Development Document for Effluent Limitations Guidelines and Standards for the Pharmaceutical Point Source Category, Proposed November 1982

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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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. ------- 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 . ------- 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. ------- (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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- discussion of this selection process in light of the criteria for exclusion in paragraph 8 of the Consent Agreement. 26 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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^rat* "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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- FIGURE m-1 PHARMACEUTICAL INDUSTRY GEOGRAPHICAL DISTRIBUTION HAWAII 44- • PUERTO RICO -«2 VIRGIN ISLANDS ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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* ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- FLOAT- CONTROL VALVE EFFLUENT[ FIGURE VII-9 FILTRATION UNIT 155 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- (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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- ^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<=iuf 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- \ 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- >• 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 ------- 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 ------- 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 ------- 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 ($) 1,044,000 275,000 1,243,000 156,000 203,000 1,539,000 715,000 89,000 387,000 171,000 5,822,000 BCT Removal (Ibs 581,000 455,000 5,407,000 39,000 54,000 6,747,000 845,000 7,000 1,080,000 22,000 16,237,000 265 ------- Plant TABLE XI-3 BCT Cost Test Criteria 12022 12026 12038 12098 12160 12187 12236 12239 12462 20257 AC C ABCD D D C C C A C Subcateqorv(s) BCT Cost ($/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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- ------- APPENDIX A Glossary ------- ------- 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 ------- 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 ------- 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. ------- 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. : ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- APPENDIX B 308 Portfolio for Pharmaceutical Manufacturing ------- ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- ". 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 ------- 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 Huttbr 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 ------- APPENDIX C Pharmaceutical Manufacturing Plants in the Original 308 Data Base ------- ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- r APPENDIX D Supplemental 308 Portfolio for the Pharmaceutical Manufacturing Industry ------- ------- 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 ------- 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 ------- 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 ------- 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 * CUXClFlLd. rl I i. i _ i i i * ^> 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.rmcn 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. r7ETEJTlO\|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^HIJ ------- 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 StHARY 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»olcl 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»iolQ9icl 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^fS,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 SUtARY 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;etj 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 \|;ed 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 / Cati(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 SlfIARY 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 IAI 'MM.- f ® >T V_J IF V* ill i i — i i .-.* s?£ - i» H — -«- ji.u. O 1 s* n'S' ' '' \ * I CM 11 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 ------- 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 ------- 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 ------- 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 ------- •, .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 ------- 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 ------- 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 ------- 0- ------- Co, ------- 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 ------- 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 ------- 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 ------- ------- APPENDIX P English Units to Metric Units Conversion Table ------- L ,,, ------- 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- ------- -------


        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

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   2
   3

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  25

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  68

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  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


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 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.

-------
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.

-------
      (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

-------
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

-------
 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

-------
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

-------
 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

-------
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

-------
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

-------
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

-------
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

-------
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

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

-------
                                 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

-------
                           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

-------
                                       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

-------
                              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

-------
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

-------
 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

-------
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

-------
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

-------
 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

-------
 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

-------
                           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

-------
                           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

-------
                           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

-------
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

-------
                        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

-------
 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

-------
                        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

-------
                        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

-------
 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

-------
                           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

-------
                          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

-------
                          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

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

-------
                           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

-------
 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

-------
                            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

-------
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

-------
 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

-------
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

-------
 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

-------
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

-------
 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

-------
           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

-------
 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

-------
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

-------
 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

-------
                                                             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

-------
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

-------
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

-------
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

-------
                           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

-------
                                                         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

-------
 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

-------
 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

-------
                                   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

-------
                               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

-------
                      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

-------
                            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

-------
(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

-------
 (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

-------
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

-------
                           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

-------
 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

-------
 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

-------
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

-------
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

-------
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*

-------
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

-------
     (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

-------
 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

-------
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

-------
  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

-------
                           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

-------
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
-------
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

61
41
37
11
3

51
1
2
9
23
9
1
1

3
5

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

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
-------
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
-------
FLOAT-
CONTROL
VALVE

EFFLUENT[
FIGURE VII-9

FILTRATION UNIT
155
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
(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.
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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.
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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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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'

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
-------
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
-------
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
-------
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
-------
^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
-------
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
-------
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
-------
(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
-------
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
-------
\
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
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
(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
-------
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*
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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.
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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
-------
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
-------
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
-------
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
-------
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
-------
1.

3.
5.

10.

11.

12.

13.

14.
SECTION XV

REFERENCES
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280
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15. Burns and Roe submittal to the U.S. EPA, "Summary Report
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16. Burns and Roe submittal to the U.S. EPA, "Summary Report
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282
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I
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286
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287
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
-------
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
-------
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
-------
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.
-------
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. :
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
APPENDIX B

308 Portfolio for Pharmaceutical Manufacturing
-------
-------
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
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
-------
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
-------
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
-------
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

-------
                                                      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

-------
                                                       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

-------
                                                      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

-------
                                                      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

-------
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

-------
". 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)

;
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

-------
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
-------
              APPENDIX C

Pharmaceutical Manufacturing Plants in the
         Original 308 Data Base
-------
-------
                           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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
r
                                          APPENDIX D

                                 Supplemental 308 Portfolio for the
                               Pharmaceutical Manufacturing Industry
-------
-------
                          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
-------
  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
-------
                                                                                        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
-------
                                                                                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
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— .

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
-------
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
-------
 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
-------
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
-------
                                                                •,	.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
-------
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
-------
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
-------
0-
-------
Co,
-------
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
-------
 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
-------
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
-------
-------
               APPENDIX P



English Units to Metric Units Conversion Table
-------
L   ,,,	
-------
                              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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