United States
Environmental Protection
Agency
Office of Water
WH-552
Washington, DC 20460
EPA 440/1-89/102
September, 1989
&EPA
Preliminary Data Summary for the
Solvent Recycling Industry
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PRELIMINARY DATA SUMMARY
FOR THE
SOLVENT RECYCLING INDUSTRY
Office of Water Regulations and Standards
Office of Water
United States Environmental Protection Agency
Washington, D.C.
September 1989
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PREFACE
This is one of a series of Preliminary Data Summaries
prepared by the Office of Water Regulations and Standards of the
U.S. Environmental Protection Agency. The Summaries contain
engineering, economic and environmental data that pertain to
whether the industrial facilities in various industries discharge
pollutants in their wastewaters and whether the EPA should pursue
regulations to control such discharges. The summaries were
prepared in order to allow EPA to respond to the mandate of
section 304(m) of the Clean Water Act, which requires the Agency
to develop plans to regulate industrial categories that
contribute to pollution of the Nation's surface waters.
The Summaries vary in terms of the amount and nature of the
data presented. This variation reflects several factors,
including the overall size of the category (number of
dischargers), the amount of sampling and analytical work
performed by EPA in developing the Summary, the amount of
relevant secondary data that exists for the various categories,
whether the industry had been the subject of previous studies (by
EPA or other parties), and whether or not the Agency was already
committed to a regulation for the industry. With respect to the
last factor, the pattern is for categories that are already the
subject of regulatory activity (e.g., Pesticides, Pulp and Paper)
to have relatively short Summaries. This is because the
Summaries are intended primarily to assist EPA management in
designating industry categories for rulemaking. Summaries for
categories already subject to rulemaking were developed for
comparison purposes and contain only the minimal amount of data
needed to provide some perspective on the relative magnitude of
the pollution problems created across the categories.
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ACKNOWLEDGEMENTS
Preparation of this Preliminary Data Summary was directed by
Donald F. Anderson, Project Officer, of the Industrial Technology
Division. Joseph Yance, Analysis and Evaluation Division, and
Alexandra Tarnay, Assessment and Watershed Protection Division,
were responsible for preparation of the economic and
environmental assessment analyses, respectively. Support was
provided under EPA Contract Nos. 68-03-3509, 68-03-3366, and 68-
03-3339.
Additional copies of this document may be obtained by writing to
the following address:
Industrial Technology Division (WH-552)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Telephone (202) 382-7131
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TABLE OF CONTENTS
Section page
1. FOREWORD . . 1
2. SUMMARY 2
3. INTRODUCTION 6
3.1 Purpose and Authority 6
3.2 Regulatory Overview 7
3.2.1 Resource Conservation and Recovery Act 7
3.2.2 Domestic Sewage Exclusion 7
3.2.3 Land Disposal Restrictions ..... 10
3.2.4 Accumulation Time Exemption 10
3.3 Overview of the Industry. 10
3.4 Data and Information Gathering 11
3.4.1 State and Local Data n
3.4.2 Trade Associations . 12
3.4.3 Telephone Contacts 12
3.4.4 Literature Review. ....... <, 12
3.4.5 Facility Site Visits 13
4. DESCRIPTION OF THE INDUSTRY. . 14
4.1 Industry Profile. 14
4.2 Solvent Recycling Processes 18
4.2.1 Solvent Storage Handling ..... 18
4.2.2 Initial Treatment. ................. 18
4.2.3 Distillation 18
4.2.4 Purification 21
4.3 Solvent Usage and Spent Solvent Generation 21
4.4 Industry Subcategorization 23
4.5 Potential for Industry Growth 24
4.6 Financial Characteristics of Commercial Facilities. . . 27
4.7 Summary 28
5. WATER USES AND WASTEWATER CHARACTERIZATION 29
5.1 Pollutant Analysis, Recovery, and Quantification. ... 29
5.2 Water Usage *.... 30
5.3 Wastewater Sources 30
5.3.1 Process Wastewater 31
5.3.2 Cooling and Miscellaneous Wastewater 41
5.4 Residuals Disposal 43
5.5 Summary ....... 46
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TABLE OF CONTENTS (Continued)
Section Page
6. CONTROL AND TREATMENT TECHNOLOGY 53
6.1 Zero Discharge Methods. . 53
6.2 In-Plant Wastewater Control 53
6.3 Wastewater Treatment. 53
6.4 Best Available Demonstrated Technology 54
6.5 Summary 58
7. COST OF WASTEWATER CONTROL AND TREATMENT 60
7.1 Process Wastewater. 60
7.2 Cooling and Miscellaneous Wastewater. . 61
7.3 Economic Assessment and Cost-Effectiveness. ...... 62
7.3.1 Economic Assessment 62
7.3.2 Cost-Effectiveness 64
7.4 Summary 68
8. ENVIRONMENTAL ASSESSMENT 70
8.1 Methodology Used to Estimate Human Health and Aquatic
Life Water Quality Impacts 70
8.1.1 Direct Discharge Analysis. ........... 70
8.1.2 Indirect Discharge Analysis 70
8.2 Results of Environmental Assessment 72
8.2.1 Process Wastewater ............... 72
8.2.2 Contaminated Cooling Water ...... .; 73
8.3 Non-water Quality Environmental Impacts ... 76
8.3.1 Air Pollution. 76
8.3.2 Solid Waste , 76
8.3.3 Energy Requirements r 76
8.4 Summary 77
9. REFERENCES 78
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LIST OF TABLES
Table Page
3-1 EPA Listed Hazardous Wastes From Nonspecific Sources .... 9
4-1 Estimated Distribution of Commercial Solvent Recyclers
by State 17
4-2 Estimated Distribution of Commercial Solvent Recyclers
by EPA Region 18
4-3 Use Distribution of the 10 Most Widely Used Organic
Solvents 22
4-4 Copy of Partial Results of the 1982 NASR Survey 24
4-5 Solvent Volumes Received and Price Ranges Recorded by 8 Firms 25
4-6 Financial Ratios for the Solvent Recycling Industry 27
5-1 EPA-ITD Sampling Program Comparison of Process Wastewater -
Conventionals and Nonconventionals 35
5-2 EPA-ITD Sampling Program Comparison of Process Wastewater -
Metals 36
5-3 EPA-ITD Sampling Program Comparison of Process Wastewater -
Superscan Metals 37
5-4 EPA-ITD Sampling Program Comparison of Process Wastewater -
Extractable and Volatile Organics 39
5-5 EPA-ITD Sampling Program: Cooling Water and Comingled
Nonprocess Wastewater 42
5-6 Still Bottoms Generated at Plant F 44
5-7 EPA-ITD Sampling Program Still Bottoms - Conventionals and
Nonconventionals . 45
5-8 EPA-ITD Sampling Program Still Bottoms - Metals 47
5-9 EPA-ITD Sampling Program Still Bottoms - Extractable and
Volatile Organics 48
5-10 EPA-ITD Sampling Program Still Bottoms - Dioxins/Furans. . . 49
5-11 EPA-ITD Sampling Program Still Bottoms - TCLP
Analysis - Metals 50
5-12 EPA-ITD Sampling Program Still Bottoms - TCLP Analysis -
Extractable and Volatile Organics 51
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LIST OF TABLES (Continued)
Table Page
6-1 EPA-ITD Sampling Program Steam Stripping Performance -
Conventionals and Nonconventionals 55
6-2 EPA-ITD Sampling Program Steam Stripping Performance -
Metals 56
6-3 EPA-ITD Sampling Program Steam Stripping Performance -
Extractable and Volatile Organics 57
6-4 BOAT Treatment Standards 59
7-1 Contract Hauling Costs for Process Wastewater. . 61
7-2 Economics of a Solvent Recovery Model Plant (800,000
Gallons per Year Capacity) 63
7-3 Economic Impact Measures 65
7-4 Cost-Effectiveness Calculation for Solvent Recyclers (Zero
Discharge of Process Wastewater by Contract Hauling) .... 66
7-5 Cost-Effectiveness Calculation for Solvent Recycling
Wastewater Treatment (Cooling Water by Steam Stripping)... 69
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LIST OF FIGURES
Figure
4-1 General Scheme for Solvent Recycling
Page
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1. FOREWORD
The Industrial Technology Division (ITD) of the U.S.
Environmental Protection Agency (EPA) has conducted a study of the
Solvent Recycling Industry as a result of findings from the
Domestic Sewage Study that the quantity of hazardous wastes
generated and discharged to publicly-owned treatment works (POTWs)
by the recycling industry was unknown. The purpose of this ongoing
work is to develop information to characterize the solvent
recycling indxistry as to the scope of the industry, its operations,
and its discharges to the Nation's waters, and to identify and
quantify the pollutants discharged into the Nation's waters.
EPA collected data and information from a variety of sources.
The Agency's information-gathering efforts were coordinated with
five local governments and all of the states. Pertinent trade
associations were contacted and nine sites were visited.
Wastewater was sampled at four sites and the data collected
represent the best available for characterizing the industry.
Analyses were conducted for more than 400 conventional,
nonconventional, priority, and Resource Conservation and Recovery
Act (RCRA) pollutants.
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2. SUMMARY
The following is a summary from the study of the solvent
recycling industry conducted by the Industrial Technology Division
(ITD) of the U.S. Environmental Protection Agency (EPA).
The Domestic Sewage Study, conducted by EPA in response
to Section 3018(a) of the Resource Conservation and
Recovery Act (RCRA), concluded that the quantity of
hazardous, wastes generated and discharged to publicly-
owned treatment works (POTWs) by the solvent recycling
industry was unknown.
Facility inspections and telephone calls conducted by EPA
reveal that not all solvent recyclers are RCRA-permitted
facilities. Generators of spent solvents are erroneously
shipping hazardous wastes to unpermitted facilities in
violation of 40 CFR 262.20b.
Spent solvents are recycled for reuse in fuel blends or
as solvents at 210 facilities located throughout the
Nation. The U.S. EPA Region with the largest number of
recyclers is Region V, with 32 percent of the Nation's
facilities. California, Illinois, and Ohio are the
states with the largest numbers of recyclers.
Solvent recyclers are generally registered under SIC Code
2869 - Industrial Organic Chemicals, Not Elsewhere
Classified. Spent solvent types include nonhalogenated
(75 percent) and halogenated (25 percent).
Solvent recyclers that recover solvents for reuse are
subject to effluent limitations guidelines for the
organic chemicals industry (40 CFR 414). Solvent
recyclers that recycle solvents for use in fuel blends,
only, are not subject to 40 CFR Part 414.
The average solvent recycler handles 0.8 million gallons
of spent solvents annually. Process wastewater
discharges average 400 gallons per day, which results
primarily from the physical separation of water from
spent solvents.
The status of the industry's process wastewater
discharges is as follows:
Discharge Status
Direct discharge
Indirect discharge
Zero discharge
TOTAL
Number of Facilities
10
30
170
210
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The status of the industry's cooling water discharges is
estimated as follows:
Discharge Status
Direct discharge
Indirect discharge
Zero discharge
TOTAL
Estimated Number
of Facilities
36
107
67
210
The industry is not expected to grow or decline
significantly. Hence, the waste quantities estimated in
this report are reasonable projections of future waste
quantities.
Still bottoms are highly concentrated mixtures of
solvents, oils, greases, and solids. Nine dioxin and
furan compounds were found in still bottoms samples. No
discharges of still bottoms to the Nation's waters are
known to occur routinely.
Industry process wastewater is characterized by high
concentrations of conventional, nonconventional, metal,
and organic pollutants. The data shown below for
selected parameters are representative of a typical
industry process wastewater:
Parameter
BOD5
COD
Oil and Grease
TOC
Iron
Lead
Zinc
Acetone
Methylene Chloride
1,1,1-Trichloroethane
Trichloroethane
Total Toxic Organics
Concentration (ma/1)
76,300
145,000
34,400
111,000
177
17
92
6,590
833
82
1.0
14,000
Forty-three extractable and volatile organics were
detected in industry raw wastewaters. Of these, 40 had
industry mean concentrations that exceeded 10 mg/1 and
24 had concentrations that exceeded
100 mg/1.
Zero discharge of process wastewater is achieved by 81
percent of the industry. Contract hauling, fuel
blending, and incineration are the primary zero discharge
technologies.
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Only half of the discharging facilities treat their
wastewater prior to discharge. No single treatment
technology prevails among dischargers.
Zero discharge of process wastewater by contract hauling
and incineration is a model treatment system for the
treatment of this industry's highly variable wastewaters.
A typical facility would incur, a capital cost of $20,000
and an annual hauling cost of $260,000.
Cooling water discharges average 11,000 gallons per day
per facility and contain significant levels of
pollutants. The data below show concentrations found in
this industry.
Parameter
BOD5
COD
TOG
Total Toxic Organics
Concentration fmq/1)
919
3,500 ,
75
440
If treatment of cooling water is needed, steam stripping
technology is available, which can be transferred to the
solvent recycling industry. For treatment of cooling
water, the average plant would incur a capital cost of
$300,000 and an annual operating cost of $35,000.
Costs developed in this report are conservative. Solvent
recyclers are likely to reduce wastewater volumes prior
to shipping wastewater via a contract hauler. Best
management practices are probably a more economical
alternative than steam stripping for the control of
organic pollutants in cooling water. If steam stripping
were a selected control technology, new equipment would
probably not be purchased. Instead, existing equipment
would be retrofit.
The typical plant treatment costs are calculated at $0.47
per gallon of solvent processed, which represents from
19 to 67 percent of the tolling fees.
The cost-effectiveness of treating the two types of
wastewater is not significantly different, ranging from
$79 to $102 per pound equivalent of pollutant removed.
Total loadings of priority pollutant inorganics from
untreated process wastewater are less than the lowest raw
waste total inorganics loadings of regulated BAT/PSES
industries. Total loadings of priority pollutant
organics are more significant and rank in the lower third
of the loadings rankings.
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Total loadings of priority pollutant inorganics and
organics from untreated cooling and miscellaneous
wastewater are low relative to the lowest raw waste
loadings from the regulated BAT/PSES industries.
Implementation of the model cost technologies would
result in a significant increase in solid and hazardous
waste, and a doubling of energy consumption.
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3. INTRODUCTION
The purpose of this section is to present the regulatory
authority and pertinent regulations, and to provide an overview of
the industry. The sources of data and information used to support
the conclusions also are discussed.
3.1 PURPOSE AND AUTHORITY
The Federal Water Pollution Control Act Amendments of 1972
established a comprehensive program to "restore and maintain the
chemical, physical, and biological integrity of the Nation's
waters, Section 101[a]". Under this statute, existing industrial
dischargers were required to achieve compliance with "effluent
limitations requiring the application of the besst practicable
control technology currently available [BPT], Section
301[b][1][A] ." These dischargers are required to achieve effluent
limitations requiring the application of the best available
technology economically achievable [BAT],... which will result in
reasonable further progress toward the national goal of eliminating
the discharge of all pollutants, Section 301[b][2][A]." New
industrial direct discharge performance standards (NSPS), based on
best available demonstrated technology, and existing and new
dischargers to publicly-owned treatment works (POTWs), are subject
to pretreatment standards under Sections 307(b) and (c) of the Act.
While the requirements for direct dischargers are to be
incorporated into National Pollutant Discharge Elimination System
(NPDES) permits issued under Section 402 of the Act, pretreatment
standards were made enforceable directly against dischargers to
POTWs (indirect dischargers).
Although Section 402(a)(1) of the 1972 Act authorized the
setting of requirements for direct dischargers on a case-by-case
basis, Congress intended that control requirements be based on
regulations promulgated by the Administrator that would provide
guidelines that consider the degree of effluent reduction
attainable through the application of BPT and BAT. Sections 304(c)
and 306 of the Act required promulgation of regulations for NSPS,
and Sections 304(f), 307(b), and 307(c) required promulgation of
regulations for pretreatment standards. In addition to these
regulations for designated industry categories, Section 307(a) of
the Act required the Administrator to develop a list of toxic
pollutants and promulgate effluent standards applicable to all
dischargers of toxic pollutants. Categorical pretreatment
standards originally were to be developed for 34 specific
industrial categories and 129 pollutants. The U.S. Environmental
Protection Agency (EPA) subsequently exempted several industries
and pollutants from regulation. Currently, categorical standards
apply to 22 specific industrial categories and 126 priority
pollutants. Finally, Section 501(a) of the Act authorized the
Administrator to prescribe any additional regulations "necessary
to carry out his functions" under the Act. The EPA Industrial
Technology Division (EPA-ITD) is responsible for developing
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effluent guidelines limitations and standards for the categorical
industries.
3.2 REGULATORY OVERVIEW
3.2.1 Resource Conservation and Recovery Act
Congress enacted the Resource Conservation and Recovery Act
(RCRA) in 1976 to define a Federal role in solid waste resource
management and recovery. The Act's primary goals are to: (1)
protect human health and the environment from hazardous and other
solid wastes, and (2) protect and preserve natural resources
through the implementation of programs emphasizing resource
conservation and recovery. The principal regulatory focus of RCRA
is to control hazardous waste. To this end, RCRA mandates a
comprehensive, system to identify hazardous wastes and to track and
control their movement from generation through transport,
treatment, storage, and ultimate disposal. The Act subsequently
was amended in 1978, 1980, and 1984.
Hazardous waste management under RCRA has often been
characterized as "cradle to grave" management. A firm generating
solid wastes is required to determine if such waste is hazardous.
Any generator of a hazardous waste must notify EPA. If the
generator chooses to move the waste off-site for treatment or
disposal, a manifest must be maintained by the generator,
transporter, and the receiving treatment, storage, or disposal
facility. Any wastes shipped off-site to be treated, stored, or
disposed of must be sent to an authorized hazardous waste disposal
facility. Wastes managed on-site, like those shipped off-site,
must be handled according to specific management and technical
requirements in RCRA.
On May 19, 1980, as part of its final and interim regulation
implementing Section 3001 of RCRA, EPA published a list of
hazardous wastes generated from nonspecific sources. Based on the
original listing and subsequent amendments, the list presently
includes 31 commonly used organic solvents and mixtures, or blends,
which contain, in total, 10 percent or more of the listed solvents.
Specifically, included are spent solvents and still bottoms from
the recovery of spent solvents. Table 3-1 is a list of the
regulated solvents. All persons who handle hazardous waste subject
to control under Subtitle C are required to notify EPA according
to Section 3010 of RCRA and obtain an EPA
ID number.
3.2.2 Domestic Sewage Exclusion
The Domestic Sewage Exclusion (DSE) is specified in Section
1004[27] of RCRA and codified in 40 CFR 261.4[A][1]. Under Section
1004[27] of RCRA, solid or dissolved material in domestic sewage
is not, by definition, a "solid waste" and, as a corollary, cannot
be considered a "hazardous waste." Thus, the DSE covers:
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TABLE 3-1. EPA LISTED HAZARDOUS WASTES FROM NONSPECIFIC SOURCES
EPA Hazardous
Waste Number
Hazardous Waste
F001
F002
F003
F004
F005
Tetrachloroethylene
Trichloroethylene
Methylene Chloride
1,1,l-Trichloroethane
Carbon Tetrachloride
Chlorinated Fluorocarbons
Tetrachloroethylene
Methylene Chloride
Trichloroethylene
1,1,1-Trichloroethane
Chlorobenzene
1,1,2-Trichloro-l,2,2-Trifluoroethane
Ortho-dichlorobenzene
Trichlorfluoromethane
Xylene
Acetone
Ethyl Acetate
Ethyl Benzene
Ethyl Ether
Methyl Isobutyl Ketone
N-Butyl Alcohol
Cyclohexanone
Methanol
Cresols
Cresylic Acid
Nitrobenzene
Toluene
Methyl Ethyl Ketone
Carbon Disulfide
Isobutanol
Pyridine
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"Untreated sanitary wastes that pass through a sewer
system"
"Any mixture of domestic sewage and other wastes that
passes through a sewer system to a POTW for treatment."
The premise behind the exclusion is that it is unnecessary to
subject hazardous wastes .mixed with domestic sewage to RCRA
management requirements, since these DSE wastes receive the benefit
of treatment offered by POTWs and are already regulated under Clean
Water Act (CWA) programs, such as the National Pretreatment Program
and the National Pollutant Discharge Elimination System (NPDES).
The exclusion allows industries connected to POTWs to
discharge hazardous wastes to sewers containing domestic sewage
without having to comply with certain RCRA generator requirements,
such as manifesting and reporting requirements. Moreover, POTWs
receiving excluded wastes are not deemed to have received hazardous
wastes and, therefore, are not subject to RCRA treatment, storage,
and disposal facility requirements.
EPA conducted a study in response to Section 3018(a) of the
Resource Conservation and Recovery Act (USEPA 1986c). This
provision required that -EPA prepare
"a report to the Congress concerning those substances
identified or listed under Section 3001 which are not
regulated under this subtitle by reason of the exclusion for
mixtures of domestic sewage and other wastes that pass through
a sewer system to a publicly-owned treatment works. Such
report shall include the types, size and number of generators
which dispose of such substances in this manner, the types and
quantities disposed of in this manner and the identification
of significant generators, wastes, and waste constituents not
regulated under existing Federal law or regulated in a manner
sufficient to protect human health and the environment."
The report is known as the Domestic Sewage Study and is an
evaluation of the impacts of wastes discharged to local wastewater
treatment plants.
In performing this study, EPA collected information on waste
discharges from 47 industrial categories and the residential
sector. Results of the evaluation concluded that the quantity of
hazardous wastes generated and discharged to POTWs by the solvent
recycling industry was unknown. EPA's regulatory efforts, in the
past, have focused on larger industrial categories. The solvent
recycling industry traditionally has been considered a less
significant waste source because of its small size and
service-related orientation. Therefore, this industry has never
been extensively reviewed at the national level for possible
regulation under the CWA.
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3.2.3 Land Disposal Restrictions
On November 7, 1986, EPA promulgated regulations that restrict
the land disposal of the solvents listed under EPA Hazardous Waste
Nos. F001, F002, F003, F004, and F005 (40 CFR 268). These wastes
are prohibited from land disposal unless deepwell injected,
generated by a small quantity generator, generated by an action
under RCRA or the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) , or contained in a mixture
with less than 1 percent total solvents. The Agency has determined
that land disposal restrictions will result in increased demand for
commercial distillation capacity. The Agency also has estimated
that existing distillation capacity should be sufficient to
accommodate any resulting shifts in solvent management practices.
3.2.4 Accumulation Time Exemption
A generator who treats, stores, or disposes of hazardous
wastes on-site must apply for a facility permit and comply with the
conditions in 40 CFR Parts 264 and 265. Regulations for owners and
operators of permitted hazardous waste facilities are addressed by
Part 264. However, a generator may accumulate hazardous waste on-
site for 90 days or less, without a permit or without having
interim status (40 CFR 262.34). As generators of still bottoms and
highly concentrated wastewater, solvent recyclers may exercise the
accumulation time exemption.
Spent solvents are also hazardous wastes, but these wastes are
generated at the sources and not at the solvent recycling
facilities. The generators of the spent solvents are required to
designate, on the manifest, one facility that is permitted to
handle the waste described on the manifest (40 CFR 262.20b).
Hence, solvent recyclers that receive spent solvents should be
RCRA-permitted facilities. Facility inspections and telephone
calls conducted by the Agency reveal that not all solvent recyclers
are RCRA-permitted facilities. Many recyclers believe that the
accumulation time exemption applies to their facility. On the
other hand, generators of spent solvent who are erroneously
shipping hazardous wastes to unpermitted facilities are in
violation of 40 CFR 262.20b.
3.3 OVERVIEW OF THE INDUSTRY
The Agency has identified 210 facilities that recycle solvents
on a commercial basis. The average facility employs eight
employees (NASR 1982). Solvent recycling became popular in the
1970's; hence, few facilities are believed to be more than 20 years
old.
Data on effluent discharges from solvent recyclers are
limited, since most dischargers are regulated by local pretreatment
authorities that do not require extensive monitoring. The Agency
estimates that process wastewater is discharged from approximately
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40 facilities based on telephone data-gathering efforts (SAIC
1987a). Furthermore, only 10 of these 40 facilities are estimated
to be direct dischargers based on a review of the Agency's
Industrial Facilities Database (SAIC 1986a). In addition to
process wastewater, solvent recyclers also discharge cooling water.
About 68 percent of the 210 identified facilities are estimated to
be dischargers of cooling water (SAIC 1987b). Based on the ratio
of direct and indirect process wastewater dischargers (10:30), the
numbers of direct and indirect dischargers of cooling water are 36
and 107, respectively.
The solvent recycling industry is not included in a specific
U.S. Department of Commerce, Bureau of Census Standard Industrial
Classification (SIC). Many solvent recyclers have identified
themselves under SIC Code 2869 - Industrial Organic Chemicals, Not
Elsewhere Classified. Most facilities classified under SIC 2869
are subject to effluent guidelines and standards for the Organic
Chemicals, Plastics, and Synthetic Fibers (OCPSF) Point Source
Category. Subpart G - Bulk Organic Chemicals, includes process
wastewater discharges resulting from the manufacture of many of the
solvents recycled in the solvent recycling industry (40 CFR 414).
However, some solvent recyclers only recycle solvents for use in
fuel blends and are not subject to OCPSF regulations. Furthermore,
noncontact cooling water discharges are not covered under. OCPSF
effluent guidelines.
3.4 DATA AND INFORMATION GATHERING
The Agency sought to obtain a broad and accurate understanding
of the solvent recycling industry and to evaluate wastewater
characteristics and treatment practices. This involved a review
of the literature, meetings with Federal and local agencies,
facility site visits, and identification of all facilities
potentially in the solvent recycling universe. In summary, the
major sources of data and information are as follows:
State and local agencies
Trade associations
Telephone contacts
Literature review
Facility site visits.
3.4.1 State and Local Data
The Agency contacted all state hazardous waste offices by
telephone and mail to identify names of solvent reclaimers. In
some cases, no information was available, since some states do not
regulate solvent reclaimers as hazardous waste facilities if
hazardous wastes are stored on-site for less than 90 days. In other
cases, the state's facility data base does not indicate the nature
of a facility's activity. In addition, hazardous waste offices in
18 states do not track solvent reclaimers. Attempts were made to
contact territories of the United States; however, information was
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not readily available. Permit applications, industrial user
permits, and monitoring data were obtained from the following
agencies:
The Metropolitan Sanitary District of Greater Chicago
The City of Detroit Water and Sewage Department
The County Sanitation District of Los Angeles County
The City of San Antonio Department of Wastewater
Management
The State of Washington, Department of Ecology.
3.4.2 Trade Associations
Membership directories and address lists were requested, by
mail, from 12 associations that are active in the waste management
field. Lists were received from the following- five associations:
Association of Petroleum Re-refiners
Chemical Waste Transportation Council
Institute of Chemical Waste Management
National Association of Solvent Recyclers
Spill Control Association of America.
Five additional trade associations also were contacted by
telephone. However, based on conversations with association
directors, these are not believed to be pertinent to this study.
In March 1982, the National Association of Solvent Recyclers
(NASR) released the results of its member survey. Twenty-five
responses were received out of 38 questionnaires sent out. ' The
survey asked 13 questions relating to plant production. Survey
results are included in Appendix A of this report.
3.4.3 Telephone Contacts
The Agency contacted 204 potential solvent recycles for the
purpose of verifying information contained in the Agency's
Industrial Facilities Database and the Hazardous Waste Data
Management System. Solvent recyclers were asked whether commercial
recovery was conducted on-site and whether process wastewater was
discharged to a POTW or to surface water. Of the 204 facilities
targeted to contact, 97 could not be contacted, no longer recover
solvents, or act only as transfer stations. Out of the remaining
107 facilities, only 21 reported direct/indirect discharge of the
solvent recovery process wastewater.
3.4.4 Literature Review ,
The Agency undertook a literature search of information on
this industry. Numerous articles report data on in-plant solvent
recovery at paint, ink, metal finishing, chemical, rubber,
plastics, and other manufacturing industries. However,
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comparatively few articles are available on the commercial solvent
recovery industry. The primary literature sources are "Source
Assessment: Reclaiming of Waste, Solvents, State of the Art,"
published by EPA's Office of Research and Development (EPA-ORD) in
April 1978, and "Best Demonstrated Available Technology (BOAT)
Background Document for F001-F005 Spent Solvents," published by
EPA's Office of Solid Waste (EPA-OSW) in November 1986.
3.4.5 Facility Site Visits
The Agency contacted numerous solvent recyclers to identify
candidates for wastewater sampling. Site visits were conducted to
locate sample points in the facilities and to collect file
information. Facilities that did not treat wastewater or did not
have accessible sample points were not selected for sampling.
Presampling and sampling site .inspections were conducted at the
following ten facilities:
Clayton Chemical Company, Sauget, Illinois
Chemical Processors Incorporated, Seattle, Washington
Environmental Processing Services, Dayton, Ohio
KDM Company, San Antonio, Texas
Oil and Solvent Process Company, Azusa, California
Omega Chemical Corporation, Whittier, California
Orgcinic Chemicals Incorporated, Grandville, Michigan
Prillaman Chemical Corporation, Martinsville, Virginia
Romic Chemical Corporation, East Palo Alto, California
Spectron Incorporated, Elkton, Maryland.
In summary, the Agency coordinated its information-gathering
efforts with five local governments and the states. Pertinent
trade associations were contacted and a literature search was
conducted. Ten facilities were visited and 204 were targeted to
be contacted by telephone. The Agency believes that the
conclusions presented in this report reflect the best information
available.
13
-------
4. DESCRIPTION OF THE INDUSTRY
The purpose of this section is to discuss industry products
and processes, as well as facility characteristics. This
information is necessary to establish groupings within the
industry. These grouping should reflect differences in wastewater
generation, control, treatment, and discharges.
4.1 INDUSTRY PROFILE
Commercial solvent recycling is defined in this report as the
recycling of spent solvents that are not the byproduct or waste
product of a manufacturing process or cleaning operation located
on the same site. Any recovery operation is considered
commercially available if it is offered to other parties not under
the same ownership as the recovery operation. A commercial
recovery plant may be operated on a site where unrelated products
are manufactured. This study does not cover recovery operations
that are an integral part of a main process, such as solvent
refining, or vegetable oil manufacturing. This study does not
cover recovery operations that are added onto a process. For
example, some surface coating and cleaning industries add on
recovery operations to reclaim spent solvents that are reused on-
site.
Solvent recycling became popular in the 1970's as a means of
reusing the solvents. During this time, the cost of solvents
increased many times following increases in the cost of crude oil.
The cost of recovering solvents, primarily through distillation,
became increasingly economical. Additionally, air and water
pollution legislation, along with the Resource Conservation and
Recovery Act (RCRA), which classified spent solvents as hazardous
wastes, resulted in a restructuring of ways to dispose of solvents
and in increasing disposal costs. As a result of these
occurrences, many industries have installed solvent reclaiming
facilities on their plant sites. However, the majority of
companies in other manufacturing industries that generate spent
solvents have opted to ship them to off-site commercial recyclers
rather than installing on-site recycling facilities. These
recyclers accept various types of solvents from various
manufacturing industries, and either return the solvent to the
industry that sent it, or sell the solvent to companies in other
industries.
Spent solvents are recycled in a variety of ways for the
purpose of reusing the product as a solvent or in fuel blends. The
products recycled for use as solvents are refined in specially
constructed distillation columns, where the solvent separates as
a condensate from the resins and pigments that remain as still
bottoms. The condensate is collected, tested for conformance with
commercial specifications, and sold for use as a primary product.
Spent solvents and still bottoms recycled for reuse as fuel
typically are collected and blended to meet predetermined fuel
14
-------
specifications and are used as a fossil fuel substitute in cement
kilns or as a feedstock for blast furnaces. The process can range
in complexity from this simple operation to a complex multistep
distillation.
In 1981, 173 million gallons of spent solvents were shipped
off-site by generators to commercial recyclers (Engineering Science
1985). Therefore, each of the 210 estimated commercial recyclers
receives an average of 0.82 million gallons annually. This
estimate does not compare well with an NASR (1982) estimate of 1.99
million gallons for an average facility. Reasons for the
difference are probably due to the small sample size in the NASR
survey. Only 18 facilities provided information on throughput, and
these facilities reported annual recycling rates ranging from 0.12
to 8.4 million gallons. Since the estimate of 173 million gallons
was determined by an independent source, a typical facility
throughput of 0.8 million gallons is reasonable.
Solvent reclaimers have three general markets (NASR 1986):
Batch Toll Processing. Some customers have long-term
contracts with a recycler to handle their particular
spent solvents, separate reusable solvent from
contaminants, and return the recycled solvents. The fee
depends on difficulty of separation and market supply and
demcind conditions.
Open Market. Recycling also may be considered a
manufacturing process that uses spent solvents as raw
materials. The spent solvents are recycled to
specification and the product is sold on the open market.
Industrial Furnace Fuel. Spent solvents and solvent
still bottoms receive some physical treatment and are
blended with fuel for use in industrial furnaces and
cement kilns.
The Agency estimates that there are 210 off-site commercial
recyclers. This estimate is based on 312 facility names reported
in literature and identified by state and local contacts, and trade
associations. The Agency contacted, by telephone, 204 of these
facilities to verify their status. Of the 157 responses received,
51 indicated that they had ceased operations or
no longer handled spent solvents. Consequently, the universe of
solvent recyclers is estimated to be 210 facilities, where
(157-51)/157 x 312 = 210.
Table 4-1 lists the potential solvent recyclers classified by
state. The states with the largest number of potential recyclers
are California, Illinois, Ohio, and Michigan. Table 4-2 lists the
potential solvent recyclers sorted by U.S. Environmental Protection
Agency (EPA) Region. Of the 210 estimated facilities, 30 percent
are located in EPA Region V. The list of 312 facility addresses
is included in Appendix B (Boubel 1985; Environmental Information
Ltd. 1986; EPA 1985a).
15
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TABLE 4-1.
ESTIMATED DISTRIBUTION OF COMMERCIAL SOLVENT RECYCLERS
BY STATE
State
Estimated Number
of Plants
Alabama
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Nebraska
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
Tennessee
Texas
Utah
Virginia
Washington
Wisconsin
(Puerto Rico)
Total
1
5
3
22
4
1
1
3
5
1
1
17
8
1
1
4
1
1
1
7
13
8
1
7
5
5
1
10
1
1
16
3
3
8
1
7
4
9
1
1
11
5
1
210
16
-------
TABLE 4-2.
ESTIMATED DISTRIBUTION OF COMMERCIAL SOLVENT RECYCLERS
BY EPA REGION
EPA Region
Estimated Number
of Plants
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
11
16
11
26
67
17
14
6
27
210
17
-------
4.2 SOLVENT RECYCLING PROCESSES
The solvent recovery process involves the unit operations,
which include storage and handling, initial treatment,
distillation, and purification. These unit operations are shown
in Figure 4-1. Most commercial solvent recovery operations are
included under this process description. Methods employed in each
unit operation are described in this section (Scofield 1975;
Tierney 1978; EPA 1986a).
4.2.1 Solvent Storage Handling
Solvents are stored before and after recovery. For example,
private contractors reclaim solvents from a variety of industries,
such as paint manufacturers and degreasing operations. The
solvents are transported from the industrial site, in tank cars and
drums, to the reclaiming plant, where they are recovered and then
returned to the site or sold to another plant for reuse.
Solvents are stored in containers ranging in size from
55-gallon drums to tanks with capacities of 20,000 gallons or more.
Drummed solvents are segregated by solvent type. Storage tanks are
of fixed or floating roof design. Fixed-roof tanks are metal
cylinders or boxes of rigid construction. Venting systems are used
to prevent solvent vapors from creating excessive pressure inside
the tanks. Floating-roof tanks have movable tops that float on the
surface of the contained solvent and form air-tight, seals with the
tank walls.
4.2.2 Initial Treatment
Received spent solvents are initially treated by mechanical
separation to remove suspended solids and water,. Methods for
mechanical separation include decanting, filtering, draining,
settling, and centrifugation. Decanting also is used to separate
water from immiscible solvent.
4.2.3 Distillation
After initial treatment, waste solvents destined for reuse as
solvents are distilled to separate solvent mixtures and to remove
dissolved impurities. Spent solvents intended to be reused in fuel
blends are not distilled. Waste solvents are distilled by one of
the five methods listed below:
Simple batch distillation
Simple continuous distillation
Steam distillation
Batch rectification (fractional distillation)
Continuous rectification (fractional distillation).
18
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In simple batch distillation, a quantity of waste solvent is
charged to the evaporator. After charging, vapors are continuously
removed and condensed. The resulting still bottoms are removed
from the evaporator after solvent evaporation. Simple continuous
distillation is the same as batch distillation except that solvent
is continuously fed to the evaporator during distillation, and
still bottoms are continuously drawn off. Both batch and
continuous distillation equipment include the use of coils to
transfer heat required for evaporation. In steam distillation,
solvents are vaporized by direct contact with steam that is
injected into the evaporator. Batch, continuous, and steam
distillations are suitable for separating solvents from their
dissolved contaminants.
The separation of mixed solvents usually requires multiple
simple distillations or rectifications. In batch rectification,
solvent vapors pass through a fractionating column where they
contact condensed solvent (reflux) entering at the top of the
column. Solvent not returned as reflux is drawn off as overhead
product. In continuous rectification, the waste solvent feed
enters continuously at an intermediate point in the column. The
more volatile solvents are drawn off at the top of the column while
higher boiling point solvents are collected at the bottom.
Common distillation and rectification equipment is not
appropriate for the recovery of some spent solvents. For example,
resinous or viscous contaminants can coat heat transfer surfaces,
resulting in a loss of evaporator efficiency. Evaporators with
heating coils exposed to waste solvent are only suitable for
solvents with less than 5 percent solids content. Two evaporators
that prevent contaminants from fouling heating surfaces are of the
scraped surface or thin-film design. In the scraped-surface type,
rotating scrapers keep contaminants from adhering to the heated
evaporator walls. For heat sensitive or viscous materials, thin-
film evaporators are the most suitable. With this design, solvent
is forced into a thin film along the heated evaporator walls by
rotating blades. These blades agitate the solvent while
maintaining a small clearance from the evaporator walls to prevent
contaminant buildup on heating surfaces.
Azeotropic solvent mixtures, which are normally difficult to
separate, can be separated during distillation by adding a third
solvent component. For example, the addition of phenol to
cyclohexane-benzene mixtures during distillation causes the
activity coefficients for cyclohexane to be nearly twice as large
as those for benzene. This factor causes the volatility of
cyclohexane to be nearly twice that of benzene, allowing for easy
separation by distillation.
Condensation of solvent vapors during distillation is
accomplished by shell and tube or barometric condensers. The shell
and tube design consists of parallel tubes running through a
cylindrical shell. Condensation of solvent is accomplished by the
flow of cooling water through the tubes, which are in contact with
solvent vapors in the shell. This arrangement prevents the mixing
20
-------
of reclaimed solvent and cooling water. In barometric condensers,
vapor is condensed by direct contact with a spray of cooling water.
Condensation of vapor results in a mixture of solvent and cooling
water.
Solvents with high boiling points (155°C) are most effectively
distilled under vacuum. Vacuum distillation greatly reduces the
amount of heat that would otherwise be required by atmospheric
distillation.
4.2.4 Purification
After distillation, additional water is removed from solvent
by decanting or salting. Additional cooling of the solvent-water
mix before decanting increases the separation of the two components
by reducing their solubility. In salting, solvent is passed
through a calcium chloride bed where water is removed by
absorption.
During purification, some reclaimed solvents may lose
buffering capacity and require stabilization. Stabilization
requires the addition of buffers to ensure that pH is kept constant
during use. The composition of buffering additives is considered
proprietary by most companies.
4.3 SOLVENT USAGE AND SPENT SOLVENT GENERATION
The types of solvents in use by industry are indicative of the
types of solvents recovered at commercial facilities. Spent
solvents are the result of product synthesis, solubilizing of
active ingredients, surface cleaning, and equipment cleaning. In
processes that involve reactions, solvents are sometimes used to
dissolve reactants or products to keep the reaction single-phased
or to aid in the purification or drying of products. Spent solvent
wastes can be generated in subsequent product purification or
solvent recovery steps. In the paint, ink, and dye industries, for
example, solvents are used to dissolve active ingredients and to
aid in the application of the product. Solvent waste is usually
generated during both the production and application of surface
coatings. Surface cleaning includes both industrial degreasing of
metal products and repair work. Surface cleaning is practiced as
either cold degreasing, in which solvent is held below its boiling
point, or as vapor degreasing, in which solvent vapors are
condensed on the product surface. Solvents are used in virtually
every industry for equipment and process cleaning.
The use distribution of the 10 most widely used organic
solvents with respect to 5 major industry groups is shown in Table
4-3 (Pope-Reid 1986). The paint and allied products group
primarily uses nonhalogenated solvents, while the surface cleaning
group primarily uses halogenated solvents. Tetrachloroethylene is
the main solvent used by laundries and dry cleaners.
21
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NASR (1982) collected information from 25 of its members on
the kinds of solvents each recovers, the types of processes used,
and the types of industries served. Table 4-4 is a copy of the
NASR survey results. Nonhalogenated and petroleum solvents
constitute 73 percent of the spent solvents processed. The
remainder is composed of halogenated compounds 26 percent, and
"others" 1 percent. The recovery processes employed typically
reclaim 74 percent of the spent solvents for reuse. A wide range
of industries is served and spent solvent storage time averages 17
days. Two-thirds of the facilities employ distillation. About 80
percent of recycled solvents are returned to the generator and the
remaining 20 percent are sold on the open market.
The cost recycling spent solvent is affected by many factors.
In some instances, a spent solvent with a high heat content is sold
for reuse in fuel blends. Thus a spent solvent generator is paid,
or credited, for the spent solvents. The cost also depends upon
the origin of the spent solvent. For example, halogenated solvents
used in degreasing cost almost three times as much to recycle as
do halogenated solvents which were used for electronic components
cleaning. Table 4-5 shows ranges of costs for recycling spent
solvents for the years 1981 through 1985. The ranges of costs and
volumes received are based on data collected by EPA for eight
solvent recyclers (USEPA 1986d). Historically, prices of recycled
solvents remained stable until 1983, when they rose sharply. The
price ranges in the 1984-1985 period then leveled off to a cost of
$3.0 per gallon for solvents recycled for reuse as solvents. Spent
solvents sold for use in fuel blends netted a credit of $0.25 per
gallon.
4.4 INDUSTRY SUBCATEGORIZATION
The primary purpose of industry subcategorization is to
establish groupings within the solvent recycling industry such that
each has a uniform set of effluent limitations. This requires that
the elements of each group be capable of using similar treatment
technologies to achieve effluent limitations. Thus, the same
wastewater treatment and control technology is applicable within
a subcategory and a uniform treated effluent results from the
application of a specific treatment and control technology.
Sufficient information on the aspects listed above is not
presently available for the purpose of subcategorizing the solvent
recycling industry. However, product type and manufacturing
process are potential bases for future subcategorization. Product
types could be delineated as halogenated or nonhalogenated
solvents, since the level of halogenated compounds in wastestreams
could affect ultimate disposal. For example, high halogen content
inputs to incinerators are not desirable. The manufacturing
process aspect could be characterized by the use or lack of use of
distillation equipment. Solvents reclaimed for reuse in fuel
blends would only use initial treatment. Solvents distilled for
reuse as solvents could require the use of steam in flash
23
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TABLE 4-5.
SOLVENT VOLUMES RECEIVED AND PRICE RANGES
RECORDED BY 8 FIRMS
Year
1980
1981
1982
1983
1984
1985
Volumes
Received
(million gallons)
24.3
N/A
39.0
63.9
17.6
33.1
Price
Range
($/gallon)
0.19-0.80
0.25-1.00
0.25-1.00
0.14-1.30
(0.06)-3.00*
(0.25)-3.00*
* Figures in parentheses refer to a credit.
Source: USEPA, 1986d
25
-------
distillation, or the use of fractional distillation, in addition
to initial treatment. At this time, however, data are insufficient
to support these potential subcategories.
4.5 POTENTIAL FOR INDUSTRY GROWTH
No significant growth is projected for this industry based on
findings by the National Association of Solvent Recyclers (NASR)
and EPA. In 1982, 19 of 25 NASR survey respondees anticipated
facility expansions through 1985. Additional facilities were
planned for Colorado, Florida, Massachusetts, Oklahoma, Texas, and
Utah. Since,that time, prices for petroleum solvents products have
generally fallen and production levels for many solvents have not
risen. In 1986, plant personnel at a site visited by the Agency
stated that business was off because of the depressed economic
conditions in oil-producing states.
In 1986, the Agency promulgated regulations to control land
disposal of solvent wastes (EPA 1986b). An analysis was conducted
to demonstrate the effect of the regulation on the commercial
solvent recyclers and other industries that recover solvents. The
analysis showed that the regulation would not create the need for
additional plant capacity.
4.6 FINANCIAL CHARACTERISTICS OF COMMERCIAL FACILITIES
EPA collected financial data for a group of companies that
operate commercial hazardous waste treatment and disposal
facilities. A subgroup of firms that operate solvent recycling
facilities were identified. The subgroup consists of firms owning
a total of 114 facilities, of which: 17 are owned by publicly-held
firms, 90 by privately-held firms, 4 by bankrupt firms, and 3 have
discontinued operations. This section presents data on the public
and private firms. Many of the firms operating commercial solvent
recycling facilities are involved in other activities and so their
net income, cash flow, and total assets may not be representative
of solvent recovery, per se. Nevertheless, this is the best data
available at this time.
Privately-held firms are more prevalent than publicly-held
firms as shown in Table 4-6. For the two groups of firms two
financial ratios are presented; net income compared to total
assets, and cash flow compared to total assets. Cash flow includes
depreciation (a non-cash, accounting expense), and so is greater
than net income. In terms of the average ratio of net income to
total assets, the values are 8 percent and 7 percent for public and
private firms, respectively. However, the estimate has a wide
dispersion; hence the two values do not differ statistically to a
significant level. In terms of the second ratio, cash flow to
total assets, the values are 15 percent and 13 percent for public
and private firms, respectively. These two values also are not
statistically different. Overall, public firms do not perform
differently from private firms as measured by these two financial
ratios.
26
-------
TABLE 4-6. FINANCIAL RATIOS FOR THE SOLVENT RECYCLING INDUSTRY
Public Firms
Private Firms
Net Income to Total Assets for Firms
Owning Commercial Facilities
Number Minimum Maximum Average Standard
of Firms Ratio (%) Ratio (%) Ratio (%) Deviation
6
78
2.0
-6.0
15.0
38.0
8.0
7.0
5.0
5.3
Cash Flow to Total Assets for Firms
Owning Commercial Facilities
Number Minimum Maximum Average Standard
of Firms Ratio (%) Ratio (%) Ratio (%) Deviation
Public Firms
Private Firms
6
65
6.0
4.0
22.0
41.0
15.0
13.0
5.0
9.7
27
-------
4.7 SUMMARY
The following list summarizes the major points discussed in
this section:
Spent solvents are recycled for reuse in fuel blends or
as solvents at approximately 210 facilities located
throughout the Nation. The U.S. EPA Region with the
largest number of reconditioners is Region V, with 32
percent of the Nation's facilities. California,
Illinois, and Ohio are the states with the largest
numbers of reconditioners.
Solvent recyclers are generally registered under SIC code
2869 - Industrial Organic Chemicals, Not Elsewhere
Classified. Spent solvent types include nonhalogenated
(75 percent) and halogenated (25 percent).
The average solvent recycler handles 0.8 million gallons
of spent solvents annually. Process wastewater
discharges average 400 gallons per day and result
primarily from the physical separation of water from
spent solvents.
The status of the industry's process wastewater
discharges is estimated as follows:
Discharge Status
Direct discharge
Indirect discharge
Zero discharge
TOTAL
Estimated Number
of Facilities
10
30
170
210
The status of the industry's cooling water discharges is
estimated as follows:
Discharge Status
Direct discharge
Indirect discharge
Zero discharge
TOTAL
Estimated Number
of Facilities
36
107
67
210
The industry is not expected to grow or decline
significantly. Hence, the waste quantities estimated in
this report are reasonable projections of future waste
quantities.
28
-------
5. WATER USES AND WASTEWATER CHARACTERIZATION
The purpose of the section is to describe sources, volumes,
and characteristics of wastewaters generated by solvent recovery
processes. This chapter also presents a discussion of analytical
methodology and factors affecting the recovery of pollutants and
their quantification.
5.1 POLLUTANT ANALYSIS, RECOVERY, AND QUANTIFICATION
In order to interpret analytical data fully, quality
assurance/quality control (QA/QC) information must first be
evaluated. This is especially true for the analysis of organic
pollutants. Of particular concern in organics analysis is percent
recovery. For example, if 100 ^g/1 of a compound is reported but
the percent recovery is 50 percent, the real concentration could
be 200 Mg/1- Conversely, if the recovery is 1,000 percent, the
real concentration could be 10 ng/1. Expected recoveries for
organic compounds using Contract Laboratory Protocols (CLP) are 60
to 150 percent, and for pesticides the recovery is 60 to 200
percent. The percent recovery for a compound becomes increasingly
important when concentrations are low (i.e., near their detection
limits).
The detection limits for the various organics in the U.S.
Environmental Protection Agency, Industrial Technology Division
(EPA-ITD) industry sampling effort ranged from 10 to 5,000 ng/1,
depending on the compound and the sample. Several reasons for this
wide range include:
A sample extract containing a large concentration of
organics can overload the GC/MS. Consequently, the
full-strength extract cannot be analyzed, making
dilutions necessary and resulting in high detection
limits.
Some detection limits are high, even in "clean water."
For example, the detection limit for organics in reagent
water ranges from 10 /xg/1 to 250 jug/1.
High concentrations of a few compounds can overshadow
other results, in this case, it may be necessary to use
large dilutions to quantify the compounds present in high
concentrations, thereby diluting those found in low
concentrations. When the full-strength extract is rerun
to detect and quantify the low concentration compounds,
the high concentration compounds mask their presence.
Some polar compounds (such as organic acids) are readily
soluble in water, and are hard to separate and analyze
29
-------
with a GC. Furthermore, some polar compounds do not
extract well during the extraction procedure.
t
Variability inherent in the methods used to analyze
conventional and nonconventional pollutants also must be evaluated
in order to interpret analytical data. For example, EPA-ITD
analytical results for BODS are only accurate to + 30 percent within
a 95 percent degree of confidence. Consequently, dissolved BOD5,
a fraction of total BOD5, can be reported within method accuracy
limits, to be 60 percent greater than total BOD. A similar
circumstance exists for ammonia, which is a fraction of total
Kjeldahl nitrogen. The levels of precision and accuracy reported
by EPA-ITD are for analyses conducted on natural water samples, not
the complex matrices found in samples collected during this study.
Furthermore, precision and accuracy data are not available for
parameters such as COD and solids.
Such analytical problems were experienced by the laboratories
used during the 1986-87 sampling programs. This resulted in
pollutants not being found in samples, when high concentrations of
these pollutants had been found in similar wastewaters in other
samples. Future ITD sampling analysis efforts will be designed to
correct these problems.
5.2 WATER USAGE
Since separation of water from spent solvents is a goal of
solvent recovery, little water is used in. any processing step.
Flash distillation is the only process that requires the use of
water in a contact mode. In this process, steam is injected into
a distillation unit.
The National Association of Solvent Recyclers (NASR) (1982)
reports the use of vacuum stills that may be sources of process
wastewater. However, information on vacuum distillation was not
available to the Agency during its visits to 10 facilities and only
one NASR survey respondent reported its use.
Cooling is the only other significant process use of water.
Cooling water is used to cool pumps and to condense solvent vapors
through the use of condensers. The volume of cooling water used
varies greatly from plant to plant.
5.3 WASTEWATER SOURCES
Wastewater generated by solvent recovery processes is the
result of initial treatment, distillation, and purification
processes. The Agency estimates that the volume of process
wastewater generated by these collective processes can range from
less than 1 percent to as much as 15 percent of the total volume
30
-------
of spent solvents. The individual process wastestreams total only
several hundred gallons daily at any facility. Therefore, process
wastestreams are seldom segregated for individual treatment.
However, noncontact cooling water is generally segregated from
process wastewater. The discussions below on process wastewater
and cooling water demonstrate that each contains significant levels
of contaminants.
5.3.1 Process; Wastewater
Solvent recovery process wastewater is composed of water that
has been separated from spent solvents, distilled solvents, and
still bottoms. Cone bottomed tanks, which provide gravity
separation, and fractional distillation units are the main sources
of wastewater.
Cone bottomed tanks, where gravity separation occurs, are
commonly used to store received spent solvents and still bottoms.
Since water is denser than most organic solvents, it is drained off
the bottom of the tanks, along with solids. Salts that are soluble
in water, but not the organic solvents, are sometimes added to
increase the density of water relative to the organic solvent.
Cone bottomed tanks are the primary source of process wastewater,
since they are used for initial treatment of spent solvents, for
treatment of still bottoms, and sometimes in the product
purification stage.
Fractional distillation units are a secondary source of
process wastewater. About 60 percent of the NASR survey
respondents use this process, which is used to separate mixed
solvents. The separation process results in an aqueous discharge.
Fractional distillation is sometimes used as a purification step
in the solvent recovery process.
The average solvent recovery facility discharges 400 gallons
of process wastewater per day. The estimate is based on data from
ten solvent reclaimers with flows that range from 1 to 2,500
gallons per day (SAIC 1987a).
Data are available that can be used to quantitatively
characterize solvent recovery process wastewater. Raw process
wastewater has been analyzed at three facilities as a result of an
EPA-Office of Research and Development (EPA-ORD) study and the
current EPA-ITD study. One facility indirectly discharges process
wastewater generated during the recovery of nonhalogenated,
paint-related solvents. A second facility uses steam stripping to
treat wastewater resulting from the recycling of halogenated and
nonhalogenated solvents. The third facility recycles mixed
solvents and contract hauls aqueous residuals. Descriptions and
analytical results are discussed below for each of the facilities
identified herein as Plants, A, B, and C.
Plant A
31
-------
Plant A recovers 300,000 gallons per year of nonhalogenated
paint-related solvents that were generated by the equipment
manufacturing industry. These spent solvents are recovered without
the benefit of initial treatment in either a flash still or a
thin-film evaporator. No wastewater results from Plant A's
processing of nonhalogenated solvents.
Plant A generates wastewater from the recovery of 100,000
gallons per year of halogenated solvents used by electronics and
medical technologies manufacturers. After flash distillation, the
solvent-water mixture is allowed to settle in a cone bottom tank.
Water is drawn off the tank bottom, held in a storage tank, and
periodically bled into the facility cooling tower. Slowdown from
the cooling tower is discharged to a publicly-owned treatment work
(POTW) along with sanitary and other nonprocess wastewater. The
total discharge averages 315 gallons per day, of which 75 gallons
are estimated to be process wastewater.
EPA-ORD sampled process wastewater from the flash still during
two separate product runs in 1986 (Alliance 1986). This work was
conducted to establish pollutant mass balances in support of air
emissions regulations development. Plant personnel believe that
the results of the first run are not representative of typical
process wastewater characteristics, since:
(1) the ambient sampling temperatures were in excess of 100°F and
approached the boiling point of the waste feed's main component,
methylene chloride; and (2) plant personnel learned later that the
waste feed was actually a still bottom generated elsewhere; hence,
they no longer accept this waste. In the first run, the following
parameters were reported in the wastewater: methylene chloride at
7,500 mg/1; 1,1,2-trichloro-l,2,2-trifluoroethane at 1,100 mg/1;
and isopropanol at 68,000 mg/1. The second run was more typical
and consisted of a 1,1,1-trichloroethane spent solvent. The
resultant wastewater contained 9,400 mg/1 of 1,1,1-trichloroethane.
Analytical detection limits for the respective runs were on the
order of 200 mg/1 and no other organic parameters were reported to
have been detected.
EPA-ITD sampled the process wastestream in 1986 as part of the
current study. The process wastewater had been collected over a
1-week period in a storage tank prior to its discharge to a cooling
tower. The sampled wastewater reflects the recovery of
fluorocarbons, methylene chloride, and 1,1,1-trichloroethane.
Plant B
Plant B recovers spent solvents for reuse in fuel blends and
for batch toll customers. Halogenated and nonhalogenated solvents
are recovered in stills for reuse as solvents. The wastewater
generated by these operations is small compared to the amount
generated as a result of fuel blending operations. Received spent
32
-------
solvents are initially treated by gravity separation and the
combined plant process wastewaters are stored for a week prior to
treatment. Oil/water separation and steam stripping is provided
prior to the discharge of 260 gallons per day.
EPA-ORD sampled process wastewater discharged from the steam
stripper (GCA 1986). During the test period, 1,1,1-trichloroethane
was being processed. The only organic compound observed in the
stripper effluent was 1,1,1-trichloroethane at 55,000 mg/1. No
other organics were found; however, analytical method detection
limits were on the order of 200 mg/1.
EPA-ITD, in 1987, obtained a sample of the process wastewater
influent to the steam stripper. Plant personnel described the raw
waste as a typical wastewater. An effluent sample also was
obtained for the purpose of evaluating treatment effectiveness, a
topic that is addressed in Section 6 of this report.
Plant C
Plant C recovers spent solvents, received in drums combining
60 percent norihalogenated, 30 percent halogenated, and 10 percent
miscellaneous solvents. Spent solvents also are received in
tankers; however, no process wastewater is associated with the
wastes. A wide range of industries are served and fuel blends are
the primary destination of recovered products. The plant also
recovers solvents on a batch toll basis and for the open market.
Phase separations are accomplished by batch distillation,
fractional distillation, and thin film evaporations. Process
wastewater is comingled, stored, and shipped off-site for treatment
and disposal if the specifications of the contract hauler are met.
The wastewater volume averages 800 gallons per day.
EPA-ITD obtained a sample of process wastewater in 1987. The
sample was obtained from a tank that held all process wastewater
collected over the previous 2 weeks. The tank contained a
flammable solvent layer (top), a solvent/water layer (middle), and
a chlorinated solvent layer (bottom), and a representative sample
of the contents of the entire tank was obtained. Plant personnel
described the tank contents as not meeting the specifications of
the contract hauler; therefore, the wastestream would be treated
by fractional distillation. An effluent sample from the still was
not available.
EPA-ITD Data
Samples collected by EPA-ITD are the best available for
characterizing raw wastewater generated by solvent recovery
processes. Process wastewaters were sampled at three different
facilities in order to represent adequately the diversity of waste
types. Plant A process wastewater was generated by the flash
distillation of halogenated solvents used by the electronics
33
-------
industry. Plant B process wastewater was primarily the result of
initial treatment processes employed to treat mixed solvents
destined for reuse in fuel blends. Plant C process wastewater is
the result of initial treatment processes applied to nonhalogenated
and halogenated solvents.
Samples collected from the three facilities were analyzed for
conventional, nonconventional, and priority pollutants, as well as
compounds on the ITD list of analytes. The discussion below
focuses on the analytical fractions reported for all of the
untreated, raw wastewater samples collected by ITD. The fractions
are: (1) conventional and nonconventional, (2) metals, (3)
extractable and volatile organics, and (4) pesticides/herbicides.
A total of three raw wastewater samples was taken at the
facilities. Two methods were used to determine mean concentrations
for individual pollutants. The first method reflects the
concentration of the pollutant when it is present in a sample and
the calculation does not include the use of zero, or not detected,
values. The second method reflects an industry average level and
the calculation includes the use of zero, or not detected, values.
Conventional and Nonconventional Parameters. Raw
wastewaters exhibited a pH range of 3.6 to 9.5 and a
similarly wide range for most of the parameters shown in
Table 5-1. For example, oil and grease levels ranged
from 205 to 97,000 mg/1, with an average of 34,400 mg/1.
Similarly, TOG ranged from 540 to 300,000 mg/1, with an
average of 111,000 mg/1. Consistently high
concentrations are shown for BOD and COD. The mean total
BOD5 is 76,300 mg/1 and the mean total COD is 145,000
mg/1.
Metals. The data in Table 5-2 show high levels for
numerous metals in the raw wastewater samples. Eight of
the 27 metals were detected at average levels above 10
mg/1. These are aluminum, boron, calcium, iron, lead,
magnesium, sodium, and zinc. In addition to the quanti-
tative analyses, qualitative analyses were run to
determine the presence of 41 additional elements. The
other elements detected are shown in Table 5-3.
Extractable and Volatile Organics. The data in Table 5-4
show that 43 organic compounds were detected in the
wastewater samples. The compounds found at each of the
three facilities sampled are 1,1,1-trichloroethane,
acetone, methylene chloride, and trichloroethene.
Compounds found at two of the three facilities are
2-butanone(MEK), ethylbenzene, isophorone, n-decane>
p-dioxane, and toluene. The industry mean concentrations
exceed 10 mg/1 for 40 parameters and exceed 100 mg/1 for
24 parameters. The total sum of toxic organics is the
sum of all means and is equal to 23,000 mg/1.
34
-------
TABLE 5-1. EPA-ITD SAMPLING PROGRAM
COMPARISON OF PROCESS WASTEWATER
Fraction: ConventionaUs and Nonconventionals
Sample Point: Raw Uastewater
Plant No.
Episode No.
Sample No.
Sample Date
Flow, Gallons per Day
A
1134
15367
Sep 19, 1986
75
B
1180
15727
Mar 20, 1987
260
C
1181
15731
Mar 31, 1987
800
Mean
Parameter
Urn ts
Ammonia
BODJf Total
BODj, Dissolved
Chloride
COD, Dissolved
COD, Total
Dissolved Solids
Fluoride
Oi 1 & Grease
Phenol
Suspended Solids
Suspended Vol Solids
TKN
Total Cyanide
Total Organic Carbon
Total Vol Solids
PH
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
NR
30000
18600
1500
71400
82100
1600C
120
97000
4
160
116
154
.76
540
4140
9.5
30.1
153000
138000
2830
150000
218000
156000
8.6
205
17
464
338
1060
3.5
300000'
8319
7.6
144
46000
39000
12800
108000
134000
34600
1.4
6100
175
4170
1900
279
7
32000
20663
3.6
87
76300
65200
5710
110000
145000
68900
43
34400
65
1600
785
498
4
111000
11000
-
Note: NR indicates no data reported
mg/l = milligrams per liter
Mean = mean of detectd values.
For example, mean ammonia = (30.1
144)/2=87
35
-------
TABLE 5-2. EPA-ITD SAMPLING PROGRAM
COMPARISON OF PROCESS WASTEWATER
Fraction: Metals
Sample Point:
Plant No.
Episode No.
Sample No.
Sample Date:
Flow, Gallons
Parameter
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Sodium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Raw Wastewater
per Day
Mg/i
Mg/i
Mg/1
fj.g/1
jitg/1
Mg/i
Atg/1
/Ltg/1
Mg/i
/Ltg/1
Mg/i
Mg/l
Mg/1
Mg/i
jitg/l
Mg/i
Mg/i
Mg/i
Atg/1
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
A
1134
15367
Sep 19,
1986
75
Units
280
117
9
55
ND-1
710
56
49000
17
29
790
6600
450
7500
170
3
57
430
50
ND-1
880000
ND-10
730
50
ND-2
ND-10
4800
B
1180
15727
C
1181
15731
Mean
Mar 20, Mar 31,
1987
260
2120
447
30
700
ND-5
26000
79
59400
3820
2050
1220
7220
3210
619
619
20
1040
656
166
13
5740000
ND-10
686
50
50
50
8900
1987
800
31800
1290
176
1290
85
14200
6010
6020000
6500
1620
13300
516000
46200
51600
13500
22
496
22100
25
29
1310000
ND-10
1110
50
147
50
261000
11400
618
72
682
85
13600
2050
2040000
3450
1230
5100
177000
16600
19900
4760
15
531
7730
80
21
2640000
ND
842
50
99
50
91600
Note: ND = Not detected above detection limit. Detection limit
shown.
Mg/1 = micrograms per liter
Mean = Mean of detected values. Neither ND values nor
zero are used in the calculation. For example, mean
silver = (13 + 29)/2=21
36
-------
TABLE 5-3.
EPA-ITD SAMPLING PROGRAM COMPARISON
OF PROCESS WASTEWATER
"raction: Superscan Metals
sample Point: Raw Wastewater
>lant No.
Ipisode No.
ample No.
ample Date
A
1134
15367
Sep 19, 1986
B
1180
15727
Mar 20, 1987
C
1181
15731
Mar 31, 1987
arameter
iismuth
:erium
lysprosium
Irbium
luropium
ladolinium
lallium
lermanium
(old
iafnium
olminum
ndium
odine
ridium
ranthanum
pithium
utetium
eodymium
iobium
ismium
'alladium
'hosphorus
'latinum
'otassium
'raseudymium
ihenium
Rhodium
Luthenium
iamarium
icandium
iilicon
itrontium
lulfur
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Detected
Detected
ND
ND
ND
ND
ND
ND
ND
Detected
ND
Detected
ND
ND
ND
ND
ND
ND
Detected
Detected
Detected
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Detected
Detected
ND
Detected
ND
ND
Nt>
ND
ND
Detected
ND
Detected
ND
ND
ND
ND
ND
ND
Detected
Detected
Detected
ND
Detected
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Detected
Detected
Detected
Detected
Detected
Detected
ND
ND
Detected
Detected
Detected
ND
ND
ND
ND
ND
ND
Detected
Detected
Detected
37
-------
TABLE 5-3. EPA-ITD SAMPLING PROGRAM COMPARISON
OF PROCESS WASTEWATER (Continued)
Fraction: Superscan Metals
Sample Point: Raw Wastewater
Plant No.
Episode No.
Sample No.
Sample Date
A
1134
15367
Sep 19, 1986
B
1180
15727
Mar 20, 1987
C
1181
15731
iMar 31, 1987
Parameter
Tantalum
Tellurium
Terbium
Thorium
Thulium
Tungston
Uranium
Ytterbium
Zirconium
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Detected
Detected
ND
ND
Note: ND indicates not detected
38
-------
TABLE 5-4. EPA-ITD SAMPLING PROGRAM
COMPARISON OF PROCESS WASTEWATER
Fraction: Extractable and Volatile Organics
Sample Point: Raw Wastewater
Plant No.
Episode No.
Sample No.
Sample Date
Flow, Gallons per Day
Parameter
1,1,1, -Trichloroethane
1,2, 4-Trichlorobenzene
1,2-Dichlorobenzerie
1, 2-Diphenylhydrazine
1, 3-Dichlorobenzerie
1 , 4-Dichlorobenzerie
2 , 4-Dimethylphenol
2-Butanone (MEK)
2-Chlorophenol
2 -Methyl naphtha 1 ene
4-Methyl-2-Pentanone
Acetone
Alpha-Terpineol
Benzene
Biphenyl
Bis ( 2 -Ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chloroform
Di-N-Butyl Phthalate
Di-N-Octyl Phthalate
Ethylbenzene
Fluoranthene
Fluorene
Isobutyl Alcohol
Isophorone
Longifolene
Methylene Chloride
N , N-Dimethy 1 f ormamide
N-Decane (N-C10)
N-Eicosane (N-C20)
N-Hexadecane (N-C16)
N-Tetradecane (N-C14)
Naphthalene
O-Cresol
P-Cresol
P-Dioxane
Units
Mg/i
Mg/i
Mg/i
MCr/1
LtCT /I
Mg/l
MO"/ 1
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
jLtg/l
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
Mg/i
A
1134
15367
Sep 19,
1986
75
209830
ND-100
ND-100
ND-200
ND-100
ND-100
ND-100
5247JL
ND-100
ND-10
ND-50
549680
ND-100
ND-100
ND-100
ND-100
ND-100
ND-100
ND-100
ND-100
2191
ND-100
ND-100
ND-10
ND-100
833
663040
ND-10
927
ND-100
ND-100
ND-100
ND-100
ND-10
ND-10
ND-100
B
1180
1-5727
Mar 20,
1987
260
3524
ND-10000
ND-10000
ND-20000
ND-10000
ND-10000
ND-10000
ND-50
ND-10000
ND-10000
ND-10
18154300
47727
16
ND-10000
ND-10000
ND-10000
ND-10
ND-10000
ND-10000
688
ND-10000
ND-10000
ND-10
12715
ND-10000
1540990
ND-1000
ND-10000
ND-10000
ND-10000
ND-10000
ND-10000
ND-10000
ND-10000
1120390
c
1181
15731
Mar 31,
1987
800
33103
248019
3162420
238308
36534
76607
51341
1460400
44460
142508
5155390
1070390
ND-10000
ND-10000
29020
1138370
178183
40529
205853
259699
ND-10000
31580
20990
165184
230639
ND-10
296310
106559
454722
228717
574539
359062
345200
33069
48238
7187800
Mean
82200
248000
3160000
238000
36500
76600
51300
756000
44400
143000
516000
6590000
47700
16
29000
1140000
178000
40500
206000
260000
1440
31600
21000
165000
122000
833
833000
107000
228000
229000
575000
359000
345000
33000
48200
4150000
39
-------
TABLE 5-4. EPA-ITD SAMPLING PROGRAM
COMPARISON OF PROCESS WASTEWATER
(Continued)
Fraction: Extractable and Volatile Organics
Sample Point: Raw Wastewater
Plant No.
Episode No.
Sample No.
Sample Date
Flow, Gallons per Day
A
1134
15367
Sep 19,
1986
75
B
1180
15721
Mar 20,
1987
260
c
1181
15731
Mar 31,
1987
800
Mean
Parameter
Units
Phenanthrene
Phenol
Pyrene
Styrene
Tetrachloroethene
Toluene
Trichloroethene
Mg/l
Mg/i
Aig/1
/Lig/1
/Ltg/1
Atg/1
Mg/i
ND-100
ND-100
ND-100
ND-100
1350350
555
8495
ND-10000
ND-10000
ND-10000
ND-10000
ND-10
ND-10
1278
46833
154046
10766
202054
ND-10000
43326
20474
46800
154000
10800
202000
1350000
21900
10100
Note: ND indicates not detected above detection limit. Detection
limit shown.
jzg/1 = micrograms per liter
Mean indicates mean of detected values. Calculation does not
include not detected or zero values. For .example, mean
toluene = (555 + 43326)/2=21900
40
-------
Pesticides/Herbicides. Wastewater at Plant A was
analyzed for 100 pesticide/herbicide compounds and none
were detected.
The EPA-ITD data for solvent recycling of raw wastewaters are
presented in this report as representative of the industry
wastestreams. The data represent halogenated and nonhalogenated
compounds recycled for use in fuel blends and recycled for reuse
as solvents. No other data are available that are representative
of wastewater that has been separated from spent solvents.
5.3.2 Cooling and Miscellaneous Wastewater
Noncontact cooling water is used in solvent recovery
operations to cool pumps and condensers. As such, no process
contact is usually associated with cooling water discharges from
cooling towers and once-through cooling. The volume of cooling
water depends on the degree to which distillation is used at a
particular facility. A plant that only provides initial treatment
for solvents destined for reuse in fuel blends would not require
cooling. On the other hand, a plant that distills spent solvents
for reuse would require cooling for condensing product vapors. The
Agency collected cooling water flow information from five plants
that showed a flow range of from 60 to 35,000 gallons per day and
an average of 11,000 gallons per day (SAIC 1987c).
EPA-ITD collected cooling water samples from two solvent
recovery facilities, identified here as Plants D and E. The Plant
D discharge consists of noncontact cooling water and steam
condensate (87 percent) pump cooling water (8 percent) and sanitary
wastewater (5 percent). Plant D recovers nonhalogenated solvents
(85 percent) and halogenated solvents (15 percent) with a thin-film
evaporator. The Plant D flow is 35,000 gallons per day. The Plant
E discharge consists of noncontact cooling water, boiler blowdown,
and a small amount of sanitary wastewater that totals 30,000
gallons per day.
Analytical data for the two facilities are summarized in Table
5-5 and include permit monitoring data from Plant D. BOD5, COD,
and TOC levels are very high for these noncontact cooling waters.
BOD5 averages 918 mg/1, COD is 3503 mg/1, and TOC is 113 mg/1.
Metals are present at fairly low levels with respect to process
wastewater except for iron. Eleven organics were detected at Plant
E, with acetone, benzene, methylene chloride,
1,1,2-trichloroethane, and 1,1,2,2-tetrachlorethane having mean
industry concentrations greater than 1 -mg/1. Four organics were
found in an EPA-ITD sample taken at Plant D and only one was
greater than 100 jug/1. Permit monitoring data supplied by Plant
D revealed eight organic compounds present in the discharge. The
total toxic organics in the three samples averaged 440 mg/1 per
sample.
41
-------
TABLE 5-5. EPA-ITD SAMPLING PROGRAM:
COOLING WATER AND COMINGLED NONPROCESS WASTEWATER
Fraction
Conventions Is
Hetals
Or games
Plant D
Permit
Parameterd) Monitoring
BOD-5, mg/l 2,
COO, mg/l 9,
TOC, mg/L
Total Suspended Solids, mg/l
Oil and Grease, mg/l
Cadmium
Chromium 5,
Iron 198,
Lead 2,
Mercury
Strontium
Zinc
Acetone
Benzene
Biphenyl
Chlorobenzene
Chloroethane
1,1-Dichloroethane
Trans- 1 , 2-D i ch loroethene
Diphenyl Ether
Ethylbenzene
Methylene Chloride
Naphthalene
Phenol
Thioxanthone
Toluene
Tri chloroethane
Tripropyleneglycol
methylether
1,1,1 -Trich loroethene
1 , 1 ,2-Trichloroethane
1,1,2, 2-Tetrach loroethane
Vinyl Chloride
Total Toxic Organics
240
680
ND
26
10
348
000
000
900
ND
ND
ND
ND
240
ND
215
17
12
9
ND
4
ND
ND
ND
ND
42
ND
ND
ND
ND
ND
17
556
Plant D
Sample
#15338
270
370
100
60
1.5
ND
6
8,100
5
ND
ND
120
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
27
ND
81
775
69
ND
ND
ND
952
Plant K
Sample
#15015
246
460
125
59
ND
8
ND
5,460
ND
6.1
150
33
415,110
26,130
85
ND
ND
ND
ND
223
ND
5,319
15
129
ND
438
352
ND
ND
2,090
2,090
ND
451,981
Mean
919
3,503
113
48
5.8
178
2,503
70,520
: 1,475
6.1
150
77
415,110
13,185
85
215
17
12
9
223
4
5,319
15
129
27
240
217
775
69
: 2,090
2,090
17
440,000
Note:
(1) Concentrations expressed in M9/l( unless otherwise noted.
mg/l = milligrams per liter
/tg/l = micrograms per liter
ND = not detected
Mean = Mean of detected values. Calculation does not include not detected or zero values.
For example, mean TOC = (100 + 125)/2=113.
42
-------
When compared to noncontact cooling water discharged in other
industries, the measured pollutant concentrations are significantly
higher. Noncontact cooling water should contain no detectable
toxic organics. Furthermore, the conventional pollutants BOD5,
COD, and TOG are observed to be at very high levels compared to
typical freshwater supplies. Effluent limitations guidelines for
the Petroleum Refining Point Source Category limit TOC in
noncontact cooling water to 5 mg/1. The data suggest that control
of noncontact cooling water may be necessary to minimize the
discharge of oxygen-demanding pollutants and toxic organics.
5.4 RESIDUALS DISPOSAL
Solvent recovery solid residuals include wastewater treatment
sludges, still bottoms, and incinerator ash. Since end-of-pipe
wastewater treatment technologies are not common in this industry,
little information is available to characterize wastewater
treatment sludges. No data are available to characterize ash
resulting from the burning of still bottoms and aqueous solvent
wastes in furnaces.
Information has been collected that can be used to
characterize still bottoms. NASR (1982) reports that 27 percent
of spent solvents distilled are not recovered. This residue, or
still bottoms, is composed of fats, oils, emulsions, organic
solvents, solids, and water. Still bottoms are typically blended
with fuels because of their high Btu value. Low levels of water
are usually acceptable in the fuel mixture. Unacceptable still
bottoms are incinerated on-site or contract handled. The Agency
is unaware of any solvent reclaimer that discharges still bottoms
directly or indirectly to the Nation's waters.
A solvent reclaimer, identified in this report as Plant F,
submitted data that show proportions of various chemical fractions
contained in two still bottoms samples. Still bottoms are
generated at Plant F by a thin-film evaporator. Spent solvent
types are limited to halogenated solvents used in machinery
degreasing and in the electronics industry. Table 5-6 shows the
result of the facility's in-house testing. The first sample is
composed mostly of organic compounds and water. About
three-quarters of the second sample is chlorinated and fluorinated
compounds.
EPA-ITD obtained a still bottom sample from Plant A for
analysis. The sample is the residual resulting from thin-film
evaporation of nonhalogenated (85 percent) and halogenated (15
percent) solvents. Table 5-7 shows conventional and
nonconventional pollutants in the sample. The very high concen-
trations of organics did not allow an accurate determination of
BOD, ammonia, TKN, dissolved COD, and some solids. The total COD
measured equaled 143 percent of the sample mass. Oil and grease
43
-------
TABLE 5-6. STILL BOTTOMS GENERATED AT PLANT F
Parameter
Weight by Percent (%)
Sample 1 Sample 2
Water
Oil
Alcohols
Hydrocarbons
Ketones
Chlorinated
Fluorinated
Resins and Solids
Specific Gravity
Layer 1
Layer 2
PH, S.U.
Flash Point, °F
40-50
10-15
4-8
3-5
2-3
25-30
10-15
3-6
1.04
1.14
7-9.0
130
2-6
15-20
5-8
2-4
2-5
35-45
25-35
1-4
1.10
'
8. 0-8 ..5
120
44
-------
TABLE 5-7. EPA-ITD SAMPLING PROGRAM STILL BOTTOMS
Fraction: Conventionals and Nonconventionals
Sample Point: Still Bottom
Plant No.
Episode No.
Sample No.
Sample Date
A
1129
15342
Jul 24, 1986
Parameter
Units
Chloride
COD, Total
Fluoride
Oil & Grease
Phenol
Total Cyanide
Total Vol Solids
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
3300
1430000
44100
188000
2.
94
280000
06
Note: mg/kg = milligrams per kilogram, wet basis.
45
-------
constituted 18.8 percent of the sample and total volatile solids
constituted 28 percent.
Metals are reported in mg/kg in Table 5-8 for the still
bottoms sample. Lead is the most significant compound and
constitutes over 5 percent of the sample. Aluminum, barium, and
zinc are the next most significant metals cind collectively
constitute 1 percent of the sample mass.
Thirteen extractable and volatile organic compounds were
measured in the 'still bottoms sample, as shown in Table 5-9. Each
compound was present in high concentrations and 2-butanone (MEK)
was highest at 7,562 mg/1. Acetone, ethylbenzene, and toluene had
concentrations of greater than 100 mg/1.
Dioxins and furans measured in the sample are shown in Table
5-10. Of the nine compounds measured, OCDF had the highest
concentration at 4,390 parts per trillion (ppt).
The still bottom sample was subjected to the Toxicity
Characteristic Leaching Procedure (TCLP). This procedure attempts
to identify compounds that could potentially leach from solid and
semi-solid matrices in the waste. Tables 5-11 and 5-12 show the
results of TCLP analyses for metals and extracta.ble and volatile
organics. Zinc is the only toxic metal measured at a significant
level. The three organic compounds identified in the TCLP extract
that were not identified by traditional methods are
alpha-terpineol, isophorone, and thioxanthone. Only 2-butanone
(MEK) was present at a concentration greater than 100 mg/1.
The still bottoms data discussed above indicate that high
levels of organics and metals are present in still bottoms. This
should be the case, since still bottoms are the solid and
nondistillable residue that remain after distillation. The
presence of dioxin and furan compounds was confirmed and levels are
significant.
5.5 SUMMARY
The following summarizes the major points that were discussed
in this section:
The average solvent recycler handles 0.8 million gallons
of spent solvents annually. Process wastewater
discharges average 400 gallons per day and result
primarily from the physical separation of water from
spent solvents.
Industry raw wastewater is characterized by very high
concentrations of conventional, nonconventional, metal,
and organic pollutants. The data shown below for
46
-------
TABLE 5-8. EPA-ITD SAMPLING PROGRAM STILL BOTTOMS
Fraction: Metals
Sample Point: Still Bottom
Plant No.
Episode No,
Sample No.
Sample Date
A
1129
15342
Jill 24, 1986
Parameter
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Sodium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Units
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
6560
117
6
4510
2
195
112
3530
1390
36
507
3400
55600
1060
55
6.5
1160
58
6
.3
1080
6
94
97
15
15
4650
Note: mg/kg = milligrams per kilogram, wet basis.
47
-------
TABLE 5-9. EPA-ITD SAMPLING PROGRAM STILL BOTTOMS
Fraction: Extractable and Volatile Organics
Sample Point: Still Bottom
Plant No.
Episode No.
Sample No.
Sample Date
A
1129
15342
Jul 24, 1986
Parameter
1, 1, 1-Trichloroethane
2-Butanone (MEK)
2-Chloronaphthalene
Acetone
Benzoic Acid
Chlorobenzene
Ethylbenzene
Methyl Methacrylate
Methylene Chloride
N-Decane (N-C10)
Phenol
Toluene
Trichloroethene
Units
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
15422
7561900
4927
110364
18520
602
298600
1379
10299
6560
1049
229730
5779
Note: mg/kg = milligrams per kilogram, wet basis,
48
-------
TABLE 5-10. EPA-ITD SAMPLING PROGRAM STILL BOTTOMS
Fraction: Dioxins/Furans
Sample Point: Still Bottom
Plant No.
Episode No.
Sample No.
Sample Date
A
1129
15342
Jul 24, 1986
Parameter
Units
1234678-HpCDF
1234789-HpCDF
12378-PCDD
123789-HxCDD
234678-HXCDF
2378-TCDD
OCDF
Total HxCDF
Total PCDD
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
ppt
259.87
491.98
16.08
9.39
58.47
28.10
4390.64
132.85
16.08
Note: ppt = parts per trillion, wet basis.
49
-------
TABLE 5-11. EPA-ITD SAMPLING PROGRAM
STILL BOTTOMS - TCLP ANALYSIS
Fraction: Metals
Sample Point: Still Bottom
Plant No.
Episode No.
Sample No.
Sample Date
A
1129
15342
Jul 24, 1986
Parameter
Units
Sodium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
/xg/1
Mg/1
jug/1
Mg/i
jLtg/l
/Lig/1
w/i
1640000 :
20
155
50
50
50
129000
Note:
= micrograms per liter > wet basis.
50
-------
TABLE 5-12. EPA-ITD SAMPLING PROGRAM
STILL BOTTOMS - TCLP ANALYSIS
Fraction: Extractable and Volatile Organics
Sample Point: Still Bottom
Plant No.
Episode No.
Sample No.
Sample Date
A
1129
15342
Jul 24, 1986
Parameter
Units
1,1,1-Trichloroethane
2-Butanone (MEK)
2-Chloronaphthalene
Alpha-Terpineol
Chlorobenzene
Ethylbenzene
Isophorone
Methylene Chloride
Thioxanthone
Toluene
Trichloroethene
jug/1
5560
13573300
4976
2658
60
10901
6082
3470
38212
63928
113
Note: Mg/1 = micrograms per liter, wet basis.
51
-------
selected parameters are representative of a typical
industry process wastewater:
Parameter
BODS
COD
Oil and Grease
TOG
Iron
Lead
Zinc
Acetone
Methylene Chloride
1,1,1-Trichloroethane
Trichloroethene
Total Toxic Organics
Concentration fmq/1)
76,300
145,000
34,400
111,000
177
17
92
6,590
833
82
10
23,000
Forty-three extractable and volatile organics were
detected in industry raw wastewaters. Of these, 40 have
industry mean concentrations that exceeded 10 mg/1, and
24 exceeded 100 mg/1.
Noncontact cooling water discharges average 11,000
gallons per day and contain significant levels of
pollutants. The data below show industry mean concen-
trations:
Parameter
BODS
COD
TOC
Total Toxic Organics
Concentration fmg/1)
919
3500
75
440
Still bottoms are highly concentrated mixtures of
solvents, oils, greases, and solids. Nine dioxin and
furan compounds were found in still bottoms samples. No
discharges of still bottoms to the Nation's waters are
known to occur routinely.
52
-------
6. CONTROL AND TREATMENT TECHNOLOGY
The purposje of this section is to describe the types of
control and treatment technologies used in the solvent recycling
industry. The pollutant removal effectiveness of these
technologies also is discussed. In addition, the control tech-
nology that allows most recyclers to achieve zero discharge of
process wastewater is discussed.
6.1 ZERO DISCHARGE METHODS
The solvent recovery industry does not employ any one
predominant technology to treat wastewater. In fact, few
facilities discharge process wastewater. The U.S. Environmental
Protection Agency (EPA) contacted recovery facilities by telephone
for the purpose of verifying discharge status. Of the 107
respondents theit generate wastewater, 81 percent reported zero
discharge of process wastewater. Zero discharge was achieved by
off-site disposal at 31 plants, by fuel blending or incineration
at 30 plants, by evaporation at 11 plants, by deep well injection
at 4 plants, and by landfilling at 2 facilities. Five respondents
reported that their solvent recovery operation generated no
wastewater and three return wastewater to the generator (SAIC
1987d).
6.2 IN-PLANT WASTEWATER CONTROL
Few opportunities exist for wastewater minimization in solvent
recovery processes. The volume of water contained in received
spent solvents is controlled at the site of the generator. An
incentive to minimize the water volume exists, since the recovery
cost of the generator is based on a per gallon charge. Flash
distillation is the only process in which water (steam) is added.
This distillation technology is not in common use and steam usage
is controlled by physical/chemical equilibria.
Facilities with fractional distillation units sometimes use
these systems to either recover solvents from dilute aqueous
solutions or to improve water quality prior to discharge. This
technology is employed primarily to recover products and is not
generally used as a wastewater treatment technology. The Agency
did not collect any samples to assess the performance of fractional
distillation. A facility that recovers halogenated solvents
reports that the solvent content of its wastewater is reduced from
5 to 0.5 percent by fractional distillation.
6.3 WASTEWATER TREATMENT
The Agency contacted solvent recycling facilities for the
purpose of determining what end-of-pipe treatment technologies are
in place (SAIC 1987a) . Of the 21 facilities that are known to
53
-------
discharge wastewater, 10 do not treat wastewater. Four facilities
circulate their wastewater through a cooling tower prior 'to
discharge. Three plants use steam stripping. One plant uses
carbon filtration, while another uses carbon after biological
treatment. Another facility uses a cooling tower followed by
chemical oxidation. The last plant uses an oil/water separator.
Only half of the known dischargers have any end-of-pipe treatment
in place and no single technology predominates.
EPA's Industrial Technology Division (EPA-ITD) made
presampling visits to three solvent recyclers in 1986 and 1987 that
had end-of-pipe treatment technology in-place. One plant used
steam stripping, but sampling points were not accessible. A second
plant was believed to use air stripping, but since this form of
treatment was being provided by a cooling tower that emitted
uncontrolled pollutants to the air, it was not sampled. The Agency
did obtain samples of steam stripper influent and effluent from
Plant B.
Steam stripper pollutant removals are calculcited and shown in
Tables 6-1, 6-2, and 6-3 for conventionals and nonconventionals,
metals, and extractable and volatile organics, respectively. Poor
removals observed for some constituents in the grab samples, such
as oil and grease and some volatile organics, can be attributed to
sampling technique. However, this is unlikely, since grab samples
were taken simultaneously at the influent and effluent sampling
points and the system had a short detention time of less than
3 minutes. Also, similarly poor removals were observed for
constituents in the remaining composite samples. In addition to
the data shown, only one dioxin/furan compound was detected. The
isomer OCDD was present in the treated effluent at 2.96 parts per
trillion (ppt).
6.4 BEST DEMONSTRATED AVAILABLE TECHNOLOGY
Five treatment technologies are demonstrated for wastewaters
containing F001-F005 spent solvents (EPA 1986a). These are carbon
adsorption, steam stripping, biological treatment, wet air
oxidation, and air stripping. Incineration and fuel substitution
were not demonstrated for wastewaters containing F001-F005 spent
solvents. The demonstrated technologies formed the basis for
development of Best Demonstrated Available Technology (BOAT) treat-
ment standards for solvent-bearing wastewater destined for land
disposal.
The data base from which the BOAT standards were developed is
composed of treatment performance data for the demonstrated
technologies. These data were abstracted from the Organic
Chemicals, Plastics, and Synthetic Fibers (OCPSF) Industries Data
Base; the Pharmaceuticals Industry Data Base; eind the Iron and
Steel Manufacturing Data Base. In addition, the Agency collected
data and information from numerous bench-, pilot-, and full-scale
studies.
54
-------
TABLE 6-1. EPA-ITD SAMPLING PROGRAM
STEAM STRIPPING PERFORMANCE
Fraction: Convent.ionals and Nonconventionals
Sample Point:
Plant No.
Episode No.
Sample No.
Sample Date
Raw Wastewater Treated Effluent
Mar
B
1180
15727
20, 1987
B
1180
15728
Mar 20, 1987
Percent
Removed
Parameter Units
Ammonia
BOD-5, Total
BOD-5 , Dissolved
Chloride
COD, Dissolved
COD, Total
Dissolved Solids
Fluoride
Oil & Grease
Phenol
Sulfide
Suspended Solids
Suspended Vol Solids
TKN
Total Cyanide
Total Organic Carbon
Total Vol Solids
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
30.1
153000
138000
2830
150000
218000
156000
8.6
205
17
.448
464
338
1060
3.5
300000
8319
22.1
105000
84000
2660
155000
247000
148000
6
3050
18.8
.744
276
200
1080
2
270000
5228
27
31
39
6
0
0
5
30
0
0
0
41
41
0
43
10
37
Note: mg/1 = milligrams per liter
55
-------
TABLE 6-2. EPA-ITD SAMPLING PROGRAM
STEAM STRIPPING PERFORMANCE
Fraction: Metals
Sample Point:
Raw Wastewater Treated Effluent
Plant No.
Episode No.
Sample No.
Sample Date
B
1180
15727
Mar 20, 1987
B
1180
15728
Mar 20, 1987
Percent
Removed
Parameter
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Sodium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
2120
447
30
700
5
26000
79
59400
3820
2050
1220
7220
3210
619
619
20
1040
656
166
13
5740000
10
686
50
50
50
8900
1200
384
10
726
5
23400
60
54100
3210
1850
731
5020
2270
26900
547
20
921
592
136
5
3240000
10
568
50
50
50
7270
43
14
67
0
0
10
24
9"
16
10
40
30
29
0
12
0
11
io
18
62
44
0
17
0
0
0
18
Note: All concentrations expressed in /Ltg/l(micrograms per liter)
56
-------
TABLE 6-3. EPA-ITD SAMPLING PROGRAM
STEAM STRIPPING PERFORMANCE
Fraction: Extractable and Volatile Organics
Sample Point:
Raw Wastewater Treated Effluent
Plant No.
Episode No.
Sample No
Sample Date
B B
1180 1180
15727 15728
Mar 20, 1987 Mar 20, 1987
Percent
Removed
Parameter
1,1, 1-Trichloroethane
2-Butanone (MEK)
4 -Methyl - 2 -Pent anone
Acetone
Allyl Alcohol
Alpha-Terpineol
'Benzene
Ethylbenzene
Isophorone
Methylene Chloride
P-Dioxane
Trichloroethene
3524
ND
ND
18154300
ND
47727
16
688
12715
1540990
1120390
1278
ND
1586260
131
15477800
36
ND
47
ND
ND
186702
767180
1264
99
0
0
15
0
99
0
99
99
88
32
1
Note: ND indicates value not detected above detection limit
All concentrations expressed in /xg/1 (micrograms per liter)
57
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The treatment standards imposed by the land disposal
regulations are shown in Table 6-4. These standards apply to
aqueous solutions as well as to Toxicity Characteristic Leaching
Procedure (TCLP) extracts from solids. The standards address all
of the 10 mostly widely used solvents shown in Table 4-3. These
are xylene, methanol, toluene, methylene chloride, methyl ethyl
ketone, tetrachloroethylene, trichloroethylene ,1,1,1-trichloro-
ethane, acetone, and methyl isobutyl ketone.
6.5 SUMMARY
The following summarizes the major points that were discussed
in this section:
Zero discharge of process wastewater is achieved by 81
percent of the industry. Contract hauling, fuel blending
and incineration are the primary zero discharge
technologies.
Only half of the discharging facilities treat their
process wastewater prior to discharge. No single
treatment technology prevails among dischargers.
58
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TABLE 6-4. BOAT TREATMENT STANDARDS
(AS CONCENTRATIONS IN THE TREATMENT RESIDUAL EXTRACT)
Wastewaters Nonwastewater
Containing Spent Solvent
Spent Solvents Wastes
Constituent (mg/1) (mg/1)
Acetone
n-Butyl alcohol
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Cresols (cresylic acid)
Cyclohexanone
1, 2-dichlorobenzene
Ethyl acetate
Ethylbenzene
Ethyl ether
Isobutanol
Methanol
Methylene chloride
Methylene chloride generated
at Pharmaceuticals plants
0.05
5.0
1.05
0.05
0.15
2.82
0,
0,
125
65
0.05
0.05
0.05
5.0
0.25
0.20
12.7
0.59
5.0
4.81
0.96
0.05
0.75
0.75
0.125
0.75
0.053
0.75
5.0
0.75
0.96
0.96
Methyl ethyl ketone
Methyl isobutyl ketone
Nitrobenzene
Pyridine
Tetrachloroethylene
Toluene
1,1, 1-Trichloroethane
1,1, 2-Trichloro-l ,2,2 -trif luoroethane
Trichloroethylene
Trichlorofluoromethane
Xylene
0 . 05
0.05
0.66
1.12
0.079
1.12
1.05
1.05
0.062
0.05
0.05
0.75
0.33
0.125
0.33
0.05
0.33
0.41
0.96
0.091
0.96
0.15
Source: U.S. EPA 1986a
59
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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 PROCESS WASTEWATER
The average process wastewater volumes discheirged by solvent
reclaimers are low in comparison to volumes economically treated
by typical wastewater treatment technologies. The daily process
wastewater flow ranges between 25 to 1,500 gallons, with an average
facility discharging 400 gallons. Approximately 81 percent of the
industry achieves zero discharge of process wastewater through the
use of fuel blending, incineration, evaporation, contract hauling,
and land disposal. The tendency to use zero discharge technologies
is related to: (1) the availability of in-plant methods such as
fuel blending and evaporation, and (2) the economics of contract
hauling when compared to end-of-pipe treatment.
In a study conducted by the U.S. Environmental Protection
Agency, Industrial Technology Division (EPA-ITD) for the pesticide
formulating and packaging industry, a flow of 750 gallons per day
was shown to be the economic limit for contract hauling of
solvent-bearing wastewater (EPA 1985b). Compliance costs for
proposed zero discharge effluent limitations were based on contract
hauling for plants that discharged less than 750 gallons per day.
Plants that discharged more than 750 gallons per day were shown to
more economically achieve compliance by installing end-of-pipe
treatment to achieve nondetectable pollutant levels. The treatment
system included pumping, equalization, steam stripping,
neutralization, dual media filtration, carbon adsorption, carbon
regeneration, and incineration.
Contract hauling is an appropriate model technology for the
purpose of determining the industry cost of complying with process
wastewater effluent guidelines. This conclusion is based on the
following information: 81 percent of the industry currently
achieves zero discharge, and the average plant discharges 400
gallons per day, which is less than the 750 gallon flow shown to
be economically contract-hauled by the pesticides industry.
Table 7-1 shows contract hauling costs for wastewater
discharge flows of 25, 400, and 1,500 gallons per day. All cost
data are abstracted from the Development Document for Effluent
Limitations Guidelines and Standards for the Pesticide Point Source
Category (USEPA 1985b).
60
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TABLE 7-1. CONTRACT HAULING COSTS FOR PROCESS WASTEWATER
Wastewater Flow (Gallons per day)
25 400 1,500
Capital Cost8
Annual Cost"
$20,000 $20,000 $20,000
$16,250 $260,000 $975,000
Capital costs include piping, pumps, and a 5,000-gallon
storage tank.
Annual costs are based on 260 operating days per year and a
contract hauling cost of $2.50 per gallon.
7.2 COOLING AND MISCELLANEOUS WASTEWATER
Sources of noncontact cooling water generated at solvent
reclaimers are similar to sources in other industries. Solvent
reclaimers use the same type of heat exchange equipment that is
found in the organic chemicals, plastics, and synthetic fibers
(OCPSF) and petroleum industries. This equipment includes
condensers, pumps, and cooling towers. The spent solvents
reprocessed by solvent reclaimers are manufactured in the OCPSF and
petroleum industries. Since similar equipment is used and similar
products are processed, the noncontact cooling waters discharged
by the solvent recovery, OCPSF, and petroleum industries should
contain comparable levels of pollutants. The cooling and
miscellaneous wastewaters sampled at Plants D and E contain
extraordinarily high levels of volatile and extractable organics
when compared to other industries. These wastestreams are composed
primarily of noncontact cooling water. Also contained in the
discharges are sanitary wastes, boiler blowdown, and steam
condensate, which are unlikely sources of the organic pollutants
found in samples collected by EPA-ITD. Possible sources of
contamination include illicit sewer connections, ground water
infiltration, and poorly maintained cooling equipment.
In-plant control measures are more appropriate for controlling
noncontact cooling water discharges than costly end-of-pipe
technologies. These in-plant measures include routine equipment
maintenance to prevent product leakage through condenser tubes, and
replacement of pump packing materials with mechanical seals. Other
control measures include segregation and separate treatment of
sanitary wastewater, floor wash, spills, and contaminated runoff.
No costs have been developed in this report to estimate the cost
of implementing in-plant control measures. These costs would
reflect plant size, plant age, and plant layout factors that are
specific to the solvent recovery industry. This information is not
currently available.
61
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Cooling water treatment costs can be estimated,
conservatively, by transferring technology demonstrated in the
organic chemicals industry. Steam stripping has been shown to
provide effective treatment for wastewaters and solvents (SAIC
1985). Of the 20 organic compounds listed in Table 5-5 as
detected, 18 are volatile compounds. The remaining two,
thioxanthone and tripropyleneglycol-methylether, are extractable
compounds and less amenable to removal by stripping. However,
these compounds were found in only one of the three samples.
Therefore, for purposes of this report, steam stripping is judged
to be the single, most effective technology suitable for the
removal of 90 percent of organics found in solvent recycling
wastewater.
The average solvent recycling plant discharges 11,000 gallons
of cooling water on a continuous basis. In terms of 1985 dollars,
an average plant that installed continuous mode treatment would
incur an equipment cost of $250,000 and a land cost of 20 percent,
or $50,000, for a total capital cost of $300,000. The annual
operating expense would be $30,000 plus a $5,000 compliance
monitoring cost, for a total operating expense of $35,000.
Appendix C includes a detailed discussion of the basis for these
costs.
7.3 ECONOMIC ASSESSMENT AND COST-EFFECTIVENESS
This subsection presents a preliminary economic assessment of
possible regulations affecting the solvent recovery industry. The
first part of the subsection presents operating and financial
characteristics of the industry. This is followed by a discussion
of the economic assessment of control options and the results of
the analysis. The final part of this subsection provides an
analysis of the cost-effectiveness of these possible regulations.
7.3.1 Economic Assessment
7.3.1.1 Treatment Technology and Model Plant
Because of the small amount of wastewater produced in solvent
recovery, the most likely end-of-pipe control option is to contract
haul the wastewater for treatment/disposal and recycle the cooling
water after steam stripping. The costs developed for the model
plant are based on this technology.
The model plant has the capacity to process 800,000 gallons
of spent solvents annually. This includes 344,000 gallons of
nonhalogenated solvents, 240,000 gallons of petroleum solvents, and
208,000 gallons of halogenated solvents. Using the percent
recovery ratios shown in Table 7-2, this plant would produce a
finished volume of 587,680 gallons of solvents, with a value of
$1,150,931.
62
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TABLE 7-2. ECONOMICS OF A SOLVENT RECOVERY MODEL PLANT
(800,000 GALLONS PER YEAR CAPACITY)
Solvent
Category
Spent Solvents
Composition
(%) (gallons)
%
Recovery
Finished
Volume
(gallons)
Solvents
Price Value
($/gal)
Nonhalogenated 43
Petroleum 30
Halogenated 26
Other 1
Total 100
344,000
240,000
208,000
8,000
800,000
74
73
74
50
254,560
175,200
153,920
4,000
587,680
1.69 430,206
0.8 140,160
3.69 567,965
3.15 12,600
1,150,931
63
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It costs $378,000 annually to implement the end-of-pipe
control option described above for an 800,000 gallon solvent
recovery plant, or about $0.47 per gallon of spent solvents
processed. In terms of finished solvents, the control cost is
about $0.64 per gallon.
One impact measure compares the annual control cost to the
annual revenues of this plant. As shown in Table 7-3, control
costs are equivalent to 33 percent of the value of the finished
solvents. A second measure compares the annual control costs to
the reclamation costs. Consulting engineering reports show that
the costs of spent solvent reclamation ranges widely, varying
between $0.20 and $1.55 per gallon (Engineering Science 1985; New
England Congressional Institute 1986). Therefore, control costs
are one-third to 2.5 times the reclamation costs. Since most
recycling operations are conducted on a tolling basis, where a fee
is charged for reclamation and the finished solvents are returned
to the supplier, a good impact measure would be a comparison of the
control costs to tolling fees. Agency data show that tolling fees
range between $0.70 and $2.50 per gallon (ICF 1986). The treatment
costs are calculated at $0.47 per gallon of solvent processed,
which represents from 19 to 67 percent of the tolling fees. Given
the wide variability in tolling fees and the uncertainty in
treatment costs, no definitive conclusion can be made regarding the
severity of the impacts.
7.3.2 Cost-Effectiveness
Cost-effectiveness is defined as the incremental annualized
cost of a pollution control option in an industry or 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 non-priority hazardous
pollutants, incremental removal may be underestimated for this
preliminary cost-effectiveness calculation.
For solvent recyclers, two wastestreams are analyzed: process
wastewater and cooling water. The control technologies for solvent
recyclers are contract hauling the process wastewater to
treatment/disposal and recycling the cooling water. In the United
States, there are about 40 solvent recyclers discharging process
wastewater; each facility generates 400 gallons per day. The
annual process wastewater flow is 4.16 million gallons.
Nationally, there are about 72 solvent recyclers generating cooling
water with detectable levels of pollutants. The annual cooling
water is 205.9 million gallons for these recyclers.
Table 7-4 shows the data used and the step-by-step
cost-effectiveness calculations for process wastewater. The pounds
equivalent (PE) removed for each pollutant is calculated on the
64
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TABLE 7-3. ECONOMIC IMPACT MEASURES
Total Amount
Cost Impact Measure
Total Cost of Treatment
Spent Solvent Processed
Solvents Recovered
Value of Recovered Solvents
Reclamation Costs
Tolling Fees
$378,000
800,000 gal
587,000 gal
$1,150,000
$0.20/gal to
$1.55/gal
$0.70/gal to
$2.50/gal
$0.47 gal
$0.64/gal
33% of value
30 to 235% of
reclamation costs
19 to 67% of
tolling fees
65
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7-4. COST-EFFECTIVENESS CALCULATION FOR SOLVENT RECYCLERS
(ZERO DISCHARGE OF PROCESS WASTEWATER
BY CONTRACT HAULING)
Number of plants
Wastewater flow
Number of days/y
Annual flow (mg)
Pollutant Name
1,1, 1-Trichloroethane
1,2, 4-Trichlorobenzene
1, 2-Dichlorobenzene
1, 2-Diphenolhydrazine
1,3-Dichlorobenzene
1,4-Dichlorobenzene
discharging wastewater (N)
(gpd) @ each plant
in operation (d)
for all plants = N
TWF
0.0003
0.02
0.017
1
0.018
0.0213
2-Chlorophenol 0.215
Bis (2-ethylhexyl) phthalate 2.1876
Chloroform 2.952
Di-N-Butyl Phthalate
Di-N-Octyl Phthalate
Fluoranthene
Fluorene
Methylene chloride
Naphthalene
Phenathrene
Butyl benzyl phthalate
Phenol
Pyrene
Tetrachloroethene
Toluene
Trichloroethene
2 , 4-Dimethylphenol
Ethylbenzene
Isophorone
P-Cresol
0.0002
0.812
0.104
0.112
2.947
0.009
0.281
0.254
0.0022
0.146
0.707
0.0004
0.207
0.0026
0.004
0.00001
0.1806
(q)
x q x d
Raw
Proba-
bility
1
0.33
0.33
0.33
0.33
0.33
0.33
0.33
0.33
0.33
0.33
0.33
0.33
1
0.33
0.33
0.33
0.33
0.33
0.33
0.67
1
0.33
0.67
0.67
0.33
40
400
260
4.16
Wastewater
Concentra-
tion (ppm)
82.1
248.0
3162.0
238.3
36.5
76.6
44.5
1138.0
40.5
205.8
260.0
31.6
21.0
833.4
345.0
46. 8
178.2
154.0
10.8
1350.0
22.0
101.0
51.3
1.44
121.7
48 . 2
Annual
PE
0.85
56.79
615.44
2728.33
7rr o
. 52
18.68
109.54
28502.54
1368.81
0.47
2417.14
37 . 63
26.93
85210.48
35. 55
15 . 06
51.82
3 . 88
18.05
10927.64
0.20
725.36
1.53
0 . 13
0 . 03
99 . 66
Sum (Organic) Cone. & Loading
8,849
132,980
66
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7-4. COST-EFFECTIVENESS CALCULATION FOR SOLVENT RECYCLERS
(ZERO DISCHARGE OF PROCESS WASTEWATER
BY CONTRACT HAULING) (Continued)
Pollutant Name
TWF
Raw Wastewater
Proba- Concentra- Annual
bility tion (ppm) PE
Cadmium
Chromium
Lead
Nickel
Zinc
Antimony
Arsenic
Copper
5.09
0.0267
1.75
0.114
0.119
0.00362
32.0295
0.467
1
1
1
1
1
1
1
1
2.1
3.5
16.6
7.7
91.6
0.6
0.07
5.1
362.02
3.24
1007.87
30.45
378.18
0.08
77.79
82.63
Sum (Metals) Cone. & Loading
127
1,942
Sum (Organic & Metal) Cone. & Loading
Annualized cost ($)
CE ($/PE)
@ each plant: Capital cost ($)
Annual hauling cost ($)
Annualized cost ($)
8,976
20,000
260,000
265,200
134,922
10,608,000
79
Data sources: Raw waste cone. (Tables 5-2 and 5-4).
67
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basis of flow and concentration of that pollutant. Since the
control option is contract hauling, raw waste loads are removed in
their entirety. EPA 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 report. Total
loading for each pollutant is calculated by applying the Method I
concentrations and the proportion of sample plants with detectable
levels of the pollutant (labeled probability in Table 7-4) to the
total number of plants. For the 40 plants, the pound equivalents
of pollutants removed are 134,922 and the annualized costs are
$10,608,000. The cost-effectiveness of this option is $79 per
pound equivalent.
Table 7-5 shows the data used and the step-by-step
cost-effectiveness calculation for treating cooling water. Since
the control technology is steam stripping, the analysis considers
organic pollutants. The Agency has cooling water sample loadings
data from two solvent recyclers, of which one has detectable
concentrations and the other does not. The cost-effectiveness
analysis assumes that one-half of the solvent recyclers discharging
wastewater (72 plants) have levels of pollutants in their cooling
water as detected at the sample plant. The total cooling water
discharge for these 72 plants is 205.9 million gallons, and the
pounds equivalent of pollutants removed is 79,355. With an
annualized cost of $113,000 for each plant, or $8,136 million for
72 plants, the cost-effectiveness of this option is $102.53.
7.4 SUMMARY
The following summarizes the major points thci:t were discussed
in this section:
Zero discharge of process wastewater by contract hauling
and incineration is a model treatment system. A typical
facility would incur a capital cost of $20,000 and an
annual hauling cost of $260,000.
If treatment of cooling water is needed, steam stripping
technology is available that can be transferred to the
solvent recycling industry. For treatment of cooling
water, the average solvent recycling plant would incur
a capital cost of $300,000 and an annual operating cost
of $35,000.
The annualized wastewater control cost is $0.47 per
gallon of solvent processed, which represents from 19 to
67 percent of the tolling fees.
The cost-effectiveness of treating the two types of
wastewater is not significantly different, ranging from
$79 to $102 per pound equivalent of pollutant removed.
68
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TABLE 7-5.
COST-EFFECTIVENESS CALCULATION FOR SOLVENT RECYCLING
WASTEWATER TREATMENT
(COOLING WATER BY STEAM STRIPPING)
Number of plants requiring steam stripping = one half of wet plants(N) 72
Cooling water (gpd) @ each plant (q) 11,000
Number of days/y in operation (d) 260
Annual cooling flow (ing) for all plants = Nxqxd 205.92
Waste Weighted
Organic Cone .
Pollutant Name (ppb) TWF
Acetone 415110 0
Benzene 26130 0.848
Methylene Chloride 5319 2.947
1,1,2-Trichloroethane 2090 0.934
1,1,2,2-Tetrachloroethane 2090 3.296
Total Cone, (ppb) 450,739
Annual loading all plants 774,087
Incremental removal (PE) for all plants
Annual ized cost ($)
CE ($/PE)
@ each plant: investment cost ($)
land cost (20% of above)
O&M cost
monitoring cost ($/y)
annualized cost ($)
Cone.
(ppb)
0
22158
15675
1952
6889
46,674
80,157
($)
Steam
Stripping
Efflu. Wtd.Efflu.
Cone.
Removal (ppb)
0.99 4151
0.99 261
0.99 53
0.99 21
0.99 21
4,507
7,741
8,
250,000
50,000
30,000
5,000
113,000
Cone.
(PPb)
0
222
157
20
69
467
802
79,355
136,000
102
Data sources: Table 5-5 and SAIC, 1987f.
69
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8. ENVIRONMENTAL ASSESSMENT
The purpose of this section is to present the results of an
environmental assessment. 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
An 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 non-priority organics, (3)
total priority inorganics, and (4) total non-priority inorganics.
The total priority organics and inorganics were then compared to
the total raw waste pollutant loadings from regulated best avail-
able technology (BAT) industries to evaluate the significance of
pollutant loadings from the industry/subcategory considered in this
document.
8.1.2 Indirect Discharge Analysis
The following analyses were performed for indirect
dischargers: (1) criteria comparisons using a publicly-owned
70
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treatment works (POTW) model and stream dilution analysis, (2)
impacts to POTWs, and (3) loading comparisons.
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 Environmental Protection Agency's (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 (Mg/l) = POTW Influent (Mg/l) x (1-Treatment Removal Efficiency)
t 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 :
POTW Effluent
x POTW Flow
T 0+- -,*.
In-Stream Diluted POTW Effluents/I) = POTW Receiving stream Flow (MGD)
. l.1_:!:inPacts on POTW operations were calculated in terms of
inhibition of POTW processes and contamination of POTW sludges
Inhibition of POTW operations was determined by comparing POTW
influent levels (Equation 3) with inhibition levels, when
a va liable.
Equation 3;
PDTW -r^fn,10,,4- * ^ ' Total Industry Flow
POTW Influent = Average Plant Concentration (/xg/1). x POTW Flow (MGD)
71
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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 (M9/1) * 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
Process Wastewater
Discharge flows of process wastewater are very small,
averaging 400 gpd per plant. Total direct discharge flow is only
4,000 gpd, and total indirect discharge flow only 12,000 gpd.
Because of very high concentrations for the majority of
detected pollutants, projected water quality impacts from direct
discharges of untreated process wastes are very significant for
small to medium receiving streams (with stream flows up to 2,000
MGD) even at small average plant discharge flows (400 gpd). Of
69 detected pollutants, 57 were at levels that may be harmful to
human health and/or aquatic life:
34 pollutants (including 10 carcinogens) have projected
human health impacts for streams with less than 2,000 MGD
flow;
40 pollutants have projected short-term (acute) aquatic
life impacts in mixing zones of receiving streams with
exceedance factors ranging from 1 to 2,000;
51 pollutants have projected long-term (chronic) aquatic
life impacts for streams with less that 150 MGD flow; and
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17 pollutants have projected drinking water impacts, but
only for 'very small streams (less than 2 MGD flow).
Untreated direct discharges of the carcinogen 1,2-
diphenylhydrazine alone would require more than 2,000 MGD receiving
stream flow to dilute the discharge concentration below levels
harmful to human health. To eliminate the aquatic life impacts of
bis(2-ethylhexyl)phthalate, a receiving stream flow of more than
150 MGD is required. Potential drinking water impacts from
discharge of 1,2-dichlorobenzene are projected only for small
streams, with less than 2 MGD flow.
Indirect discharges of untreated process wastewater, based on
projected discharge to a model 1 MGD POTW (representing the median
size POTW with indirect industrial dischargers), are expected to
inhibit POTW treatment for one pollutant but not cause any sludge
contamination; however, process wastes may cause POTWs to exceed
human health criteria in receiving streams for six pollutants (all
carcinogens), and chronic aquatic life criteria for one pollutant.
The control technology for solvent recycler process wastewater
is contract hauling to a treatment/disposal facility (zero
discharge); therefore, the environmental impacts for treated
effluents for direct and indirect dischargers were not projected.
Pollutant Loadings fibs/day)
Priority organics:
Non-priority organics:
Priority inorganics:
Non-priority inorganics:
Raw
Wastewater
288
476
4
184
Treated
Wastewater
864
1,429
12
493
932
2,798
Total loadings of priority pollutant inorganics from untreated
process wastewater (e.g., 4 Ibs/day from direct and 12 Ibs/day from
indirect dischargers) are less than the lowest raw waste total
priority pollutant inorganic loadings from regulated BAT/PSES
industries. Total raw waste loadings of priority organics from
both direct and indirect discharges (e.g., 288 Ibs/day and 864
Ibs/day, respectively) are more significant (comparable to raw
waste priority pollutant organics loadings form the raw waste
regulated industries ranked in the lower third of loading
rankings).
8.2.2
Contaminated Coolincr Water
The contaminated cooling water discharge flows average 11,000
gpd per plant. The total direct discharge flow is about 0.4 MGD,
and total indirect discharge flow about 1.2 MGD.
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Untreated Cooling Water
Potential water quality impacts from direct discharge of
untreated contaminated cooling water were projected for small
streams with less than 300 MGD flow. Of 25 detected pollutants,
13 were at levels that may be harmful to human health and/or
aquatic life:
9 pollutants (including 6 carcinogens) have projected
human health impacts for streams with less than 300 MGD
flow;
6 pollutants have projected short-term (acute) aquatic
life impacts in mixing zones of receiving streams with
exceedance factors as high as 46;
9 pollutants have projected long-term (chronic) aquatic
life impacts for streams with less that. 9 MGD flow; and
9 pollutants have projected drinking water impacts on
streams with less than 30 MGD flow.
Direct discharge of the carcinogen, methylene chloride, alone
would require more than 300 MGD stream flow to dilute the discharge
concentration below levels harmful to human health, and more than
a 30 MGD flow is needed to eliminate potential drinking water
impacts from the carcinogen benzene. Aquatic life impacts were
projected for streams up to 9 MGD flow (for acetone),
Potential water quality and POTW impacts from indirect
discharges of untreated contaminated cooling water (projected based
on a model 1 MGD POTW) are not significant. No detrimental impacts
on POTWs were projected. Only one pollutant ( the carcinogen
methylene chloride) has the potential to exceed criteria for human
health in surface waters receiving indirect discharges through
POTWs.
Treated Cooling Water
The control technology for contaminated cooling water is steam
stripping with an assumed 99 percent removal rate for all
pollutants.
Potential water quality impacts from direct discharge of
treated cooling water were projected for only very small streams
with less than 3 MGD flow. Of 25 detected pollutants, 9 were at
levels that may be harmful to human health and/or aquatic life:
4 pollutants (including 3 carcinogens) have projected
human health impacts for streams with less than 3 MGD
flow;
No pollutants have projected to have short-term (acute)
aquatic life impacts;
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4 pollutants have projected long-term (chronic) aquatic
life impacts for streams with less that 0.1 MGD flow; and
2 pollutants may have drinking water impacts on streams
with less than 0.3 MGD flow.
Potential water quality and POTW impacts from indirect
discharges treated cooling water (projected based on a model 1 MGD
POTW) are insignificant. No detrimental impacts on POTWs or
receiving streams are projected.
Pollutant Loadings flbs/dav^
Direct Dischargers
Priority organics:
Non-priority organics:
Priority inorganics:
Non-priority inorganics:
Untreated
Cooling
Water
78
1,373
14
234
1,699
Treated
Cooling
Water
0.8
13.7
0.2
2.3
17.0
Indirect Dischargers
Priority organics:
Non-priority organics:
Priority inorganics:
Non-priority inorganics:
Untreated
Cooling
Water
232
4,080
42
694
5,048
Treated
Cooling
Water
2.3
40.8
0.4
6.9
50.4
Total loadings of priority pollutant inorganics from direct
and indirect discharge of untreated contaminated cooling water
(e.g., 14 Ibs/dciy and 42 Ibs/day, respectively) are less than the
lowest raw waste priority pollutant inorganic loadings from
regulated BAT/PSES industries. The total untreated loadings of
priority pollutant organics from both direct and indirect
discharges (e.g., 78 Ibs/day and 232 Ibs/day, respectively) are
also relatively low, comparable to the raw waste priority organics
loadings for regulated industries ranked in the lower third.
Total loadings of priority pollutant inorganics from treated
cooling water are: 0.2 Ibs/day for directs; and 0.4 Ibs/day for
indirects. Total loadings of priority pollutant organics from
treated cooling water are: 0.8 Ibs/day for directs; and 2.3
Ibs/day for indirects. These are less than the lowest treated
(BAT/PSES) loadings from regulated industries.
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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 technologies would result in
significant reductions in air emissions from present rates. This
conclusion is based on the prevailing absence of end-of-pipe
treatment technologies in the solvent recycling industry. Contract
hauling and incineration of process wastewater and steam stripping
of contaminated cooling water would significantly reduce volatile
organic carbon (VOC) emissions to the atmosphere. Data are not
available, however, to accurately estimate the VOC mass potentially
reduced if model control technologies were implemented.
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 and hazardous waste would be
insignificant compared to current levels. The net residual solid
waste from contract hauling and incineration of process wastewater,
in the form of ash, will be negligible. Residuals from steam
stripping would be in the form of recyclable solvents.
8.3.3 Energy Requirements
Implementation of the model cost technologies could increase
energy consumption significantly over present industry use. The
model technologies, contract hauling and incineration of process
wastewater and steam stripping of cooling water, are similar to the
technologies used to recover solvents with respept to energy
requirements. Energy consumption could double over current usage
(SAIC 1987f). The estimated increased energy consumption is 81,000
barrels of No. 2 fuel per year. However, most plants are likely
to implement cost-effective Best Management Practices (BMPs) to
control pollutants in cooling water discharges. BMPs are less
costly and often more practical than end-of-pipe control
technologies such as steam stripping.
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8.4 SUMMARY
The following list summarizes the major points that were
discussed in this section:
Total loadings of priority pollutant inorganics from
untreated process wastewater are less than the lowest raw
waste total inorganics loadings from regulated BAT/PSES
industries. Total loadings of priority pollutant
organics, are more significant and rank in the lower third
of the loadings rankings.
Total loadings of priority pollutant inorganics and
organics from untreated cooling and miscellaneous
wastewater are low relative to the lowest raw waste
loadings from the regulated BAT/PSES industries.
Implementation of the model cost technologies would
result in significant reductions in air emissions, an
insignificant increase in solid and hazardous waste, and
a doubling of energy consumption.
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9. REFERENCES
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68-03-3243. November 1986.
Boubel, R.W. 1985. "Recovery, Reuse and Recycle of Solvents -
Unclassified" Defense Environmental Leadership Project, Washington,
B.C. December 1985.
Engineering Science. 1985. Supplemental Report on the
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Environmental Information Ltd. 1986. Industrial and Hazardous
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National Association of Solvent Recyclers. 1982. Industry Survey.
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Brochure and Membership List.
1986. Association
New England Congressional Institute, 1986. Hazardous Waste
Generation and Management in New England. February 1986.
Pope-Reid Associates, Inc. 1986. Background Document for Solvents
to Support 40 CFR 258, Land Disposal Restrictions. Prepared for
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Science Applications International Corporation. 1985, Costing
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1986a. Memorandum
1987a. Memorandum
1987b. Memorandum
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Science Applications International Corporation. 1987c. Memorandum
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Science Applications International Corporation. 1987d. Memorandum
to plant files. June 1, 1987.
Science Applications International Corporation. 1987e. Memorandum
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Science Applications International Corporation. 1987f. Memorandum
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Scofield, F., J. Levin, G. Beeland, and T. Laird. 1975.
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Allied Products Industry, Contract Solvent Reclaiming Operations,
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Environmental Protection Agency under Contract No. 530/sw-119c.
NTIS PB No. 251 669. September 1975.
Tierney D.R. and T.W. Hughes. 1978. Source Assessment Reclaiming
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U.S. Environmental Protection Agency. 1985a. Directory of
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Office of Solid Waste. Washington, D.C. December 1985.
U.~S. Environmental Protection Agency. 1985b. Development Document
for Effluent Limitations Guidelines and Standards for the Pesticide
Point Source Category. EPA 440/1-85/079. October 1985.
U.S. Environmental Protection Agency. 1986a. Best Demonstrated
Available Technology (BOAT) Background Document for F001-F005 Spent
Solvents. EPA 1530-SW-86-056. November 1986.
U.S. Environmental Protection Agency. 1986b. Hazardous Waste
Management System; Land Disposal Restrictions; Final Rule. Federal
Register. Vol. 5, No. 216, p. 40572.
U.S. Environmental Protection Agency. 1986c. Report to Congress
on the Discharge of Hazardous Wastes to Publicly Owned Treatment
Works (The Domestic Sewage Study). February 1986.
U.S. Environmental Protection Agency. 1986d. 1985 Survey of
Selected Firm in the Commercial Hazardous Waste Management
Industry. Final Report. Office of Policy Analysis. November,
1986.
Government Printing Office : 1990 - 719-391/05901
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