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TABLE 6-17. EPA-ITD SAMPLING PROGRAM
AIR FLOTATION PERFORMANCE - PLANT D
Fraction: Pesticides/Herbicides
Plant No.
Episode No.
Sample No.
Sample Point
Sample Date
D
1179
15713
Raw
2/02/87
D
1179
15714
Treated
2/02/87
D
1179
15718
Raw
2/04/87
D
1179
15719
Treated
2/04/87
Average
Percent
Removed
Parameter
Dichloran
Endosulfan I
Endosulfan Sulfate
Heptachlor
Etridazone
Isodrin
Trifluralin
Azinphos Ethyl
Azinphos Methyl
Fensul f othion
Phosmet
Diazinon
Dimethoate
Leptophos
TEPP
ND
296
ND
284
252
ND
ND
4260
6207
5795
ND
ND
ND
ND
ND
ND
ND
ND
1738
ND
2829
ND
ND
50466
ND
30972
ND
ND
ND
ND
ND
ND
528
ND
ND
ND
ND
ND
4689
7859
ND
1035
1500
3959
ND
282
ND
951
ND
ND
ND
322
ND
3769
4148
ND
ND
ND
ND
2323
0
99
0
0
99
0
0
99
9
74
0
99
99
99
0
NOTE: ND indicates not detected
All concentrations expressed in /Jg/l (/KJ/1 = micrograms per liter) .
Average percent removed = mean of positive and zero removals. ND
assumed equal to zero.
85
-------
and volatile organics found in the raw wastewater and the mean of
the averages is 63 percent. However, 10 compounds are detected in
treated effluents that were not detected in 'the raw wastewater.
Eight pesticides/herbicides are removed, however, five compounds
are found in the treated effluent that are not found in the raw
wastewater.
EPA-ITD sampled four wastewater treatment systems that are
representative of the wastewater treatment technologies used in the
industry: sedimentation, oil/water separation, and air flotation.
Poor removals were observed, which is probably due to poor
operational control during the sampling episodes rather than being
indicative of industry-wide practice. Therefore, few positive
conclusions can be drawn regarding treatment system performance for
this industry.
6.4 ZERO DISCHARGE TECHNOLOGY
EPA observed that zero discharge is achieved by a significant
number of the facilities that were visited. During routine
operations, no discharge of process wastewater from the facilities
occurs. Although discharges are likely during system shutdowns for
maintenance or when wastewater treatment systems are upset and
bypassed. Discharges are also likely during periods of' high
rainfall when extraordinarily high volumes of contaminated storm
water may be generated. Five of the 16 facilities visited by EPA
generate significant volumes ,qf. wastewater and also achieve zero
discharge. All drum reconditioners are prohibited from discharging
process wastewater in the Chicago Metropolitan Sanitation District
(MSD). EPA identified 19 facilities that are potentially active
in the city of Chicago (Appendices A and B) . Information is
available on Plant D and four more facilities identified below as
Plants N, 0, P, and Q. The-methods used to achieve zero discharge
are described below for each facility.
• Plant D - 15,000 gpd are generated as a result of the
washing and burning of 6,000 drums. The process
wastewater is treated by air flotation and reused as
makeup to caustic wash and intermediate rinses and as
, furnace quench. Most of the wastewater is lost from the
system through evaporation at the furnace or from the hot
caustic wash. City water used as final rinse is the
source of makeup to the total system. Solids are removed
by screening and as air flotation sludge.
Plant N - This facility washes 700 tight-head drums and
burns 500 open-head drums. Process wastewater is treated
by air flotation and then reused as an intermediate rinse
or as furnace quench.
• Plant O - About 1,000 open- and tight-head drums are
reconditioned daily. Open-head drums are not burned, but
are instead shot ;blasted. Hence, no wastewater is
generated. Wastewater is generated by tight-head washing
86
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processes and is treated by air flotation. The treated
wastewater is reused as an intermediate rinse or as
caustic makeup.
Plant P - 1,500 open—head drums are burned daily. Quench
water is treated by sedimentation only before being
reused. Because of high evaporation losses, the quench
water supply is made up by wastewater trucked in from
Plant Q.
Plant Q - This tight-head plant washes 600 drums daily.
Sedimentation and oil/water skimming are provided to the
process wastewater. Some wastewater is reused on-site
as caustic makeup and the remainder is trucked to Plant
P.
6.5 RESIDUALS GENERATION AND DISPOSAL
Nonaqueous liquid wastes and solids are generated in several
plant areas. Liquid residues are sometimes dumped into process
wastewater floor drains, but are usually contract hauled.
Petroleum residues are sometimes sold for use in fuel blends. Oil
and grease removed from oil/water separators is also sold for the
same purpose. Solids generated include wastewater treatment
sludges and furnace ash.
' '
Limited data do not allow a precise estimate of the total
volume of sludge and ash disposed of by the industry. Data from
three plants that use air flotation show that approximately 0.7
kilograms, or 0.17 gallons of air flotation sludge are generated
per drum reconditioned. Two of the three plants comingle ash
quench with washing wastestreams; therefore, the
0.7 kilogram estimate reflects both tight- and open-head
wastestreams. Caustic wash sediments are also comingled with the
wastestreams. The Agency believes that this estimate is the best
available for estimating the total mass of solids disposed of by
the industry (SAIC I987c).
NABADA (Touhill 1981a) reports that 51.2 percent of the
industry used air flotation or flocculation/sedimentation.
Therefore, the annual industry solids generation rate is 18 million
kilograms (51.2 percent x 0.7 kilogram per drum x 50,000,000
drums), or 153,000 pounds daily, if 260 working days per year are
assumed. Facilities that do not use air flotation or sedimentation
are assumed to dispose of solids through their wastewater
discharge. The high levels of solids observed in raw wastewaters
support this assumption.
Data collected by EPA-ITD and EPA-ORD are presented below for
caustic clarifier sludges, furnace ash, and air flotation sludges.
EPA ITD collected air flotation sludge samples at Plants B and D.
A sedimentation sludge sample was collected at Plant C. EPA-ORD
collected caustic clarifier sludge samples at Plants E and F and
a furnace ash sample was obtained from Plant G.
87
-------
6.5.1 EPA-ITD Data
The data collected by EPA-ITD are the best available for
estimating the characteristics of sludge disposed of by the
industry. Sludges at three plants were sampled. Plant B used air
flotation to treat tight-head process wastewater generated by paint
drum reconditioning facilities. Plant C used sedimentation to
remove solids from the washing and stripping of petroleum drums.
Two samples were obtained from Plant D where air flotation is used
to treat wastewaters generated by tight- and open-head processing.
A wide range of drum types are processed at Plant D and the furnace
quench constitutes 27 percent of the treatment system influent.
Sludge analyses were conducted for conventional and nonconventional
pollutants, metals, extractable and volatile organics, and
dioxins/furans. Analytical results are summarized below.
Conventional and Nonconventional - The data in Table 6-18
show that sludges are composed mainly of oil and grease
(22 percent) and suspended solids (8 percent), which are
mostly volatile solids.
Extractable and Volatile Organics - The data in Table
6-19 show detected values. Only a few conclusions can
be drawn about the presence of organics in the four
sludge samples, since detection limits in many cases are
greater than 1 mg/1. 2-Butanone (MEK), biphenyl,
bis(2-ethylhexyl)'phthalate, ethylbenzene, napthalene, and
toluene were found in samples at two of the three plants.
No single compound is found at all three sites and no
site-specific patterns are evident.
• Metals - Industry mean concentrations are shown in Table
6-20. Iron, sodium, and aluminum constitute 2.8, 3.6,
and 2.2 percent, respectively, of the typical industry
sludge. Zinc and lead, the primary wastewater
constituents, are observed at levels up to 0.3 and 0.8
percent, respectively.
• Dioxins/Furans - Twelve compound were detected in the
four samples shown in Table 6-21. Most of these are
associated with Plant D. This facility is the only one
of the sampled plants that generated furnace quench. ,No
dioxin/furans were found in raw wastewaters from the
other plants. Seventeen compounds were found in the
furnace quench sample. These compounds are the likely
result of the low temperature drum burning operation
which operates in the range of 600°F to 1,800°F.
Sludge samples also were analyzed using the Toxicity
Characteristic Leaching Procedure (TCLP). The TCLP is designed to
determine the mobility of both organic and inorganic contaminants
present in liquid, solid, and multiphasic wastes. The solid phase
of sludges are subject to extraction with an acid. The extract is
mixed with the aqueous phase and the mixed liquid is then analyzed.
The analytical results are used to determine compliance with
88
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treatment standards for solvent waste disposed of on land. Results
are shown in Tables 6-22 and 6-23. Sludge from Plants B and D fail
to meet the BDAT standards for the land disposal of spent solvents
(EPA 1986b).
6.5.2 EPA-ORD Data
6.5.2.1 Caustic Clarifier Sludges
Samples of the sludge resulting from the clarification of
caustic are shown in Table 6-24 for Plants E and F. The sample
from Plant E contained floating oil and emulsions. The level of
organics measured in Plant E sludge is considerably higher than the
level measured in the clarified effluent. The organics probably
have been absorbed by oil and emulsions that constitute the sludge.
The sludge from Plant F was scraped from the sides of the
clarifier. This sample was probably high in oils and greases that
adhered to the clarifier walls. The high hydrocarbons levels
measured reflect the fact that 95 percent of the drums serviced at
Plant F contained petroleum.
The metals levels measured in Plant E sludge are generally
lower than those measured in clarified effluent. This suggests
either poor removals or the use of analytical protocol, which did
not appropriately account for the solids. Metals data are also
listed in Table 6-24 for plants that supplied data in response to
the NABADA survey. The data are the average of sludges from
several plants and show significantly higher levels than the data
from Plant E.
Table 6-25 shows metals data for dried caustic sludge samples
from Plant G that contain about 30 percent water. If a solids
level of 1 percent were assumed for the undried sludge, then the
data would be representative of a sludge that had been concentrated
about 70 times. An extrapolation of the
data with the use of a divisor of 70 would yield metals levels that
are lower than those reported by NABADA respondents.
6.5.2.2 Furnace Ash
Ash removed from the surfaces of burned open-head drums is
likely to contain high amounts of metal as well as incompletely
combusted organics. In Table 6-26, hydrocarbons and extractable
organics are shown to be present in an ash sample collected from
Plant B.
6.6 SUMMARY
The following list summarizes the major points that were
discussed in this section:
o Zero discharge is demonstrated to be a practical control
technology for open-head facilities. Furnace quench
water typically is reused after simple sedimentation.
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TABLE 6-24.
ANALYTICAL DATA FOR CAUSTIC CLARIFIER SLUDGES
PLANTS E AND F
Parameter
Plant E
Concentration (mg/1)
Plant F
Other Data*
Acenaphthalene
Acenaphthalenes, Cl
Acenaphthalenes, C2
Acenaphthene
Aliphatics, C7-C18
Anthracene/phenanthrene
Benzenes, C3-C4
Bis-(2-ethylhexyl)-Phthalate
2-chlorophenol
Chrysene/benzo(a)anthracene
Dicyclohexylamine
Diethyl phthalate
Fluoranthrene
Fluorene
Isopropyl diphenyl amine
Naphthalene
Naphthalenes, Cl
Naphthalenes, C2
n-nitrosodiphenylamine
Pyrene
Silicones
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Cyanides
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Selenium
Silicon
Silver
Sodium
Strontium
7.6
50
14
5.4
59
5.5
12
17
47
1,200
5
11.0
3.77
. 0.076
0.520
0.060
23.1
1.16
50.8
0.880
0.960
0.990
8.98
4.28
21.7
1.21
0.178
3.41
0.48
36.7
0.023
22.9
<0.005
23,400
0.250
165
135
25
12,500
1,625
13
13
360
330
335
4,350
1.6
651
9.6
1,687
199
2,393
10
24,922
4,554
290
0.48
29.2
7,500
30.5
5,325
2.3
8,455
96
-------
TABLE 6-24.
ANALYTICAL DATA FOR CAUSTIC CLARIFIER SLUDGES
PLANTS E AND F (Continued)
Parameter
Concentration (mq/1)
Plant A
Plant B
Other Data*
Thallium
Tin
Titanium
Vanadium
Zinc
<0.1
<0.015
0.230
1.41
1.44
__
—
—
—
6,791
Other data refers to data submitted by several drum
reconditioners in response to a NABADA survey.
97
-------
TABLE 6-25. ANALYTICAL DATA FOR DRIED CAUSTIC SLUDGE PLANT G
Moisture Content, wt.%
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Selenium
Silicon
Silver
Sodium
Strontium
Thallium
Tin
Titanium
Vanadium
Zinc
Sample
27.66
8,500
889
6.6
3,100
1.94
378
65.2
23,000
1,500
209
990
81,500
5,900
3,600
779
3.1
269
1,900
4,200
1.0
1,600
231
55,600
127
<10
265
1,300
290
1,900
1 Sample 2
14.63
Concentration ,
12,700
975
11.7*
4,900
1.90
539
95.2
33,400
2,300
548
1,900
134,000
10,300
6,200
1,200
1.7
202
2,100
5,600
1.3
1,600
230
87,600
194
<10
320
6,800
341
3,300
Sample 3
45.20
mg/kg
7,800
828
6.8
3,000
<1
405
73.6
22,800
1,400
293
919
80,000
5,800
3,800
771
3.5
60.1
1,600
4,000
1.4
1,400
198
58,800
126
<10*
227
1,800
289
2,000
Average values for two analyses.
98
-------
TABLE 6-26. ANALYTICAL DATA FOR FURNACE ASH PLANT F
Parameter
Concentration mg/kg ash
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Selenium
Silicon
Silver
Sodium
Strontium
Thallium
Tin
Titanium
Vanadium
Zinc
C7-C25 Aliphatics
Anthracene
Cl Anthracene
C2 Anthracene
C3-C4 Benzene
Bis (ethylhexyl) phthalate
Butyl benzyl phthalate
Diisobutyrate
Fluoranthene
Naphthalene
C5 phenol
Pyrene
Silicones
9,700
105 '
9.2
9 ,460
<2
78.7
11
7,840
1,250
24.5
1,880
5,330
8,740
1,110
35.9
2.8
320
79.6
606
1.0
156
<30
1,450
953
<98.0
199
426
98.3
700
4,200
40
30
50
900
170
5
100
10
90
60
30
10
99
-------
Tight-head facilities generally discharge wastewater and
nearly half of the dischargers do not treat wastewater.
Wastewater treatment pollutant removal efficiencies were
poor at the four plants sampled by the Agency.
Sedimentation, oil/water separation, and air flotation
are the dominant treatment technologies at tight-head
plants. Reuse of treated effluent is possible; however,
zero discharge is only attainable if wastestreams are
segregated and water conservation measures are
imp1emented.
Approximately 124 million pounds of residue are contained
in drums received by reconditloners, annually.
Wastewater treatment sludges generated by the industry
are composed mainly of oil and grease (22 percent) and
suspended solids (8 percent). High concentrations of 23
organics are observed.
100
-------
7. COST OF WASTEWATER CONTROL AND TREATMENT
The purpose of this section is to describe appropriate
technology and costs for controlling industry wastewater
discharges. An economic assessment of possible regulations
affecting the solvent recovery industry is presented.
7.1 INTRODUCTION
.This section provides cost estimates for installing and
operating wastewater treatment technology that is currently
in-place in the drum reconditioning industry. In 1979, about half
of the respondees to the National Barrel and Drum , Association
(NABADA) survey responded that they treat process wastewater prior
to discharge. In this study, 13 out of 16 plants contacted provide
wastewater treatment prior to discharge* However, as demonstrated
in Section 6, the pollutant removal efficiencies of currently
installed equipment are low. Therefore, a U.S. Environmental
Protection Agency (EPA) decision to regulate the drum
reconditioning industry will likely result in a significant
investment in equipment and personnel.
7.2 MODEL TREATMENT SYSTEM
Physical/chemical treatment is the prevailing technology in
the drum reconditioning industry. This technology takes the forms
of sedimentation, oil/water separation, and air flotation. These
technologies and related costs have been studied by the Industrial
Technology Division (ITD) of EPA for numerous other industries.
The Final Development Document for Effluent Limitations Guidelines
and Standards for the Metal Finishing Point Source Category report
costs for an emulsion breaking system that can be used as a model
for estimating physical/chemical treatment costs for the drum
reconditioning industry (EPA 1983).
Emulsion breaking is a demonstrated zero discharge technology
for the drum reconditioning industry. The Agency visited three
washing facilities that use air flotation, a variation of emulsion
breaking, to achieve zero discharge. Each plant reconditions a
variety of drum types that total between 500 and 3,000 drums daily
per facility. Treated wastewater is used as makeup to caustic wash
and as a intermediate stage rinse water.
Open-head drum reconditioners also have achieved zero
discharge of process wastewater through the use of
physical/chemical treatment. EPA visited a facility that recycles
quench water after it is treated by sedimentation. Minor process
wastestreams, such as paint booth water curtain overflow, also are
treated and recycled. Because of evaporation losses in the quench
process, the makeup water supply is supplemented with tap water.
Two other drum burning plants discharge their quench water to
emulsion breaking treatment systems that are employed to achieve
zero discharge of their combined open- and tight-head wastewaters.
101
-------
The model emulsion breaking system is identified as treatment
system - Option 1 for the Metal Finishing Category. The system was
designed to treat raw wastewater with oil and grease and toxic
organic levels in excess of those observed in drum reconditioning
wastewaters. Figures 7-1 and 7-2 are capital cost and operating
cost curves, respectively, for the model system. All costs are
reported in 1979 dollars, and a detailed discussion is presented
in Appendix D.
Wastewater flows found in the drum reconditioning industry
range from 100 to 20,000 gallons per day; therefore, the cost
curves shown in Figures 7-1 and 7-2 are appropriate for the drum
reconditioning industry. An average drum washing plant discharges
3,000 gallons of wastewater per day. In terms of 1979 dollars, an
average plant that installs batch mode treatment would incur a
capital cost of $70,000 and an annual operating expense of $25,000.
Based on the use of cost indices, these costs would be $97,000 and
$35,000, respectively, in 1985 (Engineering News Record 1985). A
wastewater recycle system would add $13,000 to the capital cost
(Means 1986). The cost of land and retrofit of existing process
could add 20 percent to capital costs. The cost of collecting
volatile organic carbon air emissions and venting to an existing
control device would also increase costs 20 percent (EPA 1985).
Sludge residuals would average about 2.5 percent of the wastewater
volume or 75 gallons per day. The annual sludge disposal costs
would average $2,000 if sludge is generated 270 days per year and
the sludge is assumed to be nonhazardous since drum residuals are
excluded from the RCRA definition of hazardous wastes ($5,000 = 270
x 75 x 25c/). Discharge compliance monitoring costs would be
$2,000 per year. In summary, the total system capital cost would
be $154,000 (154,000 = 97,000 + 13,000 for recycle + 22,000 for
land and retrofit + 22,000 for emissions control). The total
system operating cost would be $47,000 (47,000 -= 35,000 + 5,000
for emissions control + 5,000 for sludge disposal. + 2,000 for
compliance monitoring).
7.3 ECONOMIC ASSESSMENT AND COST-EFFECTIVENESS
This subsection presents a preliminary economic assessment of
possible regulations affecting the drum reconditioning industry.
The first part of the subsection describes the treatment technology
and costs analyzed, and presents the results of the economic impact
analysis. The second part of the subsection provides an analysis
of the cost-effectiveness of the treatment option.
7.3.1 Economic Assessment
This preliminary assessment of the possible economic impacts
is based on an analysis of model plants. The impacts are measured
by comparing unit control costs to service fees and drum value.
The Agency has determined, tentatively, that the model
end-of-pipe treatment system for the drum reconditioning industry
is air flotation. For a typical plant reconditioning 427 drums per
102
-------
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103
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104
-------
day, this control option would result in a capital cost of $154,000
and an annual operating and maintenance cost of $47,000. If
capital costs are annualized using a capital recovery factor of
0.26, the total annualized cost is $87,000.
For the model plant processing 427 drums per day and operating
260 days per year, the annualized control cost is about $0.78 per
drum served. Based on the Agency data (SAIC 1986), laundry/service
fees are about $6.50 per drum. Therefore, control costs are about
12 percent of the service fee. A second impact measure compares
the control cost to the price of a reconditioned drum. Since the
price is about $12.00, control costs are about 6.5 percent of the
price of a reconditioned drum. Table 7-1 summarizes the
calculations. By either measure, the impact of this control option
is very low.
7.3.2 Cost-Effectiveness
Cost-effectiveness is defined as the incremental annualized
cost of a pollution control option in an industry, or an industry
subcategory, per incremental pound equivalent of pollutant removed
by that control option. The analysis accounts for differences in
toxicity among the pollutants with toxic weighing factors (TWF).
The methodology for calculating cost effectiveness follows that
used by EPA-ITD in studies of the Organic Chemicals, Plastics, and
Synthetic Fibers Industry. Because concentration data are not
always available for many priority and nonpriority pollutants,
incremental removal may be underestimated for this preliminary
cost-effectiveness calculation.
The control technology consists of sedimentation, oil/water
separation, and air flotation followed by partially recycling
treated wastewater. In passing through a publicly-owned treatment
works (POTW) or any treatment system using an aeration operation,
a volatile chemical can be either volatilized to the air,
decomposed, removed in sludge, or discharged via outfalls. In this
calculation, it is assumed that the volatilized portion of VOCs is
captured and removed.
Table 7-2 shows the data used and the step-by-step
calculation. For 250 drum reconditioners generating wastewater,
each producing 3,000 gallons per day, the annual wastewater flow
is'195 million gallons. The pounds equivalent (PE) removed for
each pollutant is calculated on the basis of flow, concentration
of that pollutant, and removal efficiencies. As described in
Chapter 5, the Agency estimated the concentration of each pollutant
based on sample data. Method I concentrations are appropriate for
the cost effectiveness analysis and are used in this document.
Total loadings for each pollutant are calculated by applying the
Method I concentrations and the proportion of sample plants with
detectable levels of the pollutant (labeled probability on the
table) to the total number of plants. In total, 166,551 pound
equivalents of priority pollutants are removed. The annualized
cost per plant is $87,040, or $21.76 million for 250 plants.
Therefore, the cost-effectiveness of this treatment option is $131
105
-------
TABLE 7-1. IMPACT ON DRUM RECONDITIONING INDUSTRY
Totals
Cost Impact Measure
Annualized Cost
Capacity
Laundry/Service Fee
Reconditioned Drum Price
$87,000
427 drums per day $0.78/drum
$6.50*/drum 12% of service fee
$12.00*/drum 6.5% of drum price
106
-------
TABLE 7-2 COST-EFFECTIVENESS CALCULATION FOR
DRUM RECONDITIONING WASTEWATER TREATMENT
Nuibir of plants (N) 230
NasttMttr flo* (gpd) 1 uch plant (q) 3,000
Hutbtr of days/ytar in optration (d) 260
Annual flem dgy) for all plants • K x q i d 193
Obstrvtd taipli ! Ran nastt
Proba- cone. ! Expictid cone.
Pollutant IMF bility (ppb) ! (ppb) ctd.
1,1,1-TCA
1,1-Dichlorotthtnt
1,2-Dichlorotthani
2-Chloronaphthalini
2-Nitrophtnol
Acitoni
Bie(2-ih) phthalatt
Butyl binzyl phthal
D-N-Butyl phthalatt
Ethylbtnztnt
Isophoront
Htthyltnt chloridi
Naphthaltnt
Phtnanthrtnt
phtnol
Tttrachlorotthtnt
Tolutnt
T-l,2-Dichlorotthtn
Trichlorotthtnt
Endosulfan I
Endosulfan tulfatt
0.000300
16.970000
0.596000
0.350000
0.001700
0.000000
2.186700
0.025400
0.000165
0.004000
0.000010
2.947000
0.009030
0.028100
0.002190
0.707000
0.000400
0.000500
0.207000
100.035000
100.035000
Htptachlor 3438.600000
Sui (organic)
Antiiony
Arstnic
Cadiiui
Chroiiui
Copptr
Ltad
Nickil
Zinc
Itrylliui
0.003620
32.029000
5.090000
0.026700
0.467000
1.730000
0.114000
0.119000
3.840000
fcrcury 505.026000
Sui dttals)
****************
Organici plui ntalt
Annual izid coiti for
KtM Jftf"\
(I/PE)
0.3
0.25
0.25
0.5
0.25
0.25
0.25
25
0.25
1
0.25
0.5
0.75
0.25
0.25
0.25
1
0.25
0.5
0.25
0.25
0.25
0.3
0.75
18384 9192
25286
315
2323
2953
857784
21449
3281
6887 !
21598 i
14048 !
9820 i
3108 !
11377 !
932 !
86267
20295 !
917 !
1135 !
296 !
528 1
284 !
!
3481 !
54 !
405 i
3163 !
1581 1
14485 !
201 i
24975 !
20 t
8 !
i
i
'BBBBBSBBBBBBBBSBIBBBBSBBSB | 1
all planti
6322
79
1162
738
214446
5362
82025
1722
21598
3512
4910
2331
2894
233
21567
20295
229
568
74
132
71
399,461
3481
54
405
3163
1381
14485
201
24973
10
6
48,361
3
107276
47
407
1
0
11726
2083
0
86
0
14470
21
81
1
15248
8
0
117
7403
13205
244141
416,323
13
1730
2061
84
738
23349
23
2972
38
3030
36,039
I
1
I
!
1
1
!
I
I
1
!
!
t
I
1
1
1
1
I
1
!
:
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i
i
i
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I
1
1
1
1
t
1
1
!
i
!
1
1
I
I
!
j
i
i
i
!
!
I
R
0.6
0.46
0.19
0
0.08
0.91
0.93
0.5
0.86
0.81
0.64
0.24
0.71
1
0.5
0.32
O.B
1
0.7
1
0
0
0.24
0.31
0.36
0.67
0.58
0.78
0.46
0.53
0.06
0.65
tfasttnattr triatitnt lystti
ifflutnt cone, annual rtaoval
(ppb) (rtd. (lb) (PE)
3677
3414
64
1162
679
19300
373
41013
241
4104
1264
3732
676
0
117
14665
4059
0
170
0
132
71
98,914
2646
37
259
1044
664
3187
109
11738
9
2
19,693
IB««BBBBBBBB«BBB»B| «mBBB»BSBBBi
447,822
432,382
118,608
1
37929
38
Vl>
407
1
0
821
1042
0
16
0
10997
6
0
o
10368
2
o
35
0
13203
244141
339,009
10
1193
1319
28
310
3577
12
1397
35
1061
10,962
§•49
• 7Q7
4729
o
96
317366
8110
66699
2408
28451
3655
1916
2692
4707
189
IDT
11224
2640S
»w^ vw
373
w/ v
646
120
o
0
488,780
1359
27
237
3446
1491
18374
130
21327
1
6
46,620
IBBBBSBBBBBIIBBBSIBB
349,970
i uch plant: invtstitnt (1)
land
coiti (201
of abovt)
($)
OM cott (l/y)
•enitoring coit
annual iztd cost
(l/y)
(1) including 20X
of invtstitnt 1 OtK for
capturing VflCs,
333,400
21
110,000
22,000
35,000
5,000
87,040
80253
IK
19
A
V
o
A
V
17735
1694
A
V
114
A
V
5648
24
132
A
V
7935
A
V
134
12039
0
125,736
5
872
1207
92
696
32135
17
2562
3203
40,815
BBBBBSBBI
166,551
,760,000
130 45
•) W*Bw
107
-------
per pound equivalent. The high cost-effectiveness value probably
is a result of the fact that the control technology, while
effective for removing conventional and nonconventional pollutants,
is not specifically known for removing priority pollutants.
7.4 SUMMARY
A model wastewater treatment system would include
emulsion breaking technology and treated wastewater
reuse. A typical facility would incur a capital cost of
$154,000 and an annual operating cost of $47,000 to
maintain and operate such a system.
• The annualized wastewater control cost is $0.78 per drum
reconditioned which represents about 12 percent of the
reconditioning fee.
The cost-effectiveness of treating the process wastewater
is $131 per pound equivalent of pollutant removed.
108
-------
8. ENVIRONMENTAL ASSESSMENT
The purpose of this section is to present the results of
environmental impacts analysis. The methodology used to estimate
human health and aquatic life water quality impacts is described
and results are discussed. Non-water quality impacts on emissions
to the air, solid waste generation, and energy usage are also
discussed.
8.1 METHODOLOGY USED TO ESTIMATE HUMAN HEALTH AND AQUATIC LIFE
WATER QUALITY IMPACTS
Ah environmental assessment of water quality impacts was
performed for both direct and indirect wastewater dischargers.
Average plant raw waste concentrations and discharge flows for this
industry/subcategory were used to project impacts on receiving
streams. Water quality impacts for treated effluents were not
performed because of the lack of pollutant-specific data.
8.1.1 Direct Discharge Analysis
The following analyses were performed for direct dischargers:
(1) criteria comparisons, (2) stream flows with potential impacts,
and (3) loading comparisons. The raw waste concentrations from
wastestreams were compared to available water quality criteria
(acute and chronic aquatic life criteria/ toxicity levels); human
health criteria (ingesting water and organisms) , including criteria
for carcinogenicity protection or toxicity protection; and existing
or proposed drinking water standards. A value greater than one
indicates a criteria exceedance. The numerical values associated
with these exceedances (exceedance factors) represent instream
dilutions needed to eliminate projected water quality impacts.
Because actual receiving streams flow data were not available
for this industry/subcategory, the stream flows with potential
impacts also were projected using stream dilution factors and
average plant flows.
Specific pollutant loadings were calculated based on the raw
waste concentrations and total industry/subcategory flow and
summed. The pollutant loadings were grouped into four categories:
(1) total priority organics, (2) total nonpriority organics, (3)
total priority inorganics, and (4) total nonpriority inorganics.
The total priority organics and inorganics were compared to the
total raw waste pollutant loadings from regulated BAT industries
to evaluate the significance of pollutant loadings from the i-
ndustry/ subcategory considered in this document.
8.1.2 Indirect Discharge Analysis
The following analyses were performed for indirect
dischargers: (1) criteria comparisons using a POTW model and
stream dilution analysis, (2) impacts to POTWs, and (3) loading
comparisons.
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A simplified POTW model and stream dilution analysis were
performed to project receiving stream impacts from indirect
dischargers. Actual receiving stream flow and POTW flow data were
not available for this industry/ subcategory. In order to project
receiving stream impacts, a statistical analysis was performed on
the EPA's In-House Software (IHS) Industrial Facilities Discharge
File and GAGE File to determine a POTW plant flow and a POTW
receiving stream flow for use in the analyses. The 25th, 50th, and
75th percentile flows for POTWs with industrial indirect
dischargers were 0.35, 1.1, and 3.0 million gallons per day (MGD),
respectively. For this study, a 1.0 MGD plant flow is used. This
is approximately the 50th percentile (median) flow and
representative of the typical POTW plant flow. Twenty-one POTWs
receiving industrial discharge had a plant flow of 1.1 MGD. The
median receiving stream flow for the 21 POTWs was 12 MGD at low
flow conditions and was used in the analysis to determine the
diluted POTW effluent concentration.
Potential water quality impacts on receiving streams were
determined using criteria comparisons. The POTW effluent pollutant
concentrations calculated using Equation 1 were compared to acute
aquatic criteria/toxicity levels to determine impacts in the mixing
zone.
Equation 1;
POTW Effluent (/ig/1) = POTW Influent (jug/1) *
(1-Treatment Removal Efficiency)
A calculated instream diluted POTW effluent concentration
using Equation 2 was compared to chronic aquatic life
criteria/toxicity levels, human health criteria, and drinking water
standards.
Equation 2;
In-Stream Diluted POTW Effluent(Mg/l) =
POTW Effluent fug/1) X POTW FlowfMGD)
POTW Receiving Stream Flow(MGD)
Impacts on POTW operations were calculated in terms of
inhibition of POTW processes and contamination of POTW sludges.
Inhibition of POTW operations were determined by comparing POTW
influent levels (Equation 3) with inhibition levels, when
available.
Equation 3;
POTW Influent (MS/I) = Average Plant Concentration x
Total Industry Flow (MGD)
POTW Flow(MGD)
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Contamination of sludge (thereby limiting its use) was
evaluated by comparing projected pollutant concentrations in sludge
(Equation 4) with sludge contamination levels, when available.
Equation 4;
Pollutant Concentration in Sludge (mg/kg) =
POTW Influent (jug/1) x Partition Factor x
Tmt. Removal Efficiency x 5.96 x Conversion Factors
The partition factor is a measure of the tendency for the
pollutant to partition in sludge when it is removed from
wastewater. For metals, this factor was assumed to be one. For
predicting sludge generation, the model assumed the Metcalf and
Eddy rule of thumb that 1,400 pounds of sludge is generated for
every million gallons of wastewater processed which results in a
sludge generation factor of 5.96.
To evaluate the significance of pollutant loadings from
untreated indirect discharges, loading comparisons from indirect
dischargers were performed using the same approach as with the
direct dischargers. The total raw waste priority pollutant organic
and inorganic loadings were compared to the total raw waste
pollutant loadings from regulated industries with Pretreatment
Standards for Existing Sources (PSES).
8.2 RESULTS OF ENVIRONMENTAL ASSESSMENT
8.2.1 Direct Dischargers
8.2.1.1
Raw Wastewater
Because of the high concentration for the majority of detected
pollutants, projected water quality impacts from direct discharges
of untreated (raw) wastewaters are significant for small to medium
receiving streams (with stream flows up to 16,000 MGD), even at
small average plant discharge flows (3,000). Of 77 detected
pollutants, 59 were at levels that may be harmful to human health
and/or aquatic life:
28 pollutants (including 10 carcinogens) have projected
human health impacts for streams with less than 3,000 MGD
flow;
29 pollutants have projected short-term (acute) aquatic
life impacts in mixing zones of receiving streams with
exceedance factors ranging from 1 to 36,300;
51 pollutants have projected long-term (chronic) aquatic
life impacts for streams with less that 16,000 MGD flow;
and
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8.2.1.2
17 pollutants have projected drinking water impacts for
streams with less than 11 MGD flow.
Treated Wastewater
Potential water quality impacts from the direct discharge of
treated wastewater were projected for small and medium streams
(with stream flows up to 15,000 MGD). Of the 77 detected
pollutants, 52 were at levels that may be harmful to human health
and/or aquatic life:
• 22 pollutants (including 10 carcinogens) have projected
human health impacts for streams with less than 3,000 MGD
flow;
19 pollutants have projected short-term (acute) aquatic
life impacts in mixing zones of receiving streams with
exceedance factors ranging from 1 to 33,000;
41 pollutants have projected long-term (chronic) aquatic
life impacts for streams with less that 15,000 MGD flow;
and
14 pollutants have projected drinking water impacts for
streams with less,than 6 MGD flow.
8.2.1.3 Pollutant Loadings (Ibs/day)
Priority organics:
Non-priority organics:
Priority inorganics:
Non-priority inorganics:
Raw
Wastewater
316
2,207
66
184
2,773
Treated
Wastewater
140
584
29
79
832
Total direct discharge loadings of priority pollutants from
raw wastewater are comparable to regulated industries raw loadings
as follows:
Organic loadings of 316 Ibs/day compare with the leather
tanning raw waste loadings, ranked in the lower half of
raw waste loadings from regulated industries; and
Inorganic loadings of 66 Ibs/day ar low and are less that
any raw waste loadings from regulated industries.
Total direct discharge loadings of priority pollutants from
treated wastewater are comparable to regulated industries with BAT
loadings as follows:
• Organic loadings of 140 Ibs/day compare with coal mining
and metal finishing industries, ranked in middle, in
terms of loadings, of BAT-regulated industries;
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8.2.2
8.2.2.1
Inorganic loadings of 29 Ibs/day compare with the
porcelain enameling industry, ranked in the lower fourth
of BAT-regulated industries.
Indirect Dischargers
Raw Wastewater
Indirect discharges of raw wastewaters (projected based on a
model 1 MGD POTW) are expected to inhibit POTW treatment for one
pollutant but not cause any sludge contamination; however, raw
wastewater may cause POTWs to exceed human health criteria in
receiving streams for 4 pollutants (all carcinogens), and aquatic
life criteria/toxicity levels, both acute and chronic, for 7 and
6 pollutants, respectively.
8.2.2.2 Treated Wastewater
Potential water quality and POTW impacts from indirect
discharge of treated wastewater (projected based on a model 1 MGD
POTW) are expected to inhibit POTW treatment for one pollutant but
not cause andy sludge contamination; however, treated wastewater
may cause POTWs to exceed human health criteria in receiving
streams for 4 pollutants (all carcinogens) and aquatic life
criteria/toxicity levels, both acute and chronic, for 3 pollutants.
8.2.2.3 Pollutant Loadings (Ibs/day)
Priority organics:
Non-priority organics:
Priority inorganics:
Non-priority inorganics:
Raw
Wastewater
1,263
8,828
263
737
11,091
Treated
Wastewater
559
2,338
117
316
3,330
Total indirect discharge loadings of priority pollutants from
raw wastewater are comparable to regulated industries raw loadings
as follows:
Organic loadings of 1,263 Ibs/day compare with the raw
waste loadings from the electronic component industry,
ranked in the lower half of raw waste loadings from
regulated industries; and
Inorganic loadings of 263 Ibs/day are low and compare
with the plastic molding and forming, ranked in the lower
half of raw waste loadings from regulated industries.
Total direct discharge loadings of priority pollutants from
treated wastewater are comparable to regulated industries with PSES
loadings as follows:
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• Organic loadings of 559 Ibs/day compare with the leather
tanning industry, ranked in middle of PSES-regulated
industries; and
Inorganic loadings of 117 Ibs/day also compare with the
middle of the PSES-regulated industries.
8.3 NON-WATER QUALITY ENVIRONMENTAL IMPACTS
The elimination or reduction of one form of pollution may
create or aggravate other environmental problems. Therefore,
Sections 304,(b) and 306 of the CWA require EPA to consider
non-water quality environmental impacts of certain regulations.
In compliance with these provisions, EPA has considered the effect
of possible regulations on air pollution, solid waste generation,
and energy consumption. The non-water quality environmental
impacts associated with this regulation are described below.
8.3.1 Air Pollution
Implementation of the model cost technology, air flotation,
would result in a net reduction of air emissions. This conclusion
is based on information developed during a study of dissolved air
flotation (DAF) systems used in the petroleum refining industry
(USEPA 1985). Installation of fixed roofs on DAF systems was shown
to result in a 69 percent reduction in volatile organic carbon
(VOC) emissions compared with uncovered systems. Collection of VOC
emissions and venting to a control device was shown to result in
95 percent reduction. Similar percent reductions are potentially
achievable in the drum reconditioning industry, although data are
not available to accurately estimate the VOC mass potentially
reduced.
8.3.2 Solid Waste
EPA considered the effect that implementation of the model
control technology could have on the production of solid waste,
including hazardous waste defined under Section 3001 of the
Resource Conservation and Recovery Act (RCRA). EPA estimates that
increases in total solid waste of 9,700 metric tons of sludge per
year, including hazardous waste, resulting from implementation of
the model technology, will double current levels (SAIC 1987). The
Agency included sludge incineration in the estimated engineering
costs of compliance for any incremental sludge generated by the
model treatment systems. Therefore, the net residual solid waste,
in the form of ash, will be negligible.
8.3.3 Energy Requirements
EPA estimated that implementation of the model control
technology would double energy consumption from present industry
use, since only half of the industry is believed to have any
technology currently in place. With the exception of sludge
incineration, the estimated increased energy consumption is 250
barrels of No. 2 fuel per year (SAIC 1987). The energy consumption
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associated with incineration is assumed to be small, since air
flotation sludges are composed of oil, greases, and other organics
that have high-energy values.
Such sludges can be used in fuel blends in existing furnaces,
and therefore, disposal costs are minimal.
8.4 SUMMARY . ,
The following list summarizes the major points that were
discussed in this section:
Total loadings of priority pollutant inorganics from
untreated wastewater are low when compared to raw waste
loadings of priority inorganics from regulated BAT/PSES
industries.
Total loadings of priority pollutant organics from
untreated wastewater are significant when compared to raw
waste loadings from regulated industries.
Implementation of the model cost technology would result
in a net reduction of air emissions, a doubling of the
volume of sludge generated from wastewater treatment
systems, and a doubling of energy consumption.
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9. REFERENCES
Engineering News Record. March 21, 1985. Vol. 214, No. 12, p.
98.
Means, R.S., Company Inc. 1986. Building Construction Cost
Data. 44th Annual Edition.
Rich, L.A. 1986. Drum Residue: A $ Billion Inch.
March 5, 1986. pp. 13-16.
Chemical
Science Applications International Corporation. 1986. Drum
Reconditioning Industry Mid-Project Report. September,
1986.
Science Applications International Corporation. 1987a. Memo to
project files. June 17, 1987.
Science Applications International Corporation. 1987b. Memo to
project files. May 28, 1987.
Science Applications International Corporation. 1987c. Memo to
project files. June 18, 1987.
Science Applications International Corporation. 1987d. Drum
Reconditioning Industry Plant Files.
Science Applications International Corporation. 1987e. Personal
Communications Between Richard Hergenroeder and an Industry
Representative.
Touhill, Shuckrow and Associates, Inc. 198la. Barrel and Drum
Reconditioning Industry Status Profile. EPA-600/2-81-232.
Touhill, Shuckrow and Associates, Inc. I981b. Drum
Reconditioning Process Optimization. EPA-600/2-81-233.
U.S. Environmental Protection Agency. 1983. Development
Document for Effluent Limitations Guidelines and Standards
for the Metal Finishing Point Source Category. EPA
440/1-83/091.
U.S. Environmental Protection Agency. 1985. VOC Emissions From
Petroleum Refinery Wastewater Systems - Background
Information for Proposed Standards. EPA-450/3-85-0012.
U.S. Environmental Protection Agency. 1986a. Report to Congress
on the Discharge of Hazardous Wastes to Publicly Owned
Treatment Works. EPA 530/-SW-86-004.
U.S. Environmental Protection Agency. 1986b. Hazardous Waste
Management System; Land Disposal Restrictions; Final Rule.
Federal Register Vol. 51, No. 216, p. 40572.
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