DEVELOPMENT DOCUMENT FOR PROPOSED  EFFLUENT LIMITATIONS
GUIDELINES, NEW SOURCE PERFORMANCE  STANDARDS AND PRETREATMENT STANDARDS

                                FOR THE

                      PHARMACEUTICAL MANUFACTURING
                         POINT SOURCE CATEGORY
                             ANNE GORSUCH
                             ADMINISTRATOR
                       FREDERIC A. EIDSNESS, JR.
                        ASSISTANT ADMINISTRATOR
                               FOR WATER
                            STEVEN SCHATZOW
                                DIRECTOR
               OFFICE OF WATER REGULATIONS AND STANDARDS

                            JEFFERY  D.  DENIT
                 DIRECTOR,  EFFLUENT  GUIDELINES  DIVISION

                            DEVEREAUX BARNES
                 ACTING  CHIEF,  ORGANIC  CHEMICALS  BRANCH
                          Frank  H.  Hund,  Ph.D.
                             Daniel  S.  Lent
                           Joseph S. Vital is
                            Project Officers
                             November 1982
                      Effluent  Guidelines  Division
                            Office of Water
                  U.S.  Environmental  Protection  Agency
                         Washington,  D.C.  20460

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                            ABSTRACT
This  document  presents  the  findings  of  a   study   of   the
Pharmaceutical   Manufacturing  Point  Source  Category  for  the
purpose  of  developing  effluent  limitations   guidelines   for
existing  and  new  point  sources  and to establish pretreatment
standards for existing and  new  dischargers  to  publicly  owned
treatment  works  to  implement Sections 301, 304, 306, 307, 308,
and 501 of the Clean  Water  act  (the  Federal  Water  Pollution
Control  Act Amendments of 1972, 33 USC 1251 et. seq., as amended
by the Clean Water Act of 1977, P.L. 95-217  (the
document   was  also  prepared  in  response  to
Agreement in Natural Resources Defense Council,
)).   This
Settlement
v.   Train,
8 ERG 2120 (D.D.C. 1976), modified 12 ERC 1833 (D.D.C. 1979).
The   information  presented  supports  regulations  proposed  in
February 1982,  to  improve  and  restate  standards  (originally
promulgated  in  1976)  for  best  practicable control technology
currently available (BPT) and to institute new source performance
standards (NSPS) and pretreatment standards for new and  existing
sources  (PSNS  and  PSES)  for  the Pharmaceutical Manufacturing
Point Source Category.  The report presents  and  discusses  data
gathering    efforts,    consideration    of   subcategorization,
characterization   of   wastewaters,   selection   of   pollutant
parameters,  review  of  treatment  technology, cost and nonwater
quality considerations and development of regulatory options  and
effluent limitations.

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                        TABLE OF CONTENTS
Section
                    Title
          EXECUTIVE SUMMARY
II
III
IV
VI
A.   Summary and Conclusions
B.   Effluent Standards
C.   Impact of Regulation

INTRODUCTION
A.   Purpose and Legal Authority
B.   Prior EPA Regulations
C.   Scope of this Rulemaking
n.   Definition of the Industry
E.   Summary of Methodology
F.   Data and Information Gathering Program
G.   Processing of Data and Information

DESCRIPTION OF THE INDUSTRY

A.   Introduction
B.   Detailed Industry Profile
C.   Manufacturing Processes
D.   Raw Materials and Products
E.   Current Direct Discharge Performance
F.   Comparison of Current Permits with 1976 BPT

INDUSTRY SUBCATEGORIZATION

A.   Introduction
B.   Basis for Subcategorization
C.   Selected Subcategories
D.   Subcategory Characteristics
E.   Decision Not to Subcategorize for Regulatory
     Purposes

WASTE CHARACTERIZATION

A.   Introduction
B.   Traditional  Pollutants
C.   Priority Pollutants
D.   Wastewater Flow Characteristics
E.   Precision and Accuracy Program

SELECTION OF POLLUTANT PARAMETERS

A.   Introduction
B.   Traditional  Pollutants
C.   Priority Pollutants
Page

   1

   1
   2
   3

   6
   6
   8
   8
   8
  11
  13
  25

  32

  32
  32
  33
  42
  43
  44

  63

  63
  63
  64
  65

  66

  68

  68
  68
  73
  78
  79

  98

  98
  98
 101

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VII
CONTROL  AND  TREATMENT  TECHNOLOGY
                                                                  120
          A.   Introduction
          B.   In-Plant Source Control
          C.   In-Plant Treatment
          D.   End-of-Pipe Treatment           '.
          E.   Ultimate Disposal

VIII      COST, ENERGY, AND NON-WATER OUALITY ASPECTS
                                               i
          A.   Introduction                    ;
          B.   Cost Development                '.
          C.   Analytical Costs for Monitoring:
               Priority Pollutants             ;
          0.   Energy Considerations
          E.   Non-Water Ouality Aspects       !
IX
XI
XII
 XIII
 XIV
          A.   Description of Data
          B.   Definition and Use of  Variability  Factors.
 A.    Summary
 B.    Identification of BPT          \

 BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
 CURRENTLY
 AVAILABLE (BCT)

 A.    Summary
 B.    Identification of BCT

 BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
 (BAT)                               ',

 A.    Summary
 B.    Identification of BAT          ;

 NEW SOURCE PERFORMANCE STANDARDS    ,

• A.    Summary
 B.    Identification of NSPS         ;
           A.    Summary
           B.    Identification  of Pretreatment  Standards
                                                         120
                                                         120
                                                         122
                                                         135
                                                         142
                                                         156
                                                         157

                                                         172
                                                         173
                                                         174
 ANALYSIS OF LONG TERM DATA FOR POLLUTANTS OF CONCERN    232
                                                         232
                                                         236
          BEST PRACTICABLE TECHNOLOGY  CURRENTLY  AVAILABLE  (BPT)    246
                                                                   246
                                                                   247
                                                                   254
                                                                   254
                                                                   254
267

267
268

272

272
272
 PRETREATMEMT STANDARDS FOR NEW AND EXISTING SOURCES     275
                                                         275
                                                         276

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A

B

r
XV        REFERENCES                  ^..^     *>                 280

XVI       ACKNOWLEDGEMENTS                                        294

XVIT      ABBREVIATIONS * SYMBOLS                                 291

XVIII     APPENDICES

          Glossary                                                /\_1

          308 Portfolio for Pharmaceutical Manufacturing          B-l

          Pharmaceutical  Manufacturing Plants in the
          Original  308 Data Base                                  C-l
                                                                    \
     n    Supplemental  308 Portfolio for the Pharmaceutical
          Manufacturing Industry                                  0-1

     E    Pharmaceutical  Manufacturing Plants in the
          Supplemental  308 Data  Base                              E-l

     F    Pharmaceutical  Industry General  Plant  Information
          (308  Data)  and  Probable Future Treatment                 F-l

     G    Screening/Verification Plant Oata                       G-l

     H    Priority  Pollutant  Occurrence  as Reported  in  Original
          30R Portfolio nata                                       H-l

     I     308 Portfolio (Traditional  Pollutant Data)               i-i

     .1     308 Portfolio (Wastewater  Flow Data)                     j_i

     K     RSKERL Data                                              K-l

     L     Current In-Place  Treatment  Technologies                  L-l

     M     Pharmaceutical  Industry Wastewater  Discharge  Methods     M-l

     N     Cost of Treatment and  Control  Systems                    N-l

          N-l  Approach

          N-2  Capital  Cost Indices

    0     Screening/Verification Plant Descriptions                0-1
         and Samples Points                   .

    P    English Units to Metric Units Conversion Table           P-l
                         iii

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                             TABLES            ;

Number                        Title                             Page

II-l      Summary of 308 Portfolio Mailing     ,                   27

II-?.      Characteristics of the 26 Plants Selected
          for Screening                        ,    .   .            28

II-3      Characteristics of the 5 Plants Selected
          for Verification                                        29

II-4      Characteristics of Plants Selected for
          Long Term Study                      !        '           ^

II-5      Comparison of Characteristics of Screening  and
          Long Term Plants with Those of the Total Pharma-
          ceutical Manufacturing Population                       31

III-l     Pharmaceutical Industry Geographical Distribution       45

III-?.     Subcategory Breakdown                                   48

III-3     Production Operation Breakdown                          49

III-4     Direct Dischargers: Comparison of Plant  Per-
          formance vs. 1976 BPT Percent Removal Design
          Criteria                      •       ;   •                50

111-5     Direct Dischargers: Comparison of Dlant  Performance
          vs. Proposed BCT and BAT Concentration  Design

III-6     Ranking of Direct Dischargers by Effluent
          BOD Concentration                    [       '            54

III-7     Ranking of Direct Dischargers by Effluent
          COD Concentration                                       56
                                               i •

III-8     Ranking of Direct Dischargers by Effluent
          TSS Concentration                    ;                   57

III-9     Ranking of Direct Dischargers by BOn:
          Percent Removal                      '                   59

111-10    Ranking of Direct Dischargers by COD
          Percent Removal                                         60

III-ll    Comparison of  Current Permits with  1976 BPT            61

V-l       Summary of Long Term Data            ;                   81
                                IV

-------An error occurred while trying to OCR this image.

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VTt-2
Estimated Achievable Long-Term Average Effluent

Vt I -3
VII-4
VTII-1
VIII-?,
VIII-3
VIII-A
vm-5
VIII-6
VIII-7
VIII-8
vin-9
viii-in
VIII-11
VIII-12
VIII-13
VIII-14
VIII-15

Concentrations for the Priority Pollutant Metals
Summary of End-of-Pipe Treatment Processes
Summary of Wastewater Discharges
Raw Waste Loads for Subcategory Rase Cases:
Traditional Pollutants
Typical Priority Pollutant Concentrations
Used for Base Case In-Plant Costs
Cyanide Destruction: Equipment Cost Rases and
Energy Requirements
Cyanide Destruction: Capital Costs
Cyanide Destruction: Total Annual Costs
Variation with Flow
Cyanide Destruction: Total Annual Costs
Variation with Influent CN Concentration
Chromium Reduction: Equipment Cost Rases
and Energy Requirements
Chromium Reduction: Capital Costs
Chromium Reduction: Total Annual Costs
Variation with Flow
Chromium Reduction: Total Annual Costs Variation
with Influent Concentration
Chromium Reduction: Total Annual Costs
Variation with Effluent Concentration
Metal Precipitation: Equipment Cost Rases
and Energy Requirements
Metal Precipitation: Capital Costs
Metal Precipitation: Total Annual Costs
Variation with Flow
Metal Precipitation: Total Annual Costs
Variation with Influent Concentration
vi
144
145
146
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191


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VII1-16   Metal Precipitation: Total Annual Costs
          Variation with Effluent Concentration                  192

VIII-17   Steam Stripping Cost Data                              193
              i
VIII-18   Activated Sludge System: Equipment Cost Bases
          and Energy Requirements                                194

VII1-19   Activated Sludge System: Capital Costs                 195

VII1-20   Activated Sludge System: Total Annual Costs            196

VIII-21   Rotating Biological Contactor  (RBC) System: Equip-
          ment Costs Bases and Energy Requirements               197

VIII-22   Rotating Biological Contactor  (RBC) System: Capital
          and Total Annual Costs                                 198

VIII-23   Polishing Pond: Cost Bases                             199

VIII-24   Polishing Pond: Capital and Total Annual
          Costs                                                  200

VII1-25   Activated Sludge System with Filtration:  Equip-
          ment Costs Bases and Energy Requirements               201

VIII-26   Activated Sludge System with Filtration:
          Capital  Costs                                          202

VIII-27   Activated Sludge system with Filtration:  Total
          Annual Costs                                           203

VIII-28   Rotating Biological Contactor  (RBC) System  with
          Filtration: Equipment  Costs Bases and
          Energy Requirements                                    204

VIII-29   Rotating Biological Contactor  System with
          Filtration: Capital and Total  Annual Costs             205

VII1-30   Wastewater Hauling/Treatment Costs                     206

VIII-31   Analytical Costs for Monitoring  Priority
          Pollutants                                             207

IX-1      Plant  Identifiers  and  Subcategories  in  Pharma-
          ceutical Long  Term Data Base                           242

IX-2      Daily  Variability  Factors                              243

IX-3      30-Day Variability Factors                              244
                                VTI

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IX-4      Long Term Average Concentrations, Variability
          Factors, and Limitations                               245

X-l       BPT Limitations                                        247

X-2       Effluent TSS Performance of Direct Dischargers
          (308 and Long-Term Data)            ;                   252

X-3       Subcategory Breakdown of TSS Group Plants Compared
          to all Direct Dischargers                              253
                                              i
XI-1      BCT Limitations                     ;                   254

XI-2      Incremental BPT and BCT Annual Costs and Removals      265

XI-3      BCT Cost Test Criteria                                 266

XII-1     BAT Limitations                                        267

XIII-1    New Source Performance Standards                       272

XIV-1     Pretreatment Standards for New and Existing
          Sources                             :                   275

XIV-2     Comparison of POTW and Direct Discharger
          Removal Rates for Solvents                             279
                              vi i i

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                             FIGURES
Number                        Title

III-l     Geographic nistribution

VII-1     Cyanide Destruction System - ChTorination

VII-2     Cyanide Destruction System - Alkaline
          Hydrolysis

Vll-3     Chromium Reduction System

VII-4     Metals Removal System Alkaline Precipitation

VII-5     Steam Stripping Unit

Vll-fi     Activated Carbon Adsorption Unit

VII-7     Examples of Augmented Biological  Systems

VII-8     Typical Clarifier Configurations

VII-9     Filtration Unit

VII1-1    Activated Sludge Annual  Treatment"Cost  vs.
          Wastewater Flow

VIII-?.    Activated Sludge With Supplemental Treatment.
          Annual Treatment Cost vs.  Wastewater Flow

VII1-3    RBC  System Annual Treatment Cost  vs.
          Wastewater Flow

VIH-/1    RBC  System With  Supplemental  Treatment.  Annual
          Treatment Cost vs. Wastewater Flow

VII1-5    Polishing Pond Annual Treatment  Cost vs.  Waste-
          water  Flow

VIII-6    Cyanide Destruction  Annual  Treatment Cost vs.
          Wastewater Flow

VIII-7    Cyanide Destruction  Annual  Treatment Cost vs.
          Influent  CN Concentration

VIII-8    Cyanide Destruction  Unit Treatment Cost vs.
          Wastewater Flow
Page

  62

 147


 148

 149

 150

 151

 152

 153

 154

 155


 208


 209


 210


 211


 212


 213


 214


 215
                                IX

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 VIII-9    Cyanide Destruction Unit Treatment Cost vs.
           Influent CN Concentration

 VIII-in   Chromium Reduction Annual Treatment Cost vs.
           Wastewater Flow

 VIII-11   Chromium Reduction Unit Treatment Cost vs.
           Wastewater Flow

 VII1-12   Chromium Reduction Annual Treatment Cost vs.
           Influent Cr Concentration

 VII1-13   Chromium Reduction Unit Treatment Cost vs.
           Influent Cr Concentration            '

 VII1-14   Chromium Reduction Annual Treatment Cost vs.
           Effluent Cr Concentration

 VIII-15   Chromium Reduction Unit Treatment Cost vs.
           Effluent Cr Concentration

 VIII-16   Metals  Precipitation  Annual  Treatment Cost vs.
           Wastewater Flow

 VIII-17   Metals  Precipitation  Unit Treatment Cost vs.
           Wastewater Flow

 VIII-18   Metals  Precipitation  Annual  Treatment Cost vs.
           Influent Metals Concentration

 VIII-19   Metals  Precipitation  Unit Treatment Cost vs.
           Influent Concentration

 VIII-20    Metals  Precipitation  Annual  Treatment  Cost  vs.
           Effluent Metals  Concentration

 VIII-21    Metals  Precipitation  Unit  Treatment  Cost  vs..
           Effluent Metals  Concentration

VII1-22    Steam Stripping  Annual  Cost  vs. Flow  Rate  and
           Steam Cost

VIII-23    Steam Stripping  Unit Cost vs. Flow  Rate  and
           Steam Cost

VIII-24   Wastewater Hauling Costs vs. Wastewater  Flow
 216


 217


 218


 219


 220


 221


 222


 223


 224


 225


 226


 227


 22R


 229


230

231

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                            SECTION I

                        EXECUTIVE SUMMARY
A.  SUMMARY AND CONCLUSION

This  document  presents  the  technical data to support effluent
limitations for the  pharmaceutical  manufacturing  point  source
category as required by the Clean Water Act (The Act) and related
settlement  agreements.   It  also  presents  the technologies to
achieve limitations as defined by  an  amended  best  practicable
control  technology  currently  available  (BPT),  best available
technology economically achievable (BAT)  and  best  conventional
pollutant  control  technology (BCT), and standards as defined by
new  source  performance  standards  (NSPS),   and   pretreatment
standards for new and existing sources (PSNS and PSES).

The  focus  of  the  effort  in  developing these limitations and
standards was a complex development  program  utilizing  industry
data  obtained  under  Section  308  of ' the Act, supplemented by
additional data collection programs for selected portions of  the
industry.

The    pharmaceutical   manufacturing   point   source   category
manufactureres   biological   products,   medicinal    chemicals,
botanical   products   and  pharmaceutical  products  covered  by
Standard Industrial Classification Code (SIC) Numbers 2831, 2833,
and 2834, and other commodities described within this report.

The industry is characterized by diversity of  product,  process,
plant  size,  and process stream complexity.  Subcategories based
on process characteristics were defined for purposes of technical
evaluation.  Although these subcategories  were  also  considered
for  regulatory  purposes,  such  separation  was not found to be
appropriate for this industry.  This is largely  because  of  the
predominance,   particularly   among  larger  plants,  of  multi-
subcategory operations as  well  as  the  diversity  within  each
defined subcategory.

Sections III through VIII of this document describe the technical
data  and  engineering  analyses  used  to develop the regulatory
technology options.  The rationales by which the Agency  selected
the   technology  options  for  each  of  the  proposed  effluent
limitations are presented in Sections X  through  XIV.   Effluent
limitations  guidelines  based on the application of BPT, BAT and
BCT are  to  be  achieved  by  direct  dischargers.   New  source
performance standards  (NSPS) based on best available demonstrated

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technology  are  to  be achieved by new facilities.  Pretreatment
standards for both existing sources (PSES) and new sources  (PSNS)
are to be achieved by indirect dischargers for  those  pollutants
which  are incompatible with or not susceptible to treatment  in a
publicly  owned   treatment   works    (POTW).    These   effluent
limitations  and standards are required by Sections 301, 304, and
307 of the Clean Water Act of 1977 (P.L. 95-217).

B.  EFFLUENT LIMITATIONS GUIDELINES

1.   BPT Limitations

Proposed BPT limitations* are summarized below:
Parameter

TSS (mg/1)
Cyanide (»»g/l)
   Maximum
30-Day Average

     217
     375
 Daily
Maximum
  643
The  existing  BPT  limitations  for  BODS, • COD  and  pH  remain
unchanged.    However,   alternative   30-day   average   maximum
concentrations are proposed for BODS and COD so that the existing
BPT limitations may not, in some cases, be  more  stringent  than
the   BCT   and   BAT   concentration  limitations.   The  30-day
concentration limitations are equal to the proposed BODS and  COD
limitations for BCT and BAT.  In all cases, the less stringent of
the limitations will apply.  The existing TSS limitations,  which
apply  to   3  out  of 5 subcategories, will be replaced by a new
less Stringent TSS limitation" applicable to all 5 subcategories.

2.   BAT limitations
Proposed BAT limitations are summarized below:


Parameter
   Maximum
30-Day Average
 Daily
Maximum
COD (mg/1)
Cyanide (//g/1)
     570
     375
 1024
  643
3.   BCT limitations

Proposed BCT limitations are summarized below:
Parameter

BOD (mg/1)
TSS (mg/1)
   Maximum
30-Day Average

     113
     110
 Daily
Maximum

  252
  291

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4.   NSPS limitations

Proposed NSPS limitations are summarized below:
Parameter

BODS (mg/1)
COD (mg/1)
TSS (mg/1)
Cyanide (i>g/l)
   Maximum
30-Day Average

      51
     449
      72
     375
                                              Daily
                                             Maximum

                                               126
                                               853
                                               195
                                               643
5.   PSES and PSNS

Proposed PSES and PSNS are summarized below:

Parameter                 30 Day Average
                             Maximum

                               375
                    Daily
                   Maximum

                     643
Cyanide (ug/1)

C.   IMPACT OF REGULATION                      ,

1.   BPT Regulation

Proposed BPT effluent limitations for cyanide  will  prevent  the
discharge  of  17,000  Ibs of cyanide per year to surface waters.
The total annual and investment costs that may  be  incurred  are
estimated to be $628,000 and $1,740,000, respectively.  Increases
in  energy consumption costs as a result of these limitations are
expected to be negligible when compared with the other wastewater
treatment  energy  costs  of  this  proposed   regulation.    The
information  used  to  develop these estimates was taken from 308
survey and sampling program results.

No overall decrease in the discharge of  TSS  is  expected  as  a
result  of the revised BPT TSS limitations.  Although limitations
are being established for the first time for subcategory A and  C
plants,  any  reduction  of TSS achieved by these plants would be
offset by the relaxation of the TSS limitations  for  subcategory
B,  D, and E plants.  No implementation costs are attributable to
this revised limitation because the costs are either attributable
to compliance with the current BPT BOD5 and  COD  limitations  or
are   ..not  necessary  because  this  limitation  can  be  met  by
improvements in treatment system operation.

2.   BCT Regulations

Proposed BCT effluent limitations will reduce  the  discharge  of
BOD5.  by  an  estimated  6,500  Ibs/day (1200 tons/yr) and TSS by

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 4,425  Ibs/day  (807  tons/yr).    These   values   are  based  on   the
 available  data for  direct  discharges  as  reported  in 308  responses
 and  long term  daily data submissions  with  adjustment estimates to
 reflect  all   industry  direct   dischargers.    Incremental sludge
 generation due to the proposed  limitations  is estimated   to   be
 6395  Ibs/day   (1167 tons/yr).    Sludge estimates  are based on a
 ratio  of sludge to  BOD  removal  of  0.3 and  a sludge  to TSS  removal
 ratio  of 1.0.
 Costs  to implement  BCT  were estimated on a conservative  basis   at
 $7.72  million  for total  annual  costs  and $19.4 million  for
 investment costs (1980  dollars).   These  costs  are  likely   to   be
 somewhat   overstated in   that   they  do  not reflect site-specific
 opportunities   for   modification  (as opposed to    adding   new
 treatment  units.

 The  incremental  energy   cost   impact  of , the   proposed   BCT is
 approximately  $900,000  per year  for   about  22   M   M KWH/yr   of
 electricity.   This  power can be  generated  by approximately 37,000
 BBL  of  fuel   oil.  This  energy cost when added  to the  estimated
 $2.2 M M (for   56   M M KWH/yr)   currently  being   expended   for
 wastewater  treatment   energy consumption  results in a new energy
 consumption cost for wastewater  treatment  of $3.1 MM (for 78  M M
 KWH/yr).   Since  the   total  energy   consumption  costs   of   the
 pharmaceutical   industry   are  about   $50  M   M   to  $80 M M,  the
 increment  is less than  2 percent bringing  the  total  energy costs
 devoted  to  wastewater treatment  to about 4-6  percent of  the
 industry total.

 3.   BAT Regulation

 Proposed  BAT   regulations  will   prevent   the    discharge    of
 approximately   4.4 million pounds per  year of  COD (beyond  what  is
 removed by the  BPT regulation) to the  nation's   surface   waters.
 There   are   no   costs   for   incremental  energy   requirements
 attributable to this regulation.

 4.   PSES and PSNS Regulations

Proposed  pretreatment  standards  for   existing  sources   (PSES)
control  the discharge  of cyanide to POTWs.  It is  estimated that
these standards will prevent the discharge of  5900  Ibs  per  year
of  cyanide  to  the Nation's POTWs.   Total annual  and investment
costs that may  be incurred in complying  with these  standards  are
$323,000  and   $880,000, respectively.   Energy use  increases as a
result of these standards are  expected  to  be   negligible  when
compared with the total energy use of  the  industry.

5.   NSPS Regulation

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The NSPS standards will require the  average  new  source  direct
discharger  to  reduce  its  discharge  of  BOD5,  TSS and COD by
30,000, 15,000 and 83,000 pounds  per  year,  respectively,  more
than   that   required  of  an  average  existing  source  direct
discharger.  The average  annual  costs  for  a  new  source  are
expected  to be 38% above those incurred by a existing source and
sludge  generation  is  expected  to  be  18%   higher.    5n
consumption costs for wastewater treatment are expected to be
higher than those for an average existing source.

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                            SECTION II

                           INTRODUCTION

 A-  PURPOSE AND LEGAL AUTHORITY            '! "

 The  Federal  Water  Pollution  Control  Act  Amendments  of 1972
 established a comprehensive program to restore and  maintain  the
 chemical,  physical,  and  biological  integrity  of the Nation's
 waters [  Section 101(a) ].  By July 1, 1977, existing  industrial
 direct  dischargers were required to achieve effluent limitations
 requiring  the  application  of  the  best  practicable   control
 technology  currently  available  (BPT) [  Section 301(b)(1)(A)  ].
 By July 1, 1983,  these  dischargers  were  required  to  achieve
 effluent   limitations  requiring  the  application  of  the  best
 available technology economically  achievable  (BAT)  which  will
 result in reasonable further progress toward the national  goal  of
 eliminating   the   discharge   of   all    pollutants  [  Section
 301(b)(2)(A)  J.   New industrial direct dischargers were  required
 !rS™?mPly  with  Section  306  new  source performance standards
 (NSPS) based on  best available demonstrated technology.   New and
 existing   dischargers  to  publicly  owned treatment works  (POTW)
 were  subject  to  pretreatment standards under Sections 307(b)  and
 (c)   of the Act.   The requirements for direct dischargers were  to
 be incorporated  into  National  Pollutant   Discharge  Elimination
 System  (NPDES)   permits  issued  under Section  402 of the Act.
 Pretreatment  standards were   made  enforceable  directly against
 dischargers to POTWs (indirect dischargers).

 Although   Section  402(a)U)   of  the   1972  Act authorized  local
 authorities to set  requirements for direct dischargers  on a  case-
 by-case basis, Congress  intended that  for  the most  part control
 requirements  would  be  based  on regulations promulgated  by the EPA
 Administrator.    Section    304(b)   of   the Act  required  the
 Administrator to  promulgate   regulatory   guidelines for  direct
 discharger  effluent  limitations  setting  forth   the   degree  of
 effluent  reduction  attainable  through   the  application  of   best
 practicable   control    technology    (BPT)    and   best   available
 technology  economically  achievable   (BAT).  ,  Moreover,  Sections
 304(c)  and  306  of the Act required promulgation of regulations
 for NSPS,   and  Sections   304(f),  307(b),   and  307(c)  required
 promulgation  of  regulations   for  pretreatment   standards.    In
 addition  to these regulations  for designated  industry categories,
 Section   307(a)  of  the  Act   required  the   Administrator    to
promulgate  effluent  standards  applicable  to all  dischargers of
 toxic pollutants.  Finally, Section 501(a) of  the  Act  authorized
 the   Administrator   to  prescribe  any   additional  regulations
necessary to carry out his or  her functions under  the Act.

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The EPA was unable to promulgate many of these regulations by the
dates contained in the Act.  In 1976  EPA  was  sued  by  several
environmental  groups; in settlement of this  lawsuit, EPA and the
plaintiffs executed a settlement agreement, which was approved by
the Court.  This agreement required EPA to develop a program  and
adhere to a schedule for promulgating for 21  major industries BAT
effluent  limitations guidelines, pretreatment standards, and new
source  performance  standards  for  65  "toxic"  pollutants  and
classes of pollutants.   (40)

On  December   27,  1977,  the President signed into  law  the Clean
Water Act of  1977.  Although this   law = makes several   important
Changes   in the federal  water pollution control program,  its most
significant feature is its incorporating into the Act several  ot
the  basic elements of the settlement agreement program  for toxic
pollution control.  Sections 301(b)(2)(A) and 301(b)(2)(O of the
Act now require the achievement by  July  1,  1984,  of   effluent
limitations   requiring   application of BAT  for toxic pollutants,
including the 65 priority pollutants and  classes  of  pollutants
which  Congress  declared  toxic  under Section 307(a) of the Act.
Likewise, EPA's programs for new  source performance  standards and
pretreatment   standards  are  now  aimed  principally  at   toxic
pollutant  controls.   Moreover,  to strengthen the toxics control
program,  Congress  added  Section  304(e) to   the  Act,  authorizing
the  Administrator to prescribe  best management  practices  (BMPs)
to prevent the release of  toxic   and  hazardous   pollutants   from
plant  site   runoff,  spillage or  leaks, sludge or waste  disposal,
and  drainage  from   raw  material  storage  associated   with   or
ancillary to  the manufacturing  or treatment process.

 In  keeping with its emphasis  on toxic pollutants,  the Clean Water
Act  of   1977' also revised the  control program  for   conventional
pollutants   (including   biochemical  oxygen   demand,    suspended
 solids,   fecal col iform, oil  and grease,  and PH)  identified under
 Section  304(a)(4).  Instead of  BAT for   conventional  pollutants,
' the new  Section 301(b)(2)(E)  requires by  July 1,  1984 achievement
 of   effluent  limitations  requiring   the application of the best
 conventional pollutant control   technology   (BCT).    The  factors
 considered  in  assessing  BCT  include  the reasonableness of the
 relationship between   the  costs  of   attaining  a  reduction  in
 effluents  and  the  effluent reduction  benefits derived, and the
 comparison of the cost and level of reduction for  an  industrial
 discharge  with  the  cost  and  level  of  rfduction  of similar
 parameters  for  a  typical  POTW  [Section  304(b)  4)  B) •   For
 nontoxic,  nonconventional  pollutants,  Sections 301(bH^HJ) and
 301(b)(2)(F) require  achievement  of  BAT  effluent  limitations
 within  three  years  after  their establishment or after July 1,
 1984 (whichever is later), but not later than July 1, 1987.
                                7 .

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 This document presents the technical bases for the application of
 revised BPT, and new BAT, BCT, new source  performance  standards
 (NSPS),  pretreatment  standards for existing sources (PSES), and
 pretreatment  standards  for   new   sources   (PSNS)   for   the
 pharmaceutical manufacturing point source category.

 B.  PRIOR EPA REGULATIONS

 On  November  17,  1976,   the  EPA  promulgated interim final BPT
 regulations for the  pharmaceutical  manufacturing  point  source
 category  at 41 Federal Register 50676, 40.CFR Part 439, Subparts
 A-E. (27).  The BPT regulations set monthly limitations for  BODS
 and  COD  based  on  percent  removals for'all subcategories.  No
 daily maximums were established for these two parameters.   The pH
 was set as within the range of 6.0 to 9.0 ;standard  units.   The
 rulemaking  also  set  an  average  of  daily  TSS values for any
 calendar month for subcategories B, D,  and!E.   No TSS limits were
 established for categories A  and  C.    Subpart  A  (the  section
 applicable   to  the  fermentation  operations  subcategory)  was
 amended on February 4,  1977 (42 FR 6814),  to improve the language
 referring to separable mycelia and solvent recovery and  to  allow
 the  inclusion  of spent  beers (broths) in the calculation of raw
 waste loads for subcategory A in those instances  where the  spent
 beer  is  actually  treated  in  the wastewater treatment  system.
 These regulations were never  challenged  and   are  presently  in
 effect.    The  technical  basis for these regulations was provided
 in EPA 440/1-75/060,  published in December  1976.    This  report,
 which  formed  the technical  basis for  BPT is  henceforth referred
 to as the 1976  Development  Document.  (55)   These  BPT  regulations
 were never challenged,  and  are still  in effect.

 C.    SCOPE OF THIS RULEMAKING

 In EPA's  initial  rulemaking  (August   1973   thru   November   1976),
 emphasis   was placed   on   the  achievement  of   BPT  based on the
 control of  familiar, primarily conventional pollutants,  such as
 BOD,  TSS  and  pH and non-conventional pollutants,  such  as COD.  By
 contrast,  in  this  round of rulemaking,  EPA's efforts  are directed
 toward  amending existing BPT limitations  and  instituting  BAT and
 BCT  effluent  limitations and  new  source   performance  standards,
 PSES  and  PSNS, with added attention given  to toxic pollutants.

 D.  DEFINITION OF THE INDUSTRY

 The pharmaceutical  manufacturing point  source category is  defined
 as    those   manufacturing  plants  producing  or  utilizing   the
 following products, processes, and activities:

      (1)   Biological products covered by Standard Industrial
Classification (SIC) Code No. 2831.

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      (2)   Medicinal chemicals and botanical products covered by
SIC Code No. 2833.

      (3)   Pharmaceutical products covered by SIC Code No. 2834.

     (4)   All fermentation, biological and  natural  extraction,
chemical synthesis, and formulation products which are considered
as  pharmaceutically  active  ingredients  by  the  Food and Drug
Administration, but which are not covered by SIC Code Nos.  2831,
2833,  or  2834.   (Products of these types which may not contain
pharmaceutically active ingredients will be included if they  are
manufactured  by  processes,  and  result  in  wastewaters, which
closely  correspond  to  those  of  a   pharmaceutical   product.
Examples  of ingredients which fall into this category are citric
acid, benzoic acid, gluconic acid, fumaric acid, and caffeine.)

     (5)   Cosmetic preparations covered by  SIC  Code  No.  2844
which   function  as  a  skin  treatment.   (This  would  exclude
lipsticks, eyeshadows, mascaras, rouges, perfumes,  and  colognes
which  enhance  appearance or provide a pleasing odor, but do not
provide  skin  care.   In  general,  this  would   also   exclude
deodorants, manicure preparations, and shaving preparations which
do not primarily function as a skin treatment.)

     (6)    The portion of a product with multiple end uses which
is attributable to pharmaceutical manufacturing either as a final
pharmaceutical product, component of a pharmaceutical formulation
or a pharmaceutical intermediate.  (Products with  pharmaceutical
and  nonpharmaceutical  end  uses  will be entirely covered under
this point source category  if the products are used primarily  as
Pharmaceuticals.

     (7)    Pharmaceutical research  which  includes  biological,
microbiological,  and  chemical  research,  product  development,
clinical and pilot plant activities.   (This includes animal farms
at which pharmaceutical research is conducted or at  which  phar-
maceutically   active   ingredients are tested on the farm animals.
This does not  include  farms  which  breed,  raise,  and/or  hold
animals  for research at another site.  Also excluded are ordinary
feedlot   or   farm    operations   using   feed   which  contains
pharmaceutically  active    ingredients   since   the   wastewater
generated   from   these  operations   is  not  characteristic  of
pharmaceutical wastewater).
 Products    or    activities    specifically    excluded
 pharmaceutical manufacturing  category  are:
from   the
      (1)   Surgical  and  medical  instruments and apparatus
 by  SIC  Code  No.  3841.
   covered

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      (2)   Orthopedic,  prosthetic,   and  surgical  appliances  and
 supplies  covered by SIC Code No.  3842.
 3843.
 8081.
(3)   Dental equipment and supplies covered by SIC  Code  No.


(4)   Medical laboratories covered by SIC Code No. 8071.

(5)   Dental laboratories covered by SIC Code No.  8072.

(6)   Outpatient care facilities  covered  by  SIC  Code  No.
      (7)   Health and allied services,  not
 covered by SIC Code No.  8091.
                                      elsewhere  classified,
      (8)   Diagnostic devices  not covered by SIC Code No.  3841.

      (9)   Animal   feeds   which   include  pharmaceutically  active
 ingredients  such  as  vitamins  and antibiotics.   (The  major portion
 of   the  product   is  nonpharmaceutical  and the wastewater which
 results from the  manufacture  of  feed   is  not   characteristic   of
 pharmaceutical manufacturing.)

      (10)  Foods and  beverages which are fortified with   vitamins
 or other pharmaceutically active ingredients.   (The  major portion
 of   the  product   is  nonpharmaceutical  and the wastewater which
 results  from the  manufacture   of    these  products    is  not
 characteristic of pharmaceutical manufacturing.)

 In   the  previous regulation based   on  BPT,  the pharmaceutical
 manufacturing point  source category was grouped into five product
 or activity  areas.   This  subcategorization was  based on   distinct
 differences   in manufacturing processes,  raw materials, products,
 and  wastewater characteristics and treatability.  The five sub-
 categories that were selected are:
       (1 )   Subcategory A
       (2)   Subcategory B

       (3)   Subcategory C
       (4)   Subcategory D
       (5)   Subcategory E
                          Fermentation Products.
                          Biological and Natural Extraction
                          Products.
                          Chemical Synthesis Products.
                          Formulation Products.
                          Pharmaceutical Research.
For  the  purposes  of  the  1977-82  study,  EPA  decided to de-
emphasize    pharmaceutical     research     (Subcategory     E).
Pharmaceutical  research  does  not fall within the SIC Code Nos.
2831,  2833, and 2834,  which  were  identified  in  the  Consent
Decree,  and  does  not  appear  to  be a significant part of the
                               10

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industry from the point of view of effluent.  In  addition,  this
activity does not involve production and wastewater generation on
a  regular  basis.   However,  in  cases where the pharmaceutical
research  activity  does  involve  the   production   of   active
ingredients  by processes generating wastewater which are similar
to those in the current study, the information contained  in  the
proposed  development  document may be used by permit writers and
other interested parties.

The subcategory breakdown utilized for the current study was used
for evaluative purposes only.  In terms of  analyzing  raw  waste
characteristics,    wastewater    flow,    treatment   technology
alternatives,   etc.,   a   breakdown   of   the   industry    by
product/process   (i.e.,  subcategories)  was  the most practical.
However,  as   explained   in   more   detail   below,   separate
subcategories   were  not  considered  necessary  for  regulatory
purposes, because   one  set  of  limits  could  be  met  by  all
pharmaceutical  plants.  Therefore, the limitations proposed will
be applicable across the industry  irrespective  of  the  process
source of the waste.

E.  SUMMARY OF METHODOLOGY

As  explained  in more detail in Section II. E EPA first gathered
technical and descriptive data about the industry, from which the
Agency proceeded  to develop the proposed regulations.   EPA  used
four  basic  sources   in  acquiring  data   to  support  these new
regulations.  These sources  included:

      (1)  Data acquired  from  industry  under Section  308  of  the
Act.   Using  this  approach,  308  Portfolio questionnaires were
distributed to a  representative sample of the industry.  This was
followed  by a sampling and verification  program  from  candidate
plants  chosen  from   the  first  group.    This  program used the
analytical  protocol   for  pollutant   detection  and  measurement
developed under section  304(h).

      (2)  Data acquired   through  open  literature, search  using
documents from or relevant to the pharmaceutical  industry.

      (3)  Data acquired  from EPA  regional  offices,   state  and
other government  offices, and pharmaceutical plant visits.

      (4)  The Administrative Record  from the  1976  rulemaking  for
the   pharmaceutical   industry,   including   the   1976  Development
Document.

EPA  then  studied  the pharmaceutical  industry  to  determine  whether
differences  in  such  factors  as   raw   materials,   final   products,
manufacturing    processes,    equipment,    water   use,   wastewater
                                11

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 constituents,  and age and size of  the  manufacturing  facilities
 required  the   development  of  separate effluent limitations and
 standards for  different segments of  the  industry.    This  study
 required  the   identification  of  raw waste and treated effluent
 characteristics,  including:  (1)     the water sources  and  volume
 used,  (2)  the  manufacturing  processes employed,  (3)     the
 location of  pollutant and wastewater  sources  within  the  plant,
 and  (4)    the  wastewater constituents including  toxic pollutants.
 After  tentatively designating subcategories,  EPA then  identified
 the  constituents  of  wastewaters  which should  be considered for
 effluent limitations  and standards.

 Next,  the EPA  identified several distinct control  and  treatment
 technologies,   including  both  in-plant and end-of-process tech-
 nologies,  which currently are in use  or capable  of being used  to
 control   or  treat pharmaceutical industry wastewater.   The Agency
 compiled and analyzed historical and  newly acquired  effluent data
 utilizing  these  various  technologies.    Long-term   performance,
 operational  limitations,  and reliability for each  treatment and
 control  technology were also considered and statistical   analyses
 of   long  term  data   performed   in  order  to derive performance
 standards  and  variability   factors.    Additionally,    the   EPA
 evaluated    the   non-water    environmental   impact   of   these
 technologies on air quality,  solid  waste generation,   and  energy
 requirements.

 The  EPA  developed base cases representative  of  each  subcategory
 (based   on  waste  load  characteristics)   to  derive    treatment
 processes  and  capital  and operating  costs  for  each  technology.
 These costs  were  presented as curve functions  of waste  loading
 and   flow.     The technologies evaluated  included   biological
 end-of-pipe  processes  (e.g.,  biological  enhancement),  as well   as
 in-plant   priority pollutant treatments (cyanide destruction and
 steam stripping).   The  annual   unit   costs   (including  capital
 amortization)   were  totaled at  varying  flows  and waste  loads  for
 each of  the  four  subcategories.   The  agency then evaluated  the
 economic  impact of these costs on the  industry as a  whole.   Costs
 and economic impacts  are discussed more  fully  in  "Economic  Impact
 Analysis   of Proposed  Effluent Limitations  Guidelines, New  Source
 Performance  Standards   and   Pretreatment   Standards    for    the
 Pharmaceutical  Manufacturing Point Source  Category."

EPA identified  various  control and treatment technologies as BPT,
BAT,   BCT,  NSPS,   PSES,  and PSNS.   The  proposed regulations,
however, do  not   require  the  installation   of   any  particular
 technology.     Rather,    they require   achievement  of   effluent
 limitations representative of  the  proper   application   of   these
technologies    or   equivalent   technologies.   A pharmaceutical
plant's existing  controls should be fully  evaluated, and  existing
                               12

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treatment systems fully optimized before commitment to any new or
additional end-of-pipe treatment technology.

F.  DATA AND INFORMATION GATHERING PROGRAM

EPA used a  number  of  sources  in  acquiring  data  to  support
regulations  for  the  pharmaceutical  manufacturing point source
category.  These sources are identified and  discussed  below  in
the 9 following subsections?

(1)  Preliminary  data  was  obtained  from  the   five   sources
described  below.   This information was used to direct the other
data gathering efforts.

(a)  Data acquired from 22 plants which served as the  supportive
data base for the BPT regulations issued in November, 1976.
 (b)  Data  acquired  from  PEDCo,
 (discussed in Section V).
RTP  and  RSKERL/Ada   studies
 (c)  Information acquired through an open literature search.    (A
major  portion  of this effort has been performed by The Research
Corporation  of  New  England  (TRC).   Some  of  the   important
 literature sources were  documents prepared by the Pharmaceutical
Manufacturers  Association  (PMA); the Executive Directory  of U_^.
Pharmaceutical  Industry,   Third  Edition,   Chemical   Economics
Services,Princeton,  New  Jersey;   (51)  and  the  Directory  of
Chemical  Producers  -  U.S.A.,  Medicinals,  Stanford   Research
 Institute, Menlo Park, California.  (50))

 (d)  Data acquired from EPA regional  offices,  state   and other
 government offices, and pharmaceutical plant visits.

 (e)  The  administrative  record    relating   to   previous   EPA
 regulations   included  the  original  Development  Document  (EPA-
 440/1-75/060, December 1976) and its  appendices.  This  record was
 very useful  in obtaining general information on the pharmacutical
 manufacturing  industry.    We  reviewed   this   document   for
 information   on   use   or   suspected  presence  of   toxic  and
 nonconventional   pollutants,   applicable   production   process
 controls,  and  available   effluent  treatment  techniques.   The
 administrative record also  included the original economic   impact
 analysis documents.

 (2)  Data acquired from  the industry under  Section   308   of  the
 Act.    (This approach   included   (a)  the  distribution   of  308
 Portfolios   to  members  of the   industry  population  which   we
 identified   and  (b) wastewater sampling of  candidate  plants  which
 were selected  in  accordance  with  the   criteria  discussed   in
                                13

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 Section   V.)     The   objectives   of
 Pharmaceutical Manufacturing were:
    the  308  Portfolio  for
 (1)    To obtain information for the
 hensive industry profile.
construction  of  a  compre-
 (2)    To obtain information on production,  wastewater generation,
 and   wastewater  treatment  at  existing facilities to expand the
 data base for guidelines development.
 (3)    To ascertain industry-specific problems which
 considered in guidelines development.
                need  to  be
 (4)   To develop a list of candidate plants for priority pollutant
 sampling.                                   ;

 The   308  request  also  was used to solicit information from the
 industry which it felt  would  be  relevant  to  this  rulemaking
 effort   and  to  develop  individual  plant  contacts  to lay the
 foundations for future inquiry.

 The  308 Portfolio for  Pharmaceutical Manufacturing   presented  in
 Appendix  B,   was  developed  by  EPA and  Burns and  Roe  Industrial
 Service Corp.   (BRISC)   with  the   cooperation   of   the    PMA
 Environmental   Task Force  during the spring and summer of  1977.
 During   the  same  period,   a  distribution  mailing   list    was
 formulated.    The  308 Portfolios initially were sent only to PMA
 member  firms  and to nonmember plants  included  in   previous  EPA
 guidelines work.    This  decision  was  based  on   the following
 assumptions and facts:

 (1)   PMA  members were considered more likely to provide quality
 responses  to  the 308 Portfolio.

 (2)     Development and distribution  of the 308 Portfolio could in
 part be assisted and coordinated  by  the PMA.

 (3)   Many of  the essential  contacts had  already been established
 with the PMA.
                                            i               '  "
 (4)   The  Agency felt  that the  308 Portfolio  need  cover only a
 statistically   representative  sample of  pharmaceutical  plants in
 the United States.  The  PMA  has members which   range  from   small
 one-plant  firms  to  firms with as  many as  25 plants,  some of  which
 are   large   manufacturing   complexes.    The  PMA  members   are
principally  manufacturers    of   prescription   Pharmaceuticals,
medical devices,  and diagnostics.  However, PMA member  firms  also
produce  a significant  portion  of  the over-the-counter  drugs on
 the market.  These members account for  approximately   90  to  95
percent  of  the  U.S.  sales of prescription products  and  about 50
                               14

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percent  of  the   free   world's   total   output   of   ethical
Pharmaceuticals.   For  the purpose of the 308 Portfolio, the PMA
member   firms   were   judged   to   provide   a   statistically
representative distribution.

The  PMA  List  of  Administrative  Officers  of the Member Firms
Associates, October  1976  Edition,  which  contains  130  member
firms, was used as a basis for the mailing list.  Many of the 130
members  are  subsidiaries  or divisions of common member or non-
member parent firms.  Table  II-l  summarizes  the  Original  308
Portfolio  distribution and response.  Of the 442 portfolios that
were mailed in  1977, a total of 431 were returned.   One  hundred
five   of   these  were  from  nonpharmaceutical/nonmanufacturing
plants, while   another  50  were  duplicates  of  plants  already
covered.   For  purposes  of  this  study,  EPA decide to exclude
exclusively Subcategory E plant as  explained  earlier.   The  32
plants  that  had only Subcategory E operations were dropped from
the survey.  Thus, a total of  244  pharmaceutical  manufacturing
plants  are  presently  included  in  the original 308 data base.
They are listed in Appendix C.

(3)  Supplemental 308 Portfolio

Since   1977,   EPA  has  identified  more  than  500   additional
facilities   that  may  be  part  of  this  industry.    The  open
literature file developed  by  TRC  identified  a  total  of  990
possible  pharmaceutical  sites   in  the United States.  The data
file was reviewed by BRISC and  PEDCo,  an  EPA  contractor  with
process  design and construction  experience in the pharmaceutical
industry.  This led to a revised  listing of more than  540  plant
sites  of  approximately 400 companies which were not  included in
the original 308 Portfolio distribution, but which were  possible
producers of pharmaceutically active ingredients.

Although  EPA knew that this segment of the industry  (principally
comprised of non-PMA-member companies) accounts for only a  small
fraction of sales  (5-10 percent), the total wastewater volume was
unknown.   The  Agency  also expected that these plants  are small
producers upon  whom new regulations could have  a  major  impact.
In  an  effort  to  define  the  entire pharmaceutical  population,
obtain a more complete profile of the industry, and   confirm  the
assumption  that   the  PMA  member  firms  included in  the  initial
survey do  indeed   represent  the   industry,   a  Supplemental  308
Portfolio  for  Pharmaceutical Manufacturing  was developed during
the fall of 1978.  This questionnaire, presented  in   Appendix  D,
is  an  abbreviated  form   of  the original 308 Portfolio  and was
distributed to  540 possible pharmaceutical sites  in   April   1979.
Table  II-l  presents  a summary  of the Supplemental  308  Portfolio
distribution program.  Of the  540 supplemental  portfolios,  355
were     returned.      After      accounting    for     the     128
                                15

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 nonpharmaceutical/nonmanufacturing    plants,      4      duplicate
 portfolios,   and  3  Subcategory  E-only  plants,  220 plants were
 identified as pharmaceutical  manufacturers.   They  are  listed  in
 Appendix  E.

 The   end   result  of  the   two  questionnaire mailings  was  a
 comprehensive pharmaceutical  industry  data  base   containing  464
 manufacturing  plants.   Throughout later sections  of  this report,
 references to 308  Portfolio data are to   the  comprehensive  data
 base  of   464  plants.    Table   II-l   summarizes distribution and
 response  return counts for the  entire  308 Portfolio program.

 There  are some differences in the information  requested by  first
 and second 308 questionnaires.   Both versions  contained a general
 information  section requesting  company name,  number of employees,
 etc.    The  original   308  requested   information  on  research and
 development  facilities which  was dropped  from the   supplemental
 form.   Products  manufactured   and method   of production  were
 covered by both the original  and supplemental  portfolios.

 The most  significant  difference between  the  two mailings  was  in
 the wastewater data  section.   The original  308 was very detailed
 in  this area.   Water  source,  water use,   wastewater   source   and
 wastewater  disposal   information  was  requested.    The original
 questionnaire  contained  questions concerning   solid   wastes,
 changes  in  treatment operation,  and operating costs  all of which
 were dropped from  the Supplemental 308.   In  the supplemental  form
 wastewater data was requested only if  end-of-pipe  treatment   was
 practiced.    Both   forms of the portfolio requested data relating
 to  priority  pollutant occurrence in raw  materials  and wastewater.
 The supplemental portfolio was  shortened because the  second group
 of  plants    to whom this portfolio was sent were considered to be
 smaller and  less complex on average and  to have   less  data   and
 response resources.

 (4)  Plant Visits  and Direct  Contacts

 During  the  screening/verification phase of this project,  we  also
 gathered   information  on  production    capacity,   manufacturing
 process,  waste  flows, water reuse, wastewater treatment  systems
 and performance, and  best management practices  (BMP).   The visits
 also provided  an opportunity  to  update  and  clarify   information
 from the 308 Portfolio  responses.

An  additional  plant visit was  made to  a  selected pharmaceutical
manufacturing  site  for  the purposes of the precision  and accuracy
 (P/A) analysis.  This visit   is   discussed  in  Section  V which
reviews th analytical sampling results.
                               16

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We  also  telephoned plant personnel to clarify 308 and long term
data responses.

(5)  Screening Program

a.   Background

EPA focused its sampling and analysis  on  the  toxic  pollutants
designed  in  the  Act.   However,  ,we  also sampled and analyzed
conventional and nonconventional pollutants.  We  have  explained
our analysis methods for toxic organic pollutants in the preamble
to  the  proposed regulation for the leather Tanning point source
category (44 FR 38749,  July  2,  1974).   Before  proceeding  to
analyze  industrial  wastes,  we  had  to  isolate specific toxic
pollutants for analysis.  The list of 65 pollutants  and  classes
of   pollutants   potentially   includes  thousands  of  specific
pollutants; analyses for all of them would overwhelm private  and
government   resources.    To  make  the  task  more  manageable,
therefore, EPA selected 129 specific toxic pollutants  for  study
in  this  and  other   industry  rulemakings.   The  criteria  for
choosing  these  pollutants  included  the  frequency  of   their
occurrence  in water,  their chemical stability and structure, the
amount of the chemical produced, and the availability of chemical
standards for measurement.

The  screening  program  for  the  pharmaceutical   manufacturing
industry  was developed to obtain data indicating the presence of
priority pollutants and the  extent  of  their  presence  in  the
industry's  wastewater.   The  resulting  plant-by-plant priority
pollutant     concentrations     are     included     in      the
screening/verification data base.

b.  Selection of Screening Plant Candidates

In order to prepare a  list of pharmaceutical manufacturing plants
for the screening program, specific criteria were developed which
served  as  the  basis for the selection process.  Each candidate
plant  was  subjected  to  these  criteria   to   determine   its
acceptability  as  a   screening  candidate.  The  object  of  the
selection process was  to prepare an optimal  list  of  candidates
which  was representative of the pharmaceutical industry in terms
of production methods, product lines, wastewater characteristics,
treatment technology,  and other characteristics,  and  yet  would
result  in  sampling   at  the  smallest  number  of sites.  Brief
discussions of each criterion used  in the selection  process  are
presented in the paragraphs that follow.

One  of the major criteria for selecting candidate plants for the
screening program was  the pharmaceutical plant's  subcategory  or
type of production operation.  Four different types of production
                                17

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 operations are utilized in the making of pharmaceutical products.
 They  are fermentation, biological/  natural extraction, chemical
 synthesis,  and  mixing/compounding/  formulation   (see   fuller
 discussion   in   section   III).     Because   of   the  distinct
 characteristics of each operation,  the properties  of  a  plant's
 wastewater will be influenced by the operation(s) employed at the
 site.   Since the major portion of  wastewater flow is generated by
 pharmaceutical  manufacturing plants employing more than one type
 of production operation at a particular site,   the  goal  of  the
 selection  process was to choose plants that would not only cover
 the  above  four  categories,   but   that  would  also  provide  a
 satisfactory  production  operation  mix  (i.e.,   provide various
 combinations  of  the  above  four   subcategories).    Also,   past
 experience  indicated that Subcategories A and C  were more likely
 to have priority pollutants in their discharge than Subcategories
 B  and  D.    Therefore,   the  selection  process  concentrated  on
 obtaining  plants  with  these  production  operations.    The end
 result was that  the   screening list  had  proportionately   more
 Subcategory  A and C  plants than the pharmaceutical  industry as a
 whole.
                                           i  ,          , , -         , , ,

 Another important criterion of the  selection process  dealt   with
 the  type  of  treatment  at  the plant,  since the final  effluent
 quality of any wastewater discharge will  be dependent  upon  the
 treatment  used.    For  the screening program,  the goal was to try
 to select those plants  that had significant treatment.    In   this
 analysis,   significant   treatment was defined  as  treatment beyond
 equalization,  neutralization,  and primary sedimentation,   namely,
 biological,   physical/chemical,  or  other;  secondary   treatment.
 Therefore,  the end result was  that  the screening  list  reflected a
 relatively higher degree of treatment  than  the pharmaceutical
 industry  as a whole.

 As  stated  previously, the purpose of  the  screening program was  to
 determine   the  nature   and extent of priority pollutants in the
 pharmaceutical   industry's   wastewaters.     Probably   the   most
 important   factor affecting the  presence  of  these pollutants  in  a
 plant's effluent  is their  use  as raw  materials  in the  production
 operation.     Thus,   to   optimize   the  screening  program,   the
 selection  process  concentrated on   selecting   those  plants   that
 used  a   large  number  of  different  priority pollutants  in  their
 operations.

 Some pharmaceutical plants   indicated   that  they  had  performed
 their own wastewater sampling over  a period of time.   Information
of  this kind was  thought to be  important, since  it  could  provide
background  information on the plant's  effluent quality and assist
 in  the  analyses  of  the  sampling   data \ gathered  during  the
screening  program.   Therefore, consideration was given to those
facilities known to have historical sampling data.
                               18

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The amount of  wastewater  discharged  by  a  particular  pharma-
ceutical  manufacturing  plant  is  dependent  upon many factors.
Some of  the  more  important  factors  are  type  of  production
operation,  product  line, plant size, treatment costs, etc.  For
the screening program, it was thought to be desirable  to  select
plants  which  discharged  varying  quantities of wastewater.  In
this way, the screening could ascertain the effect of  small  and
large  flows  on priority pollutant levels and also be relatively
representative  of  the  pharmaceutical  industry  as  a   whole.
However,  since it was necessary for a plant to have a measurable
wastewater flow in order to be sampled, plants  having  zero  (or
very low) wastewater flows were omitted.

Another  criterion  for selecting plant candidates had to do with
company ownership of the  particular  manufacturing  plant.   The
goal  was  to  minimize,  wherever possible, the number of plants
operated by a single company.  First, this would avoid  "biasing"
the  screening  data  because of a particular company's operating
procedures.   Second,  it  would  minimize  the  resource  impact
(personnel,   time,  costs,  etc.)  sampling  would  have  on  an
individual company.

Although they were not as significant as the  above  criteria  in
the  selection  of  plant  candidates, each manufacturing plant's
geographic location, age, number of  employees,  etc.  were  also
considered.   For  plant  location and age, the selection process
tried to obtain a good variety of facilities reflecting the total
pharmaceutical manufacturing industry.

In order to satisfy the more important  criteria,  the  selection
process  regarding  plant  employment  tended to emphasize larger
facilities since past experience indicated that the larger plants
generally had more complex operations.  Thus, the screening  list
would  tend  to  contain  more of the larger manufacturing plants
than the pharmaceutical industry as a whole would.

The development of the final list  of  pharmaceutical  plants  to
comprise  the  screening  program was accomplished in a step-wise
fashion.  For each plant,  the  BPT  data  file,  308  Portfolio,
federal  and  state  government  documents,  and  other available
information were reviewed  in  order  to  prepare  a  preliminary
screening list.  This list was frequently reviewed and revised on
the basis of the aforementioned criteria in an attempt to develop
an  optimal  final   list.   The goal was to ensure that the final
list of  screening plants maximized the  specified  criteria,  yet
comprised a minimum  number of plants  to be sampled.

The  end  result  of  the  selection  process was that 26 pharma-
ceutical manufacturing plants comprised the final screening  list.
Pertinent data on the selected plants are shown  in Table  I1-2.
                                19

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 c.   Screening  Protocol

 Following   the  final   selection   of   the   26   screening   plants,
 preparations   were   made  for  the  actual  sampling  activities.   The
 sampling protocol developed by  EPA and discussed  in  "Sampling  and
 Analysis Procedures  for  Screening of  Industrial   Effluent   for
 Priority   Pollutants"  (60) served as  the basis  for the  collection
 and  analysis of  screening samples at  the  subject pharmaceutical
 manufacturing  sites.   An  overview   of the screening  methods is
 discussed  below.

 The  general rule was to obtain  24-hour samples  wherever possible.
 In some instances, this was altered to accommodate   a   particular
 aspect of  the  plant  to  be screened.   Certain facilities had batch
 operations and/or   did not operate "around-the-clock." For these
 situations, samples  of  less than  24  hours,  generally  8  hours,
 were collected.   On the other hand,  some facilities had  varying
 operations which showed fluctuating characteristics  over a period
 longer than 24 hours.   Here a longer  sampling time was  warranted,
 generally  on the order  of 48  hours.   In  most cases,  however,   24
 hour samples were collected.  To  cover certain  unique situations,
 the  sample  period  was  increased or  decreased as necessary.   No
 significant impact was  expected from  these modifications,  since
 the  major goal  of the  screening  program was only to identify  the
 presence   and  typical  levels  of priority  pollutants   in   the
 wastewaters of the pharmaceutical  manufacturing industry.

 The  types of  samples collected during the screening program were
 based upon the sampling protocol  developed by EPA.   To identify
 these  priority  pollutants,  classified  as acid or base/neutral
 extractables and metals,  composite samples were  obtained.    For
 the  volatile  organics  and  phenols  portion  of   the priority
 pollutants, grab samples  were taken.   Samples   were  analyzed   in
 accordance with  the analytical  techniques outlined in "Sampling
 and  Analysis Procedures for Screening  of Industrial  Effluents  for
 Priority Pollutants" (60).

 Two  sampling locations  of specific interest were  the influent  and
 effluent   of   the  plants'  wastewater  treatment  systems.    The
 influent to the  treatment system was  important  in the analyses  to
 determine  the   levels  of  priority   pollutants  generated by  the
 various pharmaceutical  manufacturing   operations.    The effluent
 from  the  treatment  system was  critical  in determining  the effect
 of the various treatment  systems   on  the removal  of  priority
pollutants  and  the  resultant   levels  reaching  the  receiving
waters.

Samples were also usually collected at other locations  throughout
a particular facility.   This  was   done   to obtain   supplementary
 information  on  a  specific  operation  or  treatment  step or  to
                               20

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ensure that certain characteristics unique  to  a  certain  plant
were adequately covered.  Some examples of these sample locations
are intake water, specific production wastewaters, holding tanks,
cooling  water,  etc.   The  end  result  was  that more detailed
information for each screening plant was made available  for  the
analyses  of  the  fate  of priority pollutants in pharmaceutical
wastewaters.

(6)  Verification Program

As previously mentioned, the screening program was  developed  .to
obtain  data  which  could  be  used  to indicate the presence of
priority pollutants and to characterize their nature  and  extent
in  the  pharmaceutical  industry's wastewaters.  Having obtained
these data, the EPA then selected five of  the  screening  plants
for  the  verification  program that used the assortment of major
priority pollutants as  raw  materials  for  the  manufacture  of
Pharmaceuticals.   The purpose of the verification program was to
confirm the data obtained during the  screening  program  and  to
more   accurately  quantify  the  concentrations,  loadings,  and
percent reductions  of  those  pollutants  found  at  significant
levels during the screening program.

a.   Selection of_ Verification Plant Candidates

The final list of pharmaceutical plants to comprise  the  verifi-
cation  study is given  in Table II-3.  EPA developed this list by
selecting  those  plants  that  satisfied  one  or  more  of  the
following criteria:

           Those plants with BPT-type treatment systems.

           Those plants that use cyanide as a raw material.

           Those plants with in-plant control measures such as
           cyanide destruction, steam stripping, and solvent
           recovery.

In  addition,  EPA   selected plants that would not only cover the
four subcategories,  but that would also  provide  a  satisfactory
production  operation   mix  (i.e., provide various combinations of
subcategories at particular plants).

b.   Verification Protocol

Prior  to verification sampling,  preliminary  grab  samples  were
collected  from  the verification sampling locations to determine
the applicability of the planned  analytical  methods.   However,
the  data  obtained  from   these  grab  samples  were not used to
                                21

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quantify  effluent  levels  or  to
achieved by the treatment systems.
calculate  percent   removals
The results of analyzing the screening visit samples were usually
discussed  with  operating  personnel  to  determine   if priority
pollutants  found  were  used  by  the  plant  as  . either   raw,
intermediate,  or  final  products.   These  results and the data
obtained from  the  aforementioned  grab  samples  were  used  to
determine the final verification sampling locations and to define
the priority pollutant verification analyses to be performed.

For a detailed discussion of the sampling methods employed in the
verification  program,  the  reader  is referred to "Sampling and
Analysis Procedures for Screening  of  Industrial  Effluents  for
Priority  Pollutants"  (60).   With respect: to sampling time, the
verification program was directed toward gathering three days  of
24-hour  samples.   Where  automatic  composite  samples were not
feasible, manual composite samples were obtained for analysis  of
acid  and base/neutral extractables, metals, and conventional and
non-conventional  pollutants.   Grab  samples  were    taken   for
analysis  of  volatile  organics,  phenols,  and  cyanides.  Some
wastewater streams were grab sampled once  ;for  analysis  of  all
parameters.   Samples for the verification iphase were  analyzed in
accordance with the 304(h) approved methods found in   "Analytical
Methods for the Verification Phase of the BAT Review"  (129).

The  analysis  of  verification  samples  was  performed  under a
detailed quality-assurance/quality-control 'procedure.  The proce-
dure required  analyses  of  duplicate  extractions  for  samples
collected  on  the  first  day of verification sampling.  Samples
taken on the second and third days of verification sampling  were
extracted and analyzed, spiked with appropriate amounts of pollu-
tants, and reanalyzed.  Spike recoveries were calculated from the
data generated during these analyses.  The spiking and reanalysis
requirement  was  deleted if the original pollutant concentration
was below the detectable limit.   Another  requirement  was  that
samples not analyzed, spiked, and re-extracted within  72 hours of
sample  collection  were  subjected  to  an  additional  spiking,
holding,  and  analysis.    This  requirement  was   designed   to
determine whether the pollutants degrade during storage.

As  in  the  previous  case  of  the  sampling  programs, the two
sampling locations of specific interest  were  the  influent  and
effluent  of  each  plant's  wastewater  treatment  systems.  The
treatment system's influent was  important  in  the  analyses  to
determine  the  levels  of  priority  pollutants generated by the
various pharmaceutical manufacturing operations.   The  treatment
system's  effluent  was critical in determining the effect of the
various treatment systems on the removal of  priority  pollutants
and the resultant levels reaching the receiving waters.
                               22

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In addition to the above, samples were usually collected at other
locations  throughout  a  particular  facility.  This was done to
obtain supplementary  information  on  a  specific  operation  or
treatment  step  or to ensure that certain characteristics unique
to a plant were adequately covered.  Examples of  these  sampling
locations  are  intake  water, cooling water, specific production
wastewaters, etc.  The end result was a more detailed analysis of
the fate of priority  pollutants  for  each  verification  plant.
Since  a  goal  of the verification program was to quantify those
pollutants found during the screening program, the same  sampling
locations were generally used for the two programs.

(7)  Long-Term Data Program

In addition to 308 and Screening/Verification  data,  the  Agency
was  interested  in obtaining data which would reveal traditional
pollutant raw waste loads and their day-to-day variability.  This
required  obtaining  data,  collected  over  a  consecutive  time
period,   which   reflected  fluctuations  in  process  effluent.
Therefore, the Agency decided to identify those plants which  had
collected   data   through   self-monitoring.    The  Agency  was
particularly interested in data for the  conventional  parameters
Biochemical  Oxygen  Demand  (BOD),  and  Total  Suspended Solids
(TSS), the  non-conventional  parameter  Chemical  Oxygen  Demand
(COD), and cyanide (CN).

As  in the Screening and Verification programs, specific criteria
were developed which  served  as  the  basis  for  the  selection
process.   The  controlling  factor  for  assembling  a  list  of
candidate plants was whether  the  plant  in  question  had  been
conducting  a  self-monitoring program.  Once a list of candidate
plants had  been  developed,  they  were  subjected  to  criteria
similar to those for the screening program.

One of the major points of concern for selecting long-term plants
was  the  subcategory or type of production operation.  The prime
objective was to select plants  that  would  encompass  the  four
subcategories  and  combinations of subcategories.  This was done
to provide a representative cross section of production processes
and  the  consequent  wastewater  effluents  found   within   the
industry.   An  equally important criterion for selection was the
type of wastewater treatment used by the candidate plant.  It was
also desirable to include not only plants that had exemplary "BPT
type" but also plants with  typical  "BPT  type"  treatment.   If
possible more than one type of treatment system was included.

Also  important  as  a  selection  criterion  was  the  amount of
wastewater discharged.  Again an attempt  was  made  to  cover   a
range   of  wastewater  flows  that  was  representative  of  the
industry.
                               23

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Another criterion for selection involved company  ownership.   An
attempt   was   made  to  select  plants  operated  by  different
companies.  This was done  for  two  reasons.  This  would  avoid
biasing  the  data  because  of  a particular company's operation
circumstances and policy.  Also, it  would  reduce  the  resource
burden   that  sampling  would  be  for  an  individual  company.
However, for comparative purposes it was desirable to  have  some
plants  common  to  both the Screening/Verification data base and
the Long-Term data base.

Other criteria considered but not as significant were  geographic
location of each plant, plant age, and number of employees.

Using  the  criteria outlined above, thirty-five (35) plants were
selected as long-term data candidates.  Questionnaires were  sent
to  these plants and responses were received from 22 plants.  The
respondents represented a good cross section of the  industry  as
indicated by the statistics which follow:
SUBCATEGORY CLASSIFICATION
          SINGLE SUBCATEGORY PLANTS

               Subcategory A only
               Subcategory B only
               Subcategory C only
               Subcategory D only

          MIXED SUBCATEGORY PLANTS
                    13
WASTEWATER FLOW

     Less than 0.1 MGD
     0.1 to 1.0 MGD
     1.0 to 10.0 MGD

DISCHARGE TYPE
     Direct
     Indirect
     11
    plants
    plants
4   plants
17
The  responses  were carefully reviewed to see that the treatment
systems  and  data  were  suitable.   One  plant   (#12123)   was
eliminated  from traditional pollutant consideration because data
were available for cyanide removal only.  Five more  plants  were
eliminated because they were indirect dischargers whose treatment
systems  were  in place to avoid sewer use charges rather than to
achieve a permit-specified performance.  The data base  contained
17  plants with reasonable treatment schemes at this point of the
review.  The remaining plants were scrutinized to  determine  the
                               24

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level  of  performance of their waste treatment facilities.  Four
of the remaining plants were eliminated due to  poor  performance
of  their facilities, which made their data unsuitable as a basis
for limitations reflecting good technology as required  for  BCT,
BAT,  and  NSPS.   The  performance  of  the remaining plants was
averaged and served as the basis for  BCT  and  BAT  regulations.
Three  plants  classified  as marginal performers were eliminated
from the data base before averaging for NSPS  purposes.   Details
on the exact plant selection process are provided in Section X.

Table  I1-4 presents the total list of Long-Term Data Plants with
selected characteristics.

Table I1-5 presents a comparison  of  the  screening  plants  and
long-term  plants  versus  the total pharmaceutical manufacturing
population.

(8)  PCS Data

Another source of data was the  current  PCS  (Permit  Compliance
Schedule)   for  pharmaceutical  manufacturers  possessing  NPDES
permits.  These permits contain the limitations under  which  the
individual plants are currently being regulated.  A comparison of
the  permit  limitations versus 1976 BPT limitations is presented
in Section III.

G.  Processing of Data and Information

Stanford Research Institute  (SRI) was contracted to do a two-part
statistical analysis of the pharmaceutical  industry  data  base.
Long-term  effluent  data were evaluated to determine variability
of pollutant removal resulting  from  long-term  operation.   The
analysis  centered  on  effluent  data yielding daily and monthly
variability factors for each pollutant.  Alternative methods  for
calculating  variability  factors  were developed, permitting the
recommendation of a meaningful and useful  variability  allowance
for regulatory purposes.

In  the  second  part of the analysis, screening and verification
data were evaluated to determine the frequency of  occurrence  of
each   priority   pollutant   occurring  in   the  manufacture  of
Pharmaceuticals.  A frequency ranking was prepared for groups  of
priority  pollutants and is  discussed in Section V.  In addition,
the statistical  pattern  of  concentrations  of  each  pollutant
present  was analyzed.  Frequency of occurrence and concentration
information were two criteria on which the selection of  specific
priority  pollutants  for  regulation was based.  In addition, we
considered whether treatment required by other regulations  would
control   these  pollutants.   Section  VI  contains   a  detailed
                                25

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discussion of this selection process in light of the criteria for
exclusion in paragraph 8 of the Consent Agreement.
                              26

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                                 TABLE II-l
                          PHARMACEUTICAL SUMMARY
                     SUMMARY OF 308 PORTFOLIO MAILING
                                     Original  Supplemental  Comprehensive
                                       308's       308's       Data Base
Portfolios Distributed;
   Plants in the Initial Mailing
   "Additional" Plants Included
     in Survey

Portfolios Not Returned;

Portfolio Processing;
   Duplicate Portfolios
   Non-Mfg. (Non-Pharm.) Portfolios
   Exclusively Research
     (Subcategory E) Portfolios

Manufacturing Portfolios;
442
396
46
-11
-187
-50
-105
540
523
17
-185
-135
-4
-128
982
919
63
-196
-322
-54
-233
-32
244a
   (a)  These plants are listed in Appendix C.
   (b)  These plants are listed in Appendix E.
 -3
220b
-35
464
                               27

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                           TABLE II-2
                     PHARMACEUTICAL INDUSTRY

     CHARACTERISTICS OF THE 26 PLANTS SELECTED FOR SCREENING
Plant No.
        Subcategory  EOP Treatment*
Wastewater
    Flow
    (MDG)
 EPA
Region
Startup
  Year
12015
12022
12026
12036
12038
12044
12066
12097
12108
12119
12132
12161
12204
12210
12231
12236
12248
12256
12257
12342
12411
12420
12439
12447
12462
12999**
              D         AS,AC              0.101      III
          A   C         AS,TF              1.300      III
              C         AS,AL              0.101      II
          A             AS,TF,AL           1.128      V
          A B C D       AS,AL              0.855      V
          A     D  Primary Treatment Only  2.97       V
            BCD       AS,AL              0.26       V
              CD       AS                 0.035      V
          A   CD  Primary Treatment Only  -          II
          AD       AS                 0.0.32      II
          A   C         AS,TF              1.000      III
          A   C D       AS                 1.332      II
          A B C D       AS                 0.850      II
            B C         AL                 0.002      IV
          AD       AL                 0.50       II
              C         AS                 0.810      IV
                D       AS                 0.035      III
          A B C D  Primary Treatment Only 30.00       I
          A B C D       AS                  .600      V
          A  C D        None               0.701      II
            BCD       AL                 0.30       IV
            B   D       AS                 1.33       V
              C D       AS,AL              0.01       II
          A B C D  Primary Treatment Only  1.50       V
          A             AS,AL              0.170      VII
              C D  Primary Treatment Only  0.45       VII
Subcategory Totals:  A » 15
                         Legend: AC = activated carbon   AS
                                 AL = aerated lagoon     TF
                         1960
                         1951
                         1950
                         1948
                         1954
                         1938
                         1953
                         1951
                         N/A
                         1977
                         1941
                         1969
                         1907
                         1973
                         1968
                         1952
                         1961
                         1948
                         1965
                         N/A
                         1970
                         1973
                         1974
                         N/A
                         1972
                          N/A

                       activated
                       trickling
*
**
See Appendix M for in-plant and end-of -pipe treatment
308 Portfolio was not received from this plant.
                               28

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                                   TABLE I1-3

                             PHARMACEUTICAL INDUSTRY

          CHARACTERISTICS OF THE FIVE PLANTS SELECTED FOR VERIFICATION
PLANT CODE

  12026
  12038
SUBCATEGORY  MAJOR TREATMENT

  C          Activated Sludge
             Aerated Lagoon
             Polishing Pond
ABCD
  12097


  12236
  CD


  C
Activated Carbon
Activated Sludge
Aerated Lagoon
Phys i cal-Chemi cal
Thermal Oxidation

Activated Sludge
Physical-Chemical

Activated Sludge
                         COMMENTS

                         Has Solvent Recovery
Uses Cyanide;
Has Steam Stripping;
Has Solvent Recovery
Uses Cyanide;
Has Solvent Recovery

Uses Cyanide;
Has Solvent Recovery
  12411
 BCD
Aerated Lagoon
On-Site Incineration
of Solvents
                               29

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                                       TABLE n-4

                               PHARMACEUTICAL INDUSTRY

             CHARACTERISTICS OF 23 PLANTS SELECTED FOR LONG TERM STUDY
Plant No.
12015
12022
12026
12036
12097
12098
12117
12123
12160
12161
12186
12187
12235
12236
12248
12257
12294
12307
12317
12420
12439
12459
12462
Subcategory
D
A C
C
A
C D
D
B D
C D
D
A CD
C D
C
C
C
D
A B C D
C D
D
D
B D
C D
D
A
EOP
Treatment*
AS, AC
AS, TF
AS, AL
AS, TF, AL
AS
AS
AS
Primary Treatment Only
AS
AS
AS, AL
TF
Primary Treatment Only
AS
AS
AS
AS
AS, AL
AS
AS
AS,AL
AL
AS, AL
Wastewater
Flow (MGD)
0.101
1.448
0.161
5.156**
0.064
0.006
0.101
0.932
0.029
1.653
0.037
1.065
No Data
0.816
0.110
0.755
0.118
0.002
0.740
0.164
No Data
0.049
0.209
EPA
Region
III
III
II
V
V
II
III
II
II
II
II
I
II
IV
III
V
II
II
IV
V
II
II
VII
Startup
Year
1960
1951
1950
1948
1951
1975
1882
1937
1974
1969
1976
1949
1971
1952
1961
1922
1969
1975
1972
1973
1974
1977
1972
Employment
300
100
0
100
100
0
400
200
200
800
0
0
0
200
700
4000
300
100
2000
100
0
Not
0
- 400
- 200
- 100
- 200
- 200
- 100
- 500
- 300
- 300
- 900
- 100
- 100
- 100
- 300
- 800
- 4500
- 400
- 200
- 2500
- 200
- 100
Reported
- 25
Subcategory Totals: A =  5                         Legend: AC
                 B=  3    •    •                        AL
                 C = 12                                AS :
                 D = 16                                TF :

 * See Appendix L for in-plant and end-of-pipe treatment
** Includes non-process flows.
Activated Carbon
Aerated Lagoon
Activated Sludge
Trickling Filter

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                              TABLE H - 5

                     PHARMACEUTICAL INDUSTRY

      COMPARISON OF SCREENING PLANTS AND LONG TERM PLANTS
     VERSUS TOTAL PHARMACEUTICAL MANUFACTURING POPULATION
Item
Total Number of Plants
Subcategory
A
B
C
D
Wastewater Quantity
Less than 0.1 Mgal/d
0.1 to 1.0 Mgal/d
1.0 to 10.0 Mgal/d
Greater than 10.0 Mgal/d
EPA Region
I
II
PR
III
IV
V
VI
VII
VIII
IX
X
Plant Age (1978 Basis)
Less than 5 years
5 to 1 0 years
10 to 2 5 years
25 to 50 years
50 to 100 years
Greater than 100 years
Employment
Less than 1 00
100 to 500
500 to 1000
Greater than 1000
Screening
Plants
26
57.7%
34.6
69.2
73.1
23.1%
46.2
26.9
3.8
3.7%
14.8
14.8
14.8
11.1
33.3
0.0
7.4
0.0
0.0
0.0
18.2%
18.2
22.7
36.4
4.5
0.0
8.4%
45.8
20.8
25.0
                                      Long Term Plants
Total
All Single Subcat. Only
23
22.7%
13.0
52.2
69.6
28.6%
52.4
19.0
0.0
4.3%
17.4
30.4
17o4
8.7
17.4
OoO
4.3
0.0
OoO
0.0
17.4%
34.8
8.7
30.4
8.7
0.0
31.8%
50.0
9.0
9.0
13
15.4%
0.0
30.8
53.8
33.3%
50.0
16.7
0.0
.- 8.3%
16.7
33.3
16.7
16.7
8.3
0.0
8.3
0.0
0.0
0.0
23.0%
30.8
15.4
30.7
0.0
0.0
41.7%
41.7
8.3
8.3
                                                              464
                                                               8.0%
                                                              17.2
                                                              28.7
                                                              80.2
                                                              80.0%
                                                              15.1
                                                               4.3
                                                               0.6
                                                               3
                                                              26.1
                                                               9.5
                                                               9.5
                                                              10.6
                                                              20.0
                                                               3.4
                                                               6.0
                                                               1.3
                                                               8.6
                                                               1.3
                                                              16.2^*)
                                                              22.7 (*)
                                                              27.8 (*)
                                                              19.9 (*)
                                                              12.0 (*)
                                                               1.4 (*)
                                                              36.9%
                                                              41.0
                                                              10.8
                                                              11.3
*Only (original) 308 Portfolio plants had these data and, thus, were used to calculate
 these figures.
                                  31

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                            SECTION  III

                   DESCRIPTION OF THE  INDUSTRY
A.   INTRODUCTION
 In order to establish an  industry data base  upon  which  proposed
 regulations  can  be  developed  and promulgated, a  comprehensive
 profile was developed from survey,  sampling and  existing  data
 sources.

 This  section  presents   information  assembled to describe, in  a
 quantitative   and   specific    manner,     the    pharmaceutical
 manufacturing   industry.   The  data  comes from   responses  to
 requests provided  by  companies  in  the  industry  as  well  as
 information  obtained  from  open  literature  and other sources.
 Processes, production, plant size,  age,  geographical  location,
 employment,  and  current  wastewater  discharge  performance are
 discussed and tabularly presented.

 B.  DETAILED INDUSTRY PROFILE

 The objectives of the 308 Questionnaire  were  to  obtain  infor-
 mation   from  pharmaceutical  manufacturing facilities  and  to
 develop an  industry  profile  that  includes  plant  size,  age,
 location,  and  production  activities.  Appendix F  lists each of
 the 464 manufacturing plants contained in the  comprehensive  EPA
 data  base  by  plant  code  number  (assigned for identification
 purposes), applicable manufacturing subcategories,  manufacturing
 employment,  and  year  of operational startup.  Plants with code
 numbers in the 12000 series are from the original  308  Portfolio
 survey; those with 20000 series numbers are  from the Supplemental
 308 Portfolio survey.

 Table  III-l  shows the geographical distribution of the industry
 and the number of manufacturing plants by state and  EPA  region.
Also  shown are the average number of manufacturing employees per
plant and the average plant startup year.

Most of the pharmaceutical industry is  located  in  the  eastern
half  of  the  United  States  (See  Figure  III-l.)  Of  the 464
manufacturing plants in the comprehensive data  base,  almost  80
percent  are in the East.  New Jersey (with  about 16 percent) and
Region  II  (with  approximately  36  percent)  is  the   largest
pharmaceutical  manufacturing state and EPA  region,  respectively.
The data show that Regions II, III,  V,  and VII (the Northeast and
Midwest) have generally older plants than Regions IV,  VI,  VIII,
and  IX  (the  South  and West).   This is due to the recent trend
toward building plants in the "Sun Belt" of  the  United  States.
                               32

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Puerto  Rico  has  close  to  10  percent  of the industry and is
becoming a major pharmaceutical manufacturing center.

Table  II1-2  breaks   down   the   industry   by   manufacturing
subcategory.   These  process-based subcategories were used for a
review of the industry,  although  these  distinctions  were  not
carried  through  for  purposes  of developing the newly proposed
regulations.  Subcategory D (formulating/mixing/ compounding)  is
the  most  prevalent pharmaceutical manufacturing operation, with
80 percent  of  the  plants  in  the  industry  engaged  in  this
activity.   Fifty-eight  percent of the plants have operations in
only Subcategory D.  The remainder also have operations in  other
subcategories.

Table II1-3 summarizes the total number of batch, continuous, and
semi-continuous  manufacturing  operations by subcategory for the
entire pharmaceutical industry.   Batch-type  production  is  the
most  common type of manufacturing technique for each of the four
subcategories.

C.  MANUFACTURING PROCESSES


One of the most important generalizations which can be made about
the wastewaters produced and  discharged  by  the  pharmaceutical
industry  is  their  extreme diversity.  Products, processes, and
the materials to which wastewater is exposed vary greatly.   With
the   goal   of   relating  those  discharges  with  some  common
characteristics,  subcategories  based  on   unit  ' manufacturing
processes were defined.  The broad manufacturing processing areas
considered  were   (a)  fermentation,   (b)  biological and natural
extraction,  (c) chemical synthesis, and  (d) formulation.

One characteristic of processing in this  industry   is  that  the
ratio  of   finished  product  to  the  quantity of raw materials,
solvents, and other processing materials is generally  very  low.
This  is  most  apparent   in  natural  extraction  (Subcategory B),
followed by fermentation (A), synthesis  (C), and formulation (D),
respectively.

1.   Fermentation

Fermentation  is the usual  method for producing  most  antibiotics
and  steroids.   The   fermentation  process  involves three basic
steps:   inoculum and seed  preparation, fermentation, and  product
recovery.

Production  of  a   fermentation pharmaceutical begins with  spores
from the plant master  stock.   The  spores  are   activated  with
water,   nutrients,  and  warmth; they  are then propagated through
                                33

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 the use of agar plates, test tubes, and flasks until enough  mass
 is  produced  for  transfer  to the seed tank.   In less critical
 fermentations, a single seed tank may serve  several  fermenters.
 In  this  type  of  operation,  the  seed  tank  is never emptied
 completely, so the seed remaining will serve as the inoculum  for
 the  next  seed  batch.   The  seed  tank  may  be sterilized and
 inoculated only when contamination occurs.

 Fermentation is conventionally a large-scale  batch  process.   A
 fermentation   cycle   begins   with   a  water  wash  and  steam
 sterilization of the fermenter vessel.  Sterilized  nutrient  raw
 materials   in   water   are   then  charged  to  the  fermenter.
 Microorganisms are transferred to the  fermenter  from  the  seed
 tank  and  fermentation  begins.    During  fermentation,   air  is
 sparged into the batch and temperature is  carefully  controlled.
 After  a  fermentation period of  from twelve hours to a week, the
 fermenter batch whole broth is ready for filtration.    Filtration
 removes  mycelia  (remains  of  the  microorganisms),  leaving the
 filtered aqueous broth containing product and residual  nutrients
 ready to enter the product recovery phase.

 There  are  three  common   methods  of product recovery:   solvent
 extraction,  direct precipitation,  and ion exchange or  adsorption.
 Solvent extraction is a recovery   process  in  which   an   organic
 solvent  is  used  to  remove the pharmaceutical  product  from the
 aqueous broth  and  form  a  more  concentrated  solution.    With
 subsequent  extractions,   the  product is separated from  any con-
 taminants.    Further removal  of the product from  the  solvent  can
 be   done by either precipitation,  solvent evaporation,  or further
 extraction  processes.   Normally,   solvents   used  for   product
 recovery  are recovered and reused.   However,  small portions left
 in  the  aqueous phase during the solvent  "cut"  can appear   in  the
 plant's  wastewater stream.   The  typical  processing solvents used
 in    fermentation   operations     are     benzene,      chloroform,
 1,1-dichloroethylene,  and  1,2-trans-dichloroethylene.  (42)

 Direct   precipitation  consists  of  first precipitating  the product
 from  the aqueous  broth,  then  filtering  the broth,  and   finally
 extracting   the product  from  the solid residues.   Priority pollu-
 tants known  to be used  in  the precipitation process   are copper
 and zinc.  (42)                              i

 Ion  exchange  or   adsorption involves the  removal  of  the product
 from the broth, using such  solid materials  as  ion exchange resin,
 adsorptive resin, or activated  carbon.  The product is  recovered
 from  the solid phase with  the  use of a solvent;  it is then  reco-
 vered from the solvent.

Steam is used as  the major  sterilizing medium for most equipment.
However, to the extent that chemical disinfectants may  be   used,
                               34

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they can contribute to priority pollutant waste loads.
a commonly used disinfectant.
Phenol is
Sometimes  a fermentation batch can become infested with a phage,
a virus that attacks microorganisms.  Although phage  infestation
is  rare  in  a  well-operated  plant, when it occurs, very large
wastewater discharges may be necessary in a short period of time.
Usually the batch is discharged early and its nutrient  pollutant
concentration is higher than that of spent broth.

Another  fermentation  wastewater source is the control equipment
that is sometimes installed to clean fermentation waste  off-gas.
The  air  and  gas  vented  from  the  fermenters usually contain
odoriferous substances and large quantities  of  carbon  dioxide.
Treatment  is  often  necessary  to  deodorize the gas before its
release to  the  atmosphere.   Some  plants  employ   incineration
methods;   others   use  liquid  scrubbers.   The  blowdown  from
scrubbers may contain absorption chemicals, light soluble organic
compounds,  and  heavier  insoluble  organic  oils    and   waxes.
However,  wastewater  from  this  source  is  unlikely to contain
priority pollutants.


The pollution contribution of the spent beer arises from the fact
that the beer contains substantial food materials such as sugars,
starches, protein,  nitrogen,  phosphate,  and  other nutrients.
Methods  for  treating  the  fermentation  wastes  are  generally
biological in nature.  Although the spent beers, even in a highly
concentrated form, can be satisfactorily  handled  by biological
treatment  systems,  it is less likely to upset the system if the
wastes are first  diluted  to  some  degree.   Dilution  normally
results  from  the  equalization  of fermentation wastes with the
other waste streams.  As  a  result,  a  satisfactory biological
reduction of the contaminants can be achieved.

The  308 data shows generally that wastewaters from Subcategory  A
plants generally are characterized by  high  BOD,  COD,  and  TSS
concentrations, large flows, and a pH range of about  4.0 to 8.0.

2.   Biological and Natural Extraction

Many materials used as  Pharmaceuticals  are  derived from  such
natural sources as the roots and leaves of plants, animal glands,
and  parasitic  fungi.   These products have numerous and diverse
pharmaceutical  applications  ranging  from   tranquilizers   and
allergy   relief  medications  to   insulin  and  morphine.   Also
included  in this group is blood fractionation, which  involves the
production of plasma and its derivatives.
                                35

-------
 Despite their diversity, all extractive  Pharmaceuticals  have  a
 common  characteristic:   they  are  too  complex  to  synthesize
 commercially.  They are either very large  molecules  and/or  the
 synthesis  results in the production of several steroisomers only
 one  of  which  has  pharmacological  value.   Extraction  is  an
 expensive  manufacturing process since it requires the collection
 and processing of very large  volumes  of  specialized  plant  or
 animal matter to produce very small quantities of products.

 The  extraction  process consists of a series of operating steps.
 In almost every step,  the volume of  material  being  handled  is
 reduced  significantly.  In some processes,; the reductions may be
 in  orders  of  magnitude  and  the  complex  final  purification
 operations may be conducted on quantities of materials only a few
 thousandths  of  the  material handled in earlier steps.   Neither
 continuous processing  methods nor conventional batch methods  are
 suitable   for   extraction   processing.    Therefore,  a  unique
 assembly-line,   small-scale  batch  processing  method  has   been
 developed.     Material  is  transported  in   portable  containers
 through the plant in batches of 75 to 100 gallons.   A  continuous
 line  of  these  containers  is  sent  past  a series of operating
 stations.   At each station,  operators perform specific  tasks  on
 each  batch  in  turn.    As  the volume of material being handled
 decreases,   individual  batches  are  continually   combined   to
 maintain  reasonable  operating  volumes  and the line moves more
 slowly.   When the volume is reduced to a very small quantity,  the
 containers   used  also  become  smaller,   with   laboratory-size
 equipment used  in many cases.

 An   extraction   plant   may  produce  one product for a few weeks;
 then,  by changing the  logistical  movement  of pots and  redefining
 the  tasks to be conducted  at each station, a plant  can convert to
 the  manufacture of a different product.

 Residual  wastes  from  an  extraction   plant essentially will  be
 equal  to the weight of  raw material,  since the active ingredients
 extracted are generally present  at  very  low  levels.   Solid wastes
 will represent  the largest  pollutant  load; however,  solvents  used
 in the processing steps will  cause  both  air  and water pollution.

 The  nature   of   the  products  of   the  pharmaceutical   industry
 dictates  that   any manufacturing facility maintain  a standard of
 cleanliness   higher than   that   required  for  most    industrial
 operations.   Since most  of  these  plants  are cleaned frequently,
 detergents   and   disinfectants  are  normally   found    in    the
 wastewater.                                 >

As   in  the   fermentation  process,  a  small   number of  priority
pollutants were  identified as being used in  the manufacturing  of
extractive Pharmaceuticals.  (41) The cations  of  lead  and  zinc are
                               36

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known  to be used as precipitating agents.  Phenol was identified
as  an  equipment  sterlizing  chemical  as  well  as  an  active
ingredient.   Otherwise, priority pollutants are found to be used
only as processing solvents.  Some identified  as  solvents  were
benzene, chloroform, and 1,2 dichloroethane.

Solvents  are  used in two ways in extraction operations.  First,
they are used to remove fats and oils that would contaminate  the
products.   These  "defatting"  extractions use an organic liquid
that dissolves the fat but not the  product  material.   Solvents
are  also  used  to extract the product itself.  Plant alkaloids,
when treated with an alkali,  become  soluble  in  such  selected
organic solvents as benzene, chloroform, or 1,2 dichloroethane.

Ammonia  is  used  in  many  extraction  operations  since  it is
necessary to control the pH of water solutions from  both  animal
and  plant  sources  to achieve separation of valuable components
from waste materials.   Ammonium  salts  are  used  as  buffering
chemicals  and  aqueous  or  anhydrous  ammonia  is  used  as  an
alkalizing reagent.  The  high  degree  of  water  solubility  of
ammonium  salts  prevents  unwanted  precipitation of salt; also,
ammonia does not react chemically with animal  or  plant  tissue.
Such  basic  materials  as  hydroxides  and  carbonates of alkali
metals do not have these advantages.

The  principal  sources  of  wastewater  from  biological/natural
extraction  operations  are   (a) spent raw materals (waste plasma
fractions, spent eggs, spent media broth, plant residues,  etc.);
(b)  floor  and  equipment washwaters;  (c) chemical wastes (spent
solvents and the like); and  (d) spills.

In general, the bulk of the spent raw materials is collected  and
sent to an incinerator or landfill.  Likewise, the nonrecoverable
portions  of  the  spent  solvents are  incinerated or landfilled.
However, in both cases, portions of the residual  materials  find
their  way  into  a  plant's  wastewater.    Floor  and equipment
washings  and  spills  also   contribute  to  the  ordinary  waste
discharge.

Although   pollutant    information   for  the  biological/natural
extraction  operations  in   the  pharmaceutical  data  base   was
limited,   that  which  was  available lent itself to a preliminary
analysis.  Generally, wastewaters from  Subcategory B  plants  are
characterized  by   low  BOD,  COD,  and TSS concentrations; small
flows;  and pH values of approximately 6.0 to 8.0.

3.   Chemical Synthesis

Most of  the  compounds  used  as  drugs   today  are  prepared  by
chemical'  synthesis   (generally  by  a  batch process).   The basic
                                37

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 major equipment item is the conventional batch  reaction  vessel,
 one of the most standardized equipment designs in industry.

 Generally,  the  vessel  is equipped with a motor-driven agitator
 and an internal baffle. It is made of either stainless  steel  or
 glass-lined  carbon-steel and contains a carbon-steel outer shell
 suitable for either cooling water or steam.,  Vessels of this type
 are made in many different sizes, with  capacities  ranging  from
 0.02 to Tl.O m3 or more.

 The  basic vessels may be fitted with many different attachments.
 Baffles  usually  contain  temperature  sensors  to  measure  the
 temperature  of  the  reactor contents.   An entire reactor may be
 mounted on load cells to  weigh accurately the  reactor  contents.
 Dip  tubes  are  available to introduce  into the vessels reagents
 below the liquid surface.   One of the top nozzles may  be  fitted
 with  a  floodlight  and   another with a glass cover to enable an
 operator to observe  the   reactor  contents.    Agitators  may  be
 powered  by  two-speed motors or by variable-speed motor drives.
 Typically,  batch reactors are installed  with only the  top  heads
 extending  above  the  operating  floor   of the plant in order to
 provide the operator with easy access for loading and cleaning.

 With other suitable accessories,  these vessels  can  be  used  in
 many different  ways.   Solutions can be mixed,  boiled,  and chilled
 in   them.    By   addition   of  reflux condensation,  complete reflux
 operations are  possible.   By  application of a  vacuum,  the vessels
 become vacuum evaporators.  Solvent extraction operations can  be
 conducted  in them,  and,  by operating the agitator at  slow speed,
 they serve as crystallizers.

 Synthetic pharmaceutical manufacture consists   of   using  one  or
 more  of   these  vessels  to perform in a step-by-step  fashion the
 various operations  necessary  to make the  product.    Following a
 definite   recipe,   the  operator   (or, increasingly,  a programmed
 computer)  adds  reagents;  increases  or decreases  the  flow rate  of
 cooling   water,   chilled  water,  or  steam; and starts and  stops
 pumps  to  transfer   the  reactor  contents   into  another  similar
 vessel.   At  appropriate  steps  in  the   process,  solutions are
 pumped through  filters  or centrifuges or  are pumped  into  solvent
 recovery  headers or waste sewers.

 The  vessels  with  an assembly  of auxiliary equipment  are  usually
 arranged  into independent process units;  a  large  pharmaceutical
plant may contain many  such units.   Each unit may  be suitable  for
 the   complete   or   partial   manufacture   of   many   different
pharmaceutical  compounds.   Only with  the highest volume  products
 is  the equipment "dedicated" or modified to be suitable for  only
one process.
                               38

-------
Each pharmaceutical is usually manufactured in  a  "campaign   in
which  one  or  more  process unit is employed for a few weeks or
months to manufacture enough compound to  satisfy  its  proDected
sales  demand.   Campaigns  are  usually  tightly scheduled, with
detailed coordination extending from procurement of raw materials
to packaging and labeling of the product.  For a variable  period
of  time,  therefore,  a  process  unit  actively  manufactures a
specific compound.  At the  end  of  this  campaign,  another  is
scheduled  to follow.  The same equipment and operating personnel
are used  to  make  a  completely  different  product,  utilizing
different  raw  materials,  executing  a  different  recipe,  and
creating different wastes.

The synthetic Pharmaceuticals industry uses  a  wide  variety  of
priority  pollutants  as reaction and purification solvents  (43).
Water was reported to be used more often than would  be  expected
in  an   industry  whose products are organic chemicals.  However,
benzene  and toluene were the most widely  used  organic  solvents
since  they  are stable compounds that do not easily take part in
chemical  reactions.   Similar   ring-type   compounds   (xylene,
cyclohexane,  pyridine, etc.) also were reported as being used in
the manufacture of synthesized Pharmaceuticals or resulting  from
unwanted side reactions.

Solvents serve  several functions in a chemical synthesis,  They
dissolve gaseous,  solid,  or  viscous  reactants  to  bring all
reactants into close molecular proximity.  They serve to transmit
heat to  or from the reacting molecules.  By physically separating
molecules  from  each  other,  they slow down some reactions that
would otherwise take place too rapidly and that would  result   in
excessive temperature  increases  and unwanted side reactions.

There  are  other  less obvious uses of solvents, however.   One of
these is the  use  of  a  solvent   in  the  control   of  reaction
temperature.    It  is  common practice  in  a batch-type  synthesis  to
select a solvent whose boiling point  is  the same as   the  desired
reaction temperature  and which is compatible with the reaction.
Heat  is  then  applied  to  the reaction  mass at a rate sufficient  to
keep  the mixture  continuously  boiling.   Vapors that rise from  the
reaction vessel   are   condensed   and   the   liquefied  solvent   is
allowed  to   drain back  into  the reaction vessel.   Such refluxing
prevents both overheating and  overcooling of the reactor contents
and can  automatically compensate for  variations  in   the  rate   of
release  or eibsorption of  chemical  energy.

Essentially   all  production   plants  operate   solvent  recovery
facilities that  purify contaminated  solvent   for   reuse.    These
facilities   usually   contain   distillation   columns  and may also
 include  extraction facilities  where still  another  solvent  is used
to separate  impurities.   Many  of the  wastes   from   the   synthetic
                                39

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 pharmaceutical  industry  will  be  discharged from these solvent
 recovery facilities.  Aqueous wastes which may result  from  such
 operations   include   residues   saturated   with  the  solvents
 recovered.

 Another cause of solvent loss is storage practices.  Bulk storage
 is usually in  an  unpressurized  tank  that  is  only  partially
 filled.   The  level of the liquid in the tank rises and falls as
 liquid is added to or removed from the tank.  The  vapor  in  the
 tank  above the surface of the liquid is therefore exhausted when
 the liquid level is rising; as the level  falls,   fresh  air  (or
 nitrogen from a padding system)  is introduced.   Even if no liquid
 is  added  or  removed,   the  tank  "breathes"   as  a  result  of
 temperature and barometric pressure changes.  Each  time  a  tank
 "exhales,"  the  released  vapor is saturated with solvent vapor;
 rather large quantities of solvent can be lost  to the  atmosphere
 through this mechanism.

 Chemical  synthesis  operations   also produce large quantities of
 pollutants normally measured  as  BOD  and  COD.    Wastewater  is
 generally  produced with each chemical modification that requires
 the filling and emptying of the   batch  reactors.    These  waste-
 waters  can  contain  the unreacted raw materials as well as some
 solvents.

 The effluent from   chemical  synthesis  operations  is   the  most
 complex  to  treat   because  of   the many types of operations and
 chemical   reactions   (nitration,     amination,     halogenation,
 sulfonation,    alkylation,    etc.).    The  production  steps  may
 generate  acids,  bases,   cyanides,   metals,   and   many   other
 pollutants.   In some instances,  process solutions  and vessel wash
 waters   may  also   contain   residual   solvents.    Sometimes,  this
 wastewater  is  incompatible   with  biological  treatment  systems.
 Although  it  is possible  to acclimate the bacteria to the various
 substances,  there may  be  instances  where certain  chemical   wastes
 are  too  concentrated or too  toxic to make  this  feasible.   Thus,
 it may  be necessary  to equalize  and/or  chemically pretreat  a
 process  wastewater prior  to conventional  treatment.

 Primary  sources of  wastewater from chemical  synthesis  operations
 are  (a)  such  process  wastes  as   spent   solvents,   filtrates,
 concentrates, etc.;  (b) floor and equipment wash waters;  (c)  pump
 seal  waters;   (d)   wet  scrubber   spent  waters;  and (e) spills.
Wastewaters from Subcategory C   plant   can  be  characterized  as
having   high  BOD,   COD, and TSS concentrations; large  flows; and
extremely variable pH, ranging from  1.0  to 11.0.

4.  Formulation
                               40

-------
Although pharmaceutically active ingredients are produced in bulk
form, they must be  prepared  in  dosage  form  for  use  by  the
consumer.    Pharmaceutical  compounds  can  be  formulated  into
tablets, capsules, liquids, or ointments.

Tablets are formed in a tablet  press  machine  by  blending  the
active  ingredient,  filler, and binder.  Some tablets are coated
by tumbling with a  coating  material  and  drying.   The  filler
(usually  starch,  sugar,  etc.) is required to dilute the active
medicinal to•the proper concentration, a  binder   (such  as  corn
syrup  or  starch)  is  necessary  to  bind  the tablet particles
together.  A lubricant  (such as magnesium stearate) may be  added
for  proper  tablet machine operation.  The dust generated during
the mixing and tableting operation is collected  and  J-J  usually
recycled   directly  to  the  same  batch.   Broken  tablets  are
generally collected and recycled to the granulation operatxon   in
a  subsequent lot.  After  the tablets have been coated and dried,
they are bottled  and packaged.

Capsules are produced by first forming the hard  gelatine  shell.
These   shells  are  produced by machines  that  dip  rows of rounded
metal dowels into a molten gelatine solution and then  strip  the
capsules  from   the  dowels  after  the   capsules  have cooled and
solidified.  imperfect  empty capsules are remelted and reused,  if
possible, or sold for  glue  manufacture   Most   Pha™ceutical
companies   purchase    empty    capsules   from   a   few  specialist
producers.

The  active  ingredient and   any   filler   are  mixed  before   being
poured   by   machine  into  the empty  gelatine  capsules.  The  filled
capsules are bottled  and  packaged.  As   in   the  case  of   tablet
production,  some dust is generated.   Although this is  recycled
small  amounts  of waste  dust must be disposed of.   Some glass  and
packaging  waste from broken  bottles  and cartons  also  result from
this operation.

Liquid preparations  can be formulated for injection or  oral   use.
 in either case,  the  liquid is  first weighed and then dissolved in
water    Injectable   solutions  are  bulk  sterilized  by heat or
 filtration and then  poured into sterilized bottles.  Oral  liquid
preparations  may  be  bottled directly without the sterilization
 steps.

Wastewaters are generated by general cleanup operations,  spills,
 and  breakage.   Bad  batches  may  create a solid waste disposal
 problem.

 The   primary   objective    of    mixing/compounding/formulation
 operations  is to convert the manufactured products into a final,
 usable form.  The necessary production steps have typically small
                                41

-------
 wastewater flows because  very  few  of   the   unit   operations   use
 water  in  a  way   that   would  cause wastewater  generation.   The
 primary use of water  in the actual  formulating   process   is   for
 cooling  water  in  the chilling  units and for equipment and floor
 wash.

 Sources   of   wastewater   from  mixing/compounding/formulation
 operations  are   (a)  floor   and  equipment wash  waters,  (b)  wet
 scrubbers, (c) spills, and (d) laboratory  wastes.   The   use  of
 water  to  clean  out mixing tanks can  flush materials of  unusual
 quantity and concentration into  the  plant  sewer  system.    The
 washouts  from  recipe  kettles  may be  used to prepare the master
 batches of the pharmaceutical  compounds and may contain inorganic
 salts,   sugars,   syrup,  etc.     Other   sources  of   contaminated
 wastewater  are  dust and fumes  from scrubbers either in building
 ventilation systems or on specific equipment.  In general,  these
 wastewaters   are   readily  treatable  by  biological  treatment
 systems.

 An analysis of the pollutant information  in  the  pharmaceutical
 data base  shows  that  wastewaters  from  Subcategory  D plants
 normally  have low BOD, COD,  and  TSS  concentrations;   relatively
 small flows;  and pH values of  6.0 to 8.0.

 D.   RAW  MATERIALS  AND PRODUCTS

 The pharmaceutical   industry   utilizes   a  vast   array  of   raw
 materials   and  processing agents.   The  diversity of feedstock is
 attributable  to  the  variety of  products  and  the number of  process
 variations  common to  the   industry.   This   review  describes  a
 number  of materials  that can be used as  feedstocks and processina
 agents.

 Fermentation   operations   use   large  quantities of  nutrient
 materials such as carbohydrates and proteins.  Examples  of some
 raw materials  are  meat  extractions   and   distillers  extract.
 Materials   classified  as   priority   pollutants    which   enter
 fermentation  operations are mainly metals, as reaction modifiers
 au? j?rocessin9 agents  in the  fermenter,  and  organic  solvents,
 which  are  employed  as extractive agents for product separation
 and purification.   The   residues  from the  organic   starting
 materials  plus  mycelia   contribute  heavily to conventional BOD
 loadings.

Biological and natural  extraction  processes  can   have  a  wide
 variety  of  feedstocks including roots,  leaves of plants,  animal
 glands or parasite fungi.  These  substances  contribute  to  BOD
 loadings;   priority  pollutant  loadings  are  primarily  due   to
solvents used for extraction.    These solvents can be  any  number
                               42

-------
of  organic compounds with benzene and chloroform being among the
most widely used.

Chemical synthesis presents the  broadest  spectrum  of  starting
materials.   Feedstocks can range from oxbile to dextrose.  Given
the appropriate starting material there are many common synthetic
processes (as many as several  hundred)  by  which  the  starting
material is transformed to the product.  A number of solvents and
additives  are  required to complete the synthesis.  Solvents are
usually  inexpensive  relative  to  the  product  and  are   used
liberally for this reason.  These solvents are almost exclusively
organic  and  may  be priority pollutants.  Additives are used to
control reactions and  many  contain  metals  that  are  priority
pollutants.

Product recovery and purification from most of the processes used
to  produce  Pharmaceuticals  expose  a  -variety  of solvents and
extractive agents to the wastewater.  These include  hydrocarbons
and  other organic compounds such as methylene chloride, benzene,
carbon tetrachloride, and chloroform.  Reaction control,  and  in
some  cases reactant requirements, call for the use of many metal
compounds listed as priority pollutants.

Many of the 126 priority  pollutants  appear  in  the  industry's
wastewater.   Most of them have their source  in the raw materials
and processing agents employed.  The organic  solvent  and  metal
pollutants  are almost completely accounted for by plant material
inputs.

In summary, chemical  materials  utilized  and  produced   in  the
pharmaceutical   industry  are numerous and  diverse.  They are used
as  reactants,   extractive   solvents,    catalysts,    inhibitors,
diluents,  and   other  purposes.    In  addition,  other  chemical
compunds  may be  identified as  intermediates,  products,  and  by-
products.   Many  of  these  materials  are among  those  listed as
priority  pollutants.  In  fact,  the  vast  majority   of   the   126
priority  pollutants  listed  are present somewhere  in  the  industry
although  not necessarily  in  wastewater.    Appendix  H summarizes
the  usage  and  occurrence of  priority pollutants  as  indicated by
308 responses.

E.   CURRENT DIRECT  DISCHARGER PERFORMANCE
 1
BPT Compliance
 Direct discharger  wastewater  effluents  in  the  pharmaceutical
 industry are currently subject to 1976 BPT performance standards.
 A  plant-by-plant  analysis  of  308  data for direct dischargers
 indicates that although many plants are well within BPT limits, a
 substantial number are not meeting the BPT level  of  90  percent
                                43

-------
 BOD  removal   and  74  percent  COD  removal.
 rankings are  shown in Table II1-4.
These performance
 2-    Current Performance Compliance with Proposed BPT

 Current  performance of some  plants already meets the  approximate
 BCT   limitations   (see  Table  III-5)  for BOD,  COD,  and TSS  of  40,
 360,  and 40  mg/1,  respectively.   Tables  II1-6  through II1-8 show
 a  ranking   by  effluent  concentration   and  indicate a projected
 compatibility with the projected  design  criteria for BCT  and   BAT
 limitations.

 Tables   III-9 and  111-10   compare performance  as  judged by con-
 centration criteria and by percent removal  for BOD  and COD.    The
 ranking  derived for plants using  either  criterion are similar.

 F.   Comparison of  Current Permits with  1976 BPT

 Table Hl-ll  presents  the results   of  a   comparison   of  current
 permit    limitations    for   direct  dischargers with  1976   BPT
 limitations for BOD, COD and TSS.   Permit  limitations   (expressed
 in  Ibs/day)  were  compared to a Ibs/day value  calculated  from  308
 data, using 1976 BPT design criteria (BOD  90%, COD   74%,  TSS  52
mg/1),  for each plant.  The comparison shows  that  in general  the
majority of current permit limitations for BOD and COD  are  more
stringent   than,   or  at  least   equivalent   to,  the  1976  BPT
 limitations.   However, the majority of current permit limitations
for TSS are less stringent than 1976 BPT limitations.
                              44

-------
       TABLE II1-1

 PHARMACEUTICAL INDUSTRY
GEOGRAPHICAL DISTRIBUTION



Number of Percent of
T r^r*at* "i nn
EASTERN U.S.
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
REGION 1 Total
New Jersey
New York
Puerto Rico
Virgin Islands
REGION 2 Total
Delaware
Maryland
Pennsylvania
Virginia
West Virginia
District of Columbia
REGION 3 Total
Alabama
Georgia
Florida
Mississippi
North Carolina
South Carolina
Tennessee
Kentucky
REGION 4 Total
Til inois
Plants
368
8
0
7
0
1
' ' 1
1
17
76
43
44
2
165
2
7
26
7
2
0
44
3
6
8
2
12
3
10
5
49
38
Total Plants
79.2
1.7
0.0
1 .5
Of\
.0
0.2
0~ . '•)
. /
3.6
16.4
9.3
9 . 5
....... 0.4,
35.6
0.4
1 .5
5.6
1 .5
OA
. 4
Of\
. 0
9.4
0.6
1 .3
1 .7
' 0.4
2.6
0.6
2.2
1 . 1
10.5
8.2
Average
Number
Average
Plant
Employees Start-up
Per Plant
268
195
77
(2)
(2)
\ *• /
161
346
211
216
i •j
1 3
239
121
65
370
138
1 R1
1 */ 1

267
15
189
95
759
456
87
301
1*^
2
250
305
Year ( 1 )
1952
1963
1961
(2)
(2).

1960
1950
1943
1970

1956
1965
1938
1949
1950


1950
1958
1956
1967
1949
1971
1968
1940

1962
1951
            45

-------
 Indiana
 Ohio
 Michigan
 Wisconsin
 Minnesota
      REGION 5 Total
18
14
15
4
4
3.9
3.0
3.2
0.9
0.9
664
203
423
54
41
1944
1929
1933
1957
—
93
20. 1
                                                           351
1943
 WESTERN U.S.

 Arkansas
 Louisiana
 Oklahoma
 Texas
 New Mexico
     REGION  6  Total
 Iowa
 Kansas
 Missouri
 Nebraska
     REGION 7 Total
Colorado
Utah
Wyoming
Montana
North Dakota
South Dakota
     REGION 8 Total
Arizona
California
Neva
Hawaii
     REGION 9 Total
Alaska
Idaho
Oregon
Washington
     REGION 10 Total
96
2
2
0
12
0
16
3
4
17
4
28
5
1
0
0
0
0
6
1
38
1
0
40
0
0
2
4
20.8
0.4;
0.4i
0.0!
2.6'
'• 0.0
3.4
0.6
0.9
3.7
0.9
6.1 !
1 .1
0.2
0.0
0.0
0.0
0.0
1 .3 :
0.2
8.2
0.2
0.0
8.6
0.0
0.0 :
0.4
0.9
152
1558
9
—
127
-
129
77
123
108
201
117
96
(2)
_
_
_
-
162
(2)
139
(2)
-
137
^ ,
—
25
33
1962
1970
_
_
1967
-
1968
1963
1954
1943
1962
1951
1967
(2)

_
_
-
1968
(2)
1967
(2)

1967
_
_
_
—
           1.3
             30
(1)  Since data concerning plant start-up year were not solicited
                                                                    1955
                               46

-------
(2)
from the Supplemental 308 plants, the figures were calculated
using only the original 308 plants responses.

Employment and start-up year figures are not presented to
avoid disclosing individual plant data.
                               47

-------
 Manufacturing
 Subcategory
 Combination

 A        only
 A B
 ABC
 A B C D
 A B   D
 A   C
 A   CD
 A     D
  B      only
  B C
  BCD
  B   D
    C    only
    C D
      D  only
 Not Available
 Total Plants

 Individual
 Manufacturing
 Subcategory

A
B
C
D
Not Available
                            TABLE II1-2
                       SUBCATEGORY  BREAKDOWN
 Number of
  Plants

     4
     1
     2
     8
     4
     3
    10
     5
    21
    12
     9
    23
    47
    42
   271
   	2
   464
Number of Plants
 in Subcateqory

    37
    80
   133
   372
     2
Total number of subcategories 624*
 Percent of
   Total
   Plants
Percent of
  Totals

    6.0
   12.8
   21 .3
   59.6
    0.3
     This represents the total number of subcategories covered by
     the 464 manufacturing plants.
                               48

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                           TABLE III-3

                 PRODUCTION OPERATION BREAKDOWN

                                        Number of Operations
Subcategory

Type of Operation
Batch
Continuous
Semi -continuous
Total Number of Operations
Percent of Total Operations

A
32
3
11
46
6.7

B
76
0
9
85
12.

C
129
14
19
162
4 23.

D
359
16
17
392
6 57.2

Total
596
33
56
685*
100.0
Percent
of Total
Oper.
87.0
4.8
8.2
100.0

Percent of Subcateqory
Which is Batch
69.6 89.4 79.6 91.6   87.0
*    Since each individual subcategory within a plant may be comprised
     of more than one type of operation, this figure will be greater
     than the total number of subcategories.

NOTE:  The above data apply to 462 manufacturing plants.  For two
       plants no information was available on their subcategories
       and types of production operations.
                               49

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                           TABLE II1-4

       DIRECT DISCHARGERS: COMPARISON OF PLANT PERFORMANCE
VS. 1976 BPT PERCENT REMOVAL "DESIGN" CRITERIA (BOD a) 90% & COD a) 74%)
                       (BASED ON 308 DATA)
Summary of Comparison

     Meets design criteria, both parameters
     Meets design criteria, but data incomplete
     Does not meet criteria                 13
     Data lacking                           36
     Total Direct Dischargers
         60
               7
               4
       308 Long Term Avg.
     Plant          BOD
    Number      % Removal
  308 Long Term Avg.
BOD       COD       COD
Rank   % Removal    Rank
Plants meeting design criteria: ;
12306
12307
12353
12038*
12248
12317
12026
^Partially meeting
12160
12463
12022
20297
Plants poorer than
12161
12015
20245
12132
12236
12104
12294
12338
20165
12239
12038*
99.0
97.5
96.5
96.1
95.9
95.8
95.0
design criteria,
99.1
94.1
93.2
94.7
design criteria
92.6
92.5
88.7
87.2
86.7
85.9
85.2
85.0
84.0
81 .9
80.1
2
3
4
5
6
7
8
but
1
9
10
8
92.1
96.5
94.4
87.9
87.0
89.9
77.7
lacking one




in one or more
12
14
14
15
16
17
18
19
20
21
22
36.56
69,72
94.5
95.77
79.32
74.52
79.89
_
79.11
81 .97
—
5
1
4
7
8
6
13
data item




i terns :
17

3
2
11
15
10
M
12
9
-.
                              50

-------
     12471
     20257
     12407
Plants without % removal data:
     12001
     12006
     12095
     12097
     12098
     12117
12085
12089
12189
12194
12205
12283
12119
12261
12264
12267
12281
12459
                    23
                    24
                    25
12256
12298
12308
12339
12406
20319
                    75.78
12287
20037
20201
20246
20298
20370
                    14
12462
12014
12030
12057
12073
20402
Note: Underline indicates performance not meeting design criteria,
                               51

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                           TABLE  II1-5

        DIRECT DISCHARGERS: COMPARISON OF PLANT PERFORMANCE
 vs. PROPOSED BCT  and BAT CONCENTRATION DESIGN CRITERIA (BOD S 40 MG/L,
                COD S  360 MG/L and TSS a) 40 MG/L)
                        (BASED ON  308 DATA)

 Summary of Comparison

     Meets design criteria, both  parameters       9
     Meets design criteria, but data incomplete   9
     Does not meet design criteria          '     23
     Data lacking                               ] 9

     Total Direct Dischargers                    60
      308 Long Term Avg. 308 Long Term Avg.
          Effluent            Effluent
   Plant     BOD       BOD      COD     COD
  Number     mg/1      Rank     mq/1    Rank
Plants meeting design criteria:
   12463
   20201
   12053
   12248
   12104
   20246
   12097
   12132
   20165
 6
 1
 8
10
12
13
28
29
32
 2
 2
 5
 6
 7
10
19
20
22
 29
 50
 67
 63
 40
128
289
203
113
 1
 4
 7
 6
 2
13
16
15
12
                                308 Long Term Avg.
                                  Effluent
                                    TSS     TSS
                                   mg/1     Rank
 9
 4
 2
35
22
33
29
29
24
 4
 2
 1
19
10
18
14
14
11
Partially meeting design criteria, but lacking one or more items
   12089
   12298
   20319
   20297
   12001
   12338
   12407
   12095
   12406
13
15
15
20
21
30
54
Plants poorer than
   12160      5
   12119      7
   12036     13
 9
11
12
16
18
21
25
      design criteria in one or
            1
            5         40      2
            8        197     14
                13        7
                26       11
                 9        4
                36       20

                30       15
                17        9
                 6        2
                10        4

            more items:
                43_       23
                70       29
                44       24
                               52

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12471
12307
12015
20037
12317
12283
12287
20245
12205
12161
12026
12022
20257
12462
12236
12294
12038*
12239
12098
14
18
19
20
32
35
56
56
60
72
93
105
143
145
149
208
244
284
693
                        11
                        u
                        15
                        16
                        22
                        24
                        26
                        26
                        28
                        29
                        30
                        31
                        32
                        33
                        34
                        35
                        36
                        37
                        38
                               83
                              489

                              107
                10
                1 1

                 5
                 8
                 9
                22
                23

                19
                18
                20
                21
                24
                17
                26
                                              38
Plants poorer than design criteria in one or more items:

                        39
12038** 114-0
12261
Plants with no effluent data:
       4470
       "9880
      27
      28
     12006
     12014
     12117
     20370
            12073
            12085
            12281
12187
12194
20298
12264
12267
12057
   457
   565
12339
12459
12256
                       28
                       30

                       25
                       26
                       26
                        7
                       17
                       22
                       34
                       36
                       21

                       32
                       30
                       13
                       35
                       33
                       37
   38
   39
20402
12030
12308
*
**
  Fermentation Wastes Only
  Chemical Wastes Only
                               53

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                        TABLE II1-6
RANKING OF DIRECT DISCHARGERS BY EFFLUENT BOD CONCENTRATION
                     (DATA BASE: 308)     ,
         308 Long Term Avg,
E:
Plant No.
12160
12463
20201
12119
12053
12248
12104
12036
12089
20246
12471
12298
20319
12307
12015
20037
20297
12001
12097
12132
12338
12317
20165
12283
Design criterion
12407
12287
20245
12205
12161
12026
12022
20257
12462
12236
12294
12038*
12239
12098
ffluent BOD5_
mg/1
5
6
6
7
8
10
12
13
13
13
14
15
15
18
19
20
20
21
28
29
30
32
32
35
of 40 mg/1
45
56
56
60
72
93
105
143
145
149
208
244
284
693
Rank by BOD5_
Effluent Cone.
1
.2
2
4
5
6
7 ;
8
8
10 :
1 1
12 !
12
14 :
15
16 !
16
18 ;
19
20
21
22
22 ;
24

25
26
26
28
29 ;
so :
31
32
33
34
35
36
37
38
Rank by
% Removal
1
10
-
-
4
6
16
2
-
' - 	
22
-
-
3
13
-
9
-
-
15
19
7
20
—

25
-
14
—
12
8
1 1
24
—
16
18
5
21
-
                                                          % Removal

                                                              99.1
                                                              94.1
                                                              96.5
                                                              95.9
                                                              85.9
                                                              99.0
                                                              72.0
                                                              97.5
                                                              92.6

                                                              94.7
                                                              87.2
                                                              85.0
                                                              95.8
                                                              84.0
                                                              16.7

                                                              88.7

                                                              92.7
                                                              95.0
                                                              93.2
                                                              70.5

                                                              86.7
                                                              85.2
                                                              96.1
                                                              81 .9
                            54

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 12038**
      1 140
Plants with no BOD data;
     12006
     12014
     12030
     12057
     12073
     12085
     12095
     12117
12187
12194
12256
12261
           39
12264
12281
12281
12298
     **
                 23
12308
12339
12459
                    80.1
20298
20370
20402
Fermentation Wastes Only
Chemical Wastes Only
(Ranked as two separate plants,  but counted as one.)
                               55

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                        TABLE II1-7
RANKING OF DIRECT DISCHARGERS BY EFFLUENT COD CONCENTRATION
                     (DATA BASE: 308)
         308 Long Term Avg.   Rank by COD
Effluent COD Effluent Cone. Rank
Plant No.
12463
12104
12119
20201
12287
12015
12248
12053
20245
12205
12307
12317
20165
20246
12036
12132
12097
12239
12462
20257
mq/1
29
40
40
50
51
54
63
67
74
81
83
107
112
128
197
203
289
290
297
329
by
% Removal
1
2
2
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
«
16
-
—
—
7
9
4
3
-
1
6
13
—
5
2
—
10
—
15




















Design criterion of 360 ma/1 	
12236
12294
12161
12026
12038*
12339
12098
12038**
12261
Plants with
12001
12073
12187
12283
12459
20370
553
568
944
946
1453
2370
2886
4470
9880
no COD effluent data:
12014 12006
12085 12089
12194 12256
12298 12308
12471 20037
20402
21
22
23
24
25
16
27
28
29

12022
12095
12264
12338
20297

12
1 1
17
14
8
—
—
—
18

12030
12117
12267
12406
20298











12057
12160
12281
12407
20319

* Fermentation Waste Only
** Chemiral Wast-^ Onlw
                                                          % Removal
                                                              74.52
                                                              88.96
                                                              87.04
                                                              94.44
                                                              94.52

                                                              96.53
                                                              89.94
                                                              79.11

                                                              92.19
                                                              95.77

                                                              81 .97

                                                              75.78
                                                              79.32
                                                              79.89
                                                              68.30
                                                              77.69
                                                              87.91
                                                              36.56
                            56

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                        TABLE II1-8
RANKING OF DIRECT DISCHARGERS BY EFFLUENT TSS CONCENTRATION
                     (DATA BASE: 308)
        308 Long Term Avg
Rank by TSS
Effluent TSS
Plant No.
12053
20201
12095
20319
12463
12406
12287
12089
12015
12407
12104
70165
12298
12294
12132
12097
12338
20245
20246
12248
20297
12022
12205
Design criterion
12160
12036
20037
12283
12317
12471
12119
12236
12307
12462
12239
12161
12038*
12026
12098
mg/1
2
4
6
9
9
10
13
13
15
17
22
24
26
28
29
29
30
32
33
35
36
38
40


43
44
47
50
50
59
70
90
90
97
174
196
306
326
336
Effluent Cone. Ra,nk by
mq/1
1
2
3
4
4
6
7
7
9
10
1 1
12
13
14
15
15
17
18
19
20
21
22
23


24
25
26
27
27
29
30
31
31
33
34
35
36
37
38
% Removal
1
—
4
—
—
3
—
—
7
14
—
13
—
—
—
—
8
—
—
—
11
—
^


2
5
—
—
' —
15
—
—
—
—
—
12
8
—
16
                                                          % Removal

                                                              99.5

                                                              96.5


                                                              97.0
                                                              89.7
                                                              43.3

                                                              48.9
                                                              85.0
                                                              75.5
                                                              99.0
                                                              93.7
                                                              36.6
                                                              50.8
                                                              86.5

                                                               5.1
                             57

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 12038**
 12261
        457
        567
Plants with no TSS data:
     12001
     12073
     12194
     12281

     *
     **
     12057
     12187
     12267
     20257
12256
12339
12459
           39
           40
12308
20370
20402
                  6
                 10
                    89.8
                    81 .6
20298
12014
12030
12006
12985
121 17
Fermentation Waste Only
Chemical Waste Only
                                58

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                           TABLE II1-9
      RANKING OF DIRECT DISCHARGERS BY BOD PERCENT REMOVAL
                        (DATA BASE: 308)
Plant No.
308 Long Term Avg.
    Effluent BOD
        mg/1
12160
12036
12037
12053
12038*
12248
12317
12026
20297
12463
12022
12161
12015
Design
20245
12132
12236
12104
12294
12338
20165
12239
12038*
12471
20257
12407
*
**
5
13
18
8
244
10
32
93
20
6
105
72
19
criteria of 90% removal
56
29
149
12
208
30
32
284
1140
14
143
45
Fermentation Wastes
Chemical Wastes Onlv
                                 Rank by BOD
                                Effluent Cone,
                                     1
                                     8
                                    14
                                     5
                                    36
                                     6
                                    22
                                    30
                                    17
                                     2
                                    31
                                    29
                                    15
                                    ,27
                                    20
                                    34
                                     7
                                    35
                                    21
                                    23
                                    37
                                    39
                                    11
                                    32
                                    25
  Rank by
% Removal

     1
     2
     3
     4
     5
     6
     7
     8
     9
    10
    1 1
    12
    13
                                         14
                                         15
                                         16
                                         17
                                         18
                                         19
                                         20
                                         21
                                         22
                                         23
                                         24
                                         25
% Removal
                                                         5
                                                         5
                                                         1
    99.1
    99.0
    97
    96
    96
    95.9
    95.8
    95.0
    94.7
    94.1
    93.2
    92.7
    92.6
                 88.7
                 87.2
                 86.7
                 85.9
                 85.2
                 85.0
                 84.0
                 81 .9
                 80.1
                 80.1
                 70.5
                 16.7
                               59

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                          TABLE  111-10

            RANKING OF PLANTS BY COD PERCENT REMOVAL
                         (DATA BASE: 308)

           308 Long Term Avg.
]
Plant No.
12307
12132
20245
12053
12036
12317
12915
12038*
12248
12239
12294
12236
20165
12026
20257
12104
Design Criteria
12161
12261
affluent COD
mq/1 E
83
203
74
67
197
107
54
1453
63
290
658
553
113
946
329
40
of 74% removal
944
9880
Rank by
If fluent Cone.
11 f
16
9
8 ;
15 !
12 i
6 :
25
7
18 :
22 !
21 1
13
24
20
2

23 .
29 i
Rank by
% Removal
1
2
3
	 4
5
6
7
8
9
10
11
12
13
14
15
16

17
18
                                                              %  Removal

                                                                  96.53
                                                                  95.77
                                                                  94.52
                                                                  94.44
                                                                  92.19
                                                                  89.94
                                                                  88.96
                                                                  87.91
                                                                  87.04
                                                                  81 .97
                                                                  79.89
                                                                  79.32
                                                                  79.11
                                                                  77.69
                                                                  75.78
                                                                  74.52
                                                                 68.30
                                                                 36.56
*Fermentation Wastes Only
                                60

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                          TABLE III-11
Ilant No-
 12015
 12022
 12026
 12036
 12038
 12053
 12085
 12097
 12104
 12117
 12132
 12161
 12167
 12205
 12236
 12248
 12256
 12261
 12294
 12307
 12317
 12339
 12406
 12459
 12462
 12471
BPT       BPT

  x



  x

  X
X
X
x
>BPT

  x



  X

  x
                                             >BPT

                                               x
                                x
                                x
                                   X
                                   X
                                   X
                                     X
                                     X


                                     X


                                     X


                                     X
X
X
X
                                       X
                                       X
                                       X
                   X

                   x
                                         x
                                         X
                                            X


                                            X
                                    X
                                    X
 Kotes   BPT:  permit more stringent than BPT

 Totals?  BOD permits less stringent than EPT = 3
          BOD permits equivalent,to BPT = j*
          BOD permits more stringent than BPT 9

          COD permits less stringent than BPT J
          COD peririts equivalent to BPT jj
          COD permits itore stringent than BPT 8

          TSS permits less stringent than EPT .13
          TSS permits equivalent to BPT 2
          TSS permits more stringent than BPT j»
                                        61

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                                             FIGURE  m-1
                                       PHARMACEUTICAL INDUSTRY
                                      GEOGRAPHICAL DISTRIBUTION
HAWAII
                                                                                  44-
                                                                                       • PUERTO RICO  -«2
                                                                                       VIRGIN ISLANDS

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                           SECTION IV
                   INDUSTRY SUBCATEGORIZATION
A.   INTRODUCTION
This section defines the subcategbries  selected  for  evaluative
analysis  and  presents  the  rationale for their selection.  The
subcategory breakdown utilized in this study  was  developed  for
evaluative  purposes.   This  method  was  found  to  be the most
practical  means  Of   analyzing   raw,  waste   .characteristics,
wastewater flow, and treatment technology alternatives.  However,
at the end of the analysis, we determined that subcategories were
not  necessary  for  regulatory  purposes  because the calculated
limits would not vary significantly between subcategories.

B.   BASIS FOR SUBCATEGORIZATION

The existing BPT regulation divides the  pharmaceutical  industry
into  subcategories  based  on  the general type of manufacturing
process.   Process  method  is  an  easily  definable  basis  for
subcategorization  and  is well understood by those knowledgeable
about the industry.  Characteristically only one process is  used
for  a  given  product  or  class  of products although there are
sequential processing  exceptions.   Subcategorization  based  on
process therefore provides effective subcategorization by product
type as well.                              :

Both  plant size and wastewater flow relate to process methods in
the sense that some processing methods   (e;g.,  fermentation  and
synthesis)  are  undertaken only in large-scale or highly complex
facilities.   More  direct  product-oriented  methods,  such   as
biological  extraction  or  product formulation generally involve
small and less complex manufacturing facilities  and   less  water
use.

The  wastewater  generated by most plants in the industry results
from more than one kind of process.  Nonetheless,  the  existence
of    single    subcategory   plants   does   permit   wastewater
characterization according to process  method.   Process  methods
are often distinct from one another in their effect on wastewater
characteristics  (pollutant identities and loads and flow) because
of  differences  in  the production modes involved and the  use of
the  campaign  operation.   Production  mode  may  be  batch   or
continuous   and  in some cases semi-continuous, that is, with part
of the  process being carried out on a batch basis  (e.g.  chemical
synthesis)   and  the  other part of- the process being  carried out
                                63

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 continuously (e.g.  product  purification).   The  use  of  campaign
 operation  involves  the use  of  the same equipment train to produce
 different   products.    Both approaches to  production are employed
 where possible to reduce unit  operating costs and the  number  of
 certification analyses.

 Fermentation  and   chemical synthesis  processes  are  generally
 conducted  on a batch  basis.  Fermentation  usually involves  large
 batches,   while the   batch size  tends to vary considerably for
 chemical   synthesis  processes.    Chemical  synthesis   involving
 several  steps  is  usually  conducted  using the campaign operation
 method.  Biological extraction and product mixing and formulation
 processes  are generally carried  out continuously.

 The effect of differing uses of  production  approaches  not   only
 affects  wastewater characteristics on a plant to plant basis but
 also affect the wastewater  characteristics of  individual  plants
 on a day to day basis.   The effect of this induced variability on
 wastewater    characteristics    and   the    resulting   treatment
 inefficiency  can   be  ameliorated to  some   extent   by   flow
 equalization prior  to treatment.
C.   SELECTED SUBCATEGORIES

The   pharmaceutical    industry   subcategories
established for data analysis are:
                             selected
and
     Subcategory A
     Subcategory B
     Subcategory C
     Subcategory D
Fermentation
Biological Extraction
Chemical Synthesis
Mixing, Compounding, and Formulation
An   additional   Subcategory   (Subcategory  E  -  Research)  was
identified earlier.  However, since research does not fall within
SIC Codes 2831, 2833, or 2834 designated by  the  Consent  Decree
and   does  not  have  wastewater  characteristics  warranting  a
national regulation, it is not  included in this study.

D.   SUBCATEGORY CHARACTERISTICS

There are discernable differences among  the  subcategories  when
viewed  in terms of effluent concentration averages or ranges and
wastewater  flow   rates.    However,   diversity   within   each
Subcategory  is  often  greater  than  between subcategories.  As
explained below, this is a major reason for  not  subcategorizing
for regulatory purposes.

1.   Fermentation is the basic  processing  method  used  in  the
production  of most antibiotics and steroids.  The steps employed
are (a) preparation of a seed,  (b) innoculation of  the  nutrient
                               64

-------
batch,  (c)  fermentation  of the nutrient raw materials, and (d)
recovery  of  the  product   by   such   means   as   extraction,
precipitation, or ion exchange.

     Fermentation processes are typically very large water users.
Spent  beers are the major source of characteristically high BOD,
COD, and suspended solids levels in the wastewater.

2    Biological or natural extraction is the  extractive  removal
of  therapeutic products from such natural sources as plant parts
(e.g., roots or leaves) animal parts (e.g., glands), or parasytic
fungi (e.g., molds).

      In contrast to fermentation, biological extraction processes
are normally small-volume water users with lower  BOD,  COD,  and
suspended solids levels.

3     Chemical synthesis is utilized widely in the manufacture  of
many  drugs   in  use today.  Most production is  in batch  reactors
which can be  used for a wide variety of process  steps   (heating,
cooling,  mixing, evaporation, condensation, crystallization, and
extraction).   Generally,  these  vessels  are   constructed   of
glass-lined   or  stainless  steel.   Their  versatility  permits
multiple functions  to produce many different compounds.

Chemical synthesis  processes  are  characterized  as   relatively
large water  users  with  high pollutant  loadings.  Also,  a wide
variety of  chemical pollutants can be expected.

4     In  formulation   (mixing,  compounding,   and    formulation),
Pharmaceuticals  are  prepared  in such  useable  forms  as  tablets,
Sapsules,   liquids,  and   ointments.   Active    ingredients   are
physically mixed with  filler, formed  into dosage  quantities,  and
packaged for  distribution.

Formulation is  normally a  low-level water  user (in many  cases  a
dry operation)  with low pollutant  levels.

 5     Because  most plants in  the pharmaceutical  industry  include
operations  in   two  or  more   subcategories  and   because common
 treatment  systems  are  used to  treat  combined  wastes,   raw  waste
 characteristics   or  treatment   effectiveness  often  cannot  be
 differentiated  by  subcategory.   For  these reasons,   much  of  tne
 data  analysis   is  limited to  that portion of the  data base which
 describes  the  performance  of  single  subcategory  plants;   the
 remainder  discusses the performance  of mixed subcategory plants.

 6.   Variations in process routes employed by different producers
 are common in the pharmaceutical  industry.  Process variations in
 chemical synthesis plants manufacturing the  same  product  occur
                                65

-------
 because  different  starting materials and reaction dequences are
 used.   Two plants making the same  product  but  using  different
 starting  materials  may use different reaction sequences.   It is
 possible that once a common  intermediate  compound  is  derived,
 that the remaining processing steps will mirror each other.   Even
 if  the same starting material is used by different plants,  it is
 possible,  due to the complexity  of  a  synthesis,   that  several
 feasible  routes  to  an  end  product exist.   The decision  as to
 which  route will be employed  can  depend  on  economics,  patent
 coverage,  corporate history or even personal preferences.

 In  fermentation  and  material  extraction  processes  the  major
 differences  between  processes  will  occur  in  the  extraction
 method.    In  many  cases,  extractions can be accomplished by any
 number  of  solvents.    Choice  of  a  solvent  will  depend   on
 environmental  impact,   company  history,   economics,  patents and
 other  factors.   Due to the  number of variables involved it is not
 surprising that such processes vary widely between  companies.

 E.   DECISION NOT TO SUBCATEGORIZE FOR REGULATORY PURPOSES

 Although the industry was   analyzed  considering  these process-
 based   subcategories,   such  distinctions   were  determined  to be
 unnecessary for the statement of limitations since:

      (1)   Most  of the industry  (in  terms  of  total   wastewater
 flow)   is   composed  of plants  with operations in  more than one
 process  subcategory,   which   combine  the  wastewater  from  all
 process  subcategories   before it is treated for conventional  and
 nonconventional  pollutants.   In addition,  the  relative volumes of
 wastewater from the different subcategory  operations are subject
 to   considerable  variation.    Thus,  wastewater in most plants is
 not  normally distinguishable   by  process   origin.    Under   these
 circumstances  it  is difficult to apply different limitations to
 different  subcategories.

     (2)   The  broad product/process  diversity    within    each
 subcategory   studied tends   to  exceed  and obscure distinctions
 characteristic  of each   subcategory.   Differences   in  pollutant
 loadings   for plants within a subcategory  may  be greater than  for
plants from  different subcategories.   Subcategorization schemes
 along  different   product/process   lines were  considered but were
rejected as  being too complex  and  not necessarily more accurate.

     (3)   The treatability of  the  wastewater from  plants  within
each   subcategory   is   not   characteristically  related to   the
subcategory.  The conventional  pollutant loadings for  BOD and  TSS
are generally amenable  to reduction  by biological  treatment   and
associated    operations   (clarification)    regardless   of  their
subcategory source.  It  has also been  demonstrated that  reduction
                               66

-------
to identical pollutant levels is achievable for  wastewater  from
each of the different subcategories.  Pollutant loadings may vary
within   each  subcategory  and  across  subcategories  but  such
differences  may   be   addressed   by   design   and   operating
modifications   to  the  biological  systems.   The  current  BPT
regulation establishes identical limitations for each subcategory
covered.

     (4)  The existing subcategorization scheme is irrelevant  to
the  regulation , of  toxic  pollutants  for  this  industry.  The
occurrence of toxic pollutants in a  plant's  wastewater  is  not
dependent  on  its  process  subcategory  designation  but on the
particular mix of individual product/processes it engages in.

     (5)  The  available  performance   data   from   which   the
regulations are devised as well as the screening and verification
program  results  for  toxic pollutants suggest that the industry
can be equitably regulated by a single set of limits.
                                67

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                            SECTION V

                     WASTE CHARACTERIZATION
A.
INTRODUCTION
The Agency, through  an  extensive  data  gathering  effort,  has
studied  qualitatively  and quantitatively the wastewaters of the
pharmaceutical  industry.  This effort provided the baseline  data
necessary  for  determining the significant pollutants present in
the wastewaters of the pharmaceutical industry  and  subsequently
the   regulatory   scope  for  the  pharmaceutical  point  source
category.

As  a  result  of  earlier   studies,   particularly   the   1976
Development  Document,  the EPA had available a limited amount of
data which characterized the wastewater discharges of  the  phar-
maceutical  manufacturing  industry.  However, not only were some
of these data old, but for the most part they were  related  only
to  such "traditional" pollutant parameters as BOD, COD, and TSS.
Information on the 126  toxic  pollutants  or  classes  of  toxic
pollutants  was almost nonexistent.   In order to fill this void,
the Agency instituted a number of  programs  aimed  at  gathering
from the pharmaceutical industry the necessary data on both toxic
and traditional pollutants.                |
Wastewater
following:
       characterization  has  been addressed considering the
     (1)  Traditional pollutants
     (2)  Priority pollutants              I
     (3)  Wastewater flow                  ''

This section reviews  the  sources  of  data  and  describes  the
results   which   provide  the  basis  for  the  limitations  and
standards.

B.   TRADITIONAL POLLUTANTS

Traditional pollutants considered for regulation  are  BODS  COD,
TSS,  and  pH.   The  reasoning  behind  their  selection and the
omission of others is reviewed in Section VI.   Three  of  these,
BOD,  TSS, and pH are listed as conventional pollutant parameters
and one, COD, is listed as non-conventional.
1.
Sources of Data
                               68

-------
     a.   Previous studies - The 1976 Development Document, which
was part of the Rulemaking Package for the  1976  BPT,  comprises
the main source of previously developed information.

     b.   308 Survey - During 1978  the  pharmaceutical  industry
was   surveyed  to  obtain  wastewater  data  and  related  plant
information in support of this new rulemaking effort.  The  first
308   questionnaire   was   sent   to  member  companies  of  the
Pharmaceutical Manufacturers Association (PMA).  The  content  of
this  questionnaire  appears  as Appendix B.  The second phase of
this survey was aimed at the remainder of the industry,  and  the
questionnaire employed is in Appendix D.  Substantial differences
in  both the form and question content of these forms result from
shifts  of  program  emphasis  between   the   times   of   their
distribution.   Recipients  are  listed  in  Appendices  C and E.
Survey/response  statistics   are   reviewed   in   Section   II.
Traditional pollutant (BOD, COD, and TSS) levels, as  indicated in
the  308  Portfolio data, are summarized in Appendix  I, and flows
in Appendix J.

     c.   Long term data - A list  of  plants  was  selected  for
further  survey  of  long-term  plant  log  data  on  end-of-pipe
treatment influents and effluents, with respect to BOD, COD,  and
TSS.  The development of a long-term data base, covering at least
a  full  year's  data  for  each  plant,  was necessary to permit
establishment of a performance average for a representative group
of industry treatment plants in terms of both pollutant level and
effluent variability.  A summary of long-term data   is  presented
in Table V-1.

A  summary  of  plants  covered  by  the  long-term   data program
follows.  Some, but not all, of the plants  also  appear   in  the
screening/verification  plant list, subsequently used in priority
pollutant analysis.

The flow values presented herein  are   long-term  daily  averages
developed  from  the log data submitted by each plant.  These may
differ  from  flows reported   in  the  308  portfolio   due   to  the
different  time  periods  in  which  they were established and/or
different modes of operation during those time periods.

Plant  12015  is a Subcategory D plant which appears   in  both  the
screening plants and the  long-term data plants.  Activated sludge
and  activated  carbon   are  used  to treat 0.101 MGD of wastewater
from pharmaceutical manufacture.

Plant  12022  is a Subcategory A and C plant which  is  one   of  the
screening  plants   in   addition   to being a  long-term data plant.
Plant  12022  discharges  1.45  MGD of wastewater  from  its   treatment
                                69

-------
 facilities  which  include  activated  sludge,  trickling filters,
 equalization,  neutralization,  and primary clarification.

 Plant 12026 is a Subcategory C plant which is a screening  plant,
 a  long-term  data  plant,  and a verification plant.   This plant
 discharges 0.161  MGD of pharmaceutical  process  wastewater  after
 treatment  with  equalization,   neutralization, activated sludge,
 and a polishing pond.

 Plant 12036 is a Subcategory A plant which is  both -a  screening
 plant  and  a   long-term data plant.  This plant discharges 0.855
 MGD of  wastewater  from  pharmaceutical   manufacture,   which  is
 treated  with   activated  sludge,   trickling  filters,  an aerated
 lagoon,  and a  final  stabilization lagoon.

 Plant 12097 is a Subcategory C and D plant which is a  screening
 plant  as  well  as   a   long-term data  plant.   The chemical waste
 treatment  unit   consists   of   equalization,    neutralization,
 physical-chemical    treatment,     filtration,     and     chemical
 stabilization.   This plant discharges  0.640 MGD  of   wastewater
 from pharmaceutical  processes.

 Plant  12098   is  a Subcategory  D plant.   Activated sludge is used
 to  treat pharmaceutical  process wastewaters which amount to 0.005
 MGD.

 Plant 12117 is  a  Subcategory B  and D  plant.   Activated  sludge  is
 used  in  the   wastewater   treatment  system to  treat 0.101  MGD  of
 pharmaceutical  process wastewater.

 Plant 12123 is  a  Subcategory C  and  D  plant   which   uses  only
 primary    treatment   to  treat   0.932  MGD  of   wastewater  from
 pharmaceutical  manufacture.
                                            i
 Plant 12160 is  a  Subcategory D  plant.    Pharmaceutical  process
 wastewater   is  treated  with   activated   sludge.   The  flow  of
 wastewater  is 0.029  MGD.

 Plant 12161  is  an  Subcategory A, C, and D  plant  which appears  as
 both   a    screening   plant   and    a   long   term  data   plant.
 Pharmaceutical  process wastewaters  are treated by  neutralization,
primary  clarification,  equalization,  activated   sludge,   and
polishing ponds.   The amount of wastewater  discharged 1.65  MGD.

Plant  12186 is  a Subcategory C and D plant.  Activated  sludge and
an  aerated  lagoon are  used to treat 0.370 MGD  of pharmaceutical
process wastewaters.
                               70

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Plant  12187  is  a  Subcategory  C  plant.   The  1.07  MGD   of
pharmaceutical  process  wastewaters  is treated with a trickling
filter.

Plant 12235 is a Subcategory C plant.  Primary treatment  is  the
only treatment used for pharmaceutical process wastewater.  (This
plant  was excluded from the variability analysis since it is not
a direct discharger).

Plant 12236 is a Subcategory C plant.  This plant appears in  the
screening plants, the verification plants, and the long-term data
plants.   The  0.816 MGD of pharmaceutical process wastewaters is
treated with equalization, neutralization, primary sedimentation,
and activated sludge.

Plant  12248 is a Subcategory D plant.  Activated sludge   is  used
to treat the 0.110 MGD of pharmaceutical process wastewater.

Plant  12257 is a Subcategory A, B, C, and D plant.  This  plant^is
in  both the screening plants and the long-term data plants.  The
treatment system components are equalization, neutralization, and
activated  sludge.   The   amount    of   pharmaceutical   process
wastewater discharged is 0.755 MGD.

Plant   12294  is a Subcategory C and  D plant.  Activated sludge is
used to treat the 0.118 MGD of pharmaceutical process wastewater.

Plant  12307 is a Subcategory D plant.  Two biological treatments,
activated sludge and aerated lagoon, are used to treat the  0.002
MGD of pharmaceutical process wastewater.

Plant   12317  is a Subcategory D plant.  Activated sludge is used
to treat the  0.740 MGD of pharmaceutical process wastewater.

Plant  12420 is a Subcategory  B  and D  plant.   This  plant  is
included   in  both   the  screening   plants and  the  long-term data
plants.  Activated sludge  is used   to  treat  the   0.164   MGD  of
pharmaceutical process wastewater.

Plant   12439   is  a  Subcategory C  and D plant.   Plant  12439  is  in
both a screening and long-term data plant.    Process  wastewaters
are     treated   with    equalization,   neutralization,    primary
sedimentation, activated sludge, and an   aerated  lagoon.  Long-
term flow  data was not available.

Plant   12459   is a Subcategory D plant with  a long-term  data  flow
of  0.049 MGD.   The only  method of  wastewater   treatment   utilized
 is  an  aerated lagoon.
                                71

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 Plant  12462  is  a  Subcategory  A plant with an average flow of
 0.209 MGD.   The wastewater treatment employed includes  activated
 sludge and  aerated lagoon.

 2-    Results and Bases for Limits

 Raw waste loads for plants reporting data under  the  308  survey
 are tabulated in Appendix I.   These raw waste loads were compared
 to   1976  BPT  and proposed BCT,  and were ranked according to (1)
 effluent  concentration and (2)  percent removal for BOD,  COD,   and
 TSS.    These  ranking tabulations are included earlier in Section
 III as Tables III-4 through 111-10.

 Averages  of the raw waste concentrations  of  BOD  and  TSS  were
 developed  for  each  subcategory  as  base  case figures for the
 calculation of cost estimates.   However,  these averages   are   not
 intended  to  convey any  significance other than as a calculation
 tool  (for further discussion,  refer to Section  VIII).    They do
 indicate  relative average levels  among the subcategories,  but are
 not used  directly in establishing limits.

 The  development  of  plant-by-plant costs to accomplish proposed
 BCT  levels  used  308 reported   concentrations  as  the   flag
 indicating    which   plants are   likely   to  require additional
 treatment and to what extent.   This  is  discussed  in detail in
 Section VIII.

 Table  V-l presents a summary of long term  data.   Among the direct
 dischargers,   13  plants   are   identifiable  as  having reasonable
 removal performances (equal to  or,better than  that  required by
 the existing  regulation).   These  are summarized  in Table V-2  with
 a   notation  of   performance   in   terms of percent removal  and of
 long-term average effluent  concentrations  for BOD,  COD,  and  TSS.
 The  average   performance  of these plants  serves as the  basis for
 developing  statements of  limits for  BCT, BAT,  NSPS,  PSES and  PSNS
 as discussed  in  Sections XI, XII,  XIII, and XIV.   The development
 of the  statement  of limits   for  the  new  TSS  limitation is
 presented in  Section X.

 Similarly,  a  further selection of long-term data plants was  made
 to serve  as the  basis for NSPS, which  is   discussed  in  Section
 XIII.   This   was   accomplished  by  exclusion   of  data  from  3
 additional plants whose performance  was judged to be  marginal  as
 indicated  by  percent  removal   of  BOD.    Table  V-3 lists  this
 further group  of  selected plants  and their  data.

Statistical studies   of  this   data  were   conducted  to develop
variability  factors  reflecting  changes in;performance  occurring
from day to day  and  through the measured period   of  performance.
                               72

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The bases, methodology, and results of these variability analyses
are reviewed in Section IX,

C.   Priority Pollutants

The Consent Agreement list of priority pollutants and classes  of
priority  pollutants  potentially  includes thousands of specific
compounds.  However, for purposes of rulemaking, the  Agency  has
selected  129  specific  pollutants  for  limited  consideration.
These are listed in Table V-4.

Thirty-three priority pollutants are present in the wastewater of
at least one of the plants sampled.  However, few of the priority
pollutants are individually widespread  in  their  occurrence  or
high  in  concentration.  The significance of these facts as they
affect the choice of pollutants to be regulated is  discussed  in
Section VI.
 1
Sources of Data
a    308 Portfolio Survey -  The  308  Portfolio  Survey  was  an
invaluable  source  of  information for developing profiles of  the
pharmaceutical manufacturing industry.   Similarly,   this  survey
proved  to  be  a major source of data for waste characterization
purposes.  Not only did  it  provide  more   recent   and  detailed
information  on  traditional  pollutant parameters  and wastewater
flow characteristics, but the 308 Portfolio  was the  first   major
source   of  data  on   the  use  and/or  generation  of  priority
pollutants by this industry.

One purpose of the 308  survey was  directed   at  quantifying  the
nature  and  extent  of priority pollutants  in the  pharmaceutical
industry.  Of the 464 pharmaceutical manufacturing  plants  in  the
comprehensive  308  Portfolio  Data  Base,   212  responded  to  the
questions  concerning priority pollutants.  Of the   115   different
priority   pollutants   identified, chloroform, methylene  chloride,
phenol, toluene,  and   zinc  were  reported   as  being   the most
frequently used  as   raw materials  for manufacturing operations.
None of the priority pollutants were reported by even as many   as
ten  respondents  as   being  intermediate  or  final  products.   Some
priority  pollutants  (primarily  such  pesticide-related   compounds
as  endrin and heptachlor) were reported  as  being  analyzed  in  the
effluents of  the  manufacturing  plants  (most  probably due  to  the
mixing  of pharmaceutical  and  nonpharmaceutical  wastewaters),  but
not  as  being  a  raw material  or  a  final  product.

The  308  data  base  indicates  that   although  the   pharmaceutical
manufacturing industry uses  and therefore might  discharge a large
 number   of  priority  pollutants,   broad  occurrence  of specific
 chemical  compounds  is  limited.    Priority  pollutant  information
                                73

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 submitted by the pharmaceutical manufacturing plants is presented
 in Appendix H.

 b.    PEDCo Reports - Concurrent with the efforts to  profile  the
 pharmaceutical   manufacturing  industry  using  the 308 Portfolio
 survey,  PEDCo Environmental,  Inc.  undertook a study to detail the
 various   manufacturing  processes/steps  that  are  used  in  the
 production   of   fermentation,   extractive,   and   synthesized
 Pharmaceuticals.

 In  their  studies,   PEDCo  examined  recent  industry  data  and
 selected   those  products  that  comprise  the  major  areas  of
 production for  each   of  the   three  manufacturing  subcategories
 (i.e.,   A,   B,  and C).   With  these major product lines as a base,
 they then consulted  all available  literature describing the step-
 by-step   procedures   to  be  used   in  the  production  of   each
 substance.    As  a  result,   PEDCo  was  able to identify certain
 priority  pollutants  that were  known  to  be   used   by   the
 pharmaceutical  industry.   These pollutants are listed in Table V-
 D *

 Because  of  the  size  and complexity of the industry and the myriad
 of   products manufactured,   it was not practical for a study of
 this kind to identify  every   priority  pollutant  that  could  be
 used.    The  competitive  nature of the industry and the fact that
 many products are produced under closely held processes make much
 of  the necessary  data  unavailable.

 c.    RTP Study  -  In  December  1978,  EPA's Office  of  Air  Quality
 Planning and  Standards   at   Research  Triangle Park published a
 document  (70)  providing  guidance  on  air   pollution   control
 techniques   for  limiting  emissions of volatile organic compounds
 from the chemical  formulation subcategory of   the  pharmaceutical
 industry.

 As   part    of    this   study,   the  Pharmaceutical   Manufacturers
 Association  (PMA)  surveyed   selected   pharmaceutical   plants  to
 determine   estimates  of   the ten  largest volume volatile  organic
 compounds that  each  company purchased  and the  mechanism by  which
 they  leave   the plant  (i.e.,  sold as  product,  sent  to  the sewer,
 or emitted  as an air pollutant).

 Table V-6 presents a compilation of  the  results  of   this   survey.
 Of   the  twenty-six  reporting  companies,  25  indicated  that  their
 ten  largest  volume volatile organics   accounted   for   80   to   100
percent  of  their  total plant usage.   (The other  company  stated
 that the ten highest  volume   compounds   only   accounted   for  50
percent  of  its total plant usage.)  These  26  companies accounted
for 53 percent of the domestic sales of   ethical  Pharmaceuticals
 in 1975.
                               74

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Included  in  the list of 46 compounds presented in Table V-6 are
seven  priority  pollutants.   These  compounds   are   methylene
chloride,  toluene,  chloroform,  benzene,  carbon tetrachloride,
1,1,1-trichloroethane, and 1,2-dichlorobenzene.

Table V-7 presents a summary and analysis of the data outlined in
Table  V-6.   Priority  pollutants  represent  approximately   27
percent of the total volatile organic usage in the segment of the
industry  analyzed.   However, priority pollutants represent only
13 percent of the total mass discharge of  volatile  organics  to
the  plant  sewers.   This  indicates  a  tighter  control of the
discharge of toxic materials than of other organic materials.

Table V-7 also indicates  that  of  the  total  quantity  of  all
volatile  organic  compounds  discharged,  only  a fraction  (16.7
percent) is discharged via wastewater.  The  priority  pollutants
volatile  organics  are discharged with the wastewater in an even
lower proportion  (9.7 percent).

In  summary,  the  RTF  report  indicates   that   although   the
pharmaceutical  industry  has  a  large involvement with volatile
organic materials,  including  some  toxic  compounds,  there  is
presently  tight  control over their discharge to the environment
via plant sewers.

d    RSKERL/ADA Study - The Robert S. Kerr Environmental Research
Laboratory  at  Ada,  Oklahoma  (RSKERL/ADA)   conducted  for  the
Effluent  Guidelines  Division  (EGD)  an  applied research  study
entitled "Industry Fate Study." (90) The purpose of  this  report
was to determine  the  fate of specific priority pollutants as they
pass  through  a  biological  treatment system.  In the course of
this study, priority  pollutants associated with  the  manufacture
of  Pharmaceuticals at two  industrial facilities were identified.
The results of these  wastewater analysis  are reported in Appendix
K.  These priority  pollutants  are  listed  in  Table  V-8  with
similar   data    from  the   RTF   Study,   Pedco  Reports,  and
Screening/Verification Programs.   RSKERL/ADA  data  are  limited
since  they  are  from only  two  plants.  However, they do serve to
supplement the other  data in Table V-8.

e.   Wastewater   Sampling   Programs  -   Information  on  priority
pollutants  from   the aforementioned  reports and  surveys was
largely  qualitative,  although  the  308 Portfolio did contain  some
quantitative  data.   Moreover,  those   reports  did  not  always
distinguish between pollutants  used by a  plant and pollutants   in
the final  effluent.   To  expand  the data  base the EPA  initiated
the Screening/Verification  Sampling Program under which  a  number
of  plants representing the pharmaceutical  manufacturing  industry
were sampled for  priority   pollutants  and   for  the  traditional
pollutants   (BOD5,  COD,  and   TSS)   in  a two  phase program.   The
                                75

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 first phase,  called the screening phase,  involved 26   plants   and
 covered a broad cross-section of  the industry.   This  was  followed
 by  a  verification phase which limited  the sampling  to only  five
 carefully selected  plants.   Augmentation   of  the  existing   data
 base  with  the  analytical  results  of the Screening/Verification
 Program along with  the  qualitative  information   from the  other
 studies  provided  the   Agency with sufficient information  with
 which to characterize the industry's wastewaters.

 The  screening program was conducted  to determine the  presence  or
 absence  of  important priority pollutants  in the wastewaters  of a
 number of pharmaceutical  plants and   to  provide  a  quantitative
 estimate  of   those present.   The   information was  then used  to
 limit  the search   to   specific   priority  pollutants  for   the
 verification   program   and   to identify plants  likely to provide
 information to accurately characterize the industry wastewaters.

 Major  processing  areas  and  subcategory  coverage,  range    of
 wastewater flows,  and  an assortment  of both in-plant and end-of-
 pipe   treatment   technology/techniques  were used  as  selection
 criteria  for   the  screening plants.  Multiple subcategory plants,
 as well  as plants within  only  one  subcategory, were deliberately
 sought.    Similarly,  special  effort  was made  to  include plants
 with  wastewater flows less than 1000 GPD and more than  2.5   MGD.
 Descriptions   of  the  plants  and  of  the  sampling  points are
 presented  in Appendix O.

 Included  in the screening group  were  nine  direct  dischargers,
 seven   indirect   dischargers,  three  zero i  dischargers and seven
plants which utilized moire than one mode of  discharge.   In  the
 latter   group  there were  three plants that were  both indirect and
zero dischargers, three plants that were  both   direct  and   zero
dischargers  and  one  plant   that  utilized  all   three modes of
discharge.
          Plant ID No.  Subcateqorv
            Plaht ID No.  Subcateqorv
           12015
           12022
           12026
           12036
           12038
           12044
           12066
           12097
           12108
           12119
           12132
           12161
D
AC
C
A
ABCD
AD
BCD
CD
ACD .
AB
AC
ACD
12210
12231
12236
12248
12256
1 2257
12342
12411
1 2420
12439
12447
12462
BC
AD
C
D
ABCD
ABCD
ACD
BCD
BD
CD
ABCD
A
                               76

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           12204
                            ABCD
                                         12999
                                                          CD
The verification program was developed to confirm the presence of
the priority pollutants that were tentatively identified  by  the
screening  program and to provide qualitative pollutant data with
a known precision and  accuracy.   The  analytical  results  from
these  episodes serve as a basis for technology selection and for
use in rulemaking.

Selection of the five plants for  the  verification  program  was
based  in  part  on  general criteria presented in Section II.  A
criterion mentioned earlier and  which  weighed  heavily  in  the
final  selection  process  was  the  assortment of major priority
pollutants  that  were  being  used  as  raw  materials  for  the
manufacture  of  Pharmaceuticals.   Table VI-1 lists the priority
pollutants which appear in the  waste  streams  of  each  of  the
screening plants.  Other plant specific characteristics that were
considered in the final selection process are summarized below on
a plant-by-plant basis.
Plant  No.  12411.   Plant   12411
rxou.u  «w.  .«.~. ..   	  	  was found to have in its waste
streams three of the common priority pollutants for the  industry
—  methylene chloride, chloroform, and toluene.  The presence of
these pollutants,  a process area involving  three  subcategories,
utilization  of  a  solvent  recovery system, and pretreatment of
wastewater followed by aerated lagoon justified  this  plant  for
verification sampling.

Plant  No.  12038.   This  plant was selected for sampling in the
verification  program  because  of  its  use  of  potential   BAT
technology   including   activated   carbon,  aerobic  biological
treatment, and thermal oxidation.  The known presence of  several
priority  pollutants,  including nitrosamines; the existence of a
large historical data base  relating  to  nitrosamines;  and  the
inclusion   of   both   pesticides  and  Pharmaceuticals  in  the
manufacturing operations at the plant were also considered in the
selection process.

Plant No. 12236.  Limitation to one subcategory,  reported  flows
ofabout 0.81 MGD, use of cyanide as raw material, and treatment
of its wastewaters by activated  sludge  process  qualified  this
plant  for  the  verification program.  Also of interest were its
cyanide  destruction  and  solvent  recovery  in-plant  treatment
processes.

Plant  No.  12026.   A  treatment  train  consisting of activated
sludge,  aerated  lagoon,  and  polishing  pond  after   in-plant
treatment  for  solvent  recovery were the reasons this plant was
                                77

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 selected for verification sampling.   It has a  reported  flow  of
 0.101  MGD and belongs in Subcategory C.

 Plant   No.   12097.    Plant 12097  is  a multiple subcategory (C,  D)
 plant  with a reported flow of  0.035  MGD.   Its use of  cyanide  in
 production  and  a  treatment system consisting of in-plant solvent
 recovery,  activated  sludge,  and physical-chemical treatment  were
 considered in selecting  this plant.

 2.   Results of  Screening/Verification Program
A plant-by-plant  summary   of   the   analytical
program  is presented  in Appendix G.
results  from  the
Table V-9  lists  the  traditional and priority  pollutants  that  were
found   in  this program and  the frequency  at which  they were found
to be present in the waste  streams.  Although  a   number  of   the
priority   pollutants appeared in  the waste stream,  only a few of
them were  sufficiently repetitive  to cause  concern.   Pesticides
and  PCBs  were  detected  in one of the plants but  were not due to
pharmaceutical-related activity.

Wastewater entering and   leaving  the   end-of-pipe  wastewater
treatment  train were  among the points  in the waste stream  that
were sampled in  this program.  Concentration  levels  for   many  of
the priority pollutants in  the final effluent are  relatively  low.
The  reasons  for  this  are:  (1) in-plant treatment and process
controls to minimize specific wastewater  pollution  (2)   dilution
of  concentrated process wastewater with other less concentrated
wastewaters and  (3)  incidental removal of some  specific   chemical
pollutants by end-of&pipe treatment.

D.   Wastewater  Flow Characteristics

In  order  to  characterize  the  waste   from  plants    in    the
pharmaceutical   industry,   a determination was  made  from  308  data
of the total industry wastewater  flow  rate  and  its   component
process  subcategory  flows  for direct and indirect dischargers.
Total flow from  plants with data is compared  in Table  V-10   with
the  flows  estimated  for  the subcategories.    These are  based  on
single-subcategory plant total flow adjusted  for   the  number   of
occurrences  for  each  subcategory.   The averages of these flows
are also useful  as base-case flows for cost analysis.

Approximately 70 percent'of the direct and ' indirect  dischargers
(not  including  zero  dischargers)  within   the   308  Data  Base
reported wastewater flows totaling about 80 MGD.  Of this,  about
45  MGD  is from the plants reporting direct  discharges.   A major
factor in both of these flow totals is  the   inclusion  of  Plant
                               78

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12256  which,  due  to  a  mixed discharge of large quantities of
once-through river water, reported a flow of 30 MGD.

Using the reported single-subcategory plant flows as a  means  of
estimating  flow attributable to each subcategory, the plants not
Sporting flow are estimated to add another 13 MGD  (93 MGD  total
estimated discharge flow for the plants in the data base).  Table
V-10  summarizes  reported and estimated wastewater flows for the
industry as represented by the 308 Data Base; this  information is
more comprehensively covered in Appendix J.

E.   Precision and Accuracy Program

The  Precision  and  Accuracy  (P/A)  Study  is   a   fundamental,
continuing  program  to  insure  the  reliability and validity of
analytical   laboratory   techniques.   The  P/A  Program   is   not
utilized  as  a  separate  data  base   in support of the  proposed
limitations, but is  used  primarily  to  substantiate  the  data
illustrated  in Table V-ll.

Precision    refers   to   the   reproducibility   among  replicate
observations.   In  an   Analytical   Quality   Control    Program,
precision   is  determined  not on reference standards, but by the
use  of  actual wastewater samples which   cover  a  wide  range  of
concentrations  and  a   variety  of  interfering materials usually
encountered  by the analyst.

Accuracy  refers to a degree  of difference   between   observed  and
actual  values.   Accuracy   should   also  be determined on actual
wastewater  samples routinely analyzed   and,  preferably,  on  the
same series  as those used  in the precision determinations.

Through  this  process,  data obtained  by analysis  of  multiple
samples were  compared   to   demonstrate  that   (a)   they  Present
clearcut  evidence  that  the  analyst  is  indeed capable of  analyzing
the  samples  for   that particular  parameter   (i.e.,  he has the
standard  method  under  control,  and  is  capable  of  generating  valid
data)  and (b)  the  data can  be used  in  the  evaluation  of   daily
performance  in   reference   to replicate samples, spiked samples,
 and in the preparation of  quality  control charts.

 This type of quality assurance program is applicable to  and  can
 be adapted for all types of analytical procedures.

 TRW  and  Radian  performed on a split-sample basis for EPA a P/A
 study on a series of  24-hour  composite  influent  and ^effluent
 samples  collected  from  a  single  pharmaceutical manufacturing
 plant  (12236)  representing Subcategory  C  (chemical  synthesis).
 Extraction of the non-volatile organic  (NVO) sample for the basic
 recovery  study  was  performed  using  continuous  liquid/liquid
                                79

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 extractors.   Volatile Organics  (VGA)  were  analyzed  using  the
 purge-and-trap   procedure  adopted  for  this  study.    Standard
 spiking levels were used by both  laboratories  as  specified  by
 EPA.    The  extract volumes were selected depending upon expected
 concentration of the priority pollutants in the  sample  and  the
 established   linear response range of the GC/MS instruments.  All
 pollutants detected in the samples are summarized in Table V-l1.

 The   values   reported  by  the  two  laboratories  for    priority
 pollutants   are  well  within  the  detection  limits   of  GC/MS
 analysis,  with the exceptions of methylene chloride,  toluene,  and
 chloromethane.   The values from the  two  laboratories   are  also
 moderately  close  to  each  other.    In  some  cases,   methylene
 chloride,  toluene,  and chloromethane  were present  in  such  high
 concentrations that although reasonable recovery and  quantitation
 could  be  obtained,   the  results are  not   meaningful  due  to
 instrument  saturation.    The  high   levels  present  for   these
 compounds  apparently  did  interfere  with the analysis of other
 priority   pollutants.     Recoveries     of    2,4-dimethylphenol,
 benzidine, and the  phthalates were low and erratic.

 The   detection   of   some   of  the priority pollutants  could be the
 result  of  contamination by sources in the  field  or  laboratory.
 It  is  common practice to  equip  automatic composite samplers with
polyvinyl  chloride  (tygon)  tubing.  Phthalates  are widely used as
plasticizers to  ensure that  the  tubing remains  soft and  flexible.
These compounds  have  a tendency  to migrate to  the surface of the
tubing  and  leach  out   into water   passing   through the sample
tubing.  Results of analysis  shown in  Table  V-n  indicate the
phthalates  vary  between   laboratories.   Sample contamination is
possible  and  therefore,  some  of    the  results   cannot  be
conclusively attributed to the wastewater.
                               80

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                                                             TABLE V  - 1

                                                    SUMMARY OF  LONG TERM DATA
00
PLANT SUBCAT FLOWKGO IHBOD
12015 D
12022 A C
12026 C
12036 A
12097 CO
12098 D
12117 B
12123 CO
12160 D
12161 A CO
12186 CD
12107 C
12236 C
12248 0
12257 ABCD
1229* CD
12307 D
12317 0
12420 B D
12439 CD
12459 0
12462 A
100.93
1440.1
160.58
1092.1
63.99
5. 52
100.66
931.82
29.35
1653.3
37.49
1065
816.12
109.55
754.50
117.55
2.10
739.83
164.23

49.08
208.54
232.64
2141.6
3670
1570.8
1577.3
t
34.50

490.19
1538.9
"
.
741.97
294.44
2961.7
15S4.3

1003.7

^
69.50
1805
EFBOD
9.70
110.24
108.14
33.06
49.39
409.83
1.94
^
166.85
19.78
77.01
707.25
126.17
26.00
228.33
44.68
11.35
7.85
786.80
495.36
3.82
726.61
INBODLB EFBODLB
192.84
25830
4C69.7
14490
844.33
a
26.48
f
77.97
21142
,
t
5149.6
281.31
18750
1537.6
_
5985.6
.
B
18.05
3074.8
7.81
1303.3
135.42
293.61
30.64
12.81
1.73
t
41.80
276.37
27.05
6380.9
666.26
25.47
1439.5
43.66
0.21
43.65
1097.2
,
1.58
1272.6
IHCOD
552.68
.
7334.7
3542.3
1804.8
.
95.41
•
2160.4
4332.6
.
•
2009.7
473.90
a
3429.6
t
1102.3
.
. .
298.86
5168.2
EFCOD INCODLB EFCODLB
43.98
.
1221.8
444.49
37.61
,
24.49
.
516.69
850.24
447.54
«
501.90
95.05
.
232.29
106.39
42.34
.
971.20
112.79
2499.3
462.49
.
9700.6
32358
964.73
.
76.59
*
449.56
59231
.
.
13277
455.16
*
3332.3
.
6887.7
.
.
91.93
8666.5
35.44
•
1644.7
3919.7
20.42
.
20.34
*
137.51
11727
150.19
.
3451.8
90.90
.
228.94
2.13
254.80
. '
.
48.31
4247
IMTSS
123.76
.
87.94
1059.1
•
.
•
•
1615.2
795.94
•
.
.
.
1009.4
«
•
41.35
.
.
58.57
2012.9
EFTSS INTSSLB EFTSSLB
10.76 ~
e'4.85
283.68
78.14
18.11
392 . 08
16.00
•
115.41
31.55
119.25
60.50
61.96
60.42
715.27
59.21
32.30
9.84
966.40
.
16.74
2020.4
102.56
•
113.45
9812.4
•
.
•
.
282.17
10680
.
.
.
•
6306.4
•
.
247.66
•
.
23.71
3308.7
8.67
990.99
377.83
720.71
10.50
16.16
12.81
•
20.27
436.72
40.19
538.05
431.04
59.12
4403.8
60.53
0.60
59.53
1328.7
•
6.74
3391 .8
                                                                                                                          EFCN  EFCNLB
                                                                                                                          0.03
                                                                                                                          0.02
                                                                                                                          0.25
                                                                                                                                  0.02
                                                                                                                                  0.15
                                                                                                                                  1.72
     Note: Influents & effluents in mg/L, LB = LB/DAY.
          Period (.) indicates no data reported.

-------
                            TABLE V-2

        LONG TERM DATA PLANTS SELECTED FOR BCT AND BAT
                                            Long Term Avg. Effluent
Plant No.
12015
12022
12026
12036
12097
12117
12161
12236
12248
12294
12307
12317
12459
Type of Treatment
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
BOD%
Removal
95.8
94.9
97.1
97.9
96.9
94.4
98.7
83.0
91.2
97.2
ND
99.2
94.5
Cone, (mg/1)
BOD
j
110.2
108.1
33.1
49.4
1-9
19.8
126.2
26
44.7
11.4
7.8
3.8
COD
44.0
N/A
1222.0
444.5
37.6
24.5
850.1
501.9
95.9
232.3
106.4
42.3
112.8
TSS
10.8
84.9
283.7
78.1
18.1
16.0
31.6
62.0
60.4
59.2
32.3
9.8
16.7
N/A = Not available
ND  = Not determined
                             82

-------
                           TABLE V-3



           LONG TERM DATA PLANTS SELECTED FOR NSPS
                                            Long Term Avg. Effluent
Plant No.
12015
12036
12097
12117
12161
12248
12294
12307
12317
12459
Type of Treatment
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
BOD%
Removal
95.8
97.9
96.9
94.4
98.7
91.2
97.2
ND
99.2
94.5
Cone, (mg/1)
BOD
9.7
33.1
49.4
1.9
19.8
26.0
44.7
11.4
7.8
3.8
COD
44.0
444.5
37.6
24.5
850.1
95.9
232.3
106.4
42.3
112.8
TSS
10.8
78.1
18.1
16.0
31.6
60.4
59.2
32.3
9.8
16.7
ND = Not determined
                             83

-------
                             TABLE V-4
             LIST OF EPA-DESIGNATED PRIORITY POLLUTANTS
 *No.    Compound                       No.

 IB      acenaphthene                    7OB
 2V      acrolein                       71B
 3V      acrylonitrile                   72B
 4V      benzene                         73B
 5B      benzidine                       74B
 6V      carbon tetrachloride            75B
 7V      chlorobenzene                   76B
 8B      1,2,4-trichlorobenzene          77B
 9B      hexachlorobenzene               78B
 10V     1,2-dichloroethane              79B
 11V     1,1,1-trichloroethane           SOB
 12B     hexachloroethane                81B
 13V     1,1-dichloroethane              82B
 14V     1,1,2-trichloroethane           83B
 15V     1,1,2,2-tetrachloroethane       84B
 16V     chloroethane                    85V
 17B     bis(chloromethyl) ether**       86V
 18B     bis(2-chloroethyl) ether        87V
 19V     2-chloroethylvinyl ether        88V
 20B     2-chloronaphthalene             89P
 21A     2,4,6-trichlorophenol           90P
 22A     parachlorometa cresol           91P
 23V     chloroform                      92P
 24A     2-chlorophenol                  93P
 25B     1,2-dichlorobenzene             94P
 26B     1,3-dichlorobenzene             95P
 27B     1,4-dichlorobenzene             96P
 28B     3,3'-dichlorobenzidine          97P
 29V     1,1-dichloroethylene            98P
 30V     1,2-trans-dichloroethvlene      99P
 31A     2,4-dichlorophenol              10OP
 32V     1,2-dichloropropane             101P
 33V     1,3-dichloropropylene           102P
 34A     2,4-dimethylphenol              103P
 35B     2,4-dinitrotoluene              104P
 36B     2,6-dinitrotoluene              105P
 37B     1,2-diphenylhydrazine           106P
 38V    ethylbenzene                    107P
 39B    fluoranthene                    108P
 40B    4-chlorophenyl phenyl ether     109P
41B    4-bromophenyl phenyl ether      11 OP
42B    bis(2-chloroisopropyl)  ether    11 IP
43B    bis(2-chloroethoxy)  methane     112P
44V    methylene chloride              113P
 Compound

 diethyl phthalate
 dimethyl phthalate
 benzo(a)anthracene
 benzo(a)pyrene
 3,4-benzofluoranthene
 benzo(k)fluoranthane
 chrysene
 acenaphthylene
 anthracene
 benzo(ghi)perylene
 fluorene
 phenanthrene
 dibenzo(a,h)anthracene
 indeno(1,2,3-C,D)pyrene
 pyrene
 tetrachlorethylene
 toluene
 trichloroethylene
 vinyl chloride
 aldrin
 dieldrin
 chlordane
 4,4'-DDT
 4,4'-DDE
 4,4'-ODD
 alpha-endosulfan
 beta-endosulfan
 endosulfan sulfate
 endrin
 endrin aldehyde
 heptachlor
 heptachlor epoxide
 alpha-BHC
beta-BHC
gamma-BHC
delta-BHC
PCB-1242
PCB-1254
PCB-1221
PCB-1232
PCB-1248
PCB-T260
PCB-1016
toxaphene
(lindane)

-------
45V    methyl chloride
46V    methyl bromide
47V    bromoform
48V    dichlorobromomethane
49V    trichlorofluoromethane**
50V    dichlorodifluoromethane**
51V    chlorodibromomethane
52B    hexachlorobutadiene
53B    hexachlorocyclopentadiene
54B    isophorone
55B    naphthalene
56B    nitrobenzene
57A    2-nitrophenol
58A    4-nitrophenol
59A    2,4-dinitrophenol
60A    4,6-dinitro-o-cresol
61B    N-nitrosodimethylamine
62B    N-nitrosodiphenylamine
63B    N-nitrosodi-n-propylamine
64A    peritachlorophenol
65A    phenol
66B    bis(2-ethylhexyl) phthalate
67B    butyl benzyl phthalate
68B    di-n-butyl phthalate
69B    di-n-octyl phthalate
114M   antimony (total)
115M   arsenic (total)
116    asbestos (fibrous)
117M   beryllium (total)
118M   cadmium (total)
119M   chromium (total)
120M   copper (total)
121 ,   cyanide (total)
122M   lead (total)
123M   mercury (total)
T24M   nickel (total)
125M   selenium (total)
126M   silver (total)
127M   thallium (total)
128M   zinc (total)
129B   2,3,7,8-tetrachloro-
        dibenzo-p-dioxin  (TCDD)
   V - volatile organics
   A - acid extractables
   B - base/neutral extractables
   P - pesticides
   M - metals
**   Deleted from the list of priority pollutants as per 46 FR 2264.
                                85

-------
                             TABLE V-5
      SUMMARY OF PRIORITY POLLUTANT INFORMATION: PEDCo REPORTS

Priority Pollutants Identified As Used In;
Subcateqory AT

benzene
chloroform
1,1-dichloroethylene
1,2-trans-dichloroethylene
phenol
copper
zinc
Subcateqory B2

benzene
carbon tetrachloride
1,2-dichloroethane
chloroform
methylene chloride
phenol
toluene
cyanide
lead
mercury
nickel
zinc
Subcateqory C3

benzene
carbon tetrachloride
chlorobenzene
chloroethane
chloroform
1,1-dichloroethylene
1,2-trans-dichloroethylene
methylene chloride
methyl chloride
methyl bromide
nitrobenzene
2-nitrophenol
4-nitrophenol
phenol
toluene
chromium
copper
cyanide
lead
zinc

Total No. of Pollutants:  23

1 Reference No. 42
2 Reference No. 41
3 Reference No. 43
                               86

-------
                 TABLE V-6
COMPILATION OF DATA SUBMITTED BY THE PMA FROM
26 MANUFACTURERS OF ETHICAL DRUGS: RTP STUDY
Type of
Volatile Organic
Compound
Methylene Chloride
Skelly Solvent B'
Methanol
Toluene+
Acetone*
Dimethyl Formamide+
Ethanol
Isopropanol+
Amyl Alcohol"*"
Ethyl Acetate
Chloroform
Benzene"*"
Ethyl Ether
Methyl Isobutyl Ketone+
Carbon Tetrachloride
Xylene+
Methyl Ethyl Ketone
Trichloroethane
Hexane
Amyl Acetate
Isoprbpyl Acetate
Methyl Cellosolve
Butanol+
Isobutyraldehyde
Acetonitrile
Tetrahydrofuran
Isopropyl Ether
Acetic Acid
Acetic Anhydride
Annual Disposition (metric tons)
Annual
Purchase
10,000
1,410
7,960
6,010
12,040
1,630
13,230
3,850
1,430
2,380
500
1,010
280
260
1,850
3,090
260
135
530
285
480
195
320
85
35
4
25
930
1,265
Air
Emissions
5,310
410
2,480
1,910
1,560
1,350
1,250
1,000
775
710
280
270
240
260
210
170
170
135
120
120
105
90
85
40
30
-
12
12
8
Sewer
455
23
3,550
835
2,580
60
785
1,130
1,110
23
350
12
120
510
30
_
165
45
100
30
40
6
-
12
770
550
Incineration
2,060
980
1,120
1,590
4,300
380
915
1,150
480
150
-
1,510
1,910
60
100
230
5
-
_
4
-
-
Contract
Haul
2,180
410
1,800
770
120
200
470
0
80
175
80
30
—
140
™
475
-
130
—
~
•~
-
™
Disposal* Product
5
30 340
2,210
10,000
25 3,090
9
17
90
65
"~ ~"
3
~
-
-
110
•* "*

~
160
410

Solvent
Recovery
73,400
23,850
40,760
31 r\f\
,100
7,570
3,880
76,900
715
1,210
20,500
6^160
9t, f\f\
,400
'
25,670
311 r\
,_>1U
1,840
360
1,040
1 /. c
Llj
125

12
1,040
^00
J\J\J

-------
                                                   TABLE V-6
                                                     (Cont'd)
00
oo
Type of
Volatile Organic
Compound
Dimethylacetamide
Formaldehyde
Dimethylsulfoxide
1,4-Dioxane
o-Dichlorobenzene
Diethyl Carbonate
Blenda (Amoco)
Ethyl Bromide
Cyclohexylamine
Methyl Formate
Formamide
Ethylene Glycol
Diethylamine
Freons
Diethyl-ortho Formate
Pyridine
Polyethylene Glycol 600
Annual Disposition (metric tons)
Annual
Purchase
95
30
750
43
60
30
530
45
3,930
415
MO
60
50
7,150
54
3
3
Air
Emissions
7
5
4
2
1
1
_
_
_
_
_
_
50
6
_
_ -
-
Sewer Incineration

20
210 535
_ _
60
20
_ _
45
_ _
310
290
60
3
_
21
3 -
-
Contract
Haul
90
_
_
41
_
_
_
_
_
50
110
_
_
_
_
_
-
Disposal* Product

1
— —
— _
— —
7
530

3,930
60
30
_ _
_ _
7,145
33
— _ ' ~
3
Solvent
Recovery

«•>
4,760
—
7,060

«
7,170

1,130
_
60
300
_
«
_
_
     TOTALS
85,170
19,190   14,880
17,480
7,350
72
                                                                                             27,700  441,320
    Source -  26  member companies of the Pharmaceutical Manufacturers  Association (PMA) reported these data
             which they feel represent 85 percent of the volatile organic compounds used in their operations; these
             reporting companies caccount for approximately  53  percent  of  the 1975 domestic sales  of  ethical
             Pharmaceuticals.

    *Deepwell or landfill.

    +Annual disposition does not closely approximate annual purchase.

-------
                             TABLE V-7
 SUMMARY OF VOLATILE ORGANIC COMPOUND EMISSION DATA:  RTP STUDY
                                                  Amount:
Item;

Amount purchased  (metric tons)
Amount discharged  (metric tons)
Amount recovered within the
  plant (metric tons)
Total amount used  in plant
  (sum of items 1  and 3)
  (metric tons)
Percent recovered
Percent of total used that is
  discharged
Percent of total used that is
  discharged to sewer
Percent of total discharged that
  is discharged to sewer
    Total
  Compounds
(total of 46)
  85,170
  86,142
 441,320

 526,490

   83.8%
     16%

    2.7%

   16.7%
   Priority
  Pollutants
(total  of  7)
   19,565
   19,595
  126,020

  145,585

    86.6%
    13.5%

     1.3%

     9.7%

-------
Priority
Pollutant
                   TABLE V-3
 SUMMARY OF MAJOR* PRIORITY POLLUTANTS IDENTIFIED
      FROM MULTIPLE SOURCES OF INFORMATION
                                 :            Screening  6
            RTP   PEECo  RSKERL/  308        Verification
	Study  Reports ADA   Portfolio   Sampling Program
Acid Extractables
65  Phenol                             X

Ease Extractables
25  1,2-Dicblorobenzene         X

Volatile Crqanics
4   Benzene                     X      X
6   Carbon Tetrachloride        X      X
11  1,1,1 - Trichloroethane     X
23  Chloroform                  X      X
29  1,1-Dichloroethylene               X
30  1,2-Trans-Cichloroethylene         X
38  Ethylbenzene
44  Methylene Chloride          X      X
86  Toluene                     X      X
                                  X
                                  X

                                  X
                                  X
                                  X
X
X
X
                                                X
                                                X
                                                X
                                                X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
X
X
X
X
X
X
Ketals
119 Cfaroiriurr
120 Copper                             X
122 Lead                               X
123 Mercury
124 Nickel
128 Zinc                               X

ethers
121 cyanide                            XXX          X

*    For  this  table  toxic  compounds  were  defined as "major"
priority pollutants in accordance with the following criteria for
each data source:

B1P - The pollutant was reported by at least one plant  (26 plants
reporting)
EEDCo - The pollutant was found in two or more subcategories  (130
plants studied).                                     i
BSKERL/ADA - The pollutant was reported by at least one  plant   (2
plant study).
308  -  The  pollutant  was  identified by 25 or more plants  (464
plants surveyed).
Screening/Verification - The pollutant was  detected  at ten   or
irore plants  (26 plants sampled) .
                                    90

-------
                            TARLE V-9

      ANALYSIS OF PRIORITY POLLUTANT CONCENTRATIONS (ug/1)
                Screeninq/Ver1fication Data Rase
Influent
Rased on Values Equal to or
Priority Pollutant Nui
Acid
?1
24
31
34
57
58
60
64
65
Rase
1
25
27
35
42
54
62
66
P
Extractahles
2,4, 6-tri chl orophenol
2-chl orophenol
2,4-dichlorophenol
2, 4-dimethyl phenol
2-nitrophenol
4-nitrophenol
4,fi-dinitro-o-cresol
pentachl orophenol
phenol
Neutrals
acenaphthene
1 , 2-di chl orobenzene
1,4-dichlorobenzene
2,4-dinitrotoluene
bis( 2-chl oroisopropyl )
ether
isophorone
N-nitrosodi phenyl amine
bis(2-ethylhexyn
Greater than (10 uq/1 1
Tiber of Number of
lants Observations Minimum Maximum
1
1
1
1
2
2
1
2
20
2
2
1
1
2
2
1
8
1
1
1
1
2
2
1
2
36
2
2
1
1
2
2
1
10
20
50
10
62
23
181
1,5
42
12
35
12
90
68
300
11
12
10
20
50
10
62
119
1600
15
62
51,000
92
20
90
68
448
1014
12
760
Median Mean
20
50
10
62
71
891
15
52

64
16
90
68
374
513
12
105
20
50
10
62
71
891
15
52
7529
64
16
90
68
374
513
12
157
Standard
Deviation

•
•
*
68
1003
•
14
15,499
40
6
.
.
150
709
•
222
                                              91

-------
67
68
70
78
80
81
butyl benzyl phthalate
di-n-butyl phthalate
diethyl phthalate
anthracene
fluorene
phenanthrene
3
4
1
1
1
1
3
4
1
1
1
1
Volatile Orqanics
4
6
7
10
11
14
15
23
29
33
38
<((*
15
47
49
£5
86
87
benzene
carbon tetrachloride
chlorofcenzene
1 , 2-dichloroethane
1,1, 1-trichloroethane
1,1,2-trichloroethane
1,1,2,2-tetrachloro-
ethane
chloroform
1» 1-dichloroethylene
1,3-dichloropropylene
ethylbenzene
irethylene chloride
srethyl chloride
brornoform
trichlorof luorcmethane
tetrachlcroethylene
toluene
trichloroethylene
11
3
4
8
8
2
1
14
1
1
9
18
2
1
1
8
14
2
19
5
6
17
11
2
1
22
1
1
18
31
4
2
1
4
29
2
12
18
61
14
27
14
15
12
11
12
17
19
20
26
230
100
719
20
61
14
! 27
14
10,300
I 300
123,000
14,000
: 1,300
: 20
20
1620
230
' 100
18
20
61
14
27
14
120
18
3206
62
22
20
20
170
230
100
250
19
61
14
27
14
1586
81
36,405
2516
169
20
20
396

100
406
1
.
»
•
<*
3186
124
55,025
4944
383
1
0
470
.
•
        11  42,000     24  3237  10,020



        16 200,000        11,356 37,952



        59  13,000  8,600  7,565  5,439



        12      12    1.2     12



       970  >   970    970   970



        14      36     31    28      10



        50 227,000   310  21,075 50,223



        11  ,   124     68    68      80
92

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88   vinyl chloride
Metals
114  antimony
115  arsenic
118  cadmiutr
119  chromium
120  copper
122  lead
*123 irercury
124  nickel
125  selenium
126  silver
127  thallium
128  zinc
ether
121  cyanide
130  ECD{mg/l)
131  COD (rag/1)
132  1SS(mg/l)
                                                    14
                                                                  14
                                                                         14
8
4
4
18
21
9
16
11
4
2
2
20
8
18
18
15
9
4
5
30
39
13
31
19
5
2
3
37
16
33
33
31
12
13
10
13
14
14
0.1
15
16
24
18
29
18
98
128
10
210
43
40
650
7030
500
0. 1
630
60
40
43
2070
540
11,300
25,900
3,480
27
31
32
39

63

39
28
32
40

140
1,090
2,641
218
45
29
25
117
571
119
3.9
103
31
32
34
363
153
2, 183
3,994
649
62
12
14
155
1689
139
9.6
146
17
11
14
475
135
2,688
4,868
837
                                              93

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Effluent

Priority Pollutant


acid Extractahles
Number of  Number of                              Standards
 Plants  Observations Minimum Maximum Median Mean Deviation
34
58
65
Ease
42
66

68
70
eo
2, 4-dirr.ethylphenol
4-nitrophenol
chenol
Keutral
bis (2-chloroisopropyl)
ether
bis (2-ethylhexyl)
phthalate
di-n-butyl tbtbalate
diethyl phthalate
fluorene
1
1
9

1
6

2
2
1
1
1
12

1
9

2
2
1
15
15
10

181
10

10
10
10
15
15
i
126

181
68

15
20
10
15
15
23

161
30

13
15
10
15
15
47

181
36

13
15
10
.
46

-
21

4
7
.
Volatile Organics
2
4
6
10
11
23
29
38
44
45
acrolein
benzene
carbon tetrachloride
1 ,2-dichloroethane
1,1, 1-trichloroethane
chloroform
1, 1-dichloroetyhlene
ethylbenzene
irtbylene chloride
aethyl chloride
1
1
2
5
4
6
1
3
14
2
1
1
2
9
6
7
1
3
21
4
100
120
16
22
10
14
180
14
12
100
100
i
120
61
500
33
150
180
22
8100
410
100
120
39
62
20
90
130
17
120
310
100
120
39
158
21
79
180
18
863
283
«
»
32
169
11
55
•
4
1852
139

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49   trichlorof luororrethane  1
85   tetrachloroethylene
66   toluene
67   tr.ichloroethylene
BetaIs
114  antimony
115  arsenic
118  cadmium
119  chromium
120  copper
122  lead
*123 mercury
124  nickel
125  selenium
126  silver
127  thallium
128  zinc
Cther
121  cyanide
**130  BOD
**131  COD
**132  TSS
*A11 non-remarked data considered
**Expressed in mg/1
1
1
4
1
2
3
1
13
13
9
11
8
2
1
2
17
6
13
13
13
1
1
4
1
5
6
1
21
25
14
19
16
5
1
5
32
11
25
30
29
420
18
100
14
20
10
40
10
14
13
0.1
19
12
40
10
13
30
10
216
0.1
420
18
315
14
51
20
40
304
106
400
1.3
300
56
40
129
2009
7700
1090
3293
1200
420
18
185
14
31
12
40
27
31
33
0.7
51
45
40
11
118
100
84
528
88
420
18
196
14
34
13
40
77
38
64
0.7
83
42
40
37
240
827
155
911
237
•
-
89
•
15
4
-
94
24
100
0.5
31
18
-'
52
378
2282
211
921
338

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                           TABLE V-10
           ANALYSIS OF WASTEWATER FLOW CHARACTERISTICS
                         (BASIS:  308 DATA)

Direct Discharger Flow (All plants reporting data)
      (Without Inclusion  of Plant 12256)

Indirect Discharge Reporting Flow (178 plants)

      Total Flow Reported

Total Single Subcategory Flow/No, plants  (with data)
Subcat.
Subcat.
Subcat.
Subcat.
A
B
C
D
1 .
0.
8.
9.
30/3
67/15
80/34
80/131
=
=
=
=
0.435
0.045
0.260
0.075
                                       45 MGD
                                         (15)

                                         35

                                         80 MGD
Indirect Discharger Estimated Flow for Non-Reporting Plants
     Subcat. A
     Subcat. B
     Subcat. C
     Subcat. D
0.435 X 5  occurrences
0.045 x 16 occurrences
0.260 x 14 occurrences
0.075 x 90 occurrences
=
=
Estimated Unreported Flow

Total Discharge Flow Estimated for Data Base
     (Without Inclusion of Plant 12256)
2.175 MGD
0.72
3.64
6.75
                                         13

                                         93 MGD
                                         (63)
                               96

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                                                         TABLE V- 11

                              COMPARISON OF PRECISION & ACCURACY (P&A) DATA - PLANT 12236
                                                                                             of Other Data Sources
  Priority Pollutants (ug/1)
Volatile Organics
 44V Methylene Chloride
 86V Toluene
 45V Methyl chloride
 23V Chloroform
  4V Benzene
 10V 1,2-Dichloroethane
 30V Trans- 1,2-Dichloroethylene
 38V Ethylbenzene
 49V Trichlorofluoromethane
 29V 1,1-Dichloroethylene
 13V 1,1-Dichloroethane

 Acid Extractables
 65A Phenol
 24A 2-Chlorophenol
  57A 2-Nitrophenol
  34A 2,4-Dimethylphenol
  21A 2,4,6-Trichlorophenol
  64A Pentachlorophenol

 Base/Neutral Extractables
  42B Bis(2-chloroisopropyOether
  36B 2,6-Dinitrotoluene
  56B Nitrobenzene
  35B 2,4-Dinitrotoluene
  70S Diethyl phthalate
  68B bi-N-Butyl phthalate
  67B Butyl benzyl phthalate
P&A Sample Analyses
Radian
Influent Effluent
916,000
24,000
33,000
24-29
7-9
57-83
4-6
19-25
ND
ND
ND
6-7
ND
ND
ND
ND
ND
• ND
ND
ND
ND

1
ND
-
-
-
-
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
—
1
ND

TRW
Influent Effluent
22,000
36,000
18,000
17-21
4
51-56
2
12-13
7
9-12
1
9-10
ND-2
ND
ND
T
T-l
ND
1-4
ND-T
ND
ND
12-13
ND
2-3
T
13
T
T
ND
ND
ND
T-l
T
T-l
ND-1
1
T
ND-1
T
3
2
1
13-25
1
*^on
Screening
Influent Effluent
40,000 200
33,000 1350
1,300
30
40
12
190







i






ipartauii m. v»m«^ ^—-— — — 	
Verification 30s
Influent
14,000-80,000
56,000-71,000
8,000-13,000
10
10-27
68-650
10-12
10-16














Effluent
15,000-8,100
10 reported as used
100,410
10
10 reported as used
62-300
10
10














 ND = not detected
 T  = trace or less than 1
 -   = no data

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 A.
                      SECTION VI

           SELECTION OF POLLUTANT PARAMETERS

INTRODUCTION
 The  priority    (toxic)   and   traditional    (conventional   and
 nonconventional)   pollutants  characterized   in  Section  V  are
 discussed in  this  section  in  light  of  their  occurrence  in
 pharmaceutical   industry  wastewaters  and  their  effects on the
 environment.

 B.   TRADITIONAL POLLUTANTS

 The  Clean  Water  Act  of  1977  (P.L.  95-217)   requires   the
 Administrator to establish effluent limitations and standards for
 traditional pollutants.  Among these, the conventional parameters
 of biochemical oxygen demand (BOD),  total suspended solids (TSS),
 pH,  and  oil  and  grease  and the nonconventional parameters of
 chemical oxygen demand (COD),  total  organic carbon (TOO,  color,
 ammonia,  nitrogen, and phosphorus were considered.   Those chosen
 as representative of specific and persistent  pollution  problems
 across the industry were BOD,  TSS,  COD and pH.

 These  pollutant parameters  were identified in 100 percent of  the
 plants  for   which  data  were   obtained.    Pollutant  levels   in
 treatment  influent and untreated effluent streams are frequently
 high,  particularly in  Subcategories  A  and  C   (fermentation   and
 synthesis, respectively).

 Other   conventional parameters  subject   to regulation under  the
 Administrator's  discretion are  oil   and  grease,   pH,   and fecal
 coliform.    Although   they  do   appear  as problems  in some plant
 process wastewater, oil  and  grease is not  sufficiently widespread
 nor severe enough to justify regulation.   Fecal coliform  is   not
 of  significance  in   the  industrial wastewater effluents of this
 industry.  Similarly,  the  nonconventional   parameters   of  color,
 phosphorus   and   various   forms of  nitrogen   are  not judged to
 present a frequent  enough  problem to justify regulation.   TOC  is
 considered   to be so closely related to BOD and COD that separate
 attention is not necessary.  The BPT pH range  (6.0 - 9.0)  will be
 continued in all  other direct discharge regulations.

 1.  Biochemical  Oxygen Demand

BOD is  the quantity of oxygen required  for  .the  biological  and
 chemical oxidation of waterborne substances under ambient or test
conditions.   Substances   that  may contribute  to the BOD  include
carbonaceous organic materials usable as a food source  by aerobic
organisms; oxidizable nitrogen derived  from  nitrites,  ammonia,
                               98

-------
and  organic  nitrogen  compounds that serve as food for specific
bacteria; and such chemically  oxidizable  materials  as  ferrous
iron,  sulfides,  sulfite,  and  similar reduced-state inorganics
that will react with dissolved oxygen or that are metabolized  by
bacteria.

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.  Total exhaustion of
the dissolved oxygen in water results in anaerobic conditions and
the  production of such undesirable gases 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 may degrade water quality and minimize potential uses of the
water.   This  organic  material  promoting  a  high BOD can also
increase algal concentrations and cause blooms.

The BOD5 (5-day BOD) test is widely used to estimate  the  oxygen
requirements  of  domestic  and  industrial wastes and to evaluate
the performance of waste  treatment facilities.  To test for  BOD,
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.
Despite  its relative complexity, this test  is widely accepted for
measuring potential pollution because it is  the  best  available
method   for  evaluating   the deoxygenation  effect of a waste on  a
receiving water body.

The BOD  test measures the weight of dissolved oxygen utilized  by
microorganisms  as they oxidize  or transform the gross mixture of
chemical compounds in the wastewater.  The  degree of  biochemical
reaction involved  in the  oxidation of carbon compounds  is  related
to  the  period of incubation.   BOD5  normally measures only  60 to
80 percent of  the  total carbonaceous  biochemical oxygen demand of
the  sample, but, for most purposes, this  is a reasonable estimate
of ultimate BOD.

When  measuring BOD  either   by  the Winkler   dissolved  oxygen
titration  method  or by the dissolved oxygen probe  determination,
measured BOD at lower levels   of  approximately  2  mg/1   give   a
deviation  of   about  ±33 percent  even   under  the most  careful
laboratory  conditions.  At higher  concentrations (above  100  mg/1,
for  example),  the  deviation  is about  ±15  percent.
                                99

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 2-  Total Suspended Solids

 Suspended solids in wastewater are  normally  measured  as  total
 suspended  solids.   They  can include both organic and inorganic
 materials.  The inorganic materials may include sand, silt, clay,
 and, possibly, toxic metal compounds.  The organic  fraction  may
 include  such  materials  as  grease,  oils, animal and vegetable
 waste products, fibers, microorganisms (algae, for example),  and
 many  other  dispersed insoluble organic compounds.  These solids
 may settle rapidly and form bottom  deposits  that  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;  they  may  be
 slowly   biodegradable   materials;   or   they  may  be  rapidly
 decomposable substances.   While in suspension, they increase  the
 turbidity  of  the  water,   reduce light penetration,  and thereby
 impair the. photosynthetic  activity  of  aquatic  plants.    After
 settling  to  the  stream or lake bed,  the solids can form sludge
 banks which,  if largely organic,  create localized dead  areas  in
 the  water  body  and result in anaerobic and undesirable benthic
 conditions.    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,  by  screening light,  and  by  promoting  and
 maintaining  the development of noxious conditions through oxygen
 depletion.   Suspended solids also reduce the  recreational  value
 of  the water.
                                            i
 The  precision  of  the TSS  determination  varies  directly with the
 concentration of suspended  matter in  the  sample.   At  15  mg/1,  the
 deviation  is  shown  to  be  ±33  percent; at  242 mg/1,  the  deviation
 is  ±10 percent;  and at 1707  mg/1,  the deviation  is ±0.76 percent.
 There   is   no satisfactory  procedure  for  determining  the accuracy
 of  the TSS method on wastewater samples  since  the true  initial
 concentration cannot be determined.

 3.  Chemical  Oxygen Demand
                                            i
 COD   is  a chemical oxidation  test  devised as  an alternate method
 of estimating  the total oxygen demand of a wastewater.   Since  the
 method relies  on   the  oxidation-reduction  system  of  chemical
 analyses  rather  than on biological factors,  it is more precise,
 accurate, and  rapid than the BODS test.  The COD test  is  widely
 used to estimate the total oxygen demand  (ultimate rather  than 5-
day  BOD)  required to oxidize  the  compounds in a wastewater.  It
 is based  on   the   fact  that  with  the  assistance  of   certain
 inorganic  catalysts, strong chemical oxidizing agents under acid
conditions can oxidize most organic compounds.
                               100

-------
The COD test measures organic matter that exerts an oxygen demand
and that may affect public health.  It  is  a  useful  analytical
tool  for pollution control activities.  Most pollutants measured
by the BOD5 test can be measured by the GOD test.   In  addition,
pollutants  more  resistant  to biochemical oxidation can also be
measured as COD.  COD is  a  more  inclusive  measure  of  oxygen
demand  than BOD5 and results in higher oxygen demand values than
BOD5.

The COD of a wastewater normally exceeds BOD5 since it is usually
constituted of those materials contributing to the BOD level plus
those   more   resistant   to   biochemical   oxidation.    ^^
consideration  of  COD  and  BOD  measurements  can  indicate the
relatively biodegradability of the pollutants and the  levels  of
the chemical pollutants not easily bio-oxydized.  The correlation
between  the COD and BOD concentrations in a specific plant waste
resulting from a particular operation  is applicable only to  that
waste.  Furthermore, the level of organic pollutants as indicated
by  COD  do  not  correlate with the level of individual priority
pollutants.

Compounds more resistant to biochemical oxidation  are  of  great
concern  because  of  their slow, continuous oxygen demand on the
receiving water and also because  of   their  potentially  harmful
effects  on the health of humans and aquatic life.  Many of these
compounds  result  from  industrial  discharges;  some   of   the
compounds  have  been  found to have carcinogenic, mutagenic, and
similar adverse  effects.   Concern  about  these  compounds  has
increased  as  a result of demonstrations that their long life  in
receiving waters  (the result of a low  biochemical oxidation rate)
allows  them  to  contaminate  downstream  water  intakes.    The
commonly  used systems of water purification are not effective  in
removing these  types  of  materials   and  such  disinfection   as
chlorination may convert them  into even more hazardous materials.

The  COD  test  when performed by the  dichromate reflux procedure
will  account for  95  to  100 percent of  the theoretical values  for
most  organic compounds.  However, there are some compounds of the
aromatic  family   (benzene,  toluene,  and pyridine, for  example)
that  are not oxidized by this  procedure.

C.   PRIORITY POLLUTANTS

The frequency  and  level of priority  pollutant  occurrence   in  the
wastewaters of  the  industry  were  considered  in order to determine
the  manner   in  which  these  pollutants  might be  regulated.  The
diversity  of process and  materials  employed  by   the   industry
brings  about   a   broad presence,   with   virtually  every   toxic
pollutant   compound  listed    in    the   modified    comprehensive
settlement  agreement   present  in   at least  one plant.   However,
                                101

-------
none are present  in the effluent  in all
part of the industry.
or  even  a  predominant
Under  the  provisions of Paragraph 8 of the Settlement Agreement
in Natural Resources Defense Council, Inc. v. Train, 8  EEC  2120
(D.D.C.  1976),  modified  12  ERC  1833   (D.DTcT1979)   (1)(2)
guidance is provided to  the  Agency  on  exclusion  of  specific
priority    pollutants,   subcategories,   or   categories   from
regulations under the effluent limitations guidelines,  standards
of  performance  and  pretreatment  standards.  This paragraph is
excerpted below:

     "8(a)   The Administrator may exclude from  regulation  under
     the   effluent  limitations  and  guidelines,  standards  of
     performance, and/or pretreatment standards  contemplated  by
     this   Agreement   a   specific  pollutant  or  category  or
     subcategory of  point  sources  for  any  of  the  following
     reasons,  based upon information available to him:

     (i)     For  a  specific  pollutant   or  a   subcategory   or
     category,   equally  or   more stringent protection is already
     provided   by  an  effluent,   new source   performance,    or
     pretreatment  standard   or  by  an   effluent  limitation and
     guideline  promulgated pursuant to Section(s)  301,  304,   306
     307(a), 307(b)  or  307(c)  of  the Act;

     (ii)    For a specific pollutant,   except   for  pretreatment
     standards,  the  specific  pollutant is present  in the  effluent
     discharge   solely   as  a  result  of   its presence in  intake
     waters  taken from  the same body of  water  into  which   it  is
     discharged  and,   for  pretreatment standards,  the  specific
     pollutant  is present  in  the   effluent  which   is  introduced
     into  treatment  works (as  defined in Section  212 of  the  Act)
     which are  publicly owned solely as  a result of its presence
     in  the point source's intake waters, provided however,  that
     such point  source may be subject  to an appropriate effluent
     limitation   for  such pollutant pursuant to the  requirements
     of Section  307;

     (iii)  For   a  specific  pollutant,   the  pollutant  is  not
    detectable   (with  the  use   of  analytical methods approved
    pursuant to  304(h)  of  the  Act,  or  in  instances  where
    approved  methods  do  not exist, with the use of  analytical
    methods which represent state-of-the-art capability) in  the
    direct  discharges  or in the effluents which are  introduced
    into publicly-owned treatment works  from sources within  the
    subcategory  or  category;  or is detectable in the effluent
    from only  a small number of sources  within  the  subcategory
    and the pollutant is uniquely related to only those sources;
    or  the pollutant  is  present only in trace amounts and is
                              102

-------
    neither causing nor likely to cause  toxic  effects;  or_ is
    present  in  amounts  too small to be effectively reduced by
    technologies known to the Administrator;  or  the  pollutant
    will  be  effectively  controlled  by  the technologies upon
    which are based other effluent limitations  and  guidelines,
    standards of performance, or pretreatment standards; or

    (iv)    For  a  category  or subcategory, the amount and the
    toxicity of each pollutant in the discharge does not justify
    developing  national  regulations  in  accordance  with  the
    schedule contained in Paragraph 7(b).

    (b)     The  Administrator may exclude from regulation under
    the pretreatment standards contemplated  by  this  Agreement
    all  point  sources  within a point  source category or point
    source  subcategory:

    (i)     If 95 percent or more of all  point  sources   in  the
    point   source   category   or  subcategory   introduce   into
    treatment works  (as defined  In Section  212 of  the Act) which
    are publicly owned only pollutants which are  susceptible  to
    treatment by such treatment works and which do not  interfere
    with,  do not pass through, or  are not otherwise incompatible
    with  such treatment works; or

     (ii)     if   the  toxicity  and  amount   of  the incompatible
    pollutants  (taken together)  introduced  by  such P°injusou^ces
     into  treatment works  (as defined  in  Section  212 of  the  Act)
     that   are   publicly   owned  is  so   insignificant   as not  to
     justify developing  a  pretreatment  regulation..."

     Pollutants  Excluded from Direct  Discharger Regulations

Table  VI-1  lists the  occurrence,,  frequencies and levels found  in
the screening plant data for the  priority pollutants addressed by
the  Consent Decree.   The priority pollutant data provided in the
308 data base was used to help develop the group of plants  which
were  then screened for  priority pollutants.  However,^these data
were not used  to  support  Paragraph  8  exclusion  of  priority
pollutants  found  in  the  S/V  study  because  many  of the 308
priority  pollutant   responses   were   incomplete _ or..  •?*.  J
non-quantitative  nature.    This was due in part to the fact that
many plants have not performed a priority pollutant scan of their
wastewater.  The 308 priority pollutant data were used to exclude
those which were uniquely related to individual sources or  occur
as the result of non-pharmaceutical operations.

Compounds  numbered  17B, 49V, and 50V have  been deleted^by 46 FR
10723 and 46 FR 2266.  The remaining list of priority  pollutants
was considered under the individual subparagraphs of Paragraph 8.
a.
                               103

-------
  The   compounds   that   can   be   excluded   under each  provision  are
  tabulated  in  Tables VI-2 through  VI-5, with  those  which   can   be
  excluded   by  more  than one provision being noted by  an  asterisk
  (  ''.  In addition a few pollutant compounds  can be  excluded   bv
  combinations  of  provisions  (Table VI-5).

  Table  VI-2 lists compounds whose incidental  removal is likely  to
  be  brought   about  by  technologies  instituted  to   meet  other
  limitations.     A    significant  example    is   phenol   whose
  biodegradability makes it likely  that substantial removal will  be
  accomplished  by  activated  sludge,  aerated   lagoons,  or  other
  biological  treatment  systems  targeted  for   BOD  removal.  Air
  strippable volatiles are also likely to be removed by  the passage
  of aeration air and high surface  atmospheric exposure.

  Table  VI-3   lists   pollutants   with   levels   of   occurrence
  insufficient  to justify regulation.  Some are present at no more
  than trace amounts (  at or below  the detection  limits)  and others
 at levels below or essentially the same as  removal  capabilities
 of  applicable  technologies.    Those  compounds  with  sufficient
 volatility and low solubility to be  effectively  steam  stripped
 can  be  removed  to   no  better than about 50-100  micrograms per
 liter Ug/1).   Earlier consideration by the'Agency   (98)   of  the
 treatability  of  a   number   of  the  more  significant  priority
 pollutants  indicates  the following typical treatability criteria
 expressed on a 5-day  maximum basis:
             8B 1,2,4-Trichlorobenzene
            11V 1,1,1-Trichloroethane
            13V 1,1-Dichloroethane
            23V Chloroform
            25B 1,2-Dichlorobenzene
            26B 1,3-Dichlorobenzene
            27B 1,4-Dichlorobenzene
            44V Methylene  Chloride
            55B Naphthalene
            86V Toluene
             4V Benzene
            69B Di-n-Octyl Phthalate
 50-100
500-600
500-600
500-600
400-500
400-500
400-500
    500
400-500
    400
    400
    100
Metals removal effectiveness  is  indicated  in Table VI1-2    Table
VI-3 shows the priority pollutants which were excluded based on a
comparison  of  these  treatability  levels  with  the  screening
verification effluent data in Appendix G.

Also included in Table VI-3 are  a  number  of  phthalates  whose
presence is likely the result of sample contamination by sampling
equipment.
                              104-'

-------


                    those pollutants which are present in amounts
                               -          t
s



plants at treatable levels.
The one priority pollutant  detected   at   sufficient   levels  and
?reqSency control by direct dischargers  is cyanide.
b.   Pollutants  Excluded  from   Regulation  under   Pretreatment
Standards
        u,   o/i^   (n\   of  i-he Settlement Agreement allows for the









 discharging pharmaceutical plants.
                                105

-------
                  TABLE VI-1

SUMMARY OF PRIORITY POLLUTANT OCCURRENCE

            SCREENING PLANT DATA
                         No. of Occurrences
Detected i

No.*
IB
2V
3V
4V
5B
6V
7V
8B
9B
10V
11V
12B
13V
14V
15V
16V
17B***
18B
19V
20B
21A
22A
23V
24A
25B
26B
27B
28B
29V
30V
31A
32V
33V
34A
35B
36B
37B
38V
39B

Compound
acenaphthene
acrolein
acrylonitrile
benzene
benzidine
carbon tetrachloride
chlorobenzene
1,2,4-trichlorobenzene
hexachlorobenzene
1,2-dichloroethane
1,1, 1-trichloroethane
hexachloroethane
1, 1-dichloroethane
1 , 1 ,2-trichloroethane
1,1,2,2-tetrachloroethane
chloroethane
bis(chloromethyl) ether
bis(2-chloroethyl) ether
2-chIoroethylvinyl ether
2-chloronaphthalene
2, 4, 6-trichlorophenol
parachlorometa cresol
chloroform
2-chlorophenol
1 , 2-dichlorobenzene
1 , 3-dichlorobenzene
1 , 4-dichlorobenzene
3,3'-dichlorobenzidine
1, 1-dichloroethylene
1-2-trans-dichloroethylene
2, 4-dichlorophenol
1 ,2-dichloropropane
1 , 3-dichloropropylene
2, 4-dimethylphenol
2,4-dinitrotoluene
2, 6-dinitrotoluene
1,2-diphenylhydrazine
ethylbenzene
fluoranthene
Influent
(25)**
4 (16%)


15 (60%)
1 (4%)
3 (12%)
5 (20%)


5 (20%)
8 (32%)

4 (16%)
4 (16%)

2 (8%)

1 (4%)


1 (4%)

16 (64%)
1 (4%)
2 (8%)

1 (4%)

5 (20%)
1 (4%)



1 (4%)
2 (8%)
1 (4%)
1 (4%)
12 (48%)

Effluent
(20)**



3 (15%)

1 (5%)



4 (20%)
4 (20%)


1 (5%)



1 (5%)




9 (45%);





2 (10%)




1 (5%)
1 (5%)


2 (10%)

Above 500
ug/L in
Effluent (20)**









1





























                                                    Max. Effluent
                                                       Level
                                                    	ug/L
                                                         120

                                                         16
                                                        500
                                                         33
                                                         20
                                                        110
                                                        180
                                                         15
                                                        160
                 106

-------
TABLE VI-1 (continued)
              No. of Occurrences
Detected

No.*
40B
41B
42B
43B -
44V
45V
46V
47V
48V
49V***
50V***
51V
52B
53B
54B
55B
56B
57A
58A
59A
60A
61B
62B
63B
64A
65A
66B
67B
68B
69B
7 OB
71B
72B
73B
74B
75B
76B
77B
78B
79B
SOB
81B
82B

Compound
4-chlorophenyl phenyl ether
4-bromophenyl phenyl ether
bis(2-chloroisopropyl) ether
bis(2-chloroethoxy) methane
methylene chloride
methyl chloride
methyl bromide
bromoform
dichlorobromomethane
trichlorofluoromethane
dichlorodifluoromethane
chlorodibromomethane
hexachlorobutadiene
hexachlorocyclopentadiene
isophorone
naphthalene
nitrobenzene
2-nitrophenol
4~nitrophenol
2,4-dinitrophenol
4,6-dinitro-o-cresol
N-nitrosodimethylamine
N-nitrosodiphenylamine
N-nitrosodi-n-propylamine
pentachlorophenol
phenol
bis(2-ethylhexyl) phthalate
butyl benzyl phthalate
di-n-butyl phthalate
di-n-octyl phthalate
diethyl phthalate
dimethyl phthalate
benzo(a) anthracene
benzo(a) pyrene
3, 4-benzof luoranthene
benzo(k) fluoranthane
chrysene
acenaphthylene
anthracene
benzo(ghi) perylene
fluorene
phenanthrene
dibenzo(a,h) anthracene
Influent
(25)**

3 (1296)

17 (68%)
1 (496)
1 (4%)
1 (4%)






2 (8%)
1 (4%)
1 (4%)
3 (1296)
3 (12%)



1 (4%)

2 (8%)
14 (56%)
10 (40%)
2 (8%)
3 (12%)

1 (4%)







2 (8%)

1 (4%)
1 (4%)

Effluent
(20)**

2(100%)

15 (75%)


1 (5%)










1 (5%)

1 (5%)



4 (20%)
8 (40%)
4 (20%)

1 (5%)












Above 500
ug/L in
Effluent (20)**



2




































                                           Max. Effluent
                                               Level
                                               ug/L
                                                2600
                                                  44
                                                  15

                                                  15
                                                 120
                                                  68

                                                  15

                                                  20
         107

-------
                                  TABLE VI-1 (continued)
                                                No. of Occurrences
                                            Detected
 No.*      	Compound

  83B      indeno(l,2,3-C,D)pyrene
  84B      pyrene
  85V      tetrachloroethylene
  86V      toluene
  87V      trichloroethylene
  88V      vinyl chloride
  89P      aldrin
  90P      dieldrin
  91P      chlordane
  92P      4,4'-DDT
  93P      4,4'-DDE
  94P      4,4'-DDD
  95P      alpha-endosulfan
  96P      beta-endosulfan
  97P      endosulfan sulfate
  98P      endrin
  99P      endrin aldehyde
 lOOP      heptachlor
 101P      heptachlor epoxide
 102P      aipha-BHC
 103P      beta-BHC
 104P      gamma-BHC (lindane)
 105P      delta-BHC
 106P      PCB-1242
 107P      PCB-1254
 108P      PCB-1221
 109P      PCB-1232
 HOP      PCB-1248
 111P      PCB-1260
 112P      PCB-1016
 113P      toxaphene
 114M      antimony (total)
 115M      arsenic (total)
 116        asbestos (fibrous)
 117M      beryllium (total)
 118M      cadmium (total)
 119M      chromium (total)
 120M      copper (total)
 121        cyanide (total)
 122M      lead (total)
 123M      mercury (total)
124M      nickel (total)
125M     selenium (total)
Influent
 (25)**
 * (16%)
16 (64%)
 3  12%)
Effluent
 (20)**
  Above 500
    ug/L in
Effluent (20)**
   (10%)
   (25%)
   (10%)
Max. Effluent
    Level
    ug/L
                       18
                     1350
                       11
10 (40%)
5 (20%)
it- (16%)
8 (32%)
23 (92%)
24 (96%)
11 (44%)
13 (52%)
16 (64%)
14 (56%)
7 (28%)
3 (15%)
3 (15%)
2 (10%)
5 (25%)
15 (75%)
16 (80%)
10 (50%)
9 (45%)
12 (60%)
9 (45%)
3 (15%)
                                            90
                                            30

                                             2.0
                                            40
                                           304
                                            63
                                          7700
                                           400
                                             1.58
                                           310
                                            56
                                      108

-------
                                   TABLE VI-1 (continued)
                                                 No. of Occurrences
Detected Above 500 Max. Effluent

No.*
126M
127M
128M
129B


Compound
silver (total)
thallium (total)
zinc (total)
2,3,7,8-tetrachloro-
dibenzo-p-dioxin (TCDD)
Influent
(25)**
7 (28%)
5 (20%)
21 (8*%)


Effluent ug/L in
(20)** Effluent (20)**
3 (15%)
4 (20%)
17 (85%)


Level
UR/L
40
29
403


. *  V -  volatile organics
   A -  acid extractables
   B -  base/neutral extractables
   P -  pesticides
   M -  metals

**  Indicates number of plant streams.

*** Deleted from further consideration by 46 FR 10723 and 46 FR 2266.
                                            109

-------
                                  TABLE VI-2

PRIORITY POLLUTANTS EXCLUDED FROM DIRECT DISCHARGER REGULATIONS
                                  BASED  ON
               CONTROL BY OTHER LIMITATION TECHNOLOGIES
     Paragraph 8  (a) (i) "For a specific pollutant effectively controlled by the
                  technology  upon  which  are  based upon other  effluent
                  limitations  and guidelines,  standards  of performance, or
                  pretreatment standards ..."
      4V    benzene
     11V*   1,1,1-trichloroethane
     13V*   1,1-dichloroethane
     85V    tetrachloroethylene
     86V    toluene
     87V*   trichloroethylene
     57 A*   2-nitrophenol
     58A*   4-nitrophenol
     59A*   2,4-dinitrophenol
     65A    phenol
     25B*   1,2-dichlorobenzene
     26B*   1,3-dichlorobenzene
     27B*   1,4-dichlorobenzene
     55B*   naphthalene
(Air stripping and/or biodegradation)
(Air stripping)
(Air stripping)
(Air stripping)
(Air stripping and/or biodegradation)
(Air stripping)
(Biodegradation)
(Biodegradation)
(Biodegradation)
(Biodegradation)
(Biodegradation)
(Biodegradation)
(Biodegradation)
(Biodegradation)
    *     Indicates exclusion  under two  or  more  separate  provisions  of
          Paragraph 8.
                      V - Volatile organics

                      A - Acid extractables

                      B - Base/neutral extractables

                      P - Pesticides

                      M- Metals
                                110

-------
                                 TABLE VI-3

PRIORITY POLLUTANTS EXCLUDED FROM DIRECT DISCHARGER REGULATIONS
                                  BASED ON
                            LOW-LEVEL PRESENCE
      Paragraphs   (a)  (iii) "For a  specific pollutant-present only in trace
                   amounts "and is  neither causing nor likely to cause toxic
                   affects; or is present in amounts too small to be effectively
                   reduced by technologies known to the Administrator..."
        6V*   carbon tetrachloride
        7V    chlorobenzene
       11V*   1,1,1-trichloroethane
       13V *   1,1 -dichlor oethane
       14V*   1,1,2-trichloroethane
       15V *   1,1,2,2-tetrachloroethane
       16V*   chloroethane
       19V*   2-chloroethylvinyl ether
       30V *   1,2-trans-dichloroethylene
       32V*   1,2-dichloropropane
       33V*   1,3-dichloropropylene
       38V*   ethylbenzene
       46V*   methyl bromide
       47V*   bromoform
       48V*   dichlorobromomethane
       51V*   chlorodibromomethane
       85V*   tetrachloroethylene
       87V*   trichloroethylene
       88V*  vinyl chloride
       21A*   2,4,6-trichlorophenol
       22A*  parachlorometa cresol
       24A*   2-chlorophenol
        31 A*   2,4-dichlorophenol
        34A*   2,4-dimethylphenol
        37A*   1,2-diphenylhydrazine
        57 A*   2-nitrophenol
        58A    4-nitrophenol
        59 A*   2,4-dinitrophenol
        64A*   pentachlorophenol
        65A    phenol
         IB*   acenaphthene
         5B*   benzidine
         8B*   1,2,4-trichlorobenzene
         9B*   hexachlorobenzene
        12B *   hexachloroethane
        18B*   bis(2-chloroethyl) ether
        2 OB*   2-chloronaphthalene
        25B*    1,2-dichlorobenzene
        26B*    1,3-dichlorobenzene
27B*   1,4-dichlorobenzene
28B*   3,3-dichlorobenzidine
35B*   2,4-dinitrotoluene
36B*   2,6-dinitrotoluene
39B*   fluoranthene
40B*   4-chlorophenyl phenyl ether
^1B*   4-bromophenyl phenyl ether
43B*   bis(2-chloroethoxy) methane
52B*   hexachlorobutadiene
53B*   hexachlorocyclopentadiene
54B*   isophorone
55B*   naphthalene
56B*   nitrobenzene
61B*   N-nitrosodimethylamine
62B*   N-nitrosodiphenylamine
63B*   N-nitrosodi-n-propylamine
66B** bis(2-ethylhexyl) phthalate
67B** butyl benzyl phthalate
68B** di-n-butyl phthalate
69B** di-n-octyl phthalate
70B** diethyl phthalate
7IB**  dimethyl phthalate
72B*   benzo(a)anthracene
73B*   benzo(a)pyrene
74B*   3,4-benzof luoranthene
75B*   benzo(k)fluoranthane
76B*   chrysene
 77B*   acenaphthylene
 78B*   anthracene
 79B*   benzo(ghi)perylene
 SOB*   fluorene
 8 IB*   phenanthrene
 82B*   dibenzo(a,h)anthracene
 83B*   indeno(l,2,3-C,D)pyrene
 84B*   pyrene
129B*   2,3,7,S-tetrachloro-dibenzo-p-
        dioxin (TCDD)
114M    antimony (Total)
115M    arsenic (Total)
                                       111

-------
                            TABLE VI-3 (CONT'D.)

PRIORITY POLLUTANTS EXCLUDED FROM DIRECT DISCHARGER REGULATIONS
                                 BASED ON
                           LOW-LEVEL PRESENCE
     117M*  beryllium (Total)
     118M*  cadmium (Total)
     119M   chromium (Total)
     120M   copper (Total)
     122M   lead (Total)
     123M   mercury (Total)
     124M   nickel (Total)
     125M*  selenium (Total)
     126M*  silver (Total)
     127M   thallium (Total)
    *   Indicates exclusion under two or more separate provisions of Paragraph 8.

    **  Phthalates likely resulting from sample contamination.


        V -   Volatile organics                        :

        A -   Acid extractables

        B -   Base neutral extractables

        P -   Pesticides                              :

        M -   Metals                                 ;
                                  112

-------
                                 TABLE VI-*

PRIORITY POLLUTANTS EXCLUDED FROM DIRECT DISCHARGER REGULATIONS
                                  BASED ON
                         INFREQUENT OCCURRENCE


     Paragraph 8   (a) (iii) "For a specific pollutant—detectable in the effluent
                   from only a small number of sources within the subcategory
                   and the pollutant is uniquely related to only those sources..."
        2V    acrolein
        3V    acrylonitrile
        6V*   carbon tetrachloride
              (tetrachloromethane)
        7V*   chlorobenzene
       10V*   1,2-dichloroethane
       13V*   1,1-dichloroethane
       14V*   1,1,2-trichloroethane
       15V*   1,1,2,2-tetrachloroethane
       16V*   chloroethane
       19V*   2-chloroethyl vinyl
              (mixed)
       29V    1,1-dichloroethylene
       30V*   1,2-trans-dichloroethylene
       32V*   1,2-dichloropropane
       33V*   1,3-dichloropropylene
              (1,3-dichlor opr opene)
       38V*   ethylbenzene
       45V    methyl chloride
              (chloromethane)
       46V*   methyl bromide
              (bromomethane)
       47V*   bromoform
              (tribromomethane)
       48V*  dichlorobromomethane
        51V*  chlorodibromomethane
        85V*  tetrachloroethylene
        87V*  trichloroethylene
        88V*  vinyl chloride
               (chloroethylene)
        21 A*   2,4,6-trichlorophenol
        22A*   parachlorometa cresol
        24A*   2-chlorophenol
        31A*   2,4-dichlorophenol
        34A*   2,4-dimethylphenol
        37 A*   1,2-diphenylhydrazine
        58A*   4-nitrophenol
        59A*   2,4-dinitrophenol
60A    4,6-dinitro-o-cresol
64A*  pentachlorophenol
 IB*  acenaphthene
 5B*  benzidine
 8B*  1,2,4-trichlorobenzene
 9B*  hexachlorobenzene
12B*  hexachloroethane
1 SB*  bis(2-chloroethyl) ether
20B*  2-chloronaphthalene
25B*  1,2-dichlorobenzene
26B*  1,3-dichlorobenzene
27B*  1,4-dichlorobenzene
28B*  3,3-dichlorobenzidine
35B*  2,4-dinitrotoluene
36B*  2,6-dinitro toluene
39B*  fluoranthene
40B*  4-chlorophenyl phenyl ether
41B*  4-bromophenyl phenyl ether
42B   bis(2-chloroisopropyl) ether
43B*  bis(2-chloroethoxy) methane
52B*  hexachlorobutadiene
53B*  hexachlorocyclopentadiene
54B*  isophorone
55B*  naphthalene
56B*  nitrobenzene
61B*   N-nitrosodimethylamine
62B*   N-nitrosodiphenylamine
63B*   N-nitrosodi-n-propylamine
72B*   benzo(a)anthracene
 73B*   benzo(a)pyrene
 74B*   3,4-benzofluoranthene
 75B*   benzo(k)fluoranthene
 76B*   chrysene
 77B*   acenaphthylene
 78B*   anthracene
 79B*   anthracene
 SOB*   fluorene
 SIB*   phenanthrene
                                       113

-------
                           TABLE VI-4 (CONT'D.)

PRIORITY POLLUTANTS EXCLUDED FROM DIRECT DISCHARGER REGULATIONS
                                 BASED ON
                        INFREQUENT OCCURRENCE
  82B*
  83B*
  S4B*
 129B*

  89P**
  90P**
  9 IP**
  92P**
  93P**
  95P**
  96P**
  97P**
  98P**
  99P**
100P**
101P**
102P**
103P**
104P**
105P**
106P**
107P**
108P**
109P**
HOP**
HIP**
112P**
113P**
117M*
118M*
125M*
126M*
             dibenzo(a,h) anthracene
             indeno(l,2,3-C,D)pyrene
             pyrene
             2,3,7,8-tetrachloro-dibenzo-p
             dioxin(TCDD).
             aldrin
             dieldrin
             chlordane
             4,^-DDE
             alpha-endosulfan
             beta-endosulfan
             endosulfan sulfate
             endrin
             endrin aldehyde
             heptachlor
             heptachlor epoxide
             alpha-BHC
             beta-bhc
             gamma-BHC (lindane)
             delta-BHC
             PCB-1242
             PCB-1254
             PCB-1221
             PCB-1232
             PCB-124S
             PCB-1260
             PCB-1016
             toxaphene
             beryllium (Total)
            cadmium (Total)
            selenium (Total)
            silver (Total)
   *   Indicates exclusion under two or more separate provisions of Paragraph 8.

   **  Infrequent presence due to operations on site other than pharmaceutical.
                                V -   Volatile organics

                                A -   Acid extractables

                                B -   Base neutral extractables

                                P -   Pesticides
                                M -   Metals

-------
                             TABLE VI-5

PRIORITY POLLUTANTS EXCLUDED FROM DIRECT DISCHARGER REGULATIONS
                              BASED ON
     PRESENCE IN AMOUNTS TOO SMALL TO BE EFFECTIVELY REDUCED
           BY TECHNOLOGIES KNOWN TO THE ADMINISTRATOR
                 23V   chloroform

                 ^W   methylene chloride

                 128M   zinc (Total)
                               M-  Metals

                               V -  Volatile organics
                                115

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                                   TABLE YI-6

           POLLUTANTS EXCLUDED FROM PRETREATMENT STANDARDS
No.
Compound
No. of Occurrences
    in Indirect
   Wastewaters
1W
15V
16V
19V
32V
33V
48V
51V
88V
IB
5B
8B
9B
12B
18B
20B
25B
26B
27B
28B
35B
36B
37B
39B
40B
41B
42B
43B
52B
53B
54B
55B
56B
61B
62B
63B
66B
67B
68B
1,1, 2-trichloroethane
1,1,2,2-tetrachloroethane
chloroethane
2-chloroethylvinyl ether
1 ,2-dichloropropane
1 ,3-dichloropropylene
dichlorobromomethane
chlorodibromomethane
vinyl chloride
acenaphthene
benzidine
1,2,4-trichlorobenzene
hexachlo robenzene
hexachloroethane
bis(2-chloroethyl) ether
2-chloronaphthalene
1 ,2-dichlorobenzene
1,3-dichlorobenzene
1,4-dichlorobenzene
3,3'-dichlorobenzidine
2,4-dinitrotoluene
2,6-dinitrotoluene
1 ,2-diphenylhydrazine
fluoranthene
4-chlorophenyl phenyl ether
4-bromophenyl phenyl ether
bis(2-chloroisopropyl) ether
bis(2-chloroethoxy) methane
hexachlorobutadiene
hexachlorocyclopentadiene
isophorone
naphthalene
nitrobenzene
N-nitrosodimethylamine
N-nitrosodiphenylamine
N-nitrosodi-n-propylamine
bis(2-ethylhexyl) phthalate
butyl benzyl phthalate
di-n-butyl phthalate
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
5*
0
0
 Max. Indirect
 Wastewater
Concentration
                                                        12
                                          12

                                        2700*
Basis For
Exclusion
                                                                 Infrequent
                                                                    it
                                                                    it
                                                                    ti
                                                                    it
                                                      " & low level
                                                                    it
                                                                    ti
                                                                    it
                                                                    ii
                                                                    ti
                                                                    it
                                                                    ii
                                                                    it

                                                                    it
                                                                    ti
                                                                    it
                                                                    it
                                                                   " & low level
  Phthalate occurrence likely the result of sample contamination by sample tubing.
                                     116

-------
                              TABLE VI-6 (Continued)
No.
 69B
 7 OB
 71B
 73B
 74B
 75B
 76B
 77B
 78B
 79B
 SOB
 81B
 82B
 83B
 84B
129B

 89P
 90P
 91P
 92P
 93P
 94P
 95P
 96P
 97P
 98P
 99P
100P
101P
102P
103P
104P
105P
106P
107P
108P
109P
HOP
HIP
112P
113P
114M
115M
117M
118M
119M
              Compound
       di-n-octyl phthalate
       diethyl phthalate
       dimethyl phthalate
       benzo(a) pyrene
       3,4-benzofluoranthene
       benzo(k) f luoranthane
       chrysene
       acenaphthylene
       anthracene
       benzo(ghi) perylene
       fluorene
       phenanthrene
       dibenzo(ajh) anthracene
       indeno(l,2,3-C,D) pyrene
       pyrene
       2,3,7,8-tetrachloro-
         dibenzo-p-dioxin (TCDD)
       aldrin
       dieldrin
       chlordane
       alpha-endosulfan
       beta-endosulfan
       endosulfan sulfate
       endrin
       endrin aldehyde
       heptachlor
       heptachlor epoxide
       alpha-BHC
       beta-BHC
       gamma-BHC (lindane)
       delta-BHC
       PCB-1242
       PCB-1254
       PCB-1221
       PCB-1232
       PCB-1248
       PCS-1260
       PCB-1016
       toxaphene
       antimony (total)
       arsenic (total)
       beryllium (total
       cadmium (total)
       chromium (total)
No. of Occurrences
in Indirect
Wastewaters
o'
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0.
0
0
6
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7
3
2
3
11
Max. Indirect
Wastewater Basis For
Concentration Exclusion
Infrequent
• n
n
n
n
n
n
n
" - • ' ' n
ii
•'•••' ' ' •' 'n
' ' ; ii
n
n •
n
n
n
"-"••'•. n
n
n
210 treatable level
£13 n " n
2 ii " "
32 ii ii '•
650 " " "
                                         117

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                               TABLE VI-6 (Continued)
No.

120M
122M
123M
124M
125M
126M
127M
128M
116
       Compound
copper (total)
lead (total)
mercury (total)
nickel (total)
selenium (total)
silver (total)
thallium (total)
zinc (total)
No. of Occurrences
    in Indirect
   Wastewaters

       11
        8
        7
        8
        3

        2
       10
Max. Indirect
 Wastewater
Concentration

     150
     286
      50
     630
      30
522
              Basis For
              Exclusion
            treatable level
                                       118

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                      TABLE VI-7

POLLUTANTS CONSIDERED FOR PRETREATMENT STANDARDS
                          No. of Occurrences
No.
121

2V
3V
4V
6V
7V
10V
11V
13V
23V
29V
30V
38V
*W
47V
85V
86V
87V
Compound
cyanide
Volatile Organics:
acrolein
acrylonitrile
benzene
carbon tetrachloride
chlorobenzene
1 ,2-dichloroethane
1 , 1 , 1 -tr ichloroethane
1 , 1-dichloroethane
chloroform
1 , 1-dichloroethylene
1 ,2-trans-dichloroethylene
ethylbenzene
methylene chloride
bromoform
tetrachloroethylene
toluene
trichloroethyiene
in Wastewaters
5

2
1
6
1
2
2
4
3
6
2
1
3
9
1
1
6
1
 Max. Wastewater
Concentration Level
      (ug/L)

        590
                                                     100

                                                     100

                                                     580

                                                     300

                                                      11

                                                     290

                                                 360,000

                                                      27

                                                   1,350

                                                      10

                                                     550

                                                      21

                                                 890,000

                                                      12

                                                       2

                                                   1,050

                                                       7
                          119

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                            SECTION VII

                 CONTROL AND TREATMENT TECHNOLOGY
 A.   INTRODUCTION

 This   section   addresses   the  technologies   currently  used  or
 available  to  remove or  reduce wastewater  pollutants  generated  by
 the   pharmaceutical  manufacturing  industry.   Although  wastewater
 flow and raw  waste  load will  vary from  plant  to  plant,   they   are
 expected   to  be treatable  by  the  techniques  presented herein.
 Many possible combinations  of in-plant  and  EOF systems  exist  that
 are   capable  of achieving  the   pollutant   reduction   levels
 anticipated.   However,  each  individual plant must make the final
 decision concerning the specific combination  of  pollution control
 measures best suited to its particular  situation.

 In identifying appropriate  control  and   treatment   technologies,
 the  Agency assumed  that each  manufacturing  plant had installed or
 would  install the  equipment  necessary  to comply with limitations
 based on BPT.  Those treatment technologies currently in place in
 the  industry, as reported in   308   responses,  are   presented  by
 plant  in Appendix  L.   Thus,  the technologies described below are
 those which can  further reduce the  discharge  of  pollutants  into
 navigable  waters   or   POTW  systems.   They  are divided into two
 broad classes: in-plant and end-of-pipe (EOF)  technologies.

 Since the ultimate  receiving  point  of a plant's  wastewater  can be
 critical in determining  the overall   treatment   effort   required,
 information on ultimate discharge is  also supplied.

B.   IN-PLANT  SOURCE CONTROL

The   intent   of  in-plant source  control is  to reduce or eliminate
the   hydraulic   and/or  pollutant   loads  generated  by  specific
sources   within    the   overall   manufacturing   process.     By
 implementing  controls   at  the  source,  the   impact    on   and
requirements  of  subsequent   downstream  treatment systems  can be
minimized.

Many  of  the  newer  pharmaceutical  manufacturing  plants   are
designed  with   the  reduction   of water  use  and subsequent mini-
mization of contamination as part of  the   overall  planning   and
plant  design  criteria.    Improvements   also  have  been made in
existing plants  to  better control their  manufacturing   processes
and  other  activities  and the  consequent  environmental  effects.
Some  examples  of   in-plant  source  controls  that  have    been
effective in reducing pollution  loads are as  follows:
                                120

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(1)   Production processes have  been  modified  or  combined  and
     reaction  mixtures  have  been  concentrated to reduce waste
     loads as well as increase yields.  Processes have also  been
     reviewed   and   revised  to  reduce  the  number  of  toxic
     substances used.

(2)   Efforts are made to  concentrate  and  segregate  wastes  at
     their source to minimize or eliminate wastes where possible.
     New  process  equipment  is  designed  to  produce effluents
     requiring no further treatment.
(3)
     Several  techniques have been employed to reduce  the  volume
     of  fermentation  wastes discharged to end-of-pipe treatment
     systems.   One approach involves concentrating  "spent  beer"
     wastes  by  evaporation and then dewatering and drying waste
     mycelia.   The resulting dry product in  some  instances  has
     sufficient  economic  value  as an animal feed supplement to
     offset part of the drying cost.

(4)    Several   plants  have  installed  automatic  TOC-monitoring
     instrumentation  or  both  pH'  and  TOC monitoring to permit
     early detection  of  process  upsets  that  may  result  in
     excessive discharges to sewers.

(5)    The  recovery  of waste solvents is a common practice among
     plants using  solvents  in  their  manufacturing  processes.
     However,   to  further  reduce  the  amount  of waste solvent
     discharge, plants  have  instituted  such  measures  as  (a)
     incineration  of  solvents  that  cannot  be  recovered eco-
                      incineration  of  "bottoms"  from   solvent
                       and (c) design and construction of solvent
                                solvents  beyond  the  economical
     nomically,  (b)
     recovery  units,
     recovery columns to strip
     recovery point.
(6)   The  use of barometric condensers can result in significant
     water  contamination,  depending  upon  the  nature  of  the
     materials entering the discharge water stream.  In addition,
     barometric  condenser  use  very  high  quantities of water,
     which results in substantial increases in the  total  amount
     of  process-exposed  wastewater.   An outstanding example of
     this is plant 12256 which utilizes more than 20 MGD of once-
     through barometric  condenser  water.   As  an  alternative,
     several  plants  are  using  surface  condensers  to  reduce
     hydraulic or organic loads.

(7)  Several plants are using a recirculation system as  a  means
     of  greatly  reducing the amount of contaminated water being
     discharged from water-sealed vacuum pumps.
                                121

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 (8)  Reduction of once-through cooling water by recycling through
      cooling towers is used in numerous  plants  and  results  in
      decreased total volume of discharge.

 (9)   Separation  of  manufacturing  area stormwater is practiced
      throughout the industry and often facilitates the  isolation
      and treatment of contaminated runoff.

 (10)  Spill  prevention  is  recognized  in  the  industry  as  a
      critical  aspect  of  pollution  control.    In  addition  to
      careful management of materials and methods,  such preventive
      steps as impoundment basins are utilized in many cases.

 (11)  Wash waters can be reduced or eliminated in many situations
      by use of dry  cleanup  methods.    Containment  control  and
      removal  of  either  liquid  or solid dry process wastes can
      often be  accomplished  using  little  or  no  water.    This
      particular   approach   can  possibly ;completely  eliminate
      wastewater   discharge,    especially  ;in   Subcategory    D
      (Formulation)   plants,   where  washwater  is   often the only
      wastewater source.
 C.
IN-PLANT TREATMENT
 Besides  implementing  source controls to reduce or  eliminate  the
 waste  loads   generated   within the manufacturing process,  plants
 may  also employ  in-plant  treatment  directed at  removing  certain
 pollutants  before  they   are   combined  with  the plant's  overall
 wastewaters and  thus  diluted.


 This concept of  in-plant  treatment  of  a segregated stream   is   of
 major  importance.  First,  treatment technologies can  be directed
 specifically   toward  a   particular   pollutant.    Also,    since
 wastewater  treatment  and   pollutant   removal  costs are strongly
 influenced by  the volume  of water  to  be treated,   the   costs
 involved  in   treating  a segregated stream are considerably less
 than they would  be  in treating  combined wastewater.

 Additionally,  chemicals other than  those being  treated   are  less
 likely  to  interfere  with  the  treatment technology if  treatment
 occurs before  commingling.   Further,  lower   EOF  effluent   levels
 can be attained  due to dilution  of  the  treated  segregated stream.

 In-plant  treatment  processes   can  be visualized  as end-of-pipe
 treatment for  a  particular production process or  stage within the
plant itself,  designed to treat  specific waste  streams.  Although
 in-plant technologies can remove a  variety  of   pollutants,    their
principal applications are for the  treatment of toxic or priority
pollutants.     In the pharmaceutical manufacturing  industry,  three
                                122

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classes of priority pollutants are of particular importance.   As
indicated  in  Section  V,  the  major  priority  pollutants  are
solvents, metals, and cyanide.  Thus, the  discussions  presented
below  on  in-plant  technologies  concern the treatment of these
three classes of pollutants.     '

The  308  Portfolio  data  base  was  the  principal  source   of
information  relating  to  the  use  of in-plant treatment in the
pharmaceutical industry.  Most of this information came from  the
Supplemental  308  Portfolio  responses.   In addition, while not
specifically requested in the original 308  Portfolio,  some  in-
plant  treatment  information  was obtained from the original 308
Portfolio plants.  It was gathered via three mechanisms: a)  some
plants   provided  on  the  questionnaire  "additional"  data  or
comments relative to in-plant treatment; b)  a  small  amount  of
information  was gathered by direct contact with plant personnel;
and c) the wastewater sampling programs discussed in  Section  II
identified  the use of a few in-plant technologies.  (At the time
of the original 308 mailing, data on in-plant treatment  was  not
thought to be a critical item.  This philosophy was changed prior
to the Supplemental 308 mailing.)

Table VII-1  presents a summary of in-plant treatment technologies
identified  from  the various data bases along with the number of
plants that employ each  process.   A  listing  of  each  plant's
treatment  system,  including in-plant treatment, .is presented in
Append i x L.
1
Cyanide Destruction Technologies
Cyanide destruction is employed in the  pharmaceutical  industry,
as  noted  by  the 308 responses (table VII-.l), by limited direct
inquiry, and by information from the S/V program.

Present cyanide treatment processes demonstrated to be  effective
are based upon two fundamental approaches, chemical oxidation and
high  pressure and temperature techniques.  Chemical oxidation is
a reaction in which one or more electrons  are  transferred  from
the  chemical  being  oxidized  to  the  chemical  initiating the
transfer (oxidizing agent); as a result of  the  valence  change,
the  oxidized  substance  can then react to form a more desirable
compound.  The latter treatment is the application of  high  tem-
perature  and  pressure  to  break  down  chemical bonds; the end
result is that more tolerable substances are formed (e.g. C02 and
N02).  Under some circumstances, cyanide ions  may  combine  with
several  metals  to form inert complexes which may interfere with
removal of both the cyanide  and  the  metal.   Of  the  commonly
encountered  metals,  chromium,  manganese,  and  iron form inert
complexes, while nickel and mercury form labile complexes;
                                123

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                           Cyanide Complexes
          Inert
          Cr
          Mn
          Fe
        Labile
        Ni
        Hg (CN)4-2
Although they are classified as inert, cyanide will  be  released
from  the  inert  complexes  over  an  extended  period  of time.
However, this time period may exceed the residence  time  in  the
cyanide  destruct unit and cyanide from these complexes would not
be destroyed.  The labile complexes will present no  interference
in cyanide removal.

An  evaluation  of  cyanide limitations practically achievable by
the various technologies must consider the following:

     (1)  Theoretical reaction  equilibrium  limits.   These  are
generally extreme and therefore not a controlling factor.

     (2)  Conditions under which cyanate reversion can occur.
     (3)  Competitive reactions resulting
consumption.
in  increased  oxidant
     (4)  Chemical interferences such as iron complexing and
processing alternatives necessary to avoid them.
                   the
     (5)  Physical  interferences  which  might  hamper
availability and design methods to overcome them.
              reactant
     (6)  The  extent  to  which  equalization   dilution   after
treatment  lowers  cyanide  in the final effluent.  In most plant
situations this results in a substantial concentration  reduction
allowing   limitation   levels  at  end-of-pipe  which  might  be
difficult to reach directly.

a.   Chlorination

Destruction of cyanide by  oxidation  either  with  chlorine  gas
under  alkaline  conditions or with sodium hypochlorite is a very
common  method  of  treating  industrial  wastewaters  containing
cyanide.   Although  more  costly,  sodium  hypochlorite  is less
hazardous  and  is  simpler  to   handle.    Oxidation   can   be
approximated by the following two-step chemical reaction:

     Cl* + NaCN + 2 NaOH = NaOCN + 2 NaCl + H,O
                               124

-------
     3C1
6NaOH + 2NaOCN = 2 NaHC0
N
6 NaCl
                                                      2 H0
Cyanide  is oxidized to cyanate completely and rapidly at a pH of
about 9.5 to 10.0.  Usually 30 minutes are required to  insure  a
complete  reaction.   The  oxidation  of  cyanide  to  cyanate is
accompanied  by  a  marked  reduction   in   volatility   and   a
thousandfold reduction in toxicity.

However,   since   cyanate  may  revert  to  cyanide  under  some
conditions, additional chlorine is provided to oxidize cyanate to
carbon dioxide/bicarbonate.  At pH levels  around  9.5  to  10.0,
several  hours  are  required  for  the complete oxidation of the
cyanate, but only one hour is necessary at a pH between  8.0 .and
8.5.   Also,  excess  chlorine  must  be  provided  to break down
cyanogen chloride, a highly toxic  intermediate  compound  formed
during the oxidation of cyanate.

Although  stoichiometric  oxidation  of  one  part  of cyanide to
cyanate requires only 2.73 parts of chlorine, in practice 3 to  4
parts  of  chlorine  are  used.  Complete  oxidation  of one part
cyanide to carbon dioxide and nitrogen gas theoretically requires
6.82 parts of chlorine, but nearly 8 parts are normally necessary
in practice.  The chlorine required in practice  is  higher  than
the theoretical amount because other substances in the wastewater
compete for the chlorine.

Soluble  iron interferes seriously with the alkaline chlorination
of cyanide wastes.  Iron and cyanide form a stable complex  which
is impervious to chlorine oxidation.  Similar difficulties result
from  formation  of  nickel cyanides.  Ferrocyanides are reported
treatable  by  alkaline  chlorination  at  temperatures  of  71 C
(160 F) and at a pH of about 12.0.

Ammonia also interferes with the chlorine oxidation process since
the chlorine demand is increased by the formation of chloramines.
When cyanide is only being oxidized to cyanate, it is usually not
economical  to  remove  the  ammonia  by breakpoint chlorination,
which requires almost 10 parts of  chlorine per part  of  ammonia.
Complete   cyanate  formation  can  be accomplished by allowing an
extra 15 minutes contact time.  When complete  oxidation  of  the
cyanide  is  to  be  accomplished, the ammonia must be removed by
breakpoint chlorination  so  a  free  chlorine  residual  can  be
maintained to break down the cyanogen chloride.

An  example of a cyanide destruction system  using chlorination is
shown in Figure VII-1 .

Because of some of the advantages  of  the  chlorination  process,
this  technology   has  received  widespread  application  in  the
chemical industry  as a whole.  First, it is  a relatively low cost
                               125

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 system and does not require complicated equipment.  It also  fits
 well  into  the  flow  scheme of a wastewater treatment facility.
 The process will operate effectively at ambient conditions and is
 well  suited  for  automatic  operation,  thus  minimizing  labor
 requirements.   This technique is used by pharmaceutical processes
 manufacturers  who use cyanide in chemical synthesis.

 The  chlorination  process,   however,  does  have limitations and
 disadvantages.  For example,  toxic,  volatile intermediate-reaction
 products can be  formed.    Thus,  it  is  essential  to  properly
 control  the pH to ensure that all  reactions are carried to their
 end point.   Also,  for waste streams containing  other  oxidizable
 ma.tter, the chlorine may be consumed in oxidizing these materials
 and  may  interfere  with the treatment of the cyanide.  Finally,
 for those systems using gaseous chlorine,  a potentially hazardous
 situation exists when it is stored  and handled.

 The oxidation  of cyanide-bearing wastewaters  by  using  chlorine
 under basic conditions is a classic technology.   However,  its use
 by   the pharmaceutical industry is  limited to a few plants.   From
 the EPA's Effluent Guidelines Division's  study  to  develop  BAT
 regulations for  the electroplating industry (109),  it was found
 that cyanide levels around 40 ^g/1   are  achievable  by  in-plant
 chlorination processes,  as long as  reaction interferences  are not
 present.     The    presence   of   interfering   substances   in
 pharmaceutical  manufacturing wastewater may,  in fact,  prevent the
 attainment   of   these  levels  using  the   alkaline  chlorination
 method.

 In   addition,   the  Draft Development Document  for the Inorganic
 Chemicals Industry (71)  indicates that  the  free  cyanide  level
 after  chemical  oxidation treatment is generally below 100  ug/1.
 An  important consideration relative to  th^  reported   attainable
 effluent   level  and  the variety   of pharmaceutical  wastewaters
 encountered is  the presence  of  constituents  which interfere  by
 complexing   or   competing for  the  chlorine oxidizing  agent.   The
 extent  to which  the various   materials  foiuid  in  pharmaceutical
 wastewater  may  interfere  with chlorine oxidation  is not known.
                                            i

 Chemical  oxidation  of   cyanide is currently  the most prevalent
 technique used   by  pharmaceutical   plants   to  destroy cyanide.
 However,  the  available   data  from plants  using  this  method  does
 not permit  an adequate  evaluation   of  the  cyanide   destruction
 capability   of  this  technique as  applied  to  pharmaceutical
wastewater.                                 ;

b.   Ozonation

Ozone (allotropic  form of  oxygen) is a good oxidizing   agent   and
can  be   used  to  treat process  wastewaters; that  contain cyanide.
                               126

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 In  fact, ozone oxidizes many   cyanide   complexes   (for   instance,
 iron  and nickel  complexes) that  are not  broken down  by  chlorine.
 Ozonation is primarily used to oxidize  cyanide to  cyanate.

 With traces of copper and  manganese  as   catalysts,  cyanide   is
 reduced   to   very   low   levels,   independent   of    starting
 concentrations and form of the complex.   The  oxidation of cyanide
 by  ozone to cyanate occurs in  about 15  minutes at  a pH of 9.0   to
 10.0, but the reaction is almost  instantaneous in  the presence  of
 traces of copper.  The pH of the  cyanide  waste is  often  raised  to
 12.0  in order that complete oxidation  occurs before  the pH  drops
 to  8.0 in the process.

 Oxidation of cyanate to the  final  end  products,  nitrogen and
 bicarbonate,  is  a much slower and more  difficult process unless
 catalysts  are  present.  Therefore,  since   ozonation   will not
 readily  effect further oxidation of cyanate, it is often coupled
 with such independent processes as dialysis or bio-oxidation.

 The ozonation treatment process is beginning  to receive  more and
 more usage.  Its  initial applications in  treating metal  finishing
 wastewater  have  shown  it  to   be  quite  effective for cyanide
 removal.  Like chlorination, the  ozonation process is well suited
 to automatic control and  will  operate  effectively  at  ambient
 conditions.  Also, the reaction product (oxygen) is beneficial  to
 the  treated  wastewater.   Since the  ozone  is generated onsite,
 procurement, storage, and handling problems are eliminated.

 The ozonation process does have drawbacks.  It has higher capital
 and  operating  costs  than  chlorination  and  similar   toxicity
 problems;  also,  as with chlorination, increased ozone  demand  is
 possible if other oxidizable  matter  is  present  in the   waste
 stream.    Finally,  in  most cases the  cyanide is not effectively
 oxidized beyond the cyanate level.

 c.   Alkaline Hydrolysis

 Removal of cyanide from process wastewaters can  be   accomplished
 without  the use of strong oxidizing chemicals.   For  the alkaline
 hydrolysis system, the principal  treatment action is'  based  upon
 the application of heat and pressure.    In this process,   a caustic
 solution is added to the cyanide-bearing wastewaters  to  raise the
pH  to between 9.0 and 12.0.   Next,  the wastewater is transferred
 to a continuous reactor where  it  is subjected to temperatures  of
 about  165°C  to  185°C  (329°F   to  365°F)  and  pressured  from
 approximately 90 to 110 psia.   The breakdown of  cyanide in  the
 reactor  is generally accomplished with a residence time of  about
 1.5 hours.
                               127

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An example of an alkaline hydrolysis system for tres::ng cyanide-
bearing wastewaters is shown in Figure VI1-2.

The absence  of  specific  chemical  reactants  in  this  process
eliminates  procurement, storage, and handling problems.  As with
other cyanide processes, alkaline hydrolysis is  well  suited  to
automatic control.                         '

In the pharmaceutical industry, wastewaters with large amounts of
cyanide  content  are  more  likely  to  be  treated  by alkaline
hydrolysis, for economic reasons.

As in the case of chlorination, only a limited amount of data  is
available regarding the pharmaceutical industry's use of alkaline
hydrolysis  for cyanide treatment.  The data available from these
plants, however, indicated that the  cyanide  levels  reached  by
this technology are similar to those achieved by the chlorination
process.   Long  term  performance data has been submitted by one
plant (12236) which uses this method to destroy  cyanide  in  its
wastewater.  The available data indicate that an average effluent
value  of  200  ug/1  is  achievable  for  cyanide.  It should be
emphasized that this is an  achievable  effluent  level  and  not
necessarily   what  is  achievable  directly  as  result  of  the
treatment of pharmaceutical wastewater by the alkaline hydrolysis
technique.

2.   Metals Removal Technologies

This discussion of metals removal technologies is presented  even
though   the   Agency   is   not  proposing  effluent  guidelines
limitations for metals.  It is intended to aid permit writers and
others  who  may,  at  some  point,  have  an  interest  in   the
performance  of  these technologies.  Metals removal technologies
are reported to be in place by the 308 responses.

Proven metals treatment technologies are based upon precipitation
and filtration.  Based on the solubility  products   (Ksp)  quoted
for  insoluble metal salts (113), the concentration of metal ions
in a saturated solution can be  calculated.   This  concentration
represents the theoretically achievable levels.

          Compound          Ksp          nQ/l
          Cu S
          Ni S
          Zn S
          Hg S
          Cu(OH).,
          Ni(OH)2
  6 x 10-3«
  2 x 10-25
1 .6 X 10-25
3.5 x 10-52
3.5 x
1 .5
  10~19
x 10-15
 x 10-10
 x 10-*
 x 10-5
 x 10~18
 25
400
                                128

-------
          Zn(OH)2
          Cr(OH)3
1.8 x TO-14
6.7 x 10~31
1  x 10-3
6  x 10-1
Comparison  of theoretically achievable treatment levels of metal
priority pollutants  to  the  other  proposed  regulation  levels
(i.e.,  metal  finishing)  shows  that  sulfide  precipitation is
theoretically capable of removing the metals  to  levels  several
orders  of  magnitude  lower than the levels that are practically
achieved.  Hydroxide precipitation can result in the  theoretical
levels  of  metals  which  are  lower  then  the levels generally
achievable by hydroxide precipitation as practiced.

Thus, in most  cases,  the  solubility  level  will  not  be  the
controlling  factor  in  establishing  minimum levels.  Practical
limits of removal are set by other circumstances, many  of  which
are  peculiar  to particular treatment processes.  The efficiency
of physical removal  of  precipitate  solids  by  such  means  as
filtration   or   clarification   is  limited  by  such  particle
characteristics  as  particle  size  and  stability,  which   are
functions  of pH and other chemicals present.  Many metal cations
are subject to chemical complexing that transforms them  into  an
unprecipitable species, causing interference with their removal.

Treatment   system   performance   under   industrial   operating
conditions is indicated in Table VII-2.   The  levels  shown  are
estimates  of  practical  attainable  long-term  average effluent
concentrations for priority pollutant metals.  Of the six  metals
of  special  interest  in this study, copper, chromium, lead, and
nickel are generally amenable to reductions to approximately  500
ng/l  at the point of metals treatment.  Although zinc reductions
to about 500  ^g/1  are  reported,  1,200  »q/l  may  be  a  more
realistic limit for the zinc content of wastewater since a higher
final  concentration  is  also  reported  for all three treatment
methods.  Mercury concentration, though not treatable by alkaline
precipitation, may be reduced to around  50  ug/1  after  sulfide
precipitation and filtration.

a.   Chemical Reduction

Chromium and some other metals must be reduced  from  their  high
valence   states  before  they  can  be  precipitated.   This  is
accomplished by chemical reduction, a reaction in  which  one  or
more  electrons  are transferred from the chemical initiating the
transfer (reducing agent) to the chemical being reduced.

The main application of chemical reduction in  the  treatment  of
industrial  wastewater is in the reduction of hexavalent chromium
to trivalent chromium.  Chromium is a common metal contaminant in
the   industry  is  wastewaters  and  its  chemical  reduction  is
employed as an in-plant treatment by the industry.  The reduction
                               129

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enables  the  trivalent  chromium in conjunction with other metal
salts to be separated from  solution  by  precipitation.   Sulfur
dioxide,  sodium  bisulfite,  sodium  metabisulfite,  and ferrous
sulfate are strong reducing agents in aqueous  solution  and  are
therefore useful in industrial waste treatment facilities for the
reduction of hexavalent chromium to trivalent chromium.

The  chemical reduction of chromium wastes by sulfur dioxide is a
well-known and widely accepted treatment technology  in  numerous
plants  employing  chromium  or  other high valence ions in their
manufacturing operations.  An example of how this  system  treats
process  wastewaters  containing chromates is presented in Figure
VI1-3.  The reactions involved may be illustrated as follows:
       3SO2 + 3H20

       3H2S03 + 2H
3H2S03

Cr2(S04)3 + 5H20
This reaction is favored by a low pH;, a value of 2.0 to  3.0  is
normally  required  for  situations requiring complete reduction.
At pH levels  above  5.0,  the  reduction  rate  is  slow.   Such
oxidizing  agents  as  dissolved oxygen and ferric iron interfere
with the reduction process by consuming the reducing agent.   The
sulfate   precipitate   can   be   removed   by   filtration   or
clarification.

Chemical reduction has been  used  quite  successfully  to  treat
large  concentrations  of  hexavalent  chromium  (e.g. from metal
finishing operations).  This method is well suited  to  automatic
control and may be used when conditions are ambient.

Chemical  reduction,  however,  is  not without some limitations.
Careful pH control  is  required  for  effective  reduction.   In
addition,  when waste streams contain other reducible matter, the
reducing agent may be  consumed,  depleting  that  available  for
treatment  of  the  metals.  Also, for those systems using sulfur
dioxide, a potentially hazardous  situation  exists  when  it  is
stored and handled.  Data indicate that chromium levels below 500
vg/1  can be achieved from in-plant chromium reduction processes.
(109)                                      ;

b.   Alkaline Precipitation

The solubility of metal hydroxides, in most cases, is a  function
of  pH and therefore the success of metal hydroxide precipitation
treatment is heavily dependent on the pH level of  the  solution.
In  order  to achieve optimum formation of solid metal hydroxides
the pH of the wastewater must be adjusted to the  range  (usually
moderately  alkaline) found to be most effective for the metal(s)
                               130

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involved.  This is accomplished by measured addition of
the wastewater with concurrent pH monitoring.
1ime  to
Following the attainment of optimum pH conditions the solid metal
hydroxides   are  coagulated  (using  coagulating  agents)  in  a
clarifier and deposited as sludge.  Proper clarifier  design  and
good coagulation are important prerequisites for efficient metals
removal by alkaline precipitation.

If  substantial  sulfur  compounds are present in the wastewater,
caustic soda (sodium hydroxide) may be used instead  of  lime  to
prevent  calcium  sulfate  formation  which would increase sludge
volume.   Treatment  chemicals  for   adjusting   pH   prior   to
clarification  may be added to a rapid mix tank, to a mix box, or
directly to the clarifier, especially in batch clarification.  If
such metals as cadmium and nickel are in the wastewater, a pH  in
excess of 10.0 is required for effective precipitation.  This pH,
however,  is  unacceptable  for discharged wastewater; therefore,
the pH must be reduced by adding acid.  The acid is usually added
as the treated wastewater flows through  a  small  neutralization
tank prior to discharge.

An  example  of  a  metals  removals system using alkaline preci-
pitation is shown in Figure VI1-4.

There  are  several   advantages   to   the   use   of   alkaline
precipitation.   In  the  first  place,  it  is well demonstrated
wastewater treatment technology.  It is well suited to  automatic
control  and  will  operate at ambient conditions.  Also, in many
instances, preceding treatment steps adjust the waste (especially
pH) to aid the alkaline precipitation process.  The end result is
that  the  costs  associated  with   this   technology   may   be
substantially  lower  than  those  for other processes.  However,
this method is subject to  interference  when  mixed  wastes  are
treated.   In  addition,  this  process generates relatively high
quantities of sludge that also require disposal.

Alkaline precipitation is a classic technology being used by many
industries, although its use by the pharmaceutical  industry  has
been  limited.   The EPA study to develop BPT regulations for the
electroplating  industry  (109)  indicated  that   the   alkaline
precipitation  process  is  capable  of  achieving  the following
approximate levels: 300 ug/1 for chromium and zinc, 200 ug/1  for
copper, TOO ug/1 for lead, and 500 ug/1 for nickel.

c.   Sulfide Precipitation

In  this  process,  heavy  metals  are  removed  as   a   sulfide
precipitate.   Sulfide  is  supplied  by  adding  a very slightly
soluble metal sulfide that has a solubility somewhat greater than
                                131

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that of the sulfide  of  the  metal  to  be  removed.   Normally,
ferrous  sulfide  is  used.   It  is fed  into a precipitator where
excess sulfide is retained  in a sludge blanket that acts both  as
a  reservoir  of  available  sulfide  and  as a medium  to  capture
colloidal particles.

The process is applicable for treatment  of all heavy metals.  The
process equipment requirement required includes a  pH   adjustment
tank,  a  precipitator,  a  filter,  and pumps  to transport the
wastewater.  The filter  is  optional  and  may  be  a  standard,
dual-media pressure filter.

A   variation  of  the  process   utilizes  sulfide  for  reducing
hexavalent chromium.  Ferrous sulfide at a pH of 8.0 to 9.0  acts
as   an   agent  to  reduce  the  hexavalent  chromium  and  then
precipitates it as a hydroxide in one step.  Hexavalent  chromium
wastes  do not have to be isolated and pretreated by reduction to
the trivalent form.

With respect to the generated sludge, sulfide sludges  have  been
found  to  be  less  subject  to  leaching than hydroxide sludges.
However, sulfide precipitation produces  sludge in greater  volumes
(requiring more available storage  space)  and  requires   greater
expenditures  for  chemicals  than  does alkaline precipitation.
Pollutant levels after treatment with sulfide  precipitation  are
very   similar   to   the   pollutant    levels   after   alkaline
precipitation.

3.   Solvent Recovery and Removal

Solvents are used extensively in the pharmaceutical manufacturing
industry.    Because   such   materials   are   expensive,   most
manufacturers  try  to  recover  them in opder to purify them for
reuse whenever possible.  Solvent recovery  operations  typically
employ such techniques as decantation, evaporation, distillation,
and   extraction.    The   feasibility   and  extent  of  recovery
purification are governed largely by the quantities involved  and
by  the  complexity  of  solvent  mixtures'  to  be separated.  If
recovery is not economically practicable, the used  solvents  may
have  to  be  disposed  of by means of incineration, landfilling,
deep-well injection, or contract disposal.

Even when an effort is made to recover solvents, some  wastewater
contamination  can  be  expected.  Removal of small quantities of
organic  solvents  from  the   segregated   wastewater   can   be
accomplished  by  such  techniques  as   steam stripping or carbon
adsorption.   Further   removal   of   solvents   from   combined
end-of-pipe  wastewater  may  result from biological treatment or
from surface evaporation in the treatment system.
                               132

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a.   Steam Stripping

Steam stripping is a variation of distillation in which steam  is
used  as  both  the  heating medium and the driving force for the
removal of volatile materials.  Steam is added at the bottom of a
tower and the wastewater being  treated  is  fed  either  at  the
middle  or near the top of the unit.  As the steam passes through
the wastewater, volatile materials are vaporized and removed with
the steam exiting from the top of the tower.

Some  steam  .stripping  processes  employ  columns  packed   with
materials  that  are  inert  and  corrosion  resistant.   Packing
materials have shapes that maximize the surface area for a  given
volume.   Materials  of  construction  for packing include steel,
porcelain, stoneware, and plastic.  In tray  towers,  the  column
contains  a  series  of  trays  that contain bubble caps or sieve
perforations to allow for liquid-vapor contact.

The tower bottoms  contain  only  trace  quantities  of  volatile
materials.    Tower  overheads  contain  the  volatile  materials
removed along with steam.  Subsequent condensation results in  an
immiscible  organic  layer that is recovered and an aqueous layer
that is returned to the column.   If more than  one  compound  has
been  removed,  further  separation  possibly  may be desired for
recovery.  Separation techniques  include selective  condensation,
extraction,  and distillation.  If the organic distillate removed
is not recovered, it may  be  disposed  of  by  such  methods  as
incineration,   landfilling,  deep-well  injection,  or  contract
disposal.

An example of a steam stripping unit for removing  solvents  from
process wastewaters  is shown  in Figure VI1-5.

Steam  stripping  of organic-bearing wastewaters has been used in
pharmaceutical  manufacturing  and   in   other   industries.     A
preliminary  study   (72) by the EPA's Organic Chemical Branch has
shown  that steam stripping used as   an   in-plant  technology  can
produce     very     low    pollutant     levels    for    benzene,
1,2-dichloroethane,  chloroform, jnethylene  chloride, toluene,  and
many   other  similar  compounds.  The starting concentration does
not strongly influence  either  the  cost   of  treating  a  given
quantity  of  water  or the achievable effluent concentrations.   A
level  of  about  50  »/g/l can be reached for   the  volatile  organic
solvents  used  in commercial practice.

Steam  stripping technology  is known  to be  in-place  at  a number of
pharmaceutical  plants.   However,  adequate data has  not yet been
received  which  would  confirm   the  Agency's  estimates  of  the
pollutant reduction  capability of this technology.
                                133

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 b*   Activated Carbon Adsorption

 Adsorption  is defined as the adhesion of dissolved  molecules   to
 the  surface  of  solid  bodies  with  which  they are  in  contact.
 Granular activated carbon particles have two  properties that make
 them effective and economical adsorbents.   First,  they  have  a
 high  surface  area per unit volume which results in faster, more
 complete adsorption.  Second, they have  a  high  hardness  value
 which lends itself to reactivation and repeated use.

 The  adsorption  process  typically  is  preceded  by preliminary
 filtration or clarification  to  remove  insolubles.   Next,  the
 wastewaters  are  placed in contact with carbon so adsorption can
 take place.   Normally,   two  or  more  beds  are  used  so  that
 adsorption  can  continue  while  a  depleted bed is reactivated.
 Reactivation is accomplished by heating the carbon between  870°C
 to  9800C (1600°F to 180QOF) to volatize and oxidize the adsorbed
 contaminants.   Oxygen in the furnace is  normally  controlled  at
 less  than  1   percent  to  avoid  loss  of carbon by combustion.
 Contaminants may be burned in an afterburner.

 Carbon adsorption  is primarily  designed  to  remove  dissolved
 organic  material from wastewater although it can,  to some extent
 remove chromium,   mercury  and  cyanide.    A  discussion  of  the
 technical and  economic feasibility of  activated carbon adsorption
 technology  may   be found in "Treatability of  Priority Pollutants
 in Wastewater  by  Activated  Carbon"   by  S.   T.   Hwanq  and   P.
 Fahrenthold, EPA  report,  1979.

 The potential  use  for   this   technology  by the  Pharmaceutical
 Industry   is  limited.    Concentrations   of  most   of   the  toxic
 pollutants  (metals,  volatile organics  and cyanide)  characteristic
 of pharmaceutical  wastewater are  all reduced more effectively and
 with   less   cost  by  the previously  discussed technologies  than  by
 activated   carbon   adsorption.    Phenols,  the  other   group   of
 pollutants   found   in pharmaceutical wastewater  are  biodegradable
 and their concentrations  can be reduced   by  improved   biological
 treatment.   Carbon  adsorption   is  particularly  applicable   in
 situations where   organic  material  in   low  concentrations not
 amenable  to treatment by other technologies must be removed from
 wastewater.

 The  equipment  necessary  for  an  activated  carbon   adsorption
 treatment  system  consists  of a preliminary clarification and/or
 filtration unit to remove the bulk of the solids,  two  or   three
 columns packed with activated carbon, and pumps and piping.  When
on-site  regeneration  is  employed,  a  furnace, quench tanks,  a
spent carbon tank, and a reactivated carbon  tank  are  generally
required.     Contract  regeneration  at  a   central  location  is
frequent commercial practice.
                               13*

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An example of an activated carbon adsorption  unit  is  shown  in
Figure VII-6.

Carbon adsorption systems are compact, will tolerate variation in
influent  concentrations  and  flow  rates  and  can be thermally
desorbed to recover the carbon for reuse.   Economic  application
of  carbon  adsorption is limited to the removal of low pollutant
concentrations.    Competititive   adsorption    of    non-target
constituents,  as well as blinding by suspended solids, can cause
interference.

D.  END-OF-PIPE TREATMENT

In-plant  treatment  processes  are  used   to   treat   specific
pollutants   in   segregated  waste  streams;  end-of-pipe  (EOP)
technologies usually are designed to treat a number of pollutants
in a plant's overall  wastewater  discharge.   The  types  and/or
stages   of   EOP  treatment  are  primary  treatment,  secondary
treatment, and tertiary treatment.  Depending on  the  nature  of
the  pollutants to be removed and the degree of removal required,
combinations of the available technologies are used.

As in the case of in-plant treatment, the 308 Portfolio Data Base
was the principal source of  information  for identifying  the   use
of   EOP   treatment   by    the  pharmaceutical   industry.   inis
information  was requested by both 308 Portfolio mailings.   As  a
cross-check  for  accuracy   and  completeness,  the  308 Portfolio
responses were compared with information available from the other
data bases.

Table VI1-3  presents  a summary of the EOP technologies  identified
by the  various data bases, along with the number  of   plants   that
employ   each process.   A   listing   of  each plant  s end-of-pipe
treatment system  is presented  in Appendix L.

 1•   Primary Treatment

Primary (physical/chemical)  treatment refers  to   those processes
that are nonbiological  in  nature.   Primary  treatment involves (a)
the  screening   of  the  influent  stream  to  remove  large solids and
 (b)  gravity  separation  to  remove  settleable solids  and  floating
materials.   Commonly  used  primary treatment technologies in the
pharmaceutical   industry   are   coarse  solids  removal,    primary
 sedimentation,   primary  chemical  flocculation/clarification,  and
 dissolved air  flotation.

 In selecting EOP treatment processes for  consideration  as  BAT,
 BCT,   NSPS,   PSES,   and  PSNS  technologies,  only those that would
 follow primary treatment  were  examined.
                                135

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 2.  Secondary and Tertiary Treatments

 Secondary (biological) treatment is the principal method by which
 many pharmaceutical manufacturing plants are now meeting existing
 BPT  regulations.   This  is  one  of  the  first  steps   toward
 compliance with future BAT, BCT, and NSPS guidelines.  Biological
 treatment could also be an important technology in meeting future


 Although  it  is discussed as a single EOF treatment alternative,
 biological treatment actually encompasses a variety  of  specific
 technologies   such   as   aerated  lagoons,   activated  sludge,
 trickling filters, and  rotating  biological  contactors.   Since
 there  are  numerous  publications  available  that  describe all
 aspects of the operations  (advantages,  limitations,  and  other
 pertinent   facts),    discussions  of  these  specific  treatment
 processes will be presented  only  in  moderate  detail  in  this
 report.   Although  each has its own unique characteristics,  they
 are all based on  one  fundamental   principle:   the  reliance  on
 aerobic   and/or  anaerobic  biological  microorganisms  for  the
 removal of oxygen-demanding compounds.

 An aerated lagoon is one example of a  treatment  facility  which
 utilizes  aerobic  biological   processes.    It   is  essentially a
 stabilization  basin  to  which  air  is   added  either   through
 diffusion or  mechanical  agitation.   The air provides the oxygen
 required for  aerobic biodegradation of  the organic  waste.    If
 properly  designed,   the  air   addition  will   provide sufficient
 mixing  to maintain the  biological solids  in suspension  so  that
 they  can be  removed   in a secondary  sedimentation tank.  After
 settling,  sludge may be recycled to the head  of  the  lagoon   to
 ensure  the presence  of  a properly acclimated seed.   When  operated
 in this manner,  the aerated lagoon is  analogous to  the activated
 sludge  process.   The viable biological  solids level  in an aerated
 lagoon  is low when compared to  that  of  an activated  sludge  unit
 The  aerated  lagoon relies  primarily on  detention  time for  the
 breakdown and removal of organic matter; aeration periods of 3  to
 8  days  are common.

 The activated sludge  process   is  also  an  aerobic   biological
 process.    The  basic  process  components  include   an  aerated
 biological reactor,  a clarifier  for separation of biomass,  and  a
piping   arrangement  to return separated biomass  to the  biological
 reactor.  The aeration requirements are similar  to  those   of  an
aerated  lagoon in that aeration provides the necessary  oxygen for
aerobic  biodegradation  and  mixing  to  maintain the  biological
solids  in suspension.  The available activated  sludge  processes
that   are    used    in   the  treatment  of  wastewaters  include
conventional,  step-aeration, tapered-aeration,  modified-aeration,
contact-stabilization, complete-mix and extended-aeration.
                                136

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A trickling filter is a fixed-growth biological  system  where  a
thin-film biological slime develops and coats the surfaces of the
supporting medium as wastewater makes contact.  The film consists
primarily  of  bacteria,  protozoa,  and  fungi  that feed on the
waste.  Organic matter and dissolved oxygen are extracted and the
metabolic end products are released.   Although  very  thin,  the
biological  slime  layer  is  anaerobic at the bottom so hydrogen
sulfide, methane, and organic acids are generated.

These materials cause the slime to periodically separate  (slough
off) from the supporting medium and be carried through the system
with the hydraulic flow.  The sloughed biomass must be removed  in
a  clarifier.   Trickling  filters are classified by hydraulic  or
organic loading as "low rate" or "high  rate."  Low-rate  filters
generally  have  a  hydraulic  loading  rate  of  1  to 4 million
gal./acre/day (or an organic loading rate of  300  to  1,000  Ib.
BOD5/acre-ft./day),   a   depth   of   6   to  19  ffet,  and   no
recirculation.  High-rate filters have a hydraulic  loading  rate
of  10  to  40  million gal./acre/day, an organic loading rate  of
1,000 to 5,000 Ib. BOD5/acre-ft./day, a depth of 3  to  10  feet,
and a recirculation rate of 0.5 to 4.0.  High-rate filters can  be
single  or  two  stage.   The  medium  material used in trickling
filters must be strong and durable.  The most suitable medium   in
both  the  low-and  high-rate  filters is crushed stone or gravel
graded to a uniform size.

The rotating biological contactor  (RBC)  process  consists  of   a
series  of  disks  constructed  of  corrugated plastic plates and
mounted on a horizontal shaft.  These disks  are placed in a  tank
with  contour  bottom and  immersed to approximately 40 percent  ot
the diameter.  The disks rotate as wastewater passes through  the
tank  and  a  fixed-film   biological  growth similar  to that  on
trickling filter  media  adheres   to  the  surface.   Alternating
exposure  to  the wastewater and the oxygen  in the air results  in
biological oxidation of the  organics   in  the  wastes.   Biomass
sloughs  off   (as   in the  trickling filter)  and  is carried  out  in
the effluent  for  gravity separation.  Direct recirculation  is not
generally practiced with the rotating biological  disks.

There  are   a  few  other   biological   treatment   techniques  not
specifically  mentioned  in this   section   which utilize  either
aerobic  or   anaerobic  biodegradation   or    both.     These  are
stabilization  ponds,   anaerobic  lagoons and facultative  lagoons.
 In facultative  lagoons,   the   bacterial   reactions   include  both
aerobic  and  anaerobic decomposition.

Besides   the  direct  utilization   of   these treatment processes,
biological  treatment  also  encompasses  two  other  approaches;   in
 this   report,   they are referred  to as  biological enhancement and
 biological   augmentation.    Generally,    these   variations   are
                                 137

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 accomplished  by   (a)  modifications  made   in  the  conventional
 biological  treatment  itself  or   (b)   conventional   processes
 combined  into  a  multistage  system.   Examples  of  biological
 enhancement are  pure  oxygen  activated  sludge  and  biological
 treatment    with    powdered   activated    carbon.    Biological
              iCSUl/   b\  trickling   filter/activated   sludge,
             h-   ge/  ,,rotatin(3   biological   contactor,  aerated
             hing  pond,  or  any  combination  of  two  or   more
 conventional biological treatment processes.

 The  differences in performance inherent in differences in number
 °Lj!Jages .^Jt  on  the  applicability  of   plug-flow/back-mix
 effects.    A  true  plug-flow  system,  such  as a narrow channel
 lagoon,  approaches equivalence to an infinity of  stages  if  the
 food/microorganism  (F/M)  ratio  is  maintained.    This tends to
 beneficially maximize the availability of nutrients,   a  function
 of   the  concentration of  biodegradable pollutants.   A fully back-
 mixed system (as an activated sludge unit tends to  be)  operates
 throughout  at   its  exit  concentration.   It is thus a distinct
 finite stage incremental  with any stage before it  or  after it.   '

 In practice,  these distinctions  are  not clearcut.   Since  there  is
 some  back-mixing even in   a  channelled  lagoon,   separations   of
 units or  even of  cells within one unit may  be beneficial.   Also,
 iJLJ^t mixed systems,  the concentration gradient  established   is
 sufficient  for   some    increase    in  the  effective  nutrient
                                                    microorganSm
   .,,~,* sy?temf'  design  factors other than the concentration-
induced driving force may overshadow the  concentration  gradient
and prevent simple performance correlation.

Comprehensive   consideration  of  the  criteria  affecting  bio-
reaction performance suggests the following to be significant:

     (1)  Influent concentration of pollutants.
                                           i
     (2)  Resistive characteristics of the BOD pollutants and the
     resultant K value (i.e.,  how easily the BOD is biodegraded) .
     (3)   Presence of  potential  interfering  pollutants
     constituents toxic to the microorganisms).
   (e.g.,
     (4)   Bio-reaction characteristics and concentration  of
     microorganisms present.
      the
     (5)   Dissolved oxygen content and distribution at
     the  point  of  adequate 02  availability.
least  to
                              138

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     (6)   Sludge  recycle  as   it   may   affect   microorganism
     availability and character as represented by the F/M ratio.
     (7)
Contact efficiency of pollutants and microorganisms,
        _.     ....    r- n _ _ 	i_ J_ ^ — —.  ~. M J V1T \ 7C? O
                                                               as
     may be induced by agitation, flow pattern, and MLVSS.
     (8)   Availability  and  balance  of   nutrients,   including
     nitrogen and phosphate.

     (9)   Required target effluent.

     (10) Temperature (e.g.,  seasonal effects)

The proper design of biological systems in addition to developing
optimum operating criteria, must also take into account how  much
of  the  system's  potential  capacity  will  be  used so that an
optimum  modification  approach  will  be  available    The  most
economical  approach  may  be  simple  adjustments  of  operating
variables to exploit existing capacity  fully.   The  adjustments
mav  require  such  minor  changes as increasing agitation, power
input, or sludge recycle rate or, at the extreme, may require the
addition of an independently functioning system.  In  many  cases
the  optimum  upgrade  may be a combination of existing component
units integrated with balanced new  units.    This   is  likely  to
result   in  a  system  complex  dictated   in  part  by performance
requirements and in part by equipment already in place.

Some examples of typical augmented biological configurations  are
shown in Figure VI1-7.

Tertiary  treatment  usually  means  any   treatment following the
biological or other secondary treatment  system.    The  treatment
technologies  are  quite   varied  and are normally applied  for the
removal  of such  pollutants  as   a specific  priority  pollutant
class,   nitrogen,  color,  and so forth.   Some  tertiary treatment
processes are also applicable to  in-plant   or  primary  treatment
schemes.     The   location   in   the  overall  treatment   concept
determines whether the  operation  is a tertiary  treatment.
 Bioloqical  treatment systems are mainly intended  to  reduce  the
 level   of  the traditional pollutants BOD and COD.   Some priority
 pollutants  may be removed incidentally, even though not  targeted
 by the treatments.

 Biological    treatment   removal  efficiency  is  a  function  of
 treatment   intensity,   detention   time,   and   such    system
 characteristics   .as    bioreaction   rate   constant,   biomass
 concentration (as represented by food/microorganism  ratio),  and
 biomass  contact  efficiency.  The configuration of the system is
                                139

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 important since it affects these factors, but  the  effectiveness
 is not necessarily benefitted by splitting the bioreaction into a
 number  of steps.  In a plug-flow  (non-backmixed) system there is
 a continuation of reaction and little inherent effect of  staging
 as  in  certain  separation techniques and driving force systems.
 There may be reaction rate  advantages  in  a  back-mixed  system
 which might accrue from staging but these must be evaluated for a
 specific  system  considering microorganism availability, contact
 efficiency and other factors.

 Economic concerns often dictate  a  design  which  uses  (a)   one
 biotechnique  in preference to others (b) more than one technique
 as the reaction progresses (e.g.,  activated sludge and  trickling
 filter)  or  (b)  various  arrangement  configurations.   However,
 these design choices are highly  site  and  waste  specific,   and
 generalizations  should  be  avoided in the comparison of systems
 and in the choice a particular treatment configuration.


 One of the Agency's data-gathering programs  requested  long-term
 traditional   pollutant data from the industry.   As opposed to the
 screening/verification data obtained by a few  days  of   sampling
 and  the  annualized  308  Portfolio  data,   the  long-term  data
 consisted of raw daily or weekly influent and effluent data  that
 covered  a  period  of  one  year  and was obtained from  22  plants
 having  some  type  of  biological   treatment.    Therefore,    for
 purposes  of  predicting what the  industry:can  achieve in the way
 of  traditional  pollutant control by biological   enhancement,   the
 long-term data  selected  were  the best  available.   Summaries of
 the long-term data are presented in Table V-l.

 The thirteen plants  chosen from  among the 22  pla'nts  (see section
 IX   for   explanation  of  plant  selection)  that submitted  raw daily
 or  weekly  data  indicate  what  existing sources can achieve in   the
 way  of  traditional pollutant  control.   These  plants have achieved
 performance   in  almost   all   cases  which is   greater  than  that
 required by  the  existing regulation  for   BOD5.   and  COD.   Total
 suspended    solids    performance  was  better   than  the average
 performance  of  all plants  with biological  treatment systems.

 3.   Solids Removal

 Removal of solids from EOF wastewater  can  occur at several points
 in  the  treatment  sequence.    Grit   removal    by   screening,
 filtration,  or sedimentation  is often necessary  as a preliminary
 step in primary treatment.  After secondary biological treatment,
 it is generally necessary to complete  the  removal  of  sludge  and
other  solids by means of clarification, filtration, or  a special
operation such as flotation.
                               140

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Further solids removal occurs in tertiary treatment stages, e.g.,
incidentally by retention of wastewater in polishing ponds.

a.   Clarification

Clarification is a method  of  removing  suspended  or  colloidal
solids  by  means  of  gravity sedimentation.  Since the settling
rate of suspended  solids  is  dependent  on  particle  size  and
density (the smaller the particle size and the closer the  density
to  that  of  water, the slower the settling rate), flocculant or
coagulant aids  somkimes  must  be  added  to  promote  bridging
between  particles  and  to  render them more settleable.  A slow
settling rate  and  the  stability  of  colloidal  mixtures  make
chemical      destabilization      and      agglomeration      of
colloids/suspensions necessary.

Clarifiers are usually large  containment  vessels  that   have   a
continuous water throughput.  A conventional clarification system
utilizes  a  -rapid  mix  tank  to mix chemicals with the entering
water; the  wastewater   is  then  subjected  to  slow   agitation
Provision  for  the removal of settled solids  is also a necessary
part of the system.

Typical clarifiers are shown  in Figure VII-8.

b.   Filtration

Filtration  is  a basic solids   removal  technology   in   water   and
wastewater   treatment.   Silica sand, anthracite  coal   garnet   and
similar granular  inert materials  are among  the most  common media
used   in   this technology,   with  gravel   serving  as   a  support
material.   These  media may   be  used   separately  or   in   various
combinations.   Multimedia   filters may  be  arranged  in relatively
distinct  layers by  balancing  the  forces   of  gravity,   flow   and
buoyancy   of   the  individual particles.   This is  accomplished by
selecting appropriate filter  flow rates,  media  grain  size,   and
media  densities.

The most  common  filtration  system  is the conventional  gravity
 filter.   It normally consists of  a deep bed of granular media  in
 an  open-top  tank.    The direction of flow through the filter is
 downward  and the  flow rate is dependent solely on the hydrostatic
 pressure  of the water above the  filter  bed.    An°ther   type  of
 filter  is the pressure filter.   In this case, the basic  approach
 is the same as a gravity filter,  except the tank is enclosed  and
 pressurized.

 As  wastewater  is  processed  through the filter bed, the solids
 collect   in   the   spaces   between   the   filter   particles.
 Periodically,   the  filter  media  must  be  cleaned.    This   is
                                141

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  accomplished   by  backwashing   the  filter  (reversing  the   flow
  through   the   filter   bed).    The   flow-.rate   for  backwashing  is
  adjusted  in such a way that  the bed is  expanded  by  lifting  the
  media  particles  a  given amount.   This  expansion  and subsequent
  motion provides  a scouring action  which effectively dislodges the
  entrapped.solids from the media grain  surfaces.    The backwash
  water  fills   the  tank up to  the  level of a trough below the top
  lip of the tank  wall.  The backwash is  collected  in  the  trough7
  fed  to   a  storage  tank,   and recycled  into the waste treatment
  stream.   The backwash flow   is   continued   until  the   filter   is
  clean.
                                            !
 An example of  a  filtration unit  is  shown  in Figure  VI1-9.

 c.   Flotation                             ,

 Flotation is an optional  method  of  clarification  utilized  to
 treat  some  industrial  waste  in which the suspended solids have
 densities less than that of water.   Air-assisted flotation may be
 applied to some systems with solids slightly heavier than  water.
 As  with  conventional  clarifiers,  flocculants  are  frequently
 employed to enhance the efficiency of flotation.

 E.  ULTIMATE DISPOSAL

 In any evaluation of control  and treatment technologies,  one  of
 the  most   important  considerations  is  the  ultimate  disposal
 methods used by the  industry.    Whether  a  plant  is  a  direct
 discharger  to  surface waters,  an  indirect discharger to POTW's
 or a  zero  discharger can be  a critical  factor in determining  what
 technologies  are   most  appropriate  for  controlling  its  waste
 discharge.    Table  VII-4  summarizes  the  methods   used   by  the
 pharmaceutical  manufacturing  industry for  the  ultimate  disposal
 of its  process   wastewaters.    This  table was  prepared  from  a
 listing of each plant's individual  disposal methods  (See Appendix


 Approximately  13  percent of the   464 manufacturing   plants  have
 direct  discharges.    Seven   of   these   plants also  have indirect
 discharges, while another nine use   zero  discharge   methods  for
 some  of   their  smaller  waste   streams.    The  majority  of the
 industry are indirect  dischargers.    Almost  63  percent of  the
plants in  the 308  Portfolio Data Base discharge  to POTW's.  Seven
of  these  plants  also have direct  discharges, but another 25 use
zero  discharge  techniques   for  some   of   their  smaller  waste
streams.   Over   25  percent  of  the  manufacturing plants use only
such zero discharge  methods as   contract disposal,   evaporation
ocean  dumping, recycling,  and so forth.  Seventy-five percent of
the  zero  dischargers  were  classified  as  such   because  they
generated no process wastewaters requiring  disposal
                               142

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                           TABLE VII-V
             SUMMARY OF IN-PLANT TREATMENT PROCESSES
In-Plant Technology

Cyanide Destruction
Chromium Reduction
Metals Precipitation
Solvent Recovery
Steam Stripping
Other Technologies
         Evaporation
         Neutralization
Number of Plants

         6
         1
         3
        29
         7
        19
         9
         5

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                             TABLE VII-2
CONCENTRATIONS FOR
THE PRIORITY POLLUTANT METAT.R
Final Concentration d/a/l)*
Metal
Antimony
Arsenic
Beryllium
Cadmium
Copper
Chromium III
Lead
Mercury
Nickel
Silver
Selenium
Thallium
Zinc
Lime
Settling
800-1500
500-1000
100-500
100-500
500-1000
100-500
300-1600
-
200-1500
400-800
200-1000
200-1000
500-1500
i
Lime Sulflde
Filter Filter
400-800
I
500-1000 50-100
10-100
50-100 10-100
400-700 50-500
50-500
50-600 50-400
10-50
100-500 50-500
100-400 50-200
100-500
100-500
400-1200 20-1200
References
1 16
118,
116
117,
124,
117,
121,
113,
119,
126
1 18,
122,
120,
118,
120,
116
116
114,
120, 121

118, 123,
125
1 18, 1 19,
123, 124, 125
1 15, 118,
120, 121,
120, 121,
124
121, 128
123, 124
121, 126


118, 123.
                                                     124
*Estimated achievable levels reported in the  Inorganic Chemicals
 references iel°Pment D°<^nt 
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                            TABLE VI1-3

            SUMMARY OF-END-OF-PIPE TREATMENT PROCESSES
                      (Data Bases 308)
p»,q-of-Pipe Technology

Equalization

Neutralization

Primary Treatment

       Coarse Settleable Solids Removal
       Primary Sedimentation
       Primary Chemical Flocculation/Clarification
       Dissolved Air  Flotation

Biological  Treatment

       Activated Sludge
            Pure Oxygen
            Powdered Activated Carbon
       Trickling Filter
       Aerated Lagoon
       Waste Stabilization Pond
       Rotating Biological Contactor
       Other Biological  Treatment

 Physical/Chemical  Treatment

        Thermal  Oxidation
        Evaporation

 Additional Treatment

        Polishing Ponds
        Filtration
            Multimedia
            Activated Carbon
            Sand
        °thelecondaryn2hemical Flocculation/Clarif ication
            Secondary Neutralization
            Chlorination
Number of Plants

       .60

       79

       61
       41
       37
       11
         3

       74

       51
         1
         2
         9
        23
         9
         1
         1

        17

         3
         5

        40

         10
         16
         7
         2
         5
         17
         5
         4
         10
         treatment processes were not available.

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                             TABLE VII-4          :

                  SUMMARY OF WASTEWATER DISCHARGES
 Method  of  Discharge
Number of Plants
in the Industry
                                                              Number of Plants

Direct Only
Direct with minor Zero
Discharge
Total Direct Dischargers
Indirect Only
Indirect with minor Zero
Discharge
Total Indirect Dischargers
Combined Direct/Indirect
Dischargers
SUBTOTAL
Zero Dischargers
TOTAL

NOTE: Subcategory counts will
of multiple subcategory

44
9

251
21







not equal
plants.
i



53

272
7
/
332 ,
132
'
464
industry
FATE OF WASTEWATERS AT ZERO DISCHARGE PLANTS (TOTAL
Discharge Method Dischargers
No process Wastewater
Contract Disposal
Deep Well Injection
Evaporation
Land Application
Ocean Dumping
Recycle/Re-use
Septic System
Subsurface Discharge
98
7
o
7
6
2
2
6
	 4
Direct
w/Zero

3
i
t
i
i
•3
•J
1
1
fi
u
fl
u
_g
"^ 7 fff feA Ut* *^
A B
6 A
4
3 A
4
9 8
17 53
• 7 p
/ O
24 61
21
2
11 H
_2 _9

37 80
totals because
INDUSTRY)
Indirect
w/Zero

7
/





3
C
Iyt A
4 2

21
68 20
1C 1
5 1
83

107
27

134












Total
                                  132
                                                          25

-------
              FIGURE VH-1
CYANIDE DESTRUCTION SYSTEM - CHLORINATION
(oe
                                     FEED)
          8
          00

-------
                                              FIGURE VH-2

                               CYANIDE DESTRUCTION SYSTEM - ALKALINE HYDROLYSIS
      CAUSTIC FEED
                   1
•*=•
00
    INFLUENT
F-EED
TANK
                                 STEAM IN       STEAM OUT
                                      REACTOR VESSEL
                                                                  HEAT
                                                              EXCHANGER
                                                                                FLASH
                                                                                 TANK
                                                                RECOVERED
                                                                MATERIALS
                                                                                           EFFLUENT

-------
                                        FIGURE Vn-3



                                  CHROMIUM REDUCTION SYSTEM
ACID FEED
 VD
1UFLUEK1T
                 -*-
                        so, FEED
                   a
                   do
,-
            CMJST1C  FEED
                                                      U
                                                                  U
                                                                  T
                                                                  '
                            EFFLUEMT
                                                                        TO KLUDGE DISPOSAL
                                                                CONTACT

-------
                                   FIGURE  VII-4




                    METALS REMOVAL SYSTEM -ALKALINE PRECIPITATION
LIME FEED
          ALUM  F£ED
                                                                    EFFLUENlT
                                         P15POSAL
SOLIDS  COklTACT
                                                  FILTER.  UlsilT

-------
                               Condenser


                                           Aqueous Layer
                                           Organic Layer
                                           (Product, Recycle)
 Manometer
     FIGURE  VH-5

STEAM  STRIPPING  UNIT

-------
'l:^^^.':':^''':^:i:^:Y^
                                                        SURFACE
                                                        WASH
                                                          CARBON
                                                          BED SURFACE
CARBON
INLET &
OUTLET
                                                      SAND

                                                      GRAVEL

                                                      FILTER BLOCK



                                                      WATER OUTLET
                          FIGURE  VH-6      !

               ACTIVATED CARBON ADSORPTION UNIT
                                152

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        BPT System
                                              FIGURE  VII-7



                                EXAMPLES OF AUGMENTED BIOLOGICAL SYSTEMS




                                           Activated  Sludge
                                        Aeration Basin
                                                                                       Effluent
                                                                                    Sludge Disposal
Ui
BPT System
                                     Rotating Biological Contactors
                                                                                        Effluent
                                                                                    Sludge Disposal
                                               Polishing Pond
        BPT System
                                                                                        Effluent

-------
                 \
                              10
            SLUDGE
       EFFLUENT
INFLUENT
               (a)CIRCULAR  CENTER-FEED  CLARIFIER  WITH
                  A  SCRAPER  SLUDGE  REMOVAL  SYSTEM
INFLUENT
                                                     EFFLUENT
                                             7->  SLUDGE
        (b)CIRCULAR  RIM-FEED,  CENTER  TAKE-OFF  CLARIFIER  WITH  A
             HYDRAULIC SUCTION SLUDGE  REMOVAL  SYSTEM
                                                             INFLUENT

                                                             EFFLUENT
                                                 SLUDGE
             (cJCIRCULAR  RIM-FEED,  RIM  TAKE-OFF. CLAR I F I ER



                          FIGURE  VH-8       i

            TYPICAL CLARIFIER CONFIGURATIONS
                                154

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FLOAT-
CONTROL
VALVE

             EFFLUENT[
                                    FIGURE  VII-9

                                  FILTRATION UNIT
                                    155

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                           SECTION VIII

            COST, ENERGY, AND NON-WATER QUALITY ASPECTS
 A.
INTRODUCTION
 This section addresses the costs,  energy requirements,  and  non-
 water  quality  environmental impacts associated with the control
 and treatment technologies.

 There is substantial variability within the industry  and  within
 each  subcategory  as  to  products,  process methods, plant size,
 wastewater flow,  raw waste characteristics, and  waste  treatment
 methods  employed.    Therefore,  it is appropriate to evaluate the
 impact of limitations on an individual plant basis.

 Treatment costs are largely a function of  wastewater  flow  rate
 and  pollutant  loadings.   Choice  of  treatment methods is also of
 importance and  is   dependent on   wastewater  quality,   effluent
 target,   and  site   considerations.    In-plant treatments are,  of
 course,  largely dictated by  which  specific pollutants are  to  be
 removed.                                    ,

 It   is  not feasible to develop  exact individual  requirements for
 every plant  because  of  the lack   of  data  on site   specific
 considerations  and bioreaction  treatability (K rates).   Instead,
 an  approach has been taken which assumes  conservative (high side)
 valuation of these  considerations  across  the board.

 Capital,  operating,  and maintenance   costs  were developed  and
 applied   to each  of the processing subcategories  for  a variety  of
 in-plant  treatment  and end-of-pipe (EOF)  systems.  The  resultant
 annualized   costs    were    then  generalized  to variations  in
 wastewater flow,  raw wasteload,  and effluent  limitation  levels.
 Cost   "sensitivity"   curves  show the  effect of  these  variables  on
 annualized costs  and investments;  tabulations of  individual  plant
 costs  indicate specific cost details.

 The costs  considered are those costs  likely to  be required   over
 and  above   the   capital   and operating costs associated with BPT
 guidelines  technology.   In other words, the costs noted  are  those
 incremental   to   what   is    necessary   to    meet   current   BPT
 requirements.   Since   all   plants  within   the   industry  are not
precisely  in  compliance with BPT (many being  significantly better
or worse),  an  alternative statement of costs  was  considered   in
 the    plant-by-plant    analysis   projecting    actual    upgrade
requirements relative  to performance  capabilities  indicated  at
the  time of the  308 questionnaire (1977).  A series of  six cases
                                156

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reflecting the various target level options as well  as  starting
bases (BPT or actual) were developed.

B.   COST DEVELOPMENT

1.   Approach

Treatment costs  were  developed  for  the  direct  and  indirect
dischargers in the 308 Data Base.  Raw waste loads and flow rates
were  reviewed  to determine the required treatments for in-plant
streams, wastewater effluents to surface  waters,  and  flows  to
various POTW's.  Average flows and raw waste loads were estimated
for  each  subcategory  to  serve  as bases for cost development.
Individual plant costs were then determined by adjustment of base
costs  for  flow  and  RWL,  allowing  for  economies  of  scale.
Adjustment   of   investment   components  in  proportion  to  an
exponential ratio  is  generally  acknowledged  to  best  reflect
economies  of  scale.   Cost  extensions were applied directly to
plants with sufficient flow and concentration data,.  For  plants
with  insufficient data costs were indirectly applied by assuming
requirements similar to plants with data.

Investment  and  operating  costs  for  individual  plants   were
developed by adjustment of applicable subcategory model plants to
account  for  specific  wastewater flow and concentrations of the
subject plants.  Mixed subcategory plants containing A  and/or  C
were  evaluated  based  only  on  those subcategories since their
flows were judged to predominate.  If both A and C  process  were
used,  an  average  of  the  cost models was used.  If B and/or D
processes were employed, their cost models were employed,  either
individually   or   averaged.    It  should  be  noted  that  the
sensitivity  of  an  individual  plant  cost  to  the  choice  of
subcategory model is not great since the models are substantially
similar on comparable flow and loading bases.

The   base   costs  to  meet  proposed  design  requirements  for
limitations  were  developed  for  average  conditions  for  each
subcategory  as  presented  in  Table  VIII-1.   This was done by
establishing representative values for wastewater flow rates  and
traditional  pollutant loadings for subcategories A, B, C, and D;
costs were then  determined  for  each  of  the  end-of-pipe  and
in-plant  treatment  alternatives  for these representative flows
and loadings.  Since these base costs are not used  directly  but
only  as  calculation  bases  for  adjustment  to  specific plant
situations, the base values of flow  and  concentration  are  not
critical.

Investment  and  operating  costs  were developed by means of the
Catalytic Treatment Model.  It applies end-of-pipe  and  in-plant
treatment alternatives to influent, effluent, and flow conditions
                                 157

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stated    for    each   case.    Because  of   distinctive  processing
techniques  and  materials  employed,  not all   priority  pollutants
are   likely  to  be   associated  with   all;  subcategories   (e.g.,
reactant  and  catalyst chemicals are not likely   to  be   found   in
Subcategory  D  wastewaters).   However,  they  tend to appear  in  the
same  range  of concentrations  in those  subcategories in  which they
do  occur.    Paragraph B.2.   (Case Definition)   summarizes   the
judgment  made   as   to subcategory occurrences  of priority of
pollutants.   Cost development is limited  to   those  instances   of
likely occurrence.                         i

As  indicated  in Section V,  the priority pollutant loadings  for
the individual  subcategories  are effectively represented by   the
median  values  from  all plants in the  Screening/Verification data
base.  These  concentrations of priority pollutants were not found
to  vary  markedly   among  subcategories,  due   in  part to   the
necessity   of relying on  unsegregated  stream data.   For the total
industry, raw waste  concentrations  of  13   of the  most commonly
found priority  pollutants are presented in Table VIII-2.

Following   the   development   of  the  base  costs for the various
flow/loading  levels,  each of  the plants was  analyzed for flow  and
concentration   data,   end-of-pipe   and    in-plant    treatment
requirements,   and   incremental  cost   impacts.    Of the  direct
dischargers,  18  plants lacked sufficient data to  directly  apply
the  treatment  costs.  The indirect dischargers  include 33 plants
with sufficient  data,  144 plants with  flow  data  only,  and   105
plants   with   insufficient    flow   and    concentration   data.
Additionally, the available concentration  data for  the indirect
dischargers   was normally  presented   for  the  total flow to  the
POTW, which includes  process,  sanitary, noncontact  cooling,   and
other   wastewaters.    Further  calculations were  required   to
determine the concentration in process  wastewater prior to mixing
and the consequent estimate of treatment cost if  applied to  this
segregated stream only.

For   plants   with    sufficient   data,   the   current effluent
concentration was compared to  a target  level, and further percent
removal was calculated.  The  percent removal  was   related  to   an
incremental   number   of   "treatment stages1"  and a cost/capacity
extension of  the treatment costs was   applied.    Initially,   the
cost  for  one stage  was extended from  the appropriate  base case;
that cost was then adjusted to  reflect  any  incremental  stages
required.

A similar approach was applied to the plants  with  only  flow data.
The  incremental  stage requirement, however, was  calculated as a
constant based on  the  plants   with  sufficient   data.   Average
additional  percent removals,  average flows,  and  probabilities of
r;t);tequired treatment) were  incorporated into  the base  cases.
                               158

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Exponential  ratio  cost adjustments were made based on the ratio
of plant flow to base flow.  The costs for these  plants  can  be
combined to provide part of the total industry cost estimate.

The  costs  for  plants  with insufficient flow and concentration
data were calculated and applied in a similar  fashion  with  two
exceptions.   First,  the  average  flow  was  calculated for all
plants with flow data (including plants with flow data  only  and
plants with sufficient data on flow and concentrations).  Second,
costs  were  determined  for  this  average  set  of  conditions.
Without any individual  capacity  adjustment,  these  costs  were
applied as a constant to all plants with insufficent data.  These
costs are applicable to an average plant situation and the sum of
these  average plant costs is included in the total industry cost
estimate.

The probabilities of treatment being required for the direct  and
indirect   dischargers  were, calculated  from  the  plants  with
sufficient data.  These probabilities reflect the  percentage  of
total plants not meeting specified targets.  The probabilities of
required treatment  (both end-of-pipe and in-plant) for the direct
and  indirect  dischargers  were  calculated from the plants with
sufficient concentration data.  These probabilities  reflect  the
percentage  of  total  plants  hot  meeting  specified targets as
defined for each case.

Direct discharge plants with flows of 3,000 gallons  per  day  or
less  were  assigned costs for hauling to an off-site centralized
contract treatment  plant rather  than  on-site  treatment  costs.
Hauling  for  such  flows  was  found  to  be  a  more economical
alternative.  This  is illustrated by Figure VIII-24, which   shows
that  the  cost  curves  with  flow variation cross at about this
level.

For situations where a plant was classified as a  direct  and  an
indirect   discharger,  costs were applied to each waste treatment
segment.   The total plant  costs were derived from  the  summation
of   direct,    indirect,   and  in-plant  treatment  costs.   Zero
dischargers are not affected by  this  proposal.   Therefore,  no
costs are  developed for these plants.

2.   Assumptions, Bases, and Limitations

This section describes assumptions  regarding current  performance
levels   and  design  criteria  which were used  in developing cost
cases.   These cost  cases were then  used  to estimate the  loss that
would be  incurred by  plants  in  complying  with   the  anticipated
regulations.

a.    Case  Definition
                               159

-------
 BCT target levels for two levels of concentration and  one  level
 of  percent  removal were considered for direct dischargers.  Two
 comparison starting levels are covered, one, equivalent to BPT (90
 percent removal) and the other reported actjual performance at the
 time of the 308 responses.  One level of pretreatment of indirect
 discharge (200 mg/1 of BOD)  was  considered.   A  single  set  of
 limits for priority pollutants was considered for both direct and
 indirect  discharges.    Thus we developed six distinct cost cases
 each comprehensively covering the cost impacts for all plants.

 Case variations studied cover three potential BCT effluent design
 criteria limitations for direct discharge:

      (1).  40 mg/1 BOD,  40 mg/1 TSS

      (2).  20 mg/1 BOD,  30 mg/1 TSS

      (3).  95 percent removal BOD,  40 mg/1 TSS

 Upgrade costs for direct  dischargers  were  developed  from  two
 starting  bases.    BPT   performance  and actual  performance.  BPT
 performance of 90 percent removal  of BOD was not  fully  achieved
 at   the  time of the 1977 308 questionnaire.   Some plants met and
 even exceeded that level,  but many more did not.

 Cost cases are set forth as  follows for direct dischargers:
OPTION CASES BASED            UPGRADE  FROM
ON EOP DESIGN CRITERIA LIMITS     BPT
40 mg/1 BOD
40 mg/1 TSS

20 mg/1 BOD
30 mg/1 TSS

95% Removal BOD
40 mg/1 TSS
Case I


Case II


Case III
 UPGRADE FROM
ACTUAL REPORTED

   Case IV
   Case V


   Case VI
The costs of each treatment case were developed  for  all  direct
dischargers  using  the  data  supplied  by the plants  (flows and
influent and effluent  concentration  values).   In  cases  where
concentration data was not supplied, average values were used for
influent  and  effluent concentrations and the costs were derived
in the same manner as the  costs  based  on  known  influent  and
effluent  concentrations.   The  technology options chosen as the
control bases for the traditional pollutants (to be regulated  by
BCT,  BAT,  and  NSPS)  do  not  equate exactly to any of the six
option cases described because they  require  the  attainment  of
different  effluent  target  levels  for  BOD5_, COD, and TSS than
                              160

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specified above.  However, the overall technology bases  (varying
decrees of biological enhancement or augmentation as required) of
these  regulations  are  only  different  in  that  they  involve
slightly  different  design  requirements  to   accommodate   the
different  target concentration levels.  Plant-by-plant costs for
the  chosen  BCT/BAT  option  were  developed  by  allowing   for
necessary design modifications to Option Case IV.  The costs were
then  calculated  for  all direct dischargers requiring treatment
uparading based on  data  submissions.   New  source  costs  were
estimated  for  an  average new source direct discharger using an
adjustment of Option Case V.   In  addition,  pretreatment  costs
were  estimated  for  indirect  dischargers assuming plants would
discharge effluent containing 200 mg/1 or less of BOD5 to  POTWsj
All   costs   are  included  in  the  technical  record  of  this
rulemaking.                                                      \

In-plant treatment requirements developed to  meet  revised  BPT,
PSES, and PSNS  for the treatment most probably applicable to each
process subcategory  in each plant are:
            Steam Stripping
Subcategory   of Volatiles
 Fermentat ion

     B
 Biological
 Extraction
 Chemical
 Synthesis
                  Yes
Yes
                  Yes
                   No
                Cyanide
               Destruction

                   No
                   No
                                    Yes
                   No
 Formulation

 There  are exceptions to the exclusions set forth in this listing
 (e g.,  the use of cyanide-related materials  in  the  Vitamin-B12
 manufacture  via fermentation)  (42);  however,  for purpose of cost
 approximation, treatment for removal  of  priority  pollutants  is
 considered  whenever  actual  effluent  data reported for a given
 plant exceeds the following values:
 All volatile organics
 Cyanide
                                EOP Value

                                   1200
                                    200

            (all  values  in micrograms/1iter)
                               161

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 Removal  methods  for  priority  pollutants  for  which  specific
 processing  costs  were  developed  include  steam  stripping for
 volatile  organics,  alkaline  precipitation  for  most   metals,
 chromium  reduction,  and oxidative destruction of cyanide.  Other
 priority pollutants can be removed by methods which are generally
 cost equivalent to the methods which  have  been  costed.    These
 pollutants  include  phenol,   mercury,   and  other  metals.    The
                                               not  analyzed   here
                                                exchange,   sulfide
techniques which might be employed, although
for   cost   detail,   might   include   ion
precipitation, and thermal oxidation.
 Costs  for  in-plant  treatment   of   toxic  volatile  organics   and
 cyanide  were  developed for  individual  plants when  a comparison of
 the    data submitted   with the  above   effluent   target  values
 indicated   that   treatment   for cyanide  and/or   toxic   volatile
 organics was  required.   Costs  were also  estimated  for  plants  that
 did  not supply  effluent priority  pollutant  data by assuming  that
 the above   target  values   and  average   raw  waste values  were
 applicable to these plants.  Although  the Agency will  not develop
 limitations   on   metals in this   rulemaking,  costs  for metals
 precipitation and  chromium  reduction   (developed on   a basis
 similar  to that used  the cyanide  destruction and  steam  stripping
 cost development)  are  included  in the   technical   record.    The
 components of   all  in-plant   costs are discussed  in  the ensuing
 subsections.
b.
     Cost Factors
                                           i
The following major capital and operating cost factors were
throughout the costing effort:
                                                             used
(1)  Land - The cost estimates  presented  do  not  include  land
     costs.   The cost of land is variable and site dependent and
     cannot be estimated  on  a  national  basis.   For  in-plant
     systems,  the  necessary  equipment usually can be placed in
     existing structures near the source  stream  being  treated.
     For   end-of-pipe   systems,  the  total  area  required  is
     indicated.

(2)  Piping and Pumps - Where  required,  piping  and  pumps  are
     assumed to be 20 percent of basic equipment costs.

(3)  Delivery and Installation - These costs are assumed to be 50
     percent of total equipment costs.

(4)  Engineering and Contingency - These costs are assumed to  be
     30 percent of total installed costs.

(5)  Energy - Electricity costs are assumed to be $0.04 per  KWh-.
     Annual  power  costs  for mixing and pumping are computed as
                              162

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(6)


(7)


(8)


(9)
     (Total  horsepower)  x   (8760  hr/yr)  x   (0.746  KW/hp)    x
     ($0.04/KWh).

     Operating Labor - A  rate  of  $10/hr  including  taxes  and
     fringe benefits is assumed.

     Maintenance - Maintenance  costs are  assumed  to  be 3  percent
     of  total capital costs.

     Sludge Disposal - This  cost   (including   transportation)   is
     assumed to be $0.30 per gallon.
Capital Amortization  -
percent at 10 years.
                         This
                                    figure  is  estimated  at   10
                   -
News Record Construction  Index  number  was
         --
                                                   2670  and  the
           an          Plant Cost Index number was 2 0.6 .See
     Appendix  N tor tabulation of these indices.)  Capital costs
     for  such  major  equipment  items  as  tanks,   clarifiers,
     filters,  mixers,  sludge thickeners, and vacuum filters were
     obtained from equipment manufacturers and from a  ^tewater
     treatment  cost  data base Catalytic, Inc. developed for the
     Effluent Guidelines Division (131, 132).

c.   Cost Sensitivity Bases

Additional assumptions and bases necessary for derivation of  the
cost variations are:

(1)  Investment costs vary with  the  0.7  exponential  power  of
     wastewater throughput.

(2)  Break points or discontinuities in equipment  sizes  (as  they
     vary with flow or performance) are not  considered since they
     are  likely to be plant specific and potentially misleading.
     A smoothed transition form of  capacity  and   investment  data
     is preferred and used.

(3)  Sludge-dewatering  equipment   size   or   disposal  volume   is
     directly  proportional  to  quantity of sludge  generated.
     Disposal  costs are constant per unit of sludge  handled.

(4)  Within  the ranges considered,  labor  cost is considered  to  be
     constant  and  independent  of  equipment size  or throughput.

(5)  Treatments requiring the  addition of pH-adjustment  chemicals
     utilize such  chemicals  in proportion only to the  amount   of
     water treated.
                               163

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 (6)   Treatments based on  chemical  reaction  of  pollutants  are
      considered to require reactant-treatment chemicals in direct
      proportion to the amount of pollutant removed.

 (7)   Cost Factors applied to investment,  labor,  and  other  costs
      remain valid within the range of data and results presented.

 d.    Plant-by-Plant Cost Bases

 The  bases on which the plant-by-plant costs were developed are:

 (1)   Treatment Stages - Treatment systems costs  are  estimated  in
      relation  to  the  base costs determined by BRISC/Catalytic.
      The   extent  of  treatment   is  defined  as   a   stage   of
      biotreatment   and   is  assumed  to  :be equivalent   to  be
      approximately 85 percent BOD removal.

 (2)   Treatment Choice - Activated sludge  is used as  a cost  basis
      for  biological  treatment.   Although  it is not expected to  be
      the   treatment   selected for  every  case,   it  is the most
      broadly applicable technology and  should be  a   conservative
      cost   representation   of   other  treatment methods   (e.g.,
      aerated lagoons,  trickling  filters,  etc.).

 (3)   Bio-reaction  Kinetics - The degree of   biological  treatment
      is   developed  as  a  function of  percent BOD removal required
      to meet target  performance.   The bio-reaction is   considered
      to   be   first  order,   with  a constant K value equal  to the
      conservative  value of 1  used in  the  base study.

 (4)  Extent   of  Treatment   -  Since  detention   time   and   the
     consequent    holdup   volume  of  the   system   is  directly
     proportional  to  the  number  of  "stages",  system   investment
     cost  also  can  be  related.  The  counting of "stages"  is an
     artificial calculation  convenience used  to  compare extent of
     treatment by  comparison to  an arbitrary   standard  treatment
     extent,  chosen  at  about   85  percent BOD5_ removal for the
     purposes of these calculations.    Investment  was  taken  to
     vary  as the  0.7 exponent both of the system throughput rate
     and of the number of stages.  For the  sake  of  simplicity,
     those  system parts  (pumps,  piping,  instrumentation,  and the
     like) not varying with holdup are not estimated separately.

(5)   Throughput Effect - Wastewater flow rate  is also  considered
     to  influence  system capacity proportionately and therefore
     is also scaled by 0.7 exponent.

(6)   Low-Flow  Alternative  -  A  few  plants  among  the   direct
     dischargers  indicate  flows  to  be  low  enough to  require
     exhorbitant additional treatment cost per  unit  of  volume.
                               164

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(7)
(8)
(9)
 (10)
In  such cases, the alternative of hauling the small volumes
of wastewater to a  POTW  or  to  a  neighboring  industrial
treatment  facility is substituted.  The break point between
these methods is approximately 3,000 GPD.

TSS Removal  -  Costs  developed  for  biological  treatment
systems include secondary TSS removal.  However, there are a
few  direct dischargers for which biotreatment is not needed
but TSS treatment is.  A separate TSS removal  is  estimated
and  included in such cases.  Because of the small magnitude
of these costs and  the  uncertainty  of  applicability,  no
estimates of supplemental TSS costs were made for the plants
with insufficient data.

Direct Discharge Data Projection - Flow  data  are  reported
for most direct discharge plants.  However, performance data
in terms of influent and effluent BOD concentrations are not
available  in  the  308  data  for  a  substantial number of
plants.  If either  influent or effluent data  (not both)  are
missing,  current   BPT  compliance performance at 90 percent
removal is assumed.  If both are missing, an  average   level
of   treatment   based  on  known  treatment  plants  and  a
probability of  biotreatment  being  required  are  used  to
estimate a probability-weighted cost for each plant.

Indirect Discharge  Data Reported Projection - Data  reported
forindirect  discharge  plants   are not as  complete as the
data for direct dischargers.   Flow  data  as  well  as  BOD
concentrations   are   lacking   for   many   plants.    Where
concentration  only  is missing,  treatment  requirements  and
costs   are    scaled   t6   individual  volumes   based   on  a
"representatively   average"  plant  that  supplied  complete
data.   Where  flow also   is not  known, an average plant  is
developed  from those with data, and  its  costs  are  used   to
estimate   an   average  set  of  costs  applied  to all of the
plants  without data.

In-Plant Data  Projection   -   In-plant   treatment   data are
subject" to"considerable uncertainty  since wastewater  flows
and  concentrations  are   reported   on  an  end-of-pipe   or   a
combined   influent   basis.    Thus   flows  and local priority
pollutant  concentrations before  combination  and equalization
are  not available.   Based on  reasonable  processing  mix,   an
estimate   was  made that, for  a  typical  plant,  10  percent  of
the  total  process  wastewater   is   subject   to  each  of  the
 in-plant   treatments  applicable.   It is to  be expected that
actual  plants  will  vary  substantially above  and  below   this
proportion.    Average treatment  costs are  developed based  on
 those  plants with  data.   These averages  are  factored  by  the
probability of a treatment  being  required  for plants  without
                               165

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      data  and
      plants.
the resultant costs have been developed for these
      The application of a probability of treatment as well as the
      estimated wastewater proportion  prevents  reliance  on  the
      accuracy  of  individual  plant  costs so calculated.  These
      cost effects should be relied on  only  as  an  estimate  of
      cumulative effects for the plants without data.

 3.    In-Plant Treatment Costs

 In-plant treatment is directed  at  removing  certain  pollutants
 from  specific  waste  streams  before the water is combined with
 other wastewaters.  The costs of in-plant treatment  alternatives
 allocated to any pharmaceutical plant must be based upon the flow
 of   the  process wastewater stream bearing the specific pollutant
 or  pollutants of interest.   To prepare costs for the   subcategory
 base  cases,   the  flow  rate  of  the process waste  stream to be
 treated by in-plant  treatment  systems  was  assumed  to  be  10
 percent  of  a plant's total wastewater flow since in-plant flows
 are seldom reported individually.   In addition,   it  was  assumed
 that  the  entire  mass  loading  for  each  case  of the subject
 pollutant  (calculated  from  the  data  in'  Table VIII-2)    was
 contained  in  the  process  waste  stream.    The  major priority
 pollutants found  in  pharmaceutical  wastewaters  were  cyanide,
 metals,   and   solvents.   Therefore,  cost estimates were developed
 for treating  these three classes of  pollutants.

 a.    Cyanide  Destruction

 Cyanide  has been identified in the wastewaters  of a  number  of
 pharmaceutical   plants.   Table VIII-3  contains the equipment  cost
 bases  and energy requirements  for  oxidation  with  hypochlorite  in
 an  alkaline environment.                    :
                                            I

 Capital   cost  items   are  presented  in Table VII1-4 and  include
 detention tanks,  mixers,  piping and  pumps, and automatic chemical
 feed systems.   The annual operating  costs  for  base conditions and
 variations  are  shown  in  Tables VII1-5  and  VII1-6.    To  estimate
 the  annual   cost  of   chemicals,  it  was  assumed  that  1.2  Ibs of
 hypochlorite  ($0.60/lb)  and  1.4 Ibs  of   caustic   ($0.12/lb)   were
 added  to  each  1000  gallons  of  wastewater  treated.

 b.   Chromium Reduction

Chromium  in wastewaters  can occur  in either  a  hexavalent  or a
 trivalent  state.   Hexavalent  chromium  is extremely soluble while
trivalent chromium  forms  an insoluble hydroxide.   Therefore,  the
first step  in the  treatment of  chromium  is the reduction  of   the
hexavalent    ions   to  the  trivalent  state.   This  usually  is
                               166

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accomplished with sulfur dioxide at low pH values; however, other
reducing agents can be used.

The pH of the wastewater containing  the  trivalent  chromium  is
adlusted  to  the  range  (8  to  10) where chromium hydroxide is
precipitated  and  removed  by  clarification.    The   procedure
generally  is  performed  on  a  batch basis for systems below 15
gallons per minute and on a continuous basis for larger ^systems.
Table  VII1-7  presents  the  equipment  cost  bases  and  energy
requirements for chromium reduction systems.   Adjustment  of  pH
and clarification are included as part of the systems cost.

Tables  VIII-8  through VIII-11 present the capital and operating
costs for base conditions and variations.  Chemical  requirements
for  the systems presented  include 0.45 Ibs of sulfur dioxide  ($0
,15/lb). 0.45 Ibs of sulfuric  acid   ($0.06/lb),  and  2   Ibs  of
caustic  ($0.12/lb) for each 1000 gallons of wastewater treated.

c.   Metal Precipitation

Metal removal generally is  accomplished by pH adjustment   in   the
range of 8 to 10.  After, the metal hydroxide precipitates formed
bv  the  pH adjustment are  removed by  clarification.  There are  a
variety  of chemicals that can be used  to aid  in  the precipitation
and clarification process;  however, the data presented in  Tables
VI11-12  and  VI11-13 are based upon  lime and alum addition since
they are commonly used.  Sulfide precipitation,  similar  in cost,
is also  frequently employed.

Table  VII1-12   presents the design bases and energy  requirements
for metal  precipitation.   Solids-contact-type   clarifiers   were
used for costing purposes.  These  units  include  a flash  mix zone,
a flocculation  zone, and a  settling  zone  in  one  unit.

Since  metals   removal  by precipitation  requires very little  head
loss, most systems will be  operated  by the  head  already  available
in the  wastewater  effluent   line.    The   miscellaneous   energy
requirements   shown   in Table  VIII-12 include  those  for chemical
addition and  sludge  removal.

Table VIII-13  presents  the  capital cost  items for the  base  case
for   the  systems  outlined,  while Tables VIII-14 through  VIII-16
show   the   annual  operating   costs   for  base    conditions   and
variations.     Capital    amortization   (capital   recovery  plus
 interest)  is  the largest  portion of  annual  cost.

d.   Steam Stripping

A study (72)  conducted by  EPA  on  the  applicability  of  steam
 stripping   for  treating   wastewaters containing organic priority
                               167

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 pollutants shows  that  this   technology   is   a   feasible  in-plant
 treatment  method  for the  pharmaceutical  manufacturing industry
 and is  in fact currently  in  use.

 Since no other specific cost data were available, the preliminary
 figures reported  in that  study are used  in  this document.   Table
 VIII-17  presents   capital   and  annual  operating costs for steam
 stripping.  As work continues in this area,  more  detailed  cost
 information can be developed and incorporated  into the  analysis.

 4.   End-of-Pipe Treatment Costs

 Bi?i°iiCal treatment was found to be  the  principal  end-of-pipe
 method  in  use  by  the majority of pharmaceutical mcinufacturing
 plants now seeking to meet existing BPT  limitations  guidelines.
 This treatment alternative consists of such specific technologies
 as   activated   sludge   systems,   trickling  filters,   rotating
 biological contactors,  lagoons,  etc.   In addition,  variations  in
 the  application  of  these  specific  technologies  can  improve
 biological  treatment.     Modifications   and   combinations   of
 conventional   biological  treatment  processes are referred to as
 biological enhancement  and augmentation.

 a.   Biological  Treatment

 For the  purpose  of developing costs,  combinations   of  biological
 treatment  processes were  considered  for biological  treatment.
 The assumption was made that  a   conventional  biological  process
 would  be  added   to a BPT  system  already  in place.   For costing
 purposes,  those plants  lacking effluent  data were  assumed  to   be
 meeting  the existing BPT (90  percent  removal)  limitations.

 Data  analyses conducted during  this  study  indicate a significant
 number of  plants   utilizing  biological  treatment   can  achieve
 effluent   levels   of 40 mg/1 BOD and 40  mg/1  TSS  (an improvement
 over BPT systems in many cases).

 Table  VIII-18  presents   equipment    cost    bases    and  energy
 requirements   for   activated  sludge   systems   designed   for four
 subcategory base levels developed for cost calculation   purposes.
 Capital  cost  items  are  presented  in Table VIII-19 and include
 typically such auxiliary equipment as  aeration  basins,   aerators,
 nutrient-addition    equipment,  clarifiers,  and  sludge-handling
 facilities.  The total  annual  costs  for  base  conditions  and
 variations are shown in Table VII1-20.

Rotating  biological  contactors  (RBC's)  were  another  type of
biological treatment considered.   RBC systems were sized  for each
of the base conditions and were based  upon  the  data   in  Table
                              168

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                                                             base
        ecaep    o,
        Capital cost items and annual °P*«ting  costs  for  base
conditions  and  variations  are  presented  in Table VIII 24 ana
include excavation, grading, compaction, . an imper vjous liner^ and

Iolis9^?n?f %?ea^f sho ?d                    1hn

thf present value of such costs is judged to be

For nlant-bv-plant cost evaluation,  activated  sludge  treatment
was  considered  to  be  representative of the various biological





modification of existing systems,  although  ^"btedly   feasible
in  many  cases, because site-specific  knowledge of  each plant was
not available.

b.   Biological Treatment  and  Filtration

Filtration  can be  used as  a polishing  step   following  Biological
treatment  for  increased  solids  removal.   Analyse sindi cate that
effluent  concentrations of 20   mg/1  BOD   and  30  mg/1   TSS  are
achievable   with    biological   treatment    and    filtration  ot
pharmaceutical wastewaters.

Table   VI I 1-25  presents   equipment   cost    bases    and   energy
 VIII-27.

 Cost  estimates were also prepared .for filtration units following
 RRP easterns   The RBC units were sized for the  desired  eftiuent
 aualitv   increasing the total RBC surface area above those shown
 Tn Table vm-!T?  The same dual media filters as those  Provided
 iith  activated  sludge  systems   are specif led in Table VIII-28
 Capital and total annual costs for base conditions and variations
 are given in Table VIII-29.
                                169

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  c-    Low-Volume Wastewater Hauling
                      °Perati°ns  making  up   the   pharmaceutical
                     3  large  number  of  Plants wifch small volume
             dlscharges.   Many of these flows are so small that the
  cost  of conventional treatment, expressed as  cost  per  unit  of
  wastewater   flow,   would  be  comparatively  quite  llrge    Most
              lanJS  aP indirect dischargers to a POTW and have  no
              "astewater   treatment.   However, a few may be located
           this  is  not practical.   In such1 situations,  it  may  be
               t0 fl?d a  means  of  consolidating such small volumes
  w       <-er v?lume  system (e.g.,  hauling the  wastewater  to a
  POTW  or other combined treatment  system).

  An analysis  of wastewater  hauling costs  is  presented   in  Figure
  VIII-24 and is   supported  by Table VIII-30.   A range of hauling
 mifef CanSeP™nent*?  by  Parameters   of   round-trip  hauls  of   50
  hiJTfnn^fS  •  ? ^   S a^e Considered.   Investment for wastewater
 hauling  is included,  as  is destination cost   of  treatment    The
 current  criterion of $.36 per pound of  pollutant  (1980)  is taken
 cost reasonable aPProximation   of  a  combined  system  treatment
 armmn<-        moderately  small  flows of wastewater might be
 accommodated  by  intermediate-scale  methods,  such   as   small
 package-type  treatment  units or evaporation ponds?  Since these
 approaches are expected to be intermediate in cost  and  in  mlny
 ?S5? -A involve  .site-specific   circumstances,   they  are  nSt
 individually analyzed.   Hauling costs are considered  to  set  an
 upper,  conservative limit for small volumes.


 a£ti5??]3r«i!!3!!lln8!  aS  opP°sed  to a standard treatment .such as
 activated sludge,  becomes advantageous at about 3,000 gallons per


 5.    Cost Sensitivities
                   tr?jtment  cost  with  wastewater  flow,  raw  waste
mo                  effluent  concentration  level are recognized by
means of the  cost  sensitivity   curves   shown  in   Figures  VIIl-i
SfSyS,. VIII~24'    Subcategories are  presented as plrlmetrically
distinct curves.   The  cost axes are  stated   as   annual   cost   of
pT«S   ?   °r4-au COSt  per thousand gallons of wastewater  treated.
Flow rate must be  considered because of  its  effects on  treatment
plant investment and annual costs.                      i.i««uneni.

Biological  treatment  systems  are directed  toward  removal  of  BOD
?emoval.a related manner^  COD,   also  with   supplemental   solids
                               170

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In-plant  treatment  is  directed  primarily  toward reduction of
priority pollutants.  Cost sensitivities developed for  treatment
systems in both areas cover the following:

(1)  Activated Sludge,  Annual  Treatment  Cost  vs.   Wastewater
     Flow.
(2)  Activated  Sludge  With   Supplemental   Treatment,   Annual
     Treatment Cost vs. Wastewater Flow.

(3)  RBC System, Annual Treatment Cost  vs.  Wastewater Flow.

(4)  RBC System With Supplemental  Treatment,    Annual  Treatment
     Cost vs. Wastewater Flow.

(5)  Polishing Pond, Annual Treatment Cost  vs.  Wastewater Flow.

(6)  Cyanide  Destruction,  Annual Treatment  Cost vs.   Wastewater
     Flow.
 (7)  Cyanide  Destruction,  Annual Treatment  Cost vs.   Influent  CN
     Concentration.

 (8)  Cyanide  Destruction,  Unit  Treatment  Cost  vs.   Wastewater
     Flow.

 (9)  Cyanide  Destruction,  Unit Treatment  Cost  vs.   Influent  CN
     Concentration.

 (10) ChromiumReduction,  Annual  Treatment  Cost  vs.   Wastewater
      Flow.
 (11) Chromium Reduction,  Unit Treatment Cost vs. Wastewater Flow.

 (12) Chromium Reduction,  Annual Treatment Cost  vs.   Influent  Cr
      Concentration.

 (13) Chromium Reduction,  Unit  Treatment  Cost  vs.   Influent  Cr
      Concentration.

- (14) Chromium Reduction,  Annual Treatment Cost  vs.   Effluent  Cr
      Concentration.

 (15) Chromium Reduction, Unit  Treatment  Cost  vs.  Effluent  Cr
      Concentration.

 (16) Metals  Precipitation, Annual Treatment Cost  vs.  Wastewater
      Flow.
                                171

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  (17)  Metals  Precipitation,  Unit   Treatment  Cost   vs.   Wastewater
       Flow.

  (18)  Metals  Precipitation,  Annual   Treatment  Cost  vs.   Influent
       Metals  Concentration.

  (19)  Metals  Precipitation,  Unit   Treatment  Cost  vs.   Influent
       Concentration.
                                            i
  (20)  Metals  Precipitation,  Annual   Treatment  Cost  vs.   Effluent
       Metals  Concentration.                 ;

  (21)  Metals  Precipitation,  Unit   Treatment  Cost  vs.   Effluent
       Metals  Concentration.

  (22)  Steam Stripping, Annual Cost vs. Flow;Rate and  Steam Cost.

  (23)  Steam Stripping, Unit Cost vs. Flow Rate  and  Steam Cost.

  (24) Wastewater Hauling Costs vs. Wastewater Flow.


 C.    ANALYTICAL COSTS FOR MONITORING PRIORITY POLLUTANTS


 In  addition  to  the  cost  of   treatment  facilities  to  remove
 priority   pollutants,    the  cost  of  monitoring  the  priority
 pollutants discharged must be considered.  An estimate  of  these
 costs is shown  in Table VII1-31.

 The  basis  for  these  costs  assumes  a typical  slate of eleven
 priority pollutants to be monitored by the  example  plant:   five
 volatiles   (including   acid  extractables),  five  metals,   and
 cyanide.   This  slate  cannot cover  all  plant situations,   for
 purpose   of costing;  but it is  judged to be representative of the
 priority  pollutants  most  commonly  found  in the   industry's
 wastewater.                                               Muouty &

 Several   methods   of   analysis  are  available  for each category of
 pollutant.  For volatiles  and extractables,  the methods  are   gas
 chromatography  (GC), high-pressure  liquid  chromatography  (HPLC),
 and  gas  chromatography with  mass  spectroscopy (GC/MS).   Of these
 methods,   GC  and   HPLC  were judged  to be appropriate for  routine
 use, as  they  are considerably less expensive  than  GC/MS.   A GC/MS
 run  would  be  made  at  intervals for confirmation of the  GC  or  HPLC
 results  and  for   identification  of  any  unexpected   priority
pollutants.   An   interval of one GC/MS  for every  ten samples  was
selected as reasonable.  Which method, GC or  HPLC,  might be   used
for  routine  analysis   would depend  on the specific  pollutants
present and established  analytical   capabilities.   However,   the
                               172

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costs are very similar.  Extractables would be analyzed using the
same  methods  employed  for  volatile  organics, but preceded by
appropriate extraction.

A colorimetric test was selected for cyanide analysis.  Two tests
were considered for metals analysis: Inductively  Coupled  Plasma
(ICP)  and Atomic Absorption (AA).  A cost range for each element
analyzed was established covering these methods.

Costs of the applicable analyses are  expected  to  vary  with  a
number  of  site-and location-specific factors.  For example, the
cost of analysis would vary with the cost-of-living if  the  area
where the plant is located.  The cost of analysis would also vary
from  lab to lab, since each lab sets its own prices.  The number
of pollutants analyzed would also be a factor.  For this  reason,
a range of costs is presented along with a weighted average.  The
costs  given  are  based  on quotations from labs in Baton Rouge,
Louisiana, and U.S. Bureau of Labor Statistics  for  various  U.S.
cities.

Once  the  total  cost  per  analysis  has  been  calculated, the
required frequency of  analysis  is  established.   Factors  to  be
considered   in  setting  frequency  include the  volume of outflow,
the  compliance history of the plant, the variability history, the
nature of the product/processes and priority  pollutants  of  the
plant,  and  the  equalization   pattern  of the plant s treatment
system.  The frequencies selected for study were daily,  weekly,
monthly,  and  a three-day series once per month.  Costs based on
each of these patterns are  included  in Table VIII-31.

Finally, another monitoring  cost determinant   is the   number  of
outfall  analyses  which  must   be  covered.  Some outfalls may be
combined  if  waste characteristics are similar  and  if  a  high  level
of   priority  pollutants   is not   likely   to   cause    individual
monitoring  concern.   The  cost presented  is  per  individual  sample,
be  it  from  an  individual  outfall or a  composite.

D.   ENERGY CONSIDERATIONS

The energy  consumption impact of further limitation  on  wastewater
quality  in  the  pharmaceutical   industry   is  largely  limited  to
power  requirements  for additional pumps,  agitators,  and so forth.
One  exception   is  the substantial  steam requirement (relative to
pollutant  removed)   for   steam  stripping  removal   of  volatile
organics   or   other  solvent   recovery  technologies  based  on
volatilization.

 Incremental energy consumption is reflected within the additional
 costs noted for each plant.   Availability of power or steam where
                                173

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 needed is not judged to be a prevalent problem,
 of the relatively modest demand.
largely  because
 To  the  extent that regulatory limits on priority pollutants may
 encourage changes in manufacturing techniques, there may be  some
 specific changes in energy utilization.  These are expected to be
 minor.   Examples  are recycle and reuse of process contact water
 and  substitution  of  techniques  other  than   direct   contact
 barometric legs for vacuum systems.

 E.   NON-WATER QUALITY ASPECTS

 Although these proposed  limitations  cover  effluent  wastewater
 quality   from  the  pharmaceutical  industry,  the  effect  such
 regulations might have on other aspects of environmental  quality
 must  be  considered.   These include RCRA wastes ("solid wastes")
 and air emissions.

 1.   RCRA Wastes

 RCRA wastes generated  by the pharmaceutical  industry  fall  into
 four  general   categories:   sludges,   waste  solvents,  infectious
 wastes,  and returned rejected goods.  (129)

 a.   Sludges

 Sludges  are generated  by in-plant   and  end-of-pipe  technologies
 and range from the  relatively innocuous sludge of  aerated lagoons
 and  activated sludge  units  to sludge cakes of high metal content
 (the amount of which will not be affected by these regulations).
 Sludge from biological  treatment and  general process  waste  (e.g.,
 mycelia   from   fermentation)   is   usually  landfilled.   A current
 trend  in the industry  is  to  reprocess waste mycelia and  market  it
 as an  animal feed supplement.

 Sludge production rates  for  base-case plants are shown   for  each
 treatment process in the  cost bases tables.   The amount  of  sludge
 produced by  pharmaceutical plants  will  vary markedly  from site  to
 site.    However,  these estimates  are high  and are  expected to  be
 equal  to or  higher than the  actual  amounts   experienced by  any
 given  production site.  Based  upon these factors,  it is expected
 that any additional  sludge production will  be  minimal, especially
 when compared  to the large quantities of sludge produced by  the
 basic  in-place  technology.

 b.   Waste Solvents

Waste solvents, such as toluene, methylene chloride, benzene, and
 carbon tetrachloride, are a substantial part of RCRA wastes  from
the  pharmaceutical  industry.  Solvents which might be  separated
                              174

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from wastewater by steam  stripping  would  contribute  a  modest
increment  to such wastes.  For the most part, waste solvents are
disposed in approved hazardous waste  disposal  sites.   However,
because  of RCRA considerations this method will more than likely
decline.  Another and more attractive form of disposal for  waste
solvents  is incineration, either direct or by incorporation into
a fuel system.  These systems are designed to completely  oxidize
organic solvents and eliminate the need for landfill.

Chanaes  in  process  in  the  pharmaceutical  industry generally
require   FDA   approval.    Because   of    potential    process
contamination,  solvent  recovery would normally fall into such a
change category, effectively restricting recycle, at  least  into
pharmaceutical processing.

The   latest  estimates  available   (1980) showthe pharmaceutical
industry already generates approximately 52,000 dry U.S. tons per
year  of waste solvents(43).  A toxic  solvent  limitation   (PSES)
would have  the  effect  of  increasing  the  quantity  of waste
solvents subject to RCRA disposal.  The Agency estimates that   if
a  toxic  solvent  pretreatment  standard  were  promulgated,^  an
increase of  about 9300  tons/yr of waste solvents  requiring  RCRA
disposal would result,  assuming no  recycle.

c.    Infectious Wastes, Returned and Rejected Goods

This  category  covers  a  wide spectrum of  solid  waste materials.
Because  of   their   infectious  nature,  the  wastes  must  undergo
treatment  that will  insure destruction of pathogenic  agents.   The
two methods  most  commonly  used  in  the pharmaceutical  industry  for
the   treatment  of    infectious    waste   are   autoclaving   and
incineration.

Returned   and rejected   goods   from   formulation,   test   animal
carcasses,   bedding,    and   other  disposable    materials   are
 incinerated  and/or   landfilled,   depending  upon whether they  are
suspected  of carrying infectious  agents.

Any  new effluent  limitations  will  have  no  effect on the  disposal
 of  infectious  agents   and  other solid wastes  since these wastes
 are  not generaged by wastewater treatment.

 2.   Air Emissions

 The various types of air  emissions  which  may  emanate  from  a
 pharmaceutical manufacturing site include solvents, particulates,
 combustion  gases,   and  odors.    However,  these regulations will
 onlv affect the emissions of wastewater-borne  solvents  to  air,
 and hence only the effect of these emissions has been considered.
                                175

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The  technology  options  likely  to  be selected for  controlling
traditional pollutants and cyanide beyond existing  BPT  may,   in
some  cases,  increase  to  a  small  extent the air emissions  of
wastewater-borne volatile solvents.  In particular, plants  which
may  choose  to use aerated biological treatment systems, such  as
aerated  lagoons,  may  have  some  increase  in   emission   via
incidental air stripping.

This  may  or  may  not  result  in  local;air pollution problems
depending on the nature and amount of volatile  organics  in  the
untreated  wastewater.   However, no significant direct effect  on
air quality is anticipated as a result of any effluent guidelines
limitations  and  standards  that  may  be   proposed   in   this
rulemaking.
                             176

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                                 TABLE VIII-1

               RAW WASTE LOADS FOR SUBCATEGORY BASE CASES

                          TRADITIONAL POLLUTANTS
Traditional Pollutant

BOD, mg/1
     Ibs/day    >
COD, mg/1
     Ibs/day
TSS, mg/1
     Ibs/day
t
2
8
5
18
1
3
A
,440
,850
,180
,800
,030
,740
B
1,270
480
2,050
770
520
200
2
4
5
11
1
C
,190
,750
,160
,200
740
,600

1
1
2
1

D
,630
,020
,780
,740
370
230
Wastewater Flow
435,000
45,000
260,000
                                                               75,000
Notes:

1. Wastewater  concentrations  (mg/1)  were  developed  using  the
   results  of  the  screening and  verification  programs.
   Twenty-six  individual  plants  comprise  this data  base with
   subcategory breakdown  as noted in Table I 1-2.

2.   BOD,  COD,  and  TSS concentrations are  the  mean of the
     results in the screening  and verification data  base for
     each  of the three pollutants.  The mean concentrations are
     based on the data from all plants that had that particular
     type  of operation (Example:  data from an  ABC plant were
     used  in the A, the B, and the C determinations).

3.   The averages tabulated above include  mixed subcategory data.
                                177

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                           TABLE VII1-2

          TYPICAL  PRIORITY  POLLUTANT  CONCENTRATIONS  USED
                   FOR  BASE CASE IN-PIANT  COSTS*

Pollutant	»q/l
Acid Extractables
  Phenol

Volatile Orqanics
  Benzene
  Chloroform
  Ethylbenzene
  Methylene Chloride
  Toluene

Metals
  Chromium
  Copper
  Lead
  Mercury
  Nickel
  Zinc

Other
  Cyanide
180
100
150
 20
320
515
 45
 85
 50
  8
 50
250
280
     Concentration values are based on earlier analysis and do
      not duplicate medians of Table V-6 but are used only as a
      typical, hypothetical calculation base and introduce no
      discrepancy since cost variation with concentration is
      accounted for in individual plant costs, based on 308 data
      for each plant.
                                178

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                                 TABLE VII1-3

                            CYANIDE DESTRUCTION

               EQUIPMENT COST BASES AND ENERGY REQUIREMENTS

                    Subcategory C - 26,000 GPD Base Case

Description

Mean flow, gal/day

Type of Operation

Detention Tank(s), gal

Mixer(s), hp
Mixing Req., kWh/yr

Hypochlorite Feed
Rate, Ib/yr

Caustic Feed Rate,
Ib/yr

Pumping Req., kWh/yr

Manpower Req.,  h/yr
26,000

Continuous

One, 600

One, 0.25

 1 ,600

11,500
13,300


 2,000

   500
                                179

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                                 TABLE VII1-4
                                     i
                             CYANIDE DESTRUCTION
                                CAPITAL COSTS
                                 (dollars)
                Subcategory C -  26,000  GPD Base  Case
 Description
 Detention  Tank(s)          $  2,000
 Mixer(s)                       800
 Hypochlorite Feed            9,500
 System
 Caustic Feed System          9,500
 pH and ORP Control         10,000
 Systems

   Equipment Cost          38,200
 Installation               19,100
Engineering                 8,800
Contingency                 8,900
    Total Capital Cost    $75,000
                               180

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    26.000 GPP . x 2
                          TABLE VII1-5
                       CYANIDE DESTRUCTION
                       TOTAL ANNUAL COSTS
                         (Dollars/Year)
                       VARIATION WITH FLOW
              Subcategory C - 26,000 GPD Base Case
Description
Flow Variation           X 1/2
Chemicals
     Hypochlorite
     Caustic
Energy
Labor
Maintenance
Capital Amortization
Total Annual Cost
     $/l,000 Gal.
$ 3,500
800
100
5,000
1,500
7,650
$18,500
$ 3.90.
$ 6,900
1,600
200
5,000
2,300
12,000
$28,000
$ 2.95
$13,800
3,200
400
5,000
3,600
18,800
$44,800
$ 2.36
181

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                           TABLE VII1-6
                                      j
                        CYANIDE DESTRUCTION
                        TOTAL ANNUAL COSTS
                          (Dollars/Year)
             VARIATION WITH INFLUENT CN CONCENTRATION
               Subcategory C - 26,000 GPD Base Case
                 Effluent  Concentration = 40  ug/1
 Description
 Influent Concentration
    (ug/1)
 Chemicals
     Hypochlorite
     Caustic
 Energy
 Labor
 Maintenance
 Capital Recovery plus
     Return
Total Annual Cost
     $71,000 Gal.
161    Base 322
644
$ 3,500
1,600
200
5,000
2,300
12,080
$24,600
$ 2.59
$ 6,900
1
1,600
200
5,000
2,300
12,000
$28,000
$ 2.95
$13,800
1,600
200
5,000
2,300
12,000
$34,900
$ 3.68
                              182

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                                  TABLE VIII-7
                            CHROMIUM REDUCTION
               EQUIPMENT COST BASES AND ENERGY REQUIREMENTS

                              Subcateqory C
Mean flow, gal/day
Type of Operation
Detention Tank(s), gal

Mixers, hp

Mixing Req., kWh/yr
Clarifier Dia., ft
S02 Feed Rate, Ib/yr
Acid Feed Rate, Ib/yr
Caustic Feed Rate,
Ib/yr
Pumping Req., kWh/yr
Manpower Req., h/yr
Sludge Produced,
Ib/yr dry solids
26,000 GPD Base Case
  26,000
  Continuous
  One, 1,200
  2 sections
  One, 0.5
  One, 0.25
   4,800
       8
   4,300
   4,300
  19,000

   2,000
     500
   4,800
                              183

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 Description
 Detention  Tank(s)
 Mixers
Acid  and
Feed  Systems
pH and ORP
Control Systems
Caustic Feed System
Clarif ier
Piping and Pumps
   Equipment Cost
Installation
Engineering
Contingency
    Total Capital Cost
     TABLE VIII-8
 CHROMIUM REDUCTION
    CAPITAL COSTS
     (Dollars)

   Subcateqorv C

26,000 GPD Base Case
   $  4,500
      2,500
     19,000

     10,000
      i
      9,500
      i
     27,000
  	13,500
    86,000
    43,000
    19,500
    19,500
  $168,000
                             184

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Flow (GPD)
Chemicals
     S02
     Acid
     Caustic
Energy
Labor
Maintenance
Sludge Disposal
Capital Recovery plus
     Return
Total Annual Cost
     $/l,000 Gal.
            TABLE VII1-9
         CHROMIUM REDUCTION
         TOTAL ANNUAL COSTS
           (Dollars/Year)
         VARIATION WITH FLOW
Subcategory C - 26,000 GPD Base Case
            13,000   Base Case  52,000
$ 325
125
1,150
150
5,000
3,250
1,750
17,780
$29,530
$ 6.22
$ 650
250
2,300
300
5,000
5,100
3,500
27,900
$45,000
$ 4.74
$ 1,300
500
4,600
600
5,000
8,000
7,000
43,800
$70,800
$ 3.73
                              185

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                          TABLE VIII-10
                       CHROMIUM REDUCTION .
                       TOTAL ANNUAL COSTS
                         (Dollars/Year)
                       VARIATION WITH FLOW
              Subcategory C - 26,000 GPD Base Case
                Effluent Concentration ~ 300 ug/1
Influent Cone, (mg/1)
Chemicals
   S02
   Acid
   Caustic
Energy
Labor
Sludge Disposal
Capital Recovery plus
  Return
Total Annual Cost
   $71,000 Gal.
0.90
1 .1
1 .35
$ 650
250
2,300
300
5,000
3,500
27,900
$45,000
4.74
$ 650
250
' 2,300
300
5,000
i 14,000
27,900
$55,500
5.85
$ 650
250
2,300
300
5,000
24,500
27,900
$66,000
6.95
                                 186

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                          TABLE VI11 -.11
                       CHROMIUM REDUCTION
                       TOTAL ANNUAL COSTS
                         (Dollars/Year)
              VARIATION WITH EFFLUENT CONCENTRATION
              Subcategory C - 26,000 GPD Base Case
                Influent Concentration - 450 ug/1
Effluent Cone, (ug/1)
Chemicals
   S02
   Acid
   Caustic
Energy
Labor
Maintenance
Sludge Disposal
Capital Recovery plus
  Return
Total Annual Cost
   $/l,000 Gal.
TOO
200
                                                                  300
$ 650
250
2,300
300
5,000
5,100
8,200
27,900
$49,700
$ 5.24
$ 650
250
2,300
300
5,000
5,100
5,800
27,000
$47,300
$ 4.98
$ 650
250
2,300
300
5,000
5,100
3,500
27,900
$45,000
$ 4.74
                                 187

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                           TABLE  VII1-12
                        METAL  PRECIPITATION
          EQUIPMENT  COST BASES AND ENERGY REQUIREMENTS
Description
Mean flow, gal/day
Type of Operation

Clarifier Dia., ft
Filters Dia., ft
Lime Feed Rate, Ib/yr
Alum Feed Rate, Ib/yr
Misc. Energy Req., kWh/yr
Manpower Req., h/yr
Sludge Produced,
Ib/yr dry solids
Subcateqorv A  Subcateoorv C
 43,500        26,000
 Continuous    Continuous
     10
 Two,  3
 13,200
  2,600
    500
    500
 15,900
     8
Two, 3
 7,900
 1,600
   300
   500
 9,500
                               138

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                          TABLE VIII-13
                       METAL PRECIPITATION
                          CAPITAL COSTS
                            (Dollars)
Description

Clarifier, Solids
  Contact Type
Lime and Alum
  Feed Systems
Filtration Units
Piping
   Equipment Cost
Installation
Engineering
Contingency
    Total Capital  Cost
Subcateaorv A   Subcateaory C
   32,000
  27,000
22,000
20,000
8,400
$ 92,400
$ 46,000
20^700
20,700
19,000
30,000
7,600
$ 83,600
$ 41,000
18,000
18,000
  $180,000
$163,000
                                189

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                               TABLE VIII-14
                             METAL PRECIPITATION
Flow  (GPD)
Chemicals
     Lime
     Alum
Energy
Labor
Maintenance
Capital Recovery
  Plus Return
Total Annual
     Cost
$71,000 Gal.
TOTAL ANNUAL COSTS
I do liars/year)
VARIATION WITH FLOW
Subcategories A & C

21
$


5
3
. 5
•y
18
$33
$ 4

,750
275
100
25
,000
,450
,750
,700
,300
.19
A
43,500
$ 550
200
50
5,000
5,400
11,500
29,300
$52,000
$ 3.27

87,000
$ 1,100
400
100
5,000
8,500
23,000
46,000
$84,100
$ 2.65

13,000
$ 175
50
25
5,000
3,150
3,400
17,100
$28,900
$ 6.09
C
26,000
$ 350
100
50
5,000
4,900
6,800
26,800
$44,000
$ 4.64

52,00
$ 70
20
10
5,00
7,70
13,60
42,00
$69,30
$ 3.65
                               190

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r
                                       TABtE VIII-15




                                    METAL PRECIPITATION
TOTAL ANKUAL COSTS
(dollars/year)
VARIATION WITH INFLUENT CONCENTRATION
Effluent cone. * 1.1 mg/1
Sufccategories A 6 C

influent Conc«
(mg/1)
Chemicals
lime $
Alum
Energy
labor
Maintenance
Sludge Disposal
Capital Recovery
Plus Return
Total Annual
Cost $
$/ 1,000 Gal. $

3.0

550
200
50
5,000
5,400
6,700
29.300
47,200
2.97
=A=
4.36

$ 550
200
50
5,000
5,400
11,500
29,300
$52,000
$ 3.27

7.00

$ 550
200
50
5,000
5,400
20,800
29,300
$61,300
$ 3.86
• - . :
3.0

$ 350
50
50
5,000
4,900
4,000
26,800
$42,200
$ 4.45
C
4.36

$ 350
100
50
5,000
4,900
6,800
26,800
$44,000
$ 4.64

7.0

$ 350
100
50
5,000
4,900
12,300
26,800
$49,500
$ 5.22
                                                   191

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            TABIE VIII-16

         METAX PRECIPITATIOH

         TOTAL ANNUAL COSTS
            (dollars/year)

VARIATION WITH EFFLUENT CONCENTRATION
     Influent Cone. = 4.36 mg/1

         Sutcategories A 6 C

Effluent Cone.
(Jrg/1)
Chemicals
lime $
Alum
Energy
labor 5,
Maintenance 5 ,
Sludge Disposal 13,
Capital Recovery
Plus Return 29,
Total Annual
Cost $54,
5/1,000 Gal. $ 3.

0.5
550
200
50
000
400
600
300
100
41
j A
1-j
$ 550
200
50
5,000
5,400
11,500
29.300
$52,000
* 3.27

2.0
$ 550
200
50
5,000
5,400
8,300
29.300
$48,800
$ 3.07

0.5
$ 350
50
50
5,000
4,900
3,100
26.800
i
$45,300
$ 4.47
C
1.1
$ 350
100
50
5,000
4,900
6,800
26.800
$44,000
$ 4.64

2.0
$ 350
100
50
5,000
4,900
4,900
26,800
$42,100
$ 4.44
                   192

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                                       TABLE VIII - 17

                                       STEAM STRIPPING

                                         COST DATA
                                                   Capital Cost, Dollars
Description

Process Equipment
 Steam Stripper with 20 trays,
 4 ft. I.D. Feed rate = 200,000
 Ibs/hr (400 gpm)

Physical Plant
 207% of equipment cost

Engineering and Construction
 30% of the total equipment cost

      Direct Plant Cost

Fixed Capital
  120% of direct plant cost

Working Capital
  15% of fixed capital

      Total Capital  Cost
 Steam
  $3/1,000 Ibs. steam
  0.1 Ibs steam/lb feed

 Steam for Feed Heating
  70 C to 100 C
  0.056 Ibs stecim/l b feed

 Electricity
  $0.04Awh

 Labor
  $10/hr.
  Operating time = 8,000 hr/yr

 Maintenance
  3% of capital cost

 Capital Recovery plus Return
  16.3% of capital  cost
(57,600 GPD)
Base x 0.1
$ 22,000
46,000
20,000
h
88,000
106,000
16,000
$122,000
(288,000 GPD)
Base x 0.5
$ 63,000
130,000
58,000
251,000
301,000
45,000
$346,000
(576,000 GPD)
Base Flow
$ 98,000
203,000
90,000
391,000
469,000
71,000
$ 540,000
1,152,000 GPD
Base x 2.0
$ 154,000
318,000
142,000
614,000
737,000
111,000
$ 848,000
Annual Cost, Dollars/1,000 gal
                                      2.50
1.40
                2.50
1.40
                                                                         2.50
                                   1.40
                                                     2.50
                                     1.40
0.33
4.20
0.33
0.84
0.33
0.42
0.33
0.21
0.18
1.05
0.10
0.60
                                   0.08
                                   0.47
                                     0.06
                                     0.37
       Total Cost, $/l,000 GAL  $       9.66/
                                   1,000'GAL
          $      5.T7/
             1,000 GAL
                   5.20/
               1,000 GAL
$        4.87/
     1,000 GAL
 $/yr.                          $203,OOOAr-    $6G7,000/Yr.

 Note:  Costs have been adjusted to January 1978 dollars.

 Ref.:  Contractor's Engineering Report Pharmaceutical Industry.

                                             193
                          $l,093,000/Yr.   $2,048,OOOAr.

-------
     TABLE VIII-18



ACTIVATED SLUDGE SYSTEM
EQUIPMENT COST BASES
•
Description
Mean flow, gal/day 435
Detention Time, days
AND

~S "
,000
2.2
Aerators, hp Four, 60
Nutrient Addition, Ibs/day
Ammonia
Phosphorous
Lime
Ferric Chloride
Clarifiers, Dia., ft Two,
Sludge THickener Surface
Area, ft2
Vacuum Filter Area, ft2
Energy Req. , kwh/yr 1,625,
Sludge Produced,
Ibs/day dry solids
Area Req., ft2 61,
32
6
30
8
30
28
19
000
130
000
t
ENERGY REQUIREMENTS
Subcateaorv
B :
45,000
i
0.2
Two, 5
1 .4
0.3
Two, 10
i
_
-
104,000
6
13,000
Base Case
C D
260,000 75,000
1.2 , 0.3
Four, 30 Two, 5
16 1.4
3 0.3
17
4.5
Two, 24 Two, 12
20
10
845,000 111,000
85 8
35,000 13,000
          194

-------
     TABLE VII1-19



ACTIVATED SLUDGE SYSTEM
CAPITAL COSTS
Cost. Dollars, for
Description
Activated Sludge Unit
Aeration
Nutrient Addition
Clarification
Sludge Thickening
Vacuum Filtration
Sludge Storage
Piping (installed)
Installed Cost
Engineering
Contingency
Total Capital Cost
A
$ 420,000
218,000
13,000
180,000
33,000
142,000
—
151 ,000
1 ,157,000
174,000
174,000
$ 1,505,000
B
$ 12,000
40,000
1,000
75,000
-
. • - -
18,000
22,000
168,000
25,000
25,000
$ 218,000
Subcateaorv Base Cases
C
$ 290,000
154,000
7,000
120,000
24,000
132,000
-
108,000
835/000
125,000
125,000
$ 1,085,000
D
$ 34,000
40,000
1,000
96,000
—
-
18,000
28,000
217,000
33,000
33,000
$ 283,000
            195

-------
                      TABLE VII1-20



                 ACTIVATED SLUDGE SYSTEM
Description
Chemicals
Energy
Labor
Maintenance
Sludge Disposal
Capital Amortization
TOTAL ANNUAL COSTS
Cost, Dollars, for Subcateqory Base Cases
A B
$ 2,600 $ 200
65,000 4,200
110,000 80,000
45,200 6,500
5,700 7,900
246,500 35,200
C
$ 1,400
33,800
110,000
32,600
3,700
176,500
D
$200
4,400
80,000
8,500
10,500
46,400
Total Annual Cost   $ 475,000    $ 134,000    $ 358,000    $ 150,000
                            196

-------
TAfllE VIII-21
EQUIPMENT COST BASES AND ENERGY BEOUIREMEMS

Cescriction
Mean Flow, gal/day
Kunber of BBC Units
Shaft Lengths, ft
Total BBC Surface Area, ft2
Energy Beq. , kwh/hr
Clarifiers, Dia., ft
Manpower Beq., h/yc
Sludge Produced,
Ibs/day dry solids
Sludge Dewatering
Manpower Beq. , h/yr
Energy Beq., kwh/yr
Area Beq., ft2

A
435,000
Four
20
304,000
130,000
Two, 30
2,000
220
Yes
1500
195,000
30,000
Sufccateaorv
B
45,000
One
10
24,000
13,000
Two, 10
2,000
20
NO
-
-
2,500
Ease Cases
C
260,000
Three
20
228,000
98,000
Two, 24
2,000
130
Yes
1500
115,000
20,000

D
75,000
One
20
65,000
33,000
Two, 12
2,000
40
No
—
-
4,000
             197

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TABLE VIII-22
CAPITAL

AND TOTAL ANNUAL COSTS i

Capital Costs
($)

sutcateqorv Base Cases
Cescription
BEC Units, Steel Tankage,
Insulated covers
Clarifiers
Sludge Dewatering
Sludge Storage
Piping
Equipment cost
Installation
Engineering
Total Capital Cost
Energy
labor
Maintenance
Sludge Disposal
Capital Amortization
Total Annual Cost
A
$ 205,000
120,000
96,000
-
42.000
163,000
232,000
104,000
S 903,000
$ 13,000
35,000
27,100
9,600
147.300
* 232,000
I :
$ 40,000
50,000
1
8,000
10.000 ;
108,000
54,000
24,000
C
$ 155,000
80,000
84,000
-
32.000
351,000
176,000
79,000
$ 210,000 $ 685,000
Annual Costs *£/vrl
$ 600 ;
20,000
6,300
5,300
34.800
$ 67,000
$ 8,500
35,000
20,600
5,700
112.200
$ 182,000
£
S 50,000
64,000
-
12,000
13,000
139,000
70,000
31,000
$ 271,000
S 1,400
20,000
8,100
10,500
44.000
$ 84,000
              198

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                          TABLE VII1-23
                         POLISHING POND
Description
Mean Flow, gal/day.
Detention Time, days
Excavated Volume, yd3
Lined Area, ft2
Basin Width at Top, ft
       Square basin, Is3 slope
       Freeboard =  1 ft
       Water depth  = 8 ft
       Sludge depth » .1 ft

Manpower Req., h/yr
Area Req., ft2
COST BASES
A
435,000
5.5
15,000
40,000
230
slope
•^
:t
200
62,000
Subcateqory
B
45,.000
3.3
1,000
3,300
80

200
10,000
Base Cases
C
260,000
5.0
8,000
22,000
175

200
40,000

D
75,000
4.0
2,000
5,700
100

200
14,000
                                 199

-------
 TABLE VII1-24



POLISHING POND
CAPITAL AND TOTAL


Description A
Excavation, Grading, $ 135,000
Compaction
Impervious Liner 26,000
(installed)
Piping (installed) 24,000
Installed Cost 185,000
Engineering 28,000
Contingency 28,000
Total Capital Cost $ 241,000
Labor $ 2,000
Maintenance 7,200
Capital Amortization 38,800
Total Annual Cost $ 48,000

200
ANNUAL COSTS
Capital
Subcateqory
B
$ 9,000
2,200
1,700
12,900
2,000
2,100
$ 17,000
Annual
$ 2,000
500
2,500
$ 5,000
f-


Costs ($)
Base Cases
C
$ 72,000
14,300
12,900
99,200
14,900
14,900
$ 129,000
Costs ($/vr)
$ 2,000
3,900
21,100
$ 27,000





D
$ 18,000
3,700
3,300
25,000
4,000
4,000
$ 33,000
$ 2,000
1,000
5,000
$ 8,000
	


-------
     TABLE VII1-25



ACTIVATED SLUDGE SYSTEM
WITH FILTRATION
EQUIPMENT COST BASES AND ENERGY REQUIREMENTS

Description
Mean Flow, gal/day 435,
Detention Time, days
Aerators, hp Six,
Nutrient Addition, Ibs/day
Ammonia
Phosphorous
Lime
Ferric Chloride

A
000
8
125
32
6


Clarifiers, Dia. ,' ft Two, 30
Number of Dual Media
Filtration Units
F i 1 1 er D i ameter s , f t
Sludge THickener Surface
Area, ft z
Vacuum Filter Area, ft2
Energy Req., kwh/yr 5,600
Sludge Produced,
Ibs/day dry solids
Area Req., ft2 165
Two
10
*\ f\
20
10
,000
90
,000
Subcateoorv Base Cases
_ — B - — ^— -
45,000 260,000
1 5.5
Two, 7.5 Four, 75
1.4 16
— — O
0.3 3


Two, 10 Two, 24
Two Two
3 8
- 20
•" *• V
- 10
130,000 2,340,000
20 60
17,000 74,000

D
75,000
1
Two, 7.5
1.4
0-1
. o


Two, 12
Two
4


~
140,000
20
17,000
            201

-------
                           TABLE VII1-26
                      ACTIVATED SLUDGE SYSTEM
 Description
 Activated Sludge Unit
 Aeration
 Nutrient Addition
 Clarification
 Dual Media Filtration
 Sludge Thickening
 Vacuum Filtration
 Sludge Storage
 Piping (installed)
    Installed Cost
Engineering
Contingency
    Total Capital Cost $
WITH FILTRATION
!
CAPITAL COSTS
Cost, Dollars, for Subcateaorv
A
$ 778,000
465,000
13,000
180,000
180,000
24,000
132,000
-
266,000
2,038,000
306,000
306,000
$ 2,650,000
B
I
$ 63,000
44,000|
1,000
75,000
54,000:
-
-
44,000
i
43,000:
324,000
48,000
48,000
$ 420,000
C
$ 508,000
245,000
7,000
120,000
120,000
24,000
132,000
-
174,000
1,330,000
200,000
200.000
$ 1,730,000
Base Cases
D
$ 86,000
44,000
1,000
96,000
63,000
-
-
44,000
50,000
384,000
58,000
58f 000
$ 500,000
                              ,202

-------
Description
Chemicals
Energy
Labor
Maintenance
Sludge Disposal
Capital Recovery
   plus Return
                          TABLE VII1-27
                     ACTIVATED SLUDGE SYSTEM
                         WITH FILTRATION
                       TOTAL ANNUAL COSTS
                         Cost. Dollars, for Subcategorv Base Cases
   $  2,500
   224,000
   130,000
    79,500
4,000

   432,000
     $   200
      5,200
    100,000
     12,600
26,300

     68,700
   $  1,200
    93,600
   130,000
    51,900
2,600

   280,700
      $  200
      5,600
    100,000
     15,000
26,300

     81,900
  Total Annual  Cost   $872,000    $213,000      $560,000    $229,000
                                203

-------
               TABLE VII1-28
ROTATING BIOLOGICAL CCNTACTgB  IRECj SYSTEM
              HITH FILTRATION
EQUIPMENT COSI
EASES AND ENERGY RKnilTBRMK-WTc
i
Suhcateuorv Base Cases
Cescriction
Rean Flow, gal/day
Kuirber of REC Units
Shaft Lengths, ft
Sotal RBC Surface Area, f
Energy Reg., Jcwh/hr
Clarifiers, Dia., ft
Kumber of Dual Media
Filtration Units
filter Diameters, ft
Hdnpower Reg., h/yr
Sludge Produced,
Ibs/day dry solids
Sludge Dewatering
Manpower Reg., h/yr
Energy Reg., kwh/yr
Area Reg., ft*
A
435,000
Four
25
t* 442,000
260,000
Two, 30

Two
10
4,500

300
Yes
1500
265,000
31,000
B
45,000
One
20
65,000
33,000
Two, 10

Two
3
4,500

30
No
-
-
3,000
c
260,000
Four
20
364,000
195,000
Two, 24

Two
8
4,500

180
Yes
1500
160,000
21,000
D
75,000
One
20
65,000
33,000
Two, 12

Two
4
4,500

50
No
_
— ,
4,500
                            204

-------
                        TABLE VIII-29
— ' 	 KITH
CAPITAL AND
Descriction
BBC Units, Steel Tankage, $
Insulated Covers
Clarifiers
Filtration Units
Sludge Dewatering
Sludge Storage
Equipment cost
Installation
Engineering
Total Capital Cost $ 1
Energy
labor
Maintenance
Sludge Disposal
4*-kw£ 4- -.1 Am<-bii"+- i •* a*" \ fin
J-ILTRATIOK
TOTAL ANNUAL COSTS
Capital Costs
Sufccategory Base
A I
235,000 $ 50,000

120,000 50,000
120,000 36,000
108,000
12,000
641,000 163,000
321,000 82,000
144,000 37,000
(SI
Cases
C
$ 205,000

80,000
80,000
92,000
—
503,000
251,000
113,000
,250,000 $ 319,000 $ 980,000
Annual Costs (S/vr)_ —
$ 21,000 $ 1,«00
60,000 45,000
37,400 9,600
13,100 7,900
203.500 52.100
$ 14,200
60,000
29,400
7,900
159.500


D
$ 50,000

64,000
42,000
—
18,000
191,000
96,000
43,000
$ 3,73,000
{ 1,400
45,000
11,200
13,100
61.300
    Total Annual Cost
Kumber of
                           $ 335,000     3  116,000
$ 271,000
                                                                   $ 132,000
                                      205

-------
O
O\
           Description
     Tank Trailer Leased)
     Hauling Charges^)
     Extra Hauling Charges^)
Annual Hauling Cost
Capital Amortization^)
Total Annual Hauling Cost
Treatment Cost(5)

Total Annual Cost

     $/l,000 Gal
                                                  TABLE Vra-30
                                   WASTEWATER HAULING/TREATMENT COSTS

                                   	.	Annual Cost, $
                                           50 Miles Round Trip
                                                                               200 Miles Round Trip
1000GPD
9,000
17,000
5,000
31,000
5,000
36,000
5,000
2000GPD
9,000
35,000
8,000
52,000
5,000
57,000
10,000
3000GPD
9,000
52,000
11,000
72,000
5,000
77,000
15,000
1000GPD
9,000
29,000
5,000
43,000
5,000
48,000
5,000
2000GPD
9,000
57,000
8,000
74,000
5,000
79,000
10,000
3000GPD
9,000
86,000
11,000
106,000
5,000
111,000
15,000
                                  41,000
                                     112
67,000
    92
92,000
53,000
                                                                                145
89,000
                                                                                        122
126,000

    115
    (1)   Long Term lease for 6,000 gallon trailer with insulation and heating facilities.
    (2)   Based on New Jersey hauling rates weighted for inter- and intrastate, 50 mi. round trip - $.57/100 Ib. and 200
    (3)
    (4)
     mi. round trip - $.94/100 Ib.
     Extra charges for dead head loads, truck pump rental, driver detention time, and other misc. charges.
     20 year and 15% amortization of loading facilities and tank capital cost of $25,000.
    (5)   Based on average D subcategory loading and POTW treatment cost at $1.00-1.50/lb of BOD removed.

-------
                                                TABLE VHt31
                                     ANALYTICAL COSTS FOR MONITORING
                                           PRIORITY POLLUTANTS

METHOD
VGA (5) GC or HPLC
GC/MS
Cyanide Colormetric
Sub-total
° Metals (5) ICP
AA

COST PER COST PER
ANALYSIS* ANALYSIS*
- RANGE WEIGHTED AVG.
$ $
75-105 90
125-185 160
25-50 27

10-19 11
(per element)
15-25 17
(per element)
ANN!)
COST PER
SAMPLE
MONITORED** S
$
90
16
J7
143
55


                                                                  ANNUAL COSTS PER OUTFALL OR OUTFALL/COMPOSITE

                                                                                             3-DAY
                                                                       DAILY   WEEKLY     SERIES     MONTHLY
                                                                        AMPLE  SAMPLE  EACH MONTH   SAMPLE
                                                                        $/YR      $/YR        $/YR        S/Yr
 Total with Metals
                                                            198
                                                                        52,200     7,fOO
72,300     10,300
                      5,100
                                                                                               7,100
1,700
2,400
*   Costs from contracting laboratory contacts, adjusted for geographical distribution of industry.

**  Bases
    - Assumes one screening/confirmation GC/MS required for every ten samples.
    - Typical for five organics and five metals.

*** If outfalls are composited each composite counts as one outfall analysis.

-------
                          80Z


    ANNUAL TREATMENT COST ($1000/YR.)
•a,-dj.!ijTjiB:!:i±
                        H * f ?•*•?•*•*• 44.tf»4.+4'4">
               -W-^SWtuWJHiT
               *:::^\t-Tff-*"?rH'i-ft'f"r-r*-»-*4">->-*"'-

                           ...... J. i  • 11 ' ~T~r-rTTTT "T* rTT'i

                           r::t±5!;4.|l|fRf|5±:
                           ^ii: :n43±Hii4liiil:!z: j

                      ^fjOjouJ.j..j..,. .Si 'i.;.;.;.: 4^Zti^x




                      -H-ffH-|---  •*.•.*+ -4rJ	f*.t.:tTI
                   *±f''
             rte?|: .Tiflttfttttr
             trrftrf-ffft ?! I i.i~'i-

             fit amHErlE t:':i
             3fflHT!WPra*
          Si't«;.f.rf7'H-jjjfHrtjfcgj;t

-------
          I   I
                                                     "T
             K ^pfqure VlTTT.  Activated sludge with "supplemental  treatment.^
             .L  •     -,  .5..  ;  | Annual treatment cost vs. wastewater  flow.  \-  \
                                                                                                        —^ r
500
200
900
 600
 300
                           200
300         400         500

    VIASTE WATER FLOW RATE (1000 GPD)

-------
                   012
ANNUAL TREATMENT COST ($1000/YR.)

-------
  500
                                                                  I
                                                                                     \

                                   RBC system witTIuppTemental'treatment. Annual  treatment cost vs. j.

                                   wastewatertflow. |  j—f  ;     •*"    I   j * i   i      ]   j           "
                                                                                                                j
                                                                                                               ~~T
                  EFFLUENT BOD  20 mg/u  ,   »
  400

t/i
s
   300
   200
                                                                               600
                                                                                                        800
                                             WASTE"WATER FLOW RATE (tooo GPD)

-------
                      isning pondannual  treatment
                         .__. ^   ^    £
200
400
600
                    FLOW RATE (1000 GPD)
                        212
800
1 000

-------
              ANNUAL TREATMENT COST ($1000/YR.)
t       4       !



-------

    CO
    <=>
    CJ
N)
                           Figure  VIII-7.
                  des"tructlon annual  treatment cost  vs. influent  CN concentration'.5
                                  -HK-~J"H •! 9 **jJ** J * * i «"*-*

                                  i^fH-H-M^V^fff*--
                                            ^ . r T - • -T-1—-r-;"S"" • i"( •; : : T r  v-*-» *~*-*,+^*.»., ^.^^,

                                            "f-- •> j >-J-rH'j-n-Htt-n '- !' i-H-H-H+4-i
                                            £trl.i.!-.i:->i r r :i •! tr!-;-H-M-r ft it j! 11 <*-- -t—!
                         00
200
300
                                                                    400
                                            500
                                            600
                                                                                                                700
                                                                                          00
                                                            INFLUENT CONCENTRATION (mg/L)

-------
  15
       -1 •':- "'"{Figure VIlf-8.™ Cyanide destruction "unit treatment cost vs. wastewater flow.

        ft  i     n*: i1'    "H™i   r; T r 7 viiiiLlJ  fi  .IT"",
         | J! * *  1     • ^^^.J^^^^J^^  4 *, ^(^	hv «^*^**J ^ *4v^*v«[ v^A**^ *^^ * ny ~c^v*^, I^W-4- **-*« *-i* *-<> I ^*v*^t~^v««" ««*-*«. *• * * ^'f *v*^MW^^«« «i™**-| ^ * <~|~p-o»«-»^:
  12
V)
o
        ...,  :  J  •  ^^
              10
20
                                  30
40
50
                                                                60
                                                  70
                                         80
                                    WASTE WATER FLOW RATE (1000 GPD)

-------
              9TZ
UNIT TREATMENT  COST (DOLLARS/1000 GAL.)

-------

    100
      80

   •5 60


CO  cZ
      40
      20
                       Figure VIII-10. Chromium reduction annual  treatment cost  vs. wastewater  flow
                         *^  j. ...        ..i      a      .<•      .                   Jff      J
                                                                           w^~^-*™—      I ^^.4^~*j-'-<*
                     10
20
30    ,       40           50




     WASTEWATER FLOW RATE (1000 GPD)
60
                                                                                                     70
80

-------
                                   UNIT TREATMENT COST (DOLLARS/1000 GAL.)
                                                                                          t-o
                                                                                          0
      CO
      a
       CJ1
       CD
3

-------
                                        »   t
           gure VIII-12.  Chromium reduction
                          annual treatment
                     <     cost vs. influent
                        '  Cr concentration.
    1 . 0
INFLUENT CR (mg/L)

      219

-------
                                            treatment
                                         concentration
.30  .45
1.0   1.2   1.4
             INFLUENT CR  (mg/L)
                        220

-------

                    _ ~      —~_     	L_    I—I—.!
                Tigure VIII-14.  Chromium reduction annual  treatment
                                 •cost vs. effluent Cr concentration.
                                                               "~i— '~

  60
s
IXJ
C3
CJ
  40
  20
               0.10
0. 20
0.30
                               EFFLUENT CR (mg/L)
                                     221
0.40  0.45

-------
12
10

                 HTf
   itili
ziii i.i I'll
In'

                                           J

                 Figure VIII-15.  Chromium  reduction unit  treatment

                                       vs>  eff1uent £r  concentration.  I  I' |-
                              '  IT  i      ^  .,    .    1 .


                ".",."." ™,!i'™'!zi°l-!" j * 1 $ t ti""^.
             0.10
   0. 20
          0.30
0.40   0.45
                              EFFLUENT CR (mg/L)


                                     222

-------
  00
  80
§60
  40
  20
                                                                         i
                  Figure VIII-16.  Metals precipitation  annual  treatment cost vs.  wastewater flow.
                 10
20
30
40
50
60
70
                                           WASTE WATER FLOW RATE (1000 GPD)

-------
             tzz
UNIT TREATMENT COST (DOLLARS/1000 GAL.)

-------
                                                                        ANNUAL TREATMENT COST ($1000/YR.)


N)
   "5s

-------
11
10
                  "«"*•  *'*"*"'"**«^**^—s«^.^.j.4.-l--»>a.i..lvn^s»>l..faj^	!.„	™*^hN(vAX tmi*. *<.**. |«™ «^™, ,™J i  ^H<4^>^4r^
                  Figure VIII-19.  Metals precipitation  unit treatment   {  M  <
                  ffiWr^ii44:, w&Ui|:cost yS>  influent concentration.  *v  '  Jl  r
                               *-^^-iww***-**f**-i-i«  * ft^. ^ ^yJ,-™  +.:    i ^.^,
                               •"»«".{.-!.,, l|  3»-i3   i'  .   fr.1
                               ^f!1,,'},  I  '   »}  ,.»•
                               s?h,v. ,  I   ]  ,  -v
                                            3
                                 INFLUENT TOTAL METALS (mg/L)
                                        226

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                          V  """  7
 1            ^      !->-!•

"  FiguVeTviII-20".  Metals~pfecipitation annual treatment
                   cost vs. effluent metals concentration.
  '   T  . _   _.!_-...  |.-.|—-  .(_-,   ^^   -^
                                                           I.  I
i .0
              2 . 0
                                      4. 0
               EFFLUENT TOTAL METALS (mg/L)

                        227

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       Metals  precipi tat
       cost  vs.  effluent metal
 treatment
concentration
2-0                      4.0

  EFFLUENT TOTAL METALS (mg/L)

          228

-------
                                                      ANNUAL TREATMENT COST (51000/YR.)
e  »
    ~

-------
                  Steam stripping
                  and  steam cost.
200
    400         600          800
WASTE WATER STRIPPED (1000 GAL./DAY)
             230
1 000

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Figure" Ylll^ATwastewater!hauling  costs  vs. wastewater f 1 ow.
                                 ' °°~*~        *'  '    ....—r
                                                 Vfr fl.sfr  * * * ^^«^«^^W--'
                                                 *  *:•*:  1    *  **
                                           I              I
                                          • |:.-»-"4-     *• —i
44- 444  t
i-" 'I' "4*-"
  i  <.<•<•   !*•  *    t
  Z^tnvw^. v*^>v««i^y«l™a,»**« *«~f~*w
  ! :. *'., U  r.::i*.
              FLOWRATE  (1000  GPD)
                          231

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                            SECTION IX

       ANALYSIS OF LONG TERM DATA FOR POLLUTANTS OF CONCERN


 This  section  describes the analysis of long term BOD5., COD, TSS
 and cyanide  data  submitted  to  EPA  by  pharmaceutical  plants
 utilizing  biological  treatment  systems  and  in-plant  cyanide
 destruction.   The first part of this section details which  plant
 data were used to develop the suggested limitations and discusses
 reasons  for  the  deletion  of some of the submitted data.   Data
 verification procedures are described as well as the contents  of
 the  limitations  data  base.    The  second  part of this section
 describes the statistical methodology used to calculate the daily
 maximum and 30-day average maximum variability factors.

 A.    Description of Data

 EPA  conducted  statistical  analyses  of  long   term   effluent
 monitoring  data  from  the  pharmaceutical industry to establish
 revised BPT and  new  BCT,   BAT  and  NSPS  effluent  limitations
 guidelines  and  pretreatment   standards  (PSES and PSNS).   These
 guidelines are in the form of  daily maximum  and  30-day  average
 maximum  effluent limitations  for the conventional pollutants TSS
 and  BOD5.,   the  nonconventional   pollutant  COD  and  the  toxic
 pollutant cyanide.

 The major objectives of  the study were to quantify the day-to-day
 variability   of   treated   process    effluent  and  to  provide
 appropriate variability  factors to be used  in  conjunction   with
 appropriate  long  term   performance   averages  to  construct new
 limitations   guidelines.    The    specific   methodologies    for
 calculation  of  these   variability  factors  are presented in the
 statistical appendices of the  report  Pharmaceutical  Effluent  Data
 Analysis  conducted  by SRI International,  EPA  Contract 68-01-6062,
 Task  1.

 1.    Plant  Data Used  in  Limitations Development

 Long  term self-monitoring daily data  were  submitted  to EPA by 22
 pharmaceutical   manufacturing plants.   Information concerning the
 data  collection  is  contained in the report  entitled  "Contractor's
 Engineering Report  for the Development  of  Effluent   Limitations
 Guidelines  and   Standards  for   the  Pharmaceutical Manufacturing
 Industry  Point   Source   Category"  prepared   for  the  Effluent
Guidelines  Division  of  the  U.S.   EPA   by  the  Burns and Roe
 Industrial Service Corporation (1980).

 In order to  preserve  source  confidentiality,  each  plant  was
assigned  the  five  digit  identification  number assigned in the
                               232

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        ^08  Portfolio Survey .    In  conjunction  with  the  plant
  etica?ion  nSmbers  are listed^he manufacturing |"£«™
The plant Identifiers and subcategories
              Idicated.
are shown in Table IX-1 .

All but one of the 22 plants included in  the  study  employ  BPT
treatmen?  systems (i.e. biological systems).  The lone exception
is Slant 12123, which is an indirect discharger.








represenXuvfof Bd" treatment     '»•*"*»
                                                                be
representtveof  a  properly  designed  -»J  ^-^  biolo,ic.l
system.  These omissions  are  explained  as  follows:

Plant  12098 The data from this plant  did   not  in<=iu*f






S .
           high  effluent  concentrations  has  been assumed.  The
 Jxplain the less than BCT level of performance by this

 Plant 12187

 This plant did not provide influent data for BOD5, COD and TSS as
 well as effluent  COD  data.   The  high  effluent  average  BOD|
 concentration  (707.3.  mg/1)  indicates  that,  in  order for the
 pl2St"s treStment system to be properly designed and operated  an
 average influent BODS concentration several  times  greater  than
                                 233

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 that observed  in any other Subcategory C plant must have  existed,
 a  highly unlikely possibility.  -Therefore,  in the absence of any
 other data this high average effluent  BOD5.  value  can   only  be
 explained  by  either  improper design or  inadequate operation of
 the treatment  system.

 Plants 12160 and 12462                     !

 These plants show poor long term average   percent  reduction  for
 both  BOD  and  COD (68 percent and 67 percent, respectively, for
 BOD and 60 percent and 52 percent, respectively, for  COD).   The
 current BPT regulation requires a 90 percent reduction in BOD and
 a 74 percent reduction in COD from raw waste levels.   In addition
 both  plants  show  high  long  term average effluent TSS levels.
 These long term performance data are not representative of proper
 BCT treatment.                                                 *

 The remaining 13 plant data sets were used to derive BCT and  BAT
 limitations  and  variability  factors.   One plant (12236),  which
 achieved a less than 90 percent average  reduction  for  BOD  (83
 percent),   was   still  included in the BCT-BAT data set because it
 was a  significantly  better  overall  performer  than  the  four
 deleted  plants.)   For purposes of calculating NSPS standards and
 variability factors, we further eliminated 3  of the 13 plant data
 sets.   The performance of three plants (12022,  12026   and  12236)
 was  nudged  to be  demonstrably inferior  to that of the other ten
 Si«ntf  and therefore these plant data sets were excluded from the
 NSPS  data  set group.   While two of the three   plants   (12022  and
 12026)   have  average   long  term BOD removal percentages greater
 than  90  percent,  their  performance  regarding  COD and  TSS  was
 considerably    inferior   to    that   of   the   NSPS plants.    The
 performance of  the  third  plant,   12236,   was   considerably  below
 that  of   the  other   ten  plants  from the  standpoints  of  percent
 reduction  and final  effluent  concentration.  Although   one  plant
 in  the  NSPS  data  set (12307)  did  not provide  influent  data, it
 was retained  because its  effluent  pollutant  levels  were  deemed
 acceptable.   Finally,  only plant  12236 provided  acceptable  long
 term cyanide  destruction  performance data,  and this data was  used
 to develop BPT  (BAT) cyanide limitations and  variability factors.
                                            I
 2*   Pata Verification  Procedure

 In order to identify values that may have been coding  errors  or
 that possibly reflected physical breakdown  of the plant treatment
 system, graphic displays of daily pollutant values versus  date of
 sample were generated.   Data values found to deviate greatly from
 neighboring  values  were listed as possible transcription errors
 or  observations  reflecting  physical  breakdown  of  the  plant
 treatment  system.   As  a  result of this  procedure, some values
were corrected and others were  deleted  because  they  reflected
                               234

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in  statistical  Appendix  B of the report cited for EPA contract
68-01-6062, Task 1.
3.   C22l±!±± 2f. JJ!£ Pharmaceutical Long. Term Data Base
In addition to implementing corrections ^as  granted
and effluent pollutant loadings in mass ^charge units  (
were  computed
concentrations
flctortsK^ShrdatrbasrSontalnrtSrioliowing Information:
     (1)  Plantt The five digit plant identifier code.
     (2)  SUBCAT:   The  plant  subcategory   (EPA  classification
          based on specific nature of plant activity).
     (3)  DATE:  The date on which each observation was  taken.
     (4)  FLOW MGD:  The flow  in million  gallons per  day  through
          the plant treatment  facility.
     (5)  INBODs    Influent  biological   oxygen  demand   to   the
          treatment plant  (mg/1).
     (6)  EFBODs  Effluent  biological  oxygen  demand  from  the
          plant  (mg/1).
     (7)  INCOD:   Influent  chemical  oxygen demand  (mg/1).
      (8)  EFCOD:   Effluent  chemical  oxygen demand  (mg/1).
      (9)   INTSS:   Influent  total  suspended solids  (mg/1).
      (10) EFTSS:   Effluent  total  suspended solids  (mg/1).
      (11)  EFCN:   Effluent cyanide (ug/1).
 Also,   for   analysis  purposes,  the  following  variables
 computed:
                                                              were
      (1)  FLOWKGD:  Flow in thousand gallons per day.
      (2)  INBODLB:  Influent biological oxygen demand  (Ib/day).
                                 235

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       (3)   EFBODLB:   Effluent biological oxygen demand (Ib/day).

       (4)   INCODLB:   Influent chemical  oxygen demand (Ib/day).

       (5)   EFCODLB:   Effluent chemical  oxygen demand (Ib/day).

       (6)   INTSSLB:   Influent total  suspended solids (Ib/day).

       (7)   EFTSSLB:   Effluent total  suspended solids (Ib/day).

       (8)   EFCNLB:  Effluent  cyanide (.001  Ib/day).
 no»«   listinf.of the  data  ^se  used   in  determining  the
 pollutant   specific   variability   factors   is   available  in

 68-01-6062*     "115' A °f  ^  reP°rt  Cited  f°r  EPA  contract
 B'   Definition and Use of Variability Factors

 The pollutant effluent level from a physical treatment process is
 subject to a certain degree of inherent  day-to-day  fluctuation.
 Limitations should account for this variability while at the same
 time  incorporate  an  acceptable level of treatment performance
               a?hievable Affluent limitations are  determined  Is
 a™,,      f  °S •?   ~?ng term avera9e performance and a factor
 accounting for daily effluent variability.
            a         factor  is  defined  as  the  ratio  of  the
 estimated 99th percentile of the distribution of pollutant values
 <~  *.£    estimated mean value of the distribution.   The mean used
 is  the arithmetic average of aM the daily values for a  specific
 pollutant  which were not deleted on the basis of being erroneous
 or  descriptive of aberrant performance.
                     variability   factors   were  calculated  using
             i methods   on   the   long   term  data  available  from
           plants.   These pollutant-specific variability  factors
were then combined across plants  to obtain an overall  variability
factor  for  a  given   pollutant.   The concentration  variability
da^0rwaoa^"iajed,1fr?ln fc?e reP°fted dailV effluent  concentration
data, was used to derive limitations on effluent  concentrations.
     ?a!S _d?-?charge variability  factors were calculated from  the

             1   fl°W   V°1Ume   and    th€    dail*    concentration
«e      14        an5 30 day average maximum) variability factors
used in limitations development  are  discussed  in  the  ensuing
suDsections.
                                236

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a.   Daily Variability Factors.  Several approaches were used  to
estimate  the — 99th percentile distribution of daily values.  One
tpprSacS fit! a'paraSetric distribution to the data set and  then
estimates  the  99th  percentile  using  the fitted distribution.
?hree dfStributions we?e  examined  in  this  study:  the  normal
distribution,  the  two  parameter lognormal distribution and the
three parameter lognormal distribution.  The normal (or Gaussian)
distribution has a symmetric bell shape and is  characterized  by
?wo  parameters,  its  mean  and its standard Deviation   The two
parameter  lognormal  distributions  in  the  distribution  of   a
variable  whose  logarithm  has  a  normal  distribution;   it  is
charactSri^by the same two  parameters   This Distribution  was
examined  because it corresponds closely to the observable  skewed
behavio? of  the variables in this data set, (I.e.,  the occurrence
of a la'rae "tail" of observations  toward  the  higher  pollutant
values).   The  three parameter lognormal distribution is similar
to the  two parameter distribution but  it contains   an  additional
oarameter  which allows  a constant shift to be applied to all the
vtlSeV of the distribution.  Due to the difficulty  in • estimating
the three parameter  lognormal  distribution, two different methods
of  fitting  this distribution  to the data were used.  The methods
 68-01-6062,  Task 1 .

 Another  approach  investigated  for  estimation  of   the   99th
 pe?centile  of  the  daily pollutant values assumes no parametric
 distribution and hence is referred  to  as  "nonparametric.    The
 estimate  is referred to as a 50 percent tolerance level estimate
 of  the  99th  percentile.   For  calculation   procedures,    see
 Statistical  Appendix  D of the report cited for EPA contract 68-
 oT-6062" task 1   in order to calculate  nonparametric  tolerance
 estimates,   a  minimum  number  of  data  values  are  required
 specifically   a  50  percent  tolerance  estimate  of  the  99tn
 pelcentile  can  be calculated only if 69 or more data values are
 available.

 The final approach considered is a combination of parametric  and
 nonparametri?  methodologies.   The  data  values  above the 90th
 nercentile   (upper  10  percent   were  assumed  to   follow   an
 Ixponentill  distribution.   The  fitted exponential distribution
 SSTthen used to estimate the 99th percentile of daily  pollutant
 values?   This  estimate  is referred to as the  "ta ^exponential'
 assumption  and was suggested by the  skewness   exhibited  by  the
 data.   Since the variance associated Wlfch the  tail-exponential
 99th percentile estimate  can  be  shown   to  be   less  than  the
 variance  of  the nonparametric estimate for a  given sample size,
 this estimate was calculated only  if  69   or  more  samples  were
                                 237

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                                           \
 available.    (See  Statistical  Appendices  E   & G  of  the  earlier
 cited SRI report for procedures and references).

 In  order  to  compare  and  assess  the  fits  of  the    assumed
 distributions   to   the   plant-specific  pollutant   data sets,
 statistical goodness-of-fit  tests  were  applied.   Two   general
 tests,  the  Kolmogorov-Smirov and the Anderson-Darling were used
 to test  each  distribution:   normal  two  and  three  parameter
 lognormal,  and  tail exponential.  A specific test of normality,
 the D Agostiro test, was also used to test the fit of  the  data to
 the normal and  lognormal  distributions.   The  Watson  test  of
 exponentiality  was  applied  to  test  the tail-exponential fit.
 Overall comparisons of the goodness-of-fit of  each  distribution
 to the data for each variable were made by combining the tests at
 each  plant  via  Fisher's  combined  test  of significance.  The
 results and procedures are described in Statistical Appendix F of
 the  earlier  cited  SRI  report.    In  summary,  the   following
 conclusions   are   evident   from   the  overall  assessment  of
 distribution fit:
                                           j

 (1)   In most cases,  the normal   distribution  does  not  fit  the
      observed data.

 (2)   The  lognormal  (2- and 3-parameter)   distributions  fit  the
 data  moderately  well,   and considerably better than the normal
 distributions.  Of  these,  the 3-parameter  lognormal,   fitted  by
 the  MMLE method provided the best  overall  fit.

 (3)   The tail-exponential  distribution,   providing   a   sufficient
      number    of   observations    is   available,   fits   the  data
      acceptably and  certainly more effectively   than   the  other
      distributions.   The   instances   of  apparent  lack  of  fit  can
      reasonably be attributed to statistical fluctuation.
                                           [ I  II    1    ,,j , "' JB1'1,	',• ,' j!; '''„ •': » .1, 'ii'ii, ". v,
 Since  the nonparametric  estimate assumes no distributional   form
 the question of goodness of  fit is not at  issue.

 Many  of  the   plants  did   not provide sufficient  information  to
 calculate  either  the   tail-exponential  qr  the    nonparametric
 estimate  (i.e.  sample sizes were less thain 69).  Because  it was
 important to  utilized  as  much   plant-specific  information  as
possible   a    variability    factor   was  ; calculated  for each
plant/variable  combination   according  to  the  best   procedure
consistent with the amount of data available.

For each variable at each plant, the best procedure  is  defined as
follows:

 (1)  If 69 or more pollutant values are available,  then  utilize
     the  tail-exponential  estimate unless goodness-of-fit tests
                               238

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     reject tail-exponentiality.   Otherwise use the nonparametric
     estimate.

(2)  If 69 or more pollutant values are not available, use the 3-
     parameter lognormal MMLE fitting procedure.


For each  pollutant  the  average  of  the  selected  variability
factors  (weighted  by  the number of observations at each plant)
was computed (See Statistical Appendix H of the earlier cited SRI
report for formulas).  These average daily  maximum   variability
factors  (concentration  and  mass based), along with minimum and
maximum factors plant variability and the number of  plants  used
in the calculation of the average factors is found in Table IX-2.

b.   Monthly Variability Factors

A  30-dav average variability factor is defined  as  the  ratio  of
the  estimated  99th  percentile  of  the  distribution of 30-day
averages of daily pollutant values to  the  estimated  long  term
mean  value.  A 30-day average is the arithmetic mean of  30 daily
measurements; the sets of measurements used in  determining  each
monthly  average  are assumed to be distinct.   The long-term mean
is the long term arithmetic mean of 30 day averages   and   is  the
same as the long term mean of the daily pollutant values.

The  30-day  variability factors were developed on the basis of  a
statistical result known  as  the  Central  Limit  Theorem.   _The
Theorem    states   that,   under   general   and   nonrestnctive
assumptions, the distribution of a sum  of  a   number of _random
variables,  say  n,   is  approximated by  the normal  distribution.
The  approximation   improves  as   the  number   of  variables,   n,
increases.   The  Theorem   is quite general in  that  no particular
distributional form   is  assumed   for  the  distribution   of   the
individual variables.   In  most  applications  (as  in determining
the  30-day limitations)  the  Theorem  is used  to  approximate   the
distribution  of  the  average  of  n  observations   of   a random
variable.   The result is important because  it  makes   it   possible
to  compute  approximate probability  statements about the average
 in a wide range  of   cases.   For   instance,   it  is  possible  to
compute  a value  below which  a specified  percentage (e.g.  95  or 99
oercent)   of   the   averages  of  n  observations  are likely  to  fall.
Most textbooks state that  25 or 30  observations  are  sufficient
 for the  approximation to be valid although  in  many cases  10  or 15
 are  adequate.    In  applying  the Theorem to  the determination of
 30-dav  limitations,  we  approximate  the  distribution  of  the
 average   of  30  observations drawn from the distribution of  daily
 measurements..
                                  239

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 Various  forms  of   this  Theorem  exist  and  are  applicable  for
 different  situations.   A key  assumption in  the most  familiar form
 of   the  Central Limit  Theorem is  that  the  individual measurements
 are  independent.   That is,  it is  assumed that  measurements   made
 on   successive days   or any  fixed   number   of  days   apart are
 statistically  independent or  not   related.    This  assumption  of
 independence is rarely satisfied  in an absolute sense in effluent
 data.    In  many cases,  however,  the assumption is satisfied to a
 degree sufficient  to yield  a  suitable  result.   In  the case of the
 pharmaceutical data, there  is evidence of dependency in  the   data
 that   should   be   incorporated   into \  the  determination  of
 limitations.   The Central Limit Theorem can   still   be   used  in
 developing  variability  factors in the case of dependent  data but
 some of the necessary  calculations must  be  modified to  account
 for  the  dependency   and  more  samples  (i.e.  larger n) may  be
 required for the approximation to be adequate.   In   the   case  of
 positive  dependence (the usual situation with  effluent data) the
 modifications will result in  a larger  variance  of  the  mean   than
 would  be  obtained  if   independence   is  assumed.  This in  turn
 results in a  larger   limitation  for  the  mean   than  would   be
 obtained  if  independence  is assumed.  The technical details  of
 the Central Limit Theorem including  computational   formulae  and
 results  obtained  for  the  pharmaceutical data are described  in
 Chapter V and Statistical Appendix I of  the  earlier  cited  SRI
 report.    The average 30-day variability factors (weighted by the
 number of observations at  the  plant)   was  computed  and  these
 values,   along   with  minimum and maximum variability factors and
 the number  of plants used  in  the  calculating  of  the  averaae
 factors,   are  presented  in  Table IX-3.  Both concentration and
 mass  based  variability factors are shown.
 c.    Applicability of  Variability
 Levels  of  Plant Operation
Factors  at  New  Performance
    •  u^?®E   J°   evaluate  the  applicability  of   the  calculated
variability  factors  when applied  to plants  operating  at generally
lower levels of  pollutant concentration,  the plant-specific  daily
variability  factors  and  the  30-day  variability factors   for   each
variable  were   plotted   versus  the mean   concentratAon of the
pollutant for each plant (see Figures VI-1-1throughVI-2-8 of
the   cited SRI Task  1 report),  contractor's report).   Similarly,
iL-r^?^- t0f elaluatf   the  applicability  of   the    calculated
variability  factors  to plants  operating!  at   higher pollutant
reduction percentages, plant-specific  variability  factors   were
plotted  versus  the average  percentage reduction  of the pollutant
at each plant (see Figures VI-3-1 through Vl-4-8  of the cited SRI
report).  No trends are  generally observable   in  either  set of
plots,  except   for  the  somewhat   greater   scatter  of  the dailv
factors based on smaller numbers of  observations
                                240

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As a further check, the Spearman rank correlation, a  measure  of
monotonic  (not  necessarily linear) association, was computed in
each case.  The Spearman correlations are shown  in  Tables  VI-1
and  VI-2  of the above cited report.  Spearman correlations were
not calculated for cyanide since cyanide values  were  used  from
one  plant.   Based  on these analysis, there exists little or no
association of variability factors with the mean pollutant  level
or  percent  reduction.   As long as similar control technologies
are employed this result suggests that the  computed  variability
factors  are indeed appropriate for plants operating at different
performance levels.

d.   Regulatory Limitations

For each pollutant, concentration  and  mass  discharge  effluent
limitations   were   determined   by  multiplying  a  pollutant  s
across-plant or average variability factor  by   its  across-plant
long  term average.  As with the across-plant variability factor,
the across-plant long  term average was  determined  by  weighting
the  individual  plant's  long  term  average  by their pollutant
specific sample sizes.  Daily maximum and 30-day average  maximum
concentration  limitations   (in  concentration and mass discharge
units)  along  with  the  across-plant  long  term  averages  and
variability  factors   are  shown  for  all  the  pollutants to be
regulated  in Table IX-4.  The respective type  of  limitation  or
standard   to which the long  term averages and variability factors
apply is also indicated.

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                           Table IX-1    '.

               PLANT IDENTIFIERS AND SUBCATEGQRIES
            IN THE PHARMACEUTICAL LONG-TERM DATA BASE
PLANT CODE NO.

     12015
     12022
     12026
     12036
     12097
     12098
     12117
     12123
     12160
     12161
     12186
     12187
     12236
     12248
     12257
     12294
     12307
     12317
     12420
     12439
     12459
     12462
SUBCATEGORIES

          D
         AC
          C
          A
         CD
          A
          B
         CD
          D
        ACD
         CD
          C
          C
          C
      ABCD
         CD
          D
          D
         BD
         CD
          D
          A
                              242

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                           Table IX-2
                    DAILY VARIABILITY FACTORS
                       Concentration Data	
Pollutant

BCT and BAT Plants

     BOD
     COD
     TSS

NSPS Plants

     BOD
     COD
     TSS

     Cyanide
Number
  of
Plants
  13
  12
  13
  10
  10
  10
Weighted
Average
   VF
  4.53
  3.03
  5.07
  4.43
  3.43
  5.60

  3. 1
Min
VF
2.58
1 .92
2.35
2.58
2.20
2.56
Max
VF
    Mass Discharge Da
Number  Weighted
  of    Average    Mi
Plants     VF      VF
  16.25
   6.95
   7.60
  16.25
   6.95
   7.60
  13
  12
  13
  10
  10
  10

   1
4.65
3.30
5.15
4.64
3.55
5.74

3.34
2,
2
2,
2,
2,
2,
Note:  VF = variability factor
                                 243

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                           Table IX-3
                   30-DAY VARIABILITY FACTORS
                       Concentration Data
Pollutant

BCT and BAT Plants

     BOD
     COD
     TSS

NSPS Plants

     BOD
     COD
     TSS

     Cyanide
Number
  of
Plants
   4
   5
   6
   3
   4
   5
Weighted
Average
   VF
  2.04
  1 .96
  2.04
  2.78
  1 ,
  2,
70
07
      Min
      VF
      1 .56
      1 .48
      1 .71
1 .56
1 .48
1 .71
     Max
     VF
        2.59
        2.25
        2,70
2.04
2.25
2.70
             Mass Discharge Da|
         Number  Weighted
           of    Average    Mil
         Plants     VF      VF|
            4
            5
            6
3
4
5
          1 .81
       2.04
       1 .77
       2.09
1 .80
1 .79
2.16

2.0
Note:  VF « variability factor

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                           Table IX-4

LONG TERM AVERAGE-CONCENTRATIONS, VARIABILITY FACTORS AND LIMITATIONS
Regulation
BCT
BAT
BCT
NSPS
NSPS
NSPS
Pollutant
BOD
COD
TSS
BOD
COD
TSS
Mean
Pollutant
Level (mq/1)
55.48
338.0
50.94
28.51
263.7
34.73
D
Variability
Factor
4.53
3.03
5.07
4.43
3.23
5.60
ailv
Limitation
Value (ma/1)
252
1024
258
126
853
195
Var
Fa






     BPT, BAT and
     NSPS
Cyanide
.207
                                                 3.1
                                          .643
                                245

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                             SECTION X

                                BPT
 A .   Summary

 1 .   General

 The factors  considered  in  defining  best  practicable  control
 technology  currently available (BPT) include:  (1) the total cost
 of applying the technology relative to  the  effluent  reductions
 that  result,  (2)  the age of equipment and facilities involved,
 (3) the processes used, (4) engineering aspects  of  the  control
 technology,   (5)   process   changes,   (6)   nonwater   quality
 environmental impacts (including energy  requirements),  and  (7)
 other  factors,   as  the Administrator considers appropriate.  In
 general, the  BPT  level  represents  the  average  of  the  best
 existing  performances  of  plants within the industry of various
 ages,  sizes, processes, or other  common  characteristics.   When
 existing   performance   is  uniformly  inadequate,  BPT  may  be
 transferred in from a different  subcategory  or  category.    BPT
 focuses  on  end-of -process treatment rather than process changes
 or  internal controls,  except when  these technologies  are  common
 industry practice.

 The  existing BPT  regulation requires all subcategory plants to
 reduce  their raw  waste BOD5. loading by 90 percent and  their  raw
 waste COD loading by 74 percent.   It also requires subcategory B,
 D,   and  E plants to achieve a monthly maximum average of no more
 than 52 mg/1 for  TSS.   The  latter  requirement has been  found  to
 be   an   overly  stringent   one  for  the  technology basis of BPT.
 Amended  limitations  are   proposed  based   on  additional  data.
 Reflecting  what   is actually achievable  by that technology.   EPA
 is  also proposing new  cyanide limitations based   on  the   use  of
 cyanide destruction  technology currently  by the  industry.
     .     of limitations are being proposed.   The  first  set,  the
TSS  limitations, are to replace the existing  TSS limitations  for
subcategory B, D, and E plants with limitations which will  apply
to  subcategory  A - E plants.  The second set of limitations  are
new and will apply to all A, B, C, D, and all   mixed  subcategory
plants  but  not  to  E  only  plants.   In addition, current  BPT
limitations for  BOD5_  and  COD  Based  on  a   percent  reduction
calculation  are  revised  to  allow  dischargers   the  option of
meeting specific BCT and  BAT  concentration   based  limitations,
whichever is less stringent.

2.   Limitations
                              246

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BPT limitations are summarized in Table X-l below.

                            TABLE X-l

                    BPT EFFLUENT LIMITATIONS
Pollutant

TSS mg/1
Cyanide ug/1
BOD5_ mg/1
COD mg/1
                    30-Day Average Maximum

                              217
                              375
                         113 or existing BPT
                         570 or existing BPT
                                                  Daily Maximum
643
                                            BPT  Limitations   for
No changes are being made in the  existing
BOD5_, COD and pH (codified at 40 CFR 439).

B.   IDENTIFICATION OF BPT                       .

1.   Prior Regulations

BPT   was   originally   promulgated   for   the   pharmaceutical
manufacturing industry as an interim final regulation in November
of   1976.    The  regulation  divides  the  industry   into  five
subcategories:  fermentation  (A),  biological  extraction   (B),
chemical  synthesis   
-------
 Limitations on the discharge of  cyanide are necessary  not only  to
 control the effluent discharge of  cyanide, a  toxic pollutant,   to
 surface   waters  but  also  to  prevent   interference with  the
 operation of in-plant biological treatment systems.

 3.   Methodology Used                      |

 a.   TSS Limitation

 An  analysis  of  th  current  treatment  performance  of  direct
 discharging  plants  serves as the basis for  the modification .and
 extension of the existing TSS limitation.   ;The TSS Limitation for
 subcategories B,  D, and E in the existing regulation stipulate  a
 30 day maximum average of 52 mg/1 based on :a  long term average of
 18  mg/1.    The  NPDES permits issued, before that regulation was
 issued as well as the available 308 and  long  term  daily  data
 indicate this level is overly stringent.
                                            i
 Compliance  with   this limitation is generally achieved mostly by
 plants  that  generate  low  raw  waste  levels  of  TSS  (mostly
 formulation  (D)   only  plants).    For  the  industry as a whole,
 compliance with the TSS level could in fact force  BOD5_  and  COD
 removal  in  excess  of  that required under the 1976 regulation.
 Therefore   the  1976   TSS  limitation  is   hot  reasonable  as  a
 performance criterion for BPT.
                                            I
 Accordingly,   the  Agency has decided to propose a less stringent
 limitation which  will  apply to  all  plants  covered by  the existing
 regulation.   This limitation will be a more in keeping   with  the
 demonstrated  performance  of BPT systems.
                                            I
 This   amended limitation  is derived from data  submitted by direct
 discharging plants  in  the 308 and long term daily  data  surveys.
 The  long   term   average   performance  with respect  to TSS  Of 41
 plants  which  have in-place  some   type of   biological   treatment
 provides   the  immediate data  base for the  limitation.   This  group
 of performance values has been  specifically chosen   because  the
 group   of  plants  submitting   them is most representative of  all
 direct   discharging   pharmaceutical   plants   in   terms    of
 manufacturing processes and  treatment employed.   Table  IX-1  lists
 the TSS average values used  to  compute the  new long term average,
 the  identification  numbers  of  plants  submitting  them,  their
 process wastewater flows,  their manufacturing  subcategory(s)   and
 the  actual  source  of   the  value.    Table   IX-2  compares   the
 subcategory breakdown of  the plants  in the  new  TSS   limitation
 group with that of the entire direct  discharger population.
                                            I
When  both long term daily and 308 data were available, long term
daily average value was used in preference  to  the 308   value  for
TSS  because  the long term daily value for the TSS was supported
                               24-8

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by a significant number of observations  which  make  possible  a
more  accurate judgement about the solids removal achieved by the
plant's treatment system.  The one notable exception was  in  the
case  of data from plant 12462.  This plant submitted average TSS
values of 97 and 2022  mg/1  in  the  308  and  long  term  daily
surveys,  respectively.   The  value  of  2022  mg/1 was not used
because it reflects negative removal  of  TSS  by  the  treatment
system.   In  all  other  cases,  the  308  value  did not differ
significantly from the long term daily average  value.   The  TSS
value  of  97  is  also  a  long term average value since the 308
survey participants were requested to supply annual averages.

The new long term average concentration for TSS Is 75 mg/1.  When
multiplied by the appropriate variability factor, this results in
the amended 30 day average maximum limitation.   The  variability
factor    (2.89)  used  is  identical  to  the  one  used  in  the
development of the existing TSS limitation.  This factor was used
in preference to the one calculated from the long term data since
most of   the  averages   (25  of  41)  used  to  compute  the  TSS
limitation  base  average were from 308 submissions.  These dtata
submissions are not supported by  daily  or  weekly  values  and,
therefore,  it  was  not  possible  to calculate a 30-day average
maximum variability factor from the available data that would  be
representative  of  the  average of performance of all 41 plants.
In addition, all 41 data submissions describe the performance  of
treatment  systems    that  were  installed  in  response  to  or
coincidentally with the development of the  existing  regulation.
The TSS variability factor calculated for the original limitation
is  therefore  considered  appropriate  for  use  in  setting the
amended BPT TSS limitation.

b.   Cyanide Limitations

About  7 to  10 percent  of all pharmaceutical plants  may  use  and
generate  waterborne   cyanide  waste on a regular or  intermittent
basis.  Cyanide destruction units are in-place  in several  plants
and  long term data was  requested which describes the performance
of these  units.  Two plants provided data on the  performance  of
cyanide   control  technology.  However, one plant was an  indirect
discharger  that provided much  less extensive data  and  therefore
data    from this  plant  was  not  used   in  developing   cyanide
limitation  for direct  dischargers.

The 30-day  and daily maximum  limitations  are  derived  from  data
submitted  by  plant   12236   on   the  performance of  its  alkaline
pyrolysis cyanide destruction  unit.   The   concentration   results
submitted  are  final  effluent values and  do account  for  dilution
by other  'non-cyanide process  wastewater.   These limitations  make
no  distinction  as  to   the   form of the  cyanide  in  the  effluent
 (complexed  or noncomplexed).   The Agency  will request  additional
                                249

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data on  the performance  of  cyanide  destruction  technology in  this
rulemaking.

The statistical  treatment of  the  daily  cyanide  data was  discussed
in Section IX.                              !
c.   Alternative   BPT,
Limitations
                     BODS   and
COD
Concentration-based
The  revised alternative  concentration-based  limitations  for BOD5_
and COD are proposed to d to  revise  the  existing  BPT   regulation
to  allow  plants  with low raw waste  loads[the option  of meeting
the  concentration-based   limitations  proposed   BCT   and   BAT
limitations.   This  proposal will eliminate  the possibility that
for any plant BPT could be more stringent  than  BCT  and/or  BAT.
These  proposed  limitations are stated in  terms of 30-day average
maximums as were the original BPT percent  reduction  limitations.

4.   Engineering Aspects  of BPT

A technical review and evaluation of the  treatment  technologies
employed  in the industry presented  in Section VII Indicates that
the industry makes use of a variety of in-plant  and  end-of-pipe
technologies.    In-plant   controls  consist   of solvent recovery,
steam stripping, metals precipitation  and cyanide  destruction.
Filtration  of   mycelia from fermentation  wastewater (required by
the existing  BPT  regulation)  will   reduce  the  nutrient  BOD5_
loading before combination with other  wastewater.  In some cases,
the  mycelia  are  a  recoverable  by-product.   The  end-of-pipe
treatment technologies employed in the industry  include  primary
clarification, neutralization and neutralization and equalization
followed  by  secondary   biological  treatments such as activated
sludge, aerated  lagoons and  trickling  filters  and  finally  by
tertiary treatments such  as polishing  ponds'.
Generally,  the  industry
material and wastes which
generated.  However, some
often   necessary  before
biotreatment technologies
lagoons,  and  trickling
filtration.
                      engages  in  theiprocessing of organic
                     are strongly acid lor alkaline  are  not
                     neutralization of equalized influent is
                      secondary  treatment.   The  secondary
                     used include activated sludge;,  aerated
                     filters,  bellowed  by clarification or
5.
Cost in Relation to Benefits
The implementation costs for the amended BPT regulations will  be
incurred   by  plants  which  must  install  cyanide  destruction
equipment.  No implementation costs or Ibs of TSS removed can  be
attributed  to the new TSS limitation for two reasons.  First, as
to subcategories B, D, and E the regulation does not require  any
                                250

-------
new  treatment.   Second,  the  costs  for  subcategories A and C
plants are either attributable to  compliance  with  the  current
BOD5.  and  COD  percent reduction limitations or are not required
because the limitations can be met by changes in treatment system
operation.

On the basis of the information available from the 308 survey and
the S/V program, 6 plants will  incur  a  total  of  $628,000  in
annual  costs  and $1,740,000 in investment costs (1980 dollars).
We estimate that these regulations will result in the removal  of
17,000  Ibs/year  of  cyanide from the effluent of pharmaceutical
plants.

6.   Nonwater Quality Environmental Impact

The four general categories  of  RCRA  wastes  generated  by  the
pharmaceutical  industry  are sludges, waste solvents, infectious
wastes and returned goods.  None  of  these  is  expected  to  be
increased significantly as a result of this amended regulation.

Sludge  from biological treatment can mostly be landfilled as can
separable solid process waste such as mycelia from fermentation.
Implementation  of  BPT  in-plant  cyanide  destruction  is
expected to affect air emissions.
not
The energy consumption and energy costs of BPT implementation are
expected  to be small.  The increases in energy needs are largely
limited to additional power requirements for pumps and  agitators
needed  for cyanide destruction systems.  These requirements tend
to be very small in scale.
                                251

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                            TABLE X-l
         EFFLUENT TSS PERFORMANCE OF DIRECT DISCHARGERS
                     (308 & Long-Term Data)
PLANT NO.

  12053
  12463
  20319
  12406
  12317
  12015
  12089
  12287
  20201
  12117
  12407
  12459
  12097
  12104
  20165
  12298
  12132
  12338
  20245
  12307
  12161
  20246
  20297
  12205
  12036
  20037
  12283
  12294
  12294
  12471
  12248
  12187
  12236
  12119
  12022
  12462
  12160
  12239
  12026
  12038*
  12098
SUBCATEGORY

     D
    BD
     D
     C
     D
     D
    BD
     D
     D
    BD
     C
     D
    CD
     D
    BC
     D
    AC
     D
    AC
     D
   ACD
     C
     C
     D
     A
     D
     D
    CD
    CD
     B
     D
     C
     C
    AC
    AC
     A
     D
     D
     C
  ABCD
     D
 DATA
SOURCE

 308
 308
 308
 308
 L.T.
 L.T.
 308
 308
 308
 L.T.
 308
 L.T.
 L.T.
 308
 308
 308
 308
 308
 308
 L.T.
 L.T.
 308
 308
 308
 308
 308
 308
 L.T.
 L.T.
 308
 L.T.
 L.T.
 L.T.
 308
 L.T.
 308
 L.T.
 308
 L.T.
 308
 L.T.
FLOW
(MGD)
0.004
0.057
0.003
0.370
0.740
0.101
0.155
0.131
0.002
0.101
0.731
0.049
0.064
0.367
0.004
0.003
1.000
0.001
0.500
0.002
  653
  250
0.001
0.030
 .128
0.043
0-013
6.118
0.118
0.043
0.110
1.065
0.816
0.032
 .300
0.170
0.006
0.002
0.161
0.855
0.006
1
1
1
1
AVERAGE
EFFLUENT TSS
   (mq/L)

     2
     9
     9
    10
    10
    11
    13
    13
    14
    16
    17
    17
    18
    22
    24
    26
    29
    30
    32
    32
    32
    33
    36
    40
    44
    47
    50
    59
    59
    59
    60
    61
    62
    70
    85
    97
   115
   174
   284
   340
   392
                               252

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  12261             C              308
               Total Flow = 13.237 MGD
Plant Avg. Flow = 0.323 MGD
Flow-Weighted TSS Avg. = 65 mg/1
Plant Avg. TSS =75 mg/1
                            0.051
                         567
Plants lacking effluent TSS data;
  12001
  12006
  12014
  12030
  12057
12073
12085
12194
12235
12256
12264
12267
12281
12308
12339
20257
20298
20370
20370
20402
Plant with TSS data but without biotreatment:

  12095
*Provable process flows  only;  incinerator  scrubber  water  and
other diluting flows not included.

                            TABLE X-3

SUBCATEGORY BRACKDOWN OF TSS GROUP PLANTS COMPARED TO ALL DIRECT DISCHARGES.

     % Subcateaorv Plants  TSS Group  All Direct Dischargers
              A
              B
              C
              D
            Mixed
                    4.9
                    2.4
                   19.5
                   43.9
                   26.3
                       3.2
                       1 .6
                      19.7
                      45.9
                      29.5
                               253

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                            SECTION XI      I

         BEST  CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
                        CURRENTLY AVAILABLE
A.    Summary

1 .    GENERAL

The   1977  Amendments   added   Section  301 (;b) (2) (E)   to  the  Act
establishing   "best  conventional   pollutant  control technology"
(BCT) for discharges of  conventional  pollutants   from  existing
industrial  point  sources.    Conventional   pollutants  are those
defined  in  Section   304(a)(4)   [biological   oxygen   demanding
pollutants  (BOD5J, total  suspended solids  (TSS),  fecal coliform,
and   pH],  and  any  additional    pollutants   defined   by   the
Administrator  as  "conventional"   [oil  and grease,  44 FR  44501,
July  30, 1979].

BCT is not an additional  limitation  but  replaces BAT  for  the
control of conventional pollutants.   In addition to other factors
specified  in  section 304(b)(4)(B),   the   Act requires that  BCT
limitations   be   assessed    in    light    of    a    two   part
"cost-reasonableness"  test.  American Paper Institute v.  EPA,  660
F.2d  954  (4th Cir. 1981).  The first test; compares  the cost  for
private industry to reduce its conventional! pollutants  with  the
costs  to  publicly  owned treatment works for similar levels of
reduction in their discharge of  these pollutants.    The  second
test  examines  the  cost-effectiveness  of additional industrial
treatment  beyond  BPT.    EPA ' must  find  that limitations  are
"reasonable"  under  both  tests before establishing  them as BCT.
In no case may BCT be  less stringent  than BPT.
2.
LIMITATIONS
BCT limitations are summarized in Table XI-1 below:
                           TABLE XI-1
Pollutant

BOD (mg/1)
TSS (mg/1)
pH
               Range
30-Day Average
   Maximum
        i
   113  '
   110
Daily Maximum

   252
   291
B.
               6.0 - 9.0

Identification of BCT
                               254

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1.    Methodology BCT limitations which are  more  stringent  than
existingBPT  limitations  for  a  given  industrial category or
subcategory must satisfy a two part "cost  reasonableness  test.
The  first  part of the test involves a comparison of the average
annual removal cost incurred  by  direct  discharging  plants  in
upgrading  from  existing  BPT to BCT level performance regarding
the treatment of conventional pollutants with an  analogous  POTW
removal  cost  figure.   The  latter  figure,  $0.42/lb  in  1980
dollars, is an estimate of the incremental removal costs incurred
by an average POTW which has upgraded from secondary to  advanced
secondary   treatment.   If  the  average  industry  category  or
subcategory removal cost is  less  than  this  figure,  the  more
stringent  BCT limitations meet the requirement of the first part
of the test.  The second part of the test entails calculation  of
the  ratio  of the removal cost incurred in upgrading from BPT to
BCT to the removal cost incurred in upgrading from a raw waste or
treatment in-place (at the time of BPT  promulgation)  status  to
existing BPT.  The choice of status depends on the reliability of
the  data  available.   (The  raw  waste  status was used in this
rulemaking,  based  on  that  criterion).   This  ratio  is  then
compared  to  an  incremental  cost  ratio  1.43  (which has been
obtained by dividing the average annual removal costs incurred by
a POTW  in upgrading from a secondary  to  an  advanced  secondary
treatment  level  by the average annual removal costs incurred in
upgrading from a primary to a secondary treatment level.)  If  an
industry  category  or  subcategory  meets the requirement of the
first part of the test and the calculated  incremental  ratio  is
less  than  1.43,  then  the  cost  of  the  BCT  limitations are
considered reasonable.  If the  calculated  figures  are  greater
than  the  benchmark figures in either case, BCT limitations must
be  raised  until  the  calculated  figures  are  less  than  the
benchmark figures in both cases.
2.
Costs
The plant-by-plant  incremental  annual costs   for   upgrading   from
BPT  to BCT performance  levels  were assigned  using an  incremental
treatment  stage  approach.   First,  the  average  effluent   BOD
concentration   from  the plant's  308 as  long  term  data submission
was compared to the anticipated BCT long term  data average   for
BODS   55   mg/1.   Then .an   estimate  was  made of the number of
treatment  stages which had  to be   added  to   a plant's  existing
biological treatment system to  produce a long term effluent BOD
of 55  mg/1.  These  treatment stages are  equivalent  to  increases
in  unit   capacities within the system   (greater equalization,
aerated lagoon  or   clarifier   capacity).   All cost   increments
assume an activated sludge type  of treatment, the most expensive
of the three types  considered  (the others being RBC's  and ponds).
Costs  for  plants discharging less than 3000 gpd were based on the
assumption that they would   haul   their  concentrated   wastewater
                                255

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 (see   Table  VIII-30)   to comply with  the limitations  rather than
 upgrade  existing  biological   treatment,    an   extremely   cost
 ineffective  solution   at  these  low  flow rates.   All costs were
 computed  in 1980   dollars.   These  estimates   are   conservative,
 because  many  plants  may be able to improve removal by adjusting
 the operation of  existing treatment  stages,  thus  saving costs.

 An updated  (1980)  version of a  graph of   annual   treatment  costs
 versus flow  (see  original  document (55)) was  used  to estimate
 annual costs for  BPT (biological treatment)  systems.   This  graph
 was  obtained  by  plotting subcategory  moqlel plant annual  costs
 versus flow.   This technique was considered;appropriate  in   view
 of the number of  mixed subcategory plants.

 3.   Pollutant Loading Reduction Calculations

 The  annual   conventional   (BOD  and  TSS)    pollutant   loading
 reductions  to be  achieved  upon  upgrading  from  existing BPT to BCT
 level   performance  were   calculated  in   following manner.  The
 average long  term BOD  and  TSS concentrations submitted in the 308
 or long term  data   surveys  were  multiplied   by  the   respective
 variability  factors in the  existing  BPT regulation, 3.0 and  2.89,
 to obtain the 30-day maximum average concentrations.   (Generally,
 long   term  data   average  concentrations were  used  when available
 because they  were derived  from  data   which    were   readily
 verifiable).   Thirty-day average maximum concentrations were  used
 because the   POTW  benchmark   figures were  calculated using  this
 type of concentration  limitation.  Thereafter, the  30  day average
 maximum concentrations (mg/1) were multiplied  successively by the
 average process wastewater  flow  (MGD),  365 days per yecir,  and  a
 conversion  factor  (8.34)  to   give the annual BOD5_ and TSS  load
 from the plant's BPT system.  In a similar manner the  plant's BCT
 annual  loading  was calculated using  the long term averages and 30
 day variability factors derived  from the BCT plant  data  set  (13
 sets   of  long  term data)  in Section IX.  The  plant's  BCT loading
 was then subtracted from the existing BPT  loading  to   determine
 the  incremental   removal obtainable by upgrading from  BPT to BCT
 level performance.   The  individual  incremental  loads   for  all
plants  in  the  test  group  were   summed  to give the  aggregate
 incremental removal  for all plants tested.   This   aggregate  was
 used for both parts  of the  cost  test.
                                            i
The  other  number  required for  the  second part of  the  cost test,
 cost of BPT removal, was calculated  using raw waste and   effluent
annual  averages   from  308  and   long term data.    (A variability
factor of 1.0 was  assumed and applied to the  average   raw  waste
concentrations     to    generate     30     day   average   maximum
concentrations).   When  308   and   long   term   data    average
concentrations    were   not   available,    average   raw   waste
concentrations  characteristic  of   the   plant's   manufacturing
                               256

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activities  (in  the  case  of  TSS)  or raw waste concentrations
derived by assuming BPT compliance  (e.g. 90 percent method in the
case of BOD5) were used.  The calculations were performed in  the
same manner~as the previously described calculations.  Individual
BPT  loadings  for  plants  were  subtracted  from  the raw waste
loadings.  The results were summed to give the total  removal  by
BPT technology for all plants tested.

4.   Test Criteria Results

EPA performed the BCT cost test using data  from  28  of  the  60
known direct dischargers in the pharmaceutical industry.  Thirty-
two  plants submitted data which indicate that they are currently
in compliance with the proposed BCT limitations for BOD5_ and TSS.
(Therefore, no costs as pollutant reductions are attributable  to
these  plants).   If  the  28  plants pass the BCT cost test, the
industry passes.  The tests were performed  using  the  submitted
concentration  and  flow  data except in cases where insufficient
data were available as in  the  case  of  18  plants.   In  these
instances  the calculations were performed using industry average
effluent concentrations  for  BOD5_  and  TSS  and  plant-by-plant
estimated  upgrade costs based on these industry average effluent
concentrations.

Before  discussing  the  results,   one  exception  to  the  above
procedure requires explanation.  One plant, 12256, indicated that
it  had  an effluent flow rate of 30 MGD.  This flow was composed
of both treated process effluent and  once-through  stream  water
which  is  used  for  barametric  condensation.  Since it was not
possible to  determine  the  actual  flow  rate  of  the  treated
effluent  from  actual  manufacturing  operations, it was assumed
that ten percent of the 30 MGD flow is from manufacturing and the
costs and pollutant reductions were calculated accordingly.  This
flow (3.0 MGD) is equivalent to that of the average  large  plant
in  the  industry.  A set of criteria was also calculated for the
group of 27 plants  that  did  not   include  plant   12256.   This
procedure  was  employed so as not  to bias the results of the BCT
test for the whole industry.  Costs and removals calculated for  a
30 MGD plant are highly cost effective since this  flow  is  over
twice  that  of the reported total  flow from all the remaining 27
plants.

Initially,   two  sets  of  BCT  criteria  were  calculated.   The
calculation  of  one set of criteria assume that all  18 plants in
the  insufficient  data  group  will  incur  costs   and   achieve
pollutant  reduction  as  a  result of the BCT limitations.  The
calculations for the other set assume  only  24  percent  of  the
plants   or   35 percent of the flow  in this group will  incur costs
and  achieve   pollutant  reductions as  a  result   of  the   new
limitations.   These percentages reflect the segment  of plants who
                               257

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have submitted  data which  are  not  in  compliance  with  the proposed
BCT  limitations.  The  two sets  of  criteria  were calculated  to  be
$0.38/lb. and 0.87 and   $0.37/lb  and  0.86,   respectively.   EPA
considers the latter set of criteria,  $0.37/lb.  and 0.86  (the one
obtained usirig  the percentage  estimate for!costs and  removals)  as
the  more reliable indicator because  many of the 18 plants in the
insufficient data group are small   formulating  facilities   which
are not likely  to require  additional  treatment.

Thereafter,  four  additional  sets  of criteria were calculated.
One set of  criteria  was   calculated  for   the   28   plant   group
(including plant 12256)  and another set was  calculated for the  27
plant   group    (without   plant   12256).    These  two  sets   of
calculations assumed the aforementioned percent non-compliance.
The  results  for  each set were $0.37/lb. and 0.86 and $0.38 and
0.82,  respectively.    Finally,  two   sets    of   criteria   were
calculated  for  the  28  and  27 plant groups assuming 100% non-
compliance with proposed BCT.  These  results were $0.38/lb.  and
0.84  and  $0.40/lb.  and   0.83  for   the 28  and 27 plant groups,
respectively.

Based on the comparison of  these calculated  criteria  to  the  BCT
cost  test  benchmark   figures ($0.42/lb. and 1.43),  the proposed
BCT  limitations  meet   the requirements  of.   the    BCT    "cost
reasonableness test" regardless  of  which set  of  criteria are used
as the comparison criteria.  A subsequent analysis and discussion
of the test as applied  confirm this conclusion.
                                           j
As part of its confirmatory analysis  EPA presents the BPT and BCT
costs  and removals as  well  as the  criteria  results for 10 plants
who  have  submitted  data   which   indicate   that they  are  not
currently  achieving BCT level performance.   Table XI-2 lists the
identification numbers  of  these  plants  along  with the calculated
incremental  removals   achieved  by BPT and  to be achieved by BCT
and the estimated costs  of  these loading reductions.   Table  XI-3
lists  the  plant  identification   numbers,   their  manufacturing
subcategory classification(s), the  test criteria on   a plant   by
plant  basis and the overall results.   The 10 plants  in this test
group were specifically  chosen  further  analysis  because  they
submitted  data  which  could be  used  to calculate actual BCT cost
test criteria (estimations  had to be made in   a   few   cases)  and
their  data  indicated   that  they  were below the anticipated BCT
performance  requirements.    The   average    industry  criteria
calculated  for  this  plant  group are $0.36/lb and  0.81.  These
values confirm the overall  result for the industry.

The above analysis uses  existing BPT performance as   the  measure
of BPT removal.   Because not all plants are exactly at the levels
required  by  the  existing  BPT  regulation,  we also considered
whether the BCT cost test results would be  different  using  the
                                258

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existing  BPT  regulation, as opposed to actual performance data.
The existing BPT regulation requires that all direct  dischargers
achieve  a 90% reduction from BOD5_ levels and that subcategory B,
D and E plants comply with a maximum monthly average of  52  mg/1
for  TSS.   In  order  to  calculate  BCT cost criteria using the
existing BPT regulation (as opposed to existing BPT  performance)
as  a  base  point,  some  changes  had  to be made in the in the
identity of the plants in the test group.  Two plants (12098  and
12187) were dropped because raw waste BOD5_ data was not provided,
and  a  third  (12160)  was  dropped  because  a  90  percent BPT
reduction of its BOD5. raw waste concentration would bring it into
compliance with the BCT limitation.  Five  other  plants  (12132,
12161,  12294,  12307  and  12317)  were  added  because  90% BOD
reduction costs and concentrations can be estimated with the data
they submitted.

The calculation of BCT criteria  for  this  group  of  12  plants
involves significant difficulties.  In the first place, it is not
possible  to  establish  effluent  TSS  concentrations that exist
after a 90% reduction in raw  waste  BOD  and  therefore  average
values  must be used for plants that do not have a TSS limitation
(9 plants).  Consequently, the  BCT  criteria  derived  for  this
plant  group  will  be  based  to  a  large  extent on artificial
performance.  Secondly, the BPT TSS limitation in effect for some
plants  in  the  test  group  (3)  is  more  stringent  than  the
anticipated  amended  BPT and BCT limitations.  Attributing costs
and removals to meeting this soon-to-be deleted limitation is not
reasonable nor is  it necessarily consistent with  the  intent  of
the Clean Water Act concerning BCT.  Finally, this exercise would
require  that  the  costs  incurred by the 3 plants to meet their
existing BPT TSS limitation be separated from the costs  required
to  meet  BCT  BOD5. limits.  This is not feasible, however, since
the upgrading costs are developed based on average effluent  BOD5_
concentrations  and  not effluent TSS concentrations.  Biological
treatment systems  are designed to meet  a  target  BOD5.  effluent
level  and  if the system is operated properly roughly equivalent
effluent levels of TSS will result.  The data from plants already
meeting the anticipated BCT limits show this to be the case.

Nonetheless, BCT criteria for  this  12  plant  group  using  the
existing  BPT  regulation  as  a  base  point  were calculated by
assuming TSS average concentrations of 18 mg/1 and 178 mg/1   (the
non-regulated subcategory average), respectively, for plants with
and  without  a  TSS limitation.  No attempt was made to separate
the costs of BPT/TSS compliance from the BCT upgrade costs.   The
criteria  results,  $0.38/lb  and  0.49, should be interpreted in
light of the approximations used to obtain them.

Finally, since  we are  proposing  to  amend  the  existing  BPT
regulation,  we  considered whether those changes could alter the
                                259

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 results of the BCT cost test.   The planned amended BPT regulation
 will  be the same as the existing BPT regulation except  that  the
 current  mg/1   TSS  limitation  for B,  D and E subcategory plants
 will  be replaced by a limitation based  on  a  long  term  average
 concentration   of  75 mg/1  which will apply to all plants and all
 operations in  subcategories A  - E.

 The   calculation  of  the  test  criteria  iis  similar   to   the
 calculation just  described  except that  all  12  plants  were
 assigned a TSS concentration of 75  mg/1.    :The  criteria  results
 $0.54  and 0.76 are of questionable validity because the plant by
 plant removal  calculations  are based on contrived BPT performance
 for TSS.

 The results obtained from these exercises  support  the  Agency's
 conclusion  concerning  the BCT cost test for the pharmaceutical
 industry.   These results also   support   the  Agency's  contention
 that   the  procedure  used   to  calculate  the  BCT  criteria for
 comparison to  the  BCT  benchmark  figures  represents  the  most
 effective use  of the data available.        ;

 4.    Technology Basis for BCT

 The   treatment,  technologies   employed   by  the   industry    were
 evaluated  to   determine the   pattern   for  technology addition.
 Primary  clarification,  neutralization  and  equalization may  be
 followed   by   secondary  biological   treatments such  as activated
 sludge, aerated lagoons  or  trickling   filters  and   finally  by
 tertiary   treatment  such as polishing ponds.   After consideration
 of these   various   technologies,  the  Agency   decided  that   the
 technology  basis  for  the BCT limitations  wi;il  be add-on activated
 sludge.   Activated   sludge  is  both  commonly  used and effective,
 and any requirement   to  achieve improved  effluent   quality  as
measured  by the conventional pollutant  parameters  BOD  and TSS may
 be  accommodated  by   either   increasing  the capacity  of existing
activated sludge  units  or by adding new units.   The adoption  of
add-on    activated    sludge  technology  as  the  basis  for   BCT
 limitations does not,   of  course,  preclude   the   use  of  other
technologies to achieve  the requisite effluent  quality.

Effluent    limitations   based   on   the  performance of  these
technologies  may  be   either  on  a  percentage   basis   or   a
concentration   basis.    The  reasoning   behind  the   use  of  a
concentration basis for  effluent limits is as follows:

     a.   Markedly higher loadings  do  not  inherently  indicate
          proportionately  more  difficult  treatment.   In fact,
          removal of a pound of BOD equivalent,  for  example,   is
          generally  much easier at higher concentrations than at
          lower concentrations.
                               260

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     b.    A greater removal of pounds  of  pollutant  per  dollar
          expended  will  generally  be  accomplished  by further
          treatment of higher concentration streams, an  approach
          not  encouraged  by  percent  removal  limitations  but
          consistent with concentration limits.

     c.    Other industry regulations are based  on  concentration
          limits  and  implementation  of the regulation would be
          facilitated by this approach.
     d.   Dilution in order to meet concentration limits  can
          avoided by permit recognition of applicable flows.
be
EPA also considered two other technology options as the basis for
BCT.   Option  (2)  for advanced biological treatment entails the
addition of specific design units  (activated  sludge,  RBC's  or
polishing   ponds)  to  existing  biological  treatment  systems.
Biological systems employing these additional units  can  achieve
long term effluent performance levels of 20 mg/1 BOD5. and 30 mg/1
TSS  with appropriate treatment system design and operation.  The
other option considered (3)  was  advanced  biological  treatment
that  could  produce long term average effluent concentrations of
28  mg/1  BOD5.  and  36  mg/1  TSS.   Similarly,  this  treatment
performance  can  be achieved by the addition of activated sludge
digestors, rotating biological contactor units or polishing ponds
to existing biological systems.  Option 3 is a lower cost  option
than option 2 because of its less stringent design requirements.

Both  options  were evaluated using the BCT "cost reasonableness"
test as required by the Clean Water Act in the same manner as the
selected  option  was  evaluated.   The  results  for  the   POTW
benchmark criterion were $.54/lb. and $.53/lb., respectively, for
options 2 and 3.  These values are both greater than the $.42/lb.
benchmark criterion stipulated for the first part of the test and
therefore  the  Agency  has rejected these options for BCT on the
basis of the "cost reasonableness"  statutory  requirement.   The
failure of these options to pass the cost test is due to the fact
that  a  significant  number  of  plants  are  achieving effluent
quality in terms of BOD5. and TSS that is close to  that  required
by  these  options and further upgrading would be relatively cost
ineffective for these plants.

5.   Regulated Pollutants

Conventional pollutants to be regulated by BCT are BOD5., TSS  and
pH.  These pollutants were also regulated under the  1976 BPT.   No
other  conventional  pollutants were found to present significant
problems  in the wastewaters of the   industry.   A  more  detailed
review of the selection of pollutant parameters for  regulation  is
presented  in Section VI.
                                261

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 *>•   Profile of Industry Facilities

 An in-depth profile of the Pharmaceutical Industry is provided in
 Section  III  of  this  document.   In  this  section  the  major
 manufacturing  operations  are  evaluated  in terms of wastewater
 generating characteristics and priority pollutant  usage.   While
 there   is   significant   operational   diversity   within  each
 manufacturing subcategory and from one subcategory to  the  next,
 and  while  the raw waste loads .generated may differ with respect
 to the composition and concentration  of  pollutants,  the  waste
 load   generated   by   pharmaceutical   plants  are  nonetheless
 consistently amenable to treatment by biological  systems.   This
 is  evidenced  by  the  large  number  of mixed subcategory which
 employ one biological system  to  treat  wastes  from  all  their
 manufacturing  operations.    Moreover,   the methods of treatment
 employed by single subcategory plants do not vary  markedly  from
 subcategory  to  subcategory.    The  308 and long term daily data
 submitted provide adequate  justification for proposing one set of
 limitations for all plants  covered by this!study.

 7.    Engineering Aspects of_ BCT

 A  technical  review  and evaluation  of  treatment  technologies
 employed  in the industry,  presented in Section VII indicates use
 of  a variety of treatment technologies,  both in-plant and end-of-
 pipe.   Filtration of mycelia from fermentation wastewater  offers
 an   opportunity  for  a  major  reduction in nutrient BOD loading
 before combination with  other  wastewaters   and  also,   in  some
 cases,  a recoverable by-product.

 Since   the  manufacturing operations entail the handling of mostly
 organic materials,   waste  loads  which   are  decidedly   acid  or
 alkaline    are   usually   not    encountered.     However,    some
 neutralization  of  equalized influent before   secondary treatment
 is  often   necessary.    The secondary  biotreatment  systems  used
 include activated  sludge, aerated  lagoons, and trickling  filters,
 with clarification or  filtration following.

 8.   Variability

 The variability of  wastewater  effluent   in   the  industry  is  a
 result   of  variations  in three  general  factors.   The  first is  in
 raw  waste  loads   and   concentrations,  resulting  from  process
 variation and from phasing  of  batch  and  campaign production.  The
 second   is  in  wastewater  flow,   resulting   from  variations  in
production  rate  and  operating  techniques.   The  third   is   in
 treatment   efficiency  which   is   affected  by   seasonal  ambient
 conditions  and operating variations.
                               262

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EPA  conducted  statistical  analyses   of   long-term   effluent
monitoring  data  to  determine BAT, BCT, and NSPS limitations in
the form of daily maximum effluent limitations and 30-day average
maximum   effluent   limitations   for   traditional   pollutants
(conventional  pollutants  TSS  and  BOD5_ and the nonconventional
pollutant, COD) and the toxic pollutant, cyanide.   In  addition,
allowable mass-based variability factors were also determined.

The  specific  methodologies for calculation of these variability
factors are discussed in Chapter  IX.   Variability  factors  are
calculated  for  each pollutant in terms of both daily and 30-day
average levels.

As mentioned above, the 1976 "Development  Document"  established
five  manufacturing  subcategories of pharmaceutical products and
activities for regulatory purposes A through E.  The  statistical
analyses  presented  are herein for the set of all pharmaceutical
plants.   As  stated  earlier,   plants   operating   solely   in
subcategory  E   (Research)  were  not  studied  as  part  of  the
investigation.  The contribution of research  activities  to  the
effluent  of  plants also engaged in activities in the first four
subcategories was deemed to be negligible.

9.   Cost in Relation to Benefits

The cost of BCT  implementation is considered to be the cumulative
implementation costs for those plants not already meeting the new
limits   (including  estimated  costs  for  plants  that  supplied
insufficient  data) at  the time.of  the data surveys.  These costs
(investment and  operating) were developed on a conservative basis
for treatment module units wherever reported performance did  not
meet average  long term  performance  of 55 mg/1 for BOD and 51 mg/1
for  TSS.   Estimates   based  on the average costs for plants not
meeting  the new  limitations were projected for plants  submitting
insufficient   data,  assuming  that  the rate of  compliance  (76-6)
found  for the  plants who submitted  complete data  applies to these
plants.   The  total  annual  and  investment  costs  may  amount   to
$7.72    million   and  $19.4  million,   respectively,  for  direct
dischargers.     Actual   expenditures    are   expected   to     be
substantially    less  due  to  site specific  opportunities  for
improvement of wastewater  treatment operations.

BOD discharge  by industry  direct dischargers will  be reduced  by
an estimated   4,727,000   Ib.  per   year  and TSS discharge by  an
estimated 1,756,000 Ib. per  year.   These   discharge   reductions
were   calculated  on   a long  term  average  concentration  basis and
 include   an   estimated   contribution  from   plants    from    whom
 insufficient   data was  received.   These   discharge   reductions
reflect  reductions achievable  from actual  performance   levels  as
reported in  the  308 and long  term  data  surveys.
                                263

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 10.   Nonwater Quality Environmental  Impact

 The  four  general  categories  for  RCRA  wastes  generated  by  the
 pharmaceutical  industry   are sludges,  waste solvents,  infectious
 wastes, and  returned and  rejected goods.  !  Only   one  of   these,
 sludges,   is   expected   to   be    significantly  increased   by
 technologies expected to  be  employed under BCT.

 Sludge from  biological  treatment can mostly  be   land-filled,   as
 would   separable  solid   process waste   'such  as  mycelia from
 fermentation.

 Implementation of BCT level  technology  is  not expected  to   affect
 air  emissions significantly.               :

 The  energy  consumption and  cost effect of BCT implementation  are
 slight.   Increases   in   energy   needs  are  largely  limited   to
 additional power  requirements  for pumps, agitators,  etc.,  and  are
 not  generally a large requirement.  Costs of incremental  energy
 needs are included  in the  cost studies.    ;

 1! •  Guidance  to  Enforcement Personnel     i

The regulatory limits set  forth  earlier  >in  this  section   are
expressed  in  terms  of concentration.  In  stating permit  limits,
 it is anticipated limits will be  set based  both on  concentration
and  on  loading,  e.g., pounds per day.   The conversion requires
consideration of  flow and unit conversion  according to:


     Maximum Loading  (Ib/day) = Maximum Day Concentration  (mg/1)
                              X Maximum Applicable Flow  (MGD)
                              X 8.34  Ib x;liters
                                        mg|x MG
                               264

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                           TABLE  XI-2

        Incremental BPT and BCT Annual  Costs  and Removals
Plant t

12022

12026

12038

12098

12160

12187

12236

12239

12462

20257
BPT Cost ($)

 6,400,000

 1,400,000

 4,500,000

   200,000

   400,000

 5,200,000

 4,400,000

   150,000

  1,500,000

   300,000
 24,450,000
BPT Removal (Ibs)

    9,954,000

    1,641,000

   22,881,000

       52,000

      113,000

   17,721,000

    2,176,000

         6,000

      698,000

       22,000
   55,264,000
BCT Cost ($)

  1,044,000

    275,000

  1,243,000

    156,000

    203,000

  1,539,000

    715,000

     89,000

    387,000

    171,000
                                               5,822,000
BCT Removal (Ibs

    581,000

    455,000

  5,407,000

     39,000

     54,000

  6,747,000

    845,000

       7,000

  1,080,000

     22,000
  16,237,000
                                265

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 Plant
                            TABLE XI-3

                      BCT Cost  Test  Criteria
12022
12026
12038
12098
12160
12187
12236
12239
12462
20257
AC
C
ABCD
D
D
C
C
C
A
C
Subcateqorv(s)
BCT Cost ($/lb)


    0.66

    0.60
           i
    0.23

    3,98

    3.73

    0.23

    0.85

   12.84

    0.36

    7.93
                           Overall Ave. = 0.36*

Calculated from totals in Table XI-2.
                                         BCT/BPT Ratio


                                              1.03

                                              0.71

                                              1.17

                                              1 .04

                                              1.06

                                              0.78

                                              0.42

                                              0.47

                                              0. 17

                                              0.54
                                     Overall  Ave.  0.81*
                               266

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                           SECTION XII

        Best Available Technology Economically achievable
A.   Summary
1 .
GENERAL
As a result of the Clean Water Act of 1977,  the  achievement  of
BAT  has  become  the  principal  national  means  of controlling
wastewater  discharges  of   toxic   pollutants.    The   factors
considered   in   establishing   the  best  available  technology
economically achievable (BAT) level of control  include the  costs
of  applying the-control technology, the age of process equipment
and  facilities,  the  process  employed,  process  changes,  the
engineering   aspects   of  applying  various   types  of  control.
techniques, and non-water  quality  environmental  considerations
such  as  energy  consumption,  solid  waste, generation, and air
pollution (Section 304(b)(2)(B)).  In general,  the BAT technology
level represents, at a minimum, the best economically  achievable
performance  of plants of shared characteristics.  Where existing
performance  is  uniformly   inadequate,  BAT  technology  may  be
transferred  from a different subcategory  or industrial category.
BAT may include process changes or internal controls,  even  when
hot common industry practice.

The  statutory  assessment of BAT  "considers" costs, but does not
require a balancing of costs against effluent reduction  benefits
(see  Weyerhaeuser  v.  Costle, ;11  SRC   2149  (D.C. Cir.  1978)).
However, in assessing the proposed BAT, EPA has given substantial
weight to the reasonableness of costs.  The Agency has considered
the volume and  the nature of discharges,  the volume and nature of
discharges  expected  after  application   of  BAT,  the    general
environmental   effects  of   the  pollutants,  and the  costs and
economic   impacts  of  the   required  pollution  control   levels.
Despite    this   expanded  consideration   of  costs,  the   primary
determinant  of BAT   is  effluent  reduction   capability    using
economically achievable  technology.

2.   Limitations

BAT  limitations are  summarized  in Table  X-l  below.
           Pollutant
                           Table X-l
                        BAT LIMITATIONS

                           30-Day
                       Average Maximum
                                                  Daily
                                                Maximum
                                267

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           COD (mg/1)           570              1024
           Cyanide (mg/1)     0.375              .643
 B.    Identification of BAT
                                            [

 1.    Prior Regulations

 The  Agency  has  not  previously  proposed  or  promulgated  BAT
 effluent    limitation    guidelines   for   the   pharmaceutical
 manufacturing industry.  Suggested limitations were published  in
 the 1976 Development Document for information purposes.

 2.    Regulated Pollutants
                                            I

 The only priority pollutant sufficiently evident in the   industry
 and  requiring  BAT  limitation was cyanide.   The nonconventional
 pollutant COD will also be regulated.       !

 3.    Methodology Used                      j

 The  first  part  of  EPA's  priority   pollutant  study   of   the
 pharmaceutical   industry  involved a  review  of  the   priority
 pollutant information provided in  the  308  portfolio  responses
 concerning  the  manufacturing  use and  wastewater discharge of
 priority pollutants.   This information was evaluated to  determine
 what priority pollutants were commonly discharged as a result  of
 pharmaceutical    manufacturing   operations.     Those   priority
 pollutants known to be present in wastewater  as  a result of  non-
 pharmaceutical    manufacturing   operations    (e.g.,    pesticide
 manufacturing)  or which were  present in only  one instance  (as  a
 result   of  unique  site-specific  operations)   were  rejected as
 candidates for regulation at   that point.    After  developing  a
 group of commonly discharged priority pollutants (cyanide,  toxic
 solvents,  metals,  and phenols),  the Agency then  selected as group
 of plants for sampling in the S/Y program,  j The  purposes of  this
 program    were  to  determine  the levels j.p.f   these  pollutants
 discharged and the degree to  which the raw waste levels  of   these
 pollutants were reduced by treatment in-place.

 EPA  found 34  toxic pollutants  in  the wastewater  of pharmaceutical
 plants  who were  in the S/V program.   33 of] these pollutants  have
 been  excluded   from   direct   discharger    regulations    by   the
provisions  of  paragraph   8   of   the  Consent Decree.  A detailed
discussion  of   the  rationale  for  these  exclusions   and   the
exclusions  of   the  pollutants   not   found\ in the S/V program  is
 contained  in  Section  VI  of  this document.   !The   remaining  toxic
pollutant,  cyanide, was  found  at  levels and;frequencies  requiring
regulatory  control  (see  Section X).
                                268

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A.   Cyanide

Where toxics are present  at  levels  and  frequencies  requiring
regulation   but  insufficient technological justification exists
fo? levels more stringent than BPT, BAT levels should be  set  at
BPT  levels  for  such  toxics.   In regard to the BAT control of
cyanide in the pharmaceutical industry, EPA  has  concluded  that
further  reduction  of  cyanide  from  the BPT level has not been
adequately demonstrated by technologies for cyanide  destruction.
Therefore,  the  Agency  is  proposing BAT limitations to control
cyanide which are equal to the BPT limitations.
B.
COD
 In  addition  to  controlling   toxic  pollutants,  BAT   may    be
 appropriate   for   the   control  of  nonconventional   P°Jl"tant
 pSamlters.  One such parameter, COD   has   been^  fj«n*  «J   high
 concentrations   in   the   raw  waste   of  direct  discharging
 pharmaceutical plants.   This pollutant parameter  is a measure  of
 the    non-biodegradable   or   slowly  biodegradable  organic*  in
 wastewater.  The discharge  of  COD  is  currently being   controlled
 by percent reduction  limitation of the existing BPT regulation.

 In its analysis of  the  13 plant BCT data set discussed  in  Section
 IX     the   Agency  was  able   to  derive  a  long term  average
 concentration of COD  based  on  data submitted from 12  of  the  13
 nlants  This average performance  together  with the daily  and 30-
 day   average  variability   factors  (see  Section IX for  methods of
 calculation) were  combined  to  provide COD daily maximum  and  30-
 day    maximum   average   limitations.     This   performance   is
 characteristic  of  what  is  achievable  by  BCT biotreatment  systems
 in   regard   to  the control  of  COD.   These systems are also judged
 to be the  "best available  and  economically achievable.

 4.    Technology Basis for  BAT

 The   technology  basis   for  BAT  is  a  combination   of  cyanide
 destruction  (part  of   the  technology basis for BPT  and add-on
 activated sludge  (the technology basis for the BCT  limitations).
 Shile  Sost  Plants  will   be able to meet the COD limitations by
 proper operation  of adequately designed and  operated  biological
 treatment  to  which  any  required activated sludge capacity has
 been added,  some plants because of their  heavy  use  of  certain
 refractory  organic  materials  (e.g., solvents and some synthetic
 Starting materials) may be  required  to  carefully  control  the
 amounts  of these substances that enter their wastewater  in order
 to meet these limitations.  In  some instances  this  may  require
 appropriate  stream  segregation  and  treatment  or  disposal or
 changes in process operations.
                                269

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 EPA also considered other technology options  for  the   control  of
 COD.   Specifically,  EPA  considered  the  two advanced biological
 treatment options that were also  considered for BCT  (See  Section
 XI).  These options were rejected for  BAT  control of COD after an
 evaluation  of  the available treatment  in terms  of the processes
 which generate COD in the pharmaceutical industry indicated  that
 these  technology  options would  require a level  of COD reduction
 which is not achievable generally achievable  by   existing  direct
 dischargers.

 5.   Costs and BMP Considerations
                                            i
 Cost considerations relating to COD  limitations  are  intimately
 involved with the costs for BOD5  and TSS removal addressed by the
 BCT  cost  analysis,   as  the  same technology which achieves BCT
 limits will achieve the COD limits under BAT.    A  discussion  of
 the  BCT  costs may be found in Section XI(.  Therefore, there are
 no incremental costs for COD control  attributable  to  BAT.    In
 addition,    no  costs  are  expected  as  aresult  of  the  BAT
 limitations on cyanide discharge since any;costs to  be  incurred
 are attributable to the BPT regulation.    i

 No  BMPs (Best Management Practices) beyond those required by the
 existing BPT regulation are proposed in this rulemaking.

 6.    Guidance to Enforcement  Personnel

 Although cyanide is  the only  priority pollutant to be limited  by
 this   regulation,   enforcement personnel  are urged to limit other
 priority pollutants at  specific  plants  where they are  identified
 as  discharged  in  treatable  quantities.   Permit writers should
 study  the  product/process  mix   employed  by   each   facility  to
 determine    whether   toxic   pollutants  may   be  discharged  in
 manufacturing   operations.   The  priority   pollutants  used    in
 various  pharmaceutical manufacturing operations  are  presented  in
 the PEDCo reports   (41,   42,  43).   Raw  materials   and  process
 materials  are   the two key areas  of priority  pollutant usage.  A
 good understanding of these areas  as they  ! pertain   to a  given
 facility  is  necessary  before  any decision can be  made about
 imposing additional controls on  toxic pollutants   not   controlled
 by BAT.                                     I	
                                            i          •;      •
 Referring  to  screening  and verification  ;data will also provide
 the permiters with information on  priority  !pollutant levels in  a
plant's  discharge.  Careful note  should  be made of both influent
 and effluent  concentrations  of   toxic   compounds  so  that  the
process   and   non-process  dilution   effects  can  properly  be'
accounted for.                              i
                               270

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Although the most efficient  removals  of  toxic  pollutants  are
performed   at   the   in-plaht   treatment   level,  end-of-pipe
technologies are effective in  removing  substantial  amounts  of
priority  pollutants as well.  In-plant treatment for the removal
of toxic metals  and  solvents  (metal  precipitation  and  steam
stripping)  has  been  found to be very effective when applied to
streams containing high concentrations of these  pollutants  (see
Section VII).  The performance capabilities of these technologies
should be carefully considered when site-specific limitations are
to be imposed.

A  review  of  permit  limits  may  be required if changes in the
materials or processes occur.   Such  changes  may  require  that
limitations  on  toxics discharge be eased or made more stringent
or completely eliminated.  In some cases, new limitations may  be
necessary.   Any  changes  in  operations  reported by the permit
holder should alert the permit writer to the possibility  of  new
limitations.
                                271

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                           SECTION XIII    !

                 NEW SOURCE PERFORMANCE STANDARDS
 A.   Summary

 1.   General

 The basis for  new  source  performance  standards  (NSPS)  under
 Section  306  of  the  Act  is  the  best ; available demonstrated
 technology.   At new plants,  the opportunity exists to design  the
 best  and  most  efficient  production  processes  and wastewater
 treatment  facilities.    Therefore,  Congress  directed  EPA   to
 consider   the   best   demonstrated  process  changes,  in-plant
 controls,  and  end-of-pipe  treatment  technologies  that  reduce
 pollution to the maximum extent feasible.

 2.    Limitations
 NSPS limitations are summarized in Table XII-1,  below:
                         Table XIII-1
 NEW SOURCE  PERFORMANCE STANDARDS
Pollutant
Range
30-Day Average Max
                                                   Daily  Maximum
BOD5_ (mg/1)
COD  (mg/1)
TSS  (mg/1)
Cyanide  (mg/1)
EH	6.0
  - 9.0
               51
              449
               72
                0.375
                             126
                             853
                             195
                               0.643
B.   Identification of NSPS                :

     1.   Methodology Used
                                           i
          a.   BODS, COD and TSS

NSPS for BOD, COD and TSS were derived froip the data  of  a  more
select  group  of  plants  than that group.whose data was used to
develop BCT and BAT limitations.   This  more  select  group  was
established  by deleting data from three plants.  The performance
of  these  plants  (12022,  12026  and  12236)   was   considered
significantly  inferior to that of the other 10 plants in the BCT
(BAT) group from the standpoint of both  removal .efficiency  and
final  effluent  concentration (see discussion in Section IX) and
therefore inappropriate in light of  the  statutory  requirements
                                272

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for  NSPS.  The effluent data points
were used to develop a  long  term
parameter.   30-day average maximum
factors for each pollutant parameter
from  these  10 plants as described
multiplied by the long term average
pollutant  parameters  equal the 30
maximum limitations.

          b.   Cyanide
 from the remaining 10 plants
average  for  each  pollutant
and daily maximum variability
 were derived from  the  data
in Section IX.  These factors
 values  for  the  individual
day maximum average and daily
The cyanide NSPS are identical to those derived for the BPT,  BAT
and  PSES  regulations.   Data is not yet available to the Agency
which indicates that more stringent  levels of cyanide control can
be achieved by new sources.

2.   Regulated Pollutants

Pollutants regulated for NSPS are those also regulated under  BPT
guidelines.   These  are the conventionals BOD5_,  TSS, and pH, the
nonconventional pollutant COD, and the toxic  pollutant  cyanide.
A  more  detailed review of the  selection of pollutant parameters
for regulation is presented in Section VI.

3.   Engineering Aspects

End-of-pipe treatment  systems can be designed to  attain the   long
term  average  concentrations for BOD, COD and  TSS which form the
bases of NSPS for these pollutant parameters.   Several plants .in
the  long  term  and 308 data bases  have provided data along  with
descriptions of their  end-of-pipe systems that  demonstrate   that
these  standards  are  achievable.   Biological treatment systems
which have capacities  that  allow   for   sufficient  aeration  and
retention time and which employ  equalization  of waste loads prior
to  biotreatment  are  quite  capable of producing effluent which
meets these standards.  The  fact   that  different   wastes   from
various  manufacturing  operations   may  have different K  factors
 (biodigradability  constants)  associated  with  them  has  been  and
can  be  accounted  for  by on-site treatment  system design  and  does
not necessitate  separate standards  for  different  subcategories  of
plants.

EPA also considered  two  other technology options  as the basis for
NSPS.   One  option  was  identical  to  the  technology  option  chosen
 for  BAT  (namely   enhanced  biological   treatment  and  in-plant
 cyanide control).   After a review of the technology available  to
 treat   wastewater   from   pharmaceutical  manufacturing operations,
 the  Agency  concluded  that  this    option   did   not   provide
 sufficiantly   stringent   control of traditional pollutants (BOD5,
 COD   and  TSS)   in  terms   of  the  demonstrated  performance  of
                                273

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 available treatment systems in the industry and new sources could
 achieve  a more stringent levels of control with proper treatment
 system design.   The second option considered (also considered for
 BAT)  involved specified design treatment levels (20 mg/1 BOD5_, 30
 mg/1  TSS and 270 mg/1  COD)  for  enhanced  biological  treatment.
 After review of the best demonstrated available technology in the
 industry,   the  Agency  concluded that this technology option was
 insufficiently  demonstrated  in  the  industry  to  warrant  its
 selection.
                                            !

 In  addition to being able to design better performing end-of-pipe
 treatment   systems,  new  sources  may  also design manufacturing
 operations  and install appropriate in-plant controls  in  such  a
 way  as to  limit the amount of waste that must  be treated end-of-
 pipe.   Provision may also be made for the recycle  and  reuse  of
 water,   solvent recovery  and  reuse  and  other  resource  and
 materials   conserving   practices  by   incorporation   of   these
 functions   into the  design of the plant.   The ability to practice
 resource recovery and  reuse is not always available  to  existing
 sources because of on-site structural limitations.

 EPA  considered  the  feasibility  of  attaining  the  new source
 performance standards  at  new sites from  the standpoint  of  the
 technology   basis  (i.e.,   enhanced  biological   treatment).   The
 Agency  concluded that  these  standards   wiauld   not  impose  any
 unachievable technological   requirements  on new sources beyond
 those already met by existing sources.  We j also 'considered  the
 effect   of   the  NSPS  technological  basis ohexistingsources who
 might expand on-site pharmaceutical  operations or  start new ones.
 The Agency  concluded that  the new source  standards  applicable  to
 these   new pharmaceutical  operations  at existing sites would^also
 not impose  technological   requirements  that are   not  currently
 being satisfied by existing  source direct dischargers.

 4.   Total Capital and Annual  Costs  and  Incremental   Pollutant
Reduction

The  total   capital  and   annual   costs   of  new  source  wastewater
treatment    technology   for   an   average   mixed    subcategory
pharmaceutical  source  are estimated to  be  $3.9 million  and  $1.5
million, respectively.   These  costs for an average new  source  are
estimated to be 38 percent greater  than the  costs  incurred  by  the
average existing source in meeting  BCT/BAT,   Average  pollutant
reductions  for  BOD5_,   TSS  and COD by an new source will  be  18%
greater than that achieved by an existing source.
                               27k

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                           SECTION XIV

       PRETREATMENT STANDARDS FOR NEW AND EXISTING SOURCES
A.   Summary

1.   General

Section 307(b) of the Act requires EPA to promulgate pretreatment
standards for existing sources (PSES) that must be achieved by  a
data  specified  by  EPA which is not later than three years from
promulgation.  PSES are designed to prevent  the  discharge  from
presently  operating  facilities of pollutants that pass through,
interfere with, or are otherwise incompatible with the  operation
of POTWs.

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  control  measures, and end-of-pipe treatment and to use
plant  site  selection  to  ensure  adequate   treatment   system
installation.   PSNS  are  designed to prevent the discharge from
new facilities of pollutants that pass-through,  interfere  with,
or are otherwise incompatible with the operation of POTWs.

The  Clean Water Act of 1977 states that pretreatment is required
for pollutants, such as heavy metals, that pass through POTWs  in
amounts that would violate direct discharger effluent limitations
or  limit  POTWs1  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,  analogous  to   the   best   available
technology   for   removal  of  toxic  pollutants.   The  general
pretreatment regulations  (40 CFR Part 403)  which  serve  as  the
framework  for  these  proposed  pretreatment  regulations can be
found  in 40 FR 27736  (June 26, 1978).
 2.
Standards
 Standards  controlling  cyanide discharge  will  be  proposed.    These
 standards   are   shown   below in  table  XIV-1 and  are  identical  for
 existing and  new sources.
                                  Table  XIV-1
 PRETREATMENT  STANDARDS FOR  NEW AND EXISTING SOURCES
 Pollutant
          30 Day Maximum Average
Daily Maximum
                                275

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 Cyanide (mg/1)
0.375
0.643
 Additional standards for total volatile or>ganics (TTVO) are being
 considered and are also discussed below.

 B.   Identification of_ Pretreatment Standards

      1..   Methodology Used

           a.    Cyanide

 308 submissions indicate that 31  of the 278 indirect  dischargers
 use   cyanide   in  their  manufacturing  operations  (batch  and
 continuous).    S/V  data  indicate  that  pharmaceutical   plants
 wastewater may contain high concentrations of cyanide as a result
 of  process  operations.    High  concentrations  of  cyanide will
 interfere with the  operation  of  biological  treatment  systems
 which are  utilized  by  POTWs  and  various  ranges  of cyanide
 concentrations have been shown  to  pass  through  the  treatment
 systems   of  municipal  plants  (117).    High  concentrations  of
 cyanide  in the POTW  sludge  will  also  limit  the  alternatives
 available  for  its  management.   Consequently,  PSES and PSNS for
 the control of cyanide discharge   are  deemed  appropriate.    The
 cyanide   destruction technology and data which form the basis for
 BPT and BAT cyanide limitations may also be used to prevent  pass-
 through,  etc.  by indirect sources and therefore  is   used  as  the
 basis for PSES and PSNS.                   I

           b-    TTVO (Total  Toxic  Volatile organics)

 Although  a Paragraph   8   exclusion  of  direct   discharges   from
 limitations  controlling  the  discharge  of toxic  volatile organics
 has been  recommended for  BAT. and  NSPS,   such   an exclusion   from
 regulation   is   not   appropriate  for  indirect   dischargers.
 Information from the  308   data  base  shows   that   155   indirect
 discharging plants  use  priority   pollutant  solvents   in  their
 manufacturing   operation.   An  extropolation  of   the  S/V   flow
 weighted   mean  TTVO  raw waste concentration  (232 mg/1)  to  these
 plants results in  a TTVO  loading  of  19.5  million pounds  per  year.
 This  loading  is significant in  that  only  12 plants have  indicated
 having  treatment    in-place    which    can   reduce    raw    waste
 concentrations  of   these  pollutants,  e.g.,  steam  stripping  and
 aerated equalization.

Generally,  POTWs   with  secondary   treatment  do  reduce    their
 influent concentration of volatile organics to some  extent.  Data
from the 40 plant POTW study  (133)  indicate that POTWs may remove
68.5%  (mass   based)  of  the   raw  waste  TTVO  found in the  S/V
program.   However,  the biological  treatment  systems  of  direct
                               276

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discharaers  in  the  S/V program were able to achieve an overall
mals baled average removal rate of 96.1% for a very  similar  mix
of  solvents'    It  was also found that the POTW removal rates of
Tndividual commonly found toxic solvents were less in most  cases
than the direct discharger removal rates of the same solvents.  A
comparison  of  these  removal  rates  along  with the percent by
weight of the various solvents found in the S/V sampling  program
is presented in Table XIV-2.

The  Aaencv's  interpretation  of  the  pass-through provision of
30?(bt If the Act asLmes that pass through at POTWs occurs as  a
result  of a pollutant discharge from an industrial category  when
t-h! nercent removal  of  that  pollutant  achieved   by  the  BAT
trSatSSt  sSstSS  is  greater than that achieved by POTWs.  The
available data viewed in light  of  this  interpretation  suggest
that  prltreaLen?  standards  controlling the Discharge of toxic
solvent pollutants may be required to  prevent  pass  through of
these substances at POTWs.

The  recommended  technology  for  reducing   the  concentration of
volatile  organics  in  wastewater   is  steam  stripping.    The
performance   capability  of  steam  stripping technology has  been
discussed  in  Section VII of this  document.    The employment of
this  technology  on  a selected  In-plant basis would drastically
reduce  the  current discharge  of  toxic  solvents- from  indirect
discharges    Although a few plants  (6) have indicated that  they
hive stSm  strippers  in-place, data  has not  been   made   available
which   SSSld   allow   derivation  of standards for  TTVO.   When  such
performance data  is received  a decision on  how the  discharge  of
toxic   solvents   by  indirect  dischargers  can be regulated  will  be
made     Therefore,    pretreatment   standards   controlling   the
discharge of  TTVO are not specified  in this rulemaking.  However,
 If  Suring  this  rulemakingwe  obtain appropriate data concerning
 the performance  of  steam-stripping  to derive standards,  we  will
 include a TTVO standard in the  final regulation.

      c.   Other  Toxics

 EPA also considered the effect that other toxic pollutants, which
 were found in significant concentrations  in  the  wastewater  of
 pharmaceutical plants,  would have on the operation of POTWs.   One
 group   of   pollutants,   phenol  and  the  various  phenol  type
 pollStants, is adequately biodegraded by the biological treatment
 lystems of direct dischargers and the evidence available from the
 40-plant POTW study (117) indicates that  the .con?entrations  of
 these  pollutants  as  discharged by pharmaceutical plants can be
 adequately reduced by the secondary  treatment  works  of  POTWS.
 The   concentrations  of  toxic  metals  discharged  by  Direct
 discharaina pharmaceutical plants are low enough  that  no   pass
 through  or  interference  problems result from  this discharge at
                                 277

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 POTWs.  Therefore, no  pretreatment  standards  are  required  to
 control  the discharge of toxic metals, phenol and phenol related
 pollutants from pharmaceutical plants.

      1.   Regulated Pollutants

 Only cyanide will be controlled by pretreatment standards in this
 rulemaking.   These standards will apply to end-of-pipe discharges
 and will limit total cyanide (complexed and free).
                                            1
      2.   Engineering Aspects              ;

 Cyanide can  be controlled on an in-plant  basis  by  the  cyanide
 destruction   systems  discussed  in Section VII.   Process streams
 containing high cyanide concentrations can be selectively treated
 for cyanide  and the effluent from cyanide destruction can then be
 combined with other wastewater streams.
                                            i
      4.    Variability

 The cyanide   effluent  standards   to  be  proposed  for  indirect
 dischargers    are   30-day  maximum  average  and   daily  maximum
 standards.   These standards  are identical   to  the  BPT  and  BAT
 limitations   as  well  as the new  source  standards  (NSPS)  for
 cyanide and  account for variations in raw  waste loads and flows.

 5.    Cost  and Nonwater  Quality Aspects

 The  annual and  investment  costs   to  indirect dischargers  for
 meeting    the   cyanide  standards  are  $880,000   and   $323,000,
 respectively.   Increases  in  energy  use  as  a  result   of   these
 standards  are expected  to be very  small  and no  increase in wastes
 to be disposed  of  under RCRA is anticipated.

 *>•   Guidance to Enforcement Personnel      \
                         -••              ' •  [*:" :., .:,•'.' .,  •  .  ,
Enforcement personnel are referred  to Sections  VI,  IX and X and
an  earlier   part   of this section  for information  concerning the
development of  these standards.                  :  ;
                               278

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                           TABLE XIV-2

:OMPARISON OF POTW AND DIRECT DISCHARGER REMOVAL RATES FOR SOLVENTS


                 % by Wat. in Raw Waste                        Direct Discha
                                         POTW Removal Rate, %  Removal Rate,
•roxic ooiveiii. wj. 	
Btethylene
• chloride
ll , 1 , 1-trichloro-
• ethane
•Toluene
Ichlorobenzene
Ichloroform
Ifithylbenzene
ll ,2-Dichloro-
1 ethane
Isenzene
•Methyl
• chloride
Bothers
»J/ T tA Gill h»0
59.3
23.0
8.9
4.2
1.8
1.2
0.9
0.3
0.3
0.1
58
87
90
67
61
84
91
71
92
-
92
**
98
100
94
85
95
69
100
-
|*Other  solvents found at least once include  tetrachloroethylene,
Jui-dichloroethane,   1,1-dichloroethylene,   carbon tetrachloride,
 trichloroethylene,    chloroethane,     1,2-trans-dichloroethylene,
ll,1,2-trichloroethane and bromoform.
J       '•    •     ' ~ . •    •'.''.-".',•'.
 **Influent  concentrations  are  to  low to make accurate removal
 rate estimates.
                                279

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 1.



 2.


 3.
 5.


 6.


 7.


 8.


 9.


 10.


 11.


 12.



13.



14.
                           SECTION XV

                           REFERENCES
 Anderson, Dewey R., et al,  "Pharmaceutical  Wastewater:
 Characteristics and Treatment,"  Industrial  Wastes. March/
 April 1971, pp. 2-6.             	

 APHA Project Staff, Factbook  '76, Prescription Drug  Industry
 Pharmaceutical Manufacturers Association, 1976.

 APHA Project Staff, Handbook of  Nonprescription Drugs.
 Aerican Pharmaceutical Association, Washington, B.C., 1977.

 Breaz, Emil, "Drug Firm Cuts Sludge Handling Costs," Water
 and Wastes Engineering,, January  1972, pp. 22-23.     	"

 Burns and Roe submittal to the U.S. EPA, "Burns and Roe Review
 of TRC Data Base," May 8,1978 revised June 7, 1978 .

 Burns and Roe submittal to the U.S. EPA, "Preliminary
 Profile," February 15, 1978.

 Burns and Roe submittal to the U.S.  EPA, "Profile Report No.2
 308 Portfolio,  Subcategory A Report," June 2, 1978.

 Burns and Roe submittal to the U.S.  EPA, "Profile Report No
 3,  Industry  Population,"  June 22, 1978.

 Burns and Roe submittal to the U.S.  EPA, "Profile Report No
 4,  Fate  of Industry Wastewater, "  August; 18,1978.

 Burns and Roe submittal  to the U.S.  EPA,"Profile  Report  No.5
 Treatment Technology," September  8,  1978.

 Burns and Roe submittal  to the U.S.  EPA!, "  Profile Report No
 6A,  Production  Data by Plant Site,"  August 30,  1978.

 Burns and Roe submittal to the  U.S.  EPA!  "Summary  Report No.
 1,  Pharmaceutical Manufacturing Data Base Acquisition "
 February  14,  1978.                      !

 Burns and  Roe submittal to the U.S.  EPAi  "Summary  Report No.
 1A,  308 Portfolio Development, Pharmaceutical Manufacturing,"
 May,  1978.                                                y'

Burns and Roe submittal to  the U.S.  EPAk "Summary Report  No.2,
 308 Portfolio Computerization, Phase I,  Pharmaceutical
                               280

-------
      Manufacturing," February 24, 1978.

15.    Burns and Roe submittal to the U.S. EPA, "Summary Report
      No.  3, Industrial Subcategorization, Review of Alterna-
      tives," February 14, 1978.

16.    Burns and Roe submittal to the U.S. EPA, "Summary Report
      No.  4, Pharmaceutical Manufacturing Point Source Category
      Definition," February 14, 1978.

17.    Burns and Roe submittal to the U.S. EPA, "Summary Report
      No.  5, 308 Portfolio Computerization, Phase II, Pharma-
      ceutical Manufacturing," April 21, 1978.

18.    Burns and Roe submittal to the U.S. EPA, "Screening Plants
      Coverage of Pharmaceutical Products," letter transmitted,
      December 12, 1978.

19.    Burns and Roe submittal to the U.S. EPA, "308 Treatment
      Plant Performance Data," letter report dated December 11,
      1978.

20.    Burns and Roe submittal to the U.S. EPA, "Profile Report
      No.  1A," June 15, 1978.

21.    Crane, Leonard W., "Activated Sludge Enhancement:  A Viable
      Alternative to Tertiary Carbon Adsorption," Proceedings of
      the Open Forum on Management of Petroleum Refinery Waste-
      water, June 6-9, 1977.

22.    Dlouhy, P.E. and Dahlstrom, D.A.,  "Continuous Filtration in
      Pharmaceutical Production," Chemical Engineering Progress,
      Vol. 64, No. 4, April 1968, pp. 116-121.

23.    Dunphy, Joseph F. and Hall, Alan,  "Waste Disposal:  Settling
      on Safer Solution for Chemicals,"  Chemical Week, March 8,
      1978, pp. 28-32

24.    Echelberger, Wayne F., Jr., "Treatability Investigations for
      Pharmaceutical Manufacturing Wastes," presented at the ASCE
      National Environmental Engineering Conference, Vanderbilt
      University, July 13-15,  1977.

25.    Federal Register, Vol. 41, No.31  - Friday, February 13,  1976,
      pp.  6878-6894.

26.    Federal Register, Vol. 41, No. 106 - Tuesday, June 1, 1976,
      pp.  22202-22219.

27.    Federal Register, Vol.41, No. 223 - Wednesday, November  17,
                                281

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 28.


 29.


 30.


 31 .


 32.



 33.



 34.


 35.




 36.


 37.




 38.



40.
 1976, pp. 50676-50686.

 Federal Register. Vol. 42, No. 20 - Monday, January 31, 1977
 pp.  5697.

 Federal Register. Vol. 42, No. 24 - Friday, February 4, 1977,
 pp.  6813-6814.                       j

 Federal Register. Vol. 42, No. 148, - Tuesday, August 2, 1977,
 pp.  39182-39193.                      !

 Federal Register. Vol. 42, No. 191, - Monday,  October 3, 1977,
 pp.  53804-53820.
                                      i
 Fox,  Jeffrey L.,  " Ames Test Success Paves Way for Short-Term
 Cancer Testing,"  Chemical  and Engineering News.  December 12,
 1977,  pp. 34-46.
                                      i 	     • • •     •      	
 Grieves,  C.G., et al,  "Powdered Carbon  Improves  Activated
 Sludge Treatment," Environmental  Management. October 1977,
 pp.  125-130.	

 Humphrey,  Arthur  E.,  "Current Developments in  Fermentation,"
 Chemical  Engineering.  December 9,  1974,  pp.  98-112.

 Lawson, C.T.,  and Hovious,  J.L.,  "Realistic Performance
 Criteria  for  Activated Carbon Treatment  of Wastewaters  from
 the Manufacture of Organic Chemicals and Plastics,"  Union
 Carbide Corporation, February 14,1977.
Lund, Herbert F.,  Industrial Pollution  Control Handbook.
McGraw-Hill.                	"	£-
Marek, Anton C., Jr., and Askins, William,  "Advanced
Wastewater Treatment for an Organic Chemicals Manufacturing
Complex," U.S./U.S.S R. Symposium on Physical/Chemical
Treatment, November 12-14, 1975.
                                      I
                                      i
Mohanrao, G.J., et al, "Waste Treatment at  a Synthetic Drug
Factory in India,"  Journal Water Pollution Control
Federation. Vol. 42, No.8, Part 1, August 1970, ppTl 530-1543.
Natural Resources Defense Council, et al
8 E.R.C. 2120 (D.D.C. 1976).
                                                 vs Train,
41.   PEDCo Environmental submittal to the U.S. EPA, "The Presence
      of Priority Pollutants in the Extractive Manufacture of
      Pharmaceuticals," October 1978.
                               282

-------
42.   PEDCo Environmental submittal to the U.S. EPA, "The Presence
      of Priority Pollutant Materials in the Fermentation
      Manufacture of Pharmaceuticals," no date.

43.   PEDCo Environmental submittal to the U.S. EPA, "The Presence
      of Priority Pollutants in the Synthetic Manufacture of
      Pharmaceuticals," March 1979.

44.   Shumaker, Thomas P., "Carbon Treatment of Complex Organic
      Wastewaters," presented at Manufacturing Chemists Associ-
      ation, Carbon Adsorption Workshop, November 16, 1977.

45.   Stracke, R.J., and Bauman, E.R., "Biological Treatment of a
      Toxic Industrial Waste - Performance of an Activated Sludge
      and Trickling Filter Plant:  Salisbury Laboratories."

46.   Struzeski, E.J., Jr., "Waste Treatment in the Pharmaceuticals
      Industry/Part 1," Industrial Wastes  July/August 1976,
      pp. 17-21.

47.   Struzeski, E.J., Jr., "Waste Treatment in the Pharmaceuticals
      Industry/Part 2," Industrial Wastes  September/October 1976,
      pp. 40-43.

48.   Stumpf, Mark R., "Pollution Control at Abbott", Industrial
      Wastes, July/August 1973, pp. 20-26.

49.   "Super Bugs Rescue Waste Plants," Chemical Week  Novem-
       ber 30, 1977, p. 47 (unauthored).

50.   The Directory of Chemical Producers - U.S.A., Medicinals.
     . Stanford Research Institute, Menlo Park, CA.

51.   The Executive Directory of U.S. Pharmaceutical Industry,
      Third Edition.  Chemical Economics Services, Princeton, NJ.

52.   U.S. EPA, "Assessment of the Environmental Effect of the
      Pharmaceutical Industry," Contract No. 68-03-2510, December
      1978.                                                :'.'-'

53.   U.S. EPA, "Characterization of Wastewaters from the Ethical
      Pharmaceutical Industry," Report No. 670/2-74-057, July
      1974.

54.   U.S. EPA, "Control Techniques for Volatile Organic Emissions
      from Stationary Sources," Contract No. 68-02-2608, Task 12,
      September,  1977.

55.   U.S. EPA, "Development Document for Interim Final Effluent
      Limitations Guidelines and Proposed New Source Performance
                               283

-------
 56.



 57.


 58.


 59.



 60.


 61.



 62.


 63.


 64.



 65.



 66.




 67.



68.
 Standards for the Pharmaceutical Manufacturing Point Source
 Category," Report No. 440/1-75/060, December 1976.

 U.S. EPA, "Development Document for Proposed Existing Source .
 Pretreatment Standards for the Electroplating Point Source
 Category," Report No. 440/1-78/085, February 1978.

 U.S. EPA, Draft of "Pretreatment Standards for Ammonia,
 Phenols, and Cyanides",  Contract No. 68-01-3289, March 1976.

 U.S. EPA, "Pharmaceutical Industry: Hazardous Waste Gen-
 eration, Treatment,  and Disposal," Report No. SW-508, 1976.

 U.S. EPA, "Preliminary Evaluation of Sources and Control of
 the Wastewater Discharges of Three High Volume Pharmaceutical
 Production Processes," Contract No. 68-03-2870,  November 1977.

 U.S. EPA, "Sampling  and  Analysis Procedures for  Screening of
 Industrial Effluents for Priority Pollutants," April 1977.

 U.S. EPA, "Waste Treatment and Disposal Methods  for the
 Pharmaceutical Industry," Report No. 330/1-75-001,  February
 1975.                                                      y

 Willey,  William J.,  and  Vinnecombe, Anne T.,  Industrial
 Microbiology.   McGraw-Hill,  1976.     :
Windholz,  Martha,  The Merck Index 9th Edition.
Co., Rahway,  NJ7  1976.
Merck and
Wu,  Yeun  C.  and  Kao,  Chiao F.,  "Activated Sludge Treatment
of Yeast  Industry  Wastewater,"  Journal  Water  Pollution
Control Federation Vol.  48,  No.  11,  November  1976,  pp.2609-2618

DeWalle,  F.B., et  al,  "Organic  Matter Removal  by Powdered
Activated Carbon Added to  Activated  Sludge,"  Journal  Water
Pollution Control  Federation. April  1977.

Grieves,  C.G., et  al,  "Powdered Activated Carbon Enhancement
of Activated  Sludge for  BATEA Refinery  Wastewater Treatment,"
Proceedings of the Open  Forum' on Management of Petroleum
Refinery  Wastewater,  June  6-9,  1977.  ;

Grulich,  G.,  et  al, "Treatment  of Organic Chemicals Plant
Wastewater with  DuPont PACT  Process," presented  at AICHE
Meeting,  February  1972.

Heath, H.W.,  Jr.,  "Combined  Powdered Activated Carbon -
Biological ("PACT") Treatment of 40 MGD Industrial Waste,"
presented to  Symposium on  Industrial Waste Pollution Control
                               284

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69.


70.



71 .
72.



73.



74.




75.


76.


77.


78.


79.





80.
 at ACS National Meeting, March 24, 1977.

 Button, D.C., and Robertaccio, F.L., U.S. Patent 3,904,518,
 September 9, 1975.

 U.S. EPA, "Control of Volatile Organic Emissions from the
Manufacture of Synthesized Pharmaceutical Products," Report
No. 450/2-78-029, December 1978.

 U.S. EPA, "Draft Development Document Including the Data Base
for Effluent Limitations Guidelines (BATEA), New Source
Performance Standards, and Pretreatment Standards for the
Inorganic Chemicals Manufacturing Point Source Category,"
Contract No. 68-01-4492, April 1979.

 Hwang, Seong T., and Fahrenthold, Paul,  "Treatability of the
Organic Priority Pollutants by Steam Stripping," presented at
A.I.Ch.E, meeting, August 1979.

 Burns and Roe submittal to the U.S EPA,  "Executive Summary of
Effluent Limitations Guidelines for the Pharmaceutical
Industry," July  1979.

 Burns and Roe submittal to the U.S. EPA, "Supplement to the
Draft Contractors Engineering Report for  the Development of
Effluent Limitations Guidelines for the Pharmaceutical
Industry," July  1979.
 Fox, C.R., "Removing Toxic Organics from Wastewater,
Engineering and Process, August 1979.
Chemical
 Boznowski, J.H., and Hanks, D.L., "low-energy Separation
Processes," Chemical Engineering, May 7, 1979, pp.65-71.

 Heist, James A., "Freeze Crystallization," Chemical
Engineering, May 7, 1979, pp. 72-82.

 Hanson, Carl, "Solvent Extraction-An Economically Competitive
Process," Chemical Engineering, May 7,  1979, pp. 83-87.

 Region 2 S&A Chemistry Section memo to William Telliard of
Effluent Guidelines, "Quantitative Organic Priority Pollutant
Analyses-Proposed Modifications to Screening Procedures for
Organics," December 12, 1978.

 Arthur D. Little submittal to the U.S  EPA, "Economic Analyses
of Interim Final Effluent Guidelines for the Pharmaceutical
Industry," August 1976.
81.   Arthur D. Little submittal to the U.S. EPA,  "Preliminary
                               285

-------
      Economic Assessment of the Pharmaceutipal Industry for BATEA
      Effluent Limitation Guidelines Studies/1  February 1978.

 82.    Office of Quality Review to Robert B.  Schaffer of Effluent
      Guidelines Division,  "Treatability of "65"  Chemicals Part B-
      Adsorption of Organic Compounds on Activated Charcoal,"
      December 8,  1977.
                                            \
 83.    Waugh,  Thomas H.,  "Incineration,  Deep  Wells Gain New
      Importance,"  Science,  Vol.  204,  June 15,  1979,  pp.  1188-1190.

 84.    Wild,  Norman H.,  "Calculator program for Sour-Water-Stripper
      Design," Chemical  Engineering.  February 12,  1979,  pp.  103-113.

 85.    M  &  I  preliminary submittal  to the U.S.  EPA,  "A Demonstrated
      Approach for  Improving Performance and  Reliability of
      Biological Wastewatch  Treatment Plants,"  December 1977.

 86.    U.S. EPA,  "Control of Volatile Organic Emissions from
      Manufacture of Synthesized  Pharmaceutical Products," Report
      No. 450/2-78-029,  December  1978.       i

 87.    Swan, Raymond,  "Pharmaceutical  Industry  Sludge:  Drug  Makers
      Face Waste Management  Headache," Sludge,  July-August  1979,
      pp. 21-25.

 88.    Robins, Winston K.,  "Representation  of Extraction
      Efficiencies,"  Analytical Chemistry Vol.  51, No.  11, September
      1979, pp.  1860,  1861.                  l                ,
                                            i
 89.    Dietz,  Edward  A., and Singley,  Kennetl? F.,  "Determination  of
      Chlorinated Hydrocarbons  in Water  by  H^adspace  Gas
      Chromotography," Analyical Chemistry  Vol. 51, No.  11,
      September  1979, pp. 1809-1814.

 90.    U.S. EPA, "Indicatory Fate Study," Report No.  600/2-79-175,
     August 1979.                           !

 91.   U.S. EPA, "Biological  Treatment of High Strength Petrochemical
     Wastewater," Report No. 600/2-179-172,  August 1979.

 92.   U.S. EPA, "Activated  Carbon Treatment  of Industrial
     Wastewaters:  Selected  Technical Papers," Report No.
     600/2-79-177, August 1979.
                                            I
93.   U.S. EPA, "Biodegradation and Treatability of Specific
     Pollutants," Report No. 600/9-79-03, October 1979.
                                            !

94.   Interagency Regulatory Liasion Group,  "Publications on Toxic
     Substances:  A Descriptive Listing,"  1979.
                                286

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95.    Federal Register, Vol. 44, No. 233 - Monday, December 3, 1979,
     pp.  69464-69575.

96.    Engineering-Science, Inc. submittal to the U.S. EPA,
     "Effectiveness of Waste Stabilization Pond Systems for Removal
     of the Priority Pollutants," December 1979.

97.    U.S. EPA, "Seminar for Analytical Methods for Priority
     Pollutants," May 1978.

98.    Strier, Murray P., "Pollutant Treatability:  A Molecular
      Engineering Approach", Vol. 14,No. 1., January 1980, pp. 28-31.

99.    U.S. EPA, "Fate of Priority Pollutants in Publicly Owned
    Treatment Works - Pilot Study," Report No. 440/1-79-300,
    October 1979.

100.  Malina, Joseph F., Jr.,  "Biodisc Treatment," no date.

101.  Gloyna, Earnest F., and Tischler, Lial F.,  "Design of Waste
      Stabilization Pond Systems," presented at International
      Association on Water Pollution Research/ Conference on
      Developments on Land Methods of Waste Treatment and
      Utilization, October  1978.

      Gulp, Ressell L.,  "GAG Water Treatment Systems," Publics
      Works, February  1980, pp.  83-87.    .,   ; .

      Lawson, C.T., and  Hovious, V.C.,  "Realistic Performance
      Criteria for Activated Carbon Treatment of  Wastewaters from
      the Manufacture of Organic Chemicals and Plastics," Union
      Carbide Corporation,  February  14,  1977.
102.


103.




104.



105,



106,




107
      U.S. EPA,  "Development of Treatment and Control Technology  for
      Refractory Petrochemical Wastes," Report No.  600/2-79-080,
      April  1979.

      Pharmaceutical Manufacturers>.Association,  "Administrative
      Officers of the Member Firms and Associates  of  the  PMA,"
      October  1976.

      Manufacturing Chemists Association submittal to Paul
      Fahrenthold of Effluent Guidelines Division,  "Comments  on the
      Molecular  Engineering Approach  to Effluent Guideline
      Development," January 23,  1979.

      Chemical Manufacturers Association submitted to the U.S. EPA
      "CMA Comments on  EPA's Proposed Leather Tanning and Finishing
      Effluent Limitations Guidelines and Standards," March 27,
                                287

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       1980.

 108.   U.S. EPA,  "Ambient Water Quality Criteria," Criteria  and
       Standards  Division, unpublished draft ;report.

 109.   U.S. EPA,  "Development Document for Effluent Limitations
       Guidelines and New Source Performance iStandards for the
       Copper, Nickel, Chromium, and Zinc Segment of the
       Electroplating Point Source Category," Report No.
       440/1-74-003a, March 1974.

 110.   Walk, Haydel and Associates, Inc., "Summary Report for the
       Pharmaceutical BAT/Priority Pollutant Orientation Study,"
       Contract No. 68-01-6024, Work Assignment No. 3, May 20, 1980.

 111.   Considine, Douglas M. (ed.), Chemical and Process Technology
       Encyclopedia, McGraw Hill Book Co., New York, N.Y., 1974.

 112.   Hawley, Gessner G., The Condensed Chemical Dictionary,
       9th edition, Van Nostrand Reinhold Co., New York, N.Y., 1977.

 113. Calspan Corp. Addendum to Development Document for  Effluent
     Limitations Guidelines and New Source Performance Standards.
     Major  Inorganic  Products  Segment  of  Inorganic Chemicals
     Manufacturing Point source Category.   Contract  No.   68-01-
     3281, 1978.                            I

 114. Coleman, R.T., J.D. Colley, R.F.  Klausmeiser,  D.A.  Malish,
     N.P.   Meserole,   W.C.    Micheletti,   and  K  Schwitzgebel.
     Treatment   Methods   for   Acidic   Wastewater   Containing
     Potentially  Toxic Metal Compounds.  EPA Contract No.  68-02-
     2608, U.S.  Environmental Protection Agency, 1978. 220 pp.

 115. Colley,  J.D., C.A. Muela, M.L.   Owen,   N.P.  Meserole,   J.B.
     Riggs, and J.C. Terry.   Assessment of Technology for Control
     of  Toxic Effluents from the Electric Utility Industry.  EPA
     600/7-78-090.  U.S. Environmental Protection Agency, 1978.

 116. Hannah,  S.A., M. Jelus,  and J.M.  Cohen.   Removal of Uncommon
     Trace Metals by Physical and Chemical   Treatment  Processes.
     Journal   Water  Pollution  Control  Federation 49(11):  2297-
     2309, 1977.                            1

 117. Larsen,  H.P., J.K. Shou,  and L.W.  Ross.;  Chemical  Treatment
     of  Metal  Bearing  Mine  Drainage.   Journal Water Pollution
     Control  Federation 45(8): 1682-1695,  1973.

118. Maruvama. T., S.A. Hannah,  and  J.M.  Cohen.   Metal Removal by
     Physical and Chemical  Treatment  Processes.    Journal  Water
     Pollution Control  Federation 47(5):962-975,  1975.
                               288

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119.


120.


121 .
     Nilsson,  R.  Removal  of  Metals  by  Chemical  Treatment  of
     Municipal WAste Water.   Water Research 5:51-60, 1971.

     Patterson, J.W.,  and  R.A.   Minear.    Wastewater  Treatment
     Technology.   Illinois Institute of Technology,  1973.

     Patterson, J.W. Wastewater Treatment Technology.   Ann  Arbor
     Science Publishers, Inc.  Ann Arbor,  Micigan, 1975.

122.  Patterson, J.W., H.E.  Allen,  and  J.J.  Scala.    Carbonate
     Precipitation  for  Heavy  Metals Pollutants.  Journal Water
     Pollution Control Federation 49(12):2397-2410,  1977.

123.  Schlauch,  R.M.,  and  A.C.   Epstein.   Treatment  of  Metal
     Finishing  Wastes  by  Sulfide Precipitation.  EPA-600/2-75-
     049, U.S. Environmental Protection Agency, 1977.  89 pp.
124.
125
126,
127
 128.




 129,


 130,




 131
     Scott, M.C. Sulfex - A New Process Technology for Removal of
     Heavy Metals from Waste Streams.   The  32nd  Annual  Purdue
     Industrial  Waste  Conference,  Lafayette, Indiana, 1977. 17
     pp.

     Scott, M.C. Heavy Metals Removal at Phillips Plating,  WWEMA
     Industrial  Pollution Conference, St. Louis, Missouri, 1978.
     16 pp.

     Sorg, T.J. O.T. Love, and G.S. Logsdon.  Manual of Treatment
     Techniques for Meeting the Interim  Primary  Drinking  Water
     Regulations.     EPA-600/8-77-005.     U.S.    Environmental
     Protection Agency, 1977. 73 pp.

     U S.  EPA,  "Development  Document  for  Porposed   Effluent
     Limitations  Guidelines,  New  Source Performance Standards,
     and  Pretreatment  Standards  for  the  Inorganic  Chemicals
     Manufacturing  Point  Source  Category", Contract No. 440/1-
     80/007-6, June 1980.

     Sabade'll, J.E. Traces  of  Heavy  Metals   in  Water  Removal
     Processes    and    Monitoring.    EPA-902/9-74-001.     U.S.
     Environmental Protection Agency,  1973.

      U.S. EPA,  "Analytical Methods for the Verification Phase
      of  the BAT Review,  " June 1977.

      The Research Corporation of  New  England  submittal  to the
      U.S. EPA,  "Assessment of the Environmental Effect  of the
      Pharmaceutical  Industry, " December  1978.

      Catalytic  Inc.,  Computerized Wastewater  Treatment  Model
      prepared  for U.S. EPA  1980).
                                289

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132.   Catalytic Inc., Submittal to Burns and Roe, "Computer
      Print Out - Pharmaceutical ANalysis," Jan. 29, 1980.
                                          i
133.   U.S.  EPA, "Fate of Priority Pollutants in Publicly
      Owned Treatment Works," - Interim Report", October 1980,
                              290

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                           SECTION XVII

                     LEGEND OF ABBREVIATIONS
AA
A.C.
AE
atm
avg.
BADCT

BAT (BATEA)

bbl.
BCT
B-N
BOD5
BPT (BPCTA)

Btu
°C
C.A.
cal.
cc
cfm
cfs
cm
CN
COD
cone.
cu.m.
deg.
DO
E.Col.
Eq.
op-
Fig.
F/M

fpm
fps
ft
g
gal.
GC
GC/MS

gpd
gpm
atomic absorption
activated carbon
Acid extractables
atmosphere
average
Best Available Demonstrated Control
  Technology
Best Available Technology Economically
  Achievable  :
barrel
Best Conventional Control Technology
Base - Neutral Extractables
Biochemical Oxygen Demand, five day
Best Practicable Control Technology
  Currently Available
British Thermal Unit
degrees Centigrade
carbon adsorption
calorie
cubic centimeter
cubic feet per minute
cubic feet per second
centimeter
cyanide
Chemical Oxygen Demand
concentration
cubic meter
degree
dissolved oxygen
Escherichia coli - coliform bacteria
equation
degrees Fahrenheit
Figure
Food to microorganisms ratio
   (Ibs BOD/1bs MLSS)
feet per minute
feet per second
foot
gram
gallon
Gas chromatography
Gas chromatography/Mass
   Spectrophotometry
gallon per day
gallon per minute
                               291

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 hp
 hp-hr
 HPLC
 hr
 in
 kg
 KW
 KWh
 1
 1/kkg
 Ib
 m
 M
 mg
 MGD
 mg/1
 min
 ml
 MLSS
 MLVSS

 mm
 MM
 mole
 mph
 MPN
 mu
 NH3-N
 N03-N
 NPDES

 NSPS
 02
 P04
 P.
 pH
POTW
PP.
ppb
ppm
PSES

psf
psi
PSNS
RBC
R.O.
rpm
 horsepower
 horsepower-hour
 High  Pressure Liquid Chromatography
 hour
 inch            |
 kilogram        ;
 kilowatt
 kilowatt hour
 liter          :
 liters per  1000 kilograms
 pound
 meter
 thousand
 milligram
 million gallons per day
 milligrams per liter
 minute
 milliliter      •
 mixed liquor suspended solids
 mixed liquor volatile suspended
  solids
 millimeter
 million
 gram  molecular weight
 mile  per hour
 most
 millimicron     ;
 ammonia nitrogen
 nitrate nitrogen
 National Pollutant Discharge
  Elimination System
 New Source Performance Standards
 Oxygen          ;
 phosphate
 page
 potential hydrogen or hydrogen-ion
  index (negative logrithm of the
  hydrogen-ion concentration)
 Publicly Owned Treatment Works
 pages
 parts per billion
 parts per million
 Pretreatment Standards for Existing
  Sources
pounds per square foot
pounds per square inch
 Pretreatment Standards for New Sources
Rotating Biological Contactor
 reverse osmosis
 revolution per minute
                              292

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RWL
sec.
Sec.
SIC
SOx
sq.
sq. ft.
SS
STP
SRWL
TDS
TKN
TLM
TOC
TOD
TSS
VOA
vol
wt
yd
u
ug
ug/1
raw waste load
second
Section
Standard Industrial Classification
Oxides of Sulfur (e.g. sulfate)
square
square foot
suspended solids
standard temperature and pressure
standard reiw waste load
total dissolved solids
total Kjedahl nitrogen
median tolerance limit
total organic carbon
total oxygen demand
total suspended solids
Volatile Organic Analysis
volume
weight
yard
micron
microgram
microgram per liter
note:  symbols for chemical elements and compounds are in accordance
       with IUPAC and standard chemical nomenclature.
                               293

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                           SECTION XVI

                          ACKNOWLEDGMENTS
 Acknowledgment is made to  all  Environmental  Protection  Agency
 personnel    contributing   to  this  effort.    Specifically,   the
 development of  this  report  was  under  the  direction  of   the
 following  personnel:
      Robert  Schaffer

      Jeffrey Denit

      Devereaux  Barnes

      Paul  Fahrenthold
      Robert  Bellinger

      James Gallup
      Michael Kosakowski
      Joseph  Vitalis
      Dan Lent
      Susan Delpero
      Frank Hund
Former Director, Effluent
Guidelines Division
Director, Effluent
Guidelines Division
Deputy Division Director,
Effluent Guidelines Division
Chief, Organic Chemicals Branch
Acting Chief, Wood Fibers and
Product's Branch
Chief, Office of Quality Review
Project Officer
Project Officer
Project! Officer
Chemical Engineer
Project Officer
In  addition,  the  Organic Chemicals Branch would  like to extend
its appreciation  to the  following   individuals  for  significant
input  into  the  production  of  this Development  Document while
serving as members of the EPA pharmaceutical working group  which
provided detailed review, advice and assistance:

          Rob Ellis      - Economic Project Officer
          Jean Noroian   - Economic Project Officer
          Susan Green    - Economic Project Officer
          John Ataman    - Economic Project Officer
          Kathleen Ehrensberger - Economic Project Officer
          Henry Kahn     - Statistical Project Officer
          Russ Roegner   - Statistical Project Officer
          William Kaschak- MDSD Project Officer
          Rich Silver    - MDSD Project Officer
          Ruth Wilbur    - MDSD Project Officer
          Richard Healy -  MDSD Project Officer
          Susan Lepow    - OGC Attorney
          Catherine Winer- OGC Attorney
          Bruce Newton   - Enforcement Division
The  following  members  of  the Burns and
Corp., technical staff made significant
base development and technical analysis:
                              294
        Roe Industrial  Service
     contributions  to the data

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     Arnold S.  Vernick  -

     Barry S.  Langer
     Jeffrey A. Arnold  -
     Tom H. Fieldsend
     Thomas Gunder
     Vaidyanathan Ramaiah-
     Mark Sadowski
     Mary Surdovel
     Jeffrey Walters
     Samuel Zwickler
Manager, Environmental
       Engineering
Project Manager
Project Engineer
      Environmental Engineer
Environmental Engineer
 Environmental Engineer
      Environmental Engineer
      Environmental Engineer
      Environmental Engineer
      Senior Supervising Engineer
Walk, Haydel and Associates, Inc. provided technical support  for
this  regulatory  effort  through  the  following  members of its
technical staff:
J.S. Beaver
Forrest E. Dryden
E. Jasper Westbrook
Richard Melton
Ronald Rossi
Miles Sieffert
Efrain Toro
Fred J. Zak
Paul R. Schneider
Anita Junker
 Administrative Project Manager
 Technical Manager
 Technical Program Coordinator
 Project Engineer
 Project Engineer
 Project Engineer
 Project Engineer
 Project Engineer
 Environmental Scientist
 Environmental Technologist
     The assistance of Mrs. Kaye Storey, Mrs. Glenda Nesby, Ms. Carol Swann
the Word Processing Center of Effluent Guidelines Division  in  the
typing of  this report is  specifically noted.

     The assistance of all personnel at EPA Regional Offices and
State environmental departments who participated  in the  data
gathering  efforts  is greatly appreciated.

     The assistance of PEDCo, Cincinnati,  Ohio,  is also
acknowledged for their technical  input and text preparation used  in
the process description portion of Section II.

     Acknowledgment  is made  to all of the  pharmaceutical plants
that participated  in the  sampling programs included  in this
study.

     Acknowledgment  is made  to the environmental  committees of
the  Pharmaceutical Manufacturers  Association  (PMA)  for their
assistance during  the  course of  this  project.

     The  efforts  of  The  Research  Corporation  of  New England (TRC)
 in developing and  maintaining an  open literature data base are also
acknowledged.
                               295

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APPENDIX A



  Glossary

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                           APPENDIX A

                            GLOSSARY


Abatement.  The measures taken to reduce or eliminate pollution.

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.

Acclimation.  The ability of an organism to adapt to  changes   in
its immediate environment.

Acid.  A substance which dissolves in water with the formation  of
hydrogen ions.

Acidulate.  To make somewhat acidic.

Act.  Clean Water Act of  1977, PL  95-217.

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

Activated  Sludge Process.  A wastewater purification  process   in
which microorganisms absorb dissolved or suspended  organic  matter
and  secrete  enzyme to digest and utilize  this matter    The  term
"activated sludge" applies to the  flocculant   growths   formed   as
the microorganisms grow and reproduce.

Active   Ingredient.  The  chemical  constituent  in  a  medicine which
is responsible  for  its activity.

Adsorption.   A  method of  treating  wastes   in   which  a  material
 (designated   "adsorbent")    chemicals   or ^organic  Batter   not
necessarily responsive  to clarification or   biological   treatment
by adherence on the  surface of  solid bodies.

Advanced  Waste  Treatment.    Any   treatment  method  or  process
employed following  biological  treatment to increase  the  removal
of  pollution  load,  to remove substances  that may be deleterious
 to receiving waters or  the environment   or  to  produce  a- high-
 quality effluent suitable for reuse in  any specific manner or for
 discharge under critical  conditions.  The  term tertiary .treatment
 is commonly used to denote advanced waste  treatment methods.

 Aeration.  (1)  The bringing about of intimate contact between air
 and . a—liquid  by  one  of  the following methods:  spraying the

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 liquid ih the air, bubbling air through the liquid, or  agitation
 of  the  liquid  to  promote  surface absorption of air.   (2) The
 process or state of being supplied or impregnated  with  air;  in
 waste  treatment,  a  process  in  which  liquid from the primary
 clarifier is mixed with  compressed  air  and  with  biologically
 active sludge.
 Aerobic.   Ability
 oxygen is present.
to  live,  grow, or take place only where free
 Algae.  Unicellular or multicellular autotrophic,  photosynthetic
 protists.   They  are  a  food for fish and small aquatic animals
 and, like all plants, put oxygen into the water.
                                             I

 Alqicide.  Chemical  agent  added  to  water  to  destroy  algae.
 Copper sulfate is commonly used in large water systems.

 Alkali.      A  water-soluble  metallic  hydroxide  that  ionizes
 strongly.

 Alkalinity.    The  presence  of  salts  of  alkali  metals.    The
 hydroxides,   carbonates,   and bicarbonates of calcium,  sodium and
 magnesium  are  common  impurities  that  cause  alkalinity.     A
 quantitative measure of the capacity of liquids or suspensions to
 neutralize  strong acids  or to resist the establishment of acidic
 conditions.     Alkalinity   results   from  ; the   presence    of
 bicarbonates,    carbonates,    hydroxides,    'alkaline   salts   and
 occasionally borates and  is usually expressed  in  terms  of   the
 amount  of  calcium  carbonate  that  would  have  an  equivalent
 capacity to  neutralize strong acids.
                                             !                N

 Alkaloids.   Basic (alkaline)  nitrogenous botanical products which
 produce a marked physiological action when administered  to   ani-
 mals or humans.

 Alkvlation.    The  addition   of  a   aliphatic  group to  another
 molecule.  The media in which this  reaction is   accomplished   can
 be vapor or  liquid  phase,  as  well as  aqueous or non-aqueous.

 Ammonia  Nitrogen.   A substance produced by the microbiological
 decay of plant and  animal  protein.    When  ammonia   nitrogen   is
 found  in waters,  it  is  indicative of  incomplete treatment.

Ampules.  A small glass container that can be seated  and its con-
 tents    sterilized.    Ampoules   are  used  to  hold   hypodermic
solutions.
Anaerobic.  Ability to live, grow, or take place where
no air or free oxygen present.
                                   there  is
                              A-2

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Anton.  Ion with a negative charge.

Antagonistic  Effect.  The simultaneous action of separate agents
mutually opposing each other.

Antibiotic.  A substance produced by a  microorganism  which  has
the  power,  in  dilute  solution,  to  inhibit  or destroy other
organisms, especially bacteria.

Aqueous Solution.  One containing water or watery in nature.

Arithmetic Mean.  The arithmetic mean of a  number  of   items   is
obtained by adding   all the  items together and dividing  the total
by the number of items.  It  is frequently called the average.   It
is greatly affected  by extreme values.

Autoclave.   A  heavy  vessel  with  thick  walls  for conducting
chemical reactions under high pressure.  Also an apparatus  using
steam under pressure for sterilization.

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.

Bacteria.  Unicellular protists  having  round, rodlike, spiral,  or
filamentous  bodies  and often aggregated  into  colonies  or mobile
by means  of flagella.  They exist  in soil,  water, organic matter,
and  in  the bodies of plants and  animals.   Nutritionally, they are
autotrophic, saprophytic,  or parasitic.   Temperature  and pH   play
an   important   role   in  the  life  cycle of bacteria.   A few are
capable  of  performing    photosynthesis.     Any   ^water   supply
contaminated   by  sewage   is certain to contain a bacterial  group
called  "coliform."

Bacteriophage.   A submicroscopic,  usually  viral,   organism  that
destroys  bacteria.   Also  called  "phage."

BADCT   Limitations for  new sources which are based on the appli-
 cation of the Best Available Demonstrated Control Technology.

 Base.   A  substance  that  in  aqueous solution turns red litmus
 blue, furnishes hydroxyl  ions and reacts with an acid to  form  a
 salt and water only.
 BAT  Effluent  Limitations.  Limitations for point sources, other
 tha"n 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,  1983.

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 Batch Process.  A process which has an intermittent flow  of  raw
 materials  into the the process and a resultant intermittent flow
 of product from the process.

 BCT.  Best Conventional Pollutant Control Technology.
                                           j 	   •
 Bioassay.  An assessment which is made by using living  organisms
 as the sensors.                           :
                                           i
 Biochemical  Oxygen  Demand  (BOD).    A  measure  of  .the  oxygen
 required  to  oxidize  the  organic  material  in  a  sample   of
 wastewater   by   natural   biological   process  under  standard
 conditions.  This test is presently universally accepted  as  the
 yardstick  of  pollution  and is utilized as a means to determine
 the degree of treatment in a waste  treatment  process.   Usually
 given  in  mg/1(or  ppm)  units),   meaning  milligrams  of oxygen
 required per liter of wastewater,  it can  also  be  expressed  in
 pounds  of  total oxygen required  per wastewater or sludge batch.
 The standard BOD test is run for five days at 20 degrees C.

 Biota.   The flora and fauna (plant and animal life) of  a  stream
 or other water body.

 Biological  Products.    In the  pharmaceutical industry,  medicinal
 products derived  from  animals or   humans,   such   as  vaccines,
 toxoids,  antisera and human blood  fractions.

 Biological Treatment  System.  A system that  uses microoganisms  to
 remove organic pollutant material  from a  wastewater.
	 Fractionation.   The  separation   of   human  blood  into its
various protein  fractions.

Slowdown.   (1) Water  intentionally discharged from  a   cooling  or
heating  system  to maintain the dissolved solids  concentration of
the circulating  water  below  a  specific critical   level.    The
removal  of  a   portion  of  any  process flow   to   maintain the
constituents of  the flow within desired  levels.   Process  may  be
intermittent  or continuous.  (2)  The   water  discharged from a
boiler or cooling tower to dispose of accumulated salts.

BODJ5. Biochemical oxygen demand (BOD) is  the amount of  oxygen
required  by  bacteria  while  stabilizing ! decomposable  organic
matter under aerobic conditions.   The BOD t|est has been developed
on the basis of  a 5-day incubation period (i.e. BOD5_).
                                           i. ..' ... ' '  .   ...
Botanicals.  Drugs made from a part of a  plant,   such  as  roots,
bark, or leaves.                           :

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BPT  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.

Brine.  Water saturated with a salt.

Buffer.  A solution containing either a weak acid and its salt or
a weak base and its salt which thereby resists changes in acidity
or basicity (pH).

Capsules.  A gelatinous shell used to contain medicinal chemicals
and as a dosage form for administering medicine.

Carbohydrate.  A compound  of carbon, hydrogen and oxygen, usually
having hydrogen and oxygen in the proportion of  two  to one.

Carbonaceous.  Containing  or composed of carbon.

Catalyst.  A substance which changes the rate of a chemical reac-
tion  but undergoes no permanent  chemical change  itself.

Cation.  The ion in an electrolyte  which   carries   the  positive
charge  and which migrates toward the cathode under  the  influence
of a  potential difference.

Cellulose.   The  fibrous   constituent  of  trees  which   is   the
principal raw material of  paper  and paperboard.  Commonly  thought
of as a fibrous material of vegetable origin.

Chemical  Oxygen  Demand   (COD).   A  measure of oxygen-consuming
capacity  of organic and  inorganic  matter   present   in   water  or
wastewater.    It   is  expressed  as  the amount  of oxygen consumed
from  a chemical  oxidant   in  a specific  test.    It   does  ^not
differentiate  between stable and unstable  organic matter and  thus
does  not  correlate with  biochemical  oxygen demand.

Chemical  Synthesis.   The processes  of  chemically combining two or
more  constituent substances into a  single  substance.

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

 Coagulation.    The clumping  together  of   solids  to  make  them
 settleout" of  the   sewage  faster.    Coagulation  of solids is
 brought about with the use of  certain chemicals,  such  as  lime,
 alum or polyelectrolytes.
                                A-5

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 Combined  Sewer.
 run-off.
One which carries both sewage and storm water
 Composite Sample.    A combination of individual samples of wastes
 taken at selected intervals,  generally hourly for  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 of liquid at  the
 time of sampling.                          '• '

 Comprehensive  Pharmaceutical  Data  Base.   Combined  data  base
 formed by the first 308 survey of PMA-member companies  plus  the
 second,  or Supplemental 308 survey.

 Concentration.   The total mass of the suspended or dissolved par-
 ticles  contained   in  a  unit  volume at a  given temperature and
 pressure.
                                           i
 Conductivity.    A   reliable    measurement    of    electrolyte
 concentration  in   a  water sample.   The conductivity measurement
 can  be related  to  the concentration  of dissolved  solids  and   is
 almost  directly  proportional  to the ionic concentration of  the
 total  electrolytes.

 Contact  Process  Wastewaters.   These  are process-generated  waste-
 waters  which   have  come in  direct   or indirect contact with  the
 reactants  used  in  the process.   These  include   such  streams   as
 contact  cooling  water,  filtrates,  centrates,  wash waters,  etc.

 Continuous  Process.    A process which has a constant flow of  raw
 materials  into  the process and resultant constant flow of product
 from the process.                          !
Contract  Disposal.    Disposal
outside party for a fee.
            of  waste  products   through   an
Crustaceae.   These' are small animals ranging in size form 0.2 to
0.3 millimeters long which move very rapidly through the water in
search  of  food.  They have recognizable head and posterior sec-
tions.  They form a principal source of food for small  fish  and
are found largely in relatively fresti natural water.

Crystallization.    The  formation  of  sol id  particles within a
homogeneous phase.  Formation of crystals separates a solute from
a solution and generally leaves impurities!behind in  the  mother
liquid.

Culture.   A mass of microorganisms growing in a media.
                               A-6

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Cyanide,  Total.    Total  cyanide  as  determined  by  the  test
prodecure specified in 40 CFR Part 136  (Federal  Register,  Vol.
38, no. 199, October 16,1973).

Cyanide  A_._    Cyanides  amenable to chlorination as described in
"1972 Annual Book of ASTM  Standards"  1972:   Standard  2036-72,
Method B, p. 553.
Derivative.
substance.
substance  extracted  from  another  body  or
Desorption.   The opposite of adsorption.  A phenomenon where  an
adsorbed molecule leaves the surface of the adsorbent.

Diluent.  A diluting agent.

Direct Discharge.   The discharge of process wastewaters to navi-
gable waters such as rivers, streams and lakes.

Disinfectant.   A chemical agent which kills bacteria.

Disinfection.    The  process  of killing the larger portion  (but
not  necessarily  all)   of   the   harmful   and   objectionable
microorganisms in or on a medium.

Dissolved Oxygen (DO).   The oxygen dissolved in sewage, water or
other  liquids,  usually expressed either in milligrams per liter
or  percent  of  saturation.   It  is  the  test  used   in   BOD
determination.

Distillation.   The  separation,  by  vaporization,  of  a liquid
miscible and volatile mixture into individual components, or,  in
some  cases,  into  groups 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 other wastes
to remove recoverable products.

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

Elution.    (1)  The  process of washing out, or removing with the
use of a solvent.  (2) In an ion exchange process it  is  defined
as  the  stripping of adsorbed ions from an ion exchange resin by
                               -7

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 passing  through the resin  solutions
 relatively high concentrations.
                          containing  other  ions  in
 Emulsion.
 another.
A  suspension  of  fine  droplets  of  one  liquid in
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.                          j

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  a catalyst.   The use of  sulfuric acid has,  in
the past, caused  this type  ofonation.

Ethical Products.  Pharmaceuticals promoted  by advertising to the
medical/  dental and  veterinary professions.

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  may   not
contain   some double bonds.   They usually contain sixteen or  more
carbon atoms.
                                           i
                                           i :
Fauna.  The animal   life  adapted  for   living   in  a  specified
environment.

Fermentation.   Oxidative  decomposition of   organic   substances
through the action of  enzymes  produced by microorganisms.

Fermentor Broth.   A  slurry  of  microorganisms  in water   containing
nutrientsTcarbohydrates,     nitrogen)    necessary    for    the
microorganisms' growth.

Filter Cakes.  Wet solids generated by the filtration   of  solids
from a liquid.  This  filter cake  may be  a pure material  (product)
or  a  waste  material  containing   additional fine  solids  (i.e.,
diatomaceous  earth)   that  have   been   added  to aid   in    the
filtration.

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

Flocculants.  Those water-soluble organic  polyelectrolytes   that
are  used   alone or  in conjunction  with  inorganic coagulants  such
as lime,  alum or ferric chloride  or  coagulant  aids to  agglomerate
solids suspended in aqueous systems  or   both;  the  large  dense
                               A-a

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floes  resulting  from  this  process
efficient solids-liquid separations.
                                       permit more rapid and more
Flora.  The plant life characteristic of a region.

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

Fractionation  (or  Fractional  Distillation).  The separation of
constituents, or groups of constituents, of a liquid  mixture  of
miscible and volatile mixtures by vaporization and recondensation
over specific boiling point ranges.

Fungus.   Any  of  a  plant-like group of organisms that does not
produce chlorophyll; they derive their food either by decomposing
organic matter from dead  plants  and  animals  or  by  parasitic
attachment to living organisms, thus often causing infections and
disease.   Examples  of  fungi are molds, mildews, mushrooms, and
the rusts and smuts that infect grain  and  other  plants.   They
grow  best   in a moist environment at temperatures of about  25°C,
little or no light  being  required.   In  sanitary  engineering,
fungi  are   considered  to  be  multicellular, nonphotosynthetic,
heterotrophic protists.

Gland.  A device utilizing a soft wear-resistant material used to
minimize  leakage between a  rotating  shaft   and  the   stationary
portion of a vessel such as a pump.
                                                  Sometimes  called
Gland  Water.   Water used to lubricate a gland.
"packing water."

Grab Sample.   (1) Instantaneous sampling.  (2)  A sample taken at
a random place in space and time.

Grease.  In sewage,  grease  includes  fats,  waxes,  free  fatty
acids,  calcium  and magnesium soaps, mineral oils and other non-
fatty materials.   The  type  of  solvent  to  be  used  for  its
extraction should be stated.

Hardness.   A  measure of the capacity of water for precipitating
soap.ft is reported as the hardness that would be produced if a
certain amount of CaCoS were dissolved in water.  More  than  one
ion  contributes  to  water hardness.  The "Glossary of Water and
Wastewater  Control  Engineering"   defines   hardness   as:    A
characteristic  of  water imparted by salts of calcium, magnesium
and  iron, such as bicarbonates, carbonates,  sulfates,  chlorides
and  nitrates,  that causes curdling of  soap, deposition of scale
in boilers, damage in some  industrial  processes,  and  sometimes
                                 A-9

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 objectionable   taste.    Calcium  and  magnesium  are  the  most
 significant constituents.
 Hormone.  Any of a number of substances formed in the body  which
           specifically  receptive organs when transported to them
                       A  material  secreted  by  ductless  glands
                      Most hormones as well as synthetic analogues
activate
by the body fluids.
(endocrine glands).
have in common the cyclopentanophenanthrene nucleus.
 Indirect  Discharge.    The  discharge of (process)  wastewaters to
 publicly owned treatment works (POTW).
 Injectables.   Medicinals prepared in a  sterile
 suitable for  administration by injection.•'>
                                                 (buffered)  form
 Mycelia.    The filamentous material which makes up the vegetative
 body of a fungus.
                                           i
 New  Source.   Any facility  from  which  there  is  or  may  be  a
 discharge  of  pollutants,  the construction of which  is commenced
 after the  publication  of  proposed  regulations  prescribing  a
 standard  of performance under  section 306 of the Act.

 Non-contact  Cooling Water.  Water  used  for cooling that does  not
 come into direct contact with  any raw material,  intermediate pro-
 duct,  waste product  or finished product.

 Non-contact Process   Wastewaters.    Wastewaters   generated  by  a
 manufacturing  process which have not come! in direct  contact with
 the  reactants used in the process.   These include such streams as
 noncontact  cooling   water,  cooling  tower   blowdown,   boiler
 blowdown,  etc.

 NSPS.  New Source Performance Standards.    '.
                                           \  .' .
 NPDES.    National  Pollution  Discharge   Elimination   System.    A
 federal program requiring industry  to obtain permits  to discharge
 plant  effluents to the nation's water courses.
Nutrient.   Any  substance  assimilated  by  an  organism
promotes growth and replacement of cellular constituents.
                                                            which
Operation   and  Maintenance.   Costs  required  to  operate  and
maintain pollution abatement equipment including labor, material,
insurance, taxes, solid waste disposal, etc.

Organic Loading.  In the activated  sludge1 process,the  food  to
microorganisms (F/M) ratio defined as the amount of biodegradable
material  available  to a given amount of microorganisms per unit
of time.
                               A-10

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Oxidation.  A process in which an atom or group  of  atoms  loses
electrons;   the   combination   of   a  substance  with  oxygen,
accompanied with  the  release  of  energy.   The  oxidized  atom
usually  becomes  less positive while the oxidizing agent becomes
more negative (in chlorination, for example).

Oxidation Reduction (OR).  A class of chemical reactions in which
one of the reacting species gives up electrons (oxidation)  while
another  species  in the reaction accepts electrons (reductions).
At one time, the  term  oxidation  was  restricted  to  reactions
involving  hydrogen.   Current  chemical technology has broadened
the scope of these terms to include all reactions where electrons
are given up and taken on  by  reacting  species;  in  fact,  the
donating   and   accepting   of   electrons   must   take   place
simultaneously.

Oxidation  Reduction  Potential  (ORP).    A   measurement   that
indicates  the  activity  ratio  of  the  oxidizing  and reducing
species present.

Oxvaen. Available.  The quantity of atmospheric oxygen  dissolved
in  the  water  of  a  stream;  the  quantity of dissolved oxygen
available for the oxidation of organic matter in sewage.

Oxygen,  Dissolved.   The  oxygen  (usually  designated  as   DO)
dissolved   in  sewage,  water  or  another  liquid  and  usually
expressed in mg/1, parts per million, or percent of saturation.

Parts Per Million (ppm).  Parts by weight in sewage  analysis;ppm
by  weight  is  equal  to  milligrams  per  liter  divided by the
specific gravity.  It should be noted that in water analysis, ppm
is always understood to imply a weight/weight ratio, even  though
in practice volume may be measured instead of a weight.

Pathogenic.  Disease producing.

pH.  The  negative logarithm of the hydrogen ion concentration or
activity in a  solution.   The  number  7  indicates  neutrality,
numbers  less  than  7  indicate  increasing  acidity and numbers
greater than 7 indicate increasing alkalinity.

Photosynthesis.    The  mechanism  by  which  chlorophyll-bearing
plants  utilize  light  energy to produce carbohydrate and oxygen
from carbon dioxide and water(ihe reverse of respiration.).

Physical/Chemical  Treatment  System.   A  system  that  utilizes
physical    (i.e.,   sedimentation,   filtration,  centrifugation,
activated carbon, reverse osmosis, etc.)  and/or  chemical  means
(i.e.  coagulation,  oxidation,  precipitation,  etc.)  to  treat
wastewaters.
                              A-11

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 Plasma.  The fluid part of blood, lymph, or  intramuscular  fluid
 in which cells are suspended.

 PMA.   Pharmaceutical Manufacturers Association.

 Point Source.  Any discernible, confined and discrete conveyance,
 including  but  not  limited to any pipe, ditch, channel, tunnel,
 conduit,  well,  discrete  fissure,   container,  rolling   stock,
 concentrated   animal  feeding  operation,   or  vessel  or  other
 floating craft, from which pollutants are or may be discharged.

 Potable Water.   Drinking water sufficiently pure for human use.

 Potash.  Potassium compounds used in  agriculture  and  industry.
 Potassium carbonate can be obtained  from wood ashes.  The mineral
 potash  is  usually  a muriate (chloride).  ^Caustic potash is its
 hydrated form.
 Preaeration.
A preparatory treatment of  sewage,  consisting  of
remove  gases and add oxygen or to promote the flo-
 aeration   to
 tation of grease and aid coagulation.

 Precipitation.   The phenomenon which occurs when a substance held
 in  solution  passes  out  of that solution   into  solid  form.    The
 adjustment  of   pH  can  reduce  solubility  ancl cause precipitation.
 Alum  and  lime are frequently used  chemicals in such operations as
 water softening  or  alkalinity  reduction.

 Pretreatment.  Any  wastewater  treatment process used to  partially
 reduce the pollution load before   the  wastewater  is  introduced
 into   a  main  sewer system dr delivered  to a treatment  plant for
 substantial  reduction of  the pollution load.

 Process Waste Water.  Any water which,  during  manufacturing  or
 processing,  comes   into   direct contact  with or results from the
 production or use of any raw material,   intermediate   product,
 finished  product, by-product,  or waste product.
                                             !              ' •'     •
 Process  Water.   Any water(solid, liquid or vapor)  which, during
 the manufacturing process, comes into direct contact with any raw
 material,  intermediate product,  by-product,   waste   product,   or
 finished  product.

 Proprietary  Products.    Pharmaceuticals  promoted by advertising
directly  to the consumer.

PSES.    Pretreatment  Standards  for Existing  Sources.

PSNS.    Pretreatment  Standards  for New Sources.
                             A-12

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Raw Waste Load (RWL).    The  quantity  (kg)  of  pollutant  being
discharged  in  a  plant's  wastewater  measured in terms of some
common denominator (i.e., kkg of production or m2 of floor area).
Receiving Waters.  Rivers, lakes, oceans or
receive treated or untreated wastewaters.
                                 other  courses  that
Reduction.
electrons.
 A process in which an atom (or group of atoms) gains
Such a process always requires the input of energy.
Refractory Orqanics.   Organic materials that are only  partially
biodegradable    in   biological   waste   treatment   processes.
Refractory organics include detergents,  pesticides,  color-  and
odor-causing agents, tannins, lignins, ethers, olefins, alcohols,
amines, aldehydes, ketones, etc.

Residual  Chlorine.   The  amount of chlorine left  in the treated
water that is available to oxidize contaminants if  they enter the
stream.  It is usually  in  the  form  of  hypochlorous  acid  of
hypochlorite  ion  or  of  one  of the chloramines.  Hypochlorite
concentration alone is  called  "free  chlorine  residual"  while
together  with  the  chloramine concentration their sum is called
"combined chlorine residual."

Retort.  A vessel, commonly a glass bulb with a  long  neck  bent
downward,used for distilling or decomposing substances by heat.

Sanitary  Sewers.   In  a  separate  system, pipes  in a city that
carry only  domestic  wastewater.   The  storm  water  runoff  is
handled by a separate system of pipes.
Saprophytic Organism.
matter.
           One that lives on dead or decaying organic
Secondary  Treatment.   The  second  step  in most waste treatment
systems in which bacteria consume the organic part of the wastes.
This  is accomplished by bringing the sewage and bacteria together
either in trickling filters or  in the activated sludge process.

Seed.  To introduce microorganisms into a  culture medium.
Serum.  A fluid which  is extracted from  an animal  rendered  immune
against a pathogenic organism  and injected into  a patient  with
the disease resulting  from  the same organism.

Settleable  Solids.    Suspended  solids which will  settle out of  a
liquid waste  in a  given period of time.

Sewage, Storm.  The liquid  flowing in sewers during or  following
a period of heavy  rainfall.
                              A-13

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 Sewerage.    A  comprehensive  term  which includes facilities for
 collecting,   pumping,   treating  and  disposing  of  sewage;   the
 sewerage system and the sewage treatment works.

 SIC  Codes.   Standard  Industrial Classification.   Numbers used by
 the U.S.  Department of Commerce to denote segments of industry.

 Sludge,  Activated.   Sludge floe produced in raw or settled sewage
 by the growth of zoogleal  bacteria and  other  organisms  in   the
 presence  of  dissolved oxygen and accumulated in sufficient  con-
 centration by returning the floe previously formed.

 Sludge,  Age.   The ratio of the weight of volatile solids  in   the
 digester  to  the weight of volatile solids added per day.  There
 is a maximum sludge age beyond which no significant reduction  in
 the concentration of volatile solids will occur.

 Sludge,  Digested.   Sludge  digested  under anaerobic conditions
 until  the  volatile  content  has  been  reduced,    usually    by
 approximately 50 percent or more.

 Solution.    A  homogeneous  mixture  of two or more substances of
 dissimilar molecular  structure.    In  a  solution,   there  is  a
 dissolving medium,  solvent,  and a  dissolved substance,  solute.

 Solvent  Extraction.    The  treatment of a mixture of two or  more
 components 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 jarid"reused.

 Steam Distillation.    Fractionation in whiph  steam  is  introduced
 as  one of  the vapors or in which steam is injected to provide the
 heat  of  the  system.

 Sterilization.   The complete destruction of  all living   organisms
 in  or on a medium;  heat to 121  C at 5  psig for 15  minutes.

 Steroid.   Term applied to any  one of  a large  group  of  substances
 chemically related   to   various  alcohols  found   in plants   and
 animals.                                    !

 Still  Bottom.    The residue   remaining  after distillation  of  a
material.  Varies from  a watery slurry  to a  thick  tar  which  may
 turn  hard  when  cool.

Stillwell.   A  pipe,   chamber, or  compartment with  comparatively
small inlet or  inlets communicating with  a main  body  of  water.
 Its  purpose   is  to  dampen waves  or surges while permitting the
water level within  the  well  to  rise  and  fall  with   the  major
                              A-14

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fluctuations  of  the main body of water.  It is used with water-
measuring devices to improve accuracy of measurement.

Stoichiometric.   Characterized  by   being   a   proportion   of
substances exactly right for a specific chemical reaction with no
excess of any reactant or product.

Stripper.   A  device in which relatively volatile components are
removed from a mixture by distillation or  by  passage  of  steam
through the mixture.

Supernatant.  Floating above or on the surface.

Surge  Tank.   A  tank  for  absorbing and dampening the wavelike
motion of a volume of liquid; an  in-process  storage  tank  that
acts as a flow buffer between process tanks.

Suspended  Solids.   The  wastes  that will not sink or settle in
sewage.  The quantity of material deposited on a  filter  when  a
liquid is dreiwn through a Gooch crucible.

Svnerqistic.  An effect produced by a group of contributors which
is  greater  than  the sume of the individual contributors acting
individually.

Tablet.  A small, disc-like mass of medicinal powder  used  as  a
dosage form for administering medicine.

Tertiary  Treatment.   A process to remove practically all solids
and organic matter from wastewater.   Granular  activated  carbon
filtration is a tertiary treatment process.  Phosphate removal by
chemical  coagulation  is  also  regarded  as  a step in tertiary
treatment.

Thermal Oxidation.   The combustion of organic materials  through
the application of heat in the presence of oxygen.

Total Organic Carbon (TOO.  A measure of the amount of carbon in
a  sample  originating from organic matter only.  The test is run
by burning the sample and measuring the carbon dioxide produced.

Total Solids.  The total amount of solids in a wastewater both in
solution and suspension.

Toxoid.  Toxin treated so as to destroy its toxicity,  but  still
capable of inducing formation of antibodies.

Vaccine.  A killed or modified live virus or bacteria prepared in
suspension for inoculation to prevent or treat certain infectious
diseases.
                               A-15

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Viruses.    (1)  An obligate  intracellular parasitic microorganism
smaller than bacteria.  Most can pass through filters that retain
bacteria.  (2) The smallest (10-300 urn in diameter)  form  capable
of  producing  infection  and  diseases  in  man  or  other large
species.  Occurring in a variety of shapes, viruses consist of  a
nucleic  acid  core  surrounded  by an outer shell (capsid) which
consists of numerous protein subunits (capsomeres).  Some of  the
larger  viruses contain additional chemical substances.  The true
viruses are insensitive to antibiotics.  They  multiply  only  in
living  cells  where they are assembled as complex macromolecules
utilizing the cells' biochemical systems.  They do  not  multiply
by division as do intracellular bacteria.

Volatile  Suspended  Solids  (VSS).   The  quantity  of suspended
solids lost after the ignition of total suspended solids.

Water Quality Criteria.  Those specific values of  water  quality
associated  with  an identified beneficial use of the water under
consideration.

Zero Discharge.   Plants that do  not  discharge  wastewaters  to
either  publicly  owned  treatment  works or to navigable waters.
Plants that  use  evaporation  ponds  or  deep  well  sites,  for
example, are considered zero dischargers.
                              A-16

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               APPENDIX B



308 Portfolio for Pharmaceutical Manufacturing

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Instructions
                                                      308 PORTFOLIO
                                                           FOR
                                              PHARMACEUTICAL MANUFACTURING

                                              INSTRUCTIONS AND DEFINITIONS
2.
3.
Please complete this portfolio for each pharmaceutical manufacturing site in your company which manufactures
Fermentation Products (Subcategory A), Biological and Natural Extraction Products (Subcategory B), Chemical
Synthesis Products (Subcategory C) and Formulation Products (Subcategory D).  This.portfolio is also to be
completed for each pharmaceutical research facility (Sufacategory E) in your company.  If this copy has been
received by or for a non-manufacturing site (i.e. main office, warehouse,-sales office, etc.) or by or for a
non-manufacturing site which also does not conduct pharmaceutical research, please follow the procedure below:

A.   Please check the carbon copies list attached to Mr. Schaffer's letter to see if each of your company's
manufacturing locations has received a separate portfolio.  If any of your manufacturing locations has not
received a portfolio, please request additional copies as Indicated in  (C) below.  Please ensure that the
requested information is provided for each site where your company manufactures pharmaceutical products or
conducts pharmaceutical research.

B.   Please complete Part  I, questions 1 through 5 of the portfolio only, write "not a manufacturing site" and
return the portfolio in the enclosed envelope.   Portfolios have been sent  to company headquarters as notifi-
cation that each manufacturing site will receive and should complete a  separate portfolio.  You may reproduce
this document and maintain a copy in your files for future reference.

C    Extra copies of the portfolio may be obtained by contacting Mr. J. S.  Vitalis at 202-426-2497.  Since
each copy of this portfolio is coded, it is necessary to obtain additional  copies from Mr. Vitalis.

Please read all definitions which follow these  instructions carefully before completing  this portfolio.   It is
preferred that  the  individuals who respond to this portfolio  be familiar with the manufacturing processes  and
the wastewater  treatment systems  and operations at this site.

Please check the appropriate box  or boxes in each question where they appear throughout  this portfolio.   (More
than one box may be checked for  some questions, where appropriate.)  Please complete all questions which
require written responses  by printing or typing  in the  spaces provided.  If separate sheets or attachments are
used to clarify or  answer  a question, please make certain  that  the code number  for  this  portfolio, which
appears at  the  top  right hand  corner  of each page, is also placed  at the  top right  hand  corner of each page of
the attachments.

Please indicate which  information in your responses  is  confidential so  that it  may  be  treated  properly.

Please answer  all  items.   Also,  please  provide  a  separate  set of responses  for  each plant.   The purpose of
this request  is to  gather  all  available, pertinent information  and  is not designed  to  create an undue burden
of sampling requirements on your plant  personnel.  If a question is not applicable  to  a  particular  facility,
 indicate by writing "N/A".   If an item  is not  known,  indicate unknown and explain why  such  information  is not
available.   If an  item seems  ambiguous, complete  as  best  as  possible and  state  your assumptions in  clarifying
the apparent  ambiguity.

The U.S. Environmental  Protection Agency will  review the  information submitted  and  may,  at  a  later  date,
request your  cooperation  for  site visits and  additional sampling  in order to complete  the data base.   Please
 retain  a copy  of the completed portfolio  in  case future contact is necessary to verify your responses.

 Use the  Merck  Index,  Ninth Edition,  1976,  to  specify the  Merck  Index  Identification Numbers (Merck  Index
 Number)  in  Part II  of this questionnaire.   Many of the  Chemical  Abstract Service Registry Numbers (CAS  Numbers)
may be  found  in the Merck Index beginning  on  page REG-1 for  use in completing  Part  II  of this  portfolio.

 Pleas*  use  the enclosed,  pre-addressed  envelope to return the completed portfolio and  appropriate attachments.
 If you  are  sending supplemental  information that will not fit into the  return  envelope provided,  please send
 it under separate cover to:

                                    Mr.  Robert B.  Schaffer, Director
                                    Effluent Guidelines  Division
                                    U.S.  EPA (WH-552)
                                    401  M.  Street, S.W.
                                    Washington, 0.C.  20460
 9.   If you have

 Definitions

      Subcategory

      Subcategory



      Subcategory

      Subcategory
                                    Attention:  J.S. Vitalis

             any questions, please telephone Mr. J.S. Vitalis at 202-426-2497
             A -     Fermentation Products-Pharmaceutical products derived from fermentation processes.

             B -     Biological and Natural Extraction Products-Pharmaceutical products which include blood
                     fractions; vaccines; serums; animal bile derivatives; endocrine products; and isolation of
                     medicinal products, such as alkaloids, from botanical drugs and herbs.

             C -     Chemical Synthesis Products-Pharmaceutical products which result from chemical synthesis.

             D -     Mixing/Compounding and Formulation Products- Pharmaceutical products from plants which
                     blend, mix, compound, and  formulate pharmaceutical ingredients and includes pharmaceutical
                     preparations for  human and veterinary use such as ampules, tablets, capsules, vials,
                     ointments, medicinal powders, and solutions.

 Subcategory E -     Research - Products or services which result from pharmaceutical research, which includes
                     micro-biological, biological and chemical operations.

 POTW    -       Publicly Owned Treatment Works  - Municipal sewage treatment  plant

 NPDES   -       National Pollutant  Discharge Elimination System

 BOD     -       Biochemical Oxygen  Demand

 COD     -       Chemical Oxygen Demand

 TSS     -       Total  Suspended Solids               .
                                                   D-^i
 TOC     -       Total  Organic Carbon

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 PART I

 GENERAL INFORMATION

 1.   Name of Finn
                                                     308 PORTFOLIO FOR
                                               Pharmaceutical Manufacturing
                                      C0ttlp1ete one P°rtfoH° for *>ch manufacturing  and  research  site, and return
 2.   Address of Firm Headquarters:
                                               Robert 8.  Schaffer,  Director
                                               Effluent Guidelines  Division
                                               U.S.  EPA (WH-552)
                                               401  M Street,  S.W.
                                               Washington,  D.C.  20460

                                               Attention:   J.  S.  Vitalis
                        Street
 3.    Name of Plant
 4.    Address of Plant:
                                                        City
                                                                                       State
                        Street"~~~     City                   '         state	1

 S.    Hame(s)  of firm personnel  to  be contacted for infonnation pertaining to tin Is data collection portfolio:

                                                       T.1t1e                  :          (Area Code)  Telephone
6.   Number of Manufacturing Employees in 1976:     Minimum	

7.   Year of operational startup	

8.   Type of production operation within this site for each subcategory:

                                                       Subcateqory
                                                                            Maximum
                                                                                                    Average
     Bitch
     Continuous
     Semicontlnuous
9'*'        e
     Activities
                                           n
                                           n
                                           n
 8
n
n
a
 C
a
D
a
   D'

  D
  D
  D
                                         Total  Laboratory
                                          Square Footaqe
                                         *"" devel°Pme"t activities  conducted at  this site and, for each activity

                                                                    *'  **  ""     °f ^^ 1n C°lumn B and' ^f
Number of
Employees
                                                  C
                                               Animal
                                              Capacity
          Hlcrobloloqical
          Biological
      CD
          Chemical
          Clinical
     1— I
          Development
     D
          Pilot Plant
  b.  If animals  are used  1n  the above research activities, list their type below:
                                                       1-1

                                                    B-2

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10.  Does this plant have a National  Pollutant Discharge Elimination System Permit (NPDES)?     Yes
11.  Has plant submitted NPDES  permit application?      YesQ       N°D
12.  Permit or application number	;	;	;	
13.  Date of permit expiration	  "
14.  Does this plant have wastewater  treatment facilities  on site?     Yes Q]       NoQ
15.  Name and address of publicly owned treatment works (POTVi)  receiving plant wastewater,  If any:
     Name	    •	'
16.
17.
18.

Type of wastewater discharge to POTW:
Level of treatment provided by POTW:
Is there a user charge for discharge to

Process Q
Primary Q
the POTW?

Sanitary Q
Secondary Q
YesQ NoQ

Cool ing [~1
Tertiary Q
     If yes, provide the net annual charge below and indicate which parameters  listed  below  serve as a basis for this
     charge.
     Net Annual Charge _    '
     Basis for Charge
       D COD
       n TSS
       n TOO
       C] Other   (Specify)
 19.   Is  the plant under the requirements of a municipal sewer use ordinance or other ordinance regulating  sewer  use?
      Yes  Q      No Q
 20.   Has  an industrial wastewater survey report been submitted to the State and/or U.S. EPA Regional  Office in
      compliance with a municipal NPOES Permit compliance schedule for industrial discharge to POTW?
      Yes  Q      No Q
      If yes,  attach copy of survey report.                              . ..
                                                      1-2
                                                        B-3

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 PART II
3'
 PRODUCTS AND PRODUCTION PROCESSES
 1.   A.   ^r products which^re produced at this  site,  list  the  Fermentation Products (Subcategory A)  in Table
                               Natural  Extraction Products  (Subcategory B) in Table II B, and the Chemical Synthesis
                     	  _,  m Table II C.   In each  table,  indicate for each product the number of production
      a'nntlaj'n'.Si1::?! proce"?s and P^sical  operations)  which result in wastewater generation in column A and  the
      annual production as kilograms in column B.   For  the  Chemical Synthesis Products (Subcategory C).  list only
      the products which are produced in quantities of  100  kilograms per year or greater?  For each of the Feraen-
      tation Products (in Subcategory A) that you list  in Table II A provide a separate list of raw materials and
      a rf"S; I!??? "«
_• Chemical wastes - organic and inorganic, process waste solvents, cleanup waste solvents [21 Other (Specify) - - • „ ; .. ^.SrSdUCt1°n Er0"SS u?a?9us made '? date for the Primary -purpose of pollution control. Also chnge accordilng^y? S" resulted in an increase or decrease of raw waste load indicating the II-l B-4
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                                                      TABLE II A
List below Fermentation  Products  (Subcategory A).
listed in Table IIA.

Abbreviations:

Merck Index Number - Merck Index Identification  Number
CAS Number - Chemical Abstracts Service Registry Number

Photocopy this table before fining out
                                         ^^
Merck
Index
Number
                                                 Product
                                                                                   A
                                                                                No. of   '
                                                                              Production
                                                                                Steps
                                                                             which result
                                                                             in wastewater
                                                                              Generation
  Annual
Production
 Kilograms
                                                           II-2

                                                           B-5

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                                                       TABLE  II  B

List below Biological and Natural Extraction Products  (Subcategory B).

Abbreviations:

Herck Index Number - Merck Index Identification Number
CAS Nuaber - Chemical Abstracts Service Registry Number

Photocopy this table before filling out
CAS Nunber
Herck
Index
Number
                                                Product
      A
   No. of
 Production
 ;  Steps
which result
in wastewater
 Generation
  Annual
Production
(Ki1oqrams)
                                                  TI-3
                                                      B-6

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                                                      TABLE  II C
list below Chemical  Synthesis  Products  (Subcategory  C).

Abbreviations:

Merck Index Number - Merck Index Identification  Number
CAS Number - Chemical Abstracts Service Registry Number

Photocopy this  table before filling out.
CAS Number
                    Merck
                    Index
                    Number
                                                 Product
      A
   No. of
 Production
   Steps
which result
in wastewater
 Generation
  Annual
Production
(Kilograms)
                                                      11-4

                                                       B-7

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                                                      TABLE II 0
                                                                            I

List below Chemical  Synthesis  Products  not  fn Table  II C if they account for in unusually high  pollution load either

In terms of pounds discharged  per 1,000 pounds of production (Raw Waste Load) >or if they present  difficult treatment
problems.                                                                   ;
                                                  II-5
                                                       B-8

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PART III
      USE. REUSE AND DISCHARGE
               Total Plant Needs During  the Period January 1.  1975 to'December 31. 1976
         sr pe-rWiM ass
     representative  of that period.  Check appropriate boxes
                                                            Average Flow
                                                     (Million gallons per
                                                                                            Time Period
                                                                                           of Calculation
A.
     Water Source

      O Municipal
          Surface
          Ground
          Recycle Process
          Other
               Specify other.
                                                             Average Flow
                                                      (Million gallons per day)
                                                                                             Time Period
                                                                                           of Calculation
 B.
Mater Uses
Q Non-contact cooling
£] Direct process contact (as diluent,
solvent carrier, reactant, by-product.
Q Indirect process contact
(pumps, seals, etc.)
n Non-contact ancillary uses
(boilers, utilities, etc.)
Q Maintenance, equipment cleaning and
work area washdown
n Air pollution control
[3 Sanitary and potable
C] Other
















  c.
                Specify other_
                                                                Average Flow
                                                         (Million gallons per day)
                                                                                              Time Period
                                                                                            of Calculation
      Sources of Wastewater Flows

       Q  Non-contact cooling
           Direct process contact
           Indirect process  contact
           Non-contact ancillary uses
           Maintenance, equipment cleaning and
           work area washdown
           'Air pollution control
           Sanitary/Potable water
           Storm water (collected in treatment
           system)
            Other
                Specify other_
                                                     III-l
                                                        B~9

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  ".    Method of Disposal of Process Wastewater (exclude non-contact  cooling water)
O Surface Water
£3 Subsurface
D deep Well
d Publicly Owned Treatment Works
D Land Application
D Recycle/Reuse
D Other
Treated
Average Flow
(Million gallons Time Period
per day) of Calculation







'





i
Untreated
Average Flow
(Hellion gallons Time Period
per day) of Calculation














                Specify other
E.
2.
Method of disposal of non-contact coolinq water
O Surface Water
f") Subsurface
Q Deep Well
C] Publicly Owned Treatment Works
D Land Application
LJ Recycle/Reuse
D Other
Specify other
Quality of Water Discharged
Average Flow
(Million gallons per day)



i

;
Time Period
of Calculation






j..
                                                31,  1976,  summarize your influent, effluent and raw waste loads  in
                           .. -, — ... „.  . ,,r plants  discharging directly to publicly owned waste treatment plants
      «o««n«%"h»"n^t«»all  raw WJSieJ°ad'   Jnf?rroation  for combined waste streams should be furnished which
      represents the greatest degree of detail  available.   The tables are located at the end of this section.
      Instructions for Completing Tables III A.  Ill B.  Ill  C and III 0
      shoruldbcorrespond with^hat^eTfo"^  II? "" f°110Win9 d-"»lt1«"s and ^  "»'<"*« "vered

      Sfpercln^f^S^fKlchT^rlSu^ II  Sff^fii''^^^^*1^ Si"?**"' ^^
     lo               n?  ?I Quantity -  The  value  for the highest 30 consecutive day average  over the period January 1 ,
     1975 to December 31, 1976 or over the actual  period of analysis if less than this  two year period.  The 30
     consecutive day period may be a calendar month or any other 30 consecutive day  period for values which are
     computed on a monthly basis.
A.

8.
                                                         °f a"y day'S "mples  1f' samples are taken  av <"• ""
     i«   « nh   •»     «          "mples are taken less frequently than  daily,  over  the period January 1,
     1975 to December 31, 1976 or over  the actual period of analysis if less  than this  two year period.
D.   Annual Average Quantity - The highest twelve consecutive month average over the period January 1, 1975 to
     December 31, 1976 or over the actual period of analysis If less than this  two year period.   If the period of
     analysis is less than one year, provide the average for the entire period  of analysis.
E.   Type of Sample - Insert a number from the following list in Tables III A,  III B,  III C, and III D to indicate
     we type of samples  collected.
          Type of Sample
          Flow cosiposlte
          Tine composite
          Grab
          Continuous
          Other
                                  Number
                                    1
                                    2
                                    3
                                    4
                                    5
                                                     III-Z
                                                             B-10

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F.   Frequency of Sample -  Insert a  number  from the following list in Tables III A, III B, III C and III.0.to
     indicate the frequncy  of samples  collected.
 G.
 H.

 I
 J.
Frequency
Continuously
Hourly
Daily
Weekly
Monthly
Less than once
per month
One time sample
Other
Number
1
2
3
4
5
6
7
8
Use the blank lines at the end of each  table  to  list  additional pollutants not specifically listed, which are
inlroduced into the wastewater as the result  of  materials  used or products produced, for which you have test
data.  (Exclude the chemicals listed in Table V  A of  Part  V of this portfolio.)

identify all data which results from abnormal operating  or other conditions.

If use of a different time period (a 'portion  of  the time period January  1. 1975 to December -31 , {"6) results

IS? WMSrlS ttmeWrexSlaln  wKy ^per^if ^^^^^ SScSl"
ment to this portfolio.

Tables

Table  III A - Complete a  separate Table III A for each plant intake water source  at  this  site.

Table  III B - Complete a  separate Table III  B for each untreated  waste discharge  point from this  site  (to
publicly  owned  treatment  works,  surface waters, deep Wells,  land  application, etc.).

Table  III C - Complete a  separate Table III  C for the combined influent to ea ch treatment facility on  this
site?  Not applicable  to plants  that have not yet  installed waste treatment facilities.  This section  is  not
restricted  by type or level  of treatment.

Table  III D - Complete a  separate Table III  0 for  the treated effluent ^om each  treatMnt/acilltt on this
 site  Not applicable  to plants that have not yet  installed waste treatment facilities.  This section is  not
 restricted  by  type or level  of treatment.

 So that you may have  sufficient tables to  report  the requested inf onrat ion, please £hptocw ea|h of. TjbJss.
 Ill A  III  B  III C and  III  0 before filling in.   A  separate table is required for each plant intake water
 siuHe.eachuHtreTted wastewater discharge^  this site, and the influent to and the effluent from each
 wastewater treatment facility on this  site.                                                      ,  ,     .
                                                         •irt-3   B-H

-------
                                                      TABLE III  A

                                                     INTAKE HATER

                   fnforaat1on- complete, to the best of your ability, a separate Table III  A for  each plant intake
Abbreviations:

ragd - Billion gallons  per day
ng/1 - milligrams  per  liter
Ib/day - pounds  per day

Photocopy  this  table  before filling In the requested  information
Parameter
Flow (inqd)
BOO 5 (nw/1)
BOO 5 Mb/day)
COO (mo/1)
COO ( Ib/davl
TSS fmo/1)
TSS (Ib/day)
TOC (BO/1)
TOC Ob/
-------
                                                     TABLE III  B

                                             UNTREATED WASTE DISCHARGE
                                                                                               ""
                                                                                                          ""
With the
site (to

Abbreviations:

mgd - million gallons  per  day
mg/1 - milligrams per  liter
.Ib/day - pounds per day

Photocopy this table before  filling  in the requested information

Percent Storm Water_
                                                                                                      Frequency
                                                                                                          of
                                                                                                       Sample
 Parameter
 Flow (mgd)
 BOO 5 (mg/1)

 BOD 5 (Ib/da;

 COD (mq/1)  .

 COD (Ib/day)

 TSS (mg/1)
Maximum
Monthly
Average
 uanti tv
                                                      III-5
                                                            B-13

-------
                                                      TABLE III C

                                                   COMBINED INFLUENT         i

                   fnf°'7ia"on'  complete a separate Table III  C for  the combined Influent to each treatment

                      '                                                                            "
norestrced    t

Abbreviations:

Bgd - nil lion gallons per day
eg/1 - Milligrams per liter
Ib/day - pounds per day

Photocopy this table before  filling 1n the requested Information.

Percent Storm Water
Parameter
Flow (mad)
800 5 (mo/1)
800 5 (Ib/day)
COO (»q/l)
COO (Ib/day)
TSS (M/l)
TSS (Ib/day)
TOC r«o/l)
IOC (Ib/day)
NltjN (mo/1)
NH,H (Ib/dav)
PH
Sul fides (mq/1)
Oil and Grease (mq/1)
Chromium (isg/1)

















Maximum
Monthly
Average
Quantity
































Maximum
Daily
Average
Quantity
































Annual
Average
Quantity

























. ,






TJme
Period
of
Analysis



























f: 	 SJ 	 ^


















Type
of
Sample
































Frequency
of
































                                                      B-14
                                               ni-6

-------
                                                       TABLE III 0
                                                    TREATED EFFLUENT

With the available information, complete a separate Table III D for the treated effluent from each treatment facility
on this site.  Not applicable to plants that have not yet installed waste treatment facilities.  This section is
not restricted by type or level of treatment-,

Abbreviations:

mgd - million gallons per day
mg/1 - milligrams per liter         v
Ib/day -pounds per-day

Photocopy this table before filling in the requested information.

Percent Storm Water	          '
Parameter
Flow (mqd)
BOD 5 (mg/1)
BOD 5 (Ib/day)
COD (mg/1)
COD (Ib/day)
TSS jmg/1)
TSS (Ib/day)
TOC (mg/1)
TOC (Ib/day)
NH,-N (mg/1)
— 3 	 ' *' i 	
NH,-N (Ib/day)
— 3 	 1 — ' ' 	
PH
Sulfides (mg/1)
Oil and Grease (mg/1)
Chromium (mq/1)



















Maximum
Monthly
Average
Quanti ty


































Maximum
Daily
Average
Quanti ty


































Annual
Average
Quanti ty






















Time
Period
of
Analysis






















Type
of
Sample









Freguency
of
Sample










i


















i
!




















i



















                                                            B-15

-------
3.   Indicate all  parameters  listed In Part III. Tables III A through  III  D,: which were not measured by EPA approved
     nethods.
     Has the seed  used  1n the BOO 5 test been acclimated to the waste waters that have been treated?
     Yes O        Nod
     If yes. what  Is  the source of the seed?
      Q  Sewage treatment plant
      C]  Plant treatment facility
      C]  Laboratory  acclimation                                           ;
      D  Other
          Explain	
                                                        B-16

-------
PART IV
A.    Do you have a treatment system(s)  at  this plant?        Yes Q
                                                                         No
                              ^
      For each  treatment facility complete the following:
      Name  of  Facility_
      Source(s) of Waste Water_
1.     Check which  of the  treatment  processes listed below are employed at this plant:
         Q Equalization
         Q Neutralization
         Q Coarse Settleable Solids  Removal
            Primary Separation
              n Primary Sedimentation
              Q Primary Chemical   Flocculation/Clarification
             Q Other
                      Specify Other	—	
            Biological Treatment
              Q Activated Sludge
              n Trickling Filter
              Qj Aerated  Lagoon
              Q Waste Stabilization Ponds
              Q Bio-Discs
              n Intermittent Sand  Filtration
              __ Other
                      Specify Other	
             Physical/Chemical  Treatment
             Polishing
               Q Pond
               rj Multi-media Filtration
               Q Activated Carbon
               Q Other
                       Specify Other	
             Sludge Handling
                  Thickening
                    Q Mechanical
                    n Flotation
                    Q Centrifugatioh
                  Stabilization
                    Q Anaerobic  Digestion
                    n Chemical
                    Q Heat
                     I  I Composting
                        Other
                             Specify Other
                                                                B-17

-------
                    Co nd ifion Ing
                     D "eat
                     Q Chemical
                     D Elutriation
                    Dewatering
                     O Vacuum Filtration
                     Q Centrifugation
                     D Drying Beds
                    D Other
                            Specify Other_
                   Reduction
                    f~|  Incineration
                    n  Wet  Air Oxidation
                    D  Pyrolysis
                   Final Disposal
                    D   Landfill
                    O   Cropland Use
                   D  Ocean
                   D  Other
                            Specify Other
 Design Conditions for overall  treatment facility
          Flow (million gallons per day)   	
          BOD (milligrams per liter)       	
          300 (pounds per day)
                                   TSS  (milligrams per liter)
                                   TSS  (pounds per day)
 2.   a.   Original  installation  (treatment only)
     b.   Other costs  (include collection system, piping, pumping, etc.)
 3.       Estimated replacement  cost
 4.       Estimated total capital expenditure for this facility to date
                                                                                    Year
                                                                                                Cost  (1976 dollars)
 5.
        Annual cost of operation and maintenance
        (exclude depreciation and debt service cost).
6.
                                              SlnCe  °rl91'nal  1"»"l«ion and state the purpose of the
Modification-Addition
Treatment
Facility
                                                       Year
    Cost  !
(1976 Dollhrs)
Purpose of
Modification
                                                     iv-a
                                                           B-18

-------
7.      list future scheduled modifications or additions  and  estimated  date  of  completion and  state the purpose of
        the modification or addition.
Modification-Addition
                                    Treatment
                                    Facility
                                                       Year
                                                                        Cost
                                                                    (1976 Dollars)
Purpose of
Modification
 8.       Is  nutrient addition practiced?          Yes Q          No Q
 9.       How many  employees  (equivalent man-years/year) are primarily engaged as operators of the waste water
         treatment facility?  (exclude maintenance)
         How many employees  (equivalent man-years/year) are engaged as support personnel for the waste water
         treatment facility?
10.
11.

12.
         Is an operator always present?           Yes Q         No Q
         Quantity of wastewater treatment facility solid wastes  disposed of  at present  (dry basis).
                    _ _  pounds  per day
         Moisture content of waste solids disposed of at present.
                                                       percent moisture.
 13.    Present disposition of solids
  14.      Estimated annual cost of solids handling and disposal (1976 dollars).

                               ...   	-   ..  	L__iJ  dollars per ton dry basis

  15.      Planned  future  disposition of  solids:
  16.      What are the total annual energy requirements for the treatment  facility?
                     Electrical             	_ kilowatt-hours
                     Other (e.g.. Heat)     '  "   	'.	British thermal .units
                                                        IV-3
                                                              B-19

-------
S.       Carbon Adsorption Technology



         Hive you  determined  carbon adsorption  Isotherms on your  waste waters?

         Have carbon  adsorption  isotherms been determined for waste waters from
         your plant(s)  by  a person(s) other than company personnel?           i

         Have you or  anyone else evaluated carbon columns on waste waters from this  plant?

         Do you have  carbon adsorption data from your plant(s) on:            i

              raw wastes                                                      '

              biologically  treated wastes                                     :

              individual process lines

              combined process lines                                          |

              pilot plant studies

             contractor evaluations                                          '

             cost evaluations

             plant scale evaluations

             operational units

        For each question above which was answered  affirmatively, give a brief description  of
        TVH0C Ar UJte +mr  nAw^MfJ **f *4__  ....	j   ^   ^  .    .  j           -     «•*••»*•! i p i. > VM  w i
                                              d, plant  involved, extent of da1
                                                                                              Yes
                                                                                              D
                                                                                              a

                                                                                              a
                                                                                              a
                                                                                              a
                                                                                              a
                                                                                              a
                                                                                              a
                                                                                              a
                                                                                              a
                                                                                              a
                                                                                              a
                                                                                              a
 No
 a
 a
.a
 a
 a
 a
 a
 a
 a
 a
 a
 a
 a
                                                                                                               , j
                                                                                                               and
C.        Filtration
                       NO
                                          °" y°"r wastewate" 
-------
£         Have other treatability studies,  beyond what  was  described  in  Section A,  Part  IV, employing treatment
          processes such as sedimentation,  neutralization,  hydrolysis, precipitation, oxidation/reduction, ion
          exchange, phenol recovery, etc.,  been run  on  any  of  the  process wastewater streams from the plant?

          Yes n       No Q

          If yes, list below those product/process  streams  on  which such treatability studies were conducted.
 Note:
Use the Engineering News-Record (ENR)  Index to project costs  to  December  1976  Dollars where requested
in this portfolio.  ENR Indices for January 1964 through December 1976  are  shown on page  IV-6 of this
portfolio.-   ,
                                                              IV-5
                                                                   B-21

-------
PART V


PRIORITY POLLUTANTS


A.   Please provide the information  requested in Table V A, concerning the chemicals which are considered as priority
     pollutants and which  are  listed  in Table V A, in conformance with the folowing instructions:           Priority


                                     '° 1nd1cate a11 of the 11sted
B.
C.
1.
3'
0.
 MteHaT A'
                                                                                   g instructions:


                                                                             ijhich are used as raw or intermediate
  2.    In column B, place a check mark to indicate all  of the listed  chemicals which are manufactured at this  plant
       as a final or.intermediate material.


  3.    In column C, place a check mark to indicate all  of the listed  chemicals for which you have analyzed in  your
       wastewater.                                                             ,                              J


  4.    In column 0, insert a number from the following  list.to  indicate the frequency that the influent (I)  and
       effluent (E) In your wastewater is analyzed for  the presence of the listed chemicals.
Frequency
Continuously
Hourly
Dally
Weekly
Monthly
Less than once per
One time sample
Other
Number :
1 • •• !
2 j
3 ;
4 :
5 !
month 6
)•:. • .,.,•,.
.7 '
8
5" m°!?l7!!Ji ln?tr* ».number fr8fll th* following list to indicate the typelof sample used to analyze the influent
(I) and effluent (E) In your wastewater for the presence of the listed chemicals.
Type of Sample
Flow Composite
Time Composite
Grab
Continuous
Other
Number
1 :
2
3 ' i
4 :
5 ' - ' i
 6.    In columns F, G, and H, insert a value to indicate the  average  loading per day as pounds per day (Ib/day)

      ~™9S<  ?** aJ m
-------
                                                                                                      TABLE V A

                                                                              PROCESSING OF CHEMICALS CONSIDERED AS PRIORITY POLLUTANTS
Merck
CAS Index
Number Number Chemical
1. 83-32-9 19 acenaphthene
2. 107-02-8 123 acrolein
3. 107-13-1 127 acrylonitrile
4. 71-43-2 1069 benzene
5. 92-87-5 1083 benzidine
6. 56-23-5 1821 carbon tetrachloride (tetr&chloromethane)
7. 108-90-7 2095 chlorobenzene
8. 120-82-1 9310 1,2,4-trichlorobenzene
9. 118-74-1 4544 hexachlorobenzene
10. 107-06-2 3733 1,2-dichloroethane
11. 71-55-6 9316 1,1,1-trichloroethane
12. 67-72-1 4545 hexachloroethane
13. 75-34-3 3750 1,1-dichloroethane
14. 79-00-5 9317 1,1,2,-trichloroethane
15. 79-34-5 8906 1, 1 ,2, 2- tetrachloroe thane
16. 75-00-3 3713 chloroethane
17. 542-88-1 3046 bis(chloromethyl) ether
18. 111-44-4 3040 bis (2-chloroethyl) ether
19. 110-75-8 2119 2-chloroethyl vinyl ether (nixed)
20. 91-58-7 2127 2-chloronaphthalene
21. 88-06-2 9323 2,4,6-trichlorophenol
22. 59-50-7 2108 parachlorometa cresol
23. 67-66-3 21.20 chloroform (trichloromethnne)
24. 95-57-8 2134 2-chlorophenol
25. 95-50-1 3029 1,2-dichlorobenzene
26. 541-73-1 3028 1,3-dichlorobenzene
27. 106-46-7 3030 1 , 4-dichlorobenzene
28. 91-94-1 3032 3,3'-dichlorobenzidine
29. 75-35-4 9647 1,1-dichloroethylene
30. 540-59-0 85 1,2- trans-dichloroethylene
A B C D E F C PI
Raw or
Inter-
mediate














1 "V
















Final or
Inter-
mediate































Analyzed
in































Frequency
Analyzed






























































Type
Sample


























	










'























Loading
(Ib/day)
I •






























E""






























Flow
•lillion Gallons
I *






























E"






























Ooncun-
tral ion
(|H/1 )
I *






























fr






























DO
u>
       •  I • Influent
       " E - Effluent

-------
                                                                                          TABLE V A
                                                                     FMXZ33IH5 or WDUCAIS CONSIDERED AS rmoun rouurwrs
Korek
CAS Index
Hu»toer murtxir Chwdcal
31. 	 2,4-diehlorophenol
32. 78-87-5 7643 1,2-dichloropropana
33. 542-75-6 3051 1,3-dichloropropylena (1,3-dlchloropropeno)
34. 1300-71-6 9744 2,4-dinethylphonol
35. 	 2,4-dinitrotoluene
36. 	 2f6-dinitrotoluene
37. 	 1,2-dlphenylhydrazine
38. 100-41-4 369S ethylbenzene
39. 	 fluoranthene
40. 	 4-chlorophenyl phenyl ether
41. 	 4-bromophenyl phenyl ether
42. 	 bls(2-chloroiuopropyl) ether
43. 	 bis(2-chloroethyoxy) methane
44. 75-09-2 5932 methylene chloride (dlchloronethane)
45. 74-87-3 5916 nethyl chloride (chloromethane)
46. 74-83-9 5904 methyl bromide (bronomethane)
47. 75-25-2 1418 bronoform (tribromoraethonu)
48. 	 dichlorobromomethane
49. 75-69-4 9320 trichlorofluoromethane
50. 75-71-8 3038 dichlorodifluoromethane
51. 	 chlorodibroraome thane
52. 	 hexachlorobutadiene
53. 	 hexachlorocyclopentadiene
54. 	 ioophorone
55. 91-20-3 6194 naphthalene
56. 98-95-3 6409 nitrobenzene
57. 88-75-5 6442 2-nitrophenol
58. 100-02-7 6443 4-nitrophenol
59. 51-28-5 3277 2,4-dinitrophenol
60. 534-52-1 3275 4 ,6-dinitro-o-cresol
Raw or
Intur-
Mdiate
Material






























Final or
Intar-
Mdl«t«
Material






























Analyzed
In
Wa»ceuat«r






























rrcq
Ana!
!•






























u>»ncy
E~"








*





















T>
Sat
I •






























P«
•Ei«_
E"




















•









U»dln9
(Ib/dw)
I •






























c •






























riou
HI 11 Ion ttallon*
/Day
I •






























E "






























Concen-
tration
il>g/D
I •






























E"






























oo
     •  I - Influent
     **  E = Effluent

-------
                                                                                          TABUS V A

                                                                   PROCESSING OF CHEMICALS CONSIDERED AS PRIORITY POLLUTANTS

                                                                               A         8
Merck
CAS Index
Htmber Number Chemical
61. 62-75-9 6458 H-nitrosodimethylamine
62. 	 N-nitrpsodiphenylamine
63. 	 	 N-nitro30di-n-propylami.ne
64. 87-86-5 6901 pentachlorophenol
65. 108-95-2 7038 phenol
66. 117-81-7 1270 bto(2-ethyl!iexyl) phthalate
67. 	 butyl benzyl phthalate
68. 84-74-2 1575 dl-n-butyl phthalate
69. dl-n-octyl phthalate
70. 84-66-2 3783 diethyl phthalate
71 131 -11-3 3244 dimethyl phthalate
72. 56-55-3 1063 1,2-benzanthracene
•f 73. 50-32-8 1113 benzo (a)pyrene (3,4-benzopyrene)
74. 	 3,4-benzofluoranthene
CO — 	 ' 	 	 	 	 ' •
I 75. 	 11, 12-benzof luoranthene
01 76. 218-01-9 2252 chrysene
77. 	 acenaphthylene .
78. 120-12-7 718 anthracene
79 	 1,12-benzoperylene
80. 86-73-7 4037 fluorene
81. 85-01-8 6996 phenanthrene
82. 53-70-3 2971 l,2:5,6-dibenzanthracene
83. 	 indeno(l,2,3-C,D) pyrene
84. 129-00-0 7746 pyrene
85. 127-18-4 8907 tetrachloroethylene
86. 108-88-3 9225 toluene
87. .79-01-6 9319 trichloroethylene
88. 75-01-4 9645 vinyl chloride (chloroethylene)
89. 309-00-2 220 aldrin
90. 60-57-1 3075 dieldrin
Raw or
Inter-
mediate
Material


























' ,. ...



Final or
Inter-
Riediate
Material
















'










>.


Analyzed
in
Hastewater






























Frequency
Anal zed
I *






























E*«








*





















Ty
_Sam|
I*






























36
pie
E**






























Loading
(Ib day)
I*






























E**






























Flow
Million Gallons
/Day
I *






























E"






























Concen-
tration

-------
                                                                                                    TAKLE V A

                                                                              I'M* tSSJMC OF OltmCALS UJtBIW.RiO AS PRIORITY POtUTfAJfTS
CAS Index
Nimbftr Huttb*r Chenicdl
91. 57-74-9 20S1 chlordano (technical Mixture aitd mttabolltea)
92. 50-29-3 2822 4,4'-DDT
93. 	 4,4'-DBE (p,p'-DOX)
94. 6088-51-3 2821 4,4'-DDB (p.p'-TDK)
95. 115-29-7 3519 alpha-endosulfan
96. 115-29-7 3519 beta-endooulfan
97. 	 endosulfan sulfate
98. 72-20-8 3522 endrin
99. 	 endrin aldehyde
100. 76-44-8 4514 heptachlor
101. 	 . heptachlor cpoxide
102. 58-89-9 5341 alpha-BIIC
< 103. 58-89-9 5341 beta-BIIC
104. 58-89-9 5341 gamma-BHC (lindane)
105. 58-89-9 5341 delta-BHC
J — 	 	 — — 	 — 	
n 106. 	 PCB-1242 (Arochlor 1242) :
107. 	 PCB-1254 (Arochlor 1254)
108. 	 PCB-1221 (Arochlor 1221)
109. 	 PCB-1232 (Arochlor 1232)

110. 	 PCB-1248 (Arochlor 1248)
111. 	 PCB-1260 (Arochlor 1260)
112. 	 TCB-1016 (Arochlor 1016)
113. 8001-35-2 9252 Toxaphene
114., 7440-36-0 729 Antimony (Total)
115.;- 7440-38-2 820 Arsenic (Total)
116. 850 Asbestos (Fibrous) :
117. 7440-41-7 1184 Beryllium (Total)
118. 7440-43-9 1600 Cadmium (Total) 1 I
119. 7440-47-3 2229 iChromium (Total) . ,:
120. 7440-50-8 2436 . Copper (Total) =
A
flaw or
Intur-
•ocllat*
HjtorUl































B
final or
Inter-
Mxllata
Halerlal































C
Analyzed
in
Wascwater































— o e r r.
Pre<
Ana































uemcy
vied
£••































Tl
^2!



























!



fpc'
TJB
E*































Ixwi ding
I * ('~— i*.... ^^






























































f
Hill ir































'lev
Uf
_ 	 Jill.






























Conccn-
t r.il Ion
(|M/I )































	 6"






























*  I •= Influent ,
*• E = Effluent

-------
                                                                                                   TABLE V A


                                                                           PROCESSING OP CHEMICALS CONSIDERED AS PRIORITY POLLUTANTS
Merck
CAS Index
Number Number Chemical
121. 420-05-3 2694 Cyanide (Total)
122. 7439-92-1 5242 Lead (Total)
123. 7439-97-6 5742 Mercury (Total)
124. 6312 Nickel (Total)
125. 7782-49-2 8179 SeleniuH (Total)
126. 7440-22-4 8244 Silver (Total
127. 7440-28-0 B970 Thallium (Total)
128. 7440-66-6 9782 Zinc (Total)
129. 	 2,3,7,8 - tetr»chlorodibenzo-p-dioxin (TCDD)
A B C D E
Raw or
Inter-
mediate









Final or
Inter-
mediate









Analyzed
in









Freq
Anal









jency
zed









Type
Sample









-








t C
Loading
(Ib/day)


















Fli
Million
/D
I*









JW
Gallons
V
E**









H ,. _
Com
tra
T— S









:en-
tion
jq/i) —
E*









   •  I - Influent
   • • E • Effluent
00
I
ro

-------
ro
cx>

YEAR
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976

Jan.
917.94
947.56
987.94
1039.05
1107.37
1216.13
1308.61
1465.07
1685.72
1837.87
1939.47
2103.00
2300.42

Feb.
920.40
957.43
997.43
1040.67
1113.63
1229.56
1310.90
1466.85
1690J6
1849.70
1939.74
2127.72
23.09.97

Mar.
922.41
957.70
998.32
1043.31
1117.15
1238.14
1314.45
1494.06
_JL696.68
1858.96
1940.19
2127.65
2317.14
EN
Apr.
926.27
957.43
1006.06
1043.54
1123.73
1248.85
1329.21
1511.49
1706. 89
1873.62
1961.25
2135.03
2327.33
G INHERING
May
929.74
957.92
1014.03
1059.20
1140.31
1258.33
1345.36
1542.95
_JL735.15_
1880.26
1960.88
2163.72
2356.76
NEWS - REC
June
935.42
969.34
1028.65
1067.88
1152.78
1284.96
1368.66
1575.05
__1760,75j
1896.21
1993.47
2205.00
2409.51
!ORD (ENR)
July
944.97
977.08
1030.56
1078.45
1159.04
1282.77
1413.91
1597.80
_177L.56_
1901.24
2041.36
2247.65
2413.60
INDICES *
Aug.
947.92
984.16
1033.37
1089.14
1169.68
1292.20
1418.44
1614.78
-J1776.-80-
1920.79
2075.49
2274.30
2444.94

Sept.
947.36
986.29
1033.72
1092.22
1184.20
1285.29
1422.54
1639.64
0785,29
1929.03
2088.82
2275.34
2468.38 '-.

Oct.
947.74
986.18
1032.40
1096.22
1189.08
1299.31
1433.64
1642.59
-17-93,75-
1933.19
2094.74
2293.03
2478.22

1 Nov.
948.25
985.83
1032.71
1096.74
1190.73
1305.23
1445.13
1644.06
-1-807 ,-60
1934.85
2094.06
2291.65
2486.32

Dec.
948.12
987.74
1033.71
1098.39
1200.82
1304.76
1445.08
1654.75
1815-.86--
1938.84
2098.26
2297.15
2489.66

ANNUAL
( INDEX
936.38
971.22
1019.08
1070.40
1154.04
1270.46
1379.66
1570.57
—175-2^23
1896.74
2019.31
2211.77
2399.94
          *  CONSTRUCTION COST INDEX - BASE YEAR 1913=100

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              APPENDIX C

Pharmaceutical Manufacturing Plants in the
         Original 308 Data Base

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                           APPENDIX C
               PHARMACEUTICAL MANUFACTURING PLANTS
                             IN THE
                     ORIGINAL 308 DATA BASE
NAME

A. H. ROBINS COMPANY
A. H. ROBINS MANUFACTURING COMPANY
ABBOTT LABORATORIES
ABBOTT LABORATORIES
ABBOTT LABORATORIES - N. CHICAGO
ABBOTT: HOSPITAL PRODUCTS DIVISION
ABBOTT: MURINE COMPANY
ABBOTT: SCIENTIFIC PRODUCTS DIVISION
AHSC: DADE DIVISION
AHSC: HARLECO DIVISION
ALCON LABORATORIES (P.R.). INC.
ALCON LABORATORIES - OPHTHALMIC
ALCON: CENTER LABORATORIES, INC.
ALCON: OWEN LABORATORIES, INC.
ALZA CORPORATION
ALZA CORPORATION - BUILDING A
ALZA CORPORATION - BUILDING J
AMERICAN CYANAMID COMPANY
AMES COMPANY
AMES IMMUNOLOGY MANUFACTURING DIV.
ARBROOK  INC
ARMOUR PHARMACEUTICAL COMPANY
ARNAR-STONE LABORATORIES, INC.
ARNAR-STONE, INC.
ASTRA PHARMACEUTICAL PRODUCTS, INC.
AYERST LABORATORIES,  INC.
BARNES-HIND DIAGNOSTICS, INC.
BARNES-HIND PHARMACEUTICALS, INC.
BARRY LABORATORIES, INC.
BEECHAM LABORATORIES
BEECHAM PHARMACEUTICALS
BIO-REAGENTS AND DIAGNOSTICS, INC.
BLOCK DRUG COMPANY, INC.
BLOCK DRUG COMPANY, INC.
BOWMAN PHARMACEUTICALS, INC.
BRISTOL ALPHA AND BRISCHEM
BRISTOL LABORATORIES CORP.
BRISTOL-MYERS PRODUCTS
BRISTOL-MYERS PRODUCTS
BRISTOL-MYERS: IND. & BRISTOL LABS.
LOCATION

RICHMOND
BARCELONETA
BARCELONETA
NORTH CHICAGO
NORTH CHICAGO
ROCKY MOUNT
CHICAGO
LOS ANGELES
MIAMI
GIBBSTOWN
HUMACAO
FORT WORTH
PORT WASHINGTON
ADDISON
PALO ALTO
PALO ALTO
PALO ALTO
HANNIBAL
SOUTH BEND
ELKHART
ARLINGTON
KANKAKEE
MT. PROSPECT
AGUADILLA
WORCESTER
ROUSES POINT
CANOVANAS
SUNNYVALE
POMPANO BEACH
BRISTOL
PISCATAWAY
IRVINE
JERSEY CITY
MEMPHIS
CANTON
BARCELONETA
MAYAGUEZ
HILLSIDE
ST. LOUIS
EAST SYRACUSE
VA
PR
PR
IL
IL
NC
IL
CA
FL
NJ
PR
TX
NY
TX
CA
CA
CA
MO
IN
IN
TX
IL
IL
PR
MA
NY
PR
CA
FL
TN
NJ
CA
NJ
TN
OH
PR
PR
NJ
MO
NY
                               C-l

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BURDICK & JACKSON LABORATORIES,  INC.
BURROUGHS WELLCOME  COMPANY
BURROUGHS WELLCOME: VACCINE DIVISION
BYK-GULDEN,  INC.
BYK-GULDEN:  DAY-BALDWIN DIVISION
CARTER-WALLACE,  INC.
CARTER-WALLACE:  DENV. CHEM. (P.R.)
CENTRAL PHARMACAL COMPANY
CERTIFIED LABORATORIES, INC.
CIBA-GEIGY CORPORATION
CIBA-GEIGY CORPORATION
CIBA-GEIGY CORPORATION
CONNAUGHT LABORATORIES, INC.
COOPER LABORATORIES  (P.R.), INC.
COOPER LABORATORIES  (P.R.): SMP  DIV.
COOPER LABORATORIES: WAYNE OLD DIV.
CUTTER LABORATORIES, INC.
CUTTER LABORATORIES, INC.
CUTTER LABORATORIES, INC.
CUTTER LABORATORIES, INC.
CUTTER LABORATORIES: BAYVET DIVISION
DADE DIAGNOSTICS, INC.
DAVIS AND GECK,  INC.
DENTCO, INC.
DOME LABORATORIES DIVISION
DORSEY LABORATORIES DIVISION
DOW PHARMACEUTICALS
E. R. SQUIBB AND SONS, INC.
E. R. SQUIBB MANUFACTURING, INC.
EATON LABORATORIES, INC.
ELI LILLY - CLINTON LABS.
ELI LILLY -  INDUSTRIAL CIR. 1200
ELI LILLY - OMAHA LABS
ELI LILLY - PARK FLETCHER
ELI LILLY - TIPPECANOE LABS.
ELI LILLY AND COMPANY
ELI LILLY AND COMPANY
ELI LILLY AND COMPANY
ELI LILLY AND COMPANY
ELI LILLY INDUSTRIES
ENDO LABORATORIES, INC.
ENDO, INC.
FERNDALE LABORATORIES, INC.
FIRST TEXAS PHARMACEUTICALS, INC.
HILTON DAVIS CHEMICAL COMPANY
HOECHST-ROUSSEL PHARMACEUTICALS, INC.
HOFFMANN-LA ROCHE - AG. DIVISION
HOFFMANN-LA ROCHE, INC.
HOFFMANN-LA ROCHE, INC.
HOFFMANN-LA ROCHE, INC.
MUSKEGON
GREENVILLE
DENVER
HICKSVILLE
HILLSIDE
CRANBURY
HUMACAO
SEYMOUR
WARRINGTON
CRANSTON
SU^FERN
SUMMIT
SWIFTWATER
SAN GERMAN
PALO ALTO
WAYNE
BERKELEY
CHATTANOOGA
CLAYTON
OGDEN
SHAWNEE
AGUADA
MANATI
HUMACAO
WEST HAVEN
LINCOLN
INDIANAPOLIS
NEW BRUNSWICK
HUMACAO
MANATI
CLINTON
INDIANAPOLIS
OMAHA
INDIANAPOLIS
LAFAYETTE
CAROLINA
GREENFIELD
INDIANAPOLIS
MAYAGUEZ
CAROLINA
GARDEN CITY
MANATI
FERNDALE
DALLAS
CINCINNATI
SOMERVILLE
FORT WORTH
AMES
BELVIDERE
FRESNO
MI
NC
CO
NY
NJ
NJ
PR
IN
PA
RI
NY
NJ
PA
PR
CA
NJ
CA
TN
NC
UT
KS
PR
PR
PR
CT
NE
IN
NJ
IN
IN
NE
IN
IN
PR
IN
IN
PR
PR
NY
PR
MI
TX
OH
NJ
TX
IA
NJ
CA
                                C-2

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HOFFMANN-LA ROCHE, INC.
HOFFMANN-LA ROCHE, INC.
HOFFMANN-LA ROCHE, INC.
HOLLISTER-STIER LABORATORIES
HYNSON, WESTCOTT, & DUNNING DIVISION
ICI AMERICAS, INC.
IMC, INC.
INOLEX CORPORATION: PHARM. DIVISION
IVERS-LEE DIVISION
IVERS-LEE DIVISION
IVERS-LEE .DIVISION
J. T. BAKER CHEMICAL COMPANY
J. T. CLARK COMPANY
JELCO LABORATORIES, INC.
JELCO LABORATORIES, INC.
JENSEN-SALSBERY LABORATORIES
JENSEN-SALSBERY LABORATORIES
JOHNSON AND JOHNSON
JOHNSON AND JOHNSON
JOHNSON AND JOHNSON
JOHNSON AND JOHNSON
JOHNSON AND JOHNSON D.O.C., INC.
KNOLL PHARMACEUTICAL COMPANY
KREMERS-URBAN COMPANY
LEDERLE LABORATORIES DIVISION
LEHN AND FINK PRODUCTS COMPANY
              INC.
              INC.
              INC. - BULK LYSATE
              INC. - NUCLEAR
                   - RALEIGH CHEMICAL
                   - RALEIGH PARENT.
              INC. - RALEIGH PLASTICS
                          INC.
                      EAST. SURG. DR.
                      MIDWEST SUR. DR.
                      SW. SURG. DRESS.
MALLINCKRODT,
MALLINCKRODT,
MALLINCKRODT,
MALLINCKRODT,
MALLINCKRODT, INC.
MALLINCKRODT, INC.
MALLINCKRODT,
MARION HEALTH AND SAFETY,
MARION LABORATORIES, INC.
MCGRAW LABORATORIES
MCGRAW LABORATORIES
MCGRAW LABORATORIES
MCGRAW LABORATORIES
MCNEIL LABORATORIES, INC.
MCNEIL LABORATORIES, INC.
MEAD JOHNSON AND COMPANY
MEDIPHYSICS, INC.
MEDIPHYSICS, INC.
MEDIPHYSICS, INC.
MEDIPHYSICS, INC.
MEDIPHYSICS, INC.
MERCK AND CO., INC.
MERCK AND CO., INC. - CHEROKEE
MERCK AND CO., INC. - FLINT RIVER
NUTLEY
SALISBURY
TOTOWA
SPOKANE
BALTIMORE
DIGHTON
TERRE HAUTE
PARK FOREST SOUTH
NEWARK
SHIPSHEWANA
WEST CALDWELL
PHILLIPSBURG
GENEVA
RARITAN
RIVIERA BEACH
KANSAS CITY
KANSAS CITY
NORTH BRUNSWICK
NORTH BRUNSWICK
CHICAGO
SHERMAN
GURABO
WHIPPANY
MEQUON
PEARL RIVER
LINCOLN
DECATUR
ST. LOUIS
BEAUFORT
MARYLAND HEIGHTS
RALEIGH
RALEIGH
RALEIGH
ROCKFORD
KANSAS CITY
IRVINE
IRVINE
MILLEDGEVILLE
SABANA GRANDE
DORADO
FORT WASHINGTON
EVANSVILLE
EMERYVILLE
GLENDALE
MIAMI LAKES
ROSEMONT
SOUTH PLAINFIELD
RAHWAY
DANVILLE
ALBANY
NJ
MD
NJ
WA
MD
MA
IN
IL
NJ
IN
NJ
NJ
IL
NJ
FL
KS
MO
NJ
NJ
IL
TX
PR
NJ
WI
NY
IL
IL
MO
NC
MO
NC
NC
NC
IL
MO
CA
CA
GA
PR
PR
PA
IN
CA
CA
FL
IL
NJ
NJ
PA
GA
                                C-3

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DIV. - NORWICH
DIV. - W'DS CORNER
DIVISION
 MERCK AND CO., INC. - STONEWALL
 MERCK SHARP AND DOHME, INC.
 MERCK SHARP AND DOHME (P.R.),  INC.
 MERRELL-NATIONAL LABORATORIES,  INC.
 MERRELL-NATIONAL LABORATORIES,  INC.
 MILES LABORATORIES, INC.
 NORWICH-EATON PHARM
 NORWICH-EATON PHARM
 NORWICH-EATON PHARM
 ORGANON,  INC.
 ORTHO DIAGNOSTICS,  INC.
 ORTHO DIAGNOSTICS,  INC.
 ORTHO PHARMACEUTICALS, INC.
 PARKE-DAVIS AND COMPANY
 PARKE-DAVIS AND COMPANY
 PARKE-DAVIS AND COMPANY
 PARKE-DAVIS AND COMPANY
 PARKE-DAVIS LABORATORIES
 PENNWALT  CORPORATION
 PFIZER PHARMACEUTICALS, INC.
 PFIZER, INC.
 PFIZER, INC.
 PFIZER, INC. - MAYW'D CANCER RES'RCH
 PFIZER, INC. - VIGO
 PHARMASEAL  LABORATORIES
 PHILIPS ROXANE LABORATORIES, INC.
 PLOUGH, INC.
 PURDUE FREDERICK LABORATORIES,  INC.
 R. P.  SCHERER  (MIDWEST) CORP.
 R. P.  SCHERER  (SOUTHEAST) CORP.
 REEDCO, INC.
 REHEIS CHEMICAL COMPANY
 RIKER  LABORATORIES,  INC.
 ROSS LABORATORIES
 ROSS LABORATORIES
 S. B.  PENICK AND COMPANY
 S. B.  PENICK AND COMPANY
 S. B.  PENICK AND COMPANY
 S. B.  PENICK AND COMPANY
 S. B.  PENICK AND COMPANY
 SANDOZ, INC.
 SCHERING  (P.R.)  CORPORATION
 SCHERING CORPORATION
 SCHERING-PLOUGH  CORPORATION
SCHERING:  AMERICAN SCIENTIFIC LABS.
SEARLE AND COMPANY
SEARLE LABORATORIES
SMITHKLINE AND FRENCH COMPANY
SMITHKLINE AND FRENCH LABORATORIES
SMITHKLINE AND FRENCH LABORATORIES
 ELKTON
 WEST POINT
 BARCELONETA
 CAYEY
 CINCINNATI
 ELKHART
 NORWICH
 NORWICH
 GREENVILLE
 WEST ORANGE
 ARLINGTON
 RARITAN
 DORADO
 DETROIT
 GREENWOOD
 HOLLAND
 ROCHESTER
 FAJARDO
 ROCHESTER
 BARCELONETA
 BROOKLYN
 GROTON
 MAYWOOD
 TERRE  HAUTE
 IRWINDALE
 COLUMBUS
 MEMPHIS
 TOTOWA
 DETROIT
 MONROE
 HUMACAO
 BERKELEY  HEIGHTS
 NORTHRIDGE
 ALTAVISTA
 COLUMBUS
 LYNDHURST
 MONTVILLE
 NEWARK
 VANCOUVER
 WALLINGFORD
 EAST HANOVER
 MANATI
 UNION
 KENILWORTH
MADISON
CAGUAS
SKOKIE
CAROLINA
PHILADELPHIA
SWEPELAND
 VA
 PA
 PR
 PR
 OH
 IN
 NY
 NY
 SC
 NJ
 TX
 NJ
 PR
 MI
 SC
 MI
 MI
 PR
 NY
 PR
 NY
 CT
 NJ
 IN
 CA
 OH
 TN
 NJ
 MI
 NC
 PR
 NJ
 CA
 VA
 OH
 NJ
 NJ
 NJ
 WA
 CT
 NJ
 PR
 NJ
 NJ
WI
 PR
 IL
PR
PA
PA
          C-4

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SMITHKLINE CORPORATION
SMITHKLINE: NORDEN LABORATORIES
SMITHKLINE: SEA AND SKI CORP.
STERLING DRUG, INC.
               INC.
               INC.
               INC.
               INC.
               INC.
               INC. - EAST GREENBUSH
               INC.
STERLING DRUG,
STERLING DRUG,
STERLING DRUG,
STERLING DRUG,
STERLING DRUG,
STERLING DRUG,
STERLING DRUG,
STERWIN LABORATORIES, INC.
STERWIN LABORATORIES, INC.
STUART PHARMACEUTICALS DIVISION
STUART PHARMACEUTICALS DIVISION
SYNTEX (P.P.), INC.
SYNTEX AGRIBUSINESS, INC.
SYNTEX LABORATORIES, INC.
TENNECO CHEMICALS, INC.
TRAVENOL LABORATORIES, INC.
TRAVENOL LABORATORIES, INC.
TRAVENOL LABORATORIES, INC.
TRAVENOL LABORATORIES, INC.
TRAVENOL LABORATORIES, INC.
TRAVENOL LABORATORIES, INC.
TRAVENOL LABORATORIES, INC.
TRAVENOL LABORATORIES, INC.
TRAVENOL: CLINICAL ASSAYS
          DAYTON FLEXIBLE PROD.
          HYLAND DIVISION
          HYLAND DIVISION
          HYLAND DIVISION
                                DIV.
TRAVENOL
TRAVENOL
TRAVENOL
TRAVENOL
UPJOHN COMPANY
UPJOHN COMPANY
UPJOHN COMPANY
USV LABORATORIES
USV PHARMACEUTICAL CORP.
VICKS HEALTH CARE DIVISION
VICKS HEALTH CARE DIVISION
VICKS RESEARCH AND DEVELOPMENT DIV.
WARNER-CHILCOTT DIVISION
WARNER-CHILCOTT LABORATORIES
WARNER-CHILCOTT PHARMACEUTICAL CO.
WARREN-TEED LABORATORIES, INC.
WARREN-TEED, INC.
WESTWOOD PHARMACEUTICALS, INC.
WILLIAM H. RORER, INC.
WILLIAM H. RORER, INC.
WILLIAM P. POYTHRESS AND CO., INC.
WINTHROP LABORATORIES, INC.
LOWELL
LINCOLN
RENO
GULFPORT
MONTICELLO
MYERSTOWN
MYERSTOWN
RENSSELAER
TRENTON
RENSSELAER
MCPHERSON
MILLSBORO
OPELIKA
NEWARK
PASADENA
HUMACAO
DES MOINES
PALO ALTO
GARFIELD
CAROLINA
CLEVELAND
COSTA MESA
JAYUYA
MARICAO
MARION
MORTON GROVE
MOUNTAIN HOME
CAMBRIDGE
KINGSTREE
GLENDALE
LOS ANGELES
ROUND LAKE
ARECIBO
KALAMAZOO
KALAMAZOO
MANATI
TUCKAHOE
GREENSBORO
HATBORO
MT. VERNON
MORRIS PLAINS
CAROLINA
VEGA BAJA
COLUMBUS
HUMACAO
BUFFALO
FORT WASHINGTON
SAN LEANDRO
RICHMOND
BARCELONETA
AR
NE
NV
MS
IL
PA
PA
NY
NJ
NY
KS
DE
AL
DE
CA
PR
IA
CA
NJ
PR
MS
CA
PR
PR
NC
IL
AR
MA
SC
CA
CA
IL
PR
MI
MI
PR
NY
NC
PA
NY
NJ
PR
PR
OH
PR
NY
PA
CA
VA
PR
                               C-5

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WYETH LABORATORIES, INC.
WYETH LABORATORIES, INC.
WYETH LABORATORIES, INC.
WYETH LABORATORIES, INC.
- GR. VALLEY
MARIETTA
SKOKIE
WEST CHESTER
MALVERN
PA
IL
PA
PA
TOTAL NUMBER OF MFG. PLANTS IN THE ORIGINAL 308 DATA BASE:   244
                               Cr-6

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r
                                          APPENDIX D

                                 Supplemental 308 Portfolio for the
                               Pharmaceutical Manufacturing Industry

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                          SUPPLEMENTAL  308  PORTFOLIO
                                    FOR THE
                     PHARMACEUTICAL MANUFACTURING  INDUSTRY
Instructions

1,   Please complete the following portfolio and return within 30 days
     of receipt to:

                    Mr. Robert B.  Schaffer, Director
                    Effluent Guidelines Division
                    U.S. EPA (WH-552)
                    401 M. Street, S.W.   '
                    Washington, D.C. 20460

                    Attention:  J. S. Vital is

2.   Please read all instructions and questions carefully before completing
     this portfolio.   It is preferred that the individual(s) who responds
     to this portfolio  be familiar with manufacturing processes and
     wastewater treatment operations at the plant.

3.   Please check  the  appropriate box or  boxes in each question where
     they appear throughout this portfolio.   (More than one box may be
     checked for some  questions, where appropriate.)  Please complete
     all questions which require written  responses by printing or typing
     in the spaces provided.

4.   Please indicate which  information in your responses is confidential
     so that it may be treated  properly.

5.   The U.S.  Environmental Protection Agency will review the  information
     submitted and may, at  a  later  date,  request your cooperation for
     site  visits and additional sampling  in order to complete  the data
     base.  Please retain a copy  of the completed portfolio in case
     future contact is necessary  to verify your  responses.

6.   If you have any questions, please telephone  Mr. J.  S.  Vitalis at
     202-426-2497.
                                     D-l

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  PART I
  GENERAL INFORMATION
  1.   Kame of Plant	
  2.   Address of Plant:
                                                                                       FORM APPROVED
                                                                                       OMB No.  158-R0160
                                                                                       PLANT CODE NO.	
                                                                                       (For EPA Use OnTyT
  3.    Hame of Parent Firm
                                               City
                                                                           State
  4.    Address  of Parent  Firm Headquarters:
                                                                                                   Tip-
                   Street~   city~Stati~~	Hp	
  5.   HaBHs(s) of plant personnel to be contacted for Information pertaining to this data collection  portfolio:
                                                      T1t1e                  !          (Area  Code) Telephone
 PART II
 PLAHT DATA
 1.
      a.
      "'
           Does this plant manufacture or formulate pharmaceutical  active  ingredients?
           (Research and development activities should not be  considered.)    i
           rLt?nde?5Srthis(piifoTTo.PleaSe
                                                                                    Yes  Q      No  D
                                                  the operations at thisifacility, but do not complete the
2.
c.   If the answer to (a) is yes, please complete the remainder of this  portfolio.
Type of production operation(s) at this facility (check a_n_ items  that are  appropriate):
                                                            Batch
                                                             D
                                                             D
                                                             D
     d.   Mixing/Compounding and Formulation                 r~|
3.   HuBber of manufacturing or formulating employees  in  1978:
a.
b.
c.
Fermentation
Biological and Natural Extraction
Chemical Synthesis
                                                                   Average
Continuous
D
D
D
i D
Minimum
Semi continuous
D
D
D
D
Maximum
                                                     -1-
                                               D-2

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                                                                                        PLANT CODE NO.
4    Please list in Table 1  all products manufactured at this  plant  site  by  the  following  production subcategories
     during 1978:  (A) Fermentation, (B) Biological  and Natural  Extraction,  and/or  (C)  Chemical Synthesis.   Place
     an A, B, or C in the appropriate column to indicate the type of production  subcategory  used.   Use  the Merck
     Index, Ninth Edition, 1976, to specify the Merck Index Identification Numbers  (Merck  Index Number).  Many of
     the Chemical Abstract Service Registry Numbers  (CAS Numbers) may be  found  in  the  Merck  Index  beginning on
     page REG-1.

     Mote:  Make as many photocopies of this sheet as necessary before fining  in  the  requested  information.

                                                    TABLE 1
   CAS NUMBER
                ERCK INDEX NO.
                                                PRODUCT NAME
                                                                                 RODUCTION
                                                                                 UBCATEGORY
                                                             ANNUAL
                                                           PRODUCTION (kg/yr)
Examples:
   87081
                   6890
                                  Penicillin V
                                                                                                10.000
                                  Allergenic extracts
                                                                                                   300
    103902
                     36
Acetaminophen
                                                                                                 S.OOO.
                                                         -2-
                                                    D-3

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                                                                                PLANT CODE NO.
PART III
WASTEWATER DATA
1.   a.   Does this plant site generate process wastewaters?
                                                                     Yes Q   '   NoQ
           COctitoruf     h        «l dun'"9 """"^""ring o- processing,  comes  into  direct
           contact with or results from the production or use of any raw material,  intermediate  product   finished
                                   ""*** ""*""•  Thl'S d°eS — 1'"Clude ""It^y wastewaters, no'n-contact  cooltng
     b.   Average dally quantity of process, wastewaters  generated  during  1978,! in gallons per day
                                                                              i .........     •    •
                                                             E11l"inat1°n Sys"
      *"
                                                                                                for  the ""charge
      b.   Permit or application number _ ____
      c.   Average daily flow rate of permitted discharge during  1978,  in  gallons ........ "per ''day'
 3.   a.    Does this plant discharge process  wastewaters  to  a municipal sewage treatment plant?    Yes  Q    NoQ
      b.    Average daily flow rate of discharge  to municipal sewage  treatment plant during 1978, in gallons per day

                                         wastewater disposal (e.g., Incineration, evaporation, deep well disposal,
      Method
                                       Average daily flow rate during 1978, gallons per day
     Note.:  "ow rates presented in Questions 2.c., 3.b. and 4.  should total  the flow rate  given  in Question  l.b.
5.   Are there wastewater treatment facilities on site?        Yes Q      Complete  Question  III.6.
                                                               No  n      Go  to Part  IV.
6.   Check which of the treatment processes listed below are employed at  this plant:
     a.   In-plant
         Q   Cyanide Destruction
         D   Metal  Precipitation
         [3   Chromium Reduction                                              i
                                                                               i
         [U   Steam  Stripping
         l~]   Solvent Recovery
         l"1   Other,  Specify	i
     b.   End-of-P1pe                                                           :
         O   Equalization                                                     I
         d   Neutralization                                                   ;
         D   Coarse Settleable  Solids Removal
               Primary Separation                                               ',
         Lj       Primary Sedimentation                                       i
         Q       Primary Chemical Flocculatlon/Clarification                 !
         D       Other, Specify	                                  :
             Biological  Treatment
       D       Activated Sludge
       D       Trickling Filter
                 Aerated Lagoon
                 Waste  Stabilization Ponds
                 Rotating Biological Contactor
         a
         a
         a
                                                    -3-   D-4

-------
                                                                              PUNT CODE NO.
         a
         D
         a
          Powdered Activated Carbon

          Other, Specify	
     Physical/Chemical Treatment

     Polishing

O       Pond

Q       Multi-media Filtration

Q       Activated Carbon

O       Other, Specify	

Sludge Disposal

Q  Landfill

Q  Cropland Use

["]  Ocean
               Other,  Specify_
     If  this  plant  operates  an  end-of-pipe treatment  system and  one  or more  boxes'in  Question  6.b were  checked,
     then  please provide available data  on the performance  of that system by completing  Table  2.  Data  used  to
     compute  long term average  flow rates  and  concentrations should  be for the  time period  from July  1,  1977  to
     December 31, 1978.   If  data  is not  available for the entire 1-1/2 year  period, then please provide data  that
     is  available and indicate  the actual  time period used  to compute  long term average  values.   Do not include
     data  obtained  before July  1, 1977.   In addition, please indicate  the frequency of sampling that  occurred for
     the subject parameter dur\ng the indicated time  period.  In Table 2, please insert  a number from the  following
     list  that corresponds to that frequency.

          Frequency
          One time  sample
          Less than one sample  per month
          One sample per month  to less than one
            sample  per week                                   3
          One sample per week to  one sample per day          4
          More than one sample  per day                       5
          Note:
                 gal/d = gallons per day
                 mg/1  » milligrams per liter
                            Long Term Average Value
                                                          TABLE 2
Parameter
                      Influent to
                   End-of-Pipe System
                                  Effluent from
                                End-of-Pipe System
Time Period over
which average
cone, occurred
Frequency of
sampling during the
indicated time period
Flow (gal/d)
BODc (mq/1)
COD (mg/1)
TSS (mq/1)
Cyanide (mg/1)
Phenol (rog/1)
PART IV

PRIORITY POLLUTANTS

     Please provide the information requested in Table 3 concerning the chemicals which are considered as priority
pollutants and which are listed in Table 3 in confonnance with the following Instructions.:

1.   In column A, place a check mark to indicate all of the listed chemicals which were used as raw or intermediate
     material during 1978.

2.   In column B, place a check mark to indicate all of the listed chemicals which were manufactured at this plant
     as a final or Intermediate material during 1978.

3.   In column C, place a check mark to indicate all of the listed chemicals for which you have analyzed In your
     raw (untreated) process wastewater (R) and/or treated effluent (E), and for which analytical data are available.

4.   If one or!more check marks have been placed in column C, then please attach a copy of the analytical results.
     However, 1f the results are voluminous, the data may be summarized on a separate sheet of paper by computing
     an average concentration and flow rate and stating minimum and maximum concentrations and flow rates for each
     pollutant.  In addition, please indicate the time period over which this data was collected and the frequency
     of sampling that  occurred during that time period.
                                                       -4-
                                                            D-5

-------
      TABLES




PRIORITY  POLLUTANTS
                                      PLANT CODE NO.
Herck
CAS Index :
jJusiiser Niraber Chemical
i. 83-32-9 19 acenaphthene !
2. 107-02-8 123 acrolein j
3. 107-13-1 127 acrylonitrile ;
4. 71-43-2 1069 benzene
5. 92-87-5 1083 benzidine
6. 56-23-5 1821 carbon tetrachloride (tetrachloromethane)
7. 108-90-7 2095 chlorobenzene
8. 120-82-1 9310 1,2,4-trichlorobenzene I
9. 118-74-1 4544 hexachlorobenzene
10. 107-06-2 3733 1,2-dichloroethane j
11. 71-55-6 9316 1,1,1-trichloroethane
12. 67-72-1 4545 hexachloroethane
13. 75-34-3 3750 1,1-dichloroethane ;
14. 79-00-5 9317 1,1,2,-trichloroethane
15. 79-34-5 8906 1,1,2,2-tetrachloroetnane
16. 75-00-3 3713 chloroethane
17. 542-88-1 3046 bis (chloromethyl) ether j
18. 111-44-4 3040 bis (2-chloroethyl) ether
19. 110-75-8 2119 2-chloroethyl vinyl ether (mixed) ;
20. 91-53-7 2127 2-chloronaphthalene !
21. 88-06-2 9323 2,4,6-trichlorophenol ;
22. 59-50-7 2108 parachlorometa cresol
23. 67-66-3 2120 chloroform (trichloromethane)
24. 95-57-8 2134 2-chlorophenol j
25. 95-50-1 3029 1,2-dichlorobenzene
26. 541-73-1 3028 1,3-dichlorobenzene
27. 106-46-7 3030 1,4-dichlorobenzene
28. 91-94-1 3032 3,3'-dichlorobenzidine
29. 75-35-4 9647 1,1-dichloroethylene
30. 540-59-p 85 1,2- trans-dichloroethylene
'!• — - 2,4-dichloreph<;nol
32. 78-87-5 7643 1,2-dichloropropane
33. 542-75-6 3051 1,3-dichloropropylene (1,3-dichloropropene) i
34. 1300-71-6 9744 2,4-dimethylphenol
35. ™- 2,4-dinitrotoluene
36. — - 2,6-dinitrotoluene
3'. — 1,2-diphenylhydrazine
38. 100-41-4 3695 ethylbenzene
39. -— fluoranthene ]
40. ____ 4-chlorophenyl phenyl ether
41. -- — 4-broraophenyl phenyl ether
42. — - bis(2-chloroisopropyH ether
43. — - bis (2-chloroethyoxy) methane
ABC
Raw or
Inter-
Material











































Final or
Inter-
Analyzed
in
Material ! E E
















































\























































~"



\


















        -5-
             DJ6.

-------
                                                    TABIi  3

                                              PRIORITY POLLUTANTS
       PLANT  CODE HO.	

   'ABC
                Merck
                Index
Raw or
Inter-
mediate
Material
Final or
Inter-
mediate
Material
                                                                                                       Analyzed
                                                                                                          in
      75-09-2   5932
                         methylene  chloride  (dichloromethane)
      74-87-3   5916
                         methyl chloride (chloromethane)
      74-83-9   5904     methyl bromide (bromomethane)
47.
      75-25-2   1418.
                         bromoform (tribromome thane)
                	.     dichlorobromomethane
        -69-4   9320
                         trichlorofluoromethane
      75-71-8   3038
                         dichlorodifluoromethane
                	     chlorodibromomethane
                         hexachlorobutadiene
                         hexachlorocyclopentadiene
                ——     isophorone
       91-20-3    6194
                         naphthalene
       9B-9S-3    6409
                          nitrobenzene
 57.    88-75-5   6442
                         ,2-nitrophenol
       100-02-7  6443
                          4-nitrophenol
       51-28-5   3277
                          2,4-dinitrophenol
       534-52-1  3275
                          4f6-dinitro-o-cresol
 61.
       62-75-9   6458
                          N-nitrosodimethy lamine
 62.
                          H-nitrosodiphenylamine
                          N-nitrosodi-n-propy lamine
 64.
       87-86-5   6901
                          pentachlorophenol
        108-95-2  7038
                          phenol
        117-81-7   1270     bis(2-ethylhexyl) phthalate
                           butyl  benzyl  phthalate
        84-74-2   1575
                           di-n-butyl phthalate
                           di-n-octyl phthalate
        84-66-2
                  3783
                           diethyl phthalate
  71.
       131 -11-3  3244
                           dimethyl phthalate
        56-55-3   1063
                           1,2-benzanthracene
        50-32-8   1113     benzo  (a)pyrene (3,4-benzopyrene)
  74.
                           3,4-benzofluoranthene
                           11,12-benzofluoranthene
   76.
         218-01-9   2252
                           chrysene
                            acenaphthylene
         120-12-7    718
                            anthracene
                            1,12-benzoperylene
         86-73-7   4037
   31.
         85-01-8   6996
                            phenanthrene
         53-70-3   2971
                            1,2:5,6-dibenzanthracene
                            indeno(l,2,3-C,D) pyrene
         129-00-O  7746
                            pyrene
          127-18-4  8907
                            tetrachloroethylene
          108-88-3   9225
                             toluene
                                                             -6-   0-7

-------
TABLE  3
                              PLANT CODE NO.
PRIORITY POLLUTANTS
Korck
CAS Index
- 	 ttusb«r Nurfcer (Chemical
87. 79-01-6 9319 trichloroethylane ~~
98. 75-01-4 9645 vinyl chloride (chloroethylene)
89. 309-00-2 220 aldrin
90. 60-57-1 3075 dieldrin
91. 57-74-9 2051 chlordane (technical nixture and metabolites)
92. 50-29-3 2822 4,4'-DDT
93. 	 4,4'-DDE (p,p'-DDX)
94. 6088-51-3 2821 4,4'-DOD (p,p'-TDE)
95. 115-29-7 3519 alpha-endosulfan
96. 115-29-7 3519 beta-endosulfan
9'« -- —- endosulfan sulfate
98. 72-20-8 3522 endrin
(99. 	 endrin aldehyde
100. 76-44-8 4514 heptachlor.
101. 	 	 heptachlor epoxide
102. 58-89-9 5341 alpha-BHC
103. 58-89-9 5341 beta-BHC
104. 58-89-9 5341 ganma-BHC (lindane) , . . ,
105. 58-89-9 5341 delta-BHC
106. 	 PCB-1242 (Arochlor 1242) • ' '.
107. 	 PC3-12S4 (Arochlor 1254)
108. 	 PCB-1221 (Arochlor 1221) j
109. 	 PCB-1232 (Arochlor 1232) ;
110. 	 PCB-1248 (Arochlor 1248) i
111- 	 PCS-1260 (Arochlor 1260) I
112. — — PCB-1016 (Arochlor 1016)
113. 8001-35-2 9252 Toxaphene
114. 7440-36-0 729 Antimony (Total) ~
115. 7440-38-2 820 Arsenic (Total)
116. 350 Asbestos (Fibrous)
117. 7440-41-7 1184 Beryllium (Total)
118. 7440-43-9 16OO Cadmium (Total)
119. 7440-47-3 2229 chromium (Total)
120. 7440-50-8 2496 Copper (Total)
121. 420-05-3 2694 Cyanide (Total)
122. 7439-92-1 5242 Lead (Total)
1 123. 7439-97-6 5742 Mercury (Total)
124. 6312 Nicxel (Total) |[
125. 7782-49-2 8179 Selenium (Total)
126. 7440-22-4 8244 Silver (Total I
127. 7440-28-0 8970 Thallium (Total)
1S8. 7440-66-6 9782 Zinc (Total)
129. 	 2,3,7,8 - tetrad' j« --henzo-p-dioxin (TCDD)
A
Raw or
Inter-
mediate
Material











































B c
Final 01
Inter-
mediate











































Analyzed
in
Wastewater
R E






















































































   -?-  D-8

-------
             APPENDIX E

Pharmaceutical Manufacturing Plants in the
       Supplemental 308 Data Base

-------

-------
                         APPENDIX E


             PHARMACEUTICAL MANUFACTURING PLANTS
                           IN THE
                 SUPPLEMENTAL 308 DATA BASE
NAME

A. E. STALEY MANUFACTURING COMPANY
AJAY CHEMICALS, INC.
ALLIED CHEMICAL COMPANY
AMERCHOL, INC.
AMERICAN AGAR AND CHEMICAL COMPANY
AMERICAN APOTHECARIES COMPANY
AMERICAN CYANAMID CO. - FINE CHEM.
AMERICAN CYANAMID CO. - FINE CHEM.
AMERICAN LABORATORIES, INC.
ANABOLIC, INC.
ANDERSON DEVELOPMENT COMPANY
ARAPAHOE CHEMICALS, INC.
ARAPAHOE CHEMICALS, INC.
ARENOL CHEMICAL CORPORATION
ASH  STEVENS,  INC.  (PILOT PLT.)
ATLAS POWDER  COMPANY
BANNER GELATIN PRODUCTS CORPORATION
BARR LABORATORIES
BAYLOR LABORATORIES,  INC.
BEIERSDORF, INC.
BELPORT COMPANY, INC.
BEN  VENUE LABORATORIES, INC.
BIOCRAFT LABORATORIES,  INC.
BIOCRAFT LABORATORIES,  INC.
BIOCRAFT LABORATORIES,  INC.
BLISTEX, INC.
BOLAR PHARMACEUTICAL  COMPANY,  INC.
BOOTS PHARMACEUTICALS,  INC.
BRIOSCHI,  INC.
C AND M  PHARMACAL,  INC.
C. M. BUNDY COMPANY
CAMPANA  CORPORATION
CARSON CHEMCIALS,  INC.
CARTER-GLOGAU LABORATORIES
CARTER-GLOGAU LABORATORIES
CENTURY  PHARMACEUTICALS,  INC.
CHAP STICK COMPANY
CHASE CHEMICAL COMPANY
CHATTEM  CHEMICALS  DIVISION
CHATTEM  LABORATORIES DIVISION
LOCATION

DECATUR
POWDER SPRINGS
CHICAGO
EDISON
SAN DIEGO
LONG ISLAND CITY
BOUND BROOK
WILLOW ISLAND
OMAHA
IRVINE
ARDIAN
BOULDER
NEWPORT
LONG ISLAND CITY
DETROIT
TAMAQUA
CHATSWORTH
NORTHVALE
HURST
SOUTH NORWALK
CAMARILLO
BEDFORD
ELMWOOD  PARK
ELMWOOD  PARK
WALDWICK
OAK BROOK
COPTAGUE
SHREVEPORT
FAIR LAWN
HAZEL PARK
ERLANGER
BATAVIA
NEW CASTLE
GLENDALE
MELROSE  PARK
 INDIANAPOLIS
LYNCHBURG
NEWARK
CHATTANOOGA
CHATTANOOGA
IL
GA
IL
NJ
CA
NY
NJ
WV
NE
CA
MI
CO
TN
NY
MI
PA
CA
NJ
TX
CT
CA
OH
NJ
NJ
NJ
IL
NY
LA
NJ
MI
KY
IL
IN
AZ
IL
IN
VA
NJ
TN
TN
                                E-i

-------
 CHROMALLOY LABORATORIES
 COHELFRED LABORATORIES, INC.
 CORD LABORATORIES, INC.
 CORWOOD LABORATORIES,  INC.
 CREOMULSTON COMPANY
 CUMBERLAND MANUFACTURING COMPANY
 D. M. GRAHAM LABORATORIES, INC.
 DANBURY PHARMACAL, INC.
 DEL LABORATORIES, INC.
 DEL-RAY LABORATORY, INC.
 DELL LABORATORIES, INC.
 DEPREE COMPANY
 DEVLIN PHARMACEUTICALS, INC.
 DEWEY PRODUCTS COMPANY
 DIAMOND SHAMROCK CORPORATION
 DON HALL LABORATORIES
 DORASOL LABORATORIES
 DR. G.  H.  TICHENOR ANTISEPTIC CO.
 DR. MADIS LABORATORIES, INC.
 DR. ROSE,  INC.
 DRUGS,  INC.
 E.  E.  DICKINSON COMPANY,  INC.
 E-Z-EM COMPANY
 EASTMAN KODAK CO.  - KODAK  PARK
 ELKINS-SINN,  INC.
 EMERSON LABORATORIES
 ENZYME PROCESS  COMPANY, INC.
 EX-LAX,  INC.
 FERMCO  BIOCHEMICS,  INC.
 FLEMING AND COMPANY
 FOREST/INWOOD LABORATORIES, INC.
 FORT DODGE LABORATORIES
 FRANKLIN LABORATORIES,  INC.
 FRESH LABORATORIES, INC.
 FROMM LABORATORIES, INC.
 G AND W LABORATORIES,  INC.
 G.  E. LABORATORIES, INC.
 GANES CHEMICALS,  INC.
 GANES CHEMICALS,  INC.
 GEBAUER CHEMICAL COMPANY
 GENERIC PHARMACEUTICAL  CORPORATION
 GIBO/INVENEX DIVISION
 GOODY'S MANUFACTURING COMPANY
 GORDON LABORATORIES
 GRANDPA BRANDS COMPANY
 GUARDIAN CHEMICAL CORPORATION
 H. CLAY GLOVER COMPANY, INC.
 HALSEY DRUG COMPANY, INC.
HEATHER DRUG COMPANY, INC.
HENKEL CORPORATION
 LOS ANGELES            CA
 CHICAGO                IL
 BROOMFIELD             CO
 HAUPPAUGE              NY
 ATLANTA                GA
 NASHVILLE              TN
 HOBART                 NY
 DANBURY                CT
 FARMINGDALE            NY
 BIRMINGHAM             AL
 TEANECK                NJ
 HOLLAND                MI
 EL SEGUNDO             CA
 GRAND RAPIDS           MI
 LOUISVILLE             KY
 PORTLAND               OR
 HATQ REY               PR
 NEW ORLEANS            LA
 SOUTH HACKENSACK       NJ
 MADISON                CT
 ELIZABETH              NJ
 ESSEX                  CT
 WESTBURY               NY
 ROCHESTER              NY
 CHERRY HILL            NJ
 DALLAS                 TX
 NORTHRIDGE             CA
 HUMACAO                PR
 ELK GROVE VILLAGE       IL
 FENTON                 MO
 INWOOD,  L.I.            NY
 FORT DODGE             IA
 AMARILLO               TX
 WARREN                 MI
 GRAFTON                WI
 SOUTH  PLAINFIELD        NJ
 SHAMOKIN                PA
 CARLSTADT               NE
 PENNSVILLE              NJ
 CLEVELAND               OH
 PALISADES PARK          NJ
 GRAND  ISLAND            NY
 WINSTON-SALEM           NC
 UPPER  DARBY             PA
 CINCINNATI             OH
 HAUPPAUGE              NY
 TOMS RIVER             NJ
BROOKLYN               NY
CHERRY HILL            NJ
KANKAKEE               IL
                              E-2

-------
INC.
HEUN/NORWOOD LABORATORIES
HEXAGON LABORATORIES, INC.
HEXCEL SPECIALTY CHEMICALS
HIGH CHEMICAL COMPANY
HOBART LABORATORIES, INC.
HOLLAND-RANTOS COMPANY, INC.
HOPPE PHARMACAL CORPORTION
HUMPHREYS PHARMACAL, INC.
ICN PHARMACEUTICALS: COVINA DIVISION
INFRACORP, LTD.
INTERNATIONAL HORMONES, INC.
J. H. GUILD COMPANY, INC.
JOHN D. COPANOS COMPANY, INC.
KALLESTAD LABORATORIES, INC.
KENDALL COMPANY
KENDALL COMPANY
KEY PHARMACEUTICALS,
KOPPERS COMPANY, INC.
L. T. YORK COMPANY
LANNETT COMPANY, INC.
LARSON LABORATORIES, INC.
LEE PHARMACEUTICALS
LEWIS/HOWE COMPANY
LIBBY LABORATORIES,  INC.
LILY WHITE SALES COMPANY,  INC.
LORVIC CORPORATION
LYNE LABORATORIES,  INC.
LYPHO-MED, INC.
M. K. LABORATORIES,  INC.
MANHATTAN DRUG COMPANY
MANN CHEMICAL CORPORATION
MARSHALL PHARMACAL  CORPORATION
MAURRY BIOLOGICAL COMPANY,  INC.
MBH CHEMICAL CORPORATION
McCONNON AND COMPANY
MENTHOLAIUM COMPANY
MERICON  INDUSTRIES,  ING.
MERRICK  MEDICINE COMPANY
MERRILL-NATIONAL LABORATORIES
MICROBIOLOGICAL ASSOCIATES
MILEX  PRODUCTS,  INC.
MILLER-MORTON  COMPANY
MILROY LABORATORIES
MONSANTO CO. - JOHN F.
MORTON PHARMACEUTICALS,
MOYCO  INDUSTRIES,  INC.
MYLAN  PHARMACEUTICALS,  INC.
N.E.N. - MEDICAL  DIAGNOSTIC DIVISION
NAPP CHEMICALS,  INC.
NATCON CHEMICAL  COMPANY,  INC.
  QUEENY PLT.
  , INC.
ST. LOUIS
BRONX
LODI
PHILADELPHIA
CHICAGO
TRENTON
GRAND HAVEN
RUTHERFORD
COVINA
PETERSBURG
FORT MITCHELL
RUPERT
BALTIMORE
CHASKA
AUGUSTA
FRANKLIN
MIAMI
PETROLIA
BROOKFIELD
PHILADELPHIA
ERIE
SOUTH EL MONTE
ST. LOUIS
BERKELEY
ORISKANY FALLS
ST. LOUIS
NEEDHAM HEIGHTS
CHICAGO
FAIRFIELD
HILLSIDE
LOUISVILLE
SOUTH HACKENSACK
LOS ANGELES
ORANGE
WINONA
BUFFALO
PEORIA
WACO
MILWAUKEE
WALKERSVILLE
CHICAGO
RICHMOND
SARASOTA
ST. LOUIS
MEMPHIS
PHILADELPHIA
MORGANTOWN
NORTH BILLERICA
LODI
PLAINVIEW
MO
NY
NJ
PA
IL
NJ
MI
NJ
CA
VA
KY
VT
MD
MN
GA
KY
FL
PA
MD
PA
PA
CA
MO
CA
NY
MO
MA
IL
CT
NJ
KY
NJ
CA
NJ
MN
NY
IL
TX
WI
MD
IL
VA
FL
MO
TN
PA
WV
MA
NJ
NY

-------
 NATIONAL PHARMACEUTICAL MFG. COMPANY
 NELCO LABORATORIES, INC.
 NEPERA CHEMICAL COMPANY, INC.
 NORTH AMERICAN BIOLOGICALS, INC.
 NUTRILITE PRODUCTS, INC.
 O'NEAL, JONES, AND FELDMAN, INC.
 O'NEAL, JONES-, AND FELDMAN, INC.
 ORGANICS, INC.
 ORMONT DRUG AND CHEMICAL CO., INC.
 OTIS CLAPP AND SONS
 OTTAWA CHEMICAL DIVISION
 PASCAL COMPANY, INC.
 PAUL B. ELDER COMPANY
 PETERSON OINTMENT COMPANY
 PFANSTIEHL LABORATORIES, INC.
 PHARMACARE,  INC.
 PHARMACIA,  INC.
 PHILIPS ROXANNE,  INC.
 PIERCE CHEMICAL COMPANY
 PITMAN-MOORE,  INC.
 PRALEX CORPORATION
 PREMO PHARMACEUTICAL  LABS.,  INC.
 PRIVATE FORMULATIONS,  INC.
 RACHELLE LABORATORIES,  INC.
 RECSEI LABORATORIES
 REED AND CARNRICK,  INC.
 REID-PROVIDENT LABORATORIES,  INC.
 REXALL DRUG  COMPANY
 REXAR PHARMACAL CORPORATION
 RHONE-POULENC,  INC.
 RHONE-POULENC:  HESS AND CLARK DIV.
 RIKER LABORATORIES, INC.
 ROEHR CHEMICALS COMPANY
 RUETGERS-NEASE CHEMICAL COMPANY
 RYSTAN COMPANY, INC.
 SCHOLL,  INC.
 SCHUYLKILL CHEMICAL COMPANY
 SEIN/MENDEZ  LABORATORIES
 SHELL CHEMICAL  COMPANY
 SHERWOOD LABORATORIES,  INC.
 SINCLAIR PHARMACAL  COMPANY,  INC.
 SOUTHLAND CORPORATION
 STANBACK COMPANY, LTD.
 STANLABS PHARMACEUTICAL  COMPANY
 STIEFEL LABORATORIES,  INC.
 SUPPOSITORIA LABORATORIES, INC.
 SYNTEX AGRI-BUSINESS,  INC.
SYNTEX AGRI-BUSINESS,  INC.
SYNTEX  (F.P.),  INC.
TABLICAPS, INC.
 BALTIMORE              MD
 DEER PARK              NY
 HARRIMAN               NY
 MIAMI                  FL
 BUENA PARK             CA
 STJ  LOUIS              MO
 CINCINNATI             OH
 CHICAGO                IL
 ENGLEWOOD              NJ
 CAMBRIDGE              MA
 TOLEDO                 OH
 BELLEVUE               WA
 BRYAN                  OH
 BUFFALO                NY
 WApKEGAN               IL
 LARGO                  FL
 PISCATAWAY             NJ
 ST.  JOSEPH             MO
 ROCKFORD               IL
 WASHINGTON CROSSING    NJ
 ST.  CROIX              VI
 SOUTH HACKENSACK       NJ
 EDISON                 NJ
 LONG BEACH             CA
 GOLETA                 CA
 KENILWORTH             NJ
 ATLANTA                GA
 ST.  LOUIS              MO
 VALLEY STREAM           NY
 NEW  BRUNSWICK           NJ
 ASHLAND                OH
 NORTHRIDGE             CA
 LONG ISLAND CITY       NY
 STAJ-E  COLLEGE           PA
 LITTLE  FALLS            NJ
 CHICAGO                IL
 PHILADELPHIA            PA
 RIO  PIEDRAS             PR
 DENVER                  CO
 EASTLAKE                OH
 FISHERS  ISLAND          NY
 GREAT MEADOWS           NJ
 SALISBURY               NC
 PORTLAND                OR
 OAK HILL                NY
 FARMINGDALE             NY
 SPRINGFIELD             MO
VERONA                  MO
HUMACAO                 PR
FRANKLINVILLE           NJ
                             'E-4

-------
  TAYLOR PHARMACAL COMPANY
  TENNESSEE EASTMAN COMPANY
  THOMPSON-HAYWARD CHEMICALS
  TRUETT LABORATORIES
  UPSHER SMITH LABORATORIES
  V.  K.  BHAT
  VALE CHEMICAL COMPANY, INC.
  VINELAND LABORATORIES, INC.
  VINELAND/EVSCO, INC.
  VIOBIN CORPORATION
  VISTA LABORATORIES, INC.
  VITA-FORE PRODUCTS COMPANY
  VITAMINS, INC.
  VITARINE COMPANY, INC.
  W.  F.  YOUNG, INC.
  WALGREEN LABORATORIES, INC.
  WATKINS,INC
  WEST ARGO-CHEMICALS, INC.
  WEST ARGO-CHEMICALS, INC.
  WEST-WARD, INC.
  WESTERN RESEARCH LABORATORIES
  WESTWOOD PHARMACEUTICALS, INC.
  WHITEHALL LABORATORIES
  WHITEWORTH, INC.
  WHORTON PHARMACEUTICALS, INC.
  WILLIAM T. THOMPSON COMPANY
  WORTHINGTON DIAGNOSTICS
  XTTRIUM LABORATORIES, INC.
  YAGER DRUG COMPANY
  ZENITH LABORATORIES, INC.
DECATUR                IL
KINGSPORT              TN
KANSAS CITY            KS
DALLAS                 TX
MINNEAPOLIS            MN
EVERETT                WA
ALLENTOWN              PA
VINELAND               NJ
BUENA                  NJ
MONTICELLO             IL
ST. CROIX              VI
OZONE PARK             NY
CHICAGO                IL
SPRINGFIELD GARDENS    NY
SPRINGFIELD            MA
CHICAGO                IL
WINONA                 MN
EIGHTY FOUR            PA
KANSAS CITY            MO
EATONTOWN              NJ
DENVER                 CO
BUFFALO                NY
ELKHART                IN
GARDENA                CA
FAIRFIELD              AL
CARSON .                CA
FREEHOLD               NJ
CHICAGO                IL
BALTIMORE              MD
NORTHVALE              NJ
TOTAL NUMBER OF MFG. PLANTS IN THE SUPPLEMENTAL 308 DATA BASE:  220
                                E-5

-------

-------
                 APPENDIX F

Pharmaceutical Industry General Plant Information
    (308 Data/

-------

-------
                          APPENDIX F
                    GENERAL  PLANT  INFORMATION
 Plant
Code No.
12000
12001
12003
12004
12005
12006
12007
12011
12012
12014
12015
12016
12018
12019
12021
12022
12023
12024
12026
12030
12031
12035
12036
12037
12038
12040
12042
12043
12044
12048
12051
12052
12053
12054
12055
12056
12057
12058
12060
12061
12062
12063
 12065
Subcateqories
       D
       D
 A   CD
     C D
   B
       D
       D
 A B   D
   B   D
   B
       D
       D
 A   CD
       D
       D
 A   C
       D
       D
     C
       D
       D
       D
 A
     C D
 A B C D
   B   D
 A B   D
     C
 A     D
     C D
       .D
     C D
       D
       D
       D
       D
     C D
       D
       D
   B
     C D
   N/A
       D
  Average
Employment(1)
   2200
    380
   5930
     72
     10
     54
   1710
    224
   3540
    N/A
    365
    132
    210
    850
     39
    176
    442
   1240
     30
    200
     60
    208
    184
   1118
   1053
    433
    183
     14
    873
    425
     19
    503
    250
    350
    100
    200
    750
    100
    546
    152
    300
    313
    980
Start-Up
Year(2)
 1965
 1959
 1931
 1972
 1971  ,
 1963
 1933
 1968
 1947
 1977
 1960
 1968
 1916
 1960
 1973
 1951
 1967
 1920
 1950
 1966
 1897
 1972
 1948
 1937
 1954
 1967
 1974
 1973
 1938
 1951
 1963
 1971
 1963
 1958
 1956
 1971
 1934
 1955
 1962
 1967
 1950
 1974
 1960

-------
  12066
  12068
  12069
  12073
  12074
  12076
  12077
  12078
  12080
  12083
  12084
  12085
  12087
  12088
  12089
 12093
 12094
 12095
 12097
 12098
 12099
 12100
 12102
 12104
 12107
 12108
 12110
 12111
 12112
 12113
 12115
 12117
 12118
 12119
 12120
 12122
 12123
 12125
 12128
 12129
 12131
 12132
 12133
 12135
 12141
 12143
 12144
 12145
12147
12155

























A




A


A







A








BCD
D
D
C
D
D
C D
D
D
D
BCD
D
C
D
B D
C D
D
C D
C D
D
D
C D
C D
D
B D
C D
D
B D
C
D
B D
B I)
D
D
D
D
C D
D
D
D
D
C
D
BCD
D
D
D
D
D
C D
  666
   17
  176
    6
  220
   50
  493
  N/A
 ;1640
 , 190
  275
   74
   90
  250
   32
  560
  135
  102
 : 160
   54
   75
 i  17
 I 265
 [1415
 '•• 105
  372
   10
 t 444
   12
  922
 : 271
  455
  280
  N/A
  22
   6
  277
  32
  24
  615
  32
  383
  10
 875
 ,112
 1175
 ; 20
  18
 231
1668
 1953
 1934
 1964
 1961
 1897
 1972
 1970
 1977
 1948
 1972
 1958
  N/A
 1957
 1950
 1914
 1948
 1967
 1947
 1951
 1975
 1970
 N/A
 N/A
 1951
 1923
 1974
 1974
 1949
 1959
 1962
 1963
 1882
 1972
 1977
 1974
 1937
 1937
 1974
 N/A
 1975
 1970
 1941
 1969
 1896
 1971
 1924
 1972
1972
1965
1849
                              F-2

-------
12157
12159
12160
12161
12166
12168
12171
12172
12173
12174
12175
12177
12178
12183
12185
12186
12187
12191
12194
12195
12198
12199
12201
12204
12205
12206
12207
12210
1221 1
12212
12217
12219
12224
12225
12226
12227
12230
12231
12233
12235
12236
12238
12239
12240
12243
12244
12245
12246
12247
12248
A B
  B

  B
  B
  B
  B
A B


  B
A

A B



  B
  D
C D
  D
C D
  D
C D
C D
  D

  D
  D
  D
  D

C
C D
C
C
  D
C
  D
C D
  D
C D
  D
  D
  D
C
C
  D
  D
  D
  D
  D
  B

  B
A
A B
  D
  D
C
C
  D
  D
C D
  D
C
C
C D
C
  D
   8
 356
 215
 905
  90
 250
  70
  34
   3
  75
  66
  70
  40
 270
  26
 051
0632
 450
  20
 N/A
  70
2061
 N/A
2000
 300
 220
  55
 190
  22
 212
 140
 544
1333
  22
 124
  25
  20
 685
 341
  84
 250
  42
  46
  53
  70
 224
 230
 716
   6
 810
1973
1942
1974
1969
1974
1938
1970
1974
1940
1939
1975
1960
1962
1903
1941
1976
1949
 N/A
1973
1975
1949
1946
 N/A
1907
1968
1971
1962
1973
1976
1976
1975
1964
1915
1972
1973
1963
1969
1968
1895
1971
1952
1976
1973
1972
1973
1947
1951
1948
1969
1961
                              F-3

-------
 12249
 12250
 12251
 12252
 12254
 12256
 12257
 12260
 12261
 12263
 12264
 12265
 12267
 12268
 12269
 12273
 12275
 12277
 12281
 12282
 12283
 12287
 12289
 12290
 12294
 12295
 12296
 12297
 12298
 12300
 12302
 12305
 12306
 12307
 12308
 12309
 12310
 12311
 12312
 12317
 12318
 12322
 12326
 12330
 12331
 12332
 12333
12338
12339
12340



A
A
A B
A B



A B
B




B


B





B



D
D
D
C D
D
C D
C D
D
C
D
D
D
D
D
D
D
C
D
D
C D
D
D
D
D
C D
D
D
D
D
  B
  B

  B
  B
ABC

    C
    C
  D
  D
  D
  D

  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
C D
  D
  115
  259
   53
 1400
  444
 1239
 4600
  176
  128
   28
 4450
 ;  65
  122
  112
  135
   14
 1297
   15
 !303
   85
   37
 31! 1 2
 :  31
 1  59
 332
   8
 685
   70
 ,  88
 410
 144
 174
 ;  4
 151
 1052
  30
 170
 1008
 693
2387
 210
  98
  60
2438
 374
 N/A
 198
 150
 555
1595
 1968
 1940
 1968
 1939
 1971
 1948
 1922
 1943
 1966
 1973
 1910
 1965
 1969
 1974
 1957
 1975
 1925
 1965
 1957
 1900
 1972
 1964
 N/A
 1975
 1969
 1925
 N/A
 1972
 1962
 1953
 1901
 1971
 1976
 1975
 N/A
 1967
 1970
 1953
 1873
 1972
 1960
 1969
 1975
 1906
 1967
 N/A
 1970
1974
1970
1957
                              F-4

-------
12342
12343
12345
12375
12384
12385
12392
12401
12405
12406
12407
12409
12411
12414
12415
12417
12419
12420
12427
12429
12433
12438
12439
12440
12441
12444
12447
12454
12458
12459
12460
12462
12463
12464
12465
12466
12467
12468
12470
12471
12472
12473
12474
12475
12476
12477
12479
12481
12482
12495
A
A
C D
C D
  D
  B
  B
  B
  B
  B
A B
  B
  B
  B
  B
  B
  B
  B
  B
  B
  B
  D
  D
  D
C D
C
C
  D
C D
  D
  D
  D
  D
  D
  D
  D
  D
  D
C D
  D
C
  D
C D
  D
C D
  D
  D

  D
  D
  D
C
C
      D
    N/A
      D
 377
 166
 389
  91
  35
  60
 110
1324
  85
 163
  67
  18
 750
 627
 450
  10
 123
 160
 579
  51
 180
 560
 1 15
 235
1108
  78
4095
 710
 120
   4
  70
  25
 224
   4
 315
  18
  67
 628
  14
 328
  44
 242
  64
 153
  55
 298
   5
 N/A
 N/A
 130
1944
1967
1963
1953
1970
1966
1959
1968
1964
1948
1904
1920
1970
1951
1968
1950
1969
1973
1958
1886
1953
1964
1974
1965
1923
1977
1948
1947
1968
1977
1975
1972
1926
 N/A
1967
1958
1959
1947
1967
1972
1971
1947
1969
1966
1967
1867
1977
1918
 N/A
1959
                               F-!5

-------
 12499
 20006
 20008
 20012
 20014
 20015
 20016
 20017
 20020
 20026
 20030
 20032
 20033
 20034
 20035
 20037
 20038
 20040
 20041
 20045
 20048
 20049
 20050
 20051
 20052
 20054
 20055
 20057
 20058
 20062
 20064
 20070
 20073
 20075
 20078
 20080
 20081
 20082
 20084
 20087
 20089
 20090
 20093
 20094
 20099
 20100
 20103
 20106
20108
20115
B
      D
      D
      D
    C
      D
      D
      D
      D
      D
      D
    C D
  B   D
    C D
      D
    C
      D
      D
  B
      D
      D
      D
      D
A B
      D
      D
      D
      D
      D
      D
      D
      D
      D
      D
      D
      D
      D
      D
    C  D
      D
      D
      D
      D
      D
      D
      D
      D
      D
     D
     D
     D
1150
   2
  20
   4
1210
  45
                         68
                          3
                          1
                         79
                         38
                        .14
                         25
                          1
                         81
                         12
                         20
                         12
                         10
                         31
                         31
                          6
                         30
                         21
                         15
                        , 35
                         16
                        150
                        ; 2
                        ! 4
                         1
                         35
                        I 14
                        ! 6
                        ; 75
                         10
                         55
                         40
                        ; 3
                         2
                         5
                         34
                         3
                         3
                         62
                         7
                                         1961
                               F-6

-------
 20117
 20120
 20125
 20126
 20134
 20139
 20141
 20142
 20147
 20148
 20151
 20153
 20155
 20159
 20165
 20169
 20173
 20174
 20176
 20177
 20178
 20187
 20188
 20195
 20197
 20201
 20203
 20204
 20205
 20206
 20208
 20209
 20210
 20215
 20216
 20218
 20220
 20224
 20225
 20226
 20228
 20229
 20231
 20234
 20235
 20236
 20237
20240
20241
20242
B
B
B
B
   D
   D
   D
   D
 C  D
 C  D
   D
   D
   D
   D
 C  D
   D
   D
 C
 C
   D
 C
   D
   D
 C
   D
   D
   D
   D
   D
   D
 C
 C  D
 C
 C
   D
   D
   D
   D
   D
 C
   D
   D
   D
   D
  D
  D
  D
C
  D
  D

C
  D
C D
 127
  14
  50
  12
   6
  40
   6
  70
  15
  15
   6
  10
  20
  22
  10
  30
   3
   6
   2
   5
  12
  10
200
100
   3
   8
  93
  84
  37
  49
   2
  12
   3
  13
   6
  15
  20
   6
  65
  22
   2
  86
  20
N/A
   7
120
 28
 20
 31
  10
                               F-7

-------
20244
20245
20246
20247
20249
20254
20256
20257
20258
20261
20263
20264
20266
20267
20269
20270
20271
20273
20282
20288
20294
20295
20297
20298
20300
20303
20305
20307
20308
20310
20311
20312
20316
20319
20321
20325
20328
20331
20332
20333
20338
20339
20340
20342
20346
20347
20349
20350
20353
20355
B
B
B
B
B
B
C
C
C

C
C

C
C
C
C
C
  C
  C
C
C
C
    D
    D
    D
    D
    D
    D
    D
    D
    D
    D
    D
    D
  C
  C
D
D
D
D
D
D
    D
    D
    D
    D
  C
  C D
B C
  C
  1
 59
171
 25
  3
  3
 90
 60
 20
 15
  2
 1 1
 13
1 16
 10
  6
  6
 70
  2
 38
  9
 53
 10
N/A
 40
  1
 19
 29
  3
 15
 15
 44
 60
272
100
  5
 10
 60
 24
  3
130
  4
  4
 35
 60
  1
 50
 20
 35
 25
                                F-8

-------
20356
20359
20361
20362
20363
20364
20366
20370
20371
20373
20376
20377
20385
20387
20389
20390
20394
20396
20397
20400
20402
20405
20413
20416
20421
20423
20424
20425
20435
20436
20439
20440
20441
20443
20444
20446
20448
20450
20452
20453
20456
20460
20462
20464
20465
20466
20467
20470
20473
20476
B
C D
  D
  C D
  C D
B   D
BCD
B C
    D
  C
    D
  C D
    D
  C
  C
    D
B   D
    D
    D
    D
    D
    D
    D
    D
    D
    D
  C D
    D
  C D
    D
    D
    D
    D
C
C
B
B
B
  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
  2
 16
N/A
  4
N/A
  9
315
 45
  3
N/A
 15
  3
240
  7
 40
 40
  4
  4
 18
N/A
 65
 21
  3
 25
  2
 85
 60
  2
  2
 80
200
 11
 25
  3
  5
  3
  6
 15
  7
 20
  6
  4
  2
  4
240
110
  3
  1
150
 50
                                F-9

-------
20483
20485
20486
20490
20492
20494
20496
20498
20500
20502
20503
20504
20507
20509
20511
20518
20519
20522
20526
20527
20529
  D
  D
  D
  D
C D
  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
C D
  D
  D
  2
 ,30
  5
250
 , 3
 65
 12
  2
 31
  3
 ; i
  2
 i 3
 33
 i 8
 !5
 13
 ,6
 18
 24
  2
(1)  Average employment for orignal 308 (12000 series) plants is for
    1976;  for Supplemental 308, (20000 series) plants it is 1978.
                                             f
(2)  Data on year of operational start-up was not requested of the
    Supplemental 308 (20000 series) plants.   1
                              F-10

-------
r
                                          APPENDIX G



                                Screening/Verification Plant Data

-------

-------
                           APPENDIX G

                     SCREENING/VERIFICATION
                           PLANT DATA

Abbreviations;      GT-greater than
                     j-approximate value
                    LT-less than
                  LTDL-less than detection limit
                   NAI-not able to analyze due to interference
                    ND-not detected
                    NQ-not quantifiable due to instrument
                           saturation

Notes:    (1) numbers in parenthesis indicate number of data points.

          (2) when more than one data point was available a range
              (min-max.) is given.

          (3) pollutants not listed were not detected, below
              detection limit, or not analyzed for.
                                G-l

-------
                                       SCREENING PROGRAM	SWMARV OF PLANT  12015
SIWMARY OF SCREENING DATA
CONCENTRATION (ug/1]
Priority Pollutants Tnfi.,ant Effluent
Acid Extractables
Pentaehlorophenol 62
Phenol 8
Phenols (4AAP) 249
Base/Neutral Extractahl«
Bis (2-8thylhexyl) phthalate 170
Di-n-butyl phthalate 20
Volatile Oraanics
Benzene 79
1.2 Dtchloraethane 19
Chloroform 100GT
Ethylbcnzene 11
Hethylene chloride 100ST
Tctrachloroethylene 36
Toluene IOOGT
Trlchloroethylene 6
Ketals
Beryllitw ILT
Cattaiua 6
ChrOBlw 30
Copper 50 j
Lead 20LT ]
Mercury n 7
HJ«*«1 5LT ]
Zinc inn It
All other metals „ l
Cyanide 25LT (1
1 ND f
1 NO I
1 26 {
1) 30
1) 3
1 ND
1 ND
1 14
1 ND
1 12
1 ND
1 3
1 ND
I ILT (]
I 7 ]
1 10 ]
L 30 (]
1 20LT (]
0.1 (I
J 5LT (J
) 200 (1
) 25LT (1
1)
1)
1)
1
1
1)
I
!)
;
)
WASTEKATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Primary Sedimentation
Activated Sludge with Powdered Activated Carbon
Secondary Chemical Flocculation/Clarification
Gravity Dewatering
Aerobic Digestion
Landfill
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (HGD) Employment
D .07 300-400
PERFORMANCE OF TREATMENT SYSTEM
?SP..te?X.U COD to/D TSS (mg/1)
I-lf.1.^!?^ ."fluent Influent Effluent Influent Effluent
* Data supplied by plant ° ^*
                                         WASTEIVATER TREATMENT PLANT FLOW DIAGRAM


*

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rl I

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i












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*






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LUt>6c. 70
                                            &OU.M.IZATIOO
s^icv*^;ti.        —~J
f.eaa era          /

     \tr.of9 tfo '
                                UCCTU-'M «.LI^«V
                              — -5^ -" — -^.-—r;

                                IC?0 Lt/CKf Tli
1
L_) m.r*mc*n
j U1. MC/L TM
,J



— .

r-
--_^ 	 .


       ^3...6oe'6^i>_t_^
       TV:"i.c,viy~t«s..
                                            _SAMPLING  PROGRAM
                Saoplc Location
                1. Influent to primary clarifier
                2. XAD-2  resin
                2. Tcnax  column
                J. Return sludge
                4. clarifiot  cffluont
                                                            6-2
No. of Samples

     4
     4
     4       '

     J

-------
r
                                                      SCREENING PROGRAM—SIMIARY OF PLANT 12022

SlfttlAKY OF SCREENING DATA
CONCEtn
Priority Pollutants Influen
Acid Extractables '••'••-
2,4,6-Trlchlorophenoi 20 (1
2-Chorophenol 50 I
Phenol 1400 1
Phenols (4AAP) 1367 (1
Base/Neutral Extractables
1,2-Dichlorobenzene M U
1,4-Dichlorobenzene 90 (l
Volatile Organlcs
Benzene •- • • ' i ,
Chlorobenzene 6400
1,2-Dichloroethane 11000
Chloroform 80
Ethyl benzene 19
Methylene chloride 170 (
Toluene HOOO (
Metals (Data supplied by plant)
Antimony jjOLT
Arsenic . 50LT
Beryllium 10LT
Cadmium 2-°
Chromium 125
Copper '0
Lead , , 20LT
Mercury 1;* J
Nickel _ 510 (
Selenium 50LT
Silver ' ' ' 3
Thallium 50LT
Zinc 480
Cyanide 168

[RATION (ug/1}
t Effluent

LTDL 11)
ND (1)
) ND (1)
) 867 (1)
) ND (1)
) ND (1)

) ' nu il)
) ND (1
) 500 (1
I LTDL (1
L ND (1
L ' LTDL (1
I) ND (1

1 BOLT (1
1 BOLT (1
1 10LT 1
1 1.2 (1
1 75 (1
1 20 (1
1). 20LT (1
1) 1.0 (1
1) 310 (1
(1) BOLT (1
(1) 1.6 (1
(1) BOLT (1
(1) 100 (1
(1) 400GT (1








•
-


[
)

WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Neutralization
. Coarse Setteable Solids Removal
Activated Sludge
TMrH-inn Fllfpr
Mechanical Thickening
Chemical Conditioning
Vacuum Dewaterlng
Incineration
Landfill

- ' 'fUS - ' ' -t ' • '
PLANT aiARACTERISTICS .
Subcategory Wastewater Quantity (MSD)' SlCjJJJ?.6.?.*..
A,C 1-30 100-200

PERFORMANCE OF TREATMENT SYSTEM
BOD (mg/1) COD (mg/1) .TSSjjmg/1).
Inf1!*# .!SG.'JS!.t. LlfAKSSiS. JitltJ.'iS!.*. iP.tJ.HS??. .E.tf.lH?P.?. '
2630 680 4619 1701
                                                           WASTEWATER TREATMENT PLANT FLOW DIAGRAM .
PIAHT
CgHTAMiaOTtO1'
UffilE
Average Flw
1.5 - ?.0 H50
35,0011 WHM.
tve. B.0.0 loail
Plant

Viet
Uell
PllTlIp
Station

3
equal-
ization
Tank

—5

neutral-
ization
Tank

Cooling Hater
20.0 I1GO Flow
Disc
Rive
/
large to
r


2 Secondary
Clarlflers

' Soli
Reno
T~

2 Primary
Clarifiers
ds
val
	 !
— ?

2 Trickling
Uio-Filters



\/
3 Parallel
Acntion
BaS'ns

* •
1
Solids
Sludge
Removal
Sludge'
Thickener
• - 5
Vacuum
Filtration
-•^ Incinerator
\/
Residue to
Landfill
                                                                    SAMPLING PROGRAM
                                           Sample Location
                                           1.  Influent to biological treatment
                                           2.  Final effluent before dilution
                                              Potable water
                                                                                                                                          G-3
Ho.  of Samples

     2
     2
     1

-------
                              SCREENING PROGRAM	SUMMARY OF PLANT  12026
SIMURY OF SCREENING DATA
CONCENTRATION (ug/1)
Priority Pollutants Influent Effluent
Acid Extractables


I'hfiftOl 64 (1) 5.8 (1)
Base/Neutral Extractables
Acenapnthene 1.9 (1
Fluoranthenc 0.2 (1
Naphthalene 9.8 1
B1s(2-ethylhcxyl) phthalate 10.7 1
Anthracene 0.4 i
Volatile Organlcs
Benzene' 7 (1
Carbon Tetraehlorlde HOOD (1
1,2-Diohloroethane 17 (1
Chloroethane 1.6 (1
Chloroform 3170 (1
Ethylbenzene 130 (1
Toluene 470 (1
Acroleln 100LT" (1
Acrylonltrlle 100LT (1
Hauls.
Alimony 3 (
Arsenic 20LT (
Beryl Hum 30 (
Cadalum 1LT (
Chwwlua 11
Copper 410
Lead 10LT
Kereury 0.79
Nickel 4LT
SelcniuR 20LT
Silver 3LT
Thai 1 tun 8LT
Zinc 120
Cyanide . 1980
0.10LT 1)
0.10LT 1
0.10LT 1
14.6 1
0.10LT (1
0.01LT (1
0.01LT (1
0.01LT (1
0.01LT (1
8.1 (1
0.01LT (1
0.01LT (1
100LT (1
100LT (1
1 " 5LT (1
L 20LT (1
I 0.80 (1
L 1LT (1
1 40 1
I 80 1
1 ' 10LT 1
L 0.20 1
I 4LT 1
1 - 20LT (1
L 3LT (1
L 8LT (1
I 71 (1
63

WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Neutralization
Activated Sludge
Aerated lagoon
Polishing Pond
Anaerobic Digestion
i
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (H6D) Employment
C .101 0-100
PERFORMANCE OF TREATMENT SYSTEM
?.0.P..{mg/l) COD (mg/1) TSS (mg/1)
J"f.!".(:.n* £f.fl!i.e.nt influent Effluent Influent Effluent
1418 348.4 , 2375 159.7 621 117.6
                                WASTEKATER TREATMENT PLANT FLOW DIAGRAM
WMATCr
\OOOO
1O
                                                     .
                                       R.&TE>-JTIOkJ  J. r7ETE*JTlO|4 "2 H(Z
4C» ftPM iJOM* „. ^-^ f^ - £ W^& RWE .^fiPM/FT^
• — x 0 0 P ^_ . »)s
\ AERATIOO POM KJOMIUM. ?oO*?f 	 ~/~ 	 -| elLUDSt £ ReTUaM |
\ \c'^rt£"}.e'>iro'S2r' r"" */*«$5* I ,'°° &"M
•\ | — " * : ' z
iA r^ 3
ff\ '' 1^ If
\J. • \
I 1 f
, «?o fi.PM , ; , .,.,... ' \S
*ic &PM JOH. MA.»<. « 1
-x g u g — i- si -a
X ' 	 ' ' 	 ' ' 	 ' / ^ ; 1
N^ 3eT|oHP°Ale^ATeS«^ FeCt? ! / CONTROL
1
t
f J

/ 7 1 Ot7O(2. CC^TROL.
rn -x r r . . r . /^- -i^-
\x. V I • r ; : : / /
\ t « » : ? J /'/•• - • .
sample Location No. of Sa
P£>UI^HI*J
-------
                                      Appendix F
                                 Verification Program
                                  Analytical Results
                                     Plant 12026
                                                                                 Day 3
Priority Pollutants (uq/1)
Volatile Organics
Carbon Tetrachloride
1,2 Dichlorethane
Chloroform
Ethyl benzene
Toluene
Bromod i chl oromethane
Acid Extractables
2,4,6-Trichlorophenol
Pentachlorophenol
Phenol
*Base/Neutra1 Extnactables
*Metal s
*Pesticides
Cyanides (mg/1)
Influent

15
1.1
1620
61
122
1

ND
ND
515-750



0.45
Effluent

1LT
1LT
1LT
1LT
1LT
1LT

ND
ND
ND-3



0.35
Influent

12
1
554
25
78
1

ND
ND
99



.06
Effluent

1LT
1LT
1LT
1LT
1LT
1LT

ND
ND
3



.53
Influent

59
1LT
1100
22
193
1LT

ND
ND
450



2.0
Effluen"

1LT
1LT
1LT
1LT
1LT
1LT

ND
ND
ND



0.49
Asbestos (verification program did not analyze for this compound)
Conventionals (mg/1)
           BOD,-
           TSS5

Non-Conventi onals (mg/1)

           COD

          *NOTE:
             328
             110
            7310
216.7
   98
  970
3479
  55
6650
 98
110
                                               900
4537
1600
                                    7700
135
104
                                   903
All analytical fractions were not analyzed for samples taken for this
plant.
                                            G-5

-------
           SCREENING PROGRAM	StMUARY OF PLANT  1?n3fi
St*HARY OF SCREENING DATA
Priority Pollutants Influx Ffflupnt



Phenol 56-80 (2) ND (3)
Base/Neutral Extractables
Aeenaphthene ND-35 (3) ND (3)
Bis (2-ethylhexyl) phthalate ND-180 (2) 38-68 (3)
Di-n-butyl phthalate ND (2) NO-15 (3)
Oiethyl phthalate ND (2) ND-20 (3)
Volatile Organlcs
fcenzenc 260 (1
Carbon Tetrachloride 18 (1
1,1,1-Trichlorocthane 22 (1
Chlorofona 180 (1
1,1-Dlchlorocthylene 230 (1
Ethyl benzene 18 (i
Bsthylene chloride 6200 (1
Triehlorofluorowethane 970 (1
Tctraehloroethylene 14 (i
Toluene 310 (i
Hetals
Antimony 20LT (2
Arsenic 10-50LT (2
Chromium 16 (i
Beryllium ILT (2
Cadalu* ILT (2
Copper 50-73 (2
Lead 5LT (2
Karcury 0.5-1.2 (2
Nickel 10LT (2
Selenium 20-200LT (2
Thallium 8_18 (
Zinc 149-251 (
Cyanide 100-280 (
120 (1
16 (1
11 (1
110 (1
180 (1
22 (1
2600 (1
420 1
18 h
180 (1
10-20LT (3
10-11 (3
20LT (3
ILT (3
ILT (3
5LT-9 (3
5LT (3
0.2-0.7 (3
10LT (3
20LT (31
2) 10-11 (3
2) 60-100 (3
2) 28-30 (3
'
)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Activated Sludge !
Trickling Filter ;
Aerated Lagoon :
Waste Stabilization Pond
Polishing Pond
Aerobic Digestion j
Cropland Use
i
PLANT CHARACTERISTICS
Subcategory Hastewater Quantity (MGD) Employment
A 1-13 100-200
PERFORMANCE OF TREATMENT SYSTEM
BOD (mg/1) COD (mg/1) TSS (mg/1)
J"f.li!SES Effluent Influent Effluent Influent Effluent
1326-1900 (2) 24-35 (3) 2800-4210 (2) 227-262 (3) 700-840 (2) 44-49 (3)s
            WASTEKATER TREATMENT PLANT FLOW DIAGRAM
                                 SAMPLING  PROGRAM
Sample Location
                                                   Ho. of Samples
1 - Influent to Wastewater Treatment System at
      Manhole M-5
2 - Agricultural Research Farm  Discharge to the WTP
3 - Pond 4 Effluent Before Chlorination
4 - 001 Discharge
    Raw Water Supply
    Process Waste Discharge from Penicillin
      Packaging Operation-Manhole 12A
    Combined Process Wastestream at Manhole M-7
6-6

-------
                        SCREENING PROGRAM	Sl»MARY OF PLANT
SUMJARY OF


Priority Pollutants
Acid Extractables
Phenols (Tot.)
Volatile Organics
Benzene
1 , 2-D i chl oroethane
Chloroform
1,1-Dichloroethylene
Ethyl benzene
Trichlorofluoromethane
Toluene
Methyl ene chloride
Metals
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Cyanide
SCREENING DATA
CONCENTRATION (ug/1)

Influent* Effluent
16-17 (2)
10LT-44 2)
15-65 2)
32-56 (2)
62-90 (2
57-160 (2
180-280 (2
120-NQ 2
NQ 2
20LT 2)
14.5-50LT 2)
l.OLT 2)
l.OLT 2)
20LT-26 2)
— 44-63 2)
5LT 2)
0.2-0.4 (2)
10LT (2)
20LT (2)
l.OLT (2)
— 10LT (2
55-63 (2
300 (2)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Fermentation Waste Treatment System Chem. Waste Treatment System
Equalization Equalization
Neutralization Neutralization
Primary Sedimentation Primary Sedimentation
Activated Sludge Primary Chemical Flocculation/
Centrifugal Dewatering Clarification
Anaerobic Digestion Aerated Lagoon
Landfill Centrifugal Dewatering
Anaerobic Digestion
Thermal Oxidation System Landfill
Equalisation Pretreatment System
Neutralization In-Plant Treatment
Thermal Oxidation Heat Conditioning

PLANT CHARACTERISTICS
Subcategory Uastewater Quantity (MGD) Employment
A.B.C.D 2.60 1000-1100



PERFORMANCE OF TREATMENT SYSTEM


BOD (mg/1) COD (mg/1) TSS (mg/1)

Influent Effluent Influent,, Effluent Influent Effluent^
26-30(2) , 	 192-219(2) 	 20-24(2)
* Complex arrangement of multiple raw waste streams prevents simple
H0fVn
-------
                                                               SCREENING PROGRAM


                                                               SUMMARY OF PLANT

                                                                 12038   (continued)
                                                                                       FERMENTATION WASTE TREATMENT SYSTKM
 1.  001 tiischuge
 J.  Ceebiiwd effluent froa liaestone bed and
    hlllaiJe stora sewer
 3.  gliding T-17 process  yaste discharge
 4.  Q»olc*l synthesis influent, T302 to T303
 S.  tt«««n  influent  to  T307B  (clarifier)

        *2  I"°Ce" V"tc  linc feedlna lagoon
         froa Building  1-66
7.  CUeifier T-312 effluent
«.  COiK««Mt«d antibiotic waste - influent to
   t»iolQ9ic*l treataent                          ,
9.  Bllut* antibiotic waste influent to T201       3
W.CUrifier T-212 effluent
   Stora sewer
            raw water supply
                                                                                        SECONDARY THERMAL OXIDATION SYSTEM
            CHtMICAI. HASTE TREATMENT SYSTEM

-------

                                                                                 VERIFICATION PROGRAM
                                                                                  ANALYTICAL RESULTS
                                                                                     PLANT 12038
                                                                                                                                                                           EFFLUENT






n mil umai wp
Apparent
Concentration


Pol lutant
Loading
/l/fl/Haul
Priority Pollutants

O
1
to











Volatile Organlcs
Benzene
1 , 2-0 1 ch 1 oroethane
Ch 1 orof orm
1, I -D Ichl oroethy 1 ene
1 , 2-Trans-O Ichl oroethy 1 ene
Ethyl benzene
Methyl ene Chloride
Monoch 1 orobenzene

Acid Extractables
Phenol
2-Chlorophenol
Pentachlorophenol
Phenol (4 AAP)
Base/Neutral Extractables
Pesticides
• Product X
D 1 propy 1 n I trosoam 1 ne

"Chrom 1 urn
Copper
Zinc
Cyanide
Asbestos
10
10-30
10
10
10-105
10
10-560
10
10


10-50
10-50
10
81-279


13,000-17,000
170-5,500

49-180
40-115
1
50-202
104,00-135,000
(Verification
.001- .0027
.001- .0079
.001- .0027
.001- .0027
.001- .011
.001- .0027
.001- .148
.001- .0027
.001- .0027

• .'
.0023-. 0068
.0023-. 0056
.0027
.009-. 075


3.03-4.49
.04-1.5 '

.0067-.019
.004-. 018
.0001-.0002
.006-. 055
11.1-15
program did not
Conventional

BODc (Concentration In Mb/L)
TSS (Concentration In MG/L)
Non-Convent 1 ona 1 s

COO (Concentration In Mb/L)

4,390-7,130
i

696-1,640

From Chemical
Apparent
Concentration
(ug/Llter)

100-10,300
3,500-14,000
160-690
10-20
10
5,600-42,000
6,400-16,000
26,000-227,000
100-123,000

3 500-6 400
' 10-25*
21,500-48,500

I

5

37-126
5,170-6,670
1-15
313-2,690

analyze for this
3,790-9,300
892-2,140
9,800-21,000

Operations
Pollutant
Load 1 ng
(kg/Day)

.09-9.74
3.31-13.2
.15I-.653
.009
.009
5.30-39.7
6.05-15.1
24.6-215
.09-116

3.31-6.05
.009-. 024
20.3-45.9

.0009

.0047

.035-. 1 19
4.89-6.65
.0009-.0142
.296-2.54

compound )
3,590-8,800
844-2,020
9,440-19,800
INI-LUENI 	 	 	 _ 	 	 	 	 —
	 *n«n+ fionr 	 0 1 1 ute Wastes
	 •3V™ " ' "qCT 	 — 	 _. — _ 	 j 	 •£ 	 — 	 D i 4 .^.-..j. Annarnnt
Apparent Pollutant Apparent ronutanT Apparent
Concentration Loading Concentration Loading Concentration
,"g/"It«rl (ko/Dav) (uq/Llter) (kq/Day) (uq/Llter)
!
10
22-44
10 '
10
10 :
10 ;
16-26
10
10
i



20-23

1-1.9
1- 2

60-81
57-61
1
68-82

32-136 .036-. 159 10-32 .01 1-.031 56-85 .

9,900-10,500 11,600-11,900 674-1,210 I^f*S,n ?»dfi
1,210-1,430 1,410-1.730 548-1,100 524-1,070 28-46
17 100-20.300 20,700-22,900 1,520-2,200 1,450-1,840 216-274
'78-128 ' 91.3-145 2.3-21.8 2.24-24.1 23.7-25

Pollutant
Loading
(ka/Day)

.275
.605-1.21
.275
.275
.275
.275
. .44-,715
.275
.275




.55-. 63

.028-.05
.02S-.05

1.65-2.23
1.65-1.68
.0275
1.87-2.26

1.54-2.34

578-1 ,270
770-1,270
5,940-7,540
652-688
NHj-N (Concentration In  MG/L)

-------
                                           SCREENING PROGRAM	SUMMARY OF PUNT  12066

SU*tARY OF SCREENING DATA
CONCENTRATION (ug/l|

Priority Pollutants Influent Effluent
Acid Extractables
4.6-Dlnltro-b-cresol ND (1) 15 (i
Phenol 45 d) ND |:
Base/HBUtral Extractables
liZ-Olchlorobcnzene 12 (i) ND (1
H-nltrosodiphenylaraine 12 (1) ND (1
Bis (2-ethylhexyl) phthalate 130 (1) 44 (i
Volatile Organlcs
Cnlorofora 51 m un /i
Kcthylene chloride 35 (i) 31 {{
HaUls
SnTliohy 28 (1 9 (i
tos*"te ZOLT 1 30 1
Castelua 7 i g );
ChrcrafuB 136 i 165 fj
Copper 22 i 41 J
"«;:cujy 0.9 i o.s a
Selenium 16 (i 30 (1
Zinc 191 i oca n
•HXi"« ILT 1 ?LT !
H^C'(C1 SLT 1 5LT fl
Th»lH« BOLT 1 50LT(1
Pyanff FLOiV DIAGRAM
       Location
1. Influent to Pretreataont Facility
S. Effluent froa Prctroatacnt Facility
                                       Mo.  of samples
                                                       G-10

-------
                                   SCREENING PROGRAM	SUMMARY OF PLANT _12Q2Z_

SUNWABY OF SCREENING DATA
Priority Pollutants
Acid Extractables
Phenol
Base/Neutral Extractables
Acenaphthene
Benzidine
2,4-Dinitrotoluene
• 2,6-Dinitrotoluene
Bis (2-chloroisopropyl) ether
Volatile Organics
Benzene
Chi oro benzene
1,1,1-Trichloroethane
Chloroform
Ethyl benzene
Methyl ene chloride
Bromoform
Toluene
Metals
Antimony
Aisenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Influent Effluent
19
135
27
32
19
38
92
139
LTDL
LTDL
445
87
ND ,
617
2000LT
2000LT
ILT
6
55
154
119
1.8
31
2000LT
ILT
2000LT
458
ND
ND
ND
14
ND
48
80
LTDL
20
13
LTDL
397
44
LTDL
2LT
2LT
ILT
2LT
8
13
20LT
O.ILT
5LT
2LT
ILT
2LT
60LT
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
rhemical Waste Treatment System Floor H^sl^jre^e"t1^^t^nlovj1
Neutralization ^vi^cSon^ ^^
Chemical°Stab11izition Secondary Chemical Flocculatlon/
Chemical Conditioning Uc1?rit 1" t^?4 ,+,„„
Vacuum Dewatering Chemical Stabilization
Lantm ' ' Vacuum Dewatering
Landfill
PLANT CHARACTERISTICS
Subcategory Hastewater Quantity (MGD) l?.?.1.?^.6."?..
CjD 0.035 If"-200
PERFORMANCE OF TREATMENT SYSTEM
BOD (mg/1) COD (mg/1) TSSjmg/l^
Influent Effluent . Jnf.li1.^ .!f^3"^.t. {.if.VJ?.?.*. .E.t.f.l.u.!.n.t.
	 "'_" 	 "." """ — 262 5LT
Note: Weak chemical waste reported only. Strong chemical waste 1s
deep well injected.
                              25
                                            48
                                         WASTEWATER TREATMENT PLANT FLOW DIAGRAM
Sample Location

Raw Waste  for Deep Well
Treated Waste for Deep Well
Raw Waste  from Floor Drains
Treated Waste from Floor Drains
River Intake
Cooling Water Discharge
Well Water
                               No. of Samples
                                                          G-ll

-------
                                                                       VERIFICATION PROGRAM
                                                                        ANALYTICAL RESULTS
                                                                        •   PLANT 12097
Priority Pollutants
      Volatile Organ Ics
      Benzene
      To Iuene
      Acid Extractables
      Phenol
                                       TAP WATER
                                   Concentration (tig/I)
                                          12
             WEAK CHEMICAL WASTE
 CONCENTRATION (ug/I)  POLLUTANT LOADIN6 (kg/day)
 influent   EffluSnfInfluentEffluent
                                               STRONG CHEMICAL WASTE (Deep
                                                     (Ugyi)  POLLUTMT
                                       influent   Effluent
 15-180
90-6600
                                                           24-58
 3-6
7-49
                                                                        3-5
      Base/Neutral  Extractables
15000-87000   1100-10000
1400-130000    720-75000
                                                                                                               44-5700
                                                                                                                           140-4600
Pesticides
Metals
Antimony
Arsenic
Bery 1 1 1 urn
Cadi mum
Chromium
Copper
Lead
Mercury

"4 J 6-11 1-13 244-336 91-206 1 15-36 1-2 1 i j 134-397 31-154 program did not 1000-3973 85-109 7.1-7.3 39-43 798-1234 350-750 689-1148 309-710 .25-7.5 1762-4685 51 1-665 1.18-4.31 1-2 2 2 3-22 40-44 1 1 6 1-2 1 1 4 1-154 analyze for this compound) 186-240 3.5-16 7.1-7.6 2-5 1380-1662 176-392 1377-1646 174-387 304-508 80-150 .8-1.1 1-2 1-10 1 7-23 2-222 431-922 93-409 1-30 91-447 3-12 1 1 254-540 1-2 - 1-3 1 6-19 2-155 562-665 67-291 1-22 94-378 1-11 1 1 308-687 220-1090 16427-72320 118-354 5.0-6.7 79-216 19742-31148 1596-3736 19624-30794 1517-3520" .3-130 40000-92928 13000-18000 252-455 69-5900 37760-54400 9-22 4.6-6.6 6-20 20652-30364 2068-3616 20634-30355 2582-3610 .1-.4 20200-78731 14500-20200 297-435 Influent Effluent


-------
SCREENING PROGRAM	SUMMARY OF PT.ANT  12108
SUMMARY OF

Priority Pollutants

Acid Extractables
Phenols ( 4AAP)
Volatile Organics
Benzene
Carbon tetrachloride
1,1,1-Trichl oroethane
1,1-Dichloroethane
Chloroform
Methyl ene chloride
To! uene
Metals
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Zinc
Selenium
Thallium

Cyanide

SCREENING DATA
CONCENTRATION (ug/1)
Influent* Effluent


925 (1)
390 (1)
300 (1)
1300 (1)
0.1 (1)
1350 (1)
200000 (1)
53 (1)

NAI
NAI
10LT (1)
32 (1)
107 (1)
116 (1)
286 (1) —
50 (1)
137 (1)
24 (1)
522 (1)
NAI
NAI

2LT 	

WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Neutralization
* Plant 12108 is a zero discharger. Influent sample was taken
from a tank truck holding waste to be trucked off site.









PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (HGD) Employment
A.C.D — . 30°-400
t


PERFORMANCE OF TREATMENT SYSTEM


BOD (mg/1) COD (mg/1) TSS (mg/D

Influent Effluent Influent Effluent Influent Effluent

11300 	 25900 — 2640
    WASTEWATER TREATMENT PLANT FLOW DIAGRAM
                    NOT APPLICABLE







                 SAMPLING PROGRAM




        Sample Location        No.  of Samples




         Raw Process Wastewater      1
                               G-13

-------
             SCREENING PROGRAM	StMttRY OF PLANT  12119
SU.WARY OF SCREENING DATA
Priority Pollutants Influent Effluent
Acid Extractables
'l-Hitrophcnol ND
PenUchlorophenol 42
Phenols (4AAP) 190
Base/Neutral Extractables
bis (2-chloroisopropyl) ether 448 (
Isophorone 11 (
Butyl benzyl phthalate 18 (
Volatile Ornanlcs
1,1,1-trlchloroethane 10LT (
Kethylenc chloride 23 (
Hfltals
Antlsony 40
Arsenic 10LT
Beryllium 10LT
Chromium 57
Copper 93
Lead 75
Hercury 5.5
Nickel 112
SclcniuBi 28
Thallium NAI
Zinc 1395 (
Cyanide 2LT (
1) 15 (1)
1) 10LT (1)
2) 5LT (1)
1) ND (1)
1 ND 1
1} ND (1)
1) 10 (1)
1) 349 (1)
1 NAI
1 NAI
1 10LT 1)
1 19 1)
1 39 1)
1 89 (1)
1 0.5 1)
1 50 (1)
I) NAI
2LT (1)
I) 403 (1)
L) 2LT (1)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Neutralization '
Coarse Settleable Solids Removal
Primary Sedimentation:
Activated Sludge
Phys./Chem. Evaporation
Anaerobic Digestion
Drying Beds
Sludge to POTW
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (HGD) Employment
A,D ' .032 N/A
PERFORMANCE OF TREATMENT SYSTEM
KP.11!?/..1.) : co° ("19/1 ) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
833 10 1410 232 475 10
               WASTEWATER TREATMENT PLANT FLOW DIAGRAM
                        Not available.
Sample Location

Raw process water
Process Wastewater
Stripped Wastewater
Influent to treatment
Effluent from treatment
                          SAMPLING PROGRAM
ijo. of Samples
                                 6-14

-------
                                  SCREENING PROGRAM	SUMMARY OF PT ANT  12132
SIM1ARY OF SCREENING DATA
CONCENTRATION
Priority Pollutants
Add Extractables
2-Nitrophenol
4-Nitrophenol
Phenols (Tot.)
Base/Neutral Extractables
Bis (2-ethy1hexy1) phthalate
Di-n-butyl phthalate
Volatile Organics
Benzene
1,1,1-Trichloroethane
l,l-D1chloroethane
Chloroform
• Ethyl benzene
Heth'ylene chloride
Toluene
Metals
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Zinc
Cyanide
Influent
119 (1)
181 (1)
188 (1)
ND (1)
ND (1)
100GT (1)
19 (1)
5 (1)
100GT (1)
100GT (1)
100GT (1)
50 (1)
10LT (1)
20GT (1)
200 (1)
200 (1)
200LT (1)
0.7 (1)
50LT (1)
10LT (1)
600LT (1)
1485 (1)
J.??/.1.!
Effluent
ND (1)
ND (1)
126 (1)
liil
ND (1)
ND 1)
ND 1)
ND 1)
ND 1)
100GT (1)
ND (1)
400 GT (1)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Neutralization
Coarse Settleable Solids Removal
Primary Sedimentation
Primary Chemical Flocculation/Clarification
Activated Sludge
Trickling Filter
Waste Stablization Ponds
Flotation Thickening
Centrifugal Thickening
Centrifugal Dewatering
Incineration
Landfill
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (HGD)
A,C 1.02
PERFORMANCE OF TREATMENT SYSTEM
BOD (mg/1) COD (mg/1) TSS
Influent Effluent Influent Effluent Influent
Employment
300-400
(mg/1)
Effluent
420 246 5512 1803
                                      WASTEWATER TREATMENT PLAMT FLOW DIAGRAM
        a'
                                               *!7I
&i_._"7,;
C-T '!••
AVa.'
os.y-i
                                                 TSS,
                                                                                          Sedimentation Basin Effluent
                                                                                          Final Clarifier Sludge
                                                                                          Final Clarifier Effluents
                                                                                          DAF Skimmings
                                                         6-15

-------




SCREENING PROGRAM 	 SUf.MARY OF PLANT I?1fi1

SU.MARY OF SCREENING DATA


PrtoHty Pollutants
Acid Extractables
Phenol ics
Base/Heutral Extractables
&\s (Z-ethylhexyl) phthalate
Volatile Organics
benzene
1,1,2-Trichloroothane
Chloroethane
Chloroforn
Ethyl benzene
Bethylene chloride
Toluene
totals
Ant1«ony
Arsenic
Beryl Hun
Cficfwf UBI
Chromtun
Copper
Lead
Nickel
Silver
Zinc
Cyanide

CONCENTRATION (ug/1)

Influent

Effluent
57-204 (2) 8-16 (2)
39 (1) 0.10LT (1)

48
0.9
6.1
1050
7.5
2.2
10400

24 (
20LT (
1.6 (
32
14
27
46
89 (
4 (
250 {]
40LT (2


1) 0.01LT (1)
1) 0.01LT (1)
1) 0.01LT (1)
I) 2.8 (1)
1) 0.01LT (1)
U 1.7 (1)
I) 0.01LT (1)

I 0.17 (1)
L 20LT (1)
I 0.20LT (1)
1 l.OLT (1)
L 2.0LT (1)
L 0.2LT (1)
L 10LT (1)
I 56 (1)
L 3LT 1)
I) 14 (1)
!) 40LT (2)

WASTEWATER TREATMEOT PLANT UNIT OPERATIONS
Equalization
Neutralization
Coarse Settleable Solids Removal
Primary Sedimentation
Primary Chemical Flocculation/Clarification
Activated Sludge
Polishing Ponds :
Gravity Thickening
Aerobic Digestion
Compositing
Landfill
Cropland Use


PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (MGD) Employment
""*""""*""
. A,C,D 1.33 900-1000


PERFORMANCE OF TREATMENT SYSTEM

?.°.P.lm?/.].! co° ("19/1 ) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
748-1043(2) 34-61(2) 1800-3000(3)600-780(3) 150-398(3) 60-88(3)
WASTEWATER TREATMENT PLANT FLOW DIAGRAM
CHLoraie poo-Men AMMOWU
j I PHOSPKSfilC AC10
©i .~i., i 	 — 	 !
pt— 	
— 	 	 	 2 «— |
CL, TANK 	
* POLISHING POflDS
'«'***-£ cxeSu 	 *E™!LCB «_„.
X^^/ TANKS If G 1^ il
usafi • y
- »H-UfJC raw SUPENHATAHT "
--eHfii;e*tj 1 i'l
X
M
PRS-CUn«EJ! stUOOE ' ^
^ U
uJ
" 1
fSECONO\ SECOND STAGED j
\FINAL J ' n
X___X AERATIOK
I TANK 4
*
RETURN ^LUOGE zcJ STAGE
< "CESS SLUOGE L .^^^
Kruiw suiDGf i:: OT.'.G-
t '.
FIRST STAGE ' /*~
\ . T.v.x 3 /FiRSl
>jj
t?
3 ^
'os
as
ti
O LJ
H
dr:
i
^
iltri"-'" VsSf J 1 J 2 L t.~*(cLAt>rer,;) iri - -1 -[STAGS j 	 ; 	 J
' ' * V nf J < AERATIOM VFIKAL /
u 	 -1 V^L/ [.... TANS 2 V /
EQUALIZATION PONDS
LIME rOL^UQ
sut.runic ACID
SAMPL
Sample Location


	
	 T 	
AMVCXIA 	 	 ' 	
tt*>*"«X>X ™° lsaHM
ENG PROGRAM
1. Raw waste (combined) to wwrp 5
2. Discharge 001 - Treated from WWTP t 	 5
Raw waste - Plant A 	 	
Raw waste - Plant B 	 ' 	 ^ 	
Raw waste - Plant C 4
6-16
	

-------
            SCREENING PROGRAM—-SUMMARY OF PLANT   1??na
SUMJARY OF SCREENING DATA
CONCENTRATION (ug/1)

Priority Pollutants Influent Effluent
Acid Extractables

2,4 Dimethyl phenol 62 (1) 0.10LT (1)
Phenol 38 (1) 3.8 (1)
Phenolics 134 (1) 17 (1)
Base/Neutral Extractables
Bis (2-ethylhexyl) phthalate 0.10LT (1) , 25 (1)
Volatile Organics
Acrolein 100LT (1) 100LT (1)
Acrylonitrile 100LT (1) 100LT (1)
Benzene 6.5 1) 0.10LT (1)
Chlorobenzene 1.9 1 0.10LT (1)
1,2-Dichloroethane 28 1 0.10LT (1)
1,1,1-Trichloroethane 27 (.1) 33 (1)
Chloroform 150 (1) 90 (1)
1,1-01 chloroethylene 2.1 (1) 0.01LT (1)
Ethyl benzene 14 (1) 0.01LT (1)
Hethylene chloride 1400 (1) 0.01LT (1)
Trichlorofluoromethane 0.9 1) 0.01LT (1)
Tetrachloroethylene 1.91) 1.4(1)
Toluene 190 1 0.01LT (1)
Trichloroethylene 6.6 1 0.8 (1)
Metals
Antimony 20J (1) 8J (1)
Arsenic 20LT 1) 20LT (1)
Beryllium 0.2LT 1) 0.2LT (1)
Cadmium 4J 1) 1LT (1)
Chromium 23 1) 19 (1)
Copper 88 J (1) 16 (1)
"Lead 63J (1 20 (1)
Mercury 1.3 (1 1.3 (1)
Nickel 28 1 37 1)
Silver 6J 1 31)
Thallium 7LT 1 7LT 1)
Zinc 500J 1) 300J 1)
Cyanide 40LT (1) 40LT (1)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Neutralization
Coarse Settleable Solids Removal •
Primary Chemical Flocculation/Clarification
Activated Sludge with Pure Oxygen
Mechanical Thickening
Chemical Conditioning
Vacuum Dewatering
Compositing
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (MGD) Employment
A.B.C.D 0.85 2000-2100
PERFORMANCE OF TREATMENT SYSTEM
BOD (mg/1) COD (mg/1) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
690-1090 (3) 15-75 (3) 1215-1815 (3) 243-303 (3) 900-1200 (3) 90-120 (3)
Traditional data supplied by plant.
               WASTEWATER TREATMENT PLANT FLOW DIAGRAM
                   Not available.
                     SAMPLING PROGRAM
Sample Location
Municipal water
Well water
Combined influent
Final effluent
Building "A" process wastewaters
No.  of Samples

     4
     4
     5
     5
     5
                                         G-17

-------
           SCREENING PROGRAM	SUM.IARY OF PLANT   12210
SWtlAW OP SCREENING DATA
CONCENTRATION (ug/1)
Priority Pollutants Influent Effluent
Acid Extractables
4-Nhrophenol IOLT
Pentachlorophenol IQLT
Phenol IOLT
Phenols (4MP) 420
Basa/Meutral Extractables
Bis iz-ethyinexyi) phthalate 2700
Ofethyl phthalate IOLT
Fluorene IOLT
It-nUrosodiphenylamlne 10LT
Volatile Orqanlcs
Benzene 7 7
Chloroform 5^7
Ethyl benzene 5Q
Hethylene chloride 150
Tetrachloroethylene 5LT
Toluene 5LT
1,1,1-Trichloroethane SLT
Kotals
JuHony 10UT
Arsenic 10LT
Beryl Hum IOLT
Cstalius 10LT
Chroiaiwi 56
Copper 147
|;e*d NAI
Mercury 0.48
Klcfccl 96
felenlw 10LT
Silver IOLT
ThalHua 10LT
Zinc 503
.CyMJdc 4 (
{,
(]
a
8
!!
j!
1
!
i
i]
1
i
i)
i)
i)
L)
Li :::
>
i
—
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Aerated Lagoon (Receives only sanitary waste)
of ^ff 'site 1S a 2er° diischar9er- A11 P^cess wastewater is disposed
i
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (HGD) Employment
B>C -002 100-200
PERFORMANCE OF TREATMENT SYSTEM
BOD {rag/1 ) : COD (ng/1) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
480
              WASTHYATER IREABENr
                        Not available
                                          FIXHV DIAGRAM
                         SAMPLING PROGRAM
       Location
process wastowater at waste storage tanks
Influent to pretreatment system for sanitary
wastewater
Effluent from pretreatment system for sanitary
wastewater
                                                         of Samples
                               6-18

-------
        SCREENING PROGRAM	SUMARY OF Pt.ANT  12231
SWtlARY
Priority Pollutants
Acid Extractables
. Phenols (4AAP)
Volatile Organics
Hethylene chloride
Metals
1 Antimony
1 Arsenic
Beryl 1 ium
1 Cadmium
1 Chromium
1 Copper
1 Lead
1 Mercury
Nickel
1 Selenium
Thallium
Zinc
1 Cyanide
OF SCREENING DATA
CONCENTRATION (ug/lj
Influent Effluent
180 (1
20LT (1
10LT (1
10LT (1
10LT (1
57 (1
150 (1
18 (1
0.72 J
10LT 1
10LT 1
NAI
208 (]
2LT (]
) 20 (1)
72 (1)
) 20LT (1)
) 10LT (1)
) 10LT (1)
10LT 1)
51 1)
59 1)
89 1)
) 0.5 1)
) 22 1)
) 10LT 1)
5 1)
) 48 (1)
) 2LT (1)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Neutralization
Coarse Settleable Solids Removal
Primary Sedimentation
Aerated Lagoon
Waste Stabilization Ponds
Anaerobic Digestion
Landfill
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (HGD) Employment
A,D 0.50 600-700
PERFORMANCE OF TREATMENT SYSTEM
BOD (mg/1) COD (rag/1) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
3200 147 2160 436 113 12
           WASTSVATER TREATMENT PLANT FLOW DIAGRAM
      To
                          SAMPLING PROGRAM
Sample Location

1. Influent -  raw waste to treatment
2. Intermediate WW'P point
3. Final effluent
   Raw process water
No.  of Samples

     2
     2
     2
     1
                                   G-19

-------
                                             SCREENING  PROGRAM	SWMARY OF PLANT   12236
SU.MARY OF SCREENING QVTA
CONCENTRATION (ug/lj
Priority Pollutants Influent Effluent
Acid Extractables
Phenols (4AAP) 780
Bise/Heutral Extractables
Bis (2-chloroethyl) ether 10
l,Z-Dtph«nyl hydrazine 20 i
Volatile Organlcs
oenzcne 40
Chloroform 30
Methyl ene chloride 40000
Ethyl benzene 12
Toluene 33000
1,1-Dlchloroethylene 190
Kethyl chloride 1300
Brcnmethane 30
Hauls
fintTiony NAI
Arsenic NAI
Beryllium 10LT /
Ca*ti(iw 10LT (
Chromium 34 |
Copper 16
tead NAI
Kfcury 0.2LT
Hickel 63
Selenium HAI
Silver 10LT (
Thallium 30
Zinc 191 I
Cyanide 560 (
1) 580 (1)
1) 20 (1)
1) ND (1)
1
1
1 200 (1)
1 1350 (1)
1 "I
1)
NAI
NAI
1 10LT (1)
1 10LT (1)
1 10LT (1)
1 10LT (1)
1 96 1)
1 0.80 (1)
I) 63 (1)
NAI
1) 10LT (1)
1 NAI
1) 34 (1)
1) ' 220 (1)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equal Ization
Neutral Ization
Primary Sedimentation
Activated Sludge
Flotation Thickening
Chemical Conditioning
Vacuum Dewatering '
Landfill :
PLANT CHARACTERISTICS
Subcategory Uastewater Quantity (MGD) Employment
C ! -810 200-300
PERR3K.IANCE OF TREATMENT SYSTEM
BOD (rag/1) COD (mg/1) TSS (mg/1)
Influent Effluent . Influent Effluent; Influent Effluent
1200ST 300 3500 1370 188 94
                                                WASTEWATER TREATf-IBrT PLAfH1 FLOllT DIAGRAM
faar>lc location
                    SflHPLMO PBOCRAM
                                                                                                           EFFLUTIJT
                                                                                                           FLOW METER
I. Influent to wastewater treatraant system

-------
r
                                 VERIFICATION  PROGRAM
                                  ANALYTICAL RESULTS
                                     PLANT  12236
                                 Adjusted Concentration    Pollutant Loading
Influent Effluent
(ug/Liter) (ug/Liter)
Priority Pollutants
Volatile Organics
Toluene
Methylene Chloride
Chloroform
1 , 1-Dichloroethylene
1 , 2-Dichloroethane
Benzene
Ethylbenzene
Ch lorome thane
Acid Extractables


56,000-71,000
14,000-80,000 1
10
10-16
68-560
10-27
10-12
8,000-13,000



10
500-8100
10
10
62-300
10
10
100-410

Influent
(kg/day)


170-210
42-2403
.030
.030-. 048
.2-1.7
.030-. 081
.030-. 036
24-39

Effluent
(kg/day)


.032
4.8-26
.032
.032
.2-. 96
.032
.032
.32-1.3

Base/Neutral Extractables
Pesticides
Metals
Beryl ium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
Cyanides
Phenol (4AAP)
Asbestos

Conventional
BOD
Non-Conventional


10
10
42-152
14-16
40
0.62-0.69
26-39
40
10
69-159
20-270
940-1900
(Verification
compound )

1023-1266



10
10
10-16
10
25
0.2-0.56
21-30
40
10
13-173
9-228
55-455
program


130-140



.030
.030 .
.126-. 456
.042-. 048
.12
.002
.078-. 117
.12
.030
.2-. 477
.06-. 81
2.82-5.7


.030
.030
.03-. 048
.030
.075
.0006-. 0017
.063-. 09
.12
.030
.039-. 52
.027-. 684
.16-1.4
did not analyze for this


3070-3800



390-420

          COD
1904-2641
633-640
5712-7923  1900-1920
                                            G-21

-------
SCREENING PROGRAM	SUMMARY OF PLANT

SU-tlARY OF SCREENING DATA
CONCENTRATION (ug/1
Priority Pollutants Influent Efflue
Acid Extractables
Phenols (Tot.) 694 (1) NO
Base/Heutral Extractables
&ls (2-ethylhexyl) phthalate 50 1) 10
EH-n-butyl phthalate 20 1) 4
Volatile Orqanics
1,2-Dlchloroethane 15 1 ND
1,1,1-Trlchloroethane 17 1 ND
Chloroform 100GT 1 ND
Bethylene chloride 100GT 1 100GT
Toluene 2 (1 ND
totals
BeryTTiuw 1LT (i) ILT
Cadwiu* 2LT (1) 4
Chromium 30 (1 10
Copper 80 (1 20
lead 20LT (1) 20LT
Hlckel 5LT (1 5LT
Silver ILT (1) ILT
Zinc 60LT (l) 100
Cyanide 25LT (1) 25LT (
1
nt
(1)
(1)
(1)
1
1
1
1)
1)
1)
I
I
l\
1)
1)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Coarse Settleable Solids Removal
Activated Sludge
Mechanical Thickening
Aerobic Digestion
Gravity Dewatering ',
Landfill
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (HGD) Employment
D .035 800-900
PERFORMANCE OF TREATMENT SYSTEM
BOD (mg/1) COD (mg/1) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
. —
   WASTEWATER TREATMENT PLANT FLOW DIAGRAM
           1. Influ'-.'lt To KWTP
           2. Efflil'tit from wvn-p
                                                                         G-22

-------
                          SCREENING PROGRAM	SUM-tARY OF PLANT   12256
SUMMARY OF SCREENING DATA
CONCENTRATION (up/1)

Priority Pollutants

Add Ex trac tables
Phenol
Volatile Organics
Chloroform
Methylene chloride
Toulene
Hetals
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
1 Mercury
1 Nickel
Selenium
Silver
Thallium
1 Zinc





Influent Effluent






10 (1)* 33 (1)<

40 (
300LT (


0 40 (1)
I) 300LT (1)
100J (1) 100J (1)


400LT-1000LT (2) 400LT-1000LT
Cl T 1 O /O\ CI X 1 A
Dl_ I - 1 3 V
10LT (,
10LT-40 (
50LT ('
100LT (I
100LT-500 (.
0.2-10 (,
100LT-300
5LT-21 .
5LT-40 /
100LT !
-i yi.i~i*?
I 10LT
2 10LT-40
I BOLT
2 . 100LT
2) 100LT-400

2)
9^
<•)
2)
2)
2)
2)
2)
2) 0.2-0.7J (2)
2) 100LT-300 (2)
2) 5LT-12
2) 5LT-40
2) 100LT
2
2
2
50LT-310 (2) 50LT-230 (2






1 * Influent and effluent samples believed to be
| Interchanged when labeled.
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Neutralization
Coarse Settleable Solids Removal
Primary Sedimentation w/Skimming









PLANT CHARACTERISTICS

Subcategory Wastewater Quantity (MGD)

A.B.C.D 30.0



PERFORt.lANCE OF TREATMENT SYSTEM
BOD (mg/1) COD (mg/1) TSS
Influent Effluent Influent Effluent Influent
— .177-242(3) — 300-420(3)
Traditional data supplied by plant.











i




Employment

1200-1300




(mg/1)
Effluent
29-42 (3)
                            WASTEWATER TREATMENT PLANT FLOW DIAGRAM


                                        NOT AVAILABLE




                                      SAMPLIHG PROGRAM

                                Sample Location

                                Well Area before Discharge Through Outfall #001
                                Split Manhole Discharging To Outfall #002
                                Manhole Prior to Discharge To Outfall #003
                                Skimming Basin Which Discharges To Outfall #008
                                Collection Basin Discharge to the Skimming Basin
                                Municipal Sewers Pumping station
                                Raw Freshwater Supply '
                                Saltwater Supply At Intake structures
NOTE:   ALL REPORTED  CONCENTRATION  VALUES HAVE  NOT  BEEN CLEARLY ASSOCIATED
         WITH  PROCESS  FLOW STREAMS.   THEREFORE DATA  FROM THIS  SAMPLING EFFORT
         WILL  NOT  BE USED  IN  S/V DATA  ANALYSIS.
                                           G-23

-------
  SCREENING PROGRAM	SUMMARY OF PLANT   12257
StJMIARY OF SCREENING DATA
CONCENTRATION (ug/1)
Priority Pollutants Influent
Acid Extraetables
Fncnol (Tot.) 320LT-4700 (
Volatile Organics
l,Z-Dichlorocthane
Hethylcne chloride
totals
Antimony 12-100LT (
Arsenic 10LT-43 (
Beryl H wa l
Cadmium l.OLT
Chrosilum 630-650
Copper 97-110 I
Lead 5LT-14 !
Mercury 0.20LT <
Nickel 56-630 <
Selenium IOL.T ;
Silver 2LT-4LT :
Thallium 40-43 2
Zinc 289-319 (2
Cyanide 440-580 (2
Effluent
2} 50LT-540LT(3
13-290(3
30-67(3
2 10LT(3
2 10LT-20(3
2 1LT(3
3 1.0LT(3)
2 160-190 3
> 21-31 3
'. 20-24 3
> .20LT(3
'. 160-190(3
! 10LT(3)
1 2LT(3)
10LT-29(3
) 113-163(3
) 70-7700(3)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Neutralization ;
Activated Sludge '
Centrifugel Dewaterring
Cropland Use
. PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (H6D) Employment
	 i 	 	
A.B.C.D r .600 2100-2200
PERFORMANCE OF TREATMENT SYSTEM
?.°.P.lm9/1) C00 (mg/1) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
3100-4500 (2) 36-56 (3); 4610-6430 (2) 482-626 (3) 876-968 (2) 94-144 (3)
    WASTEWATER TREATMENT PLANT FLOW DIAGRAM
Sample Location
                                      No.  o£'...SampI gs
1. Raw fermentation process wastes
2. Raw chemical synthesis process wastes
3. Combined plant process wastes after
   neutralization
4. Treated effluent to WWTP
   Cooling water discharge at bypass line
   "nricipal water  supply
G-24

-------
r
                                                     SCREENING PROGRAM	Slf*IARY  OF PT.ANT  12342
SIM1ARY OF SCREENING DATA
CONCENTRATION (ug/1)
Priority Pollutants
Acid Extractables
Phenol
Base/Neutral Extractables
Bis (2-ethylhexyl) phthalate
Volatile Organics
Chloroform
Toluene
1,1-Dichloroethane
Ethyl benzene
Acrolein
Metal s
Antimony
Arsenic
Cadmium
Chromium
Copper
Lead
Nickel
Selenium
Silver
Thallium
Cyanide
* Plant 12342 is an indirect
influent is an influent to
Influent * Effluent
14000 (1)
760 (1)
2 (1)
2 1)
2 1)
1 (1)
100LT (1)
27 1)
20LT 1)
1LT 1
20 1
130 1)
10LT 1
22 1
20LT 1
3LT (1)
8LT (1)
40LT (1)
discharger and the
a POTW.
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
NO TREATMENT PROVIDED
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (HGD) Employment
A,C,0 .701 300-400
PERFORMANCE OF TREATMENT SYSTEM
BOD (mg/1) COD (mg/1) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
5810 — 12840 — 3480
                                                        WASTEWATER TREATMENT PLANT FLOW DIAGRAM
                                                                       NOT APPLICABLE
                                                                       SAMPLING PROGPAM
                                                        Sample Location

                                                         Discharge  from Manhole No. 1
                                                         Discharge  from Manhole No. 5
                                                         Discharge  from Manhole No. 6
                                                         Discharge  from Manhole No. 7
                                                         Potable  Water -  Building 28
                                                         Potable  Water -  Building 1
                                                         Potable  Water -  Building 5
                                                         Potable  Water -  Building 20R
No. of Samples

     3
     3
     3
     3
     1
     1
     1
     1
                                                                                  G-25

-------
         SCREENING PROGRAM	SUMMARY OF PLANT  12411
SUMMARY OF SCREENING DATA
CONCENTRATION (ug/1)




Priority Pollutants Influent Effluent

Acid Ex trac tables


Phenol 34 (1) 10LT (1)
Phenols (4AAP) NAI 70 (1)
Base/Neutral Extractables

Bis (2-ethylhexyl) ph thai ate 38 (1) 28 (1)
Volatile Qrganics
Benzene 6.7
Chloroform 860
ft ht/l hiftn9Ann Rl T
ciny lucfizcnQ OLI
Tetraehloroethylene 5LT
1
1
i
NO
5LT
wn
nu
ND
Toluene 290 (1) 5LT
Kethylene chloride 11000 (1) 32
totals
Antimony 68 (1
Arsenic 32 1
Beryl Hun 10LT
Cadiaiw) 10LT
Chroaiua 16
Copper 35
Lead 80
Kercury NAI
Nickel 20
Selenium 30
Silver 10LT
Thai Hun 5
i
I
i
i
i
i
!
Zinc 146 (1
Cyanide 590 (1)
NAI
NAI

1)
}
l)
1)
1)
1)


10LT (1)
i nt T M \
1UU 1
16
tl
26 (1)
NAI
1.58
40
NAI
10LT (
7
99
52
1)
1)
1)
i)
1!
i)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Neutralization
Aerated Lagoon
Incineration









PLANT CHARACTERISTICS
Subcategory Uastewater Quantity .(MGD) Employment
B.C.D 0.35 700-800


PERFORI.IANCE OF TREATI.IENT SYSTEM

BOO (mg/1) COD (mg/1) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
167GT 167GT — — 316 585
            WASTEWATER TREATMENT PLANT FLOW DIAGRAM
                        .
                         ni
                        .
                         n
                                           j ro,t>oa
                                  itccso
                                  1   JURU
                                  c .   comiottu
                                  r   noi
                                  1   IKDICilOR
                                  11   LIOUIB UY£l
                                   i   BECOME*
                                   1C  13UI C1RI!K
                                   TflC  IQIU CIC1SIC C1M3H
       Location
                            SAMPLING PROGRAM
1. Influent to pretreatment system
2. Effluent from pretreatment system
   Combined sanitary cooling water and pretreated      '•
   process wastewater at access pit                    13
No. Of Samples

     ;3
                                  6-26

-------
                             VERIFICATION  PROGRAM
                              ANALYTICAL RESULTS
                                  PLANT  12411
                                 Concentration
                           Pollutant Loading
Priority Pollutants

      Volatile Organics  ,
      Toluene
      Methylene Chloride
      Chloroform

      Acid Extractables
                               Influent
                              (ug/Liter)
              Effluent
             (ug/Liter)
            Influent
            (kg/day)
             Effluent
             (kg/day)
      10
  110-380
11000-280,000
      2-Chlorophenol               10
      2-Nitrophenol                14
      Phenol                       10
      2,4-Dimethylphenol           10
      2,4-Di chlorophenol           10
      2,4,6-Trichloro Phenol       10
      4-Chloro-3-Methylphenol      10
      2,4-Dinitro-2-Methylphenol   10
      Pentachlorophenol            10
      4-Nitrophenol                10

      Base/Neutral Extractables

      Pesticides
   10
   10
 10-170
                 10
                 10
                 10
                 10
                 10
                 10
                 10
                 48
                114
                 10
      Metals
      Berylium
      Cadmium
      Chromium
      Copper
      Nickel
      Lead
      Selenium
      Zinc
      Mercury

      Cyanides

      Asbestos
Convent ional
      BOD

Non-Conventional

      COD
     10
     10
   35-89
   20-30
  126-130
     25
     40
  111-388
    1-310

   96-268
   10
   10
 27-40
 19-21
 51-85
   25
   40
110-2009
.74-.96

144-254
,0086-.011
 .095-.33
  9.5-310
              .01
              .015
              .011
              .011
              .011
              .011
              .011
              .011
              .011
              .011
,0086-.011
,0086-.011
,0086^.19
                .011
                .011
                .011
                .011
                .011
                .011
                .011
                .053
                .13
                .011
    .009
    .009
  .03-.095
 ,018-.03
 ,113-.136
    .027
    .04
  .12-.39
    0-.0045

  106-260
    .009
    .009
    .036
    .02
 .055-.07
    .27
    .04
  .12-1.7
     0

  160-246
  (Verification program did not analyze for this
   compound)
   1470
  294
   1270
    254
 4400-5750    2900-3300   4830-5600   2770-3610
                                      6-27

-------
SCREENING PROGRAM—SUMMARY OF PI.ANT  12420
SU-MARY
Priority Pollutants
Acid Extraetables
i-Mltrophenol
Phenol
Volatile Organics
Benzene
Toluene
fatal s
beryllium
Cadmium
Chromium
Copper
Lead
Hereury
Nickel
Zinc
Cyanide
OF SCREENING DATA
CONCENTRATION (ug/1)
Influent
23 (1
240-51000 (2
580 (1
1050 (1
ILT (1
2LT h
212 (1
106 (1
27 (1
0.4 (1
5LT 1
151 (1
5LT (1)
Effluent
) ND (1)
I ND-120 (2)
NO (1)
LTDL (1)
ILT (1)
2LT 1
304 1
14 1)
42 1
0.1 (1
5LT (1
83 (1
5LT (1)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Activated Sludge
Chemical Conditioning
Centrifugal Dewatering
Landfill
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (MGD) Employment
B,D — 100-200
PERFORMANCE OF TREATMENT SYSTEM
BOD (mg/1) , COD (mg/1) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
3250 195 355 638 	 490
   WASTEKATER TREATMENT PLANT FLOW DIAGRAM
t*. .1.1.1
<»»;.* •
ii
|i-u
> r
111

I*AI


'MM.*- f
®
>T 	
V_J
IF
V*
ill
i i
— i
i
.-.*
s?£ -
i»
H —
-«-
ji.u. O 1 s*
n'S' ' '' \
* I CM 1*1 11 \
4J \ 	 k

Sample Location
1. Influent to pr
2. Effluent from
Rescreening: 1
2
,v


^^^^ 20,000 Cal/H^y
,6t< rr?j nc^ 	
,000 Pl-D EC1[!5
,Kt TKS TSS
,1 .SJl rw rr.s txn
Ri.-,,! 	 >A:A ;5 Ji; p.i;.
3r..l:..ir.c V. J U(>
(l=.,li ricx) >^ S7
B.U v.,.t. r,« ru.vt jj£
SAMPLING PROGRAM
No. of
H't . I/-,.
4 i
20.000 Callon ' " -^jii^l
Clarltlcr ' j "•• | ' ^O1 ,„,„„,.
	 ! 	 "' , 190,000 aro
' >!„.•., m,..!, 	 ttfc FfM SOff
flu«,.B|Troi.rh l.COOWJ BOD
* Tot,-.l 52.3M CPO i,
-------
                     SCREENING PROGRAM	SUMMARY OF PLANT  12439
SIS-MARY OF SCREENING DATA
CONCENTRATION (ug/lj
.•••••••••••••••••••*••••••••"•'
Priority Pollutants Influent Effluent
Add Extractables
2,4-Dimethyl phenol 10LT (1 15
Phenols (4AAP) 42 (1 36
Base/Neutral Extractables
Acenaphthene 9Z (1) NO
2,4-D1n1trotoluene 65 (1) 10LT
B1s (2-Chlorosopropyl) ether 300 1) 181
Isophrone 1014 (1) 10LT
Butyl benzyl phthalate 719 (l) ND
01-n-butyl phthalate 19 (1) 10LT
Dlethyl phthalate 61 (1) ND
Anthracene 14 (1) 10LT
Fluorene 27 (1) 10LT
Phenanthrene 14 (1) 10LT
Volatile Organics
Benzene 73 (1) 10LT
Chlorobenzene 12 (1) ND
1,1,1-Trlchloroethane 261 (1) 10LT
1,1,2-Trlchloroethane 19 (1 ND
Chloroform 26 (1 16
Ethyl benzene 82 (1 10LT
Methyl ene chloride 640 (1 108
Tetrachloroethylene 26 (1 ND
Toluene 342 (1) 270
Trlchloroethylene 124 (1) 11
Metals
Antimony 20LT (1 20L
Arsenic 10LT (1 10L
Beryllium 10LT (1 10L
Cadmium 10LT (1 10L
Chromium 9 (1) 1
Copper . 32 (1) 3
Lead ' 10LT (0) 1
It
.!
!
1)
18
(l)
i)
l
i
1 .
:i
i)
i)
1}
T (1)
T 1)
T 1)
T 1
5 1
2 (1
4 (1
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Neutralization
Primary Sedimentation
Activated Sludge
Aerated Lagoon
Landfill
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (MGD) Employment
C,D 0.01 100-200
PERFORMANCE OF TREATt.a-OT SYSTEM
BOD (mg/1) COO (mg/1) TSS (mg/1)
Influent Effluent Influent ' Effluent Influent Effluent
6841 2297 10 125
CONCENTRATION (ug/1)
Metals (Continued) Influent Effluent
Mercury 0.67 (1) 0.76 (1)
Nickel 10LT (1) 10LT (1)
Silver 10LT (1) 10LT (1)
Thallium 5 (1) 8 (1)
Z1nc 29 (1) 153 (1)
Cyanide 2LT (1) 2LT (1)
                         WASTEWATER TREATMENT PLANT FLOW DIAGRAM
Raw Waste	^Neutralization	^-Primary Sedimentation-
(activated sludge)	>-Lagooning.
                                                                    —^-Aeration  Units
Design Considerations

Detention  time of Aerators—2 hrs
Detention  time of lagoons	 60 days
Treatment  Plant Capacity——30,000 gpd
Solvent Wastes	>-recovery
                              SAMPLING PROGRAM
                Sample Location
                Industrial Stream Influent
                Secondary Clarifier Effluent
                                             Mo. of Samples
                                         G-29

-------
                                            SCREENING PROGRAM	SIM4ARY OF PLANT   12(144
StMlARY OF SCREENING DATA
CONCENTRATION (ug/1)
Priority Pollutants Influent Effluent
Acid Extractables
Phenols (4AAP) 5
Base/lleutral Extractables
STsTZ-ethylhexyl) phthalate 10
Volatile Organlcs
Ehloro benzene ' 11
1,1,1-Trlchloroethane 22
Ethyl benzene 21
Hathylene chloride 16
Bromfom 12
HeUTs
Antiiohy 210
Beryl HIM 2
ChroaliM 102
Copper 148
Lead 30
Kereury 0.1
Hlckel 23
Silver 4
Zinc 254
Arsenic 20LT
Cadalun 2LT
Selenium 2LT
Thallium 100LT
Cyanide 7
[1
[1
!
[i
>
i
!
[i
—
—
...
WASTEWATER; TREATMENT PLANT UNIT OPERATIONS
Neutralization
Note: The arrangement of the wastewater streams was such that a
representative sample of untreated influent could not be
obtained. The influent samples analyzed were taken at
MH-81 through with 90 percent of the process wastewater flows.
PLANT CHARACTERISTICS
Subcategory Wastewater Quantity (MGD) Employment
A,D 2.97 MGD 000-900
PERFORMANCE OF TREATMENT SYSTEM
BOD (mg/1) COD (mg/1) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
1425 — , 3390
*  Influent Is Influent to POTW.
                                               WASTEWATER TREATMENT PLANT FLOW DIAGRAM
                                                       NOT APPLICABLE
                                                     SAMPLING PROGRAM

                                         Sample Location

                                         Citric Acid Effluent After Lime
                                          Neutralization-881 Manhole
                                         Effluent At #83 Manhole
                                         Effluent At «7A Manhole
                                         Effluent At #6 Manhole
                                         Effluent At 874 Manhole
No. of Samples
                                                                G-30

-------
  SCREENING PROGRAM	SUMMARY OF PLANT
SUMMARY OF SCREENING DATA
CONCENTRATION (ug/1)
Priority Pollutants * Influent ** Influent
Acid Extractables
Phenol 280 (
Phenols (Tot.) 129 (
Volatile Organlcs
Benzene 100 (
1,1,1-Trichloroethane 12 (
1,1-Dichloroethane ND
Chloroform 460
l,l-D1chloroethylene NO (
l,2-Trans-d1chloroethylene ND (]
Hethylene chloride 1700000 (]
Toluene 700 (1
Metals
Antimony 57 (
Arsenic 20LT (]
Beryllium 1LT (I
Cadmium 2LT-(]
Chromium 91 :
Copper 86
Lead 21 (1
Hercyr 0.7 (1
Nickel 50 1
Selenium ' • 48 ]
Silver 41
Thallium 100LT 1
Zinc 311 ]
Cyanide 19 0
L) ND 1
I) 54 1
I) 500 1
I) 720000 1
I) 54 1
L 900 1
I 20 1
1100 1)
t 80000 1}
) 40 (1)
I) 10 1)
) 91)
) 1LT (1)
) • ' 2LT (1)
) 20 (1
181 (1
96 (1
) 0.1 (1
5LT (1
2LT (1)
4 (1)
2.9 (1)
154 (1)
) 38 (1)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Plant 12447 is an indirect/zero discharger. Strong chemical wastes
are 'deep well injected. With no pretreatment, these two streams
are discharged to a POTW.
* Fermentation. and fine chemicals process wastewaters.
** Formulation process wastewaters.
PLANT CHARACTERISTICS
Subcategory Uastewater Quantity (MGD) Employment
A.B.C.D *1.0 **1.0 4000-4100
PERFORMANCE OP TREATMENT SYSTEM
BOD (mg/1) COD (mg/1) TSS (mg/1)
Influent **Influent *Influent **Influent *Influent **Inf1uent
2600 ,45 7400 139
     WASTEWATER TREATMENT PLANT  FLOW DIAGRAM



                   NOT AVAILABLE

                 SAMPLING PROGRAM
Sample Location
                                       No,  of Samples
Process Wastes From Building 197             5
Process Wastes From Building 42              5
Process Wastes To  Injection Wells            4
Non-Contact Cooling Water to Outfall 001     5
Non-Contact Cooling Water to 85 Acre Pond     5"
                        G-31

-------
SCREENING PROGRAM 	 Stff.WARY OF PI.ANT 12462

SUMMARY OF SCREENING DATA
CONCENTRATION (ug/lj
Priority Pollutants Influent Effluent
Acid Extrac tables
4-MHrophenol 1600
Phenol 70
PbinoU (Tot.) 1200
Volatile Organics
Ho thy 1 one cnl orlde —
(totals
Antimony 10LT
Arsenic 10LT
Beryl HM 1LT
Cactalwi 1LT
Chrcniiw 10LT
Copper 48
Lead 31
Kercury 0.60
Hickel 50LT
Selenium 22
Silver 1LT
Thill 1us 100LT
Zinc 76
1) 400LT
1) 20LT
1) 70LT-540LT
70
1 21-51
1 IOLT-20LT
1 1LT-2.4
1 1LT
1 10LT-17
1 36-48
1 5LT-6
1 0.4-1.3
1 60LT
1 43-56
1 1LT
1 100LT
1 57-122
jl)
|3)
(1)
3)
1}
3)
3
3
3
3)
3)
3
3
3

WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Activated Sludge
Aerated Lagoon
Sludge Hauling
PLANT CHARACTERISTICS
Subcategory Uastewater Quantity (MGD) Employment
A .170 0-100
PERFORMANCE OF TREATKBTT SYSTEM
BOD (mg/1) ; COD (mg/1) TSS (mg/1)
Influent Effluent Influent Effluent Influent Effluent
2090 84-156 (3) 2690 548-1300 (3) 150 372-1000 (3)
I!!!1:"" 	 •! 	 • • f.'." . 	 ' , .! 	 , "i1' ,• • • • 	 	 .• •:• ,. 	 i - 	
            V/ASTBVATER TREATMENT PLANT FLOW DIAGRAM
                         Not available.
                          SAMPLING PROGKflM
Sample Location
Raw water supply
Existing backwash lagoon effluent
Biological waste treatment system effluent
Process wastes influent line  to  the biological
  treatment system
Combined influent to the biological wastewater
  treatment system
Effluent from final clarifier
No. of Samples

     1
     1
     6
                              G-32

-------

SIMIARY OF SCREENING DATA
CONCENTRATION (ug/1)
Priority Pollutants
Acid Extractables
2-Nitrophenol
4-Nitrophenol
Phenol
Base/Neutral Extractables
Nitrobenzene
Volatile Orgam'cs
1,1-Dichloroethylene
1,2-Dichloroethane
1,1,2-Trichloroethane
Metal s
Antimony
Arsenic
Cadmium
Chromium
Copper
Lead
Nickel
Selenium
Silver
Thallium
Zinc
Influent Effluent
4100 (1)
1100 (1)
16500 (1)
30 (1)
370 (1)
20 (1)
6650 (1)
35-90 3
5700-7200 3
ILT 3
5LT-9 (3)
19-35 (3)
5LT (3)
50LT (3)
210-310 (3)
2LT (3)
5LT-10LT (3)
49-70 (3)
WASTEWATER TREATMENT PLANT UNIT OPERATIONS
Equalization
Neutralization
Primary Chemical Flocculation/Clarification
Detention Pond
PLANT CHARACTERISTICS
C,D 0.45 Unknown
PERFORMANCE OF TREATt.STr SYSTEM
BOD (mg/1) COO (mg/1) TSS (mg/1)
Influent Effluent Influent Effluent i."!1."?.".1; F.f.f.l.u.!.1*.
310-675 (3) — 680-1380 (3) . — 3-31 (3)
      WASTEWATER TREABEMT PLANT FLOW DIAGRAM
                    NOT AVAILABLE
                  SAMPLING PROGRAM
Sample Location
Detention Pond Effluent
Raw Waste Feed for Bench Scale Treatment   2
   Units
activated Sludge  Effluent                  1
Powdered Activated Carbon Treatment (PACT)
   Effluent                               1
Mo. of Samples

     3
                        G-33

-------

-------
              APPENDIX H

Priority Pollutant Occurrence as Reported in
        Original 308 Portfolio Data

-------

-------
                            APPENDIX H

                   PRIORITY POLLUTANT OCURRENCE
           AS REPORTED IN ORIGINAL 308 PORTFOLIO DATA
Priority Pollutants by Plant
Plant 12003:
A CD
N*
Copper
Nickel
Zinc
Plant 12018:



A CD N*
   Zinc

Plant 12037:
                             Concentrations (ug/1)
                             Influent     Effluent
                                                             100
                                                                 10
                                                                 80
                                                                  5
  CD
N*
      Methylene Chloride
      Chromium
      Copper
      Lead
      Mercury
      Nickel
      Zinc
      Cyanide
Plant 12038:
ABCD
      Phenol
      Chromium
      Lead
      Mercury
      Cyanide
AS, AL, PC*
Plant 12052:
  CD
AS*
      Phenol
      Chromium
      Copper
      Lead
      Mercury
      Nickel
      Zinc
      Cyanide

Plant 12056:
         AC*
      Chromium
      Zinc
                                                12
                                               930
                                               190
                                                50
                                                 0.
                                               100
                                                40
                                                89
                                               102
                                                20
                                               100
                                                 0,
                                                30
                                              1100
                                                21
                                                45
                                               100
                                                10
                                               100
                                                92
                                               100
                                                 5
                                             17900
                                 H-l

-------
 Plant 12057:
       Toluene
    CD
  N*
                                                                 780
 Plant 12062:
    CD
 N*
      Zinc

 Plant 12065:
   Cyanide

 Plant 12089:
      Mercury

 Plant 12102:
      Phenol
      Chromium
      Copper
      Lead
      Mercury
      Nickel
      Zinc
      Cyanide

Plant 12107:
     Phenol
     Chromium
     Lead

Plant  12123:
                                                200
           N*
                                             1000
   B D
 TF, AS, PP*
   CD
N*
 B D
N*
  CD
N*
     Benzene
     Carbon Tetrachloride
     Chloroform
     Methylene Chloride
     Toluene
     Chromium
     Copper
     Lead
     Mercury
     Nickel
     Zinc
     Cyanide
     Phenol
     Chromium
     Zinc
                                                  0.3
                                              8000
                                                100
                                                500
                                                100
                                                 1 .
                                                500
                                              1000
                                              1000
                                               290
                                               290
                                                90
                                                 6
                                                50
                                                50
                                                15
                                                67
                                               108
                                                73
                                                13
                                                35.
                                                50
                                               368
                                               110
                                                30
                                                50
                                               370
Plant 12161
A CD
 As,  PP*
     Phenol
     Benzene
                                                   800
                                                14
                                               250
                                 H-2

-------
     Chloroform
     Toluene
     Chromium
     Copper
     Lead
     Mercury
     Nickel
     Zinc

Plant 12186:
                               11000
                                9100
CD
     Phenol
     Chromium
     Copper
     Lead
     Mercury
AS, AL*
Copper
Plant 12195: C
Chromium
Copper
Lead
Mercury
Nickel
Zinc
Cyanide
Plant 12204: ABCD
Chromium
Plant 12224: D
Copper
Zinc
Plant 12235: C
Cyanide
Plant 12236: C
Cyanide
Plant 12244: C
Chromium
Mercury
Plant 12245: ABC
Toluene
Plant 12252: A CD
Chromium
Plant 12257: ABCD
N*
AS*
N*
N*
AS*
N*
N*
p*
AS*
                                                    34


                                                   120
                                             290000
                                       6
                                      17
                                      10
                                      80
                                      70
                                       2,
                                    2100
                                     137
                                                               240
                                                               200
                                                               200
                                                               200
                                                                 0.1
                                                               300
                                                               400
                                                                10
                                                                15
                                                                97
                                                               177
                                              14


                                             290


                                             500
                                          0.5


                                         14000
                                                                70
                                              30
                                             100
                                              50
                                              50
                                               0.1
                                 H-3

-------
Nickel
Zinc
Cyanide
Plant 12282: BCD
Mercury
Plant 12287: D
Phenol
Chromium
Zinc
Cyanide
Plant 12289: D
Chromium
Copper
Lead
Mercury
Nickel
Zinc
Cyanide
Plant 12302: C
SF*
AL*
N*
N*
     Toluene
Plant 12339;
A CD
     Phenol
     Chloroform
     Methylene Chloride
     Chromium
     Copper
     Lead
     Mercury
     Zinc
     Cyanide
Plant 12342:
A CD
     Phenol
     Methylene Chloride
Plant 12407:
                                                    -31
                                                    100
                                                    80
AS, PC*
                              22000000


                                   117

                                120000
N*
          AS, PC, PP*
     Chromium
     Copper
     Lead
     Mercury
     Zinc
     Cyanide

Plant 12411 ;
     Phenol
 BCD
AL*
                                                              1300
                                                               250
                                                                10
                                                                80.0
                                                10
                                               100
                                                80
                                                20
                                                               300
                                                               540
                                                               680
                                                                 7.0
                                                               200
                                                              2050
                                                                15
                                      79
                                       9
                                     742
                                      85
                                     541
                                     117
                                       4,
                                     983
                                    2100
                                               210
                                              9300
                                                70
                                                23
                                                90
                                                10.0
                                                21
                                              2300
                                               106
                                H-4

-------
     Chloroform
     Methylene Chloride
Plant 12414;
  D
                          N*
     Chromium
     Copper
     Lead
     Nickel
     Zinc

Plant 12420;
B D
AS*
     Phenol
     Toluene
     Copper
     Lead
     Nickel
     Zinc
     Cyanide

Plant  12440;
                                  168
                                  174
         N*
     Phenol
     Chloroform
     Methylene Chloride
     Chromium
     Copper
     Lead
     Mercury
     Nickel
     Zinc
     Cyanide
 Plant 12458:
  CD
                           N*
   Phenol

 Plant 12468;
                                             3990
                                             1650
                                                4
                                               49
                                                4
                                                7
                                              130
                                     160
                                     174
                                     300
                                     170
                                     260
                                     600
                                       3
                                              750
                                              300
                                             1000
                                               11
                                               70
                                               70
                                                 0,
                                               26
                                               80
                                              200
                                                             192
          N*
      Copper
      Lead
      Mercury
      Nickel
      Zinc

 Plant 12475;
                                               140
                                                24
                                                 0.
                                               100
                                               180
          AS*
    Phenol

 Plant 12477:
                                         10
                                                              10
 BC
 N*
      Phenol
      Chromium
      Copper
      Lead
      Mercury
                                                50
                                              20QO
                                               300
                                                50
                                                 5.0
                                H-5

-------
       Nickel
       Zinc
       Cyanide
  Plant 20033;
       Phenol
       Chromium
       Copper
       Mercury
       Nickel
       Zinc
  CD
 P*
 Plant  20037:
   Phenol
   D
AS, AL. PP*
 Plant 20245:
      Phenol
A C
AS*
      Benzene
      Chloroform
      Methylene Chloride
      Toluene
      Chromium
      Copper
      Lead
      Mercury
      Nickel
      Zinc
      Cyanide
                                   200
                                   130
                                   130
                                    72
                                     4
                                 40000
                                  1700
                                    37
                                  8400
                                     0.
                                   490
                                 37000
                                  1500
 Plant 20246
      Phenol
         AS, MF*
      Benzene
      Chloroform
      Methylene  Chloride
      Toluene
      Chromium
      Copper
      Lead
      Mercury
      Nickel
      Zinc
      Cyanide
Plant 20254;
     Phenol~~
         AL,  PP*
     Cyanide

Plant 20297:
     Phenol
     Cyanide
                          TF, AS. PC*
                                 1800
                                  200
                                                500
                                               5600
                                                760
                                      200
                                      250
                                      110
                                       0.2
                                      200
                                      250
                                      34
                                       2
                                      42
                                       2
                                       1
                                      86
                                      23
                                      41
                                       0.
                                       6
                                    3500
                                      40
                                               172
                                                3
                                                8
                                                6
                                                1
                                               19
                                               55
                                                2
                                                0.
                                                2
                                               88
                                               36
                                               65
                                               70
                                     60
                                    110
                                H-6

-------
Plant 20321;
N*
     Copper
     Zinc

Plant 20342:
P*
     Phenol
     Chloroform
     Toluene
      Chromium
      Copper
      Mercury
      Nickel

*End-of-Pipe Treatment Abbreviations:

N   =   No Treatment
P   =   Primary
TF  =   Trickling Filter
AS  =   Activated Sludge
AL  =   Aerated Lagoon
PP  =   Polishing Pond
PC  =   Physical/Chemical
AC  =   Activated Carbon
MF  =   Multimedia Filter
SF  =   Sand Filtration
                                                    21
                                     300
                                    2000
                                      12
                                      20
                                       8
                                       50
                                       50
                                        0,
                                       50
                               H-7

-------

-------
       APPENDIX I

       308 Portfolio
(Traditional Pollutant Data)

-------

-------
               APPENDIX I

308 PORTFOLIO TRADITIONAL POLLUTANT DATA
12000
12001
12012
12015
12016
12018
12022
12023
12026
12031
12036
12037
12038
               Sub-
             Category
 B D
   D
   D
A CD
A C
   D
  C
   D
A
  CD
ABCD
12040
12053
12062
12066
12069
12084
12087
12089
12095
12097
12098
12102
12104
12119
12125
12132
12135
12141
12143
12159
12160
B D
D
CD
BCD
D
BCD
C
B D
CD
CD
D
CD
D
A D
D
A C
BCD
D
D
CD
D
 Major End-of-Pipe
     Treatment*

         N
         AL
         P
    AS, AC, OP

         N
      TF, AS
         N
    AS, AL, PP
         N
    TF, AS, AL, PP
         N
Fermentation Wastes
      AS, PC
  Chemical Wastes
      AL, PC
         N
    TF, AS, SF
         N
      AS, AL
         N
         N
         P
    TF, AS, PP
      PC, OP
   ASw/PAC, OP
         AS
         N
         SP
      AS, PC
         PC
    TF, AS, SP
         P
         AS
         N
         N
    AS, PC, MF
                  BOD(mg/l)
Inf.
80

611
259
1210
33
1551
4597
1865
344
1340
1811
6210
5717
210
2 9
2600
1195
320
5772
27416


465
2705
85


2330
200

93
79
530
Eff.

21

19


105

93

13

244
1140

8

331



13
28
693

12
7
218
29

4


5
                                                              COD(mg/l)
                                                            Inf.      Eff.
                     TSS(mg/l)
                   Inf.      Eff.

                     80
916
489

 76
                                     4240

                                     2521
                                     6893

                                    12023

                                     1741
                                      800
                                     1205
                                     2924

                                      450
                                    10450
                                    56902
                                     2556
                                     5124
                                      157

                                      256
                                     4800
                                      400

                                      358
 54




946

197
273
146
135
 11

512
 84
222
705
775
                                                                      15
                               326

                                44
1453


67







289
2886

40
40
456
203




2264
4483
280
383
49
116
30
1465
2501

193

354
143
19

53

200

143
4128
306
457

2

251



13
6
29
336

22
70
88
29

12

43

-------
            APPENDIX I  (coat.)

308 PORTFOLIO TRADITIONAL POLLUTANT DATA
Plant
Code
12161
12168
12183
12185
12186
12187
12191
12195
12199
12204
12205
12231
12235
12236
12239
12240
12248
12257
12261
12275
12283

12287,
12294!
12298'
12307*
12308
12317
12338
12339^
12343 ••
12406
12407
12411
12420
12454 i
12462 I
12463 '
r
Sub-
Category
A CD
ABCD
B
BC
CD
C
BCD
C
A CD
ABCD
D
D
C
C
D
CD
D
ABCD
C
BC
D

D
CD
D
D
D
D
D
A CD
A CD
C
C
BCD
B D
B D
A
B D
Major Knd-of-Pipe
Treatment*
AS, PP
N
N
N
AS, AL
TF
P
N
N
AS
AS, SP
AL, SP
N
AS
AS
PC
AS
AS
AL, PC
P
AS

AL
AS, MF
AS
AS, AL
AS
AS, PC, MF
AS, SF
AS, PC
P
PC, PP, OP
AS, PC, PP
AL
AS
TF
AS, AL
AS, SP, PC, OP
BODjng/1)
Inf.
•^^•M
987
1300
4
47

653

215
2180
1220

2500
12374
1117
1573

244
3000

366
- - 	
30
1404

732
130
760
200

636

54
7100
7520


102
Eff.
IBMBMIT*
72



129




146
60
200

149
284
3636
10
120


35
56
208
15
18

32
30



45
869
4636
288
143
6
                                       COD (nag/1)
            TS8(ag/l)
Inf.
2978
3300
10
154

1950
1352
584

2628


22250
2674
1608

486

15574
— ... 	 	 _
50
3288

2390
372
1064

430
Bgf.
944



683




407
81
600

553
290
8481
63

9880
	 ..
51
658

83

107

2370
Ing.
398
500
3
7

124
92

650
2000

100





950
3089
—
12


A9-7
67
3*
200

EM.
196



328




320
40
50

90
174
286
35
500
567
50
13
28
26
90

50
30

                                    15700
                                    12032
7418

 297
  29
 420
  30
 369
4923
  10
  17
1793
4048

  97
   9

-------
                                                APPENDIX I (cont.)

                                    308 PORTFOLIO TRADITIONAL POLLUTANT DATA
12471
12475
12476
12477
20037
20165
20201
20204
20206
20245
20246
20257
20297
20312
20319
20342
20363
  Sub-
Category.

  B
   C
    D
  BC
    D
  BC
    D
   CD
   C
 A C
   C
   C
   C
  BCD
    D
   C
 A CD
                           Major Bnd-of-Pipe
                               Treatment*   f

                               AL,  PP,  OP
                                    AS
                                    AS
                                    N
                               AS,  &L,  B2
                                    AL
                                    AS
                                    AL
                                    AL
                                    AS
                                 ASf MFf
                                    AS
                               TF,  AS,  PC
                                    AL
                                 TF, SP
                                    P
                                    P
  BOD(«q/l)
Inf.      Bff.
                                         C00(»g/l)
                                       Inf.      Bff.
            T8S(ag/l)
          Inf.      Bff.
   50
10670
10670
  327

  200

 1600
 1600
  497

  484
  380
 1500

  609
 846G
  14
1960
1960

  20
  32
   6
 370
   5
  56
  13
 143
  20
 150
  15
                                         169
                                       16140
                                       16140
                                         725

                                         541

                                        1370
                                       12000
                                        1350

                                        1358
                                         870
                                       16748
6440
6440
 113
  50

 340
  74
 128
 329
                                                              93
                                            47
            147
            500

             32
           1535
  59
2340
2340

  47
  24
  14

  10
  32
  33

  36
  150
    9
* ABBREVIATIONS:

N   -   No Treatment
P   -   Primary
TF  -   Trickling Filter
.AS  -   Activated Sludge  (w/PAC
AL  •   Aerated Lagoon
SP  -   Stabilization Pond
pp  «   Polishing Pond
OP  »   Other Polishing
PC  »   Physical/Chemical
AC  -   Activated Carbon
MF  -   Multimedia  Filter
SF  -    Sand Filtration
with Powdered Activated Carbon)

-------

-------
     APPENDIX J

     308 Portfolio
(Wastewater Flow Data)

-------

-------
                                          APPENDIX J
                                        308 PORTFOLIO
                                     WASTEWATER FLOW DATA
DIRECT DISCHARGERS
Plant No. Subcategor
12001
12006
12014
12015**
12022
12026
12030
12036
12038**
12053
12057*
12073
12085
12089
12095
12097*
12098
12104*
12117
12119
12132*
12160
12161
12175
12187*
12194
12205
12236
12239
12248
12256*/**
D
D
B
D
A C
C
D
A
A B C D
D
C D
C
D
B D
C D
C D
D
D
B D
A D
A C
D
A CD
D
C
D
D
C
D
D
A B C D
                              Discharge
                              Flow. MGD

                                0.155
                                0.125
                                ***
                                0.074
                                1.300
                                0.101
                                0.030
                                1.128
                                2.607
                                0.004
                                0.005
                                0.015
                                0.001
                                0.155
                                0.071
                                0.035
                                0.002
                                0.367
                                0.121
                                0.032
                                0.460
                                .0.006
                                1.332
                                0.004
                                0.913
                                0.002
                                0.030
                                0.810
                                0.002
                                0.035
                               30.000
Plant No.

12261
12264*
12267
12281*
12283
12287*
12294**
12298
12307
12308**
12317
12338
12339**
12406
12407
12459
12462
12463**
12471.
20037
20165
20201
20245
20246
20257**
20297
20298
20319
20370
20402
Subcategory

A










A



A





A







C
B D
D
D
D
D
C D
D
D
D
D
D
C
C
C
D

B D
B
D
B C
D
C
C
C
C
C
D
B C
D
Discharge
Flow, _MGD

  0.051
  0.044
  0.005
  ***
  0.013
  0.131
  0.089
  0.003
  0.001
  0.059
  0.390
  0.001
  1.600
  0.370
  0.731
  0.073
  0.170
  0.003
  0.043
  0.037
  0.004
  0.002
  0.500
  1.250
  0.015
  ***
  ***
  0.003
  0.014
  0.024
                                              J-l

-------
                                         APPENDIX J
                                       308 PORTFOLIO
                                    WASTEWATER FLOW DATA
INDIRECT DISCHARGERS:
Plant No.
12000
12003
12004
12005
12007
12011
12012
12016
12018**
12019
12023
12024**
12031
12035
12037
12040
12042
12043**
12044**
12048
12051
12054
12055
12056
12057*
12058
12060
12061
12062
12065**
12066
12068
12069
12074
12076
12077
12078
12080
12083
12084
12087
Subcategory
D
A CD
C D
B
D
A B D
B D
D
A CD
D
D
D
D
D
C D
B D
A B D
C
A D
C D
D
D
D
D
C D
D
D
B
C D
D
BCD
D
D
D
D
C D
D
D
D
BCD
C
                               Discharge
                               Flow, HGD

                                 0.140
                                 0.980
                                 0.003
                                 0.001
                                 0.527
                                 0.031
                                 0.340
                                 0.009
                                 0.020
                                 ****
                                 0.020
                                 0.033
                                 0.001
                                 0.003
                                 0.125
                                 0.063
                                 ****
                                 0.001
                              •  2.973
                                 0.089
                                 0.009
                                 0.008
                                 0.002
                                 0.110
                                 0.080
                                 0.005
                                 0.104
                                 0.042
                                 0.075
                                 0.005
                                 0.259
                                 ***
                                 0.017
                                 0.037
                                 0.001
                                 0.022
                                 ***
                                 0.090
                                 0.217
                                 0.008
                                 0.232
 Plant No.

 120881
 12093
 12094'
 121001
 12104!*
 12107
 12108**
 12110
 12112
 12113
 12115
 12118*
 12120
 12122:
 12123
 12125;
 12128;
 12129'
 12131'
 12135:
 12141
 12143 :
 12144
 12145
 12147
 12155,
 12157:
 12166
 12168
 12171
 12172
 12177
 12178
 12183
 12186
12191
12195
12198
12199
Subcategory

       D
     C D
       D
     C D
       D
   B   D
 A   CD
       D
   B   D
     C
       D
 A B   D
       D
       D
       D
     C D
       D
       D
       D
       D
   BCD
       D
       D
       D
       D
       D
     C  D
       D
       D
A  B  C  D
   BCD
       D
       D
   B
   B
     C  D
     C
A  B  C  D
     C
   B    D
A    CD
Discharge
Flow, MGD

  0.002
  0.004
  ****
 	0.062	
  0.190
  0.009
  ****
  ****
  ****
  0.005
  0.380
  0.010
  0.009
  0.001
  ****
  0.404
  ****
  ****
  ****
 " "67604
  1.650
  0.001
  0.037
  ****
  0.001
  ****
  1.170
  ****
  O.OQ4
  0,159
  0.001
 ****
 ****
 0.005
 0.090
 0.052
 0.078
 ****
 0.080
 0.012
 0.500
                                           J-2

-------
                                       APPENDIX J
                                     308 PORTFOLIO
                                  WASTEWATER FLOW DATA
 NDIRECT DISCHARGERS (CONT'D.)
'lant No.

 2204
 2206
 2207
L2210
 2211
 2212
12217**
L2219
L2224
 2226
L2230
L2233
L2235**
L2238
[2240**
L2243
.2244
L2245**
.2246**
.2247
L2249
.2250
.2251
,2252
.2254**
L2256*
L2257**
L2260
L2264*
L2265
L2268
L2273
L2275
12277
L2281
L2282
L2287*
L2289
L2290
L2295
L2296
L2300
L2302
Subcategory

  A B C D
        D
        D
    B C
        D
        D
        D
        D
        D
    B
    B
        D
      C
        D
      C D
      C
      C
  ABC
      C D
      C
        D
        D
        D
  A
  A
  A B
    B
    C D
      D
A B C D
A B C D
      D
      D
      D
      D
      D
  B C
      D
      D
  BCD
      D
      D
      D
    B
      D
      D
Discharge
Flow, MGD

  0.850
  0.130
  ****
  0.002
  ****
  0.040
  ****
  0.053
  ****
  0.040
  0.001
  ****
  0.295
  0.010
  0.013
  ****
  0.042
  0.085
  0.362
  0.029
  0.002
  0.047
  0.001
  0.865
  0.213
  0.410
  0.600
  0.125
  0.127
  0.003
  ****
  ****
  0.426
  ****
  0.034
  0.004
  0.070
  0.003
  ****
  ****
  0.016
  0.160
  1.028
Plant No.

12305
12309
12310
12311
12312
12318
12322
12330
12331
12332
12333
12340
12342
12343
12345
12375
12384
12385
12392
12401
12405
12409
12411
12414
12415
12417
12419
12420**
12427
12429
12433
12438
12440
12441
12444
12454
12458
12460
12464
12465
12467
12468
12470
Subcategory

        D
    B C
      C D
  A B C D
    B   D
        D
        D
  A B C D
        D
      C
      C D
        D
  A   CD
  A   CD
        D
    B
    B
        D
        D
  A     D
      C D
        D
    BCD
        D
        D
        D
    B'  D
    B   D
        D
        D
        D
        D
        D
      C
        D
    B   D
      C D
                                                        B
        D
        D
        D
                                                      A
Discharge
Flow. MGD

  0.034
  0.007
  0.018
  0.240
  ****
  0.100
  0.010
  1.606
  0.380
  0,045
  0.017
  0.034
  0.701
  0.088
  0.020
  ****
  0.002
  ****
  ****
  0.223
  ****
  ****
  0.300
  0.464
  0.080
  ****
  ****
  ****
  0.011
  0.005
  ****
  0.004
  ****
  1.300
  0.076
  0.100
  0.778
  ****
  ****
  0.018
  0.002
  0.038
  0.001
                                           J-3

-------
                                      APPENDIX J
                                    308  PORTFOLIO
                                 WASTEWATER  FLOW DATA
DIRECT DISCHARGERS  (CONT'D.)
Plant No.

12472
12473
12474
12477
12479
12481
12482
12495
12499
20012
20017
20026
20032
20033
20034
20050
20052
20057
20058
20062
20064
20081
20089
20117
20120
20126
20139
20142
20147
20153
20155
20169
20174
20177
20187
20188
20203**
20205
20216
20220
20224
20231
20234
Subcategory

    B C
    B C
        D
    B C
    B
  ****
  A B
  D
  D
C
  D
  D
  D
C D
  D

  D
  D
  D
  D
  D
  D
  D
  D
  D
  D
C D
  D
  D
  D
  D
  D
  D
C
  D
  D
C
C
  D
  D
  D
  D
  C
Discharge
Flow, MGD

  0.001
  0.023
  0.003
  2.400
  ****
  ****
  ****
  ****
  ****
  ****
  ****
  ****
  ****
  0.200
  0.001
  ****
  ****
  ****
  ****
  ****
  0.001
  ****
  ****
  ****
  ****
  ****
  0.060
  0.001
  ****
  ****
  ****
  0.026
  ****
  0.001
  0.002
  0.008
  0.034
  ****
  0.001
  ****
  ****
  ****
  ****
                               Plant No.
20237
20240
20244
20247
20254
20258
20261
20263
20264
20267
20269
20270
20273
20282
20288
20303
20307
20310
20311
20312
20321
20328
20331
20333
20339
20342
20346
20349
20350
20353
20355
20356
20359
20361
20362
20363
20364
20366
20371
20377
20385
20389
20400
Subcategory

    B
      C
      C
    B
      C
      C D
        D
        D
        D
        D
        D
        D
        D
        D
        D
    B
    B
      C
      C
    BCD
        D
        D
      C
        D
        D
      C
    B C
      C
      C D
    B C
      C
      C D
    B   D
                                                     A
                                                     A
      C D
      C D
    B   D
    BCD
        D
      C D
        D
Discharge
Flow, MGD

  0.040
  0.002
  0.001
  0.059
  0.020
  0.002
  ****
  ****
  ****
  ****
  ****
  0.002
  ****
  ****
  0.037
  ****
  ****
  0.190
  0.034
  0.900
  0.008
  0.001
  0.107
  ***
  0.500
  0.039
  ****
  0.018
  0.003
  0.006
  0.033
  ****
  ****
  ****
  ****
  0.125
  0.006
  0.010
  ****
  ****
  ****
  ****
  ****
                                          J-4

-------
                                        APPENDIX J
                                      308 PORTFOLIO
                                   WASTEWATER FLOW  DATA
INDIRECT DISCHARGERS (CONT'D.)
Plant No.

20405
20423
20439
20441
20443
20446
20450
20453
20456
20460
20465
20466
20473**
20476
20490
20492
20494
20503
20519
20527
Subcategory

        D
        D
        D
        D
    B   D
        D
        D
        D
        D
        D
        D
        D
    B
        D
        D
        D
        D
      C D
        D
        D
Discharge
Flow. MGD

  ****
  ****
  ****
  ****
  0.023
  ***
  ****
  0.010
  ****
  ****
  ****
  0.001
  0.001
  ****
  ****
  ****
  0.001 '
  ****
  0.010
  0.001
                                             J-5

-------
                                    APPENDIX J
                                  308 PORTFOLIO
                               WASTEWATER FLOW DATA
ZERO DISCHARGERS (ONLY)
Plant No.
12021
12052
12063
12099
12102
12133
12159
12173
12174
12175
12185
12225
12231
12263
12269
12297
12306
12326
12439
12447
12466
12475
Plant No.
12476
20006
20014
20015
20016
20030
20035
20038
20040
20041
20045
20048
20049
20051
20054
20055
20070
20073
20075
20078
20080
20082
                              Plant No.

                              20084
                              20087
                              20090
                              20093
                              20094
                              20099
                              20100
                              20103
                              20106
                              20108
                              20115
                              20125
                              20134
                              20141
                              20148
                              20151
                              20159
                              20173
                              20176
                              20178
                              20195
                              20197
Plant No.

20204
20206
20208
20209
20210
20215
20218
20225
20226
20228
20235
20236
20241
20242
20249
20256
20266
20271
20294
20295
20300
20305
 Plant  No.

 20308
 20316
 20325
 20332
 20338
 20340
 20347
 20373
 20376
 20387
 20390
•20394
 20396
 20397
 20413
 20416
 2'0421
 20424
 20425  " -
 20435
 20440
Plant No.

20440
20444
20448
20452
20462
20464
20467
20470
20483
20485
20486
20496
20498
20500
20502
20504
20507
20509
20511
20518
20522
20526
20529
                                        J-6

-------
                                     APPENDIX J
                                   308 PORTFOLIO
                                 WASTEWATER FLOW DATA
   *  These plants are combined direct/indirect dischargers.
      is for the appropriate portion of the total  discharge.

  **  These plants also have some zero discharge operations.
      is not .included.

 ***  Flow is negligibly small  (less than 500 MGD).

****  Data unavailable.
The value reported
Zero discharge flow
      Notes:
          The above plants were the only ones to report flow data in the 308
          Portfolio.  For all  others the discharge flows were unknown or
          negligible.

          The discharge flows  consist of wastewater from the following sources.
          - Direct process contact
          - Indirect process contact
          - Non-contact
          - Maintenance and equipment cleaning
          - Air pollution control

          The discharge flows  do not contain:
          - Non-contact cooling water
          - Sanitary/potable water
          - Storm water
                                         J-7

-------

-------
APPENDIX K



RSKERL Data

-------

-------
ANALYTICAL DATA (PLANT 4)
Influent Return Sludge Effluent
Priority Pollutant Gig/1)
CLASSICAL
TOTAL CYANIDES (mg/1)* <.05 *
TOTAL PHENOL 35°
TOTAL METALS
Arsenic *1
Selenium - *!"
o
Cadmium *
Beryllium *
Copper 120
Antimony <^
Chromium 12
Nickel <10
Zinc 620
Silver <10
Thallium <10
Lead 12
Mercury ^.B
ORGANICS (GAS CHROMATOGRAPHY)
PURGEABLES
1 , 2-Dichloroethane
Toluene <1^
Chloroform • <1^
Methylene chloride <10
Benzene <40
Ethylbenzene • ^0
Tetrachloroethylene 10
Trichloroethylene <10
PHENOLICS
Phenol 17
Pentachlorophenol 18
PHALLATES
Bis(2-ethylhexyl) phthallate
Di-n-butyl phthallate
*Note: Total Cyanides expressed in mg/1.
**Key: N.D. - Not Detectable, or less than detectable
N.A. - Not Applicable
N.S. - No Standard Available
N.P. - No Procedure "
(ug/D

<.05*
74


-------
ANALYTICAL DATA (PLANT 5)

Priority Pollutant
CLASSICAL
TOTAL CYANIDES (mg/1)*
TOTAL PHENOL
TOTAL METALS
Arsenic
Selenium
Cadmium
Beryllium
Copper
Antimony
Chromium
Nickel
Zinc
Silver
Thallium
Lead
Mercury
ORGANICS (GAS CHROMATOGRAPHY)
PURGEABLES
•Benzene
Chloroform
Methylene( chloride
Toluene
Ethylbenzene
1,1, 1-trichloroethane
1, 2-dichloroethane
PHENOLICS
4-Nitrophenol
2-Nitrophenol
PHTHALLATE ^ ESTERS
Bis (2-ethylhexyl) phthallate
Influent
(PR/1)
.25*
945
<10
3
120.
10.
12
39
41
<10
<10
22
<2.0
127
47
150
<10
<10
N.D.
123'
« DAF
Skimmings
(PR/1)
.22*
107
16
<10
: 11
<3
1,900
<10
1,500
42
5,600
17
12
N.A.
; ii
ii
ii
it
1 it
1 it
381
387
Clarifier
Effluent
(PR/1)
.17*
39
<10
<10
<1
<3
34
<10
34
38
9
<10
<10
<2.0
<40
<10
<3.0
<10

-------
                    4-
   (Continued)
     Priority Pollutant
Sparged Air, XAD-2 . Sparged Air, Tenax3
U grams per 1,755 ft  ugrams per	ft
POLYNUCLEAR AROMATICS
     Naphthalene
     2-Chloronaphthane
     Acenaphthalene
     Acenaphthene
     Fluorene
     Phenanthrene/Anthracene
     Fluoranthene
     Pyrene
     1,2-Benzanthracene
     Chrysene
     3,4-Benzopyrene
     1-, 2:5,6-Dibenzanthracene

PHENOLICS
     2-Chlorophenol
     2-Nitrophenol
     Phenol
     2,4-Dimethylphenol
     2,4-Dichlorophenol
     2,4,6-Trichlorophenol
     4-Chloro-m-cresol
     2,4-Dinitrpphenol
     4,6-Dinitro-o-cresol
     Pentachlorophenol
     4—Nitrophenol

PURGEABLES
     Methylene chloride
     1,1-Dichloroethane
     1,2-Trans-dichloroethylene
     Chloroform
     1,2-Dichloroethane
     1,1,1-Trichloroethane
     Carbon tetrachloride
     Dichlorobromomethane
     1,2-Dichloropropane
     Benzene
     Trichloroethylene
     Chlorodibromomethane
     1,1,2-Trichloroethane
     Methyl bromide
     Bromoform
     1,1,2,2-Tetrachloroethane
     Tetrachloroethylene
     Toluene
     Chlorobenzene
     Ethylbenzene       	
    90
   <35
   N.D.

   <25
   <25
   <25
    80
   110
   100
   <25
   <25
   <25
                     No  results  - sample
                     lost.   Analytical
                     equipment malfunction.
                                      K-3

-------
                                        (Continued)
      Priority Pollutant
                                     Sparged Air, XAD-2
                    Sparged Air, Tenax
                   	(ug)	
 POLYNUCLEAR AROMATICS
      Naphthalene
      2-Chloronaphthane
      Acenaphtbalene
      Acenaphthene
      Fluorene
      Phenanthrene/Anthracene
      Fluoranthene
      Pyrene
      1,2-Benzanthracene
      Chrysene
      3,4-Benzopyrene
      1,2:5,6-Dibenzanthracene
 PHENOLICS
      2-Chlorophenol
      2-Nitrophenol
      Phenol
      2,4-Diroethylphenol
      2,4-Dichlorophenol
      2,4,6-Trichlorophenol
      4-Chloro-m-cresol
      2,4-Dinitrophenol
      4,6-Dinitro-o-cresol
      Pentachlorophenol
      4-Nitrophenol
 PURGEABLES                 ;   '
      Methylene  chloride
      1,1-Dichloroethane
      1,2-Trans-dichloroethylene
      Chloroform
      1,2-Dichloroethane
      1,1,1-Trichloroethane
      Carbon tetrachloride
      Dichlorobromomethane
      1,2-Dichloropropane
      Benzene
      Trichloroethylene
      Chlorodibromometharie
      1,1,2-Trichloroethane
      Methyl bromide
      Bromoform
      1,1,2,2-Tetrachloroethane
      Tetrachloroethylene
      Toluene
      Chlorobenzene
	Ethylbenzone	
   940
5,000
   <60
   60
   <78
   150
   <6U
   <60
   <60
   <60
 <210
   N.D.


 <150
 <150
   <60
 <150
1,500
1,800
 <600
  600
 <150
 <150
                   Sample lost  -
                   Analytical apparatus
                   malfunction.
                                      K-4

-------
            APPENDIX L



Current In-Place Treatment Technologies

-------
I    I
                                 ..I i*

-------
                               APPENDIX L
               CURRENT IN-PLACE TREATMENT TECHNOLOGIES
Plant
Code No.

12001
 12022
Subcateqories

      D
12003
12007
12011
12012
12014
12015
A C D
D
A B D
B D
B
D
   A C
         Treatment
           System

Industrial Wastes
Equalization
Primary Chemical Flocculation/
  Clarification
Aerated Lagoon
Drying Beds
Landfill

Sanitary Wastes
Activated Sludge
Sand Filtration.
Mechanical Thickening
Sludge to POTW

Neutralization

Neutralization
Sludge to Sewer System

Neutralization

Equalization

Biological Treatment

Equalization
Primary Sedimentation
Activated Sludge with Powdered
  Activated Carbon
Secondary Chemical Flocculation/
  Clarification
Gravity Dewatering
Aerobic Digestion
Landfill

Cyanide Destruction
Equalization
Neutralization
Coarse Settleable Solids  Removal
Primary Sedimentation
Activated Sludge
   BPT
Treatment

    X
                                                                   X

                                                                   X
                                 L-l

-------
12026
12030

12036
   D

   A
12038
A B C D
             Trickling Filter
             Mechanical Thickening
             Chemical Conditioning
             Vacuum Dewatering
             Incineration       ;
             Landfill           ;

             Equalization       '
             Neutralization     \
             Activated Sludge
             Aerated Lagoon     \
             Polishing Pond     •
             Anaerobic Digestion'
Retention for Radioactive Decay

Activated Sludge
Trickling Filter
Aerated Lagoon
Waste Stabilization Pond
Polishing Pond      :
Aerobic Digestion
Cropland Use        |

Fermentation Wastes
Equalization
Neutralization
Coarse Setteable Solids Removal
Primary Sedimentation
Activated Sludge
Tertiary Plant
Centrifugal Dewatering
Anaerobic Digestion
Landfill

Chemical Wastes     ;
Solvent Recovery
Equalization
Neutralization
Coarse Settleable Solids Removal
Primary Sedimentation
Primary Chemical Flocculation/
  Clarification
Aerated Lagoon      ;
Tertiary Plant      .
Centrifugal Dewatering
Anaerobic Digestion
Landfill

Pretreatment
                                                                   X
                                                                  X
                                1-2

-------
12042


12043



12044

12052


12053
12056
12066
A B D


  C



A D

C D
BCD
12077
  C D
 Solvent Recovery
 In-Plant Evaporation
 Steam Stripping
 Tertiary Plant
 Heat Conditioning

 Thermal Oxidation
 Equalization
 Neutralization
 P/C: Thermal Oxidation
 Tertiary Plant

 Equalization
 Neutralization

 Solvent Recovery
 Neutralization
 Coarse Settleable Solids Removal

 Neutralization

 Primary Sedimentation
 Activated Sludge

 Equalization
 Coarse Settleable Solids Removal
 Activated Sludge
 Trickling Filter
 Sand Filtration
- Jfteclianical Thickening
 Drying Beds
 Cropland, Use

 De-Gas if ier
 De-Mineral izer
 Neutralization
 Activated Carbon Filtration

 Neutralization
 Activated Sludge
 Aerated Lagoon
 ^Mechanical Thickening
 Sludge to POTW

 Equalization
 Neutralization
 Coarse Settleable Solids Removal
 Primary Sedimentation
 Dissolved Air Flotation
 Sludge to POTW
X


X
                                 L-3

-------
 12085


 12087
  D


  C
 12089
 B D
12093

    2
12095
C D


C D
12097
C D
 Activated Sludge
 Landfill

 Solvent Recovery
 Neutralization   '
 Coarse Settleable Solids Removal
 Dissolved Air Flotation
 Sludge Hauling

 Equalization
 Neutralization ,
 Coarse Settleable Solids Removal
 Primary Sedimentation
 Activated Sludge
 Trickling Filter
 Polishing Pond
 Mechanical Thickening
 Anaerobic Digestion
 Drying Beds
 Cropland Use

 Equalization
 Aerated Equalization  Tanks
                  i      , '
 Equalization
 Neutralization,   !
 Coarse Settleable'Solids Removal
 Primary Chemical  Flocculation/
  Clarification
 Physical/Chemical  Treatment
 Secondary  Neutralization
 Flotation  Thickening
 Sludge Hauling
                  i
 Chemical Wastes
 Equalization
 Neutralization
 Physical/Chemical  Treatment
 Filtration/Presses
 Chemical Stabilization
 Chemical Conditioning
 Vacuum Dewatering
 Landfill

 Floor Washes      ;  ' "
Coarse Settleable Solids Removal
Activated Sludge with Powdered
  Activated Carboy
Physical/Chemical Treatment
                                L-4

-------
12098


12102


12104
12108

12113


12117
12119
 12123


 12125



 12132
  D


 C D


  D
A C D

  D


 B D
 A D
 C D


  D



 A C
                           Secondary  Chemical  Flocculation/
                             Clarification
                           Chemical Stabilization
                           Chemical Conditioning
                           Vacuum Dewatering
                           Landfill
Activated
Landfill
Sludge
Equalization
Neutralization

Equalization
Neutralization
Waste Stabilization Ponds
Chemical Conditioning
Mechanical Dewatering
Landfill

Neutralization

Equalization
Neutralization

Activated Sludge
Chlorination
Gravity
Aerobic Digestion
Dewatering
     x
Equalization
Neutralization
Coarse Settleable Solids Removal
Primary Sedimentation
Activated Sludge
P/C: Evaporation
Anaerobic Digestion
Drying Beds
Sludge to POTW

Equalization
Neutralization

Neutralization
Physical/Chemical Treatment
Secondary Neutralization

Solvent Recovery
Equalization
                                 L-5

-------
 12132 (cont'd)  A C
 12135



 12141




 12159


 12160
BCD
 C D


  D
12161
A C D
                            Neutralization
                            Coarse Settleabje Solids Removal
                            Primary Sedimentation
                            Primary Chemical Flocculation/
                              Clarification
  Activated Sludge
  Trickling Filter
  Waste  Stablization  Ponds
  Flotation Thickening
  Centrifugal  Thiqkening
  Centrifugal  Dewatering
  Incineration
  Landfill        |

  Cyanide Destruction
  Equalization    ;
  Neutralization

  Neutralization
  Primary Sedimentation
 Activated Sludge!
 Sludge Hauling  \

 Solvent Recovery
 Steam Stripping

 Equalization
 Neutralization
 Coarse  Settleable Solids Removal
 Primary Sedimentation
 Activated  Sludge
 P/C:  Evaporation
 Multi-Media Filtration
 Flotation  Thickening
 Anaerobic  Digestion
 Sludge  Hauling

 Solvent Recovery
 Equalization
 Neutralization  '
 Coarse  Settleable Solids Removal
 Primary Sedimentation
 Primary Chemical Flocculation/
 Clarification    :
Activated Sludge
Polishing Pond   ;
Gravity Thickening
Aerobic Digestion
Composting
                                                                   X
                                L-6

-------
12175

12186




12187
  D

 C D
12191

12199

12204
 ABC

 A C D

A B C D
12205
12210

12231
 B C

 A D
Landfill
Cropland Use

Equalization

Neutralization
Activated Sludge
Aerated Lagoon
Ozone Polishing

Solvent Recovery
Zinc Isolation
Equalization
Neutralization
Coarse Settleable Solids Removal
Dissolved Air Flotation
Trickling Filter
Gravity Thickening
Sludge to POTW
Vacuum Dewatering
Landfill

Neutralization

Solvent Recovery

Solvent Recovery
Mercury Collection
Neutralization
Coarse Settleable Solids Removal
Primary Chemical Flocculation/
  Clarification
Activated Sludge with Pure Oxygen
Mechanical Thickening
Chemical Conditioning
Vacuum Dewatering
Composting

Equalization
Activated Sludge
Sand Filtration
Mechanical Thickening
Aerobic Digestion
Sludge to POTW

Aerated Lagoon

Equalization
Neutralization
Coarse Settleable Solids Removal
X

X
                                 L-7

-------
 12236
 12239


 12240




 12246


 12248
  D


C D




C D


  D
12252
12254
A C D
 A D
 Primary Sedimentation
 Aerated Lagoon
 Waste Stabilization Ponds
 Anaerobic Digestion
 Landfill

 Weak Wastes      :
 Cyanide Destruction
 Solvent Recovery ;
 Equalization     :
 Neutralization   •
 Primary Oil/Solvent Skimming
                  1
 Strong Wastes
 Cyanide Destruction
 Solvent Recovery
 Equalization     ;
 Neutralization
 Primary Sedimentation
 Activated  Sludge ;
 Flotation  Thickening
 Chemical Conditioning
 Vacuum Filtration
 Landfill         '

 Activated  Sludge
 Landfill
                  i

 Equalization     ;
 Neutralization   '•.
 Physical/Chemical  Treatment
 Chlorination
                  I
 Solvent  Recovery
 In-Plant Evaporation

 Equalization
 Coarse Settleable  Solids Removal
 Activated Sludge
 Mechanical Thickening
 Gravity  Dewatering
 Aerobic  Digestion
 Dewatering
 Landfill          |

 Equalization
 Neutralization
 Coarse Settleable (Sol ids Removal
                  I
Equalization
                                                                   X
X


X
                                L-8

-------
                           Neutralization
12256
A B C D
12257
A B C D
12261
12275


12282
 B C


 BCD
 12283


 12287



 12294
    C D
Solvent Recovery
In-Plant Evaporation
Equalization
Neutralization
Coarse Settleable Solids Removal
Primary Sedimentation w/Skimming

Equalization
Neutralization
Activated Sludge
Centrifugal Dewatering
Cropland Use

Equalization
Neutralization
Coarse Settleable Solids Removal
Primary Sedimentation
Aerated Lagoon
P/C: Thermal Oxidation
Secondary Neutralization
Ch1orination
Vacuum Dewatering
Landfill

Equalization
Neutralization

Neutralization
Coarse Settleable Solids Removal
Primary Sedimentation
Primary Chemical Flocculation/
Clarification
Sand Filtration
Gravity Dewatering
Sludge Storage

Activated Sludge
Landfill

Coarse Settleable Solids Removal
Primary Sedimentation
Aerated Lagoon

Solvent Recovery
Equalization
Neutralization
Activated Sludge
Multi-Media Filtration
                                                     X


                                                     X
                                 L-9

-------
  12298


  12305


  12307
 12308
 12311
 12317
12330

12332



12333
    D
    D
A B C D
A B C D

   C



  C D
12338
  Centrifugal  Thickening
  Centrifugal  Dewatering
  Incineration
  Landfill
                   i
  Activated Sludge
  Landfill

  Equalization
  Neutralization

  Primary Sedimentation
  Activated Sludge
  Aerated Lagoon
  Chlorination
  Mechanical Thickening
  Flotation Thickening
                   i
 Activated Sludge
 Chlorination
 Landfill

 Activated Sludge
 Mechanical  Thickening
 Centrifugal  Thickening
 Landfill

 Equalization
 Neutralization
 Coarse Settleable  Solids  Removal
 Activated Sludge
 Physical/Chemical  Treatment
 Multi-Media Filtration
 Mechanical Thickening
 Aerobic  Digestion
 Cropland Use

 Neutralization

 Equalization
 Neutralization
 Waste Stabilization Pond

 Solvent Recovery
 Coarse Settleable Solids Removal
 Primary Sedimentation
Multi-Media Filtration
Landfill

Coarse Settleable Solids Removal
                                L-10

-------
12339
A C D
12343

12392

12406
A  C  D

   D

   C
 12407
Primary Sedimentation
Activated Sludge
Sand Filtration
Mechanical Thickening
Anaerobic Digestion
Sludge Hauling

Thermal Oxidation  (3 Units)
Neutralization
Coarse Settleable  Solids Removal
P/C: Thermal Oxidation
Tertiary Plant

Oil Dehydration
Neutralization
P/C: Evaporation
Tertiary Plant
Centrifugal Dewatering
Pyrolysis
Landf ill

Sanitary Wastes
Primary Separation
Activated Sludge
Tertiary Plant
Mechanical  Thickening
Evaporation
Aerobic Digestion
Dewatering
Pyrolysis
.Landfill >;

Solvents
Solvent Recovery
Steam  Stripping
Tertiary  Plant

Neutralization            ,  vj

Neutralization

 Neutralization
 Physical/Chemical  Treatment
 Secondary Chemical Flocculation/
   Clarification
 Polishing Pond-,
 Sludge Dewatering
 Landfill

 Equalization
                                                                   X
                                 L-ll

-------
 12411
  BCD
 Neutralization
 Coarse Settleabl^ Solids Removal
 Primary Sedimentation
 Primary Chemical Flocculation/
   Clarification
 Activated Sludge
 Physical/Chemical Treatment
 Polishing Pond   ;
 Flotation Thickening
 Landfill
                  i

 Solvent Recovery
 Equalization
 Neutralization
 Aerated Lagoon
 Incineration
12420




12438

12439
   B D




   D

  'C D
12441
12447
A B C D
12454
  B D
Activated  Sludge j
Chemical Conditioning
Centrifugal  Dewat'ering
Landfill          !

Aerated Equalization Tanks

Equalization'
Neutralization
Primary Sedimentation
Activated  Sludge
Aerated Lagoon
Landfill
                  i

Equalization      I
Neutralization
Coarse Settleable Solids Removal
Primary Sedimentation

Deep Well  Injection
Equalization      ;
Neutralization    ;
Coarse Settleable 5!plids Removal
Primary Sedimentation
Physical/Chemical Treatment
Diatomaceous-Eartl? Filtration

Primary Sedimentation
Trickling Filter
Anaerobic Digestion
Landfill
                                L-12

-------
12458


12459





12462



12463
12471
12475





12476





12477


20014

20017


20030
C D


 D
B D
  B
 B C


  D

  D


C D
Equalization
Neutralization

Equalization
Aerated Lagoon
Polishing Pond
Ch1orination

Activated Sludge
Aerated Lagoon
Sludge Hauling

Coarse Settleable Solids Removal
Activated Sludge
Waste Stabilization Pond
Physical/Chemical Treatment
Secondary Chemical Flocculation/
  Clarification
Flotation Thickening
Sludge Hauling

Coarse Settleable Solids Removal
Aerated Lagoon
Secondary Chemical Flocculation/
  Clarification
Polishing Pond
Secondary Neutralization
Chlorination
Drying Beds
Landfill

Equalization
Neutralization
Activated Sludge
Forest Land Use

Equalization
Neutralization
Activated Sludge
Forest Land Use

Equalization
Neutralization

In-Plant Evaporation

Activated Carbon Filtration
Landfill

In-Plant Evaporation
                                 L-13

-------
20033

20037





20057


20139



20153

20165

20177

20195

20201


20203
20204
20205
C D

  D





  D


C D



  D

B C

  C

  D

  D
C D
20206
Primary Sedimentation

Activated Sludge
Aerated Lagoon
Polishing Pond
Landfill
                j

Primary Sedimentation
Landfill        ,

Cyanide Destruction
Solvent Recovery!
In-Plant Neutralization

Multi-Media Filtration

Aerated Lagoon

Neutralization

P/C: Evaporation

Solvent Recovery
Activated Sludge

Cyanide Destruction
Chromium Reduction
Metals Precipitation
Solvent Recovery
Equalization
Neutralization
Coarse Settleable Solids Removal
Primary Chemical Flocculation/
Clarification
Landfill   '•  '  \
                i
Solvent Recovery
In-Plant Neutralization
Neutralization  ;
Aerated Lagoon
Sludge Lagoon

Solvent Recovery
Neutralization  •
Coarse Settleable Solids Removal
Aerated Lagoon
Landfill        j
                |
Solvent Recovery
X

X



X

X
                                L-14

-------
20234



20236

20237



20244
  B
20245
A C
20246
20254
 20257
Equalization
Aerated Lagoon
Landfill

Solvent Recovery
Neutralization
Primary Sedimentation

Activated Sludge

Solvent Recovery
Steam Stripping
Equalization

Solvent Recovery
Equalization
Neutralization
Primary Chemical Flocculation/
Clarification
Landfill

Solvent Recovery
Steam Stripping
In-Plant Neutralization
Equalization
Neutralization
Coarse Settleable Solids Removal
Primary Chemical Flocculation/
Clarification
Activated Sludge
Landfill

Equalization
Neutralization
Primary Sedimentation
Activated Sludge
Multi-Media Filtration
Chi or inaction
Vacuum Filtration
Incineration

Solvent Recovery
Neutralization
Primary Sedimentation
Aerated Lagoon
Polishing Pond

Equalization
Neutralization
Coarse Settleable Solids Removal
                                 L-15

-------
 20258



 20263

 20273


 20297
 20298
 20310
20339

20342



20349
C D



  D

  D
20312
20319
BCD
D
                            Primary Sedimentation
                            Activated Sludge
                            Sludge Lagoon    i
 Equalization
 Neutralization   ;
 Activated Sludge ;

 Coarse Settleable; Solids Removal

 Coarse Settleable Solids Removal
 Sludge Hauling

 Neutralization   ;
 Coarse Settleable; Solids Removal
 Primary Sedimentation
 Activated Sludge
 .Trickling Filter
 P/C: Evaporation

 Metals Precipitation
 Xn-Plant Evaporation
 Neutralization   >
 Primary Sedimentation
 Activated Sludge
 incineration
 Cropland Use
                  I
 Cyanide Destruction
 Solvent Recovery
 Steam Stripping
 Neutralization
 Coarse SEttleable Solids Removal
                  i
 Aerated Lagoon
 Landfill

 Coarse Settleable Solids Removal
 P/C:  Oxidation
 Trickling Filter
 Waste Stabilization'Pond
 Sludge Hauling

 Waste Stabilization Pond

 In-Plant Neutralization
 Coarse Settleable Solids Removal
 Sludge Hauling    ;

Neutralization
X
                                                                   X


                                                                   X
                                L-16

-------
20355

20356

20363



20370



20373




20376

20389

20402
  C

  C D

  C D
B C
20423
20456
20476
D
D
D
Neutralization

In-Plant Neutralization

Equalization
Neutralization
Primary Sedimentation

Rotating Biological Contractor
Chlorination
Sludge Hauling

Steam Stripping
In-Plant Evaporation
Neutralization
Primary Sedimentation w/Skimming

In-Plant Evaporation

Aerated Lagoon

Primary Sedimentation
Waste Stabilization Pond
Multi-Media Filtration

In-Plant Evaporation

Primary Sedimentation

Metals Precipitation
Ultraviolet Sterilization
Chlorination
                                L-17

-------

-------
          APPENDIX M

Pharmaceutical Industry Wastewater
        Discharge Methods

-------

-------
                           APPENDIX M
                     PHARMACEUTICAL INDUSTRY
                  WASTEWATER DISCHARGE METHODS
 Plant
Code No.

12000
12001
12003
12004
12005
12006
12007
12011
12012
12014
12015
12016
12018
12019
12021
12022
12023
12024
12026
12030
12031
12035
12036
12037
12038
12040
12042
12043
12044
12048
12051
12052
12053
12054
12055
12056
12057
12058
12060
Indirect
    X
    X
    X

    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
Direct
Zero
Comment
               X
               X
                  Recycle/Reuse

                  Land Application

                  No Process Wastewater
  POTW1
Treatment
  Level
                                             P
                                             S
                                             S

                                             S
                                             S
                                             T
                                   S
                                   S
               X
               X
               X

               X
                  Recycle/Reuse

                  Private Treatment System




                  Evaporation
                  Subsurface Discharge
                  Subsurface Discharge
                              Subsurface Discharge
                                   T
                                   T

                                   S

                                   S

                                   S
                                   S
                                   S
                                   S
                                             S
                                             P
                                             S
                                             S
                                M-r

-------
12061
12062
12063
12065
12066
12068
12069
12073
12074
12076
12077
12078
12080
12083
12084
12085
12087
12088
12089
12093
12094
12095
12097
12098
12099
12100
12102
12104
12107
12108
12110
12111
12112
12113
12115
12117
12118
12119
12120
12122
12123
12125
12128
12129
12131
12132
12133
12135
12141
12143
X
X

X
X
X
X

X
X
X
X
X
X
X

X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface Discharge
Septic System
Private Treatment System
Contract Disposal
           X
           X
           X
                   X

                   X
Deep Well Injection
   i
Contract Disposal

Ocean Discharge

   !
Ocean Discharge
           X

           X
Private Treatment System
Subsurface Discharge
                          Land Application
                          No Process Wastewater
S
S

S
T
T
P
P
P
S
P
T

S
P

S
T
P
P
T
S
S

S

S

S



T
                           S
                           s
                           s
                                M-2

-------
12144
12145
12147
12155
12157
12159
12160
12161
12166
12168
12171
12172
12173
12174
12175
12177
12178
12183
12185
12186
12187
12191
12194
12195
12198
12199
12201
12204
12205
12206
12207
12210
1221 1
12212
12217
12219
12224
12225
12226
12227
12230
12231
12233
1 2235
12236
12238
12239
12240
12243
12244
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X

X
X
X
X
X

X
X
X
X
X
X
X
X

X
X
X

X
X
X
X
                                          T
                                          s
                                          s
           X
           X
                   X
                   X
X

X
               Recyc1e/Reuse
               Private Treatment System
               Evaporation
               No Process Wastewater
               Evaporation
               Private Treatment System
Ocean Discharge

(Also Contract Disposal)

Private Treatment System
        X
           X
           X
Land Application


Contract Disposal


No Process Wastewater



Subsurface Discharge

Ocean Discharge



Contract Disposal
                           S
                           S
S
S

S
S
S

S
S
S
S
s

s
p
s

p
s
p
s
                                          s
                                          p
                                          T
                                M-3

-------
12245
12246
12247
12248
12249
12250
12251
12252
12254
12256
12257
12260
12261
12263
12264
12265
12267
12268
12269
12273
12275
12277
12281
12282
12283
12287
12289
12290
12294
12295
12296
12297
12298
12300
12302
12305
12306
12307
12308
12309
12310
12311
12312
12317
12318
12322
12326
12330
12331
12332
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X

X
X
X
X
X
X
X
X
X

X
X

X
X
X
               Evaporation
               Contract Disposal

               Private Treatment System
X

X

X
                   X
(Also Land Application)
LanJ3 Application
   I

Septic System
               Septic System
X
X
                   X
           X
           X
               Contract Disposal
                          Septic System
S
P
S

S
S
S
S
S
S
T
T
                           S
                           S
               Septic System
                           P
                           T

                           S
                           S
                                          P
                                          S
                                          T
                                          S
                                          S
                           P
                          ,,g
                          	S

                           S
                           P

                           P
                           S
                           S
                                M-4

-------
12333
12338
12339
12340
12342
12343
12345
12375
12384
12385
12392
12401
12405
12406
12407
12409
12411
12414
12415
12417
12419
12420
12427
12429
12433
12438
12439
12440
12441
12444
12447
12454
12458
12459
12460
12462
12463
12464
12465
12466
12467
12468
12470
12471
12472
12473
12474
12475
12476
12477
           X
           X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X

X
X
X

X
X
X

X
X
X
Land Application


Land Application
           X
           X
Contract Disposal
Land Application
Deep Well Injection
           X
           X
Land Application
Septic System
P
S
P.
S
S
S
T
S
S
T

T
T
S
S
S
S
S
S

S
S
                           S
                           S
                           P.
                           P
                           S
                   X
                   X
Land Application
Land Application
                                M-5

-------
12479
12481
12482
12495
12499
20006
20008
20012
20014
20015
20016
20017
20020
20026
20030
20032
20033
20034
20035
20037
20038
20040
20041
20045
20048
20049
20050
20051
20052
20054
20055
20057
20058
20062
20064
20070
20073
20075
20078
20080
20081
20082
20084
20087
20089
20090
20093
20094
20099
20100
X
X
X
X
X

X
X
X
X
X

X
X
X
X

X
X
X
X
X
X
                   X
                   X
                   X
                   X
                   X
                   X
                   X
                   X
                   X
                   X
                   X
X
X
X
X
X

X
X
X

X
X
X
X
X
       Ocean Discharge
       No Process Wastewater
       Evaporation
       No Process Wastewater
       No Process Wastewater
       Evaporation
                          No Process Wastewater
                        S
                        P
       No Process
       No Process
       No JProcess
       No {Process
       No Process
       No Process
        Wastewater
        Wastewater
        Wastewater
        Wastewater
        Wastewater
        Wastewater
       No Process Wastewater
       Septic System
       Contract Disposal
       No Process Wastewater
                          No JProcess
                          No process
                          No Process
                          No Process
                          No process
        Wastewater
        Wastewater
        Wastewater
        Wastewater
        Wastewater
                          No Process Wastewater
                          No Process Wastewater
                          No Process Wastewater
                          No
                          No
                          No
                          No
Process
Process
process
Process
                          No Process
Wastewater
Wastewater
Wastewater
Wastewater
Wastewater
                                 M-6

-------
20103
20106
20108
20115
20117
20120
20125
20126
20134
20139
20141
20142
20147
20148
20151
20153
20155
20159
20165
20169
20173
20174
20176
20177
20178
20187
20188
20195
20197
20201
20203
20204
20205
20206
20208
20209
20210
20215
20216
20218
20220
20224
20225
20226
20228
20229
20231
20234
20235
20236
X
X

X

X

X
X
X
X
X

X

X

X
X



X

X
X

X
X
X
X
X
                   X      No Process Wastewater
                   X      No Process Wastewater
                   X      Evaporation
                   X      Septic System
X      No Process Wastewater

X      No Process Wastewater

X      No Process Wastewater
       Contract Disposal

X      No Process Wastewater
X      No Process Wastewater


X      No Process Wastewater
       Contract Disposal

X      No Process Wastewater

X      No Process Wastewater

X      No Process Wastewater
X      Evaporation
X      No Process Wastewater

       Land Application
X      Land Application

X      Land Application
X      No Process Wastewater
X      No Process Wastewater
X      No Process Wastewater
X      No Process Wastewater

X      No Process Wastewater
                   X      No Process Wastewater
                   X      No Process Wastewater
                   X      No Process Wastewater
                   X      No  Process Wastewater
                   X      Contract Disposal
                                 M-7

-------
20237
20240
20241
20242
20244
20245
20246
20247
20249
20254
20256
20257
20258
20261
20263
20264
20266
20267
20269
20270
20271
20273
20282
20288
20294
20295
20297
20298
20300
20303
20305
20307
20308
20310
20311
20312
20316
20319
20321
20325
20328
20331
20332
20333
20338
20339
20340
20342
20346
20347
X
X
X

X
X
X
X
X

X
X
X

X
X
X
X

X

X
X
X
X
X

X

X

X
X
           X
           X
           X
           X
                   X
                   X
X

X
X
                   X
                   X
X

X

X
X

X

X
       No Process Wastewater
       No Process Wastewater
No Process Wastewater

No Process Wastewater
Contract Disposal
       No Process Wastewater
No Process Wastewater
       No Process Wastewater
       No Process Wastewater
No Process Wastewater

l^o Process Wastewater

ita Process Wastewater
Contract Disposal
 |
No Process Wastewater


No Process Wastewater


Kfo Process Wastewater

No Process Wastewater

Evaporation
                          No Process Wastewater
                                M-8

-------
20349
20350
20353
20355
20356
20359
20361
20362
20363
20364
20366
20370
20371
20373
20376
20377
20385
20387
20389
20390
20394
20396
20397
20400
20402
20405
20413
20416
20421
20423
20424
20425
20435
20436
20439
20440
20441
20443
20444
20446
20448
20450
20452
20453
20456
20460
20462
20464
20465
20466
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
 X
 X

 X

 X

 X
 X
 X
 X
 X
                   X
                   X
                   X
                   X
                   X
                   X
                   X
                   X
                   X

                   X
                   X
                   X
                   X
X

X

X
                    X
                    X
      Contract  Disposal

      Land  Application
      Evaporation
       Contract Disposal

       No Process Wastewater
       No Process Wastewater
       No Process Wastewater
       No Process Wastewater
       Contract Disposal
       No Process Wastewater
       No Process Wastewater
       Evaporation
       No Process Wastewater
       No Process Wastewater
       No Process Wastewater
       No Process Wastewater

       No Process Wastewater
No Process Wastewater

No Process Wastewater

No Process Wastewater
       No Process Wastewater
       No Process Wastewater
                                 M-9

-------
 20467
 20470
 20473
 20476
 20483
 20485
 20486
 20490
 20492
 20494
 20496
 20498
 20500
 20502
 20503
 20504
 20507
 20509
 20511
 20518
 20519
 20522
 20526
20527
20529
 X
 X
X
X
X
X


X
                    X
                    X
                    X
                    X
                    X
X
X
X
X

X
X
X
X
X

X
X
        Subsurface Discharge
        No Process Wastewater
        Deep Well  Injection

        No Process Wastewater
        No Process Wastewater
        No Process Wastewater
                          No Process Wastewater
                          No Process Wastewater
                          No Process Wastewater
                          No Process Wastewater
                          No Process
                          No Process
                          No Process
                          No Process
                          No Process
           Wastewater
           Wastewater
           Wastewater
           Wastewater
           Wastewater
No Process Wastewater
Contract Disposal

No Process Wastewater
  1POTW Treatment Level Symbols;
    P - Primary
    S - Secondary
    T - Tertiary
  2Data on POTW treatment level was not requested from the
   Supplemental 308 (20000 series)  plants
                               M-10

-------
           APPENDIX N



Cost of Treatment and Control Systems

-------

-------
                          .APPENDIX N

             COSTS OF TREATMENT AND CONTROL SYSTEMS
N-l  APPROACH (Also see Section VIII):
     1.   Define industry as represented by cost data.
     2.   Define subcategories.
     3    Determine representative flow for each subcategory based
          on single subcategory plants from 308 data base.
     4.   Determine representative raw waste loads for each sub-
          category from screening/verification data base.
     5    Estimate the respective treatment system investment costs
          (catalytic treatment cost model) and adjust to  1978 dollar
          basis which is the baseline year for all costs.
     6.   Estimate annual treatment costs for the various systems
          including operating, maintenance and annual ized investment
          costs (catalytic treatment cost model).
     7.   Estimate costs for contract hauling and other low volume
          wastewater treatment systems .
     8    Using costs estimated above for base case  "model  conditions
          develop variations of cost with flow, RWL and effluent target
          as parameters for the various wastewater systems.
     9.   Plot these variations in the form of cost sensitivity curves.

N-2
2.
                            RECORD  (ENR)  CONSTRUCTION  COST INDICES
           CHEMICAL  ENGINEERING  (CE)  PLANT  INDICES
                                N-l

-------
                                              APPENDIX "N
                     ENGINEERING NEWS - RECORD (BNR) CXtHgTRPCTION COST INDICES *

1964
1965 '
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
...1976— -
1977
1978
1979
1580
Jan.
918
948 '
988
1039
1107
1216
1309
1465
1686
1838
1940
2103
2305
2494
2672
2872
3237
Feb.
920
957
997
1041
1114
1229
13-11
1467
1691
1850
1940
2128
2314
2505
2681
2877
Mar.
922
958
998
1043
1117
1238
1314
1496
1697
1859
1940
2128
2322
2513
2693
2886
Apr.
926
957
1006
1044
1124
1249
1329
1513
1707
1874
1961
2135
2327
2514
2698
2886
May
930
958
1014
1059
1142
1258
1351
1551
1735
1880
1961
2164
2357
2515
2733
2889
June
935
969
1029
1068
1154
1270
1375
1589
1761
1896
1993
2205
2410
2541
2753
2984
July
945
S77
1031
1078
1158
1283
1414
1618
1772
1901
2040
2248
2414
2579
2821
3052
Aug.
948
984
1033
1089
1171
1292
1418
1629
1777
1902
2076
2274
2445
2611
2829
3071
Sept.
947
986
1034
1092
1186
1285
1421
1654
1786
1929
2089
2275
2465
2644
2851
3120

Oct.
948
986
1032
1096
1190
1299
1434
1657
1794
1933
2100
2293
2478
2675
2851
3122

Nov.
948
986
1033
1097
1191
1305
1445
1665
1808
1935
2094
2292
2486
2659
2861
3131

Dec.
948
988
1034
1098
1201
1305
1445
1672
1816
1939
2101
2297
2490
2660
2869
3140

Annual
Index
936
971
1019
1070
1155
1269
1385
1581
1753
. . .1895
2020
2212
2401
2557
2776
3003

* Construction Cost Index - Base Year  1913 - 100

-------
                                                        APPENDIX N
                                      CHEMICAL ENGINEERING (CB) PLANT COST INDICES*
Year
1972
1973
1974
1975
1976
1977
1978
1979
1980
Jan*
136.5
140.8
150.0
179.6
187.1
198.7
210.6
225.9
249.9
Feb.
136.0
140.4
150.7
179.5
187.5
198.5
213.1
231.0
255.1
Mar.
137.0
141.5
153.8
180.7
188.4
199.3
214.1
232.5

Apr.
137.1
141.8
156.7
180.7
188.9
200.3
215.7
234.0

May
137.1
142.4
161.4
161.0
190.2
201.4
216.9
236.6

June
136.5
144.5
164.7
181.8
191.1
202.3
217.7
237.2

July
136.5
144.6
168.8
181.8
192.0
204.7
219.2
239.3

Aug.
137.0
145.0
172.2
181.9
193.9
206.4
221.6
240.7

Sept.
137.8
146.4
174.8
183.7
195.6
208.8
221.6
243.4

Oct.
138.2
146.7
176.0
185.4
196.3
209.0
223.5
245.8

Nov.
138.4
147.5
177.4
185.7
196.4
209.4
224.7
246.8

Dec.
139.1
148.2
177.8
186.6
197.4
210.3
225.9
247.6

Annual
Index
137.2
144.1
165.4
182.4
192.1
204.1
218.8
238.7

I
CO •
         *  CB Plant Cost  Index - Base Year  1957-59 »  100

-------

-------
r
                                            APPENDIX 0

                                      Screening/Verification
                                     Plant Descriptions  and
                                           Sample Points

-------

-------
                        Screening Samples
Location
                                        Lab No.
                    Sample Type
Discharge from Treatment Plant
Sta 12	

Extractable (NVQA)
Composite Sampler Blank Flush
Metals Scan*, Phenols, Cyanides,
  purgeables (VGA)
TSS, COD, BOD5.

Influent to Neutralization Bldg.
Sta ft!	

Extractables (NVOA)
Composite Sampler Blank Flush
Metals Scan*, Phenols, Cyanides,
  purgeables (VOA)
TSS, COD, BOD5

Lab and Sanitary Waste Manhole
Building *46. Sta'tS	

Extractables (NVOA)
Composite Sampler Blank Flush
Metals Scan*, Phenols, Cyanides,
  purgeables (NOA)
TSS, BODJ5,  COD

Concentrated Waste Bldg.
Sta.  #4	

Extractables  (NVOA)
Metals Scan, Phenols,  Cyanides,
  Purgeables  (VOA)
TSS,  COD, BOD5

Animal and  Sanitary  Waste near
Bldq  ft74,  Standoipe  Sta  »3

Extractables (NVOA)
Composite Sampler Blank  Flush
Metals Scan*,  Phenols, Cyanides
   purgeables (VOA)
 TSS,  COD,  BOD5

 Super "0" Blank	
1935
1925
1935,
1935B
1935
1934
1924
1934,
1934B
1934
1933
1922
1933,
1933B
1933
 1932
 1932B

 1932
 1931
 1926
 1931,
 1931B
 1931
1935A,
1934A
1933A
 1931A
Composite
Grab
3 Grabs

Composite
Composite

3 Grabs

Composite
Compos i te
Grab
3 Grabs
              Grab**
              Grab**

              Grab**
 Composite
 Grab
 3 Grabs

 Composite
                                 0-1

-------
Extractables (NVOA)
Purgeables  (VOA)

Well $1 - Bldq 44
Extractables
Purgeables

Well »2 - Bldq 34
Extractables
Purgeables

Well. »3 - Bldq 49
Extractables
Purgeables
1930
1930
1927
1927
1928
1928
1929!
1929
Grab
Grab
Grab***
Grab
Grab***
Grab
Grab***
Grab
  *  Composited in Edison Lab               |
 **  Two Grab Samples Composited - All Samples Taken from Composite
***  Flow from three wells totals about 0.8'MGD
                              0-2

-------
                           Plant 12026

                      Verification Samples
 Sample
Location
Sample
 Type
Pollutants
 Analyzed
Intake Water (Well #34)
Intake Water (Well #44)
Intake Water (Well #49)
Return Slud,ge
(Secondary Clarifier)
Treated Effluent (Day 1 )
Treated Effluent (Day 2)
Treated Effluent (Day 3)
Grab

Blank

Grab

Blank

Grab

Blank

Grab

Grab

Grab
Blank
Blank

Composite
Grab

Composite
Grab
Blank

Composite
Grab
Blank
Extractables, VOA
Cyanides
Extractables, VOA

Extractables, VOA,
Cyanides
Extractables, VOA

Extractables, VOA
Cyanides
Extractables, VOA

Extractables, VOA
Cyanides
Extractables, VOA
Cyanides
Extractables, VOA
Cyanides

Extractables
VOA, Extractables
COD, BOD
TSS
VOA, Cyanides

BOD, TSS
VOA, Cyanides
VOA

BOD, TSS
VOA, Cyanides
VOA
                               0-3

-------
 4.    Plant 12036
 Plant  12036  is a Subcategory A plant which discharges 1.13 MGD of
 wastewater from pesticide manufacturing  processes.    This  plant
 also manufactures synthetic organic chemicals.

 The treatment  system for this plant consists of activated sludge,
 trickling    filters,   secondary  clarification,  aerated  lagoons
 (other  than  activated  sludge),   a  stabilization   lagoon,   and
 chlorination.    The   sampling  points  and parameters sampled for
 follow;
 001 Discharge

 Date

 8/31/77

 8/31 -
 9/1/77


 9/1/77
               Time

               0905

               0910
               to  1010


               1010
                               Temp
                               25
Pond 4 Effluent Prior to Chlorination
                              Temp ~C
Date
8/31/77
8/31 -
9/1/77
Time
0930
0930
to 0955
9/1/77
9/1 -
2/77
9/2/77


9/1/77
               0955
               0955
               to 0855
               0855
               1120
                              24
                                              Parameters
                                               i
                                               i
                                              Organics (sampler blank)

                                              Priority pollutants,
                                              pH,  BOD5_, COD,  NFS,
                                              nutrients

                                              Volatile organics,
                                              phenolics,  cyanide
                                              Parameters
                                               !
                                              Organics (sampler blank)

                                              Priority pollutants,
                                              BQD5_,  pH,  COD,  nutrients,
                                              NFS

                                              Volatile organics,
                                              phenolic,  cyanide

                                              Priority pollutants,
                                              BOD5_,  pH,  COD,  NFS,
                                              nutrients
                                             Volatile orgcmics,
                                             phenolics, cyanide

                                             Priority pollutants,
                                             BQD5_, pH, COD, NFS,
                                             nutrients
                               0-4

-------
Agricultural Research Farm Discharge to the Waste Treatment Plant

Date                Time                Parameters

                    1140
9/1/77

9/1  -
2/77

9/2/77
                    1140
                    to 0955

                    0955
               Organics (sampler blank)

               Priority Pollutants
               Volatile organics, phenolics,
               cyanide
Process Waste Discharge from Packaging Operations

Date                Time           •     Parameters"

9/1/77
9/1 -
2/77
                    0910

                    0915
                    to 0930
               Organics (sampler blank)

               Priority Pollutants
9/2/77              0930


Combined Wastestreams from Organic Chemical Synthesis, Most of
                                        Volatile organics, phenolics,
                                        cyanide
the Fermentation, the Offices and
Date
8/31/77
8/31 -
9/1/77
Time Temp °C
. 1000 —
1015
to 0830
the Laboratories
Parameters
Organics (sampler blank)
Priority pollutants
9/1/77
               0830
44
Volatile organics, phenolics,
cyanide
5.   Plant 12038
Plant 12038 is a multiple-subcategory plant (A, B, C> D) with  an
annual  average  flow  of  2.61  MGD.  A brief description of the
wastewater sampling points is as follows:

                        Screening Samples

Point 1 - Wastewater treatment plant  effluent  (001  Discharge).
Four  manual  composite  samples were taken here and analyzed for
priority pollutants, BOD5,  COD,  pH,  nutrients,  non-fillerable
solids (NFS), and Al.
                               0-5

-------
Point 2 - Combined effluent from limestone bed and hillside storm
sewer.   Three  samples   (one  blank)  were  taken  here and were
analyzed for priority pollutants.
                                          i
Point 3 - Building  T-17  process  waste  discharge   (pesticide).
Three  samples  (one  blank)  were  taken  here  and  analyzed for
priority pollutants.

Point 4 - Chemical  synthesis  influent   T302  to  T303.   Three
samples  (1  blank)  were  taken  here  and analyzed  for priority
pollutants.
Point 5 - Influent to T307B clarifier.
and analyzed for priority pollutants.
One sample was taken here
Point 6 - Effluent line from carbon column train.  One sample was
taken here and analyzed for metals, BOD£, COD, pH, nutrients, and
phenols                                   '

Points 7 and 10 - Adjacent points near T312 and T212 clarifier.

Point 8 - Concentrated antibiotic  waste-influent  to  biological
treatment.   One  sample was taken here and analyzed for priority
pollutants.
                                          i
Point 9 -  Dilute  antibiotic  waste  influent  to  T201.   Three
samples  (one  blank)  were  taken here and analyzed for priority
pollutants.

Plant 12038 uses a number of  wastewater  treatment  technologies
which  include  equalization,  neutralization,  activated sludge,
aerated lagoon, and in-plant treatments.
                               0-6

-------
                           Plant 12038

                      Verification Samples
Sample
Location
T66 Influent
(Pesticides)
T57 Effluent
(Pesticides)
T66 Effluent
(Pesticides)
307B Influent
(Pesticides)
307B Effluent
(Pesticides)
Tertiary Plant
Effluent (All)
312 Effluent
Type
Grab

Grab

Grab

Grab

Grab

Grab

Grab
Sample Pollutants
Analyzed
Priority Pollutants,
COD
Priority Pollutants,

Priority Pollutants,
COD
Priority Pollutants,
BOD, COD, TSS
Priority Pollutants,

Priority Pollutants
BOD, COD, TSS, NH3-N
Priority Pollutants
(Synthesis &
Pesticides)

300 Effluent
(Synthesis)
(302/306 Influent)

212 Effluent
(Fermentation)

Beer Storage
Tank (Fermentat ion)

100 & 200 Influent
(Fermentation)

Thermal Oxidizer
Waste (Pesticides)

Tertiary Plant
Influent (All)
Grab



Grab


Grab


Grab


Grab
               BOD, COD, TSS
Priority Pollutants
BOD, COD, TSS
Cyanide, BOD, COD,
TSS, NH3-N

Cyanide, BOD, COD,
TSS, NH3-N

Cyanide, BOD, COD
TSS, NH3-N

Cyanide
               Priority Pollutants
               BOD, COD, TSS, NH3-N
                               0-7

-------
6.
Plant 12044
Plant 12044 is a multiple  subcategory (A,  D)  pla'ht with an annual
average flow of 2.97 MGD.                        I
                                                                      ,,,!!„,' 	;,i,|i	;„ , .if;,,;
Seven sample points were   identified;
actually sampled.
Screening Samples
                                  however,  only   five   were
Citric  acid production effluent after  neutralization with lime -
Location 1, #81 manhole:
CDO Sample
Number
23-05-CM13R03
23-05-CM13S05
               Date
               8/1/78

               8/2/78
 Time
(Hours)
1500
0822 8/2
to 0822 8/3
23-05-CM13SO6
23-05-CM13S07
23-05-CM1 3SO8
8/2/78
8/2/78
8/2/78
Effluent at Location 2, #83
CDO Sample
Number
23-05-CM13S11
23-05-CM13S12
23-05-CM13S13
23-05-CM13S14
Date
8/2/78
8/2/78
8/2/78
8/2/78
0749
0735
0735
manhole:
Time
(Hours)
0850 to
1445
1003
1000
1000
Parameters
___^^_^___
Quality control  (QC) blank
for extractable  organics,
metals and COD
24-jiour composite for
extractable organics, metals,
COD and BOD
Grab for VOA
   i
Grab for phenol
Grab for cyanide
                                             Parameters
                                                 I
                                             Composite Comprising three
                                             3-liter grabs for extractable
                                             organics, metals, BOD and COD
                                             Grab for VOA
                                             Grab for phenol
                                          "f
                                             Grab for cyanide
                                0-8

-------
Effluent at Location 4, #37A manhole:
CDO Sample
Number
23-05-CM13S21
23-05-CM13S22
23-05-CM13S23
23-05-CM13S24
Effluent at Location
CDO Sample
Number
23-05-CM13S31
23-05-CM13S32
23-05-CM13S33
23-05-CM13S34
Effluent at Location
CDO Sample
Number
23-05-CM13S36
23-05-CM13S37
23-05-CM13S38
23-05-CM13S39
Date
8/2/78
8/2/78
8/2/78
8/2/78
6, *6
Date
8/2/78
8/2/78
8/2/78
8/2/78
7, #74
Date
8/2/78
8/2/78
8/2/78
8/2/79
Time
(Hours)
0905 to
1455
1035
1033
1033
manhole:
Time
(Hours)
0926 to
1510
1115
1115
1115
manhole:
Time
(Hours)
0920 to
1415
1 125
1125
1125
Parameter
Composite comprising three
3-liter grabs for extractable
organics, metals, BOD and COD
Grab for VOA
Grab for phenol
Grab for cyanide

Parameter
Composite comprising three
3-liter grabs for extractable
organics, metals, BOD and COD
Grab for VOA
Grab for phenol
Grab for cyanide

Parameter
Composite comprising three
3-liter grabs for extractable
organ ics, metals, BOD and COD
Grab for VOA
Grab for phenol
Grab for cyanide
The only method of wastewater treatment
is neutralization.
employed by  plant  12044
                              0-9

-------
 7.    Plant 12066

 Plant 12066 is predominately a Subcategory B manufacturer with  a
 small  percentage of activities under Subcategories C and D.   The
 annual  average  flow  is   0.26   MGD.     Wastewater   treatment
 technologies  employed  are neutralization,  activated sludge,  and
 aerated lagoon.

 Screening Samples

 Influent to Pretreatment Facility

 An  ISCO Model  1680 automatic sampler  #104  was installed   to  pump
 equal  volume  aliquots from the wet well of  the  raw sample house.
 Grab  samples were also  obtained.   The  following   samples  were
 collected:
SAD
Sample No.

23-05-CMIIS02
(Blank)
23-05-CMIIS02



23-05-CMIISO3

23-05-CMIIS04

23-05-CMIISO
6/28/78
6/29/78
6/29/78

6/28/78

6/28/78
0825
0830
1015

1515

1515
Parameters

Quality Control (QC)
Blank for extractable
organics, metals and
COD

24 hr. composite for
extractable organics,
metals, COD, and BOD

Grab for VOA

Grab for phenols

Grab for cyanide
Effluent from Pretreatment Facility
An  ISCO  Model 1680 automatic sampler #108 was installed to pump
equal volume aliquots from  the  discharge  flume  of  the  final
clarifier.   Grab  samples  were  also  obtained.   The following
samples were collected:
                              0-10

-------
SAD
Sample No.

23-05-CMIISOI
(Blank)
23-05-CMIISOI



23-05-CMIISO6

23-05-CMIIS07

23-05-CMIISO8

8.   PLant 12097
Date

6/27/78
Time

1315
6/28/78
6/29/78
6/29/78
6/28/78
6/28/78
0825
0835
0930
1430
1435
Parameters

Quality Control (QC)
Blank for organics,
metals and COD

24 hr. composite
for organics, metals,
COD and BOD

Grab for VOA

Grab for phenols

Grab for cyanide
Plant 12097 is a multiple-subcategory plant  (C, D) with an annual
average flow of 0.10 MGD.  The wastewater treatment  technologies
employed  include  equalization,  neutralization,  and  activated
sludge with powdered activated carbon.

Screening Samples

Well Water - Sample #2305EG16S13

A single grab sample was obtained directly from a tap in building
141 .

River Intake - Sample #2305EG16S09-10

Composite samples were obtained by  ISCO sampler through a grating
covering the intake structure.  Grab samples were  obtained   from
the surface water below the grating..The intake was located  in a
small creek estuary of the Black River.

Cooling Water Discharge - Sample I2305EG16S11-12

Composite samples were obtained by  ISCO sampler below the weir at
the  discharge  point to Black River.  Grab  samples were obtained
from the surface water of the cooling water  discharge.

Treated Floor Drain - Sample I2305EG16SO7-78

Composite samples were obtained by  ISCO sampler from a small  sump
receiving  water  from  90°  V-notch  weir.    Grab  samples   were
collected from the flow over the V-notch weir.
                                0-11

-------
Raw Waste Floor Drain - Sample #2305EG16S05-06

Composite  samples  were  obtained  by  ISCO sampler from a small
equilization tank  prior  to  activated  sludge  aeration.   Grab
samples  were obtained from the surface water of the equilization
tank.

Treated Deep Well - Sample #2305EG16S03-04

Composite samples were obtained by  ISCO  sampler  from  a  metal
bucket  receiving  water  from  a  pipe  inside  the  pump house,
building #31.  Grab samples were collected Directly from the pipe
flow.

Raw Waste Deep Well - Sample #2305EG16S01-02
                          obtained  by  ISCO   sampler   from   c
                     jar  which receives water from a small pipe.
Composite  samples  were
2 1/2-gallon  glass
Grab samples were obtained directly from the pipe.
Sample Types and Frequency

All sample sites, except the well-water sites, included a 24-hour
composite sample and one grab sample.  All composite samples were
obtained by ISCO samplers programmed to collect aliquots every 30
minutes.   Two  samplers  were  used  at  each  site  to   obtain
sufficient  sample  volume  to  provide a split with the company.
Composite sample types  included  general  Chemistry,  nutrients,
metals,  and  liquid  extraction  organics.!   One additional grab
sample was collected at each composite site!for phenols, cyanide,
and volatile organic analyses.  The sample ;types  obtained  from
the  well-water  site were all grab samples for the same analyses
as those collected at the composite sites. .

Field parameters, pH and temperature, were  determined  for  each
grab  sample, while pH was determined on each composite sample at
the end of the survey.   Flow  data  was  obtained  for  the  two
treated waste streams and the cooling water discharge.
                                0-12

-------
                           Plant 12097

                      Verification Samples
 Sample
Location

Tap Water SP6
Tap Water SP6
Tap Water SP6
Tap Water SP6
River Water SP7
River Water SP7
River Water SP7
River Water SP7
Infl Floor SP1
Infl Floor SP1
Infl Floor SP1
Infl Floor SP1
Infl Floor SP1
Infl Floor SP1
Effl Floor SP2
Effl Floor SP2
Effl Floor SP2
Effl Floor SP2
Effl Floor SP2
Effl Floor SP2
Infl DP Well SP3
Infl Dp Well SP3
Infl Dp Well SP3
Infl Dp Well SP3
Effl Dp Well SP4
Effl Dp Well SP4
Effl Dp Well SP4
Effl Dp Well SP4
Effl Dp Well SP4
Effl Dp Well SP4
Tap Water SP6
Tap Water SP6
Tap Water SP6
Tap Water SP6
Tap Water SP6
River Water SP7
River Water SP7
River Water SP7
Sample
 Type

Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Comp
Comp
Grab
Grab
Grab
Grab
Comp
Comp
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Comp
Comp
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Pollutants
 Analyzed

Phenol
Cyanide
BOD5 - TSS
COD - TOC
Phenol
Cyanide
BOD5. - TSS
COD - TOC
Phenol
Cyanide
Phenol
Cyanide
BOD5. - TSS
COD - TOC
Phenol
Cyanide
Phenol
Cyanide
BOD5. - TSS
COD - TOC
Phenol
Cyanide
BOD5 - TSS
COD - TOC
Phenol
Cyanide
Phenol
Cyanide
BOD5. - TSS
COD - TOC
VGA
VOA (Dup)
VGA (Sup 2)
Extractable
Extrac (Dup)
VOA
VOA (Dup)
VOA (Dup2)
                               0-13

-------
                           Plant  12097

                 Verification Samples  (Cont'd.)
 Sample
Location

River Water SP7
River Water SP7
Infl Floor SP1
Infl Floor SP1
Infl Floor SP1
Infl Floor SP1
Infl Floor SP1
Infl Floor SP1
InflFloor SP1
Infl Floor SP1
Infl Floor SP1
Infl Floor SP1
Infl Floor SP1
Effl Floor SP2
Effl Floor SP2
Effl Floor SP2
EFfl floor SP2
Effl Floor SP2
Effl Floor SP2
Effl Floor SP2
Effl Floor SP2
Effl Floor SP2
Infl DP Well SP3
Infl Dp Well SP3
Infl DP Well SP3
Infl Dp Well SP3
Infl Dp Well SP3
Effl Dp Well SP4
Effl Dp Well SP4
Effl Dp Well SP4
Effl Dp Well SP4
Effl Dp Well SP4
Effl Dp Well SP4
Effl Dp Well SP4
Effl Dp Well SP4
Effl Dp Well SP4
Tap Water SP6
River Water SP7
Infl Floor SP1
Effl Floor SP2
Infl Dp Well SP3
Effl Dp Well SP4
Sample
 Type

Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
SB
Comp
Comp
TB
TB
Grab
Grab
Grab
Grab
Grab
Grab
SB
Comp
Comp
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
SB
Comp
Comp
Grab
Grab
Comp
Comp
Grab
Comp
                               0-14
                                        SB
                                        TB
     Pollutants
      Analyzed

     Extractable
     Extrac (Dup)
     VOA
     VGA (Dup)
     VOA (Dup2)
     VOA
     VOA (Dup)
     VOA (Dup2)
     Sampler Blnk
     Extractable
     Extrac (Dup)
     VOA
     VOA (Dup)
     VOA (Pres)
     VOA-DUP-PRES
     VOA-DP2-PRES
     VOA (Pres)
     VOA-DUP-PRES
     VOA-DP2-PRES
     Sampler Blnk
     Extractable
     Extrac (Dup)
     VOA
     VOA (Dup)
     VOA (Dup2)
     Extractable
     Extrac (Dup)
     VOA
     VOA (Dup)
     VOA (Dup2)
     VOA
     VOA (Dup)
     VOA (Dup2)
     Sampler Blnk
     Extractable
     Extrac (Dup)
     Metals
     Metals
     Metals
     Metals
     Metals
     Metals

Sampler Blank
Trip Blank

-------
 9.    Plant 12108

 Plant 12108  is a multiple-subcategory (A7  C,   D)   plant  with  an
 annual   average  flow  of   0.14 MGD.   The  facility utilizes ocean
 disposal of  their wastewater;  they provide no treatment.

 Screening Samples

 Point 1  - sample set  taken  from tank  truck loading  from   holding
 tanks.

 Samples:

 (1)   One gallon for extractable organics

 (2)   Four 1/2-gallon  samples for BOD's,  metals,   cyanides,   COD,
 and TOC

 (3)   Two  1-pint samples for phenol  and mercury

 (4)   Two  4-ounce  vials for volatile organics

 10.   Plant 12119

 Plant 12119 has fermentation (A) and formulation  (B)  subcategory
 operations.   Wastewaters  are   collected  in an equalization  tank
 and then  treated  in an activated sludge system.

Screening Samples

 Intake Water (EL-OOR)  - A grab sample was  collected from a tap on
the city water distribution line.
SAD Sample No.

23-04-78C-1783
                    Date           Time      Parameter

                    7/27/78        0940      BOD, COD, TOC, TKN,
                                             NH3-N, N0?-N03, Total P,
                                             solid series, chlorides,
                                             pH, temperature, non-
                                             volatile organics, Hg,
                                             metals, CN, phenol,
                                             volatile organics

Fermentation Wastewater (EL-OOF)—A grab sample was collected at
a tap on the waste broth tanks (C-135).                    ~	
                             0-15

-------
SAD Sample No.

23-04-78C-1784
                    Date

                    7/27/78
Time

0925
Parameter

BOlL COD. TOG. TKN,NH,-N,
Total P, solids series, pH,
Hg, temperature, metals,
non-volatile orqanics, phenol,
CN. volatile orpanics
Ammonia Stripped Wastewater |EL-OON)—A grab sample vtes collected
at a tap on the Ammonia Stripping line.
SAD Sample No.

23-04-78C-1785
                    Date           Time      Parameter

                    7/27/78        0910      BOD, COD, TOC, TKN, NH3-N,
                                             N03-N02, Total P, solids
                                             series, metals, pH, Hg, CN,
                                             temperature, non-volatile
                                             orqanics, VOA, phenol

Influent to Treatment (EL-OOI)—A composite sample was  collected
atthe flow eauilization box upstream of any treatment, using an
ISCO  1680
collected.
           "automatic  sampler.   The  following   samples   were
SAD Sample No.

23-04-78C-1565




23-04-78C-1786




23-04-78C-1786
                    Date

                    7/6/78
                    7/26/78
                    7/27/78
                    7/27/78
Time      Parameter

1505      QC Blank precollected at
          the SAD Lab, Athens, GA
          noiji-volatile organics,
          metals, mercury
             !

1000/     BOD, COD,  TOC, Total P,
0830      solids series, TKN, NH3-N,
          N03-N02, nonvolatile organics,
          mercury, metals

0835      cyanide, phenol,  pH, tem-
          perature,  volatile  organics
                                0-16

-------
 1]•  Plant  12132

 Plant  12132  is a  combination A  and C plant  with  an  annual  average
 flow   of  1.0  MGD.   The  wastewater    treatment    consists    of
 equalization,  neutralization,  activated   sludge   and   trickling
 filter.

 Samples Collected

 (1)  Sedimentation Basin Effluent (Influent  to  Biotreatment)  -
     Grab  and  composite samples taken  and analyzed for priority
     pollutants.

 (2)  Final Clarifier Effluents  - Grab and composite  samples taken
     and analyzed for priority  pollutants.

No analyses were run for  traditional  pollutants;   however,  the
plant  did  supply these data.  Two additional sample points were
identified (final clarifier sludge and DAF skimmings),  but  were
not sampled in the screening program.

12.  Plant 12161                                              ;

Plant  12161  is a multiple-subcategory (A, C,  D)  plant  with  an
annual  average  flow  of  1.0  MGD.    The  wastewater  treatment
employed includes equalization,  neutralization, activated  sludge
and polishing ponds.
                              0-17

-------
                        Screening Samples
                                   Lab No.

Raw Waste-Vitamin C Plant

Nonvolatile Organics, Metals       50689
Phenols, Cyanides, Purgeables      50677
Phenols, Cyanides, Purgeables      50682
Composite Sampler Blank Rinse      50671

Raw Waste-Sulfa Plant

Nonvolatile Organics, Metals       50690
Phenols, Cyanides, Purgeables      50678
Phenols, Cyanides, Purgeables      50683
Composite Sampler Blank Rinse      50672

Raw Waste-Fermentation Plant

Nonvolatile Organics, Metals       50691
Phenols, Cyanides, Purgeables      50679
Phenols, Cyanides, Purgeables      50684
Composite Sampler Blank Rinse      50673

Raw Waste (Combined) to WWTP

Nonvolatile Organics, Metals       50688
Phenols, Cyanides, Purgeables      .50676
Phenols, Cyanides, Purgeables      50681
BOD5., TSS, COD                     50687
Composite Sampler Blank Rinse      50670

Discharge 001 - Treated from WWTP

Nonvolatile Organics, Metals       50692
Phenols, Cyanides, Purgeables      50680
Phenols, Cyanides, Purgeables      543685
BOD5_, TSS, COD                     50693
composite Sampler Blank Rinse      50674
  Sample
   Type
Compos i te
  Grab
  Grab
  Grab
Compos i te
  Grab
  'Grab
  Grab
Composite
  Grab
  Grab
  Grab
Composite
  Grab
  Grab
Composite
  Grab
Composite
  Grab
  Grab
  Grab
  Grab
Flow
(MGD)
1 .45*
0.726*
0.726*
Blank
0.018*
0.009*
0.009*
Blank
0.062
0.028
0.035
Blank
3.74
1 .73
2.01
1 .73
Blank
3.54
1 .78
1 .76
1 .76
Blank
* Estimates
                                0-18

-------
 13.  Plant  12204

 Plant  12204  is a multiple-subcategory  (A, B, C,  D) plant with   an
 annual  average  flow  of  0.20  MGD.  This plant employs primary
 treatment  and  pure-oxygen  activated  sludge   for   wastewater
 treatment.
 Sample
Location

Municipal Water
Well WAter
Combined Treated
Process Wastewaters
Combined Raw
Process Wastewaters
Fermentation Processing
Area Discharge
                        Screening Samples
Sample
 Type

Grab
Grab
Grab
Grab

Grab
Grab
Grab
Grab

Composite
Grab
Grab
Grab
Grab

Composite
Grab
Grab
Grab
Grab

Composite
Grab
Grab
Grab
Grab
     Pollutants
      Analyzed

Non-volatile Organics, Metals
Cyanides/ Phenols
Purgeable Organics
Purgeable Blank

Non-Volatile Organics, Metals
Cyanides/ Phenols
Purgeable Organics
Purgeable Blank

Non-Volatile Organics/ Metals
Composite Sampler Blank Rinse
Cyanides, Phenols
Purgeable Organics
Purgeable Blank

Non-volatile Organics, Metals
Composite Sampler Blank Rinse
Cyanides, Phenols
Purgeable Organics
Purgeable Blank

Non-volatile Organics/ Metals
Composite Sampler Blank Rinse
Cyanides, Phenols
Purgeable Organics
Purgeable Blank
No  analyses  were  made for traditional pollutants; however, the
plant provided data for these pollutants.

14.  Plant 12210

Plant 12210 is a multiple-subcategory (B, C) plant with an annual
average  flow  of  0.01  MGD.   The  only  method  of  wastewater
treatment utilized by Plant 12210 is an aerated lagoon.
                               0-19

-------
                        Screening Samples
Volatile  Organics Blank (CL-OOB) — Samples of MJ116Q water from
the Region IV laboratory were returned for analyses.
Sample Number*

23-04-78C-1022
                    Date

                    4/25/78
Time

1015
Parameter

Volatile Organics
Process Wastewater at Waste  Storage  Tanks   (CL-OOP)  —An  ISCO
Model  1580  automatic  sampler  was used to pump wastewater from
each  of  the  three  wastewater  storage  tanks  into  a  single
composite jug.  The following samples were collected.
                    Date      Time      Parameter

                    4/25/78   1025      Quality control blanks
                                        for non-volatile organics,
                                        metals, mercury

                    4/25/78   1030      Non-volatile organics,
                                        metals, mercury,
                                        TSS, volatile organics,
                                        cyanide, phenols

Influent  to Pretreatment System for Sanitary Wastewater (CL-OOI)
—- A single grab sample was collected  at  ;the  influent  to  the
aeration system.                           :
Sample Number

23-04-78C-1020



23-04-78C-1021
Sample Number

23-04-78C1024
                                           I	  •   	
                    Date      Time      Parameter

                    4/25/78   1055      Nori-volatile organics,
                                        metjals, mercury, volatile
                                        organics, cyanides, phenols,
                                        Bod5_, TSS
Effluent  from  Pretreatment  System for Sanitary Wastewater  (CL-
OOE) — A single grab sample was collected at the  effluent   from
the aeration system.                       ;
Sample Number

23-04-78C-1023




15.  Plant 12231
                    Date

                    4/25/78
Time

1100
Parameter
   i
Non-volatile organics,
metals, mercury, volatile
organics, cyanide, phenols,
BOD5_, TSS
                                0-20

-------
a^--       -v- QV'-0o


       „  ** W*^  ~

  ,rt  °^ ^*^0^
 a^-AtapO ^v a^

-------

-------
 Effluent from Wastewater Treatment System (MA-OOE)—An ISCO Model
 1680  automatic sampler was installed at  the  effluent  from  the
 final  clarifiers.    The intake line was placed in the wastewater
 stream.   The following samples were collected.
 SAD  Sample  No.

 23-04-78C-1142
23-04-78C-1143
23-04-78C-1144
 Date       Time       Parameter

 5/9/78     0945       Quality  control  blank  for
                     non-volatile  organics,  metals,
                     mercury

 5/9/78     1000       pH

 5/9/78     1000       Non-volatile  organics,  metals,
 5/10/78    0930       mercury, BOD5, TSS, TKN, COD

 5/10/78    0930       Cyanide, phenols,  volatile
                     organic, pH
Non-contact Cooling Water Discharge  (MA-OOC)—An  ISCO  Model   1580
automatic  sampler  was  installed   adjacent   to   the  non-contact
cooling water discharge ditch.  The  intake  line was placed  in the
cooling water stream.  The following samples were collected.
SAD Sample No.

23-04-78C-1148




23-04-78C-1 149


23-04-78C-1150
Date

5/9/78
5/9/78
5/10/78
Time

1030
1045/
1030
5/10/78   1015
Parameter

Quality control blank for
non-volatile organics, metals,
mercury

non-volatile organics, metals,
mercury

Volatile organics, phenols,
cyanide
                      Verification Samples
Volatile Organics Trip Blank - Preserved and unpreserved volatile
organic trip blanks (one each) were prepared in Athens EPA Region
IV laboratory prior to the sampling trip.  The blanks  were  left
exposed  to  ambient  conditions  and  shipped  with  the organic
samples to the contract laboratory.
SAD Sample No.

Samples shipped
to contract lab
Date
Time
6/21/79   1435
Parameter

Volatile Organics
                               0-23

-------
Raw Water Supply  (MH-OOR)  - Raw  water   was   collected   from  the
facility's well No.  6 at"the  discharge  side  of  the  well  pump.
SAD Sample No.      Date       Time

Samples shipped     6/26/79    1100
to contract lab
                    Parameter

                    volatile organics
Influent  to  the Waste Treatment System  (MH-OOI) - An  ISCO  Model
1680 automatic sampler was  installed at   the   equalization   basin
discharge.   The  intake  line was placed  in the wastewater stream
at the overflow ditch.  The following samples  were collected.
SAD Sample No.

23-04-79C-1571



23-04-79C-1572
Samples shipped to
contract lab

Samples shipped to
contract lab

23-04-79C-1573
23-04-79C-1574
Samples shipped to
contract lab

23-04-79C-1575
23-04-79C-1625
Samples shipped to
contract lab

23-04-79C-1626
Date

6/25/79
6/26/79
6/27/79
6/26/79


6/27/79
6/27/79
6/28/79

6/27/79
6/28/79
6/28/79
6/29/79
Time

1540
0830/
0830
6/26/79   0930
1330
0825
0845/
0830

1345
0830
0840/
0815
6/28/79   1330
6/29/79   0815
Parameter
Quality control blank
for metals sample
mercury

Metals, mercury
          pH, temp, volatile
          organics
pH, temp, volatile
organics
pH, temp, phenols,
cyanide, volatile organics
BOD, COD, Metals, TKN,
TSS, mercury

Volatile organics
pH, temp, cyanide,
phenols, volatile organics

BOD\COD, Metals, TKN,
TSSf Mercury

Volatile organics
          pH, temp, cyanide, phenols,
          volatile organics
                              0-24

-------
Effluent from the Waste Treatment System  (MH-OOE)—An  ISCO  Model
1680  automatic smapler was  installed at  the  final effluent after
secondary clarification.  The  intake line was placed in  the waste
stream at the facility's rectangular weir.  The following samples
were collected:
SAD Sample No.

23-04-79C-1576


23-04-79C-1577
Samples shipped to
contract lab

Samples shipped to
contract lab

23-04-79C-1578
23-04-79C-1579
Samples shipped to
contract lab

23-04-79C-1580
23-04-79C-1627
Samples shipped
to contract lab

23-04-79C-1628
Date      Time      Parameters

6/25/79   1600      Quality control blanks
                    for metals, mercury

6/26/79   0840-     Metals, mercury
6/27/79   0845

6/26/79   0950      pH, temp, volatile
                    organics

6/26/79   1400      pH, temp, volatile
                    organics

6/27/79   0900      pH, temp, cyanide,
                    phenols, volatile organics

6/27/79   0900-     BOD, COD, Metals, TKN,
6/28/79   0855      TSS, mercury

6/27/79   1415      Volatile organics
6/28/79   0900      pH, temp, cyanide, phenols
                    volatile organics

6/28/79   0900      BOD, COD, metals, TKN,
6/29/79   0900      TSS, mercury

6/28/79   1400      Volatile organics
6/29/79   0900      Cyanide, phenols, volatile
                    organics
                              0-25

-------
Effluent from Sludge Thickener  (MH-OOS)  six  grab  samples  were
collected from the sludge thickener  (before addition of polymers)
at a discharge line leading from the bottom of the mix tank.  The
following samples were collected:
SAD Sample No.      Date      Time

Samples shipped     6/26/79   1030

Samples shipped     6/26/79   1445
to contract lab

23-04-79C-1569      6/27/79   1000


Samples shipped     6/27/79   1515

23-04-79C-1570      6/28/79   1000
Samples shipped     6/28/79   1430
contract lab

23-04-79C-1629      6/29/79   0945
                    Parameters

                    Volatile organics
                       i
                    Volatile organics
                       i
                       i
                    Cyahide, metals, volatile
                    organics, mercury

                    Voljatile organics
                       !"••  -	•   ••   	••
                    Volatile organics, mercury,
                    metals, cyanide

                    Voljatile organics
                    Volatile organics,
                    metals, mercury
Effluent  from  the  Cyanide Destruct Unit  (MH-CN) - Grab samples
were colelcted  by  facility  personnel  from  a  bleedoff  value
leading  from  the cyanide destruct unit effluent.  The following
samples were collected.
SAD Sample No.

23-04-79C-1566

23-04-79C-1567

23-04-79C-1568
Date      Time      Parameters

6/26/79   1600      Cyanide

6/27/79   1030      Cyanide
                       i
6/28/79   1030      Cyanide
In-line Process from Factory !_ (NH-IP) - In-line process  samples
were  collected  from the production of acrylonitrile by facility
personnel.  The following samples were collected.
SAD Sample No.

23-04-79C-1565
Date

6/27/79
Time

1500
Parameters

COD, cyanide, metals, TKN,
extractable organics,
phenols, TSS, volatile,
organics, mercury
                               0-26

-------
17.  Plant 12248  ;
Plant 12248 is a single subcategory  (D)  plant  with  an  annual
average flow of 0.04 MGD.  Wastewater treatment employed includes
equalization and activated sludge.
Screening Samples
(1)
(2)
Equalization Basin (Influent to  treatment)  -  All  samples
taken were 24-hour composites and were analyzed for priority
pollutants.
Final Clarifier (Effluent  from  treatment)  -  All  samples
taken were 24-hour composites and were analyzed for priority
pollutants.
No traditional pollutant data were available for this plant.
18.  Plant 12256
Plant 12256 is a multiple-subcateogry (A, B, C, D) plant with  an
annual  average flow of 30 MGD.  End-of-pipe treatment is limited
to equalization, neutralization and solids removal.
Screening Samples1
(1)  Well area before discharge through outfall #001
(2)  Split Manhole discharging to outfall t002
(3)  Manhole prior to discharge to outfall #003
(4)  Skimming basin discharging to outfall f008
(5)  Collection basin discharge to skimming basin
(6)  Municipal sewers pumping station
(7)  Freshwater supply
(8)  Saltwater supply
In general, composite samples  (24 hour) were taken  for  priority
pollutants  other  than phenols, cyanides, and volatile organics,
for which grab samples were taken.
19.  Plant 12257
Plant 12257 is  an  A,  B,  C,  and  D  subcategories  plant.   A
treatment  system  composed  of neutralization, equalization, and
                              0-27

-------
activated sludge  is used to treat  0.5 MGD o£ wastewater prior  to
discharge to a POTW.

A  summary  of  sample  points  and  parameters  analyzed for are
presented below.

                        Screening  Samples
Combined plant process wastes after neutralization and  activated
sludge treatment.                           ,
Date
10/24/77
10/25/77
10/25/77
10/26/77
1 0/26/77
10/26/77
Combined
Date
1 0/24/77
1 0/25/77
Time
0940
0900
0900
0820
0820
0923
Plant
Time
0950
0925
Description
i
Tubing flush blank
Set of grab samples for phenol/
cyanide, volatile organics
24-hour automatic composite
i
i
Set of grab samples for phenol,
cyanide, and volatile organics
24-hour automatic composite
Set of grab samples for phenol,
cyanide, volatile organics, and
a 2 1/2-gallon grab sample
Process Wastes After Neutralization
Description
Tubing flush blank
Set of grab samples for !phenol,
10/26/77


10/26/77
0830


0830
cyanide, volatile organics, and
a 2 1/2-gallon grab sample

Set of grab samples for phenol,
cyanide, and volatile organics
24-hour automatic composite
                              0-28

-------
Raw  Fermentation  Process Wastes
Date
Time
 10/24/77   1005
 10/25/77   mo

 10/25/77  .1110
 10/26/77   0855

 10/26/77   0855
 10/26/77   0940
Description
Tubing flush blank
Set of grab samples for phenol,
cyanide, and volatile organics
24-hour automatic composite
Set of grab samples for phenol,
cyanide, and volatile organics
24-hour automatic composite
Set of grab samples for phenol,
cyanide, volatile organics, and
a 2 1/2-gallon grab sample
Raw Chemical Synthesis Process Wastes
Date
Time
10/24/77  1015
10/25/77  1130

10/26/77  0905

10/26/77  0905
10/26/77  0910
Description
Tubing flush blank
Set of grab samples for phenol,
cyanide, volatile organics, and
a 2 1/2-gallon grab sample
Set of grab samples for phenol,
cyanide, and volatile organics
24-hour automatic composite
Set of grab samples for phenol,
cyanide, volatile organics, and
a 2 1/2-gallon grab sample
Cooling Water Discharge at Bypass Line
Date      Time      Description
10/24/77  1040
          Set of grab samples for phenol,
          cyanide,  volatile organies,  and
          a 2 1/2-gallon grab sample
                              0-29

-------
Municipal Water Supply
Date

10/25/77

10/25/77
          Time

          1500

          1500
Description

Flow measurement

Set of grab samples for phenol,
cyanide,  volatile organics,  and
a 2 1/2-gallon grab sample
Volatile Organics Blank
                    Description

                    Volatile organics blank
Date      Time

10/25/77  1510

Plant 12311

20.  Plant 12342                           l
                                           i    •  	  . . .

Plant  12342  is  an  A,  C,  and  D  subcategories  plant  which
discharges 1.06 MGD of process wastewater without pretreatment to
a  POTW.   Below,  is  a  table  of  sample  points  and  sampled
parameters for this plant.
Discharge from Manhole No. 1*

Extractables (NVOA)
Sampler Blank (flush)
Metals**, Phenols, Cyanides,
 purgeables (VOA)
BOD, TSS, COD

Discharge from Manhole No. 5*

Extractables (NVOA)
Sampler Blank (flush)
Metals**, Phenols,
 cyanides, Purgeables (VOA)
BOD, TSS, COD

Discharge from Manhole No. 5*

Extractables (NVOA)
Sampler Blank (flush)
Metals**, Phenols,
 cyanides, Purgeables (VOA)
BOD, TSS, COD

Super "Q" Blank
                                        Sample Type
                                             Composite
                                           [  Grab
                                             3 Grabs

                                           "•  Composite
                                           l
                                        Sample Type

                                           |  Composite
                                           I  Grab
                                           j  3 Grabs
                                           i
                                           i  Composite
                                           i	   ., ,
                                        Sample Type

                                             Composite
                                             Grab
                                             3 Grabs

                                             Composite
                                           i
                                           ',  Sample Type
                               0-30

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Extractables (NVOA)
Purgeables (VGA)

Potable Water - Building 28

Extractables {NVOA)
Purgeables (VOA)
     Grab
     Grab

Sample Type

     Grab
     Grab
                                   Lab No
     Sample Type
Potable Water - Building No. 1

Extractables (NVOA)                2082
Purgeables (VOA)                   2082

Potable Water - Building No. 5

Extractables (NVOA)                2083
Purgeables (VOA)                   2083

Potable Water - Building No. 20A

Extractables (NVOA)                2084
Purgeables (VOA)                   2084
     Grab
     Grab
     Grab
     Grab
     Grab
     Grab
21.  Plant 12411

Plant 12411 is a B, C, and  D  subcategories  plant.   Wastewater
from   the   process   area   is   treated  with  neutralization,
equalization, and aeration, then combined with sanitary waste and
once-through cooling water, and then  discharged  to  a  sanitary
sewer.  The flow of process wastewater is 0.35 MGD.

The sample points and pollutants sampled for are presented below.

Screening Samples

Influent  to  Pretreatment System ™ An ISCO Model  1680 automatic
sampler was installed at the pretreatment system  influent.   The
intake  line was placed in the equalization basin,  the following
samples were collected.
                               0-31

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 Date
 Time
 Parameters
 4/26/78    0945
 4/26/78    1100
 4/26/78
 4/27/78
 1045
 0945
4/27/78    0945
 Quality control blank
 for non-volatile o|rganics,
 metals,  mercury   ;

 Temperature,  pH   ;

 Non-volatile  organics,
 metals,  mercury,  TSS BOD5_,
 total  phosphorus

 Volatile organics,  cyanide,
 phenols,  temperature, pH
Effluent  from  Pretreatment  System—An  ISCO Model   1680   automatic
sampler   was   installed  at  the pretreatment system effluent.   The
intake line was placed   in   the  mid-channel  upstream   fron   the
V-notch weir.  The  following samples were  collected.
Date
Time
4/26/78    1000
4/26/78    1045
4/27/78    0930
4/26/78   1100

4/27/78   0930
Parameters

Quality control  blank for
non-volatile organics, metals,
mercury
Non-volatile organics,
mercury, TSS, BOD5_
phosphorus

Temperature, pH
                                      metals,
                                   total
               Volatile organics, cyanide,
               phenols, temperature, pH
Combined Sanitary Cooling Water and Pretreated Process Wastewater
at  Access  Pit  —An  ISCO  Model  1680  automatic  sampler  was
installed at the "access pit." The intake line was places  in  the
waste  stream  at
were collected.
         the  bottom of the pit.  The following samples
4/26/78
4/27/78
1100
1015
Parameters

Quality control blank for
non-volatile organics, metals
mercury

Non-volatile organics, metals,
mercury, TSS, BOD5_> total
phosphorus
                              0-32

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4/26/78

4/27/78
1 100

1015
Temperature, pH

Volatile organics, cyanide,
phenols, temperature, pH
Plant 12411

Verification Samples

Volatile Organic Blanks (VOA) — A trip blank consisting of  well
water  was  placed  in a preserved and unpreserved VOA bottle and
carried into the field.
SAD Sample No

79C-1502
          Date

          6/7/79
     Time

     0900
Parameters
VOA
Effluent from Aeration Basins (BS-001E) —  An  ISCO  Model  1680
automatic  sampler  was  installed at the discharge weir box from
the aeration basins and collected the following samples:
SAD Sample No
79C-1578
79C-1519


79C-1520

79C-1521


Sample sent to
contract lab

79C-1522

79C-1523
Sample sent to
contract lab

79C-1524
          Date
          6/12/79
          6/12/79
          6/13/79
     Time
     1130
     1200
     1130
          6/13/79   1130
          6/13/79
          6/14/79
     1 130
     1100
          6/13/79   1325
          6/14/79

          6/14/79
          6/15/79
     1100

     1100
     1000
          6/14/79   1130
          6/15/79
     1000
Parameters
Quality control blanks
for non-volatile organics,
metals, mercury

Non-volatile organics,
metals, mercury, COD, TSS

VOA, phenol, cyanide

Non-volatile organics,
metals, mercury, COD, TSS

VOA
VOA, phenol, cyanide

Non-volatile organics,
metals, mercury, COD,
BOD5_, TSS

VOA
VOA, phenol, cyanide
Influent to Aeration  Basins  Collected  from  Holding/Mix  Basin
(BW-001I) —An ISCO Model 1680 automatic sampler was installed in
                              0-33

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                                                                •,	.Jit: 'tifS!1:	1!;i|!-tt:;:":*J|!111!
 the  holding  basin  before aeration.
 collected:
 SAD  Sample No

 79C-1504



 79C-1505


 79C-1506

 79C-1507


 Sample sent  to
 contact lab

 79C-1508

 79C-1509
Sample sent to
contract lab

79C-1510
Date

6/12/79
6/12/79
6/13/79

6/13/79

6/13/79
6/14/79
6/14/79
6/15/79
Time

1115
1230
1015

1015

1100
1030
6/13/79   1335
6/14/79   1030
1030
0920
6/14/79   1145
6/15/79   0930
The following samples were


 Parameters

 Quality control blanks
 for non-volatile organics,
 metaljB, mercury

 Non-volatile organics,
 metals, mercury, COD, TSS

 VOA,  phenol, cyanide

 Non-volatile organics, metals,
 mercury,  COD, TSS

 VOA  |


 VOA,  phenol, cyanide

 Non-volatile organics,
 metals, mercury, COD, BODS,
 TSS

 VOA
          VOA, phenol, cyanide
Barometric Condenser Mix Basin  (BW-002I)  —  Art   ISCO  Model  1680
automatec  sampler  was  installed  in  the mix basin and collected
the following samples:
                               0-34

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SAD Sample No
79C-1511

79C-1512

79C-1513
79C-1514

Sample sent to
contract lab
79C-1515
79C-1517
Sample sent to
contract lab
79C-1517
Date
6/12/79
6/12/79
6/13/79
Time
1145
1215
1100
6/13/79   1100
6/13/79
6/14/79
1115
1000
6/13/79   1320
6/14/79
6/14/79
6/15/79
1000
1000
0900
6/14/79   1140
6/15/79
0900
Parameters
Quality control blanks
for non-volatile organics,
metals, mercury
Non-volatile organics,
metals, mercury, COD,TSS
VGA, phenols, cyanide
Non-volatile organics,
metals, mercury, COD, TSS
VGA
VOA, phenol, cyanide
Non-volatile organics,
metals, mercury, COD, BOD5_
TSS
VOA
VOA, phenol, cyanide
Raw Water Sample (BS-RW) — A grab sample was collected from  the
City  of  Greenville  water  supply  from a tap in the wastewater
treatment plant laboratory.
SAD Sample No
79C-1503
Date
6/12/79
Time
1430
Parameters
Non-volatile organics,*
metals, mercury, phenol,
VOA,* cyanide
*The VOA and non-volatile organics samples were  shipped  to  the
contract lab; the metals, COD, BOD5_ and TSS samples were taken to
the Revion IV, US-EPA Laboratory, Athens, Georgia.
22.  Plant 12420
Screening Samples
Plant 12420 is a subcategory B, D plant.  The wastewater flow  of
0.17  MGD  from  this  plant  is pretreated with an aeration pond
followed by a secondary clarifier, then discharged to  a  private
wastewater treatment facility.
                               0-35

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The  sample  points  and  pollutants  analyzed  for are tabulated
below.                                     !
                                VOA   Pest.   Base Neut.
                                		Acid

Effluent to pretreatment plant   x       x          x           x
Effluent from Sec. clarifier     x       x  ,        x           x
Effluent at manhole              x       x          x           x
Intake water                     x       x          x           x

23.  Plant 12439

Screening Samples

Plant 12439 is a C and D subcategories plant.  A flow of  0.01 MGD
is reported for this plant/even though this plant  is  classified
as  a zero discharger.  This flow arises from wastewater  which is
discharged  to  an  irrigation   system   after    neutralization,
settling, activated sludge, and lagooning.
                                           \
Two  sampling  points  were  used during the screening visit: the
industrial stream influent and the secondary clarifier  effluent.
The secondary clarifier effluent contains treated  wastewater  from
the  industrial  stream  influent and sanitary wastewater.  These
two streams were sampled for priority and traditional pollutants.

24.  Plant 12447                           ;

Screening Samples

Plant 12447 is an A,  B,  C,  and  D  subcategories  plant  which
discharges   1.5   MGD   of   wastewater.  ; This   plant   produces
non-pharmaceuticals.  Wastewater is dischariged without  treatment
to a POTW except for some very concentrated; wastes which  are  deep
welled.
                                           i,    ,  „,   ,, ,          ,
The  following  table  lists dates, times, and parameters sampled
for at the various sampling sites.         I
                               0-36

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0-

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Co,

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8/9/78



8/9/78

8/9/78

8/9/78
1105
1450
1437

1437

1437
25.  Plant 12462
     A 3-grab composite for
     extractable organics,
     metals, BOD, and COD

     Grab for VOA

     Grab for phenol

     Grab for cyanide
     pH and temperature
     measured 6.5 and 21°C

     Organic free water used
     in field to pump through
     samplers for sampler blanks.
     Also used direct for reagent
     blanks for phenol and cyanide
     and as VOA trip blanks
Plant 12462 is a Subcategory  A  plant  which  discharges  to  an
aerated   lagoon   0.3   MGD   from  pharmaceutical  manufacture.
Non-pharmaceutical products are also produced at this plant.

Six sample sites were selected during the screening visit.   Grab
samples  were  taken  from  the  intake water and backwash lagoon
discharge.  Composite samples were obtained of the  phamaceutical
manufacturing  influent  to the aerated lagoon the total influent
to the aerated lagoon, the effluent from the final clarifier, and
the final plant effluent.  Pollutants analyzed  for  include  the
traditional pollutants and priority pollutants.

The  table shown below gives a breakdown of the samples taken and
pollutants sampled for:

                        Screening Samples
9/19/77
9/20/77

9/20/77
Time

1510

0850
1200

1240
                           Flow
                         (gallons)
29,400
Parameters

Organics (sampler blank)

Priority pollutants, BOD,
pH, COD, NFS, nutrients

Volatile organics,
phenolics,  cyanide
                               0-39

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 Combined influent to aerated lagoon

 Date           Time      Temp °C
 9/20/77
 9/21/77

 9/21/77
1230
1025

1025
30
            Parameters
                i
            Priority pollutants/ pH,
            BOD, COD, NFS, nutrients
Volatile organics,
phenolics, cyanide
Biological  waste treatment system effluent
 9/19/77         1540

 9/19/77         1550
 9/20/77         11 45

 9/20/77         1230
9/20/77         1200
9/21/77         1020

9/21/77         1020


9/21/77         1200




Plant outfall

Date            Time

9/1 9/77         1 545

9/19/77         1600
9/20/77         1150

9/20/77         1230


9/21/77         1015




26.  Plant 12999
             21


             21
          Temp
            25
                         Organics (sample blank)

                         Priority pollutants, pH,
                         BOD5, COD,  NFS, nutrients

                         volatile organics,
                         phenolics,  cyanide
            Priority pollutants, Ph,
            BOD5_,;  COD,  NFS, nutrients

            Volatile organics,
            phenolics,  cyanide

            Priority pollutants, pH,
            BOD5,  COD,  NFS, Nutrients,
            phenolics,  volatile organics,
            cyanide
            Parameters
                I
            Organics (sampler blank)

            Priority pollutants,  pH
            BOD5_,  COD,  NFS,  nutrients
                i
            Volatile organics,
            phenolics,  cyanide

            Priority pollutants,  pH,
            BOD5_,  COD,  NFS,  Nutrients
            volatile organics,
            phenolics,  cyanide
                               0-40

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Screening Samples

Plant 12999 is a subcategories C and  D  plant  which  discharges
0.45 MGD of wastewater to a municipal treatment plant.

The  Plant 12999 wastewater treatment facility currently consists
of a primary clarifier and an equalization  pond.   However,  the
plant is performing bench scale treatability studies to determine
the  effectiveness  of  activated  sludge  and powdered activated
carbon on its wastewater.  The activated  sludge  unit  effluents
and  the powdered activated carbon unit effluents were two of the
sample points during the screening visit.  The other  two  sample
points  were  the raw waste feed to the bench scale units and the
equalization pond effluent which is discharged to the POTW.   The
parameters  sampled  for  were  the  traditional  pollutants  and
priority pollutants.
                              0-41

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               APPENDIX P



English Units to Metric Units Conversion Table

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L   ,,,	

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                              APPENDIX  P



          ENGLISH UNITS TO METRIC UNITS CONVERSION  TABLE
Multiply (English Units)
English Unit
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
By To Obtain (Metric Units)
Conversion Metric Unit
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
ha
cu m
kg cal
kg cal/
kg
cu m/
min
cu m/
min
cu m
1
cu cm
°c
m
1
I/sec
atm
hectares
cubic meters
Kilogram-
calories
kilogram
calories per
kilogram
cubic meters
per minute
cubic meters
per minute
cubic meters
liters
cubic centi-
meters
degree Centi
grade
meters
liter
liters per
second
atmospheres
(absolute)
* Actual conversion,  not a  multiplier
                                   P-l
                                              *U.S. G07EHSMENT PRINTING OFFICE : 1982 0-381-085/4484-

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