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EFFLUENTI
WATER
LEVEL.
STORED
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WATER
INFLUENT
ALUM
POLYMER
THREE WAY VALVE
DRAIN
FIGURE VIM4. GRANULAR BED FILTRATION
828 .
-------
PERFORATED
BACKING PLATE,
FABRIC
FILTER MEDIUM
SOLID
RECTANGULAR
END PLATE -
r
r
r
Afl=
INLET
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• FABRIC
FILTER MEDIUM
.ENTRAPPED SOLIDS
PLATES AND FRAMES ARE
FILTRATION CYCLE
N
RECTANGULAR
METAL PLATE
FILTERED LIQUID OUTLET
J^^
RECTANGULAR FRAME
FIGURE VII-15. PRESSURE FILTRATION
829
-------
SEDIMENTATION BASIN
INLET ZONE
BAFFLES TO MAINTAIN
QUIESCENT CONDITIONS
OUTLET ZONE
INLET LIQUID
. T*"5-.^ * . SETTLING PARTIfLf
• ^^"**»i^:« TRAJECTORY . «
• • • • • fT*.*- • - _ I
OUTLET LIQUID
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BELT-TYPE SOLIDS COLLECTION
MECHANISM
SETTLED PARTICLES COLLECTED
AND PERIODICALLY REMOVED
CIRCULAR CLARIFIER
SETTLING ZONE.
INLET LIQUID / CIRCUI-AR BAFFLE
I/ , ANNULAR OVERFLOW WEIR
.
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• « . V* • •
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OUTLET LIQUID
•SETTLING PARTICLES
REVOLVING COLLECTION
MECHANISM
I
SETTLED PARTICLES
COLLECTED AND PERIODICALLY
REMOVED
SLUDGE DRAWOFF
FIGURE VIM6. REPRESENTATIVE TYPES OF SEDIMENTATION
830:
-------
FLANGE
WASTE WATER
WASH WATER
SURFACE WASH
MANIFOLD
BACKWASH
INFLUENT
DISTRIBUTOR
BACKWASH
REPLACEMENT CARBON
CARSON REMOVAL PORT
TREATED WATER
SUPPORT PLATE
FIGURE VIM7. ACTIVATED CARBON ADSORPTION COLUMN
831
-------
CONVEYOR DRIVE
IOWL DRIVE
LIQUID
OUTLET
SLUDGE
INLET
CYCLOGEAR
SLUDGE
DISCHARGE
BOWL
REGULATING
RING
IMPELLER
FIGURE VII-18. CENTRIFUGATION
832
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CONTROLS
OZONE
GENERATOR
ifl
DRY AIR
D
J Jl II
OZONE
REACTION
TANK
.. ., TREATED
-{XI——*
WASTE
X
RAW WASTE-
FIGURE VII-20. TYPICAL OZONE PLANT FOR WASTE TREATMENT
834
-------
MIXER
WASTEWATER
FEED TANK
TREATED WATER
EXHAUST
GAS
TEMPERATURE
CONTROL
PH MONITORING
TEMPERATURE
CONTROL
PH MONITORING
TEMPERATURE
CONTROL
PH MONITORING
OZONE
OZONE
GENERATOR
FIGURE Vll-21. UV/OZONAT10N
835
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o
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836
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OILY WATER
INFLUENT
WATER
DISCHARGE
OVERFLOW
SHUTOFF
VALVE
EXCESS
AIR OUT
LEVEL
CONTROLLER
TO SLUDGE
TANK •*
FIGURE VII-23. DISSOLVED AIR FLOTATION
837
-------
CONDUIT
TO MOTOR
INFLUENT
CONDUIT TO
OVERLOAD
ALARM
EFFLUENT PIPE
EFFLUENT CHANNEL
PLAN
INFLUENT
TURNTABLE
BASE
HANDRAIL
CENTER COLUMN
— CENTER CAGE
STILTS
CENTER SCRAPER
WEIR
SQUEEGEE
SLUDGE PIPE
FIGURE VII-24. GRAVITY THICKENING
838
-------
WASTE WATER CONTAINING
DISSOLVED METALS OR
OTHER IONS
DIVERTER VALVE
REGENERANT
SOLUTION
DISTRIBUTOR
SUPPORT
yREGENERANT TO REUSE,
7 TREATMENT. OR DISPOSAL
-DIVERTER VALVE
METAL-FREE WATER
FOR REUSE OR DISCHARGE
FIGURE VII-25. ION EXCHANGE WITH REGENERATION
839
-------
MACROMOLECULES
AND SOLIDS
MEMBRANE
Ap « 4SO PSI
*
WATER
PERMEATE (WATER)
-MEMBRANE CROSS SECTION.
IN TUBULAR, HOLLOW FIBER.
OR SPIRAL-WOUND CONFIGURATION
FEED-
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o 0*0
9 i '
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00. O
CONCENTRATE
(SALTS)
O SALTS OR SOLIDS
• WATER MOLECULES
FIGURE VII-26. SIMPLIFIED REVERSE OSMOSIS SCHEMATIC
840
-------
PERMEATE
TUBE
ADHESIVE BOUND
SPIRAL MODULE
FLOW
CONCENTRATE
BACKING MATERIAL
•MESH SPACER
•MEMBRANE
SPIRAL MEMBRANE MODULE
POROUS SUPPORT TUBE
WITH MEMBRANE
• 4 •
•:•:.——
.••* BRACKISH
* WATER
FEED FLOW
PRODUCT WATER
PERMEATE FLOW
BRINE
CONCENTRATE
FLOW
PRODUCT WATER
TUBULAR REVERSE OSMOSIS MODULE
OPEN ENDS
OF FIBERS
SNAP
RING
"O" RING
SEAL
,— EPOXY
TUBE SHEET
POROUS
BACK-UP DISC
SNAP
RING
CONCENTRATE
OUTLET
END PLATE
POROUS FEED
DISTRIBUTOR TUBE—'
PERMEATE
END PLATE
HOLLOW FIBER MODULE
FIGURE Vll-27. REVERSE OSMOSIS MEMBRANE CONFIGURATIONS
841
-------
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SECTION A-A
FIGURE VII-28. SLUDGE DRYING BED
842
-------
ULTRAFILTRATION
p. 10-50 FSI
MEMBRANE
*
WATER SALTS
-MEMBRANE
PERMEATE
• I
FEED 0
• • •
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0. . . .
•o»-.o
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o • V
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• DISSOLVED SALTS AND LOW-MOLECULAR-WEIGHT ORGANICS
FIGURE VII-29. SIMPLIFIED ULTRAFILTRATION FLOW SCHEMATIC
843
-------
II
FABRIC OR WIRE
FILTER MEDIA
STRETCHED OVER
REVOLVING DRUM
ROLLER
DIRECTION OF ROTATION
SOLIDS SCRAPED
OFF FILTER MEDIA
VACUUM
SOURCE
STEEL
CYLINDRICAL
FRAME
LIQUID FORCE
THROUGH
MEDIA BY
MEANS OF
VACUUM \
\
SOLIDS COLLECTION
HOPPER
INLET LIQUID
TO BE
FILTERED
FILTERED LIQUID
FIGURE VII-30. VACUUM FILTRATION
844
-------
w
c£
£
ai
SS
o
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ul
LU O
845
-------
(a)
30-40 in—*
UNDERDRA1N
CHAMBER —I
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TROUGH
INFLUENT
1. ..
™KP
•.'•.•.•.•COARSE
EFFLUENT
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DEPTH
EFFLUENT
t
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UNOERORAIN
CHAMBER—1
CHAMBER —*
INFLUENT
(d)
COARSE MEDIA-
INTERMIX ZONE-
FINER MEDIA —
FINEST MEDIA-
•ANTHRACITE
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T
30-
i
30-40in
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FINER MEDIA-
FINEST MEDIA-
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28-48 in
UNDERDRAW
CHAMBER —I
EFFLUENT
UNOERORAIN
CHAMBER —1
^•GARNET SAND
EFFLUENT
Figure VII-32
FILTER CONFIGURATIONS
(a) Single-Media Conventional Filter.
Cb) Single-Media Upflow Filter.
(c) Single-Media Biflow Filter.
(d) Dual-Media Filter.
(e) Mixed-Media (Triple-
Media) Filter.
846
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849
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EVAPORATION
CONTACT COOLING
WATER
COOLING
TOWER
SLOWDOWN
DISCHARGE
RECYCLED FLOW
MAKE-UP WATER
Figure VII-36
FLOW DIAGRAM FOR RECYCLING'WITH A COOLING TOWER
850
-------
OUTGOING WATER
WORK MOVEMENT
INCOMING WATER
DOUBLE COUN"
RINSE
-•*-> f-*--
li-itf
r ' * r
*J
TERFLOW
WORK
+ - A~ •*•""*" MOVEMENT
1 |j-~ INCOMING WATER
* 1 i —
T7TT
OUTGOING WATER*3 '
b
TRIPLE COUN
RINS
> J V *__^__ J
0
i
OUTGOING WATER
TERFLOW
,E
WORK MOVEMENT
1 *=* INCOMING
s- i f r~ WATER
sfl ^T~
Figure VII-37
COUNTER CURRENT RINSING (TANKS)
851
-------
1000
Rinse Stages
Figure VII-38
EFFECT OF ADDED RINSE STAGES ON WATER USE
852
-------
05
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853
-------
-------
SECTION VIII
COST OF WASTEWATER TREATMENT AND CONTROL
This section presents estimates of the costs of implementing the
major wastewater treatment and control technologies described in
Section VII. These cost estimates, together with the estimated
pollutant reduction performance for each treatment and control
option presented in Sections IX, X, XI, and XII, provide a basis
for evaluating the options presented and identification of the
best practicable technology currently available (BPT), best
available technology economically achievable (BAT), best demon-
strated technology (BDT), and the appropriate technology for pre-
treatment. The cost estimates also provide the basis for deter-
mining the probable economic impact on the aluminum forming cate-
gory of regulation at different pollutant discharge levels. In
addition, this section addresses nonwater quality environmental
impacts of wastewater treatment and control alternatives, includ-
ing air pollution, solid wastes, and energy requirements.
GENERAL APPROACH
Capital and annual costs associated with compliance with the
aluminum forming regulation have been calculated on a plant-by-
plant basis for 124 plants and extrapolated for the remainder
(seven plants) in the aluminum forming category that discharge
wastewater. These costs have been used as the basis for economic
impact analysis of the category. Prior to proposal, costs were
generated for 104 aluminum forming plants using the pre-proposal
cost estimation methodology described below. After proposal, 26
additional plants were costed and added to the total; six plants
were removed because of closure or because the plants no longer
discharge wastewater; and 12 plants were recosted because of a
methodological error that substantially overstated the cost to
small plants. A total of 124 plants were costed for the final
rulemaking. Costs estimated before proposal were made by the
pre-proposal contractor (Contractor A) and the post-proposal
costs estimated by the post-proposal contractor (Contractor B).
Cost methodologies of the two contractors were compared by
costing the identical plants and found to compare favorably.
Prior to estimating any new costs after proposal, a comparison of
costs generated by the pre-proposal and post-proposal methodolo-
gies was performed. A study previously done in 1982, in which
wastewater treatment system costs were estimated for 10 porcelain
enameling plants was used to compare the pre-proposal and post-
proposal cost methodologies. The results of this study showed
that the costs generated by the two methodologies agreed well.
The sum of the total capital costs estimated for the 10 plants by
the post-proposal methodology was 5.5.percent higher than those
855
-------
obtained from the pre-proposal methodology. The average of the
?0S? n^n?rCe™ deviations between the costs for each plant was
i£;i P TS ? 'corresponding figures for the annual costs
costs bl^d nSSfh and -17'] P^cent, respectively (the annual
costs based on the pre-proposal methodology are higher) These
results indicate that costs generated by the two cost methodolo-
gies are comparable, considering the accuracy of cost estimation
The principal cost factor differences between the pre-proposai
and post-proposal costs are tabulated in Table VIII-1
«i-ln J98£\a 10-Plant cost study (using the same porcelain
enameling plants) was performed simultaneously by three separate
contractors and compared with actual industry costs for five of
the plants. The cost methodologies of all three contractors were
within +20 percent of the mean for each plant and the mean cost
was within ±20 percent of the i estimated industry costSon the
five plants. The pre-proposal contractor was one of the threJ
contractors that participated in the study. As discussed abovl
*nS P?st~Proposal contractor also estimated the same 10 plants
and had capital costs about 5 percent above the pre-proposal
ro£n^2°r^°StS; • Addj,tionaHy' °ne Of the three contactors'
compared the estimated compliance costs for 80 steel plants with
actual costs incurred by the companies and found the model costs
to overestimate actual costs by about 10 percent. The costs
actually incurred included siteHspecif ic costs such as line
segregation, area rehabilitation, and retrofit of equipment. All
farX?2M£? A Tre S601"3^ comPe"sated by the cost estimating
factors included in the methodology.
™ JL rK?UlJ °f fc£iS comParison, the Agency concluded that it was
reasonable to perform post-proposal costing efforts using the new
cost methodology and to combine these new costs with those gener-
ated prior to proposal. .
COST ESTIMATION METHODOLOGY; PRE-PROPOSAL
Sources of_ Cost Data
i,- C°St data for the selected treatment processes
were collected from four sources: (!) literature, (2) data col-
lection portfolios, (3) equipment manufacturers, and (4) in-house
nb?*?n^Pf°JeC^; ?e ma^ty i of the cost information wK
citSd Jbf^n^ ^Jerature sources. ! Many of the literature sources
cited obtained their costs from surveys of actual design proi-
^'^J°r e^amPler Black & Veatch prepared a cost manual that
aJ a SiS /nd const^u^ion cost data from 76 separate projects
as a basis for establishing average construction costs. Data
collection portfolios completed by companies in the aluminum
forming category contained a limited amount of chemical and unit
process cost information. Most of the dcp's did not include
856
-------
treatment plant capital or information was annual cost
information, and reported for the entire treatment plant.
Therefore, little data from the data collection portfolios was
applicable for the determination of individual unit process
costs. Additional data was obtained from equipment manufacturers
and design projects performed by Sverdrup & Parcel and
Associates.
Determination of Costs
To determine capital and annual costs for the selected treatment
technologies, cost data from all sources were plotted on a graph
of capital or annual costs versus a design parameter (usually
flow). These data were usually spread over a range of flows.
Unit process cost data gathered from all sources include a vari-
ety of auxiliary equipment, basic construction materials, and
geographical locations. A single line was fitted to the data
points thus arriving at a final cost curve closely representing
an average of all the cost references for a unit process. Since
the cost estimates presented in this section must be applicable
to treatment needs in varying circumstances and geographic loca-
tions, this approach was felt to be the best for determining
national treatment costs. For consistency in determining costs,
accuracy in reading the final cost curves, and in order to pre-
sent all cost relationships concisely, equations were developed
to represent the final cost curves. The cost curves are
presented in Figures VIII-1 through VIII-30, capital and annual
cost equations are listed in Table VII1-2.
All cost information was standardized by backdating or updating
the costs to first quarter 1978. Two indices were used: (1) EPA
- Standard Treatment Plant index and (2) EPA - Large City
Advanced Treatment (LCAT) index. The national average, rather
than an index value for a particular city, was used for the EPA-
LCAT index. The national average was used because the regional
differential of the supporting cost data was dampened by averag-
ing the cost data.
857
-------
Capital. All capital cost equations include:
(!) Major and auxiliary equipment
(2) Piping and pumping
(3) Shipping
(4) Sitework
(5) Installation
(6) Contractors' fees i
(7) Electrical and instrumentation
(8) Enclosure \
(9) Yard piping !
(10) Engineering <
(11) Contingency
Items (1) through (7) are included to the extent that they are
provided for in each source in the literature. In cases where a
certain item(s) is missing, an estimate is made in order to aver-
age the cost values. Enclosure costs are estimated separately
and are included only for those technologies' performances deemed
subject to weather conditions. Contingencies and engineering are
assumed to be 15 and 10 percent, respectively, of the installed
equipment cost. Yard piping is estimated at 10 percent of the
installed equipment cost.
The cost of land has not been considered in the cost estimates.
Based on engineering visits at 22 aluminum forming plants, it is
believed that most wastewater treatment and supporting facilities
can be constructed in existing buildings or on land currently
owned by the plants. Also, the plant wastewater flows in the
aluminum forming category are low (majority of plants less than
50,000 gpd); thus, land requirements for treatment facilities are
small for most plants. ,
For new plants, the amount of land necessary to house the waste-
water treatment system is assumed to be insignificant relative to
other capital costs. This is particularly true since the plant
design would optimize the space available.
The non-water quality aspects associated with capital costs
include sludge handling for precipitation and skimming systems
generating large quantities of sludge. Capital investment is
required only for systems generating greater than 140,000 gallons
per year in order to dewater the sludge prior to hauling. This
is based on economic assessment of the break point for sludge
hauling and landfilling. The 14p,000 gallon per year volume is
the volume at which contract hauling at a cost of thirty cents
per gallon (discussed later in this section) would equal the
investment costs for a vacuum filtration system. Investment
includes costs for vacuum filtration and holding tanks. See the
cost calculation example for further detail.
858
-------
Annual. All annual cost equations include:
Operation and maintenance labor
Operation and maintenance materials
Energy
Chemicals
Operation and maintenance labor requirements for each unit pro-
cess were recorded from all data sources in terms of manhours per
year. A labor rate of 20 dollars per manhour, including fringe
benefits and plant overhead, was used to convert the manhour
requirements into an annual cost.
Operation and maintenance material costs account for the replace-
ment, repair, and routine maintenance of all equipment associated
with each unit process. Material costs were developed solely
from data reported in the literature.
Electrical energy requirements for process equipment were tabu-
lated in terms of kilowatt-hours per year. The cost of electric-
ity used is 4.0 cents per kilowatt-hour, based on the average
value of electricity costs as reported in the aluminum forming
category data collection portfolios. Fuel oil and natural gas
costs used were also obtained from the data collection portfol-
ios. The average fuel oil cost was 26 cents per therm and the
average natural gas cost was 22 cents per therm.
Chemicals used in the treatment processes presented in this sec-
tion are sulfuric acid and caustic for pH adjustment, hydrated
lime for heavy metals precipitation, sulfur dioxide for hexaval-
ent chromium reduction, and alum and polymer for emulsion break-
ing.
Although not included in the annual cost equations, amortization,
depreciation, and sludge disposal are considered in the plant-by-
plant cost analysis. See the example which follows in this
section.
Capital costs are amortized over a 10-year period at 12 percent
interest. The corresponding capital recovery factor is 0.177.
The annual cost of depreciation was calculated on a straight line
basis over a 10-year period. The costing methodology resulted in
double-counting the value for depreciation. The annual cost
estimates were corrected by subtracting 10 percent of the capital
cost from the annual cost.
Many of the unit processes chosen as treatment technologies pro-
duce a residue or sludge that must be discarded. Sludge disposal
costs presented in this section are based on charges made by
private contractors for sludge hauling services. Costs for haul-
859
-------
ing vary with a number of factors including quantity of sludge to
be hauled, distance to disposal sitp, disposal method used by the
contractor, and variation in landfill policy from state to state.
Costs for contractor hauling of sludges are based on data col-
lected in the development of effluent guidelines for the paint
industry in which 511 plants reported contractor hauling
information. ;
A cost of 30 cents per gallon was used for the paint guideline
development as a sludge hauling and landfill ing cost and is used
in this report. This value is conservative since many sludgers
hauled in the paint industry are considered hazardous wastes and
require more expensive landfilling facilities relative to
landfill facilities required for nonhazardous wastes.
Cost Data Reliability ,- • • '
To check the validity of the capital cost data, the capital costs
developed for this category were, compared to capital costs
reported in the data collection portfolios. As stated earlier,
the cost information reported in the data collection portfolios
was for treatment systems rather |than individual unit processes
and therefore was not used to develpp costs for existing treat-
ment facilities in the aluminum forming category.
Nineteen plants reported treatment system capital cost informa-
tion. The total reported capital cost for all 19 facilities is
equal to $3,600,000. The sum of the cost estimates developed
with the costing methodology described herein for the same 19.
treatment systems is equal to $4,300,000. Although variations at
individual plants were occasionally much greater, the overall
difference of capital costs was 19 percent. Detailed design
parameters (i.e., retention times, chemical dosages, etc.) for
the data collection portfolio treatment systems were seldom
reported. Therefore, the costs : developed in this section are
based on one set of design parameters which may differ from the
design parameters actually used at the 19 plants which reported
cost information. This could result in large variances at indi-
vidual facilities, but the effect of the possible design differ-
ences is dampened when a large number of facilities are consid-
ered as is indicated by the 19 percent difference in costs for
the 19 treatment systems studied.
Treatment Technologies and Related ICosts
Costs have been determined for the following wastewater treatment
and sludge disposal technologies to be used in the various treat-
ment alternatives: ,
- Skimming ;
860 ;
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items which
Chemical emulsion breaking
Dissolved air flotation ;
Thermal emulsion breaking
Multimedia filtration
pH adjustment
- Lime and settle (L&S)
- Hexavalent chromium reduction
- Cyanide oxidation
Cyanide precipitation
- Activated carbon adsorption
Vacuum filtration
Contractor hauling
- Countercurrent cascade rinsing
- Regeneration of chemical baths
Costs have also been determined for the following
relate to the operation of a treatment plant:
Flow equalization
- Pumping
Holding tank
Recycle
- Monitoring
A discussion of the design parameters used and major and auxili-
ary equipment associated with each treatment technology and
related items is contained below.
Skimming. Skimming is included as a wastewater treatment option
to remove free oils commonly found in aluminum forming plants.
The equipment used as the basis for developing capital and annual
costs for skimming are as follows:
Gravity separation basin
- Oil skimmer
- Bottom sludge scraper
It is assumed that the oil to be removed has a specific gravity
of 0.85 and a temperature of 20°C. Sludge quantities, in terms
of gallons of sludge per 1,000 gallons of wastewater generated,
are tabulated in Table VIII-3, based on sampling data. The basis
for energy requirements is the use of a 1/2-HP motor for skimming
based on TOO gal/hr of oil. Figure VIII-4 presents capital and
annual costs of oil skimming.
Chemical Emulsion Breaking. Alum and polymer addition to
wastewater aids in the separation of oil from water, as discussed
in Section VII (p. 736). To determine the capital and annual
costs, 400 mg/1 of alum and 10 mg/1 of polymer are assumed to be
added to waste streams containing such emulsified oils as spent
861
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rolling emulsions. The equipment
annual costs are as follows: '
- Chemical feed system
included in the capital and
1. Storage units
2. Dilution tanks ,
3. Conveyors and chemical feed lines
4. Chemical feed pumps
- Rapid mix tank (detention time, 5 minutes)
1. Tank
2. Mixer ;
3. Motor drive unit
- Skimming
1. Gravity separation basin
2. Surface skimmer
3. Bottom sludge scraper
Costs were derived based on a composite of various systems which
included the above equipment. Alum and polymer costs were
obtained from vendors: dry alum at $0.15 per pound and polymer
at $3.00 per pound. Energy requirements were also composited
from various literature sources to be included in the annual
costs. Capital and annual costs for chemical emulsion breaking
are presented in Figure VII1-5.
Dissolved Air Flotation. Dissolved air flotation (DAF) can be
used by itself, in conjunction w,ith gravity separation for the
removal of free oil, or also in conjunction with coagulant and
flocculant addition to increase oil removal efficiency. The
capital and annual cost equations in Table VII1-2 provide" costs
only for the dissolved air flotation unit; other systems, such as
flocculant addition, may be added in separately.
The equipment used to develop capital and annual costs (Figure
VII1-6) for the DAF system is as follows:
- Flotation unit
- Surface skimmer
- Bottom sludge scraper
- Pressurization unit
- Recycle pump
- Electrical and instrumentation
- Concrete pad, 1 ft. thick
862
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a recycle ratio of 30 percent. All costs and energy requirements
were derived as composites of various sytems presented in the
literature. Energy requirements are estimated to range from
54,000 Kw-hr/yr at 30,000 GPD to 35,000,000 Kw-hr/yr at 10 MGD.
Below 30,000 GPD flowrate, energy requirements are considered to
be constant.
Thermal Emulsion Breaking. Thermal emulsion breaking is used to
treat spent emulsion wastes potentially yielding a salable oil
by-product. The system and its components which were costed for
this technology is described in detail in Section VII. Standard
"off the shelf" thermal emulsion breaking systems were costed.
The Agency believes that custom design to account for site-
specific requirements might significantly reduce the overall
cost'. A separate boiler was costed for heat supply to the unit.
Equipment sizing was based on continuous operation. Influent oil
concentration was assumed to be 5 percent and the effluent, 80
percent. For economic assessment purposes, a credit of $0.20 per
gallon of treated oil was assumed. Capital and annual costs of
thermal emulsion breaking are presented on Figure VII1-7.
In determining annual costs, the energy requirements were calcu-
lated using 1.5 pounds of steam per pound of water evaporated.
In practice, low-grade waste heat may be available to support the
thermal emulsion breaking process. To be conservative, however,
capital and annual costs include the boiler operation. The usage
of energy was found to range from 8,500 therms/year at 150 GPD to
680,000 therms/year at 12,000 GPD.
Multimedia Filtration. Multimedia, filtration is used as a
wastewater treatment polishing device to remove suspended solids
not removed in previous treatment processes. The filter beds
consist of graded layers of gravel, coarse anthracite coal, and
fine sand. The equipment used to determine capital and annual
costs (Figure VIII-8) are as follows:
- Filter tank and media
- Surface wash system
- Backwash system
- Valves
- Piping
- Controls
- Electrical system
The filters were sized based on a hydraulic loading rate of 4
gpm/ft2 and pumps were sized based oh a backwash rate of 16
gpm/ft2. All costs and energy requirements were derived as a
composite of a variety of literature sources and vendor contacts.
Energy requirements for the filtration operation are estimated to
range from 300 Kw-hr/yr at 1,000 GPD to 300,000 Kw-hr/yr at 10
863
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MGD. Energy requirements are constant between
10,000 GPD.
1,000 GPD and
Adjustment. The adjustment of pH is particularly important
for treatment of wastewater streams such as cleaning or etching
streams. Sulfuric acid and caustic are used as the chemical
agents for addition to the wastewater stream. The following
equipment are used in determining capital and annual costs:
- Chemical feed system ;
— Bulk storage tank
— Dry tank ;
~ Mixer !
— Flow regulator |
- Concrete tank (detention time, 15 minutes)
- Mixing equipment
- Instrumentation
- Sump pump
Operating costs are based on the following assumptions:
- Sulfuric acid dose rate of 0.5 pound per 1,000 gallons of
wastewater.
- Caustic dose rates of 0.5, 5, and 20 pounds per 1,000
gallons of wastewater.
- Caustic (NaOH) cost of $175 per ton for 50 percent
solution (Chemical Marketing Reporter).
- Sulfuric acid cost of $41 per ton for 63 percent
solution (Chemical Marketing Reporter).
Labor and energy costs were assumed to be equal for all alkali
and acid dose rates. Energy requirements on a system basis are
linear from 10,000 GPD to 500,000 GPD at 660 Kw-hr/yr and
increase to 14,000 Kw-hr/yr at 10 MGD.
Capital and annual costs for pH adjustment with acid are
presented on Figure VIII-9, pH adjustment with caustic are
presented on Figure VIII-10. >
and Settle (L&S) . Quicklime (CaO) or hydrated lime
[Ca(OH)2J can be used to precipitate heavy metals. Hydrated lime
is commonly used for wastewaters with low lime requirements since
864
-------
the use of slakers, required for quicklime usage, is practical
only for large-volume application of lime. Wastewater sampling
data were analyzed to determine lime dosage requirements and
sludge production for those waste streams in the aluminum forming
category that contain heavy metals .selected as pollutants. The
results of this analysis are tabulated in Table VII1-4. Due to
the low lime dosage requirements in this industry, hydrated lime
is used for costing.
The pH of waste streams treated with lime precipitation may
require readjustment before discharge. Sulfuric acid is used to
adjust the pH to an acceptable discharge level (pH 6 to 9).
Thus, hydrated lime, sulfuric acid storage and feed systems, and
a clarifier are included in the lime and settle capital and
annual costs. Optional treatment systems which have been costed
separately and which may be used in conjunction with the above
lime and settle systems are a polymer feed system and floccula-
tor.
The following equipment were included in the determination of
capital and annual costs (Figure VIII-11) based on 'continuous
operation:
- Lime feed system
— Storage units
— Dilution tanks
Feed pumps
- Acid neutralization system
— Storage units
— Mixer :
— Flow regulator
— Instrumentation
Other annual cost bases are as follows: .
- Lime dosage rates include 200 mg/1 and 2,000 mg/1.
- Hydrated lime cost of $35.75,per ton (Chemical Marketing
Reporter).
The lime dosage was selected based on raw wastewater characteris-
tics. Those waste streams with low contaminant levels required
200 mg/1 of lime. Those with higher contaminant levels required
2,000 mg/1. The lime dosages used for each waste stream are
summarized in Table VIII-4.
865
-------
Cost equations are presented for both of the above lime dosage
rates. All cost equations and energy requirements for lime and
settle were based on composited values of various systems.
Energy requirements which were found to vary with flowrate are
estimated to range from 2,000 Kw-hr/yr at 1 GPM to 225,000 Kw-
hr/yr at 10,000 GPM.
i
Hexavalent Chromium Reduction. Chromium present in aluminum
forming wastewaters is considered to be in the hexavalent state.
The addition of sulfur dioxide at low pH values reduces hexaval-
ent chromium to trivalent chromium, which forms a precipitate.
The equipment included in the capital and annual costs are as
follows:
Reaction vessel (detention time, 45 minutes) .,
- Sulfuric acid storage and feed system
- Sulfonator !
- Oxidation reduction potential meter
Associated pressure regulator and appurtenances
This system has been costed both on a continuous and batch basis.
The composite-based capital cost equations presented in Table
VIII-2 include batch operation for flows greater than 0.2 gpm and
less than 20 gpm. Above 20 gpm, the system is continuous.
Capital and annual costs for chromium reduction are presented on
Figure VIII-12.
Operation and maintenance costs include labor, chemicals, and
repair parts. The labor rate used is $20.00 per manhour; it is
estimated that supply and labor costs contribute equally to the
O&M cost.
Energy requirements include electricity for pumps, mixers, and
monitors. The combined energy requirement for this equipment was
determined to be constant over the range of flowrates at 9,480
Kw-hr/yr. !
Cyanide Oxidation. In this technology, cyanide is destroyed by
reaction with sodium hypochlorite under alkaline conditions. A
complete system for this operation includes reactors, sensors,
controls, mixers, and chemical feed equipment. Control of both
pH and chlorine concentration through oxidation reduction
potential (ORP) is important for effective treatment.
Capital costs for cyanide oxidation as shown in Table VIII-2
include reaction tanks, reagent storage, mixers, sensors, and
controls necessary for operation. Costs are estimated for both
batch and continuous systems, with the operating mode selected on
a least cost basis. Specific costing assumptions are as follows:
866
-------
For both continuous and batch treatment, the cyanide oxidation
tank is sized as an above-ground cylindrical tank with a reten-
tion time of four hours based on the process flow. Cyanide
oxidation is normally done on a batch 'basis; therefore, two iden-
tical tanks are employed. Cyanide is removed by the addition of
sodium hypochlorite with sodium hydroxide added to maintain the
proper pH level. A 60-day supply of sodium hypochlorite is
stored in an in-ground covered concrete tank, 0.3 m (1 ft) thick.
A 90-day supply of sodium hydroxide also is stored in an in-
ground covered concrete tank, 0.3 m (1 ft) thick.
Mixer power requirements for both continuous and batch treatment
are based on 2 horsepower for every 11,355 liters (3,000 gal) of
tank volume. The mixer is assumed to be operational 25 percent
of the time that the treatment system is operating.
A continuous control system is costed for the
ment alternative. This system includes:
continuous treat-
- 2 immersion pH probes and transmitters
2 immersion ORP probes and transmitters
2 pH and ORP monitors
2 2-pen recorders
- 2 slow process controllers
- 2 proportional sodium hypochlorite pumps
2 proportional sodium hydroxide pumps
- 2 mixers
- 3 transfer pumps
1 maintenance kit
- 2 liquid level controllers and alarms and miscellaneous
electrical equipment and piping ;
A complete manual control system is costed for the batch treat- '"'•
ment alternative. This system includes:
- 2 pH probes and monitors
1 mixer
1 liquid level controller and horn :
1 proportional sodium hypochlorite pump
- 1 on-off sodium hydroxide pump and PVC piping from the.
chemical storage tanks
Operation and maintenance costs for cyanide oxidation include
labor requirements to operate and maintain the system, electric
power for mixers, pumps, controls, and treatment chemicals.
Labor requirements for operation are substantially higher for
batch treatment than for continuous operation. Maintenance labor
requirements for continuous treatment are fixed at 150 manhours
per year for flow rates below 23,000 gph and thereafter increase
according to:
867
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Labor = .00273 x (Flow - 23,000);+ 150
Maintenance labor requirements for batch treatment are assumed to
be negligible.
Annual costs for treatment chemicals are determined from cyanide
concentration, acidity, and flow!rates of the raw waste stream
according to:
Ibs sodium^hypochlorite = 62.96 x Ibs CN
Capital and annual costs for cyanide oxidation are presented in
Figure VIII-13.
Cyanide Precipitation. Cyanide ;precipitation is a two stage
process to remove free and non-complexed cyanide as a precipi-
tate. For the first step, the wastewater is contacted with an
excess of FeS04.7H20 at pH 9.0 to ensure that all cyanide is
converted to the complex form:
FeS04 • 7H20 + 6 CN-
7H20
The hexacyanoferrate is then routed to the second stage, where
additional FeSO* . 7H2O and acid are added to lower the pH to 4.0
or less, causing the precipitation of Fe4(Fe(CN)6)3 (Prussian
blue) and its analogues: >
pH <4.0
4 FeSCu • 7H20 + 3 Fe((N)6*-r
Fe«. (Fe(CN)6)3 + 7H2O ;
The blue precipitate is settled
discharged for further treatmentf
and the clear overflow is
The cyanide precipitation system! includes chemical feed equipment
for sodium hydroxide, sulfuric acid, and ferrous sulfate
addition, a reaction vessel, agitator, control system, clarifier,
and pumps. ;
i
Costs can be estimated for both batch and continuous systems with
the operating mode selected on a,least cost basis. This decision
is a direct function of flowratei. Capital costs are composed of
five subsystem costs: (1) FeS04 feed system, (2) NaOH feed
system, (3) reaction vessel with agitator, (4) sulfuric acid feed
system, (5) clarifier, and (6) recycle pump. These subsystems
include the following equipment:!
(1) Ferrous sulfate feed system;
ferrous sulfate steel storage hoppers with dust
collectors (largest hopper size is 6,000 ft3; 15
868
-------
days storage)
enclosure for storage tanks
volumetric feeders (small installations)
mechanical weigh belt feeders (large installations)
dissolving tanks (5 minute detention time, 6 percent
solution)
- dual-head diaphragm metering pumps
- instrumentation and controls
(2a) Caustic feed system (less than 200 Ib/day usage)
- volumetric feeder
mixing tank with mixer (24-hour detention, 10
percent solution)
feed tank with mixer (24-hour detention)
dual-head metering pumps
instrumentation and controls
(2b) Caustic feed system (greater than 200 Ib/day usage)
storage tanks (15 days, FRP tanks)
dual-head metering pumps including standby pump
- instrumentation and controls
(3) Reaction tank (60 minutes detention time, stainless
steel, agitator mounting, agitator, concrete slab)
(4) Sulfuric acid feed system (93 percent H2S04)
acid storage tank (15 days retention)
chemical metering pump
- instrumentation and control
(5) Clarifier [based on 700 GPD/ft2; to include a
steel or concrete vessel (depending on flow rate),
support structure, sludge scraper assembly and
drive unit]
(6) Recycle pumps (for sludge or supernatant)
Operation and maintenance costs for cyanide precipitation include
labor requirements to operate and maintain the system, electric
power for mixers, pumps, clarifier and controls, and treatment
chemicals. Electrical requirements are also included for the
chemical storage enclosures for lighting and ventilation and in
the case of caustic storage, heating. The following criteria are
used in establishing O&M costs:
(1) Ferrous sulfate feed system
maintenance materials - 3 percent of/ manufactured
869
-------
equipment cost i
- labor for chemical unloading
—5 hrs/50,000 Ib for bulk handling
—8 hrs/16,000 Ib for bag feeding to the hopper
—routine inspection and adjustment of feeders is
10 min/feeder/shift
maintenance labor ,
—8 hrs/yr for liquid metering pumps
—24 hrs/yr for solid feeders and solution tank
- power [function of instrumentation and control,
metering pump HP and volumetric feeder (bag feed-
ing)] :
(2) Caustic feed system i
maintenance materials - 3 percent of manufactured
equipment cost (excluding storage tank cost)
- labor/unloading
—dry NaOH - 8 hrs/16,000 Ib
— liquid 50 percent |NaOH - 5 hrs/50,000 Ib
labor operation (dry NaOH only) - 10 min/day/feeder
- labor operation for metering pump - 15 min/day
annual maintenance -; 8 hrs
- power includes metering pump HP, instrumentation
and control, volumetric feeder (dry NaOH)
(3) Reaction vessel with agitator
- maintenance materials - 2 percent of equipment cost
- labor ;
—15 min/mixer/day routine O&M
—4 hrs/mixer/6 mos - oil changes
—8 hrs/yr - draining, inspection, cleaning
- power - based on horsepower requirements for
agitator
(4) Sulfuric acid feed system
labor unloading - .25 hr/drum acid
- labor operation - 15 min/day
- annual maintenance - 8 hrs
- power (includes metering pump)
- maintenace materials - 3 percent of capital cost
(5) Clarifier
- maintenance materials range from 0.8 percent to
2 percent as a function of increasing size
labor - 150 to 500 tjrs/yr (depending on size)
power - based on horsepower requirements for sludge
870
-------
pumping and sludge scraper drive unit
(6) Recycle pump
- maintenance materials - percent of manufactured
equipment cost variable with flowrate
- 50 ft TDK; motor efficiency of 90 percent and pump
efficiency of 85 percent
Annual costs for treatment chemicals are determined from cyanide
concentration, pH, metals concentrations, and flowrate of the raw
waste stream.
Activated Carbon Adsorption. Activated carbon is used primarily
for the removal of organic compounds from wastewater. The
capital and annual costs for this process are based on a system
using granular activated carbon (GAC) in a series of downflow
contacting columns. Separate cost equations are presented for
GAC contacting units and GAC replacement.
Two methods of replacing spent carbon were considered: (1)
thermal regeneration of spent carbon and (2) replacement of spent
carbon with new carbon and disposal of spent carbon. Thermal
regeneration of spent activated carbon is economically practical
only at relatively large carbon exhaustion rates. Simply
replacing spent carbon with new carbon is more practical jbhan
thermal regeneration for plants with low carbon usage.
An analysis was performed to determine the carbon usage rate at
which thermal regeneration of spent carbon becomes practical. It
was determined that thermal regenerating facilities are practical
above a carbon usage of 400,000 Ibs per year. Carbon exhaustion
rates for all waste streams are presented in Table VII1-5. Data
from the literature were analyzed to determine a relationship
between TOC concentration and carbon exhaustion rate. These data
were applied to sampling data to obtain the carbon .exhaustion
rates shown in Table VII1-5.
A 30-minute empty-bed contact time was used to size the downflow
contacting units. The activated carbon used in the columns was
assumed to have a bulk density of 26 pounds per cubic foot and
cost 53 cents per pound. Included in the capital for a carbon
contacting system are carbon contacting columns, initial carbon
fill, carbon inventory and storage backwash system, and waste-
water pumping.
Thermal regeneration is assumed to be accomplished with multiple
hearth furnaces at a loading rate of 40 pounds of carbon per
square foot of hearth area per day. Activated carbon thermal
regeneration facilities include a multiple hearth furnace, spent
871
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carbon
veyors,
storage and dewatering equipment, quench tank, screw con-
and regenerated carbon refining and storage tanks.
Energy requirements for activatedlcarbon systems are two-fold;
heating for thermal regeneration (above 400,000 Ibs carbon used
per year) and electricity. The Btu requirements for heating
range from 1 x TO10 Btu/yr at 400,000 Ibs carbon to 2.1 x 1011
Btu/yr at 30 x TO6 Ib carbon. Electrical requirements are from
250,000 Kw-hr/yr at 200,000 Ibs carbon up to 1.5 x 106 Kw-hr/yr
at 30 x 106 Ibs carbon.
Capital and annual costs for activated carbon adsorption are
presented on Figure VIII-14.
Vacuum Filtration. Vacuum filtration is a technology utilized in
sludge dewatering. This system is included in the wastewater
treatment train depending on the amount of sludge generated from
precipitation systems. Per the discussion presented in the
costing example, vacuum filtration is costed if sludge generation
exceeds 140,000 gallons per year. Below this value, it is not
economically attractive to dewater the sludge prior to disposal.
Capital costs are based on the area of filter required, or a
solids loading rate of 4 pounds per hour per square foot, and an
operating period of six hours per day. The equipment included in
the vacuum filtration unit are as follows:
- Motor and drive :
- Auxiliaries
- Piping and ductwork
- Instrumentation
- Electrical •
Insulation
- Paint ;
- Accessories I
- Vacuum system ;
A minimum capital cost of $66,000 is assumed. Annual costs were
developed in terms of the amount of sludge to be dewatered. The
assumed influent suspended solids concentration is 7 percent and
the effluent, 30 percent. Energy requirements are based on fil-
ter size and flow rate, as in the case of capital costs. These
are estimated to range from 45,000 kw-hr/yr for 100 ft2 filter
area to 268,000 kw-hr/yr for 960 £t2.
Capital and annual costs for vacuum filtration are presented in
Figure VIII-15.
Contract Hauling. As stated previously, information obtained
from 511 plants in an EPA Effluent Guidelines Division study of
872
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the paint industry was used to determine contractor hauling
costs. Costs in the paint study ranged from 1 cent to over 50
cents per gallon. A value of 30 cents per gallon, selected as a
reasonable estimate in the paint study, was used in the develop-
ment of the aluminum forming guidelines for the disposal cost of
sludge and wastewater by contractor hauling. The cost of
contract hauling is presented in Figure VIII-16.
Countercurrent Cascade Rinsing. Countercurrent cascade rinsing
is a technique used to reduce wastewater flows from rinsing
operations. This technology has been described in detail in
Section VII (p. 775).
Capital costs are based on the number of tanks needed to achieve
a required flow reduction, and pumping if water cannot be moved
between the tanks by gravity flow. Each tank is assumed to be
rectangular, of dimensions 15 feet by 5 feet, by 8 feet deep.
Capital cost estimating for Countercurrent cascade rinsing
systems is highly site-specific. Tank sizing, in particular
cross-sectional area, may be determined by or limited by the
cross-sectional area of the workpiece. No piping costs are
included since it is assumed that pumping will not be necessary.
Final rinse stage tanks can be easily raised, or variable height
overflow weirs can be installed in a single large tank to allow
gravity flow of the rinse water. No retrofit land costs are
included. Based on plant visits to 22 aluminum forming sites,
the Agency believes that there is enough floor space for
installation of Countercurrent cascade rinsing operations at
existing plants.
The capital expenditure involved in installing Countercurrent
cascade rinsing technology will be in part offset by reduced
water use and sewer fees, and the overall reduction in the size
of the required waste treatment system, which is designed on the
basis of volumetric flow.
There are no significant operation and maintenance costs associ-
ated with tanks so the annual cost estimates include only annual
depreciation and amortization.
Regeneration of. Chemical Baths. Bath " regeneration is used to
recover or replenish the bath chemicals, reduce contaminant
levels in the bath, and to achieve zero discharge. As discussed
in Section VII (p. 779), regeneration of chromic acid and sul-
furic acid baths is accomplished through periodic addition of
solid chromic acid or sulfuric acid. Salts formed in the bath
constantly precipitate and must be drawn off the bottom of the
tank. In general, there are no additional capital costs required
for equipment to regenerate these types of baths. Removal of
settled precipitates is accomplished by existing pumping equip-
873
-------
ment used for emptying the bath in plants not currently regener-
ating baths. Chemical costs associated with regeneration were
costs for replenishing chromic acid and sulfuric acid.
For caustic baths, addition of lime and elevation of the bath
temperature is required for regeneration. The Agency assumed
that plants have sufficient waste heat available to elevate the
bath temperature. Chemical costs associated with regeneration of
caustic baths were costs for lime.|
The capital expenditures required for recovering and reusing
alkaline cleaning bath chemicals |was the cost of an ultrafiltra-
tion system. Membrane life was assumed to be one year as a
result of discussions with equipment manufacturers. The cost of
the membranes was assumed to be $100 per membrane. One hour per
week was used for maintenance labor. Alkaline cleaning chemicals
were assumed to cost $0.50 per pound. In addition, the ultrafil-
ter was assumed to be washed with a cleaner, one time each week.
The cleaner cost was assumed to be $2.00 per pound.
In considering the costs discussed above associated with regener-
ation, EPA concluded that the costs incurred will be offset by
decreased chemicals cost through recovery, reduced water, use and
sewer fees, the overall reduction in the size of the required
treatment system, and the reduced labor requirements for main-
taining the baths.
Flow Equalization. Flow equalization is used in order to
minimize potentially wide fluctuations in raw wastewater flow and
characteristics. Equalization has been included in the costs
associated with each treatment option presented.
The equipment included in the capital and annual costs is an
equalization tank with associated mixing equipment. The deten-
tion time assumed is four hours. For this technology, capital
and annual costs (Figure VIII-17) were derived by compositing
various system costs from the literature. Energy requirements
are expected to range from 2,500 Kw-hr/yr at 1 gpm to 300,000 Kw-
hr/yr at 10,000 gpm.
Pumping. The cost of pumping raw wastewater to a treatment plant
was considered, as was the cost for a dry well enclosure of the
pumping facility. Costs for wet Wells have not been considered
since the equalization basin f(br treatment plant operation can
function as a wet well. The pump; station electrical requirements
are based on a total dynamic head of 30 feet and a pumping
efficiency of 65 percent. These requirements are estimated to
range from 54 Kw-hr/yr for 1,000 gpd to 550,000 Kw-hr/yr for 10
MGD flowrate. ;
874
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Capital
VIII-18.
and annual costs for pumping are presented in Figure
Holding Tank. The cost of holding tanks has been considered for
the storage of sludges removed from skimming, dissolved air
flotation, and lime and settle operations. The equations can
also be used for the storage of dewatered sludge cake.
Allowances are made for storage of two weeks of sludge production
to a minimum of 150 gallons for sludges requiring contractor
hauling.
Capital and annual
Figure VIII-19.
costs for holding tanks are presented in
Recycle of Cooling Water. As discussed in Section VII (p. 772),
direct chill casting contact cooling water is commonly recycled
at rates of 96 percent or greater. For those plants that do not
recycle direct chill casting contact cooling water, the cost of
recycle has been determined. Recycle capital costs include a
cooling tower, a pump station, and piping. The capital costs for
a cooling tower assume the use of a mechanical draft tower. The
sizing of the tower is based on a temperature range of 25°F, an
approach of 10°F, and a wet bulb temperature of 70°F. The
cooling tower equipment include the following:
- Cooling tower
- Basin
- Handling and setting (installation)
- Piping
- Concrete foundations and footings
Instrumentation
- Plant mechanical draft system
Accessories
A minimum cost is assumed to be $62,000. Energy requirements are
a function of the fan size and horsepower required, depending on
recirculation ratio. These requirements are estimated to range
from 14,600 Kw-hr/yr at 0.1 MGD to 1,460,000 Kw-hr/yr at 10 MGD.
To account for recycle piping requirements, costs have been
determined for 1,000 feet of installed force main. Capital costs
for recycle piping include the following:
Concrete-lined ductile iron pipe
- 3, 4, 8, 12, 16, or 24 inch pipe diameters
- 0, 10, 20, or 40 ft. static heads
- 3 feet per second water velocity
875
-------
Pipe fittings ;
— 3 gate valves
— 1 standard tee
— 4 long sweep elbows
- Installation with excavation and backfill (below ground)
Energy requirements for pumping are the same as those given above
in the pumping discussion'. i
Capital and annual costs associated with recycling are presented
in Figure VIII-20. |
Enclosures. The cost of an enclosure is included in the capital
cost equations for all unit processes except skimmming,
equalization, lime and settle (lime and sulfuric acid storage and
chemical feed systems are enclosed) and the cooling tower
associated with recycle since the performance of these unit
processes is not typically affected by inclement weather. The
cost of enclosure includes the following:
- Roofing
- Insulation |
Sitework
- Masonry
- Glass
Plumbing
- HVAC and electrical |
The total capital cost is calculated by determining the required
area to be enclosed and applying $30 per square foot.
Cost Calculation Example
Capital and annual costs for each of the treatment alternatives
presented in Sections X and XII can be estimated both from the
cost equations in Table VII1-2 and, depending on the alternative,
from the data on oily sludge production, lime dosage and lime
sludge production, and carbon exhaustion rate shown in Tables
VIII-3 through VIII-5. Once the;wastewater flows are determined,
the costs associated with a treatment alternative are calculated
systematically using the following steps.
1. Determine capital and annual costs for each of the
treatment processes in the alternative using Table
VIII-1. '•
2. Determine capital and operating costs for pumping,
876
-------
3.
4.
equalization, and monitoring using Table VIII-1.
Calculate daily production, if any, of oily sludge and
lime sludge from Tables VIII-3 and VIII-4. Determine
the costs associated with the disposal of these residues
using Table VIII-2.
Determine total capital and annual costs for the alter-
native by summing up all cost data obtained in Steps 1
through 3. The annual cost so determined does not
include amortization and depreciation of capital invest-
ment. Obtain the total annual cost by including 17.7
percent and 10 percent of the capital cost for amortiza-
tion and depreciation, respectively.
As described previously, capital and operating costs associated
with the lime and settle (L&S) and activated carbon processes are
influenced by the lime dosage and carbon replacement require-
ments, respectively. Therefore, Tables VIII-3 and VIII-4 should
be consulted first to determine lime dosage for the particular
wastewater, stream under consideration or to evaluate the economic
choice between thermal regeneration and throwaway of spent carbon
for the activated carbon process.
Disposal of lime sludge is based on vacuum filtration, with the
resulting cake hauled by contractor or contractor-hauling of
undewatered liquid sludge. The economic choice between these two
methods depends upon the quantity of sludge requiring disposal,
with the dividing line being approximately 140,000 gallons per
year. Direct contractor-hauling of liquid sludge is less expen-
sive for smaller .sludge quantities, while the opposite is true
for greater sludge quantities. The cost components for the
former are holding tank capital cost (minimum capacity, 150
gallons) and contractor-hauling cost, while those for the latter
are holding tank capital cost (both for liquid sludge and cake),
vacuum filtration cost, and contractor-hauling cost for cake.
The cost components for oily sludge disposal are holding tank
capital cost (minimum capacity, 150 gallons) and contractor-
hauling cost.
The cost calculating procedures described above are illustrated
for a plant in the Forging Subcategory with the following condi-
tions:
Wastewater source: Forging solution heat treatment contact
cooling water
Operating time: 24 hours per day, 7 days per week,
52 weeks per year
Wastewater flow: 200 gallons per minute
Treatment alternative: BPT consisting of (1) cyanide'
877
-------
oxidation, (2) chromium reduction,
(3) pkimming, and (4) lime and
settle (see Figure IX-4)
Step 1 : :
Determine the capital and annual costs of the three treatment
processes shown above using appropriate equations in Table
VIII-2. For example, the capital cost (C) of chromium reduction
for a flow (x) of 200 gpm can be calculated as:
t
C = antilog [-0.0248 (log 200)'] + 0.108 (log 200)2 +
0.213 (log 200) + 4.107 + 384.8 (200)°.«7
= antilog (4.86) + 13,390 !
= 86,000
The forging solution heat treatment contact cooling water stream
requires 2,000 mg/1 lime dosage for precipitation (Table VIII--4);
use cost equations for lime and settle corresponding to this
dosage. A summary of Step 1 costs is shown below.
Cyanide oxidation
Chromium reduction
Skimming
Lime and settle
Subtotal
Capital
166:, 000
86,000
55,000
221,000
528,000
Annual ($/yr)
17,000
10,000
10,000
63,000
100,000
Step 2:
Capital and annual costs are calculated for flow equalization,
pumping, and monitoring. By using the appropriate equations in
Table VIII-2, the following costs are obtained for flow equaliza-
tion and pumping. Monitoring costs are constant at a capital
cost of $8,000 and an annual cost of $5,000.
Flow equalization
Pumping
Monitoring
Subtotal
Capital ($)
103,000
31,000
8,000
142,000
Annual ($/yr)
10,000
14,000
5,000
29,.000
Step 3:
(a) Determine daily production of oil skimmings (oily sludge)
using data in Table VIII-3, required holding tank capacity,, and
associated disposal costs from Table VIII-2.
Oil Skimmings = [
878
-------
0.07 gallons skimmings x 200 gallons x 1,440 min = 20 gallons
1,000 gallons min day day
As discussed previously, holding tanks are sized for two weeks'
sludge production, or a minimum of 150 gallons holding tank
capacity. Required holding tank capacity is:
20 gallons x 7 days
day week
x 2 weeks = 280 gallons
The capital cost (holding tank) and annual cost (contractor haul-
ing) for the disposal of oily sludge are then calculated as:
Oil skimmings disposal
Capital ($)
2,100
Annual ($/yr)
2,200
(b) Determine daily production of lime sludge using data in
Table VII1-4, then determine whether the sludge should be
dewatered by vacuum filtration prior to disposal.
Lime sludge =
6 gallons sludge x 200 gallons x 1,440 minutes = 1,700 gallons
1,000 gallons min day day
At 365 days per year operation, this quantity corresponds to an
annual lime sludge production of 620,000 gallons. Therefore,
vacuum filtration and cake hauling is more cost-effective than
liquid sludge hauling.
To estimate the required size of vacuum filters and the volume of
filter cake,, lime slpdge from the settling tank and the filter
cake are assumed to contain 7 percent and 30 percent solids,
respectively, and have a specific gravity of 1.0.
Vacuum filter area required must be determined before the capital
cost equation for vacuum filtration in Table VIII-2 can be used.
At 7 percent solids, 6 hours of operation per day and a 4
Ibs/hour/sq ft loading rate, one square foot of vacuum filter
area can dewater 40 gallons of sludge per day. The vacuum filter
area requirement for this example is presented below:
1,700 gallons x
day
1
40 gallons/day/sq ft
= 43 sq ft
Daily production of filter cake is
1.700 gallons x 7% solids = 400 gallons
day 30% solids day
879
-------
Two storage tanks are required for vacuum filtration, one to
store the daily clarifier underflow to facilitate a controlled
flow into the vacuum filter, and the other to store the dewatered
sludge. Therefore, a 1,700-gallon storage tank is required to
store daily clarifier underflow. The filter cake storage tank is
sized as follows:
400 gallons x 7 days x 2 weeks > 5,600 gallons
day week :
COST ESTIMATION METHODOLOGY; POST-PROPOSAL
Sources of_ Cost Data ;
Capital and annual cost data for the selected treatment processes
w?re obtained fr°m three sources: ; (1) equipment manufacturers,
(2) literature data, and (3) cost ;data from existing plants. The
ma^or source of equipment costs was contacts with equipment ven-
dors, while the majority of annual cost information was obtained
from the literature. Additional cost and design data wore
obtained from data collection portfolios when possible.
Components of Costs
Capital Costs. Capital costs jconsist of two component's:
equipment capital costs and system capital costs. -Equipment
costs include: (1) the purchase price of the manufactured
equipment and any accessories assumed to be necessarv (2)
delivery charges, which account for the cost of shipping the
purchased equipment a distance of 500 miles; and ("3)
installation, which includes labor, excavation, site work, and
materials. The correlating equations used to generate equipment
costs are shown in Table VIII-6. Capital system costs include
contingency, engineering, and contractor's fees. These system
costs, each expressed as a percentage of the total equipment
cost, are combined into a factor which is multiplied by the total
equipment cost to yield the tptal capital investment. The
components of the total capital investment are listed in Table
V JL X J.""" / • t
Annua* Costs. The total annualized costs also consist of a
direct and a system component as in the case of total capital
£S^ WT?T Components of the total annualized costs are listed
Table VIII-8. Direct annual costs include the following:
o Raw materials - These costs are for chemicals used in
the treatment processes, which include lime, sulfuric
acid, alum, polyelectrolyte, and sulfur dioxide.
o Operating labor and materials - These costs account for
880
-------
the labor and materials directly associated with opera-
tion of the process equipment. Labor requirements are
estimated in terms of manhours per year. A labor rate
of 21 dollars per manhour was used to convert the man-
hour requirements into an annual cost. This composite
labor rate included a base labor rate of nine dollars
per hour for skilled labor, 15 percent of the base labor
rate for supervision and plant overhead at 100 percent of
the total labor rate. Nine dollars per hour is the
Bureau of Labor national wage rate for skilled labor
during 1982.
o Maintenance and repair - These costs account for the
labor and materials required for repair and routine
maintenance of the equipment. Maintenance and repair
costs were usually assumed to be 5 percent of the direct
capital costs based on information from literature
sources unless more reliable data could be obtained from
vendors.
o Energy - Energy, or power, costs are calculated based
on total nominal horsepower requirements (in kw-hrs),
an electricity charge of $.0483/kilowatt-hour and an
operating schedule of 24 hours/day, 250 days/year unless
specified otherwise. The electricity charge rate (March
1982) is based on the industrial cost derived from the
Department of Energy's Monthly Energy Review.
System annual costs include monitoring, insurance and amortiza-
tion (which is the major component). Monitoring refers to the
periodic sampling analysis of wastewater to ensure that discharge
limitations are being met. The annual cost of monitoring was
calculated using an analytical lab fee of .$120 per wastewater
sample and a sampling frequency based on the wastewater discharge
rate, as shown in Table VIII-9.
Insurance cost is assumed to be one percent of the total depreci-
able capital investment (see Item 23 of Table VIII-7).
Amortization costs, which account for depreciation and the cost
of financing, were calculated using a capital recovery factor
(CRF). A CRF value of 0.177 was used, which is based on an
interest rate of 12 percent, and a taxable lifetime of 10 years.
The CRF is multiplied by the total depreciable investment to
obtain the annual amortization costs (see Item 24 of Table viii-
8).
881
-------
Cost Update Factors
stndardized
adjusting to the first quarter of
components of costs
Investment - Investment costs
were
adjusted using the
EPA-Sewage Treatment Plant Construction Cost Index. The value of
this index for March 1982 is 414.0. v«*iut or
and Maintenance Labour - The Engineering News-Record
iS USed to adjust the Portion of Qper-
attributable to labor. The March
Maintenance Materials - The producer price index published bv the
Department of Labor, Bureau of Statistics is used The March
1982 value of this index is 276.5: warcn
Chemicals - The Chemical Engineering Producer Price Index for
industrial chemicals is used. This indL is published biwJeklv
magazine' The MarchP1982 value o? Sis
Energy - Power costs are adjusted by using the nrice of
electricity on the desired date and multiplying^ by the energy
requirements for the treatment module in kw-hr equivalent!.
Cost Estimation Model
— _^__^_ ^
Was Accomplished lising a computer model which
S^i^1"9 th\^ui^ treatment system chemJJal
of the raw waste Streams, flow rates and treat-
°f th^e stre^s, and operating scSd-
. f 9omP"ter-aided design of a waste-
system containing modules that are configured to
te equipment at an individual plant. The
t^atment m°dule and then executes a costing
the cost data for each module. The capital
ules
A ®
?5i?nS
tion f^om^hr^hn^10?6?-^ c?uPlin9 theoretical design informa-
tion trom the technical literature with actual desian data fr-nm
operating plants. This permits: the most repr Sedative design
approach possible to be used, which is a very important elSeS
and ™^Sly estimating costs. The fundamental Snits for dSiJn
and costing are not the modules themselves but the components
882
-------
within each module, e.g., the lime feed system within the chemi-
cal precipitation module. This is a significant feature of this
model for two reasons. First, it does not limit the model to
certain fixed relationships between various components of each
module. For instance, cost data for chemical precipitation sys-
tems are typically presented graphically as a family of curves
with lime (or other alkali) dosage as a parametric function. The
model, however, sizes the lime feed system as a funtion of the
required mass addition rate (kg/hr) of lime. The model thus
selects a feed system specifically designed for that plant.
Second, this approach more closely reflects the way a plant would
actually design and purchase its equipment. The resulting costs
are thus closer to the actual costs that would be incurred by the
facility.
Overall Structure. The cost estimation model consists of two
main parts: a design portion and a costing portion. The design
portion uses input provided by the user to calculate design
parameters for each module included in the treatment system. The
design parameters are then used as input to the costing routine,
which contains cost equations for each discrete component in the
system. The structure of the program is such that the entire
system is designed before any costs are estimated.
The pollutants or parameters which are tracked by the
shown in Table VI11-10.
model are
An overall logic diagram of the computer programs is depicted in
Figure VIII-1. First, constants are initialized and certain var-
iables such as the modules to be included, the system configura-
tion, plant and wastewater flows, compositions, and entry points
are specified by the user. Each module is designed utilizing the
flow and composition data for influent streams. The design
values are transmitted to the cost routine. The appropriate cost
equations are applied, and the module costs and system costs are
computed. Figures VIII-2 and VIII-3 depict the logic flow dia-
grams in more detail for the two major segments of the program.
Costing Input Data. Several data inputs are required to run the
computer model. First, the treatment modules to be costed and
their sequence must be specified. Next, information on hours of
operation per day and number of days of operation per year for
the particular plant being costed is required. The flow values
and characteristics must be specified for each wastewater stream
entering the treatment system, as well as each stream's point of
entry into the wastewater treatment system. These values will
dictate the size and other parameters of equipment to be costed.
The derivation of each of these inputs for costed plants in the
aluminum forming category will be discussed in turn.
883
-------
Choice of the appropriate modules and their sequence for a plant
that is to be costed are determined by applying the treatment
technology for each option (see Figures X-l through X-5). These
option diagrams were adjusted to accurately reflect the treatment
system that the plant being costed would actually require. For
example, if it were determined by examining a plant's dcp that
sodium bichromate would not be used in the plants pickling oper-
ation, then a chromium reduction module would not be included in
the treatment required for that plant. In addition, if a plant
had a particular treatment module in place, that module would not
be costed. Flow reduction modules were not costed for plants
whose waste stream flow rates were Already lower than the regula-
tory flows. The information on hoiirs of operation per day and
days of operation per year was obtained from the data collection
portfolio of the plant being costed.
I
The flows used to size the treatment equipment were derived as
follows: production (kkg/yr) and flow (1/yr) information was
obtained from the plant's dcp, or from sampling data where possi-
ble, and a production normalized flow in liters per kkg was cal-
culated for each waste stream. > This flow was compared to the
regulatory flow, also in liters per kkg, and the lower of the two
flows was used to size the treatment equipment. Regulatory flow
was also assigned to any stream for which production or flow data
was not reported in the dcp.
The raw waste concentrations of influent waste streams used for
costing were based on sampling data and the assumption that the
total pollutant loading (mg/hr) in a particular waste stream is
directly proportional to the production rate (kkg/hr) associated
with that waste stream. The procedure used for determining the
pollutant concentrations (mg/1) to :be used as input to the cost
model was as follows: for a given input waste stream to the
model during actual costing, the average production normalized
raw waste values (mg/kkg) are divided by the production normal-
ized costing flow (1/kkg) (actual or regulatory based, whichever
is lower) to obtain the pollutant concentration for costing. The
underlying assumption is that the amount of pollutant generated
corresponds directly with the amount of product produced. A sig-
nificant result of this assumption [is that the total pollutant
loading (mg/hr) remains constant when in-process flow reduction
techniques are used (e.g., for a stream that is reduced by a fac-
tor of two via a flow reduction measure, the pollutant concentra-
tions will increase correspondingly by a factor of two).
Model Results. For a given plant, the model will generate
comprehensive material balances for each parameter (pollutant,
temperature and flowrate) tracked at any point in the system. It
will also summarize design values for key equipment in each
treatment module, and provide a tabulation of costs for each
884
-------
piece of equipment in each module, module subtotals, total
equipment costs, and system capital and annual costs.
Cost Estimates for Individual Treatment Technologies
Introduction. Treatment technologies have been selected from
among the larger set of available alternatives discussed in
Section VII after considering such factors as raw waste charac-
teristics, typical plant characteristics (e.g., location, produc-
tion schedules, product mix, and land availability), and present
treatment practices. Specific rationale for selection is
addressed in Sections IX, X, XI, and XII. Cost estimates for
each technology addressed in this section include investment
costs and annual costs for depreciation, capital, operation and
maintenance, and energy. Capital and annual costs for each
technology are presented in Figures VIII-21 through VIII-30.
The specific assumptions for each wastewater treatment module are
listed under the subheadings to follow. Costs are presented as a
function of influent wastewater flow rate except where noted in
the unit process assumptions.
Costs are presented for the following control and treatment
technologies:
- Lime Precipitation and Gravity Settling,
- Vacuum Filtration,
Flow Equalization,
- Multimedia Filtration,
Chemical Emulsion Breaking,
Oil Skimming,
Chromium Reduction,
- Recyde-Cool ing,
- Countercurrent Cascade Rinsing, and
- Contract Hauling.
Cyanide treatment was not costed because only two plants were
found to have cyanide in their wastewaters. Additionally, plants
are expected to choose chemical substitution as a means of con-
trolling the discharge of cyanide as opposed to the installation
of cyanide treatment.
Lime Precipitation and Gravity Settling. Precipitation using
lime followed by gravity settling is a fundamental technology for
metals removal. In practice, either quicklime (CaO) or hydrated
lime (Ca(OH)2) can be used to precipitate toxic and other metals.
Hydrated lime is more economical for low lime requirements since
the use of slakers, which are necesary for quicklime usage, are
practical only for large-volume application of lime.
885
-------
Lime is used to adjust the pH of the influent waste stream to a
value of approximately 9, at which optimum precipitation of the
metals is assumed to occur (see Section VII, page 701), and to
react with the metals to form metal hydroxides. The lime dosage
is calculated as a theoretical stoichiometric requirement based
on the influent metals concentrations and pH. The actual lime
dosage requirement is obtained by assuming an excess of 10
percent of the theoretical lime dosage. The effluent
concentrations are based on thb Agency's combined metals data
base lime precipitation treatment effectiveness values.
The costs of lime precipitation and gravity settling were based
on one of three operation modes, depending on the influent flow-
rate: continuous, normal batch, and "low flow" batch. The use
of a particular mode for costing purposes was determined on a
least (total annualized) cost basis for a given flowrate. The
economic breakpoint between continuous and normal batch was esti-
mated to be 11,800 liters/hour. Below 2,000 liters/hour, it was
found that the "low flow" batch system was most economical.
For a continuous operation, the following equipment were included
in the determination of capital and annual costs:
I
- Lime feed system (continuous)
I
r
1. Storage units (sized for 30-day storage)
2. Slurry mix tank (5 minute retention time)
3. Feed pumps
4. Instrumentation (pH control)
- Polymer feed system
1. Storage hopper !
2. Chemical mix tank ;
3. Chemical metering pumpi
i
- pH adjustment system !
1. Rapid mix tank, fiberglass (5 minute retention time)
2. Agitator (velocity gradient is 300/second)
3. Control system ;
i
- Gravity settling system \
1 .
2.
Clarifier, circular, steel (overflow rate is 0.347
gpm/sq. ft., underflowisolids is 3 percent)
Sludge pumps (1), (to transfer flow to and from
clarifier)
886
-------
Ten percent of the clarifier underflow stream is recycled to the
pH adjustment tank to serve as seed material for the incoming
waste stream.
The direct capital costs of the lime and polymer feed were based
on the respective chemical feed rates (dry Ibs/hour), which are
dependent on the influent waste stream characteristics. The
flexibility of this feature (i.e., costs are independent of other
module components) was previously noted in the description of the
cost estimation model. The remaining equipment costs (e.g., for
tanks, agitators, pumps) were developed as a function of the
influent flowrate (either directly or indirectly, when coupled
with the design assumptions).
Direct annual costs for the continuous system include operating
and maintenance labor for the feed systems and the clarifier, the
cost of lime and polymer, maintenance materials and energy costs
required to run the agitators and pumps.
The normal batch treatment system (used for 2,000 liters/hour
flow 11,800 liters/hour) consists of the following equipment:
Lime feed system (batch)
1. Slurry tank (5 minute retention time)
2. Agitator
3. Feed pump
- Polymer feed system
1. Chemical mix tank
2. Agitator
3. Chemical metering pump
pH adjustment system
1. Reaction tanks (2), (8 hour retention time each)
2. Agitators (2), (velocity gradient is 300/second)
3. Sludge pump (1), (to transfer sludge to dewatering)
4. pH control system
The reaction tanks used in pH adjustment are sized to hold the
wastewater volume accumulated for one batch period (assumed to be
8 hours). The tanks are arranged in a parallel setup so that
treatment occurs in one tank while wastewater is accumulating in
the other tank. A separate gravity settler is not necessary
since settling will occur in the reaction tank after precipita-
tion has taken place. The settled sludge is then pumped to the
dewatering stage.
887
-------
If additional tank capacity is required in the pH adjustment sys-
tem in excess of 25,000 gallons (largest single fiberglass tank
capacity for which cost data were compiled), additional tanks are
added in pairs. A sludge pump and agitator are costed for each
tank.
* i
The cost of operating labor is the major component of the direct
annual costs for the normal batch system. For operation of the
batch lime feed system, labor requirements range from 15 to 60
minutes per batch, depending on the lime feed rate (5 to 1,000
pounds/batch). This labor is associated with the manual addition
of lime (stored in 50 pound bags). For pH adjustment, required
labor is assumed to be one hour per batch (for pH control,
sampling, valve operation, etc,). Both the pH adjustment tank
and the lime feed system are assumed to require 52 hours per year
(one hour/week) of maintenance labor. Labor requirements for the
polymer feed system are approximately one hour/day, which
accounts for manual addition of dry polymer and maintenance asso-
ciated with the chemical feed pump and agitator.
i1
Direct annual costs also include the cost of chemicals (lime,
polymer) and energy required for the pumps and agitators. The
costs of lime and polymer used in the model are $47.30/kkg of
lime ($43/ton) and $4.96/kg of polymer ($2.25/pound), based on
rates obtained from the Chemical Weekly Reporter (lime) and
quotations from vendors (polymer) .;
For small influent flowrates (less than 2,000 liters/hour) it is
more economical on a total annualized cost basis to select the
'low flow" batch treatment system, The lower flowrates allow an
assumption of five days for the batch duration, or holdup, as
opposed to eight hours for the normal batch system. However,
whenever the total batch volume (based on a five day holdup)
exceeds 25,000 gallons, the maximiim single batch tank capacity,
the holdup is decreased accordingly to maintain the batch volume
under this level. Capital and annual costs for the low flow
system are based on the following equipment:
- pH adjustment system i
1 .
2.
3.
Rapid mix/holdup tank I (5 days or less retention time)
Agitator
Transfer pump !
Only one tank is required for both holdup and treatment because
treatment is assumed to be accomplished during non-operating
hours (since the holdup time is much greater than the time
required for treatment). A lime feed system is not costed since
lime addition at low application rates can be assumed to be done
manually by the operator. A common pump is used for transfer of
888
-------
both the supernatant and sludge through an appropriate valving
arrangement. Addition of polymer was assumed to be unnecessary
due to the extended settling time available.
As in the normal batch case, annual costs are comprised mainly of
labor costs for the low flow batch system. Labor requirements
are constant at 1.5 hours per batch for operation (e.g.,' pH
control, sampling, etc.) and 52 hours per year (one hour per
week) for maintenance. Labor is also required for the manual
addition of lime directly to the batch tank, ranging from 0.25 to
1.5 hours per batch depending on the lime requirement (1 to 500
pounds per batch). Annual costs also include energy costs
associated with the pump and agitator.
Capital and annual costs for these three operation modes of
chemical precipitation and settling (lime and settle) are
presented in Figure VIII-21. The curves shown in Figure VIII-21
cannot be extrapolated beyond the points shown.
Vacuum Filtration. The underflow from the clarifier is routed to
a rotary precoat vacuum filter, which dewaters the hydroxide
sludge (it may also include calcium sulfate and fluoride) to a
cake of 20 percent dry solids. The dewatered sludge is disposed
of by contract hauling and the filtrate is recycled to the rapid
mix tank as seed material for sludge formation.
The capacity of the vacuum filter, expressed as square feet of
filtration area, is based on a yield value of 14.6 kg of dry
solids/hr per square meter of filter area (3 lbs/hr/ft2), with a
solids capture of 95 percent. It was assumed that the filter was
operated 8 hours/day.
Cost data were compiled for vacuum filters ranging from 0.9 to
69.7 m2 (9.4 to 750 ft2) in filter surface area. Based on a
total annualized cost comparison, it was assumed that it was more
economical to directly contract haul clarifier underflow streams
which were less than 42 1/hr (0.185 gpm), rather than dewater by
vacuum filtration before hauling.
The capital
ing:
costs for the vacuum filtration include the follow-
Vacuum filter with precoat but no sludge conditioning,
Housing, and
Influent transfer pump.
Operating labor cost is the major component of annual costs,
which also include maintenance and energy costs. Capital and
annual costs of vacuum filtration are presented in Figure
VIII-22.
889
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Flow Equalization. Flow equalization is accomplished through
steel equalization tanks which are sized based on a retention
time of eight hours and an excess capacity factor of 1.2. Cost
data were available for steel equalization tanks up to a capacity
of 500,000 gallons; multiple units were required for volumes
greater than 500,000 gallons. ;The tanks are fitted with agita-
tors with a horsepower requirement of 0.006 kw/1,000 liters (0.03
hp/1,000 gallons) of capacity to prevent sedimentation. An
influent transfer pump is also included in the equalization
system. ;
Capital and annual costs for flow equalization are
Figure VIII-23.
presented in
Multimedia Filtration. Multimedia filtration is used as a
wastewater treatment polishing device to remove suspended solids
not removed in previous treatment processes. The filter beds
consist of graded layers of grave'l, coarse anthracite coal, and
fine sand. The equipment used to determine capital and annual
costs are as follows:
Influent storage tank sized for one backwash volume;
- Gravity flow, vertical steel cylindrical filters with
media (anthracite, sand, and garnet);
- Backwash tank sized for one backwash volume;
i
Backwash pump to provide .necessary flow and head for
backwash operations;
Influent transfer pump; and
Piping, valves, and a control system.
The hydraulic loading rate is 7,335 lph/m2 (180 gph/ft2) and the
backwash loading rate is 29,340 lph/m2 (720 gph/ft2). The filter
is backwashed once per 24 hours for 10 minutes. The backwash
volume is provided from the stored filtrate.
Effluent pollutant concentrations are based on the Agency's com-
bined metals data base for treatability of pollutants by filtra-
tion technology.
Cartridge-type filters are costed to treat small flows (less than
1,150 liters/hour) since they are; more economical compared to
multimedia filters (based on |a least total annualized cost
comparison) at these flows. It was assumed that the effluent
quality achieved by cartridge-typ^ filters was at least the level
attained by multimedia filters. The costs for cartridge-type
890
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filters are based on a two-stage filter unit, a holding tank
(capacity is equal to the total batch volume of preceding batch
chemical precipitation tank) and an influent transfer pump.
The majority of the annual cost is attributable to replacement of
the spent cartridges which depends upon the amount of solids
removed. The maximum loading for each cartridge is assumed to be
0.225 kg of suspended solids. The annual energy and maintenance
costs associated with the pump are also included in the total
annual costs.
Capital and annual costs for cartridge and multimedia filters are
presented in Figure VIII-24.
Chemical Emulsion Breaking. Chemical emulsion breaking involves
the separation of relatively stable oil-water mixtures by
chemical addition. Alum, polymer, and sulfuric acid are commonly
used to destabilize oil-water mixtures. In the determination of
capital and annual costs based on continuous operatibn, 400 mg/1
of alum and 2 mg/1 of polymer are added to waste streams
containing emulsified oil. The equipment included in the capital
and annual costs for continuous chemical emulsion breaking are as
follows:
Alum and polymer feed systems:
1. Storage units
2. Dilution tanks
3. Conveyors and chemical feed lines
4. Chemical feed pumps
Rapid mix tank (retention time of 15 minutes; mixer
velocity gradient is 300/sec)
Flocculation tank (retention time of 45 minutes;
mixer velocity gradient is 100/sec)
Pump
Following the flocculation tank, the stabilized oil-water mixture
enters the oil skimming module. In the determination of capital
and annual costs based on batch operation, sulfuric acid is added
to waste streams containing emulsified oil until a pH of 3 is
reached. The following equipment is included in the determina-
tion of capital and annual costs based on batch operation:
Sulfuric acid feed systems
1. Storage tanks or drums
891
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2. Chemical feed lines
3. Chemical feed pumps '
Two tanks equipped with agitators (retention time of
8 hrs., mixer velocity gradient is 300/sec)
Two belt oil skimmers
Two waste oil pumps |
[
- Two eff1uent water pumps j •
\
One waste oil storage tank ,(sized to retain the waste
oil from ten batches) [ . •
The capital and annual costs for continuous and batch chemical
emulsion breaking (Figure VII1-25) were determined by summing the
costs from the above equipment. Alburn, polymer and sulfuric acid
costs were assumed to be $.257 p!er kg ($.118 per pound), $4.95
per kg ($2.25 per pound) and $0.08 per kg of 93 percent acid
($.037 per pound of 93 percent acid), respectively. (See
Chemical Weekly Reporter, March, 1982).
Operation and maintenance and energy costs for the different
types of equipment which comprise the batch and continuous
systems were drawn from various literature sources and are
included in the annual costs.
The cutoff flow for determining the operation mode (batch or con-
tinuous) is 5,000 liters per hour, above which the continuous
system is costed; at lower flows, the batch system is costed.
For annual influent flows to the chemical emulsion breaking sys-
tem of 91,200 liters/year (24,00:0 gallons/year) or less, it is
more economical to directly contract haul rather than treat the
waste stream. The breakpoint flow is based on a total annualized
cost comparison and a contract hauling rate of $.40/gallon (no
credit was given for oil resale), i
Oil Skimming. Oil skimming costs apply
water mixtures using a coalescent plate
essentially an enhanced API-ltype
Coalescent plate separators were not
chemical emulsion breaking since jthe
with a belt type oil skimmer, served as
tank. The cost of the belt skimmer in
part of the chemical emulsion breaking
to the separation of oil-
>-type separator (which is
oil-^-water separator).
required following batch
batch tank, in conjunction
the oil-water separation
this case was included as
costs.
Although the required separator capacity is dependent on many
factors, the sizing was based primarily on the influent waste-
892
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water flow rate, with the following design values assumed for the
remaining parameters of importance:
Parameter
Specific gravity of oil
Operating temperature (°F)
Influent oil concentration (mg/1)
Nominal Design Values
0.85
68
30,000
Extreme operating conditions, such as influent oil concentrations
greater than 30,000 mg/1, or temperatures much lower than 68°F
were accounted for in the sizing of the separator.
The capital and annual costs of oil skimming (Figure VIII-26)
included the following equipment:
- Coalescent plate separator with automatic shutoff
valve and level sensor
Oily waste storage tanks (2-week retention time)
- Oily waste discharge pump
Effluent discharge pump
Influent flow rates up to 159,100 1/hr (700 gpm) are costed for a
single unit; flows greater than 700 gpm require multiple units.
The direct annual costs for oil skimming include the cost of
operating and maintenance labor and replacement parts. Annual
costs for the coalescent separators alone are minimal and involve
only periodic clean out and replacement of the coalescent plates.
Chromium Reduction. This technology can be applied to waste
streams containing significant concentrations of hexavalent
chromium. Chromium in this form will not precipitate until it
has been reduced to the trivalent form. The waste stream is
treated by addition of acid and gaseous S02 dissolved in water in
an agitated reaction vessel. The S02 is oxidized to sulfate
while it reduces the chromium.
The equipment required for this continuous stream includes an S02
feed system (sulfonator), an E^SO^ feed system, a reactor vessel
and agitator, and a pump. The reaction pH is 2.5 and the S02
dosage is a function of the influent loading of hexavalent
chromium. A conventional sulfonator is used to meter S02 to the
reaction vessel. The mixers velocity gradient is 100/sec.
Annual costs are as follows:
893
-------
1.
2.
3.
S02 feed system j
1. S02 cost at $0.1 I/kg ($0.25/lb)
2. Operation and maintenance labor requirements vary
from 437 hrs/yr at 4.5 kg S02/day (10 Ib S02/day')
to 5,440 hrs/yr at 4!,540 kg S02/day (10,000 Ibs
SO2/day),
3. Energy requirements ;at> 570 kwh/yr at 4.5 kg S02/day
(10 Ibs S02/day) to >31,000 kwh/yr at 4,540 kg SO,/
day (10,000 Ibs SO2/day). ' .
H2S04 feed system i
Operating and maintenance labor at 72 hrs/yr at
37.8 Ipd (10 gpd) of 93 percent H2S04 to 200
hrs/yr at 3,780 Ipd (1 ,1000 gpd),
Maintenance materials at 3 percent of the equip-
ment cost, i
Energy requirements for metering pump and storage
heating and lighting. |
Reactor vessel and agitator
1. Operation and maintenance labor at 120 hrs/yr,
2. Electrical requirements for agitator.
Capital and annual costs of chromium reduction are presented in
Figure VIII-27.
Cooling Towers/Tanks. Cooling towers are used to recycle direct
chill casting and solution heat treatment contact cooling waters
for recirculating flow rates above ; 3,400 1/hr (15 gpm). The
minimum flow rate represents '. the smallest cooling tower
commercially available from the vendors contacted. Conventional
holding tanks are used to recycle flow rates less than 15 gpm.
The required cooling tower capacity is based on the amount of
heat removed, which takes into account both the flow rate and
temperature range (decrease in cooling water temperature). The
recirculation flow rate through the cooling tower is based on the
BPT (option 1) flow allowance, and the bleed stream which enters
the treatment system is based on the BAT (Option 2) flow allow-
ance. For solution heat treatment cooling water, this results in
a recycle rate of 73.6.percent (e.g., 7705 1/kkg - 2037 1/kkg/
7705 1/kkg). A recycle rate of 85; percent was assumed for cool-
ing of direct chill casting cooling water since recycle is a BPT
technology for this waste stream. ! The range was based on a cold
water temperature of 85°F and an average hot water temperature
for each particular waste stream calculated from sampling data.
When the hot water temperature was not available from sampling
data, or found to be below 95°F, a value of 95°F was assumed,
894
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resulting in a range of 10°F (95-85°F). The remaining
significant design parameters, the wet bulb temperature (ambient
temperature at 100 percent relative humidity) and the approach
(of cold water temperature to the wet bulb temperature) are
assumed to be constant at 77°F and 8°F, respectively.
The capital costs of cooling tower systems include the following
equipment:
Cooling tower (crossflow, mechanically-induced) and
typical accessories
Piping and valves (305 meters (1000 ft.) 'carbon steel)
Cold water storage tank (1 hour retention time)
-• Recirculation pump, centrifugal
Chemical treatment system (for pH, slime and corrosion
control)
For nominal recirculation flow rates greater than 159,100 1/hr
(700 gpm), multiple cooling towers are assumed to be required.
A holding- tank system would consist of
recirculation pump.
a holding tank and a
The direct capital costs include purchased equipment cost,
installation and delivery. Installation costs for cool ing' towers
were assumed to be 200 percent of the cooling tower cost based on
information supplied, by vendors.
Direct annual costs included raw chemicals for water treatment,
fan energy requirements, and maintenance and operating labor was
assumed to be constant at 60 hours per year. The water treatment
chemical cost was based on a rate of $5/gpm of recirculated
water.
Capital and annual costs for cooling towers and holding tanks
presented in Figure VIII-28.
are
Countercurrent Cascade Rinsing. This technology is used to
reduce water use in rinsing operations for BAT options. It
involves multiple-stage rinsing, with product and rinse water
moving in opposite directions (see Section VII for more details
on theory). This allows for a significant reduction in flow over
single stage rinsing, while achieving the same product cleanli-
ness by contacting the most contaminated rinse water with the
incoming product.
895
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The costs for countercurrent cascade rinsing apply to a two-stage
rinse system, each consisting of the following equipment:
o Two fiberglass rectangular tanks (Existing source costs
include only one tank since the other tank was assumed
to be already in place).
o One centrifugal, transfer pump,
o One sparger (air diffuser) for agitation,
o One blower (including motpr) for supplying air to the
sparger.
Tanks were sized based on the production rate associated with
each rinsing operation, as follows:
Production Rate
(kkg/yr)
1,000
1,000 - 5,000
5,000
Tank Volume
(gallons)
1,500
3,600
8,000
The above tank volumes and breakpoints were based on information
obtained from dcp's and a telephone survey of several anodizina
plants. ' y
For the case of multiple rinsing operations undergoing counter-
current rinsing, each operation was costed individually because
of the wide variability in the rinsing flowrates due to the vary-
ing production rates (since reduced flowrates are determined by
multiplying the flow allowance by the production).
When it was determined from a pflant's dcp that two-stage coun-
tercurrent cascade rinsing could be achieved by converting two
existing adjacent rinse tanks, only piping and pump costs were
accounted for. A constant value of $1,000 was estimated for the
piping costs. |
Capital and annual costs for countercurrent cascade rinsing are
presented in Figure VII1-29.
Contract Hauling. Concentrated sludge and waste oils are removed
on a contract basis for off-site disposal. The cost of contract
hauling depends on the classification of the waste as being
either hazardous or nonhazardous. j For nonhazardous wastes a
rate of $0.106/liter ($0.40/gallon) was used in determining
contract hauling costs. This value is based on reviewing
information from several sources, including a paint industry
896
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survey, comments from the aluminum forming industry, and the
literature. The contract hauling cost for nonhazardous waste was
used in this cost estimation because the Agency believes that the
wastes generated from aluminum forming plants are not hazardous
as defined under 40 CFR 261. The capital cost associated with
contract hauling is assumed to be zero. The annual cost of
contract hauling is presented in Figure VIII-30.
Regeneration. As discussed in Section X, the regeneration
technology applicable to cleaning or etching baths is no longer
included in the Option 2 and Option 3 model treatment technolo-
gies. For the plants costed after proposal, the flows attributa-
ble to cleaning or etching baths were added to the total flow
treated through the appropriate end-of-pipe treatment technolo-
gies. •
o
SUMMARY OF COSTS
A summary of the capital and annual costs associated with com-
pliance with the aluminum forming regulation is presented in
Table VIII-ll for each subcategory.
NORMAL PLANT
In order to estimate costs, pollutant removals, and nonwater
quality aspects for new sources, the Agency developed a normal
plant for each of the six subcategories. A normal plant is a
theoretical plant which has each of the manufacturing operations
covered by the subcategory and production that is the average
level of each operation in that subcategory. (The total produc-
tion for the core operation and for each ancillary operation in
the subcategory 'was divided by the number of plants in the sub-
category.) The normal plant flows are the characteristic produc-
tion times the production normalized flow allowance at each
option. In addition, a normal plant was assumed to operate 8
hours per day, 5 days per week, 50 weeks per year. Tables VIII-
12 to VIIIH7 present the composition of the normal plants for
each subcategory. The capital and annual costs generated for
each normal plant for the three options are presented in Table
NONWATER QUALITY ASPECTS
The elimination or reduction of one form of pollution may aggra-
vate other environmental problems. Therefore, Sections 304(b)
and 306 of the Act require EPA to consider the nonwater quality
environmental impacts (including energy requirements) of certain
regulations. In compliance with these provisions, EPA has con-
sidered the effect of this regulation on air pollution,.solid
waste generation, water scarcity, and energy consumption. This
897
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regulation was circulated to and reviewed by EPA personnel
responsible for nonwater quality environmental programs. While
it is difficult to balance pollution problems against each other
and against energy utilization, the Administrator has determined
that the impacts identified belo^ are justified by the benefits
associated with compliance with the limitations and standards.
The following are the nonwater quality environmental impacts
(including energy requirements) associated with compliance with
the aluminum forming regulation. ;
Air Pollution :
Imposition of BPT, BAT, NSPS, PSES, and PSNS will not create any
substantial air pollution problems because the wastewater treat-
ment technologies required to meet these limitations and
standards do not cause air pollution. ^
Solid Waste ;
EPA estimates that aluminum forming facilities generated 79,000
kkg (87,000 tons) of solid wastes (wet basis) in 1977 due to the
treatment of wastewater. These wastes were comprised of treat-
ment system sludges containing toxic metals, including chromium,
zinc, and cyanide; aluminum; and oil removed during oil skimming
and chemical emulsion breaking that contains toxic organics.
EPA estimates that BPT will contribute an additional 52 kkg (57
tons) per year of solid wastes over that which is currently being
generated by the aluminum forming industry. BAT and PSES will
increase these wastes by approximately 77 kkg (85 tons) per year
beyond BPT levels. These sludges will necessarily contain addi-
tional quantities (and concentrations) of toxic metal pollutants.
The normal plant was used to estimate the sludge generated at
NSPS and PSNS and is estimated to be a 3 percent increase over
BAT and PSES.
The Agency considered the solid wastes that would be generated at
aluminum forming plants by lime anjd settle treatment technologies
and believes that they are not hazardous under Section 3001 of
the Resource Conservation and Recovery Act (RCRA). This judgment
is made based on the recommended technology of lime precipita-
tion. By the addition of a small excess of lime during treat-
ment, similar sludges, specificalljy toxic metal bearing sludges
generated by other industries such as the iron and steel indus-
try, passed the EP toxicity test. See 40 CFR 261.24 (45 FR 33084
(May 19, 1980)).
The Agency requested specific data and information in response to
comments from three companies that claimed that aluminum forming
lime and settle treatment sludges should be classified as hazard-
898
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ous. The responses did not support their comments that solid
wastes generated by treatment of aluminum forming wastewater
would be classified as hazardous under RCRA. The Agency believes
that the proper treatment of this wastewater through the recom-
mended lime and settle treatment technology would create a non-
hazardous sludge. Since these aluminum forming solid wastes are
not believed to be hazardous, no estimates were made of costs for
disposing of them as hazardous wastes in accordance with RCRA
requirements.
Wastes which are not hazardous must be disposed of in a manner
that will not violate the open dumping prohibition of Section
4005. of RCRA. The Agency has calculated as part of the costs for
wastewater treatment the cost of hauling and disposing of addi--
tional wastes generated as a result of these requirements.
Only wastewater treatment sludge generated by cyanide treatment
is likely to be hazardous under the regulations implementing
subtitle C of RCRA. Wastewater sludge generated by cyanide
treatment of aluminum forming solution heat treatment contact
cooling water may contain cyanides and may exhibit extraction
procedure (EP) toxicity. Therefore, these wastes may require
disposal as a hazardous waste. Wastewater treatment sludge from
cyanide treatment of a process waste stream is generated sepa-
rately from lime and settle sludge and may be disposed of sepa-
rately. Disposal costs for these hazardous wastes were based on
$0.80 per gallon ($0.21 per liter). The disposal cost is based
on information obtained from a number of sources including a
study of battery manufacturing plants in 1981, comments received
on the proposed battery manufacturing regulation, and a study
performed by Charles River Associates, Inc., and the costs have
been updated to 1982 dollars. We estimate that five plants in
the category may need to have cyanide precipitation, generating
an estimated 3,200 kkg of potentially hazardous sludge. The
additional total annual disposal cost for this sludge is
$283,200.
Generators of these wastes must test the waste to determine if
the wastes meet any of the characteristics of hazardous waste.
See 40 CFR 262.11 (45 FR 12732-12733 (February 26, 1980)). The
Agency may also list these sludges as hazardous pursuant to 40
CFR 260.11 (45 FR 33121 (May 19, 1980)), as amended at 45 FR
76624 (November 19, 1980)).
If these wastes are identified as hazardous, they will come
within the scope of RCRA's "cradle-to-grave" hazardous waste man-
agement program, requiring regulation from the point of genera-
tion to point of final disposition. EPA's generator standards
would require generators of hazardous aluminum forming wastes to
meet containerization, labeling, recordkeeping, and reporting
899
-------
requirements. In addition, if;aluminum formers dispose of haz-
ardous wastes off-site, they would have to prepare a manifest
which would track the movement of the wastes from the generator's
premises to a permitted off-site treatment, storage, or disposal
facility. See 40 CFR 262.20 (45iFR 33142 (May 19, 1980)). The
transporter regulations require - transporters of hazardous wastes
to comply with the manifest system to assure that the wastes are
delivered to a permitted facility. See 40 CFR 263.20 (45 FR
33151 (May 19, 1980)), as amended at 45 FR 86973 (December 31,
1980)). Finally, RCRA regulations establish standards for haz-
ardous waste treatment, storage,'and disposal facilities allowed
to receive such wastes. See 40 CFR Parts 264 and 265.
Consumptive Water Loss ;
Treatment and control technologies that require extensive
recycling and reuse of water may require cooling mechanisms.
Evaporative cooling mechanisms can cause water loss and con-
tribute to water scarcity problems—a primary concern in arid and
semi-arid regions. While this regulation assumes water reuse,
the overall amount of reuse through evaporative cooling mecha-
nisms is low and the quantity of water involved is not signifi-
cant. In addition, most aluminum forming plants are located east
of the Mississippi where watfer scarcity is not a problem. We
conclude that the consumptive water loss is insignificant and
that the pollution reduction benefits of recycle technologies
outweigh their impact on consumptive water loss.
Energy Requirements
i
EPA estimates that the achievement of BPT effluent limitations
will result in a net increase in electrial energy consumption of
approximately 65 million kilowatt-hours per year. The BAT
effluent technology should not substantially increase the energy
requirements of BPT because reducing the flow reduces the pumping
requirements, the agitation requirement for mixing wastewater,
and other volume-related energy requirements. Therefore, the BAT
limitations are assumed to require an equivalent energy consump-
tion to that of the BPT limitations. To achieve the BPT and BAT
effluent limitations, a typical direct discharger will increase
total energy consumption by less than 1 percent of the energy
consumed for production purposes.
i
The Agency estimates that PSES will result in a net increase in
electrical energy consumption of approximately 50 million
kilowatt-hours per year. To achieve PSES, a typical existing
indirect discharger will increase energy consumption by less than
1 percent of the total energy consumed for production purposes.
9100
-------
NSPS will not significantly add to total energy consumption of
the energy. A normal plant for each subcategory was used to
estimate the energy requirements for new sources. A new source
wastewater treatment system will add approximately 1 million
kilowatt-hours per year to the total industry energy require-
ments. PSNS, like NSPS, will not significantly add to total
energy consumption.
901
-------
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Table VIII-3
OILY SLUDGE PRODUCTION ASSOCIATED WITH ALUMINUM FORMING
Operation
Direct chill casting
Continuous casting
Extrus ion
contact cooling
heat treatment contact
cooling
dummy block contact
cooling
die cleaning
Hot rolling oil
Etch line
acid rinse
deoxidant dip
deoxidant rinse
caustic rinse
water rinse
leveler rinse
scrubber
detergent rins-e
Forging heat treatment
contact cooling
Forging scrubber
Drawing oil
Drawing heat treatment
contact cooling
Cold rolling oil
Cold rolling heat treat-
ment contact cooling
Foil rolling oil
Oily Sludge
Production
(gal/1,000 gal)
0.2
0.2
0.07
0.08
0.14
Site-specific
0.07
0.32
Site-specific
Site-specific
Site-specific
909
-------
Tab;ie
LIME DOSAGE REQUIREMENTS AND LIME SLUDGE PRODUCTION
ASSOCIATED WITH ALUMINUM FORMING
Operation
Direct chill casting
Continuous casting
Extrusion
contact cooling
heat treatment contact
cooling
dummy block contact
cooling
die cleaning
Hot rolling oil
Etch line
acid rinse
deoxidant dip
deoxidant rinse
- caustic rinse
water rinse
leveler rinse
scrubber
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Forging heat treatment
contact cooling
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Drawing oil
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cooling •
Cold rolling oil
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contact cooling
Foil rolling oil
Lime
Dosage
(mg/1)
2,000
2,000
2,
2,
2,
2,
2,
2,
000
000
000
000
000
000
2,000
2,000
200
200
2,000
2,000
2,000
Lime Sludge
Production
(gal/1,000 gal)
46
38
63
63
63
63
63
63
63
63
6
6
38
38
38
-------
Table VIII-5
CARBON EXHAUSTION RATES ASSOCIATED WITH ALUMINUM FORMING
Operation
Direct chill casting
Continuous casting
Extrusion
contact cooling
heat treatment contact
cooling
dummy block contact
cooling
die cleaning
Hot rolling oil
Etch line
acid rinse
- deoxidant dip
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caustic rinse
water rinse
leveler rinse
scrubber
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Forging heat treatment
contact cooling
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Drawing oil
Drawing heat treatment
contact cooling
Cold rolling oil
Cold rolling heat treat-
ment contact cooling
Foil rolling oil
Carbon
Exhaustion Rate
(Ibs carbon/
1,000 gal)
2
2
0.5
10
0.
0.
0.
2
1
1
1
1
5
10
0.5
1 0
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10
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WASTEWATER SAMPLING FREQUENCY - POST-PROPOSAL
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Table VIII-10
COST PROGRAM POLLUTANT PARAMETERS
Parameter
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pH
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Ammon i a
Antimony
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945
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SECT-ION IX
BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
This section defines the effluent characteristics attainable
through the application of best practicable control technology
currently available (BPT), Section 301(b)(1)(A). BPT reflects
the existing performance by plants of various sizes, ages, and
manufacturing processes within the aluminum forming category, as
well as the established performance of the recommended BPT sys-
tems. Particular consideration is given to the treatment already
in place at plants within the data base.
The factors considered in identifying BPT include the total cost
of applying the technology in relation to the effluent reduction
benefits from such application, the age of. equipment and facili-
ties involved, the manufacturing processes employed, nonwater
quality environmental impacts (including energy requirements),
and other factors the Administrator considers appropriate. In
general, the BPT level represents the average of the best exist-
ing performances of plants of various ages, sizes, processes, or
other common characteristics. Where existing performance is uni-
formly inadequate, BPT may be transferred from a different sub-
category or category. Limitations based on transfer of technol-
ogy are supported by a rationale concluding that the technology
is, indeed, transferable, and a reasonable prediction that it
will be capable of achieving the prescribed effluent limits. See
Tanner's Council of America v. Train, 540 F.2d 1188 (4th Cir.
1976). BPT focuses on end-of-pipe treatment rather than process
changes or internal controls, except where such practices are
common industry practice.
TECHNICAL APPROACH TO BPT
The Agency studied the aluminum forming category to identify the
manufacturing processes used and wastewaters generated during
aluminum forming. Information was collected from industry using
data collection portfolios, and wastewaters from specific plants
were sampled and analyzed. The Agency used these data to sub-
categorize the operations and determine what constitutes an
appropriate BPT. The factors which were considered in establish-
ing subcategories are discussed fully in Section IV. Nonwater
quality impacts and energy requirements are considered in Section
VIII.
The category has been subcategorized, for the purpose of regula-
tion, on the basis of forming operations. On examining each of
these forming operations, several additional or subsidiary
processes were identified. To organize the principal forming
959
-------
process and subsidiary processes into a workable matrix for the
purpose of regulation, the primary forming process 'and subsidiary
operations usually associated with it at plants throughout the
industry have been grouped together in what is known as a core.
Additional subsidiary processes which may or may not be present
at a facility with a given core are called ancillary operations.
The basis of regulation at any facility is the set of core
operations plus those ancillary operations actually found at the
specific facility.
In making technical assessments of data, reviewing manufacturing
processes, and evaluating wastewater treatment technology
options, both indirect and direct dischargers have been consid-
ered as a single group. An examination of plants and processes
did not indicate any process differences based on the type of
discharge, whether it be direct or indirect. Hence, BPT is
described in substantial detail for direct discharge subcatego-
ries/ even though there may be no direct discharge plants in that
subcategory.
Wastewater produced by the deformation operations contains signi-
ficant concentrations of oil and grease, suspended solids, toxic
metals, and aluminum. Surface cleaning produces a rinse water in
which significant concentrations of oil and grease, suspended
solids, toxic metals, and aluminum are found. The other surface
treatment wastewaters have similar characteristics. Wastewater
from anodizing and conversion coating, which are considered as
cleaning or etching operations, also may contain chromium and
cyanide. Contact cooling water is associated with some methods
of casting and heat treatment and contains significant concentra-
tions of oil and grease, suspended solids, toxic metals,
aluminum, and cyanide.
BPT for the aluminum forming category is based upon common treat-
ment of combined streams within each subcategory. Sixty-five
percent of the aluminum forming plants with treatment combine
waste streams in a common treatment system. The BPT treatment is
similar throughout the category to the extent that oil and
grease, suspended solids, and metals removal are required within
each subcategory. The general, treatment scheme for BPT is to
apply oil skimming technology,.to ^remove ^oil and grease, followed
or combined with lime and sejs-ffle technology to remove metals and
solids from the combined wastewaters. Separate preliminary
treatment steps for chromium reduction, emulsion breaking, and
cyanide removal are utilized when required. The BPT effluent
concentrations are based on the performance of chemical precipi-
tation and sedimentation (lime and settle) when applied to a
broad range of metal-bearing wastewaters. The basis for lime and
settle performance is set forth in substantial detail in Section
VII. The BPT treatment train varies somewhat between subcatego-
960
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ries to take into account treatment of hexavalent chromium,
cyanide, and emulsified oils.
For each of the subcategories, a specific approach was followed
for the development of BPT mass limitations. To account for pro-
duction and flow variability from plant to plant, a unit . of
.production or production normalizing parameter (PNP) was deter-
mined for each waste stream which could then be related to the
flow from the process to determine a production normalized flow.
Selection of the PNP for each process element is discussed in
Section IV. Each process within the subcategory was then
analyzed to determine (1) whether or not operations included
generated wastewater, (2) specific flow rates generated, and (3)
specific production normalized flows for each process. This
analysis is discussed in general in Section V and summarized for
the core operations in each subcategory and for the ancillary
operations.
Whenever possible, the Agency establishes wastewater limitations
in terms of mass rather than concentration. The production nor-
malized wastewater flow (1/kkg or gal/ton) is a link between the
production operations and the effluent limitations. The pollu-
tant discharge attributable to each operation can be calculated
from the normalized flow and effluent concentration achievable by
the treatment technology.
Normalized flows were analyzed to determine which flow was to be
used as part of the basis for BPT mass limitations. The selected
flow (sometimes referred to as a BPT regulatory flow or BPT flow)
reflects the water use controls which are common practices within
the industry. The BPT normalized flow is based on the average of
all applicable data. Plants with existing flows above the
average may have to implement some method of flow reduction to
achieve the BPT normalized flow and thus the BPT limitations. In
most cases, this will involve improving housekeeping practices,
better maintenance to limit water leakage, or reducing excess
flow by turning down a flow valve. Except for the case of direct
chill casting which requires water recycle, it is not believed
that these modifications would incur any costs for the plants.
The BPT model treatment technology assumes that all wastewaters
generated within a subcategory were combined for treatment in a
single or common treatment system for that subcategory, even
though flow and sometimes pollutant characteristics of process
wastewater streams varied within the subcategory. A disadvantage
of common treatment is that some loss in pollutant removal effec-
tiveness will result where waste streams containing specific
pollutants at treatable levels are combined with other streams in
which these same pollutants are absent or present at very low
concentrations. Under these circumstances a plant may prefer to
961
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segregate these waste streams and bypass treatment. Since
treatment systems considered under BPT are primarily for metals,
oil and grease, and suspended solids removal, and many existing
plants usually had one common treatment system in place, a common
treatment system for each subcategory is reasonable in terms of
cost and effectiveness. Both treatment in place at aluminum
forming plants and treatment in other categories having similar
wastewaters were evaluated.
The overall effectiveness of end-of-pipe treatment for the
removal of wastewater pollutants is improved by the application
of water flow controls within the process to limit the volume of
wastewater requiring treatment. The controls or in-process tech-
nologies recommended under BPT include only those measures which
are commonly practiced within the category or subcategory and
which reduce flows to meet the production normalized flow for
each operation.
For the development of effluent limitations, mass loadings were
calculated for each operation within each subcategory. This
calculation was made on a process-by-process basis, primarily
because plants in this category may perform one or more of the
ancillary operations in conjunction with the core operations
present. The mass loadings (milligrams of pollutant per metric
ton of production unit - mg/kkg) were calculated by multiplying
the BPT normalized flow (1/kkg) by the concentration achievable
using the BPT model treatment system (mg/1) for each pollutant
parameter to be regulated under BPT.
Regulated Pollutant Parameters
Pollutant parameters are selected for regulation in the aluminum
forming subcategories because of their frequent presence at
treatable concentrations in raw wastewaters. Total suspended
solids, oil and grease, pH, chromium, zinc, aluminum, and cyanide
have been selected for regulation in each subcategory. Treatment
of wastewater from all subcategories is presumed for BPT and
therefore it is necessary to regulate (provide a discharge
allowance) for all regulated pollutants in each subcategory
wastewater discharge.
Total suspended solids, in addition to being present at high con-
centrations in raw wastewater from aluminum forming operations,
is an important control parameter for metals removal in chemical
precipitation and settling treatment systems. The metals are
precipitated as insoluble metal hydroxides, and effective solids
removal is required in order to ensure reduced levels of toxic
metals in the treatment system effluent. Total suspended solids
are also regulated as a conventional pollutant to be removed from
the wastewater prior to discharge.
962
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Oil and grease is regulated under BPT since a number of aluminum
forming operations (i.e., rolling with emulsions, roll grinding,
continuous rod casting, and drawing with emulsions) generate
emulsified wastewater streams which may be discharged. As seen
in Section V, several waste streams have high concentrations of
oil and grease. As will be discussed in detail in Section X, the
organic pollutants considered for regulation in Section VI are
soluble in the oil and grease fraction and are found associated
with the concentrated oily wastes. Data across oil and grease
treatment at sampled aluminum forming plants show that effec-
tively removing the oil also removes 97 percent of the toxic
organics (see Table X-21, p. 1106).
The importance of pH control is documented in Section VII (p.
701), and its importance in metals removal technology cannot be
over emphasized. Even small excursions from the optimum pH level
can result in less than optimum functioning of the system and
inability to achieve specified results. The optimum operating
level for most metals is usually found to be pH 8.8 to 9.3; when
aluminum is also being removed, the optimum pH may be as low as
7.5 to 8.0. To allow a reasonable operating margin and to
preclude the need for final pH adjustment, the effluent pH is
specified to be within the range of 7.0 to 10.
Total chromium is regulated since it includes both the hexavalent
and trivalent forms of chromium. Only the trivalent form is
removed by the lime and settle technology. Therefore, the hexa-
valent form must be reduced in order to meet the limitation on
total chromium in each subcategory. Chromium may be found at
high levels in wastewaters from anodizing and conversion coating
operations.
.Zinc has been selected for regulation under BPT since it and
chromium are the predominant toxic metals present in aluminum
forming wastewaters. The Agency believes that when these param-
eters are controlled with the application of chemical precipita-
tion and sedimentation, control of the other toxic metals is
assured.
Aluminum has been selected for regulation under BPT since it is
found at high concentrations in process wastewater streams from
aluminum forming facilities and since it is the metal being pro-
cessed, it is found in all aluminum forming process wastewaters.
Cyanide is being regulated because it was found in treatable
concentrations in two solution heat treatment contact cooling
water streams, one associated with a forging operation and the
other a drawing operation. Sampling data after proposal indicate
that cyanide was also present in one extrusion press heat treat-
ment contact cooling water stream. Data indicate that cyanide is
963
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sometimes used as a corrosion inhibitor in the heat treatment
operations. Since such corrosion inhibitors are not unique to
these three plants, cyanide is selected for regulation. However,
representatives of the industry have indicated that other process
chemicals can be used to replace cyanide in these operations.
Therefore, the most effective means for a plant to control
cyanide may be for that plant to merely avoid the use of cyanide.
A special monitoring provision for cyanide which allows for the
owner or operator of a plant to forego periodic analysis for
cyanide if certain conditions are met is included in this
regulation.
The wastewaters generated during coil coating of aluminum are
relatively similar to the wastewaters generated in aluminum
forming in that both wastewaters contain oil and grease, sus-
pended solids, toxic metals, aluminum, and sometimes cyanide.
Concentrations of pollutants may vary somewhat. For instance,
toxic metals and aluminum concentrations tend to be slightly
higher in coil coating wastewaters; however, in terms of treat-
ability, the characteristics of the wastewaters from aluminum
coil coating and aluminum forming are essentially similar, and
the same treatment should be equally effective when properly
applied to either. Eighteen aluminum forming plants reported
that they also do aluminum coil coating. Aluminum coil coating
is a subcategory of the coil coating point source category. To
simplify compliance with two regulations at these 18 plants, mass
limitations have been established for both categories based on
the application of the same treatment. Permissible discharge
would be calculated by simply adding the masses that may be
discharged for each category. In addition, the same pollutants
are limited for both aluminum coil coating and aluminum forming,
thus making it easier for plants to co-treat wastewaters from
these processes.
The Agency based the proposed limits for the pollutant aluminum
on data from one aluminum forming plant and one aluminum coil
coating plant. Since proposal the Agency sampled four additional
aluminum forming plants that treated wastewaters through lime and
settle treatment. Aluminum concentration data from two of these
plants were incorporated with the proposed data and the treatment
effectiveness concentrations for aluminum were revised. The
Agency did not use data from the other aluminum forming plants
sampled since proposal because they were improperly operating
their treatment systems. One plant had an effluent TSS concen-
tration coming out of the clarifier of greater than 50 mg/1 and
an effluent pH above 10.0. The effluent pH of the second plant
was below 7.0.
964
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ROLLING WITH NEAT OILS SUBCATEGORY
Production Operations and Discharge Flows
The primary
a rolling
production
annealing,
degreasing,
treatment,
listed in
operation in this subcategory is rolling aluminum in
mill using neat oil as a lubricant. Other ancillary
operations in this subcategory include roll grinding,
stationary casting, homogenizing, artificial aging,
sawing, continuous sheet casting, solution heat
and cleaning or etching. These unit operations were
Section IV (p. 151 ), along with the waste streams
generated by these operations and the production normalizing
parameters. Table IX-1 lists these production operations, sepa-
rating them into core and ancillary operations, and identifies
the production normalized wastewater flows generated from each.
The core allowance for the Rolling with Neat Oils Subcategory
without an annealing furnace scrubber is 55.31 1/kkg (13.27 gal/
ton). This one allowance represents the sum of the individual
allowances for the core waste streams which have a discharge
allowance. These streams are roll grinding spent emulsion,
sawing spent lubricant and miscellaneous nondescript wastewater
sources. The core allowance for the Rolling with Neat Oils
Subcategory with an annealing scrubber is 81.66 1/kkg (19.60 gal/
ton). This one allowance represents the sum • of the individual
allowances for the core waste streams 'listed above plus the
wastewater discharge allowance for the annealing scrubber liquor.
The following paragraphs discuss these operations and wastewater
discharge allowances.
Core Operations
Rolling with Neat Oils. The mineral oil (kerosene) based
lubricants used in neat oil rolling are recycled with sediment
removal or filtration. After extended use, the rolling oils are
periodically disposed of by reclamation or incineration. None of
the 50 plants rolling aluminum with neat oils reported any
discharge of these oils to surface waters or publicly owned
treatment works (POTW). For this reason, the production
operation has been assigned a zero wastewater discharge
allowance.
Roll Grinding. Nine facilities that perform emulsion roll
grinding were contacted; one did not supply enough information to
characterize the water use or discharge, and two achieved zero
discharge through complete recycle of the -roll grinding emul-
sions. The remaining six plants provided information about
either their water use or wastewater generation related to roll
grinding (see Table V-7 p. 210). The BPT discharge flow for this
stream is 5.50 1/kkg (2.2 gal/ton) of aluminum rolled, based on
965
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the mean normalized flow of the five plants which reported
discharge of this stream.
Annealing. As discussed in Section III (p. 110 ), the annealing
operation does not use process water. The annealing operation
has been included in the core of all six subcategories, because
it is not specifically associated with any of the major forming
processes (rolling, extruding, forging, drawing), it is a dry
operation and it can be found at plants throughout the category.
One of the plants surveyed in this study anneals aluminum which
is rolled with neat oils and derives the inert gas atmosphere
used in its annealing process from furnace off gases. Because of
the sulfur content of furnace fuels, the off gases require
cleaning with wet scrubbers to remove contaminants. The scrubber
used involves a large flow of water with more than 99 percent
recycle of the normalized flow and less than 1 percent blowdown.
The blowdown at this plant is 26.35 1/kkg (6.320 gal/ton).
Another plant visited by the Agency uses an electrostatic
precipitator on their annealing furnace. No flow data v/ere
available from this plant; however, it does generate a wastewater
discharge.
Because particulate removal is necessary to the operation of the
annealing furnace, an allowance has been included as part of the
core of the Rolling with Neat Oils Subcategory. Other plants
purchase cleaned gases or burn natural gas to provide an inert
atmosphere. These plants do not need any air pollution control
devices, therefore, the Agency has established two core
limitations for the Rolling with Neat Oils Subcategory. Because
most plants do not have an annealing scrubber liquor flow,
separate allowances will be established for core waste streams
without an annealing furnace scrubber and for core waste streams
with an annealing furnace scrubber.
The annealing scrubber liquor allowance has been included in the
core to maintain consistency in the regulation. For the other
five subcategories, all annealing operations are performed using
no process water and annealing has been assigned a zero pollutant
allowance and is included in the core.
Stationary Casting. In stationary casting, molten aluminum is
poured into specific shapes for rolling and further processing.
It was observed that in 14 plants that reported this operation,
stationary casting is performed without the discharge of any
contact cooling water. Frequently, the aluminum is allowed to
air cool and solidify. Often, the stationary molds are
internally cooled with noncontact cooling water. In some plants,
a small amount of water or mist is applied to the top of the
stationary cast aluminum to promote more rapid solidification and
allow earlier handling. In most cases, contact cooling water is
966
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either collected and recycled or it
stationary casting is included in the
Neat Oils Subcategory with no wastewater
evaporates. Therefore,
core of the Rolling with
discharge allowance.
Homogenizing. Homogenizing is a type of heat treatment to
control physical properties of the aluminum which frequently
follows casting. Two plants indicate the use of water to aid
final cooling after homogenizing; however, the water flow is very
small. Twenty-seven other plants performing homogenizing
reported no water use in this process. Therefore, no flow
allowance has been provided for this operation. Since
homogenizing is a zero discharge process, it is included in the
core of the Rolling with Neat Oils Subcategory with no wastewater
discharge allowance.
Artificial Aging. Artificial aging is a type of heat treatment
to control physical properties of the aluminum. Because the
process is a dry process, it is included in the core of the
Rolling with Neat Oils Subcategory with no wastewater discharge
allowance.
Degreasing. Thirty-four plants with solvent degreasing
operations were surveyed, and only two indicated having process
wastewater streams associated with the operation/ One facility
uses a water rinse after solvent degreasing, while the second
discharges solvent recovery sludge to the facility's oil
treatment system. Because 32 plants practice solvent degreasing
without wastewater discharge, the Agency believes zero discharge
of wastewater is an appropriate discharge allowance.
Spent degreasing solvents which are used in the aluminum forming
category have been listed as hazardous wastes from nonspecific
sources (45 FR 33123). If degreasing spent solvents are combined
with any other aluminum forming wastewaters and discharged, then
that discharge could be a hazardous waste and may become subject
to the requirements of the Resource Conservation and Recovery Act
(RCRA) (see 45 FR 33066). Thus, this waste should not be com-
bined with wastewater treatment sludges because disposal of the
combined discharge would be difficult and costly to achieve under
the RCRA requirements.
Sawing. Although the sawing operation is assumed to be present
at all facilities, only 12 plants specifically stated that they
perform this operation. Some of these plants reported using a
neat oil for lubrication, although emulsified lubricants are also
used. One plant reported no oils disposal due to evaporation and
carryover. Six other plants supplied wastewater discharge flow
data which were used to calculate a mean value of 4.807 1/kkg
(1.153 gal/ton) of aluminum rolled for the BPT discharge flow for
this stream (see Table V-29 p. 260).
967
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Miscellaneous Nondescript Wastewater Sources. A flow allowance
of 45.0 1/kkg (10.8 gal/ton) of aluminum processed through the
core operations is being established for miscellaneous
nondescript wastewater streams such as ultrasonic testing,
maintenance and clean-up, roll grinding of caster rolls, and seal
and dye baths when not followed by a rinse. These miscellaneous
wastewaters were observed during site visits and sampling visits
at some facilities and are characterized by intermittent, low
flow discharges. The flow allowance was calculated by averaging
three flow values of this waste stream submitted by industry/ two
are ultrasonic testing flows and one is a maintenance and clean-
up flow (see Table V-79 p. 460).
Ancillary Operations
Continuous Sheet Casting. Contact cooling water is not normally
used in continuous casting of aluminum sheet; however, lubricants
may be required in the associated smoothing roller. Fifteen
plants with continuous sheet or strip casting were surveyed;
seven reported no lubricants used, two claimed to achieve 100
percent recycle of lubricants without disposal, three indicated
periodic disposal of recycled material was necessary, and three
provided insufficient data. For the three plants reporting
disposal of the lubricant, the mean normalized discharge flow is
1.964 1/kkg (0.471 gal/ton) of aluminum cast; this is the BPT
wastewater discharge flow for the stream (see Table V-71 p. 429).
When a plant performs roll grinding of these caster rolls on
site, the discharge from that operation is covered by the
miscellaneous nondescript flow allowance.
Solution Heat
contain data
solution and
subcategories.
used does
therefore, the
7,705 1/kkg
solution heat
Treatment. Tables V-39 through V-49 (pp. 285-317)
taken from dcp's on the wastewater flow from
press heat treatment quenching for all the
It has been determined that the amount of water
not vary significantly between subcategories;
data are grouped, and the mean normalized flow of
(1,848 gal/ton) of aluminum quenched following
treatment is the BPT discharge flow.
Of the 89 heat treatment quenching processes surveyed, 52 report
no recycle of quench water, 25 recycle varying amounts of quench
water, and 12 claimed no discharge of this wastewater stream by
practicing total recycle. It is possible that the plants report-
ing no discharge of cooling water inadvertently failed to mention
necessary periodic blowdown of the cooling tower to prevent
solids accumulation. Since no technology for avoiding the
buildup of solids in completely recycled cooling water is known
to be applied in this category, only nonzero wastewater values
were used as a data base for selecting the BPT discharge flow.
968
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This includes plants that vary from
recycle.
no recycle to 99 percent
Cleaning or Etching. Cleaning or etching functions are performed
in approximately 20 percent of the rolling with neat oils
facilities. Wastewaters are or may be produced from three
segments of cleaning or etching operations. These are from
process baths, which are usually batch dumped; product rinsing;
and air pollution control scrubbing.
All of the subcategories include a wide range of cleaning or
etching operations including caustic baths and rinses, acid baths
and rinses, detergent baths and rinses, and conversion coating
and anodizing baths and rinses. The Agency has concluded that
these processes are similar in that a workpiece is placed in a
bath for the time necessary to obtain the desired result, removed
and rinsed to remove excess solution and undesired dragout from
the bath. In many cases, a workpiece is sequentially exposed to
several etch line baths and rinses. The generation of wastewater
from these operations is generally similar and any known differ-
ences have been taken into account by inclusion of all wastewater
generated by the entire cleaning and etching line. Separate
consideration of each and every possible cleaning and etching
operation would severely increase the complexity of the
regulation. Therefore, the Agency believes" that it is appropri-
ate to combine these operations into a single allowance.
The ancillary operation of cleaning or etching includes all
surface treatment operations, including chemical or electrochemi-
cal anodizing and conversion coating when performed as an inte-
gral part of the aluminum forming process. For the purposes of
this regulation, surface treatment of aluminum is considered to
be an integral part of aluminum forming whenever it is
at the same plant site where aluminum is formed.
etching operation is defined as a cleaning or
followed by a rinse. Multiple baths are considered multiple
cleaning or etching operations with a separate limitation for
each bath which is followed by a rinse. Multiple rinses follow-
ing a single bath will be regulated by a single limitation.
Process Baths. Of the 34 plants reporting cleaning or
etching operations, three indicated that the chemical baths
used for cleaning or etching of formed aluminum products are
discharged continuously into the wastewater from the rinsing
operation; 12 plants indicated that the process baths are
discharged periodically in a batch discharge mode; and 14
operate indefinitely without discharge by adding make-up
chemicals and water to offset the dragout loss from
processing. The remaining five plants supplied no
information about discharges from cleaning or etching baths.
performed
A cleaning or
etching bath
969
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While it is assumed that the majority of plants dispose of
the chemical bath by a solid waste contractor or eliminate
the bath in other ways, some plants do in fact treat and
discharge their process baths. For BPT, it is assumed that
the process baths will be periodically discharged to
treatment by bleeding them over a long period of time to
achieve an equal distribution of flow. Based on 16 flow
values from the 12 plants which reported a wastewater
?/!!£ /ge flow' a mean normalized discharge flow of 179
1/kkg (43 gal/ton) of aluminum etched is the flow allowance
for this stream. A summary of this data is presented in
Table V-52 (p. 326).
Product Rinses. A summary of water use and wastewater
discharge from product rinses is presented in Table V-55 (p
349). This shows that some plants discharge very small
volumes of wastewater even though their water use is
substantial. These data have been restructured in Table IX-
2 to more clearly show the rinse line characteristic of this
data. All plants with cleaning or etching operations
reported discharging their rinses. For the purpose of
establishing BPT limitations, all 44 data points were
averaged on a per-rinse-operation basis. ' The mean
^5iDal/Zed wastewater flow per rinsing operation is 13,912
1/kkg (3,339 gal/ton) of aluminum rinsed, which is the BPT
discharge flow for this stream.
Air Pollution Control Scrubbers. Seven plants surveyed
reported using wet air pollution control devices on cleaning
or etching operations. As presented in Table V-58 (p 391)
data were available to calculate normalized wastewater flows
from four of the seven plants, and the mean wastewater flow
is 15,900 1/kkg (3,816 gal/ton) of aluminum cleaned or
etched.
Pollutants
The pollutants considered for regulation under BPT are listed in
Section VI, along with an explanation of why they have been
selected. The pollutants selected for regulation under BPT are
chromium (total), cyanide (total), zinc, aluminum, oil and
grease, TSS, and pH. The toxic organic pollutants, cadmium,
copper, lead, nickel, and selenium, listed in Section VI are not
specifically regulated under BPT for the reasons explained in
Section X (p. 1058).
Table IX-3 lists the pollutants considered for regulation associ-
o u .Wlth each wastewater stream in the Rolling with Neat Oils
Subcategory and the corresponding maximum and minimum concentra-
tions detected for each pollutant.
970
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Treatment Train
The BPT model treatment train for the Rolling with Neat Oils
Subcategory consists of preliminary treatment when necessary,
specifically emulsion breaking and skimming, hexavalent chromium
reduction, and cyanide precipitation. The effluent from prelimi-
nary treatment is combined with other wastewaters for common
treatment by skimming and lime and settle. Sawing spent lubri-
cants, roll grinding spent emulsions, and casting spent lubri-
cants require emulsion breaking and skimming, and may require
hexavalent chromium reduction prior to combined treatment by
skimming and lime and settle. Solution heat treatment contact
cooling water may require cyanide precipitation, while cleaning
or etching wastewaters may require chromium reduction in addition
to cyanide precipitation. Following the preliminary treatment,
these wastewaters are then treated by oil skimming and lime and
settle. This treatment train is presented in Figure IX-1.
Cyanide precipitation is practiced on coil coating wastewaters at
six plants, two of which have both aluminum forming and aluminum
coil coating operations. Although it is not currently practiced
at plants which perform only aluminum forming operations, the
same cyanide and metallocyanide complexes would be present in
these wastewaters as in the coil coating wastewaters. These
wastewaters include heat treatment contact cooling water streams
and cleaning or etching (conversion coating) wastewater streams
which are subject to the aluminum forming regulation. The
cyanide precipitation technology demonstrated on coil coating
wastewater would be applicable to aluminum forming wastewaters.
The process, which is described in detail in Section VII (p.
706), involves the addition of ferrous sulfate heptahydrate and
pH adjustment chemicals to the raw wastewater in a rapid mix
tank. The resulting sludge is settled in a clarifier or other
settling device, and the treated water is routed to downstream
processing. Advantages of the cyanide precipitation process over
the conventional oxidation route are reported to include better
removal of complexed cyanide and significant cost savings.
Technology transfer of cyanide precipitation is justified because
existing treatment in the aluminum forming category is uniformly
inadequate since no plants are currently treating wastewaters
from aluminum forming with any cyanide removal technology. In
addition, as discussed previously in this section, the waste-
waters generated during coil coating of aluminum are similar to
the wastewaters generated in aluminum forming.
Transfer of cyanide precipitation technology from the coil coat-
ing category to the aluminum forming category is appropriate
because the cyanide is derived from processing aluminum in both
971
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categories and the raw wastewater matrices are homogeneous. The
homogeneity of these raw wastewaters has been tested during the
development of the combined metals data base and their
homogeneity confirmed. Full details of this examination are
presented in the administrative record of this rulemaking.
Data available to the Agency, discussed in Section VII (p. 706)
and presented in Table VII-8 (p. 795), indicate that the
application of cyanide precipitation technology can achieve the
cyanide treatment effectiveness concentration presented in Table
VII-20 (p. 807), even over a wide range of cyanide concentration
in the raw waste.
Effluent Limitations
Table VII-20 (p. 807), presents the treatment effectiveness
corresponding to the BPT model treatment train for pollutant
parameters considered in the Rolling with Neat Oils Subcategory.
Effluent concentrations (one day maximum and ten day average
values) are multiplied by the normalized discharge flows
summarized in Table IX-1 to calculate the mass of pollutants
allowed to be discharged per mass of product. The results of
these calculations are shown in Table IX-4.
Benefits
In establishing BPT, EPA must consider the cost of treatment and
control in relation to the effluent reduction benefits. BPT
costs and benefits are tabulated along with BAT costs and bene-
fits in Section X. As shown in Table X-3 (p. 1076), the applica-
tion of BPT to the total Rolling With Neat Oils Subcategory wi'll
remove approximately 1,725,611.3 kg/yr (3.796 million Ibs/yr) of
pollutants. As shown in Table X-l, (p. 1074), the corresponding
capital and annual costs (1982 dollars) for this removal are
$13.5 million and $10.7 million per year, respectively. As shown
in Table X-9 (p. 1089), the application of BPT to direct dis-
chargers only, will remove approximately 1,448,032.2 kg/yr (3.186
million Ibs/yr) of pollutants. As shown in Table X-2 (p. 1075),
the corresponding capital and annual costs (1982 dollars) for
this removal are $9.55 million and $8.20 million per year,
respectively. The Agency concludes that these pollutant removals
justify the costs incurred by plants in the Rolling with Neat
Oils Subcategory.
ROLLING WITH EMULSIONS SUBCATEGORY
Production Operations and Discharge Flows
The primary operation in this Subcategory is rolling aluminum in
a rolling mill using emulsified oil as a lubricant. Other sub-
972
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sidiary production operations in the subcategory include roll
grinding, annealing, stationary casting, homogenizing, artificial
aging, degreasing, sawing, direct chill casting, solution heat
treatment, and cleaning or etching. These unit operations were
tabulated with the waste streams generated and production normal-
ized parameters in Section IV (p. 154). Table IX-5 lists these
production operations, separating them into core and ancillary
operations, and identifies the production normalized wastewater
flows generated from each. The core allowance for the Rolling
with Emulsions Subcategory is 129.8 1/kkg (31.2 gal/ton). _..This
one allowance represents the sum of the individual _a_lJLow-an'ces for
the core waste streams which have a discharge "alTowance. These
streams are rolling with emulsions spent emulsions, roll grinding
spent emulsions, sawing spent lubricant and miscellaneous non-
descript wastewater sources. The following paragraphs discuss
these operations and wastewater discharge flows.
Core Operations
Rolling with Emulsions. The oil in water emulsion used as a
lubricant in many rolling operations is frequently discharged to
surface waters or a POTW. All of the 29 plants in this subcate-
gory recycle their emulsions. Five plants report recycle with a
continuous bleed, and the remaining plants dump their emulsions
periodically.
In selecting the BPT discharge flow appropriate for spent rolling
emulsions, a number of variables were analyzed for their effect
on the wastewater generated:
- Degree of recycle.
- Degree of reduction.
Product type.
- Annual production.
The data presented in Table V-4 (p. 196) show the production
normalized volume of spent lubricant which is discharged by the
plants in the Rolling with Emulsions Subcategory. The median
value is extremely small in comparison to the discharge flows
from the plants with higher production normalized discharges.
Therefore, the BPT discharge flow is based on the normalized mean
of all available data for spent rolling emulsions and is 74.51
1/kkg (17.87 gal/ton).
Recycle rates at plants with a bleed discharge varied from 85 to
99 percent. The remaining plants discharge periodically, imply-
ing recycle, but in most cases percent recycle values cannot be
assigned. Neither the degree of recycle nor the mode of dis-
charge significantly affected the normalized wastewater flow
distributions.
973
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Although most of the cold rolling operations surveyed use neat
oil lubricants, a few plants indicated the use of emulsions for
cold rolling operations. Analysis of the data showed that cold
rolling with emulsions results in discharge values comparable to
those associated with hot rolling processes. Normalized dis-
charge flows vary from plant to plant; especially high values
were noted at one plant for both their cold rolling and hot roll-
ing operations. Since the process itself may be considered to be
confidential, a thorough discussion of this data is precluded.
The data which are available suggest that the reduction of plate
to sheet or foil by emulsion cold rolling results in emulsion
discharge comparable to the amount discharged by the hot rolling
of ingot to plate. Discharge rates from these two operations are
compared below for the same plants:
Cold Rolled
Cold Roll
1/kkq
183.5
7.26
0.584
0.668
Discharge
qpt
44
1 .74
0.14
0.16
Product
Sheet
Sheet and
Sheet and
Sheet and
Foil
Foil
Foil
Hot Roll
1/kkq
304.4
0.392
89.4
Discharqe
qpt
73
0.094
21 .44
Therefore, the Agency is not distinguishing between cold rolling
emulsions and hot rolling emulsions to establish the BPT
normalized discharge flow.
Roll Grinding. Roll grinding is associated with virtually all
rolling operations and is, therefore, included in the core of the
Rolling with Emulsions Subcategory. This operation was described
previously in the discussion of rolling with neat oils. Roll
grinding operations and wastewater discharges are similar
throughout the industry; therefore, the same BPT technology and
normalized flow is applied to roll grinding in both rolling
subcategories.
Annealing. Annealing is a type of heat treatment which is often
associated with aluminum forming operations. The basic operation
is dry, although water can be used to clean furnace off gases.
In the Rolling with Emulsions Subcategory, no annealing operation
uses water for scrubbing; therefore, this stream is assigned a
zero discharge allowance and is included in the core for
regulatory convenience.
Stationary Casting. Stationary casting is similar throughout the
aluminum forming category, and no discharge of process wastewater
was ever reported. Therefore, stationary casting is included in
the core of the Rolling with Emulsions Subcategory with no
974
-------
wastewater discharge allowance. For a more detailed discussion,
refer to the Rolling with Neat Oils Subcategory description.
Homogenizing. Homogenizing is a heat treatment process that
frequently follows casting. For the reasons discussed previ-
ously, it has been assigned a zero discharge allowance and is,
therefore, included as a core stream in this subcategory.
Homogenization operations are similar throughout the industry.
For a more detailed description of the operation, refer to the
Rolling with Neat Oils Subcategory discussion.
Artificial Aging. Artificial aging, a common heat treatment,
does not generate process wastewater. Therefore, artificial
aging is included in the core of the Rolling with Emulsions
Subcategory as a regulatory convenience.
Deqreasing. All plants surveyed in this subcategory reporting
degreasing operations indicated that no wastewater is discharged;
therefore, this stream has no wastewater discharge allowance.
Degreasing operations are similar in all subcategories of the
industry. For a more detailed description of the operation,
refer to the Rolling with Neat Oils section.
Sawing. Sawing is assumed to be associated with all rolling
operations and has been included in the core of the Rolling with
Emulsions Subcategory. On the basis of available data, sawing
operations and lubricant discharge practices appear to be similar
throughout the aluminum forming category. For a description of
the normalized discharge flow associated with sawing, refer to
the Rolling with Neat Oils Subcategory description.
Miscellaneous Nondescript Wastewater Sources. An allowance for
miscellaneous wastewater sources is included in the core of each
subcategory. A description of this allowance and the BPT
discharge flow designated for these miscellaneous wastewater
sources was presented in the discussion of the Rolling with Neat
Oils Subcategory.
Ancillary Operations
Direct Chill Casting. At 20 of the 29 plants surveyed in the
Rolling with Emulsions Subcategory, aluminum is cast by the
direct chill method before it is rolled. As a regulatory con-
venience, direct chill casting has been designated as an ancil-
lary operation associated with this subcategory. In addition,
primary aluminum reduction plants and some secondary aluminum
plants covered by the nonferrous metals category use direct chill
casting. The direct chill casting process used in the aluminum
forming and primary aluminum plants is identical. Direct chill
casting has been included in the aluminum forming category as a
975
-------
regulatory convenience.
limitat'
Therefore, it is appropriate to consider
°m a11 the plants\n\hese categories
casting when establishing BPT effluent
»A 61 aiuminul!1 forming plants, 25 primary aluminum plants,
and five secondary aluminum plants have direct chill casting
dir^10"h-nThe ^ibution of wastewater rates associated with
AHA =L ^ casting is presented in Tables V-64 and V-65 (pp.
404 and 406, respectively). Recycle of the contact cooling
JnS »t? pr-?ctlced aV° Aluminum forming, nine primary aluminum?
3 2- I. f?!ve secondary aluminum plants. Of these, 13 plants
indicated that total recycle of this Stream made it possible t?
3T=id a"Y dlscharge of wastewater; however, the majority of the
plants discharge a bleed stream. The BPT discharge flow for this
SSrSiSSi-8 ^ed ?n the avera9e of the best, which is the aver-
age normalized discharge flow of the 23 plants with 90 percent
recycle or greater. That flow is 1,329 1/kkg (319 gal/ton) of
aluminum cast by direct chill methods. ^/^n, or
Hgat Treatment . Solution heat treatment is practiced by
^ aluminum forming subcategories. Solution
rultsn n/T^r5 rter <*uenchir>9 ^ the hot metal anS
results in substantial water use requirements. Due to the
similarity in Water use requirements among the various subcate-
gories, the water use data were combined and analyzed as a single
5? solution heat treatment operation Yand normalised
.flow .for the associated wastewater streams are
Subctegory1" Con:|unctlon with fche Rolling with Neat Oils
Cleaning or Etching. Cleaning or etching operations were
described in detail in the Rolling with Neat Oils sibcJtegSry
description. Wastewater streams associated with these operations
chemical baths, rinse water, and air pollution con?
' ^RefSr t0 Rollin9 with Neat Oils section for a
of these wastewater streams and discharge flows.
Pollutants
o
Section
considered for regulation under BPT are listed in
along with an explanation of why they have been
P°llutants selected for regulation unde? IPT ate
CnidH (t?tal)' ZinC' aluminum, oil and
u T . Th? toxic or9anic pollutants, cadmium,
nickel, and selenium, listed in Section VI are not
in
976
-------
Table IX-6 lists the pollutants considered for regulation
associated with each wastewater stream in the Rolling with
Emulsions Subcategory and the corresponding maximum and minimum
concentrations detected for each pollutant.
Treatment Train
The BPT model treatment train for the Rolling with Emulsions
Subcategory consists of preliminary treatment when necessary,
specifically emulsion breaking and skimming, hexavalent chromium
reduction, and cyanide precipitation. The effluent from prelimi-
nary treatment is combined with other wastewaters for common
treatment by oil skimming and lime and settle. Sawing spent
lubricant, roll grinding spent emulsions, and casting spent
lubricants require emulsion breaking and skimming, and may
require hexavalent chromium reduction prior to combined treatment
by skimming and lime and settle. Solution heat treatment contact
cooling water may require cyanide precipitation, while cleaning
or etching wastewaters may require chromium reduction in addition
to cyanide precipitation. Following the preliminary treatment,
these wastewaters are then treated by skimming and lime and
settle. This treatment train is presented in Figure IX-2.
Effluent Limitations
Table VII-20 (p. 807) presents the treatment effectiveness
corresponding to the BPT model treatment train for pollutant
parameters considered in the Rolling with Emulsions Subcategory.
Effluent concentrations (one day maximum and ten day average
values) are multiplied by the normalized discharge flows
summarized in Table IX-5 to calculate the mass of pollutants
allowed to be discharged per mass of product. The results of
these calculations are shown in Table IX-7.
Benefits
In establishing BPT, EPA must consider the cost of treatment and
control in relation to the effluent reduction benefits. BPT
costs and benefits are tabulated along with BAT costs and bene-
fits in Section X. As shown in Table X-4 (p. 1078), the applica-
tion of BPT to the total Rolling with Emulsions Subcategory will
remove approximately 12,300,000 kg/yr (2.7 million Ib/yr) of
pollutants. As shown in Table X-l (p. 1074), the corresponding
capital and annual costs (1982 dollars) for this removal are
$14.7 million and $15.2 million per year, respectively. As shown
in Table X-10 (p. 1091), the application of BPT to direct dis-
chargers only, will remove approximately 10,730,699.0 kg/yr
(23.607 million Ib/yr) of pollutants. As shown in Table X-2 (p.
1075), the corresponding capital and annual costs (1982 dollars)
for this removal are $13.96 million and $14.48 million per year
977
-------
respectively. The Agency concludes that these pollutant removals
justify the costs incurred by plants in the Rolling with
Emulsions Subcategory.
EXTRUSION SUBCATEGORY
Production Operations and Discharge Flows
The primary operation in this subcategory is extrusion, including
die cleaning and dummy block cooling operations. Other subsidi-
ary production operations in the subcategory include annealing,
stationary casting, homogenizing, artificial aging, degreasing,
sawing, direct chill casting, extrusion press hydraulic fluid
leakage, solution and press heat treatment, cleaning or etching,
and degassing. These unit operations were tabulated with the
waste streams generated and production normalized parameters in
Section IV (p. 156). Table IX-8 lists these production opera-
tions, separating them into core and ancillary operations, and
identifies the production normalized wastewater flows generated
from each. The core allowance for the Extrusion Subcategory is
363.82 1/kkg (87.4 gal/ton). This one allowance represents the
sum of the individual allowances for the core waste streams which
have a discharge allowance. These streams are extrusion die
cleaning bath, rinse and scrubber liquor, sawing spent lubricant,
and miscellaneous non-descript wastewater sources. The following
paragraphs discuss these operations and wastewater discharge
flows.
Core Operations
Extrusion Die Cleaning Bath and Rinse. The cleaning of extrusion
dies by immersion in caustic baths is described in Section III
(p. 101). Although most of the plants contacted discharge the
caustic bath (with or without treatment) to surface waters or a
POTW, the solution is hauled from at least four plants by an
outside contractor. Thirteen plants reported discharge rates as
shown in Table V-10 (p. 220). One plant reported no discharge of
the die cleaning bath, and 27 plants did not report enough data
to calculate a normalized discharge flow.
The volume of caustic required will depend on the intricacy of
the die orifice, the temperature of extrusion, the lubricant
used, and many other factors. Sufficient data are not available
to investigate these possibilities. Furthermore, it is likely
that the effect of individual plant practices (e.g., dumping
prior to saturation) may mask the effect of these factors.
Therefore, the mean normalized discharge flow, 12.9 1/kkg (3.096
gal/ton) of aluminum extruded, based on all 13 plants that dis-
charge die cleaning baths, has been chosen as the basis for BPT
limitations. In addition, any effect of these factors on the
978
-------
discharge flow is taken into account by the use of the 13 flow
values collected by industry.
As discussed in Section V (Table V-ll, p. 221), the wastewater
flows for extrusion die cleaning rinses are available for 13 of
the 37 plants known to have die cleaning operations. Of the 13
plants, one reports no discharge of die cleaning rinse water.
The normalized mean of the other 12 is 25.62 1/kkg (6.145
gal/ton).
Although many factors could influence the amount of water needed
for rinsing the dies, it appears that individual plant practices
are the most significant factor. Frequently, the dies are simply
hosed off, and the quantity of water used is not carefully con-
trolled. It is anticipated that plants discharging volumes
greater than the mean will be able to reduce the volume of water
discharged by applying tighter controls on the water used to
rinse the dies.
The normalized discharge flow for the BPT limitations of the com-
bined bath and rinse streams is the summation of the two means,
12.90 1/kkg and 25.62 1/kkg, which is 38.52 1/kkg (9.245
gal/ton).
Extrusion Die Cleaning Scrubber. A wet scrubber can be used to
control caustic fumes from the die cleaning bath. Although only
two plants with die cleaning baths reported scrubbers, it is
believed that most employ wet scrubbers. The two plants supplied
enough information to calculate a normalized discharge flow.
These flows were averaged to be 275.5 1/kkg (66.08 gal/ton) which
will be used as the BPT wastewater discharge flow.
Two plants reported the use of wet scrubbers at the extrusion
presses to remove caustic fumes. One of these scrubbers is
operated only when the die cleaning process is in operation and
serves to remove the caustic fumes generated by cleaning the
dies. This scrubber is considered an extrusion die cleaning
scrubber and will have the same flow allowance of 275.5 1/kkg.
The second scrubber operates at all times, although the die
cleaning process is in operation only intermittently. This
scrubber serves to remove fumes from various sources in the area
as well as the die cleaning caustic fumes. This scrubber is
considered an area scrubber as well as a die cleaning scrubber.
Because area scrubbers are included in the miscellaneous nonde-
script wastewater allowance, this scrubber will receive both flow
allowances: extrusion die cleaning scrubber liquor at 275.5
1/kkg and miscellaneous nondescript wastewater at 45 1/kkg.
979
-------
Dummy Block Cooling. Of the 163 plants that practice extrusion,
only three report discharge of a dummy block contact cooling
stream. Air cooling of the dummy blocks is used for cooling by
the vast majority of extrusion plants. For this reason, dummy
block contact cooling has been classified as a zero pollutant
discharge allowance stream.
Annealing. Annealing is a type of heat treatment which is often
associated with aluminum forming operations. The basic operation
is dry, although water can be used to clean furnace off gases.
In the Extrusion Subcategory, no annealing operation uses water
for scrubbing; therefore, this stream is assigned a zero
discharge allowance and is included in the core for regulatory
convenience.
Stationary Casting. Stationary casting is associated with most
of the aluminum forming subcategories and is designated as a zero
discharge operation. The operation is similar throughout the
industry and was never found to generate a wastewater stream.
Therefore, stationary casting is included in the core of the
Extrusion Subcategory with no wastewater discharge allowance.
For a more detailed description, refer to the discussion of
stationary casting operations associated with the Rolling with
Neat Oils Subcategory.
Homogenizing. Homogenizing is a heat treatment process that
frequently follows casting. For the reasons discussed previ-
ously, it has been assigned a zero discharge allowance and is,
therefore, included as a core stream in this Subcategory.
Homogenization operations are similar throughout the industry.
For a more detailed description of the operation, refer to the
Rolling with Neat Oils Subcategory discussion.
Artificial Aging. Artificial aging, a common heat treatment,
does not generate process wastewater. Therefore, artificial
aging is included in the core of the Extrusion Subcategory as a
regulatory convenience.
Degreasing. All of the extrusion plants surveyed which reported
having degreasing operations indicated that those operations
generated no wastewater discharge; therefore, this stream has no
wastewater discharge allowance. Degreasing operations are
similar in all subcategories of the industry. For a more
detailed description of the operation, refer to the Rolling with
Neat Oils Subcategory description.
Sawing. Because sawing is associated with extrusion operations,
it has been included in the core of the Extrusion Subcategory.
On the basis of available data, sawing operations and lubricant
discharge practices appear to be similar throughout the aluminum
980
-------
forming category. For a description of the normalized discharge
flow associated with sawing, refer to the Rolling with Neat Oils
Subcategory description.
Miscellaneous Nondescript Wastewater Sources. An allowance for
miscellaneous wastewater sources is included in the core of each
subcategory. A description- of this allowance and the BPT
discharge flow designated for these miscellaneous wastewater
sources was presented in the discussion of the Rolling with Neat
Oils Subcategory.
Ancillary Operations
Chill Casting. At 44 of the 163 plants surveyed in the
Extrusion Subcategory, aluminum is cast by the direct chill
method before extrusion. In addition, rolling with emulsions
plants as well as primary and secondary aluminum plants fre-
quently use direct chill casting. See the Rolling with Emulsions
Subcategory for a discussion of how the BPT discharge flow for
direct chill casting was determined.
Extrusion Press Hydraulic Fluid Leakage. Extrusion press
hydraulic fluids are used in extrusion presses. Neat oil
hydraulic fluids are most commonly used and are not discharged.
Oil-water emulsions are also used, primarily in conjunction with
the processing of hard aluminum alloys and for processing very
large extrusions. Five plants reported the use and wastewater
discharge of oil-water emulsion hydraulic fluids as shown in
Table V-75 (p. 436). Data and information collected during
engineering plant visits indicate that a flow allowance for this
wastewater source is necessary because emulsion hydraulic fluids
tend to leak thereby generating a wastewater source. A BPT
discharge flow allowance of 1,478 1/kkg (355 gal/ton) for this
waste stream is based on the average of the production normalized
flow data for the three plants that did not perform recycle.
This flow allowance is applicable when extrusion press hydraulic
fluid leakage is treated and discharged by a plant.
Solution and Press Heat Treatment. Solution heat treatment is
practiced by plants in all of the aluminum forming subcategories.
Solution heat treatment involves water quenching of the heated
metal and results in substantial water use requirements. Press
heat treatment is a water spray operation which cools the metal
immediately after extrusion. Water use for all heat treatment
contact cooling operations show the similarity in water use
requirements among solution and press heat treatment and the
various subcategories. Due to this similarity, the water use
data were combined and analyzed as a single data set. The
solution heat treatment operation and the normalized discharge
981
-------
flow for the associated wastewater stream are described in
conjunction with the Rolling with Neat Oils Subcategory.
Cleaning or Etching. Wastewater streams associated with cleaning
or etching operations may include chemical baths, rinse water,
and air pollution control scrubbers. Refer to the Rolling with
Neat Oils section for a description of these wastewater streams
and the associated discharge flows.
Degassing. In remelting aluminum prior to casting or continuous
casting/ it is sometimes necessary to remove significeint amounts
of magnesium or dissolved gases through the addition of chlorine
to the molten metal mass. When this is performed to remove
magnesium, it is called demagging and is a common refining
practice in the secondary aluminum industry. In the aluminum
forming industry, chlorine or inert gases are used to remove
dissolved gases in a similar operation called degassing, which
does not change the metal content of the melt. The degassing
processes and scrubber liquor wastewater characteristics are
similar for aluminum forming and primary aluminum plants.
Demagging is subject to the secondary aluminum effluent
limitations, while degassing is considered part of aluminum
forming when it is performed as an integral part of an aluminum
forming process.
Only one aluminum forming plant employs a wet scrubber for their
degassing operation, and no data are available to calculate that
discharge flow. Therefore, the BPT discharge flow for degassing
scrubber liquor blowdown is based on the mean normalized flow
from four primary aluminum subcategory plants using degassing
scrubbers and is 2,607 1/kkg (626 gal/ton) as shown in Table V-72
(p. 430).
Pollutants
The pollutants considered for regulation under BPT are listed in
Section VI, along with an explanation of why they have been
selected. The pollutants selected for regulation under BPT are
chromium (total), cyanide (total), zinc, aluminum, oil and
grease, TSS, and pH. The toxic organic pollutants, cadmium,
copper, lead, nickel, and selenium, listed in Section VI are not
specifically regulated under BPT for the reasons explained in
Section X (p. 1058).
Table IX-9 lists the pollutants considered for regulation associ-
ated with each wastewater stream in the Extrusion Subcategory and
the corresponding maximum and minimum concentrations detected for
each pollutant.
982
-------
Treatment Train
The BPT model treatment train for the Extrusion Subcategory
consists of preliminary treatment when necessary, specifically
emulsion breaking and skimming, hexavalent chromium reduction,
and cyanide precipitation. The effluent from preliminary treat-
ment is combined with other wastewaters for common treatment by
skimming and lime and settle. Sawing spent lubricants require
emulsion breaking and skimming and may require hexavalent chro-
mium reduction prior to combined treatment by skimming and lime
and settle. Solution and press heat treatment contact cooling
water may require cyanide precipitation, while cleaning or
etching and die cleaning wastewaters may require chromium reduc-
tion in addition to cyanide precipitation. Following the prelim-
inary treatment, these wastewaters are then treated by skimming
and lime and settle. This treatment train is presented in Figure
IX-3.
Effluent Limitations
Table VI1-21 (p. 807) presents the treatment effectiveness
corresponding to the BPT model treatment train for pollutant
parameters considered in the Extrusion Subcategory. Effluent
concentrations (one day maximum and ten day average values) are
multiplied by the normalized discharge flows summarized in Table
IX-8 to calculate the mass of pollutants allowed to be discharged
per mass of product. The results of these calculations are shown
in Table IX-10.
Benefits
In establishing BPT, EPA must consider the cost of treatment and
control in relation to the effluent reduction benefits. BPT
costs and benefits are tabulated along with BAT costs and bene-
fits in Section X. As shown in Table X-5 (p. 1080), the applica-
tion of BPT to the total Extrusion Subcategory will remove
approximately 4,207,477.7 kg/yr (9.26 million Ib/yr) of pollu-
tants. As shown in Table X-l (p. 1074), the corresponding
capital and annual costs (1982 dollars) for this removal are
$34.6 million and $25.5 million per year, respectively. As shown
in Table X-l1 (p. 1093), the application of BPT to direct
dischargers only, will remove approximately 2,831,772.1 kg/yr
(6.23 million Ib/yr) of pollutants. As shown in Table X-2 (p.
1075), the corresponding capital and annual costs (1982 dollars)
for this removal are $21.1 million and $13.0 million per year,
respectively. The Agency concludes that these pollutant removals
justify the costs incurred by plants in the Extrusion
Subcategory.
983
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FORGING SUBCATEGORY
There are no direct discharging facilities which use forging
processes to form aluminum. Consequently, the Agency is exclud-
ing the Forging Subcategory from this regulation for existing
direct dischargers (BPT and BAT). The discussion which follows
is presented for consistency and completeness. In addition, this
discussion forms the basis for pretreatment standards for the
Forging Subcategory presented in Section XII.
Production Operations and Discharge Flows
The production operations that may be present at a forging plant
include forging, annealing, artificial aging, degreasing, sawing,
forging scrubbing, solution heat treatment, and cleaning or etch-
ing. These unit operations were tabulated with the waste streams
generated and production normalizing parameters in Section IV (p.
158). Table IX-11 lists these production operations, separating
them into core and ancillary operations, and identifies the
production normalized wastewater flows generated from each. The
core allowance for the Forging Subcategory is 49.8 1/kkg (11.95
gal/ton). This one allowance represents the sum of the
individual allowances for the core waste streams which have a
discharge allowance. These streams are sawing spent lubricant
and miscellaneous non-descript wastewater sources. The following
paragraphs discuss these operations and wastewater discharge
flows.
Core Operations
Forging. As discussed in Section III (p. 102), the forging
process itself does not use any process water; therefore, forging
is assigned a zero discharge allowance and is included in the
core for regulatory convenience.
Annealing. Annealing is a type of heat treatment which is often
associated with all aluminum forming operations. The basic
operation is dry, although water can be used to clean furnace off
gases. In the Forging Subcategory, no annealing operation uses
water for scrubbing; therefore, this stream is assigned a zero
discharge allowance and is included in the core for regulatory
convenience.
Artificial Aging. Artificial aging, a common heat treatment,
does not generate wastewater. Therefore, artificial aging is
included in the core of the Forging Subcategory as a regulatory
convenience.
Degreasinq. All plants reporting degreasing operations indicated
that no wastewater is discharged; therefore, this stream has no
984
-------
wastewater discharge allowance. Degreasing operations are
similar in all subcategories of the industry. For a more
detailed description of the operation, refer to the Rolling with
Neat Oils section.
Sawing. Because sawing can be associated with forging opera-
tions, it has been included in the core of the Forging Subcate-
gory. On the basis of available data, sawing operations and
lubricant discharge practices appear to be similar throughout the
aluminum forming category. For a description of the normalized
discharge flow associated with sawing, refer to the previous
discussion in the Rolling with Neat Oils section.
Miscellaneous Nondescript Wastewater Sources. An allowance for
miscellaneous wastewater sources is included in the core of each
subcategory. A description of this allowance and the BPT dis-
charge flow designated for these miscellaneous wastwater sources
was presented previously in the discussion of the Rolling with
Neat Oils Subcategory.
Ancillary Operations
Forging Scrubbing. Particulates and smoke are generated from the
partial combustion of oil-based lubricants used in the forging
process. Of the 16 forging plants surveyed, four indicated that
wet scrubbers are used to control the emissions associated with
this process. Three of these plants reported discharge rates for
the scrubber blowdown. Three indicated that dry air pollution
control devices are employed. The mean normalized discharge flow
from three wet scrubbers, 1,547 1/kkg (371.0 gal/ton), has been
selected as the BPT discharge flow for the forging scrubber
liquor stream.
Solution Heat Treatment. Solution heat treatment is practiced by
plants in all of the aluminum forming subcategories. Solution
heat treatment involves water quenching of the hot metal and
results in substantial water use requirements. Due to the
similarity in water use requirements among the various
subcategories, the water use data were combined and analyzed as a
single data set. The solution heat treatment operation and the
BPT normalized discharge flow for the associated wastewater
stream are , described in conjunction with the Rolling with Neat
Oils Subcategory.
Cleaning or Etching. Wastewater streams associated with cleaning
or etching operations may include chemical baths, rinse water,
and air pollution control scrubbers. Refer to the Rolling with
Neat Oils section for a description of these wastewater streams
and the associated BPT discharge flows.
985
-------
Pollutants
The pollutants considered for regulation under BPT are listed in
Section VI, along with an explanation of why they have been
selected. The pollutants selected for regulation under BPT are
chromium (total), cyanide (total), zinc, aluminum, oil and
grease, TSS, and pH. The toxic organic pollutants, cadmium,
copper, lead, nickel, and selenium, listed in Section VI are not
specifically regulated under BPT for the reasons explained in
Section X (p. 1058) .
Table IX-12 lists the pollutants considered for regulation asso-
ciated with each wastewater stream in the Forging Subcategory and
the corresponding maximum and minimum concentrations detected for
each pollutant.
Treatment Train
The BPT model treatment train for the Forging Subcategory con-
sists of preliminary treatment when necessary, specifically
emulsion breaking and skimming, hexavalent chromium reduction,
and cyanide precipitation. The effluent from preliminary treat-
ment is combined with other wastewaters for common treatment by
skimming and lime and settle. Sawing spent lubricants require
emulsion breaking and skimming and may require hexavale;nt
chromium reduction prior to combined treatment by skimming and
lime and settle. Solution heat treatment contact cooling water
may require cyanide precipitation, while cleaning or etching and
forging scrubber wastewaters may require chromium reduction in
addition to cyanide precipitation. Following the preliminary
treatment, these wastewaters are then treated by skimming and
lime and settle. The treatment train is presented in Figure IX-
4.
Effluent Limitations
Table VII-20 (p. 807) presents the treatment effectiveness of BPT
model treatment train for pollutant parameters considered in the
Forging Subcategory. Effluent concentrations (one day maximum
and ten day average values) are multiplied by the normalized
discharge flows summarized in Table IX-11 to calculate the mass
of pollutants allowed to be discharged per mass of product. The
results of these calculations are shown in Table IX-13.
Benefits
BPT level costs and benefits are tabulated along with BAT costs
and benefits in Section X. As shown in Table X-6 (p. 1082), the
application of BPT level technology to the total Forging
Subcategory will remove approximately 767,120.6 kg/yr (1.688
986
-------
million Ib/yr) of pollutants. As shown in Table X-l (p. 1074),
the corresponding capital and annual costs (1982 dollars) for
this removal are $11.45 million and $8.28 million per year,
respectively.
DRAWING WITH NEAT OILS SUBCATEGORY
Production Operations and Discharge Flows
The primary operation in this subcategory is drawing aluminum
using neat oil as a lubricant. Other subsidiary production oper-
ations in this subcategory include annealing, stationary casting,
homogenizing, artificial aging, degreasing, sawing, swaging,
continuous rod casting, solution heat treatment, and cleaning or
etching. These unit operations were tabulated with the waste
streams generated and production normalizing parameters in Sec-
tion IV (p. 160). Table IX-14 lists these production operations,
separating them into core and ancillary operations, and identi-
fies the production normalized wastewater flows generated from
each. The core allowance for the Drawing with Neat Oils
Subcategory is 49.8 1/kkg (11.95 gal/ton). This one allowance
represents the sum of the individual allowances for the core
waste streams which have a discharge allowance. These streams
are sawing spent lubricants and miscellaneous nondescript
wastewater sources. The following paragraphs discuss these
operations and wastewater discharge flows.
Core Operations
Drawing with Neat Oils. Of the 64 plants using neat oils as
drawing lubricants, none were found to discharge this oil either
directly or indirectly. The most common practice appears to be
filtration and recycle. Frequently, carryover is the only method
of disposal, but in other cases the oil is periodically disposed
of either to a contractor or an incinerator. A number of tele-
phone contacts with industry and trade associations confirmed
this information. Because no plants are known to be discharging
drawing neat oils to receiving waters or a POTW, the stream has
been assigned a zero discharge allowance.
Annealing. Annealing is a type of heat treatment which is often
associated with aluminum forming operations. The basic operation
is dry, although water can be used to clean furnace off gases.
In the Drawing with Neat Oils Subcategory, no annealing operation
uses water for scrubbing; therefore, this stream is assigned a
zero discharge allowance and is included in the core for
regulatory convenience.
Stationary Casting. Stationary casting is associated with most
of the aluminum forming subcategories and is designed as a zero
987
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discharge process. The operation is similar throughout the
industry and was never found to generate a wastewater stream.
Therefore, stationary casting is included in the core of the
Drawing with Neat Oils Subcategory with no wastewater discharge
allowance. For a more detailed description, refer to the
discussion of stationary casting operations associated with the
Rolling with Neat Oils Subcategory.
Homogenizing. Homogenizing is a heat treatment process that
frequently follows casting. For the reasons discussed previ-
ously, it has been assigned a zero discharge allowance and is,
therefore, included as a core stream in this Subcategory.
Homogenization operations are similar throughout the industry.
For a more detailed description of the operation, refer to the
Rolling with Neat Oils Subcategory discussion.
Artificial Aging. Artificial aging, a common heat treatment,
does not generate wastewater. Therefore, artificial aging is
included in the core of the Drawing with Neat Oils Subcategory as
a regulatory convenience.
Degreasinq. All plants in this Subcategory reporting degreasing
operations indicated that no wastewater is discharged; therefore,
this stream has no wastewater discharge allowance. Degreasing
operations are similar in all subcategories of the industry. For
a more detailed description of the operation, refer to the
Rolling with Neat Oils section.
>awinq. Because sawing is typically associated with drawing
Derations, it has been included in the core of the Drawing with
i,,.dt Oils Subcategory. On the basis of available data, sawing
operations and lubricant discharge practices appear to be similar
throughout the aluminum forming category. For a description of
the normalized discharge flow associated with sawing, refer to
the previous discussion in the Rolling with Neat Oils section.
Sw 4*vj. Swaging operations point the end of tube or wire to
prepute it for drawing. Although swaging may require lubricants,
no r"^nt was found to discharge wastewater from this operation.
Therefore, zero
appropriate.
discharge of wastewater is considered
Miscellaneous Nondescript Wastewater Sources. An allowance for
•'scellaneous wastewater sources is included in the core of each
^ubcategory. A description of this allowance and the BPT
^'.scharge flow designated for these miscellaneous wastewater
sources was presented previously in the discussion of the Rolling
'••'ith Neat Oils Subcategory.
988
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Ancillary Operations
Continuous Rod Casting Cooling. A method of casting rod in
preparation for drawing is continuous casting. A stream of water
is circulated through the casting wheel to cool the molten
aluminum as it is cast. This water is in theory noncontact
cooling water; however, many of the plant personnel contacted
have indicated that it is impossible to prevent the water from
coming into contact with the product. Only one of the aluminum
forming plants surveyed supplied sufficient information to
calculate a production normalized flow. The BPT normalized flow,
1,555 1/kkg (249.9 gal/ton) of aluminum cast is based on these
data, as shown in Table V-68 (p. 426).
Data obtained from dcp's .for primary aluminum plants were subse-
quently considered. Two plants provided sufficient information
to calculate a discharge flow. One plant reported a production
normalized discharge flow of 415 1/kkg and the other 11.3 1/kkg.
Both of the primary aluminum plants employ a high degree of
recycle (99 percent). The former plant uses approximately the
same amount of water as the single aluminum forming plant. The
latter plant uses approximately 40 times as much water as the
other two plants. There is no apparent reason to believe that
the casting operations at these three plants are different and
that they would require significantly differing amounts of water.
As such, the Agency believes that the primary aluminum data
support the selection of the BPT normalized flow based on the
aluminum forming data.
Continuous Rod Casting Lubricant. An emulsion is used as a
lubricant for rolling of aluminum rod, part of the rod casting
process, and not to be confused with the Rolling with Emulsions
Subcategory. Of the three plants with continuous rod casting
operations, one reported 100 percent recycle of their lubricants
without discharge, and two plants periodically dispose of this
waste stream with contractor hauling. Neither of these two
plants reported sufficient information to calculate a discharge
flow. The Agency has transferred the normalized discharge flow
for continuous sheet casting lubricant, 1.9 1/kkg (0.442 gal/ton)
of aluminum cast to apply to continous rod casting. The Agency
believes these processes are similar and the amount of lubricant
required per pound of sheet cast is comparable to the lubricant
used per pound of rod produced.
Solution Heat Treatment. Solution heat treatment is practiced by
plants in all of the aluminum forming subcategories. Solution
heat treating involves water quenching of the heated metal and
results in substantial water use requirements. Due to the
similarity in water use requirements among the various
subcategories, the water use data were combined and analyzed as a
989
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single data set. The solution heat treatment operation and the
BPT normalized data flow for the associated wastewater stream are
described in conjunction with the Rolling with Neat Oils
Subcategory.
Cleaning or Etching. Wastewater streams associated with cleaning
or etching operations may include chemical baths, rinse water,
and air pollution control scrubbers. Refer to the Rolling with
Neat Oils section for a description of these wastewater streams
and the associated BPT discharge flows.
Pollutants
The pollutants considered for regulation under BPT are listed in
Section VI, along with an explanation of why they have been
selected. The pollutants selected for regulation under BPT are
chromium (total), cyanide (total), zinc, aluminum, oil and
grease, TSS, and pH. The toxic organic pollutants, cadmium,
copper, lead, nickel, and selenium, listed in Section VI are not
regulated under BPT for the reasons explained in Section X (p.
1058).
Table IX-15 lists the pollutants considered for regulation
associated with each wastewater stream in the Drawing with Neat
Oils Subcategory and the corresponding maximum and minimum
concentrations detected for each pollutant.
Treatment Train
The BPT model treatment train for the Drawing with Neat Oils
Subcategory consists of preliminary treatment when necessary,
specifically emulsion breaking and skimming, hexavalent chromium
reduction, and cyanide precipitation. The effluent from prelimi-
nary treatment is combined with other wastewaters for common
treatment by skimming and lime and settle. Sawing spent lubri-
cants require emulsion breaking and skimming and may require
hexavalent chromium reduction prior to combined treatment by
skimming and lime and settle. Solution heat treatment contact
cooling water may require cyanide precipitation, while cleaning
or etching wastewaters may require chromium reduction in addition
to cyanide precipitation. Following the preliminary treatment,
these wastewaters are then treated by skimming and lime and
settle. The treatment train is presented in Figure IX-5.
Effluent Limitations
Table VII-20 (p. 807) presents the treatment effectiveness of the
BPT model treatment train for pollutant parameters considered in
the Drawing with Neat Oils Subcategory. Effluent concentrations
(one day maximum and ten day average values) are multiplied by
990
-------
the normalized discharge flows summarized in Table IX-14 to
calculate the mass of pollutants allowed to be discharged per
mass of product. The results of these calculations are shown in
Table IX-16.
Benefits
In establishing BPT, EPA must consider the cost of treatment and
control in relation to the effluent reduction benefits. BPT
costs and benefits are tabulated along with BAT costs and bene-
fits in Section X. As shown in Table X-7 (p. 1085), the applica-
tion of BPT to the total Drawing with Neat Oils Subcategory will
remove approximately 756,582.6 kg/yr (1.664 million Ib/yr) of
pollutants. As shown in Table X-l (p. 1074), the corresponding
capital and annual costs (1982 dollars) for this removal are
$4.69 million and $2.94 million per year, respectively. As shown
in Table X-l2 (p. 1095), the application of BPT to direct dis-
chargers only, will remove approximately 536,194.5 kg/yr (1.180
million Ib/yr) of pollutants. As shown in Table X-2 (p. 1075),
the corresponding capital and annual costs (1982 dollars) for
this removal are $3.03 million and $1.75 million per year,
respectively. The Agency concludes that these pollutant removals
justify the costs incurred by plants in the Drawing with Neat
Oils Subcategory.
DRAWING WITH EMULSIONS OR SOAPS SUBCATEGORY
Production Operations and Discharge Flows
The primary operation in this Subcategory is drawing aluminum
using emulsified oil or soap as a lubricant. Other subsidiary
production operations in this Subcategory include annealing,
stationary casting, homogenizing, artificial aging, degreasing,
sawing, continuous rod casting, solution heat treatment, and
cleaning or etching. These unit operations were tabulated with
the waste streams generated and production normalizing parameters
in Section IV (p. 162). Table IX-17 lists these production
operations, separating them into core and ancillary operations,
and identifies the production normalized wastewater flows
generated from each. The core allowance for the Drawing with
Emulsions or Soaps Subcategory is 466.3 1/kkg (111.9 gal/ton).
This one allowance represents the sum of the individual
allowances for the core waste streams which have a discharge
allowance. These streams are drawing with emulsions or soaps
spent lubricants, sawing spent lubricants and miscellaneous non-
descript wastewater sources. The following paragraphs discuss
these operations and wastewater discharge flows.
991
-------
Core Operations
Drawing with Emulsions or Soaps. Of the 13 plants which use
emulsions or soap solutions for drawing, eight provided enough
data to calculate normalized discharge flows. Table IX-18 shows
the wide range of values.
Surface area of product, or wire gauge, is one factor that
affects water use. However, there are also many other factors,
including wire hardness, reduction in diameter per die stage,
drawing speed, alloys used, and mechanisms for recovering and
reusing the lubricant. The Agency examined the dcp information
and found that there are plants that draw fine wire gauges and
are currently meeting the BPT flows and limitations; thus, it is
demonstrated that plants drawing fine wire are able to meet the
limitations and flows.
Comparison of Table V-26 (p. 254) and Table IX-18 shows that
plant 8 does not recycle its soap solutions, while plant 6 does
recycle soap solutions. This partially explains the extremely
large wastewater flow of plant 8 and is the reason for eliminat-
ing plant 8's flow from the mean flow calculation. A comparison
of wastewater from plant 6 using soap as a lubricant and waste-
water from other plants using emulsions shows that the type of
lubricant does not seem to influence the lubricant normalized
discharge flow.
The mean normalized discharge flow of the six plants that recycle
and discharge drawing emulsions has been chosen as the basis of
BPT, 416.5 1/kkg (99.89 gal/ton) of aluminum drawn.
Annealing. Annealing is a type of heat treatment which is often
associated with all aluminum forming operations. The basic
operation is dry, although water can be used to clean furnace off
gases. In the Drawing with Emulsions or Soaps Subcategory, no
annealing operation uses water for scrubbing; therefore, this
stream is assigned a zero discharge allowance and is included as
a core stream for regulatory convenience.
Stationary Casting. Stationary casting is associated with most.
of the aluminum forming subcategories and is designed as a zero
discharge operation. The operation is similar throughout the
industry and was never found to generate a wastewater stream.
Stationary casting is, therefore, included in the core of the
Drawing with Emulsions or Soaps Subcategory with no wastewater
discharge allowance. For a further description, refer to the
discussion of stationary casting operations associated with the
Rolling with Neat Oils Subcategory.
992
-------
Homogenizing. Homogenizing is a heat treatment process that
frequently follows casting. For the reasons discussed previ-
ously, it has been assigned a zero discharge allowance and is
therefore, included as a core stream in this Subcategory!
Homogenization operations are similar throughout the industry
For a more detailed description of the operation, refer to the
Rolling with Neat Oils Subcategory discussion.
Artificial Aging. Artificial aging, a common heat treatment
does not generate wastewater. Therefore, artificial aging is
included in the core of the Drawing with Emulsions or Soaps
Subcategory as a regulatory convenience.
Degreasing. All plants surveyed in this Subcategory reporting
degreasing operations indicated that no wastewater is discharged-
therefore, this stream has no wastewater discharge allowance'
Degreasing operations are similar in all subcategories of the
industry. For a more detailed description of the operation,
refer to the Rolling with Neat Oils section. "tion,
Sawing. Because sawing is typically associated with drawing
operations, it has been included in the core of the Drawing with
Emulsions or Soaps Subcategory. On the basis of available data
sawing operations and lubricant discharge practices appear to be
similar throughout the aluminum forming category. For a descrip-
tion of the normalized discharge flow associated with sawing
reier to the previous discussion under Rolling with Neat Oils.
Swaging. Swaging operations point the end of tube or wire to
prepare it for drawing. Although swaging may require lubricants
no plant was found to discharge wastewater from this operation
Therefore, zero discharge of wastewater is considered appropri-
Miscellaneous Nondescript Wastewater Sources. An allowance for
miscellaneous wastewater sources is included in the core of each
Subcategory. A description of this allowance and the BPT
discharge flow designated for these miscellaneous wastewater
sources was presented in the discussion of the Rolling with Neat
Oils Subcategory.
Ancillary Operations
in
Continuous Rod Casting Cooling. Rod casting forms the metal m
preparation for rolling or drawing. In the process, cooling
water is circulated through the casting wheel and often contacts
the molten metal. As discussed in the Drawing with Neat Oils
section only one plant supplied sufficient information to
calculate a normalized flow which is designated the BPT discharge
flow of 1,042 1/kkg (249.9 gal/ton) of aluminum cast.
993
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Continuous Rod Casting Lubricant. Part of the rod casting
process involves rolling the cast aluminum with an emulsion as a
lubricant. Of the three plants with continuous rod casting oper-
ations, one reported 100 percent recycle of lubricants, and two
plants periodically dispose of this waste stream with contractor
hauling. As discussed in the Drawing with Neat Oils section, it
is assumed that the discharge flow is equal to that of continuous
sheet casting lubricant, 1.843 1/kkg (0.442 gal/ton) of aluminum
cast.
Solution Heat Treatment. Solution heat treatment is practiced by
plants in all of the aluminum forming subcategories. Solution
heat treating involves water quenching of the heated metal and
results in substantial water use requirements. Due to the
similarity in water use requirements among the various
subcategories, the water use data were combined and analyzed as a
single data set. The solution heat treatment operation and the
BPT normalized data flow for the associated wastewater stream are
described in conjunction with the Rolling with Neat Oils
Subcategory.
Cleaning O£ Etching. Wastewater streams associated with cleaning
or etching operations may include chemical baths, rinse water,
and air pollution control scrubbers. Refer to the Rolling with
Neat Oils section for a description of these wastewater streams
and the associated BPT discharge flows.
Pollutants
The pollutants considered for regulation under BPT are listed in
Section VI, along with an explanation of why they have been
selected. The pollutants selected for regulation under BPT are
chromium (total), cyanide (total), zinc, aluminum, oil and
grease, TSS, and pH. The toxic organic pollutants, cadmium,
copper, lead, nickel, and selenium, listed in Section VI are not
regulated under BPT for the reasons explained in Section X (p.
1058).
Table IX-19 lists the pollutants considered for regulation asso-
ciated with each wastewater stream in the Drawing with Emulsions
or Soaps Subcategory and the corresponding maximum and minimum
concentrations detected for each pollutant.
Treatment Train
The BPT model treatment train for the Drawing with Emulsions or
Soaps Subcategory consists of preliminary treatment when neces-
sary, specifically emulsion breaking and skimming, hexavalent
chromium reduction, and cyanide precipitation. The effluent from
preliminary treatment is combined with other wastewaters for
994
-------
common treatment by skimming and lime and settle. Sawing spent
lubricants require emulsion breaking and skimming and may require
hexavalent chromium reduction prior to combined treatment by
skimming and lime and settle. Solution heat treatment contact
cooling water may require cyanide precipitation, while cleaning
or etching wastewaters may require chromium reduction in addition
to cyanide precipitation. Following the preliminary treatment,
these wastewaters are then treated by skimming and lime and
settle. The treatment train is presented in Figure IX-6.
Effluent Limitations
Table VII-20 (p. 807) presents the treatment effectiveness of the
BPT model treatment train for pollutant parameters considered in
the Drawing with Emulsions Subcategory. Effluent concentrations
(one day maximum and ten day average values) are multiplied by
the normalized discharge flows summarized in Table IX-17 to
calculate the mass of pollutants allowed to be discharged per
mass of product. The results of these calculations are shown in
Table IX-20.
Benefits
In establishing BPT, EPA must consider the cost of treatment and
control in relation to the effluent reduction benefits. BPT
costs and benefits are tabulated along with BAT costs and bene-
fits in Section X. As shown in Table X-8 (p. 1087 ), the
application of BPT to the total Drawing with Emulsions or Soaps
Subcategory will remove approximately 134,342.9 kg/yr (0.296
million Ib/yr) of pollutants. As shown in Table X-l (p. 1074),
the corresponding capital and annual costs (1982 dollars) for
this removal are $1.05 million and $0.82 million per year,
respectively. As shown in Table X-l3 (p. 1097), the application
of BPT to direct dischargers only, will remove approximately
53,036.9 kg/yr (0.117 million Ib/yr) of pollutants. As shown in
Table X-2 (p. 1075), the corresponding capital and annual costs
(1982 dollars) for this removal are $0.73 million and $0.47
million per year, respectively. The Agency concludes that these
pollutant removals justify the costs incurred by plants in the
Drawing with Emulsions or Soaps Subcategory.
APPLICATION OF LIMITATIONS IN PERMITS
The purpose of these limitations (and standards) is to form a
uniform basis for regulating wastewater effluent from the alumi-
num forming category. For direct dischargers, this is accom-
plished through NPDES permits. Since the aluminum forming
category is regulated on an individual waste stream "building-
block" approach, two examples of applying these limitations to
995
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determine the allowable
facilities are included.
discharge from aluminum forming
Some process wastewater streams may not be covered by this regu-
lation or other effluent guidelines but are 'generated in the
aluminum forming plant and must be dealt with either in the
permit or pretreatment context. Whenever such wastewaters are
encountered, the permit writer or control authority should take
into account the minimum necessary water use for the process
operation and the treatment effectiveness of the model technology
using these factors to derive a mass discharge amount for the
unregulated process wastewater. As an example painting, which is
not specifically regulated in aluminum forming sometimes gener-
ates a wastewater. Metal preparation prior to painting such as
chromate conversion coating should be included as an etch line
operation while other process wastewater such as a water spray
curtain should be allowed an added discharge allowance based on
the minimum necessary water use and the appropriate treatment
effectiveness.
Example J_
Plant X forms aluminum using an extrusion process and operates
250 days per year. The total plant production is 50,000 kkg/yr.
All of the aluminum is degassed and cast by the direct chill
method; 70 percent of the aluminum is solution heat treated; and
50 percent of the aluminum is etched with caustic. The plant has
a degassing scrubber, and the etch line consists of a single bath
followed by a two-stage rinse. Table IX-21 illustrates the
calculation of the allowable BPT discharge of TSS.
The daily production from the extrusion operation would equal
50,000 off-kkg/yr divided by 250 days/yr to get 200 off-kkg/day.
This production rate is then multiplied by the extrusion core
limitation (mg/off-kkg) to get the daily discharge limit for the
core at Plant X. A production of 200 off-kkg/day is also used to
multiply with the limitation of direct chill casting, since 100
percent of the direct chill casting product is extruded. To
determine the mass of aluminum that is processed through solution
heat treatment the mass of aluminum extruded (200 off-kkg/day) is
multiplied by 70 percent to achieve a production rate of 140
off-kkg/day. The same procedure is followed for the cleaning or
etching operation and the sum of the daily limits for the
individual operations becomes the plant limit.
Example 2,
Plant Y, which operates 300 days per year, forms 10,000 off-kkg/
yr of aluminum sheet by rolling with emulsions and also forms
2,000 off-kkg/yr of aluminum by drawing with emulsions. All of
996
-------
the rolled aluminum is cast by the direct chill method; all of
the drawn aluminum is cast by the continuous rod casting method-
70 percent of the rolled aluminum is solution heat treated- 30
percent of the rolled aluminum is etched with caustic- and 5
percent of the drawn aluminum is etched with caustic. The etch
line consists of a caustic bath followed by a single-stage rinse
followed by a detergent bath followed by a second single-stage
£™S!: Jable IX~22 iHustrates the calculation of the allowable
BPT discharge of zinc.
The first step in determining the daily limits for Plant Y is to
?n nnn6 ^Od,UCti^n Jn terms of off-kkg/day. The plant produces
10,000 kkg/yr of aluminum sheet, all of which is cast on-site by
direct chill casting. Thus, the daily production for direct
chill casting is 10,000 off-kkg/yr divided by 300 days/yr or 33 3
off-kkg/day. Following the casting operation the aluminum ingot
is heated then processed through the rolling mill to produce
plate and removed to cool. The aluminum plate is then returned
to the rolling mill and processed once more to produce sheet,
thus the same off mass of aluminum undergoes two process cycles'
The production parameter used to obtain the daily limit from the
rolling process is two times the production of the direct chill
casting process or 66.6 off-kkg/day. The production and daily
performe^t flan? y?" ™* "-" ^ aU <* the operations
997
-------
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Table IX-4
BPT MASS LIMITATIONS FOR THE ROLLING WITH NEAT OILS SUBCATEGORY
Rolling With Neat Oils - Core Waste Streams Without An Annealing
Furnace Scrubber
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum rolled with neat oils
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0.019
0.024
0.105
0.016
0.023
0.106
0.068
0.081
0.356
1 .106
2.268
0.008
0.010
0.055
0.007
0.011
0.070
0.030
0.034
0.174
0.664
1.079
Within the range of 7.0 to 10.0 at all times
Rolling With Neat Oils - Core Waste Streams With An Annealing
' Furnace Scrubber
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum rolled with neat oils
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead *
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0.027
0.036
0.155
0.024
0.035
0.157
100
119
525
634
348
0.012
0.015
0.082
0.010
0.017
0.104
0.045
0.050
0.257
0.980
1.593
Within the range of 7.0 to 10.0 at all times
*Regulated pollutants.
1003
-------
Table IX-4 (Continued)
BPT MASS LIMITATIONS FOR THE ROLLING WITH NEAT OILS SUBCATEGORY
Continuous Sheet Casting - Spent Lubricant
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
.Monthly Average
mg/kg (Ib/million Ibs) of aluminum cast by continuous methods
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0.0007
0.0009
0.0037
0.0006
0.0008
0.0038
0.0024
0.0029
0.0127
0.0393
0.0805
0.00035
0.0004
0.0020
0.00024
0.0004
0.0025
0.0011
0.0012
0.0063
0.0236
0.0383
Within the range of 7.0 to 10.0 at all times
Solution Heat Treatment - Contact Cooling Water
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum quenched
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
2.62
3.39
14.64
2.24
3.
14.
9.
11,
49.55
154.10
315.91
24
79
48
25
16
39
71
93
54
79
24
4.70
24. 66
92.46
150.25
1.
1,
7.
0.
1.
9.
4.
Within the range of 7.0 to 10.0 at all times
*Regulated pollutants.
1004
-------
Table IX-4 (Continued)
BPT MASS LIMITATIONS FOR THE ROLLING WITH NEAT OILS SUBCATEGORY
Cleaning or Etching - Bath
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0.061
0.079
0.340
0.052
0.075
0.344
0.220
0.262
1.150
3.580
7.339
0.027
0.032
0.179
0.022
0.035
0.227
0.098
0.109
,573
,148
,491
0,
2,
3,
Within the range of 7.0 to 10.0 at all times
Cleaning or Etching - Rinse,
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
1 18
119
120
121
122
124
125
128
ma
/kg '(Ib/million Ibs) of aluminum cleaned or etched
Cadmium 4.730
Chromium* 6.121
Copper 26.433
Cyanide* 4.034
Lead 5.843
Nickel 26.711
Selenium 17.112
Zinc* 20.312
Aluminum* 89.454
Oil & Grease* 278.240
Total Suspended 570.390
Solids*
pH*
2.
2.
13.
1.
2.
17.
7.
8.
44.
166.
271.
087
504
912
669
783
668
652
486
518
944
284
Within the range of 7.0 to 10.0 at all times
*Regulated pollutants
1005
-------
Table IX-4 (Continued)
BPT MASS LIMITATIONS FOR THE ROLLING WITH NEAT OILS SUBCATEGORY
Gleaning or Etching - Scrubber Liquor
Pollutant or
Pollutant Property
Maximum for
_Any One Day
Maximum for
Monthly Averas
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
118
119
120
121
122
124
125
128
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
PH* wi
5.406
6.996
30.210
4.611
6.678
30.528
19.557
23.214
102.237
318.000
651.900
thin the range of 7.0 to
2O Q C
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20.067
8.745
Q fiQQ
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50. 880
190.800
310.050
10.0 at all tiroes.
*Regulated pollutants.
1006
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Table IX-7
BPT MASS LIMITATIONS FOR THE ROLLING WITH EMULSIONS SUBCATEGORY
Rolling With Emulsions - Core Waste Streams
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum rolled with emulsions
118 Cadmium
11 9 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0.044
0.057
0.247
0.038
0.055
0.249
0.160
0. 190
0.835
2.596
5.323
0.019
0.024
0.130
0.016
0.026
0.165
0.071
0.079
0.416
1.558
2.531
Within the range of 7.0 to 10.0 at all times
Direct Chill Casting - Contact Cooling Water
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cast by direct chill methods
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0.452
0.585
2.525
0.385
0..558
2.552
,635
,940
545
26.580
54.489
1,
1 ,
8,
0. 199
0.239
1.329
0.159
0.266
1 .688
0.731
0.811
4.253
15.948
25.916
Within the range of 7.0 to 10.0 at all times
*Regulated pollutants.
1010
-------
Table IX-7 (Continued)
BPT MASS LIMITATIONS FOR THE ROLLING WITH EMULSIONS SUBCATEGORY
Solution Heat Treatment - Contact Cooling Water
Pollutant or
Pollutant Propert
Maximum tor
Any One Day
(Ib/million Ibs) of aluminum quenched
118 Cadmium
1 1 9 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
2.620
3.390
14.640
2.234
3.236
14.794
9.477
11.249
49.543
154.100
315.905
1.156
1.387
7.705
0.925
1.541
9.785
4.238
4.700
24.656
92.460
150.248
Within the range of 7.0 to 10.0 at all times
Cleaning or Etching - Bath
Pollutant or
Pollutant Property
Maximum for
Monthly Average
Hb/million Ibs) of aluminum cleaned or etched
1.18
119
120
121
122
124
125
128
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0.061
0.079
0.340
0.052
0.075
0.344
0.220
0.262
151
,580
,339
1,
3,
7
0.027
0.032
0.179
0.022
0.036
0.227
0.098
0.109
,573
.149
.491
0.
2.
3.
Within the ran;
10.0 at all times
*Regulated pollutants
1011
-------
Table IX-7 (Continued)
BPT MASS LIMITATIONS FOR THE ROLLING WITH EMULSIONS SUBCATEGORY
Cleaning or Etching - Rinse
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum
Monthly AA
for
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
118
119
120
121
122
124
125
128
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
PH* W
4.730
6.121
26.433
4. 034 •>
5.843
26.711
17.112
20.312
89.454
278.240
570.392
ithin the range of 7.0 to
2. 087
13912
H «J • y i £-
2i783
17.668
7.652
8. 486
44 51 8
HT*T • *J 1 \J
166.944
271.284
10.0 at all times.
Cleaning or Etching - Scrubber Liquor
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
118
119
120
121
122
124
125
128
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
PH* w
5.406
6.996
30.210
4.611
6.678
30.528
19.577
23.214
102.237
318.000
651.900
ithin the range of 7.0 to
2O Q C
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*Regulated pollutants.
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Table IX-9
CONCENTRATION RANGE OF POLLUTANTS CONSIDERED FOR
BPT REGULATION IN CORE AND ANCILLARY WASTE STREAMS -
EXTRUSION SUBCATEGORY
Cadmium Total Chromium Copper Total Cyanide Lead Nickel
earn (mE/1) (nig /I) (mg/l) ("R/D IffR/1) iffi/H
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1015
-------
Table IX-10
BPT MASS LIMITATIONS FOR THE EXTRUSION SUBCATEGORY
Extrusion - Core Waste Streams
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
118
119
120
121
122
124
125
128
mg/kg (Ib/million Ibs) of aluminum extruded
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0
0
0
0.
0.
0.
0.
0.
2.
7.
14.
124
161
695
106
153
702
450
534
34
314
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0
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0.
0.
0.
1.
4.
7.
055
066
366
044
073
464
201
223
16
338
131
Within the range of 7.0 to 10.0 at all times
Direct Chill Casting - Contact Cooling Water
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cast by direct chill methods
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0,
0,
2.
0.
0.
2.
1.
1.
8.
26.
54.
452
585
525
385
558
552
635
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545
580
489
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1.
0.
0.
1 .
0.
0.
4.
15.
25.
199
239
329
159
266
688
731
81 1
253
948
916
Within the range of 7.0 to 10.0 at all tim<
*Regulated pollutants.
1016
-------
Table IX-10 (Continued)
BPT MASS LIMITATIONS FOR THE EXTRUSION SUBCATEGORY
Solution and Press Heat Treatment - Contact Cooling Water
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum quenched
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
2.620
3.390
1 4.640
2.234
3.236
14.794
9.477
249
543
100
905
11
49
154
315
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387
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925
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785
238
4.700
24.656
92.460
150.248
1,
1.
7.
0.
1.
9.
4.
Within the range of 7.0 to 10.0 at all times,
Cleaning or Etching - Bath
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0.061
0.079
0.340
0.052
0.075
0.344
0.220
0.261
151
580
339
1,
3,
7.
0.027
0.032
0.1 79
0.022
0.036
0.227
098
109
573
148
491
Within the range of 7.0 to 10.0 at all times
*Regulated pollutants.
1017
-------
Table IX-10 (Continued)
BPT MASS LIMITATIONS FOR THE EXTRUSION SUBCATEGORY
Gleaning or Etching - Rinse
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
118 Cadmium 4.730
119 Chromium* 6.121
120 Copper 26.433
121 Cyanide* 4.034
122 Lead 5.843
124 Nickel 26.711
125 Selenium 17.112
128 Zinc* 20.312
Aluminum* 89.454
Oil & Grease* 278.240
Total Suspended 570.392
Solids*
pH*
2.
2.
13.
•1.
2.
17.
7.
8.
44.
166.
271.
087
504
912
669
783
668
652
486
518
944
284
Within the range of 7.0 to 10.0 at all times.
Cleaning or Etching - Scrubber Liquor
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
118 Cadmium 5.406
119 Chromium* 6.996
120 Copper 30.210
121 Cyanide* 4.611
122 Lead 6.678
124 Nickel 30.528
125 Selenium 19.557
128 Zinc* 23.214
Aluminum* 102.237
Oil & Grease* 318.000
Total Suspended 651.900
Solids*
pH*
2.385
2,
15.
1 .
3.
20.
8.
9.
50.
190.
310.
862
900
908
180
193
745
699
880
800
050
Within the range of 7.0 to 10.0 at all times
*Regulated pollutants.
1018
-------
Table IX-10 (Continued)
BPT MASS LIMITATIONS FOR THE EXTRUSION SUBCATEGORY
Degassing - Scrubber Liquor
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
118
119
120
121
122
124
125
128
mg/kg (Ib/million Ibs) of aluminum degassed
Cadmium 0.887
Chromium* 1.1 48
Copper 4.957
Cyanide* 0.757
Lead 1.096
Nickel 5.009
Selenium 3.209
Zinc* 3.809
Aluminum* 16.776
Oil & Grease* 52.180
Total Suspended 106.969
Solids*
pH*
0.
0.
2,
0.
0.
3.
1.
1.
8.
31.
50.
391
470
609
313
552
313
435
591
349
308
876
Within the range of 7.0 to 10.0 at all times
Extrusion Press Hydraulic Fluid Leakage
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
.503
.650
,808
0.429
0.621
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818
,158
504
29.560
60.60
0,
0,
2,
2,
1,
2.
9.
0.222
0.266
1.478
0.177
0.296
1.877
0.813
0.902
4.730
17.736
28.821
Within the range of 7.0 to 10.0 at all times
*Regulated pollutants.
1019
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1022
-------
Table IX-13
BPT MASS LIMITATIONS FOR THE FORGING SUBCATEGORY*
Forging - Core Waste Streams
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum forged
118
119
120
121
122
124
125
128
Cadmium
Chromium
Copper
Cyanide
Lead
Nickel
Selenium
Zinc
Aluminum
Oil & Grease
Total Suspended
Solids
0,
0.
0,
0.
0.
0.
0.
0.
0.
0.
2.
017
022
095
014
021
096
061
073
320
996
042
0,
0.
0,
0.
0.
0.
0.
0.
0.
0.
0.
007
009
050
006
010
063
027
030
159
598
971
Within the range of 7.0 to 10.0 at all times
Forging - Scrubber Liquor
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum forged
1 18
119
120
121
122
124
125
128
Cadmium
Chromium
Copper
Cyanide
Lead
Nickel
Selenium
Zinc
Aluminum
Oil & Grease
Total Suspended
Solids
pH Within
0.526
0.681
2.939
0.449
0.650
2.970
1.903
2.259
9.947
30.940
63.427
the range of 7.0 to
0.232
0.278
1 .547
0. 186
0.310
1 .965
0.851
0.944
4. 950
18.564
30.167
10.0 at all times.
*A11 pollutants shown in Table IX-13 are not regulated at BPT
since there are no existing forgers who are direct dischargers
1023
-------
Table IX-13 (Continued)
BPT MASS LIMITATIONS FOR THE FORGING SUBCATEGORY
Solution Heat Treatment - Contact Cooling Water
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum quenched
1 1 8
1 1 9
1 20
1 21
1 22
1 24
1 25
128
Cadmium
Chromium
Copper
Cyanide
Lead
Nickel
Selenium
Zinc
Aluminum
Oil & Grease
Total Suspended
Solids
2.620
3.390
14.640
2.234
3.236
14.794
9.477
249
543
100
11
49
154
315
905
156
387
705
925
541
785
238
4.700
24.656
92.460
150.248
1 .
1.
7.
0.
1.
9.
4.
Within the range of 7.0 to 10.0 at all times
Cleaning or Etching - Bath
Pollutant or
Pollutant Property
118
119
120
121
122
124
125
128
mg/kg (Ib/million
Cadmium
Chromium
Copper
Cyanide
Lead
Nickel
Selenium
Zinc
Aluminum
Oil & Grease
Total Suspended
Solids
Maximum for Maximum for
Any One Day Monthly Average
Ibs) of aluminum cleaned or
0.061
0.079
0.340
0.052
0.075
0.344
0.220
0.261
1.151
3.580
7.339
pH Within the range of 7.0 to 10.0
etched
0.027
0.032
0.179
0.021
0.036
0.227
0.098
0.109
0.573
2.148
3.491
at all times.
1024
-------
Table IX-13 (Continued)
BPT MASS LIMITATIONS' FOR THE FORGING SUBCATEGORY
Cleaning or Etching - Rinse
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
118
119
120
121
122
124
125
128
Cadmium
Chromium
Copper
Cyanide
Lead
Nickel
Selenium
Zinc
Aluminum
Oil & Grease
Total Suspended
Solids
pH
4.730
6.121
26.433
4. 034
5.843
26.711
17.112
20.312
89.454
278.240
570.392 *-•'-•
Within the range of 7.0 to
2.087
2.504
13.912
1.699
2.783
17.668
7.652
8.486
44.518
166.944
271.284
10.0 at all times.
Cleaning or Etching - Scrubber Liquor
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/mjllion Ibs) of aluminum cleaned or etched
1 18
119
120
121
122
124
125
128
Cadmium
Chromium
Copper
Cyanide
Lead
Nickel
Selenium
Zinc
Aluminum
Oil & Grease
Total Suspended
Solids
pH
5.406
6.996
30.210
4.611
6.678
30.528
19.557
23.214.
102.237
318.000
651.900
Within the range of 7.0 to
2.385
2.862
15.900
,1.908
3.180
20.193
8.745
9.699
50.880
190.800
31.0.050
10.0 at all times.
1025
-------
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1028
-------
Table IX-1 6
BPT MASS LIMITATIONS FOR THE DRAWING WITH NEAT OILS SUBCATEGORY
Drawing With Neat Oils - Core Waste Streams
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
118
119
120
121
122
124
125
128
mg/kg (Ib/million Ibs) of aluminum drawn with neat oils
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
0.017
0.022
0.097
0.015
0.021
0.096
0.061
0.073
0.320
0.996
2.042
0.007
0.009
0.050
0.005
0.010
0.063
0.027
0.031
0.160
0.598
0.972
Within the ranee of 7.0 to 10.0 at all times
Continuous Rod Casting - Contact Cooling Water
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
118
119
120
121
122
124
125
128
(Ib/million Ibs) of aluminum cast by continuous methods
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0.
0,
2.
0,
0,
2.
1
2
10
31
63
529
684
955
451
653
986
913
,271
,00
,100
,755
0.
0,
1,
0,
0,
1
0
0
4
18
30
233
28
555
,187
,311
,975
,855
,949
.976
.660
.322
Within the range
of 7.0 to 10.0 at all times
*Regulated pollutants
1029
-------
Table IX-16 (Continued)
BPT MASS LIMITATIONS FOR THE DRAWING WITH NEAT OILS SUBCATEGORY
Continuous Rod Casting - Spent Lubricant
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cast by continuous methods
118
119
120
121
122
124
125
128
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
0.0007
0.0009
0.0037
0.0006
0.0008
0.0038
0.0024
0.0029
0.0126
0.0393
0.0805
0.0003
0.0004
0.0020
0.0003
0.0004
0.0025
0.001 1
0.0012
0.0063
0.0236
0.0383
pH*
Within the range of 7.0 to 10.0 at all times
Solution Heat Treatment - Contact Cooling Water
Pollutant orMaximum for
Pollutant Property Any One Day
Maximum for
Monthly Average
118
119
120
121
122
124
125
128
mg/kg (Ib/million Ibs) of aluminum quenched
Cadmium 2.620
Chromium* 3.390
Copper 14.640
Cyanide* 2.235
Lead 3.236
Nickel 14.794
Selenium 9.477
Zinc* 11.249
Aluminum* 49.543
Oil & Grease* 154.100
Total Suspended 315.905
Solids*
1.
1 ,
7.
0.
1.
9.
,156
,387
,705
,925
541
785
4.238
4.700
24.656
92.460
150.248
pH*
Within the range of 7.0 to 10.0 at all time!
*Regulated pollutants.
1030
-------
Table IX-16 (Continued)
BPT MASS LIMITATIONS FOR THE DRAWING WITH NEAT OILS SUBCATEGORY
Cleaning or Etching - Bath
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
ing/kg (Ib/million Ibs) of aluminum cleaned or etched
118 Cadmium
1 1 9 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
0.061
0.079
0.340
0.052
0.075
0.344
0.220
0.261
150
580
339
1,
3,
7,
0.027
0.032
0.179
0.022
0.036
0.227
0.098
0.109
0.573
2.148
3.491
Within the range of 7.0 to 10.0 at all times,
Cleaning or Etching - Rinse
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
118 Cadmium
1 19 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
4.730
6. 121
26.433
4.034
5.843
26.711
17.112
20.312
89.454
278.240
570.392
2.087
2.504
13.912
1.669
2.783
17.668
7.652
8.486
44.518
166.944
271.284
Within the range of 7.0 to 10.0 at all times
*Regulated pollutants.
1031
-------
Table IX-16 (Continued)
BPT MASS LIMITATIONS FOR THE DRAWING WITH NEAT OILS SUBCATEGORY
Cleaning or Etching - Scrubber Liquor
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
118
119
120
121
122
124
125
128
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
Cadmium 5.406
Chromium* 6.996
Copper 30.210
Cyanide* 4.611
Lead 6.678
Nickel 30.528
Selenium 19.557
Zinc* 23.214
Aluminum* 102.237
Oil & Grease* 318.000
Total Suspended 651.900
Solids*
pH*
2
2,
15,
1.
3,
20.
8.
9.
50.
190.
310.
385
862
900
908
180
193
745
699
880
800
050
Within the range of 7.0 to 10.0 at all time:
*Regulated pollutants.
. 1032
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-------
Table IX-18
COMPARISON OF WASTEWATER DISCHARGE RATES
FROM DRAWING EMULSION AND SOAP STREAMS
Order of
Plant Wastewater Increasing Lubricant
Number (gal/ton) (1/kkg) Production TvtJe
1
2
3
4
5
6
7
8
9
10
11
12
0
0.8100
2.810
6.279
62.50
260.0
267.0
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3.377
11.72
26.18
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1,084
1,113
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*
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8
10
6
9
3
2
5
1
4
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7
Emulsion
Emulsion
Emulsion
Emulsion
Emulsion
Soap
Emulsion
Soap
Emulsion
Emulsion
Emulsion
Soap and
Emulsion
Product
Type
Tube
Wire
Wire
Wire
Wire
Wire
Wire
Wire
Wire
Wire
Wire
Wire
13
Soap
Wire
*Sufficient data not available to calculate these values
1034 -
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-------
Table IX-20
BPT MASS LIMITATIONS FOR THE DRAWING WITH EMULSIONS.
OR SOAPS SUBGATEGORY
Drawing With Emulsions or Soaps - Core Waste Streams
Pollutant or
Pollutant Property
rag/kg
1 18
119
120
121
122
124
125
128
(Ib/million Ibs)
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH* Wi
Maximum for
Any One Day
of aluminum drawn
0.159
0.205
0.886
0.135
0.196
0.895
0.574
0.680
2.998
9.326
19.118
thin the range of
Maximum for
Monthly Average
with emulsions or soaps
0.070
0.084
0.466
0.056
0.094
0.592
0.256
0.285
1.492
5.596
9.093
7.0 to 10.0 at all times.
Continuous Rod Casting - Contact Cooling Water
Pollutant or Maximum for
Pollutant Property Any One Day
mp
118
1 19
120
121
122
124
125
128
/kg (Ib/million Ibs)
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH* Withi
of aluminum
0.529
0.684
2.955
0.450
0.653
2.986
1.913
2.270
9.999
31.100
63.755
.n the range
Maximum for
Monthly Average
cast by continuous methods
0.233
0.28
1 .555
0.187
0. 311
1.975
0.855
0.949
4.976
18.660
30.323
of 7.0 to 10.0 at all times.
*Regulated pollutants
1037
-------
Table IX-20 (Continued)
BPT MASS LIMITATIONS FOR THE DRAWING WITH EMULSIONS
OR SOAPS SUBCATEGORY
Continuous Rod Casting - Spent Lubricant
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum cast by continuous methods
118
119
120
121
122
124
125
128
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
0.0007
0.0009
0.0037
0.0006
0.0008
0.0038
0.0024
0.0029
Oi0126
0.0393
0.0805
0.0003
0.0004
0.0020
0.0003
0.0004
0.0025
0.0011
0.001
0.0063
0.0236
0.0390
pH*
Within the range of 7.0 to 10.0 at all times.
Solution Heat Treatment - Contact Cooling Water
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of aluminum quenched
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
2.620
3.390
14.640
2.234
3.236
14.794
9.477
11.249
49.549
154.100
315.905
1.156
1.387
7.705
0.925
1.541
9.785
4.238
4.700
24.656
92.460
150.248
Within the range of 7.0 to 10.0 at all times
*Regulated pollutants.
1038
-------
Table IX-20 (Continued)
BPT MASS LIMITATIONS.FOR THE DRAWING WITH EMULSIONS
OR SOAPS SUBCATEGORY
Cleaning or Etching - Bath
Pollutant or
Maximum for
Any One Day
Maximum for
Monthly Average
1 18
119
120
121
122
124
125
128
mg/kg (Ib/mill
Cadmium
Chromium*
Copper
Cyanide*
Lead
Nickel
Selenium
Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
ion Ibs) of aluminum cleaned or
0.061
0.079
0.340
0.052
0.075
0.344
0.220
0.262
1 .151
3.580
7.339
Within the range of 7.0 to 10.0
etched
0.027
0.032
0.179
0.022
0.036
0.227
0.098
0.109
0.573
2. 148
3.491
at all times.
Cleaning or Etching - Rinse
Maximum for
Monthly Average
Pollutant or
Pollutant Property
Maximum for
Any One Day
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
118 Cadmium
119 Chromium*
120 Copper
121 Cyanide*
122 Lead
124 Nickel
125 Selenium
128 Zinc*
Aluminum*
Oil & Grease*
Total Suspended
Solids*
pH*
4.730
6.121
26.433
4.034
5.843
26.71 1
17
20
89
278
570
112
312
,454
240
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2.
2.
13.
1.
2.
17.
7.
8.
44,
166,
271,
087
504
912
669
783
668
652
486
519
944
284
Within the range of 7.0 to 10.0 at all times
*Regulated pollutants
1039
-------
Table IX-20 (Continued)
BPT MASS LIMITATIONS FOR THE DRAWING WITH EMULSIONS
OR SOAPS SUBGATEGORY
Cleaning or Etching - Scrubber Liquor
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
118
119
120
121
122
124
125
128
mg/kg (Ib/million Ibs) of aluminum cleaned or etched
Cadmium 5.406
Chromium* 6.996
Copper 30.210
Cyanide* 4.611
Lead 6.678
Nickel 30.528
Selenium 19.557
Zinc* 23.214
Aluminum* 102.237
Oil & Grease* 318.000
Total Suspended 651.900
Solids*
2,
2,
15.
1 .
3.
20.
8.
9.
50.
190.
310.
385
862
900
908
180
193
745
699
880
800
050
pH*
Within the range of 7.0 to 10.0 at all times
*Regulated pollutants.
1040
-------
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1048
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SECTION X
BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
The effluent limitations in this section apply to existing direct
dischargers. A direct discharger is a facility which discharges
or may discharge pollutants into waters of the United States.
These effluent limitations, which must be achieved by July 1,
1984, are based on the best control and treatment technology
employed by a specific point source within the industrial cate-
gory or subcategory, or by another industry where it is readily
transferable. Emphasis is placed on additional treatment tech-
niques applied at the end of the treatment systems currently
employed for BPT, as well as improvements in reagent control,
process control, and treatment technology optimization.
The factors considered in assessing best available technology
economically achievable (BAT) include the age of equipment and
facilities involved, the process employed, process changes, non-
water quality environmental impacts (including energy require-
ments), and the costs of application of such technology. BAT
technology represents the best existing economically achievable
performance of plants of various ages, sizes, processes, or other
characteristics. Those categories whose existing performance is
uniformly inadequate may require a transfer of BAT from a differ-
ent subcategory or category. BAT may include process changes or
internal controls, even when these are not common industry
practice. This level of technology also considers those plant
processes and control and treatment technologies which at pilot
plant and other levels have demonstrated both technological per-
formance and economic viability at a level sufficient to justify
investigation.
TECHNICAL APPROACH TO BAT
The Agency reviewed a wide range of technology options and evalu-
ated the available possibilities to ensure that the most effec-
tive and beneficial technologies were used as the basis of BAT.
To accomplish this, the Agency elected to examine at least three
significant technology alternatives which could be applied to
aluminum forming as BAT options and which would represent sub-
stantial progress toward prevention of polluting the environment
above and beyond progress achievable by BPT. The statutory
assessment of BAT considers costs, but does not require a
balancing of costs against effluent reduction benefits see
Weyerhaeuser v. Costle, 11 ERC 2149 (D.C. Cir. 1978); however, in
assessing the proposed BAT, the Agency has given substantial
weight to the reasonableness of costs.
1049
-------
EPA evaluated six levels of BAT for the category at proposal.
Option 1 is BPT treatment. Option 2 is BPT treatment plus flow
reduction and in-plant controls. Options 3, 4, 5, and 6 provide
additional levels of treatment. Options 1, 2, 3, 4, and 5
technologies are, in general, equally applicable to all the
subcategories of the aluminum forming category, while Option 6 is
applicable to one subcategory (forging). Eacn treatment option
produces similar concentrations of pollutants in the the effluent
from all subcategories. Mass limitations derived from these
options may vary; however, because of the impact of different
production normalized wastewater discharge flow allowances.
Options 1, 2, and 3 are based on the chemical emulsion breaking
technology from the BPT technology train, whereas Options 4, 5,
and 6 are based on thermal emulsion breaking.
In summary form, the treatment technologies which were considered
for aluminum forming are:
Option 1 (Figure X-l) is based on:
Oil skimming,
Lime and settle (chemical precipitation of metals
followed by sedimentation), and
pH adjustment; and, where required,
Cyanide removal,
Hexavalent chromium reduction, and
Chemical emulsion breaking.
(This option is equivalent to the technology on which
BPT is based.)
Option 2 (Figure X-2) is based on:
Option 1, plus process wastewater flow reduction by
the following methods:
- Heat treatment contact cooling water recycle through
cooling towers.
- Continuous rod casting contact cooling water
recycle.
- Air pollution control scrubber liquor recycle.
- Countercurrent cascade rinsing or other water effi-
cient methods applied to cleaning or etching and
extrusion die cleaning rinses.
1050
-------
- Regeneration or contract hauling of cleaning or
etching baths (proposed but not promulgated)
Use of extrusion die cleaning rinse for bath
make-up water
- Alternative fluxing or in-line refining methods,
neither of which require wet air pollution control,
for degassing aluminum melts.
Option 3 (Figure X-3) is based on:
Option 2, plus multimedia filtration at the end
of the Option 2 treatment train.
Option 4 (Figure X-4) is based on:
Option 1 plus process wastewater flow reduction by the
following methods:
- Thermal emulsion breaking or contractor hauling for
concentrated emulsions.
- Heat treatment contact cooling water recycle through
cooling towers.
Continuous rod casting contact cooling water
recycle.
- Air pollution control scrubber liquor recycle.
- Hauling or regeneration of spent cleaning or etching
baths.
- Countercurrent cascade rinsing or other water effi-
cient methods applied to cleaning or etching and
extrusion die cleaning rinses.
Alternative fluxing or in-line refining methods,
which do not require wet air pollution control, for
degassing aluminum melts.
Option 5 (Figure X-5) is based on:
Option 4, plus multimedia filtration at the end of
the Option 4 treatment train.
Option 6 (Figure X-6) is based on:
Option 5, plus granular activated carbon treatment
as a preliminary treatment step to remove toxic
organics.
Option 1_
Option 1 represents the BPT end-of-pipe treatment technology.
This treatment train consists of preliminary treatment when
1051
-------
necessary of emulsion breaking and skimming, hexavalent chromium
reduction, and cyanide removal. The effluent from preliminary
treatment is combined with other wastewaters for central treat-
ment by skimming and lime and settle.
Option 2^
Option 2 builds upon the BPT end-of-pipe treatment technologies
of skimming, lime and settle with preliminary treatment to reduce
chromium, remove cyanide and break emulsions. Flow reduction
measures, based on in-process changes, are the mechanisms for
reducing pollutant discharges at Option 2. Flow reduction
measures eliminate some wastewater streams and concentrate the
pollutants in others. Treatment of a more concentrated stream
allows a greater net removal of pollutants and economies of
treating a reduced flow. Methods for reducing process wastewater
generation or discharge include:
Heat Treatment Contact
Towers. The cooling
Cooling
and recycle
Water Recycle Through Cooling
_ of heat treatment contact
cooling water is practiced by 15 plants. The function of heat
treatment contact cooling water is to remove heat quickly from
the aluminum. Therefore, the principal requirements of the water
are that it be cool and not contain dissolved solids at a level
that would cause water marks or other surface imperfections.
There is sufficient industry experience to assure the success of
this technology using cooling towers or heat exchangers.
Although four plants have reported that they do not discharge any
quench water by reason of continued recycle, some blowdown or
periodic cleaning is likely to be needed to prevent a build-up of
dissolved and suspended solids.
Scrubber Liquor Recycle. The recycle of scrubber liquor from
cleaning or etching process baths is practiced by two plants, on
forging scrubbers at two plants, and by one plant for its anneal-
ing scrubber. The scrubber water picks up particulates and fumes
from the air. Scrubbers have relatively low water quality
requirements for efficient operation, accordingly, recycle of
scrubber liquor is appropriate for aluminum forming operations.,
A blowdown or periodic cleaning is necessary to prevent the
buildup of dissolved and suspended solids.
Countercurrent Cascade Rinsing Applied to Cleaning or Etching and
Die Cleaning Rinses. Countercurrent cascade rinsing is a
mechanism commonly encountered in aluminum forming, electroplat-
ing, and other metal processing operations (Section VII, p. ).
The cleanest water is used for final rinsing of an item, preceded
by rinse stages using water with progressively more contaminants
to partially rinse the item. Fresh make-up water is added to the
final rinse, and contaminated rinse water is discharged from the
1052
-------
initial rinse stage. The make-up water for all but the final
rinse stage is from the following stage.
The countercurrent cascade rinsing process substantially improves
efficiencies of water use for rinsing. For example, the use of a
two-stage countercurrent cascade rinse can reduce water usage to
approximately one-tenth of that' needed for a single-stage rinse
to achieve the same level of product cleanliness. Similarly, a
three-stage countercurrent cascade rinse would reduce water usage
to approximately one-thirtieth. Countercurrent cascade rinsing
is practiced at least four aluminum forming plants. In addition,
although not strictly countercurrent cascade rinsing, two plants
reuse the rinse water following one cleaning or etching bath for
the rinse of a preceding bath. The installation of countercur-
rent cascade rinsing is applicable to existing aluminum forming
plants in that the cleaning and etch operations are usually dis-
crete operations and space is generally available for additional
rinse tanks following these operations.
Alternative Fluxing Methods. There are a number of alternatives
available to replace systems requiring wet scrubbers for
degassing operations (melting furnace air pollution control).
Among the alternatives are fluxes not requiring wet air pollution
control and in-line refining methods that eliminate the need for
fluxing. All aluminum forming plants but one have adopted the
alternative fluxing methods and thereby eliminated their
scrubbers.
If enough metal refining is taking place that large amounts of
gases are being emitted and a wet scrubber is necessary, this is
considered metal manufacturing and is covered under the aluminum
subcategories of the nonferrous metals manufacturing point source
category.
Regeneration or Contract Hauling of Cleaning or Etching Baths.
The Agency proposed a zero discharge allowance for cleaning or
etching baths based on regeneration or contract hauling of the
baths. The Agency has reevaluated the basis of the zero
discharge allowance and is establishing a flow allowance for this
waste stream. New information and comments submitted on the
proposed rule indicated that regeneration is not a fully
developed technology applicable to all facilities in the
category. Further, contract hauling produces no environmental
benefit since these wastes are generally hauled to an off-site
waste treatment facility which would treat them in much the same
manner as they would be treated at the aluminum forming plant.
1053
-------
Option 3_
Option 3 builds upon the technical requirements of Option 2 by
adding conventional mixed-media filtration after the Option 2
technology train and the in-process flow reduction controls.
There are two aluminum forming plants which presently treat
wastewaters with a polishing filter. Option 3 differs from
Option 5 only in the type of emulsion treatment it is based on.
Option 3 is based on the chemical emulsion breaking technology,
which does not achieve zero discharge.
Option 4_
Option 4 builds upon the technologies established for Option 2.
Thermal emulsion breaking is the principal mechanism for reducing
pollutant discharges at Option 4.
Thermal Emulsion Breaking or Contractor Hauling to Achieve Zero
Discharge of Concentrated Emulsions. The Agency has "noted that
recycle or contractor hauling of several waste streams (e.g.,
continuous rod casting lubricant, rolling emulsions, roll grind-
ing emulsions, drawing emulsions, and saw oils) are common prac-
tices. Organics were found to be constituents of these wastes.
Contractor hauling eliminated potential wastewater discharges,
obviated the need for organics removal (granular activated
carbon), and was the most cost-effective approach for many
plants. It was, therefore, the method suggested and included in
the cost estimate for many of these waste streams when small
volumes were considered.
Thermal emulsion breaking also eliminates any discharge from the
concentrated emulsion waste streams by concentrating the oil and
distilling the water. The water can then be reused in the
process. EPA is aware of one application of thermal emulsion
breaking in this category. In addition, it is being used at four
copper forming plants to treat their emulsified lubricants. The
processes performed and lubricants used in copper forming are
similar to those in aluminum forming, and as such the thermal
emulsion breaking technology is applicable to the aluminum
forming concentrated emulsion waste streams.
Thermal emulsion breaking does not eliminate contractor hauling
of spent lubricants, but it does reduce the volume of waste to be
disposed of, an important consideration in the face of the rising
disposal costs.
Two aluminum forming plants reported achieving zero discharge of
their emulsified wastes through treatment. One plant treats
their emulsion with chemical emulsion breaking, followed by
ultrafiltration, with the concentrate being recycled back through
1054
-------
chemical emulsion breaking, and the filtrate is clarified and
reused elsewhere in the plant. The second plant applies gravity
separation to their emulsions and skims the oil, which is further
processed and used as fuel. The water fraction, which still
contains 0.1 percent oil, is sprayed onto a field.
Option 5_
Option 5 builds upon the technical requirements of Option 4 by
adding conventional mixed-media filtration. The filter suggested
is of the gravity, mixed-media type, although other filters, such
as rapid sand or pressure filters would perform equally well.
Option 6_
Option 6 builds upon the technical requirements of Option 5.
Option 6 complements the other technologies by applying granular
activated carbon (GAC) to waste streams for which toxic organics
were selected. By applying granular activated carbon as a
preliminary treatment step rather than end-of-pipe treatment for
waste streams where organics were found at significant levels,
treatment efficiency is improved, and total treatment costs are
reduced.
The Agency considered options 2 through 6 for BAT technology.
Options 4 and 5 were rejected before proposal because of the
extremely high energy requirements and costs associated with
retrofitting thermal emulsion breaking technology into existing
aluminum forming plants. Option 6 was also eliminated from
consideration early in the decision process because of the high
cost associated with its application and the minimal incremental
removals of toxic organics achieved.
The Agency proposed BAT limitations based on Option 2 and stated
that it would give equivalent consideration to Option 3, which is
Option 2 with end-of-pipe polishing filtration added.
Industry Cost and Environmental Benefits of the Various Treatment
Options
As a means of evaluating the economic achievability of each of
these options, the Agency developed estimates of the compliance
costs and benefits for Options 2 and 3. An estimate of capital
and annual costs for BAT options 2 and 3 was prepared for each
subcategory as an aid in choosing best BAT model technology. The
cost estimates for the total subcategory are presented in Table
X-l. Plant-by-plant cost estimates were made for 49 of 59 direct
dischargers and extrapolated to the remaining direct dischargers
in the category. These estimates are presented in Table X-2.
All costs are based on 1982 dollars.
1055
-------
The cost methodology has been described in detail in Section
VIII. Standard cost literature sources and vendor quotes were
used for module capital and annual costs. Data from several
sources were combined to yield average or typical equipment costs
as a function of flow or other wastewater characteristics and
design parameters. The resulting costs for individual pieces of
equipment were combined to yield module costs. The cost data
were coupled with specific flow data from each plant to establish
system costs for each plant.
The total costs presented in Tables X-l and X-2 represent esti-
mates which were revised after proposal to consider plants which
reported discharge flow from anodizing and conversion coating
operations, and the treatment technology required for those
wastewater streams which were not considered to be in-scope waste
streams when the original cost estimates were prepared. In
addition, the preproposal annual cost estimates were adjusted by
subtracting 10 percent of the capital cost from the annual cost.
This was done because an error in the original costing
methodology doublecounted the value for depreciation.
Pollutant reduction benefit estimates were calculated for each
option for each subcategory. The benefits that the treatment
technologies can achieve are presented in Tables X-3 through X-8.
The benefits that the treatment technologies will achieve for
direct dischargers are presented in Tables X-9 through X-l3. The
benefits that the treatment technologies can achieve for a
"normal plant" in each subcategory are presented in Tables X~14
through X-l9. The characteristics of the normal plants are
presented in Section VIII (p. 897).
The first step in the calculation of the benefit estimates is the
calculation of production normalized raw waste values (mg/kkg)
for each pollutant in each waste stream. These values, along
with raw waste concentrations, are presented in Tables X-20
through X-25. raw waste values were calculated using one of
three methods. When analytical concentration data (mg/1) and
sampled production normalized flow values (1/kkg) were available
for a given waste stream, individual raw waste values for each
sample were calculated and averaged. This method allows for the
retention of any relationship between concentration, flow, and
production. When sampled production normalized flows were not
available for a given waste stream, an average concentration was
calculated for each pollutant, and the average raw waste
normalized flow taken from the dcp information for that waste
stream was used to calculate the raw waste. When no analytical
values were available for a given waste stream, the raw waste
values for a stream of similar water quality was used. The raw
waste concentrations (mg/1) in Tables X-20 through X-25 were
1056
-------
calculated by dividing the raw waste values (mg/kkg) by the
average raw waste production normalized flow (1/kkg).
The total flow (1/yr) for each option for each subcategory was
calculated by summing individual flow values for each waste
stream in the subcategory for each option. The individual flow
values were calculated by multiplying the total production asso-
ciated with each waste stream in each subcategory (kkg/yr) by the
appropriate production normalized flow (1/kkg) for each waste
stream for each option.
The raw waste mass values (kg/yr) for each pollutant in each sub-
category were calculated by summing individual raw waste masses
for each waste stream in the subcategory. The individual raw
waste mass values were calculated by multiplying the total pro-
duction associated with each waste stream in each subcateqorv
(kkg/yr) by the raw waste value (mg/kkg) for each pollutant in
each waste stream.
The mass discharged (kg/yr) for each pollutant for each option
for,each subcategory was calculated by multiplying the total flow
u /ii:) f0* those waste streams which enter the treatment system,
by the treatment effectiveness concentration (mg/1) (Table VII-
20, p. 807) for each pollutant for the appropriate option.
The total mass removed (kg/yr) for each pollutant for each option
for each subcategory was calculated by subtracting the total mass
discharged (kg/yr) from the total raw mass (kg/yr).
Total treatment performance values for each subcategory were
calculated by using the total production (kkg/yr) of all plants
in the subcategory for each waste stream. Treatment performance
values for direct dischargers in each subcategory were calculated
by using the total production (kkg/yr) of all direct dischargers
in the subcategory for each waste stream. Treatment performance
values for normal plants" in each subcategory were calculated by
the same method described above, based on normal plant produc-
tions and flows.
SELECTED OPTION FOR BAT
The Agency evaluated the compliance costs and benefits for
Options 2 and 3 presented in Tables X-l through X-19 to select a
final option as BAT. Both of the options (2 and 3) provided
additional pollutant reduction beyond that provided by BPT.
EPA has selected Option 2 as the basis for BAT effluent limita-
tions. This option was selected because it provides protection
of the environment consistent with proven operation of in-process
controls and treatment effectiveness. The reduction of pollu-
1057
-------
tants in the effluent, especially toxic metals, is substantial
and economically achievable thus resulting in a minimal impact on
the industry.
Option 2 builds upon the technologies established for BPT. Flow
reduction measures are the principal mechanisms for reducing
pollutant discharges at Option 2. Flow reduction measures result
in eliminating some wastewater streams and concentrating the
pollutants in others. Treatment of a more concentrated stream
allows a greater net removal of pollutants and may reduce the
cost of treatment by reducing the flow and hence the size of the
treatment equipment.
All of the flow reduction technologies or control methods are
presently employed in at least one aluminum forming plant. The
application of technologies such as countercurrent cascade
rinsing to cleaning or etching lines is not expected to cause
serious interruptions in production since these operations tend
to be used during one shift each day, five days per week allowing
preliminary changes to be scheduled.
The Agency has decided not to include filtration as part of the
model BAT treatment technology. EPA estimates that 29,000 kg/yr
(64,000 Ib/yr) of toxic metal pollutants will be discharged after
the installation of BPT treatment technology; the model BAT
treatment technology is estimated to remove an additional 15,000
kg/yr (33,000 Ib) of toxic metals. The addition of filtration
would remove approximately 4,300 kg/yr (9,500 Ib/yr) of toxic
pollutants discharged after BAT or a total removal of 94 percent
of the total current discharge. This additional removal of 4,300
kg/yr achieved by filtration is equal to an additional removal of
approximately 1 kg (2.2 Ib) of toxic pollutants per day per
discharger. The incremental costs of these effluent reductions
are $8.2 million in capital cost and $2.5 million in total annual
costs for all direct dischargers. In addition, 18 aluminum
forming plants also perform coil coating. The Agency has
structured the aluminum forming regulation and coil coating
regulation to allow cotreatment of wastewaters at integrated
facilities. The BAT limitations for the coil coating category
are based on technology not including filtration. Establishing
aluminum forming limitations based on polishing filters would
have the effect of requiring such integrated facilities to
install polishing filters. The Agency believes that given all of
these factors, the costs involved do not warrant selection ot
filtration as a part of the BAT model treatment technology.
REGULATED POLLUTANT PARAMETERS
The raw wastewater concentrations from individual operations and
the subcategory as a whole were examined to select those pollu-
1058
-------
tant parameters found at frequencies and concentrations warrant-
ing regulation. Several toxic metals and aluminum were selected
for regulation in each subcategory.
Many of the toxic organic compounds were detected above their
level of quantification in wastewaters containing oils or oil
emulsions. Organic compounds are known to be insoluble or
slightly soluble in water and highly soluble in oil and, as a
result of the normal mixing processes during wastewater
treatment, equilibrium distribution of pollutants between the
wastewater and oil should occur readily. Then by applying oil
removal processes (i.e., oil-water separation or emulsion
breaking), the organic pollutant levels are reduced.
The laboratory procedure of extracting a compound from organic
and aqueous phases is analogous to the removal of nonpolar
organic pollutants by oil skimming during wastewater treatment.
Work on extraction of toxic organic pollutants, using the hydro-
carbon solvent hexane, has demonstrated extractions ranging from
88 to 97 percent for polynuclear aromatic hydrocarbons when using
a one-part hexane to 100-parts wastewater matrix. Addition of
ionizable inorganic compounds enhances the extraction of pollu-
tants by hexane. Equilibrium distribution of the pollutants is
achieved by two minutes of shaking.
Extraction of pollutants by oil removal treatment processes
varies in effectiveness with the relative solubilities of the
pollutant. The chemical nature of the process produces a pollu-
tant concentration in the effluent (water), which is a function
of the influent (oil and water) concentration of the pollutant.
In some cases, the water resulting from the oil treatment process
contains organics at concentration levels which are treatable bv
GAC. .
For aluminum forming wastewaters, effective oil removal technol-
ogy (such as oil skimming or emulsion, breaking) is capable of
removing approximately 97 percent of the total toxic organics
(TTO) from the raw waste. As shown in Table X-26, the achievable
TTO concentration is approximately 0.69 mg/1. The influent and
effluent concentrations presented for each pollutant were taken
from the data presented in Section V for several plants with
effective oil removal technologies in place. In calculating the
concentrations, if only one day's sampling datum was available,
that value was used; if two day's sampling data were available,
the higher of the values was used; and, if three day's sampling
data were available, the mean or the median value was used,
whichever was higher. The Agency assumes that the 0.69 mg/1
value is an appropriate basis for effluent limitations, since the
highest values were used in the calculation.
1059
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In addition to the pollutants listed in Table X-26, several other
toxic organic pollutants are considered. These include p-chloro-
m-cresol (022), 2-chlorophenol (024), 2,4-dinitrotoluene (035),
1,2-diphenylhydrazine (037), fluoranthene (039), isophorone
(054), bis(2-ethylhexyl) phthalate (066), di-n-butyl phthalate
(067), di-n-ethyl phthalate (068), benzo(a)pyrene (073), 3,4-ben-
zofluoranthene (074), benzo(k)fluoroanthene (075), chrysene
(076), acenaphthylene (077), benzo(ghi)perylene (079), dibenzo-
(a,h)anthracene (082), indeno(1,2,3-c,d)pyrene (083), vinyl
chloride (088), and endrin aldehyde (099). This list includes
all the polynuclear aromatic hydrocarbon (PAH) compounds and
several toxic organics found in drawing spent emulsions not found
in rolling spent emulsions. These compounds are included because
the Agency believes that any of the PAH's and these other com-
pounds can be substituted for one another to serve as pressure
building compounds in the formulations of the emulsified
lubricants.
The total toxic organic benefit estimate values (kg/yr) presented
in Tables X-3 through X-19 are calculated by multiplying the oil
and grease mass (kg/yr) by 0.0015. From the data presented in
Section V, it has been determined that the sum of the concentra-
tions of the toxic organics in any given sample is on the average
equal to 0.15 percent of the oil and grease concentration in that
sample.
Since effective oil and grease removal can remove 97 percent of
the TTO, no TTO limitation will be set at BAT because the Agency
believes that the oil and grease removals under the BPT limita-
tions should provide adequate removal of toxic organics.
As discussed in Section VII (p. 701), maintaining the correct pH
in the treatment system is important to assure adequate removal
of toxic metals. The Agency believes that by maintaining the
correct pH range for removal of chromium, zinc, and aluminum,
adequate removal of the other toxic metals, cadmium, copper,
lead, nickel, and selenium, should be assured. The Agency
believes that the mechanism and the chemistry of toxic metals
removal in a lime and settle system are the same for all of the
toxic metals. This theoretical analysis is supported empirically
by performance data of lime and settle systems collected by the
Agency. The theoretical background for toxic metals removal as
well as the performance data have been presented in Section VII.
Since chromium, zinc, and aluminum are present at the highest
concentrations in raw wastewater streams, these pollutants have
been selected to be used to ensure adequate removal of the other
toxic metals listed above. Chromium and zinc are considered to
be indicator pollutants for cadmium, copper, lead, nickel, and
selenium, which were found at treatable levels.
1060
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Effluent pH should be maintained within the range of 7.0 to 10.0
at all times. This pH range applies to the clarifier effluent.
Maintaining the pH in this range should ensure effective removal
of the vast majority of the toxic metals.
ROLLING WITH NEAT OILS SUBCATEGORY
Discharge Flows
Table X-27 lists the BAT wastewater discharge flows for core and
ancillary streams that received an allowance under BPT. The flow
allowances for BAT for core operations are identical to those of
BPT.
Ancillary streams with a BAT discharge allowance are from contin-
uous sheet casting lubricant, solution heat treatment contact
cooling, and cleaning or etching baths, rinses, and scrubbers.
The bath allowance at BAT is identical to the bath allowance at
BPT.
The BAT wastewater discharge flow for the solution heat treatment
contact cooling water (heat treatment quench) stream is 2,037
1/kkg (488.5 gal/ton). Of the 89 heat treatment quench opera-
tions surveyed, 18 reported recycle of this stream. Eight of
these appear to achieve zero discharge of this wastewater stream
by practicing total recycle. It is likely, however, that the
plants reporting no discharge failed to mention periodic dis-
charge, such as occasional blowdown or discharge with annual
cleaning of the cooling tower. Because no technology for avoid-
ing the buildup of solids in completely recycled cooling water is
known to be applied in this industry, only nonzero discharge
values were used as a basis for the BAT discharge flow. The BAT
discharge flow for the solution heat treatment contact cooling
water stream is the mean of four plants using recycle for which
sufficient data are available on both normalized discharge flow
and water use flow (i.e., the percent recycle). The normalized
discharge flows for these plants ranged from 881 to 3,059 1/kkg
(211 to 733 gal/ton), with a mean of 2,037 1/kkg (488.5 gal/ton),
which is selected as the BAT discharge flow.
The BAT wastewater discharge flows for cleaning or etching oper-
ations are 179 1/kkg (43 gal/ton) for cleaning or etching baths,
1,391 1/kkg (339.8 gal/ton) for cleaning or etching rinses, and
1,933 1/kkg (463.5 gal/ton) of aluminum cleaned or etched for
cleaning or etching scrubber liquor.
The BAT discharge for cleaning or etching baths is identical to
that of BPT. At proposal, consideration was given to not estab-
lishing a BAT discharge allowance based upon hauling or regenera-
tion of bath solutions. Based on comments received from industry
1061
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and data obtained since proposal, the Agency has established a
bath allowance at BAT.
The BAT wastewater discharge flow for the cleaning or etching
rinse is based upon flow reduction using two-stage countercurrent
cascade rinsing or other suitable rinsing techniques including
but not limited to spray rinsing and simply rinsewater recircu-
lation. The allowance is per bath and associated rinse opera-
tion. Plants which have more than one cleaning or etching bath
are given an allowance for the rinse that follows each bath.
Eighteen of the 44 rinse dischargers reported throughout all of
the subcategories meet the BAT flow without further flow reduc-
tion. Eleven are known to use recirculating or spray rinsing
techniques or a combination of the two. Hot water rinses or
treatment of recirculating rinse water are used by four of these
11 plants. Stagnant rinsing is used by three plants which meet
the BAT discharge flow, as well as two which do not.
Most of the plants with discharge flows higher than the BAT
allowance are forging plants. Five utilize once-through overflow
rinsing, two use stagnant rinsing, and two reuse rinse water from
one rinse operation for another. Two-stage countercurrent
cascade rinsing is used by one plant which could meet the BAT
discharge flow by adding a third countercurrent cascade rinsing
stage combined with a slight reduction in the rinse ratio. By
using two-stage countercurrent cascade rinsing, with an expected
90 percent reduction in rinse water use, 20 of 26 plants can meet
the BAT discharge flow. The other six plants would need to add
additional countercurrent cascade rinsing stages, reduce their
rinse ratio, or use other more efficient rinsing techniques to
conserve water. As shown in an example presented in Section VII
(p. 776), the reduction in the flow that is achievable with two-
stage countercurrent cascade rinsing can be as high as 99.5
percent. For the aluminum forming category the BAT flow
allowance is based on 90 percent recycle.
Three of the seven plants with wet air pollution control devices
on cleaning or etching operations use water recycle. The BAT
wastewater discharge flow for the cleaning or etching scrubber
liquor stream is 1,933 1/kkg (463.5 gal/ton), which is based on
the mean normalized discharge flow of the two plants using
recycle.
The BAT discharge for continuous sheet casting spent lubricants
is identical to that of BPT 1.964 1/kkg (0.471 gal/ton). This is
based upon recycle of this stream.
1062
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Pollutants
The pollutants considered for regulation under BAT are listed in
Section VI, along with an explanation of why they have been
selected. The pollutants selected for regulation under BAT are
chromium (total), cyanide (total), zinc, and aluminum. The
organic pollutants, cadmium, copper, lead, nickel, and selenium,
listed in Section VI are not regulated under BAT. As discussed
previously, oil removal and the limitation placed on oil and
grease at BAT should result in reduction in the amount of organic
pollutants which are discharged, and by achieving the zinc,
chromium, and aluminum limitations, the other metals listed above
should also be removed.
Treatment Train
EPA has selected Option 2 as the basis for BAT in this subcate-
gory. Again, this option uses the same end-of-pipe technology as
BPT, with the addition of measures to reduce the flows from
selected waste streams. The end-of-pipe treatment configuration
is shown in Figure X-2. The combination of in-process control
and technology significantly increases the removals of pollutants
over that achieved by BPT and is cost effective.
Effluent Limitations
Table VII-20 (p. 807) presents the treatment effectiveness
corresponding to the BAT model treatment train for pollutant
parameters considered in the Rolling with Neat Oils Subcategory.
Effluent concentrations (one day maximum and ten day average
values) are multiplied by the normalized discharge flows summa-
rized in Table X-27 to calculate the mass of pollutants allowed
to be discharged per mass of product. The results of these
calculations are shown in Table X-28.
Benefits
In establishing BAT, EPA considered the cost of treatment and
control and the pollutant reduction benefits to evaluate economic
achievability. As shown in Table X-3 the application of BAT to
the total Rolling with Neat Oils Subcategory will remove approxi-
mately 1,790,870.2 kg/yr (3.940 million Ib/yr) of pollutants. As
shown in Table X-l the corresponding capital and annual costs
(1982 dollars) for this removal are $16.2 million and $8.13
million per year, respectively. As shown in Table X-9 the appli-
cation of BAT to direct dischargers only, will remove approxi-
mately 1,511,558.8 kg/yr (3.325 million Ib/yr) of pollutants. As
shown in Table X-2 the corresponding capital and annual costs
(1982 dollars) for this removal are $12.5 million and $6.13
million per year, respectively.
1063
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ROLLING WITH EMULSIONS SUBCATEGORY
Discharge Flows
Table X-29 lists the BAT wastewater discharge flows for core and
ancillary streams that received an allowance under BPT. The flow
allowances for the core operations are identical to BPT.
Ancillary streams with a BAT discharge allowance are from solu-
tion heat treatment contact cooling, cleaning or etching baths,
rinses, and scrubbers, and direct chill casting contact cooling.
The BAT wastewater discharge flow for the solution treatment
contact cooling water stream is 2,037 1/kkg (488.5 gal/ton). The
BAT wastewater discharge flows for cleaning or etching operations
are 179 1/kkg (43 gal/ton) for the cleaning or etching bath,
1,686 1/kkg (404.4 gal/ton) for the cleaning or etching rinse,
and 1,933 1/kkg (463.5 gal/ton) for cleaning or etching scrubber
liquor. Refer to the Rolling with Neat Oils Subcategory portion
of this section for further discussion of these flow allowances.
The BAT wastewater discharge flow for direct chill casting opera-
tions is 1,329 1/kkg (318.96 gal/ton). This is the same as the
BPT discharge flow and is based upon the average of plants that
recycle this stream.
Pollutants
The pollutants considered for regulation under BAT are listed in
Section VI, along with an explanation of why they have been
selected. The pollutants selected for regulation under BAT are
chromium (total), cyanide (total), zinc, and aluminum. The
organic pollutants, cadmium, copper, lead, nickel, arid selenium,
listed in Section VI are not regulated under BAT. . As discussed
previously, oil removal and the limitation placed on oil and
grease at BPT should result in reduction in the amount of organic
pollutants which are discharged, and by achieving the zinc,
chromium, and aluminum limitations, the other metals listed above
should also be removed.
Treatment Train
EPA has selected Option 2 as the basis for BAT in this subcate-
gory. Again, this option uses the same end-of-pipe technology as
BPT, with the addition of measures to reduce the flows from
selected waste streams. The end-of-pipe treatment configuration
is shown in Figure X-2. The combination of in-process control
and technology significantly increases the removals of pollutants
over that achieved by BPT and is cost effective.
1064
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Effluent Limitations
Table VII-20 (p. 807) presents the treatment effectiveness
corresponding to the BAT model treatment train for pollutant
parameters considered in the Rolling with Emulsions Subcategory.
Effluent concentrations (one day maximum and ten day average
values) are multiplied by the normalized discharge flows summa-
rized in Table X-29 to calculate the mass of pollutants allowed
to be discharged per mass of product. The results of these
calculations are shown in Table X-30.
Benefits
In establishing BAT, EPA considered the cost of treatment and
control and the pollutant reduction benefits to evaluate economic
achievability. As shown in Table X-4 the application of BAT to
the total Rolling with Emulsions Subcategory will remove approxi-
mately 12,338,901.1 kg/yr of pollutants (27.15 million Ib/yr).
As shown in Table X-l the corresponding capital and annual costs
(1982. dollars) for this removal are $16.5 million and $8.71
million per year, respectively. As shown in Table X-10 the
application of BAT to direct dischargers only, will remove
approximately 10,762,880.8 kg/yr (23.68 million Ib/yr) of
pollutants. As shown in Table X-2 the corresponding capital and
annual costs (1982 dollars) for this removal are $15.1 million
and $7.97 million per year, respectively.
EXTRUSION SUBCATEGORY
Discharge Flows
Table X-31 lists the BAT wastewater discharge flows for core and
ancillary streams that received an allowance under BPT. The core
allocation for BAT is less than BPT due to flow reduction applied
to the die cleaning waste streams. The Extrusion BAT core flow
allowance is 340.1 1/kkg (81.6 gal/ton).
The BAT wastewater discharge flow for the die cleaning bath and
rinse stream is 12.9 1/kkg (3.1 gal/ton). This normalized
discharge flow is based upon zero allowance for the die cleaning
rinse using flow reduction by countercurrent cascade rinsing and
total reuse of the reduced rinse' flow as make-up to the die
cleaning bath. The allowance for the die cleaning bath contribu-
tion is the same as the die cleaning bath BPT allowance. Three
plants currently practice total reuse of die cleaning rinse water
from bath make-up. Because the average amount of die cleaning
rinse discharge, 26.52 1/kkg (6.354 gal/ton), is greater than the
average die cleaning bath water use, 17.56 1/kkg (4.212 gal/ton),
rinse water flow reduction may be required at BAT. Countercur-
1065
-------
rent cascade rinsing is the
achieving the flow reduction.
model treatment technology for
The BAT wastewater discharge flow for the die cleaning scrubber
liquor stream is 275.5 1/kkg (66.08 gal/ton), which is the same
as the BPT flow. The BAT discharge flow for the miscellaneous
nondescript wastewater sources stream Is 45.0 1/kkg (10.8
gal/ton).
Ancillary streams with a BAT discharge allowance are from solu-
tion and press heat treatment, direct chill casting contact cool-
ing, extrusion press hydraulic fluid leakage, and cleaning or
etching baths, rinses and scrubbers.
The BAT wastewater discharge flow for the solution and press heat
treatment contact cooling water stream is 2,037 1/kkg (488.5
gal/ton), as discussed in the Rolling with Neat Oils Subcategory
of this section.
The BAT wastewater discharge flows for cleaning or etching opera-
tions are 179 1/kkg (43 gal/ton) for cleaning or etching baths,
1,391 1/kkg (334 gal/ton) for cleaning or etching rinses, and
1,933 1/kkg (463.5 gal/ton) for cleaning or etching scrubber
liquor. Refer to the discussion for the Rolling with Neat Oils
Subcategory of this section.
The BAT wastewater discharge flow for direct chill casting con-
tact cooling is 1,329 1/kkg (318.96 gal/ton). This is the same
as the BPT discharge flow and is based upon the average of plants
that recycle this stream.
The BAT wastewater discharge flow for extrusion press hydraulic
fluid leakage is the same as the BPT discharge flow and is based
on the average of plants that do not recycle this stream. EPA
visited several plants with emulsion-based hydraulic extrusion
presses after the public comment period to study the potential
for recycle of the hydraulic medium because we were aware that
there were plants that were currently doing so. We determined
that the modifications required for an existing plant would
include rerouting of collection pits and channels which are
generally a part of the floorspace and foundation, installation
of pumps to transfer the collected hydraulic fluid to a central
point for recycle, and possibly installation of a corrugated
plate separator-to separate insoluble oils and a filter to remove
dirt and debris. Recycle was considered for BAT and PSES; how-
ever, it was ultimately rejected because of the expense and the
complexity of these process changes that would be required for
existing plants to install recycle systems.
1066
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The degassing scrubber liquor stream is zero allowance at BAT.
Application of the alternative fluxing and in-line refining
methods discussed in Section VII (p. ), eliminate the need for
wet air pollution controls associated with degassing of aluminum
melts prior to casting. Because this technology is currently
available and in use at most aluminum forming plants with casting
operations, dry air pollution control has been identified as the
BAT control. Aluminum refining is regulated under the nonferrous
metals manufacturing category and any predefining step before
casting that requires air pollution control which generates a
wastewater stream should be regulated under the appropriate sub-
category of nonferrous metals manufacturing.
Pollutants
The pollutants considered for regulation under BAT are listed in
Section VI, along with an explanation of why they have been
selected. The pollutants selected for regulation under BAT are
chromium (total), cyanide (total), zinc, and aluminum. The
organic pollutants, cadmium, copper, lead, nickel, and selenium,
listed in Section VI are not regulated under BAT. As discussed
previously, oil removal and the limitation placed on oil and
grease at BPT should result in reduction in the amount of organic
pollutants which are discharged, and by achieving the zinc, chro-
mium, and aluminum limitations, the other metals listed above
should also be removed.
Treatment Train
EPA has selected Option 2 as the basis for BAT in this subcate-
gory. Again, this option uses the same end-of-pipe technology as
BPT, with the addition of measures to reduce the flows from
selected waste streams. The end-of-pipe treatment configuration
is shown in Figure X-2. The combination of in-process control
and technology significantly increases the removals of pollutants
over that achieved by BPT and is cost effective.
Effluent Limitations
Table VII-20 (p. 807) presents the treatment effectiveness
corresponding to the BAT model treatment train for pollutant
parameters considered in the Extrusion Subcategory. Effluent
concentrations (one day maximum and ten day average values) are
multiplied by the normalized discharge flows summarized in Table
X-31 to calculate the mass of pollutants allowed to be discharged
per mass of product. The results of these calculations are shown
in Table X-32.
1067
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Benefits
In establishing BAT, EPA considered the cost of treatment and
control and the pollutant reduction benefits to evaluate economic
achievability. As shown in Table X-5 the application of BAT to
the total Extrusion Subcategory will remove approximately
4,465,352.6 kg/yr (9.824 million Ib/yr) of pollutants. As shown
in Table X-l the corresponding capital and annual costs (1982
dollars) for this removal are $34.5 million and $23.7 million per
year, respectively. As shown in Table X-ll the application of
BAT to direct dischargers only, will remove approximately
3,002,188.1 kg/yr (6.605 million Ib/yr) of pollutants. As shown
in Table X-2 the corresponding capital and annual costs (1982
dollars)-for this removal are $18.3 million and $10.1 million per
year, respectively.
FORGING SUBCATEGORY
There are no direct discharging facilities which use forging pro-
cesses to form aluminum. Consequently, the Agency is excluding
the Forging Subcategory from regulation under BPT and BAT. The
discussion which follows is presented for consistency and
completeness.
Discharge Flows
Table X-33 lists the BAT wastewater discharge flows for core and
ancillary streams that received an allowance under BPT. The pro-
duction normalized discharge flow for the core under BAT is equal
to the core discharge flow under BPT.
Ancillary streams with a BAT discharge allowance are from forging
scrubbers, solution heat treatment contact cooling, and cleaning
or etching baths, rinses, and scrubbers. The BAT wastewater
discharge flow for the forging scrubber liquor stream is 94.31
1/kkg (22.65 gal/ton). Three aluminum forming plants with dry
air pollution control systems use baghouses or afterburners.
Because of high operating and maintenance costs and fire hazards
associated with the baghouses, dry air pollution control systems
have not been selected for BAT. Of the three plants using wet
scrubbers, two recirculate the scrubber water with periodic
discharge, while one plant does not recirculate and discharges
continuously. The BAT discharge flow is the average of the flows
for the two plants with recirculating scrubbers.
The BAT wastewater discharge flow for the solution heat treatment
contact cooling water stream is 2,037 1/kkg (488.5 gal/ton), as
discussed in the Rolling with Neat Oils Subcategory of this
section.
1068
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The BAT wastewater discharge flows for cleaning or etching opera-
tions are 179 1/kkg (43 gal/ton) for the cleaning or etching
bath, 1,391 1/kkg (334 gal/ton) for the cleaning or etching
rinse, and 1,933 1/kkg (463.5 gal/ton) for cleaning or etching
scrubber liquor. Refer to the discussion for the Rolling with
Neat Oils Subcategory of this section.
Pollutants
The pollutants considered for regulation under BAT are listed in
Section VI, along with an explanation of why they have been
selected. The pollutants selected for regulation under BAT are
chromium (total), cyanide (total), zinc, and aluminum. The
organic pollutants, cadmium, copper, lead, nickel, and selenium,
listed in Section VI are not regulated under BAT. As previously
discussed, oil removal and the limitation placed on oil and
grease should result in reduction in the amount of organic pollu-
tants which are discharged, and by achieving the zinc, chromium,
and aluminum limitations, the other metals listed above should
also be removed.
Treatment Train
EPA has selected Option 2 as the basis for BAT in this subcate-
gory. Again, this option uses the same technology as BPT, with
the addition of measures to reduce the flows from selected waste
streams. The end-of-pipe treatment configuration is shown in
Figure X-2. The combination of in-process control and technology
significantly increases the removals of pollutants over that
achieved by BPT and is cost effective.
Effluent Limitations
Table VI1-20 (p. 807) presents the treatment effectiveness
corresponding to the BAT treatment train for pollutant parameters
considered in the Forging Subcategory. Effluent concentrations
(one day maximum and ten day average values) are multiplied by
the normalized discharge flows summarized in Table X-33 to
calculate the mass of pollutants allowed to be discharged per
mass of product. The results of these calculations are shown in
Table X-34.
Benefits
In establishing BAT, EPA considered the cost of treatment and
control and the pollutant reduction benefits to evaluate economic
achievability. As shown in Table X-6 the application of BAT
level technology to the total Forging Subcategory will remove
approximately 794,745.9 kg/yr (1.748 million Ib/yr) of
pollutants. As shown in Table X-l the corresponding capital and
1069
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annual costs (1982 dollars) for this removal are $4.87 million
and $2.32 million per year, respectively.
DRAWING WITH NEAT OILS SUBCATEGORY
Discharge Flows
Table X-35 lists the BAT wastewater discharge flows for core and
ancillary streams that received an allowance under BPT. The BAT
discharge flow from the core is the same as the BPT discharge
flow.
Ancillary streams with a BAT discharge allowance are from contin-
uous rod casting, solution heat treatment contact cooling, and
cleaning or etching baths, rinses, and scrubbers.
The continuous rod casting contact cooling stream is reduced
under BAT to 193.3 1/kkg (46.4 gal/ton) of aluminum cast, with
the application of recycle. The flow allowance is based on the
average of three flows, two of which are from primary aluminum
plants practicing recycle. The third is based on the application
of 90 percent recycle of the one aluminum forming flow available.
One aluminum forming plant reported recycle with only periodic
discharge of the continuous rod casting cooling stream, however,
they did not provide data to calculate their production normal-
ized flows. Seventeen aluminum forming plants, five primary
aluminum plants and one secondary aluminum plant, which recycle a
similar type of cooling stream to direct chill casting, reported
recycle rates of greater than 90 percent. Therefore, the Agency
believes that the flow based on the application of recycle is
appropriate for this waste stream.
The BAT wastewater discharge flow for the solution heat treatment
contact cooling water stream is 2,037 1/kkg (488.5 gal/ton), as
discussed in the Rolling with Neat Oils Subcategory of this
section.
The BAT wastewater discharge flows for cleaning or etching opera-
tions are 179 1/kkg (43 gal/ton) for the cleaning or etching
bath, 1,391 1/kkg (334 gal/ton) for the cleaning or etching
rinse, and 1,933 1/kkg (463.5 gal/ton) for the cleaning or etch-
ing scrubber liquor. Refer to the discussion for the Rolling
with Neat Oils Subcategory of this section.
Pollutants
The pollutants considered for regulation under BAT are listed in
Section VI, along with an explanation of why they have been
selected. The pollutants selected for regulation under BAT are
chromium (total), cyanide (total), zinc, and aluminum. The
1070
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organic pollutants, cadmium, copper, lead, nickel, and selenium,
listed in Section VI are not regulated under BAT. As discussed
previously, oil removal and the limitation placed on oil and
qrease at BPT should result in reduction in the amount of organic
pollutants which are discharged, and by achieving the zinc,
chromium, and aluminum limitations, the other metals listed above
should also be removed.
Treatment Train
EPA has selected Option 2 as the basis for BAT in this subcate-
aorv. Again, this option uses the same end-of-pipe technology as
BPT with the addition of measures to reduce the flows from
selected waste streams. The end-of-pipe treatment configuration
is shown in Figure X-2. The combination of in-process control
and technology significantly increases the removals of pollutants
over that achieved by BPT and is cost effective.
Effluent Limitations
Table VII-20 (p. 807) presents the treatment effectiveness
corresponding to the BAT model treatment train for pollutant
parameters considered in the Drawing with Neat Oils Subcategory.
Effluent concentrations (one day maximum and ten day average
values) are multiplied by the normalized discharge flows
summarized in Table X-35 to calculate the mass of pollutants
allowed to be discharged per mass of product. The results of
these calculations are shown in Table X-36.
Benefits
In establishing BAT, EPA considered the cost of treatment and
control and the pollutant reduction benefits to evaluate economic
achievability. As shown in Table X-7 the application of BAT to
the total Drawing with Neat Oils Subcategory will remove approxi-
mately 788,995.7 kg/yr (1.736 million Ib/yr) of pollutants. As
shown in Table X-l the corresponding capital and annual costs
(1982 dollars) for this removal are $3.96 million and $1.96
million per year, respectively. As shown in Table X-l2 the
application of BAT to direct dischargers only, will remove
approximately 559,481.0 kg/yr (1.231 million Ib/yr) of pollu-
tants. As shown in Table X-2 the corresponding capital and
annual costs (1982 dollars) for this removal are $2.21 million
and $1.00 million per year, respectively.
1071
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DRAWING WITH EMULSIONS OR SOAPS SUBCATEGORY
Discharge Flows
Table X-37 lists the BAT wastewater discharge flows for
3iSchi?X SJ"™. that received an allowance'unde? IPT he
BP?CS?s?harge°fl0w?r ^ COre °f thiS sub-tegory is equal to he
Ancillary streams with a BAT discharge allowance are from contin-
uous rod casting, solution heat treatment contact coolinS and
cleaning or etching baths, rinses, and scrubbers COOlinq' and
"??? f?C cleani^ or etching opera-
Pollutants
chrium(tota,,cyne Uol - -^ulatlon der BAT are
organic. pollutiita^SSSiu. Copper, lead,' niSkel^an^^ienium6
Treatment Train
, with the
- -
of measures to reduce the flows from
1072
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selected waste streams. The end-of-pipe treatment configuration
is shown in Figure X-2. The combination of in-process control
and technology significantly increases the removals of pollutants
over that achieved by BPT and is cost effective.
Effluent Limitations
Table VII-20 (p. 807) presents the treatment effectiveness
corresponding to the BAT model treatment train for pollutant
parameters considered in the Drawing with Emulsions or Soaps
Subcategory. Effluent concentrations (one day maximum and ten
day average values) are multiplied by the normalized discharge
flows summarized in Table X-37 to calculate the mass of pollu-
tants allowed to be discharged per mass of product. The results
of these calculations are shown in Table X-38.
Benefits
In establishing BAT, EPA considered the cost of treatment and
control and the pollutant reduction benefits to evaluate economic
achievability. As shown in Table X-8 the application of BAT to
the total Drawing with Emulsions or Soaps Subcategory will remove
approximately 140,583.4 kg/yr (0.309 million Ib/yr) of
pollutants. As shown in Table X-l the corresponding capital and
annual costs (1982 dollars) for this removal are $0.62 million
and $0.27 million per year, respectively. As shown in Table X-l3
the application of BAT to direct dischargers only, will remove
approximately 57,501.6 kg/yr (0.127 million Ib/yr) of pollutants.
As shown in Table X-2 the corresponding capital and annual costs
(1982 dollars) for this removal are $0.41 million and $0.18
million per year, respectively.
1073
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