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

FROM:
Bob
Southworth,
ERG
Senior
Environmental
Engineer
DATE:
October
30,
2003
SUBJECT:
Review
of
the
TWPE
Loads
for
Selected
Nonferrous
Metals
Manufacturing
Facilities
Calculated
Using
2000
TRI
Data
This
memorandum
presents
the
results
of
a
review
of
the
Toxic
Weighted
Pound
Equivalent
(
TWPE)
loads
for
selected
nonferrous
metals
(
NFM)
manufacturing
facilities
calculated
using
2000
Toxic
Release
Inventory
(
TRI)
data.
It
provides
background
information
on
the
NFM
manufacturing
facilities
that
released
93
percent
of
the
TWPE
load,
discusses
the
pollutants
with
the
highest
TWPE
loads,
and
identifies
the
NFM
manufacturing
facilities
that
released
the
pollutants
with
the
highest
TWPE
loads.
The
TRIReleases2000
database
contains
pollutant
loads
for
both
direct
and
indirect
discharging
facilities.
The
development
of
this
database
is
discussed
in
more
detail
in
the
data
dictionary
entitled
TRIReleases2000
Data
Dictionary,
dated
December
12,
2003.
Please
note
that
indirect
dischargers
in
the
NFM
manufacturing
industry
are
not
discussed
in
this
memorandum
because
the
scaled
TWPE
load
for
the
indirect
dischargers
is
only
17,058
pounds.

Background
Six
of
the
direct
discharging
NFM
manufacturing
facilities
in
the
2000
TRI
database
released
93
percent
of
the
TWPE
load
for
the
NFM
manufacturing
industry.
Four
of
those
facilities
released
86
percent
of
the
TWPE
load.
Four
have
a
Standard
Industrial
Classification
(
SIC)
Code
of
3334
and
two
have
a
SIC
Code
of
3339.
The
total
TWPE
load
discharged
by
NFM
manufacturing
facilities
that
reported
a
release
to
surface
water
in
the
2000
TRI
database
was
971,191.
Attachment
A
lists
the
TWPE
loads
calculated
using
2000
TRI
data
by
facility
and
by
pollutant.
The
percentage
of
the
total
TWPE
load
for
each
pollutant
by
facility
and
the
cumulative
percentage
of
the
total
TWPE
for
each
pollutant
by
facility
also
are
presented
in
Attachment
A.

Pollutants
With
High
TWPE
Loads
The
TWPE
loads
for
three
pollutants
comprise
93
percent
of
the
total
TWPE
load
for
NFM
manufacturing
facilities
calculated
using
2000
TRI
data.
Table
1
lists
the
three
pollutants
and
the
TWPE
load
for
each
pollutant.
MEMORANDUM
October
30,
2003
Page
2
2
TABLE
1
TWPE
LOAD
FOR
TOP
THREE
POLLUTANTS
Pollutant
TWPE
(
pounds)

Polycyclic
aromatic
compounds1
831,010
Vanadium
compounds1
37,495
Sodium
nitrite1
34,727
Total
903,232
1
Non­
conventional
pollutant
All
three
pollutants
are
non­
conventional
pollutants.
One
pollutant
(
i.
e.,
polycyclic
aromatic
compounds)
accounts
for
92
percent
of
the
TWPE
load
for
the
top
three
pollutants.

Facilities
With
Highest
TWPE
Loads
The
following
NFM
manufacturing
facilities
discharged
the
three
pollutants
with
the
highest
TWPE
load.
The
number
in
parenthesis
is
the
TRI
identification
number
for
the
facility.

Facility
Name
Facility
Location
(
ID)
SIC
Reynolds
Metals
Company
Longview,
WA
(
98632RYNLD40291)
3334
ALCOA
Badin,
NC
(
28009LMNMCHWY74)
3334
Reynolds
Metals
Company
Massena,
NY
(
13662RYNLDSOUTH)
3334
U.
S.
Vanadium
Corp
Hot
Springs,
AK
(
71901SVNDM5911M)
3339
Osram
Sylvania
Products
Towanda,
PA
(
18848GTPRDHAWES)
3339
Northwest
Aluminum
Co.
The
Dalles,
OR
(
97058NRTH3313W)
3334
Table
2
lists
the
NFM
manufacturing
facilities
that
released
the
highest
percentage
of
the
TWPE
load
for
the
top
three
pollutants
and
the
percentage
of
the
TWPE
load
released
by
the
facility.
MEMORANDUM
October
30,
2003
Page
3
3
TABLE
2
NFM
MANUFACTURING
FACILITIES
THAT
RELEASED
THE
HIGHEST
PERCENTAGE
OF
THE
TOP
THREE
POLLUTANTS
Pollutant
Facility
Percentage
of
TWPE
Released
by
Facility
Polycyclic
aromatic
compounds1
Reynolds
Metals
­
Longview
ALCOA
Reynolds
Metals
­
Massena
Northwest
Aluminum
Co
50
41
5
4
Vanadium
compounds1
U.
S.
Vanadium
Corporation
100
Sodium
nitrite1
Osram
Sylvania
Prod.
Inc.
100
1
Non­
conventional
pollutant
As
shown
above,
four
NFM
manufacturing
facilities
released
the
total
TWPE
load
for
polycyclic
aromatic
compounds.
One
hundred
percent
of
the
TWPE
load
for
vanadium
compounds
and
sodium
nitrite
is
from
one
NFM
manufacturing
facility.

Except
for
one
of
the
pollutants
(
i.
e.,
benzo(
a)
pyrene)
in
the
group
of
polycyclic
aromatic
compounds
reported
on
Form
R,
there
are
no
limits
for
the
above
pollutants
in
the
effluent
limitations
guidelines
(
ELG)
for
the
NFM
manufacturing
industry.
If
EPA
decides
not
to
establish
limits
for
the
other
pollutants
in
an
ELG,
limits
for
those
pollutants
and
a
revised
limit
for
benzo(
a)
pyrene
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
the
TWPE
load
for
the
pollutants
is
released
to
surface
water
by
a
small
number
of
NFM
manufacturing
facilities.

Attachment
ATTACHMENT
A
TWPE
LOADS
CALCULATED
USING
2000
TRI
DATA
BY
POLLUTANT
AND
BY
NONFERROUS
METALS
MANUFACTURING
FACILITY
