1
Tobacco
Products
Processing
Detailed
Study
Plan
November
8,
2004
1.01
INTRODUCTION
ERG
will
support
EPA
in
collecting
additional
information
about
the
tobacco
products
processing
industry
(
SIC
code
21),
which
is
not
currently
regulated
by
effluent
guidelines
or
categorical
pretreatment
standards.
ERG
will
collect
data
to
determine
the
nature
and
quantity
of
pollutants
discharged
by
tobacco
processing
plants
and
whether
those
pollutants
are
likely
to
pass
through
or
interfere
with
POTWs
receiving
tobacco
industry
wastewaters.
Identification
of
wastewater
pollution
control
technologies
and
the
performance
and
costs
of
those
control
technologies
are
not
a
focus
of
this
study.
However,
information
on
control
technologies
may
be
collected
during
engineering
visits
to
tobacco
processing
plants,
if
such
information
is
available
from
the
visited
facilities.
For
planning
purposes,
ERG
assumes
it
will
conduct
four
site
visits
with
characterization
(
grab)
sampling.
Selection
of
these
sites
is
discussed
below.

2.0
BACKGROUND
The
tobacco
product
processing
industry
is
classified
by
four
SIC
codes:

2111
Cigarette
Manufacturing;

2121
Cigar
Manufacturing;

2131
Chewing
and
Smoking
Tobacco
and
Snuff;
and
2141
Tobacco
Stemming
and
Redrying.

The
NAICS
classifies
the
tobacco
industry
into
three
categories:

312221
Cigarette
Manufacturing;

312229
Other
Tobacco
Products;
and
121
facilities
reported
to
TRI
in
2002,
but
did
not
report
POTW
transfers
or
surface
water
releases.
These
facilities
may
transfer
chemicals
to
POTWs
(
or
release
chemicals
to
surface
water)
that
don't
meet
TRI
reporting
requirements.

2
312210
Tobacco
Stemming
and
Redrying.

NAICS
312229
includes
products
formerly
categorized
as
2121,
2131,
and
some
products
from
2141
(
i.
e.,
services
for
the
production
of
reconstituted
tobacco
sheet).

2.1
Number
of
Facilities
As
presented
in
Table
1
(
located
at
the
end
of
this
plan),
the
2002
Economic
Census
enumerated
114
tobacco
products
establishments
operated
by
96
companies.
Of
these
114
establishments,
nine
are
permitted
to
discharge
wastewater
directly,
and
all
nine
are
classified
as
minor
dischargers.
Because
they
are
minor
dischargers,
PCS
does
not
contain
any
information
about
their
permit
limits
or
pollutant
discharges.

Of
the
114
tobacco
products
establishments,
31
reported
releases
of
toxic
chemicals
to
TRI
for
2002.
Six
reported
transfers
of
toxic
chemicals
to
POTWs
(
including
one
facility
that
also
reported
direct
releases
to
receiving
streams).
Thus,
of
the
114
establishments
enumerated
by
the
census,
nine
are
identified
by
PCS
as
direct
dischargers,
six
reported
POTW
releases
to
TRI,
for
a
total
of
15
discharging
facilities.
We
do
not
know
how
many
of
the
99
facilities
(
114
­

9
­
6)
not
identified
as
dischargers
may
have
some
indirect
discharges1.

2.2
Pollutants
Discharged
Tobacco
products
facilities
reported
to
TRI
that
they
released
nine
toxic
chemicals
to
POTWs
or
receiving
streams
in
2002.
The
following
three
chemicals
were
reported
by
more
than
one
facility:
3
Ammonia;

Nicotine
and
salts;
and
Nitrate
compounds.

In
addition,
the
Chesapeake
Bay
Foundation
has
filed
a
suit
appealing
the
Virginia
Water
Control
Board's
decision
to
permit
Philip
Morris
to
increase
its
nitrogen
(
nitrate)
and
phosphorus
discharges
to
the
James
River.
This
Philip
Morris
plant,
in
Chesterfield
County,
reported
releasing
280,000
pounds
of
nitrate
compounds
in
2002.

3.0
INFORMATION
COLLECTION
ERG
will
conduct
the
following
information
collection
activities.

3.1
Identification
of
Tobacco
Products
Facilities
ERG
will
develop
a
list
of
tobacco
products
facilities,
that
includes:

facility
name
address
company
that
owns
the
facility
type
of
product
manufactured
non­
tobacco
activities
on­
site
(
e.
g.,
printing,
co­
generation
of
electric
power)
TRI
ID
and
contact
information
NPDES
ID
and
contact
information
local
POTW
POTW
contact
information
other
information
as
available,
including
quantity
of
production.

In
addition
to
PCS
and
TRI
databases,
the
sources
of
information
ERG
will
consult
to
identify
tobacco
product
facilities
include:
2The
minor
dischargers
listed
in
PCS
are
distributed
as
follows:
3
plants
­
North
Carolina
2
plants
­
Virginia
1
plant
each
­
Kentucky,
Maryland,
Pennsylvania,
and
Puerto
Rico
4
1.
U.
S.
Alcohol
and
Tobacco
Tax
and
Trade
Bureau
(
http//
www.
ttb.
gov)

collects
taxes
and
statistics
on
tobacco
production
contact
industry
analyst:
J.
R.
McCollum,
404­
417­
2620,

IndustryAnalyst.
tobacco@
ttb.
gov
2
U.
S.
Department
of
Agriculture,
Economic
Research
Service
tobacco
expert:
Thomas
Capehart
thomasc@
ers.
usda.
gov
3.
Websites
and
other
records
of
tobacco
companies,
to
identify
manufacturing
sites.

3.2
Collect
Available
Information
about
Direct
Dischargers
ERG
will
collect
available
information
for
the
nine
identified
direct
discharging
facilities2.

ERG
will
contact
state
permitting
authorities
to
obtain
permit
application
files
(
including
effluent
monitoring
data),
permit
fact
sheets,
permits,
results
of
compliance
monitoring
conducted
by
the
facility
and
provided
to
the
state,
and
results
of
any
monitoring
conducted
by
the
state.

At
the
direction
of
the
EPA
WAM,
ERG
will
interview
cognizant
state
permitting
and
enforcement
staff
to
discuss
any
ongoing
compliance
or
enforcement
issues
with
the
facilities.
3From
TRI
2002,
the
facilities
reporting
transfers
to
POTWs
are
distributed
as
follows:
2
plants
­
North
Carolina
2
plants
­
Virginia
1
plant
­
Georgia
5
3.3
Identify
Indirect
Dischargers
and
Collect
Available
Information
about
Indirect
Dischargers
Identification.
For
facility
names
and
addresses
obtained
from
web
searches
or
possibly
from
the
Tobacco
Tax
and
Trade
Bureau,
collected
as
described
in
3.1,
ERG
will
identify
the
facilities
with
the
largest
production.
ERG
will
identify
the
POTW
(
if
any)
receiving
wastewater
from
facilities
not
identified
as
direct
dischargers
and
not
reporting
transfers
to
POTWs
in
TRI.
ERG
will
identify
the
POTWs
using
available
information
from
PCS
or
other
EPA
databases
and
information
from
the
pertinent
city
and
state.

Collect
information
about
indirect
dischargers.
For
facilities
identified
as
indirect
dischargers,

ERG
will
contact
state
pretreatment
coordinators3.
ERG
will
determine
if
any
of
the
states'

indirect
discharging
tobacco
plants
are
SIUs
and
obtain
any
monitoring
data
or
other
information
retained
by
the
state.
At
the
direction
of
the
EPA
WAM,
ERG
will
interview
the
state
pretreatment
coordinator
to
identify
other
indirect
discharging
tobacco
facilities
and
discuss
any
ongoing
compliance
or
enforcement
issues
with
the
indirect
discharging
facilities.

ERG
will
contact
(
by
telephone
and/
or
mail)
the
POTWs
that
receive
wastewater
from
tobacco
facilities
to
determine
if
these
wastewaters
have
caused
upsets,
interference,
or
other
problems
with
the
operation
of
the
POTW.
ERG
will
ask
questions
focusing
on
nutrients
(
nitrates
and
phosphorus)
and
on
specific
toxic
pollutants.
ERG
will
request
any
monitoring
information
maintained
by
the
POTW,
including
treatment
performance
data
for
tobacco­
derived
pollutants
(
e.
g.,
nicotine
and
salts).
These
inquiries
are
expected
to
be
similar
to
inquiries
made
of
POTWs
receiving
aniline­
containing
discharges
from
OCPSF
facilities.
6
3.4
Site
Visits
and
Grab
Sampling
ERG
assumes
it
will
conduct
four
site
visits
with
characterization
(
grab)
sampling.

The
purpose
of
the
site
visits
is:

°
to
understand
the
process
sources
of
contaminated
wastewater
discharges
and
thus
likely
contaminants;

°
to
review
wastewater
treatment
technologies
and
other
pollution
control
technologies
used
to
control
wastewater
pollutant
discharges;
and
°
to
collect
any
effluent
monitoring
data
available
at
the
plant,
not
previously
obtained
from
control
authorities.

ERG
will
collect
samples
of
treated/
pretreated
effluent
in
order
to
identify
the
pollutants
discharged
from
the
visited
facilities.
Wastewater
flow
rate
information
will
also
be
collected,
in
order
to
estimate
the
mass
of
pollutants
discharged.

Site
selection.
ERG
recommends
selecting
sites
for
visits
after
available
information
about
direct
and
indirect
dischargers
has
been
collected
and
reviewed.
Criteria
for
selecting
sites
include:

°
Wastewater
is
treated
and
discharged
directly
or
indirectly;

°
Sites
manufacture
cigarettes
and/
or
engage
in
tobacco
stemming
and
redrying;
and
°
No
more
than
two
sites
owned
by
the
same
company
will
be
visited.

Wastewater
sample
analysis.
Samples
will
be
analyzed
for
priority
pollutants
and
other
toxic
and
nonconventional
pollutants.
Suggested
analytes
are
listed
in
Table
2
(
located
at
the
end
of
this
plan).
The
selected
analytes
reflect
the
following
current
understanding
of
tobacco
facility
wastewater
discharges:
7
°
Toxic
compounds
reported
discharged
from
tobacco
processing
plants
include
nicotine
and
salts,
ammonia,
metals,
and
other
organic
compounds.

°
Propylene
glycol
is
used
as
a
humectant
in
tobacco
processing.

°
Tobacco
air
emissions
contain
nicotine,
formaldehyde,
and
acetaldehyde.

°
A
variety
of
pesticides
is
applied
to
tobacco
in
the
field
and
during
fumigation
in
tobacco
storage
facilities.

ERG
will
contact
agricultural
specialists
in
tobacco­
growing
states
to
identify
pesticides
applied
to
tobacco
in
order
to
identify
potential
wastewater
contaminants.
At
the
direction
of
the
EPA
WAM,
ERG
will
work
with
EPA/
EAD
Methods
staff
to
ensure
that
the
appropriate
analytical
methods
are
selected
for
this
work.

4.0
Quality
Assurance
Planning
Under
a
separate
task,
ERG
is
preparing
a
QA
Project
Plan
for
the
development
of
detailed
industry
studies.
This
QA
Project
Plan
will
include
the
criteria
for
determining
if
secondary
data
are
suitable
for
EPA's
use.
In
addition,
the
detailed
study
QA
Project
Plan
will
cover
sample
collection
and
analysis
that
may
be
performed
during
the
study.

5.0
Documentation
(
Draft
Technical
Support
Document)

All
information
collected
by
ERG
will
be
prepared
for
inclusion
in
the
docket
supporting
EPA's
2006
Effluent
Guidelines
Program
Plan.
Confidential
Business
Information
(
CBI)
will
be
handled
in
accordance
with
EPA
policy
and
ERG's
approved
CBI
plan.

ERG
will
prepare
a
document
summarizing
the
findings
of
the
study.
The
goal
of
the
detailed
study
of
the
tobacco
industry
is
to
determine
the
nature
and
quantity
of
pollutants
discharged
by
plants
and
whether
those
pollutants
are
likely
to
pass
through
or
interfere
with
POTWs
receiving
tobacco
industry
wastewaters.
Information
collected
about
wastewater
8
pollution
control
technologies
during
site
visits
will
be
included
in
the
summary
document,
though
the
performance
and
costs
of
treatment
technologies
are
not
a
focus
of
this
study.
ERG
will
summarize
information
on
the
tobacco
products
processing
category
in
a
format
similar
to
the
EPA
document,
Preliminary
Data
Summary
­
Industrial
Container
and
Drum
Cleaning
Industry
(
EPA­
821­
R­
02­
011).
CBI
will
not
be
included
in
this
document.
The
draft
report
will
be
submitted
in
WordPerfect
®
and
Adobe
®
Acrobat
PDF
(
suitable
for
E­
Docket
and
Internet
posting).
9
Table
1
Number
of
Tobacco
Products
Processing
Facilities
NAICS
code
Description
SIC
Code
2002
Census
Current
PCS1
2002
TRI
Reporters
comp
estab
emp
(
All
Minor)
Total
No
reported
discharge
Direct
Indirect
Both2
312­
221
cigarette
mfg
2111
13
16
15,190
2
12
5
2
5
0
312­
229
other
tobacco
products
2121
(
cigars)
70
83
6,649
1
0
0
0
0
0
2131
(
chewing
&

smoking
tobacco)
1
5
5
0
0
0
312­
210
tobacco
stemming
and
redrying
2141
13
16
2,721
5
14
11
2
0
1
total
96
115
24,560
9
31
21
4
5
1
Sources:
2002
Economic
Census,
TRI
2000,
EPA/
OECA's
OTIS
tool,
search
on
SIC
code
=
21
Note:
Facilities
in
SIC
code
2141
may
also
make
cigarettes.

1.
Accessed
November
5,
2004.

2.
Facilities
reporting
both
direct
and
indirect
discharges.
10
Table
2
Analytes
for
Grab
Samples
from
Tobacco
Products
Processing
Parameter
Method
Number
Number
of
Samples
(
a)

Volatile
Organic
Compounds
1624
or
624
4+
1
Semivolatile
Organic
Compounds
1625
or
625
4+
1
Total
Metals
EPA
200.7,
200.8,
200.9,
and
245.7
(
Mercury
only)
4+
1
HEM/
SGT­
HEM
1664a
none
recommended
Cyanide,
Total
335.2
?

Cyanide,
Available
1677
?

Biochemical
Oxygen
Demand
(
5­
day)
405.1
4
Group
I
(
b)
­
4
Group
II
(
c)
­
4
Dioxins
and
Furans
EPA
1613b
4+
1
Organo­
Phosphorus
Pesticides
1657,
with
high
res
confirmation
(
d)
8
Organo­
Halide
Pesticides
1656,
with
high
res
confirmation
(
d)
8
Proplyene
Glycol
tbd
4+
1
Nicotine
tbd
8
Formaldehyde
tbd
4+
1
Acetaldehyde
tbd
4+
1
(
a).
4+
1
means
4
samples
and
1
"
process
water"
blank.
(
b))
Group
I
includes
total
dissolved
solids
(
TDS),
total
suspended
solids
(
TSS),
sulfate,
chloride,
and
alkalinity.
(
c)
Group
II
includes
total
organic
carbon
(
TOC),
chemical
oxygen
demand
(
COD),
ammonia
as
nitrogen,
nitrate/
nitrite
as
nitrogen,
total
Kjeldahl
nitrogen
(
TKN),
and
total
phosphorus.
(
d)
Methods
1657
and
1756
have
not
reliably
identified
pesticides
in
recently
analyzed
wastewaters.
ERG
recommends
including
a
third
column,
high
resolution
GC
confirmation
of
any
pesticides
detected
in
preliminary
anlaysis
of
sampled
wastewar.
ERG
also
recommends
collecting
a
process
water
blank,
collected
at
each
sampled
facility,
and
anlalyzing
the
background
sample
for
pesticides.
