&EPA
             United States
             Environmental Protection
             Agency
Effluent Guidelines Division
WH-552-
Washtngton, DC 20460
                         EPA 440/1 -79/078-b
                         December 1979
             Water and Waste Management
             Proposed
Development
Document for
Effluent Limitations
Guidelines and
Standards for  the
             Gum and Wood Chemicals
             Manufacturing
             Point Source Category
                               202-eBQ*i|iQ1


                             jett.george@epa.gov
                      George M. Jett
                      Chemical Engineer
                    U.S. Environmental Protection Agency
                    Engineering and Analysis Division (4303)
                     1200 Pennsylvania Avenue, NW
                     Washington, D.C. 20460

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           DEVELOPMENT DOCUMENT

                   for

PROPOSED EFFLUENT LIMITATIONS GUIDELINES,
  NEW SOURCE PERFORMANCE STANDARDS, AND
          PRETREA.TMENT STANDARDS

                 for the

          GUM AND WOOD CHEMICALS
          POINT SOURCE CATEGORY
            Douglas M. Costle
              Administrator
            Robert B.  Schaffer
  Director,  Effluent Guidelines Division

              John E.  Riley
  Chief,  Wood Products and Fibers Branch

         William Thomson II,  P.E.
             Project Officer
              December,  1979
       Effluent Guidelines Division
  Office of Water  and Waste Management
  U.S.  Environmental Protection  Agency
        Washington,  D.C.   20460

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                               ABSTRACT

This document presents the findings of an extensive study of  the  gum
and  wood  chemicals  industry  for the purpose of developing effluent
limitations for existing sources, standards  of  performance  for  new
sources,  and  pretreatment  standards for existing and new sources to
implement Sections 301, 304, 306, and 307 of the Clean Water Act.  The
study covers approximately 119 gum and wood  chemicals  facilities  in
SIC  Group  2861  of  which  seven  are  specifically  affected by the
findings.

Effluent limitations guidelines  are  set  forth  for  the  degree  of
effluent  reduction  attainable  through  the  application of the best
practicable control technology currently available   (EPT)  for  a  new
subcategory,   Sulfate  Turpentine  processing.   Effluent  limitation
guidelines  are  set  forth  for  the  degree  of  effluent  reduction
attainable  through  the  application of the best available technology
economically achievable (BAT)   and  the  best  conventional  pollutant
control  technoloyg   
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                          TABLE OF CONTENTS

Section

   I   CONCLUSIONS

  II   RECOMMENDATIONS

           GENERAL                                                9
           EFFLUENT LIMITATIONS GUIDELINES                        9

 III   INTRODUCTION                                              17

           AUTHORITY                                             17
           PURPOSE AND SCOPE                                     17
           GENERAL DESCRIPTION OF INDUSTRY                       18
           SUMMARY OF METHODOLOGY                                19
           DATA AND INFORMATION GATHERING PROGRAM                20

                308 Data Collection Portfolio                    21
                Plant Visits                                     22
                Raw Materials Review                             22
                Screening Sampling                               23
                Verification Program                             23
                Processing of Information                        24

           PROFILE OF INDUSTRY                                   25

                Char and Charcoal Eriquets                       25
                Gum Rosin and Turpentine                         26
                Wood Rosin, Turpentine, and Pine Cil             26
                Tall Oil Rosin, Fatty Acids, and Pitch           26
                Essential Oils                                   27
                Rosin-Based Derivatives                          27
                Sulfate Turpentine                               28

           DESCRIPTIONS OF PROCESSES                             28

                Char and Charcoal Eriquets                       28
                Gum Rosin and Turpentine                         29
                Wood Rosin, Turpentine, and Pine Cil             29
                Tall Oil Rosin, Fatty Acids, and Pitch           32
                Essential Oils                                   3U
                Rosin Derivatives                                36
                Sulfate Turpentine                               36
                                 111

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 IV    INDUSTRIAL  SUBCATEGORIZATICN                              41

          SUBCATEGORIZATION REVIEW                              41

               Manufacturing Process                            42
               Plant Location and Climate                       42
               Raw Materials                                    45
               Plant Age                                         45
               Plant Size and Flows                             46
               Product                                          46
               Wastewater Characteristics and Treatability      46

          POTENTIAL SUBCATEGORIES                               47

  V    WASTEWATER  CHARACTERISTICS                                49
          GENERAL                                               49

               Exclusion  Under Paragraph 8                      49
               Wood Rosin, Turpentine, and Pine Oil             49
               Tall Oil Rosin, Pitch, and Fatty Acids           52
               Sulfate Turpentine                               55
               Rosin Derivatives                                62

 VI    SELECTION OF POLLUTANT PARAMETERS                         64

          WASTEWATER PARAMETERS OF SIGNIFICANCE                 65

          CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
            PARAMETERS                                          65

               BOD                                             65
                TSS                                             66
                PH                                              67

          TOXIC POLLUTANTS                                      6®

            Organic Toxic Pollutants                            68
               Volatile Fraction                               68
                Semi-Volatile Fraction                          75
                Acidic Fraction                                 76

            Inorganic Toxic Pollutants                          77

VII    CONTROL AND TREATMENT TECHNOLOGY                          81

          GENERAL                                               81
          IN-PLANT CONTROL MEASURES                             81
               Wood Rosin, Turpentine, and Pine Oil
81
                                 IV

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                Tall Oil Rosin, Pitch, and Fatty Acids            82
                End-of-Pipe Treatment                             85
                In-Place Treatment Technology—BPT                92

VIII   COST, ENERGY, AND NON-WATER QUALITY ASPECTS                97

           COST INFORMATION                                       97

                Energy Requirements cf Candidate Technologies     98
                Total Cost of Candidate Technologies              98
                Cost of Compliance for Individual Plants          98

           NON-WATER QUALITY IMPACTS OF CANDIDATE TECHNOLCGIES    98

  IX   EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION
       OF THE BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
       AVAILABLE—EFFLUENT LIMITATIONS GUIDELINES                139

           GENERAL                                               139

                 Age and Size of Equipment and Facilities        140

           BEST PRACTICABLE TECHNOLOGY                           140

   X   EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION
       OF THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY
       ACHIEVABLE—EFFLUENT LIMITATIONS GUIDELINES               145

           INTRODUCTION                                          145
           IDENTIFICATION OF THE BEST AVAILABLE TECHNOLOGY
             ECONOMICALLY ACHIEVABLE                             146

                 Metals Removal                                  146

           DEVELOPMENT OF BAT EFFLUENT LIMITATIONS               146
           REGULATED POLLUTANTS                                  147
           SIZE, AGE, PROCESSES EMPLOYED, LOCATION OF
             FACILITIES                                          147
           TOTAL COST OF APPLICATION                             147
           ENGINEERING ASPECTS OF BEST AVAILABLE TECHNOLOGY
             ECONOMICALLY ACHIEVABLE                             148

                 Process Changes                                 148

           NON-WATER QUALITY ENVIRONMENTAL IMPACT                148

  XI   EFFLUENT REDUCTION ATTAINABLE BY BEST CONVENTIONAL
         POLLUTANT CONTROL TECHNOLOGY                            151

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 XII   NEW SOURCE PERFORMANCE STANDARDS                         155

XIII   PRETREATMENT GUIDELINES                                   159

           INTRODUCTION                                          159
           PRETREATMENT STANDARDS  JFOR  EXISTING SOURCES          160

                 Pretreatment Technology                         160

           RATIONALE FOR THE PRETR£ATMENT  STANDARD
             REGULATED POLLUTANTS                                 161
           SIZE, AGE, PROCESSES EMPLOYED,  LOCATION OF
             FACILITIES                                          162
           TOTAL COST OF APPLICATION                             162
           ENGINEERING ASPECTS OF  PRETREATMENT TECHNOLOGY AND
             RELATIONSHIP TO PUBLICLY-OWNED TREATMENT WORKS     162

           IN-PLANT CHANGES                                      163
           PRETREATMENT STANDARDS  FOR  NEW  SOURCESS              165
           RATIONALE FOR THE PRETREATMENT  STANDARD              165
           NON-WATER QUALITY ENVIRONMENTAL IMPACT               165

 XIV   PERFORMANCE FACTORS FOR TREATMENT PLANT OPERATIONS       167

           PURPOSE                                               167
            FACTORS WHICH INFLUENCE VARIATIONS IN PERFORMANCE
             OF WASTEWATER TREATMENT FACILITIES                 167

                Temperature                                      167
                Shock Loading                                    167
                System Stabilization                             168
                System Operation                                 168
                Nutrient Requirements                            168
                System Controllability                          168

  XV   ACKNOWLEDGEMENTS                                          169

 XVI   BIBLIOGRAPHY                                              171

XVII   GLOSSARY OF TERMS AND ABBREVIATIONS                      183

APPENDIX A       LIST OF TOXIC POLLUTANTS                        195

APPENDIX B       SAMPLE 308 DATA COLLECTICN PCRTFCLIO           203

APPENDIX C       RECOMMENDED PARAGRAPH 8 EXCLUSION UNDER THE
                   NRDC SETTLEMENT AGREEMENT                    217

APPENDIX D       ANALYTICAL METHODS AND EXPERIMENTAL PROCEDURE  225

APPENDIX E       CONVERSION TABLE                                245
                                  VI

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                            LIST OF TABLES




Table                                                             ga
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VI-3     Toxic Pollutants Detected  (Organics)                       71

VI-4     Toxic Pollutants Detected  (Metals)                         73

VII-1    Plant 476—Comparison of Raw Wastewater and "Oily
           Water" Cooling System                                    84

VII-2    Secondary Treatment Feed and Effluent Analysis and
           Performance Data                                         90

VII-3    Typical Total Treatment System Performance Data            91

VII-4    Plant 976—Pollutant Reduction Across Fly Ash Slurry       94

VII-5    Treatment Scheme                                           95

VIII-1   Cost Assumptions                                          100

VIII-2   Gum and Wood Candidate Treatment Technologies—
         Indirect Discharge                                        101

VIII-3   Gum and Wood Candidate Treatment Technologies—
         Direct Discharge                                          101

VIII-4   Tall Oil Rosin, Fatty Acid, and Pitch Producing
         Plants—Model Plant Design Criteria                       102

VIII-5   Tall Oil Rosin, Fatty Acid, Pitch, and Rosin
         Based Derivatives Producing Plant—Model Plant
         Design Criteria                                           102

VIII-6   Sulfate Turpentine Producing Plants—Model Plant
         Design Criteria                                           103

VIII-7   Sulfate Turpentine and Rosin Eased Derivatives
         Producing Plants—Model Plant Design Criteria             104

VIII-8   Tall Oil Rosin, Fatty Acids, and Pitch
         Producing Plants                                          105

VIII-9   Tall Oil Rosin, Fatty Acids, and Pitch
         Producing Plants                                          106

VIII-10  Tall Oil Rosin, Fatty Acids, and Pitch and
         Rosin Based Derivatives                                   107

VIII-11  Tall Oil Rosin, Fatty Acids, and Pitch and
         Rosin Based Derivatives                                   108
                                 viia

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VIII-12  Tall Oil Rosin, Fatty Acids, and Pitch and Rosin
         Based Derivatives                                         109

VIII-13  Tall Oil Rosin, Fatty Acids, and Pitch and Rosin
         Based Derivatives                                         110

VIII-14  Tall Oil Rosin, Fatty Acids, and Pitch and Rosin
          Derivatives                                              111

VIII-15  Tall Oil Rosin, Fatty Acids, and Pitch and Rosin
          Based Derivatives Producing Plants                       111

VIII-16  Sulfate Turpentine                                        112

VIII-17  Sulfate Turpentine                                        113

VIII-18  Sulfate Turpentine                                        113

VIII-19  Sulfate Turpentine                                        114

VIII-20  Sulfate Turpentine                                        114

VIII-21  Sulfate Turpentine                                        115

VIII-22  Tall Oil Rosin, Fatty Acids, and Pitch;
         Rosin Based Derivatives; and Sulfate Turpentine           116

VIII-23  Tall Oil Rosin, Fatty Acids, and Pitch;
         Rosin Based Derivatives; and Sulfate Turpentine           117

VIII-24  Tall Oil Rosin, Fatty Acids, and Pitch;
         Rosin Based Derivatives; and Sulfate Turpentine           118

VIII-25  Tall Oil Rosin, Fatty Acids, and Pitch;
         Rosin Based Derivatives; and Sulfate Turpentine           119

VI11-26   Tall Oil Rosin, Fatty Acids, and Pitch; Rosin
          Based Derivatives; and Sulfate Turpentine                120

VIII-27   Tall Oil Rosin, Fatty Acids, and Pitch; Rosin
          Based Derivatives; and Sulfate Turpentine                121

VIII-28   Treatment Option for Plant 151                           122

VIII-29   Treatment Option for Plant 151                           123

VIII-30   Treatment Option for Plant 090                   '   '    124

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VIII-31   Treatment Option for Plant 090                           125

VIII-32   Treatment Option for Plant 686                           126

VIII-33   Treatment Option for Plant 686                           127

VIII-34   Treatment Option for Plant 698                           128

VIII-35   Treatment Option for Plant 948                           129

VIII-36   Treatment Option for Plant 416                           130

VIII-37   Treatment Option for Plant 333                           131

VIII-38   Treatment Option for Plant 121                           132

VIII-39   Treatment Option for Plant 087                           133

VIII-40   Treatment Option for Plant 087                           134

VIII-41   Treatment Option for Plant 266                           135

VEII-42   Treatment Option for Plant 800                           136

VIII-43   Treatment Option for Plant 606                           137

VIII-44   Treatment Option for Plant 693                           138

IX-1      Review of Individual Plants                              142

IX-2      BPT Effluent Limitations Guidelines                      143

IX-3      BPT Effluent Limitations Guidelines
          (Sulfate Turpentine)                                     144

X-1       BAT Effluent Limitations Guidelines                      149

XI-1      BCT Effluent Limitations Guidelines                      152

XII-1     NSPS Effluent Limitations Guidelines                     156

XIII-1    PSES Effluent Limitations Guidelines                     164

XIII-2    PSNS Effluent Limitations Guidelines                     166

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                           LISI  OF FIGURES

Figure                                                           Page

III-1   Gum Rosin and Turpentine Production                         31

III-2   Wood Rosin, Pine Oil,  and Turpentine
        Via Solvent Extraction                                      32

III-3   Crude Tall Oil Fractionation and Refining                   34

III-4   Distillation and Refining cf Essential Oils                 36

III-5   Rosin Derivatives Manufacture                               38

III-6   Basic Process Flow Turpentine Distillation                  39

IV-1    Location of Naval Stores Plants                             43

IV-2    Location of Charcoal Plants                                 4U

VI1-1   Stump Wash Water Treatment System—Plant 687                83

VII-2   Solubility Curves for Chromium, Copper, Nickel,
        and Zinc                                                    88
                                  XI

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                              SECTION I

                             CONCLUSIONS

The  Giim and Wood Chemicals manu fact taring point source category encom-
passes seven industrial segments.  This document  provides  background
information and the technical data base used in the review of effluent
limitations  guidelines  for  the  Gum and Wood Chemicals pcint source
category.   Technologies  are  defined  as  best  practicable  control
technology  currently  available  (BPT),  best  conventional pollutant
technology  (BCT), best available  technology  economically  achievable
(BAT), and pretreatment standards (PSES and PSNS).

The rationale for the exclusion of three subcategories from regulation
is  given  in  accordance  with  the  provisions of Paragraph 8 of the
Settlement Agreement in Natural Resources Defense Council, et. al.  v.
Train (June 8, 1976).

The  Agency  has  extensively sampled the remaining four subcategories
(50 percent of the plants were sampled in the verification phase)   for
the presence or absence of the 129 tcxic pollutants listed in Appendix
A.   Many  of the toxic pollutants fcund in the raw wastes and treated
effluents originate in  specific  process-related  raw  materials  and
chemicals  used  in the manufacturing process.  In the case of certain
pollutants found in widely varying amounts or with erratic frequencies
of occurrence, the precise sources generally remain unknown,  but  are
not suspected to be process-related.

The  rationale by which the Agency then developed effluent limitations
guidelines based on each technology level is presented.  A  review  of
the  previously  promulgated  BPT  limitations  demonstrated  that the
industry  can  meet  the  limitations  with  the  EPT  or   equivalent
biological  technologies  in  use.  The BPT rationale was then used to
derive  the  BPT  effluent  limitations  guidelines  for  the  Sulfate
Turpentine subcategory.

Eased  on  data  from  the  sampling  program,  it appears that BPT or
equivalent  biological  treatment  (including  oil/water   separation,
activated  sludge  or  aerated lagoons treatment,  and polishing ponds)
provides effective control for the organic toxic pollutants.  The data
available indicate that after the application of EPT  technology,   the
organic  toxic pollutants decrease tc levels equal to or less than 0.2
ing/I.

Two  of  the  subcategories,  Rosin-Based  Derivatives   and   Sulfate
Turpentine,   employ   modification   cf   intermediates  by  metallic
catalysts.  These catalysts - copper and nickel in sulfate  turpentine
and zinc in rosin-based derivatives - were detected in the effluent at
a  number  of the plants.  Therefore, for these two subcategories, EPA

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proposes BAT numerical effluent limitations guidelines to limit  these
metallic  toxic  pollutants.   The  remaining  two subcategories—Wood
Rosin, Turpentine, and Pine Oil and Tall Gil Rosin, Fatty  fields,  and
Pitch do not use metals in their processes.

Pretreatment  standards  for  existing  sources  (PSES)  recognize that
organic  toxic  pollutants  in  this  industry  are  reduced  by  good
biological  treatment.   Numerical effluent limitations guidelines are
proposed  for  control  of  metallic  toxic  pollutants  in  the  same
subcategories  covered  by  metallic toxic pollutant limitations under
EAT.

New source performance standards for direct dischargers are equivalent
to BPT  and  BAT.   New  source  performance  standards  for  indirect
dischargers are equivalent to PSES.

The  Agency estimates that the total investment cost to be incurred by
existing sources, both direct and  indirect  dischargers,  to  achieve
these  effluent limitations guidelines (BPT for Sulfate Turpentine and
BAT) and pretreatment standards (PSES)  is $484  thousand,  with  total
operating  cost  of  $937  thousand.   A  total  of  approximately 150
additional pounds per day of conventional pollutants will  be  removed
as  a  result  of the proposed BPT regulations fcr Sulfate Turpentine.
In addition, a total of 2 pounds per day of nickel, 11 pounds per  day
of  copper,  and  120  pounds  per  day  of  zinc,  will be removed by
coirpliance with BAT and PSES regulations.

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                                             Values for BAIEA (1983)
                                                          30-Day     3CH)ay     30-Day
                                                          Average    Average    Average
                          Contaminants     Treatment      Copper     Nickel      Zinc
Subcategories             of Interest      Technology      ng/1       t^/l
Subcategpry A                             jfo discharge of tiie process wastewater pollutants
Char sad Charcoal
Briquets

Subcategory B
Gun Rosin and
Turpentine

Subcategory C
Wood Rosin, Turpentine
and Pine Oil

Subcategory D
Tall Oil Rosin,
Pitch aad Fatty Acids

Subcategory E
Essential Oils

Subcategory F             Zinc           Metals Itenoval                          1.8
Rosin-Based                              and Sludge
Derivatives                              Disposal

Subcategory G             Copper         Metals Reroval    1.8
Sulfate Turpentine        Nickel         ari Sludge
                                         Disposal                     1.8

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                              SECTION II

                           RECOMMENDATIONS
GENERAL

This document recommends effluent limitations guidelines  commensurate
with  BPT,  BCT,  BAT,  PSES,  NSPS,  and  PSNS  for  the Gum and Wood
Chemicals manufacturing point source category.  A  discussion  of  in-
plant  and  end-of-pipe  control  technology  required  to achieve the
recommended effluent limitations guidelines and new source performance
standards is included.

EFFLUENT LIMITATIONS GUIDELINES

After review of  industry  processes  and  wastewater  treatment,  the
Agency  recommended  exclusion  of  three  subcategories  from further
study.  The basis for the exclusion of Char and Charcoal Briquets, Gum
Rosin and Turpentine, and Essential Oils appears in Appendix C.

Table II-1 presents effluent limitation guidelines  commensurate  with
EFT  for  the  Sulfate  Turpentine  subcategory  of  the  Gum and Wood
Chemicals industry.  The effluent limitation guidelines represent  the
maximum  average  of  daily  values  for  30  consecutive days and the
maximum for any one day and were developed on the basis of perfcririance
factors discussed in Sections IX and XIV of this Development Document.

Process wastewaters subject to these limitations do not  include  non-
contact  sources  such as boiler and cooling water blowdown, sanitary,
and other similar flows.  BPT also includes the maximum utilization of
applicable in-plant pollution abatement technology to minimize capital
expenditures for end-of-pipe wastewater  treatment  facilities.   Flow
for BPT is identical with flow for BCT and BAT in this document.  End-
of-pipe  technology  for  BPT  involves  the application of biological
treatment, as typified by activated sludge  or  equivalent  biological
treatment systems.

Effluent  limitations  guidelines to be attained by application of EAT
are presented in Table II-3.  Treatment for BAT includes at-the-source
metals precipitation by pH adjustment and filtration or  clarification
for sulfate turpentine and rosin-based derivatives.  This treatment is
to  be  followed by BPT treatment of all process waste streams.  It is
emphasied that the model treatment system does not preclude the use of
other metals  removal  technologies.   EAT  is  further  discussed  in
Section X.

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Effluent  limitations guidelines to be attained by application of NSPS
are presented in Table  II-4.    Treatment  for  NSPS  includes  metals
precipitation  at-the-source by pH adjustment and filtration or clari-
fication for sulfate turpentine and rosin-based  derivatives  followed
by  biological  treatment.    NSPS is further discussed in Section XII.
Effluent limitations guidelines to be attained by application of  PSNS
and  PSES  are  presented in Tables II-5 and II-6, respectively.  PSNS
and PSES includes metals precipitation at-the-source by pH  adjustment
and filtration or clarification for sulfate turpentine and rosin-based
derivatives.
                                 10

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           Table II-1.  BPT Effluent Limitations Guidelines
                                       Effluent Limitations
                             Maximum for       Average of Daily Values
               Effluent      Any One Day       for 30 Consecutive Days
gubcategory  Characteristic
A No discharge of
B BODS
TSS
C BODS
TSS
D BODS
TSS
E BODS
TSS
F BODS
TSS
G BODS
TSS
»— j — =*•
process
1.420
0.077
2.08
1.38
0,995
0.705
22.7
9.01
1.U1
0.045
5.504
0.686
wastewater pollutants
0.755
0.026
1.10
0.475
0.529
0.243
12.0
3.11
0,748
0.015
2.924
0.236
* kg/kkg production is equivalent to Ibs/1,000 Ibs production.
                                 11

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           Table II-2.  BCT Effluent Limitations Guidelines
               Effluent
Subcategory  Characteristic
                     Effluent Limitations
           Maximum for       Average of Daily Values
           Any One Day       for 30 Consecutive Days
              (kg/kkg)*	Shall Not Exceed
    G
BOD5
TSS

BOD5
TSS

BOD.5
TSS

BOD.5
TSS
2.08
1.38

0.995
0.705

1.41
0.045

5.504
0.686
1.10
0.475

0.529
0.243

0.748
0.015

2.924
0.236
                                  12

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           Table II-3.   BAT Effluent Limitations Guidelines
                                    Effluent Limitations
                             Maximum for       Average of Daily Values
               Effluent      Any One Day       for 30  Consecutive Days
Subcategory  characteristic	mg/1	Shall Not Exceed	(mg/1)
F
G

Zinc**
Copper**
Nickel**
4.2
4.5
4.1
1.8
1.8
1.8
*  kg/kkg production is equivalent to lbs/1,000 Ibs production.
** At the source (mg/1).
                                 13

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            Table II-4.  New Source Performance Standards
                                    Effluent Limitations
                             Maximum for       Average of Daily Values
               Effluent      Any One Day       for 30 Consecutive Days
Subcateqory  Characteristic	{kq/kkcj)	Shall Not Exceed  (kq/kkg)*

    C            BOD£              2.08                 1.10
                 TSS               1.38                 0.475

    D            BOD1              0.995                0.529
                 TSS               0-705                0.243

    F            BOD5              1.41              •   0.748
                 TSS               0.045                0.015
                 Zinc**            4.2                  1.8

    G            BODji              5.504                2.924
                 TSS               0.686                0.236
                 Copper**          4.5                  1.8
                 Nickel**          4,1                  1,8

*  kg/kkg production is equivalent tc Ibs/1,000 Ibs production.
** At the source (mg/1),
                                 14

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         Table II-5.  Pretreatment Standards for New sources
               Effluent
Subcategory  Characteristic
                      Effluent Limitations
            Maximum for       Average of Daily Values
            Any Cne Day       for 30 Consecutive Days
                (mq/11    _____ Shall Not Exceed	(mg/1)
    F

    G
Zinc*

Copper*
Nickel*
4.2

a. 5
* At the source (mg/1).
1.8

1.8
1.8
                                 15

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       Table II-6.   Pretreatment Standards for Existing Sources
               Effluent
Su bcateorory  Characteristic
                       Effluent Limitations
             Maximum for     Average of Daily Values
             Any One Day     fcr 30 Consecutive Days
                (mq/1)	Shall Not Exceed   (mq/1)
F

G
Zinc*

Copper*
Nickel*
4.2

4.5
4.1
1.8

1.8
1.8
*At the source (mg/1)
                                  16

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                             SECTION III

                             INTRODUCTION

AUTHORITY

Section  304(b)  of  the  Federal  Water Pollution Control Act of 1972
required the Administrator to publish regulations providing guidelines
for effluent limitations, including BAT.   Section  306  required  the
Administrator to publish regulations establishing Federal standards of
performance  for categories of new industrial sources  (NSPS).  Section
304(b) required the Administrator to publish regulations  establishing
pretreatment standards for the introduction of incompatible pollutants
into publicly owned treatment works.  Further, section 307 (a) required
the   Administrator   to  publish  regulations  establishing  effluent
standards  for  certain  toxic-  pollutants.   Finally,   section   501
authorized the Administrator to prescribe such regulations in order to
carry out these functions under the Act.

EPA  was  unable to promulgate many of the regulations required by the
1972 Act's prescribed dates.  In 1976,  several  environmental  groups
sued  EPA with respect to this issue.  EPA and the plaintiffs executed
a "Settlement Agreement", with Court approval.  The Agreement required
EPA to develop a program and adhere to a schedule for promulgating BAT
effluent  limitations  guidelines,  pretreatment  standards,  and  new
source  performance standards for 65 "priority"  (toxic) pollutants and
classes of pollutants.  See Natural Resources Defense Council, Inc. y^
Train 8 EEC 2120 (D.D.C. 1976).

On December 27, 1977, the President signed into law  the  Clean  Water
Act  of 1977, amending the prior Act.  The amendment incorporates into
the Act many elements of the Settlement Agreement  program  for  toxic
pollutants  control.   section 301 (b)(2)  requires achievement, by July
1, 1984,  of  BAT  for  toxic  pollutants.   "Conventional  pollutant"
parameters,  including  biochemical  oxygen  demand, suspended solids,
fecal coliform bacteria and pH,  are to  be  controlled,  by  the  same
date,  pursuant  to  BCT.  For non-toxic, non-conventional pollutants,
sections  301 (b) (2) (A)  and  (b) (2) (F)   require  achievement  of   BAT
effluent  limitations  within three years after their establishment or
by July 1, 1984,  whichever is later, but not later than July 1, 1987.

Guidelines and standards developed with  reference  to  this  document
will be directed toward implementation of those requirements.

PURPOSE AND SCOPE

This  document  presents  the  technical  data  base used to establish
effluent  limitations  guidelines  for  the  Gum  and  Wood  Chemicals
Industry.    The  information  presented  is  intended to support EPA's
                                 17

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establishment  of  guidelines  defining   best   practicable   control
technology currently available ("EFT"; see sections 301 (b) (1) (A),  (B) ,
and  (C)   and  30U (b) (1)   of  the Clean Water Act, 33 U.S.C.  e1251 et
seq.)  for  the  Sulfate  Turpentine  subcategory  and  best  available
technology  economically achievable ("BAT"; see sections 301 (b) (2) (A) ,

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 The   Standard   Industrial  Classifications   list  was developed by the
 United  States  Department  of  Commerce   and   is   oriented  toward  the
 collection  of  economic  data related  to gross production, sales, and
 unit  costs.  The list  is useful  in that it divides  American  industry
 into    discrete  product-related  segments.   The  SIC  list  is  not
 necessarily related to the' nature of the industry in terms  of  actual
 plant  operations,  production processes, or  considerations associated
 with  water pollution control.

 More  specifically, then, the scope of coverage of this  study  is   as
 follows:

 1.    Plants  engaged in the manuracture of char and charcoal briquets,
 as well as pyroligneous acids and other by-products;

 2.  Plants engaged in  the manufacture of gum  rosin and  turpentine   by
 the distillation of crude pine gum;

 3.    Plants  engaged in the manufacture of wocd resin, turpentine, and
 pine  oil from  pine stump wood;

 4.  Plants engaged in  the manufacture of tall oil rosin, fatty  acids,
 and pitch by fractionation of Kraft process crude tall oil;

 5.    Plants  engaged   in  the  manufacture of essential oils-turpenes,
 hydrocarbons,  alcohols, or ketones;

 6.  Plants engaged in  the manufacture of rosin   derivatives:  esters,
 adduct  modified esters, and alkyds; and

 7.  Plants engaged in  the processing of sulfate turpentine.

 SUMMARY OF METHODOLOGY

 The   effluent  limitations and pretreatment standards were developed  in
 the following  manner.  EPA reviewed the original  development  document
 (1976)  for  possible  industry  subcategorization.   This  evaluation
 studied whether  differences in raw material   used,  product  produced,
 manufacturing   process  employed,  equipment,  age,  size,  wastewater
 constituents,  and other  factors  required  development  of  different
 industry  subcategories.    The   raw  waste  characteristics  for  each
 subcategory were identified and  used in this  analysis.    The  analysis
 included  consideration  of:  (1) the sources and volume of water used
 in the  processes and the sources of pollutants and wastewaters in  the
 plant and (2)   the constituents (including thermal) of all wastewaters,
 including  toxics and  other constituents which produce taste, odor, or
 color in water or aquatic organisms.  The wastewater  constituents  to
 be  considered for pretreatment standards were identified (see Section
VI).
                                 19

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The  Agency  identified  the  full  range  of  control  and  treatment
technology  existing  within the point source category.   This included
identification of each  distinct  control  and  treatment  technology,
including  the  amounts  of  constituents  (including thermal)  and the
chemical, physical, and biological characteristics of pollutants,  and
the  effluent  levels  resulting  frcm  the application cf each of the
treatment and control technologies.  The  problems,  limitations,  and
reliability  of  each  treatment  and  control  technology  were  also
identified.  Also discussed were the non-water  quality  environmental
impacts  of such technologies upon other pollution problems, including
air, solid waste, and noise.

EPA considered various factors  in  assessing  treatment  and  control
technologies.    These   included   the   total   cost  of  technology
application, the equipment  and  facilities  involved,  the  processes
employed,  the engineering aspects of the application of various types
of   control   techniques,   process   changes,   non-water    quality
environmental  impacts   (including  energy  requirements),  and  other
factors.

DATA AND INFORMATION GATHERING PROGRAM

The first step in the review process was to assemble and evaluate  all
existing sources of information on the wastewater management practices
and  production  processes  of  the  Gum  and fcood Chemicals Industry.
Sources of information included:

1.  Current  literature,  EPA  demonstration  project   reports,   EPA
Technology Transfer reports;

2.   Development   Document  for  Interim  Final  Effluent  Limitation
Guidelines and Proposed New Source Perfcrmance Standards for  the  Gum
and  wood  Chemicals  Manufacturing  Point  Source Category, U.S. EPA,
April 1976;

3. Data submitted by  individual  plants  and  trade  associations  in
response  to  publication  of  proposed  regulations,  and  information
provided directly for this study;

4. Information obtained  from  direct  interviews,  plant  visits,  and
sairpling visits to production facilities.

Section  XVI  of this document presents a complete bibliography  of all
literature reviewed during the course of this  project.   Analysis  of
the  above  sources  indicated  the  need  for additional information,
particularly concerning  the use and  discharge  of  toxic   pollutants.
The  Agency  also  needed  updated  information   en production-related
process raw waste loads   (RWL),   potential  in-process  waste   control
                                  20

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techniques,   and   the  identity  and  effectiveness  of  end-of-pipe
treatment systems.

308 Data Collection Portfolio

Recognizing that the best sources cf  existing  information  were  the
individual  plants,  EPA prepared a data collection portfolio and sent
it directly to manufacturing plants.  The portfolio  was  designed  to
update the existing data base concerning water consumption, production
processes,  wastewater  characterization,  raw  waste  loads  based on
historical  production  and  wastewater  data,  method   cf   ultimate
wastewater  disposal,  in-process  waste  control  techniques, and the
effectiveness  of  in-place  external   treatment   technology.    The
portfolio  also  requested information concerning the use of materials
which could contribute toxic pollutants to wastewater  and  asked  for
any  data  on  toxic  pollutants  in wastewater discharges.  Responses
served as the source of updated, long-term, historical information for
the traditional parameters such as BOD, COD, solids, pH, phenols,  and
metals.  A copy of the blank survey form appears in Appendix B.
                                                                    *
The  mailing  list  for the data collection portfolio was derived from
the following sources:

1.  Previous plant listings in the EPT administrative record;

2.  1977 Dun and Bradstreet listing for SIC 2861;

3,  State Chambers of Commerce directories of manufacturing;

4.  Standard and Poor listing;

5.  1977 Stanford Research Institute Directory of Chemical Producers.

The final revised mailing list consisted of 343 plants.

There were a total of 195 responses to the 308  survey.    Since  plant
visits and ether contacts with the industry indicated that in  a number
of  cases  the survey had been received either late or not at  all, the
Agency took a follow-up telephone survey to determine receipt   of  the
questionnaire.   Eighty-seven plants were contacted by telephone.
                                 21

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Table III-l.
List of Plants Identified in the Gum and Wood Chemicals
Study
      Plant
                                                    Location
Reichhold Chemicals Inc.
Arizona Chemical Co., lac.
Reichhold Chemicals, Inc.
Reichhold Chemicals, Inc.
S.C.H. Corp.
Sylvachem Corp.
Union Camp Corp.
Hercules, Inc.
Hercules, Inc.
Union Camp Corp.
Union Camp Corp.
Arizona Chemical Co., Inc
Westvaco
Crosby Chemicals,  Inc.
Hercules, Inc.
Monsanto Company
Hercules, Inc.
Hercules, Inc.
Westvaco
Reichhold Chemicals,  Inc.
                              Bay Minette, AL
                              Panama City, FL
                              Telogia, FL
                              Pensacola, FL
                              Jacksonville, FL
                              Port St. Joe, FL
                              Jacksonville, FL
                               Savannah, GA
                              Brunswick, GA
                              Valdosta.f GA
                              Savannah, GA
                              Springhill, LA
                              DeRidder, LA
                              Picayune, MS
                              Hattiesburg, MS
                              Hitro, WV
                              Portland, OR
                              Franklin, VA
                              Charleston Heights,  SC
                              Oakdale,  LA
                            22

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              Summary of Response to Industry survey
Survey returned—Gum & Wood
Telephone responses—Gum S Wood

Survey returned—Charcoal
Telephone responses—Charcoal
Status unconfirmed—Charcoal

Survey returned—not applicable
Telephone responses—not applicable

Survey returned—out of business
Telephone responses—out of business

Dnreachable—no listing
Dnreachable—disconnected

   TOTAL

Plant Visits
 35
  2

 37
  8
 32

117
 63

  6
  6

 28
  q

338
Total

  37



  77


 180


  12


  32^

 338
Survey  teams  of  project  engineers and scientists visited 12 plants
from December 1977 to  June  1978.   The  selected  plants  were  most
representative  of  the  industrial  processes  and  treatment systems
available in the industry.

Information on process plant operations and  the  associated  RWL  was
obtained   through   interviews   with   plant   operating  personnel,
examination of  plant  design  and   operating  data   (original  design
specifications,  flow  sheets, and day-to-day material balances around
individual process modules or unit   operations  where  possible),  and
sampling   of  individual  process   wastewater.   Information  On  the
identity and performance of wastewater treatment systems was  obtained
through  interviews  with plant water pollution ccntrol or engineering
personnel,  examination  of  treatment  plant  design  and  historical
operating   data,  and  sampling  of treatment  plant  influents  and
effluents.

Raw Materials Review

Only in rare instances did plants acknowledge the  presence  of  toxic
pollutants  in  waste  discharges  in  the   responses  to  the  survey
questionnaires.  Establishing toxic  pollutant data in waste discharges
of the  industry,  therefore,  required  engineering  review  of  raw
materials   and  production  processes  and   a  screening  sampling and
analysis program.  EPA made every effort to  choose   facilities  where
                                  23

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meaningful information for both treatment facilities and manufacturing
operations could be obtained.

Screening Sampling

The  screening  sampling  program  took  place during April and May of
1978.  Five plants were sampled, representing six of the  seven  major
Gum  and  wood  Chemicals  processes.    (The seventh process, char and
charcoal briquets, is dry).  A single  24-hour  composite  sample  was
obtained from the raw and treated wastewater streams at each plant and
analyzed  for  the  129 toxic  pollutants listed in Appendix A of this
document.  Sampling and analyses were conducted according to  Sampling
and  Analysis  Procedures  for  Screening  of Industrial Effluents for
Priority PollutantsL U.S. EPA, Cincinnati, March 1977   (revised  April
1977),  and  Analytical  Methods for the Verification Phase of the EflT
Review, U.S. EPA Effluent Guidelines Division, Washington, E.G.,  June
1977.

The  purpose  of  the  screening  sairpling and analysis program was to
determine which toxic pollutants were present in wastewaters from each
sairpled  industrial  segment  and  to  determine  the  extent  of  the
contamination.

EPA  then  evaluated  the results cf the screening analyses along with
the process  engineering  review  for  each  subcategory.   The  toxic
pollutants found in levels above the detection limits for the analyses
or those suspected of being present due to their use as raw materials,
by-products,  final  products,  etc,,  were selected for verification.
Asbestos, cyanide,  PCB's, and the pesticides were not analyzed in  the
verification  phase  because  they  did not appear in levels above the
detection limit in the screening phase.  The screening sarr.fling visits
to the five selected plants also  produced  two  24-hour  verification
samples at four of the plants.

Verification Program

The  verification  sampling  and  analysis  program,  conducted over a
three-month period, was intended to obtain  for  each  subcategory  as
much  quantitative  data  as possible on the toxic pollutants selected
for verification during the screening  prcgram.   The  sampled  plants
represented   the  full  range  of  in-place  process  and  wastewater
treatment technology for each subcategory.  Nine plants  were  sampled
during  verification  sampling.   The verification program analyzed for
all  129  toxic  pollutants  except  asbestos,  cyanide,  PCB1s,   and
pesticides.

Three  consecutive  24-hour  composite  samples of the raw wastewater,
final treated effluent,  and,  in  appropriate  cases,  effluent  from
intermediate  treatment  steps  were obtained at each plant.  A single
                                 24

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grab sample of incoming fresh process water also  was  taken  at  each
plant.

Processing of Information

The technical data base which established subcategcrizaticn within the
industry  (Section IV), and identified the full range of in-process and
treatment   technology   options  available  within  each  subcategory
(Section VII)  consisted of the following:

1.  Review of available literature and previous studies;

2.  Analysis of the data collection portfolios;

3.  Information from industry and trade associations;

4,  Information from plant visits; and

5,  Results of analyses from the screening and  verification  sampling
programs.

The   raw   waste  characteristics  for  each  subcategory  were  then
identified (Section V).  This included an analysis of:

1.  The source and volume of water used in the specific processes  and
the sources of wastes and wastewaters in the plant; and

2.   The  constituents  of  all wastewaters, including traditional and
toxic pollutants.

The full range of control and treatment technologies  existing  within
each candidate subcategory was identified.  This included an identifi-
cation  of  each  existing control and treatment technology, including
both  in-plant  and  end-of-pipe  systems.   It   also   included   an
identification  of  the  wastewater characteristics resulting from the
application of each existing treatment and control technology.

The  costs  and  energy  requirements  of  each   of   the   candidate
technologies  identified were then estimated (Section VIII)  both for a
flow-weighted average plant within the subcategory and on a  plant-by-
plant  basis.    BPT  technology  costs  were net considered except for
sulfate turpentine processing.

Additional evaluation was  made  of  non-water  quality  environmental
impacts,  such  as the effects of the application of such technologies
en other pollution problems.
                                 25

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PROFILE OF INDUSTRY

The Gum and Wood Chemicals Industry began in the  United  States  when
early  colonists  harvested  pine cleorosin for use in construction of
naval vessels.  Since that time the industry has grown and expanded as
new uses  have  been  found  for  pine  products.   One  of  the  more
significant  innovations  has been the development of by-products from
the Kraft paper  process—tall  oil  and  sulfate  turpentine—as  raw
materials for the Gum and Wood Chemicals Industry.

The  modern  Gum  and  Wood Chemicals Industry can be grouped into the
following major areas:

1.  Char and charcoal briquets;

2.  Gum rosin and turpentine;

3.  Wood rosin, turpentine, and pine oil;

4.  Tall oil rosin, fatty acids, and pitch;

5.  Essential oils;

6.  Rosin derivatives; and

7.  Sulfate turpentine.

Char and Charcoal Briquets

Char results  from  the  destructive  distillations  of  softwood  and
hardwood (primarily the latter).  Char, in turn, may be processed into
charcoal  briquets  or activated carbon.  Pyroligneous acid was once a
by-product of the process, but  has  been  discontinued  in  favor  of
petroleum  substitutes.   with the rising cost of petrochemicals, some
plants are considering reinstituting the recovery process.

Charcoal is one of the more economically important products of the Guir
and wood Chemicals Industry,  It is  widely  used  as  a  recreational
fuel,  in  the  chemical  and  metallurgical  industries, and in other
areas, including use as a filter for gaseous and liquid streams.

The char and charcoal industry in the United  States  consists  of  77
plants  primarily  concentrated in the eastern section of the country,
with the heaviest concentration in the Ozark and Appalachian  hardwood
areas.   Plant ownership varies from companies with numerous plants to
singly-owned plants with local product distribution.
                                 26

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Gum Rogin and Turpentine

In terms of product value, gum rosin and  turpentine  products  are  a
minor  portion  of  the  Gum  and Wood Chemicals Industry.  High labor
costs  for  gum  collection  coupled  with  competition  frcm  foreign
products  has  reduced  the  number of plants and the value of product
shipments and the decline will probably continue.

Currently there are only seven plants in this segment of the industry,
all located in Georgia.  The greatest production  is  concentrated  in
southern  and  southeastern  Georgia.   The  two  largest  plants have
diversified  and  now  are  producing   rosin-based   derivatives   in
conjunction with gum rosin and turpentine.

The  raw material comes from a few remaining pine gum farmers and from
gum wholesalers.  Although gum rosin and turpentine  are  the  highest
quality  of  such  products  in  the naval stores industry, decreasing
availability of domestic gum rosins is forcing manufacturers  to  rely
on  foreign  sources  or  to  use weed or tall oil rosin in derivative
operations.

Wood Rosin, Turpentine, and Pine Gil

Wood  rosin,  turpentine,  and  pine  oil  produced  by  the   solvent
extraction and steam distillation cf rosinous wood stumps, account for
19  percent  of  the total product value of the Gum and Wood Chemicals
Industry, according to the 1972 Census cf Manufacturers.  The economic
life of this segment of the industry is  limited  by  diminishing  raw
materials and the development of competitive processes.

Historically,  the  industry  used  the pine stumps remaining from the
harvesting of first-generation southern pine forests in the early part
of the twentieth century.  Few such stumps remain at the present  time
and second-generation stumps contain considerably lower rosin content.

This   segment  of  the  industry  consists  of  five  plants—one  in
Mississippi, three  in  Florida,  and  one  in  Georgia,   Each  plant
cccupies  a  land  area  of  40 to 60 hectares (100 to 150 acres), the
majority of which is used for raw  material  storage.   Three  of  the
plants  are  located  in  urban  areas; the remaining two are in rural
settings.

Ta11 Oil Rosin, Fatty Acids, and Fitch

The growth of tall oil refining has continued since 1949; however, the
production  of  fatty  acids  and  rosins   with   low   cross-product
contamination is a fairly recent development.
                                 27

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Crude tall oil is particularly attractive as a raw material because of
its  availability  as  a  "waste"  product of the Kraft pulp and paper
industry; this segment of the industry, therefore, provides increasing
supplies of raw materials for tall oil fractionatcrs.   While there  is
a  steady  decline  in  naval  stores  production  from  gum  and wood
extraction, there is a corresponding  production  increase  from  tall
oil.

Recent  trends in the amount of tall oil produced by the kraft process
have indicated a reduced rate of increase  in  the  amount  available.
This  has  resulted  from changes both in the Kraft process and in the
Kraft process raw materials.  More hardwood and ycunger  growth  pines
are  in  use  so  that  less  oleoresin  is  available.  If this trend
continues, the availability of tall cil may decline.

Twelve tall  oil  distillation  plants  are  currently  in  operation,
primarily  in  the  Southeast.   Two  additional  plants  are  not  in
operation, but could be made operational  if  economic  conditions  so
dictated,

Essential Oils

The essential oils produced in the Gum and Wood Chemicals Industry are
cedarwood  oil  and  pine  scent.   Cedarwood  oil  is produced by the
steaming of cedarwood sawdust in pressure retorts to  remove  the  oil
from  wood  particles.   One plant produces pine leaf oil for use as a
scent in Christmas products.  Pine needles are steamed to extract  the
oil.

In  the  eastern  United  States, cedarwood oil is a by-product of the
production  of  cedarwood  lumber   and   furniture   from   Juniperus
virginiana-   This  wood contains 2 to 4 percent cil.   Currently three
plants produce cedarwood oil from this type of cedarwood.

In the western portion of  the  country,  cedarwood  oil  is  produced
directly  from  a  tree  of the Cedarus family which is unsuitable for
lumber production.  Five plants use this raw  material.   The  process
involves grinding the whole tree into wood dust and extracting the oil
by steaming.

The  growing  concerns  in the industry are competition with synthetic
oils and the dwindling supply of trees as raw material.

Rosin-Based Derivatives

Rosin-based derivatives are not included in SIC  2861,  Gum  and  Wood
Chemicals,   but  in  SIC  2821,  Plastics  and  Synthetic  Materials.
However, derivatives production is a natural extension  of  processing
in  Gum  and Wood Chemicals plants since the resin is available in the
                                 28

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 plants.   This  study  applies only  tc those  derivatives  operations  which
 are located  within and  in conjunction  with   Gum   and  Wood  Chemicals
 facilities.

 Currently  13   Gum   and Wood  Chemicals   plants   are  producing  rosin
 derivatives.   These  plants are located within all  four types of   rosin
 producing plants.

 Of   all   the Gum and Wood Chemicals processing operations, derivatives
 prccessing is  the most  profitable,  at least   partly  due  to  a   large
 product   and  market development effort in the industry.  Derivatives
 products   include  ink  resins,   paint  additives,  paper  size,    oil
 additives,   adhesives,  wetting agents, chewing gum base, and chemical-
 resistant resins.

 Sulfate Turpentine

 Sulfate turpentine originally was considered  a waste   product  in  the
 digester   relief  gas of the Kraft  pulp and paper process; with modern
 technology,  however, it can be profitably  recovered to such an  extent
 that  sulfate   turpentine is the  major source of turpentine in the  Gum
 and Wood  Chemicals Industry.

 The distillation of  sulfate turpentine yields four major  compounds-a-
 pinene,   b-pinene, dipentene, and pine oil.   The primary uses of  these
 compounds are  for flavor, fragrances, resins,  and insecticides.   While
 b-pinene  and dipentene  are the components  of  greatest  use, new methods
 and markets  currently are being developed  for a-pinene.

 Turpene derivatives—generally produced in conjunction  with  sulfate
 turpentine distillation with b-pinene and  dipentene as raw materials—
 provide tack (stickiness)  in polymeiic mixtures and pressure sensitive
 tapes.

 DESCRIPTIONS OF PROCESSES

 Char and  Charcoal Briquets

 Char  and  charcoal result from the  combustion (thermal decomposition)
 of ^raw wood which drives off gases  and vapors  and  leaves  about  one-
 third  of  the  wood,  by weight, as charcoal.  Commercial charcoal is
 produced  at a temperature of about  400°  tc 500°C.

During  carbonization,  distillates—collectively   referred   to   as
pyroligneous   acid—are  formed.   Pyrcligneous  acid  contains  such
compounds as methanol, acetic acid, acetone,  tars, and oils.    Because
synthetic  substitues  are cheaper, current industry practice does not
recover the by-products, but feeds the distillate and other flue gases
to an afterburner for thermal destruction  before  exhausting  them  tc
                                 29

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the  atmosphere.   This study found no facilities in the United States
which recover distillation by-products.  The  condensable  distillates
or vapor also may be recycled as a fuel supply supplement, but this is
not common in the industry.

Gum Rosin and Turpentine

Crude  gum  is  obtained  from  healthy pines by exposing the sapwood.
This operation usually takes place during December or  January,  since
early  removal  of  the  bark stimulates early gum flow in the spring.
The main flow of gum occurs from March  through  September,  with  the
wound typically being treated with sulfuric acid to prolcng the period
of flow.

The  processing  plants  receive  the  raw  gum,  composed of about 68
percent rosin and 20 percent turpentine, in 197.3 kg  (435 Ib) barrels.
A typical process flow schematic is shewn in Figure III-1.  The gum is
emptied into a vat by inverting the crude gum containers over a  high-
pressure steam jet.  This mixture is then filtered and washed, and the
prepared  crude  gum  material is distilled to separate the turpentine
frcm the gum rosin.   Non-contact  shell-and-tube  steam  heating  and
sparging  steam  are  used  in  the  stills.  Turpentine and water are
distilled overhead and condensed with shell-and-tube  condensers.   The
water is separated from the turpentine in the downstream receivers.

The  gum rosin is removed from the bottom of the still and transferred
to  shipping  containers  while  the  rosin  is  in   a  molten  state.
Wastewater usually originates in three areas:

1.  The liquid waste from the raw gum wash tank;

2.  The water fraction from the turpentine-water separator; and

3,   In  some plants, a brine waste frcm a sodium chloride dehydration
used to dewater the turpentine.

^ood Rosin, Turpentine and Pine Oil

Figure III-2 shows a typical process diagram.  Pine stumps are  washed
in  the  plant  and the water and sedimert flow to a settling pond  from
which water recycles  back  to  the  washing  operation.   Wood  hogs,
chippers,  and  shredders mechanically reduce the wood stumps to chips
approximately 5 centimeters  (2 inches) in  length  and  3  millimeters
 (1/16  inch)  thick.   The  chips  are  fed  to  a  battery  of retort
extractors, which employ the following steps:

 1.  Water is removed from the chips by azeotropic distillation with   a
water-immiscible solvent;
                                  30

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 2.   The   resinous  material  is  extracted from the wood chips with a
 water-immiscible solvent; and

 3.  Residual solvent is removed from the spent wood chips by steaming.

 After the  steaming step, spent chips are removed from the  retort  and
 sent to the boilers as fuel.  Any entrained wood fines coining from the
 retorts  are  removed  in  the  entrainment separator and used also as
 fuel.  The vapors from the entrainirent  separator  are  condensed  and
 proceed  to  one  or  more  separators where the solvent-water mixture
 separates.  The solvent is recycled for use in the retorts.

 The extract liquor is sent to a distillation column  to  separate  the
 solvent  from the products.  The overhead from the column is condensed
 and enters a separator where condensed solvent is removed and recycled
 to the retorts.  The vapor phase from the  separator  condenses  in  a
 shell-and-tube exchanger and enters a separator in which the remaining
 solvent  and  is  separated.   The  solvent  is  sent  to  recycle and
 wastewater to treatment.


 The bottom stream from the first distillation column enters  a  second
 distillation  column, as shown in Figure III-2.  Steam introduced into
 the bottom of the tower  strips  off  the  volatile  compounds.   This
 overhead   steam  enters  a  condenser and separator.  A portion of the
 condensed  liquor phase is refluxed back tc  the  distillation  column,
 but   a  larger  portion  is  stored  as  crude  turpene  for  further
 processing.  The non-aqueous phase from the  separator  is  stored  as
 crude  turpene  while the aqueous phase is removed as wastewater.  The
 bottom stream from the second distillation column is the finished wood
 rosin product.

 The crude turpene removed in the second distillation column is  stored
 until  a   sufficient  quantity  accumulates  for processing in a batch
 distillation column.  The distillation  column  is  charged  with  the
 crude turpene material, and the condensed material enters a separator.
 The  turpene  and  pine  oil  products are removed from the separator,
while the vapors and steam from  the  steam  ejector  enter  a  second
 shell-and-tube  exchanger and proceed tc a separator.   The bottom from
 this batch distillation column is a  residue  containing  high-boiling
point materials, best described as pitch, which are used as fuel.

Ta 11 Oil Rosin, Fatty Acids, and Pitch

A  schematic  process  flow  diagram  of  a  typical  crude  tall  oil
fractionation process is presented in Figure III-3.

The crude tall oil is treated with dilute sulfuric acid tc remove some
residual  lignins  as  well  as  mercaptans,  disulfides,   and   color
                                 33

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materials.   Acid  wash water is discharged to the process sewer.  The
stock then proceeds  to  the  fractionation  process.   In  the  first
fractionation  column,  the  pitch  is removed from the bottoms and is
either sold, saponified for production of paper  size,  or  burned  in
boilers  as  fuel.   The remaining fraction of the tall oil (rosin and
fatty acid) proceeds to the pale plant, which improves the quality  of
the raw materials by removing unwanted materials such as color bodies.
The  second  column  separates  low-boiling point fatty acid material,
while the third column completes the separation  cf  fatty  and  rosin
acids.

The  wastewater  generated  in this subcategory results from pulling a
vacuum on the distillation towers.  This water generally is  recycled,
but excess water is discharged to the plant sewer.

Essential oils

Figure  III-4  is  a  typical process flow schematic diagram for steam
distillation of cedarwood oil from scrap wood fines of red cedar.

Paw dry dust from the planing mill and raw grain dust from the sawmill
are mixed to obtain a desired blend  and  then  fed  pneumatically  to
mechanical  cyclone  separators  located  on  top of the retorts.  The
cedarwood oil is  extracted  by  injecting  steam  directly  into  the
retort.   The  steam diffuses through the cedarwocd dust, extracts the
oil of cedarwood, exits through the top of the retort,  and  condenses
to  an  oil/water  mixture.  Following the steam extraction, the spent
sawdust cools.  It is then stored and eventually sent to the boiler as
a fuel.

The primary product is a crude light oil which  is  separated  by  two
oil/water  separators  immediately  downstream of the condensers.  The
light oil is removed and mixed with clay which lightens the product by
removing color bodies and stabilizes  the  color  cf  the  product  by
inhibiting further oxidation.   The clay/oil slurry is filtered through
plate  and frame filter presses, and the spent clay-filter material is
hauled to landfill for final  disposal.   The  lightened  oil  product
proceeds  to  bulk  storage  and  blending, and is finally drummed for
shipment.

The water phase, which is separated  in  the  stillwells,  contains  a
heavy  red crude oil.  This material is separated from the water phase
in  three  consecutive  settling  tanks.    The  heavy   red   oil   is
periodically  removed  and drummed for sale as a by-product, while the
underflow, or remaining water phase, is discharged as wastewater.
                                 35

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Bosin Derivatives

Figure III-5 illustrates a typical rosin  derivative process.   Process
operating   conditions  in  the   reaction kettle  depend  on  product
specifications, raw materials, and ether  variables.  A simple ester is
produced from stump wood rosin  (WW grade)  and  U.S.P.  glycerin  under
high-temperature  vacuum conditions.  A steam  sparge  (lasting approxi-
mately 2-3 hours) removes excess  water of esterification; this  allows
coirpletion  of  the  reaction  and   removes  fatty acid impurities for
compliance with product specifications.    The  condensable  impurities
are  condensed in a non-contact condenser on the vacuum leg and stored
in a receiver.  Non-condensables  escape tc the atmosphere through  the
reflux  vent  and  steam  vacuum  jets.    The  production of phenol and
maleic anhydride modified tall oil resin  ester is  similar  to  simple
rosin  ester production except that  steam sparging is seldom, if ever,
used; and other  polyhydric  alcohols  may be used  in  the  product
formulation.

Wastewater  comes  from  the chemical reaction, separation of product,
and wash down of reaction vessels.

Sulfate Turpentine

Figure  III-6  is  a  simple  process  flow  schematic   diagram   for
distillation of sulfate turpentine, which  is condensed from the relief
gas   from   the  digestor  of  the  Kraft pulping  process.   During
distillation, the first tower usually strips   odor-causing  mercaptans
from  the  turpentine.  Subsequent fractionation breaks the turpentine
into its major components:  alpha-pinene,  beta-pinene, dipentene,  and
sulfated  pine  oil.  Minor components include limonene, camphene, and
anethol.

The distillation of sulfate turpentine is  an   intermediate  production
step.    Some  of  these  turpentine  components  are  marketed  after
distillation, but the majority of them remain  in the plant for further
processing.

The operations are usually batch reactions that take place in reaction
kettles in the presence of some organic solvent  and  metal  catalyst.
The  selection  of  catalysts  and  solvents   depends  on  the desired
products, of which there are approximately 200.

Wastewater usually is generated from the condensation in the distilla-
tion tower and from wash down of reactors.
                                 37

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                              SECtlON IV

                     INDUSTRIAL SUECATEGORIZATICN

Review of existing industrial subcategorizaticn fcr the Gum  and  Wood
Chemicals  Industry  required  a  determination  cf whether sufficient
differences  exist  within  the  industry  to  support   the   current
subcategorization  scheme, or whether modifications are required.  The
rationale for subcategorization is based upon such  factors  as:    (1)
plant    characteristics    and    raw   materials;    (2)   wastewater
characteristics,  including  toxic  pollutant   characteristics;    (3)
manufacturing  processes;  and   (4)  applicable  methods cf wastewater
treatment and disposal.

In developing the previously published effluent limitation  guidelines
and  pretreatment  standards  for  the  industry,  EPA determined that
plants  exhibited   sufficient   differences   to   justify   multiple
subcategorization.  That subcategorization was as follows:

1.  Char and charcoal briquets;

2.  Gum rosin and gum turpentine;

3.  Wood rosin, turpentine, and pine oil;

4.  Tall oil rosin, pitch, and fatty acids;

5,  Essential oils; and

6.  Rosin derivatives.

The  subcategorization  review  confirmed the above subcategories were
appropriate, except that a seventh  subcategory,  Sulfate  Turpentine,
should be included.

SUECATEGORIZATION REVIEW

The  Agency  considered the following factors in the subcategorization
review:

1.  Manufacturing process;

2.  Plant location and climate;

3,  Raw materials;


4.  Plant age,  size,  and flow;

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5.  Products;  and

6.  Wastewater characteristics and treatability.

Manufacturing Process

The process step common to gum, weed,  tall  oil  chemical,  essential
oils,   and   sulfate  turpentine  production  is  the  use  of  steam
distillation to separate the major constituents.   However, there is  a
large  difference  in  the  degree  of  technology  used  in  the five
processes.  Wood, rosin, tall oil chemicals,  and  sulfate  turpentine
use  fractionation  towers  for multi-product separation.  The gum and
essential oil  subcategories  use  simple  reactors  to  separate  the
volatile from the non-volatile components.

The  production  of  charcoal and rosin-based derivatives differs from
the other processes because steam distillation is not employed.  Char-
coal is a destructive distillation product of wood.  The production of
rosin-based  derivatives  is  not  a  distillation  but   a   chemical
modification.   For some reactions, a catalyst is employed.  The Agency
has determined that these distinct manufacturing processes are a basis
for subcategorization.

Plant Location and Climate

The  1972  Census  of Manufacturers places the majority of the gum and
wood chemicals production  facilities  in  the  southern  states   (see
Figures  IV-1 and IV-2).  These plants produced over 84 percent of the
industry output in terms of dollar value added to the raw material.

Plant location and local climate can affect the performance of certain
end-of-pipe wastewater treatment systems, e.g.,  aerated  lagoons  and
activated  sludge.   However,  treatment  systems including biological
treatment, can be adapted to the sirall variation in climate  found  in
the  Gum  and Wood Chemicals Industry.  Plant location and climate are
not criteria for subcategorization because of the general southeastern
location of the plants and the adaptability of the  treatment  systems
to climatic conditions.
                                  42

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 Raw Materials
 The  basic
 follows:

 Pr cduct
raw materials for each of the product subcategories are as
 Char  and
 Charcoal Briquets

 Gum Rosin  and
 Turpentine
          Raw Material Source
              Hardwood and softwood scraps
 Wood Rosin, Turpentine,
 and Pine Oil

 Tall Oil Rosin, Pitch,
 and Fatty Acids

 Essential Oils
Rosin Derivatives
Sulfate Turpentine
              Crude "gum" oleoresin from the
              sapwood of living trees

              Wood stumps and other resinous woods
              from cut over forest

              By-product crude tall oil
              from the Kraft process

              Scrap wood fines, twigs, barks, or roots
              of select woods or plants

              Rosin products from gum, wood, and
              tall oil chemicals

              Low boiling vapors condensed frcir
              the Kraft pulping of pine wood
Variations in raw materials within each  subcategcry  do  occur.   For
example,  seasonal  changes can change crude gum composition.  Late in
the growing season,  crude  gum  is  termed  scrape,  which  generally
contains  less  turpentine  and  more  rosin.  Where variations in raw-
materials require additional processing to  achieve  product  quality,
additional wastes are generated.

Because  of these factors, the Agency concluded that raw materials are
a  basis  for  subcategorization.   Variations   in   raw   wastewater
generation  due  to  seasonal changes are reflected in the analysis of
long term wastewater characteristics and were determined not to  be  a
factor requiring further subcategorization.

Plant Age

Manufacturers  continuously upgrade and modernize their operations and
equipment as it becomes necessary, thus the actual age  of  production
facilities  cannot  be determined accurately.   Furthermore,  the age of
the equipment  does  not  necessarily  affect  wastewater  generation.
Operation and maintenance of the equipment are more important factors.
Therefore, plant age in itself is net a basis for subcategorization.

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Plant Size and Flows

Operations   in  gum  and  wood  chemicals  manufacturing  range  from
intermittent batch operations operated by a handful of  personnel,  to
large   complexes   which   employ  hundreds.   Water  use  management
techniques are affected by economy of scale, as well as  such  factors
as  geographical  location.  On the ether hand, smaller operations may
have waste treatment and disposal options,  such  as  retention,  land
spreading,  and  trucking to landfill, that are impractical for large-
scale operations.

The volume of wastewater produced by the plants in the  Gum  and  Wood
Chemicals  Industry ranges from 9 to 7,570 cubic meters per day (2,300
to  2,000,000  gallons  per  day).   Discharge  flow  rates  for  each
sufccategory  are  difficult  to  quantify  because  most  plants  have
combined processes that fall under  several  different  subcategories,
and  all process wastewater typically is discharged to a common sewer.
Although total plant flow can be determined from this discharge  pipe,
a  breakdown into components from each process is net possible.  Table
IV-1 tabulates wastewater  flows  for  each  plant,  and  groups  them
according to the processes within the plant.

Plant   size  does  not  appear  tc  affect  wastewater  quantity  and
characteristics;  therefore,  plant  size   is   not   a   basis   for
subcategorization.

Product

The  major  products  of  the  Gum  and Wood Chemicals Industry differ
significantly as discussed in Section III.  Therefore, product type is
a  basis for subcategorization.

Wastewater Characteristics and Treatability

The physical characteristics of the wastewater from the Gum  and  Wood
Chemicals  plants are similar.  The raw wastewaters have  floating oils
and emulsified oils; the organic components  of the wastewater   include
turpenes,  natural  components  of  the. wood,  and  various solvents.
Metals are used  as  catalysts in two subcategories in the  Gum and  Wood
Chemicals  Industry.  The type of manufacturing process determines the
type of metals found in the waste stream.

The  Gum  and  Wood Chemicals  wastewater   streams  are   amenable  to
biological  treatment, which is the major  treatment method now  used by
the direct discharging plants.  Moreover, where  iretals   are   used  as
catalysts,    they   are    subcategcry    specific.     The  wastewater
characteristics  and treatability themselves  do not  support the  use  of
this as a criterion for further subcategorization.

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POTENTIAL SUBCATEGORIES

Consideration  of the plant characteristics, raw materials, wastewater
volume,  wastewater  characteristics,  manufacturing  processes,   and
wastewater  treatment  and  disposal  methods  current in the industry
confirms the existing subcategorization of the Gum and Wood  Chemicals
Industry and adds the sulfate turpentine subcategory.
                                 47

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           Table IV-1.   Tabulated Wastewater Flows by Plant
Subcate-
gories
G
G,F
G,C,F
G,D,F
E,F
C
C,F
D,F
D
Plant
No.
009
885
159
571
222
743
993
485
934
242
334
244
714
660
454
040
049
759
436
590
Type
Discharge
Indirect
Indirect
Direct
Indirect
Indirect
Direct
*
Indirect
Direct
Direct
Direct
Direct
*
Indirect
*
*
*
Direct
Direct
*
Production
Ibs/day
126,900
190,000
99,715
480,000
1,023,000
460,000
1,028,000
100,000
106,000
740,000
438,000
306,000
422,900
152,300
675,000
499,000
595,000
360,000
335,000
425,000
Wastewater
Flow (GPD)
72,000
325,000
1,180,000
580,000
463,000
180,000
1,011,000
5,000
155,000
1,930,000
800,000
168,000
533,000
49,100
118,000
900,000
352,000
41,760
600,000
260,000
B = Gum rosin and turpentine
C = Wood rosin, turpentine, and pine oil.
D = Tall oil rosin, pitch,  and fatty acid.
F = Rosin- and turpene-based derivatives.
G = Sulfate turpentine.

* Plant discharges into the waste stream of another plant
                                 48

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                              SECTION  V

                       WASTEWATER  CHARACTERISTICS

 GENERAL

 This   section    defines   the  plants wastewater  quality  -in   those
 subcategories identified in  Section  IV.   Raw waste  load  (RWL)  data  are
 also  presented   for   some  plants which   produce   in  more  than  one
 subcategory  or   process flows that  produce data extending across more
 than  one  subcategory.  Raw waste  load  data are  for both  traditional
 parameters and for toxic pollutants  for each subcategory.

 The   term "raw   waste load," as used in this document, refers to  the
 quantity  of  a pollutant in wastewater  prior to  a   treatment   process.
 Where treatment processes are designed primarily to recover raw  mate-
 rials from   the   wastewater  stream,   raw waste  loads  are   obtained
 following these  processes.   An example is the use cf gravity oil-water
 separators   which  remove the surface  oils for reprocessing or recover
 them  for  fuel value.

 For purposes of  cost  analysis only,  EPA has defined representative  raw
 waste characteristics  for  each   subcategcry  in  crder  to  establish
 design parameters for  model  plants.

 The   data in  this   document  represent  a summary  of the most current
 information  available  from each contacted plant.   Sampling   data  in
 most  cases  are the  sole source of qualitative information for  toxic
 pollutant raw waste loads.

 Exclusion Under  Paragraph £

 EPA   has  submitted  three   of  the  seven Gum  and   Wood   Chemical
 subcategories  for  exclusion under paragraph 8 of  the NRCC Settlement
 Agreement.  These subcategories are char   and  charcoal  briquet,   gum
 rosin  and   turpentine,  and  essential  oil.   Appendix  C  is  the
 recommendation package containing the  rationale for the  exclusion  of
 these subcategories.

E2°<1 Rosin, Turpentine, and  Pine  Gil

 Five  plants  process  wood  stumps  fcr their extractable components.
Only  one plant has segregated wood rosin waste streams;  the other four
plants have multi-process waste streams.    The  multi-process  streams
could not be used to characterize the wastewater from the subcategory.

Table  V-1  shows the analytical results of sampling conducted at this
plant.  Levels for methylene chloride and benzene in the ground  water
are  unusually  high  and may indicate contamination of  the sample for

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Table V-l.  Sample Analysis, Plant 464
Parameters . 1757
ug/1
Me thy lane
Chloride 910
Chloroform 20
Ethylbenzene
Toluene
Arsenic
Copper
Chromium
Lead
Zinc
Total Phenols 120
Suspended
Solids (mg/1)
COD.(mg/l) 11
BOD (mg/1)
Oil & Grease (mg/1)
1758
190

50
Ind.

33
1500
15
160
460
240
1200
1500

1759
560
10
10
>400


980
17
89
980
220
1100
650

8676 1760 8678
Blank
NA 260 NA
NA 30 NA
NA NA
NA >400 NA
15 14 17

620
13
29 150 46
10
160
730
270
18
1761 8190 8187 8677
Blank
260 430 340 280


10
22 12
16 21
92 130 110

49 29 32 56
30 140
48 70 48
110 230 340
27 25 13
12
 Values of <10 ug/1 have not been included.
 Blank values have not been subtracted.
 Ind.—Indeterminate because of high organic compound loading.
 NA—Not analyzed.
                                    50

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Table V-lA.  Sample Numbers, Plant 464
     1757

     1758

     1759


     1760

     1761


     8190


     8187
Process make-up water—well water

Wastewater influent to equalization basin

Wastewater effluent from equalization basin of
  approximately 15-day retention

Wastewater effluent from ash settling basin

Final wastewater effluent after aerated lagoon
  and settling

Final wast.ewater effluent after aerated lagoon
  and settling

Final wastewater effluent after aerated lagoon
  and settling
     8676, 8678, 8677    Blanks
                                  51

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these two compounds.  As shown in the analysis, toluene is  the  irajor
organic toxic pollutant contained in the wastestream.

Toluene  is  the extractive solvent in the production process and this
explains its presence in the  wastestream.   For  removal  of  toluene
concentrations  below  10  mg/1,  biological  treatment  is  the least
expensive  method.   Table  V-1  clearly  shows  a  reduction  from  a
concentration  greater  than 400 ug/1 to a concentration of 10 ug/1 or
less.  Benzene  and  ethylbenzene  are  trace  contaminants  found  in
industrial  grade toluene.  These compounds appeared in concentrations
of 200 and 50 ug/1  in  the  raw  process  wastestream  but  were  not
detected in the discharge effluent.  These compounds are also amenable
to  biological  treatment,  which  this  plant  provides  by use of an
aerated lagoon and a settling basin.  This plant also employs a unique
pretreatment procedure of mixing wood ash from  the  boiler  with  the
equalized  wastewater.   The  wastewater with ash is allowed to settle
and  is  then  sent  to  the  biological  treatment.   The  adsorption
characteristics of the wood ash have not been determined.

The  major inorganic toxic pollutants for this plant were chromium and
zinc.  Chromium in the raw wastewater, as shown in Table V-1, was 1500
ug/1, and decreased to approximately 100 ug/1 in the treated effluent.
Zinc was reduced through the treatment system, frcm 160  ug/1  in  the
raw  wastewater to approximately 30 ug/1 in the treated effluent.  The
other metals occurred at concentrations of less than 20 ug/1.

Tall Oil, Rosin, Pitch, and Fatty flcids

Of the twelve tall oil distillation plants currently in the  industry,
three   perform  only  tall  oil  distillation  and  some  rosin  size
operations.  One of these plants (Plant 949)  was  sampled  during  the
sampling  program,  and  the results of that sampling are presented in
Table V-2.   The nine other tall oil distillation plants have  combined
processes  which  make  them  unsuitable  for characterizing the waste
streams.

The plant's makeup water comes from wells located on  plant  property.
The  analysis  of  the  well water showed high concentration levels of
methylene chloride (710 ug/1)  and also concentrations of benzene  (120
ug/1)  and toluene (20 ug/1),  These are unusually high levels of these
compounds for well water and may be due to sample contamination.   This
plant  is  the  only  plant  in  the industry that recycles all of its
barometric condenser water from the  tall  oil  fractionaticn  towers.
Sample  Number  8186  presents an analysis of this recycled barometric
condenser water.   Phenol was the major toxic pollutant found  in  this
waste   stream.     The   concentration   level  was  7.5  mg/1.    This
concentration may be due to a high equilibrium  concentration  of  the
recycled wastewater.
                                 52

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Table V-2.  Sample Analysis, Plant 949
Parameters
ug/1
Methylene
Chloride
Chloroform
Benzene
Ethylbenzene
Toluene
Phenol
Copper
Chromium
Lead
Nickel
Selenium
Zinc
Total Phenols
Suspended
Solids (mg/1)
COD (mg/1)
BOD (mg/1)
Oil & Grease
(mg/1)
8182 1718
740 710
10 10
120 120
20
20 20

150
110 83
14
13 19
11
50
550
44
1100
42
48
8675 8184
Blank
30 780
10
110
10
50

16 230
85 97

20 24

70 27
100
15
160
12

8186
210

30

70
7500
300
280
26
66

80
1700
170
8400
176
167
1735
850
10
120

20

220
88

43

44
29
19
130

13
8684
Blank






280
100

14







Values of <10 ug/1 have not been included.
Blank values have not been subtracted.
                                     53

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Table V-2A.
Sample Numbers, Plant 949
Sample Numbers



     8182



     1718



     8184



     8186



     1735
Process make-up water—well water



Raw effluent



Effluent after initial settling



Barometric condenser closed system



Treated effluent
                                  54

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Aerated lagoons are used in this plant to provide biological treatment
of  the  wastewater,  supplemented  by  the use of alum coagulation to
enhance settling of emulsified oils.

Sulfate Turpentine

There are seven U.S. plants which fractionate sulfate turpentine.  The
Agency sampled four of these plants.  Tables V-3 through V-5A show the
results.  Two of the  sampled  plants  have  waste  streairs  that  are
combined  with  effluents  from  ether processing areas.  Under normal
circumstances,  the  products  of  sulfate  turpentine  fraction   are
chemical  intermediates  used  in  ether  processing steps.  The major
products of fraction are a-pinene, b-pinene, dipintene, camphene,  and
pine  oil.  The final products of these intermediaries are "synthetic"
pine oil, poly-turpene resins, insecticides, fragrances, and sizes.

Plants  337  and  610  produce  fragrances  and  Plant  065   produces
polyturpene  resins  and  turpene  specialty  products.  The  sampling
results for Plants 337 and 610 appear in Tables V-3 and V-4.

The volatile organic toxic pollutants are toluene in concentrations of
approximately 2 mg/1 and benzene in the concentration range of 50 ug/1
to 220 ug/1.  Chloroform was found in concentrations of 1 mg/1 to  1.4
mg/1 in Plant 337, but was not fcund in Plant 610.  Methylene chloride
appeared  in  well water supplies cf both plants, which may indicate a
contamination problem.

The significant non-volatile organics were phenol at  a  concentration
of  700  to  850  ug/1 at Plant 337 and bis(2-ethylhexyl) phthalate at
Plant 610 at a concentration of 1,900 ug/1 after biological treatment.
Phenol  is  a  natural  component  of  wocd.   The   bis (2-ethylhexyl)
phthalate  is not used in the processes of Plant 610 and was not found
in the raw effluent.  It was detected in only one sample cut of  three
and may be either a contaminant cr a result of the treatment process.

The  major  inorganic  toxic  pollutants are copper, nickel, and zinc.
These three metals are common catalysts in the gum and wood  chemicals
industry.    Copper  was  found  IE concentrations as high as 4.5 mg/1,
nickel as high as 1.1 mg/1, and zinc at 2.4 mg/1.

The waste stream from Plant 065 differs greatly from  that  of  Plants
337  and 610.   Much higher concentrations cf volatile organic solvents
occur in this process waste stream than in  those  of  the  other  two
plants.    Toluene  was found to be as high as 40 mg/1 and ethylbenzene
concentrations as high as 67 mg/1.   Phenol was found in concentrations
cf 1.1  mg/1, and bis (2-ethylhexyl)  phthalate at a concentration  of  3
mg/1.   Table V-5 shews the results of the sample analysis.
                                 55

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Table V-3.  Sample Analysis, Plant 337
Parameters
ug/1
Methylene
Chloride
Chloroform
Benzene
Toluene
Phenol
Arsenic
Copper
Chromium
Lead
Nickel
Zinc
Total Phenols
Suspended
Solids (mg/1)
COD (mg/1)
BOD (mg/1)
Oil & Grease
(mg/1)
801 802
400 450
1000
74

760
35
1800
1300

520
170
28 1600
60
18 6400
3400
354
804
740
1400

2200
130
43
6000
760
21
4100
530
1000

7300
3200
407
1745 743
Blank

980

1000

59 12
2700 32
580
12
3000
300 29
960
18
5400
2200
284
803
490
900
120
1900
850
35
2700
880

180
99
2600
36
6400
3900
485
805
2100
1400
240
2000

120
3100
850
13
700
430
1300
32
7400
4800
506
1753
980
1000
210
1100

73
1800
480

1100
260
1000
30
5800
2500
450
742
Blank
360

70







32





 Values of <10 ug/1 have not been included
 Blank values have not been subtracted.
                                    56

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Table V-3A.  Sample Numbers, Plant 337
     801                        Process make-up water

     802, 804, 1745             Process effluent  after  skimming and
                                   initial  settling

     803, 805, 1753             Final  effluent
                           57

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Table  V-4.   Sample Analysis, Plant 610
Parameters 705
ug/1
Methylene
Chloride 560
Benzene
Toluene
Bis(2-ethylhexyl)
phthalate
Arsenic
Copper 250
Chromium 120
Lead
Nickel 36
Selenium
Zinc
Total Phenols 18
Suspended
Solids (mg/lj
COD (mg/1) 16
BOD (mg/1)
Oil & Grease
(mg/1)
708
16000




2700
510
13
220

200
1300
300
15000
1200

450
710 726
3200 650
140
2100 920

110
1700 1600
49 51
11
160 140

290 240
4500 530
240 180
7900 7500
1200 2000

260 160
8667 723
Blank
NA 1700
NA
NA
1900

190 4700
36 250
14
13 46
19
30 320
14000
520
5600
590

49
703
1900
210
170


1900
94
19
310

450
2000
470
3800
400

74
711
2400




2300
100
14
340

320
1600
280
4600
330

300
8666
Blank
300




220
16

16

30






Values of <10 ug/1 have not been included.
Blank values have not been subtracted.
                                58

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Table V-4A.  Sample Numbers, Plant 610
     705                         Process make-up  water—well  water




     708, 710,  726               Raw process  effluent




     723, 703,  711               Final  treated effluent




     8667,  8666                 Blanks
                           59

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Table V-5.  Sample Analysis, Plant 065—Turpene Sump
Parameter (ug/1
Methylene Chloride
Chloroform
1,1,1-Trichloroethane
Benzene
Ethylbenzene
Toluene
Phenol
Bis(2-ethylhexyl)
Phthalate
Arsenic
Copper
Chromium
Lead
Nickel
Zinc
Total Phenols
Suspended Solids (mg/1)
COD (mg/1)
BOD (mg/1)
Oil & Grease (mg/1)
1747
2000
320

180
67000
4300
150

20
100
130
57
66
680
2000
200
15000
4500
14
1751
2400
1000
640
Ind.
Ind.
>40000



180
190

130
810
970
190
19000
4800
1800
1755
510
80

90
6600
730
1100
3000
17
33
130
27
120
320
6000
170
7000
960
670
8668
Blank
52


60




11




39





Values of <10 ug/1 have not been  included.
Blank values have not been subtracted.
Ind.—Indeterminate because of high organic compound  loading.
                           80

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Table V-5A.  Sample Numbers, Plant 065
     1747                Turpene sump, first day




     1751                Turpene sump, second day




     1755                Turpene sump, third day




     8668                Blank
                             61

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Rosin Derivatives

Rosin  derivatives  are  a  major  product  within  the  Gum  and Wood
Chemicals Industry.  These products are net classified under SIC  Code
2861,  but  rather  under  SIC  CCDE 2821  (rosin-raodifed resins).  The
Agency determined that these products should fce covered under Guir  and
Wocd  Chemicals  as  long as they were directly related tc the Gum and
Wood Chemicals plants in SIC code 2861.

EPA selected Plant 097 for sampling because  it  separated  the  rosin
derivatives  process  wastewater  frcm ether waste streams.  The rosin
derivatives subcategory has a diverse product line, however, and these
results may not characterize all resin  derivatives  operations.   The
results of the verification analyses appear in Table V-6.

The  major  toxic  pollutants  in  this  subcategory  are  the organic
solvents.  Toluene  is  a  standard  solvent  used  in  the  industry.
Ethylbenzene  is  not  used  in  the  plant  specifically,  but  is  a
contaminant of the industrial grade xylene which the plant uses in its
process.

The only non-volatile organic found in sampling was phenol.  High con-
centrations of phencl  (23  mg/1)   were  present  because  this  plant
produces a phenolic resin.

Zinc  is  a  common  catalyst used in the industry and the high levels
were not unexpected.

The  consistently  high  levels  of  methylene  chloride   suggest   a
contamination  problem  because it is net used in the plant processes.
Its presence could not be explained  by  the  plant's  raw  materials,
production process, or through interviews with plant personnel.
                                 62

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Table V-6.  Sample Analysis, Plant 097—Rosin Derivatives Process
Parameter (ug/1
Chloroethane
Methylene Chloride
1,1, 1-Trichloroethane
Benzene
Ethylbenzene
Toluene
Phenol
Arsenic
Cadmium
Copper
Chromium
Lead
Nickel
Zinc
Total Phenols
Suspended Solids (mg/1)
COD (mg/1)
BOD (mg/1)
Oil & Grease (mg/1)
730

2700


12000
17000
>10620
41
95
300
48
54
100
38000
41000
71
31000
1260
92
706

7300
830
170
2200
5300
14000
53
120
180
62
72
34
38000
46000
87
40000
450
146
737 2694
Blank
520
6700 630

710
28000
>4000
23000

100
190
34
49
35
38000
53000
70
38000

62
 Values of <10 ug/1 have not been included.
 Blank values have not been subtracted.
                          63

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Table V-6A.  Sample Numbers, Plant 097
     730                 Resin plant effluent,  first day




     706                 Resin plant effluent,  second  day




     737                 Resin plant effluent,  third day




     2694                Blank
                              64

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                              SECTION VI

                  SELECTION OF POLLUTANT PARAMETERS

KASTEWATER PARAMETERS OF SIGNIFICANCE

A thorough analysis of the literature, industry data and  sampling data
obtained  from  this  study  and EFA permit data  demonstrates that the
following wastewater parameters are of significance  in   the  gum  and
wood chemicals industry:

Conventional and Nonconventional Pollutant Parameters

     Biochemical Oxygen Demand (5-day, 20 degrees C., BOD5)
     Total Suspended Solids  (TSS)
     pH

Toxic Pollutants

     Organics
          Volatile
          Semi-Volatile
               Basic/Neutral Fraction
               Acidic Fraction

     Inorganics
          Metals

CQNVENTIONALE AND NONCONVENTIONAL POLLUTANT PARAMETERS

Biochemical Oxygen Demand (BOD)

Biochemical  oxygen  demand is the quantity of oxygen required for the
biological  and  chemical  oxidation  of  waterborn  substances  under
ambient  or test conditions.  Material which may contribute to the BOD
include:  carbonaceous organic materials usable as a  food  source  by
aerobic organisms; cxidizaBle nitrogen derived from nitrites, ammonia,
and  organic  nitrogen  compounds  which  serve  as  food for specific
bacteria; and certain chemically oxidizable materials such as  ferrous
ircn,  sulfides, sulfite, etc.,  which will react with dissolved oxygen
or which are metabolized by bacteria.

In the gum and wood chemicals wastewaters, the BOD derives principally
from organic materials, such as  fatty acids and resins.

The BOD of a waste adversely affects the dissolved oxygen resources of
a body of water by reducing the  oxygen available to fish, plant  life,
and  other  aquatic species.   It  is possible to reach conditions which
totally exhaust the  dissolved  oxygen  in  the  water,   resulting  in
                                 65

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anaerobic  conditions' and the production of undersirable gases such as
hydrogen sulfide and methane.   The reduction of dissolved  oxygen  can
be  detrimental  to  fish populations, fish growth rate, and organisms
used as fish food.   A total lack of oxygen due to  excessive  BOD  can
result in the death of all aerobic aquatic inhabitants in the affected
area.

Water  with  a  high BOD indicates the presence of decomposing organic
matter and associated increased bacterial concentrations that  degrade
its   quality   and   potential   uses.    High  EOD  increases  algal
concentrations and blooms; these result from decaying  organic  matter
and form the basis of algal populations.

The  BOD5   (5-day  EOD)  test  is  used  widely to estimate the oxygen
requirements of discharged domestic and industrial  wastes.   Complete
biochemical  oxidation  of  a  given  waste  may  require  a period of
incubation too long for practical analytical test purposes.  For  this
reason,  the  5-day period has been accepted as standard, and the test
results have been designated as BOD5.  Specific chemical test  methods
are   not  readily  available  for  measuring  the  quantity  of  many
degradable substances and their reaction  products.   In  such  cases,
testing  relies  on  the  collective  parameter, ECD5.  This procedure
measures the weight of dissolved oxygen utilized by microorganisms  as
they  oxidize  or transform the gross mixture of chemical compounds in
the wastewater.  The biochemical reactions involved in  the  oxidation
of  carbon  compounds are related to the period of incubation.  The 5-
day BOD normally measures only 60 to 80 percent  of  the  carbonaceous
biochemical oxygen demand of the sample, and for many purposes this is
a  reasonable parameter.  Additionally, it can be used to estimate the
gross quantity of oxidizable organic matter.

Total Suspended Solids  (TSS)

Suspended solids include both organic and  inorganic  materials.   The
inorganic  compounds  include sand, silt, clay, and toxic metals.  The
organic fraction includes such materials as grease,  oil,  animal  and
vegetable  waste  products,  and  adsorbed  toxic  organic pollutants.
These solids may settle out rapidly and bottom deposits  are  often   a
mixture of  both organic and inorganic solids,  solids may be suspended
in  water for a time and then settle to the bed of the  stream or lake.
They  may   be  inert,  slowly  biodegradable  materials,  or   rapidly
decomposable  substances.   While  in   suspension  they  increase  the
turbidity of the water,  reduce  light  penetration,  and  impair  the
phctosynthetic activity of aquatic plants.

Aside  from any toxic  effect attributable to substances  leached out by
water, suspended  solids  may  kill  fish  and  shellfish  by  causing
abrasive    injuries,   by  clogging  gills  and  respiratory  passages
screening out light, and by promoting and maintaining the  development
                                  66

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 of  noxious  conditions  through oxygen  depletion.   Suspended  solids  also
 reduce  the  recreational value of  the  water.
£H,   Although  not  a  specific pollutant,  pH is related tc the acidity
or alkalinity of a wastewater stream.   It  is not  a   linear  or   direct
measure  of  either;   however, it  way  properly be used tc control  both
excess acidity  and excess alkalinity in water.  The  term pH  describes
the   hydrogen   ion — hydroxyl ion balance in water.   Technically, pH is
the   hydrogen   ion  concentration  or   activity   present  in  a  given
solution.   pH  numbers are the negative logarithm of the hydrogen ion
concentration.  A pH of 7 generally indicates neutrality or a  balance
between  free   hydrogen  and  free hydroxyl ions.  Solutions with  a pH
above 7 indicate that  the solution is  alkaline, while  a  pH  below  7
indicates that  the solution is acidic.

Knowledge  of   the  pH of  water  or   wastewater  aids in determining
measures necessary  for  corrosion control,  pollution  control,  and
disinfection.    To    protect   POTW   from  corrosion,  pH  levels  of
wastewaters entering the sewerage  system must remain above 5.   Waters
with  a pH below 6,0 corrode waterworks  structures, distribution lines,
and   household plumbing  fixtures.    This  corrosion  can  add   such
constituents to drinking water as  iron,  copper,  zinc,  cadmium,  and
lead.   Low pH  waters  not only tend to  dissolve metals from structures
and fixtures, but also tend to redissolve or leach metals from sludges
and bottom sediments.  The hydrogen ion concentration also can  affect
the taste of water; at a low pH, water  tastes "sour."

Extremes  of  pH  or rapid pH changes can stress cr  kill aquatic life.
Even moderate changes  from  "acceptable"  pH  limits  can  harm  some
species.   Changes  in  water  pH  increase  the relative toxicity* to
aquatic life of many materials.   Metalccyanide complexes can  increase
a thousand-fold in toxicity with a drop of 1.5 pH units.   The toxicity
of  ammonia similarly  is a function of  pH.  The bactericidal effect of
chlorine in most  cases  lessens   as  the  pH  increases,  and  it  is
economically advantageous to keep  the pH close to 7.

The  lacrimal fluid of the human eye has a pH of approximately 7.0 and
a deviation of  0.1 pH unit  from   the  norm  may  irritate  the  eyes;
appreciable irritation will cause  severe pain,

Wastewater  pH  values  below  6.0  can  magnify  problems of hydrogen
sulfide gas evolution and poor metals removal.    Cn  the   ether  hand,
unusually  high  pH  (for instance 11.0) can cause significant loss of
active biomass in biological treatment systems,   especially   activated
sludge.
                                 67

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TOXIC POLLUTANTS

The  129  toxic  pollutants  are  divided  into  three  major  groups:
organics, pesticides and  PCB's,  and  inorganics.   Toxic  pollutants
detected  in  gum and wood chemicals wastes are discussed on the basis
of these three groups.

Tables VI-3 and VI-4 present information on the  molecular  structure,
number   of  plants  where  identified,  concentration  range  in  the
wastewater, and, wherever possible, a brief description of the gum and
wood chemical industry uses of these compounds.

Organic Toxic Pollutants

Several of the organic toxic pollutants appeared in the gum  and  wood
chemical  wastewaters at concentrations of 10 ppb cr higher.  Crganics
are classified by the physical-chemical properties which permit  GC/MS
analysis  of  these  materials.   The crganic toxic pollutants include
compounds in a volatile fraction, a basic or neutral fraction, and  an
acidic fraction.

Volatile  Fraction.   Table VI-3 summarizes the volatile crganic toxic
pollutants identified  in  the  gum  and  wood  chemical  wastewaters.
Frequency   of  identification  and  concentration  ranges  for  these
compounds also are summarized along-with information on  common  uses.
Nine  organic  pollutants  were  found  at  least  once in the sampled
ef fluents.

*The term toxic or toxicity is used herein in  the  normal  scientific
sense of the word, not the legal.

Benzene  appeared  in  raw effluents in levels ranging up to 3800 ppb,
and in concentrations up to 270 ppb in treated effluents.  Eenzene  is
not  a  major  process  raw  material  in  the  gum and wood chemicals
industry.  It is, however, a contaminant of toulene, which is a  major
solvent used in the industry.

The EPA proposed water quality criterion to protect freshwater aquatic
life  from  the  toxic  effects  of benzene is 3,100 ug/1 as a 24 hour
average; the  concentration  should  never  exceed  7,000  ug/1.   For
saltwater  aquatic  life,  the 24 hour average and maximum permissible
concentrations are 920 ug/1 and  2,100 ug/1, respectively.

Eenzene  is a suspected human carcinogen.  Studies  of  the   effect  of
benzene  vapors  on   humans  indicate  a  relationship between chronic
benzene poisoning and a high  incidence  of  leukemia.   There   is  no
recognized  safe concentration  for  a human carcinogen; for the maximum
protection of human health from  the potential  carcinogenic   effect  of
benezene   exposure through ingestion of water  and contaminated aquatic
                                  68

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Table VI-1.  Screening Sample Results for Halomethanes
Plant
Sample
                                          Concentration ug/1
Methylene
 Chloride
Chloroform
 868
 055
 723
  013
  001
  0722
  0728
  2290-B

  8182
  1718
  8184
  8186
  1735
  8675-B

  0705
  0708
  0723
  8666-B

   714
   724
   730
   707
  2694-B

  1710

  3150
  1720

  1714
  8670-B
   -108
   >341
   >568

    710
    680
    750
    180
    820
     30

    260
  15,700
   1,400
    300

    -20
     40
   2070
   1270
    630

   -1100

   -200
   -480

   -720
   1300
      0
      0
     10

     10
     10
     10

     10
     10
                                                              10
                             69

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Table VI-2.  Screening Sample Results  for Aromatic Solvents
                                            	Concentration ug/1
Plant        Sample #        Benzene        Toluene      Ethylbenzene
868


0720
0728
2290-B
90
>64
140
0
20
20
 055           8182             120             20
               1718             120             20
               8184             110             50
               8186             30             70
               1735             120             20
               8675-B

 723           0705
               0708
               0723
               8666-B

 086            714             110             20
                724             140             100
                730                         17,000           12,000
                707                                          2,700
               2694-B

               1710             20             10

 001           3150          >1110           >1220
               1720            >131             180

               1714             590            2500
               8670-B
                            70

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organisms, the Agency recommends an  ambient  water  concentration  of
zero,
Dichloromethane,  also  known  as methylene chloride, was found in the
raw, primary, and secondary effluents of a number of plants. It  as  a
common  solvent;  found  in  insecticides;  and  is  used  also  as  a
degreasing and cleaning liquid.

The proposed criterion to protect freshwater  aquatic  life  is  4,000
ug/1 as a 24 hour average; the concentration should never exceed 9,000
ug/1-  The proposed 24 hour average concentration to protect saltwater
aquatic  life  is  1,900  ug/1,  and the maximum ccncentration xs 4,400
ug/1.  For the protection of human health from the toxic properties of
methylene chlroide ingested through water, the  Agency  recommends  an
ambient water quality criterion cf 2 ug/1.

Ethylbenzene  appeared  in gum and wood chemical effluents at a higher
concentration   than   any   other   volatile    organic    pollutant.
Concentrations were as high as 67 ppm in raw wastewater and as high as
21 ppm in the treated wastewater.

Exposure  to  ethylbenzene  has  been  shewn  to adversely affect both
aquatic and human life.  The compound can affect fish by direct  toxic
action  and by imparting a taste tc fish flesh.  Fcr the protection of
human health  from  the  toxic  properties  of  ethylbenzene  ingested
through  water,  the proposed ambient water quality criterion is 1,1OU
ug/1.

Tetrachloromethane, commonly  known  as  carbon  tetrachloride,  is   a
solvent  for  fats,  oils,  and  waxes; an insecticide; and a chemical
intermediate.  Toxicological data shew that rats and mice   exposed  to
carbon  tetrachloride  incur  liver  and  kidney   damage,   biochemical
changes in  liver function, neurological damage, and  liver  cancer.   It
is   well  documented  that  carbon  tetrachloride  is toxic to humans.
Poisoning symptoms include nausea, abdominal pain, liver   enlargement,
and  renal failure.

Carbon  tetrachloride  has been  shewn tc  be a  carcinogen  in laboratory
animals   and  is  a  suspected   human   carcinogen.   As  there   is  nc
recognized    safe  concentration  for   a  human  carcinogen,   EPA   has
recommended that for the   maximum  protection  of  human   health,   the
ambient   water  concentration  of carbon  tetrachlcride  equal  zero.  To
protect  freshwater and saltwater  aquatic  life, the  proposed   24  hour
average   concentration  is   620 ug/1 and  2,000 ug/1,  respectively;  the
recommended maximum concentrations  of   1,400  ug/1   and   4,600   ug/1,
respectively.
                                  74

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 Toluene,  a common general organic sclvent, appeared in concentrations
 varying from trace to more than 30 ppi in raw wastewater.  In  treated
 wastewater the highest concentration was 2000 ppb.

 A  study  using  mice  showed that tcluene is a central nervous system
 depressant that can cause  behavioral  changes  as  well  as  loss  of
 consciousness  and  death  at  high concentrations.  Human exposure to
 toluene for a 2-year period has led to cerebellar disease and impaired
 liver function.  The  proposed  water  quality  criterion  to  protect
 freshwater  aquatic  life  is  2300  ug/1  as  a  24 hour average; the
 concentration should never exceed 5,200 ug/1.  The 24 hour average and
 maximum concentrations to protect saltwater aquatic life are 100  uq/1
 and 230 ug/1, respectively.

 1, 1,1-Trichloroethane  was  found  in  raw and treated effluents.   Its
 primary use is as a solvent and degreasing agent.  It exhibits  strong
 solvent action on organics, especially oils,  greases, waxes, and tars;
 ana  it  blends  with  other  solvents to reduce their flamntability or
 prcvide added solvent properties.

 Trichlorofluoromethane was detected in the raw and  treated  effluents
 of   four plants.   It is used in aerosals,  as  a refrigerant, and in air
 conditioning.   It is not used in the  gum and  wood chemicals processing
 industry.                                                    v        y

 Trichloromethane,  commonly known as chloroform,  appeared  in  the   raw
 and  treated  effluents  of  several  plants.   It is a general solvent,
 refrigerant, and  cleaning agent,  and  is registered for  pesticide   use
 on   cattle.    Lab  tests  show  chloroform to be toxic to organisms at
 various levels of  the food chain;  in  higher organisms it exhibits  both
 temporary   and lasting  effects.   Several  studies   indicate   that
 chloroform  is  carcinogenic   to   rats  and  mice.    Human exposure to
 chloroform can lead to liver  damage,  hepatic   and  renal  damage,   and
 depression of  the  central  nervous system.

 The   proposed   24   hour average  and  maximum  concentrations to  protect
 freshwater aquatic life from  the  tcxic effect  of   chlorofcrm  are   500
 ug/l  and   1,200   ug/1,  respectively.   ahe   proposed   water   quality
 criterion  to protect  saltwater  aquatic  life is 620  ug/1  as  a  24   hour
 average,   with  a maximum concentraticn  cf  1,400 ug/1.  For  the  maximum
 protection of human health  from the potential  carcinogenic  effects  of
 exposure to chloroform, the recommended  ambient water concentration is
 zero.

 Semi-Volatile Fraction

Basic/Neutral  Fraction.  The Agency identified only two basic/neutral
organic  compounds.   These  were  naphthalene  and  bis(2-ethylhexyl)
phthalate.   BIS (2-ethylhexyl) phthalate was the only phthalate ester
                                 75

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identified in gum and wood chemical wastewater.  It is not used in the
direct processing of gum and wood chemical, but was found xn  the  raw
and treated effluents.

Phthalate  esters  can  harm  aquatic and terrestrial organisms at low
concentrations.   The  compounds  exhibit  teratogenic  and  mutagenic
effects  under  certain  laboratory  conditions.   Of the fish species
tested, the rainbow trout was the least sensitive and the bluegill the
most sensitive to di-n-butyl phthalate.  A cray  fish  species  tested
was  the  least  sensitive  and  a  freshwater  zooplanktcn  the  most
sensitive of all species tested.

High levels of phthalate concentration  in  water  where  reproductive
impairment   in   certain   species   are   suggestive   cf  potential
environmental damage.   The  presence  of  these  compounds  in  water
affects  the  growth  and  reproduction  essential  for maintenance of
animal populations.

As a class, the phthalate esters' response to  biochemical oxidation is
inversely related to their molecular weight.   Adsorption on  activated
carbon is directly related to increasing molecular weight.

Naphthalene  appeared  in the raw and treated  effluent frcm one plant.
It was found to be a contaminate in a industrial grade  alcohol.   The
effects   of  naphthalene  poisoning  on   humans  have  been   studied.
Naphthalene poisoning can cause convulsions and  hematolcgic   changes.
Reports   also  indicate  that  workers  exposed  to  naphthalene  for
extensive periods of time are likely to develop malignant tumors.

Naphthalene  bioconcentrates  in  aquatic  organisms  and  reduces  or
interferes  with  microbial  growth.   It  also reduces photosynthetic
rates  in  algae.   Naphthalene  accumulates   in    sediments    up   to
concentrations  twice  that  in overlying  water and can be degraded by
microorganisms to  1,2-dehydro-1,2-dihydroxynaphthalene and  ultimately
to carbon dioxide  and water.

acidic Fraction-  EPA identified two acidic fraction  organic  compounds
from gum and wood  chemicals  plants; phenol and pentachlorcphenol.

Phenol   was  found   in   seven   plants.   Phenolic  compounds can affect
freshwater fishes  adversely  by  direct  toxicity to  fish   and   fish-food
organisms,   by   lowering the amount of available  oxygen  because of  the
high oxygen  demand of compounds,  and   by   tainting   fash   flesh.    The
toxicity  of   phenol to  fish  increases as the dissolved oxygen level
diminishs; the temperature  rises;  and   hardness  is  lessens.    Phenol
 appears  to  act as  a  nerve poison,  causing  too irich  blood  to get to  the
 gills  and to the heart  cavity.
                                  76

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 Mixed  phenolic  substances  are  especially  troublesome in imparting
 taste to fish flesh.   Monochlorophenols produce  a bad  taste  in   fish
 far  below  lethal  or toxic doses.  Threshold concentrations for  taste
 or odor in chlorinated water supplies have been   reported  as  low  as
 0.0003 mg/1.

 The  human  ingestion  of   a  concentrated  phenol solution results  in
 severe pain,  renal  irritation,  shock, and possibly death.

 Various environmental conditions can increase the toxicity of  phenol.
 lower   dissolved  oxygen   concentrations;   increased   salinity;  and
 increased  temperature  all  enhance  the  toxicity  of  phenol.   The
 recommended water quality criterion  to protect freshwater aquatic  life
 is  600  ug/1  as a 24 hour average  and the  concentration should never
 exceed 3,400  ug/1.

 Pentachlorophenol was found in  one raw wastewater sample  at one plant
 at  a  concentration   of  47 ppb.    Several bioassays  have shown  that
 pentachlorophenol is  lethal to  various species of aquatic  life at   a
 concentration of  approximately  200 ug/1.   The lethal  concentration for
 species  tested  ranged from 195 ug/1 for the brown shrimp to 220  ug/1
 for the gold  fish.    The  recommended  24 hour   average   and  iraximum
 concentrations to  protect  freshwater aquatic life are  6.2 ug/1 and  14
 ug/1,   respectively.    To   protect   saltwater   aquatic    life,   the
 recommended  24  hour average concentration  is not to exceed 3.7 ug/1;
 at no time  should the pentachlorophenol  concentration exceed 8.5 ug/1.

 A   study   of   genetic  activity   demonstrated that  pentachlorophenol
 exhibited   weak  but  definite mutagenic  activity.   In nonhuman  mammals
 the  sublethal  effects  of    pentachlorophenol    poisoning    include
 pathological   and  histopathological   changes in   the kidneys, liver,
 spleen, lungs,  and  brain.   In humans,  the  results  of  pentachlorophenol
 poisoning can  range from elevated  blood  pressure  and  rapid  respiration
 to coma and death.  For the protection of  human   health  the   ambient
 water concentration should  be no greater  than 680  ug/1.

 Pentachlorophenol   is  highly   persistent   in  soils.   Reports   have
 indicated that  the compound can  persist in moist  soil for at  least  a
 12-month period.

 Inorganic Toxic Pollutants

 Several  of  the inorganic toxic pollutants were found in gum and wood
 chemical wastewaters at levels of 10 ppb or more.   The   three  metals
used in the industry copper, nickel,  and zinc.

Chromium  also  appeared in  the wastewater streams.  It  is not used in
the processing of  gum  and wood cheiricals except as a biocide  in  some
                                 77

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coding  towers.    The  raw wastewater's highest concentration was 1.5
ppm and the treated wastewater concentration was 0.88 ppir.

Chromium in its various valence states is hazardous to  man.   It  can
produce  lung  tumors  when  inhaled  and induces skin sensitizations.
larqe doses of chromates have  corrosive  effects  on  the  intestinal
tract  and  can cause inflammation cf the kidneys.  Levels of chromate
ions that have no effect on man appear to be so  low  as  to  prohibit
determination  to  date.   The  toxicity of chromium salts to fish and
ether aquatic life varies widely with the  species,  temperature,  pH,
valence  of  the  chromium,  and  synergistic or antagonistic effects,
especially those of hard water.  Studies show that trivalent  chromium
is  more  toxic  to  fish  of  some types than is hexavalent chronr.ium.
Other studies show opposite effects.  Fish food  organisms  and  other
lower  forms  of  aquatic life are extremely sensitive to chromium; it
also inhibits the growth of algae.   Therefore,  tcth  hexavalent  and
trivalent   chromium   must   be  considered  potentially  harmful  to
particular fish or organisms.

Fish appear to be relatively tolerant of chromium,  but   some  aquatic
invertebrates  are  quite  sensitive,.   Tcxicity  varies  with species,
chromium oxidation state, and pH.

Chromium concentration factors in marine organisms have been  reported
to  be  1,600  in  benthic  algae,  2,300  in  phytcplankton, 1,900 in
zooplankton, and 440 in molluscan soft parts.

Copper.   Copper  oxides  and  sulfates  are  used    for    pesticides,
fungicides,  and  certain  metallized dyes.  The  tcxicity of  copper to
aquatic life is dependent on the  alkalinity  of  the water,  as  tne
copper  ion  is  complexed  by  anions  present,  which in  turn  affect
toxicity.  At  lower  alkalinity  ccpper  is  generally more  toxic to
aquatic  life.   Other  factors affecting toxicity include  pH, organic
compounds, and the species tested.  Relatively  high  concentrations of
copper  may  be tolerated  by  adult  fish for  short periods of  time; the
critical effect of copper  appears to  be its higher toxicity  to   young
cr  juvenile  fish.

In   most    natural    fresh    waters   in  the   United  States,   copper
concentrations below 0.025  mg/1 as  copper evidently   are   not  rapidly
fatal  for  most common fish species.   In acute  tests  coppers sulfate  in
 soft   water  was   toxic to  rainbow  trout  at  0.06  irg/1 copper.   In very
hard water the toxic concentration  was 0-6  mg/1  ccpper.    In  general
 the salmonids are very sensitive  and the  sunfishes  are less sensitive
 to copper.

 copper appears in  all soils,  and  its  concentration ranges from  10  to
 80 ppm.   In  soils,  copper  occurs  in association with hydrcus oxides of
manganese   and  iron  and  also as  soluble  and insoluble complexes with
                                  78

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organic matter.   Keeney and Walsh (1975)  found  that  the  extractable
copper  content  of  sludge-treated  soil  decreased  with time, -which
suggests that a reversion of copper to less soluble forms.

Copper is essential to the growth of plants, and the normal  range  of
concentrations   in  plant  tissue  is  front  5  tc  20  ppro.    Ccpper
concentrations in plants normally do not build up to high levels  when
toxicity  occurs.   For  example,  the  concentrations  of  copper  in
snapbean leaves and pods was less than 50 and  20  ppm,  respectively,
under  conditions of severe copper toxicity.  Even under conditions of
copper toxicity, most  of  the  excess  copper  accumulates  in  plant
tissues.   Copper  toxicity  may develof in plants from application of
sewage sludge  if  the  concentration  of  copper  in  the  sludge  is
relatively high.

For  copper,  the  proposed  water  quality criterion depends on water
hardness.  At  a  hardness  of  75  mg/1,  the  criterion  to  protect
freshwater  aquatic  life  is  2.4  ug/1  as  a  24  hour average, the
concentration should never exceed 16 ug/1 at this water hardness.  The
recommended criterion to protect saltwater aquatic life is  0.79  ug/1
and    18   ug/1   as  24  hour  average  and  iraximum  concentrations,
respectively.

Nickel-  studies of the toxicity of nickel to  aquatic  life  indicate
that  tolerances  vary  widely  and  are  influenced  by  species,  pB
synergistic effects, and other factors.

Available data indicate that:   (1) nickel in water is toxic  to  plant
life  at  concentrations  as  low  as  100  ug/1;  (2) nickel adversely
affects reproduction of a freshwater crustacean at  concentrations  as
low  as  0.095 mg/1;  (3) nickel concentrations as low as  0.31 mg/1 can
kill marine clam larvae; and  (4) nickel seriously affects reproduction
of freshwater minnow at concentrations as low as  0.73  ing/1  and  the
reproduction of Daphnia at 53 ug/1.

In  nonhuman  mammals  nickel acts to inhibit insulin release, depress
growth, and reduce cholesterol.  A high incidence  of  cancer  of  the
lung   and  nose has been reported in humans engaged in the refining of
nickel.

Zinc.  Toxic concentrations of zinc compounds cause adverse changes in
the morphology and physiology of fish.  Acutely  toxic  concentrations
induce  cellular  breakdown of the gills, and possibly the clogging of
the gills with  mucous.   Chronically  toxic  concentrations  of  zinc
compounds,  in  contrast,  cause  general  enfeeblement and widespread
histological changes to many organs, but not  to  gills.   Grwoth  and
maturation  are retarded.  In general, salmonids are most sensitive to
elemental zinc in soft water; the rainbcw trout is the most  sensitive
in  hard  waters.   In  tests  with several heavy metals, the immature
                                  79

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aquatic insects seem to be  less  sensitive  than  many  tested  fish.
Although available data is sparse on the effects of zinc in the marine
environment,  zinc  accumulates  in  some  species, and marine animals
contain zinc in the range of 6 tc 1,500 mg/kg.  Fcr zinc, the proposed
water quality criterion depends on water hardness.  At a  hardness  of
75  mg/1, the proposed criterion to protect freshwater aquatic life is
35 ug/1 as a 24 hour average and the concentration should never exceed
185 ug/1 at this hardness.

                                80


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                              SECTION VII

                    CONTROL AND TREATMENT TECHNOLOGY

 GENERAL

 This section discusses the range of wastewater control  and  treatment
 technologies  available  to  the Gum and Wcod Cheiricals Industry.   In-
 plant  pollution  abatement   as   well   as   end-of-pipe   treatment
 technologies  are presented.   For the purpose cf cost analysis, one or
 more candidate technologies were selected for each subcategory.

 There are many  possible  combinations  of  in-plant  and  end-of-pipe
 systems capable of attaining  the pollutant reductions reported for the
 candidate technologies.  Performance levels reported for the candidate
 treatment  technologies are based upon the demonstrated performance of
 similar systems within the industry cr upon well documented results of
 readily transferable  technology.   The  industry  can  achieve  these
 performance levels by using the mcdel treatment systems proposed.   The
 purpose  of  the  model  treatment systems is to establish the cost of
 ^£eV^ng-     effluent levels reported  for  the  candidate  treatment
 technologies.    Each  individual  plant  must  make the final decision
 concerning  the specific combination of pollution control measures  best
 suited to its  particular situation.

 IN-PLANT CONTROL MEASURES

 w°gd  Rosin* Turpentine f  and Pine Oil

 The major in-plant water  control measure  in this  subcategory  is   the
 recycling  of   stump wash water.   Stumps  are washed irainly to minimize
 tne a&rasiye effect  of sand on  subsequent  processing  equipment.    The
 quantity  of sand has become a major factor only  in the  last few years.
 ^L<.CUrr!nt  prac*ice  of  Plowing stumps  cut cf the ground with large
 tractors  does  not loosen  sand as  the older blasting method did.

 Spent wash  water is  collected and pumped to settling basins,  the  size
 of which  depends on  the land available to  the  plant.
«*£!™+ II6  an*  °68  *ave  basins large enough to allow for settling
without the addition of a settling aid.  They use a  two-basin  system
in  which  one  basin  operates  while the other is dredged.  Dredging
varies with the plant work schedule.                          imaging

Because of limited space. Plant 102 has a settling  basin  9.7  meters
(32  feet)  by 11.5 meters (38 feet) by 3.7 meters (12 feet).  Because
of its size, polymer is added to the basin to enhance settling.   Daily
dredging reiroves approximately 90 to 181 metric tens (100 to 200 tons)
                                 81

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per day of wet sand  and sediment, approximately 50  percent of which is
water.

Plant 687 does not recycle its stump wash water but  routes  it  to  a
basin  for  settling  and solids removal followed by clarification and

sssstifi-of'isa. s£Ug.**2 so1^!. *s ^r?s «ss
daily flow from the  stump washing operation is 22,330 cubic meters per
day  (5.9 mgd) .  The  long term average daily solids  loading  from  the
plant   is  approximately  1,080  kg/day   (2,UOO  Ibs/day),  which  is
discharged to the surface water.

Tall Oil Rosin, Pitch, and Fatty Acids

Tall oil plants use  barometric condensers to induce  reduced   pressure
in  the distillation tower.  The barometric condenser water 1S^co"ta?t
water and becomes contaminated with  the low boiling point constituents
cf the tall oil.

The  tall  oil  distillation industry  recirculates  its  barometric
condenser  water  through  separate  "oily water" cooling towers,  which
skim off the condensed oil prior tc  cycling through the  main   cooling
tower.  The skimmed  oil is returned  to  the process or is sold  as  a by
prcduct.   The  volume  of   water  gcir.g into  the "oily water" cooling
system depends on the amount of  steam  used   for  distillation.    The
steam  is  then  condensed   by the barometric  condenser along  with any
water retained in the tall oil.  The ccndensate  is the source  of  make-
up water for the "oily water" cooling system.
 Water volume in the "oily water" system is  controlled by  J™^"*^
 drift,   and  blowdown  from  the  cooling  tower.   Plant 877 has zero
 discharge from this type of system;  the holding  basin is large  enough
 to  handle  any  excess  "oily  water"  generated  during times of low
 evaporation or rainy weather.  The largest  flow  noted  from  an  "oily
 wlter"   system was a long term average of 272  cubic meters per day (50
 gpm) from Plant 176

 Recvclinq this "oily water" concentrates it.    The  "oily  water"  in
 pfant   476  was sampled in conjunction with that cf the waste streams.
 The pollutants were more concentrated than  those in the raw wastewater
 discharged by the plant.  Table VII-1 ccmpares the raw wastewater  and
 the "oily water" cooling system.

 The use of barometric condensers is standard throughout plants located
 in  the south; however, the size cf the holding b».81?? ™rl~ 8Xg£f\
 cantly between the plants.  The  holding  pond  at Plant   «7«  has   a
 capacity  lust  equal   to  the volume of the cooling tower  and the cil
 skimmer?  ThK plant uses  a  continuous  cooling   tower  blowdown  of
 IpF^oximately  54.5  cubic  meters  per  day  (10  gpm) tc mamtam the
                                  82

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              83

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Table VII-1.  Plant 476—Comparison  of Raw Wastewater and "Oily Water"
              Cooling System
Raw
Wastewater
Total Phenol mg/1 550
Total Suspended Solids mg/1 44
COD mg/1 1100
Phenol mg/1 *
"Oily Water"
Cooling System
1700
170
8400
7500T
* Value was less than the detection  limit.

t Value may vary from that for the total phenol because  of  analytical
  technique.

-------
proper level in the system.  Other plants have intermittent  blowdowns
depending  on the solids build-up in the tower and the need to control
the water level in the system.

Plants 140 and 864, located in a relatively cold  climate,  use  steam
jets  to  reduce the water in the distillation towers, and non-contact
condensers to cool the condensate.  The ccndensate  is  discharged  to
the  waste treatment process.  Plant 140 estimates the flow due tc the
steam jet vacuum system and the ccndensate  tc  be  approximately  272
cubic meters per day  (50 gpm) .

End-of-Pipe Treatment

EPA identified the following end-of-pipe treatment unit operations for
potential  inclusion  in  BPT  Sulfate  Turpentine,  ECT, EAT, and New
Source Performance Standards.

Free Oil Removal—Oily products such as turpentine and fatty acids are
a major factor in this industry.  Gravity oil-water separation is used
throughout the industry to recover oil for use as  a  fuel  supplement
or, in some cases, for recycle to the plant process.
A baffle separator at the effluent end of an equalization basin is the
most  common system used in the industry.  The oil can be skimmed from
the basin either manually or continuously, depending on the wastewater
flew and the quantity of oil products produced  at  the  plant.   This
study  did  not  consider  free oil removal as a part of the treatment
system, and wastewater  characteristics  across  cil-water  separators
were not considered.

Chemical Flocculation—Wastewater from the industry typically has high
concentrations  of  emulsified  oil, the quantity of which varies from
plant to plant depending on the efficiency of the cil-water  separator
and  the pH of the waste stream.  A pH less than 3 greatly reduces the
emulsion problem; however, the pH of industry waste  streams  industry
typically ranges from 3 to 9.

Chemical  coagulation  of the emulsified oil is a recognized method of
removal.    The  coagulants  normally  used  in  industrial  wastewater
processes  are  lime,  alum,  and  ferric chloride, with polymer often
added as a flocculant.  The selection of a coagulant  depends  on  the
characteristics of each particular waste stream.

Plants  877  and  68  currently using chemical coagulation.   One plant
fractionates tall oil, and the other is a major producer in  the  wood
rosin  and  turpene area.   These plants reduce oil and grease by 65 to
85 percent using coagulation and settling equipment with polymer as  a
flocculation  aid.   The flocculated effluent generally contains from 7
to 16 mg/1 of oil and grease.
                                 85

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Equalization—Equalization is a treatment  step  used  to  smooth  out
surges  in  both  flow and pollutant concentration.  Because treatment
unit  operations  must  be  able  to  handle  peak  flow   rates   and
concentrations, plants can realize significant capital cost savings by
minimizing  the peaks with equalization.  Operating costs for chemical
addition processes also can be reduced by optimizing chemical  dosage.
Plant   wastewater  flow  rates  and  pollutant  concentrations  vary,
depending on the process and the process stage.  The retention tiire in
the equalization basin can be reduced by using  seme  type  of  mixing
method such as aeration.

Neutralization—Gum  and  Wood Chemicals industrial waste streams vary
in pH from 3 to 9, which may require neutralization before the various
treatment steps.  Oil emulsion breaking is best accomplished with a pB
of less than 3; metals precipitation is best accomplished with a pH of
approximately 9; and biological treatment is best accomplished with  a
pH of approximately 7.

pH  adjustment  uses  either  alkalies  or  acids, depending on the pH
requirement.  Commonly used alkalies are lime, caustic, cr  soda  ash.
Sulfuric acid is the usual acid.

Flotation—Flotation  is a process which separates solids or oils from
the carrier wastewater by attaching  them  to  floating  gas  bubbles.
Flotation  occurs  in  three  ways:   (1)  air  flotation—aeration at
atmospheric pressure;   (2)  dissolved  air  flotation—aeration  of  a
liquid under pressure with subsequent release cf the pressure; and  (3)
vacuum   flotation—aeration  of  a  liquid  at  atmospheric  pressure
followed by  application  of  a  vacuum  to  the  liquid.   The  basic
principle  is  that  air  bubbles attach themselves to oil globules or
suspended particles and  float  them  tc  the  surface  fcr  skimming.
Chemicals  such  as  coagulants,  polymers, acids, and/or alkalies  are
often used prior to flotation to promote the formation of larger  more
easily removed particles.

Plants  778  and  767 use air flotation devices.  A study conducted by
Plant 778 reported that air flotation removed  204  kg/day   (450  Ibs/
day)  of  BOD,  181  kg/day   (400  Ibs/day) of oil and grease, and  236
kg/day  (521 Ibs/day) of COD,  Plant 767 is  currently  installing   the
flotation equipment, and pollutant removal rates are not available.

Plant  102 also uses a dissolved air flotation process.  A plant study
shewed a reduction cf TOC across the flotation unit  of  2,860  kg/day
 (6,300  Ib/day).  Oils recovered from the flotation unit are used as  a
fuel supplement.

Metals Removal—Varying levels  of copper,  chrome,  nickel,  and  zinc
appeared  in  the  waste  streams  across the  industry.  Seme of these
metals are used as catalysts  in industry processes.
                                  86

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The most accepted method of metals removal is the formation  of  metal
hydroxides.   Heavy  metal  ions  can  be precipitated from wastewater
streams as metal hydroxides.  The first step  in  the  process  is  to
adjust  the  wastewater pH to a level at which the solubility of heavy
metals is sufficiently low.  The sclubility  curves  for  four  common
metals in distilled water are shown in Bigure VII-2.

Figure  VII-2  suggests  that  a  pH  of  9  can  remove  metals  most
efficiently; however, the actual operating pH level must be determined
for each plant.  Metal salt formation varies  with  the  waste  stream
matrix  and the metal ions present.  The Agency suggests the formation
of metal hydroxides instead of metal sulfides.

Although the particles formed by metal salts are colloidal  in  nature
and  are kept in suspension by electrical surface charges, they can be
neutralized by the use  of  coagulants  or  polymers  which  bond  the
smaller  colloidal particles into larger floe particles and allow them
to settle with conventional settling techniques.

Biological Treatment—Biological treatment is the controlled oxidation
of organic matter to inorganic end products like GO2,  H20,  NO3,  and
SO4    by    aquatic   microorganisms   (primarily   bacteria).    The
microorganisms utilize organic matter as a food source; in  so  doing,
they  simultaneously  propogate  themselves.   Two types of biological
treatment processes treat Gum and Wocd Chemicals wastewater: activated
sludge and aerated lagoons.

In the activated sludge system, wastewater, microorganism sludge,  and
nutrients  are  fed into a tank with sufficient detention time for the
required BOD reduction.  The tank is aerated to supply oxygen and  mix
the  sludge  enough  to  keep  it  in  suspension.    The aeration tank
effluent then goes to a clarification tank where  the  sludge  settles
out  of the treated wastewater stream and is partially recycled to the
aeration tank.  Because net solids are  produced  by  the  propogating
microorganisms, a portion of the sludge must be wasted to avoid build-
up of excess solids in the system.

Aerated ^lagoons use the same basic process.  Hastewater and nutrients
are fed into the lagoon and aerated.   However, the  aerated lagoons  do
not  recycle  sludge,  excess sludge produced by the biological action
settles either in the poorly  mixed  zones  of  the  lagoon  or  in  a
separate clarification basin,

Carbon  Adsorption—The  efficacy  cf  activated  carbon in wastewater
treatment has been  "rediscovered"  in  recent  years,   although  very
little  of  the  work  has been relevant to the Gum and Wood Chemicals
Industry.
                                 87

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        10 -
       i.o  -
                                                                      - 0.1
CO
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      0.01  Z
                                              -  0.01
      0.001 -
                                              -  0.001
          Figure  VII-2.
          SOLUTION  pH
       (From  EPA-440/1-73-003)
Solubility Curves for Chromium, Copper, Nickel,  and Zinc
                                    88

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Cne facility presently uses activated carbon  adsorption.   Plant  102
has  oil-water  separation,  neutralization,  dissolved air flotation,
filtration,  and  finally,  granular  activated  carbon  (GAC).   This
granular  activated  carbon  system  is  used  in  lieu  cf biological
treatment.

Adsorption isotherms were developed  by  three  separate  laboratories
using  the parameter COD.  The results were carbon loadings of between
0.85 and 1.2 kg COD/kg carbon (0.85 Ib COD/1.2 Ib carbon).   The  pilot
plant  studies revealed that the optimal conditions were flow rates of
176 to 293 m3/m2/day (3 to 5 gpm/ft2) and a contact time of 45  to  50
minutes.   Under these conditions, COD removals were 75 tc 85 percent.
The pilot plant results confirmed the isotherm results by  yielding  a
carbon  loading  of  approximately  1.0  kg  COD/kg  carbon (Ib CCD/lb
carbon) .

The GAC system was designed and is operating at a  carbon  loading  of
approximately  1.2 kg COD/kg carbon  (1.2 Ib CCD/lb carbon)  and 0.44 kg
TOC/kg carbon (0.44 Ib  TOC/lb  carbon).   Pollutant  reductions  were
approximately  84  percent  COD  and  79  percent TOC.  Representative
performance data for the GAC system appear in Table VII-2.   The entire
treatment system removed better  than  95  percent  of  CCD  and  TCC.
Typical  performance  data for the total treatment system are shown in
Table VII-3.

Very little data are available on adsorption of  toxic  pollutants  in
Gum and Wood Chemicals wastewater.  Carbon adsorption is not effective
for  removing  most  metals.   The crganics ccmmonly identified during
screening and verification were benzene,  toluene,  ethylbenzene,  and
phenol.    Guisti,  et  al. (1975)  performed tests which indicated that
carbon adsorption probably could remove 75 percent of these compounds.
Actual screening and sampling data from Plant 102 showed removals  for
benzene  and  toluene  of approximately 64.4 percent and 74.9 percent,
respectively.

Evaporation—Due  to  the  significant  volumes  cf  plant  wastewater
generated,  evaporation is not a widely-used technology in the Gum and
Wood Chemicals  Industry.   However,  it  may  apply  to  disposal  of
specific high-strength, low volume, process waste streams.

Spray  evaporation involves containing the wastewater in lined lagoons
sufficiently  large  to  accommodate   several   months   of   process
wastewater,  as  well  as  directly  rainwater  on  the  lagoon.   The
wastewater is sprayed under pressure through nozzles,  producing  fine
aerosols  which  evaporate  in  the atmosphere.  The driving force for
this evaporation is the difference in relative  humidity  between  the
atmosphere  and  the  humidity  within  the  spray  evaporation  area.
Temperature, relative humidity,  pond  dimensions,  wind  speed,  spray
                                 89

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Table VII-2.  Secondary Tre<*Lment  Feed  and  Effluent  Analysis and
              Performance Data
                                                               Removal
     Item                 Influent    Effluent     % Reduction   Ib/day
Design:
12,260 m3/day (3.24 mgd)
COD, mg/1
TOG, mg/1
BOD, mg/1
Start-up period:
9,810 m3/day (2.592 mgd)
COD, mg/1
TOC, mg/1
Typical operation:
9,810 m3/day (2.592 mgd)
COD, mg/1
TOC, mg/1
Selected samples:
(2.592 mg/1)
BOD, mg/1
Phenols, mg/1
Ni, mg/1
Zn, mg/1
Cd, mg/1
Cu, mg/1
Cr, mg/1
TS, mg/1 1
SS, mg/1
DS, mg/1 1
Chlorides, rag/1
N02» mg/1
Oil and grease, mg/1


600
160
250


975
222


752
203


300
4.66
1.02
1.11
0.91
1.29
1.12
,211
81
,130
1.82
5.16
28.1


125
30
50


152
46


160
42


82
0.58
0.33
0.29
0.22
0.36
0.26
965
13
952
0.84
4.28
2.2


79
81
80


84
79


79
79


73
88
68
74
76
72
77
20
84
16
48
17
92


12,800
3,500
5,400


17,800
3,500


12,800
3,500


4,700
88
15
18
15
20
19
5,300
1,500
3,800
19
19
560
                          90

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Table VII-3.  Typical Total Treatment System Performance Data*



Parameter
COD
TOC
BOD
TSS
Oil and Grease

Raw Waste
Water
(mg/1)
3,200
1,200
1,600
320
500
Primary
Treated
Effluent
(mg/D
670
198
267
72
25
Secondary
Treated
Effluent
(mg/1)
143
37
73
12
2

Overall
Reduction
(%)
95.5
96.9
95.4
96.3
99.6
* 
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nozzle  height, and pressure are all variables which affect the airount
cf wastewater which can be evaporated.

To  be  effective,  spray  evaporation  should  follow  effective  cil
removal.   Excess oil content in the wastewater may retard evaporation
and increase the potential for air pollution.  Careful segregation  of
uncontaminated  water  from  the  wastewater  stream  is  particularly
important in minimizing the amount of wastewater tc be evaporated.

land Disposal Systems—Controlled application on land can  dispose  of
wastewater   or   sludge.    Methods   of  application  include  spray
irrigation,   subsurface   injection,   overland   flow,   and   rapid
in filtration.
The  pollutant removal mechanisms include biological oxidation by soil
microorganisms,  ion  exchange,  physical  straining,   precipitation,
nutrient  uptake  by  vegetation, and volatilization.  Pretreatment of
wastewater is required to prevent odors; to maximize  the  application
rate;  and to protect crops, public health, grcundwater, soil, and the
application equipment.  Pretreatment processes  typically  include  pH
adjustment, suspended solids removal, cil removal, and chlorination.

One  plant  practices land disposal cf aerated lagccn sludge.  Current
EPA encouragement of land disposal and  increasingly  strict  effluent
Limitations may result in more plants using this system in the future.
A  major  drawback for many existing plants is the absence of suitable
land.

In-Place Treatment Technology

This  report  assumes  that  "Best  Practicable   Control   Technology
Currently  Available"   (BPT)  requirements  are being met.  The direct
discharge plants in the industry have not all used the sav.e  treatment
scheme.  The Gum and wood Chemicals plants that discharge to municipal
treatment  plants  presently  are not required by Federal law to treat
wastewater.   Some   municipalities   do   require   pretreatmeni:   of
wastewater, but this is on a city-by-city basis only.  The final group
of plants discharges wastewater to the waste streams of pulp and paper
mills.   These  waste  stream flows are generally large—in the 20 MGD
range, while flows from the Gum and Wood Chemicals plants are 1 MGD or
less.

Metals removal is not practiced generally  in  the  industry  at  this
time.   Plant  17  treats  for  metals  on  a  particular waste stream
containing  heavy  metals.   The  lack  of  industry-wide  information
required  a  review  of the technology available from other industrial
categories,  while the levels of metals found in the plating  industry
are  higher  than  those  in  the Gum and Wood Chemicals Industry, the
general technique of precipitating metal  salts  is  a  well  accepted
treatment  method.   Additionally,  the  wastewaters  from  the  metal
                                 92

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plating  operations  more  closely  resemble  the  types  of  problems
encountered  in  the  Gum and Wood Chemicals industry industry oil and
grease and chelating agents.

Plant 102  uses  granular  activated  carbon  in  lieu  of  biological
treatment.   Operational  problems  have  resulted in the formation of
biomass in the columns, restricting the flow.  Down time of the carbon
regeneration system due to equipment failure also has been a  problem,
A new type of regeneration furnace is being installed and a biological
treatment study is underway.

Plant  976  slurries  carbonaceous  ash from the spent wood chip-fired
boiler with the wastewater to utilize the adsorption capacity  of  the
ash.  Table VII-4 shows the effectiveness of this method.

Table   VII-5  shows  a  matrix  cf  the  current  in-place  treatment
technology in the Gum and Wood Chemicals Industry.  As mentioned  pre-
viously,  the direct dischargers have at least soire treatment in-place
at this time; pretreatment processes for indirect  dischargers  depend
on  the  requirements  of the receiving treatment works.  Eight plants
discharge their wastewater to POTW's and four plants  discharge  their
wastewater  to  the waste streams cf other industries such as pulp and
paper mills.  The plants  that  discharge  to  POTW's  have  treatment
equipment to meet POTW's requirements.
                                 93

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Table VII-4.  Plant 976—Pollutant Reduction Across Fly Ash Slurry
Parameter
Trichloroethylene
Benzene
Toulene
Ethylbenzene
COD

Influent
3 ug/1
100 ug/1
ND
10 ug/1
1,100 mg/1
Concentration
Effluent
NF
10 ug/1
ND
NF
730 mg/i
NF » Not found.




ND = Not determined.
                            94

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Table 7II-5.   Treatment Scheme




778
476
976
068
291
649
017
110
687

974
474
573
377
286
102
140
479
864
943
767


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                                             95

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             COST, ENERGY, AND NCN-WATER QUALITY ASPECTS

COST INFORMATION

This  section  presents  cost  information for the candidate treatment
technologies developed in Section VII in order to assess the  economic
impact on the industry.

EPA  has  arrived  at  two  types of cost estimates.  First, the total
battery limit costs of the technologies are estimated  for  the  model
plants  according  to  raw  wastewater  characteristics  described  in
Section V for each subcategory.  These estimates include the  cost  of
each  unit  process  associated  with the suggested technology at each
level of treatment.

The second  type  of  cost  estimate  presented  is  a  plant-by-plant
estimate   of   the   costs  of  achieving  the  applicable  candidate
technologies within each subcategory.  This estimate was prepared  for
every plant in the technical data base.

A  number  of  factors  affect  the cost cf a particular facility, and
these highly variable factors may differ from those  assumed  in  this
study.   One  of the most variable factors is the cost of land.  Other
site-specific factors  include  local  scil  ccnditicns,  construction
materials  (e.g.,  steel versus concrete tanks), building codes, labor
costs, and energy costs.

Some  installations  may  use  cost  accounting  systems  which  cause
reported  costs to differ from those in this section.  For example, it
is  not  uncommon  for  a   portion   of   a   manufacturing   plant's
administrative  costs  to  be allocated to the waste treatment system.
Such factors are not included in this document.

Table VIII-1 lists  the  assumptions  used  in  developing  the  costs
presented  in  this  section.   Tables VIII-2 and VIII-3 describe each
technology for  which  costs  are  estimated  for  the  Gum  and  Wood
Chemicals  Industry.  In considering costs for these technologies, the
four existing plants who comingle their wastes with  other  industrial
wastewaters  prior  to treatment and discharge to waters cf the United
States are considered as indirect dischargers.

EPA developed model plants for four different types of  Gum  and  Wood
manufacturing  plants:  (1)   those which produce tall oil rosin, fatty
acids, and pitch; (2)  those which produce tall oil rosin, fatty acids,
pitch, and rosin-based derivatives; (3)  those  which  produce  sulfate
turpentine; and (4)  those which produce sulfate turpentine, and resin-
based  derivatives.   The development cf model plants was restricted to
                                 97

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•these four types of  manufacturing  facilities  because  the  existing
market  and  raw  material supply almost precludes construction of the
ether types of Gum and Wood plants.

Raw wastewater characteristics for the model plants were based on data
provided by plants in the industry.   The  production  and  wastewater
flow  data  were  based  on  historical  data  provided  by  the  data
collection  portfolio  respondents.   Tables  VIII-4  through   VIII-6
contain  the  design  flow  and raw wastewater characteristics for the
model plants.

Energy Requirements of Candidate Technologies

Energy costs are itemized in each cf the ccst estimates  presented  in
this section.

Total Cost of Candidate Technologies

Tables VIII-7 through VIII-27 present the total battery limit costs of
candidate treatment technologies for combinations of subcategories for
which new plants might reasonably be expected.

Cost of Compliance for Individual Plants

EPA  performed a piant-by-plant analysis on each Gum and Wood plant in
the technical data base to determine  the  compliance  cost  for  each
applicable  candidate  treatment  technology.   The individual plants'
wastewater  flow,  raw  wastewater   characteristics,   and   in-place
technology  were  all  considered.  Costs cf compliance for individual
Gum and Wood plants appear in Tables VIII-28 through VIII-44.

NON-WATER QUALITY IMPACTS OF CANDIDATE TECHNOLOGIES

The  most  significant  non-water  quality  impact  of  the  candidate
technologies  involves  the  disposal  of  wastewater  sludges.   Such
disposal must be managed properly tc mitigate ground or surface  water
contamination.

Data in this document have indicated that organic toxic pollutants may
be   removed  by  biological  treatment.   Organic  materials  may  be
bicdegraded, stripped from the wastewater by aeration, or removed with
the waste sludge.  Metals precipitated from the wastewater may  appear
in the sludge.

It  was not within the scope of this document to define whether wastes
from the Gum and Wood Chemicals Industry are hazardous materials.   No
effort  was  made  to characterize accurately the sludge produced as a
result of wastewater treatment.   No  sludge  samples  were  collected
during  the screening or verification sampling program.  However, some
                                 98

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wastes generated as a result of these regulations may be classified as
hazardous under new RCRA regulations.

Some impacts on air quality may occur as a result of spray evaporation
or cooling tower evaporation, since the  wastewater  being  evaporated
contains volatile organic compounds which may evaporate with the waste
and  increase  the  equivalent  hydrocarbon content of the air.  Drift
losses caused by wind may also cause an air quality impact as a result
of spray evaporation  or  cooling  tcwer  evaporation.   In  addition,
volatile   organic  compounds  may  be  stripped  from  wastewater  by
aeration, such as in activated sludge units or aerated lagocns.

Precipitation of metals as hydroxide  floes  will  result  in  sludges
containing some water.  The disposal of these sludges will result in a
small  increase in consumptive water losses.  However, the industry is
located in areas with sufficient water  supplies  and  no  significant
impacts are anticipated.

Increased  energy  consumption  resulting from implementation of these
effluent guidelines will be small.  One of the two direct  discharging
sulfate turpentine plants may have to upgrade the biological treatment
system  by  addition  of  aeration  horsepower.   For the EAT and PSES
treatment systems, six of the twenty plants may require seme pumps and
other ancillary equipment for operation of  the  system.    The  Agency
projects that increased energy consumption resulting from BPT, BAT and
PSES will be kilowatts per year.
                                 99

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                   Table VIII-1.   Cost Assumptions

 1.  All  costs  are  reported in June  1977  dollars.
     (Engineering News Record, "Construction  Cost Index,"  Conversion
    to March 1979  Dollars =  1.136)
 2.  Excavation costs $5.00 per  cubic yard.
 3.  Reinforced concrete costs $210  per cubic yard.
 4.  Site preparation costs $2,000 per acre.
 5.  Contract hauling of sludge  tc landfill costs $25  per  cubic  yard,
 6.  On-site sludge disposal  costs $5 per cubic  yard.
 7.  Land costs $10,000 per acre
 8.  Surface dressing for lagoons costs $0.03 per square foot.
 9.  Fencing costs  $2.00 per  linear  foot, installed.
10.  Clay lining for lagoons  costs $0.23  per  square  foot.
11.  New  carbon costs $0.40 per  pound.
12.  Epoxy coating  costs $2.00 per square foot.
13.  Electricity costs  $0.05  per kilcwatt-hour.
14.  Phosphoric acid costs  $0.25 per pound.
15.  Anhydrous  ammonia  costs  $0.18 per pound.
16.  Polymer costs  $0.60 per  pound.
17.  Sulfuric acid  costs $0.06 per pcund.
18.  Sodium hydroxide costs $0,10 per pound.
19.  Sulfur dioxide costs  $0.25  per  pound.
20.  Engineering costs  15 percent cf ccnstruction cost.
21.  Contingency is 15  percent of the sum of  the capital  cost,  land
    cost, and  engineering  cost.
22,  Annual insurance and taxes  cost 3 percent of the  sum  of the capital
     cost plus  land cost.
23.  Average labor  costs $20,000 per man  per  year,  including fringe
     benefits  and overhead.
24.   Equipment  Life Expectancy—20 years.
                                 100

-------
Table VIII-2.
Gum and Wood Candidate Treatment
Technologies - Indirect Discharge
          Technology 1
          Technology 2
          Metals Removal (At Source)
          Monitoring Station
          Sludge Disposal  (Truck Haul and/or
               On-Site Landfill)

          Metals Removal (End-of-Pipe)
          Sludge Disposal  (Truck Haul and/or
               On-Site landfill)
Table VIII-3
Gum and Wood Candidate Treatment
Technologies - Direct Discharger
          Technology  1
           Technology  2
           Technology 3
           Technology
          Equalization
          Pump Stations  (2)
          pH Adjustment
          Polymer  Addition
          Air Floatation  (Tall  Cil  Only)
          Neutralization
          Nutrient Addition
          Activated Sludge
          Monitoring Station
          Control  Hcuse
          Sludge Disposal

          Metals Removal  (At  the Scurce)
          Monitoring Station
          Sludge Disposal (Truck Haul  and/or
               On-Site landfill)

          Metals Removal  (End-of-Pipe)
          Sludge Disposal (Truck Haul  and/or
               On-Site Landfill)

          Filtration and  Activated  Carbon
               Adsorption
          Sludge Disposal (Spent Carbon)
                                  101

-------
Table VIII-4.  Tall Oil Rosin, Fatty  Acid,  and Fitch Producing
               Plants - Model Plant Eesign  Criteria


                                                   resign Criteria
                                                   1             2

     Production, Kkg/day  (TPD)                  290  (320)      290  (320}

     Unit Wastewater Flow, bl/Kkg  (kgal/ton)    1.7  (0.4)      8.3  (2.0)

     Wastewater Flow, Kkl/day (MGD)            0.38  (0.1)      2.3  (0.6)

     Influent BOD Concentration, mg/1           612            612

     Influent OSG Concentration, mg/1           111            111

     Influent pH                                6.5            6_5
Table VIII-5.  Tall oil. Rosin, Fatty Acid, Pitch, and Resin Based
               Derivatives Producing Plant - Model Plant Eesign Criteria
                                                   Eesign Criteria
                                                   1             2

     Production, Kkg/day (TPD)                  100 (110)     249  (275)

     Unit Wastewater Flow,  kl/Kkg (kgal/ton)   3.6 (0.87)    7.9  (1.9)

     Wastewater Flow, Kkl/day (MGE)            0.38 (0.1)     1.9  (0.5)

     Influent BOD Concentration, mg/1          850           850

     Influent OSG Concentration, mg/1          467           467

     Influent pH                               5.0           5.0
                                 102

-------
Table VIII-6.  Sulfate Turpentine Producing Plants - Model Plant
               Design Criteria
                                                   Design Criteria

     Production, Kkg/day (TPD)                         72  (79)

     Unit Wastewater Flow,  kl/Kkg  (kgal/ton)          9.6  (2.3)

     Wastewater Flow, Kkl/day (MGD)                  0.76  (0.2)

     Influent BOD Concentration, rcg/1                    1,916

     Influent OSG Concentration, mg/1                     448

     Influent pH                                          9.0
                                 103

-------
Table VIII-7.  Sulfate Turpentine and Rosin Based Derivatives
               Producting Plants - Model Plant Design Criteria
Production, Kkg/day (TPD)
Unit Wastewater Flow, kl/Kkg (kgal/ton)
Wastewater Flow, kkl/day (MGD)
Influent BOD Concentration, mg/1
Influent O&G Concentration, mg/1
Influent pH
Design Criteria

     45(50)
     30 (7.2)
     1.5 (0.4)
     5,107
       810
       3.9
                                  104

-------
Table VIII-8.  Tall Oil Rosin, Fatty Acids, and Pitch Producing Plants




                      COST SUMMARY FOR NEW SOURCES




                DIRECT DISCHARGERS TREATMENT TECHNOLOGY 1
Unit
Equalization
Pump Stations (2)
pH Adjustment
(PH->2.5)
Polymer Addition
Air Flotation
Neutralization
Activated Sludge
Nutrient Addition
Monitoring Station
Control House
Land
Engineering
Contingency
Sludge Disposal
Labor
Insurance and Taxes

Capital
($)
275,000
76,000
39,300
6,500
142,000
46,800
629,000
23,800
16,390
31,000
10,000
192,870
223,800



Flow =0.6 MGD
Operating
($/YR)
24,000
8,600
54,040
22,500
5,300
111,050
72,170
15,000
2,170
1,600



8,000
20,000
38,580

Energy
($/YR)
16 , 000
2,680
810
750
580
810
37 , 500
1,250
530
350






   TOTAL
1,711,960
383,010
                                                                 61,260
                            105

-------
Table VIII-9.  Tall Oil Rosin, Fatty Acids, and Pitch Producing Plants
                      COST SUMMARY FOR NEW SOURCES
                DIRECT DISCHARGERS TREATMENT TECHNOLOGY 4
                                              Flow =0.6 MGD
  Unit
Capital
  ($)
Operating
 ($/YR)
Energy
($/YR)
Activated Carbon                   2,200,000
Land                                  10,000
Engineering                          330,000
Cont ingency                          381,000
Sludge Disposal (Spent Carbon)
Labor
Insurance and Taxes
   TOTAL                           2,921,000
              400,000
                9,600
               20,000
               66,300
                44,000
                            44,000
                           106

-------
Table VIII-10.
Tall Oil Rosin, Fatty Acids, and Pitch and Rosin Based
Derivatives

      COST SUMMARY FOR NEW SOURCES

DIRECT DISCHARGERS TREATMENT TECHNOLOGY 1
Unit
Equalization
Pump Stations (2)
pH Adjustment
(pH->2.5)
Polymer Addition
Air Flotation
Neutralization
Activated Sludge
Nutrient Addition
Monitoring Station
Control House
Land
Engineering
Cont ingency
Sludge Disposal
Labor
Insurance and Taxes

Capital
($)
246,000
70,000
26,200
6,300
205,000
40,200
449,000
24,800
16,390
31,000
10,000
167,240
193^20



Flow -0.5 MGD
Operating
($/YR)
20,800
7,800
28,660
19,800
8,700
92,730
39,250
17,500
2,170
1,600



4,000
20,000
33,750

Energy
($/YR)
13,500
2,300
800
750
1,400
800
19,000
1,250
530
350






   TOTAL
                   1,485,950
296,760
                                                                 40,680
                          107

-------
Table VIII-11.
Tall Oil Rosin, Fatty Acids, and Pitch and Rosin Based
Derivatives

      COST SUMMARY FOR NEW SOURCES

DIRECT DISCHARGERS TREATMENT TECHNOLOGY 2
Unit
Metals Removal at Source
Monitoring Station
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL

Capital
($)
40,100
16,390
10,000
8,474
9,973



84,937
Flow - 0.1 MGD
Operating
($/YR)
59,840
2,170



31 , 000
20,000
1,995
115,005

Energy
($/YR)
2,870
530






3,400
                           108

-------
Table VIII-12.
Tall Oil Rosin, Fatty Acids, and Pitch and Rosin Based
Derivatives
      COST SUMMARY FOR NEW SOURCES
DIRECT DISCHARGERS TREATMENT TECHNOLOGY 3
  Unit
                                              Flow - 0.5 MGD
                     Capital
                       ($)
Operating
 (9/YR)
Energy
($/YR)
Metals Removal End of Pipe
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
   TOTAL
                      98,000
                      10,000
                      14,700
                      18,405
  258,060
                      141,105
   62,000
   20,000
    3,240
  343,300
 2,990
 2,990
                        109

-------
Table VIII-13.
Tall Oil Rosin, Fatty Acids, and Pitch and Rosin Based
Derivatives
      COST SUMMARY FOR NEW SOURCES
DIRECT DISCHARGERS TREATMENT TECHNOLOGY 4
  Unit
                                              Flow =0.5 MGD
                     Capital
                       ($)
Operating
 ($/YR)
Energy
($/YR)
Activated Carbon                   2,070,000
Land                                  10,000
Engineering                          310,500
Cont ingency                          358,575
Sludge Disposal (Spent Carbon)
Labor
Insurance and Taxes
   TOTAL                           2,749,075
                                   320,000
                                     8,000
                                    20,000
                                    62,400
                                   410,400
                39,400
                39,400
                         110

-------
Table VIII-14.  Tall Oil Rosin, Fatty Acids, and Pitch and Rosin Based
                Derivatives

                      COST SUMMARY FOR NEW SOURCES

              INDIRECT DISCHARGERS TREATMENT TECHNOLOGY 1


Unit
Metals Removal at Source
Monitoring Station
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL

Capital
($)
40,100
16,390
10,000
8,473
11,245



86,208
Flow * 0.1 MGD
Operating
($/YR)
59,840
2,170



31,000
20,000
1,995
115,005

Energy
($/YR)
2,870
530






3,400
Table VIII-15.  Tall Oil Rosin, Fatty Acids, and Pitch and Rosin Based
                Derivatives

                      COST SUMMARY FOR NEW  SOURCES

              INDIRECT DISCHARGERS TREATMENT TECHNOLOGY 2


Unit
Metals Removal End of Pipe
Monitoring Station
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL

Capital
($)
98,000
16,390
10,000
17,158
21,232



145,622
Flow » 0 .5 MGD
Operating
($/YR)
258,060
2,170



62,000
20 , 000
3,732
345,962

Energy
($/YR)
2,990
530






3,520
                           111

-------
Table VIH-16.  Sulfate Turpentine




                      COST SUMMARY FOR NEW SOURCES




                DIRECT DISCHARUJSRS TREATMENT  TECHNOLOGY  1
Unit
Equalization
Pump Stations (3',
Ne utral izat ion
Nutrient Addition
Activated Sludge
Monitoring Station
Control House
Land
Engineering
Contingency
Sludge Disposal
Labor
Insurance and Taxes
TOTAL

Capital
($)
220,000
96,000
34,000
27,500
1,005,000
16,390
62,000
10,000
219,134
255,004



1,945,028
Flow - 0.4 MGD
Operating
($/YR)
17,500
10,200
1,350
39,000
192,600
2,170
3,200



105,825
20,000
7,950
399,795

Energy
($/YR)
11,000
3,000
790
1,250
132,400
530
700






149,670
                          112

-------
Table VIII-17.  Sulfate Turpentine




                      COST SUMMARY FOR NEW SOURCES




                DIRECT DISCHARGERS TREATMENT TECHNOLOGY 2


Unit
Metals Removal at Source
Monitoring Station
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL

Capital
($)
40,100
16,390
10,000
8,480
11 , 250



86,220
Flow - 0.1 MGD
Operating
($/YR)
59,840
2,170



31,000
20,000
2,000
115,010

Energy
($/YR)
2,870
530






3,400
Table VIII-18.  Sulfate Turoentine




                      COST SUMMARY FOR NEW SOURCES




                DIRECT uXSCHARGERS TREATMENT TECHNOLOGY 3


Unit
Metals Removal End of Pipe
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
insurance and Taxes
TOTAL

Capital
($)
86,000
10,000
12,900
16,335



125,235
Flow « 0.4 MGD
Operating
($/YR)
217,150



48,000
20,000
2,880
288,030

Energy
($/YR)
2,960






2,960
                           113

-------
Table VIII-19.  Sulfate Turpentine




                      COST SUMMARY FOR NEW SOURCES




                DIRECT DISCHARGERS TREATMENT TECHNOLOGY 4


Unit
Activated Carbon
Land
Engineering
Contingency
Sludge Disposal (Spent Carbon)
Labor
Insurance and Taxes
TOTAL

Capital
($)
1,950,000
10,000
292,500
337,875



2,590,375
Flow - 0.4 MGD
Operating
($/YR)
250,000



6,400
20,000
58,800
335,200

Energy
($/YR)
35,000






35,000
Table VIII-20.  Sulfate Turpentine




                      COST SUMMARY FOR NEW SOURCES




              INDIRECT DISCHARGERS TREATMENT TECHNOLOGY 1


Unit
Metals Removal at Source
Monitoring Station
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL

Capital
($)
40,100
16,390
10,000
8,480
11,250



86 , 220
Flow ~ 0.1 MGD
Operating
($/YR)
59,840
2,170



31,000
20,000
2,000
115,010

Energy
($/YR)
2,870
530






3,400
                           114

-------
Table VIII-21.  Sulfate Turpentine
                      COST SUMMARY FOR NEW SOURCES
              INDIRECT DISCHARGERS TREATMENT TECHNOLOGY 2
  Unit
Capital
  ($)
                                              Flow - 0.4 MGD
Operating
 ($/YR)
Energy
($/YR)
Metals Removal End of Pipe
Monitoring Station
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
   TOTAL
 86,000
 16,390
 10,000
 15,360
 19,170
  217,150
    2,170
146,920
   59,000
   20,000
    3,370
  301,690
 2,960
   530
 3,490
                          115

-------
Table VIII-22,
Tall Oil Rosin, Fatty Acids, and Pitch? Rosin Based
Derivatives and Sulfate Turpentine

      COST SUMMARY FOR NEW SOURCES

DIRECT DISCHARGERS TREATMENT TECHNOLOGY 1
Unit
Equalization
Pump Stations (2)
pH Adjustment
(pH->2.5)
Polymer Addition
Air Flotation
Activated Sludge
Nutrient Addition
Neutralization
Monitoring Station
Control House
SUBTOTAL (1)
Engineering
Land
SUBTOTAL (2)
Contingency

Capital
($)
246,000
70,000
26 , 200

6,300
205,000
550,000
33,000
40,200
16,390
• 31,000
1,224,090
183,620
10,000
1,417,710
212,660
Flow - 0.5 MGD
Operating
($/YR)
20 , 800
7,800
28,660

19,800
8,700
114,750
52,000
92,730
2,170
1,600
349,010





Energy
(S/YR)
13,500
2,300
800

750
1,400
87,660
1,250
800
530
350
109,340




Insurance and Taxes
Sludge Disposal
Labor

   TOTAL
                   1,630,370
 37,020
  4,000
 20,000

410,030
109,340
                          116

-------
Table VIII-23.  Tall Oil Rosin, Fatty Acids, and rii.cn; Rosin Based
                Derivatives and Sulfate Turpentine

                      COST SUMMARY FOR NEW SOURCES

                DI8ECT DISCHARGERS TREATMENT TECHNOLOGY 2
                     Sulfate Turpentine Processing

                                             Flow = 0.075 MGD
Unit
Metals Removal at Source
Monitoring Station
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL
Capital
($)
24,400
16,390
10,000
6,120
8,540



65,450
Operating
(S/YR)
29,945
2,170



26,000
20,000
1,530
79,645
Energy
($/YR)
1,990
530






2,520
                   Rosin Based Derivatives Processing
                                              Flow » 0.1 MGD
Unit
Metals Removal at Source
Monitoring Station
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL
Capital
($)
27,700
16,390
10,000
6,620
9,110



69,820
Operating
($/YR)
37,075
2,170



31,000
20,000
1,630
91,875
Energy
($/YR)
1,990
530






2,520
                          117

-------
Table VIII-24.
Tall Oil Rosin, Fatty Acids, and Pitch; Rosin Based
Derivatives and Sulfate Turpentine

      COST SUMMARY FOR NEW SOURCES
DIRECT DISCHARGERS TREATMENT TECHNOLOGY 3
  Unit
                                              Flow -0.5 MGD
                                     Capital
                                 Operating
                                  ($/YR)
              Energy
              ($/YR)
Metals Removal End of Pipe
Land
Engineering
Contingency
Sludge Disposal  (Metals)
Labor
Insurance  and Taxes
   TOTAL
                      70,500
                      10,000
                      10,575
                      13,661
149,500
                      104,736
 62,000
 20,000
  2,415
233,915
2,050
2,050
                           118

-------
Table VIII-25.
Tall Oil Rosin, Fatty Acids, and Pitch; Rosin Based
Derivatives and Sulfate Turpentine

      COST SUMMARY FOR NEW SOURCES

DIRECT DISCHARGERS TREATMENT TECHNOLOGY 4

Unit
Activated Carbon
Land
Engineering
Contingency
Sludge Disposal (Spent Carbon)
Labor
Insurance and Taxes
TOTAL

Capital
($)
2,172,000
10,000
325,800
376,170



2,883,970
Flow =0.5 MGD
Operating
($/YR)
323,200



8,000
20,000
65,460
416,660

Energy
($/YR)
40,700






40,700
                         119

-------
Table VIII-26.  Tall Oil Rosin, Fatty Acids, and Pitch; Rosin Based
                Derivatives and Sulfate Turpentine

                      COST SUMMARY FOR NEW SOURCES

              INDIRECT DISCHARGERS TREATMENT TECHNOLOGY 1
                     Sulfate Turpentine Processing
  Unit
                                             Flow » 0.075 MGD
                                     Capital
           Operating
            ($/YR)
             Energy
             ($/YR)
Metals Removal at Source
Monitoring Station
Land
Engineering
Contingency
Sludge Disposal  (Metals;
Labor
Insurance and Taxes

    TOTAL
24,400
16,390
10,000
 6,120
 8,540
65,450
29,945
 2,170
26,000
20,000
 1,530

79,675
1,990
  530
2,520
                    Rosin Based Derivatives  Processing
                                               Flow =0.1  MGD
Unit
Metals Removal at Source
Monitoring Station
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL
Capital
($)
27,700
16,390
10,000
6,620
9,110



69,820
Operat ing
($/YR)
37,075
2,170



31,000
20 , 000
1,630
91,875
Energy
($/YR)
1,990
530






2,520
                             120

-------
Table VIII-27.  Tall Oil Rosin, Fatty Acids, and Pitch; Rosin Based
                Derivatives and Sulfate Turpentine
                      COST SUMMARY FOR NEW SOURCES
              INDIRECT DISCHARGERS TREATMENT TECHNOLOGY 2
  Unit
                                              Flow -0.5 MGD
Capital
  ($)
Operating
 ($/YR)
Energy
($/YR)
wetals Removal End of Pipe
Land
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
   •i-OTAL
 70,500
 10,000
 10,575
 13,661
  149,500
104,736
   62,000
   20,000
    2,415
  233,915
 2,050
 2,050
                          121

-------
Table VIII-28.
                     TREATMENT OPTION FOR PLANT 151




                              TECHNOLOGY 2
Rosin Based
Unit
Metals Removal at Source
Monitoring Station
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL
Sulfate
Unit
Metals Removal at Source
Monitoring Station
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
Derivatives Process
Flow = 0.133 MGD
Capital Operating
($) ($/YR)
29,650 46,109
16,390 2,170
6,910
7,942
32,000
20,000
1,381
60,892 101,660
Turpentine Process
Flow = 0.012 MGD
Capital Operating
($) ($/YR)
15,300 12,447
16,390 2,170
4,760
5,467
6,000
20,000
950


Energy
($/YR)
2,025
530
2,555


Energy
($/YR)
1,960
530
   TOTAL
42,217
41,567
2,490
                            122

-------
Table VIII.29
                     TREATMENT OPTION FOR PLANT 151




                              TECHNOLOGY 3
Unit
Metals Removal End of Pipe
Neutralization
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes

Capital
($.)
87,500
22,700
16,530
19,010



Flow — 0.58 MGD
Operating
($/YR)
276,550
1,250


65,000
20,000
3,310

Energy
($/YR)
2,190
800





    TOTAL
145,740
366,110
2,990
                             123

-------
Table  VIII-30,
                      TREATMENT OPTION FOR PLANT 090
                               TECHNOLOGY 2
   Unit
Capital
  <$)
                                              Flow—0.005  MGD
Operating
  ($/YR)
Er-irgy
($/YR)
Metals Removal at Source
Neutralizat ion
Engineering
Contingency
Sludge Disposal (Mecals)
Labor
Insurance and Taxes
 14,560

  2,180
  2,510
 11,313
                 2,500
                20,000
                   440
2,058
   TOTAL
 19,250
                                                34,250
                 2,058
                           124

-------
Table VIII-31
                     TREATMENT OPTION FOR PLANT 090
                              TECHNOLOGY 3
   Unit
Capital
  ($)
                                             Flow—0.005 MGD
Operating
  ($/YR)
Energy
($/YR)
Metals Removal End of Pipe
Neutralizat ion
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
 14,560

  2,180
  2.51C
 11,313
                 2,500
                20,000
                   440
2,058
   TOTAL
 19,250
 34,250
2,058
                            125

-------
Table VIII-32.
                     TREATMENT OPTION FOR PLANT 686




                              TECHNOLOGY 2
                                              Flow - .001 MGD
Unit
Metals Removal at Source
Monitoring Station
Engineering
Cont ingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
Capital
($)
12,100
16,390
4,280
4,915



Operating
($/YR)
9,107
2,170


500
20,000
854
Energy
($/YR)
1,910
530





   TOTAL
37,685
32,631
2,440
                            126

-------
Table VIII-33
                     TREATMENT OPTION FOR PLANT 686




                              TECHNOLOGY 3
Unit
Metals Removal End of Pipe
Neutralization
Engineering
Cont ingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes

Capital
($)
33,600
10,400
6,600
7,590



Flow— 0.12 MGD
Operating
($/YR)
64,930
4,930


34,000
20,000
1,320

Energy
($/YR)
2,130
780





   TOTAL
58,190
125,180
2,910
                           127

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Table VIII-34.
                     TREATMENT OPTION FOR PLANT 698
                              TECHNOLOGY 2
Unit
Metals Removal at Source
Monitoring Station
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL

Capital
($)
48,400
16,390
9,719
11,180
85,689
Flow =0.52 MGD
Operat ing
($/YR)
154,345
2,170
41,000
20,000
1,940
219,460

Energy
($/YR)
2,010
530
2,540
TECHNOLOGY 3
Unit
Metals Removal End of Pipe
Engineering
Contingency
Sludge Disposal (Metals)
Insurance and Taxes

Capital
($)
216,500
32,470
37,350
Flow - 1.93 MGD
Operat ing
($/YR)
937,245
92,150
6,480

Energy
($/YR)
3,490
   TOTAL
286,320
1,035,875
3,490
                             128

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Table VII1-35.
                     TREATMENT OPTION FOR PLANT 948
                              TECHNOLOGY 2


Unit
Metals Removal at Source
Monitoring Station
Engineering
Cont ingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL


Unit
Metals Removal End o£ Pipe
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL

Capital
($)
25,300
16,390
6,260
7,190



55,140
TECHNOLOGY 3

Capital
($)
39,200
5,880
6,762



51,842
Flow - 0.08 MGD
Operat ing
($/YR)
31,240
2,170


27,000
20 , 000
1,250
81,660

Flow * 0.168 MGD
Operat ing
($/YR)
89,980


41,000
20,000
1,176
152,156

Energy
($/YR)
1,990
530





2,520


Energy
($/YR)
2,120





2,120
TECHNOLOGY 4

Unit
Filtration and Activated
Carbon Adsorption
Land
Engineering
Contingency

Capital
($)

1,470,000
5,000
220,500
254,325
Sludge Disposal (Spent Carbon)
Labor
Insurance and Taxes
TOTAL


1,949,825
Flow - 0.168 MGD
Operating
($/YR)

107,000



8,000
320 , 500
44,250
479,750

Energy
($/YR)

23,800






23,800
                             129

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Table VIII-36.
                     TREATMENT OPTION FOR PLANT 416




                              TECHNOLOGY 4
Unit
Filtration & Activated
Carbon Adsorption
Land
Engineering
Contingency
Sludge Disposal (Spent Carbon)
Labor
Insurance and Taxes

Capital
($)

950,000
5,000
143,250
164,740



Flow — 0.042 MGD
Operating
($/YR)

38,000



670
150,000
28,650

Energy
($/YR)

15,500






   TOTAL
1,262,990
217,320
15,500
                           130

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Table VIII-37
                     TREATMENT OPTION FOR PLANT 333
                              TECHNOLOGY 4
   Unit
  Capital
    ($)
                                             Flow—0.6 MGD
Operating
  ($/YR)
 Energy
 ($/YR)
Filtration & Activated
  Carbon Adsorption           2,200,000
Land                              5,000
Engineering                     330,750
Cont ingency                     380,360
Sludge Disposal (Spent Carbon)
Labor
Insurance and Taxes
                 380,000
                45,000
                   9,600
                 340,000
                  79,910
   TOTAL
2,916,110
 66,150
45,000
                            131

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Table VIII-38.
                     TREATMENT OPTIONS FOR PLANT 121
                              TECHNOLOGY 2
Unit
Metals Removal at Source
Monitoring Station
Engineering
Contingency
Sludge Disposal (Metals)
Labor
Insurance and Taxes
TOTAL

Capital
($)
47 , 700
16,390
9,620
11,060
84,770
Flow - 0.288 MGD
Operating
($/YR)
89,168
2,170
45,000
20,000
1,920
158,260

Energy
($/YR)
2,030
530
2,560
TECHNOLOGY 3
Unit
Metals Removal End of Pipe
Neutralization
Engineering
Contingency
Sludge Disposal (Metals)
Insurance and Taxes
TOTAL

Capital
($)
133,500
36,000
24,425
29,090

223,020
Flow - 1.18 MGD
Operating
($/YR)
493,320
40,423
80,000
5,090
618,830

Energy
($/YR)
2,340
860

3,200
TECHNOLOGY 4
Unit
Filtration and Activated
Carbon Adsorption
Land
Engineering
Contingency
Sludge Disposal (Spent Carbon)
Labor
Insurance and Taxes
TOTAL

Capital
($)

3,000,000
5,000
450,750
518,360
3,974,110
Flow * 1.18 MGD
Operat ing
($/YR)

800,000
18,880
420,000
90,150
1,329,080

Energy
($/YR)

73,000
73,000
                            132

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Table VIII-39
                     TREATMENT OPTION FOR PLANT 087




                              TECHNOLOGY 2
Unit
Metals Removal at Source
Neutralization
Engineering
Cont ingency
Sludge Disposal (metals)
Labor
Insurance and Taxes

Capital
($)
57,500
16,800
11,150
12,820



Flow — 0.325 MGD
Operating
($/YR)
159,210
11,810


53,500
20,000
2,230

Energy
($/YR)
2,140
785





   TOTAL
98,270
246,750
2,925
                            133

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Table VIII-40.
                     TREATMENT OPTION FOR PLANT 087
                              TECHNOLOGY 3

                                             Flow—0.325 MGD
                                Capital        Operating        Energy
   Unit                           <$)            ($/YR)         ($/YR)
Metals Removal End of Pipe       57,500        159,210          2,140
Neutralization                   16,800         11,810            785
Engineering                      11,150
Contingency                      12,820
Sludge Disposal (metals)                        53,500
Labor                                           20,000
Insurance and Taxes                              2,230

   TOTAL                         98,270        246,750          2,925
                           134

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Table VIII-41.




                     TREATMENT OPTION FOR PLANT 266




                              TECHNOLOGY 3






                                             Flow—0.072 MGD
Unit
Metals Removal End of Pipe
Neutralization
Engineering
Cont ingency
Sludge Disposal (Metals)
Labor
Insurance and taxes
Capital
($)
26,800
8,500
5,295
6,090



Operating
($/YR)
49,680
3,325


25,000
20,000
1,060
Energy
($/YR)
2,100
770





   TOTAL                         46,685          99,065           2,870
                            135

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Table VIII-42.
                     TREATMENT OPTION FOR PLANT 800
                              TECHNOLOGY 4
Flow— 0.18 MGD
Capital
Unit ($)
Operating
($/YR)
Energy
($/YR)
Filtration & Activated
   Carbon Adsorption           1,500,000
Land                               5,000
Engineering                      225,750
Contingency                      259,610
Sludge Disposal  (Spent Carbon)
Labor
Insurance and Taxes
   TOTAL                       1,990,360
115,000
24,000
  2,800
235,000
 45,150
397,950
24,000
                            136

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Table VIII-43.
                     TREATMENT OPTION FOR PLANT 606
                              TECHNOLOGY 4
Flow— 0.155 MGD
Capital
Unit ($)
Operating
($m>
Energy
<$/YR)
Filtration & Activated
   Carbon Adsorption           1,450,000         100,000         23,000
Land                               5,000
Engineering                      218,250
Contingency                      250,990
Sludge Disposal  (Spent Carbon)                     2,480
Labor                                            225,000
Insurance and Taxes                              43,650
   TOTAL                       1,924,240         371,130         23,000
                            137

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Table VIII-44.

                     TREATMENT OPTION FOR PLANT 693
                              TECHNOLOGY 4
Flow — 0.097 MGD
Capital
Unit ($)
Operating
($/YR)
Energy
($/YR)
Filtration & Activated
   Carbon Adsorption           1,240,000        680,000          19,700
Land                               5,000
Engineering                      186,750
Contingency                      214,760
Sludge Disposal (Spent Carbon)                    1,550
Labor                                           200,000
Insurance and Taxes                              37,350
   TOTAL                       1,651,510        918,900          19,700
                            138

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                              SECTION IX

        EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION
         OF THE BEST PRACTICABLE CCNTROL TECHNOLOGY CURRENTLY
              AVAILABLE—EFFLUENT LIMITATIONS GUIDELINES
GENERAL
The  effluent  limitations  which were to be achieved by July 1, 1977,
specified the degree of  effluent  reduction  attainable  through  the
application  of  the  Best  Practicable  Control  Technology Currently
Available (EPT).  The best practicable  control  technology  currently
available  generally  was  based upon the average of the best existing
performance by plants of  various  sizes,  ages,  and  unit  processes
within the industry.  This average was not based upon a bread range of
plants   within   the  Gum  and  Wood  Chemicals  Industry,  but  upon
performance  levels  achieved  by  exemplary  plants.   In  industrial
categories   where   present  control  and  treatment  practices  were
uniformly inadequate, a higher level of control than any currently  in
place  may have been required if the technology to achieve such higher
level could be practically applied.

In establishing the  Best  Practicable  Control  Technology  Currently
Available Effluent Limitations Guidelines, the Agency was to consider:

     1,  The total cost of applying the technology ir relation to the
         effluent reduction benefits achieved froir such
         application;

     2.  The age and size of equipment and facilities involved;

     3.  The processes employed;

     4,  The engineering aspects of applying various types of
         control techniques;

     5.  Process changes; and

     6.  Non-water quality environmental impact  (including energy
         requirements).

EPT  emphasized  treatment  facilities  at  the  end  of manufacturing
processes, but also included control technologies within  the  process
itself when the latter were normal practice within an industry.

A  further  consideration  was  the degree of'economic and engineering
reliability which the technology must have demonstrated  in  order  to
have  been  "currently  available."   As  a  result  of  demonstration
projects, pilot plants, and general use, there  must  have  existed   a
                                  139

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high   degree   of   confidence    in   the  engineering   and  economic
practicability of the technology at the beginning of construction  for
the control facilities.

Age and Size of Equipment and Facilities

As indicated previously in this repcrt, there appeared to have been no
significant  data  to  substantiate that either the age or the size of
the Gum and Wood Chemicals plant justified  special  consideration  of
different effluent limitations.

IDENTIFICATION OF BEST PRACTICABLE TECHKQLCGY CURRENTLY AVAILABLE

EPT  regulations were published Interim Final on May 18,  1976, for the
Char and Charcoal Briquets; Gum  Resin  and  Turpentine;  Wood  Rosin,
Turpentine,  and  Pine  Oil;  Tall  Cil Rosin, Fatty Acids, and Pitch;
Essential  Oils;  and  Rosin-Based  Derivatives  subcategcries.    The
following  unit operations and unit processes served as the technology
base for these regulations:

     Oil/water separation.
     Equalization;
     Dissolved air flotation (Wood Rosin and Tall Oil) ;
     Secondary biological treatment (Activated Sludge); and
     Polishing Pond.

The current review of effluent guidelines limitations for the Gum  and
Wocd  Chemicals  Industry  has  added  the  new subcategory of Sulfate
Turpentine  to  the  regulations.    Two  options  were  evaluated  for
developing the effluent limitations for this subcategory.

The  first  option would have required the industry to submit three or
four years of effluent data (flow, EOD5, TSS, and pH)   and  production
data  (types  and  amounts  of  end-products).   The  Agency  use this
information to correlate production and effluent quality  and  develop
long-term   treatability;   additionally,  the  Agency  would  develop
variability factors for use in deriving statistically accurate maximum
30-day averages and maximum  daily  effluent  limitations  guidelines.
Several  problems  were apparent with this approach.  Direct discharge
sulfate turpentine facilities  are  all  associated  with  ether  unit
operations in the Gum and Wood Chemicals Industry and their wastewater
streams  are  comingled.    Industry  compilation  of  the data and the
statistical review by the  Agency   would  have  been  very  time-  and
manpower-intensive.

The  second option involved reviewing the rationale for the previously
promulgated regulations.   See Table IX-1.   The basis of this rationale
had been  long-term  BODS  data  and  short-term  TSS  data  frcm  one
activated  sludge  treatment  system in the industry,  with performance
                                 140

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factors transferred from the Petroleum Refining Point Source Category.
In evaluating the rationale, the Agency would use the production  data
from the plants and the promulgated effluent guidelines limitations to
develop  niass  limitations.    The  Agency  then  would  compare  these
limitations to the actual data supplied by plants in response  to  the
308 survey questionnaire.  If plants with BPT or equivalent biological
treatment  in-place  achieved  the  limitations,  they  would  form  a
reasonable basis for  applying  the  same  rationale  to  the  Sulfate
Turpentine subcategory.

The  Agency  chose  Option  Two  because  it significantly reduced the
effort required by individual plants and would  allow  review  of  the
currently   existing  effluent  limitations  guidelines-   Table  IX-2
presents the results of the analysis.  The  review  demonstrated  that
the  limitations were consistently achievable by the EPT or equivalent
biological treatment systems.  The Agency is therefore basing EPT  for
the Sulfate Turpentine subcategory en the EPT treatment system used in
the 1976 regulations.

This  review  has demonstrated that the methodology for developing the
original  BPT  effluent  limitations  guidelines  is  reasonable   and
demonstrably  achievable.   To develop effluent limitations guidelines
for the sulfate turpentine subcategory, the Agency obtained raw  waste
load   data  from  an  indirect  discharge  sulfate  turpentine  plant
exhibiting good water use.  These data were compiled  to  establish  a
long-term  raw waste load and the resulting loads then were reduced by
90 percent, reflecting BPT long-term average  daily  effluent  values.
EPA  applied  performance  factors  from  the  Petroleum  Pcint Scurce
Category to the BPT long-term average daily effluent values to  derive
the  maximum  30-day  average  and  maximum  day  effluent limitations
guidelines.  These values are presented in Table IX-3.

These values plus the previously promulgated guidelines were then used
to calculate mass loading limitations for direct discharge plants with
sulfate turpentine unit operations.  These  were  then  compared  with
data  from  the  direct  discharging  plants  with  sulfate turpentine
production.   Based  on  this  analysis,  the   effluent   limitations
guidelines can be achieved by existing plants by implementation of the
EPT technology.
                                 141

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Table IX-1.  Review of Individual Plants
     *  Eight direct discharging plants

        Three plants have products that are not in the Gum
        and Wood Chemicals Industry

        Two plants have insufficient data due to plant
        transitions

        Three plants were checked for compliance:

           Plant A
             In compliance
                   10 of 12 months
             TSS--0 of 12 months

           Plant B
             In compliance
             BOD,- — 12 of 12 months
             TSS — 0 of 12 months

           Plant C
             In compliance
             BODe — 6 of 12 months
             TSS — 0 of 12 months
                             142

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                              SECTION X

       EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF
       THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE-
                   EFFLUENT LIMITATIONS GUIDELINES

INTRODUCTION

The  effluent  limitations which must be achieved by July 1, 1984, are
not based on an average of the best performance within  an  industrial
category,  but  on  the  very  best  control  and treatment technology
employed by a specific point source within the industrial category  or
subcategory   or   by  another  industry  from  which  it  is  readily
transferable.  The Agency must determine the availability  of  control
measures  and  practices  to  eliminate  the  discharge of pollutants,
taking into account the cost of such elimination.

EPA also considers:

1.  The age of the equipment and facilities involved;
2.  The process employed;
3,  The engineering aspects of applying various types of
    control techniques;
4.  Process changes;
5.  The cost of achieving the effluent reduction resulting from
    applying the technology; and
6.  Non-water quality environmental  impact  (including energy
    requirements) .

BAT emphasizes in-process controls as well  as  control  or  additional
treatment  techniques  employed  at  the end of the  production  process;
including those which are not coirmon industry practice.

This level of technology considers those plant processes  and  control
technologies  which  at the pilot plant, semi-works, and  ether levels,
have demonstrated  sufficient technological  performance   and   economic
viability to justify investing in such facilities.  BAT represents the
highest  degree  of  demonstrated  control  technology for plant-scale
operation, up to and including "no  discharge" of pollutants.   Although
economic factors are considered, this  level of control is intended  to
incorporate   the   top-of-the-line  current  technology,  subject  to
limitations imposed by economic  and  engineering   feasibility.    There
may  be  some technical risk, however, with respect to performance and
certainty of costs; some technologies may require  process  development
and adaptation  before application at a specific plant site.
                                  145

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 IDENTIFICATION   OF   THE   BEST   AVAILABLE  TECHNOLOGY  ECONOMICALLY
 ACHIEVABLE                           '	

 EAT uses BPT as a basis for   further improvements.    The  Agency  has
 selected  the  treatment  of  toxic  metals  by   pH  adjustment  to form
 hydroxide floes and  the  treatment  of  toxic  organics  by  granular
 activated   carbon   columns   as  candidate  technologies.   EPA  has
 determined,  however,  that the use of GAC is economically  damaging  to
 the  industry,   and  has  not  proposed  it  as   a   treatment process.
 Conventional pollutants and  the tcxic organics are treated adequately
 by the  biological treatment  required by BPT.

 Metals  Removal

 Three  metals  were identified as a significant  prcblem—copper,  zinc,
 and nickel.   These metals enter the waste stream through their  use  as
 catalysts   in    sulfate  turpentine   and   rosin-based  derivatives
 prccessing.   Treatment  of metals  in  the  particular  process   streams
 where  they   are  used  is the most economical  method,  because of  lower
 flews.

 DEVELOPMENT  OF  EAT EFFLUENT  LIMITATIONS

 The effluent limitations  were  developed  for   the  control  technology
 options  in   a   building   block fashion,  using EPT technology (oil and
 grease  removal,  biological treatment) as a  base.

 After establishing  the  BPT base,  the  Agency selected a plant  in   each
 subcategory   that   fulfilled   the  EPT requirements.  The  manufacturing
 processes  and sampling  results for the  plant were studied tc determine
 the incidence of  toxic  pollutants.    This   analysis  showed  that   BAT
 regulations   for toxic  organic  pollutants would  net  be necessary;  wood
 rosin and  tall  oil  distillation wastewaters showed reduced  levels  of
 toxic  pollutants when  treated with the required EPT treatment  scheme.
 The Agency concluded that no further  treatment   for  toxic  pollutants
 was required.

 The  remaining  two  subcategories, sulfate turpentine and rosin-based
 derivatives, use metal  catalysts - copper, nickel, and zinc -   in   the
 prccessing.   These metals appeared in  the wastewater effluents of  the
 plants.   The use of these catalysts is  process-specific.  Cne plant  in
 the sulfate turpentine industry has a   metals  removal  unit  for   the
 process   in  which  a metal catalyst is used.  Prior to treatment, the
 initial  concentration  was  155  mg/1;   metals  removal  reduced  the
 concentration  to   1 mg/1.  To supplement this information, the Agency
reviewed the wastewater characteristics and the treatability data  from
 several  other industrial categories which already  treated  for  these
metals.     This   review   indicated  that  the  wastewater  from  the
 electroplating  industry  appears  to   resemble   more    closely   the
                                 146

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wastewater   from  gum  and  wood  chemicals.   Several  of  the  same
characteristics which may present treatability problems  (i.e; oil  and
grease   and   chelating   agents)   also   appear  in  electroplating
wastewaters.  Therefore, EPA has transferred the numerical limitations
fcr copper, nickel, and zinc  from  the  Electroplating  Point  Source
Category to the Gum and Wood Chemicals Point Source Category.

PECULATED POLLUTANTS

1)   Non-toxic,  non-conventional  pollutants—There are no non-toxic,
non-conventional pollutants limited by these proposed regulations.

2)  Toxic pollutants—The toxic pollutants  expressly  controlled  for
direct  dischargers  in  two  subcategcries  are ccpper, zinc, nickel,
which are subject to numerical limitations expressed in milligrams per
liter of pollutant.

SIZE, AGE, PROCESSES EMPLOYED, LOCATION OF FACILITIES

In the Gum and Wood Chemicals Industry, size, age, and location of the
plants  do  not  affect  the  application  of  BAT  technology.    The
industrial  process  employed  does  affect EAT technology in that two
sufccategories, wood rosin and tall oil, dc not use metal catalysts and
do not require metals removal.  The remaining  subcategories,  sulfate
turpentine  and  rosin-based  derivatives, do use metals in processing
and require metals removal treatment.

TOTAL COST CF APPLICATION

The statutory assessment  of  BAT  "considers"  costs,  but  does  not
require  a balancing of costs against effluent reduction benefits (see
Weyerhaeuser v. Costle,  supra) .   In  developing  the  proposed  BAT,
however,  EPA  has  given  substantial weight to the reasonableness of
costs.  The Agency has considered the volume and nature cf discharges,
the volume and nature of discharges expected after application of BAT,
the general environmental effects of the pollutants, and the costs and
eccnomic impacts of the required pclluticn control levels.

Twelve plants in the  Gum  and  Wood  Chemicals  Industry  are  direct
dischargers  subject  to BAT standards for existing sources-  Eight of
these plants are multiple-subcategcry plants (i.e.,  plants  producing
in  more  than  one subcategory).  The estimated costs assume that all
plants have BPT technology in-place.  A survey of  sulfate  turpentine
and  rosin-based derivatives plants indicates that metals removal will
be required at two of the 12 plants.  Total investment costs  to  meet
proposed  BAT  will  be  approximately $226 thousand with total annual
operating costs of about $460 thousand.
                                 147

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EPA expects the achievement of BAT regulations to remove approximately
60 pounds per day of zinc from twc resin-based derivatives plants.
ENGINEERING
ACHIEVABLE
ASPECTS  OF  BEST   AVAILABLE   TECHNOLOGY   ECONOMICALLY
Metals  removal is the major treatment process for EAT and will impact
only the two  subcategories  -  rosin-based  derivatives  and  sulfate
turpentine  -  where  metal  catalysts are used.  The use of metals is
process specific and not distributed throughout the whole category.

The most accepted method of metals removal  is  the  precipitation  of
metal salts.  These include hydroxides, sulfides, and carbonates.  The
one plant in the industry that currently removes metals uses hydroxide
salts for the precipitation process.  The sulfide salts produce better
removal rates, but the system is ir.cre complex and the stability of the
sludges  has  not  been  determined.   Carbonate  salts have the least
effective removal rate.

Process Changes

The most cost- and performance-effective waste treatment  approach  is
to prevent the entry of pollutants into the waste stream, or to remove
the  pollutants from the source stream before dilution, contamination,
or other interaction occurs in the mixing of  several  waste  streams.
Aside   from  in-plant  waste  streair  isolaticn  and  collection  for
treatment, no in-plant process changes are required for achievement of
the recommended effluent limitations,

NON-WATER QUALITY ENVIRONMENTAL IMPACT

The primary non-water quality environmental impact of the proposed EAT
effluent limitations is the potential concentration of toxic  metallic
pollutants removed from wastewater.

No  increase  in  air  pollution should result from the EAT technology
since metals removal is accomplished  in  the  aqueous  phase  and  no
release   of   hydrocarbons  or  metals  to  the  air  should  result.
Consumptive water loss by entrainirent cf water in the hydroxide  floes
should  be minor.  Small increases in energy requirements are expected
for operation of pumps and other ancillary equipment.
                                  148

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TABLE X-1
BAT EFFLUENT LIMITATIONS
SUECATEGORY F—ROSIN-BASED DERIVATIVESS
Pollutant or
Pollutant Property
                                  EAT Effluent Limitations
          Maximum for
          Any One Day
            Average of Daily Values
            for 30 Consecutive Days
 Zinc*

* At the source
                 milligrams per liter  (mg/1)

             4.2                        1.8
SUECATEGORY G—SULFATE TURPENTINE
Pollutant or
Pollutant Property
                   EAT Effluent Limitations
          Maximum for        Average of Daily Values
          Any One Day        for 30 Consecutive Days
 Ccpper*
 Nickel*

* At the source
             U,5
             4,1
milligrams per liter (mg/1)

                       1.8
                       1.8
                                 149

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                              SECTION XI

                EFFLUENT REDUCTION ATTAINABLE EY EEST
              CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY

The 1977 amendments to the Act added section 301 (b) (4) (E)  establishing
"best conventional pollutant control technology" (ECT)  for  discharges
of  conventional  pollutants  from  existing industrial point sources.
Conventional pollutants are those defined in  section  304 (b) (4)—BCD,
TSS,  fecal coliform, and pH—and any additional pollutants defined by
the Administrator as "conventional."  On July 29,  1979, EFA added  oil
and grease to the conventional pollutant list (44  Fed.  Reg*  44501).

ECT  is not an additional limitation, tut replaces BAT for the control
of  conventional  pollutants.   ECT  requires  that  limitations   for
conventional   pollutants  be  assessed  in  light  of  a  new  "cost-
reasonableness" test, which compare the cost and level of reduction of
conventional pollutants from the discharge of publicly-owned treatment
works to the cost and level of reduction of  such   pollutants  from  a
class or category of industrial sources.  As part  of its review of EAT
for  certain  "secondary"  industries, the Agency  proposed methodology
for this cost test.  See 44 Fed. Reg^ 50732 (August 26, 1979).

The Agency conducted a search to upgrade the existing  BPT  tschnolcgy
for evaluation as BCT.  Various oxidation techniques have been studied
but none of them is in current use in the industry.  Therefore, EPA is
proposing  BCT  effluent limitations at the same level as EPT effluent
limitations.
                                 151

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TABLE XI-1-    BCT EFFLUENT LIMITATIONS

Subcategory C—Wood Rosin, Turpentine, and Pine Oil Subcategory


Pollutant or             Maximum for        Average of Daily Values
Pollutant Property       Any One Cay        for 30 Consecutive Days


                         Jcg/kkg  (or lb/1,000 Ib) cf product

 ECD5                       2.08                       1.10
 TSS                        1.38                       0.475
 PH                      Within the range of 6.0 to 9.0 at all times
Subcategory D—Tall oil Rosin, Pitch, and Fatty Acids Subcategory
Pollutant or             Maximum fcr        Average of Daily Values
Pollutant Property       Any One Eay        for 30 Consecutive Days
                         kg/kJcg (or li)/1,000 lb> cf product

 BCD5                       0.995                      0.529
 TSS                        0.705                      0.243
 pH                      Within the range of 6.0 to 9.0 at all times
                                 152

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Subcategory F—Rosin-Based Derivatives
Pollutant or
Pollutant Property
Maximum fcr
Any One Day
average of Daily Values
fcr 30 Consecutive Days
 BCD5
 TSS
 pH
kg/kkg  (or lb/1,000 Ib) cf product

   1.41                       0.748
   0.045                      0.015
Within the range of 6.0 to 9.0 at all times
Subcategory G—Sulfate Turpentine
Pollutant or
Pollutant Property
 BCD5
 TSS
 pH
Maximum for
Any One Day
Average of Daily Values
for 30 Consecutive Days
kg/kkg  (or lb/1,000 Ib) cf product

   5.504                      2.924
   0.686                      0.236
Within the range of 6.0 to 9.0 at all times
                                 153

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                             SECTION XII

                   NEW SOURCE PERFORMAKCE STANDARDS


The basis for new source performance standards  (NSPS)   under  section
306  of  the Act is the best available demonstrated technology (BADT).
New plants have the opportunity tc design the best and mcst  efficient
Guir   and   Wood   Chemicals   processes   and   wastewater  treatment
technologies, and Congress therefore directed EPA to consider the best
demonstrated  process  changes,  in-plant  controls,  and  end-of-pipe
treatment  technologies  which  reduce polluticn tc the maximum extent
feasible.  A major difference between NSPS and BAT  is  that  the  Act
does not require evaluation of NSPS in light of the BCT cost test.

EPA  has  selected  EPT plus metals removal for the sulfate turpentine
and rosin-based derivatives subcategory.  Metals removal need  not  be
required  if  a  plant  can  show  that  the  metals  are  not used as
catalysts,  active  ingredients,  or  by-products.   The  new   source
requirements  for  the wood rosin and the tall oil subcategory are the
EPT requirements currently in effect.

The biological treatment required by EPT has shown adequate removal of
the  toxic  organic  compounds.   EPA  believes  that  GAC    (granular
activated  carbon)  columns  would be too expensive for the removal of
toxic chemicals,

Since the control and treatment techixilcgy basis for NSPS is the  same
as  for BPT, the methodology used to develop the effluent limitations,
the engineering aspects of this technology, and the numerical effluent
limitations are also the same.
                                 155

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TAELE XII-1.   NSPS EFFLUENT LIMITATIONS

Subcategory C—Wood Rosin, Turpentine, and Pine Oil Subcategory
Pollutant or
Pollutant Property
 BCD5
 TSS
 pH
Maximum  for
Any One  Eay
Average of Daily Values
for 30 Consecutive Days
kg/kkg  (or lb/1,000 Ib)  cf product

   2.08                       1.10
   1.38                       0.475
Within the range of 6.0  to 9.0 at all times
Subcategory D—Tall Oil Rosin, Pitch, and Fatty Acids Subcategory
Pollutant or
Pollutant Property
Maximum for
Any One Day
Average of Daily Values
for 30 Consecutive Days
 BCD5
 TSS
 pH
kg/kkg  (or lb/1,000 Ib) cf product

   0,995                      0.529
   0.705                      0.243
Within the range of 6.0 to 9.0 at all times
                                 156

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Subcategory F-~Rosin-Based Derivatives
Pollutant or
Pollutant Property
 BCD5
 TSS
Zinc*

 pH

*At-the-source
Maximum for
Any One Day
Average of Daily Values
for 30 Consecutive Days
                         kg/kkg (or lb/1,000 Ib)  cf product
   1.41
   0.045
           0.748
           0.015
milligrams/liter  (mg/1)

   4.2                        1.8

Within the range of 6.0 to 9.0 at all times
Sufccategory G—Sulfate Turpentine
 BCD5
 TSS
Zinc*
Nickel*

 pH

*At-the-source
                         Maximum fcr
                         Any One Day
                   Average of Daily Values
                   for 30 Consecutive Days
kg/kkg  (cr lb/1,000 Ib) cf product,

   5.504                      2.924
   0.686                      0.236

milligrams per liter  (mg/1)

   4.2                        1.8
   4.1                        1.8

Within the range of 6.0 to 9.0 at all times
                                 157

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                             SECTION XIII
                        PRETREATMENT STANDARDS
INTRODUCTION
The effluent limitations that must be achieved  by  new  and  existing
sources  in  the  Gum  and  Wood Chemicals Industry discharging into a
publicly-owned  treatment  works   (PCTW)   are   termed   pretreatment
standards.   Section  307 (b)  of  the  Act  requires EPA to promulgate
pretreatment standards for existing  sources   (PSES)  to  prevent  the
discharge  of  pollutants  which  pass through, interfere with, or are
otherwise incompatible with the operation cf PCTWs.  The  Clean  Hater
Act  of  1977  adds  a  new  dimension  by  requiring pretreatment for
pollutants, such as heavy metals, that limit  FOTVi  sludge  management
alternatives,  including the beneficial use of sludges on agricultural
lands.  The  legislative  history  of  the  1977  Act  indicates  that
pretreatment  standards  are  to be technology-based, analagous to the
best available  technology  for  removal  of  toxic  pollutants.   The
general  pretreatment regulations  (40 CFR Part 403) can be found in 43
fe^. Reg^ 27736-27773 (June 26, 1978).

In establishing a pretreatment standard, the  Agency  also  considered
the following:

1.  The total cost of applying technology in relation to the
    effluent reduction benefits achieved from such
    application;
2.  The size and age of equipment and facilities involved;
3,  The processes employed;
4.  The engineering aspects of applying pretreatment
    technology and its relationship to POTH;
5.  Process changes; and
6.  Nonwater quality environment iir.pact (including energy
    requirements) .

Pretreatment  standards  must reflect effluent reduction achievable by
the application of the best available pretreatment  technology.   This
iray  include  preliminary treatment technology as used in the industry
and in-plant controls considered tc be normal industry practice.

A final consideration is the determination of economic and engineering
reliability in the application of the pretreatment  technology.   This
is  developed through demonstration projects, pilct plant experiments,
and,  most preferably, general use within the industry.
                                 159

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PRETREATMENT STANDARDS FOR EXISTING SOURCES

Eretreatment Technology

Candidate control technologies for pretreatment include the  same  in-
plant  control  and  pretreatment technologies considered as candidate
EAT technologies for direct dischargers.

These technologies include:

       Water conservation and reuse for reduced flow
       Stream segregation for separate pretreatment
       Metals removal by pH adjustment and filtration or

RATIONALE FCR THE PRETREATMENT STANDARD

The rationale for the pretreatment standard  rests  primarily  on  the
concept  of  interference with or pass-through POTW as used in section
30 7(b)  of  the  Act  and  delineated  in  the  recently   pr onrnlgated
pretreatment  regulations  (40  CFR Part 403, 43 Fed. Reg.. 27773, June
26, 1978).  Among the pollutants in the raw waste from  Gum  and  Wood
Chemicals  plants,  copper,  nickel,  and  zinc  appear  in sufficient
concentrations to present potential problems of pcllutant pass-through
or sludge disposal for POTW,

Within this technology-based analysis, EPA has assumed the following:

* Any joint municipal-industrial PCTW  which  receives  Gum  and  Wood
Chemicals  wastewater  includes  primary  sedimentation  and secondary
biological treatment with final clarification and  sludge  management.
These facilities are properly designed and diligently operated.

*  Analysis of pass-through and upset cf FOTW has been determined front
the point of wastewater release frcm the Gum and wood Chemicals plant;
therefore, specific collection system circumstances must be considered
at the local level.

* Locally specific water quality constraints and unique operational or
sludge disposal problems, beyond the requirement fcr  compliance  with
section 405 (d) of the Clean Water Act, have not been considered within
this technology-based analysis.

*  Strict adherence to and local enforcement of the general prohibited
discharge provisions  of  the  pretreatment  regulation,  and  sircilar
provisions in local ordinances, are essential to enstre that potential
problems of upset and/or pass-through noted below are not permitted to
cccur.
                                  160

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Wastewaters from sulfate turpentine and rosin-based derivatives plants
potentially  can  create or contribute to the following problems for a
POTW:

* A potential future problem with disposal of sludges.

* Potential sludge digestion problems.

These problems can be eliminated largely through strict  adherence  to
prohibited  discharge  provisions of local ordinances and the national
pretreatment regulation.

The data and information gathered during this study indicate that  the
EOE5  and TSS found in Gum and Wood Chemicals wastewaters respond well
to properly designed and operated secondary biological treatment.

Siirilarly, oil and grease found  in  Gum  and  Wood  Chemicals  plants
decreased  to low levels through a ccmbination of cil/water separation
and biochemical oxidation in biological treatment  systems.   Properly
designed  and  operated  oil/water  separators prior to discharge to a
FOTW should result in treatable levels cf oil and grease.  This  fact,
and the nature of the oil and grease being discharged  (i.e., primarily
animal   and/or   vegetable   origin)  make  pretreatment  limitations
unnecessary.

The same data indicate that, in general, copper, nickel, and zinc  are
removed  from wastewater.  Since these elements are not biodegradable,
the Agency suspects that they form hydroxide floes at the elevated  pH
necessary  for  biological treatment  (i.e., pH 7) or that they complex
with other components of the waste stream.  In either case, the metals
probably occur in the sludges formed by biological treatment.  Studies
conducted at the Robert A. Taft Sanitary Engineering  Center  indicate
that copper, zinc, and nickel may interfere with biological treatment.
In  addition,  copper  and  zinc  may  interfere with the digestion of
sludge in the activated sludge process.

Effluent data from Gum  and  Wood  Chemicals  plants  with  biological
treatment  indicate  that  organic  toxic pollutants of concern  (i.e.,
phenol,  toluene,  benzene,  and  ethylbenzene)  are   discharged   at
concentrations  less  than  or equal to 0.2 mg/1.  In consideration of
this performance and the  enhanced  treatment  provided  fcy  activated
sludge treatment systems, pretreatment limitations are unnecessary for
the toxic organic pollutants.

REGULATED POLLUTANTS

1)    Conventional  Pollutants  -  As  noted  above,  the  conventional
pollutants from Gum and Wood Chemicals plants respond well to properly
                                 161

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designed  and  operated secondary biological treatment,  therefore, no
limitations are proposed for the conventional pollutants.

2)    Non-toxic, non-conventional pollutants - there are no  non-toxic,
non-conventional pollutants limited by these proposed regulations.

3)    Toxic pollutants - The toxic pollutants expressly controlled  for
direct  dischargers in two subcategories are copper, nickel, and zinc,
which are subject to numerical limitations expressed in milligrams per
liter of pollutant.

SIZE, AGE, PROCESSES EMPLOYED, LOCATION OF FACILITIES

The size and age of Gum and Wood Cheirical plants  do  not  affect  the
proposed  pretreatment control technology.  Neither is the location of
the facilities a factor.  The processes  employed  were  a  factor  in
prescribing  pretreatment.   Subcategories  C  and D use no metals and
those present are probably the result of corrosion or other  forms  of
non-process  related  contamination.  For Subcategories F and G, which
use metals in the chemical modification of rosins  and  turpenes,  at-
the-source   effluent   treatment  is  proposed  as  the  pretreatment
standard.

TOTAL COST CF APPLICATION

At this time eight plants in  the  Gum  and  Wood  Chemicals  Industry
discharge  to POTWs and are thus subject to pretreatment standards for
existing sources.  The estimated  costs  are  based  on  a  survey  of
sulfate  turpentine and rosin-based derivatives plants indicating that
metals removal units will be required at four plants (this  technology
is  in-place  at  one  of the four plants).  Total investment costs to
ireet proposed PSES will be  approximately  $259  thousand  with  total
annual operating costs of about $470 thousand.

Achievement   of  PSES  regulations  by  metals  removal  control  and
treatment technology is expected to remove approximately 13 pounds per
day of copper and nickel and 119 pcunds per day of zinc.

ENGINEERING ASPECTS OF PRETREATMENT  TECHNOLOGY  AND  RELATIONSHIP  TO
PUELICLY-OWNED TREATMENT WORKS

As noted earlier in this section, each of the problems associated with
Guir  and Wood Chemicals wastewater can be controlled largely by strict
adherence to general prohibited discharge  regulations  and  tc  these
pretreatment  standards  which  liirit  copper,  nickel, and zinc.  The
metals are being regulated directly  as  the  most  significant  toxic
pollutants  because of their pass-through of PCTWs and their potential
to reduce biodegradation at the  POTW  and  affect  sludge  digestion.
Careful  design  and  diligent  operation of a PCTW are also extremely
                                 162

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important for  progress  toward  achievement  of  secondary  treatment
standards by POTWs.

IN-PLANT CHANGES

While  metals precipitation at-the-source is considered an end-of-pipe
treatment technology, the  technology  needs  to  be  located  near  a
process   unit  dedicated  to  chemical  mcdificaticn  of  rosins  and
turpenes.  Since these units are generally abovegrour.d, a repiping  of
the  wastewater  piping  and dedication of certain plant areas will be
required.  These costs plus the cost of the  unit  will  be  generally
smaller  than installation cf metals rerroval technology applied to the
total  waste  stream  from  a  sulfate   turpentine   or   rosin-based
derivatives plants.
                                  163

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Table XIII-1 Subcateqory F—Rosin-Based Derivatives	

                                  FSES Effluent Limitations
Pollutant or                 Maximum for     Average of Daily Values
Pollutant Property	Any Cne Day	for 30 Consecutive Days

                           milligrams per liter (mg/1)

Zinc*                           4.2               1.8

*At-the-Source
Subcategory G—Sulfate Turpentine
                                  PSES Effluent Limitations
Pollutant or                 Maximum for     Average of Daily Values
Pollutant Property	 Any Cne Day	for 30 Consecutive Days

Copper*                         4.5               1.8
Nickel*                         4.1               1.8

*At-the-Source
                                 164

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FRETREATMENT STANDARDS FOR NEW SOURCES

Section  307(c)  of  the  Act  requires EPA to promulgate pretreatment
standards for new sources  (PSNS) at the same time that it  promulgates
NSPS,  New indirect dischargers, like new direct dischargers, have the
opportunity   to   incorporate   the   best   available   demonstrated
technologies including process changes, in-plant controls, and end-of-
pipe treatment technologies, and to use plant site selection to ensure
adequate treatment system installation.

Candidate  control  technologies  fcr  pretreatment  for  new  sources
include  the  same  in-plant  control  and  pretreatment  technologies
considered as candidate pretreatment technologies discussed previously
for existing sources.

RATIONALE FCR THE PRETREATMENT STANDARD

The rationale for the pretreatment standard  rests  primarily  on  the
concept  of  interference with or pass-through POTW as used in section
307(b)   of  the  Act  and  delineated  in  the  recently   promulgated
pretreatment  regulations   (40  CFR  Part 403, FR27736-27773, June 26,
1978).  Among the pollutants in  the  raw  waste  from  Gum  and  Wood
Chemicals  plants  copper,  nickel,  and  zinc  appear  in  sufficient
concentrations to present potential problems of pollutant pass-through
or sludge disposal for POTW.

As noted in  the  rationale  for  PSES,  metals  removal  pretreatment
technology   should  permit  achievement  by  POTWs  of  EAT  effluent
limitations resulting in levels of toxics less than or equal  to  that
achieved  by  BAT.   While  pass-through  of  toxic pollutants and the
presence of toxic pollutants in sludges will still occur, they  should
be  at  levels  low  enough not tc interfere with biological treatment
and, in the case of organic toxic pollutants,  at  levels  lower  than
achieved  by  BPT.  The Agency has therefore chosen to propose PSNS at
the  same  effluent  quality  required   by   PSES.    The   numerical
concentration  limitations  for  Subcategories  F  and G are listed as
follows:

NOtv-WATER QUALITY ENVIRONMENTAL IMPACT

As with BAT, the Agency expects the primary non-water  quality  impact
to  be  the  concentration  of toxic metal pollutants removed from the
wastewater.  The Agency also expects no increase in air pollution  and
small increases in consumptive water loss and energy requirements.
                                 165

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Table XIII-2 Subcategory F—Rosin-Eased Derivatives	
Pollutant or             Maximum for        Average of Daily Values
Pollutant Property	Any One Day	for_30_C°J}secutive_Days.
 Zinc*

*At-the-Source
   4.2
                                milligrams per liter (mg/1)

                                                       1.8
 SufccategorY G—Sulfate Turpentine
Pollutant or
Pollutant Property
Maximum for
Any One Day
                Average of Daily Values
                for 30 Consecutive Days
                                milligrams per liter  (mg/1)
 Ccpper*
 Nickel*

 *At-the-Source
4.5
4.1
                              1-8
                                  166

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                             SECTION XIV

          PERFORMANCE FACTORS FOR TREATMENT PLANT OPERATIONS

PURPOSE

This  section discusses the causes of variations in the performance of
wastewater treatment facilities and techniques  for  minimizing  these
variations,

FACTORS  WHICH  INFLUENCE  VARIATIONS  IN  PERFORMANCE  OF  HASTEWATER
TREATMENT FACILITIES

The factors influencing the variation  in  performance  of  wastewater
treatment  facilities  are  common  to  all  subcategories.   The most
important factors are summarized in this section.

Temperature

Temperature affects the  rate  of  biological  reaction;  lower  temp-
eratures  decrease  biological  activity and cause higher effluent BCD
levels.   Effluent  solids  levels  also  increase  as  a  result   of
incomplete  bio-oxidation  and  decreased settling rates under reduced
temperatures.  Settling basins and aerated lagoons are susceptible  to
thermal  inversions.  Significant variations in the levels of effluent
solids may result as settled  solids  rise  to  the  surface  and  are
discharged.

Proper  design  and  operation  considerations  can reduce the adverse
effects of temperature on treatment efficiencies.  Such considerations
include the installation of  insulation  and  the  addition  of  heat.
Techniques  for  temperature  control are both well known and commonly
used in the sanitary engineering field.  Cost-effectiveness is usually
the critical criterion for the extent and effectiveness of temperature
control.

Shock Loading

Once a system is acclimated to a given set of steady state conditions,
rapid quantitative or qualitative changes in loading rates can cause a
decrease in treatment efficiencies.  Several days cr weeks  are  often
required  for a system to adjust to a new set of operating conditions.
Systems with short retention times,  such  as  activated  sludge,  are
particularly sensitive to shock leading.

While  it  is  unlikely  that  total and permanent prevention of shock
loadings for a particular system can be achieved,  proper  design  and
operation   can  greatly  reduce  adverse  effects.   Sufficient  flow
equalization prior to biological treatment can mitigate  shock  loads.
                                 167

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Coirplete  mix activated sludge is less likely to upset conditions than
ether activated sludge modifications.

System Stabilization

A new biological system, or  one  that  has  been  out  cf  operation,
requires  a  stabilizing period of up to several weeks before optimum,
consistent efficiency can be expected.  During this  start-up  period,
large  variations  in  pollutant  parameters  can  be  expected in the
discharge,

System Operation

Good  operation  and  maintenance  is  essential  to  the   successful
performance  of  any activated sludge system.  Operators must be well-
trained specialists thoroughly  fairiliar  with  the  system  they  are
operating.

Nutrient Requirements

Adequate  amounts  cf nutrients, particularly nitrogen and phosphorus,
are  necessary  to  maintain  a  viable  microbial  population  in   a
biological  system.   Proper  design  and  operation  of a system will
provide sufficient nutrients for optimum performance.

System Controllability

In addition to the design considerations mentioned above, an activated
sludge system should include appropriate meters and accurate, control-
lable gates, valves, and pumps for cptiirum performance.   A  qualified
instrument technician should be available.

An  adequate  laboratory  should  be  provided,  along with monitoring
facilities.  Essential control tests should be conducted at least once
every 8-hour shift, and more frequently when necessary.
                                 168

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                              SECTION XV

                           ACKNOWLEDGEMENTS

This report was prepared by the Environmental Protection Agency on the
basis of a comprehensive study of this manufacturing segment performed
by Environmental Science and Engineering, Inc. under contracts No. 68-
01-4728 and No. 78-A130.

The study was conducted and prepared for the Environmental  Protection
Agency  under  the direction of Project Director John Crane, P.E., and
Technical Project Manager, Ernest E. Frey.  The  following  individual
members  of  the staff of Environmental Science and Engineering, Inc.,
significantly contributed to the overall effort:   Eevin  A.  Eeaudet,
P.E.,  and Eric G. Hanson, P.E., assisted in writing and reviewing the
document; Dr. John J. Mousa managed analytical work;  Mr.  Russell  V.
Eowen  managed  the  development of the cost analysis; Ms. Patricia L.
McGhee coordinated the editing and production of the document; and Ms.
Kathleen Fariello and  Ms.  Eileen  Smith  typed  the  report  in  its
entirety.
            \
The  initial  phases  of  the  ESE  study  were  conducted  under  the
supervision and guidance of Dr. James Gallup.  The final phases of the
study and the preparation of this document were  conducted  under  the
supervision  and  guidance  of  Mr.  William Thomson II, P.E., Project
Officer.

Overall guidance and excellent assistance  was  provided  the  Project
Officer  by  his  associates  in  the  Effluent  Guidelines  Division,
particularly Messrs. Robert B. Shaffer, Director, and John  E.  Riley,
Branch  Chief,   Special acknowledgement is also made to ethers in the
Effluent Guidelines Division:  Messrs. James Gallup, Richard Williams,
Robert Dellinger, Donald Anderson, Jchn  Cunningham,  Carl  Kassebaum,
and  James  Berlow, for their helpful suggestions and timely comments.
Effluent  Guidelines  Division  project   personnel   also   wish   to
acknowledge  the  assistance  of  the  personnel  at the Environmental
Protection Agency's regional centers for their special assistance.

Appreciation is extended to Ms. Dianne Olsson of  the  EPA  Office  of
General Counsel for her invaluable input.

In  addition.  Effluent  Guidelines  Division would like to extend its
gratitude to the following individuals for the significant input  into
development  of  this  document  while  serving  as members of the EPA
working group which provided detailed review, advice, and assistance:

     R.  Williams, Interim Chairman, Effluent Guidelines Division
     W.  Thomson II, Chairman, Project Officer, Effluent Guidelines
       Division
                                 169

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     D.  Gibbons,  Office of Analysis and Evaluation
     J,  Gallup,  Effluent Guidelines Division
     W.H.  Cloward, Region IV,  EPA
     E.  Notzen,  Monitoring and Data Support Division
     L.  Delpire,  Monitoring and Data Support Division
     J.  Riley,  Effluent Guidelines Division
     D.  Olsson,  Office of General Counsel
     K.  Mackenthun, Criteria and Standards Division
     M.  Halper,  Monitoring and Data Support Division
     J.  Stiebing, Region VI, EPA
     J.  Noroian,  Office of Analysis and Evaluation
     M.  Flaherty, Criteria and Standards Division
     W.  Lee, Region III, EPA
     D.  Bodien,  Region X, EPA
     H.  Holman,  Economic Analysis Division

EGD would  also like to acknowledge the Pulp Chemicals Association  and
the  personnel  of  selected  plants  cf  the  Gum  and Wood Chemicals
manufacturing point source category for their help in  the  collection
of  data  relating  to  process  raw  waste  loads and treatment plant
performance.

The cooperation of the individual Gum and wood Chemicals companies who
offered their facilities for survey and contributed pertinent data  is
gratefully appreciated.  Alphabetically, the companies are:

     1.   Arizona Chemical, Inc.
     2.   Crosby Chemical, Inc.
     3.   Hercules
     4.   Monsanto-Emery
     5.   Reichhold
     6.   SCM Corporation
     7.   Union Camp
     8.   Westvaco

Manufacturing representatives playing a significant part in the success
of this study were:
     H. Arlt (1)
     J. Bowers  (7)
     R. Gressang  (8)
     J. Kruirbein  (5)
W. Lakusta (1)
J. Ralston (7)
D. Tippey (4)
                                  170

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                             SECTION XVI

                             BIBLIOGRAPHY

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Gulp, R.L. , Wesner, G.M.  and Gulp, G.C., Handbook of Advanced Wastewater
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Fleischer, M., et al., "Environmental Impact of Cadmium:  A Review by
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Ford, D.L., et al., "Temperature Predictions in Activated Sludge Easins
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Gardner, Frank H., Jr. and Williamson, A.R., Naval Stores Wastewater
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Goldsmith, R.L. et a!P, "Soluble Oil Waste Treatment Using
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Hager, D.G., "Industrial Wastewater Treatment by Granular Activated
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Hammer, J.J., Water and Waste Water Technology, John Wiley 6 Sons, Inc.,
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Harlowe, H.W., et al., "A Petro-Chemical Waste Treatment System," Proc.,
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                                 173

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Hauser, E.A., Colloidal Phenomena, 1st Edition, McGraw-Hill Book
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Henshaw, T.E., "Adsorption/Filtration Plant Cuts Phenols from Effluent,"
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Hill, W.B., et al., "Argyria Investigation—Toxicological Properties of
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Hsu, C.P., et al.,  "Phenolic Industrial Wastes Treatment by a Trickling
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Irukayama, F., et al., "Studies on the Origin of the Causative Agent of
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                                  175

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McKee, J.E. and Wolf, H.W. , Water Quality Criteria, State Water Quality
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Parker, C.L., Estimating the Cost of Wastewater Treatment Ponds,
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                                 177

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                                  178

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                                 179

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     U.S.  EPA Technology Transfer, EPA, Washington, D.C., August 1973.

U.S. Environmental Protection Agency, "National Conference on
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U.S. Environmental Protection Agency, Process Design Manual for
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U.S. Environmental Protection Agency, Process Design Manual for Carbon
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U.S. Environmental Protection Agency, Quality Criteria for Water, U.S.
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U.S. Environmental Protection Agency, "Survey of Two Municipal Waste-
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     Metals," (NSF/RANN Grand 61-31605), Progress Report, May 1-
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     Urbana-Champaign  (1972).

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     Health, 16:147  (1957).

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     Van Norstrand Reinhold Co., 1977,

Wang, Lawrence K., Environmental Engineering Glossary  (Draft), Calspan
     Corporation, Environmental Systems Division, Buffalo, New York,
1974.

Weast, R,,  (ed.), CRC Handbook of Chemistry and Physics, 54th Edition,
     CRC Press, Cleveland,  Ohio, 1973-1974.

Weber, C,I., (ed.) , "Biological Field and Laboratory Methods for
     Measuring the Quality  of Surface Waters and Effluents,"
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                                 180

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     Ohio, July 1973.

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     Professional Paper #713, USGPO  (1970).

Kilson, T.E., "Beneficial Use of Industrial Wastes in Municipal
     Wastewater Treatment Plants," Proc. 32nd Purdue Ind. Waste Conf.,
     1977, pp. 594-598.

Kynn, C.S., et al. , Pilot Plant for Tertiary Treatment of Wasteviater
     with Ozone, EPA Rept. R2/73/146 (1973).

Quality  Criteria  for  Water,  U.S.  Environmental Protection Agency,
Report No. 440/9-76-023, Washington, D.C., July 1976.

Proposed Water Quality Criteria, U.S. Environmental Protection Agency,
44 FR 15926, March 15, 1979.

Benzene.   Draft  Criteria  Document,  U.S.  Environmental  Protection
Agency.  PB 292421, Natl. Tech. Inf. Serv., Springfield, VA.

Proposea Water Quality Criteria, U.S. Environmental Protection Agency,
44 FR 43660, July 15, 1979.

Tetrachloroethylene.   Draft  Criteria  Document,  U.S.  Environmental
Protection Agency.  PB 292424, Natl. Tech.  Inf.  Serv.,  Springfield,
VA.

Toluene.   Draft  Criteria  Document,  U.S.  Environmental  Protection
Agency.  PB 296805, Natl. Tech. Inf. Serv., Springfield, Va.

Trichloroethylene.   Draft  Criteria  Document,   U.S.   Environmental
Protection  Agency.   PB  292445, Natl. Tech. Inf. Serv., Springfield,
VA.

Chloroform,  Draft Criteria Document,  U.S.  Environmental  Protection
Agency,  PB 292427, Natl. Tech. Inf. Serv., Springfield, VA.

Bichlorobenzenes.     Draft   Criteria   Document,  U.S.  Environmental
Protection Agency.  PB 292429, Natl. Tech.  Inf.  Serv.,  Springfield,
VA.

Nitrosamines.   Draft Criteria Document, U.S. Environmental Protection
Agency,  PB 292438, Natl. Tech. Inf. Serv., Springfield, VA.

1,2-Diphenylhydrazine.  Draft Criteria  Document,  U.S.  Environmental
Protection Agency, PB 296795, Natl. Tech. Inf. Serv,, Springfield, VA.
                                 181

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Eenzidine.   Draft  Criteria  Document,  U.S. Environmental Protection
Agency.  PB 297918, Natl. Tech.  Inf. Serv., Springfield, VA.

3,3'-Dichlorobenzidine.  Draft Criteria Document, U.S.   Environmental
Protection  Agency.   PB 296793, Natl. Tech.  Inf. Serv., Springfield,
VA.

Iscphorone.  Draft Criteria Document,  U.S.  Environmental  Protection
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Naphthalene.   Draft  Criteria Document, U.S. Environmental Protection
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Polynuclear Aromatic  Hydrocarbons.   Draft  Criteria  Document,  U.S.
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Phenol.    Draft  Criteria  Document,  U.S.  Environmental  Protection
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VA.

Chlorinated Phenols
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VA.

2,4-Dimethylphenol.
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VA.
Draft  Criteria  Document,  U.S.   Environmental
PB  292431, Natl. Tech. Inf. Serv., Springfield,
 Draft  Criteria  Document,  U.S.  Environmental
PB 296790, Natl. Tech. Info. Serv., Springfield,
Draft  Criteria  Document,  U.S.   Environmental
PB  292432, Natl, Tech. Inf. Serv., Springfield,
Pentachlorophenol.   Draft  Criteria  Document,  O.S.    Environmental
Protection  Agency.   PB 292439, Natl. Tech.  Inf. Serv,, Springfield,
VA.

Chromium.  Draft  Criteria  Document,  U.S.  Environmental  Protection
Agency.  PB 297922, Natl. Tech. Info. Serv., Springfield, VA.

Copper.    Draft  Criteria  Document,  U.S.  Environmental  Protection
Agency.  PB 296791, Natl. Tech. Info. Serv., Springfield, VA.

Nickel.   Draft  Criteria  Document,  U.S.  Environmental   Protection
Agency.  PB 296800, Natl. Tech. Info. Serv., Springfield, VA.
                                 182

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                              SECTION  XVII

                  GLOSSARY  OF  TERMS  AND  ABBREVIATIONS

 Absorption—A   process  in which  one  material  (the  absorbent)  takes up
 and   retains   another   (the   absorbate)  with   the  formation    of    a
 homogeneous  mixture  having  the  attributes  of  a  solution.   Chemical
 reaction  may accompany or  follow  absorption.

 Act—The  Federal  Water  Pollution  Ccntrol  Act  Amendments  of   1972,
 Public Law 92-500.

 Activated  Carbon—Carbon  which is  treated  by  high-temperature heating
 with  steam or  carbon dioxide  producing  an  internal  porous   particle
 structure.

 Activated Sludge—Sludge floe produced  in raw  or  settled wastewater by
 the growth of  zoogleal bacteria and other organisms in the presence of
 dissolved  oxygen and  accumulated  in sufficient  concentration  by
 returning floe  previously  formed,.

 Activated Sludge  Process—A biological  wastewater treatment process in
 which a mixture of wastewater and activated  sludge  is  agitated  and
 aerated.   The  activated  sludge  is  subsequently separated  from the
 treated wastewater  (mixed  liquor)  by  sedimentation  and  wasted  or
 returned to the process as needed.

 Adsorption—An  advanced method of  treating wastes in which a  material
 removes organic matter not necessarily  responsive to clarification  or
 biological treatment by adherence en  the surface  cf solid bodies.

 Aerated  Lagoon—A  natural or artificial wastewater treatment pond in
 which mechanical or diffused-air  aeration is used  to  supplement  the
 oxygen supply.

 Aqueous Solution—One containing water  or watery  in nature.

 Azeotrope—A  liquid  mixture  that   is  characterized  by  a  constant
 minimum or maximum boiling point which  is lower or higher than that of
 any of the components and that distills without change in composition.

 EAT (BATEA)  Effluent Limitations—Limitations for point sources,  other
 than  publicly-owned  treatment  works,  which  are   based   on   the
 application  of the Best Available Technology Economically Achievable.
These limitations must be achieved by July 1,  1981.
                                 183

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Eiological Wastewater  Treatment—Forms  of  wastewater  treatment  in
which  bacterial  or  biochemical  action is intensified to stabilize,
oxidize,  and   nitrify   the   unstable   organic   matter   present.
Intermittent  sand  filters,  contact  beds,  trickling  filters,  and
activated sludge processes are examples.

Blank—deionized water  used  to  rinse  automatic  sampler  prior  to
collection of sample.

Slowdown—The removal of a portion of any process flow to maintain the
constituents of the flow at desired levels.

EOD—Biochemical   Oxygen   Demand   is   a   measure   of  biological
decomposition of organic matter in a water sample.  It  is  determined
by  measuring  the  oxygen  required  by microorganisms to oxidize the
organic contaminants of  a  water  sample  under  standard  laboratory
conditions.   The standard conditions include incubation for five days
at 20 C.

EOD7—A modification of the BOD test in which incubation is maintained
for seven days.  The standard test in Sweden.

EPT(BPCTCA) Effluent Limitations—Limitations for point sources, other
than  publicly-owned  treatment  works,  which  are   based   on   the
application  of  the  Best  Practicable  Control  Technology Currently
Available.  These limitations must be achieved by July 1,  1977.

Carbonization—A process whereby a carbon residue is produced via  the
destructive distillation of wood.

Chipper—A machine which reduces logs or wood scraps to chips.

Chlorination—The   application   cf  chlorine  tc  water,  sewage  or
industrial wastes, generally  for  the  purpose   cf  disinfection  but
frequently for accomplishing other biological or  chemical  results.

Clarification—Process  of  removing turbidity and suspended solids by
settling.  Chemicals can be added to improve and  speed up  the settling
process through coagulation.

Clarifier—A unit of which the  primary  purpose is to reduce the  amount
of suspended matter in a liquid.

cm—Centimeters.

COE—chemical Oxygen Demand.  Its determination provides  a measure  of
the  oxygen  demand  equivalent tc that portion  cf matter in a  sample
which  is  susceptible to oxidation by a  strong chemical oxidant.
                                  184

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 Composite  Sample—A  combination  of  individual  samples of wastes   taken
 at   selected intervals,  generally hourly  fcr 24  hours, to minimize  the
 effect  of  the variations in  individual  samples.    Individual  samples
 making   up  the  composite   may  be of   equal  volume  or  be roughly
 apportioned  to the volume of flow cf liquid at the  time cf  sampling.

 cu m—Cubic  meters.

 cu ft—Cubic feet.

 Cyclone—A  conical-shaped   vessel  for   separating either entrained
 solids  or  liquid materials from  the carrying air or vapor.  The vessel
 has  a tangential entry nozzle at or near  the largest diameter, with an
 overhead  exit for   air or vapor  and a  lower exit for the more  dense
 materials.
 Data Collection Portfolio—Information  solicited  from
 Section 308 of the Act.
industry  under
 Derivative—A substance extracted  from  another body or substance.

 Destructive  Distillation—Decomposition  cf wood  (cr a hydrocarbon)  by
 heat in  a  closed  container  and the   collection  of  the  volatile
 substances produced.

 Digester—(1) Device for conditioning chips using  high pressure steam,
 <2)  A  tank  in  which  biological  decomposition (digestion) of the
 organic matter in sludge takes place.

 Distillation—The separation, by vaporization, of  a liquid mixture   of
 miscible  and  volatile  substance into  individual components, or,  in
 some cases, into a group of components.   The process  of  raising  the
 temperature  of  a  liquid  to  the  boiling  point and condensing the
 resultant vapor to liquid form by  cooling.   It   is  used  to  remove
 substances  from  a  liquid  or to obtain a pure liquid from one which
 contains impurities or which is a  mixture of  several  liquids  having
 different boiling temperatures.  Used in  the treatment of fermentation
 products,   yeast,  etc.,  and  ether  wastes  to  remove  recoverable
 products.

 DO—Dissolved Oxygen is a measure  of the  amount of free  cxygen  in  a
water  sample.   It  is  dependent  on  the  physical,  chemical,  and
 biochemical activities of the water sample.

Effluent—A liquid which leaves a  unit operation cr process.   Sewage,
water  or  other  liquids, partially or completely treated cr in their
natural states,  flowing out of a reservoir basin, treatment  plant  or
any other unit operation.  An influent is the incoming stream.
                                 185

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Entrainment  separator—A device tc remove liquid and/or solids from a
gas stream.  Energy source is usually derived froir  pressure  drop  to
create centrifugal force.

Equalization  Basin—A  holding  basin in which variations in flow and
composition of a liquid are averaged.  Such basins are used to provide
a flow of reasonably uniform volume and  composition  to  a  treatment
unit.

Essential   Oils—Oils   composed   mainly   of  terpene  hydrocarbons
(turpentine), which are obtained by steam distillation of wood  chips,
bark, or leaves of select trees.

Ester  Gum—A  resin  made  from resin or rosin acids and a polyhydric
alcohol, such as glycerin or pentaerythritol.

Esterification—This generally involves the combination of an  alcohol
and  an  organic  acid to produce an ester and water.  The reaction is
carried out in the liquid phase, with aqueous  sulfuric  acid  as  the
catalyst.   The  use of sulfuric acid has in the past caused this type
of reaction to be called sulfation.
Exudate—Exuded matter.
                                                                    or
Exude—To ooze or trickle forth through pores or gushes, as  sweat
gum, etc.

Fatty    Acids—An   organic   acid   obtained   by   the   hydrolysis
(saponification) of natural fats and oils, e.g., stearic and  palmitic
acids.    These  acids  are  monobasic  and may or way not contain some
double bonds.  They usually contain sixteen or more carbon atoms.

Fines—Crushed solids sufficiently fine tc pass through a screen, etc.

Flccculation—The  agglomeration  cf  colloidal  and  finely   divided
suspended matter.

Flotation—The  raising  of  suspended  matter  to  the surface of the
liquid  in  a  tank  as  scum—by  aeration,  the  evolution  of  gas,
chemicals,  electrolysis,  heat,  or  bacterial decomposition—and the
subsequent removal of the scum by skimming.

F:M Ratio—The ratio  of  organic  material   (food)  to  mixed  liquor
(microorganisms) in an aerated sludge aeration basin,

Fractionation    (or   Fractional   Distillation) —The   separation  of
constituents, or  group  of  constituents,  of  a  liquid  mixture  of
miscible  and  volatile substances by vaporization and  recondensing at
specific boiling point ranges.
                                  186

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Gal—Gallons.

Gland Water—Water  used  to  lubricate  a  gland.
"packing water."

GPE—Gallons per day.
        Sometimes   called
GPM—Gallons per minute.

Grab  Sample—(1)  Instantaneous  sampling;
random place in space and time.
(2)   A   sample taken  at  a
Gum—The  crystallized  pine  oleoresin  or  "scrape"  collected  from
scarified   "faces" of trees being worked for turpentine, exudates from
living long leaf and slash pine trees.

Hardwood  (or Deciduous Woods)—Trees that lose their leaves  annually.
Morphologically and chemically distinct from the conifers and commonly
referred  to  as hardwoods, despite the fact that certain species such
as basswood and poplar have woods that are  relatively  soft.   Fibers
are  substantially  shorter  than those of coniferous wood.  Normally,
deciduous woods are not a source of turpentine.

Holding Ponds—See Impoundment.

Impoundment—A pond, lake, tank, basin, or other space, either natural
cr created in  whole  or  in  part  by  the  building  of  engineering
structures,  which  is  used  for  storage, regulation, and control of
water, including wastewater.

Influent—Any sewage, water, or other liquid,  either  raw  or  partly
treated, flowing into a reservoir, basin, treatment plant, or any part
thereof.   The  influent  is the stream entering a unit operation; the
effluent is the stream leaving it.

Kl/day—Thousands of liters per day,

Kraft (or  Sulfate)   Process—The  digestion  of  wood  chips  with  a
solution  of sodium hydroxide, sodium sulfide, and scdium carbonate to
produce paper pulp.   This process delignifies the wood chip and allows
separation cf the cellulose fibers from a caustic solution  of  lignin
degradation  products  (sugars, hemicellulose, resin, and fatty acids)
and unsaponifiables.

Lagoon—A pond containing raw or partially treated wastewater in which
aerobic or anaerobic stabilization occurs.
Leaching—Mass transfer of chemicals to water from wood
contact with it.
           which  is  in
                                 187

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I/day—Liters per day.

Metxic ton—One thousand kilograms.

MGD—Million gallons per day,

mg/1—Milligrams  per  liter  (equal  parts per million, ppm, when the
specific gravity is one).

Mixed Liquor—A mixture of activated sludge and organic matter  under-
going activated sludge treatment in an aeration tank,

ml/1—Milliliters per liter.

mm—Millimeters.

Naval  Stores—Chemically  reactive  oils,  resins,  tars, and pitches
derived fronr the oleoresin contained in, exuded by, or extracted  from
trees  chiefly  of the pine species (Genus Pinus), or from the wood of
such trees,

Neutralization—The  restoration  of  the  hydrogen  or  hydroxyl  ion
balance  in  a  solution  so that the icnic ccncentrations of each are
equal.  Conventionally, the notation "pH"   (puissance  d1hydrogen)  is
used to describe the hydrogen ion concentration or activity present in
a  given  solution.  For dilute solutions of strong acids, i.e., acids
which  are  considered  to  be  completely  dissociate    (ionized   in
solution), activity equals concentration,

Non-Condensables—Vapors  or gases that remain in the gaseous state at
the temperature and  pressure  specified.   These  normally  would  be
considered the final vented gases under operating conditions.

No  Discharge—The  complete prevention of polluted process wastewater
from entering navigable waters,

NPDES—National Pollutant Discharge Elimination System.

NSFS—New Source Performance Standards.

Nutrients—The nutrients in contaminated water are routinely  analyzed
to  characterize  the  food  available  for  microorganisms to promote
organic decomposition.  They are:

          Ammonia Nitrogen  (NH3), mg/1 as N
          Kjeldahl Nitrogen (ON), mg/1 as N
          Nitrate Nitrogen  (NO3), mg/1 as N
          Total Phosphate  (TP), mg/1 as P
          Ortho Phosphate  (OP), mg/1 as P
                                  188

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Oil-Recovery System—Equipment used to reclaim oil from wastewater.

01eoresin--Pine  gum,  the  non-aqueous  secretion  of   rosin   acids
dissolved  in  a  terpene  hydrocarbon oil which is produced or exuded
from the intercellular resin ducts of a living  tree  or  accumulated,
together  with oxidation products, in the dead wood of weathered limbs
and stumps.

PCE—Polychlorinated Biphenyls.

PCP—Pentachlorophenol.

Pentachlorophenol—A chlorinated phenol with the formula  C15C60H  and
formula  weight  of  266.35  that  is  used  as  a  wocd preservative.
Commercial grades  of  this  chemical  are  usually  adulterated  with
tetrachlorophenol to improve its solubility.

pH—pH  is  a  measure of the acidity or alkalinity of a water sample.
It is equal to the negative log of the hydrogen ion concentration.

Phenol—The simplest aromatic alcohol.

Phenols, Phenolic Compounds—A wide range of  organic  compounds  with
one or more hydroxyl groups attached to the aromatic ring.

Pine  Tar  Oil—The  oil  obtained  by  condensing the vapors from the
retorts  in  which  resinous  pine  wocd  is  destructively  distilled
(carbonized).

Pitch—A   dark   viscous   substance   obtained  as  residue  in  the
distillation of the volatile oils frcm retort pine oil or  crude  tall
oil.

Pitch,  Brewer's—A  term  used  tc  designate a type of pitch made by
blending certain oils, waxes, or other ingredients with rosin for  the
coating of beer barrels.

Point Source—A discrete source of pollution.  Channeled wastewater.

POTW—Publicly-owned treatment works.

Pretreatment—Any  wastewater  treatment  processes  used tc partially
reduce pollution load  before  the  wastewater  is  delivered  into  a
treatment  facility.   Usually consists of removal of coarse solids by
screening or other means.

Primary Treatment—The first major treatment in a wastewater treatment
works.  In the classical sense, it normally consists of clarification.
                                 189

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As used in this document,  it  generally  refers  to  treatment  steps
preceding biological treatment.

Priority  Pollutants—Those  compounds  listed  in  the  1976  Consent
Eecree.

Process Wastewater—Water, which during manufacturing  or  processing,
comes into contact with or results in the production or use of any raw
material, irtermediate product, finished product, by-product, or waste
product.

psi—Pounds per square inch,

Pyroligeneous  Acid—A  product  cf  the  destructive  distillation of
hardwoods composed primarily of acetic acid, crude methanol,  acetone,
tars and oils, and water-.

Resin—A  large  class  of  synthetic  products  that  have properties
similar to natural resin, or rosin, but are chemically different.

Retort—A vessel in which substances are distilled  or  decomposed  by
heat.

Rosin—A  specific kind of natural resin obtained as a nitreous water-
insoluble material from pine oleoresin  by  removal  of  the  volatile
oils,  or  from  tall  oil by the removal of the fatty acid components
thereof.  It consists  primarily  of  tricyclic  monocarboxylic  acids
having the general empirical formula C20 H30 02, with small quantities
of  compounds  saponifiable with bciling alcohclic potassium or sodium
hydroxide, and some unsaponifiable.  The three general classifications
of kinds of rosins in commerce are:   gum  rosin,  obtained  from  the
cleoresin  collected from living trees; wood rosin, from the oleoresin
contained in dead wood, such as stumps and knots; and tall oil  rosin,
from tall oil.

Rosin,  Modified—Rosin  that has been treated with heat or catalysts,
or both; with or without added chemical substances,  so  as  to  cause
substantial   change   in   the  structure  of  the  rosin  acids,  as
isomerization,  hydrogenation,  dehydrogenation,  or   polymerization;
without substantial effect on the carboxyl group.

RWL—Raw Waste Load.  Pollutants contained in untreated wastewater.

Saponification—The reaction in which caustic combines with fat or oil
to produce soap.

Screening—The  removal  of relatively coarse, floating, and suspended
solids by straining through racks cr screens.
                                 190

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Seal  Leg—The  line  through  which  an   underflow   liquid   flows,
constructed to maintain a liquid trap that will net empty upon nominal
pressure changes in the vessel.

Secondary  Treatment—The  second  major  step  in  a  waste treatment
system.  As used in this  document,  the  term  refers  to  biological
treatment.

Sedimentation  Tank—A  basin  or  tank  in  which water or wastewater
containing settleable solids is retained to remove by gravity  a  part
cf the suspended matter.

Separator—The  vessel  connected  tc the vent-relief to separate wood
fines carried over in the vent-relief gases,  and  which  permits  the
steam and turpentine vapors  (including non-condensables)  to proceed in
vapor form to the condenser.

Settling  Ponds—An  impoundment  for  the  settling out cf settleable
solids.

Sludge—The accumulated solids separated from liquids, such  as  water
cr wastewater, during processing.

Softwood—Wood from evergreen or needle-bearing trees.

Soil  Irrigation—A  method  of  land  disposal in which wastewater is
applied to a prepared field.  Alsc referred to as soil percolation.


Solids—Various types of  solids  are  commonly  determined  on  water
sairples.  These types of solids are:

          Total  Solids  (TS)—The material left after evaporation and
          drying a sample at 103 -105 C.

          Suspended Solids  (SS) —The material removed  from  a  sample
          filtered  through a standard glass fiber filter.  Then it is
          dried at 103 -105 C.

          Total Suspended Solids (TSS)—Same as Suspended Solids.

          Dissolved Solids  (DS) —The difference between the total  and
          suspended solids.

          Volatile  Solids  (VS)—The  material which is lost when the
          sample is heated to 550 C.

          Settleable Solids (STS)—The material which  settles  in  an
          Immhoff cone in one hour.
                                 191

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Solvent.  Extraction—A  mixture  of  twc  components  is  treated by a
solvent that preferentially dissolves one or more of the components in
the mixture.  The solvent in the  extract  leaving  the  extractor  is
usually recovered and reused.

Sparge—To  heat  a  liquid  by means of live steam entering through a
perforated or nozzled pipe.

Spray Evaporation—A method of wastewater disposal in which the  water
in  a  holding  lagoon equipped with spray nozzles is sprayed into the
air to expedite evaporation.

Spray Irrigation—A method of disposing of some organic wastewaters by
spraying them on land, usually from pipes equipped with spray nozzles.
See Soil Irrigation.

sq m—Square meter.

Steam Distillation—Fractionation in which steam introduced as one  of
the  vapors  or  in which steam is injected to provide the heat of the
system.

Steaming—Treating wood material with steam to soften it.

Sump—(1)   A  tank  or  pit  that  receives  drainage  and  stores  it
temporarily,  and  from which the drainage is pumped or ejected; (2) A
tank or pit that receives liquids.

Tall Oil—A generic name for a number of products  obtained  from  the
manufacture  of  wood . pulp  by  the  alkali  (sulfate)  process, more
popularly known as the Kraft process.   Tc  provide  some  distinction
between  the  various  products,  designations  are  often  applied in
accordance with the process or composition, seme of  which  are  crude
tall  oil,  acid-refined  tall oil, distilled tall oil, tall oil fatty
acids, and tall oil rosin.

Tall Oil,  Crude—A dark brown  mixture  of  fatty  acids,  rosin,  and
neutral  materials  liberated  by the acidification of soap skimmings.
The fatty acids are a mixture of oleic acid  and  linoleic  acid  with
lesser  amounts  of  saturated and other unsaturated fatty acids.  The
rosin is composed of resin acids similar to those  found  in  gum  and
wood  rosin.   The neutral materials are composed mostly of polycyclic
hydrocarbons, sterols, and other high-molecular-weight alcohols.

Terpenes—The major chemical components of  turpentine.   A  class  of
unsaturated  organic  compounds  having the empirical formula C10 H16,
occurring  in   most   essential   oils   and   oleoresinous   plants.
Structurally,   the  important  terpenes  and  their  derivatives  are
                                 192

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classified as monocyclic (dipentene), bicyclic (pinene), and  acyclic (
myrcene).

Tertiary   Treatment—The  third  major  step  in  a  waste  treatment
facility.   As used in this document,  the  term  refers  tc  treatment
processes following biological treatment.

TOC—Total Organic Carbon is a measure of the organic contamination of
a water sample.  It has an empirical relationship with the biochemical
and chemical oxygen demands.

T-FO4-P—Total phosphate as phosphorus.  See Nutrients.

Total Phenols—See Phenols.

Traditional  Parameters—Those  parameters  historically  of interest,
e.g., BOD, COD, SS, as compared to Priority Pollutants.

Turpentine—A light-colored,  volatile  essential  oil  from  resinous
exudates  or  resinous  wood associated with living or dead coniferous
kinds of turpentine as  follows:   (1)  gum  turpentine,  obtained  by
distilling  the  gum  collected  from  living  pine  trees; (2) steam-
distilled wood turpentine, from the oleoresin within the wood cf  pine
stumps   or  cuttings,  either  by  direct  steaming  of  mechanically
disintegrated wood or after solvent extraction of the  oleoresin  from
the wood;  (3) sulfate wood turpentine, recovered during the conversion
of wood pulp by the Kraft  (sulfate) process.   (Sulfate wood turpentine
is  somewhat  similar  to  gum  turpentine  in  composition);   and  (4)
destructively distilled wood turpentine, obtained by fracticnation  of
certain oils recovered from the destructive distillation cf pine wood.

Vacuum  Water—Water  extracted  from  wocd  during  the vacuum period
following steam conditioning.

Vat—Large metal containers in which logs are  "conditioned" or  heated
prior  to  cutting.   The  two basic methods for heating are by direct
steam contact in "steam vats" or by steam-heated water in  "hot  water
vats."

Water  Balance—The  water  gain   (incoming  water) of a system versus
water loss (water discharged or lest).

Water-Borne Preservative—Any one of several formulations of inorganic
salts, the most common of which are based  on  ccpper,  chromium,   and
arsenic.

Wet  Scrubber—An  air  pollution  control  device  which involves  the
wetting of particles in an air stream and the  impingement  of  wet  or
dry particles on collected surfaces, followed  by flushing.

Zero Discharge—See No Discharge.
                                 193

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                                               APPENDIX  A
EPA   Effluent   Guidelines  Division   List  of
Priority  Pollutants  for   B.A.T.  Revision  Studies
COMPOUND NAME

  1.  'acenaphthene
  2.  "acrolein
  3.  "aery ion itrile
  4.  "benzene
  5.  "benzidine
  6.  "carbon tetrachioride
        (tetrachloromethane)
     •chlorinated benzenes (other than
        d icfi I orobenzenesi
  7.     chlorobenzene
  8.     1,2.4-trichlorobenzene
  9.     hexachlorobenzene
     'chlorinated ett-anes (including 1 2-
        dichloroethane, 1,1,1-trichloro-
        ethane and Nexachloroethane)
 10.     1,2-dichloroethane
 11.     1,1,1 -trichtorcethane
 12.     hexachlo roe thane
 13.     1,1-dichlorDethane
 14.     1,1 ,2-trichl aroethane
 15.     1.1 22-tetrachloroethane
 16.     chloroethane
     •chloroaikyl athers (chloromethyl,
        chloroethyl and mixed ethers)
 17,     bis(chloromethyi) ether
 18.     bts(2-chloroethyl) ether
 19.     2-chioroethyl vinyl ether (mixed)
     •chlorinated naphthalene
 20.     2-chloronaphthalene
     •chlorinated phenols (other than
        those listed elsewhere; includes
        trichlorophenofs and chlorinated
        cresols)
 21.     2 4,6-trichlorophenol
 22.     parachlorometa cresol
 23.  'chloroform (trichlorometharie)
 24.  *2-chlorophenol
     * dichloroben2enes
 25.     1,2-dichlorobenzene
 26.     1,3-dichforobenzene
 27.     1,4-dichlorobenzene
     'dichlorobenzidine
 28.     3,3'
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                              APPENDIX A-l

     TOXIC OR POTENTIALLY TOXIC SUBSTANCES NAMED IN CONSENT DECREE
Acenapthene
Acrolein
Acrylonitrile
Aldrin/Dieldrin
Antimony
Arsenic
Asbestos
Benzidine
Benzene
Beryllium
Cadmi urn
Carbon Tetrachloride
Chlordane
Chlorinated Benzene
Chlorinated Ethanes
Chlorinated Ethers
Chlorinated Phenol
Chloroform
2-Chlorophenol
Chromium
Copper
Cyanide
DDT
Dichlorobenzene
D i chlorobenzi di ne
Dichloroethylene
2,4-Dichlorophenol
Dichloropropane
2,4-Dimethylphenol
Dinitrotoluene
1,2-Diphenylhydrazine
Endosulfan
Endrin
Ethyl benzene
Fluoranthene
Haloethers
Halomethanes
Heptachlor
Hexachlorobutadiene
Hexachlorocyclohexane
Hexachlorocyclopentadiene
Isophorone
Lead
Mercury
Nickel
Nitrobenzene
Nitropnenol
Nitrosarm'nes
                           197

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                              APPENDIX A-2

      LIST OF SPECIFIC UNAMBIGUOUS RECOMMENCED PRIORITY POLLUTANTS
 1.  benzidine
 2.  1,2,4-trichlorobenzene
 3.  hexachlorobenzene
 4.  chlorobenezene
 5.  bis(chloromethyl) ether
 6.  bis(2-chloroethyl) ether
 7.  2-chloroethyl  vinyl ether (mixed)
 8.  1,2-dichlorobenzene
 9.  1,3-dichlorobenzene
10.  1,4-dichlorobenzene
11.  3,3'-di chlorofaenzidi ne
12.  2,4-dinitrotoluene
13.  2,6-dinitrotoluene
14.  1,2-di phenylhydrazi ne
15.  ethyl benzene
16.  4-chlorophenyl phenyl ether
17.  4-bromophenyl  phenyl ether
18.  bis(2-chloroisopropyl) ether
19.  bis(2-chloroethoxy) methane
20.  isophorone
21.  nitrobenzene
22.  N-nitrosodimethylamine
23.  N-nitrosodiphenylamine
24.  N-nitrosodi-n-propylamine
25.  bis(2-ethylhexyl) phthalate
26.  butyl benzyl  phthalate
27.  di-n-butyl phthalate
28.  diethyl phthalate
29.  dimethyl phthalate
30.  toluene
31.  vinyl chloride (chloroethylene)
32.  acrolein
33.  acrylonitrile
34.  acenaphthene
35.  2-chloronaphthalene
36.  fluoranthene
37.  naphthalene
38.  1,2-benzanthracene
39.  benzo(a)pyrene(3,4-benzopyrene)
40.  3,4-benzofluoranthene
41.  11,12-benzof1uoranthene
42.  chrysene
43.  acenaphthylene
44.  anthracene
45.  1,12-benzoperylene
46.  fluorene
47.  phenanthrene
48.  1,2,5,6-dibenzanthracene
                            198

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2.  list of Specific Unambiguous Recommended Priority Pollutants

     1.  benzidine
     2.  1,2,4-trichlorobenzene
     3.  hexachlorobenzene
     4.  chlorobenezene
     5.  bis(chloromethyl) ether
     6.  bis(2-chloroethyl) ether
     7.  2-chloroethyl vinyl ether (mixed)
     8.  1,2-dichlorobenzene
     9.  1,3-di chlorobenzene
    10.  1,4-dichlorobenzene
    11.  3,3'-dichlorobenzidine
    12.  2,4-dinitrotoluene
    13.  2,6-dinitrotoluene
    14.  1,2-diphenylhydrazine
    15.  ethyl benzene
    16.  4-chlorophenyl phenyl ether
    17.  4-bromophenyl phenyl ether
    18.  bis(2-chloroisopropyl) ether
    19.  bis(2-chloroethoxy) methane
    20.  isophorone
    21.  nitrobenzene
    22.  N-nitrosodimethylami ne
    23.  N-nitrosodiphenylamine
    24.  N-nitrosodi-n-propylamine
    25.  bis(2-ethy1hexyl) phthalate
    26.  butyl benzyl phthalate
    27.  di-n-butyl phthalate
    28.  diethyl phthalate
    29.  dimethyl phthalate
    30.  toluene
    31.  vinyl chloride (chloroethylene)
    32.  acrolein
    33.  acrylonitrile
    34.  acenaphthene
    35.  2-chloronaphthalene
    36.  fluoranthene
    37.  naphthalene
    38.  1,2-benzanthracene
    39.  benzo(a)pyrene(3,4-benzopyrene)
    40.  3,4-benzof1uoranthene
    41.  11,12-benzof1uoranthene
    42.  chrysene
    43.  acenaphthylene
    44.  anthracene
    45.  1,12-benzoperylene
    46.  fluorene
    47.  phenanthrene
    48.  1,2,5,6-dibenzanthracene
                         199

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49.  indeno (1,2,3-,cd)pyrene
50.  pyrene
51.  benzene
52.  carbon tetrachloride (tetrachloromethane)
53.  1,2-dichloroethane
54.  1,1,1-trichloroethane
55.  hexachloroethane
56.  1, 1-di ch1oroethane
57.  1,1,2-trichloroethane
58.  1,1,2,2-tetrachlorcethane
59.  chloroethane
60.  1,1-di chlcroethylene
61.  1,2-trans-dichloroethylene
62.  1,2-di chloropropane
63. " 1,2-dichloropropylene (1,2-dichloropropene)
64.  methylene chloride (dichloromethane)
65.  methyl chloride (chloromethane)
66.  methyl bromide (bromomethane)
67.  bromoform (tribromomethane)
68.  dichlorobromomethane
69.  trichlorofluoromethane
70*  dichlorodifluoromethane
71.  chlorodi bromomethane
72.  hexachlorobutadi ene
73.  hexachtorocyclopentadiene
74.  tetrachloroethylene
75.  chloroform (trichlororcethane)
76.  tri chloroethylene
77.  aldrine
78.  dieldrin
79.  chlordane (technical mixture and metabolites)
80.  4,4'-DDT
81.  4,4'-DDE (p.p'-DDX)
82.  4,4'-ODD (p.p'-TDE)
83.  a-endosulfan-Alpha
84.  b-endosulfan-Beta
85.  endosulfan sulfate
86.  endrin
87.  endrin aldehyde
88.  endrin ketone
89.  heptachlor
90.  heptachlor epoxide
91.  a-BHC-Alpha
92.  b-8HC-Beta
93,  r-BHC (lindane)-Gamrca
94.  g-BHC-Delta
95.  PCB-1242 (Arochlor 1242)
96.  PCB-1254 (Arochlor 1254)
97.  toxaphene
98.  2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
99.  2,4,6-trichlorophenol
                       200

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100.  parachlorometa cresol
101.  2-chlorophenol
102.  2,4-dichloropnenol
103.  2,4-dimetnylphenol
104.  2-nitrophenol
105.  4-m'trophenol
106.  2,4-dim'trophenol
107.  4,6-di nitro-o-cresol
108.  pentachlorophenol
109.  phenol
110.  cyanide (Total)
111.  asbestos (Fibrous)
112.  arsenic (Total)
113.  antimony (Total)
114.  beryllium (Total)
115.  cadmium (Total)
116.  chromium (Total)
117.  copper (Total)
118.  lead (Total)
119.  mercury (Total)
120.  nickel (Total)
121.  selenium (Total)
122.  silver (Total)
123.  thallium (Total)
124.  zinc (Total)
                        201

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Table A-l.  Itemizatlon of Volatile Priority Pollutants
chloromethane
bromomethane
chloroethane
t ri chlorof1uororoethane
bromochloromethane (IS)
trans-l,2-dichloroethylene
1,2-dichloroethane
carbon tetrachloride
bis-chloromethyl ether (d)
trans-l,3-dichloropropene
dibromochloromethane
1,1,2-tri chloroethane
2-chloroethylvinyl ether
bromoform
1,1,2,2-tetrachloroethane
toluene
ethyl benzene
acrylonitrile
di chlorodi f1uoromethane
vinyl  chloride
methylene chloride
1,1-di chloroethylene
1,1-dichloroethane
chloroform
1,1,1-tr! chloroethane
bromodichloromethane
1,2-dichloropropane
trichloroethylene
cis-ls3-dichloropropene
benzene
2-bromo-l-chloropropane (IS)
1,1,2,2-tetrachloroethene
1,4-dichlorobutane (IS)
chlorobenzene
acrolein
                        202

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                                    APPENDIX B
                      SAMPLE 308 DATA COLLECTION PORTFOLIO
                                          Plant Code/Subcat._
                                          Date Response Rec'd.
         GUM AND WOOD CHEMICALS MANUFACTURING POINT SOURCE CATEGORY

                                 (SIC 2861)
               Note:  Carefully read Instructions and Definition
                      of Terms before responding to these questions.
A.  GENERAL INFORMATION

(1)  Plant/firm name 	

(2)  Plant Location	
(3)  Plant mailing address
(4)  Name of Respondent	|	Title,

(5)  Address of Respondent	
(6)  Telephone number of Respondent	


8.  PLANT OPERATIONS

     (7)  []   If this plant does no manufacturing on site (i.e., a sales office,
     warehouse, etc,), do not complete the remainder of this survey.  Check
     this block and return the entire form in the enclosed envelope.

     (8)  []   If this plant manufactures only char and charcoal briquets,
     check this block and answer questions 64 or 65, then return the entire
     form in the enclosed envelope.

     Has this plant filled out another industry survey for the EPA Effluent
     Guidelines Division?
      (9) []    Yes
     (10) []    No
     If yes, in what category was the questionnaire submitted? (11)	
     Indicate the type of operations at this site:
     (12) []   Only Gum and Wood Chemicals (SIC 2861) are produced at this
               site.
     (13) []   This plant produces gum and wood chemicals (SIC 2861), but
               also, produces other classes of products. (Specify)	
                                203

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     Indicate the date this plant was placed in operation (14)
     Indicate the date of the most recent physical  plant renovation
     (15)     	.


C.    PRODUCTS AND PROCESSES

     Please provide a simple schematic diagram  of the manufacturing processes
     involving gum and wood chemicals.

     Total  1977 production of Gum and Wood Chemicals  was (16)	pounds.

     Average 1977 production of Gum and Wood Chemicals was  (17)	pounds
     per day.

     Number of days in 1977 with production of  Gum  and Wood Chemicals
     (18)	days.

     Total  1977 production of all other products  manufactured  at plant location
     was (19)	pounds.

     Average 1977 production of all  other products  manufactured  at plant
     location was (20)	pounds per day.

     Is the production of Gum and Wood Chemicals  seasonal at your plant?
     (21)  []  yes
     (22)  []  no

     Provide approximate  percentages of total production of Gum  and Wood
     Chemicals for each of the following products,  if produced in 1977:

     Subcategory A -Sulfated turpentine, a by-product of the Kraft (sulfate)
                    pulping process:

          a - Pinene          (23)	
          b - Pinene          (24)	
          Dipentine           (25)	
          Limonene            (26)	
          Other               (27)	
     Subcategory B -  Gum resin and turpentine manufacture by steam distillation
                     of crude gum (exudate)  from living longleaf pine and
                     slash pine trees:

          Gum Resin           (28)	
          Gum Terpentine      (29)	
          a - Pinene           (30)	
          b - Pinene           (31)	
          Paper Size           (32)	
          Other               (33)	
                                 204

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Subcategory C - Wood Resin, turpentine, and pine oil manufacture by
                solvent extraction and steam distillation of old resinous
                wood stumps from cut-over pine forests:

     Wood Resin          (34)	
     Wood Turpentine     (35)	
     Dipentene (intermediate
       terpenes)         (36)	
     Wood Pine Oil       (37)	
     a - Pinene          (38)	
     b - Pinene          (39)	
     Paper Size          (40)	
     Other               (41)	
Subcategory D - Tall oil resin, pitch, and fatty acids manufacture  by
                fractionation of crude tall oil, a by-product  of  the
                Kraft  (sulfate) pulping process:

     Tall Oil Resin      (42)                    _  ^_^
     Tall Oil Fatty Acids(43)"
     Tall Oil Pitch       (44),
     Sulfate Turpentine   (45)"
     Sulfate Pine Oil     (46)
     Methyl Mercaptan     (47)"
     a - Pinene           (48)"
     b - Pinene           (49)"
     Paper Size           (50)
     Other                (51)"
Subcategory E - Essential oils manufacture  by  steam distillation of scrap
                wood  fines  from  select  lumbering  operations:

     Cedarwood Oil        (52)	
     Wintergreen  Oil      (53)	
     Spearmint Oil        (54)	
     Eucalyptus Oil       (55)_	
     Other                (56)	
Subcateqory  F  -  Resin  based  derivatives  (specifically,  resin esters  and
                 modified  resin  esters) manufactured by  the chemical
                 reaction  of  gum,  wood, and tall  oil resins:

      Resin Oils           (57)	
      Ester Gum (Glycerol
        esters)           (58)	
      Synthetic Resins:
        Phenolic  resins    (59)	
        Alkyd resins       (60)	'
        Maleic  resins      (61)	
        Fumeric resins     (62) 	
        Other             (63)	
                                205

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D.   WASTEWATER GENERATION
    Note:   Process wastewaters include those resulting from contact cooling,
            wet scrubbers, and cleanup, or other process related use, i.e. water
            contacting product or raw materials.
            Segregated non-contact cooling waters, boiler blowdown, and
            sanitary wastewaters are not included.

    Does any process wastewater result from your operations?
    (64)  []   Yes
    (65)  []   No

     Estimated volume of process wastewater in gallons per day that corresponds
     to the production data given in Section C for each of the following
     products during normal manufacturing of Gum and Wood Chemicals only:

     Subcategory A -Sulfated turpentine, a by-product of the Kraft (sulfate)
                    pulping process:
          a - Pinene
          b - Pinene
          Dipentine
          Limonene
          Other
                    (66)
                    (67)'
                    (68)-
                    (69)
                    (70)
     Subcategory B - Gum resin and turpentine manufacture by steam distillation
                     of crude gum (exudate)  from living longleaf pine "and
                     slash pine trees:
Gum Resin
Gum Terpentine
a - Pinene
b - Pinene
Paper Size
Other
                              (71)
                              (72)
                              (73)
                              (74)
                              (75)
     Subcategory C - Wood Resin,  turpentine,  and pine oil  manufacture by
                     solvent extration and steam distillation of old resinous
                     wood stumps  from cut over pine forests:

          Wood Resin          (77)	
          Wood Turpentine     (78)	
          Dipentene (intermediate
            te rpenes)         (79)	
          Wood Pine Oil        (80)	
          a - Pinene          (81)	
          b - Pinene          (82)	
          Paper Size          (83)	
          Other               (84)	
                                     206

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Subcategory D - Tall  oil resin, pitch, and fatty acids manufacture by
                fractionation of crude tall  oil, by-products of the
                Kraft (sulfate) pulping process:

     Tall Oil Resin      (85)
     Tall Oil Fatty Adds(86)
     Tall Oil Pitch      (87)
     Sulfate Turpentine  (88)"
     Sulfate Pine Oil    (89)'
     Methyl Mereaptan    (90)
     a - Pinene          (91)"
     b - Pinene          (92)"
     Paper Size          (93)"
     Other               (94)"
Subcategory E - Essential oils manufacture by steam distillation of scrap
                wood fines from select lumbering operations:

     Cedarwood Oil       (95)	
     Wintergreen Oil     (96)	
     Spearmint Oil       (97)	
     Eucalyptus Oil      (98)	
     Other               (99)	
Subcategory F - Resin based derivatives (specifically, resin esters and
                modified resin esters) manufactured by the chemical
                reaction of gum, wood, and tall oil resins:

     Resin Oils         (100)	
     Ester Gum (Glycerol
       esters)          (101)	
     Synthetic Resins:
       Phenolic resins  (102)	
       Alkyd resins     (103)	
       Maleic resins    (104)	•
       Fumeric resins   (105) 	
       Other            (106)	
     If you have reason to believe that your Gum and Wood Chemicals manu-
     facturing operations do not fit into any of the above subcategories,
     please attach an explanation of your rationale and an estimate of the
     gallons of wastewater generated each day for each product.

     The average volume of process wastewater produced from Gum and Wood
     Chemicals manufacturing operations (107)	gallons/day.

     The average volume of process wastewater produced from all  other
     manufacturing operations at plant location (108)	gallons/day,

     Do you use wet scrubbers in the Gum and Wood Chemicals manufacturing
     for air pollution control?
     (109)  [J   Yes
     (110)  []   No
                                   207

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E.  WASTEWATER DISPOSAL

     Please indicate method used to dispose of process wastewaters.

     (Ill) []  Do you discharge treated or untreated  process-related wastewaters
               directly to a receiving body of water? If so,  check this  block.

     (112) []  Do you discharge partially treated or  untreated process-related
               wastewaters directly to a Publicly Owned  Treatment Works  (POTW)
               via municipal sewer system?  If so, check this  block.

     (113) []  If you have a discharge other than that described by  (111)  or
               (112), such as to the waste stream of  another plant, a  septic
               tank, an evaporation lagoon, an irrigation system, etc.,  please
               explain briefly below:
     (114) []  If you answered Question 111 or 113 yes, do you have firm
               plans to discharge process-related wastewater to a POTW in the
               future? 	.

     Do you have an NPDES permit?
     (115) []
     (116) []
Yes
No
     If not, have you made application for an NPDES permit?
     (117) []   Yes
     (118) []   No

     If you discharge directly to a receiving body of water, attach a copy of
     your most recent permit and application if you answered yes to (115),
     (117), above and provide agency name, complete address, telephone
     number, and contact to which application, monitoring data, or other
     permit information is sent:
      (119).
      If  process-related wastewater is discharged to a publicly owned treatment
      works,  provide  complete name, address, and telephone number of municipality
      or  sewer  authority:

      (120)	:	_	
                                  208

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If process-related wastewater is discharged to a city sewer,  indicate if
the municipality or sewer authority utilizes any of the following:
(121)
(122)
(123)
(124)
        Industrial  Waste  Ordinance  (If yes,  attach  copy)
        Wastewater  sampling at your plant
        Local  permit system to discharge  to  the  sewer
        A requirement that you sample and analyze your  own waste.
If you discharge to an industrial  treatment plant or to the wastewater
stream of another plant, provide the complete name, address, and
telephone number of the plant that is providing this service to you.

(125)	______^_^_	
This plant makes use of the following method(s) of treatment or condition-
ing for Gum and Wood Chemicals process wastewater prior to discharge:
Note:
(126)
(127)
(128)
(129)
(130)
(131)
(132)
(133)
(134)
(135)
(136)
(137)
(138)
(139)
(140)
(141)
(142)
Please provide a_ simple schematic diagram of the  treatment methods
involving gum and wood chemicals process  wastewater.

        None
        Contract hauling
        Equalization
        Clarification
        Aerated Lagoon
        Activated Sludge
        Neutralization
        Nutrient Addition
        Non-aerated Pond
        Air Flotation Control
        Granular Activated Carbon
        Powdered Carbon Addition
        Filtration
        Evaporation
        Oil Skimming
        Settling
        Other (specify)	.
Do you discharge substandard or other spoiled batches with wastewater?
(143)   []     Yes
(144)   []     No
                             209

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F.    WASTEWATER MONITORING DATA
     This section refers to routine monitoring  data  for untreated  or  treated
     process-related wastewaters  or sludges  resulting  from  the manufacture  of
     Gum and Wood Chemicals ONLY.   Please  note  whenever data  are for  process
     wastewater combined with non-process  wastewater or wastewater from  other
     than Gum and Wood Chemical manufacturers.

     Report average 1977 concentrations  (mg/1)  of treated and untreated
     wastewater.   Please attach copies of  your  1977  monitoring data.
               Parameter

          (145)  BODS
          (146)  COD
          (147)  Flow (MGD)
          (148)  pH
          (149)  Oil  and Grease
          (150)  Phenols
          (151)  Phosphorus
          (152)  Dissolved Solids
          (153)  Nitrogen Compounds
          (154)  Sul fates
          (155)  Temperature
          (156)  TOC
          (157)  TSS
          (158)  Heavy Metals
          (159)  Trace Organics
          (160)  Other (specify)
Wastewater   Sample    Wastewater    Sample
Untreated   Frequency  Treated      Frequency
     This facility is conducting or has  conducted  any  of  the  following measures
     in the past three years  to abate  water  pollution:

          (161)  []  private consultant studies
          (162)  []  in-house  engineering studies
          (163)  []  bench scale treatability studies
          (164)  []  pilot plant studies
          (165)  |]  in-process  hydraulic surveys
          (166)  []  treatment system improvements
          (167)  []  process changes or modifications
          (168)  []  other	
                                  210

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G.    WATER POLLUTION COSTS:   ALLOCATED ANNUAL COSTS  TO  GUM AND WOOD  ONLY.
     DIRECT DISCHARGERS
     	                                                 Average/year
                                     Before                             Projected
                                      1975     1975      1976     1977     1978-83

     (169)  Annual Operating Costs  $	   	   	   	  	

     (170)  Capital Expenditures    $	   	   	   	  	
     INDIRECT DISCHARGERS:  ALLOCATED ANNUAL COSTS TO GUM AND WOOD CHEMICALS ONLY.
                                                                     Average/year
                                                                     Projected
                                      1974    1975    1976    1977    1978-83
      (171) Annual User Charges     $

      (172) Annual Capital cost
             Decovery Charge       $

      (173) Pretreatment System
             Capital Cost          $

      (174) Annual Operating Cost   $
      ENERGY USAGE  FOR WASTEWATER TREATMENT.

      (175) Electric  power  cost for  1977  £	/kwh  Total kilowatt/hours(176)_
      (177) Other Energy  Required 1977 	BTU.

      Approximate percentage  of total energy  usage in Gum and Wood Chemical
      Manufacturing attributable to  water pollution controls  (178)	%.


 H.    PRIORITY POLLUTANTS FOR GUM AND WOOD  CHEMICAL MANUFACTURING ONLY.

      Please complete the following  Priority  Pollutant  listing.  For each
      pollutant please  check  whether it  is  Known  To Be  Present,  Suspected To
      Be Present, Suspected To Be Absent, Known To Be Absent, or Unknown.
      Suitable responses  should be based on the following descriptions:

      Known To Be Present:  The compound has  been detected in the discharge or
      is known to be  present  in the  raw  waste load.

      Suspected To  Be Present: The  compound  is a raw material  in the  processes
      employed, a product,  a  by-product, catalyst, etc.  Its  presence  in the
      raw waste load  and  discharge  is  a  reasonable technical  judgment.

      Suspected To  Be Absent:  No  known  reason to predict that  the  compound is
      present  in the  discharge.

                                  211

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 Known To Be Absent:   The compound  has  not been  detected  in  the  raw waste  load.

 Unknown:   The compound has  not been  tested for  in  the  raw waste  load  and  Is  not
 a  raw material  employed in  the process,  a product,  a by-product,  catalyst, etc.

 _  .   .                             Known      Suspected  Suspected  Known
 Priority Pollutant                Present   Present   Absent    Absent Unknown

 (179)   acenaphthene               	
 (180)   acrolein                   ZZZZ  ~~~  ~~~_  	  	
 (181)   acrylonitrile               	              	  	  	
 (182)   benzene                    HZH  HHZ	  	
 (183)   benzidine                  	        '             	  	
 (184)   carbon  tetrachloride       	  ZUZZ  	  	  	
        (tetra chloromethane)                                            	

 (185)   ch1orobenezene             	  	
 (186)   1,2,4-trichlorobenzene     	  ZZZIZ  ZUZZ  	  	
 (187)   hexachlorobenzene                                                	
(188)  1,2-dichloroethane
(189)  1,1,1, trichlorethane
(190)  hexach1oroethane
(191)  1,1-dichloroethane
(192)  1,1,2-trichloroethane
(193)  1,1,2,3-tetrachloroe-
        thane
(194)  chloroethane

(195)  bis(chloromethyl) ether
(196)  bis(2-ch1oroethyl)
        ether
(197)  2-chloroethyl vinyl
        ether (mixed)

(198)  2-chloronaphthalene

(199)  2,4,6-trichlorophenol
(200)  parachlorometa cresol
(207)  chloroform (trichlorome-
        thane)
(202)  2-chlorophenol
(203)  1,2-dichlorobenzene
(204)  1,3-di chlorobenzene
(205)  1,4-di chlorobenzene

(206)  3,3-dichlorobenzidine

(207)  1,1-dichloroethylene
(208)  1,2-trans-dichloroethylene
(209)  2,4-HTcnTorophenol
                          212

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 Part VI  (Cont.)

                                  Known     Suspected Suspected Known
 Priority Pollutant                Present   Present   Absent    Absent Unknown

 (210)  1,2-dichloropropane        	   	   	
 (211)  1,3-dichloropropylene      	      	                     	
       (1,3-dichloropropene)
 (212)  2,4-dimethylphenol         	   	   	   	  	

 (213)  2,4-dinitrotoluene         	   _____
 (214)  2,6-dinitrotoluene         HIZII   ZZZZ   ZZZZ   HZZ  ^HZ

 (215)  1,2-diphenylhydrazine      	   	   	

 (216;  ethylbenzene               	   	       	

 (217)  Fluoranthene
(218)  4-chlorophenyl phenyl
        ether
(219)  4-bromophenyl phenyl
        ether
(220)  bis(2-chloroisopropyl)
        ether
(22*H  bis(2-chloroethoxy)
        methane

(222)  methylene chloride
       (dichloromethane)
(223)  methyl chloride
       (chloromethane)
(224)  methyl bromide
       (bromomethane)
(225)  bromoform (tribromome-
        thane
(226)  di ch1orobromomethane
(227)  trichlorofluoromethane
(228)  dichlorodifluoromethane
(229)  chlorodibromomethane

(230)  hexachlorobutadiene

(231)  hexachlorocyclopentadiene

(232)  isophorone

(233)  napthalene

(234)  nitrobenzene
                              213

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Part VI (Cont.)
Priority Pollutant

(235)  2-nitrophenol
(236)  4-nitrophenol
(237)  2,4-di ni trophenoI
(238)  4,6-dinitro-o-cresol

(239)  N-nitrosodimethylamine
(240)  N-nitrosodiphenylamine
(241)  N-nitrosodi-n-propylamine

(242)  pentachlorophenol

(243)  phenol

(244)  bis(2-ethylhexy1)
        phthalate
(245)  butyl benzyl phthalate
(246)  di-n-butyl phthalate
(247)  diethyl phthalate
(248)  dimethyl phthalate
(249)  di-n-octyl phthalate
(250)  1,2-benzathracene
(251)  benzo (a)pryene (3,4-benzo
       pyrene)
(252)  3,4-benzofluoranthene
(253)  11,12-benzofluoranthene
(254)  chrysene
(255)  acenaphthylene
(256)  anthracene
(257)  1,12-benzoperylene
(258)  fluorene
(259)  phenanthrene
(260)  l,2:5,6-dibenzanthracene
(261)  indeno{1,2,3-C,D) pyrene
(262)  pyrene

(263)  2,3,7,8-tetrachlorodi-
        benzo-p-dioxin (TCDD)
(264)  tetrachloroethylene

(265)  toluene

(266)  tri chloroethylene

(267)  vinyl chloride
        (chloroethylene)

(268)  xylene
Known     Suspected Suspected Known
Present   Present   Absent    Absent Unknown
                              214

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Part VI (Cont.)

                                  Known     Suspected Suspected Known
Priority Pollutant                Present   Present   Absent    Absent Unknown

       Pesticides and Metabolites

(269)  aldrin                     	   _____
(270)  dieldrin                   ^^_____   ^^_2         '    ^^ ^^
(271)  chlordane (technical mixture
       and metabolites)           ^_^_
(272)  4,4'-DDT                   ~~   ~~~   ——'	
(273)  4,4'-DDE (p,p'-DDX)        ~~~   ~~   ~~~~	
(274)  4,4'-ODD (p.p'-TDE)        ~~   ~~~	
(275)  a-endosulfan
(276)  B-endosulfan
(277)  endosulfan sulfate         ;

(278)  endrin
(279)  endrin aldehyde

(280)  heptachlor
(281)  heptachlor epoxide         "

(282)  a-BHC
(283)  B-BHC
(284)   -BHC (lindane)
(285)   -BHC                      ;

(286)  PCB-1242 (Archlor 1242)
(287)  PCB-1254 (Archlor 1254)
(288)  PCB-1221, 1248, 1232, 1260,"
       or 1016
(289)  Toxaphene
       Metals
(290)  Antimony (Total)
(291)  Arsenic (Total)
(292)  Asbestos (Fibrow)
(293)  Beryllium (Total)
(294)  Cadmium (Total)
(295)  Chromium (Total)
(296)  Copper (Total)
(297)  Cyanide (Total)
(298)  Lead (Total)
(299)  Mercury (Total)
(300)  Nickel (Total)
(301)  Selenium (Total)
(302)  Silver (Total)
(303)  Thallium (Total)
(304)  Zinc (Total)
                             215

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For those Priority Pollutants which are known or suspected to be present,
please indicate to the best of your knowledge the prime source of the material.
Specifie Pollutant
Source (Raw Material/Process Line)
QUESTIONNAIRE COMPILATION

Please provide the following information regarding completion of questionnaire
Compiler
      Title
Office Location_

Date Completed
      Telephone
If you have any questions, please contact
THANK YOU FOR YOUR COOPERATION.  UPON COMPLETION OF THE SURVEY, PLACE THE
FORMS AND ALL REQUESTED ATTACHMENTS IN THE ENVELOPE PROVIDED AND RETURN TO

                U. S. EPA GUM AND WOOD CHEMICALS INDUSTRY SURVEY

                             P. 0. BOX 13454

                         GAINESVILLE, FL.  32604
BE SURE TO RETAIN A COMPLETE COPY FOR YOUR RECORDS.  RESPONDENTS WILL BE
CONTACTED WHEN NECESSARY TO COMPLETE OR CLARIFY ANSWERS.
                                  216

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                              APPENDIX C

                       RECOMMENDED PARAGRAPH 8
            EXCLUSION UNDER THE NRCC SETTLEMENT AGREEMENT

GUM AND WOOD CHEMICALS INDUSTRY CHAR AND CHARCOAL BRIQUETS SUBCATEGOR*

Summary of Recommendations

EPA  is  recommending the exclusion of revise EAT and NSPS limitations
for  all  specific  pollutants  based  on  paragraph  8(a) (i)   of  the
Settlement  Agreement  since  the  existing  EPT  already  requires no
discharge of process wastewater.

Production Processes and Effluents

Char and charcoal are produced by the  thermal  decomposition  of  raw
wood.   Decomposition forms wood distillates which leave the kiln with
the flue gases.  The condensable distillates are collectively referred
to  as  pyroligneous  acid,  which  contains  methanol,  acetic  acid,
acetone,  tars,  oils,  and  water.   These  materials  have  steadily
declined  in  economic  importance  because   of   cheaper   synthetic
substitutes;  therefore, most plants have discontinued recovery of the
by-products from the pyroligneous acid.  Instead, the  distillate  and
other  flue  gases  are  exhausted to the atmosphere.  The condensable
distillates may also be recycled as fuel for the kiln or  recycled  in
the vapor phase as a fuel supply supplement.

A typical flow diagram for char and charcoal briquets manufacturing is
illustrated  in  Figure  1.   This  study  found  no  facilities which
recovered distillation by-products in the United States.

The off gases from the furnaces contain compounds such as acetic acid,
methanol, acetone, tars, and  oils.   These  materials  are  presently
oxidized  in  the afterburners.  The natural gas fuel required for the
afterburners is a significant operating cost.  An alternative emission
control now under consideration scrubs the off gases from the  furnace
to  remove  the  condensables  frcir  the  flue  gases.   The resulting
scrubber liquor would be sent to a separator  where  the  pyroligneous
acid  could  be  recovered.   The water and soluble compounds would be
reused in the scrubber system.  The separated  products  can  then  be
recovered for sale cr used as an auxiliary fuel.
                                 217

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                                       218

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Plants

Seventy-seven  plants  were  identifled
fifty-five percent responded.

Toxic Pollutants
in  the  industry profile and
Toxic pollutant sampling was not conducted on this subcategcry because
current BPT, BAT, and NSPS limitations  call  for  zero  discharge  of
process  wastewater.  All of the plants responding had no discharge of
process wastewater.

EAT and NSPS Limitations

EPA is recommending the  exclusion  of  revised  EAT  and  NSPS  under
paragraph 8 (a) (i)  for all toxic pollutants based on the response of 55
percent  of the plants, all of which had no process wastewater, and on
the basis of existing BPT limitations which require zero discharge  of
process wastewater.

Pretreatment Limitations

EPA  is  recommending  the exclusion of pretreatment limitations under
paragraph 8 (a) (i)  based on a survey cf 55 percent of all plants,  none
of which had process wastewater.
                                219

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RECOMMENDED PARAGRAPH 8 EXCLUSION UNDER THE NREC SETTLEMENT AGREEMENT

GUM AND WOOD CHEMICALS INDUSTRY ESSENTIAL OIL SUECATEGORY

Summary of Recommendations

EPA  is  recommending  the  exclusion  cf  BAT, NSPS, and pretreatment
standards  for  all  specific  toxic  pollutants  based  on  paragraph
8 (a) (iii) .   This subcategory includes seven plants—none of which are
direct  dischargers.   One  plant  is  an  indirect  discharger;   the
remaining  six  do not discharge.  Flows of process wastewater in this
subcategory are low (a maximum flow of 0.015  MGD  from  the  indirect
discharger  under  full-scale  production) .  The cnly toxic pollutants
detected from the screening of the indirect  discharger  were  benzene
and metals, and all were at low levels.

EPA  is recommending the exclusion of the NSPS limitation since no new
sources are expected due to competition from synthetic  oils  and  the
lack  of raw materials.  Exclusion cf pretreatment also is recommended
since only one indirect discharger exists, discharging a small  number
cf toxic pollutants at low concentrations from a small flew.

Production Processes and Effluents

The  only essential oil produced in this subcategcry is cedarwood oil.
Cedarwood oil is produced by steaming cedarwood saw dust  in  pressure
retorts  to  remove  the  oil  from  the wood particles.  The overhead
vapors are condensed and separated  into  cedar  oil  and  wastewater.
Production  of  cedarwood  oil  is  under  stiff  competition from the
synthetic oils manufactured by petroleum companies.  The cedarwood oil
industry is divided into two branches—the western cedar group and the
eastern  cedar  group.   The  western  group  is  a  more   economical
production  because  its  sole function is the production of cedarwood
oil.  Entire cedar trees are ground up for the  oil  production.   The
eastern branch, however, produces cedarwood oil as a by-product of the
production  of  cedar  wood.  The effluent from six of these plants is
self-contained by a lagoon or spraj irrigation.  The  single  indirect
discharger  releases  the  effluent  with  no  pretreatment to a POTW.
Wastewater from this plant is about 15,000 gallons per  day  when  all
three pressure retorts are in operation.

Plants

Nine  plants  exist  in  this subcategory, one indirect discharger and
seven self-contained dischargers.  The indirect discharger  discharges
a  maximum  of  approximately  0.015 MGD when all three retorts are in
operation.  In 1977, the plant used  only  one  retort  (approximately
0,005  MGD)   because  of  a  shortage  of raw materials and low market
                                 221

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demand.  Future retort use by this plant will depend priirarily en  the
market demand for cedarwood oil.

Toxic  Po_llutants  Screen  sampling  was  conducted  at  the  indirect
discharger.  The analytical results detected benzene and metals in low
concentrations.

EAT and NSPS Limitations

EPA is recommending the exclusion of BAT and  NSPS  limitations  under
paragraph  8 (a) (iii)  for  all  toxic  pollutants on the basis that no
direct erist and no new plants dischargers are expected.

Pretreatment Limitations

EPA is recommending the exclusion cf  pretreatment  limitations  under
paragraph  8(a) (iii)  for  all tcxic pollutants on the basis that only
one indirect  discharger  exists,  the  volume  of  discharge  is  low
(approximately   0.015   MGD  maximum),  the  concentration  of  toxic
pollutants is low, and the industry is not expected to grow because of
competition from synthetic oils and raw material limitations.
                                 222

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RECOMMENDED PARAGRAPH 8 EXCLUSION UNDER THE NREC SETTLEMENT AGREEMENT

GUM AND WOOD CHEMICALS INDUSTRY GUM ROSIN ANE TURPENTINE SUECATEGCRY

Summary of Recommendations

EPA is recommending the  exclusion  cf  BAT,  NSPS,  and  pretreatment
standards  for all specific toxic pollutants on the basis of paragraph
8(a) (iii).  Of seven plants  in  the  industry,  one  is  an  indirect
discharger and the remaining six are self-contained.  These six plants
operate  on  a seasonal basis between May and September  (approximately
180 days per year).  Flows of process wastewaters in this  subcategory
are quite low  (averaging about 1,400 gals/day per plant).

The  only  toxic  pollutants  found  during  screening analysis of the
indirect  discharger  were  benzene,  toluene,  d-EHC,   and   metals.
Exclusion  of  the  NSPS  limitations  is  recommended  because no new
sources are expected and most existing plants are  expected  to  close
within   the  next  10  years  for  economic  reasons.   Exclusion  of
pretreatment also is recommended because only one indirect  discharger
exists.

Production Processes and Effluent

Gum  turpentine  and  rosin  are  produced by the distillation of pine
oleoresin.  The crude oleoresin is collected from the exposed  sapwood
of  pine  trees.   This process is limited to the growing cycle of the
tree which occurs during May through September.

The crude oleoresin is delivered tc the processing  plants  in  435-lb
barrels,  steam-washed,  to remove trash, and stored or processed.  The
process is a simple distillation.  The crude gum  is  heated  and  the
lower  boiling  turpentine and water are collected as condensate.  The
higher boiling rosin is taken from the bottom of the still  as  a  hot
liquid.

The  wastewater  generated  by this process is from the washing of the
crude gum and the  water  freed  in  the  distillation  process.   The
condensed  water is chemically treated, then recycled and used for gum
wash water.

In all but one of the gum processes the wastewater  is  collected  on-
site  and  held in evaporation/percolation ponds.   The one plant which
does not use this method discharges to a POTW.
                                 223

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PIants

There are seven plants in Subcategory E (Gum  Turpentine  and  Rosin).
Six  have self-contained discharges cf low-volume process wastewaters,
and one plant,  which  is  an  indirect  discharger,  has  a  flow  of
approximately  2,300  GPD  from its Subcategory B operations and about
2,700 GPD from its Subcategory F (Resin-based derivatives) operation.

Toxic Pollutants

Sampling was conducted at the indirect discharging plant-  The process
wastewater flow from the  Gum  Rosin  and  Turpentine  production  was
sampled  separately from rosin-based derivatives wastewater flow.  The
analytical results detected benzene, toluene, d-BBC, and metals.

EAT and NSPS Limitations

EPA is recommending exclusion under paragraph 8(a) (iii) for all  toxic
pollutants  on  the  basis  that  nc  direct dischargers exist, no new
plants are expected, and most plants in this subcategory are  expected
to close within the next 10 years,

EPA  is  recommending  the exclusion of pretreatment limitations under
paragraph 8 (a) (iii) for all toxic pollutants on the  basis  that  only
one  indirect  discharger  exists,  and it discharges very low volumes
(2,300 gal/day).
                                 224

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APPENDIX D

ANALYTICAL METHODS AND EXPERIMENTAL PROCEDURE


INTRODUCTION

Protocol

Sampling and analysis of samples for the Gum and Wood Chemicals  Point
Source  Category  were  conducted  from  March  1978  to  October 1978
according to  "Sampling  and  Analysis  Procedures  for  Screening  of
Industrial  Effluents,"  U.S.  Environmental  Protection Agency, March
1977  (revised April 1977).

Overview of Methods

The toxic pollutants may be conventionally considered according to the
broad classification of organics and metals.  The organic toxic pollu-
tants constitute the larger group and were analyzed according  to  the
categories  of  purgeable  volatiles,  extractable semi-vclatiles, and
pesticides and PCB"s.  The principal analytical method for identifica-
tion and quantitation  of  organic  toxic  pollutants  was  repetitive
scanning Gas Chromatography/Mass Spectrometry (GC/MS).  Pesticides and
PCE's  were  analyzed  by Gas Chrcmatography/Electron Capture Detector
(GC/ECD) .

The mass spectrometers  were  tuned  daily  in  a  manner  to  provide
consistent  compound  fragmentation  thereby  permitting  quantitation
directly from the mass spectral reconstructed chrcmatograms.

Compound identification entailed both  gas  chrcmatographic  and  mass
spectroscopic criteria.  These criteria are enumerated as fellows: (1)
Appropriate  retention time within a window defined as + 1 minute that
of the compound in the standard; (2) coincidence of the extracted  ion
current  profile  maxima  of  two   (volatiles) or three (extractables)
characteristic  ions  enumerated  in  the  protocol;  and   (3)  proper
relative ratios of these extracted ion current profile peaks.

Relative response factors for the individual compounds were determined
as:

R  =Ac/Cc=Ac Cs
           As/Cs     As Cc

where  A  is  the integrated area taken from the extracted ion current
profile, and C is the concentration of the component expressed in ppb,
and the subscripts c and s denote corrpcund and standard, respectively.
                                 225

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Concentrations were calculated using these response factors  according
to the expression:
C  =Ac Cs
           As R
with the terms as defined previously.

Due to the variable nature of the samples as indicated by the presence
of  very  large  peaks or large unresolved humps in the chrcmatograms,
all base neutral  and  phenolic  extracts  were  subjected  to  GC/FID
screening under conditions quite similar to that employed in the GC/MS
analysis.    Those   extracts  with  very  large  peaks  and/or  large
unresolved humps were diluted appropriately prior to  GC/MS  analysis.
Due  to  the  number  of  extracts  requiring  dilution,  the internal
standard was added after dilution.

The concentrations cf compounds  in  these  extracts  were  calculated
according  to  the  above  expression  with  the  incorporation  of  a
multiplicative  dilution  factor.   This  factor  is  defined  as  the
quotient  of  the final diluted sairple extract volume and the original
sample extract volume.

Pesticides and PCB's were  analyzed  by  GC/ECD.   Identification  was
based  on  retention  time  relative  to a standard analyzed under the
identical conditions,  Quantitation was based on peak height  for  the
same  standard injection.  Confirmation analysis was routinely carried
out on a dissimilar chromatographic  column  with  GC/MS  confirmation
restricted to high level samples.

The metals were done by atomic absorption spectroscopy.  All classical
parameters were done by standard methods.

DETAILED DESCRIPTION OF ANALYTICAL METHODS

Volatile Toxic Pollutants

The  purgeable  volatile  toxic  pollutants  are those compounds which
possess a relatively high vapor pressure  and  lew  water  solubility.
These  compounds  are  readily  stripped with high efficiency from the
water  by  bubbling  an  inert  gas  through  the  sample  at  ambient
temperature.

The analytical methodology employed for the volatiles was based on the
dynamic headspace technique of Bellar and Lichtenberg.  This procedure
consists  of  two  steps.   Volatile organics are purged from the raw-
water sample onto a Tenax GC-silica gel trap with a  stream  of  inert
gas.   The  volatile  organics are then thermally desorbed into the GC
inlet for subsequent GC/MS identification and quantitation.
                                 226

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The purgeable volatile toxic pollutants are listed in Table D-1
Table D-1.  Purgeable Volatile Toxic Pollutants
chlorometh ane
brcmomethane
chloroethane
trichlorofluoromethane
trans-1,2-dichloroethylene
1,2-dichloroethane
carbon tetrachloride
bis-chloromethyl ether (d)
trans-1,3-dichloropropene
dibromochloromethane
1,1,2-trichloroethane
2-chloroethylvinyl ether
brcmoform
1,1,2r2-tetrachloroethane
toluene
acrylonitrile	
ethylbenzene
dichlorodifluoromethane
vinyl chloride
methylene chloride
1,1-dichlcroethylene
1,1-dichloroethane
chloroform
1,1,1-trichloroethane
bromodichloromethane
1,2-dichloropropane
tr ichloroeth ylene
cis-1,3-dichloropropene
benzene
1, 1,2,2-tetrachloroethene
chlorcbenzene
                                 227

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A 5-ml aliquot of the  raw  water  sample  spiked  with  the  internal
standards  bromochlcromethane  and  1,4-dichlorobutane  was  purged at
ambient temperature with He for 12 minutes onto a 25-cm x 1/8-in. o.d.
stainless steel trap containing an 18-cm bed of Tenax  GC  60/80  mesh
and  a  5-cm bed of Davison Grade 15 silica gel 35/60 mesh.  This 5-ml
aliquot represented a single grab sample or a composite of the various
grab samples collected at the individual station.

The organics were thermally desorbed from the trap for  4  minutes  at
180  with a He flow of 30 ml/min into the GC inlet.  The collection of
repetitively  scanned  mass spectra was initiated with the application
of heat to the trap.  The enumeration cf all instrument parameters  is
presented in Table D-2.

The  bromochloromethane  internal  standard was eirployed to quantitate
individual volatile compounds in a manner analogous to that  discussed
previously in the Overview of Methods.

The  high  levels  of  organics contained in many cf the process waste
streams necessitated preliminary screening of samples.  Tc  accomplish
such  screening,  a  10-ml  portion of the sample was extracted with a
single 1-ml portion of isooctane, and the  extract  was  subjected  to
GC/FID  analysis  to  permit  the  judicious  selection of appropriate
sample volume, i.e., less than 5 ml,  fcr  purge  and  trap  analysis.
Organic-free  water was employed for the dilution so that a uniform 5-
ml sample was purged in all cases.

Many samples contained milligram-per-liter  levels  of  phenol,  alkyl
sulfides  and  disulfides, and a variety of isoprenoid compounds.  The
presence of phenol and the late eluting  isoprenoid  compounds  caused
some  difficulty  in the volatile analyses as these compounds are very
slowly eluted from the gas chromatographic column.

Although  the  nonvolatile   compounds   purge   poorly,   significant
quantities  can  accumulate  on  the  analytical  cclumn  from samples
containing high levels of  organics  present  in  the  wastewater.   A
column   of  0.1  percent  SP-1000   (Carbowax  20  M  esterified  with
nitroterephthalic acid) on 80/100-mesh Carbopack C was employed.   The
greater  temperature  stability  of  the  SP-1000 stationary phase, as
compared with the lower  molecular  weight  Carbowax  1500,  permitted
column  bake out at elevated temperatures for extended periods cf time
without adverse effects.

For  the  same  reasons,  the  purge  and  trap   apparatus   employed
emphasized:   (1)  short-heated  transfer  lines,   (2)  low dead-volume
construction,  (3) manually-operated multiport  valve,  and   (4)  ready
replacement  of  all component parts.  This design permitted the ready
substitution  of  component  parts  with   thoroughly   preconditioned
                                 228

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replacement
blanks.
parts  when serious contamination was indicated by system
Foaming  tended  to  be  excessive  with  a  number  of  the  samples,
particularly  those  analyzed without dilution.  The brief application
of localized heat to the foam trap, as foam began to  accumulate,  was
often  ;ffective  in breaking the foam.  A stock standard was prepared
on a weight basis by dissolving  the  volatile  solutes  in  methanol.
Intermediate  concentrations  prepared  by  dilution  were employed to
prepare aqueous standards at the  20-  and  100-ppb  levels.   A  5-ml
aliquot  of these standards was spiked with the internal standards and
analyzed in a manner identical to that employed with the samples.  The
attendant reconstructed total ion current chroiratcgram for a purgeable
volatile organic standard is presented in Figure E-1.

Semivolatile Toxic Pollutants

The extractable semivolatile toxic pollutants are compounds which  are
readily  extracted  with  methylene chlcride.  They are subjected to a
solubility class separation by serial extraction of  the  sample  with
methylene  chloride  at pH of 11 or greater and at pH 2 or less.  This
provides  the  groups  referred  tc  as  base  neutrals  and   acidics
(phenolics) , respectively.

Ease  neutrals  and  phenolics  were  fractionated  on  the basis of a
solubility class separation.  Due to the widely varying  chemical  and
physical  properties  possessed  by  the individual semivolatile toxic
pollutants, the whole sample, i.e., suspended solids, oil and  grease,
etc., was subjected to extraction,  A listing of the base neutrals and
acidic  semivolatiles is provided in Tables D-3 and D-4.  A 0.7- to 1-
liter sample was subjected to two successive  extractions  with  three
portions  of  methylene  chloride  (150-,  75-, and 75-ml)  at pH 11 or
greater and pH 2 or less  to  provide  the  base  neutral  and  acidic
fractions, respectively.

Emulsions  were broken by the judicious addition of Na2S04 or methanol
and/or simply by standing.

The extract from each fraction was dried by  passage  thrcugh  Na2S04,
and the volume was reduced with a Kuderna-Danish evaporator to 5 to 10
ml.   The  extract  was  further .concentrated to 1 ml in the Kuderna-
Danish tube, using a modified micrc Snyder column and  gentle  heating
on a water bath.

The  solvent extract was subjected to GC/FID screening and spiked with
10 ul of  the d10-anthracene internal standard solution of 2 ug/ul  for
GC/MS analysis.
                                 229

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                                                       1,1,1 - TRICHLOROETHANE

                                                TRANS - 1,2 - DICHLOROETHYLENE


                                                 1,2-DICHLOROETHANE


                                                        CHLOROFORM
                       BROMOCHLOROM ETHANE
                                                      1,1 - DICHLOROETHANE

                                                      1,1 -DICHLOROETHYLENE
                                          METHYLENE CHLORIDE
                                                                       OJ
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                                       230

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The  presence  of  large  quantities  of  a variety of organics in the
extracts of many of the process waste streams  necessitated  screening
of  all  extracts  by GC/FID prior to GC/MS analysis.   Sample extracts
were diluted as indicated by the GC/FID scan and  subjected  to  GC/MS
analysis.   Reconstructed  total  icn  current  chromatograms for base
neutrals and for phenolic standard are shown in Figures D-2  and  D-3,
respectively.

GC/MS instrument parameters employed for the analysis of base neutrals
and phenolics are presented in Tables D-5 and D-6.
                                  231

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                                   BENZO (G,H,I) PERYLENE
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                        DIBENZO (A.H) ANTHRACENE
                        1NDENO (1,2,3 • C,D) PYRENE;
                                               BENZO(A)PYRENE
           BENZO (A) ANTHRACENE
            CHRYSENE
BIS (2 - ETHYLHEXYL) PHTHYLATE

   BUTYLBENZYLPHTHYLATE —
                                                   BENZIDINE
                                           PYRENE
                                   FLUORANTHENE —
                        01 -N - BUTYLPHTHYLATE
         N - NITROSODIPHENYLAMINE-
                                          PHENANTHRENE
                                 HEXACHLORO8ENZENE
                     DIETHYLPHTHYLATE
                          AZOBENZENE
                                           FLUORENE
                                   DIMETHYLPHTHYLATE
                                  ACENAPHTHENE    ' —
                                         ACENAPHTHYLENE
                                    2 - CHLORONAPHTHALENE
                           HEXACHLOROCYCLOPENTADIENE
         1,2,4 - TRICHLOROBENZENE &

           HEXACHLOROBUTAOIENE
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                      1,2 - DICHLOROBENZENE &
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                                       1,4 - DICHLOROBENZENE

                                       t,3 - DICHLOROBENZENE
                              232
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              PENTACHLOROPHENOL


 2,4-OINITROPHENOL +  4,6 - DINITRO * 0 - CRESOL
                                   D10 - ANTHRACENE
           4 - CHLORO - M - CRESOL
2,4,8 - TRICHLOROPHENOL
                      2,4 - DtCHLOROPHENOL

                               2,4 - DIMETHYLPHENOL
      2 • NITROPHENOL
                                PHENOL
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                               233

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Table D-2-  Parameters for Volatile Organic Analysis
Purge Parameters

Gas
Purge duration
Purge temperature
Sample purge volume
Trap
Desorption temperature
Eesorption time

GC Parameters

Column

Carrier
Program

Separator

MS Parameters

In strument
Mass Range
lonization Mode
lonizatijon Potential
Emission Current
Scan time
He 40 ml/min
12 min
5 ml
Ambient
10 in x 1/8 in o.d. 316 ss and
 0.010 in wall thickness containing
7 in Tenax GC 60/80 mesh plus
2 in Eavison Grade 15 silica gel
35/60 mesh
180
4 min
8 ft x 1/8 in nickel, 0.156 SP-1000
on Carbopack C 80/100
He 30 ml/min
50  isothermal 4 min then 8 /min to
175  isotheriral 10 min
Single-stage glass jet at 185
Hewlett Packard 5985A
35-335 amu
Electron impact
70 eV
210 uA
2 sec
                                 234

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Table D-3.  Base Neutral Extractables
1,3-dichlorobenzene
hexachloroethane
bis(2-chloroisopropyl) ether
1,2,4-trichlorobenzene
bis(2-chloroethyl)  ether
nitrobenzene
2-chlorona phth alene
acenaphthene
fluorene
1,2-diphenylhydrazine
N-nitrosod iphenylamine
U-bromophenyl phenyl ether
anthracene
diethylphthalate
pyrene
benzidine
chrysene
benzo (a) anthracene
benzo (k) fluoranthene
indeno (1,2,3-cd)pyrene
benzo(g h i)perylene
N-nitrosodi-n-propylamine
endrin aldehyde
2,3,7,8-tetrachlorodibenzo-p-dioxin
           phthalate	
1,4-dichlcrobenzene
1,2-dichlcrobenzene
hexachlorctutadiene
naphthalene
hexachlorccyclopentadiene
bis(2-chloroethoxy) methane
acenaphthylene
isophorone
2,6-dinitrctoluene
2 , 4-dinitrotoluene
hexachlorcbenzene
phenanthrene
dimethylphthalate
fluoranthene
di-n-butylphthalate
butyl benzylphthalate
bis (2-ethylhexyl)phthalate
benzo (b) fluoranthene
benzo 
-------
Table D-4.  Acidic Extractables
     2-chlorophenol
     2-nitrophenol
     phenol
     2,4-ditnethylphenol
     2,4-dichlorophenol
     2,4,6-trichlorcphenol
     4-chloro-m-cresol
     2,4-dinitrophenol
     4,6-dinitro-o-cresol
     pentachlorophenol
     4-nitrophenol	
                                 236

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Table D-5,  Parameters for Base Neutral Analysis
GC Parameters

Column


Ca rrier
Program

In jector
Separator
Injection Volume

MS Parameters

Instrument
Mass Range
lonization Mode
lonization Potential
Emission Current
Scan time
6 ft x 2 mm i.d., glass, 1%
SP-2250 on 100/120 mesh
Supelcopcrt
He 30 ml/win
50  isothermal 4 min then 8 /min to
275  for 8 min
285
Single-stage glass jet at 275
2 ul
Hewlett Packard 5985 A
35-400 amu
Electron impact
70 eV
2.10 UA
2.a sec           ___
                                  237

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Table D-6.  Parameters  for  Phenolic Analysis
GC Parameters
Column
Carrier
Program
Injector
Separator
Injection Volume

MS Parameters

Instrument
Mass Range
lonization Mode
lonization Potential
Emission Current
Scan time
6 ft  x  2 mm  i.<3,,  glass,  1%
SP-1240 DA on  100/120 mesh
Supelcopcrt
He 30 ml/irin
90 to 200  at  8  /min with 16  min
hold

250
Single-stage glass  jet at 250
2 ul
Hewlett Packard 5985 A
35-UOO amu
Electron impact
70 eV
210 uA
2.4 sec
                                 238

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The  SP-1240 DA chromatographic phase employed for the analysis of the
phenolic extracts provided superior performance as compared with  that
achieved  on Tenax GC.  The SP-1240 DA phase provided improved separa-
tion, decreased tailing,  decreased  adsorption  of  nitrcphenols  and
pentachlorophenol,   and   increased   column   life.    The  improved
chromatographic performance of this phase is clearly  demonstrated  in
Figure D-3.

PESTICIDES AND PCB1s

Pesticides and PCB's were extracted and analyzed as a separate sample.
These  compounds  were  analyzed  by  gas  chromatograph with electron
capture detection (GC/ECD).  Only when the compounds were  present  at
high levels were the samples subjected to GC/MS confirmation.

GC/ECD  detection  limits  vary  with  the degree of chlorination, but
range from one-half part  per  billicn  for  PCB's  to  50  parts  per
trillion  for  the  chlorinated  pesticides, while the GC/MS detection
limits are in the mid- to low-ppb range.   The  pesticides  and  PCE's
reported  below  2 ppb have been confirmed on two columns using GC/ECD
but not by GC/MS.  Table D-7 presents the GC/ECD  parameters  employed
for the analysis of pesticides and PCB's.

The  procedure  used  for  the  analysis of pesticides and PCB's was a
modification of the procedure from the Federal Register.   Figure  D-4
provides  a flow chart indicating the step-by-step procedure employed.
The major difference  between  the  procedure  used  and  the  Federal
Register  procedure is the substitution of silica gel clean-up for the
Flcrisil clean-up procedure.  Sufficient quality control  was  run  on
standard solutions in order to determine the proper eluticn volume for
the individual pesticides.

The   compounds   of  this  category  are  listed  in  Table  D-8.   A
chromatogram of  selected  representative  compounds  is  provided  in
Figure D-5.

METALS

The  metals  analysis was performed by atomic absorption spectroscopy.
The metals analyzed consisted of the following:
          Beryllium
          Cadmium
          Chromium
          Copper
          Nickel
          Lead
          Zinc
Silver
Arsenic
Ant imony
Selenium
Thallium
Mercury
                                 239

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          FLOW CHART FOR PESTICIDES AND PCB'S
Fraction  I
Containing
   PCB
Figure D-4.
                          Sample Received
                             Adjust pH
                           Measure Volume
                              Serial
                         Solvent Extraction
                           Concentration
                             Silica Gel
                             Separation
    Fraction II
     Containing
TOX,  Chlordane,  DDT
Fraction III
 Containing
 Cyclodienes
                                240

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                     HEPTACHLOR EPOXIDE
                                                               4,4 - DOT
4,4 - ODD
                                           ALDRIN
                                                    HEPTACHLOR


                                                    V-BHC
                           - CO
                                                                                 - 
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Table D-7, GC/ECD Parameters for Pesticide and PCE Analysis	

Instrument                           Hewlett Packard U739A
                                     Radiofrequency Pulsed 63Ni ECD

Column          ,                     6 ft x 2 mm i.d. glass
                                     1.5% OV-17/1.95% QF-1
                                     Confirmation 6% SF-30/4% CV210
                                     On Supelcoport 80/100

Carrier                              5% methane/Argon
                                     50 ml/min

Program	       200 C isotheriral

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Table D-8.   Pesticides and PCB's
     -endosulf an
       -BHC
       -BHC
       -BHC
       -BHC
      aldrin
      heptachlor
      heptachlor epoxide
     -endosulf an
      dieldrin
      a , a « -ODD
      U, 4 « -DDT
      endrin
      endrin aldehyde
      endosulfan sulfate
     -BHC
      chlordane
      toxaphene
      PCB-1016
      PCB-1221
      PCB-1232
      PCB-1242
      PCB-1248
      PCB-125U
      PCB-1260
                                 243

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Excluding the Hg analysis, all  samples  were  worked  up  with  three
successive  digestions  with  concentrated  nitric acid.  Samples were
screened by flame for all metals except Hg.  Samples with levels below
the flame detection limit were re-analyzed  by  graphite  furnace,   A
separate  portion  of  the sample was worked up fcr the Hg analysis by
the cold vapor technique.  The analyses for Be, Tl,  Se,  Sb,  and  Ag
were  not Table D-7.  GC/ECD Parameters for Pesticide and PCB Analysis
performed on the verification samples since the screening data  showed
no significant levels of these metals.

The  metals  analysis  was  characterized  at  times  by severe matrix
problems.  The method of standard additions was normally  adequate  to
compensate for these interferences; however, some analyses such as for
Se, As, and Hg required extensive dilution,

TRADITIONAL OR CLASSICAL PARAMETERS

The traditional parameters investigated included:

          BOD
          COD
          TSS
          Oil and Grease
          Total Phenol
         Total Cyanide

All of these parameters were analyzed by standard methods.

The  colormetric method for cyanide entailed the steam distillation of
cyanide from strongly acidic solution.  The hydrogen cyanide  gas  was
absorbed  in  a  solution  of  sodium  hydroxide,  and  the  color was
developed with addition of pyridine-barbituric acid reagent.
                                 244

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APPENDIX E
CONVERSION TABLE
Multiply (English Units) By
English Unit Abbreviation Conversion
acre
acre-feet
British Thermal
Unit
British Thermal
Unit/ pound

cubic feet
per minute
cubic feet
per second
cubic feet
cubic feet
cubic inches

degree Farenheit
feet
gallon
gallon per
minute
pounds per
square inch
ac
ac ft
BTU
BTU/lb

cfm

cfs

cu ft
cu ft
cu in

F
ft
gal
gpm
psi
* Actual conversion, not
0.405
1233.5
0,252
0.555

0.028

1.7

0.028
28.32
16.39

0.555( F-32)*
0.3048
3.785
0.0631
0.06803
a multiplier
To Obtain (Metric Units)
Abbreviation Metric Unit
ha hectares
cu m cubic meters
kg cal kilogram-
calories
kg cal/kg kilogram
calories
per kilo-
gram.
cu m/min cubic meters
per minute
cu m/min cubic meters
per minute
cu m cubic meters
1 liters
cu cm cubic centi-
meters
C degree
Centigrade
m meters
1 liter
I/sec liters per
second
atm atmospheres
(absolute)

   245

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                               CONVERSION TAEIE



Multiply (English  Units)            Ey           To Obtain




English  Unit    Abbreviation	._C_onversion   Abbreviation
(Metric Units)



   Metric Unit
gallon per ton
horsepower
inches
trillion gallons
per day
pounds per square
inch (gauge)
pounds
board feet
ton
mile
square feet
gal/ton
hp
in
MGD
psi
Ib
b.f.
ton
mi
ft2
* Actual conversion, not a
4.173
0.7457
2.54
3.7 x 10-3
(0.06805 psi + 1)*
0.454
0.0023
0,907
1.609
0.0929
multiplier.
1/kkg
kw
cm
cu m/day
atm
kg
cu m, m3
kkg
km
m2

liters per
metric ton
kilowatts
centimeters
cubic ireters
per day
atmospheres
kilograms
cubic meters
metric ton
kilometer
square meters

irU.S. GOVERNMENT PRINTING OFFICE: 1979 O— 307-176/6665
                                    246

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