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



  19

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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

                                10

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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

                                11

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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,

                                12

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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

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                 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

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 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

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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

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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

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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

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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

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 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

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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

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          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

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          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

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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

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     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

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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

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                 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

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                     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

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          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

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        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

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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

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       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

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        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

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       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

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              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

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              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

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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

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               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

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                 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

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                 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

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                 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

                                72

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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.
                                73

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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;
                                74

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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.
                                75

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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.
                                77

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                          9.   REFERENCES
Alliance Technologies Corporation.   1986.  Performance Evaluations
of  Existing Treatment  Systems,  Site-Specific Sampling  Report. .
Prepared for the  U.S.  Environmental Protection Agency,  Hazardous
Waste   Engineering  Research   Laboratory  under   Contract   No.
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
Technological  Assessment  of  Treatment   Alternatives   for  Waste
Solvents.  Prepared  for the U.S. Environmental Protection Agency,
Waste Treatment Branch.  July  1985.

Environmental  Information  Ltd.  1986.   Industrial  and Hazardous
Waste Management  Firms.  Minneapolis, Minnesota.

GCA  Corporation.     1986.    Performance  Evaluations  of Existing
Treatment System: Site-Specific Sampling Report.   Prepared for the
U.S. Environmental Protection  Agency, Hazardous Waste Engineering
Research Laboratory  under Contract                    :
No. 68-03-3243.   July 1986.

National Association of Solvent Recyclers.  1982.   Industry Survey.
National  Association of  Solvent  Recyclers.
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
the  U.S.  Environmental  Protection  Agency  under  Contract   No,
68-01-6892.   August  1986.

Science  Applications International Corporation.   1985,   Costing
Documentation and Notice of New Information Report.  Prepared  for
the  U.S.  Environmental  Protection Agency - industrial  Technology
Division under Contract No. 68-01-6947.   June 12,  1985.
 Science Applications International Corporation.
 to  project files.   September 3,  1986.

 Science Applications International Corporation.
 to  project files.   June 24,  1987.

 Science Applications international Corporation,
 to  project files.   October 5,  1987.
  1986a.  Memorandum
  1987a.  Memorandum
  1987b.  Memorandum
                                78

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 Science Applications International Corporation.  1987c.  Memorandum
 to plant  files.   June 6,  1987.

 Science Applications International Corporation.  1987d.  Memorandum
 to plant  files.   June 1,  1987.

 Science Applications International Corporation.  1987e.  Memorandum
 to plant  files.   November 17,  1987.

 Science Applications International Corporation.  1987f.  Memorandum
 to project  files.   December 4,  1987.

 Scofield,   F.,  J.  Levin,  G.  Beeland,  and  T.  Laird.    1975.
 Assessment  of  Industrial  Hazardous  Waste  Practices,  Paint  and
 Allied Products Industry,  Contract Solvent Reclaiming  Operations,
 and  Factory  Applications  of  Coatings.   Prepared  for the  U.S.
 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
 of Waste  Solvents.-   State  of  the Art.    Prepared  for the  U.S.
 Environmental  Protection  Agency under Contract No.  600/2-78-004f
 NTIS PB No. 282 934.   April 1978.

 U.S.  Environmental  Protection  Agency.    1985a.    Directory  of
 Commercial  Hazardous  Waste Treatment  and Recycling  Facilities.
 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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