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Effluent Guidelines

Potential Chlorine and Chlorinated Hydrocarbon (CCH) Manufacturing Guidelines

Formerly known as Vinyl Chloride and Chlor-Alkali Manufacturing

We are beginning a new rulemaking to address wastewater discharges from facilities that manufacture chlorine and certain chlorinated hydrocarbons. Chlorinated hydrocarbon manufacturers considered in this rulemaking are based in part on the type of manufacturing process involved. We are collecting additional information on CCH manufacturing operations in order to:

Some common questions follow.

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What are chlorinated hydrocarbons?

Chlorinated hydrocarbons are chemical compounds of chlorine, hydrogen, and carbon atoms only. Many of them form the building blocks of other chemical products such as pharmaceuticals, plastics, and solvents.

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Background

Section 304(m) of the Clean Water Act requires EPA to publish a schedule every two years for annually reviewing and possibly revising effluent guidelines that have been promulgated as required by Section 304(b).

During the 2003 annual review (PDF) (45 pages, 347 Kb), EPA selected the OCPSF Point Source Category for a more detailed review. This category ranked highest in reported pollutant discharges among all industrial point source categories. Dioxins were among the primary pollutants responsible for the high pollutant discharge levels. Additional information on dioxins can be found at EPA's National Center for Environmental Assessment.

EPA identified the manufacture of the following chlorinated hydrocarbons: ethylene dichloride (EDC), vinyl chloride monomer (VCM), and polyvinyl chloride (PVC), as possible sources of dioxins and conducted a detailed study of these manufacturing processes as part of the Technical Support Document for the 2004 Effluent Guidelines Program Plan (PDF) (559 pages, 4,530 Kb).

EPA also selected the Chlor-Alkali Subcategory of the Inorganics Point Source Category for possible revision. EPA added this category because many chlor-alkali operations are co-located with EDC, VCM, and PVC manufacturing. Chlorine produced by operations other than chlor-alkali will also be reviewed as part of this rulemaking.

In addition to dioxins, mercury discharges are of particular concern for mercury-cell chlor-alkali facilities, especially as new air regulations have been implemented. (On December 19, 2003, EPA promulgated National Emission Standards for Hazardous Air Pollutants (NESHAP) for Mercury Emissions from Mercury Cell Chlor-Alkali Plants (40 CFR Part 63).) The regulation covers all plants engaged in the manufacture of chlorine and caustic in mercury cells and requires rigorous work practice standards. EPA is aware that the implementation of these air regulations could increase the amount of mercury in wastewater at chlor-alkali plants.

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Which effluent guidelines cover chlorinated hydrocarbon manufacturing discharges?

  1. Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Point Source Category (40 CFR Part 414)
  2. Pesticide formulating, packaging, and repackaging Point Source Category (40 CFR Part 455)
  3. Pharmaceutical manufacturing Point Source Category (40 CFR Part 439)

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Which effluent guidelines cover chlorine manufacturing discharges?

  1. Inorganic Chemicals Manufacturing (Inorganics) Point Source Category (40 CFR Part 415) covers the manufacture of chlorine via the chlor-alkali manufacturing process.
  2. Chlorine production as a by-product of other manufacturing processes such as magnesium production are also being considered though they are not included in 40 CFR Part 415.

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Which chlorinated hydrocarbons are being considered for this rulemaking?

Chlorinated hydrocarbons in the OCPSF point source category that are manufactured by processes similar to the production for EDC and VCM are part of this rulemaking. These processes include direct chlorination and oxychlorination (used to produce EDC) as well as dehydrochlorination (used to produce VCM).

NOTE: Chlorinated hydrocarbons regulated as pharmaceuticals or pesticides are not included in this rulemaking study.

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What facilities may be affected by this rulemaking?

Facilities that manufacture chlorine or certain chlorinated hydrocarbons may be affected by this rulemaking study. Selected chlorinated hydrocarbons, manufacturing processes involved, and identified facilities are discussed in a memorandum describing the Chlorinated Hydrocarbon Manufacturing Segment (PDF) (29 pages, 345 Kb). This document is available through www.regulations.gov.

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What are the next steps in the CCH effluent guidelines rulemaking process?

  1. We are developing a profile of the CCH manufacturing industry. This Industry Profile will describe the manufacturing operations, current industry conditions and regulations, the data sources used to evaluate this industry, and wastewater characteristics.
  2. We are conducting site visits of CCH manufacturing facilities for a greater understanding of manufacturing operations and process wastewater generation and treatment.
  3. We plan to send a questionnaire to facilities identified as manufacturing CCH products. In April 2006, we announced our plans for the questionnaire in the Federal Register and requested comments (PDF version of FR notice, (2 pages, 79 K)). In January 2007, we revised the questionnaire and submitted it to OMB for approval. At this time, we again requested comments.
  4. We will analyze wastewater samples collected from a subset of facilities. This analysis will help us
    • characterize the industry's wastewaters
    • develop baseline pollutant discharge loads
    • evaluate treatment performance
    These data will be used in the development of treatment alternatives or best management practices as needed.
  5. After considering the collected data on this industry, EPA will publish a draft recommendation on whether or not additional effluent guidelines limitations are warranted (based on the criteria established in the Clean Water Act). A notice of proposed rulemaking will summarize the data collection results and solicit public comment prior to final action.

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Contact Information

If you would like to be included in an e-mail list for this effluent guidelines rulemaking project, or for more information, please contact:

Samantha Lewis, Project Manager
Engineering and Analysis Division
202-566-1058
lewis.samantha@epa.gov

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316(b) | UNDS | NPDES

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