MEMORANDUM
TO:
304(
m)
Record
(
EPA
Docket
Number
OW­
2003­
0074)

FROM:
Bob
Southworth,
ERG
Senior
Environmental
Engineer
DATE:
October
7,
2003
SUBJECT:
Review
of
the
TWPE
Loads
for
Selected
Inorganic
Chemicals
Manufacturing
Facilities
Calculated
Using
Data
from
the
2000
TRI
Database
This
memorandum
presents
the
results
of
a
review
of
the
Toxic
Weighted
Pound
Equivalent
(
TWPE)
loads
for
selected
inorganic
chemicals
manufacturing
facilities
calculated
using
data
from
the
2000
Toxic
Release
Inventory
(
TRI)
database.
It
provides
background
information
on
the
inorganic
chemicals
manufacturing
facilities
that
released
90
percent
of
the
TWPE
load
to
surface
water,
discusses
the
pollutants
with
the
highest
TWPE
loads,
and
identifies
the
inorganic
chemicals
manufacturing
facilities
that
released
the
pollutants
with
the
highest
TWPE
loads.
The
TRIReleases2000
database
contains
pollutant
loads
for
direct
discharging
and
indirect
discharging
facilities.
Only
the
TWPE
loads
from
direct
discharging
facilities
are
discussed
in
this
memorandum
because
the
scaled­
up
TWPE
load
for
indirect
discharge
is
only
230,898
pounds.

Background
Fourteen
of
the
inorganic
chemicals
manufacturing
facilities
in
the
2000
TRI
database
released
90
of
the
TWPE
load
to
surface
water
for
the
inorganic
chemicals
manufacturing
industry.
Four
of
the
facilities
have
a
Standard
Industrial
Classification
(
SIC)
Code
of
2812,
three
have
a
SIC
Code
of
2816,
and
seven
have
a
SIC
Code
of
2819.
The
TWPE
of
non­
conventional
and
priority
pollutants
released
by
the
14
facilities
in
2000
was
834,620.
Attachment
A
contains
the
TWPE
load
for
inorganic
chemicals
manufacturing
facilities
calculated
using
data
from
the
2000
TRI
database,
the
percentage
of
the
total
TWPE
load
for
each
facility,
and
the
cumulative
percentage
of
the
total
TWPE
for
each
facility.

Pollutants
With
High
TWPE
Loads
The
TWPE
loads
for
seven
pollutants
comprise
90
percent
of
the
total
TWPE
load
for
direct
discharging
inorganic
chemicals
manufacturing
facilities
in
the
2000
TRI
database.
The
seven
pollutants
and
the
TWPE
load
for
each
pollutant
are
presented
in
Table
1.
2
TABLE
1
TWPE
LOAD
FOR
THE
POLLUTANTS
THAT
COMPRISE
90
PERCENT
OF
THE
TWPE
LOAD
FOR
THE
INORGANIC
CHEMICALS
MANUFACTURING
INDUSTRY
Pollutant
TWPE
(
pounds)

Dioxin/
Dioxin­
Like
Compounds1
536,932
Hexachlorobenzene1
145,559
Sodium
Nitrite2
85,124
Chlorine2
36,552
Manganese
Compounds2
12,467
Vanadium
Compounds2
9,404
Silver
Compounds1
8,582
Total
834,620
1
Priority
pollutant
2
Non­
conventional
pollutant
Three
of
the
pollutants
with
the
highest
TWPE
loads
are
priority
pollutants
and
four
are
non­
conventional
pollutants.
Two
of
the
pollutants
(
i.
e.,
dioxin
and
hexachlorobenzene)
account
for
approximately
75
percent
of
the
TWPE
load
for
the
above
seven
pollutants.

Facilities
With
Highest
TWPE
Loads
The
following
inorganic
chemicals
manufacturing
facilities
released
the
TWPE
load
in
the
2000
TRI
database
for
the
above
seven
pollutants.
The
number
in
parenthesis
is
the
TRI
identification
number.

°
Oxy
Vinyl
L.
P.
Deer
Park,
TX
SIC
2812
(
77536CCDNT1000T)

°
DuPont
New
Johnsonville,
TN
SIC
2816
(
37134DPNTJ1DUPO)

°
PPG
Industries,
Inc.
New
Martinsville,
WV
SIC
2812
(
26155PPGNDSTATE)
3
°
Millennium
Inorganic
Baltimore,
MD
SIC
2816
Chemicals,
Inc
(
21226SCMCH3901G)

°
GFS
Chemicals
Columbus,
OH
SIC
2819
(
43223GFRDR867MC)

°
Occidental
Chemical
Corp.
St.
James,
LA
SIC
2812
(
70723CCDNTHIGHW)

°
DuPont
Edgemoor,
DE
SIC
2816
(
19809DPNTD104HA)

°
Repauno
Prods
L.
L.
C.
Gibbstown,
NJ
SIC
2819
(
08027RPNPR200NR)

°
Nyacol
Nano
Techs,
Inc.
Ashland,
MA
SIC
2819
(
01721NYCLPMEGUN)

°
Engelhard
Corp.
Erie,
PA
SIC
2819
(
16503CLSCT1707G)

°
Occidental
Chemical
Corp
St.
Charles,
LA.
SIC
2812
(
70057CCDNTLAHWY)

°
AMAX
Metals
Recovery
Braithwaite,
LA
SIC
2819
(
70040MXMTLLAHWY)

°
Engelhard
Corp.
Seneca,
SC
SIC
2819
(
29678NGLHR554MO)

°
Sud­
Chemie,
Inc.
Louisville,
KY
SIC
2819
(
40210NTDCT1227S)

The
inorganic
chemicals
manufacturing
facilities
that
released
the
highest
percentage
of
the
TWPE
load
for
the
above
seven
pollutants
are
listed
in
Table
2.
4
TABLE
2
INORGANIC
CHEMICALS
MANUFACTURING
FACILITIES
THAT
RELEASED
THE
HIGHEST
PERCENTAGE
OF
THE
TOP
SEVEN
POLLUTANTS
Pollutant
Facility
Percentage
of
TWPE
Released
by
Facility
Dioxin/
Dioxin­
Like
Compounds
Oxy
Vinyl
L.
P
PPG
Industries,
Inc.
Millennium
Inorganic
Chem.
Occidental
Chem.
­
St.
James
DuPont
New
Johnsonville
Occidental
Chem.­
St.
Charles
55
16
15
6
5
3
Hexachlorobenzene
DuPont
New
Johnsonville
DuPont
Edgemoor
80
20
Sodium
Nitrite
Repauno
Prods.
L.
L.
C.
Nyacol
Nano
Techs,
Inc.
Engelhard
Corp
­
Erie
Engelhard
Corp
­
Seneca
32
30
27
11
Chlorine
GFS
Chemical,
Inc.
100
Manganese
Compounds
Millennium
Inorganic
Chem.
100
Vanadium
Compounds
AMAX
Metals
Recovery
100
Silver
Compounds
Sud­
Chemie,
Inc.
100
For
four
of
the
above
pollutants
(
i.
e,
chlorine,
manganese
compounds,
vanadium
compounds,
and
silver
compounds),
one
facility
released
100
percent
of
the
TWPE
load
for
the
pollutants.
For
dioxin/
dioxin­
like
compounds,
three
facilities
released
86
percent
of
the
TWPE
load
for
those
compounds.
For
hexachlorobenzene,
one
facility
released
80
percent
of
the
total
TWPE
for
that
pollutant.
In
the
case
of
sodium
nitrite,
three
facilities
released
89
percent
of
the
TWPE
load
for
that
pollutant.

The
effluent
limitations
guidelines
(
ELG)
for
the
inorganic
chemicals
manufacturing
industry
contain
limits
for
one
of
the
above
pollutants
(
i.
e.,
silver).
If
EPA
decides
not
to
establish
limits
for
the
other
pollutants
in
an
ELG,
limits
for
those
pollutants
and
a
revised
limit
for
silver
could
be
established
on
a
case­
by­
case
basis
in
a
National
Pollutant
Discharge
Elimination
System
permit
based
on
Best
Professional
Judgement.
This
is
a
feasible
approach
because
a
small
number
of
inorganic
chemicals
manufacturing
facilities
released
most
of
the
TWPE
load
for
each
of
the
pollutants.
5
Attachment
6
ATTACHMENT
A
TWPE
LOADS
FOR
INORGANIC
CHEMICALS
MANUFACTURING
FACILITIES
CALCULATED
USING
DATA
FROM
THE
2000
TRI
DATABASE
