MEMORANDUM
TO:
Project
File
FROM:
Meghan
Kandle,
ERG
DATE:
03
June
2004
SUBJECT:
Producers
of
L­
Lysine
for
Animal
Feed
EPA
is
investigating
facilities
classified
under
SIC
code
2048
(
Animal
Feed
Preparations)
in
response
to
comments
submitted
by
the
National
Resources
Defense
Council
on
March
18,
2004.
The
purpose
of
this
memorandum
is
to
provide
general
information
on
L­
lysine
and
its
application
in
the
manufacture
of
animal
feeds,
as
well
as
identify
major
producers
of
L­
lysine
in
the
United
States.

L­
Lysine
L­
lysine
is
an
essential
amino
acid
for
the
lean
muscle
development
of
swine
and
poultry
(
1).
Animals
often
lack
lysine
in
their
diets,
which
can
impair
growth.
Manufacturers
of
swine
and
poultry
feed
use
lysine
as
a
supplement
to
stimulate
growth
and
improve
the
quality
of
the
meat.

Lysine
may
be
produced
by
the
following
methods:

°
Fermentation;
°
Enzymatic
conversion;
°
Isolation
from
natural
sources;
and
°
Chemical
synthesis.

Chemical
synthesis
of
lysine
results
in
a
50:
50
mixture
of
D­
and
L­
lysine.
Separating
this
mixture
can
be
expensive
(
2).
Therefore,
fermentation
is
the
preferred
process.
The
fermentation
process
uses
a
bacteria
strain,
such
as
Corynebacteium
glutamicum,
to
synthesize
lysine
from
sugar
or
molasses
(
3).

Manufacturers
of
L­
Lysine
°
BioKyowa
(
Cape
Girardeau,
MO)

The
BioKyowa
facility
in
Cape
Girardeau,
MO
accounts
for
54
percent
of
the
total
TWPE
assigned
to
SIC
code
2048
(
Animal
Feed
Preparations)
in
the
TRIReleases
2000
database.
The
facility
reports
a
discharge
of
376,000
pounds
of
ammonia
to
surface
waters,
which
accounts
for
more
than
99
percent
of
the
total
facility's
TWPE
in
TRI.

BioKyowa
reports
to
PCS
for
2000
under
SIC
code
2833
(
Medicinals
and
Botanicals),
which
would
classify
the
facility
in
the
Pharmaceuticals
Manufacturing
Point
Source
Category.
The
facility
reports
a
discharge
of
1,270
pounds
of
ammonia
to
PCS
for
2000,
which
is
much
lower
than
the
TRI­
reported
discharge.

On
June
1,
ERG
contacted
Frank
Hund
at
EPA
Headquarters
to
discuss
the
scope
of
the
Pharmaceuticals
Rule
and
its
applicability
to
the
BioKyowa
facility.
Frank
had
visited
the
BioKyowa
facility
in
Cape
Girardeau,
MO
in
1999.
He
described
the
facility
as
being
similar
to
a
chemical
plant
aside
from
the
fermentation
process
used
to
produce
lysine.

This
facility
is
out
of
scope
for
the
Pharmaceuticals
Rule
because
the
primary
purpose
of
the
L­
lysine
product
is
not
pharmaceutical
in
nature.
The
end
use
of
the
lysine
produced
at
the
BioKyowa
plant
is
as
a
feed
supplement
for
swine
and
poultry.
Furthermore,
the
operations
at
the
BioKyowa
facility
are
not
regulated
by
FDA.

On
June
2,
ERG
contacted
John
Dunn
at
EPA
Region
7
regarding
the
development
of
the
permit
for
this
facility.
No
effluent
guidelines
were
applied
as
the
basis
for
permit
limits,
rather
water
quality
standards
and
best
professional
judgement
were
used.
Mr.
Dunn
said
that
the
wastewater
at
this
facility
is
not
similar
to
wastewater
at
pharmaceutical
facilities.
The
wastewater
from
the
lysine
fermentation
consists
only
of
the
fermentation
broth,
which
is
high
in
nutrients,
ammonia,
and
salt.
The
facility
implemented
an
ammonia
recovery
unit
to
address
the
high
ammonia
discharge.

BioKyowa
has
switched
over
their
fermentation
process
from
producing
L­
lysine
to
producing
a
range
of
amino
acids.
The
amino
acid
products
have
multiple
end­
uses
including
animal
feeds.
Mr.
Dunn
was
unsure
of
the
current
primary
SIC
code
for
this
facility.
According
to
2001
TRI
data,
the
facility
still
reports
a
primary
SIC
code
of
2048.

°
Archer
Daniels
Midland
Company
(
ADM)
(
Decatur,
IL)

The
ADM
facility
in
Decatur,
IL
has
several
manufacturing
operations
including
a
corn
processing
plant
(
SIC
2046
­
Wet
Corn
Milling,
2869
­
Industrial
Organic
Chemicals),
a
Vitamin
C
plant
(
SIC
2834
­
Pharmaceutical
Preparations),
a
soybean
oil
mill
(
SIC
2075),
a
lysine
plant
(
2048
­
Animal
Feed
Preparations),
and
a
cogeneration
plant
(
SIC
4911).
Each
plant
reports
to
TRI
separately.
ADM
Bioproducts
(
TRI
ID:
62526DMBCH4666F)
is
the
lysine
plant.
The
facility
reports
to
TRI
under
SIC
code
2048.
No
wastewater
discharges
are
reported.
According
to
2000
TRI
data,
the
facility
transfers
290,000
pounds
of
ammonia
for
wastewater
treatment
and
2,200,000
pounds
of
ammonia
for
reuse
or
recovery
at
the
ADM
Corn
Sweeteners
facility
in
Decatur,
IL
(
4).

The
facility
has
two
NPDES
(
non­
major)
permits
for
the
corn
processing
plant
(
SIC
2046).
The
permits
cover
stormwater
runoff
and
spray
irrigation
(
4).
°
Ajinomoto
USA/
Heartland
Lysine
(
Eddyville,
IA)

The
Ajinomoto
facility
in
Eddyville,
IA
reports
to
TRI
under
two
TRI
Ids.
Ajinomoto
Food
Ingredients
LLC
(
52553JNMTS1AJIN)
reports
a
primary
SIC
code
of
2869
(
Industrial
Organic
Chemicals)
to
TRI.
Ajinomoto
Heartland
LLC
(
52553HRTLNHIGHW)
reports
a
primary
SIC
code
of
2048
(
Animal
Feed
Preparations)
to
TRI.
Neither
facility
reports
wastewater
discharges.
According
to
TRI
data
for
2000,
Ajinomoto
transfers
360,078
pounds
of
ammonia
to
the
Cargill
Corn
Milling
facility
in
Eddyville,
IA
for
wastewater
treatment.
Heartland
transfers
64,724
pounds
of
ammonia
to
Cargill
(
4).

The
facility
also
has
two
NPDES
(
non­
major)
permits.
Ajinomoto
Heartland
(
IA0065692)
reports
under
SIC
2934
(
Pharmaceutical
Preparations)
to
PCS.
The
permit
covers
discharges
for
cooling
tower
blowdown
and
sanitary
waste
effluent.
Ajinomoto
Food
Ingredients
(
IA0072389)
reports
under
SIC
code
2099
(
Food
Preparations)
to
PCS.
The
permit
covers
cooling
water
discharges
(
4).

°
Midwest
Lysine
LLC
(
Blair,
NE)

The
Midwest
Lysine
facility
in
Blair,
NE
was
built
in
1998
as
a
joint
venture
between
Cargill
and
Degussa
Corp.
In
2003,
Degussa
purchased
Cargill's
share
and
assumed
full
ownership
of
the
lysine
facility
(
5).
The
facility
reports
to
TRI
and
PCS
under
SIC
code
2869
(
Industrial
Organic
Chemicals).
According
to
TRI
data
for
2000,
the
facility
transfers
32,746
pounds
of
ammonia
to
Cargill
North
America
Sweeteners
in
Blair,
NE
for
wastewater
treatment,
and
9,650
pounds
to
Chamness
Tech,
Inc
in
Blairsburg,
IA
for
land
disposal.
The
NPDES
(
nonmajor
permit
for
the
facility
covers
non­
contact
cooling
water
(
4).

References:

1.
de
Roos,
N.
1999.
Examining
Models
of
Collusion:
the
Market
for
Lysine.
Department
of
Economics,
Yale
University.

2.
L­
Lysine
L­
Lysine
HCl.
<
www.
tidco.
com/
tidcodocs/
tn/
Opportunities/
L­
LYSINE­
L­
LYSINE%
20HCl.
doc>
Accessed
06/
02/
2004.

3.
BASF.
1999.
Biotechnology:
Fermentation.
<
www.
basf.
de/
en/
produkte/
biotech/
biokatalyse/
fermentation.
htm>
Accessed
06/
02/
2004.

4.
US
EPA
Envirofacts
<
www.
epa.
gov/
enviro>.

5.
News
Aktuell.
June
20,
2003.
Degussa
Attains
Sole
Ownership
of
Midwest
Lysine/
Strengthens
business
in
amino
acids
for
animal
nutrition.
<
www.
presseportal.
de>
Accessed
06/
02/
2004.
