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

FROM:
Bob
Southworth,
ERG
Senior
Environmental
Engineer
DATE:
November
19,
2003
SUBJECT:
Review
of
the
Facilities
Listed
in
the
2000
PCS
Database
for
the
Fertilizer
and
Phosphate
Manufacturing
Point
Source
Categories
This
memorandum
presents
the
results
of
a
review
of
the
facilities
listed
in
the
2000
Permit
Compliance
System
(
PCS)
database
for
the
fertilizer
and
phosphate
manufacturing
point
source
categories.
It
discusses
the
purpose
of
the
review,
identifies
the
SIC
code
for
the
facilities
that
discharged
90
percent
or
more
of
the
toxic
weighted
pound
equivalent
(
TWPE)
load
for
these
categories,
and
presents
the
revised
TWPE
load
for
the
fertilizer
and
phosphates
categories
based
on
the
results
of
the
review.

Purpose
The
purposes
of
the
review
of
the
facilities
in
the
2000
PCS
database
for
the
fertilizer
and
phosphate
industrial
categories
was
to
identify
facilities
listed
in
more
than
one
category
and
to
determine
the
correct
category
for
those
facilities.

Facilities
That
Discharged
90
Percent
of
the
TWPE
Load
For
the
fertilizer
category,
two
facilities
discharged
97
percent
of
the
TWPE
load
for
the
category.
The
facilities,
the
SIC
code
for
the
facilities,
and
the
TWPE
load
for
each
facility
are
listed
in
Table
1.
The
TWPE
loads
for
all
of
the
facilities
in
the
fertilizer
category
as
of
November
6,
2003,
are
presented
in
Attachment
A.

For
the
phosphate
category,
four
facilities
discharged
90
percent
of
the
TWPE
load
for
the
category.
The
facilities,
the
SIC
code
for
the
facilities,
and
the
TWPE
load
for
each
facility
are
listed
in
Table
2.
The
TWPE
load
for
all
of
the
facilities
in
the
phosphate
category
as
of
November
6,
2003,
are
presented
in
Attachment
B.
MEMORANDUM
19
November
2003
Page
2
TABLE
1
FACILITIES
THAT
DISCHARGED
97
PERCENT
OF
THE
TWPE
LOAD
FOR
THE
FERTILIZER
CATEGORY1
Facility
SIC
Code
TWPE
(
pounds)

IMC
Phosphates
Co­
Uncle
Sam,
LA
2874
1,081,075
IMC
Phosphates
Co.
Donaldsonville,
LA
2873
97,604
Total
1,178,679
1
For
TWPE
loads
generated
on
November
6,
2003.

TABLE
2
FACILITIES
THAT
DISCHARGED
90
PERCENT
OF
THE
TWPE
LOAD
FOR
THE
PHOSPHATE
CATEGORY1
Facility
SIC
Code
TWPE
(
pounds)

IMC
Phosphates
Co
­
Uncle
Sam,
LA
2874
1,081,075
Norit
Americas
Inc.
2819
359,891
Kincaid
Enterprises
2879
168,828
Clearon
Corporation
2819
74,656
Total
1,684,450
1
For
TWPE
loads
generated
on
November
6,
2003.

The
IMC
Phosphates
Co.
facility
in
Uncle
Sam,
LA.,
is
the
facility
with
the
highest
TWPE
load
in
both
Tables
1
and
2.
To
determine
the
correct
category
for
the
Uncle
Sam
facility,
a
call
was
made
to
the
contact
listed
on
the
Toxic
Release
Inventory
(
TRI)
Form
R
for
the
facility.
According
to
Russell
G.
Oliver
of
IMC
Phosphates
Co.,
the
Uncle
Sam
facility
produces
phosphoric
acid
and
hydrofluoric
acid.
Both
of
these
production
processes
are
in
the
phosphate
category.
Sulfuric
acid
also
is
produced
at
the
Uncle
Sam
facility
by
burning
sulfur
(
i.
e.,
a
fertilizer
category
process).
All
of
the
sulfuric
acid
produced
is
used
in
the
production
phosphoric
acid.
The
only
wastewater
generated
during
the
production
of
sulfuric
acid
is
non
contact
cooling
water.
MEMORANDUM
19
November
2003
Page
3
Mr.
Oliver
agreed
that
the
Uncle
Sam
facility
should
be
in
the
phosphate
category.
For
this
reason,
the
TWPE
load
for
the
Uncle
Sam
facility
was
deleted
from
the
TWPE
load
for
the
fertilizer
category
in
the
2000
PCS
database.

As
shown
in
Table
2,
two
of
the
four
facilities
that
discharged
90
percent
of
the
TWPE
load
for
the
phosphate
category
have
a
SIC
Code
of
2819
and
one
has
a
SIC
Code
of
2879.
Follow­
up
calls
were
made
to
each
of
these
facilities
to
verify
their
SIC
code.

Curtis
Miles
of
Norit
Americas
and
Ken
Smith
of
Clearon
Corporation
indicated
that
the
SIC
code
for
their
facility
is
2819
and
that
their
primary
business
is
the
manufacture
of
inorganic
chemicals.
For
this
reason,
the
TWPE
load
for
those
facilities
was
deleted
from
the
TWPE
load
for
the
phosphate
category
in
the
2000
PCS
database.
[
Note
that
these
loads
are
already
included
in
the
inorganic
chemicals
point
source
category.]

Brian
S.
Kincaid
of
Kincaid
Enterprises
indicated
that
Kincaid
Enterprises
produces
pesticides.
For
this
reason,
TWPE
load
for
this
facility
should
not
be
included
in
the
TWPE
load
for
either
the
inorganic
chemicals
manufacturing
or
phosphate
categories.
The
TWPE
load
for
Kincaid
Enterprises
was
deleted,
therefore,
from
the
TWPE
load
for
those
two
categories
and
added
to
the
TWPE
load
for
the
pesticide
category.
