EPA/540/G-90/005
                                         August 1990
CERCLA Site Discharges to POTWs
            Guidance Manual
                  Prepared by

         The Industrial Technology Division
      Office of Water Regulations and Standards
                Office of Water
                 Prepared for

     Office of Emergency and Remedial Response
        U.S. Environmental Protection Agency
              Washington, DC 20460

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  ACKNOWLEDGEMENTS

  Preparation of this document was directed by  Ruth A. Lopez, Project Officer, of the
  Industrial Technology Division, Office of Water Regulations and Standards. Additional
  EPA Support  was provided by select EPA Headquarters and Regional personnel who
  supplied valuable  comments and recommendations. Support was provided under EPA
  Contract No.  68-03-3412.
  Additional copies of this document may be obtained from:

                     National Technical Information Service (NTIS)

                     U.S. Department of Commerce

                     5285 Port Royal Road

                     Springfield, Virginia  22161

                     (703) 487-4600
NOTE TO READERS: This document was prepared using the most recent U.S. Environmental Protection
Agency (USEPA) guidance and regulations. However, because USEPA continually updates the guidance
and regulations, the reader is advised to use the Federal Register and Code of Federal Regulations, or to
contact the appropriate authorities to ensure that guidance and regulations are current.

Documents being prepared at the release of this guidance manual that may impact the information contained
within include:

      • The proposed "Procedures for Planning and Implementing Off-Site Response Actions"
        (40 CFR ง300.440 upon promulgation)

      • New Domestic Sewage Study Regulations (40 CFR ง122 and 403 upon promulgation)

      • The Proposed Sludge Regulations (40 CFR ง503 upon promulgation)

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TABLE OF CONTENTS

EXECUTIVE SUMMARY                                             ES-1

1.     INTRODUCTION                                               1-1

      1.1.   THE REMEDIAL INVESTIGATION/FEASIBILITY STUDY         1 -1
           PROCESS
      1.2.   POLICIES THAT APPLY TO THE POTW DISCHARGE            1-1
           ALTERNATIVE
      1.3.   COMPLIANCE WITH APPLICABLE OR RELEVANT AND         1-5
           APPROPRIATE REQUIREMENTS (ARARs)
           1.3.1.     Applicable Requirements                             1-5

           1.3.2.     Relevant and Appropriate Requirements                  1-5

      1.4.   GUIDANCE MANUAL ORGANIZATION                       1-6

2.     IDENTIFY AND CHARACTERIZE CERCLA WASTEWATER          2-1
      DISCHARGE

      2.1.   IDENTIFY THE CERCLA WASTEWATER DISCHARGE           2-1

      2.2.   CHARACTERIZE THE CERCLA WASTEWATER                2-1
           DISCHARGE
           2.2.1.     Data Requirements                                 2-1

           2.2.2.     Data Collection and Evaluation                        2-5

           2.2.3.     Definition of Wastestream Quality and Quantity            2-5

           2.2.4.     Determine whether CERCLA Wastestream is a            2-5
                    RCRA Hazardous Waste
3.     IDENTIFY LOCAL POTWs                                      3-1

      3.1.   IDENTIFY THE AREA OF CONSIDERATION                   3-1

           3.1.1.     Applicability of the Domestic Sewage Exclusion           3-1

           3.1.2.     RCRA Permit-by-Rule Requirements for POTWs     ,      3-3

           3.1.3.     Selection of an Appropriate Transport Technology          3-3

      3.2.   IDENTIFY POTENTIAL POTWs                              3-4
                                      111

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TABLE OF CONTENTS
4.    INVOLVE POTW IN THE EVALUATION PROCESS AND            4-1
     SCREEN POTWs

     4.1.   COMPLIANCE STATUS OF POTWs                         4-1

     4.2.   TECHNICAL FEASIBILITY                                4-2

     4.3.   ADMINISTRATIVE FEASIBILITY                           4-3

           4.3.1.    Permitting Process                                4-3

           4.3.2.    Local Ordinances                                 4-4

           4.3.3.    Potential Liability Associated with Accepting             4-4
                   CERCLA Wastes
           4.3.4.    Indemnification                                  4-5

5.    EVALUATE PRETREATMENT REQUIREMENTS                  5-1

     5.1.   OBTAIN OR ESTIMATE POTW'S LOCAL LIMITS               5-1

     5.2.   COMPARE CERCLA DISCHARGE CHARACTERISTICS TO       5-3
           LOCAL LIMITS
6.    IDENTIFY AND SCREEN PRETREATMENT ALTERNATIVES        6-1

     6.1.   IDENTIFY PRETREATMENT TECHNOLOGIES                 6-1

     6.2.   ASSEMBLE ALTERNATIVE PROCESS TRAIN                 6-4
           PRETREATMENT

           6.2.1.    Flow Equalization and Phase Separation                 6-4

           6.2.2.    Metals Removal                                  6-4

           6.2.3.    Organics Removal                                6-4

           6.2.4.    Polishing and Discharge                            6-5

7.    DETAILED ANALYSIS OF THE POTW DISCHARGE                7-1
     ALTERNATIVE

     7.1.   OVERALL PROTECTION OF HUMAN HEALTH AND THE        7-2
           ENVIRONMENT

     7.2.   COMPLIANCE WITH ARARs                              7-6
                                     IV

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                                                         TABLE OF CONTENTS
      7.3.   LONG-TERM EFFECTIVENESS AND PERMANENCE            7-6

      7.4.   REDUCTION OF MOBILITY, TOXICITY, OR VOLUME           7-7
           THROUGH TREATMENT
      7.5.   SHORT-TERM EFFECTIVENESS                             7-7

      7.6.   IMPLEMENTABILITY                                     7-8

      7.7.   COST                                                  7-8

      7.8.   STATE ACCEPTANCE                                     7-9

      7.9.   COMMUNITY ACCEPTANCE                               7-9

      7.10.  SUMMARY EVALUATION                                 7-9

8.     CLEAN WATER ACT AND THE NATIONAL PRETREATMENT       8-1
      PROGRAM

      8.1.   NATIONAL PRETREATMENT PROGRAM                     8-1

           8.1.1.    National Categorical Standards                        8-1

           8.1.2.    General Pretreatment Regulations                      8-2

           8.1.3.    Development of Local Limits or Other State or Local        8-3
                   Discharge Requirements
           8.1.4.    Discharge Control Mechanism                         8-3

      8.2.   NATIONAL POLLUTANT DISCHARGE ELIMINATION           8-4
           SYSTEM

           8.2.1.    Ambient Water Quality Standards                      8-4

           8.2.2.    Controlling Effluent Toxicity                         8-5

9.     RCRA REQUIREMENTS                                        9-1

      9.1.   DETERMINE WHETHER THE WASTE IS SPECIFICALLY         9-1
           LISTED
      9.2.   DETERMINE WHETHER THE WASTE EXHIBITS                9-4
           HAZARDOUS CHARACTERISTICS
      9.3.   DETERMINE WHETHER THE WASTE IS A MIXTURE            9-4

      9.4.   DERIVED-FROMRULE                                    9-4

      9.5.   GROUNDWATER AND UNKNOWN ORIGIN EXCEPTIONS        9-4
           TO RCRA

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TABLE OF CONTENTS
10.   ESTIMATE PRETREATMENT LIMITS                                10-1




      10.1.   ESTIMATE LIMITS                                             10-1




             10.1.1.    Evaluate Biological Inhibition                            10-1




             10.1.2.    Calculate Mass Balance                                  10-14




                10.1.2.1.  Calculate Concentration in POTW Effluent              10-15




                10.1.2.2.  Calculate Concentration in Air Emissions and Sludge      10-16




                10.1.2.3.  Calculate Amount Biodegraded                        10-16




             10.1.3.    Evaluate Permit Limit/Criteria Compliance                 10-16




             10.1.4.    Calculate CERCLA Site Discharge Limits                  10-20




             10.1.5.    Toxicity Reduction Evaluation                            10-20




      10.2.   PHYSICAL/CHEMICAL PROPERTIES                             10-21




             10.2.1.    Henry's Law Constant                                   10-21




             10.2.2.    Octanol/Water Partition Coefficient                        10-22




             10.2.3.    Water Solubility                                        10-22




             10.2.4.    Biodegradation                                         10-22




      10.3.   COMPOUND CLASSIFICATION                                  10-23




             10.3.1.    Volatile Organic Compounds                             10-23




             10.3.2.    Semivolatile Organic Compounds                         10-24




             10.3.3.    Pesticides and Herbicides                                10-24




             10.3.4.    PolychlorinatedBiphenyls                                10-26




             10.3.5.    Dioxins and Dibenzofurans                               10-26




             10.3.6.    Elements                                              10-26




             10.3.7.    Miscellaneous                                          10-26
                                           VI

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                                                                    TABLE OF CONTENTS
                                                                    ——'•""•	--"- —— •"-•"- "    • • • -^


11.   HYPOTHETICAL CASE STUDIES                                       11-1

      11.1. ACASE STUDY #1                                             ,::   11-1

             11.1.1.    Identify and Characterize CERCLA Wastewater              11-2
                       Discharge
             11.1.2.    Identify Potential Local POTWs                            11-2

             11.1.3.    Involve POTW in Evaluation Process and Screen             11-2
                       POTWs
          •       11.1.3.1.   Determine Compliance Status                           11-2

                 11.1.3.2.   Consider Technical Feasibility                     '     11-4

                 11.1.3.3.   Consider Administrative Feasibility                      11-5

             11.1.4.    Obtain/Estimate POTW Local Limits                       11-6

                 11.1.4.1.   Obtain Local Limits                •                t!li\l-6

                 11.1.4.2.   Estimate Local Limits.                           :'   "'11-6

             11.1.5.    Identify and Screen Pretreatment Alternatives             ilj 11-15

                 11.1.5.1.   Identify Pretreatment Technologies                     -11-15

            '     11.1.5.2.   Assemble Alternative Process Train Pretreatment          11-15

             11.1.6.    Detailed Analysis of Discharge Alternative                *  *11-15

      11.2.  CASE STUDY #2                                           :       11-16

             11.2.1.    Identify and Characterize CERCLA Wastewater              11-16
                       Discharge
             11.2.2.    Identify Potential Local POTWs                            11-18

            ~'l 1.2.3.    Involve POTW in Evaluation Process and Screen             11-18
                       POTWs
                 11.2.3.1.   Determine Compliance Status                           11-19
          f'                                             .
                 11.2.3.2.   Consider Technical Feasibility                          11-19

                 11.2.3.3.   Consider Administrative Feasibility                      11-19

             11.2.4.    Obtain/Estimate POTW Local Limits                       11-20

                 11.2.4.1.   Obtain Local Limits                                   11 -20
                                             vii

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TABLE OF CONTENTS
                11.2.4.2.  Estimate Local Limits
                                                                            11-21

             11.2.5.   Identify and Screen Pretreatment Alternatives               11-26

                11.2.5.1.  Identify Pretreatment Technologies                     11-26

                11.2.5.2.  Assemble Alternative Process Train Pretreatment         11-26

             11.2.6.   Detailed Analysis of the POTW Discharge Alternative        11-27

       11.3.  CASE STUDY #3                                                11 -27

             11.3.1.   Identify CERCLA Wastewater Discharge                   11-28

             11.3.2.   Characterize CERCLA Wastewater Discharge               11-28

             11.3.3.   Identify Potential Local POTWs                          11-30

             11.3.4.   Involve POTW in the Evaluation Process and Screen         11-31
                      POTWs

                11.3.4.1.  Determine Compliance Status                         11-31

                11.3.4.2.  Consider Technical Feasibility                         11-32

                11.3.4.3.  Consider Administrative Feasibility                    11-33

             11.3.5.   Conclusion                                            11-33

GLOSSARY

REFERENCES

APPENDICES
                                           vm

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LIST OF TABLES
TABLE    TITLE                                        PAGE NUMBER

2-1        MOST COMMON CONTAMINANTS DETECTED AT            2-2
          CERCLA SITES

2-2        COMMON CONTAMINANTS IN CERCLA SITE                2-3
          WASTEWATER

4-1        POTW COMPLIANCE CHECKLIST                        4-6

6-1        APPLICABILITY OF PRETREATMENT TECHNOLOGIES         6-2

7-1        SUMMARY OF CRITERIA FOR ANALYSIS OF THE            7-3
          DISCHARGE TO POTW ALTERNATIVE

10-1       BIOLOGICAL INHIBITION THRESHOLD - INORGANIC         10-4
          COMPOUNDS                                    ,  , ซ

10-2       BIOLOGICAL INHIBITION THRESHOLD - ORGANIC           10-8
          COMPOUNDS

10-3       BIODEGRADABELITY OF COMPOUNDS                    10-17

10-4       VOLATILE ORGANIC COMPOUND SUBCLASSES             10-25

11-1       CASE STUDY #1 - CONCENTRATIONS OF                   11-3
          POLLUTANTS DETECTED IN CERCLA SITE
          WASTESTREAM

11 -2       CASE STUDY #1 - EVALUATION OF TECHNICAL             11 -5
          FEASIBILITY OF CERCLA WASTESTREAM
          DISCHARGE TO IDENTIFIED POTWs

11 -3       CASE STUDY #1 - TREATMENT PROCESS AT POTW 4         11-7

11 -4       CASE STUDY #1 - MASS BALANCE FOR CERCLA             11-8
          WASTESTREAM CONTAMINANTS AT POTW 4

11 -5       CASE STUDY #1 - TREATABILITY OF CERCLA               11-11
          WASTESTREAM AT POTW 4

11 -6       CASE STUDY #1 - PRETREATMENT OPTIONS FOR            11-15
          CERCLA WASTESTREAM
                                   IX

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LIST OF TABLES
11-7       CASE STUDY #2-CONCENTRATION OF POLLUTANTS         1H7
          DETECTED IN CERCLA WASTESTREAM

11-8       CASE STUDY #2 - EVALUATION OF TECHNICAL              11 -20
          FEASIBILITY OF CERCLA WASTESTREAM
          DISCHARGE TO IDENTIFIED POTWS

11-9       CASE STUDY #2 - POTW 2 UNIT OPERATIONS               11-21

11-10      CASE STUDY #2 - TREATABILITY OF CERCLA               11-22
          WASTESTREAM AT POTW 2                        ;

11-11      CASE STUDY #2 - PRETREATMENT OPTIONS FOR             11-27
          CERCLA WASTESTREAM

11-12      CASE STUDY #3 - METALS AND CONVENTIONAL      *       11 -29
          POLLUTANT CONCENTRATIONS IN GROUNDWATER

11-13     , CASE STUDY #3 - ORGANIC CONCENTRATIONS IN            11-30
          GROUNDWATER

11-14      CASE STUDY #3 - SCREENING POTENTIAL POTWS -           11 -32
          CERCLA WASTESTREAM DISCHARGE AND
          TREATMENT - EVALUATING TECHNICAL               .
          FEASIBILITY                                      ;

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LIST OF FIGURES
                         V

FIGURE   r TITLE                                       PAGE NUMBER

ES-1       PROCESS FOR EVALUATING CERCLA DISCHARGES          ES-3
          TOPOTWs

1-1        PHASED RI/FS PROCESS                               1-2

1-2        PROCESS FOR EVALUATING CERCLA DISCHARGES          1-7
          TOPOTWs

2-1        CHARACTERIZING THE CERCLA WASTEWATER             2-4
          DISCHARGE

3-1        EVALUATING POTWs                                 3-2

5-1        OBTAINING POTW LOCAL LIMITS                 . '    ' : 5-2
6-1        PRETREATMENT PROCESS TRAIN FLOW                  6-6
          EQUALIZATION AND PHASE SEPARATION

6-2        PRETREATMENT PROCESS TRAIN METALS                 6-7
          TREATMENT

6-3        PRETREATMENT PROCESS TRAIN ORGANICS               6-8
          TREATMENT

6-4        PRETREATMENT PROCESS TRAIN POLISHING AND           6-9
          DISCHARGE

9-1        DETERMINATION OF RCRA HAZARDOUS WASTE            9-2
          STATUS

9-2        DETERMINATION OF GROUNDWATER AS RCRA             9-3
          HAZARDOUS WASTE

10-1       ESTIMATING POTW LOCAL LIMITS                       10-2
                                  XI

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                                            EXECUTIVE
                                            SUMMARY
6098-01

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EXECUTIVE SUMMARY
The purpose of this guidance manual is to provide
Feasibility Study (FS) writers, USEPA Remedial
Project Managers (RPMs), state officials, and
Publicly Owned Treatment Works (POTW)
personnel with the current regulatory framework
and technical and administrative guidance that is
necessary to evaluate the remedial alternative of
discharging wastes from  Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA) sites to POTWs. This
remedial alternative is to be evaluated and
compared to other alternatives developed in the
FS.

The POTW discharge alternative consists of
discharging untreated or pretreated wastes to a
POTW for treatment and disposal. Aqueous
wastes from CERCLA sites can constitute a
majority of waste treated  during remedial
clean-up efforts.  These wastes can include
groundwater, leachate, surface runoff, and other
aqueous wastes.

Currently, there are few CERCLA sites with
existing discharges to POTWs.  However, at the
sites that have negotiated and implemented a
discharge to a POTW, the success is largely due to
the parties involved possessing a good
understanding of the regulatory requirements and
performing a thorough technical and
administrative evaluation of the remedial
alternative.

USEPA's most comprehensive statement of
policy concerning discharge of CERCLA wastes
to a POTW was presented in a policy
memorandum, "Discharge of Wastewater from
CERCLA Sites into POTWs,"  dated April 15,
1986. The criteria outlined in the policy that must
be considered for evaluating the feasibility of
discharging CERCLA wastewater to a POTW are
as follows:
• The pollutants in the discharged
  CERCLA wastewater must not pass
  through, interfere, contaminate
  sludge, or become hazardous to
  employees at the POTW.

• The POTW must have legal
  authority and enforcement
  mechanisms to ensure compliance
  with applicable pretreatment
  standards and requirements.

• The POTW should have a good
  record of compliance with its
  National Pollutant Discharge
  Elimination System (NPDES)
  permit and pretreatment program
  requirements.

• The potential for volatilization of
  the wastewater contaminants and
  the potential for groundwater
  contamination from transport of
  CERCLA wastewater or
  impoundment at the POTW must be
  considered.

• The CERCLA wastewater
  discharge must not violate water
  quality standards in the POTW's
  receiving waters, including  the
  narrative standards of "no toxics in
  toxic amounts."

• The POTW must be knowledgeable
  of and in compliance with any
  applicable Resource Conservation
  and Recovery Act (RCRA) or other
  environmental statute
  requirements.
                                         ES-1

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JSXttCJUTJL VK SUMMARY
   •  The various costs of managing
      CERCLA wastewater, including all
      risks, liabilities, and permit fees,
      should be considered.

The "CERCLA Site Discharges to POTWs
Guidance Manual" presents a stepwise approach
to guide the manual user through a comprehensive
evaluation of the discharge to a POTW remedial
alternative, conforming to the USEPA April 15,
1986, Policy Memorandum. The manual is
organized so that the user can systematically
identify and review the various technical,
administrative, and regulatory issues in order to
screen the POTW discharge alternative.  If after
the initial screening of the alternative it appears
plausible, sufficient information to perform a
detailed evaluation of the POTW discharge
alternative is included and/or referenced in the
guidance manual.

The remainder of the Executive  Summary is a
general overview of the contents of each section of
the guidance manual.

Section 1.0 - Introduction. The introduction
states the purpose of the document and describes
how the material in the guidance manual is
organized to lead the user through a thorough and
expedient evaluation of CERCLA site discharges
to POTWs. Section 1.0 also provides an
overview   of   the   Remedial
Investigation/Feasibility  Study (RI/FS) process,
and discusses the important issues and criteria that
must be considered during the remedial
alternative evaluation, as well as issues related to
compliance with Applicable or Relevant and
Appropriate Requirements (ARARs).

In addition to the regulatory framework (NPDES
and Pretreatment) established under the Clean
Water Act (CWA), two USEPA policy
statements require a POTW to comply with
applicable regulations before accepting CERCLA
wastewater. These policy statements (i.e.,
USEPA's Off-site Policy and USEPA's April 15,
1986, policy memorandum entitled, "Discharge
of Wastewater from CERCLA Sites into
POTWs") are also summarized in Section 1.0.

Sections 2.0 through 7.0 discuss the six steps of
the process for analyzing the POTW discharge
alternative.  Figure ES-1 also shows major points
discussed in each section.

Sections 8.0 through 10.0 provide additional
information that will assist the RI/FS team during
development and evaluation of the POTW
discharge alternative.

Section 2.0 - Identify and Characterize
CERCLA Wastewater Discharge. To identify
and characterize a CERCLA discharge, the
quantity and quality of the discharge must be
estimated.  Section 2.0 describes how to evaluate
the site-specific CERCLA wastewater. Data
collection and evaluation requirements, definition
of the wastestream quality and quantity, and
determination of whether the CERCLA
wastestream is a RCRA hazardous waste are
discussed in  this section.  If the waste is
considered hazardous, it is subject to RCRA
Subtitle C regulations, and additional constraints
must be considered when determining whether the
waste can be  discharged to a POTW. These
constraints may make it more  difficult or
impractical  to discharge the CERCLA
wastestream  to a POTW.  Therefore, it is
important to determine early in the RI/FS process,
with confirmation of the lead agency, whether the
wastestream is a RCRA hazardous waste.

Section 3.0 - Identify Potential POTWs. Local
POTWs that may be potential receptors for
CERCLA wastewater need to be identified early
in the FS process. Section 3.0 identifies some of
the important technical and administrative criteria
that should be used to identify potential POTWs.
The economics of transporting  the waste (i.e., by
dedicated pipe, truck, rail, or sewer connection) to
a POTW and the compliance history of a POTW
will often serve as a first cut to identify acceptable
treatment facilities.
                                           ES-2

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                   SECTION 2i
iSECTION 3:
Identify and Characterize S -v;:.-:.
CERCLA ,*-;;- &Eซ;.
Wdslewafer Discharge jCir
• Identify the site-specific CERCLA
wastewater discharges
• Determine data requirements and
collect data to fulfill these
requirements
• Evaluate all available data to
. characterize wastewater
• Determine if the CERCLA
wastewater is a RCRA hazardous
waste


f -ilidentiry Local. POTWs \ ': J/i
I*--'' /-"V" ; •-" •• :':<;*j :::- -:;^"'^: '.'-'.'.- v -<.'4;^ii:
• Determine geographic area to be
considered
• IfCERCLAwastestreamisa
hazardous waste, determine if
Domestic Sewage Exclusion is
appliable. If not, determine Permit -
by - Rule requirements
• Consider methods of transporting the
wastestream to the POTW
• Identify potential POTWs and gather
information about each facility


-
•=*:>;5-,::.v: Involve POTW In f ne>:":ฃ:5Hf ?''"
:f ;:; & Evaluation^ Process ahiif *fvb"
31ito;ซ-:.Screeh POIWi :M^mmi.
• Contact the POTW to determine if
they are willing to accept a CERCLA
wastestream
• Investigate the compliance status of
the POTW
• Evaluate the POTWs ability to
handle and properly treat the
CERCLA wastestream '
• Evaluate the current permits of the
POTW and determine changes
required and other permits needed
• Address and discuss the POTWs
potential liability associated with
accepting a CERCLA wastestream


SECTION 5:
Evaluate Pretredfment
Requirements
• Pretreatment requirements (local
limits) should prevent pass through,
inhibition, and sludge contamination
at the POTW
• Obtain or estimate the local limits
enforced by the POTW to prevent
pass through, inhibition and sludge
contamination

• Compare CERCLA discharge
characteristics to local limits to
determine which contaminants
require pretreatment

















;:&>• :vyM SE:J:S?::;-l5>
• Identify possible pretreatment
technologies

• Develope a pretreatment process
train to properly pretreat the
CERCLA wastestream

























- -W -:il: & :.::SECf ION 7:
• f : -f:beiailed Analysis of the
iVi; U4 : ; POTW Discharge
: y:li;i;i:P:ii::i AftemaHve
Evaluate the POTW discharge
alternative using the following nine
criteria:

1. Overall protection of human health
and the environment
2. Compliance with ARARs
3. Long-term effectiveness and
permanence
4. Reduction of mobility, toricity, or
volume through treatment
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance

                                                                                           FIGURE ES-1
                                                     PROCESS FOR EVALUATING CERCLA DISCHARGES TO POTWs
6098-01

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EXECUTIVE SUMMARY
The Domestic Sewage Exclusion (DSE) and the
RCRA permit-by-rule requirements impact the
feasibility of discharging to a POTW. If the
CERCLA wastewater is a RCRA hazardous waste
and it must be transported by truck, rail, or
dedicated pipe to a POTW, the POTW is required
to be a RCR A-permitted or RCRA permit-by-rule
facility. However, if the wastewater is discharged
into the sewer system, the DSE may exclude the
POTW from the RCRA requirements. Instead,
these wastes would be regulated under the CWA
pretreatment program.

Section 4.0 - Involve POTWs in the Evaluation
Process and Screen POTWs. This section
emphasizes the importance of establishing contact
with personnel associated  with prospective
POTWs early in the FS process. Once a line of
communication has been established, prospective
POTWs can be screened efficiently by asking if
they are willing to accept the CERCLA
wastewater, determining the compliance status of
the POTW, and considering the technical and
administrative feasibility of discharging the
CERCLA wastewater to the POTW.

Section  5.0 - Evaluate  Pretreatment
Requirements. Another important step in
evaluating the CERCLA discharge to a POTW is
to determine whether the POTW can adequately
treat the site wastewater or whether pretreatment
is required. This step ensures that the site
discharge will not violate the goals of the National
Pretreatment Program by causing pass through,
inhibition, or sludge contamination at the POTW.
During this step, the POTW's pretreatment limits
must be obtained for each pollutant contained in
the CERCLA waste. If the POTW does not have
limits for each pollutant in the CERCLA waste,
the FS writer and the POTW can derive a
conservative estimate of pretreatment limits.
Section 5.0 also compares pretreatment limits to
the CERCLA site discharge to evaluate whether
pretreatment will be necessary.

Section 6.0 - Identify and Screen Pretreatment
Alternatives. If it is determined that the
CERCLA wastestream requires pretreatment
before discharging to a POTW, Section 6.0
describes how to evaluate and select an
appropriate pretreatment technology. Table 6-1
presents the application of various pretreatment
technologies for the major classes of compounds.
Pretreatment process trains are included for flow
equalization and phase separation, metals
treatment, organics treatment, and polishing and
discharge. Section 6.0 also describes how the
appropriate pretreatment technologies required to
treat the CERCLA waste can be assembled into a
pretreatment train.

Section 7.0 - Detailed Analysis of the POTW
Discharge Alternative.  The final phase of an FS
is to perform a detailed analysis of the most
promising remedial options that were identified
during the development/screening of alternatives.
If discharge to a POTW is being considered, the
viability of  treating a wastestream at the POTW
needs to be evaluated.                    ;

As required in Section 300.430(e)(iii) of the
National Contingency Plan, each remedial
alternative must be evaluated against the
following criteria: 1) overall protection of human
health and the environment; 2) compliance with
ARARs; 3) long-term effectiveness and
permanence; 4) reduction of mobility, toxicity, or
volume through treatment; 5) short-term
effectiveness; 6) implementability; 7) cost; 8)
state acceptance; 9) community acceptance.
Factors that should be considered specifically for
a POTW discharge with respect to each criterion
are listed in Table 7-1.

Section 8.0 - Clean Water Act and the National
Pretreatment Program. This section is a
synopsis of the regulatory framework under
which a POTW must operate. To date, specific
regulations (i.e., categorical pretreatment
standards) governing  the discharge of CERCLA
wastes to a POTW have not been promulgated.
However, CERCLA wastes are treated as
nondomestic wastestreams and, therefore, are
subjected to the general pretreatment regulations
                                          ES-4

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                                                               EXECUTIVE SUMMARY
promulgated under the CWA. Similar to other
nondomestic wastestreams, a CERCLA
wastewater discharge to a POTW may not be
accepted if itwill cause pass through, interference,
or exceedance of the general pretreatment
regulations, specific prohibitions, or local
pretreatment limits or ordinances.

Section 8.0 presents a brief overview of the
National Pretreatment  Program, NPDES
discharge permits, and other applicable
requirements under the CWA.  References for
detailed discussion of these regulations are
included in Section 8.0.

Section 9.0 - RCRA Requirements. RCRA
hazardous waste is defined in this section. Two
flow charts were developed to assist the manual
user in determining whether the site-specific
hazardous waste and/or contaminated
groundwater requiring treatment is a RCRA
waste. Exempted wastes are also described in
Section 9.0.

Section 10.0 - Estimate Pretreatment Limits.
In the event that pretreatment limits will have to be
obtained to complete the initial screening and
detailed analysis of the POTW discharge
alternative, a conservative approach to estimate
the limits is presented in Section 10.0. The
procedure requires the FS writer, RPM, state
official, and/or POTW authority to accumulate the
applicable regulatory requirements to evaluate the
acceptable concentrations that can volatilize,
partition to the sludge, and/or pass through the
POTW in the effluent.

A conservative mass balance approach that
focuses  on the three principal removal
mechanisms (i.e., volatilization, partitioning to
sludge, and biodegradation) is described to help
the user evaluate the fate and estimate the limits
for each contaminant in the CERCLA waste.
Once the probable fate of each compound in the
POTW has been determined, the impact to each
removal mechanism must be evaluated to
determine whether quality standards will be
exceeded. If it is determined that water, sludge,
and/or air quality standards will be exceeded by
discharging CERCLA wastewater to the POTW,
pretreatment of the CERCLA wastewater will be
required. This mass balance process must be
performed for each regulated pollutant detected in
the CERCLA wastewater.

Section 11.0 - Hypothetical Case Studies.
Three hypothetical case studies provide examples
of how to evaluate the POTW discharge
alternative using the approach presented in the
guidance manual. The case studies were
developed by  assigning a wastestream from an
actual CERCLA site, a hypothetical flow rate, and
a USEPA region to three different FS writers with
varying amounts of FS experience. With this
information, each case study writer was free to
choose a specific location of the site within the
assigned USEPA region and begin to make
contacts with the appropriate USEPA, state, and
local POTW authorities.

Appendices -  Appendices A and B present two
USEPA policies that may be useful in evaluating
a CERCLA site discharge to a POTW.  The two
policies are the USEPA off-site policy (USEPA,
1987f) and the USEPA policy on discharges from
CERCLA sites to POTWs (USEPA, 1986a)
(Appendices A and B, respectively).

Appendix C presents data generated from a
number of published studies on the total percent
removal of specific pollutants in biological
treatment systems. The data, to be used primarily
with Section 10, can be used to obtain an
estimated overall percent removal of specific
compounds.
                                          ES-5

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                                            SECTION 1
                                       INTRODUCTION
6091-01

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1.  INTRODUCTION
The POTW discharge alternative consists of
discharging untreated or pretreated CERCLA
aqueous wastes to a POTW for treatment and
disposal.  To more effectively develop and
evaluate this alternative, the administrative and
technical issues associated with discharging
CERCLA wastewater to a POTW must be clearly
identified.
1.1. THE REMEDIAL
    INVESTIGATION/FEASIBILITY
    (RI/FS) STUDY PROCESS

During an RI/FS, data defining site and waste
characterisitcs are collected and evaluated, and
specific site problems are identified (figure 1-1).
Based on the site characteristics and the potential
risks posed by the site, remedial alternatives are
developed and screened as necessary to focus on
the most promising options, and evaluated in
detail during the FS.

The criteria used to evaluate alternatives are:

   • Overall protection of human health
     and the environment

   • Compliance with Applicable or
     Relevant and Appropriate
     Requirements (ARARs)

   • Long-term effectiveness and
     permanence

   • Reduction of mobility, toxicity, or
     volume through treatment

   • Short-term effectiveness

   • Implementability

   • Cost
   • State acceptance

   • Community acceptance

Once the RI/FS is complete, a proposed plan is
prepared identifying EPA's preferred alternative
and made available for public comment. Once
comments have been received and considered,
EPA documents the final selection in a Record of
Decision (ROD). EPA is required under
CERCLA to select remedies that are 1) protective
of human health and the environment; 2) comply
with state and federal requirements that are
ARARs unless a waiver is justified; 3) is
cost-effective; and 4) utilizes permanent solutions
and alternative treatment technologies or resource
recovery technologies to the maximum extent
practicable.

The development and evaluation of alternatives
involving the discharge to a POTW may require
additional coordination with agencies and POTW
authorities, as well  as the technical analyses to
determine whether a POTW can accept the
discharge.
1.2. POLICIES THAT APPLY TO THE
    POTW DISCHARGE ALTERNATIVE

Aqueous wastes from CERCLA sites can
comprise a majority of waste treated during
remedial clean-up efforts. This waste can include
groundwater, leachate, surface runoff, and other
aqueous wastes. In addition, the selected remedy
may produce liquid wastestreams that require
remediation. For example, incineration of soil or
solid wastes produces scrubber effluent that must
be treated or disposed.

Currently, aqueous wastes at many CERCLA
sites are either treated on- or off-site at a Resource
Conservation and Recovery Act (RCRA)
treatment, storage, and disposal (TSD) facility.
                                           1-1

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                                                               REMEDIAL INVESTIGATION
10
FROM:

-PRELIMINARY
 ASSESSMENT

-SITE INSPECTION

-NPL LISTING
                           '  SCOPING
                           OF THE RI/FS
                       SITE PLANNING

                      -COLLECT AND ANALYZE
                       EXISTING DATA

                      - DEVELOP SITE
                       MANAGEMENT
                       STRATEGY

                      PROJECT PLANNING
-IDENTIFY INITIAL
 PROJECT/OPERABLE
 UNIT, LIKELY RESPONSE
 SCENARIOS &
 REMEDIAL ACTION
 OBJECTIVES

- INITIATE FEDERAL/
 STATE ARAR
 IDENTIFICATION

-IDENTIFY INITIAL DATA
 QUALITY OBJECTIVES
 (DQOs)

- PREPARE PROJECT
 PLANS
                                                      SITE CHARACTERIZATION
                            - CONDUCT FIELD INVESTIGATIONS

                            - DEFINE NATURE AND EXTENT OF
                            CONTAMINATION (WASTE TYPES.
                            CONCENTRATIONS. DISTRIBUTIONS)

                            - IDENTIFY FEDERAL/STATE
                            CONTAMINANT & LOCATION
                            SPECIFIC ARARs

                            -CONDUCT BASELINE RISK
                            ASSESSMENT

                            - DEFINE REMEDIAL ACTION GOALS
                                                                                     TREATABILITY
                                                                                    INVESTIGATIONS
                                                                                • PERFORM BENCH OR PILOT
                                                                                TREATABILITY TESTS AS
                                                                                NECESSARY
FEASIBILITY
   STUDY
                                                  DEVELOPMENT AND SCREENING OF ALTERNATIVES
                                                - IDENTIFY POTENTIAL
                                                 TREATMENT TECHNOLOGIES.
                                                 CONTAINMENT/DISPOSAL
                                                 REQUIREMENTS FOR
                                                 RESIDUALS OR UNTREATED
                                                 WASTE

                                                -SCREEN TECHNOLOGIES

                                                - ASSEMBLE TECHNOLOGIES
                                                 INTO ALTERNATIVES

                                                - IDENTIFY ACTION-SPECIFIC
                                                 ARARs
                                                                     - SCREEN ALTERNATIVES
                                                                      AS NECESSARY
                                                                      TO REDUCE NUMBER
                                                                      SUBJECT TO DETAILED
                                                                      ANALYSIS

                                                                     - PREPARE AN
                                                                      APPROPRIATE RANGE OF
                                                                      OPTIONS
                                                                                            DETAILED ANALYSIS
                                                                                            OF ALTERNATIVES
                   - FURTHER REFINE
                    ALTERNATIVES AS
                    NECESSARY

                   - ANALYZE ALTERNATIVES
                    AGAINST THE NINE CRITERIA

                   -COMPARE ALTERNATIVES
                    AGAINST EACH OTHER
TO:

-REMEDY SELECTION

- RECORD OF DECISION

- REMEDIAL DESIGN

-REMEDIAL ACTION
   SOURCE USEPA RI/FS GUIDANCE (USEPA, 1988c)
                                                                                                                             FIGURE 1-1
                                                                                                              PHASED  RI/FS  PROCESS

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                                                                       INTRODUCTION
However, another alternative for effective
treatment of CERCLA wastewaters may be to
^discharge them to one of the 15,000 POT Ws in the
U.S. Because many POTWs have excess capacity
and may be capable of treating some CERCLA
wastewater discharges, such an alternative may be
the most cost-effective method of disposal.

Before a CERCLA wastestream  can be
discharged to aPOTW, many legal, technical, and
administrative issues must be considered and
evaluated. In addition to the requirements under
federal environmental statutes, particularly the
Clean Water Act (CWA), two USEPA policies
affect the POTW discharge alternative:
(1) USEPA's Procedures for Planning and
Implementing Off-site Response Actions (40
CFR ง300.440 upon promulgation), and
(2) USEPA's policy memorandum entitled,
"Discharge of Wastewater from CERCLA Sites
into POTWs."

USEPA's Procedures  for Planning and
Implementing Off-site Response Actions (40
CFR ง300.440 upon promulgation). USEPA
has developed procedures that must be observed
when a response action under CERCLA involves
off-site management of CERCLA wastes. A
discharge to a POTW is generally considered an
off-site activity, even if CERCLA waste is
discharged to a sewer located on-site (USEPA,
1988a). Therefore, USEPA's Procedures for
Off-site Management of CERCLA Wastes (40
CFR ง300.440 upon promulgation) would
generally apply to a discharge of CERCLA waste
to a POTW.

Prior to proposing 40 CFR ง300.440, USEPA
issued "Guidance on the Requirements for
Selecting an Off-site Option in a Superfund
Response Action" in January 1983. This first
guidance required a facility inspection and that all
major violations at the facility be corrected in
order for the facility to receive CERCLA wastes
from remedial or removal actions.  In May 1985,
USEPA issued "Procedures for Planning and
Implementing Off-site Response Actions" (50 FR
45933), which detailed the criteria for evaluating
the acceptability of facilities to receive CERCLA
wastes.

In 1986, SARA affirmed USEPA's 1985 policy
for off-site transfer of CERCLA waste. SARA
Section 121(d)(3) provides that CERCLA
hazardous substances, pollutants, or contaminants
may only be transported to a facility operating in
compliance with Sections 3004 and 3005 of
RCRA and other applicable laws or regulations;
Section 121(d)(3) also provided that releases must
be eliminated or controlled at land disposal
facilities in order for those facilities to receive
CERCLA wastes. To implement this SARA
requirement, USEPA issued revised procedures
for implementing off-site response actions on
November 13, 1987, and provided detailed
procedures for issuing and reviewing
unacceptability determinations.

On November 9, 1988, "Procedures for Planning
and Implementing Off-site Response Actions"
were issued as a proposed rule. The general
requirements of the rule are similar to those of
USEPA's previous off-site policy, and will
supersede the policy when finalized.  The final
rule, expected to be issued in 1990, will amend the
National Oil and Hazardous Substances Pollution
Contingency Plan (40 CFR ง300) by adding a
new Section 300.440.

Generally, this policy requires that an off-site
facility accepting the waste have no relevant
violations, uncontrolled releases, or other
environmental conditions that pose a significant
threat to human health, welfare, or the
environment, or otherwise affect the satisfactory
operation of the facility. The purpose of the rule is
to direct these wastes only to facilities determined
to be environmentally sound and avoid having
CERCLA wastes contribute to present or future
environmental problems.
                                           1-3

-------
INTRODUCTION
Specific criteria are used to determine whether a
facility is acceptable to receive off-site transfers of
CERCLA waste, and to ensure that the waste will
be appropriately managed. The criteria generally
apply to RCRA Subtitle C TSD facilities, and to
other non-RCRA facilities. To the extent that
POTWs have a RCRA permit-by-rule, they may
be considered RCRA treatment facilities;
non-RCRA POTWs are considered "other
facilities." (See 40 CFR ง300.440 upon
promulgation.)

USEPA's Policy Memorandum - Discharges
from CERCLA Sites to POTWs.  In  this
USEPA memorandum, criteria are outlined that
should be considered in the RI/FS process for
evaluating the feasibility of discharging CERCLA
wastewater to a POTW (USEPA, 1986a). These
criteria were considered when developing the
stepwise evaluation process discussed in
Subsection 1.4. The criteria that must be
considered and the sections of the manual that
address them are as follows:

   • The quantity and quality of the
     CERCLA wastewater (the
     constituents in the wastewater must
     not cause pass through or
     interference, including
     unacceptable sludge contamination
     or a hazard to employees at the
     POTW) (Sections 2.0 and 5.0)

   • The ability (e.g., legal authority and
     enforcement mechanisms) of the
     POTW to ensure compliance with
     applicable pretreatment standards
     and requirements, including
     monitoring and reporting
     requirements (Subsections 4.2 and
     8.1.4)

   • The POTW's record of compliance
     with its National Pollutant
     Discharge Elimination System
(NPDES) permit and pretreatment
program requirements to determine
whether the POTW is a suitable
discharge option for CERCLA
wastewater (Subsection 4.2)

The potential for volatilization of
the wastewater contaminants at the
CERCLA site and POTW and its
impact on air quality (Section 7.0)

The potential for groundwater
contamination from transport of
CERCLA wastewater or
impoundment at the POTW, and the
need for groundwater monitoring
(Section 7.0)

The potential effect of the CERCLA
wastewater on the POTW's
discharge, as evaluated by
continued compliance with the
NPDES permit and by maintenance
of water quality standards in the
POTW's  receiving waters,
including the narrative standard of
"no toxics in toxic amounts"
(Section 5.0)

The POTW's knowledge,of and
compliance with any applicable
RCRA or other environmental
statute requirements (RCRA
permit-by-rule requirements may
be triggered if the POTW receives
CERCLA wastewaters classified as
"hazardous wastes" without prior
mixing with domestic sewage [e.g.,
direct delivery to the POTW by
truck, rail, or dedicated pipe].
CERCLA wastewaters are not
necessarily considered hazardous
wastes; case-by-case determination
has to be made.) (Subsection 4-2)
                                         1-4

-------
                                                                       INTRODUCTION
   • The various costs of managing
     CERCLA wastewater, including all
     risks, liabilities, and permit fees
     (Section 7.0)

To date, few CERCLA sites have discharged
wastestreams to POTWs for treatment. For some
sites, USEPA selected a remedial alternative that
included a CERCLA wastewater discharge to a
POTW; however, it was not implemented because
it was not -sufficiently evaluated in the FS.  The
reason that  these alternatives were  not
implemented is that prospective POTWs are
frequently not involved in the FS evaluation
process.

If a discharge is properly evaluated prior to
remedy selection and necessary negotiations are
conducted, the feasibility of discharging  to a
POTW can be accurately determined prior to final
selection of the site remedial action (i.e., signing
the ROD). The purpose of this manual is to guide
FS writers, USEPA Remedial Project Managers
(RPMs), state officials, and POTW officials in
evaluating potential discharges to POTWs during
anFS.
1.3.  COMPLIANCE WITH APPLICABLE
     OR RELEVANT AND APPROPRIATE
     REQUIREMENTS (ARARs)

The National Contingency Plan (NCP) (40 CFR
ง300.430[e]) and SARA Section 121(d)(2)(A)
require that CERCLA remedial actions at least
attain levels or standards of control that are legally
applicable to the contaminant concerned, or are
relevant and appropriate under the circumstances
of the release. Therefore, the POTW discharge
alternative must comply with ARARs, as defined
in the following subsections.

1.3.1. Applicable Requirements

Applicable requirements are those clean-up
standards, standards of control, and other
substantive environmental protection
requirements, criteria, or limits promulgated
under federal or state law that specifically address
a hazardous substance, pollutant, contaminant,
remedial action, location, or other circumstance at
a CERCLA site.

1.3.2. Relevant and Appropriate
      Requirements

Relevant and appropriate requirements (RARs)
are those environmental clean-up standards,
standards of control, and other substantive
requirements, criteria, or limitations promulgated
under federal or state law. While not
independently applicable to a hazardous
substance, pollutant, contaminant, remedial
action, location, or other circumstance at a
CERCLA site, they do address problems or
situations sufficiently similar to those
encountered at the CERCLA site, and their use is
well-suited to the particular site,  and may be
required under CERCLA. A requirement must be
both relevant and appropriate to be a RAR.

Only substantive requirements of other laws are
considered potential ARARs; permitting and
other administrative requirements are not required
for on-site CERCLA  actions (see SARA
121[e][l]). Off-site actions must comply with all
legally applicable requirements, both substantive
and administrative, as well as USEPA's
"Procedures for Planning and Implementing
Off-site Response Actions" (40 CFR ง300.440
upon promulgation). The concept  of "relevant
and appropriate" is not pertinent to off-site
actions.

In general, a discharge to a POTW is considered
an off-site activity. Therefore, CERCLA sites are
required to comply with substantive and
procedural requirements of applicable
regulations. If a remedial alternative involves
discharging CERCLA wastewater  to a POTW,
                                          1-5

-------
 INTRODUCTION
 applicable regulations that regulate such a
 discharge must be identified and evaluated.  The
 major applicable regulations that apply to
 discharges to POTWs involve regulations
 promulgated under the CWA and RCRA.

' The CWA, as implemented through the NPDES
 permit program, regulates discharges of
 pollutants or a combination of pollutants to U.S.
 waters from any point source. It requires the
 establishment of a permit containing applicable
 standards and requirements to control the
 discharge of pollutants to U.S. waters. A
 discharge to a POTW is considered an indirect
 discharge. The General Pretreatment Regulations
 (40 CFR ง403) and categorical pretreatment
 standards were developed by USEPA to control
 the discharge of pollutants into POTWs by
 categorical industrial users (e.g., leather tanning
 and metal finishing) and other nondomestic
 sources. The purpose of the pretreatment
 regulations and standards is to prevent the
 discharge of pollutants that pass through, interfere
 with, or are otherwise incompatible with the
 POTW. Local pretreatment programs developed
 by POTWs under the CWA are responsible for
 developing "local limits" on industrial user
 discharges to prevent pollutant pass through or
 interference, and for enforcing both local and
 national pretreatment standards andrequirements.

 RCRA deals with specific waste management
 activities. The Subtitle C requirements apply to
 hazardous waste management and regulate
 treatment, storage, and disposal of hazardous
 waste. RCRA requirements may be considered
 applicable when discharging RCRA hazardous
waste to a POTW, and may determine how the
waste must be handled (see Subsection 2.2.4 for
discussion of whether CERCLA wastewater is a
RCRA hazardous waste). The specific^
requirements of RCRA and CWA regulations and
other ARARs are discussed in Sections 8.0 and
9.0, and throughout this guidance manual.
1.4. GUIDANCE MANUAL
    ORGANIZATION

Issues concerning the discharge of CERCLA
wastestreams to POTWs must be carefully
evaluated during the RI/FS. To facilitate this
evaluation, a six-step process was developed to
lead the FS writer through a thorough and
expedient evaluation of CERCLA site discharges
to POTWs. This process was developed
considering the USEPA "Discharge of
Wastewater from CERCLA Sites into POTWs"
memorandum. The evaluation process and the
respective sections that present each step are
shown in Figure 1-2.

Sections 2.0 through 7.0 discuss the six steps of
the process for analyzing the POTW discharge
alternative. The remaining sections of the
guidance manual provide additional information
that will assist the RI/FS team during
development and evaluation of the POTW
discharge alternative.
                                          1-6

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SECTION 2:
Identity and Characterize
CERCLA
Wasfevrafer Discharge
• Identify the site-specific CERCLA
wastewater discharges
• Determine data requirements and
collect data to fulfill these
requirements
• Evaluate all available data to
characterize wastewater
• Determine if the CERCLA
wastewater is a RCRA hazardous
waste





SECTION 3:
Identify Local POTWs
• Determine geographic area to be
considered
• IfCERCLAwasteslreamisa
hazardous waste, determine if
Domestic Sewage Exclusion is
appliable. If not, determine Permit -
by - Rule requirements
• Consider methods of transporting the
wastestream to the POTW
• Identify potential POTWs and gather
information about each facility





SECTION 4:
Sft::V Involve POTW In the
*;;•--ฃ:ฅ Evaluation Process and
•Sซ?:i|:4:Sci'eeri PQWs
• Contact the POTW to determine if
they are willing to accept a CERCLA
wastestream
• Investigate the compliance status of
the POTW
• Evaluate the POTWs ability to
handle and properly treat the
CERCLA wasleslream
• Evaluate the current permits of the
POTW and determine changes
required and other permits needed
• Address and discuss the POTWs
potential liability associated with
accepting a CERCLA wastestream




m. ^SECTION 5;*?T" ^ :', ='
..lilllilva'iuaJe'^r^edtmenV "'; '-'^
5งiiJ;iS?;r:^ReqMlrerh9nt$ ::ir>.--',:: >?&:•
•jp?pK:;||4:::>s^';r:: .:^T--- '.':'• /M^JyU'K;
• Pretreatment requirements (local
limits) should prevent pass through,
inhibition, and sludge contamination
at the POTW
• ofctain or estimate the local limits
enforced by the POTW to prevent
pass through, inhibition and sludge
contamination
• Compare CERCLA discharge
characteristics to local limits to
determine which contaminants
require pretreatment















' "^ SECTION & p -;Kง
%:x.:; ซ;! •••! Identify and Screen -''isSM
:-&sl2 Pretreatment Alternatives g :i • y
ms-i ซ:H-
• Identify possible pretreatment
technologies

• Develope a pretreatment process
train to properly pretrcat the
CERCLA wastestream






•^












SECTION 7:
. Detailed Analysis of the
POTW Discharge
Alternative
Evaluate the POTW discharge
alternative using the following nine
criteria:

1. Overall protection of human health
and the environment
2. Compliance with ARARs
3. Long-term effectiveness and
permanence
4. Reduction of mobility, toxicity, or
volume through treatment
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
                                                                                          FIGURE 1-2
                                                    PROCESS FOR EVALUATING CERCLA DISCHARGES TO POTWs
6098-01

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-------
                                                                               SECTION 2
                                                  IDENTIFY AND CHARACTERIZE
                                         CE'RCLA WASTEWATER DISCHARGE
      Section 2: •••:..!
     ,:. iliientlfyarid '"<
    Characterize: CERCL A
    \' ;Wastewater , .
        Discharge
Section 3:
  Identify
Local POTWs
 Section 6:
Identify and Screen
  Pcetreannent
  Alternatives
  Section 7:
Detailed Analysis of
the POTW Discharge
   Alternative
         Identify and Characterize CERCLA
         Wastewater Discharge

            •  Identify the site-specific CERCLA
              wastewater discharges

            •  Determine data requirements and
              collect data to fulfill these requirements

            •  Evaluate all available data to characterize
              the wastewater

            •  Determine if the CERCLA wastewater is
              a RCRA hazardous waste
6098-01

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2.  IDENTIFY AND CHARACTERIZE CERCLA
    WASTEWATER DISCHARGE
Identification and characterization of a CERCLA
wastewater discharge are the first steps of the
evaluation process shown in Figure 1-1. In these
steps, the FS writer will define the quantity and
quality of the CERCLA discharge, as required by
the USEPA memorandum concerning discharge
to POTWs.  After the wastestream is
characterized, the FS writer should determine
whether it is a RCRA hazardous waste. A RCRA
hazardous waste is defined in  Section 9.0.
2.1. IDENTIFY THE CERCLA
    WASTEWATER DISCHARGE

When scoping the RI/FS, the RI/FS team should
identify wastewater streams that could be
discharged from the CERCLA site to a POTW.
Potential wastewater  streams may include
groundwater, leachate, surface runoff, or other
aqueous wastes that exist on-site, or process
streams generated by remedial activities.
Examples of process wastestreams include
scrubber effluent resulting from incineration of
soil or solid waste; wastewater from soil-washing
activities; and water used to decontaminate
equipment after remedial activities.

CERCLA wastewaters originate from a wide
variety of sources, and range from groundwater
with low levels of contamination to heavily
contaminated leachate and storage tank  contents.
The types of contaminants vary greatly among
sites and wastestreams. Table 2-1 lists the 18
contaminants most commonly found at CERCLA
sites, including chlorinated and aromatic
organics, as well as metals. Table 2-2 lists the
contaminants commonly found in 15 CERCLA
site wastewaters during 1987-1988 sampling for
the full Industrial Technology Division (ITD) list
of 443 analytes.
2.2. CHARACTERIZE THE CERCLA
    WASTEWATER DISCHARGE

After the potential wastestream(s) is identified,
the RI/FS team should characterize it in terms of
quality and quantity. Characterization consists of
the following steps:

   • Identification of data requirements ,
     considering data quality and
     analytical parameters

   • Collection of necessary data

   • Evaluation of data, including
     Applicable or Relevant and
     Appropriate Requirements
     (ARARs) analysis and risk
     assessment

   • Characterization of wastestream
     quality and quantity using results of
     the data evaluation

These steps are discussed in the following
subsections and shown in Figure 2-1.
2.2.1.  Data Requirements
Selecting the level of data quality to be achieved
and the analytical parameters to be investigated
are critical first steps to characterizing a
wastestream. In general, five levels of data
quality are employed in the RI/FS process. The
first level, field-screening data, uses portable
monitoring  equipment and provides the most
rapid results; however, it is usually qualitative
rather than quantitative.  Field analysis data (the
second level) are generated using mobile
analytical instruments. Depending on the
instruments  and environmental conditions, field
analysis data may be  either qualitative  or
                                         2-1

-------
IDENTIFY AND CHARACTERIZE CERCLA WASTE WATER DISCHARGE
                                       TABLE 2-1
           MOST COMMON CONTAMINANTS DETECTED AT CERCLA SITES
                               Trichloroethylene
                               Lead
                               Toluene
                               Chromium and Compounds
                               Benzene
                               Chloroform
                               Polychlorinated Biphenyls
                               1,1,1-Trichloroe thane
                               Tetrachloroethene
                               Zinc and Compounds
                               Cadmium
                               Arsenic
                               Phenol
                               Xylene
                               Ethylbenzene
                               Copper and Compounds
                               1,2-Trans-Dichloroethylene
                               Methylene Chloride
NOTES:

These contaminants were detected in soil, water, and other media at more than 10 percent of the 888 CERCLA sites for which
chemical data are available.

A more comprehensive table of contaminants detected at CERCLA sites, compiled in October 1986, is in "CERCLA Site
Discharges to POTWs Treatability Manual" (USEPA, 1990).
quantitative. The third, fourth, and fifth levels
involve laboratory analysis, but differ in the
analytical methods, quality control, and validation
procedures used. The third level is laboratory
analysis with less than Contract Laboratory
Program (CLP) quality.  The fourth level,
CLP-Routine Analytical Services, is usually used
for CERCLA sites and has more stringent quality
control and validation procedures. The fifth level
is CLP-Special Analytical Services for
nonstandard analytical methods. Because the
quality of the data determines its usefulness, the
category of data quality required for an RI/FS
should be carefully selected. "Data Quality
Objectives for Remedial Response Activities"
contains more guidance on data quality objectives
(USEPA, 1987a).

Analytical parameters should also be  carefully
selected when determining data requirements.
Under usual circumstances, CERCLA samples
undergo analyses for those compounds on the
Target Compound List (TCL). The TCL is a list
of 152 volatile and semivolatile  organic
compounds (VOCs and SVOCs), pesticides,
polychlorinatedbiphenyls (PCBs), and inorganics
                                           2-2

-------
                 IDENTIFY AND CHARACTERIZE CERCLA WASTEWATER DISCHARGE




                                        TABLE 2-2

              COMMON CONTAMINANTS IN CERCLA SITE WASTEWATER
QRGAMC'CONTAMINANT 	
•.** ' ^ % s •" "•
••..•• .>' . "•''•.".. , _ , , v v.
Trichloroethylene
Phenol
Acetone
Trans- 1 ,2-Dichloroethylene
Benzoic Acid
Tetrachloroethylene
Toluene
Benzene
Hexanoic Acid
Chlorobenzene
.. -,y •. s, v. **** ""
EMOROA^C CONTAMINANT — ;^ ' "
Zinc
Sodium
Manganese
Boron
Iron
Calcium
Barium
Aluminum
Magnesium
Titanium
-.-. -, -.-.V. ^^?ฃ>T?/!*1^t TSyWiT^V1 %-.% s •
jp f^l^ti JFt^ >.Q j^y v. X
"" v.1. ^^^
f •••.%
10
9
9
8
8
7
7
6
6
6.
%
FREQUENCY
14
14
14
14
14
14
13
13
13
12
NOTES:

These contaminants were commonly detected in the wastewaters (groundwater and/or leachate) of 14 CERCLA sites sampled
for the USEPA Industrial Technology Division List of Analytes during a 1987-88 sampling program.

The complete list of compounds detected in the wastewaters of 14 CERCLA sites, the frequency of occurrence, and the
concentration ranges detected is presented in "CERCLA Site Discharges to POTWs Treatability Manual" (USEPA, 1990).
                                            2-3

-------
               Data Requirements
              41 Determine level of
                 date quality  '

             , • Determine analytical^,
             ''  ^'parameters .
             ]•           -",:, --
                f  f       *       /
             ;• Consider pretreat-  "-
             "'••  •• mehtrequirements '>-:,?
                 aadNPDES permit I
              v%  conditions.      ';x
  Data Collection
  and Evaluation
 Sample and analyize
^ wastestream
             %   ^
 Determine if public
, liealth or environmental
, riskis^present  v
 Define Wastestream
• Determine quantity
  of wastestream as a
  function of timer
     'i          '  -   '+
• Determine quality of
  wastestream       ;
        '  '      ,
* Determine if CECLA
  wastestream is a RCRA
 - Hazardous Waste
;  '(See Section 9).
                                                                                                      FIGURE 2-1
                                                       CHARACTERIZING THE CERCLA WASTEWATER DISCHARGE
6098-01

-------
                IDENTIFY AND CHARACTERIZE CERCLA WASTEWATER DISCHARGE
used in the CLP tinder CERCLA. In addition,
POTWs usually require information about
conventional and nonconventional pollutants in
the wastestream (e.g., five-day biological oxygen
demand [BOD], chemical oxygen demand
[COD],  total suspended solids [TSS],
nitrite-nitrate, total Kjeldahl nitrogen, total
phosphorus, oil and grease, total dissolved solids,
color, total  sulfides, and pH). Applicable
pretreatment requirements and NPDES permit
conditions should be reviewed while designing
the analytical program.

2.2.2. Data Collection and Evaluation

After the data requirements are determined,
samples of the wastestream should be collected
and analyzed. The data should be validated and
evaluated for precision, accuracy,
representativeness, consistency, and
completeness.  In addition, for many CERCLA
wastestreams (e.g., groundwater  or surface
water), the RI/FS team must determine whether
the contaminants in the wastestream present a
human health or environmental risk at the site. If
the risk due to exposure to the wastestream is not
considered significant, no remediation of the
wastestream would be required. Risk evaluations
would include study of the extent of
contamination, determination of exposure
pathways, assessment of risk, and determination
of the need to remediate the wastestream.

2.2.3. Definition of Wastestream Quality
      and Quantity

After the data evaluation is completed, the waste
should be described in terms of quantity and
quality. Quantity should be considered as a
function of time (most POTWs will be interested
in daily average and daily maximum flows and in
batch discharges). Will the wastestream be
generated as a result of a one-time removal action,
or will it continue over time? If it will continue,
for how long, and will the quantity and quality
remain constant? To estimate quality, the RI/FS
team should carefully consider all available data,
and then use that  which will be most
representative of the future discharge.

When determining both quality and quantity, the
RI/FS team should carefully evaluate the accuracy
of the data. Accurate identification of specific
compounds and concentrations of compounds
detected is important when trying to determine
whether the POTW is technically capable of
handling and treating the waste. For example, if a
POTW has only 0.1 million gallons per day (mgd)
of available hydraulic capacity and a CERCLA
site wants to discharge 0.075 mgd, the POTW
would be hydraulically capable of accepting the
discharge. However, if the CERCLA site
discharge quantity is only estimated at 50 percent,
that quantity could be as high as 0.12 mgd, which
is greater than the POTW's available capacity.
Similarly, a poor estimate of the CERCLA
discharge water quality could cause biological
interference in the POTW and cause the POTW to
exceed its NPDES discharge limits.

2.2.4. Determine whether CERCLA
      Wastestream is a RCRA Hazardous
      Waste

After the quality and quantity of the CERCLA
discharge have been adequately characterized, the
RI/FS team (in conjunction with the lead agency)
should determine whether the waste is a RCRA
hazardous waste. If the waste is hazardous, it is
subject to RCRA Subtitle C regulations, and
additional constraints must be considered when
determining whether the waste can be discharged
to a POTW. These constraints may make it more
difficult or impractical to discharge the CERCLA
wastestream to a POTW.  Therefore, it is
important to determine early in the RI/FS process,
with the lead agency's agreement, whether the
wastestream is a RCRA hazardous waste. Section
9.0 provides guidance on determining whether a
CERCLA site discharge is a RCRA hazardous
waste.
                                          2-5

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-------
                                                              SECTION 3
                                       IDENTIFY LOCAL  POTWs
i Section.;3:. -
I ; Identify : •';!
I tocal EOTWs;
1 • ••-..'-.• f-:t:4i
X
"ffk
Section 4:
Involve POTW in the
Evaluation Process
and Screen POTWs


Section 5:
Evaluate
Pzetteatment
Requirements


Section 6:
Identify and Screen
Pretxeatment
Alternatives


Section 7:
Detailed Analysis of
the POTW Discharge
Alternative
Idenity Local POTWs

   • Determine geographic area to be considered

   • If CERCLA wastesneam is a hazardous waste
     determine if Domestic Sewage Exclusion is
     applicable, if not, determine Permit-by-Rule
     requirements

   • Consider methods of transporting the
     wastestream to the POTW

   • Identify potential POTWs and gather
     information about each facility

-------

-------
3.  IDENTIFY LOCAL POTWs
During the RI/FS scoping and site
characterization, local POTWs should be
identified. The first step in identifying candidate
POTWs is to determine the area that should be
considered. After the area is determined, POTWs
within it can be identified.
3.1. IDENTIFY THE AREA OF
    CONSIDERATION

There is no rule for determining an area within
which POTWs will be considered; it must be
determined on a site-by-site basis. Many factors
can affect such a determination. For example, if
few alternatives (other than disposal to the
POTW) for remediating the wastestream are
available, a greater area of consideration may be
selected. Because selection of an area of
consideration is site-specific, USEPA or another
authorized agency should be involved with the
selection.

Several factors should be considered when
evaluating POTWs at most sites, including the
following:

   • If the CERCLA wastestream is
     considered a RCRA hazardous
     waste, does the Domestic Sewage
     Exclusion (DSE) apply to the
     discharge of that waste to a POTW?

   • If the CERCLA wastestream is
     considered a RCRA hazardous
     waste and the DSE does not apply,
     does the POTW meet the RCRA
     permit-by-rule requirements?

   •Is it  technically  and
     administratively feasible to pipe or
     truck the CERCLA wastestream to
     a local POTW?
These factors are discussed in the following
subsections and a flowchart is presented in Figure
3-1 to show the evaluation process.

3.1.1. Applicability of the Domestic Sewage
      Exclusion

To determine the most feasible way to transport
CERCLA waste to a POTW, the FS writer should
consider whether the waste is regulated as a
RCRA hazardous waste and, if so, whether the
DSE would apply to the discharge of that waste to
a POTW.

Under 40 CFR ง261.4, the Domestic Sewage
Exclusion, domestic sewage and any mixture of
domestic sewage and other wastes that flow
through a sewer system to a POTW for treatment
are excluded from the definition of solid waste
and, therefore, would not be considered a
hazardous waste under RCRA. If a known RCRA
hazardous waste is mixed with domestic sewage
and this mixture flows through a sewer system to
a POTW for treatment, the mixture is excluded
from most RCRA requirements. This exclusion is
known as the Domestic Sewage Exclusion.

While the DSE extends to most wastes that reach
POTWs, it does not exempt wastes received
within the POTW's property boundary by truck,
rail, or dedicated pipeline. In addition, hazardous
waste cannot simply be introduced to sewers
outside the POTW property boundary; this would
violate RCRA manifesting regulations. These
regulations require that all hazardous waste must
be transported to designated RCRA facilities (i.e.,
those with RCRA permits). Although DSE
wastes are exempt from most RCRA
requirements, they are subject to applicable
pretreatment standards and requirements under
the Clean Water Act (CWA) (see Section 8.0).
                                          3-1

-------
                   Is the
                wastestream
                  aRCRA
                 hazardous
                  waste?
                  Does the
               omestic Sewage
              Exclusion apply ?
                (!••. wastestream
                I* not transported
               via truck or dedicated
                 pipe to POTW)
NO
      No RCRA requirements apply.
  Wastestream can be trucked or piped
        without a RCRA permit
 YES
  Wastestream sent to POTW via sewer
   system. No RCRA requirements for
             the POTW.
        Wastestream is a hazardous waste.
     POTW becomes a RCRA Permit - by - Rule
                    Facility
                    Does
                 the POTW
                 meet RCRA
               Permit - by -Rule
               Requirements?
 NO
  POTW must change procedures and/or
operations to meet RCRA Permit - by - Rule
 requirements to accept the wastestream.
                      YES
        POTW can accept the wastestream.
                                                                                 FIGURE 3-1
                                                                        EVALUATING POTWs
€09841
                                               3-2

-------
                                                             IDENTIFY LOCAL POTWs
3.1.2. RCRA Permit-by-Ruie Requirements
      for POTWs

If a POTW receives CERCLA wastewater that is
classified as a RCRA hazardous waste and that
waste is not covered by the DSE (i.e., direct
delivery to the POTW by truck, rail, or dedicated
pipe), the RCRA permit-by-rule requirements
will be triggered.  These requirements are
summarized as follows:

   • If a POTW is  operating under an
     NPDES permit issued before
     November 8,1984 (i.e., the date of
     enactment of the Hazardous and
     Solid Waste Amendments to
     RCRA), the following
     permit-by-rule requirements under
     40 CFR ง270.60(c) apply: (1) the
     POTW must  currently have an
     NPDES permit; (2) the POTW must
     be in compliance with its NPDES
     permit; (3) the POTW must comply
     with RCRA regulations regarding
     an identification number, use of a
     manifest system, identification of
     manifest discrepancies,  and
     reporting requirements; and (4) the
     waste received must meet all
     federal, state, and local
     pretreatment requirements  that
     would apply to the waste if it were
     discharged through a sewer, pipe, or
     similar conveyance (i.e., the same
     pretreatment  standards as if the
     DSE applied).

   • If a POTW is  operating under an
     NPDES permit issued or renewed
     after November 8, 1984, it must
     comply with the permit-by-rule
     requirements discussed in the
     preceding paragraph and corrective
     action requirements under 40 CFR
     ง264.101.
Some POTWs identified as potential receivers of
RCRA hazardous waste may be located so that the
waste must be shipped to the POTW by truck, rail,
or dedicated pipe and discharged. These POTWs
may need to be ruled out as potential discharge
options if they do not comply with the
permit-by-rule requirements; or if they are not
already a RCRA permit-by-rule facility and are
not willing to comply with the additional
requirements for such facilities.

Most POTWs are not RCRA permit-by-rule
facilities because they receive no hazardous
wastes by truck, rail, or dedicated pipe.
Therefore, if the CERCLA wastestream is
considered a RCRA hazardous waste, discharge to
the POTW by such means would create new
obligations for that POTW. The RI/FS team
should consider this issue when determining
whether transport by truck, rail, or dedicated pipe
is feasible and in selecting a reasonable area of
consideration.

3.1.3. Selection of an Appropriate
      Transport Technology

There is no rule for determining whether piping,
trucking, or rail transport is the more appropriate
way to transport a CERCLA wastestream to a
POTW. However, several factors can greatly
affect the cost of the transport technology,
including the following:

   • Area geology and topography

   • Need to obtain rights-of-way for
     road or pipeline construction

   • Wastestream quality characteristics
     (i.e., Is the stream a RCRA
     hazardous waste and will the DSE
     apply to the discharge of the waste
     to a sewer system?)

   • Distance to the POTW or its
     existing sewer lines
                                          3-3

-------
IDENTIFY LOCAL POTWs
   • Volumes of the CERCLA
     wastewater

   • Viscosity or percent solids of the
     CERCLA wastewater

Area geology should be considered; if bedrock is
shallow, it may require removal prior to pipe
placement. Also, topography would determine
whether the liquid could flow by gravity or a
pump would be necessary to force wastewater
through the sewer line. If the piping needs to
extend beyond property boundaries, or roads or
rail lines must be built prior to waste transport,
rights-of-way may be needed beforehand.


3.2.  IDENTIFY POTENTIAL POTWs

After transport options have been considered,
POTWs within the area should be identified.  In
addition, the authorities that administer the
NPDES program in the appropriate states should
be identified and contacted.  This authority will
either be the USEPA regional office or a state
                                              agency. States authorized to administer the
                                              NPDES and pretreatment programs within their
                                              jurisdiction are listed in "CERCLA Site
                                              Discharges to POTWs Treatability Manual"
                                              (USEPA, 1990).

                                              The NPDES authority (state or federal) can help
                                              identify potential POTWs, and can provide
                                              additional information (e.g., the level of
                                              treatment, capacity, operating history, and
                                              collection system) that will be helpful for
                                              screening the POTWs (see Section 5.0).  In
                                              addition, USEPA Headquarters generates a
                                              Quarterly Noncompliance Report, which includes
                                              a listing of the POTW facilities that are in
                                              significant noncompliance each quarter. This
                                              document does not list all the facilities that have
                                              violated daily maximum limits; therefore, it
                                              should not be relied upon as a complete
                                              compliance screening tool.

                                              At this stage in the evaluation, the RI/FS team
                                              should compile a list of potential POTWs and the
                                              information available concerning each one.
                                          3-4

-------
                                          SECTION 4
    INVOLVE POTW IN THE EVALUATION
            PROCESS AND SCREEN PQTWs
Section 2:
Identify and
Characterize CERCLA
Wastewater
Discharge


Section 3:
Identify
Local POTWs
Involve-POTW In the
 Evaluation Process
 and Screen POTWs
    Involve POTW In the Evaluation
    Process and Screen POTWs
        Contact the POTW to determine if they are
        willing to accept a CERCLA wastestream
        Investigate the compliance status of the POTW
        Evaluate the POTWs ability to handle and
        properly treat the CERCLA wastestteam
        Evaluate the current permits of the POTW and
        determine changes required and other permits
        needed
        Address and discuss the POTW's potential
        liability associated with accepting a CERCLA
Section 5:
Evaluate
Pielieaonent
Requirements


Section 6:
Identify and Screen
Pntreatment
Alternatives


Section 7:
Detailed Analysis of
the POTW Discharge
Alternative

-------

-------
4.  INVOLVE POTW IN THE EVALUATION PROCESS AND
    SCREEN POTWs
Once potential POTWs have been identified, the
RI/FS team should contact the municipal
authority responsible for technical and
administrative oversight of each POTW to gather
specific information. This information will be
used to screen the list of potential POTWs. The
POTW screening process should consider the
following information:

   • Whether the POTW is willing to
     accept CERCLA discharges

   • Compliance status of the POTW

   • The technical feasibility of
     discharging the  CERCLA
     wastewater to the POTW

   • The administrative feasibility of
     discharging the  CERCLA
     wastewater to the POTW

If possible, screening of POTWs should be
conducted during the site characterization phase
of the RI/FS process. POTW screening and
involvement are discussed in the following
subsections.
4.1. COMPLIANCE STATUS OF POTWs

One factor that should be considered in the initial
screening of a POTW is its compliance status.
USEPA regulations prohibit sending CERCLA
wastewater to POTWs not in compliance with the
Clean Water Act (CWA) and other applicable
laws.  Based  on review of the POTW's
compliance history, the POTW may be
determined an unacceptable receptor of CERCLA
wastewater. Two USEPA policies previously
described discuss procedures for determining
whether a POTW may accept CERCLA
wastewater: (1) USEPA's Procedures for
Planning and Implementing Off-site Response
Actions (40 CFR ง300.440 upon promulgation),
and (2) USEPA's policy memorandum entitled,
"Discharge of Wastewater from CERCLA Sites
into POTWs."

40 CFR ง300.440 (upon promulgation) describes
procedures that must be observed when a
CERCLA response action involves off-site
management of CERCLA  waste. The regulation
prohibits the transfer of CERCLA wastewater to a
POTW if USEPA has information indicating that
there are releases from the POTW that pose a
significant risk to health.  Regional off-site
coordinators have been established in each region
to collect available information on the
acceptability status of potential receiving
facilities. In addition, criteria for evaluating
whether to send CERCLA waste specifically to a
POTW are discussed in a USEPA-issued
memorandum entitled, "Discharge of Wastewater
from CERCLA Sites into POTWs." This
memorandum states that full compliance with all
applicable requirements of CWA and RCRA is
necessary (e.g., including monitoring and
reporting requirements).

According to USEPA's policy memorandum, if
the discharge of CERCLA wastes to a POTW is
being considered, the following points pertaining
to compliance status should be evaluated:

   • The ability (e.g., legal authority and
     enforceable mechanisms) of the
     POTW to ensure compliance with
     applicable pretreatment standards
     and requirements,  including
     monitoring and reporting
     requirements
                                         4-1

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INVOLVE POTW IN THE EVALUATION PROCESS AND SCREEN POTWs
   • The POTW's record of compliance
     with its NPDES permit and
     pretreatment program requkements

   • The POTW's knowledge of and
     compliance with any applicable
     RCRA requirements or other
     environmental statutes

   • The potential for groundwater
     contamination from transport of
     CERCLA wastewater to an
     impoundment at the POTW

As stated in the memorandum, POTWs under
consideration as potential receptors of CERCLA
wastewaters may include those POTWs either
with or without an approved pretreatment
program. POTWs with an approved pretreatment
program are required to have mechanisms
necessary to ensure compliance by industrial
users with applicable pretreatment standards and
requirements. POTWs without an approved
pretreatment program must be evaluated to
determine whether sufficient mechanisms exist to
enable the POTW to ensure compliance with
national general pretreatment requirements,
which prohibit discharges that would cause pass
through or interference (i.e., develop, monitor
compliance, and enforce local limits).  (The
pretreatment program requirements are discussed
in more detail in Section 8.0.) Therefore, the
POTW must clearly demonstrate that its
operations are in compliance and that it will
continue to operate in an environmentally sound
manner.

If a POTW receives RCRA-defined hazardous
waste in a case when the DSE would not apply, it
is subject to RCRA permit-by-rule facility
requirements.  In accordance with the RCRA
requirements, these facilities will be inspected as
appropriate.

To determine the ability of a non-RCRA
permit-by-rule POTW to accept CERCLA waste
when the DSE does not apply, a compliance check
may be performed during the FS by identifying
the POTW's operations and responsibilities (e.g.,
direct discharges, sludge management and
disposal, pretreatment enforcement, and
hazardous waste treatment), and the regulations
applicable to those activities.  The checklist in
Table 4-1, which should be used to determine a
POTW's compliance status, includes a synopsis
of potentially applicable requirements. Because
USEPA routinely updates and modifies
regulatory requkements for POTWs, the checklist
should be considered only a preliminary tool for
assessing POTW compliance, to be supplemented
by a review of recent regulatory amendments.
Answers to the compliance checklist questions
may be ascertained through (1) interviews with
the POTW personnel; (2) documents such as the
facility's permit applications and permits; and
(3) file reviews to determine compliance history
at appropriate USEPA and state offices.

The RI/FS team should use the compliance
checklist as a preliminary guide to determining
whether a POTW is in compliance with applicable
environmental laws. The lead agency should be
involved in this determination, especially because
many of the compliance issues are not clear cut
and require interpretation.
4.2. TECHNICAL FEASIBILITY

In the first step, the POTW should be screened to
determine whether it can technically accept the
waste. This determination should be made using
information gathered during contacts with the
POTW, as well as information on the quantity and
quality of the CERCLA wastestream. This step
will serve as a screening step prior to further
contact with  the POTW.  During this
determination, the following questions should be
considered:

   • Is the POTW willing to accept the
     CERCLA discharge?
                                          4-2

-------
                 INVOLVE POTW IN THE EVALUATION PROCESS AND SCREEN POTWs
   • Does the POTW have the hydraulic
     and organic load capacity to accept
     the CERCLA waste?

   • Are  the POTWs unit operations
     suitable for treatment of contaminants
     in the CERCLA wastestream?

   • If the CERCLA wastestream will be
     discharged to a sewage collection
     system, is that system separate from
     or combined with the storm drain
     system, and will that system provide
     proper containment of the
     wastestream?

   • Are there combined sewer overflows
     between the site and the POTW?

   • Are the capacity and age of the sewer
     piping system adequate for the
     CERCLA discharge flow rate?

   • Which sludge disposal processes are
     currently employed by the POTW?

   • Is it likely that the POTW could treat
     the CERCLA wastestream for the
     duration required?

   • Are there any other technical reasons
     why the POTW could not accept the
     CERCLA wastestream?

If the RI/FS team, USEPA Remedial Project
Manager (RPM), and POTW authority believe the
POTW is technically capable of accepting the
CERCLA wastestream, the POTW should be
retained for further consideration.
4.3. ADMINISTRATIVE FEASIBILITY

After a POTW is determined to be in compliance
with its NPDES permit, capable of ensuring
compliance with applicable pretreatment standards
and requirements, and technically capable of
accepting the waste, it should be screened to
determine whether acceptance of the CERCLA
waste is administratively feasible. Early in this
preliminary evaluation process, the RI/FS team will
have to determine whether the POTW is willing and
able to accept the CERCLA wastestream. These
negotiations should include the POTW authority
and USEPA and/or state agency representatives,
and the following information should be discussed
with the POTW:

   • A description of the CERCLA site
     history and wastestream
     characteristics

   • A summary of the information about
     the POTW and POTW screening
     results to date

Based on this information, the POTW authority
must determine whether it is willing to accept the
CERCLA waste and,  if so, whether there are any
additional issues the POTW should resolve before
further discussions. If a POTW is willing to accept
CERCLA wastes, the FS writer may wish to include
a member of its staff on the FS technical review
committee.

During the screening  of POTWs, several
administrative issues must be considered, such as
obtaining or changing permits, delays associated
with the permitting process, restrictions imposed by
local ordinances, and  a POTW's unwillingness to
accept CERCLA wastewater due to potential
liabilities associated with it. These issues are
discussed in the following subsections.

4.3.1.  Permitting Process

POTWs are required to notify the regulatory agency
issuing NPDES permits in its state of any new
introduction of pollutants to the POTW by an
indirect discharger (40 CFR  ง122.42[b]).  If a
CERCLA indirect discharge (to a POTW) contains
a pollutant not previously limited in the POTW's
NPDES permit, the NPDES permit may require
                                          4-3

-------
 INVOLVE POTW IN THE EVALUATION PROCESS AND SCREEN POTWs
modifications. Also, the POTWs pretreatment
program may need to be revised to regulate the new
pollutant or increased discharges of previously
limited pollutants. If permitting changes are
substantial, discharging to the POTW may be
deemed inappropriate either because the POTW is
unwilling to have the changes made to its permit or
pretreatment program, or because the changes
cannot be made in a timely manner.

4.3.2.  Local Ordinances

Local ordinances should also be reviewed in
evaluating the possibility for discharging CERCLA
wastewaters to POTWs. An ordinance may permit
only domestic discharges to the POTW. The town
where the POTW is located may have contracts to
accept waste only from specific neighboring towns.
The municipality may restrict groundwater or
surface water runoff. Restrictions should be
identified and local officials contacted to determine
whether the restrictions apply to the  CERCLA
discharge or whether a variance to the ordinance
may be obtained.

4.3.3.  Potential Liability Associated with
       Accepting CERCLA Wastes

Another major administrative issue is the liability
associated with accepting CERCLA waste.
Potential liabilities should be identified and
discussed with the POTW during negotiations, and
steps that may be taken to minimize potential
liability.

Under CERCLA, Section 107, whenever there is a
release or threatened release of a hazardous
substance(s), the responsible parties can be held
liable for the costs of cleanup of that release.
Responsible parties may include current owners and
operators of a facility, owners and operators of the
facility at the time of  the release, persons who
transported the hazardous substances and selected
the disposal facility, waste generators, and persons
who arranged for disposal or treatment of the
hazardous substances. However, "federally
permitted releases" are not subject to such liabilities
(CERCLA 107[j]).

In the proposed rule for "Reporting Exemptions for
Federally Permitted Releases of Hazardous
Substances" (Federal Register. July 1088), USEPA
clarified this exemption for CERCLA release
liability provisions. Under these proposed
regulations, "federally permitted releases" would
include the following:

    • Discharges covered by an NPDES
     permit, permit application, or permit
     administrative record

    • The introduction of any pollutant into
     a POTW when such pollutant is
     specified in and in compliance with
     pretreatment standards and a
     pretreatment program has been
     submitted to USEPA for approval

If a categorical pretreatment standard or a local limit
were absent for a specific pollutant, discharge of that
pollutant to a POTW would not be considered a
"federally permitted release" and, therefore, would
not be exempted from CERCLA liability or
reporting provisions according to this proposed
rule. Therefore, the POTW should identify all
possible hazardous substances likely to be received
and establish local limits for these substances. This
will avoid the possibility of non-federally permitted
releases and the associated liabilities.

In addition, to qualify for this exemption, the POTW
must have a local pretreatment program approved
by the approval authority or a state-implemented
pretreatment program approved for the specific
POTW. In addition to liability under CWA,  a
POTW would be subject to CERCLA reporting and
liability provisions if its discharge of a hazardous
substance violates its NPDES permit, as defined in
CERCLA Section 102.

It should be made clear to the POTW accepting the
waste that compliance with the requirements of the
proposed rule (and final rule when issued) for
reporting exemptions and compliance with the
                                           4-4

-------
                 INVOLVE POTW IN THE EVALUATION PROCESS AND SCREEN POTWs
NPDES permit terms and conditions may protect
against liability. Additionally, the POTW may
arrange with a potentially responsible party to cover
any financial liability that may be incurred due to the
POTW accepting a CERCLA wastestream.

4.3.4,  Indemnification

Another administrative issue, which is related to
liability and should be discussed with the POTW, is
indemnification. SARA Section 119 authorizes
indemnification from liability to response action
contractors. However, under SARA Section
119(c)(5)(D), indemnification cannot be provided
tc- facilities regulated under RCRA, including
RCRA permit-by-rule POTWs.

POTWs not subject to RCRA regulations (i.e.,
POTWs without a RCRA permit or permit-by-rule)
are not explicitly prohibited from USEPA
indemnification authority under Section 119.
However, according to the "USEPA Interim
Guidance on Indemnification of Superfund
Response Action Contractors under Section 119 of
SARA" (USEPA, 1987e), USEPA has determined
that an extension of indemnification to any POTW
would not be consistent with Congressional intent in
Section 119. Therefore, USEPA will not provide
indemnification to POTWs under Section 119
authority.

After all potential POTWs have been screened and
the appropriate ones contacted, the RI/FS team
should compile a list of those able and willing to
accept the waste, and issues that would require
resolution.
                                          4-5

-------
                                                       TABLE 4-1
                                           POTW COMPLIANCE CHECKLIST
                      (Consult Appropriate Regulations for Amendments and Additions to These Rules)

Direct Discharges

1.   Is the POTW in compliance with its  CWA-NPDES
    NPDES permit, or has the POTW    Regulations (40 CFR
    been reported in a recent Quarterly   ง 122,125)
    Noncompliance Report (QNCR)?

2.   Is the POTW in compliance with     State Discharge
    state discharge requirements?        Permit Programs
                      If the POTW discharges wastewater into U.S. waters, an NPDES
                      permit is required. Specific requirements include compliance with
                      effluent limitations based on secondary treatment requirements and
                      any water quality standards, establishment of a discharge monitoring
                      system, and routine reporting of the discharge monitoring results.*
                      Some states have permit programs that are part of the NPDES system.
Sludge Management/Hazardous Waste'
Management

3.  If the POTW disposes of the sludge
    on land, does it violate standards
    for PCBs, cadmium, and
    pathogens in the sludge?
RCRA - Criteria for
Classification of
Solid Waste Disposal
Facilities and
Practices (40 CFR
ง257)
These criteria provide guidelines for sludge utilization and disposal
under Section 405(d) of the CWA. To comply with Section 405(e),
the owner/operator of a POTW must not violate these criteria when
disposing of sludge on land. Standards have been promulgated for
pathogens applied to the land surface or incorporated into the soil, and
for cadmium and PCBs when applied to land used for production of
food-chain crops.
* If a POTW is operating under an expired permit, the conditions of the permit normally continue in force until the effective date of a new permit. Most NPDES per-
mits provide for such extensions, unless this would violate state law (in those states authorized to administer the NPDES program). Therefore, a CERCLA site could
discharge to a POTW that has an exoired permit, if the POTW has received an extension nermissible under state law and is in comnliance with the extended oermit.

-------
                                                      TABLE 4-1
                                                      (continued)
                                          POTW COMPLIANCE CHECKLIST
Sludge Mngmt/Hazardous Waste Mngmt
(continued)

3. (continued)
4.   If the pollutants regulated by
    NESHAPS are present in the
    POTW's sludge, and the sludge is
    stored in piles, dried, and/or
    incinerated, do the air emissions
    violate the standards?
5.   If pollutants regulated by National
    Ambient Air Quality Standards
    (NAAQS) are present in the
    POTW's sludge, and the sludge is
    stored in waste piles and/or
    incinerated, do the air emissions
    violate the standards?
CAA - National
Emission Standards
for Hazardous Air
Pollutants
(NESHAPS) (40 CFR
ง61)
CAA - National
Ambient Air Quality
Standards (40 CFR
ง50)
If the POTW operates its own solid waste disposal facility for sewage
sludge disposal, the solid waste disposal facility must also meet the
general environmental performance standards set forth in 40 CFR
ง257. These criteria currently include sewage sludges from POTWs.
However, USEPA is currently developing specific standards for
managing POTW sewage sludge (40 CFR ง503) (see No. 20), and
may amend Section 257 to exclude POTW sewage sludge from its
requirements.
Windblown particulates, mercury and beryllium, from sludge piles and
stack emissions from sludge incinerators may be regulated by
NESHAPS, depending on the pollutants present and processes
involved.
EPA has promulgated NAAQS for six pollutants: paniculate matter
equal to or less than 10 microns particle size, sulfur dioxide, carbon
monoxide, ozone, nitrogen dioxide, and lead.  These standards are
national limitations on ambient concentration. Different requirements
will be triggered depending on whether the source is located in an
attainment or non-attainment area. The standards only apply to "major
sources" (i.e., emits 250 or more tons of any regulated pollutant per
year).  .

-------
                                                      TABLE 4-1
                                                      (continued)
                                          POTW COMPLIANCE CHECKLIST
Sludge Mngmt/Hazardous Waste Mngmt
(continued)
6.
If the sludges contain PCBs greater TSCA - Storage and    Incinerators burning sludges that contain PCBs in amounts greater
than 50 ppm, are they properly      Disposal (40 CFR      than 50 parts per million (ppm) must be in compliance with specific
disposed of?                     ง761.60-761.79)      design and operational requirements of TSCA.
    If the POTW incinerates its sludge
    and is subject to the provisions of
    40 CFR ง60, Subpart 0, do the air
    emissions violate standards for
    paniculate matter and/or opacity?
                                 CAA - Standards of
                                 Performance for
                                 Sewage Treatment
                                 Plants, Standards for
                                 Paniculate Matter (40
                                 CFR ง60.152)
8.
If the POTW incinerates its sludge
and is subject to No. 7, does it
conduct the appropriate air
monitoring?
                     These requirements apply to sewage sludge incinerators that combust
                     wastes containing more than 10-percent sewage sludge (dry basis) or
                     incinerators that charge more than 1,000 kg/day municipal sewage
                     sludge (dry basis). Facilities under this description must have
                     commenced construction or modification after June 11,1973, to be
                     subject to the requirements. A sewage sludge incinerator shall not
                     discharge into the atmosphere paniculate matter at a rate in excess of
                     0.65 grams/kg dry sludge input nor any gases which exhibit 20-percent
                     opacity or greater.
CAS - Monitoring of   The owner or operator of a sludge incinerator subject to these
Operations (40 CFR    provisions must conduct the appropriate monitoring.
ง60.153)

-------
                                                    TABLE 4-1
                                                    (continued)
                                         POTW COMPLIANCE CHECKLIST
                                   APPLICABLE    ;  ^-V     .      ,    :    ••  r  ',\ ,, '  ,    -
                       Wf-^ > -. < "I " REQUIREMENT '^' > RlQtimEMENT SYNOPSIS,' ' >," *  *  :- <. ,
Sludge Mngmt/Hazardous Waste Mngmt
(continued)
9,   If the POTW dumps its sludge into
    ocean waters, does it violate any
    prohibitions, limits, or conditions
    set by its permit, or does it contain
    any of the constituents at certain
    concentrations prohibited from
    dumping?
MPRSA-Criteria for
the Evaluation of
Permit Applications
for Ocean Dumping
of Materials (40 CFR
ง227)
                                   US Code - Title 33,
                                   Navigation and
                                   Navigable Waters
                                   (1989 Cumulative
                                   Annual Pocket Part,
                                   Section 1414b.)
This regulation constitutes the criteria for the issuance of ocean
disposal permits after consideration of the environmental effect of the
proposed dumping operation.  Specifically, materials containing the
following constituents, other than trace contaminants, are prohibited
from ocean dumping: organohalogen compounds, mercury and
mercury compounds, cadmium and cadmium compounds, oil, and
known or suspected carcinogens, mutagens, or teratogens. In addition,
wastes may only be ocean dumped so as not to exceed the limiting
permissible concentration (LPC).
Section 1414b, ocean dumping of sewage sludge and industrial waste
prohibits the issuance of permits to dump sewage sludge at sea, except
to persons who were authorized by a permit or court order. It also
renders it unlawful to dump sewage sludge at sea by any person after
December 31,1991.

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CONSIDERATION BEFORE
DISCHARGING TO POTW   J

Sludge Mngmt/Hazardous Waste Mngmt
(continued)

10. Is the POTW sludge and/or
    wastewater considered a
    hazardous waste?
                                                   TABLE 4-1
                                                   (continued)
                                        POTW COMPLIANCE CHECKLIST
APPLICABLE
REQUIREMENT  I  REQUIREMENT SYNOPSIS   \t.
 11. If the POTW generates hazardous
    wastes, does it have a USEPA
    identification number?
 12. Does the POTW properly manifest
    its hazardous waste?
RCRA - Standards
Applicable to
Generators and
Hazardous Wastes,
Hazardous Waste
Determination (40
CFR ง262.11)
RCRA- USEPA
Identification (40
CFR ง262.12)
RCRA - Manifest
Requirements (40
CFR ง262.20 -
262.23)
POTW sludge and/or wastewater may be RCRA hazardous waste if it
exhibits a hazardous characteristic or is derived from the treatment of a
mixture (see 40 CFR ง261.3[a]2) of listed hazardous waste received
by truck, rail, or dedicated pipe and other sewage or waste.
If the POTW produces hazardous wastes, including sludges that are
hazardous, the POTW must notify USEPA of its activities and obtain a
USEPA identification number.
If hazardous waste is shipped off-site, the shipments must be
accompanied by a uniform hazardous waste manifest. The manifest
provides the mechanism for tracking hazardous wastes.  A POTW
must also complete manifests as the recipient of hazardous waste sent
to it by truck, rail, or dedicated pipe. The procedures to follow in
using the manifest are outlined in 40 CFR ง262.22 and 262.23.

-------
                                                    TABLE 44
                                                    (continued)
                                         POTW COMPLIANCE CHECKLIST
CON$fl)ERATI0$ BEFORE
DISCHARGING TO P0TW.  v
                                   APPLICABLE-/'
                                   REQUIREMENT :
Sludge Mngmt/Hazardous Waste Mngmt
(continued)

13.  Are hazardous wastes packaged in
    the manner prescribed for the
    specific material in accordance
    with Department of Transportation
    (DOT) and RCRA regulations?

14.  Are containers holding hazardous
    wastes labeled with the labels
    prescribed for the material as
    specified in DOT and RCRA
    regulations?

15.  Does the POTW accumulate
    hazardous wastes for 90 days or
    less before the waste is picked up
    by a licensed transporter? If not,
    does the POTW generate less than
    1,000 kg/month of waste, transport
    it more than 200 miles, or have a
    RCRA storage permit?
                                   RCRA - Pre-transport
                                   Requirements (40
                                   CFR ง262.30 -
                                   262.34); DOT
                                   Regulations (49 CFR
                                   ง171-179)
                                   RCRA - Pre-transport
                                   Requirements (40
                                   CFR ง262.30 -
                                   262.34); DOT
                                   Regulations (49 CFR
                                   ง171-179)
                                   RCRA - Pre-transport
                                   Requirements (40
                                   CFR ง262.30 -
                                   262.34)
The POTW must assure that hazardous wastes are shipped in proper
containers, are accurately marked and labeled, and the transporter is
provided with the proper placards.
The POTW must assure that hazardous wastes are shipped in proper
containers, are accurately marked and labeled, and the transporter is
provided with the proper placards.
If the POTW accumulates 1,000 kg/month of hazardous wastes on-site
for more than 90 days, the POTW is classified as a hazardous waste
storage facility, and must comply with Sections 264,265, and 270, and
obtain a RCRA storage permit. (This could include a permit-by-rule
under 40 CFR ง270.60[c].)  POTWs generating between 100 and
1,000 kg/month of waste can accumulate wastes for 180 or 270 days if
waste must be transported more than 200 miles for treatment and
disposal.

-------
                                                    TABLE 4-1
                                                    (continued)
                                        POTW COMPLIANCE CHECKLIST
CONSIDERATION BEFORE
DISCHARGING TO POTW

Sludge Mngmt/Hazardous Waste Mngmt
(continued)

16. Does the POTW properly dispose
    of the sludge classified as
    hazardous waste?
17. Does the POTW comply with
    permit requirements for sludge use
    and disposal?
/APPLICABLE              *'*>
REQUIREMENT     REQTJffiEMENTSYNOPSIS
18. Does the POTW comply with
    permit requirements for sludge use
    and disposal?
 RCRA - Land
 Disposal Restrictions
 40 CFR ง268
 CWA - Establishing
 limitations, standards,
 and other permit
 conditions (40 CFR
 ง122.44)
 CWA -
 USEPA-administered
 Permit Programs:
 NPDES (40 CFR
 ง122)
If the hazardous sludge is land-disposed, it must be treated to the
applicable treatment standard specified in the RCRA Land Disposal
Restrictions prior to disposal.
Regulations require that when there are no applicable standards for
sewage sludge use or disposal, the permit shall include requirements
developed on a case-by-case basis to protect public health and the
environment from toxic pollutants in sewage sludge.

Regulations that pertain to sludges are based on CWA Section 405(f),
which requires that NPDES permits must include requirements to
implement the sludge use and disposal standards (40 CFR ง503),
unless such requirements have been included in a permit issued under
RCRA, SDWA, CAA, or MPRSA and an approved state sludge
management program. Permits with requirements for sludge use or
disposal will also be required for treatment works treating domestic
sewage not subject to NPDES.

-------
                                                      TABLE 4-1
                                                      (continued)
                                         POTW COMPLIANCE CHECKLIST
  ...      t   ff         -.    s   <• S •>     f        f.   f          -,       f          $       .
  -   -"  >';->'>  „-"-<•< ^';;-••/  ,,  :_;*::'"    '' V" " V- :   ;''      -v^-   ''', ^1^'     *•",
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  E5Ot4ป0I^
              '        '           ^,'     '      s       *   %  %     *         '''        '   ^\ f '•• /
Sludge Mngmt/Hazardous Waste Mngmt
(continued)

19. (Compliance question to be         CWA - Conditions
    determined upon finalization of     applicable to all
    sewage sludge technical standards.)  permits (40 CFR
                                    ง122.41)
20. (Compliance question to be
    determined upon finalization of
    the proposed CWA sludge
    regulations.)
CWA - Sewage
Sludge Technical
Standards (40 CFR
ง503)
21.  (Compliance question to be         RCRA - Solid Waste
    determined upon finalization of     Disposal Facility
    the proposed RCRA - Solid Waste   Criteria (40 CFR
    Disposal Criteria.)                 ง258)
Regulations require the POTW to comply with standards for sludge
use or disposal even if the permit has not yet been modified to
incorporate the regulatory requirement.  The POTW must take all
reasonable steps to minimize or prevent sludge use or disposal in
violation of the permit. Test procedures may be specified under 40
CFR ง503.
Proposed regulations set sludge technical standards for the use and
disposal of nonhazardous sewage sludge. The proposed standards
address the agricultural and nonagricultural land application,
distribution, marketing, surface disposal, landfilling, and incineration
of sewage sludge. They specify numerical limits or equations for
calculating these limits for 28 pollutants based on public health and
environmental criteria. In addition, these proposed regulations include
management practices and other general requirements pertaining to use
and disposal of sewage sludge.
Under proposed regulations, sewage sludge co-disposed with solid
waste in municipal landfills would be regulated under a new 40 CFR
ง258. These regulations establish various management and operation
requirements including numerical limitations in the form of
groundwater protection standards.

-------
                                                      TABLE 4-1
                                                      (continued)
                                          POTW COMPLIANCE CHECKLIST
Pretreatment
22. Is the POTW violating its NPDES    CWA-National
    permit and/or sludge use or
    disposal requirements as a result
    of an indirect discharge?
Pretreatment
Standards -
Prohibited
Discharges (40 CFR
ง403.5(c))
23. Do any industrial discharges violate
    categorical standards for
    discharges to the POTW?
CWA - Pretreatment
Standards Categorical
Standards (40 CFR
ง403.6)
POTWs are required to develop "local limits" for indirect dischargers
introducing pollutants into their receptor systems to prevent discharges
of pollutants in amounts sufficient to interfere with or pass through the
POTW. Discharges must not violate:
     - the POTW's NPDES permit
     - relevant sludge use or disposal requirements, thereby
      restricting the POTW's sludge use or disposal practices
     - the specific prohibition listed in 40 CFR ง403.5(b)
Enforcement of these prohibitions is a requirement of pretreatment
program approval. Waste must be pretreated to a level that will not
violate these prohibitions.
Categorical Standards specify quantities or concentrations of
pollutants or pollutant properties that may be discharged to a POTW
by existing or new industrial users in specific industrial subcategories,
which have been established as separate regulations under the
appropriate subpart of 40 CFR Chapter I, Subchapter N. Violation of
pretreatment standards may indicate POTW violation of requirements
described in No. 25.

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DISCHARGING TO PQTW
Pretreatmem (continued)

24.  If required to develop a
    Pretreatment Program, has the
    POTW developed the program by
    the appropriate deadline?
25. Has the POTW enforced the
    Pretreatment Program and
    properly implemented procedures
    to ensure compliance?
                                                     TABLE 4-1
                                                     (continued)
                                         POTW COMPLIANCE CHECKLIST
                                   APPLICABLE, ,
                                   - REQUIREMENT
                                   CWA - POTW
                                   Pretreatment
                                   Programs:
                                   Development by
                                   POTW (40 CFR
                                   ง403.8)
                                   CWA - National
                                   Pretreatment
                                   Standards: Prohibited
                                   Discharges (40 CFR
                                   ง403.5)
Any POTW with a total design flow greater than 5 mgd that receives
pollutants from industrial users which pass through or interfere with
operations, or which are otherwise subject to national categorical
pretreatment standards, must establish a Pretreatment Program, unless
the NPDES state exercises its option to assume local responsibility.
Other POTWs may also be required to establish Pretreatment
Programs, upon an appropriate finding of need by USEPA or an
authorized state agency. The deadline for program approval is July 1,
1983.
A POTW is required to develop a local pretreatment program and
implement procedures to ensure compliance with the requirements of
the Pretreatment Program, including identifying all nondomestic users
of its system, identifying the character and volume of their discharges,
notifying them of applicable standards, sampling industrial effluents,
conducting inspections, and annually publishing the names of
nondomestic users in significant violation of the Pretreatment Program.

-------
f-
I—>
0\
                                                         TABLE 4-1
                                                         (continued)
                                              POTW COMPLIANCE CHECKLIST
      Hazardous Waster Treatment

      26.  If the POTW treats hazardous
          wastes, is it permitted under
          RCRA, and does it comply with
          the permit?
RCRA-
Permit-by-Rule (40
CFR ง270.60)
The owner or operator of a POTW that accepts hazardous waste for
treatment is deemed to have and be in compliance with a RCRA
permit-by-rule if it has an NPDES permit, is in compliance with the
NPDES permit, meets RCRA reporting, manifest, and (for certain
facilities) corrective action requirements.  The hazardous waste
received by the POTW meets all federal, state, and local requirements
and, if applicable, the POTW complies with RCRA corrective action
requirements.

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                                                                              SECTION 5
                                                      EVALUATE PRETREATMENT
                                                                       REQUIREMENTS
Section 2:
Identify and
Characterize CERCLA
Wastewater
Discharge


Section 3:
Identify
Local POTWs


Section 4:
Involve POTW in the
Evaluation Process
and Screen POTWs
1 Section 5:
1 Evaluate
1 iFretreatment
1 Requirements
\.
\
Section 6:
Identify and Screen
Preocatment
Alternatives
••iปP'm4l!U,JJlill ' 'V. . 1 J ..,.-.-.. •. .-- _


Section 7:
Detailed Analysis of
the POTW Discharge
Alternative
                                                      Evaluate Pretreatment Requirements

                                                        • Pnstnatment requirements (local limits) should
                                                          prevent pass through, inhibition, and sludge
                                                          contaminatioa at the POTW

                                                        • Obtain or estimate the local limits enforced by
                                                          the POTW to prevent pass through, inhibition,
                                                          and sludge contamination

                                                        • Compare CERCLA discharge characteristics to
                                                          local limits to determine which contaminants
                                                          require pretreatment
eott-oi

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5.  EVALUATE PRETREATMENT REQUIREMENTS
The next step in evaluating the CERCLA
discharge to a POTW is to determine whether
pretreatment is required prior to discharging to a
POTW. This step should be conducted during the
development of alternatives phase of the RI/FS
process.  An accurate evaluation of the
pretreatment requirements for the CERCLA
discharge will help ensure that the National
Pretreatment Program objectives are attained (i.e.,
that pass through, interference, and sludge
contamination be prevented at the POTW). In
addition, this evaluation is consistent with the
USEPA policy memorandum concerning
CERCLA discharges to POTWs.  The
memorandum requires that the quantity and
quality of the CERCLA wastewater, including the
possibility  of pass through, interference, and
sludge contamination, be evaluated. Also, it
requires that the potential effect of the CERCLA
wastewater on the POTW's discharge be
evaluated.

The process for evaluating pretreatment
requirements consists of two activities:
(1) obtaining or estimating local limitations for
the contaminants in the CERCLA discharge; and
(2) comparing the CERCLA wastewater
characteristics against the local limitations and
prohibited discharge standards.

In order to  avoid problems that could arise in
treating highly concentrated wastestreams, it may
be more practical to pretreat before discharging to
a POTW.
5.1.  OBTAIN OR ESTIMATE POTW'S
     LOCAL LIMITS

Local limits will serve as a basis for evaluating
pretreatment requirements. Local limits are
specific requirements developed and enforced by
individual POTWs to prevent pass through and
interference.  Such limits may be required for the
CERCLA wastestream contaminants because
uniform federal standards establishing the
required level of pretreatment for CERCLA
wastes being discharged to a POTW are not
currently available (i.e., categorical standards for
CERCLA sites). Rather, these standards must be
determined on a site-specific basis depending on
the compounds present in the wastestream and
their concentrations, the POTW characteristics,
the body of water that will receive the discharge,
POTW sludge disposal practices and
requirements, and/or POTW NPDES permit
requirements.

The POTW may have local limits for all the
contaminants in the CERCLA discharge.
However, it is more likely that the POTW will not
have such limits for all contaminants or that
existing limits may need to be changed based on
the acceptance of the new discharge. If some local
limits do not exist, they must be developed by the
POTW, or estimated by the FS team so that
pretreatment alternatives can be evaluated.
However, if these limits are estimated and the
POTW later agrees to accept the discharge, the
POTW must develop the estimated limits into
enforceable ones (see Section 8.0).

To determine whether local limits can be obtained
from the POTW or must be estimated, the FS team
must contact the POTW.  Working with the
POTW authority and/or the agency responsible
for developing local limits, the team should
evaluate the local limits that already exist for
compounds detected in the CERCLA waste and
determine whether others must be developed or
estimated. The flow chart in Figure 5-1 identifies
important points that should be addressed to
evaluate local limits.

As shown in the flow chart, the simplest but most
unlikely scenario would be that the POTW
already has local limits developed for all
compounds detected in the CERCLA waste and
                                          5-1

-------
                           DOES
                         THE POTW
                        HAVE LOCAL
                     LIMITS FOR CERCLA
                      SITE DISCHARGE
                       CONTAMINANTS
                              FS WRITER SHOULD
                               ESTIMATE LOCAL
                              LIMITS USING THE
                             APPROACH PRESENTED
                               IN SECTION 10.1
  PRETREATMENT
BE ABLE TO DEVELOP.
  LOCAL LIMITS
    QUICKLY?
                           WILL
                       THE DISCHARGE
                      OF CERCLA WASTE
                       EXCEED LOCAL
                         LIMITS?
                          SHOULD
                         THE LOCAL
                       MITS BE REVISED
                      TO ACCOMMODATE
                       DITIONAL LOADIN
                       FROM CERCLA
                          WASTES
                           WILL
                         THE POTW
                        BE ABLE TO
                      REVISE THE LOCAL
                      LIMITS QUICKLY
 FS WRITER SHOULD
  ESTIMATE LOCAL
  LIMITS USING THE
APPROACH PRESENTED
  IN SECTION 10.1
                               GO TO RGURE 10-1
                            TO ESTIMATE LOCAL LIMITS
                    DETERMINE LEVEL OF
                      PRETREATMENT,
                       IF NECESSARY
                                                                                       FIGURE 5-1
                                                             OBTAINING  POTW LOCAL  LIMITS
tOM-01
                                                     5-2

-------
                                         EVALUATE PRETREATMENT REQUIREMENTS
that the addition of the CERCLA waste would not
exceed the existing local limits. If this situation
did occur, the FS writer could evaluate the
pretreatment requirements quickly. However, if
the CERCLA waste would be a significant portion
of the POTW influent, it would be appropriate to
reevaluate the current local limits.

In most instances, however, enforceable local
limits will not exist for all compounds detected in
the CERCLA wastes, and will have to be
developed by the POTW or estimated by the FS
team. If this is the case, it is important to get an
estimate of the time required by the POTW to
develop new local limits. Depending on staffing,
laboratory capabilities, and treatment plant
performance experience, some POTW authorities
may be capable of developing acceptable local
limits for a wide range of compounds in a
reasonably short period.

If new or revised local limits are needed, the
POTW should notify the NPDES regulatory
agency. The earlier that this agency  is notified,
the greater the chance that revised NPDES limits
and local limits will  be developed by the time a
decision must be made concerning remedial
action. Several iterations to develop and agree on
the acceptable  limits should be expected.
However, high priority may not necessarily be
given to a CERCLA site clean-up effort, and
several months could be required to develop local
limits.

The time required by the POTW to develop local
limits for compounds in the CERCLA waste will
determine whether FS writers have to estimate
local limits to evaluate pretreatment requirements.
To estimate local limits, the FS team must conduct
several activities:

   • Collect and evaluate the pertinent
     regulatory criteria
   • Calculate a mass balance for each
     compound detected in  the
     CERCLA waste using treatability
     data

   • Evaluate the.impact each
     contaminant has on air emissions,
     treatment plant operations, sludge
     disposal, and effluent water quality

   • Estimate local limits and the
     expected level of pretreatment
     necessary, at a minimum, to ensure
     continued compliance with NPDES
     permit limits and applicable air
     emission standards, avoid any
     exceedance of state water quality
     standards, and maintain acceptable
     levels of sludge quality

These activities and a method for estimating local
limitations are discussed in Section 10.0.
5.2. COMPARE CERCLA DISCHARGE
    CHARACTERISTICS TO LOCAL
    LIMITS

After local limits have been obtained or estimated,
they should be compared to CERCLA wastewater
characteristics (i.e., contaminant concentrations
and flow rate), as determined in Section 2.0.  In
addition, these characteristics should be evaluated
considering General Pretreatment Regulations
(see Subsection 8.1.2), which forbid the discharge
of pollutants that cause fire or explosion hazard,
corrosive structural damage, obstruction of flow,
interference, or inhibition of biological activity
due to excessive heat.

Based on these comparisons, the FS team should
determine which contaminants, if any, require
pretreatment, and the percent removal required for
each contaminant. In addition, if local limits were
estimated, the FS team, POTW, and appropriate
authorities should develop and obtain approval of
                                           5-3

-------
EVALUATE PRETREATMENT REQUIREMENTS
enforceable local limits and issue a mechanism of
control for the contaminants in the CERCLA
discharge (see Section 8.0).
                                       5-4

-------
                                                                    SECTION 6
                                                     IDENTIFY AND SCREEN
                                           PRETREATMENT ALTERNATIVES
     Section 2:
     Identify and
   Characterize CERCLA
     Wastcwatcr
   	Discharge	
Section 3:
Identify
Local POTWs


Section 4:
Involve POTW in the
Evaluation Process
and Screen POTWs


Section 5:
Evaluate
Pretreatment
Requirements
/
/
J
Section 6; j
Identify and Screen J
Prelreatment J
Alternatives •
 Section?:
Detailed Analysis of
the POTW Discharge
  Alternative
                                        Identify and Screen Pretreatment
                                        Alternatives
                                          a Identify possible prereatment
                                          • Develops a pretreatment process train to
                                            properiy pntreat the CERCLA wastestream
6053-01

-------

-------
6.  IDENTIFY AND SCREEN PRETREATMENT
    ALTERNATIVES
At this point in the development of the discharge
to a POTW alternative, the FS team has
determined that a POTW is available to accept the
wastewater, and has determined if pretreatment is
required. This section describes the process for
selecting and evaluating an appropriate
pretreatment alternative.  Various technologies
are presented for pretreating the CERCLA site
discharge, and a strategy is given on how to
assemble the appropriate technologies into a
treatment train. Detailed information for several
technologies is available in the "CERCLA Site
Discharges to POTWs Treatability Manual"
(USEPA, 1990) and other sources. This
information can be used by the FS team to
evaluate the pretreatment/discharge to POTW
alternative.

Approaching this section, the FS writer should
have certain information, including a complete
description of the stream to be discharged (i.e.,
flow rates and chemical composition), and
necessary treatment levels for key contaminants
prior to acceptance at the POTW. This section is
not intended  to be an exhaustive review of
available technologies or possible pretreatment
trains; rather, it provides a simple approach to
establishing a basic pretreatment train.
Refinements of the train will be necessary based
on a more  detailed review of available
technologies.
6.1. IDENTIFY PRETREATMENT
    TECHNOLOGIES

The technologies presented in this section were
identified based on review of available
demonstrated wastewater treatment technologies
and a review of technologies that have been used
for pretreatment of CERCLA discharges to
POTWs. New technologies for treating
wastewater are continually being developed, and
the FS team is referred to technical journals and
outside references for additional information on
recent developments.

The technologies discussed in this section are a
basic set of unit operations capable of pretreating
a wide variety of wastestreams and contaminants,
including most identified contaminants of
concern. The technologies can be combined to
form a complete train for many mixed
wastestreams that might be expected from a
CERCLA site.

The technologies covered briefly in this section
can be grouped into the following three general
categories:

TREATMENT TECHNOLOGIES

Aerobic Biological Treatment
Air- and Steam-stripping
Anaerobic Biological Treatment
Separation
Neutralization
Oxidation
Precipitation
Reduction

SEPARATION TECHNOLOGIES

Clarification
Filtration
Oil and Grease

POLISHING TECHNOLOGIES

Carbon Adsorption
Ion Exchange

These technologies are presented in Table 6-1
with information on how the technologies are
used, which combinations of technologies are
                                         6-1

-------
                                                    TABLE 6-1
                             APPLICABILITY OF PRETREATMENT TECHNOLOGIES



:
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Oxidizing Metals
Oxidizing Organics

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tling, flow equalization

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Prior to Biological Treatment


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Prior to Clarification/Filtration
Following Precipitation
Following Aerobic Biological Treat-
ment


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Following Biological/Precipitation
Prior to Air-stripping
Prior to Polishing w/Carbon or Ion Ex-
change




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~ = Not Applicable or insufficient data available for compounds in this class

-------
                                                      TABLE 6-1
                                                      (continued)
                              APPLICABILITY OF PRETREATMENT TECHNOLOGIES
if f ' f '
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- = Not Applicable or insufficient data available for compounds in this class

-------
IDENTIFY AND SCREEN PRETREATMENT ALTERNATIVES
most frequently used, and the applicability of each
technology to the classes of contaminants.
Table 6-1 should be considered when combining
technologies into process trains capable of
pretreating discharges from CERCLA sites.


6.2.  ASSEMBLE ALTERNATIVE
     PROCESS TRAIN PRETREATMENT

This subsection discusses an approach to
assembling a process train for pretreatment of a
CERCLA discharge. The approach presented in
the following paragraphs, one of many possible
approaches to development of a process train, is
designed to aid in selection of the basic unit
operations necessary to treat a wastestream.

The remainder of this subsection consists of four
decision flow charts that will enable the FS team
to assemble a treatment train. The flow charts are
arranged in the following order: (1) Flow
Equalization and Phase Separation, (2) Metals
Removal, (3)  Organics Removal, and
(4) Polishing and Discharge.

Each flow chart deals with a specific segment of
an overall pretreatment train. After each step in
the flow chart, the concentrations in the stream
must be recalculated. Data for this recalculation
can be obtained through treatability tests, or from
data available in the literature.  For this
subsection, it is assumed that the FS team has such
data available. If the data are not available, the
information in Table 6-1 provides a rough
indication of the effectiveness of each technology.
This information can be expanded upon during
detailed evaluation of the alternative.

6.2.1.  Flow Equalization and Phase
       Separation

The first segment of the pretreatment process
involves screening and equalization of solids
followed by the removal of any nonaqueous
liquid.  As described in Figure 6-1, one or more
operations may be required to accomplish these
steps.  Coarse screens may be used to remove
large solids; sedimentation and grit removal will
remove smaller solids.  Flow equalization is
necessary when the concentration or flow rate of a
stream varies over time, as might occur with
intermittent pumping of groundwater or leachate.
Organic nonaqueous phase liquids may be
removed using a settling step for heavy fractions,
or an oil and grease separator for lighter fractions.
These preliminary steps may be accomplished in a
single settling chamber or in a series of chambers.

If solids removal, oil and grease removal, or flow
equalization achieves the necessary pretreatment
levels, the stream may be discharged. If dissolved
organic or inorganic constituents are of concern,
the stream requires further pretreatment.

6.2.2.   Metals Removal

The next segment in the pretreatment process
addresses dissolved metals. Dissolved metals can
be removed by forming insoluble precipitates that
can be flocculated and settled or filtered from the
solution (Figure 6-2). The types of chemicals
used for precipitation are highly specific to the
individual wastestream. In  some cases, metal
species need to be oxidized  or reduced before
precipitation.

The pretreatment process  train consists of
reduction or oxidation, precipitation/flocculation,
and filtration and/or clarification. Removal rates
for each metal species can be calculated from
bench-test results.  In some cases,  a second
precipitation operation, using different pH and
chemical dosages, is necessary to achieve
acceptable removal of all metallic species present.
After precipitation, residual metals can be
removed during the polishing phase, if necessary.
6.2.3. Organics Removal

The third segment of the pretreatment process
involves removal or treatment of organics (Figure
6-3). Air- or steam-stripping is used to remove the
                                            6-4

-------
                             IDENTIFY AND SCREEN PRETREATMENT ALTERNATIVES
volatile organic compounds (VOCs);
semi-volatile organic compounds (S VOCs) are
treated using a combination of oxidation and/or
biological treatments. The effectiveness of
biological treatment is highly compound-specific.

6.2.4.  Polishing and Discharge

Following the treatment segments for metals and
organics, additional treatment may be necessary
to meet the pretreatment levels established by the
POTW or otherwise deemed necessary by the FS
writer.  This manual discusses two polishing
processes: carbon adsorption for organics and ion
exchange for metals. Following these polishing
steps, final pH adjustment may be necessary
before discharge. These processes are presented
in Figure 6-4. Both carbon adsorption and ion
exchange are somewhat compound-specific.
With proper design  considerations, both
technologies have been applied successfully to
reduce trace contaminant levels.
After identifying the appropriate technologies
from each of the four flow charts, the FS writer can
assemble a complete pretreatment alternative. As
a first approximation, the train can be assembled
in the order the technologies were identified in the
flow charts.

The order of unitprocesses in the treatment train is
highly site-specific. Factors such as type of
contamination, size of the site, and availability of
materials will affect the final design. The process
can be made more efficient by optimizing the
design and order of technologies used for
pretreatment.

Once the treatment train has been developed, the
entire alternative  can be  evaluated using
information gathered during discussions with the
POTW authority and more detailed information
on treatment technologies contained in other
references.
                                           6-5

-------
                            CERCLA RAW DISCHARGE
OW X YES
SOLIDS j> ^
INCH* /
COARSE
SCREENS



Solids (>1/2
Inch)
      DISCHARGE TO POTW
     IS
  THE FLOW
VARIABLE OR
NONUNIFORM
                                                        FLOW
                                                    EQUALIZATION
                                                      CHAMBER
                                  HIGH
                                SOLIDS OR
                                SUSPENDED
                                MATERIAL
                       SETTLING
                       CHAMBER
   TOTAL
  OIL AND
  GREASE
  > 35 mg/l*
                                                      OIL/WATER
                                                     SEPARATOR
   DOES
  TREATED
   WASTE
TREAM EXCEE
   POTW
   LIMITS
GO TO FIGURE 6-2
    INDICATES LIMITS ARE BASED
    ON BEST PROFESSIONAL JUDGEMENT
                                       FIGURE 6-1
                 PRETREATMENT PROCESS TRAIN
    FLOW EQUALIZATION  AND PHASE SEPARATION
6058-01
                                        6-6

-------
                           DISCHARGE PROM FIGURE 6-1
         GO TO FIGURE 6-3
      DO
   METALS
   REQUIRE
PRETREATMENT
      DO
METALS REQUIRE
 OXIDATION OR
  REDUCTION
                                                         OXIDIZE OR
                                                         REDUCE AS
                                                        APPROPRIATE
                                      DO
                                    METALS
                                   REQUIRE
                                 PRECIPITATION
                       PRECIPITATION/
                       FLOCCULATION
                                                       CLARIFICATION
                                   NO
                                                             I    I Solids
                                                        FILTRATION
                                                                   Solids
                           NO
        DISCHARGE TO POTW
     DOES^
   TREATED
    WASTE
 STILL  EXCEED
     POTW
     LIMITS
YES
    -ป. GO TO FIGURE 6-3
                                                                  FIGURE  6-2
                                           PRETREATMENT  PROCESS  TRAIN
                                                        METALS TREATMENT
6098-01
                                      6-7

-------
                  DISCHARGE FROM  FIGURE 6-2
        GOTO
      FIGURE 6-4*
           DO
        ORGANICS
         REQUIRE
      PRETREATMENT
                                                                      DO
                                                                   ORGANICS
                                                                   REQUIRE
                                                                   FURTHER
                                                                  TREATMENT
          ARE
        ORGANICS
       STRIPPABLE
                                          AIR OR STREAM
                                            STRIPPING
        GOTO
      FIGURE  6-4ซ
          COD
        > 100 mg/l *
                                                                      DO
                                                                  ORGANICS
                                                                   REQUIRE
                                                                   FURTHER
                                                                  TREATMENT
        ORGANICS
          BIO-
      DEGRADABLE ?
                                             OXIDIZE
                                            ORGANICS
                                                                     ARE
                                                                   OXIDIZED
                                                                   ORGANICS
                                                                BIODEGRADABLE
                                                                   AND COD
                                                                     100 mg
YES       COD   *
       > 200 mg/l*
ANAEROBIC
BIOLOGICAL
TREATMENT
                         AEROBIC
                        BIOLOGICAL
                        TREATMENT
GOTO
FIGURE
  6-4
GO TO
FIGURE
  6-4
GOTO
FIGURE
  6-4
                                              * INDICATES LIMITS ARE BASED
                                                ON BEST PROFESSIONAL JUDGEMENT
                     GO TO FIGURE 6-4
                                                             FIGURE  6-3
                                      PRETREATMENT  PROCESS TRAIN
                                                ORGANICS TREATMENT
6093-01
                                             6-8

-------
                       DISCHARGE FROM FIGURE 6-3
                                                  DISCHARGE
                                                   TO POTW
 DOES
STREAM
EXCEED
 POTW
 LIMITS
                                DO
                              ORGANICS
                              REQUIRE
                              FURTHER
                             TREATMENT
                     CARBON
                   ADSORPTION
                                 DO
                               METALS
                               REQUIRE
                               FURTHER
                             TREATMENT
                       ION
                    EXCHANGE
                                IS pH
                             ACCEPTABLE
                  NEUTRALIZATION
                          DISCHARGE TO POTW
                                                              FIGURE 6-4
                                         PRETREATMENT PROCESS TRAIN
                                              POLISHING AND DISCHARGE
6098-01
                                     6-9

-------

-------
                                                                                   SECTION  7
                                             DETAILED ANALYSIS OF THE POTW
                                                          DISCHARGE ALTERNATIVE
       Section 2:
       Identify and
    Characterize CERCLA
       Wastewater
    	Discharge	
Section 3:
Identify
Local POTWs


Section 4:
Involve POTW in the
Evaluation Process
and Screen POTWs
 Section 6:
Identify and Screen
  Preffeatment
  Alternatives
 Evaluate
Pzetreatment
Requirements
Detailed Analysis Of
the POTW Dlscha
   Alternative':
                                                                Detailed Analysis of the POTW
                                                                Discharge Alternative
                                                                • Evaluate Hiป POTW discharge altomaiiv* wing thป
                                                                following nine criteria:
                                                                  1. Overall protection of human health and
                                                                   the environment
                                                                  2. Compliance with ARARs
                                                                  3. Long-tram effectiveness and performance
                                                                  4. Reduction of mobility, toidcity, or volume
                                                                   through treatment
                                                                  5. Short-term effectiveness
                                                                  6. Implementability
                                                                  7. Cost
                                                                  8. State acceptance.
                                                                  9. Community acceptance
SOM-OI

-------

-------
7.  DETAILED ANALYSIS OF THE POTW DISCHARGE
    ALTERNATIVE
The identification of the preferred alternative and
the remedy selection decision are based on an
evaluation of the major tradeoffs among the
alternatives in terms of the following nine
evaluation criteria:

   • Overall protection of human health
     and the environment

   • Compliance with Applicable or
     Relevant and Appropriate
     Requirements

   • Long-term effectiveness and
     permanence

   • Reduction of mobility, toxicity, or
     volume through treatment

   • Short-term effectiveness

   • Implementability

   • Cost

   • State acceptance

   • Community acceptance

Remedial alternatives must be protective of
human health and the environment and comply
with ARARs (or justify a waiver) in order to be
eligible for selection. These are the two threshold
criteria.

The tradeoffs, identified in the detailed analysis,
are balanced among alternatives with respect to
long-term effectiveness and permanence,
reduction of toxicity, mobility or volume through
treatment, short-term effectiveness,
implementability, and cost. This initial balancing
determines preliminary conclusions as to the
maximum extent to which permanent solutions
and treatment can be practicably utilized in a
cost-effective manner.

The preferred alternative in the proposed plan is
the alternative that is protective of human health
and the environment, is ARAR-compliant, and
affords the best combination of attributes.  State
and community acceptance are factored into a
final balancing in which the remedy and the extent
of permanent solutions and treatment practicable
for the site are determined.

The detailed analysis of an alternative involving
discharge to a POTW will usually focus on three
of the nine criteria:

   • Reduction of toxicity, mobility, or
     volume through treatment - under
     this factor the on-site pretreatment
     of the material ultimately to be
     discharged should be described

   • Short-term effectiveness - the
     potential adverse impacts of
     transporting the wastewater to the
     POTW and the timing of the
     remedial action

   • Cost - costs of discharging to the
     POTW should be compared to those
     of other alternatives

Generally, because the POTW discharge is to an
off-site facility, the remaining six criteria would
be addressed in the development and screening of
remedial alternatives (i.e., in  evaluating the
compliance status and ability of the POTW to
receive the CERCLA waste, etc.).
                                          7-1

-------
DETAILED ANALYSIS OF THE POTW DISCHARGE ALTERNATIVE
The following factors, as required by the USEPA
memorandum concerning CERCLA discharges to
POTWs, are considered initially during the
development and screening of remedial
alternatives and are carried forward into the
detailed analysis as necessary:

   • The quantity and quality of the
     CERCLA wastewater and its
     compatibility with the POTW

   • The ability of the POTW to ensure
     compliance with applicable
     pretreatment standards and
     requirements, including monitoring
     and reporting requirements

   • The POTW's record of compliance
     with its NPDES permit and
     pretreatment program requirements
     to determine whether the POTW is
     a suitable disposal site for the
     wastewater

   • The potential for volatilization of
     the wastewater at the CERCLA site
     and POTW and its impact on air
     quality

   • The potential for groundwater
     contamination from transport of
     CERCLA wastewater or
     impoundment at the POTW, and the
     need for groundwater monitoring

   • ThepotentialeffectoftheCERCLA
     wastewaters on the POTW's
     discharge as evaluated by
     maintenance of water quality
     standards in the POTW's receiving
     waters, including the narrative
     standard of "no toxics in toxic
     amounts"

   • The POTW's knowledge of and
     compliance with any applicable
     RCRA requirements or
     requirements of other
     environmental statutes

   • The various costs of managing
     CERCLA wastewater, including all
     risks, liabilities, and permit fees

Elaboration on the nine criteria and how they
relate to the anlysis of the POTW discharge, both
in the development and screening of remedial
alternatives and in the detailed analysis, are
summarized in Table 7-1.
7.1. OVERALL PROTECTION OF
    HUMAN HEALTH AND THE
    ENVIRONMENT

This criterion assesses whether each alternative
meets the requirement for protection of human
health and the environment. Basic guidance for
this criteria is provided in a two manual set
entitled "Risk Assessment Guidance for
Superfund" (USEPA, 1989c). Volume I, "Human
Health Evaluation Manual," provides guidance
for health risk assessment. Volume II,
"Environmenal Evaluation Manual," provides
guidance for ecological assessment at Superfund
sites.  Attainment of chemical-and
location-specific ARARs is addressed, when
appropriate. Adverse effects associated with
construction and operation of each remedial
alternative are described in terms of direct effects
(e.g., loss of habitat) or indirect effects (e.g.,
increased erosion and sedimentation). Inevitable
effects are distinguished from reversible effects,
where appropriate. Measures to mitigate adverse
effects are also discussed herein.

Additionally, USEPA developed a risk-based
methodology for evaluating the feasibility and
risk associated with discharging a CERCLA
waste to a POTW. This methodology is described
in "Feasibility and Risks Associated with
Discharge of Superfund Wastes to POTWs"
(USEPA, 1988b).
                                        7-2

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                                                          TABLE 7-1
            SUMMARY OF CRITERIA FOR ANALYSIS OF THE DISCHARGE TO POTW ALTERNATIVE
Overall Protection of Human Health and the Environment    -
Compliance with ARARs
    What is the potential for short- or long-term health effects to the public and the environment if the
    alternative is implemented?
-   Will the alternative meet pretreatment and NPDES requirements? See Subsections 4.3. land 8.2.

-   Will the pretreatment identified meet pretreatment standards and local limits? See Section 5.0.
-   Can the POTW ensure compliance with applicable pretreatment requirements? See Section 5.0.
-   If the POTW accepts the discharge, will the POTW meet its NPDES discharge requirements?  See
    Subsections 4.3.1 and 8.2.
-   If the POTW accepts the discharge, will the POTW discharge be in compliance with state water quality
    standards? See Subsection 4.3.
-   If the POTW accepts the discharge, will the POTW meet its sewage sludge disposal requirements?  See
    Subsections 4.1 and 4.2.
-   Is the POTW in compliance with RCRA permit-by-rule requirements? See Subsection 3.1.2.
-   Will the alternative meet the requirements of RCRA? In particular, is the wastestream considered a
    RCRA hazardous waste? If so, will the DSE apply?  See Subsections 2.2.4 and 3.1.1 and Section 9.0.
-   Witt the alternative meet other action- and location-specific requirements? See Subsections 1.3 and 7.2.
Long-term Effectiveness and Permanence
-   After the alternative is implemented, how much risk will still be posed if receptors are exposed to the
    wastestream?  See Subsection 7.3.
-   What types of long-term management will be required for the pretreatment and storage systems? See
    Subsection 7.3.
-   How reliable are the system components?
-   Is it likely that the POTW could treat the CERCL A wastestream for the time duration required? See
    Section4.0.
-   Witt contaminants pass through the POTW?  See Section 5.0.

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                                                            TABLE 7-1

                                                            (continued)

            SUMMARY OF CRITERIA FOR ANALYSIS OF THE DISCHARGE TO POTW ALTERNATIVE

Reduction of Mobility, Toxicity, or Volume
Through Treatment
Short-term Effectiveness
Implementability

        Technical Feasibility
        Demonstrated Performance
        Support Requirements
-   Are the pretreatment technologies or the POTW unit operations innovative technologies, which reduce
    mobility, toxicily, or volume?

-   How much will the alternative reduce the mobility, toxicity, or volume of pollutants? See Subsection
    7.4.

-   What residuals will result from the process? How will they be treated and/or disposed?


-   What risks will be posed to workers, the community, or the environment as a result of constructing the
    systems involved in the alternative?  See Subsection 7.5.

-   How long will it take to implement the alternative?

-   What is the potential that human or environmental receptors will be exposed to the wasteslrearn during
    on-site storage or off-site transport and disposal? See Subsections 3.1.3 and 7.5.

-   What is the potential that the pretreatment system will not be adequately effective? See Section 5.0.

-   How long must the system operate?

-   Will operation of collection or extraction systems and the pretreatment systems cause adverse
    environmental impacts?  What is the cost of mitigating these impacts?
    Is the transport technology (i.e., piping or trucking) feasible? See Subsection 3.1.3.

    Are the POTWs' unit operations suitable for contaminant treatment? See Subsection 4.2.

    If the wastestream will be discharged to a sewage collection system, is that system separate from or
    combined with the storm drain system?  Are there combined sewer overflows between the site and the
    POTW? See Subsection 4.2.

    Has the pretreatment system been proven on the contaminants at the site? See Subsection 4.2.

    Is the POTW effective on site contaminants? See Subsection 4.2.

    What sludge disposal processes are currently employed by the POTW?  Are they adequate?  What other
    support requirements would be necessary? See Subsections 4.1 and 4.2.

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                                                                   TABLE 7-1
                                                                   (continued)
                     SUMMARY OF CRITERIA FOR ANALYSIS OF THE DISCHARGE TO POTW ALTERNATIVE
        Implementability (continued)
                Availability

                Installation

                Permitting and Legal Constraints
-j4
Ul
        Cost
-   Does the POTW have the hydraulic capacity to accept the wastestream? See Subsection 4.2.
-   Are pretreatment systems available? See Subsection 4.2.
-   Are the collection, storage, or pretreatment systems difficult to construct?  See Subsection 6.0.
-   How long will construction of these systems take?
-   Will the POTW agree to accept the waste? See Section 4.0.
-   Would the POTW need additional permits or changes in current permits? See Subsection 4.3.
-   Is the POTW in compliance with its NPDES permits and pretreatment program requirements? See
    Subsections 3.2 and 4.1.
-   Can the POTW ensure compliance of the CERCL A site with applicable pretreatment standards and
    requirements? See Section 4.0 and Subsection 4.1.
-   Is the POTW regulated by any local ordinances that limit the waste types they may accept?  If so, does
    the ordinance affect the CERCLA discharge?  See Subsection 4.2.
-   Is the POTW's discharge in compliance with state water quality standards and applicable sludge use
    and disposal requirements? See Subsections 4.1 and 4.2.

-   What are the capital costs of this alternative?
-   What are the long-term O&M costs of this alternative (including O&M of the pretreatment system and
    site sewers, fees or user charges for the POTW, and monitoring and reporting costs?)
-   What is the net present-worth cost of this alternative?
-   How do these costs compare to the costs of other alternatives?
        State and Community Acceptance
-   Is the state or community expected to support or oppose the alternative? See Subsections 7.8 and 7.9.

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DETAILED ANALYSIS OF THE POTW DISCHARGE ALTERNATIVE
The USEPA document uses a risk-based
evaluation to evaluate the impact of a CERCLA
site discharge to a POTW in the absence of
environmental guidelines for the POTW effluent,
air emissions, and sludge disposal. The wastes are
assessed on the basis of three exposure pathways:
volatilization, pass through, and sludge quality.
The risks associated with each exposure pathway
are evaluated using a two-tiered approach. In
Tier I, a simple screening model consisting of
worst-case assumptions is applied to evaluate
maximum probable risk impacts associated with
each pathway. If the risks associated with Tier I
analyses are inconsequential, then no further
analyses are performed.  If the Tier I model
reveals the potential for significant exposures,
then Tier 2 assumptions are applied. In Tier 2,
more realistic assumptions  are made,
plant-specific data are used, and more complex
models are employed. The risk assessor actually
evaluating a POTW as a remedial alternative
could consult the USEPA document for a more
detailed discussion.
7.2.  COMPLIANCE WITH ARARs

This evaluation criterion is used to determine how
each alternative complies with applicable or
relevant and appropriate federal and state
requirements, as defined in SARA Section 121.
The detailed analysis summarizes which
requirements are applicable or relevant and
appropriate to an alternative, and describes how
the alternative meets those requirements. The
three general categories of ARARs (i.e.,
chemical-, location-, and action-specific) are
discussed for each alternative along with the
alternative's compliance with appropriate criteria,
advisories, and guidance. RARs are not pertinent
to evaluations of off-site response actions.


73.  LONG-TERM EFFECTIVENESS AND
     PERMANENCE

The primary focus of this evaluation is the extent
and effectiveness of the controls that may be
required to manage the risk posed by treatment
residuals and/or untreated wastes. The following
components of the criterion should be addressed
for each alternative:

   • Magnitude of remaining risk. This
     factor assesses the residual risk
     remaining from untreated waste or
     treatment residuals at the
     conclusion of remedial activities.
     The potential for this risk may be
     measured by numerical standards
     such as cancer risk levels or the
     volume or concentration of
     contaminants in waste, media, or
     treatment residuals remaining
     on-site. Characteristics of the
     residuals  are considered to the
     degree that they remain hazardous,
     taking into account their toxicity,
     mobility, and propensity to
     bioaccumulate.

   • Adequacy of controls. This factor
     assesses the adequacy and
     suitability  of controls (if any) that
     are used to manage treatment
     residuals or untreated wastes
     remaining at the site.  It may
     include  an assessment of
     institutional controls to determine
     whether they are sufficient to
     ensure that any exposure to human
     and environmental receptors is
     within protective levels.

   • Reliability  of controls. This factor
     addresses the long-term reliability
     of management controls for
     providing continued protection
     from residuals. It includes (1) the
     assessment of the potential need to
     replace technical components of the
     alternative;  (2)  the potential
     exposure pathway; and (3) the risks
     posed if the remedial action needs
     replacement.  USEPA has
                                          7-6

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                     DETAILED ANALYSIS OF THE POTW DISCHARGE ALTERNATIVE
     developed a risk-based
     methodology for evaluating the
     feasibility and risk associated with
     discharging CERCLA site
     wastewater to a POTW.  This
     methodology is presented in the
     USEPA document, "Feasibility and
     Risks Associated with Discharge of
     Superfund Wastes to POTWs"
     (USEPA, 1988b).
7.4. REDUCTION OF MOBILITY,
    TOXICITY, OR VOLUME THROUGH
    TREATMENT

This evaluation criterion addresses the statutory
preference for selecting remedial actions that
employ treatment technologies that permanently
and significantly reduce mobility, toxicity, or
volume of hazardous substances as their principal
element. This preference is satisfied when
treatment is used to reduce the principal threats at
a site through destruction of toxic contaminants,
reduction of the total mass of toxic contaminants,
irreversible reduction in contaminant mobility, or
reduction of total volume of contaminated media.

This evaluation focuses on the following specific
factors for a particular remedial alternative:

   • The treatment processes, the
     remedies they will employ, and the
     materials they will treat

   • The amount of hazardous materials
     that will be destroyed or treated,
     including how principal threats will
     be addressed

   • The degree of expected reduction in
     mobility, toxicity, or volume
     measured as a percentage of
     reduction (or order of magnitude)

   • The degree to which the treatment
     will be irreversible
     The type and quantity of treatment
     residuals that will remain following
     treatment
7.5. SHORT-TERM EFFECTIVENESS

This evaluation criterion addresses effects of the
alternative during the construction and
implementation phase until remedial action
objectives are achieved. Under this criterion,
alternatives are evaluated with respect to their
effects on human health and the environment
during implementation of the remedial action.
The following components of this criterion are
addressed for each alternative:

   • Protection of the community during
     remedial actions.  This aspect of
     short-term effectiveness addresses
     any risk that results from
     implementation of the proposed
     remedial action.

   • Protection of workers during
     remedial actions.  This factor
     assesses threats that may be posed
     to workers and the effectiveness
     and reliability of protective
     measures that could be taken.

   • Environmental impacts. This
     factor addresses the potential
     adverse environmental impacts that
     may result from implementation of
     an alternative and evaluates how
     effective available mitigation
     measures would be in preventing or
     reducing the impacts.

   • Time until remedial action
     objectives are achieved. This factor
     includes an estimate of the time
     required to achieve protection for
     either the entire site or individual
     elements associated with specific
     site areas or threats.
                                          7-7

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DETAILED ANALYSIS OF THE POTW DISCHARGE ALTERNATIVE
7.6.  EVIPLEMENfABILITY

The implementability criterion addresses the
technical and administrative feasibility of
implementing an alternative and the availability
of various services and materials required during
its implementation.  This criterion involves
analysis of the following factors.

Technical Feasibility

   • Construction and operation.  This
     relates to the technical difficulties
     and unknowns  associated with a
     technology.

   " Reliability of technology.   This
     focuses on the ability of a
     technology to meet specified
     process efficiencies or performance
     goals. The likelihood that technical
     problems will  lead to schedule
     delays is considered as well.

   • Base of undertaking additional
     remedial action. This includes a
     discussion of which (if any) future
     remedial actions may need to be
     undertaken and how difficult it
     would be to implement such
     additional actions.

   • Monitoring considerations. This
     addresses the ability to monitor the
     effectiveness of the remedy and
     includes an evaluation of the risks
     of exposure if monitoring is
     insufficient to detect a system
     failure.

Administrative Feasibility

   • Activities needed to coordinate
     with other offices and agencies
     (e.g., obtaining permits for off-site
     activities orrights-of-way for
     construction)

Availability of Services and Materials

   • Availability of adequate off-site
     treatment, storage capacity, and
     disposal services

   • Availability of necessary
     equipment, specialists, and
     provisions to ensure any necessary
     additional resources

   • Timing of the availability of
     technologies under consideration

   • Availability of services and
     materials, plus the potential for
     obtaining competitive bids, which
     may be particularly important for
     innovative technologies
7.7. COST

In the analysis of each remedial alternative, the
"Guidance for Conducting Remedial
Investigations and Feasibility Studies Under
CERCLA" (USEPA, 1988c) requires that cost
estimates include the following five principal
elements:

   • Capital costs

   • Operation and maintenance (O&M)
     costs

   • Five-year review costs

   • Present-worth analysis

   • Potential future remedial action
     costs
                                          7-8

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                     DETAILED ANALYSIS OF THE POTW DISCHARGE ALTERNATIVE
Capital costs consist of direct (construction) and
indirect (nonconstruction and overhead) costs.
Typically, capital costs include those
expenditures initially incurred to develop,
construct, and implement a remedial action.
Direct costs include expenditures for the
equipment, labor, and materials necessary to
install remedial actions. Direct capital costs
include construction, equipment, land and site
development, buildings and utilities (including
sewer construction), and disposal.

Indirect costs include expenditures for
engineering, financial, and other services that are
not part of actual installation activities but are
required to complete remedial alternatives.
Indirect capital costs may include engineering
expenses, start-up costs, legal fees and
license/permit costs, health and safety costs, and
contingency allowances.

Controls and costs associated with protecting
workers on-site during remedial action  are
difficult to quantify and vary with site-specific
conditions. Some important health and safety
cost components likely to impact total remedial
costs are decontamination, emergency
preparedness, hazard assessment, insurance,
manpower inefficiencies, medical
services/surveillance, personal protection,
personnel training, recordkeeping, and site
security.

O&M costs refer to expenditures associated with
long-term power and equipment requirements and
long-term post-construction costs (e.g.,
equipment replacement costs, sewer use charges,
and permit fees) required to effectively operate
and maintain the remedial action throughout its
useful life.

CERCLA as amended, Section 121(c), states that
a five-year review of a remedial action is required
if that remedial action results in hazardous
contaminants remaining on-site. Additional costs
associated with the five-year review should be
considered.
A present-worth analysis evaluates the
expenditures that occur over different time
periods by discounting all future costs to a
common base year. Present-worth analysis
allows remedial alternatives to be compared on
the basis of a single cost representing an amount
that, if invested in the base year and disbursed as
needed, would be sufficient to cover all costs
associated with the remedial action over its
planned life.


7.8.  STATE ACCEPTANCE

This assessment evaluates technical and
administrative issues and concerns the  state may
have regarding each alternative. Comments
provided by the state during the FS should be
evaluated and discussed in the Record of Decision
(ROD) and the responsiveness  summary.
Additional information is provided in the
"Guidance  for Conducting Remedial
Investigations and Feasibility Studies Under
CERCLA" (USEPA, 1988c).


7.9.  COMMUNITY ACCEPTANCE

This assessment incorporates public input into the
analysis of alternatives. Formal public comments
are provided during the 21-day public  comment
period on the  RI/FS report and proposed plan.
Specific public concerns or comments  should be
addressed in the ROD and responsiveness
summary. Additional information is provided in
the "Guidance for Conducting Remedial
Investigations and Feasibility Studies Under
CERCLA" (USEPA, 1988c).


7.10. SUMMARY EVALUATION

Following detailed analysis, the results  should be
summarized and compared considering the
following factors used by USEPA during remedy
selection in the ROD process:
                                          7-9

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DETAILED ANALYSIS OF THE POTW DISCHARGE ALTERNATIVE
     Protection of human health and the
     environment

     Attainment of federal and state
     human health and environmental
     requirements identified for the site

     Cost-effectiveness
   • Use of permanent solutions and
     alternative treatment technologies
     or resource recovery technologies,
     to the maximum extent practicable

Additional information is provided in the
"Guidance for Conducting Remedial
Investigations and Feasibility Studies Under
CERCLA" (USEPA, 1988c).
                                       7-10

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                                        SECTION 8
                             CLEAN WATER ACT AND
               THE NATIONAL PRETREATMENT PROGRAM
6098-0!

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8.  CLEAN WATER ACT AND THE NATIONAL
    PRETREATMENT PROGRAM
To date, specific national categorical pretreatment
standards governing the discharge of CERCLA
wastes to a POTW have not been promulgated.
As a result, CERCLA wastes are treated as
nondomestic wastestreams, and are subject to the
general pretreatment regulations promulgated
under the Clean Water Act (CWA) and to any
more stringent local  or state requirements.
Similar to other nondomestic wastestreams, a
CERCLA wastewater discharge to a POTW will
not be accepted if it will cause contaminant pass
through, interference with the POTW operation,
violations of the general pretreatment regulations,
or violations of local pretreatment limits or
ordinances.

It is not the intent of this section to present an
exhaustive listing of all the regulations that may
pertain to CERCLA waste discharge to a POTW,
but rather to familiarize the FS writer with the
major components of the National Pretreatment
and NPDES programs.  References for a detailed
discussion of the National Pretreatment Program
include the "Guidance Manual on the
Development and Implementation of Local
Discharge Limits under the Pretreatment
Program" (USEPA,  1987i) and "CERCLA
Compliance with Other Laws Manual (Draft)"
(USEPA, 1988a).  The NPDES requirements are
discussed in the "Training Manual for NPDES
Permit Writers" (USEPA, 1987c).  Other useful
documents include "Guidance for Implementing
RCRAPermit-by-Rule Requirements at POTWs"
(USEPA, 1987g), "Guidance Manual for the
Identification of Hazardous Wastes Delivered to
POTWs by Truck, Rail or Dedicated Pipe"
(USEPA, 1987J), "RCRA Information on
Hazardous Wastes for Publicly Owned Treatment
Works" (USEPA, 1985), and "Overview of
Selected USEPA Regulations and Guidance
Affecting POTW Management" (USEPA,
1989b).  These references were used to develop
the information presented in the following
subsections.
8.1. NATIONAL PRETREATMENT
    PROGRAM

The National Pretreatment Program, authorized
under CWA Section 307(b), was established to
regulate the introduction of pollutants from
nondomestic sources into POTWs.  The goal of
the program is to protect POTWs and the
environment from damage that may occur when
hazardous, toxic, or other nondomestic wastes are
discharged into a sewer system. The discharges
targeted for regulation include those that (1) will
interfere with the operation of a POTW, including
interference with its sludge use or disposal;
(2) will pass through the POTW; or (3) are
otherwise incompatible with the POTW. The
pretreatment program is implemented primarily
through approved local programs administered by
POTWs.  The National Pretreatment Program
consists of two elements that interact to
accomplish the objectives  of the program:

   • National Categorical Standards

   • General Pretreatment Regulations

The controls imposed by national categorical
standards and general pretreatment regulations
are described in the following subsections.
Greater emphasis is placed on the discussion of
local limits because of the flexibility in
developing specifically tailored local limits by
POTWs on a case-by-case basis.

8.1.1.  National Categorical Standards

The national categorical standards are
technology-based effluent limits developed by
                                         8-1

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CLEAN WATER ACT AND THE NATIONAL PRETREATMENT PROGRAM
USEPA to provide standard limits on the
introduction into POTWs of wastes generated by
particular categories of industry (e.g., leather
tanning and metal finishing). Categorical
standards have not been developed for CERCLA
sites.

8.1.2.  General Pretreatment Regulations

The general pretreatment regulations are intended
to address site-specific problems at POTWs, and
to apply a broader baseline level of control to all
industrial users discharging to any POTW. These
regulations apply whether or not the water has
been generated by aparticular industrial category.
The general treatment regulations consist of
general prohibitions, specific prohibitions, and
local limits.

General Prohibitions. The general prohibitions
of the pretreatment regulations (40 CFR
ง403.5[a]) are national prohibitions applicable to
nondomestic uses that control the introduction of
contaminants into POTWs to accomplish the
following:

    • Prevent interference with the
     operation (including sludge
     management) of a POTW

    • Prevent pass through of
     contaminants through the POTW

The term "interference" means  a discharge that,
alone orin conjunction with discharges from other
sources, inhibits or disrupts aPOTW, its treatment
processes or operations, or its sludge processes,
use, or disposal, causing a violation of its NPDES
permit or other requirements. "Pass through" is
any discharge to  a POTW in quantities or
concentrations that, alone or in conjunction with
discharges from other sources, causes a violation
of any requirement of the POTW's NPDES permit
(e.g., a pollutant "passes through" the POTW to
surface waters without sufficient treatment to
comply with discharge limits).
Specific Prohibitions. The specific prohibitions
(40 CFR ง403.5[b]) are national prohibitions that
apply to all nondomestic users and protect against
pollutant discharges causing the following:

    • A fire or explosion hazard in the
     sewers or POTWs

    • Corrosive structural damage to the
     POTW (pollutants with a pH lower
     than 5.0)

    • Obstruction of flow in the sewer
     system

    • Interference due to the pollutant's
     high concentration or flow rate

    • An increase in temperature of
     wastewater entering the  POTW
     which inhibits biological activity
     resulting in interference

Local Limits. The third segment of the
prohibited discharge standards are local limits.
"Local limits" are specific requirements
(including, for example, specific  prohibitions or
limits on pollutants or pollutant parameters)
developed and enforced by individual POTWs to
implement the national  general and specific
prohibitions.  They are federally enforceable
under Section 403.5(d).  The development of
these limits  will ensure that  pretreatment
standards protect both the local POTW and the
environment.

States and localities may also impose more
stringent requirements on dischargers. These
additional requirements may be based on state
pretreatment regulations or local ordinances.
                                           8-2

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                CLEAN WATER ACT AND THE NATIONAL PRETREATMENT PROGRAM
8.1.3. Development of Local Limits or
      Other State or Local Discharge
      Requirements

POTWs that are required under 40 CFR ง403 to
have pretreatment programs or those that
experience pass through and interference
problems must develop and enforce local limits.
In a few cases, states are responsible for
administering pretreatment programs and
developing local limits for particular POTWs.
Development of local limits requires site-specific
data to identify pollutants of concern that may be
discharged in quantities sufficient to cause POTW
or environmental problems.  Briefly, the process
used to develop local limits requires a review of
plant operations and environmental criteria.
During this process, the sources, character, and
volume of contaminants in the POTW influent,
effluent, and sludge are evaluated, and a technical
approach for developing the limits is selected and
implemented. Detailed descriptions of methods
to develop local limits are in the "Guidance
Manual on the Development and Implementation
of Local Discharge Limits under the Pretreatment
Program" (USEPA, 1987i).  An abbreviated
discussion of developing local limits is presented
in Section 10.0.

Local limits are dynamic and POTWs should
review and revise the limits periodically to
respond to changes in federal or state regulations,
environmental protection criteria, plant design
and operational criteria, or the nature of the
industrial or other nondomestic contributions to
the POTW influent.

Specific examples of potential changes that may
require the POTW authority or other responsible
regulatory agency to derive new local limits
include the following:

   • Changes in NPDES permit limits

   • Changes in water quality standards,
     including toxicity requirements
   •  Changes in sludge disposal
      standards or POTW sludge disposal
      methods

   •  Modifications to the treatment
      plant, causing changes in the
      process removal efficiencies and
      tolerance to inhibition from
      pollutants

   •  Availability of additional
      site-specific data pertaining to
      pollutant removal efficiencies
      and/or process inhibition

   •  Introduction of new or additional
      industrial wastes (or CERCLA
      wastewaters) into the POTW

A POTW's local limits must, at a minimum, be
based on meeting the statutory and regulatory
requirements expressed in the CWA and General
Pretreatment Regulations and any applicable state
and local requirements. Because individual
NPDES permit conditions, sludge disposal
practices, and state and local requirements vary
among POTWs, various concerns must
potentially be addressed through local limits. The
types of concerns  that a POTW will likely be
required to address as a result of federal, state, or
local requirements include water quality
protection, sludge quality protection, operational
problems, worker health and safety, and air
emissions.

8.1.4. Discharge Control Mechanism

Under the proposed Domestic Sewage Study
(DSS) rule (40 CFR ง112 and 403), POTWs that
have pretreatment programs would be required to
issue permits or equivalent individual control
mechanisms for each significant industrial user.

The mechanisms must contain the following
components:
                                          8-3

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CLEAN WATER ACT AND THE NATIONAL PRETREATMENT PROGRAM
     Statement of duration - five years or
     less
CERCLA site discharge, with submission of
results to the POTW.
   • Statement of nontransferability of
     the permit without prior notification
     to the POTW

   • Applicable effluent limits based on
     general pretreatment in 40 CFR
     ง403, national categorical
     pretreatment standards, local limits,
     and applicable state law

   • Applicable self-monitoring,
     sampling, reporting, and
     recordkeeping requirements,
     including sampling location,
     sampling frequency, and sample
     type

   • Notification requirements for slug
     discharges as defined in 40 CFR
     ง403.5(b)

   • Statement of applicable civil and
     criminal penalties for violation of
     pretreatment standards  and
     requirements and, where required,
     any applicable compliance
     schedules

Compliance Schedules/Reporting
Requirements. Under 40 CFR ง403.8(f)(l)(iv),
the POTW with an approved pretreatment
program must also have the authority to require
(1) the development of a compliance schedule by
each industrial user for the installation of
technology required to meet applicable
pretreatment standards and requirements; and
(2) the submission of all notices and
self-monitoring reports from dischargers as are
necessary to assess and assure compliance by
industries with pretreatment standards and
requirements.  The POTW is likely to require
some type of self-monitoring program for the
8.2. NATIONAL POLLUTANT
    DISCHARGE ELIMINATION
    SYSTEM

Control of point sources of water pollution is
implemented through the National Pollutant
Discharge Elimination System (NPDES), which
was established under the CWA. The NPDES
program requires dischargers to obtain permits
specifying the permissible concentration or level
of contaminants in the effluent.  USEPA and the
states use the NPDES permitting system to control
point sources and thereby help attain and maintain
ambient water quality standards for their surface
water bodies.  Every POTW must apply for and
obtain an NPDES permit which includes limits
that control the pollutants that may be discharged
in its effluent.

8.2.1.  Ambient Water Quality Standards

States are responsible for setting water quality
standards for the waters within their borders. Two
types of standards are used: narrative standards
such as "no toxics in  toxic amounts," and
numerical standards. These standards designate
the uses of specific water bodies and the
associated numeric or narrative criteria applicable
to these waters which are to be maintained via
effluent limits set in permits. USEPA reviews and
approves the state standards, in accordance with
regulations specified in 40 CFR ง131.

When setting standards, states must consider toxic
pollutants listed pursuant to Section 307 of the
CWA to determine whether:

   • The discharge or presence of any
     pollutant on the list could interfere
     with the designated uses of the
     water body.
                                          8-4

-------
                CLEAN WATER ACT AND THE NATIONAL PRETREATMENT PROGRAM
   • USEPA has published numeric
     criteria for those pollutants under
     Section 304(a) of the CWA.

If both of these conditions are met, the state must
adopt specific numeric criteria for those
pollutants; otherwise, adopt a procedure to derive
a numeric limit from a narrative criterion to
protect the designated uses of the water body.
Depending on the state's evaluation of local
conditions, its numeric pollutant criteria may be
more or less stringent than USEPA criteria. In
cases where the state determines that a specific
toxic pollutant could interfere with a water body' s
designated uses but USEPA has not yet published
numeric criteria, the state must adopt pollutant
criteria based on biological monitoring or
assessment methods.

8.2.2.  Controlling Effluent Toxicity

Reducing effluent toxicity may be considerably
more difficult than treating conventional
pollutants. Not only are there hundreds of toxic
chemicals that may be discharged to receiving
waters, but analysis of these chemicals is
sometimes difficult. In addition, it is difficult to
predict the toxicity of chemical mixtures.

In response to these difficulties, USEPA has
placed considerable emphasis on a water
quality-based approach to NPDES permitting,
while also requiring that all applicable
technology-based requirements be met. In its
1984 "Policy for the Development of
Water-quality-based Permit Limitations for Toxic
Pollutants" (49 FR 9016), USEPA recommended
the use of biological testing of effluents in
conjunction with other data to establish NPDES
permit conditions.

In addition to meeting the technology-based
requirements  of secondary treatment, POTWs
must meet any more stringent water-quality-based
limits imposed by the permitting authority. In
some cases, local limits for industrial users of the
POTWs may  need to be developed to ensure
attainment  and  maintenance of
water-quality-based limits established in POTW
permits.

Effluent toxicity can be managed in some cases by
chemical-specific effluent analysis and control
(e.g., removing residual chlorine in the effluent).
Frequently, however, biological monitoring is
needed to identify the interactive effects of toxic
pollutants in the discharge.  This is known as
Whole Effluent Toxicity Monitoring.  USEPA
and the states will develop NPDES permit limits
based on whole effluent toxicity where it is an
appropriate control parameter.
                                           8-5

-------

-------
        SECTION 9
RCRA REQUIREMENTS

-------

-------
 9.  RCRA REQUIREMENTS
Whether a CERCLA site wastewater is a RCRA
hazardous waste and whether the Domestic
Sewage Exclusion (DSE) applies will affect the
feasibility of discharge to aPOTW and the method
of wastewater transport.

Under RCRA regulations, a material must be a
solid waste to be a hazardous waste.  According to
40 CFR ง261, "Identification and Listing of
Hazardous Waste," the term "solid waste"
includes virtually all physical forms of discarded
material (i.e., solids, liquids, semisolids, or
contained gaseous substances) that are
abandoned, recycled, or "inherently waste-like."
A material is abandoned if it is disposed of,
burned, or incinerated.  Materials that are stored,
treated, or accumulated before or instead of being
disposed of, burned, or incinerated are considered
abandoned. A material is also a solid waste if it is
recycled in a manner constituting disposal by
burning for energy recovery, reclamation, or
speculative accumulation.  Finally, material is
inherently wastelike if USEPA so defines it by
regulation (40 CFR ง261.2[d]). Any material
meeting this description that is not excluded under
40 CFR ง261.4(c) is a solid waste. The most
. significant exemption from the definition of solid
waste for purposes of assessing the CERCLA site
discharge to a POTW is the DSE. The DSE
exempts domestic sewage or any mixture of
domestic sewage, and other wastes, that pass
through a sewer system to a POTW for treatment
from consideration as solid waste (40 CFR
ง261.4[a][l]). This exclusion does not apply to
wastes received within the POTW's property
boundary by truck, rail, or dedicated pipe (see
Subsection 3.1.1).

Additionally, residual products from the
treatment of hazardous waste are themselves
hazardous wastes (40 CFR ง261.3(c)(2)).
However, if the waste prior to treatment was
hazardous solely by characteristic and the
treatment rendered a residual that did not exhibit
any of the characteristics of hazardous, then that
residual is not a hazardous waste (40 CFR ง261.3
If a waste is considered a solid waste under
RCRA, it may also be a RCRA hazardous waste.
To determine whether a solid waste is a RCRA
hazardous waste, the RI/FS team can conduct
several steps.  These steps are shown in Figures
9-1 and 9-2, and discussed in the following
subsections.
9.1. DETERMINE WHETHER THE
    WASTE IS SPECIFICALLY LISTED

If a solid waste has not been exempted, the second
step is to determine whether the waste is listed as
a hazardous waste in Subpart D of 40 CFR ง261.
If a waste appears on any of the lists, it is a
regulated hazardous waste, regardless of its
concentration or whether it displays hazardous
waste characteristics. The listed  wastes are
subcategorized into the following four separate
categories.

Hazardous Wastes from Nonspecific Sources.
These wastes are generated by activities that are
not specific to a particular industry  or process.
For example, spent degreasing solvents are listed
as hazardous wastes. Wastes listed in  this manner
appear on the "F" list.

Hazardous Wastes from Specific Sources.
These include wastes generated by a specific
product process in a particular industry, such as
emission control dust or sludge from secondary
lead smelting. These wastes appear on the "K"
list.

Acutely Hazardous Commercial Chemical
Products, Off-specification Species, Container
Residues, and Spill Residues. These wastes are
acutely hazardous and include discarded chemical
                                           9-1

-------
                                                              IDENTIFY CERCLA
                                                         WASTE AND CONSTITUENTS
                                                           OFTHEWASTESTREAM
                              (u* tvaaion tar qcouKlwatSf) YES
                                                              REVIEW LISTED
                                                            HAZARDOUS WASTE
                                                           ซ CFR 261. SUBPART D
                                                                                P LIST
                                                                           ACUTE HAZARDOUS
                                                                              WASTE FROM
                                                                         PRODUCTION OF OFF-SPEC
                                                                             OR DISCARDED
                                                                              COMMERCIAL
                                                                              CHEMICALS?
HAZARDOUS WASTE
                               HAZARDOUS WASTE
                                                                 LISTED  N.  YES
                                                                WASTE?
                                                            DETERMINE IF WASTE
                                                            EXHIBITS HAZARDOUS
                                                            CHARACTERISTICS
                                                                EXHIBITS
                                                             CHARACTERISTICS
                                                       DOES CERCLA WASTE RESEMBLE
                                                     A LISTED WASTE, POSE A SUBSTANTIAL
                                                      PRESENT OR POTENTIAL HAZARD TO
                                                     PUBLIC HEALTH OR THE ENVIRONMENT
                                                  WHEN IMPROPERLY MANAGED, OR CONTRIBUTE
                                                        TO AN INCREASE IN MORTALITY
                                                           OR SERIOUS ILLNESS?
                                                                                          MAKE A CASE-BY-CASE
                                                                                             DETERMINATION
                                               WASTE IS NOT A
                                           RCRA HAZARDOUS WASTE
                                                                                                                                 HAZARDOUS WASTE
                                                                                                                                         FIGURE 9-1
                                                                                                DETERMINATION OF RCRA HAZARDOUS WASTE STATUS
WfMl
                                                                       9-2

-------
                              DOES
                           GROUNDWATER
                           CONTAIN RCRA
                            HAZARDOUS
                             WASTE
                               9
                                            CONDUCT
                                          PRETREATMENT
                                               DOES
                                             TREATED
                                           GROUNDWATER
                                           STILL CONTAIN
                                            HAZARDOUS
                                              WASTE
         NOT SUBJECT TO
         RCRA SUBTITLE C
           REGULATIONS
  SUBJECT TO
RCRA SUBTITLE C
 REGULATIONS
                                                                   FIGURE 9-2
                 DETERMINATION OF GROUNDWATER AS RCRA HAZARDOUS WASTE
6098-01
                                      9-3

-------
RCR A REQUIREMENTS
products manufactured or formulated for
commercial or manufacturing use, which consist
of the commercially pure grade of the chemical,
any technical grades of the chemical produced or
marketed, and all formulations in which the
chemical is the sole active ingredient. These
wastes were listed to account for all acutely toxic
chemical products that are sometimes discarded in
pure or diluted form. Wastes listed in this manner
appear on the "P" list.

Toxic Commercial Chemical Products,
Off-specification Species, Container Residues,
and Spill Residues. Substances may be listed as
hazardous because they are chronically toxic or
they exhibit one or more characteristics of
hazardous waste (i.e., ignitability, corrosivity,
reactivity, or Extraction Procedure  [EP]
toxicity/Toxic Characteristic Leaching Procedure
(TCLP)).  These wastes include chemical
products manufactured or formulated for
commercial or manufacturing use, and which
consist of the commercially pure grade of the
chemical, any technical grades of the chemical
produced or marketed, and all formulations in
which the chemical is the sole active ingredient.
Wastes listed in this manner appear on the "U" list.
exhibiting any or all of these characteristics are
defined in 40 CFR ง261.20-261.24.
9.3. DETERMINE WHETHER THE
    WASTE IS A MIXTURE

Finally, if the waste is composed of a mixture of a
listed hazardous waste and other waste, it is also
treated as a hazardous waste, unless (1) the listed
hazardous waste in the mixture was listed solely
because it exhibits a hazardous characteristic and
the mixture does not exhibit that characteristic; or
(2) the mixture consists of certain specified
hazardous wastes and wastewater (the discharge
of which is subject to regulation under the CWA).
To qualify under the second exemption, the
concentrations must not exceed the
concentrations specified in 40 CFR
ง261.3(a)(2)(iv).

A mixture including  a nonlisted hazardous waste
and a solid waste will be deemed hazardous only
if the  entire  mixture exhibits one of the four
hazardous waste characteristics.
                                               9.4. DERIVED-FROM RULE
9.2. DETERMINE WHETHER THE
    WASTE EXHIBITS HAZARDOUS
    CHARACTERISTICS

As shown in the preceding definitions,
determining whether a waste is listed often
requires knowing its source. However, at a
CERCLA site, the source of the waste is often
unknown, especially when there may have been
many contributors to the contamination. If the
source of the waste is unknown, it cannot be
determined if the waste is listed; therefore, it
would be considered "nonlisted." Nonlisted
wastes are still covered by RCRA if they possess
one of the four hazardous waste characteristics.
Therefore, the third step is to determine whether
the waste exhibits ignitability, corrosivity,
reactivity, or EP toxicity. The properties of waste
The derived-from rule (40 CFR ง261.3(c)(2))
states that any solid waste derived from the
treatment, storage, or disposal of a listed RCRA
hazardous waste is itself a listed hazardous waste
(regardless of the concentration of hazardous
constituents). For example, ash and scrubber
water from the incineration of a listed waste are
hazardous wastes on the basis of the derived-from
rule. Solid wastes derived from a characteristic
hazardous waste are hazardous wastes only if they
exhibit a characteristic.
9.5. GROUNDWATER AND UNKNOWN
    ORIGIN EXCEPTIONS TO RCRA

There are two exceptions to the rules set forth in
40 CFR ง261. These exceptions pertain to the
RCRA regulatory status of (1) groundwater
                                          9-4

-------
                                                                RCRA REQUIREMENTS
contaminated with hazardous waste leachate, and
(2) CERCLA waste of unknown origin.

Groundwater. Under 40 CFR ง261,
groundwater contained in the aquifer is not
considered a solid waste, because it is not
"discarded" in the sense of being abandoned,
recycled, or inherently wastelike, as those terms
are defined in the regulations. Therefore,
contaminated groundwater cannot be considered a
hazardous waste under the mixture rule, because a
hazardous waste must be mixed with a solid waste
to form a hazardous waste mixture. However,
according to a USEPA memorandum,
groundwater contaminated with hazardous waste
leachate is subject to RCRA Subtitle C regulations
because the ground water contains hazardous
waste (USEPA, 1986c).  The memorandum also
states that if, as a result of treatment, the
groundwater no longer contains hazardous waste,
the groundwater would not be subject to the
hazardous waste rules. The determination of the
treatment level for groundwater so as to "no
longer contain" hazardous waste must be made on
a case-by-case basis, depending on factors such as
health-based levels and analytical detection
levels. A contained-in waste does not have to be
delisted; it only has to "no longer contain" the
hazardous waste.
Unknown Origin. A waste is hazardous under
RCRA if it is a listed waste or if it exhibits
hazardous waste characteristics. If the waste does
not exhibit any of the characteristics and is located
at a CERCLA site where the origin of the waste is
unknown, a positive determination of its
regulatory status cannot be made.  It is not
necessary to presume that a CERCLA hazardous
substance is a RCRA hazardous waste unless there
is affirmative evidence to support such a finding.
It is appropriate to use "reasonable efforts" to
determine whether a substance is aRCRA listed or
characteristic waste.  (Current data collection
efforts during CERCLA removal and remedial
site investigations should be sufficient for this
purpose.)  For listed hazardous wastes, if
manifests or labels  are not available, this
evaluation likely will require fairly specific
information about the  waste (e.g., source, prior
use,  and process type) that is "reasonably
ascertainable" within  the scope of a CERCLA
investigation. Such information may be obtained
from facility business records or from an
examination of the processes used at the facility.
For characteristic wastes, site managers may rely
on the results of the tests described in 40 CFR
ง261.21 - 261.24 for each characteristic or on
knowledge of the properties of the substance.
                                           9-5

-------

-------
                SECTION 10
ESTIMATE PRETREATMENT LIMITS

-------

-------
10. ESTIMATE PRETREATMENT LIMITS
A stepwise approach can be used to estimate
appropriate pretreatment limits. These limits can
then be used to calculate the level of pretreatment
required at the CERCLA site. Detailed guidance
on setting POTW local limits is provided in the
"Guidance Manual on the Development and
Implementation of Local Discharge Limits Under
the Pretreatment Program" (USEPA, 1987i).


10.1. ESTIMATE LIMITS

Figure 10-1 outlines the procedures the FS writer
should follow to predict the fate and potential
impacts of the CERCLA waste in a POTW.  First,
the FS writer needs to compile the regulatory
requirements discussed in Subsection 4.2. This
includes al.l Applicable or Relevant and
Appropriate Requirements (ARARs) for the
sludge, air emissions, worker health and safety,
treatment system protection, and effluent water
quality  for the specific POTW.  The POTW
authority or regulatory agency should be asked to
supply the FS writer with a comprehensive list of
the specific ARARs for the POTW. These should
include  effluent, sludge disposal, air emission
requirements, and any existing limitations on
non-domestic discharges.

While estimating local limits, the FS writer should
conservatively estimate the treatability of
compounds in the CERCLA waste, and their
potential to impact the various removal processes
in the treatment system. To obtain this estimate,
the anticipated average flow rate and pollutant
concentrations discharged from the CERCLA site
should be added to the POTW's existing low flow
and high pollutant concentrations. The new
resulting combined influent can then be used to
estimate the various potential impacts to the
treatment system operations, sludge disposal, air
emissions,  and effluent water quality.
Considerable dilution of the CERCLA waste will
often result when it is discharged to the POTW.
However, because dilution alone will not be
considered an acceptable treatment mechanism,
analysis of the fate of the contaminants in the
wastestream will be required.

10.1.1. Evaluate Biological Inhibition

The low flow toihe POTW usually represents a
worst-case scenario for evaluating the impact of
discharging CERCLA wastes to a POTW. At low
flow there is less dilution of pollutants in the
POTW. During the evaluations, the first concern
is to address the potential for biological inhibition
in the treatment system. POTW interference can
be caused by a wide variety of chemical,
biological, and physical factors.  Studies reported
in the literature discussing chemical interference
(i.e., inhibition) range from research done in the
laboratory to studies of actual treatment plant
operations.  A  substantial amount of work has
been done to determine the concentrations of
different compounds that will cause inhibition in
various biological treatment systems (USEPA,
1979; USEPA, 1981a; Russell et al., 1983; Wetzel
and Murphy, 1986; and USEPA, 1987d). The
following biological inhibition summary is from
the "Guidance Manual for Preventing Interference
atPOTWs" (USEPA, 1987h).

The most important conditions that affect
biological inhibition are as follows:

   •  The nature and strength of the
      inhibiting agent

   •  Biomass  characteristics

   •  pH

   •  Temperature

   •  Synergism/antagonism
                                          10-1

-------
                   FROM FIGURE 5-1
             ACCUMULATE ALL APPLICABLE
             CRITERIA/PERMIT LIMITS FROM
            THE PHETHEATMENT  AUTHORITY,
             STATE, FEDERAL GOVERNMENT
      PRIORITIZE CRITERIA/PERMIT LIMIT INFORMATION
               USING THE POTW LOW FLOW
       AND CONCENTRATION, ADD THE CERCLA FLOW
    AND CONCENTRATION TO THE EXISTING POTW INFLUENT
                        WILL
                   'THE INFLUENT"
                   CONCENTRATION
                     INHIBIT THE
                     BIOLOGICAL
                     TREATMENT
                     >ROCESSESy
                          7
                          LYES
NO
              CERCLA DISCHARGE MUST BE
                PRETREATED TO AVOID
                  INHIBITION OF POTW
                TREATMENT PROCESSES
 ESTIMATE % REMOVAL DUE TO VOLATILIZATION
PARTITIONING TO SLUDGE, AND % PASS THROUGH
 FOR THE SPECIFIC POTW PROCESS.  ESTIMATES
   CAN BE BASED ON DATA REPORTED IN THE
  LITERATURE OR SPECIFIC POTW  TREATMENT
      DATA GENERATED BY THE FACILITY
             CALCULATE CONCENTRATION EXPECTED TO PASS
                 THROUGH IN THE EFFLUENT, VOLATILIZE
           AND/OR PARTITION  TO SLUDGE USING A CONSERVATIVE
                       ESTIMATE OF % REMOVAL
                                                                      WILL THE
                                                                   CONCENTRATION
                                                                       OF ANY
                                                                      COMPOUND
                                                                    EXCEED THE
                                                                    CRITERIA OR
                                                                       PERMIT
                                                                       LIMITS
                                                          ASSUME NO
                                                          ADDITIONAL
                                                         PRETREATMENT
                                                           REQUIRED
                                                                                                  FIGURE 10-1
                                                                      ESTIMATING POTW LOCAL LIMITS
•09*01
                                                         10-2

-------
                                                   ESTIMATE PRETREATMENT LIMITS
   •  Acclimation

Diverse biomass population characteristics in
various biological treatment plants will result in
significant variations in the inhibitory
concentration levels of pollutants. The pH plays a
particularly important role in metal-caused
inhibition because the solubility of metal ions is
directly related to pH.  When metals are in the
soluble state, they are the most toxic to
microorganisms.  Synergism (i.e., the increase in
the inhibitory effect of one substance by the
presence of another) is most important when
considering combinations of metals.  Toxic
organics do not exhibit this effect as often as
metals. On the other hand, some compounds are
antagonistic toward each other, decreasing the
inhibitory effect of either compound alone.

Substances that cause interference/inhibition
problems can be divided into three groups:
(1) conventional pollutants, (2) metals and other
inorganics, and (3) organic compounds.

Conventional Pollutants.  Conventional
pollutants consist of commonly measured
parameters, such as BOD, TSS, pH, and oil and
grease. Interference/inhibition problems result
from exceeding the peak mass loadings specified
by the plant design.  Such "shock loadings" (i.e.,
slug loadings) of conventional pollutants are a
common cause of permit violations resulting from
oxygen transfer limits, insufficient
biodegradation, and solids carryover.  Oil and
grease are normal constituents of domestic
wastewater which, if present in elevated
concentrations, can interfere with normal waste
treatment by preventing biological floe from
settling properly, limiting oxygen transfer, and
disrupting mechanical equipment operation. The
pH and temperature of wastewater can also cause
interference if either too high, too low, or widely
fluctuating.

When discharging CERCLA wastes to aPOTW, it
is important to consider how the  waste will
contribute to the concentrations  of various
conventional pollutants. For example,
compounds that are highly biodegradable increase
BOD loadings to the POTW, thereby placing an
increased demand on the treatment system. This
may or may not be the case when considering
compounds in which the major removal
mechanism is volatilization or partitioning to
sludge.

Metals and Other Inorganics. Research efforts
studying the impact of heavy metals on biological
treatment exceed those for all other classes of
compounds. Many of the insoluble metals and
metal salts that enter a POTW settle out during
primary or secondary clarification, impacting
sludge disposal alternatives.  The soluble
fractions of metals can upset the secondary
treatment processes.  Table 10-1 presents the
ranges of metal and other inorganic pollutant
concentrations inhibiting biological processes.
The value ranges reflect differences in the pH,
solubility, and definition of inhibition used by
researchers reporting the results.  In general, the
lower end of the range refers to concentrations
inhibiting unacclimated systems, while the upper
end of the range corresponds to acclimated
biological processes.

Organic Compounds.  The  amount of
information available on the impacts of organic
contaminants is small compared to metals, due in
large part to the number of compounds of interest,
as well as the sophisticated analytical equipment
required to measure these organics.  Table 10-2
presents the ranges of concentrations for toxic
organic compounds that inhibit biological
systems. However, data for specific compounds
are limited.

If the addition of the CERCLA contaminants to
the POTW influent is suspected of causing
biological interference, then the CERCLA waste
must be pretreated. Individual compounds in the
CERCLA waste should be evaluated to determine
the concentration at which biological inhibition
may occur. Treatability studies can also be
                                           10-3

-------
                                               TABLE 10-1
                                 BIOLOGICAL INHIBITION THRESHOLD
                                        INORGANIC COMPOUNDS
                                                             "        *
'' COMPOUND,
               CONCENTRE
               TJONRAN0E
            SCALE2
       REF*
                            CONCENtRA*
                            TIONRANG6
                                            CONCENTRA-
       REF3
AMMONIA
                 480
              U
       '  5
                1500-8000 (T)
              U
                 >480
              U
                                              1500-3000
                              U
ARSENIC
                 0.1
              U
       1,2,5
                1.6 (S)
              U
                 0.04-0.4
              U
                                              1.5
                              U
                                                                                           U
                                                                             0.1-1
                                                                          U
BORON
                 0.05-10
              U
                                                            U
CADMIUM
                  1-10
              U
                5.2
U
0.02 (S)
U
1,2
                  1
              U
                5.2
B
<20(T)
U
                 0.5-10
              U
                5-9
U
0.02-1
U
CALCIUM
                 2500
              U
CHLORIDE
                                                180
                                            U
                                              20000
                              U
CHROMIUM (TOT)
                  1-100
                              0.25-1.9
                              U
                1.5-50
              U
                 0.1-20
              U
                0.25-1
U
CHROMIUM Gil)
 15-50
lo
U
U
                50-500(8)
                130 (T)
                15
              U
              U
             17

-------
                                           TABLE 10-1
                                           (continued)
                                BIOLOGICAL INHIBITION THRESHOLD
                                     INORGANIC COMPOUNDS
**V,$ct^V'
•>"•' -X - is ;*
L.iMkk:5" \..:
COMPOUND
CHROMIUM (VI)


COPPER



CYANIDE




IRON
LEAD



MAGNESIUM
v '^iv^'^'iv*'^? •••.'^/^i' ?Ji*^lv A 'A ;
^^^l^i.^XMn-^i^-^" — -"-"-^-"^5^^'^^"^-
CONCENTRA*
TION RANGE
(ppm)1 !
1-10
1

1
1
0.1-1

0.1-5
0.1
5
0.05-20

5-500
1-5
0.1
10-100
0.1-10

SCALE2
U
u

U
p
u

u
u
F
U

U
U
U
B
U

REF3
1
2

1,2
5
4

1
2
5
4

4
1
2
5
4

S$ '?'' i\ '*•>#! ' %'"•'#•%'*. '{-.?'$ '"' r ^ •4rZ**J!} '"if''' ?'
*'&?&&***& "ซ ^^W^t^fi
,^..CI!,.^^'^*l,J-'"^->"^— ^^^••"•-•
CONCENTRA-
TION RANOE
(ppm)1
0.25
1-10

0.05
0.48
0.05-0.5

0.34-0.5 ,
0.34
0.3-20



0.5
0.5-1.7


50
SCALE2
U
U

U
u
u

u
u
u



u
u


u
REF3
1,2
5

1
2
4

1
2
4



1,2
4


4

CONCENTRA-
TI0NRANGE
i 
-------
           TABLE 10-1
            (continued)
BIOLOGICAL INHIBITION THRESHOLD
     1NOKCANIC COMPOUNDS
-^ ^ ^
<
/
> f~
COMPOUND
MANGANESE
MERCURY


MERCURY (II)
NICKEL



SILVER


SODIUM
SULFATE
SULFIDE

TIN
VANADIUM
'^^i^^^^!!-;i;i
f''f ^ ซ " s ' % I
,.,„?*,. -v / . / *> > * * |*N
CONCENTRA*
TION RANGE
, tppro)1 ,
10
0.1-1
0.1
0.1-5
2.5
1-2.5
1
5
1-5
0.25-5
5
0.03-5


25-30
>50

20
f
SCALE2/
U
U
U
U
B
U
U
P
U
U
U
U


U
U

U
REP3
4
1
2
4
5
1
2
5
4
1
2
4


5
4

4
8 ?i 3 f-v " ฃ ซ ป*
^ ปSK ^ ;MriaoRSC^rio^ - & * ,|
A j- Jj -^ $XA ,\ ^v:^ ?^^^
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CONCEN1PRA'
TIONRANOE
^pm)1 x

2-12.5



0.25-0.5
0.25
5
0.25-5
0.25








/
SCALE2,

U



U
U
P
U
U








! < /
REF3

4



1
2
5
4
4








||K? MP^PBIC^^E^IIMI[ *sfjS
^S "" " 5 "ซ< .. .x^L",^^
CCปICENTRA^
TlON,RAN0g

-------
                                                TABLE 10-1
                                                 (continued)
                                   BIOLOGICAL INHIBITION THRESHOLD
                                         INORGANIC COMPOUNDS
 ,  COMPOUND
CONCENTRE
TJON RANGE
,  (PR""}1
SCALE2
REF*
                                               CONCEN/tRA*
                                               TIONRANOE
                                                CONCENTRA-
SCALE2
       REF5
ZINC
                  0.3-5
                U
                   0.08-0.5
                        U
                    5-20 (S)
U
                  0.03
                U
                   0.03
                        U
                   400 (T)
U
                  5-10
                                 0.01-1
                                 U
                                         1.5
                                  U
                  0.30-20
                U
                                                   1-10
                                                       U
NOTES:
         Reference did not distinguish between total or soluble pollutant inhibition levels unless otherwise indicated; (T)-Total,
          (S)-Soluble
        2(U)-Unknown, (B)-Bench top, (P)-Pilot plant, (F)-Full scale
         References:
            1. Anthony and Breimhurst, 1981
            2. Russell, Cain, and Jenkins, 1983
            3. Tabak, Quave, Mashni, and Barth, 1981
            4. USEPA, 1987h
            5. USEPA, 1987i

-------
          TABLE 10-2
BIOLOGICAL INHIBITION THRESHOLD
      ORGANIC COMPOUNDS
IT
COMPOUND
1 ,1 ,1-TRICHLOROETHANE

1 ,1 ,2,2-TETRACHLOROETHANE
1 ,1 ,2-TRICHLOROETHANE

1 ,1 -DICHLOROETHANE
1 ,1-DICHLOROETHENE
1 ,2,4-TRICHLOROBENZENE
1 ,2-DICHLOROBENZENE

1,2-DICHLORETHAMฃ
1 ,2-DICHLOROPROPAME

1 ,2-DIPHEN YLH YDR AZINE
1 ,2-TR ANS -DICHLOROETHEMi
1,3-CYCLOPENTADIEMฃ,1,2)3,4,5
5-HEXACHLORO
1 ,3-DICHLOROBENZENE
1 ,4-DICHLOROBENZENE
•. f f f .A...,.-...
CONC
RANGE
, (ppmr '
•I :
+NI AT 10
360*
MAT 201
MATS
440*
MAT 10
MAT 10
MAT6
5

MAT 258
M AT 182
520*
5
MAT 10
MAT 10
5
5
^ &t "^ 1 "*"
^ซtf 3.^
SCAfcE2
B
B
U
B
B
B
U
B
B

U
U
B
B
B
B
B
B
* "• ' &
DT?T3^'t
f\CcJP
3'
6
2
3
6
3
2
3
3

2
2
6
3
3
3
3
3
JWJLlUJ
CONC
RANGE
y


















&C&Ott&
SCALED


















':y.
REF3


















^ AttogiM
CONC RANGE


20





. 0.23-3.8 (T)
0.23++
1






1.4++
|f m
zmmmm.
SCALED


U





B
U
U






U

>*>


2





5
2
2






2

-------
                                            TABLE 10-2
                                             (continued)
                                BIOLOGICAL INHIBITION THRESHOLD
                                       ORGANIC COMPOUNDS
                           C0NC
                                    SCALE*
      REP*
             CONC  *
             RANGE ;
                                                                          CONCRANG1
1,4-DICHLOROBENZENE
                                       1.4-5.3 (T)
                                                                                          B
2,4,6-TRICHLOROPHENOL
                           50
u
                           50-100
B
2,4-DICHLOROPHENOL
                           64
U
64
U
                           MAT 75
U
2,4-DIMETHYLPHENOL
                           40-200
u
                           MAT 10
B
                           190*
B
2,4-DINITROPHENOL
                                      B
              150
            u
                           110*
B
2,4-DINITROTOLUENE
                                      B
2,6-DINITROTOLUENE
                                      B
2-CHLOROETH YL VINYL
ETHER
                           MAT 10
B
2-CHLORONAPHTHALENE
                           MAT 10
B
2-CHLOROPHENOL
                           20-200
U
                           MAT 10
B
2-NITROPHENOL
                           MAT 10
B
2-PROPENAL
                           MAT 62
U

-------
           TABLE 10-2
           (continued)
BIOLOGICAL INHIBITION THRESHOLD
      ORGANIC COMPOUNDS
^ * $.Q J* ^•'••^ *, \ $r \ $ f AA *" Wv
', "> .ฃ. '•
COMPOUND
2-PROPENENITRILE

4-NITROPHENOL

ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE

BENZENE


BENZIDINE

BIS(2-CHLOROETHYL) ETHER
BIS(2-CHLOROISOPROPYL)
ETHER
BIS(2-ETHYLHEXYL)
PHTHALATE
BROMODICHLOROMETHANE
BUTYL BENZYL PHTHALATE
^s •*• "fr, x
CONC
RANGE

Krf
2

3
6
3
3
2
5
1
2
5
1
2
3
3
3
3
3
ซ **} * ;4<" '
CONC
RANGE


















w/wm
SCALED I


















&h
ฅ>1TJ'TJV
JCV-M*^


















f ป
CONC RANGE
(ppm)1
5(S)
5









5(S)
5





	 ^ i't '
cwimm
SCALE*
U
U









U
U





""I^U
RBF^
1
2









1
2






-------
                                           TABLE 10-2

                                            (continued)

                               BIOLOGICAL INHIBITION THRESHOLD

                                      ORGANIC COMPOUNDS
       COMPOUND
 CONC
RANGE
 {ppmf
REE3
        CONC
       RANGE
SCALED
                                                                        CONCRANGE
          SCALE*
     REF3
CHLOROBENZENE
                          140*
            B
                                0.96++
                            U
                                                                           0.96-3 (T)
                                                              B
CHLOROFORM
                          NI AT 10
            B
        10
  U
10-16(8)
U
                          500*
            B
                                1
                            U
                                                                           5-16(T)
                                                              B
CHLOROMETHANE
                          MAT 180
            U
                                3.3
                            U
                                                                           3.3-536.4 (T)
CHRYSENE
                          NIAT5
            B
DI-N-OCTYL PHTHALATE
                          NI AT 16.3
            U
DIBROMOCHLOROMETHANE
                          NI AT 10
            B
DIETHYL PHTHALATE
                          NI AT 10
            B
ETHYLBENZENE
                          200
            U
                          NI AT 10
            B
FLUORANTHENE
                          NIAT5
            B
FLUORENE
                          NI AT 10
            B
HEXACHLOROBENZENE
                                     B
HEXACHLOROBUTADIENE
                          NI AT 10
HEXACHLOROETHANE
                          NI AT 10
            B
ISOPHORONE
                          NI AT 15.4
            U

-------
           TABLE 10-2
           (continued)
BIOLOGICAL INHIBITION THRESHOLD
      ORGANIC COMPOUNDS
	 ,Xf.'-."..--^-*S.*5.^1lf.',.'lE'-r,'
^ -. % v^,
COMPOUND "-•>
METH YLENE CHLORIDE
N-NITROSODIPHENYLAMINE
NAPHTHALENE

NITROBENZENE

PCB - 1016
PCB - 1221
PCB - 1232
PCB - 1242
PCB - 1254
PENTACHLOROPHENOL



PHENANTHRENE

PHENOL

I ;, ' | 'j,* f i '^ jป
^>-:"-<-'^*if,--(ni~tn*Hnu 	 L 	 ' 	 ,.,...v.*.^.
CONC
RANGE,
- (PPM)1

MAT 10
500
500
30-500
500
NIAT1
NIAT1
NIAT10
NIAT1
NIAT1
50
0.95
75-150
2.6*
500
500
50-200
200
'SCALE2 -

B
U
B
U
U
U
U
B
U
U
U
U
B
B
U
B
U
U
REF*

3
1,2
5
1
2,5
2
2
3
2
2
1
2
5
6
2
5
1
2,5
* 	 "' i 	
1 '- -U3Btซfl
CONC
RANGE
- (ppW,
- ;' ',',
s s

















4-10
4
+f.*ซ <* , iJ^t-**'
^ ! f F' - jg^jg'lj
j. A^J j, w^JwRjf^^ J; y*
SCAtJB2 -

















U
U
w&

















I
1
fe M
^if^jKip!, -^^ >^ ^i^ ' „ g *•<. ^^ ^-^^
CONCRAM3E
, ^ , 
-------
                                                  TABLE 10-2

                                                   (continued)

                                    BIOLOGICAL INHIBITION THRESHOLD

                                            ORGANIC COMPOUNDS
        COMPOUND
 CONC
RANGE
 (ppm)
SC&UB*
  CONC
; RANGE
  (ppror
                                                                                    CONCRANGE
SCALE2
REF3
PHENOL
                              2.6
             B
PYRENE
                              NIAT5
             B
TETRACHLOROETHENE
                              NI AT 10
             B
                                              20
   U
TETRACHLOROMETHANE
                              NI.AT 10
             B
                                              10-20(8)
   U
                                                                                      2.9
                                                                       U
                                                                                      2.9-159.4(1)
                                                                       B
TOLUENE
                              200
             U
                              MAT 35
             U
TRIBROMOMETHANE
                              NI AT 10
             B
 TRICHLOROETHENE
                              NI AT 10
             B
                                              20 (S)
   U
                                                                                      20
                                                                       U
                                                                                       1-20 (T)
                                                                       B
 TRICHLOROFLUOROMETHANE
                              NI AT 10
             B
                                              0.7
   U
NOTES: Reference did not distinguish total or soluble pollutant inhibition levels unless otherwise indicated; (T)-Total, (S)-Soluble
                n, (B)-Bench top, (P)-Pilot plant, (F)-Full Scale
       References:
             1. Anthony and Breimhurst, 1981
             2. Russell, Cain, and Jenkins, 1983
             3. Tabak, Quave, Mashni, and Barth, 1981
             4. USEPA, 1987i
             5. USEPA, 1987h
             6. Volskay and Grady, 1988
                                 * Concentration reducing oxygen consumption by 50% of control
                                 + Nl-no inhibition at tested concentration

-------
ESTIMATE PRETRE ATMENT LIMITS
performed to test for the actual biological
inhibition concentrations.

10.1.2. Calculate Mass Balance

Once the biological inhibition concentrations of
contaminants in the CERCLA waste have been
estimated, the next step is to calculate a mass
balance for each compound in the CERCLA
waste. The purpose of the mass balance is to
calculate the general treatment efficiency of the
POTW and identify which POTW removal
mechanisms will be impacted by the removal of
each constituent from the CERCLA wastestream.

The level of treatment that can be anticipated in a
POTW for each contaminant varies widely. This
level is a function of the type of treatment process
and treatment efficiency at the POTW, the
physical and chemical properties of the pollutant,
and the mixtures and concentrations of the
contaminants in  the POTW influent. The three
principal toxic removal mechanisms in a
conventional wastewater treatment facility are
Stripping, partitioning (sorption) to the solids and
biomass, and biodegradation. The great majority
of "fate in a POTW" research has focused on the
priority pollutants. Much of the reported data
shows inconsistencies in removal efficiencies,
which is a result of the various treatment unit
processes used at POTWs; the scale of the
treatment process; the combinations of
compounds in the wastestreams and the
antagonistic/synergistic reactions occurring
within the POTW; the degree of acclimation at the
plant receiving  the waste; the ranges of
concentrations detected in the influents; and the
inconsistencies in sampling, handling, and
analytical techniques.  Despite the anomalies in
the treatability data for some compounds, certain
compounds have predictable fates in conventional
biological treatment processes; conservative
estimates of their fates can be made.

Several options are available to estimate a mass
balance in a POTW, including the following:
   • Use of specific POTW treatability
     data and/or data from
     POTW-specific bench-scale
     treatability studies

   • Use of published treatability data to
     calculate a mass balance for each
     compound detected in  the
     wastestream

   • Use of computer models

   • Where actual or published
     treatability data are not available,
     comparison of removals of
     compounds to similar
     physical/chemical data for which
     published  removal data are
     available

   • Use of the most conservative
     approach, assuming that  100
     percent of each compound ends up
     in the air, effluent, and sludge

POTW Treatability Data.   There  is no
substitute for actual POTW-specific treatability
data.  This is the most desirable method for
developing a mass balance, and it should be used
when the information is available. However, any
local limits  developed solely  by POTW
treatability experience should still be discussed
with the NPDES regulatory agency to confirm
acceptance. Situations will arise in which the
loading deemed acceptable by the POTW will not
be permitted by the regulatory agency.  In most
cases, actual POTW treatability data will not be
available for all the compounds and ranges of
concentrations detected in CERCLA  wastes.

If the POTW has not conducted treatability
studies in the past, treatability studies could be
performed by the POTW authority, or the FS
writer in conjunction with the POTW  authority, to
test specific biological response to compounds in
the CERCLA waste. These tests  would also
                                         10-14

-------
                                                  ESTIMATE PRETRE ATMENT LIMITS
indicate the removal mechanism for the
contaminants present in the wastewater and
expose problems that may be encountered when
treating the waste during full-scale system
operation.

Published Treatability Data. The second
alternative is to estimate a mass balance based on
published treatability data. In recent years, major
monitoring efforts have been performed to
•measure the fate of contaminants in conventional
biological treatment systems.  Research
conducted at the bench-, pilot-, and field-scale
levels has attempted to quantify the removal
efficiency of many priority pollutants in various
conventional biological treatment systems.
Attempts have also been made to measure the
percentages volatilized, partitioned to sludge, and
biodegraded; these attempts have been met with
varying degrees of success. Appendix C
summarizes treatability data for many
compounds.

Computer Models.  Computer  software
packages are available to help POTW authorities
and regulatory agencies develop local limits.
USEPA has released a computer program called
"PRELIM," which is intended to facilitate the
development of pretreatment programs  and
numeric limits by simulating the methodology
and calculations normally used in this
limit-setting process (USEPA, 1987i). The
program is designed to accept POTW-specific
data, and USEPA strongly encourages POTWs to
develop and use data specific to its plant  and
receiving environment.  However, PRELIM also
contains several data bases to which the user can
default if the POTW-specific data are not readily
available. PRELIM is written for local limitation
development for industrial  wastes, but can be
modified for various wastestreams. A list of other
computer software packages is  included in the
"CERCLA Site Discharges to POTWs
Treatability Manual" (USEPA, 1990).

Comparison of Compounds. Where removal
information is not available for a specific
compound, it is possible to estimate a mass
balance by comparing it to another similar
compound.  This can be accomplished by looking
at the physical/chemical constants and the
compound classes (see Subsections 10.2 and 10.3,
respectively), and locating similar compounds for
which mass balance information is available.

The Conservative Approach.  If all else fails
and there is no accurate way to estimate the mass
balance, then a conservative approach should be
used. It is assumed that 100 percent of the
compound volatilizes, 100 percent partitions to
the sludge,  and 100 percent passes through the
POTW and into the effluent. This approach
ensures that, regardless of the fate of a compound,
the worst possible case has been used for
comparison to standards and that the POTW and
the environment will be protected.

10.1.2.1.  Calculate Concentration in POTW
         Effluent

The first step in calculating a mass balance is to
sum the pollutant loading from the CERCLA site
with the existing loading in the POTW influent.
With this information, the user can calculate the
mass loading of each contaminant to the POTW
per day (mass/day). Appendix C presents the
mean percent  removal of compounds in
conventional biological wastewater treatment
systems for chlorinated and nonchlorinated
systems. Because a greater percent removal of
organic compounds is expected as influent
concentration increases, the total percent removal
data for each data set are broken down into ranges
of influent concentrations.

Data exist for approximately 160 compounds.
Care should be taken when using treatability data
from Appendix C to observe the number of
samples (N) collected and used to calculate the
mean percent removal.

Compounds with No Treatability Data. Total
percent removal may have to be estimated for
compounds for which there are no treatability
                                         10-15

-------
ESTIMATE PRETRE ATMENT LIMITS
data. This can be done by comparing the
physical/chemical properties of these compounds
to others with similar properties and for which
treatability data are available. The mean total
percentremoval calculated for certain compounds
based on just one or two data points should also be
compared to compounds with similar properties
that have more extensive treatability information
available.  Physical/chemical properties and
compound classification are discussed in
Subsections 10.2 and 10.3, respectively.

10.1.2.2.   Calculate Concentration in Air
          Emissions and Sludge

The next step in the mass balance calculation is to
estimate the amount of each compound that will
be air-stripped and partitioned to sludge in the
POTW. Appendix C presents tables showing the
mean percent volatilization and partitioning to
sludge that will occur for a limited number of
compounds. In each instance, when calculating
total percent removal  in the POTW and
percentages volatilized and partitioned to sludge,
the value present in Appendix C should be used in
the mass balance calculation.

10.1.23.   Calculate Amount Biodegraded

The purpose of estimating a mass balance is not to
account for 100 percent of each compound in the
CERCLA waste, but rather to develop an
understanding of which compounds will have the
greatest impact on the removal mechanisms, and
to identify these limiting compounds so that
pretreatment alternatives can be assessed. The
residual in the mass balance could be used to
estimate the percent biodegradation; however,
this has proven to be an inaccurate evaluation in
many cases. Therefore, the relative
biodegradability of many of the compounds
(i.e., rapid, moderate, slow,  and resistant) is
presented in Table 10-3.
10.1.3. Evaluate Permit Limit/Criteria
      Compliance

Once the relative concentrations of each
CERCLA compound predicted to volatilize,
partition to the sludge, or pass through the POTW
untreated have been determined, the pertinent
permit limits and other criteria must be assessed to
determine whether the POTW will be in
compliance.

Comprehensive guidelines regulating air
emissions, sludge loading, and effluent
concentrations are not likely to be available for all
compounds.  Therefore, it will be necessary to
request guidelines from the appropriate regulatory
agency or to develop environmental guidelines.

The NPDES regulatory agency will have the
ultimate responsibility for approving the level of
pretreatment required before discharging the
CERCLA waste to the POTW.

Compounds not treated by the POTW, as
measured by total percent removal, can be
assumed to pass through the POTW. The
concentration of each compound in the POTW
effluent (estimated in Subsection 10.1.2) should
be compared to the NPDES permit limits. If
NPDES permit limits do not exist for each
compound, federal or state ambient water quality
standards and criteria should be checked.

To date, only limited guidance for  acceptable air
emissions from POTWs is available. In the
absence of criteria, the user can identify and
estimate the area of all closed spaces within the
POTW treatment facility if volatilization is
expected to be a problem. The greatest volatile
organic compound (VOC) losses within the
POTW will  occur in an area where there is
turbulence (e.g., weirs and aeration tanks). The
concentration of VOCs in each closed space
should be estimated given the mass loading to air
(i.e., percent removal due to volatilization times
influent flow times concentration) and the
ventilation rate in the closed space. If the POTW
                                          10-16

-------
                                      TABLE 10-3
                       BIODEGRADABILITY OF COMPOUNDS
MISCELLANEOUS
Cyanides (soluble salts and complexes) NOS

PCB
PCB-1016
PCB-1221
PCB-1232
PCB-1242
PCB-1248
PCB-1254
PCB-1260

PESTICIDES (HERBICIDES)

DNBP \ Dinoseb \ 2-sec-buty 1-4,6-dinitrophenol

PESTICIDES (ORGANOHALIDES)
Endrin
Aldrin
Dieldrin
4,4'-DDD/Benzene
l,r-(2,2-dichlorethylidene)bis
  [4-chloro-4,4'-DDE/Benzene]
1 ,r-(dichlorethylidine)bis[4-chloro-4,4'-DDT/Benzene]
1 , 1 '-(2,2,2-trichIoroethylidene)bis
  [4-chloro-Chlordane]
Captan
Methoxychlor
Chlorobenzilate \Ethyl-4 ,4 '-dichlorobenzilate
6,9-Methano-2,3,4-benzodioxathiepin,
  6,7-Camphechlor

PESTICIDES (ORGANOPHOSPHORUS)
Naled \Dibrom
Phorate \Thimet
Disulfoton
Parathion \Parathion, ethyl
Methyl parathion \Parathion-methyl \Metaphos
                                                     M
                                                     S
                                                     M
                                                     M
                                                     S
                                                     O
                                                     O
                                                     O
                                                     O
                                                     O
                                                     O

                                                     O
                                                     O
                                                     S
                                                     S
                                                     O
                                                                    ANAEROBIC SYSTEM
                                                                              M
                                                                              M
                                                                              R
                                                                              M
                                                                              M
                                                                              M
                                                                              S
                                                                              R
                                                                              R
                                                                              R
                                                                              R
NOTES:    R = rapid
SOURCE: USEPA, 1987i
                            M = moderate
                                                 S = slow
                                                               O = resistant
                                          __

-------
                                  TABLE 10-3
                                   (continued)
                     BIODEGRADABILITY OF COMPOUNDS
"* '"'**•,'"• ^sC" '
•^ ^%T *•' ? ^ \ - Cs s •> *
REGULATORY NAME ^f A^r * r -v^-'.." '
'ซ ^Xv.ciif^.f'l 	 ."< ^Ir"''" "•
SEMIVOLATILES (ACIDS)
2,4,6-Trichlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2-Chlorophenol
Pentachlorophenol
Phenol
Resorcinol
SEMIVOLATILES (BASES)
1 ,4-Dichlorobenzene
2,6-Dinitrotoluene
2-Chloronaphthalene
33'-Dichlorobenzidine
Benzenamine
Benzidine
N-Nitrosodimethylamine
Nitrobenzene
Pyridine
SEMIVOLATILES (NEUTRAL)
1 ,2,4-Trichlorobenzene
1 ,2-Dichlorobenzene
1 3-Dichlorobenzene
4-Bromophenyl phenyl ether
Acenaphthylene
Benzo(a)anthracene
Benzo(a)pyrene
Bcnzo(b)fluoranthene
Benzo(ghi)perylene
Butyl benzyl phthalate
Chrysene
Di-n-octyl phthalate
Dibcnzo(a,h)anthracene
Dicthyl phthalate
Hexachlorobenzene
Hcxachlorobutadicne
S '
fff f '• ', '*"''% ' '' '
AEROBIC SYSTEM ' " "AN^BปC
A*>s % •• s % ' ' *••••'*

M
M
R
R
R
M
R
R

S
S
R
O
R
S
S
R
M

S
S
S
S
M
S
S
S
S
R
S
M
S
R
S
S
" •"
''
mC SYSTEM


M
M
R

R
S
R
R





R


R






M




R

M

R

S
NOTES:   R = rapid         M = moderate        S = slow      O = resistant
SOURCE: USEPA, 1987J
                                    __

-------
                                 TABLE 10-3
                                 (continued)
                    BIODEGRADABILITY OF COMPOUNDS
SEMIVOLATILES (NEUTRALS) (continued)
Hexachloroe thane
Naphthalene
bis(2-Chloroethoxy)methane
bis(2-Chloroethyl)ether
bis(2-Chloroisopropyl)ether
bis(2-Ethylhexyl)phthalate
VOLATILES
1,1,1 ,2-Tetrachloroethane
1 ,1 ,1-Trichloroethane
1 , 1 ,2,2-Tetrachloroethane
1 , 1 ,2-Trichloroethane
1 ,1-Dichloroethane
1 ,2,3-Trichloropropane
1 ,2-Dichloroethane
1 ,2-Dichloropropane
2-Picoline
2-Propenenitrile
Benzene
Bromomethane
Carbon disulfide
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
Dibromochloromethane
Dibromomethane
Ethylbenzene
Isobutyl alcohol
Methylene chloride
Tetrachloroethene
Tetrachloromethane
Toluene
Tribromomethane
TrichloroeuV-ne
Trichlorofluoromethanc
Vinyl chloride
trans- 1 ,2-Dichloroethene
fMftM"* SVST'lK'Mf % 5 )8
S
M
R
R
R
M

S
R
S
S
M
S
M
S
S
R
M
M
M
M
S
M
M
O
S
R
R
R
M
M
R
S
M
M
M
M
\ ••
S
M
R


M





M




R
M

M
M
S
S
M

S
R
M
M

M
R

S

M
M
NOTES:   R = rapid
SOURCE: USEPA, 1987i
M = moderate
S = slow
O = resistant
                                   10-19

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ESTIMATE PRETRE ATMENT LIMITS
is in a National Ambient Air Quality Standard
(NAAQS) nonattainment area for ozone,
additional restrictions may be imposed for VOC
discharges to the POTW.

Sludge disposal criteria are often available in state
guidelines and may vary among states. Criteria
regulating sludge disposal options for several
compounds are outlined in the checklist described
in Subsection 4.2.  Many of the criteria are based
on federal standards and apply to a wide range of
compounds and concentrations. The proposed
rule for "Standards for the Disposal of Sewage
Sludge" (40 CFR ง503) includes specific
numerical limits or equations for calculating these
limits for 28 pollutants in one or more use or
disposal methods.  In addition, the proposed rule
for Solid Waste  Disposal Facility Criteria
(40 CFR ง258) establishes numerical limits (in
the form of Groundwater Protection Standards)
for sewage sludge codisposed with municipal
solid waste. It should be noted that 40 CFR ง503
is currently a proposal, and limits will be
developed on a case-by-case basis using existing
regulatory framework and guidance. Additional
information can be found in, "Guidance for
Writing Case-by-Case Permit Requirements for
Municipal Sewage Sludge" (USEPA, 1988d).

10.1.4. Calculate CERCLA Site Discharge
      Limits

Afterthe mass balance andcriteriacomparison are
complete, the remaining task is  to calculate
acceptable CERCLA site discharge limits.  The
steps necessary to develop the CERCLA site
discharge limits are as follows.

Calculate acceptable POTW influent loading.
This is done by back calculating the influent
concentration/mass using the percent removals
and the criteria exceeded (e.g., if the criterion for
the POTW effluent is 12 parts per billion [ppb]
and the total percent removal is 40 percent, the
acceptable influent concentration is 20 ppb; or, if
the acceptable mass loading to air is 1 kilogram
per day  [kg/day] and the percent volatilized is
20 percent, then the acceptable influent loading is
5 kg/day). Mass-based (kg/day or Ibs/day)
acceptable influent loadings should be calculated.

If a compound exceeds criteria for more than one
medium, the acceptable POTW influent loading
should be calculated for each medium and the
lowest value should be used.

Subtract the existing loading to the POTW
from the acceptable loading. This will give the
remainder available for allocation.  A portion of
the available allocation should be reserved for
future industrial growth; the remainder can be
allocated to the CERCLA site. An accurate
characteristic of existing loadings to the POTW
from industrial and domestic sources is essential.
The  existing loadings plus the anticipated
loadings from the CERCLA discharges and any
safety factors, must not exceed the maximum
allowable loading.

Calculate the POTW discharge limits
concentrations.  This is done by dividing the
mass loading allocated to the CERCLA site by the
CERCLA site flow.

The new estimated pretreatment local limits can
now be used to select pretreatment technologies
for the site.

10.1.5. Toxicity Reduction Evaluation

The FS writer may also consider the toxicity of the
CERCLA wastewater especially if the POTW has
Whole Effluent Toxicity testing requirements in
its NPDES permit. If the GERCLA site discharge
is likely to cause the POTW to fail its effluent
toxicity testing criteria, a toxicity reduction study
can be performed.  The USEPA document,
"Toxicity Reduction Evaluation Protocol for
Municipal Wastewater Treatment Plants" outlines
a method to reduce toxicity to meet applicable
NPDES permit limits (USEPA, 1989a). The
evaluation first looks at possible in-plant sources
of toxicity. If plant performance is not the
principal cause of toxicity, the toxicity reduction
                                          10-20

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                                                   ESTIMATE PRETREATMENT LIMITS
evaluation (TRE) proceeds to toxicity
identification evaluation (TEE). TIE protocol is
performed in three phases: toxicity
characterization, toxicity identification, and
toxicity confirmation. During the evaluation,
batch-testing is performed on the site waste mixed
with the POTW wastewater to evaluate the
toxicity of the CERCLA site wastewater. The
causes of the toxicity are then identified using
specific test methods and confirmed through
additional toxicity tests. The FS writer is referred
to the TRE protocol manual for a more thorough
description of the procedures.


10.2. PHYSICAL/CHEMICAL
    PROPERTIES

The physical and chemical properties most often
used to predict the fate of contaminants in
wastewater treatment include the Henry's Law
constant, the octanol/water partition coefficient,
and the water solubility.  The potential for a
compound to biodegrade is another property
crucial in predicting fate. Although a
considerable amount of work has been done to
substantiate a compound's affinity for
biodegradation, it is impossible to predict the
exact amount of biodegradation that will occur
during biological treatment.  In most mass
balance equations, biodegradation is estimated as
the residual, or the percent of the compound not
accounted for after considering percentages
volatilized, partitioned to the sludge, and
untreated and passing through in the effluent.

Henry's Law constants, octanol/water partition
coefficients, solubilities in water, and molecular
weights for the ITD list of analytes are included in
the "CERCLA Site Discharges to POTWs
Treatability Manual" (USEPA, 1990).

The physical and chemical properties of a specific
compound can be used as an important reference
when treatability data are not available. The fate
of compounds sharing similar physical and
chemical properties can be compared so that the
treatability and the potential impact to the POTW
effluent, sludge, and air emissions can be
estimated for compounds for which there is no
treatability information. Comparison of
compounds based solely on physical and chemical
properties can be misleading, and should be used
only in the preliminary assessment to determine
which removal mechanisms may be most heavily
impacted.  Drawing conclusions from a
compound's physical and chemical properties
should not be used as a replacement for actual data
or treatability studies.

A general discussion of the important physical
and chemical properties used to characterize the
fate of contaminants in a POTW follows. This
information was summarized from the "Report to
Congress on the Discharge of Hazardous Wastes
to Publicly Owned Treatment Works" (USEPA,
1986b).

10.2.1. Henry's Law Constant

The Henry's Law constant, which is the ratio of a
substance's vapor pressure to its water solubility,
is used to relate the air and aqueous concentrations
of a volatile  substance at equilibrium.  It is an
appropriate means for estimating releases to air or
the ability of a chemical to be stripped or removed
from contaminated water. The higher the Henry' s
Law constant of a substance, the more likely it is to
migrate from water to air. Compounds with
Henry's Law constants greater than 10"  atm
m /mole have been shown in the literature to be
easily stripped. The most common formula given
for Henry's Law constant is as follows:
                H = Pv/Cs
where:
H = Henry's Law constant (atm m /mole)

Pv = compound's vapor pressure in air (atm)

Cs = compound's soluble concentration in water
     (mole/m )
                                          10-21

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ESTIMATE PRETREATMENT LIMITS
A pollutant's affinity to adsorb onto biomass or to
biodegrade will have an effect on the amount of
material stripped during conventional treatment.
These two variables may greatly control the total
amount of volatilization, particularly at low
concentrations, and should be considered when
estimating the ability to be stripped of compounds
inaPOTW.

10.2.2. Octanol/Water Partition Coefficient

The octanol/water partition coefficient (Kow) is a
measure of acompound's tendency to concentrate
either in the organic phases or in water at
equilibrium. The octanol/water partition
coefficient is a widely used tool for evaluating
water solubility and the subsequent potential for
sorption of organic compounds onto particulates
and biomass. KOW is often expressed as a
logarithm to the base 10, or Log Kow. In general,
compounds that have Log KOW values greater than
3,5 are significantly hydrophobic and adsorptive
on solid organic matter, such as mixed liquor
volatile suspended solids  (MLVSS) or sludge.
Compounds that have Log KOW values less than
3.5 are more likely to be removed through
biodegradation or, in the case of a more volatile
pollutant, through  air-stripping. Due to their
adsorptive nature, compounds with a high Log
KOW also may be expected to concentrate in
sludge.  In addition, the presence of other
compounds, electrolytes, oils and greases, and
sorbents may also greatly affect the rate and total
amount of adsorption that will occur in sludge.

10.2.3. Water Solubility

Water solubility is the maximum concentration of
a chemical that dissolves in pure water at a
specific temperature and pH.  Solubility of an
inorganic species can vary widely, depending on
temperature, pH, Eh (i.e., oxidation/reduction
potential), and the types and concentrations of
complex species present. Soluble chemicals tend
to be more readily biodegradable than those with
low solubility (Lyman et al., 1982). Solubility,
along with several other factors, can also affect
volatilization from water. In general, high
solubility is associated with lower volatilization
rates (Menzer and Nelson, 1980). Highly soluble
compounds are usually less strongly adsorbed to
organic material and, therefore, may be more
susceptible to pass through the treatment system if
not biodegradable.

10.2.4. Biodegradation

Biodegradation plays a substantial and sometimes
controlling role in the ultimate fate of the VOCs in
conventional wastewater treatment, especially
VOCs of moderate volatility. The extent of
biological oxidation depends on the ease of
biodegradation of the compound, availability of
co-metabolites  serving as food for the biota, and
the concentration of biologically active
solids (e.g., MLVSS and oxygen), as well as the
degree of acclimation of the MLVSS.

The rate of biodegradation can be influenced by
the availability of oxygen, a compound's extent of
halogenation, and biochemical oxidation. In a
well-aerated system,  air-stripping may be the
dominant removal mechanism for compounds
such as benzene and toluene, which biodegrade to
some degree under normal aeration conditions.
The degree of halogenation influences the relative
biodegradability of the compound, in that the
more halogens in a chemical compound by
weight, the less biodegradation will occur.
Biochemical oxidation is highest for organic
priority pollutants with low Log KOW values (less
than 3.5). In addition, air-stripping has been
shown to  compete with biodegradation as a
removal mechanism in activated sludge treatment
for some compounds  that have relatively high
Henry's Law constants (e.g., benzene, toluene,
ethylbenzene, and chlorobenzene).

Among the  three mechanisms (i.e.,
biodegradation, sorption, and volatilization), the
dominant removal route at any one time will
depend on the relative rates of aeration. The
removal mechanisms are affected critically by the
plant design and flow, air-to-liquid rates, and the
                                          10-22

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                                                  ESTIMATE PRETRE ATMENT LIMITS
concentration and activity of MLVSS. These
factors are critically dependent on how well the
facility is run, and the distribution, characteristics,
and concentrations of the pollutants in
wastewater.  If the treatment system is acclimated
to the pollutants in the plant influent,
biodegradation may be a more effective removal
mechanism for biodegradable compounds. In
unacclimated treatment systems, removal of
many organics by volatilization and sorption to
solids and biomass may be more significant than
in acclimated systems. Dissolved salts also affect
all three removal mechanisms associated with
biological treatment systems. Factors such as
surface tension, interstitial tension, viscosity, and
diffusion also must be considered in ultimate
environmental fate analysis.


10.3. COMPOUND CLASSIFICATION

The compounds described in this section are the
443 compounds included in the USEPA Office of
Water Industrial Technology Division (ITD) list
of analytes (USEPA, 1987b). For the purposes of
this guidance manual, the compounds were
categorized into one of the following seven
classes:

   • Volatile organic compounds
     (VOCs)

   • Semi volatile organic compounds
     (SVOCs)

   • Pesticides and herbicides

   • Polychlorinated biphenyls (PCBs)

   • Dioxins and dibenzofurans

   • Elements

   • Miscellaneous
The compounds were categorized based on
various physical properties (e.g., solubility and
volatility), as well as similarities in chemical
structure. Another major factor considered in the
compound classification is the USEPA analytical
method used to quantify the chemical.  The
"CERCLA Site Discharges to POTWs
Treatability Manual" (USEPA, 1990) classifies
each compound by Regulatory Name (except for
pesticides, which are listed by Common Name).
The Regulatory Name is not always the familiar
compound name reported; therefore, the
compounds are also sorted by Chemical Abstract
System (CAS) Number and Common Name to
help locate the specific compounds of interest.
The comprehensive listing of compounds in
SARA Title III, Section 313, is also
recommended for identifying compound
synonyms and CAS numbers.

The general discussion presented in this section
concerning the compound classification relates to
pure compounds.  The synergistic  and
antagonistic effects of mixtures of compounds is
likely to significantly alter their inherent
physical/chemical properties, but  the magnitude
of these alterations is difficult to predict. For
example, the presence of organic solvents in a
wastewater stream will greatly enhance the
solubility of compounds such as PCBs.  For
treatability purposes, bench- or pilot-scale
evaluation is helpful.

10.3.1. Volatile Organic Compounds

VOCs consist of organic liquids and gases, which
are generally amenable to analysis by purging
from the sample with an inert gas and analyzing
the purged compounds via gas chromatography
(GC). A total of 63 VOCs is included in this class.
Most compounds classified as volatile have a
molecular weight less than 250, a Henry's Law
constant greater than 4x10 atm m /mole,
solubility in water ranging from completely
miscible to less than 1 mg/L, and log KOW
partition coefficients ranging from less than zero
to occasionally greater than 3.
                                         10-23

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ESTIMATE PRETRE ATMENT LIMITS
Groups of compounds within this class include
aromatics, halogenated aliphatics, halogenated
aromatics, alcohols, ketones, aldehydes, and a
group of miscellaneous compounds (Table 10-4).
The groups can be further categorized by their
purge efficiency. The range in volatility as
expressed by Henry's Law constants and
solubilities indicates that the purge efficiency for
these compounds ranges from near zero to 100
percent. In general, halogenated compounds are
very purgeable, while oxygenated ones are poorly
purged. Therefore, the alcohols, ketones, and
aldehydes are considered poorly purged, while the
aromatics, halogenated aromatics, and
halogenated aliphatics purge well. Conversely,
the poorly purged compounds are an excellent
food source for biodegradation.

10.3.2. Semivolatile Organic Compounds

The class of 175 S VOCs consists primarily of
those organic compounds not elsewhere
categorized and not amenable to analysis by
purging  from the sample. Instead, various
extractions are performed, and the extracts are
concentrated and then analyzed  via GC. This
class is further subdivided into groups based on
whether the compounds are extracted from the
sample under acid, base, or neutral conditions.
There are 24 acid-extract able,  40
base-extractable, and 111 neutral-extractable
organic compounds. The neutral-extractable
SVOCs are commonly analyzed in conjunction
with the base-extractables.

The acid-extractable organics are primarily
phenolics and, while biodegradable, are more
likely to adsorb to organic  sludges.
Biodegradability decreases with  increasing
halogenation. The water solubility ranges from
less than 1 to approximately 93,000 mg/L.
Molecular weights generally range between 90
and 270.  Henry's Law constants are mostly less
than 10"  atm m /mole. Log KOW ranges from
less than 1 to 5.
The base-extractable organics characteristically
contain nitrogen. Most are more biodegradable
than other extractable organics. Molecular
weights range from approximately 70 to over 270.
Solubility in water may be less than 1 to over
2,000 mg/L. Henry's Law constants are typically
less than 10" atm m/mdle and decrease to 10
atm m /mole; however, a few compounds,
notably dichlorobenzene, are reported at 10  atm
m /mole.  The dichlorobenzenes may also be
determined analytically with the volatile fraction,
if desired.

Data for log KOW are scarce and apparently range
from near zero to 8  (but more typically 2 to 8),
indicating a propensity to adsorb on organic
solids.

The neutral-extractable organics, the largest
group of extractable organics, contain aromatics,
polynuclear aromatics, heterocyclics, and
long-chain aliphatics; all may be halogenated or
otherwise substituted. Of the extractable fraction,
the neutral extractables are the most refractory in
regard to biodegradation. Molecular weights
range from 75 to 400.  Solubility in water is
generally low, typically less than 100 mg/L, but
ranges  up to approximately 900 mg/L. Henry's
Law constants are typically less than 10"  atm
  "t                         9       0
m /mole, with a range of 10"  to 1 0  atm
m /mole.

10.3.3. Pesticides and Herbicides

There are 88 compounds in the pesticides and
herbicides classification, including
35 organo-halide, 41 organo-phosphorus,
10 carbamate, and 2 nitrophenolic  compounds.
Analytically, the pesticides and herbicides are
determined in a fashion similar to SVOCs
(i.e., extract, concentrate, and analyze using GC).
The nitrophenolics and phenoxyacetic acids are
considered exclusively herbicides; the others may
function as pesticides or herbicides. The
carbamate (i.e., containing nitrogen) and
organo-phosphorus (i.e., containing phosphorus)
compounds both hydrolyze rapidly in water to
                                          10-24

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                                                  ESTIMATE PRETRE ATMENT LIMITS
                                     TABLE 10-4

                   VOLATILE ORGANIC COMPOUND SUBCLASSES
ALCOHOLS
2-Propen-l-ol
Isobutyl alcohol

ALDEHYDES
2-Butenal
2-Propenal

AROMATICS
Benzene
Ethylbenzene
Styrene
Toluene
o + p xylene

HALOGEN ATED ALIPHATICS
1,1,1,2-Tetrachloroethane
1,1,1 -Trichloroe thane
1,1,2,2-Tetrachloroethane
1,1,2-Trichloroethane
1,1 -Dichloroethane
1,1 -Dichloroethene
1,2,3-Trichloropropane
1,2-Dibromoethane
1,2-Dichloroethane
1,2-Dichloropropane
1,3-Dichloropropane
3-Chloro-1 -propane
l,4-Dichloro-2-butene (mixture of cis and trans)
2-Chloro-1,3-butadiene
Bromodichloromethane
Bromomethane
Chloroethane
Chloroform
Chloromethane
Dibromochloromethane
Dibromomethane
Dichloroiodomethane
lodomethane
HALQGENATED ALIPHATICS (continued)
Methylene chloride
Tetrachloroethene
Tetrachloromethane
Total xylenes
Tribromomethane
Trichloroethene
Trichlorofluoromethane
Vinyl chloride
cis-1,3-Dichloropropene
trans-1,2-Dichloroethene
trans-1,3-Dichloropropene
trans-1,4-Dichloro-2-butene

HALOGENATED AROMATICS
1 -Bromo-2-chlorobenzene
l-Bromo-3-chlorobenzene
Chlorobenzene

KETONES
2-Butanone
2-Hexanone
2-Propanone
4-Methyl-2-pentanone

MISCELLANEOUS
1,4-Dioxane
2-Chloroethylvinyl ether
Carbon disulfide
Diethyl ether
Ethyl methacrylate
Methyl methacrylate
Vinyl acetate

NITROGEN COMPOUNDS
2-Picoline
2-Propenenitrile
2-Propenenitrile-2-methyl-chloroacetonitrile
Ethyl cyanide
                                         10-25

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ESTIMATE PRETREATMENT LIMITS
alcohols. They function as pesticides through
cholinesterase inhibition. These compounds are
typically high in molecular weight (i.e., 200 to
500). The pesticides are low in water solubility
(generally less than 100 mg/L), while the
herbicides are soluble in water up to 1,000 mg/L.

103.4. Polychlorinated Biphenyls

Seven PCB mixtures (also known as Aroclors) are
included in the PCB classification. The mixtures
are differentiated by the amount of chlorine in the
Aroclor. The last two digits of the Aroclor
number denote the percentage of chlorine (except
PCB-1016, which is 41 percent chlorine). PCBs
were widely used for various applications due to
their extremely good thermal and chemical
stability; production was  banned in 1976.
Analytically, PCBs are determined via extraction
and GC,

Except for PCB-1232, the solubility of these
mixtures in water is less than 0.6 mg/L. PCBs are
very hydrophobic and are most likely to be found
adsorbed to organic solids. Log KOW ranges
between 4 and 7, and published Henry's Law
constants  are 10"3 to  1 O^atm m3/mole;
biodegradability is very low.

10.3.5. Dioxins and Dibenzofurans

These compounds are characterized by two
benzene rings linked by either one (furans) or two
(dioxins) oxygen molecules.  The rings may
undergo chlorine substitution at up to eight
locations, creating families of compounds
(e.g.,  there  are  22  possible
tetrachlorodibenzodioxins). Molecular weights
exceed 300. Dioxins and furans are very
hydrophobic, with solubilities in many cases less
than 1 mg/L and log KOW greater than 6.
Therefore, these compounds are expected to be
found adsorbed to the organic solids.

10.3.6. Elements

Seventy elements, primarily metals, are identified
on the ITD list of analytes. The elements may be
divided into two separate subcategories in
reference to then" natural state in solution: cations
and anions. Cations are positively charged, while
anions are negatively charged.

These identified elements form predominantly
inorganic compounds, but are included in some
organic compounds as well. Metals generally
combine to form insoluble salts and concentrate in
the sludges.

10.3.7. Miscellaneous

The miscellaneous class includes the remaining
29 analytes on the ITD list of analytes.  Most are
useful in controlling treatment processes or as
indicators, and are commonly referred to as the
conventional contaminants in biological
treatment systems  (i.e., BOD, COD, and TSS).
Several others classified as miscellaneous are
used to characterize a solid waste for disposal.
                                          10-26

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              SECTION 11
HYPOTHETICAL CASE STUDIES

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11. HYPOTHETICAL CASE STUDIES
Three hypothetical case studies were developed to
guide FS writers, regulatory agencies, andPOTW
authorities through the process of evaluating the
potential for discharging CERCLA wastes to a
POTW. In most cases, evaluation of the POTW
discharge alternative will be complicated by many
technical and administrative requirements and
concerns.  Therefore, it is essential to perform a
preliminary screening of the POTW alternative.
The purpose of the initial screening is to identify
the site-specific technical and administrative
issues  that will influence the outcome of the
evaluation.  It is important to identify and
understand these issues early in the evaluation of
the remedial alternatives to determine whether a
full-scale detailed evaluation of the POTW
alternative is warranted. There will be cases
where the POTW discharge alternative can be
ruled out early in the FS process; an example of
this is included in the case studies.

The  case  studies describe the preliminary
screenings of the POTW discharge alternative for
three unique wastestreams. Each assessment
closely follows the stepwise approach for
evaluating the discharge of CERCLA waste to a
POTW, as presented in this guidance manual.
Each case study highlights the important technical
and administrative issues raised during the course
of the  evaluation. With the examples and
information presented in the case studies, FS
writers, regulatory officials, and POTW
authorities will become more familiar with many
of the important technical and administrative
issues  involved and will be able to apply this
information to perform a preliminary screening of
the POTW alternative.

The  case studies were designed using actual
analytical data obtained from four CERCLA sites.
Initially, each case study writer was given a data
set and a hypothetical flow volume and rate, and
was  told what state the CERCLA site was in.
Three USEPA regions were selected for the case
studies to take into account any regional
differences in administrative requirements.
Given the background information, the case study
writers identified and contacted the appropriate
location of the hypothetical CERCLA site. State
and USEPA officials were instrumental in helping
the case study writer to gather information
concerning actual POTW authorities that were
operating in the designated area.

The case studies were organized to follow the
procedures for evaluating the discharge of
CERCLA wastes to a POTW, as presented in this
guidance manual. To assist the guidance manual
user, each case study is prefaced with a summary
of the contents of the case study (i.e., wastestream
characteristics, specific technical/administrative
issues, and results of the evaluation).  Therefore,
the guidance manual user can screen the case
studies and determine which case study presents
the most relevant information useful to his/her
own evaluation.
11.1. CASE STUDY #1

Case Study #1 evaluates the remedial alternative
of discharging a finite quantity of liquid waste
from a lagoon to a POTW. The lagoon is 0.5 acre
in area; the depth of liquid waste averages
approximately 4 feet. Field investigations during
the RI determined that the lagoon was lined;
therefore, the only on-site waste requiring
treatment was the approximately 650,000 gallons
of liquid in the lagoon. Samples from the lagoon
that were collected for analysis revealed elevated
concentrations of many organics (i.e., benzoic
acid, acetone, chloroform, phenol, and toluene)
and inorganics (i.e., aluminum, cadmium,
magnesium, and manganese).

Five POTWs within a 10-mile radius of the site
were identified for the feasibility screening
evaluation. A sewer line was not present at the
                                           11-1

-------
HYPOTHETICAL CASE STUDIES
site. Therefore, Case Study #1 emphasizes
administrative issues and concerns associated
with obtaining permits to truck or pipe liquid
waste to a POTW. A complete evaluation of
treatability of the liquid waste in a POTW that
employs activated sludge is also included in Case
Study #1.

11.1.1. Identify and Characterize CERCLA
      Wastewater Discharge

The CERCLA wastestream is liquid waste
contained in a half-acre lagoon. Approximate
volume of wastewater requiring treatment is
650,000 gallons. Analytical work from the RI
phase identified concentrations of contaminants
in the lagoon (Table 11-1). The waste fails TCLP
tests for cadmium, and contains several
compounds in excess of the  Maximum
Contaminant Levels (MCLs). The RI risk
assessment indicated the lagoon waste is a hazard
to human health and the environment.

Lagoon contents are classified as solid waste
because they have been discarded and abandoned
(40 CFR 261.2). Under RCRA regulations, the
lagoon waste is classified as hazardous because it
fails TCLP testing and cannot be excluded from
regulation under 40 CFR ง261.4(b). Hazardous
Waste No. D006 is assigned to the lagoon,
corresponding to cadmium (i.e., the contaminant
causing it to be hazardous  [40 CFR ง261.24]).

11.1.2. Identify Potential Local POTWs

The site is not located near any POTW sewer
lines; therefore, liquid waste will have to be taken
to a local POTW using trucks or dedicated pipe.
For the purpose of this evaluation, a pumping rate
of 5,000 gallons per day (gpd) will be used to
assess pumping and/or hauling costs associated
with transporting the wastestream to the POTW.
POTWs located within a 10-mile radius of the
lagoon were identified, and will be evaluated as
potential receptors of the piped or trucked liquid
waste.
The USEPA regional Water Management
Division was contacted for assistance in locating
POTWs and making contact with POTW
authorities (i.e., within the 10-mile radius chosen
for initial screening of the POTW discharge
alternative). The USEPA Pretreatment
Coordinator recommended two POTW
Authorities (i.e., POTW Authorities A and B),
which operate a total of five plants in the area.

11.1.3. Involve POTW in Evaluation Process
      and Screen POTWs

USEPA personnel emphasized the importance of
involving all concerned parties early in the
evaluation process to arrive at a suitable treatment
scheme.  Both POTW authorities were contacted
to determine if the POTWs were willing to accept
a CERCLA discharge, to obtain information
about technical capabilities (e.g., capacity and
unit operations), and to determine compliance
status of the POTWs. The state was then notified
about POTWs being considered. Useful
information for screening  POTWs was obtained
from these initial contacts.

11.1.3.1.  Determine Compliance Status

The compliance status of the five POTWs
identified within the 10-mile radius was checked
using the compliance checklist (see Subsection
4.2) and by telephoning the Regional Off-site
Coordinator.  POTW Authority A administers
three treatment plants (i.e., POTWs 1, 2, and 3);
each is currently in compliance with applicable
permits  and regulations. POTW Authority B
administers two treatment plants (i.e., POTWs 4
and 5). POTW 5 is currently in violation of its
NPDES permit; therefore, it was eliminated from
consideration as a potential waste receiver.
POTW 4 is in compliance with applicable permits
and regulations. POTWs 3,4, and 5 participate in
the National Pretreatment Program.  None of the
POTWs is currently a RCRA permit-by-rule
facility (see Subsection 3.1.2).  There was no
information on any of the facilities indicating a
significant potential for contamination of
                                          11-2

-------
                                                    HYPOTHETICAL CASE STUDIES


                                    TABLE 11-1

                                  CASE STUDY #1

 CONCENTRATIONS OF POLLUTANTS DETECTED IN CERCLA SITE WASTESTREAM
                    •"v\   '-'if*
Organics
1,1,2,2-Tetrachloroethane                                  3,040
1,2-Dichloroethane                                       1,450
2,4-Dichlorophenol                                      10,000
2,6-Dichlorophenol                                      10,000
Acetone                                               68,580
Benzene                                                3,740
Benzoic Acid                                        4,050,000
Benzyl Alcohol                                         10,000
Chlorobenzene                                           3,100
Chloroform                                            12,600
Chloromethane                                          16,100
Ethylbenzene                                            2,690
Methylene Chloride                                       5,340
Phenol                                             2,090,000
Tetrachloroethene                                        3,470
Toluene                                               14,200
Trans-1,2-dichloroethene                                  1,720
Trichloroethene                                          4,150

Herbicides/Pesticides
Dieldrin                                                  42
Lindane                                                  75

Metals
Aluminum                                              5,530
Antimony                                                200
Arsenic                                                   40
Cyanide                                                  28
Cadmium                                               2,820
Calcium                                             1,080,000
Copper                                                   52
Iron                                                 1,230,000
                                        11-3

-------
HYPOTHETICAL CASE STUDIES
                                      TABLE 11-1

                                      (continued)

                                    CASE STUDY #1

  CONCENTRATIONS OF POLLUTANTS DETECTED IN CERCLA SITE WASTESTREAM
 POLLUTANTS
 Metals (continued)
 Magnesium
 Manganese
 Nickel
 Selenium
 Sodium
 Thallium
 Zinc
 Lead
 Phosphorus
 Potassium
         306,000
          14,400
           2,210
             20
       4,020,000
             20
            830
           1,550
         169,000
         840,000
ug/L ซ micrograms per liter
groundwater from impoundment of the CERCLA
wastewater.

To be eligible to receive the hazardous lagoon
waste by either truck, rail, or dedicated pipe, a
POTW must comply with its NPDES and other
permits, and RCRA reporting and manifest
requirements (40 CFR ง270.60).  Remedial
activities at the lagoon site would need to comply
with the substantive requirements of the RCRA
standards for hazardous waste generators (40 CFR
ง262) and transporters (40 CFR ง263).

11.1.3.2.   Consider Technical Feasibility

A screening table was prepared to evaluate
technical feasibility of the five POTWs (Table'
11-2). Of the three POTWs in the Authority A
district, only POTW 3 treats industrial waste.
POTW 3 uses activated sludge secondary
treatment and incinerates its sludge. POTWs 1
and 2 are low-flow primary treatment plants, and
were excluded from consideration because their
unit operations were unsuitable for treatment.

The POTW closest to the site is POTW 4,
administered by POTW Authority B. This plant
uses activated sludge secondary treatment and
landspreads sludge. POTW 4 has sufficient
excess capacity to treat lagoon waste over the five
to six months it is expected to be discharged.
Therefore, based on technical feasibility, POTWs
1 and 2 were excluded as potential receptors.
                                         11-4

-------
                                                      HYPOTHETICAL CASE STUDIES
                                     TABLE 11-2

                                   CASE STUDY #1

                   EVALUATION OF TECHNICAL FEASIBILITY OF

            CERCLA WASTESTREAM DISCHARGE TO IDENTIFIED POTWs
      CRITERIA
 Does the POTW have
 hydraulic capacity to
 handle additional
 CERCLA wastestream
 flow?

 Are unit operations
 suitable for treatment of
 contaminants in the
 CERCLA wastestream?

 Is there a domestic
 sanitary sewer piping
 system running from the
 CERCLA site to the
 POTW?

 Distance from CERCLA
 site to POTW? (miles)


 POTW's sludge disposal
 process?

 Could the POTW treat
 the CERCLA
 wastestream for the time
 duration required?
Yes
No
No
6.0
Yes
                        POTWS
No
Yes
Yes
No
No
Yes
Yes
Yes
No
No
No
No
3.0
5.0
0.5
7.0
 Landfill     Landfill     Incinerate   Landspread  Incinerate
No
Yes
Yes
No
11.1.3.3.  Consider Administrative
         Feasibility

The reaction of POTW Authority A to potentially
accepting the lagoon waste varied. Acceptance of
the waste was not summarily refused; however,
                  the waste originates in the Authority B district;
                  therefore, Authority A believes the waste is the
                  primary responsibility of Authority B. Authority
                  A expressed a strong disinterest in meeting RCRA
                  permit-by-rule requirements if the lagoon waste
                  were trucked or piped from the site to be treated by
                                         11-5

-------
 HYPOTHETICAL CASE STUDIES
 Authority A. POTW 3 was excluded from further
 consideration because administrative obstacles
 were encountered during negotiations with
 Authority A.

 As a result of accepting several industrial
 wastestreams, local limits for industrial
 discharges to POTW 4 were recently developed
 for metals, cyanide, oil and grease, and several
 organics. The POTW 4 operator stressed that
 these limits apply to all dischargers to the plant.

 The NPDES authority developed NPDES limits
 for all the CERCLA site contaminants not
 currently limited in the POTW's NPDES permit.
 Additionally,  the POTW officially developed
 local limits for all compounds in the CERCLA
 waste before the CERCLA site discharge was
 implemented. In addition to creating limits,
 developing NPDES and local limits helped reduce
 the POTW's long-term liability.

 Developing discharge limits for the lagoon waste
 would be an iterative process based on several
 technical and administrative factors. The
 following factors would have significant impact
 on the decision to truck or pipe the lagoon waste to
 a POTW: (1)  water quality standards for the
 receiving body of water, and other regulations;
 (2) NPDES permit limits;  (3) treatability
 characteristics of the POTW; (4) potential for
 pretreatment of the lagoon waste; (5) associated
 costs of pretreatment and trucking or piping to the
 POTW; (6) liability for accepting the waste; and
 (7) political pressure.

 The POTW 4 operator expressed a willingness to
 accept the waste if he were relieved of liability
 issues. Under SARA Section 119(c)(5)(D),
 indemnification from liability to response action
 contractors cannot be provided to facilities
regulated under RCRA (including RCRA
permit-by-rule POTWs). The POTW 4 operator
 subsequently decided to meet the RCRA
permit-by-rule requirements during the CERCLA
site discharge.
Many issues that will ultimately determine the
outcome of a POTW discharge alternative are
administrative and political, and cannot be
predicted in the initial screening of the POTW
alternative. However, for the purpose of
completing Case Study #1, the FS writer assumed
that POTW 4 will comply with the RCRA
permit-by-rule regulations and, therefore, is
capable of accepting the waste via truck or
dedicated pipe.

11.1.4. Obtain/Estimate POTW Local Limits

11.1.4.1.  Obtain Local Limits

The FS team requested a copy of POTW 4 local
limits on discharges, NPDES permit limits, and
sludge disposal permit limits. The operator
indicated that local limits on organics were
derived from the USEPA Toxicity Characteristic
Leaching Procedure proposed regulatory levels
(Federal  Register,  1986). Because of the
relatively small volume and short duration of the
wastestream discharge, the operator indicated that
no influent limits  would  be placed on
conventional and nonconventional pollutants,
except for oil and grease. Local limits for metals
would be imposed as for other discharges to the
plant.  The operator stated that sludge from
POTW 4 is not considered a hazardous waste;
therefore, it does not need to be disposed of as
such. Sludge samples are routinely analyzed for
metals and TCLP. The operator explained that
discharge limits for metals are imposed on
industrial users to ensure metal loading does not
impact sludge quality. Table 11-3 shows the
treatment process currently employed at POTW 4.

11.1.4.2.  Estimate Local Limits

After state and USEPA officials conditionally
approved the operator's initial assessment of the
CERCLA wastestream discharge requirements,
the FS team prepared summary tables to identify
and assess the fate and treatability of compounds
in the  wastestream at POTW 4 requiring
pretreatment.
                                          11-6

-------
                                                      HYPOTHETICAL CASE STUDIES
                                     TABLE 11-3

                                   CASE STUDY #1

                          TREATMENT PROCESS AT POTW 4
 Screening
 Grit Removal
 Pretreatment
 Primary Settling
 Intermediate Treatment
 Activated Sludge
 Filters
 Disinfection
 Sludge Digestion
 Sludge Disposal
TRE AT&HaSfT METHODS
\

Bar Rack
Grit Chamber
None
Clarified
None
Conventional
None
Chlorine Gas
Anaerobic
Land Spreading	
After studying information from this document
andPOTW-specific inhibition data, theFS writers
determined that pollutant concentrations in the
wastestream were not sufficiently high to cause
biological inhibition of POTW treatment
processes.

Table 11-4 presents mass balance information for
compounds in the CERCLA wastestream.  The
purpose of mass balance is to calculate general
POTW treatment efficiency and to identify
POTW removal mechanisms (i.e., partitioning to
sludge and volatilization) impacted by constituent
removal from the CERCLA wastestream.
POTW-specific treatability data were not
available for all contaminants in the lagoon;
therefore, liquid waste, total removal,
volatilization, and partitioning percentages were
compiled from treatability data in Subsection 10.2
and other POTW treatability data.

Table 11-5 summarizes the treatability of the
CERCLA wastestream at POTW 4 and identifies
compounds that require pretreatment.  For
compounds  with local limits, pretreatment
decisions were straightforward. For compounds
   without specifically regulated discharge
   concentrations, the pretreat-or-discharge decision
   was made by calculating effects of CERCLA
   discharge on the quality of POTW influent and
   effluent.  Predicted POTW effluent
   concentrations were compared to effluent limits,
   including existing permit limits, Ambient Water
   Quality Criteria (AWQC), and drinking water
   standards to determine whether compounds in the
   CERCLA wastestream will be effectively treated
   at the POTW or whether pretreatment will be
   required.

   TheFS team's mass balance and treatability tables
   were examined by USEPA, state, and POTW
   officials.  After negotiations, the groups
   tentatively agreed on the list of compounds
   requiring pretreatment (see Table 11-5).
                                          11-7

-------
                                      TABLE 11-4
                                    CASE STUDY #1
             MASS BALANCE FOR CERCLA WASTESTREAM CONTAMINANTS AT POTW 4
* t - - = -- *
f -f" V '' ' *
^V** ^> KH^ISPPAJST, ,
>,,v^.;...,.f,.,., .v,. ./...-...,. ^.,... .^
Orgartics
1 ,1,2,2-Tetrachloroethane
1,2-Dichloroethane
2,4-Dichlorophenol
2,6-Dichlorophenol
Acetone (2-Propanone)
Benzene
Benzoic Acid
Benzyl Alcohol
Chlorobenzene
Chloroform
Chloromethane
Ethylbenzene
Methylene Chloride
Phenol
Tetrachloroethene
Toluene
Trans- 1 ,2-dichloroethene
SrTECON-
f AMJ^ANT
'C0#i
€ปBA-
-ttWtmgty
j. ^ftrfwv j"'-,"f'j'j-r -ftps •"";

3.04
1.45
10.00
10.00
68.58
3.74
4050.00
10.00
3.10
12.60
16.13
2.69
5.34
2090.00
3.47
14.20
1.72
€AL€t!LATlD i
€Q^Aiyi(
'

45
0
O2
1

ND
ND


86
24




63
^ j.
.IUSSIPC^!
AlR:
' '

12.3
0
0
13.0





262.2
12.2




20.5
' * ''
*,"
^%tO-,v
v $Li|DO^
x *
' ' ' ,

4
8
82
10

ND
ND


1
0




49
<
f- * 4
f ff :
MMsat>^
Sitl0ซB
, ^^j
> - ' ^
^'
. -^
*, ' % :

1.1
15.1
15.1
129.8





0
0




15.9
"'"'"- "
teSSTO
Jj^lUfE^T-
i -^^>
v^ v v v
'

16.5
7.6
7.6
64.9





54.9
29.5




18.8
See notes, p.l 1-10

-------
                                                     TABLE 11-4
                                                     (continued)
                                                   CASE STUDY #1
                  MASS BALANCE FOR CERCLA WASTESTREAM CONTAMINANTS AT POTW 4

Trichloroethene
   4.15
  NC
Herbicides/Pesticides
Dieldrin
   0.04
  0.8
32 M
o5
95
0.07
0.5
Lindane
   0.08
  NC
Metals/Elements
Aluminum
   5.53
 104.7
90 M6
                     90
        94.2
           10.5
Antimony
   0.20
  3.8
 17 M
                     90
         3.4
           3.2
Arsenic
   0.04
  NC
Cyanide
   0.03
  NC
Cadmium
   2.82
  NC
Calcium
1080.00
20440.0
 4M6
                     90
      18396.0
        19622.4
Copper
   0.05
  NC
Iron
1230.00
23280.0
81 M
                     90
     20952.0
         4423.2
Magnesium
 306.00
 5791.0
 OM
                     90
      5211.9
         5791.0
                                  14.40
             272.5
              38 M
                                90
                            245.2
                   169
                                   2.27
              NC
Selenium
   0.02
  0.4
  OM
                     90
         0.4
           0.4
See notes, p. 11-10

-------
                                                          TABLE 11-4
                                                           (continued)
                                                        CASE STUDY #1
                    MASS BALANCE FOR CERCLA WASTESTREAM CONTAMINANTS AT POTW 4

                                   CON-

 Sodium
4020.00
76090.0
 OM
90
68481.0
76090.0
Thallium
   0.02
  0.4
90 M6
90
    0.4
    0.1
Zinc
   0.83
  NC
Lead
   1.55
  NC
Phosphorus
 169.00
 3202.0
 80 G
90
 2881.8
  640.4
 Potassium
 840.00
15890.0
  OG
90
14301
15890.0
NOTES:
'Calculated Contaminant Load (g/day) = [Calc. infl. cone. (mg/L)] [plant flow (L/day)] (1 g/^mg)
 Used data from 2,4-dichlorophenol based on similar physical and chemical properties.
 Used data from 101-500-parts per billion (ppb) concentration range.
TJsed data from vinyl chloride based on similar physical and chemical properties.
 Used data from lindane and other pesticides based on similar physical and chemical properties.
\Jsed data from >5,000-ppb concentration range.
 Used data from 1,001-5,000-ppb concentration range.
 Used data from 501-1,000-ppb concentration range.
9Used data from aluminum based on similar physical and chemical properties.

G = Source: Treatability data from another activated sludge POTW (Grand Rapids, Michigan)
M = Source: "CERCLA Site Discharges to POTWs Treatability Manual" (USEPA1990).
NC = Mass balance not calculated. Influent concentration regulated by local limit.
ND = No Data
 Due to the use of several sources and conservative addumptions, % to air plus % to sludge may not equal % removal.

-------
                                                           TABLE 11-5
                                                         CASE STUDY #1
                                TREATABILITY OF CERCL A WASTESTREAM AT POTW 4
Orgaiilcs
 1,1,2,2-Tetrachloroethane
   3.04
                                                     1.3
                                              Pretreat
 1,2-Dichloroethane
   1.45
3.38x10''
 60 M
LSSxlO"
                                        5xlO"3C
                                  Discharge
2,4-Dichlorophenol
  10.00
l.llxlO';
               96 M
4.44x10'-
                           0.7 S
                                  Discharge
2,6-Dichlorophenol
  10.00
l.llxHT
              96 M3
4.44x10'-
                           0.73S
                                  Discharge
Acetone (2-Propanone)
  68.58
7.62xlO'3
95 M4
3.81x10
                                         0.05 E
                                  Discharge
Benzene
   3.74
                                                     0.07
                                              Pretreat
Benzoic Acid
4050.00
  0.450
                                     no limit P
                                  Discharge
Benzyl Alcohol
  10.00
1.11x10
                                                              ,-3
                                     no limit P
                                  Discharge
Chlorobenzene
   3.10
                                                     1.4
                                              Pretreat
Chloroform
  12.60
                                                     0.07
                                              Pretreat
Chloromethane
  16.10
1.79x10
                                                              ,-3
 82 M
3.22x10
                                                            Pretreat
Ethylbenzene
   2.69
2.99x10^
 42 M
1.73x10
                                         0.68 R
                                  Pretreat
Methylene Chloride
   5.34
                                                     8.6
                                              Pretreat
Phenol
2090.00
                                                     14.4
                                              Pretreat
Tetrachloroethene
   3.47
                                                     0.1
                                              Pretreat
Toluene
  14.20
                                                     14.4
                                              Discharge
See notes, p. 11-14

-------
                                        TABLE 11-5
                                        (continued)
                                      CASE STUDY #1
                      TREATABILTTY OF CERCLA WASTESTREAM AT POTW 4
s^-fMj^
*f Of /^-^ IK •*> <. 4 " :
>* " - '^ "
'-r-'/V '* - "*
^^^iJQIJJWlAMr', * "
	 .v..,!.l?l,.?f *.ฃ,>:. *
Trans- 1 ,2-dicWoroethene
Trichloroethene
, '',' '"•••'', ' ' ',,
Berbiiades/Pe^dcid^s ; ;;, , ",
Dieldrin
Lindane
R4etals/El6Jrtetits :; - ..
Aluminum
Antimony
Arsenic
Cyanide
Cadmium
Calcium
Copper
Iron
Magnesium
Manganese
>*ฃ .
' & l ' ,
J*4*
~.$nrEj!**
ปLOฎ*rf
'^tsaweV
-Ne" '
Jttg^tf ^
1.91X10"4
—
', ' 1
','' ,, ''- *
4.67X10"6
-
* *f t
",-\<,\*
6.14X1Q-4
2.22xlO"5
~
—
—
0.1200
-
0.1367
0.034
1.600xlO'3
t
j
s
' *%^
mMtii%isฃ
/
^
42 M
—
-. ' f •" f
* ^ */ s*t
f f f
', t ' f
31.91 M6
--
„' - ''-- *
90 M7
17 M
--
.
—
4M7
—
81 M8
OM7
38 M9
1 *,ซ ^ , 4,
?• ";
„ j i
e&i,euซ i
uaws^'i i
^aesfiwr 'j
%cm&$i*f}
,. 	 .i.^./j.... j
l.llxlO"4
-
,'A\ '^
' '', ', 'i *•> ^
3.18X10"6
—
^' "" *!•
6.14xlO'5
1.84xlO'5
—
-
-
0.11
-
0.02
0.034
9.85X10"4
Wff&&$&\
siawar i
'  i
/..,.^.....-S"....Sป.ซ..J
0.07 R
-
',^ ', -, ";
* * ', 5/
j ^ \ •* ^ ^
7.1xlO'8 A
—
•ff
0.5 P
0.146 A
.. ^
--
~
no limit P
~
0.3 E
0.3 E
0.3 E
FOTW"
LOC^
>ซ&>
^ ^^ Xl
-
0.07
f, j .
' *'-'>".. *,< '•
	 f. 	 -: . . f.
-
0.06
' s
~
--
LOP
2.0 P
3.0 P
-
3.0 P
-
—
-
it'Srt,^ ซ t |-jl
O < ~
^ S A ^
^l/ >
E&W&E&T&&'
^sisoyj&g i
	 s.,.,A.^..j:..^....Lii
Pretreat
Pretreat
, , -x f ^
%>"*'* /<: A
Pretreat
Pretreat
v-.r-.?:; ••';
Discharge
Discharge
Discharge
Discharge
Discharge
Discharge
Discharge
Discharge
Discharge
Discharge
See notes, p. 11-14

-------
                                                       TABLE 11-5
                                                        (continued)
                                                     CASE STUDY #1
                              TREATABILITY OF CERCLA WASTESTREAM AT POTW 4
Nickel
   2.27
0.006
                                     6.0 P
                               Discharge
Selenium
   0.02
          2.22xW6
    OM
2.22x10"*
 0.045 R
                               Discharge
Sodium
4020.00
           0.4467
   OM4
 0.4467
no limit P
                               Discharge
Thallium
   0.02
         2.222x10''
90 M
                                                                   ,7,10
2.22x10'
                                                     ,-7
 0.013 A
                               Discharge
Zinc
   0.83
0.157
                                     5.0 P
                               Discharge
Lead
   1.55
0.010
                                     3.0 P
                               Discharge
Phosphorus
 169.00
           0.0188
   80 G
3.76xlO':
              1.0 P
                   Discharge
Potassium
 840.00
           0.0933
    OG
 0.0933
no limit P
                               Discharge
See notes, p. 11-14

-------
HYPOTHETICAL CASE STUDIES










| TABLE 11-5





O
1
I

r* Cd
(continued)
CASE STUDY #
TREATABILITY OF CERCLA WAST
r—
d
o
1
*S
c
^
&
d
c
ง

<—
NOTES:
Calculated Influent Cone. (mefL) = lYsite infl. cone. (me/LVI Fsite infl. flow volume(L/dav









1—1
[Total flow (L/day;
Site influent flow volume = 18,930 L/day
POTW flow volume = 170,330,000 L/day

















CO
o
•e
Total flow (with site discharge) = 170,348,930 L/day
POTW influent concentration was assumed to be zero if no data was available.
2Calculated Effluent Cone. frog/Li = [calc. infl. cone. Cmg/Lt] [1 - % Removal^
100
3Used data from 2,4-dichlorophenol based on similar physical and chemical properties.
'Hjsed data from 101-500 parts per billion (ppb) concentration range.
5Used data from vinyl chloride based on similar physical and chemical properties.
^Used data from lindane and other pesticides based on similar physical and chemical prope
Used data from >5,000-ppb concentration range.
8Used data from 1,001-5,000-ppb concentration range.
Used data from 501-1,000-ppb concentration range.
Alsed data from aluminum based on similar physical and chemical properties.










1 A = Source: Ambient Water Quality Criteria










| C = Source: Maximum Contaminant Limit










| E = Source: Decision by USEPA Regional Water Permits Section









a
G = Source: Treatability data from another activated sludge POTW (Grand Rapids, Michij
M = Source: "CERCLA Site Discharges to POTWs Treatability Manaual" (USEPA 1990)
P = Source: Decision by POTW Authority










R = Source: Recommended Maximum Contaminant Limit
S = Source: Drinking Water Suggested No Adverse Response Level, Chronic










-- = No Data
                                11-14

-------
                                                        HYPOTHETICAL CASE STUDIES
11.1.5. Identify and Screen Pretreatment
      Alternatives

11.1.5.1.   Identify Pretreatment
          Technologies

FS writers used information from this document
to identify and screen pretreatment technologies
(Table 11-6).

11.1.5.2.   Assemble Alternative Process
          Train Pretreatment

The FS team planned a pretreatment train for the
CERCLA wastestream.  The proposed
pretreatment included oil and grease separation,
followed by activated carbon adsorption.  The
scheme was designed to effectively pretreat the
wastestream while minimizing the number of
required processes.
                       11.1.6. Detailed Analysis of Discharge
                             Alternative

                       The FS team's evaluation determined that the
                       POTW discharge alternative is feasible for the
                       CERCLA wastestream; the final analysis will be
                       based primarily on the administrative and political
                       feasibility of the POTW to accept hazardous waste
                       by truck or dedicated pipe. Lagoon waste will be
                       collected, pretreated in a two-step process, and
                       transported to the POTW by either truck or
                       dedicated pipe. POTW, state, and USEPA
                       officials are confident that the wastestream will be
                       effectively treated at the POTW, based on past
                       experience and FS team calculations.

                       The POTW discharge alternative is expected to be
                       effective in the short- and long-term,
                       implementable, and cost-effective. It should
                       reduce toxicity of contaminants, protect human
                       health and the environment, and comply with
                                       TABLE 11-6

                                     CASE STUDY #1
               PRETREATMENT OPTIONS FOR CERCLA WASTESTREAM
 POLLUTANT
          s    <•.-.-.

 1,1,2,2-Tetrachloroe thane
 Benzene
 Chlorobenzene
 Chloroform
 Chloromethane
 Ethylbenzene
 Methylene Chloride
 Phenol
 Tetrachloroethene
 Trans-1,2-dichloroethene
 Trichloroethene
 Dieldrin
 Lindane
 Oil & Grease
         CLASS      APPLICABLE TECHNOLOGIES

             V       Steam stripping, activated carbon
             V       Steam stripping, activated carbon
             V       Steam stripping, activated carbon
             V       Steam stripping, activated carbon
             V       Steam stripping, activated carbon
             V       Steam stripping, activated carbon
             V       Steam stripping, activated carbon
           S V(A)     Steam stripping, activated carbon
             V       Steam stripping, activated carbon
             V       Steam stripping, activated carbon
             V       Steam stripping, activated carbon
           P(OH)     Activated carbon
           P(OH)     Activated carbon
                      Oil & Grease Separation
V = Volatile
SV(A) = Semi-Volatile(Acid)
P(OH) = Pesticide(Organohalides)
                                          11-15

-------
HYPOTHETICAL CASE STUDIES
ARARs. Because POTW, state, and USEPA
officials were involved in the planning of the
alternative, the community and state are expected
to accept the CERCLA wastestream discharge to
POTW alternative.
11.2. CASE STUDY #2

In Case Study #2, a POTW was identified that
already had local limits for several compounds
detected in the CERCLA wastestream during the
RI. The CERCLA site examined in Case Study #2
is a landfill that received municipal and industrial
wastes. The wastestream of concern is the landfill
leachate, which is contaminated by organics,
metals, pesticides, and conventional and
nonconventional pollutants.

To achieve remedial action objectives, treatment
of leachate discharged at a maximum rate of
80,000 gpd for five years is required. POTW
operators contacted during the screening process
were generally receptive to accepting the
CERCLA wastestream  because of their
experience with industrial discharges and
knowledge of specific process capabilities.
Regional USEPA and state regulatory personnel
approved the discharge of pretreated CERCLA
waste to a POTW.  Based on treatability
calculations generated during the screening of the
POTW alternative, pretreatment would probably
be required for several organics and metals
detected in the leachate.

11.2.1. Identify and Characterize CERCLA
      Wastewater Discharge

The CERCLA wastestream is a leachate that
drains into a collection system installed beneath
the landfill. Samples collected during the RI
identified leachate contaminant concentrations
(Table 11-7). The leachate contains many
compounds in excess of AWQC. The risk
assessment undertaken during the RI indicated
that leachate quality is a potential hazard to human
health and the environment, and cannot be
discharged without treatment.

Proposed remedial actions specify that leachate
will be generated at a rate of 80,000 gpd over a
five-year period. Wastestream quality is expected
to improve with time; however, to be most
protective of human health, the environment, and
the treatment plant  unit operations, the initial
POTW discharge evaluation is based on the worst
case (i.e., all compounds are present in the
wastestream at the maximum concentration
detected).

The CERCLA wastestream is classified under
RCRA regulations as hazardous waste; the
landfill contents, which include drums of spent
solvents and chemical waste, are classified under
RCRA as solid wastes because they have been
discarded and abandoned (40 CFR ง261.2).
Spent solvents and chemical waste in the landfill
are considered hazardous, and fall under F-, U1,
and P-listed wastes (RCRA  Subpart D). In
addition, a mixture of solid waste and hazardous
waste is defined as hazardous waste if it exhibits
hazardous characteristics  (40 CFR
ง261.3[a][2][iv]).  Therefore, the leachate is
defined as a hazardous waste, because it is a "solid
waste  generated from the ...disposal of a
hazardous waste."

The leachate could be excluded as  a hazardous
waste if and when the DSE were  applicable.
According to the DSE, "any mixture of domestic
sewage and other wastes that pass through a sewer
system to a POTW for treatment" is excluded as a
solid and, therefore, hazardous waste (40 CFR
ง261.4[a][l][ii]). For the DSE to apply, leachate
would need to be discharged into a sewer on-site;
trucking to an off-site manhole is unacceptable.
                                          11-16

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                                                       HYPOTHETICAL CASE STUDIES


                                      TABLE 11-7

                                    CASE STUDY #2

    CONCENTRATION OF POLLUTANTS DETECTED IN CERCLA WASTESTREAM
Organics
1,1,2,2-Tetrachloroethane                               1,300 |Hg/L
1,2,4-Trichlorobenzene                                4,660 [J.g/L
1,2-Dichlorobenzene                                    720 |J.g/L.
1,4-Dichlorobenzene                                    960 fig/L
2,4-Dichlorophenol                                     830 (ig/L
Acetone                                               500 |ig/L
Benzene                                             1,740 (ig/L
BenzoicAcid                                       96,300 |ig/L
Benzyl Alcohol                                         710 fO-g/L
Carbon Tetrachloride                                    140 |ig/L
Chlorobenzene                                       3,770 p.g/L
Chloroform                                         '   520 |ig/L
p-Cresol                                               160 [ig/L
Pentachlorobenzene                                     550 |ig/L
Phenol                                                200 (ig/L
Tetrachloroethene                                     1,300 |ig/L
Toluene                                            18,200 [ig/L
Trans- 1,2-dichloroethene                                 170 |ig/L
Trichloroethene                                         600 fJ.g/L

Herbicides/Pesticides
Heptachlor                                              35 [ig/L
Toxaphene                                              50 }ig/L

Metals
Calcium                                           225,000 |ig/L
Cobalt                                                 10 fig/L
Iron                                                 6,700 |J.g/L
Magnesium                                         55,300 (Ig/L
Manganese                                             850 (ig/L
Nickel                                                140 [ig/L
Selenium                                                2 [ig/L
Sodium 	   89,200
                                         11-17

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HYPOTHETICAL CASE STUDIES
                                     TABLE 11-7

                                      (continued)

                                   CASE STUDY #2
 POLLUTANT
 Metals (continued)
 Zinc
 Chromium
 Potassium

 Conventionals
 BOD
 O&G
 TSS

 Nonconventionals
 Ammonia, as N
 COD
 Fluoride
 Nitrogen, Total Kjeldahl
 Sulfide, Total Colorimetric
 TDS
 TOC
CONCENTRATION-
          70 u.g/L
      103,000 |ig/L
       10,000 |lg/L
          120mg/L
          20 mg/L
        1,300 mg/L
         1.6 mg/L
         260 mg/L
         0.70 mg/L
          2.0 mg/L
          2.0 mg/L
        7300 mg/L
          90 mg/L
11.2,2. Identify Potential Local POTWs

Because the CERCLA site is located in an urban
area with several large POTWs to handle city
wastewater, the FS writers chose a 5-mile radius
from the landfill within which to identify and
characterize POTWs.

The USEPA Regional Water Management
Division, Water Permits and Compliance Branch,
was contacted to assist in locating individual
POTWs and/or POTW authorities within a 5-mile
radius of the site.  Contact was made with
representatives from three POTWs (i.e., POTWs
  1, 2, and 3). Each POTW is administered by a
  separate authority.

  11.2.3. Involve POTW in Evaluation Process
        and Screen POTWs

  USEPA personnel emphasized the importance of
  involving all concerned parties (i.e., state officials
  and POTW managers) early in the evaluation
  process to discuss the potential for discharging to
  a POTW, and to arrive at a suitable treatment
  scheme. The three POTW managers were
  contacted and asked to provide information about
  available capacity, treatment unit processes,
  treatment capabilities, and local ordinances
                                        11-18

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                                                        HYPOTHETICAL CASE STUDIES
regulating their operations (i.e., pretreatment
program, sludge disposal practices,
influent/effluent monitoring, air emissions, and
local limits for industrial users). Information
obtained from initial discussions with POTW
managers was relayed to state officials to initiate
an open communication path between all parties.

11.2.3.1.  Determine Compliance Status

Because the state agency administered the
NPDES program for the local POTWs, the state
water permits division was asked to provide
copies of the NPDES permit for each POTW
under consideration, and the AWQC for POTW
receiving waters.  Air emissions permits were
requested from the state air permits section.  The
Regional Off-site Coordinator was contacted to
provide any applicable information. State
regional offices were asked to provide summary
data for each POTW influent, effluent, sludge, and
air emissions monitoring programs, where
applicable.

All POTW managers contacted indicated that
their facilities have a good history of compliance
with applicable regulations; there was no
information indicating significant potential for
groundwater contamination from impoundment
of the CERCLA wastewater. Using the POTW
compliance checklist (see Table 4-1), the
facilities' individual permits (i.e., NPDES,
sludge, and air) were examined. The regional
USEPA Water Permits and Compliance Section
was contacted to confirm that the POTWs were
operating up to standards. Each POTW has an
approved pretreatment program.

11.2.3.2.  Consider Technical Feasibility

A screening table was prepared to evaluate
technical feasibility of CERCLA wastestream
discharge to the three plants (Table 11-8).
Information from the POTWs indicated that all
three use primary settling in combination with
activated sludge treatment processes. In addition,
POTW 3 uses a tertiary sand-filter system.
POTWs 1 and 2 incinerate sludge and landfill the
ash; POTW 3 composts and landspreads sludge.

Of the three, POTW 2 has the largest capacity
(56.2 mgd), followed by POTW 1 (34 mgd) and
POTW 3 (11.4 mgd). POTWs 2 and 3 are
expected to have sufficient available capacity to
handle discharge from the CERCLA site for the
five-year duration; however, allowing for average
loading increases from surrounding communities,
POTW 1 is currently operating at capacity and is
experiencing overloading problems during
storms. Therefore, it would not be technically
feasible to discharge to POTW 1. POTW 3 has
available capacity to handle the CERCLA
discharge. However, the operator was concerned
about the effects of accepting the wastewater on
his ability to continue to compost and landspread
the sludge; therefore, the operator was hesitant to
agree to accept the wastewater.

11.2.3.3.  Consider Administrative
         Feasibility

The sewer system on-site is connected to POTW
2. Discharging to this sewer would be covered by
the Domestic Sewage Exclusion (DSE). Treating
the CERCLA wastestream at POTW 3 would
require trucking or piping to the facility, and the
facility would be required to obtain a RCRA
permit-by-rule.  Therefore, to discharge to POTW
3 would be more costly, and to obtain required
permits would be more difficult than for POTW 2.
In addition, public pressure to not accept the
CERCLA wastestream (because of concerns
about land application of the sludge) may rule out
POTW 3. Due  to administrative circumstances,
discharge to POTW 2 is the preferable alternative.
Once POTW 2 was identified as the most suitable
alternative, discharge negotiations between the
POTW authority, USEPA Remedial Project
Manager (RPM), state authorities,  and the FS
team were initiated to discuss specific details of
discharging CERCLA waste to the POTW. Table
11-9 shows the treatment process and methods
employed at POTW 2.
                                          11-19

-------
HYPOTHETICAL CASE STUDIES
                                     TABLE 11-8

                                   CASE STUDY #2

    EVALUATION OF TECHNICAL FEASIBILITY OF CERCLA WASTESTREAM DIS-
                           CHARGE TO IDENTIFIED POTWs
      CRITERIA
                     POTWS
 Does the POTW have
 hydraulic capacity to
 handle additional
 CERCLA wastestream
 flow?

 Are unit operations
 suitable for treatment of
 contaminants in the
 CERCLA wastestream?

 Is there a domestic
 sanitary sewer piping
 system running from the
 CERCLA site to the
 POTW?

 Distance from CERCLA
 site to POTW? (miles)
No
                                                  „ 2
Yes
Yes
Yes
Yes
Yes
No
Yes
No
5.2
1.6
3.5
 POTW's sludge disposal    _  .      „   ,„,
 process?                 Incinerate/Landfill
               Incinerate/Landfill     Compost/Landspread
The NPDES authority developed NPDES limits
for all the CERCLA site contaminants not
currently limited in the POTW's NPDES permit.
Additionally, the POTW officially developed
local limits for all compounds in the CERCLA
waste before the CERCLA site discharge was
implemented. In addition to creating limits,
developing NPDES and local limits helped reduce
the POTW's long-term liability.
               11.2.4. Obtain/Estimate POTW Local Limits

               11.2.4.1.  Obtain Local Limits


               The FS team requested a copy of POTW 2 local
               limits for industrial users and NPDES, air
               emissions, and sludge disposal permit limits. The
               operator indicated that local limits were contained
               in the municipality sewer use ordinance for metals
               and cyanide only. Because of the relatively small
               volume of the leachate (compared to the current
                                        11-20

-------
                                                       HYPOTHETICAL CASE STUDIES
                                      TABLE 11-9

                                    CASE STUDY #2

                              POTW 2 UNIT OPERATIONS
 Screening

 Grit Removal

 Primary Sedimentation

 Aeration

 Final Sedimentation

 Disinfection

 Sludge Thickening
Bar Rack

Grit Chamber

Settling Tank

Activated Sludge

Clarifier

Chlorine Gas

Gravity Thickening
influent to the POTW), the operator indicated that
influent limits would not initially be placed on
conventional and nonconventional pollutants.
Metals and cyanide local limits would be the same
as for other discharges to the plant.

11.2.4.2.  Estimate Local Limits

The FS writers evaluated the effect of CERCLA
site discharge on the POTW, and estimated local
limits that might be appropriate. The leachate
contained concentrations of several compounds
that created the potential for inhibition of
activated sludge treatment processes at POTW 2.
Among the compounds for which biological
inhibition threshold concentrations are available
(see Tables 10-1 and 10-2), only chlorobenzene
and chromium were present in the leachate at
possible inhibitory concentrations. However,
when diluted by plant flow, concentrations will be
well below inhibitory levels.
  At the time of the evaluation, biological inhibition
  data were not available to the FS writers for the
  following compounds present in the leachate:
  2-propanone, benzoic acid, benzyl alcohol,
  p-cresol, pentachlorobenzene,
  trans-1,2-dichloroethene (trans-1,2-DCE),
  heptachlor, toxaphene, cobalt, magnesium,
  selenium, sodium, and potassium. However, the
  FS writers inferred the behavior of the substances
  based on physical and chemical properties.
  Oxygenated species (e.g., 2-propanone, benzoic
  acid, benzyl alcohol, and p-cresol) at leachate
  concentrations are assumed sufficiently
  biodegradable to not impair the biological system.
  Chlorinated organics pentachlorobenzene and
  trans-1,2-DCE should behave similarly to
  compounds 1,2,4-trichlorobenzene and
  tetrachloroethene and, therefore, should not
  biologically inhibit at leachate concentrations.
  Highly soluble metals (i.e., magnesium, sodium,
  and potassium) are expected to behave similarly
  to calcium and,  therefore, should not inhibit
                                          11-21

-------
                                                            TABLE 11-10

                                                          CASE STUDY #2

                                 TREATABILITY OF CERCLA WASTESTREAM AT POTW 2


                                                                                                      > 4
                                                                                                     f
Organics
1,1,2,2-Tetrachloroethane
 1.300
<0.005
                                                              4 35x10
85
M
                                                        6.53X10"
                                                            1.7x10
   ''Pretreat
1 ,2,4-Trichlorobenzene
 4.660
                                                              6.63xlO"3
                                83
      M
                                                        I.l3xl0'
                                                            0.01
                                     Discharge
1 ,2-Dichlorobenzene
 0.719
 0.003
                                                              4.02xlO'
                                                                     '3
40
M
                                                        2.41xlO'
                                                            0.62
D
Discharge
1 ,4-Dichlorobenzene
 0.964
<0.011
                                                              6.86xlO'3
86
M
                                                        9.61X10"
                                                            0.75
D
Discharge
2,4-Dichlorophenol
 0.833
                                                              1.18xlO"
                                                                     "3
                                95
      M
                                                        5.92xlO'
                                                                                                   '5
                                                            SxlO"
                                     Discharge
Acetone (2-Propanone)
 0.500
                                                              7.11X10"
                                95
      M4
                                                        3.55xlO'
                                                            0.05
                                     Discharge
Benzene
 1.740
 0.001
                                                              3.47xlO'3
74
M
                                                        9.03X10"
                                                            6.6X10"
   *Pretreat
 Jenzoic Acid
96.300
                                                              1.37X10'
                                                                     '1
                                                        1.37X10"1
                                                            No Limit
                                                                           Discharge
 Jenzyl Alcohol
 0.709
                                                              LOlxlO'3
                                                        l.OlxlO"
                                                            No Limit
                                                                           Discharge
Carbon Tetrachloride
(Tetrachloromethane)
 0.141
                                                              2.00X10"
                                50
      M
                                                        LOOxlO"
                                                            4X10"
                                  D
   Discharge
 hlorobenzene
 3.770
<0.005
                                                              7.86xlO'
                                                                     '3
62
M
                                                        2.99xlO'
                                                            0.06
D
 Discharge
 hloroform
 0.518
 0.005
                                                              5.73xlO'
80
                                                        l.lSxlO'
                                                                                                   '3
                                                            1.9X10"
                                      Pretreat
 )-Cresol
 0.161
                                                              2.29X10"
                                95
      M
                                                        1.14xlO
                                                                                                   '5
                                                            0.05
                                     Discharge
Pentachlorobenzene
 0.548
                                                              7.79X10"
                                      M
                                                        7.79X1Q-
                                                            7.2xlO'7
                                           'retreat
 'henol
 0.199
 0.055
                                                              5.52xlQ-
85
                                                        8.28xlO
                                                                                                   '3
                                                            IxlO"
                                     Pretreat
retrachloroethylene
 1.300
 0.015
                                                              1.68xlO'
                                                                     2
80
                                                        3.36xlO'
                                                            SxlO"
                                     "Pretreat
   . notes, n. 11 -25

-------
                                                          TABLE 11-10
                                                            (continued)
                                                         CASE STUDY #2
                                TREATABILITY OF CERCLA WASTESTREAM AT POTW 2
Toluene
 18.200
0.015
                                                             4.08x10"
                                                                    •2
93
                                                        2.86x10"-
                                                          2.0
Trans-1,2-dichloroethy lene
  0.170
0.002
                                                             2.24xlO"3
49
M
                                                        1.14x10"-
                                                          0.07
D Discharge
Trichloroethylene
  0.601
0.017
             1.78x10"'
76
                                                                                           4.28xlO"3
                                                                       2.7x10'
                                                                            ,-3
                                    *Pretreat
Heptachlor
  0.035
                                              0.0004
                          4.49xlO"4
                               80
      M
                                           8.98x10'
                                                                                                 i-5
                           2.8x10"
                                    *Pretreat
Toxaphene
  0.050
                                                             7.11xlO"5
                               94
      M
                                                        4.26x10"
                                                          7.1x10"
                                    *Pretreat
Metals/Elements
Calcium
225
                                              74
                          74.2
                                           72.0
                           No Limit
                                                                         Discharge
 "obalt
  0.010
                                              0.011
                          1.10x10:
                                                                   ,-2
                                           l.OOxlO"2
                           0.01
                                                                         Discharge
Iron
  6.70
                                              1.32
                          1.33
                               26
                                           0.984
                           No Limit
                                          Discharge
Magnesium
 55.30
                                              20
                          20.1
                                           19.1
                           No Limit
                                                                         Discharge
Manganese
  0.850
                                              0.062
                          6.32x10"'
                                           6.13x10"'
                           0.3
                                                                         Discharge
Nickel
  0.144
                                                             2.05xlO"4
                               35
      M
                                                        1.33x10"*
                                                          1.5
                                    Discharge
Selenium
  0.002
                                              <0.003
                          LSOxlO"3
                                    M
                                           1.50xlO":
                           0.01
                                          Discharge
Sodium
 89.2
                                              131
                          131
                                           130
                           No Limit
                                                                         Discharge
Zinc
  0.070
                                                             9.95x10
                                                                   ,-5
                               69
      M
                                                        3.08x10
                                                              ,-5
                                                          2.6
                                     Discharge
See notes, p. 11-25

-------
                                                        TABLE 11-10
                                                         (continued)
                                                      CASE STUDY #2
                               TREATABDLHY OF CERCLA WASTESTREAM AT POTW 2
Chromium
 103.0
                                                          1.46X10'1
 80
                                                       2.93x10"
Potassium
  10.0
                                                          1.149x10"'
                                                       1.149x10"
BOD
 120
                                            103
                          103
84.0
             n
   18
P5 Discharge
TSS
1,300
                                            135
                          135
 87
             17.6
   30
               P Discharge
SfonconveDtioniate
Ammonia, As N
   1.6
                                            11.3
                          11.3
             11.3
   13.5
P5 Discharge
COD
 260
                                            328
                          328
 70
             98.4
Monitor Only
P  Discharge
Fluoride
   0.72
                                                          1.07xlO';
                                                       1.07xlO";
                           4.00
                                       D Discharge
Nitrogen, Total Kjeldahl
   2.1
                                            17.16
                          17.1
  15
             14.5
Monitor Only
   )ischarge
Sulfide, Total (lodometric)
   2.0
                                                          2.98xlO";
                                                       2.98xlO'3
                           0.05
                                       E Discharge
TDS
7300
                                            718
                          727
             727
                        Monitor Only
               P Discharge
TOC
  89
                                            65
                          65.0
 63
             24.1
Monitor Only
P Discharge
Total Phosphorus, As P
   0.38
                                            3.68
                          3.68
 80
             0.736
   1.0
               P Discharge

-------
                                                         TABLE 11-10

                                                          (continued)
                                                       CASE STUDY #2
                               TREATABBLITY OF CERCLA WASTESTREAM AT POTW 2


-- = No Data Available
A = Source: POTW Annual Report
D = Source: Maximum Contaminant Limit or Recommended Maximum Contaminant Limit
E = Source: Decision by USEPA Regional Water Permits Section
M = Source: "CERCLA Site Discharges to POTWs Treatability Manual" (USEPA 1990)
P = SPDES Permit Limit
S = Ambient Water Quality Standard
T = POTW #2 Treatability Studies
L = Local Limit on Site Influent; Not an Effluent Limit
B = No Treatability Data Available - Assuming Zero % Removal


'Calculated Influent Cone. (mg/L) =
                  (Site Effluent Cone.) (Avg. Daily Site Flow Volume) + (POTW Avg. Infl. Cone.) (Avg. Daily POTW Flow Volume)
                                            (Avg. Daily Site How Volume + Avg. Daily POTW Flow Volume)
CERCLA waste flow - 80,000 gpd
POTW #2 low seasonal average flow - 56.2 mgd
Combined influent - 56,280,000 gpd
POTW influent concentration was assumed to be zero if no data was available.

Calculated Effluent Cone. (mg/L) = (Calculated Influent Cone.) (1 - % Removal)
                                                         100
 Compound present at concentrations below the detection limit. Assumed concentration is half the reported detection limit.
4Data obtained from 101-500-ppb influent concentration range
5Low seasonal limit
* Pretreatment decisions based on Ambient Water Quality Standards.  NPDES permit limits need to be developed for each original compound that exceeds stand-
ards. Based on NPDES limits, pretreatment may not be required for each compound.

-------
HYPOTHETICAL CASE STUDIES
biological systems at leachate concentrations.
The pesticides heptachlor and toxaphene, as well
as the metals cobalt and selenium, are a concern;
however, leachate concentrations are low, and
with dilution by other wastewaters at the treatment
plant, inhibitory effect is expected to be
insignificant.

Table 11-10 summarizes treatability of the
CERCLA wastestream at POTW 2.  No local
limits were in place for organic pollutants;
however, reasonable conservative effluent
concentration limits were compiled from MCLs
for drinking water and input from the regional
USEPA Water Permits Section.  Fortunately,
POTW 2 compiled extensive treatability data
through a USEPA grant; therefore, the fate of
many CERCLA wastestream contaminants in
POTW 2 processes was estimated. Treatability
data also provided a comprehensive background
study of pollutants regularly present in POTW 2
influent.

To determine treatability of the CERCLA
wastestream at POTW 2, an influent
concentration was calculated for each component
(see Table 11-10). The calculated influent is the
product of the daily CERCLA wastestream flow
and concentration,  and POTW average low
seasonal flow and concentration, divided by the
total flow. Effluent concentration for each
contaminant was determined as the difference
between influent concentration and total
percentage removed.  Principal removal
mechanisms in a POTW are volatilization,
biodegradation, and partitioning to the biomass.
Removal percentages for various wastestream
components were compiled from POTW 2
treatability studies, the POTW 2 annual report,
and the treatability of compounds information
presented in previous sections of this manual.
Pretreatment was elected when wastestream
contaminant concentration exceeded the local
limit.

For compounds without specifically regulated
discharge concentrations,  the
pretreat-or-discharge decision is made by
calculating effects of the CERCLA discharge on
the quality of POTW influent and effluent.
Calculated POTW effluent is compared to
existing NPDES permit limits, AWQC, and
drinking water standards to decide whether
particular compounds in the  CERCLA
wastestream will be effectively treated at the
POTW or whether pretreatment will be required.

The treatability table, generated during the POTW
alternate screening process, was examined by
USEPA, state, and POTW  officials. After
negotiations, the groups tentatively agreed on the
list of compounds requiring pretreatment (see
Table 11-10).

11.2.5. Identify and Screen Pretreatment
      Alternatives

.11.2.5.1.  Identify Pretreatment
         Technologies

The FS writers identified and screened
pretreatment technologies, and examined
pretreatment options for compounds requiring
concentration reduction before discharge to
POTW 2. Table 11-11 lists compounds requiring
pretreatment, their chemical classes, and the
effective pretreatment  techniques.  Appropriate
unit processes for the compounds requiring
pretreatment are reduction/precipitation,
steam-stripping, and activated carbon treatments.

11.2.5.2.  Assemble Alternative Process
         Train Pretreatment

The FS team proposed a pretreatment train for the
CERCLA wastestream, including reduction,
precipitation, and activated carbon adsorption, to
effectively pretreat  the wastestream while
minimizing the number of processes required.

Using the checklist in Subsection 6.2, FS writers
determined that their pretreatment and discharge
plan would meet ARARs.  The treatability
calculations and pretreatment plan were presented
                                         11-26

-------
                                                       HYPOTHETICAL CASE STUDIES
                                     TABLE 11-11

                                    CASE STUDY #2

              PRETREATMENT OPTIONS FOR CERCLA WASTESTREAM
 1,1,2,2-Tetrachloroethane
 Benzene
 Chloroform
 Phenol
 Tetrachloroethylene
 Trichloroethylene
 Heptachlor
 Toxaphene
 Chromium
   V
   V
   V
 S V(A)
   V
   V
 P(OH)
 P(OH)
M+E(C)
Steam-stripping, activated carbon
Steam-stripping, activated carbon
Steam-stripping, activated carbon
Steam-stripping, activated carbon
Steam-stripping, activated carbon
Steam-stripping, activated carbon
Activated carbon
Activated carbon
Reduction, precipitation
to POTW 2 for comment and approval and were
accepted after verification through bench-tests.

11.2.6. Detailed Analysis of the POTW
      Discharge Alternative

The initial screening indicated that the POTW
discharge alternative will be feasible for the
CERCLA wastestream. Landfill leachate will be
collected, pretreated on-site in a two-step process,
and transported to the POTW through the on-site
domestic sewer, thereby invoking the DSE and
eliminating the need for RCRA permit-by-rule
procedures and other hazardous waste
transporting and recordkeeping requirements.
POTW, state, and USEPA officials are confident
that the wastestream will be effectively treated at
the POTW, based on past experience and the FS
team calculations.

The POTW discharge alternative is expected to be
effective in the short-  and long-term,
implementable, and cost-effective.  It should
reduce the toxicity of contaminants, protect
human health and the environment, and comply
with ARARs. Because POTW, state, and USEPA
         officials were involved in the planning, the
         community and state are expected to accept the
         alternative.
         11.3. CASE STUDY #3

         Case Study #3 focuses on the feasibility of treating
         contaminated groundwater at a CERCLA site that
         resulted from improper disposal practices at
         several dye-manufacturing companies. Remedial
         action objectives established in the site FS dictate
         that groundwater remediation must achieve
         applicable drinking water standards and
         acceptable risk levels.  Based on site conditions,
         groundwater extraction using a series of pumping
         wells appears technically feasible. The FS,
         therefore, evaluates both on- and off-site
         treatability alternatives for the extracted
         groundwater.  Included in the list of remedial
         alternatives  was the option to discharge
         contaminated  groundwater to a POTW. Case
         Study #3 includes procedures, assumptions to
         evaluate discharging groundwater to a POTW,
         and conclusions of the evaluation.  This case
         study emphasizes  the need to examine
         administrative feasibility of using a POTW to treat
                                         11-27

-------
HYPOTHETICAL CASE STUDIES
CERCLA wastes early in the POTW screening
process.

A range of contaminants was detected in
groundwater samples collected during the site RL
Metal concentrations ranged from 0.0012 mg/L
(mercury) to 850 mg/L (sodium), and organic
compound concentrations ranged from 125 mg/L
(chlorodibromomethane) to 14,000 mg/L
(nitrobenzene). Two groundwater pumping
scenarios were developed in the FS.  The first
scenario assumed a pumping rate of 1 mgd to be
implemented over a three-year period. The
second assumed a pumping rate of 0.1 mgd, over
a 10-year period. Both pumping schemes were
considered during the evaluation process.

Three POTWs located near the site (i.e., POTWs
1,2, and 3) were evaluated, based on compliance
status of the POTW, hydraulic capacity, ability of
the POTW to treat waste, options available to
transport waste to the POTW, distance from the
site, POTW limits, ability of the POTW to treat the
wastestream for the required duration, and
administrative feasibility.

It was concluded, based on  administrative
obstacles, that discharge of CERCLA site waste to
the three POTWs was not a feasible alternative.
POTW 1 was eliminated because its by-laws
specifically prohibit discharge of treated or
untreated groundwaters to the sewer system. Its
by-laws also prohibit discharge of hazardous
waste generated from treatment of hazardous or
toxic waste. In addition, POTW 1 is currently
operating over capacity and is not in compliance
with its NPDES permit.  POTWs 2 and 3 were
eliminated for two reasons: (1) the CERCLA site
was located outside the POTW  districts, and the
sewer commissioner indicated that discharge
originating from outside the sewerage district is
prohibited; and (2) the waste would need to be
sent to these POTWs via truck or dedicated pipe;
therefore, the DSE would not apply.  Neither
POTW was willing to obtain RCRA
permit-by-rule status.
11.3.1. Identify CERCLA Wastewater
      Discharge

The CERCLA wastewater stream to be potentially
discharged and treated by a POTW consists of
contaminated groundwater.  Several
dye-manufacturing companies contributed to the
contamination through improper disposal
practices.  Tables  11-12 and 11-13  list
contaminants and the  concentrations at which
they were detected. Several metals and organic
compounds were detected in a wide range of
concentrations.

11.3.2. Characterize CERCLA Wastewater
      Discharge

MCLs, the maximum permissible level  of a
contaminant in water delivered to any user of a
public water system, are not available for most
compounds detected in the groundwater.
However, chromium and lead levels exceed the
MCL, andtrichlorethylene concentrations exceed
the MCL by a factor of almost 1,000.
Concentrations of other organic constituents
exceed 1 mg/L; COD of the water is 290 mg/L.

The need to pump and treat groundwater  was
established through the risk assessment process
during the RL Two groundwater pumping
scenarios were developed in the FS. The  first
scenario, designed to rapidly remediate the
aquifer, assumed a pumping rate of 1 mgd (i.e.,
approximately 700 gpm) to be implemented over
a three-year period through a series of extraction
wells. The second scenario assumed a pumping
rate of 0.1 mgd (i.e., approximately 70 gpm) over
a 10-year period.  Flow rates represent average
daily flows generated from aquifer pumping, and
are estimated to 15 percent. Decision-makers
must consider both pumping schemes before
selecting an extraction system in the ROD;
therefore, the FS must evaluate technical and
institutional issues associated with both flow
rates.
                                         11-28

-------
                                             HYPOTHETICAL CASE STUDIES
                              TABLE 11-12




                             CASE STUDY #3



 METALS AND CONVENTIONAL POLLUTANT CONCENTRATIONS IN GROUND WATER
s^- - V : ' ' - ^-' "V',VU'r\' '•xxt*'-''
v.tt "^ " ""' 'v. ""'"''' " - f'ฎ"
, "•ซ"•.••'•••• ***.•• \" v •• %
ซ.... ••ซ..•. •.•,*•...'• " s - "X "••.•*ป •• •. ••••v %%
%™ •. .. % •. V s % •- ^%%w , s \ •. •.ซ ^ "
w. *•.'•" *" s
jjrf^ip ^i -f ฅTf* ji. IWfT^ ''".•.'• ^ ^'"''
%%% A ,.-..'•• %-Tv. "^"ซซ , v% ,-. : •
•,<.'' ^ "" s '•'•'• ff^ ^I^^^^
Metals
Aluminum
Arsenic
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Zinc
Conventionals
Ammonia
Organic Carbon
COD
Total Phosphorus
Suspended Solids
"'v"rr' xj 	 w-™ ^ '"-v-- ' ' ' •"w^"'^x • •; ' ;•,„ 	 r
F;^:r?iSTO5T|D\\^^^ r-MAilMW^ '
ป l'" ,V :BlSงitAEiGfB ^ " ^ ; C^AMENANT,
ts^ -.'•'•'• "* -.\----x--- ""^xjE^^^ikJ^^SM^J^f*^ ji *if*'i'^TfcAjs ^" •• "* ^r'f'i^oi/i^f ff f •.
\ "" •, ,\^ v* *Tซrf*3Kw^? A Jw9k * * W* ป -. -jH/Jcr T J&*r4-
-" " (mg/L) ""'"'"•i""- x" """ " - " " s (roe/L) "
. .;.. ff '...,,,,„. -— - s ^ s / "" \^ "" ^ " -• sv ""•- •• •- "
•• ^ % *•

24
0.02 0.05
0.18
210
0.06 0.05
0.18
0.3 1.3
89
0.08 0.05
48
16
0.001 0.002
0.21
26
850
0.78

6.0
73
290
0.18
1610
NOTE:




mg/L = milligrams per liter
                                  11-29

-------
 HYPOTHETICAL CASE STUDIES
                                     TABLE 11-13

                                    CASE STUDY #3

                   ORGANIC CONCENTRATIONS IN GROUNDWATER
                                                                     CONTAMINANT
 POLLUTANT
 Chlorobenzene
 Chlorodibromomethane
 Chloroethane
 Trichloroethylene
 1,2-Dichlorobenzene
 Nitrobenzene
 Aniline
 3,400
 125
 250
 4,900
 2,100
 14,000
 1,900
NOTE:

mg/L = milligrams per liter
Determine whether CERCLA Wastestream is
a RCRA-listed Hazardous Waste. RCRA
regulatory status of contaminated groundwater at
the site was evaluated in conjunction with the lead
agency.  It was clearly established that discarded
material from former dye-manufacturing
operations was the source of contaminants in
groundwater at the site. The FS team made a
case-specific assessment to determine
applicability of RCRA Subtitle C regulations.

The RI from the site indicated contaminants in
groundwater leached from sludge disposed of on
the property and from several soil areas where
aqueous residues were dumped from barrels.
According to interviews with former employees,
discarded waste included distillation bottoms
from aniline production, process residuals from
aniline extraction, and combined wastewater
streams generated from nitrobenzene/aniline
production. These wastes are listed hazardous
under 40 CFR ง261.32 (i.e, K083, K103, and
K104).  Interviews also revealed that aniline
residuals, listed a U102, and spent solvents (i.e.,
F001) were dumped on the property. Because the
groundwater contained these wastes and their
constituents, the groundwater must be managed as
a hazardous waste until it no longer contains the
waste, in accordance with the "contained-in"
policy.

11.3.3. Identify Potential Local POTWs

The FS team contacted the Water Management
Division, Municipal Facilities Branch, and
Municipal Permits Section at USEPA regional
offices to obtain locations, contact names, and
telephone numbers for POTWs near the site.  The
state water pollution control agency was
contacted to provide NPDES permits for POTWs
near the site and state ambient water quality
standards.
                                         11-30

-------
                                                       HYPOTHETICAL CASE STUDIES
A major consideration for identifying POTWs
that may accept the CERCLA discharge is
determining whether the CERCLA waste would
be regulated as a RCRA hazardous waste and, if
so, whether the DSE applies to the discharge of the
waste to the POTW.

Under 40 CFR ง261.4, domestic sewage, and any
mixture of domestic sewage and other wastes that
flow through a sewer system to a POTW, is
excluded as solid waste, and therefore would not
be considered hazardous waste under RCRA
Subtitle C. Even if domestic sewage mixes with a
known RCRA hazardous waste and flows through
a sewer system to a POTW, the mixture is
excluded from RCRA control.

The DSE extends to most wastes that reach
POTWs; however, it does not exempt waste
received within POTW property boundaries by
truck, rail, or dedicated pipeline. The DSE is only
applicable to any solid wastes that mix with
sanitary wastes in a sewer system leading to a
POTW. USEPA ruled that waste falls within the
DSE when it first enters a sewer system in which
mixing with sanitary wastes will occur before
receipt  by a POTW (Federal Register. 1980).

In this  instance, a sewer main passes along the
road to the site; abandoned buildings on the site
property were connected to the sewer line to
discharge sanitary waste water and some process
wastewaters.  The sewer line transports
wastewater to a large metropolitan wastewater
treatment facility (i.e., POTW 1) 20 miles east of
the  site. Discharge of the groundwater into this
sewer would be covered by the DSE.

State officials identified two other POTWs within
a 15-mile radius of the site (i.e., POTWs 2 and 3).
Because no existing sewer line connects these
plants to the site, pumped groundwater would
need to be sent to these POTWs via truck or
dedicated pipe. Therefore, DSE would not apply
and the waste would have to be disposed of as a
RCRA waste.  These two POTWs are not
currently RCRA Permit-by-Rule facilities. The
following descriptions summarize POTWs 1,2,
and 3.

   • POTW 1 is 20 miles east of the site;
     a domestic sanitary sewer line runs
     from the site to the treatment
     facility.  Discharge of the
     groundwater into the sewer line
     would be covered by the DSE.

   • POTW 2 is 15 miles from the site.
     No existing sewer line connects the
     site to the facility. If the
     groundwater is transported by
     truck, rail, or dedicated pipe, the
     POTW must become a RCRA
     permit-by-rule facility.

   • POTW 3 is 15 miles from the site.
     No existing sewer line connects the
     site  to  the facility. If the
     groundwater is transported by
     truck, rail, or dedicated pipe, the
     POTW must become a RCRA
     permit-by-rule facility.

11.3.4. Involve POTW in the Evaluation
      Process and Screen POTWs

11.3.4.1.  Determine Compliance Status

The first step in initially screening the three
POTWs is to determine compliance status of each
treatment plant. A compliance evaluation was
done for each POTW by using the compliance
checklist in Table 4-1, and consulting with an
official from each POTW. Results of the
evaluation indicated that POTW 1 exceeded its
hydraulic capacity and periodically exceeds its
NPDES permit limits for suspended solids, fecal
coliform, and BOD. POTW 2 is currently in
compliance with its NPDES permit, pretreatment
program requirements, and all other applicable
RCRA requirements or other laws. Although
POTW 3 was generally in compliance, the facility
is composting its sludge on-site and has received
negative publicity due to significant odor
                                          11-31

-------
HYPOTHETICAL CASE STUDIES
                                    TABLE 11-14

                                   CASE STUDY #3

                          SCREENING POTENTIAL POTWs

               CERCLA WASTESTREAM DISCHARGE AND TREATMENT

                      EVALUATING TECHNICAL FEASIBILITY
CRITERIA

Does the POTW have hydraulic capacity to handle
additional CERCLA flow?
Are unit operations suitable for treatment of contaminants
in the CERCLA wastestream?
Is there a domestic sanitary sewer piping system running
from the site to the POTW and will the DSE apply?
Is the POTW a RCRA Permit-by-Rule facility?
Distance from the site to POTW? (miles)
POTW sludge disposal process?
Could the POTW treat the CERCLA wastestream for the
time duration required?

f^;^;
No
Yes
Yes
No
20.0
Composting
No
POTWS
•H' ; -'-^
Yes
Yes
No
No
15.0
Landfill
No

5<>4 ** "'/}<,
Yes
Yes
No
No
15.0
Composting
No
problems. There was no information at any of the
candidate facilities indicating a significant
potential for groundwater contamination from
impoundment of the CERCLA wastewater.

11.3.4.2.  Consider Technical Feasibility

The second step of the initial screening is
determining whether each POTW can technically
accept the waste. Table 11-14 summarizes
technical information obtained from each POTW.
Officials at the water resource authority for
POTW 1 indicated that the treatment facility flow
is over capacity and therefore could not accept the
waste.

POTWs 2 and 3 serve the northern and southern
portions (respectively) of a small city, and both
receive domestic and industrial wastewater. No
existing sewer line connects these plants to the
site; the FS team considered installing a dedicated
pipe from the site to the POTW sewer systems.
Both POTWs are operating near capacity, but
were not excluded as potential receivers of the
waste.
                                        11-32

-------
                                                        HYPOTHETICAL CASE STUDIES
The FS team determined it would not be feasible
to truck or pipe wastewater to POTWs located
outside the 15-mile radius of the site, based on the
anticipated flow rates of wastewater from the site
and the projected costs for trucking or building a
dedicated pipe from the site to the sewer
connection. Therefore, additional local POTWs
were not contacted.

11.3.4.3.  Consider Administrative
          Feasibility

The third step of the initial screening is to consider
administrative feasibility of discharging the waste
to the POTWs. When the sewer commission
responsible for overseeing operations at POTWs 2
and 3 was contacted, the commissioner indicated
that the two POTWs are not willing to comply
with the additional requirements to become
RCRA permit-by-rule facilities. In addition, both
POTWs prohibit discharges originating from
outside the sewerage district. Both plants
currently operate close to capacity; therefore, the
sewer commission would not consider
exemptions to this by-law. Discharge to POTWs
2 and 3 was deemed administratively infeasible.
The FS team considered discharge to other
POTWs beyond the initial 15-mile radius. On the
basis of a preliminary screening, this option was
considered significantly less cost-effective than
on-site groundwater treatment by more
conventional systems (e.g., air-stripping or
granular activated carbon).

11.3.5. Conclusion

Because administrative obstacles were
encountered at each POTW, use of a POTW to
treat the contaminated groundwater at the site is
not a viable alternative; further discussions with
local POTWs  were discontinued. POTW 1 was
eliminated because it had difficulties meeting
compliance standards and is currently operating
over capacity. POTWs 2 and 3 were eliminated
because neither POTW was willing to become a
RCRA permit-by-rule facility and each prohibits
discharges originating from outside the sewer
district. In addition, POTWs 2 and 3 are operating
near capacity; therefore, the sewer commission
would not consider exemption to this by-law.
                                          11-33

-------

-------
GLOSSARY OF ACRONYMS AND ABBREVIATIONS
ARARs
AWQC

BAT
BCT
BOD
BPJ
BPT

CAS
CERCLA
CLP
COD
CWA
Applicable or Relevant and Appropriate Requirements
Ambient Water Quality Criteria

Best Available Technology Economically Achievable
Best Conventional Pollutant Control Technology
biological oxygen demand
Best Professional Judgment
Best Practicable Control Technology Currently Available

Chemical Abstract System
Comprehensive Environmental Response, Compensation, and Liability Act
Contract Laboratory Program
chemical oxygen demand
Clean Water Act
DCE
DSE
DSS

ELGs
EP

FS
FWPCA
dichloroethene
Domestic Sewage Exclusion
Domestic Sewage Study

effluent limits guidelines
Extraction Procedure (toxicity)

Feasibility Study
Federal Water Pollution Control Act
GC
gpm

ITD

kg/day
KOW

MCL
mgd
gas chromatography
gallons per day
gallons per minute

Industrial Technology Division

kilogram per day
Octanol/water partition coefficient

Maximum Contaminant Level
million gallons per day
                                      Glossary -1

-------
 GLOSSARY OF ACRONYMS AND ABBREVIATIONS
mg/L
MLVSS

NAAQS
NCP
NPDES
NPL

O&M
OSWER

PCB
PHE
POTW
PRP

RAR
RCRA
RI
ROD
RPM

SARA
SVOC

TCL
TCLP
TIE
TRE
TSD
TSS

USEPA

VOC
milligrams per liter
mixed liquor volatile suspended solids

National Ambient Air Quality Standards
National Contingency Plan
National Pollutant Discharge Elimination System
National Priority List

operation and maintenance
Office of Solid Waste and Emergency Response

polychlorinated biphenyl
Public Health Evaluation
Publicly Owned Treatment Works
parts per billion
potentially responsible party

relevant and appropriate requirement
Resource Conservation and Recovery Act
Remedial Investigation
Record of Decision
Remedial Project Manager

Superfund Amendments and Reauthorization Act
semivolatile organic compound

Target Compound List
Toxic Characteristic Leaching Procedure
toxicity identification evaluation
toxicity reduction evaluation
treatment, storage, and disposal
total suspended solids

U.S. Environmental Protection Agency

volatile organic compound
                                      Glossary - 2

-------
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Federal Register. Vol. 45, No. 98; p. 33097; May 19,1980.

Federal Register. Vol. 51, No. 216; pp. 40573-40654; November 7,1986.

Federal Register. Vol. 53, No. 138; p. 27268-27281; July 19,1988.

Lyman, W.J., et al., 1982. "Solubility in Water"; in Handbook of Chemical Property Estimation Methods:
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Menzer, R.E., and J.O. Nelson,  1980.  "Water and Soil Pollutants" in Toxicology, edited by J. Doull,
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Russell, L.L., C.B. Cain, and D.I. Jenkins, 1983. "Impact of Priority Pollutants on Publicly Owned
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Tabak, H.H., S.A. Quave, C.I. Mashni, and E.F. Earth, 1981.  "Biodegradability Studies with Organic
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USEPA, 1979.  "Biodegradation and  Treatability of Special Pollutants"; E.F. Earth and R.L. Burch;
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USEPA, 1980.  "Innovative and Alternative Technology Assessment Manual"; USEPA 430/9-78-009;
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USEPA, 198la. "Literature Study of the Biodegradability of Chemicals in Water"; J. Gearing (Editor);
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USEPA, 198Ib. "304(g)  Guidance Document: Revised Pretreatment Guidelines"; USEPA; Cincinnati,
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USEPA, 1985.  "RCRA Information on Hazardous Wastes for Publicly Owned Treatment Works"; Office
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USEPA Memorandum, 1986a.  "Discharge of Wastewater .from CERCLA Sites into POTWs"; H.L.
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                                       References-1

-------
REFERENCES
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USEPA, 1986c. "Mobile Treatment for Superfund Wastes"; Office of Emergency and Remedial Response;
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USEPA, 1987a.  "Technology Briefs - Data Requirements for Selecting Remedial Action Technology";
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USEPA, 1987b.  "The 1987 Industrial Technology Division List of Analytes"; USEPA, Office of Water
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USEPA, 1987c. "Training Manual for NPDES Permit Writers"; Office of Water Enforcement and Permits;
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USEPA, 1987d.  "Nitrate Removal from Contaminated Water Supplies: Vol. H"; Water Engineering
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USEPA Memorandum, 1987e.  "USEPA Interim Guidance on Indemnification of Superfund Response
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USEPA Memorandum, 1987f.  "Revised Procedures for Planning and Implementing Off-site Response
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USEPA, 1987g. "Guidance for Implementing RCRA Permit-by-Rule Requirements at POTWs"; OSWER
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USEPA, 1987h. "Guidance Manual for Preventing Interference at POTWs"; Office of Water Enforcement
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USEPA, 1987L  "Guidance Manual on the Development and Implementation of Local Discharge Limits
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USEPA, 1987J. "Guidance Manual for the Identification of Hazardous Wastes Delivered to POTWs by
      Truck, Rail, or Dedicated Pipe"; USEPA Contract No. 68-01-7043; June 1987.

USEPA, 1988a.  "Draft CERCLA Compliance with Other Laws Manual"; Office of Emergency and
      Remedial Response; OSWER Directive No. 9234.1-01 and 02; May 1988.

USEPA, 1988b. "Feasibility and Risks Associated with Discharge of Superfund Wastes to POTWs"; Draft;
      Office of Policy, Planning, and Evaluation; August 1988.
                                      References-2

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                                                                           REFERENCES
USEPA,  1988c.  "Guidance for Conducting Remedial Investigations  and Feasibility  Studies Under
      CERCLA"; OSWER Directive 9355.3-01; Interim Final; October 1988.

USEPA,  1988d.  "Guidance for Writing Case-by-Case Permit Requirements for Municipal  Sewage
      Sludge"; Draft; Office of Water Enforcement and Permits; September 1988.

USEPA, 1989a. "Toxicity Reduction Evaluation Protocol for Municipal Wastewater Treatment Plants";
      Office of Research and Development; Risk Reduction Engineering Laboratory; USEPA/600/2-
      88/062; April 1989.

USEPA, 1989b. "Overview of Selected EPA Regulations and Guidance Affecting POTW Management";
      Office of Water, Office of Municipal Pollution Control; September 1989.

USEPA, 1989c. "Risk Assessment Guidance for Superfund, Volume I and II"; Office of Emergency and
      Remedial Response; USEPA/540/1-89/001 and 002; 1989.

USEPA, 1990. "CERCLA Site Discharges to POTWs Treatability Manual"; Office of Water Regulations
      and Standards; USEPA/542/90/007; 1990.

Walsh, J.J.,  J.M. Lippitt, and M. Scott, 1983.  "Cost of Remedial Actions at Hazardous Waste Sites -
      Impacts of Worker Health and Safety Considerations"; in Proceedings of the 4th National Con-
      ference T Management of Uncontrolled Hazardous Waste Sites; Hazardous Waste Control Research
      Institute.

Wetzel, E.D., and S.B. Murphy, 1986.  "Interference at Publicly Owned Treatment Works (POTWs)";
      Office of Research and Development; Water Engineering Research Laboratory; Cincinnati, Ohio.

Zorc, J.M., J.C. Hall, and C.L. Rissetto, 1988.  "Minimizing Liabilities Facing POTWs"; Journal WPCF:
      Vol. 60, No. 1; pp. 29-35; January 1988.
                                       References-3

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     APPENDIX A




USEPA OFF-SITE POLICY
      A-l

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             United Scales
             Environmental Proiection
             Agency
                Office ol
                Solid Wast* and
                EmซrgซncY Response
 oEPA
DIRECTIVE NUMBER:
                                 9814.11
              TITLE: Revised Procedures for Implementing Off-Site
                    Response Actions


              APPROVAL DATE."  November 13, 1987

              EFFECTIVE DATE:  November 13, 1987

              ORIGINATING OFFICE: Office of Waste Programs
                                 Enforcement
              Q FINAL (Interim)

              C DRAFT

                LEVEL OF DRAFT

                  Q A — Signed by AA or DAA
                  D B — Signed by Office Director
                  DC — Review & Comment

              REFERENCE (other documents):
>WER         OSWER        OSWER
 DIRECTIVE     DIRECTIVE
                                  A-3

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                                 vs cnvronmentw Protection Agvncy
                                  Washington. OC 20460
                OSWER Directive Initiation Request
                                    1. Directive Number
                                          9834.11
                                 2. Originator Information
    Nun* of ConUct Person
      NKNCY BROWS
     Mail Cod*
Office
 PM
Telephone Code
    3. Title
      Revised Procedures for Implementing Off-Site Response Actions
    4, Summary of Directive {include bnel statement of purpose)
      This Directive describes procedures that should be observed when a response action
      under CERCCA or Section  7003 of RCRA involves the off-site treatment, storage or
      disposal of CERCLA waste.
    5. Keywords
     Off-Site Policy, Off-Site Waste, CERCLA Waste, Off-Site Manaoenient of Waste
    6a. Does This Directive Superset* Previous Directive^)?
    b. Does It Supplement Previous Directive
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                                                          98.34.11
       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                   WASHINGTON. D.C. 20460
                       November 13, 1987
                                                    OFFICE OF
                                           SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM

SUBJECT: /Tlevised Procedures for Planning and Implementing
         \dff~?ite Response Actions
FROM:
         .Assistant Administrator

TO:       Regional Administrators
          Regions I-X

     With this memo I am transmitting the revised  procedures
for planning and implementing off-site response  actions  (the
"off-site policy").  These procedures should be  observe'd when
a response action under the Comprehensive Environmental  Response/
Compensation and Liability Act (CERCLA) or -Section 7003  of  the
Resource Conservation and Recovery Act (RCRA)  involves off-site
treatment/ storage or disposal of CERCLA waste.

     This policy incorporates all of the mandates  of  CERCLA as
amended by the Superfund Amendments and Reauthorization  Act
(SARA) and expands several of the more stringent requirements
when applying them to wastes resulting from  CERCLA decision
documents signed, and RCRA section 7003 actions  initiated/
after the enactment of SARA.  This revised policy  also
reinterprets the original off-site policy/ issued  in  May 1985/
as it applies to CERCLA wastes resulting from  decision
documents signed/ and RCRA section 7003 actions  initiated/
before the enactment of SARA.

     This revised policy is effective  immediately upon  issuance.
It is considered to be an interim final policy as key elements
of the policy will be incorporated in  a proposed rule to be
published in the Federal Register.  As part  of that rulemaking,
the policy will be subject to public comment.   Comments  received
during that period may cause additional revisions to the policy.
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                              -2-

     If you have comments regarding this revised  policy,
please contact Gene Lucero, Director, Office of Waste Programs
Enforcement.

cc:  Waste Management Division Directors
     Regions I-X
                                     (\-6

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                                                         9834.1
 REVISED PROCEDURES FOR IMPLEMENTING  OFF-SITE  RESPONSE ACTIONS
I.   INTRODUCTION

     The off-site policy describes  procedures that should be
observed when a response action under the Comprehensive
Environmental Response, Compensation and Liability Act  (CERCLA)
or Section 7003 of RCRA involves off-site storage, treatment  or
disposal of CERCLA waste.  The procedures also apply to  actions
taken jointly under CERCLA and another statute.

     The purpose of the off-site policy is to avoid having
CERCLA wastes contribute to present or future environmental
problems by directing these wastes  to facilities determined to
be environmentally sound.  It is EPA's responsibility to ensure
that the criteria for governing off-site transfer of CERCLA
waste result in decisions that are  environmentally sensible and
that reflect sound public policy.  Therefore, in developing
acceptability criteria, the Agency  has applied environmental
standards and other sound management practices to ensure that
CERCLA waste will be appropriately managed.

     EPA issued the original off-site policy in May 1985.  See
"Procedures for Planning and Implementing Off-Site Response
Actions", memorandum from Jack W. McGrav to the Regional
Administrators.  That policy was published in the Federal
Register on November 5, 1985.  The 1986 amendments to CERCLA,
the Superfund Amendments and Reauthorization Act  (SARA),
adopted EPA's policy for off-site transfer of  CERCLA wastes,
with some modifications.  CERCLA ง121(d)(3) requires that
hazardous substances, pollutants or contaminants  transferred
off-site for treatment, storage or disposal during a CERCLA
response action be transferred to a facility operating  in
compliance with งง3004  and 3.005 of RCRA  and other applicable
laws or regulations.  The statute also requires that receiving
units at land disposal  facilities have no releases  of hazardous
wastes or hazardous constituents.  Any releases from other
units at a land disposal facility must also be controlled  by  a
RCRA or equivalent corrective  action program.   While the
original policy required compliance with RCRA  and other
applicable laws, SARA goes beyond the original policy,
primarily by prohibiting disposal at units at  a land disposal
facility with releases,  rather than  allowing the  Agency to
judge whether the releases constituted  environmental conditions
that affected the satisfactory operation of  a  facility.

     The off-site policy has  been  revised in light of  the
mandates of SARA.  This revised policy  also  extends the SARA
concepts to certain situations not  specifically covered by the
statute.  These requirements  apply  to  CERCLA decision  documents
signed, and RCRA ง7003  actions taken,  after  enactment  of SARA.
Specifically, this policy  covers:

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                                                         9834.1 1
                              -2-
     o   Extending SARA's "no release" requirement to all RCRA
         units  receiving CERCLA waste, not just units at RCRA
         land disposal facilities;

     o   Expanding SARA's release prohibition to include
         releases of CERCLI. hazardous substances, in addition
         to releases of RCRA hazardous waste and hazardous
         constituents;

     o   Addressing releases from other units at RCRA treatment
         and storage facilities; and

     o   Addressing off-site transfer to non-RCRA facilities.

The revised policy also reinterprets the May 1985 policy as it
now applies to  CERCLA decision  documents signed, and RCRA ง7003
actions  taken,  prior to the enactment of SARA.

     The revised off-site policy is effective immediately upon
issuance.  It is considered to  be an,  interim policy as key
elements of the policy will be  incorporated in  a proposed rule
to be published in the Federal  Register.  As part of that
rulemaking, the policy will be  subject to public comment.
Comments received during that period may cause  additional
revisions  to the policy.  The final rule will reflect the final
policy under CERCLA  ง121(d)(3)  and EPA will issue a revised
implementation  policy memorandum if necessary.


II.  APPLICABILITY

     There are  a number of variables  which will determine
whether  and how the  off-site policy, applies:  waste  type,
authority, funding source, and  whether the decision  document or
order supporting the clean-up was  signed  before or after the
enactment  of SARA  (i.e., before or after  October 17,  1986).  In
order to determine which elements  of  the  policy apply to a
specific CERCLA cleanup each  factor must  be  considered.

     The first  factor to consider  is  the  type  of waste to  be
transferred.  The revised policy applies  to  the off-site
treatment, storage or disposal  of  all CERCLA waste.   CERCLA
wastes include  RCRA  hazardous wastes  and  other CERCLA hazardous
substances, pollutants and  contaminants.   RCRA hazardous wastes
are either listed or defined  by characteristic in 40 CFR Part
261.  CERCLA hazardous substances  are defined  in 40 CFR 300.6.

     Because RCRA permits and interim status apply to specific
wastes and specific  storage,  treatment or disposal processes,
the Remedial Project Manager  (RPM)  or On-Scene Coordinator
(OSC) must determine that the facility's permit or interim
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                                                          9834.1 l
                              -3-
status authorizes receipt of the wastes that would be
transported to the facility and the type of process
contemplated for the wastes.  Therefore, it is important that
facility selection be coordinated with RCRA personnel.

     A CERCLA hazardous substance that is not a RCRA hazardous
waste or hazardous constituent (i.e.,  non-RCRA waste) may be
taken to a RuRA facility if it is not otherwise incompatible
with the RCRA waste, even though receipt of that waste  is not
expressly authorized under interim status or in the permit.
Non-RCRA wastes can also be managed at non-RCRA facilities.
Criteria applicable to CERCLA wastes that can be disposed of at
non-Subtitle C facilities are discussed later in this revised
policy.

     The second factor to consider in determining whether this
revised policy applies is the statutory authority for the
action.  This revised off-site policy applies to any remedial
or removal action involving the off-site transfer of any
hazardous substance, pollutant, or contaminant under any CERCLA
authority or under RCRA ง7003. -This policy also applies to
response, actions taken under ง311 of the Clean Water Act,
except for cleanups of petroleum products.  The policy also
covers cleanups at Federal facilities under ง120 of SARA.

     The third factor to assess is the source of funding.  The
revised policy applies to all Fund-financed response actions,
whether EPA or the State is the lead agency.  The policy does
not apply to State-lead enforcement actions  (even at NPL sites)
if no CERCLA funds are involved.  It does apply to State-lead
enforcement actions where EPA provides any site-specific
funding through a Cooperative Agreement or Multi-Site
Cooperative Agreement, even though the State may be using its
own enforcement authorities to compel the cleanup.  Similarly,
non-NPL sites are covered by this policy only where there is an
expenditure of Fund money or where the  cleanup  is undertaken
under CERCLA authority.

     Tha final factor that  affects how  this  revised policy
applies is the date of the  decision document.   As  noted
earlier, there are two classes of actions  subject  to slightly
different procedures governing off-site transfer:   first, those
actions resulting from pre-SARA decision documents  or  RCRA
ง7003 orders issued prior to October  17, 1986,  are subject  to
the May 1985 policy as updated by this  revised  policy;  and
second, those actions resulting from  post-SARA  decision
documents or RCRA ง7003 orders  issued after October 17,  1986,
are subject to the requirements of SARA as interpreted and
expanded by this revised policy.  Although the  procedures in
this policy are similar for these two classes of actions,  there
are important differences  (e.g., the  requirements pertaining to


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                                                         9834.11
                              -4-
releases from other units at a facility)  that will be
highlighted throughout this document.

     Compliance with the revised procedures is mandatory for
removal and remedial actions.  However, there is an emergency
exemption for removals if the OSC determines that the
exigencies of the situation require off-site treatment,  storage
or disposal without following the requirements.  This exception
may be used when the OSC believes that the threat posed  by the
substances makes it imperative to remove the substances
immediately and there is insufficient time to observe these
procedures without endangering public health, welfare or the
environment.  In such cases, the OSC should consider temporary
solutions (e.g., interim storage) to allow time to locate ah
acceptable facility.  The OSC must provide a written.
explanation of his or her decision to use this emergency
exemption to the Regional Administrator within 60 days of
taking the action.  In Regions in which authority to make
removal decisions has not been fully delegated by the Regional
Administrator to the OSC, the decisions discussed above must be
made by the Regional official to whom removal authority has
been delegated.  This emergency exemption is also available to
OSC's taking response actions under  ง311 of the Clean Water
Act.
Ill.  DEFINITIONS

A.Release

     For the purposes of this policy, the term "release" is
defined here as  it  is defined by  ง101(22) of CERCLA, which is
repeated in 40 CFR  300.6 of  the NCP, and the RCRA  ง3008 (h)
guidance ("Interpretation  of Section 3008(h) of the Solid Waste
Disposal Act", memorandum  from J. Winston Porter and Courtney
M. Price to the  Regional Administrators, et al. December 16,
1985).  To summarize, a release is  any  spilling, leaking,
pumping, pouring, emitting,  emptying, discharging, injection,
escaping, leaching, dumping  or disposing to the environment.
This .includes releases to  surface water, ground water,  land
surface, soil and air.

     A release also includes a substantial threat  of a  release.
In determining whether a substantial threat of release  exists,
both the imminence  of the  threat  and the potential magnitude of
the release should  be considered.   Examples of situations where
a substantial threat of a  release may exist include a weakened
or Inadequately  engineered dike wall at a surface  impoundment,
or a severely rusted treatment or storage tank.

     De minimis  releases from receiving units  are' exempt; that
is, they are not considered  to be releases under the  off-site


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                                                        9834.1 1
                              -5-
policy.  pe minimis releases are those that do not adversely
affect public health ojf the environment, such as releases  to
the air from temporary opening and closing of bungs,  releases
between landfill liners; of l gallon/acre/day or less,  or stack
emissions from incinerators not otherwise subject to  Clean Air
Act permits.  Releases that need to be addressed by
implementing a contingency plan would not normally be
considered de minimis releases.

     Federally-permitted releases, as defined by CERCLA
ง101(10) and 40 CFR 300.6, are also exempt.  These include
discharges or releases in compliance with applicable permits
under RCRA, the Clean Water Act, Clean Air Act,, Safe Drinking
Water Act, Marine Protection, Research and Sanctuaries Act, and
Atomic Energy Act or analogous State authorities.

     For purposes of this policy, an interim status unit in
RCRA ground-water assessment monitoring  (under 40 CFR 265.93)
or a permitted unit in compliance monitoring  (under 40 CFR
264.99). is not presumed to have a release.  EPA will evaluate
available information, including the data which led to a
determination of the need for assessment or compliance
monitoring, data gathered during assessment monitoring, and any
other relevant data, including that gathered  from applicable
compliance inspections.  A determination of unacceptability
should be made when information will support  the conclusion
that there is a probable release to ground water from the
receiving unit. Finding a release can happen  at any time
before, during or after an assessment or compliance monitoring
program.

     On the other hand, it is not necessary to have  actual
sampling data to determine that there is a release.  An
inspector may find other evidence that  a release has occurred,
such as a broken dike or feed line at a surface  impoundment.
Less obvious indications of  a release might  also be  adequate to
make the determination.  For example, EPA  could  have sufficient
information on the contents  of  a  land disposal  unit, the  design
and operating characteristics  of  the unit,  or the  hydrogeology
of the area in which the unit  is  located to  conclude that there
is or has been a release to  the environment.

S.  Receiving Unit

     The receiving unit  is  any unit  that receives off-site
CERCLA waste:

     (1)  for treatment  using  BOAT,  including any pre-
          treatment  or storage units used prior to treatment;

     (2)  for treatment  to  substantially reduce its mobility,



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                                                          9834.1 1

                              -6-
          toxicity or persistence in the absence  of  a defined
          BDAT  or

      (3)  for storage or ultimate disposal  of  waste  not treated
          to the previous criteria.

Note that the acceptability criteria may vary  from unit to
unit, and that the receiving unit may vary  from transfer to
transfer.

c,  other Units

     Other units are all other regulated units and solid waste
management units (SWMU's) at a facility that are not receiving
units.

D.  Controlled Release

     In order to be considered a controlled release, the
release must be addressed by a RCRA corrective action program
(incorporated in a permit or order.) or a corrective action
program "approved and enforceable under another applicable
Federal or delegated State authority.

E.  Relevant Violations

     Relevant violations include Class I violations as defined
by the RCRA Enforcement Response Policy  (December 21, 1984, and
subsequent revisions) at or affecting a  receiving unit.  A
Class I violation is a significant  deviation  from regulations,
compliance order provisions or permit conditions designed to:

     o    Ensure that hazardous waste is destined for and
          delivered to authorized facilities;

     o    Prevent releases of hazardous  waste or constituents
          to the environment;

     o    Ensure early detection  of such releases;  or

     o    Compel corrective action  for  releases.

Recordkeeping and reporting requirements (such as failure  to
submit the biennial report or  failure to maintain a copy  of the
closure plan at the facility)  are generally not considered to
be Class I violations.

     Violations affecting a receiving unit include all
ground-water monitoring  violations  unless  the receiving  unit is
outside the waste management  area which the ground-water
monitoring system was designed to monitor.  Facility-wide Class
I violations  (such as failure  to comply with financial

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                                                          9834.1 1
                              -7-
responsibility requirements, inadequate closure plan,
inadequate waste analysis plan, inadequate inspection  plan,
etc.) that affect the receiving unit are also relevant
violations.

     Violations of State or other Federal laws should  also  be
examined for relevance, conridering the significance of the
requirement that is being violated; the extent of deviation
from the requirement; and the potential or actual threat to
human health or the environment.

F.  Relevant Release

     A relevant release under this revised policy includes:

     o    Any release or significant threat of release of a
          hazardous substance  (defined in 40 CFR 300.6) not
          previously excluded  (i.e., de minimis releases or
          permitted releases) at all units of a RCRA Subtitle C
          land disposal facility and at receiving units of a
          RCRA Subtitle C treatment or storage facility; and

     o    Environmentally significant releases of any hazardous
          substance not previously excluded at non-receiving
          units at RCRA Subtitle C treatment and storage
          facilities and at all units at other facilities.

G.  Relevant Conditions

     Relevant conditions include any environmental conditions
(besides a relevant violation) at a facility that pose a
significant threat to public health, welfare or the environment
or that otherwise affect the satisfactory operation of the
facility.

H.  Responsible Agency

     Determinations of acceptability to  receive an off-site
transfer of CERCLA waste will  be made by EPA or by states
authorized for corrective action under  ง3004(u) of RCRA.
References in this document to the  "responsible Agency"  refer
only to EPA Regions or to States with this  authority.

I.  Responsible Government  Official

     The responsible government official is that  person
authorized in the responsible  Agency to make acceptability
determinations under this revised  policy.
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                                                         9834.11
                              -8-
IV.  ACCEPTABILITY CRITERIA

A.  Acceptability Criteria for Wastes Generated Under  Pre-SARA
    Decision Documents

     CERCLA wastes from actions resulting from pre-SARA
decisior documents and pre-SARA RCRA ง7003 order .s may  go  to  a
facility meeting the following criteria:

     o    There are no relevant violations at or affecting the
          receiving unit; and

     o    There are no relevant conditions at the facility
           (i.e., other environmental conditions that pose a
          significant threat to public health, welfare or the
          environment or otherwise affect the satisfactory
          operation of the facility).

     In order to determine if there is a relevant violation,
an appropriate compliance inspection must be conducted no more
than six months before the expected date of receipt of CERCLA
waste.  This inspection, at a minimum, must address all
regulated units.  This inspection may be conducted by EPA, a
State or an authorized representative.  When a State conducts
the inspection, it should determine the facility's compliance
status.  Where a violation or potential violation comes to
EPA's attention  (e.g., through a citizen complaint or a
facility visit by permit staff), the Region or State is
expected to investigate' whether a violation occurred as soon as
is reasonably possible.

     The May 1985 policy does not refer specifically to
releases.  Rather, a corrective action plan is reguired for
relevant conditions.  Therefore, in some  cases,  a facility
receiving CERCLA wastes from an action subject to a pre-SARA
decision document may not need to institute a program  to
control releases.  Releases will be evaluated by the
responsible Agency to determine whether such  releases
constitute relevant conditions under this policy.

     The activities related to determining acceptability,
providing notice to facilities, regaining acceptability  and
implementation procedures are discussed  in the  "Implementation"
section of this document, and apply to off-site transfers of
waste generated under pre-SARA and post-SARA decision
documents.
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                                                          9834.1 1
                              -9-
    Acceptability Criteria for Wastes  Generated Under Post-SARA
    Decision Documents
     Under this revised policy,  there are three basic criteria
that are used to determine the acceptability of a facility to
receive off-site transfers of CERCLA waste generated under a
post-SARA decision document or post.-SARA RCRA ง7003 cleanup.
The criteria are:

     o ,   There must be no relevant violations at or affecting
          the receiving unit;

     o    There must be no releases from receiving units and
          contamination from prior releases at receiving units
          must be addressed as appropriate; and

     o    Releases at other units must be addressed as
          appropriate.

The last two criteria are applied somewhat differently,
depending on the type of facility.  These differences are
described below.

     1.  Criteria Applicable to All RCRA Sub/fcj.'tlฎ  C Treatment.
Storage and Disposal Facilities.  The first criterion that
applies to all Subtitle C facilities is that there can be no
relevant violations at or affecting the receiving  unit.  As
discussed earlier, this determination must be based on an
inspection conducted no more than six months prior to receipt.
of CERCLA waste.

     A second element that applies to all Subtitle C  facilities
is that there must be no releases at receiving units.  Releases
from receiving units, except for de minimis releases  and  State-
and Federally-permitted releases, must be eliminated  and  any
prior contamination from the release must be controlled by a
corrective action permit or order under Subtitle C,  as
described 'in the next section.

     The final criterion that applies to  all Subtitle C
facilities, is that the facility must have  undergone a RCRA
Facility Assessment  (RFA) or equivalent  facility-wide
investigation.  This  investigation addresses EPA's affirmative
duty under CERCLA ง121 (d) (3) to determine that there are  no
releases at the facility.

     Releases of RCRA hazardous waste or hazardous
constituents and CERCLA hazardous  substances  are all included
under the policy.  While the RFA  need not focus on identifying
releases of hazardous substances  that are not  RCRA hazardous
wastes or hazardous constituents,  to the extent such releases
are discovered in an  RFA or  through  other means, they will be

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                                                          9834.1
                              -10-
 considered the  same as a release of hazardous waste or
 hazardous  constituents.

      o  Additional Criteria Applicable to RCRA Subtitle C Land
 Disposal Facilities.  Land disposal facilities must meet
 additional requirements imposed by SARA and this policy.  The
 term "land disposal facility" means any RCRA facility at which
 a  land disposal unit is located, regardless of whether the land
 disposal unit is the receiving unit.  Land disposal units
 include surface impoundments, landfills, land treatment units
 and waste  piles.

      As stated  earlier, there must be no releases at or from
 receiving  units.  In addition, releases from other units at a
 land disposal facility must be controlled under a corrective
 action program.  The RFA will help determine whether there is a
 release.  In addition, land disposal facilities must have
 received a comprehensive ground-water monitoring evaluation
 (CME)  or an operation and maintenance  (O&M) inspection within
 the last year.

      Units at RCRA Subtitle C land disposal facilities
 receiving  CERCLA waste that is also RCRA hazardous waste must
 meet the RCRA minimum technology requirements  of RCRA  ง3004(o) .
 Only where a facility has been granted a waiver can a  land
 disposal unit not meeting the minimum technology requirements
 be considered acceptable for off-site disposal of CERCLA waste
 that is RCRA hazardous waste.

      o  Criteria Applicable to Subtitle C Treatment and Storage
 Facilities.   The criterion for controlling releases from  other
 units does not  apply to all releases at treatment and  storage
 facilities,  as  it does at land disposal facilities.  Releases
 from other units at treatment and storage facilities must be
 evaluated  for environmental significance and  their  effect on
 the satisfactory operation of the facility.   If  determined by
 the responsible Agency to be environmentally  significant,
 releases must be controlled by a corrective action  program
 under an applicable authority.  Releases from other units at
 treatment  and storage facilities determined not  to  be
 environmentally significant do not  affect the acceptability of
 the facility for receipt of CERCLA  waste.

      2.  Criteria Applicable to RCRA Permit-by-Rule Facilities.
 This revised policy is also applicable  to  facilities  subject to
 the RCRA permit-by-rule provisions  in  40 CFR  270.60.   These
 include ocean disposal barges or vessels,  injection wells and
 publicly owned  treatment works  (POTWs).  Permit-by-rule
 facilities receiving RCRA hazardous waste must have a RCRA
 permit or  RCRA  interim status.  RCRA permit-by-rule facilities
must also  receive an inspection for compliance with applicable
RCRA permit or  interim status requirements.   In addition, these


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                                                         9834J
                             -ii-
facilities (and other non-RCRA facilities)  should  be inspected
by the appropriate inspectors  for  other applicable laws.

     In general,  except for POTWs  (discussed  below), these
facilities will be subject to  the  same requirements as RCRA
treatment and storage facilities.  That is, there  can be no
releases of hazardous waste, hazardous constituents or
hazardous substances from receiving  units.  There  also can be
no relevant violations at or affecting the  receiving unit, as
confirmed by an inspection conducted no more  than  six months
prior to the receipt of CERCLA waste.  Releases from other
units determined by the responsible  Agency  to be
environmentally significant must be  controlled by  an
enforceable agreement under the applicable  authority.

     Criteria for discharge of wastewater from CERCLA  sites  to
POTWs can be found in a memorandum titled,  "Discharge  of
Wastewater from CERCLA Sites into  POTWs," dated April  15,  1986.
That memorandum requires an evaluation during the  RI/FS process
for the CERCLA site to consider such points as:

     o    the quantity and quality of the CERCLA wastewater  and
          its compatibility with the POTW;

     o    the ability of the POTW  to ensure compliance with
          applicable pretreatment  standards;

     o    the POTWs record of compliance with its NPDES permit;
          and

     o    the potential for ground-water contamination from
          transport to or impoundment of CERCLA wastewater at
          the POTW.

Based on a consideration of these and other points listed in
the memorandum, the POTW may be deemed appropriate or
inappropriate for receipt of CERCLA waste.

     3.  Criteria Applicable to Non-Subtitle  C Facilities.  In
some instances, it may be appropriate to use  a non-Subtitle C
facility for off-site transfer:   for example,  PCS disposal  is
regulated under the Toxic Substances Control  Act  (TSCA);
nonhazardous waste disposal is regulated under  Subtitle D of
RCRA and applicable State laws; and disposal  of radionuclides
is regulated under the Atomic Energy Act.  At such facilities,
all releases are treated  in the same manner  as  releases from
other units at Subtitle C treatment and  storage facilities.
That is, the responsible Agency should make  a determination as
to whether the release is environmentally  significant and,  if
so, the release should be controlled by  a  corrective  action
program under the applicable  Federal or  State authority.

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                                                         9834J
                             -12-
     Requirements for the disposal of PCBs are established  in
40 CFR 761.60.  Generally, these regulations require that
whenever disposal of PCBs is undertaken,  they must be
incinerated,* unless the concentrations are less than 50  ppm.
If the .concentrations are between 50 and 500 ppm,  the rule
provides for certain exceptions that provide alternatives to
the incineration requirements.  The principal alternative is
disposal in a TSCA-permitted landfill for PCBs.  If a TSCA
landfill is the receiving unit for PCBs,  then that facility is
subject to the same criteria applicable if a RCRA land disposal
unit is the receiving unit; i.e., no relevant violations, no
releases at the receiving unit and controlled releases at other
units.  PCBs at levels less than 50 ppm may be transported  to
acceptable Subtitle D facilities as discussed previously.


V.  IMPLEMENTATION

A.  Determining Acceptability

     Acceptability determinations under the .off-site policy
will be made by EPA or by States authorized for corrective
action under ง3004(u) of RCRA.  Where States have such
authority, the State may make acceptability determinations for
facilities in the State in consultation with EPA.  Regardless
of a State's authorization status, the Region  and States should
establish, in the Superfund Memorandum of Agreement, mechanisms
to ensure timely exchange of  information, notification of
facilities and coordination of activities related to the
acceptability of facilities and potential selection  of
facilities for off-site transfer.  The Regions and  States  also
need to establish or enhance  coordination mechanisms with  their
respective RCRA program staffs in order to ensure timely
receipt of information on inspections, violations and releases.
These agreements can be embodied  in  State authorization
Memoranda of Agreement, State grant  agreements, or  State-EPA
enforcement agreements.

     Thซ responsible government  official  in the "Region  or  State
in which a hazardous waste  facility  is located will determine
whether the facility has relevant violations  or releases which
may preclude its use for off-site transfer  of  CERCLA wastes.
Each Region and State should  have a  designated off-site
coordinator responsible for ensuring effective communication
between CERCLA response program  staff and RCRA enforcement
staff within the Regional Offices, with States, and with other
Regions and States.

     The off-site coordinator should maintain a  file of all
information on the compliance and release  status  of each
commercial facility in the  Region or State.   This information
should be updated based on  the  results  of  State-  or

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                                                         9834.U
                             -13-
EPA-conducted compliance inspections or other  information  on
these facilities.

     CERCLA response program staff should identify potential
off-site facilities early in the removal action or the remedial
design process and check with the appropriate  Regional and/or
State off-site coord: nator(s) regarding the acceptability
status of the facilities.  If one or more facilities is
identified that has not received an inspection within the  last
six months, the Regional off-site coordinator(s) should arrange
to have such inspection(s) conducted within a  timeframe
dictated by the project schedule.  The CERCLA  REM/FIT
contractor may conduct the inspection under the direction  of
the Deputy Project Officer.  If contractor personnel are used,
the Region should ensure- that such personnel are adequately
trained to conduct the inspections.

     Responsible Agencies should base their acceptability
determinations on an evaluation of a facility's compliance
status and, as appropriate, whether the facility has releases
or other environmental conditions that affect the satisfactory.-
operation of the facility.  States not authorized for HSWA
corrective action may assist EPA in making the acceptability
determination by determining a facility's compliance status
(based on a State inspection) and providing this information to
EPA.  Regions and States should use the following types of
information to make acceptability determinations:

     o    State- or EPA-conducted inspections.  EPA will
          continue to assign high priority to conducting
          inspections at commercial land disposal, treatment
          and storage facilities.  Facilities designated  to
          receive CERCLA waste must be  inspected within six
          months of the planned  receipt of the  waste.  In
          addition, land disposal facilities  must have received
          a comprehensive  ground-water  monitoring  inspection
           (CHE) or an operation  and maintenance (O&M)
          inspection within  the  last year,  in accordance  with
          the timeframes  specified  in  the  RCRA Implementation
          Plan  (RIP).

     o    RCRA Facility Assessments  fRFAs).   To be eligible
          under this policy,  a RCRA Subtitle  C facility must
          have had an RFA or equivalent facility-wide
          investigation.   The RFA or its equivalent must  be
          designed to identify existing and potential releases
          of hazardous waste and hazardous constituents from
          solid waste management units at the facility.

     o    Other data sources.   Other documents such as the
          facility's permit  application,  permit, Ground Water
          Task Force report,  ground-water monitoring data or

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                                                           9834.1 I
                              -14-
           grovmd-water assessment report can contain
           information on violations, releases or other
           conditions.   Relevant  information from these
           documents should also  be used to determine a
           facility's acceptability to receive waste under the
           off-site policy.

 B.   Notice Procedures

      EPA expects that Regions and States will take timely and
 appropriate enforcement action on determining that a violation
 has occurred.   Where a responsible Agency performs an
 inspection that identifies a relevant violation at a commercial
 facility likely to accept CERCLA wastes, within five working
 days of the violation determination, the responsible Agency
 must provide written notice to the facility of the violation
 and the effects of applying this policy.  States  not authorized
 for HSWA corrective action should  inform EPA of the violation
 so that EPA can notify the facility  of the effect of the
 violation under this policy.  (See RCRA Enforcement Response
 Policy for a discussion of appropriate enforcement responses
-and timeframes for Class I violations".)

      When the responsible Agency determines that  a relevant
 release has occurred, or that relevant conditions exist,  the
 responsible Agency must notify the facility in  writing within
 five working days of that determination.'  The notice must also
 state the effect of the determination under this  policy.   A
 copy of any notice must also be provided to the non-issuing
 Region or State in which the facility  is located.  States not
 authorized for HSWA corrective action  should provide EPA with
 information on releases so that EPA can determine whether a
 relevant release has occurred.

      Private parties conducting a  response  action subject to
 this policy will need to obtain information on  the
 acceptability of commercial facilities.  The  responsible Agency
 must respond with respect to both pre-SARA  and post-SARA
 wastes.  In addition, the responsible Agency  should indicate
 whether the facility is currently undergoing  a review of
 acceptability and the date the review is  expected to be
 completed.  No enforcement sensitive or predecisional
 information should be released.

      A facility may submit a bid for receipt of CERCLA waste
 during a period of unacceptability.  However,  a facility must
 be  acceptable in order to be awarded a contract for receipt of
 CERCLA waste.

      Scope and Contents of the Notice.  The responsible Agency
 must send the notice to the  facility owner/operator by
 certified and first-class mail, return receipt requested.  The


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                                                           9834.1
                             -15-
certified notice,  if not acknowledged by the- receipt return
card,  will be considered to have been received by the addressee
if properly sent by first-class mail to the last address known
to the responsible Agency.   The notice should contain the
following:

     o    A finding that the facility may nave conditions that
          render"it unacceptable for receipt of off-site waste,
          based upon available information from an RFA, an
          inspection, or other data sources;

     o    A description of the specific acts, omissions or
          conditions that form the basis of the findings ;

     o    Notice that the facility owner/operator has* the
          opportunity to request an informal conference with
          the responsible government official to discuss the
          basis for the facility's unacceptability
          determination under this revised policy, provided
          that such a request is made within 10 calendar days
          from the date of the notice.  The owner/operator may
          submit written comments within 30 calendar days from
          the date of the notice in lieu of holding the
          conference.

     o    Notice that failure to request an informal meeting or
          submit written comments will result in no further
          consideration of the determination by the responsible
          Agency during the 60 calendar days after issuance  of
          the notice.  The responsible Agency will cease any
          transport of CERCLA waste to the  facility on the  60th
          calendar day after issuance of the notice.

     o    Notice that the owner/operator may request,  within 10
          calendar days of hearing  from the  responsible
          government official after the informal  conference or
          the submittal of written  comments, a  reconsideration
          of the determination by the Regional  Administrator or
          appropriate State official.  The  Regional
          Administrator or State official may  agree to review
          the determination at his  or her discretion; and

     o    Notice that such a review by the  Regional
          Administrator or appropriate State official, if
          agreed to, will be conducted within 60 calendar days
          of the initial notice, if possible,  but that the
          review will not stay the  determination.

     The facility may continue to receive  CERCLA waste for  60
calendar days after  issuance of  the initial notice.  As
indicated above, facility owners or operators may request an
informal conference  with the responsible  government official

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                                                          9834.1 i
                              —16—
 within 10 calendar  days  from the  date of issuance of the
 notice,  to discuss  the basis for  a violation or release
 determination 'and its relevance to the  facility's acceptability
 to receive CERCLA wastes.   Any such  meeting should take place
 within 30 calendar  days  of  the date  the initial notice is
 issued.   If unacceptability is based on a State inspection or
 enforcement action,  L, representative of the State should attend
 the meeting.   If the State  does not  attend, EPA will notify the
 State of the outcome of  the meeting.  The owner/opeator may
 submit written comments  within 30 calendar days from the date
 of the notice in lieu of holding  the conference.  If the
 responsible Agency  does  not find  that the information submitted
 at the informal conference  or in  comments is sufficient to
 support a finding of acceptability to receive CERCLA wastes,- it
 should so inform the facility orally or in writing.

      Within 10 calendar  days of hearing from the responsible
 government official after the informal  conference or the
 submittal of written comments, the facility owner or operator
 may request a reconsideration of  the determination by the
 Regional Administrator or appropriate State official.  The
 Regional Administrator or appropriate State official may use
 his or her discretion in deciding whether to conduct a review
 of the determination.  Such a review, if granted, should be
 conducted within the 60  day period  (originating with the
 notice)  to the extent possible..   The review will not stay the
 determination.

      The RPM,  OSC or equivalent site manager must stop transfer
 of waste to a facility on the 60th calendar day after  issuance
 of a notice.   The facility  then remains unacceptable until such
 time as  the responsible  Agency notifies the owner or operator
 otherwise.   The off-site coordinator and the OSC/RPM should
 maintain close coordination throughout  the 60-day period.

      In  limited cases, the  responsible  Agency may use  its
 discretion to extend the 60 day period  if  it requires  more time
 to reviaw a submission.  The facility should be notified of  any
 extension,  and it remains acceptable during any extension.

      The responsible Agency may also use  its discretion to
 determine that  a facility's unacceptability is  immediately
 effective upon  receipt of a. notice to that effect.  This may
 occur in situations such as, but  not limited to,  emergencies
 (e.g., fire or explosion) or egregious  violations  (e.g.,
 criminal violations or chronic recalcitrance)  or  other
 situations  that render'the  facility  incapable  of  safely
handling CERCLA waste.

      Implementation of this notice  provision  does not relieve
the  Regions or  States from  taking appropriate  enforcement
action under  RCRA or CERCLA.
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                                                        9834.1
                             -17-
C.  Procedures for Facilities with  Outstanding  Unacceotabilitv
    Determinations

     Under ,the original May 1985 off-site policy,  facilities
determined to be unacceptable to receive CERCIA wastes were
provided with written notice and were generally afforded
informal opportunities to comment on the determination (the
latter step was not required by the policy) .  Although the
Agency believes that these steps represented  adequate
procedural safeguards for facilities seeking  to receive CERCLA
wastes, EPA has decided to provide an additional opportunity
for review, in light of this revised policy,  for facilities
with unacceptability determinations already in  place on the
effective date of the revised policy.

     Any such facility that wishes to meet  with the responsible
Agency to discuss the basis for a violation or  release
determination and its relevance to the facility's ability to
receive CERCLA wastes, may request an informal  conference with
or submit written comments to the responsible Agency at any
point up to the 60th day after the publication of the proposed
rule on the off-site policy in the Federal  Register.  Such a
meeting should take place within 30 calendar days of the
request.  If the responsible government Agency does not find
the information presented to be sufficient to support a finding
of acceptability to receive CZRCLA wastes,  then it should
inform the facility orally or  in writing that the
unacceptability determination  will continue to be in  force.
The facility may, within 10  calendar days of hearing  from  the
responsible government official after the informal conference
or submittal of written comments, petition the EPA Regional
Administrator or appropriate  State official for
reconsideration.  The Regional Administrator or State official
may use his or her discretion in deciding whether to  grant
r econs ider at ion.

     Thesซ procedures  for  review of  unacceptability
determinations that were already  in  place  on the  effective date
of this revised policy will  not act  to stay the effect of the
underlying unacceptability determinations  during  the period of
review.

D.  Re-evaluating Unacceptabilitv

     An unacceptable  facility can  be reconsidered for
management of  CERCLA  wastes whenever the responsible Agency
finds  that the facility  meets the criteria described in the
"Acceptability Criteria"  section of this policy.

      For  the  purposes of this policy,  releases will be
considered controlled upon 'issuance of an  order or permit that


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                               -13-
 initiates and requires  completion of one or mere of the
 following:   a facility-wide RCRA Facility Investigation (RFI) ?
 a Corrective Measures Study  (CMS) ; or Corrective Measures
 Implementation (CMI).   The facility must complv with the permit
 or order to -remain acceptable to receive CERCIA waste.  At the
 completion  of any such  phase of the corrective  action process,
 the responsible Agency  should again review the  facility for
 acceptability under the off-site policy using the criteria
 listed  in this document, and as necessary and appropriate, make
 new acceptability determinations, and issue additional orders
 or modify .permit conditions to control identified releases.
 Releases that require a determination of environmental
 significance will be considered controlled upon issuance of an
 order or permit to conduct an RTI, CMS or CMI,  or unon
 completion  of an RFI which concludes that the release is not
 environmentally significant.  Again, the facility must comply
 with, the permit or order to remain acceptable to receive CERCLA
 waste.

      If  the  facility is determined to be-unacceptable as a
 result of relevant violations at or affecting the receiving
 unit,  the State (if it made 'the initial determination) or EPA
 must determine  that the receiving unit is in full -physical
 compliance with all applicable requirements.  Where a State not
 authorized for  ESWA corrective action makes this determination,
 it should notify EPA immediately .of the facility's return to
 compliance, so  that the Agency can expeditiously inform the
 facility that it  is once again acceptable to receive CSRCLA
 wastes.

     The responsible Agency will notify the facility of its
 return to acceptability by certified and first-class mail, '
 return receipt  requested.

 5..  linolementation  Procedures

     All remedial decision documents must discuss compliance
 with this policy for alternatives involving off-site management
 of CERCIA wastes.   Decision documents for removal actions also
 should include such a discussion.

     Provisions requiring  compliance with this  policy should be
 included in all contracts  for response action,  Cooperative
 Agreements with States undertaking Superfund response actions,
 and enforcement agreements.   For ongoing projects, these
provisions will be implemented as follows,  taking into
 consideration the differences in applicable requirements for
pre- and post-SARA decision documents:

     0     RT/TS;  The Regions shall  immediately notify Agency .
           contractors and States that alternatives for off-site
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                                                        9834,1 1
                             -19-
          management of wastes must  be  evaluated against the
          provisions of this policy.

     o    Remedial Design:  The Regions shall  immediately
          notify Agency contractors,  the States, and the U.S.
          Army Corps of Engineers that  all  remedies that
          include off-site disposal  of  CERCLA  waste must comply
          with the provisions of this policy.

     o    Remedial Action:  The Regions shall  immediately
          assess the status of compliance,  releases and other
          environmental conditions at facilities receiving
          CERCLA waste from ongoing projects.   If a facility is
          found not to be acceptable, the responsible Agency
          should notify the facility of its unacceptability.

     o    Enforcement:  Cleanups by responsible parties under
          enforcement actions currently under negotiation  and
          all future actions must comply with this policy.
          Existing agreements need not  be amended.  However,
          EPA reserves the right to apply these procedures to
          existing agreements, to the extent it- is consistent
          with the release and reopener clauses in the
          settlement agreement.

     If the response action is proceeding under a Federal  lead,
the Regions should work with the Corps of Engineers or EPA
Contracts Officer to negotiate a contracts modification to an
existing contract, if necessary.  If the response action  is
proceeding under a State  lead, the Regions should amend the
Cooperative Agreement.
                             A-25

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                   APPENDIX B

USEPA POLICY MEMORANDUM - DISCHARGES FROM CERCLA
                  SITES TO POTWs
                       B-l

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                      WASHINGTON, D.C. 20460
                          APR  151966
MEMORANDUM
SUBJECT:  Discharge of Wastewater  from  CERCIiA  S/dJces  into POTWS
FROM:     Henry L. Longest  II, Director   **  JA I
          Office of Emergency and Remediai7jt3|Bt>6nse

          Rebecca Hanmer, Director     l\cflo*'CX^_.
          Office of Water Enforcement  and  Permits
          Gene A. Lucero,  Director
          Office of Waste  Programs  Enforcement

TO:       Waste Management Division Directors
          Regions I - X

          Water Management Division Directors
          Regions I - X


     A number of emergency removals and remedial cleanup actions
under CERCLA will involve  consideration of publicly owned treat-
ment works (POTWs) for discharge of wastewater.  The current
off-site policy (issued on May 6, 1985) does not address the set
of concerns and issues unique to POTWs that must be evaluated
during the Remedial Investigation and Feasibility Study (RI/FS)
for discharge of CERCLA wastewater  to POTWs.

     Recently, we have had meetings with representatives of the
Association of Metropolitan Sewerage Authorities (AMSA) to discuss
technical and policy concerns related to the POTW/CERCLA issue.
This memorandum is to highlight some of the major points under
consideration which were shared with AMSA at their recent Winter
Technical Conference.  The Agency intends to develop policy on
the use and selection of POTWs for  CERCLA wastewater.  Your
comments are sought on the proposed criteria set forth herein.
These criteria may be useful in evaluation of POTWs for response
actions (fund financed or  responsible party financed) to be taken
in the interim.

     Our position is that no CERCLA discharges to a POTW should
occur unless handled in a manner demonstrated to be protective
of human health and the environment.  Full compliance with all
applicable requirements of the Clean Water Act (CWA), the
Resource Conservation and Recovery  Act (RCRA), and any other
relevant or appropriate environmental statutes will be necessary .
                           B-2

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                               - 2 -


      The  national  pretreatment program,  under the Clean Water Act,
 requires  an  analysis to determine whether the discharge of an
 industrial user  of a POTW may pass through the POTW to cause
 receiving water  quality problems or may  interfere with POTW
 operations  (including sludge disposal).   If the analysis suggests
 that limits  on the industrial user's discharge are needed to pre-
 vent pass through  or interference, local limits or other safe-
 guards, as necessary, must be established by the POTW and/or the
 NPDES permitting authority.  The national pretreatment program
 requirements apply to the introduction of all non-domestic
 wastewater  into  any POTW, and include, among other things, the
 following elements:

      o Prohibited discharge standards - prohibit the intro-
        duction  of pollutants to the POTW which are ignitable,
        corrosive, excessively high in temperature, or which
        may  cause  interference or pass through at the POTW.

      o Categorical discharge standards  - include specific pre-
        treatment  standards which are established by EPA for the
        purpose  of regulating industrial discharges in specific
         industrial categories.

      o - Local limits - where no categorical standards have been
        promulgated or where more stringent controls are necessary.

      POTWs  under consideration as potential receptors of CERCLA
 wastewaters  may  include those POTWs either with or without an
 approved  pretreatment program.  POTWs with an approved pretreat-
 ment program are required to have the mechanisms necessary to
 ensure compliance  by industrial users with applicable pretreatment
 standards and requirements.*  POTWs without an approved pretreat-
 ment program must  be evaluated to determine whether sufficient
 mechanisms  exist to allow the POTW to meet the requirements of
 the national pretreatment program in accepting CERCLA wastewaters.
 As noted  above,  pass through and interference are always prohibited,
 regardless  of whether a POTW has an approved pretreatment program.
 POTWs without an approved pretreatment program must therefore
 have mechanisms  which are adequate to apply the requirements of
 the national pretreatment program to specific situations.
*POTWs with approved pretreatment programs must, among other
 things, establish procedures to notify industrial users (lUs) of
 applicable pretreatment standards and requirements,  receive and
 analyze self-monitoring reports from lUs, sample and analyze
 industrial effluents, investigate noncorapliance, and comply with
 public participation requirements.
                           . B-3

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                               -3-


    Determination of a POTWs ability to accept CERCLA wastewater
as an alternative to on-site treatment and direct discharge to
receiving waters must be made during the Remedial Investigation/
Feasibility Study (RI/FS) process.  During the remedial alternatives
analysis, the appropriateness of using a POTW must be carefully
evaluated.  Water Division officials and their state counterparts
should participate in the evaluation of any remedial alternatives
recommending the use of a POTW, and should concur on the selection
of the POTW.

     If an alternative considers the discharge of wastewater from
a CERCLA site into a POTW, the following points should be evaluated
in the RI/FS prior to the selection of the remedy for the site:

     o  The quantity and quality of the CERCLA wastewater and its
        compatibility with the POTW (The constituents in the
        CERCLA wastewater must not cause pass through or inter-
        ference, including unacceptable sludge contamination or
        a hazard to employees at the POTW; in some cases, control
        equipment at the CERCLA site may be appropriate in order
        to pretreat the CERCLA discharge prior to introduction to
        the POTW).

     o  The ability (i.e., legal authority, enforceable mechanisms,
        etc.) of the POTW to ensure compliance with applicable
        pretreatment standards and requirements, including monitor-
        ing and reporting requirements.

     o  The POTW1s record of compliance with its NPDES permit
        and pretreatment program requirements to determine if
        the POTW is a suitable disposal site for the CERCLA waste-
        water.

     o  The potential for volatilization of the wastewater at the
        CERCLA site and POTW and its impact upon air quality.
                                                     •

     o  The potential for groundwater contamination from trans-
        port of CERCLA wastewater or impoundment at the POTW, and
        the need for groundwater monitoring.

     o  The potential effect of the CERCLA wastewaters upon the
        POTW's discharge as evaluated by maintenance of water
        quality standards in the POTW's receiving waters,
        including the narrative standard of "no toxics in toxic
        amounts".
                            B-4

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                              - 4 -
     o  The POTW1s knowledge of and compliance with any applicable
        RCRA requirements or requirements of other environmental
        statutes (RCRA perrait-by-rule requirements may be trig-
        gered if the POTW receives CERCLA wastewaters that are
        classified as "hazardous wastes" without prior mixing
        with domestic sewage, i.e., direct delivery to the POTW
        by truck, rail, or dedicated pipe; CERCLA wastewaters are
        not all necessarily considered hazardous wastes; case by
        case determinations have to be made).

     o  The various costs of managing CERCLA wastewater, including
        all risks, liabilities, permit fees, etc. (It may be
        appropriate to reflect these costs in the POTW's connection
        fees and user charg-e system) .

     Based upon consideration of the above elements, the discharge
of CERCLA wastewater to a POTW should be deemed inappropriate if
the evaluation indicates that:

     o  The constituents in the CERCLA discharge are not com-
        patible with the POTW and will cause pass through, inter-
        ference, toxic pollutants in toxic amounts in the POTW's
        receiving waters, unacceptable sludge contamination, or a
        hazard to employees of the POTW.

     o  The impact of the transport mechanism and/or discharging of
        CERCLA wastewater into a POTW would result in unacceptable
        impacts upon any environmental media.

     o  The POTW is determined to be an unacceptable receptor
        of CERCLA wastewaters based upon a review of the POTW's
        compliance history.

     o  The use of the POTW is not cost-effective.

     If consideration of the various elements indicates that the
discharge, of CERCLA wastewater to a POTW is deemed appropriate:

     o  There should be early public involvement, including
        contact with POTW officials and users, in accordance
        with the CERCLA community relations plan and public
        participation requirements.

     o  The NPDES permit and fact sheet may need to be modified
        to reflect the conditions of acceptance of CERCLA waste-
        waters; permit modification may be necessitated by the
        need to incorporate specific pretreatment requirements,
        local limits, monitoring requirements and/or limitations
        on additional pollutants of concern in the POTW's dis-
        charge or other factors.
                             8-5

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                               -5-


     Policy to be developed in the future will apply to all
removal, remedial, and enforcement actions taken pursuant to
CERCLA and Section 7003 of RCRA.  We would appreciate your feed-
back on this memorandum and any experience in the use of POTWs
for CERCLA removal or remedial actions that you have to offer.

     If you have any comments or questions on this issue, please
submit written comments to the workgroup co-chairs:  Shirley Ross
(FTS-382-5755) from the Office of Emergency and Remedial Response,
or Victoria Price (FTS-382-5681) from the Office of Water.

cc:  Ed Johnson
     Russ Wyer
     Tim Fields
     Steve Lingle
                           B-6

-------
              APPENDIX C




PERCENT REMOVAL OF COMPOUNDS IN POTWs
                C-l

-------
APPENDIX C ~ PERCENT REPPVftL OF COMPOUNDS IN POTWS.   To evaluate  the
feasibility of  discharging wastes from CERCLA sites to POTWs,  the user
of  the  guidance  manual  may need to  estimate  the  treatability  of
cxxipounds  in the  CERCXA waste  and their potential  to impact removal
processes  in the treatment system.   The removal  mechanisms in a FOTW
include  air  stripping,  partitioning  (sorption)   to  the  solids  and
biomass,  and biodegradation.  Appendix C  presents summary tables  of
published treatability data for individual compounds that can be used to
estimate  a  mass  balance  for  each  compound  detected  in  a  CERdA
wastestream if site specific treatability data is unavailable.

The  data  presented in Appendix  C  was generated from  a  number  of
different  published studies on  the total percent removal of  specific
pollutants  in  biological   treatment systems.    Biological  treatment
systems presented  in the tables  include aerated lagoon  (AL),  activated
sludge (AS), and trickling filter (TF).  The data was separated into  six
concentration ranges,  and distinguished between effluent samples that
were chlorinated and those that were not.   The number of observations
(OBSV)  is the  number of  publications from  which data was taken  and
averaged to obtain  a  mean  percent removal.  The minimum and maximum
percent removal, standard error  (SE), and  90% confidence interval  are
also presented.

The following key is to be used with Appendix C:

AIป   -  Aerated lagoon                 MEAN - Mean Percent Removal
AS   -  Activated Sludge               MEN  - Minimum Percent Removal
TF   -  Trickling Filter               MAX  - Maximum Percent Removal
N   -   Number of Data Points          SE   - Standard Error
OBSV  - Number of Publications Used    90% d - 90% Confidence Interval
                                   C-2

-------
POTW - Percent Removal




PARAMETER:  1,1,1-TRICHLOROETHANE
18-Apr-90


TMP1
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000
	 _.

CHLORINATED
TREATMENT: AL
N
6

_
.
-
OBSV MEAN
1 88.76

_
.
-
MIN
88.76

.
.
-
MAX
88.76

.
.
-
SE
0.00

.
.
-
90% C.I.
(0,0)

_
.
-
TREATMENT: AS
N
140
29
24
.
0
6
OBSV MEAN
16 50.51
4 83.47
4 87.82
. -
1 98.28
1 87.04
MIN
0.00
58.94
68.66
•
98.28
87.04
MAX
95.35
98.65
99.56
•
98.28
87.04
SE
10.45
8.66
6.76
•
0.00
0.00
90% C.I.
(32,69)
(63 99)
(72,99)

(0,0)
(OlO)
TREATMENT: TF
N
30
12
6
-
.
-

OBSV MEAN
5 55.08
1 97.00
1 92.94
•
.
-

MIN
0.00
97.00
92.94
-
-
-

MAX
98.00
97.00
92.94
*
-
-

SE
22.57
0.00
0.00
-
-
-

90% C.I.
(7,100)
(0,0)
(0)0)

.
-
	 	 	

NON-CHLORINATED

N
6
.
.
.
-

N
103
6
24
-
7
6

N
6
-
6
•
-
•

TREATMENT: AL
OBSV MEAN MIN
1 90.91 90.91
- - -
-
-
-
TREATMENT: AS
OBSV MEAN MIN
18 69.67 0.00
2 77.64 69.57
4 95.33 90.40
. - .
2 98.93 97.98
2 99.25 98.64
TREATMENT: TF
OBSV MEAN MIN
1 41.18 41.18
...
1 98.40 98.40
. - -
...
- - -
	 	 	

MAX
90.91
„
m
_
-

MAX
100.00
85.71
99.77
•
99.88
99.24

MAX
41.18

98.40
-
.
-


SE
0.00



-

SE
7.06
8.07
1.93
.
0.95
0.60

SE
0.00

0.00
.
.
-


90% C.I.
(0,0)


•
-

90% C.I.
(57.82)
(19.100)
(91|100)
_
(93,100)
(95,100)

90% C.I.
(0,0)

(0,0)

.
-

'ARAMETER:  1,1,2,2-TETRACHLOROETHANE



CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000

CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
53 4 22.22 0.00 88.89 22.22 (0,75)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.


NON -CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
TREATMENT: AS
N OBSV MEAN MIN MAX
7 2 85.29 70.59 100.00
0 1 90.00 90.00 90.00
6 2 95.31 94.53 96.15
TREATMENT: TF
N OBSV MEAN MIN MAX
.



SE 90% C.I.
-
SE 90% C.I.
14.71 (0,100)
0.00 (0,0)
0.81 (90,100)
SE 90% C.I.
:r::======:5=:s — =====
                                                              C-3

-------
POTW - Percent Removal
18-Apr-9C
PARAMETER: 1,1,2-TRICHLOROETHANE



CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-SO
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000
axBBXsaastss:
CHLORINATED
TREATMENT: AL
N OBSV MEAN HIM MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
81 5 47.67 0.00 95.65 19.83 (5.90)
TREATMENT: TF
H OBSV MEAN MIN MAX SE 90% C.I.

NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
5 3 52.78 0.00 100.00 29.00 (0,100)
20 2 79.47 78.95 80.00 0.53 (76,83)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
.
PARAMETER:  1,1-DICHLOROETHANE
IHFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000

CHLORINATED
TREATMENT: AL
H OBSV MEAN
MIN MAX SE 90% C.I.
6 1 62.96 62.96 62. 96 0.00 (0,0)
TREATMENT: AS
N OBSV MEAN
MIN MAX SE 90% C.I.
12 3 45.83 0.00 87.50 25.35 (0,100)
TREATMENT: TF
H OBSV MEAN
MIN MAX SE 90% C.I.
6 1 0.00 0.00 0.00 0.00 (0,0)
                                                                                      NON-CHLORINATED
                                                                                      TREATMENT: AL
                                                                           N     OBSV   MEAN     MIN    MAX    SE   90% C.I.

                                                                            14     1  68.75   68.75  68.75   0.00    (0,0)


                                                                                      TREATMENT: AS
N



47
14
OBSV
11
2
MEAN
49.97
92.22
MIN
0.00
90.00
MAX
100.00
94.44
SE
9.
2.

59
22
90%
C.I.
(33,55)
(78
,100)
TREATMENT: TF
N



6
14
OBSV
1
1
MEAN
75.00
34.72
MIN
75.00
34.72
MAX
75.00
34.72
SE
0.
0.

00
00
90%


C.I.
(0,0)
(0,0)
                                                             C-4

-------
POTW -  Percent  Removal
                                                                                                                   18-Apr-90
PARAMETER:  1,1-DICHLOROETHENE



CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
100 8 50.92 0.00 98.61 15.43 (22,80)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
6 1 75.00 75.00 75.00 0.00 (0.0)
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
14 1 60.85 60.85 60.85
TREATMENT: AS
N OBSV MEAN MIN MAX
12 4 53.47 0.00 97.22
20 1 99.74 99.74 99.74
14 2 94.20 93.40 95.00
TREATMENT: TF
N OBSV MEAN MIN MAX
6 1 50.00 50.00 50.00
14 1 59.91 59.91 59.91


SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
20.33 (6,100)
0.00 (0.0)
0.80 (89,100)
SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
PARAMETER: 1,2,4-TRICHLOROBENZENE

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000

CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN
MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN
35 2 57.35 50.00
TREATMENT: TF
N OBSV MEAN MIN
MAX SE- 90% C.I.
64.71 7.35 (11,100)
MAX SE 90% C.I.
-.---- -
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
0 1 83.33 83.33 83.33 0.00 (0,0)
16 4 89.51 83.33 100.00 3.75 (81,98)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
.
                                                                C-6

-------
POTW - Percent Removal




PARAMETER: 1,2-DICHLOROBENZENE
18-Apr-90


cone.
0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
TREATMENT: AS
N OBSV MEAN MIN MAX
76 11 53.22 0.00 95.65
6 1 98.00 98.00 98.00
6 1 94.29 94.29 94.29
TREATMENT: TF
N OBSV MEAN MIN MAX
12 2 25.00 0.00 50.00


SE 90% C.I.
-
SE 90% C.I.
12.27 (31.75)
0.00 (6,0)
0.00 (0,0)
SE 90% C.I.
25.00 (0,100)
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE
TREATMENT: AS
N OBSV MEAN MIN MAX SE
36 8 39.96 0.00 100.00 14.
5 3 91.79 90.00 93.82 1.
6 2 99.72 99.50 99.94 0.
TREATMENT: TF
N OBSV MEAN MIN MAX SE
6 1 28.57 28.57 28.57 0.


90% C.I.
-
90% C.I.
72 (12,68)
11 (89,95)
22 (98,100)
90% C.I.
00 (0,0)
0-50
51-100
101-500
501-1000
1001-5000
> 5000
12 2
25.00 0.00 50.00
25.00 (0,100)
6 1 28.57
PARAMETER: 1,2-D1CHLOROETHANE

1NFL
CONG.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000

N OBSV
CHLORINATED
TREATMENT: AL
MEAN MIN MAX

SE 90% C.I.
TREATMENT: AS
N OBSV
6 4
6 1
6 2
H 08SV
6 1
MEAN MIN MAX
21.72 0.00 86.91
99.75 99.75 99.75
60.94 32.85 89.03
TREATMENT: TF
MEAN MIN MAX
50.00 50.00 50.00
SE 90% C.I.
21.72 (0,73)
0.00 (0.0)
28.09 (0,100)
SE 90% C.I.
0.00 (0,0)
28.57 28.57 0.

NON-CHLORINATED

00 (0,0)


TREATMENT: AL
N OBSV MEAN
MIN
14 1 70.59 70.59
TREATMENT: AS
N OBSV MEAN
MIN
4 4 60.30 0.00
14 2 87.81 85.62
5 1 98.28 98.28
6 2 98.41 98.25
TREATMENT: TF
N OBSV MEAN
14 1 39.22
MIN
39.22
MAX SE
70.59 0.
MAX SE
90.00 20.
90.00 2.
98.28 0.
98.57 0.
MAX SE
39.22 0.
90% C.I.
00 (0,0)
90% C.I.
71 (12,100)
19 (74,100)
00 (0,0)
16 (97,99)
90% C.I.
00 (0,0)
                                                            C-6

-------
POTW - Percent Removal




PARAMETER:  1,2-DICHLOROPROPANE
18-Apr-90

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLO
RINATEO
TREATMENT: AL
N OBSV MEAN MIN
MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN
6 1 99.54 99.54
TREATMENT: TF
N OBSV MEAN MIN
6 1 33.33 33.33
PARAMETER: 1,3-DICHLOROBENZENE

MAX SE 90% C.I.
99.54 0.00 (0,0)
MAX SE 90% C.I.
33.33 0.00 (0,0)
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90%
•=====
C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90%
8 2 75.00 50.00 100.00 25.00 (0,
25 3 94.33 90.00 98.06 2.35 (88,
6 2 99.33 99.01 99.65 0.32 (97,
TREATMENT: TF
N OBSV MEAN MIH MAX SE 90%
---•*-

C.I.
100)
100)
100)
C.I.
-



CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
35 2 45.70 33.33 58.07 12.37 (0,100)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.

NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
TREATMENT: AS
N OBSV MEAN MIN MAX
0 1 87.10 87.10 87.10
0 1 90.00 90.00 90.00
6 3 99.80 99.48 99.99
TREATMENT: TF
N OBSV ; MEAN MIN MAX
-


SE 90% C.I.
-
SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
0.16 (99,100)
SE 90% C.I.
; ;
                                                               C-7

-------
POTU • Percent Removal


PARAMETER: 1,4-DICHLOROBENZENE
                                                                                                       18-Apr-90
   IHFL
  CONG.
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
             .SKSSSSSSSSSSSSBSSSBSSSSSSSSSSSSSSSSSrSISSSSSSSSZ:::


                                      CHLORINATED
            TREATMENT: AL

 N    OBSV   MEAN    MIN    MAX     SE    90% C.I.
            TREATMENT: AS

 N    OBSV   MEAN    MIN    MAX

" 35* "" r*83~33  83.33  83.33
            TREATMENT: TF

      OBSV   MEAN    MIN
                                                    SE   90% C.I.

                                                    0.00    (0,0)
                                             MAX
                                                    SE   90% C.I.
                                                                                       NON-CHLORINATED


                                                                                       TREATMENT: AL
                                                            N    OBSV   MEAN    MIN    MAX    SE   90% C.I.


                                                             11       2  83.33  67.67 100.00  16.67  (0,100)
          TREATMENT: AS

    OBSV   MEAN    MIN    MAX
                                                                            N
                                                                                                               SE    90% C.I.
36      5  86.52  70.59 100.00   5.02   (76.97)
11      1  94.62  94.62  94.62   0.00     (6,0)
 0      1  90.00  90.00  90.00   0.00     (00)
                                                                                       TREATMENT: TF

                                                                            N    OBSV   MEAN    MIN    MAX     SE    90% C.I.
                                                                             11
        1  37.63  37.63  37.63   0.00
                                                                                                      (0,0)
            ssssas:ssssss:i::ss==:3sr:ssi::====:3==s=:==:s===:==::=====:=s:==:=s=====
PARAMETER; 2,4-DICHLQROPHENOL
INFL
COHC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000


CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN
MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN
35 1 50.00 50.00
TREATMENT: TF
N OBSV MEAN MIN
MAX SE 90% C.I.
50.00 0.00 (0,0)
MAX SE 90% C.I.
-
NON- CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
11 1 32.02 32.02 32.02
TREATMENT: AS
N OBSV MEAN MIN MAX
.2 1 100.00 100.00 100.00
16 3 95.88 93.08 99.54
6 2 86.19 77.18 95.20
TREATMENT: TF
N OBSV MEAN MIN MAX
11 1 12.28 12.28 12.28


SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)
1.92 (90,100)
9.01 (29,100)
SE 90% C.I.
0.00 (0,0)
                                                                C-8

-------
POTW - Percent Removal




PARAMETER: 2,4-DIMETHYLPHENOL
18-Apr-90
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT : AL
N OBSV MEAN MIN
MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN
35 1 0.00 0.00
TREATMENT: TF
N OBSV MEAN MIN
.
MAX SE 90% C.I.
0.00 0.00 (0,0)
MAX SE 90% C.I.
.
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX

SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
3 1 100.00 100.00 100.00
8 1 99.06 99.06 99.06
5 2 96.57 95.00 98.15
TREATMENT: TF
N OBSV MEAN MIN MAX

SE 90% C.I.
0.00 (0,0)
0.00 (0.0) '
1.57 (87,160)
SE 90% C.I.
-
PARAMETER:  2,4-DINITROPHENOL
™=

CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
-
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
TREATMENT: AS
N OBSV MEAN MIN MAX
0 1 90.00 90.00 90.00
5 1 91.23 91.23 91.23
6 1 99.31 99.31 99.31
TREATMENT: TF
N OBSV MEAN MIN MAX
__ — ซ•ป
=================

SE 90% C.I.
-
SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
-
                                                             C-9

-------
POTU - Percent Renปval




PARAMETER:  2-CHLORONAPHTHALENE
18-Apr-9(
IHFL
COHC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
PARAMETER: Z
IHFL
COHC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED


TREATMENT: AL
N OBSV MEAN MIN MAX
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
SE 90% C.I.
TREATMENT: TF
N OBSV MEAN MIN MAX
SE 90% C.I.
*••*.ซ* ซ
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
0 1 100.00 100.00 100.00
TREATMENT: AS
N OBSV MEAN MIN MAX
0 1 50.00 50.00 50.00
0 1 95.00 95.00 95.00
0 1 100.00 100.00 100.00
TREATMENT: TF
N OBSV MEAN MIN MAX
0 1 0.00 0.00 0.00


SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
0.00 (O',0)
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)
-CHLOROPHENOL
CHLORINATED
— — — ซ
TREATMENT: AL
N OBSV MEAN MIN MAX
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
35 1 0.00 0.00 0.00
TREATMENT: TF
N OBSV MEAN MIN MAX ,
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
------
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
2 1 100.00 100.00 100.00
5 1 33.96 33.96 33.96
0 1 95.00 95.00 95.00
TREATMENT: TF
N OBSV MEAN MIN MAX
SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
0.00 (OiO)
SE 90% C.I.
-

                                                            C-10

-------
POTW - Percent Removal




PARAMETER:   ACENAPHTHENE
18-Apr-90

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN
MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN
35 2 89.18 88.89
TREATMENT: TF
N OBSV MEAN MIN
MAX SE 90% C.I.
89.47 0.29 (87,91)
MAX SE 90% C.I.

NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
1 1 100.00 100.00 100.00 0.00 (0,0)
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
18 3 99.00 96.99 100.00 1.01 (96,100)
5 1 94.05 94.05 94.05 0.00 (0,0)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
. -
PARAMETER: ACENAPHTHYLENE


CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
35 1 0.00 0.00 0.00 0.00 (0,0)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
.
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
0 1 100.00 100.00 100.00 0.00 (0,0)
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
0 1 50.00 50.00 50.00 0.00 (0,0)
5 1 92.31 92.31 92.31 0.00 (0,0)
0 1 95.00 95.00 95.00 0.00 (0,0)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
-
                                                             C-ll

-------
POTU - Percent  Resnoval




PARAMETER:  ANTHRACENE
18-Apr-90
nmwnuann
IHFL
COHC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
sssasxsssss
PARAMETER: A

CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
H OBSV MEAN MIN MAX SE 90% C.I.
116 14 8.10 0.00 80.00 6.02 (0.19)
6 1 78.85 78.85 78.85 0.00 (6,0)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
42 6 6.76 0.00 40.54 6.76 (0,20)
HTIMOW

IHFL
COHC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
35 3 41.23 0.00 73.68 21.72 (0,100)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
..*_.• -
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE
6 1 0.00 0.00 0.00 0.00
TREATMENT: AS
N OBSV MEAN MIN MAX SE
62 11 17.95 0.00 100.00 12.04
0 1 95.00 95.00 95.00 0.00
TREATMENT: TF
N OBSV MEAN MIN MAX SE
6 1 0.00 0.00 0.00 0.00

NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE
90% C.I.
(0,0)
90% C.I.
(0,49)
(0,0)
90% C.I.
(0,0)


90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE
0 2 17.11 0.00 34.21 17.11
0 1 0.00 0.00 0.00 0.00
TREATMENT: TF
N OBSV MEAN MIN MAX SE
90% C.I.
(0,100)
(0,0)
90% C.I.

                                                               C-12

-------
POTW - Percent Removal
PARAMETER: ARSENIC
                                        18-Apr-90
3==S===S3===
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
PARAMETER: B
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
=s=x=ssss===
3=s======sa==S3==s5=s=s=sss==:==ssa=s=s
CHLORINATED
===================
TREATMENT: AL
N OBSV MEAN MIN MAX
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
149 19 39.40 0.00 90.63
0 1 50.00 50.00 50.00
TREATMENT: TF
N OBSV MEAN MIN MAX
6 1 25.00 25.00 25.00
=r:=sss===ss:=sr:sss:s=ssr:s=====r:5:ssi;=s=s=
ARIUM
CHLORINATED
SE 90% C.I.
7.53 (26.53)
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)
=sss:=ss=sssss;sr:=ss5
TREATMENT: AL
N OBSV MEAN MIN MAX
6 1 75.90 75.90 75.90
TREATMENT: AS
N OBSV MEAN MIN MAX
6 1 72.09 72.09 72.09
37 5 70.43 64.15 75.64
170 18 72.75 43.72 99.17
4 1 65.68 65.68 65.68
TREATMENT: TF
N OBSV MEAN MIN MAX
18 3 58.56 38.89 87.37
30 4 50.21 21.28 70.23
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)
2.24 (66,75)
3.79 (66.79)
0.00 (6,0)
SE 90% C.I.
14.72 (16,100)
11.91 (22,78)
s=ssa=s=s=ss=ss=as:
                                                                    ====================================
                                                                                      NON-CHLORINATED
           TREATMENT: AL
N    OBSV   MEAN    MIN    MAX
                                                                                                             SE   90% C.I.
                                                                                    '  TREATMENT:  AS
                                                                                OBSV   MEAN    MIN    MAX
                                                                                                             SE    90% C.I.
                                                                            45      3  33.85  18.93  63.33  14.74   (0,77)
                                                                             0      1  50.00  50.00  50.00   0.00    (0,0)
                                                                                      TREATMENT:  TF
                                                                           N    OBSV   MEAN     MIN     MAX     SE    90% C.I.
                                                                             6      1   10.00  10.00   10.00   0.00    (0,0)

                                                                                      NON-CHLORINATED

                                                                                      TREATMENT:  AL
                                                                           N    OBSV   MEAN     MIN     MAX     SE    90% C.I.
                                                                             6      1   56.60  56.60  56.60   0.00    (0,0)
           TREATMENT:  AS
     OBSV   MEAN    MIN    MAX
                                                                                                             SE    90% C.I.
                                                                            12      2  75.82  72.62  79.01    3.20  (56,96)
                                                                            52     10  76.14  62.31  94.21    4.04  (69,84)
                                                                                      TREATMENT:  TF
                                                                           N    OBSV   MEAN    MIN    MAX    SE   90% C.I.
                                                                            1
         2  55.65  53.55  57.75   2.10  (42,69)
                                                              C-13

-------
POIW - Percent Removal




PARAMETER: BENZENE
18-Apr-90
INFL
CONG.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
ssatassxascsEs
PARAMETER: B
asES=sssซss
INFL
COHC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
6 1 98.91 98.91 98.91
TREATMENT: AS
H OBSV MEAN MIN MAX
124 13 53.68 0.00 85.71
18 3 96.72 91.09 99.55
TREATMENT: TF
N OBSV MEAN MIN MAX
30 4 56.74 0.00 96.97
ISC2-CHLOROETHOXY) METHANE

CHLORINATED
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
9.02 (38,70)
2.81 (89,100)
SE 90% C.I.
21.26 (7,100)
NON-CHLORINATED

TREATMENT: AL
N OBSV MEAN MIN MAX
2 2 100.00 100.00 100.00
0 1 100.00 100.00 100.00
TREATMENT: AS
N OBSV MEAN MIN MAX
56 12 74.04 48.53 98.25
20 1 99.73 99.73 99.73
13 4 98.41 95.00 99.83
5 1 98.97 98.97 98.97
15 3 99.95 99.87 100.00
TREATMENT: TF
N OBSV MEAN MIN MAX
6 1 91.67 91.67 91.67


TREATMENT: AL
H OBSV MEAN MIN MAX
SE 90% C.I.
TREATMENT: AS
N OSSV MEAN MIN MAX
35 1 66.67 66.67 66.67
TREATMENT: TF
N OBSV MEAN MIN MAX
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
...ป.- -
NON-CHLORINATED
SE 90% C.I.
0.00 (100.100)
o.oo (6,0)
SE 90% C.I.
5.58 (64,84)
0.00 (6.0)
1.14 (96,160)
0.00 (0,0)
0.04 (99,100)
SE 90% C.I.
0.00 (0,0)


TREATMENT: AL
N OBSV MEAN MIN MAX
0 1 100.00 100.00 100.00
TREATMENT: AS
N OBSV MEAN MIN MAX
0 1 66.67 66.67 66.67
0 1 10.00 10.00 10.00
TREATMENT: TF
N OBSV MEAN MIN MAX
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
------ *
                                                         C-H

-------
     - Percent Removal





PARAMETER: BIS(2-CHLOROETHYL) ETHER
t8-Apr-90
ss333ssasa=s
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000

CHLORINATED


TREATMENT: AL
N OBSV MEAN MIN MAX
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
0 1 0.00 0.00 0.00
TREATMENT: TF
N OBSV MEAN HIN MAX
• V • — V
PARAMETER: BIS(2-ETHYLHEXYL> PHTHALATE
s=ss==sss===
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
====================================
CHLORINATED
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
-
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
11 1 28.67 28.67 28.67
TREATMENT: AS
N OBSV MEAN MIN MAX
0 3 66.67 0.00 100.00
11 2 84.51 79.02 90.00
TREATMENT: TF
N OBSV MEAN MIN MAX
11 1 7.69 7.69 7.69


TREATMENT: AL
N OBSV MEAN MIN MAX
6 1 40,65 40.65 40.'65
TREATMENT: AS
N OBSV MEAN MIN MAX
157 17 39.80 0.00 87.50
36 6 61.57 0.00 89.54
18 4 76.24 55.63 98.76
TREATMENT: TF
N OBSV MEAN MIN MAX
36 5 32.94 14.29 64.52
6 2 6.06 0.00 12.12
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
7.91 (26,54)
14.37 (33,91)
9.93 (53,100)
SE 90% C.I.
8.50 (15,51)
6.06 (0,44)
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
5 1 100.00 100.00 100.00
6 1 23.47 23.47 23.47
11 1 79.76 79.76 79.76
TREATMENT: AS
N OBSV MEAN MIN MAX
41 10 43.93 0.00 78.00
26 4 48.41 10.11 78.14
61 6 82.25 58.53 100.00
TREATMENT: TF
N OBSV MEAN MIN MAX
12 3 65.66 33.33 100.00
11 1 76.79 76.79 76.79
:srs======s;s===========s==s:2:===========


SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
33.33 (0,100)
5.49 (50,100)
SE 90% C.I.
0.00 (0,0)


SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
9.40 (27,61)
16.56 (9 87)
6.19 (70,95)
SE 90% C.I.
19.27 (10,100)
0.00 (0,0)
                                                           C-15

-------
POTU - Percent Removal




PARAMETER:  BROHOOICHLOROMETHANE
18-Apr-90
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
PARAMETER: B

CHLORINATED


TREATMENT: AL
N OBSV MEAN HIN MAX
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
18 4 30.83 0.00 50.00
TREATMENT: TF
N OBSV MEAN MIN MAX
-
UTYL BENZYL PHTHALATE

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
SE 90% C.I.
10.83 (5,56)
SE 90% C.I.
w —
NON-CHLORINATED
=================
TREATMENT: AL
N OBSV MEAN MIN MAX
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
5 2 87.50 75.00 100.00
20 1 99.78 99.78 99.78
TREATMENT: TF
N OBSV MEAN MIN MAX
" - ซ. - - -


TREATMENT: AL
N OSSV MEAN HIN MAX
6 1 0.00 0.00 0.00
TREATMENT: AS
N OSSV MEAN MIN MAX
146 20 24.60 0.00 92.00
6 1 96.67 96.67 96.67
6 2 99.56 99.43 99.68
TREATMENT: TF
N OBSV MEAN MIN MAX
48 7 32.06 0.00 97.30
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
7.16 (12.37)
0.00 (0.0)
0.13 (99,100)
SE 90% C.I.
15.76 (1,63)
NON- CHLORINATED
SE 90% C.I.
12.50 (9,100)
0.00 (0,0)
SE 90% C.I.
-


TREATMENT: AL
N OBSV MEAN MIN MAX
6 2 96.43 92.86 100.00
TREATMENT: AS
N OBSV MEAN MIN MAX
74 15 47.90 0.00 100.00
5 1 93.02 93.02 93.02
0 1 95.00 95.00 95.00
TREATMENT: TF
N . OBSV MEAN MIN MAX
12 2 31.25 0.00 62.50
SE 90% C.I.
3.57 (74,100)
SE 90% C.I.
10.72 (29.67)
0.00 (6,0)
0.00 (0,0)
SE 90% C.I.
31.25 (0,100)
                                                         C-16

-------
POTW -  Percent Removal




PARAMETER:  CADMIUM
1S-Apr-90
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
sssssisssssssssts:
PARAMETER: C
SpSSSaaaSSSBSSS
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
* > 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000

CHLORINATED


TREATMENT: AL
N OBSV MEAN MIN MAX
6 1 0.00 0.00 0.00
TREATMENT: AS
N OBSV MEAN MIN MAX
265 35 39.47 0.00 99.47
12 2 43.14 0.00 86.28
6 1 91.38 91.38 91.38
6 1 90.06 90.06 90.06
6 1 93.96 93.96 93.96
TREATMENT: TF
N OBSV MEAN MIN MAX
48 7 6.35 0.00 33.33
HLOROBENZENE

SE 90% C.i.
0.00 (0,0)
SE 90% C.I.
6.24 (29.50)
43.14 (0,100)
0.00 (0,0)
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
4.76 (0,16)
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
6 1 44.00 44.00 44.00
TREATMENT: AS
N OBSV MEAN MIN MAX
119 15 30.60 0.00 97.06
6 1 97.02 97.02 97.02
0 1 27.00 27.00 27.00
TREATMENT: TF
N OBSV MEAN MIN MAX
20 2 14.00 0.00 28.00
6 1 76.12 76.12 76.12

CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
6 1 100.00 100.00 100.00
TREATMENT: AS
N OBSV MEAN MIN MAX
41 2 40.00 0.00 80.00
6 2 99.32 98.91 99.72
TREATMENT: TF
N OBSV MEAN MIN MAX
6 2 37.50 0.00 75.00
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
40.00 (0,100)
0.40 (97,100)
SE 90% C.I.
37.50 (0,100)
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX


SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
9.47 (14.47)
0.00 (6,0)
0.00 (0,0)
SE 90% C.I.
14.00 (0,100)
0.00 (0,0)


SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
17 3 62.22 20.00 100.00
20 4 97.10 90.00 99.89
TREATMENT: TF
N OBSV MEAN MIN MAX
SE 90% C.I.
23.20 (0,100)
2.37 (92,100)
SE 90% C.I.
....•• -
                                                             C-17

-------
POTW - Percent Removal




PARAMETER:  CHLOROETHANE
18-Apr-90

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED


TREATMENT: AL
N OBSV MEAN MIN MAX
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
SE 90% C.I.
TREATMENT: TF
N OBSV MEAN MIN MAX
ป nป •• ซ• —
PARAMETER: CHLOROFORM
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
XXXXXKXXXXX
CHLORINATED
SE 90% C.I.

TREATMENT: AL
N OBSV MEAN MIN MAX
6 1 97.79 97.79 97.79
TREATMENT: AS
N OBSV MEAN MIN MAX
152 23 40.27 0.00 96.49
41 2 60.44 52.06 68.83
6 1 50.00 50.00 50.00
TREATMENT: TF
N OBSV MEAN MIN MAX
42 6 37.64 0.00 87.50
6 1 85.92 85.92 85.92
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
6.78 (29.52)
8.39 (7,100)
0.00 (0,0)
SE 90XC.I.
15.59 (6.69)
0.00 (6,0)
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
--------------_
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
5 1 58.33 58.33 58.33
0 1 95.00 95.00 95.00
TREATMENT: TF
N OBSV MEAN MIN MAX
.
SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
-
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
6 1 0.00 0.00 0.00
14 1 60.74 60.74 60.74
3 1 100.00 100.00 100.00
TREATMENT: AS
N OBSV MEAN MIN MAX
166 28 59.22 0.00 100.00
39 4 92.58 86.67 97.37
0 1 99.25 99.25 99.25
TREATMENT: TF
N OBSV MEAN MIN MAX
12 3 87.83 77.78 100.00
14 1 24.44 24.44 24.44
SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
0.00 (0|0)
SE 90% C.I.
5.56 (50,69)
2.55 (87,99)
0.00 (0,0)
SE 90% C.I.
6.50 (69,100)
0.00 (0,0)
                                                          C-18

-------
POTU - Percent Removal




PARAMETER:  CHLOROMETHANE
18-Apr-90


TMPI
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000
PARAMETER:



CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000



N
6
N
47
18
N
6
CHROMIUM



N
6
N
58
53
160
6
18
N
36
12

CHLORINATED
TREATMENT: AL
OBSV MEAN MIN MAX
1 58.33 58.33 58.33
TREATMENT: AS
OBSV MEAN MIN MAX
2 0.00 0.00 0.00
3 81.65 67.29 97.98
TREATMENT: TF
OBSV MEAN MIN MAX
1 0.00 0.00 0.00


CHLORINATED
TREATMENT: AL
OBSV MEAN MIN MAX
1 89.78 89.78 89.78
TREATMENT: AS
OBSV MEAN MIN MAX
8 45.67 0.00 83.72
9 68.55 18.99 94.55
19 75.05 21.43 93.44
1 93.36 93.36 93.36
3 94.24 89.73 97.46
TREATMENT: TF
OBSV MEAN MIN MAX
5 36.41 0.00 58.33
2 46.49 22.59 70.40



SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)
8.92 (56,100)
SE 90% C.I.
0.00 (0,0)




SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
13.66 (20,72)
7.61 (54J83)
4.20 (68.82)
0.00 (6.0)
2.32 (87,100)
S^ 90% C.I.
10.12 (15,58)
23.90 (0,100)

NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
0 1 100.00 100.00 10.00
TREATMENT: AS
N OBSV MEAN MIN MAX
6 1 0.00 0.00 0.00
0 1 95.00 95.00 95.00
TREATMENT: TF
N OBSV MEAN MIN MAX
6 1 60.32 60.32 60.32


NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
6 1 48.78 48.78 48.78
14 1 70.59 70.59 70.59
TREATMENT: AS
N OBSV MEAN MIN MAX
12 2 85.39 73.33 97.44
18 4 78.29 68.75 94.55
50 10 81.29 70.00 89.49
45 1 46.03 46.03 46.03
TREATMENT: TF
N OBSV MEAN MIN MAX
6 1 67.39 67.39 67.39
20 2 54.20 51.58 56.18



SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)




SE 90% C.I,
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
12.05 (9,100)
5.79 (65,92)
1.90 (78.85)
0.00 (6,0)
SE 90% C.I.
0.00 (0,0)
2.62 (38,71)
                                                           C-19

-------
POTW - Percent Removal


PARAMETER:  COPPER
                                    18-Apr-90


TIIP1
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1061-5000
> 5000


0-50
51-100
101-500
501*1000
1001-5000
> 5000
mumnmnuuu

^*s=*a"*™— ™~
-~ 	 a™

i-33= 	 3333=t_-____ 	 = 	 ===_3========333====
CHLORINATED
TREATMENT: AL
N




OBSV MEAN
.
96.38
.
~
MIN
,
96.38
-
-
MAX
„
96.38
.
-
SE 90X C.I.
— •
0.00 (0,0)
.
~ ™
TREATMENT: AS
N
39
89
137
18
6

OBSV MEAN
7 63.77
10 80.18
18 81.85
3 91.47
1 92.43

MIN
0.00
41.27
50.00
89.91
92.43

MAX
90.00
99.00
95.51
93.82
92.43

SE 90% C.I.
11.82 (41,87)
6.26 (69,92)
2.95 (77,87)
1.20 (88,95)
0.00 (0,0)

TREATMENT: TF
N
6
12
24

.
-

OBSV MEAN
1 0.00
2 53.89
4 58.41

-
- -
333SSS8S3JZ3S33S
MIN
0.00
49.15
38.18

.
-
=333=33
MAX
0.00
58.62
74.79

-
-
	 -33—
SE 90% C.I.
0.00 (0.0)
4.73 (24,84)
9.56 (36,81)
* -
.
~ "

==9333=
=3====
53333B3333
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN . MIN
™ *> ซ B
6 1 20.97 20.97
14 1 74.20 74.20
....
....
TREATMENT: AS
N OBSV MEAN MIN
6 2 45.24 0.00
12 3 79.93 56.10
62 10 80.07 0.00
45 1 80.00 80.00

" ' " ~
TREATMENT: TF
N OBSV MEAN MIN
-
....
....
....

MAX

20.97
74.20
.
-

MAX
90.48
99.00
96.97
80.00

-

MAX
-
.
.
•
SE

0.00
0.00
_
-

SE
45.24
12.61
9.18
0.00

-

SE
-
_
-
-
	
90% C.I.

(0,0)
(0|0)
_
-

90% C.I.
(0,100)
(43'100)
(6i.97)
(6,0)

-

90% C.I.
-
.
.
-

PARAMETER: CYANIDE


f it ri
INrU
CONC.
0-SO
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1006
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000
XKZXXXXXXXS:
CHLORINATED
TREATMENT: AL

H
ป
.
.
.
6


ossv
.
ซ.
m
-
1
~

MEAN
ป
~
.
-
89.78


MIN
m
m
.
-
89.78
••

MAX
.
.
ป
-
89.78
•

SE




0.



*
-
*
-
00
*•

90% C.I.
.
.
.
.
(0,0)

TREATMENT: AS
H
50
83
42
12
18
~
OBSV
6
8
8
2
"*
MEAN
55.68
18.99
59.78
69.04
86.72
~
MIN
0.00
0.00
28.76
57.91
71.13
"
MAX
85.71
67.07
91.87
80.17
97.58
"
SE
11.
9.
7.
11.
7.

87
65
99
13
99
"
90% C.I.
(32,80)
(&T5)
(0,100)
(63,100)
"
TREATMENT: TF
H
_
6
36
6

-
SS33SS33:
OBSV
_
1
1

-
MEAN
ซ.
36.15
39.29
56.80

-
MIN
_
36.15
0.00
56.80

-
MAX
.
36.15
73.14
56.80

-
SE

0.
16.
0.


_
00
19
00
-
-
:SS333==3==3==33S333==S33===3=====:
90% C.I.
•
(0,0)
(5.74)
(6,0)

"
:=========
                                                                                          SSSSS35SSSSSSSSCSSS—SKISiSISSSSWiSSSSSSSSSJSSB"*"™ 2S 2SSSKS!


                                                                                         NON-CHLORINATED
      TREATMENT: AL

OBSV   MEAN    MIN    MAX
                                                                                                                SE   90%C.I.
                                                                                       1    7.35   7.35   7.35   0.00     (0,0)
                                                                                         TREATMENT: AS

                                                                                   OBSV   MEAN    MIN
                                                                                                         MAX
                              SE   90% C.I.
                                                                               12

                                                                               30
                                                                               6
                                                                               18
    4  47.57   0.00  75.00   17.45   (7,89)
7  58.29
1  65.41
3  85.49
              33,14
              65.41
              79.92
90.00
65.41
89.49
7.97  (43.74)
0.00    (6,0)
2.87  (77,94)
                                                                                         TREATMENT: TF

                                                                                  OBSV   MEAN    MIN
                      MAX
                              SE   90% C.I.
                                                                               12
    2  42.16  26.64  57.68  15.52  (0,100)
                                                                                                       =======================
                                                          C-20

-------
POTU - Percent Removal




PARAMETER:  OI-N-OCTYL PHTHALATE
18-Apr-90
sssssasasssa
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN
MAX
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN
35 1 0.00 0.00
TREATMENT: TF
N OBSV MEAN MIN
MAX
0.00
MAX
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
-
PARAMETER: DIBROMOCHLOROMETANE

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000

NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
13 2 82.56 82.14 82.98 0.42 (80,85)
0 1 100.00 100.00 100.00 0.00 (0,0)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
.._.__ .

CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN
MAX
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN
MAX
SE 90% C.I.
TREATMENT: TF
N OBSV MEAN MIN
MAX
SE 90% C.I.
.
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
5 1 0.00 0.00 0.00 0.00 (0,0)
20 1 87.93 87.93 87.93 0.00 (0,0)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
-
                                                            C-21

-------
POTW - Percent Removal




PARAMETER: DIETHYL PHTHALATE
18-Apr-90
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
PARAMETER: E
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
H OBSV MEAN MIN MAX SE 90% C.I.
187 23 54.03 0.00 100.00 8.05 (40,68)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
30 4 33.75 0.00 60.00 13.44 (2,65)
THYLBENZENE

NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
6 2 50.00 0.00 100.00
TREATMENT: AS
N OBSV MEAN MIN MAX
85 14 28.68 0.00 100.00
5 2 91.64 90.00 93.28
TREATMENT: TF
N OBSV MEAN MIN MAX
12 2 30.77 0.00 61.54
0 1 100.00 100.00 100.00

SE 90% C.I.
50.00 (0,100)
SE 90% C.I.
11.57 (8,49)
1.64 (81,100)
SE 90% C.I.
30.77 (0,100)
0.00 (0,0)

IHFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN
6 1 61.54 61.54
TREATMENT: AS
N OBSV MEAN MIN
199 24 41.53 0.00
12 3 98.73 97.45
TREATMENT: TF
N OBSV MEAN MIN
48 7 33.03 0.00
MAX
61.54
MAX
97.73
98.73
MAX
90.00
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
8.98 (26,57)
0.64 (97,100)
SE 90% C.I.
13.06 (8,58)

N
9
14
N
95
26
19
24
0
N
12
14
NON-CHLORINATED
TREATMENT: AL
OBSV MEAN MIN MAX
2 91.67 83.33 100.00
1 75.68 75.68 75.68
TREATMENT: AS
OBSV MEAN MIN MAX
17 62.10 0.00 99.22
3 96.66 90.72 99.76
4 96.91 94.60 99.80
1 100.00 100.00 100.00
1 99.95 99.95 99.95
TREATMENT: TF
OBSV MEAN MIN MAX
6 25.00 0.00 50.00
1 72.07 72.07 72.07

SE 90% C.I.
8.33 (39,100)
0.00 (0,0)
SE 90% C.I.
9.57 (45.79)
2.97 (88,100)
1.26 (94)100)
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
25.00 (0,100)
0.00 (0,0)
                                                        C-22

-------
POTW - Percent Removal


PARAMETER: FLUORANTHENE
                                                                                                 18-Apr-90


CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90XC.I.
:::::: :
...... .
......
...... .
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
35 2 41.67 0.00 83.33 41.67 (0,100)
...... -
......
......
......
......
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
......
......
......
......
......

NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
0 1 100.00 100.00 100.00
11 1 65.39 65.39 65.39
.....
.....
TREATMENT: AS
N OBSV MEAN MIN MAX
13 4 85.46 64.71 100.00
.....
11 1 95.19 95.19 95.19

.....
.....
TREATMENT: TF
N OBSV MEAN MIN MAX
.....
.....
11 1 52.89 52.89 52.89
.....
.....



SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
. .
-

SE 90% C.I.
7.73 (67,100)
. _
0.00 (0,0)

.
-

SE 90% C.I.
„
.
0.00 (0,0)

-

PARAMETER: FLUORENE
   INFL
  CONC.
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
                                     CHLORINATED
           TREATMENT: AL

     OBSV   MEAN    MIN
                                            MAX
       SE   90% C.I.
           TREATMENT: AS

N    OBSV   MEAN    MIN

 35      1   0.00   0.00
                            TREATMENT: TF

                      OBSV   MEAN    MIN
MAX

0.00
SE   90% C.I.

0.00    (0,0)
                           MAX
                                  SE   90% C.I.
                                   NON-CHLORINATED


                                   TREATMENT: AL

                             OBSV  MEAN    MIN    MAX
SE   90% C.I.
                                                                                      TREATMENT:  AS

                                                                                OBSV   MEAN    MIN
                                                         MAX
SE   90% C.I.
10      3  97.42  94.12 100.00
 5      1  91.07  91.07 91.07
                                                                                      TREATMENT:  TF
1.74 (92,100)
0.00    (0,0)
N

OBSV

MEAN

MIN

MAX

SE

90% C.I.

                                                          C-23

-------
POIU - Percent Removal


PARAMETER: HEPTACHLOR
                                                                                                                  18-Apr-90
   IHFL
  CONC.
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
   „ 0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
     0-50
   51-100
  101-500

1001-5000
   > 5000
                                     CHLORINATED
                           TREATMENT: AL

                     OBSV   MEAN    MIN    MAX
                                                   SE   90% C.I.
                            TREATMENT: AS

                      OBSV  MEAN    MIN
                                            MAX
                                                  SE   90% C.I.
                            TREATMENT: TF

                 N    OBSV   MEAN    HIN
                                           MAX
                                                  SE   90% C.I.
                                                                                     NON-CHLORINATED


                                                                                     TREATMENT: AL
                                                                          N    OBSV   MEAN    MIN    MAX    SE   90% C.I.

                                                                            3      1  66.67  66.67  66.67~"o*00    (0~0)"
                                                                    TREATMENT: AS

                                                         N    OBSV   MEAN    MIN    MAX    SE   90% C.I.

                                                          11      2  79.71   6.67~ 92.74 ~13~04~~<0~100)"
                                                                    TREATMENT: TF

                                                         N    OBSV   MEAN    MIN    MAX    SE   90% C.I.

                                                           3      1  53.85  53.85"53.85  ~o"oo""(oio)"
POTU • Percent Removal


PARAMETER: IRON
   IHFL
  COHC.
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
                                     CHLORINATED
                           TREATMENT: AL

                    *08SV   MEAN    MIH    MAX
                                  SE   90% C.I.
                         1  85.46  85.46  85.46   0.00    (0,0)
                           TREATMENT:  AS

                "il"   08SV"~HEAN~" HIN    MAX
                                                  SE   90X C.I.
  6      1  81.18  81.18  81.18  .0.00    (0.0)
120     15  80.66  42.58  98.00   3.37  (75,87)
 85      9  88.41  66.78  99.20   4.11  (81,96)
                            TREATMENT: TF

                     "oasv   JON    MIN ""MAX
                                                   SE    90% C.I.
 24      3  74.52  55.23  90.71  10.36 (44.100)
 18      3  32.65   3.74  69.97  19.58   (6.90)
  6      1  50.61  50.61  50.61   0.00    (6,0)
                                                                                     NON-CHLORINATED
           TREATMENT:  AL

N    OBSV   MEAN     MIN    MAX    SE   90% C.I.
                                                           6      1  25.98  25.98  25.98   0.00    (0,0)



                                                                    TREATMENT: AS

                                                         N    OBSV   MEAN    MIN    MAX    SE   90% C.I.
                                                                           111     12  85.41  67.00  96.65   3.27  (80,91)
                                                                    TREATMENT: TF

                                                          N    OBSV   MEAN    MIN    MAX    SE   90% C.I.
                                                                            12     6  72.30  68.87  75.72   3.42  (65,79)
                                                              C-24

-------
POTW - Percent Removal




PARAMETER:  ISOPHORONE
18-Apr-90

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000

CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN
MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN
MAX SE 90% C.I.
TREATMENT: TF
N OBSV MEAN MIN
.
MAX SE 90% C.I.
-

N
0
11
N
2
11
5
N
11

NON-CHLORINATED
TREATMENT: AL
OBSV MEAN MIN MAX
1 100.00 100.00 100.00
1 23.60 23.60 23.60
TREATMENT: AS
OBSV MEAN MIN MAX
1 100.00 100.00 100.00
1 97.75 97.75 97.75
1 100.00 100.00 100.00
TREATMENT: TF
OBSV MEAN MIN MAX
1 19.10 19.10 19.10


SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)
PARAMETER:  LEAD

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000

CHLORINATED
TREATMENT: AL
N
.
-
_
6
.
"
OBSV MEAN
_
.
.
1 7.83
. *
• •
MIN
•
*
*
7.83
.
-
MAX
..
'
-
7.83

-
SE



0.0


90% C.I.
ป
-
-
(0,0)

-
TREATMENT: AS
N •
148
56
65
6
6
"
OBSV MEAN
15 45.95
9 77.21
12 73.91
1 79.93
1 97.22
" ™
MIN
0.00
1.96
51.22
79.93
97.22
™
MAX
97.96
98.68
98.18
79.93
97.22
"
SE
10.88
10.59
4.86
0.00
0.00
"
90% C.I.
(27,65)
(58 97)
(65183)
(6,0)
(00)

TREATMENT: TF
N
42

6

.
-

OBSV MEAN
6 9.03

1 19.62

.
-

MIN
0.00

19.62

.
'-

MAX
54.17

19.62

.
-

SE
9.03
-
0.00
-
-
-

90% C.I.
(0,27)

(0,0)

•
-

N

6
•
14
-
-

N
18
24
38
45

™

N
6
6
14
-
-
-



OBSV
.
1
*
1
* .
-

OBSV
0
5
7
-
—

OBSV
1
1
1
-
-
-

NON -CHLORINATED
TREATMENT: AL
MEAN MIN
ป
0.00 0.00
. *
57.58 57.58
•
-
TREATMENT: AS
MEAN MIN
0.00 0.00
48.17 9.09
56.59 25.20
87.50 87.50

~ ™
TREATMENT: TF
MEAN MIN
0.00 0.00
45.06 45.06
47.88 47.88

.
-



MAX
_
0.00
-
57.58
-
-

MAX
0.00
86.46
83.09
87.50

**

MAX
0.00
45.06
47.88
_
.
-


SE 90% C.I.
_ ป
0.00 (0,0)

0.00 (0,0)

-

SE 90% C.I.
0.00 (0,0)
13.20 (20,76)
8.56 (40.73)
0.00 (6,0)

"* ™

SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
0.00 (0,0)
-
.
-

                                                              C-25

-------
POTW - percent Removal


PARAMETER: LINOANE
                                                                                                 18-Apr-90
   1HFL
  COHC.
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
     0-50
   51-100
  101-500
 501-1000
1001-5000
   > 5000
                                     CHLORINATED
           TREATMENT: AL

     06SV   MEAN    MIN
MAX
SE   90% C.I.
           TREATMENT: AS

H    OBSV   MEAN    MIN

  0 ...... 2"37"50~"6Io6
                            TREATMENT:  TF

                      OBSV   MEAN    MIN
                                            MAX
                                                   SE   90% C.I.
                           MAX.   SE    90% C.I.
                                                                                     NON-CHLORINATED


                                                                                     TREATMENT:  AL
                                                         N    OBSV   MEAN    MIN    MAX    SE

                                                           3      1  43.59  43.59  43.59   0.00
                                                                                                   (oo)
                                                                                     TREATMENT: AS
PARAMETER: MANGANESE
N OBSV
11 2
0 1
N OBSV
3 1

MEAN
MIN
31.91 20.51
7.58 7.58
TREATMENT: TF
MEAN
12.82

MIN
12.82

MAX SE
43.30 11.39
7.58 0.00
MAX SE
12.82 0.00

90% C.I.
(0,100)
(0,0)
90% C.I.
(0,0)



IHrL
COHC.
0-50
51-100
101-500
501-1000
™>m

0-50
51-100
101-500
501-1000
1001-5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
H OBSV MEAN MIN MAX
TREATMENT: AS
H OBSV MEAN MIN MAX
21 3 33.33 0.00 50.00
7 1 33.33 33.33 33.33
91 9 32.69 11.77 86.67
TREATMENT: TF
N OBSV MEAN MIN MAX
JSS3SS— — "— ""^S— •"'"SSSSSSBSSSSSSSSSS


SE 90% C.I.
-
SE 90% C.I.
16.67 (0.82)
0.00 (6.0)
7.96 (18,47)
SE 90% C.I.
===================:
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
TREATMENT: AS
N OBSV MEAN MIN MAX
45 1 38.46 38.46 38.46
TREATMENT: TF
N OBSV MEAN MIN MAX



SE 90% C.I.
-
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.

                                                           C-26

-------
POTW - Percent Removal




PARAMETER:  MERCURY
18-Apr-90
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
PARAMETER: M
SSS 8 SSSSBSSa SSSS S3 SSESS ZS S 8 S5Z S S SSS! 3 SS33S 5SSS2 EZ S K SI 3 SSZ'SS
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
6 1 66.67 66.67 66.67 0.00 (0,0)
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
205 27 42.06 0.00 93.75 7.08 (30.54)
6 1 40.01 40.01 40.01 0.00 (6,0)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
48 7 42.82 0.00 75.00 12.15 (19,66)
ETHYLENE CHLORIDE

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
6 1 81.62 81.62 81.62 0.00 (0,0)
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
6 1 0.00 0.00 0.00 0.00 (0,0)
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
111 16 53.18 0.00 100.00 10.17 (35,71)
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90% C.I.
12 2 60.71 50.00 71.43 10.71 (90,100)

NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
6 1 96.15 96.15 96.15 0.00 (0,0)
3 1 100.00 100.00 100.00 0.00 (0,0)
                                                            C-27

-------
POTU - Percent Removal




PARAMETER:  NAPHTHALENE
18-Apr-90
IHFL
CONG.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
PARAMETER: N
• BBBBBBBXBBX
IHFL
CONC.
0-50
51-100
101-500
501-1000
KJ01-5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED

N

OBSV
TREATMENT: AL
MEAN HIN

MAX

SE


90% C.I.
TREATMENT: AS
H
157
12
6
H
18
6
BBBSBBS3
ICKEL

OSSV
17
1
OBSV
3
1
333333:
MEAN HIN
41.12 0.00
89.79 85.46
94.65 94.65
TREATMENT: TF
MEAN MIN
16.67 0.00
60.00 60.00
MAX
96.33
94.12
94.65
MAX
50.00
60.00
CHLORINATED

N
6
H
104
99
80
6
6
N •
24
18
6

OBSV
i
OBSV
16
13
1
OBSV
4
2
TREATMENT: AL
MEAN MIN
75.69 75.69
TREATMENT: AS
MEAN MIN
39.86 0.00
22.45 0.00
50.26 15.00
44.87 0.00
81.22 81.22
TREATMENT: TF
MEAN MIN
15.92 0.00
54.43 23.44
4.27 4.27

MAX
75.69
MAX
94.44
56.99
99.71
76.56
81.22
MAX
56.00
85.42
4.27
SE
10.33
4.33
0.00
SE
16.67
0.00


SE
0.0
SE
8.49
8.24
7.92
23.06
0.00
SE
13.48
30.99
0.00
90% C.I.
(23.59)
<62(0ฐ0)
90% C.I.
(0.65)
(6,0)

90% C.I.
(0,0)
90% C.I.
(25,55)
(6|38)
(36 64)
(0,100)
90% C.I.
(0.48)
(0,100)
(0,0)

N
8
11
N
80
8
11
0
N
6
0
11

N
6
14
N
30
18
77
0
N
6
20



OBSV
2
1
OBSV
13
2
1
OBSV
1
1
333 333333 333333333333
NON-CHLORINATED
TREATMENT: AL
MEAN MIN
50.00 0.00
66.67 66.67
TREATMENT: AS
MEAN MIN
31.94 0.00
99.09 99.09
95.65 95.00
99.25 99.25
97.83 97.83
TREATMENT: TF
MEAN MIN
96.30 96.30
100.00 100.00
31.48 31.48

MAX
100.00
66.67
MAX
100.00
99.09
96.30
99.25
97.83
MAX
96.30
100.00
31.48


SE 90% C.I.
50.00 (0,100)
0.00 (0,0)
SE 90% C.I.
11.88 (11.53)
0.00 (6.0)
0.65 (92,160)
0.00 (0,0)
0.00 (OlO)
SE 90% C.I.
0.00 (0,0)
0.00 (00)
0.00 (00)
333a333333333333333333333== ===333 = ==33 ==3=;= =
NON-CHLORINATED

OBSV
1
1
OBSV
5
7
OBSV
1
2
TREATMENT: AL
MEAN MIN
13.64 13.64
35.46 35.46
TREATMENT: AS
MEAN MIN
8.33 0.00
39.37 16.67
35.19 5.80
27.34 0.00
TREATMENT: TF
MEAN MIN
35.48 35.48
32.84 30.50

MAX
13.64
35.46
MAX
41.67
66.67
60.00
54.69
MAX
35.48
35.19

SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
8.33 (0,26)
14.62 (0,82)
6.64 (22 48)
27.34 (0,100)
SE 90% C.I.
0.00 (0.0)
2.34 (18,48)
                                                           C-28

-------
POTU -  Percent Removal




PARAMETER:  NITROBENZENE
18-Apr-90

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000

CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN
MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN
MAX SE 90% C.I.
TREATMENT: TF
N OBSV MEAN MIN
-
PARAMETER: PCB-1254
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000

MAX SE 90% C.I.
- •
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
0 1 100.00 100.00 100.00
TREATMENT: AS
N OBSV MEAN MIN MAX
0 1 0.00 0.00 0.00
0 2 93.89 90.00 97.79
5 1 96.97 96.97 96.97
6 2 65.83 33.87 97.80
TREATMENT: TF
N OBSV MEAN MIN MAX


SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)
3.90 (69,100)
0.00 (0.0)
31.97 (0,160)
SE 90% C.I.
------

CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN
MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN
MAX SE 90% C.I.
TREATMENT: TF
N OBSV MEAN MIN
MAX SE 90% C.I.
.
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
8 1 91.34 91.34 91.34
0 1 92.00 92.00 92.00
TREATMENT: TF
N OBSV MEAN MIN MAX
SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.

                                                           C-29

-------
(O'O) OO'O
'I '3X06 3S
(O'O) OO'O
(O'O) OO'O
(OOl'ฃZ) S6'ฃ6
T3X06 38
(O'O) OO'O
(O'O) OO'O
T3 %06 3S

(O'O) OO'O
(O'O) OO'O
•I'3 %06 38
(O'O) OO'O
(O'O) OO'O
•i '3 %06 as
2ฃ'9V
XVH
*2'86
6TS6
82'/6
XVH
06'/S
OO'OOl
XVW

a
98' Sฃ
Bฃ'E
XVH
OO'OS
XVH
2ฃ'9* 2ฃ'9* I 11
NIH NV3H ASSO N
V2'86 *2'86 I 0
6/*S6 6TS6 I 11
ฃ9'06 S6'ฃ6 Z 8
NIH NV3H ASSO N
O V * 1 IJ3U 1 W3U 1
9* * inSlflAฅ3QJ,
06'/S 06'ZS I U
OO'OOl OO'OOl I 0
NIH NV3H ASSO N
IV :1N3H1V3H1
lllVNia01H3-NON
98'Sฃ 98'Sฃ I 9
8ฃ'2 8ฃ'2 I 11
NIH NV3H ASSO N
H'2ฃ n'2ฃ I U
OO'OS OO'OS I 9
NIH NV3H ASSO N
.
'1-3 X06 3S


XVH

NIH NV3H ASSO N
IV :1N3H1V3H1
aaiVNiaoiH3-NON
3sss:s=B===seEES===j5S5:s:5S5::;=:====3=ssss:=::
-
T3 X06 3S XVH NIH
dl :iN
(O'O) OO'O S8'8Z SB'SZ
U8'0) ฃ6' IZ ฃ9'06 OO'O
'I'3X06 as XVH NIH
NV3H ASBO N
3H1V32U
SS'SZ I 9
9l'Sฃ V 0ป
NV3H ASBO H
-
T3X06 3S XVH NIH
NV3H ASSO N
1W • 1 U3LJ 1 W3)J 1
iv *xnanxฅaaii
aaivNiaoiHO
(09'2) OS'ฃl 68'89 OO'O
'I '3 X06 33 XVH NIH
di UN
(ZS'02> VO'Ol Z9'98 OO'O
'1-3X06 38 XVH NIH
— ซ
3H3aHiNVN3H
I8'0ฃ S 9ฃ
NV3H ASSO N
aHivaai
2S'8ฃ 6 VOl
NV3H ASSO N
SV :JLN3H1V3U1
'1*3 X06 3S XVH NIH
NV3H ASSO N
iv uNanivaai
Q3J.VNIS01H3


OOOS <
OOOS-lOOl
OOOl-lOS
oos-ioi
OOl-lS
os-o
OOOS <
OOOS-lOOl
OOOl-lOS
OOS-IOI
OOl-lS
os-o
OOOS <
OOOS-lOOl
OOOl-lOS
oos-ioi
ooi-is
os-o
•3H03
1JHI
ซBKMปCltX*XK*
d :aai3HV8Vd
OOOS <
OOOS-lOOl
oooi-ios
OOl-lS
os-o
OOOS <
OOOS-lOOl
oooi-ios
oos-ioi
OOl-lS
os-o
OOOS <
OOOS-lOOl
OOOl-lOS
OOS-IOI
OOl-lS
os-o
•3N03
UNI
,
- (UW

-------
POTU - Percent Removal


PARAMETER: PHENOL

T&ICI
INrL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN
6 1 0.00
.
...
...
...
...
MIN
0.00
-
*
•
-
-
MAX
0.00
•
-
-
.
-
SE
0.00
•
.
-
.
"
90X C.I.
(0,0)

-
-
.
-
TREATMENT: AS
N OBSV MEAN
116 14 31.28
18 3 54.82
53 4 93.12
12 2 99.57

*
MIN
0.00
11.11
80.10
99.25

•
MAX
94.44
95.71
99.59
99.89
.
-
SE
11.67
24.46
4.48
0.32
-
-
90X C.I.
(11.52)
(0,100)
(83,100)
(98,100)
-
-
TREATMENT: TF
N OBSV MEAN
6 1 96.08

. .
-
.
"* ™
MIN
96108

-
-
-
'
MAX
96.08

-
-
-
"
SE
0.00
.
.
-
.
"
9055 C.I.
(0,0)

- -
-
-
"























                                                                                      NON-CHLORINATED
                                                                                      TREATMENT:  AL

                                                                                OBSV  MEAN    MIN
                                                                                                     MAX
                                                                                                             SE   90XC.I.
                                                                             9      2  75.00   50.00100.00   25.00   (0,100)

                                                                            11      1  33.33   33.33  33.33    0.00     (0,0)
                                                                                      TREATMENT:  AS
N 0
54
61
BSV
9
7
MEA
19.
94.
N
07
14
M
0
80
IN
.00
.77
MA
80.
100.
X
00
00
s
10
2
E
.11
.69
90%
(0
(89
C.I.
,37)
,99)
                                                                             6      1  99.99   99.99  99.99   0.00    (0,0)


                                                                                     TREATMENT:  TF

                                                                           1     OBSV  MEAN    MIN    MAX    SE   90% C.I.

                                                                             6      2  90.00   80.00  100.00   10.00 (37,100)
                                                                             6      1  98.18   98.18  98.18   0.00    (0.0)
                                                                            11      2  74.60   49.21  100.00   25.40  (0,160)
POTU - Percent Removal


PARAMETER:PYRENE

TIICI
CONC.
.0-50
51-100
101-500
501-1000
1001-5000
> 5000

0-50
51-100
101-500
501-1000
1001-5000
> 5000.

0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX SE 90% C.I.
TREATMENT: TF
N OBSV MEAN MIN MAX SE 90X C.I.
. -
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
0 1 100.00 100.00 100.00
11 1 65.39 65.39 65.39
TREATMENT: AS
N OBSV MEAN MIN MAX
18 3 86.04 64.71 100.00
11 1 95.19 95.19 95.19
TREATMENT: TF
N OBSV MEAN MIN MAX
11 1 53.85 53.85 53.85
================

SE 90X C.I.
0.00 (0,0)
0.00 (0,0)
SE 90X C.I.
10.84 (54,100)
0.00 (0,0)
SE 90XC.I.
0.0 (0,0)
=================
                                                            C-31

-------
POTW • Percent Removal




PARAHETER:SILVER
19-Apr-90
INFL
cone.
0-50
51-100
101-500
501-1000
100i-iJB8
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
ปHHaaair?s*ป!gi
CHLORINATED
TREATMENT: AL
H 06SV MEAN
HIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN
MIN MAX SE 90% C.I.
35 4 72.258 26.04 94.22 15.72 (35,100)
TREATMENT: TF
H OBSV MEAN
MIN MAX SE 90% C.I.
ซSnSS33B-SSS:3SS3SSS33SSSS3rn3^===S:s==S3-;— SSS^s-aSSf^^SSS^^rsS
NON-CHLORINATED
TREATMENT:
AL
N OBSV MEAN MIN MAX
TREATMENT:
AS
N OBSV MEAN MIN MAX
45 4 58.80 26.
0 1 90.00 90.
TREATMENT:
04 94.22
00 90.00
TF
N OBSV MEAN MIN MAX

SE 90% C.I.
-
SE 90XC.I.
16.15 (21,97)
0.00 (0,0)
SE 90% C.I.

PARAHETER:TETRACHLOR06THENE
IHFL
COHC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N
1

_
.
•
~
OBSV
6
-
*
.
-
•
MEAN
80.00
-
-
.
-
~
MIN
80.00
*
-
.
-
"
MAX
80.00
•
.
_
-
~
SE
0.00
•
*
•
.
m
90X C.I.
(0,0)

.
-
-
"
TREATMENT: AS
N
95
198
0
6

OBSV
17
!
1
•
MEAN
47.11
78.63
74.02
99.21
84.63
""
HIN
0.00
32.69
65.20
99.21
84.63
~
MAX
100.00
97.53
79.49
99.21
84.63
™
SE
9.07
9.93
4.46
0.00
0.00
™
90X C.I.
(31,63)
(59,99)
(61*87)
(6,0)
(0)0)
"
TREATMENT: TF
N
30
12
6

-
—
OBSV
4
2
1

-
—
MEAN
48.50
90.59
97.80

-
"
HIN
0.00
87.27
97.80
-
-
"
MAX
81.82
93.90
97.80
-
-
"
SE
17.29
3.32
0.00
-
-
"
90X C.I.
(8.89)
(70,100)
(0,0)
-
-
"

N
6
•
-
m
-
~

N
120
47
6

—

N
12
-
-
-


OBSV
2
•
•
-
-
""

OBSV
21
4
2
-
—

OBSV
2
-
-
-
NON-CHLORINATED
TREATMENT: AL
MEAN MIN MAX
95.65 91.30 100.00
...
•
...
...
...
TREATMENT: AS
MEAN MIN MAX
62.69 0.00 100.00
93.50 90.00 96.68
98.24 97.42 99.05
...
...
TREATMENT: TF
MEAN MIN MAX
90.00 86.67 93.33
...
...
.


SE 90X C.I.
4.53 (68,100)
-
.
-
-
" .

SE 90XC.I.
7.02 (51,75)
1 ;37 (90,97)
0.82 (93,100)
-
"

SE 90XC.I.
3.33 (69,100)
-
-
-

                                                        C-32

-------
PQTU - Percent Removal





PARAMETER rTETRACHLOROMETHANE
19-Apr-90

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
===sa==sss=:
PARAMETER: TO


CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN
MAX
SE 90XC.I.
TREATMENT: AS
N OBSV MEAN MIN
12 1 50.00 50.00
6 1 87.79 87.79
TREATMENT: TF
N OBSV MEAN MIN
. . . >
LUENE

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
MAX
50.00
87.79
MAX
========
SE 90% C.I.
0.00 (0,0)
0.00 (0,0)
SE 90X C.I.
. —

N
14
N
0
26
0
N



OBSV
1
OBSV
1
3
i
OBSV

NON-CHLORINATED
TREATMENT: AL
MEAN MIN MAX
78.26 78.26 78.26
TREATMENT: AS
MEAN MIN MAX
0.00 0.00 0.00
93.61 81.16 100.00
95.00 90.00 100.00
99.90 99.90 99.90
TREATMENT: TF
MEAN MIN MAX
================
SE 90XC.I.
0.00 (0,0)
SE 90XC.I.
0.00 (0.0)
6.23 (75,160)
5.00 (63,100)
0.00 (0,0)
SE 90% C.I.
------

CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN
6 1 97.23 97.23
TREATMENT: AS
N OBSV MEAN MIN
124 17 53.74 'O.OO
12 2 98.24 97.86
57 6 78.88 0.00
12 2 96.16 92.84
6 1 99.81 99.81
TREATMENT: TF
N OBSV MEAN MIN
42 6 61.90 0.00
6 1 97.29 97.29
MAX
97.23
MAX
97.73
98.63
99.11
99.48
99.81
MAX
96.00
97.29
SE 90% C.I.
0.00 (0,0)
SE 90% C.I.
9.51 (37.70)
0.39 (96,100)
15.87 (47,100)
3.32 (75 100)
0.00 (0,0)
SE 90% C.I.
14.50 (33,91)
0.00 (0,0)

N
6
N
112
19
58
6
5
0
N



OBSV
1
OBSV
19
4
6
1
OBSV

NON-CHLORINATED
TREATMENT: AL
MEAN MIN MAX
88.89 88.89 88.89
TREATMENT: AS
MEAN MIN MAX
85.21 0.00 100.00
98.01 96.67 99.00
98.85 95.00 100.00
95.39 95.39 95.39
99.84 99.84 99.84
99.94 99.94 99.94
TREATMENT: TF
MEAN MIN MAX


SE 90% C.I.
(0,0)
SE 90XC.I.
5.65 (75,95)
0.49 (97.99)
0.78 (97,100)
0.00 (0,0)
0.00 (0,0)
0.00 (0)0)
SE 90* C.I.
• _ซ*•ซ ™
                                                           C-33

-------
POTM - Percent Removal




PARAHฃTER:TRANS-1,2-DICHLOROETHANE
19-Apr-90
nnuntuiuutx
IHFL
COHC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
PARAMETERS



CHLORINATED
TREATMENT: AL
N OBSV MEAN
MIN MAX SE 90X C.I.
6 1 0.00 0.00 0.00 0.00 (0,0)
TREATMENT: AS
N OBSV MEAN
MIN MAX SE 90% C.I.
146 20 42.09 0.00 100.00 8.88 (27,57)
TREATMENT: TF
H OBSV MEAN
48 7 47.07
IBROMOMETHANE

INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000

HIN MAX SE 90X C.I.
0.00 97.67 17.99 (12,82)
S3S3S3S33==S:3S=3S=3SS=a:33S==KS3=S=S
CHLORINATED
TREATMENT: AL
N OBSV MEAN
MIN MAX SE 90% C.I.
TREATMENT: AS
N OBSV MEAN
MIN MAX SE 90X C.I.
TREATMENT: TF
N OBSV MEAN
MIN MAX SE 90% C.I.
• B ซ " • ™
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
6 1 87.50 87.50 87.50
TREATMENT: AS
N OBSV MEAN MIN MAX
59 11 49.22 0.00 93.75
0 1 90.00 90.00 90.00
TREATMENT: TF
N OBSV MEAN MIN MAX
6 1 50.00 50.00 50.00
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
14 1 83.33 83.33 83.33
TREATMENT: AS
N OBSV MEAN MIN MAX
0 1 100.00 100.00 100.00
14 1 67.78 67.78 67.78
0 1 65.00 65.00 65.00
0 1 100.00 100.00 100.00
TREATMENT: TF
N OBSV MEAN MIN MAX
14 1 54.44 54.44 54.44
================
SE 90XC.I.
0.00 (0,0)
SE 90XC.I.
12.45 (27,72)
0.00 (0,0)
SE 90X C.I.
0.00 (0,0)
SE 90XC.I.
0.00 (0,0)
SE 90X C.I.
0.00 (0,0)
0.00 (00)
0.00 (0,0)
0.00 (0,0)
SE 90% C.I.
0.00 (0,0)
                                     ===================
                                                               :====_=======================================
                                                              C-34

-------
PQTU - Percent Removal


PARAMETER:TR1CHLOROETHENE
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000


0-50
51-100
101-500
501-1000
1001-5000
> 5000
CHLORINATED
TREATMENT: AL
N
6
-
.
•
.
" "
OBSV
1
.
.
.
.
•
MEAN
75.00
•
•
-
*
~
MIN
75.00
•
•
-
*
~
MAX
75.00
ซ
-
-
.
•
SE
0.






00
•
-
-
-
•
90% C.I.
(0,0)
-
.
.
-
-
TREATMENT: AS
N
157
36
12
6

-
OBSV
17
5
1

"
MEAN
48.24
78.46
89.71
86.80

-
MIN
0.00
51.72
86.86
86.80

-
MAX
97.73
98.21
92.56
86.80

-
SE
10.
7.
2.
0.



22
87
85
00
-
-
90% C.I.
(30,66)
(62J95)
(72.100)
(0,0)

"
TREATMENT: TF
N
24
18
6

.
"
OBSV
3
3
1

.
"
MEAN
94.19
94.19
99.19

.
"
MIN
88.84
88.84
99.19
-
.
"
MAX
98.04
98.04
99.19
.
-

SE
2.
2.
0.



85
85
00
.
.

90% C.I.
(86,100)
(86 100)
(0,0)

-

NON-CHLORINATED
TREATMENT: AL
N 08SV MEAN MIN
6 1 97.30 97.30
. . . - .
....
....
....
....
TREATMENT: AS
N OBSV MEAN MIN
106 18 53.77 0.00
6 1 97.65 97.65
26 3 97.74 95.00
....
- - - -
TREATMENT: TF
N OBSV MEAN MIN
6 2 91.67 83.33
6 1 88.24 88.24
....
....
....

MAX
97.30
.
.
.
.
-

MAX
100.00
97.65
99.61
-
-

MAX
100.00
88.24
-
.
.

SE 90% C.I.
0.00 (0,0)

. _
. —
. _
-

SE 90% C.I.
8.26 (39,68)
0.00 (6.0)
1.40 (94,160)
-
- -

SE 90% C.I.
8.33 (39,100)
0.00 (0,0)

-
-
"
PARAMETER: TRICHLOROFLUOROMETHANE
    INFL
  CONC.
     0-50
   51-100
   101-500
 501-1000
 1001-5000
   > 5000
     0-50
   51-100
   101-500
  501-1000
 1001-5000
   > 5000
     0-50
    51-100
   101-500
  501-1000
 1001-5000
    > 5000
                                     CHLORINATED
      TREATMENT: AL

OBSV   MEAN    NIN
                           MAX
                                  SE   90% C.I.
  41
       TREATMENT:  AS

 OBSV   MEAN    MIN

..... 2"48~65    oT6o
                                            MAX
                                                  SE
                                 90% C.I.

                                   (0, 100)
            TREATMENT:  TF

 N    OBSV  MEAN     MIN

"*6	i""iuio""oI6o~
                      MAX

                     "o'.oo"
                             SE   90% C.I.

                             "6.66 " (6,0)"
                                                                                    NON-CHLORINATED
                                                               TREATMENT: AL

                                                          OBSV   MEAN    MIN
                          MAX
SE   90% C.I.
                                                                                     TREATMENT: AS

                                                                               OBSV   MEAN    MIN    MAX
                                                                                           SE   90% C.I.
                                                                   1  95.00  95.00  95.00   0.00    (0,0)
                                                                   1 100.00 100.00 100.00   0.00    (0,0)
           TREATMENT:  TF

N    OBSV   MEAN    MIN    MAX    SE   90% C.I.

 ~o"~*   i ioo.oo~i6o.oo  ioo.oo"~6.oo    (oi6)~
                                                            C-35

-------
POTU * Percent Removal
                                                                                                               19-Apr-90
PARAHETERtVIHYL CHLORIDE
mJaaaaaaamof
INFL
CONC.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
PARAMETER :ZI
nuBsxroxzx
INFL
CONG.
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
0-50
51-100
101-500
501-1000
1001-5000
> 5000
5 BSSiiS33SSS3HBSgEt S333SS3S333333S3333 a 3 5 S23 3SS3333SSS33EE ซ
CHLORINATED
TREATMENT: AL
H OBSV MEAN MIN
MAX
SE 90XC.I.
TREATMENT: AS
N OBSV MEAN MIN
41 2 0.00 0.00
6 1 71.43 71.43
6 1 94.05 94.05
6 1 92.93 92.93
TREATMENT: TF
N OBSV MEAN MIN
NC
MAX
0.00
71.43
94.05
92.93
MAX
m

CHLORINATED
SE 90X C.I.
0.00 (0,0)
0.00 (0,0)
0.00 (0,0)
0.00 (0,0)
SE 90XC.I.
-

NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
===============
SE 90X C.I.
TREATMENT: AS
N OBSV MEAN MIN MAX
5 1 100.00 100.00 100.00
0 1 95.00 95.00 95.00
TREATMENT: TF
N OBSV MEAN MIN MAX
.


TREATMENT: AL
H OBSV MEAN MIN
6 1 89.98 89.98
TREATMENT: AS
N OBSV MEAN MIN
7 1 97.50 97.50
183 21 68.59 29.73
24 3 82.13 74.15
69 13 83.32 49.05
12 2 71.27 63.64
TREATMENT: TF
N OBSV MEAN MIN
6 1 17.20 17.20
42 6 47.20 30.77
MAX
89.98
MAX
97.50
68.59
88.74
99.25
78.90
MAX
17.20
75.17
SE 90% C.I.
0.00 (0,0)
SE 90X C.I.
0.00 (0,0)
3.41 (63,74)
4.27 (70)95)
4.66 (75,92)
7.63 (23,100)
SE 90% C.I.
0.00 (0.0)
6.27 (34,60)
NON-CHLORINATED
TREATMENT: AL
N OBSV MEAN MIN MAX
6 1 51.10 51.10 51.10
TREATMENT: AS
N OBSV MEAN MIN MAX
48 9 79.90 60.00 90.27
18 3 77.24 82.55 80.45
45 3 74.10 62.90 90.63
TREATMENT: TF
N OBSV MEAN MIN MAX
12 2 69.25 65.49 73.0
SE 90XC.I.
0.00 (0,0)
0.00 (0,0)
SE 90X C.I.
" ™


SE 90XC.I.
0.00 (0,0)
SE 90X C.I.
3.42 (74,86)
1.63 (7282)
8.26 (51,99)
SE 90XC.I.
3.76 (46,93)
                                                           C-36

-------
                                APPENDIX D
                                  REFERENCES
Anthony, Richard M. and Breimhurst, Lawrence H.,  "Determining Maximum Influent
     Concentrations of Priority Pollutants for Treatment Plants."  Journal of
     the Water Pollution Control Federation. Vol. 53, No. 10, (Oct. 1981) pg.
     1457-1468.

Berglund, R.L. and Whipple, G.M. ,  "Predictive Modeling of Organic Emissions."
     Chemical Engineering Progress. (Nov. 1987) pg. 46-54.

Convery, J.J., Cohen, J.M. and Bishop, D.F., "Occurrence and Removal of Toxics
     in Municipal Wastewater Treatment Facilities."  Seventh Joint United
     States/Japan Conference, May 1980.

Hannah, Sidney A., et al., "Comparative Removal of Toxic Pollutants by Six
     Wastewater Treatment Processes."  Journal of the Water Pollution Control
     Federation. Vol. 58, No. 1, (Jan. 1986) pg.  27-34.

Hutton, D.G. and E.I. duPont de Nemours and Co.,  Inc., "Removal of Priority
     Pollutants."  Industrial Wastes. March/April, 1980, pg. 22-26.

Kincannon, Don F., et al., "Removal Mechanisms for Toxic Priority Pollutants."
     Journal of the Water Pollution Control Federation. Vol. 55,  No. 2 (Feb.
     1983) pg. 157-163.

Namkung, Eun and Rittman, Bruce E., "Estimating Volatile Organic Compound
     Emissions From Publicly Owned Treatment Works."  Journal of the Water
     Pollution Control Federation. Vol. 59, No. 7 (July 1987) pg. 670-678.

Neiheisel, Timothy W., et al., "Toxicity Reduction: Municipal Wastewater
     Treatment Plants."  Journal of the Water Pollution Control Federation. Vol.
     60, No. 57 (Jan. 1988) pg. 57-67.

Patterson, John, Industrial Wastewater Treatment Technology. 2nd Edition, pg.
     340-360.

Petrasek, A.C., Kugelman, I.J., "Metals Removals and Partitioning In
     Conventional Wastewater Treatment Plants."  Journal of the Water Pollution
     Control Federation. Vol. 55,  No. 9, (Sept. 1983) pg. 1183-1190.

Petrasek, Albert C., et al., "Fate of Toxic Organic Compounds In Wastewater
     Treatment Plants." Journal of the Water Pollution Control Federation. Vol.
     55, No. 10 (Oct. 1983) pg. 1286-1296.

Russell, Larry L., et al., "Impact of Priority Pollutants on Publicly Owned
     Treatment Works Processes:  A Literature Review.  1984 Purdue Industrial
     Waste Conference.
                                 D-l

-------
Weber, W.J. and Jones B.E., "Toxic Substance Removal In Activated Sludge and PAC
     Treatment Systems."  USEPA Office of Research and Development,.Water
     Engineering Research Laboratory.

Yurteri, Coskun, et al., "The Effect of Chemical Composition of Water on Henry's
     Law Constant." Journal of the Water Pollution Control Federation. Vol.  59,
     No. 11.  (Nov. 1987) pg. 950-956.

USEPA, "Fate of Priority Pollutants in Publicly Owned Treatment Works - 30 Day
     Study."  (July 1982).

USEPA, "Fate of Priority Pollutants in Publicly Owned Treatment Works - Final
     Report."  (Sept. 1982).

USEPA, "Guidance Manual on the Development and Implementation of Local Discharge
     Limitations Under the Pretreatment Program."  (Nov. 1987).

USEPA, "Report to Congress on the Discharge of Hazardous Wastes to Publicly
     Owned Treatment Works."  (Feb. 1986).
                                   D-2

-------