DEVELOPMENT DOCUMENT
                   FOR
     EFFLUENT LIMITATIONS GUIDELINES
    NEW SOURCE PERFORMANCE STANDARDS
                   AND
         PRETREATMENT STANDARDS
                 FOR THE
            ORGANIC CHEMICALS
                 AND THE
      PLASTICS AND SYNTHETIC FIBERS
          POINT SOURCE CATEGORY
                Volume  I

              Lee M. Thomas
              Administrator

            Lawrence J.  Jensen
    Assistant Administrator for Water

         William  A.  Whittington
                Director
Office of Water Regulations and Standards
        Devereaux Barnes,  Director
      Industrial Technology Division
             Marvin B. Rubin
     Chief,  Chemicals  Industry  Branch
             Elwood  H.  Forsht
          Senior  Project  Officer
              Frank H. Hund
               Hugh E.  Wise
             Janet  K.  Goodwin
              Wendy D.  Smith
               Project Team
               October 1987
      Industrial Technology Division
Office of Water Regulations and Standards
   U.S.  Environmental Protection Agency
         Washington, D.C.  20460

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                                   ABSTRACT
     This document describes the technical development of the U.S.
Environmental Protection Agency's promulgated effluent limitations guidelines
and standards that control the discharge of pollutants into navigable waters
and publicly owned treatment works (POTWs) by existing and new sources in the
organic chemicals, plastics, and synthetic fibers point source category.  The
regulation establishes effluent limitations guidelines attainable by the
application of the "best practicable control technology currently available"
(BPT) and the "best available technology economically achievable" (BAT),
Pretreatment standards applicable to existing and new discharges to POTWs
(PSES and PSNS, respectively), and new source performance standards (NSPS)
attainable by the application of the "best available demonstrated control
technology."  The regulation was promulgated under the authority of Sections
301, 304, 306, 307, 308, and 501 of the Clean Water Act (the Federal Water
Pollution Control Act Amendments of 1972, 33 U.S.C. 1251 et seq., as amended).
It was also promulgated in response to the Settlement Agreement in Natural
Resources Defense Council, Inc. v. Trian, 8 ERC 2120 (D.D.C. 1976), modified,
12 ERC 1833 (D.D.C.).

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                              TABLE OF CONTENTS
                                   VOLUME I
I.   INTRODUCTION

     A.  LEGAL AUTHORITY	     1-1

         1.  Best Practicable Control Technology Currently
               Available (BPT)	     1-2
         2.  Best Available Technology Economically
               AchieVable (BAT)	     1-3
         3.  Best Conventional Pollutant Control
               Technology (BCT) 	     1-3
         4.  New Source Performance Standards (NSPS).  .  ......  .  .     1-4
         5.  Pretreatment Standards for Existing
               Sources (PSES)	     1-4
         6.  Pretreatment Standards for New Sources (PSNS).  .  .  .     1-4

     B.  HISTORY OF OCPSF RULEMAKING EFFORTS	     1-5

II.  SUMMARY AND CONCLUSIONS

     A.  OVERVIEW OF THE INDUSTRY	     H-l

     B.. ..-.CONCLUSIONS	     11-^5

         1.  Applicability of the  Promulgated Regulation.  ....     II-5
         2.  BPT	     II-6
         3.  BCT	     II-8
         4.  BAT	     II-8
         5.  NSPS	:.'.....	     11-11
         6.  PSES		'".     11-16
         7.  PSNS	     H-17

III. INDUSTRY DESCRIPTION

     A.  INTRODUCTION	     III-l

     B.  DEFINITION OF THE INDUSTRY	     III-3

         1.  Standard Industrial Classification System.  .....     III-3
         2.  Scope of  the Final Regulation.	  .     III-3
         3.  Raw Materials and Product Processes	     111-20
         4.  Geographic Distribution	     111-32
         5.  Plant Age	     111-32
         6.  Plant Size	     111-35
         7.  Mode of Discharge.	     111-41

     C.  DATA BASE DESCRIPTION. ....... 	     111-41

         1.  1983 Section 308 Questionnaire Data Base	     111-41
         2.  Daily Data Base Development	     111-46
         3.  BAT Data Base	     111-47
                                      111

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                         TABLE OF CONTENTS (Continued)
 IV.   SUBCATEGORIZATION

      A.   INTRODUCTION	      IV-1

      B.   BACKGROUND	„	      IV_2

          1.  March  21,  1983,  Proposal	      IV-2
          2.  July 17,  1985, Federal Register NOA	  ....      IV-3
          3.  December 8,  1986,  Federal Register	,•  •  •      IV-5

      C.   FINAL ADOPTED BPT AND  BAT SUBCATEGORIZATION
           METHODOLOGY AND RATIONALE	      IV-9

          1.  Performance  and  Treatment System Shifts.  ......      IV-12
          2.  Flow and  Total Production Adjustment Factors  ....      IV-13

     b.   FINAL ADOPTED BAT SUBCATEGORIZATION APPROACH  ......      IV-16

     E.   SUBCATEGORIZATION FACTORS. ...-..•	      IV-18

          1.  Introduction	      IV-18
          2.  Manufacturing Product/Process	      IV-19
          3.  Raw Materials	      IV-22
          4.  Facility  Size	.....'.....	      IV-24
          5.  Geographical Location	      IV-24
          6.  Age of Facility and Equipment	      IV-26
          7.  Wastewater Characteristics and Treatability	      IV-28

V.   WATER USE AND WASTEWATER CHARACTERIZATION

     A.  WATER USE AND SOURCES OF WASTEWATER	     V-l

     B.  WATER USE BY MODE OF DISCHARGE	     V-3

     C.  WATER USE BY SUBCATEGORY .	   '' V-3
        i
     D.  WATER REUSE AND RECYCLE.	     V-23

         1.  Water Conservation and Reuse Technologies	     V-23
         2.  Current Levels  of Reuse and Recycle	     V-24

     E.  WASTEWATER CHARACTERIZATION	     V-29

         1.  Conventional Pollutants	     V-29
         2.  Occurrence and  Prediction  of Priority Pollutants  . .     V-49
                                      iv

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                         TABLE OF CONTENTS  (Continued)
     F.  RAW WASTE¥ATER CHARACTERIZATION DATA  ....  !  .  .  ;. .  .      V-89

         1.   General	  .	  .  .".  . .'  '.      V-89
         2.   Raw tfastewater Data Collection Studies  .  .  .  .  ;. .  i      V-90
         3.   Screening Phase  I	 i  .      V-90
         4.   Screening Phase  II  .  .  .  .  . . .  .  • -..;'•  •  •  •  • .  •  ,    V-94
         5.   Verification Program .  .  .  ....  .  .  •  .  ...  ... '•  .••' '  •      V-94
         6.   EPA/CMA Five-Plant  Sampling .Program.  .  ....  . .,  .      V-101
         7.   12-Plant Long-Term  Sampling Program	-.".'•    V-103

   ,  G.  WASTEWATER DATA SUMMARY.  .  . '.  '..". V  . ,."".".'," •  ..".,".  X'.,...;,." '    V-105

         1.   Organic Toxic Pollutants .  ...  .  .  .  .  ......  . .  .  -.    V-105
         2.   Toxic Pollutant  Metals  .  .  ., . ...,..,.-.;.;.      V-112

VI.  SELECTION OF POLLUTANT PARAMETERS                   , ,

     A.  INTRODUCTION	 ....  .^ .  ..;.' ...;.;_/    VI-1

     B.  CONVENTIONAL POLLUTANT  PARAMETERS. ....  ,  •«,..> •  •  /.   VI-2

         1.   Five-Day Biochemical Oxygen Demand  (BOD5).  .  .  . .  . ,.    VI-2
         2.   Total Suspended  Solids  (TSS) . .  .  ..  ...  ...  . ,.•  . _    VI-3
         3.   PH	  ...,..'...  '<..,,..;.;;'.<•  .  :    VI-4
         4.   Oil and Grease .(O&G) ....  ... .. .  .  .  v.  .  .  !,v ...  . ,;-,   VI-5

     C.  NONCONVENTIONAL POLLUTANTiPARAMETERS  .  .  .  .'.  .  .  . '.  .      VI-6

         1.   Chemical Oxygen  Demand  (COD) . '.'".  .  .  .  .  .  .  . .  .      VI-6
         2.   Total Organic Carbon (TOC) •. . ...  .  -•-.  .  .  .. .;;, •:  ;- r    Vf-6

     D.  TOXIC POLLUTANT PARAMETERS . ... , . .. .  .• .  •..•  .  --,..., •  •  ,   .v?-7

     E.  SELECTION CRITERIA	  .  .  ,  •  >  ;.„ >;•*.}•;•••? \\    V,I-9

         1.   Conventional Pollutants. .  . . .  »,.,•; .. -•;. %;.>;...>-; >;.,« V*;'  VI-9
         2.   Nonconventional  Pollutants  ....  .' .  .  .  .  . .'  .  .      VI-10
         3.   Toxic Pollutants .  .. .  . .....  ,.. •• •-.•--.;-..:..- ..i,  .  ,    VI-10

     REFERENCES	  . '." .: .  .....  .  .  .  .  .  ...      VI-44
                                           -  V.,;-:--'-"-.;  --'I.-- ,; .; v.vif. ^' ^   ,'i- -
VII. CONTROL AND TREATMENT TECHNOLOGIES

     A.  INTRODUCTION  ...  ..... ....;... Y •.;.  .,  ..  ",,  "••.- .'-. -,--. .      VII-1

     B.  BEST MANAGEMENT PRACTICES	      VII-4

          1.   In-Plant Source  Controls 	      VII-4
         2.   Operation and Maintenance  (O&M)  Practices	      VII-9

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                    TABLE OF CONTENTS  (Continued)
 C.   IN-PLANT TREATMENT TECHNOLOGIES	     VII-11

     1.   Introduction	     VII-11
     2.   Chemical Oxidation (Cyanide Destruction) 	     VII-13
     3.   Chemical Precipitation 	     VII-18
     4.   Chemical Reduction (Chromium Reduction)	  .•     VII-27
     5.   Gas Stripping (Air and Steam).	     VII-29
     6.   Solvent Extraction	'.  .     VII-36
     7.   Ion Exchange 	  .  	  ........     VII-39
     8.   Carbon Adsorption	     VII-40
     9.   Distillation	..." 1  .'....     VII-42
     10.  Reverse Osmosis	„	     VII-44
     11.  Ultrafiltration.  	  	     VII-46
     12.  Resin Adsorption  	  .  	     VII-48
     13.  In-Plant Biological Treatment.  .  	     VII-48

 D.   END-OF-PIPE TREATMENT TECHNOLOGIES  	     VII-49

     1.   Introduction	  .     VII-49
     2.   Primary Treatment Technologies  ...........     VII-51
     3.   Secondary Treatment Technologies  	  .....      VII-61
     4.   Polishing and Tertiary Treatment  Technologies.  .  .  .      VII-105

 E.   TOTAL TREATMENT  SYSTEM PERFORMANCE  ...........      VII-125

     1.   Introduction	      VII-125
     2.   BPT Treatment System 	      VII-127
     3.   Nonbiological Treatment Systems	      VII-127
     4.   BAT Treatment System	  .      VII-137

 F.   WASTEWATER  DISPOSAL	      VII-138

     1.   Introduction	  .      VII-138
     2.   Deep Well  Injection	      VII-138
     3.   Off-Site Treatment/Contract Hauling.  .  .	      VII-147
     4.   Incineration 	  *...'......      VII-148
     5.   Evaporation. .	      VII-149
     6.   Surface Impoundment	      VII-149
     7.   Land Application	      VII-150

G.   SLUDGE TREATMENT AND DISPOSAL	      VII-150

H.  LIMITATIONS DEVELOPMENT	      VII-153

    1.  BPT Effluent Limitations 	     VII-153
    2.  BAT Effluent Limitations ....  	     VII-183
    3.  BAT and PSES Metals and Cyanide Limitations	     .VII-219
    4.  BAT Zinc Limitations for Plants Manufacturing
          Rayon by the Viscose Process and Acrylic
          Fibers by  the Zinc Chloride/Solvent Process. . . .     VII-227
                                 VI

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                         TABLE  OF  CONTENTS. (Continued)


                                                                       Page

         5.  PSES Effluent Limitations.  ..  . ....  .  ...  ,  . .. ...  .      VII-228

       REFERENCES 		      VII-230

 '":  ;                              ; VOLUME II

VIII.   ENGINEERING COSTS AND NON-WATER QUALITY ASPECTS

       A.  INTRODUCTION	,,., .    VIII-1

           1.  BPT Costing Methodology	      VIII-2
           2.  BAT Costing Methodology	      VIII-7
           3.  PSES Costing Methodology	      VIII-24
           4.  Other Factors.  ..................      VIII-26

       B.  BPT TECHNOLOGIES	;  *  .  .      VIII-40

           1.  Activated Sludge	,...,.•	      VIII-40
           2.  Biological Treatment Upgrades	      VIII-56
           3.  Chemically Assisted Clarification	      VIII-67
           4.  Filtration Systems .. .  .  .•  .  .  ....  .  .  ...  .      VIII-77
           5.  Polishing Ponds. ..................      VIII-78
           6.  Algae Control.  . .	      VIII-84

       C.  BAT AND PSES TECHNOLOGIES.  .	      VIII-95

           1.  Steam Stripping. .  . .	  .      VIII-95
           2.  Activated Carbon Systems  ......,,.	      VIII-119
 ;          3.  Coagulation/.Flocculation/Clarification  System.  .  .      VIII-139
           4.  Cyanide Destruction	  .  ,	      VIII-180
           5.  In-Plant Biological Treatment.  ..........  .      VIII-187

       D.  ADDITIONAL COSTS ...  	  .......  ......      VIII-197

           1.  Contract Hauling-	 .     VIII-197
           2.,  Monitoring Costs	      VIII-198
           3.  Sludge Disposal and Incineration  .  .  .  .  .  .  .  .  .      VIII-203
           4.  RCRA Baseline Costs, 	  .......  ,  ,  .      VIII-222

       E.  WASTEWATER AND AIR EMISSION LOADINGS  ...  	      VIII-236

           1.  BPT Conventional Pollutant  Wastewater Loadings  .  .      VIII-236
  • -        2.  BAT and PSES Toxic\Pollutant  Wastewater            •
                 Loadings	  .  .  .	      VIII-236
 ,-  .       3.  BAT and PSES Toxic1 Pollutant  Air  Emission  . .   '
  ''               Loadings  . .  . .'...<..,  ....  . • .  .  .  :.  .  . •".'  .      VIII-270
                                      VII

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                         TABLE OF CONTENTS (Continued)
IX.  EFFLUENT  QUALITY ATTAINABLE  THROUGH THE APPLICATION OF
       BEST  PRACTICABLE  CONTROL TECHNOLOGY CURRENTLY AVAILABLE

     A.  INTRODUCTION	     ix_l

         1.  Regulated Pollutants .  .,	     IX-2
         2.  BPT  Subcategorization	     IX-2

     B.  TECHNOLOGY SELECTION	     IX-2

     C.  BPT EFFLUENT LIMITATIONS GUIDELINES	     IX-5

     D.  COST AND EFFLUENT REDUCTION BENEFITS	  . .  .     IX-9

     E.  IMPLEMENTATION OF THE BPT EFFLUENT LIMITATIONS
           GUIDELINES	     IX-9

     F.  NON-WATER QUALITY ENVIRONMENTAL IMPACTS	     IX-12

         1.  Air  Pollution. .  . ^ . .  . . . .   . . . . . . .  . .  .     IX-12
         2.  Solid Waste	  .     IX-13
         3.  Energy Requirement 	     IX-13

X.   EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION OF
       BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE

     A.  INTRODUCTION  . . .,	     X-l

     B.  BAT SUBCATEGORIZATION	     X-l

     C.  TECHNOLOGY SELECTION .	     X-2

         1.  Option I ......... 	  .......     X-3
         2.  Option II	     X-3
         3.  Option III	     X-4

     D.  POLLUTANT SELECTION	     X-4

     E.  BAT EFFLUENT LIMITATIONS GUIDELINES	     X-10

         1.  Volatiles Limits	     X-ll
         2.  Cyanide Limitations	     x-11
         3.  Metals Limitations 	     X-12
         4.  Other Organic Pollutants 	     X-28

     F.  COST AND  EFFLUENT REDUCTION BENEFITS  IMPLEMENTATION
           OF THE  BAT EFFLUENT.  .	     X-31
                                    Vlll

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       G.
                        TABLE OF JCONTENTS  (Continued)
LIMITATIONS GUIDELINES ...  .  .  .  .  .  ."".. .  •  •  •  •  •  •'   X-31
           1.  NPDES Permit Limitations  „  .	  ......    X-31
           2.  NPDES Monitoring Requirements.	  ~.  .    X-32

       H.  NON-WATER QUALITY ENVIRONMENTAL IMPACTS:  .  .  .  ...  .  .  .    X-36

           1.  Air Pollution	•    X-37
           2.  Solid Waste	  .  .   , X-37
           3.  Energy Requirements	    X-37

XI.    EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION OF
         NEW SOURCE PERFORMANCE STANDARDS  (NSPS)<

       A.  INTRODUCTION . . ..'..'  .	•  •  •  •  •  • ;  •  ••  •    XI-1

       B.  POLLUTANT AND TECHNOLOGY  SELECTION .  	  .....    XI-1

XII.   EFFLUENT QUALITY ATTAINABLE THROUGH THE PRETREATMENT
         STANDARDS FOR EXISTING SOURCES  AND  PRETREATMENT
         STANDARDS FOR NEW  SOURCES

       A.  INTRODUCTION	•    XII-1

       B.  POLLUTANT SELECTION.  ...  .:.'.  ......  ...;....    XII-1

       C.  TECHNOLOGY SELECTION  .............. ...  .    XII-2

       D.  PSES AND PSNS	    XII-3

       E.  COST AND EFFLUENT  REDUCTION BENEFITS .  .  .....  .  .  .    XII-6

       F.  NON-WATER QUALITY  ENVIRONMENTAL IMPACTS.  ........    XII-6

           1.  Air Pollution	'.' . .. .  .  .  . ,,.;-•..  .. •    XII-7
           2.  Solid Waste. .' .  ?. ._ ...  •  •  ......  •  •'•.-• -• . •  •  •  •    XII-7
           3.  Energy Requirements.	..'..-,	    XII-7

XIII.  BEST  CONVENTIONAL  POLLUTANT CONTROL TECHNOLOGY' ..'.i ...  .  .    XIII-1

XIV.   ACKNOWLEDGEMENTS	•	    XIV-1

XV.    GLOSSARY	'.	    XV-1

APPENDIX III-A:   PRODUCT  LISTINGS BY INDUSTRIAL'SEGMENT .  ..."." • •   III-A1

APPENDIX IV-A:    RATIONALE FOR THE FORM OF THE>BPT BOD5   :
                    REGRESSION MODEL	  	   IV-A1
                                       ix

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                          TABLE OF  CONTENTS  (Continued)
 APPENDIX VI-A:

 APPENDIX VII-A:


 APPENDIX VII-B:



 APPENDIX VII-C:



 APPENDIX VII-D:

 APPENDIX VII-E:

 APPENDIX VII-F:.

 APPENDIX VII-G:



 APPENDIX VIII-A:



 APPENDIX VIII-B:


 APPENDIX VIII-C:

APPENDIX VIII-D:


APPENDIX VIII-E:
 LIST OF THE 126 PRIORITY POLLUTANTS
 BPT LONG-TERM AVERAGE BOD- AND TSS PLANT-
   SPECIFIC TARGETS. . .	
 RAW WASTEWATER AND TREATED EFFLUENT BOD ,  TSS,
   COD,  AND TOC DATA BEFORE AND AFTER ADJUSTMENT
   BY PLANT-SPECIFIC DILUTION FACTORS. 	
 LISTING OF 69 BPT DAILY DATA PLANTS INCLUDED
   AND EXCLUDED FROM BPT VARIABILITY
   FACTOR CALCULATIONS .....  	
 BPT STATISTICAL METHODOLOGY ...

 DISTRIBUTIONAL HYPOTHESIS TESTING

 BAT STATISTICAL METHODOLOGY .  .  .
EVALUATION OF THE VALIDITY OF USING FORM 2C
  DATA TO CHARACTERIZE PROCESS AND FINAL
  EFFLUENT WASTEUATER JUNE 17, 1985 .  . .  .
METHODOLOGY FOR CALCULATING BPT TARGETS AND
  IMPUTING MISSING ACTUAL BODE AND TSS
  EFFLUENT VALUES ...  . . . . . . .
BPT, BAT, AND PSES COMPLIANCE COST ESTIMATES
  AND TECHNOLOGY BASIS	
BPT PLANT-BY-PLANT BOD. AND TSS LOADINGS.
BAT AND PSES PLANT-BY-PLANT TOXIC POLLUTANT
  WASTEWATER LOADINGS 	 ....
BAT .AND PSES PLANT-BY-PLANT AIR EMISSION
  LOADINGS	
 Page

 VI-A1


 VII-A1



 VII-B1



 VII-C1

 VII-D1

 VII-E1

 VII-F1



 VII-G1



 VIII-A1


 VIII-B1

 VIII-C1


VIII-D1


VIII-E1
                                      x

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LIST OF FIGURES
   VOLUME I
Figure
III-l

IV-1

IV-2

IV-3
IV-4
IV-5

IV-6
IV-7
V-I
V-2
V-3
V-4
V-5
V-6
V-7
V-8
V-9
V-10

V-ll
V-12
V-13


Relationships Among the SIC Codes Related to the
Production of Organic dhemicals, Plastics, and
Synthetic Fibers 	 	
Distribution of Plants by Product and BOD5
(Thermoplastics) .... . . . ...... 	 	
Distribution of Plants by Product and BOD5
(thermosets) . . . ....... . . ....*..••
Distribution of Plants by Product and BOD5 (Rayon) . . .
Distribution of Plants by Product and BOD5 (Fibers). . .
Distribution of Plants by Product and BODg
(Commodity) 	 • • v • ,« •*•*•** * •'
Distribution of Plants by Product and BOD5 (Bulk). . . .
Distribution of Plants by Product and BOD5 (Specialty) .
Primary Feedstock Sources 	 	 . . . . . . .
Coal Tar Refining. . . . ,. . . .... ...... ....

Ethylene ... 	 ..... 	 	
Propylene . . . . . . . • • • • ... • • .... • . . •
Butanes/Butenes. . . . . . .'•*..;'..'; . . . , . . . i '• >
Aromatics 	 	 . .. . • • . « «.• «, « •
Plastics and Fibers 	 • 	 	
Plastics and Fibers 	 	
Nitroaromatics, Nitrophenols, Benzidines, Phenols,
Nitrosamines 	 ................
Chlorophenols , Chloroaromatics, Haloaryl Ethers, PCBs. .
Chlorinated C2s, C4, Chloroalkyl Ethers 	
Chlorinated C3s, Chloroalkyl Ethers, Acrolein,
Arrvloni trile. Isoohorone 	 '. . . .
rage

III-6

IV-30

IV-31
IV-32
IV-33

IV-34
IV-35
IV-36
V-57
V-58
V-59
V-6Q
V^-61
V-62
V-63
V-64
V-65

V-66
V-67
V-68

V-69
        xi

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LIST OF FIGURES (Continued)
Figure
V-14
V-15

V-16
VII-1

VII-2



VIII-1

VIII-2

VIII-3

VIII-4

VIII-5

VIII-6

VIII-7

VIII-8

VIII-9

VIII-10

VIII-11

VIII-12


Halogenated Methanes . . 	 	 	
Priority Pollutant (PRIPOL) Profile of the
OCPSF Industry . . 	 	
A Chemical Process 	
Solubility of Metal Hydroxides and Sulfides as a
Function of pH 	
Plot of Average TSS Effluent Versus BOD Effluent
for Plants With Biological Only Treatment With
> = 95% BOD5 Removal or BOD5 Effluent < = 40 mg/1. . .. . .
VOLUME II
Annualized Capital Cost Versus Additional
BOD Removal 	
Annualized Unit Capital Cost Curve Versus Additional
BOD5 Removal 	 	
Total Capital Cost Curve Versus Flow for Chemically
Assisted Clarification Systems 	
Annual O&M Cost Curve Versus Flow for Chemically
Assisted Clarification Systems 	
Land Requirements Curve Versus Flow for Chemically
Assisted Clarification Systems 	
Total Capital Cost Curve Versus Flow for Multi-
media Filter Systems 	
Annual O&M Cost Curve Versus Flow for Multi-media
• Filter Systems 	
Land Requirements Curve Versus Flow for Multi-
media Filter Systems 	
Total Capital Cost Curve Versus Flow for Polishing
Pond Systems 	
Annual O&M Cost Curve Versus Flow for Polishing
Pond Systems 	
Land Requirements Curve Versus Flow for Polishing
Pond Systems 	 	
Annual O&M Cost Curve Versus Flow for Algae
Control in Polishing Ponds Systems 	
Page
V-70

V-73
V-75

VII-20


VII-167


VIII-64

VIII-65

VIII^72

VIII-73

VIII-74

VIII-81

VIII-82

VIII-83

VIII-86

VIII-87

VIII-88

VIII-91
          xii

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                          LIST OF  FIGURES  (Continued)
Figure

VIII-13  Capital Cost Curve Versus Flow for Benzene at
           Effluent Concentration of 0.01 mg/1.  .  . .	•     VII.I~>11

VIII-14  Capital Cost Curve Versus Flow for Benzene at
           Effluent Concentration of 1.0 rag/1	     VIII-112

VIII-15  Capital Cost Curve Versus, Flow for Hexachloro-
           benzene at Effluent Concentration of  0.01  mg/1  .  .  •  •     VIII-113

VIII-16  Capital Cost Curve Versus Flow for Hexachloro-
           benzene of Effluent-Concentration of  1.0 mg/1;'"." .  .  !;  '   VIIT-114

VIII-17  Annual O&M Cost  Curve Versus  Flow for Benzene
           and Hexachlorobenzene.  	     VIII-llo

VIII-18  Total Capital  Cost Curve Versus Flow  for Large  BAT
           In-Plant Control Carbon Treatment Systems;
           Medium Carbon  Adsorption  Capacity.  ..........     VIII-143

VIII-19  Total Capital  Cost Curve Versus Flow  for Large  PSES
'<••«'.'     In-Plant Control Carbon Treatment Systems;
           Medium Carbon  Adsorption  Capacity.  .  . 	 '  '  .V

VIII-20  Annual O&M Cost  Curve Versus  Flow for Large  BAT
           In-Plant Control Carbon Treatment  Systems;
           Medium Carbon  Adsorption  Capacity.  .  . .   . .  .  • •  •  •      VIII-1

VIII-21  Annual O&M Cost  Curve Versus  Flow for Large  PSES              .-...•>
           In-Plant Control Carbon Treatment  Systems;
           Medium Carbon  Adsorption  Capacity.  ...   . .  .  . .  .  •      VIII-146

VIII-22  Total  Capita! Cost  Curve Versus Flow for Large BAT                 -
'•',   "      In-Plant  Control  Carbon Treatment  Systems;
           Low  Carbon Adsorption Capacity 	      VIII-147
                             ....-.,  .   :. .    , '    .-.,:"•  ,     <:<•. •  '••;••'';" -1   '. . •-.•' ' * '

VIII-23  Total  Capital Cost  Curve Versus Flow for Large PSES
           In-Plant  Control  Carbon Treatment Systems;
            Low  Carbon Adsorption Capacity .  .  ...  . ;  .- . . % . ;    VIII-T48

VIII-24  Annual O&M Cost Curve Versus Flow for  Large BAT               ....,„
            In-Plant Control Carbon Treatment Systems;                    •
            Low Carbon Adsorption Capacity .......... •'* .'    VIII-149

 VIII-25   Annual O&M Cost Curve Versus Flow for  Large PSES
            In-Plant Control Carbon Treatment Systems;
            Low Carbon Adsorption Capacity	, • •     VIII-150

 VIII-26   Total Capital Cost Curves Versus Flow  for Large
            End-of-Pipe Carbon Treatment Systems (On-site              ,
            Carbon Regeneration Systems) . . . .  . •  ...» . • •     VIH-151
                                      XI11

-------
                            LIST  OF  FIGURES  (Continued)
  Figure
  VIII-27  Annual O&M Cost Curves Versus Flow for Large
             End.-of-Pipe Carbon Treatment Systems (On-site
             Carbon Regeneration Systems) 	      VIII-152

  VIII-28  Total Capital Cost Curve Versus Flow for Small
             In-Plant and End-of-Pipe Carbon Treatment
             Systems (Low,  Medium,  High Carbon Adsorption
             Capacities)	_      VIII-157

  VIII-29  Annual O&M Cost  Curve Versus Flow for Small BAT
             In-Plant Control Carbon Treatment Systems;
             Medium Carbon  Adsorption Capacity	      VIII-158

  VIII-30  Annual O&M Cost  Curve Versus Flow for Small PSES
             In-Plant Control Carbon Treatment Systems;
             Medium Carbon  Adsorption Capacity	      VIII-159

 VIII-31   Annual  O&M Cost  Curve Versus  Flow for  Small BAT
             In-Plant  Control  Carbon  Treatment  Systems;
             Low Carbon Adsorption Capacity	    VIII-160

 VIII-32  Annual O&M Cost Curve Versus Flow  for  Small PSES
            In-Plant Control Carbon Treatment Systems;
            Low Carbon Adsorption Capacity	    VITi-161

 VIII-33  Annual O&M Cost Curves Versus Flow for Small
            End-of-Pipe Carbon Treatment Systems	    VIII-162

 VIII-34  Land Requirements Curve Versus Flow for Activated
            Carbon Treatment Systems	     VIII-163

 VIII-35  Total Capital Cost Curve Versus Flow for
            Coagulation/Flocculation/Clarification Systems	     VIII-166

 VIII-36  Land Requirements Curve Versus Flow for
            Coagulation/Flocculation/Clarification Systems	     VIII-168

 VIII-37  Annual  O&M Cost Curve Versus Flow  for
            Coagulation/Flocculation/Clarification Systems	     VIII-169

 VIII-38  Comparison of  Actual Systems Capital Cost and EPA's
            Estimates for Coagulation/Flocculation/
            Clarification 	         VIII-17T

VIII-39  Total Capital  Cost  Curve Versus Flow for Sulfide
            Precipitation Systems	    VIII-177

VIII-40  Annual O&M  Cost Curve  Versus Flow  for Sulfide
           Precipitation Systems 	    VIII-178
                                     xiv

-------
LIST OF FIGURES (Continued)
Figure
VIII-41
VIII-42

VIII-43
VIII-44
VIII-45

VIII-46

VII 1-47
VIII-48
VIII-49
, , .
VIII-50

VIII-51

VIII-52
VIII-53

VIII-54

VIII-55
VIII-56

VIII-57

Total Capital Cost Curve Versus Flow for Cyanide
Destruction Systems 	 	
Annual O&M Cost Curve Versus Flow for Cyanide
Destruction Systems . . ... . . . . • • - 	
Total Capital Cost Curve Versus Flow for Small
In-Plant Biological Treatment Systems 	
Total Capital Cost Curve Versus Flow for Large
In-Plant Biological Treatment Systems 	
Annual O&M Cost Curve Versus Flow for Small
In-Plant Biological Treatment Systems . . . . . .......
Annual O&M Cost Curve Versus Flow for Large
In-Plant Biological Treatment Systems .........
Land Requirements Curve Versus Flow for Small
In-Plant Biological Treatment Systems 	
Land Requirements Curve Versus Flow for Large
In-Plant Biological Treatment Systems . . . ... .....
Total Capital Cost Curve Versus Flow for Belt
Filter Press Systems., . . ... ... « «. • • -• - • •
Land Requirements Curve Versus Flow for Belt
Filter Press Systems. . . . 	 	 .•-.•.-.••
Annual O&M Cost Curve Versus. Flow for Belt
Filter Press Systems., 	 .- . . . ....
Total Capital. Cost Curve Versus Flow for
Fluidized Bed Incineration Systems. . .. . . < . . •
Annual O&M Cost Curve Versus Flow for.
Fluidized Bed Incineration, Systems. ........
Overview of Methodology for Identification of
OCPSF Plants Requiring RCRA Baseline Costing* ... ..
Raw Waste Load Calculation Logic Flow 	
BPT, BAT, and Current Waste Load Calculation
Logic Flow 	
PSES Waste Load Calculation 	 	 ..
rage
, , VIII-185

, . VIII-186
VIII-190
, . VIII-191

VIII-192

VIII-193
VIII-195
VIII-196
" • , >
. . VIII-209
.,
. . VIII-210

VIII-212
VIII-217

VIII-219

VIII-223
VIII-261

VIII-268
, . VIII-269
              XV

-------
                                 LIST OF TABLES
                                    VOLUME I

 Table

 II-l      BPT Effluent Limitations and NSPS by
             Subcategory (mg/1)	    I]:_9

 II-2      BAT Effluent Limitations and NSPS for the End-of-.
             Pipe Biological Treatment Subcategory	    11-12

 II-3      BAT Effluent Limitations and NSPS for the Non-End-
             of-Pipe Biological Treatment Subcategory 	    11-14

 II-4      Pretreatment Standards for Existing and New Sources
             (PSES and PSNS)	      H-1Q

 III-l     SIC 2865:  Cyclic (Coal Tar),- Crudes,  and Cyclic
             Intermediates,  Dyes,  and Organic Pigments
             (Lakes and Toners) 	    111-10

 III-2     SIC 2869:  Industrial Organic Chemicals,  Not
             Elsewhere Classified	 .    111-12

 III-3     SIC 2821:  Plastic  Materials,  Synthetic Resins,
             and  Nonvulcanizable Elastomers  	    111-15

 III-4     SIC 2823:  Cellulosic Man-Made Fibers	    111-16

 III-5     SIC 2824:  Synthetic Organic  Fibers, Except
             Cellulosic 	    111-17

 III-6     OCPSF  Chemical Products Also  Listed as  SIC  29110582
             Products  	     111-18

 III-7     OCPSF  Chemical Products Also  Listed as  SIC 29116324
             Products  	     111-19

 III-8     Major  Generalized Chemical Reactions and Processes
             of the  Organic Chemicals, Plastics, and
             Synthetic  Fibers Industry	       111-29

 III-9      Plant  Distribution by State	     111-33

 111-10     Distribution of Plants by age of Oldest OCPSF
            Process Still Operating as of 1984 	     111-34

III-ll     Plant  Distribution by Number of Employees	       111-36

111-12    Plant  Distribution by Number of Product/Processes
            and  Product/Product Groups for Primary Producers
            That are Also "Direct and/or Indirect Dischargers . . .    111-37
                                     xvi

-------
                          LIST OF TABLES (Continued)
Table
111-13    Distribution of 1982 Plant Production Quantity by
            OCPSF SIC Group. ........ ......... .  • .'

111-14    Distribution of 1982 Plant Sales Value by OCPSF
            SIC Group ......  ..........•••••••

111-15    Mode of Discharge ..... •  •  .....  •  •  ......    111-42

111-16    Data Base Designation.  ...... ..  ^  ........    111-49

IV-1      BAT Effluent Estimated  Long-Term Average  Concentration
            Comparison Between Plastics and  Organics  Plants
            and Pure BPT  Subcategory Plants ..........  •  .    IV-4U

V-l       Total OCPSF Plant Process Wastewater Flow
            Characteristics by Type of Discharge  .........    v-4

V-2       Total OCPSF Plant Nonprocess Wastewater Flow
            Characteristics by Type of Discharge  .........    V-5

V-3        Process Wastewater Flow for  Primary  OCPSF Producers by
             Subcategory  and Disposal Method. ...  ........     v '

V-4        Process Wastewater Flow During 1980  for Secondary
             OCPSF Producers by Subcategory and Disposal Method .  .     V-«

 V-5        Process Wastewater Flow for Primary  and Secondary
             OCPSF Producers That are Zero/Alternative
             Dischargers ................. •*'.**.*'

 V-6       Non-Process Wastewater Flow During 1980 for Secondary
             OCPSF Producers and Zero/Alternative Dischargers
             by Subcategory and Disposal Method ..........     "-1U

 V-7       Total OCPSF Non-Process Wastewater Flow  in  1980 for
             Primary Producers by Subcategory and Disposal
             Method , ..... ..................    V~li

 V-8       Non-Process Cooling Water Flow for Primary  OCPSF
             Producers by Subcategory  and Disposal  Method  .....    v-i*.

 V-9       OCPSF  Miscellaneous Non-Cooling Non-Process
             Wastewater Flow for  Primary Producers  by Sub-
             category and Disposal Method  .  .....  .......

 V-10     Process Wastewater Flow for Primary OCPSF  Producers
             by Subcategory and Disposal Method ..........     v
                                       xvii

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                            LIST OF TABLES (Continued)
  V-12



  V-13



  V-14



  V-15


  V-16



 V-17

 V-18


 V-19



 V-20



 V-21



 V-22



 V-23



V-24
  Process Wastewater Flow During 1980 for Secondary
    OCPSF Producers by Subcategory and Disposal Method .  .    V-15

  Process Wastewater Flow for Primary and Secondary
    OCPSF Producers That are Zero/Alternative
    Dischargers	             V-16

  Non-Process Wastewater Flow During 1980 for Secondary
    OCPSF Producers and Zero/Alternative Dischargers
    by Subcategory and Disposal Method 	     V-17

  Total OCPSF Non-Process Wastewater Flow in  1980 for
    Primary  Producers  by Subcategory and Disposal
    Method	     V-18

  Non-Process  Cooling  Water  Flow for Primary  OCPSF
    Producers  by Subcategory and Disposal Method  	     V-19

  OCPSF Miscellaneous  Non-Cooling Non-Process Waste-
   water Flow for Primary Producers  by  Subcategory
   and Disposal Method	?.....    V-20

 Water Conservation and Reuse Technologies	 .    v-25

 Water Reciirculated and Reused by Use for the OCPSF
   Industries 1978 Census Data (a)	    v_2y

 Summary of OCPSF Process and Nonprocess Wastewater
   Recycle Flow for Primary Producers Excluding
   Zero Dischargers 	 ?.....     V-28

 Summary Statistics of Raw Wastewater BOD Concen-
   trations  by Subcategory Group and Disposal Methods
   Producer  = Primary	       V 32

 Summary Statistics  of Raw Wastewater BOD Concen-
   trations  by Subcategory Group and Disposal Method
   Producer  =  Secondary	^       v_33

 Summary  Statistics  of Raw Wastewater COD Concen-
   trations  by Subcategory Group and  Disposal Method
   Producer  = Primary  	  ......         v-34

Summary Statistics  of Raw Wastewater  COD Concen-
   trations  by Subcategory Group  and Disposal Method
  Producer  = Secondary	• .^      v_35

Summary Statistics of Raw Wastewater TOC Concen-
  trations by Subcategory Group and Disposal Method
  Producer = Primary	;	     v_36
                                    xviii

-------
                          LIST OF TABLES (Continued)
Table
V-25      Summary Statistics of Raw Wastewater TOG Concen-
            trations by Subcategory Group and Disposal Method
            Producer = Secondary	•  •  • •.  •  •    V-37

V-26      Summary Statistics of Raw Wastewater TSS Concen-
            trations by Subcategory Group and Disposal Method
            Producer = Primary 		    V-38

V-27      Summary Statistics of Raw Wastewater TSS Concen-
            trations by Subcategory Group and Disposal Method
            Producer = Secondary .  .	• -.' -•.  -  •• •  v '    V-39

V-28      Summary Statistics of ,Raw Wastewater BOD Concen-
            trations by Subcategory Group and Disposal Method
            (with 95% and  70% Rule) Producer = Primary  ......    V-41

V-29      Summary Statistics of Raw Wastewater BOD Concen-
            trations by Subcategory Group and Disposal Method
            (with 95% and  70% Rule) Producer = Secondary  .....    V-42

V-30      Summary Statistics of Raw Wastewater COD Concen-
             trations by Subcategory Group and Disposal Method
            (with 95% and  70% Rule) Producer = Primary  .  .  .  .  .  .    V-43

V-31      Summary Statistics of Raw Wastewater COD Concen-
            trations by Subcategory Group and Disposal  Method
            (with 95% and  70% Rule) Producer = Secondary  .  .  •  •  •    v~44

V-32      Summary Statistics of.Raw Wastewater TOG Concen-
             trations by  Subcategory Group and Disposal  Method
             (with 95% and  70% Rule) Producer = Primary  .  .  .  •  •  •    v-45

V-33       Summary Statistics of Raw Wastewater TOG Concen-
             trations by  Subcategory Group and Disposal  Method
             (with 95% and  70% Rule) Producer  =  Secondary	    V-46

V-34       Summary  Statistics  of  Raw Wastewater TSS  Concen-   .
             trations  by  Subcategory Group  and  Disposal  Method
             (with  95%  and  70% Rule) Producer .=  Primary  .  .  . .  v     v-47

V-35       Summary  Statistics  of  Raw Wastewater  TSS Concen-
             trations  by Subcategory Group  and Disposal  Method
             (with 95% and  70% Rule) Producer = Secondary ...  . .     V-48

 V-36       Generic Procceses Used to Manufacture Organic
             Chemical Products.  ,	     V-52

 V-37       Major Plastics and Synthetic Fibers Products by
             Generic Process.  ... .  . • •  •  •	•, •  • •     V-54
                                       xix

-------
                           LIST OF TABLES (Continued)
 Table

 V-38


 V-39


 V-40


 V-41


 V-42


 V-43


 V-44


 V-45


 V-46


 V-47


 V-48


 V-49


 V-50


 VI-1

 VI-2



VI-3
                                                             Page

 Critical Precursor/Generic Process Combinations
   That Generate Priority Pollutants. .  .	    V-72

 Organic Chemicals Effluents with Significant
   Concentrations (>0.5 ppm) of Priority Pollutants .  .  .    V-77

 Plastics/Synthetic Fibers Effluents with Significant
   Concentrations (>0.5 ppm) of Priority Pollutants .  .  .    V-81

 Priority Pollutants in Effluents of Precursor-
   Generic Process Combination	    V-84

 Overview of Wastewater Sampling Programs Included
   in BAT Raw Waste Stream Data Base.  .	    V-91

 Phase II Screening - Product/Process  and Other
   Waste Streams Sampled at Each Plant	    V-95

 Selection Criteria for Testing Priority Pollutants
   in Verification Samples.  .  .  .	     V-100

 Number of Sampling Days for 12-Plant  Long-Term
   Sampling Program	     V-104

 Summary Statistics for Influent  Concentrations for
   All OCPSF Plants	     V-106

 Summary Statistics  for Influent  Concentrations for
   Organics-Only OCPSF  Plants  	     V-108

 Summary Statistics  for Influent  Concentrations for
   Plastics-Only OCPSF  Plants  	  	     V-109

 Summary Statistics  for Influent Concentrations  for
   Organics  and  Plastics OCPSF Plants  .  .  	     V-110

 Summary of  Priority Pollutant Metal-Product/
   Process-Plant Validation  .  . . .  :	     V-115

Twenty-six Toxic Pollutants Proposed for Exclusion .  .  .    VI-8

Frequency of Occurrence and Concentration Ranges
  for Selected Priority Pollutants in Untreated
  Wastewater	  t       VI-12
 ..Toxic Pollutants Excluded from Regulation for BAT
  Subcategories One and Two Under Paragraph 8(a)(iii)
  of the Settlement Agreement Because they Were...  . ,
                                                                      VI-16
                                      xx

-------
                          LIST OF TABLES (Continued)
Table
Page
VI-4      Wastewater Loading for Eight Toxic Pollutants .
            Being Considered for Paragraph Eight Exclusion ..,.'. .    VI-19

VI-5      Four Toxic Pollutants Reserved from Regulation Under
            BAT for Subcategory One.	• • • •  • •    VI-21

VI-6      Eight Toxic Pollutants Reserved from Regulation
            Under BAT for Subcategory Two. 	  .... .  . .    VI-21

VI-7      Final PSES Pass-Through Analysis Results (Non-
            End-of-Pipe Biological Subcategory Data)  	    VI-23

VI-8      Final PSES Pass-Through Analysis Results (End-of-
            Pipe Biological Subcategory Data). ..........    VI-25

VI-9      Volatile and Semivolatile Toxic Pollutants
            Targeted for Control Due to Air Stripping, ......    VI-29

VI-10     Estimated POTW Removal Data from Pilot- or  Bench-.
            scale Studies for Selected Toxic Pollutants, ......    VI-35

VI-11     Forty-seven Toxic Pollutants Determined to  Interfere
            With, Inhibit, or Pass-Through POTWs, and Regulated
            Under PSES and PSNS Based on Table VII-7	    VI-39

VI-12     Six Toxic Pollutants Determined not to ,interfere
            With, Inhibit, or Pass-Through POTWs, and Excluded
            from Regulation Under PSES and PSNS.  ..........    VI-40

VI-13     Six Toxic Pollutants That Do Not Volatilize
            Extensively and Do Not  Have POTW Percent
            Removal Data	    VI-40

VI-14     Results of PSES Analysis  to Determine  if Toxic
            Pollutant Removals were "...Sufficiently  Controlled
            by  Existing Technologies..."  .	    VI-41

VI-15     Three Toxic Pollutants Excluded from PSES and PSNS
            Regulation Under  Paragraph 8(a)(iii)  of the Settle-
            ment Agreement because  they were  "...  Sufficiently.
            Controlled by Existing  Technologies..."	    VI-42

VI-16     Three Pollutants Reserved from  Regulation,Under
            PSES and PSNS Due to Lack of  POTW Percent.
            Removal Data  .  :	    VI-42

VII-1      Frequency of In-Plant Treatment Technologies  in  the
            OCPSF  Industry  Listed  by  Mode of  Discharge  and
            Type of Questionnaire  Response  	    VII-12
                                      xxi

-------
LIST OF TABLES (Continued)
Table

VII-2
VII-3

VII-4

VII-5

VII-6
VII-7
VII-8

VII-9


VII-10
VII-11

VII-12


VII-13

VII-14

VII-15

VII-16

VII-17

VII-18



Oxidation of Cyanide Wastes With Ozone 	
Performance Data for Total Cyanide Oxidation
Using Chlorination 	
Comparison of OCPSF and Metal Finishing Raw Waste
Metals and Cyanide Concentrations 	
Raw Waste and Treated Effluent Zinc Concentrations
from Rayon and Acrylic Fibers Manufacturing. ....
Henry's Law Constant (Hi) Groupings 	
Steam Stripping Performance Data 	 	
Steam Stripping and Activated Carbon Performance
Data ... 	
Daily Activated Carbon Performance Data for
Nitrobenzene, Nitrophenols, and 4,6-Dinitro-
0-Cresol Plant No. 2680T 	 . 	
Typical Ion Exchange Performance Data . . . . . .
Carbon Adsorption Performance Data from Plant
No. 2680T 	
Performance Data from Hydroxide Precipitation and
Hydroxide Precipitation Plus Filtration for
Metal Finishing Facilities . 	 	 	
Ultrafiltration Performance Data for Metals in
Laundry Wastewater-OPA Locka, Florida 	 	
Performance Data Basis for In-Plant Biological
Systems 	
Frequency of Primary Treatment Technologies in the
OCPSF Industry 	 	
Frequency of Secondary Treatment Technologies in
the OCPSF Industry 	
Frequency of Polishing/Tertiary Treatment
Technologies in the OCPSF Industry 	
Activated Sludge Performance Data for BOD
and TSS 	 5
Po IT A
rage
VII 15

VII-16

VII-25

VII 28
VII-33
VII-35

VII-37


VII-38
VII-41

VII-43


VII-45
} .
VII-47

VII-50

VII-52

VII-53

VII-54

VII-65
          XXll

-------
                         LIST OF TABLES  (Continued)
Table
VII-19
VII-20

VII-21

VII-22
VII-23

VII-24

VII-25

VII-26
VII-27
VM-28

VII-2.9

VII-30
VII-31
• j.
VII-32
"\
VII-33
: •;.,
VII-34
VII-35


Lagoon Performance Data for BOD5 and TSS 	
Attached Growth Treatment Systems Performance
Data for BOD5 and TSS 	 	 	 :
Typical Design Parameters for Secondary Clarifiers
Treating Domestic Wastewater. 	 	
Monthly BOD5 Removal Efficiency . 	
Monthly BOD Efficiency by Region Subset I
(Northern— WV, IA, IL, IN, RI). 	
Monthly BOD Efficiency by Region Subset II
(Southern— GA, LA, SC, TX). .... . . , 	 	
Monthly BOD Efficiency by Region Subset III
(Middle-Latitude— VA, NC) . . . 	 	
Average Effluent BOD by Month . . . . . . . . . . . . .
Average Effluent TSS by Month . . . . . . . . . . . . •
Monthly Effluent BOD5 by Region Subset I
(Northern— WV, IL, RI, IA, IN). 	 	
Monthly Effluent BOD5 by Region Subset H!
(Southern— TX, GA, LA, SC) 	 	
Monthly Effluent BOD. by; Region Subset III
(Middle-Latitude-,-VA, NC) 	 	 	
Monthly Effluent TSS by Region Subset I
(Northern— WV, IL, RI, IA, IN). . . . .... . . . .
Monthly Effluent TSS by Region Subset II
(Southern — TX, GA, LA, SC) 	 	
Monthly Effluent TSS by Region Subset III
(Middle-Latitude— VA, NC) 	 	
Monthly Data for Plant #2394. • • • •' • • • • • > • '« • '
Matrix of . 18 Plants With Polishing Ponds Used
as Basis for BPT Option II Limitations 	
Page
VII-69

VII-72

VII-74
VII-84

VII-85

VII-86

VII-87
VII-91
VII-92

VII-94

VII-95
VII-96

VII-97

VII-98

VII-99
VII-103

VII-106
VII-36    Option III OCPSF Plants With Biological Treatment
            Plus Filtration Technology That Pass the BPT
 '•}••'"      Editing Criteria	,. . .
VII-109
                                     xxiii

-------
                            LIST  OF TABLES  (Continued)
 VII-37     Summary  of  Chemically Assisted  Clarification
             Technology  Performance Data  .  .  .......... '.     VII-114

 VII-38     Final Effluent Quality of a Chemically Assisted
             Clarification System Treating Bleached
             Kraft  Wastewater .................. •  e     VII-116

 VII-39     Classes  of  Organic Compounds Adsorbed on Carbon ....     VII-121

 VII-40     Summary  of  Carbon Adsorption Capacities ..... ...     VII-122

 VII-41    End-of-Pipe Carbon Adsorption Performance Data
             from Plant No. 3033 ..................    VII-126

 VII-42    Treatment Technologies for Direct Nonbiological
             Plants. •  •*'• .....  ....... .  ........     VII-128

 VII-43    Performance of OCPSF Nonbiological Wastewater
             Treatment  Systems  .............. ....     VII-135

 VII-44    BOD5 and TSS Reductions  by Clarification at
             Selected Pulp,  Paper,  and Paperboard Mills ......     VII-136

 VII-45    List of  Regulated  Toxic  Pollutants and the
             Technology Basis for BAT Subcategory One and
             Two Effluent Limitations ...............     VII-139

 VII-46    Summary  of the Long-Term  Weighted Average  Effluent
             Concentrations  for  the  Final  BAT Toxic Pollutant
             Data Base  for BAT Subcategory One ....  ......      VII-142

 VII-46    Summary  of the Long-Term Weighted Average  Effluent
             Concentrations for  the Final  BAT Toxic Pollutant
             Data Base  for BAT Subcategory  Two ..........      VII-144

 VII-48    Frequency of Waste Stream Final  Discharge  and
             Disposal Techniques  ......  ...........      VII-146

 VII-49    Frequency of Sludge Handling, Treatment, and
             Disposal Techniques  ................ .      VII-151

 VII-50    Contaminated and Uncontaminated  Miscellaneous
             "Nonprocess" Wastewaters Reported in the 1983
             Section 308 Questionnaire ........... ...      VII-155

VII-51     Summary Statistics for Determination of BPT BOD
            Editing Criteria by Groups .......... 5.           VII-163

VII-52    Rationale  for Exclusion of Daily Data Plants
            from Data Base ................... ;      VII-173
                                     xxiv

-------
LIST OF TABLES (Continued)
Table
VII-53

VII-54

VII-55

VII-56

VII-57
:'-•' '
VII-58

VII-59

VII-60

VII-61


VII-62


VII-63

VII-64

VII-65
VII-66

VII-67


BPT Subcategory Long-Term Averages (LTAs)
for BOD5 	 	 	 	
BPT Subcategory Long-Term Averages (LTAs)
for TSS 	 	
Overall Average Versus Production-Proportion-
Weighted Variability Factors 	 	
BOD Variability Factors for Biological Only
Systems (Effluent BOD < 40 mg/1 or BOD5
Percent Removal > 95%).: . . . ..... » . . . . . •
TSS Variability Factors for Biological Only
Systems (Effluent BOD5 < 40 mg/1 or BOD ;
Percent Removal > 95% and TSS < 100 mg/1) •'•; . . .
Priority Pollutant (PRIPOL) Data Sources for the
Final ;OCPSF Rule. . . . .... ... ..... .
Data Retained from Data Sets 3 and 4 Following
BAT Toxic Pollutant Editing Criteria. ........
Explanation of BAT Toxic Pollutant Data Base
Performance Edits . . . 	 .......
. '
Plant and Pollutant Data Retained in BAT Organic
Toxic Pollutant Data Base > for BAT Subcategory
One Limitations 	 	
Plant and Pollutant Data Retained in BAT Organic
Toxic Pollutant 'Data Base for BAT Subcategory
Two Limitations .... i ........ . . .. • • • •
Treatment Technologies for Plants in the Final BAT
Toxic Pollutant Data Base . 	 	 • ...
BAT Toxic Pollutant Median of Estimated Long-Term
Averages for BAT Subcategory One and Two. . '. . . ." .
Priority Pollutants by Chemical Groups 	 	
Individual Toxic Pollutants Variability Factors
for BAT Subcategory One 	 ......... .
Individual Toxic Pollutants Variability Factors
for BAT Subcategory Two . .' 	 • 	 • •
Page

VII-176

VII-176

VII-178.

. VII-179

VII-181

VII-184
. . '
VII-188
,
VII-189

1 1
VII-191


VII-199

VII-202

VII-208
VII-212

VII-220

VII-223
             XXV

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           Table

           VII-68
                                     LIST OF TABLES (Continued)
BAT Subcategory One and Two Long-Term Averages and
  Variability Factors for Metals and Total Cyanide.
                                                                                 VII-226
           VII-69    BAT Zinc Long-Term Averages and Variability Factors
                       for Rayon (Viscose Process) and Acrylic (Zinc
                       Chloride/Solvent Process) Fibers Plants 	     VIII-229

                                             VOLUME II

           VIII-1    BPT Costing Rules 	 ........     VIII-3

           VIII-2    Generic Chemical Processes	 .	     VIII-8

           VIII-3    "Trigger" Values Used as BAT Option II In-Plant
                       Costing Targets for Plants With End-of-Pipe
                       Biological Treatment In-Place . . .  . .  .  . . .  .  .  .     VIII-10

           VIII-4    BAT Long-Term Medians Used as Costing Targets for
                       Plants Without Biological Treatment In-Place. ....     VIII-12

           VIII-5    Pollutants to be Controlled Using In-Plant
                       Biological Treatment	     VIII-14

           VIII-6    High Strippability Priority Pollutants Costed
                       Steam Stripping for BAT Option  IIA and PSES IVA  ...     VIII-16

           VIII-7    Medium Strippability Priority Pollutants Costed
                       for Steam Stripping for BAT Option IIA and
                       PSES Option IVA	     VIII-17

           VIII-8    Medium Adsorpability Priority Costed for Activated
                       Carbon for BAT Option IIA and PSES Option  IVA ....     VIII-18

           VIII-9    Low Adsorpability Priority Pollutants  Costed for
                       Activated Carbon for BAT Option IIA  and  PSES
                       Option IVA	       VIII-19

           VIII-10    High Strippability Priority Pollutants Costed for
                       Steam Stripping for BAT  Option  IIB and PSES
                       Option IIB	       VIII-20

           VIII-11    Medium Strippability Priority Pollutants Costed                    r
                       for  Steam Stripping for  BAT Option IIB and
                       PSES Option  IVB;		       VIII-21

           VIII-12    Medium Adsorpability Priority Pollutants Costed                    [
                       for  Activated  Carbon  for BAT Option  IIB  and
                       PSES Option  IVB	 ......       VIII-22
                                               xxvi
_

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                          LIST OF TABLES (Continued)
Table
VIII-13   Low Adsorpability Priority Pollutants Costed
            for Steam Stripping for BAT Option IIB and
            PSES Option IVB. ........	      VIII-23

VIII-14   Overall Averages of the Average Ratio Values
          (Process to Total Flow). . . . .  . . ... . . . . .  .      VIII-25

VIII-15   Regulated Pollutants and LTMs for PSES Option IV ...      VIII-27

VIII-16   Temperatures and Temperature Cost Factors Used
            to Calculate Activated Sludge Cost and to
            Adjust Biological Treatment Upgrade Costs. . . . .  .      VIII-30

VIII-17   Land Cost for Suburban Areas	 ...      VIII-33

VIII-18   Summary of Land Cost in the United States. 	      VIII-37

VIII-19   Activated Sludge Default and Replacement Data
            for Unit Cost Items Used in Costing Exercise
            CAPDET Model (1979)		      VIII-42

VIII-20   Activated Sludge K-Values and MLVSS Values
            from 308 Questionnaires	      VIII-43

VIII-21   Activated Sludge Table of Reported 308
            Questionnaire Data 	      VIII-45

VIII-22   Activated Sludge Table of Reported Capital Cost
            Per Gallon and O&M Cost per 1,000 Gallon	      VIII-46

VIII-23   Activated Sludge Comparison of CAPDET and
            Reported Capital and O&M Costs  (1982 Dollars). ...      VIII-48

VIII-24   Activated Sludge Comparison of Reported and
            CAPDET Detention Times (Td).  	  .....      VIII-49

VIII-25   Activated Sludge Comparison of Reported and
            and CAPDET O&M Costs  (1982 Dollars)	  .      VIII-50

VIII-26   Activated Sludge Comparison of Operation and
            Maintenance Man-Hours.  ...  .  .  .	 .  .  .      VIII-52

VIII-27   Activated Sludge Table of Reported Operating
            and Maintenance Labor Rates (1982 Dollars)  .  . .  .  .      VIII-54
    =*•                               '                     '   '        "
VIII-28   Activated Sludge Revised Land Requirements  ......      VIII-55

VIII-29   Capital and Annual Costs of Biological
    v       Treatment Modifications for Activated Sludge
            System Upgrades.  .  .	      VIII-58
                                    .xxvai

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                           LIST OF TABLES (Continued)
 Table
 VIII-30   Product Mix of the Five Facilities Used in the
             Development of the Capital Cost Curve for
             Activated Sludge System Upgrades	       VIII-59

 VIII-31   Current Influent and Effluent BOD5 Concen-
             trations at the Five Facilities Used in the
             Development of Capital Cost Curves for
             Activated Sludge System Upgrades 	  ....       VIII-62

 VIII-32   Project Capital and Operation and Maintenance (O&M)
             Costs Associated with Activated Sludge
             System Upgrades	       VIII-66

 VTII-33   Summary of Chemically Assisted Clarification
             Specifications 	       VIII-68

 VTII-34   Itemized Capital Costs for Chemically Assisted
             Clarifiers  	       VIII-69

 VIII-35   Itemized Annual Operating Costs for Chemically
             Assisted Clarifiers	       VTII-71

 VIII-36   Benchmark Comparison 	  	       VIII-75

 VIII-37   Sumnfary of Filtration System Specifications	       VIII-79

 VIII-38   Summary of Capital  and O&M Costs  for Filtration
             Systems 1982  Dollars (March)	       VIII-80

 VIII-39   Summary of Capital  and O&M Costs  for Polishing
             Ponds	       VIII-85

 VIII-40   Annual  Operating Cost  for  Algae Control  in
             Polishing Ponds  (1982 Dollars)  	       VIII-90
       i
 VIII-41    Ten Treatment Systems  With Polishing Ponds
             In-Place (At Nine  Plants)  That Were Costed
             Only  for Copper Sulfate  Addition  	  .....       VTII-92

 VIII-42    Summary of  Capital and O&M Costs for Polymer
             Addition  Systems for Upgrading Secondary
             Clarifiers  	       VIII-93

VIII-43    Summary  of  Polymer Addition  Costs for Six
            Treatment Systems  Selected for Secondary
            Clarifier Upgrades  	       VIII-94
                                    xxviii

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                          LIST OF TABLES (Continued)
Table

VIII-44   Comparison of Predicted and Reported Capital
            and O&M Costs for Steam Stripping	

VIII-45   Priority Pollutants Divided Into Groups
            According to Henry's Constant Values 	

VIII-46   Reported Steam Stripping Average Influent and
            Effluent BAT from the 1983 Supplemental
            Questionnaire	

VIII-47   Steam Stripping Design Parameters for High
            Henry's Law Constant Pollutants	

VIII-48   Steam Stripping Design Parameters for Medium
            Henry's Law Constant Pollutants. . . . .  . .  .

VIII-49   Steam Stripping Design Parameters for Low
            Henry's Law Constant Pollutants	

VIII-50   Steam Stripping Results for Removal of
            Benzene (1982 Dollars) . . . . .... .  . .  .

VIII-51   Steam Stripping Results for Removal of
            Hexachlorobenzene (1982 Dollars)	

VIII-52   Equations for Determining Computerized Cost
            Curves from Steam Stripping Results
            (1982 Dollars)	

VIII-53   Steam Stripping ($$) Overhead Disposal Cost
            Estimates	. .  . .  .

VIII-54   Steam Stripping Upgrade Costs	

VIIB-55   Adjustments to CAPDET Default Data and Results
            for Activated Carbon Systems .... 	

VIIIr56   Influent/Effluent Levels of Total Organic
    *-•  -    Priority Pollutants of Biological Treatment
            Systems for Typical Organic Chemical Plants.  .

VIII-57   Summary of In-Plant Carbon Adsorption Capacities
    -        (Ibs of Pollutants Adsorbed/lb Carbon) ....

VIII-58   Carbon Usage Rate for Priority Pollutants
            (In-Plant BAT Treatment) (Ibs of Pollutants
    -        Adsorbed/lb Carbon). .	

VIII-59   Summary of In-Plant Carbon Adsorption Capacities
            (Ibs of Pollutants Adsor,bed/lb Carbon) ....
VIII-96


VIII-99



VIII-100


VIII-102


VIII-104


VIII-106


VIII-108


VIII-109



VIII-110


VIII-117

VIII-120


VIII-122



VIII-125


VIII-127



VIII-130


VIII-131
                                     XXIX

-------
                          LIST OF TABLES  (Continued)
Table

VIII-60    Carbon  Usage Rate  for  Priority  Pollutants
             (In-Plant PSES Treatment)  (Ibs  of  Pollutants
             Adsorbed/lb  Carbon)	

VIII-61    Summary of Carbon  Adsorption Capacities  (End-
             of-Pipe) (Ibs of Pollutants Adsorbed/lb
             Carbon)	

VIII-62    Carbon  Usage Rate  for  Priority  Pollutants
             (End-of-Pipe Treatment)  (Ibs  of Pollutants
             Adsorbed/lb  Carbon)	

VIII-63    Granular Activated Carbon  Equipment  Cost Basis
             In-Plant Carbon  Treatment  System Low Carbon
             Adsorption Capacity	

VIII-64    Granular Activated Carbon  Equipment  Cost Basis
             In-Plant Carbon  Treatment  System Low Carbon
             Adsorption Capacity	

VIII-65    Granular Activated Carbon  Equipment  Cost Basis
             (Erd-of-Pipe Treatment)	

VIII-66    Total Capital  and  O&M  Costs  for Large In-Plant
             Medium Carbon Adsorption Treatment Systems
             (1982  Dollars) 	

VIII-67    Total Capital  and  O&M  Costs  for Large In-Plant
             Low Carbon Adsorption Treatment Systems
             (1982  Dollars) 	

VIII-68    Cost Estimate  for  Large End-of-Pipe  Carbon
             Treatment Systems (1982  Dollars) 	

VIII-69    Itemized Capital Cost  for  Small In-Plant and
             End-of-Pipe  Carbon Treatment Systems
             (1982  Dollars) 	

VIII-70    Itemized O&M Cost  for  Small  In-Plant Medium
             Carbon Treatment  Systems (1982 Dollars). . .

VIII-71    Itemized O&M Cost  for  Small  In-Plant Low
             Carbon Treatment  Systems (1982 Dollars). . .

VIII-72    Itemized O&M Cost  for  Small  End-of-Pipe
             Carbon Treatment  Systems (1982 Dollars). . .

VIII-73    Itemized Capital Costs for Coagulation/
             Flocculation/Clarification Systems 	
VIII-133



VIII-134



VIII-135



VIII-136



VIII-137


VIII-138



VIII-140



VIII-141


VIII-142



VIII-153


VIII-154


VIII-155


VIII-156


VIII-165
                                     xxx

-------
LIST OF TABLES (Continued)
Table
VIII-74

VIII-75

VIII-76

VIII-77

VIII-78


VIII-79
VIII-80

VIII-81

VIII-82
VIII-83

VIII-84
VIII-85
VIII-86
VIII-87




VIII-88

VIII-89

VIII-90


Itemized Annual Operating Costs for Coagulation/
Flocculation/Clarification Systems 	
Benchmark Comparison for Coagulation/
Flocculation/Clarification Systems . 	
Itemized Capital Costs for Sulfide Precipitation
Systems 	 • • • 	
Annual Operating Costs for Sulfide Precipitation
Systems. 	
A Comparison of Annual Operating Cost for Lime
Precipitation Systems and Sulfide Precipitation
Systems 	 	 	
Chemical Precipitation Upgrade Costs 	 •
Design Specifications for Cyanide Destruction
System . 	 	 • 	
Total Capital and O&M Cost for Cyanide
Destruction Systems. . . 	 	
Comparison of Technology Costs for PSES Plants ....
Total Capital and O&M Cost for the In-Plant
Biological Treatment Control Systems 	
In-Plant Biological Treatment Land Requirements. . . .
Monitoring Frequencies 	 .....
Number of Parameters and Fractions to be Analyzed. . .
Comparison of Annual Monitoring Cost (1982
Dollars) for Organic and Plastics Facilities
Using Analysis Methods 624/625 or 1624/1625
With Either a More Stringent or Less Stringent
Monitoring Frequency 	
Summary of Design Specifications for Belt Filter
Press Systems. 	 	 	
Itemized Capital Costs for Belt Filter Press
Systems 	
Itemized Annual Operating Cost for Belt Filter
Press Svstems 	 	
Page

VIII-170

VIII-171

VIII-175

VIII-176


VIII-179
VIII-181

VIII-183

VIII-184
VIII-188

VIII-189
VIII-194
VIII-200
VIII-201




VIII-204

VIII-207

VIII-208

VIII-211
            xxxi

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                           LIST OF TABLES  (Continued)


 Table                                                        .          D
 	                                                                  Page

 VIII-91   Summary of Fluidized Bed Incinerator  System
             Design Specifications	       VIII-214

 VIII-92   Itemized Capital Costs for Fluidized  Bed
             Incinerator Systems	„	       VIII-215

 VIII-93   Itemized Annual Operating Cost  for Fluidized
             Bed Incineration Systems 	       VIII-218

 VIII-94   Capital and O&M Costs for the Belt Filter Press
             and Fluidized Bed Incineration Systems  	       VIII-220

 VIII-95   Annualized Cost for Sludge Handling Systems	      VIII-221

 VIII-96   Parameters Used to Design and Cost Liners and
             Monitoring 	      VIII-226

 VIII-97   Liner and Monitoring Well Equipment and
             Installation Costs for Selected OCPSF Facilities .  .      VIII-228

 VIII-98   Summary of Liner,  Monitoring, and Administrative
             RCRA Baseline Costs	      VIII-232

 VIII-99   Summary of BPT,  BAT,  and  PSES Compliance Costs
             For Final Regulatory  Options (1982  Dollars)	      VIII-233

 VIII-100   Plants With No Cost	      VIII-234

 VIII-101   Major Products by  Process of  the Organic
             Chemicals  Industry	       VIII-239

 VIII-102   Major Products by  Process of  the Plastics/
             Synthetic  Fibers Industry	       VIII-247

 VIII-103   Generic Chemical Processes  	       VIII-250

 VIII-104   Overview of Wastewater Studies Included  in Raw
             Wastewater Toxic Pollutant  Loadings  Calculations  .  .       VIII-251

 VIII-105   Phase  II Screening - Product/Process and Other
             Waste Streams Sampled at Each  Plant	       VIII-255

 VIII-106   BPT, BAT Option II, BAT Option III, and PSES
             Toxic Pollutant Concentrations Used  in Loadings.  .  .       VIII-263

VIII-107   BAT Wastewater Toxic Pollutant Loadings	       VIII-271

VIII-108   PSES Wastewater Toxic Pollutant Loadings 	      VIII-273
                                    XXX11

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                          LIST OF TABLES (Continued)
Table

VIII-109
VIII-110


VIII-111


VIII-112


IX-1


IX-2


X-l


X-2


X-3


X-4



 X-5



 XII-1
Priority Pollutants Considered for Estimating
  a Portion of the OCPSF Industry Air Emissions
  from Wastewater Treatment Systems for 32
  Selected VOCs	
Volatilization from Pre-Biological Unit Operations
  for Selected VOCs	
BAT Toxic Pollutants Air Emission Loadings
  (Ibs/year)	•  •	
PSES Toxic Pollutant Air Emission Loadings
  (Ibs/year)	
BPT Effluent Limitations and NSPS by Subcategory
   (mg/1)  	

Derivation  of BPT Limitations  for a Hypothetical
   Plant	•	

BAT Effluent Limitations and NSPS for  the  End-of-
   Pipe  Biological Treatment Subcategory	•
 BAT  Effluent  Limitations  and  NSPS for the  Non-
   End-of-Pipe Biological  Treatment Subcategory

 Cyanide-Bearing Waste Streams (by product/
   process)	 •  • •  •
 Noncomplexed Metal-Bearing Waste Streams for
   Chromium,  Copper,  Lead,  Nickel,  and Zinc
   (by product/process) .  ...  . .  •  •  • • •
 Complexed Metal Bearing Waste Streams for
   Chromium, Copper, Lead, Nickel, and Zinc
   (by product/process)	•  •
 Pretreatment Standards for Existing and New
   Sources (PSES and PSNS). .  .  .  .  .  •  • •  •
VIII-277


VIII-281


VIII-284


VIII-285


IX-8


IX-11


X-6


X-8


X-13



X-15



X-26


 XII-4
                                     xxxiii

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                                  SECTION I
                                 INTRODUCTION

     This document describes the technical development of the U.S.
Environmental Protection Agency's ,(EPA's) promulgated effluent limitations
guidelines and standards that limit the discharge of pollutants into navigable
waters and publicly owned treatment wbrks (POTWs) by existing and new sources
in the organic chemicals, plastics, and synthetic fibers (OCPSF) point source
category.  The regulation establishes effluent limitations guidelines
attainable by the application of the "best practicable control technology
currently available" (BPT) and the "best available technology economically
achievable" (BAT), pretreatment standards applicable to existing and new
discharges to POTWs (PSES and PSNS, respectively), and new source performance
standards (NSPS) attainable by the application of the "best available
demonstrated technology."

A.  LEGAL AUTHORITY
     This regulation was promulgated under the authority of Sections 301, 304,
306, 307, 308, and 501  of the Clean Water Act (the Federal Water Pollution
Control Act Amendments  of 1972, 33 U.S.C. 1251 et seq., as amended) also
referred  to as "the Act" or "CWA."  It was also  promulgated in response to  the
Settlement Agreement in Natural Resources Defense Council, Inc. v. Train,
8 ERG  2120 (D.D.C. 1976), modified, 12 ERC 1833  (D.D.C. 1979), modified by
Orders dated October 26, 1982; August 2,  1983; January  6,  1984; July 5, 1984;
January  7, 1985; April  24,  1986; and January 8,  1987.

     The Federal Water  Pollution Control Act Amendments of 1972 established a
comprehensive  program  to  "restore  and maintain  the  chemical,  physical, and
biological integrity of the Nation's waters" (Section 101(a)).  To  implement
the Act,  EPA was  required  to  issue effluent  limitations guidelines,  pretreat-
ment standards,  and NSPS for  industrial  dischargers.
                                      1-1

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      In addition to these regulations for designated industrial categories,
 EPA was required to promulgate effluent limitations guidelines and standards
 applicable to all discharges of toxic pollutants.  The Act included a time-
 table for issuing these standards.  However, EPA was unable to meet many of
 the deadlines and, as a result, in 1976, it was sued by several environmental
 groups.  In settling this lawsuit, EPA and the plaintiffs executed a "Settle-
 ment Agreement" that was approved by the Court.  This agreement required EPA
 to develop a program and adhere to a schedule for controlling 65 "priority"
 toxic pollutants and classes of pollutants.   In carrying out this program, EPA
 was required to promulgate BAT effluent limitations guidelines, pretreatment
 standards, and NSPS for a variety of major industries,  including the OCPSF
 industry.

      Many  of the basic elements of the Settlement Agreement were incorporated
 into the Clean Water Act of 1977.   Like the  Agreement,  the Act stressed  con-
 trol of toxic pollutants,  including the 65 priority toxic pollutants and
 classes of pollutants.

      Under the Act,  the EPA is  required  to establish  several different kinds
 of  effluent  limitations guidelines and  standards.   These  are summarized
 briefly below.

      1.  Best  Practicable Control  Technology Currently Available  (BPT)
      BPT effluent limitations guidelines are generally based on the  average  of
 the best existing performance by plants of various  sizes,  ages, and  unit pro-
 cesses within  the category or subcategory  for control of  familiar (e.g., con-
 ventional) pollutants,  such as BOD5, TSS, and pH.

     In establishing BPT effluent  limitations guidelines,  EPA considers  the
 total cost in relation  to the effluent reduction benefits, age  of equipment
and facilities involved, processes employed,  process changes required,
engineering aspects of the control technologies, and nonwater quality
environmental impacts (including energy requirements).  The Agency balances
the category-wide or subcategory-wide cost of applying the technology against
the effluent reduction benefits.
                                     1-2

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     2.  Best Available Technology Economically Achievable (BAT)
     BAT effluent limitations guidelines, in general, represent the best
existing performance in the category or subcategory.  The Act establishes BAT
as the principal national means of controlling the direct discharge of toxic
and nonconventional pollutants to navigable waters.

     In establishing BAT, the Agency considers the age of equipment and facil-
ities involved, processes employed, engineering aspects of the control
technologies, process changes, cost of achieving such effluent reduction, and
nonwater quality environmental impacts.

     3.  Best Conventional Pollutant Control Technology (BCT)
     The 1977 Amendments to the Clean Water Act added Section 301(b)(2)(E),
establishing "best conventional pollutant control  technology" (BCT) for the
discharge of conventional pollutants from existing industrial point sources.
Section 304(a)(4) designated  the  following as conventional pollutants:  BODg,
TSS, fecal coliform, pH, and  any  additional pollutants defined by  the Admin-
istrator as conventional.  The Administrator designated oil and grease a con-
ventional pollutant on July 30, 1979 (44 FR 44501).

     BCT is not an additional limitation, but replaces BAT for  the control of
conventional pollutants.  In  addition  to other factors specified in Section
304(b)(4)(B),  the Act  requires that  the  BCT effluent limitations guidelines be
assessed in  light of a two part "cost-reasonableness"  test [American Paper
Institute v. EPA, 660  F.2d 954 (4th  Cir. 1981)].   The  first  test compares  the
cost for private industry  to  reduce  its  discharge  of conventional  pollutants
with the costs  to POTWs  for similar  levels of reduction  in their discharge of
these  pollutants.  The second test examines  the  cost-effectiveness of
additional  industrial  treatment beyond BPT.  EPA must  find that limitations
are "reasonable" under both  tests before establishing them as BCT. In no  case
may BCT be  less  stringent  than BPT.

     EPA has promulgated a methodology for  establishing  BCT  effluent  limita-
 tions  guidelines (51  FR 24974, July  8,  1986).
                                      1-3

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      4.  New Source Performance Standards  (NSPS)
      NSPS are based on  the performance of  the best available demonstrated
 technology.  New plants have the opportunity to install the best and most
 efficient production processes and wastewater treatment technologies.  As a
 result, NSPS should represent the most stringent numerical values attainable
 through the application of best available demonstrated control technology for
 all pollutants (i.e., toxic, conventional, and nonconventional).

      5.  Pretreatment Standards for Existing Sources (PSES)
      PSES are designed to prevent the discharge of pollutants that pass
 through,  interfere with, or are otherwise incompatible with the operation of
 POTWs.   The Clean Water Act requires pretreatment standards for pollutants
 that pass through POTWs or interfere with either the POTW's treatment process
 or chosen sludge disposal method.   The legislative history of the 1977 Act
 indicates that  pretreatment standards are to be technology-based and analogous
 to the  BAT effluent limitations  guidelines for  removal of  toxic pollutants.
 For the purpose  of determining whether to promulgate national category-wide
 PSES and  PSNS, EPA generally determines  that there is pass through of pollu-
 tants,  and thus  a need  for categorical standards if the nationwide average
 percentage of pollutants removed by well-operated  POTWs achieving secondary
 treatment  is less  than  the percent  removed by the  BAT model treatment system.
 The General Pretreatment Regulations,  which serve  as  the framework for
 categorical pretreatment standards,  are  found at 40 CFR Part  403.   (Those
 regulations contain a definition of  pass  through  that addresses  localized
 rather  that national instances of pass through and  does not use  the  percent
 removal comparison  test  described above  (52  FR 1586,  January  14,  1987).)

     6-  Pretreatment Standards  for New Sources  (PSNS)
     Like PSES, PSNS are designed to prevent the discharge of pollutants that
 pass through, interfere with, or are otherwise incompatible with  the operation
 of a POTW.  PSNS are to be issued at the same time as NSPS.  New  indirect
 dischargers, like new direct dischargers, have the opportunity to incorporate
 in their plant the best available demonstrated technologies.  The Agency con-
 siders the same factors in promulgating PSNS as  it considers in promulgating
NSPS.
                                     1-4

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B.  HISTORY OF OCPSF RULEMAKING EFFORTS
     EPA originally promulgated effluent limitations guidelines and standards
for the organic chemicals manufacturing industry in two phases.  Phase I,
covering 40 product/processes (a product that is manufactured by the use of a
particular process — some products may be produced by any of several proces-
ses), was promulgated on April 25!, 1974 (39 FR 14676).  Phase II, covering 27
additional product/processes, was promulgated on January 5, 1976 (41 FR 902).
The Agency also promulgated effluent limitations guidelines and standards for
the plastics and synthetic fibers industry in two phases.  Phase I, covering
13 product/processes, was promulgated on April 5, 1974 (39 FR 12502).  Phase
II, covering eight additional product/processes, was promulgated on January
23, 1975 (40 FR 3716).

     These regulations were challenged, and on February 10, 1976, the Court in
Union Carbide v. Train, 541 F.2d 1171 (4th Cir. 1976), remanded the Phase I
organic chemicals regulation.  EPA also withdrew the Phase II organic chem-
icals regulation on April 1, 1976 (41 FR 13936).  However, pursuant to an
agreement with the industry petitioners, the regulations for butadiene manu-
facture were left in place.  The .Court also remanded the Phase I plastics and
synthetic fibers regulations in FMC Corp. v. Train, 539 F.2d 973 (4th Cir.
1976) and in response EPA withdrew both the Phase I and II plastics and
synthetic fibers regulations on August 4, 1976 (41 FR 32587) except for  the pH
limitations, which had not been addressed in the lawsuit.  Consequently, only
the regulations covering butadiene manufacture for the organic chemicals
industry and the pH regulations for the plastics and synthetic fibers industry
have been in effect to date.  These regulations were superseded by  the regula-
tions described in this report.

     In  the absence of promulgated, effective effluent limitations  guidelines
and standards, OCPSF direct dischargers have been  issued National Pollutant
Discharge Elimination System  (NPDES)  permits on a  case-by-case basis using
best professional judgment  (BPJ), as  provided in Section 402(a)(l)  of  the CWA.

'•'••'••  •' Subsequent  to the withdrawal/suspension of  the national  regulations cited
above, studies and data-gathering were  initiated in order  to  provide a basis
                                      1-5

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 for  issuing  effluent  limitations guidelines  and standards for this industry.
 These  efforts  provided a basis  for the March 21,  1983  proposal (48 FR 11828);
 the  July  17, 1985  (50 FR 29071),  October  11,  1985 (50  FR 41528),  and December
 8, 1986 (51  FR 44082) post-proposal notices  of  availability  of information;
 and  the final  regulation.

     This report presents  a  summary of the data collected by the  Agency  since
 1976,  the data submitted by  the  OCPSF  industry  in response to the Federal
 Register notices cited above, and  the  analyses  used  to support the promulgated
 regulations.   Section II presents  a summary  of  the findings  and conclusions
 developed in this document as well as  the promulgated regulations.   Sections
 III  through VIII present the technical  data  and  the  supporting analyses  used
 as the basis for the  promulgated regulations, and  Sections IX through XIII
 include the rationale  and derivation of the national effluent  limitations and
standards.  Detailed data displays  and  analyses are  included  in the
appendices.
                                     1-6

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                                  SECTION II
                            SUMMARY AND  CONCLUSIONS

A.   OVERVIEW OF THE INDUSTRY
     The organic chemicals, plastics, and synthetic fibers (OCPSF) industry is
large and diverse, and many plants in the industry are highly complex.  The
industry includes approximately 750 facilities whose principal or primary
production activities are covered under the OCPSF regulations.  There are
approximately 250 other plants that are secondary producers of OCPSF products
(i.e., OCPSF production is ancillary to their primary production activities).
Thus, the total number of plants to be  regulated totally or in part by the
OCPSF industry regulation is approximately 1,000.  Secondary OCPSF plants may
be part of the other chemical producing industries such as the petroleum
refining, inorganic chemicals, pharmaceuticals, and pesticides industries as
well as the chemical formulation industries such as the adhesives and
sealants, paint and ink, and the plastics molding and forming industries.
Although over 25,000 different organic  chemicals, plastics, and synthetic
fibers are manufactured, less than half of these products are produced in
excess of 1,000 pounds per  year.

     Some plants produce chemicals in large volumes while others produce only
small volumes of "specialty" chemicals.  Large volume production tends to
utilize continuous processes.  Continuous processes are generally more effi-
cient than batch processes  in minimizing water use and optimizing the consump-
tion of raw materials.

     Different products are made by  varying  the  raw materials,  the chemical
reaction conditions, and  the chemical engineering unit processes.  The
products being manufactured at a single large  chemical plant  can vary on a
weekly or even daily basis.  Thus, a single  plant may simultaneously  produce
many different products using a variety of  continuous and batch operations,
and  the product mix may change on a  weekly  or  daily basis.               /
                                      II-l

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      A total of 940 facilities  (based on 1982 production) are included in  the
 technical and economic studies  used as a basis for this regulation.  Approxi-
 mately 76 percent of these facilities are primary OCPSF manufacturers (over
 50 percent of their total plant production involves OCPSF products), and
 approximately 24 percent of the facilities are secondary OCPSF manufacturers
 that produce mainly other types of products.  An estimated 32 percent of the
 plants are direct dischargers; about 42 percent discharge indirectly to
 publicly owned treatment works  (POTWS); and the remaining facilities
 (26 percent) are either zero or alternative dischargers, or their discharge
 status is unknown.  The estimated average daily process wastewater discharge
 per plant is 1.31 millions of gallons per day (MGD) for direct dischargers and
 0.25 HGD for indirect dischargers.  The non-discharging plants use dry
 processes,  reuse their wastewater, or dispose of their wastewater by deep well
 injection,  incineration,  contract hauling,  or by means of evaporation and
 percolation ponds.

      As  a result of  the wide  variety and  complexity of raw materials and
 processes used and of  products manufactured  in the  OCPSF industry,  an excep-
 tionally  wide variety  of  pollutants  are found  in  the  wastewaters  of this
 industry.   This  includes  conventional  pollutants  (pH,  BOD5, TSS,  and oil  and
 grease);  an unusually wide variety of  toxic  priority  pollutants (both metals
 and  organic compounds); and a  large  number of  nonconventional  pollutants.
 Many of  the toxic and nonconventional  pollutants  are  organic compounds
 produced  by the  industry  for sale.   Others are created by  the  industry as
 by-products  of their production  operations.  This study focused on  the
 conventional pollutants and on  the 126 priority pollutants.

     To control  the wide variety of pollutants discharged by the OCPSF
 industry, OCPSF plants use a broad range of in-plant controls, process
 modifications, and end-of-pipe treatment techniques.   Most plants have
 implemented programs that combine elements of both in-plant control and
 end-of-pipe wastewater treatment.  The configuration of controls and
 technologies differs from plant  to plant,  corresponding to the differing mixes
of products manufactured by different facilities.   In general,  direct
dischargers treat their wastes more extensively than indirect  dischargers.
                                     II-2

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     The predominant end-of-pipe control technology for direct dischargers in
the OCPSF industry is biological treatment.  The chief forms of biological
treatment are activated sludge and aerated lagoons.  Other systems, such as
extended aeration and trickling filters, are also used, but less extensively.
All of these systems reduce biochemical oxygen demand (BOD5) and total
suspended solids (TSS) loadings, and in many instances, incidentally remove
toxic and nonconventional pollutants.  Biological systems biodegrade some of
the organic pollutants, remove bio-refractory prganics and metals by sorption
into the sludge, and strip some volatile organic compounds (VOCs) into the
air.  Well-designed biological treatment systems generally incorporate
secondary clarification unit operations to ensure adequate control of solids.

     Other end-of-pipe treatment technologies used in the OCPSF industry
include neutralization, equalization, polishing ponds, filtration, and carbon
adsorption.  While most direct dischargers use these physical/chemical
technologies in conjunction with end-of-pipe biological treatment, at least
71 direct dischargers use only physical/chemical treatment.

     In-plant control measures employed at OCPSF plants include water
reduction and reuse techniques, chemical substitution, and process changes.
Techniques to reduce water use includ.e the elimination of water use where
practicable, and the reuse and recycling of certain streams, such as reactor
and floor washwater, surface runoff, scrubber effluent, and vacuum seal
discharges.  Chemical substitution is utilized to replace process chemicals
possessing highly toxic or refractory properties with others that are less
toxic or more amenable to .treatment.  Process changes include various measures
that reduce water use, waste discharges, and/or waste loadings while improving
process efficiency.  Replacement of barometric condensers with surface
condensers, replacement of steam jet ejectors with vacuum pumps, recovery of
product or by-product by steam stripping, distillation, solvent extraction or
recycle, oil-water separation, and carbon adsorption, and the addition of
spill control systems are examples of process changes that have been
successfully employed in the OCPSF industry to reduce pollutant loadings while
improving process efficiencies.
                                     II-3

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      Another type of control widely used in the OCPSF industry is physical/
 chemical in-plant control.  This treatment technology is generally used
 selectively on certain process wastewaters to recover products or process
 solvents,  to reduce loadings that may impair the operation of the biological
 system,  or to remove certain pollutants that are not treated sufficiently by
 the biological system.  In-plant technologies widely used in the OCPSF
 industry include sedimentation/clarification, coagulation, flocculation,
 equalization, neutralization, oil-water separation,  steam stripping,  distil-
 lation,  and dissolved air flotation.

      Some  OCPSF plants also use physical/chemical treatment after biological
 treatment.  Such treatment is usually intended to reduce solids loadings  that
 are discharged from biological treatment systems. The most common post-
 biological treatment unit operations  are polishing ponds and multimedia,
•filtration.   These unit operations are sometimes used in lieu of secondary
 clarification or to improve upon substandard biological treatment systems.   A
 few plants also use activated carbon  after biological treatment as a  final
 "polishing"  step.

      At  approximately 9 percent of the direct discharging plants surveyed,
 either no  treatment is provided or no treatment beyond equalization and/or
 neutralization is  provided.   At another 19 percent,  only physical/chemical
 treatment  is provided.  The remaining 72 percent utilize biological treatment.
 Approximately 41 percent of biologically treated effluents are further treated
 by  polishing ponds,  filtration,  or other forms of physical/chemical control.

      At  approximately 39 percent of the indirect discharging plants surveyed,
 either no  treatment is provided or no treatment beyond equalization and/or
 neutralization is  provided.   At another 47 percent,  some physical/chemical
 treatment  is provided.  The remaining 14 percent utilize biological treatment.
 Approximately 22 percent of biologically treated effluents are further treated
 by  polishing ponds,  filtration,  or other forms of physical/chemical control.

      Economic data provided in response to questionnaires  completed pursuant
 to  Section 308 of  the CTA indicate that OCPSF production in 1982 totaled  185
 billion  pounds and that the quantity  shipped was 151  billion pounds.   The
                                     II-4

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corresponding value of shipments equaled $59 billion, while employment in the
industry totaled 187,000 in 1982.  In that same, year a total of 455 firms
operated the 940 facilities referenced above.

B.   CONCLUSIONS

     1.  Applicability of the Promulgated Regulation
     The OCPSF regulation applies to process vastewater discharges from
existing and new organic chemicals, plastics, and synthetic fibers (OCPSF)
manufacturing facilities.  OCPSF process wastewater discharges are defined as
discharges from all establishments or portions of establishments that manufac-
ture products or product groups listed in the applicability sections of the
promulgated regulation (see Appendix III-A of this report), and are included
within the following U.S. Department of Commerce, Bureau of the Census,
Standard Industrial Classification (SIC) major groups:

     •  SIC 2865 - Cyclic Crudes and Intermediates, Dyes, and Organic Pigments
     •  SIC 2869 - Industrial Organic Chemicals, not Elsewhere Classified
     •  SIC 2821 - Plastic Materials, Synthetic Resins, and Nonvulcanizable
        Elastomers
     •  SIC 2823 - Cellulosic Man-Made Fibers
     •  SIC 2824 - Synthetic Organic Fibers, Except Cellulosic.

     The regulations apply to plastics molding and forming processes only when
plastic resin manufacturers mold or form (e.g., extrude and pelletize) crude
intermediate plastic material for shipment off-site.  This regulation also
applies to the extrusion of fibers.  Plastic molding and forming processes
other  than those described above are regulated by the plastics molding and
forming effluent guidelines and standards found in 40 CFR Part 463.

     The regulations also apply to wastewater discharges from OCPSF research
andidevelopment, pilot plant, technical service, and laboratory bench-scale
operations if such operations are conducted  in conjunction with and related to
existing OCPSF manufacturing activities at the plant;site.           ;
                                     II-5

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     The regulations do not apply to discharges resulting from the manufacture
of OCPSF products if the products are included in the following SIC subgroups,
and have in the past been reported by the establishment under these subgroups
and not under the OCPSF SIC groups listed above:

     •  SIC 2843085 - Bulk Surface Active Agents
     •  SIC 28914 - Synthetic Resin and Rubber Adhesives
     •  Chemicals and Chemical Preparations, not Elsewhere Classified
        -  SIC 2899568 - sizes, all types
        -  SIC 2899597 - other industrial chemical specialties, including
           fluxes, plastic wood preparations, and embalming fluids
     •  SIC 2911058 - Aromatic Hydrocarbons Manufactured from Purchased
        Refinery Products
     •  SIC 2911632 - Aliphatic Hydrocarbons Manufactured from Purchased
        Refinery Products.

     The regulations are not applicable to any discharges for which a
different set of previously promulgated effluent limitations guidelines and
standards in 40 CFR Parts 405 through 699 apply, unless the facility reports
OCPSF production under SIC codes 2865, 2869, or 2821, and the facility's OCPSF
wastewater is treated in a separate treatment system or discharged separately
to a POTW.  They also do not apply to any process wastewater discharges from
the manufacture of organic chemical compounds solely by extraction from plant
and animal raw materials or by fermentation processes.

     2.  BPT
     The technology basis for the promulgated effluent limitations for each
BPT subcategory consists of biological treatment, which usually involves
either activated sludge or aerated lagoons, followed by clarification (and
preceded by appropriate process controls and in-plant treatment to ensure that
the biological system may be operated optimally).  Many of the direct dis-
charge facilities have installed this level of treatment.
                                     II-6

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     The Agency designated seven subcategory classifications for the OCPSF
category to be used for establishing BPT limitations.  These subcategory
classifications are 1) rayon fibers .(viscose process only); 2) other fibers
(SIC 2823, .except rayon, and 2824);' 3) thermoplastics (SIC 28213); 4 thermo-
sets (SIC 28214); 5) commodity organic chemicals (SIC 2865 and 2869); 6) bulk
organic chemicals (SIC 2865 and 2869); and 7) specialty organic chemicals
(SIC 2865 and 2869).  The specific products and product groups within each
subcategory are listed in Appendix III-A.

     While some plants may have production that falls entirely within one of
the seven subcategory classifications, most plants have production that is
divided among two or more subcategories.  In applying the subcategory
limitations set forth in the regulation, the permit writer will use what is
essentially a building-block approach that takes into consideration applicable
subcategory characteristics based upon the proportion of production quantities
within each subcategory at the plant.  Production characteristics are
reflected explicitly in the plant's limitations through the use of this
approach.

     The long-term median effluent BOD5  concentrations were calculated for
each subcategory through the use of a mathematical equation that estimates
effluent BOD5 as a function of the proportion of the production of each
subcategory at each facility.  The coefficients of this equation were
estimated  from reported plant data using standard statistical regression
methods.   Plants were selected for developing BPT BOD5 limitations only if
they achieved at least  95 percent removal for BOD5 or a long-term average
effluent BOD5 concentration at or below  40 mg/1.  The long-term median
effluent TSS concentrations were calculated for each subcategory  through the
use of a mathematical equation that estimates effluent TSS as a function of
effluent BOD5.  The coefficients of this equation were also estimated from
reported plant data using standard statistical regression methods.  Plants
were selected for developing BPT TSS  limitations if  they passed the BOD5 edit
and also achieved a long-term average effluent TSS concentration  at or below
100 mg/1.  This  statistical analysis  is  described in detail in Sections IV and
VII.
                                      II-7

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      "Maximum  for monthly average" and  "maximum  for any one day"  effluent
, limitations were determined by multiplying long-term median effluent  concen-
 trations by appropriate variability factors  that were calculated  through
 statistical analysis of long-term BOD5  and TSS daily data.  This  statistical
 analysis is described in detail in Section VII.

      The BPT subcategory BOD5 and TSS effluent limitations are presented in
 Table II-l; pH, also a regulated parameter, must remain within the range of
 6.0 to 9.0 at all times.  EPA has determined that the BPT effluent limitations
 shall apply to all' direct discharge point sources.

      3.   BCT
      The Agency did not promulgate BCT effluent limitations as part of this
 regulation.  BCT is reserved until a future BCT analysis is completed.

      4.   BAT                                                                 ,
      The Agency promulgated  BAT limitations for two subcategories.  These
 subcategories  are largely determined  by conventional pollutant raw waste
 characteristics.   The end-of-pipe  biological  treatment  subcategory (BAT Sub-
 category One)  includes  plants  that  have or will install  biological treatment
 to comply with BPT limits.   The non-end-of-pipe biological treatment  sub-
 category (BAT  Subcategory Two)  includes plants  that  either generate such low
 levels of BOD5  that  they do  not  need  to utilize biological treatment,  or that
 choose to use  physical/chemical  treatment  to  comply  with the BPT  limitations.
 The Agency  has  concluded that, within  each subcategory, all plants can treat
 priority pollutants  to  the levels established for that subcategory.

     Different  limits are being established for  these two  subcategories.
 Biological  treatment  is  an integral part of the model BAT  treatment technology
 for the  end-of-pipe biological treatment subcategory; it achieves  incremental
 removals  of some priority pollutants beyond the removals achieved  by in-plant
 treatment without end-of-pipe biological treatment.  In addition,  the Agency
 is  establishing two different limitations  for zinc.  One is based  on data
 collected from rayon manufacturers and acrylic fibers manufacturers using the
zinc chloride/solvent process.  This limitation applies only to those plants
                                     II.-8

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                                 TABLE XI-1.
           BPT EFFLUENT LIMITATIONS AND NSPS BY SUBCATEGORY (rag/1)
Subcategory
Rayon Fibers
Other Fibers
Thermoplastic Resins
Thermosetting Resins
Commodity Organic Chemicals
Bulk Organic Chemicals
Specialty Organic Chemicals

Effluent Limitations1
Maximum for
Monthly Average
BOD5 TSS
24
18
24
61
30
34
45
40
36
40
67
46
49
57
Maximum
Any One
BOD5
64
48
64
;163
80
92
120
for
Pay
TSS
130
115
130
216
149
159
183
xpH, also a regulated parameter, shall remain within the range of 6.0 to 9>0,
 at all times.

2Product and product group listings for each subcategory are contained in
 Appendix III-A.
                                     II-9

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 that  use the viscose process to manufacture rayon and  the zinc chloride/
 solvent  process  to manufacture acrylic fibers.   The other zinc limitation is
 based on the performance of chemical precipitation technology used  in the
 metal finishing  point source category,  and  applies to  all plants  other than
 those described  above.

      The concentration-based BAT effluent limitations  hinge  on the  performance
 of  the end-of-pipe treatment component  (biological treatment for  the  end-6f-
 pipe  biological  treatment subcategory and physical/chemical  treatment for the
 non-end-of-pipe  biological treatment subcategory)  plus in-plant control
 technologies that  remove priority pollutants  prior to  discharge to  the
 end-of-pipe  treatment system.

      The in-plant  technologies include  steam  stripping to remove  selected
 volatile and semivolatile priority pollutants, such as toluene, benzene,
 carbon tetrachloride,  and the  dichlorobenzenes;  activated carbon  for  selected
 base/neutral priority pollutants,  such  as 4-nitrophenol and  4,6-dinitro-
 o-cresolj hydroxide  precipitation for metals; alkaline chlorination for
 cyanidej  and in-plant  biological  treatment  for selected acid and  base/neutral
 priority pollutants,  such as phenol,  the phthalate esters, and the polynuclear
 aromatics.

      The limits  are  based on priority pollutant  data from both OCPSF  and  other
 industry plants  with well-designed and  well-operated BAT  model treatment
 technologies  in  place.   The  organic  priority  pollutant limits are derived  from
 selected  data within the Agency's  verification study,  cooperative EPA/CMA
 study, the 12-Plant  Study, and  the industry-supplied data base.  Except as
noted  above,  the cyanide and metal priority pollutant  limits  are derived  from
 the metal finishing  industry data  base.  The  organic priority pollutant limits
apply  at  the end-of-pipe process wastewater discharge  point.  There are no
 in-plant  limitations established  for  volatile organic  priority pollutants.
However,   the cyanide and metal  limitations apply only  to  the  process waste-
water  flow from  cyanide-bearing and metal-bearing waste streams.  Compliance
for cyanide and metals could be monitored in  the plant or, after accounting
for dilution by noncyanide-  and nonmetal-bearing process wastewater and
nonprocess wastewater, at  the outfall.
                                    11-10

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     Derivation of the limitations is detailed in Section VII.  "Maximum for
Monthly Average" and "Maximum for Any One Day" limitations have been
calculated for each regulated pollutant.  Effluent limitations have been
established for 63 pollutants for the end-of-pipe biological  treatment
subcategory and 59 pollutants for the non-end-of-pipe biological  treatment
subcategory; these limitations are listed in Tables II-2 and  II-3,
respectively.

     In the final rule, EPA has decided that each discharger  in a subcategory
will be subject to the effluent limitations for all pollutants regulated for
that subcategory.  Once a pollutant is regulated in the OCPSF regulation,  it
must also be limited in the NPDES permit issued to direct dischargers  (see
Sections 301 and 304 of the Act; see also 40 CFR Part 122.44(a)).  EPA
recognizes .that, guidance on appropriate monitoring requirements for OCPSF   ,
plants would be useful, particularly to assure  that monitoring will not be
needlessly required for pollutants that are not likely  to be  discharged at  a
plant.  EPA intends to publish guidance on OCPSF monitoring in  the near
future.  This guidance wi;ll address the issues  of compliance  monitoring in
general, of initially determining which pollutants should be  subject only  to
infrequent monitoring based on a conclusion  that they are unlikely to  be
discharged, and of determining the appropriate  flow upon which  to derive
mass-based permit requirements.

  ,,  ,EPA has determined that  this  technology basis is  the best  available
technology economically achievable ,for  all plants except  for  a  subset,of  small
facilities.  For plants whose annual OCPSF production  is  less than,or  equal to
5 million pounds, EPA has  concluded that  the BAT effluent limitations  are  not
economically achievable.   For these plants,  EPA has set BAT equal to BPT.

      5. . NSPS         :     .   -.. .•       . '  •   . ,    • •   ••..-.    ;  •- • v  .''•.•:""•"••
     'EPA promulgated new  source  performance  standards  (NSPS)  on the basis  of
the::best available demonstrated  technology.  NSPS  are  established for  convert
tional  pollutants  (BOD5,  TSS, and  pH)  on  the basis of  BPT model treatment
technology;  Priority pollutant  limits  are based on BAT model  treatment
technology.
                                     11-11

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                 TABLE  II-2.
  BAT  EFFLUENT  LIMITATIONS AND NSPS  FOR THE
END-OF-PIPE BIOLOGICAL TREATMENT SUBCATEGORY
Pollutant
Number
1
3
4
6
7
8
9
10
11
12
13
14
16
23
24
25
26
27
29
30
31
32
33
34
35
36
38
39
42
44
45
52
55
56
57
58
59
60
65
66
68
70
Pollutant Name
Acenaphthene
Acrylonitrile
Benzene
Carbon Tetrachloride
Chlorobenzene
1,2, 4-Trichlorobenzene
Hexachlorobenzene
1 , 2-Dichloroethane
1,1,1-Trichloroethane
Hexachloroe thane
1-1-Dichloroethane
1,1, 2-Trichloroethane
Chloroe thane
Chloroform
2-Chlorophenol
1 , 2-Di chlorobenzene
1 , 3-rDichlorobenzene
1 , 4-Dichlorobenzene
1 , 1-Dichloroethylene
1, 2-Trans-dichloroethylene
2,4-Dichlorophenol
1 , 2-Dichloropropane
1 , 3-Dichloropropene
2 , 4-Dimethylphenol
2,4-Dinitrotoluene
2 , 6-Dini tro toluene
Ethylbenzene
Fluoranthene
Bis(2-Chloroisopropyl)ether
Methylene Chloride
Methyl Chloride
Hexachlorobutadiene
Naphthalene
Nitrobenzene
2-Ni trophenol
4-Nitrophenol
2 , 4-Dini trophenol
4, 6-Dini tro-o-cresol
Phenol
Bis(2-ethylhexyl)phthalate
Di-n-butyl phthalate
Diethyl phthalate
BAT Effluent
Maximum for
Any One Day
59
242
136
38
28
140
28
211
54
54
59
54
268
46
98
163
44
28
25
54
112
230
44
36
285
641
108
68
757
89
190
49
59
68
69
124
123
277
26
279
57
203
Limitations and NSPS1
Maximum for
Monthly Average
22
96
37
18
15
68
15 .
68
21
21
22
'21
104
21
31
77
31
15
16
21
39
153
29
18
113
255
32
25
301
40
86
20
22
27
41
72
71
78
15
103
27
81
                  11-12

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                                 TABLE II.-2.
                  BAT EFFLUENT LIMITATIONS AND NSPS FOR THE
          END-OF-PIPE BIOLOGICAL TREATMENT  SUBCATEGORY  (Continued)
                                         BAT Effluent  Limitations and NSPS1
Pollutant
Number
71
72
73
74
75
76
77
78
80
81
84
85
86
87
88
119
120
121
122
124
128
Pollutant Name
Dimethyl phthalate
Benzo(a)anthracene
Benzo(a)pyrene
3,4-Benzofluoranthene
Benzo(k) f luoranthene
Chrysene
Acenaphthylene
Anthracene
Fluorene
Phenanthrene
Pyrene
Tetrachloroethylene
Toluene
Trichloroethylene
Vinyl Chloride
Total Chromium
Total Copper
Total Cyanide
Total Lead
Total Nickel
Total Zinc2'4
Maximum for
Any One Day
47
59
61
61
59
59
59
59
59 .
59
67
56
80
54
268
2,770 ,
3,380
1,200
690
3,980
2,610
Maximum for
Monthly Average
19
22
,23
23
: 22
22
22
22
22
22
25
22
26
21
104
1,110
1,450
420
320
1,690
1,050
 All units are micrograms per liter.

2Metals limitations apply only to noncomplexed metal-bearing waste streams,
 including those listed in Table X-4.  Discharges of chromium, copper, lead,
 nickel, and zinc from "complexed metal-bearing process wastewater," listed in
 Table X-5, are not subject to these limitations.

3Cyanide limitations apply only to cyanide-bearing waste streams, including
 those listed in Table X-3.

4Total zinc limitations and standards for rayon fiber manufacture by the
 viscose process and acrylic fiber manufacture by the zinc chloride/solvent
 process are 6,796 ug/1 and 3,325 ug/1 for Maximum for Any One Day and Maximum
 for Monthly Average, respectively.
                                     11-13

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                   TABLE II-3.
    BAT  EFFLUENT LIMITATIONS  AND NSPS  FOR THE
NON-END-OF-PIPE BIOLOGICAL TREATMENT SUBCATEGORY
Pollutant
Number
1
3
4
6
7
8
9
10
11
12
13
14
16
23
25
26
27
29
30
32
33
34
38
39
42
44
45
52
55
56
57
58
59
60
65
66
68
70
Pollutant Name
Acenaphthene
Acrylonitrile
Benzene
Carbon Tetrachloride
Chlorobenzene
1,2, 4-Tri chlorobenzene
Hexachlorobenzene
1 , 2-Dichloroethane
1,1, 1-Trichloroethane
Hexachloroethane
1-1-Dichloroethane
1,1, 2-Trichloroethane
Chloroethane
Chloroform
1 , 2-Dichlorobenzene
1 , 3-Di chlorobenzene
1,4-Dichlorobenzene
1, 1-Dichloroethylene
1 , 2-Trans-dichloroethylene
1 , 2-Dichloropropane
1 , 3-Dichloropropene
2,4-Dimethylpheriol
Ethylbenzene
Fluoranthene
Bis (2-Chloroisopropyl) ether
Methylene Chloride
Methyl Chloride
Hexachlorobutadiene
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2 , 4-Dini trophenol
4 , 6-Dini tro-o-cresol
Phenol
Bis(2-ethylhexyl)phthalate
Di-n-butyl phthalate
Diethyl phthalate
BAT Effluent
Maximum for
Any One Day
, 47
232
134
380
380
794
794
574
59
794 .
59
127
295
325
794
380
380
60
66
794
794
47
380
54
794
170
295
380
47
6,402
231
576
4,291
277
47
258
43
113
Limitations and NSPS1
Maximum for
Monthly Average
19
94
57
142
142
196
196
180
22
196
22
32
110
111
196
142
J-*ri*
142
J.*T£>
22
25
196
196
19
142
22
196
36
110
142
19
i
2.237
£* p £, J /
65
\J *J
162
1,207
78
/ \J
19 ";
•*• *f
95 ;
20
£j\J
46
                    11-14

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                                TABLE II-3.
                 BAT EFFLUENT  LIMITATIONS AND NSPS  FOR THE
        NON-END-OF-PIPE BIOLOGICAL TREATMENT SUBCATEGORY (Continued)
BAT Effluent Limitations and NSPS1
Pollutant
Number
- 	 71
72
73
74
75
76
77
78
80
81
84
85
86
87
88
119
120
121
122
124
128
Pollutant Name
Dimethyl phthalate
Benzo(a)anthracene
Benzo(a)pyrene
3 , 4-Benzof luoranthene
, Benzo(k)f luoranthene
Chrysene
Acenaphthylene
Anthracene
Fluorene
Phenanthrene
Pyrene
Tetrachloroethylene
Toluene
Trichloroethylene
Vinyl Chloride2
Total Chromium
Total Copper
Total Cyanide
Total Lead
Total Nickel^
Total Zinc2'
Maximum
Any One
47
47
48
48
47
47
47
47
47
47
48
164
74
69
172
2,770
3,380
1,200:
690
3,980
2,610
for Maximum for
Day Monthly Average
19
19
20
20
19
19
19
19
19
19
; 20
IT ri
52
28
' 26
97
1,110
1,450
420
320
1,690
1,050
     units are micrograms per,liter.                            ,

2Metals limitations apply only to nbncomplexed metal-bearing waste streams,
 including those listed in Table X-4.  Discharges of chromium, copper, lead,
 nickel, and zinc from "complexed metal-bearing process wastewater," listed in
 Table X-5, are not subject to these limitations.  ,            .

3Cyanide limitations apply only to cyanide-bearing waste streams,  including
 those listed in Table X-3.   .                         ,  ,

4Total zinc limitations and standards for rayon fiber manufacture by the  ;
 viscose process and acrylic fiber manufacture by the zinc,chloride/solvent
 process are 6,796 ug/1 and 3,325; ug/1 for Maximum for Any One Day and Maximum
 for Monthly Average, respectively.                             :
                                     11-15

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      The Agency issued conventional pollutant new source standards for the
 same seven subcategories for which BPT limits were established.  These
 standards are equivalent to the limits established for BPT shown in
 Table II-l. Priority pollutant new source standards are applied to new sources
 according to the same subcategorization scheme applicable under BAT.  The set
 of 63 standards listed in Table II-2 for the end-of-pipe biological treatment
 subcategory will apply to new sources that use biological treatment in order1
 to comply with BOD5 and TSS limitations.   The standards in the subcategory for
 sources that do not use end-of-pipe biological treatment apply to new sources
 that will either generate such low levels of BOD5 that they do not need to use
 end-of-pipe biological treatment,  or that choose to use physical/chemical
 treatment to comply with the BOD5  standard.   These facilities will have to
 meet the 59 priority pollutant standards  listed in Table II-3,  which are  based
 on the application of in-plant control technologies with or without end-of-
 pipe physical/chemical treatment.

      EPA has determined that NSPS  will not  cause a barrier to entry for new
 source OCPSF plants.

      6.   PSES                         ,
      Pretreatment  standards  for  existing  sources applicable  to  indirect
 dischargers  are generally analogous  to BAT limitations  applicable  to  direct
 dischargers.  The  Agency  promulgated  PSES for  47 priority  pollutants  which
 were determined to pass  through  POTWs.  The  standards apply  to  all  existing
 indirect  discharging  OCPSF plants.  EPA determines which pollutants  to
 regulate  in  PSES on the basis  of whether or  not  they pass  through,  cause  an
 upset, or otherwise.interfere  with operation of  a POTU  (including interference
 with sludge  practices).   A detailed discussion of  the pass-through analysis is
 presented in  Section  VI.

      Indirect dischargers generate wastewater with the  same pollutant
 characteristics as  the direct  discharge plants;  therefore, the same tech-
nologies that were  discussed for BAT are appropriate for application at PSES.
The Agency established PSES for all indirect dischargers on the same
 technology basis as the BAT non-end-o'f-pipe biological  treatment subcategory.
                                   ' 11-16

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Therefore, the pretreatment standards for existing sources>-shown in Table
II-4, are equivalent to the BAT limitations for the non-end-of-pipe biological
treatment subcategory for the pollutants deemed to pass through,

     EPA is not including end-of^pipe biological treatment in the final PSES
model technology in part, because, as a matter of treatment thepry, biological
pretreatment may be largely redundant to the biological treatment provided by
the POTV.      ,,       .               .;--,        ,.....,--,.

     Although EPA has rejected the option pf adding end-of-pipe biological
treatment, EPA sometimes uses biological treatment as part of its model
technology for the in-plant treatment of certain semivolatile pollutants  such
as phenol, the phthalate esters, and  the polynuclear aromatics.  Specifically,
for such pollutants, EPA has in some  cases used in-plant biological treatment
systems as an alternative to in-plant activated carbon adsorption for  these
organic pollutants.  Thus, EPA actually has used biological treatment.as  part
of PSES model treatment technology where appropriate.

     7.  PSNS
     Like PSES and BAT, PSNS is generally analogous to NSPS.  However, as for
PSES, EPA is not establishing PSNS limits for  conventional pollutants  or
including end-of-pipe biological  treatment  in  its PSNS model  treatment tech-
nology,  for  the same reasons discussed above with respect  to  PSES.  The Agency
promulgated  PSNS on the same technology basis  as PSES, and  issued standards
for  the  47 priority pollutants in Table II-4 that have been determined to pass
through  or otherwise interfere with  the operation of POT¥s.   The Agency has
determined that PSNS will not cause  a barrier  to entry for new  source  OCPSF
plants.
                                     11-17

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                            TABLE II-4.
PRETREATMENT STANDARDS FOR EXISTING AND NEW SOURCES (PSES AND PSNS)
Pollutant
Number
1
4
6
7
8
9
10
11
12
13
14
16
23
25
26
27
29
30
32
33
34
38
39
44
45
52
55
56
57
58
60
65
66
68
70
71
78
80
81
84
85
86
87
Pretreatment Standards1
Pollutant Name
Acenaphthene
Benzene
Carbon Tetrachloride
Chlorobenzene
1,2, 4-Trichlorobenzene
Hexachlorobenzene
1 , 2-Dichloroethane
1 , 1 , 1-Trichloroethane
Hexachloroethane
1-1-Dichloroe thane
1,1, 2-Tri chloroe thane
Chloroethane
Chloroform
1 , 2-Dichlorobenzene
1 , 3-Di chlorobenzene
1,4-Dichlorobenzene
1, 1-Di chloroe thy lene
1,2-Trans-dichloroethylene
1 , 2-Dichloropropane
1 , 3-Dichloropropene
2 , 4-Dimethylphenol
Ethylbenzene
Fluoranthene
Methylene Chloride
Methyl Chloride
Hexachlorobutadiene
Naphthalene
Ni.trobenzene
2-Nitrophenol
4-Nitrophenol
4,6-Dinitro-o-cresol
Phenol
Bis(2-ethylhexyl)phthalate
Di-n-butyl phthalate
Diethyl phthalate
Dimethyl phthalate
Anthracene
Fluorene
Phenanthrene
Pyrene
Tetrachloroethylene
Toluene
Trichloroethylene
Maximum for
Any One Day
47
134
380
380
794
794
574
59
794
59
127
295
325
794
380
380
60
66
794
794
47
380
54
170
295
380
47
6,402
231
576
Til
47
258
43
113
47
47
47
47
48
164
74
69
Maximum for
Monthly Average
19
57
142
142
196
196
180
22
196
22
32
110
111
196
142
142
22
25
196
196
19
142
22
36
110
142
19
2,237
65
162
78
19
95
20
46
19
19
19
19
20
52
28
26
                              11-18

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                                 TABLE II-4.
     PRETREATMENT STANDARDS FOR:EXISTING AND NEW SOURCES (PSES AND PSNS)
                                 (Continued)

Pollutant
Number
88
121
122
128


Pollutant Name
Vinyl Chloride
Total Cyanide
Total Lead
Total Zinc '
Pre treatment
Maximum for
Any One Day
172
1,200
690
2,610
Standards
Maximum for
Monthly Average
97
420
320
1,050
     units are micrograms per liter.

2Cyanide limitations apply only to cyanide-bearing waste streams, including
 those listed in Table X-3.

3Metals limitations apply only to noncomplexed metal-bearing waste streams,
 including those listed in Table X-4.  Discharges of lead and zinc from
 "complexed metal-bearing process wastewater," listed in Table X-5, are not
 subject to these limitations.

4Total zinc limitations and standards for rayon fiber manufacture by the
 viscose process and acrylic fiber manufacture by the zinc chloride/solvent
 process are 6,796 ug/1 and 3,325 ug/1 for Maximum for Any One Day and Maximum
 for Monthly Average, respectively.
                                     11-19

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                                 SECTION III
                             INDUSTRY DESCRIPTION

A.  INTRODUCTION
     The organic chemicals industry began modestly in the middle of the 19th
century.  The production of coke, used both as a fuel and reductant in blast
furnaces for steel production, generated coal tar as a by-product.  These tars
were initially regarded as wastes.  However, with the synthesis of the first
coal tar dye by Perkin in 1856, chemists and engineers began  to recover the
waste tar and use it to manufacture additional products.

     The organic chemicals industry began with the isolation  and commercial
production of aromatic hydrocarbons (e.g., benzene and toluene and phenolics
from coal tar).  As more organic compounds possessing valuable properties were
identified, commercial production methods for these  compounds became  desir-
able.   The early products of  the chemical industry were  dyes, explosives, and
Pharmaceuticals.

     The economic  incentive  to recover and use by-products  was a  driving  force
behind  the growing  synthetic  chemicals industry.  For  example,  the manufacture
of chlorinated  aromatics was  prompted by:   1)  the availability of large
quantities of  chlorine  formed as  a  by-product  from  caustic  soda  production
 (already a commodity  chemical),  2)  the availability of benzene derived from
 coal  tar, and  3)  the  discovery that compounds  could serve as  intermediates  for
 the production of  other valuable derivatives,  such  as  phenol  and picric  acid.
 Specialty products such as  surfactants, pesticides,  and aerosol  propellants
 were  developed later  to satisfy particular  commercial  needs.

      The plastics  and synthetic fibers industry began later as an outgrowth of
 the organic  chemicals industry.  The first  commercial polymers,  rayon and
 bakelite,  were produced in the early 1900's from feedstocks manufactured by
 the organic  chemicals industry.  In  the last several decades, the development
 of a variety of plastic and synthetic fiber products and the diversity of
                                      III-l

-------
  markets  and  applications  of these products  have  made  the  plastic  and  synthetic
  fibers industry  the  largest (measured  by volume) consumer of  organic
  chemicals.
                                                                             i
      Chemicals derived  from coal  were  the principal feedstocks of the early
  industry, although ethanol,  derived  from fermentation, was  the source of some
  aliphatic compounds.  Changing  the source of industry feedstocks  to less ex-
  pensive petroleum derivatives lowered  prices and  opened new markets for
  organic chemicals, plastics, and  synthetic  fibers during  the  1920's and
  1930's.   By World War II,  the modern  organic chemicals and plastics and syn-
  thetic fiber industries based on  petro-chemicals were firmly  established in
  the United States.

      Today,  the organic chemicals, plastics and synthetic fibers  (OCPSF)
 industry includes production facilities of two distinct types:  those whose
 primary function is chemical synthesis, and those that recover organic chemi-
 cals as by-products from unrelated manufacturing operations such as coke
 plants  (steel production)  and pulp mills (paper production).  The majority of
 the plants in this industry are plants  that  process chemical precursors  (raw
 materials) into a wide variety of products for virtually every industrial and
 consumer  market.

      Approximately 90 percent (by weight) of the  precursors,  the  primary
 feedstocks for  all of the  industry's  thousands  of products,  are derived  from
 petroleum and natural gas.   The  remaining 10 percent is  supplied  by plants
 that  recover  organic  chemicals  from coal tar condensates generated by  coke
 production.

      There are numerous ways to  describe the OCPSF industry; however,  tradi-
 tional profiles such  as number of  product  lines or volume  of product sales
 mask  the industry's complexity and diversity.   The industry is even more
 difficult  to describe  in terms that make distinctions among plants according
 to wastewater characteristics.  Subsequent parts  of this section discuss the
OCPSF industry from several  different perspectives, including  product line,
product sales, geographic distribution,   facility  size,  facility age, and
wastewater treatment and disposal  methods as practiced by  the  industry.  OCPSF
                                    III-2

-------
wastewater treatment practices are summarized in Section II and described in
detail in Section VII of this document.  The subcategorization of plants
within the OCPSF industry by process chemistry, raw and treated wastewater
characteristics, and other plant-specific factors, is discussed in Section IV.

B.  DEFINITION OF THE INDUSTRY
     A single definition of the OCPSF  industry is difficult to derive because
of the complexity and diversity of the products and the manufacturing proces-
ses used in  the industry.  However, some  traditional profiles can provide
general descriptions of the industry,  and these are discussed briefly in the
following subsections:

     •  Standard Industrial Classification  (SIC)  system
     •  Scope of the final regulation
     •  Raw  materials and product, processes
     •  Geographic  location
     •  Age  of  plant
     •  Size of plant
     •  Mode of discharge.

     1.   Standard  Industrial  Classification System
     Standard  Industrial  Classification  (SIC)  codes,  established by the U.S.
 Department  of  Commerce,  are  classifications of commercial and industrial es-
 tablishments by type of activity in which they are engaged.   The primary pur-
 pose of the SIC code is to  classify the  manufacturing industries for the col-
 lection of  economic data.   For this reason, the product descriptions in SIC
 codes  are arbitrary,  often technically ambiguous, and in some cases inaccur-
 ately  representative of the products  that are purported to be classified.   SIC
 codes  also list archaic products that are no longer relevant to the OCPSF
 industry.   In some industries the SIC Code(s) match the activities covered by
 the issuance of effluent guidelines and standards regulations.    For the OCPSF
 industry,  product descriptions under  the following SIC codes are nominal at
 best:

      2865   Cyclic (Coal Tar) Crudes, and Cyclic Intermediates, Dyes, and
             Organic Pigments (Lakes and Toners)
                                      III-3

-------
       2869
       2821

       2823
       2824
  Industrial Organic Chemicals, Not Elsewhere Classified
  Plastics Materials, Synthetic Resins, and Nonvulcanizable
  Elastomers
  Cellulosic Man-Made Fibers
  Synthetic Organic Fibers,  Except Cellulosic.
 In addition, as a  result  of  1976  litigation  and  agreement,  the  organic  chemi-
 cals manufacturing, and the  plastics and  synthetic materials manufacturing
 industries  (since  combined into the industry category addressed by  this devel-
 opment document) was defined to include all  facilities manufacturing products
 that could  be construed to fall within these specific SIC codes.  The U.S.
 Environmental Protection Agency (EPA) considered two of these SIC codes:  SIC
 2865, cyclic (coal tar) crudes, and cyclic intermediates, dyes, and organic
 pigments (lakes and toners);  and SIC 2869, industrial organic chemicals, not
 elsewhere classified,  to be applicable to the organic chemicals manufacturing
 industry.

      The products that the SIC Manual includes  in the industrial organic chem-
 ical  industry (SIC 286) are natural products  such as  gum and wood chemicals
 (SIC  2861),  aromatic and other organic  chemicals  from the processing of  coal
 tar and  petroleum (SIC 2865), and  aliphatic or  acyclic  organic  chemicals (SIC
 2869).

     These chemicals are  the  raw materials for  deriving  products  such as plas-
 tics, rubbers, fibers,  protective  coatings, and detergents,  but  have few
 direct consumer uses.   Gum and  wood chemicals (SIC 2861) are regulated under a
 separate  consent decree industrial category,  gum  and wood chemicals  manufac-
 turing (40 CFR 454).

     The  plastics and synthetic materials  manufacturing category as  defined  by
 the 1976  agreement, comprises SIC 282, plastic materials and synthetic resins,
synthetic rubber,  and synthetic and other manmade fibers, except glass.   SIC
282 includes the following SIC codes:
     2821
Plastics Materials, Synthetic Resins, and Nonvulcanizable
Elastomers
                                    III-4

-------
     2822   Synthetic Rubber (Vulcanizable Elastomers)
     2823   Cellulosic Man-Made Fibers
     2824   Synthetic Organic Fibers,  Except Cellulosic.

     Of these codes, SIC 2822 is covered specifically in the 1976 agreement by
another industrial category, rubber manufacturing (40 CFR 428).  Similarly,
miscellaneous plastic products (SIC 3079), which is related to the plastics
industry, is covered by the specific industrial category, plastics molding and
forming (40 CFR 463).  EPA considers a plant that merely processes a polymeric
material for any end use other than as a fiber to be in SIC 3079.  In con-
trast, if the plant manufactures that polymeric material from monomeric raw
materials, then that portion of its production is in SIC 2821.

     The relationship of all the industries listed in the SIC Manual as being
related  to production of organic chemicals, plastics, or synthetic fibers  is
shown  in Figure III-l.

         a.  Additional  SIC  Codes Could Be  Considered  as Part of  the OCPSF
            Industry
     A review of  SIC  product code  data supplied  by OCPSF industry  facilities
in  the 1983 Section 308 Questionnaire identified 11  SIC product  categories
that are classified under SIC  codes different  from  those in the  Settlement
Agreement discussed above that could  be  considered as part  of  the  OCPSF
industry because  they include  the  manufacture  of OCPSF  products  or utilize
OCPSF  process chemistry.  These additional SIC code  product categories are
also shown  in Figure III-l  and listed below.
      SIC Code
      2891400

      2891423

      2891433
      2891453
   Description
Synthetic Resin (and Rubber)
   Adhesives
Phenolics and Modified Phenolics
   Adhesives
Urea and Modified Urea Adhesives
Acrylic Adhesives
                                      III-5

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                  Petrochemical  Inter-Industry Relationship
  Feedstock Industries
Petrochemical Industries
                                                                Petrochemical-Dependent
                                                                   Chemical Industries
                                                  2821
                                                 Plastic
                                                Materials

                                                  2822
                                                Synthetic
                                                Rubbers

                                                  2824
                                                Synthetic
                                                 Fibers

                                                  2843
                                               Surfactants
                                      3079
                                   Misc. Plastics
                                    Products



1311
Crude .
Petroleum
and Natural Gas

r-»> 1321 -*.
Natural
Gas Liquids





—*-2911— *•
Petroleum







Refining
r-+~ 2865 — ft*
Cyclics and 1
Aromatics 1
— »- 2869 Jft.
Acyclics and
Aliphatics








^
^


*
^

Nitrogenous j __
Fertilizers *

Carbon """
Black
                                                                 2823 Cellulosic Fibers
                                                                 2831 Biologicals

                                                                 2833 Medicinals and Botanicals
                                                                 2834 Pharmaceuticals
                                                                 2841 Detergents
                                                                 2842 Polishes
                                                                 2844 Toiletries  ,
                                                                 2851 Paints

                                                                 2879 Pesticides
                                                                 2891 Adhesives


                                                                 2874 Phosphatic Fertilizers
                                                                 2875 Mixed Fertilizers
                                                                 2892 Explosives


                                                                 2893 Printing Inks
         Source: U.S. Department of Commerce, 1981. " 1981 U.S. Industrial Outlook."
                Bureau of Industrial Econo'mics, Washington, D.C.
                                Figure 111-1.
Relationships Among the SIC Codes Related to the Production
      of Organic  Chemicals, Plastics, and Synthetic  Fibers
                                    m-6

-------
    2843085
    2899568
    2899597


    2899598


    2911058

    2911632


    3079000
Bulk Surface Active Agents
Sizes, All Types
Other Industrial Chemical Specialties,
   Including Fluxes, Plastic Wood Prep-
   arations and Embalming Chemicals
Other Industrial Chemical Specialties,
   Including Fluxes and Plastic Wood
   Preparations
Aromatics", Made from Purchased
   Refinery Products
Liquified Refinery Gases (Including
   Other Aliphatics), Made from Purchased
   Refinery Products
Miscellaneous Plastics Products (Including
   Only Cellophane Manufacture From  the
   Viscose Process)
        b.  Primary, Secondary, and Tertiary SIC Codes
     SIC codes, established by the U.S. Department of Commerce, are classifi-
cations of commercial and industrial establishments by type of activity in
which they are engaged.  The SIC code system is commonly employed for collec-
tion and organization of data  (e.g., gross production, sales, number of em-
ployees, and geographic location) for U.S. industries.   An establishment is
an economic unit that produces goods or services (e.g., a chemical plant, a
mine, a factory, or a store).   The establishment is a single physical loca-
tion and is typically engaged  in a single or dominant type of economic activ-
ity for which an industry code is applicable.

     Where a single physical location encompasses two or more distinct and
separate economic activities for which different industrial classification
codes seem applicable  (e.g., a steel plant that produces organic chemicals as
a result of its coking operations), such activities are treated as separate
establishments under separate  SIC codes, provided that:  1) no one industry
description in the  SIC includes such combined  activities; 2)  the employment  in
each such economic  activity is significant;  3) such activities are not
ordinarily associated  with  one another at  common physical locations; and
                                     III-7

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 4) reports  can  be  prepared  on  the number  of  employees,  their wages  and
 salaries, and other establishment type data.  A single  plant may  include more
 than one establishment and  more  than one  SIC code.

      A plant is assigned a  primary SIC code  corresponding to its  primary
 activity, which is the activity  producing its primary product or  group of
 products.  The primary product is the product having the highest  total annual
 shipment value.   The secondary  products of  a plant are all products other
 than the primary products.  Frequently in the chemical industry a plant may
 produce large amounts of a low-cost chemical, but be assigned another SIC code
 because of lower-volume production of a high-priced specialty  chemical.  Many
 plants are also assigned secondary,  tertiary, or lower order SIC codes corres-
 ponding to plant activities beyond their primary activities.   The inclusion
 of plants with a secondary or lower order SIC code produces a list of plants
 manufacturing a given class of industrial products,  but also includes plants
 that  produce only minor (or in some cases insignificant) amounts of thpse
 products.   While the  latter plants are part  of  an  industry economically,  their
 inclusion may distort the description of the industry's wastewater production
 and treatment,  unless the wastewaters can be segregated by SIC  codes.

         c-   Products  of Various SIC  Categories
      Important  classes  of chemicals  of  the organic chemicals industry  within
 SIC 2865  include:   1) derivatives of  benzene, toluene,  naphthalene,  anthra-
 cene, pyridine,  carbazole, and  other  cyclic  chemical products;  2)  synthetic
 organic dyes; 3) synthetic organic pigments;  and 4) cyclic  (coal  tar)  crudes,
 such as light oils  and  light oil  products; coal tar acids; and  products of
 medium and heavy oil such as creosote oil, naphthalene,  anthracene and their
 high homologues, and  tar.

     Important classes of chemicals of the organic chemicals industry within
 SIC 2869 include:   1)  non-cyclic organic chemicals such as acetic,  chloroi-
acetic, adipic, formic, oxalic acids and their metallic salts, chloral, for-
maldehyde, and methylamine; 2) solvents such  as amyl,  butyl, and ethyl alco-
hols;  methanol; amyl,  butyl, and  ethyl acetates; ethyl ether, ethylene glycol
ether, and diethylene glycol ether; acetone,   carbon disulfide, and chlorinated
                                    III-8

-------
solvents such as carbon tetrachloride, tetrachloroethene, 'and trichloroethene;
3) polyhydric alcohols such as ethylene glycol, sorbitol, pentaerythritol, and
synthetic glycerin? 4) synthetic perfume and flavoring materials such as
coumarin, methyl salicylate, saccharin, citral, citronellal, synthetic
geraniol, ionone, terpineol, and synthetic vanillin; 5) rubber processing
chemicals such as accelerators and antioxidants, both cyclic and acyclic; 6)
plasticizers, both cyclic and acyclic, such as esters of  phosphoric acid,
phthalic anhydride, adipic acid, lauric acid, oleic acid, sebacic acid, and —
stearic acid; 7) synthetic tanning agents such as sulfonic acid condensates;
and 8) esters, amines, etc. of polyhydric alcohols and fatty and other acids.
Tables III-l and 111^2 list specific  products of SIC 2865 and SIC 2869,
respectively.

     important products produced by the plastics and synthetic fibers industry
within SIC  2821  include:  cellulose acetate, phenolic, and other  tar acid
resins; urea and melamine resins; vinyl acetate resins;  polyethylene resins;
polypropylene resins;  rosin modified  resins; coumarone-indene resins;
petroleum resins;  polyamide resins, silicones, polyisobutylenes,  polyesters,
polycarbonate resins,  acetal  resins,  fluorohydrocarbon resins.  Table III-3
lists  important  products of SIC  2821:.

     Important cellulosic man-made  fibers  (SIC 2823)  include:  cellulose
acetate, cellulose triacetate and rayon,  triacetate  fibers.   Important  non-
cellulosic  synthetic  organic  fibers  (SIC  2824)  include:   acrylic,  modacrylic,
fluorocarbon, nylon,  olefin,  polyester, and polyvinyl.   Tables III-4 and -111-5
list 'specific products of SIC 2823  and SIC 2824,  respectively.

     Certain products of  SIC  groups  other than 2865,  2969,  2821,  2823,  and
2824 are identical to OCPSF  industry  products.   Benzene,  toluene,  and mixed
xylenes  manufactured  from purchased refinery products in SIC 29110582  (in
contrast to benzene,  toluene, and mixed xylenes  manufactured in  refineries—
 SIC 2,9110558) are manufactured with the same reaction chemistry  and unit
operations  as OCPSF products  (see  Table III-6).   Similar considerations apply
 to aliphatic hydrocarbons manufactured from purchased refinery products—
 SIC .29116324 (see Table III-7).
                                      III-9

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                                  TABLE III-l.
         SIC  2865:   CYCLIC  (COAL TAR),  CRUDES, AND CYCLIC INTERMEDIATES,
                 DYES, AND ORGANIC PIGMENTS  (LAKES AND TONERS)
 Acid dyes, synthetic
 Acids, coal tar: derived from coal tar
   distillation
 Alkylated diphenylamines,  mixed
 Alkylated phenol, mixed
 Arainoanthraquinone
 Aminoazobenzene
 Arainoazotoluene
 Arainophenol
 Aniline
 Aniline oil
 Anthracene
 Anthraquinone dyes
 Azine dyes
 Azo dyes
 Azobenzene
 Azoic dyes
 Benzaldehyde
 Benzene hexachloride (BHC)
 Benzene,  product of coal tar
   distillation
 Benzoic acid
 Benzol,  product  of coal, tar  distillation
 Biological stains
 Chemical indicators
 Chlorobenzene
 Chloronaphthalene
 Chlorophenol
 Chlorotoluene
 Coal  tar  crudes,  derived from coal
   tar distillation
 Coal  tar  distillates
 Coal  tar  intermediates
 Color lakes  and  toners
 Color pigments,  organic: except animal
  black and  bone  black
 Colors, dry: lakes,  toners,  or full
  strength organic colors
 Colors, extended  (color  lakes)
 Cosmetic dyes, synthetic
 Creosote oil, product of coal tar
  distillation
 Cresols, product of coal tar
  distillation
Cresylic acid, product of coal tar
  distillation
Cyclic crudes, coal tar: product of
  coal tar distillation
 Hydroquinone
 Isocyanates
 Lake red C toners
 Leather dyes and stains,  synthetic
 Lithol rubine lakes and toners
 Maleic anhydride
 Methyl violet toners
 Naphtha,  solvent: product of coal
   tar distillation
 Naphthalene chips and flakes
 Naphthalene,  product of coal tar
   distillation
 Naphthol,  alpha and beta
 Nitro dyes
 Nitroaniline
 Nitrobenzene
 Nitrophenol
 Nitroso dyes
 Oil,  aniline
 Oils:  light,  medium,  and  heavy—pro-
   duct of  coal tar distillation
 Organic pigments  (lakes and  toners)
 Orthodichlorobenzene
 Paint  pigments, organic
 Peacock blue  lake
 Pentachlorophenol
 Persian orange lake
 Phenol
 Phloxine toners
 Phosphomolybdic acid  lakes and toners
 Phosphotungstic acid  lakes and toners
 Phthalic anhydride
 Phthalocyanine  toners
 Pigment scarlet lake
 Pitch,  product of coal  tar
  distillation
 Pulp colors, organic
 Quinoline dyes
 Resorcinol
 Scarlet 2 R lake
 Stains  for leather
 Stilbene dyes
 Styrene
 Styrene monomer
Tar, product of coal tar distillation
Toluene, product of coal tar
  distillation
                                    111-10

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                         ,    •    TABLE .1.11-1.
       SIC 2865:  CYCLIC (COAL TAR), CRUDES, AND CYCLIC INTERMEDIATES,
                DYES, AND ORGANIC PIGMENTS (LAKES AND TONERS)
                                 (Continued)
Cyclic intermediates
Cyclohexane
Diphenylamine
Drug dyes, synthetic
Dye (cyclic) intermediates
Dyes, food: synthetic
Dyes, synthetic organic
Eosine toners
Ethylbenzene
Toluidines
Toluol, product of coal tar distilla-
  tion
Vat dyes, synthetic
Xylene, product of coal.tar distilla-
  tion
Xylol, product of coal  tar distilla-
  tion
Source:  OMB 1972.  Standard Industrial Classification Manual  1972.
         Statistical Policy Division, Washington, D.C.
                                      III-ll

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              SIC 2869:
          TABLE III-2.
INDUSTRIAL ORGANIC CHEMICALS,  NOT ELSEWHERE
           CLASSIFIED
  Accelerators, rubber processing:
     cyclic and acyclic
  Acetaldehyde
  Acetates, except natural acetate of
     lime
  Acetic acid, synthetic
  Acetic anhydride
  Acetin
  Acetone,  synthetic
  Acid  esters, amines,  etc.
  Acids,  organic
  Acrolein
  Acrylonitrile
  Adipic  acid
  Adipic  acid  esters
  Adiponitrile
  Alcohol,  aromatic
  Alcohol,  fatty:  powdered
  Alcohol,  methyl:  synthetic
     (methanol)
  Alcohols, industrial:  denatured
     (nonbeverage)
 Algin products
 Amyl acetate and alcohol
 Antioxidants, rubber processing:
    cyclic and acyclic
 Bromochlorome thane
 Butadiene, from alcohol
 Butyl  acetate, alcohol,  and
    proprionate
 Butyl  ester solution of 2,  4-D
 Calcium oxalate
 Camphor, synthetic
 Carbon bisulfide (disulfide)
 Carbon tetrachloride
 Casing fluids,  for  curing fruits,
    spices, tobacco,  etc.
 Cellulose  acetate, unplasticized
 Chemical warfare  gases
 Chloral
 Chlorinated solvents
 Chloroacetic  acid and metallic
    salts
 Chloroform
 Chloropicrin
 Citral
 Citrates
Citric acid
Citronellal
                  Coumarin
                  Cream of tartar
                  Cyclopropane
                  DDT,  technical
                  Decahydronaphthalene
                  Dichlorodifluoromethane
                  Diethylcyclohexane  (mixed  isomers)
                  Diethylene glycol ether
                  Dimethyl divinyl acetylene
                     (di-isopropenyl  acetylene)
                  Dimethylhydrazine,  unsymmetrical
                  Embalming fluids
                  Enzymes
                  Esters of phosphoric, adipic,
                    lauric, oleic, sebacic, and
                    stearic acids
                 Esters of phthalic anhydride
                 Ethanol, industrial
                 Ether
                 Ethyl acetate, synthetic
                 Ethyl alcohol, industrial
                    (non-beverage)
                 Ethyl butyrate
                 Ethyl cellulose, unplasticized
                 Ethyl chloride
                 Ethyl ether
                 Ethyl formate
                 Ethyl nitrite
                 Ethyl perhydrophenanthrene
                 Ethylene
                 Ethylene glycol
                 Ethylene glycol ether
                 Ethylene glycol,  inhibited
                 Ethylene oxide
                 Fatty  acid esters, amines, etc.
                 Ferric ammonium oxalate
                 Flavors and flavoring materials,
                   synthetic                       \
                 Fluorinated hydrocarbon gases      ;
                 Formaldehyde (formalin)
                 Formic acid and metallic salts    ;
                 Freon
                Fuel propellants, solid:   organic  .
                Fuels, high energy:  organic        ;
                Geraniol,  synthetic
                Glycerin,  except from fats
                   (synthetic)                     ,
                Grain alcohol,  industrial
                   (non-beverage)
                                    111-12

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                                 TABLE III-2.
            SIC 2869:   INDUSTRIAL ORGANIC CHEMICALS,  NOT ELSEWHERE
                            •CLASSIFIED (Continued)
Hexamethylenediamine
Hexamethylenetetramine
High purity grade chemicals,
   organic: refined from technical
   grades
Hydraulic fluids, synthetic base
Hydrazine
Industrial organic cycle compounds
lonone
Isopropyl alcohol
Ketone, methyl ethyl
Ketone, methyl isobutyl
Laboratory chemicals, organic
Laurie acid esters
Lime citrate
Malononitrile, technical grade
Metallic salts of acyclic organic
   chemicals
Metallic stearate
Methanol, synthetic (methyl
   alcohol)
Methyl chloride
Methyl perhydrofluorine
Methyl salicylate
Methylamine
Methylene chloride
Monochlorodifluoromethane
Monomethylparaminophenol sulfate
Monosodium glutamate
Mustard gas
Napthalene sulfonic acid
   condensates
Naphthenic acid  soaps .
Normal hexyl  decalin
Nuclear fuels, organic
Oleic  acid esters
Organic acid  esters
Organic chemicals, acyclic
Oxalates
Oxalic acid and  metallic salts
Pentaerythritol
Perchloroethylene
Perfume materials, synthetic
Phosgene
Phthalates          * •.
Plasticizers, organic:   cyclic  and
    acyclic
Polyhydric alcohol esters,  amines,
    etc.
Polyhydric alcohols
Potassiium bitartrate
Propellants for missiles, solid:
   organic
Propylene
Propylene glycol
Quinuclidinol ester of benzylic
   acid
Reagent grade chemicals, organic:
   refined from technical grades
Rocket engine fuel, organic
Rubber processing chemicals,
   organic: accelerators and
   antioxidants
Saccharin
Sebacic acid
Silicones
Soaps, naphthenic acid
Sodium acetate
Sodium alginate
Sodium benzoate
Sodium glutamate
Sodium pentachlorophenate
Sodium sulfoxalate formaldehyde
Solvents, organic
Sorbitol
Staaric acid salts
Sulfonated naphthalene
Tackifiers, organic
Tannic acid
Tanning agents, synthetic organic
Tartaric  acid and metallic  salts
Tartrates
Tear  gas
Terpineol
Tert-butylated  bis
    (p-phenoxyphenyl)  ether  fluid
Tetrachloroethylene
Tetraethyl lead
Thioglycolic acid, for  permanent.
    wave lotions
Trichloroethylene
Trichloroethylene  stabilized,
    degreasing
Trichlorophenoxyacetic  acid
Trichlorotrifluoroethane
    tetrachlorodi  fluoroethane
    isopropyl alcohol
Tricresyl phosphate
                                     111-13

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                                 TABLE III-2.
            SIC 2869:  INDUSTRIAL ORGANIC CHEMICALS, NOT ELSEWHERE
                            CLASSIFIED (Continued)
Tridecyl alcohol
Trimethyltrithiophosphite (rocket
   propellants)
Triphenyl phosphate
Vanillin,' synthetic
Vinyl acetate
Source:  OMB 1972.  Standard Industrial Classification Manual 1972.
         Statistical Policy Division, Washington, D.C.
                                   111-14

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                                 TABLE III-3.
               SIC 2821:  PLASTIC MATERIALS, SYNTHETIC RESINS,
                        AND NONVULCANIZABLE ELASTOMERS
Acetal resins
Acetate, cellulose (plastics)
Acrylic resins
Acrylonitrile-butadiene-styrene resins
Alcohol resins, polyvinyl
Alkyd resins
Allyl resins
Butadiene copolymers, containing less
  than 50% butadiene
Carbohydrate plastics
Casein plastics
Cellulose nitrate resins
Cellulose propionate (plastics)
Coal tar resins
Condensation plastics
Coumarone-indene resins
Cresol-furfural resins
Cresol resins
Dicyandiamine  resins
Diisocyanate resins
Elastomers, nonvulcanizable  (plastics)
Epichlorohydrin bisphenol
Epichlorohydrin diphenol
Epoxy resins
Ester gum
Ethyl cellulose plastics
Ethylene-vinyl acetate  resins
Fluorohydrocarbon resins
Ion exchange resins
lonomer  resins
Isobutylene polymers
Lignin  plastics
Melamine resins
Methyl  acrylate resins
Methyl  cellulose plastics
Methyl  methacrylate  resins
Molding compounds, plastics
Nitrocellulose plastics (pyroxylin)
Nylon resins
Petroleum polymer resins
Phenol-furfural resins
Phenolic resins
Phenoxy resins
Phthalic alkyd resins
Phthalic anhydride resins
Polyacrylonitrile resins
Polyamide resins
Polycarbonate resins
Polyesters
Polyethylene resins
Polyhexamethylenediamine adipamide
  resins
Polyisobutylenes
Polymerization plastics, except
fibers
Polypropylene resins
Polystyrene resins
Polyurethane resins
Polyvinyl chloride resins
Polyvinyl halide resins
Polyvinyl resins
Protein plastics
Pyroxylin
Resins, phenolic
Resins, synthetic: coal  tar  and
  non-coal  tar
Rosin modified resins
Silicone fluid solution  (fluid  for
  sonar transducers)
Silicone resins
Soybean plastics
Styrene resins
Styrene-acrylonitrile  resins
Tar acid resins
Urea resins
Vinyl resins
 Source:   OMB 1972.   Standard Industrial Classification Manual 1972.
          Statistical Policy Division,  Washington,  D.C.
                                     111-15

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                                 TABLE III-4.
                     SIC 2823:  CELLULOSIC MAN-MADE FIBERS
Acetate fibers
Cellulose acetate monofilament, yarn,
  staple, or tow
Cellulose fibers, man-made
Cigarette tow, cellulosic fiber
Cuprammonium fibers
Fibers, cellulose man-made
Fibers, rayon
Horsehair, artifical:  rayon
Nitrocellulose fibers
Rayon primary products: fibers,
  straw, strips, and yarn
Rayon yarn, made in chemical
  plants (primary products)
Regenerated cellulose fibers
Triacetate fibers
Viscose fibers, bands, strips,
  and yarn
Yarn, cellulosic:  made in chemical
  plants (primary products)
Source:  OMB, 1972.  Standard Industrial Classification Manual 1972.
         Statistical Policy Division, Washington, D.C.
                                   111-16

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                                TABLE III-5
            SIC 2824:   SYNTHETIC ORGANIC FIBERS,  EXCEPT CELLULOSIC
Acrylic fibers
Acrylonitrile fibers
Anidex fibers
Casein fibers
Elastomeric fibers
Fibers, man-made:  except cellulosic
Fluorocarbon fibers
Horsehair, artificial:  nylon
Linear esters fibers
Modacrylic fibers
Nylon fibers and bristles
Olefin fibers
Organic fibers, synthetic:  except
   cellulosic
Polyester fibers
Polyvinyl ester fibers
Polyvinylidene chloride fibers
Protein fibers
Saran fibers
Soybean fibers (man-made textile
   materials)
Vinyl fibers
Vinylidene chloride fibers
Yarn, organic man-made fiber
   except cellulosic
Zein fibers
 Source:   OMB  1972.   Standard  Industrial  Classification Manual  1972.
          Statistical Policy Division,  Washington,  D.C.
                                      111-17

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                                 TABLE III-6.
         OCPSF CHEMICAL PRODUCTS ALSO LISTED AS SIC 29110582 PRODUCTS
                                Benzene
                                Cresylic acid
                                Cyclopentane
                                Naphthalene
                                Naphthenic Acid
                                Toluene
                                Xylenes, Mixed
                                C9 Aromatics
Sources  1982 Census of Manufacturers and Census of Mineral Industries.
         Numerical List of Manufactured and Mineral Products.  U.S. Department
         of Commerce, Bureau of the Census, 1982.
                                   111-18

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                                TABLE III-7.
         OCPSF CHEMICAL PRODUCTS ALSO LISTED AS SIC 29116324 PRODUCTS
C2 Hydrocarbons
Acetylene
Ethane
Ethylene
C3 Hydrocarbons
Propane
Propylene
C4 Hydrocarbons
Butadiene and butylene fractions
1,3-Butadieae, grade for rubber
n-Butane
Butanes, mixed
1-Butene
2-Butene
1-Butane and 2-butene, mixed
Hydrocarbons, C4, fraction
Hydrocarbons, C4, mixtures
Isobutane (2-Methylpropane)
Isobutylene (2-Methylpropene)
C4 Hydrocarbons, all other
   amylenes
Dibutanized aromatic concentrate
C5 Hydrocarbon, mixtures
Isopentane (2-Methylbutane)
Isoprene (2-Methyl-l,3-bu£adiene)
n-Pentane
1-Pentene
Pentenes, mixed
Piperylene (1,3-Pentadiene)
C5 Hydrocarbons, all other
C6 Hydrocarbons
Diisopropane
Hexane
Hexanes, mixed
Hydrocarbons, C5-C6, mixtures
Hydrocarbons, C5-C7, mixtures
Isohexane
Methylcyclopentadiene
Neohexane  (2,2-Dimethylbutane)
C6 Hydrocarbons, C6, all  other
n-Heptane
Heptenes,  mixed
Isoheptanes
C7 Hydrocarbons
C8 Hydrocarbons
Diisobutylene (Diisobutene)
n-Octane
Octenes, mixed
2,2,4-Trimethylpentane (Isooctane)
C8 Hydrocarbons, all other
C9 and above Hydrocarbons
Dodecene
Eicosane
Nonene (Tripropylene)
Alpha olefins
Alpha olefins, C6-C10
Alpha olefins, Cll and higher
n-Paraffins
n-Paraffins, C6-C9
n-Paraffins, C9-C15
n-Paraffins, C10-C14
n-Paraffins, C10-C16
n-Paraffins, C12-C18
n-Paraffins, C15-C17
n-Paraffins, other
Hydrocarbons, C5-C9, mixtures
Polybutene
Hydrocarbon derivatives
n-Butyl mercaptan (1-Butanethiol)
sec-Butyl mercaptan  (2-Butanethiol)
tert-Butyl mercaptan (2-Methyl-
   2-propanethiol)
Di-tert-butyl disulfide
Diethyl sulfide  (Ethyl sulfide)
Dimethyl sulfide
Ethyl mercaptan  (Ethanethiol)
Ethylthioethanol
n-Hexyl mercaptan (1-Hexanethiol)
Isopropyl mercaptan  (2-Propanethiol)
Methyl  ethyl  sulfide
Methyl  mercaptan (Methanethiol)
tert-Octyl mercaptan (2,4,4-Trimethyl-
    2-pentanethiol)
Octyl mercaptans
Thiophane  (Tetrahydrothiophene)
Hydrocarbon  derivatives:   all  other
    hydrocarbon  derivatives
Hydrocarbons, C9 and above,  all  other,
    including mixtures
 Source:  1982 Census of Manufacturers and Census of Mineral Industries.
          Numerical List of Manufactured and Mineral Products.   U.S.  Department
          of Commerce, Bureau of the Census, 1982.
                                     111-19

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      2.  Scope of the Final Regulation
      The promulgated regulation establishes effluent limitations guidelines
 and standards for existing and new organic chemicals, plastics, and synthetic
•fibers manufacturing facilities (BPT, BAT, NSPS, PSES, and PSNS).  The final
 regulations apply to process wastewater discharges from these facilities.

      For the purposes of this regulation, OCPSF process wastewater discharges
 are defined as discharges from all .establishments or portions of establish-
 ments that manufacture the products  or product groups listed in the applica-
 bility sections of the regulation and also in Appendix III-A of this document,
 and are included within the following U.S. Department of Commerce Bureau of
 the Census SIC major groups:

      •  SIC 2865 - Cyclic Crudes and Intermediates,  Dyes,  and Organic Pigments
      •  SIC 2869 - Industrial Organic .Chemicals,  Not Elsewhere Classified
      •  SIC 2821 - Plastic Materials,  Synthetic Resins,  and Nonvulcanizable
         Elastomers
      •  SIC 2823 - Cellulosic Man-Made Fibers
      •  SIC 2824 - Synthetic  Organic Fibers, Except  Cellulosic.

      The OCPSF regulation does not apply  to process  wastewater discharges from
the manufacture  of organic chemical  compounds  solely by  extraction  from  plant
and animal  raw materials  or by fermentation processes.   Thus,  ethanol  derived
from  natural sources  (SIC 28095112)  is  not considered  to be  an OCPSF  industry
product; however,  ethanol produced synthetically  (hydration  of ethene) is  an
OCPSF industry product.

      The OCPSF regulation covers all OCPSF products or processes whether  or
not they are located at facilities where  the OCPSF covered operations are  a
minor portion  of and ancillary to the primary production activities or a major
portion of  the activities.

     The OCPSF regulation does not apply  to discharges from OCPSF product/
process operations that are covered by  the provisions of other categorical
                                    111-20

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industry effluent limitations 'guidelines and standards if the wastewater is
treated in combination with the non-OCPSF industrial category regulated waste-
water.  (Some products or product groups'are manufactured by different pro-
cesses and some processes with slight operating condition variations give dif-
ferent products; EPA uses the term "product/process" to define all different
variations within this category of the same basic process to manufacture dif-
ferent products as well as to manufacture the same product using  different
processes.)  However, the OCPSF regulation applies to  the product/processes
covered by this regulation if the .facility'reports OCPSF products under SIC
codes 2865, 2869, or 2821, and its OCPSF wastewaters are treated  in  a  separate
treatment system at the facility or  discharged  separately to a  publicly owned
treatment works  (POTW).

      For example, some vertically  integrated  petroleum refineries and  pnarma-
ceutical manufacturers discharge wastewaters  from the  production of  synthetic
organic chemical  products  that are specifically regulated under the  petrochem-
ical and  integrated subcategories  of the petroleum refining point source  cate-
gory (40  CFR  Part 419,  Subparts  C  and E) or the chemical synthesis products
subcategory of the  Pharmaceuticals manufacturing point source category (40 CFR
Part 439,  Subpart C).   Thus,  the principles discussed in the preceding para-
graph apply  as follows:   the process wastewater discharges  by petroleum refin-
eries and pharmaceutical manufacturers from production of organic chemical
 products  specifically covered by 40 CFR Part 419 Subparts C and E and Part 439
 Subpart C,  respectively,  that are treated in combination with other petroleum
 refinery or pharmaceutical manufacturing wastewater, respectively, are not
 subject to regulation no matter what SIC they use to report their products.
 However,  if the wastewaters from their OCPSF production is separately dis-
 charged to a POT¥ or treated in a separate treatment system, and they report
 their products (from these processes) under SIC  codes 2865, 2869, or  2821,
 then these manufacturing operations  are subject  to regulation under the OCPSF
 regulation, regardless of whether the OCPSF products  are covered by 40 CFR
 Part 419, Subparts C and E and Part  439, Subpart C.
                                       _,.-,---,,.    , .   '•'-•,.'.,   - -1'  -..•>,   '-<•-
      The promulgated OCPSF category regulation applies  to  plastics  molding  and
 forming processes when plastic resin manufacturers mold or  form (e.g., extrude
 and pelletize)  crude intermediate plastic  material  for  shipment  off-site.
                                      111-21

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  This regulation also applies to the extrusion of fibers.   Plastics molding and
  forming processes other than those described above are regulated by the plas-
  tics molding and forming effluent guidelines and standards (40 CFR Part 463).

       Public comments requested guidance relating to the coverage of OCPSF
  research and development facilities.   Stand-alone OCPSF research and develop-
  ment, pilot-plant,  technical service,  and  laboratory bench-scale operations
  are  not  covered  by  the  OCPSF regulation.   However,  wastewater  from such opera-
  tions conducted  in  conjunction with and related  to  existing OCPSF manufactur-
  ing  operations at OCPSF facilities  is  covered by the OCPSF regulation because
  these operations would  most  likely  generate  wastewater  with characteristics
 similar  to  the commercial manufacturing facility.  Research and  development,
 pilot-plant,  technical  service, and laboratory operations  that are  unrelated
 to existing OCPSF plant  operations, even though  conducted  on-site,  are  not
 covered by the OCPSF regulation because  they may generate wastewater with
 characteristics dissimilar to  that  from  the commercial OCPSF manufacturing
 facility.

      Finally, as described in the following paragraphs, this regulation does
 not cover certain production that has historically been reported to the Bureau
 of Census under a non-OCPSF SIC subgroup heading, even if  such production
 could be reported under  one of the five SIC code groups covered by the final
 regulation.

      The  Settlement  Agreement required  the  Agency to establish  regulations for
 the organic  chemicals manufacturing SIC codes 2864 and 2869 and for the  plas-
 tics  and  synthetic materials  manufacturing  SIC Code  282.   SIC 282 includes the
 three codes  covered  by this regulation,  2821,  2823,  and  2824, as  well as SIC
 2822,  synthetic rubber (vulcanizable elastomers),  which  is  covered specific-
 ally  in the  Settlement Agreement by  another industrial category,  rubber  manu-
 facturing (40  CFR 428).   The  Agency  therefore directed its  data collection
 efforts to those facilities that report  manufacturing activities  under SIC
 codes 2821, 2823, 2824,  2865, and  2869.   Based on an  assessment of  this  infor-
mation and the integrated nature of  the  synthetic OCPSF  industry,  the Agency,
also defined the applicability of  the OCPSF regulation by listing  the specific
products and product groups that provide  the technical basis for  the regula-
 tion (see Appendix II1-A).
                                    111-22

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     Since many of these products may be reported under more than one SIC code
even though they are often manufactured with the same reaction chemistry or
unit operations, the Agency proposed to extend the applicability of the OCPSF
regulation (50 PR 29068; July 17, 1985 or 51 PR.44082; December 8,, 1986) to
include OCPSF production reported under the following SIC subgroups:

     •  SIC 2911058 - aromatic hydrpcarbons manufactured from purchased
        refinery products
     •  SIC 2911632 - aliphatic hydrocarbons manufactured from purchased
        refinery products
     •  SIC 28914 - synthetic resin and rubber adhesives (including only those
        synthetic resins listed under both SIC 28914 and SIC 2821  that are
        polymerized for use or sale, by adhesive manufacturers)
     •  Chemicals and chemical preparations, not elsewhere  classified:
        -  SIC  2899568  - sizes, all types
        -  SIC  2899597  - other industrial chemical  specialties,^including
           fluxes,  plastic wood preparations, and embalming fluids
     •  SIC 2843085 - bulk surface active agents
     •  SIC 3079  -  miscellaneous  plastics products  (including only cellophane
        manufacture from  the  viscose  process).

 However,  for  the  reasons  discussed below,  the Agency has decided not  to  extend
 the applicability of  the  OCPSF regulation  to discharges from establishments
 that manufacture  OCPSF  products  and  have,  in the past,  reported such  produc-
 tion under these  non-OCPSF  SIC subgroups.

     As noted earlier,  the  SIC codes  are classifications  of commercial and
 industrial establishments by type of activity  in which they are engaged.   The
 predominant  purpose of  the  SIC  code  is to classify the manufacturing indus-
 tries  for the collection of economic data.   The product descriptions in SIC
 codes  are often technically ambiguous and also list products that are no
 longer produced in commercial quantities.   For this reason, the Agency pro-
 posed  to define the applicability of the OCPSF regulation in terms Of both SIC
 codes  and specific products and product groups (50 FR 29073, July 17/ 1985).
 Many chemical products.may appear under more than one SIC code depending on
                                     111-23

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 the manufacturing raw material sources, use  in  the next stiage of  the manufac-
 turing process, or type of sale or end use.  For example, phenolic, urea, and
 acrylic resin manufacture may be reported under SIC 28914, synthetic resin
 adhesives, as well as under SIC 2821, plastics materials and resins.  Benzene,
 toluene, and xylene manufacture may be reported under SIC 2911, petroleum
 refining, or under SIC 2911058, aromatics, made from purchased refinery pro-
 ducts, as well as SIC 2865, cyclic crudes and intermediates.  Likewise, alkyl-
 benzene sulfonic acids and salts manufacture may be reported under SIC
 2843085, bulk surface active agents, which include all amphoteric, anionic,
 cationic, and nonionic bulk surface active agents excluding surface active
 agents produced or purchased and sold as active incredients in formulated
 products, as well as SIC 286,  industrial'organic chemicals.

      Many commenters stated that the Agency's OCPSF technical and economic
 studies do not contain sufficient information to extend coverage to all
 facilities reporting OCPSF manufacturing under all of the above SIC subgroups.
 The Agency agrees in part  with these commenters.   The OCPSF  technical,  cost,
 and economic impact, data-gathering efforts focused only on those primary and
 secondary manufacturers  that  report OCPSF manufacturing activities under SIC
 codes  2821,  2823, -2824,  2865,  and 2869.   Specific  efforts  were  not directed
 toward gathering technical and financial  data from facilities that report
 OCPSF  manufacturing  under  SIC  subgroups 2911058, 2911632,  28914,  2843085,
 2899568,  2899597, and  3079.  As  a result,  EPA lacks cost and  economic  informa-
 tion from a  significant  number of plants  that report  OCPSF manufacturing
 activities to  the Bureau of the  Census under  these  latter  SIC subgroups.   Con-
 sequently, the applicability section of the final  regulation  (§414.11)  clari-
 fies that  the OCPSF regulation does not apply to a plant's OCPSF production
 that has been reported by  the  plant in the past under SIC groups 2911058,
 2911632, 28914,  2843085, 2899568, 2899597, and 3079.

     Approximately 140 of  the 940 OCPSF plants that provide the technical
 basis  for the final regulation reported parts of their OCPSF  production under
 SIC codes 2911058, 2911632, 28914, 2843085, 2899568, and 2899597, as well as
 SIC codes 2821, 2823, 2824,,2865, and 2869.  As a result of the definition of
applicability, a smaller portion of plant production than was reported as
OCPSF production for these plants is covered by the final regulation.
                                    111-24

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     The Agency does note, however,  that  theOCPSF,manufacturing  processes  are
essentially  identical  regardless  of  how manufacturing  facilities  may  report
OCPSF production  to  the  Bureau  of the  Census.   Therefore,  the  OCPSF  technical
.data base  and  effluent limitations and standards  provide permit  issuing
authorities  with  technical guidance  for establishing "Best Professional Judg-
ment" (BPJ)  permits  for  OGPSF production  activities  to which this regulation
does not apply.

     Some  of the  nbn-OCPSF  SIC  subgroups  were  the subject of prior EPA deci-
sions not  to establish national regulations for priority pollutants under the
 terms of  Paragraph 8 of  the Settlement Agreement.  Such action was taken for
adhesive  and sealant manufacturing (SIC 2891), as well as plastics molding and
 forming (SIC 3079),  paint and ink formulation and printing (which industries
were within SIC 2851,  2893,  2711, ,2721,  2731 and 10 other SIC 27 groups) and
 soap and  detergent manufacturing  (SIC 2841).  However, it should be noted  that
 in specific instances where a plant in these categories has OCPSF production
 activities, toxic pollutants may  be present in the discharge in amounts that
 warrant BPJ regulatory control.   Moreover, the adhesives and sealants, plas-
 tics molding and forming, and paint and ink formulation and printing Paragraph
 8 exclusions do not include process wastewatier from the secondary manufacture
 of synthetic resins.  Similarly,  the  soaps and detergents Paragraph 8  exclu-
 sion does not include process wastewater from  the manufacture of surface
 active agents (SIC 2843).  In  these cases, and even in  cases where priority
 pollutants  from OCPSF production covered by other categorical standards  (e.g.,
 petroleum refining and  Pharmaceuticals) have  been excluded  from  those  regula-
 tions under the  terms of Paragraph  8  of  the Settlement  Agreement, BPJ  priority
 pollutant regulation  for individual plants having OCPSF production may be
 appropriate.

      3.   Raw  Materials  and Product  Processes

         a.  Raw  Materials
      Synthetic organic  chemicals are  derivatives of naturally occurring mater-
  ials  (petroleum,  natural gas,  and coal)  that  have undergone at  least one chem-
  ical reaction.   Given the  large number  of potential starting materials and
                                      111-25

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  chemical reactions available to the industry,  many thousands of organic chemi-
  cals are produced by a potentially large number of basic processes having many
  variations.   Similar considerations also apply to the plastics and synthetic
  fibers  industry,  although both the number of starting materials and processes
  are  more limited.   Both organic chemicals and  plastics are commercially pro-
  duced from six  major raw material  classifications:   methane,  ethane,  propene,
  butanes/butenes,  and higher  aliphatic  and aromatic  compounds.   This list  can
  be expanded  to  eight by further defining the aromatic compounds to include
  benzene,  toluene,  and xylene.   These raw materials  are derived  from natural
  gas  and  petroleum,  although  a  small portion  of  the  aromatic compounds  is
  derived  from coal.

      Using these eight  basic raw materials (feedstocks) derived  from the
 petroleum refining  industry, process technologies used  by  the OCPSF industry
 lead to  the formation of a wide variety of products and intermediates, many of
 which are produced  from more than one basic raw material either as a primary
 reaction product or as a co-product.  Furthermore,  the reaction product of one
 process  is frequently used as the raw material  for a subsequent process.  The
 primary  products of the organic chemicals industry, for example, are the raw
 materials of  the plastics and synthetic fibers  industry.  Furthermore,  the
 reaction products of one process at a plant are frequently the reactants for
 other processes  at the same plant,  leading to the categorization of a chemical
 as a  product  in  one process and a reactant in another.  This ambiguity con-
 tinues until  the manufacture  of the ultimate  end product,  normally at the
 fabrication or consumer stage.   Many products/intermediates can be made from
 more  than one raw material.   Frequently,  there  are  alternate  processes by
 which a product  can be made from the same basic  raw  material.

      A second characteristic  of the  OCPSF industry that adds  to  the complexity
 of the industry  is  the high degree of integration  in manufacturing units.
Most  plants in this  industry  use several  of the  eight  basic raw  materials  '
derived from petroleum or natural gas- to  produce a single product.

     In addition, many plants do not use  the eight basic raw materials, but
rather use products produced at  other plants as   their raw materials.  Rela-
tively few manufacturing facilities are single product/process plants unless
                                    111-26

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the final product is near the fabrication or consumer product stage.   Any
attempt to define or subcategorize the industry on the basis of the 8 raw
materials would require the establishment of over 256 definitions or subcate-
gories.  Schematic diagrams illustrating some of these relationships are shown
in Section V of this document (see Figures V-l to V-16).

        b.  Process Chemistry
     Chemical and plastics manufacturing plants share an important  character-
istic:  chemical processes never  convert 100 percent o£ the  feedstocks  to  the
desired products, since  the chemical  reactions/processes never  proceed  to
total  completion.

     Moreover,  because there  is generally  a variety  of  reaction pathways
available to  reactants,  undesirable  by-products  are  often  generated.   This
produces  a mixture  of  unreacted raw  materials,  products, and by-products  that
must be  separated and  recovered by operations  that generate residues with
little or no  commercial value.  These losses  appear  in process wastewater, in
air emissions,  or directly as chemical wastes.   The  specific chemicals that
appear as losses are determined  by the feedstock and the process chemistry
 imposed  upon  it. The different  combinations  of products and production
 processes distinguish the wastewater characteristics of one plant from those
 of another.

      Manufacture of a chemical product necessarily consists of three steps:
 1) combination of reactants under suitable conditions to yield the desired
 product; 2) separation of the product from the reaction matrix (e.g.,  by-
 products, co-products, reaction  solvents); and 3) final purification and/or
 disposal of the wastewaters.   Pollutants arise from the  first step as a
 result of alternate reaction pathways; separation of reactants and products
 from  a reaction mixture  is imperfect and  both raw materials and  products  are
 typically  found in  process wastewaters.

       Although  there is  strong economic  incentive  to recover both raw materials
 and products,  there is  little incentive  to recover  the myriad of by-products
 formed  as  the  result  of alternate reaction pathways.   An  extremely wide
                                      111-27

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 variety of  compounds  can  form within  a given  process.  Typically,  chemical
 species do  not  react  via  a  single  reaction pathway; depending on  the nature of
 the reactive  intermediate,  there is a variety of pathways  that lead to a
 series of reaction products.   Often, and certainly the case for  reactions of
 industrial  significance,  one pathway  may be greatly favored over  all others,
 but never to  total exclusion.  The direction  of reactions  in a process
 sequence is controlled through careful adjustment and maintenance  of condi-
 tions in the  reaction vessel.  The physical condition of species  present
 (liquid, solid, or gaseous phase), conditions of temperature and pressure, the
 presence of solvents and  catalysts, and the configuration of process equipment
 dictate the kinetic pathway by which a particular reaction will proceed.

      Therefore, despite the differences between individual chemical production
 plants,  all transform one chemical to another by chemical reactions and physi-
 cal processes.  Although each transformation represents at least  one chemical
 reaction,  production of most of the industry's products can be described  by
 one or more of the 41 major generalized chemical reactions/processes listed in
 Table III-8.  Subjecting the basic feedstocks to sequences of these 41  generic
 processes  produces most commercial organic  chemicals and  plastics.

      Pollutant formation is  dependent  upon  both  the raw material  and process
 chemistry,  and broad  generalizations  regarding raw wastewater loads based
 solely on  process  chemistry  are difficult at  best.   Additionally,  OCPSF manu-
 facturing  processes  typically employ unique combinations of the major generic
 processes  shown  in Table III-8  to produce organic chemicals,  plastics, and
 synthetic  fibers that  tend to blur  any distinctions possible.

        c.   Product/Processes
     Each chemical product may be made by one  or more combinations  of raw
 feedstock and  generic process sequences.   Specification of the sequence of
 product synthesis  by identification of the product and the generic  process by
which it is produced is called a "product/process."  There are, however,
 thousands of product/processes within  the OCPSF industries.   Data  gathered on
 the nature and quantity of pollutants associated with the manufacture of
specific products within the organic chemicals and plastic/synthetic fibers
                                    111-28

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                          TABLE III-8.
       MAJOR GENERALIZED CHEMICAL REACTIONS AND PROCESSES
OF THE ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC FIBERS INDUSTRY
    Acid cleavage
    Alkoxylation
    Alkylation
    Amination
    Ammonolysis
    Ammoxidation
    Carbonylation
    Chlorohydrination
    Condensation
    Cracking
    Crystallization/Distillation
    Cyanation/Hydrocyanation
    Dehydration
    Dehydrogena t i on
    Denydrohalogenati on
    Distillation
    Electrohydrodimerization
    Epoxidation
    Esterification
    Etherification
    Extractive distillation
    Extraction
Fiber production
Halogenation
Hydration
Hydroacetylation
Hydrodealkylat ion
Hydrogenation
Hydrohalogenat ion
Hydrolysis
Isomerizatio.n
Neutralization
Nitration
Oxidation
Oxyhalogena t i on
Oxymation
Peroxidation
Phosgenation
Polymerization
Pyrolysis
Sulfonation
                               111-29

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  industries have been indexed for 176 product/processes.
  cussed in Section V of this document.
These data are dis-
       Organic chemical plants vary greatly as to the number of products manu-
  factured and processes employed,  and may be either vertically or horizontally
  integrated.   One representative plant,  which is both vertically and horizon-
  tally integrated,  may produce a total of 45 high-volume products with an
  additional 300 lower-volume products.   In contrast,  a specialty chemicals
  plant may produce  a total of 1,000 different products with 70 to 100 of these
  being produced on  any given day.

       On  the  other  hand,  specialty  chemicals may involve several chemical
  reactions  and  require a  more detailed description.   For example,  preparation
  of toluene diisocyanate  involves three  synthesis steps  —  nitration,  hydro-
 genation,  and  phosgenation.   This  example,  in fact,  is  relatively simple;
 manufacture of other  specialty chemicals  is more complex.  Thus, as  individual
 chemicals  become further removed from the feedstock of  the industry, more
 processes are required to produce  them.

      In contrast to organic chemicals, plastics and synthetic fibers are
 polymeric products.  Their manufacture directly utilizes only a small subset
 of either the chemicals manufactured or processes used within the OCPSF indus-
 try.   Such products are manufactured by polymerization processes in which
 organic chemicals (monomers) react  to form macromolecules or polymers, com-
 posed of thousands  of monomer units.  Reaction conditions are designed to
 drive the polymerization as far to  completion as practical and to recover
 unreacted monomer.

      Unless a solvent  is  used in  the polymerization,  by-products of  polymeric
 product manufacturers  are usually restricted to  the monomer(s)  or to  oliomers
 (a polymer  consisting  of  only a few monomer  units).   Because  the mild reaction
 conditions  generate few by-products,  there is economic  incentive to recover
 the monomer(s)  and  oliomers  for recycle;  the principal yield  loss  is  typically
scrap  polymer.  Thus,  smaller  amounts of  fewer organic chemical  co-products
 (pollutants) are generated by  the production of  polymeric plastics and syn-
thetic fibers than  are generated by  the manufacture of the monomers and other
organic chemicals.
                                    111-30

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     For the purposes of characterizing the OCPSF industry in this section,
the manufacturing facilities are assigned to one of the following three groups
based on SIC codes reported in the 1983 Section 308 Questionnaire.
          Plant Group
         Organics Plants
         Plastics Plants
         Organics and Plastics
           Plants (Mixed)
Associated SIC Codes Reported
     2865, 2869
     2821, 2823, 2824
     One or more from each of
       the two groups above
        d.  Industry Structure by Product/Process
     A portion of  the branched product structure of  the OCPSF  industry  is
illustrated in Figures V-l  to V-16  of Section V, which include key  OCPSF pro-
ducts and organic  priority  pollutants.  The  total  product  line of the industry
is  considerably more complex, but Figures  V-l to V-16 illustrate  the ability
of  the organic chemicals  industry to produce a  product by  different synthesis
routes.  For  each  of the  products that are produced  in excess  of  1,000  pounds
per year  (approximately 1,500  to 2,500 products),  there  is an  average of  two
synthetic routes.   The more than 20,000  compounds  that are produced in  smaller
quantities  by the  industry  tend  to  be more complex molecules that can be  syn-
.thesized  by multiple routes.   Because many products  are  often  produced  by  more
 than one  manufacturer, using the same or different synthetic routes,  few
 plants  have exactly the  same product/process combinations  as other  plants.

      An important  characteristic of the  OCPSF industry  is  the degree  of verti-
 cal integration among  manufacturing units at individual  plants..  Since  a
 majority of the basic  raw materials is  derived from petroleum or natural gas,
 many of the commodity  organic chemical  manufacturing plants are either part of
 or contiguous to petroleum refineries;  most of these plants have .the flexi-
 bility to produce a wide variety of products.

      Relatively few organic chemical manufacturing facilities.are  single
 product/process plants,  unless  the final  product  is near  the  fabrication or
 consumer product  stage.
                                     111-31

-------
      Additionally,  many  process  units  are  integrated  in  such a way  that  pro-
 duction levels  of related  products  can be  varied as desired over wide  ranges.
 There can be a  wide variation  in the size  (production capacity) of  the manu-
 facturing complex,  as well as  diversity of product/processes.  In addition to
 variations based on the  design capacity and design product mix, economic and
 market conditions of both  the  products  and raw materials can greatly influence
 the production  rate and  the processes  that are employed even on a relatively
 short-term basis.

      4.   Geographic Distribution
      Plant distribution by state is presented in Table III-9.   Most organic
 chemical plants are located in coastal regions or on waterways near either
 sources  of raw materials (especially petrochemicals) or transportation
 centers.   Plastics and synthetic fibers plants are generally located near
 organic  chemicals plants to minimize costs of monomer feedstock transporta-
 tion.  However,  a significant number of plastics plants  are situated near
 product  markets  (i.e.,  large population centers) to minimize costs  of trans-
 porting  the  products to market.

     5.  Plant Age
     The ages of plants  within  the OCPSF industry are  difficult  to  define,
 since  the  plants are generally  made up  of  more than one  process unit, each
 designed to  produce  different products.  As the  industry  introduces  new pro-
 ducts and  product  demand  grows, process units  are added  to  a plant.   It is  not
 clear which  process  should  be chosen to define plant age.   Typically, the
 oldest process in  current operation  is  used to define  plant age.  Information
 concerning plant age was  requested  in the  1983 "308" Questionnaire.

     Respondents were asked to  report the year plant operation began and the
year the oldest  OCPSF process line still operating went into operation.  Table
111-10 presents  the  plant distribution  of the  age of the oldest OCPSF process
line still operating.   Table 111-10 indicates that a  few plants are currently
operating processes  that are over 100 years old.   However, over two-thirds of
the plants began operating  the  oldest process within the past 35 years.   In
addition,  the startup of new plants has been declining since the early 1970's.
                                    111-32

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                               TABLE III-9.
                        PLANT DISTRIBUTION BY STATE
State*
AL
AR
CA
CO
CT
DE
FL
GA
TA
IL
IN
KS
KY
LA
MA
MD
MI
MN
MO
MS
MT
NC
NE
NH
NJ
NY
OH
OK
OR
PA
PR
RI
SC
TN
TX
UT
VA
WA
WI
WV
Total
Organ! cs
Plants
14
4
19
2
6
5
2
7
2
16
7
3
7
27
4
4
9
1
8
4
_
13
1
2
70
23
27
_
1
22
_
4
17
8
57
2
7
3
4
13
425
Plastics
Plants
4
2 ;
40 ,
1
8 ,
2 '
6
9
4
24
3
_
9
12
13
5
8 :
1
6
5
_
18 !
—
2
23
15 •
30
2
5
13
1
2
12
6
20;
— . -
15
4
5
3
338
Organ! cs and
Plastics Plants
5
2
4
-
2
2
3
2
.
15
2
1
5
8
3
1
4
1
1
3
1
10
1 ' ; -" " "
-
16
5
12
'
4
8
1
3
8
4
29
.-......-
2
1
3
6
177
Total
23
8
63
3
16
9
11
18
6
55
12
4
21
47
20
10
21
3
15
12
1
41
1
4
109
43
69
2
10
43
2
9
37
18
106
... 2 •
24
8
12
22
940
*0nly states that contain at least one facility are listed.

Source:  EPA CWA Section 308 Survey, October 1983.
                                    111-33

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                                 TABLE 111-10.
                    DISTRIBUTION OF PLANTS BY AGE OF OLDEST
                    OCPSF PROCESS  STILL OPERATING AS OF 1984
Plant Age
1-5
6-10
11-15
16-20
21-25
26-30
31-35
36-40
41-50
51-60
61-70
71-80
81-90
91-100
101-120
>120
Data not
Available
Total
Organ! cs
Plants
24
37
40
55
44
50
42
24
30
23
28
16
3
3
5
-

1
425
Plastics
Plants
14
29
41
54
46
41
24
17
23
19
16
4
5
1
1
-

3
338
Organics and
Plastics Plants
2
2
20
17
19
28
20
21
16
8
10
5
4
3

1*

1
177
Total
40
68
101
126
109
119
86
62
69
50
54
25
12
7
6
1*

5
940
 *Note:  The one plant whose age is >120 is 137 years old.

Source:  EPA CffA Section 308 Survey, 1983.
                                   111-34

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     This major decline in startup of combined organics and plastics plants in
the past 10 years may indicate a trend toward construction of plants that
produce fewer products or many specialty products geared toward specific mar-
kets, since the combined plants tend to be the larger, multi-product, verti-
cally integrated plants.

     6.  Plant Size
     Although plant size may be defined in many ways, including number of
employees, number of product/processes, plant capacity, production volume, and
sales volume, none of these factors alone is sufficient to define plant size;
each is discussed in this subsection.
        t,
        a.  Number of Employees
     Perhaps  the most obvious definition of plant  size would  be  the  number of
workers employed.  However, continuous process plants producing  high-volume
commodity  chemicals  typically employ  fewer workers per unit of production  than
do  plants  producing  specialty (relatively low-volume) chemicals.  Table III-ll
presents  the  plant distribution by the average number of  employees  engaged in
OCPSF  operations during 1982.  These  data were obtained from  the 1983  Section
308 Questionnaire.

         b. Number of  Product/Processes
      Plant size may  also be expressed in terms of  the number  of  product/
processes that are operated at  a  plant.   Analysis  of the  number  of  product/
processes for 546  primary producers in the  edited  1983  Section 308  Question-
naire data base is presented in Table 111-12.  The table  generally  includes
only direct and indirect discharge facilities whose total plant  production is
greater than 50 percent OCPSF products.   Detailed  product/process information
was not collected  from zero discharge or secondary OCPSF.  manufacturing
 facilities.

      The data presented in Table 111-12 may understate the number of distinct
 product/processes  because plants were requested to group certain products that
 were listed in the questionnaire instructions or  that individually constituted
 less than 1 percent of the total plant production.  For example, many dye
                                     111-35

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                                 TABLE III-ll.
                   PLANT DISTRIBUTION BY NUMBER OF EMPLOYEES
Number of
Employees
1-105
11-20
21-30
31-40
41-50
51-100
101-200
201-500
501-1000
1001-2000
2001-5000
>5000
Data not
Available
Total
Organ! cs
Plants
70
55
41
39
34
64
53
36
7
5
—
-

11
425
Plastics
Plants
73
58
32
26
23
45
27
23
9
9
7
-

6
338
Organics and
Plastics Plants
19
16
11
10
4
21
14
30
19
17
8
*1

7
177
Total
162
i±\J £r
129
•L £* s
94
x^
75
/ -*•
61
\J -L
no
JL.+J\J
94
^*T
RQ
o y
OK
*J-^
Tl
J a.
15
*1

24
940
*Note:  The only plasnt with >5,000 employees hasd 11,262 employees,

 Source:  EPA OTA Section 308 Survey, 1983.
                                   111-36

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                               TABLE  111-12.
            PLANT DISTRIBUTION BY NUMBER  OF  PRODUCT/PROCESSES AND
             PRODUCT GROUPS FOR PRIMARY PRODUCERS THAT ARE ALSO
                     DIRECT  AND/OR  INDIRECT  DISCHARGERS*
Number of
Product/Processes
1
2
3
4
5
6
7
8
9
10
11-12
13-15
16-20
21-30
31-40
41-50
Total
Organics
Plants
41
23
30
24
15
34
18
11
6
16
12
9
4
7
_
-
250
Plastics
Plants
72
30
27
17
8
10
6
2
2
_
1
-
-
-
-

175
Organics and
Plastics Plants

5
15
16
13
11
13
-
3
5
13
6
7
12
1
1 (50)
121
Total
113
58
72
57
36
55
37
13
11
21
26
15
11
19
1
1
546
*Table consists of plants that completed Part B of the 1983 Section 308
 Questionnaire.
                                     111-37

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 plants reported  individual  dye  products, while others  reported  types  of  dyes
 such as Azo- or  Vat-dyes  as one product.  A  review of  Table 111-12  shows that:
 plastics plants  tend  to have  fewer product/processes with 88 percent  reporting
 5 or fewer; organics  plants have a wider range of number of product/processes
 with 87 percent  reporting 10  or fewer; and that plants manufacturing  both
 organics and plastics, although fewer in number, tend  to have more  product/
 processes with 88 percent reporting 20 or fewer.

         c.  Plant Capacity  and  Production Volume
      For the purposes of  this report, plant size cannot be sufficiently de-
 fined based on design capacity due to the often broad differences between a
 plant's design capacity or  rate and its average production rate per year.
 Plants continuously producing high-volume chemicals (generally employing
 relatively few workers),  may be physically smaller than plants producing
 lower-volume specialty chemicals by batch processes.   Table 111-13 presents
 the distribution of plant OCPSF production and total  production for the year
 1982 with  plants sorted by their primary SIC code.  The rates  given are total
 (all products)  production for  the plant,  not  just  the product  SIC group under
 which they are  listed. All  data are  from the 1983  Section  308  Questionnaire.
 Additional production  information is  available in  the Economic  Impact  Analysis
 Report.  Even  though the  table includes  38  plants  that  have  been determined to
 be  non-scope facilities,  the general  trends  reflected in  the table should
 apply  to the final  list of 940 scope  facilities.

        d.   Plant Sales Volume
     Sales volume alone is not necessarily an accurate  indicator of  plant
 size.  High-volume  commodity chemicals are typically  less expensive  than
 specialty chemicals.   However, sales volume or production volume in  terms 6f
 dollars is very useful in  describing plant size in economic terms.   This
 definition of size has been  used in the economic analysis for this OCPSF  rule.
Table 111-14 presents  the  distribution of plants by OCPSF total  1982 sales
value with plants sorted by  their major SIC code.  These 1983 Section  308  "
Questionnaire data are presented  in the same  format as production volumes
above.  Additional sales data  are available in the Economic Impact Analysis
Report.  Like Table 111-13,  Table 111-14 includes 38 facilities  that have been
determined to be non-scope facilities.
                                    111-38

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                               TABLE 111-13.
     DISTRIBUTION OF  1982 PLANT  PRODUCTION QUANTITY  BY OCPSF  SIC  GROUP
No SIC
No. of
Plants
OCPSF Production
(Million Ibs.)
No data
0-.2
.2-1
1-2
2-10
10-20
20--100
100 Plus
All
Total Production
(Million Ibs.)
No .data
0-.2
.2-1
1-2
2-10 ,
10-20
20-100
100 Plus
All " '
39
-
-
-
-
-
-
-
39
12
2
2
1
12
5
3
2
39
2821
No. of
Plants
3
10
22
18
67
60
120
83
383
3
6
12
12
40
50
151
109
383
2823 2824
No. of No. of
Plants Plants
2
-
. -_ . ' 1
-
1 6
2
1 12
4 '18
.6 41
2
-
_ i
. • -
1 6
2
1 11
4 19
6 41
2865
No. of
Plants

6
17
5
25
10
14
34
111

3
14'
7
23
11
14
39
111
2869
No. of
Plants
3
29
22
19
75
37
109
104
398
3
22
12
11
65
33
107
145
398
All
No. of
Plants
47
45
62
42
174
109
256
243
9781
20
33
41
31
147
101
287
318
9781
All
Percent
4.8
4.6
6.3
4.3
17.8
11.1
26.2
24.8
100.0
2.0
3.4
4.2
3.2
15.0
10.3
29.3
32.5
100.0
1Includes 38 plants that have been determined to be lion-scope facilities.

 Source:  OCPSF Economic Impact Analysis.
                                    111-39

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                                TABLE 111-14.
          DISTRIBUTION OF 1982 PLANT SALES VALUE BY OCPSF SIC GROUP
No SIC
No. of
Plants
OCPSF Production
(Million $)
No data 39
0-1
1-5
5-10
10-50
50-100
100-500
500 Plus
All 39
Total Sales
Value (Million $)
No data 13
0-1 2
1-5 9
5-10 3
10-50 9
50-100 2
100-500 1
500 Plus
All 39
2821
No. of
Plants

11
34
76
61
128
33
38
r*
" 2
383

5
15
32
56
157
58
50
10
383
2823 2824 2865
No. of No. of No. of
Plants Plants Plants

2
-
2
1 3
1 8
5
4 20
_ -^
6 41 ,

2
-
1
1 3
1 9
5
4 20
1
6 41

-
5
23
11
45
10
17
-
Ill

-
5
15
13
47
13
18
-
Ill
2869
No. of
Plants

8
39
56
47
132
43
57
16
398

6
26
45
33
143
46
82
17
398
All
No. of
Plants

60
78
157
123
314
91
136
19
9781

26.
48
102
109
366
124
175
28
9781
All
Percent

6.1
8.0
16.1
• 12.6
32.1
9.3
13.9
1.9
100.0

2.6
4.9
10.4
11.1
37.4
12.7
17.9
2.9
100.0
Includes 38 plants that have been determined to

Source:  OCPSF Economic Impact Analysis.
be non-scope facilities.
                                   111-40

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7.  Mode of Discharge
     There are three basic discharge modes utilized by the industry:  direct,
indirect, and zero or alternative disposal/discharge.  Direct dischargers are
plants that produce a contaminated process wastewater, treated or untreated,
that is discharged directly into a surface water.  Plants that produce only
noneontact cooling water and/or sanitary sewage effluents (non-process waste-
water) are not considered to be direct dischargers of OCPSF process wastewater
for purposes of this report.  Indirect dischargers are plants that .route their
OCPSF process wastewater effluents to POTWs.  Zero or alternative disposal/
dischargers are plants that discharge no OCPSF process wastewater to surface '
streams or to POTWs.  For the purposes of this report, these include plants
that generate no process wastewaters, plants  that recycle all contaminated
waters, and plants that use some kind of alternative disposal technology
(e.g., deep well injection, incineration, contractor • removal, etc).

     The discharge of process wastewaters into the system of an  adjoining
manufacturing facility or to* a  treatment system not owned by a government
entity is not considered indirect discharge,  but  is termed off-site  treatment
and is considered an alternative disposal method.  Table 111-15  shows  the
plant distribution based on mode of  discharge.  The table also shows  the
distribution between primary producers  (i.e., plants 'whose OCPSF production
exceeds  50 percent of the plant total)  and  secondary producers.

     Fifteen plants discharge  treated and/or  untreated wastewater both di-
rectly and indirectly.  In general,  these plants  discharge high-strength or
"difficult to treat" wastewater to POTWs and  direct discharge more  easily
treated  low-strength wastewater.
    *                                '                       ;
C.   DATA BASE DESCRIPTION
    %r       •'        •
    ~1.   1983 Section 308 Questionnaire Data  Base
     "•In  the  preamble  to  the  March  21,  1983  proposed  regulation,  the Agency
recognized  the  need  to gather  additional data to ensure  that  the final regula--
 tion is  based upon information that  represents  the  entire  industry  and to
assess wastewater treatment  installed  since 1977.  Therefore,  the Agency
                                     111-41-

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                                  TABLE 111-15.
                                MODE  OF DISCHARGE
Direct
Primary Producers
Organics Plants 96
Plastics Plants 72
Organics & Plastics
Plants 70
Total Primary
Producers 238
Secondary Producers
and/or Zero Dischargers
Organics Plants 30
Plastics Plants 13
Organics & Plastics
Plants 8
Total Secondary
Producers/Zero
Dischargers 51
Total All Plants 289
Indirect

146
96
45
287
48
41
17
106
393
Direct and
Indirect

5
2
5
12
1
1
1
3
15
Zero Unknown

3
5
1
9
92 4
104 4
29 1
225 9
234 9
Total

250
175
121
546
175
163
56
393
940,
Source:  EPA OTA Section 308 Survey, 1983.
                                    111-42

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conducted an extensive data-gathering program to improve the coverage of all
types of OCPSF manufacturers.  A comprehensive Clean Water Act Section 308
Questionnaire was developed and distributed in 1983.  The mailing list was
compiled from the following references that identify manufacturers of OCPSF
products:

     •  Economic Information Service
     •  SRI Directory of Chemical Manufacturers
     •  Dun and Bradstreet Middle Market Directory
     •  Moody's Industrial Manual
     «  Standard and Poor's Index
     •  Thomas Register
     •  Red Book of Plastics Manufacturers
     •  1976 and 1977 308 Questionnaire Data Bases
     •  Plastics Manufacturers Telephone Survey of  301  Plants.

     In October 1983, the Agency sent  a General Questionnaire  to  2,840  facili-
 ties and corporate headquarters  to  obtain  information regarding individual
 plant characteristics, wastewater treatment efficiency,  and the statutory
 factors expected  to vary  from  plant to plant.  The  General  Questionnnaire
 consisted  of  three parts:   Part  I (General Profile), Part II (Detailed  Produc-
 tion Information), and Part III  (Wastewater Treatment Technology, Disposal
 Techniques, and Analytical  Data  Summaries).

     Some  plants  that received the  Section 308 Questionnaire had  OCPSF
 operations that were  a minor portion of  their principal production activities
 and related wastewater streams.   The data collected from these  facilities
 allow  the  Agency  to  characterize properly the impacts  of ancillary (secondary)
 OCPSF  production.  Generally,  if a  plant's 1982 OCPSF  production  was less than
 50 percent of the total  facility production  (secondary manufacturer), then
 only Part  I of the questionnaire was completed.

      Part  I identified  the plant,  determined whether the plant conducted
 activities relevant  to  the survey,  and solicited general data (plant age,
 ownership, operating status, permit numbers,  etc.).  General OCPSF and non-
 OCPSF production and flow information was collected for all plant manufactur-
 ing activities.   This part also requested economic information,   including data
                                     111-43

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 on shipments and sales by product groups, as well as data on plant employment
 and capital expenditures.

      Part I determined whether a respondent needed to complete Parts II and
 III  (i.e., whether the plant is a primary or secondary producer of OCPSF pro-
 ducts,  whether the plant discharges wastewater, and for secondary producers,
 whether the plant segregates OCPSF process wastewaters).   For those plants
 returning only the General Profile, Part I identified the amounts of process
 wastewater generated,  in-place wastewater treatment technologies, wastewater
 characteristics,  and disposal techniques.

      Part II requested detailed 1980 production information for 249 specific
 OCPSF products,  99 specific OCPSF product groups,  and OCPSF products that
 constituted more  than  1 percent of total plant production.   Less detailed
 information was  requested for the facility's remaining OCPSF and non-OCPSF
 production.   Part II also requested information on the use  or known presence
 of  the  priority pollutants for each OCPSF product/process or product group.
 Part  III  requested detailed information  on plant wastewater sources and flows,
 technology installed,  treatment system performance,  and disposal techniques.

      Responses to economic and sales  items in  Part I  pertained  to calendar
 year  1982,  which  were  readily available,  since the plants were  required to
 submit  detailed 1982 information to the  Bureau of  the  Census.   This reduced
 the paperwork burden for  responding plants.

      The  remainder  of  the  Section  308  Questionnaire, however, requested data
 for 1980,  a more  representative  production year.   The Agency  believed that
 treatment  performance  in  1982  would be unrepresentative of  treatment during
more  typical  production periods.  This is  because  decreased production  nori
mally results in  decreased wastewater generation.  With lower volumes of
wastewater being  treated, plants in the  industry might be achieving levels'of
effluent quality  that  they could not attain during periods of higher produc-
tion.   The year 1980 was selected in consultation with industry as  representa-
tive of operations during more normal production periods,  but recent enough to
identify most new treatment installed by the industry since 1977.  The  indus-
try representatives did not assert that significant new treatment had been
installed since 1980.
                                    111-44

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     The Section 308 Questionnaires were designed to be encoded into a
computer data base directly from the questionnaires.  To ensure that the ques-
tionnaires were filled out completely and correctly a copy of each question-
naire was reviewed by engineers.  Due to the diversity and complexity of the
OCPSF industry, a number of problems were encountered in reviewing the ques-
tionnaires.  Some of the problems encountered included incorrect units of
measure, incomplete responses, misinterpretation of data requested, conflict-
ing data, for different questions, pooling of data for separate questions, ,and
unusual circumstances at the plant.

     Solutions to these problem included recalculation of the data, followup
contacts for clarification, or in some cases rejection of the data.  Some of
these, problems may be explained in part by  the fact that some companies simply
did not keep records of the information that was requested by the question-
naire, and consequently could not respond fully on all items of interest.

     The data were encoded onto computer .tapes from the corrected copies of
the.questionnaires.  Each questionnaire was double entered by separate  indi-
viduals to help eliminate keypunch errors.  The data were then sorted into
separate computer files for each question.

    - The data  in each question-file were  then verified by various means.
Verification methods included but were not  limited  to:  visual inspection of
the file printout, checks for missing data, checks  for conflicting  data,  and
checks  for unusually high or  low values.  In addition, many  of the  engineering
analyses required a more detailed review  of the data, plus  the execution  of
the analyses often exposed  faulty data  through erroneous results or the in-
ability of a program to run.  Wherever  suspect data were identified, .they were
referred  to  the  review engineers who  then took appropriate  action  to  resolve  .
the problem.   The economic  study assessments also  determined that  some  plants
that  responded as a scope  facility  should be considered non-scope.  A separate
data  file  called  the Master Analysis  File has been created, from  the 308
Questionnaire  data.   This  data file  contains only data  that are  useful in, the
engineering  analyses and  are  used  for that  purpose.
                                   i  111-45

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       The Section 308 Questionnaires were mailed in October 1983.  In February
 1984, Section 308 followup letters were sent to 914 nonrespondents.  A total
 of 940 questionnaire responses provide the basis for the final technical and
.economic studies.  A total of 1,574 responses were from facilities that were
 determined to be outside of the scope of the final regulations (e.g., sales
 offices, warehouses, chemical formulators, non-scope production, etc.); 166
 were returned by the Post Office; and 160 did not respond.   A followup
 telephone survey of 52 randomly selected nonrespondents concluded that over 90
 percent of the nonrespondents were not manufacturers of OCPSF products.

      In addition, a Supplemental Questionnaire was sent to  84 facilities known
 to have installed selected wastewater treatment unit operations.    Detailed
 design and cost information was requested for four major treatment components
 commonly used to treat OCPSF wastewaters  (i.e.,  biological  treatment, steam
 stripping,  solvent extraction,  and granular activated  carbon)  and summary
 design and cost information for other wastewater and sludge treatment compon-
 ents.   The questionnaires also  collected  available treatment  system perform-
 ance  data for in-plant  wastewater control  or  treatment  unit operations,  in-
 fluent to the main wastewater  treatment system,  intermediate waste stream
 sampling locations,  and  final effluent from the  main wastewater  treatment
 system.   Unlike the  General Questionnaire,  it asked  for individual daily  data
 rather than summary  data.   After  a followup effort 64 plants responded with
useful data and  information.

     2.   Daily Data  Base  Development
     One  of the  major purposes of  this study is  the development of  long-term
daily  pollutant  data.  These data  are required to derive variability  factors
that characterize wastewater treatment performance and  provide the basis for
derivation of proposed effluent limitations guidelines  and  standards.  Hun-
dreds of  thousands of data points  have been collected,   analyzed, and entered
into the  computer.

     The  first effort at gathering daily data involved  the BPT and BAT mail-
ings in 1976 and 1977.  These questionnaires asked each plant for backup
information to support the long-term pollutant values reported.  Many plants
                                    111-46

-------
submitted influent and effluent daily observations convering the time period
of interest in the BPT questionnaire (January 1, 1976 to September 30, 1976).
Additionally, there were other conventional and nonconventional pollutant
daily data in the files from the period of verification sampling.  Some plants
also submitted additional data with their public comments for the 1983 pro-
posed requlations.  Additional data were collected through the supplemental
1983 Section 308 Supplemental Questionnaires.

     3.  BAT Data Base
     The BAT Data Base contains long- and short-term priority pollutant data
used in the development of effluent limits.  The data base consists primarily
of end-of-pipe wastewater treatment system influent and effluent data, but
also includes other types of samples.  These other samples, include individual
process streams* intermediate samples within the end-of-pipe system,  and  in-
fluent and effluent samples of individual treatment units, especially those
under consideration as BAT technology.

     Data sources include both EPA  sampling programs and data supplied by
OCPSF plants.  In all cases, the analytical data have been considered accept-
able for limitations development only if  the QA/QC procedures were documented
and in the case 'of organic pollutants the analyses were confirmed by  GC/MS or
known  to be  present based on process chemistry.  The major sources of data are
listed below:

     •  EPA  Screening Sampling Program  (1977 to 1979)
     •  EPA  Verification  Sampling  Program (1978 to  1980)
     •  EPA/CMA  Five-Plant  Study  (1980  to 1981)
     •  EPA  12-Plant  Sampling  Program  (1983  to 1984)
     •   Plant  Submissions Accompanying  Comments to  the  March 1983  Proposed
        Regulations
     •   Plant  Submissions Accompanying  Comments to  the  July and October 1985
         and  December  1986 Notices  of New Information
     •  Supplemental  Sections  to  the 1983 Section 308 Questionnaire.
                                     111-47

-------
     The data base designations used  throughout  this report are  listed  in
Table 111-16.  The four EPA sampling  programs are discussed in greater  detail
in Sections V and VII of this report.
                                   ±JL±-4

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                                TABLE 111-16.
                            DATA BASE DESIGNATION
Data Base File Name
     Description
308 Data Base
Data base containing all data
extracted from 1983 Section 308
Questionnaires
Master Analysis File (MAF)
Contains data excerpted from the
1983 Section 308 Data Base
(includes conventional pollutant
parameter long-term average data)
Daily Data Base
Contains long-term conventional
pollutant effluent daily data from
69 plants
BAT Data Base
Contains long- and short-term
treatment system influent and
effluent daily data for priority
pollutants
Master Process File  (MPF)
Contains priority pollutant raw
wastewater characterization data
for 176 OCPSF product/processes
                                     111-49

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                                  SECTION IV
                               SUBCATEGORIZATION

A.  INTRODUCTION
     Sections 304(b)(l)(B) and 304(b)(4)(B) of the Clean Water Act (CWA) re-
quire the U.S. Environmental Protection Agency (EPA) to assess certain factors
in establishing effluent limitations guidelines based on the best practicable
control technology (BPT) and best available technology economically achievable
(BAT).  These factors include  the age of equipment and facilities involved;
the manufacturing process employed; the engineering aspects of the application
of recommended control technologies,.including process changes and in-plant
controls; nonwater quality environmental impacts, including energy require-
ments; and such other factors  as deemed appropriate by the Administrator.

     To accommodate these factors, it may be necessary to divide a major
industry into a number of subcategories of plants sharing some common charac-
teristics.  This allows  the establishment of uniform national effluent limita-
tions guidelines and standards, while at the same time accounting for the
particular characteristics of  different groups of facilities.

     The factors considered for technical significance in the subcategoriza-
tion of  the Organic Chemicals  and Plastics and Synthetics Fibers (OCPSP) point
source categories include:

     •   Manufacturing product/processes
     «   Raw materials
     •   Wastewater characteristics
     •   Facility size
     •   Geographical location
     •   Age of  facility  and equipment
     •   Treatability
     •   Nonwater quality environmental  impacts
     •   Energy  requirements.
                                      IV-1

-------
      The impacts of  these factors have been evaluated  to determine  if sub-
 categorization is necessary or feasible.  These evaluations, which  are dis-
 cussed in detail in  the following sections, result in  the following final
 subcategories:

      o  BPT:  Rayon, other fibers, thermoplastic resins, thermosetting resins,
         commodity organics, bulk organics, and specialty organics
      o  BAT:  Subcategory One (end-of-pipe biological  treatment) and Subcate-
         gory Two (non-end-of-pipe biological treatment).
 B.  BACKGROUND

      In the March 21, 1983,  Federal Register,  EPA proposed a subcategorization
 approach for regulation of the OCPSF industry.   A Notice of Availability (NOA)
 appeared in the July 17,  1985, Federal Register,  which addressed a number of
 concerns raised by industry relating to the March 1983 proposal.  Another NOA
 appeared in the December  8,  1986,  Federal Register,  which presented an altern-
 ative subcategorization approach.   This section discusses the subcategoriza-
 tion methodologies for the proposal and the two NOAs  and presents the  concerns
 and  issues  raised during  the public comment periods  for each.

      1.  March 21,  1983 Proposal
      The March 21,  1983,  proposal  established four subcategories (Plastics
 Only,  Oxidation,  Type I,  and Other  Discharges)  for BPT  effluent  limitations,
 which were  based  on generic  chemical  reactions  such as  oxidation,  peroxida-
 tion,  acid  cleavage,  and  esterfication  and whether a  plant produced  plastics
 or organics.   This approach was found to  be  too cumbersome to implement be-
 cause  the process information  necessary to place a plant  in a subcategory was
 not readily available.  Also,  a major problem raised  by both industry and
 regulatory agencies in  public  comments on the proposal  was that  a plant could
 shift from one subcategory to  another simply by changing a single product/
 process.

     The March 21, 1983, proposal also established two  subcategories (Plastics
Only and Not Plastics Only) for BAT effluent limitations.  The rationale for
 this two-subcategory approach was that plants in the Plastics Only subcategory
 tended to have fewer toxic pollutants present and less significant levels than
                                     IV-2

-------
the remaining discharges, all of which result from the manufacture of at least
some organic chemicals which were contained in the Not Plastics,Only subcat-
egory.  The Agency also announced its intention to establish a separate BAT
subcategory with different zinc limitations for those plants manufacturing
rayon and utilizing the viscose process.

     After reviewing public comments and evaluating its proposed subcategori-
zation methodology, the Agency decided to revise its approach and developed
another subcategorization approach, which was published for public comment in
the July 17, 1985, Federal Register NOA.  This revised methodology is dis-
cussed in the following section.

      2.  July 17,  1985, Federal Register NOA            /
      The July 17,  1985, Federal Register NOA sought to correct some  of  the
difficulties described above by categorizing plants according to  the products
accounting for most of their production.  Under  this .subcategorization  strat-
egy,  every plant was  to  be  put  into a single categoric grouping.  The subeate-
gories in this approach were as follows!          ,   ,

      1.  Thermoplastics  Only (SIC 28213)        ,      .
      2.  Thermosets  (SIC 28214  plus Organics)
      3.  Rayon  (Viscose)
      4.  Other  Fibers (SIC  2824 and  2823  plus  Organics)
      5.  Thermoplastics  and Organics  (SIC 28213  and  2865  or 2869)
      6.  Commodity Organics
      7.  Bulk Organics                                           ,
      8.1 Specialty Organics.                                                  ,

      These  eight subcategories  were  defined as follows:

      •  Subcategories 1  and 3  were defined as facilities  that produced at
         least 95 percent thermoplastics and rayon, respectively.
      •  Subcategories 2  and 4 were for facilities whose production was at
         least 95 percent of the subcategory heading or facilities whose combi-
         nation of organic chemicals and the subcategory heading represented at
         least 95 percent of the plant production.
                                      IV-3

-------
      •  Subcategory 5 represented plants with a production that was at least
         95 percent thermoplastic and organic products with neither product
         group representing 95 percent production.  This group was interpreted
         to be vertically integrated plants producing organics, which were then
         used primarily for the production of thermoplastics.
      •  Subcategories 6 through 8 identified the relatively pure organics
         plants that had a production that was at least 95 percent organics.
         Organics production was further subdivided according to volume.
         -  Commodity:  Those chemicals produced nationally in amounts greater
            than or equal to 1 billion pounds per year.
         -  Bulk:  Those chemicals produced nationally in amounts less than 1
            billion but more than 40 million pounds per year.
         -  Specialty:  Those chemicals produced nationally in amounts less
            than or equal to 40 million pounds per year.

      Plants were assigned to these categories based on their mix of produc-
 tion;  plants having at least 75 percent commodity or specialty were assigned
 to  these respective subcategories.   Remaining plants were assigned to the bulk
 subcategory.   Thus,  a plant might be assigned to the bulk subcategory,  but it
 could  also  manufacture both commodity and specialty chemicals.

     The July 17,  1985,  Federal Register NOA also announced  the Agency's  in-
 tentions to establish a single set  of BAT effluent limitations  that  would be
 applicable  to all  OCPSF facilities  rather than  the two subcategory approach
 presented in  the March 21,  1983,  proposal.   The  rationale for  this "one BAT
 subcategory"  approach was  that the  available data for  BAT show  that  plants in
 differing BPT subcategories  can  achieve  similar  low toxic pollutant  effluent
 concentrations by  installing  the  best  available  treatment components.   The
 Agency also again  announced its  intention to establish a  separate  BAT subcate-
 gory with different zinc limitations  for  those plants manufacturing  rayon and
 utilizing the viscose  process.

     While  the subcategories developed for the July  17, 1985, Federal Register
NOA were more useful  than those established  for  the March  21, 1983, proposal,
 the revised subcategorization  approach was still criticized by OCPSF trade
associations and companies for the reasons summarized below.
                                     IV-4

-------
        a.  Multiple Subcategory Plants
     A significant number of the plants cannot be classified according to the
July 17, 1985, Federal Register NOA subcategorization approach for the follow-
ing reasons:

     •  No single subcategory accounts for the majority of the production at a
        number of plants.
     •  No allowance was made in the thermoplastics and organics subcategory
        for variations in the types of organic products produced.  From analy-
        sis of the data, plants with high specialty volume can be expected  to
        have  higher BOD5 effluent  concentrations when compared to plants with
        high  commodity production.
     •  Plants could change  their  subcategory classifications by making small
        changes  in  the proportion  of products produced.

        b.  Low  Flow/High Flow  Plants
     In the March 21,  1983,  Proposal,  the Agency incorporated a  low  flow/high
 flow cutoff in one  of  its proposed subcategories,  because flow was  found  to be
 a statistically  significant  subcategorization factor.   This  adjustment was not
 made in the July 17,  1985,  Federal Register NOA because flow was not found to
 be a statistically.significant  factor  for  the revised subcategorization
 approach.  However,  the Agency  received numerous public comments requesting
 that consideration be given to  plants  that conserve water and are low water,
 users.

      All the above considerations led the Agency to modify the July 17, 1985,
 subcategorization approach  to accommodate these issues while trying to pre-
 serve a workable subcategorization and guideline structure.

      3.  December 8, 1986,  Federal Register
      The Agency  again revised  its subcategorization methodology and presented
  it  in  the December 8, 1986, Federal Register NOA.  Initially, a regulatory
  approach that would have created  plant specific long-term averages  based  on a
  flow proportioning of individual  product subcategory long-term  averages was
  attempted.   This would  have eliminated a number of difficulties associated
  with multiple subcategory plants  and  was consistent  with current permit writ-
  ing "building block"  practices.
                                       IV-5

-------
      Production/flow information had been requested from industry in the 1983
 308 Questionnaire Survey in'anticipation of implementing such an approach.
 Unfortunately,  much of the production/flow information (when supplied) was
 either- estimated or grouped with other product/process flows and was con-
 sidered too inaccurate or nebulous for subcategorization purposes.   However,
 since relatively accurate production volume information by product/process  or
 product groups  was available,  a regulatory approach that proportions the vari-
 ous subcategory long-term averages for each plant based on the reported pro-
 portion of production by product group was developed.   This revised subcate-
 gorization approach incorporated essentially the same  product-based subcate-
 gories  as  presented in the July 17,  1985,  Federal Register NOA:

      1.  Thermoplastics  (SIC 28213)
      2.  Thermosets (SIC 28214)
      3.  Rayon  (Viscose  Process)
      4.  Other  Fibers  (SIC 2823  and  2824)
      5.  Commodity Organics (SIC  2865  and  2869)
      6.  Bulk Organics (SIC 2865  and 2869)
      7.  Specialty Organics (SIC  2865  and  2869).

While the  prior subcategorization approaches incorporated  subcategories  that
included both a major production  group and other  secondary  production,  these
seven subcategories represented only single production groups, while plants
that have  production that  falls into more  than one production group, were
handled by a regression model that emulates the production  proportioning used
by permit writers.  This regression model was as  follows:
           ln(BODA) =  a + Z wij-Tj + B- [ln(flowi )] + D-15.^ +
           where li^BODj), w  ,  ln(flow ), and 15  are plant-specific data
           available in the data base (for plant i), and the parameters a, T ,
           and D are values, estimated from the data base using standard     j
           statistical regression methods.  Definitions of the terms in this
           regression equation (and also used in subsequent equations) are as
           follows :
     ln(BODi)    = natural logarithm (In) of the 1980 annual arithmetic average
                  BOD  effluent  in mg/1, which has been adjusted for dilution
                  with uncontaminated miscellaneous wastewaters (as described
                  in Section VII),  for plant i.
                                     IV-6

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            )  = ln(total flow (MGD)), corrected for non-process waste
                 streams) for plant i, with associated coefficient B.
    15.         = indicator variable for plant i
               = 1, if plant i meets 95 percent BODg removal or at most 50
                 mg/1 BOD5 effluent editing criteria (95/50), for plants with
                 biological treatment and polishing ponds,
               =0, otherwise
    w          = proportion of OGPSF  1980 production from plant i from sub-
     13          category j
    e.         = statistical error  term associated with plant i

    The seven  subcategories, represented by  the subscript j, are  as  follows:
    j=l:  Thermoplastics
    j=2:  Thermosets
    j=3:  Rayon                                                .
    j=4:  Other Fibers                            ,
    j=5:  Commodity Organics
    j=6:  Bulk Organics
    j=7:   Specialty Organics.

    The coefficients T. and D are related to the intercept of this equation
(denoted by "a").  The T..  coefficients are subcategorical deviations from the.
                                        7
overall intercept "a.
The restriction E T.=0 is placed on the regression
               3=1 D
equation, as discussed in Appendix IV-A, to allow for estimation of these
values by standard multiple regression methods.  The coefficient D represents
the difference between the intercept of this equation (based on .all.full-
response, direct discharge OCPSF plants that have at least biological treat-
ment in place and have provided BOD5 effluent, subcategorical production, and
flow data) and the intercept based on the subset of these plants that have
biological treatment and polishing ponds and meet the 95/50 editing criteria
used by EPA at the time of the 1986 NOA.
                                      IV-7

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       In addition to its production proportioning approach,  the Agency also
  included a flow adjustment factor in its regression model in an attempt to
  respond to public comments criticizing its elimination in the July 17,  1985,
  subcategorization approach.   When included in the regression model and  tested
  statistically,  the flow adjustment coefficient,  B,  was found to be statistic-
  ally  significant in explaining plant-to-plant variation of  reported average
  BOD5  effluent.

       A  regression model relating  effluent  TSS to effluent BOD5  was also devel-
  oped  to calculate estimated TSS effluent long-term  averages  for individual
  plants,  as  follows:
=  a
                               b- [ln(BOD. )]
 where:
            ln(TSS..) = ln(1980 annual arithmetic average TSS effluent in mg/1,
                       which has been adjusted for dilution with uncontaminated
                       miscellaneous wastewaters, as described in Section VII),
                       for plant i
            e..  = statistical error term associated with plant i.
      The data base used to determine these long-term averages included all
 full-response,  direct discharge OCPSF plants with biological treatment and
 polishing ponds that met the 95/50 editing criteria for BOD5 described pre-
 viously and that had TSS effluent concentrations of at most 100 mg/1.   The
 variables ln(BOD±) [defined previously]  and ln(TSS.) are plant-specific data
 available in this data base,  and the intercept and slope parameters a  and  b,
 respectively, are values estimated from  the data base using standard statis-
 tical  regression methods.

     The  December 8,  1986,  Federal Register NOA  retained the "one BAT  subcate-
gory"  approach  along with  the separate subcategory and different zinc  limita-
 tions  for rayon manufacturers utilizing  the viscose  process.

     While  the  revised subcategorization approach  was  yet another improvement
on previous subcategorizations, a  number of  major  issues were raised during
the public comment period for the  December  8,  1986,  Federal Register NOA,
which are detailed below.
                                     IV-8

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     a.  Flow Adjustment Factor
     Many comments were received which stated that the flow adjustment factor
was not the equitable flow correction that the Agency intended, since it util-
ized total wastewater flow in its adjustment that would penalize high-
production facilities with high flows and plants with certain product/
processes that typically utilize and discharge large volumes of wastewater
(e.g., rayon and fibers plants).  Commenters suggested that the flow adjust-
ment factor be changed to account for production volume at each facility;
i.e.,  use a gallon of wastewater/pound production adjustment factor.

     A related issue raised  by  commenters also concerned  the flow  adjustment
factor:  a flow adjustment coefficient based on  the use of all OCPSF plants
with biological treatment, regardless of effluent BOD5,.. causes a small group.
of  plants exhibiting high effluent  BOD5 and low  wastewater flow  to dispropor-
tionately influence  the estimated  long-term averages  for  other plants, based
on  the regression  model.  The commenters  stated  that  if approximately  16
plants with  effluent BOD5 values greater  than  200 mg/1 were  removed from the
regression,  the  flow adjustment coefficient, B,  was  no longer  significant.

         b.   Total  Production
      Commenters  stated that  a total production factor should be  included in
 the regression model even though production was evaluated in the December 8,
 1986,  subcategorization approach and was found not to be significant.
 C.
FINAL ADOPTED BPT AND BAT SUBCATEGORIZATION METHODOLOGY AND RATIONALE
      Based on an assessment of the comments on the subcategorization method-
 ology presented in the December 8, 1986, Federal Register NOA, the Agency
 revised its regression model and  the methodology for using the model to estab-
 lish effluent BOD5 long-term averages.  The final revised regression model is
 as follows:
             ln(BOD.) =  a  +  I w   •T,  +  B-I4   +  C-Ib.  +  e.
                                       IV-9

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Ib
 where:

      1^ «   performance indicator variable for plant i

              J"A if ?lant i meets the 95 Percent BOD  removal or at most
              40 mg/1 BOD5 effluent editing criteria (the final BODC perform-
              ance editing criteria)                               5

          =   0, otherwise

              treatment indicator variable for plant i

              1, if plant i has only biological treatment

              0, if plant i has treatment in addition to biological treatment

      e.,^  = statistical error term associated with plant  i.


The  other terms have  been defined previously.


      The  values for a,  T^ ,  B  and C  are  regression  coefficients  that are  esti-

mated from  the  157 full-response, direct discharge OCPSF plants  that have at

least biological treatment  in place and  provided BOD5 effluent and subcategor-
ical  production data.


      Procedures used  to  estimate  the model  coefficients  and the estimates are
presented in Appendix IV-A, Exhibit 1.   The data base employed to obtain the
estimates is presented in Appendix  IV-A, Exhibit 8.


     This regression model differs  from  the model presented in the December 8,
1986, Federal Register NOA in several major respects:


     •  BPT_Treatment System:   The revised regression model is designed to
        estimate BOD  effluent long-term averages for biological treatment
        only (the selected BPT regulatory option) rather than for biological
        treatment and polishing ponds (see Section IX for rationale of options
        selection) .

             ^formance Edit:  The indicator variable 15.  in the December 8,
             subcategorization specified at  least 95 percent  BODC  removal or
        at most  50  mg/1 BOD5 in the treated  .was tewater (95/50),  while  the
        otT/n/  reSression model has indicator variable  14. ,  which specifies
        95/40 (see  Section VII for discussion on change  of  performance  editing
        rules).                         •                                     e
  198
                              IV-10

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       Performance and Treatment System Shifts:  The regression model pre-
       sented in the December 8, 1986 Federal Register NOA included a single-
       parameter to account for differences in the logarithm of BOD, due to
       treatment systems other than biological treatment and polishing ponds
       and less than adequate performance: (defined as 95/50).  The revised
       regression model includes separate  parameters to accourit for differ-
       ences:  one parameter to distinguish between BPT treatment systems
       (now biological only) and other  treatment systems; ancT another para-
       meter  to account for performance  (now defined as 95/40).  Discussion
       of  these changes in parameters is  included  in this section.

       Adjustment  for OCPSF flow:  The  model published  in the  December 8,
       1986,  subcategorization  included an OCPSF  flow adjustment, but  the
       current model  includes no  such adjustment  for flow.   Discussion of
       this  change is  included  in this  section.
     •  Individual Plant Versus Subcategory Long-Term Averages!  Q
        subcategorization methodology published in the December 8, 1986,  NOA
        yielded individual plant-specific long-term averages, the revised
        subcategorization methodology yields pure subcategory BOD  and TSS
        effluent long-term averages that will be applied by the NPDES permit
        writers.


The procedures used to calculate the pure subcategory long-term averages are

presented in Appendix IV-A.  (See Section VII for discussion of rationale for

choosing between pure subcategory and individual plant-specific long-term

averages . )


     'The Agency retained  the same methodology presented in  the December  8,
1986, Federal Register  NOA  for calculating TSS  effluent long-term averages.  A
discussion  of  the  relationship of TSS  to BOD5 effluent concentrations  is pre-

sented  in Section  VII,  along with a  discussion  of  the final TSS  performance

criterion.   The regression  model for estimating TSS effluent long-term

averages  is as  follows:                                      .        ;
                       a •
b-[ln(BOD.)]
ei
      The coefficients a and b are estimated from the 61 OCPSF plants that have

 only biological treatment in place, meet the 95/40 editing criteria for BOD5

 described previously, and have TSS effluent concentrations of at most

 100 mg/1.
                                      IV-11

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       Estimates of the TSS-model coefficients are given in Appendix IV-A,
  Exhibit  2.   The data base employed to generate the estimates is presented in
.Appendix IV-A,  Exhibit 8.

       The following sections  discuss  the  rationale behind  some of the  changes
  made  to  the  subcategorization methodology.

       1-   Performance  and Treatment System Shifts
       One  change  in  the  form  of  the BOD5  long-term average model  is a  revision
  of the indicator  functions.  The regression model published  in  the December  8,
  1986, Federal Register NOA had a single  shift  indicator.  This indicator was
  the sole explanatory variable to account for adjusted differences in average
  treatment performance between biological plants having polishing ponds and
 satisfying the proposed 95/50 performance criterion and all other plants.

      If this kind of single indicator function was applied to the revised BPT
 treatment and performance standards of biological only and 95/40, then this
 single shift indicator would account  for adjusted differences between biologi-
 cal only, 95/40 plants and all  other  plants.   The set of all other facilities
 can be divided into three distinct  subsets;   plants with treatment other than
 biological only which satisfy the performance criterion;  plants with treatment
other  than biological only which do not satisfy the performance criterion?  and
plants with  only biological treatment which do  not satisfy the performance
criterion.   Clearly,  plants with more than biological treatment  are  expected
to  perform at least  as well as biological-only  facilities,  and biological-only
plants that  fail  to  satisfy the  95/40 edit will perform below the BPT  "average
of  the best"  performance.   A  single shift indicator  alone,  similar to  that
included  in the regression  model  published in the  December 8,  1986, NOA,
cannot separately  account for the adjusted differences due  to  treatment'and
performance between  the biological-only,  95/40  plants and all  other plants.
In an effort  to reformulate the revised BOD5 long-term average model to better
reflect the separate effects of the treatment and performance  characteristics
of the data base, EPA redefined the single indicator shift in  the form of two
indicator variables for the model:  one indicator accounts for adjusted dif-
ferences between biological only treatment and  treatment other than biological
                                    IV-12

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only, and the other indicator accounts for adjusted differences between plants
meeting the 95/40 performance criteria and those that do not.

     2.  Flow and Total Production Adjustment Factors
     The regression model published in the December 8, 1986, Federal Register
NOA contained a flow adjustment term in the form of the natural logarithm of
the plant OCPSF flow in MGD.  EPA included this term in an effort  to account
for plants  that practice water conservation.  The  regression coefficient for
that term was negative, which resulted in a decreasing BOD5  long-term  average
concentration for  increasing flow.  Although  this  result  is  reasonable and  may
account  for water  conservation, it  could  impose unreasonably low  limitations
on plants with  a high  proportion of fibers production  that already achieve  low
effluent BOD5 levels  (i.e.,  12 mg/1).  Industry commenters claimed that flow
rate alone  cannot  distinguish between plants  that  practice water  conservation
and  those  plants  that  use  excessive amounts of water.   Certain product/pro-
cesses (e.g.,  rayon manufacture)  must use large amounts of water  in relation
 to  other plants and are then unjustly penalized with lower  limits.  Further-
more,  commenters  stated the inclusion of the  flow adjustment term does not
 reflect total production,  which should be incorporated into the subcategorical
 regression model.   According to the commenters,  increased production should
 result in larger flows and higher BOD5 concentrations, which is contrary,to
 the results obtained from the regression model EPA published in the December
 8,  1986, NOAi  An examination of these issues is  summarized below.

      EPA reexamined the inclusion  of the flow adjustment factor.  Based on
 that examination, EPA agrees that  flow rate  alone does not  indicate whether a
 plant practices water conservation.  Moreover, the 1986  published model, in
 EPA's assessment, did result in excessively  low BOD5 long-term average con-
 centrations for some  plants with large flows.

       Commenters further argued that  the  statistical significance of  the flow
 adjustment factor for the regression model presented  in  the December  8, 1986,
 NOA was due entirely  to a small  number  of plants  with small flows and large
 BOD  effluents.   EPA's examination of the data base revealed  that facilities
                                       IV-13

-------
  with relatively high BOD, and low flows are mostly facilities that have bio-
  logical treatment but failed the 95/40 performance criteria.  To formalize
  this analysis, EPA considered models in the context of the data base used for
  determining BOD5 effluent long-term averages to explore the effects of these
  plants on flow adjustments.   In particular, the model
                            /
             ln(BOD±) = a + Z w^-T.,  + F- [ln(flow. )] + e±

  was  examined separately for  the following four subsets of the data base:

       (1) Biological only and 95/40
       (2) Biological only and not  95/40
       (3) Not  biological  only and  95/40
       (4) Not  biological  only and  not  95/40

      These four mutually  exclusive subsets partition completely the 153 full-
 response, direct discharger  OCPSF plants  that have at least biological treat-
 ment in place and provided BOD5 effluent, flow, and subcategorical production
 data.  The computer analysis for these regression models and plots of ln(BOD
 effluent) versus In(flow) are presented in Appendix IV-A, Exhibit 3.  Note  *
 that the set of plants in (1) above has information regarding all subcate-
 gories.   Rayon plants are not present in the set of plants in subsets (2),
 (3),  and (4),  however, and the term corresponding to rayon has been excluded
 from  the model for these sets of plants.   Also,  fibers  plants are not  present
 in the set  of plants in subset (4),  and  the term corresponding to fibers  has
 also  been excluded from the model  when examining the set  of plants in  (4).
 These models  were  examined for the significance  of  the  coefficient F,  corres-
 ponding  to  the natural logarithm of  flow.

      Based on  this analysis,  the Agency agrees with  the commenters that the
significance of the  flow  adjustment term in the  December model  is  largely
influenced by  the poorly  performing plants (plants that do not  meet  the 95/40
BPT performance edit) with only  biological treatment.  Because  this pattern is
exhibited only by a subset of plants that are not well-designed and operated,
                                    IV-14

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the Agency concludes that this pattern should not be reflected in the esti-
mation of long-term BODg averages as a construct of the model.  Therefore, EPA
has deleted the flow adjustment factor from the model.

     EPA has also examined the inclusion of a production adjustment factor
using the following model:

                          7
           ln(BOD..) = a + E w.^Tj + G-[ln(prod. )]  +  e..

where:
           ln(prod.) =  In (OCPSF  1980  total production)  from plant  i,  in
                   1     millions of pounds  per year, with associated
                        coefficient G.

      As  described in  the  analysis of  flow,  this model was  examined  separately
 for the  four  subsets  of the  157  full-response,  direct discharge OCPSF plants
 that have at  least biological treatment in place and  provided BOD5  effluent
 and subcategorical production data.   The computer analysis for these regres-
 sion models  and plots of In(BOD)  are presented in Appendix IV-A, Exhibit 4.
 These models were examined  for the coefficient of G,  corresponding to the
 natural logarithm of production.   The same pattern emerges with this factor as
 was present  when the natural logarithm of flow was examined; namely, the sig-
 nificance of this term is largely due to the poorly performing plants with
 biological only treatment (plants that do not meet the 95/40 BPT performance
 edit).  Consequently, EPA has decided not to add a production adjustment
 factor to the model.

      Commenters have asserted that increased production should  result in
 higher BOD  effluent concentrations.  As seen  by the  regressions involving
 total production,  the data do not support a positive  association between BOD5
 effluent concentration and total production (higher  BOD5  effluent  concentra-
 tions associated with.higher production levels), after  adjustment  for propor-
 tion of  production in a subcategory.
                                      IV-15

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       EPA has also considered the effect of flow per unit of production, using
  the following model, applied separately to the 4 subsets of 153 full-response,
  direct discharge OCPSF plants that have at least biological treatment in place
  and provided BOD5 effluent,  flow,  and subcategorical production data (4 of the
  157 full-response plants did not report flow):
ln(BOD.) =
a +
      w.
                                   .  + H- [ln(365*flowi/prodi)]  +
 where?
                        = annual  total  flow  (MGD), corrected  for non-process
                          waste streams, for plant i, divided by OCPSF  1980
                          production  (in millions of pounds per year),  for
                          plant i.
      The units for ln(365*f low, /prod,) are gallons/pound-the significance of
 the coefficient H, associated with this quantity, was examined.  Results simi-
 lar to those found for flow and production were observed, in the sense that
 this flow per unit production variable is only marginally significant for
 plants with biological only treatment that do not meet the 95/40 BPT perform-
 ance edit (see Appendix iy-A,  Exhibit 5).   The Agency concluded that a flow
 per unit production adjustment factor was  not appropriate for the same reasons
 described for flow and production;  that is,  the model should not reflect  a
 pattern exhibited  only by a subset  of plants  that are not well-designed and
 operated.

 D.   FINAL ADOPTED  BAT  SUBCATEGORIZATION APPROACH
     Based on  comments  received during public  comment  periods for  the  proposal
 and  the NOAs,  the  Agency  noted that a  certain  subset of OCPSF plants existed
 that either generate such low raw waste BOD5 levels that  they do not require
 end-of-pipe biological  treatment or choose to  use physical/chemical treatment
alone to comply with BPT  effluent limitations.  The Agency has decided  to
establish two BAT subcategories that are largely determined by raw waste BOD
characteristics, as follows":                                                5

     •  Subcategory One - all plants that have or will install biological
        treatment to comply with BAT effluent  limitations.
                                    IV-16

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     .  Subcategory Two - all plants which,  based on raw waste characteris-
        tics,  will not utilize biological treatment to comply with BPT
        effluent limitations.

     In addition, the Agency is also establishing a different BAT effluent
limitation for zinc, including manufacturers of rayon by the viscose process
and plants manufacturing acrylic fibers utilizing the zinc chloride/solvent
process.

     BAT effluent limitations for, Subcategory One will be based on the per-
formance of biological  treatment and in-plant controls.  Biological treatment
is an  integral  part of  this  subcategory's model BAT  treatment  technology;  it
achieves incremental  removals of some  toxic  pollutants beyond  the removals
achieved by in-plant  treatment without end-of-pipe biological  treatment.   BAT
effluent limitations  for Subcategory Two will be  based on  the  performance of
only in-plant treatment technologies such as steam stripping,  activated
carbon,  chemical precipitation,  cyanide destruction,  and in-plant biological
treatment  of  selected waste streams.   The Agency has concluded that,  within
each Subcategory,  all plants can treat priority pollutants to the  levels
established.   (The Agency determined that  further BPT subcategorization  for
plants without end-of-pipe biological  treatment is unnecessary.   As described
 in the Section VII assessment of mmbiological end-of-pipe treatment systems,
 the Agency concluded that plants that  do not need biological treatment to
 comply with the BPT BOD5 limitations can meet the TSS limitations with physi-
 cal/chemical controls alone.  As also shown, some plants achieve sufficient
 control of BOD5 through the use of •, only physical/chemical treatment unit
 operations.)

       The Agency also received comments  (supported by submitted data) during
 public comment  periods  stating that plants  manufacturing acrylic fibers  by the
 zinc  chloride/solvent  process produced  raw  waste and treated  effuent levels of
 zinc  similar to those  levels produced by rayon manufacturers  utilizing  the
 viscose process.   After examining  these data,  the Agency  agreed with  the
 commenters that it was appropriate  to include  these plants  along with rayon
 manufacturers.   Based  on this decision, the Agency  is establishing  two  dif-
 ferent limitations for the pollutant  zinc.  One  is  based  on data collected
                                      IV-17

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  from rayon manufacturers and acrylic fibers manufacturers using the zinc
  chloride/solvent process.  This limitation applies only to those plants that
  use the viscose process to manufacture rayon and the zinc chloride/solvent
  process to manufacture acrylic fibers.  The other zinc limitation is based on
  the performance of chemical precipitation technology used in the metal fin-
  ishing point source category, and applies to all plants other than described
  above.

  E.   SUBCATEGORIZATION FACTORS
       1.   Introduction
      All  nine factors listed  in the beginning  of this  section were  examined
  for  technical significance  in the  development  of the proposed subcategoriza-
  tion scheme.   However,  in general,  the proposed  subcategorization reflected
  primarily differences  in waste  characteristics,  since many of the other eight
  factors, while considered,  could not be examined  in appropriate technical and
  statistical depth due  to the  intricacies of the plants  in this industry.
 Therefore, variations  in waste  characteristics were utilized  to evaluate the
 impact of the  other eight factors on subcategorization.  For  example, the
 ideal data base for evaluating  the need for subcategorization and the develop-
 ment of individual subcategories would include raw wastewater and final efflu-
 ent pollutant data for facilities which segregate and treat each process raw
 waste stream separately.  In this manner,  each factor could be evaluated
 independently.  However, the available information consists of historical  data
 collected  by individual companies,  primarily for the purpose  of  monitoring the
 performance  of end-of-pipe  wastewater treatment technology and compliance  with
 NPDES permit  limitations.'  The OCPSF industry  is  primarily composed  of  multi-
 product/process,  integrated  facilities.  Wastewaters generated from  each
 product/process are  typically  collected in  combined  plant  sewer systems and
 treated in one main  treatment  facility.

      Therefore, each plant's overall  raw wastewater characteristics are
affected by all of the  production processes occurring at the site at one time.
The effects of  each production operation on the raw wastewater characteristics
cannot be isolated accurately  from all of the other site-specific factors.
Therefore,  a combination of both technical and statistical methodologies had
                                    IV-18

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to be used to evaluate the significance of each of the subcategorization fac-
tors.  The methodologies and analyses necessarily are limited to indicating
trends rather than yielding definitive quantitative significance of the fac-
tors considered.

     In the methodology that was employed, the results of the technical analy-
sis were compared to the results of the statistical efforts to determine the
usefulness of each factor as a basis for subcategorization.  The combined
technical/statistical evaluations of the nine factors are presented below.

     2.  Manufacturing Product/Processes
     Comments have been received that state that  the choice of  the final seven
subcategories based on production is arbitrary, since the Agency did not per-
form a statistical analysis  to group plants in optimal subcategories.  Product
groups are based on both  the marketing structure  of  the  industry and technical
factors affecting  the generation of contaminants.

     By choosing subcategories based on SIC codes,  the marketing character-
istics by which the industry is organized  are  emphasized;  facilities can be
easily classified  since  the  SIC codes  are  readily available  to  the plant.
Furthermore,  from  a technical point  of view, based on engineering judgment and
analysis  of  the data  supplied by  the  industry, most  of these subcategories
represent  different waste streams.

      The  purpose  of subcategorization is  the division of the OCPSF  industry
into smaller groups  that account  for the  particular common characteristics  of
different facilities.   The OCPSF  industry (as  defined by EPA) is  recognized  to
comprise  several  product groups:

      •  Organic Chemicals (SIC 2865/2869)
      •  Plastic Materials and Synthetic Resins (SIC 2821)
      •  Cellulosic Manmade Fibers (SIC 2823)
      •  Synthetic Organic Fibers (SIC 2824).
                                      IV-19

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 Vertical integration  of  plants within  these  industries  is  common, however,
 blurring distinctions  between' organic  chemical  plants and  plastics/synthetic
 fibers plants.  As a  practical matter,  the OCPSF  industry  is divided among
 three types of plants:

      •  Plants manufacturing  only organic chemicals (SIC 2865/2869)
      *  ooon/S manufacturin£  only plastics and  synthetic materials (SIC 2821/
         2823/2824)
      •  Integrated plants manufacturing both organic chemicals and plastics/
         synthetic materials (SIC 2865/2869/2821/2823/2824).

 Each type of plant is unique not only in terms of product type (e.g., plas-
 tics) but also in terms of process chemistry and engineering.  Using raw
 materials provided by organic chemical plants, plastic plants employ only a
 small subset of the chemistry practiced by the OCPSF industry to produce a
 limited  number of products (approximately 200).   Additionally,  product  re-
 covery from process wastewaters  in plastic plants generally is  possible,  thus
 lowering raw waste BOD5 concentrations.  Plants  producing organic chemicals,
 on the other hand,  utilize a much larger set  of  process  chemistry and engi-
 neering  to  produce approximately  25,000 products;  process wastewaters from
 these plants are  in general not as amenable  to product recovery and  are gen-
 erally higher in  raw waste BOD5 concentration and  priority pollutant  loadings.

      Further divisions are possible within these broad groupings.  Plastic
 materials and  synthetic resins manufacturers  can be  subdivided  into  thermo-
 plastic materials  (SIC 28213)  producers and thermosetting resin (SIC  28214)
 producers.   Rayon manufacturers and synthetic organic fiber manufacturers  are
 also  both unique.  Again,  process  chemistry and  engineering are  broadly con-
 sistent within these groupings in  terms  of BOD .

      The organic chemicals  industry produces  many  more products  that does  the
 plastics/synthetic fibers  industry and  is correspondingly more complex.   While
 it is indeed possible  to separate  this  industry  into product groups,  the num-
 ber of such product groups is  large.  Moreover, with few exceptions,  plants
 produce organic chemicals from several product groups and thus limit the
utility of such an approach.
                                    IV-20

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     An alternative to a product-based approach is an approach based on the
type of manufacturing conducted at a plant.  Large plants producing primarily
commodity chemicals (the basic chemicals of the industry, e.g., ethylene,
propylene, benzene) comprise the first group of plants.  A second tier of
plants- includes plants that produce high-volume, intermediates  (bulk chemi-
cals).  Plants within this tier typically utilize the products of the com-
modity chemical plants (first tier plants) to produce more structurally com-
plex chemicals.  Bulk chemical plants are generally smaller  than those in the
first group, but still may produce several hundred million pounds of chemicals
per year  (e.g., aniline, methylene dianiline, toluene diisocyanate).  The
third group  includes  those plants that are devoted primarily to manufacture of
specialty chemicals — chemicals  intended  for a particular end use  (e.g., dyes
and pigments).  Generally, specialty  chemicals are more  complex structurally
than either  commodity or bulk chemicals.

     Chemicals  within the  three groups  —  commodity,  bulk, and specialty —
are defined  on  the basis of national  production.   Commodity  chemicals  are
 those  chemicals produced nationally  in  amounts greater than  or equal to  1
 billion pounds  per year.   Bulk  chemicals are defined to  be those  chemicals
 produced nationally in amounts  less  than 1 billion but more  than  40 million
 pounds per year.   Specialty chemicals are those  chemicals produced nationally
 in amounts less than or equal to  40, million pounds per year.  Using these
 definitions, there are 35  commodity chemicals,  229 bulk chemicals or bulk
 chemical groups,  and more  than 786 specialty chemicals or specialty chemical
 groups.

      In general, the rate of biodegradation decreases with  increasing molecu-
 lar complexity.  Because commodity chemical plants produce  the least complex
 chemicals,  a general trend of lower BOD5 effluent concentrations for commodity
 chemical plants to higher BOD5 effluent concentrations  for  specialty chemical
 plants is observed.

      ¥ith regard  to  subcategorization for BAT, the Agency considered whether
 the industry should  be subcategorized by  evaluating  the same subcategorization
 approach developed for BPT, which is based  primarily  on manufacturing product/
 processes.  The available data for BAT  show that  plants, in  differing BPT sub-
 categories  can achieve similar low  toxic  pollutant  effluent concentrations by
                                      IV-21

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  installing the best  available treatment  components.   Since all plants within
  the  two  BAT technology-based  subcategories  can achieve compliance with the
  same BAT effluent  limitations through  some  combination of  demonstrated tech-
  nology,  the predominant  issue relates  to the  cost  of  the required treatment
  technology.  EPA has analyzed these  costs and their associated impacts and has
  determined  them to be reasonable.  Therefore,  the  Agency believes that BAT
  subcategorization based  on manufacturing product/processes  is  not necessary
  for  effective,  equitable regulation.

      3.  Raw Materials
      Synthetic  organic chemicals can be  defined as derivative  products of
 naturally occurring materials (e.g., petroleum, natural gas, and  coal) that
 have undergone at least one chemical reaction, such as oxidation, hydrogena-
 tion, halogenation, or alkylation.  This definition,  when applied to the
 larger number of potential starting materials and the host  of chemical reac-
 tions that can be applied,  leads to the possibility of many thousands of
 organic chemical compounds being produced by a potentially  large number of
 basic processes having many variations.  There are more than 25,000 commercial
 organic chemical products derived principally from petrochemical sources.
 These are produced  from five major raw  material classifications:  methane,
 ethylene, propylene,  C4 hydrocarbons  and  higher aliphatics,  and aromatics.
 This  major raw materials  list  can be  expanded  by further defining the aro-
 matics  to include benzene,  toluene, and xylene.   These raw  materials  are
 derived from natural  gas  and petroleum, although a  small portion of the
 aromatics are derived from  coal.

      Currently,  approximately  90  percent  (by weight) of the  organic chemicals
 used  in the  world are derived  from petroleum or  natural gas.  Other sources of
 raw materials are coal and some naturally occurring renewable material  of
which fats,  oils, and  carbohydrates are the  most important.

     Regardless  of the  relatively limited number of basic raw materials util-
ized by the organic chemicals  industry,  process  technologies lead  to  the for-
mation of a wide variety of products and  intermediates, many of which can be
produced from more than one basic raw material either as a primary reaction
                                    IV-22

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product or as a byproduct.  Furthermore, primary reaction products are fre-
quently processed to other chemicals that categorize the primary product from
one process as the raw material for a subsequent process.

     Delineation between raw materials and products is nebulous at best, since
the product from one manufacturer can be the raw material for another manufac-
turer.  This lack of distinction is more pronounced as the process approaches
the ultimate end product, which is normally the fabrication or consumer stage.
Also, many products/intermediates can be made from more  than one raw material.
Frequently, there are alternate processes by which a product can be made from
the same basic raw material.

     Another characteristic of the OCPSF industry that makes subcategorization
by raw material difficult is  the high degree of integration in manufacturing
units.' Since  the majority of basic raw materials derive from petroleum and
natural gas, many of  the  organic.chemical manufacturing  plants are  either
incorporated into or  contiguous  to petroleum refineries, and may formulate a
product at almost any point  in a process from any or all of  the  basic  raw
materials.  Normally,  relatively few  organic chemical  manufacturing facilities
are  single product/process plants unless the final  product  is near  the fabri-
cation or  consumer  product stage.

      Because  of  the integrated  complexity  of  the  largest (by weight)  single
segment  of  the organics industry (petrochemicals),  it  may be concluded that
BPT  and  BAT  subcategorization by raw materials  is not  feasible  for the fol-
 lowing reasons:

      •  The  organic chemicals industry is  made up primarily of  chemical
         complexes of various sizes  and complexity.
      •  Very little,  if any, of the total production is represented by single
         raw material plants.
      •  The raw materials used by a plant can be varied.widely over short time
         spans.
      •  The toxic,  conventional, and nonconventional wastewater pollutant
         parameter data gathered for this study were not collected and are not
         available on a raw material orientation basis,  but rather represent
         the mixed end-of-pipe plant wastewaters.
                                      IV-23

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       4.  Facility Size

       Although  sales  volume,  number  of  employees,  area  of  a  plant  site,  plant
 capacity, and  production  rate might logically  be  considered to  define  facility
 size, none of  these  factors  alone describes  facility size in a  satisfactory
 manner.  Recognizing these limitations,  the  Agency has chosen total OCPSF
 production to  define facility size.

      The regression  model approach  allows the Agency to easily  test for BPT
 subcategorization factors such as facility size as measured  by  total OCPSF
 production.   EPA has analyzed total OCPSF production, as discussed previously
 in this section, to determine its appropriateness as a subcategorization fac-
 tor, and determined  that the significance of production is due largely to
 plants with only biological treatment that do not meet the 95/40 BPT perform-
 ance edit.   Consequently,  an adjustment factor for production is not incorpo-
 rated into  the model.

      In terms of a BAT subcategorization factor,  although  facility sizes (as
 measured by  total OCPSF production)  of  the waste  streams with the OCPSF indus-
 try vary widely,  ranging from less  than 10,000  pounds/day  to more than
 5  million pounds/day, this definition fails  to  embody fundamental character-
 istics such as  continuous  or  batch manufacturing  processes.   While equivalent
 production rates  may  be accomplished by either  production  method,  the charac-
 teristics of  these waste streams  in  terms of  toxic pollutants may vary  sub-
 stantially because of different yield losses  inherent in each process.   There-
 fore,  the Agency  has  determined that no  adequate method exists for defining
 facility  size and that  there  is no technical  basis for  the use of  facility
 size as a BAT subcategorization factor.

     5.  Geographical Location
     Companies  in the OCPSF industry usually  locate their plants based on a
number of factors.  These include:

     •  Sources of raw materials
     •  Proximity of markets for products
     •  Availability of an adequate water supply
                                    IV-24

-------
     •  Cheap sources of energy
     •  Proximity to proper modes of transportation
     •  Reasonably priced labor markets

In addition, a particular product/process- may be located in an existing facil-
ity based on availability of certain types of equipment or land for expansion.

     Companies also locate their facilities based on the type of production
involved.  For example, specialty producers may be located closer to their
major markets, whereas bulk producers may be centrally located to service a
wide variety of markets.  Also, a company that has committed itself to zero
discharge as its method of wastewater disposal has the ability to locate any-
where, while direct dischargers must locate near receiving waters, and in-
direct dischargers must locate in a city or town that has an adequate POTW
capacity to treat OCPSF wastewaters.:

     Because of the complexity and inter-relationships of the factors affect-
ing plant locations outlined above, no clear basis for either BPT or BAT sub-
categorization according  to plant location could be found.  Therefore, loca-
tion is not a basis for BPT and BAT subcategorization of the OCPSF industry.

     Since  biological  treatment installed to meet BPT effluent limitations  is
an important part of both BPT and BAT subcategorization approaches, the Agency
decided  to  perform an  analysis to confirm that  temperature (as defined by  the
heating-degree day variable to measure winter/summer effects), instead of
location, is not a subcategorization factor.  The Agency used a  regression
model approach similiar  to  the analysis  for facility size.  Analysis on the
following regression model was performed  to test for the significance of  this
factor:                                                                 .
= a +
 where:
               Z wij'Tj +
                                       ' (degree days..)  + ei
degree days.
                           the number of. degrees that the mean daily outdoor
                           temperature is below 65 °F for a given day,  accumu-
                           lated over the number of days in the year that the
                                     IV-25

-------
                            mean temperature is below 65°F,  at plant i (with
                            associated coefficient J).

      .This  analysis  was  performed  separately for  the four subsets  described
 previously which  partition the 157  full-response,  direct discharge OCPSF
 plants  that have  at least  biological treatment in  place and  provided BOD5
 effluent and subcategorical production data.  The  computer analysis  for these
 regression models is presented in Appendix IV-A, Exhibit 6.   In none of these
 four subsets was  temperature significant,  and consequently a temperature
 factor is  determined to be inappropriate.

      6.  Age of Facility and Equipment
      The age of an OCPSF plant is difficult to define accurately.  This is
 because production facilities are continually modified to meet production
 goals and  to accommodate new product lines.  Therefore, actual process equip-
 ment is generally modern (i.e., 0-15 years old).   However,  major building
 structures and plant sewers are not generally upgraded unless the plant
 expands significantly.   Older plants may use open sewers and drainage ditches
 to collect process wastewater.   In addition, cooling waters,  steam conden-
 sates,  wash waters,  and  tank drainage waters are  sometimes  collected in these
 drains  due to  their  convenience and  lack of other collection alternatives.
 These ditches  may  run inside the process  buildings  as  well  as between manu-
 facturing centers.   Therefore,  older facilities are likely  to exhibit higher
 wastewater  discharge flow rates than newer facilities.   In  addition,  since  the
 higher  flows may result  from  the inclusion of  relatively clean noncontact
 cooling waters  and steam condensates as well as infiltration/inflow,  raw
 wastewater  concentrations may be lower due to  dilution  effects.  Furthermore,
 recycle techniques and wastewater segregation  efforts normally cannot be
 accomplished with existing  piping systems,  and would require  the installation
 of new collection lines as well as the isolation  of.the existing collection
 ditches.  However, due to water conservation measures as well  as ground con-
 tamination  control, many older  plants are  upgrading  their collection  systems.
In addition, the energy crisis of recent years has caused many plants  to
upgrade their steam and cooling systems to make them more efficient.  Based on
 the factors mentioned above, the Agency has determined its only accurate age
                                    IV-26

-------
measurement to be the age of the oldest process at each OCPSF facility.
Analysis on the following regression model was performed to test for the
significance of age:

                          7
           ln(BOD.) = a + E W..-T. + K^age^) + e±
                 •L        • T •*• J  J
where:
age
                   the age of  the  oldest process  at  plant  i  (with  associated
                   coefficient K).
     This  analysis was  performed  separately  for  the  four  subsets  described
 previously that partition  the  157 full-response,  direct discharge OCPSF plants
 that have  at  least biological  treatment  in place and provided BOD5 effluent
 and subcategorical production  data.   The computer analysis for these regres-
 sion models is  presented in Appendix IV-A, Exhibit 7.  Results of this
 analysis are  similar to results seen for production, flow, and flow per unit
 of production;  that  is, the only group of plants that exhibit a relationship
 between age and effluent BOD5  concentration  is the subset of poorly performing
 biological-only plants  (plants that do not meet  the 95/40 BPT editing cri-
 teria). Consequently,  the Agency has determined that an age factor is not
 appropriate.

      The  extent to which process wastewaters are contaminated with toxic pol-
 lutants depends mainly upon the degree of contact that process water has with
 reactants/products,  the effectiveness of  the separation train, and the
 physical-chemical properties of  those priority pollutants formed  in the reac-
 tion.   Raw wastewater quality is determined by the  specific process design and
 chemistry.  For example, water formed during a reaction, used to .quench a
 reaction mixture, or used  to wash reaction products will contain  greater
 amounts of pollutants  than does  water that does not come  into direct  contact
 with reactants or products.  The effectiveness of a separation train  is deter-
 mined  by  the process design and  the  physical-chemical properties  of those
 pollutants present.  ¥hile improvements  are continually made  in  the design  and
 construction of process equipment,  the  basic  design of such  equipment may  be
                                      IV-27

-------
 quite old.  Process equipment does, however, deteriorate during use and re-

 quires maintenance to ensure optimal performance.   When process losses can no

 longer be effectively controlled by maintenance,  process equipment is re-

 placed.   The maintenance schedule and useful life  associated with each piece

 of equipment are in part determined by equipment age and process conditions.

 Equipment age,  however,  does not directly affect either pollutant concentra-

 tions in  influent or effluent wastewaters and is therefore  inappropriate  as a
 basis for BAT subcategorization.


      7-   Wastewater Characteristics and Treatability

        a.   BPT  Subcategorization

      The  treatability of  OCPSF wastewaters is  discussed  in detail  in  Section

VII.  The  treatability of a  given wastewater  is affected by  the  presence  of

inhibitory materials (toxics), availability of alternative disposal methods,

and pollutant concentrations  in,  and variability of, the raw wastewater con-

centrations.  However, all of these factors can be controlled by sound waste

management,  treatment technology  design, and operating practices.  Examples of
these are:
     •  The. presence of toxic materials in the wastewater can be controlled by
        in-plant treatment methods.  Technologies such as steam stripping,
        metals precipitation, activated carbon, and reverse osmosis can elimi-
        ?aufu-   Presence of materials in a plant's wastewater that may
        inhibit or upset biological treatment systems.

     •  Although some plants utilize deep well injection for disposal of high-
        ly toxic wastes to avoid treatment system upsets,  other alternative
        disposal techniques such as contract  hauling and incineration are
        available to facilities that cannot utilize deep well disposal.   In
        addition,  stricter groundwater regulations may eliminate the option of
        deep  well disposal for some plants and make it uneconomical for
        others,  forcing facilities  to look more closely at  these other
        options.

     •  Raw waste  concentration variability can easily be controlled by  the
        use of equalization basins.   In some  plants,  "at-process" storage  and
        equalization is  used to meter specific process wastewaters,  on a con-
        trolled  basis,  into the plant's wastewater treatment  system.

     •  Raw waste  concentrations  can be reduced  with  roughing biological
        filters  or with  the use of  two-stage  biological  treatment systems.
        These  techniques are discussed  in  detail  in Section VII.
                                   IV-28

-------
     OCPSF wastewaters can be treated by either physical-chemical or biologi-
cal methods, depending on the pollutant to be removed.  Also, depending on the
specific composition of the wastewater, any pollutant may be removed to a
greater or lesser degree by technology not designed for removal of this pol-
lutant.  For example, a physical-chemical treatment system designed to remove
suspended solids will also remove a portion of the BODg of a wastewater if the
solids removed are organic and biodegradable.  It is common in the OCPSF in-
dustry to use a combination of technologies adapted to the individual waste-
water stream to achieve desired results.  These concepts are discussed in
detail in Section VII.  In general, the percent removals of BOD5 and TSS are
consistent across the seven final subcategories.  It is also possible for
plants in these subcategories to achieve high percent removals (greater than
95%) for both BOD5 and TSS (data supporting these removals are presented and
discussed in Section VII).  Also, OCPSF plants producing the same products and
generating similiar raw waste BOD5 concentrations are, in general, equally
distributed above and below the pure subcategory long-term averages for BOD5
effluent as determined by the BPT regression equation.  Figures IV-1 through
IV-7 present the distribution of plants within each pure subcategory (defined
as full-response direct discharge plants that have at least 80 percent of
their  total OCPSF production in one of  the seven final subcategories) by
effluent BOD  and the product(s) each plant produces.  Also included with each
plant's BOD5 effluent is its associated raw waste BOD5 concentration (when
available); in addition, if a plant produces more than one product within a
subcategory, its effluent and raw waste BOD5 values are repeated and noted on
each figure, as multiple effluent and influent, respectively.

     In reviewing these figures, it should be noted that for most of the pro-
ducts  within a pure subcategory, plants with fairly high raw waste BODg con-
centrations are equally distributed above and below the subcategory long-term
average BOD5 effluent and that even for plants producing the same products
that did not have raw waste BOD5 concentration data, BOD5 effluents are fairly
well-distributed above and below the subcategory median BOD5 effluent for
certain products within selected subcategories.  Situations  in which there are
a  disproportionate number of plants either above or below the subcateogry
long-term average maybe explained by a  number of factors, including the con-
tribution of remaining 20 percent of.each plant's product mix to  its BOD5
                                     IV-29

-------
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            IV-35

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            IV-36

-------
effluent, the end-of-pipe treatment systems in place at each plant and the
in-plant controls currently in place at each plant that may cause raw waste
BOD  concentrations to be reduced or that may remove toxic pollutants that
inhibit biological activity and cause higher BOD5 effluent concentrations.  It
should also be noted in any event that for those plants substantially above
the subcategory long-term average BOD5 effluent value, as well as for other
plants, EPA/s costing methodology and resulting cost estimates and economic
impact estimates have fully accounted for any required treatment improvement.

     Based on the distribution of raw waste and effluent BOD5 concentrations,
the relative consistency of percent  removal data across  the  final seven  sub-
categories, and BOD5 effluent data within subcategories  and  product  groups
within  those subcategories, the Agency has concluded  that  the adopted BPT
subcategorization accounts sufficiently  for wastewater characteristics and
treatability.

      b.   BAT Subcategorization
      Typically,  the treatability  of  a waste  stream is described in  terms of
 its  biodegradability,  as  biological  treatment usually provides  the  most  cost-
 effective means of  treating  a high volume,  high (organic)  strength  industrial
 waste (i.e., minimum capital  and  operating costs).   Furthermore,  biodegrad-
 ability serves  as an important  indicator of the toxic nature of the waste load
 upon discharge  to the environment.   Aerobic (oxygen-rich)  biological treatment
 processes achieve accelerated versions of the same type of biodegradation that
 would occur much more slowly in the receiving water.   These treatment pro-
 cesses accelerate biodegradation by aerating the wastewater to keep the dis-
 solved oxygen concentration high and recycling microorganisms to maintain
 extremely high concentrations of bacteria, algae, fungi,(and protozoa in the
 treatment system.  Certain compounds that resist biological degradation  in
 natural waters may be readily oxidized by a microbial population adapted to
 the waste.  As would occur in the natural environment, organic compounds may
 be removed by volatilization (e.g., aeration) and adsorption on solid mater-
 ials (e.g., sludge) during biological treatment.
                                      IV-37

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       One of the primary limitations of biological treatment of wastewaters
  from the OCPSF industry is the presence of both refractory (difficult to
  treat)  compounds as well as compounds that are toxic or inhibitory to biologi-
  cal processes.   Compounds oxidized slowly by microorganisms can generally be
  treated by subjecting the wastewater to biological treatment for a longer
  time,  thereby  increasing the overall conventional and toxic pollutant re-
  movals.   Lengthening the duration of treatment,  however,  requires larger
  treatment tanks  and more aeration,  both of which add to the expense of the
  treatment.  Alternatively,  pollutants  that are refractory,  toxic,  or inhibi-
  tory to  biological  processes  can  be removed prior to biological  treatment of
  wastewaters.  Removal  of pollutants prior  to biological treatment  is known as
  pretreatment.

      The  successful  treatment of wastewaters  of  the  OCPSF industries  primarily
 depends on effective physical-chemical pretreatment  of wastewaters,  the abil-
 ity to acclimate biological organisms to the  remaining pollutants in  the waste
 stream (as in activated sludge processes),  the year-round operation of the
 treatment system at an efficient removal rate, the resistance of the  treatment
 system to toxic or inhibitory concentations, and the stability of the treat-
 ment system during variations in the waste loading (i.e., changes in product
 mixes).

      However, as  discussed earlier in this section, the Agency determined that
 a subset  of OCPSF plants, based  on their low raw waste BOD5  levels,  did not
 necessarily require  biological treatment to comply with BPT  effluent limita-
 tions.   Some of these plants produced chlorinated hydrocarbons that  typically
 generate 'wastewater  characterized,  by low raw waste BOD5  concentrations.   In
 these cases, biological treatment  would  not be effective in  treating refrac-
 tory priority pollutants  that  would  not  be  amenable to biodegradation.  There-
 fore, the  Agency decided  that  separate BAT  effluent limitations based  on  the
 performance of physical-chemical treatment  technologies  only were appropriate
and has established a separate subcategory  for these  plants based on  their
unique raw wastewater characteristics and treatability.

     The Agency also maintains that similar  toxic pollutant effluent concen-
trations can be achieved by plants  in differing BPT subcategories, i.e.,
                                    IV-38

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plants with different product mixes, by installing the best available treat-
ment technologies.  These toxic pollutants are being controlled using a combi-
nation of in-plant and end-of-pipe treatment technologies.  The in-plant
controls are based upon specific pollutants or groups of pollutants identified
in waste streams and controlled by, technologies for which treatment data are
available or transferred with appropriate basis (see Section VII of this docu-
ment).  Thus, subcategory groupings of plants based on product mix for BAT are
not appropriate.  Nevertheless, the Agency has attempted  to perform a quanti-
tative assessment of treatability of BAT  toxic pollutants by BPT subcategory
classification.  The capability to perform this assessment is limited because
the frequency of occurrence  of BAT  toxic  pollutants is determined by the pres-
ence of specific product/processes  (or reaction chemistry) within plants that
is not  totally  dependent on  BPT subcategory classifications.  Table IV-1 pre-
sents a comparison  of  toxic  pollutant mean effluent concentrations achieved by
100 percent  plastics and organics .plants  contained in  the final, edited BAT
toxic pollutant data base  that were used  in  the calculation  of  BAT effluent
limitations. Also  included is  thetsame comparison between those 100 percent
"pure"  BPT  subcategory plants  contained  in  the  same data base.   The  first
comparison  shows  that, with the  exception of  two  pollutants  (#10 and  #32),
plastics  and organics  plants achieve effluent concentrations that  approach the
analytical  minimum level.   The same results  are found  for the second  "pure"
subcategory comparison, even though fewer plants  were  available for  the analy-
sis.   For the two pollutants with disparate results,  the Agency believes that
 these differences are not  the result of  dissimilar wastewater treatability,
 but a lack of effluent concentration data for these pollutants from 100 per-
 cent plastics plants.   EPA notes that when more than one 100 percent plastics
 plant is available for comparison (e.g., pollutant #86),'the effluent concen-
 trations are similar.

      In addition to each OCPSF plant's ability to achieve similar effluent
 concentrations, the Agency  also believes that its extensive BAT toxic pollu-
 tant data base is  representative of OCPSF: wastewaters, treatment technologies,
 processes, and products.  In total, 186  plants were sampled in  the Agency's
 screening, verification, 5-plant, and 12-plant studies.  After editing the
 data base so that  only quality data (i.e., having adequate QA/QC) representing
 BAT treatment  were used,  the editedJBAT  data base contains sampling data for
                                      IV-39

-------
                           TABLE IV-1.
BAT EFFLUENT ESTIMATED LONG-TERM AVERAGE CONCENTRATION COMPARISON
             BETWEEN PLASTICS AND ORGANICS  PLANTS AND
                   PURE BPT SUBCATEGORY PLANTS
Plant
Numbers ?
Plastics
883
2221
4051 10
1349
1617
2536
Organ! cs
12 10
296 10
444 10
1609 10
1753
2394
2693
3033
Thermoplastics
883
1617
4051 10
2536
1349
Thermosets
2221
Bulk Organics
444 10
Specialty Organics
1753
Concentrations (ppb) by
Pollutant Number
10 32 38 65 86 "
Plastics vs. Organics
10
10 10 10
1016 923 - _ 103
10
10 10

10 12 10
12 - - 10 10
10
10 18
10
10 59 10
10 13 I 15 I
Pure Subcategory

10
10
1016 923 - _ 103
10 10-

- - 10 10 10
10

10

87
16

10

16

_


-
IV-40

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36 OCPSF plants (including industry supplied data) representing 232 product/
processes.  These 36 plants account for approximately 26 percent of production
volume and 24 percent of the process wastewater flow of the entire industry.
The types of product/processes utilized by these 36 plants represent approxi-
mately 13 percent of the types of OCPSF product/processes in use.  Since the
products manufactured by these facilities are manufactured at other OCPSF
facilities, the data obtained from these plants represent even greater per-
centages of total industry production and flow.  Thus, about 68 percent of
OCPSF industry production (in total pounds)  is represented and about 57 per-
cent of  the OCPSF industry wastewater is accounted  for by the products and
processes utilized  by  the 36 plants in  the limitations data base.  Products
that could be manufactured by the  232 product/processes utilized  at or manu-
factured by the  36  plants account  for 84 percent  of industry  production and
76  percent of process  wastewater.

     The OCPSF  industry manufactures more  than 20,000 individual  products;
however, overall production  is  concentrated  in a  limited  number  of high-volume
chemicals.  Excluding consideration of  plastics,  resins,  and  synthetic fibers,
EPA has identified  36 organic chemicals that are  manufactured in quantities
greater than  1  billion pounds per year.  These chemicals  are  referred to as
 commodity chemicals.  Two hundred eighteen organic chemicals  are manufactured
 in quantities between 40 million and 1 billion pounds per year.   These chemi-
 cals are referred to as bulk chemicals.  Together, these 254 chemicals account
 for approximately 91 percent of total annual production volume of organic
 chemicals as reported in the 308 Questionnaire survey data base for the OCPSF
 industry.  By sampling OCPSF plants that manufacture many of these high-volume
 chemicals, as well, as other types of OCPSF  plants, EPA has, in fact, gathered
 sampling data that are representative of production in the entire industry.

      Based on the results of its  comparison analysis and the adequate coverage
 of the  OCPSF industry  in its sampling  programs,  the Agency believes that
 plants  within each  of  its BAT subcategories can achieve BAT effluent limita-
 tions despite differing product/process mix.

      The Agency has also determined that because  of  their unique high raw
 wastewater zinc characteristics and treatability  noted in Sections V and VII,
                                      IV-41

-------
 respectively, producers of rayon by  the viscose process and acrylic fibers by
 the zinc chloride/solvent process will receive different BAT effluent limita-
 tions for zinc than the remainder of the OCPSF industry, whose BAT limitations
 will be based on the performance of chemical precipitation technology used in
 the Metal Finishing Point Source Category.

         c.   Energy and Non-Water Quality Aspects
      Energy and non-water quality aspects include the following:

      •  Sludge production
      •  Air pollution derived from wastewater generation and  treatment
      •  Energy consumption due to wastewater generation and  treatment
      •  Noise from  wastewater treatment.

The basic treatment step,  used by virtually  all plants  in all subcategories
that generate raw wastes containing basically BOD5 and  TSS, is biological
treatment.  Therefore,  the generation of sludges, air pollution, noise, and
the consumption of  energy will be homogeneous across the industry.  However,
the levels of these factors will  relate to the volume of wastewater treated'
and their associated pollutant  loads.  Since  the volumes of wastewater gener-
ated and wastewater characteristics were considered in earlier sections, it is
believed that all energy and nonwater quality aspects have been adequately
addressed in  this final subcategorization approach.
                                   IV-42

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                                  SECTION V                            '•-•-'-
        .          WATER USE AND WASTEWATER CHARACTERIZATION

A.  WATER USE AND SOURCES OF WASTEWATER
     The Organic Chemicals, Plastics, and .Synthetic Fibers (OCPSF) industry
uses large volumes of water in the manufacture of products.  Water use and
wastewater generation occur at a number of points in manufacturing processes
and ancillary operations, including:  1) direct and indirect contact process
water; 2) contact and noncontact cooling water; 3) utilities, maintenance, and
housekeeping waters; and 4) waters from air pollution control systems such as
Venturi scrubbers.

     The OCPSF  effluent limitations  and standards apply  to  the  discharge  of
"process wastewater," which  is defined as any water that, during manufacturing
or  processing,  comes into direct contact with or  results from  the production
or  use of any  raw material,  intermediate product, finished  product,
by-product,  or  waste product (40 CFR 401.11(q)).  An  example of direct  contact
process wastewater  is  the  use of aqueous  reaction media. The  use of water as
a medium  for certain chemical processes  becomes a major  high-strength process
wastewater  source after the  primary reaction has been completed and the final
product has been separated from the water media,  leaving residual product and
unwanted  by-products  formed  during secondary reactions in solution.

      Indirect contact  process wastewaters,  such as  those discharged from
 vacuum jets and steam ejectors,  involve the recovery of solvents and volatile
 organics  from the chemical reaction kettle.  In using vacuum jets, a stream of
 water is  used to create a vacuum,  but also draws off volatilized solvents and
 organics from the reaction kettle into solution.  Later, recoverable solvents
 are separated and reused while unwanted volatile organics remain in solution
 in the vacuum water,  which is discharged as process wastewater.  Steam ejector
 systems are similar to vacuum jets  with steam being substituted  for water.
 The steam  is then drawn off  and condensed  to form a source  of  process
 wastewater.
                                       V-l

-------
       The major volume of water used in the OCPSF industry is cooling water.
  Cooling water may be contaminated,  such as contact cooling water (considered
  process wastewater)  from barometric condensers,  or uncontaminated noncontact
  cooling water.   "Noncontact cooling water" is defined  as  water used for
  cooling that  does not come into direct contact with any raw material,  inter-
  mediate product,  waste product,  or  finished product (40 CFR 401.11(n)).
  Frequently, large volumes  of noncontact  cooling  water  may be used on a once-
  through basis and discharged after  commingling with process  wastewater.  Many
  of the  wastewater characteristics reported  by plants in the  data  bases were
  based on flow volumes  that  included  both process wastewater  and nonprocess
 wastewater such as noncontact cooling water.   Other  types  of nonprocess
 wastewater include:  boiler  blowdown, water  treatment wastes, stormwater,
 sanitary waste, and steam condensate.  An adjustment of the reported volumes
 of the effluents was therefore required to arrive at performance of treatment
 systems and other effluent characteristics.

      This adjustment was made by eliminating the uncontaminated cooling water
 volume from the total volume, to arrive at the contaminated wastewater flow at
 the sampling site.  The concentrations of the conventional pollutants BOD5,
 COD,  TSS,  and  TOC were adjusted using the simplifying judgment  that the
 uncontaminated cooling water did not contribute to  the  pollutant level.
 However, it  should be noted that in  some cases noncontact  cooling water can
 contribute pollutant  loading, especially to typically low-strength plastics
 and synthetic  materials wastewaters.

      In  some cases, effluent  priority pollutant and  daily  conventional
 pollutant data submitted  by  plants were  from  sample  sites  that  included
 nonprocess wastewater.  Where this dilution with noncontact cooling water or
 other nonprocess wastewater was significant  (i.e., >25 percent of  total), such
 data were considered nonrepresentative of actual treatment  systems' daily
 performance and were excluded from the data base used for assessing treatment
system performance variability factors.
                                     V-2

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B.   WATER USE BY MODE OF DISCHARGE
     Industry process wastewater flow descriptive statistics are summarized in
Table V-l for 929 OCPSF plants that submitted sufficient information in the
1983 Section 308 Questionnaire.  This data base is classified by direct,
indirect, or zero discharge status.  "Zero" discharge methods include no
discharge, land application, deep well injection, incineration, contractor
removal, evaporation, off-site treatment by a privately owned treatment
system, and discharge to septic and leachate fields.

     Some of the plants  in  the 308 data base discharge waste streams by more
than one method.  However,  for purposes of  tabulating wastewater data, each
plant was assigned  to a  single discharge category  (i.e., no double counting
appears  in  the  direct,  indirect,  and  zero discharge  data columns). A  plant
was classified  as a zero or alternate discharger only  if all of its waste
streams  were reported as zero  or  alternate  discharge streams.   Plants  were
classified  as  direct dischargers  if  at least  one  process wastewater stream was
direct.   Plants whose process  wastewater  streams  were discharged to publicly
owned  treatment works (POTWs)  were classified as  indirect  dischargers.  Many
of the indirect discharge  plants  discharge noncontact cooling water directly
 to surface waters.

      Industry nonprocess wastewater flow descriptive statistics are summarized
 in Table V-2 for 718 OCPSF plants as classified in Table V-l by process
 wastewater discharge status.

 C.   WATER USE BY  SUBCATEGORY
      As discussed  previously in Section IV, data relating  product/process
 production information  to  flow was requested from industry in  the 1983 Section
 308 Questionnaire  to facilitate  the  flow proportioning of  individual  product
 subcategory limitations for multiple  subcategory plants.   This information
 would have also facilitated the  presentation of the wastewater flow data by
  subcategory.   Unfortunately, much of  the production/flow  information  (when
  supplied) was  either estimated or grouped  with other product/process  flows  and
  was considered too inaccurate or nebulous  for use.   Since this information
                                       V-3

-------
                                    TABLE V-l.
                       TOTAL OCPSF PLANT PROCESS VASTEWATER
                    FLOW CHARACTERISTICS BY TYPE OF DISCHARGE
                                            Process tfastewater
                                             Discharge  Status
                                        Direct
Indirect
      Descriptive Statistics
 Number of Plants*
 Percentage of Plants
 Total Flow (MGD)
 Average Flow (MGD)
 Median Flow (MGD)
 Frequency Counts (ft of Plants)
   By Flow Range
 <0.005 MGD
 0.005  to  0.01  MGD
 >0.01  to  0.10  MGD
 >0.10  to  0.50  MGD
 >0.5 to 1.0 MGD
 >1.0 to 5.0.MGD
 >5.0 to 10.0 MGD
 >10 MGD (up to a maximum of 19.3 MGD)
*(N) « 929 out of 940 scope facilities
Source:  1983 Section 308 Questionnaire Responses
                                                                Zero
304
33%
387
1.31
0.40
393
422
94
0.25
0.04
232
25%
32
0.24
0.007
25
12
54
80
43
75
8
7
106
34
136
77
26
12
1
1
161
11
30
16
4
10
0
0
                                     V-4

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                                 TABLE V-2.
                  TOTAL OCPSF PLANT NONPROCESS WASTEWATER
                 FLOW CHARACTERISTICS  BY TYPE OF DISCHARGE
                                       Nonprocess Wastewater
                                          Discharge Status
                                      Direct
Indirect
Frequency Counts (# of Plants)
  By Flow Range
                                                              Zero
Descriptive Statistics
Number of Plants*
Percentage of Plants
Total Flow (MGD)
Average Flow (MGD)
Median Flow (MGD)

278
39%
3,973
14.29
0.40

332
46%
353
1.06
0.03

108
15%.
103
0.95
0.05
<0.005 MGD
0.005 to 0.01 MGD
>0.01 to 0.10 MGD
>0.10 to 0.50 MGD
>0.5 to 1.0 MGD
>1.0 to 5.0 MGD
>5.0 to 10.0 MGD
>10 MGD (up to a maximum of 1,732 MGD)
11
14
53
77
32
42
12
37
76
36
117
56
22
19
3
3
21
16
34
20
8
5
1
3
 *(N)  =  718  out  of  940 scope  facilities  reporting  discharge  of  nonprocess
  wastewater

 Source:  1983 Section 308 Questionnaire Responses
                                      V-5

-------
  could not be used to group these flow data accurately, the Agency has decided
  to present these data using two methodologies.  The first method utilizes an
  approach similar to the regression model used for subcategorization to
  proportion these data among subcategories.   The second methodology places
  individual plants completely in one of the  seven final subcategories based on
  a prescribed set of rules.   These two methodologies are discusssed in more
  detail in the following sections.

      Tables  V-3  through V-16  provide the 1980 process  and nonprocess
  wastewater flow  statistics  by subcategory and disposal method.   Tables V-3
  through V-9  present  separate  tabulations for  primary and  secondary  producers
  and for process  and  nonprocess wastewater.  In each  table,  the mean and median
  flows  for  multi-subcategory plants have  been  divided into  subcategories using
  the regression methodology described  in  Section IV based on plant production
 volume proportions for each subcategory.  Thus, mean and median  flows given in
 some cases may not represent actual plant subcategory  flow since, on a unit of
 production basis, different products produce different flow volumes.  However,
 data constraints preclude direct attribution of process and nonprocess flows
 to individual products or product subcategory groups.  Production weighted
 mean subcategory flow values were calculated using the following formula:

      Production Weighted Mean =  PiFi  + P2F2  + P3F3 + ••• + piFi
     Where:

     Px  =  Decimal  subcategory  proportion  of  total  OCPSF  plant  production  for
            plant  #1 (range  =  0  to  1.0)
     Fj  =  Total  process  flow for  plant  #1.

     In determining  the median,  the wastewater flow  of each plant  that has  at
least one product within a subcategory are  ranked from lowest to highest.   The
subcategory decimal  production proportions  are summed starting from the lowest
flow plant until the sum equals or exceeds  50 percent of the total of all the
decimal production proportions.  The wastewater flow of the plant whose
proportions when added to the proportion sum causes  the total to exceed
                                     V-6

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                    TABLE  V-3
PROCESS WASTEWATER FLOW FOR PRIMARY OCPSF PRODUCERS
         BY SUBCATEGORY AND DISPOSAL  METHOD
                 DIRECT DISCHARGERS
SUBCATEGORY

THERMOPLASTICS
THERHOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGAN I CS
MEAN
(MGD)
1.00
0.71
8.04
1.14
2.16
1.53
0.84
MEDIAN
(MGD)
0.43
0.08
8.57
0.57
1.00.
0.29
0.30
STANDARD
DEVIATION
1.70 '
1.66
2.98
2.31
3.73
3.43
1.74
NUMBER OF
OBSERVATIONS.
60.99
12.10
3.19
13.73
48.85
47.53
41.61
NUMBER OF
PLANTS
104
31
5
22
84
113
103
INDIRECT DISCHARGERS
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGAN ICS
MEAN
(MGD)
0.25
0.08
0.05
0.57
0.48
0.34
MEDIAN
(MGD)
0.05
0.02
0.02
0.04
0.05
0.06
STANDARD
DEVIATION
0.65
0.28
0.06
1.71
1.15
1.49
NUMBER OF
OBSERVATIONS
68.57
40.97
7.00
18.43
33.71
106.31
NUMBER OF
PLANTS
108
80
8
36
84
154
                   V-7

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                                 TABLE  V-4
           PROCESS WASTEWATER FLOW DURING 1980  FOR SECONDARY OCPSF
                 PRODUCERS BY SUBCATEGORY AND DISPOSAL METHOD
                              DIRECT DISCHARGERS
  SUBCATEGORY


 THERMOPLASTICS    0.15

 THERMOSETS

 ORGAN ICS



  SUBCATEGORY


 THERMOPLASTICS

 THERMOSETS

ORGANICS
MEAN
(MGD)
0.15
0.50
0.70

MEAN
(MGD)
0.03
0.03
0.11
MEDIAN
(MGD)
0.08
0.01
0.20
INDIRECT
MEDIAN
(MGD)
0.01
0.00
0.02
STANDARD
DEVIATION
0.26
0.93
1.27
DISCHARGERS
STANDARD
DEVIATION '
0.05
0.08
0.18
NUMBER OF
OBSERVATIONS
8.68
4.03
28.29

NUMBER OF
OBSERVATIONS
16.59
20.90
52.51
NUMBER OF
PLANTS
12
5
30

NUMBER OF
PLANTS
27
30
58
                             V-8

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                     TABLE V-5
    PROCESS WASTEWATER FLOW FOR  PRIMARY & SECONDARY
OCPSF PRODUCERS THAT ARE ZERO/ALTERNATIVE DISCHARGERS
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGAN I CS
MEAN
(MGD)
0.08
0.01
0.42
0.33
0.91
0.31
0.16
MEDIAN
(MGD)
0.01
0.00
0.03
0.08
0.91
0.30
0.11
STANDARD
DEVIATION
0.26
0.08
0.93
0.98
•
0.37 ;
0.19
NUMBER OF
OBSERVATIONS
24.92
33.11
60.71
2.31
0.84
1 .30
2.81
NUMBER OF
PtANTS
36
40
69
3
1
3
4
                  V-9

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                                  TABLE V-6
                     NON-PROCESS WASTEWATER FLOW DURING 1980
                         FOR SECONDARY OCPSF PRODUCERS
                        AND ZERO/ALTERNATIVE DISCHARGERS
                        BY SUBCATEGORY & DISPOSAL METHOD

                     SECONDARY AND DIRECT DISCHARGE PLANTS
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
ORGAN I CS
MEAN
(MGD)
0.320
0.242
3.564
MEDIAN
(MGD)
0.190
0.250
0.255
STANDARD
DEVIATION
0.760
0.242
11.546
SECONDARY AND INDIRECT DISCHARGE
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
ORGAN I CS

SUBCATEGORY

THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
MEAN
(MGD)
0.072
0.458
1.240
SECONDARY
MEAN
(MGD)
0.242
0.101
0.658
6.455
MEDIAN
(MGD)
0.005
0.020
0.015
AND OTHER
MEDIAN
(MGD)
0.013
0.019
0.031
0.710
STANDARD
DEVIATION
0.206
1.179
6.470
NUMBER OF
OBSERVATIONS
8.72
1.03
27.25
PLANTS
NUMBER OF
OBSERVATIONS
19.50
17.99
46.51
NUMBER OF
PLANTS
12
2
29

NUMBER OF
PLANTS
29
27
52
DISCHARGE PLANTS*
STANDARD
DEVIATION
1.367
0.184
2.960
20.921
NUMBER OF
OBSERVATIONS
18.00
27.01
47.67
1.31
NUMBER OF
PLANTS
26
33
57
2
NOTE: THERE ARE 9 PRIMARY PLANTS NOT INCLUDED IN THIS TABLE
THAT ARE ZERO DISCHARGERS.
                             V-10

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                      TABLE V-7
   TOTAL OCPSF NON- PROCESS WASTEWATER FLOW IN 1980
FOR PRIMARY PRODUCERS BY  SUBCATEGORY & DISPOSAL METHOD
                  DIRECT  DISCHARGERS
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MEAN
( MGD )
9.266
5.228
2.295
9.279
55.125
21.990
8.142
MEDIAN
( MGD )
0.280
0.450
2.500
1.910
0.720
0.475
0.200
STANDARD
DEVIATION
67.664
62.392
4.263
17.113
232.600
128.821
42.871
NUMBER OF
OBSERVATIONS
58.905
11.904
2.187
11.851
45.738
46.253
35.162
NUMBER OF
PLANTS
101
33
4
19
78
108
96
INDIRECT DISCHARGERS
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
( MGD )
0.211
0.141
0.077
3.434
4.808
0.418
DISCHARGERS
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
( MGD )
0.027
0.000
0.150
14.560
MEDIAN
< MGD )
0.027
0.020
0.024
0.311
0.064
0.043
OTHER THAN
. MEDIAN
( MGD )
0.010
0.000
0.150
0.150
STANDARD
DEVIATION
1 .326
0.738
. 0.090
11.510
21.021
1.765
NUMBER OF
OBSERVATIONS
55.056
29.003
4.002
15.329
27.823
74.786
NUMBER OF
PLANTS
85
62
5
30
67
116
DIRECT OR INDIRECT
STANDARD
DEVIATION
0.026
.
.
24.171
NUMBER OF
OBSERVATIONS
2.122
0.878
0.208
2.792
NUMBER OF
PLANTS
3
1
1
3
                        V-ll

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                  TABLE V-8
   NON-PROCESS COOLING WATER  FLOW  FOR PRIMARY
OCPSF PRODUCERS BY SUBCATEGORY & DISPOSAL METHOD
               DIRECT  DISCHARGERS
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MEAN
( MGD
0.814
0,259
0.140
0.369
1.097
0.431
0.381
MEDIAN
> ( MGD )
0.182
0.063
0.120
0.337
0.537
0.100
0.077
STANDARD
DEVIATION
2.058
0.661
0.125
0.321
1.651
0.936
1.042
NUMBER OF
OBSERVATIONS
58.415
11.992
2.187
12.153
42.908
43.148
42.196
NUMBER OF
PLANTS
96
33
4
19
75
107
100
INDIRECT DISCHARGERS
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
( MGD 3
0.085
0.171
0.068
0.776
0.213
0.097
DISCHARGERS
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
( MGD )
0.065
0.004
0.121
0.039
0.023
MEDIAN
> ( MGD )
0.012
0.007
0.090
0.118
0.028
0.011
OTHER THAN
MEDIAN
( MGD )
0.043
0.004
0.121
0.003
0.003
STANDARD
DEVIATION
0.204
1.015
0.057
1.781
0.380
0.231
NUMBER OF
OBSERVATIONS
45.578
25.319
4.027
13.479
24.790
68.806
NUMBER OF
PLANTS
73
52
5
25
59
99
DIRECT OR INDIRECT
STANDARD
DEVIATION
0.039
.
.
.
0.036
NUMBER OF
OBSERVATIONS
2.168
0.878
0.838
0.302
2.815
NUMBER OF
PLANTS
4
1
1
2
4
                  V-12

-------
                        TABLE V-9
OCPSF MISCELLANEOUS NON-COOLING NON-PROCESS WASTEWATER FLOW
   FOR PRIMARY PRODUCERS BY SUBCATEGORY  &  DISPOSAL HETHOO
                     DIRECT DISCHARGERS
SUBCATEGORY
'-
THERMOPLASTICS ,
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MEAN
( MGD; )
9.474
4.956
1.671
9.288
52.918
20.449
6.504
MEDIAN
( MGD )
0.485
0.290
0.240
1.585
1 .400
0.660
0.233j
STANDARD
DEVIATION
66.066
59.320
3.467
16.800
226.990
123.687
37.616
NUMBER OF
OBSERVATIONS
62.632
13.183
3.187
12.323
48.535
50.649
46.491
NUMBER OF
PLANTS
107
36
5
' 20
84
118
111
INDIRECT DISCHARGERS
SUBCATEGORY


THERMOPLASTICS
:THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
( MGD >

0.242
0.236
0.116
3.727
4.365
0.434
DISCHARGERS
SUBCATEGORY

THERMOPLASTICS
THERMOSETS ;
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
( MGD )
0.063
0.004
0.121
0.143
14.466
MEDIAN
( MGD }

0.030
0.025
0.063,
0.639
0.106
0.069
OTHER THAN
MEDIAN
( MGD )
0.090
0.004
0.121
0.153
0.153
STANDARD
DEVIATION
• -• t
1.318
1.088
0.130
11.519
19.798
1.708
NUMBER OF
OBSERVATIONS

64.020
35.707
5.002
16.932
31.855
87.483
NUMBER OF
' PLANTS

100
72
6
32
75
131
DIRECT OR INDIRECT
STANDARD
DEVIATION
0.048
"
•
. •
24.107
NUMBER OF
OBSERVATIONS
3.168
0.878
0.838
0.302
2.815
NUMBER OF
PLANTS
5
1
1
2
4
                          V-13

-------
   SUBCATEGORY
   THERMOPLASTICS
   THERHOSETS
   RAYON
   FIBERS
   COMMODITY ORGAN ICS
   BULK ORGANICS
   SPECIALTY ORGANICS
  MIXED
 SUBCATEGORY
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
                                             TABLE V-10
                         PROCESS WASTEWATER FLOW FOR PRIMARY OCPSF PRODUCERS
                                  BY SUBCATEGORY AND DISPOSAL METHOD
                                          DIRECT DISCHARGERS
                                         < 95% & 70% RULES  )
TOTAL
FLOW
(MGD)'
24.884
3.080
24.639
7.422
25.909
27.146
16.985
194.299
MIN
(MGD)

0.02100
0.00001
5.03000
0.24300
0.00144
0.00020
0.00075
0.00002
MAX
(MGD)

3.450
2.680
11.039
1.482
3.890
18.000
3.450
19.323
MEAN
(MGD)

0.61
0.51
8.21
0.82
0.96
1.04
0.59
2.23
MEDIAN
(MGD)

0.31
. 0.09
8.57
0.63
0.66
0.11
0.26
0.85
STANDARD
DEVIATION

0.73
1.06
3.02
0.46
1.04
3.49
0.91
3.68
NUMBER OF
PLANTS

41
6
3
9
27
26
29
87
INDIRECT DISCHARGERS

TOTAL
FLOW
(MGD)
8.0439
0.7884
0.3768
11.4154
8.1822
32.4242
22.3383
( 95X
MIN
(MGD)

0.0000070
0.0001000
0.0003000
0.0078000
0.0007000
0.0000100
0.0000343
& 70X RULES )
MAX
(MGD)

1.240
0.350
0.160
7.970
2.963
15.439
4.840
MEAN
(MGD)

0.16
0.05
0.05
1.14
0.48
0.36
0.26
MEDIAN
(MGD)

0.05
0.00
0.02
0.28
0.05
0.07
0.03
STANDARD
DEVIATION

0.27
0.10
0.06
2.46
0.92
1.63
0.74 ft
NUMBER OF
PLANTS

49
16
7
10
17
90
86
                                         V-14

-------
                      TABLE V-11
PROCESS WASTEWATER FLOW DURING  1980 FOR SECONDARY OCPSF
      PRODUCERS BY SUBCATEGORY  AND DISPOSAL METHOD
                     < 95  % RULE  )
                   DIRECT  DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED

SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
MINIMUM
(MGD)
0.00016
0.00369
0.00001
0.75000

MINIMUM
(MGD)
0.000300
0.000054
0.000050
0.000200
MAXIMUM
(MGD)
0.20
1.90
4.70
0.97
( 95
INDIRECT
MAXIMUM
(MGD)
0.0920
0.1400
0.6300
0.5585
MEAN
(MGD)
0.08
0.50
0.69
0.86
MEDIAN
(MGD)
0.05
0.06
0.17
0.86
STANDARD
DEVIATION
0.08
0.93
1.30
0.16
NUMBER OF
OBSERVATIONS
8
4
27
2
X RULE )
DISCHARGERS
MEAN
(MGD)
0.02
0.02
0.10
0.07
MEDIAN
(MGD)
0.01
0.00
0.02
0.01
STANDARD
DEVIATION
0.03
0.04
0.17
0.15
NUMBER OF
OBSERVATIONS
11
15
48
16
                       V-15

-------
                                      TABLE V-12
                     PROCESS WASTEWATER  FLOW  FOR PRIMARY & SECONDARY
                 OCPSF PRODUCERS  THAT  ARE ZERO/ALTERNATIVE DISCHARGERS
                                  ( 95%  & 70% RULES )
 SUBCATEGORY
 THERMOPLASTICS

 THERMOSETS

 ORGANICS

 FIBERS

 COMMODITY ORGANIC!

 BULK ORGANICS

SPECIALTY ORGANICS    0.00450

MIXED
MINIMUM
(MGD)
0.00001
0.00004
0.00000
0.00010
0.90700
0.29700
0.00450
0.00006
MAXIMUM
(MGD)
0.34
0.02
4.40
0.08
0.91
0.30
0.33
2.20
MEAN
(MGD)
0.05
0.00
0.40
0.04
0.91
0.30
0.15
0.33
MEDIAN
(MGD)
0.01
0.00
0.03
0.04
0.91
0.30
0.11
0.01
STANDARD
DEVIATION
0.09
0.00
0.94
0.06
•
•
0.16
0.70
NUMBER OF
PLANTS
21
27
55
2
1
1
3
16
                                      V-16

-------
                                  TABLE V-13
                     NOW-PROCESS WASTEWATER FLOW DURING 1980
                         FOR SECONDARY OCPSF PRODUCERS
                        AND ZERO/ALTERNATIVE DISCHARGERS
                        BY SUBCATEGORY & DISPOSAL METHOD
                              ( 9SX & 70% RULES )

                     SECONDARY lAND DIRECT DISCHARGE PLANTS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED

SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAMICS
MIXED
MINIMUM
(MGD)
0.00165
0.25000
0.00200
0.19000
SECONDARY
MINIMUM
(MGD)
0.00010
0.00090
0.00010
0.00050
MAXIMUM MEAN
(MGD) (MGD)
0.710 0.234
0.250 0.250
59.800 3.500
7.600 3.510
MEDIAN
(MGD)
0.120
0.250
0.125
2.740
STANDARD
DEVIATION
0.289
12.038
3.765
NUMBER OF
PLANTS
8
1
25
3
( 95% & 70% RULES )
AND INDIRECT DISCHARGE PLANTS
MAXIMUM MEAN
(MGD) (MGD)
0.250 0.037
5.000 0.492
44.100 1.317
2.100 0.341
MEDIAN
(MGD)
0.003
0.007
0.012
0.059
STANDARD
DEVIATION
0.072
1.372
6.806
0.590
NUMBER OF
PLANTS
14
13
42
15
( 95% & 70% RULES )
SECONDARY AND OTHER DISCHARGE PLANTS*
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
MIXED
MINIMUM
(MGD)
0.00050
0.00171
0.00001
0.71000
0.08370
MAXIMUM MEAN
(MGD) (MGD)
1.500 0.136
0.590 0.092
5.750 0.360
0.710 0.710
24.700 1.935
MEDIAN
(MGD)
0.010
0.020
0.028
0.710
0.076
STANDARD
DEVIATION
0.381
0.156
0.934
6.559
NUMBER OF
PLANTS
15
22
42
1
14
NOTE: THERE ARE 9 PRIMARY PLANTS NOT INCLUDED IN THIS TABLE
THAT ARE ZERO DISCHARGERS.
                                   V-17

-------
                       TABLE V-14
   TOTAL OCPSF NON-PROCESS WASTEWATER FLOW  IN 1980
FOR PRIMARY PRODUCERS BY SUBCATEGORY & DISPOSAL METHOD
                  DIRECT DISCHARGERS
                 ( 95% & 705! RULES )
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MIXED
MINIMUM
( MGD )
0.00022
0.00007
0.14000
0.07200
0.00200
0.00521
0.00266
0.00010
MAXIMUM
( MGD }
30.744
15.605
2.500
44.364
648.000
38.400
15.626
1731.700
MEAN
( MGD )
2.106
2.659
1.320
10.727
25.595
3.267
1.842
43.023
MEDIAN
( MGD )
0.212
0.218
1.320
4.526
0.409
0.269
0.179
1.281
STANDARD
DEVIATION
5.603
5.741
1.669
15.621
126.949
8.123
3.613
195.531
NUMBER OF
PLANTS
39
7
2
8
26
25
22
83
INDIRECT DISCHARGERS

SUBCATEGORY

THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED


SUBCATEGORY

THERMOPLASTICS
SPECIALTY ORGANICS
MIXED

MINIMUM
( MGD )
0.00000
0.00030
0.01770
0.00520
0.00290
0.00020
0.00010
DISCHARGERS

MINIMUM
( MGD )
0.01000
0.05000
0.00010
< 95% & 70%
MAXIMUM
( MGD )
1.490
0.335
0.210
47.146
111.260
8.830
11.157
OTHER THAN
( 95% & 70%
MAXIMUM
( MGD )
0.047
40.480
0.000
RULES )
MEAN
( MGD )
0.154
0.052
0.077
6.859
8.662
0.439
0.469
DIRECT OR
RULES )
MEAN
( MGD )
0.028
13.560
0.000

MEDIAN
( MGD )
0.021
0.012
0.040
1.159
0.060
0.063
0.030
INDIRECT

MEDIAN
( MGD >
0.028
0.150
0.000

STANDARD
DEVIATION
0.306
0.099
0.090
16.310
30.827
1.271
1.648


STANDARD
DEVIATION
0.026
23.313
m

NUMBER OF
PLANTS
40
11
4
8
13
61
69


NUMBER OF
PLANTS
2
3
1
                    V-18

-------
                  TABLE V-15
   NON-PROCESS COOLING WATER  FLOW FOR PRIMARY
OCPSF PRODUCERS BY SUBCATEGORY & DISPOSAL METHOD
               DIRECT DISCHARGERS
              ( 95% & 70% RULES )
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MIXED
MINIMUM
( MGD }
0.00414
0.00007
0.10000
0.08300
0.00500
0.00165
0.00001
0.00070
MAXIMUM
( MGD )
10.045
1.072
0.120
1.086
3.167
3.300
2.303
12.400
MEAN
< MGD )
0.736
0.290
0.110
0.411
0.884
0.277
0.229
0.843
MEDIAN
( MGD )
0.177
0.038
0.110
0.325
0.468
0.078
0.041
0.288
STANDARD
DEVIATION
1 .969
0.441
0.014
0.351
0.999
0.699
0.456
1.791
NUMBER OF
PLANTS
40
7
2
8
24
22
29
81
INDIRECT DISCHARGERS

SUBCATEGORY

THERMOPLASTICS.
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED

MINIMUM
( MGD )
0.00009
0.00010
0.00731
0.02814
0.00300
0.00004
0.00001
( 95% & 70%
MAXIMUM
< MGD )
0.890
0.029
0.135
2.758
0.999
1.600
8.000
DISCHARGERS OTHER THAN

SUBCATEGORY

THERMOPLASTICS
COMMODITY ORGANICS
SPECIALTY ORGANICS
MIXED

MINIMUM
< MGD )
0.04300
0.12100
0.00120
0.00400
( 95% & 70%
MAXIMUM
( MGD )
0.092
0.121
0.060
0.004
RULES )
MEAN
( MGD )
0.077
0.009
0.067
0.786
0.172
0.096
0.247
DIRECT OR
RULES )
MEAN
( MGD )
0.067
0.121
0.021
0.004

MEDIAN
( MGD )
0.012
0.006
0.063
0.481
0.014
0.011
0.016
INDIRECT

MEDIAN
( MGD )
0.067
0.121
0.003
0.004

STANDARD
DEVIATION
0.194
0.009
0.057
0.931
0.320
0.232
1.074


STANDARD
DEVIATION
0.035
•
0.034


NUMBER OF
PLANTS
34
9
4
8
13
58
56


NUMBER OF
PLANTS
2
1
3
1
                     V-19

-------
                        TABLE V-16
OCPSF MISCELLANEOUS WON-COOLING  NON-PROCESS WASTEWATER FLOW
   FOR PRIMARY PRODUCERS BY SUBCATEGORY & DISPOSAL METHOD
                     DIRECT DISCHARGERS
                    ( 95% & 70%  RULES >
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGAN I CS
SPECIALTY ORGAN I CS
MIXED
MINIMUM
( MGD )
0.00100
0.00015
0.12000
0.22100
0.01200
0.00521
0.00031
0.00080
MAXIMUM
( MGD )
30.896
15.643
2.500
44.447
651.167
41.700
15.703
1739.330
MEAN
( MGD )
2.657
2.949
0.953
11.138
25.432
3.135
1.474
40.435
MEDIAN
( MGD )
0.396
0.290-
0.240
4.929
0.884
0.304
0.173
1.410
STANDARD NUMBER OF
DEVIATION PLANTS
6.235 42
5.687 7
1.341 3
15.500 8
125.062 27
8.264 28
3.097 32
188.898 90
INDIRECT DISCHARGERS ,

SUBCATEGORY

THERMOPLASTICS
THERHOSETS
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MIXED


SUBCATEGORY

THERMOPLASTICS
COMMODITY ORGANICS
SPECIALTY ORGANICS
MIXED

MINIMUM
( MGD )
0.00000
0.00010
0.02411
0.04480
0.00300
0.00004
0.00011
DISCHARGERS

MINIMUM
( MGD }
0.01000
0.12100
0.05120
0.00410
( 95% & 70%
MAXIMUM
( MGD )
2.380
0.350'
0.345
49.904
111.960
9.367
11.417
OTHER THAN
< 95% & 70%
RULES )
MEAN
( MGD >
0.187
0.047
0.115
6.795
7.178
0.449
0.592
DIRECT OR
RULES )
MAXIMUM MEAN
{ MGD )
0.092
0.121
40.540
0.004
( MGD )
0.064
0.121
13.581
0.004

MEDIAN .
( MGD )
0.028
0.018
0.063
0.898
0.081
0.080
0.052
INDIRECT

MEDIAN
( MGD )
0.090
0.121
0.153
0.004

STANDARD NUMBER OF
DEVIATION PLANTS
0.411 47
,0.092 14
0.131 5
16.218 9
27.944 16
1.286 72
1.797 78


STANDARD, NUMBER OF
DEVIATION PLANTS
0.047 3
1
23.347 3
1
                        V-20

-------
50 percent is then chosen as the.median.  If, however, the total equals
50 percent exactly, then the median is the average of the wastewater flow of
that plant and the next plant in the sequence.  The tables are divided into
primary and secondary producers because less detailed production data were
collected from secondary producers.  Likewise, less detailed data were
collected from both primary and secondary zero discharge plants.  Production
data are identified only by Standard Industrial Classification (SIC) code for
secondary or zero discharge producers, ,and thus the organics subcategories
(i.e., bulk, commodity, specialty) must be grouped together.

     In each table, the column for "Number of Plants" represents the total
number of plants for whom at least part of their  flow .was used to derive  the
subcategory statistics.  Therefore, double or multiple counting of  plants
occurs for multi-subcategory plants.  The column  for  "Number of Observations"
represents the sum of  plant subcategory production proportions.

     Tables V-10  through V-16 also provide 1980 process  and nonprocess
wastewater flow statistics  by subcategory and disposal  technique, but use a
different method  to aggregate plants  by subcategory.  Plants were placed  in
one of  five  categories (Thermoplastics, Thermosets, Rayon, Organics, Fibers)
if their  production was at  least 95  percent  contained in that  category.
Plants  having  less than 95  percent were placed  in a sixth category  (Mixed).
The organics  category was  then  further  subdivided into  three  subcategories
 (Commodity,  Bulk,  Specialty)  if the  plant's  organics  production was at  least
 70 percent  contained  in one of  the subcategories.  Plants with less than
 70 percent  production were  also placed  in the mixed  category.   As  with the
 tables  generated  using the  regression methodology,  production data are
 identified  only by SIC code for secondary or zero discharge producers,  and
 thus the organics subcategories (Commodity,  Bulk, Specialty)  were grouped
 together in the tables for these plants.

      Tables V-3 and V-4 provide process wastewater flow statistics for primary
 and secondary producers,  respectively,  with,each divided into direct and
 indirect dischargers using the regression methodology.  Tables V-10 and V-ll
 present the same flow statistics using the  95 percent production basis for
 assigning plants  to subcategories for the four nonorganics subcategories and
                                      V-21

-------
 the 70 percent organics production basis  for  the  three organics subcategories
 (95/70 methodology).  Table V-5 provides  process  wastewater flow statistics
 for the zero or alternate discharge plants using  the regression methodology,
 while Table V-12 presents the same flow statistics using the 95/70 methodology.
 Tables V-6 through V-9 provide 1980 flow  statistics for nonprocess wastewaters
 using the regression methodology, while Tables V-13 through V-16 present the
 same flow statistics using the 95/70 methodology.

      The data in each table are grouped by the disposal method of the plants'
 process wastewater.  In general, plants that discharge process wastewater
 directly will also discharge nonprocess wastewater directly.   However, in some
 cases,  plants that discharge process wastewater indirectly or by zero or
 alternate discharge methods may discharge their non-process wastewaters
 directly due to the generally lower treatment requirements of many nonprocess
 waste  streams.

     Tables  V-6 and V-13 provide the nonprocess flow statistics for secondary
 producers  and zero and alternate dischargers.   Tables  V-7  and  V-14 provide  the
 total nonprocess  flow statistics for primary producers, while  Tables  V-8
 through V-9  and Tables V-15  through  V-16  provide the portions  of  these flows
 that are composed  of cooling water versus  other miscellaneous  nonprocess
 wastewater.
           fr

     The cooling water in Tables V-8 and V-15  include both  once-through
 noncontact cooling water plus.cooling  tower  blowdown and for some plants may
 include other nonprocess wastewater where  flows  were reported as a  combined
 total.  It is evident  from these tables that cooling water  comprises  the major
 portion of nonprocess wastewater for most  plants and that direct dischargers
 produce greater quantities of nonprocess wastewater than indirect dischargers.

     In general, the summary statistics for wastewater flow by subcategory
 that were generated by the two methodologies compare favorably; all of the
differences between subcategory medians calculated by the two methodologies
fell within the standard deviations calculated by either methodology.  Reasons
for the differences include the inaccurate nature of assigning individual
plants to subcategories, i.e.,  the arbitrary assignment of plants based on the
                                     V-22

-------
95/70 rule, which was determined to be insufficient for previous sub-
categorization efforts, as well as the relative contribution of the extra 5 or
30 percent of other subcategories' flows .depending on if the plant is pre-
dominantly plastics or organics, respectively.  Based on the inherent
limitations of the 95/70 methodology, the Agency has much more confidence in
the utility of the regression methodology summary statistics, but has included
the 95/70  summary statistics for comparison purposes.

D.   WATER REUSE AND RECYCLE

     1.  Water Conservation and Reuse Technologies
     A variety of water  conservation practices  and  technologies are  available
to OCPSF plants.  Because  of  the  diversity within  the  industry, no one  set  of
conservation  practices is  appropriate  for all plants.   Decisions  regarding
water reuse and  conservation  depend  on  plant-specific  characteristics,  as well
as site-specific water supply and environmental factors (e.g.,  water avail-
ability,  cost, and  quality).  Therefore,  this  section will  describe  the  range
of practices  and technologies available for water  conservation.

      Conventional water  conservation practices  include (McGovern  1973;  Holiday
 1982);

      •   Recovery and reuse of steam condensates and process condensates, where
         possible
      •   Process  modifications to recover more product  and solvents
      •   Effective control of cooling-tower treatment and blowdown to optimize
         cycles of concentration
      •  Elimination of contact cooling for off vapors
      •  Careful monitoring of water uses; maintenance of raw water  treatment
         systems and prompt attention to faulty equipment, leaks,  and other
         problems
      •  Installation  of automatic monitoring and alarm systems on in-plant
         discharges.
                                      V-23

-------
 Table V-17 summarizes water conservation  technologies, and  their applications,
 limitations, and relative costs  to  industry plants.  Some of  these  technolo-
 gies, such as steam stripping, are  also considered effluent pollution control
 technologies.  Water conservation,  in fact, can often be a benefit  of mandated
 pollution control.

      2.  Current Levels of Reuse and Recycle
      Data on the amount of water reused and recycled in the OCPSF industry
 from the 1978 Census Bureau survey and the 1983 308 Questionnaires are
 presented in Tables V-18 and V-19, respectively.

      In Table V-18, the Census Bureau defines "recirculated or reused water"
 as the volume of water recirculated multiplied by the number of times the
 water was recirculated.   Seventy-nine percent of the OCPSF plants surveyed by
 the Census Bureau reported some recirculation or reuse of water.   Census
 Bureau statistics show that  the bulk of recirculated water is  used for cooling
 and condensing operations,  such as closed-loop cooling systems for heat
 transport.   Chemical algaecides and fungicides are routinely added to these
 cooling waters to prevent  organism growth  and  suppress  corrosion,  both of
 which can cause exchanger  fouling and reduction of heat  transfer  co-
 efficients.

      As  water evaporates and leaks from, such closed  systems, the  concentration
 of minerals  in these waters increases, which may lead  to  scale formation,
 reducing heat transfer efficiency.   To  reduce  such scaling,  a  portion of such
 closed system waters is periodically discharged as blowdown  and replaced by
 clean water.                             >
        t
      Table V-19 shows the 1980  recycle flow of process and nonprocess
wastewaters for OCPSF plants that are primary producers, excluding zero  and
alternate dischargers as reported  in  the 1983 Section 308 Questionnaire.  The
flow  rates shown were for wastewater streams where the final disposal method
was reported as recycle.  Thus, the data do not reflect the number of times
the wastewater is recycled (as  in Census Bureau data), nor do  they include
flow  in closed-loop systems such as cooling towers, since water in such
                                     V-24

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                                 V-28

-------
systems is not considered wastewater until it leaves the system as blowdown.
As a result of these differences, Table V-19 shows a much lower number of
plants reporting recycle.

     The fact that Table V-19 excludes plants that are considered zero dis-
chargers may account for some of this discrepancy, since any plant that recy-
cles 100 percent of its process wastewater would be excluded.

D.   WASTEWATER CHARACTERIZATION                            !

     1.  Conventional Pollutants
     A number of different pollutant parameters are used to characterize
wastewater discharged by OCPSF manufacturing  facilities. .These include:

     •  Biochemical Oxygen Demand  (BOD5)
     9  Total Suspended  Solids (TSS)
     •  pH
     0  Chemical Oxygen  Demand (COD)
     •  Total Organic Carbon (TOC)                       :
     •  Oil  and Grease  <0&G).

     BOD   is one of  the  most important gauges of  the  pollution potential  of a
wastewater and varies with  the amount  of  biodegradable matter  that  can be
assimilated  by biological organisms under aerobic conditions.   Large,  complex
facilities  tend  to discharge a higher  BOD5 mass  loading, although concentra-
tions  are not necessarily different from  smaller  or less complex  plants.   The
nature of specific chemicals discharged into wastewater affects the BOD5  due
to the differences in  susceptability of different molecular structures to
microbiological  degradation. Compounds with lower susceptibility to decom-
position by  microorganisms  tend  to exhibit lower BOD5 values,  even though the
 total  organic  loading  may  be much higher than compounds exhibiting
substantially higher BOD5  values.
                                      V-29

-------
       Raw wastewater TSS is a function of the products manufactured and their
  processes, as well as the manner in which fine solids that may be removed by a
  processing step are handled in the operations.   It can also be a function of a
  number  of other external factors,  including stormwater runoff,  runoff  from
  material storage areas,  and landfill leachates  that may be diverted to the
  wastewater treatment system.   Solids are frequently washed into the plant
  sewer and removed at the wastewater treatment plant.   The  solids may be
  organic,  inorganic,  or a mixture of both.   Settleable portions  of the
  suspended solids  are usually removed in  a primary  clarifier.  Finer materials
  are carried through  the  system,  and in the  case of an activated  sludge system,
  become enmeshed with the biomass where they are then  removed with the sludge
 during secondary  clarification.  Many of the manufacturing plants  show an
 increase  in TSS in the effluent  from the treatment  plant.  This  characteristic
 is usually associated with biological systems and  indicates an inefficiency of
 secondary clarification  in removal of secondary solids.  Also, treatment
 systems that include polishing ponds or lagoons may exhibit this characteristic
 due to algae growth.  However,  in plastics and synthetic materials wastewaters,
 formation of biological solids within the treatment plant may cause this
 solids increase due to the low strength nature of the influent wastewater.

      Raw wastewater pH can be a function  of the nature of the processes
 contributing to the waste stream.  This parameter can vary  widely from  plant
 to plant and can also show extreme  variations in a single plant's raw
 wastewater,  depending on  such factors as  waste  concentration and the portion
 of the process cycle discharging at the time of  measurement.   Fluctuations in
 pH are readily reduced by equalization followed  by a neutralization system, if
 necessary.   Control of pH is  important regardless  of the disposition of  the
 wastewater stream  (i.e.,  indirect discharge  to a POT¥ or direct  discharge)  to
 maintain  favorable conditions for biological  treatment system organisms, as
 well as receiving  streams.

     COD is a measure of  oxidizable  material in a wastewater as determined by
subjecting the waste  to a powerful chemical oxidizing  agent (such  as dichro-
mate) under standardized  conditions.  Therefore, the COD  test can show the
presence of organic materials that are not readily  susceptible to attack by
biological microorganisms.  As a result of this difference,  COD values are
                                     V-30

-------
almost invariably higher than BOD5 values for the same sample.  The COD test
cannot be substituted directly for the BOD5 test because the COD/BOD5 ratio is
a factor that is extremely variable and is dependent on the specific chemical
constituents in the wastewater.  However, a COD/BOD5 ratio'for the wastewater
from a single manufacturing facility with a constant product mix may be
established.  This ratio is applicable only to  the wastewater from which it
was derived and cannot be utilized to estimate  the BOD5 of another plant's
wastewater.  It is often established by plant personnel to monitor process and
treatment plant performance with  a minimum of analytical delay.  As  production
rate and product mix  changes,  however,  the COD/BOD,  ratio must be Devaluated
for  the new conditions.  Even  if  there  are no changes  in production,  the  ratio
should be reconfirmed periodically.

      TOG measurement  is  another means  of determining the, pollution potential
of wastewater.   This  measurement shows the presence of organic compounds  not
necessarily measured  by either BOD or  COD tests.  TOG can also be related to
 delay.   As  production rate and product mix changes, however, the COD/BOD5
 ratio must  be reevaluated for the new conditions.  Even if there are no
 changes  in production, the ratio should be reconfirmed periodically.

      Tables V-20 through V-27 provide a statistical analysis of raw wastewater
 BOD , COD,  TOC, and TSS by subcategory and disposal method.  For
 multi-subcategory plants, the plants'  pollutant values have been
 production-weighted  for calculatipn of mean values and selection of median
 values.  The following equation  illustrates the method for  calculating the
 production-weighted  mean concentrations:
  Subcategory:
Production-weighted Mean = P*Ci +
                                              + P'C»  * ' ' ' '  *
                                      Pl  + P2  + P3
  Where:
       P   = Decimal subcategory proportion of total plant production for plant
        1     #1 (Range 0 to 1.0)
       C   = Pollutant concentration for plant ttl.
                                       V-31

-------
                       TABLE V-20
SUMMARY STATISTICS OF  RAW WASTEWATER BOD CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD

DISPOSAL SUBCATEGORY
METHOD

ALL PLANTS THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
DIR/IND THERMOPLASTICS
THERMOSETS
BULK ORGANICS
SPECIALTY ORGANICS
DIRECT THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
INDIRECT THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
ZERO THERMOPLASTICS
THERMOSETS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
r i\uuuv.CK-r K 1 PIHK I
# OF # OF PLANTS
PLANTS (PRODUCTION

108
44
4
20
51
95
104
1
1
1
2
62
16
4
18
38
53
46
43
26
2
12
40
55
2
1
'1
1
1
WEIGHTED)
65.7538
15.6468
2.1871
13.1475
29.9702
34.9281
60.3664
1.0000
0.0337
0.2863
1.6800
37.1289
4.0231
2.1871
11.1475
21.6020
16.8416
1B.0697
27.4570
10.7119
2.0000
7.5305
17.7067
40.5939
0.1680
0.8781
0.8377
0.0935
0.0228
PRODUCTION
WEIGHTED
MEAN
1328.886
1856.433
169.756
921.281
1724.727
1465.540
1320.423
469.000
577.000
577.000
245.745
725.190
1569.784
169.756
904.556
1504.018
1199.871
1347.053
2182.704
2092.435
1014.500
2518.558
1738.854
1353.627
323.534
340.000
280.000
280.000
280.000
PRODUCTION
WEIGHTED
MEDIAN
351.000
572.000
175.000
986.000
679.000
705.000
715.000
469.000
577.000
577.000
20.500
386.000
668.000
175.000
706.200
694.000
668.000
718.000
198.000
453.800
1014.500
679.000
705.000
715.000
340.000
340.000
280.000
280.000
280.000
PRODUCTION
WEIGHTED
STD. DEV.
4634.526
4824.965
11.139
663.397
2284.493
2120.879
1819.967


429.352
830.834
2119.824
11.139
724.331
2009.651
1399.325
2038.317
7093.989
5779.452
40.305
3042.237
2665.783
1766.617




                        V-32

-------
                      TABLE V-21
SUMMARY STATISTICS OF RAW WASTEUATER BOD CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL SUBCATEGORY
METHOD

ALL PLANTS THERMOPLASTICS
THERMOSETS
ORGAN I CS
DIR/IND THERMOPLASTICS
ORGAN I CS
DIRECT THERMOPLASTICS
THERMOSETS
ORGAN I CS
INDIRECT THERMOPLASTICS
THERMOSETS
ORGAN I CS
ZERO THERMOPLASTICS
ORGAN I CS
UNKNOWN THERMOPLASTICS
	 PROOUCER=SECONDARY 	
# OF # OF PLANTS PRODUCTION
PLANTS

30
24
62
Z
1
9
3
23
17
21
37
1
1
1
(PRODUCTION
WEIGHTED)
17.4317
16.6878
55.8805
1.0567
0.9433
5.6808
2.0319
21 .2874
9.1103
14.6559
33.2337
0.5839
0.4161
1.0000
WEIGHTED
MEAN
673.612
796.882
920.621
42.073
621.500
66.951
39.624
58.193
1194.172
901.867
1492.966
7.000
7.000
434.000
PRODUCTION
WEIGHTED
MEDIAN
117.800 ,
304.000
96.900
9.230
621.500
54.500
24.000
41.000
361.000
360.000
451.000
7.000
7.000
434.000
PRODUCTION
WEIGHTED
STD. DEV.
1698.067
1459.787
2228.595
595.622
•
73.167
22.498
75.010
2276.641
1533.251
2758.663
•

•
                           V-33

-------
                       TABLE V-22
SUMMARY STATISTICS OF  RAW UASTEWATER COO CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL
METHOD
ALL PLANTS






DIR/IND



DIRECT






INDIRECT





ZERO




SUBCATEGORY

THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
THERMOPLASTICS
THERMOSETS
BULK ORGANICS
SPECIALTY ORGANICS
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
THERMOPLASTICS
THERMOSETS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
	
# OF
PLANTS
95
49
4
17
62
79
93
2
1
2
2
56
18
4
15
43
48
41
35
29
2
18
28
49
2
1
1
1
1
# OF PLANTS
(PRODUCTION
WEIGHTED)
53.6896
20.3799
2.1871
11.5417
33.9393
27.2478
46.0146
1.0293
0.0337
1.2533
0.6836
32.0356
6.6961
2.1871
9.5417
24.1352
13.7100
15.6944
20.4567
12.7719
2.0000
8.9665
12.1911
29.6138
0.1680
0.8781
0.8377
0.0935
0.0228
PRODUCTION
WEIGHTED
MEAN
3035.613
7497.533
503.405
1657.671
3457.453
4811.004
3362.890
944.575
6912.000
4794.021
6897.501
2429.787
9414.566
503.405
1632.135
2600.765
3291.938
2354.756
3927.833
4870.899
1779.500
6030.363
6553.362
3817.702
22733.387
31105.000
600.000
600.000
600.000
PRODUCTION
WEIGHTED
MEDIAN
1395.000
2709.000
500.000
1501.000
1645.000
2066.000
1772.500
850.000
6912.000
4167.000
6912.000
1425.000
4094.000
500.000
1217.000
1645.000
3092.000
1756.000
1226.800
2394.000
1779.500
2709.000
1435.000
1772.500
31105.000
31105.000
600.000
600.000
600.000
PRODUCTION
WEIGHTED
STD. DEV.
5851.739
10315.211
83.729
1668.644
5075.267
8651 .988
5231 .467
3269.370

2563.254

4783.865
11736.813
83.729
1847.690
2737.533
3011.197
2418.299
7041.918
7574.041
393.858
8614.405
12603.269
6242.976





                       V-34

-------
                       TABLE V-23
SUMMARY STATISTICS OF  RAW WASTEWATER COD CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL SUBCATEGORY
METHOD

ALL PLANTS THERMOPLASTICS
THERMOSETS
ORGAN I CS
DIR/IND THERMOPLASTICS
ORGAN I CS
DIRECT THERMOPLASTICS
THERMOSETS
ORGAN I CS
INDIRECT THERMOPLASTICS
THERMOSETS
ORGAN I CS
ZERO THERMOPLASTICS
ORGAN I CS
	 PRODUCER=SECONDARY 	
# OF # OF PLANTS PRODUCTION
PLANTS

24
19
49
2
1
7
1
19
14
18
28
1
1
(PRODUCTION
WEIGHTED)
11.1848
14.2420
45.5732
1.0567
0.9433
3.7185
1.0000
18.2815
5.8257
13.2420
25.9323
0.5839
0.4161
WEIGHTED
MEAN
1825.124
3282.064
3126.985
795.978
14115.333
272.776
274.500
377.963
3157.083
3509.187
4710.872
284.100
284.100
PRODUCTION
WEIGHTED
MEDIAN
800.000
1808.000
636.700
41.000
14115.333
141.000
274.500
248.000
1995.000
2340.000
1698.000
284.100
284.100
PRODUCTION
WEIGHTED ,
STD. DEV.
2640.893
3996.106
.6883.309
13691 .642
•
219.334
•
571 .528
2823.567
'4059.385
8463.117
•
•
                            V-35

-------
                       TABLE V-24
SUMMARY STATISTICS OF  RAW WASTEWATER TOC CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL SUBCATEGORY
METHOD

ALL PLANTS THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
DIRECT THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
INDIRECT THERMOPLASTICS
THERMOSETS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
	 f
# OF
PLANTS

42
16
7
39
56
55
31
7
7
37
45
41
11
9
2
11
14
'RODUCER=PRIMAR^
# OF PLANTS
(PRODUCTION
WEIGHTED)
18.9470
4.8893
3.8143
20.6337
23.5709
22.1449
14.5154
1.2449
3.8143
19.3261
17.6060
14.4933
4.4316
3.6444
1 .3076
5.9648
7.6516
r 	
PRODUCTION
WEIGHTED
MEAN
992.384
426.877
475.170
1096.466
989.221
1247.866
1132.305
351.164
475.170
970.419
897.761
1424.170
534.079
452.741
2959.352
1259.177
913.918
PRODUCTION
WEIGHTED
MEDIAN
486.000
349.000
391.200
418.000
484.000
575.000
522.000
349.000
391.200
418.000
358.000
424.000
50.000
654.000
4660.000
505.000
604.000
PRODUCTION
WEIGHTED
STD. DEV.
1997.567
274.541
173.191
1385.640
1749.485
2463.687
2124.494
182.526
173.191
1199.265
1557.493
2965.838
1654.798
322.723
4594.570
2384.023
1120.472
                      V-36

-------
                      TABLE V-25
SUMMARY STATISTICS OF  RAW WASTEWATER TOC CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL SUBCATEGORY
METHOD

ALL PLANTS THERMOPLASTICS
THERMQSETS
ORGAN I CS
DIR/IND THERMOPLASTICS
ORGAN I CS
DIRECT THERMOPLASTICS
THERMOSETS
ORGAN I CS
INDIRECT THERMOPLASTICS
THERMOSETS
ORGAN I CS
	 PRODUCER=SECONDARY 	
# OF # OF PLANTS PRODUCTION
PLANTS (PRODUCTION WEIGHTED

9
7
27
2
1
5
2
13
2
5
13
WEIGHTED)
5.4525
4.7260
24.8216
1.0567
0.9433
2.6737
1.0319
11.2945
1.7221
3.6941
12.5838
MEAN
349.877
278.596
1478.439
316.970
5644.333
131.137
68.104
174.445
709.665
337.393
2336.539
PRODUCTION
WEIGHTED
MEDIAN
215.000,
78.000
249.000
15.000
5644.333
118.000
68.000
23.800
500.000
145.500
445.000
PRODUCTION
WEIGHTED
STD. DEV.
698.064
365.633
3094.234
5476.268

87.972
3.298
414.016
381.009
403.957
3957.989
                             V-37

-------
                       TABLE V-26
SUMMARY STATISTICS OF  RAW WASTEWATER TSS CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL SUBCATEGORY
METHOD

ALL PLANTS THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGAN I CS
DIR/IND THERMOPLASTICS
THERMOSETS
BULK ORGAN I CS
SPECIALTY ORGANICS
DIRECT THERMOPLASTICS
THERMC.«ETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
INDIRECT THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
ZERO THERMOPLASTICS
THERMOSETS
	 F
# OF
PLANTS

113
54
3
15
56
92
109
2
1
2
3
55
15
3
13
36
44
37
55
37
2
20
46
69
1
1
>RODUCER=PRIMAR1
# OF PLANTS
(PRODUCTION
WEIGHTED)
69.2105
21.9417
1.9756
9.8263
29.1388
37.3944
60.5127
1.0293
0.0337
1.2533
1.6836
32.7511
5.4898
1.9756
7.8263
19.4999
14.5703
13.8871
35.3082
15.5401
2.0000
9.6390
21.5708
44.9420
0.1219
0.8781
r 	
PRODUCTION
WEIGHTED
MEAN
639.742
822.065
399.500
135.510
378.424
1026.209
526.438
66.792
6103.000
1545.294
2485.942
729.522
1756.192
399.500
158.895
302.818
603.532
381.469
564.396
347.309
44.000
531 .376
1281.553
497.827
3181.000
3181.000
PRODUCTION
WEIGHTED
MEDIAN
263.000
212.000
635.000
72.000
157.000
174.000
154.000
63.000
6103.000
196.000
34.700
302.000
1598.000
635.000
156.000
157.000
234.000
194.000
202.000
129.400
44.000
186.000
129.400
151.800
3181.000
3181.000
PRODUCTION
WEIGHTED
STD. DEV.
971.596
1203.909
339.319
126.695
678.674
2990.516
1236,554
131.090

5515.897
4672.420
1115.037
1358.482
339.319
132.934
433.753
913.698
473.399
824.529
739.290
4.243
1028.767
3832.206
1229.205


                     V-38

-------
                      TABLE V-27
SUMMARY STATISTICS OF  RAW WASTEWATER TSS CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL SUBCATEGORY
METHOD

ALL PLANTS THERMOPLASTICS
THERMOSETS
ORGAN I CS
DIR/IND THERMOPLASTICS
ORGAN I CS
DIRECT THERMOPLASTICS
THERMOSETS
OR CAN I CS
INDIRECT THERMOPLASTICS
THERMOSETS
ORGANICS
ZERO THERMOPLASTICS
ORGANICS
UNKNOWN THERMOPLASTICS
	 PRODUCER=SECONDARY 	
# Of # OF PLANTS PRODUCTION
PLANTS

31
25
64
2
1
9
3
26
18
22
36
1
1
1
(PRODUCTION
WEIGHTED)
18.2239
17.7299
58.0462
1 .0567
0.9433
5.6808
2.0319
24.2874
9.9025
15.6980
32.3995
0.5839
0.4161
1 .0000
WEIGHTED
MEAN
121.241
255.721
800.089
25.286
350.000
32.303
38.924
76.918
164.678
283.782
1365.387
14.600
14.600
360.000
PRODUCTION
WEIGHTED
MEDIAN
64.000
168.000
76.700
6.880
350.000
29.000
26.000
38.900
130.000
168.000
173.000
14.600
14.600
360.000
PRODUCTION
WEIGHTED
STD. DEV.
122.123
262.125
4456.709
333.790
•
20.124
19.618
107.027
112.000
266.163
5943.781
•
•
•
                            V-39

-------
      In determining the  median,  the  actual  pollutant  concentrations, of  each
 plant  that has at  least  one  product  within  a  subcategory are  ranked  from
 lowest to highest.   The  subcategory  decimal production  proportions are  summed
 starting from the  lowest  concentration plant  until  the  sum equals or exceeds
 50 percent of the  total  of all the decimal  production proportions.   The
 pollutant concentration  of the plant whose  proportions  when added to the
 proportion sum causes the total  to exceed 50  percent is then  chosen  as  the
 median.  If, however, the sum equals 50 percent exactly, then the median is
 the average of the pollutant concentrations of that plant and the next plant
 in the sequence.

      Tables V-28 through V-35 also provide raw wastewater statistics for BOD ,
 COD,  TOC,  and TSS by subcategory and discharge technique,  but use the 95/70
 methodology discussed earlier in this section to aggregrate plants by subcate-
 gory.  As  in previous tables concerning wastewater volumes,  these tables are
 separated  into primary producers and a few zero/alternate  dischargers versus
 secondary  producers and most zero dischargers.  For some indirect and zero
 dischargers  who  pretreat  their wastewater,  the data used are  typically from
 the effluent of  their pretreatment system rather than strictly raw wastewater.
 Most  indirect dischargers only sample their  wastewater at  the  point  where  it
 enters  the POTO  collection system.   It  should  also be noted  that,  as  described
 in  Section VII,  the concentrations of pollutants  for raw wastewater  of  the
 primary producers  that  are direct dischargers  have been  corrected  for dilution
 by  uncontaminated  nonprocess  wastewater.  This correction was  not  performed on
 secondary producers,  nor  on  indirect  and  zero  dischargers.

      As with  the summary  statistics for wastewater flow  by subcategory,  the
 summary statistics  for raw wastewater BOD5,  COD, TOC, and TSS  concentrations
 by subcategory that were generated by the two  methodologies compare favorably;
 most  of the differences between subcategory  medians  calculated by  the two
 methodologies fell within  the standard deviations  calculated by either
methodology.   For the reasons stated earlier in this section when discussing
 the summary statistics for wastewater flow by  subcategory,  the Agency has much
more confidence in the accuracy of the summary statistics calculated  by the
regression methodology, but has included the summary statistics calculated by
 the 95/70 methodology for comparison purposes.
                                     V-40

-------
                                   TABLE V-28
            SUMMARY STATISTICS OF  RAW WASTEWATER BOD CONCENTRATIONS
                    BY SUBCATEGORY GROUP AND DISPOSAL METHOD
                            (  WITH 95%  & 70% RULE  )
ALL PLANTS    THERMOPLASTICS          48
              THERMOSETS               5
              RAYON                    2
              FIBERS                   9
              COMMODITY ORGANICS      14
              BULK ORGANICS           18
              SPECIALTY ORGANICS      52 ,
              MIXED                   74
DIR/IND       THERMOPLASTICS           1
              BULK ORGANICS            0
              SPECIALTY ORGANICS       1
              MIXED                    1
DIRECT        THERMOPLASTICS          26
              THERMOSETS               2
              RAYON      '              2
              FIBERS       .            7
              COMMODITY ORGANICS       9
              BULK ORGANICS            8
              SPECIALTY ORGANICS      12
              MIXED                   45
 INDIRECT      THERMOPLASTICS          21
              THERMOSETS               3
              FIBERS                   2
              COMMODITY  ORGANICS       4
              BULK ORGANICS           10
              SPECIALTY  ORGANICS      39
              MIXED                   27
 ZERO         THERMOPLASTICS           0
              COMMODITY  ORGANICS        1
              BULK ORGANICS             0
              SPECIALTY  ORGANICS        0
              MIXED                    1
iRY --------
MEAN
1088.883
1191.200
169.000
739.244
2099.000
940.156
1263.161
1814.754
469.000
20.500
577.000
647.205
2415.500
169.000
660.600
2209.944
901 .625
1534.810
1079.856
1665.240
375.000
1014.500
2304.125
970.980
1211.440
3140.048
MEDIAN
266.500
250.000
169.000 ;
706.200
629.500
393.500 '
704.500
737.000
469.000
20.500
577.000
380.500
2415.500
169.000
444.000
694.000
264.000
773.500
785.000
138.000
250.000
1014.500
766.500
430.000
694.000
757.000
STD. DEV.
4312.183
1991.833
8.485
531,238
2887.453
1074.395
1623.229
3811.602
•
;

810.973 .
3239.256
8.485
586.126
2959.328
1051.801
2567.712
920.978
6500.336
436.148
40.305
3402.801
1147.855
1249.419
6037.743
280.000
340.000
            280.000
            340.000
                                          V-41

-------
                       TABLE V-29
SUMMARY STATISTICS OF  RAW WASTEWATER BOD CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
                <  WITH 95% & 70% RULE )

DISPOSAL
METHOD
ALL PLANTS.




DIR/IND


DIRECT



INDIRECT



ZERO




UNKNOWN


SUBCATEGORY # OF

THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
MIXED
THERMOPLASTICS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
PLANTS
12
13
51
0
14
1
0
1
5
2
20
2
5
11
31
10
0
0
0
0
1
1
0
0
.UIYUHM ----
MEAN

441 .894
623.608
972.029
.
964.434
9.230
_
621.500
70.940
39.950
60.801
24.500
900.960
729.727
1559.918
1282.458
.
.
.
.
7.000
434.000
m

MEDIAN

161 .900
277.000
82.000

302.000
9.230

621.500
54.500
39.950
43.000
' 24.500
651.000
360.000
451.000
402.000




7.000
434.000


STD. DEV.

705.702
871.510
2327.405

2239.655



77.758
22.557
76.557
30.406
938.746
911.519
2848.442
2611.835








                      V-42

-------
                     • TABLE V-30
SUMMARY STATISTICS OF RAW WASTEWATER COO CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
                ( WITH 95%  8 70% RULE )
DISPOSAL
METHOD
ALL PLANTS







DIR/IND



DIRECT







INDIRECT






ZERO




	 PRODUCER=PRIMARY 	
SUBCATEGORY # OF MEAN
MEDIAN
STD. DEV.
PLANTS
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGAN I CS
MIXED
THERMOPLASTICS
BULK ORGAN I CS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
34
7
2
8
15
11
37
81
1
1
0
1
19
.4
2
6
10
5
12
46
14
3
2
4
5
25
33
0
1
0
0
1
2172.459
5773.143
522.500
1132.000
2914.633
2839.545
2658.803
5450.385
850.000
4167.000
.
. 6912.000
1774.974
8865.250
522.500
916.167
2579.200
5020.200
2173.000
3254.714
. 2806.365
1650.333
1779.500
4331.875
393.400
2891.989
7689.313
.
600.000
.

31105.000
1158.000
1700,000
522.500
1000.000
1943.000
598.000
1692.000
2066.000
850.000
4167.000

6912.000
1286.000
6815.500
522.500
710.000
1971.500
3796.000
1544.500
1689.500
455,500
509.000
1779.500
2229,250
500.000
1692.000
2709.000
•
600.000
-
.
31105.000
3478.292
7882.793
31 .820
875.063
3401 .295
3411.839
2746.715
9051.549
•
•
•
•
1734.512
9586.722
31 .820
904.102
2590.289
3896.203
2220.908
5735.796
507A.226
1984.647
393.858
5387.018
238.931
2980.155
11217.300
•
•
•
•
•
                             V-43

-------
                       TABLE V-31
SUMMARY STATISTICS OF  RAW WASTEWATER COO CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
                (  WITH 95% & 70% RULE )

DISPOSAL
METHOD
ALL PLANTS




DIR/INO


DIRECT



INDIRECT



ZERO




UNKNOWN



SUBCATEGORY

THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
MIXED
THERMOPLASTICS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
ppnni IPPD— c
r I\\sU U U CK ""5
# OF
PLANTS
8
12
40
0
11
1
0
1
3
1
17
2
4
11
23
7
0
0
0
0
1
0
0
0
•cp/ittn A DV
MEAN

1509.000
3219.000
3007.794
.
3513.803
41.000
_
14115.333
245.333
274.500
393.626
248.200
2823.750
3486.682
4940.004
3393.714
•
•
'.
.
284.100
.
.
.

MEDIAN

646.000
1753.500
582.500

1364.000
41.000

14115.332
141.000
274.500
248.000
248.200
2247.500
2340.000
1698.000
1808.000




284.100




STD. DEV.

2032.859
4181.376
7111.048

4438.984



214.463

587.223
341.957
2234.261
4276.269
8955.829
2962.999








                        V-44

-------
                       TABLE V-32
SUMMARY STATISTICS OJ- RAW;WASTEWATER  fdC  CONCENTRATIONS
        BY SUBCATEGORY; GROUP AND,DISPOSAL METHOD
                (WITH 95%  & 70% RULE )     „
DISPOSAL
METHOD
ALL PLANTS







DIR/IND




DIRECT








INDIRECT






ZERO




	 PRODUCER=PRIMARY 	
SUBCATEGORY # OF MEAN

THERMOPLASTICS
THERMOSETS'
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
BULK ORGANICS
, *
SPECIALTY ORGANICS
MIXED . '
THERMOPLASTICS
THERMOSETS '

RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
PLANTS
11
0
0
3
10
T9'.
16
45
0
0

0
;' *0 '
8
'•o
i. ' " . '.'
* 0
3
9
6
10
35
3
0
0
1
3
6
10
0
0
0
0
0

470.470
.
.
472.733
1811.067
637.000
1252.500
1017.778
.'
.

.
.
618.396
„

.
472.733
1494.519
758.667
1472.000
994.250
76.000
.
.
4660.000
393.667
886.667
1100.126
.
.
.
.
.
MEDIAN ,

166.000
.

391.200 '
1088.000
308.000
516.500
505.000
,
.

•
-
418.000
.

....
391.200
389.000
238.500
408.000,
486.000
35.000

'•
4660.000
500.000
777.000
579.500
•
.
.
.
.
STD. DEV. ,

770.042 ,
.. . • •
. ', .1 . •
160.829
1860.990
1013.431
2764.300
1774.971
'
.

•
, -
868.222
.

•
160.829
1664.006
1254.864
3514.778
1695.554
74.505
• i, ' .
,
'
195.541
656.135
2128.878
•
•
•
-
•
                          V-45

-------
                      TABLE V-33
SUMMARY STATISTICS OF  RAW WASTEWATER TOC CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
                (  WITH 95% & 70% RULE )
DISPOSAL
METHOD
ALL PLANTS




DIR/IND


DIRECT



INDIRECT



ZERO
fr



UNKNOWN


	 P
SUBCATEGORY

THERMOPLASTICS
THERMOSETS
ORGANICS
FIBERS
MIXED
THERMOPLASTICS
ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANICS
FIBERS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANICS
'ROOUCER-:
#OF
PLANTS
4
4
22
0
5
1
0
1
2
1
10
2
1
3
12
2
0
0
0
0
0
0
0
0
MEAN
200.337
259.125
1423.514
•
1353.267
15.000
•
5644.333
143.175
68.000
191.480
61.000
500.000
322.833
2450.208
500.000
MEDIAN
143.175
111.750
259.750
118.000
15.000
"•
5644.332
143.175
68.000
30.400
61.000
500.000
145.500
612.500
500.000
STD. DEV.
216.795
325.740
3144.832
•
2434.943
•
•
101.576
m
439.123
80.610
m
367.162
4024.083
707.107
                     V-46

-------
                                   TABLE  V-34  ,
            SUMMARY STATISTICS w'kty WASTEWATER TSS CONCENTRATIONS
                    BY SUBCATEGORY GROUP  AND DISPOSAL METHOD
                            ( WITH 95% &  70% RULE )
DISPOSAL
METHOD

ALL PLANTS
DIR/IND
 DIRECT
 INDIRECT
 ZERO
              SUBCATEGORY
                  PRODUCER=PRIMARY

                      # OF
                      PLANTS
THERMOPLASTICS          49
THERMOSETS               7
RAYON                    2
FIBERS                   7
COMMODITY ORGAN ICS ,.    10
BULK ORGANICS           20
SPECIALTY ORGANICS      51
MIXED                   84
THERMOPLASTICS           1
BULK ORGANICS            1
SPECIALTY ORGANICS       1
MIXED                    1
THERMOPLASTICS          21
THERMOSETS               3
RAYON                    2
FIBERS                   5
COMMODITY ORGANICS       6
BULK ORGANICS            6
SPECIALTY ORGANICS ,      10
MIXED                    43
THERMOPLASTICS          27
THERMOSETS  .             4
 FIBERS                  2
 COMMODITY ORGANICS      4
 BULK ORGANICS           13
 SPECIALTY ORGANICS      40
 MIXED                   39
 THERMOPLASTICS           0
 COMMODITY ORGANICS       0
 BULK ORGANICS            0
 SPECIALTY ORGANICS       0
 MIXED                    1
RY 	 •
MEAN
640.032
1212.000
396.500
117.286
247.658
1358.959
445.072
617.603
63.000
196.000
34.700
6103.000
749.452
2590.333
396.500
146.600
194.222
977.333
404.466
452.398
576.299
178.250
44.000
327.813
1624.552
465.482
593.374
MEDIAN
182.000
362.000
396.500
50.000
140.000
124.500
151.800
232.000
63.000
196.000
34.700
6103.000
.... 237.000
"2509.000
396.500
'' 72.000
,'139.000
180.500
193.500
235.000
154.000
155.500
44.000
186.500
83.000
151.400
187.000
STD. DEV.
1066.040
1425.356
337.290
126.805
251 .969
3979.027
1124.192
1020.412
•
•
.
•
1275.399
1035.399
337.290
142.672
143.518
1348.864
528.479
584.672
905.587
154.675
4.243
376.642
4903.910
1245.249
948.802
                                               3181.000    3181.000
                                     V-47

-------
                       TABLE V-35
SUMMARY STATISTICS OF  RAW WASTEWATER TSS CONCENTRATIONS
        BY SUBCATEGORY GROUP AND DISPOSAL METHOD
                (  WITH 95% & 70% RULE )
	 PRODUCER=SI
DISPOSAL
METHOD
ALL PLANTS




DIR/IND


DIRECT



INDIRECT



ZERO




UNKNOWN


SUBCATEGORY

THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
MIXED
THERMOPLASTICS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
# OF
PLANTS
12
14
53
0
15
1
0
1
5
2
23
2
5
12
30
11
0
0
0
0
1
1
0
0
MEAN
98.348
284.270
861.552
157.557
6.880
350.000
29.860
39.450
79.553
36.400
132.800
325.073
1461.083
175.087
14.600
360.000
MEDIAN
49.200
168.000
76.700
130.000
6.880
350.000
29.000
39.450
38.900
36.400
122.000
189.500
165.500
163.000
14.600
360.000
STD. DEV.
112.008
281.031
4663.029
134.590
•

19.646
19.021
109.397
27.719
86.955
283.886
6174.386
127.525

„ , -
                       V-48

-------
     2.  Occurrence and Prediction of Priority Pollutants
     The Clean ¥ater Act required the Agency to develop data characterizing
the presence (or absence) of 129 priority pollutants in raw and treated waste-
waters of the OCPSF industry.  These data have been gathered by EPA from
industry sources and extensive sampling and analysis of individual OCPSF
process wastewaters.  An adjunct to these data-collection efforts was the
correlation of priority pollutant occurrence with product/process sources by a
consideration of the reactants and process chemistry.  This approach offers
the advantage of qualitative prediction of organic priority pollutants likely
to be present in plant wastewaters.  A systematic means of anticipating the
occurrence of priority pollutants is beneficial to both the development and
implementation of regulatory guidelines:

     •  Industry-wide qualitative product/process coverage becomes feasible
        without the necessity of sampling and analyzing hundreds of effluents
        beyond major product/processes.
     •  Guidance is provided for discharge permit writers, permit applicants,
        or anyone trying to anticipate priority pollutants that are likely to
        be found in the combined wastewaters of a .chemical plant when the
        product/processes operating at the facility are known.

Qualitative prediction of priority pollutants for these industries is possible
because, claims of uniqueness notwithstanding, all plants within the OCPSF
industry are alike in one important sense—all transform feedstocks to
products by chemical reactions and physical processes in a stepwise fashion.
Although each transformation represents at least one chemical reaction,
virtually all can'be classified by,one or more generalized chemical reactions/
processes.  Imposition of these processes upon the eight basic feedstocks lead
to commercially produced organic chemicals and plastics.  It is the permuta-
tion of the feedstock/process combinations that permit the industries to
produce such a wide variety of products.

     Chemical manufacturing plants share a second important similarity;
chemical processes almost never convert 100 percent of the feedstocks to the
desired products; that is, the chemical reactions/processes never proceed to
                                     V-49

-------
 total  completion.   Moreover,  because there are generally a variety of reaction
 pathways  available to  reactants,  undesirable by-products are  often unavoidably
 generated.   This  results  in a mixture of unreacted  raw materials  and  products
 that must be separated and  recovered by unit operations that  often generate
 residues  with little or no  commercial value.   These yield losses  appear  in
 process contact wastewater, in air  emissions,  or  directly as  chemical wastes.
 The specific chemicals that appear  as yield losses  are determined by  the feed-
 stock  and the process  chemistry imposed upon it,  i.e.,  the feedstock/generic
 process combination.

          a.   General
     Potentially,  an extremely wide variety of compounds could  form within a
 given  process.  The formation of  products  from reactants depends  upon the
 relationship of the free  enthalpies of products and  reactantsj  more important,
 however,  is  the existence of  suitable reaction pathways.   The rate  at which
 such transformations occur cannot (in general)  be calculated  from first
 principles and must be empirically  derived.  Detailed  thermodynamic calcu-
 lations,  therefore, are of limited  value in predicting  the entire spectrum of
 products  produced  in a process, since both  the  identity  of true reacting
 species and  the assumption of  equilibrium between reacting species  are often
 speculative.  Although kinetic models  can in principle predict  the  entire
 spectrum  of  products fotmed in a process, kinetic data concerning minor side
 reactions are generally unavailable.   Thus, neither  thermodynamic nor kinetic
analyses  alone can be  used for  prediction of species formation.1  What these
analyses  do  provide, however,   is a  framework within which  pollutant formation
may be considered and generalized.
 Prediction of pollutant formation is necessarily of a qualitative rather than
 quantitative nature; although reactive intermediates may be identified
 without extensive kinetic measurements, their rate of formation (and thus
 quantities produced) are difficult to predict without kinetic measurements.
 Other quantitative approaches, for example, detailed calculation of an
 equilibrium composition by minimization of the free energy 6f a system,
 require complete specification of all species to be considered.  Because such
 methods necessarily assume equilibrium, the concentrations generated by such
 methods represent only trends or, perhaps at best, concentration ratios.
                                     V-50

-------
      The reaction chemistry of a process  sequence is controlled through
 careful adjustment and maintenance of conditions in the reaction vessel.   The
.physical condition of species  present^(liquid,  solid,  or gaseous phase),
 condition of temperature and pressure,  the presence of solvents and catalysts,
 and the configuration of process equipment are  designed to favor a reaction
 pathway by which a particular  product is  produced.   From this knowledge,  it is
 possible to identify .reactive  intermediates and thus anticipate species
 (potential pollutants) formed.

      Most chemical transformations performed by the OGPSF industry may be
 reduced to a small number of basic steps  or unit processes.  Each step or
 process represents a chemical  modification of the starting matrials and is
 labeled a "generic process."  For example, the generic process " nitration"
 may represent either the substitution or  addition of an "-N02" functional
 group to an organic chemical.   Generic processes may be quite complex
 involving a number of chemical bonds being broken and formed, with the overall
 transformation passing through a number of distinct (if transitory) i^'^r-
 mediates.  Simple stoichiometic equations, therefore, ar-
 descriptions of chemical reactions arid only rarely account for observed
 by-products.

      Table V-36 lists the major organic chemicals produced by the OCPSF
 industry (approximately 250) by process,  and Table V-37 gives the same
 information for the  plastics/synthetic fibers industry.  Certain products
 shown in Table V-36  are not derived  from primary feedstocks, but rather from
 secondary or higher  order materials  (e.g., aniline  is produced by hydrogena-
 tion of nitrobenzene that is  produced by nitration  of benzene).  For such
 multistep syntheses,  generic  processes appropriate  to each step must be
 evaluated separately.  For  many commodity  and bulk  chemicals, it is sufficient
 to specify  a feedstock and  a  single  generic process,  because they are  gener-
 ally manufactured  by a one-step process.   Nitration of  benzene  to produce
 nitrobenzene, for  example,  is a sufficient description  to  predict constituents
 of the  process wastewater:  benzene, nitrobenzene,  phenol, and  nitrophenols
 will be the principal process wastewater  constituents.   Similarly,  oxidation
 of butane  to produce acetic acid  results  in wastewater  containing a wide
 variety of  oxidized species,  including formaldehyde,  methanol,  acetaldehyde,
 n-propanol, acetone, methyl ethyl ketone,  etc.
                                      V-51

-------




GENERIC
PROCESS
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HYDROHALOCENATK3N
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OCHYDROHALOCENATION
OXYHALOCENATION
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                                 V-52

-------
     The reaction chemistry of a process sequence is controlled through
careful adjustment and maintenance of conditions in the reaction vessel.  The
physical condition of species present .(liquid, jsolid, or gaseous phase),
condition of temperature and pressure, the presence of solvents and catalysts,
and the configuration of process equipment are designed to favor a reaction
pathway by which a particular product is produced.  From this knowledge, it is
possible to identify .reactive intermediates and  thus anticipate species
(potential pollutants) formed.

     Most chemical transformations performed  by  the  OCPSF  industry may be
reduced to a small number  of  basic steps or unit processes.  Each step or
process represents a  chemical modification of the starting matrials  and  is
labeled a "generic process."  For example, the generic process  " nitration"
may  represent  either  the substitution  or addition of an «-N02"  functional
group  to an organic  chemical.  Generic processes may be quite  complex
 involving a number of chemical  bonds being broken and formed,  with  the overall
 transformation passing through  a number of distinct (if transitory)  !-• ar-
 mediates.   Simple stoichiometic equations,  therefore, ar~
 descriptions  of chemical reactions  and only  rarely account for observed
 by-products.

      Table V-36 lists the major organic chemicals produced by the OCPSF
 industry (approximately 250) by process, and Table V-37 gives the same
 information for the plastics/synthetic fibers industry.  Certain products
 shown in Table V-36 are not  derived from primary  feedstocks, but rather from
 secondary or higher order materials (e.g., aniline  is  produced by hydrogena-
 tion of nitrobenzene  that is produced  by .nitration  of  benzene).  For such
 multistep syntheses,  generic processes appropriate  to  each  step must be
 evaluated separately.   For many commodity and bulk chemicals,  it is sufficient,
 to  specify a  feedstock  and a single generic  process,  because  they are gener-
 ally  manufactured by a  one-step process.  Nitration of benzene to  produce
 nitrobenzene,  for example,  is  a sufficient  description to predict  constituents
 of  the process wastewater:   benzene,  nitrobenzene,  phenol,  and nitrophenols
 will  be the  principal process  wastewater constituents.  Similarly,  oxidation
  of  butane  to produce acetic acid results; in wastewater containing a *ide
  variety of oxidized species, including formaldehyde, methanol, acetaldehyde,
  n-propanol,  acetone, methyl ethyl ketone,  etc.
                                       V-51

-------
[nic Chemical Products
                                           ••O*OO*O*O*O* OO»OO«OO««
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                                 • e««o

-------
                                                                                                                        Table V-36
                                                                                  Generic Processes Used to  Manufacture Orga
AUCOXYLATION

CONDENSATION

HALOCENATION

OXIDATION

POLYMERIZATJOM

HYDROLYSIS

HYOROGENATION

ESTERIRCATION

 PYROLYSIS

 ALKYLATKJN

 OEHYOROGENAT10N

 AMINAT10N (AMMONOLYSIS)

 NTTRATION

 SULFONAT1ON

 AMMOXIDAT10N

 CARBONYLATION

 HYDROHALOGENAT10N

 DEHYDRATION

 DEHYOROHALOCENAT1ON

  OXYHALOGENATTON

 CATALYTIC CRACKING

 HYDRODEALKYLATION

  PH05CENATK5N

  EXTRACTION

  DISTILLATION

  OTHER

  HYDRATK3M
                                                             «e«  «o
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0*00
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                                         V-52

-------

-------
                                                                                                 Tabh


                                                                  Generic  Processes Used to
      GENERIC

      PROCESS
                       Jl
                       |U VI
ALKOXYLATK3N




CONDENSATION




HALOGENATION




OXIDATION




POLYMERIZATION




HYDROLYSIS




HYDROCENATION




ESTERIFICATION




 PYROLYSIS




 ALKYLATION




 DEHYDROGENATION




AMtNATION (AMMONOLYSIS)




 NITRATION




 SULFONATION




 AMMOXIDATJON




 CARBONYLATION




 HYDROHALOCENATION




 DEHYDRATION




 DEHYOROHALOGENAT10N




 OXYHALOGENATION




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 PHOSCENATJON




 EXTRACTION




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                                              V-53

-------

-------
i (Continued)
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-------
     Specialty chemicals, on the other hand, may involve several chemical
reactions and require a fuller description.  For example, preparation of
toluene diisocyanate from commodity chemicals involves four synthetic steps
and three generic processes as shown below:
                               Phosgenation
                                                 N
                                                 C
                                                 0
 This example is relatively simple and manufacture of other specialty chemicals
 may be more complex.  Thus, as individual chemicals become further removed
 from the basic feedstocks of the industry, fuller description is required for
 unique specification of process wastewaters.  A mechanistic analysis of
 individual generic processes permits a spectrum of product classes to be
 associated with every generic process provided a feedstock is specified.  Each
 product class represents compounds that are structurally related to the
 feedstock through the chemical modification afforded by the generic process.

          b.  Product/Process Chemistry Overview
      The primary feedstocks of the OCPSF  industry  include:  benzene,  toluene,
 o,p-xylene, ethene,  propene, butane/butene, and methane; secondary  feedstocks
 include  the principal  intermediates  of  the  synthetic routes to  high-volume
                                       V-55

-------
 organic chemicals and plastics/synthetic  fibers.  Other products  that are
 extraneous to  these routes, but are priority pollutants, are also considered
 because of their obvious importance to guidelines development.

      Flow charts used to illustrate a profile of the key products of the two
 categories were constructed by compositing the synthetic routes from crude oil
 fractions, natural gas, and coal tar distillates (three sources of primary
 feedstocks) to the major plastics and synthetic fibers.  Figures V-l through
 V-7 depict the routes through the eight primary feedstocks and various inter-
 mediates to commercially produced organic chemicals; Figures V-8 and V-9 show
 the combinations of monomers that are polymerized in the manufacture of major
 plastics and synthetic fiber products.  "Also shown in Figures V-l through V-7
 are processes in current use within these industries.

      These charts illustrate the tree-shaped structure of  this  industry's
 product  profile (i.e.,  several products derived  from the same precursor).   By
 changing the  specific  conditions of a process, or use  of a  different  process,
 several  different groups of products can  be  manufactured from the  same  feed-
 stock.   There is  an obvious advantage in  having  to purchase and  maintain  a
 supply of  as  few  precursors (feedstocks)  and  solvents  as possible.  It  is also
 important  to  integrate  the^product  mix at  a  plant so that one product provides
 feedstock  for another.   A typical chemical plant  is  a  community  of production
 areas, each of  which may produce a  different product group.  While the product
 mix at a given  plant is  self-consistently  interrelated, a different mix of
 products may be manufactured from plant to plant.  Thus, a  plant's product mix
 may be independent of, or may complement the product mix at, other plants
within a corporate system.

     The synthetic routes to priority pollutants are illustrated in Figures
V-10 through V-14; these flow charts provide a separate scheme for each of the
following five classes of generic groups of priority pollutants:

     1.   Nitroaromatic compounds, nitrophenols,  phenols, benzidines and
         nitrosamines
     2.   Chlorophenols,  chloroaromatic  compounds,  chloropolyaromatic
         compounds,  haloaryl ethers  and  PCBs
                                    V-56

-------


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 Monomer(s)


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 Polybutadiene
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 Acrylic acid esters

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                            Fibers  Spinning    Notes
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                                     Source: Wise  & Fahrenthold,  1981.
                              Figure V-8
                          Plastics and Fibers
                                V-64

-------
Monomer(s)


Terephthalic acid   —
Dimethyl terephthalate
Ethylene glycol—	
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                              Alkyd Resins
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 Cellulose-
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 Diketene	—	
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 Dicyclopentadiene


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Petroleum
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salt


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Plastics Polymerization    Fiber Spinning
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                                                Notes
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                                                       Priority pollutant
                                                     & Fahrenthold; 1)981.
                               Figure V-9
                            Plastics and Fibers
                                   V-65

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     3.   Chlorinated C2 and C4 hydrocarbons; chloroalkyl ethers
     4.   Chlorinated C3 hydrocarbons, acrolein, acrylonitrile, isophorone, and
         chloroalkyl ethers
     5.   Halogenated methanes.

The generic processes associated with these synthesis routes are denoted by
numbers individually keyed to each chart.

     The precursor(s) for each of these  classes is reasonably  obvious  from the
generic group name.  Classes  1 and 2 are,  for  the most  part,  substituted
aromatic compounds, while Classes 3, 4,  and 5  are derivatives  of ethylene,
propylene, and methane,  respectively.  The common response  of  these precursors
to  the chemistry  of a  process has important implications, not  only for the
prediction of priority  pollutants, but for their regulation as well;  that  is,
group members generally occur together.

     It  is significant to  note that  among the many  product/processes of the
 industry,  the  collection of products and generic  processes  shown in Figures
V-10 through V-14 are primarily responsible for the generation of  priority
 pollutants.  The critical precursor-generic process combinations associated
 with these products are summarized in Table V-38.   While there may be critical
 combinations other than those considered here, Table V-38 contains the most
 obvious and probably the most likely combinations to be encountered in the
 OCPSF industrial categories.
          c.
              Product/Process Sources of Priority Pollutants
      The product/processes  that generate priority pollutants become obvious if
 the synthesis routes  to  the priority pollutants are,  in effect, superimposed
 upon the synthesis  routes employed  by  the  industry  in the manufacture of  its
 products.  Figure V-15 represents a priority  pollutant profile  of  the OCPSF
 industry by  superimposing Figure V-l  through  V-9  and  V-10 through  V-14  upon
 one another  so  as  to  relate priority  pollutants  to  feedstocks and  products.

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      In  any  product/process,  as  typified  by  Figure V-16,  if  the  feedstock
  (reactant),  solvent,  catalyst system,  or  product  is a priority pollutant,  then
  it is likely to  be  found  in  that product/process  wastewater  effluent.  Equally
  obvious  are  metallic  priority pollutants, which are certainly not  transformed
  to another metal  (transmutation) by exposure to process conditions.  Since
  side reactions are  inevitable and characteristic  of all.co-products of the
  main reaction, priority pollutants may appear among the several  co-products of
  the main reaction.  Subtler sources of priority pollutants are the impurities
  in feedstocks and solvents.

      Priority pollutant impurities may remain unaffected, or be  transformed to
 other priority pollutants, by process conditions.   Commercial grades of
 primary feedstocks and solvents commonly contain 0.5 percent or more of
 impurities.   While 99.5 percent purity approaches  laboratory reagent quality,
 0.5 percent  is nevertheless equal to 5,000 ppm.  Thus,  it is not  surprising
 that  water coming into direct contact with these process streams  will acquire
 up to 1  ppm  (or more)  of the impurities.   It  is  not  unusual to find priority
 pollutants representing raw material impurities  or their derivatives reported
 in the 0.1-1  ppm concentration range in analyses of  product/process effluents.
 Sensitive instrumental methods currently employed  in wastewater analysis  have
 the ability of measuring priority pollutants  at  concentrations below 0.1  ppm.
 Specifications or assays of commercial chemicals at  these  trace levels  are
 seldom available,  or were not  previously (before BAT) of any  interest,  since
 even  0.5  percent  impurity in  the  feedstock and/or  solvent  would typically have
 a negligible  effect  on process efficiency  or  product quality.  Only in  cases
 where impurities  affect a  process  (e.g., poisoning of a  catalyst) are contami-
 nants specifically limited.

          d'   Priority  Pollutants in Product/Process Effluents
     During the Verification sampling program, representative samples were
 taken from the effluents of 147 product/processes  manufacturing organic chemi-
cals and 29 product/processes  manufacturing plastics/synthetic fibers.  These
176 product/processes  included virtually all those shown in Figures V-l
through V-9.   Analyses of  these samples, averaged  and summarized  by individual
product/processes, showed  the priority pollutants  observed in these effluents
                                     V-74

-------
[Reactant(s)]•
(Impurities)
                        •Catalyst-
-CHEMICAL-
 PROCESS •
                            Spent Catalyst-
[Product(s)]
                         • [Solvent ]•*-
                                  Equipment
                                  Cleaning
                           • Derivatives—
                           of Impurities
                            Coproducts-
                            Byproducts-

                            Miscellaneous
                            Res inous	
                            Materials*
                                                     Material
                                                     Losses
                                Notes
                                	  Limits of the process area in the
                                      plant.
                                  *    Still bottoms, reactor coke, etc.

                                Source:  Wise & Fahrenthold, 1981.
                               Figure V-16
                           A Chemical Process
                                   V-75

-------
 to be consistent with  those  that  can  be predicted, based on  the precursor
 (with impurities) generic process combinations.

      Consistency between observation  and prediction was most evident at con-
 centrations >0.5 ppm.  Below that level, an increasing number of extraneous
 priority pollutants were reported that were unrelated to the chemistry or
 feedstock of the process, and typically reported at concentrations less than
 0.1 ppm.  These anomalies could usually be attributed to one or more of the
 following sources:

      •  Extraction solvent (methylene chloride), or its associated impurities,
         e.g.,  as residuals in the GC/MS system from previous runs
      •  Sample contamination during sampling or during sample preparation at
         the laboratory (e.g., phthalate leached from anhydrous sodium sulfate
         used to dry the concentrated extract prior to injection into the GC)
      •  In-situ generation in the wastewater collection system (sewer).

 In the reconciliation of product/process  effluent analytical data,  it was
 expedient  to initially sor.t  out  the  extraneous from the significant priority
 pollutants.  In most  cases,  only the latter can be related  to the  product/
 process.   Less  than half of  the  effluents of key product/processes  manufac-
 turing organic  chemicals contained priority pollutants  at concentrations
 greater  than 0.5 ppm.   The generic groups of priority pollutants associated
 with  these product/processes  are summarized in Table V-39 and are consistent
 with  those predicted  in Table V-36.  Many product/process effluents have
 little potential to contain greater  than 0.5 ppm of priority  pollutants,
 because they do  not involve critical precursor-generic process combinations.

     Generic classes of priority pollutants reported at >0.5  ppm in the
 effluent of product/processes manufacturing plastics/synthetic fibers are
 summarized in Table V-40.  The priority pollutants found in polymeric product/
 process effluents are usually restricted to the monomer(s) and its  impurities
or derivatives.  Since all monomers or accompanying impurities are not pri-
ority pollutants, some plastics and synthetic fibers effluents are essentially
free of priority pollutants.
                                     V-76

-------
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-------
                                 TABLE V-40.
                   PLASTICS/SYNTHETIC FIBERS EFFLUENTS WITH
                    SIGNIFICANT CONCENTRATIONS (>0.5 ppm)
                           OF PRIORITY POLLUTANTS
Product
Monomer(s)
    Associated
Priority Pollutants
ABS resins



Acrylic fibers



Acrylic resins (Latex)



Acrylic resins

Alkyd resins



Cellulose acetate


Epoxy resins



Phenolic  resins


Polycarbonates




Polyester
Acrylonitrile
Styrene
Polybutadiene

Acrylonitrile
Comonomer (variable)
Vinyl chloride

Acrylonitrile
Acrylate Ester
Me thylme thacrylate

Methylmethacrylate

Glycerine
Isophthalic acid
Phthalic anhydride

Diketene (acetylating
   agent)

Bisphenol A
Epichlorohydrin
 Phenol
 Formaldehyde

 Bisphenol A
 Terephthalic acid/
 Dimethylterephalate
 Ethylene glycol
Acrylonitrile
Aromatics
Acrylonitrile

Chlorinated C2's

Acrylonitrile
Acrolein


Cyanide

Acrolein
Aromatics
Polyaromatics

Isophorone
Phenol
Chlorinated C3's
Aromatics

Phenol
Aromatics

(Not  investigated)
Predicted:  Phenol
Chloroaromatics
Halomethanes

Phenol
Aromatics
                                      V-81

-------
                                  TABLE V-40.
                   PLASTICS/SYNTHETIC  FIBERS EFFLUENTS WITH
                     SIGNIFICANT CONCENTRATIONS (>0.5 ppm)
                      OF PRIORITY POLLUTANTS (Continued)
Product
HD Polyethylene resin
Polypropylene resin
Polystyrene
Poly vinyl chloride resin
SAN resin
Monomer (s)
Ethylene
Propylene
Styrene
Vinyl chloride
Stvrene
Associated
Priority Pollutants
Aromatics
Aromatics
Aromatics
Chlorinated C2'
Arnmati r.502)
Polybutadiene

Maleic anhydride
Phthalic anhydride
Propylene glycol
(Styrene added later)
Acrylonitrile

Aromatics
Phenol
Aromatics
                                    V-82

-------
     In comparison with effluents from product/processes manufacturing- organic
chemicals, effluents from polymeric product/processes generally contained
fewer priority pollutants at lower concentrations.  The polymeric plastics and
fibers considered in this report have virtually no water solubility.  Further-
more, the process is designed to drive the polymerization as far to completion
as is practical and to recover unreacted monomer (often with its impurities)
for recycle to the process.  Thus, the use of only a few priority pollutant-
related monomers, the limited solubility of polymeric products, and monomer
recovery, results in the reduction of the number of priority pollutants and
their relative loading in plastics/synthetic fibers effluents.

     Table V-41 lists priority pollutants detected in OCPSF process
wastewaters by precursor/generic process combinations.  Priority pollutants
are generically grouped and the groups are arrayed horizontally.  Priority
pollutants reported from Verification analyses of product/process effluents
are noted in  four, concentration ranges, reading across  from each precursor.
-This arrangement  makes it more apparent, particularly at higher concentration
ranges,  that  reported priority pollutants tend to aggregate within  those
groups  that would be expected from  the corresponding precursor-generic  process
combination.

     In contrast  with organic priority pollutants  that  are co-produced  from
other  organic chemicals, metallic priority pollutants cannot  be  formed  from
other  metals.  Except  for  a possible change  of oxidation state,  metals  remain
immutable throughout  the generic  process.  Thus,  to  anticipate metallic
priority pollutants,  the metals  that were introduced  into a generic process
must be known.

     Metallic priority  pollutants,  individually  and  in  combinations,  are most
often  related to a  generic process  via  the catalyst  system.   The metals
comprising catalyst systems that  are commonly employed  with  particular
precursor/generic process  combinations  to manufacture important  petrochemical
products have been  generally  characterized  in the technical  literature
 (especially in patents).   An  obvious way to  offer clues for  predicting
metallic priority pollutants  was to expand  the generic  process descriptors in
 the listing of Table V-41  to  include this  information.
                                      V-83

-------

-------
                                                      Priority Pollutants in  Effluents ofl
                      PHENOLS
                                      POLYAROMAT1CS
                                              NITROARC

                                CHLOROPHENOLS
                   CHLOROAROMATICS    HALOARYL E




PRODUCT
PROCESS
CODE








0890-01
0530-01
3393^01
0949-01
3300-01
1244-01
3295-02
3410-03
08.10-01

1650-01
19 80-0 Z
3120-02

35ZO-80
3530-02

1221-01
3535-01

3015-01
3354-01

0185-04
1700-01
1800-01

0820-03

0080-02
2690-01
2265-02
1450-01
\y PRIORITY
N. POLLUTANT
N. GROUPS

\^
^^
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PRECURSOR N.
(FEEDSTOCK) \
N.
\
DIRECT CHLORINATION
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Toluene
1,4-Dichlorobenzene
Nitrobenzene
Phthalic anhydride
Ethylene
Ethylene dichloride4
Ethylene dichloride5
Methane6
CHLOROHYDRINATION
Allyl chloride
Ethylene 1
Propylene ^
DEHYDROCHLORINATION
Ethylene dichloride
1,1,2-Trichloroethane
HYDROFLUORINATION
Carbon tetrachloride
1,1,1-Trichloroe thane
PHOSGENATION
Poly MDA8
2,4-Tolylenediamine
AMMONATION
Adipic acid
Ethanol
Ethylene dichloride9
ACETYLATION
Cellulose/Acetic anhyd.
DEHYDRATION
Acetic acid
Cumene hydroperoxide
t-Butanol
Acetic acid









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1. Eitnnituii  to pnduct/pfoe««t.
2. Fil» miatlit.
3. 1210-01.1220-01 h«t« ilnllir (Bilytn.
4. 0810-04. hn (lillal >aily»le.
9. Chlorlnitid C2*i «r« ilailm  Ira* this iailr>l>-
8. 0830—02.2820—02.2380—03 h«»  i.lailir •n»lyl».
 a I
lol
                                   V-84

-------
IM,

-------
                                                                          table V-4J

                                  Priority  Pollutants in Effluents of.Precurs
      PHENOLS

AROMAT'ICS
POLYAROMATICS
                                                N1TROAROMAT1CS

                                    CHLOROPHENOLS       NITROPHENO|

                         CHLOROAROMATICS    HALOARYL ETHERS
\ PRIORITY
\ POLLUTANT
1
PRODUCT
PROCESS
CODE








0890-01 1
0530-01 '
3393-01
0949-01
3300-01
1244-01
3295-02
3410-03
08.10-01
1650-01
1980-02
3120-02
3520-80
3530-02
1221-01
3535-01

3015-01
3354-01

0185-04
1700-01
1800-01
0820-03
0080-02
2690-01
2265-0<
1450-01
\ GROUPS
\
\

\
\
\
PRECURSOR \
(FEEDSTOCK) \



:

1
c y c fl>
o

i = 1 <


<5 '
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• ^ r
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\ 1 CO O — I -^ • °
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DIRECT CHLORINATION 1 J~
Benzene 3
roluene
1,4-Dichlorobenzene
Nitrobenzene
Phthalic anhydride
Ethylene
Ethylene dichloride4
Ethylene dichloride5
Methane6
CHLOROHYDRDMATION
Allyl chloride
Ethylene 7
Propylene 7
DEHYDROCHLORINATION
Ethylene dichloride
1,1,2-Trichloroe thane
HYDROFLUORINATION
Carbon tetrachloride
1,1,1-Trichloroe thane
PHOSGENATION
Poly MDA8
2,4-Tolylenediamine
AMMONATION
Adipic acid
Ethanol-
Ethylene dichloride9
ACETYLATION
Cellulose/ Acetic anhyd.
DEHYDRATION
. Acetic acid
Cumene hydroperoxide
, t-Butanol
Acetic acid
#• • 0
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                     V-84

-------

-------

-------
 »r-Generic Process  Combinations
 LS   BENZIOINES
 POSAMIMES     PHTHAUATES  HALOGENATEO METHANES
              CHLORINATED C3's       MISCELLANEOUS
CHLORINATED C2's          CHLOROALKYL ETHERS
                                                       METALS
\l
m— — 1
Iff!
1
1
1
I
1
1
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1.3-Dichloroprops
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bis(Chloroethyl)el
bis(2-Chlorolsopr
2-Chloroelhylvlny
bis(2-Chloroatho:







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Acrolein
Acrylonitrlle
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                                                     4c=0.1 - O.S ppm
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                                                        (ailed lo ilnioct

-------
                                                                              Table V-41 {Contir
                                           Priority  Pollutants in  Effluents  of Precursor-]
               PHENOLS

        AROMATICS
POLYAROMATICS
                                                   NITROAROMATICS

                                      CHLOROPHENOLS        NITROPHENOLS
                          CHLOROAROMATICS    HALOARYL ETHERS      NITRIC



PRODUCT
PROCESS
CODE






ESTERJJ
2665-02
3066-01
0240-01
3510-05
0165-09
0165-10
0165-02
0165-11
2470-02
1530-01
3006-21
2883-01
2859-01
2863-01
2886-01
0189-01
3501-01
2951-02
2680-01

2090-01
2090-03
2460-01
3042-80
1660-01
2360-01
0650-01

2460-01
2665-02
0192-04

0185-05

2070-01
3570-02
\v PRIORITY
\ POLLUTANT
\ GROUPS

\

\
\
PRECURSOR \
(FEEDSTOCK) \
\
\
[CATON/POLYMERIZATIO
Acetone cyanohydrin
Acetic acid/n-Piropanol
Acetic acid/Pentanol (Amyl
Acetic acid/Ethylene
Acrylic acid/n-Butanol
Acrylic acid/Ethajiol
Acrylic acid/Isobutanol
Acrylic acid/2-Ethylhexanol
MMA/Butanol
TPA/Methanol
TPA/Ethylene glycol
PA/Ethanol
PA/2-Ethylhexanol
PA/C11-C14 Alcohols
PA/Butanol/Benzyl chloride
PA Glycerin
PA/MA/Propylene glycol
POCl3/Phenol/Isodecanol
Salicylic acid/Methanol
HYDRATTON/HYDROLYSIS
Allyl alcohol
Epichlorohydrin
Acetone cyanohydrin
Polyviny} acetate 2
Ethylene
Propylene
Butene
HYDROCYANA-nON
Acetone
Acetone/Methanol
C13-C19 Olefins
HYDRODIMEREATION
Acrylonitrile
EOMERZZAT7.ON
Maleic acid
m-Xylene







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-------
 nued)
r-Generic Process Combinations
[NOtS   DENZIDIN'ES
H1TROSAMINES    PHTHALATES  HALOGENATED METHANES
              CHLORINATED C3's       MISCELLANEOUS
CHLORINATED C2's          CHLOROALKYL ETHERS
METALS



I
10


































f"
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H-rtttrojod»t>rnnyl am
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Bonzldlno
3.3'-DJchto
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6
0
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1.3-Dichloropropyler



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                                                         failed to delect

-------
                                                                          Table V-41 (Cont|
                                        Priority Pollutants  in Effluents  of Precurs<
               PHENOLS
                              POLYAROMATICS
                                              NITROAROMATICS
                                  CHLOROPHENOLS        NITROPHf]
                      CHLOROAROMATICS    HALOARYL ETHERS



PRODUCT
PROCESS
CODE






AI
0005-01
3172-01
3235-01
3030-02
3030-04
0153-01
0155-03
2856-01
3008-01
3008-04
3020-03
3040-01
3048-02
3048-01
3048-04

0156-01
3145-01
CONDEN
0560-01
2000-01
1656-01
2443-01
2905-01
3506-01
2825-01
2825-03
3013-01

1830-01
1300-01
3325-02
1666-03
1666-02

3025-01
3025-02
NV PRIORITY
\ POLLUTANT
>v GROUPS
\^
^y
*v
\^
\
PRECURSOR \y
(FEEDSTOCK) \
N.
\
DITION POLYMERIZATION
ACN/Polybutadiene/Styrene
ACN/Styrene
Styrene/Butadiene
Styrene (suspension)
Styrene (bulk)
ACN/AA esters/MMA
tfethylmethacrylate
Mcyclopentadiene
Ethylene (HDPE)
Ethylene (LDPE)
Propylene
Vinyl acetate
Vinyl chloride (susp.)
Vinyl chloride (etnul.)
Vinyl chloride (bulk)
FIBER SPINNING
Acrylic resin
Cellulose
SAT1ON/POLYMERIZATION
Acetone/Phenol
n-Butyraldehyde
Epichlorohydrin/Bisphenol A
Melamine/Formaldehyde
Phenol/Formaldehyde
Urea/Formaldehyde
Caprolactam
Nylon salt
Aniline/For m aldehyde
ETHOXYLAITON
Ethylene oxide/water
Ethylene glycol2
Ethylene glycol still btm's3
Cll, C12 Linear alcohols3
Alkylphenol
PROPOXYLATION
Propylene glycol
Glycerin







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2.  3480-01 hit ilill.r indyilt.
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3.  3480-03 hi« «l«llir inilysU.
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-------
ued)
Generic Process  Combinations
  BENZIOINES                                                      CHLORINATED C3's       MISCELLANEOUS
SAMINES    PHTHALATES  HALOGENATED METHANES      CHLORINATED C2's        • CHLOROALKYL ETHERS              METALS

,i
I H-Wcoiodtptonyl «m»i
I H-Hilrojodi-n-piopyl i


































1,2-D»ptvoO.S ppm
    *=0.1 - 0.5 ppm
    0 =r,01 - 0.1 ppm
    0 =<-01 ppm, or analysis
       (ailed lo detect

-------
                                                                    Tabfe  V-47 (Contin
                                Priority  Pollutants in  Effluents of Preeursor-
     PHENOLS
                     POLYAROMATICS
                                   NITROAROMATICS
                      CHLOROPHENOLS        NITROPHENd
         CHLOROAROMATICS    HALOARYL ETHERS       Nil



PRODUCT
PROCESS
CODE







1770-01
1770-02
1770-04
0130-03
E
0380-02
0380-04
0380-09
0590-01
1171-01
2701-02
2265-01
1710-02
2350-02
.0720-01"

1710-01
1060-01
'0195-01

0380-01

0785-06
0785-09

1171-01
1450-01

3170-01


1550-01
2770-01

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>v PRIORITY
N. POLLUTANT
\. GROUPS
\^
N.
\^
N.
\
PRECURSOR \^
(FEEDSTOCK) \
\^
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CRACKING
LPG2
Naphtha/Gas oil
Naphtha/LPG 4
Naphtha/LPG
TRACTION/DISTILLATION
Catalytic reformate 5
Coal tar light oil
Pyrolysis gasoline
C4' Pyrolyzates
C5 Pyrolyzates
?yrolysis gasoline
C4 Pyrolyzates
BTX Extract '-•
C5 Pyrolyzates
C4 Pyrolyzates
ALKYLATION
Benzene/Ethylene
Benzene/Propylene 9
Phenol/Octene/Nonene
HYDRODE ALKYLATION
Toluene/Xylene
OXIMATION
Phenol/Cyclohexanone
Cyclohexane/Cyclohexanon
DIMEREATION
Cyclqpentadiene
Ketene
CARBOXYLATION
Phenol
NITRATION

Toluene
Benzene
DLAZOTIZATION
2,4,6-Trichloroaniline
Aniline
4-Nitro.aniline
2-Nitro aniline







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1. Eilnn«nu«  to pfsdus t/proe«ii.
Z. 3090-02 nat aliilar  cndysla.
3. 3890-03 kaa alilltr  caaiyaia.
4. 3080-11 hot Jl»li = r  =ll»! .mlyi.t.
1.  3580-01 ha« altllir an
-------
ontinued)
rsor-Generic Process Combinations
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-------
                                                              Table V-41 (C|
                                Priority Pollutants in Effluents  of  Preci
     PHENOLS
AROMATICS
                  POLYAROMAT1CS
                      NITROAROMATICS
           CHLOROPHENOLS       NlTROPHEl
CHLOROAROMATICS   HALOARYL ETHERS



PRODUCT
PROCESS
CODE









2430-01
0091-01
1135-01
0180-80
2960-01
2960-02
3280-01
0030-02
1980-01
0140-01
0160-80
0180-01
2640-07
0070-04
3066-01
2200-01
0130-01
0180-03
0430-01

0200-01
2165-02
0640-02
2500-02
3351-01
0300-04
2000-01
3070-01

0185-04
3230-01
2500-02
2040-01
0090-11
2640-01
HYDRO1
3050-01
2750-01
0640-02
0070-05
0160-03
\ PRIORITY
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Cumene4
Cyclohexane
Cyclohexane/-ol/-one
Naphthalene
o-Xylene
p-Xylene5
ithylene
ithylene
'ropylene 6
Propylene
Cyclohexanol
sec-Butanol/Acrolein
Acetaldehyde
'ropionaldehyde
Aniline
Methane
~yclohexanol/one mix
Toluene 8
• HYDROGENATION -
Acrolein/sec-Butanol
Adiponitrile
n-Butyraldehyde 9
Carbon monoxide
Dinitrotoluene
Nitrobenzene
2-Ethyl-2-hexenal
'ropionaldehyde
DEHYDROGENATION
Adipoamide
Jthylbenzene
•iethane
rlethanol
sopropanol
sec-Butanol
ORMYLATION/CARBONYL
ithylene
sobutylene
*ropylene
ilethanol
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                V-86

-------
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-------
     Copper, chromium, and zinc were the metallic priority pollutants most
frequently reported in the higher concentration ranges for all product/process
effluents.  Copper and chromium are used in many catalyst systems.  Another
significant source of chromium, as well as zinc, is the "blowdown" that is
periodically wasted from an in-plant production area's recycled noncontact
cooling water.  These metals find application in noncontact cooling waters as
corrosion inhibitors.  In some wastewater collection systems, it is possible
for the blowdown to become mixed with product/process effluent before the
combined flow leaves the production area to join the main body of wastewater
within the plant.  Another source of metallic priority pollutants is the
normal deterioration of production equipment that comes into contact with
process water.

     Extraneous or unexpected priority pollutants were also reported in
product/process effluents.  Priority pollutants may be considered extraneous
when they cannot be reconciled with the precursor (or its impurities) and the
process chemistry.  In Table V-41, extraneous priority pollutants were noted
only when they were reported at greater than 0.5 ppm.  Thus, the  failure  to
flag a priority pollutant at less than 0.5 ppm does not necessarily preclude
it from being extraneous.  As a general rule, one extraneous generic group
member indicates that the entire group is probably anomalous.  These data are
presented here to assist NPDES permit writers in establishing effective
monitoring  requirements for OCPSF plants' end-of-pipe discharges.  The
phthalate esters are  an example of such a group  that persisted  throughout the
Verification data.  Except for processes  that manufacture phthalate esters,
these priority pollutants are now recognized as  analytical artifacts and
edited out  of the BAT and PSES effluent limitations data base.

E.   RAW  WASTEWATER CHARACTERIZATION DATA

     1.   General
     As described under "Water Usage"  earlier  in this  section,  the OCPSF
industry  generates significant volumes of process wastewater  containing a
variety of  pollutants.  Most  of  this raw  wastewater  receives  some treatment,
either as an  individual process waste  stream or at a wastewater treatment
                                      V-89

-------
 plant serving waste streams from the whole manufacturing facility (see Section
 VII).  To decide what pollutants merit regulation and evaluate what technol-
 ogies effectively reduce discharge of these pollutants, data characterizing
 the raw wastewaters were collected and evaluated.  This section describes the
 Agency's approach to this important task and summarizes the results.

      2.  Raw ffastewater Data Collection Studies
      Section III of this document introduced the many wastewater data
 collection efforts undertaken for development of these regulations.   Studies
 that produced significant data on raw wastewater characteristics include the
 308 Surveys,  the Phase I and II screening studies,  the Verification Study,  the
 EPA/CMA Five-Plant Study and the New 12-Plant Sampling Program.   The 308
 Surveys have been described in Section III;  the remaining studies are
 summarized in Table V-42 and are discussed below.  The results of the studies
 are presented in the "Wastewater Data Summary"  at the end of this Section.

      3.   Screening Phase I
      The wastewater quality data reported in the 1976 Section 308 Question-
 naire were the result  of monitoring and analyses by each of the  individual
 plants  and their contract laboratories.   To  expand  its priority  pollutant data
 base and improve data  quality  by minimizing  the discrepancies among  sampling
 and analysis  procedures,  EPA in 1977  and  1978 performed  its Phase I  Screening
 Study.   The Agency and  its  contractors sampled  at 131 plants,  chosen because
 they operated product/processes that  produce the highest  volume  organic
 chemicals  and plastics/synthetic fibers.

      Samples  were  taken  of  the  raw  plant  water,  some  product/process  influents
and  effluents, and  influents and effluents at the plant wastewater treatment
facilities.   Samples were analyzed  for all priority pollutants except
asbestos, and  for several conventional and nonconventional  pollutants.
Screening samples were collected and analyzed in  accordance with  procedures
described in  the 1977 EPA Screening Procedures Manual.  Samples for
liquid-liquid extraction  (all organic pollutants  except the volatile fraction)
and for metals analyses were collected in glass compositing bottles over a
24-hour period, using an automatic sampler generally set for a constant
                                     V-90

-------

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                V-92

-------
aliquot volume and constant time, although flow- or time-proportional sampling
was allowed.  For metals analysis, an aliquot of the final composite sample
was poured into a clean bottle.  Some samples were preserved by acid addition
in the field, in accordance with the 1977 EPA Screening Procedures Manual;
acid was added to the remaining samples when they arrived at the laboratory.

     For purge and trap (volatile organic) analysis, wastewater samples were
collected in 40- or 125-ml vials, filled to overflowing, and sealed with
Teflon-faced rubber septa.  Where dechlorination of the samples was required,
sodium thiosulfate or sodium bisulfite was used.

     Cyanide samples were collected  in 1-liter plastic bottles as  separate
grab samples.  These samples were checked for chlorine by using potassium-
iodide starch test-paper strips,  treated with ascorbic acid  to eliminate  the
chlorine, then preserved with  2  ml of ION sodium hydroxide/liter of sample
(pH 12).

     Samples  for  total  (4AAP)  phenol colorimetric  analysis were collected in
glass  bottles as  separate grab samples.  These samples .were  acidified with
phosphoric  or sulfuric  acid  to pH 4, then sealed.
                1  1      -
     All samples  were maintained at  4°C  for  transport  and  storage  during
analysis.   Where  sufficient  data were available,  other sample preservation
requirements (e.g.,  those  for  cyanide,  phenol, and VOAs by purge  and  trap as
described above)  were deleted  as appropriate (e.g., jif chlorine was known to
be absent).  No analysis was performed  for  asbestos during the Phase  I
screening effort.
         i
      In general,  the Phase I Screening Study generated data that  were
 qualitative in nature due to false positive pollutant identification, which
 occurs as a result of the procedures used for interpreting ambiguous pollutant
 identification based on the 1977 screening level GC/MS analytical protocols
 and QA/QC procedures.   These procedures are discussed in more detail in
 Section VI of this document.
                                      V-93

-------
       4.   Screening Phase II
       In  December 1979,  samples  were collected  from an  additional  40 plants
  (known as Phase II facilities)  manufacturing products  such  as  dyes,  flame
  retardants,  coal tar  distillates,  photographic chemicals, flavors,  surface
  active agents,  aerosols,  petroleum additives,  chelating agents, micro-
  crystalline  waxes,  and  other low-volume specialty  chemicals.   As  in  the
  Phase I  Screening  study,  samples were analyzed for all the  priority  pollutants
  except asbestos.   The 1977  EPA  Screening Procedures Manual  was followed in
  analyzing priority pollutants.  As  in Screening Phase I, some  samples for
  metals analysis were preserved  by addition of  acid  in the field (in  accordance
 with the 1977 Screening Manual) and acid was added  to the remaining  samples
 when they arrived at the laboratory.  In addition,  the organic compounds
 producing peaks not attributable to priority pollutants with a magnitude of at
 least 1 percent of  the total ion current were  identified by computer matching.

      Intake,  raw influent, and effluent samples were collected for nearly
 every facility sampled.   In addition, product/process wastewaters  that could
 be isolated at a facility were also sampled,  as were influents and effluents
 from some treatment technologies in place.   Fourteen direct  dischargers,
 24 indirect dischargers, and 2 plants discharging to deep  wells were sampled.
 Table V-43 lists the product/process and other  waste streams sampled at  each
 plant.                                      «

      As with  the Phase I Screening  Study, data  from this study  were  considered
 as  qualitative in nature for the same reasons stated for Phase  I.

      5.   Verification  Program
      The  Verification Program was designed to verify the occurrence and
 concentrations of specific priority  pollutants  in waste streams from
 individual product/processes and to  determine the performance of end-of-pipe
 treatment systems.

     The product/processes to be sampled were generally chosen  to maximize
coverage of the product/processes used to manufacture organic priority pollu-
tants, chemicals derived from priority pollutants, and chemicals produced in
                                     V-94

-------
                                 TABLE V-43.
                PHASE II SCREENING - PRODUCT/PROCESS AND OTHER
                     WASTE STREAMS  SAMPLED AT EACH PLANT
Plant Number
                                     Waste Streams Sampled.
    1

    2


    3

    4

    5

    6


    7

    8

    9.

    10


    11

    12

    13

    14

    15

    16



    17

    18

    19
Combined raw waste (fluorocarbon)

Anthracene                             :
Coal tar pitch

Combined raw wastes (dyes)
                                    •
Combined raw wastes (coal tar)

Combined raw wastes (dyes)

Oxide
Polymer

Freon

Freon

Ethoxylation

Nonlube  oil additives
Lube oil additives

Combined raw  wastes (dyes)

Combined raw  wastes (flavors)

Combined raw  wastes (specialty chemicals)

Combined raw  wastes (flavors)

 Hydroquinone

 Esters
 Polyethylene
 Sorbitan monosterate                     ;

 Dyes

 Combined raw wastes  (surface active agents)

 Fatty acids
                                       V-95

-------
                                  TABLE V-43.
                PHASE II SCREENING - PRODUCT/PROCESS AND OTHER
                WASTE STREAMS SAMPLED AT EACH  PLANT (Continued)
Plant Number
                                     Waste Streams Sampled
   20



   21

   22

   23

   24

   25

   26

   27

   28


   29

   30
  31

  32



  33

  34
 Organic pigments
 Salicylic acid
 Fluorescent brightening agent

 Surfactants

 Dyes

 Combined raw wastes (flavors)

 Chlorination of paraffin

 Phthalic anhydride

 Combined raw waste (unspecified)

 Dicyclohexyl phthalate

 Plasticizers
 Resins

 Combined  raw waste (unspecified)

 Polybutyl phenol
 Zinc  Dialkyldithiophosphate
 Calcium phenate
 Mannich condensation product
 Oxidized co-polymers

 Tris  (3-chloroethyl) phosphate

 Ether  sulfate sodium salt
 Lauryl sulfate sodium salt
 Cylene distillation

 Dyes

 Maleic anhydride
 Formox formaldehyde
 Phosphate ester
Hexamethylenetetramine
                                   V-96

-------
                                 TABLE V-43.
                PHASE II. SCREENING - PRODUCT/PROCESS AND OTHER
               WASTE,STREAMS SAMPLED AT EACH PLANT  (Continued)
Plant Number
     Wafste Streams Sampled
   35

   36

   37



   38

   39
    40
Acetic acid

Combined raw Waste (coal tar)

"680" Brominated fire,retardants
Tetrabromophthalic anhydride
Hexabromodyclodpdecane

Hexabromodyclododecane

Fatty acid amine ester
Calcium suylfonate in solvent  (alcohol)
Oil  field deemulsifier blend
   (aromatic solvent)
Oxylakylated phenol—:formaldehyde  resin
Ethoxylated monyl phenol
Ethoxylated phfenol—•formaldehyde resin

Combined raw waste (surface active agents)
                                      V-97

-------
  excess of 5 million pounds per year.  The priority pollutants selected for
  analysis in the waste stream from each product/process were chosen to meet
  either of two criteria:

       •  They were believed to be raw materials,  precursors,  or products,  in
          the product/process,  according to the process chemistry;  or

       *  5ey<>h!}d bfren.^tected ^ the grab samples taken several  weeks before
          the 3-day Verification exercise (see below)  at concentrations exceed-
          ing tne threshold concentrations listed 'in Table V-44.

       The threshold concentrations listed in Table  V-44 were  selected  as
 follows.  The concentrations  for pesticides,  PCBs, and other organics are
 approximate  quantitative  detection limits.   The concentrations  for  arsenic,
 cadmium,  chromium,  lead,  and  mercury  are one  half  the  National  Drinking Water
 Standard  (40 FR  59556 to  74j  December 24,  1975).

      The Agency  sampled at six integrated manufacturing  facilities  for the
 pilot program to develop  the  "Verification Protocol."  Thirty-seven plants
 were eventually  involved  in the Verification effort.    Samples were  taken from
 the effuents of  147 product/processes manufacturing organic chemicals and 29
 product/processes manufacturing plastics/synthetic fibers, as well as from
 treatment system influents and effluents at each facility.

      Each plant  was visited about 4 weeks before the  3-day Verification
 sampling to  discuss the  sampling program with plant personnel, to  determine
 in-plant sampling locations,  and to take a grab sample at each designated
 satopling^site.   These samples  were analyzed to develop the analytical  methods
 used  at each plant for the 3-day sampling exercise  and to develop  the  target
 list  of pollutants (analytes)  for analyses at each  site during the 3-day
 sampling.  Some  pollutants that  were  targeted for Verification,  since  they
 were  raw materials,  precursors,  or co-products, were  not  detected  in the
 Verification  program grab  samples.  If such  a pollutant was also not detected
 in the  sample from  the first day  of the 3-day  verification sampling, it was
 dropped  from  the  targeted  list of  analytes  for  that sample location.   Other
 compounds were added  to  the analysis list, since they were found in  the grab
sample at a concentration  exceeding the  threshold criteria in  Table  V-44.
                                     V-98

-------
Priority pollutants known by plant personnel to be present in the plant's
wastewater were also added to the Verification list.

     At each plant, Verification samples generally included:  process water
supply, product/process effluents, and treatment facility influent and
effluent.  Water being supplied to the process was sampled to establish the
background concentration of priority pollutants.  Product/process samples were
taken at locations that would best provide representative samples.  At various
plants, samples were  taken at the influent to and effluent from both
"in-process" and "end-of-pipe" wastewater treatment  systems.

     Samples were  taken on each of 3 days during  the Verification exercise.
Twenty-four hour composite samples for extractable  organic compounds  and
metals  were  taken  with automatic  samplers.   Where automatic  sampling  equipment
would violate  plant  safety codes  requiring explosion-proof motors,  equal
volumes of  sample  were collected  every 2 hours  over an 8-hour day and manually
composited,  Raw water supply samples were  typically collected as daily  grab
samples because of the low variability of  these waters.

      Samples  for  cyanide analysis were  collected as either a single grab
 sample each day or as an equal-volume,  8-hour composite of four aliquots every
 2 hours.

      For purge and trap  (volatile! organic)  analysis, duplicate grab samples
 were collected four times over an 8-hour period each day.

      The temperature and pH of the sample,  the measured or estimated
 wastewater flow at the time of sampling, and the process production levels
 were all recorded, particularly in connection with  operational upsets (in the
 production units or wastewater treatment facilities)  that could result in the
 collection of an unrepresentative sample.     ,

      It should be noted that for organic priority pollutants, gas  chroma-
 tography with conventional detectors (GC/CD) was used instead of GC/MS.  GC/MS
 analysis was used on 10 ten  percent of  the  samples  to, confirm the  presence  or
 absence of pollutants whose  GC peaks overlapped other peaks.  The  analytical
                                       V-99

-------
                                  TABLE V-44.
                        SELECTION CRITERIA FOR TESTING
                  PRIORITY POLLUTANTS IN VERIFICATION SAMPLES
Parameter
                                                  Criterion (ug/1)
Pesticides and PCBs
Other Organics
Total Metals:
     Antimony
     Arsenic
     Beryllium
     Cadmium
     Chromium
     Copper
     Lead
     Mercury
     Nickel
     Selenium
     Silver
     Thallium
     Zinc

     TOTAL Cyanide
 0.1
 10

 100
 25
 50
 5
 25
 20
 25
 1
 500
 10
5
0
1,000

20
                                   V-100

-------
methods finally developed for a given plant were usually applicable (with
minor modifications) to~all sampling sites at that plant.

     Raw data from a laboratory's reporting form were encoded on computer data
tapes.  The encoded data were verified to be consistent with the raw data
submitted in the reporting forms.  Data across injections, extracts, and
laboratories were averaged to derive a concentration value identified uniquely
by plant, chemical number, sample site, and date.

      The data were  then reviewed by EPA for consistency with the process
chemistry in operation at  the plant during  the sampling  period.  After  being
judged acceptable  for  use  in the OCPSF rulemaking,  the data were provided  to
statisticians  for  analysis.

      6.  EPA/CMA Five-Plant  Sampling  Program
      From June 1980 to May 1981,  EPA,  with cooperation from the Chemical
 Manufacturers  Association (CMA),  and  five participating chemical plants,
 performed the EPA/CMA Five-Plant Study to gather longer-term data on
 biological treatment of toxic pollutants at organic chemical plants.  The
 three primary objectives of the program were to:

      •  Assess the effectiveness of biological wastewater treatment for the
         removal of toxic organic pollutants
      •  Investigate the accuracy, precision, and reproducibility of the
         analytical methods used for measuring toxic organic pollutants in
         OCPSF industry wastewaters
       • Evaluate potential  correlations between biological removal  of  toxic
         organic pollutants  and biological  removal  of conventional and
         nonconventional pollutants.

       Since the  biological wastewater  treatment  system influent samples were
  taken upstream  of  any preliminary  neutralization  and  settling of  each  chemical
  plant's  combined  waste stream,  the samples of  influent  to biological  treatment
  reflect  each  facility's raw waste  load  following any  in-plant treatment  of
  waste streams from individual  product/processes.
                                       V-101

-------
       EPA selected the five participants because of the specific toxic organic
  pollutants expected to be found.  The five participating OCPSF plants were
 • characterized as having well-designed and well-operated activated sludge
  treatment systems.  Typically, 30 sets of influent and effluent samples
  (generally 24-hour composites) were collected at each plant over a 4- to
  6-week sampling period.

       Only selected toxic organic pollutants were included in this  study;
  pesticides,  PCBs,  metals,  and cyanides were not  measured.   Samples were
  analyzed  for a selected  group of toxic organic pollutants that  were specific
  to each plant as well  as for  specified conventional and nonconventional
  pollutants.   Not all toxic organic  pollutants  included in this  study were
  analyzed  at  all locations.

      EPA's contract laboratories analyzed all  influent and effluent  samples
  for toxic organic pollutants using GC/MS or GC/CD procedures (44 FR  69464 et
 seq., December 3, 1979, or variations acceptable to the EPA Industrial Tech-
 nology Division).  One EPA laboratory used GC coupled with flame ionization
 detection (GC/FID).  Approximately 25 percent of the influent and effluent
 samples collected at each participating plant were analyzed by the CMA
 contractor using GC/MS  procedures (44 FR 69464 et seq.,  December 3, 1979,  or
 equivalent).   Some variation occurred in the analytical procedures  for the
 toxic organic pollutants  used  by both the EPA contract laboratories and CMA
 laboratory during this  study.   An extensive QA/QC program  was included to
 define the precision and  accuracy of the analytical  results.

      Each  participant analyzed conventional  and nonconventional  pollutants  in
 their  influent and  effluent wastewaters using  the methods  found  in  "Methods  of
 Chemical Analysis of Water  and  Wastes,"  EPA  600/4-79-020,  March  1979.
 Additionally,  four  of the participating plants  analyzed from  25  to  100 percent
 of the samples  collected  by EPA for  some of  the to::ic organic pollutants being
 discharged by  the plant.  The  influent  concentrations measured in this  study
 prior to end-of-pipe treatment  are discussed later in this chapter.   The
 biological treatment effluent results are discussed and used in Section VII
and IX.
                                    V-102

-------
     7.   12-Plant Long-Term Sampling Program
     In response to concerns about the limited amount of long-term toxic
pollutant data contained in the database, EPA conducted a long-term sampling
program from March 1983 through May 1984.  Twelve plants were selected based
upon the products manufactured, the pollutants generated, and the in-plant and
end-of-pipe treatment technologies employed.  Special emphasis vas placed on
identifying plants with pollutants for which existing data were limited.

     The number  of sampling days  at  the  12 plants sampled are presented in
Table V-45.  The plants were visited  several weeks prior to  the long-term
sampling.  During  these visits, background data were collected, sample  sites
were selected, and grab samples were  collected.  The grab samples enabled EPA
to  confirm the presence of suspected  pollutants and  enabled  the laboratory  to
determine  the proper dilutions to be used during analysis.

      Samples were collected for each plant's  end-of-pipe treatment  system,  and
 included influent,  effluent,  and sludge samples.   Where plants  utilized
 in-plant control or tertiary treatment, samples were also collected at the
 influent and effluent of  these systems.  Samples were analyzed for conven-
 tional, nonconventional,  and priority pollutants.

      Organic priority pollutants were analyzed by EPA Method 1624, "Volatile
 Organic Compounds by Isotope Dilution GC/MS"; and Method 1625, "Semi-volatile
 Organic Compounds by isotope Dilution GC/MS."  These methods employ GC/MS for
 separation, detection, and quantitation  of organic  priority pollutants, based
 on the capability of the  mass spectrometer to distinguish the isotopically
 labeled analogs of  the organic priority  pollutants  that were spiked into every
 sample prior to extraction.   Metal  priority pollutants were analyzed by atomic
 absorption (AA) spectrophotometry, using the 200 series methods in EPA
 publication USEPA 600/4-79-020,  "Methods for'Chemical  Analysis of Water and
 Wastes."  Dioxin  was analyzed by EPA Method  613.  Asbestos  was analyzed using
  the  transmission electron microscopy (TEM) methods  described  in EPA
  publication USEPA 600/4-80-005,  "Interim Methodology  for Determining  Asbestos
  in Water."
                                      V-103

-------
                             TABLE V-45.
                       NUMBER OF SAMPLING DAYS
               FOR 12-PLANT LONG-TERM SAMPLING PROGRAM
Number of Plants


       1

       7

       1

       2

       1
Number of Days Sampled


          20

          15

          12

          10

           1
                             V-104

-------
     For the first four plants, data were reported by the laboratory on
manually transcribed data sheets to EPA's Sample Control Center (SCC) for
encoding and quality assurance.  For the last eight plants, data were
transmitted by the laboratories to the SCC via magnetic tape.  The data were
also reviewed by EPA for consistency with the process chemistry in operation
at the plant during the sampling period.  After having been judged to be
acceptable for use in the OCPSF rulemaking, the data were transmitted by SCC
to the IBM computer at EPA's National Computer Center in Research Triangle
Park, North Carolina, for loading into the OCPSF data base.

     In addition to data collected in the sampling studies discussed above,
the Agency also received data  as part of public comments on  the March 1983
Proposal and the July 17, 1985 and December 9, 1986 Federal Register Notices
of Availability (NOA).  These  data were reviewed by the Agency to determine
their accuracy and validity and selected data were included  in EPA's final BAT
toxic pollutant data base, which was used in limitations development.  A
discussion of the Agency's review and the selection of plant  data for the
final toxic pollutant data base is presented in Section VII.

F.   WASTEWATER DATA SUMMARY

     1.  Organic Toxic Pollutants
     The Agency's wastewater  data collection studies  as well as data submitted
during  public comment periods on  the proposal and  NOAs discussed above yielded
substantial long- and short-term  priority  pollutant concentration data for
50 data sets  from 43 manufacturing plants.  Tables V-46  through V-49 provide a
statistical summary  of  the  priority  pollutant concentrations in  the  combined
influent  to the end-of-pipe  treatment systems for  these  plants.  For illus-
trative purposes,  the data  for all plants  are presented  in Table V-46 with
Tables  V-47 through  V-49  sorted into organics only, plastics only,  and
organics  and  plastics  plants, respectively.
                                     V-105

-------
                                                      TABLE V-46
                                  SUMMARY STATISTICS FOR INFLUENT  CONCENTRATIONS FOR
                                                   ALL OCPSF PLANTS
CHEHICAL CHEMICAL
 KUH8ER    NAME

    1    ACENAPHTHENE
    2    ACROLEIN
    3    ACRYLOHITR1LE
    4    BENZENE
    6    CARBON TETRACHLORIDE
    7    CHLOROBENZENE
    8    1,2,4-TRICHLOROBENZENE
    9    HEXACHLOR08ENZENE
   10    1,2-DICHLOROETHANE
   11    1,1,1-TRICHLOROETHANE
   12    KEXACHLOROETHANE
   13    1,1-DICHLOROETHANE
   14    1,1,2-TRICHLOROETHANE
   15    1,1,2,2-TETRACHLOROETHANE
   16    CHLOROETHANE
   18    BIS <2-CHLOROETHYL)ETHER
   21     2,4,6-TRICHLOROPHENOL
   23    CHLOROFORM
   24     2-CHLOROPHENOL
   25     1,2-DICHLOROBENZENE
   26     1,3-DICHLOROBENZENE
   27     1.4-DICHLOR08ENZENE
   28    3,3-DICHLOROBEHZIDIHE
  29    VINYLIDENE CHLORIDE
  30    1,2-TRANSDICHLOROETHYLENE
  31    2,4-DICHLOROPHENOt
  32    PROPYLENE CHLORIDE
  33    1,3-DICHLOROPROPENE
  34    2,4-DIHETHYLPHENOL
  35    2,4-DINITROTOLUENE
  36    2,6-DINlTROTOLUENE
  38    ETHYLBEHZENE
  39  ' FLUORANTHENE
  42    BIS-(2-OHLOROISOPROPYL) ETHER
  44    DICHLOROMETHANE
  45    CHLOROHETHANE
  47    BROHOFORH
  52    HEXACHLOR08UTADIENE
  54     ISOPHORONE
  55     NAPHTHALENE
  56    NITROBENZENE
THRESHOLD
VALUE
10
50
50
10
10
10
10
10
10
10
10
10
10
10
50
10
10
10
10
10
10
10
50
10
10
10
10
10
10
10
10
10
10
10
10
50
10
10
16
10
14
FRACTION
BASE/NEUTRAL
VOLATILES
VOLATILES
VOLATILES
VOLATILES
VOLATILES
BASE/NEUTRAL
BASE/NEUTRAL
VOLATILES
VOLATILES
BASE/NEUTRAL
VOLATILES
VOLATILES
VOLATILES
VOLATILES
BASE/NEUTRAL
ACIDS
VOLATILES
ACIDS
BASE/NEUTRAL
BASE/NEUTRAL
BASE/NEUTRAL
BASE/NEUTRAL
VOLATILES
VOLATILES
ACIDS
VOLATILES
VOLATILES
ACIDS
BASE/NEUTRAL
BASE/NEUTRAL
VOLATILES
BASE/NEUTRAL
BASE/NEUTRAL
VOLATILES
VOLATILES
VOLATILES
BASE/NEUTRAL
BASE/NEUTRAL
BASE/NEUTRAL
BASE/NEUTRAL
* OF
HOMDETECTS
43
0
2
24
6
40
23
0
39
32
0
20
17
38
30
6
11
66
31
31
3
36
0
49
26
4
4
14
3
0
8
31
2
3
36
7
18
0
1
25
27
* OF
DETECTS
30
3
66
178
30
51
355
18
106
17
18
5
14
5
16
13
79
96
34
399
20
22
10
40
9
27
58
28
42
22
24
143
31
18
109
8
2
18
1
76
382
# OF
PLANTS
8
1
7
23
7
8
4
2
13
6
2
2
4
4
4
2
7
17
5
12
2
4
1
8
4
4
6
4
7
3
4
20
6
2
13
1
1
2
1
14
6
MINIMUM
VALUE
10.00
2500.00
290.00
11.00
10.00
10.00
20.00
13.00
10.00
10.00
38.00
11.00
10.50
10.00
60.00
25.00
10.00
10.00
10.33
10.50
11.50
10.00
371.00
10.50
12.83
60.00
28.50
10.00
10.00
715.00
29.00
15.50
14.87
193.00
10.00
51.00
24.00
83.00
253.00
12.00
86.00
MAXIMUM MEAN
VALUE
7000
34500
890000
713740
44000
49775
2955
920
1272220
7234
3400
640
1201
192
2840
1700
16780
5250
247370
23326
4616
721
38351
1300
515
72912
11000
4850
73537
17500
4675
80000
7175
19486
19000
129
71
9100
253
37145
90500
VALUE
773.8
13633.3
94771.4
24389.6
2203.1
3028.7
571.6
242.9
20730.2
594.1
516.7
163.5
299.4
111.1
522.7
413.5
427.7
643.0
13206.0
1039.6
417.3
105.6
6147.5
348.2
255.9
7153.6
1405.7
447.7
11932.6
3301.3
775.0
2382.5
1249.9
2267.9
2469.7
83.4
47.5
2006.3
253.0
4579.1
3881.6
MEDIAN
VALUE
513.0
3900.0
31500.0
812.3
543.0
382.0
301.0
121.5
410.0
30.5
156.5
15.0
23.3
121.5
104.0
54.0
59.0
216.0
117.5
829.0
25.5
42.0
1700.0
262.5
236.3
665.0
505.0
178.5
4470.0
1659.0
379.5
220.0
1040.0
787.0
1091.0
90.0
47.5
1111.0
253.0
623.6
2802.0
                                                 V-106

-------
                                                         TABLE V-46
                                     SUMMARY STATISTICS FOR INFLUENT  CONCENTRATIONS  FOR
                                                      ALL OCPSF PLANTS
   CHEMICAL  CHEMICAL
    NUMBER     NAME

      57     2-NITROPHENOL
      58     4-NITROPHENOL
      59     2,4-DINITROPHENQL
      64     PENTACHLOROPHENOL
      65     PHENOL
      66     BIS-(2-ETHYLHEXYL> PHTHALATE
      68     DI-N-BUTYL PHTHALATE
      69     DI-N-OCTYL PHTHALATE
      70     01ETHYL PHTHALATE
      71     DIMETHYL PHTHALATE
      72     BENZO
-------
                                                            TABLE V-47
                                        SUMMARY STATISTICS  FOR  INFLUENT CONCENTRATIONS FOR
                                                   ORGANICS-ONLY OCPSF PLANTS
      CHEMICAL CHEMICAL
      NUMBER    NAME

          1     ACENAPHTHENE
          4     BENZENE
          6     CARBON TETRACHLORIDE
          7     CHLOROBENZENE
          8     1,2,4-TRICHLOROBENZENE
        10     1.2-DICHLOROETHANE
        11     1.1,1-TRICHLOROETHANE
        21     2,4,6-TRICHLOROPHENOL
        23     CHLOROFORM
        24     2-CHLOROPHENOL
        25     1,2-DICHLOROBENZENE
        27     1,4-DICHLOROBENZENE
        31    2.4-DICHLOROPHENOL
        34    2,4-DIHETHYLPHENOL
        38    ETHYLBENZENE
        39    FLUORANTHENE
        47    BROHOFORH
        55    NAPHTHALENE
        56    NITROBENZENE
        57    2-NITROPHENOL
        58    4-N1TROPHENOL
        59    2.4-DINITROPHENOt
        65    PHENOL
        72    BENZOPYRENE
        74    BENZO-B-FLUORANTHENE
        75    BENZO
-------
                                                         TABLE  V-48
                                     SUMMARY STATISTICS FOR INFLUENT  CONCENTRATIONS FOR
                                                PLASTICS-ONLY OCPSF PLANTS
   CHEMICAL  CHEMICAL
    NUMBER     NAME

       2     ACROLEIN
       3     ACRYLONITRILE
       4     BENZENE
      10     1.2-DICHLOROETHANE
      13     1,1-OICHLOROETHANE
      14     1.1,2-TRICHLOROETHANE
      15     1,1,2,2-TETRACHLOROETHANE
      23     CHLOROFORM
      29     VINYLIDENE  CHLORIDE
      32     PROPYLENE CHLORIDE
      33     1,3-DICHLOROPROPENE
      34     2.4-DJMETHYLPHENOL
      38     ETHYLBENZENE
      44     DICHLOROMETHANE
      55     NAPHTHALENE
      65     PHENOL
      86     TOLUENE
      87     TRICHLOROETHYLENE
      88     CHLOROETHYLENE
NUMBER OF DATASETS= 7,  NUMBER OF PLANTS=  7
THRESHOLD
  VALUE    FRACTION
  # OF       # OF   * OF  MINIMUM MAXIMUM  MEAN  MEDIAN
NONDETECTS DETECTS PLANTS VALUE    VALUE   VALUE VALUE
SO
50
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
50
VOLATILES
VOLATILES
VOLATILES
VOLATILES
VOLATILES
VOLATILES
VOLATILES
VOLATILES
VOLATILES
VOLATILES
VOLATILES
ACIDS
VOLATILES
VOLATILES
BASE/NEUTRAL
ACIDS
VOLATILES
VOLATILES
VOLATILES
0
0
1
0
0
0
0
0
0
0
0
0
1
2
0
0
0
0
0
3
21
5
1
1
1
1
3
1
1
3
1
25
1
9
24
12
1
3
1
3
2
1






1
1
5
1
3
4
4
1
1
2500.00
1200.00
14.00
1534.00
140.10
21.00
188.20
13.75
52.50
2258.00
175.00
13.50
22.00
10.00
25.00
62.00
60.00
483.70
233.50
34500
414785
190
1534
140
21
188
23
53
2258
1095
14
3565
23
3600
1900
1900
484
2396
13633
154682
81
1534
140
21
188
17
53
2258
550
14
435
17
463
498
525
484
993
3900
163600
62
1534
140
21
188
14
53
2258
380
14
112
17
40
472
230
484
350
                                                      V-109

-------
                                                     TABLE V-49
                                  SUMMARY  STATISTICS FOR INFLUENT CONCENTRATIONS  FOR
                                          ORGANICS & PLASTICS OCPSF PLANTS
CHEMICAL CHEMICAL
 NUMBER    HAME

    1    ACEHAPHTHENE
    3    ACRYLONITRILE
    4    BENZENE
    6    CARBON TETRACHLORIDE
    7    CHLOROBENZENE
    8    1.2,4-TRICHLOROBENZENE
    9    HEXACKLOROBENZENE
   10    1.2-DICHLOROETHANE
   11     1.1,1-TRICHLOROETHANE
   12    HEXACHLOROETHANE
   13    1.1-OICHLOROETHANE
   14     1.1,2-TRICHLOROETHANE
   15     1.1,2,2-TETRACHLOROETHANE
   16    CHLOROETHANE
   18    BIS (2-CHLOROETHYDETHER
   21    2,4,6-TRICHLOROPHENOL
   23    CHLOROFORM
   2*    2-CHLOROPHENOL
   25    1.2-DICHLOROBENZENE
   26    1.3-DICHLOROBEN2ENE
  27    1,4-DICHLOROBENZENE
  28    3.3-DICHLOROBENZIDINE
  29    VINYLIDENE CHLORIDE
  30    1,2-TRANSDICHLOROETHYLENE
  31    2,4-DlCHLOROPHENOL
  32    PROPYLENE CHLORIDE
  33    1.3-D1CHLOROPROPENE
  34    2,4-DIHETHYLPHENOL
  35    2,4-DIHITROTOLUENE
  36    2.6-DINITROTOLUENE
  38    ETHYLBENZEHE
  39    FLUORANTHENE
  42    BIS-C2-CHLOROISOPROPYL) ETHER
  44   DICHLOROMETHANE
  45   CHLOROHETHAHE
  52   HEXACHLOROBUTAOIENE
  54   1SOPHORONE
  55    NAPHTHALENE
 56    NITROBENZENE
 57    2-NITROPHENOL
 58    4-HITROPHENOL
THRESHOLD
VALUE
10
50
10
10
10
10
10
10
10
10
10
10
10
50
10
10
10
10
10
10
10
50
10
10
10
10
10
10
10
10
10
10
10
10
50
10
16
10
14
20
50
FRACTION
BASE/NEUTRAL
. VOLATILES
VOLATILES
VOLATILES
VOLATILES
BASE/NEUTRAL
BASE/NEUTRAL
VOLATILES
VOLATILES
BASE/NEUTRAL
VOLATILES
VOLATILES
VOLATILES
VOLATILES
BASE/NEUTRAL
ACIDS
VOLATILES
ACIDS
BASE/NEUTRAL.
BASE/NEUTRAL
BASE/NEUTRAL
BASE/NEUTRAL
VOLATILES
VOLATILES
ACIDS
VOLATILES
VOLATILES
ACIDS
BASE/NEUTRAL
BASE/NEUTRAL
VOLATILES
BASE/NEUTRAL
BASE/NEUTRAL
VOLATILES
VOLATILES
BASE/NEUTRAL
BASE/NEUTRAL
BASE/NEUTRAL
BASE/NEUTRAL
ACIDS
ACIDS
# OF
NONDETECTS
22
2
22
4
22
6
0
39
31
0
> 20
17
38
30
6
7
66
30
15
3
20
0
49
26
3
4
14
2
0
8
14
1
3
34
7
0
1
7
8
8
15
# OF
DETECTS
6
45
143
29
46
352
18
102
15
18
4
13
' 4
16
13
76
90
32
395
20
18
10
39
9
25
57
25
17
22
24
100
7
18
108
8
18
1
43
381
27
13
# OF MINIMUM
PLANTS VALUE
4
4
16
6
6
3
2
11
5
2
1
3
3
4
2
6
15
4
11
2
3
1
7
4
3
5
3
3
3
4
12
3
2
12
1
2
1
8
5
4
3
10.000
290.000
11.000
10.000
11.500
20.000
13.000
10.000
10.000
38.000
11.000
10.500
10.000
60.000
25.000
10.000
10.000
10.333
10.500
11.500
10.000
371.000
10.500
12.833
60.000
28.500
10.000
10.000
715.000
29.000
15.500
14.870
193.000
10.000
51.000
83.000
253.000
12.000
86.000
26.000
83.000
MAXIMUM MEAN
VALUE
57
890000
713740
44000
49775
2955
920
1272220
7234
3400
640
1201
192
2840
, 1700
16780
5250
247370
23326
4616
220
38351
1300
515
72912
11000
4850
8787
17500
4675
3850
289
19486
19000
129
9100
253
4018
90500
1625
5990
MEDIAN
VALUE VALUE
24.5
66813.2
22706.0
2275.7
3345.7
575.9
242.9
21491.4
642.9
516.7
169.4
320.8
95.7
522.7
413.5
443.5
669.0
13111.7
1025.5
417.3
61.5
6147,5
355.8
255.9
7665.2
1390.8
435.9
3342.0
3301.3
775.0
495.2
69.2
2267.9
2514.3
83.4
2006.3
253.0
797.9
3891.4
219.2
887.6
23.0
23000.0
990.0
666.3
426.0
305.5
121.5
374.5
23.5
156.5
13.5
23.5
120.0
104.0
54.0
59.5
216.0
96.8
824.0
25.5
32.0
1700.0
270.0
236.3
655.0
480.0
173.0
3415.0
1659.0
379.5
223.5
30.0
787.0
1110.5
90.0
1111.0
253.0
399.5
2802.0
147.0
450.0
                                              v-no

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                                                        TABLE V-49
                                     SUMMARY STATISTICS  FOR  INFLUENT CONCENTRATIONS FOR
                                             ORGANICS &  PLASTICS OCPSF PLANTS
  CHEMICAL  CHEMICAL
   NUMBER     NAME

     59     2.4-OINITROPHENOL
     64     PENTACHLOROPHENOL
     65     PHENOL'
     66     BIS-<2-ETHYLHEXYL) PHTHALATE
     68     DI-N-BUTYL PHTHALATE
     69     DI-N-OCTYL PHTHALATE
     70     DIETHYL PHTHALATE
     71     DIMETHYL PHTHALATE
     72     BENZO(A)ANTHRACENE
     74     BENZO-B-FLUORANTHENE
     75     BENZO
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      In each  table,  the number bf nondetects  is  the number of daily samples
 that were  taken at or below  the  threshold concentrations and the number of
 detects are the number of da,ily,  samples  that  exceeded  the threshold value.  In
 the calculation of the statistical values, all nondetect samples were assigned
 the threshold value  (the analytical method nominal detection limit).  Specific
 pollutant data for each plant were retained only if they were detected in at
 least one sample.

      2.  Toxic Pollutant Metals
      There are process sources of certain metal priority pollutants1 in the
 process wastewaters of the OCPSF industry.  These metals (including cyanide)
 and their affiliated process sources may be anticipated from published generic
 process chemistry that is typically used to manufacture each of the industry's
 products.   Analytical data in the Master Process File from verification
 sampling,  in which the process effluents of 176 of the major product/processes
 of the  industry were characterized for both metal and organic priority
 pollutants,  offered confirmation  of some of the metals (and  cyanide)  that  were
 anticipated.   Confirmation was also found in the industry's  response to the
 1983  '308'  Questionnaire,  in  which plants were asked  to affiliate  priority
 pollutants  with  each  of  the product/processes  in operation.

     Concentrations of metals in  wastewater  from individual  in-plant processes
 are typically  low  (less  than  1.0  ppm).   Few  of the  treatment  systems in the
 OCPSF industry have precipitation technology being  applied to a  process's
 wastewater prior to its joining the combined flow.  Many OCPSF wastewater
 treatment systems  do  not have a primary  clarifier.  This implies the absence
 of solids in the combined  flow that results from metals fortuitously precipi-
 tated by contact with various  precipitants, and a concentration of metals  in
 the combined flow  that is  typically too  low to utilize precipitation technol-
ogy.  One obvious  exception to this generalization is plants manufacturing
rayon that are controlling zinc losses by chemical precipitation, using lime
or caustic.
 For the purposes of this discussion, total cyanide is included in the metal
 priority pollutants (or toxic pollutants) term.
                                    V-112

-------
     In the 1983 308 Questionnaire, each plant was asked to affiliate priority
pollutants with the various product/processes in operation at the plant in
1980.  They were also asked to indicate the priority pollutants' role within
the product process, i.e., catalyst, solvent, raw material, or contaminant in
the raw material, by-product, or waste product.  This file, containing
the priority pollutant metal-product/process affiliations, was retrieved from
the 308 data base and a listing was prepared for each metal.  Another file,
containing product/process-plant affiliations, was also retrieved and listed
for reference.

     Of the five roles, the role of solvent was dismissed  for metals.  In
addition in contrast to organics chemicals, metals cannot  be generated by  the
process chemistry, only lost from  the process.  For  this reason, by-product
sources were also ignored.  The plants frequently affiliated a metal with  the
waste products of the product/process, but affiliation with waste products was
considered to have merit  only when the metal was also listed as a catalyst or
raw material for the product/process.  Thus, editing focused mainly on
catalyst and raw material roles of the metal in validating the product/
process.

     The editing criteria for validation  of  product/processes and plants were
as follows:

     •  Invalidate  a product/process affiliated with a metal listed as a
        by-product  or waste  product, unless  it was also listed  as a catalyst
        or raw material.   Exclude  solvent affiliations.
     •  Invalidate  a product/process affiliated with a metal listed as a
        catalyst or raw material,  if affiliation  is  inconsistant with  the
        chemistry of  the  generic process  or  is an otherwise anomalous  affili-
        ation.   Add a  product/process when a metal  is generally associated
        with  the chemistry of  the  process (or  can be confirmed  by plant con-
        tact), but  was  not listed  by plants  that  operate  the product/process.
     •  Invalidate  a  product/process affiliated with a metal listed as  part  of
        the catalyst  system,  if  the metal is a minor constituent  (less  than  5%
        by weight)  of  the catalyst, process  reactor  design severely limits
        catalyst losses,  -and/or  the catalyst is exposed only  to non-aqueous
        process  streams.
                                     V-113

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      •   Invalidate a product/process  that  is a valid source of a metal,  if the
         metal is  unlikely to emerge in the wastewater from the process at  a
         treatable level (less than 1  mg/1),  before mixing with the wastewater
         rrom other processes in operation  at the  plant.
      •   Invalidate a product/process,  if less than half  of the plants  that
         operate the product/process listed the metal as  being  affiliated with
         the  product/process.
      •   Invalidate a plant affiliated  with a valid product/process,  if the
         plant no  longer operates  the product/process.

     A summary of  the results of  this  validation analysis  is presented in
Table V-50.  A listing  of the product/processes that have  been determined  to
be process sources  of metals and  cyanide is  presented in Section X of  this
document.  Based on  these results,  the Agency determined that a total of eight
toxic pollutant metals  (including cyanide) had a substantial number of process
sources in the OCPSF industry.  Also, as discussed in the  following section,
the remaining seven toxic pollutants (including arsenic) were eliminated from
further consideration for regulation under this rulemaking.
                                   V-114

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                                 TABLE V-50.,
    SUMMARY OF PRIORITY POLLUTANT METAL-PRODUCT/PROCESS-PLANT VALIDATION
Priority
Pollutant
Metals
114 Antimony
115 Arsenic
117 Beryllium
118 Cadmium
119 Chromium
120 Copper
121 Cyanide
122 Lead
123 Mercury
124 Nickel
125 Selenium
126 Silver
127 Thallium
128 Zinc
No. off PP1
Before
Validation
(Sb)
(As)
(Be) ,
(Cd)
(Cr)
(Cu)
(CN)
(Pb)
(Hg)
(Ni)
(Se)
(Ag)
(Th)
(Zn)
43
46
8
34
116
131
47
46
31
124
20
19
9
152
No. of '
Plants No. of PP ,
Before After
Validation, Validation
126 15
113 ; 25 ' "'
19 ......-,
85 ...
207 24'
240 62
73 41
149 13
93 1
163 63
46
68
20
298 46
No. of
... Plants
After
Validation
29
18


„ 71 ..:-...
.• • 62
37
1
64



81
1 product/processes
                                     V-115

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                                  SECTION VI
                      SELECTION OF POLLUTANT PARAMETERS

A.  INTRODUCTION
     Specific toxic, conventional, and nonconventional pollutant parameters
were determined to be potentially significant in the Organic Chemicals, Plas-
tics, and Synthetic Fibers (OCPSF) Industry and were selected for evaluation
based on:  1) an industry characterization, 2) data collected from field
sampling efforts, 3) historical data collected from the literature, and 4)
data provided by industry either by questionnaire (Section 308 Questionnaire
Survey) or through public comment on the proposed regulations or subsequent
Federal Register Notices of Availability of New Information.

     The U.S. Environmental Protection Agency (EPA) has considered for
regulation the following conventional pollutant parameters for the final BPT
effluent limitations presented in this document:  five-day biochemical oxygen
demand (BOD5), total suspended solids (TSS), pH, and oil and grease (O&G).
Nonconventional pollutant parameters considered by  the Agency for  the  final
BPT, BAT, NSPS, PSES, and PSNS effluent  limitations guidelines and standards
include  chemical oxygen demand (COD) and  total organic carbon (TOG).

     In  developing  its BAT, NSPS, PSES,  and PSNS effluent limitations  guide-
lines and standards for toxic pollutants,  the Agency specifically  addressed a
list of  126  toxic pollutants, which are  presented in Appendix VI-A.  As  the
list of  65 toxic pollutants and classes  of pollutants  includes potentially
thousands of specific pollutants, EPA limited its data collection  efforts  to
the  126  specific compounds referred  to as "priority" pollutants.   The  criteria
that were used  in  the late 1970's to classify these pollutants as  "priority"
pollutants included the frequency of their occurrence  in water,  their  chemical
stability and structure,  the  amount  of  the chemical produced, and  the  avail-
ability  of chemical standards and analytical methods for measurement.
                                      VI-1

-------
      This section presents descriptions of each of the conventional,
 nonconventional, and toxic pollutant parameters considered by the Agency and
 discusses the selection criteria used to select pollutants for control under
 BPT, BAT, NSPS, PSES, and PSNS.

 B.    CONVENTIONAL POLLUTANT PARAMETERS
      1•   Five-Day Biochemical Oxygen Demand (BOD )
      The Five-Day Biochemical Oxygen Demand (BOD5) test traditionally has been
 used to  determine the pollutant strength of domestic and industrial waste-
 waters.   It  is a measure of the oxygen required by biological organisms to
 assimilate the biodegradable portion of a waste under aerobic conditions
 (6-1).   Substances that may contribute to the BODg include carbonaceous
 materials usable as a food source by aerobic organisms;  oxidizable nitrogen
 derived  from organic nitrogen compounds,  ammonia and nitrates that are
 oxidized by  specific bacteria;  and chemically oxidizable materials such as
 ferrous  compounds,  sulfides,  sulfite,  and similiar reduced-state  inorganics
 that will react with dissolved  oxygen or that are metabilized by  bacteria.

      The BODg  of a wastewater is  a measure of the dissolved  oxygen depletion
 that might be  caused by the discharge of that wastewater to  a body of water.
 This depletion reduces  the oxygen available to fish,  plant life,  and other
 aquatic  species.   Total exhaustion of the dissolved  oxygen .in water results in
 anaerobic conditions, and  the subsequent  dominance of  anaerobic species  that
 can  produce  undesirable gases such as  hydrogen sulfide and methane.   The
 reduction of dissolved  oxygen can be  detrimental  to  fish populations,  fish
 growth rates,  and  organisms used  as fish  food.  A total  lack of oxygen can
 result in the  death  of  all aerobic aquatic  inhabitants in  the affected area.

     The  BODg  test  is widely  used to  estimate  the  oxygen demand of  domestic
 and  industrial wastes and  to  evaluate  the performance  of waste treatment
 facilities by measuring  the amount of  oxygen depletion in a  standard  size
 flask after  5 days incubation.  The test  is widely used  for  measuring  poten-
 tial pollution, since no other  test methods have been developed that  are as
suitable  or  as widely accepted  for evaluating  the deoxygenation effect of a
waste on  a receiving water body.
                                     VI-2

-------
     The BOD  test measures the weight of dissolved oxygen utilized by
microorganisms as they oxidize or transform the gross mixture of chemical
compounds in the wastewater.  The degree of biochemical reaction involved in
the oxidation of carbon compounds is related to the period of incubation and
the rate of biodegradation of the compound(s) within the mixture.  When
municipal sewage is tested, BOD5 normally measures only 60 to 80 percent of
the total carbonaceous biochemical oxygen demand of the sample.  When testing
OCPSF wastewaters, however, the fraction of total carbonaceous oxygen demand
measured can range from less than 10 percent to more than 80 percent.  The
actual percentage for a given waste stream will depend on the degradation
characteristics of the organic components present, the degree to which the
seed is acclimated to these components, and the degree to which toxic or
inhibitory components are present in the'waste (6-1).

     2.  Total Suspended Solids (TSS)
     Suspended solids can.include both organic and inorganic materials.  The
inorganic materials include sand, silt, and clay and may include insoluble
toxic metal compounds.  The organic fraction includes such materials as
grease, oils, animal and vegetable waste products, fibers, microorganisms, and
many other dispersed insoluble organic compounds (6-2).  These solids may
settle rapidly and form bottom deposits that are often a mixture of both
organic and inorganic solids.

     Solids may be suspended in water for a time and then settle to the bottom
of a stream or lake.  They may be inert, slowly biodegradable materials, or
they may be rapidly decomposable substances.  While in suspension,  they
increase the  turbidity of  the water, reduce light penetration, and  impair  the
photosynthetic activity of aquatic plants.  After settling  to  the stream or
lake bed,  the solids can  form sludge banks, which, if largely organic, create
localized  anaerobic and undesirable benthic conditions.  Aside from any toxic
effect attributable to substances leached out by water, suspended solids may
kill fish  and shell-fish  by  causing abrasive injuries, clogging gills and
respiratory passages, screening light, and by promoting and  maintaining
noxious  conditions  through  oxygen depletion.  Suspended solids may  also reduce
the  recreational  value of a" waterway and can cause problems  in water used  for
                                      VI-3

-------
 domestic purposes.   Suspended solids in intake water may interfere with many
 industrial processes,  and cause foaming in boilers, or encrustations on
 exposed equipment,  especially at elevated temperatures.

      3.  pjl
      The term pH describes the hydrogen ion-hydroxyl ion equilibria in water.
 Technically,  pH is  a measure of the hydrogen ion concentration or activity
 present in a  given  solution.  A pH number is the negative logarithm of the
 hydrogen ion  concentration.   A pH of 7.0 indicates neutrality or a balance
 between free  hydrogen  and free hydroxyl ions.   A pH above 7.0 indicates that a
 solution is alkaline?  a pH below 7.0 indicates that a solution is acidic.

      The pH of discharge water is of concern because of  its  potential impact
 on  the  receiving body  of water.   Wastewater effluent,  if not neutralized
 before  release,  may alter the pH of the receiving water.   The critical range
 suitable for  the existence of most biological  life is  quite  narrow,  lying
 between pH 6  and pH 9.

      Extremes of pH or rapid pH  changes can harm or kill aquatic life.   Even
 moderate changes from  acceptable pH limits  can harm some species.   A change  in
 the pH  of water  may increase or  decrease the relative  toxicity of many mate-
 rials to aquatic life.   A drop of even  1.5  units,  for  example,  can increase
 the toxicity  of  metalocyanide complexes a thousandfold.   The bactericidal
 effect  of chlorine  in  most cases lessens as the  pH increases.

     Waters with a  pH  below  6.0  corrode waterworks  structures,  distribution
 lines,  and household plumbing fixtures.  This  corrosion  can  add to  drinking
water constituents  such  as iron,  copper, zinc, cadmium,  and  lead.   Low  pH
waters  not only  tend to  dissolve metals  from structures  and  fixtures,  but also
 tend  to  redissolve  or  leach  metals  from sludges  and  bottom sediments.

     Normally, biological  treatment systems  are  maintained at  a pH between 6
and 9; however,  once acclimated  to  a narrow pH range, sudden deviations  (even
in the 6  to 9 range) can cause upsets in the treatment system with a resultant
decrease  in treatment efficiency.
                                     VI-4

-------
     4.  Oil and Grease (O&G)
     Oil and grease analyses do not actually measure the quantity of a
specific substance, but measure groups of substances whose common character-
istic is their solubility in freon.  Substances measured may include hydro-
carbons, fatty acids, soaps, fats, oils, wax, and other materials extracted by
the solvent from an acidified sample and not volatilized by the conditions of
the test.  As a result, the term "oil and grease" is more properly defined by
the conditions of  the analysis rather than by a specific compound or group of
compounds.  Additionally, the material identified in the O&G determination is
not necessarily free floating.  It may be actually in solution but still
extractable from water by the solvent (6-3).

     Oils and greases of hydrocarbon .derivatives, even  in small quantities,
cause  troublesome  taste and odor problems.   Scum lines  from these agents are
produced on water  treatment basin walls and  other containers.  Fish and water
fowl are adversely affected by oils in  their habitat.   Oil emulsions may cause
the suffocation of fish by adhering to  their gills and  may taint the flesh of
fish when microorganisms exposed  to waste oil are eaten.  Deposition of oil
in the bottom sediments of natural waters can serve  to  inhibit normal  benthic
growth.  Oil and grease can also  exhibit an  oxygen demand.

     Levels of  oil and grease  that are  toxic to  aquatic organisms vary greatly
depending on  the oil and grease  components and  the susceptibility of  the
species exposed to them.  Crude  oil in  concentrations as low  as  0.3 mg/1  can
be extremely  toxic to  freshwater fish.   Oil  slicks prevent  the  full aesthetic
enjoyment of  water.  The presence of  oil in  water  can also  increase  the
toxicity of other  substances  being discharged  into  the  receiving bodies of
water.  Municipalities frequently limit the  quantity of oil and  grease that
can  be discharged  to their  wastewater treatment  systems.

     There  are  several approved  modifications  of the analysis for  oil and
grease.  Each is designed  to increase the accuracy or  enhance the  selectivity
of  the analysis.   Depending on the procedure and detection method  employed,
 the  accuracy  of the  test can vary from 88 percent  for  the Soxhlet  Extraction
Method to 99  percent for the Partition-Infrared Method.
                                      VI-5

-------
 C.   NONCONVENTIONAL POLLUTANT PARAMETERS
      1«  Chemical Oxygen Demand  (COD)
      COD is a chemical oxidation test devised as an alternate method of
 estimating the oxygen demand of a wastewater.  Since the method relies on the
 oxidation-reduction system of a chemical reaction rather than a biological
 reaction, it is more precise, accurate, and rapid than the BOD5 test.  The COD
 test is sometimes used to estimate the total oxygen (ultimate rather than the
 five-day BOD5) required to oxidize the compounds in a wastewater.  In the COD
 test, strong chemical oxidizing agents under acid conditions, with the assis-
 tance of certain inorganic catalysts, can oxidize most organic compounds,
 including many that are not biodegradable.   However,  it should be noted that
 the COD test may not measure the oxygen demand of certain aromatic species
 such as benzene,  toluene,  and pyridine (6-4).

      The COD test measures  organic  components  that  may exert  a biological
 oxygen  demand  and may affect public health.   It  is  a  useful analytical  tool
                                    Most  pollutants  measured by the BOD  test
for pollution control activities.
will be measured by the COD test.  In addition, pollutants resistant to
biochemical oxidation will also be measured as COD.
     Compounds  resistant  to  biochemical  oxidation are  of great  concern  because
of  their slow,  continuous oxygen demand  on  the receiving water  and also,  in
some cases, because of  their potential health effects  on aquatic life and
humans.  Many of  these  compounds result  from industrial discharges and  some of
the compounds have been found to have carcinogenic, mutagenic,  and similar
adverse effects.  Concern about these compounds has increased as a result of
demonstrations  that their long life in receiving water (the result of a low
biochemical oxidation rate)  allows them  to contaminate downstream water
intakes.  The commonly  used  systems of water purification are not effective in
removing these  types of materials and disinfection with chlorine may convert
them into even more objectionable materials.

     2.  Total Organic Carbon (TOG)
     TOC measures all oxidizable organic material in a waste stream,  including
the organic chemicals not  oxidized (and therefore not  detected)  in BOD  and
                                    VI-6

-------
COD tests.  TOC analysis is a rapid test for estimating the total organic
carbon in a waste stream.

     ¥hen testing for TOC, the organic carbon in a sample is converted to
carbon dioxide (C02) by catalytic combustion or by wet chemical oxidation.
The C02 formed can be measured directly by an infrared detector or it can be
converted to methane (CH4) and measured by a flame ionization detector.  The
amount of C02 or CH4 is directly proportional to the concentration of carbo-
naceous material in the sample.  TOC tests are usually performed on  commer-
cially available automatic TOC analyzers.  Inorganic carbons, including
carbonates and bicarbonates, interfere with these analyses and must  be removed
during sample preparation (6-5).

D.  TOXIC POLLUTANT PARAMETERS
     Paragraph 8 of the  Settlement Agreement contains provisions authorizing
EPA to exclude toxic pollutants and  industry subcategories from regulation
under certain circumstances.  Paragraph 8(a)(iii) authorizes  the Administrator
to exclude from regulation:  toxic pollutants not detectable  by Section  304(h)
analytical methods or  other  state-of-the-art methods; toxic pollutants present
in amounts too small to  be effectively  reduced by available  technologies;
toxic pollutants present  only  in  trace  amounts and neither causing  nor likely
to cause  toxic effects;  toxic  pollutants  detected in  the  effluent  from only  a
small number of sources  within  a  subcategory and uniquely related  tovonly
those sources;  toxic' pollutants  that will be effectively  controlled by  the
technologies upon  which  are  based other effluent limitations  and  standards;  or
toxic  pollutants  for which more stringent protection  is already  provided under
Section  307(a)  of  the  Act.

      Pursuant  to  the  Paragraph 8(a)(iii)  criteria,  the  Agency decided early in
 the  rulemaking to  eliminate  from further  consideration  26 toxic  pollutants,
consisting of  18  pesticides, seven polychlorinated  biphenyls  (PCBs), and .
asbestos.  These  toxic pollutants are  listed  in  Table VI-1,  and  are excluded
because  they are  not  produced  as products or  co-products  and are unlikely to
appear as raw material contaminants  in OCPSF  product/processes.   At facilities
manufacturing OCPSF product/processes,  but where pesticide pollutants are also
                                      VI-7

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                          TABLE VI-1.
                 TWENTY-SIX TOXIC POLLUTANTS.
                    PROPOSED FOR EXCLUSION
Aldrin
Dieldrin
Chlordane
4,4'-DDT
4,4'-DDE
4,4'-DDD
alpha-Endosulfan
beta-Endosulfan
Endosulfansulfate
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
 alpha-BHC
 beta-BHC
 gamma-BHC
 delta-BHC
 Toxaphene
 PCB-1242 (Arochlor 1242)
 PCB-1254 (Arochlor 1254)
 PCB-1221 (Arochlor 1221)
 PCB-1232 (Arochlor 1232)
 PCB-1248 (Arochlor 1248)
 PCB-1260 (Arochlor 1260)
 PCB-1016 (Arochlor 1016)
Asbestos
                          VI-8

-------
synthesized by product/processes inSIC Codes corresponding to the pesticides
category, pesticide discharges wi11»be regulated under effluent limitations
for the separate pesticide category.  On occasion, pesticides may appear in
discharges that contain OCPSF effluents only but can be attributed to applica-
tion of pesticide formulations around the plant grounds.  PCBs are no longer
manufactured in the United States; however, PCBs may occasionally appear in
OCPSF effluents and are probably the result of leaking transformers containing
PCB-contaminated oil which finds its way into the wastewater through storm-
water runoff or plant floor drains.  Asbestos is neither manufactured nor
utilized as a raw material or catalyst by the OCPSF industry.  In any event,
none of  the 18 pesticides, 7 PCBs, and asbestos are currently related to OCPSF
production.

     With the exception of dibxin, all remaining priority pollutants were
considered for regulation; however, as described later in this section, some
were ultimately excluded  from regulation under Paragraph 8.  Regulation of
dioxin (TCDD) has been reserved even though it was not detected at any of the
sample locations.  The minimum detection or analytical  threshold level of the
2,3,7,8-tetrachlorodibenzo-p-dioxin analytical method used at the time of the
EPA laboratory studies that included dioxin (March 1983  to May 1984/12-plant
study) was significantly  higher  than the level presently being used by the
Agency.  The minimum detection level used  for  the OCPSF  dioxin analyses was
3  x 10"7 grams/liter, which is five orders of magnitude  higher than the
current  minimum detection level  being used by  the Agency to  study industrial
sources  of dioxin  in wastewater  discharges.  Thus, the Agency decided  to
reserve  dioxin rather  than use  the higher  analytical detection level as a
basis  for exclusion  from  regulation.

E.   SELECTION CRITERIA
     1.   Conventional  Pollutants
     The Agency has  decided  to  control  five-day  biochemical  oxygen  demand
 (BOD5),  total  suspended  solids  (TSS),  and  pH under  its  final BPT  effluent
 limitations  guidelines.   While  the Agency  considered developing  limitations
 for  oil  and  grease,  EPA  determined that  the  effluent levels  of oil  and grease
 observed at  BPT  treatment systems were achieved  through incidental  removal  by
                                      VI-9

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 a  treatment system primarily designed  to remove BOD5 and TSS.  It should be
 noted  that certain plants  install oil  and grease treatment technologies to
 ensure that subsequent  treatment units  (e.g., other physical/chemical or bio-
 logical treatment) can  operate properly. .Therefore, based on these reasons,
 the Agency decided not  to  establish BPT effluent limitations for oil and
 grease.

      2.  Nonconventional Pollutants
      While the Agency had  considered the development of BPT,  BAT, NSPS, PSES,
 and PSNS effluent limitations guidelines and standards for specific non-
 conventional pollutants, EPA has determined that the regulation of nonconven-
 tional pollutants will be deferred.   One reason for this deferment is the
 enormity of the task of developing analytical methods for many of the noncon-
 ventional toxic pollutants.  Another reason for not regulating the more famil-
 iar nonconventional pollutants such  as COD and TOC is that much of the per-
 formance data obtained by the Agency is the result  of incidental removals  by
 treatment  technologies installed to  remove  conventional and/or toxic (prior-
 ity)  pollutants and not designed for the removal of the nonconventional pol-
 lutants present,  including COD and TOC.  The Agency believes  that the proper
 installation  of treatment technologies to meet  BPT,  BAT,  NSPS,  PSES,  and PSNS
 effluent limitations  guidelines and  standards will  result in  significant re-
 ductions of nonconventional pollutants.   For example, nonconventional volatile
 pollutants such as xylene that  are present  in BTX process wastewaters will  be
 removed by steam strippers  installed  for removal of  benzene and  toluene.

     3.  Toxic  Pollutants
        i
     Toxic pollutant  parameters are controlled under BAT  and NSPS  for  direct
 dischargers and PSES  and PSNS for indirect dischargers  and the criteria  for
 selecting toxic pollutants  for  regulation for each mode of discharge  is  dif-
 ferent.  Therefore, discussion of the selection criteria  for BAT and NSPS and
 PSES and PSNS are presented separately  in the following sections.

         a.  Selection Criteria for BAT and NSPS Toxic  Pollutants
     As stated previously,  dioxin was reserved from regulation at this time.
In addition,  Paragraph 8 of the Settlement Agreement contains provisions
                                    VI-10

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authorizing EPA to exclude toxic pollutants and industry subcategories from
regulation under certain circumstances.  Pursuant to these criteria (as stated
previously), the Agency eliminated 18 pesticides, 7 PCBs, and asbestos from
further regulatory consideration.  The remaining 99 toxic pollutants were then
evaluated based on the specific criteria set forth in Paragraph 8 of the
Settlement Agreement.

     Table VI-2 presents the frequency of occurrence of  99 toxic pollutants
sampled for in untreated wastewaters  (discharged to the  end-of-pipe treatment
systems) during the  following EPA  toxic pollutant sampling studies:  1) Phase
I Screening, 2) Phase II Screening, 3) Verification, 4)  EPA/CMA S^Plant Study,'-
and 5) EPA  12-Plant  Study.  Also presented  are  the minimum and maximum
reported concentrations from the last three studies.              ;

     Only the  last  three studies for  the minimim/maximum values were used
because  the analytical methods  used for  the two screening studies allow  the
data only to be used qualitatively.   False  positive pollutant identification
could  occur in the  Phase I and  II  screening studies as  a result of  the  pro-
cedures  used for  interpreting ambiguous  pollutant  identification  based  on  the
1977 screening level GC/MS analytical protocols and QA/QC procedures.   The
screening level analytical procedures based pollutant  identification on three
peaks  of the mass spectrum.  If these peaks did not agree exactly with the
reference or library, spectrum,  then judgement calls were generally made in
 favor  of compound presence.  These judgement calls were made approximately
 10 to  20 percent  of the time.   This was  a conservative approach for identify-
 ing pollutants of concern for future organic priority pollutant field sampling
 and analysis  studies because it minimized the occurrence of. false negative re-
 porting.  Use  of  the screening analytical protocols also led to the reporting
 of a range of  analytical threshold levels or "detection limits" for various
 toxic compounds.   In general,  the analytical threshold levels that were
 reported as "less than" values are associated with raw waste, sample matrix
 interferences.  The reporting of data as such does not  imply the presence of
 the toxic compounds at the reported  "less  than" values.  Rather, it means that
 the presence ^«r absence of these compounds  cannot be verified due to analyti-
 cal limitations.   The frequency counts presented in Table VI-2 treats reported
 "less than" values  as non-detected.   (The  initial frequency  counts presented
                                      VI-11

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                                                          TABLE VI-2
                                      FREQUENCY OF OCCURENCE AND CONCENTRATION RANGES FOR
                                      SELECTED PRIORITY POLLUTANTS IN UNTREATED WASTEWATER
  03S  POLLUTANT
       NAME
    1
    2
    3
    4
    5
    6
    7
    8
    9
  10
  11
  12
  13
  14
  15
  16
  17
  18
  19
  20
  21
  22
  23
  24
  25
  26
  27
  28
  29
  30
  31
  32
 33
 34
 35
 36
 37
 38
 39
 40
 41
 42
 43
 44
 45
 46
 47
48
49
50
(TOTAL)
(TOTAL)
(TOTAL)
   ZINC
   COPPER
   MERCURY
   PHENOL
   CHROMIUM  (TOTAL)
   TOLUENE
   NICKEL   (TOTAL)
   BENZENE
   ETHYLBENZENE
   D1CHLOROHETHANE
   CHLOROFORM
  ARSENIC  (TOTAL)
  SILVER   (TOTAL)
  8IS-(2-ETHYLHEXYL) PHTHALATE
  CYAHIDE  (TOTAL)
  CADMIUM  (TOTAL)
  LEAD     (TOTAL)
  ANTIMONY (TOTAL)
  NAPHTHALENE
  SELENIUM (TOTAL)
  1,1,1-TRlCHLOROETHANE
  1,2-DICHLOROETHANE
  CHLOROBENZENE
  THALLIUM (TOTAL)
  PERCHLOROETHYLENE
  CARBON  TETRACHLORIDE
  2,4-DIHETHYLPHENOL
  VIHYLIDENE CHLORIDE
  Dl-N-BUTYL PHTHALATE
  TR1CHLOROETHYLENE
 ACENAPHTHENE
 PHENAHTHRENE
 ANTHRACENE
 FLUORENE
 ACENAPHTHYLENE
 BERYLLIUH(TOTAL)
 PYRENE
 2,4,6-TRICHLOROPHENOL
 2-CHLOROPHEHOL
 FLUORANTHENE
 2,4-DICHLOROPHENOL
 1,2-TRAHSDICHLOROETHYLENE
 PROPYLEHE CHLORIDE
 1,2-DICHLOROBENZENE (0-DICHLOROBENZENE)
 1,4-DICHLOROBEHZENE (P-DICHLOR06EHZENE)
DIETHYL  PHTHALATE
DIMETHYL PHTHALATE
BUTYLBEHZYL PHTHALATE
1,1,2,2-TETRACHLOROETHANE
BENZO(A)ANTHRACENE
                                          POLLUTANT
                                FRACTION  NUMBER
                                                                                   NUMBER OF  MIN            MAX
                                                                  H   DET  RATIO   PLANTS     CONCENTRATION  CONCENTRATION
M
M
M
A
M
V
H
V
V
V
V
M
«
B
M
M
M
M
B
M,
V
V
V
H
V
V
A
V
B
V
B
B
B
B
B
M
B
A
A
B
A
V
V
B
B
B
8
B
V
B
128
120
123
65
119
86
124
4
38
44
23
115
126
66
121
'm
122
114
55
125
11
10
7
127
85
6
34
29
68
87
1
81
78
80
77
117
84
21
24
39
31
30
32
25
27
70
71
67
15
• 72
137 131 95.620
134 123 91.791
126 95 75.397
148 110 74.324
141 102 72.340
137 96 70.073
126 80 63.492
134 78 56.209
13D 75 57.692
122 69 56.557
131 71 54.198
120 62 51.667
122 58 47.541
127 57 44.882
118 49 41.525
126 48 38.095
131 49 37.405
123 42 34.146
125 42 33.600
119 38 31.933
112 35 31.250
115 34 29.565
115 33 28.696
118 33 27.966
112 28 25.000
113 28 24.779
117 28 23.932
106 25 23.585
118 25 21.186
113 23 20.354
117 23 19.658
117 23 19.658
117 21 17.949
118 21 17.797
118 19 16.102
118 19 16.102
119 18 15.126
113 17 15.044
115 17 14.783
117 17 14.530
114 15 13.158
107 14 13.084
107 14 13.084
116 15 12.931
113 14 12.389
112 13 11.607
113 13 11.504
115 13 11.304
109 12 11.009
112 12 10.714
21
19
13
29
26
26
10
20
18
7
13 .
6
1
1
3
3
8
7
14
4
6
11
7
2
5
6
7
7
1
8
7
10
7
9
8
_
6
6
5
6
4
4
5
9
4
2
1
B
3
5
14.000
23.500
0.500
13.000
60.000
13.000
49.000
12.500
15.500
10.310
11.000
5.000
3.634
11.000
130.000
5.519
103.800
5.000
12.000
3.000
11.000
12.000
11.500
2.000
11.000
15.000
13.500
10.500
19.000
10.222
11.000
18.500
15.000
10.500
12.000

11.000
11.000
10.333
14.870
60.000
12.833
28.500
10.500
10.500
13.500
10.333

34.000
12.030
450000
4834
900
978672
5330
160000
37500
713740
80000
12480
5250
711
18
18830
5063
10
430000
630
37145
250
7234
1272220
49775
5
31500
44000
73537
1300
5930
484
7000
11000
2900
1873
18500

5500
16780
247370
7175
72912
515
11000
23326
721
15000
625

192
2400
                                             ALL  CONCENTRATION
                                         RATIO »  100*DET/N(100
                                               IN  UNITS  OF  PPB
                                               * # DETECTED/TOTAL)
                                                     VI-12

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                                                    TABLE VI-2(CON'T.)
                                    FREQUENCY OF OCCURENCE AND CONCENTRATION RANGES  FOR
                                    SELECTED PRIORITY POLLUTANTS IN UNTREATED WASTEUATER
08S  POLLUTANT
     NAME
          POLLUTANT
FRACTION  NUMBER
                -NUMBER  OF   MIN            MAX
N   DET  RATIO   PLANTS      CONCENTRATION - CONCENTRATION
51   CHRYSENE
52   OICHLOROBROMOMETHANE
53   BROMOFORH
54   ACRYLOHITRILE
55   NITROBENZENE
56   PENTACHLOROPHENOL
57  , 1,1,2-TRICHLOROETHANE
58   2,6-DIMITROTOLUENE
59   4-NITROPHENOL
60   2-NITROPHENOL
61   CHLOROMETHANE
62    1,1-DICHLOROETHAHE
63    1,3-DICHLOROPROPENG
64    BIS-(2-CHLOROISOPROPYL) ETHER
65    2.4-OINITROPHENOl
66    BIS (2-CHLOROETHYDETHER
67   CHLOROETHANE
68    CHLORODIBROMOMETHANE
69   1,3-DICHLOROBENZnNE (M-DICHLOROBENZENE)
70   OI-N-OCTYL PHTHALATE
 71    1,2.4-TRICHLOROBENZENE
 72   BENZO-B-FLUORANTHENE
 73   HEXACHLOROBENZENE
 74   HEXACHLOROETHANE
 75 .  N-NITROSODIPHENYLAMINE
 76   PARA-CHLORO-META-CRESOL
 77   2,4-OINITROmUEME
 78  • BENZO
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 in Table VI-2, Vol II of  the proposed Development Document  (EPA 440/1-83/009,
 February 1983) had tabulated "less  than" values as detected.)

      It should also be noted that the selected untreated wastewater sampling
 locations at some plants may be downstream of in-plant controls that may treat
 one or more OCPSF product/process sources of wastewater before commingling
 with other OCPSF process wastewater at the influent to the end-of-pipe treat-
 ment system.  Therefore, the end-of-pipe raw wastewater summaries include some
 partially treated wastewater.  This situation is unavoidable for several
 reasons.  Foremost is the practical difficulties of accurately sampling and
 flow proportioning multiple in-plant sources of wastewater to obtain com-
 pletely untreated wastewater characteristics.  The Agency's in-plant sampling
 efforts often required the cooperation of plant personnel to modify existing
 plumbing to accommodate sampling and flow measurement devices.   The OCPSF
 industry does not measure most  in-plant  sources of wastewater (the vast major-
 ity of in-plant flows reported  in the 1983 Section 308 survey were qualified
 estimates).   In addition,  many  of these  in-plant  controls are operated  as
 product recovery rather than wastewater  treatment  units.   For example,  many
 existing in-plant controls such as  steam stripping were originally installed
 for product  recovery  purposes,  but  may be operated more efficiently or
 upgraded for pollution  control  purposes.   Also, some  in-plant controls  that
 precede biological  treatment protect the  biota  and otherwise ensure that  the
 biological system functions  effectively and  consistently.   Sampling prior to
 product recovery  and  prior to necessary  in-plant control  elements  of biologi-
 cal  treatment would tend  to  overestimate  typical raw waste  concentrations.
 For  these reasons,  the Agency believes that  sampling of raw  wastewater  prior
 to end-of-pipe  treatment provides the most reasonable  available basis for
 assessing typical current OCPSF  industry  plant-level priority pollutant
 concentrations.
               • i
     In reviewing Table VI-2, two pollutants  (hexachlorocyclopentadiene and
N-nitrosodimethylamine) were not detected at any of the 186 OCPSF plants
sampled.  An additional five pollutants (2-chloronaphthalene, 4-chlorophenyl
phenyl ether, 4-bromophenyl phenyl ether, methyl bromide, and N-nitrosodi
N-propylamine) were detected at only one OCPSF facility, three pollutants
(2-chloroethyl vinyl ether, acrolein, and bis(2-chloroethoxy)methane) were
                                    VI-14

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detected at only two OCPSF facilities, one pollutant (benzidine) was detected
at only three OCPSF facilities, two pollutants (parachlorometa cresol and
1,2,-diphenylhydrazine) were detected at only four OCPSF facilities, and one
pollutant (N-nitrosodiphenylamine) was detected at only five OCPSF facilities.
 These pollutants (with the exception of acrolein) were not detected in«any of
the samples from the quantitative ;minimum/maximum data set and were found at
this limited number of plants out of a total plant population of 186 facil-
ities.   In addition, one pollutant (butyl benzyl phthalate)., which was found
at a higher percentage of OCPSF facilities was never detected in the quanti-
tative minimum/maximum data set.

     Based on  the limited number  of plants at which these pollutants occur,
the fact that  all but one of  these pollutants were never quantitatively
identified and that  the qualitative data  from the two screening studies tend
to exhibit false ;positive values,'the Agency believes that  these 15 organic
toxic pollutants described above  and  an additional 7 priority  toxic metals
(discussed later in  this section) and listed in Table VI-3  should  be excluded
as follows:   two pollutants should be excluded from regulation  under BAT  on
the basis  of  Paragraph 8(a)(iii)  of  the Settlement Agreement because  these
pollutants were "...  not detected by  Section 304(h) analytical  methods or
other state-of-the-art methods ..."  and the remaining 13  organic  toxic
pollutants and 7 metals  should be excluded  from  regulation  under BAT  on the
basis of Paragraph  8(a)(iii)  of the  Settlement Agreement  because  these pollu-
 tants were "... detected in  the effluent  from a  small number of sources and
are uniquely  related to  those sources ..."

      Also,  three toxic pollutants (benzo  (ghi)  perylene,  dibenzo  (a,,h)
anthracene,  and ,indeno (l,2,3-c,d)  pyrene)  were  detected in two or fewer OCPSF
 plants  in  the qualitative frequency of occurrence data base,  were reported at
 less  than  25  ppb in the quantitative minimum/maximum concentration data base
 and  are part  of the polynuclear aromatic  (PNA)  pollutant class, which gener-
 ally occur together and for which 11 of 14 pollutants in the class are being
 regulated  under BAT.  Based on these factors,  the Agency has decided to ex-
 clude these three toxic pollutants (also presented in Table VI-3) from regula-
 tion under BAT on the basis of Paragraph 8(a)(iii) of the Settlement Agreement
 because these  pollutants were "...effectively, controlled by the technologies
 upon which are based other effluent limitations guidelines and standards..."
                                    '  VI-15

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                             TABLE VI-3.
         TWO TOXIC POLLUTANTS EXCLUDED FROM REGULATION FOR BAT
       SUBCATEGORIES ONE AND TWO UNDER PARAGRAPH 8(a)(iii) OF THE
cr,^TJE^xuENT AGREEMENT BECAUSE THEY WERE "... NOT DETECTED BY
SECTION 304(h) ANALYTICAL METHODS OR OTHER STATE-OF-THE-ART METHODS
                       Hexachlorocyclopentadiene
                       N-Ni trosodimethylamine
      TWENTY TOXIC POLLUTANTS  EXCLUDED  FROM REGULATION  FOR BAT
„   SUBCATEGORIES  ONE AND  TWO  m»ER  PARAGRAPH 8(a)(iii) BECAUSE THEY
WERE  "... DETECTED IN THE EFFLUENT  FROM A SMALL NUMBER OF SOURCES AND
              ARE UNIQUELY RELATED  TO  THOSE SOURCES  ..."
                   Acrolein
                   2-Chloronaph thalene
                   4-Chlorophenyl phenyl ether
                   4-Bromophenyl phenyl ether
                   Methyl Bromide
                   N-Ni trosodi-n-propylamine
                   2-Chloroethyl vinyl ether
                   Bis (2-chloroethoxy) ether
                   Benzidine
                   Parachlorometa Cresol
                   1,2-Diphenylhydrazine
                   N-Nitrosodiphenylamine
                   Butyl Benzyl Phthalate
                   Arsenic
                   Beryllium
                   Cadmium
                   Mercury
                   Selenium
                   Silver
                   Thallium
          THREE TOXIC POLLUTANTS EXCLUDED FROM REGULATION FOR BAT
        SUBCATEGORIES ONE AND TWO UNDER PARAGRAPH 8(a)(iii)
           OF THE SETTLEMENT AGREEMENT BECAUSE THEY WERE
  "...EFFECTIVELY CONTROLLED BY TECHNOLOGIES UPON WHICH ARE  BASED
     OTHER EFFLUENT LIMITATIONS,  GUIDELINES,  AND  STANDARDS    "
                  Benzo(ghi)Perylene
                  Dibenzo(a,h)Anthracene
                  Indeno(l,2,3-c,d) Pyrene
                              VI-16

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                      TABLE VI-3.   (Continued)
EIGHT TOXIC POLLUTANTS EXCLUDED FROM REGULATION FOR BAT SUBCATEGORIES
  ONE AND TWO UNDER PARAGRAPH 8(a)(iii) OF THE SETTLEMENT AGREEMENT
   BECAUSE THEY WERE "...PRESENT ONLY IN TRACE AMOUNTS AND NEITHER
            CAUSING NOR LIKELY TO CAUSE TOXIC EFFECTS..."
                         1,1,2,2-Tetrachlproethane
                         Bis(2-Chloroethyl)Ether
                         Chlorqdibromomethane
                         Isopho.rone
                         Pentachlorophenol
                         Di-n-Octyl Phthalate
                         Bromoform
                         Di chlorobromome thane
                                 VI-17

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       In addition  to  the  18 organic  toxic pollutants  (listed  in Table VI-3)
  that vere excluded for the reasons  mentioned above,  another  eight organic
  toxic pollutants  (also shown in Table VI-3) are being excluded after examining
  the Agency's toxic pollutant wastevater loadings estimates for direct and
  indirect dischargers.  Table VI-4 presents a summary of the  toxic pollutant
  wastewater loadings estimates by direct and indirect dischargers for these
  eight toxic pollutants.   Three toxic pollutants (bis(2-chloroethyl)ether,
  bromoform,  and dichlorobromomethane), while being detected at a relatively
  high number of plants (8, 10,  and 11 plants,  respectively) in the qualitative
  frequency  of occurrence  data base,  were'estimated never to occur in the Agen-
  cy's current toxic pollutant  wastewater loadings  calculations for direct and
  indirect dischargers.  These  wastewater loadings  were calculated  on a  plant-
  by-plant basis  utilizing  each  plant's current product/process mix as reported
  in  the 1983  Section 308 Questionnaire Survey and  are  considered an up-to-date
  quantitative measurement  of a  toxic  pollutant's industry-wide presence.   Five
  toxic pollutants (1,1,2,2-tetrachloroethane, chlorodibromomethane,  isophorone
  pentachlorophenol, and di-n-octyl phthalate) had relatively low current  waste-
  water loadings predicted  using this  up-to-date product/process mix information
 with average current discharge loadings ranging from  0.007 to 0.237  Ibs/day.
 Based on these factors, the Agency has decided to exclude these eight toxic
 pollutants from regulation under BAT on the basis of paragraph 8(a)(iii) of
 the Settlement Agreement  because these pollutants were "...present only in
 trace amounts and neither causing nor likely to  cause toxic effects,.."

      In addition to the 26 organic toxic pollutants excluded from regulation
 above under  BAT,  the Agency had intended to  reserve 10 pollutants  (in addition
 to  dioxin)  in the subcategory  with end-of-pipe biological treatment (BAT Sub-
 category One) and 14 toxic pollutants (in addition to  dioxin)  from regulation
 in  the  subcategory  without end-of-pipe biological  treatment  (BAT Subcategory
 Two)  because  the  in-plant  control  performance data  for carbon  adsorption  and
 chemical precipitation  that had been  collected via  the sampling programs,
 Section 308 Questionnaire  Survey or technology transfer orior  to promulgation
 was not adequate in the Agency's judgment  to support regulation of  these
 pollutants.  However, based on an analysis of pollutant loading estimates for
 these pollutants at direct discharge  OCPSF facilities, seven pollutants (all
metals) did not appear in  the wastewater loadings estimates revised by EPA
                                    VI-18

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                                     TABLE VI-4.
                    WASTEWATER LQADDKS FOR EIGHT TOXK POLLUTANTS
                    BEING CONSIDERED FOR PARAGRAPH EIGHT EXCLUSION
                                       Direct
                        Indirect
                                                                             Total
Pollutant   Pollutant
 Number       Name
	Current            Current       Average
No. of    Daily    No. of    Daily       Plant Daily ,
Plants   Loading*  Plants   Loading*      Loading
        (Ibs/day)          (Ibs/day)   (Ibs/day/plant)
15 1,1,2,2-Tetrachloroethane 30 5.358 —
18 Bis(2-chloroethyl) ether — — —
47 Bromoform — —
48 Dichlorobromomethane — — , —
51 Chlorodibromotnethane 64 0.436 —
54 Isophorone 34 8.055 —
64 Pentachlorophenpl 	 — 13
69 Di-N-Octyl Phthalate 45 2.681 —
— 0.179 >
•. — ' — •
— —
— . — -
— 0.007
— 0.237
0.318 0.024
— 0.060
        loadings are calculated from annual loadings assuming discharge 365 days per
  year.
                                           VI-19

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  after conducting a  thorough analysis, which was discussed  in  Section V,  to
  validate the Verification Master Process File  to include only the metals
  concentration data  for product/processes that  are confirmed process sources.
  This validation found a limited number of plants that utilized these seven
  metals in their processes.  Therefore, based on the analysis  and validation
  activities, the Agency has decided to exclude an additional seven pollutants
  (arsenic,  beryllium, cadmium,  mercury, selenium,  silver, and  thallium) because
  they were  "...detected in the effluent from a small number of sources and are
  uniquely related to those sources ..." (see Table VI-3).

       This  leaves a  total  of  four pollutants that  the Agency intends  to reserve
  from regulation  under BAT Subcategory One and  eight  pollutants that  the Agency
  intends  to  reserve  from regulation  under  BAT Subcategory Two.   Tables  VI-5 and
  VI-6 present  the pollutants which have been reserved from  regulation under the
  two  BAT  subcategories.  Based  on these decisions,  the Agency will regulate a
  total of 63 toxic pollutants in  BAT Subcategory One  and  59  toxic pollutants in
  BAT  Subcategory Two.

          b*  Selection Criteria  for PSES and PSNS Toxic  Pollutants
      As discussed in Section XI, Pretreatment Standards  for Existing Sources
 (PSES) and  Pretreatment Standards for New Sources (PSNS), indirect dischargers
 need only address those pollutants that upset,  inhibit,  pass-through,  or
 contaminate sludges  at Publicly Owned Treatment Works (POTWs).   The Agency has
 assumed  for purposes of this  analysis and  based upon the available data, that
 within each Subcategory,  the  raw wastewaters at indirect discharging OCPSF
 plants are  not significantly  different from  those  at  direct discharging OCPSF
 plants.   In  selecting pollutants  regulated for  pretreatment  standards,  the
 toxic pollutants  that the  Agency  considered  as  candidates for BAT  regulation
 in both subcategories were  evaluated with  respect  to  the  pass-through cri-
 teria.  In the final  regulation,  the Agency  addressed the 59 pollutants  regu-
 lated  for BAT  Subcategory Two because  it was determined  that the end-of-pipe
 biological treatment  used for BAT Subcategory One was not the appropriate  PSES
 technology.   The Agency evaluated data  on removal of  these pollutants at POTWs
and at industrial treatment plants meeting BAT,   to establish which pollutants
pass through POTWs.  Pollutants found not to pass through were  eliminated from
                                    VI-20

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                 TABLE VI-5.
FOUR TOXIC POLLUTANTS RESERVED FROM REGULATION
         UNDER BAT FOR SUBCATEGORY ONE
        2,4,6-Trichlorophenol
        3,3'-Dichlorobenzidine
        Antimony
        Dioxin (TCDD)
                  TABLE VI-6.
     EIGHT TOXIC POLLUTANTS  RESERVED FROM
     REGULATION UNDER BAT  FOR SUBCATEGORY TWO
            2,4,6 - Trichlorophenol
            2 - Chlorophenol
            3,3' - Dichlorobenzidine
            2,4 - Dichlorophenol
            2,4 - Dinitrotoluene
            2,6 - Dinitrotoluene
            Antimony
            Dioxin (TCDD)
                      VI-21

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  consideration for regulation under PSES and PSNS.   The remaining pollutants
  were then selected as candidates for regulation.   The procedure used for the
  pass-through analysis is described below.   Results of this procedure for both
  BAT subcategories are shown in Tables VI-7 and VI-8.

           c.   PSES Pass-Through Analysis
      Prior  to establishing  pretreatment standards  for a  toxic  pollutant,  the
 Agency must  determine whether  the  pollutant  passes  through POTWs  or  interferes
 with POTW operation or sludge  disposal  practices.   In determining whether
 pollutants pass through  a POTW,  the Agency generally  compares  the percentage
 of a pollutant removed by POTWs  with  the percent of a pollutant removed  by
 direct discharging industrial  facilities applying BAT.  Under  this approach, a
 pollutant is deemed to pass through the POTW when the  average percentage
 removed by POTWs nationwide is less than the percentage removed by direct
 discharging industrial facilities applying BAT for that pollutant.

      This approach to the definition of pass-through satisfies two competing
 objectives set by Congress:   that standards for indirect dischargers be analo-
 gous to standards for direct dischargers, and that  the treatment capability
 and  performance of POTWs  be  recognized and taken into account in regulating
 the  discharge of pollutants  from indirect dischargers.  Rather than  compare
 the  mass  or concentration of pollutants discharged  by POTWs with the mass or
 concentration of pollutants  discharged by direct dischargers,  EPA compares the
 percentage of the  pollutants removed  with POTWs'  removals.   EPA takes this
 approach  because a comparison  of mass  or concentration of pollutants  in a POTW
 effluent  with pollutants  in  a  direct  discharger's effluent  would not  take into
 account the mass of pollutants  discharged  to  the POTW  from  nonindustrial
 sources nor the dilution  of  the pollutants  in the POTW effluent  to lower  con-
 centrations from the addition of  large amounts  of nonindustrial wastewater.

     Presented  below are  brief  descriptions of  PSES pass-through analysis
methodologies utilized  for proposal and  the two Federal Register NOAs as well
as a more detailed discussion of  the methodology and results of the PSES pass-
through analysis used for the final regulation.
                                    VI-22

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                                      VI-25

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VI-26

-------
March 1983 Proposal Approach
     In the March 21, 1983 proposal (48 FR 11828), the Agency modified the
general pass-through analysis methodology discussed above.  Cognizant of the
analytical variability typical of organic toxic pollutants in POTW and OCPSF
wastewater, EPA proposed to find that pass-through occurs only if the percent-
age removed of a certain pollutant by direct dischargers applying BAT is at
least 5 percent greater than the percent removed by well-operated POTWs
("Five percent differential").  The methodology used  for calculating POTW and
industrial percent removals was as follows:  1) for an individual POTW or
OCPSF plant,  the influent and effluent data around the particular treatment
system were paired on a daily basis; 2) daily  percent removals were calculated
for each  pollutant;  3) an average daily "percent removal was  calculated for
each pollutant by OCPSF plant or POTW; and 4)  for each pollutant, a median
percent removal was  calculated using average daily percent removals for  each
OCPSF plant or POTW.  Also,  the Agency assumed pass-through  for  all pollutants
that did  not  have POTW percent removals, but were regulated  under BAT  and had
OCPSF industry percent removal data.

     Using the above methodology,  EPA  determined  that six pollutants  in  the
Plastics-Only subeategory and  29  pollutants  in the Not  Plastics-Only  subcate-
gory should be  controlled under  PSES and  PSNS  on  the basis of pass-through.
 (These  subcategories appeared  in the proposal, but  have not  been retained in
 the final regulation.)

 July 1985 NOA Approach
      In the July 17, 1985 Federal Register NOA,  the Agency retained the same
 methodology used for the March 1983 proposal,  but introduced several different
 approaches for public comment and included additional OCPSF sampling data
 (i.e.,  the EPA 12-Plant Sampling Study) in the OCPSF percent removal calcula-
 tions.   These approaches included the use of either  a 0 percent differential
 or a 10 percent differential between POTW and OCPSF  percent removals in deter-
 mining pass-through and the possible finding of pass-through for selected
 volatile pollutants that are air stripped in POTW collection and treatment
 systems, regardless of whether they passed through using the traditional pass-
                                      VI-27

-------
 through analysis.  A list of  these volatile pollutants  is presented  in Table
 VI-9.  Section VIII discusses air emissions from wastewater  treatment systems
 and the derivation of  this list.

      Based on this methodology, the Agency proposed control of 48 toxic pol-
 lutants under PSES and PSNS using the traditional pass-through methodology and
 identifying pollutants of concern for which POTW percent removal data were not
 available.  The Agency also proposed to find pass-through for 12 toxic vola-
 tile and seraivolatile pollutants on' the basis of volatilization.

 December 1986 NOA Approach
      After assessing the public comments on the July 17, 1985 NOA,  a number of
 different pass-through analysis methodology changes were examined,  including:
 1) the use of all published literature sources in determining a representative
 POTW percent  removal for all pollutants  without full-scale POTW percent
 removal data;  2)  the continued finding of pass-through for pollutants volatil-
 ized rather than  treated by POTWs;  3)  modifying the typical  pass-through
 analysis  in order to not regulate  certain acid and  base/neutral pollutants
 that were regulated  based on pass-through analysis  results,  but might be  shown
 not  to pass-through  based on certain means of  evaluating industry and POTW
 removals  for  comparable ranges of  influent pollutant concentrations;  4) chang-
 ing  the methodology  for calculating the  POTW and OCPSF percent  removals;  and
 5) modifying  the  5 percent differential  rule between POTW and OCPSF percent
 removals.

     The first revision of the original  POTW pass-through analysis incorpor-
 ated literature,  pilot-  and bench-scale  plant  percent  removal data for POTWs
 for  those  toxic-pollutants that were not adequately covered by  the 40 POTW
 Study data base.  In the  previous pass-through analyses,  toxic pollutants  with
no full-scale POTW percent removal data were considered  to pass through POTW
 treatment systems, requiring them to be regulated under  PSES.  For those pol-
lutants without full-scale POTW removal data,  the PSES cost estimates for  the
December 1986 NOA were based on POTW percent removals from a number of sources
that were utilized to perform the revised pass-through analysis.  These
sources included a report to Congress that presented the results of a study
                                    VI-28

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                                 TABLE $1-9.
                  VOLATILE AND SEMIVOLATILE TOXIC POLLUTANTS
                   TARGETED FOR CONTROL DUE TO AIR STRIPPING
(1) Acenaphthene*
(3) Acrylonitrile*
(4) Benzene
(6) Carbon Tetrachloride
(7) Chlorobenzene
(8) 1,2,4-Trichlorobenzene
(9) Hexachlorobenzene
(10) 1,2-Dichloroethane
(11) 1,1,1-Trichloroethane
(12) Hexachloroethane
(13) 1,1-Dichloroethane
(14) 1,1,2-Trichloroethane
(16) Chloroethane
(23) Chloroform
(25) 1,2-Dichlorobenzene
( 26 ) 1,3-Di chlorobenzene
(27) 1,4-Dichlorobenzene
(29) 1,1-Dichloroethylene
(30) 1,2-Trans-dichloroethylene
(32) 1,2-Dichloropropane
(33) 1,3-Dichloropropylene
(38) Ethylbenzene
(42) Bis (2-chloroisopropyl) Ether*
(44) Methylene Chloride
(45) Methyl Chloride
(48) Dichlorobromomethane
(52) Hexachlorobutadiene
(55) Naphthalene*
(85) Tetrachloroethylene
(86) Toluene
(87) Trichloroethylene
(88) Vinyl Chloride
*These pollutants were determined to be less susceptible to air stripping and
 removed from the list of volatiles for which volatilization overrides the
 percent removal pass-through analysis.
                                     VI-29

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 examining  the discharge of  listed hazardous wastes  to POTtfs  (the February  1986
 Domestic Sewage  Study), the General Pretreatment Regulations  (40 CFR  128 and
 403), and  the best professional judgment estimates  of EPA's Wastewater Engi-
 neering Research Laboratory (EPA-WERL) and other Agency personnel based on
 various pilot-plant studies performed by or for EPA-WERL.

      The second  revision involved the permanent incorporation of the  finding
 of pass-through  for volatile pollutants that are air stripped rather  than
 treated in POTtfs (see Table V-9).

      In addition to evaluating alternative data sources to replace missing
 full-scale POTtf percent removals, the Agency also performed further analyses
 using the 40 POTtf Study and the OCPSF data bases to evaluate treatability of
 toxic pollutants as it relates to influent concentration levels.  Specific-
 ally, these data were first plotted to show a relationship between percent
 removal and influent  concentration and then a comparison of the POTW and  OCPSF
 plots were  made.   To  facilitate the analysis,  the toxic pollutants  were
 combined into groups  that  have previously been used in the calculation of
 toxic pollutant  variability factors  (See  Section VII).   In general,  few of  the
 groups had  both  adequate POTtf  and OCPSF data to draw any firm conclusions.
 Since POTtfs and  OCPSF facilities  do  not have equivalent  influent concentra-
 tions for most pollutants  (because  of  the dilution  effects of domestic sewage
 and other industry wastewaters  on POTW influents),  POTtf  percent  removals  tend
 to be based upon  calculations  using  lower average influent concentration.
 Thus,  the percent removal  results may  be  strongly influenced  by  the  influent
 concentration.  Another factor  influencing  the  percent removals  is related  to
 effluent concentration.  From  the groups  with adequate data,  a definite asymp-
 totic  relationship was observed for  certain groups,  that generally occurs
 because of  the analytical minimum levels  ("limits of detection") at  the low
 end of the  concentration range.  For many of the pollutant groups, this does
 not indicate an inability to remove pollutants  but the lack of quantification
 below  the analytical minimum level that limits  the maximum percent removal
 that can be calculated.

     Based on these results, selected pollutants were identified for further
analysis from the following groups:
                                    VI-30

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     «  Group 1  - Halogenated Methanes
     •  Group 2  - Chlorinated C2s
     •  Group 11 - Aromatics
     •  Group 12 - Polyaromatics (PNAs)
     •  Group 13 - Chloroaroraatics
     «  Group 16 - Phthalate Esters j
     •  Group 18 - Benzidienes
     •  Group 19 - Phenols.

     Comparing POTW and OCPSF percent removals at individual influent ranges,
a detailed pass-through analysis was performed for each selected pollutant.
The results of this analysis were that seven pollutants (acenaphthene, ben-
zene, chloroform, phenol, anthracene, phenanthrene, and toluene) that had
previously been considered to require regulation based on pass-through analy-
sis results were now shown not to pass-through.  However, since all but three
of these pollutants were contained in the list of volatile pollutants, only
phenol, anthracene, and phenanthrene were selected for consideration in this
alternative regulatory option as not passing through.

     The fourth revision involved the evaluation of the methodology used to
calculate the POTW and OCPSF percent removals used in the PSES pass-through
analysis, which was revised to conform with other calculations being used  for
limitations development and to avoid the use of daily influent/effluent pairs
in order to accommodate retention times in treatment systems larger than
24 hours.  The new data editing methodology was as follows:  1) all influent
and effluent data around the biological treatment system were assembled;
2) average influent and effluent  concentrations were calculated for each
pollutant; 3)  an average percent  removal was calculated  for each pollutant
(instead of an average daily percent removal); and 4) for each pollutant,  a
median  percent removal was  calculated  using the average  percent removals for
each  OCPSF plant or POTW.   Also,  based on revised BAT industry data editing
techniques,  industrial percent  removal data were no longer available  for six
toxic pollutants  (1,1-dichlbroethane,  bromoform, dichlorobromomethane,  penta-
chlorophenol,  cadmium, and silver).  Therefore,  these pollutants were  elimi-
nated.  Also,  these revised BAT data editing  techniques  eliminated some indus-
trial data,  thus  changing  (raising  or  lowering, depending on  the pollutant)
the  calculated industrial  percent removals.
                                     VI-31

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      Finally, the Agency decided not to use a 5 or 10 percent differential and
 concluded that the most reasonable approach is to accept the available data as
 the best information on the relative percent removals of BAT and POTWs and to
 perform BAT/POTW comparisons directly based on that data.  EPA decided that
 such an approach was unbiased in that it does not favor either the over-
 statement or under-statement of pass-through for the pollutants.

 Adopted Approach and Rationale
      After reviewing public comments received on the December 1986 NOA pass-
 through methodology revisions,  the Agency again examined its procedures and
 instituted a final set of changes.   As stated previously, the Agency decided
 not to use a 5 or 10 percent differential.   In urging EPA to adopt a 5 or
 10 percent differential,  commenters stated  that use of the differential would
 address the problem of low POTW effluent concentrations  that may mask the full
 extent of POTW treatment.   These commenters also  supported the rationale that,
 in addition to analytical variability,  a differential was supported by the
 fact  that POTW influent concentrations  are  typically  much lower  than industry
 treatment system  influent  concentrations, and  many  POTW  effluent  samples  are
 below detection,  preventing a complete  accounting of  all pollutants removed  by
 the POTW.

      The  problem  with  using a differential  is  that  it  is uncertain  whether the
 POTWs  are treating  to  levels substantially  below detection  or not,  since  the
 data  analyses  results  were  from  measurements only to  the detection  limits.
 Thus,  it  is difficult  to determine  the extent  to which POTW removals  are
 underestimated and  the  degree to which compensation is justified.   (It should
 be  noted  that  the risk  of underestimation exists also with  respect  to  calcu-
 lating BAT removals with data reflecting effluent levels  below the  detection
 level.)  Moreover, a 5  or 10 percent differential, unless restrictively
 drafted, would often result in overcompensating for the uncertainty.  It
 should be noted that to allow even a few pollutants to go unregulated based on
 the 5 percent differential could be significant in terms of the number of
pounds of unregulated toxic pollutants discharged.  Finally, the potential
effect discussed by the commenters will be greatly mitigated by changes in the
data editing criteria,  which are discussed below.
                                    VI-32

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     EPA has modified the criteria under which the full-scale POTW data for
conducting the pass-through comparison test were selected.  In previous analy-
ses, EPA used data when influent concentrations exceeded 20 ppb.  For pollu-
tants with low influent concentrations, i.e., not much higher than 20 ppb, the
effluent concentrations were consistently below the detection level and could
not be precisely quantified.  The conservative technique of estimating the
effluent by rounding it up to the detection limit had the effect of understat-
ing the POTW's percent removal.  In many cases, in fact, both POTW and BAT
treatment systems with relatively low  influent concentrations yielded efflu-
ents below detection, and the resulting percent removals were not true mea-
sures of treatment effectiveness, but  rather were primarily functions of  the
influent concentrations.  The percent  removal comparison  thus had the effect
of  determining pass-through  if and only if  the POTW had a lower pollutant
influent concentration, rather than basing  the determination on true treat-
ability criteria.  A second  concern with the 20 ug/1 criterion  is its incon-
sistency with the criteria used  to select  industry data that EPA considers
generally acceptable for assessing treatability and calculating BAT effluent
limitations.  One of EPA's criteria for using  industry data  to  set effluent
limitations  is  that  the  influent data  must  exceed 10  times  the  pollutant's
minimum analytical  threshold level for that plant.  When  an  influent concen-
tration is  below this  level,  effluent  concentrations  below  the  pollutant's
analytical  minimum  level often may be  achieved using  less than  BAT level
treatment.   The editing  criterion ensures  that effluent limitations generally
reflect  the technical  capability of BAT level  treatment rather  than  low influ-
ent concentrations.

      Consistent with the general BAT  editing approach,  EPA has  used  the "ten
 times the minimum level" (i.e.,  100  ppb for most  pollutants)  criterion for BAT
 and POTW influents  for purposes  of  selecting the data used to perform pass-
 through comparisons for the final rule when available.   When BAT or  POTW
 influents greater than "ten times the minimum level"  were not available,
 pass-through comparisons were made using the 20 ppb criterion for BAT and POTW
 influents.   For the final pass-through determination, 28 of the pollutants
 were found to pass-through using data edited at 10 times the minimum level;
 three pollutants demonstrated no pass-through at this level of editing.
                                      VI-33

-------
       EPA also retained the modified approach of calculating plants'  percent
  removals using average plant removals.   Previously,  for each plant,  EPA had
  averaged daily percent removals.   This  is technically inappropriate.   First,
  many OCPSF treatment systems have retention times exceeding one day's time.
  Thus,  it is improper to compare influent and effluent samples taken  on the
  same day.   Second,  even if the retention time is  shorter than a full  day, any
  sampled  influent, after mixture and dispersal within  the treatment system,
  cannot be  traced  to a particular  sample  leaving the system.   In fact,  in  the
  typical  biological  treatment  system, a portion of the biological  solids are
  recirculated within the system.   Thus again,  it is improper  to  compare any
  influent and effluent  samples  as  a  pair.  Third,  due  to  the  low concentrations
  found in both OCPSF treatment  and POTW biological systems (due  to dilution by
  other wastewaters),  small  daily changes  in pollutant  concentrations yield a
 misleading picture  of  variability in the daily efficiency of  these systems.
 Therefore, EPA has  modified its approach to calculate a plant's percent
 removal by averaging all influent samples, averaging all effluent samples, and
 calculating percent removals using  these averages.

    The Agency also decided to retain the use of qualified bench- or pilot-
 scale POTW percent removal data in the absence of  sufficient full-scale POTW
 removal data on specific pollutants to perform the removal comparison.  A
 summary of the bench/pilot-scale data results and  the  studies that are the
 sources of these data is presented in Table  VI-10. Despite  the fact  that  EPA
 sampled 50 POTWs in  addition to conducting many OCPSF  sampling efforts, there
 are 12 pollutants  regulated at BAT for which EPA lacks sufficient  full-scale
 POTW data to perform this analysis.   In  the  1983 proposal, EPA adopted the
 approach  of assuming pass-through  in the  absence of data  to  the  contrary.
 Some industrial  commenters  objected  to this  approach arguing  that  Section
 307(b) authorizes  EPA to promulgate  pretreatment standards only  for pollutants
 that pass-through  or interfere  with  the POTW,  and  that  EPA is  thus required
 to  affirmatively find pass-through or interference as  a precondition to pro-
 mulgating pretreatment  standards.  Environmental groups argued to  the  contrary
 saying that EPA has  an  obligation  to require pretreatment if  there may  be
 pass-through or interference and that in  the absence of adequate data,  the
 possibility of pass-through must be assumed.   In subsequent notices, EPA
 requested comment on an alternative approach of using qualitative data  to
determine POTW removal rates in the absence of full-scale quantitative data
                                    VI-34

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and to use that data for the comparative analysis.  EPA made the alternative
approach data available for comment.  After considering public comments on
this approach and on the data to be used, EPA has decided in the final rule to
use certain pilot- and bench-scale .data when adequate full-scale POTW data are
lacking.  These alternative data were used for seven pollutants, and four of
these pollutants were found to pass-through.

     EPA disagrees with the comment that it must assume pass-through in the
absence of quantitative data to the contrary.  Section 307(b) of the Act
requires EPA  to promulgate pretreatment standards "for those pollutants which
are determined not to be susceptible to'treatment by (the POTW) or which would
interfere with the operation of such treatment works."  Thus, at least one
reasonable interpretation of the statute is that EPA must make a determination
of pass-through or interference prior  to promulgating pretreatment standards,
rather  than assume pass-through.   In any event,  the statute does not prohibit
the use of bench- or pilot-scale data  when  they  are the best available data.
Certainly, EPA has a preference for full-scale POTW data and has expended
considerable  resources  to obtain such  data  for the OCPSF rulemaking.  However,
to address remaining full-scale POTW data gaps,  EPA believes  that  it  is
appropriate  to use the  besjt alternative  information available.   Some  industry
commenters objected  that  the alternative data are of lesser quality  than  the
full-scale POTW data and  have  a larger range of  potential  error.   EPA acknow-
ledges  that  this  may be the case with  estimates  not based  on  pilot-  or  bench-
scale studies.  However,  EPA believes  that  the pilot-  or bench-scale data used
for  the seven pollutants  for which, pass-through  is  evaluated  for this rule-
making  are  of sufficient  technical quality  to  use in  the  comparative analysis
and  may thus be used  in the absence of adequate  full-scale POTW data.   Fur-
 ther, EPA does not  agree that  the  use  of a  5  or  10  percent differential to
compare BAT and  POTW removal  efficiencies  is  compelled when using alternative
data.  As discussed  previously,  any error  in the data,  whether full-scale or
not,  can affect  results in either  direction.

      Finally, the Agency has  retained the override of the pass-through analy-
 sis results for three volatile pollutants where the overall percent removal
 includes in substantial part  the emission of these pollutants to air rather
                                      VI-37

-------
  than actual  treatment.  As discussed  in  Section VIII, EPA has decided  to
  regard  these  three pollutants  (hexachlorobenzene, hexachloroethane, and hexa-
  chlorobutadiene), as passing through  the POTW due to volatilization and thus
 warranting promulgation of pretreatment  standards.

      Table VI-11 presents the  results of the final PSES pass-through analysis
 for the 59 toxic pollutants being regulated under the non-end of pipe biologi-
 cal subcategory (BAT Subcategory TWo).   Based on the results of this final
 analysis, 47 toxic pollutants have been  determined to pass-through POWs and
 thus require regulation under PSES and PSNS.  Summaries of the results for
 pollutants not regulated are presented in Tables VI-12 through VI-16.

      The Agency performed an additional PSES pass-through analysis, which used
 the same methodology as discussed above except that  OCPSF percent removals
 were calculated using the end-of-pipe biological (BAT Subcategory One)  per-
 formance data base.   The results of this  alternative pass-through analysis
 (presented in Table  VI-8)  show  that a total of 47  toxic  pollutants pass
 through.  Because  the final  PSES are based  upon physical-chemical treatment
 (including in-plant  biological  treatment  for certain organip  pollutants),
 unlike  the proposed  PSES which  were based upon biological  treatment,  the  final
 pass-through  analysis calculated OCPSF percent  removals  based upon the  per-
 formance required  by  BAT Subcategory Two  (noh-end-of-pipe biological treat-
 ment).   This  ensured  that  PSES  would be required only  if  the  PSES  limits
 (which are based upon BAT  Subcategory  Two limits) would result in  percent
 removals exceeding those achieved by POTWs.  These results are reflected in
 Table VI-7.  The six  toxic pollutants, listed in Table VI-12, could not be
 evaluated  by  the PSES pass-through analysis  because estimated volatilization
 rates are  low and POTtf percent  removal data  could not be obtained.  An analy-
 sis was  conducted of pollutant  loading estimates for these pollutants at indi-
 rect, full response OCPSF  facilities revealed that the toxic pollutants 2,4-
 dinitrophenol, benzo(k) fluoranthene, and acenapthylene would be treated by an
 appropriate in-plant control installed on the same waste streams for other
 toxic pollutants that have been determined to pass through.  Table VI-14 pre-
sents the results of this analysis.   Therefore, the Agency has decided to
exclude three of these toxic pollutants from regulation under PSES and PSNS on
 the basis of Paragraph 8(a) (iii)(4) of the Settlement Agreement  since they
                                    VI-38

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                                   TABLE VI-11.
     FORTY-SEVEN TOXIC POLLUTANTS DETERMINED TO INTERFERE WITH,.INHIBIT,,
           OR PASS-THROUGH POTWS,  AND REGULATED UNDER PSES AND PSNS
                             BASED ON TABLE VII-7
Pollutant Name
        Reason For Regulation
Acenaphthene
Benzene
Carbon Tetrachloride
Chlorobenzene
1,2,4-Trichlorobenzene
Hexachlorobenzene
1,2-Dichloroethane
1,1,1-Trichloroethane
Hexachloroe thane
1,1-Dichloroethane
1,1,2-Trichloroethane
Chloroethane
Chloroform
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethylene
1,2-Trans-Dichloroethylene
1,2-Dichloropropane
1,3-Dichloropropylene
2,4-Dimethylphenol
Ethylbenzene
Fluoranthene
Methylene Chloride
Methyl Chloride
Hexachlorobu tadi ene
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
4,6-Dini tro-0-Cresol
Phenol
Bis(2-Ethylhexyl)Phthalate
Di-N-Butyl Phthalate
Diethy1 Phthalate
Dimethyl Phthalate
Anthracene
Fluorene
Phenanthrene
Pyrene
Tetrachloroethylene
Toluene
Trichloroethylene
Vinyl Chloride
Cyanide
Lead
Zinc
Pass-through Comparison; @ 10 x MDL
Pass-through Comparison @ 10 x MDL
Pass-through Comparison @ 10 x MDL
Pass-through Comparison @ 10 ,x MDL
Pass-through Comparison @ 10 x MDL
Volatilization          "
Pass-through Comparison @ 10 x MDL
Pass-through Comparison @ 10 x MDL
Volatilization
Pass-through Comparison @ 20 ppb
Pass-through Comparison i@ 20 ppb
Pass-through Comparison @ 20 ppb
Pass-through Comparison @ 10 x MDL
Pass-through Comparison @ 10 x MDL
Pass-through Comparison @ 20 ppb
Pass-through Comparison @ 20 ppb
Pass-through Comparison @ 10 x MDL
Pass-through Comparison 
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                 TABLE VI-12.
SIX TOXIC POLLUTANTS DETERMINED NOT TO INTERFERE
 WITH, INHIBIT, OR PASS-THROUGH POWs, AND EXCLUDED
       FROM REGULATION UNDER PSES AND PSNS
              Benzo(A)Anthracene
              Benzo(A)Pyrene
              Chrysene
              Chromium
              Copper
              Nickel
                TABLE VI-13.
      SIX TOXIC POLLUTANTS THAT DO NOT
   VOLATILIZE EXTENSIVELY AND DO NOT HAVE
          POTtf PERCENT REMOVAL DATA
          Acrylonitrile
          Bis(2-Chloroisopropyl)Ether
          2,4-Dini trophenol
          3,4-Benzofluoranthene
          Benzo(K)Fluoran thene
          Acenaph thylene
                   VI-40

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                               'TABLE VI-14.
                  RESULTS OF PSES ANALYSIS TO DETERMINE IF TOXIC
                    POLLUTANT REMOVALS WERE "...  SUFFICIENTLY
                     CONTROLLED BY, EXISTING TECHNOLOGIES
                                        Percent of. plants at .which the pollu-
                                        tant is adequately treated or costed
Pollutant
Number
3
42
59
74
75
77
Pollutant due td presence
Name treatable
Acrylonitrile
Bis(2-Chloroisopropyl)Ether
2 , 4-Dini trophenol
3 , 4-Benzof luoranthene
Benzo ( k) Fluoran thene
Acenaphthylene
of: .another similarly
toxic pollutant
39%
50%
;ioo%
*
100%
87%
*  Analysis could not be performed
                                     VI-41

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                      TABLE VI-15.
  THREE TOXIC POLLUTANTS EXCLUDED FROM PSES AND PSNS
     REGULATION UNDER PARAGRAPH 8(a)(iii) OF THE
SETTLEMENT AGREEMENT BECAUSE THEY WERE "... SUFFICIENTLY
       CONTROLLED BY EXISTING TECHNOLOGIES ..."
                 2,4-Dini trophenol
                 Benzo(K)Fluoranthene
                 Acenaph thylene
                     TABLE VI-16.
   THREE POLLUTANTS RESERVED FROM REGULATION UNDER
          PSES AND PSNS DUE TO LACK OF POTW
                  PERCENT REMOVAL DATA
                Acrylonitrile
                Bis(2-Chloroisopropyl)Ether
                3,4-Benzofluoran theme
                     VI-42

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will be "...sufficiently controlled by existing technologies."  The Agency has
also decided to reserve the three remaining toxic pollutants from regulation
under PSES and PSNS in addition to the seven pollutants shown in Table VI-6
(see Tables VI-15 and VI-16, respectively).
                                     VI-43

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                                   SECTION VI


                                   REFERENCES



6-1      U!CTKT™ ^HVPCR' STANDARD METHODS FOR EXAMINATION OF WATER AND
         WASTEWATER, 4TH EDITION,  WASHINGTON, DC, APHA, 19076, P. 549

6-2      Ibid., p. 94


6-3      Ibid., p. 516, 517, 519,  521.


6-4      Ibid., p. 554


6-5      Ibid., p. 534
                                   VI-44

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                   VII.   CONTROL AND TREATMENT TECHNOLOGIES
A.   INTRODUCTION
     This section identifies and describes the principal Best Management
Practices (BMPs) and in-plant and end-of-pipe wastewater control and treatment
technologies currently used or available for the reduction and removal of
conventional, nonconventional, and priority pollutants discharged by the OCPSF
industry.  Many OCPSF plants have implemented programs that combine elements
of BMPs, in-plant wastewater treatment, and end-of-pipe wastewater treatment
to minimize pollutant discharges from  their facilities.  Due  to the diversity
of the OCPSF industry, the configuration of these controls and technologies
differs widely from plant to plant.

     BMPs are in-plant source controls and general  operation  and maintenance
(O&M) practices  that prevent or minimize the potential for the release of
toxic pollutants or hazardous substances to surface waters or POTWs  (7-1).
The  following pages describe  these  in-plant source  controls  (i.e., process
modifications;  instrumentation; solvent recovery; and water  reuse, recycle,
and  recovery) and  O&M practices that  are employed,  or could  potentially  be
employed, at OCPSF plants.

     Physical/chemical  in-plant treatment  technologies are used  selectively in
 the  OCPSF industry on certain process wastewaters  to recover products  or
 process  solvents,  to  reduce loadings  that  may  impair the operation of  a
 biological  treatment  system,  or  to  remove  certain  pollutants that  are  not
 sufficiently removed  by biological  treatment  systems. The  in-plant  treatment
 technologies currently  used or available  to the OCPSF industry and available
 performance data for  these technologies are described and presented  in Part C
 of this section.

      End-of-pipe treatment systems  in the OCPSF industry employ physical,
 biological, and physical/chemical treatment,  and often consist of a
 combination of primary (neutralization and settling), secondary (biological
 high rate aeration and clarification), polishing,  and/or tertiary (ponds,
 filtration, or activated carbon adsorption) unit operations.  The end-of-pipe
                                      VII-1

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  treatment technologies currently used or available to the OCPSF industry and
  available performance data for these technologies are described and presented
  in Part D of this section.

       The performance of selected BPT and BAT total treatment systems,
  including nonbiological treatment systems,  are presented in Part E of  this
  section.   tfastewater discharge or disposal  methods (other than direct  to
  surface waters  and  indirect  through POTWs)  used by OCPSF plants,  frequently
  called  zero  or  alternate discharge methods,  are presented in Part  F.   Part G
  presents  treatment  and  disposal options  for  the sludges  resulting  from certain
  wastevater treatment  operations.   Finally, Part H  presents  the procedures  used
  to develop the  effluent  limitations  guidelines  and  standards  for the OCPSF
  industry.

      The Environmental Protection Agency (EPA)  developed  three  technology
 options for promulgating BPT.  BPT Option I consists of biological treatment,
 which usually involves either activated sludge  or aerated lagoons,  followed by
 clarification (and preceded by appropriate process controls and in-plant
 treatment to  ensure that the biological system may be operated optimally).
 Many of the direct discharge facilities have installed this level of treat-
 ment.   BPT Option II is based on Option I with the addition of a polishing
 pond to follow biological treatment.   BPT Option III is based on multimedia
 filtration as an alternative  basis (in lieu  of BPT Option II polishing  ponds)
 for additional total suspended solids (TSS)  control after biological
 treatment.

     EPA has  selected  BPT Option I-biological treatment  with  secondary
 clarification-as  the  technology basis  for BPT limitations controlling  BOD
 and TSS  for the  OCPSF  industry.   This option has been previously described'by
 EPA as "biological treatment."   However, a properly  designed biological  treat-
 ment system includes "secondary  clarification" which usually consists of a
 clarifier following  the biological  treatment step of activated  sludge, aerated
lagoons, etc.   The rationale for  the  selection of BPT Option I as the basis
for the final  BPT effluent limitations is discussed in detail in Section IX.
                                    VII-2

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     EPA developed three final options for BAT effluent limitations.  BAT
Option I would establish concentration-based BAT effluent limitations for
priority pollutants based on using BPT-level biological treatment for tHe
end-of-pipe biological treatment subcategory.  Since some plants do not have
sufficient BOD5 in their wastewater to support (or require) biological
treatment, there is a non-end-of-pipe biological treatment subcategory.  The
plants in this subcategory db not use end-of-pipe biological  treatment.; their
BAT Option I  treatment involves  in-plant controls that consist of physical/
chemical treatment and in-plant  biological  treatment to achieve  toxic
pollutant limitations, with  end-of-pipe TSS control if necessary.

   '   BAT Option II would  establish  concentration-based BAT effluent
limitations  based on  the  performance  of  the end-of-pipe  treatment  component
(biological  treatment for the end-of-pipe  biological  treatment  subcategory and
physical/chemical  for the non-end-of-pipe  biological  treatment  subcategory),
plus  in-plant control technologies  that  remove priority  pollutants prior  to
discharge  to the  end-of-pipe treatment  system.  The in-plant technologies
 include steam stripping to remove selected volatile and  semivolatile (as
 defined by the analytical methods)  priority pollutants,  activated carbon for
 various base/neutral priority pollutants,  chemical precipitation for metals,
 alkaline chlorination for cyanide,  and in-plant biological treatment for
 removal of selected priority pollutants, including several polynuclear
 aromatics (PNA),  several phthalate esters, and phenol.

      BAT Option III adds activated carbon  to  the end-of-pipe treatment to
 follow biological treatment or  physical/chemical treatment in addition to the
 BAT  Option II level  of in-plant controls.

      The Agency has  selected Option  II as  the basis for BAT limits for both
 subcategories.  The  rationale  for  the selection of BAT Option II as the  basis
 for  the final BAT effluent  limitations  for both subcategories  is discussed in
 detail  in Section X.

      The Agency  is  promulgating PSES for  all indirect dischargers*based  on  the
  same technology  basis as the BAT non-end-of-pipe  biological treatment
  subcategory.  The  rationale for selection of this  technology basis for  the
  final  PSES  effluent limitations guidelines is discussed in  Section XII.
                                      VII-3

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       A review of waste management practices and well-designed and -operated
  wastewater treatment system configurations currently in use by the OCPSF
  manufacturing facilities, reveals that there are numerous approaches for
  implementing effective pollutant control practices.  Since the Agency does not
  specify what technology must be used to achieve the promulgated numerical
  effluent limitations and standards,  the following portions of this section
  describe the unit operations and treatment practices that provide the bases of
  the  selected technical options,  as well as alternative  unit operations and
  treatment  systems that may also  be utilized to  achieve  pollutant  reduction
  goals.   As noted  in  Section VIII,  the  Agency's  methodology for estimating the
  engineering  costs of compliance  for  individual  facilities is  based on costing
  one  or more  of  the treatment  unit  operations included in  the  selected
  technology option, depending  on  the  difference  between  current  effluent pollu-
  tant concentrations  and  target effluent concentrations  that would  be  required
  to achieve compliance with  regulatory  requirements.

 B.   BEST MANAGEMENT PRACTICES
      Best Management Practices (BMPs) consist of a variety of procedures to
 prevent or minimize the potential for the release of toxic pollutants or
 hazardous substances to surface waters or POTWs  (7-1).   Specific practices
 that  limit the volume and/or contaminant concentration of polluted waste
 streams,  such as solvent recovery,  water reuse,  and various pretreatment
 options,  involve applying BMPs to facility design.   O&M  procedures such as
 preventive'maintenance measures,  monitoring of key parameters,  and equipment
 inspections that minimize the potential for unit process failures  and
 subsequent  treatment  plant upsets are also considered part of  BMPs.   The
 following discussion  is  divided into  two parts:   in-plant  source controls
 (i.e., process modifications;  instrumentation; solvent recovery; and  water
 reuse, recycle,  and recovery)  and general  O&M practices.   Several  specific
 examples  of how  wastewater treatment  plants  improved  their performances
 through minor modifications  are also  included.

     !•  In-Plant  Source Controls
     In-plant source controls include processes or operations that reduce
pollutant discharges within a plant.  Some in-plant controls reduce or
                                    VII-4

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eliminate waste streams, while others recover valuable manufacturing
by-products.

     In-plant controls provide several advantages:  income from the sale of
recovered material, reduction of end-of-pipe treatment costs, and removal of
pollutants  that upset or inhibit end-of-pipe treatment processes (7-2).

     While  many newer chemical manufacturing plants were designed to reduce
water use and pollutant generation,  improvements  can often be made  in  older
plants  to control  pollution  from their manufacturing activities.  The  major
in-plant source controls  that are  effective  in  reducing pollutant loads  in  the
OCPSF industry are described below.

         a.   Process Modifications
     Most manufacturers within  the OCPSF industry use  one  or more  toxic  prior-
 ity pollutants  in various stages  of  production.  In some  cases,  problems per-
 taining to  a difficult-to-treat pollutant can be solved by finding less  toxic
 or easier  to treat substitutes  for that  compound.  In many cases,  a suitable
 substitute  can be found at no or minor additional cost.

      In some situations, plants can improve their effluent quality by shifting
 from batch processes to continuous operations, thus eliminating the waste-
 waters generated between batches by cleanup with solvents or caustic.  Such
 modifications increase production yields and reduce wastewater generation.

      Effluent quality at a  facility can sometimes be improved by taking advan-
 tage of'unused equipment or by simply reconfiguring existing equipment and
 structures.  Some  plant-specific  approaches are  as follows:

      •  Floor drains  likely to receive  spills can be designed  to  flow  into  a
          collection sump  instead  of directly  into an  industrial sewer system.
          This allows concentrated wastes  to be recovered,  treated,  or
          equalized prior  to being pumped  or  transferred to  the  wastewater
          treatment plant.
      •  Highly  acidic or basic waste streams  can be  neutralized  or diluted  by
          being mixed  together  upstream  of the wastewater  treatment plant.
                                      VII-5

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           Unused tanks at a facility can be fitted to intercept shock loadings
           and allow concentrated pollutants to be gradually mixed in with
           process wastewater at a high dilution rate.  Excess tank or lagoon
           capacity can also be used to increase detention times and improve
           equalization of wastewaters.
           An abandoned steam stripper from a closed process line can be con-
           Preheating or cooling waste streams designated for biological treat-
           ment can also be a great asset as activated sludge systems generally
      Two  examples  of  process  modifications  from other industries  may be  appli-
 cable  to  the  OCPSF industry.   The  first  involves biological  degradation.
 Although  anaerobic digestion  is  common at the mesophilic  temperature of  30°C,
 use of  thermophilic digestion has  gained popularity of late  because  of poten-
 tially  increased solids destruction.  New York  City,  in its  wastewater treat-
 ment operation, conducted thermophilic digestion  directly after mesophilic
 digestion.  This has led to increased sludge solids destruction, and when
 employed with increased decanting, has led to a reduction in sludge volume and
 more efficient operation (7-3).

      Another modification involves the use of a step-feed operating program.
 Having a variety of feed points enables the  protection of effluent quality
 while steps are taken to correct malfunctions in the biological treatment
 process.

          b.  Instrumentation

     Process upsets resulting  in  the  discharge of products, raw materials,  or
 by-products  are  important sources of  pollution in the  OCPSF industry.  Well-
 designed monitoring, sensor, and  alarm systems can enable  compensatory action
 to be taken  before  an unstable condition  results  in such process upsets.

     Some  common parameters  that  can  be monitored  and  controlled using various
 types of sensors and equipment  include flow (both  open channel and closed
conduit), pump speed, valve position, and tank level.  Analytical measurements
such as PH, dissolved oxygen (DO), suspended solids, and chemical residuals
                                    VII-6

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can also be monitored and regulated using feedback control equipment.  At many
facilities, the overpressurization of reaction kettles, the bursting of
rupture-disks, and the discharge of chemical pollutants could be controlled
with a proper early warning system.

         c.  Solvent Recovery
     The recovery of waste solvents has become a common practice among plants
using solvents in their manufacturing processes.  In some cases> solvents can
be recovered in a sufficiently pure form to be used in the same manner as new
solvents.  Solvents of lesser quality may still be usable in other areas of
manufacturing or be sold  to another facility for use in applications not
requiring  a high level of purity.  Also, many private  companies exist  that
collect and reclaim spent solvents which are then sold back  to the same or
other OCPSF facilities.

     Solvents  that cannot be  recovered  or reused can be destroyed  through
incineration.  Incineration may  also  be the best disposal method  for used
solvents  that  cannot  be  economically  recovered  and  for wastes  such as  bottoms
from solvent  recovery units.

     Solvent  recovery,  off-site  reclaiming,  reuse,  and incineration  are
methods of removing  solvents  from waste streams before they arrive at  an end-
of-pipe treatment  system or  a POTW.   Therefore,  they  contribute  to protecting
biological treatment units  from  toxic shocks  which could  cause poor  effluent
quality.   In addition,  as the cost for disposal of hazardous liquid  waste
 increases, solvent recovery  becomes more economical.

          d.   Water Reuse, Recycle, and Recovery
      Water conservation through reuse, recycle, and recovery can result in
 more efficient manufacturing operations and a significant reduction in indus-
 trial effluent requiring treatment.  Recycling cooling water through the use
 of cooling towers is a common industrial practice that dramatically decreases
 total discharge volume.  While noncontact cooling water may require little or
 no treatment prior to recycling (other than reducing the water temperature in
 cooling towers and adding corrosion inhibitors), treatment of the wastewater
                                      VII-7

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  prior to reuse is usually necessary  to ensure a return stream of sufficient
  quality for use in the process.  In  some cases, the treatment required is
  simple, and facilities may already exist on-site (e.g., sedimentation).

       fiy reducing the volume of wastewater discharged,  recycling often allows
  the use of abatement practices that are uneconomical on the full waste stream.
  Further,  by allowing concentrations to increase,  the opportunities for recov-
  ery of waste components to offset treatment cost  (or even achieve profitabil-
  ity) are  substantially improved.   In addition,  pretreatment costs of process
  water (and  in some cases,  reagent use) may be reduced.   For example, removal
  efficiencies for metals in chemical precipitation units  are increased at
  higher raw  waste concentrations and proper  chemical coagulant  dosage.  More
  economical  recovery of solvents is  obtained from a  properly designed steam
  stripper at elevated  solvent  feed levels.   Recycling also  enables many plants
  to achieve  zero discharge, eliminating the  need for ultimate disposal or
  surface discharge.

      Recycling systems can achieve significant pollutant load reductions or
 zero discharge at relatively low  cost.  The systems are easily controlled by
 simple instrumentation, and relatively little operator attention is required.
 The most important  design-parameter is the recycle rate (rate of return) to
 the process stream or blowdown rate from closed loop recycle systems  to avoid
 build-up of dissolved solids.

      Recycling limitations  include the potential  for plugging and scaling  of
 the process  lines and  excessive heat build-up in  the recycled water  which  may
 require cooling prior  to reuse.  Chemical  aids are often  used in  the recycle
 loops to inhibit scaling or corrosion.

      Other approaches  to  reducing  industrial discharge volumes  include equip-
ment  modifications and  separation  of stormwater and  process  wastewater.  The
use of  barometric condensers can result in significant water contamination,
depending upon  the nature of the materials entering  the discharge water
streams.  As an alternative, several plants use surface condensers to  reduce
hydraulic or organic loads.   Water-sealed vacuum pumps can also create water
pollution problems.   These problems can be minimized by using a water recircu-
lation system to reduce the amount  of water being discharged.
                                    VII-8

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     Separation of stormwater and process wastewater enables each waste stream
to receive only the treatment required, and prevents problems caused by large
volumes of stormwater being contaminated by process wastewater, which sub-
sequently requires specialized treatment.  If stormwater contains polluted
runoff from contaminated areas of a site, it may be possible to collect the
stormwater in retention basins and then gradually blend it in with process
wastewater in an equalization basin at the beginning of the wastewater treat-
ment cycle.

     2.  Operation and Maintenance (O&M) Practices
     Many O&M practices minimize  the potential  for unit process failures and
subsequent treatment plant upsets.  Inspections of those aspects of  site
operation that have  the highest potential for uncontrolled chemical  releases
should be conducted  by qualified  maintenance or environmental  engineering
staff members.  Construction  records should be  reviewed to assure  that under-
ground tanks and  pipes have  coatings or  cathodic  protection  to inhibit
corrosion.  Storage  tanks  and pipelines  should  be regularly  inspected for
leaks, corrosion,  deterioration  of  foundation or  supports,  pitting,  cracks,
deformation, or any  other  abnormalities.   Seams,  rivets,  nozzle connections,
valve  function and position,  and any  associated ancillary equipment  should.
also be  inspected regularly  to check  for deterioration as well as  potential
 leaks  from human  error (e.g., valve not  closed, loose pipe connections).

     Training  is  important to assure  that an operator reacts properly to upset
 conditions.  Treatment plant personnel should receive on-the-job and classroom
 training covering the fundamental theories of wastewater treatment,  specific
 information about the equipment in use at that facility,  the nature of
 manufacturing processes and potential for upset,  and prearranged procedures
 for responding to upset conditions.  Plants with operational flexibility may
 be able to compensate to some degree for sudden changes in weather  conditions
 or inflow volume and quality by adjusting factors such as hydraulic retention
 times and clarifier overflow rates through altering recycling rates, putting
 backup units on-line, or directing excess wastewater  to a holding basin until
 flow rates return to normal.  In addition, manufacturing personnel  upstream of
 a treatment plant should be  trained in  the proper disposal of waste chemicals
                                      VII-9

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  and the restrictions associated with disposal of wastes in industrial sewers
  or storm drains.

       Facilities handling a wide range of  chemicals  should  be  particularly
  sensitive to  potential  problems arising from  incompatible  materials  mixing  in
  tanks or pipelines.   Monitoring storm sewers  and  industrial sewers on a
  regular  basis for  toxic and hazardous pollutants  is useful in  identifying
  potential misuse of  sewers  or evidence of infiltration  of  industrial  wastes.
  This  type of internal housekeeping helps to reduce  the  potential for  uncon-
  trolled  releases from a facility or shock loadings  to an on-site treatment
  plant.

      At some facilities, waste  treatment operations can be improved by
 bringing in private contractors to handle some or all facets of operations.
 Contractors experienced in treatment plant operations may have greater avail-
 able technical resources to draw from than typical plant personnel in the
 event of an operational problem.  For example, a company specializing in
 sludge handling may be able to improve that  aspect of treatment plant
 operations with a  higher level of expertise  and a lower  cost  than plant
 personnel.   In addition, a contractor operating several  treatment plants  may
 be  able  to reduce  costs  for all  facilities  through bulk  purchasing  of
 chemicals and  pooling parts inventories.

      If  properly applied,  certain O&M  practices can  compensate  for  cold
 weather  temperatures.  Plants operating in cold weather  conditions  must
 recognize that unnecessary  storage of  wastewater prior to treatment may reduce
 the  temperature of  the biotreatment system.  Cold  weather operation may
 require insulation  of  treatment  units,  covering of open  tanks,  and/or  tracing
 of chemical feed lines.  Maintenance of higher  mixed liquor suspended  solids
 (MLSS) concentrations and a reduced food-to-microorganism (F/M) ratio  may be
necessary.  Plant-specific techniques are presented in the summer/winter
discussion in the secondary treatment  technology section.
                                   VII-10

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C.   IN-PLANT TREATMENT TECHNOLOGIES
     1.  Introduction
     In-plant treatment is directed toward removing certain pollutants from
segregated product/process waste streams before these waste streams are com-
bined with the plant's remaining wastewaters.  In-plant technologies, usually
designed to treat toxic or priority pollutants, could often be used for
end-of-pipe treatment of the plant's combined waste streams.  Using these
technologies on segregated internal waste streams is usually more cost-
effective, since treatment of low volume, concentrated, and homogenous waste
streams generated by specific product/processes is more efficient.

     In-plant treatment is frequently employed to protect the plant's end-
of-pipe treatment by removing the following  types of pollutants (7-2):

     •  Pollutants toxic or inhibitory to biological treatment systems
     •  Biologically refractive pollutants
     •  High concentrations of specific pollutants
     •  Pollutants that may offer an economic recovery potential  (e.g., sol-
        vent recovery)
     •  Pollutants that are hazardous if combined with other chemicals down-
        stream
     •  Pollutants generated in small volumes in remote areas of  the plant
     •  Corrosive pollutants that are difficult to transport.

  >•   Many  technologies have proven  effective in removing specific pollutants
from the wastewaters produced by OCPSF plants.  The selection of  a specific
in-plant  treatment scheme depends on  the nature of the pollutant  to  be
removed, and on engineering and cost  considerations.

     The  frequency of  in-plant  treatment technologies  in the OCPSF industry  is
presented  in Table VII-1.  This information  was compiled from the 546 OCPSF
manufacturers  that responded to all three parts of the Section 308 Question-
naire  and  the  394 Part A  plants that  responded  to only Part A of  the Section
308 Questionnaire.   OCPSF manufacturers  are  defined as "full-response"  if
                                     VII-11

-------
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over 50 percent of their total plant production includes OCPSF products; if
they treat their OCPSF was testers in a separate treatment system; or if only
one treatment system is employed, the non-OCPSF wastewaters contribute less
than 25 percent of the total process flow.  Part A plants are those that meet
the definition of being zero dischargers or do not meet the full-response
requirements stated above as direct or indirect dischargers.  The 1983 Section
308 Questionnaire requested information on the plant's general profile
(Part I); detailed production information (Part II); and wastewater treatment
technology, disposal techniques, and analytical data summaries (Part III).
In-plant controls frequently used by OCPSF plants for the treatment of
individual waste streams include steam stripping (82 plants), distillation
(72), filtration (54), chemical precipitation (50), solvent extraction  (29),
and carbon adsorption  (18).

     This section presents a general description and performance  data for
selected in-plant treatment processes that are currently used or  that may be
applicable to  treat wastewaters from the OCPSF industry.  General descriptions
of  the  treatment technologies are based largely upon material found in  the EPA,
Treatability Manual, most recently  revised in February  1983  (EPA-600/2-82-
OOla).  Performance data specific to various technologies are derived from
four sources.  The first source  is  OCPSF data compiled  from  responses to  the
1983 OCPSF Section 308 Questionnaire, responses to  the  Supplemental Question-
naire sent to  84 facilities, and data collected by  EPA  in several sampling
studies previously detailed in  Section V.  The second source is data obtained
from other point source categories  found  in EPA technical development
documents  and  the Treatability  Manual.  The third source  is  data  submitted as
part of public comments, on  the  proposal and NOAs.   Technical literature serves
as  the  final source of performance  data.

     2.  Chemical Oxidation (Cyanide Destruction)
     Oxidation is a chemical  reaction process  in which  one  or more  electrons
are transferred  from  the  chemical being oxidized  to.the chemical  initiating
 the transfer  (the oxidizing agent). The  primary  function performed by  oxida-
 tion is detoxification.   For  instance,  oxidants are used  to convert cyanide  to
                                     VII-13

-------
 the less toxic cyanate or completely to carbon dioxide and nitrogen.  Oxida-
 tion has also been used for the removal of phenol and organic residues in
 wastewaters and potable water.  Oxidation can also be used to assure complete
 precipitation, as in the oxidation of iron from the ferrous (Fe*2) to the
 ferric (Fe+3) form where the more oxidized material has a lower solubility
 under the reaction conditions.  Cyanide destruction (the oxidation of cyanide
 to carbon dioxide and nitrogen) is a form of chemical oxidation and will be
 used to illustrate the oxidation process,  which is discussed in detail below.

      Cyanide Destruction.   Chlorine in elemental or hypochlorite salt form is
 a strong oxidizing agent in aqueous solution,  and is used in industrial waste
 treatment facilities primarily to oxidize cyanide.   Chemical oxidation equip-
 ment often consists of an  equalization tank followed by two reaction tanks,
 although the reaction can  be carried out in a  single tank.   The cyanide alka-
 line chlorination process  uses chlorine and a  caustic to oxidize cyanides to
 cyanates and ultimately to carbon dioxide  and  nitrogen.   The oxidation
 reaction between  chlorine  and  cyanide is believed to proceed in two steps,  as
 follows :
          (1)  CN" + .01,  «  CNC1  +  Cl
          (2)  CNC1 + 20H~
CNO"
H20
The cyanates can be further decomposed  into nitrogen and carbon dioxide by
excess chlorination:
         (3)  2CNO" + 40H~ + 3C1,
        ecr
2C0
N
              2H20
     According to the Section 308 Questionnaire data base, 30 OCPSF plants use
chemical oxidation as an in-plant treatment technology; of these, 11 plants
use chemical oxidation for cyanide destruction.  Performance data for chemical
oxidation are not available for the OCPSF industry.  However, data for cyanide
destruction from the metal finishing industry are available, and can be
applied to the OCPSF industry as discussed in detail later in this section and
in Tables VII-2 and VII-3.
                                    VII-14

-------
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                        VII-15

-------
                                 TABLE VII-3.
        PERFORMANCE DATA FOR TOTAL CYANIDE OXIDATION USING CHLORINATION
                Plant  ID
 Adjusted Average Total CN
Effluent Concentration (mg/1)
12065
21051
38051
06075
36623
19050
20079
05021
20078
20080
15070
33073
09026
31021
33024
0.14
0.0
0.0
0.039
0.103
0.031
17.54
0.035
0.083
0.949
0.323
0.707
0.119
0.708
0.204
Source: Development Document for Effluent Limitations Guidelines
        New Source Performance Standards for the Metal Finishing
        Point Source Category, June 1983.
                                    VII-16

-------
     As shown in Table VII-2, removal efficiency for plant #30022 using ozone
as an oxidant varies between 87 and 96 percent.  The oxidation of cyanide
using ozone results in high capital and energy costs, and its efficiency is
limited when treating wastewaters containing more than one pollutant.  Cyanide
can also be destroyed using hydrogen peroxide, but this results in high energy
costs because the wastewater must be heated prior to treatment. Furthermore,
peroxide only partially oxidizes cyanide to cyanate, and the addition of a
formaldehyde catalyst results in a higher strength (BOD5 level) wastewater.

     Results of cyanide oxidation using chlorination from a number of metal
finishing plants can be seen in Table VII-3.  Average effluent cyanide
concentrations range from 0.0 (plant #2.1051)  to 17.54 mg/1 (plant #20079).

     EPA indicated  in its December 8, 1986, Notice that it was considering
using  the performance data for cyanide destruction from the metal finishing
industry to develop cyanide  limitations and standards.  These data are based
on alkaline chlorination (a  type of chemical  oxidation).  Public comments on
this notice suggested that EPA should transfer cyanide destruction performance
data from the pharmaceutical manufacturing  industry  rather than  from the metal
finishing industry  because of the similarity  in wasfew'ater characteristics
shared by the OCPSF and pharmaceutical categories.   EPA has evaluated the
pharmaceutical cyanide destruction performance data  and has rejected transfer
of these.data for use in the development of OCPSF  cyanide limitations because
the cyanide(destruction performance data from the  pharmaceutical industry are
from a cyanide hydrolysis  system that utilizes high  temperatures and pressures
to hydrolyze free  cyanide;  this  particular  type of cyanide destruction tech-
nology has not yet  been demonstrated  to be  effective on OCPSF  cyanide-bearing
wastewater.  EPA believes  that  the  cyanide  destruction  by alkaline  chlor-
ination data  from  the metal  finishing  industry are more appropriate  for
transfer to  the  OCPSF  industry  since  this  technology is used  on cyanide  waste
streams in  the  OCPSF  industry.

     Another  significant  issue  raised  concerning  the use  of  alkaline
chlorination technology  in the OCPSF  industry was  the contention that while
 this  technology may effectively reduce concentrations of  free cyanide in OCPSF
wastewaters,  it cannot  reduce concentrations  of metal-complexed cyanides.
                                     VII-17

-------
 Industry comraenters have stated that the limitations and standards should be
 for amenable cyanide only.  EPA has evaluated the expected amount of cyanide
 complexing resulting from the presence of certain transition metals (i.e.,
 nickel, copper, silver, and cobalt in OCPSF cyanide-bearing waste streams),
 and has concluded that only cyanide complexed by copper, silver, or nickel
 could present a problem for treatment by alkaline chlorination.  However,
 silver is found at such low levels in the process wastewater of so few
 product/processes that cyanide complexing would not present a problem, and
 only a limited number of product/process waste streams would contain combina-
 tions of either copper and cyanide (four sources),  or nickel and cyanide (two
 sources).   For these six product/process sources, a potential for cyanide
 complexing is present.   However,  no data have been submitted to demonstrate
 that the actual levels of complexing interfere with the ability of the plant
 to meet the total cyanide limitations.  Thus,  EPA believes that limitations and
 standards  controlling total  cyanide are appropriate for all dischargers
 subject to this regulation.   A discussion identifying the sources of cyanide
 and the product/processes with a  potential for complex formation with nickel
 and copper are contained in  Section V of this document.

      3.  Chemical Precipitation
      Chemical precipitation  is a  principal  technology used  to remove metals
 from OCPSF wastewaters.   Most  metals  are relatively  insoluble as hydroxides,
 sulfides,  or  carbonates,  and can  be precipitated  in  one  of  these forms.   The
 sludge  formed is  then separated from  solution  by  physical means  such as  sedi-
 mentation  or  filtration.  Hydroxide precipitation is  the conventional  method
 of  removing metals from  wastewater.   Most commonly,  caustic soda (NaOH)  or
 lime  (Ca(OH)2)  is added  to the wastewater to adjust  the  pH  to  the point  where
 metal hydroxides  exhibit minimum solubilities  and are  thus precipitated.
 Sulfide precipitation has also been demonstrated  to be an alternative  to
hydroxide precipitation  for  removing metals from  certain wastewaters.
Sulfide, in the form of hydrogen sulfide, sodium sulfide, or  ferrous sulfide,
is added to the wastewater to precipitate metal ions as  insoluble metal
sulfides. Carbonate precipitation, while not used as frequently as hydroxide
                                    VII-18

-------
or sulfide precipitation, is another method of removing metals from waste-
water.  A carbonate reagent such as calcium carbonate is added to the waste-
water to precipitate metal carbonates.  The solubility of metal hydroxides and
sulfides as a function of pH is shown in Figure VII-1.  The solubility of most
metal carbonates is between hydroxide and sulfide solubilities.

     Chemical precipitation has proven to be an effective technique for
removing many industrial wastewater pollutants.  It operates at ambient
conditions and is well suited to automatic control.  Hydroxide precipitation
has been used to remove metal ions such as antimony, arsenic, chromium,
copper, lead, mercury, nickel, and zinc;  Sulfide precipitation has mainly
been used  to remove mercury, lead, and silver  from wastewater, with less
frequent use to remove other metal ions.  Carbonate precipitation has been
used  to remove antimony and lead from wastewater.  To achieve maximum
pollutant  removals, chemical precipitation should be carried out in four
phases:  1) addition of  the chemical  to  the wastewater;  2)  rapid (flash)
mixing  to  distribute the chemical homogeneously into  the wastewater; 3) slow
stirring to promote particle growth by various coagulation  mechanisms
(flocculation); apd 4) clarification  (or  sedimentation  or filtration)  to
remove  the flocculated solid particles.

      The use of chemical precipitation  technology as well as  the availability
of performance data may  be limited  for  several reasons.  First,  treatable raw
waste concentrations of  product/process  sources of  priority pollutant  metals
are not prevalent  throughout  the industry.   Furthermore, plants  that generate
process sources of metals  and  plants  that utilize  in-plant  chemical precipi-
 tation unit  operations  also tend to rely on co-dilution of  metal-bearing
wastestreams  by non-metal-bearing process wastewater as well as  incidental
metal removals  in end-of-pipe  treatment systems.   Fifty OCPSF plants  in the
 Section 308  Questionnaire  data base report using  chemical  precipitation as an
 in-plant treatment technology;  however,  very few  facilities reported in-plant
 chemical precipitation performance data.

      Second,  sulfide precipitation technology may generate toxic hydrogen
 sulfide and may result in discharges of wastewaters containing residual levels
 of sulfide.   The generation of toxic hydrogen sulfide can be controlled by
                                     VII-19

-------
 ci
s
 o
1
+•»
1
j
102..
        10° -•
       10-2 . .
                                                           Pb (CH)2
                                                               Cr (OH)3

                                                              Zn (CH)2
                   2   34   5   6   7   8    9   10   11  12   13   14
           Figure VII-1: Solubility of Metal Hydroxides and Sulfides
                               as a Function of pH
     Source: Treatability Manual. 1981.
                              VII  20

-------
maintaining the pH of the solution between 8 and 9.5.  The discharge of waste-
waters containing sulfide can be controlled by carefully monitoring the amount

of sulfide added.


     Third, in some instances, chemical precipitation may be limited by inter-

ference of chelating agents and complexed metal ions.  Because of the varying

stabilities,of metal complexes and the wide variety of organic ligands in

OCPSF wastewaters, each plant with highly stable complexes has adapted or

should adapt its treatment system to control the concentrations of the metals

present in its process wastewater.  Thus, control options for complexed

metals, and the degree to which control is necessary or cost-effective, are

unique to individual plants.


     Several of the strategies employed by the OCPSF industry for treating

complexed metals in process wastewater are as follows:


     •  Destabilize the complex by chemically reducing  the metal's valence  to
        zero.  The released non-rionic metal is insoluble and can be captured
        via agglomeration with other solids that are being separated  from  the
        wastewater.  Reductive destabilization is also  effected by electro-
        plating, in which case the metal  is captured on the cathode.

     •  Destabilize the complex by degrading the organic ligand.  The released
        metal  is then captured a's an insoluble salt  by  subsequent addition  of
        a reagent  (e.g., lime, caustic, or sodium sulfide).  In special cases,
        ion exchange could be used to capture  the metal ion.

     •  Capture  the metal directly from  the complex  through  the addition of  a
        reagent  (e.g., sodium sulfide to  a copper complex)  that forms an
        exceedingly insoluble salt of the metal.

     •  Concentrate the wastewater (e.g., in an  evaporator)  beyond  the typi-
        cally  limited solubility  of  the metal-dye complex,  so  that  it and
        other  solids separate as  a sludge.

     •  Use carbon adsorption technology  to capture  the complexed metal  from
         the wastewater.via  the organic  ligand, which will  adsorb  on  the  carbon
        as  if  it were not complexed.


 Specific  examples  of  the  abovementioned  precipitation  technologies  are

 detailed  below:


      •   Plant  1647.   Complexed  copper  (cuprous,  +2)  in a  dyestuff process
        wastewater could  not  be  precipitated  effectively  in a  plant's combined
                                     VII-21

-------
    wastewater by lime addition.  The segregated wastewater from the
    dyestuff process was pretreated with sodium borohydride.  Although
    relatively expensive, the pretreatment destabilized the complex by
    reducing the metal ion to copper (0), which was no longer amenable to
    complexation by the organic ligand.  Since copper (0) is insoluble,
    the plant was then able to effectively remove the metal from the
    combined wastewater via agglomeration with other solids precipitated
    by the lime addition.

 •  Plant 1593.  Copper (+2) and trivalent chromium (+3) are complexed
    with organic ligands in metallized dyes manufactured at the plant.
    The product is captured as a presscake on a plate-and-frame filter.
    The filtrate,  together with wastewater from floor drains and other
    processes,  is  segregated into dilute and concentrated wastewater.
    Concentrated wastewater is concentrated still further in an
    evaporator, where most of the complexed metals separate as a residue
    which is sent  to a surface impoundment.   Condensed overhead from the
    evaporator  and the dilute wastewater from a surge lagoon (flow
    equalization),  neither of which now contains concentrations of
    complexed metals above their toxic  thresholds,  are combined as
    influent to a  powdered activated carbon (PAC)  biological treatment
    system.

    Prior to segregating  the  dilute and  concentrated  wastewaters,  the
    combined process wastewater  flow had to  be pretreated  with  activated
    carbon columns  to  protect  the  biota  from the toxic effects  of  metals
    released after  complexing  organic ligands  had  been biodegraded.  Since
    most  of  the combined  flow  was  dilute wastewater that did not contain
    complexed metals at toxic  levels, the  treatment system was  modified  to
    segregate the concentrated wastewater  for  pretreatment to eliminate
    the carbon  column.  Substantial  operating  cost savings were achieved
    by these modifications.

•   Plant  1572.  Cadmium  (+2) chelated with an unknown organic  ligand  is
    used as  a catalyst in a reactor.  Reactor  washout  is treated with
    sodium hydrosulfide to form a cadmium sulfide precipitate directly
    from the complexed cadmium.  The solids are captured by centri-
    fugation, and the centrifugate is passed - through a rapid sand filter
    to capture any fines.  The solids from the centrifuge  are saved and
   are1 available to the plant as a cadmium reclaiming option with the
   catalyst supplier.

•  Plant 1769.   Two organometallic products,  tetraethyl lead (TEL) and
   tetramethyl lead (TML), are produced at this plant.  Although the
   chemical bonding in organometallies differs from the metallized dye
   complexes discussed previously, the treatment technology is the same
   in principle.  After adjusting the wastewater to a pH of 8 to 10 with
   dilute sulfurie acid,  sodium borohydride is added  to reduce the ethyl
   groups to ethane by hydride transfer.  The released lead (+4) then
   reacts with  water to precipitate lead dioxide,  which is captured in a
   clarifier.  The lead dioxide is recycled to refiners,  which regenerate
   the lead  for sale to the market.
                              VII-22

-------
     •   Plant  2447.   This  plant  manufactures  oil-soluble dialkyl dithio-
        carbamates  and  water-soluble  dithiocarbamates  of antimony,  cadmium,
        nickel,  lead, and  zinc.   The  metals  in this  plant's wasteyater are not
        present  as  stable  complexes but  as salts of  organic acids.   This
        example  is  given only to illustrate  the wide variety of treatment
        strategies  used by the OCPSF  industry to control metals.
        Since  metal dithiocarbamates  have low solubility in water,  a
        precipitating reagent is readily available that is effective for con-
        trolling these  metals in the  wastewater.  The  wastewater .is generated
        in batches  as washout from mixing tanks and  reactors, and is collected
        in a storage tank.  Depending on the characteristics; of the batch, the
        plant  will  either  incinerate  the waste, or route it to the wastewater
        treatment system.   Treatment  consists of adding sodium dithiocarbamate
        to precipitate  the metals, and a coagulant (ferrous sulfate) to aid
        settling of the solids in a clarifier.-

     Wastewaters from the OCPSF  industries generally do not contain high con-
centrations of metal ions.  Rayon and certain acrylic fibers manufacturing,
however, generate elevated levels of zinc in wastewaters.  Other industrial
processes may also have metals in their wastewaters due to use of metals in
chemical processing and as trace contaminants from raw materials and
equipment.

     In the December 8, 1986, Federal Register Notice of Availability,  the
Agency proposed  to establish limitations for metals, from OCPSF  plants with and
without end-of-pipe biological  treatment in-place for BAT  and PSES based upon
the use of hydroxide precipitation data  from several metals  industries.  For
OCPSF waste streams with  complexed metals, EPA  proposed the  use  of sulfide
precipitation to achieve  the same limitations.                       ,

     Industry commenters  strongly criticized several aspects of EPAfs  proposed
approach.  First,  they  argued that most  priority pollutant metals  are  not
present in significant  quantities in OCPSF wastewaters.   They  criticized^the
data base upon  which EPA  had  estimated  loadings for these pollutants.   They
argued  that these  pollutants  resulted not from OCPSF,processes,  many,of which
do not  use metals,  but  rather from non-process wastewaters (e.g.,  zinc and
chromium  used as corrosion inhibitors and .often contained in cooling water
blowdown) or  due to their presence in intake waters.   The commenters concluded
that EPA  should regulate  only those  metals  present  in OCPSF process  waste-
waters  as a result of  the process use of the metals,  applying the  limits to
those wastewaters  only.
                                     VII-23

-------
       To address these comments, EPA has conducted a detailed analysis of the
  process wastewater sources of metals in the OCPSF industry.   In response to
  criticism that EPA has relied too heavily on limited Master  Process File
  metals data,  EPA reviewed the responses to the 1983 Section  308 Questionnaire
  to  examine which metals were used as catalysts in particular OCPSF product/
  processes,  or were for other reasons likely to be present  in the effluent  from
  these processes.   When necessary,  EPA contacted plant  personnel for additional
  information.   The results of EPA's analysis,  together  with supporting documen-
  tation, are set  forth  in Section  V of this document.

       Based upon  this analysis,  EPA has  concluded  that  chromium,  copper,  lead,
 nickel, and zinc  are discharged from OCPSF process  wastewaters  at  frequencies
 and levels that warrant  national  control.   However, EPA agrees  that many OCPSF
 wastewaters do not contain these pollutants or  contain them only at insignif-
 icant levels.  At most plants, process wastewater flows containing  these
 metals constitute only a small percentage  of the total plant OCPSF process
 wastewater flow.  As a result, end-of-pipe data obtained by EPA often do not
 reflect treatment but rather reflect  the dilution of metal-bearing process
 wastewater by nonmetal-bearing wastewater.  Thus, these data are unreliable
 for  the purpose of setting effluent limitations reflecting the use of best
 available technology.   Consistent with the comments, EPA has  decided to focus
 its  regulations on metal-bearing process wastewaters only.

      The concentration limitations are based upon the use of  hydroxide
 precipitation  technology, which is the standard metals  technology that forms
 the  basis  for  virtually all of EPA's BAT metals limitations for  metal-bearing
 wastewaters.   Because  very little  OCPSF data on the  effectiveness of hydroxide
 precipitation  technology are  available,  EPA has decided to  transfer data  for
 this  technology from the metal finishing industry  point source category.  A
 comparison  of  the  metals  raw  waste  data from the metal  finishing industry
 data base with the validated  product/process OCPSF raw  waste  data  indicates
 that the concentrations  of  the metals of  concern are generally within  an
acceptable range of concentrations  found  at metal  finishing plants,  except  for
lead.  Table VII-4 presents this comparison of  available OCPSF and metal
finishing raw waste metals concentrations.   With respect to lead, some OCPSF
plants' raw waste  concentrations exceed the  range of metal finishing raw waste
                                    VII-24

-------
                                 TABLE VII-4.
                   COMPARISON OF OGPSF AND METAL FINISHING
                 RAW WASTE METALS AND CYANIDE CONCENTRATIONS
Parameter
Range of OCPSF
Raw Waste Concen-
trations  (mg/1)
                                                               Metal Finishing
                                             Range of          Effluent Long-
                                           Metal Finishing      Term Average
                                             RaV Waste          Concentration
                                          Concentrations (mg/1)     (mg/1)
Total Chromium (119)

Total Copper (120)

Total Cyanide (121)

Total Lead (122)

Total Nickel (124)

Total Zinc (L28)3
  0.200-0.799

  0.100-14.500

  0.140- 5200.000

 50.060-218.9002

  0.270-4.000

  0.400-20.000 ,
p.650-393.000

0.880-108.000

0.045-1680.000

0.052-9.701
             !

1,070-167.000

0.630-175.000
0.572

0.815

0.180

0.197

0.942

0.549
1OCPSF raw, waste concentration data are limited  to data  from  the Master
 Process File for only  product/processes  that are validated process sources of
 metals.                                             ._

2OCPSF raw waste concentration data for lead are from two  validated product/
 processes that occur at  the  same  plant.  These  values compare  to  the  raw
 waste concentrations for a lead battery  manufacturing facility (identified as
 plant #672  in  the  battery manufacturing  industry study).  The  lead battery
 plant raw waste concentration range  was  2.21  to 295 mg/1  for lead; its
 effluent long-term average concentration (after lime/hydroxide precipitation)
 was  0.131 mg/1.  The effluent data ranged  from  0.01 to  0.81  mg/1.

 3Excludes raw waste zinc  concentrations  from rayon and acrylic  fiber
 manufacturers.                                            ,                 ;,
                                     VII-25

-------
  concentrations.  A comparison was made between the available OCPSF raw waste
  concentrations and the data from the lead battery subcategory of the battery
 .manufacturing point source category..  This comparison, as noted in Table
  VII-4,  shows that the battery manufacturing lead raw waste concentrations
  encompass the range of OCPSF raw waste concentrations.  Since hydroxide
  precipitation achieves lead effluent concentrations at battery manufacturing
  facilities that are as good as or better than those demonstrated by metal
  finishing plants,  EPA.believes that  transfer of metal finishing lead data is
  appropriate.

      In addition,  the  metal finishing wastewater  matrices  contain  organic
  compounds  that  are used as  cleaning  solvents  and  plating bath  additives.   Some
 of these compounds serve as complexing agents,  and  their presence  is  reflected
 in the metal  finishing industry data  base.  This  data  base contains hydroxide
 precipitation performance results from plants with waste streams from certain
 operations (electroless plating, immersion plating, or printed circuit board
 manufacturing) containing complexing agents.  This is  important because the
 data base reflects both treatment of waste streams containing complexing
 agents and segregation of these waste streams prior to treatment.

      The transfer of technology and limitations from the metal finishing
 industry is further supported by the theory of precipitation.  Given suffi-
 cient retention time and the proper pH (which is frequently achieved by the
 addition of a lime hydroxide),  and barring the binding up of meta.ls in unusual
 organic  complexes (see discussion below),  a metal exceeding its solubility
 level in water can be removed to a particular concentration (i.e.,  the
 effluent can  be  treated to  a level approaching solubility  for each  constituent
 metal).  This  is a physical/chemical  phenomenon that  is relatively  independent
 of  the type of wastewater,  barring the presence of complexing agents.

      Some product/processes  do  have wastewaters  that  contain  organic  compounds
 that  bind up the  metals in stable  complexes  that are not amenable to  optimal
settling through  the use of  lime.  EPA  asked for comments in  the December  1986
Notice on the use of sulfide precipitation in  these situations.  Industry
commenters argued that  the effectiveness of this technology has not been
demonstrated for highly stable, metallo-organic chemicals.  EPA agrees.
                                    VII-26

-------
Strongly complexed priority pollutant metals are used or created, for
instance, in the manufacture of metal complexed dyestuffs (metallized dyes) or
metallized organic pigments.  The most common priority pollutant metals found
in these products are trivalent chromium and copper.  The degree of complexing
of these metals may vary among different product/processes.  Consequently,
each plant may need to use a different set of unique technologies to remove
these metals.  Thus, metals limits are not set by this regulation and must be
established by permit writers on a case-by-case basis for certain product/
processes containing complexed metals.  These product/processes  are listed in
Appendix B to the regulation and in Table X-5.

     The list in Table X-5 has been compiled based  upon  the analysis
summarized in Section V of  this document.  EPA has  concluded  that all other
metal-bearing process wastewaters  (whether listed in Table"X^5 or established
as metal-bearing by a permit writer)  can be  treated using hydroxide
precipitation to  the levels set forth in the regulation.

     As noted previously,  since certain manufacturers of rayon and acrylic
fibers  have  significantly  higher  raw  waste  zinc  concentrations  than  any other
OCPSF  process wastewaters,  the  lime precipitation performance data received
from the subject  facilities are only  applicable  to  certain types of  processes.
Table  VII-5  presents a  summary  of zinc raw  waste concentration  data  and lime
precipitation performance  data  from three  rayon  facilities,  as  well.as  one
acrylic fibers  plant  that  uses  a  zinc chloride/solvent  process.   Acrylic
 fibers facilities using the zinc  chloride/solvent  process have  been  combined
with rayon facilities  for  the purpose of  establishing BAT zinc  limitations
 because ,of their high  raw  waste zinc concentrations.   By comparing the raw
 waste concentrations  and resulting effluent concentrations for  zinc in Tables
 VII-4 and VII-5,  the fairly distinct differences in the two data sets are
 obvious.

     4.  Chemical Reduction (Chromium Reduction)
     Reduction is a chemical reaction process in which one or more electrons
 are transferred to the chemical being reduced from the chemical initiating  the
 transfer (the reducing agent).  The major application of chemical reduction
                                     VII-27

-------
                                   TABLE VII-5.
                          RAW WASTE AND TREATED EFFLUENT
                          ZINC CONCENTRATIONS FROM RAYON
                         AND ACRYLIC FIBERS MANUFACTURING
Plant No.  Plant Type
  Average
Influent Zinc     No. of
Concentration  .of Influent
   (mg/1)      Observations
  Average
Effluent Zinc
Concentration
   (mg/1)
   No. of
  Effluent
Observations
  63       Rayon           143.471

 387       Rayon           135.257

 1012      Acrylic Fibers  287.686

 1774      Rayon            15.570
                   365

                   354

                   363

                   346
    3.847

    2.198

    2.291

    2.409
    253

    258

    358

    346
                                    VII-28

-------
involves the treatment of chromium wastes.  To illustrate the reduction
process, the conversion of hexavalent chromium to trivalent chromium (chromium
reduction) is discussed below.

    Chromium Reduction.  A common chemical used in industrial plants for the
reduction of chromium is sulfur dioxide.  Chemical reduction equipment usually
consists of one reaction tank where gaseous sulfur dioxide is mixed with the
wastewater.  The reduction occurs when sulfurous acid, produced through the
reaction of sulfur dioxide and water, reacts with chromic acid as follows:

           (1)  3S02 + 3H20 = 3H2S03
           (2)  3H2S03 + 2H2Cr04 = Cr2(S04)3 + 5H20

     According to  the Section 308 Questionnaire data  base, 11 OCPSF plants use
chromium reduction as an in-plant treatment technology.

     5.  Gas Stripping  (Air and Steam)
     Stripping,  in general, refers  to the removal of^relatively volatile  com-
ponents from a wastewater  by  the  passage of air, steam,  or other  gas  through
the  liquid.  The stripped  volatiles are  usually  processed  further by  recovery
or incineration.

     Stripping  processes  differ  according to  the stripping medium chosen  for
 the  treatment  system.   Air and  steam are the  most  common media,  with  inert
gases  also used.  Air and steam stripping are described below.

     Air  Stripping.   Air stripping is essentially a gas transfer process  in
which  a liquid containing dissolved gases is  brought into contact with air and
 an exchange of gases takes place between the  air and the solution.  In
 general*  the application of air stripping depends on the environmental impact
 of the resulting air emissions.   If sufficiently low concentrations are
 involved, the gaseous compound can be emitted directly to the air.  Otherwise,
 air pollution control devices may be necessary.
                                    'VII-29

-------
       The exchange of gases takes place in the stripping tower.  The tower
  consists of a vertical shell filled with packing material to increase the
  surfade area for gas-liquid contact, and fans to draw air through the tower.
  The towers are of two basic types-countercurrent towers and crossflow towers.
  In countercurrent towers, the entire airflow enters at the bottom of the
  tower,  while the water enters the top of the tower and falls to the bottom.
  In crossflow towers,  the air is pulled through the sides of the tower along
  its entire height,  while water flow proceeds down the tower.

      The  removal of pollutants by air stripping  is adversely affected  by low
  temperatures,  because  the solubility of gases in water increases  as
  temperature  decreases.

      Steam stripping.  Steam stripping is essentially  a  fractional
 distillation of volatile  components  from a wastewater  stream.  The volatile
 component may be a gas or an organic- compound  that is  soluble in  the waste-
 water stream.  More recently, this unit operation has  been applied to the
 removal of water immiscible compounds (chlorinated hydrocarbons), which must
 be reduced to trace levels because of their toxicity.

      Steam stripping is usually conducted as a continuous operation in a
 packed  tower or conventional fractionating distillation column (bubble cap or
 sieve tray) with more  than one stage of vapor/liquid contact.  The preheated
 wastewater from the  last  exchanger enters  near the top of the distillation
 column and then flows  by  gravity countercurrent to superheated steam and
 organic  vapors  (or gas) rising  up from the  bottom of  the column.   As  the
 wastewater passes  down  through  the column,  it  contacts  the  vapors  rising  from
 the bottom of the  column.  This  contact progressively reduces the  concen-
 trations of volatile organic compounds or gases in  the  wastewater  as  it
 approaches  the bottom of  the column.   At the bottom of  the  column, the waste-
vater is heated by the incoming  steam, which also reduces the concentrations
of volatile components to  their  final  level.  Much of the heat in  the
wastewater discharged from the bottom  of the column can then  be recovered by
preheating the feed to the column.
                                   VII-30

-------
     Reflux (condensing a portion of the vapors from the top of the column and
returning it to the column) may be practiced if it is desired to alter the
composition of the vapor stream that is derived from the stripping column
(e.g., increase the concentration of the stripped material for recovery    ,
purposes).  There also may be advantages to introducing the feed to a tray
below the top tray when reflux is used.  Introducing the feed at a lower tray
(while still using the same number of trays in the stripper) will have the
effect of either reducing steam requirements, as a result of the need for less
reflux, or yielding a vapor stream richer in the volatile components.  The
combination of using reflux and introducing the feed at a lower tray will
increase  the concentration of  the volatile organic components  in the overhead
(vapor phase) beyond that obtainable by  reflux alone and increase  the poten-
tial  for  recovery.

      Stripping of  the  organic  (volatiles) constituents  of  the  wastewater
stream occurs because  the  organic volatiles  tend  to  vaporize  into  the steam
until its concentration in the vapor and liquid phases  (within the stripper)
are in equilibrium.  The height of  the column  and the amount  of packing
material and/or  the  number of  metal trays along with steam pressure in  the
column generally determine the amounts of volatiles  that  can be removed  and
 the effluent  pollutant levels  that  can be attained by the stripper.  After the
volatile pollutant is  extracted from the wastewater into  the superheated
 steam,  the steam is  condensed to form two layers  of generally immiscible
 liquids—the aqueous and volatile layers.  The aqueous layer is generally
 recycled back to the steam stripper influent feed stream because it may still
 contain low levels of the volatile.  The volatile layer may be recycled to the
 process, incinerated on-site,  or contract hauled (for incineration,
 reclaiming, or further treatment off-site)  depending on the specific plant's
 requirements.

      Steam stripping  is an energy-intensive technology in which heat energy
 (boiler  capacity) is  required  to both preheat the wastewater  and  to generate
 the  superheated steam needed  to extract  the volatiles  from wastewater.  In
 addition,  some waste  streams  may require pretreatment  such as solids removal
 (e.g.,  filtration)  prior  to stripping because accumulation of solids within
 the  column will prevent efficient  contact between  the  steam and wastewater
                                      VII-31

-------
   phases.   Periodic cleaning of the column and its packing materials or trays is
   a  necessary part  of routine steam stripper maintenance to assure  that low
   effluent  levels are consistently achieved.

       Steam  strippers are designed to remove  individual volatile pollutants
   based on  a  ratio  (Henry's  Lav Constant)  of  their aqueous  solubility (tendency
   to stay in  solution) to vapor pressure (tendency to volatilize).  The column
  height and  diameter, amount of packing or number of trays, the operating steam
  pressure,  and temperature of the heated  feed (vastevater) are varied according
  to the strippability (using Henry's Lav Constant) of the volatile pollutants
  to be stripped.   Volatiles vith lover Henry's Lav Constants require greater
  column.height,  more trays or packing material,  greater steam pressure and
  temperature, more  frequent cleaning,  and  generally more careful operation than
  do  volatiles vith  higher strippability  (7-4).  Although the degree to  vhich a
  compound is  stripped can depend  to some extent  upon the vastevater matrix,  the
  basis  for  the design and operation of steam strippers  is such  that matrix
  differences  are taken into  account for the  volatile compounds  the  Agency  has
  evaluated.

      Since Henry's Lav Constants  vere such  important design parameters, the
 Agency initially proposed that, for consolidation purposes, toxic  pollutants
 could be grouped into three general ranges of Henry's Lav Constants termed
 high, medium, and low; these groups are presented in Table VII-6.  The pollu-
 tants in the lov Henry's Lav Constant group vere determined to require
 treatment  other than steam stripping (i.e.,  carbon adsorption or in-plant
 biological  treatment).   The remaining groups vere then  used in the development
 of^team stripping  cost  curves and in the  transfer of steam stripping perfor-
 mance data  to toxic pollutants vithout performance data, depending on vhether
 they fell vithin the high or medium grouping.  For the  purposes of  this docu-
 ment,  these groupings are designated "strippability" groups.

     According to the Section  308  Questionnaire  data base,  eight OCPSF  plants
 report using  air stripping and 82  report using steam stripping  as an in-plant
 treatment technology.  Steam stripping performance data  collected during the
EPA 12-Plant  Study or submitted by  industry for  selected volatile organic
compounds are presented in Table VII-7.  The data indicate  that high removal
                                    VII-32

-------
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  efficiencies  (e.g., most  plant-pollutant  combinations are  over  992)  can  be
  achieved  for  these volatile organic compounds.  It should  also  be recognized
  .that most treatment systems consist of several unit processes and that addi-
  tional removal of organic compounds will  likely occur, especially in systems
  with biological treatment units.

       Nitrobenzene performance data .from two plants in the OCPSF industry that
  employed steam stripping followed by activated carbon are presented in Table
  VII-8.   The data indicate that a high removal efficiency (e.g.,  approximately
  99*) can be obtained for this semi-volatile organic compound by using these
  two processes.  However, the data shown in Table VII-9 also indicate that com-
  petitive adsorption may be occurring among nitrobenzene,  the dinitrotoluenes
  (2,4- and 2,6-dinitrotoluene),  and the nitrophenols (2-  and 4-nitrophenol and
  2,4-dinitrophenol)  which seem  to favor adsorption  of nitrophenols  over  nitro-
  benzene  because of  their more attractive  chemical  affinity  to the  carbon.  The
  nitrotoluene data are not  available  because  matrix interferences prevented
  quantitation with the analytical methods  that had  been used.

     6.  Solvent Extraction
     Solvent extraction, also referred  to as  liquid-liquid extraction, involves
  the separation of the constituents of a liquid solution by contact with
 another immiscible liquid for which the impurities have a high affinity.  The
 separation can be based either on physical differences that affect differen-
 tial solubility between solvents or on a definite chemical reaction.

     The  end result  of solvent extraction is to separate the original  solution
 into two  streams-a  treated stream and  a recovered  solute stream  (which  may
 contain small amounts  of water  and solvent).   Solvent extraction  may  thus  be
.considered a recovery  process since the solute chemicals  are generally
 recovered  for reuse, resale,  or  further treatment and disposal.   A  process for
 extracting a solute  from solution will  typically  include  three basic  steps:
 1)  the actual extraction,  2) solvent  recovery from  the  treated stream, and
 3)  solute  removal from the  extracting solvent.  The process  may be operated
 continuously.
                                    VII-36

-------
VII-37

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-------
    Solvent extraction is presently applied in two main areas:  1) the
recovery of phenol frpm aqueous wastes, and 2) the recovery of halogenated
hydrocarbon solvents from organic solutions containing other water-soluble
components.                        ,

    Although effective in recovering solvents and other organic compounds for
recycle and reuse, solvent extraction  is not a widespread wastewater treatment
technology because effluent concentration levels that are acceptable for
recycle and reuse are generally too high for wastewater discharge.  According
to the Section 308 Questionnaire data  base, 29 OCPSF plants use solvent
extraction as an in-plant control or a raw material reclamation technology.
Performance data are summarized for petroleum refining and organic chemical
manufacturing plants in Volume III of  the Treatability Manual.  The data  show
a wide variation in removal efficiency, varying  from 12 to 99 percent. Most
volatile organics are removed with greater  than  90 percent efficiency, but
base/neutrals show removal efficiencies generally below 75 percent.

     7.  Ion Exchange
     Ion exchange  involves  the  process  of  removing anions  and  cations  from
wastewater.  Wastewater  is  brought  in  contact with a  resin  that exchanges the
ions in  the wastewater with a  set  of  substitute  ions.  The  process  has four
operations carried  out  in  a complete  cycles   service,  backwash,  regeneration,
and  rinse.  The wastewater is  passed  through the resin until  the  available ex-
change sites  are  filled  and the contaminant appears  in the  effluent (break-
 through point).   When this point is reached,  the service  cycle is stopped and
 the  resin bed is. backwashed with water in a reverse  direction to that of the
 service cycle.   Next,  the exchanger is regenerated  (converted to original
 form) by contacting the resin with a sufficiently concentrated solution of the
 substitute ion.  Finally,  the bed is rinsed to remove excess regeneration
 solution prior to the next service step.

     Ion exchange is used in several ways.  In industrial wastewaters, ion
 exchange may be used to remove ammonia, arsenic, chromium,  and nickel.  It is
 commonly used to recover rinse water  and process chemicals,  or to reduce salt
 concentrations in incoming water sources.
                                     VIIv-39

-------
      According to the Section 308 Questionnaire data base,' only seven OCPSF
  plants use ion exchange as an in-plant treatment technology.   Based on the
  limited number of OCPSF plants employing ion exchange and the absence of OCPSF
  ion exchange performance data, ion exchange was not considered as a BAT or
  PSES -candidate technology.   Performance data for ion exchange systems in the
  metal  finishing industry are presented in Table VII-10.   Although removal
  efficiencies are greater for the electroplating and printing  circuit  board
  plants  (e.g.,  91 to  greater  than 99%)  than for plant  #11065 (e.g.,  zero
  removal  to greater than 99%),  the influent pollutant  concentrations are also
  much greater.

      8.  Carbon Adsorption
      Activated carbon adsorption  is a proven technology primarily used  for the
 removal of organic chemical  contaminants  from  individual process waste
 streams.  Carbon has a very  large surface area per unit mass and removes
 pollutants through adsorption and physical separation mechanisms.  In addition
 to removal of many organic chemicals,  activated carbon achieves limited
 removal of other pollutants such as BOD5 and metals.  Carbon used in a fixed
 column,  as opposed to being directly applied in granular or powdered form to a
 waste stream, may also act as a filtration unit.

      Activated carbon can be used as an in-plant treatment technology in order
 to protect downstream treatment units  such as biological systems from high
 concentrations of toxic pollutants that could adversely affect system
 performance.   In-plant activated carbon treatment also enables removal of
 pollutants from low volume waste streams before the  waste  streams mix  with and
 contaminate much larger volumes of wastewater,  which would  be  more difficult
 and  costly to treat.

     According to  the Section 308  Questionnaire data base,  18  OCPSF plants  are
 known to use  activated carbon as an  in-plant  treatment  technology.  Although
 performance data  for  a specific  individual in-plant  carbon  adsorption unit
 prior to biological treatment were not available,  the Agency collected
performance data from a carbon adsorption  unit  following steam stripping at an
OCPSF facility for which  the  carbon adsorption unit  treated a separate process
                                    VII-40

-------
                                        TABLE, yn-io.
                           TYPICAL ICN EXCHANGE PERFORMANCE DATA.
Electroplating Plant ^,


Parameter
Zinc (Zn)
Cadmium (Cd)+3
Chromium (Cr+ )
Chromium (Cr )
Copper (Cu)
Iron (Fe)
Nickel (Ni)
Silver (Ag)
Tin (Sn)
Cyanide (CM)
Manganese (Mn)
Aluminum (A3.)
Sulfate (S04)
Lead (Pb)
Gold (Au) .
Prior To
Purifi-
cation
14.8
5.7
3.1
7.1
4.5
7.4
6.2
1.5
.1.7
9.8
4.4
5.6
After
Purifi-
cation
0.40
0.00
0.01
0.01
0.09
0.01 ,
0.00
0.00
0.00
0.04
0.00
0.20 ..
Removal
Efficiency
.<*>'.
• 97
100
100
100
98
100
100
•100
100,
100
100
96
Printed Circuit Board Plant
Prior To
*' Purifi-
, cation
_
-
• -
43.0
1.60
9.10
. 1.10
3.40
—
210.00
" 1.70
2.30
After
Purifi-
cation
-
—
—
o.io
0.01
o!io
0.09 :
*•"
2.00
0.01
. 0.10
Removal
Efficiency
(%)



100
99 .
*1 /Vv
100
91
97

99
99
% .
Plant #11065, which was visited and sampled, employs an ion exchange unit to remove metals
from rinsewater.   The results of  the sampling are displayed below.
                                POLLUTANT CONCHM33ATION (mg/1)
                                "~       Plant #11065   ~^~~


Parameter
TSS
Cu
Ni
Cr, Total
Cd
Pb
Day.l

Input To
Ion Exchange
6.0
52.080
0.095
0.043
0.005
0.010
Day 2

Effluent From
Ion Exchange
.4.0
0.118
0.003
0.051.
0.005
0.011
Removal
Efficiency
(%)
33
'100 "
97
0
0
0

Input To
Ion Exchange
1.0
189.3
0.017
0.026
0.005
0.010

Effluent From
Ion Exchange
1.0 -
0.20
0.003
0.006
0.005
0.010

Removal
Efficiency
(%)
0
100
82
77
0
0
 Sources  Development Document for Effluent Limitations Guidelines New Source Performance
         Standards  for the Metal Finishing Point Source Category, June 1983.
 1Concentrations in mg/1.
                                             vn-4i

-------
  waste stream prior to discharge.   This unit was sampled during the EPA
  12-Plant Study.   This plant manufactures only interrelated products whose
  similar waste streams are combined and sent to a physical/chemical treatment
  system consisting of steam stripping followed by activated carbon.   The  toxic
  pollutants  associated with these  waste streams are  removed by  either steam
  stripping or activated carbon,  or a combination of  both.

      The Agency has  decided to  use this  available performance  data from  the
  end-of-pipe  carbon adsorption unit as  the basis  for establishing BAT limits
  for four pollutants  (2-nitrophenol,  4-nitrophenol, 2,4-dinitrophenol, and
 4,6-dinitro-o-cresol),  and  the  combination  of  steam stripping  and  activated
 carbon adsorption for  nitrobenzene.  Table  VII-11 presents  the performance
 data for  the carbon adsorption  unit  at this plant.  These data show  very good
 removals  (greater than  99%) for the  carbon  adsorption unit  for 4,6-dinitro-
 o-cresol, 2-nitrophenol, 4-nitrophenol, and 2,4-dinitrophenol.   However,  the
 concentration data indicate that for 2,4-dinitrophenol and nitrobenzene the
 carbon adsorption unit  is experiencing competitive adsorption phenomena.   As
 shown in Table VII-9, this condition exists when a matrix contains adsorbable
 compounds in solution that are being selectively adsorbed and desorbed.

      9.   Distillation
      Distillation  is  a unit process usually employed to separate volatile
 components of a waste stream or  to purify liquid organic product streams. ' The
 process involves boiling a liquid  solution and collecting and condensing  the
 vapor,  thus  separating the components of the solution.   The vapor  is collected
 in a  vessel  where  it  is condensed,  resulting in a separation of materials  in
 the feed  stream into  two streams of different  composition.

     The  distillation process is used to  recover  solvents  and chemicals from
 industrial wastes  that  otherwise would  be destroyed by waste treatment.
Although  effective in  recovering solvents and  other organic  compounds for
recycle and reuse, distillation  is  not  a widespread wastewater  treatment tech-
nology because effluent  levels that  are acceptable for recycle  and  reuse are
generally  too high for wastewater discharge.  According  to  the  Section 308
Questionnaire, 72 OCPSF  plants use  distillation as an in-plant  control and/or
secondary product or raw material reclamation  technology.
                                    VII-42

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       No performance data are available for distillation as  a wastewater
  control technology.

       10.   Filtration
       Filtration  is  a proven  technology for achieving  the removal of suspended
  solids  from wastewaters.  The removal  is accomplished by the  passage of water
  through a  physically restrictive medium (e.g., sand, coal,  garnet, or diato-
  maceous earth) with  resulting entrapment of suspended paniculate matter by a
  complex process  involving one or more  removal mechanisms, such as straining,
  sedimentation, interception,  impaction, and adsorption.  In-plant filtration
  can serve  to remove  suspended  solids and subsequently improve the performance
 of downstream treatment units  that may  be  adversely affected by larger parti-
 cles in the waste stream.  In  addition, filtration units can serve to collect
 solids with reclamation value  from specific waste streams.

      According to the Section 308 Questionnaire data base, 54 OCPSF plants use
 filtration as an in-plant treatment technology.   Performance data for filtra-
 tion as an in-plant technology were not available in the OCPSF industry;  how-
 ever,  performance data for hydroxide precipitation plus in-plant  filtration
 from the metal finishing point source category for TSS and selected metals are
 presented in  Table VII-12,  along with the  hydroxide precipitation performance
 data from metal finishing for comparison purposes.

      11.  Reverse  Osmosis
     Reverse  osmosis is  a pressure-driven membrane  process  that separates  a
 wastewater  stream into a purified  "permeate" stream and  a residual  "concen-
 trate" stream  by  selective permeation of water through a semipermeable
 membrane.   This occurs by developing  a  pressure gradient large enough to
 overcome  the osmotic  pressure of the  ions within  the waste stream.  This
 process generates a  permeate  of relatively  pure water, which can be recycled
 or disposed, and  a concentrate stream containing most of the pollutants
 originally  present, which can be treated further, reprocessed, or recycled.
Reverse osmosis systems generally require extensive pretreatment (pH
adjustment, filtration, chemical precipitation, activated carbon adsorption)
of the wastewater  stream  to prevent rapid fouling or deterioration of the
membrane surface.
                                    VII-44

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                                TABLE VII-12.
              PERFORMANCE DATA FROM HYDROXIDE PRECIPITATION AND
                 HYDROXIDE PRECIPITATION PLUS FILTRATION FOR
                          METAL FINISHING FACILITIES
     Parameter
Hydroxide Precipitation
          only
         (mg/1)
                                                      Hydroxide Precipitation
                                                          Plus Filtration
                                                               (mg/1)
Total Suspended Solids
Chromium, Total
Copper
Lead
Nickel
Zinc
         16.8
          0.572
          0.815
          0.051
          0.942
          0.549
12.8
 0.319
 0.367
 0.031
 0.459
 0.247
Source:  Development Document for Effluent Limitations Guidelines New Source
         Performance Standards  ffcr  the Metal Finishing Point Source Category,
         June  1983.
                                     VII-45

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      Reverse  osmosis  has  been  used  in  industry  for  the  recovery  and  recycle of
 chemicals.  Metals and  other reusable  materials  can easily  be separated  from a
 waste stream.  Although reverse osmosis  is slightly more effective than  chemi-
 cal precipitation for metals removal,  it is very expensive  and appropriate
 only for low  volume waste streams high in'dissolved solids.

      12. Ultrafiltration
      Ultrafiltration  is a physical unit process, similar to reverse osmosis,
 that is used  to segregate dissolved or suspended solids from a liquid stream
 through the use of semipermeable polymeric membranes.   The membrane of an
 ultrafilter forms a molecular screen that separates molecular particles based
 on their differences in size,  shape, and chemical structure.  A hydrostatic
 pressure is applied to the upstream side of a membrane unit, which acts as a
 filter,  passing small particles such as salts while blocking larger emulsified
 and suspended  matter.   Ultrafiltration differs from reverse osmosis in the
 size of contaminants  passed.   Ultrafiltration generally retains .participates
 and materials  with  a  molecular  weight greater than  500,  while reverse osmosis
 membranes generally pass only materials with  a molecular weight  below 100.

     Ultrafiltration  has been used  in oil/water  separation  and for the removal
 of  macromolecules such as  proteins,  enzymes,  starches, and  other  organic
 polymers.   Ultrafiltration is presently not a  widely used process but  has
 potential application  to OCPSF  wastewater  treatment.   Summary performance data
 are available  from EPA's Volume III  Treatability  Manual  for  the aluminum
 forming, automobile and  other laundries,  rubber manufacturing, and timber
 products processing industries  and are  presented  in  Table VII-13.  The data
 show a wide variation  in removal efficiencies  and effluent levels.  An experi-
 mental combined Ultrafiltration and  carbon adsorption system does  show
 promise.  This system  consists of powdered activated carbon suspended in
wastewater.   The mixture is then pumped through 20 ultrafilter modules
arranged in two parallel trains.  Heavy metal removal data for this system are
presented in Table VII-13.
                                   VII-46

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                                TABLE VII-13.
                 ULTRAFILTRATION PERFORMANCE DATA FOR METALS
                  IN LAUNDRY WASTEVATER-OPA LOCKA, FLORIDA
Parameter (mg/1)
Zinc
Copper
Lead
Chromium (total)
Cadmium
Raw
0.52
0.51
0.4
0.1
0.03
Supernatant
<0.20
0.14
0.1
<0.01
<0.02
Permeate
<0.20
0.06
0.01
' <0.01
<0.02
Source:  Van Gils, G. and M. Pirbazari.  August 1986. Development of *
         Combined Ultrafiltration and Carbon Adsorption System for Industrial
         Wastewater Reuse and Priority Pollutant Removal.  Environmental
         Progress 5(3):167-170.
                                     VII-47

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       13.  Resin Adsorption
       Resin adsorption  is  a process  that  may  be  used  to  extract  and,  in  some
 cases,  recover  dissolved  organic  solutes from aqueous wastes.   Waste treatment
 by resin adsorption  involves  two  basic steps:   1)  contacting  the  liquid waste
 stream  with  the resin, allowing the  resin to adsorb  the solutes from the
 solution, and 2) subsequently regenerating the  resin by removing  the adsorbed
 chemicals, often accomplished by  simply  washing with the proper solvent.
 Resin adsorption is  similar in nature to activated carbon adsorption; the most
 significant difference being  that resins are chemically regenerated  while
 carbon  is usually thermally regenerated,  eliminating the possibility of mater-
 ial recovery.  Resins generally have a lower adsorptive capacity  than carbon,
 and are not likely to be competitive with  carbon for the treatment of high
 volume waste streams containing moderate or high concentrations of mixed
 wastes with no recovery value.

      Current  applications of resin adsorption include removal of copper and
 chromium both as salts and organic chelates,  removal of color associated with
 metal complexes  and organics,  and  the recovery of phenol from a waste stream.
 According to  the Section 308 Questionnaire data base, no plants reported using
 resin adsorption.   No data, are available  from other industries.

      14. In-Plant  Biological  Treatment
      For certain segregated waste  streams and pollutants,  in-plant biological
 treatment is  an  effective  and  less costly alternative to carbon  adsorption  for
 control  of toxic organic pollutants,  especially  those which  are  effectively
 absorbed into  the sludge and are relatively biodegradable.   In-plant
 biological treatment  may require longer detention  times  and  certain species of
 acclimated biomass  to be effective as compared to  end-of-pipe  biological
 treatment that is predominantly designated to treat BOD5.  EPA has determined
 that in-plant biological treatment with an acclimated biomass  is as effective
as activated carbon adsorption for removing priority  pollutants  such  as
polynuclear aromatics (PNAs) like naphthalene, anthracene, and pyrene; phenol;
and 2,4-dimethylphenol as shown in the sampling  data collected at  plant  #1293
of the 12-Plant Sampling Study, which are presented later in this  section.
Plant #1293 is a coal tar facility with flows of less than 50,000 gallons per
                                    VII-48

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day (gpd), which generates the highest raw waste concentrations of these toxic
pollutants.  Its treatment system consists of equalization, extended above-
ground aerated lagoon, and secondary clarification prior to discharge to a
POTW.  This treatment system reduces the concentrations of all the above-
mentioned toxic pollutants to their respective analytical minimum levels.

     After reviewing  the performance data from this plant, the Agency deter-
mined that other relatively biodegradable toxic pollutants could also be
controlled by this type of dedicated biological treatment system (i.e., with a
minimum amount of dilution with other process wastewaters).  This determina-
tion was made after review of performance data from selected end-of-pipe
biological treatment  systems (plant 1948 and #2536) receiving wastewaters
whose main toxic pollutant constituents included the  following:  acrylo-
nitrile, bis (2-ethylhexyl) phthalate, di-N-butyl phthalate, diethyl
phthalate, and dimethyl phthalate.

     The Agency has determined  that these data are appropriate  for use  in
characterizing  the performance  of  in-plant  biological treatment  based upon  the
waste stream characteristics of the influent  to  the  treatment systems.   The
selected  plants generate  major  sources of  these  pollutants.

     According  to  the Section  308  Questionnaire  data base,  33 OCPSF  plants
report  using some  form of biological, treatment  prior to discharge  to an end-
of-pipe treatment  system  (direct dischargers)  or POTW (indirect dischargers).
Table VII-14 presents the performance data for the  three plants chosen  by  the
Agency  to represent  the performance of in-plant  biological treatment.

D.   END-OF-PIPE  TREATMENT TECHNOLOGIES
      1.   Introduction
      End-of-pipe  treatment systems in the OCPSF industry often consist  of
 primary,  secondary,  and polishing or tertiary unit  operations.   In primary
 treatment, physical operations are used to remove floating and settleable
 solids  found in wastewater.  In secondary treatment, biological and chemical
 processes are used to remove most of the organic matter.  In polishing or
 tertiary treatment,  additional combinations of unit operations and processes
                                     VII-49

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are used to remove other constituents that are not removed by primary or
secondary treatment.  Many technologies have proven effective in removing
specific pollutants from the wastewaters produced by OCPSF plants.  The selec-
tion of a specific end-of-pipe treatment scheme depends on the nature of the
pollutant to be removed and on engineering and cost considerations,:  Data on
the frequency of application of specific primary, secondary, and polishing or
tertiary end-of-pipe treatment technologies are presented in Tables VII-15,
VII-16, and VII-17, respectively.  Primary treatment technologies used by the
OCPSF plants to remove floating and settleable solids, to protect the biolog-
ical segment of the system from shock loadings, and to assure the efficiency
of biological treatment include neutralization (365 plants), equalization
(297), primary clarification (144), and nutrient addition (114).  Secondary
treatment technologies used by OCPSF plants to remove organic matter include
secondary clarification (174 plants), activated sludge (143), and aerated,
lagoons  (89).  Polishing or tertiary treatment technologies used  to remove
certain  constituents not sufficiently removed by  the primary and  secondary
systems  include polishing ponds  (64  plants), filtration  (41), and carbon
adsorption  (21).

      2.   Primary  Treatment Technologies
      Although  the  final BPT, BAT,  and PSES effluent  limitations  guidelines  are
not  based on these primary  treatment technologies, many  OCPSF  facilities  uti-
lize one or some  combination of  these  technologies  to  enhance  the performance
of subsequent  treatment  steps  (e.g.,  biological).  The Agency  encourages  the
use of  any  of  the primary  treatment  technologies  discussed  to  improve  the
 removal efficiency of  the  overall treatment system.                       <

          a.  Equalization
      Equalization involves the process  of dampening flow and pollutant
 concentration variation of wastewater before subsequent  downstream treatment.
 By reducing the variability of the raw waste loading,  equalization can:     ;
 significantly improve the performance of downstream treatment processes that
 are more efficient if operated at or near uniform hydraulic, organic,  and
 solids loading rates and that reduce effluent variability associated with slug
                                     VII-51

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raw waste loadings.  Equalization is accomplished in a holding tank manufac-
tured from steel or concrete, or in an unlined or lined pond.  The retention
time of the tank or pond should be sufficiently long to dilute the effects of
any highly concentrated continuous flow or batch discharges on treatment plant
performance.                                                                  -

     Equalization  is reliable from both equipment and process standpoints, and
is used to increase the reliability of the flow-sensitive treatment processes
that follow by reducing the variability of flow and pollutant concentrations.
Equalization is a  common treatment technology  to the OCPSF industry.  Accor-
ding to the Section 308 Questionnaire data base, 297 OCPSF plants use
equalization as a  primary  treatment  technology.

          b.  Neutralization
     Neutralization  involves  the process  of  adjusting  either an  acidic  or  a
basic  waste stream closer  to  a  neutral pH.   Neutralization may be accomplished
in either a collection tank,  rapid mix  tank, or  an  equalization  tank by mixing
acidic and alkaline  wastes,  or  by the addition of  chemicals. Alkaline  waste-
waters are typically neutralized by adding sulfuric or hydrochloric acid,  or
compressed carbon dioxide.  Acidic wastewaters may be neutralized with
limestone or  lime slurries,  soda ash, or caustic soda.  The  selection of
neutralizing  agents  depends  upon cost,  availability,  ease of use,  reaction
 by-products,  reaction rates,  and quantities of sludge formed.  The most
 commonly used chemicals are lime (to raise the PH) and sulfuric acid (to lower
 the pH).

      Neutralization of an excessively acidic or basic waste stream is
 necessary in a variety of situations, including 1) the precipitation-of
 dissolved heavy metals; 2) the prevention of metal corrosion and damage to
 other construction materials; 3) preliminary  treatment allowing effective
 operation of the  biological  treatment process; 4) the providing of neutral pH
 water for recycle uses; and  5)  the reduction  of detrimental effects in  the
 receiving water.
                                      VII-55

-------
       Neutralization is highly reliable with proper monitoring,  control,  and
  proper pretreatment to control interfering substances.   Neutralization is  a
  common treatment  technology to the OCPSF industry;  according to the Section
  308  Questionnaire data base,  365  OCPSF plants  neutralize their  wastewaters.

          c.   Screening
       Screening  is the  process  of  removing coarse and/or  gross solids  from
 wastewater before subsequent downstream treatment,  and is usually accomplished
 by passing wastewater  through  drum- or  disk-type screens.  Typically,  coarse
 screens are stainless  steel or nonferrous wire mesh with openings from 6 to
 20 mm.  Fine  screens have openings that are less than 6 mm.  Solids are raised
 above  the liquid  level by rotation of the screen and are backflushed  into
 receiving troughs  by high-pressure jets.

      Screening has proven to be a very reliable process when properly designed
 and maintained.   According to  the Section 308 Questionnaire data base,
 49 OCPSF plants use screening as a primary treatment technology.

          d.   Grit  Removal
      Grit removal  is achieved in specially designed chambers.  Grit  consists
 of sand, gravel, cinders, or other heavy solid  materials  that have subsiding
 velocities or specific  gravities substantially  greater than those of the
 organic putrescible solids in wastewater.   Grit chambers  are  used to protect
 moving mechanical  equipment  from abrasion; to reduce formation of heavy de-
 posits in pipelines,  channels,  and conduits;  and  to reduce  the frequency of
 digester cleaning  that  may be required  as  a result  of  excessive  accumulations
 of grit in such  units.

      Normally, grit chambers  are designed  to remove  all grit  particles with a
 0.21  mm diameter,  although many chambers have been designed to remove  grit
 particles with a 0.15 mm  diameter.  According to the Section  308  Questionnaire
 data  base, 41  OCPSF plants use  grit removal as a primary  treatment process.

         e.  Oil Separation  (Oil Skimming, API Separation)
     Oil separation techniques  are used  to remove oils and grease from waste-
water.  Oil may exist as  free or emulsified oil.  The separation of free oils
                                    VII-56

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and grease is accomplished by gravity, and normally involves retaining the
oily waste in a holding tank and allowing oils .and other materials less dense
than water to float to the surface.  This oily top layer is skimmed off the
wastewater surface by.a mechanism such as a rotating drum-type or a belt-type
skimmer.  Emulsified oil, after it has gone through a "breaking" step
involving chemical or thermal processes to generate free oil, can also be
separated using a skimming system.

     Oil separation is used  throughout the OCPSF  industry to recover oil for
use as  a fuel supplement  or  for recycle,  or to reduce the concentration of
oils, which  reduces any deleterious  effects on subsequent treatment or
receiving waters.  In the OCPSF industry, oil separation also removes many
toxic organic chemicals  (typically :large  non-polar molecules) that  tend  to
concentrate  in  oils and grease.   However, since  the removal of  these  toxic
pollutants  is incidental  to  oil separation/removal,  this  treatment  process  was
not used  as  the technology  basis  for this final  regulation.  Still,  the  Agency
encourages  its  use to improve the performance of the overall treatment  system
 for  removing unwanted floating oils  and  greases.

      According  to the Section 308 Questionnaire data base,  86 OCPSF plants use
 oil  separation; 58 use API separation (a common gravity oil separation based
 upon design standards published by the American Petroleum Institute); and
 111 practice oil skimming as a preliminary treatment technology.  No OCPSF
 performance data are available;  however, data from the iron and steel manufac-
 turing and electrical and electronic components industries are presented in
 Volume III of the EPA Treatability Manual.  The data show  generally high
 removal efficiencies for metals and  toxic organics.

          f.  Flotation
      Flotation is a  process  by which suspended solids, free and emulsified
 oils,  and grease are separated from wastewater by releasing gas bubbles into
 the wastewater.  The gas bubbles  attach  to the solids, increasing  their
 buoyancy and causing them  to float.  A surface  layer of sludge  forms, and  is
 usually  continuously skimmed for  disposal.   Flotation  may  be performed  in
 several  ways,  including  foam (froth), dispersed  air, dissolved  air,  vacuum
                                      VII-57

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  flotation,  and flotation with chemical addition.   The principal difference
  between these variations is  the method of gas  bubbles generation.

      Flotation is  used  primarily in  the treatment  of  wastewater streams  that
  carry heavy loads  of  finely  divided  suspended  solids  or  oil.   Solids having a
  specific gravity only slightly  greater than water, which would  require abnor-
  mally long  sedimentation times,  may  be removed  in  much less  time by flotation.
  Thus, it is  often  an  integral part of  standard  clarification.

      According  to  the Section 308 Questionnaire data  base, 31 OCPSF plants
 used dissolved air flotation as  a primary  treatment technology.  No OCPSF
 performance data are available.  The Volume III EPA Treatability Manual
 presents performance data from  textile mills, pulp and paper mills, auto and
 other laundries, and petroleum refineries.  The data show a median removal
 efficiency of 61 percent for BOD5 and a median effluent concentration of
 250 rag/1.  Toxic removal efficiencies show large variations.

          8>   Clarification (settling, sedimentation)
      Qlarification  is  a  physical process used to remove suspended solids from
 wastewater  by gravity  settling.   Settling tanks, clarifiers,  and sedimentation
 ponds or basins are designed  to let wastewater  flow slowly  and quiescently,
 providing an adequate  retention time  to permit  most solids  more dense  than
 water to settle to  the bottom.   The settling  solids form  a  sludge at  the
 bottom of the tank  or  basin.   This sludge is  usually pumped out  continuously
 or  intermittently from settling  tanks or clarifiers, or scraped  out period-
 ically from  sedimentation ponds  or basins.

      Settling is used  alone or as part  of a more complex  treatment process.
 It  is usually the first  process  applied to  wastewaters containing high
 concentrations of settleable  suspended  solids.   Settling  is also often used in
 conjunction with other treatment  processes  such  as  removal of biomass after
 biological treatment or  removal  of metal  precipitates  after chemical
 precipitation.  Clarifiers, in conjunction with  chemical addition, are used to
 remove materials such as dissolved solids that are not removed by simple
sedimentation (chemically assisted clarifiers are discussed later in this
section under polishing and tertiary treatment).
                                    VII-58

-------
     Clarification (or sedimentation or settling) is a common primary
treatment technology in the OCPSF industry; according to the Section 308 -
Questionnaire data base, 144 OCPSF plants use primary clarification.

         h.  Coagulation and Flocculation
     Chemical coagulation and flocculation are  terms often used  interchange-
ably to describe the physiochemical process of  suspended particle aggregation
resulting from chemical additions to wastewater.  Technically, coagulation
involves the reduction of electrostatic surface charges and  the  formation of
complex hydrous oxides.  Coagulation is essentially instantaneous in  that the
only time required is that necessary for dispersing the chemicals in  solution.
Flocculation is the  time-dependent  physical process of  the aggregation of
wastewater  solids into  particles  large enough to be separated  by sedimenta-
tion.       '               '      .            ......         ,  .-.,  •...  .. . '< •••• ,.

     The purpose of  coagulation is  to  overcome electrostatic repulsive surface
forces  and  cause small  particles  to agglomerate into  larger  particles, so that
gravitational  and  inertia!  forces will predominate and  affect  the  settling  of
the, particles.  The  process  can be  grouped into two sequential mechanisms:

      •   Chemically  induced  destabilization of the repulsive surface-related
         forces,  thus allowing particles to stick together when contact, .between
         particles  is made.
      •   Chemical bridging and physical enmeshment between the non-repelling
         particles,  thus allowing for  the formation of large particles.
                                                      '.       "  ~ .    -.'''-
      There are three different types  of coagulants:  inorganic electrolytes,
 natural organic polymers, and synthetic polyelectrolytes.

      Inorganic electrolytes are salts or multivalent ions such as  alum
 (aluminum  sulfate), lime, ferric chloride, and  ferrous sulfate.'  The
 inorganic  coagulants act by neutralizing  the  charged double layer  of  colloidal
 particles  and by precipitation reactions.  Alum is typically  added to the
 waste stream as a solution.  At an alkaline  pH and upon mixing, the  alum
 hydrolyzes and forms fluffy gelatinous precipitates of aluminum hydroxide.
 These precipitates, partially  as a  result of  their large surface area,  act to
                                      VII-59

-------
  enmesh small particles and  thereby  create  large particles.  Lime and  ion
  salts, as well as alum, are used as flocculants primarily because of  this
  tendency to form large fluffy precipitates of "floe" particles.

       Natural organic polymers derived from starch, vegetable materials, or
  monogalactose act to agglomerate colloidal particles through hydrogen bonding
  and electrostatic forces.  These are often used as coagulant aids to enhance
  the efficiency of inorganic coagulants.

       Synthetic polyelectrolytes are polymers that  incorporate ionic or other
  functional  groups along the carbon chain in the  molecule.   The functional
  groups can  be  either anionic (attract positively charged species),  cationic
  (attract negatively  charged species), or neutral.  .Polyelectrolytes  function
  by  electrostatic  bonding  and the formation,of physical  bridges  between
  particles,  thereby causing them  to agglomerate.  These  are also most often
  used as coagulant aids  to  improve floe formation.

      The coagulation/flocculation and sedimentation process entails the
  following steps:

      •   Addition of the coagulating  agent to the liquid
      •   Rapid mixing to dispense the coagulating agent throughout the liquid
                          ml?lng ,t0 allov for cont*ct between small particles
          and agglomeration into larger particles.

      Coagulation and flocculation are used for the clarification of industrial
 wastes containing colloidal and suspended solids.  Coagulants are most
 commonly added  upstream of sedimentation ponds,  clarifiers,  or filter units to
 increase the efficiency of solids separation.  This practice has also been
 shown  to improve dissolved metal removal as  a  result of  the  formation of
 denser,  rapidly settling floes,  which appear to  be more  effective in  absorbing
 and adsorbing fine metal hydroxide precipitates.   Coagulation may also be  used
 to remove emulsified oil from industrial  wastewaters.  Emulsified oil  and
grease is aggregated by  chemical  addition through  the processes  of  coagulation
and/or acidification in  conjunction with  flocculation.  Performance data for
                                    VII-60

-------
coagulation/flocculation units are presented in the context of TSS and metals
removal in the section on chemical precipitation.

     According to the Section 308 Questionnaire data base, 42 OCPSF plants
utilize coagulation and 66 OCPSF plants utilize flocculation as part of their
preliminary treatment systems.

     3.  Secondary Treatment Technologies
         a.  Activated Sludge  ,
     The activated sludge process is a biological  treatment process primarily
used for the removal of organic material from wastewater.  It is  characterized
by a suspension  of aerobic and-facultative  microorganisms  maintained  in a
relatively homogenous state by mixing or by the  turbulence induced by  aera-
tion.  These microorganisms oxidize  soluble organics and  agglomerate  colloidal
and particulate  solids  in  the  presence of dissolved molecular oxygen.  The
process  can be preceded by sedimentation  to remove larger and heavier  solid
particles  if needed.  The  mixture of microorganisms, agglomerated particles,
and wastewaters  (referred  to  as mixed  liquor)  is aerated  in  an  aeration  basin.
The aeration step is  followed  by  sedimentation to separate biological sludge
from  treated wastewater.   The major  portion of the microorganisms and solids
removed  by sedimentation  are  recycled  to  the aeration  basins to be recombined
with  incoming  wastewater,  while  the  excess, which constitutes  the waste
sludge,  is sent  to sludge disposal  facilities.

      The activated sludge biomass is made up of bacteria, fungi, protozoa, and
 rotifers.   The bacteria are the most important group of microorganisms as they
 are responsible for stabilization of the organic matter and formation of the
 biological floe.  The function of the biomass is to convert the soluble
 organic compounds to cellular material.   This conversion  consists of  transfer
 of organic matter (also referred to as substrate or food) through the cell
 wall into the cytoplasm,  oxidation of substrate to produce energy, and
 synthesis of protein and other cellular components from  the substrate.  Some
 of the cellular material undergoes auto-oxidation (self-oxidation or
 endogenous respiration) in the aeration basin,  the remainder forming  net
 growth or excess sludge.  In addition to the direct removal of dissolved
                                     VII-61

-------
  organics by biosorption, the biomass can also remove suspended matter and
  colloidal matter.  The suspended matter is removed by enmeshment in the
  biological floe.  The colloidal material is removed by physiochemical
  adsorption on the biological floe.  Volatile compounds may be driven off to a
  certain extent in the aeration process.  Metals are also partially removed,
  and accumulate in the sludge.

       The effectiveness of the activated sludge process is governed by several
  design and operation variables.   The key variables are organic loading,  sludge
  retention time,  hydraulic or aeration detention time,  oxygen requirements,  and
  the biokinetic rate  constant (K).   The organic loading is described as  the
  food-to-microorganism (F/M)  ratio,  or the kilograms of BOD5  applied daily to
  the system  per kilogram  of mixed  liquor suspended  solids  (MLSS).   The MLSS  in
  the aeration tank is  determined by  the  rate and  concentration  of  activated
  sludge  returned  to the tank.  The organic loading  (F/M  ratio)  affects the BOD5
  removal,  oxygen  requirements, biomass production,  and  the  settleability of  the
  biomass.  The  sludge  retention time  (SRT) or sludge age is a measure of the
  average retention  time of solids in  the activated  sludge system.  Sludge
  retention time is  important  in the operation of an activated sludge system as
  it must be maintained at a level that is greater than the maximum generation
  time of microorganisms in the system.  If adequate sludge retention time is
 not maintained, the bacteria are washed from the system faster than they can
 reproduce themselves  and the process fails.   The SRT also affects the degree
 of treatment and production of waste sludge.   A high SRT results in carrying a
 high quantity of solids in the system and obtaining a higher degree of treat-
 ment and also results in the  production of less waste sludge.   The hydraulic
 detention time  is used to determine the size  of the aeration tank and should
 be determined by use  of F/M ratio,  SRT,  and MLSS.   The  biokinetic rate
 constant (or K-rate)  determines  the  speed of  the biochemical  oxygen demand
 reaction and generally ranges from 0.1 to 0.5 days'1  for municipal waste-
 waters.   The value of  K for any given organic compound  is  temperature-
 dependent; because microorganisms  are more active at higher temperatures, the
 value of K increases with  increasing  temperatures (7-5).   Oxygen  requirements
 are  based  on the  amount required for  BOD5 synthesis  and  the amount required
 for  endogenous  respiration.   The design  parameters  will vary with  the type of
vastewater to be  treated and  are usually determined  in a treatability study.
                                    VII-62

-------
The oxygen requirement to satisfy BOD5 synthesis is established by the
characteristics of the wastewater.  the oxygen requirement to satisfy

endogenous respiration is established by'the total solids maintained in the

system and their characteristics.  A detailed discussion of  typical design

parameters used in the OCPSF industry and how these parameters are used in the

Agency's compliance cost estimates are presented in Section  VIII.


     Modifications of  the activated sludge  process are  common, as  the  process

is extremely versatile and  can  be adapted for a wide  variety of  organically
contaminated wastewaters.   The  typical modification may represent  a variation

in one or more  of  the  key design parameters,  including  the F/M loading, aera-

tion location and  type,  sludge  return, and  contact basin configuration.   The

modifications in practice have  been  identified  by  the major  characteristics

that distinguish the  particular configuration.  The  characteristic types  and

modifications are  briefly described  as  follows:


      •   Conventional.   The  aeration  tanks are long and  narrow,  with plug flow
         (i.e.,  little forward or backwards  mixing).

      •   Complete Mix.   The  aeration  tanks are shorter and wider, and the
         aerators,  diffusers, and entry points of the influent and return
         sludge are arranged so that  the wastewater mixes completely.

      •  Tapered Aeration/"'  A modification of the conventional process in which
         the diffusers are arranged to supply more air  to the influent end of
         the tank,  where the oxygen demand is highest.

      •  Step Aeration.  A modification of the conventional  process in which
         the wastewater is introduced to the aeration tank at several points,
         lowering the peak oxygen demand.

      ,  High Rate Activated Sludge.  A modification  of conventional or tapered
         aeration in which  the  aeration times are shorter, the pollutants
         loadings are higher per unit mass of microorganisms in  the tank.  The
         rate of BOD   removal for this process is higher  than that of  conven-
         tional activated sludge processes, but the total removals are lower.

      •  Pure Oxygen.  An activated sludge  variation  in which pure oxygen
         instead of air  is  added  to  the aeration tanks, the  tanks  are  covered,
         and the oxygen-containing off-gas  is recycled.  Compared  to normal  air
         aeration, pure  oxygen  aeration  requires a smaller aeration  tank  volume
         and treats high-strength wastewaters and widely fluctuating organic
         loadings  more effectively.

      •  Extended  Aeration.   A  variation of complete  mix in  which  low  organic
         loadings  and long  aeration  times permit more complete wastewater
         degradation  and partial aerobic digestion  of the microorganisms.
                                      VII-63

-------
       •  Contact Stabilization.   An activated sludge modification using two
          aeration stages.   In the first,  wastewater is aerated with the return
          sludge in the contact tank for 30 to 90 minutes,  allowing finely
          suspended colloidal and dissolved organics to absorb to the activated
          sludge.   The solids are settled  out  in a clarifier and then aerated in
          the  sludge aeration (stabilization)  tank for 3 to 6 hours before
          flowing into the  first  aeration  tank.
       •  Oxidation Ditch Activated  Sludge.  An  extended aeration process  in
          which  aeration and  mixing  are  provided by brush rotors placed  across  a
          race track-shaped basin.   Waste  enters the ditch  at one end, is
          aerated  by the rotors,  and circulates.

      Activated sludge  is the  most  common end-of-pipe  biological treatment
 employed in the  OCPSF  industry.  According to  the  Section  308  Questionnaire
 data base, 143 OCPSF plants reported using activated  sludge, 2  plants  reported
 using an oxidation ditch, and 8 plants reported using pure  oxygen activated
 sludge.  Performance data for BOD5 and TSS removal are  from  the OCPSF Master
 Analysis File and are presented in Table VII-18.  The data show that activated
 sludge treatment results in a median removal efficiency of 96 percent for BOD5
 and 81 percent for TSS.  For those plants meeting the BPT performance edit of'
 95 percent removal of BOD5 or having an effluent BOD5 concentration no greater
 than 40 mg/1,  the BOD5 median removal efficiency is 98 percent and the TSS
 median removal efficiency is 82 percent.   (A detailed discussion of EPA's BPT,
 data editing  criteria is  presented later in this section.)

          b.   Lagoons
      A body of  wastewater  contained in  an earthen dike and designed for
 biological  treatment is termed a lagoon or stabilization pond or oxidation
 pond.   While  in the lagoon,  the  wastewater is biologically treated to reduce
 the  degradable  organics and  also reduce suspended  solids by sedimentation.
 The  biological  process  taking  place in  the  lagoon  can  be either aerobic or
 anaerobic, depending on the  design  of the lagoon.   Because  of their  low
 construction and  operating costs, lagoons offer a  financial  advantage over
 other  treatment methods and  for  this reason have become  popular  where
 sufficient land area  is available at reasonable  cost.

     Lagoons are used in industrial wastewater  treatment for  stabilization of
suspended, dissolved, and colloidal organics either as a main biological
                                    VII-64

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  biological treatment systems.  Aerobic, facultative, and aerated lagoons are
  generally used for industrial wastewater of low and medium organic strength.
  High strength wastewaters are often treated by a series of ponds; the first
  one will be virtually all anaerobic, the next facultative, and the last
  aerobic.

       The performance of lagoons in removing degradable organics depends upon
  detention time,  temperature,  and the nature of waste.   Aerated lagoons  gener-
  ally provide  a high  degree of BOD5 reduction more  consistently than  the
  aerobic  and facultative lagoons.   Typical  problems associated  with .lagoons  are
  excessive algae growth,  offensive  odors  from anaerobic ponds if sulfates  are
  present  and the pond  is  not covered, and seasonal  variations of effluent
  quality.

      There are four major classes  of lagoons  that  are  based on  the nature of
  biological activity.

      Aerobic Lagoons.  Aerobic lagoons are shallow ponds that contain
 dissolved oxygen (DO) throughout their liquid volume at all times.   These
 lagoons may be lined with concrete or an impervious flexible lining,  depending
 on soil conditions and wastewater characteristics.   Aerobic bacterial
 oxidation and  algal photosynthesis are the  principal biological processes.
 Aerobic lagoons are best suited to treating soluble organics in wastewater
 relatively free of suspended solids.   Thus,  they are often used to provide
 additional treatment  of effluents from anaerobic ponds  and other partial
 treatment processes.

      Aerobic lagoons depend  on algal  photosynthesis,  natural reaeration,
 adequate  mixing, good  inlet-outlet  design, and  a  minimum annual  air temper-
 ature above about 5°C  (41°F),  for a major portion of  the required DO.  Without
 any one of  these conditions, an aerobic pond may  develop anaerobic conditions
 or be ineffective or both.  Because light penetration decreases  rapidly with
 increasing depth, aerobic pond depths are restricted  to 0.2 to 0.3 m (0.6  to
 1.0 ft) to maintain active algae growth from top  to bottom.  In order to
achieve effective pollutant removals with aerobic lagoons,  some means of
                                    VII-66

-------
removing algae (coagulation, filtration, multiple-cell design) is sometimes
necessary.

     Anaerobic Lagoons.  Anaerobic lagoons are relatively deep ponds (up to
6 meters) with steep sidewalls in which anaerobic conditions are  maintained
by keeping organic loading so high that complete deoxygenation is prevalent.
Some oxygenation is possible in a shallow surface zone.  If floating materials
in the waste form an impervious surface layer, complete anaerobic conditions
will develop.  Treatment or stabilization results from anaerobic digestion of
organic wastes by acid-forming bacteria that break down organics.  The
resultant acids are then converted to carbon dioxide, methane, and other end
products.  Anaerobic lagoons are capable of providing treatment of high
strength wastewaters and are resistant  to shock loads.  These lagoons are
sometimes used to digest the waste sludge from an activated sludge plant.

     In  the  typical anaerobic  lagoon, raw wastewater enters near  the bottom of
the pond  (often at  the center) and mixes with  the active microbial mass  in  the
sludge blanket, which  can  be as much as 2 meters  (6 feet)  deep.   The discharge
is located near one of the sides of  the pond,  submerged below the liquid
surface.  Excess  sludge is washed out with  the effluent and  recirculation  of
waste sludge is not required.

     Anaerobic lagoons are customarily  contained  within earthen dikes.
Depending on soil and  wastewater  characteristics,  lining  with various
 impervious  materials,  such as  rubber, plastic,  or clay may be necessary.  Pond
geometry may vary,  but surface area-to-volume ratios  are  minimized to  enhance
heat  retention.

      Facultative Lagoons.   Facultative lagoons are intermediate depth ponds of
 1 to 2.5 m (3 to 8 feet) in which the wastewater is stratified into three
 zones.   These zones consist of an anaerobic bottom layer,  an aerobic surface
 layer,  and an intermediate zone.   Stratification is a result of solids
 settling and temperature-water density variations.  Oxygen in the surface
 stabilization zone is provided by reaeration and photosynthesis.  The photo-
 synthetic activity at the lagoon surface produces oxygen diurnally, increasing
 the DO content during daylight hours, and decreasing it during the night.  In
                                     VII-67

-------
  general,  the aerobic surface layer serves to reduce odors while providing
  treatment of soluble organic by-products of the anaerobic processes operating
  at the bottom.   Sludge at the bottom of facultative lagoons will undergo
  anaerobic digestion,  producing carbon dioxide and methane.

       Facultative lagoons  are customarily contained within earthen dikes.
  Depending on soil and wastewater  characteristics,  lining  the lagoon with vari-
  ous impervious materials,  such as .rubber,  plastic,  or  clay,  may be necessary.

      Aerated  Lagoons.  Aerated lagoons  are medium-depth basins  of 2.5  to  5 m
  (8 to  15  ft)  in  which oxygenation is  accomplished  by mechanical or diffused
 aeration  units and from induced surface  aeration.   Surface aerators  may be
 high speed, small diameter or  low speed, large diameter impeller  devices,
 either fixed-mounted  on piers  or  float-mounted on pontoons.  Diffused aerators
 may be plastic pipe with regularly spaced holes, static mixers, helical
 diffusers, or other types.  Aerated lagoons can be either aerobic or fac-
 ultative.   Aerobic ponds are designed to maintain complete mixing.  Thus, all
 solids are in suspension and separate sludge settling and disposal facilities
 are required to separate the solids from the treated wastewater.

     According to the Section 308  Questionnaire data base, lagoons are a
 common secondary  treatment technology in the OCPSF industry;  89 plants
 reported using aerated lagoons, 24 plants reported using  aerobic lagoons,  and
 12  plants  reported using anaerobic lagoons.   Performance  data for BOD5  and TSS
 removal from these lagoon  systems  were obtained from the  OCPSF Master Analysis
 File and are presented in  Table VII-19.   The  data  show  that  lagoon treatment
 results in a median removal efficiency of 89  percent for BOD5  and 66 percent
 for TSS, when all plants using  only  this  secondary  treatment  process are
 considered.   For  those plants meeting  the BPT  performance  edit,  the median
 BOD5 removal  efficiency is  90 percent  and the  median TSS removal efficiency is
 75 percent,

         c.  Attached  Growth Biological Systems
     Attached growth biological treatment systems are used to biodegrade the
organic components of a wastewater.  In these systems, the biomass adheres to
                                    VII-68

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  the surfaces of rigid supporting media.  As wastewater contacts the supporting
  medium, a thin-film biological slime develops and coats the surfaces.  As this
  film (consisting primarily of bacteria, protozoa, and fungi) grows, the slime
  periodically breaks off the medium and is replaced with new growth.  This
  phenomenon of losing the slime layer is called sloughing and is primarily a
  function of the organic and hydraulic loadings on the system.   The effluent
  from the system is usually passed to a clarifier to settle and remove the
  agglomerated solids.   Attached growth biological treatment systems are appli-
  cable  to industrial wastewaters amenable to aerobic biological treatment  in
  conjunction  with suitable pre- and  post-treatment.   The process is effective
  for  the removal of suspended or colloidal materials,  but  less  effective for
  the  removal  of  soluble organics.  The two major  types of  attached  growth
  biological treatment processes  used  in  the  OCPSF industry  are  trickling
  filters  and  rotating biologic  contactors.   These processes  are  described
  below:

      Trickling Filters.  The physical unit  of a  trickling filter consists of a
 suitable structure packed with an inert medium (usually rock, wood, or
 plastic) on which a biological mass is grown.  The wastewater is distributed
 by either.a fixed-spray nozzle system or a rotating distribution system over
 the upper surface of the medium and as it flows through the medium covered
 with biological slime,  both dissolved and suspended organic matter are removed
 by adsorption.  The adsorbed matter is oxidized by the organisms in the slime
 during their metabolic  processes.  Air flows through the filter by convection,
 thereby providing the oxygen needed to maintain aerobic conditions.  Most
 trickling filters are classified as  either low- or high-rate,  depending on the
 organic and hydraulic loading.   A low-rate filter generally has a media bed
 depth of 1.5  to  3 meters (5 to 10 feet)  and  does  not use recirculation.
 High-rate filter media  bed depths can vary from 1 to 9 meters  (3 to 30 feet)
 and require recirculation.   The recirculation of  effluent  in high-rate filters
 is necessary  for  effective sloughing  control.   Otherwise, media  clogging and
 anaerobic conditions could  develop as  a  consequence  of the  high  organic
 loading  rates  employed.

     Rotating Biological Contactors.  The most common  types  of rotating
biological contactors consist of a plastic disk or corrugated plastic medium
                                    VII-70

-------
mounted on horizontal shafts.  The medium slowly rotates in wastewater (with
40 to 50% of its surface immersed) as the wastewater flows past.  During rota-
tion, the .medium picks up a thin layer of wastewater, which flows over its
surface absorbing oxygen from the.air.  A biological mass growing on the
medium surface adsorbs and coagulates organic pollutants from the wastewater.
The biological mass biodegrades the organic matter.  Excess microorganisms and
other solids are continuously,removed from the film on  the disk by shearing
forces created by the rotation of the disk in the wastewater.  This rotation,
also mixes ,the wastewater, keeping sloughed solids in suspension until they
are removed by final clarification.                                  :

     According to the Section 308, Questionnaire  data base, 8  plants  report
using  rotating biological  contactors  and  12 plants report  using  trickling
filters  as a  secondary  treatment  technology.  Performance  data  fqr  BOD5  and
TSS  removal are  from  the OCPSF  Master Analysis  File  and are  presented  in Table
VII-20.   The  data show  that  attached  growth biological  treatment  results in  a
median removal efficiency  of 92 percent for BOD5 and 70 percent  for TSS, when
all  plants  using only this secondary  treatment  process  are considered.   For
 those plants  meeting the BPT performance edits,  the  median BOD5  removal      ,  .
 efficiency  is 92 percent and the median TSS removal  efficiency is 70 .percent.

          d.   Secondary Clarification
      The function of secondary clarifiers varies with  the method of,biological
 treatment utilized.  Clarifiers in an activated sludge system serve a dual
 purpose.  In addition to providing a clarified effluent, they must also
 provide a concentrated source of return sludge for process control.  Adequate
 area and depth must be provided  to allow this compaction to occur while
 avoiding rejection of solids into the  tank effluent (7-6).  Secondary clari-
 fiers dn activated sludge systems are  also sensitive to sudden changes -in flow
 rates.  Therefore, the use of multispeed pumps  for in-plant wastewater  lift
 stations is strongly recommended where adequate  flow equalization  is not
 provided (7^7).

       Clarifiers in activated sludge  systems must be designed not only for
 hydraulic overflow rates, but  also for solids  loading  rates.  This  is due
                                      VII-71

-------
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-------
mainly to the need for both clarification and thickening in activated sludge
clarifiers to provide both a well clarified effluent and a concentrated return
sludge (7-6).

     When the MLSS concentration is less than about 3,000 mg/1, the clarifier
size will normally be governed by hydraulic overflow rates.  At higher MLSS
values, the ability of the clarifier .to thicken solids becomes the governing
factor.  Therefore, solids loading rates become more critical in determining
tank size.  Design size should be computed for both average and peak  condi-
tions  to ensure satisfactory effluent quality at all times  (7-6).

     Depth of clarifiers  in activated sludge systems is  extremely  important.
The depth must be sufficient to permit  the development of a sludge blanket,
especially under conditions when  the sludge may be bulking.  At  the same  time,
the interface of the  sludge blanket and the clarified wastewater should be
well below the effluent weirs  (7-6).

     For  long rectangular tanks,  it  is  common  practice  to  locate  the  sludge
withdrawal hopper about  l/3«?to 1/2  the  distance  to  the  end  of  the  tank to
reduce the effects  of density  currents  (7-6,  7-7).

     Typical design parameters for  clarifiers  in  activated sludge  systems
 treating typical domestic wastewaters  are also presented in Table  VII-21.  The
design of these clarifiers should be based upon an evaluation of average and
 peak overflow rates and solids loadings.   That combination of parameters that
 yields the largest  surface area should be used (7-6).

      Clarifiers following trickling filters must effectively separate
 biological solids sloughed from the filter media. .The design of clarifiers
 following trickling filters is based on hydraulic overflow rates similar to
 the method used for primary clarifiers.  Design overflow rates must  include
 recirculated flow where  clarified secondary effluent is used for recir-
 culation.  Because the influent SS concentrations are low, tank solids
 loadings need not be considered.  Typical design parameters for clarifiers
 following trickling  filters are also presented in Table VII-21 (7-6).
                                     VII-73

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                                  TABLE  VII-21.
               TYPICAL DESIGN PARAMETERS FOR SECONDARY CLARIFIERS
                          TREATING DOMESTIC WASTEWATER
 Type of Treatment
     Overflow Rate
     (gpd/sq ft)
 Average       Peak
 Settling Following
   Trickling Filtration  400-600

 Settling Following Air-
   Activated Sludge
   (Excluding Extended
   Aeration)             400-800
Settling Following
  Extended Aeration

Settling Following
  Oxygen-Ac t i va t ed
  Sludge with Primary
  Settling
200-400
1,000-1,200




1,000-1,200


    800
400-800    1,000-1,200
                 Solids Loading1     Depth
              (Ib solids/day/sq ft)    ft
                Average       Peak
                                                     20-30
                            20-30
                                                    25-35
                                                 10-12
                                         <50    12-15
                              <50    12-15
                              <50     12-15
 Allowable solids loadings are generally governed by sludge settling
 characteristics associated with cold weather operations.    e"-Ling

Source:  Process Design Manual for Upgrading Existing Wastewater Treatment
         Plants, EPA 625/l-71-004a, October 1974.
                                   VII-74

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         e.  Operating, Managing, and Upgrading Biological Treatment Systems
     This section identifies methods by which biological treatment systems in
the OCPSF industry may modify their existing facilities in order to upgrade or
improve performance.  Most of the upgrades discussed pertain to activated
sludge and aerated lagoon systems, since these are the biological treatment
systems most commonly used in the OCPSF industry and the systems most amenable
to operational and design modifications.  Approaches to upgrading biological
treatment units include adding unit treatment processes, modifying the design
and operational parameters of existing units, acclimating existing bacteria to
certain toxicants or using bioaugmentation (the addition of acclimated types
of bacteria bred to remain active under a variety of adverse conditions),
particle size reduction, nutrient addition, and the addition of powdered
activated carbon (PAC) to aeration units.

     In some cases, the only means of improving the performance of a
biological treatment system is to add additional unit  treatment processes.
Aeration basins and clarifiers are sometimes added to  accommodate higher waste
loads or to address inadequacies  in the original treatment plant design.  The
addition of primary.unit treatment such as equalization improves system
performance by diluting slugs of  concentrated wastes,  minimizing routine
variations in influent wastewater flow and pollutant concentration, and
removing suspended  particles.  Preaeration basins are  often added to raise
wastewater DO levels and improve  the  treatability and  settling characteristics
of the wastes.  Postaeration basins are added  to systems  to raise the DO  in
treatment  plant effluent before  it flows  into  receiving streams.  Microscreen
and  filtration units can be added to  improve suspended solids removal prior  to
effluent discharge.  In summary,  there are a number of unit processes
available  that can  be  added to a  facility, provided that  land is available,  to
address  specific  treatment problems.

     Upgrading existing bioreactor  facilities  can include adding chemical and
physical treatments such as the  addition  of  polyelectrolytes  to clarifiers  to
improve  solids settling or  the installation  of a surface  skimmer  to a pre-
treatment  unit to  accomplish oil and  scum removal.  Operational changes
affecting  the quantity and  species  of microorganisms  in a system, however,  are
                                     VII-75

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  often the most significant  with regard to improving the removal  of  pollutants
  and  increasing a treatment  system's  capacity to  handle  large  raw waste  loads.
  Experience at  some facilities  indicates that operation  of  an  activated  sludge
  plant to  maintain a stable  mixed liquor fauna (i.e.,  maintain a  specific
  distribution of bacterial species),  rather  than  operation  based  on  a  constant
  aeration  rate  or MLSS  concentration, yields  more consistent treatment of BOD
  and  priority pollutants  (7-8).   Thus,  operational changes  and unit  treatment
  modifications  should be  planned  giving appropriate  consideration  to this
  approach.  Many  of the concepts  for  improving the performance of  biological
  units discussed  below are presented  in the context  of activated sludge and
  aerated lagoon systems;  however,  in many  cases they also apply to other types
  of biological units, such as fixed film reactors.

      As previously discussed, flow equalization  is important  in improving the
  treatability of a waste stream by minimizing variations in wastewater
 characteristics, such as temperature, pH, and pollutant concentrations.   One
 facility in the OCPSF industry improved the equalization of its wastewater by
 removing several feet of sedimentation from a primary clarifier,  thus
 increasing the  wastewater detention time.  This plant also added  heat
 exchangers upstream of the treatment  units to lower  the wastewater temperature
 and provide a more uniform wastewater temperature year round.

      Modifications to the operations  of activated sludge units include
 changing influent flow patterns;  altering the division,  mixing, and  aeration
 characteristics of the  tanks; and recycling  sludge from  the secondary
 clarifier  to one or more  locations in the treatment  train.   Step  aeration,
 introducing primary effluent at  several locations in the aeration basin, can
 be  used  to upgrade the  performance of a plant with high  pollutant  loadings
 (7-9).   Distribution of the  waste equalizes  the loading  in  the aeration  basin
 and enables  the  microorganisms  to function more efficiently.

      In  situations  where  a treatment  system needs to be  modified  to handle an
 increased  waste load, a conventional single tank  activated  sludge  process can
 be converted into a  two-stage contact stabilization process.   The main advan-
 tage of  contact stabilization is  that it operates with a much  shorter
hydraulic  retention  time and hence enables the  facility  to  treat a larger
                                    VII-76

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waste load. In other situations where oxygen requirements are not being met
and the facility has extra capacity, oxygen supply can be improved by creating
a complete mix activated sludge system from a contact stabilization or
conventional activated sludge unit.  Another approach to improving oxygen
supply is to convert a standard air supplied aeration system to a pure oxygen
system.

     Pure oxygen systems are recommended for situations where wide fluctua-
tions occur in the organic loading  to a plant and for strong industrial waste-
water.  Since they are more efficient than conventional aeration systems,  they
can be used to increase  the treatment capacity of existing  plants.  A means  of
further improving a pure oxygen or  air supplied  aeration system is to use
diffusers  that produce smaller diameter bubbles  (and hence  increase the
surface area  to bubble volume ratio), and  to increase the contact  time between
the bubble and the wastewater.

     In some  treatment  train configurations, it  is  possible to create a  second
biological  treatment  unit  by recycling sludge  from  a secondary clarifier to  a
preaeration unit.  As presented  in the discussion of summer/winter issues,
 this was  done by  plant  #2394  in  the OCPSF  industry  to  improve  the  performance
of its  treatment  plant  during  cold weather.  An  additional  benefit of
 recycling sludge  in  this manner  is that  there  is usually a  decrease  in  the
 total  sludge  volume  generated.   Plant #2394 used 100  percent recycle  and hence
 had no waste  sludge  during winter months.

      Fixed film biological treatment units sometimes  have problems associated
 with waste distribution and waste loading.  Low flows  in trickling filter
 plants may result in poor distribution of wastewater over the filter media.
 Recirculation of part of the treatment plant effluent will increase the flow
 through the plant and improve the motion of the distribution arm.   An approach
 to increasing the capacity or improving the performance of some trickling
 filter plants is to replace traditional filter media usually consisting of
 stones with synthetic media designed to have a much larger surface area.

      Efficient operation of a bioreactor is dependent on maintaining viable
 populations of bacteria.  Organic  priority pollutant removal is often
                                     VII-77

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  problematic as  the pollutants  often inhibit  the growth of organisms  respon-
  sible  for  their degradation (7-10).   To  efficiently degrade  these  organics,
  the  inhibitory  levels  should be  determined and  should  not be exceeded  in  plant
  operations.  In addition,  bacteria  can be acclimated to certain  toxicants by
  subjecting the  activated sludge  to  an acclimation  program or by  using
  "pre-acclimated" bacteria,  the latter process being called bioaugmentation.
  Bioaugmentation has also been used  to supplement plants in cold  weather with
  specialized  bacteria that maintain high  levels  of  biodegradation activity at
 wastewater  temperatures as  low as 40°F.  In addition,  bioaugmentation has been
 proven to improve oxygen transfer, reduce sludge generation, and improve
 sludge settling characteristics.  Furthermore,  bioaugmentation will greatly
 reduce the time needed for  recovery from a shock loading.  Preserved bacteria
 can be added to a biological treatment system as needed  to maintain existing
 populations and to increase biodegradation capabilities  in the event of a
 chemical upset.

      The efficiency of a biological system can be improved by reducing the
 particle size of solids in the  influent  through pretreatment with coagulation/
 flocculation, sedimentation, or other processes.  Rates of adsorption,
 diffusion,  and  biochemical reaction are  all  enhanced by smaller particle size.
 Particles smaller than  1 x 10~6  meter in  diameter can be biochemically
 degraded at a much  faster> rate  than larger particles (7-11).    This is  due to
 the increase in  surface area to  mass ratio as  particle  size decreases.   Higher
 quality secondary effluent  from  the  biological treatment unit will  result  in
 subsequent  improvements in  the performance of  downstream units  such as  filtra-
 tion  and  activated  carbon units.

      Secondary clarification systems  can  also  be modified or  operated
 differently  in order to upgrade or improve TSS effluent performance.  An
 Agency  study  of  full-scale municipal  treatment systems  shows  that rectangular
 clarifier modifications such as reaction  baffles and  other  flow-modifying
 structures at clarifier inlets resulted in a 13.8 percent  reduction in
 effluent TSS.  Also, the additional installation of a stop-gate in a channel
upstream of the  aeration basins to reduce large  flow  transients to a rectang-
ular secondary clarifier resulted in 31.5 percent lower effluent TSS levels
 than the unmodified clarifier without  the stop-gate.  In another case, this
                                    VII-78

-------
study also shows that slowing the rotational speed of hydraulic sludge removal
mechanisms .in circular clarifiers to 56 percent of its design speed reduced
effluent TSS by 10,5 percent.  Also, the additional installation of a
cylindrical ring baffle/flocculation chamber in secondary clarifiers resulted
in 38.5 percent lower effluent TSS levels than the unmodified secondary
clarifier  (7-7).

     For a biological system  to function properly, nutrients such as organic
carbon, nitrogen, and phosphorus must be available in adequate amounts.  While
domestic wastewaters usually  have an excess of nutrients, industrial waste-
waters are sometimes deficient.  If a deficiency  is  identified,  the perfor-
mance of an  industrial wastewater treatment plant can be  improved  through
nutrient addition.  According to the Section 308  Questionnaire data base,
114  OCPSF  plants utilize nutrient addition  prior  to  biological treatment.

     Removal of organics can be  enhanced  by mixing powdered activated  carbon
(PAC)  in  the aeration  basin of a biological treatment system (7-12).   PAC
improves  treatment  in  the activated sludge  process because  of its  adsorptive
and  physical properties.  Lighter weight  organics, such as  phenols,  appear to
adsorb reversibly  on the carbon.  Use,of  PAC  can dampen the shock effects  of
concentrated slugs  of  inhibiting organics on  the bacteria culture,  as  the
organics  will initially adsorb on  the carbon.   The PAC  can be bioregenerated
as these lighter weight organic species desorb from the PAC and are degraded.
 Heavier organics,  such as the residual metabolic end products,  appear to
 adsorb irreversibly on the PAC.   PAC also helps  to remove pollutants by
 extending the contact time between the pollutant and the biomass.   When
 adsorbed  by the carbon, pollutants settle into the sludge and contact time
 with the  biomass is extended from hours to days.  The waste sludge that
 contains  powdered carbon is  removed from the activated sludge system,
 dewatered, and either disposed of or regenerated.  The regenerated carbon may
 require an acid wash to remove metals as well as other inorganic materials  to
 improve the adsorption  capacity.
          e.
               Summer/Winter
       In  commenting  on  the  1983  proposal  and  subsequent  notices,  many  commen-
  ters  asserted  that  EPA incorrectly evaluated the  effect of  temperature on
                                      VII-79

-------
  Diological treatment systems and incorrectly concluded that temperature is ,,„,
  important in the context of effluent limitations guidelines.   They claimed
  that  one element of this incorrect analysis was EPA's deletion of nine plants
  from  the data base simply because they had been issued "Best  Professional
  Judgement" NPDES permits with separate compliance standards for summer and
  winter months.   They claim that  this is an arbitrary  decision that virtually
  ensures  that  the effect  of temperature will not be considered in estimating
  effluent  variability.

      EPA  has  studied  the effects  of  temperature variations  on biological
  treatment  system performance, in  the  OCPSF  industry and disagrees with  these
  comments.  With  regard to  operations  in warm climates, the  Agency  believes
  that warmer than average  temperatures  do not have  any significant  effect on
  biological treatment efficiency or variability.  However, algae blooms in
 ponds can be a wastewater  treatment problem in  ponds located  in warm climates.
 Nonetheless, polishing ponds are not part of the technology basis  for BPT
 limitations.  Also, EPA was not able to associate algae bloom problems'with
 any elements of biological treatment (aerated lagoons, clarification, equali-
 zation basins, etc.).  Consequently, EPA believes that algae growth problems
 in warm climates are not  relevant to the promulgated BPT regulations.

      In order to evaluate winter performance of biological treatment systems,
 EPA has  analyzed BOD5 removal efficiency,  BOD5  effluent concentration,  and
 operational changes for 21 plants reporting daily data and other plants
 located  in various parts  of the country.   These analyses  indicated that there
 is a slight reduction in  average  BOD5 removal efficiency  and a small increase
 in average effluent BOD5  concentrations during  winter  months for some plants.
 However,  other plants  were able to maintain a BOD5  removal efficiency of
 95 percent or  greater  and effluent BOD5 concentrations  characteristic of good
 operation  during  the entire year.   The analysis  also suggests  that  the  plants
 with lower efficiencies are affected  as much by  inefficient  operation
 practices  as by winter  temperature considerations.   A discussion  of
 inefficient operating practices used  by some  plants  as well  as  practices
 employed by plants  achieving superior all year performance  is  presented below.
The adoption of practices used by  plants with higher winter  efficiencies
should result in  improved winter effluent quality.
                                    VII-80

-------
     EPA has determined that temperature effects can be mitigated by opera-
tional and technological changes so that compliance with BPT limitations using
biological treatment is possible for all OCPSF plants with well-designed and
well-operated biological systems.  As also discussed below, the potential
effects of winter operations are included in the plant-specific factors that
affect derivation of the variability factors used to establish effluent
limitations guidelines.  In addition, EPA has developed costs for plants that
need to upgrade their winter-time biological treatment operation to comply
with the promulgated BPT limitations.

:    .Regarding the deletion of nine summer/winter plants'  data from the data
base,  the Agency notes  that because these plants were subject to meeting two
different sets of permit limits, they had no incentive to  attempt to achieve
uniform limitations  throughout  the year.  Not suprisingly  then,  the daily  data
from these  plants exhibit  a two-tier pattern.   These data  can be characterized
by-two means, and the  variability of these  data over a 12-month  period  is
fundamentally different from  the data from  plants required to meet only one
set of permit limits.   Consequently, the data generated  during  these periods
are not representative of  well-operated biological  treatment, which as  noted
ibove, is  capable of uniform  treatment  throughout  the year as demonstrated by
£ number  of plants.  Another  problem with  daily data from  these plants  is  that
during certain  periods of  the spring and  fall,  these plants may be  able to
Operate  their  treatment plants at  less  than full  efficiency because they  are
required  to meet the less  stringent  set of permit  limits.

  :    In summary, the Agency believes that  it has  accounted adequately for the
 effect of temperature changes on biological treatment performance in its
 variability analysis by including in the variability data, base a number of
 well-designed and well-operated plants from climates with significant tempera-
 ture variation.  The inclusion of data from plants with summer/winter permits
 would result in an overestimate of the variability of biological treatment
 operations in the OCPSF categories.

       The detailed analyses described below are based on two sets of data  that
 were  analyzed in order to determine the effect of  temperature on the treatment
 of BOD  and TSS.  The  first  set included the OCPSF daily  data base, which
                                      VII-81

-------
 contained daily  data  from  69  plants.   Of  these,  48 were excluded  from  the
 final BPT daily  data  base  analysis  for a  variety of  reasons,  including greater
 than 25 percent  non-process wastewater dilution,  summer/winter NPDES permit
 limits, changes  in  treatment  system during sampling, non-representative
 treatment, and effluent data  after  post-biological tertiary treatment.  As a
 result, daily data  from 21 plants formed  the basis of the variability
 component of the BPT limits and were included in  the summer/winter analysis.
 These 21 plants are #s 387, 444, 525,  682, 741, 908, 970, 1012, 1062,  1149,
 1267, 1407, 1647, 1973, 1977, 2181, 2430, 2445, 2592, 2626, and 2695.  The
 second data set includes 131 plant  responses to a Section 308- Survey question
 regarding average winter and average summer performance and operating para-
 meters that were gathered to highlight practices used to accommodate cold
 weather conditions.

      The principal parameters evaluated for correlation with temperature were
 average effluent  BOD5  and TSS concentration,  and BOD5 removal  efficiency.   In
 addition,  two plants that had made operational  changes  to increase winter
 efficiency  were also evaluated.
     525s  Removal Efficiency.   Of the 21 plants with long-term daily data,
 14  had  sufficient BOD5  influent and effluent  data (total  BOD5  values were
 used) to enable  the  calculation of BOD5  monthly removal efficiencies.   Six
 plants  <#s 387,  444,  1149,  1267,  2626, and  2695)  were not used because  they
 had no  BOD5  influent  values, and  plant ;#908 was eliminated because  its
 geographic location  in  Puerto Rico made  any seasonal distinctions meaningless

     The plants  that  were used  had a  minimum  of three influent  and  effluent
 values  each month; if there were  time periods where  fewer  values were avail-
 able, these specific  time periods  were excluded from the analysis (Plant 1062
 had only one influent measurement  between 1-1-79 and  7-31-79 and plant 2592
had no  influent sampling between 12-1-79 and 7-9-80).  For each plant where
sampling occurred over a period exceeding 1 year, values for the same month
but different years were averaged  together.

     The monthly efficiencies were derived by use of  the formula
                                    VII-82

-------
     Fraction removed =  1 -
                             [average BOD effluent for the month]
                              average BOD influent for the monthJ

    'The result of the efficiency analysis is presented in Table VII-22.

     As can be seen, the annual average BOD5 removal efficiency is 95 percent.
Seven of the.fourteen plants (#s 682, 970, 1062, 1647, 1977, 2181, and 2430)
had greater than.95 percent removal of BOD5 throughout the year.  If the   '
winter months are defined to be January-February-March and the summer months
are defined to be June-July-August, two plants had removal efficiencies in the
winter months that were greater than or equal to those in the summer: months.
Plant 1062 had 97 percent removal efficiency in both the winter and  summer
months, and Plant 2430 had 99 percent removal efficiency in  the winter months
and 98 percent removal efficiency in the  summer.  In addition, five  plants
(ts 682, 970, 1647, 1977 «and 2181) had average winter removal efficiencies
within 1 percent of their average summer  removal efficiencies.

     The 14 plants  are located  in three different geographical regions.   Plant
data were analyzed  by region, with subset I including data  from,the  five
plants located in the ncnrth  (W, IL, RI,  lA, IN), subset II  including data
from the six  plants located  in  the south  '(TX, GA, LA, SC),  and subset III
including data from the  three plants located in  the middle-latitudes (VA, NG).
These  results are presented  in  Tables VII-23, VII-24, and VII-25.  Monthly
average removal  efficiencies for each plant were obtained,  and  these were
combined into an overall monthly average  for each subset.   Plants located in
the northern region had  the  highest  average  removal efficiency  (northern
plants - 98  percent;  southern plants -  95 percent; middle  latitude - 89
percent).  In the northern region,  four of the  five plants  (682,  1062,  1647,
and  2181) had removal efficiencies  greater than 95 perc.ent  throughout  the   ;
^Although it was also possible to obtain monthly efficiencies by calculating
  daily efficiencies and-averaging them for each month, such a method would
  have resulted in elimination of many data points when only influent or efflu-
  ent values, not both, were available for a specific day-  Also, because
  retention times are generally greater than 1 day, and because wastewaters are
  mixed during treatment,  an effluent value cannot necessarily be correlated
  with an influent value for that same day or for any other particular time.
                                     VII-83

-------
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 year.   In  the  southern region,  only two  of the six plants  (1977  and  2430)  had
 greater than 95  percent removal efficiencies  throughout  the  year;  in the
 middle  latitudes,  one.out  of  the three plants  (970) had  greater  than 95
 percent  removal  efficiency.   This analysis shows  that  removal efficiency was
 affected primarily by  nonclimate-related  factors.

      A similar analysis was performed using the data base derived  from plants
 that responded to  the  OCPSF 308  Questionnaire  on summer/winter operations.
 Question C-12 of the questionnaire 'asked each  respondent to select a  3-month
 period in the summer and a 3-month period  in the winter of the same year.  The-
 summer period was generally selected as-June-July-August or July-August-
 September,  although a  few respondents selected May-June-July.  The winter
 period was  generally selected as January-February-March,  although some
 respondents selected various other 3-month periods from October through
 February.  For  these two periods, the respondent was to provide summary data
 for a variety of parameters,  including average daily,total  BOD5  influent and
 effluent concentrations, TSS influent and effluent concentrations,  MLSS con-
 centration,  mixed liquor volatile suspended solids (MLVSS)  concentration,  and
 food to  microorganism ratio (F/M).   Plants were included  in the  analysis if
 there were  both influent and  effluent total BOD5  values so  that  a BOD5 removal
 efficiency  could  be calculated.   Of  all plants  for which  information  was
 available from  Question C-12,  131 had sufficient  information  to  enable the
 calculation  of  BOD5  removal efficiency.   When estimated values were given,
 they were used.   For  the four  plants  using recycled waste streams (296,  2551,
 1617, 2430), only the initial  influent and  final effluent values were used;
 although  this might result  in  artificially  high efficiencies, it represented
 the  only  logical  approach.  Two  plants (1038 and 1389)  had two different sets
 of values, so each  set  was  used.  Two plants (227 and 909) had influent data
 from one biological treatment  system and 'effluent data  from another, and were
not used in  the analysis.
                                    VII-88

-------
    The  results  of  the  analysis  are  as  follows:
                                       Summer
                                                       Winter
Plant Category
All Plants
Southern Plants
Northern Plants
Middle Latitude
Plants
N !
131
52
46
33

Avg
Sfficiencj
0.89
0.91
0.86
0.89

Std Avg Std
r Dev Efficiency Dev
0.31
0.14
0.48
0.18

0.86
0.86
0.85
0.87

0.25
0.21
0.32
0. 19

     Southern plants were located in Alabama, Florida, Georgia, Louisiana,
Mississippi, South Carolina, and Texas.  Northern plants were located in
Connecticut, Iowa, Illinois, Indiana, Michigan, New Jersey, New York, Ohio,
Pennsylvania, Rhode Island, and West Virginia.  Middle latitude plants were
located in Arkansas, Delaware, Kentucky,. Maryland, North Carolina, Oregon,
Tennessee, Virginia, and Washington.

     These results are consistent with  the results of the  14-plantdaily  data
analysis discussed previously.  The BOD5 removal efficiencies  for all plants
are 3 percent less during  the winter period  than the .summer period (86% vs.
89%).  The  regional removal efficiencies are 1  to 5 percent less  in  the winter
period than  in  the summer  period.  The  greatest regional variation in
efficiency  occurs in  the south.  The standard deviation.of the efficiency is
large relative  to the efficiency difference  within each category, reflecting
the large variations  among plants  within  the same category.   These results
tend  to  indicate that while northern and  middle latitude  plants would  have
larger swings  in temperature going from season to season,  these swings have
been  compensated for  through operation and process modifications as  indicated
by the  similar summer and  winter removal efficiencies (86% vs. 85%).  The
 larger  difference between  summer and winter removal  efficiencies for southern
 plants  (91% vs. 86%)  indicate that these facilities  have  not  "adequately
 addressed the smaller temperature swings by operational and process  modifica-
 tions.
                                     VII-89

-------
       These findings support several conclusions.  There may be differences
  between efficiencies attainable in summer and in winter, but these differences
  are nonetheless small.  The large standard deviations obtained reflect differ-
  ences in operating practices among plants.  Plants that operate efficiently do
  so year-round,  and have been able to minimize or at least partially compensate
  for temperature effects through equipment and operational treatment system
  adjustments.   In addition,  plants located in the colder northern climate show
  minimal efficiency differences between winter and summer months,  which
  provides further evidence that temperature effects are  minimal.   The daily
  data  assessment also indicates minimal efficiency variations  during the  spring
  and autumn months,  when temperature  fluctuations would  tend  to  be greatest;
  this  result casts  doubt on  the theory  that fluctuations,  rather  than continued
  cold, would reduce  BOD5  removal  efficiency by preventing the  formation of  a
  stable microbial population.

 Average Effluent BOD., and TSS

      The effect of  temperature on effluent BOD5  and TSS  levels was evaluated
 previously in the July  1985 document entitled  "Selected  Summary of Information
 in Support of the OCPSF Point Source Category Notice of Availability of New
 Information."  EPA calculated rank correlation by subcategory for BOD5 efflu-
 ent and TSS effluent versus heating degree days, a measure typically used by
 power companies to estimate heating bills.  The results of the analysis were
 consistent with the assumption that temperature is not a factor.  With the
 exception of  effluent TSS for specialty chemicals, all calculated rank
 correlations  were not significant.   In  the case of specialty  chemicals,  the
 correlation was  positive and significant.   However, the  positive correlation
 implies  that TSS increases as temperature  decreases.   Since engineering
 considerations dictate that  TSS should  not decrease as temperature increases,
 this result is considered spurious.

     A new analysis  was  conducted,  employing data from. 20 of  the  21  plants  in
 the data  base used  for  the calculation  of  BPT variability factors.   The only
plant  not used was #908,  because  of its  location  in Puerto Rico.   BOD, and  TSS
effluent averages were compared to months  rather  than  heating  degree  days (see
Tables VII-26 and VII-27).  The annual average  BCD, and. TSS effluent  concen-
trations are 22 mg/1 and 31 mg/1, respectively.   Seven of the  20 plants (525,
                                    VII-90

-------
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682, 970, 1062, 1973, 2181, and 2430) have monthly average BOD5 effluent
concentrations less than 22 rag/1 throughout the year, while four of the
20 plants (387, 1012, 1407, and 2626) have monthly average. BOD5 effluent
concentrations less than 37 mg/1 throughout the year.  Also, if winter months
are defined as January-February-March and summer months are defined as
June-July-August, three plants (1062, 1149, and 2430) have lower average BOD5
effluent concentrations for the winter months than for the summer months.  In
addition, two plants (387 and 2626) have average BOD5 effluent concentrations
for the winter within 3 mg/1 of the summer average BODg effluent concentra-
tions, while four plants (444, 1973, 2626, and 2695) have average TSS effluent
concentrations for the winter months within 3 mg/1 of the summer average TSS
effluent concentrations.

     Another analysis was performed comparing each plant's average BODg and
TSS effluent concentrations in the winter and summer months to its annual
average BOD5 and TSS effluent targets that provide the basis for BPT effluent
limitations.  These annual compliance targets are presented in Appendix VII-A
of this document.  Eight of the 20 plants (525, 682, 1062, 1407, 1647, 1973,
2181, and 2430) had both winter and summer average BOD5 effluent concentra-
tions below their annual average; BOD5 effluent compliance targets, while eight
plants (387, 444, 525, 1CTL2, 1407, 1973, 2181, and 2626) had both summer and
winter average TSS effluent concentrations below their annual average TSS
effluent compliance targets.

     The plants were then divided into geographical regions,and the same
analyses performed.  Subset I consisted of six northern plants from West
Virginia, Illinois, Rhode Island, Iowa, and Indiana; subset II consisted of
10 southern plants from Texas, Georgia, Louisiana, and South Carolina; and
subset III consisted of four middle latitude plants from Virginia and North
Carolina (see Tables VII-28, VII-29, VII-30, VII-31, VII-32, and VII-33).  The
annual average BOD5 effluent concentrations were 13 mg/1, 30 mg/1, and 16 mg/1
for the northern, southern, and middle latitude plants, respectively; annual
average TSS effluent concentrations were 38 mg/1, 31 mg/1, and 19 mg/1 for the
northern, southern, and middle latitude plants, respectively.  Approximately
66 percent, 70 percent, and 50 percent of the plants in the northern,
southern, and middle latitude regions, respectively, have annual average BOD5
                                    VII-93

-------
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VII-99

-------
 concentrations less than the regional annual average BOD5 effluent concentra-
 tion; approximately 66 percent, 66 percent, and 50 percent of the plants in
 the northern, southern, and middle latitude regions, respectively, have annual
 average TSS effluent concentrations below the regional annual average TSS
 effluent concentrations.

 Additional Parameters
      Evaluating other parameters using the 21-plant daily data base was not
 possible since BODg,  TSS,  and flow were the only parameters monitored.  The
 Question C-12 data base provides average summer and winter values for MLSS,
 HLVSS,  and F/M.   For all plants used in the previous C-12 data analysis for
 BOD5  efficiency and for which values for MLSS,  MLVSS,  or F/M were available
 for both summer and winter periods,  average values for MLSS,  MLVSS,  and F/M
 were  determined.

      Several  editing  rules were used.   If estimates were given,  they were
 used.   For Plant  #1340,  two different  biological treatment processes had the
 same  BOD5  values,  but  had  two different  sets of MLSS,  MLVSS,  and  F/M values.
 Both  sets  were used.   For  Plant #296,  which recycled waste streams,  the MLSS,
 MLVSS,  and F/M values  for  each recycled  stream  were used.   For Plants #1389
 and #1038, -where  two sets  of BOD5  values were used,  two sets  of MLSS,  MLVSS,
 and F/M values were also used.

      Based on  these rules,  average MLSS,  MLVSS,  and F/M values are as  follows:
         HLSS  (mg/1)
     Summer
     4634
Winter
4950
                  MLVSS (mg/1)
Summer
3003
Winter
3444
Summer
1.024
F/M
 Winter
 0.863
     An attempt was made to correlate the summer and winter values for MLSS,
MLVSS, and F/M to the summer and winter values for BOD5 removal efficiency.
This exercise yielded no conclusive results; the analysis found some plants
with poor winter performance to have higher MLSS concentrations and lower F/M
ratios (which should help to compensate for lower temperatures), while other
poor winter performers had the opposite trend in operating conditions.  There
also appeared to be no correlation between plant location (northern or
                                   VII-100

-------
southern) and seasonal operating parameters.  This exercise also found plants
in northern climates achieving high year-round performance with very little
variation in seasonal MLSS, MLVSS, and F/M values.  Therefore, it seems that
good plant performance is a function of a combination of factors (including
system design, operating parameters, and operating procedures) whose separate
contributions cannot be readily determined based on the level of information
gathered in this segment of the Section 308 Questionnaire.

Operational Changes
     Two plants (948 and 2394) were identified as having made operational or
process changes in an effort to improve efficiency and provide at least
partial compensation for temperature.

     Plant #948, which has a warm process effluent, has instituted several
operational changes in winter months to improve  the performance of its
biological treatment system.  First, it turns off some of  its cooling towers
to compensate for greater heat loss during winter months.  The facility also
decreases the number of aerators  by 5  percent since there  is significant heat
loss during the aeration process.  The MLSS level and sludge age are increased
by decreasing the sludge wastage  rate.  These measures increase  the sludge's
capacity  to oxidize and metabolically  assimilate organic material.  A disad-
vantage of the increased sludge age is that sludge settling characteristics
are adversely affected.  The plant  largely  compensates for this  by increasing
the pplyelectrolyte dosage  to  the influent  to the clarifier in the winter.

     A second facility, Plant  #2394, has  also instituted process modifications
to improve the performance  of  its activated sludge system  in  the winter.   In
the summer,-the plant  uses  a preaeration  basin  followed by a  single stage
activated sludge unit  and  secondary elarifiers.   In  the summer,  sludge  from
the elarifiers  is  recycled  ,to  the activated sludge unit.   In  the winter,
sludge from  the elarifiers  is  recycled to the preaeration  unit,  thus  con-
verting  it.into a  second  biological unit.   In summary,  the installation of
additional piping  to  allow flexibility in the sludge  recycle  point allows  the
plant  to have a one-stage  biological  treatment  system in  the  summer and a
 two-stage system  in the winter.
                                    VII-101

-------
      Data are not available for Plant #948 to correlate its operational
 changes with removal efficiency.   Monthly monitoring data are available for
 Plant 12394, although the plant was excluded from the 21-plant data base for
 calculating BPT variability factors because the treatment system was modified
 during the period of record and the effluent data were collected after  terti-
 ary treatment.   Monthly BOD5 influent and effluent levels (IBOD5 and EBOD ),
 TSS effluent levels  (ETSS),  and removal efficiencies for Plant #2394 are
 presented in Table VII-34 for the period December 1981 to March 1984.   The
 results are inconclusive.   They show reduced efficiency during the months of
 January and February.   They also  show an efficiency increase of 19 percent
 between January 1982 and January  1983,  and an increase of 13 percent between
 February 1982 and February 1983.   The efficiency for January 1984 then  drops
 by  7  percent from the preceding January,  but the February 1984 efficiency of
 95  percent  is the same as  the efficiency of the preceding February.   The sharp
 efficiency  increase  between  winter 1982 and winter 1983 suggests the effec-
 tiveness of the operational  changes,  but  the reasons for the decrease between
 January 1983 and January 1984 cannot  be determined from the  available data.
 It  is  not known if production changes occurred  during that  period.

 Conclusion
     Results  of the  BOD5 removal  efficiency,  BOD5  effluent,  and  operational
 changes  analyses  performed above  show a slight  reduction in  efficiency  at  some
 plants  during the months of  January"and February.   Efficiencies  vary widely
 among  plants, and many plants  have  attained  efficiencies  of  95  percent  or
 greater  for  all months  of  the  year.   This  suggests  that  the  plants with lower
 efficiencies  are  affected as much by  inefficient operating practices as  by
winter  temperature considerations.  Adoption  of  certain  practices used  by
 plants with higher winter efficiencies  by  these  plants  should  result in
 improved winter efficiency.

     Technologies and operating techniques exist that,  if properly applied,
can compensate for temperature.   Plants operating in cold weather conditions
should recognize  that excessive storage prior to treatment may reduce the
 temperature of the biotreatment system.  Cold weather operation may require
insulation of treatment units, covering of open  tanks, and tracing of chemical
                                   VII-102

-------
       TABLE VII-34.
MONTHLY DATA FOR PLANT #2394

1981
1982











1983











1984



December
January
February
March
April
May
June
July
August
September
October
November
December
January
February
March
April
May
June
July
Augus t
September
October
November
December
January
February
March
Average
Influent
BOD
(mg/1)
396
311
475
484
468
364
416
350
608
427
570
530
521
377
457
420
387?
404
436
332
474
364
415
388
351
295
397
354
Average
Effluent
BOD
(mg/1)
59
76
84
38
1 9
5
5
2
2
3
9
9
14
20
21
13
8
'5
4
3
3
3 .
4
8
11
35
21
15
Average
Effluent
TSS
(mg/1)
26
20
20
22
24
14
19
13
8
7
8
10
15
15
14
14
22
17
17
13
8
10
13
21
15
24
25
26
BOD5
Removal
Efficiency
(%)
0.85
0.76
0.82
0.92
0.98
0.99
0.99
0.99
1.00
0.99
0.98
0.98
0.97
0.95
0.95
0.97
0.98
0.99
0.99 ' •• •'
0.99 ,
0.99
0.99
0.99
0.98
0.97
0.88
• 0.95
0.96
           VII-103

-------
feed lines.  Insulation may include installing  tanks in  the ground rather than
aboveground, using soil around  the walls of aboveground  units, or enclosing
treatment units.  During colder periods, maintenance of  higher MLSS concen-
trations and suitable, reduced F/M may be necessary.  Plant-specific
techniques, such as those used at Plants #948 and #2394, should also be
applied.

     Another case study, cited in vendor literature, discusses cold weather
modifications for a biological treatment system at a West Virginia polyester
resin manufacturer.  During the winter, the plant uses its equalization basin
for biological contact stabilization before the wastewater enters the
biological aeration basin.  The plant replaced some of its aerators with
mechanical aerators especially designed for cold weather operation and added
similar aerators to the equalization basin for winter use.  The new aerators
designed specifically for winter conditions provide "aeration, mixing, and 02
transfer without the temperature loss of conventional aerators during cold
weather."  The West Virginia facility now achieves "a 99 percent BOD removal,
with influent BOD at 2,500 mg/1 and effluent at 20 mg/l~even in the winter."
Part of the improvement in effluent quality was attributed to warmer basin
temperature (7-13).

     Two other points should be made.  First, temperature is only one of many
factors that impacts wastewater treatment performance.  Waste load variations,
biomass acclimation, flow variations, waste treatability, and temperature of
the wastewater as well as adequacy of treatment system design and operation
must all be considered.  The interaction among these factors makes it diffi-
cult to isolate any one factor separately.  Temperature considerations must be
viewed as specific to a given site in the context of these factors, rather
than as specific to a given geographic area.

     Secondly, EPA has taken the cost of improving winter efficiency into
account by using the minimum State temperature in the K-rate equation for
estimating costs for full-scale and second-stage biological systems and by
adding a cost factor for biological upgrades.  The cost factor ranges from
1.0 to 2.0 and is also based upon a State's minimum average ambient
temperature.  Both State minimum temperature and the biological upgrade cost
factor are discussed in more detail in Section VIII.
                                   VII-104

-------
     4.  Polishing and Tertiary Treatment Technologies
     Polishing technologies consist of polishing ponds, filtration, and
chemically assisted clarification (CAC).  Tertiary treatment includes only
activated carbon treatment.

         a.  Polishing Ponds
     Polishing ponds are bodies of wastewater, generally limited  to 2 to
3 feet in depth, used for the removal of residual suspended solids by
sedimentation.  They are usually used as a tertiary treatment step following
biological treatment.  Depending on the nature of the pollutant to be removed
and the degree of removal required, the polishing treatment system can consist
of one unit operation or multiple unit operations in series.

    , According to the Section 308 Questionnaire data base, 64 OCPSF plants
reported using polishing ponds as an end-of-pipe treatment.  Originally, 18 of
these 64 plants were used to establish treatment performance limits for BPT
Option II.  However, following the December 9, 1986, Federal Register Notice
of Availability, the Agency carefully reviewed the BPT data base  identifying
plants that reported having polishing ponds, and evaluated the data that they
provided.  The 18 plants used to calculate BPT Option II effluent limitations
met the preliminary BFT effluent criteria, which was 95 percent removal of
BOD5 across the treatment system or an effluent BOD5 concentration equal to or
less than 50 mg/1 and an effluent TSS concentration .equal to or less than
100 mg/1.

     The Agency reviewed the information provided in response to  the Section
308 Questionnaires and contacted permit writers in the Regions and/or States
in which the facilities were located.  The results of this effort identified
16 of the 18 plants as not containing BPT Option II treatment systems.  Only
two plants are actually using their ponds as a final polishing step to remove
suspended solids and BOD5 from the effluent produced by a biological system
operating at a BPT Option I level.  A summary of the results of this evalu-
ation is given in Table VII-35.  A' description of the 16 plants without the
BPT Option II technology follows.  Seven of the 16 plants combine treated
wastewater from the biological treatment system with other wastewaters in a
                                   VII-105

-------
                                TABLE VII-35.
                      MATRIX OF 18 PLANTS WITH POLISHING
              PONDS USED AS BASIS FOR BPT OPTION II LIMITATIONS
Plant ID
157
267
284
384
500
811
866
948
990
1020
1061
1438
1695
1698
1717
2471
2528
4017
Pond
Serves as
Equalization
Basin
X
X
X
X
X
X
X
Pond Pond Pond Pond
Serves as Serves as Known to Serves as
Secondary Reaeration Have Algae a Final
Clarifier Basin Problem Polish
X
X
X
X
X
X
X
X
X
X
X
TOTAL
                                  VII-106

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final pond.  Since these ponds mix different wastewaters, they achieve some
dilution of treated process wastewater prior to discharge.  Because the actual
removal of the pollutants through biodegradation or settling cannot be
demonstrated, these ponds cannot be characterized as polishing ponds.  Another
plant uses a "polishing pond" as a reaeration basin to increase the level of
dissolved oxygen (DO) in its effluent and to prevent a depressed oxygen level
from occurring in the receiving stream.  Finally, one plant is known to have
an algae problem associated with its pond operation during the summer months,
that indicates that this plant may not be meeting the BPT Option II criteria
during part of the year.

     As for the remaining 30 plants that reported having polishing ponds that
were not used to form the basis for the BPT Option II limits, four plants that
reported effluent BOD5, TSS, and flow data did not meet the BPT Option II
criteria.  Fifteen plants did not report any BOD5 or TSS data;  seven of these
15 plants use their ponds as a secondary clarification step, and six plants
use their ponds as a final mixing step.  The remaining 11 plants were not used
because three plants have BPT Option III treatment (filtration); one plant
recycles water back to its production processes from the pond; one plant is an
indirect discharger; two plants discharge from their polishing ponds into
subsequent treatment stages; and four plants do not use biological treatment.
Based on the above information, the Agency concluded that the use of polishing
ponds to provide additional removal ,of conventional pollutants (BODg and TSS)
beyond that achievable by well-designed and well-operated biological treatment
(Option I) is not successfully demonstrated in the OCPSF industry.

         b.  Filtration
     Filtration is an established unit operation for achieving the removal -of
suspended solids from wastewaters.  The removal is accomplished by the passage
of water through a physically restrictive medium (e.g., sand, coal, garnet, or
diatomaceous earth) with resulting entrapment of suspended particulate matter
by a complex process involving one or more removal mechanisms, such as
straining, sedimentation, interception, impaction, and adsorption.  Continued
filtration reduces the porosity of the bed as particulate matter removed from
the wastewater accumulates on the surface of the grains of the media and in
                                    VII-107

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 the pore spaces between grains.   This reduces the filtration rate and
 increases the head loss across the filter bed.   The solids must be removed by
 "backwashing" when the head loss increases to a limiting value.  Backwashing
 involves forcing wash water through the filter bed in the reverse direction of
 the original fluid flow so that  the solids are dislodged from the granular
 particles and are discharged in  the spent wash water.   When backwashing is
 completed,  the filter is returned to service.

      Filtration is an established -wastewater treatment technology currently in
 full-scale  use for industrial waste treatment.   Filtration has several
 applications:   1)  pretreatment to remove suspended solids prior to processes
 such  as  activated carbon adsorption,  steam stripping,  ion exchange,  and
 chemical oxidation;  2)  removal of residual biological  floe from settled
 treatment process  effluents;  3)  removal of residual chemically coagulated  floe
 from  physical/chemical  treatment process effluents;  and 4) removal of oil  from
 oil separation and dissolved air flotation effluents.

      According to  the Section 308 Questionnaire data base,  41  OCPSF  plants use
 filtration  as  a polishing technology.   EPA evaluated BPT Option III  (bio-
 logical  treatment  plus  multimedia filtration)  technology to determine if this
 option could achieve, in'°a practicable  manner,  additional conventional pollu-
 tant  removal beyond  that  achievable by  well-designed,  well-operated  biological
 treatment with secondary  clarification.   Eleven plants in the  BPT  data base
 use BPT  Option III  technology and meet  the final BPT editing criteria.  Thus,
 this  option would  require EPA to regulate all seven  subcategories  based upon a
 very  small  data set.  As  shown in Table VII-36,  the  median effluent  TSS
 concentration  value  for  these plants  is 32 mg/1.   Even if three  additional
 plants are  included  in  this  data base because they use Option  I  treatment  plus
 either ponds or  activated carbon followed  by1filters,  the resulting  median TSS
 value is  34 mg/1.  These  results,  when  compared  to the performance of
 clarification  only following  biological treatment  (median value  of 30  mg/1),
 clearly  show that  the efficiency of filtration  following  good  biological
 treatment and  clarification  is not  demonstrated for  this  industry.   Moreover,
on  the average,  OCPSF plants  with  more  than Option I treatment in EPA's data
base  (biological treatment plus  filtration) have not demonstrated significant
BOD5 removal beyond  that  achievable by  Option I treatment alone.  The median
                                   VII-108

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                        TABLE VII-36.
      OPTION III OCPSF PLANTS WITH BIOLOGICAL TREATMENT
PLUS FILTRATION TECHNOLOGY THAT PASS THE BPT EDITING CRITERIA
Plant ID
2551
1943
102
2536
883
2376
1343
2328
909
1148
844
Median value
Effluent TSS
(mg/1)
9
16
18
18
27
32
36
37
41
46
54
32
Effluent BOD
(mg/1)
11
22
7
3
20
27
8
19
21
37
5
19
                            VII-109

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concentration value for these plants is 19 mg/1 compared to a median
 BOD,
 value of 23 mg/1 BOD5 for the plants with Option I technology in place which
 meet the 95 percent/40 mg/1 BOD5 editing criteria.  Therefore, EPA does not
 believe that the data support any firm estimate of incremental pollutant
 removal benefits and incremental costs for BPT Option III.

      One commenter suggested that, in light of the apparent poor incremental
 performance of filters in the OCPSF industry, EPA should transfer data from
 non-OCPSF filtration operations, specifically from domestic sewage treatment.
 EPA has evaluated the additional removal achievable by multimedia filtration
 on the effluent from the biological treatment of domestic sewage.  Data found
 in EPA's "Process Design Manual for Suspended Solids  Removal" (EPA 625/1-
 75-003,  January 1975) indicates that multimedia filtration achieves a median
 of 62 percent  removal of TSS from biological treatment effluent  TSS levels of
 25 mg/1 or  less.

      The Agency also considered transferring multimedia filtration performance
 data from the  pharmaceutical manufacturing  point  source category for use  in
 the development of BPT Option III (biological treatment plus  filtration)
 limitations.   Daily data across multimedia  filtration systems at three
 pharmaceutical  plants demonstrated  that  effluent  concentrations  of  TSS from
 advanced biological treatment in that  industry could  be reduced  by  50 percent
 over a  15 to 100  mg/1 influent  concentration range  by multimedia filtration
 (no removal of  BOD5  across multimedia  filtration  was  demonstrated).   This
 concentration range covers the  range of  performance of OCPSF  plants  that meet
 the Agency's Option I 95  percent/40 mg/1  (BOD5) and 100 mg/1  (TSS)  editing
 criteria to define  well-designed and well-operated biological  treatment.

      However, the OCPSF industry filtration  data  do not  indicate any
 substantial TSS or BOD5 removal  beyond that  achieved  by  Option I  technology.
 This  indicates  that differences  in the biological solids in the OCPSF  industry
 may  be responsible for the lack  of filtration effectiveness.  For example,  if
 the OCPSF biological  floe (solids) were to break into  smaller sized or
 colloidal particles,  they could  pass through the filter substantially
untreated.   While EPA cannot be  certain.whether this occurs, the data  indicate
                             VII-110

-------
that filters in this industry are not as effective in removing OCPSF waste-
water solids as they may be for domestic sewage or certain other industry
wastewater solids.  EPA does not believe that the appropriateness of
transferring data from these other wastewaters to the OCPSF industry is
demonstrated.

         c.  Chemically Assisted Clarification (GAG)
     Coagulants are added to clarifiers (chemically assisted clarifiers) to
enhance liquid-solid separation, permitting solids denser  than water to settle
to  the bottom and materials less dense than water (including oil and grease)
to  flow to the surface.  Settled solids form a sludge at the bottom of the
clarifier, which can be pumped out continuously or intermittently.  Oil and
grease and other floating materials may be skimmed off  the surface.

     Chemically assisted clarification may be used alone or as part of a more
complex treatment process.  It may also be used as:

     •  The  first process applied  to  wastewater containing high  levels of
        settleable  suspended solids.
     •  The  second  stage of most biological  treatment processes  to  remove  the
        settleable  materials,  including microorganisms,  from  the wastewater;
        the  microorganisms can then be either recycled  to  the  biological
        reactor or  discharged  to the  plant's sludge handling  facilities.
     9  The  final stage of most chemical  precipitation  (coagulation/
        flocculation)  processes  to remove the  inorganic floes  from  the
        wastewater.

     As discussed  in Section VIII,  chemically  assisted  clarification  was  a
 component  of the  model wastewater  treatment  technology  for estimating the BPT
 engineering  costs  of compliance.   First,  when  biological treatment  was  in
 place  (with  or without secondary  clarification),  an additional chemically
 assisted  clarification unit  operation iwas costed  if the reported TSS  effluent
 concentration was more than  3  mg/1 above  the plant's  long-term average
 compliance target.   Second,  for plants  that  do not need biological treatment
 to comply with their BOD5  compliance targets,  chemically assisted clarifi-
 cation unit  operations were  costed if the reported TSS effluent concentrations
 were more than 3 mg/1 above  the long-term average compliance target.
                                     VII-111

-------
      Although chemical addition was not frequently reported by plants in the
 OCPSF industry, chemically assisted clarification is a proven technology for
 the removal of BOD5 and TSS in a variety of industrial categories, partic-
 ularly in the pulp and paper industry.  Case studies of full-, pilot-, and
 laboratory-scale chemically assisted clarification systems in the pulp and
 paper industry as well as other industrial point source categories are
 discussed in the following sections.

 Full-Scale Systems
      Several full-scale,  chemically assisted clarification systems have been
 constructed in the pulp,  paper,  and paperboard industry and in other indus-
 trial point source categories.   Data on the capability of full-scale systems
 to  remove conventional pollutants are presented below.

      Recent experience with full-scale,  alum-assisted clarification of
 biologically treated kraft mill  effluent suggests  that  final effluent  levels
 of  15 mg/1 each of BODg and TSS  can be achieved.   The desired alum dosage  to
 attain these levels can be expected to vary depending on the chemistry of  the
 wastewater to be treated.   The optimum chemical dosage  is dependent on pH.

      Chemical clarification following activated sludge  treatment  is currently
 being employed  at  a groundwood (chemi-mechanical)  mill.   According to  data
 provided  by mill personnel,  alum is added  at a dosage .of about  150 mg/1  to
 bring the pH to an optimum level of 6.1.   Polyelectrolyte is  also  added  at  a
 rate  of 0.9  to  1.0 mg/1 to improve  flocculation.

      Neutralization using  NaOH is practiced prior  to  final discharge to  bring
 the pH within acceptable discharge  limits.  The  chemical/biological solids  are
 recycled  through the activated sludge system with  no  observed adverse  effects
 on biological organisms.   Average reported results for 12 months of sampling
 data  (as  supplied  by mill  personnel)  show a raw wastewater to final effluent
BOD5  reduction  of  426  to 12 mg/1, and TSS reduction of 186 to 12 mg/1.
                                   VII-112

-------
     Treatment system performance at the mill was evaluated as part of a study
conducted for the EPA (7-14).  Data obtained over 22 months show average final
effluent BOD5 and TSS concentrations of 13 and 11 mg/1, respectively.  As part
of this study, four full-scale chemically assisted clarification systems in
other industries were evaluated.  Alum coagulation at a canned soup and juice
plant reduced final effluent BOD5 concentrations from 20 to 11 mg/1, and TSS
levels from 65 to 22 mg/1.  Twenty-five mg/1 of alum plus 0.5 mg/1 of poly-
electrolyte are added to the biologically treated wastewater to achieve these
final effluent levels.  Treatment plant performance was evaluated at a winery
where biological treatment followed by chemically assisted clarification was
installed.  Final effluent levels of 39.6 mg/1 BOD5 and 15.2 mg/1 TSS from a
raw wastewater of 2,368 mg/1 BOD5 and 4,069 mg/1 TSS were achieved. The
influent wastewater concentrations  to the clarification process were not
reported.  The chemical dosage was  10 to 15 mg/1 of polymer (7-14).  A
detailed summary of the results  of  the study of full-scale systems  is pre-
sented in Table VII-37 (7-14).

     In October'1979, operation  of  a full-scale chemically assisted
clarification system  treating effluent from an aerated stabilization basin at
a northeastern bleached kraft mill  began.  This plant was designed  and
constructed  after completion of  extensive pilot-scale  studies.  The purpose of
the  pilot plant was to demonstrate  that proposed water quality  limitations
could  be met  through  the  use of  chemically assisted clarification.'  After
demonstrating that  it was  possible  to meet  the proposed  levels, studies were
conducted to optimize chemical  dosages.  The  testing  conducted  showed  that  the
alum dosage  could be  reduced significantly  by  the  addition  of acid  for  pH
control, while  still  attaining  substantial  TSS removal.   In the pilot-scale
study,  it was shown that  total  alkalinity,  a  measure  of  a system's  buffering
capacity, was a reliable  indicator  of wastewater variations and treatability.
Through this study,  a direct relationship between  total  alkalinity and  alum
demand was  shown.   High  alkalinity  (up  to 500 mg/1)  caused by the discharge of
 black liquor or lime mud  results in high alum demands.   Therefore,  a sub-
 stantial portion of alum dosage can be used as an  expensive and ineffective
 means of reducing alkalinity (pH) to the effective pH point (5  to 6) for
 optimum coagulation.   The use of acid to assist  in pH optimization can mean
 substantial cost savings and reduction in the alum dosage rate  required to
                                    VII-113

-------
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effect coagulation.  In one instance, use of concentrated sulfuric acid for pH
reduction decreased alum demand by 45 percent.  Acid addition was also
effective in reducing alum dosage for wastewaters with low alkalinity
(approximately 175 mg/1) (7-15).

     Table VII-38 summarizes effluent quality of the full-scale system since
startup; this system has been operated at an approximate alum dosage rate of
350 mg/1 without acid addition.  Recent correspondence with a mill represen-
tative indicated that, with acid addition,  this dosage rate could be reduced
to 150 mg/1  (7-16).  However, this lower dosage rate has not been confirmed by
long-term operation.

      Scott et al.  (7-17) reported on a cellulose mill located on  the shore of
Lake  Baikal  in  the USSR.   The mill currently  produces 200,000 kkg  (220,000
tons) of  tire cord cellulose and  11,000 kkg (12,100 tons)  of kraft  pulp per
year.  Average  water usage is  1,000  kl/kkg  (240 kgal/t).   The mill  has  strong
and weak  wastewater collection  and  treatment  systems.  The average  BOD5  for
the weak  wastewater system is  100 mg/1, while the  strong wastewater BOD5 is
400 mg/1.  Only 20 percent of  the total wastewater flow  is included in  the
strong wastewater  system.   Each stream receives  preliminary treatment  con-
sisting  of'neutralization  of  pH to  7.0,  nutrient  addition, and  aerated
equalization.   Effluent from  equalization is  discharged  to separate aeration ,
and  clarification  basins.   These basins  provide biological treatment using a
 conventional activated sludge operation.   Aeration is followed  by secondary
 clarification.   Suspended  solids are settled, and 50 percent of the sludge is
 returned to the aeration process.  Waste sludge is discharged to lagoons.  The
 separate streams are combined after clarification and are treated for color
 and'suspended solids removal in reactor clarifiers with 250 to 300 mg/1 of
 alum and 1  to 2 mg/1 of polyacrylamide flocculant, a nonionic polymer.   The
 clarifiers  have an overflow rate of approximately 20.4 m  per day/m
 (500 gpd/ft2).

      Chemical clarification overflow is discharged to a sand filtration
 system.  The sand beds are 2.9 m (9.6 ft)  deep with the media arranged  in five
 layers (7-18).  The sand  size varies from  1.3 mm  (0.05  in) at-the  top  to 33 mm
 (1.3 in) at the bottom.   The filter is loaded at  0.11 m3  per minute/m
                                     VII-115,

-------
                               TABLE VII-38.
              FINAL EFFLUENT QUALITY OF A CHEMICALLY ASSISTED
          CLARIFICATION SYSTEM TREATING BLEACHED KRAFT WASTEWATER
Date
 Average
for Month
                         BOD. (mg/1)
                               Maximum Day
 Average
for Month
                                     TSS (mg/1)
                                         Maximum Day
September 1979
October 1979
November 1979
December 1979
January 1980
February 1980
March 1980
April 1980
May 1980
11
8
9
21
8
7
13
9
11
21
12
18
83
16
14
46
16
22
87
40
28
21
28
31
44
32
38
254
92
47
56
36
68 -
113
96,
80
                                VII-116

-------
(2.7 gpm/ft2).  Effluent from sand filtration flows to a settling basin and
then to an aeration basin; both basins are operated in series and provide a
7r-hour detention time.
     The effluent quality attained is as follows:
     Parameter                  ". Raw Waste
     BOD5 (mg/1)                    300
     Suspended Solids (mg/1)         60
     PH                              -
Final Effluent
      2
  •  '• 5
  6.8 - 7.0
Individual treatment units are not monitored for specific pollutant
parameters.                                                        '

Pilot- and Laboratory-Scale Systems   ,
     Several laboratory- and pilot-scale  studies of  the  application  of
chemically assisted clarification have  been conducted.   Available  data  on  this
technology to  remove conventional pollutants based on  laboratory-  and pilot-
scale studies  are  presented below.

     As  part of  a  study of various solids reduction  techniques,  Great Southern
Paper Co. supported a  pilot-scale study of chemically  assisted clarification
(7-19).  Great Southern operates an  integrated unbleached kraft mill,
Treatment consists of  primary  clarification and aerated  stabilization followed
by  a holding pond. The average  suspended solids in  the  discharge  from  the
holding  pond were  65 mg/1  for  the period  January 1,  1973,  to December 31,
1974.  In  tests  on this wastewater,  70  to 100  mg/1  of  alum  at a pH of 4.5
provided optimum dosages;  the  removals  after  24 hours  of settling  ranged from
83  to 86 percent.   Influent  TSS  of  the  sample tested was 78 mg/1.   Effluent
TSS concentrations ranged  from 11  to 13 mg/1;

   -  In  a  recent EPA-sponsored laboratory study, alum, ferric chloride, and
 lime in  combination with  five  polymers, were  evaluated  in further treatment of
 biological effluents  from four pulp and paper mills (7-20).  Of the three
 chemical coagulants,  alum provided  the most  consistent flocculation at  minimum
 dosages, while lime was the least  effective of the three.   However, the study
                                    VII-117

-------
  provides the optimum chemical dosage for removal of TSS from biologically
  treated  effluents.   These, inconclusive findings  are the result  of a number  of
  factors,  including  the lack of determination  of  optimum pH  to effect removal
  of TSS;  the  lack of consideration  of higher chemical dosages when performing
  laboratory tests even though data  for some mills indicated  that  better  removal
  of TSS was possible with  higher chemical dosage  (a  dosage of 240 mg/1 was the
  maximum  considered  for alum and ferric chloride,  while  200  mg/1  was  the
  maximum  dosage used for lime);  the  testing of effluent  from one  mill where  the
  TSS concentration was  4 mg/1 prior  to the addition  of chemicals;  and the elim-
  ination  of data  based  simply on a visual determination  of proper  flocculation
  characteristics.

      Laboratory data on alum  dosage  rates for chemically assisted
 clarification have been submitted to  the Agency  in  comments on the pulp,
 paper, and paperboard contractor's draft report  (7-21).   Data submitted for
 bleached and  unbleached kraft pulp and paper wastewaters indicate that
 significant removals of suspended solids occur at alum dosages in the range of
 100 to 350 mg/1 (7-22, 7-23, 7-24).  For wastewaters resulting from the
 manufacture of dissolving 'sulfite pulp, effluent  BOD5 and TSS data were
 submitted for dosage rates of 250 mg/1; however,  it  was  stated that dosages
 required  to achieve  an effluent TSS concentration on the order of 15 mg/1
 would  be  in the range of 250 to 500 mg/1 (7-25).   During the pulp, paper,  and
 paperboard rulemaking, NCASI assembled jar test data for several process types
 and submitted it  to  the Agency (7-26).  Data for  chemical pulping subcategories
 indicated that alum  dosages in the  range of 50 to 700 mg/1 will  effect
 significant removals of TSS.   The average dosage  rate for all chemical  pulping
 wastewaters was 282  mg/1.   Data submitted for  the groundwood,  deink,  and
 nonintegrated-fine papers  subcategories indicate  that dosages in  the  range of
 100 to 200 mg/1 .will significantly  reduce effluent TSS.

     Data on  the  frequency of this  technology are not  available for  the OCPSF
 industry  although data  on  the frequency of other  similar  technologies
 (coagulation,   flocculation,  clarification, chemical  precipitation) have been
 previously presented.   However,  based  upon the above information and  upon the
general performance of  clarifiers in  treating TSS, EPA has concluded  that
 chemically assisted clarification can  treat TSS in non-end-of-pipe biological
plants to meet the BPT TSS limits.
                                   VII-118

-------
         d.  Activated Carbon Adsorption
     Activated carbon adsorption  is a  physical separation  process  in which
organic and  inorganic materials are removed  from wastewater  by  sorption or  the
attraction and accumulation  of one substance on,the  surface  of  another.   There
are  essentially  three consecutive steps  in the sorption of dissolved materials
in wastewater by activated carbon.  The  first step is the  transport of the
solute through a surface film  to  the: exterior of  the carbon. The  second step
is  the diffusion of solute within the pores of  the activated carbon.   The
third  and  final  step is  sorption  of  the  solute  on the interior  surface bound-
ing the pore and capillary spaces of  the activated carbon, ,While  the  primary
removal mechanism is adsorption,  biological degradation and  filtration also
may reduce the  organics  in the solution.

      Activated  carbon is considered to be a non-polar sorbent and tends to
.sorb the least.polar and least soluble organic compounds;  it will sorb most,
 but not all, organic compounds.   As activated carbon adsorbs organics from
 wastewater,  the carbon pores eventually become saturated and the exhausted
 carbon must be regenerated for reuse or replaced with fresh;carbon.  The
 adsorptive capacity of the carbon can be  restored by chemical or  thermal
 regeneration.                                           :_•'-••
                                          s               t f ;,  * '.    -    '
      There are  two  forms  of activated carbon in common  use—granular  and
 powdered.  Granular carbon  is generally preferred for.most  wastewater applica-
 tions because it  can be  readily  regenerated.  The two  forms of  carbon used  and
 different process configurations are  described below.

       Granular Activated  Carbon.  Granular carbon  is about 0.1  to  1 mm in
 diameter  and is contacted with wastewater in columns or beds.   The water to be
 treated is  either filtered  .down  (downflow)  or forced up (upflow)  through the
 carbon column or bed.   Additional design configurations of  carbon contact
 columns include gravity or  pressure  flow, fixed  or  moving beds, and single
  (parallel)  or multi-stage (series) arrangements.   In a typical downflow
  countercurrent  operation, two columns are operated.in series with a  common
  spare column.   When breakthrough occurs for the  second column  (i.e.,  the
  concentration  of a, target  pollutant in the effluent is higher than  the
                                     VII-119

-------
  desired concentration), the exhausted column is removed from service for
  regeneration of the  carbon.  The partially exhausted second column becomes
  the lead column, and the fresh spare column is added as a second column in the
  series.  When breakthrough is again reached, the cycle is repeated.  The fixed
  bed downflow  operation, in addition to adsorption,  provides filtration but
  may require frequent backwashing.   In an upflow configuration,  the exhausted
  carbon is removed at the bottom of the column,  and virgin or regenerated
  carbon is added at the top,  thereby providing countercurrent contact  in a
  single vessel.

      Powdered Activated  Carbon.  Powdered  carbon is  about  50 to  70 microns  in
  diameter  and is  usually  mixed with  the wastewater  to be  treated.   This
  "slurry"  of carbon and wastewater is  then  agitated to allow  proper contact.
  Finally,  the spent carbon carrying  the adsorbed  impurities is  settled  out  or
  filtered.  In practice,  a multi-stage, countercurrent  process is commonly used
  to make the most efficient use of the  carbon's capacity.

      Carbon adsorption systems have been demonstrated as practical and
 economical for the reduction of dissolved organic and  toxic pollutants  from
 industrial wastewaters.  Activated carbon can be used  to remove chemical
 oxygen demand (COD),  biochemical oxygen demand (BOD), and related parameters;
 to remove toxic and refractory organics;  to remove and recover certain
 organics;  and to remove selected inorganic chemicals  from industrial waste-
 water.   Compounds that are readily  removed by activated carbon include
 aromatics, phenolics, chlorinated hydrocarbons,  surfactants,  organic dyes,
 organic acids,  higher molecular  weight alcohols,  and  amines.   Activated  carbon
 can also be used to remove selected  inorganic chemicals,  such as  cyanide,
 chromium,  and mercury.  A summary of classes  of  organic compounds adsorbed  on
 carbon  are presented  in Table VII-39,  and a summary of carbon adsorption
 capacities (the  milligram of  compound  adsorbed per gram of  carbon)  is
 presented  for powdered carbon in  Table  VII-40.

     The major benefits of carbon treatment involve its applicability  to a
wide variety of organics  and  its high removal efficiencies.  The system  is
compact, and recovery of  adsorbed materials is sometimes practical.  The
limitations of the  process include ineffective removal of low molecular weight
                                   VII-120

-------
                                TABLE VII-39.
               CLASSES OF ORGANIC COMPOUNDS ADSORBED ON CARBON
Organic Chemical Class
Examples of Chemical Class
Aromatic Hydrocarbons

Polynuclear Aromatics


Chlorinated Aromatics



Phenolics


Chlorinated Phenolics
 High  Molecular  Weight  Aliphatic
 and Branch  Chain Hydrocarbons*

 Chlorinated Aliphatic  Hydrocarbons
 High Molecular Weight Aliphatic
 Acids and Aromatic Acids*

 High Molecular Weight Aliphatic
 Amines and Aromatic Amines*

 High Molecular Weight Ketones,
 Esters, Ethers, and Alcohols*

 Surfactants

 Soluble Organic Dyes
benzene, toluene, xylene

naphthalene, anthracenes ,
biphenyls

chlorobenzene, polychlorinated
biphenyls, aldrin, endrin,
toxaphene, DDT

phenol, cre'sol,  resorcenol, and
polyphenyls

trichlorophenol,
pentachlorophenol

gasoline,  kerosene
 1,1,1-trichloroethane,
 trichloroethylene,  carbon
 tetrachloride,  perchloroethylene

 tar acids,  benzoic acid
 aniline,  toluene diamine


 hydroquinone, polyethylene
  glycol

 alkyl benzene sulfonates

 methylene blue, Indigo carmine
 *High Molecular Weight includes compounds in the range of 4 to 20 carbon atoms
                                     VII-121

-------
                                   TABLE  VII-40.
                      SUMMARY OF  CARBON ADSORPTION CAPACITIES
  Compound
  bis(2-Ethylhexyl)
      phthalate
  Butylbenzyl phthalate
  Heptachlor
  Heptachlor epoxide
  Endosulfan sulfate

  Endrin'
  Fluoranthene
  Aldrin
  PCB-1232
  beta-Endosulfan

  Dieldrin
 Hexachlorobenzene
 Anthracene
 4-Nitrobiphenyl

 Fluorene
 DDT
 2-Acetylaminofluorene
 alpha-BHC
 Anethole*

 3,3-Dichlorobenzidine
 2-Chloronaph thalene
 Phenylmercurie Acetate
 Hexachlorobutadiene
 gamtna-BHC (lindane)

 p-Nonylphenol
 4-Dimethylaminoazobenzene
 Chlordane
 PCB-1221
 DDE

 Acridine yellow*
 Benzidine dihydrochloride
 beta-BHC
N-Bu tylph thalate
N-Ni trosodiphenylamine
  Adsorption8
Capacity (mg/g)
                                             Compound
                         Adsorption*
                       Capacity (mg/g)
    11,300
     1,520
     1,220
     1,038
       686

       666
       664
       651
       630
       615

       606
       450
       376
       370

       330
       322
       318
      303
      300

      300
      280
      270
      258
      256

      250
      249
    ,  245
      242
      232

      230
      220
      220
      220
      220
  Phenanthrene•                 215
  Dimethylphenylcarbinol*       210
  4-Aminobiphenyl               200
  beta-Naphthol*                200
  alpha-Endosulfan              194
  Acenaphthene                  190
  4,4' Methylene-bis-
      (2-chloroaniline)        190
  Benzo(k)fluoranthene          181
  Acridine orange               180
  alpha-Naphthol                IQQ

  4,6-Dinitro-o-cresol          169
  alpha-Naphthylamine           160
  2,4-Dichlorophenol            157
  1,2,4-Trichlorobenzene        157
 2,4,6-Trichlorophenol         155

 beta-Naphthylamine           150
 Pentachlorophenol            150
 2,4-Dinitrotoluene           146
 2,6-Dinitrotoluene           145
 4-Bromophenyl  phenyl  ether   144

 p-Nitroaniline*               140
 1,1-Diphenylhydrazine        135
 Naphthalene                   132
 l-Chloro-2-nitrobenzene       130
 1,2-Dichlorobenzene           129

 p-Chlorometacresol            124
 1,4-Dichlorobenzene           121
 Benzothiazole*                120
 Diphenylamine                 120
 Guanine*                      120

 Styrene                       12Q
 1,3-Dichlorobenzene           118
Acenaphthylene                115
4-Chlorophenyl phenyl ether   111
Diethyl phthalate            no
                                   VII-122

-------
                                TABLE Vli-40.
             SUMMARY OF CARBON ADSORPTION CAPACITIES (Continued)
Compound
  Adsorption3
Capacity (mg/g)
 Compound
                                                                 Adsorption3
                                                               Capacity (mg/g)
2-Nitrophenol
Dimethyl phthalate
Hexachloroethane
Chlorobenzene
p-Xylene

2,4-Dimethylphenol
4-Nitrophenol
Acetophenone
1,2,3,4-Tetrahydro-
     naphthalene
Adenine*

Dibenzo(a,h)anthracene
Nitrobenzene
3,4-Benzofluoranthene
1,2-Dibromo-3-chloro-
     propane

Ethylbenzene
2-Chlorophenol
Tetrachloroethene
o-Anisidine*
5 Bromouracil

Benzo(a)pyrene
2,4-Dini trophenol
Isophorone
Trichloroethene
Thymine*
 Toluene
 5-Chlorouracil*
 N-Ni trosodi-n-propylamine
 bis(2-Chloroisopropyl)
      ether
 Phenol
        99
        97
        97
        91
        85

        78
        76
        74

        74
        7.1

        69
        68
        57

        53

        53
        51
        51
        50
        44

        34
        33
        32
        28
        27
         26
         25
         24

         24
         21
Bromoform                     20
Carbon tetrachloride          11°
bis(2-Chloroethoxy)
    methane                   H
Uracil*         .      .        11
Benzo(ghi)perylene            11

1,1,2,2-Tetrachloroethane     li
1,2-Dichloropropene          8.2
Dichlorobromomethane         7.9
Cyclohexanone*               6.2
1,2-Dichloropropane          5.9

1,1,2-Trichloroethane        5,-8
Trichlorofluorome thane       ->.6
5-Fluorouracil*              5.5
1,1-Dichloroethylene         4.9
Dibromochloromethane         4^8

2-Chloroethyl vinyl
      ether                   3.9
1,2-Dichloroethane          3.6
1,2-trans-Dichloroethene    3.1
Chloroform           '      ;  2.6
1,1,1-Trichloroethane       2.5
 1,1-Dichloroethane
 Acrylonitrile
 Methylene chloride
 Acrolein
 Cytosine*

 Benzene
 Ethylenediaminetetra-
      acetic acid
 Benzoic acid
 Chloroethane
 N-Dimethylnitrosamine
    1.8
    1.4
    1.3
    1.2
    1.1

    1.0

    0.86
    0.76
  '  0.59
6.8 x 10-5
                                     VII-123

-------
                                  TABLE VII-40.
               SUMMARY OF CARBON ADSORPTION CAPACITIES  (Continued)
                                  NOT ADSORBED
            Acetone cyanohydrin
            Butylamine
            Cyclohexylamine
            Ethanol
            Hydroquinone
            Triethanolamine
         Adipic acid
         Choline chloride
         Diethylene glycol
         Hexamethylenediamine
         Morpholine
Ion

Na+
K+
Ca++
Mg++
                     ^  "mineralized"  distilled  water  containing  the  following
Cone, (mg/1)

     92
     12.6
    100
     25.3
Ion

P04
S04
Cl-
Alkalinity
Cone, (mg/1)

     10
    100
    177
    200
Source:
                                                         concentration of
                            Isotherms for Toxic Organics."  MERL, April 1980.
                                  VII-124

-------
or highly soluble organics, low tolerance for suspended solids in the waste-
water, and relatively high capital and operating costs.  Preliminary treatment
to reduce suspended solids and to remove oil and grease will often improve the
effectiveness of the activated carbon system.

     Treatability tests should be performed on specific waste streams to
determine actual performance of an activated carbon unit.  The degree of
removal of different organic compounds varies depending on the nature of  the
adsorbate, the pH of the solution, the temperature of  the solution, and the
wastewater characteristics.  If the wastewater contains more  than one organic
compound, these compounds  may mutually enhance adsorption, may act relatively
independently, or may interfere.with one another.

      According to the Section 308 Questionnaire  data base, 21 OCPSF plants
reported  using carbon adsorption as a  tertiary treatment  technology.  Table
VII-41  presents  tertiary activated carbon  performance  data for an OCPSF plant
sampled during the  EPA  12-Plant Study.

E.    Total Treatment  System Performance
      1.   Introduction
      The  last two  sections presented  descriptions and  performance  data  for
 those in-plant and  end-of-pipe  treatment technologies  currently  used  or avail-
 able for  the reduction  and removal  of conventional,  nonconventional,  and
 priority  pollutants discharged  by the OCPSF industry.   The performance  data
 presented were primarily for those  pollutants that the technologies were
 primarily designed to remove.   For  example, BOD5 and TSS data were presented
 for activated sludge; metals data were presented for chemical precipitation;
 and volatile priority pollutant data were presented for steam stripping.

      This section discusses the removal of pollutants from all treatment
 technologies by presenting the performance of total treatment systems.   The
 treatment systems studied are those used  to promulgate the BPT and BAT
 effluent limitations.  In addition,- the performances  of those treatment
 systems within the OCPSF  industry that do not use biological treatment are
 also presented.
                                     VII-125

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                                 TABLE VII-41.
                   END-OF-PIPE CARBON ADSORPTION PERFORMANCE
                            DATA  FROM PLANT NO.  3033
 Pollutant
  Name
       Average
Influent Concentration
  to Activated Carbon
        (ug/1)
       Average
Effluent Concentration
from Activated Carbon
        (ug/1)
Bis(2-chloroethyl)ether  (18)

1,2-Dichloropropane  (32)

2,4-Dimethylphenol (34)

Methylene Chloride (44)
Phenol (65)

Bis(2-ethylexyl)Phthalate (66)
        13.64

        10.46

        13.92

        12.21

        11.42

        14.31
       10.00 (ND)

       10.00 (ND)

       10.00 (ND)

       11.46

       10.00 (ND)

       13.00
                                  VII-126

-------
     2.   BPT Treatment Systems
     EPA has promulgated concentration-based BPT effluent limitations based on
selected biological end-of-pipe technologies that are designed primarily to
address the conventional pollutants BOD5 and TSS.  These are supplemented by
those in-plant controls and technologies that are commonly used to assure the
proper and efficient operation of the end-of-pipe technologies, such as steam
stripping, activated carbon, chemical precipitation, cyanide destruction, and
in-plant biological treatment.  Activated sludge and aerated lagoons are the
primary examples of such biological treatment.

     The. performance of BPT treatment systems is represented by the  long-term
BOD  and TSS averages  for each subcategory  and  the overall maximum monthly and
daily maximum variability factors presented in  the limitations development
part of  this section.

     3.  Nonbiological Treatment  Systems
     Approximately 84  plants  rely exclusively upon end-of-pipe physical/
chemical treatment or  did not  report  any  in-place  treatment  at all.   These
facilities must  comply with the  BPT effluent limitations guidelines  based  on
biological treatment  system performance.   Some  of  these plants generate low
levels  of  BOD5,  thus  finding physical/chemical  treatment more  effective in
reducing TSS loadings.  Without  nutrient  addition,  biological  systems
generally cannot function unless influent BOD5  is  high enough  to  sustain their
biota.   Other plants  have determined, based on  an analysis of  the types and
volumes of pollutants that  they discharge,  that physical/chemical treatment is
more economical, easier to operate, or otherwise more appropriate.   Some of
 these plants can control conventional pollutants effectively without using the
 biological component of the BPT Option I technologies.  However,  other plants
 seem to rely on dilution of process wastewater prior to discharge rather than
 the appropriate Option I treatment.  A listing of available BOD5 and TSS
 effluent data and in-place controls reported by those plants with nonbiolog-
 ical treatment systems is presented in Table VII-42.  Forty-one of  the
 physical/chemical treatment only plants reported discharge BOD5 concentration
 data, and 46 provided TSS concentration data.  After adjusting the  reported
 wastewater concentration data for  non-process wastewater dilution,  29 percent
                                     VII-127

-------
                     TABLE VII-42.
TREATMENT TECHNOLOGIES FOR DIRECT NONBIOLOGICAL PLANTS*
Plant
ID
76
87
105
114
155

159



225


259
260
294
373

447
451

502
536
Effluent BOD.
(mg/1)
-
929
-
15
-

429



96


350
20
57
62

23,628
-

93
31
Effluent TSS
(rag/I) Type of Controls Reported
Neutralization
44 Equalization, neutralization, primary
clarification, carbon adsorption
Str-eam stripping, neutralization, primary
clarification
89 Filtration
282 Neutralization, API separation, dissolved
air flotation
Filtration, chemical precipitation, steam
stripping, equalization, coagulation,
neutralization, oil separation, primary
clarification, filtration, carbon adsorp-
tion, second stage of an indicated
treatment unit
s>
46 Steam stripping, distillation, equaliza-
tion, settling pond, neutralization,
screening, oil skimming
Filtration, coagulation, API separation,
surface impoundment
8 Cooling tower, API separation
119 Reuse for steam, coagulation, flocculation,
neutralization, oil separation, primary
clarification
155 Neutralization, oil separation, oil
skimming
22,898 Neutralization, filtration
Chemical precipitation, primary clarifi-
cation, flocculation
38 Water scrub, neutralization
1 Neutralization
                      VII-128

-------
                                TABLE VII-42.
           TREATMENT TECHNOLOGIES FOR DIRECT NONBIOLOGICAL PLANTS
                                 (Continued)
Plant  Effluent BOD5
  ID      (mg/1)
         Effluent TSS
            (mg/1)
                 Type of Controls Reported
 569

 614



 657


 663



 669



 709


 727




 775


 814



  819



  859


  876
16


 7



56



91


84
225


 90
          Steam stripping, primary clarification

          Distillation, equalization, acidification/
          aeration, neutralization, filtration,
          equalization

  17      Collection basin, neutralization, oil
          separation

  47      Equalization, flocculatioh, neutralization,
          dissolved air flotation, mechanical skim-
          ming, spray  cooling, polishing pond

  42      Filtration,  steam stripping, neutraliza-
          tion, oil skimming, dissolved air flota-
          tion, air stripping

  98      Settling pond,  neutralization, API separ-
          ation,  filtration, carbon  adsorption

  108      Equalization, flocculation,  chemical  pre-
          cipitation,  grit removal,  oil skimming,
          clarification,  air stripping,
          neutralization,  polishing  pond

    6      Chemical precipitation,  neutralization,
          primary clarification

          Carbon  adsorption, neutralization,  oil
          skimming,  oil separation,  API separation,
          coagulation, flocculation

  128      Chemical precipitation,  equalization, neu-
           tralization, oil separation, carbon adsorp-
           tion

4,369       Equalization, neutralization,  primary
           clarification

   76       Formaldehyde treatment,  carbon absorption,
           equalization, neutralization,  primary
           clarification
                                     VII-129

-------
                                 TABLE VII-42.
            TREATMENT TECHNOLOGIES FOR DIRECT NONBIOLOGICAL PLANTS*
                                  (Continued)
Plant  Effluent BOD,.
  ID       (mg/1)
           Effluent TSS
              (rag/1)
                Type of Controls Reported
 877

 913


 938
1618

1688


1774
  4

142


  8
                54


                27
942
962
991
992
1249
1439
1532
1569
71
17
-
-
-
302
110
18
66
25
-
-
-
1,463
-
44
11

46
 Dissolved air flotation

 Chemical oxidation, steam stripping, equal-
 ization, phase separation, neutralization

 Steam stripping, equalization, floccula-
 tion, hypochlorite addition, filtration,
 neutralization,  primary clarification,
 settling pond

 Steam stripping, neutralization,  oil skim-
 ming, primary clarification

 Equalization, primary clarification

 Solvent  decantation

 Distillation, equalization,  neutralization

 Equalization, neutralization

 Settling, solvent  extraction,  equalization,
 neutralization,  steam  stripping

 Steam stripping, mercury  treatment,  neu-
 tralization,  carbon adsorption

 Distillation, equalization, neutralization,
 primary clarification, blending and  air
 stripping, filtration

 Oil skimming

 Steam stripping,  equalization,  floccula-
 tion, neutralization,  primary clarification

Equalization, flocculation, neutralization,
primary clarification,  filtration
                                  VII-130

-------
                                TABLE VII-42.
           TREATMENT TECHNOLOGIES FOR DIRECT NONBIOLOGICAL PLANTS
                                 (Continued)
Plant  Effluent BOD.
  ID
(mg/1)
Effluent TSS
   (mg/1)
Type of Controls Reported
 1776


 1785



 1794

 1839

 2030


 2055



 2062



 2073

 2090


 2206

 2268


 2345
  168
     6

  862
    50
  2400     5,640

  2419


  2527
    100      Steam stripping, grit removal, oil skim-
             ming, neutralization

     -       Chemical precipitation, chromium reduction,
             steam stripping, ion exchange, carbon ad-
             sorption, equalization, neutralization

             Oil skimming, API separation

             Steam stripping, gravity settling

             Chemical precipitation, chromium reduction,
             air stripping,  neutralization, flocculation

             Steam stripping, coagulation,  flocculation,
             recycle basin,  clarification,  polishing
             pond

             Chemical precipitation, steam stripping,
             carbon adsorption,  coagulation,  floccula-
             tion, neutralization,  pH adjustment   .

      40      HOPE skimmer,  polishing pond,  pH adjustment

      50      Distillation,  equalization,  neutralization,
             grit removal

             Oil  skimming,  oil  separation

     264      Equalization,  sedimentation,  neutraliza-
              tion,  filtration

      29       Steam  stripping, solvent  extraction,  floc-
              culation,  redox reactor,  redox towers,
              neutralization, polishing pond,  noncontact
              coolers

   1,175       Solvent  extraction, distillation

              Equalization,  neutralization, oil skimming,
              dissolved air flotation

              Oil skimming,  aerobic spray field
                                     VII-131

-------
                                 TABLE VII-42.
            TREATMENT TECHNOLOGIES FOR DIRECT NONBIOLOGICAL PLANTS*
                                  (Continued)
 Plant  Effluent BOD,
   ID
(mg/1)
 2735



 2767

 2770


 2771


 2786
  16

 140
 80
4010
Effluent TSS
   (rag/1)
                                           Type of Controls Reported
2531
639
145
Equalization,
flocculation,
neutralization.
primary clarification, carbon adsorption
2533
2590
-
16
31
13
Equalization,
Sulfur recovei
screening
:y, single stac

re flash .
2606
2647
2668
2680
-
47
939
48
-
51
5,866
26
    21



    31

    17


    13


    55
                         176
 equalization, stormwater  impoundment, neu-
 tralization, oil separation, filtration,
 carbon adsorption

 Neutralization

 Filtration, distillation

 Steam stripping, distillation

 Decant sump, equalization, steam stripping,
 neutralization,  carbon adsorption

 Pellet skimming, neutralization, oil
 skimming,  dissolved air flotation,
 clarification

 Neutralization

 Distillation, equalization,  neutralization,
 oil  skimming, primary clarification

 Equalization, neutralization, primary
 clarification

 Filtration,  chemical  precipitation,  air
 stripping,  steam stripping,  equalization,
 neutralization,  oil skimming, oil
 separation, API  separation,  dissolved air
 flotation,  polishing  pond, (nutrient
 addition prior to a septic tank  for  part of
 the plant flow)

Depolymerization, distillation,  pH adjust-
ment, neutralization, centrifugation
       n           '  446'.601' 611' 664> 956, 1033,  1327, 1593, 1670, 1986,
    ,  and 2660 report no in-place treatment technology.
                                  VII-132

-------
of the physical/chemical treatment plants were determined to require no
further treatment to comply with the individual plant BPT Option I BOD5 long-
term average effluent compliance targets (discussed later in this section and
in Section VIII).  For another 69 percent of the plants, the engineering costs
of compliance were based on activated sludge treatment systems because their
discharge BOD5 concentrations (after correction for non-process wastewater
dilution) ranged from 15 to 23,600 mg/1 above  their individual plant BPT
Option I BOD5 long-term average effluent compliance targets.  The remaining
2 percent of the plants were costed for contract hauling because their
wastewater flows were less  than 500 gallons per day (gpd).

     In  the case of TSS, 38 percent of  the 46  physical/chemical  treatment  only
plants that reported TSS data were determined  to require no  further  treatment
to comply with  the  individual plant BPT Option I TSS  long-term average efflu-
ent  compliance  targets.  For 49 percent of  the plants,  the engineering, costs
of TSS compliance were  associated with  the  activated  sludge  treatment-system
costed for BOD5.control.   For another 7 percent  of the  plants,  t>e  engineering
costs of TSS  compliance were based  on chemically assisted  clarification
 treatment  systems}  for  4'percent  of  the plants,  costs were based on copper
sulfate  addition to polishing  ponds;  and  for  2 percent, on contract hauling
 because  the  wastewater  flows were less  than 500  gpd.

      Currently, 14 plants do  not  report any in-place treatment at all;  of
 these/two plants reported BOD5  and TSS concentrations.  One plant would
 require no treatment and the other plant would require biological treatment to
 comply with their respective BPT compliance targets.

      The Agency did not establish alternative limitations for facilities that
 do not utilize or install biological treatment systems to comply with the BPT
 effluent limitations.  Some industry commenters criticized the Agency for not
 exempting,or establishing, alternative BOD5 limitations for stand-alone
 "chlorosolvent" manufactures.  They claim that "chlorosolvent" wastewaters
 cannoV sustain a biomass and should not be subject to  limitations based on
 biological treatment, but did not provide supporting data.  The Agency
 identified only three stand-alone "chlorosolvent" facilities (plants 569, 913,
 and 2062) using the commenters definition of  "chlorosolvents" as chlorinated
                                     VII-133

-------
  Cl and C2 hydrocarbons.   These three plants use only physical/chemical
  controls to achieve their current discharge levels.   However, of these three
  plants,  only plant 913 reported BODS data that provided a long-term average of
  4  mg/1 BOD5.   Since this is significantly below the  plant's BPT long-term
  effluent compliance target of 21 mg/1 BOD5,  the Agency concluded that  plant
  913 would comply with the BOD5  effluent  limitations  without the use of
  biological treatment.  The only other identified stand-alone chlorinated
  organics plant  that did  not use biological  treatment was  plant  1569, a manu-
  facturer of chlorinated  benzenes.  This  plant  reported a  long-term  average
  BOD5 discharge  concentration of 18 mg/1,  a level already  below  its  BPT long-
  term effluent compliance  target of 27  mg/1 BOD5.  The  Agency also identified
  three other manufacturers  that  produced  "chlorosolvents"  along with other
 products  (plants  1532, 2770,  and 2786);  they reported  long-term average BOD5
 discharge concentrations of  110, 140,  and 80 mg/1, respectively—sufficient5
 levels to sustain biota.  In  fact, the Agency identified  13  OCPSF plants that
 utilize biological  treatment systems with reported influent BOD5 concentration
 less than 125 mg/1.  The influent concentrations for seven of these plants
 range from 60 to 80 mg/1 BOD5.  Furthermore, another plant (725) sampled by
 EPA has an activated sludge system that treats wastewater with a 37 mg/1 BOD5
 average influent concentration.   The product mix at this facility included
 tetrachloroethylene and chlorinated paraffins.
                       •Gfr
     The nonbiologicar wastewater treatment  performance information  for OCPSF
 plants  that reported influent and effluent BOD5  and/or TSS data  is  listed  in
 Table VII-43.  As shown,  the ranges  of BOD5  and TSS percent removals are 27  to
 98  percent and 0 to 91 percent,  respectively.   Some of these systems include
 clarification  treatment,  but in  combination with other physical/chemical
 wastewater treatment unit  operations.

     In an effort  to identify performance  data  for physical/chemical
 clarification treatment systems  treating BOD5 and TSS,  the Agency was able to
 obtain influent  and  effluent  BOD5 and TSS  data for clarification systems at
pulp, paper, and paperboard mills.  Table VII-44  presents  performance data for
clarification systems at 27 mills, and  the data show  that  clarification
systems can obtain significant removals of both TSS and BOD5 as well as
reducing TSS levels  in raw wastewaters  to levels comparable to BPT Option I
                                   VII-134

-------
                               ', TABLE VII-43.
       PERFORMANCE OF OCPSF NONBIOLOGICAL WASTEWATER TREATMENT  SYSTEMS
Plant ID
           Reported  Reported
Pollutant  Influent  Efficient     .•%,•;.   In-Place
Parameter   (mg/1)    (mg/1)   Removal  Treatment*
   657
   669
   938
 BOD
 TSS


 BOD
 TSS



 BOD
 TSS
  22
  47
2804
 451
                         226
  1688
  1776
  2055
 BODC
 TSS"
 BODC
 TSS"
 BOD
 TSS
 235




 100


 237
 16        27     Collection basin,
 17 i -      64     neutralization,  oil
                separation

 56        98     Filtration,  steam
 42        91     stripping, neutralization,
                oil skimming,  dissolved air-
                flotation, air stripping

                Steam stripping, equaliza-
 27        88     tion, flocculation,
                hypochlorite addition,
                filtration,  neutralization,
                primary clarification,
                settling pond

142        —     Steam stripping, equaliza-
 46        80     tion, flocculation,
                neutralization,  primary
                clarification

                Steam stripping, grit
100        0     removal, oil skimming,
                neutralization    , .

168       29     Steam stripping, coagula-
                tion,, flocculation, recycle
                basin, secondary clarifi-
                cation, polishing pond
 individual  plants  may treat  all  process  wastevater or a portion of the
  process  wastewater by the reported treatment  unit  operations.   Reported
  influent data may  not precede all listed unit operations.
                                    VII-135

-------
8
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                 cn co c



                 C; b; fc? S3 E?
                 O» O» CT* \7\ CM
                 rH T-l i-l rH <-H
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                                                                                en

                                        VII-136

-------
long-term average levels in a wastewater matrix containing low BODg levels.

In addition, for these plants BOD5 effluent values are also comparable to BPT

Option I long-term average levels.


     Based on the discussion and the performance data presented above, the

Agency concludes that:


     •  There are a limited number of OCPSF plants with either no treatment or
        physical/chemical treatment in-place (which have BOD  and TSS effluent
        data) that are not in compliance with the BOD5 and TSS BPT long-term
        average effluent compliance targets and have not had BPT compliance
        costs estimated based on biological treatment.

     •  There are a limited number of OCPSF plants with either no treatment or
        physical/chemical treatment in-place (which have BOD5 and TSS effluent
        data) that are in compliance with BOD5 but not in compliance with TSS
        BPT Option I long-term average effluent compliance targets.

     •  BPT Option I long-term averages for BOD5 and TSS, which are based on
        the performance of biological treatment, can be attained by physical/
        chemical treatment systems either in-place or used by the Agency to
        estimate BPT compliance costs (i.e., chemically assisted clarifica-
        tion).


     Furthermore, compliance with BAT toxic pollutant effluent limitations

guidelines  based on installation of physical/chemical or biological treatment
or improvements in the design and operation of in-place treatment would also

result in incidental reductions of conventional pollutants.


     For these reasons, the Agency has decided not to establish a separate set
of BPT effluent limitations for OCPSF plants that do not require biological

treatment to  comply with BPT.


     A.  BAT  Treatment Systems

     The Agency promulgated BAT limitations for two subcategories  that were
largely determined by raw waste characteristics.  First, the end-of-pipe
biological  treatment  subcategory  includes  plants  that have or will  install

biological  treatment  to comply with BPT limits.   Second, the non-end-of-pipe

biological  treatment  subcategory  includes  plants  that either generate such low

levels of BOD5  that  they do not need biological treatment or choose to use
                                    VII-137

-------
 physical/chemical treatment alone to comply with the BPT limitations for BOD5.
 The BAT limitations are based on the performance of the biological treatment
 component plus in-plant control technologies that remove priority pollutants
 prior to discharge to the end-of-pipe treatment system.  These in-plant
 technologies include steam stripping to remove volatile and semivolatile
 priority pollutants, activated carbon for various base/neutral priority
 pollutants,  chemical precipitation for metals,  cyanide destruction for
 cyanide,  and in-plant biological treatment for removal of polynuclear aromatic
 (PNA)  and other biodegradable priority pollutants.   Table VII-45  presents a
 list of the  regulated BAT toxic pollutants and the  technology basis for the
 final  BAT Subcategory One and Two effluent limitations for each.   Tables
 VII-46 and VII-47 present a summary of the long-term weighted average effluent
 concentrations for the final BAT toxic pollutant data base for BAT Subcategory
 One and Subcategory Two.   The minimum,  maximum,  and median of the plant's
 weighted  average effluent concentrations  were  calculated for each pollutant  to
 display the  performance of well-operated  treatment  systems in the OCPSF
 industry.

 F.   WASTEWATER DISPOSAL
     1.   Introduction
     The  method of treatment  for direct and  indirect  dischargers  was  discussed
 in  Sections  C  and D.   In  this  section  the treatment  processes  and disposal
 methods associated with zero  or  alternate discharge  in the OCPSF  industry are
 described.   Zero  or alternate  discharge at  the OCPSF  plant  is  defined  as  no
 discharge  of contaminated  process wastewater to  either surface water  bodies or
 to  POTWs.  Table  VII-48 presents  the frequency of waste  stream final  discharge
 and  disposal techniques.   This section describes deep  well  injection  (56  OCPSF
 plants), contract  hauling  (128 plants), incineration  (93  plants),  evaporation
 (29  plants), surface  impoundment  (25 plants), and land application  (19  plants).

     2.  Deep Well  Injection
     Deep well  injection is a process used for the ultimate disposal of
wastes.  The wastes are disposed by injecting them into wells at depths of up
 to 12,000 ft.  The wastes must be placed  in a geological  formation  that
prevents the migration  of  the wastes to the surface or to groundwater
                                   VII-138

-------
                                TABLE VII-45.
         LIST OF REGULATED TOXIC POLLUTANTS AND THE TECHNOLOGY BASIS
             FOR BAT SUBCATEGORY ONE AND TWO EFFLUENT LIMITATIONS
Poll't.
 No.  Pollutant Name
        BAT
     Subcategory One
       End-of-Pipe
Biological Treatment Plus
     BAT
Subcategory Two
  1   Acenaphthene
  3   Acrylonitrile
  4   Benzene
  6   Carbon Tetrachloride
  7   Chlorobenzene
  8   1,2,4-Trichlorobenzene
  9   Hexachlorobenzene
 10   1,2-Dichloroethane
 11   1,1,1-Trichloroethane
 12   Hexachloroethane  n
 13   1,1-Dichloroethane
 14   1,1,2-Trichloroethane
 16   Chloroethane
 23   Chloroform
 24   2-Chlorophenol
 25   1,2-Dichlbrobenzene
 26   1,3-Dichlorobenzene
 27   1,4-Dichlorobenzene
 29   1,1-Dichloroethylene
 30   1,2-Trans-Dichloroethylene
 31   2,4-Dichlorophenol
 32  5 1,2-Dichloropropane
 33   1,3-Dichloropropene
 34   2,4-Dimethylphenol
 35   2,4-Dinitrotoluene
 36   2,6-Dinitrotoluene
 38   Ethylbenzene
     In-,Flant Biological
     In-Plant Biological
     Steam Stripping
     Steam Stripping
     Steam Stripping
     Steam Stripping
     Steam Stripping
     Steam Stripping
     Steam Stripping
     Steam Stripping
     Steam Stripping**
     Steam Stripping
     Steam Stripping
     Steam Stripping
     (Biological Only)
     Steam Stripping
     Steam Stripping
     Steam Stripping
     Steam Stripping
     Steam Stripping
     (Biological Only)
     Steam Stripping
     Steam Stripping
     InrPlant  Biological
     (Biological Only)
     (Biological Only)
     Steam Stripping
In-Plant Biological
In-Plant Biological
Steam Stripping
Steam Stripping*
Steam Stripping*
Steam Stripping*
Steam Stripping
Steam Stripping*
Steam Stripping
Steam Stripping*
Steam Stripping
Steam Stripping
Steam Stripping
Steam Stripping
Reserved
Steam Stripping*
Steam Stripping*
Steam Stripping*
Steam Stripping
Steam Stripping
Reserved
Steam Stripping*
Steam Stripping*
In-Plant Biological
Reserved
Reserved
Steam Stripping*
                                    VII-139

-------
                                TABLE VII-45.
          LIST  OF REGULATED TOXIC  POLLUTANTS AND THE TECHNOLOGY BASIS
             FOR BAT SUBCATEGORY'ONE AND TWO EFFLUENT LIMITATIONS
                                  (Continued)
Poll't.
 No.  Pollutant Name
        BAT
     Subcategory One
       End-of-Pipe
Biological Treatment Plus
      BAT
 Subcategory Two
 39   Fluoranthene
 42   Bis(2-Chloroisopropyl)Ether
 44   Methylene Chloride
 45   Methyl Chloride
 52   Hexachlorobutadiene
 55   Naphthalene
 56   Nitrobenzene

 57   2-Nitrophenol
 58   4-Nitrophenol
 59   2,4-Dinitrophenol
 60   4,6-Dini tro-o-Cresol
 65   Phenol
 66   Bis(2-Ethylhexyl)Phthalate
 68   Di-N-butyl  Phthalate
 70   Diethyl Phthalate
 71   Dimethyl Phthalate
 72   Benzo(a)Anthrancene
 73   Benzo(a)Pyrene
 74   3,4-Benzofluoranthene
 75   Benzo(k)Fluoranthene
 76   Chrysene
 77    Acenaphthylene
 78    Anthracene
 80    Fluotene
 81    Phenanthrene
     In-Plant Biological
     Steam Stripping
     Steam Stripping
     Steam Stripping
     Steam Stripping
     In-Plant Biological
     Steam Stripping and
     Activated Carbon
     Activated Carbon
     Activated Carbon
     Activated Carbon
     Activated Carbon**
     In-Plant Biological
     In-Plant Biological
     In-Plant Biological
     In-Plant Biological
     In-Plant Biological
     In-Plant Biological
     In-Plant Biological
     In-Plant Biological
     In-Plant Biological
     In-Plant Biological
     In-Plant  Biological
     In-Plant  Biological
     In-Plant  Biological
     In-Plant Biological
 In-Plant Biological'
 Steam Stripping*
 Steam Stripping
 Steam Stripping
 Steam Stripping*
 In-Plant Biological
 Steam Stripping and
 Activated Carbon
 Activated Carbon
 Activated Carbon
 Activated Carbon
 Activated Carbon
 In-Plant  Biological
 In-Plant  Biological
 In-Plant  Biological
 In-Plant  Biological
 In-Plant  Biological
 In-Plant  Biological
 In-Plant  Biological
 In-Plant  Biological
 In-Plant  Biological
 In-Plant  Biological
 In-Plant Biological
 In-Plant Biological
In-Plant Biological
In-Plant Biological
                                  VII-140

-------
                                TABLE VII-45.
         LIST OF REGULATED TOXIC POLLUTANTS AND THE TECHNOLOGY BASIS
             FOR BAT SUBCATEGORY ONE AND TWO  EFFLUENT  LIMITATIONS
                                 (Continued)
Poll't.
 No.  Pollutant Name
        BAT
     Subcategory One
       End-of-Pipe
Biological Treatment Plus
     BAT
Subcategory Two
 84   Pyrene

 85   Tetrachloroethylene

 86   Toluene

 87   Trichloroethylene

 88   Vinyl Chloride

119   Total Chromium


120   Total Copper


121   Total Cyanide


122   Total Lead


124   Total Nickel


128   Total Zinc
     In-Plant Biological

     Steam Stripping

     Steam Stripping

     Steam Stripping

     Steam Stripping

     Hydroxide Precipi-
       tation***

     Hydroxide Precipi-
       tation***

     Alkaline Chlori-
       nation***

     Hydroxide Precipi-
       tation***

     Hydroxide Precipi-
       tation***

     Hydroxide Precipi-
       tation***
In-Plant Biological

Steam Stripping

Steam Stripping

Steam Stripping

Steam Stripping

Hydroxide Precipi-
  tation***

Hydroxide Precipi-
  tation***

Alkaline Chlori-
  nation***

Hydroxide Precipi-
  tation***

Hydroxide Precipi-
  tation***

Hydroxide Precipi-
  tation***
  *Steam stripping performance data transferred based on Henry's Law Constant
   groupings.

 **Transferred from Subcategory Two.

***Metals and cyanide limitations based on hydroxide precipitation and
   alkaline chlorination, respectively, only apply at the process source.
                                    VII-141

-------
                            TABLE VH-46.
SIMWRY OF THE LOWS-TERM WEIGHED AVERAGE EFFLUENT OONCEmMTICNS FOR THE
      FINAL BAT TOXEC POLLUTANT DATA BASE FOR BAT SUBGATBGORY ONE
Pollutant
Umber
1
3
4
6
7
8
9
10
11
12
14
16
23
24
25
26
27
29
30
31
32
33
34
35
36
38
39
42
44
45
52
Pollutant Name
Acenaphthene
Acrylonitrile
Benzene
Carbon Tetrachloride
Chlorobenzene
1,2, 4-Trichlorobenzene
Hexachlorobenzene
1, 2-Dichloroethane
1, 1, 1-Trichloroethane
Hexachloroethane
1, 1,2-Tridiloroethane
Chloroethane
Chloroform
2-Chlorophenol
1, 2-Dichlorobenzene
1 , 3-Dichlorobenzene
1,4-Dichlorobenzene
1 , 1-Dichloroethylene
1 , 2-Trans-dichloroe'thylene
2,4-Wchlorophenol
1 , 2-Dichloropropropane
1 , 3-Dichloropropene
2,4-Dimethylphenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Ethylbenzene
Fluoranthene
Bis(2-Chloroisopropyl)Ether
Methylene Chloride
Methyl Chloride
Hexachlorobutadiene
Number of
Plants
3
5
17
3
2
3
1
9
2
2
3
4
8
3
7
1
1
5
3
3
6
3
4
2
2
14
3
1
8
1
2
Median of
Est. Long-
Term Means
(ppb)
10.000
50.000
10.000
10.000
10.000
42.909
10.000
25.625
10.000
10.000
10.000
50.000
12.208
10.000
47.946
24.800
10.000
10.000
10.000
17.429
121.500
23.000
10.794
58.833
132.667
10.000
11.533
156.667
22.956
50.000
10.000
Minimum of
Est. Long-
Term Means
(ppb)
10.000
50.000
10.00
10; 00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
24.80
10.00
10.00
10.00
10.00
13.19
10.25
10.00
10.00
10.00
10.00
10.13
156.67
10.00
50.00
10.00
Maximum of
Est. Long-
Term Means
(ppb)
13.00
122.67
16.62
10.00
10.00
69.46
10.00
1228.33
10.00
10.00
10.00
50.00
43.00
93.30
88.20
24.80
10.00
11.60
77.67
21.62
923.00
63.33
13.47
107.67
255.33
10.00
12.27
156.67
206.67
50.00
10.00
                             Vn-142

-------
                             TABLE VIP-46.
SUMMARY OF 1HE LOWS-TERM WEIGHTED AVERAGE EFFLUENT CONCHflEATIONS FCR THE
      FINAL BAT TOXLC POLLUTANr DATA BASE FOR BAT SUBCATEGORY ONE
                              (Continued)
Pollutant
Number
55
56
57
58
59
65
66
68
70
71
72
73
74
75
76
77
78
80
81
84
85
86
87
88
Pollutant Name
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2,4-Dinitrophenol
Phenol
Bis(2-Ethylhe5^1)Phthalate
Di-N-Butyl Phthalate
Diethyl Phthalate
Dimethyl Phthalate
Benzo(a)Anthracene
Benzo(a)Pyrene
3, 4-Benzofluoranthene
Benzo(K)Fluoranthene
Chrysene
Acenaphthylene
Anthracene
Fluorene
Phenanthrene
Pyrene
Tetrachloroethylene
Toluene
Trichloroethylene
Vinyl Chloride
Number of
Plants
10
4
2
3
3
22
2
2
2
2
2
1
1
1
3
3
3
3
6
3
3
24
4
3
Median of
Est. Long-
Term Means
(ppb)
10.000
14.000
27.525
50.000
50.000
10.363
47.133
17.606
42.500
10.000
10.000
10.333
10.267
10.000
10.000 .
10.000
10.000
10.000
10.000
11.333
10.423
10.000
10.000
50.000
Minimum of
Est. Long-
Term Means
(ppb)
10.00
14.00
20.00
50.00
50.00
10.00
43.45
13.09
23.67
10.00
10.00
10.33
10.27
10.00
10.00
10.00
10.00
10.00
10.00
10.33
10.00
10.00
10.00
50.00
Maximum of
Est. Long-
Term Means
(ppb)
10.21
149.67
35.05
145.00
105.35
120.00
50.81
22.12
61.33
10.00
10.00
10.33
10.27
10.00
10.00
13.00
10.00
10.00
17.92
16.00
227.00
102.67
16.00
174.00
                                 VH-143

-------
                             TABLE VII-47.
SUflfiRY OF THE LONG-TERM WEIGHTED AVERAGE EFFLUENT COMmRATIONS FOR THE
       FINAL BAT TOXIC POLLUTANT DATA. BASE FOR BAT SUBCATEQORY TWO
Pollutant
foiriber
1
3
4
6
7
8
9
10
11
12
13
14
16
23
25
26
27
29
SO
32
33
34
38
39
42
44
45
52
Pollutant Name
Acenaphthene
Acrylonitrile
Benzene
Carbon Tetrachloride
Chlorobenzene
1,2, 4-Tridilorobenzene
Hexachlorobenzene
1 , 2-Dichloroethane
1, 1, 1-Trichloroethane
Hexachloroe thane
1 , 1-Dichloroethane
1, 1, 2-Trichloroethane
Chloroe thane
Chloroform
1 , 2-Dichlorobenzene
1,3-Dichlorobenzene
l,4^chlorobenzene
1 , 1-Dichloroethylene
1, 2-Trans-dichloroethylene
1 , 2-Dichloropropane
1 , 3-^ti.chloropropene
2,4-Dimethylphenol
Ethylbenzene
Fluoranthene
Bis(2-Chloroisopropyl)Ether
Methylene Chloride
Methyl Chloride
Hexachlorobutadiene
Number of
Plants
1
1
4
_
_
_
_
2
1
_
1
2
2
2
_
_
_
2
2
_
_
1
_
1
_
3
1
:
Median of
Est. Long-
Term Means
(ppb)
10.000
50.000
28.576
64.500
64.500
64.722
64.722
64.722
10.000
64.722
10.000
10.293
50.000
44.108
64.722
64.500
64.500
10.052
11.052
64.722
64.722
10.000
64.500
11.533
64.722
10.800
50.000
64.500
Minimum of
Est. Long-
Term Means
(ppb)
10.000
50.000
10.00
64.50
64.50
64.72
64.72
62.77
10.00 '
64.72
10.00
10.00
50.00
11.81
64.72
64.50
64.50
10.00
10.00
64.72
64.72
10.00
64.50
11.53
64.72
10.00
50.00
64.50
Maximum of
Est. Long-
Term Means
(ppb)
10.00
50.00
200.33
64.50
64.50
64.72
64.72
66.67
10.00
64.72
10.00
10.59
50.00
76.41
64.72
64.50
64.50
10.10
12.10
64.72
64.72
10.00
64.50
11.53
64.72
30.33
50.00
64.50
                               VLT-144

-------
                             TABLE Vn-47.
SUMMARY OF THE LONG-TERM WEIGHTED AVERAGE EFFLUENT CONCENTRATIONS FOR THE
       FINAL BAT TOXIC POLLUTANT DATA BASE FOR BAT SUBCATBQORY TWO
                              (Continued)
Pollutant
Number
55
56
57
58
59
60
65
66 	
68
70
71
72
73
74
75
76
77
78
80
81
84
85
86
87
88
Pollutant Name
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2 , 4-Dini trophenol
4 , 6-Dini tro-0-Cresol
Phenol.
Bis(2-Ethylhe?yl)Phthalate
Di-N-Butyl Phthalate
Diethyl Phthalate
Dimethyl Phthalate
Benzo(a)Anthracene
Benzo(a)Pyrene
3 , 4-Benzofluoranthene
Benzo(k)Fluoranthene
Chrysene
Acenaphtnylene
Anthracene
Fluorene
Phenanthrene
Pyrene
Tetrachloroethylene
Toluene
Trichloroethylene
Vinyl Chloride
Number of
Plants
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
2
2
Median of
Est. Long-
Term Means
(ppb)
10.000
948.675
20.000
50.000
373.000
24.000
10.000.
43.455
13.091
23.667
10.000
10.000
10.333
10.267
10.000
10.000
10.000
10.000
10.030
10.000
10.333
18.429
12.418
11.586
64.500
Minimum of
Est. Long-
Term Means
(ppb)
10.00
712.60
20.00
50.00
373.00
24.00
10.00
43,45 ,
13.09
23.67
10.00
10.00
10.33
10.27
10.00
10.00
10.00
10.00
10.00
10.00
10.33
18.43
10.951
10.00
50.00
Maximum of
Est. Long-
Term Means
(ppb)
10.00
1184.75
20.00
50.00
373.00
24.00
10.00
43.45
13.09
23.67
10.00
10.00
10.33
10.27
10.00
10.00
10.00
10.00
10.00
10.00
10.33
18.43
13.88
13.17
79.00
                                 VH-145

-------
                                 TABLE VII-48.
                    FREQUENCY OF WASTE STREAM  FINAL DISCHARGE
                            AMD DISPOSAL TECHNIQUES
 Disposal Technique
 No.  of Plants   No.  of Plants   Total No.
(Full Response)     (Part A)      of Plants
Direct Discharge to Surface Water
Discharge to Publicly
Owned Treatment Works
Discharge to Privately Owned
Off-Site Treatment Facilities
Deep Well Injection
Contract Hauling
Incineration
Land Application
Evaporation
Surface Impoundment
Recycle
250
287
6
32
82
63
0
13
8
36
54
106
35
24
46
30
19
16
17
0
304
393
41
56
128
93
19
29
25
36
NOTE:  Combined direct and indirect discharges have been counted with the
       direct dischargers; otherwise, remaining disposal techniques can be
       double-counted for applicable plants.
                                  . VII-146

-------
supplies.  The most suitable site for deep well. injection is a porous zone of
relatively low to moderate pressure that is sealed above and-below by unbroken
impermeable strata.  Limestones, sandstones, and dolomites are among the  rock
types most frequently used because of their relatively high  porosity. The
formation chosen must have sufficient volume to contain  the  waste without
resulting in an increase in the hydraulic pressure, which could  lead to a
crack in the confining rock layers.                                         .

     The most significant hindrance  to  the  application of deep well  injection
is  the potential for groundwater and  surface water  contamination;  -Careful  ..,-.
control  of the process is necessary  to  prevent  any  contamination,  and
injection should only be used  in certain geographically  acceptable areas.  The
process  is also limited  to waste streams with  low levels of  suspended  solids
to  prevent plugging of the well screen  which  can  cause  unstable  operation.
Pretreatment  such  as  filtration can  prevent .clogging of the  screen and the
disposal aquifer.   Another practical limitation is that waste streams  to be
injected should have a pH value between 6.5 and 8.0 to  prevent equipment
corrosion.   In general,  all  streams  subject to deep well injection are.treated
 through  equalization, neutralization, and  filtration before disposal.   Deep
well injection may be particularly attractive for disposal of inhibitory or
 toxic organic waste streams.

      According  to the Section 308 Questionnaire data base, 56 OCPSF plants use
 deep well injection as  a means for ultimate disposal for all or a portion of
 their wastes.      . .  --..    ;:.:....   •;.•...,,..-•. -..•..-.--••-  :•,;..•.  • -,._  . -r , ;  - 4..-v

      3.   Off-Site Treatment/Contract Hauling
      Off-site treatment refers to wastewater treatment  at a site other than
 the generation site.  Off-site treatment may occur at a cooperative or
 privately owned centralized facility.   Often a contract hauler/disposer  is
 paid to pick up the wastes at  the generation site  and  to haul them  to  the
 treatment facility.  The hauling may.be accomplished by truck,  rail,  or  barge.
                                     VII-147

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       Off-site treatment/contract hauling is usually limited to low volume
 wastes,  many.of which may require specialized  treatment  technologies  for
 proper disposal.   Generators  of these  wastes often find  it  more economical  to
 treat the wastes  at  off-site  facilities  than to  install  their  own  treatment
 system.  Sometimes,  adjacent  plants  find it more feasible to install  a
 centralized facility to handle  all wastes  from their sites.  The costs usually
 are shared by  the  participants  on a  prorated basis.

      According  to  the  Section 308 Questionnaire  data base,  128  plants use con-
 tract hauling and  off-site treatment as  a  final  disposal technique for part or
 all of their wastes.

      4.   Incineration
      Incineration is a frequently used zero discharge method in the OCPSF
 industry.  The process involves the oxidation of  solid, liquid, or gaseous
 combustible wastes primarily to carbon dioxide, water,  and ash.  Depending
 upon the  heat  value of the material being incinerated,  incinerators may  or may
 not require auxiliary fuel.   The gaseous  combustion or  composition  products
 may require scrubbing,  particulate removal, or  another  treatment to capture
 materials that cannot be discharged  to  the atmosphere.  This treatment may
 generate  a waste stream tnat  ultimately will require some degree of treatment.
 Residue left after oxidation will also  require some means of disposal.

     Incineration  is  usually used for the ultimate disposal  of  flammable
 liquids,  tars,  solids,  and hazardous  waste  materials of low  volume  that are
 not amenable to  the usual  end-of-pipe treatment technologies.   To achieve
 efficient destruction of the waste materials  by incineration, accurate and
 reliable information  on the physical  and  chemical  characteristics of the waste
must be acquired in order  to determine appropriate operating conditions for
 the process (e.g.,  feed rates, residence  time, and temperature) and the
required destruction efficiency.
                                   VII-148

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     According to the Section 308 Questionnaire data base, 93 OCPSF plants use
incineration as an ultimate disposal technique.

     5.  Evaporation
     Evaporation is a concentration process involving removal of water from a
solution by vaporization to produce a concentrated residual solution.  The
energy source may be synthetic (s.team, hot gases, and. electricity) or natural
(solar and geothermal).  Evaporation equipment can range  from simple open
tanks or impoundments to sophisticated multi-effect evaporators capable of
handling large volumes of liquid.  The evaporation process is designed on the
basis of the quantity of water to be evaporated, the quantity of heat required
to evaporate water from solution, and the heat transfer rate.  The process
offers the possibility of total wastewater elimination with only the remaining
concentrated solution requiring disposal and also offers  the possibility of
recovery and recycle of useful chemicals from  wastewater.

     According  to  the Section 308 Questionnaire  date  base, 29 OCPSF  plants use
evaporation as  a final disposal  technique.

     6.  Surface Impoundment                         ,
     Impoundment generally  refers  to  wastewater  storage  in large ponds.
Alternate  or  zero discharge from these  facilities  relies  on  the natural  losses
by  evaporation,  percolation into the  ground,  or  a  combination  thereof.
Evaporation  is  generally  feasible  if  precipitation,  temperature, humidity,  and
wind velocity combine  to  cause  a net  loss  of  liquid  in the pond.   Surface
 impoundments  are usually  of shallow depth  and large  surface  area  to encourage
 evaporation.   If a net  loss does not  exist,  recirculating sprays,  heat,  or
 aeration can be used to  enhance the evaporation rate to provide a  net  loss.
 The rate of  percolation  of water into the  ground is  dependent  on  the subsoil
 conditions of the area of pond construction.   Since  there is a great potential
 for contamination of the shallow aquifer from percolation, impoundment ponds
 are frequently lined or sealed to avoid percolation and thereby make the
 basins into evaporation ponds.   Solids that accumulate over a period of time
 in these sealed ponds will eventually require removal.  Land area requirements
 are a major factor limiting the amount of wastewater disposed of by this
 method.
                                     VII-149

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       According to the Section 308 Questionnaire data base, 25 OCPSF plants
  report using surface impoundments as a final disposal technique.

       7.  Land Application

       Land treatment is the direct application of wastewater onto land with
  treatment being provided by natural processes (chemical, physical,  and
  biological)  as the effluent moves through a vegetative cover or the soil.
  Land application  greatly reduces or eliminates  BOD5  and suspended solids,
  results in some nutrient removal,  may result in some heavy metal removal,  and
  can  recharge groundvater.   A portion of  the wastewater is  lost  to the atmo-
  sphere  through evapotranspiration,  part  to surface water by overland  flow, and
  the  remainder percolates to the  groundwater system.

      Land  disposal of industrial wastewaters must be  compatible  with  land use
 and  take into  consideration the potential  for environmental pollution, damage
 to crops,  and entrance into the human food  chain.  To protect soil  fertility
 and  the food chain during land disposal, it is necessary to determine  the
 capacity of soils to remove nitrogen, the potential toxicity of organic and
 inorganic contaminants to plant life and soil, and the deleterious effects of
 dissolved salts, including sodium, on plants and soil.

      According to  the Section 308 Questionnaire  data base,  19 OCPSF plants
 report using  land  application as  a final disposal technique.

 G.  SLUDGE TREATMENT AND  DISPOSAL

      Solid  residues  (sludge) are  generated  by many wastewater treatment
 processes discussed  in previous sections  of this  chapter.   Sludge is generated
 primarily in  biological treatment,  chemical precipitation (coagulation/
 flocculation),  and chemically assisted clarifiers.  Sludge  must  be treated  to
 reduce its  volume and to  render it  inoffensive before  it  can be disposed.
 Sludge treatment alternatives  include thickening, stabilization,  conditioning,
and dewatering.  Disposal options include combustion and disposal  to land.
The frequency of these treatment and disposal alternatives,  according  to the
Section 308 Quesionnaire data base, is presented in Table VII-49.
                                   VII-150

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       Sludge thickening is the first step in removing water from sludges to
  reduce their volume.  It is generally accomplished by physical means,
  including gravity settling, flotation, and centrifugation.  The principal
  purposes of stabilization are to make the sludge less odorous and putrescible,
  and to reduce the pathogenic organism content.  The technologies available for
  sludge stabilization include chlorine oxidation,  lime stabilization,  heat    '
  treatment,  anaerobic digestion,  and aerobic digestion.   Conditioning  involves
  the biological,  chemical,  or physical treatment of a sludge to enhance
  subsequent  dewatering techniques.   The two  most common  methods used to
  condition sludge are thermal and chemical conditioning.   Dewatering,  the
  removal of  water from solids to  achieve  a volume  reduction greater  than that
  achieved by thickening, is desirable  to  prepare sludge  for disposal and to
  reduce the  sludge volume and mass  to  achieve lower  transportation and  disposal
  costs.  Some common  dewatering methods include  vacuum filtration, filter
  press, belt filter,  centrifuge,  thermal, drying beds, and  lagoons.  Combustion
  serves as a means for  the ultimate disposal of  organic constituents found in
 sludge.  Some common equipment and methods used to incinerate sludge include
 fluidized bed reactors, multiple hearth furnaces, atomized spray combustion,
 flash drying incineration,  and wet air oxidation.  Environmental impacts of
 combustion may include discharges to the atmosphere (particles and other toxic
 or noxious emissions), surface waters (scrubbing water), and land (ash).
 Disposal of  sludge to land  may include the application of the sludge (usually
 biological treatment  sludge)  on land as a soil  conditioner and as a  source  of
 fertilizer for plants,  or  the stockpiling of sludge in landfills or  permanent
 lagoons.   In selecting a land disposal site,  consideration must be given to
 guard against  pollution of groundwater or surface  water  supplies.

      According  to the Section 308 Questionnaire  data  base,  116  plants  report
 treating their sludge by thickening or  dewatering  (26  by  thickening, 4  by
 centrifugation, 4 by  filtration,  22 by  digestion,  and 50  by dissolved air
 flotation).  Of the 104 plants reporting sludge  disposal  methods, 21 use
on-site landfills, 15 employ  incineration, 18 use  contract  hauling,  and 50
dispose of sludge at off-site landfills.
                                   VII-152

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H.  LIMITATIONS DEVELOPMENT
     This section describes the methodology used to develop BPT, BAT, and PSES
effluent limitations and standards and includes discussions of data editing
criteria, derivation of long-term averages, and derivation of "Maximum for
Monthly Average" and "Maximum for Any One Day" variability factors.

     1.  BPT Effluent Limitations
     As discussed in Section VI, the Agency decided to control BOD5 and TSS
under BPT.  This section discusses the data editing rules and methodology used
to derive the final BPT effluent limitations guidelines  for BOD5 and TSS.

         a.  Data Editing Criteria
     Two sets of data editing rules were developed for BPT; one set was used
to edit  the data base, which was utilized  to calculate the long-term averages
(LTA) BOD5 and TSS values for each subcategory, while  the second set was used
to edit  the BPT daily data  base, which was utilized to derive variability
factors.

         b.  LTA Data Editing
     The two major  forms of data editing  performed on  the LTA data base
obtained through  the  1983 Section:308 Questionnaire were the dilution  adjust-
ment assessments made  for each  full-response,  direct discharge  OCPSF facility
which  submitted BOD,., or"TSS influent  and/or  effluent data and a BPT perform-
ance edit.

     Dilution  Adjustment  -  Since  the  limitations  apply to all process
wastewater  as  defined in  Section V,  the Agency grouped all  volumes of  process
and  non-process wastewater  for  the purpose of adjusting reported plant-level
BOD  and TSS concentrations for dilution by nonprocess wastewater.  This also
 permitted the  Agency to estimate  engineering costs  of  compliance based on the
 proper process wastewater flows and conventional pollutant  concentrations.
 For  example,  if BOD5  was  reported as  28 mg/1 at the final effluent sampling
 location with 1 MGD of process  wastewater flow that was combined with 9 MGD of
 unconlaminated nonprocess cooling water flow,  then the BOD5 concentration in
                                     VII-153

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 the process wastewater alone was actually 280 mg/1 before dilution.  This
 conservatively assumes that the cooling water flow is free of BODg and TSS.

      However,  in the Agency's judgment, many of the sources and flows reported
 as nonprocess  wastewater by plants in their respective Section 308 Question-
 naires are contaminated by process sources of BOD5 and TSS.   Table VII-50
 presents  a list of the miscellaneous wastewaters reported in the Section 308
 Questionnaires as nonprocess,  which EPA has determined to be either contam-
 inated (and therefore process  wastewater)  or uncontaminated  with conventional
 pollutants.  The Agency reviewed this list after receiving public comments on
 both NOAs criticizing some of  its assignments and determined that,  in general,
 its assignments were correct.

     Since  the limitations apply to process  wastevater (which  includes
 "contaminated  nonprocess"  wastewater)  only,  the  relative  contributions of
 process wastewater versus  "uncontaminated  nonprocess"  wastewater  were  deter-
 mined  at  the influent  and  effluent  sample  sites.   These data were used to
 calculate plant-by-plant "dilution  factors"  for  use in adjusting  pollutant
 concentrations  at influent  and effluent sampling locations as appropriate.

     The general procedure  for determining sample-site dilution factors and
adjusting BOD5  and TSS values was as follows:

     •  Sum uncontaminated nonprocess wastewater flows for an individual plant
        (e.g.,  Plant No. 61 uncontaminated nonprocess wastewater flow =
        0.280 MGD)
     •  Sum process wastewater flow for an individual plant  (e.g., Plant No
        61 process wastewater flow =0.02 MGD)
     •  Divide  the sum of uncontaminated nonprocess wastewater flows by the
        total process wastewater flow to determine dilution factor (e.g., for
        Plant No. 61, 0.280 MGD/ 0.02 MGD = 14.0)
     •  Apply the sample-site dilution factor (plus 1) by  multiplying by the
        reported BOD  or TSS value to be adjusted (e.g.,  for Plant No. 61,
        196 mg/1 effluent BOD5  x (14.0 + 1) = 2,940 mg/1 effluent BOD .
                                   VII-154

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                                TABLE VII-50.
    CONTAMINATED AND UNCONTAMINATED MISCELLANEOUS "NONPROCESS"  WASTEWATERS
                REPORTED IN THE 1983 SECTION 308 QUESTIONNAIRE
Contaminated "Nonprocess" Wastewaters
     (therefore designated as
        process wastewater)
Uncontaminated Nonprocess Wastewaters
Air Pollution Control Wastewater (B5)
Sanitary (receiving biological treat-
ment) (B4)
Boiler Slowdown
Sanitary (indirect discharge)
Steam Condensate
Vacuum Pump Seal Water
Wastewater Stripper Discharge
Bi  from Vertac
Boiler Feedwater Lime
Softener Slowdown
Contaminated Water Offsite
Condensate
Storage, Lans,  Shops
Laboratory Waste
Steam Jet Condensate
Water Softener  Backwashing
Miscellaneous Lab Wastewater
Raw Water Clarification
 Landfill Leachate
 Water Treatment
 Technical Center
 Scrubber Water
 Utility Streams
 Washdown N-P Equipment
 Contact Cooling Water
 Vacuum Steam Jet Slowdown
 Densator Slowdown
 Bottom Ash-Quench Water
                                  ! ,
 Demineralizer Washwater
Non-Contact Cooling Water (Bl)
Sanitary (no biological treatment,
direct discharge) (B4)
Cooling Tower Slowdown (B2)
Stormwater Site Runoff (S3).
Deionized Water Regeneration
Miscellaneous Wastewater (conditional)
Softening Regeneration
Ion Exchange Regeneration
River Water intake
Make-up Water
Fire Water Make-up
Tank Dike Water
Demineralizer Regeneranf'
Dilution Water
Condensate Losses
Shipping Drains
Water Treatment  Slowdown .
Cooling Tower .Overflow
Chilled Water  Sump  Overflow
Air Compressor and  Conditioning Blow
 Firewall  Drainings
 Other Non-contact  Cooling
Miscellaneous  Leaks and .Drains
 Boiler House Softeners  '  .
 Fire Pond Overflow
 Boiler Regeneration Backwash
 Groundwater (Purge)
 Firewater Discharge
 Freeze Protection Water
                                     VII-155

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                                  TABLE VII-50.
      CONTAMINATED AND UNCONTAMINATED MISCELLANEOUS "NONPROCESS"  WASTEWATERS
                  REPORTED IN THE 1983 SECTION 308  QUESTIONNAIRE
                                   (Continued)
  Contaminated "Nonprocess"  Wastewaters
       (therefore designated as
          process wastewater)
 Uncontaminated Nonprocess  tfastewaters
 Water  Softening  Backwash
 Lab Drains
 Closed Loop Equipment Overflow
 Filter Backwash
 Demineralizer Wastewater
 Laboratory Offices
 Demineralizer Slowdown
 Utility Clarifier Slowdown
 Steam Generation
 RO Rejection Water
 Power House Slowdown
 Inert Gas Gen.  Slowdown
 Contaminated Groundwater
 Potable Water Treatment
 Unit  Washes
 Non-Contact Floor Cleaning
 Slop Water from Dist.  Facilities
 Laboratory and  Vacuum  Truck
 Ion Bed Regeneration
 Tankcar Washing (HCN)
 Film Wastewater
 Generator  Slowdown
 Air Sluice Water
 Research and Development
 Quality Control
 Steam Desuperheating
 Pilot Plant
Other Company Off-site Waste
Ion Exchange Resin Rinse
 H2  and CO Generation
 Demineralizer Spent Regenerants
 Lime Softening of Process
 Miscellaneous Service Water
 Recirculating Cooling System
 HVAC Slowdown Lab Utility
 Condenser Water Backwash
 Deonfler Regenerant
Raw Water Filter Backwash
Distribution
                                   VII-156

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                                TABLE VII-50.
    CONTAMINATED AND UNCONTAMINATED MISCELLANEOUS "NONPROCESS"  WASTEWATERS
                REPORTED IN THE 1983 SECTION 308  QUESTIONNAIRE
                                 (Continued)
Contaminated "Nonprocess" Wastewaters
     (therefore designated as
        process wastewater)
Uncontaminated Nonprocess Wastewaters
Iron Filter Backwash
Area Washdown
Vacuum Pump Wastewater
Garment Laundry
Hydraulic Leaks
Grinder Lubricant
Utility Area Process
Contact Rainwater
Alum Water Treatment
Incinerator H20
Product Wash
Backflush from Demineralizer
Water Clarifier Blowdown
Water Treatment Filter Wash
Equipment Cooling H20
Belt Filter Wash
Ejector
OCPSF Flow from Another Plant
                                   . VII-157

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      Plant-specific dilution factor calculations and adjustments are
 summarized in Appendix VII-B.

      BPT Performance Edits - As stated earlier in Section VII, the Agency has
 chosen BPT Option I (which is based on the performance of biological treatment
 only) as the technology basis for the final BPT effluent limitations.  After
 selecting the technology basis, the Agency developed the associated limita-
 tions based on the "average-of-the-best" plants that use the BPT Option I
 technology.  A performance criterion was developed to segregate the better
 designed and operated plants from the inadequate performers.  This was done to
 ensure that the plant data relied upon to develop BPT limitations reflected
 the average of the best existing performers.   Since the data base also
 included plants that are inadequate performers,  it is necessary to develop
 appropriate criteria for differentiating poor from good plant performance.
 The BOD5 criteria used for the  March 21,  1983 Proposal,  the  July 17,  1985 and
 the December 8,  1986 Federal Register NOAs  was to include in the data base any
 plants with a biological treatment  system that,  on the average 1)  discharged
 50  mg/1 or  less  BOD5  after treatment,  or  2) removed 95 percent or  more of the
 BOD5  that entered the end-of-pipe  treatment system.

      The Agency  has  received two diametrically opposed sets  of comments on  the
 proposed data editing criteria  used  to develop BPT  limitations.  EPA  proposed
 to  select plants  for  analysis in developing limitations  only if  the plants
 achieve  at  least  a 95  percent removal efficiency  for  BOD5 or a long-term
 average  effluent  BOD5  concentration  below 50  mg/1.  On one hand, many  industry
 commenters  argued that  these criteria were too stringent, were based upon data
 collected after  1977  from  plants that had already achieved compliance with BPT
 permits  and  thus  raised  the standard of performance above what it would  have
 been had the  regulation been promulgated in a  timely  manner,   and had the
effect of excluding from the BPT data base some well-designed, well-operated
plants.  An environmental  interest group argued, in contrast,  that the
criteria were not stringent enough, in that they resulted in  the inclusion of
the majority of plants in  the data base used to develop effluent limitations.
                                   VII-158

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     The data collected by EPA for the BPT regulation were indeed, as industry
commenters have noted, based largely on post-1977 data.  EPA had originally
collected data in the early and mid-1970s that reflected OCPSF pollutant
control practices at that time.  As a result of industry challenges to EPA's
ensuing promulgation of BPT (and other) limitations for the OCPSF industry,
EPA began a new regulatory development program, which included a new series of
data-gathering efforts (see Section I of this document).  Industry commenters
are correct in noting that the data are thus taken to a large extent from
OCPSF plants that had already been issued BPT permits that required compliance
by July 1977 with BPT limitations established by the permit writers on a
case-by-case basis.  It is thus fair  to conclude that the performance of at
least some of these plants was better when EPA collected the data for the  new
rulemaking effort than it had been in the mid-1970s when the original BPT
regulations were promulgated.

     EPA  does not believe that the use of post-1977 data is improper.  First,
the Clean Water Act provides  for  the  periodic  revision  of BPT regulations  when
appropriate.  Thus  it  is within EPA's authority  to write BPT regulations after
1977 and  to base them on  the  best  information  available at  the  time.  More-
over,  it  is not unfair to the industry.  The  final BPT  regulations are based
on  the  same  technology that was used  to  effectively control BOD5  and TSS in
the  1970s—biological treatment preceded by appropriate process controls and
in-plant  treatment  to ensure  effective,  consistent control  in  the biological
system,  and  followed  by  secondary clarification  as necessary  to ensure
adequate  control of solids.   The  resulting  effluent  limitations are  not  neces-
sarily more  (or  less) stringent  than  they would  have  been  if  based on  pre-1977
data.   Many  of  the  plants that satisfy  the  final data editing criteria
discussed below, and thus are included  in  the BPT data base,  would not  have
satisfied those  criteria in the  mid-1970s.  The  improved  performance wrought
by  the issuance  of  and compliance with BPT  permits  in the 1970's has resulted
in  EPA's ability in 1987 to use,data  from a larger  number of  plants  to  develop
 the BPT limitations.   Approximately 72 percent of the plants  for which  data
were obtained pass  the final BOD5 editing criteria (95 percent/40 mg/1  for
 biological only treatment);  the editing criteria have excluded other plants
 that,  despite having BPT-type technology in-place,  were determined not  to  meet
 the performance criteria used to establish the data base for support of BPT
                                     VII-159

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  limitations.   EPA concludes that the use of post-1977  data has  resulted  in a
  good  quality  but  not  unrealistic BPT data base.

       EPA  has  modified the  BOD5  editing  criteria  to  make  them  slightly more
  stringent.  However,  it  must  be noted that  EPA does not  consider  the selection
  of editing criteria to be  a strict numerical exercise  based upon  exclusion of
  data  greater  than  a median or any other  such measure.  EPA specifically
  disagrees with the comment  that  data reflecting BPT performance must
  necessarily constitute performance levels better than  a median.   The criteria
  represent in numerical terms  what is  essentially an exercise  of the Agency's
 judgment, informed in part  by industry data, as to  the general range of
 performance that should be  attained  by the range of diverse OCPSF plants
 operating well-designed biological systems properly.  The numerical analyses
 discussed below should thus be regarded as an analytical tool that assisted
 EPA in exercising its judgment.

      The data to which the criteria have been applied reflect  the performance
 of plants that have been issued  BPT permits requiring compliance with BPT
 permit limits.  It is  not unreasonable to expect,  therefore,  that the class of
 facilities identified  as  the "best"  performers  in the industry is considerably
 larger than  it would have been had the data been  collected  in  the mid-1970s.
 This  result  is consistent with the purpose and  intent  of  the NPDES program:
 to require those plants performing below the level of  the best performers to
 improve their  performance.   Moreover, it  should be noted  that  while the major-
 ity of OCPSF plants pass  the initial  screening criteria,  a  majority of OCPSF
 plants (approximately  70  percent) will nonetheless need to  upgrade their
 treatment  systems'  performance to comply  with the BPT effluent limitations
 guidelines, based upon the  reported effluent data (for  1980),  and  the long-
 term average targets for BOD5  and TSS.  The  fact that a majority of  plants
 will need  to upgrade years  after  they received their initial BPT permits
 indicates  that the  result of the  adoption of the data base  used to develop  the
 limitations is appropriately judged the best practicable treatment.

     The editing criteria were applied to the "308"  survey data,  composed of
annual average BOD5 and TSS  data  from plants in the OCPSF industry.  The
purpose of the editing criteria was to establish a minimum level of treatment
                                   VII-160

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performance acceptable for admission of a plant's data into the data base that
would be used to determine BPT limitations.  First, only data from plants with
suitable treatment (i.e., biological treatment) were considered for inclusion
in the data base.  For these plants, the use of both a percent removal
criterion and an average effluent concentration criterion for BOD5 is
appropriate, since well-operated treatment can achieve either substantial
removals and/or low effluent levels.  In addition, use of only a percent
removal criterion would exclude data from plants  that submitted usable data
but did not report influent data.  The use of an  effluent level criterion
allowed the use of data from such plants in estimating the regression
equation.

     Following review of the data base, EPA continues to believe  that
95 percent BOD5 removal is an appropriate editing criterion.  Over half  the
plants in the "308" survey data  that reported both influent and effluent BOD5
achieve better than 95 percent removal.  The median removal for these plants
is 95.8 percent, which reflects  good removal from an engineering  point of
view.

     The Agency also continues to believe  that  a  cut-off for.,average effluent
BOD  concentration  is necessary  to  establish an acceptable  standard of
performance  in addition  to percent  removal.  In order  to establish a cutoff
value  for  the final regulation and  respond  to various .comments,  the Agency
re-examined  the  "308" survey  data.  There  are data from a  total of 99  full
response direct  discharging  plants  with end-of-pipe  biological  treatment only
 (the selected BPT  technology, as discussed below) that  reported average
effluent BOD5 and  a full range of information  regarding  production at  the
 plant.  All of  these data were used in the evaluation  of  the  BOD5 cutoff,  even
 in cases of plants that  did  not  report influent values  and  for  which  removal
 efficiencies could therefore not be estimated.   The median  BOD5  average
 effluent  for these 99  plants is  29  mg/1.   There is no  engineering or  statis-
 tical  theory that  would  support  the use of the  median  effluent  concentration
 as a cutoff for developing a regulatory data base.  In fact,  there are many
 plants that, in the Agency's best judgment, achieve excellent treatment  and
 have average effluent  values greater than the overall  median of 29.   There are
 many reasonable explanations for differences in average effluent levels  at
                                     VII-161

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 well  operated  plants.   Differences  in  a  plant's BPT  permit limitations coupled
 with  individual  company waste management practices and wastewater  treatment
 system design  and operation practices, in addition to the type of  products and
 processes at each plant, contribute  to differences in average effluent levels
 achieved.  To  obtain insight into differences in BOD5 values among different
 subcategories, the data were grouped into different  subsets based  on
 subcategory production  at each plant.  The results of this analysis are
 summarized in  Parts A and B of Table VII-51.

      The Agency grouped the data two different ways  for analysis.  Thus,  the
 data were assigned by plant into two different groupings, each with different
 subgroups, and the medians of the average BOD5 effluent values in each sub-
 group were determined.   The first grouping placed plants into three subgroups
 (plastics, organics,  and mixed)  and the second into five subgroups (fibers/
 rayon, thermoplastics,  thermosets,  organics,  and mixed).   All plants
 considered in the analysis had  biological treatment only in  place.   The
 assignment of a plant to a subgroup was determined  by the predominant
 production at the plant  (i.e., whether  a plant had  95% or more of its
 production in the subgroup).  For instance,  if a plant has 95 percent  or  more
 plastics  production,  it  was  placed  in the plastics  subgroup.   Those plants  not
 containing 95 percent or more of  a  subgroup production were classified as
 mixed.

     The  largest  subset  median average  effluent BOD5  in both groupings is
 42.5 mg/1, which  suggests  that the proposed 50 mg/1 criterion  is  high.

     In the absence of a theoretical  engineering or statistical solution  that
would determine what value should be  used in a regulatory context,  the Agency
examined some reasonable alternatives suggested by the results displayed  in
Parts A and B of Table VII-51.  The Agency considered using different  editing
criteria for different product subgroups, such as those listed in Part A  of
Table VII-51, but decided to use a single criterion to define the final data
base.
                                   VII-162

-------
                                TABLE VII-51.
                     SUMMARY STATISTICS FOR DETERMINATION
                    OF BPT BOD  EDITING CRITERIA BY GROUPS
Subset
  Number of
Plant Averages
                                                      Median of Plant
                                                      Average Effluent
                                                         BOD  (mg/1)
                  A.   Summary  of Groups  for Three Groupings
Plastics                          30
Organics                          42
Mixed (all remaining plants)      27

All Plants                        99
                                20.5
                                42.5
                                35

                                29
                 B.  Summary of Groups for the Five Groupings
Rayon/Fibers
Thermoplastics
Thermosets
Organics
Mixed  (all  remaining  plants)

All  plants    ...-..:
      7
     17
      3
     42
     30

     99
14
18
32
42.5
35.5

29
                                     VII-163

-------
      An important reason for using a single edit criterion for all subcate-
 gories is that this facilitates setting an edit criterion for the group of
 plants that do not fall primarily into a single subcategory.  These mixed
 plants comprise a significant segment of the industry; thus, regulations must
 be based on data from this segment as well.  Editing criteria that are
 subcategory-specific cannot be applied to mixed plants.  The Agency did,
 however,  examine BOD5  levels by subgroups to gain insight into what uniform
 editing criterion would be appropriate.

      For the subgroups exhibiting relatively high BOD5 levels (organics and
 mixed plants),  EPA determined that a 40  mg/1 BOD5 edit would be appropriate.
 This  value is between  the median for these  two  subgroups.   Given the fact  that
 plants with  substantial organics production tend to  have  fairly high influent
 BOD5  levels  or  complex,  sometimes difficult to  biodegrade  wastewaters,  EPA
 believes  that a more stringent  edit  would not be appropriate for these  two
 groups.  However,  EPA  believes  that  a less  stringent  edit  would  be  inappro-
 priate, since many plants  in  these subgroups meet  the 40 mg/1 criterion.

     The other  subgroups have median  values  below 40  mg/1, and EPA  examined
 them closely  to determine whether  they should be subject to  more  stringent
 edits  than the organics and mixed  subgroups.  EPA concluded  that  they should
 not for the reasons discussed below.
BOD,
     The  thermosets subgroup  contains  three  plants, whose average effluent
     levels are approximately 15, 32,  and 34 mg/1, respectively.  EPA believes
all three should be retained  in  the data base.  This is particularly important
because a major source of wastewater at the  plant with the lowest value is
only melamine resin production;  several other types of resins fall under the
thermoset classification.  Thus, including all three plants' data provides
improved-coverage of thermoset operations in the data base.  An edit of
30 mg/1 arbitrarily excludes  data from the two plants whose performance
slightly exceeds 30 mg/1 and would result in melamine resin production being
the predominant thermoset production represented in the data base.
                                   VII-164

-------
     The average BOD5 effluent values for rayon/fibers and thermoplastics are
lower than the average values for thermosets, organics, and mixed.  The Agency
evaluated the effects of these subgroups by uniformly editing the industry
data base at 30, 35, 40, and 50 mg/1, using the BPT regression approach to
calculating subcategory long-term average values.  The long-term averages
calculated for rayon/fibers and thermoplastics are relatively insensitive to
the use of the 30, 35, 40, and 50 mg/1 edited data bases.  That is, the
long-term averages are roughly the same regardless of which of these edits is
used.

     After considering the effect of  the various editing criteria on the
different subgroups discussed above,  EPA has concluded that a 95 percent/
40 mg/1 BOD  editing criterion is most appropriate.  Moreover, in defining
BPT-level performance, this criterion results in a data base that provides
adequate coverage of the  industry.

     As discussed previously,  the Agency also saw a need to edit  the data base
for TSS performance.   Some commenters recommended additional editing for TSS,
and  the Agency  agrees  that this  is justified.  The Agency  is using  two edits
for  the TSS  data.   The primary edit  is  that  the  data must  be from a plant  that
meets  the BOD5  edit  (i.e., achieves  either 95 percent  removal of  BOD5  or
40 mg/1).   Second  is an  additional requirement  that  the average effluent TSS
must be  100  mg/1 or less.  As  a  result  of  this  edit, TSS data from  61  plants
are  retained for analysis.

     In  a well-designed,  well-operated  biological  treatment  system, achievable
effluent TSS concentration levels  are related  to achievable  effluent BOD5
levels and,  in fact,  often are approximately proportional  to BOD,..  This  is
reflected  in the OCPSF data base for those plants  that meet  the BOD5  perfor-
mance  editing criteria (provided that they also exhibit  proper  clarifier
performance, as discussed below).   By using TSS data only from plants  that
have good  BOD5 treatment, the Agency is thus establishing an effective initial
edit for TSS removal by the biological system.   However,  as  BOD5  is treated
 through biological treatment,  additional TSS may be generated  in the form of
 biological solids.   Thus, some plants may need to add post-biological
 secondary clarifiers to ensure that such biological solids are appropriately
 treated.
                                     VII-165

-------
       Thus, while the 95/40 BOD5 editing ensures good BOD5 treatment and a
  basic level of TSS removal, plants meeting this BOD5 editing level will not
•  necessarily meet a TSS level suitable for inclusion in the data base used to
  set TSS limitations.  To ensure that the TSS data base for setting limitations
  reflects proper control, EPA proposed in the December 8,  1986,  Notice to
  include only data reflecting a long-term average TSS concentration of less
  than or equal to 100 mg/1.

       The December 1986 Notice requested comment on the use of the 100 mg/1 TSS
  editing criterion and,  as an alternative,  use of 55 mg/1  TSS concentration as
  the editing criterion along with setting the TSS limitations based upon the
  relationship between BOD5 and TSS.   Some commenters criticized  both the 100
  mg/1 and 55 mg/1 as  overly  stringent,  and  asserted that such additional TSS
  edits were unnecessary since the BOD5  edit was  sufficient  to assure that TSS
  was adequately  controlled.   These commenters, while agreeing that  there was a
  relationship between  BOD5 and  TSS, also  recommended a  slightly  different
  methodological  approach  for  analyzing  the BOD5/TSS relationship.

       The Agency disagrees with  the commenters who  argued in  effect  that  all
 TSS  data from plants  that meet  the BOD5  criteria be  included  in the data base
  for  setting TSS  limitations.  The Agency has examined  the data and has
 concluded  that an additional TSS edit is required  at a level  of 100 mg/1.
 Support for  this is evident in  the reasonably consistent BODg and TSS
 relationship for plants in the data set  that results from the 95/40 BOD  edit,
 for TSS values of 100 mg/1 or less.   For TSS values above 100 mg/1, there is a
 marked change in the pattern of the BOD5/TSS relationship.  Below 100 mg/1
 TSS, the pattern in the BOD5/TSS data shown in Figure VII-2 is characterized
 by a homoscedastic or reasonably constant dispersion pattern along the range
 of the data.  Above the 100  mg/1 TSS value, there is a marked spread in the
 dispersion pattern of the TSS data.   The Agency believes that this change in
 dispersion (referred  to as heteroscedastic) reflects insufficient  control of
 TSS in some of the treatment systems.   The Agency has concluded  that the
 100 mg/1 TSS edit provides a reasonable measure  of additional control of TSS
 required in good biological  treatment  systems that  have met  the  BODg edit
 criterion.
                                    VII-166

-------
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                                         VII-167

-------
      The Agency  considered a more  stringent TSS editing criterion of 60 mg/1,
 rather  than  100  mg/1.  The Agency's analysis demonstrated  that  this is not
 appropriate.  Most fundamentally,  this criterion would result in the exclusion
 of plants that EPA believes are well-designed and well-operated plants.
 Moreover, the relationship between BOD5 and TSS is well defined for plants
 with TSS less than 100 mg/1 and BOD5 meeting the 952/40 mg/1 criteria.

      The Agency gave serious consideration to the statistical method
 recommended by a commenter for the analysis of the BOD../TSS relationship.
 This commenter recommended a linear regression relationship between the
 untransformed (not converted to logarithms) BOD5 and TSS data.  The Agency has
 retained the use of a linear regression relationship between the natural
 logarithms of the BOD5 and TSS data.   The logarithmic appproach is similar to
 that recommended by the commenter,  but resulted in a somewhat better fit to
 the data.

      In  response to comments,  the Agency  also  considered  an editing criterion
 based on secondary clarifier  design criteria (i.e.,  clarifier overflow rates
 and solids loadings rates).   While  the Agency  agrees that  using  these  design
 criteria,  if  available, may have  provided  an appropriate  editing criterion,
 very little data  were  supplied  by industry in  response to  the Agency's  request
 for data regarding these  design criteria or were otherwise contained in the
 record.

 Daily Data Base Editing                                                       ;
     Prior to the calculation of  BPT variability factors,  the BPT daily data
 base was reviewed to determine  if each plant's BOD5  and TSS  data were
 representative of the BPT  technology performance.

     The BPT daily data base contains daily data from  69 plants.  The sources
of the data were  the Supplemental Questionnaire, public comment data from
plants and the State of South Carolina, and data obtained during the EPA
12-Plant Study.   The daily data, which included flow, BOD5, and TSS, were
entered on a computer data base.  The sampling site for each parameter was
identified by a treatment code that was entered along with the data.  The
                                   VII-168

-------
treatment code allowed specific identification of the sampling site within the
treatment plant.  For example, effluent data were identified as sampled after
the secondary clarifier, after a polishing pond, after tertiary filtration, at
final discharge, etc.

     After the data base was established, the data at each sampling site
were compared with the treatment system diagrams obtained in the 1983 Section
308 Questionnaire.  The comparison served to verify that the data corresponded
to the sampling sites indicated on the diagrams, and to determine if the data
were representative of the performance of OCPSF waste treatment systems.  Non-
representative data were those data from effluent sampling sites where the
treatment plant effluent was diluted (>25 percent) with uncontaminated
non-process waste streams prior to sampling; treatment systems where a
significant portion of the wastewater treated by the treatment system
(>25 percent) was uncontaminated non-process or non-OCPSF wastewater;
treatment systems where side streams of wastewaters entered the treatment
system midway through the process, and no data were available for these waste
streams; and treatment systems where the influent sampling site did not
include all wastewaters entering the head of the treatment system (e.g., data
for a single process waste stream rather than all of the influent waste
streams).

     Examination of  the data available for each plant and the treatment system
diagrams provided  the basis for exclusion of some of the plants from further
analysis.  The  criteria used were:

     •  Performance  based on more than BPT Option I controls
     •  Data not representative of the performance of the plant's treatment
        system
     •  Treatment  systems not  representative of the treatment technology
        normally used in the OCPSF industry (e.g., effluent data did not
        represent  one wastewater treatment system, such as multiple
        end-of-pipe  treatment  systems)
     •  Insufficient data due  to -infrequent sampling (less than once per week
        while operating) or omission of  one or  more parameters from  testing
         (BOD5,  TSS,  or  flow)
     •  Treatment  plant performance below that  expected from  the treatment
         technology in operation (i.e., fail to  meet the editing criteria of
        95/40 for  BOD.  and  100 mg/1 for  TSS).
                                    VII-169

-------
 Of the plants excluded from the data base, most were excluded for two or more
 reasons.  Other editing rules for plants retained in the data base included:

      •  Use of the most recent 12 months of all reported daily data when more
         than 1 year of data was available.  This allowed the Agency to use the
         data from treatment systems with the most recent treatment system
         improvements.
      •,  When historical reported long-term average and Section 308 Supplemen-
         tal Questionnaire daily data were both available for a plant,  the
         Supplemental daily data were used to calculate the long-term average
         because they provided a reproducible basis for calculating the
         averages.
      •  When daily BOD5 or TSS values- were received or calculated
         [concentration = C*(mass -f flow)] in decimal form,  they were rounded
         to the nearest milligram per liter.

      Plots of concentration versus time and  other analyses  revealed  that most
 observations clustered around  the mean with  excursions  far  above or  below the
 mean.  In  the case of influent data,  the excursions  were believed to be
 related  to production factors  such as  processing unit  startups  and shutdowns,
 accidental spills,  etc.   Effluent  excursions,  particularly  those of  several
 days  duration, were believed  to  be related to  seasonal  trends,  upsets  of the
 treatment  system,  and production factors.  Verification of  the  cause of  the
 excursions and of  the apparent outliers  in the data  bases was deemed necessary
 in order to  supplement the  analysis of  the data with engineering judgment and
 plant  performance  information.   Each plant was contacted and asked to  respond
 to a  series  of questions  regarding their treatment system,  its  performance,
 and the data submitted.  The plants were asked about seasonal effects  on
 treatment  system performance and compensatory  operational adjustments, winter
 and summer NPDES permit limits, operation problems (slug loads,  sludge
 bulking, plant upsets, etc.),  production changes and time of operation, plant
 shutdowns, and flow metering locations.  Data  observations  that were two
 standard deviations above and  below the  mean were identified, and the plants
were asked to provide  the cause of each  excursion.  The results of this effort
are described below.
                                   VII-170

-------
     The plant contacts and analysis of the data that were identified as being
more than two standard deviations above and below the mean revealed some of
the strengths and weaknesses of treatment in the industry.  Plants within the
OCPSF.industry, regardless of products manufactured at an individual plant,
experience common treatment system problems.  Daily data compiled over at
least a year show operational trends and problems, plant upsets, and seasonal
trends that would not be apparent for plants sampled less than daily.
Equalization and diversion basins are commonly used to reduce the effects of
slug loads on the treatment system and to prevent upsets.  Influent data
obtained before equalization or diversion may show high strength wastes, but
the effluent may not because of equalization and diversion.  Seasonal effects
tend  to be more pronounced in southern climates because treatment systems
there generally may not be designed for cold weather.  Operational techniques
to compensate for reduced efficiency are similar and should be practiced
industry-wide whenever needed or impossible with the existing treatment
system.

      While common operational problems appear to be consistent across the
industry, responsive  treatment system design and operation changes are not
fully documented within the data base.  For example, some  treatment  systems
incorporating similar unit operations produced substantially different
effluent quality.  The reasons for  this may include strength and  type of raw
wastes, capacity of  the treatment system  (under- or overloaded),  knowledge and
skill of operating personnel, and design  factors.  While  the raw  waste  type
can  be  categorized somewhat by dividing  the OCPSF industry into subcategories,
the  degree  to which  the other factors affect plant performance may not  be
readily apparent in  the data.  For  example, the daily data may not show
seasonal  trends  because of  plant design  or  operational  adjustments which
adequately  compensate for cold weather.

      Sampling and  analytical  techniques  are another  potential  problem area of
 the  data  base,  particularly for  the BOD5  data.  The  OCPSF industry manufac-
 tures and  uses a multitude of  toxic substances  that  can affect  a  bioassay  such
 as the BOD5  test.  Also,  certain facilities sometimes  collect  unrefrigerated
.BOD  composite samples which  will  affect the results  of the  analysis.
 However,  since the majority of  the effluent data  were  collected  for  NPDES
                                    VII-171

-------
   permit  compliance  and  approved  analytical  methodologies  (such as  standard
   methods or  EPA's test  method) and  QA/QC procedures  are stipulated in each
   facility's  NPDES permit,  it was assumed that  the  effluent  data utilized  were
   collected and analyzed in an acceptable manner.

       Table  VII-52  presents a summary of the plants  that were  excluded  from  the
   BPT daily data base and the reasons for the exclusion.  Appendix  VII-C
   presents a  plant-by-plant accounting of all 69 BPT  daily data plants and
   provides detailed  explanations  of  each  plant's inclusion or exclusion.

       Based  on the  BPT  daily data base editing, daily data  from a  total of
  21 plants remain to calculate BOD5 variability factors and 20 plants remain to
  calculate TSS variability factors  (one  plant does not meet the TSS editing
  criterion).   For these plants,  all reported daily data from the most recent
  12 months of sampling were included in  the calculation of variability factors
  because the Agency could not obtain sufficient information through plant
  contacts and followup efforts to provide an adequate basis for deleting any
  specific daily data points.

  Derivation of Subcategory BOD.,  and TSS Long-Term Averages (LTAs)
      As  presented previously in  Section IV, the Agency's  final revised
  subcategorization approach also  included a  methodology for calculation of BPT
  BOD5 and TSS LTAs for each subcategory,  which  are  used together with vari-
  ability  factors  to  derive  facility  subcategorical  daily and monthly maximum
  limitations. Recall  from  Section IV  that the  final  subcategorization model is
  given by:
               = a

 To estimate the average l^BOD.J corresponding  to a set of  the  independent
 variables wi;j, I4i, and Ib£,  the random error term e.^ is deleted.  The
 estimates of the coefficients a, !.,, B, and D are used with  the values of the
' independent variables to obtain the estimate.
                                    VII-172

-------

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VII-173

-------
      The LTA BOD5 for subcategory k is based on a plant that has 100 percent
 of its OCPSF production in subcategory k.  Therefore, to obtain the LTA BOD5
 for subcategory k, set
            If J=k
            0,
 Also,  because the subcategorical LTA BOD5 is based on a plant that satisfies
 the BOD5 95/40 criterion (set I41=l) and that has biological only treatment
 (set Ibi-l),  it follows that the BOD5 LTA for subcategory k is given by


     BOD5  LTAk = exp [a + Tk + B + D],


 where  a, Tk,  B,  and D are estimates of  the model parameters given in Appendix
 IV-A,  Exhibit 1.   The estimates are derived from the data base of 157 full-
 response,  direct  discharge OCPSF facilities that have at  least biological
 treatment  in  place,  and that provided BOD5  effluent  and subcategorical produc-
 tion data.  The  parameter estimates are restated below and the subcategorical
 LTAs for BOD5  are given in Table VII-53.
     Parameter

     a+Tl:  Thermoplastics
     a+T2:  Thermosets
     a+T3:  Rayon
     a+T4:  Other Fibers
     a+T5:  Commodity Organics
     a+T6:  Bulk Organics
     a+T7:  Specialty Organics
        B:  Performance Shift
        C:  Treatment Shift
 Estimate

 4.27270510
 5.22885710
 4.32746980
 4.03782486
 4.49784137
 4.66262711
 4.92138427
-1.94453768
 0.41834828
     The subcategory LTAs for TSS are based on the final subcategorization
regression model for TSS, which was presented in Section IV as:


     In (TSSi) = a + b [ln(BOD..)] + e. .
                                   VII-174

-------
The estimates of the regression parameters a and b are derived from the
61 OCPSF plants that have at least biological treatment in place, meet the
95/40 editing criteria for BOD5, and have TSS effluent concentrations of at
most 100 mg/1.  The estimates of parameters a and b are presented in Appendix
IV-A, Exhibit 2, and they are:
and
     a = 1.84996248
     b = 0.52810227.
Now, this model  is used  to provide  subcategorical TSS  LTAs  corresponding to
the subcategorical BOD5  LTAs.  Again,  e.^  is  set  to  zero  in  the model,  and

     TSS LTAR  =  exp  (a + b lln(BOD5  LTAk)]

for k=l, 2,  ...,  7.   The calculated TSS LTA  values  are given in Table  VII-54.

     These  subcategorical BOD,, and  TSS LTAs  allow  the  determination of
                              •*   -.
plant-specific BOD5  and  TSS  LTAs, even for a plant  that  has production in more
than one subcategory. These plant-specific  LTAs are then used with variability
factors  to  derive the effluent limitations guidelines  presented in Section IX.

     In  particular,  for  a'^specific  plant, let w.. be the  proportion of that
plant's  production in subcategory j.  The plant-specific LTAs are given by:
      Plant BOD,.  LTA - £   w.(BOD  LTA )
 and
Plant TSS LTA =
                          w..(TSS LTA..),
 where BOD  LTA. and TSS LTA. are the BOD. and TSS long-term averages presented
          5    ]            3            s
 in Tables VII-53 and VII-54, respectively.  This approach is analogous  to the
 building-block approach typically used by permit writers.
                                     VII-175

-------
                                  TABLE VII-53.
                BPT SUBCATEGORY LONG-TERM AVERAGES  (LTAs) FOR BOD
  Subcategory
                                                     BOD  LTA  (mg/1)
 Thermoplastics
 Therraosets
 Rayon
 Other Fibers
 Commodity Organics
 Bulk Organics
 Specialty Organics
  16
  41
  16
  12
  20
  23
  30
                                 TABLE VII-54.
               BPT SUBCATEGORY LONG-TERM AVERAGES (LTAs) FOR TSS
 Subcategory
                                                    TSS LTA  (mg/1)
Thermoplastics
Thermosets
Rayon
Other Fibers
Commodity Organics
Bulk Organics
Specialty Organics
27
45
27
24
31
33
38
                                   VII-176

-------
Calculation of BPT Variability Factors
     After establishing a, final BPT daily data base, data from 21 plants for
BOD  and 20 plants for TSS were retained to calculate variability factors
using the statistical methodology shown in Appendix VII-D.  These statistical
methods assume a log-normal distribution; hypothesis tests investigating this
assumption are discussed in Appendix VII-E.  The Agency has been using the
95th percentile average "Maximum for Monthly Average" and the 99th percentile
average "Maximum for Any One Day" variability factors for BOD5 and TSS,
regardless of the subcategory mix of each plant.  However, many industry
commenters argued that effluent variability was subcategory-specific  and
should be  taken into account in variability factor  calculations.  In  response
to  these comments,  the Agency performed an alternative variability factor
analysis which calculated  production proportion-weighted  variability  factors
by  category  (plastics or organics)  and  subcategory  for the  21 daily data
plants for BOD5 and the 20 plants  for TSS.  Table VII-55  presents  the results
of  this analysis which compares overall average variability factors with  the
subcategory  production proportion-weighted variability factors.  This
comparison shows  that subcategory-specific variability factors  are  not
substantially different  from the  overall  average  variability factors.  This
would  be  expected  since  subcategory differences would be reflected  more in the
long-term average  values,  while variability  factors are  dependent ,on treatment
system performance which is fairly consistent given that all plants use
biological treatment and perform well (i.e.,  after the 95/40/100 editing
 rule).   Based on the results of this alternative subcategory weighted
 variability factor analysis, the Agency has  decided to retain its approach of
 calculating overall average variability factors and applying them to all OCPSF
 facilities.

      Individual plant variability  factors are listed in Tables VII-56 and
 VII-57 for BOD5 and TSS, respectively.  As shown in the tables, the  average
 BOD  Maximum for Monthly Average and Maximum for Any One Day variability
 factors are 1.47 and 3.97, respectively.  The average TSS Maximum for Monthly
 Average and Maximum for Any One Day variability factors are 1.48 and 4.79,
 respectively.
                                     VII-177

-------
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                                         VII-179

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                                                 VII-180

-------
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                                                            VII-182

-------
     2.   BAT Effluent Limitations

     As discussed in Section VI, the Agency has decided to control 63 toxic

pollutants under BAT Subcategory One (End-of-Pipe Biological Plants) and 59

toxic pollutants under BAT Subcategory Two (non-End-of-Pipe Biological

Plants).  This section discusses the data editing rules and methodology used

to derive the toxic pollutant long-term averages and variability factors that

provide the basis of the final BAT effluent limitations guidelines for both

subcategories.                                             ,   .


         a.  BAT Data Editing Rules

     The BAT toxic pollutant data base has basically two sources of data:

1) data collected during EPA sampling studies, and 2) data submitted by
industry either in response to  Section 308 Questionnaire requests or as a

result of submissions during the public comment periods for ,the March 21,

1983, Proposal, the July 17, 1985. Federal Register Notice of Availability, or
the December 8, 1986, Federal Register Notice  of Availability.  Table VII-58

presents a  summary of the BAT toxic  pollutant  data sources as organized into

four sets for review and editing purposes.


     In general,  the Agency's BAT  toxic pollutant data base editing criteria

were as follows:


     •  Analytical methodology  had to be  EPA-approved  (or  equivalent) and  have
        adequate  supporting QA/QC  documentation.

     •  It  was  not necessary  to have influent-effluent data pairs for  the  same
        day,  because many  treatment  systems  have  a wastewater  retention time
        of  more than 24 hours.

     •   Since most  of  the  effluent data have values  of ND,  the average
         influent  concentration  for a compound had to be  at least  10 times  the
         analytical  minimum level ;(ML)  for the difference to be meaningful  and
         qualify effluent concentrations for  calculation  of effluent limits.
         For in-plant control  effluent  data for steam stripping and activated
         carbon, the average influent concentration  for a compound had  to be at
         least 1.0 ppm.

      •  Exclude data for effluent  that  has been diluted  more  than 25 percent
         after treatment, but  before final discharge.  NPDES monitoring data
         often reflects such dilution,  which may be  discerned  by reference to
         the wastewater flow diagram in a plant's response to  the 1983 Section
         308 Questionnaire.  Appendix VII-G characterizes the  problems
         associated with dilution of NPDES application Form 2C data.
                                     VII-183

-------
                                  TABLE VII-58.
        PRIORITY POLLUTANT (PRIPOL) DATA SOURCES FOR THE FINAL OCPSF RULE
 EPA Sampling Programs

      1.1  37 Plant Verification Study, 1978-80
      1.2  Five Plant Study, 1980-81 (EPA/CMA Study)

      2.0  Twelve Plant Study, 1983-84

 OCPSF Proposal. 48 FR 11828 (March 21. 1983)

      3.1  Data attached to 28 public comments

 1983 Supplemental "308" Questionnaire*
      (sent to selected plants only)

      3.2  Data submitted by 74 selected plants

 NOA (Proposal Revision 1),  50 FR 29068 (July 17,  1985)

      4.1  Data attached to  comments,  or requested by EPA
           as  an extension of the attached  data**

      4.2  Requested  from commenters,  because the  comment
           implied  that  supporting  data were  available**

NOA (Proposal Revision  2).  51  FR 44082 (Dec.  8, 1986)

     4.3  Data  attached  to  comments from 5 commenters
Data  Set  1
Data Set 2

Data Set 3
Data Set 4
  ™f     r?f r?f EirV Prlori1ty Pollutant data submitted in response to
  questions C13-C16 of the general questionnaire were average concentration
  values instead of daily concentration values. This precluded the use of the
  data for statistical calculation of effluent limitations.

**Data from a total of 21 plants were reviewed for data sets 4.1 and 4.2.
                                   VII-184

-------
    •  Cyanide should be considered as having an analytical minimum level of
       0.02 mg/1, and subject to the four criteria listed above.

    •  For data submitted by industry, exclude total phenols data, which
       become meaningless with the specific measurement of phenol (priority
       pollutant 65).  The total phenol parameter represents a colorometric
       response to the 4-Aminoantipyrine (4-AAP) reagent, which is non-
       specific and characteristic of a host of both phenolic and non-
       phenolic organic chemicals.

    •  Data not representative of BAT technology performance were eliminated
       from the data base.  Examples of reasons for not being representative
       of BAT technology performance include process spills; treatment system
       upsets; equipment malfunctions; performance not up  to design specifi-
       cations; past historical performance; or performance exhibited by
       other plants  in  the data base with BAT  technology in place.

    •  Exclude data  for pollutants  that could  not be validated  as present
       based on  the  product/processes and  the  related process chemistry
       associated with  each product/process.   Examples include  phthalate
       esters found  because of sample contamination by the automatic  sampler
       tubing and methylene chloride  found  because of sample contamination in
       the  laboratory  (methylene  chloride  is a common extraction  solvent  used
       in GC/MS  methods).

     •  Data for  pollutants  that do  not  satisfy the 10  times  ML  editing
       criteria  at  the  influent  to'the  end-of-pipe  treatment sampling site,
       because  their original raw waste concentrations had been reduced
       previously by an in-plant  control  technology, were  retained  when
       sufficient  information (i.e.,  verification,  12-Plant  Sampling Reports,
       or  Section 308 Questionnaire)  was  available  to  validate  the  in-plant
       control's presence.


     In addition to  the detailed editing criteria presented above, more

general editing criteria involved;


     •  Deletion of presampling grab samples collected prior to the EPA
        12 Plant Sampling Study

     •  Choosing the appropriate sampling sites for the treatment system of
        interest( e.g., influent to and effluent from steam stripper for BAT
        Subcategory Two data base)

     •  Deletion of not quantifiable (NQ) values discussed above

     •  Averaging of replicate and duplicate samples or analyses at a sampling
        site by day and, if appropriate, then  across multiple laboratories.
        All data points in decimal  form as  a result of replicate and duplicate
        averaging were  rounded to the nearest  whole number (in  ppb)
                                    VII-185

-------
          SSt I™ ?  Z!r° dlscha5&ers a°d plants without  appropriate BAT or
          PSES treatment systems (e.g.,  indirect  dischargers  without  appropriate
          in-plant controls such as  steam stripping,  and direct  dischargers
          without end-of-pipe biological treatment or in-plant controls).

                                              BAT
      •  Deletion  of  plants with more  than  the recommended BAT  treatment
         technology.   [Plant  2680V  from  the BAT Subcategory Two data base]


      •  Deletion  of  plants without a  combined raw waste sampling point, or if

         430V,P1563V]  r°CeSS Sampling data were collected at a plant.  [Plants
                             tOXl  P°llutant data f"m six plants for which
                                              vere utnized-  [piants
      •  Deletion of plant/pollutant combinations for which no effluent data
         exist
         ™tHm* combinations when all influent values were
         not detected (ND) (except for the overrides discussed above for
         pollutants that do not satisfy the 10 times ML editing criteria)


      •  All values reported by the analytical laboratory at less than the

         level      minimum level were set equal to the analytical minimum
         *nn    °f,combined Pollutant analytical results  (e.g.,  anthracene
         and phenanthrene reported as  a combined total concentration)
             »na      Xf ora^ory-comPosited  volatile  grab  samples  as  required  by
         the  analytical protocols  instead of  individual grab  or automatic
         composite  sample  analyses


     •   Deletion of  plant/pollutant  combinations based on BAT Option III

         and  £ni°S ^'*"  ^^ Controls, end-of-pipe biological treatment,
         and  end-of-pipe activated carbon).   [Plant  1494V, benzene]


     •   Deletion of  plants which  will be regulated  under another point source
         category.  [Plant  1099V under the  Petroleum Refining Point Source
         Category] .




     In addition to  the editing criteria mentioned above, the Agency also

established another set of editing criteria in reviewing priority pollutant

metals data:
                      °!! *riori*y Poll«tant metals from non-process sources,
          »     non-contact cooling water blowdown and ancillary sources.   An
        example of an ancillary source is caustic, which commonly assays for
        low levels of Cr(119), Cu(120),  Ni(124),  and sometimes Hg(123)
                                   VII-186

-------
    •  Excluded end-of-pipe  (NPDES) data, as well as data  from  other  sampling
       points, that do not represent  the direct  effluent from technology  that
       is specifically for the  control  of metals.   In  general,  NPDES  monitor-
       ing  data do not directly reflect the reduction  of.priority, pollutant
       'metal  concentrations  by  such technology.  Rather, the data reflect
       dilution (by process  wastewater  and non-contact cooling  water) and/or
       absorption into biomass  (if biological  treatment of the  process waste-
       water  is employed).   Both dilution and  biomass  absorption of priority
       pollutant  metals  are  plant-specific factors  that vary widely through-
       out  OCPSF  wastewater  collection  and treatment systems.         -

    •  Exclude complexed priority pollutant metal data, unless  it is  .the
       direct effluent from  technology  that  is specifically for the control
       of  complexed  priority pollutant  metals.  This  edit  is generally appli-
       cable  to priority pollutant metals  (e.g., chromium*3 and copper+2)
       that have  been very strongly  complexed  with  organic dyes or chelating
       compounds, so  that the metal  remains  in solution and is  unresponsive
        to  precipitation  with usual reagents  (lime or  caustic).

     •  Exclude data that represent the  direct  effluent from technology
       specifically for  the control  of  metals, if there is no  corresponding
        influent  data with which to evaluate  the effectiveness  of the
        technology.                                              .


     The  Agency's  editing procedure differed somewhat  for each data, source.

The data from the EPA sampling programs were edited using a combination of

computer analysis  and manual analysis by Agency personnel.   This was  done
because al.l sampling data had previously been  encoded.  Data submitted by
industry were first reviewed to determine if the data  submitted warranted,
encoding for  further study, lending itself to  manual editing rather than
computer analysis.  However, all manual editing  that could  be validated by
computer analysis (e.g.,  the 10 x ML/1.0 ppm edit)  was performed.   Based  on

this analysis, data from industry sources for  a  total  of 17 plants  were

retained for  use  in calculation of final BAT effluent  limitations.  Table
VI1-59 presents a summary of  the  data retained for  each plant and how-, it  was

utilized.


     Table  VII-60 presents a detailed explanation of  the data excluded from
the limitations analysis based  on the BAT performance  editing criterion.

Based on this analysis,  data from a  total of 36 plants (plus six plant
overlaps due  to resampling)  for Subcategory One and 10 plants for Subcategory
Two  (with  nine plant  overlaps with Subcategory One) from Agency studies and

public comments were  retained for the limitations  analysis, and,  are presented

in Table VII-61 for  BAT  Subcategory  One and Table VII-62  for BAT Subcategory

Two.
                                    VII-187

-------
                 TABLE VII-59.
DATA RETAINED FROM DATA SETS 3 AND 4 FOLLOWING
     BAT TOXIC POLLUTANT EDITING CRITERIA
Plant ID
63
387
500
682
1012
1650
1753
2227
1617
2445
2693
267
399
415
913
1769
1774
T, -,-, Data
Pollutants set
Zinc 3
Zinc 3
Nitrobenzene 3
Toluene 3
Zinc 3
Benzene, Naphthalene, Phenanthrene, 3
Toluene
Ethylbenzene 3
1,2-4-Trichlorobenzene, 1,2-Dichloroben- 3
zene, Nitrobenzene
Toluene 3
Methylene Chloride, Phenol 3
Chloroform, Methylene Chloride 3
Methylene Chloride 4
Zinc 4
Benzene, Toluene 4
1,2-Dichloroethane, 1,1,1-Trichloroe thane, 4
1,1,2-Trichlorethane, Chloroethane, Chloro-
form, 1,1-Dichloroe thane, 1,2-Trans-
Dichloroethylene, 1,1-Dichloroethylene,
Methylene Chloride, Tetrachloroethylene,
Trichloroethylene, Vinyl Chloride
Chlorobenzene, Chloroethane, 4
1 , 2-Dichlorobenzene, 2 , 4-Dini trotoluene ,
2,6-Dinitrotoluene, Nitrobenzene, Phenol
Zinc 4
BAT Subcategory
Data Base
One and Two
One and Two
Two Only
One Only
One and Two
One Only
One Only
One Only
One Only
One Only
One Only
One Only
One and Two
Two Only
Two Only
One Only
One and Two
                 VII-188

-------

TABLE VII-60.
F BAT TOXIC POLLUTANT DATA
PERFORMANCE EDITS
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This pollutant should be treated in-plant with activated carbon
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because the listed pollutants were basically passing through the
activated carbon system untreated, this plant's treatment system
performance was considered inadequate.

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                                                         VII-190

-------
                         TABLE VII-61.
PLANT AND POLLUTANT DATA RETAINED IN BAT ORGANIC TOXIC POLLUTANT
          DATA BASE FOR BAT  SUBCATEGORY  ONE  LIMITATIONS
Plant ID
2394








2536


725








3033





384





415








Data Set Pollutant #
1 7
25 .
27
38
57
58
59
65
86
1 3
38
65
1 6
9
12
23
44
45
52
85
88
1 10
32
34
55
65
85
1 	 	 	 4.
38
55
65
76
86
1 10
14
16
23
' • 	 ' 	 "•• 	 - 29
30
32
44
87
Pollutant Name
Chlorobenzene
1 , 2-Dichlorobenzene
1 , 4-Dichlorobenzene
Ethylbenzene
2-Nitrophenol
4-Nitirophenol
2 , 4-Dini trophenol
Phenol
Toluene
Acrylonitrile
Ethylbenzene
Phenol
Carbon Tetrachloride
Hexachlorobenzene
Hexachloroe thane
Chloroform
Me thylene Chloride
Chloromethane
Hexachlorobu tad i ene
Tefrachloroe thylene
Vinyl Chloride
1,2-Dichloroethane
1,2-Dichloropropane
2 , 4-Dimethylphenol
Naphthalene
Phenol
Tetrachloroe thylene
Benzene
Ethylbenzene
Naphthalene
Phenol
Chrysene
Toluene
1,2-Dichloroethane
1,1, 2-Trichloroethane
Chloroe thane
Chloroform
1,1, -Dichloroethylene
1 , 2-Trans-dichloroe thylene
1 , 2-Dichloropropane
Methylene Chloride
Trichloroe thylene
                              VII-191

-------
                                   TABLE VII-61.
         PLANT AND POLLUTANT DATA RETAINED IN BAT ORGANIC TOXIC POLLUTANT
                   DATA BASE FOR BAT SUBCATEGORY ONE LIMITATIONS
                                    (Continued)
 2313
 2631
2481
   1
   4
  34
  39
  55
  65
  72
  73
  74
  75
  76
  77
  78
  80
  81
  84
  86

  8
 24
 25
 26
 31
 58
 81

  4
 10
 14
 16
 23
 29
 30
 32
 33
 38
 44
 86
 87

 4
56
59
  Acenaphthene
  Benzene
  2,4-Dimethylphenol
  Fluoranthene
  Naphthalene
  Phenol
  Benzo(a)Anthracene
  Benzo(a)Pyrene
  3,4-Benzofluoranthene
  Benzo(k)Fluoranthene
  Chrysene
  Acenaphthylene
  Anthracene
  Fluorene
  Phenanthrene
  Pyrene
  Toluene

  1,2,4-Trichlorobenzene
  2-Chlorophenol
  1,2-Dichlorobenzene
  1,3-Dichlorobenzene
 2,4-Dichlorophenol
 4-Nitrophenol
 Phenanthrene

 Benzene
 1,2-Dichloroethane
 1,1,2-Trichloroethane
 Chloroethane
 Chloroform
 1,1-Dichloroethylene
 1,2-Trans-dichloroethylene
 1,2-Dichloropropane
 1,3-Dichloropropene
 Ethylbenzene
 Methylene Chloride
 Toluene
 Trichloroethylene

Benzene
Nitrobenzene
2,4-Dini trophenol
                                   VII-192

-------
                         TABLE VII-61.
PLANT AND POLLUTANT DATA RETAINED IN BAT ORGANIC TOXIC POLLUTANT
          DATA BASE FOR  BAT  SUBCATEGORY  ONE  LIMITATIONS
                           (Continued)
Plant ID
948










267



12






2221


2711

725







444

Data Set Pollutant #
2 3
4
10
29
38
65
66
68
70
71
86
2 8
25
31
65
2 1
4
34
38
55
65
86
3 38
65
86
3 65
86
3 6
10
12
23
30
52
85
88
3 4
86 ,
Pollutant Name
Acrylonitrile
Benzene
1 , 2-Dichloroe thane
1 , 1-Dichloroethylene
Ethylbenzene
Phenol
Bis-(2-Ethylhexyl)Phthalate
Di-N-Butyl Phthalate
Diethyl Phthalate
Dimethyl Phthalate
Toluene
1 , 2-4-Trichlorobenzene
1 , 2-Dichlorobenzene
2 , 4-Dichlorophenol
Phenol
Acenaphthene
Benzene
2 , 4-Dimethylphenol
Ethylbenzene
Naphthalene
Phenol
Toluene
Ethylbenzene
Phenol
Toluene
Phenol
Toluene
Carbon Tetrachloride
1 , 2-Dichloroethane
Hexachloroe thane
Chloroform
1 , 2-Trans-dichloroethylene
Hexachchlorobutadiene
Tetrachloroethylene
Vinyl Chloride
Benzene
Toluene
                              VII-193

-------
                          TABLE VII-61.
PLANT AND POLLUTANT DATA RETAINED IN BAT ORGANIC TOXIC POLLUTANT
         DATA  BASE  FOR  BAT  SUBCATEGORY  ONE  LIMITATIONS
                          (Continued)
Plant ID Data Set Pollutant
695 3 4
6
10
23
24
25
29
32
38
42
44
55
65
86
L650 3 4
38
55
65
77
80
81
86
•48 3 3
65
66
68
70
71
430 3 4
55
65
86
349 3 3
88
# Pollutant Name
Benzene
Carbon Tetrachloride
1 , 2-Dichloroethane
Choloroform
2-Chlorophenol
1 , 2-Dichlorobenzene
1,1-Dichloroethylene
1 , 2-Dichloropropane
Ethylbenzene
Bis-(2-Chloroisopropyl) Ether
Methylene Chloride
Naphthalene
Phenol
Toluene
Benzene
Ethylbenzene
Naphthalene
Phenol
Acenaphthylene
Fluorene
Phenanthrene
Toluene
Acrylonitrile
Phenol
Bis-(2-^Ethylhexyl) Phthalate
Di-N-Butyl Phthalate
Diethyl Phthalate
Dimethyl Phthalate
Benzene
Naphthalene
Phenol
Toluene
Acrylonitrile
Vinyl Chloride
                          VII-194

-------
                         TABLE VII-61.
PLANT AND POLLUTANT DATA RETAINED IN BAT ORGANIC TOXIC POLLUTANT
          DATA  BASE FOR BAT,SUBCATEGORY  ONE  LIMITATIONS
                           (Continued)
Plant ID
1494









883

659
1609






851








1890
1890*

Data Set Pollutant #
3 25
35
36
44
56
57
58
	 59
65
86
3 3
38
3 38
3 4
23
24
- 31
65
86
87
3 4
38
39
55
78
80
81
84
86
3 86
3 65
86
Pollutant Name
1 , 2-Dichlorobenzene
2 , 4-Dini t ro toluene
2,6-Dinitrotoluene
Methylene Chloride
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2 , 4-Dini trophenol
Phenol
Toluene
Acrylonitrile
Ethylbenzene
Ethylbenzene
Benzene
Chloroform
2-Chlorophenol
2 , 4-Dichlorophenol
Phenol
Toluene
Trichloroethylene
Benzene
Ethylbenzene
Fluoranthene
Naphthalene
Anthracene
Fluorene
Phenanthrene
Pyrene
Toluene
Toluene
Phenol
Toluene
                              VII-195

-------
                                 TABLE VII-61.
       PLANT AND POLLUTANT DATA RETAINED IN BAT ORGANIC TOXIC POLLUTANT
                 DATA BASE FOR BAT SUBCATEGORY  ONE LIMITATIONS
                                  (Continued)
Plant ID
Data Set    Pollutant #
                                             Pollutant Name
2631 3 4
10
11
14
16
23
29
32
33
38
55
65
86
i051 3 4
10
32
33
86
87
196 3 4
10
11
65
86
06 3 1
4
34
39
65
72
76
77
78
81
84
86
57 4 44
'2 4 86
Benzene
1 , 2-Dichloroethane
1,1, 1-Trichloroethane
1,1,2-Trichloroethane
Chloroethane
Chloroform
1,1-Dichloroethylene
1 , 2-Dichloropropane
1 , 3-Dichloropropene
Ethylbenzene
Naphthalene
Phenol
Toluene
Benzene
1 , 2-Dichloroethane
1, 2-Dichloropropane
1, 3-Dichloropropene
Toluene
Trichloroethylene
Benzene ,
1 , 2-Dichloroethane
1,1, 1-Trichloroethane
Phenol
Toluene
Acenaphthene
Benzene
2 , 4-Dimethylphenol
Fluoranthene
Phenol
Benzo(a)Anthracene
Chrysene
Acenaphthylene
Anthracene
Phenanthrene
Pyrene
Toluene
Methylene Chloride
Toluene
                                 VII-196

-------
                                TABLE VII-61.
       PLANT AND POLLUTANT DATA RETAINED IN BAT  ORGANIC TOXIC  POLLUTANT
                DATA BASE FOR BAT SUBCATEGORY ONE LIMITATIONS
                                 (Continued)
Plant ID
Data Set    Pollutant #
                                             Pollutant Name
1617

1650




1753
   4

   4
86

 4
55
81
86

38
Toluene

Benzene
Naphthalene
Phenanthrene
Toluene

Ethylbenzene
1769






2227


2445

2693

4 7
16
25
35
36
56
65
4 8
25
56
4 44
65
4 23
	 44
Chlorobenzene
Chloroe thane
1 , 2-Dichlorobenzene
2 , 4-Dini trotoluene
2 , 6-Dini trotoluene
Nitrobenzene
Phenol
1 , 2-4-Trichlorobenzene
1 , 2-Dichlorobenzene
Nitrobenzene
Methylene Chloride
Phenol
Chloroform
Methylene Cloride
 Note:   * denotes  a plant  which had tvo different  treatment  systems  in the data
        base
        Data Set  1 denotes 12-Plant Study.
        Data Set  2 denotes 5-Plant  Study.
        Data Set  3 denotes Verification Study.
        Data Set  4 denotes public comments  and  supplemental  questionnaire data.
                                    VII-197

-------
                          TABLE VII-62.
PLANT AND POLLUTANT DATA RETAINED IN BAT ORGANIC TOXIC POLLUTANT
          DATA BASE  FOR BAT  SUBCATEGORY  TWO  LIMITATIONS
Plant ID
725


1494
415







2680
415

913











2680




500
)48



Data Set Pollutant #
1 44
45
88
1 4
1 10
14
16
23
' 29
30
44
87
1 4
3 4
86
3 10
11
13
14
16
23
29
30
44
85
87
88
1 56
57
58
59
60
3 56
2 66
68
70
71
Pollutant Name
Methylene Chloride
Chlorome thane
Vinyl Chloride
Benzene
1 , 2-Dichloroetheane
1, 12-Trichloroethane
Chloroe thane
Chloroform
1 , 1-Dichloroethylene
1 , 2-Trans-Dichloroethylene
Methylene Chloride
Trichloroethylene
Benzene
Benzene
Toluene
1 , 2-Dichloroethane
1 , 1 , 1-Trichloroethane
1 , 1-Dichloroethane
1,1, 2-Trichloroethane
Chloroe thane
Chloroform
1 , 1-Dichloroethylene
1 , 2-Trans-Dichloroethylene
Methylene Chloride
Te t rachloroe thylene
Trichloroethylene
Vinyl Chloride
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2 , 4-Dini trophenol
4 , 6-Dini tro-o-Cresol
Nitrobenzene
Bis-(2-Ethylhexyl) Phthalate
Di-n-Butyl Phthalate
Diethyl Phthalate
Dimethyl Phthalate
                           VII-199

-------
                                TABLE VII-62.
       PLANT AND POLLUTANT DATA RETAINED IN BAT ORGANIC:TOXIC POLLUTANT
                DATA BASE FOR BAT SUBCATEGORY TWO LIMITATIONS
                                 (Continued)
Plant ID
Data Set
Pollutant #
                                             Pollutant Name
2536 1 3
1293 1 1
34
39 '
55
65
72
73 "
74 , '
75
76
77
78
80
81
84
Acrylonitrile
Acenaphthene
2 , 4-Dimethylphenol
Fluoranthene
Naphthalene
Phenol
Benzo(a) Anthracene
Benzo(a)Pyrene
3 , 4-Benzof luoranthene
Benzo(k) Fluoranthene
Chrysene
Acenaphthylene
Anthracene
Fluorene
Phenanthrene
Pyrene
Note:  Data Set 1 denotes 12-Plant Study.
       Data Set 2 denotes 5-Plant Study.
       Data Set 3 denotes public comments and supplemental questionnaire data.
                                    VII-200

-------
      One industry commenter questioned the validity of treating pollutant data
 from one plant in two different sampling projects independently.  It should be
 noted that the six plant overlaps occur because these plants were either
 sampled in separate Agency studies or the Agency received data submitted by
 commenters in addition to its sampling studies.  EPA has treated these over-
 lapping plant data sets separately for limitations calculations purposes
 because of general changes in a plant's production levels and product mix,  and
 changes in a plant's treatment system or treatment system operation in the
 time period between sampling studies.  Using the plant data in this manner did
 not significantly affect most of the pollutants being regulated.

      EPA reviewed its files on these six plants relating to circumstances at
 the plants during the sampling episodes.   Plant 725  upgraded a steam bath to a
 steam stripper by adding trays between sampling episodes.   Plant  2631 had two
 processes in  operation during the  first  sampling event and  three  on the
 second.   EPA,  accordingly,  maintains that  the  4 data sets associated with
 these 2  plants be treated  separately because of the  referent known  changes.

      For the  remaining four  plants,  EPA combined  the  corresponding eight data
 subsets  into  four to  yield  a  single  data set for each  of the four plants.  EPA
 then  recomputed all of the  end-of-pipe BAT toxic limitations to perform a
 comparative analysis  of  these  results  to those  for the EPA methodology  for
 calculating daily maximum limitations for all of the 55 organic pollutants
 derived  by this analysis.

     The findings were that 11 of the 55 daily  limitations changed value, but
 for seven of the  11 changes the shifts were only 5 percent or less.   For  the
 four limitations  that showed larger changes,  two increased and two decreased.

     EPA maintains that the general rationale for treating these six plants as
12 separate entities is appropriate and that  there is no bias introduced by
this approach.
                                   VII-200

-------
         b.  Derivation of BAT Toxic Pollutant LTAs
     Table VII-63 presents a .summary of the plants retained in the BAT toxic
pollutant data base for BAT Subcategory One and Two, and the in-plant and
end-of-pipe technologies in-place at each plant based on the 1983 Section 308
Questionnaire for industry-supplied data and on field sampling reports for,EPA
data.  The table shows that the technology basis for the data to be used for
BAT Subcategory One is mainly end-of-pipe biological treatment (in the form of
activated sludge) preceded in many cases by some form of in-plant control.
These in-plant controls are sometimes in the form of highly efficient tech-
nologies such as activated carbon or steam stripping, or are a more gross form
of control used more for product recovery (e.g., distillation), but nonethe-
less contributing to a reduction.or equalization of raw waste concentrations
discharged to the end-of-pipe biological treatment system.  The technology
basis for the BAT Subcategory Two toxic pollutant data base is based on
performance data from in-plant controls such as steam stripping, activated
carbon, and in-plant biological treatment.

     For each pollutant at each plant from each of  the four data sets, an
estimated long-term average (LTA) effluent concentration .was calculated.  The
nondetected values at a plant were assigned an analytical minimum level value
using the minimum levels associated with EPA analytical methods 1624 and 1625.
The estimated long-term average was computed using  a method that assigned
nondetected values a relative weight in accordance with the frequency with
which nondetected values for the pollutant were found in the daily data plants
as defined in Appendix VIII-C.

     The estimated long-term average, m, for a plant-pollutant combination  is
as follows:          .
                                X.
          =   pD
(1 - p)
                               n
                                    VII-201

-------
                                 TABLE VII-63.
                   TREATMENT TECHNOLOGIES FOR PLANTS IN THE
                      FINAL BAT TOXIC POLLUTANT  DATA BASE
Plant I.D.
                                      Treatment Technology
   2394



   2536

    725


   3033


    384

    415



   1293


   2313



   2680

   2481

   948

   267


   12


  2221


  2711

   444
 Steam stripping, distillation, chemical oxidation, thio-
 sulfate waste reuse, sewer segregation, phase separation,
 EQ, NEU, GRSP, ASL, SCLAR, POL, PAER

 Gravity separation, EQ, NEU, SCR, CLAR, ASL, SCLAR, FILT

 Steam stripping, API separator, EQ,  NEU, FLOCC,  CLAR, ASL,
 SCLAR,  FILT,  CHLOR, SLDTH, SLDFILT

 NEU,  SCSP,  NUDADD,  ALA, SSIBS, SETTLING LAGOON,  POL,  FILT,
 CAD,  SSITS,  POLISH  BAGFILTERS

 EQ, NEU, API,  ASL,  SCLAR,  POL

 Air stripping,  steam stripping, carbon adsorption, distil-
 lation,  retention impoundment, oil separation, API
 separation,  EQ,  NEU,  CLAR, NUDADD,1 MULTISTAGE POASL,  SCLAR

 Primary  settling, oil removal, EQ, BIOLOGICAL DIGESTION,
 CLAR

 Chemical precipitation,  steam stripping,  solvent
 extraction, distillation,  chemical oxidation,  filtration,
 equalization,  EQ, NEU,  CLAR,  NUDADD, ASL,  PACA, SCLAR

 Decant sump, EQ,  NEU,  SS,  CAD

 Carbon adsorption,  EQ,  NE,  SCR, CLAR,  FLOCC,  ASL,  SCLAR

 NEU, ASL, SCLAR,  POL

 Steam stripping, NEU,  SCR,  OLSK,  OLS,  CLAR, NUDADD, TF,
 ASL, SCLAR, POL                                     . ..

 Solvent  extraction,  decantation,  EQ, NEU, OLS, API, NUDADD,
 ASL, SCLAR

 Solvent  extraction,  carbon  adsorption, distillation,  EQ,
GR, ASL, SCLAR

EQ, ARL, ANL, SCLAR

EQ, NEU, ASL, SCLAR, DAF
                                  VII-202

-------
                                TABLE VII-63.
                   TREATMENT TECHNOLOGIES FOR PLANTS IN THE
                     FINAL  BAT TOXIC POLLUTANT DATA BASE
                                  (Continued)
Plant I.D.
                   Treatment Technology
    695



   2430

   1349


   1494


    883

    659

   1609

    851

   1890



   1890*


   2631


   4051

  «  '296


    306


      63


    387
Chemical precipitation, steam stripping, chemical
oxidation, filtration, separation, catalyst recovery, EQ,
NEU, OLSK, OLS, DAF, CLAR, FLOCC, NUDADD, ALA, SCLAR

EQ, NEU, OLS, DAF, FLOCC, NUDADD, TF, POASL, SCLAR

Steam stripping, EQ, NEU, CLAR, COAG, FLOCC, NUDADD, ASL,
SCLAR, POL

Steam stripping, solvent extraction, EQ, NEU, CLAR, ASL,
SCLAR, CAD

EQ, ASL, SCLAR, POL, FILT

EQ, NEU, SCR, DAF, COAG, FLOCC, ALA, SCLAR

EQ, NEU, CLAR, ASL, SCLAR

EQ, API, NUDADD, ASL, TF, SCLAR

Septic tank, API separator, gravity separation, ion
exchange, steam stripping, GR, API, EQ, NEU, API, NUDADD,
ALA, TF, FSA, SCLAR, FILT, CHLORINE ADDITION

Septic tank, API separator, EQ, NEU, NUDADD, ASL, SCLAR,
FILT, AERATION

Steam stripping, solvent extraction, EQ, NEU, API, CLAR,
ASL, SCLAR

API, ALA, DAF

Steam stripping, ion exchange, distillation, decantation,
org. recovery^ EQ, NEU, GR, OLSK, CLAR, ALA, POASL,  SCLAR

Steam stripping, EQ, NEU, OLS, FLOCC, NUDADD, ASL, SCLAR,
FILT

Distillation,  chemical  precipitation, evaporation, EQ,
CLAR, ARL, ASL, SCLAR,  CHLOR

Filtration,  crystallization,  evaporation,  EQ, NEU, SCR,
CLAR, NUDADD,  POLISHING BASIN, ASL,  SCLAR
                                    VII-203

-------
                                 TABLE VII-63.
                   TREATMENT TECHNOLOGIES  FOR PLANTS  IN THE
                      FINAL BAT TOXIC POLLUTANT DATA BASE
                                  (Continued)
Plant I.D.
                   Treatment Technology
    500


    682


    913


   1012

   1617

   1650


   1753

   1769


   1774

   2227

   2445


   2693
Steam stripping, carbon adsorption, spill containment, NEU,
CLAR, ASL, SCLAR, POL, pH ADJUSTMENT

Settling, flotation, EQ, NEU, SCR, CLAR, COAG, SETTLING,
FLOTATION, MIXING, SURFACE BAFFLES, ASL, SCLAR, DEAERATION

Steam stripping, chemical oxidation, phase separation, EQ,
NEU

EQ, SEDIM, CP, RBC, TF, SCLAR, SEDIM

Distillation, EQ, COAG, SAND BED FILTRATION, TF, SCLAR, POL

NEU, SCR, OLSK, OLS, API, ARL1, ARL2, ARL3, ARL4, ARL5,
ARL6, ANL

EQ, NEU, CLAR, NUDADD, POLADD, CP, POASL, SCLAR

Chemical precipitation, NEU, CLAR, NUDADD, FLOCC, ASL,
PACA, SCLAR, POL

EQ, NEU, CLAR, FLOCC, FILT

EQ, NEU, CLAR, FLOCC, NUDADD, ASL, SCLAR

Dissolved air flotation, EQ, NEU, SCR, API, CLAR, NUDADD,
POASL, SCLAR

Chemical precipitation, steam stripping filtration, EQ,
NEU, NUDADD, ASL, SCLAR
Note:  The order in which these treatment technologies are listed does not
       necessarily indicate that they are in series, since certain plants
       employ multiple treatment systems to treat segregated waste streams.

*Two separate treatment systems were sampled at the same plant during the same
 sampling study.
                                   VII-204

-------
                                TABLE VII-63.
                   TREATMENT TECHNOLOGIES FOR PLANTS IN THE
                     FINAL BAT TOXIC POLLUTANT DATA BASE
                                 (Continued)
Key:

CND - Cyanide Destruction
CP - Chemical Precipitation
CHRRED - Chromium Reduction
AS - Air Stripping
SS - Steam Stripping
DISTL - Distillation
EQ - Equalization
NEU - Neutralization
SCR - Screening
GR  - Grit Removal
OLSK - Oil Skimming
OLS - Oil Separation
API - API Separation
DAF - Dissolved  Air Flotation
CLAR  -  Primary Clarification
COAG  -  Coagulation
FLOCC - Flocculation
NUDADD - Nutrient Addition
ASL - Activated  Sludge
 ALA - Aerated Lagoon
 ARL - Aerobic Lagoon
 ANL - Anaerobic Lagoon
 RBC - Rotating Biological Contractor
 TF - Trickling Filters
 POASL - Pure Oxygen Activated Sludge
 SSIBS - Second Stage of Indicated Biological System
 PACA - Powdered Activated Carbon Addition
 SCLAR - Secondary  Clarification
 POL - Polishing Pond
 FILT - Filtration
 CAD - Carbon  Adsorption
 SSITS - Second  Stage of Indicated Tertiary  System
 GRSP - Gravity  Separation
 PAER -  Post Aeration
 CHLOR  - Chlorination
 FSA  -  Ferrus  Sulfide Addition
 SLDTH  - Sludge  Thickening
 SLDFILT -  Sludge Filtering
 AER  -  Aeration
  SEDIM - Sedimentation
  POLADD - Polymer Addition
  Notes:
  Upper Case:
  Lower Case:
End-of-Pipe Treatment
In-Plant Control
                                      VII-205

-------
 where  H^  is  the  estimated  long-term average  at  plant  j;  D  is  the  analytical
 minimum level; n is  the  number  of  concentration values where  Xi is  detected  at
 or above  the minimum level at plant j;  and p is the proportion of nondetected
 values reported  from all the daily data base plants.  That  is, p  equals  the
 total  number of  reported nondetected values  from all  daily  data plants for a
 particular pollutant  divided by  the total number of values  reported from all
 daily  data plants for a  particular pollutant.   For plant-pollutant  combina-
 tions  with all nondetected values,  the  long-term average, m,  equals the
 analytical minimum level.  For plant-pollutant  combinations where all values
 are detected, the long-term average  is  the arithmetic mean of all values.
 Pollutant group values for p were  used when  pollutant-specific estimates were
 not available.

          c.   Steam Stripping Long-Term Averages
      EPA is  regulating 28 volatile organic pollutants  based on steam stripping
 technology.   EPA had data on 15  of these pollutants, which were used to deter-
 mine  limitations  using the  same  methodology used to determine other  BAT
 organic pollutant limitations.   For 13  volatile organic pollutants controlled
 by steam stripping,  EPA lacked sufficient data to calculate estimated  long-
 terra  averages directly from data relating to  these  pollutants.  Instead,  EPA
 concluded  that  these  pollutants  may be  treated to levels  equivalent, based
 upon  Henry's Law  Constants,  to those achieved for the  15  pollutants  for which
 there were data.   Dividing  the 15 pollutants  into "high"  and "medium"
 strippability subgroups,  EPA developed  a long-term  average  for each  subgroup
 and applied these to  the  13 pollutants  for which data  were  lacking (six
 pollutants in the high subgroup  and seven in  the medium subgroup).   The
 long-term average for pollutants  with no  data in each  subgroup was determined
 by the  highest of the  long-term averages  within  each subgroup  based upon  the
 15 pollutants for which the Agency  had data.   This approach  tends  to be
 somewhat conservative  but in the  Agency's judgment not unreasonable in light
 of the  uncertainty that would be  associated with  achieving a lower long-term
average for the pollutants for which  data are  unavailable.  The high
strippability long-term average thus  derived  is 64.5 jMg/1, while the medium
strippability long-term average is  slightly higher,  64.7 ug/1.
                                   VII-206

-------
     While it may appear anomalous that the high strippable subgroup yields
just a slightly lower long-term average effluent concentration, EPA believes
that this is not the case.  First, in the context of the maximum levels
entering the steam strippers within the two subgroups (12,000 ug/1 to over
23 million ug/1), the differences between these two long-term averages is
negligible and essentially reflect the same level of long-term control from an
engineering viewpoint.  Second, the "high" and "medium" strippable compounds
behave comparably in steam strippers, in the sense that roughly the same low
effluent levels can be achieved with properly designed and operated steam
strippers.  In other words, it is possible to mitigate small differences in
theoretical strippability among compounds in these groups with different
design and operating techniques.  The small differences in long-term average
performance seen in the data reflect, in EPA's judgment, no real differences
in strippability among pollutants but rather the difference in steam stripper
operations among the plants from which the data were taken.  Indeed, one could
reasonably collapse the two subgroups into one group and develop a single
long-term average for the 13 pollutants for which EPA lacks data.  While such
an approach might be technically defensible, EPA decided it would be.most
reasonable to retain the distinction between "high" and "medium" subgroups,
which remains a valid and important distinction  for the purpose of  transfer-
ring variability factors, as discussed below.

     Table VII-64 presents  the long-term average values for each organic
pollutant, calculated by  taking the median of  the plant estimated averages for
those pollutants regulated  under  BAT Subcategory One and Two.  The  BAT
Subcategory  One  median  of long-term average values  for  1,1-dichloroethane  and
4,6-dinitro-o-cresol have been transferred  from BAT  Subcategory Two.   Since
the in-plant  steam  stripping and  activated  carbon units attain effluent  levels
equal  to the analytical minimum level,  the  addition  of  end-of-pipe  biological
treatment  for BAT  Subcategory  Two will not  produce  a measurable  lower effluent
concentration.

          d.   Calculation  of Daily Maximum and  Maximum  Monthly Average
              Variability  Factors>
      After determining estimated long-term average  values  for each pollutant,
EPA developed two  variability  factors  for each pollutant-^-a 99th percentile
                                    VII-207

-------
                  TABLE VII-64.
BAT TOXIC POLLUTANT MEDIAN OF ESTIMATED LONG-TERM
    AVERAGES FOR BAT  SUBCATEGORY ONE AND TWO
Subcategory One Subcategory Two
Median of Median of
Pollutant- »• • , Estimated Estimated
MnmK^ D n „ fc „ Minimum Number Long-Term Number Long-Term
Number Pollutant Name Level of Plants Means of Plants Means
1 Acenaphthene
3 Acrylonitrile
4 Benzene
6 Carbon Tetrachloride
7 Chlorobenzene
8 1,2,4-Trichlorobenzene
9 Hexachlorobenzene
10 1,2-Dichloroe thane
11 1,1,1-Trichloroethane
12 Hexachloroe thane
13 1 , 1-Dichloroethane
14 1,1,2-Trichloroethane
16 Chloroethane
23 Chloroform
24 2-Chlorophenol
25 1 , 2-Di chlorobenzene
26 1,3-Dichlorobenzene
27 1,4-Dichlorobenzene
29 1,1-Dichloroethylene
30 Trans-l,2-Dichloroethylene
31 2,4-Dichlorophenol
32 1,2-Dichloropropane
33 1,3-Dichloropropene
34 2,4-Dimethyl Phenol
35 2, 4-Dinitro toluene
36 2,6-Dinitrotoluene
10
50
10
10
10
10
10
10
10
10
10
10
50
10
10
10
10
10
10
10
10
10
10
10
10
10
3
5
17
3
2
3
1
9
2
2
-
3
4
8
3
7
1
1
5
3
3
6
3
4
2
2
10.0 1
50.0 1
10.0 4
10.0
10.0
42.909
10.0
25.625 2
10.0 1
10.0
(10.0)** 1
10.0 2
50.0 2
12.208 2
10.0
47.946
24.80
10.0
10.0 2
10.0 2
17.429
121.50
23.00
10.794 1
58.833
132.667
10.00
50.00
28.5761
64.5000*
64.5000*
64.7218*
64.7218*
64.7218
10.0
64.7218*
10.00
10.2931
50.00
44.1081

64.7218*
64.5000*
64.5000*
10.0517
11.0517

64.7218*
64.7218*
10.00


                   VII-208

-------
                  TABLE VII-64.
BAT TOXIC POLLUTANT MEDIAN OF ESTIMATED LONG-TERM
    AVERAGES  FOR  BAT  SUBCATEGORY ONE AND TWO
                   (Continued)
Subcategory One Subcategory Two
Pollutant Minimum
Number Pollutant Name Level
38
39
42

44
45
52
55
56
57
58
59
60
65
66
68
70
71
72
73
74
75
76
77
78
80
81
Ethyl benzene
Fluoranthene
Bis-(2-Chloroisopropyl)
Ether
Methylene Chloride
Methyl Chloride
Hexachlorobutadiene
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2 , 4-Dini trophenol
4 , 6-Dini tro-0-Cresol
Phenol
Bis(2-Ethylhexyl)Phthalate
Di-n-Butyl Phthalate
Diethyl Phthalate
Dimethyl 'Phthalate
Benzo (a) Anthracene
Benzo(a)Pyrene
3 , 4-Benzof luoranthene
Benzo (k) . Fluoranthene
Chyrsene
Acenaphthylene
Anthracene
Fluorene
Phenanthrene
10 i
10
10

10
50
10
10
14
20
50
50
24 ;
10
10
10
10
10
10 ,
10 ;
10 '
10
10
10
10
10
10
Median of Median ot
Estimated Estimated
Number Long-Term Number Long-Term
of Plants Means of Plants Means
14
3
1

8
1
2
10
4
2
3
3
.. -
22
2
2
2
2
2
1
1
1
3
3
-3
3
. 6
10.0
11.533
156.667

22.956
50.0
10.0
10.0
14.0
27.525
50.00
50.0
(24.0)**
10.363
47.133
17.606
42.50
10.0
10.0
10.333
10.267
10.00 '
10.0
10.0
10.0
10.0
1QJ).
-
1
-

3
1
-
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
64.5000*
11.5333
64.7218*

10.800
50.00
64.5000*
10.0
948.675
20.00
50.00
373.00
24.00
10.0
43.4545
13.0909
23.6667
10 ..00
10.00
10.333
10.2667
10.00
10.00
10.00
10.00
10.00
10.00
                      VII-209

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                                 TABLE VII-64.
               BAT TOXIC POLLUTANT MEDIAN OF ESTIMATED LONG-TERM
                    AVERAGES FOR BAT SUBCATEGORY ONE AND TWO
                                  (Continued)
                                         Subcategory One
                                                 Median of
                              Subcategory Two
                                      Median of
 Pollutant
  Number    Pollutant  Name
                  Estimated           Estimated
Minimum  Number   Long-Term  Number   Long-Term
 Level  of Plants   Means   of Plants   Means
84
85
86
87
88
Pyrene
Te t rachloroe thy lene
Toluene
Trichloroethylene
Vinyl Chloride
10
10
10
10
50
3
3
24
4
3
11
10
10
10
50
.333
.4231
.00
.00
.0
1
1
2
2
2
10.
18.
12.
11.
64.
3333
4286
4177
5862
5000
Note: All units in ug/1 or ppb.

 transferred median of long-term means by strippability groupings.
**Transferred from BAT Subcategory Two.
                                  VII-210

-------
 Maximum for  Any  One Day variability factor (VF1)  and a 95th percentile Maximum
 for Monthly  Average variability factor ,(VF4).   These .were developed by fitting
 a statistical distribution to the daily data for  each pollutant at each plant;
 estimating a 99th percentile and a mean of the daily data distributions for
 each pollutant at each plant; estimating a 95th percentile and a mean of the,
 distribution of 4-day monthly averages for each pollutant at each plant;
 dividing the 99th and 95th percentiles by the respective means of daily and
 4-day average distributions to determine.plant-specific variability factors;
 and averaging variability factors across all plants to determine a VF1-and VF4
 for each pollutant.  All plant-pollutant combinations for which variability -
 factors were calculated have at least seven effluent concentration values
 (including NDs) with at least three values at or above the minimum level.

      For certain pollutants, the amount of daily data was limited and
 individual pollutant variability factors could not  be calculated.  For such
 pollutants regulated in BAT  Subcategory One, variability factors were Imputed
 from the variability factors for groups of pollutants expected  to exhibit
 comparable  treatment variability based upon comparison of chemical structure
 and characteristics.   The priority  pollutants'were^grouped, as  shown  in Table
 VII-65, by generic classification  based  on a  similarity  of  functional group or.
 structure (isomers, homologs,  analogs, etc.).  As  a consequence of  these
 similarities, members  of  each  group share precursors, and/or  have  a  common
 response  to  generic process  chemistry (7-27)  and,  in the Agency's  judgment,
 would  be  expected  to  exhibit similar characteristics in  wastewater treatment
  unit operations.   Each pollutant  in each chemical  group  without a variability
  factor was  then assigned  a  VF1 and VF4 equal  to  the average of the VFls and
  VF4s of any pollutants in the  same group.   However, there  are six pollutants
  without individual variability factors that  are  also in  pollutant variability
  groups without  an average variability factor.  An  overall  average variability
  factor based on all individual pollutant variability factors  was transferred
  to these  pollutants [acrylonitrile, 2,4-dinitrotoluene,  2,6-dinitrotoluene,
~ bis(2-chloroisopropyl) ether,  hexachlorobutadiene, and nitrobenzene].  In the
  case of acrylonitrile and hexachlorobutadiene, the reason for not having
  individual  variability factors was not lack of sufficient daily data but that
  all or nearly all values for these pollutants were not detected.
                                      VII-211

-------
                                  TABLE VII-65.
                      PRIORITY POLLUTANTS  BY CHEMICAL GROUPS
      Halogenated Methanes  (Cls)
      46
      45
      44
      47
      23
      48
      51
      50
      49
      6
 Methyl bromide
 Methyl chloride
 Methylene chloride (dichloromethane)
 Broraoform (tribromomethane)
 Chloroform (trichloromethane)
 Bromod i chlorome thane
 Dibromochloromethane
 Dichlorodifluoromethane
 Tri chlorofluorme thane
 Carbon tetrachloride (tetrachloromethane)
 2.  Chlorinated C2s
     16
     88
     10
     13
     30
     29
     14
     11
     87
     85
     15
     12
Chloroethane  (ethyl chloride)
Chloroethylene  (vinyl chloride)
1,2-Dichloroethane (ethylene dichloride)
1,1-Dichloroethane
1,2-1 rans-Di chloroe thylene
1,1-Dichloroehtylene (vinylidene chloride)
1,1,2-Trichloroethane
1,1,1-Trichlorethane (methyl chloroform)
Trichloroethylene
Tetrachloroethylene
1,1,2,2-Tetrachloroethane
Hexachloroe thane
 3.  Chlorinated  C3s

    32   1,2-Dichloropropane
    33   1,3-Dichloropropylene

 4.  Chlorinated  C4

    52  Hexachlorobutadiene

5.  Chlorinated C5

    53  Hexachlorocylopentadiene

6.  Chloroalkyl Ethers

    17  bis(chloromethyl)ether
    18  bis(2-chloroethyl)ether
    42  bis(2-chloroisopropyl)ether
    19  2-chloroethylvinyl ether
    43  bis(2-chloroethoxy) methane
                                   VII-212

-------
                                TABLE VHr-65.
                    PRIORITY,POLLUTANTS  BY CHEMICAL GROUPS
                                 (Continued)
7.  Metals

    114  Antimony
    115  Arsenic
    117  Beryllium
    118  Cadmium
    119  Chromium
    120  Copper
    122  Lead
    123  Mercury
    124  Nickel
    125  Selenium
    126  Silver
    127  Thallium
    128  Zinc
                   .'	' HI  .1 ,    _  f '4. ' :
8.  Pesticides

      89  Aldrin
      90  Dieldrin
      91  Chlordane
      95  alpha-Endosulfan
      98  Endrin
      99  Endrin  aldehyde
     100  Heptachlor
     101  Heptachlor  epoxide
     102  alpha-BHC
     103   beta-BHC
     104   gamma-BHC  (Lindane)
     105   delta-BHC
      92   4,4'-DDT
      93   4,4'-DDE (p,p'-DDx)
      94   4,4'-DDD (p,p'-TDE)
     113   Toxaphene

 9.  Nitrosamines

      61   N-Nitrosodimethyl amine
      62   N-Nitrosodiphenyl amine
      63  N-Nitrosodi-n-propyl amin.e

 10. Miscellaneous

       2  Acrolein
       3  Acrylonitrile
      54  Isophorone
      121  Cyanide
                                     VII-213

-------
                                  TABLE VII-65.
                      PRIORITY POLLUTANTS  BY CHEMICAL GROUPS
                                   (Continued)
  11.   Aromatics

        4   Benzene
       86   Toluene
       38   Ethylbenzene

  12.   Polyaromatics
14.
15.
16.
      55
       1
      77
      78
      72
      73
      74
      75
      76
      79
      82
      80
      39
      83
      81
      84
     Naphthalene
     Acenanaphthene
     Acenaphthylene
     Anthracene
     Benzo(a)anthracene (1,2-benzantharacene)
     Benzo(a)pyrene (e,4-benzopyrene)
     3,4-Benzofluorantehne
     Benzo(k)fluorantehene (11,12-benzofluoranthene)
     Chrysene
     Benzo(ghi)perylene (1,1,2-benzoperylene)
     Dibenzo(a,h)anthracene (1,2,5,6-dibenzanthracene)
     Fluorene
     Fluoranthene
     Indeno(l,2,3-cd)pyrene (2,3-o-Phenylene pyrene)
     Phenanthrene
     Pyrene
 13.   Chloroaromatics

       7   Chlorobenzene
      25   o-Dichlorobenzene
      27   p-Dichlorobenzene
      26   m-Dichlorobenzene
       8   1,2,4-Trichlorobenzene
       9   Hexachlorobenzene
Chlorinated Polyaromatic

20  2-Chloronaphthalene

Polychlorinated Biphenyls

106-112  Seven listed

Phthalate Esters
     66
     67
     68
     69
     70
     71
    bis(2-Ethylhexyl)
    Butylbenzyl,  .,
    Di-n-butyl
    Di-n-octyl
    Diethyl
    Dimethyl
                                   VII-214

-------
                                TABLE VII-65.
                    PRIORITY  POLLUTANTS  BY CHEMICAL GROUPS
                                 (Continued)
17.  Nitroaromatics

     56  Nitrobenzene
     35  2,4-Dinitrotoluene
     36  2,6-Dinitrotoluene

18.  Benzidines

      5  Benzidine
     28  3,3'-Dichlorobenzidine
     37  1,2-Diphenylhydrazine

19.  Phenols                       _

     65  Phenol
     34  2,4-Dimethylphenol

20.  Nitrophenols

     57  2-Nitrophenol
     58  4-Nitrophenol
     59  2,4-Dinitrophenol
     60  4,6-Dinitro-o-cresol

 21.  Chlorophenols

      24  2-Chlorophenol
      22  4-Chloro-m-cresol
      31  2,4-Dichlorophenol
      21  2,4s,6-Trichlorophenol
      64  Pentachlorophenol

 22.  144 TCDD (2,3,7,8-Tetrachloro-dibenzo-p-dioxin)

 23.  Haloaryl Ethers

      40  4-Chlorophenylphenyl ether
      41  4-Broraophynylphynyl ether
  Priority pollutant  numbers  refer to a published  alphabetical  listing  of  the
    priority pollutants.

  Source:   Wise,  H.E.,  and P.O.  Fahrenthold (1981).   Occurrence and
    Predictability of Priority Pollutants in ffastewaters of the Organic
    Chemicals and Plastics/Synthetic Fibers Industrial Categories,  USEPA 1981.
                                     VII-215

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       For pollutants regulated  in  Subcategory Two  (non-end-of-pipe  biological),
  a different methodology was employed  to  transfer  variability factors  to
  pollutants without individual  variability factors.  In this case,  transfer was
  accomplished not by pollutant  group,  but instead  by the in-plant control
  technology.  Therefore, variability factors were  transferred among the
  pollutants treated by steam stripping, activated  carbon,  and in-plant
  biological treatment.   The Agency further subdivided the pollutants controlled
  by steam stripping into high and medium strippability groups (based on Henry's
  Law Constants).   As discussed previously in this section,  Henry's Law Constant
  is an important  criterion in the design of steam strippers and  is therefore an
  appropriate factor for the transfer of variability factors.   Further  sub-
  division of the  pollutants controlled  by in-plant  biological treatment was not
  considered  necessary since all  pollutants were  determined  to be effectively
  biodegraded,- transfer  of variability factors by adsorpability groups  for
  pollutants  controlled  by activated carbon was based on using the variability
  factor for  2,4-dinitrophenol  (low  adsorpability) for the other  three  pollu-
  tants controlled by activated carbon.

      For certain pollutants controlled by in-plant biological treatment, the
 transferred variability factors for in-plant biological treatment systems are
 lower than the variability factors used for end-of-pipe BAT Subcategory One.
 This results because BAT Subcategory One variability factors ares  1)  in
 general,  calculated using a different data base; and 2)  transferred using the
 pollutant variability groups (presented in Table VII-65)  rather  than across
 the technology  (as BAT  Subcategory Two  variability factors  are transferred).
 Based on  these  differences, pollutants  controlled by in-plant biological
 systems which require  transferred variability factors will  receive variability
 factors based on  data from  three phthalate esters [bis(2-ethylhexyl)
 phthalate, di-n-butyl phthalate, and diethylphthalate]: this  occurs  because
 all other pollutants controlled  by  in-plant biological systems have  all  daily
 data  equal to the analytical minimum level.  The Agency believes  that,  in
 addition  to  the reasons mentioned above,  the larger end-of-pipe  biological
 systems have higher variability  factors because  they receive more commingled
waste streams with a larger number  of organic pollutants;  thus,  they may be
more susceptible to daily fluctuations  in performance.
                                   VII-216

-------
     Based on the reasons mentioned above, the Agency has decided to retain
the methodology used to transfer in-plant biological system variability
factors.  EPA feels that it would be inconsistent to transfer a higher
variability factor to pollutants whose in-plant biological system reduces high
raw waste concentrations (higher than end-of-pipe biological raw waste
concentrations) to the analytical minimum level solely on the basis of
chemical structure.  (It should be noted  that the transferred end-of-pipe
biological system variability factor for  all polynuclear aromatics would be
based on one plant-pollutant combination.)

     In response  to comments on  the statistical aspects  of  the  proposed
limitations development,  several statistical  techniques  were  investigated  for
deriving  limitations.   This  investigation found  that  a modification  of  the
delta-lognormal procedures provides a  reasonable  approximation  of  the under-
lying  empirical toxic  pollutant  data.   The delta-lognormal  distribution
assumes that  data are  a mixture  of positive lognormally  distributed  values and
zero values.   Consequently,  zero concentration values are modeled  by a  point
distribution;  positive concentration  values follow a lognormal  distribution;
and the mixture of these values  forms the delta-lognormal distribution.  The
 statistical methodology used for testing the assumption of lognormality is
 found  in Appendix VII-E, previously referenced in the BPT Section; the results
 of these hypothesis tests are also included in this Appendix.

      This method provides a reasonable approach for combining quantitative
 concentration values with information expressed only as a nondetect, which  is
 more qualitative in nature.  For  the determination of variability factors,  the
 delta-lognormal procedure was modified by  placing the point distribution  at
 the' analytical minimum level.  The details of this modification of  the delta
 distribution are presented  in Appendix VII-F.  This  approach, is somewhat
 conservative since values reported as  nondetect  may  actually be any value
 between  zero and  the  minimum level.  The detection limit used  for each pollu-
 tant  was  the analytical minimum level  in EPA analytical methods 1624 and  1625.
 Assigning a  minimum level to nondetected values  in  calculating both variability
 factors  and  long-term averages  for this  data base tends to result in slightly
 higher limitations than would  be  derived if lower values were  assumed.   If the
 point distribution were set to  a value below the analytical minimum level,
                                     VII-217

-------
  then the variability component of the limitation would increase and the
  component corresponding to the mean would decrease.  The net effect (mean
  times variability factor) would generally result in lower limitations.  In the
  absence of establishing a firm estimate of the distribution of data below the
  analytical minimum levels, the Agency concluded that it would be more
  equitable to use the analytical minimum level to model the point distribution
  in the modification to the delta-lognormal statistical procedures.

       Comments were also received regarding the use of the average variability
  factor for transfer to pollutants without  individual variability factors  for
  BAT  Subcategory One within each of the  23  pollutant groups.   Commenters stated
  that  the  source of data for many of  the  pollutants  was  the 3-day Verification
  sampling  program,  and  that transfer  of an  average variability factor  to an LTA
  based only on data from a  3-day sampling program did not  adequately address
  the effluent  variability of a pollutant.   To address this  comment, the Agency
  examined  its  edited BAT toxic pollutant  data base and determined  that the
  predominant reason for  a pollutant not having an individual variability factor
 was not lack  of sufficient daily data but  that all  or nearly all values for
  that pollutant were not detected.  Therefore, the Agency has decided to retain
  the use of an overall average variability factor for each pollutant group to
 transfer variability factors to all pollutants within the group without an
 individual variability factor.

      The Agency also notes the  exclusion of two plants (2227P and 500P)  from
 the variability factor calculations even though they were retained for
 calculation of long-term averages.   For  plant 2227P, EPA examined the
 end-of-pipe biological treatment performance data submitted by the plant
 (which consisted of data for 1,2,4-trichlorobenzene, 1,2-dichlorobenzene,  and
 nitrobenzene  over a 1-year  period)  and observed  a  2-month  period  when  effluent
 concentrations of these  pollutants  were considerably higher than  the remaining
 10-month period;  during  this period of higher effluent concentrations, the
 corresponding  raw waste  concentrations were consistent with the remaining
 10 months  of raw waste concentration  data.  Based on this  inconsistent
 performance, the Agency  has concluded that  this plant did not have good enough
 control of variability to be used to develop variability factors.  Thus, the
Agency has excluded this plant from variability factor calculations. However,
                                   VII-218

-------
the overall long-term performance is good and consistent with that achieved by
other, good performers.  Therefore, this plant's data has been retained for
long-term average calculations.

     For plant 500P,  the Agency examined the steam stripping and carbon
adsorption performance data submitted by the plant (which consisted of data
for nitrobenzene over a 3-month period) and believes the data exhibit both
competitive adsorption effects and column breakthrough.  Competitive
adsorption exists when a matrix contains adsorbable compounds in solution
which are being selectively adsorbed and desorbed.  A  review of  the data
indicates that while  the plant's  long-term performance demonstrates
significant removals' of pollutants,  it  is not  consistent,  thus much more
variable  than that  of another plant  using similar treatment and  achieving
comparable  long-term average  concentrations.   Therefore,  the Agency has
excluded  this plant from variability factor  calculations  but has retained  the
data for  long-term average calculations.

      Table  VII-66 presents the individual pollutant variability factors for
BAT Subcategory One summarized by pollutant  group including the pollutants for
which the overall average variability factor has been transferred.  Table
VII-67 presents the  individual pollutant variability factors for BAT Sub-
 category Two summarized by in-plant control technology and strippability and
 adsorpability groups for steam stripping, and activated carbon, respectively.

      3.  BAT and PSES Metals and Cyanide Limitations
      Raw wastewaters generated by certain 6.CPSF  facilities contain relatively
 high concentrations  of.metals and total cyanide.  Based on a detailed analysis
 (as discussed in Sections V  and  VI .of  this document),  the  Agency  has. decided
 to  regulate  the  following six pollutants under BAT and PSES:

      •  Total chromium
      •  Total copper            ,        •  .  .
      •  Total lead
      •  Total nickel
      •  Total  zinc
       •   Total  cyanide.               ....-.-
                                     VII-219

-------
                                 TABLE VII-66.
                INDIVIDUAL TOXIC POLLUTANT VARIABILITY FACTORS
                            FOR BAT SUBCATEGORY 
-------
                                TABLE VII-66.
                INDIVIDUAL TOXIC  POLLUTANT VARIABILITY FACTORS
                           FOR BAT SUBCATEGORY ONE
                                 (Continued)
Pollutant
 Number   Pollutant Name
Daily VF
Monthly VF
Imputed Varia-
bility Factor?
Pollutant Class = 12
1 Acenaphthene
39 Fluoranthene
55 Naphthalene
72 Benzo(a)Anthracene
73 Benzo(a)Pyrene
74 3,4-Benzofluoranthene
75 Benzo(k)Fluoranthene
76 Chrysene
77 Acenaphthylene
78 Anthracene
80 Fluorene
81 Phenanthrene
84 Pyrene

7 Chlorobenzene
8 1,2,4-Trichlorobenzene
9 Hexachlorobenzene
25 1,2-Dichlorobenzene
26 1,3-Dichlorobenzene
27 1,4-Dichlorobenzene

5.89125
5.89125
5.89125
5.89125
5.89125
5.89125
5.89125
5.89125
5.89125
5.89125
5.89125
5.89125
- 5.89125
Pollutant Class = 13
2.79155
3.25317
2.79155
3.38091
1.74057
2.79155
Pollutant Class = 16
66 Bis-(2-Ethylhexyl) Phthalate 5.91768
68 Di-n-Butyl Phthalate 3.23768
70 Diethyl Phthalate 4.75961
71 Dimethyl Phthalate 4.63833

35 2,4-Dinitrotoluene
36 2,6-Dinitrotoluene
56 Nitrobenzene
Pollutant Class = 17
4.83045
4.83045
4.83045
2.1563
2.1563
2.1563
2.1563
2.1563
2.1563
2.1563
2.1563
2.1563
2.1563
2.1563
2.1563
2.1563

1.46787
1.58318
1.46787
1.59720
1.22323
1.46787

2.17027
1.51824
1.89895
1.86249

1.91724
1.91724
1.91724
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
•Yes

Yes
Yes
Yes

Yes

Yes
Yes
Yes
                                     VII-221

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                                 TABLE VII-66.
                INDIVIDUAL TOXIC POLLUTANT VARIABILITY FACTORS
                            FOR BAT SUBCATEGORY ONE
                                  (Continued)
Pollutant
 Number   Pollutant Name
  34   2,4-Dimethylphenol
  65   Phenol
 57  2-Nitrophenol
 58  4-Nitrophenol
 59  2,4-Dinitrophenol
 24  2-Chlorophenol
 31  2,4-Dichlorophenol
                                     Daily VF
                                   Imputed Varia-
                       Monthly VF  bility Factor?
 Pollutant  Class  =19

         3.25650        1.59976
         2.49705        1.40602

 Pollutant Class  = 20

         2.49725        1.4643
         2.47783        1.4331
         2.45842        1.4019

Pollutant Class = 21

        9.70575       3.05490
        6.37097       2.22674
Yes
                                VII-222

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                                TABLE VII-67.
                INDIVIDUAL TOXIC  POLLUTANT VARIABILITY  FACTORS
                           FOR BAT SUBCATEGORY TWO
Pollutant
 Number   Pollutant Name
                                   Daily VF
Monthly VF
Imputed Varia-
bility Factor?
 4
11
13
16
23
29
30
45
85
86
87
88

10
14
44
4.65485
5.88383
5.88383
5.88383
7.36230
5.88383
5.88383
5.88383
8.85657
5.88383
5.88383
2.66160
8.8604
12.2662
15.6720
1.97430
2.18759
2.18759
2.18759
2.49394
2.18759
2.18759
2.18759
2.78458
2.18759
2.18759
1.49754
2.77681
3.02524
3.27366

Yes
Yes
Yes

Yes
Yes
Yes

Yes
Yes


Yes

      Benzene
      1,1,1-Trichloroe thane
      1,1-Dichloroe thane
      Chloroe thane
      Chloroform
      1,1-Dichloroe thy lene
      1,2-Trans-dichloroethylene
      Methyl Chloride
      Tetrachloroethylene
      Toluene
      Trichloroethylene
      Vinyl Chloride

       1,2-Dichloroe thane
       1,1,2-Trichloroethane
       Methylene Chloride




        variability factors when no variability factors available.
 Pollutant
  Number   Pollutant Name
                                    Daily VF
 Monthly VF
                                                              Imputed Varia-
                                                              bility Factor?
56
57
58
59
60
Nitrobezene
2-Nitrophenol
4-Nitrophenol
2 , 4-Dini t rophenol
4 , 6-Dini t ro-o-Cresol
6.7477
11.5023
11.5023
11.5023
11.5023
2.35797
3.23479
3.23479
3.23479
3.23479
Yes
Yes
Yes
  Note:   Pollutant variability factors-variability factors for pollutant 59
         used to impute variability factors for 57, 58,  and 60.
                                      VII-223

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                 TABLE  VII-67.
INDIVIDUAL TOXIC POLLUTANT VARIABILITY FACTORS
           FOR BAT  SUBCATEGORY TWO
                  (Continued)
Pollutant
Number Pollutant Name
1 Acenaphthene
3 Aery lonit rile
34 2,4-Dimethylphenol
39 Fluorantehene
55 Naphthalene
65 Phenol
66 Bis-(2-Ethylhexyl) Phthalate
68 Di-n-Butyl Phthalate
70 Diethyl Phthalate
71 Dimethyl Phthalate
72 Benzo(a)Anthracene
73 Benzo(a)Pyrene
74 3,4-Benzofluoranthene
75 Benzo(k)Fluoranthene
76 Chrysene
77 Acenaphthylene
78 Anthracene
80 Fluorene
81 Phenanthrene
84 Pyrene
Daily VF
—
4.63833
4.63833
4.63833
4.63833
4.63833
4.63833
5.91768
3.23768
4.75961
4.63833
4.63833
4.63833
4.63833
4.63833
4.63833
4.63833
4.63833
4.63833
4.63833
4.63833
1 	 . —
Monthly VF
1.86249
1.86249
1.86249
1.86249
1.86249
1.86249
2.17027
1.51824
1.89895
1.86249
1.86249
1.86249
1.86249
1.86249
1.86249
1.86249
1.86249
1.86249
1.86249
1.86249
Imputed Varia-
bility Factor?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
                 VII-224

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The technology basis for control of these pollutants is hydroxide precipita-
tion for the metals and alkaline chlorination for cyanide.  Although sulfide
precipitation was the basis for BAT and PSES compliance cost estimates,  it was
not used as the technology basis for  the limitations because the Agency's
final regulation does not include control of complexed sources  of  these
metals.  This results in a slight overestimation of costs  for compliance with
the metals limits for ,BAT and  PSES levels of control.

     Although  the concentrations of  these pollutants  in  certain samples  of
untreated OCPSF wastewater are relatively high,  the metals fall within the
range of concentrations found  in untreated  wastewaters  from metal processing
and  finishing,  such as  those  for  the metal  finishing  and battery manufacturing
 industries.   Because no metals treatment performance  data for OCPSF waste-
waters  generated  by the validated  product/processes  listed in Section V were
 available,  the Agency decided to transfer limitations from the metal finishing
 point source category.   Cyanide is found at levels in certain OCPSF waste
 streams at higher concentrations than in metal finishing.  Destruction; of
 cyanide by alkaline chlorination is demonstrated in the OCPSF industry; this
 technology uses .excess oxidizer (chlorine) and excess alkaline conditions, and
 should be able to treat cyanide by adding sufficient detention time which has
 been costed.  Table VII-68 presents  the long-term averages and daily and
 monthly maximum variability factors  for each pollutant.

      The monthly maximum limitations  for the metal finishing industry are
 based  on an assumed monitoring requirement of 10 samples  per month and  employ
 the 99th percentile as a basis for  the  monthly maximum  standard.   For  the
 OCPSF  standard, however, the  monthly maximum standards  are based  on an  assumed
 monitoring  requirement of four samples  per month and  they use  the 95  percen-
  tile as a basis.   The  above  limitations have been adjusted accordingly  to be
  consistent  with  the other OCPSF BAT limitations  by deriving 4-day variability
  factors  from the distributional  parameters determined  from the 10-day metal
  finishing variability factors (see Appendix VII-F).   The OCPSF daily and
  monthly maximum limitations for each pollutant  is  the product of the respec-
  tive long-term averages and respective 1-day and 4-day variability factors.
                                      VII-225

-------
                                 TABLE VII-68.
               u              °NE AND TWO LONG-TERM AVERAGES AND
               VARIABILITY FACTORS FOR METALS AND TOTAL CYANIDE
Pollutant
 Number
  119

  120

  121

  122

  124

  128
   Pollutant
     Name
Total  Chromium

Total  Copper

Total  Cyanide

Total  Lead

Total Nickel

Total Zinc
Long-Term
 Average
  (mg/1)
  0.572

  0.815

  0.180

  0.197

  0.942

  0.549
Maximum Monthly
   Average VF
     1.934

     1.781

     2.343

     1.642

     1.796

     1.912
Maximum Daily
    .  VF
     4.85

     4.15

     6.68

     3.52

     4.22

     4.75
                                 VII-226

-------
     4   BAT Zinc Limitations for Plants Manufacturing Rayon by the Viscose
         Process and Acrylic Fibers by the Zinc Chloride/Solvent Process
     Raw wastewaters generated by the manufacture of rayon by the viscose
process and acrylic fibers by the'zinc chloride/solvent process exhibit high
concentrations of zinc with levels generally exceeding 100 mg/1.  Accordingly,
the Agency has decided to control zinc in the process wastewaters from these
product/processes by establishing separate BAT effluent limitations.  Since
these wastewaters do not contain-complexed sources of zinc that could inhibit
treatment by conventional methods, the Agency has selected hydroxide precipi-
tation as the basis for these process-specific BAT effluent limitations.

     During  the  public comment periods on the March  21, 1983,  proposal and
July 17, 1985, NOA, industry commenters  submitted hydroxide precipitation
performance  data for  four rayon  plants and one acrylic  fibers  plant.  These
data sets contained influent and effluent data for  four plants (three rayon,
one acrylic  fiber) with over 200 influent/effluent  data pairs  for each  data
set.   One rayon plant (399) was  eliminated because  only effluent  data were
submitted.   Following a quality  assurance review,  the effluent concentrations
 that  exceeded 10 mg/1 or  that  exhibited less than 90 percent  removal of zinc
were  deleted from these  three  data sets.  For the performance data from the
 acrylic fibers plant  (1012),  174-percent of  the effluent  zinc concentrations
 were deleted, while for  the three remaining rayon plants  (63,  387, and 1774),
 5.9,  0.8,  and 63.6 percent of the respective effluent zinc concentrations were
 deleted.

      The Agency then investigated the data set for plant 1774 because of the
 failure of 63.6 percent of the data to  pass the editing criteria.  Analysis of
 the data revealed that the majority of  the data failed the 90 percent removal
 criteria.  Further investigation revealed that the  failure to achieve 90 per-
 cent removal was not because of high effluent zinc  concentrations  but due to
 low influent concentrations that are the result of  a zinc recovery unit
 upstream of  the influent sampling point.  Based on  these findings,  the entire
 performance  data set  for plant  1774 was deleted  from  further  limitations
 calculations.
                                     VII-227

-------
      The data sets for the two remaining rayon plants and the one acrylic
 fibers  plant were analyzed according to the methodology for deriving BAT
 effluent limitations  described in Appendix VII-F.   Table VII-69 presents the
 resulting long-term averages  and  variability factors  for the remaining  plants.

     5-   PSES Effluent Limitations
     As  presented  earlier  in  Section VI,  the Agency has  determined  that
47 toxic  pollutants pass through  POTtfs and will be controlled by PSES effluent
limitations.  For  these 47  toxic  pollutants, PSES effluent limitations are
equal to BAT Subcategory Two effluent limitations.
                                 VII-228

-------
                                                      •—•
Plant
Number

63
387
1012
Long-Term
Average
(mg/1)
1.739
2.114
2.190
Maximum Monthly
VF

1.79
1.41
1.52
Maximum Daily
VF
	
4.19
2.50
2.95
Median of LTA    2.114
Average VF
                                 1.572
                                                    3.214
                         	 VII-229

-------
7-1
7-2
  7-3




  7-4




 7-5


 7-6




 7-7




 7-8




 7-9




 7-10



7-11




7-12
                                    SECTION VII


                                    REFERENCES


                                 Cited References



        U.S. Environmental Protection Agency (USEPA).  1981   NPDF
-------
                                 SECTION VII

                            REFERENCES (Continued)

                         Cited References (Continued)


7-13  Aire-02 News, Volume 4, No, 3, Summer 1987.  Aeration Industries, Inc.,
      Chaska, Minnesota.

7-14  Filtration and Chemically Assisted Clarification of Biologically Treated
      Pulp and Paper Mill Industry Wastewaters.  .Draft Report  to  the U.S.
      Environmental Protection Agency, Edward C.  Jordan Co., Inc.,  19/y..   ,

7-15  Rice, N., A.A. Kalinske, and W.I. Arnold.   1979.  A Pilot Study of;_  -
      Advanced Wastewater Treatment  for  the Ticonderoga Mill,  August 1977.

7-16  Personal Communication  withsDana Dolloff,  International  Paper Co., June
      26,  1980.                                                    ..•.••--'••

7-17  Ambere, H.R., I.  Gellman,  and  R.H.  Scott.   "The Status of. Water    ,-.-,•
      Pollufion Control in the Soviet Union,"  TAPPI,  Vol....58,  No. 11, November
      1975.                                            .-:••••-.-•-

7-18  Scott, R.H.   1978.   "Sophisticated Treatment of Baikal Pulp Mill  in
      USSR," Pulp  and  Paper,  Vol.  48;, No.  4,  April 1978.

7-19  Smith, O.D.,  R.M, Stein,,and C.E.  Adams,  Jr, ^975.   "How Mills  Cope _
      With Effluent Suspended Solids,"  Paper Trade Journal,  VoK  159,  No.  I/,
      July 1975.

7-20  Peterson,  R.R.  and J.L. Graham.  1979.  CH2M Hill,  Inc., Post Biological
      Solids Characterization and Removal from Pulp Mill Effluents.
      EPA 600/2-79-037.

 7-21   "Preliminary Data Base'for Review of BATEA Effluent Limitations
      Guidelines,  NSPS, and Pretreatment Standards for 'the Pulp, Paper,, and
       Paperboard Point Source Category," Edward C. Jordan, Co.,  Inc., June
       1979. .    -	• ..     .  , ...  . ^   -	 •	:   '	      ^   '      ,"  : "'

 7-22  Ambers, H.R..  1979.   Crown Zellerbach Corp.,  Comments  on  B.C. Jordan's
       Draft Report, "Preliminary Data Base for Review of BATEA Effluent
       Limitations Guidelines, NSPS, ,and Pretreatment  Standards for .the Pulp,
       Paper, and Paperboar4  Point Source Category,"  September 197:9.

 7-23  Cashen, R.P.  1979.  St.  Regis Paper Co.,  Comments on B.C.  Jordan's
       Draft Report, "Preliminary  Data Base  for  Review of BATEA Effluent
       Limitations Guidelines, NSPS,  and Pretreatment Standards for the Pulp,
       Paper, and  Paperboard  Point  Source Category,"  September 1979.

 7-24  Button, E.F.  1979.   ITT  Rayonier .Inc.,  Comments on E.G. Jordan's Draft
       Report.   "Preliminary  Data  Base  for Review of BATEA Effluent Limitations
       Guidelines,  NSPS,  and  Pretreatment  Standards for  the Pupp, Paper, and
       Paperboard  Point Source Category."   September 1979.
                                     VII-231

-------
                                  SECTION VII

                            REFERENCES  (Continued)

                         Cited References  (Continued)
7-25  Barton, Curtis A..   1979.  The  Proctor  &  Gamble  Co.,  Comments  on  B.C.
      Jordan's Draft Report,  "Preliminary Data  Base  for Review  of  BATEA
      Effluent Limitations Guidelines, NSPS,  and  Pretreatment Standards for
      tne Pulp, Paper, and Paperboard Point Source Category," September 1979.

7-26  National Council of  the Paper Industry  for  Air and Stream Improvement,
      of BiS^Sil  ? °', I8""™"7 °f Data-chemically Assisted Clarification
      SDA/ £J g S i yTTr!ated Wastewaters,» Presented  in Meeting with U.S.
      EPA/ Edward C. Jordan Co., Portland, Maine, February  7, 1980.

7-27  Wise,  H.E.  and P.O. Fahrenthold.  1981.   Occurrence and Predictability
      2?  L   /F P°llutan^ :ln tfastewaters of the Organic Chemicals and
      2£3 ^y^hetic Fibers Industrial Categories,  Presented at the 181st
      April"? 198l!    Society National Meeting, Atlanta,  Georgia, March 29 -
                               Other References

      Beardsley,  M.L.  and J.M.  Coffey.   1985.   Bioaugmentation:   Optimizing
      biological  wastewater treatment.   Pollution Engineering 17(12): 30.

      Berger,  B.B.   1983.   Control of organic  substances in water and
      wastewater.   EPA-600/8-83-011,  NTIS  PB86 184744/AS.
             TK'S\  19i!5i'i  Contract  operations:   Private  contracts  for  public
     work.  J. Water Poll. Control  Fed. 57(7):750-755.                 FUUX.IC

     Eckenfelder, Jr., J.J., j. Patoczka, and A.T. Watkin.   1985.  Wastewater
     treatment.  Chem. Eng.  92:60-74.                             wasiewater

     Eischen, G.W. and J.D. Keenan.  1985.  Monitoring aerated lagoon
     performance.  J. Water Poll. Control Fed.  57(8):876-881.

     Foess, G.W. and W.A. Ericson.  1980., Toxic control - the trend of the
     tuture.  Water & Wastes Engineering (February 1980):  21-27.

     Gaudy, Jr., Anthony F. and E.T. Gaudy.   1980.  Microbiology for
     environmental engineers and scientists.  New York:  McGraw-Hill Book
     Company .

     Johnson,  T., F. Lenzo, and K. Sullivan.  1985.   Raising Stripper
     Temperature Raises MEK Removal.  Pollution Engineering 17(9): 34.
              R'S\ 19o5<   Waftevater treatment plant instrumentation
     NTISPB86-108636/AS?ear         Cincinnati,  Ohio.   EPA/600/8-85-026,
                                  VII-232

-------
                           SECTION VII

                      REFERENCES (Continued)

                   Other References (Continued)


Metcalf & Eddy, Inc.  1979.  Wastewater engineering:  Treatment/
disposal/reuse.  New York:  McGraw-Hill Book Company.

Municipal Environmental Research Laboratory (MERL).  1980.  Carbon
Adsorption Isotherms for Toxic Organics.  EPA-600/8-80-023.
PB 80197320.  April 1980.

Peters, R.W., Y/ Ku, and D. Bhattacharyya.  Evaluation of recent
treatment techniques for removal of heavy metals from industrial
wastewaters.  AIChE Symposium Series.   243:18.

Richards, S.R., C. Hastwell, and M. Davies.  1984.   The  comparative
examination  of  14  activated sludge-plants using enzymatic  techniques.
Water  Poll.  Control Fed,  (G^B.) 83:300.

SAIC    1985.   Costing documentation and notice of new information
report,  Prepared  for?   Industrial  Technology Division of the  USEPA.
June 12,  1985.

Sekizawa, T.,  K,  Fujie,  H. Kubota, T.  Kasakura, and A. Mizuno.   1985.
Air diffuser performance in activated  sludge aeration  tanks.   J.  water
Poll.  Control Fed.  57(l):53-59.

U.S. Environmental Protection  Agency  (USEPA).   1974.  Processing Design
Manual for  Upgrading Existing  Wastewater  Treatment  Plants.   PB-259 148,
EPA 625/l-71-004a.  October  1974.

U.S.  Environmental Protection  Agency  (USEPA).   1979.  Summary Report,
Control and Treatment Technology for  the Metal Finishing Industry:
 Sulfide Precipitation.   EPA 625/8-80-003.

 U.S.  Environmental Protection Agency (USEPA).   1980.  Sources and
 Treatment of Wastewater in the Nonferrous Metals Industry.  EPA
 600/2-80d-074.

 U.S.  Environmental Protection Agency (USEPA).   1982.  Development
 Document for Effluent Limitations, Guidelines, and  Standards for  the
 Battery Manufacturing Point Source Category.  EPA 440/l-82-067b.

 U.S. Environmental Protection Agency (USEPA).  ,1983a.   Development
 Document for Effluent Limitations Guidelines  New Source Performance
 Standards for  the Metal Finishing Source Category.

 U.S.  Environmental Protection Agency  (USEPA).  1983c.   Treatability
 Manual.  Office of Research and Development.  EPA-600/2-82-001a.
 February 1983.
                               VII-233

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                                          SECTION VII




                                   REFERENCES (Continued)



                                Other References  (Continued)
                            d
                                                                   of a Combined
*U,S GOVERNMENT PRINTING OFFICE:1993 -715 -i
                                         VII-234
                              003/87033

-------