Evaluation of RSEI Model Runs Prepared for:

U. S. Environmental Protection Agency Engineering and Analysis Division Office of Water 1200 Pennsylvania Avenue, NW Washington DC 20460 Prepared by:

Eastern Research Group, Inc. 14555 Avion Parkway Suite 200 Chantilly, VA 20151 August 6, 2003 Addendum Added December 12, 2003 EPA Contract No. 68 C02 095 Work Assignment 0 05 and 1 05 ACKNOWLEDGMENTS AND DISCLAIMER The Agency would like to acknowledge the contributions of Carey Johnston and Pat Harrigan of EPA's Office of Water and Steven Hassur of EPA's Office of Pollution and Prevention and Toxics in the development of this technical document. In addition, EPA acknowledges the contribution of Eastern Research Group.

Neither the United States government nor any of its employees, contractors, subcontractors, or other employees makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use of, or the results of such use of, any information, apparatus, product, or process discussed in this report, or represents that its use by such a third party would not infringe on privately owned rights. References to proprietary technologies are not intended to be an endorsement by the Agency.

Questions or comments regarding this technical document should be addressed to:

Ms. Lynn Zipf Biologist Engineering and Analysis Division ( 4303T) U. S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460 ( 202) 566  1429 zipf. lynn@ epamail. epa. gov i RSEIreport_ 121203. wpd TABLE OF CONTENTS Page EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES 1 1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 2.0 OVERVIEW OF RSEI MODEL ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1 2.1 Overview of TRI Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2 2.2 Types of RSEI Model Output . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 4 2.3 Adaptations to Customize RSEI Output . . . . . . . . . . . . . . . . . . . . . . . 2 6 2.4 Calculation of Risk Related Results . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 7 2.4.1 Exposure Pathways . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 8 2.4.2 Chemical Toxicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 9 2.5 Completeness of RSEI Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 11 3.0 RSEI RANKINGS BY POINT SOURCE CATEGORY . . . . . . . . . . . . . . . . . . . . . . . . 3 1 3.1 Steam Electric Power Generation ( 40 CFR Part 423) . . . . . . . . . . . . . 3 6 3.1.1 Industry Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 6 3.1.2 Summary of RSEI TRI Data . . . . . . . . . . . . . . . . . . . . . . . . . . 3 8 3.2 Organic Chemicals, Plastics, and Synthetic Fibers ( 40 CFR Part 414) . 3 9 3.2.1 Industry Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 9 3.2.2 Summary of RSEI TRI Data . . . . . . . . . . . . . . . . . . . . . . . . . 3 12 3.3 Timber Products Processing ( 40 CFR Part 429) . . . . . . . . . . . . . . . . 3 14 3.3.1 Industry Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 14 3.3.2 Summary of RSEI TRI Data . . . . . . . . . . . . . . . . . . . . . . . . . 3 16 3.4 Pulp, Paper, and Paperboard ( 40 CFR Part 430) . . . . . . . . . . . . . . . . 3 17 3.4.1 Industry Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 18 3.4.2 Summary of RSEI TRI Data . . . . . . . . . . . . . . . . . . . . . . . . . 3 19 3.5 SIC Code 5171: Petroleum Bulk Stations and Terminals . . . . . . . . . . 3 20 3.5.1 Industry Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 20 3.5.2 Summary of RSEI TRI Data . . . . . . . . . . . . . . . . . . . . . . . . . 3 22 3.6 Petroleum Refining ( 40 CFR Part 419) . . . . . . . . . . . . . . . . . . . . . . . 3 23 3.6.1 Industry Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 23 3.6.2 Summary of RSEI TRI Data . . . . . . . . . . . . . . . . . . . . . . . . . 3 25 3.7 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 27 4.0 ITEMS FOR FURTHER CONSIDERATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 1 TABLE OF CONTENTS ( Continued)

ii RSEIreport_ 121203. wpd Attachment A: TRI OVERVIEW Attachment B: CALCULATION OF EAD TWF HAZARD Attachment C: RELATION OF SIC CODES TO POINT SOURCE CATEGORIES Attachment D: POINT SOURCE CATEGORY RANKINGS BY EAD TWF HAZARD Addendum: DATA CORRECTIONS AND REVISED RESULTS iii RSEIreport_ 121203. wpd LIST OF TABLES Page 3 1 Ranking of Point Source Categories That Comprise 90% of EAD TWF Hazard . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3 3 2 Summary Statistics for Point Source Categories That Comprise 90% of EAD TWF Hazard . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 5 3.1 1 Summary Statistics for the Steam Electric Power Generation Point Source Category ( 40 CFR Part 423) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 8 3.1 2 Chemical Summary Statistics for the Steam Electric Power Generation Point Source Category ( 40 CFR Part 423) . . . . . . . . . . . . . . . . . . 3 9 3.2 1 Summary Statistics for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category ( 40 CFR Part 414) . . . . . . . . . . . . . 3 12 3.2 2 Chemical Summary Statistics for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category ( 40 CFR Part 414) . . . . . . . . . . 3 13 3.3 1 Summary Statistics for the Timber Products Processing Point Source Category ( 40 CFR Part 429) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 16 3.3 2 Chemical Summary Statistics for the Timber Products Processing Point Source Category ( 40 CFR Part 429) . . . . . . . . . . . . . . . . . . . . . . . . . . 3 17 3.4 1 Summary Statistics for the Pulp, Paper, and Paperboard Point Source Category ( 40 CFR Part 430) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 19 3.4 2 Chemical Summary Statistics for the Pulp, Paper, and Paperboard Point Source Category ( 40 CFR Part 430) . . . . . . . . . . . . . . . . . . . . . . . . . . 3 20 3.5 1 Summary Statistics for SIC Code 5171: Petroleum Bulk Stations and Terminals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 22 3.5 2 Chemical Summary Statistics for SIC Code 5171: Petroleum Bulk Stations and Terminals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 23 3.6 1 Summary Statistics for the Petroleum Refining Point Source Category ( 40 CFR Part 419) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 25 3.6 2 Chemical Summary Statistics for the Petroleum Refining Point Source Category ( 40 CFR Part 419) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 26 ES 1 RSEIreport_ 121203. wpd EXECUTIVE SUMMARY The Clean Water Act requires EPA to periodically revise existing effluent limitations guidelines and standards ( ELGs), and promulgate ELGs for new point source categories of discharges. EPA published a draft National Strategy that sets forth a planning process to review national effluent guidelines and set priorities. EPA identified four major factors, derived from sections 301( b)( 2) and 304( b) of the CWA, that could lead EPA to conclude that a revision of an existing effluent guideline or a promulgation of new guideline would be appropriate: 1) the extent to which the industry category is discharging pollutants that pose a risk to human health or the environment; 2) the identification of an applicable and demonstrated technology, process change, or pollution prevention approach that would substantially reduce the remaining risk; 3) the cost, performance, and affordability of the technology, process change, or pollution prevention approach that would substantially reduce that risk; and 4) implementation and efficiency considerations, such as whether revising a guideline is the most effective approach for reducing the risk. Factor 1 evaluates the extent to which an industry category is discharging pollutants that pose an impact to human health or the environment. EPA is considering the use of several data sources and tools available to evaluate human health and environmental impacts. One of these tools is the Risk Screening Environmental Indicators ( RSEI) model, developed by EPA's Office of Pollution Prevention and Toxics ( OPPT).

The RSEI model uses Toxic Release Inventory ( TRI) data to estimate chronic human toxicity associated with long term exposures from air and water releases. To support initial screening level analyses for the Strategy, EPA's Engineering and Analysis Division ( EAD)

conducted a review of the RSEI model output for water discharges ( based on TRI reported releases for the year 2000). This review evaluated the completeness of the RSEI model relative to the goals of the Strategy, and assessed the validity of the ranked lists of point source categories and SIC codes contributing potential risk. EAD also performed an analysis of RSEI output customized to incorporate EAD toxic weighting factors ( TWFs), which consider both human health and aquatic life effects. EAD found the following results: ES 2 RSEIreport_ 121203. wpd

Approximately 50 facilities out of approximately 7,800 facilities that reported direct or indirect discharges to surface water in the 2000 TRI contribute 90 percent of both the RSEI risk related and EAD TWF hazard scores for the entire United States. ( The specific facilities comprising 90 percent of the two results differ.)

RSEI risk related and EAD TWF hazard scores for many of the top SIC codes and point source categories are driven by discharges from a few or only one facility.

Thirty four out of 400 SIC codes are assigned RSEI risk related results of zero; 9 of the 400 SIC codes were assigned an EAD TWF hazard of zero.

Eighty of the 329 TRI list chemicals with reported direct and indirect discharges to surface water in the 2000 TRI included a RSEI risk related score of zero due to the lack of chronic human health toxicity data in the RSEI model. Fifty six of the 329 TRI list chemicals received an EAD hazard score of zero due to the lack of EAD TWFs.

Metals and metal compounds represent approximately 78 percent of the total RSEI risk related results, but only 4 percent of the TRI reported pounds discharged. Two TRI compound categories, polycyclic aromatic compounds ( PACs) and dioxin and dioxin like compounds, represent approximately 93 percent of the EAD TWF hazard scores, but less than 0.005 percent of the total TRI reported pounds discharged.

To customize RSEI output for analyses supporting the National Strategy, EAD created a ranked list of industries ( using EAD's point source categories) comprising 90 percent of the EAD TWF hazard scores. The six categories are:

EAD TWF Hazard Score Rank Point Source Category 1 Steam electric power generation 2 Organic chemicals, plastics, and synthetic fibers 3 Timber products processing 4 Pulp, paper, and paperboard 5 SIC 5171: Petroleum bulk stations and terminals 6 Petroleum refining ES 3 RSEIreport_ 121203. wpd EAD also identified some general items for further consideration, which reach across point source categories and SIC codes. Section 4.0 lists details of the general and point source category specific items that EAD identified, including validating the water related RSEI results, investigating whether the reported PAC and dioxin and dioxin like compound releases represent a reasonable measure of actual discharges, and conducting site specific second level screening and evaluation to validate RSEI results.

Following the initial screening level review of PCS data, EAD conducted additional data quality reviews of reported pollutant discharges for certain top ranking industries and facilities. These reviews identified both misreported and miscalculated data, including:

° Adjustments to SIC codes associated with reported discharges ( affecting the point source category or industry to which the pollutant loads are attributed);

° Revisions to TWFs used for certain TRI chemical categories ( e. g., dioxin, PACs) to better reflect the specific chemicals discharged by a specific industry;

° Adjustments to the point source category/ SIC crosswalk to eliminate or minimize double counting of pollutant loads between industry categories; and ° Facility and pollutant specific adjustments to reflect misreported or miscalculated pollutant loadings.

An addendum detailing these data corrections, as well as the revised pollutant loads by point source category and industrial grouping, is included at the end of this report. 1 1 RSEIreport_ 121203. wpd 1.0 INTRODUCTION The Clean Water Act requires EPA to periodically review existing effluent guidelines, pretreatment standards, and new source performance standards and to revise them " if appropriate" or, in the case of new source performance standards, " as technology and alternatives change." In addition, the Clean Water Act requires EPA to promulgate effluent guidelines for new point source categories of discharges under certain circumstances. EPA is proposing a process to establish priorities for the Effluent Guidelines Program that is predicated on selecting opportunities for the greatest potential risk or hazard impact reduction, and to make choices in consultation with the public and regulated communities based on the potential to cost effectively reduce levels of potential impact to human health and the environment.

EPA published a draft National Strategy that sets forth a planning process to review national effluent guidelines and set priorities. EPA identified four major factors, derived from sections 301( b)( 2) and 304( b) of the CWA, that could lead EPA to conclude that a revision of an existing effluent guideline or a promulgation of new guideline would be appropriate: 1) the extent to which the industry category is discharging pollutants that pose a risk to human health or the environment; 2) the identification of an applicable and demonstrated technology, process change, or pollution prevention approach that would substantially reduce the remaining risk; 3)

the cost, performance, and affordability of the technology, process change, or pollution prevention approach that would substantially reduce that risk; and 4) implementation and efficiency considerations, such as whether revising a guideline is the most effective approach for reducing the risk. The Strategy describes how EPA intends to evaluate readily available information on potential risk and impacts associated with point source discharges, solicit input from stakeholders, gather additional information, evaluate whether effluent guidelines are the most efficient approach to achieving environmental improvements, and present results to the public.

Factor 1 evaluates the extent to which an industrial category is discharging pollutants that pose a potential impact to human health or the environment. In this evaluation,

EPA expects to consider the total amount of pollutants discharged by the industrial category, the 1 2 RSEIreport_ 121203. wpd toxicity of that discharge to both human health and the environment, the fate and transport of those pollutants, and the number of potentially exposed individuals. EPA is considering the use of several data sources and tools available to evaluate human health and environmental impacts, as discussed in the report entitled, " Factor 1 Analysis: Human Health and Environmental Impacts,"

dated December 2003. One of these data sources is EPA's TRI, which includes estimates of pollutant discharges to water.

The RSEI model, developed by EPA's Office of Pollution Prevention and Toxics ( OPPT), is a tool used to estimate the risk associated with discharges to the environment. The RSEI model uses data reported in the TRI to estimate chronic human toxicity associated with long term exposures from air and water releases. Since publication of its first proposed methodology in 1991, the Risk Screening Environmental Indicators ( RSEI; earlier known as the TRI Relative Risk Based Environmental Indicators) has been reviewed by risk experts including experts in academia, industry trade associations, federal and state government, and the EPA Science Advisory Board ( SAB). The SAB reviews endorsed the RSEI methodology ( including the framework of the water release model) and the revised toxicity weighting approach for screening purposes. Validation of the air release model was conducted by Agency staff. EAD also evaluated TRI reported discharges output from the RSEI model using EAD TWFs. These TWFs incorporate both human health and aquatic life effects.

This report discusses initial screening level analysis of RSEI model output for both direct and indirect water discharges reported in the 2000 TRI. The remainder of this report is organized in the following sections:

Section 2.0 gives an overview of the RSEI model, as well as an overview of TRI;

Section 3.0 presents a discussion of six point source categories from the RSEI model ranking; and

Section 4.0 discusses future activities under consideration. 1 3 RSEIreport_ 121203. wpd Throughout the review of TRI data, EPA identified and corrected misreported or miscalculated data. A summary of these data changes can be found in the addendum to this report. EPA does not believe that all errors have been corrected at this time. Additional corrections will be added to the addendum as they occur. 2 1 RSEIreport_ 121203. wpd 2.0 OVERVIEW OF RSEI MODEL ANALYSIS EPA's TRI collects data for 612 chemicals released and transferred by selected facilities in the United States. Some of these chemicals have qualifiers associated with them, and only those qualified forms of the chemical are reported to TRI ( e. g., aluminum is only reportable in the form of a fume or dust). It is important to note that conventional pollutants ( e. g., total suspended solids, biochemical oxygen demand, pH, and oil and grease) are not reported to TRI,

and therefore are not modeled. In 2000, facilities reported releases of 527 chemicals and chemical categories. RSEI contains toxicity data on 426 of these chemicals and chemical categories.

The RSEI model allows users to complete screening level analyses of facilities and chemicals using TRI data. One way facilities are identified in RSEI is by primary 4 digit Standard Industrial Classification ( SIC) code. The RSEI model incorporates the following information into the model:

Amount of the chemical released as reported from TRI;

Location of the chemical release, assumed to be the actual facility location as reported from TRI;

Proportional toxicity and toxicity weights based on sources such as the Integrated Risk Information System ( IRIS);

Estimated fate and transport of the chemical in the environment once released;

Pathway of release based on the TRI reported medium and extent of human exposure;

Number of people exposed through fish ingestion based on 1990 U. S. Census data; and

Number of people exposed based on drinking water populations from the Safe Drinking Water Information System ( SDWIS) for assessment of drinking water exposures. 2 2 RSEIreport_ 121203. wpd These components are combined and modeled to offer a quantitative screeninglevel risk related perspective for relative comparisons of chemical releases. The model also allows users to examine results from a hazard based perspective ( i. e., where TRI releases are weighted only by the toxicity of the chemical released, without considering the potential for exposure or number of people exposed), as well as view results from a pollutant loadings ( in pounds) perspective. This feature allows users to conduct analyses of releases and transfers of chemicals where exposure and modeling information is absent.

Section 2.1 presents an overview of TRI and how data are reported to EPA.

Section 2.2 describes types of RSEI model output, and Section 2.3 discusses EPA's adaptations to customize RSEI output for analyses supporting the National Strategy. Section 2.4 discusses the way RSEI calculates a risk related result, including discussions of exposure pathways modeled and chemical toxicity weights. Finally, Section 2.5 discusses the completeness of the RSEI analysis.

2.1 Overview of TRI Reporting TRI is the common name for Section 313 of the Emergency Planning and Community Right to Know Act ( EPCRA). Each year, facilities that meet certain thresholds ( such as number of employees) must report their releases and other waste management activities ( quantities recycled, collected, and combusted for energy recovery, treated for destruction, or disposed) for listed toxic chemicals. A separate report must be filed for each chemical that exceeds a threshold.

There are three criteria that a facility must meet to be required to submit a TRI report for that reporting year. The criteria are:

1) SIC Code Determination: Facilities in SIC Codes 20 through 39, seven additional SIC codes outside this range, and federal facilities must evaluate whether additional criteria are met and whether reporting is required. EPA rarely checks or refutes facility claims regarding the SIC code identification. The primary SIC code, which is based on the facility's 2 3 RSEIreport_ 121203. wpd primary activity as reported by the submitter, determines TRI reporting and has been used as the basis for the RSEI analysis.

2) Number of Employees: Facilities must have 10 or more full time employees or their equivalent. EPA defines a " full time equivalent" as a person that works 2,000 hours in the reporting year ( there are several exceptions and special circumstances that are well defined in the TRI reporting instructions).

3) Activity Thresholds: If the facility is in a covered SIC code and has 10 or more full time employee equivalents it must conduct an activity threshold analysis for every chemical and chemical category on the current TRI list. The facility must determine whether it manufactures, processes, OR otherwise uses each chemical at or above the appropriate activity threshold. Reporting thresholds are not based on the amount of release. All TRI thresholds are based on mass, not concentration. Different thresholds apply for persistent bioaccumulative toxic ( PBT) chemicals than for non PBT chemicals.

If a facility does not manufacture, process, or otherwise use any EPCRA Section 313 chemicals, it is not required to report to the TRI. This may account for the number of facilities known to be part of an SIC code in the 1997 U. S. Economic Census but not included in the RSEI analysis.

EPA identified several factors associated with TRI reporting that could cause confusion when analyzing RSEI results:

Range Reporting: TRI provides the option for facilities to report releases as specific numbers or as ranges, if appropriate. Specific estimates are encouraged if data are available to ensure the accuracy; however, EPA allows facilities to report releases in the following ranges: 1 to 10 pounds, 11 to 499 pounds, and 500 to 999 pounds. Range reporting is not permitted for PBT chemicals. The RSEI model uses the mid point of each reported range.

Detection Limits: Companies are required to use their judgement and report the most accurate information. The TRI program does not specify the use ( or non use) of detection limits. TRI guidance states that if a facility reasonably expects a chemical to be present in waste streams, the facility should assume half of the detection limit for estimates. If the 2 4 RSEIreport_ 121203. wpd facility does not reasonably expect the chemical to be present, they can assume a concentration of zero.

The De Minimis Exemption: TRI includes an exemption such that, in general, chemicals in any process or waste stream below 1 percent ( by mass) for non carcinogens or below 0.1 percent for carcinogens ( as defined by OSHA) should be excluded from both threshold and release estimates. The de minimis exemption is not applicable to the manufacture of any TRI chemical nor to PBT chemicals.

Alternate Certification Statement ( Form A): Starting in 1997, EPA instituted an optional second type of TRI Report, commonly called the Form A. With implementation of Form A, facilities may now certify that the total quantity of a specific chemical released and managed as waste is less than 500 pounds without quantifying estimates to any media. A significant number of Form A's are submitted by every industry each year; Form A's cannot be submitted for PBT chemicals. According to the 2000 Public Data Release 8, 456 Form A's were filed. Initial analysis of RSEI indicates that, because no release quantity can be assigned to any media, RSEI ignores all Form A submissions.

Test Data: EPCRA mandates that facilities use the " best readily available information" to prepare threshold and release estimates for TRI reporting. It does not require the facility to conduct tests on the chemicals. However, if testing has been conducted for any other purpose, the facility is required to consider using the results if they are appropriate.

Further information on TRI reporting, including discussions of how facilities report metals and metal compounds, how TRI data change over time, and TRI data quality, can be found in Attachment A to this report. More detailed information on the TRI program is located on EPA's TRI homepage: http:// www. epa. gov/ tri/.

2.2 Types of RSEI Model Output Using RSEI model results generated by the OPPT, EAD analyzed RSEI model output encompassing a subset of TRI releases and transfers of chemicals by facilities to surface waters and POTWs for the year 2000. Although RSEI can model both air and water releases, this model cannot currently account for air deposition modeling that could result in chemical deposition into lakes, streams, and watersheds from stack air emissions. 2 5 RSEIreport_ 121203. wpd RSEI develops four rankings from the TRI data: 1) RSEI risk related result, 2)

modeled hazard, 3) hazard, and 4) total TRI pounds. EAD developed a fifth ranking: EAD TWF hazard. These rankings are defined as follows:

Risk Related Results  The risk related result is the product of the surrogate dose ( estimated using exposure models), the chemical's toxicity weight, and the exposed population. This result requires all necessary modeling parameters to be present, and provides the most comprehensive ranking available by the model. The amount of chemical released is the modeled amount based on the fate and transport of the chemical pounds and physical/ chemical properties of the chemical.

Modeled Hazard  This value is computed by multiplying modeled TRI pounds by the proportional toxicity weight of the chemical appropriate for the exposure pathway selected ( i. e., inhalation toxicity weight or ingestion toxicity weight). Modeled TRI pounds are those in which all of the required input parameters required to calculate a risk related result are present. Modeled TRI pounds do not necessarily include all reported discharges to surface waters or POTWs ( e. g., pounds may be excluded because other required parameters are not available).

Hazard  This value is calculated for TRI chemicals that have toxicity weights and provides a perspective regarding the chronic human health hazard of these releases. The hazard score is calculated by multiplying reported TRI pounds by the toxicity weight of the chemical associated with the release pathway selected ( i. e., inhalation toxicity weight or oral toxicity weight). The model uses the inhalation toxicity weight when calculating the hazard score for air releases. For TRI on site direct water releases and offsite transfers to POTWs, the model uses the oral toxicity weight ( riskrelated calculations use toxicity weights for both exposure pathways when modeling the air and water releases from POTWs). For unmodeled releases, RSEI uses the highest toxicity weight for the hazard score. For this analysis, for indirect dischargers, the hazard score accounts for treatment at a POTW.

Total TRI Pounds  This amount reflects the number of pounds released or transferred that are reported to the TRI. The model includes pounds discharged to surface water by both direct and indirect discharges. For indirect discharges, the reported pounds transferred off site to POTWs are adjusted to account for treatment at a POTW.

EAD Toxic Weighting Factor ( TWF) Hazard  This value is calculated for TRI chemicals that have EAD TWFs, as developed by EAD's Economic & Environmental Assessment Branch. EAD TWF hazard scores 2 6 RSEIreport_ 121203. wpd are calculated by multiplying total TRI pounds ( described above) by the EAD TWF of the chemical. For more details on how EAD TWFs were calculated, see Section 2.3.

2.3 Adaptations to Customize RSEI Output In the thirty years since Congress passed the 1972 Clean Water Act, EPA has promulgated effluent guidelines that address 56 categories, and in the process has developed a variety of tools and methodologies to evaluate effluent discharges. To customize RSEI output to support the National Strategy, EAD incorporated the following factors into its analyses:

EAD TWFs in place of RSEI toxic weights; and

Point source category designations by facility based on the primary SIC code ( retaining the 4 digit SIC code for those facilities not included in existing point source categories).

As discussed in Section 2.4.2, the RSEI model considers only chronic human health effects in assigning chemical toxicity. In contrast, EAD assigns chemical toxicity based on both aquatic life effects and human health effects. EAD maintains a Toxics Data Base containing aquatic life and human health toxicity data, as well as physical/ chemical property data, for more than 1,900 pollutants compiled from over 100 references. Chemical specific information needed to generate EAD TWFs include aquatic life criteria or toxic effect data for native aquatic species,

human health reference doses ( RfDs), and cancer potency slope factors ( SFs). In developing an EAD TWF, a value for aquatic life effects and a value for human health effects are added. The calculation is performed by dividing aquatic life and human health criteria ( or toxic effect levels)

for each pollutant, expressed as a concentration in micrograms per liter ( µ g/ L), into the former copper criterion of 5.6 µ g/ L:

TWF

5.6 AQ  5.6 HHOO where:

TWF = toxic weighting factor AQ = chronic aquatic life value ( µ g/ L) 2 7 RSEIreport_ 121203. wpd HHOO = human health ( ingesting contaminated organisms only) value ( µ g/ L).

For more details on how EAD determines TWFs, see Toxic and Pollutant Weighting Factors of the Final Effluent Limitations Guidelines and Standards for Iron and Steel Industry, Final Report April 30, 2002.

The TRI list includes 612 chemicals and compound categories; however, reported direct or indirect discharges to surface water in the 2000 TRI included a total of 329 TRI list chemicals and compound categories. EAD TWFs have not been developed for 56 of these chemicals, resulting in an EAD TWF hazard score of zero for these compounds. For more details on how EPA correlated EAD TWFs to the TRI list of chemicals and compound categories, see Attachment B. Note that two compounds, PACs and dioxin and dioxin like compounds,

represent less than 0.005 percent of the TRI reported pounds discharged to water, but approximately 93 percent of the total EAD TWF hazard score as a result of the relatively high EAD TWFs for these compounds. See Section 3.0 for further discussion of this issue.

To analyze RSEI output at the point source category level, EAD related SIC codes to point source categories for existing ELGs. Facilities are required to report a primary SIC code that best characterizes the activities occurring at the facility. ( Facilities may report up to five more additional codes.) For this analysis, EPA used the reported primary SIC code. EAD aggregated the results of the model for discharges to surface waters and transfers to POTWs and ranked the results by point source category and/ or primary SIC code. See Section 3.0 for further information regarding the classification of point source categories and compilation of RSEI output by point source categories.

2.4 Calculation of Risk Related Results Version 2.1 of the RSEI model calculates values that reflect, for modeled TRI releases and transfers, chronic human health risk related impacts. The model does not include 2 8 RSEIreport_ 121203. wpd acute human health risks or risks to aquatic life. The values output by the model can only be interpreted as relative measures and are only meaningful in relationship to one another.

The model uses many parameters, all of which must be present in order to calculate a risk related result. For example, facilities are assumed to discharge to the nearest receiving stream reach ( i. e., a linear, unbranched section of a water body), as long as that reach is within six kilometers of the facility or the actual receiving body is known; otherwise, the discharge is not modeled. Note that stream reach data are not available for Alaska, Hawaii, Puerto Rico,

the U. S. Virgin Islands, Guam, American Samoa, and the Northern Marianis Islands; therefore, no surface water releases are modeled for those areas, and no risk related results are calculated.

2.4.1 Exposure Pathways The RSEI model calculates chronic human health exposures for surface water releases for two pathways: drinking contaminated water and eating non commercial contaminated fish. RSEI evaluates the exposure pathway by assuming that facilities discharge chemicals into the nearest stream reach, unless the actual receiving body is known ( in which case RSEI uses the reported reach). Chemical concentrations are estimated for distances up to 200 kilometers downstream from the chemical release location. For more details on how RSEI calculates exposure, see the document DCN00233 in Section 3.1.1 of the National Strategy docket.

RSEI evaluates fish ingestion based on a county level data set from state fish and wildlife data ( fishing or hunting/ fishing licenses) for 1996 ( or 1997 if 1996 was not available).

RSEI matches the county level data in conjunction with U. S. Economic Census data to estimate the number of people by age and gender who would likely ingest fish. The model estimates the chemical concentration in fish based on fate and transport in streams to which chemicals are released. Matching all these data together, RSEI estimates the human exposure resulting from fish ingestion.

Estimates of the population served by each drinking water intake are obtained from the SDWIS. The model uses these estimates as inputs for population size for exposure through 2 9 RSEIreport_ 121203. wpd drinking water. Note that if a stream reach contains no drinking water intake, the exposed population is set to zero for exposure through drinking water and the RSEI risk related result is zero. However, a hazard related result may still be calculated based on the pounds of chemical discharged and the chemical toxicity.

For indirect discharges ( transfers to POTWs), RSEI models chemicals entering the POTW as liquid influent. Depending on the chemical's physical properties, some portion of the influent chemical may be discharged into surface water, resulting in human exposure through drinking water or fish ingestion. Therefore, the model considers overall removal efficiencies of POTWs and resulting discharges. The model requires input on all of the following parameters to model exposure from chemical transfers to POTWs:

Location of the POTW to which chemicals are discharged;

Location of the stream reach to which the POTW discharges;

Overall removal efficiencies of POTWs and resulting removal rate ( i. e., contaminant specific removal rate); and

Residuals management at POTWs ( i. e., partitioning within the POTW).

Methods used to estimate population exposure to surface water effluent discharges from POTWs are the same as for estimating population exposure to direct surface water discharges, as previously described.

2.4.2 Chemical Toxicity EPA chose a method of assigning toxicity weights to chemicals based upon easily accessible and publicly available information, and uses expert EPA wide judgments to the greatest extent possible. The toxicity weights in RSEI are based upon the single, most sensitive chronic human health endpoint ( i. e., cancer or the most sensitive noncancer effect) for inhalation or ingestion exposure, and do not reflect severity of effects, multiple health effects, or dermal absorption. Neither acute human toxicity nor environmental toxicity are modeled. RSEI reflects 2 10 RSEIreport_ 121203. wpd the toxicities of chemicals relative to one another using a continuous system of numerical weights.

Toxicity weights for chemicals increase as the toxicological potential to cause chronic human health effects increases.

The TRI list includes 30 chemical compound categories. EPA's methodology for assigning toxicity weights to these categories was to determine a representative chemical for each group ( if possible) and assign the toxicity weight of that representative compound to the entire category. Table B 1 of Attachment B lists the 30 TRI chemical compound categories and the representative chemical used to assign RSEI toxicity weights.

RSEI makes two significant assumptions regarding the toxicity of metals and metal compounds. These assumptions are necessary because TRI reporting does not identify the valence state of metals or metal compounds, and because the chemical identity of metal compounds released to the environment is not reported ( only the quantity of the parent metal contained within compounds). The first assumption RSEI makes is that metal compounds have the same toxicity weight as that of the parent metal, even though the chronic human toxicity of some metal compounds may be higher or lower than the parent metal. The second, conservative assumption is that the entire release consists of the valence state associated with the highest chronic human toxicity ( e. g., for chromium, Cr+ 6 versus Cr+ 3). Therefore, RSEI results may overestimate the potential risk for metals, and may overestimate or underestimate the potential risk for metal compounds. For more information on metals and their bioavailability, see the February 24, 2003 memorandum entitled " Evaluation of the Appropriateness of Representative Chemicals for Influential Chemical Groups" from Susan Keane and Kristina Watts, Abt Associates, to Lynn Zipf, EPA\ OW. Note that metals and metal compounds represent only 4 percent of the TRIreported pounds discharged, but approximately 78 percent of the total RSEI risk related results,

likely as a result of these two assumptions.

The TRI list includes 612 chemicals and compound categories. One hundred eighty six chemicals reported in TRI lack chronic human health toxicity data, including dioxins ( reported by 172 facilities). However, discharges for many of these chemicals were not reported to TRI ( reported direct or indirect discharges to surface water in the 2000 TRI included a total of 2 11 RSEIreport_ 121203. wpd 329 TRI list chemicals and compound categories). Furthermore, some chemicals have only inhalation toxicity data and not ingestion toxicity data. In some cases, such as with ammonia ( reported by 1,301 facilities), RSEI does not assign risk associated with surface water discharges and transfers to POTWs because there is evidence that using inhalation data in this case is inappropriate. As a result of these factors, 80 of the 329 TRI list chemicals with reported direct or indirect discharges to surface water in the 2000 TRI include a RSEI risk related score of zero.

2.5 Completeness of RSEI Analysis Sections 2.3 and 2.4.2 of this report described the completeness of the RSEI analysis at the pollutant level. This section describes the completeness of the analysis at the SIC code and point source category level.

There are a total of 400 SIC codes represented by all facilities with reported direct or indirect discharges to surface water in the 2000 TRI. Because all input parameters required to calculate RSEI model results may not be present, EPA analyzed how many SIC codes were evaluated in the RSEI model. The results are as follows:

395 of the 400 SIC codes have RSEI model toxicity data for at least one chemical that is discharged, while 391 of the 400 SIC codes have EAD TWF hazard data for at least one chemical that is discharged.

366 SIC codes were assigned a risk related result that was greater than zero, while 34 SIC codes were assigned a risk related result of zero. [ Note that the RSEI model can assign a risk related result of zero for different reasons ( e. g. lack of required parameters for modeling, or an exposed population of zero)].

All 391 SIC codes with EAD TWF hazard score for at least one chemical were assigned a total EAD TWF hazard score greater than zero, while the remaining 9 SIC codes were assigned an EAD TWF hazard score of zero.

RSEI is likely to underestimate the discharge because only the primary SIC is used.

For facilities in several SIC codes, RSEI would be underestimating the discharges in those other SIC codes and overestimating the discharges for the primary SIC codes. 3 1 RSEIreport_ 121203. wpd 3.0 RSEI RANKINGS BY POINT SOURCE CATEGORY RSEI output shows 7,814 facilities reported discharges to surface waters and transfers to POTWs during the year 2000. Of these 7,814 facilities, 6,074 were assigned a riskrelated result greater than zero, and 1,740 facilities were assigned a risk related result of zero. In contrast, 7,625 of the 7,814 facilities were assigned an EAD TWF hazard score greater than zero,

while 189 facilities were assigned an EAD TWF hazard score of zero. Analysis also shows that approximately 50 facilities represent 90 percent of both the total national RSEI risk related result and the EAD TWF hazard score ( the specific facilities comprising 90 percent of the two results differ). Therefore, less than one percent of the total number of facilities reporting releases and transfers account for 90 percent of the RSEI model results, either on a risk basis or a hazard basis.

To facilitate analysis of the RSEI model results to support the National Strategy,

EAD summed SIC code specific RSEI results for each of the point source categories with existing effluent limitation guidelines and standards. Attachment C describes the methodology EPA used to assign SIC codes to point source categories, as well as tables relating point source categories to SIC codes. Some SIC codes fall in more than one point source category. In these cases, the RSEI model results are either distributed among applicable point source categories or counted in each point source category in which they are regulated, depending on the specific SIC code as discussed in Attachment C. ( Double counting of RSEI model results for certain SIC codes accounts for approximately 8.5 percent of the total RSEI risk related result and 1.5 percent of the total EAD TWF hazard score.) Some SIC codes do not fall within any of the existing point source categories. That is, no existing ELGs apply to wastewater discharges from these industries. For these SIC codes, RSEI model results are reported and reviewed at the 4 digit SIC code level. EPA may consider these SIC codes, or combinations of these SIC codes, in identifying new potential point source categories for regulatory action or other initiatives.

Attachment D presents the RSEI model results by point source category ( or 4 digit SIC code for those industries not included in existing point source categories) ranked in order of descending EAD TWF hazard. The remainder of this report focuses on analysis of the EAD TWF hazard scores, which EPA believes best supports the National Strategy. First, as discussed in 3 2 RSEIreport_ 121203. wpd Section 2.3, the EAD TWF hazard analysis is more closely aligned to the methodologies EAD uses in developing effluent limitations. Second, initial review identified facilities that comprise 90 percent of the RSEI risk related results. EAD further investigated the facilities for which the data or model appear to produce discrepancies that would affect the estimated risk. For example, the Kimberly Clark mill in Everett, Washington discharges to the Everett Harbor ( Port Gardner)

Puget Sound, yet received a relatively high RSEI risk related score. The Puget Sound is not a drinking water source, and RSEI does not model consumption of marine species, thus EAD would expect little or no risk associated with this facility. Third, EPA has not yet completed validating the water related RSEI fate and transport calculations. For these reason, EPA will limit the consideration of RSEI risk related results to use as a source of secondary or confirmation information for other analyses.

Table 3 1 lists the six point source categories that comprise 90 percent of the EAD TWF hazard score for the United States and the corresponding result of all five rankings discussed in Section 2.2. As part of the initial screening effort, EAD reviewed the top six point source categories to determine and comment on the underlying factors that drive the EAD TWF hazard scores. Sections 3.1 through 3.6 summarize the initial analysis for each of the six top point source categories.

Note that Table 3 1 also presents the number of facilities that comprise 90 percent of the EAD TWF hazard score for water discharges for each point source category ( or SIC code).

This information provides an indication of the extent to which the EAD TWF hazard score reasonably represents the hazard for the point source category as a whole rather than that of possibly atypical facility( s). For example, the Steam Electric Power Generation point source category is ranked first using the EAD TWF hazard score, yet greater than 90 percent of the EAD TWF hazard score for this point source category is attributed to only one facility. In contrast, the Pulp, Paper, and Paperboard point source category is ranked fourth using the EAD TWF hazard score; 90 percent of the EAD TWF hazard score for this point source category is attributed to 50 facilities. RSEIreport_ 121203. wpd 3 3 Table 3 1 Ranking of Point Source Categories That Comprise 90% of EAD TWF Hazard 40 CFR Part Point Source Category/ SIC Code EAD TWF Hazard Ranking Risk Related Results Ranking TRI Pounds Ranking Hazard Ranking Modeled Hazard Ranking Number of Facilities Contributing 90% of EAD TWF Hazarda 423 Steam Electric Power Generation 1 1 13 1 2 1 414 Organic Chemicals, Plastics and Synthetic Fibers 2 6 2 2 1 4 429 Timber Products Processing 3 36 57 35 42 10 430 Pulp, Paper, and Paperboard 4 12 4 8 10 50 N/ A SIC 5171: Petroleum Bulk Stations and Terminals 5 19 74 28 39 2 419 Petroleum Refining 6 10 6 7 4 16 aThis value represents the number of facilities whose EAD TWF hazard scores, when summed, account for 90% of the hazard for that point source category. 3 4 RSEIreport_ 121203. wpd Table 3 2 provides additional relevant statistics for the top six point source categories, such as the total number of facilities that comprise the point source category ( as reported in the 1997 U. S. Economic Census), the total number of facilities reporting to TRI, the total number of facilities reporting water discharges ( direct or indirect) in TRI, and the number of facilities that are assigned a EAD TWF hazard score associated with those water discharges. This table provides additional insight and information to assist in determining whether that result is characteristic of the entire category, such as the percentage of facilities in each point source category reported water discharges and contribute to the EAD TWF hazard score. For example,

for Steam Electric Power Generation, only 638 of 6,212 facilities ( 10.3 percent) in the 1997 U. S.

Census submitted TRI reports in 2000 ( see Section 2.1 for a description of who must submit a TRI report). Of the 638 Steam Electric Power Generation facilities reported to TRI, 342 ( 53.6 percent) reported water discharges.

Finally, as discussed in Section 2.3, two compounds, PACs and dioxin and dioxinlike compounds, represent less than 0.005 percent of the TRI reported pounds discharged, but approximately 93 percent of the total EAD TWF hazard score as a result of the relatively high EAD TWFs for these compounds. Accordingly, the top six point source categories are comprised of one or more individual facilities reporting discharges of these two compounds. Further investigation is required to determine whether discharges of these two pollutants are isolated,

sitespecific instances or representative of the entire category. In addition, further investigation is required to determine whether EAD TWF hazard scores for these compounds provide a reasonable measure of actual discharges or are instead a phenomenon of TRI reporting based on pollutant detection limits and/ or unrealistically high assumptions regarding the presence or absence of pollutants at concentrations less than the detection limit. Further investigation is also required to evaluate whether the selected chemical ( and associated EAD TWF) assigned to these two chemical compound categories was appropriate on an industry specific basis. RSEIreport_ 121203. wpd 3 5 Table 3 2 Summary Statistics for Point Source Categories That Comprise 90% of EAD TWF Hazard EAD TWF Hazard Rank Point Source Category b Number of Facilities Reporting to 1997 U. S. Economic Census Facilities Reporting to TRI ( 2000) Facilities Reporting Water Release or Transfer in TRI ( 2000) a Number of Water

Discharging Sites Assigned EAD TWF Hazard Number of Facilities Percentage of Facilities Number of Facilities Percentage of Facilities 1 Steam Electric Power Generation 6,212 638 10.3 342 53.6 342 2 Organic Chemicals, Plastics and Synthetic Fibers 1,570 996 63.4 576 57.8 574 3 Timber Products Processing 8,940 373 4.2 102 27.3 87 4 Pulp, Paper, and Paperboard 512 328 64.1 232 70.7 230 5 SIC 5171: Petroleum Bulk Stations and Terminals 9,104 502 5.5 167 33.3 167 6 Petroleum Refining 242 183 75.6 136 74.3 136 aThe number of facilities reporting a direct or indirect water discharge to TRI. This number excludes facilities with no releases, facilities with only air and/ or solids releases, or facilities that are not required to report due to small size or not exceeding reporting thresholds.

bSome SIC codes were included in multiple point source categories. See Section 3.0 and Attachment C for further information regarding EPA's methodology to relate SIC codes to point source categories. None of the SIC codes included in the RSEI analyses for these top 6 point source categories overlap with any other point source categories. 3 6 RSEIreport_ 121203. wpd Section 4.0 presents additional items for further consideration related to the point source category analysis. These results suggest further review of the six top point source categories and their underlying RSEI model results data during the detailed screening level investigation phase.

3.1 Steam Electric Power Generation ( 40 CFR Part 423)

This subsection discusses the RSEI model output for the Steam Electric Power Generation point source category. Section 3.1.1 briefly describes the types of facilities that fall within this point source category. Section 3.1.2 summarizes the results from the RSEI TRI data and discusses the top SIC codes, facilities, and pollutants that contribute to the EAD TWF hazard score.

3.1.1 Industry Description The Steam Electric Power Generation point source category includes establishments primarily engaged in the generation of electric energy for distribution or sale which results primarily from a process utilizing fossil type fuel ( coal, oil, or gas) or nuclear fuel in conjunction with a thermal cycle employing the steam water system as the thermodynamic medium. In the United States, approximately half of all electricity is generated using coal as the energy source.

Steam electric generation is by far the Nation's largest industrial water user with approximately 30 to 40 times the water use of the Nation's second largest industrial water user,

Chemicals and Allied Products. Steam electric units require large amounts of cooling water for steam condensation and efficient thermal operation. Power plants use one of two types of noncontact cooling water: a once through system or a recirculating cooling water system. The majority of electric utilities use recirculating cooling towers. In a once through cooling water system, the cooling water flow rate through the condenser is by far the largest process water flow,

normally equating to about 98 percent of the total process water flow for the entire unit. In recirculating systems, cooling tower blowdown ( a percentage of the recirculated water normally 3 7 RSEIreport_ 121203. wpd equating to 30 to 60 percent of total process water flow) is discharged regularly and additional fresh makeup water is treated and added into the recirculating system to relieve the buildup of solids. Other major wastestreams with effluent limitations include fly ash and bottom ash handling wastewaters, coal pile runoff, and chemical metals cleaning wastes. The wastewaters from nonchemical metal cleaning wastes do not have effluent limitations. Facilities also generate a variety of low volume wastes ( e. g., demineralizer wastes, boiler blowdown, wet scrubber pollution control systems).

Chemicals of concern in non contact cooling water discharges include biocides,

organic chemicals, and trace metals ( chromium and zinc) from biofouling and corrosion control.

Oxidizing biocides such as chlorine and bromine predominate in electric utilities because of cost,

environmental, and efficacy issues. At facilities with once through systems, halogens support rapid biocidal action, which is critical to providing high enough treatment levels to be effective while also complying with a narrow time frame for treatment ( e. g., one to two hours per day as required by NPDES permits). At facilities with recirculating systems, cooling tower blowdown containing biocide is normally sent to a discharge holding pond, where free available chlorine is consumed by other materials or " deactivated" based on retention time. Halogens and other chemicals ( e. g., peracetic acid and glutaraldehyde) may also be used to control Zebra Mussels and Asiatic Clams.

The 1982 ELGs for this point source category, provided at 40 CFR 423, are currently being applied to utility steam electric facilities ( discussed above), and potentially to nonutility steam electric generators and to utility and nonutility combined generators. Nonutility steam electric generators are mainly comprised of cogenerators and renewable fuel burners.

Cogenerators are facilities that primarily produce products other than electricity but generate some or all of their own electricity requirements by operating plants producing both steam and power ( i. e., cogeneration plants). Renewable fuel burners are facilities whose processes utilize alternative fuels such as biomass, municipal solid waste, or wood. Combined generators are facilities that use a type of non steam electric power generation process comprised of a gas turbine followed by a heat recovery stream generator. 3 8 RSEIreport_ 121203. wpd 3.1.2 Summary of RSEI TRI Data The Steam Electric Power Generation Point Source Category applies to facilities in SIC Code 4911, Electric Services. However, within this SIC code, only those facilities that combust coal and/ or oil for the purpose of generating electricity for distribution in commerce are required to report to TRI. The 1997 U. S. Economic Census shows 6,212 establishments engaged in operations under this SIC code. Of these, 342 facilities reported wastewater discharges in the TRI database. EAD TWF hazard scores were assigned to all 342 facilities. Table 3.1 1 provides statistics related to the Steam Electric Power Generation Point Source Category. Table 3 2 in Section 3.1 presents summary statistics for the top six point source categories.

Table 3.1 1 Summary Statistics for the Steam Electric Power Generation Point Source Category ( 40 CFR Part 423)

Rank Point Source Category Number of Facilities Reporting to 1997 U. S. Economic Census Facilities Reporting to TRI ( 2000) Facilities Reporting Water Release or Transfer in TRI ( 2000) a Number of Water Discharging Sites Assigned EAD TWF Hazard Score Number of Facilities Percentage of Facilities Number of Facilities Percentage of Facilities 1 Steam Electric Power Generation 6,212 638 10.3% 342 53.6% 342 In the 2000 TRI database, 41 chemicals were reported as being discharged to water by facilities in this point source category. Of these, 40 chemicals were assigned EAD TWF hazard scores. Discharges of PACs, reported by five facilities, account for 97 percent of the EAD TWF hazard score associated with this category. Table 3.1 2 below lists the chemicals driving the EAD TWF hazard score for the Steam Electric Power Generation Point Source Category. 3 9 RSEIreport_ 121203. wpd Table 3.1 2 Chemical Summary Statistics for the Steam Electric Power Generation Point Source Category ( 40 CFR Part 423)

Chemical Number of Facilities in Category Reporting Discharge to Water SIC Codes in Category Reporting Discharge to Water Percent of Category EAD TWF Hazard Score Polycyclic aromatic compounds 5 4911 97%

The high EAD TWF hazard score associated with this point source category is due primarily to the release of PACs from one facility. In 2000, the Pepco Chalk Point Generating Station ( TRI Facility ID 20608CHLKP25100) in Aquasco, Maryland reported a release to surface water of 9,500 pounds of PACs. This release accounts for 96 percent of the EAD TWF hazard score for the entire point source category. Further investigation of this facility's operations and discharges, as compared to those of other facilities, is necessary to determine the accuracy of this facility's EAD TWF hazard score.

3.2 Organic Chemicals, Plastics, and Synthetic Fibers ( 40 CFR Part 414)

This subsection discusses the RSEI model output for the Organic Chemicals,

Plastics, and Synthetic Fibers ( OCPSF) point source category. Section 3.2.1 briefly describes the types of facilities that fall within this point source category. Section 3.2.2 summarizes the results from the RSEI TRI data and discusses the top SIC codes, facilities, and pollutants that contribute to the EAD TWF hazard score.

3.2.1 Industry Description The OCPSF industry converts wood and fossil fuel products into intermediate or basic finished chemicals. The applicability of the OCPSF point source category is specifically defined as comprised of facilities in the following SIC codes: 3 10 RSEIreport_ 121203. wpd SIC 2821: Plastics materials, synthetic resins, and non vulcanizable elastomers. This industry produces thermoplastic and thermoset resins. Commercially important thermoplastic resins include poyethylene, polyvinyl chloride, polypropylene, and polystyrene. Leading thermosets in sales include phenolic resins, urea resins, and unsaturated polyester resins.

SIC 2823: Cellulosic manmade fibers. Products from this industry are formed by the conversion of cellulose ( an abundant, naturally occurring organic compound) into a soluble derivative, followed by reforming as filaments. Commercially important cellulosic fibers include rayon and cellulose acetate.

SIC 2824: Manmade organic fibers, except cellulosic. This industry produces synthetic fibers through polymerization and subsequent fiber formation of synthetic organic chemicals and refined petroleum products. Nylons, polyesters, polyolefins, and acrylics are some important products of the noncellulosic fiber industry.

SIC 2865: Cyclic organic crudes and intermediates, and organic dyes and pigments. Products from this industry are processed from petroleum, natural gas, and coal. Benzene, toluene, xylene, and naphthalene are a few of the important products produced by the cyclic crudes and intermediates sector. Facilities in this sector are primarily located near the Gulf of Mexico ( where many petroleum based feedstocks are produced) and near downstream industrial users in the Northeast and Midwest.

SIC 2869: Industrial organic chemicals, not elsewhere classified. This is the largest and most diverse sector of the industry. Facilities in this sector are also primarily located near the Gulf of Mexico and in the Northeast and Midwest. Important products of this industry include:

Aliphatic and other acyclic organic chemicals, such as ethylene, butylene, and butadiene;

Acetic, chloroacetic, adipic, formic, oxalic, and tartaric acids and their metallic salts;

Chloral, formaldehyde, and methylamine;

Solvents, such as amyl, butyl, and ethyl alcohols; methanol; amyl, butyl, and ethyl acetates; ethyl ether, ethylene glycol ether, and diethylene glycol ether; acetone; carbon disulfide; and chlorinated solvents, such as carbon tetrachloride, perchloroethylene, and trichloroethylene;

Polyhydric alcohols, such as ethylene glycol, sorbitol, pentaerythritol, and synthetic glycerin; 3 11 RSEIreport_ 121203. wpd

Synthetic perfume and flavoring materials, such as coumarin, methyl salicylate, saccharin, citral, citronellal, synthetic geraniol, ionone, terpineol, and synthetic vanillin;

Rubber processing chemicals, such as accelerators and antioxidants, both cyclic and acyclic;

Plasticizers, both cyclic and acyclic, such as esters of phosphoric acid, phthalic anhydride, adipic acid, lauric acid, oleic acid, sebacic acid, and stearic acid;

Synthetic tanning agents, such as naphthalene sulfonic acid condensates;

Chemical warfare gases; and

Esters, amines, etc., of polyhydric alcohols and fatty and other acids.

These industries are subject to the requirements of the EPA Effluent Guidelines and Standards for OCPSF, 40 CFR Part 414, established in 1987 and revised in 1993. This effluent guideline separates the OCPSF industry into eight product groups and sets separate conventional pollutant ( BOD 5, TSS, pH) limitations for each group. In addition, the regulation establishes separate toxic pollutant ELGs for: direct discharge point sources that use end of pipe biological treatment; direct discharge point sources that do not use end of pipe biological treatment; and indirect discharge point sources.

As a result of the wide range of processes used and products produced, a variety of pollutants are found in the wastewaters of the organic chemical industry, including conventional pollutants, toxic priority pollutants, and nonconventional pollutants. Many of the toxic and nonconventional pollutants found in the wastewaters of this industry are organic compounds produced by the industry for sale, while others are by products of the production processes. Since there is generally more than one reaction pathway available to the reactants of chemical reactions, undesirable by products are often produced resulting in a mixture of unreacted raw materials, products, and by products. The processes used to separate the desired product from this mixture generate additional residues with little or no commercial value and that end up in process wastewater, air emissions, and chemical wastes. The combination of raw materials and production processes used at a facility determine the characteristics of the wastewater generated. 3 12 RSEIreport_ 121203. wpd Potential sources of pollutant discharges in wastewater include equipment and product washing,

lab samples, surplus chemicals, spent/ used solvents, waste oils/ lubricants, seal flushes, scrubber blowdown, cooling water, steam jets, vacuum pumps, and leaks and spills.

3.2.2 Summary of RSEI TRI Data The 1997 U. S. Economic Census shows 1,570 establishments engaged in operations under one of the six SIC codes related to OCPSF. Of these, 576 facilities reported wastewater discharges in the TRI database. EAD TWF hazard scores were assigned to 574 of these 576 facilities. Table 3.2 1 provides statistics related to the OCPSF Point Source Category.

Table 3 2 in Section 3.1 presents summary statistics for the top six point source categories.

Table 3.2 1 Summary Statistics for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category ( 40 CFR Part 414)

Rank Point Source Category Number of Facilities Reporting to 1997 U. S. Economic Census Facilities Reporting to TRI ( 2000) Facilities Reporting Water Release or Transfer in TRI ( 2000) a Number of Water Discharging Sites Assigned EAD TWF Hazard Scores Number of Facilities Percentage of Facilities Number of Facilities Percentage of Facilities 2 Organic chemicals, plastics and synthetic fibers 1,570 996 63.4% 576 57.8% 574 In the 2000 TRI database, 240 chemicals were reported as being discharged to water by facilities in the OCPSF Point Source Category. Of these, 205 chemicals were assigned EAD TWF hazard scores. Dioxin and dioxin like compounds, reported by 16 facilities, accounts for 69 percent of the EAD TWF hazard scores associated with this category. PACs, reported by six facilities, accounts for 27 percent of the EAD TWF hazard.

The OCPSF industry generates wastewater containing organic compounds,

nutrients, metals, and cyanide. Pollutants of concern include volatile organic compounds, semi 3 13 RSEIreport_ 121203. wpd volatile organic compounds, alcohols, PAHs, nitrate and ammonia nitrogen, and metals. Metals include chromium, cobalt, copper, lead, nickel, zinc, and total cyanide. Table 3.2 2 below lists the chemicals driving the EAD TWF hazard scores for OCPSF.

Table 3.2 2 Chemical Summary Statistics for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category ( 40 CFR Part 414)

Chemical Number of Facilities in Category Reporting Discharge to Water SIC Codes in Category Reporting Discharge to Water Percent of Category EAD TWF Hazard Score Dioxin and dioxin like compounds 16 2821, 2869 69%

Polycyclic aromatic compounds 6 2821, 2865, 2869 27%

SIC Code 2869 ( Industrial organic chemicals, not elsewhere classified ( n. e. c.))

accounts for 72 percent of the EAD TWF hazard score for the OCPSF Point Source Category.

This is due primarily to the releases of dioxin like compounds from two facilities. The Dow Chemical Co. Louisiana Division facility ( TRI Facility ID 70765THDWCHIGHW) in Plaquemine,

Louisiana reported a release to surface water of 1.64 pounds of dioxin like compounds. The Dow Chemical Co. Freeport facility ( TRI Facility ID 77541THDWCBUILD) in Freeport, Texas reported a release to surface water of 1.24 pounds of dioxin like compounds. These two chemical releases account for 61 percent of the EAD TWF hazard score for the entire point source category. Further investigation of these facilities' operations and discharges, as compared to those of other facilities, is necessary to determine the accuracy of their EAD TWF hazard scores.

SIC Code 2821 ( Plastics materials, synthetic resins, and non vulcanizable elastomers) accounts for 25 percent of the EAD TWF hazard score for the OCPSF Point Source Category. This is due primarily to the release of PACs from one facility. The Exxon Chemical Baton Rouge Chemical Plant ( TRI Facility ID 70805XXNCH4999S) in Baton Rouge, Louisiana 3 14 RSEIreport_ 121203. wpd reported a release to surface water of 1,801 pounds of PACs. This chemical release accounts for 24 percent of the EAD TWF hazard score for the entire point source category.

3.3 Timber Products Processing ( 40 CFR Part 429)

This subsection discusses the RSEI model output for the Timber Products Processing point source category. Section 3.3.1 briefly describes the types of facilities that fall within this point source category. Section 3.3.2 summarizes the results from the RSEI TRI data and discusses the top SIC codes, facilities, and pollutants that contribute to the EAD TWF hazard score.

3.3.1 Industry Description The timber products processing point source category includes facilities that conduct any timber products processing operations, as well as the production of insulation board where wood is a major raw material. Timber products processing operations covered by the ELGs include barking, veneer manufacturing, plywood production, hardboard production, wood preserving, wet log or roundwood storage, log washing, sawing and planing, finishing, particle board manufacturing, insulation board production, and furniture and fixture production. Listed below are the applicable SIC codes included in the RSEI analysis for this point source category:

2421  Sawmills and planing mills, general;

2435  Hardwood veneer and plywood;

2436  Softwood veneer and plywood;

2491  Wood preserving;

2493  Reconstituted wood products; and

2499  Wood products, n. e. c.

For most industry subcategories, applicable effluent limitations specify either zero discharge or include only the conventional pollutants BOD 5, TSS, and/ or pH. However, the wood preserving subcategories include effluent limitations for oil and grease, COD, and the toxic pollutants phenols, copper, chromium, and/ or arsenic. 3 15 RSEIreport_ 121203. wpd The wood preserving process consists of two basic processing steps: ( 1) reducing the moisture content of the wood by seasoning, kiln drying, steaming, or other processes, and ( 2)

impregnating the wood with chemicals to impart insecticidal, fungicidal, or fire resistant properties to the wood. The major types of preservatives used in wood preserving are creosote,

pentachlorophenol ( PCP), and various formulations of water soluble inorganic chemicals, the most common of which are the salts of copper, chromium, and arsenic ( chromated copper arsenate or CCA). Fire retardants are formulations of salts, the principal ones being borates,

phosphates, and ammonium compounds. Sources of process wastewater include the wood drying processes, condensers ( barometric and surface type), barometric cooling water, and coil condensate. Toxic pollutants in wastewaters from plants that treat with organic preservatives are principally volatile organic solvents such as benzene and toluene, and the PACs of creosote,

including anthracene, pyrene, and phenanthrene, that are contained in the entrained oils. Phenol and phenol derivatives are also found in these wastewaters. PCP is found in wastewaters from plants that use this preservative, and the heavy metals copper, chromium, and arsenic are found in wastewaters from plants that use CCA.

PCP was widely used as a pesticide and wood preservative; however, since 1984,

the purchase and use of PCP has been restricted to certified applicators. It is no longer available to the general public, but is still used industrially as a wood preservative for utility poles, railroad ties, and wharf pilings. Creosote is commonly used to treat wood in building fences, bridges, or railroad tracks, or installing telephone poles.

On February 12, 2002, EPA announced a voluntary decision by industry to move consumer use of treated lumber products away from a variety of pressure treated wood that contains arsenic by December 31, 2003, in favor of new alternative wood preservatives. This transition affects virtually all residential uses of wood treated with CCA, including wood used in play structures, decks, picnic tables, landscaping timbers, residential fencing, patios and walkways/ boardwalks. As of January 1, 2004, EPA will not allow CCA products to be used to treat wood intended for any of these residential uses. Although the Agency has not concluded that there is unreasonable risk to the public from these products, it has been determined that any reduction in exposure to arsenic is desirable. ( See document: Response to Requests to Cancel 3 16 RSEIreport_ 121203. wpd Certain Chromated Copper Arsenate ( CCA) Wood Preservative Products and Amendments to Terminate Certain Uses of other CCA Products , Federal Register: April 9, 2003 ( Volume 68,

Number 68)

3.3.2 Summary of RSEI TRI Data As shown in Table 3.3 1, the 1997 U. S. Economic Census reports 8,940 facilities engaged in the production of timber products in the United States. Of these, 102 facilities reported wastewater discharges in the 2000 TRI database, of which 87 facilities were assigned EAD TWF hazard scores. Table 3 2 in Section 3.1 presents summary statistics for the top 6 point source categories.

Table 3.3 1 Summary Statistics for the Timber Products Processing Point Source Category ( 40 CFR Part 429)

EAD TWF Hazard Rank Point Source Category Number of Facilities Reporting to 1997 U. S. Economic Census Facilities Reporting to TRI ( 2000) Facilities Reporting Water Release or Transfer in TRI ( 2000) a Number of Water Discharging Sites Assigned EAD TWF Hazard Score Number of Facilities Percentage of Facilities Number of Facilities Percentag e of Facilities 3 Timber Products Processing 8,940 373 4.2 102 27.3 87 aThe number of facilities reporting a direct or indirect water discharge to TRI. This number excludes facilities with no releases, facilities with only air and/ or solids releases, or facilities that are not required to report due to small size or not exceeding reporting thresholds.

The 2000 TRI database reports 24 chemicals discharged in this industry. Of these,

only 1 chemical, creosote, was not assigned an EAD TWF hazard score. Dioxin and dioxin like compounds, reported by 25 facilities, accounts for nearly 97 percent of the EAD TWF hazard score associated with this category. PACs, reported by 4 facilities, accounts for approximately 3 percent of the EAD TWF hazard score. Table 3.3 2 summarizes the chemicals that comprise the majority of the EAD TWF hazard. 3 17 RSEIreport_ 121203. wpd Table 3.3 2 Chemical Summary Statistics for the Timber Products Processing Point Source Category ( 40 CFR Part 429)

Chemical Number of Facilities in Category Reporting Discharge to Water SIC Codes in Category Reporting Discharge to Water Percent of Category EAD TWF Hazard Score Dioxins and dioxin like compounds 25 2491, 2499 96.6%

Polycyclic aromatic compounds 4 2491 3.2%

SIC Code 2491 comprises 99.9 percent of the total EAD TWF hazard score for the timber products processing point source category. SIC Code 2491 is comprised of 75 facilities, of which 10 facilities comprise greater than 90 percent of the EAD TWF hazard score for both this SIC code and the entire point source category. The single facility with the greatest EAD TWF hazard score, Koppers Inds. Inc., Granada, MS, comprises 31.1 percent of the total EAD TWF hazard score for the entire point source category. The facility with the second highest EAD TWF hazard score for the category is Electric Mills Wood Preserving, Scooba, MS,

comprising 13.2 percent of the total EAD TWF hazard score. Further investigation of these facilities' operations and discharges, as compared to those of other facilities, is necessary to determine the accuracy of their EAD TWF hazard scores.

3.4 Pulp, Paper, and Paperboard ( 40 CFR Part 430)

This subsection discusses the RSEI model output for the Pulp, Paper, and Paperboard point source category. Section 3.4.1 briefly describes the types of facilities that fall within this point source category. Section 3.4.2 summarizes the results from the RSEI TRI data and discusses the top SIC codes, facilities, and pollutants that contribute to the EAD TWF hazard score. 3 18 RSEIreport_ 121203. wpd 3.4.1 Industry Description Facilities that fall in the pulp, paper, and paperboard point source category manufacture pulp, paper, and paperboard as their major products shipped. These facilities include market pulp mills ( mills that manufacture and ship pulp); integrated mills ( mills that manufacture both pulp and paper or paperboard); and nonintegrated mills ( mills that manufacture paper or paperboard from pulp manufactured by other mills or from secondary fiber). Discharges from pulp, paper, and paperboard manufacturing operations are covered under 40 CFR 430, updated in April 1998. Listed below are the applicable SIC codes included in the RSEI analysis for this point source category:

2611  Pulp mills ( market pulp mills);

2621  Paper mills ( integrated and nonintegrated paper mills); and

2631  Paperboard mills ( integrated and nonintegrated paperboard mills).

Pulp manufacturing operations generate wastewaters with high concentrations of biochemical oxygen demand, chemical oxygen demand, color, and TSS. Pulp bleaching operations generate wastewaters containing these pollutants and also toxic chlorinated pollutants.

The toxic chlorinated pollutants include dioxin and dioxin like compounds ( including furans),

chloroform, and chlorinated phenolic compounds. Compliance with EPA's BAT effluent limitations guidelines promulgated in April 1998 will effectively eliminate the discharge of these toxic chlorinated pollutants. These guidelines apply to about 100 facilities in the pulp, paper, and paperboard manufacturing industry. Pulp mills treat their wastewater with biological treatment,

either the activated sludge process, aerated stabilization basins, or both. Integrated mills will also generate the pollutants listed above during onsite pulp manufacturing, but will also generate wastewaters from paper or paperboard finishing operations, such as surface treatments ( e. g.,

external sizing or coating), and super calendaring, which generate the conventional pollutants BOD 5 and TSS. Nonintegrated mills that deink secondary fibers ( deink mills) typically do not bleach their pulp; however, those that do bleach secondary fiber with hypochlorite may generate wastewaters containing chloroform. An EPA sampling program did not find dioxins in deink mill discharges. 3 19 RSEIreport_ 121203. wpd 3.4.2 Summary of RSEI TRI Data As shown in Table 3.4 1, the 1997 U. S. Economic Census reports 512 facilities engaged in the production of pulp, paper, and paperboard in the United States. Of these, 232 facilities reported wastewater discharges in the 2000 TRI database, of which 230 facilities were assigned EAD TWF hazard scores. Table 3 2 in Section 3.1 presents summary statistics for the top 6 point source categories.

Table 3.4 1 Summary Statistics for the Pulp, Paper, and Paperboard Point Source Category ( 40 CFR Part 430)

EAD TWF Hazard Rank Point Source Category Number of Facilities Reporting to 1997 U. S. Economic Census Facilities Reporting to TRI ( 2000) Facilities Reporting Water Release or Transfer in TRI ( 2000) a Number of Water Discharging Sites Assigned EAD TWF Hazard Score Number of Facilities Percentage of Facilities Number of Facilities Percentag e of Facilities 4 Pulp, Paper, and Paperboard 512 328 64.1 232 70.7 230 aThe number of facilities reporting a direct or indirect water discharge to TRI. This number excludes facilities with no releases, facilities with only air and/ or solids releases, or facilities that are not required to report due to small size or not exceeding reporting thresholds.

The 2000 TRI database reports 49 chemicals discharged in this industry. Of these,

only 2 chemicals, C. I. Direct Blue 218 and sulfuric acid, were not assigned an EAD TWF hazard score. PACs, reported by 35 facilities, account for approximately 53 percent of the EAD TWF hazard score associated with this category. Dioxin and dioxin like compounds, reported by 81 facilities, account for approximately 39 percent of the EAD TWF hazard score. Table 3.4 2 summarizes the chemicals that comprise the majority of the EAD TWF hazard. 3 20 RSEIreport_ 121203. wpd Table 3.4 2 Chemical Summary Statistics for the Pulp, Paper, and Paperboard Point Source Category ( 40 CFR Part 430)

Chemical Number of Facilities in Category Reporting Discharge to Water SIC Codes in Category Reporting Discharge to Water Percent of Category EAD TWF Hazard Polycyclic aromatic compounds 35 2611, 2621, and 2631 52.9%

Dioxins and dioxin like compounds 81 2611, 2621, and 2631 39.1%

SIC Code 2611 comprises 53.6 percent of the total EAD TWF hazard score for the pulp, paper, and paperboard point source category. SIC Code 2621 comprises 21.6 percent of the hazard, and SIC Code 2631 comprises 24.9 percent of the hazard. Fifty of the 232 facilities that reported water discharges compose greater than 90 percent of the EAD TWF hazard score for the entire point source category. The single facility with the greatest EAD TWF hazard result,

Stone Container Corp, Florence, SC, comprises 13.2 percent of the total EAD TWF hazard for the entire point source category.

3.5 SIC Code 5171: Petroleum Bulk Stations and Terminals This subsection discusses the RSEI model output for the Petroleum Bulk Stations and Terminals ( PBST) industry. Section 3.5.1 briefly describes the types of facilities that fall within this SIC code. Section 3.5.2 summarizes the results from the RSEI TRI data and discusses the top facilities and pollutants that contribute to the EAD TWF hazard result.

3.5.1 Industry Description The PBST industry comprises establishments primarily engaged in the wholesale distribution of crude petroleum and petroleum products from bulk liquid storage facilities.

Petroleum products handled by PBSTs include crude oil, gasoline, aviation gasoline, jet fuel ( JP

4), diesel fuel, fuel oil, kerosene, naphtha, and lubricating oils. As specified by SIC Code 5171, 3 21 RSEIreport_ 121203. wpd the bulk liquid storage capacity at these establishments meets or exceeds 10,000 gallons. This industry is not included in any existing point source category.

The main function of PBSTs is to collect, store, and distribute product within the petroleum industry. PBSTs may also perform the following processes: tank cleaning, vehicle and equipment washing and maintenance, hydrostatic testing, product heating, and blending operations ( i. e., adding additives to petroleum products). The product is collected from refineries or preliminary gathering stations and terminals by pipeline, water transport, or rail transport.

PBSTs store the product in above ground storage tanks until distribution by tank trucks to service stations or other industrial and commercial operations.

PBST facilities handle several different types of wastewater, including stormwater,

tank bottom water, washing and maintenance wastewater, hydrostatic testing wastewater,

wastewater from soil and groundwater remediation, and wastewater from pollution prevention practices, including vapor recovery systems. Stormwater runs over the facility yard, roofs, and drives; seeps into floating roof product tanks; accumulates in concrete or soil tank basins designed to collect stormwater and contain accidental spills or contaminated tank bottom water; contacts the vehicle loading/ unloading area; and flows into vehicle and equipment washing and maintenance areas. Tank bottom water is a combination of stormwater that has seeped into the tank, condensed humidity from air pumped into the tank during product removal, condensed humidity from tank breathing that occurs during changes in weather and climate, and entrained product water from the refineries. Washing and maintenance wastewater ( including washing of loading/ unloading racks) originates as fresh water, but becomes wastewater after contact with surfactants and other cleaning products. Fresh water is also used in on site lavatories and for hydrostatic testing. If a site has contaminated soil or groundwater, practices such as soil washing and groundwater pump and treat generate wastewater. Finally, pollution control devices such as vapor recovery systems may generate wastewater while removing pollutants from other media ( e. g., air).

PBST wastewaters generally contain oil and grease, volatile and semivolatile organic compounds, and oxygenated fuel additives. The volume of wastewater requiring 3 22 RSEIreport_ 121203. wpd treatment prior to discharge at PBSTs varies depending on the number of storage tanks at the facility, annual rainfall amounts, and the amount of contaminated groundwater ( if any) being removed.

3.5.2 Summary of RSEI TRI Data The 1997 U. S. Economic Census shows 9,104 establishments engaged in operations under SIC Code 5171. Of these, 167 facilities reported wastewater discharges in the TRI database. EAD TWF hazard scores were assigned to all 167 facilities. Table 3.5 1 provides statistics related to the PBST industry. Table 3 2 in Section 3.1 presents summary statistics for the top six point source categories.

Table 3.5 1 Summary Statistics for SIC Code 5171: Petroleum Bulk Stations and Terminals Rank Point Source Category Number of Facilities Reporting to 1997 U. S. Economic Census Facilities Reporting to TRI ( 2000) Facilities Reporting Water Release or Transfer in TRI ( 2000) a Number of Water Discharging Sites Assigned EAD TWF Hazard Score Number of Facilities Percentage of Facilities Number of Facilities Percentage of Facilities 5 SIC 5171: Petroleum Bulk Stations and Terminals 9,104 502 5.5% 167 33.3% 167 In the 2000 TRI database, 23 chemicals were reported as being discharged to water by facilities in the PBST industry. All 23 chemicals were assigned EAD TWF hazard scores. Discharges of PACs, reported by six facilities, account for 99.99 percent of the EAD TWF hazard score associated with this category.

Table 3.5 2 below lists the chemicals driving the EAD TWF hazard score for the PBST industry. 3 23 RSEIreport_ 121203. wpd Table 3.5 2 Chemical Summary Statistics for SIC Code 5171: Petroleum Bulk Stations and Terminals Chemical Number of Facilities in Category Reporting Discharge to Water SIC Codes in Category Reporting Discharge to Water Percent of Category EAD TWF Hazard Polycyclic aromatic compounds 6 5171 99.991%

The high EAD TWF hazard score associated with this industry is due primarily to the release of PACs from two facilities. In 2000, the Global Revco Terminal facility ( TRI Facility ID 01843BFGDRONEJA) in Revere, Massachusetts reported a release to surface water of 370 pounds of PACs. This release accounts for 53 percent of the EAD TWF hazard score for the entire industry. The Chelsea Sandwich facility ( TRI Facility ID 02150CHLSS11BRO) in Chelsea,

Massachusetts reported a release to surface water of 293 pounds of PACs. This release accounts for 42 percent of the EAD TWF hazard score for the entire industry. Further investigation of these facilities' operations and discharges, as compared to those of other facilities, is necessary to determine the accuracy of their EAD TWF hazard scores.

3.6 Petroleum Refining ( 40 CFR Part 419)

This subsection discusses the RSEI model output for the Petroleum Refining point source category. Section 3.6.1 briefly describes the types of facilities that fall within this point source category. Section 3.6.2 summarizes the results from the RSEI TRI data and discusses the top SIC codes, facilities, and pollutants that contribute to the EAD TWF hazard score.

3.6.1 Industry Description The Petroleum Refining point source category comprises establishments that primarily manufacture fuels ( motor gasoline, diesel and distillate fuel oil, liquefied petroleum gas,

jet fuel, residual fuel oil, and kerosene), finished nonfuel products ( solvents, lubricating oils, 3 24 RSEIreport_ 121203. wpd greases, petroleum wax, petroleum jelly, asphalt, and coke), and chemical industry feedstocks ( naphtha, methane, ethane, propane, butane, ethylene, propylene, butylenes, butadiene, benzene,

toluene, and xylene) from the physical, thermal, and chemical separation of crude oil into its major distillation fractions which are then further processed through a series of separation and conversion steps into finished petroleum products. In general, the major petroleum refinery products can be classified into one of four groups, based on physical characteristics:

Low Boiling Products. These products include compounds that are gas at ambient temperatures and pressures: methane, ethane, propane, butane, and corresponding olefins.

Gasoline. Gasolines are mixtures of hydrocarbons having typical boiling ranges from 38 to 205  C. Gasoline components include light straight run gasoline or isomerate,

catalytic reformate, catalytically cracked gasoline, hydrocracked gasoline, polymer gasoline,

alkylate,   butane, and additives such as methyl tertiary butyl ether ( MTBE), ethyl tertiary butyl ether ( ETBE), tertiary amyl methyl either ( TAME), and ethanol.

Distillate Fuels. Distillate fuels include jet or turbine fuels, diesel fuels, and heating oils, all of which are blended from a variety of refinery streams to meet specifications.

Diesel fuels include automotive diesel fuels and railroad diesel fuels.

Residual Fuel Oils. Residual fuel oil consists of the heaviest fractions of the crude oil, which is generally the fractionating tower bottoms from vacuum distillation. Residual fuel oil is generally considered a byproduct of petroleum refineries.

Petroleum refinery processes can be grouped into three categories: the initial crude preparation and distillation operations; downstream separation, combination, and reshaping operations; and supporting operations ( e. g., wastewater treatment, sulfur recovery, and heat exchanger cleaning). Four types of wastewater are produced: surface water runoff, cooling water, process water, and sanitary wastewater. Surface water runoff is intermittent and contains constituents from spills to the surface, leaks in equipment, and any materials that may have 3 25 RSEIreport_ 121203. wpd collected in drains. Runoff surface water also includes water coming from crude and product storage tank roof drains. Cooling water is typically does not come into direct contact with process oil streams, but may contain chemical additives and antifouling biocides. Process wastewaters are generated from several of the petroleum refining processes, including desalting crude oil, steam stripping operations, pump gland cooling, product refractionator reflux drum drains, and boiler blowdown. Because process water often comes into direct contact with oil, it is usually highly contaminated. Process wastewater generated from refineries typically contains hydrogen sulfide, ammonia, oil and grease, suspended solids, chemical oxygen demand,

biochemical oxygen demand, and organic chemicals. Process wastewater from desalting operations may also contain low levels of metals.

3.6.2 Summary of RSEI TRI Data The Petroleum Refining Point Source Category applies to facilities in SIC Code 2911, Petroleum Refining. The 1997 U. S. Economic Census shows 242 establishments engaged in operations under this SIC code. Of these, 136 facilities reported wastewater discharges in the TRI database. EAD TWF hazard scores were assigned to all 136 facilities. Table 3.6 1 provides statistics related to the Petroleum Refining Point Source Category. Table 3 2 in Section 3.1 presents summary statistics for the top six point source categories.

Table 3.6 1 Summary Statistics for the Petroleum Refining Point Source Category ( 40 CFR Part 419)

Rank Point Source Category Number of Facilities Reporting to 1997 U. S. Economic Census Facilities Reporting to TRI ( 2000) Facilities Reporting Water Release or Transfer in TRI ( 2000) a Number of Water Discharging Sites Assigned EAD TWF Hazard Score Number of Facilities Percentage of Facilities Number of Facilities Percentage of Facilities 6 Petroleum Refining 242 183 75.6% 136 74.3% 136 3 26 RSEIreport_ 121203. wpd In the 2000 TRI database, 82 chemicals were reported as being discharged to water by facilities in this point source category. Of these, 78 chemicals were assigned EAD TWF hazard scores. Discharges of PACs, reported by 19 facilities, account for 88 percent of the EAD TWF hazard score associated with this category. Discharges of dioxin and dioxin like compounds, reported by 17 facilities, account for seven percent of the EAD TWF hazard score.

Dioxins and furans are generated in some catalytic reformers, and have been found in in plant streams at the part per thousand level. These compounds may be present in air pollution control scrubber wastewaters from catalyst regeneration.

Table 3.6 2 below lists the chemicals driving th EAD TWF hazard for the Petroleum Refining Point Source Category.

Table 3.6 2 Chemical Summary Statistics for the Petroleum Refining Point Source Category ( 40 CFR Part 419)

Chemical Number of Facilities in Category Reporting Discharge to Water SIC Codes in Category Reporting Discharge to Water Percent of Category EAD TWF Hazard Polycyclic aromatic compounds 19 2911 88%

Dioxin and dioxin like compounds 17 2911 7%

Unlike some of the other point source categories evaluated, the petroleum refining industry does not have a small number of facilities that are largely responsible for the category's high EAD TWF hazard score. Instead, there are 16 facilities that comprise 90 percent of the category EAD TWF hazard score. At the top of the list is the Lyondell Citgo Refining facility ( TRI Facility ID 77017LYNDL12000) in Houston, Texas, which reported a discharge of 2,380 pounds of PACs to a publicly owned treatment works ( POTW); following POTW removals, the discharge to surface water is estimated to be 175 pounds. This discharge accounts for 33 percent of the EAD TWF hazard score for the entire point source category. The Valero Refining Texas facility ( TRI Facility ID 77592TXSCTLOOP1) in Texas City, Texas reported a direct discharge of 64 pounds of PACs, accounting for 12 percent of the EAD TWF hazard. The Tosco San 3 27 RSEIreport_ 121203. wpd Francisco refinery ( TRI Facility ID 94572NCLSNOLDHI) in Rodeo, California reported a direct discharge of 57 pounds of PACs, accounting for 11 percent of the EAD TWF hazard.

3.7 References 4. U. S. EPA. Preliminary Data Summary for the Steam Electric Point Source Category. Office of Water, Engineering and Analysis Division. EPA 821 Z 96 010. April 1996.

5. Email With Attached Presentation from Carey Johnston with EPA to Deborah Bartram with ERG. Answers to Questions from EPA about Cooling Tower Biocides. May 29, 2003.

6. U. S. EPA. Profile of the Organic Chemicals Industry. Office of Compliance Sector Notebook. EPA 310 R 95 012. September 1995.

7. U. S. EPA. Development Document for Effluent Limitations Guideline New Source Performance Standards for the Organic Chemicals and the Plastics and Synthetic Fibers Point Source Category. Vol. 1. Washington, DC. October 1987.

8. Chemical Manufacturer's Association. Designing Pollution Prevention into the Process: Research, Development and Engineering, Washington, D. C. 1993.

9. U. S. EPA. Development Document for Effluent Limitations Guidelines and Standards for the Timber Products. Section I  Executive Summary. EPA 440/ 1 81/ 023. January 1981.

10. U. S. EPA. EPA Newsroom: Whitman Announces Transition from Consumer Use of Treated Wood Containing Arsenic. February 12, 2002.

11. U. S. EPA. Pesticides: Topical & Chemical Fact Sheets. Manufacturers to Use New Wood Preservatives, Replacing Most Residential Uses of CCA. February 12, 2002.

12. ATSDR ( Agency for Toxic Substances and Disease Registry). ToxFAQs for CREOSOTE. CAS# Wood Creosote 8021 39 4, Coal Tar Creosote 8001 58 9, Coal Tar 8007 45 2. September 2002.

13. ATSDR ( Agency for Toxic Substances and Disease Registry). ToxFAQs for Pentachlorophenol. CAS# 87 86 5. September 2001.

14. U. S. EPA. Profile of the Lumber and Wood Products Industry. EPA Office of Compliance Sector Notebook Project. EPA 310 R 95 006. September 1995. 3 28 RSEIreport_ 121203. wpd 15. U. S. EPA. Proposed Technical Development Document for the Pulp, Paper, and Paperboard Category Effluent Limitations Guidelines, Pretreatment Standards, and New Source Performance Standards. Office of Science and Technology, Engineering and Analysis Division. October 29, 1993.

16. U. S. EPA. EPCRA Section 313 Industry Guidance, Petroleum Terminals and Bulk Storage Facilities. Office of Pollution Prevention and Toxics ( EPA 745 B 00 002). Washington, DC. February 2000.

17. U. S. EPA. AP 42  Compilation of Emission Factors. Office of Air Quality Planning and Standards. January 1995.

18. American Petroleum Institute. Impacts of Petroleum Product Marketing Terminals on the Aquatic Environment. Health and Environmental Sciences Department. Publication Number 4673, April 1999.

19. American Petroleum Institute. Design, Construction, Operation, Maintenance, and Inspection of Terminal & Tank Facilities. API Standard 2610. Washington, DC, July 1994.

20. American Petroleum Institute. Minimization, Handling, Treatment, and Disposal of Petroleum Products Terminal Wastewaters. Health and Environmental Sciences Department and Manufacturing, Distribution, and Marketing Department. Publication Number 4602, August 1994.

21. ERG. Draft Profile of the Petroleum Bulk Stations and Terminals ( PBST) Industry. March 3, 2003.

22. U. S. EPA. Profile of the Petroleum Refining Industry. Office of Compliance Sector Notebook. EPA/ 310 R 95 013. September 1995. 4 1 RSEIreport_ 121203. wpd 4.0 ITEMS FOR FURTHER CONSIDERATION This section discusses items that EAD intends to consider during a more detailed review phase to ensure that RSEI outputs are correctly interpreted and incorporated into the National Strategy.

Based on the results presented in Section 3.0, EAD believes, for some point source categories, the EAD TWF hazard score analyses identify specific facilities that contribute hazard,

but may not return results that indicate potential hazard representative of points source categories as a whole. To better correlate results with the National Strategy, EAD may consider developing revised EAD TWF hazard rankings after removing facilities that drive risk related results (" atypical" facility discharges, such as those pollutants reported by only one facility, or pollutant discharges that are significantly different than those reported by other facilities in the SIC code).

This analysis would occur as a component of EPA's second level screening of industries for further investigation.

Further investigation is required to determine whether EAD TWF hazard results for PACs and dioxin and dioxin like compounds, which represent approximately 93 percent of the total EAD TWF hazard score, represent a reasonable measure of actual discharges or are instead a phenomenon of TRI reporting based on pollutant detection limits and/ or unrealistically high assumptions regarding the presence or absence of pollutants at concentrations less than the detection limit. EAD will also further evaluate whether the representative chemical ( and associated EAD TWF) assigned to these two chemical compound categories ( PACs, dioxin and dioxin like compounds) was appropriate on an industry specific basis. ( See Attachment B for further information regarding the selection of EAD TWFs for TRI chemical compound categories.) For example, use of the EAD TWF for benzo( a) pyrene to represent PACs may be appropriate for the Iron and Steel point source category, which is known to generate and discharge benzo( a) pyrene, but may not be the most appropriate compound to represent PACs for other point source categories. 4 2 RSEIreport_ 121203. wpd EPA has not yet completed validating the water related RSEI calculations and results. Most RSEI calculations are related to determination of risk related scores, which are not the focus of this report; however, the data sources ( 2000 TRI) and some calculations also relate to determination of EAD TWF hazard. Specifically, in addition to the facility specific activities discussed in Sections 4.2 through 4.7, EAD has identified the following model validation activities that it may consider:

Further investigate the basis for the chemical removal efficiencies used in RSEI for discharges to POTWs.

Consider developing EAD TWFs for the remaining 56 chemicals with reported direct or indirect discharges to surface water in the 2000 TRI, prioritized based on RSEI risk related results.

Validate differences in reported water releases ( pollutants and loadings) for sites based on production processes and capacities.

Validate reported water releases based on comparison to other data sources such as EPA's NPDES permit compliance system.

Review reported primary SIC code for relevance to water releases ( see further discussion below).

During initial review of the RSEI model results, EPA identified some outlier values. In investigating these cases, EPA determined that the following modification were appropriate for certain SIC code assignments ( six facilities) and pollutants ( 1 facility) as listed below:

Dow Chemical Co., Freeport, TX ( 77541THDWCBUILD); Dow Chemical Co, Plaquemine, LA ( 70765THDWCHIGHW); and PPG Inds Inc, Lake Charles, LA ( 70669PPGNDCOLUM) Primary SIC code reported for TRI for these three facilities was 2812 ( Alkalies and Chlorine); however, a search of the EPA web tool OTIS ( http:// www. epa. gov/ idea/ otis/ mm_ idea_ query. html) identified SIC code 2869 ( Industrial organic chemicals, n. e. c.) as the primary SIC code for the facilities' NPDES permits. 4 3 RSEIreport_ 121203. wpd

ExxonMobil Chemical Co Olefins Plant, Baytown, TX ( 77522XXNCH3525D) Primary SIC code reported for TRI was 2822 ( Synthetic rubber ( vulcanizable elastomers)); however, a search of OTIS identified SIC code 2869 as the primary SIC code for the facility's NPDES permit.

Exxon Chemical, Baton Rouge, LA ( 70805XXNCH4999S) Primary SIC code reported for TRI was 2869; however, a search of OTIS identified SIC code 2821 ( Plastics materials, synthetic resins, and non vulcanizable elastomers) as the primary SIC code for the facility's NPDES permit.

Kimberly Clark Tissue Co, Everett, WA ( 98201SCTTP2600F) Primary SIC code reported for TRI was 2611 ( Pulp mills); however, EAD's knowledge of this facility based on its recent investigation of this industry identified SIC code 2621 ( Paper mills) as the more appropriate primary SIC code.

Metallurgical Products, West Chester, PA ( 19381MTLLR810LI) This facility reported water discharges of elemental phosphorus. Contact with facility personnel indicated the actual discharge was phosphates or phosphoric acid and not elemental phosphorus.

These modifications indicate that the primary SIC code reported in 2000 TRI may not be the most appropriate primary SIC code for water discharges, particularly at complex facilities with multiple processes. EAD expects that additional modifications to TRI reported SIC codes and pollutants may be identified during second level screening investigation of the top point source categories. A 1 RSEIreport_ 121203. wpd ATTACHMENT A TRI OVERVIEW The purpose of this section is to provide a summary of the Toxic Release Inventory ( TRI), specifically focusing on how the data are reported. This summary does not provide all details about the TRI program; rather it is intended to give the reader a basic understanding that is needed perform an analysis of TRI data using the Risk Screening Environmental Indicators ( RSEI) software program, specifically for comparative risks associated with releases to water. More detailed information can be found at EPA's TRI homepage:

http:// www. epa. gov/ tri/.

General TRI Background:

TRI is the common name for Section 313 of the Emergency Planning and Community Right to Know Act ( EPCRA). Each year, facilities that meet certain thresholds must report their releases and other waste management activities ( quantities recycled, collected and combusted for energy recovery, treated for destruction, or disposed) for listed toxic chemicals. A separate report must be filed for each chemical that exceeds a threshold. The TRI list of chemicals for reporting year 2000 ( the most recent data available) includes more than 600 chemicals and chemical categories.

TRI reports are sent to EPA by July 1 of each year for information pertaining to the previous calendar year ( for example, reports due on July 1, 2003 will include releases from January 1, 2002 through December 31, 2002). EPA collates the TRI reports and performs a series of quality assurance checks before finalizing the TRI database ( typically approximately 90,000 individual reports from 20,000 different facilities are submitted each year). Once data are verified, EPA's RSEI team uses the data to compile the most recent RSEI database. A 2 RSEIreport_ 121203. wpd Who Must Report:

There are three criteria that each facility must consider every year. If, and only if,

a facility meets all three criteria, it must submit a TRI report for that reporting year. The criteria are:

1. SIC code determination: Facilities in Standard Industrial Classification ( SIC) primary codes 20 through 39, seven additional SIC codes outside this range, and federal facilities must submit a TRI report. There are many situations where a facility has multiple on site establishments, some within the TRI reporting universe, some outside the universe. In these situations, the primary SIC code, which is based on the facility's primary activity as reported by the submitter, determines TRI reporting. The RSEI analyses that are presented throughout this document have been filtered to only assign data to the facility identified primary SIC code.

2. Number of Employees: Facilities must have 10 or more full time employees or their equivalent. EPA defines a " full time equivalent" as a person that works 2,000 hours in the reporting year. Therefore, this criterion is met if the facility employs any number of workers that log a total of 20,000 hours in the reporting year ( there are several exceptions and special circumstances that are well defined in the TRI reporting instructions).

3. Thresholds: If the facility is in a covered SIC code and has 10 or more fulltime employee equivalents it must conduct an activity threshold analysis for every chemical and chemical category on the current TRI list. The facility must determine whether it manufactures, processes, OR otherwise uses each chemical at or above the appropriate activity threshold. All TRI thresholds are based on mass, not concentration. Also, it is very important to recognize that facilities must report any amount released to any media regardless of thresholds. Therefore, many facilities submit TRI reports that show zero or very small releases.

Essentially, there are two types of thresholds. The first applies to " non PBT chemicals". The non PBT threshold determinations for the three activity categories are mutually exclusive. That is, the facility must conduct a separate threshold determination for each activity category and if any threshold is exceeded, all releases must be reported. The non PBT thresholds A 3 RSEIreport_ 121203. wpd are 25,000 pounds for manufacturing; 25,000 pounds for processing; and 10,000 pounds for other use.

The second type of threshold applies to PBT chemicals. One primary difference in TRI reporting for PBTs is that there is one combined threshold for all three activities

manufacturing, processing, and other use are NOT mutually exclusive. Therefore, the facility must sum the amounts associated with these activities. If this total amount meets the threshold associated with the specific PBT chemical, a TRI Form R must be submitted. The reporting thresholds for the 20 PBT chemicals are either 10 pounds or 100 pounds ( or 0.1 grams for dioxins/ furans.

Changes to TRI Reporting Over Time Any trend analysis using TRI data in general or RSEI results should consider the primary changes that have occurred over the past several years. The primary changes affecting RSEI analyses are briefly presented here:

Chemical Expansion: The original TRI list included approximately 300 chemicals. This list was approximately doubled in 1995. Additionally, each year EPA may adjust the list in response to petitions to add and remove specific chemicals ( typically one or two per year).

Industry Expansion: The original industries covered in TRI only included those in the manufacturing sector ( SIC codes 20 through 39). Federal Facilities were included via an executive order in 1994 ( regardless of associated SIC codes), and seven additional industries were added in 1997. The seven additional industries include:

  SIC codes 10  Metal Mining ( except 1011, 1081, and 1094),

  SIC codes 12  Coal Mining ( except 1241),

  SIC codes 49  Electric, Gas, and Sanitary Services ( limited to 4911, 4931, 4939, and 4953 and limited to those facilities that combust coal and/ or oil for the purpose of generating electricity for distribution in commerce), A 4 RSEIreport_ 121203. wpd   SIC code 5169  Chemical and Allied Products, n. e. c.,

  SIC code 5171  Petroleum Terminals and Bulk Stations, and   SIC code 7389  Business Services, n. e. c.

The PBT and Lead Rules: Prior to reporting year 2000, the three activity thresholds for all TRI chemicals were identical: 25,000 pounds for manufacturing; 25,0000 pounds for processing; and 10,000 pounds for other use. However, as of reporting year 2000, EPA designated 18 chemicals as PBTs. The thresholds for PBTs were lowered to either 10 pounds for " highly persistent" biocaccumulative, toxic chemicals or 100 pounds for other PBTs ( dioxins/ furans are the exception where the threshold is 0.1 grams). Lead and lead compounds were not designated as PBTs until reporting year 2001.

Metals and Metal Compounds TRI and RSEI have special requirements and methods of analysis for metals. The factors associated with TRI reporting for metals that are most important for analysis of RSEI results are presented below.

TRI Reporting for Metals vs. Metal Compounds: In most cases, the TRI list of chemicals includes a listing for the elemental metal and a separate listing for all compounds of the metal ( e. g., nickel and nickel compounds). In general, facilities are required to conduct separate threshold analyses and then submit TRI reports for the parent metal and the metal compound or one combined report if both thresholds are met.

Metal Compounds  Reporting the Mass of the Elemental Metal: When conducting a threshold analysis for metal compounds, the facility must estimate and sum the mass of all compounds manufactured, processed, or otherwise used. However, if a threshold is exceeded, only the mass of the elemental metal that is released is reported. For example, if a facility releases 100 pound of lead oxide ( PbO), it should report the associated mass of elemental lead ( 93 pounds), not the entire 100 pounds of lead oxide.

Mercury and Lead: Mercury and mercury compounds have been on the TRI list for several years. However, until reporting year 2000, the mercury thresholds were those for non PBT chemicals ( 25,000 pounds or 10,000 pounds). Therefore, it is expected that many facilities may have reported A 5 RSEIreport_ 121203. wpd these chemicals for the first time in 2000 when the threshold dropped to 10 pounds. Any trend analysis should consider this fact. Lead and lead compounds have also been TRI chemicals for several years; however, they were not considered PBT chemicals until reporting year 2001.

Combustion of Fossil Fuels: All fossil fuels contain trace amounts of most TRI metals and/ or metal compounds. Because these chemicals are present in low concentrations in the fuel, it requires thousands of tons of coal, oil, wood, and even natural gas to meet a reporting threshold. Most facilities with reasonably sized combustion units easily burn enough fuel to meet a threshold. However, while virtually every electricity generating power plant and most facilities with large boilers and industrial furnaces ( BIFs) report for nearly every TRI metal, many smaller facilities will not, or they may only report for some TRI metals.

Aluminum, Zinc, and Vanadium Fume and Dust Qualifier: Historically, TRI has designated these three metals with a " fume and dust qualifier". Essentially, this qualifier means that only the amount of these metals that is manufactured, processed, or otherwise used as a fume and/ or dust should be included in threshold and release estimates. Therefore, facilities may exceed a threshold, generate significant amounts of non dust releases, but will ( correctly) not report these releases. Beginning with reporting year 2000, the TRI reporting requirements for vanadium were modified to remove the fume and dust qualifier.

Vanadium Compounds: Prior to reporting year 2000, vanadium metal was a TRI chemical. At the same time the fume and dust qualifier was removed from vanadium, all physical forms of vanadium compounds were added to the TRI list.

Other Factors Affecting RSEI Result Analyses There are several factors associated with TRI reporting that could cause confusion when analyzing RSEI results. The primary factors that have been that could affect the RSEI results are discussed below.

Range Reporting: TRI provides the option for facilities to report releases as specific numbers OR as ranges, if appropriate. Specific estimates are encouraged if data are available to ensure the accuracy; however, EPA allows facilities to report releases in the following ranges: 1 to 10 pounds, 11 to 499 pounds, or 500 to 999 pounds. Range reporting is not permitted for PBT chemicals. The RSEI model uses the mid point of each range. 1TRI 2000 Executive Summary. http:// www. epa. gov/ tri.

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Detection Limits: Companies are required to use their judgement and report the most accurate information. The TRI program does not specify the use ( or non use) of detection limits. TRI guidance states that if a facility reasonably expects a chemical to be present in waste streams, the facility should assume half of the detection limit for estimates. If the facility does not reasonably expect the chemical to be present, they can assume a concentration of zero.

The De Minimis Exemption: TRI includes an exemption such that in general chemicals in any process or waste stream below 1% ( by mass) for non carcinogens or below 0.1% for carcinogens ( as defined by OSHA) should be excluded from both threshold and release estimates. The de minimis exemption is not applicable to the manufacture of any TRI chemical nor to PBT chemicals.

Alternate Certification Statement ( Form A): Starting in 1997, EPA instituted an optional second type of TRI Report, commonly called the Form A. With implementation of Form A, facilities may now certify that the total quantity of a specific chemical released and managed as waste is less than 500 pounds without quantifying estimates to any media. A significant number of Form A's are submitted by every industry each year; Form A's cannot be submitted for PBT chemicals. According to the 2000 Public Data Release 8, 456 Form A's were filed. Initial analysis of RSEI indicates that, because no release quantity can be assigned to any media, RSEI ignores all Form A submissions.

Test Data: EPCRA mandates that facilities use the " best readily available information" to conduct threshold AND release estimates for TRI reporting. It does NOT require any testing to be conducted in any circumstances. However, if testing has been conducted for any other purpose, the facility is required to consider using the results if they are appropriate.

Data Quality EPA's TRI Division has always been concerned with the quality of information that is released in the public database. Therefore, an overall quality assurance program has been instituted. In 2000, 23,834 facilities submitted a total of 91,513 forms1. While the majority of the data appear to provide reasonable pollutant information, EPA acknowledges that significant A 7 RSEIreport_ 121203. wpd errors associated with individual estimates do exist. The primary aspects of TRI's data quality program and the uncertainties that affect RSEI runs are briefly presented below.

Internal Checks of Submitted Reports: EPA headquarters collects all reports, either electronic submissions or manual submissions, and conducts a series of internal quality control checks before any information is made available to the public. All data for every report is entered into an electronic master database. Written submissions are hand entered by two clerical personnel and cross checked for transcription errors. After data are entered, each data element is electronically checked to identify omissions and information that has been recorded in an incorrect field. Potential errors are identified and mailings are sent to submitters requesting verification of the information.

Increaser/ Decreaser Checks: Facilities that show significant increases or decreases from one year to the next are identified and an EPA or contractor scientist contacts the facilities to verify the estimates in question.

Reality Checks: In addition to the increaser/ decreaser effort, EPA scientists review many TRI reports and conduct a reality check, focusing on anomalies in submitted data.

Regional QA/ QC Efforts: Individual states and regions also conduct quality assurance checks. Many regional TRI coordinators work closely with facilities and know specific issues associated with individual companies. These coordinators often review individual TRI submissions and then personally contact facilities with questions.

Revisions: If EPA or a facility identifies any errors, a revised report may be submitted. Revisions that are received prior to the data freeze are incorporated into the national database and made available to the public ( and RSEI programers) with the yearly Public Data Release. Revisions that are received after the data freeze are not incorporated until the following reporting year.

Site Survey Program: EPA conducted site visits to 165 facilities in several industry sectors to assess the quality of facility estimates. EPA observed that most facility estimates were within 10% of surveyor estimates based on site surveyor's assessments of information that was " readily available". There were also many circumstances when more significant errors were identified. The accuracy varied significantly with the industry sector that was investigated. No surveys have been conducted since 1998. A 8 RSEIreport_ 121203. wpd It is important to note that the site survey program analysis only considered the " best readily available information". When no test data or emission factors were available the uncertainty in actual releases is expected to increase significantly. The site surveyors did not conduct additional testing.

Sector vs. Facility Accuracy: The accuracy of estimates ( the actual pounds released to specific media) does not necessarily coincide with appropriate reporting. In reality, a facility may correctly report for TRI and in good faith may provide the best estimate of releases possible; however, the uncertainty in the estimate may be extremely high. Results from TRI's Site Survey Program can be considered to show that a microscopic evaluation of individual estimates can result in significant uncertainties. However, survey results indicate that as many facilities over report, as those that under report. Therefore, a macroscopic evaluation of entire sectors may show considerably less uncertainty and may show more reasonable results. 1EAD Toxics Database developed by VERSAR, version developed in 2001.

B 1 RSEIreport_ 121203. wpd ATTACHMENT B CALCULATION OF EAD TWF HAZARD EAD ranked the RSEI results using EAD TWFs in place of RSEI toxic weights.

This value, the EAD TWF hazard, is calculated for TRI chemicals that have EAD TWFs developed by EAD's Environmental Assessment Branch. EAD TWF hazard scores are calculated by multiplying total TRI pounds ( see Section 2.2) by the EAD TWF of the chemical. For indirect discharges, the reported pounds transferred off site to POTWs are adjusted to account for treatment at a POTW.

The TRI list includes 612 chemicals and compound categories. Using a table of EAD TWFs1, EAD was able to identify matching entries for 580 of these chemicals and assigned EAD TWFs accordingly. Of the 329 TRI chemicals and compound categories with reported direct or indirect discharges to surface waters, EAD TWFs have not been developed for 55 of these chemicals. See Section 2.3 for further information regarding the development of EAD TWFs.

For the 30 TRI chemical compound categories, EPA could not use CAS Numbers to identify matching compounds to assign EAD TWFs. Table B 1 lists the 30 TRI chemical compound categories for which EAD identified representative chemicals using means other than CAS Number, and provides the rationale for this assignment. This table provides the name and CAS Number of the TRI chemical compound category, the chemical used as the basis of RSEI toxicity data, the name and CAS number of the chemical used to select an EAD TWF, and the EAD TWF ( where available). B 2 RSEIreport_ 121203. wpd Table B 1 Specific Chemicals and Toxic Weighting Factors Selected to Represent TRI Chemical Compound Categories TRI Category Number TRI Chemical Compound Category RSEI Toxicity Based On Representative EAD TWF Chemical EAD TWF Chemical CAS NO EAD TWF Rationale for Assignment N010 Antimony compounds Antimony Antimony 7440 36 0 4.8 x 10 3 1 N020 Arsenic compounds Arsenic Arsenic 7440 38 2 3.47 1 N040 Barium compounds Barium Barium 7440 39 3 2.0 x 10 3 1 N050 Beryllium compounds Beryllium Beryllium 7440 41 7 1.06 1 N078 Cadmium compounds Cadmium Cadmium 7440 43 9 2.61 1 N084 Chlorophenols Pentachlorophenol Pentachlorophenol 87 86 5 0.44 2 N090 Chromium compounds Chromium hexavalent Chromium hexavalent 18540 29 9 0.51 2 N096 Cobalt compounds Cobalt Cobalt 7440 48 4 0.11 1 N100 Copper compounds Copper Copper 7440 50 8 0.63 1 N106 Cyanide compounds Copper cyanide Copper cyanide 544 92 3 2.6 x 10 3 2 N120 Diisocyanates None ( no toxicity data assigned) None ( no EAD TWF chemical identified) 101 68 8 Not available N150 Dioxin and dioxin like compounds None ( no toxicity data assigned) Hexachlorodibenzofuran 1,2,3,6,7,8 57117 44 9 6.7 x 106 3 N171 Ethylenebisdithiocar bamic acid, salts and esters Metiram Metiram 9006 42 2 8.7 x 10 3 2 N230 Glycol ethers Methoxyethanol, 2 Methoxyethanol, 2 109 86 4 1.1 x 10 4 2 N420 Lead compounds Lead Lead 7439 92 1 2.24 1 N450 Manganese compounds Manganese Manganese 7439 96 5 0.070 1 N458 Mercury compounds Mercury Mercury 7439 97 6 117.08 1 N495 Nickel compounds Nickel Nickel 7440 02 0 0.11 1 N503 Nicotine and salts None ( no toxicity data assigned) None ( no EAD TWF chemical identified) 54 11 5 Not available N511 Nitrate compounds Nitrate Nitrate 14797 55 8 6.2 x 10 5 2 N575 Polybrominated biphenyls ( PBBs) Polybrominated biphenyls, NOS None ( no EAD TWF chemical identified) 59536 65 1 Not available N583 Polychlorinated alkanes None ( no toxicity data assigned) None ( no EAD TWF chemical identified) Not available Not available N590 Polycyclic aromatic compounds Benzo( a) pyrene Benzo( a) pyrene 50 32 8 4,283.56 2 N725 Selenium compounds Selenium Selenium 7782 49 2 1.12 1 N740 Silver compounds Silver Silver 7440 22 4 16.47 1 N746 Strychnine and salts Strychnine Strychnine 57 24 9 0.095 2 N760 Thallium compounds Thallium Thallium 7440 28 0 1.00 2 N770 Vanadium compounds Vanadium Vanadium 7440 62 2 0.62 1 N874 Warfarin and salts Warfarin Warfarin 81 81 2 1.86 2 Table B 1 ( Continued)

TRI Category Number TRI Chemical Compound Category RSEI Toxicity Based On Representative EAD TWF Chemical EAD TWF Chemical CAS NO EAD TWF Rationale for Assignment B 3 RSEIreport_ 121203. wpd N982 Zinc compounds Zinc Zinc 7440 66 6 0.047 1 Rationale for Assignment 1  With the exception of some compound categories and other special cases, RSEI assumes that metal compounds have the same toxicity weight as that of the parent metal. Representative EAD TWF chemicals for these categories were identified following the same assumption. 2  RSEI Technical Appendix A ( 2002). 3  Table II, Section C of the Toxic Chemical Release Inventory Reporting Forms and Instructions ( 2002) provided a list of the 17 chemicals included in the dioxins category for TRI reporting. 1,2,3,6,7,8 Hexachlorodibenzofuran has the median EAD TWF of these 17 chemicals and was selected as the representative chemical. 1An initial table ( NAIC_ codes. wpd) relating point source category to SIC and NAICS codes was developed by Hugh Wise of EAD and used as the basis for this analysis.

C 1 RSEIreport_ 121203. wpd ATTACHMENT C RELATION OF SIC CODES TO POINT SOURCE CATEGORIES The following tables relate the 4 digit SIC codes to existing point source categories that may regulate discharges from those industries. Table C 1 lists point source categories and their corresponding SIC codes1. Table C 2 lists the primary SIC codes present in the RSEI model ( based on 2000 TRI data) that are not currently covered by a point source category.

Some SIC codes fall in more than one point source category. In these cases, the RSEI model results are either distributed among applicable point source categories or counted in each point source category in which they are regulated, depending on the specific SIC code. The majority of overlapping SIC codes among point source categories occurs between the Metal Products and Machinery ( MP& M, 40 CFR Part 438) and Metal Finishing ( 40 CFR Part 433)

point source categories. EAD determined it would be inappropriate to double count RSEI model results for these point source categories because the final MP& M rule at § 438.1( b) specifically excludes both metal bearing wastewaters and wastewaters subject to other effluent guidelines ( e. g., Metal Finishing). To more accurately represent the applicability of these two point source categories in the RSEI analysis, EAD developed a methodology to distribute the RSEI model results by allocating only organic chemical releases to MP& M and all other releases to Metal Finishing. Although EAD believes this simplified methodology reasonably distributes releases,

EPA acknowledges that the MP& M allocation is somewhat overestimated at the expense of the Metal Finishing allocation because commingled metal bearing and organic bearing wastewaters are regulated only under Metal Finishing.

For SIC codes that overlap point source categories other than MP& M and Metal Finishing, RSEI model results are counted in each point source category in which they are regulated. Double counting of RSEI model results for certain SIC codes accounts for C 2 RSEIreport_ 121203. wpd approximately 8.5 percent of the total RSEI risk related result and 1.5 percent of the total EAD TWF hazard result.