the
total
pollutant
loads
and
total
TWPE
in
the
PCSLoads2000
and
TRIReleases2000
databases.

°
Review
discharge
permits
and
available
monitoring
data
for
the
top
dischargers.

°
Review
existing
guideline
and
development
document
in
light
of
findings
to
evaluate
whether
the
existing
guideline
is
insufficient
to
address
current
issues
and
to
clarify
the
SIC
Codes.
Review
Plan
December
15,
2003
Page
9
Pulp,
Paper,
and
Paperboard
(
Phase
II)

Stakeholders
expressed
concern
about
discharges
into
smaller
water
bodies
and
the
difficulties
of
establishing
whole
effluent
toxicity
limits.
They
also
expressed
concerns
about
the
discharge
of
dyes
and
dioxin
from
bleaching
at
secondary
fiber
mills
and
requested
EPA
to
establish
a
measurable
limit
for
color.

In
specific,
EPA
plans
to
do
the
following:

°
Review
the
assignment
of
facilities
as
Phase
I
versus
Phase
II
mills
to
ensure
pollutants
reported
are
classified
with
the
proper
processes.

°
Verify
the
pollutant
loads
and
TWPE
that
account
for
90
percent
of
the
total
pollutant
loads
and
total
TWPE
in
the
PCSLoads2000
and
TRIReleases2000
databases.

°
Determine
the
source
of
the
PACs
and
dioxin
in
the
discharges
from
Phase
II
pulp
mills
and
confirm
the
TWPE
for
those
pollutants
in
the
TRIReleases2000
database.

Steam
Electric
Generation
The
following
comments
were
received
from
stakeholders:

°
Clarify
the
applicability
of
the
guideline
with
respect
to
cogeneration
units.

°
Concerns
were
expressed
regarding
toxic
pollutants
in
coal
pile
runoff
(
including
mercury
and
selenium)
and
the
increased
use
of
POTW
effluent
as
cooling
water.

°
Expand
the
scope
of
the
effluent
limitations
guidelines
to
include
exempted
facilities
that
should
not
be
exempted
and
new
facilities
not
currently
subject
to
the
guideline.

°
Update
the
1982
effluent
limitations
guidelines
to
be
more
representative
of
the
industry.
Suggested
changes
include
addressing:
(
1)
problems
with
the
temperature
of
discharged
cooling
water
and
with
mercury
and
arsenic
in
the
discharge
from
ash
ponds;
(
2)
the
analytical
methods
for
priority
pollutants;
(
3)
process
additives
for
which
there
are
no
limits;
(
4)
the
footnotes
in
the
current
guidelines,
which
are
in
error;
and
(
5)
combined
cycle
plants
constructed
in
the
last
decade
that
are
not
subject
to
the
current
guidelines.

EPA
plans
to
conduct
the
following
analyses:
Review
Plan
December
15,
2003
Page
10
°
Verify
the
pollutant
loads
and
TWPE
that
account
for
90
percent
of
the
total
pollutant
loads
and
total
TWPE
in
the
PCSLoads2000
and
TRIReleases2000
databases.

°
Evaluate
whether
a
significant
portion
of
the
estimated
TWPE
is
driven
by
low
concentrations
and/
or
non­
detectable
concentrations
in
very
large
flows.

°
Determine
the
source
of
the
PCBs
and
PACs
in
the
discharges
and
confirm
the
TWPE
for
those
pollutants
in
the
TRIReleases2000
database.

°
Confirm
the
TWF
used
for
metal
compound
categories.

Textile
Manufacturing
Stakeholders
were
concerned
with
industrial
sludge
disposal,
and
expressed
a
need
for
a
measurable
limit
for
color
and
copper.

In
specific,
EPA
plans
to
do
the
following
analyses:

°
Verify
the
pollutant
loads
and
TWPE
that
account
for
90
percent
of
the
total
pollutant
loads
and
total
TWPE
in
the
PCSLoads2000
and
TRIReleases2000
databases.

°
Attempt
to
determine
the
main
source
of
the
pollutant
loads.

°
Estimate
the
extent
of
discharge
of
color
and
copper.

°
Review
the
Textile
study
materials
and
update
as
appropriate.

Timber
Products
Processing
Stakeholders
believe
EPA
should
amend
the
definition
of
process
wastewater
in
40
CFR
429
to
exclude
wastewater
generated
in
air
pollution
control
devices
and
in
operation
and
maintenance
activities.

EPA
plans
to
do
the
following
analyses:

°
Verify
the
pollutant
loads
and
TWPE
that
account
for
90
percent
of
the
total
pollutant
loads
and
total
TWPE
in
the
PCSLoads2000
and
TRIReleases2000
databases.
Review
Plan
December
15,
2003
Page
11
°
Attempt
to
determine
the
source
and
cause
of
the
TWPE
and
pounds
discharged
that
account
for
90
percent
of
the
total
pollutant
loads
and
total
TWPE
in
the
PCSLoads2000
and
TRIReleases2000
databases.

°
Review
discharge
permits
and
available
monitoring
data
for
the
top
dischargers.

°
Review
existing
guideline
and
development
document
in
light
of
findings
to
evaluate
whether
the
existing
guideline
is
insufficient
to
address
current
issues.

°
Quantify
the
pre­
and
post
National
Emission
Standard
for
Hazardous
Air
Pollutant
toxic
pollutant
loadings
for
the
Plywood
and
Composite
Wood
Products
category
(
40
CFR
63,
Subpart
DDDD).

Oil
and
Gas
Extraction
(
including
coalbed
methane
as
a
potential
new
subcategory)

This
industry
is
of
concern
because
of
the
large
quantities
of
wastewater
produced,
the
discharge
load
for
total
dissolved
solids,
and
the
sodium
adsorption
ration
(
SAR)
of
the
wastewater.
No
data
are
available
for
this
industry
in
the
PCSLoads2000
and
TRIReleases2000
databases.
It
is
being
considered
as
a
new
subcategory
in
the
oil
and
gas
extraction
category
based
on
comments
received
during
the
public
outreach
activities
for
the
20004/
05
304(
m)
plan.

The
following
comments
were
received
from
stakeholders:

°
Revise
the
oil
and
gas
effluent
limitations
guidelines
(
40
CFR
435)
to
address
issues
arising
from
the
coalbed
methane
extraction
procedure.

°
Pollutants
discharged
during
coalbed
methane
extraction
have
no
water
quality
criteria
or
standards.
For
this
reason,
effluent
limitations
guidelines
should
be
developed
for
this
subcategory.
This
is
supported
by
the
State
of
Wyoming,
the
Clean
Water
Action
Network,
and
the
Wyoming
Outdoor
Council.

EPA
Region
8,
in
conjunction
with
EAD,
is
currently
conducting
a
study
of
this
industry
for
facilities
located
in
Region
8.
No
additional
data
analysis
has
been
identified
at
this
time.
