v>EPA
United States
Environmental Protection
Agency
Office of Water
Regulations and Standards
Washington, DC 20460
Water
Report to Congress
on the Discharge
of Hazardous Wastes
to Publicly Owned
Treatment Works
530SW86004
MM I
-------
i
-------
REPORT TO CONGRESS ON THE
DISCHARGE OF HAZARDOUS WASTES
TO PUBLICLY OWNED TREATMENT WORKS
(THE DOMESTIC SEWAGE STUDY)
February, 1986
U.S. Environmental Protection Agency
Office of Water Regulations and Standards
401 M Street, SW
Washington, DC 20460
-------
-2-
In requiring the Agency to prepare this report, Congress
1s Inquiring about the ability of the regulatory programs
under the Clean Water Act. supplemented by other
environmental statutes, to control the discharge of
Hazardous waste to POTW's for adequate protection of
human health and the environment*
The report contains, along with an executive summary and
Introduction, a description of the types of hazardous waste
Included In the study; presentation of the types and numbers
of Industries that discharge hazardous waste to POTW's, as
well as the types and amounts of hazardous waste discharged
by these Industries; an analysis of the fate of hazardous
waste discharged to POTW's; the environmental and health
effects of these discharges; and an analysis of the
regulatory programs controlling these discharges.
N.
The following Is a summary of the key findings of the Report
0 POTW's have and will continue to have a major
role In the disposal and treatment of waste
containing hazardous constituents discharged by
Industrial facilities,
0 Hazardous waste, as well as hazardous waste mixed
with other wastewaters are typically the same
wastestreams that are regulated under the pre-
treatment and the Industrial treatment standards
programs of the Clean Water Act.
0 The study evaluated 47 Industrial categories and
Identified approximately 160,000 Industrial
facilities that discharge wastewater containing
hazardous constituents to POTW's. These facilities
discharge an estimated 3.2 billion gallon per day
of process wastewater.
0 The study showed that the Clean Water Act's
regulatory programs have made substantial
reductions In the discharge of hazardous
constituents to POTW's (approximately 95
percent of the metals and 50 percent of the
organlcs). Continuation of these programs can
bring about major, additional reduction of
organlcs constituents.
-------
-3-
* The study Identified key areas where additional
Information 1s necessary for the continued
evaluation of the Domestic Sewage Exclusion
* The study concluded that the Domestic Sewage
Exclusion should be retained.
This study Is a pajor contribution to the understanding of the
relationship between the Clean Water Act, the Resource Recovery
and Conservation Act, as well as other environmental legislation
Moreover, It underscores the Importance of coordination at
the Federal, State and local level*
He believe that the Report has addressed all the tasks mandated
by the Congress, and the Report supports the continuation of
the Domestic Sewage Exclusion. Because of the key role that
POTH's have In the discharge and treatment of these wastes
to their systems, the Agency will continue to evaluate
Municipal performance In controlling wastes received as a
result of the Domestic Sewage Exclusion. We have already
Identified areas where additional Information 1s necessary
for this evaluation.
He anticipate that this Information will be complex and
require some time for analysis and evaluation. In addition,
the Agency Is committed to a regulatory development process,
which because of Its public participation and review
requirements, also requires valuable time. While, we will
make every effort to move as quickly as possible, I wanted
to take this opportunity to Inform you that we are concerned
with meeting the 18 month promulgation requirements for
additional regulations 1n Section 3018(b) of HSWA.
The study provides a sound and
of hazardous wastes to POTU's.
solid Information base on this
thorough summary of the discharge
I believe It establishes a
subject.
Lee M. Thomas
Enclosure
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
FEE 71986
THE ADMINISTRATOR
Honorable Thomas P. O'Neill, Jr.
Speaker, U.S. House of Represesentatlves
Washington, D.C. 20515
Oear Mr. Speaker:
I am pleased to send you a copy of the Environmental Protection
agency's (EPA) Report to Congress on the Discharge of Hazardous
Wastes to Publicly Owned Treatment Work's (POTW's). The Report
1s referred to as the Domestic Sewage Study and responds to
Section 3018(a) of the Hazardous and Solid Waste Amendments
of 1984 (HSWA).
Section 3018(a) requires that "the Administrator shall, not
later than 15 months after the date of enactment of the
Hazardous and Solid Waste Amendments of 1984, submit a report
to the Congress concerning those substances identified or
listed under Section 3001 which are not regulated under this
subtitle by reason of the exclusion for mixtures of domestic
sewage and other wastes that pass through a sewer system to
publicly owned treatment works. Such report shall Include
the types, size and number of generators which dispose of
such substances in this manner, the types and quantities
disposed of 1n this manner, and the Identification of
significant generators, wastes, and waste constituents jiot
regulated under existing Federal law or regulated 1n a manner*
sufficient to protect humanhealth and the environment^.
The purpose of the Domestic Sewage Study was to evaluate the
Impacts of waste discharged to publicly owne*d treatment works
(POTW's) as a result of the Domestic Sewage Exclusion. The
Domestic Sewage Exclusion, (specified In Section 1004(27) of
RCRA) provides that a hazardous waste, when mixed with
domestic sewage is no longer considered hazardous. Therefore,
POTW's receiving hazardous waste 1n this manner are not subject
to the RCRA treatment, storage and disposal facility require-
ments. The premise behind the Domestic Sewage Exclusion
1s that RCRA management of wastes within a POTW 1s unnecessary
and redundant since these wastes are regulated under the Clean
Water Act's regulatory programs.
-------
-2-
In requiring the Agency to prepare this report, Congress
Is Inquiring about the ability of the regulatory programs
under the Clean Water Act, supplemented by other
.environmental statutes, to control the discharge of
hazardous waste to POTW's for adequate protection of
human health and the environment.
The report contains* along with an executive summary and
Introduction, a description of the types of hazardous waste
Included In the study; presentation of the types and numbers
of Industries that discharge hazardous waste to POTW's, as
well as the types and amounts of hazardous waste discharged
by these Industries; an analysis of the fate of hazardous
waste discharged to POTW's; the environmental and health
effects of these discharges; and an analysis of the
regulatory programs controlling these discharges.
Tlje following 1s a summary of the key findings of the Report:
POTW's have and will
role 1n the disposal
containing hazardous
Industrial facilities
continue to have a major
and treatment of waste
constituents discharged by
0 Hazardous waste, as well as hazardous waste mixed
with other wastewaters are typically the same
wastestreams that are regulated under the pre-
treatment and the Industrial treatment standards
programs of the Clean Water Act.
0 The study evaluated 47 Industrial categories and
Identified approximately 160,000 Industrial
facilities that discharge wastewater containing
hazardous constituents to POTW's. These facilities
discharge an estimated 3,2 billion gallon per day
of process wastewater.
0 The study showed that the Clean Water Act's
regulatory programs have made substantial
reductions 1n the discharge of hazardous
constituents to POTW's (approximately 95
percent of the metals and 50 percent of the
organlcs). Continuation of these programs can
bring about major, additional reduction of
organlcs constituents.
-------
-3-
0 The study Identified key areas where additional
Information 1s necessary for the continued
evaluation of the Domestic Sewage Exclusion
* The study concluded that the Domestic Sewage
Exclusion should be retained.
This study is ft Major contribution to the understanding of the
relationship between the Clean Water Act, the Resource Recovery
and Conservation Act* as well as other environmental legislation
Moreover, It underscores the Importance of coordination at
the Federal, State and local level.
Me believe that the Report has addressed all the tasks mandated
by the Congress, and the Report supports the continuation of
the Domestic Sewage Exclusion. Because of the key role that
POTU's have in the discharge and treatment of these wastes
to their systems, the Agency will continue to evaluate
Municipal performance in controlling wastes received as a
rtftult of the Domestic Sewage Exclusion. He have already
identified areas where additional Information 1s necessary
for this evaluation.
We anticipate that this Information will be complex and
require some time for analysis and evaluation. In addition,
the Agency 1s committed to a regulatory development process,
which because of Its public participation and review
requirements, also requires valuable time. While, we will
make every effort to move as quickly as possible, I wanted
to take this opportunity to Inform you that we are concerned
with meeting the 18 month promulgation requirements for
additionalregulations 1n Section 3018(b) of_HSH_A.
The study provides a sound and thorough summary of the discharge
of hazardous wastes to POTW's. I believe It establishes a
solid Information base on this subject.
Lee M. Thomas
Enclosure
-------
-------
FOREWORD
This report was prepared by the Office of Water Regulations and
Standards, the United States Environmental Protection Agency, with support
from a contractor, Science Applications International Corporation (SAIC), on
EPA Contract No. 68-01-6912. The EPA manager was Tom O1Parrel 1, and the SAIC
managers were Peter Trick and Frank Sweeney. In addition, an EPA Work Group,
comprised of members from the Office of Water, the Office of Solid Waste and
Emergency Response, the Office of General Counsel, the Office of Policy,
Planning, and Evaluation, the Office of Research and Development, the Office
of Air and Radiation, the Office of Pesticides and Toxic Substances, the
Office of External Affairs, and EPA Regions provided technical input and
review.
-------
-------
TABLE OF CONTENTS
EXECUTIVE SUMMARY .......................................... ....... E-l
1. INTRODUCTION ................................................. 1-1
1.1 PURPOSE ................................................. 1-1
1.1.1 Statutory Mandate ................................ 1-2
1.1.2 Legislative History .............................. 1-3
1.2 REGULATORY AND ENVIRONMENTAL BACKGROUND FOR THE
DOMESTIC SEWAGE STUDY (DSS) ............ . ................. 1-3
1.2.1 The RCRA Program ................................. 1-7
1.2.2 The National Pretreatment Program ................ 1-7
1.2.3 Comparison of RCRA and Pretreatment .............. 1-9
1.2.4 Potential Environmental Impacts Associated with
DSE Wastes ....................................... 1-10
1.3 METHODOLUGY FOR THE DOMESTIC SEWAGE STUDY ............... 1-12
1.3.1 Data Sources ..................................... 1-12
1.3.2 Availability of Data ............................. 1-13
1.3.3 Central Study Approaches ......................... 1-16
1.4 REPORT ORGANIZATION ..................................... 1-18
2. DESCRIPTION OF HAZARDOUS WASTES AND POLLUTANTS EVALUATED IN
THE STUDY ................. . ................................... 2-1
2.1 METHODOLOGY FOR THE SELECTION OF DSS POLLUTANTS ......... 2-1
2.1.1 Regulatory Definition of Hazardous Wastes ........ 2-1
2.1.2 Rationale for Pollutant-Specific Study Approach.. H-4
2.1.3 Methodology for Pollutant Selection .............. 2-7
2.2 DESCRIPTION OF DSS POLLUTANTS .............. . ............ 2-17
3. TYPES, QUANTITIES, AND SOURCES OF HAZARDOUS WASTES DISCHARGED
TO POTWS ................................................. .... 3-1
3.1 BACKGROUND AND METHODOLOGY FOR ANALYSIS OF HAZARDOUS
WASTE TYPES, QUANTITIES, AND SOURCES 3-1
3.1.1 Methodology for Development of an Industry
Categorization Scheme ............................ 3-2
3.1.2 Summary and Evaluation of Major Data Sources ..... 3-5
3.1.3 Organization of the Chapter ...................... 3-11
Kill
-------
3.2 TYPES AND QUANTITIES OF HAZARDOUS WASTES AND
CONSTITUENTS DISCHARGED BY THE ORGANIC CHEMICALS
INDUSTRIAL CATEGORIES. 3-11
3,2.1 Background and Methodology for Evaluation of the
Organic Chemicals Industrial Categories 3-12
3.2.2 Presentation of Findings for the Four Organic
Chemicals Industrial Categories 3-18
3.3 TYPES AND QUANTITIES OF HAZARDOUS WASTES AND CONSTITUENTS
DISCHARGED BY SELECTED CONSENT DECREE INDUSTRIES 3-37
3.3.1 Dischar9e Characteristics of Selected Consent
Decree Industries 3-39
3.3.2 Hazardous Constituent Loadings for the Selected
Consent Decree Industrial Categories 3-42
3.3.3 Analysis of Hazardous Constituent Loadings for the
Selected Consent Decree Industrial Categories.... 3-45
3.3,4 Analysis of Other Pertinent Data for the Selected
Consent Decree Industrial Categories 3-55
3.3,5 Summary of Hazardous Waste and Constituent Data
Presented for the Selected Consent Decree
Industrial Categories 3-71
3.4 ANALYSIS OF OTHER POTENTIAL SOURCES OF HAZARDOUS WASTE
DISCHARGES TO POTWs 3-84
3.4,1 Overview and Description of the Data Sources 3-84
3.4.2 Industrial Category Profiles 3-8b
3,5 SOURCE EVALUATION OF HAZARDOUS CONSTITUENT LOADINGS
TO POTW INFLUENT WASTEWATERS 3-114
3.5.1 Projected National Loadings of Priority Hazardous
Constituents to POTWs 3-115
3.5.2 Estimates of National POTW Loadings of Selected
Nonpriority Organic Hazardous Constituents 3-121
3.5,3 Production/Use Profiles for Selected Hazardous
Organic Constituents 3-127
3.6 RESIDENTIAL CONTRIBUTION TO POTW INFLUENT LOADINGS 3-152
3.7 SUMMARY ."...- 3-154
3.7,1 Types, Sources, and Quantities of Hazardous
Constituent Loadings to POTWs 3-154
3.7,2 Analysis of Hazardous Waste Types Discharged
to POTWs 3-163
4. FATE OF HAZARDOUS WASTE AND POLLUTANTS IN POTW COLLECTION AND
TREATMENT SYSTEMS 4-1
4.1 BACKGROUND AND METHODOLOGY 4-1
xiv
-------
4.1.1 Summary of Current State of Knowledge on Pollutant
Fate 4-3
4.1.2 Summary of Findings on Pollutant Fate 4-7,
4.2 ANALYSIS OF POLLUTANT FATE WITHIN POTW COLLECTION SYSTEMS 4-8
4.2.1 Analysis of Pollutant Volatilization within POTW
Col 1 ecti on Systems 4-8
4.2.2 Analysis of Potential for Ground Water
Contamination 4-9
4.3 ANALYSIS OF POLLUTANT FATE WITHIN POTW TREATMENT SYSTEMS. 4-13
4.3.1 Evaluation of POTW Removal Efficiencies - Pass
Through to Receiving Waters 4-13
4.3.2 Analysis of Pollutant Volatilization Rates Within
POTW Treatment Systems 4-14-
4.3.3 Analysis of Sludge Removal Rates Within POTW
Treatment Systems 4-19
4.3.4 Evaluation of POTW Biodegradation Processes 4-22
4.3.5 Evaluation of Pollutant Interference with POTW
Treatment Systems 4-24
4.3.6 Estimating the Risk Posed by the Migration of
Selected Contaminants from POTW Surface
Impoundments to Drinking Water Wells 4-28
4.4 SUMMARY OF POLLUTANT FATE WITHIN POTW COLLECTION AND
TREATMENT SYSTEM 4-28
5. EFFECTS OF DISCHARGES OF DOMESTIC SEWAGE STUDY POLLUTANTS TO
POTWs 5-1
5.1 INTRODUCTION 5-1
5.1.1 National Estimates of DSS Pollutant Releases 5-1
5.2 ASSESSMENT OF ENVIRONMENTAL EFFECTS OF SURFACE WATER
QUALITY 5-12
5.2.1 Projected Instream Concentrations of OSS
Pol 1 utants , 5-13
5.2.2 Summary of Empirical Data 5-18
5.2.3 Concl usi ons 5-23
5.3 ASSESSMENT OF EFFECTS OF AIR RELEASES 5-26
5.3.1 Description of Air Emissions from POTWs 5-27
5.3.2 Assessments of Effects 5-31
5.4 EFFECTS ON GROUND WATER 5-40
5.5 CONCLUSIONS 5-51
xv
-------
6. EVALUATION OF GOVERNMENT CONTROLS ON HAZARDOUS WASTE DISCHARGES
TO SEWERS 6-1
6.1 RATIONALE FOR HAZARDOUS WASTE DISCHARGES TO SEWERS 6-2
6.1.1 RCRA/CWA Overview 6-2
6.1.2 The Domestic Sewage Exclusion: Origins and
Implications for Generators/IUs 6-5
6.1.3 Implications of DSE for POTWs and Other Routes for
Hazardous Waste Discharge to Sewers 6-7
6.2 RELEVANT RCRA, CWA, AND OTHER STATUTORY/REGULATORY
REQUIREMENTS 6-9
6.2.1 RCRA's "Cradle to Grave" System 6-9
6.2.2 POTWs Jointly Regulated Under RCRA and CWA 6-26
6.2.3 Administrative Responsibilities of the State and
Federal Government Under RCRA 6-26
6.2.4 Clean Water Act Controls 6-29
6.2.5 Responsibilities at the Local, State, and Federal
Level 6-34
6.2.6 Other CWA Requirements Affecting Control of DSE
Wastes 6-37
6.2.7 Other Statutory Controls Affecting the Discharge
of Hazardous Wastes to Sewers 6-41
6.3 EVALUATION OF THE EFFECTIVENESS OF THE PRETREATMENT
PROGRAM IN CONTROLLING DSS WASTES 6-49
6.3.1 Status of Pretreatment Program Implementation 6-50
6.3.2 Effectiveness of Categorical Standards 6-62
6.3.3 Effectiveness of Prohibited Discharge Standards... 6-66
6.3.4 Effectiveness of Spill Control and Liquid Waste
HaulI er Control s 6-73
6.3.5 Municipal Perceptions on the Need for Hazardous
Waste Control at POTWs 6-77
6.4 CONCLUSIONS 6-80
6,4.1 Administrative Necessity for DSE: RCRA/CWA
Interaction 6-81
6.4.2 The Effectiveness of CWA Pretreatment Controls.... 6-82
6.4.3 Appropriateness of RCRA/CWA Controls on POTWs
Receiving Hazardous Wastes 6-84
7. FINDINGS AND RECOMMENDATIONS 7-1
7.1 INTRODUCTION 7-1
7.2 FINDINGS 7-1
7.3 RECOMMENDATIONS 7-10
LIST OF REFERENCES
XVI
-------
LIST OF TABLES
Table Page
1-1 COMPARISON OF MAJOR COMPONENTS OF THE RCRA AND
PRETREATMENT PROGRAMS 1-4
1-2 PRINCIPAL DATA SOURCES USED IN THE STUDY 1-14
1-3 EVALUATION OF OW/OSW DATA BASES 1-lb
2-1 PESTICIDE CLASSIFICATION SYSTEM 2-13
2-2 LIST OF TIER 1, 2, 2A, AND PESTICIDE POLLUTANTS FUR THE DSS 2-18
2-3 REGULATORY STATUS OF DSS POLLUTANTS 2-21
3-1 DSS INDUSTRIAL CATEGORIES 3-3
3-2 STRENGTHS AND WEAKNESSES OF MAJOR INDUSTRIAL DATA SOURCES 3-6
3-3 ADEQUACY OF AVAILABLE DATA SOURCES FOR EVALUATION OF DSS
INDUSTRIAL CATEGORIES 3-7
3-4 TYPES OF UATA CONTAINED IN ITD AND ISDB DATABASES 3-15
3-5 DISCHARGE CHARACTERISTICS OF THE ORGANIC CHEMICALS
INDUSTRIAL CATEGORIES 3-19
3-6 SUMMARY OF HAZARDOUS CONSTITUENT LOADINGS FOR ORGANIC
CHEMICALS INDUSTRIAL CATEGORIES 3-21
3-7 TOP TWENTY HAZARDOUS CONSTITUENTS WITH THE HIGHEST RAW,
CURRENT AND PSES LOADING FOR FOUR ORGANIC CHEMICALS
INDUSTRIAL CATEGORIES - ITD DATA ONLY 3-23
3-8 TOP TWENTY HAZARDOUS CONSTITUENTS WITH THE HIGHEST RAW,
CURRENT, AND PSES LOADING FOR FOUR ORGANIC CHEMICALS
INDUSTRIAL CATEGORIES - ISDB DATA ONLY 3-24
3--9 LOADINGS OF VOLATILE AND IGNITABLE/REACTIVE CONSTITUENTS
FROM THE FOUR ORGANIC CHEMICALS INDUSTRIAL CATEGORIES 3-28
3-10 PROFILE OF ULTIMATE DISPOSAL METHODS FOR CONCENTRATED
HAZARDOUS WASTES GENERATED BY FOUR ORGANIC CHEMICALS
INDUSTRIES 3-30
3-11 SUMMARY OF CONCENTRATED HAZARDOUS WASTE GENERATED ANO
ULTIMATELY DISCHARGED BY FOUR ORGANIC CHEMICALS
INDUSTRIAL CATEGORIES AND PETROLEUM REFINING CATEGORY 3-34
XV11
-------
3-12 DISCHARGE CHARACTERISTICS OF SELECTED CONSENT DECREE
INDUSTRIAL CATEGORIES (INCLUDING ORGANIC CHEMICALS
INDUSTRIAL CATEGORIES) 3-41
3-13 LOADINGS OF TOTAL PRIORITY HAZARDOUS METALS AND CYANIDE
AND TOTAL PRIORITY HAZARDOUS ORGANICS FOR SELECTED
CONSENT DECREE INDUSTRIAL CATEGORIES 3-46
3-14 TOP TEN INDUSTRIAL CATEGORIES WITH THE HIGHEST LOADINGS
FOR TOTAL HAZARDOUS CONSTITUENTS (PRIORITY METALS AND
CYANIDE) 3-48
3-15 TOP TEN INDUSTRIAL CATEGORIES WITH THE HIGHEST LOADINGS
FOR TOTAL HAZARDOUS CONSTITUENTS (PRIORITY ORGANICS) 3-49
3-16 TOP TEN INDUSTRIAL CATEGORIES WITH THE HIGHEST LOADINGS
FOR TOTAL HAZARDOUS CONSTITUENTS (ALL PRIORITY
POLLUTANTS) 3-50
3-17 TOP TWENTY HAZARDOUS CONSTITUENTS (PRIORITY POLLUTANTS)
WITH THE HIGHEST LOADINGS FOR THE SELECTED CONSENT DECREE
INDUSTRIAL CATEGORIES 3-53
3-18 LOADINGS OF TOTAL VOLATILE POLLUTANTS (TVP) AND TOTAL
IGNITABLE/REACTIVE POLLUTANTS (TI/RP) FOR SELECTED
CONSENT DECREE INDUSTRIAL CATEGORIES 3-56
3-19 NUMBER OF INDIRECT DISCHARGES AND HAZARDOUS WASTE
QUANTITIES FOR SMALL QUANTITY GENERATORS 3-60
3-20 SMALL QUANTITY GENERATOR HAZARDOUS WASTE TYPE(S)
ACCOUNTING FOR 90 PERCENT OF WASTE QUANTITY FOR
SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES 3-63
3-21 RESULTS FROM PARAGRAPH 4(c) STUDY FOR THE SELECTED
CONSENT DECREE INDUSTRIAL CATEGORIES 3-66
3-22 ESTIMATED LOADINGS OF HAZARDOUS NONPRIORITY VOLATILE
ORGANIC POLLUTANTS FOR THE PHARMACEUTICAL MANUFACTURING
INDUSTRIAL CATEGORY 3-75
3-23 SUMMARY OF OSS SAMPLING AT AN INDIRECT DISCHARGING
PAINT MANUFACTURING FACILITY 3-83
3-24 SMALL QUANTITY GENERATOR HAZARDOUS WASTE TYPE(S)
ACCOUNTING FOR 90 PERCENT OF WASTE QUANTITY FOR
OTHER INDUSTRIAL CATEGORIES 3-87
3-25 DATA FOR HAZARDOUS WASTE CLEANUP SITES WHERE WASTES
WERE DISCHARGED TO POTWS 3-95
3-26 COMPARISON OF INDUSTRIAL FLOW PERCENTAGES FOR 40 POTWs
AND EPA NEEDS POTWs 3-117
-------
3-27 NATIONAL HAZARDOUS PRIORITY CONSTITUENT LOADINGS TO
POTW INFLUENT 3-118
3-28 USE AND INFLUENT LOADINGS DATA FOR SELECTED HAZARDOUS
ORGANIC CONSTITUENTS 3-133
3-29 PROJECTED INFLUENT LOADINGS FOR SELECTED NONPRIORITY
ORGANIC HAZARDOUS CONSTITUENTS 3-126
3-30 OCCURRENCE OF HAZARDOUS ORGANIC CONSTITUENTS AT POTWs
BASED ON PARAGRAPH 4(c) SAMPLING DATA 3-128
3-31 RESIDENTIAL CONTRIBUTION TO OVERALL POTW INFLUENT
CONSTITUENT LOADINGS 3-153
3-32 SUMMARY OF HAZARDOUS CONSTITUENT LOADINGS TO POTWs FOR
THE SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES 3-156
3-33 QUANTITIES OF HAZARDOUS WASTE TYPES DISCHARGED TO POTWs
FROM SMALL QUANTITY GENERATORS FOR OTHER INDUSTRIAL
CATEGORIES 3-161
3-34 COMPARISON OF INDUSTRY-WIDE METAL CONCENTRATIONS'WITH
MAXIMUM EP CONTAMINANT CONCENTRATIONS 3-165
3-35 PROFILE OF INDUSTRIAL SOURCES OF ORGANIC CONSTITUENTS
WHICH ARE RCRA SPENT SOLVENTS 3-166
4-1 SUMMARY OF FIRE/EXPLOSION RISK CHARACTERISTICS FOR THOSE RCRA
STUDY POLLUTANTS WHOSE FLASHPOINT IS BELOW AN AMBIENT
TEMPERATURE (100°F) THAT MIGHT BE FOUND IN POTW COLLECTION
SYSTEMS 4-10
4-2 COMPARISON OF ESTIMATED PERCENT REMOVALS WITH THOSE OBTAINED
USING THE 40 POTW STUDY DATABASE 4-15
4-3 ADJUSTMENTS TO EPA-WERLS ESTIMATED VOLATILIZATION RATES 4-17
4-4 HENRY'S LAW CONSTANT/PARTITION COEFFICIENT GROUPINGS USED
TO EXTRAPOLATE AVERAGE PARTITION RATES 4-21
4-5 SUMMARY TABLE OF ESTIMATED FRACTION REMOVED: STRIPPED,
PARTITIONED AND BIODEGRADED FOR THOSE POLLUTANTS WITH
INDIVIDUAL FRACTION PARTITIONED FIGURES 4-23
>
4-6 REPORTED VALUES FOR BIOLOGICAL PROCESS TOLERANCE LIMITS
OF ORGANIC PRIORITY POLLUTANTS 4-25
4-7 POTW PASS THROUGH 4-29
4-8 AIR EMISSIONS 4-33
4-9 PARTITIONING TO SLUDGE 4-38
XIX
-------
5-1 LOADINGS OF DSE POLLUTANTS TO POTW AND RESULTANT
RECEIVING ENVIRONMENTS 5-2
5-2 SUMMARY OF POLLUTANT LOADINGS 5-7
5-3 EFFECTS STUDY DATA LIMITATIONS 5-9
5-4 MODEL INDICATORS OF WATER QUALITY EXCEEDANCES USING
MODIFIED CRITERIA AT 1,839 POTWs 5-15
5-5 HUMAN HEALTH CRITERIA EXCEEDANCES 40 POTW DATABASE 5-17
5-6 HUMAN HEALTH CRITERIA EXCEEDANCES BASED ON AMSA AND
REGION V DATA 5-19
5-7 SUMMARY OF INDEPTH NURTH CAROLINA POTW TOXICITY
EXAMINATIONS 5-21
5-8 1982-1984 FLORIDA BIOASSAY RESULTS - LC50 (48 hr.) 5-24
5-9 MAJOR POLLUTANT EMISSIONS TO AIR BY POTW VOLATILIZATION 5-29
5-10 SUBSTANCES UNDER CONSIDERATION FOR LISTING UNDER SECTION
112 OF THE CLEAN AIR ACT 5-30
5-11 DOCUMENTATION OF OCCUPATIONAL HEALTH HAZARDS IN POTW
COLLECTION AND TREATMENT SYSTEMS 5-32
5-12 TOXICITY OF 16 MAJOR VOLATILE POLLUTANTS 5-34
5-13 AIR MONITORING RESULTS FOR PHILADELPHIA'S NORTHEAST
WATER POLLUTION CONTROL PLANT 5-39
S-14 SUMMARY OF NATIONWIDE GWSS OCCURRENCE DATA 5-44
5-15 NATIONAL LOADINGS TO SLUDGE (KG/YR) 5-47
5-16 INCREMENTAL RANKING FOR LANDFILLING 5-48
5-17 INCREMENTAL RANKING FOR LAND APPLICATION 6-49
6-1 DEFINITIONS FROM 260.10; MINIMUM STATUTORY TSDF REQUIREMENTS 6-17
6-2 MINIMUM STATUTORY TSDF REQUIREMENTS 6-18
6-3 STATUS OF STATE FINAL AUTHORIZATIONS 6-28
6-4 STATE NPOES PROGRAM STATUS AS OF JUNE 1985 6-36
6-5 PRETREATMENT PROGRAM APPROVAL STATUS 6-54
6-6 SUMMARY STATUS OF NATIONAL CATEGORICAL PRETREATMENT
STANDARDS 6-59
6-61
6-7 COMPLIANCE STATUS OF FACILITIES BY EPA REGION
xx
-------
LIST OF FIGURES
Figure
1-1
2-1
2-2
2-3
POTENTIAL PATHWAYS AND ENVIRONMENTAL IMPACTS ASSOCIATED
WITH USE WASTES
SCHEMATIC DIAGRAM SHOWING THE INTERRELATIONSHIP BETWEEN
POLLUTANT SELECTION PROCEDURES AND KEY STUDY COMPONENTS
PROFILE OF REGULATORY STATUS OF DSS POLLUTANTS
REPRESENTATION OF KEY RCRA AND CWA POLLUTANT LISTS ON
DSS POLLUTANT LIST
3-1 COMPARISON OF LOADINGS OF NONPRIORITY TO PRIORITY
ORGANIC CONSTITUENTS FOR THE FOUR ORGANIC CHEMICAL
INDUSTRIES
3-2 PROFILE OF DISPOSAL METHODS FOR CONCENTRATED
HAZARDOUS WASTE GENERATED BY FOUR ORGANIC CHEMICALS
INDUSTRIAL CATEGORIES
3-3 SOURCE PROFILE FOR HAZARDOUS WASTES ULTIMATELY DISCHARGED
BY FOUR ORGANIC CHEMICALS INDUSTRIAL CATEGORIES
3-4 PROFILE OF HAZARDOUS WASTE TYPES DISCHARGED TO POTWs
BY FOUR ORGANIC CHEMICALS INDUSTRIAL CATEGORIES
3-5 CORRELATION BETWEEN INDUSTRIAL END USE AND AVERAGE
NATIONAL POTW INFLUENT LOADINGS
5-1 RANKING OF INFLUENT OF TOTAL TOXIC METALS
5-2 RANKING OF INFLUENT OF TOTAL TOXIC ORGANICS
6-1 GENERATORS, TRANSPORTERS, AND TSDS
6-2 WHEN IS A WASTE A HAZARDOUS WASTE? THE CASE OF THE
INDUSTRIAL USER
6-3 THE POTW AS A GENERATOR AND TSDF
6-4 TSDs PROJECTED TO REQUIRE PERMITS
6-5 LOCAL PRETREATMENT PROGRAM APPROVALS IN FY 82, 83, 84,
and 85
Page
1-11
2-15
2-27
2-28
3-26
3-35
3-36
3-38
3-125
5-10
5-11
6-3
6-10
6-15
6-19
6-53
xxi
-------
LIST OF ACRONYMS
ACGIH
AERL
AMSA
BMR
BPJ
CAA
CERCLA
CFCs
CFR
CWA
DSE
DSS
FIFRA
FWPCA
GCA
HSWA
HWDMS
I SOB
I TO
I Us
IWC
kkg
MDSD
mgd
MLVSS
American Council of Government Industrial Hygienists
Athens Environmental Research Laboratory
Association of Metropolitan Sewerage Agencies
Baseline Monitoring Report
Best Professional Judgment
Clean Air Act
Comprehensive Environmental Response, Compensation and
Liability Act (Superfund)
Chlorinated Fluorohydrocarbons
Code of Federal Regulations
Clean Water Act
Domestic Sewage Exclusion
Domestic Sewage Study
Federal Insecticide, Fungicide, and Rodenticide Act
Federal Water Pollution Control Act
Gulf Coast Authority
Hazardous and Solid Waste Amendments
Hazardous Waste Data Management System
Industry Studies Data Base
Industrial Technology Division
Industrial users
Instream wastewater concentration
Metric tons
Monitoring and Data Support Division
Million gallons per day
Mixed liquor volatile suspended solids
XXll
-------
LIST OF ACRONYMS (Continued)
MPRSA
NESHAPs
NPDES
NRC
NRDC
NSPS
OCPSF
OSHA
OSW
OSWER
OTA
OU
PELS
PIRT
POTWs
PSES
RCRA
RIA
SDWA
SIC
SIPs
SQG
TLVs
TSCA
Marine Protection, Research, and Sanctuaries Act
National Emission Standards for Hazardous Air
Pollutants
National Pollutant Discharge Elimination System
National Response Center
Natural Resources Defense Council
New source performance standards
Organic Chemicals and Plastics and Synthetic Fibers
Industry
Occupational Safety and Health Administration
Office of Solid Waste
Office of Solid Waste and Emergency Response
Office of Technology Assessment
Office of Water
Permissible exposure limits
Pretreatment Implementation Review Task Force
Publicly Owned Treatment Works
Pretreatment Standards for Existing Sources
Resource Conservation and Recovery Act
Regulatory Impact Analysis
Safe Drinking Water Act
Standard Industrial Classification
State Implementation plans
Small Quantity Generator
Threshold limit values
Toxic Substances Control Act
XX 111
-------
TSDF
TSP
TTO
U.S. EPA
VHAPS
VOCs
WERL
LIST OF ACRONYMS (Continued)
Treatment, storage, and/or disposal facility
Total suspended particulates
Total Toxic Organlcs
United States Environmental Protection Agency
Volatile hazardous air pollutants
Volatile organic compounds
Wastewater Environmental Research Laboratory
XXIV
-------
VOLUME II
LIST OF APPENDICES
APPENDIX A - 65 COMPOUNDS OR CLASSES OF COMPOUNDS
APPENDIX B - POLLUTANT DESCRIPTIONS
APPENDIX C - OSS INDUSTRY CATEGORIZATION SCHEME
APPENDIX D - DETAILED DESCRIPTION OF METHODOLOGIES USED TO ESTIMATE POLLUTANT
LOADING AND HAZARDOUS WASTE DISCHARGE QUANTITIES FOR THE ORGANIC
CHEMICALS INDUSTRY
APPENDIX E - HAZARDOUS POLLUTANT LOADINGS FOR THE ORGANIC CHEMICALS INDUSTRY
CATEGORIES
APPENDIX F - DSS INDUSTRY PROFILE FORMS
APPENDIX G - HAZARDOUS POLLUTANT LOADINGS FOR THE SELECTED CONSENT DECREE
INDUSTRIAL CATEGORIES
APPENDIX H - HAZARDOUS WASTE DATA MANAGEMENT SYSTEM (HWDMS) SUMMARY FOR THE
SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES
APPENDIX I - STATE/LOCAL HAZARDOUS POLLUTANT DATA FOR DSS INDUSTRIAL
CATEGORIES
APPENDIX J - DSS SAMPLING PROGRAM RESULTS
APPENDIX K - AMSA SURVEY RESULTS
APPENDIX L - BASIC CHARACTERISTICS FOR OTHER INDUSTRIAL CATEGORIES
APPENDIX M - SUMMARY OF HAZARDOUS WASTE DATA MANAGEMENT SYSTEM (HWDMS) FOR
OTHER INDUSTRIAL CATEGORIES
APPENDIX N - DSS POLLUTANTS REVIEWED AND PHYSICAL/CHEMICAL DATA USED TO
EVALUATE POLLUTANT FATE
APPENDIX 0 - ACCLIMATED AND UNACCLIMATED PERCENT REMOVALS USED TO ESTIMATE
PASS THROUGH LOADINGS
APPENDIX P - ACCLIMATED AND UNACCLIMATED VOLATILIZATION FACTORS
APPENDIX Q - SLUDGE PARTITION FACTORS USED TO ESTIMATE DSS LOADINGS TO THE
SLUDGE
APPENDIX R - FEDERAL ENVIRONMENTAL STANDARDS AND CRITERIA
APPENDIX S - OSHA PERMISSIBLE EXPOSURE LIMITS AND AMERICAN COUNCIL OF
GOVERNMENT INDUSTRIAL HYGIENISTS THRESHOLD LIMIT VALUES
XXV
-------
-------
EXECUTIVE SUMMARY
-------
-------
EXECUTIVE SUMMARY
This report presents the results of the Domestic Sewage Study (DSS)
performed by the U.S. Environmental Protection Agency in response to Section
3018(a) of the Resource Conservation and Recovery Act (added by the Hazardous
and .Solid Waste Amendments of 1984). This provision requires that EPA
prepare:
... a report to the Congress concerning those substances
identified or listed under section 3001 which are not
regulated under this subtitle by reason of the exclusion
for mixtures of domestic sewage and other wastes that pass
through a sewer system to a publicly owned treatment works.
Such report shall include the types, size and number of
generators which dispose of such substances in this manner,
the types and quantities disposed of in this manner, and
the identification of significant generators, wastes, and
waste constituents not regulated under existing Federal law
or regulated in a manner sufficient to protect human health
and the environment.
Within EPA, the Office of Water has accepted lead responsibility for
preparing this report.
Purpose
The purpose of the OSS is to evaluate the impacts of wastes discharged to
publicly owned treatment works (POTWs) as a result of the Domestic Sewage
Exclusion (DSE). The DSE provides that a hazardous waste, when mixed with
domestic sewage, is no longer considered a hazardous waste. The exclusion
allows industries connected to POTWs to discharge hazardous wastes to sewers
containing domestic sewage without having to comply with certain RCRA
generator requirements, such as manifesting and reporting requirements.
Moreover, POTWs receiving DSE wastes are not deemed to have received hazardous
wastes and, therefore, are not subject to RCRA treatment, storage, and
disposal facility requirements. Section 3018{a) directs EPA to ascertain how
much hazardous waste is being discharged to sewers as a result of this
exclusion, and whether existing regulations provide sufficient protection for
human health and the environment.
E-l
-------
Study Approach
Specifically, Congress requested a report containing information on:
Types, size, and number of generators using the DSE
Types and quantities of wastes disposed under the DSE
Significant generators, wastes, and constituents not sufficiently
regulated to protect human health and the environment.
In performing its source evaluation, EPA collected information on waste
discharges from 47 industrial categories and the residential sector. The DSS
analysis provides detailed loadings estimates for 30 selected industries
covered under the consent decree negotiated between the National Resources
Defense Council (NRDC) and EPA in 1976. EPA presently does^jiotjiaye
sufficient data to characterize fully waste discharges by the £ema1ri1jigJ7'
9 although It appears, based on limited available data,
that certain of these categories may be discharging 5ignificajit__guajitUjeS-af
waste.
After assessing the various data sources available for performance of the
DSS, EPA adopted a technical approach that provides estimates for loadings of
specific hazardous constituents (e.g., benzene, tetrachloroethylene, acetone,
etc.) rather than generic RCRA waste types (e.g., spent solvents, electro-
plating baths, still bottoms, etc.). The Agency collected and evaluated
discharge data for 165 selected hazardous constituents. Because of data
limitations, the analysis provides more extensive estimates for loadings of
priority hazardous constituents (i.e., those hazardous constituents that also
are considered Clean Water Act priority pollutants) rather than nonpriority
hazardous constituents. Generic hazardous wastes can include both priority
and nonpriority hazardous constituents. More comprehensive assessment of
hazardous waste discharges, then, is heavily dependent on the collection of
additional data on discharges of nonpriority hazardous constituents to POTWs.
EPA was able to develop more detailed information on hazardous wastes,
constituents, and management practices for the organic chemicals industry,
£-2
-------
using the Office of Solid Waste's Industry Studies Data Base (ISDB). DSS
estimates of the quantity of hazardous waste constituents produced by the
organic chemicals industry (and ultimately disposed to sewers) focused on the
quantities of hazardous materials generated at the actual production process
as its point of measurement. This method of estimating the quantities of
hazardous wastes is significantly different from traditional methods of
measurement used in the RCRA program, which consider not only the quantity of
hazardous waste generated in the production process, but also account for any
mixing of hazardous waste with nonhazardous materials as a result of their
treatment, storage, and disposal. Nevertheless, use of a point of production
approach for the DSS represented a valid methodology for the development and
interpretation of constituent-specific data.
Furthermore, there is a fundamental lack of knowledge on the behavior and
effects associated with many hazardous constituents. In particular, little is
known about ground water contamination as a result of exfiltration from POTW
systems or air emissions due to industrial discharges to sewers. Projections
based on best professional judgments were used to overcome inadequate data
where some information existed. Otherwise, gaps, are documented to help guide
future research.
The DSS report presents findings on the types, sources, and quantities of
hazardous wastes discharged to sewers. The fate of hazardous constituents in
POTW systems is examined and environmental effects are analyzed. The adequacy
of existing government controls is evaluated. Major findings and recommenda-
tions in each of these areas are discussed below.
Overview of Sources, Types, and Quantities of Hazardous Constituents
Discharged to Sewers
The DSS source assessment evaluated discharge data for 47 industrial
categories and the residential sector, and identified approximately
160,000.industrial and commercial facilities discharging wastes that
contain hazardous constituents. Together, these facilities discharge
an estimated 3,200 million gallons per day of process wastewater,
constituting approximately 12 percent of total POTW flow. The 30
selected consent decree industries discharge 62,000 metric tons per
year of the hazardous metal constituents at raw discharge levels, and
3,300 metric tons per year of the hazardous metal constituents,
E-3
-------
assuming full PSES reductions. With full implementation and enforce-
ment, categorical standards should produce a 94 percent reduction in
metal constituent loadings from the consent decree industries.
These same industries discharge between 37,000 and 52,000 metric tons
per year of the priority organic constituents at raw discharge levels,
and approximately 20,000 metric tons per year of these constituents,
assuming implementation of existing and proposed PSES standards. At
projected PSES control levels, categorical standards will provide
reductions in organic constituent loadings of between 47 and 60
percent. Relative contributions of metal and priority organic
constituents from the residential sector will increase significantly
following PSES implementation.
Discharge of Nonpriorlty RCRA Constituents to POTWs
EPA currently lacks the data necessary to estimate fully the loadings
of nonpriority RCRA constituents from most industrial categories.
Still, the ISDB contains substantial nonpriority constituent data for
the four organic chemicals industrial categories.
Based on ISDB, raw loadings to POTWs of nonpriority hazardous con-
stituents are estimated to be approximately 64,000 metric tons per
year, of which only 736 metric tons constitute nonpriority metals.
This analysis indicates that the major organics industries discharge
approximately 2.5 kilograms of nonpriority constituents for each
kilogram of priority constituents. Information collected from a
variety of data sources ^suggests that nonpriority constituents also
are discharged in significant quantities by numerous other industries.
Even if extensive loadings information existed, there is a lack of
technical data necessary to determine fate and effects of these
compounds. Before EPA can effectively regulate any of these
compounds, it will be necessary to improve our knowledge of the
sources, quantities, and impacts of these constituents.
Discharge of Solvents and Other Common Organics to POTWs
Certain priority organics, especially chlorinated solvents, aromatic
hydrocarbons, and phthalate esters, frequently are detected in POTW
influent wastewaters, Nonpriority organic solvents, such as xylene,
methyl ethyl ketone, acetone, ethyl acetate, methanol, and others also
are projected to be common constituents of POTW wastewaters. The
prevalence of these organic compounds in POTW wastewater raises
concerns about, potential effects on _humanheaUh. the environment, and
POTW operations when discharged to sewerT;*
Solvents may be discharged by a broad range of industrial categories.
Consequently, any regulatory strategy to develop and implement solvent
controls must adequately reflect the number and variety of possible
sources of solvent wastes.
E-4*
-------
t Pollutant Fate Within POTW Treatment Systems
Assuming a fully acclimated biological treatment system, EPA estimates
that 92 percent of all pollutants are removed by POTWs from discharges
to surface waters. Under this scenario, 14 percent of all pollutants
are air-stripped, 16 percent are removed to sludge, 62 percent are
biodegraded, while 8 percent pass through to receiving waters. Assum-
ing unacclimated POTW treatment, an estimated 82 percent of all pol-
lutants are removed by POTWs from discharges to surface waters. Under
this second scenario, 25 percent of all pollutants are air-stripped,
14 percent are removed to sludge, 43 percent are biodegraded, while 18
percent pass through to receiving waters. As indicated by these
projections, the degree of biological acclimation in P.OTW treatment
units may significantly affect overall POTW removal efficiencies, as
well as pollutant fate within treatment systems. Generally, as system
acclimation decreases, POTW removal efficiencies tend to decrease,
while pollutant quantities air-stripped tend to increase due to
reductions in competing processes, such as biodegradation. Without
additional information on wastewater discharge patterns and biological
acclimation rates, EPA cannot at this time determine which treatment
scenario is more representative of actual treatment conditions at
POTWs accepting industrial wastewater.
' Evaluation of the Fate and Effects of Hazardous Waste Discharges
The analysis of the fate and effects of DSS pollutant discharges to
POTWs shows clearly that environmental degradation can occur as a
result of these discharges. However, quantitative estimates of these
effects are hampered by a Lack of environmental criteria, and a lack of
available data. There are four significant pollutant fates within
POTW treatment systems, including air-stripping, adsorption to sludge,
biodegradation, and pass through to receiving waters. An estimated
total annual loading of 92 million kilograms of hazardous pollutants
enter POTWs nationwide. While these loadings are important, findings
on sludge and water quality impacts show that the significant effects
are associated with the toxicity and characteristics of specific
pollutants and not just the quantities of pollutants entering the
environment.
Adequacy of Existing Government Controls on the Discharge of Hazardous
Wastes to Sewers
Substantial amounts of hazardous waste constituents have been
regulated, and sufficient authorities do exist under CWA and RCRA to
control the known impacts associated with the discharge of hazardous
wastes to sewers. This finding supports retention of the DSE at the
present time, recognizing the logic of RCRA's reliance on CWA's
pretreatment program for regulation of the discharge of aqueous
hazardous wastes to sewers. At the same time, deficiencies exist in '\
Federal pretreatment standards and weaknesses in local pretreatment I
programs that could be improved, under existing authorities, to better]t
protect human health and the environment.
E-5
-------
A basic lack of information on releases of hazardous wastes to ground
water and air from POTWs requires that further study be undertaken
prior to completion of the assessment of the need for additional
regulatory controls. These potential impacts may require increased
reliance on RCRA and/or other statutes to fill gaps in protection
afforded by the provisions of the CWA.
Recommendations
The following four recommendations for improving controls on hazardous
waste discharges to sewers have been derived from the findings of the
Domestic Sewage Study:
Additional research, data collection, and analysis are necessary to
fill information gaps on sources and quantities of hazardous
wastes, their fate and effects in POTW systems and the environment,
and the design of any additional regulatory controls which might be
necessary.
- Improvements can be made to Federal categorical standards and local
pretreatment controls to enhance control of hazardous wastes
discharged to sewers.
- EPA should emphasize improvement of controls on hazardous wastes
through ongoing implementation of water programs. This will
require coordination with the water quality program, sludge
management program, and enforcement programs,
- RCRA, CERCLA, and CAA should be considered along with CWA to
control hazardous waste discharges and/or receiving POTWs if the
recommended additional studies indicate problems.
E-6
-------
CHAPTER 1
INTRODUCTION
-------
-------
1. INTRODUCTION
This report presents the results of the Domestic Sewage Study, a study
conducted by the U.S. Environmental Protection Agency (EPA) in response to a
specific Congressional mandate in the Hazardous and Solid Waste Amendments
(HSWA) of 1984. These amendments to the Resource Conservation and Recovery
Act (RCRA) added Section 3018(a), which required that:
The Administrator shall, not later than 15 months after the date of
enactment of the Hazardous and Solid Waste Amendments of 1984,
submit a report to the Congress concerning those substances
identified or listed under section 3001 which are not regulated
under this subtitle by reason of the exclusion for mixtures of
domestic sewage and other wastes that pass through a1 sewer system to
a publicly owned treatment works. Such report shall include the
types, size and number of generators which dispose of such sub-
stances in this manner, the types and quantities disposed of in this
manner, and the identification of significant generators, wastes,
and waste constituents not regulated under existing Federal law or
regulated in a manner sufficient to protect human health and the
environment.
In response to this mandate, a study plan was prepared, circulated for
Agency-wide comment, and approved early in 1985. Project responsibility
resided with the Office of Solid Waste and Emergency Response (OSWER). OSWER
delegated lead responsibility to the Office of Water (OW) because of OW's
experience in performing similar analytical studies, such as the Regulatory
Impact Analysis of the General Pretreatment Regulations. An internal Agency
work group was established to provide advice and to review the report. In
addition, Science Applications International Corporation (SAIC) provided
significant technical support. Technical work began in March 1985 and was
completed in October of that year.
1.1 PURPOSE
The purpose of the Domestic Sewage Study is to evaluate the impacts of
wastes discharged to local wastewater treatment plants as a result of the
Domestic Sewage Exclusion [specified in Section 1004(27) of RCRA and codified
in 40 CFR 261.4(a)(l)]. Under Section 1004(27) of RCRA, solid or dissolved
material in domestic sewage is not, by definition, a "solid waste" and, as a
1-1
-------
corollary, cannot be considered a "hazardous waste." Therefore, this material
is exempt from RCRA regulation. In codifying this statutory provision,
Section 261.4(a)(l) of 40 CFR provides that "any mixture of domestic sewage
and other wastes that passes through a sewer system to a publicly owned
treatment works for treatment" is similarly not a solid waste.
Thus, the Domestic Sewage Exclusion (DSE) means that a hazardous waste,
when mixed with domestic sewage (hereinafter referred to as DSE waste), is no
longer considered a solid waste and consequently, no longer considered
hazardous by definition. The premise behind the DSE is that It is unnecessary
(and redundant) to subject hazardous wastes mixed with domestic sewage to RCRA
management requirements since these DSE wastes would receive the benefits of
treatment offered by publicly owned treatment works (POTWs) and be regulated
under Clean Water Act programs, such as the National Pretreatment Program.
1.1.1 Statutory Mandate
The statutory language in Section 3018(a) identified three basic areas of
interest to be addressed in the Domestic Sewage Study:
Types, size, and number of generators that dispose of wastes pursuant
to the DSE
Types and quantities of wastes disposed of under the DSE
Significant generators? wastes., and constituents not sufficiently
regulated to protect£{iuman healtj^and the environment.
Interest in these three issues stems from Congressional concern that the
DSE may be a significant loophole in RCRA. EPA stated in the Preamble to the
1980 RCRA regulations that, while the National Pretreatment Program should
ensure that environmental problems did not occur as a result of the DSE, the
Agency's action to continue the exclusion was not based on any formal deter-
minations about the health and environmental risks of such wastes in sewers.
Instead, EPA acknowledged that maintenance of the DSE was based solely on
Congressional intent. Congress, by requiring EPA to conduct the Domestic
Sewage Study, clearly has directed the Agency to revisit this issue.
1-2
-------
1.1.2 Legislative History
Analysis of the legislative history of the HSWA indicates that Congress
was interested particularly in having EPA evaluate the efficacy of the
interaction between the Nation's hazardous waste management and pretreatment
programs. Congressman Molinari (R.N.Y.), the sponsor of the amendment adding
Section 3018, characterized the Domestic Sewage Study as an effort:
... Quantifying, as accurately as possible, the nature and scope of
hazardous waste disposal into domestic sewers, including the types
of wastes and wastestreams; the extent to which the exclusion is
justified and should be modified or eliminated; and the adequacy of
pretreatment as a means of dealing with this proFlem lemphasis
added).
Congressman Molinari further clarified the intent behind the study by saying
that:
The purpose oj the study is to identify {gaps^currently in RCRA which
may threaten (gubliJjTeaJth) and the environment. My amendment wou 1 d
simply requi re tPAto review the discharge of hazardous wastes
listed under RCRA and estimate the scope of hazardous waste cur-
rently exempt from regulation....If the receiving publicly owned
treatment plants can handle the waste in a manner which adequately
protects human health and the environment, then regulatory change
will not be necessary (emphasis added)/1'
1.2 REGULATORY AND ENVIRONMENTAL BACKGROUND FOR THE DOMESTIC SEWAGE STUDY
(DSS)
Because the DSE occurs at the intersection of two major environmental
programs -- RCRA and the Clean Water Act (CWA), its regulatory and environ-
mental impacts are both extensive and complex. To understand these impacts,
it is important first to understand key RCRA and CWA features relevant to the
DSS. Table 1-1 summarizes and compares the RCRA and pretreatment programs.
The following sections present an overview of each program in terms of
regulatory approaches, affected regulatory communities, and environmental
concerns, and highlight the differences between the programs. More detailed
information on these programs is found in Chapter 6 of this report.
1-3
-------
TABLE 1-1. COMPARISON OF MAJOR COMPONENTS OF THE RCRA
AND PRETREATMENT PROGRAMS
PROGRAM AREA
PARTIES
REGULATED
POLLUTANTS/
MATERIALS
REGULATED
CONTROL
AUTHORITIES
TYPE OF
STANDARDS
EMPLOYED
PRETREATMENT
t 14,000 categorical Industries
{covering 22 Industrial
categories)
Unknown number of noncategorical
Industrial users
1,463 POTWs (comprising 80
percent of National POTW flow)
required to develop Federal
programs
All other POTWs
t 126 priority pollutants (metals
and toxic organlcs)
Nonconventlonal pollutants
t Pollutants regulated by
prohibited discharge standards
that may cause:
- Fire or explosion
- Corrosion (pH <5)
- Obstruction
- Interference
- Heat
- Pass through
Any other pollutant covered by
local limits
EPA HQ
EPA Regions
21 States have approved programs
1,278 POTWs have approved
programs
Categorical standards:
- Numerical limits for selected
126 pollutants and
nonconventionals
- Technology-based
- Production- or concentration-
based
Local limits:
- Numerical and absolute
prohibitions
t General and specific prohibitions
RCRA
56,000 HW generators (generators
<1000 kg/mo exempted)
12,500 HW transporters
4,800 HW treatment, storage, and
disposal facilities (TSDFs)
t Characteristic wastes that
exhibit one or more of the
following:
- Ignltability
- Corrosivity
- Reactivity
- EP Toxicity
Listed Wastes - covering
characteristic wastes, acute
hazardous wastes, and toxic
wastes (pollutants covered
include App. VIII 375 hazardous
constituents)
EPA HQ
EPA Regions
13 States have interim
authorization
33 States have pre-HWSA final
authorization
Standards for generators and
transporters are concerned
principally with handling waste
analysis and manlfestiny
TSDFs are subject to a variety of
operational and design standards
1-4
-------
TABLE 1-1. COMPARISON OF MAJOR COMPONENTS OF THE RCRA
AND PRETREATMENT PROGRAMS (Continued)
PROGRAM AREA
PERMITTING
MECHANISMS
RECORDKEEPING/
REPORTING
REQUIREMENTS
PRETREATMENT
t lUs discharging to about 1,500
pretreatment POTWs controlled by
"permit, contract, order or
similar means"
Other IUs may be permitted by
States, although no explicit
regulations currently exist
t POTWs regulated by Federal or
State NPDES permits
POTWs:
- Industrial Waste Survey - to
Identify IUs, pollutants, name,
address
- Discharge Monitoring Reports -
a NPDES reporting requirement
- PQTW Annual Report - annual
summary of pretreatment
activities
RCRA
TSDFs regulated by a two-phase
permitting system - Part A and
Part B permits
Permits-by-rule for certain
disposal practices, including HW
treatment at POTWs
Generators:
- Notify EPA - to obtain I.D. No.
- Maintain waste analysis records
- Maintain manifests for 3 years
- Submit Biennial Report -
covering generating activities
- Submit Exceptions Report - when
manifest not received
INSPECTIONS AND
SAMPLING
IUs:
- IWS response
- Permit application
- Baseline Monitoring Report
(within ISO days of cat. std.
effective date)
- Compliance Date Report (within
90 days of compliance date for
cat. std.)
- Self-monitoring reports
- Slug load notifications
Federal/State Inspections:
- Compliance Sampling Inspections
- Compliance Evaluation
Inspections
- Compliance Biomonitoring
Inspections
- Performance Audit Inspections
- Pretreatment program audits
- NPDES self-monitoring
Transporters:
- Notify EPA for I.D. number
- Comply with manifesting
regulations
TSDFs:
- Notify EPA for I.D. number
- Comply with manifesting
regulations
- Maintain waste analysis records
- Maintain operating records
- Submit Biennial Report on
wastes received, generators,
methods of treatment, storage,
etc.
Federal Inspections - primary
agent for RCRA enforcement
State Inspections - compliance
evaluation program
1-5
-------
TABLE 1-1. COMPARISON OF MAJOR COMPONENTS OF THE RCRA
AND PRETREATMENT PROGRAMS (Continued)
PROGRAM AREA
INSPECTIONS AND
SAMPLING
(Continued)
ENFORCEMENT
PRETREATMENT
POTW Compliance Monitoring
- Routine industrial demand
monitoring
- Compliance monitoring
- IU self-monitoring
Federal/State IU monitoring
(backup compliance sampling of
lUs)
Federal Authority:
- Civil penalties up to
$10,000/day per violation
- Criminal fines up to
$25,000/day and/or imprisonment
up to 1 year per violation
- Civil remedies
State Authority:
- Civil penalties up to
$5,000/day per violation
- Criminal fines up to
$10,000/day per violation
POTW's Authority:
- Typical penalties range from
$100 to $l»000/day
- Also emergency relief
RCRA
Federal Authority:
- Civil penalties up to
$25,000/day
- Criminal fines up to $25,000
($50,000)/day depending on type
and up to 1-2 years
imprisonment
- Knowing endangerment - criminal
fines up to $250,000 and
imprisonment for 2-5 years
State Authority:
- Interim Authorization - civil
or criminal up to $l,000/day
- Final Authorization - civil up
to $10,000/day per violation
and criminal up to JlO,000/day
per violation and at least 6
months imprisonment.
1-6
-------
1.2.1 The RCRA Program
Hazardous waste manayement under RCRA often has been characterized as
"cradle to grave" management. A firm yenerating solid wastes is required to
determine if such waste is hazardous (either a waste listed as hazardous by
EPA or which exhibits certain hazardous characteristics). Any generator of a
hazardous waste must notify EPA. If the generator chooses to move the waste
offsite for treatment or disposal, a paperwork trail (manifesting) must be
maintained by the generator, transporter, and the receiving treatment,
storage, or disposal facility (TSDF). Any wastes shipped offsite to be
treated, stored, or disposed of must be sent to an authorized hazardous waste
management facility, such as a secure landfill, treatment unit, or land
disposal facility. Wastes managed onsite (e.g., in wastewater treatment
units, incinerators, or surface impoundments), like those shipped offsite,
must be handled according to specific management and technical requirements in
RCRA. As shown in Table 1-1, there are approximately 56,000 generators and
4,800 TSDFs subject to RCRA.
1,2.2 The National Pretreatment Program
In contrast to RCRA, the National Pretreatment Program under the CWA has
a different charge the control of industrial wastewater discharges to the
Nation's sewers. There are approximately 15,000 POTWs that treat domestic,
nonresidential, and industrial wastewaters in the United States. While key
provisions of the National Pretreatment Program apply to all POTWs,
approximately 1,500 of these POTWs are required by the General Pretreatment
Regulations (40 CFR 403) to have Federally approved local pretreatment
programs. These facilities treat 82 percent of all industrial wastewater
discharged to POTWs and over 90 percent of wastewater from industries subject
to National categorical pretreatment standards (described below).
These POTWs must develop pretreatment programs because they meet one of
the following criteria:
1-7
-------
Design flow greater than five million gallons per day (mgd)
t Design flow of less than five mgd, but receive nondomestic wastes that
have caused treatment plant upsets, contaminated sludge, or violated
permit limits.
A local pretreatment program is designed to achieve four basic objectives:
(1) to prevent pass through; (2) to prevent plant interference; (3) to prevent
sludge contamination; and (4) to protect worker health/safety. To date, 1,278
POTWs have received EPA approval of their pretreatment programs.
The General Pretreatment Regulations establish two types of Federal
standards to control toxic wastewater discharges from lUs into treatment
plants: (1) prohibited discharge standards, and (2) categorical pretreatment
standards. Prohibited discharge standards apply to all industrial and
commercial establishments connected to all POTWs Nationwide. They prohibit
discharges that are flammable, explosive, or corrosive; obstruct flow; upset
treatment processes; or increase temperature. These standards are
particularly relevant to control the discharge of DSE wastes.
Categorical pretreatment standards originally were to be issued for 34
specific industrial categories and 129 pollutants. EPA subsequently exempted
several industries and pollutants from regulation. Currently, categorical
standards apply to 22 specific industrial categories and cover 126 priority
pollutants. These EPA-developedf industry-specific performance standards are
applicable to regulated firms no matter where they are located in the country.
EPA estimates that roughly 14,000 lUs nationally are subject to categorical
pretreatment standards.
RCRA and pretreatment overlap because many of these categorical lUs also
may be RCRA generators. For example, the largest industrial category subject
to pretreatment standards is the metal finishing industry. At the same time,
plating sludges from the metal finishing Industry are a listed hazardous waste
under RCRA.
1-8
-------
The pretreatment regulations also require that POTWs develop pollutant-
specific local limits to implement general prohibitions against pass through,
interference, and sludge contamination, as well as the specific prohibitions
identified in the prohibited discharge standards. Local limits apply to
affected lUs in the POTWs service area.
1.2.3 Comparison of RCRA and Pretreatment
Three major differences are apparent between the RCRA and pretreatment
programs. First, the two programs regulate pollutant discharges to different
environmental media. CWA protects the Nation's waters. To provide this
protection, the National Pretreatment Program regulates toxic pollutants in
wastewater and sludge. RCRA focuses on hazardous wastes in all environmental
media not only in wastewater and sludge, but also in ground water and air.
In addition to the pretreatment program, other statutes could potentially
minimize risks from the disposal of DSE wastes. The Clean Air Act (CAA),
Occupational Health and Safety Act (OHSA), the Safe Drinking Water Act (SDWA),
and the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) may operate to prevent harm to health and the environment. These
statutes are discussed in Chapter 6.
A second major difference between the RCRA and pretreatment programs is
the types of substances chosen for regulation toxic pollutants versus
hazardous wastes. Federal pretreatment standards are aimed primarily at the
control of 126 toxic pollutants. Although the pretreatment program emphasizes
these pollutants, EPA has established standards for other pollutants as well.
Further, municipalities can regulate additional pollutants through local
limits and prohibited discharge standards. In order to do so, a municipality
must engage in an analytical process to identify additional pollutants that
may interfere with plant operations, contaminate sludge, or pass through the
treatment system. To date, however, POTWs have not concentrated on hazardous
wastes.
RCRA, on the other hand, is oriented toward hazardous wastes. Wastes may
be deemed hazardous if they possess certain characteristics or if they have
been specifically listed by EPA. Listed wastes may contain one or more of 375
hazardous constituents.
1-9
-------
The third difference between RCRA and pretreatment is in Federal
responsibilities, in the former program, the Federal government retains a
much greater role in standards development, inspections, and enforcement.
States can receive RCRA program approval, but EPA continues to assert a
pervasive oversight role. RCRA places no responsibilities at the local level.
The pretreatment program, on the other hand, relies heavily on localities to
be principal actors in standard setting, inspections, and enforcement, making
use of POTW expertise on local conditions. EPA and approved States also may
exercise review and pretreatment oversight functions, but their involvement is
not intended to be as uniformly direct as in the RCRA program.
One last factor affects the interaction between RCRA and pretreatment,
namely the respective timiny of the development and implementation of these
programs. RCRA was passed by Congress in 1976 and its key implementing
regulations were promulgated from 198U-1982. The major thrust of toxics
control under the National Pretreatment Program was established in the CWA
Amendments of 1977; the General Pretreatment Regulations became final in
January 1981. The development of these programs basically has been
simultaneous. Thus, there has been little time to observe, analyze, and
respond in formulating pretreatment controls that address problems caused by
OSE wastes. This factor gives Special relevance to the DSS.
1-2.4 Potential Environmental Impacts Associated with USE Wastes
Congress expressed specific concern that existing regulatory controls on
DSE wastes may not adequately protect human health and the environment. As
indicated in Figure 1-1, the POTW receiving environment is quite broad and
impacts associated with DSE wastes potentially could affect all media. The
DSS identified six major impacts:
Water Pollution - which can occur as a result of improper POTW
operation and maintenance* It also can occur as a result of IU
discharges that bypass, pass through, or upset the treatment plant.
t Sludge Contamination - which can occur if Ills fall to remove
pollutants of concern from their discharges. As a result, the
municipality may be limited 1n Its disposal options.
1-10
-------
Collection System
Exfiltration
ft n ,4 Land Spreading
/
Groundwater
Contamination
Incineration
FIGURE 1-1. POTENTIAL PATHWAYS AND ENVIRONMENTAL IMPACTS
ASSOCIATED WITH DSE WASTES
1-11
-------
' Air Pollution - which can occur from volatilization in the collection
system or at the PUTW, or through incineration of sludges.
Worker Health and Safety - which can be jeopardized by industrial
discharges that result in explosions and worker exposure to toxics in
the wastewater, fumes, or sludge.
Overall POTU Operation - which may be adversely affected due to upset
and Interference problems caused by industrial discharges.
Ground Water Pollution - which may occur due to POTW sewer
exfiItratlon and leacftate from POTW sludge.
1.3 METHODOLOGY FOR THE DOMESTIC SEWAGE STUDY
EPA's approach to conducting the OSS followed directly from the language
of Section 3Q18(a), Three goals were established for the Agency's work:
Determine sources and amounts of hazardous waste being discharged to
municipal sewage collection systems.
Determine effects of hazardous waste discharges on POTWs, human
health, and the environment.
Evaluate current methods for the control of hazardous waste discharged
to municipal sewage systems at the Federal, State, and local levels.
1.3.1 Data Sources
In light of the time and resources available for the study, EPA had to
rely as much as possible on previously collected information and included
limited sampling and analysis data. Moreover, since Congressional interest
centered on a National evaluation rather than site-specific characterizations,
emphasis was given to the use of comprehensive National environmental data
bases. Guided by these considerations, EPA established a two-phased approach
to the study. In Phase 1 of the study (from March to June 1985), intensive
data collection and analysis occurred in order to judge the adequacy of
existing information and to design effective methods of analyzing data. Phase
II (from July to October 1985) consisted of interpretation of the information
collected.
1-12
-------
In Phase I, major existing data bases available in the Office of Solid
Waste (OSW) and the Office of Water were reviewed in detail. Table 1-2 lists
these 13 principal data sources. To supplement data available from OSW and
OW, several State, local, and industrial data sources were explored and used.
Selected States, EPA Regions, and municipalities were contacted for informa-
tion on hazardous waste discharges to POTWs. Permit files also were examined
and baseline monitoring reports from categorical Ills were analyzed. In addi-
tion, spills and enforcement information was solicited. Finally, data from
major pretreatment cities were provided by the Association of Metropolitan
Sewerage Agencies (AMSA), which conducted a survey of its membership on
hazardous waste issues.
All of these data sources -- both National and site-specific -- were
evaluated, both for their relevance to specific study questions and their
accessibility. Table 1-3 shows this evaluation of major data sources. The
two most complete sources for data were the Industry Studies Data Base (ISDB)
and the Industrial Technology Division (ITD) organic chemicals/pesticides data
bases.
1.3.2 Availability of Data
In Phase 1 of the study, several data characteristics were identified.
First, much of the available data were specific to different media (either
water or hazardous waste, but not both). Although RCRA and water data bases
contained extensive information on sources, wastestreams, management prac-
tices, fate, and effects relevant to their respective regulatory mandates,
this information could not be extended further. For example, ITD's data,
while containing excellent information on concentrations of constituents in
wastewaters, were largely restricted to the 126 priority pollutants and the
categorical industries. Information on solid wastes and hazardous waste
generation, nonpriority pollutants, and less traditional industries generally
was not available from water data sources, either Nationally or locally.
Conversely, hazardous waste data rarely contained constituent-specific
information {i.e., pollutant concentrations) and were much less rigorous when
water-related disposal practices were involved (e.g., discharge to sewers or
rivers). Thus, one of the methodological challenges, confronted throughout
1-13
-------
TABLE 1-2. PRINCIPAL DATA SOURCES USED IN THE STUDY
Office of Solid Waste Data
- ISDB - a large data base characterizing residuals from organic
chemicals and related industries
- Damage Incidents Data Base - a nationwide compilation of hazardous
waste mismanagement incidents
- Hazardous waste Data Management System - a large data base tracking
permit, compliance, and enforcement status of RCRA facilities
- National Survey of Hazardous Waste Generators and Treatment,
Storage, and Disposal Facilities - a survey containing waste
characteristic, quantity, and cost data on generators and TSDFs
- Small Quantity Generator (SQG) Survey - a data base profiling SQGs,
management practices, and quantities
- Constituent Hazard Classification System - a chemical effects data
base associated with ISDB
- Delisting Petitions Status Matrix System - an automated compilation
of delisting petitions with information on wastestreams.
Office of Water Data
- Existing ITD Data Bases and Monitoring and Data Support Division
(MDSD) Summary Sheets - survey and sampling results for regulated
and unregulated pollutants associated with development of water
regulations
- The 40 POTW Study Data - comprehensive POTW toxics sampling results
at 40 municipalities
- Other Municipal Wastewater Sampling Studies, including the 4 City,
25 City, 30 Day, Combined Sewer Overflow and Seattle Metro
Pretreatment Toxicant Study
- Pretreatment Regulatory Impact Analysis (RIA) Data - a data base
assembled to evaluate the effectiveness of the National
Pretraatment Program.
- Paragraph 4(c) Studies - containing data identifying municipal
nonpriority organic chemicals in industrial wastewaters
- NEEDS Data Base - the Construction Grants data base containing
survey profile information on POTWs.
1-14
-------
SL-L
*
»
-<
M
II
W
P-
CD
PT
u
r*
t*
Bt
M
a
&
B
PO
II
r
B
H-
r*
n
a
01
n
1
8
0
u
i
H»
R
i
n
d
«*
i
a.
«i
0
n
r
p
n
o
&
r*
Bi
1 NDSD Summary Sheets
'»
»
i
ro
**
!
»"
If
**
M
*
KJ
HlflHI
*
**
(*
*
*!
-
State Pretreatwnt/
Hazardous Haste Data
hj
ro
f~
*
r*
"
if
fs»
K>
N
M
Kl
^l^^B^m
*
^*
N)
S>
j
1 POW Industrial Data
»
»
M
M
k
h-
M
N
Ka
M
M
Kl
^M^^
*
N»
4
»
-
a|
S3
fS
«!
VI
*
*
»
If
»
If
If
*
If
If
»
*
M*M«^
N)
NX
If
S9
**
1
P
r
K>
K»
+
N
(«
*
»
If
w-
If
If
*
»
^«
*
M
| Seattle Metro
*
if
*
if
-
»
*
if
»
M
M
«
*
N)
H.
>H
**
V
1
i
s
*
*
»
*
H*
If
*
N)
M
N
If
K)
If
N>
1
t*
s
»
1
l»
p
If
*
If
If
fr
If
If
»
If
4
If
if
mfamm
M
hJ
N*
1
!
Hit
7
sr
r
s
M
to
M
MM
M
!-
1
If
*
M
M
M
M^H.
N)
*
w
IlTD Organic Cheaicals/
Pesticide Data Base
M
ls>
N*
*
M
M
t
^"
»
M
If
k»
1
M
Biennial Survey
»
»
if
if
if
if
»
#
if
*
if
N)
r-
1 Industry Studies Data
Base
**
**
** .
*-
»-
N
M
M
*
M
If
V*
»
N)
$
(M
*"
K>
N>
M
*
M
N)
N)
**
M
l-l
1 'Hazardous Haste Data
fbnageaent Systea
M
ls>
If
If
If
*
*
K)
M
N
ts}
KJ
N»
«-<
m
£
M
N
*
If
*
If
If
N) '
N
*
*
K>
V*
w-
1 X
U> v^
HuMber of Hazardous
Haste Generators
Hazardous Haste Type/
Quantity
Niafctr of Indirect
Dischargers
Hazardous Haste Type/
Quantity Discharged
to POTH
RCRA/PHorUy
Pollutants Detected
RCRA/PHoHty Pollutant
Concentratl on/Mass
Other RCRA Pollutants
Detected
Other RCM Pollutant
Concentratl on /Mass
TreatBent/Reaoval s
Major Organic
Generators
Nijor Met«l Generators
Fowl ators/Speclal ty
Chwlcal Users
Haste Management
Services
Servlces/SQG
Miscellaneous
RCW/Pr1orHy Pollutants
Detected at POTH
RCM/PrloHty Pollutant
Concentration/Mass at POTM
Other RCRA Pollutants
Detected at POTW
Other RCRA Pollutant
Concentration/Mass at POTH
POTM Fate/Effects
Availability
Recency
Computerized
Geographic Accessibility
Confidentiality
/
I
m
I
i
O
i
si
_=J
*8
gs
s
i
1
3
fi
S
5
m
S5
ja s
S
>
m
t
u*
m
5
£
m
-------
the DSS, was the selective merging of discrete data bases across programs to
arrive at meaningful National estimates.
A second consideration that affected this study was the lack of sampling
and analytical data on many of the wastes and compounds being studied. Data
on many of the organic compounds that may be hazardous and present in
municipal and industrial influents or effluents simply were not available.
This may, in part, be explained by the media-specific orientation of the data
bases discussed above. Likewise, the complexity, expense, and reliability of
analytical procedures also hinder efforts to detect and quantify the presence
of these substances.
A final consideration of the DSS, which particularly influenced the
methods and results of the fate and effects work, relates to a fundamental
lack of knowledge on the behavior and impacts of many hazardous constituents.
For example, little empirical data exist on the volatilization of toxic
organic compounds in POTW collection systems and treatment works. Similarly,
critical information on the basic kinetics of these compounds in treatment and
receiving environments has not yet been developed. In addition, a study of
the phenomenon of sewer exfiltration and its impacts on ground water has yet
to be undertaken. Thus, information central to a complete resolution of the
adequacy of controls on DSE wastes was lacking.
1.3.3 Central Study Approaches
These three considerations influenced EPA's approach to the study. In
view of these considerations, it was decided that the most appropriate
approach would be a traditional pollutant impact study. However, the DSS
would cover more pollutants, more industrial sources of hazardous discharges,
and more environmental effects than typically considered by the Agency. One
hundred and sixty-five pollutants were selected for the study from the
universe of about 400 hazardous/toxic pollutants. Chapter 2 explains the
methods followed to choose these pollutants. More industrial sources were
included, such as waste oil recyclers, hazardous waste landfills, Superfund
sites, and small quantity generators. In fact, the study examined 47 indus-
trial categories, 13 more than the 34 categorical industries historically
1-16
-------
considered in EPA's water regulatory evaluations. In addition, in order to
better integrate OSW and OW data bases, a different industrial categorization
was developed. Both the industries and the subcategorization scheme used in
the study are discussed in Chapter 3. Finally, efforts were made to examine
the impacts of DSE wastes on ground water and air (see Chapters 4 and 5).
When data were lacking in any of these areas, it was handled in one of
two ways. One way was simply to document the current state of knowledge and
additional lines of inquiry necessary. Such findings, in and of themselves,
should be useful to the Agency and Congress in assigning priorities for future
research.
The second way to handle lack of data was to employ, wherever possible,
theoretical work or best professional judgments to overcome data gaps. Thus,
pilot studies and basic research and engineering evaluations by the Water
Environmental Research Laboratory in Cincinnati (Office of Research and
Development) were used to produce estimates of the allocation of DSE wastes to
the various receiving environments -- air, water, sludge, etc. In addition,
since few criteria (e.g., water quality criteria or air toxics standards) are
in place to judge the impacts of releases of hazardous wastes, secondary
measures were used to allow for an intuitive assessment of the pathways and
the potential for deleterious effects. Examples of these measures include the
magnitude of mass released to the environment, ranges in concentrations of
releases, proximity to sensitive receptors (e.g., proximity to drinking water
intakes) and the number of facilities that may cause a particular problem.
Although the three considerations discussed above shaped the study's
approach, the basic objectives -- to determine the types, quantities, and
sources of hazardous wastes discharged to sewers and the adequacy of existing
controls -- never varied. Chapters 2 through 6 provide more detailed infor-
mation on the specific methods and data sources used to select pollutants for
study, and to perform the industrial, fate, effects, and regulatory analyses.
A bibliography of the principal data sources used in the OSS appears at the
end of this report.
1-17
-------
1.4 REPORT ORGANIZATION
The remainder of this Domestic Sewage Study report consists of six
chapters that parallel the statutory interests expressed by Congress in
Section 3018(a) of RCRA. The purpose and summary of each chapter is outlined
below.
Chapter 2 - DESCRIPTION OF HAZARDOUS WASTES AND POLLUTANTS STUDIED:
discusses the pollutant-specific approach and the reasons for
selecting 165 pollutants to study.
Chapter 3 - TYPES, QUANTITIES, AND SOURCES OF HAZARDOUS UASTES
DISCHARGED TO POTWS: presents the methods, data sources, and findings
of the characterization of the types, quantities, and sources of
hazardous wastes discharged to sewers; includes an analysis of
categorical industries, major organics dischargers, other potential
sources, and a production/use profile of hazardous wastes.
Chapjer 4 - FATE OF HAZARDOUS WASTES AND POLLUTANTS IN POTW COLLECTION
SYSTEM AND TREATMENT WORKS: summarizes methods, data sources, and
findings on the fate of hazardous wastes and pollutants in POTW
collection and treatment systems; emphasizes state of knowledge on
pollutant fate and concentrates on volatilization and exfiltration in
collection system and pass through, biodegradation, volatilization,
and sludge adsorption in treatment works; also considers potential for
POTW interference and ground water contamination as a result of
hazardous wastes in treatment works.
Chapter 5 - EFFECTS OF HAZARDOUS WASTES DISCHARGED TO POTWS: assesses
the environmental effects of hazardous waste discharges to POTWs;
characterizes loadings to POTWs and the POTW receiving environment
generally; assesses the availability of criteria to gauge impacts;
contains discrete impacts analyses for surface and drinking waters,
air and worker health/safety, and land and ground water.
Chapter 6 - EVALUATION OF GOVERNMENT CONTROLS ON HAZARDOUS WASTES
DISCHARGED TO SEWERS: explains in detail the existing RCRA framework
under which DSE discharges occur as well as CWA and other statutory
measures to regulate these wastes; also evaluates the effectiveness of
pretreatment Nationally and locally in controlling these discharges.
Chapter 7 - FINDINGS AND RECOMMENDATIONS:
recommendations of the technical study.
summarizes findings and
1-18
-------
CHAPTER 2
DESCRIPTION OF HAZARDOUS WASTES
AND POLLUTANTS EVALUATED IN THE STUDY
-------
-------
2. DESCRIPTION OF HAZARDOUS WASTES AND POLLUTANTS
EVALUATED IN THE STUDY
As discussed in Chapter 1, Section 3018 of RCRA required EPA to submit a
report identifying types, quantities, sources, and effects of hazardous wastes
discharged to POTWs under the Domestic Sewage Exclusion. Specifically, this
provision called on the Agency to examine "substances identified or listed
under [RCRA] Section 3001..." which are not regulated under RCRA due to the
domestic sewage exclusion (emphasis added). Section 3018(a) also required EPA
to Identify "wastes and waste constituents not regulated under existing
Federal law or regulated in a manner sufficient to protect human health or the
environment" (emphasis added). This statutory language reflects Congressional
Intent that the Domestic Sewage Study focus primarily on materials designated
as hazardous wastes and hazardous waste constituents under the RCRA program.
This chapter explains the study approach adopted to respond to the
statutory mandate. More specifically, it explains the methodology employed to
select representative-hazardous wastes/constituents for evaluation in the
study, and discusses the study pollutants and their key characteristics.
2.1 METHODOLOGY FOR THE SELECTION OF DSS POLLUTANTS
At first glance, the effort to identify pollutants relevant to the study
may appear straightforward. However, three factors complicated this exercise:
(1) the complexity of the regulatory process by which a solid waste is
identified as hazardous; (2) the sheer number of potentially hazardous
constituents refer'red to in RCRA regulations; and (3) data base limitations.
This section outlines the regulatory intricacies of RCRA's waste identifi-
cation process, which influenced the waste selection effort. It also
discusses the need to adopt a pollutant-specific approach and the specific
criteria employed to select compounds. Section 2.2 describes pollutants
included in this study.
2.1.1 Regulatory Definition of Hazardous Wastes
Section 1004(5) of RCRA defines hazardous waste as "a solid waste, or
combination of solid wastes, which, because of its quantity, concentration, or
physical, chemical,.or infectious characteristics, may:
2-1
-------
(A) cause, or significantly contribute to an increase in mortality or an
increase in serious irreversible, or incapacitating irreversible,
illness; or
(B) pose a substantial present or potential hazard to human health or
the environment when improperly treated, stored, transported, or
disposed of, or otherwise managed."
EPA has established two methods by which a solid waste may be determined
to be a hazardous.waste. First, if it exhibits one or more of four character-
istics, It 1s considered a characteristic waste under RCRA. Currently, the
four characteristics that qualify a material as a hazardous waste are:
Ignitability (40 CFR 261.21)
Corrosivity (40 CFR 261,22)
Reactivity (40 CFR 261.23)
.Extraction Procedure (EP) Toxicity (40 CFR 261.24).
.In each instance., the characteristic must be demonstrable..as measured by. a
standardized testing method or as determined by a generator's specific
knowledge of that solid waste. The Hazardous and Solid Waste Amendments of
1984 require EPA to reevaluate the EP-toxicity test and to develop other
hazardous waste characteristics.
Second, if the solid waste (or any part of it) is listed in 40 CFR
261.31-261.33, it is"commonly called a listed waste in RCRA regulations. The
Agency lists classes or types of solid waste as hazardous waste where it has
reason to believe that individual wastes, within the class or type of waste,
are typically or frequently hazardous. The RCRA regulations establish four
lists:
F-list -- hazardous waste from nonspecific sources, such as spent
cyanide plating baths from electroplating operations
K-list « hazardous waste from specific sources, such as leaded tank
bottoms from the petroleum refining industry
2-2
-------
P-list -- acutely hazardous commercial chemical products (including
off-specification species)
U-list toxic chemical commercial products (including off-
specification species).
To date, the Agency has listed 27 hazardous wastes from nonspecific sources on
the F-list in 40 CFR 261.31 and 82 hazardous wastes from specific sources on
the K-list in 40 CFR 261.32. The P- and U-lists include numerous commercial
chemical products or manufacturing intermediates that are considered hazardous
wastes if discarded in pure or dilute form.
The hazardous constituents in Appendix VIJI to 40 CFR 261 form one basis
for determining whether a specific pollutant is a listed waste. A chemical is
included in Appendix VIII if it is -shown, in reputable scientific studies, to
have toxic, carcinogenic, mutagenic, or teratogenic effects on humans or other
life .forms. Curreritly, there are 383 chemicals in Appendix VIII." Although
Appendix VIII is one criterion for designating a pollutant as hazardous, some
wastes appear on a list solely because they exhibit one or more of the
characteristics of a hazardous waste.
Two other RCRA provisions affect what material is considered hazardous
waste:
The mixture rule, which states that any solid waste that is a mixture
of a hazardous waste and a solid waste also may be a hazardous waste.
In the case of a listed hazardous waste [see 40 CFR 261.3(a)(2)(iv)j,
a waste mixture must be handled as a hazardous waste unless the
mixture is specifically delisted by the Agency. In the case of a
characteristic hazardous waste [see- 40 CFR 261.3(a)(2)(iii)], a waste
mixture need not be handled as a hazardous waste if it does not
exhibit any of the characteristics of hazardous waste.
The treatment rule, which specifies that any hazardous waste that is
treated may remain a hazardous waste [see 40 CFR 261.3(c)(l)]. In the
case of a listed hazardous waste [see 40 CFR 261.3(dj(2)L a treated
hazardous waste remains a hazardous waste unless it is specifically
delisted by the Agency. In the case of a characteristic hazardous
waste [see 40 CFR 261.3{d)(l)], the treated hazardous waste remains a
hazardous waste only if the waste continues, after treatment, to
exhibit any of the characteristics of hazardous waste. Residuals from
the treatment, storage, or disposal of listed or characteristic
hazardous wastes are regulated in an analogous manner under RCRA
2-3
-------
regulations [see 40 CFR 261.3(c)(2) and 261.3(d}]. Treated hazardous
wastes discharged by point sources regulated under Section 402 of the
Clean Water Act are not considered hazardous [see 40 CFR 261.4(a)(2)].
Although both characteristic and listed hazardous wastes are included in this
study, it is necessary to recognize that the mixture and treatment rules could
operate to alter technically the classification of some wastes as hazardous.
2.1.2 Rationale for Pollutant-Specific Study Approach
Recognizing these regulatory considerations, EPA faced -a very basic
decision; namely, deciding upon an approach to the study. Two approaches were
possible: the study could examine wastestreams and types (the subjects of
RCRA regulation) or the study could emphasize specific pollutants (the Clean
Water Act's focus). Based on an extensive evaluation of existing water and
hazardous waste data sources, the pollutant-specific approach was chosen.
Thus,vthe study's approach was to evaluate mass loadings to PQTUs of specific
pollutants and waste constituents (such as benzene, tetrachloroethylene, or
cyanide). The decision to use this approach derived from four specific
considerations:
Lack of data on types and quantities of generic RCRA wastes discharged
to POTWs
Availability of priority pollutant data for categorical industries in
the Office of Water
Uncertainty in the estimates of waste quantities due to the mixture/
treatment rules under RCRA
Need for evaluation of the fate and effect of pollutants in POTW
collection and treatment systems.
Each consideration is discussed below.
2.1.2.1 Lack of Data on the Discharge of RCRA Wastes
Due to the widespread belief that the DSE provides a blanket exemption
from notification requirements, most generators have not notified EPA and
States of hazardous waste discharges to POTWs. Moreover, even where notifi-
cation has occurred, data generally have not been collected and organized, in
2-4
-------
Federal, State and local data bases, in a manner that allows effective
evaluation. Consequently, traditional notification data provide neither
comprehensive nor representative information on types and quantities of
hazardous waste discharged to POTWs. Recognizing the considerable effect of
the DSE on industry notification practices, Congress enacted Section 3018(d)
of the 1984 RCRA Amendments, which extends RCRA notification requirements to
generators discharging hazardous wastes to POTWs. This provision, however, has
not yet yielded significant data for use in the DSS.
Difficulties in relating RCRA data to this study are somewhat heightened
by the lack of data on concentrations of specific waste constituents in RCRA
wastes. While the extent of waste sampling has increased, many available RCRA
background and listing documents contain minimal data on constituent concen-
trations of listed wastes. Without these data, generic waste loadings (e.g.,
degreasing solvents, electroplating bath solutions) could not be readily -
*-., * '
converted to loadings of specific pollutants (e.g.; tet'rachloroethylene,
cyanide). Data on.pollutant loadings are-essential for the proper evaluation
of pollutant fate and effect within POTW systems and the receiving
environment.
Notwithstanding the limitations of the RCRA data sources as they relate
to the DSE, some RCRA data bases did provide useful information on the
discharge of RCRA characteristic and listed wastes to sewers. Where this type
of data exists (such as in the Industry Studies Data Base and the Small
Quantity Generator Data Base), pertinent data are presented in this report.
2.1.2.2 Availability of Priority Pollutant Data
As part of the 1976 Consent Decree between EPA and the Natural Resources
Defense Council, EPA agreed to promulgate technology-based standards for 65
toxic compounds or classes of toxic compounds for 34 categories of industry.
One hundred and twenty-nine priority pollutants subsequently were selected by
EPA from the original 65 compounds. The number of priority pollutants was
later reduced to 126'when three of the original 129 pollutants were removed
from consideration. Section 2.1.3.4 provides further background on these
priority pollutants.
2-5
-------
Because of this Consent Decree, the Office of Water began a thorough
examination of the priority pollutants and the industries that discharge them.
The Office of Water's Industrial Technology Division (formerly the Effluent
Guidelines Division) undertook extensive surveys and sampling to compile
information on these pollutants and industries. The availability of such
detailed and comprehensive priority pollutant data was another reason that the
pollutant-specific approach was adopted.
2.1.2.3 Uncertainty Relating to RCRA Mixture/treatment Rules .
Efforts to quantify POTW loadings of RCRA wastes, both listed and
characteristic, are greatly complicated by the uncertain application of RCRA
mixture/treatment rules to industrial user practices. As mentioned earlier,
under the mixture rule, a listed waste that is.diluted remains a listed waste.
Accordingly, where a wastewater 'contains a listed waste, the entire wastewater
becomes a' listed hazardous waste. Because process wastewaters are often mixer4
with high-volume nonprocess wastewaters (e.g., cooling water, sanitary
wastewaters, etc;-) 'prior to discharge to 'a POTW," strict" a'pp'Tication of the
mixture rule in these situations results in the generation of massive
quantities of dilute hazardous waste. Thus, any failure to consider and
relate the possible effects of dilution on hazardous waste generation rules
can easily result in confusing and misleading estimates for hazardous waste
loadings of listed wastes.
. In the case of a -characteristic hazardous waste, a diluted or treated
waste does not have to be handled as a hazardous waste unless it continues to
exhibit any of the hazardous characteristics. Consequently, for the purposes
of evaluating the DSE, wastewater characteristics are more appropriately
evaluated at the point of discharge to a municipal collection system, after
dilution and/or treatment have occurred. In the absence of sampling data on
wastewater characteristics at this point of discharge, it is difficult to
determine whether the wastestream discharged to the POTW should be considered
a hazardous waste under the Domestic Sewage Exclusion.
For one set of industries, the Organic Chemicals Industry, EPA used waste
estimates (available from the ISDB) of concentrated hazardous wastes.generated
2-6
-------
by industry in production processes and prior to treatment and mixture with
wastewaters. This eliminated uncertainties about the effects of treatment and
dilution on the accuracy of waste estimates. Where this approach is used in
the DSS, resulting estimates are impossible to compare with previous EPA OSW
hazardous waste estimates (e.g., Westat/RIA or SQG data bases).
2.1.2.4 Need to Evaluate Pollutant Fate and Effect
Data on loadings of specific pollutants and waste constituents are
essential for the proper evaluation of pollutant fate within POTW collection
and treatment systems an'd pollutant effects on POTW operations, human health,
and the environment. These analyses are strongly dependent upon examination
of physical, chemical, and toxicological properties of specific waste
constituents. Observations concerning fate and effects of specific waste
constituents then can be applied to generic RCRA wastes containing these con-
stituents. A final benefit of this approach is that it enabled pollutant-
specific results-to be converted into waste type aggregations (e.g., con-
solidating all of the volatile organic results to make an estimate of
characteristic hazardous waste due to ignitability).
2.1.3 Methodology for Pollutant.Selection
Having made the decision to follow the specific pollutant approach, it
was then necessary to identify the specific constituents that would be
included in the study. Five classes of pollutants regulated under RCRA and
CWA were reviewed to identify the appropriate universe of pollutants for the
study:
RCRA Appendix VIII Hazardous Constituents
RCRA Appendix VII Hazardous Constituents
t RCRA Characteristic Hazardous Wastes
CWA Priority Pollutants
Pesticides.
.
The following subsections briefly describe the five classes.
2-7
-------
2.1.3.1 RCRA Appendix VIII Hazardous Constituents
The initial Appendix VIII hazardous constituent list was promulgated as
part of the May 19, 1980 RCRA regulations Implementing the RCRA program. EPA
reviewed the following sets of chemicals for possible Inclusion 1n the
Appendix VIII list:
Pesticides cancelled for some or all uses, or undergoing Rebuttable
Presumption Against Registration (RPAR) procedures under the Federal
Insecticide, Fungicide and Rodentldde Act (FIFRA)
Chemicals listed as poisonous by Department of Transportation (DOT)
regulations
Pollutants included in the CWA priority pollutant list
Chemicals found to be actual or potential human carcinogens by the
International Agency for Research on Cancer.
These substances were reviewed to determine whether they met the listing
criteria specified. In .the RCRA. regulations (see 40 CFR 261.11 and discussion
below). The Agency examined diverse toxicological materials (such as RPAR
documentation, Cancer Assessment Group materials, and data from the National
Institute of Occupational Safety and Health Registry of Toxic Effects) to
final determinations on specific chemicals.
Appendix VIII has been expanded since the original May 19, 1980
rulemaking, which listed 359 chemicals. There are now 383 chemicals and
chemical classes on the Appendix VIII list, including a preponderance of the
CWA priority pollutants. Moreover, the Agency has proposed a significant
expansion of the Appendix VIII list by adding the so-called "Michigan
chemicals list" (see 49 FR 49784). If promulgated as proposed, this
regulation would add 120 new chemicals to Appendix VIII.
The Appendix VIII list has considerable regulatory importance for the
RCRA program. First, Appendix VIII chemicals may be cited as a basis for
listing toxic wastes. 'Second, when evaluating delisting petitions, the Agency
must consider any Appendix VIII constituent {including constituents other than
those for which a waste is listed) that may cause a waste to be a hazardous
2-8
-------
waste. The Agency also may require RCRA permittees to perform ground water
and air monitoring for Appendix VIII constituents.
2.1.3.2 RCRA Appendix VII Hazardous Constituents
The Appendix VII list is a subset of Appendix VIII. It identifies
constituents that are the basis for placing wastes on the F-list (from
nonspecific sources) and the K-list (from specific sources). Currently, there
are 114 constituents on the Appendix VII list.
2.1.3.3 RCRA Characteristic Hazardous Wastes
In some instances, the Agency has listed wastes that exhibit hazardous
characteristics. For example, certain spent solvents are listed wastes solely
because they contain ignitable constituents, such as xylene, acetone,'or ethyl
acetate. This set of ignitable, corrosive, reactive, and EP-toxic chemicals
also vas included in the universe of pollutants reviewed for the study.
2.1.3.4 .CWA Priority Pollutants
The CWA priority pollutant list originally was developed during negoti-
ations between the Natural Resources Defense Council (NRDC) and EPA. It was
incorporated as part of a settlement agreement that ended litigation over the
toxics control provisions of the 1972 Federal Water Pollution Control Act
(FWPCA) amendments [NRDC v. Train, 8 ERC 2120 (D.D.C. 1976), modified March
1979, October 1982, August 1983, January 1984, July 1984, and January 1985].
Commonly referred to as the "NRDC Consent Decree," this agreement required EPA
to promulgate'technology-based standards addressing 65 compounds or classes of
compounds (Appendix A of this report lists these compounds). This list of
toxic pollutants subsequently was adopted by Congress in the 1977 CWA
amendments.
The list of 65 compounds and classes of compounds were chosen on the
basis of three different sets of criteria:' '
Known occurrence of these compounds in point source effluents, in
aquatic environments, in fish, and/or drinking water
2-9
-------
Substantial evidence of carcinogenicity, mutagenicity, and/or
teratogenicity in human epidetniological studies or in animal bioassay
systems
Likelihood that point source effluents contribute substantially to
human hazards, at least locally.
Section 307(a){l) of the Clean Water Act directed EPA to publish the list
of 65 toxic pollutants. The Agency published this list on January 31, 1978
(see 43 FR 4109). Section 307(a) also authorized EPA to revise the list from
time to time. The statutory criteria for such revisions are:
Toxicity of pollutant
Persistence
Oegradability
Usual or potential presence of the affected organism
« Importance of affected organisms
Nature and ex-tent of the effect of the toxic pollutant on such
organisms.
Since the list of 65 toxic pollutants includes very broad categories or
classes (e.g., chlorinated benzenes, DDT and metabolites, haloethers, etc.) as
well as specific compounds, the list actually could encompass hundreds of
compounds. To facilitate the evaluation and control of these toxics, EPA
believed that it should focus on specific compounds within the classes.
Therefore, the Agency developed a list of 129 individual priority pollutants
from the list of 65 compounds or classes of compounds. EPA also established a
set of criteria that may be used to support a petition to revise the list (see
44 FR 18279). Briefly, these criteria are:
t Toxicity of the pollutant, including acute toxicity (LC~50s); maximum
acceptable concentration; embryo-larval and egg-fly tests; dose-
related lethal or chronic sub-lethal effects; and information on
carcinogenicity, teratogenicity, and mutagenicity
Persistence of a pollutant, including its mobility and degradability
in water
t Bioconcentration, bioaccumulation, and biomagnification of a pollutant
or of its degradation prap-e-rties and effects of the pollutant
2-10
-------
Synergistic propensities and effects of the pollutant
Water solubility and octanol-water partition coefficient
determinations for the pollutant
Extent of point source discharges into water, including qualitative
presence and quantitative concentrations of the pollutant in
effluents, ambient water, benthic sediments, fish, and other plant and
animal aquatic organisms
Potential exposure of persons to the pollutant through drinking water,
fish, or shellfish consumption; identical exposure of aquatic
organisms and wildlife to the pollutant
Annual production of the pollutant In the United States
Use patterns
Capability of analytical methods to identify and quantitatively
determine the pollutant's presence in ambient water or wastewaters.
Since" January 1978, the priority pollutant list has been reduced to 126
compounds, with the elimination of dichlorodifluoromethane, trichlorofluorp-
methane, and bis (chloromethyl ) ether (see 40 FR 2266 and 46 FR 10723).
Paragraph 4(c) of the Consent Decree [added in March 1979 (NRDC v.
Costle, 12 ERC 1833, March 9, 1979 D.D.C.)] also requires EPA to identify and
regulate pollutants, other than the priority pollutants, which interfere with,
pass through, or are otherwise incompatible with a POTW. At a minimum, EPA
was required to evaluate 12 additional compounds and compound classes
specified in Appendix C of the Consent Decree. After extensive evaluation of
analytical data derived from CWA rulemakings, EPA established a Paragraph 4(c)
(2)
list containing six nonpnority organic pollutants. ' These pollutants are
carbazole, 1,2,3-trichlorobenzene, 2,4,5-trichlorophenol , 1,4-dioxane,
dibenzofuran, and 2,3,6-trichlorophenol .
2.1.3.5 Pesticides
Four general classes of pesticides were reviewed for possible inclusion
in the DSS:
2-11
-------
I. Phosphorus-containing
11. N1trogen-contai ni ng
III. Halogen-containing
IV. Miscellaneous.
Table 2-1 shows the pesticide classification system used 1n the study.
Pesticides chosen represent all four classes.
The Initial DSS pollutant universe drawn from RCRA and CWA encompassed
over 475 specific compounds, including RCRA Appendix VIII hazardous constit-
uents and other compounds listed under RCRA regulations (e.g., F-list wastes,
P-list wastes, etc.) solely because of their hazardous characteristics (see
Appendix B for pollutant descriptions). This initial pollutant universe did
not include proposed RCRA hazardous constituents (i.e., Michigan chemicals),
although certain proposed constituents (e.g;, styrene) were added to the OSS
pollutant list based on a subsequent review of industrial and POTW sampling
data.
2.1.3.6 Selection of DSS Pollutants
The goal behind the selection of DSS constituents was to ensure the most
comprehensive coverage of study pollutants. EPA wanted to choose those
RCRA hazardous wastes that would include significant sources of DSE wastes and
to characterize accurately the nature of- those wastes. 'To accomplish this, .
the following five general factors were used to evaluate specific pollutants:
Regulatory Status: The regulatory status (such as priority pollutant,
or listed or characteristic hazardous waste) of each constituent to be
studied was important to ensure that a representative cross-section of
all CWA and RCRA regulated pollutants/hazardous wastes was included.
Magnitude of National Production: Congress expressed an interest in
significant sources.Therefore, compounds for which National produc-
tion rates are high (as opposed to specialty chemicals) were used.
Waste Generation by Specific Industries: Pollutants in the
wastestreams of industries known to be large waste generators were of
particular interest since these may be more likely to appear in
sewers. Other pollutants were selected because of their association
with industries known to be industrial users.
2-12
-------
TABLE 2-1. PESTICIDE CLASSIFICATION SYSTEM
Pesticide Class
Typical Pesticides
in Each Chemical Class
I. Phosphorus-Containing Pesticides
(1) Phosphates and Phosphbnates
(11) Phosphorothioates
(i i i) Phosphorodi thi oates
(iv)
Other Organophosphates
Mevlnphos, TEPP, Azodrin, Dichlorvos,
Bidrin, Naled
Diazinon, Methyl"Parathion, Parathion,
Demeton, Oursban, Fenthion, Zinophos,
Dasanit
Disulfoton, Phorate, Malathion, Guthion,
Ethion, Trithion
Ruelene, DEF Defoliant, Folox
II. ^ Nitrogen-Containing Pesticides
(i) Carbamates, Thiocarbamates , and
Dithiocarbamates -
(ii) Amides, Anilides, Imides, and
Hydrazides
(iii) Ureas and Uracils
(iv) Triazines
(v) Amines, Nitro Compounds, and
Quaternary Ammonium Compounds
(vi) Other Nitrogen-Containing Compounds
Carbaryl; Aldicarb, Carbofuran, Bux Ten,
Sutan, Eptam, Maneb, Perbam, Zineb
Diphenamid, Alachlor, Randox, Propachlor,
Captan, Difolatan, MH
Diuron, Linuron, Monuron, Bromacial
Atrazine, Propazine, Simazine
Picloram, Trifluralin, Benefin, Nitralin,
Dinoseb, Diquat, Paraquat
Antu, Dodine, Naptalam
III. Halogen-Containing Pesticides
(i) DDT and Related Compounds
(i i) Chiorophenoxy Compounds
(iii) Aldrin-Toxaphene Group
(iv) Dihaloaromatic Compounds
(v) Highly Halogenated Compounds
Methoxychlor, Chlorobenzilate, Dicofol
2,4-D, Silvex, 2,4,5-T, MCPA
Chlordane, Toxaphene, Endrin, Heptachlor
Amiben, Paradichlorobenzene, Banvel
Pentachlorophenol, Fenac, Dacthal
IV.
Miscellaneous Pesticides
Warfarin, Endothall, Fumarin, Rotenone,
Pyrethine, Sodium Fluoroacetate, Omite
2-13
-------
Exertion of Specific Effect: To determine the impact of hazardous
wastes on POTWs, pollutants exhibiting specific effects (such as
corrosivity, ignltability, or toxicity) were selected.
Data Availability: Since there was a stated interest in the fate and
effect of DSE discharges, constituents that have been measured
routinely in industrial/municipal wastestreams yielded particularly
good data for review.
Using these 5 factors, EPA selected 165 pollutants for study, all but 15
of .which are RCRA constituents. Thirty-eight pesticides were included, 22 of
which are either currently regulated under RCRA or proposed to be regulated
under RCRA.
The final DSS pollutants were grouped Into four categories to facilitate
analysis: Tier 1, Tier 2, Tier 2A, and pesticide pollutants. The Tier 1
pollutants consist of EP-toxic metals and F-list solvents. Tier 2 pollutants
include other pollutants that are regulated extensively under RCRA hazardous
waste regulations and are used and discharged by a wide range of industries.
These two sets were selected, 1n particular, to aid in the evaluation of
discharges by "nonorganlcs" industries/ ' Tier 2A pollutants represent
additional constituents detected 1n discharges from organic chemical Indus-
tries. Tier 2A and pesticide-pollutants were chosen later in the study to
enable a more detailed investigation of the organlcs industries. Figure 2-1
provides an overview of the Interrelationship between the various pollutant
selection procedures and key study components. The 'specific reasons behind.
each pollutant grouping.are discussed below.
Tier 1 and 2 Pollutants. Tier 1 and 2 pollutants were selected because:
RCRA Regulatory Status - The Tier 1 pollutant set consisted of
EP-toxic metals and F-list spent solvents. Also, Appendix VII
constituents were included since they actually had been cited as a
basis for listing F- or K-hazardous wastes.
Availability of Data - A substantial cross-section of CWA priority
pollutants were included because all priority poUutants were also
RCRA hazardous constituents and because priority pollutant data are
extensively collected by POTW and industrial facilities.
2-14
-------
Review of the
Universe of
DSS Pollutants
(ALL RCRA Pollutants)
i
Tier 1 and 2
Pollutants
(107 Pollutants)
Evaluation of
Non-organics Industries
(107 Pollutants)
Evaluation of
Organics Industries
(All RCRA Pollutants)
Tier ZA
Pollutants
(20 Pollutants)
Pesticide
Pollutants
(38 Pollutants)
y
Evaluation of Pollutant
Fate and Effect
Hi thin POTW
(165 Pollutants)
FIGURE 2-1. SCHEMATIC DIAGRAM SHOWING THE INTERRELATIONSHIP BETWEEN
POLLUTANT SELECTION PROCEDURES AND KEY STUDY COMPONENTS
2-15
-------
Characteristic Wastes - Compounds exhibiting hazardous characteris-
tics, especially ignitabiHty, were given special consideration to
enhance coverage of characteristic wastes.
End Use by Nonorganics Industries - Special preference was given to
compounds that may be used widely by nonorganics industries. These
compounds include solvents, plasticizers, preservatives, disinfec-
tants, refrigerants, lubricants, etc. This criterion was designed to
exclude compounds used predominantly as pesticides or as dye,
chemical, or pesticide intermediates in the organics industries.
Production Rate - Chemicals produced at higher rates were given higher
priority.
40 POTW Study Detection Frequencies - Pollutants detected with greater
frequency m HUTW influents, based on sampling/analytical data from
the 40 POTW study, were given higher priority.
Sampling/Analytical Considerations - To facilitate related POTW and
industrial sampifng efforts for-the study, pollutants for which
adequate sampling/analytical procedures and standards already exist
were included.
Most data used for the "pol lutant evaluation are provided tn pollutant
descriptions contained in Appendix B.
Tier 2A pollutants. Tier 2A pollutants consisted of pollutants dis-
charged to POTWs by organic industries. The Tier 2A pollutant list was
intended to supplement Tier 1 and 2 sets with the addition of chemicals known
to be discharged, in significant quantities, to POTWs by organi.c industries.
Discharge data from the ISDB were reviewed to identify Tier 2A pollutants.
Many compounds were not Included as Tier 2A pollutants only because they
already were listed as Tier 1 or 2 pollutants.
Pesticide Pollutants. Selection criteria for the pesticide pollutants
were:
Representative of Diverse Pesticide Classes - Pesticides were chosen
to represent adequately the range of pesticide functional classes.
Functionality was selected as the first selection criterion since
toxicity has been shown to correlate with chemical structure. For
example, broad pesticide classes of insecticides, herbicides, and
fungicides tend to exhibit decreasing toxlclty, respectively. The
representation of the 16 basic classes of pesticides was especially
important for pollutant fate and effect analyses.
2-16
-------
Used or Produced in U.S. - The pesticide set also was selected based
upon production volume and projections of future use in the United
States. For each pesticide functional class, several pesticides were
chosen based upon production volume and present discharge levels to
POTWs. These pollutants, because of their production volumes, are
expected to represent the bulk of potential environmental damage.
Existing/Proposed RCRA Waste - Where possible, pesticides selected
were either existing or proposed RCRA Appendix VIII hazardous con-
stituents. Several of the remaining pollutants were included for
functional completeness by using the ITD list of nonconventional
pesticides from the final promulgated effluent standards and
limitations for the pesticide manufacturing and formulating industry.
Using the appropriate selection criteria for the four lists, 165
pollutants were selected for examination in the Domestic Sewage Study.
Section 2.2 describes these pollutants.
2.2 DESCRIPTION OF DSS.POLLUTANTS
v
Table 2-2 lists the 165 DSS pollutants. It also identifies CWA priority
pollutants and indicates which pollutants were-considered-to b-e volatile or
ignitable/reactive. Table 2-3 summarizes the regulatory status of DSS
pollutants by indicating regulatory authorities to which the pollutants are
*
subject. Figure 2-2 profiles these DSS pollutants. As can be seen, the
qverwhelming majority of pollutants (121 constituents or 73 percent) are RCRA
Appendix VIII constituents. In decreasing order of size, RCRA Appendix VII
hazardous waste constituents account for 74 pollutants (45 percent), CWA
priority pollutants 67 pollutants (41 percent), and RCRA characteristic wastes
are represented by 41 constituents (25 percent).
Figure 2-3 describes the extent to which key RCRA and CWA pollutant lists
are represented in the DSS pollutant list. As demonstrated in the figure, 74,
or 65 percent, of all RCRA Appendix VII hazardous constituents are included,
while 121, or 32 percent, of all RCRA Appendix VIII hazardous constituents are
included in the DSS pollutant list. These results show the representativeness
of RCRA pollutants studied. CWA pollutants also are well-represented with 67,
or 53 percent, of all priority pollutants selected for study.
2-17
-------
TABLE 2-2. LIST OF TIER 1, 2, 2A, AND PESTICIDE POLLUTANTS
FOR THE DSS
Tier 1 - EP Toxic Metals and F-list Solvents (34 Pollutants
Acetone - I/R, V
Arsenic and Compounds - P
Barium and Compounds
N-Butyl Alcohol - I/R
Cadmium and Compounds - P
Carbon Disulfide - I/R, V
Carbon Tetrachloride - P, V
,hlorobenzene - P, I/R
Chromium and Compounds - P
Cresols (3 isomers)
Cyclohexanone - I/R
1,2-Dichlorobenzene - P
Dichlorodifluoromethane - V
Ethyl Acetate - I/R, V
Etnyl Benzene - P-, 1/R-* V -
Etnyl Ether - t/R , V
Isobutanol - I/R
Lead and Compounds - P
Mercury and Compounds - P, V
Methanol - I/R, V
Methyl Ethyl Keto/ie - I/R, V
Methyl Isobutyt Ketone * I/R
Methylene Chloride - P, V
Nitrobenzene - P .
Pyrldine - I/R, V
Selenium and Compounds - P
Silver and Compounds - P
Tetrachloroethylene - P, V
Toluene - P, I/R, V
1,1,1-Trichloroethane - P, V
Trichloroethylene - P, V-
Trichloronuoromethane - V
l,l,2-Trichloro-l,2,2-Trifluoroethane - V
Xylenes {3 isomers) - I/R, V
Tier 2 - Selected RCRA Pollutants (73 Pollutants/
Acetaldehyde - I/R, V
Acetonecyanohydrin - I/R
Acetonitrile - I/R, V
Acetophenone - V
Acetyl Chloride - I/R, V
Acrolein - P, I/R, V
Aniline - I/R
Antimony and Compounds - P
Benzene - P, I/R, V
p-Benzoquinone
Benzyl Chloride
Bis-(2-Ch1oroethoxy) Methane - P
Bis-(2-Cnloroethyl) Ether - P, I/R,
Bis-(2-Ethyl Hexyl} Phthalate - P
Bromomethane - P, V
Butyl Benzyl Phthalate - P
P * CWA priority pollutant
I/R - Ignitable or reactive compound
V = Volatile compound
. 2-18
-------
TABLE 2-2. LIST OF TIER 1, 2, 2A, AND PESTICIDE POLLUTANTS
FOR THE OSS (Continued)
Her'2 - Sel_e_cted_RCRA Pollutants (73 Pollutants)
p-Chloro-m-Cresol - P
Chloroethane - P, I/R, V
Chloroform - P, V
Chloromethane - P, J/R, V
2-Chloronapthalene - P
Cumene - I/R, V
Cyanide - P, I/R
Cyclohexane - I/R, V
Di-N-Butyl Phthalate P
1,3-Dichlorobenzene - P
1,4-Dichtorobenzene - P '
1,1-01 Chloroethane - P, I/R, .V
1,2-Dichloroethane - P, I/R, V
1,1-Dichloroethylene - P, I/R, V
Trans-l,2-Dichloroethylene - P, I/R, v
2,4-Dichlorophenol - P
1,2-Dichlorbpropane - P, I/R, V
Dichloropropanol
Diethyl Phthalate - P
Dimethyl amine - I/R, V
2,4-Dimethyl Phenol - P
Dimethyl Phthalate - P
Di-N-Octyl Phthalate - P
l.4-01oxane - I/R
Diphenyl Amine
Epichlorohydrin - I/R, V
Ethylene Oxide - I/R, V
Formaldehyde - I/R, V
Formic Acid, V
P « CWA priority pollutant
I/R » Ignltable or reactive compound
V - Volatile compound
Furan - I/R, V
Furfural - I/R, V
Hexachloro-l,3-Butadiene - P
Hexachloroethane - P
Hydrazlne - I/R, V
Napthalene - P
Nickel and Compounds - P
2-Nitropropane - I/R, V
N-Nitrosodimethyl Amine - P
PCB - P
Pentachloroethane
Pentachlorophenol - P
Phenol - P
Phenylene Diamine
2-Picoline - V
Resorcinol
Tetrachlorobenzene
1,1,1,2-Tetrachloroethane - V
1,1,2,2-Tetrachloroethane - P,
Tetrahydrofuran - I/R, V
Thiourea
Thiram
Trlbromomethane - P
l,2,4*Trichlorobenzene - P
1,1,2-Trichloroethane - P, V
2,4,6-Trichlorophenol - P
1,2,3-Tricnloropropane
Vinyl Chloride - P, I/R, V
2-19
-------
TABLE 2-2. LIST OF TIER 1, 2, 2A, AND PESTICIDE POLLUTANTS
FOR THE OSS (Continued)
Tier 2A - Additional RCRA Pollutants Discharged by Organlcs Plants
(20 Pol1uta"ntsT
Acenaphthylene - P
Acrylamide
Acrylic Add - I/R
Acrylonitrile - P, I/R, V
Anthracene - P
Benzal Chloride
Benzotrichloride - I/R '
2-Chlorophenol - P
Dlbromomethane - V
3,3-Dintethoxy Benzidine
2,4-Dinftrophenol - P
Ethyl ene Thiourea
Malelc Hydrazlde
Methanethiol - I/R, V
p-N1troanil1ne - I/R
Phosgene - V
Phthalic Anhydride
Styrene - I/R, V
Toluene Diamlne
Vanadium Pentoxlde
Pesticides List - Representative Sample of Pesticides Used and Produced In U.S.
(38 Pollutants!! '
Alachlor
Aldicarb
Aldrin - P
Antu
Atrazine
Bromacl1
Captan
Carbofuran
Chlordane - P
Chtorobenz11ate
2,4-D
2,4-DB
Diazinon
Dichlorvos
Dicofol
Dinoseb
Diphenamid
Disulfoton
Diuron
Endrin - P
Penthi oh
Ferbam
Folex
MCPA
Methoxychlor
Mevinphos
Naled
Naptalam
Oxamyl
Parathlon
Parathion Methyl
Phorate
Pyrethrins
Sodium Fluoroacetate
Stirofos
2,4,5-T
Toxaphene - P
Trlfluralin
P * CWA priority pollutant
I/R = Ignltable or reactive compound
V * Volatile compound
2^20
-------
TABLE 2-3. REGULATORY STATUS OF OSS POLLUTANTS
DSS
DSS . / REGULATORY PROJECT.
POLLUTANTS / DESIGNATIONS STATUS '
Acenaphthylene
Acetatdehyde
Acetone
Acetonecyanohydrin
Acetonitrile
Acetophenone
Acetyl Chloride
Acrolein
Aery I amide
Acrylic Acid
Acrylonitrile
Alachlor
Aldicarb
Aldrin
Aniline
Anthracene
Antimony and Compounds
Ant u
Arsenic and Compounds
Atra/ine
Barium and Compounds
Benzal Chloride
Benzene
p- Ben zoqui none
Benzotrichloride
Benzyl Chloride
Bis-(2-Chloroethoxy) Methane
B1s-(2-Chloroethyl) Ether
Bis-(2-Ethyl Hexyl ) Phthalate
Bromacil
Bromomethane
H-Buty) Alcohol
Butyl Benzyl Phthalate
2A
2
1
2
2
2
2
2
2A
2A
2A
P
P
P
2
2A
2
P
1
P
1
2A
2
2
2A
2
2
2
2
P
2
1
2
CUA
PRIORITY .
POLLUTANT*
CUA
*
CUA
*
CUA
CUA
CUA
CUA
*
CUA
CUA
*
CUA
CUA
CUA
CUA
CUA
RCRA
APPENDIX VII
CONSTlTUtNr
'A?
A7
A7
A7
A7
A7
A7
A7
A7
A7
A7
A7
'
RCRA
F-CODE NUMBER OF RCRA
SOLVENT/PLATING F.K-CODE
UASTE LISTING
1
0
F/S 1
0
2
0
0
* . 0
1
0
3
0
0 .
0
3
t
1
0
5
0
0
o
4
0
1
2
0
1
0
0
0
F/S 1
0
RCRA RCRA
CHARACTERISTIC APPENDIX VIII
UASTE3 CONSTITUENT0
i
1
i
C,R
I
*
i
*
EP
EP
i
*
C.R
*
*
*
I
AS
*
*
AS
AS
AS
AS
AS
AS
AS
*
AS
AS
AS
AS
*
AS
AS
AS
AS
AS
AS
AS
AS
AS
AS
*
AS
AS
SELECTED 7
PESTICIDES'
*
*
*
p
p
p
*
*
p
*
p
*
*
p
*
*
*
-------
TABLE 2-3. REGULATORY STATUS OF DSS POLLUTANTS (Continued)
ro
ro
ro
DSS / REGIILAIORY
POLLUTANTS / DESIGNATIONS
Cadmium and Compounds
Cap tan
Carbofttran
Carbon Disulfide
Carbon TetrachloHde
Chlordane
CMorobenzene
Chlorobrrmlate
Chloroethane
p-Chl oro-m-Cresol
Chlorofonn
Chloromethane
Chloronaphthalenp
2-Chlorophenol
Chromium and Compounds
Cresols (3 isomers)
Cumene
Cyanide
Cyclohexane
Cytlnhexanone
2,4-D
2.4-DB
Dia/inon
Dtbrnmomethane
Di-N-ftutyl Ph thai ate
1.2-Dtchlorobenzene
1,3-Dfchlorobenzene
1 ,4-Di chlorobenzene
Die h 1 orodf f I uoromethane
1 , 1-Di chloroethane
"1 ,2-D* chloroethane
1 , 1-Df chloroethylene
Trans-l,2-Di chloroethylene
DSS
PROJECT.
STAIUS 1
I
P
P
1
1
P
1
P
2 ,
2
2
2
2
2A
1
1
2
2
2
1
P
P
P
2A
2
1
2
2
1
2
2
2
2
CUA
PRIORITY -
POLLUTANT*
CUA
.
CUA
CUA
CUA
.
CUA
CUA
CUA
CUA
CUA
CUA
CUA
.
.
CUA
m
.
*
*
CUA
CUA
CUA
CUA
*
CUA
CUA
CUA
CHA
RCRA
APPENDIX VII
CONST 1 Tut NT
A7
.
A7
A7
A?
A7
,
A?
A?
A7
,
A7
A;
A7
,
A7
^
.
.
.
*
A7
A7
A7
A7
A7
A7
A7
A7
RCRA
F-CODt
SOLVENT/PLftTlHG
UASTF
F/P
.
F/S
F/S
-
F/S
-*
m
.
-
.
.
F/P
F/S
,
F/P
a
F/S
9
*
-
*
F/S
F/S
f
,
KUHBtlR OF RCRA
F.K-cnuc
I ISTINI;
. 4
n
0
1
7
1
4
n
0
I
8
3
0
1
1
2
0
1
0
I
0
0
0
0
0
5
3
3
1
1
7
5
1
RCRA RCRA
CHARACTERISTIC APPENDIX VIII
HASTE3 CONSTItUENT0
EP AS
(P)
(P)
I AS
AS
AS
Afl
Afl
AS
AS
AS
1 AS
. . AS
AS
EP AS
AS
1
AS
1
r
AS
.
(P)
AS
AS
AS
AS
AS
AS
AS
AS
AS
AS
SELECTED ,
PESTICIDES'
*
p
p
.
p
.
p
-
.
.
.
f
f
-
*
V
.
.
P
P
P
*
.
.
-------
TABLE 2-3. REGULATORY STATUS OF DSS POLLUTANTS (Continued)
I
t-o
OSS
ruU.IITANTS
/ KIGIH.ATORY
/ ItlSIGNATlONS
nss
PROJKT
CUA
PR10HITY
STATUS ' POILIITANT*
HCKA
APPENDIX VIL
CONST | Till NT
RtHA
F-cnm
S(1LVtNT/PL4TIHr,
HASH.
flllMBlH OF
F,K-CO|)F
LtSTJHI,
RCRA
RCRA
SELECTED
CHARACTERISTIC APPENDIX VIII ...^.^ 7
WASTE9 CONSTITUENT0 PESTICIDES*
? , 4 -Di chl orophnnol
1 ,?-nithJoropropane
Dichloropropanol
ttithlnrvos
flicofol
Dipthyl Phthalate
3,3-niroethoxy ben ;i dine
Dimethylamine
2,4-niim?thyl Phenol
Dimethyl Phthalate
2,4-Dinitrophpnol
Dinoseb
Oi-N-Octyl Phthalate
1 ,4-t)ioxane
Diphenatnid
Diphenyl Amine
Oi sul fol ton
Diuron
Endrin
f pirhlorohvdrin
llhyl Acetate
Ethyl Benzene
Ethylene Oxide
Fthylene Thiourea
Ethyl Fther
Fenthion
Ferbam
Folex
Formaldehyde
Formic Acid,
Furan
Furfural
Mexachl oro- 1 , 3-Butadiene
2 CWA A7
2 CWA A7
2 . A?
P
P
2 CHA
2A
2
2 CUA A7
2 CUA
?A CUA A 7
P . .
2 CUA
2
P
2 . A7
P
P
P CUA
? . A7
1
1 CUA
2
2A
1
P
P
P
2 . A7
2 . A7
?
2
2 CUA A7
2
0
M
n
n
o
n
0
2
0
1
0
0
n
0
2
0
0
0 .
1
l/S 1
F/S 1
0
0
F/S 1
0
0
0
4
2
0
0
4
AS
A8
AS
(P)
,
AS
AR
1
AB
A8
AH
A8
AH
AS
A8
A8
A8
A8
A8
I
1
I AS
AS
1
(P)
* *
A3
C AB
I
1
AS
*
.
P
P
*
- - .
.
m
.
P
.
.
P
9 '
P
P
P
.
.
.
f
P
P
P
t
* ^
-------
TABLE 2-3. REGULATORY STATUS OF DSS POLLUTANTS (Continued)
»SS / RIGWATORY
I'OIIHTANFS / niStr.HATlONS
HP.acnloroPtha.it>
Hydra /inn
Isohutannl
1 i>am
Nickel and Compounds
p-Nit roanil ine
Hit rohi'n/ene
?-Nitropropane
N-Nitrosodimetnyl Amine
Oxantyl
Pa rat hi on
Parathion Methyl
PCS
Pentachloroethane
Pentachlorophenol
Phenol
Phenylene Diamine
Phorate
Phosgene
Phthalic anhydride
DSS
PRO.IKJT
STATUS l
2
2
1
1
?A
1
?A
P
1
P
1
1
1
P
P
2
P
.2
2A
1
2
2
P
P
P
2
2
2
2
2
P
2A
2A
CWA
PRIORITY -
POILUTANT
CUA
.
CUA
.
CUA
.
.
.
CUA
.
CUA
.
CUA
.
CUA
CUA
.
.
CUA
CUA
CUA
.
.
Rf.HA
APPFNU1X VII
CnriSIIFlKNT3
A7
.
A7
A7
.
A7
.
f
-
,
A7
A7
.
A7
.
A7
m
A7
-.
.
*
.
-
A7
A7
A7
A7
.
A7
K-cont i
SOLVlNT/PUTINf,
UAsrr
.
F/S
.
.
.
.
F/S
fc
F/S
F/S
F/S
.-
*
»
F/P
.
i/s
'
.
.
9
.
.
ft
»
'JllMKflt (11 RCRA
r.K-ronr
1 ISIINI,
4
0
i
13
0
?
0
n
i
n
i
i
5
0
0
5
0
i
0
4
0
0
n
0
0
0
i
3
4
3
2
0
4
RCRA RCRA
CHARACTIRISTIC APPENDIX VII!
UASFE3 CONSTITUENT6
. . AB
R AB .
I AA
EP AB
AB
EP Afl
1 Afl
, 9
\
AB
1 . ;A8
I
AB
(P)
(P)
AS
. .
A8
AB
AB
I
AS
. .
AS
AB
Afl
Afl
AS
AB
AB
AS
AB
A8
SFltCTEl)
PESTICIOts'
.
.
.
.
P
P
.
m
P
P
.
P
B
.
*
m
P
P
P
.
t
.
P
.
-------
TABLE 2-3. REGULATORY STATUS OF DSS POLLUTANTS (Continued)
ro
i
ro
in
IJSS / REGULATORY
POLLUTANTS / DESIGNATIONS
2-Picoline
Pyrethrins
Pyriiline
Resorcinol
Selenium and Compounds
Silver and Compounds
Sodium Fluoroacetate
Stirofos
Styrene
2.4.5-T
Tetrachlorohenzene
1,1 ,1,2-Tetrachloroethane
1,1, 2, 2-Tetrachl oroethane
fetrachloroethylene
Tetrahydrofuran
Thiorea
Thiram
Toluene
Toluene Diamtne
To*A()hene
Irihromonrethdne
l,?,4-THcblDrobenzene
1 , 1 , 1 - Tr i chl oroethane
1 , 1 ,2-TrichI oroethane
Trichloroethylene
Trichlorofluoromethane
2,4;6-Trichlorophenol
1 ; 2, 3-Trichl oropropane
l.!,?-Tricl>loro~
1 , 2, 2-Tr i f 1 uoroethane
Trifluralin
OSS
PROJECT
STATUS *
2
P
1
2
1
I
P
P
2A
P
2
2
2
J
2
2
2
1
2A
P
?
2
1
2
I
I
2
2
1
P
CUA
PRIORITY
POLLUTANT*1
.
CUA
CUA
f
,
CUA
CUA
ft
CUA
ft
CUA
CUA
CUA
CUA
CUA
CUA
.
CUA
.
.
RCRA
RCRA F-CODE
APPENDIX VII SOLVENT/PLATING
CONSTITUENT"1 UASTE*
. A7
.
A7 F/-S
* . *
,
"
t
f t
-
,
A?
A7
A7
A7 F/S
.
t f
A7 F/S
A7 ...
A7
A7
A7 F/S
A7
A7 F/S
A7 F/S
A7
A7
A7 F/S
NUMBER OF RCRA
F.K-CODE
LISTING
I
0
2
0
0
0
0
0
0
0
2
5
6
3
0
0
0
4
1
0
0
1
9
6
6
1
3
- o
*
1
0
RCRA RCRA
CHARACTERISTIC APPENDIX VIII SELECTED 7
UAST£D CONSTITUENT0 PESTICIDES'
AS
P
I AS
AS
EP AS
EP AS
AS P
P
(P)
AS P
AS
AS
AS
AS
I . .
A8
AS
I AS
AS
(P) P
AS
AS
AS
AS
AS
AS
. AS
A8
AS
(P) P
-------
TABLE 2-3. REGULATORY STATUS OF DSS POLLUTANTS (Continued)
RCRA
IV
i
rv
cr*
DSS / REGULATORS
POLLUTANTS / DESIGNATIONS
Vanadium Pentoxide
Vinyl Chloride
Xylenes (3 isomers)
Pollutant Totals
Key:
DSS
PROJECT.
STATUS A
2A
2
1
165
CWA
PRIORITY
POLLUTANT'
CWA
67
RCRA
APPENDIX VII
CONSTITUENT-1
A7
74
F-CODE
SOLVENT/PLATING
WASTE*
F/S
30
NUMBER OF RCRA
F.K-COOE
LISTING
0
5
1
N/A
RCRA
CHARACTERISTIC
WASTE5
i
41
RCRA
APPENDIX VIII SELECTED 7
CONSTITUENT0 PESTICIDES'
A8
AS
121 38
2=DSS Tier 2 pollutant
2A=DSS Tier 2A pollutant
P=OSS Pesticide pollutant
CHA=CUA priority pollutant
A7=RCRA Appendix VII hazardous constituent
F/S=F-code solvent waste
F/P=F-code plating waste
l=Ignitable waste
R^Reactive waste
C=Corrosi»e waste
IP=EP toxic waste
Afl=RCRA Appendix Vlll hazardous constituent
(P)=Proposed RCRA Appendix VIII hazardous constituent
P=Selected pesticide
-------
IN)
I
ro
Totd DSS Pollutants: 165
3
Ok
at
Selected Pesticides - 38
RCRA Characteristic Wastes - 41
RCRA Appendix VII Constituents - 74
RCRA Appendix VIM Constituents
2O SO 40 30 eO 7O 8O 9O 100 110 120 130
Number of Pollutants
FIGURE 2-2. PROFILE OF REGULATORY STATUS OF DSS POLLUTANTS1
^Because of double-counting (where same pollutant appears on more than one list),
for Figure is 341, rather than 165.
-------
i
ro
CO
Total CWA Priority Pollutants ~ 126
CWA Priority Pollutants on OSS Ust - 67
Total Appendix VH Constituents - 114
O»
QC
Appendix VII Constituents on OSS List - 74
&%&%0000&0^^
Total Appendix VNI Constituents - 383;
jj%0!i!a3J0^
Appendix VHI Constituents on DSS Ust - 121
100
«0 200 290 300
Number of Pollutants .
350
400
490
FIGURE 2-3. REPRESENTATION OF KEY RCRA AND CWA POLLUTANT LISTS ON DSS POLLUTANT LIST*
^Because of double-counting (where sane pollutant appears on nore than one list),
total for Figure is 262, rather than 165.
-------
In the following chapters, the DSS pollutants are discussed as
"nonpriority hazardous constituents" and "priority hazardous constituents."
The nonpriority constituents are all constituents with -the exception of the
CWA priority pollutants. Conversely, the priority hazardous constituents are
the CWA priority pollutants. Both classifications discuss the metals and
organics.
2-29
-------
-------
CHAPTER 3
TYPES, QUANTITIES, AND SOURCES OF
HAZARDOUS WASTES DISCHARGED TO POTWs
-------
-------
3. TYPES, QUANTITIES, AND SOURCES OF HAZARDOUS WASTES DISCHARGED TO POTWS
This chapter describes the types, quantities, and sources of hazardous
wastes and constituents discharged to publicly owned treatment works (POTWs).
To provide a comprehensive profile of current and future discharge practices,
the chapter presents data for 47 different industrial categories, ranging from
the largest hazardous waste generators, such as the organic chemicals and
petroleum refining industries, to small quantity generators (SQGs), such as
laundries and motor vehicle services. Thus, these 47 industrial categories
include the traditional Natural Resources Defense Council (NRDC) Consent
Decree industries as well as new, emerging industries {e.g., waste
reclamation, waste treatment) and smaller service-oriented industries.
As described in Chapter 2, this study is based mainly on the loadings to
POTWs of individual Resource Conservation and Recovery Act (RCRA) waste
constituents (e.g., benzene, cyanide) rather than generic waste types (e.g.,
spent solvents, still bottoms). However, where Environmental Protection
Agency (EPA) data sources provided information on the discharge of RCRA
characteristic and listed hazardous wastes to POTWs, this information has been
included in Chapter 3.
To evaluate the efficiency of existing and proposed controls on the
discharge of hazardous waste constituents, the analysis in this chapter
presents discharge estimates for three treatment scenarios: raw waste,
current treatment, and treatment after compliance with Pretreatment Standards
for Existing Sources (PSES). The raw waste scenario assumes the discharge of
untreated wastewater; the current treatment scenario assumes the discharge of
wastewater at existing treatment levels; and the treatment after PSES scenario
projects pollutant loadings following the installation of treatment necessary
to meet National categorical pretreatment standards.
3.1 BACKGROUND AND METHODOLOGY FOR ANALYSIS OF HAZARDOUS WASTE TYPES,
QUANTITIES, AND SOURCES
The following section outlines the methodology used to analyze types,
quantities, and sources of hazardous wastes discharged to POTWs. This
3-1
-------
methodology involved several steps, Including the development of an industry
categorization scheme; the evaluation of pertinent EPA Office of Water (OW),
EPA Office of Solid Waste (OSW), State, and local data sources; the com-
pilation of discharge data for each industrial category; and the analysis and
interpretation of data for each industrial category. The first two method-
ological steps development of an industry categorization scheme and review
of data sources -- are described below,
3.1.1 Methodology for Development of an Industry Categorization Scheme
The initial step in determining possible sources of hazardous wastes
discharged to POTWs was to develop an industry categorization scheme. This
procedure entailed identifying the types of industrial facilities that
generate, transport, treat, store, or dispose any significant quantity (i.e.,
greater than 100 kg/mo) of hazardous waste. Identification of these
industrial categories involved reviewing several industrial data sources:
Documentation supporting effluent guidelines rulemakings undertaken by
EPA's Industrial Technology Division (ITD) for the NRDC consent decree
industries and other "secondary" industries
EPA/OSW report, National Small Quantity Hazardous Waste Generator
Survey, which contains industrial groups for SQGs
Other EPA/OSW studies such as, Economic Impact Analysis of Subtitle C
RCRA of 1976, and National Survey of Hazardous Waste Generators and
Treatment, Storage and Disposal Facilities Regulated Under RCRA in
1981
Standard Industrial Classification Code Manual
Industrial waste survey data from various State and local pretreatment
programs.
Based on the analysis of these data sources, a final list of 47 industrial
categories was developed. Table 3-1 lists these 47 industrial categories.
Many of the Domestic Sewage Study (DSS) Industrial categories correspond
well with industry groupings used by ITD during various effluent guidelines
rulemakings. In addition, several new industrial categories were added to the
list based on the review of the data sources cited above. The use of ITD
3-2
-------
TABLE 3-1. DSS INDUSTRIAL CATEGORIES
Adhesives and Sealants
Battery Manufacturing
Coal, Oil, Petroleum Products, and Refining
Construction Industry {Contract and Special Trade)
Cosmetics, Fragrances, Flavors, and Food Additives
Dye Manufacture and Formulation
Electric Generating Power Plants and Electric Distribution Services
Electrical and Electronic Components
Electroplating/Metal Finishing
Equipment Manufacture and Assembly
Explosives Manufacture
Fertilizer Manufacture
Food and Food By-Products Processing
Gum and Wood Chemicals, Varnishes, Lacquers, and Related Oils
Hazardous Waste Site Cleanup
Industrial and Commercial Laundries
Ink Manufacture and Formulation
Inorganic Chemicals Manufacturing
Iron and Steel Manufacturing and Forming
Laboratories and Hospitals
Leather Tanning and Finishing
Miscellaneous Chemical Formulation
Motor Vehicle Services
Nonferrous Metals Forming
Nonferrous Metals Manufacturing
Organic Chemicals Manufacturing
Paint Manufacture and Formulation
Pesticides Formulation
Pesticides Manufacturing
Pharmaceutical Manufacturing
Photographic Chemicals and Film Manufacturing
Plastics Molding and Forming
Plastics, Resins, and Synthetic Fibers Manufacturing
Porcelain Enameling
Printing and Publishing
Pulp and Paper Mills
Rubber Manufacture and Processing
Service Related Industries (other than motor vehicle services)
Soap and Detergents, Cleaning Preparations, and Waxes Manufacture and Formulation
Stone, Clay, Glass, Concrete, and Other Mineral Products
Textile Mills
Timber Products Processing
Transportation Services
Waste Reclamation Services
Waste Treatment and Disposal Services
Wholesale and Retail Trade
Wood Furniture Manufacture and Refinishing
3-3
-------
categories enabled more efficient use of data collected by ITD in support of
their rulemakings. In some cases, ITD categories were subdivided or combined
for this study. Examples of modifications to ITD industry categories include:
Expanding the petroleum refining category to include the production of
coal and oil products and renaming the category coal, oil, petroleum
products, and refining.
Combining the coll coating category with the electroplating/metal
finishing category because of the s1m1l1arity of their processes,
Combining the aluminum, copper, and nonferrous metals forming
categories Into one category entitled nonferrous metals forming.
Dividing the metals molding and casting category into its ferrous and
nonferrous metals subcategories. The nonferrous metals subcategories
were included in the nonferrous metals manufacturing category and the
ferrous metals subcategories were included in the iron and steel
manufacturing and forming category.
Dividing the organic chemicals, plastics, and synthetic fibers
category into three categories, Including dye manufacture and
formulation; organic chemicals manufacturing; and plastics, resins,
and synthetic fibers manufacturing categories.
Including the photographic processing category as a subcategory under
the service-related industries category.
Subcateyory assignment also relied substantially on schemes created by
ITD during effluent guidelines rulemakings. Development of industry sub-
categories allowed greater discrimination within the larger industrial
categories and provided greater flexibility in the incorporation of informa-
tion from various data sources and presentation of results. However, some
subcategorization schemes used by ITD in effluent guidelines rulemakings were
not used or were amended for purposes of this study. Examples of modification
to ITD subcategories Include:
Moving the car wash subcategory from the auto and other laundry
category to the motor vehicle services category
Expanding the electroplating/metal finishing subcategories to include
other nonregulated metal fabrication and metal products manufacturing
processes
3-4
-------
Combining subcategorles In the inorganic chemicals category, which are
organized by specific Inorganic compounds produced, into major
compound groups
Expanding the leather tanning and finishing and pulp and paper
subcategories to include processing of the finished product.
Finally, 'Standard Industrial Classification (SIC) codes were assigned to
each industrial category and subcategory. SIC codes describe the primary
activity at a facility based on the principal product or group of products
produced or distributed, or services rendered. Assignment of SIC codes to
industrial categories and subcategories was «n important step in this study
since SIC codes are a common element in most industrial data sources. While
SIC codes received considerable emphasis from ITD during rulemakings, numerous
SIC codes were added to industry categories and subcategories to ensure that
data from other sources, primarily EPA/OSW and State and local data sources,
could be incorporated into the industry categorization scheme adopted for this
study. Appendix C presents the list of industrial categories, subcategories,
and SIC codes for each subcategory. The industry categorization scheme shown
in Appendix C provides the basis for the organization of the wastewater and
hazardous waste data gathered and analyzed for this study.
3.1.2 Summary and Evaluation of Major Data Sources
The major industrial data sources used in the assessment of types,
quantities, and sources of hazardous waste discharged to POTWs are shown 1n
Table 3-2. This table also provides an analysis of the strengths and weak-
nesses of each data source as it relates to industry background information
and wastewater discharge characteristics. Table 3-3 presents a similar
analysis of strengths and weaknesses of these data sources as they relate to
specific industrial categories.
Table 3-2 includes EPA/OSW, EPA/OW, and State and local data sources.
The OSW data sources consisted of the National Survey of Hazardous Waste
Generators and Treatment, Storage and Disposal Facilities Regulated Under RCRA
in 1981, the Hazardous Waste Data Management System (HWDMS), the National
Small Quantity Hazardous Waste Generator Survey, and the Industry Studies Data
Base (ISDB).
3-5
-------
TABLE 3-2. STRENGTHS AND WEAKNESSES OF MAJOR INDUSTRIAL DATA SOURCES
DATA ELEMENTS
MAJOR
INDUSTRIAL
DATA SOURCES
DATA ON INDUSTRIAL DISCHARGERS
*
*
I
£
£
£ 8
OSH National Survey of Hazardous Haste Gener-
ator* and Treatammt* Storage and Disposal
Factl
-------
TABLE 3-3. ADEQUACY OF AVAILABLE DATA SOURCES FOR EVALUATION
OF OSS INDUSTRIAL CATEGORIES
^*w MM ELO«TS
INDUSTRIAL ^S.
MM SOUHttS ^X.
Adhecfves and Sealants
Battery Manufacturing
Coal. Oil. PetroleuB Products, and Refining
Construction Industry (Contract and Special
Trade)
Cosaettcs, Fragrances, Flavors, and Food
Additives
Dye Manufacture and Formulation
Electric Generation Power Plants and Electric
Distribution Services
Electrical and Electronic Components
Electroplating/Metal Finishing
Equipment Manufacture and Assembly
Explosives Hinufacture
, Ferti liter Manufacture
Food and Food Ay-Products Processing
Gum and ttood Chemicals. Varnishes. Ucojuers
and Related Oils
Hazardous Haste Site Clean-Op
Industrial and Commercial Laundries
Ink Manufacture and Forawletton
Inorganic Chemicals Manufacturing
Iron and Steel Manufacture and Forming
Laboratories and Hospitals
Leather Tanning and Finishing
Miscellaneous Chemical Formulation
MM « INDUSTRIAL DISCHARGE*.
1 Number of Imaardows
matte Generators
1
1
1
1
1
1
2
1
1
1
I
1
1
1
»
1
1
1
1
1
I
1
'!
il
1
l
1
2
2
1
1
1
1
1
1
t
1
1
2
1
1
1
2
1
2
Hazardous meste
quantities Generated
*
2
2
2
2
1
2
2
2
2
2
*
2
2
2
2
2
2
2
2
Number of Indirect
Mfcluroirs
i
i
i
2
2
1
2
1
1
*
1
Z
2
1
1
1
1
1
2
1
2
OM/rrlerUy
PollnUntc Detected
1
I
1
2
1
I
I
*
1
1
1
1
1
1
ROM/Priority Pol Intent
Concentration/Hiss
1
1
1
1
,
1
I
*
1
*
1
1
1
1
1
1
'
Other KM Pollutants
0* tec ted
2
2
2
1
.
2
2
2
2
*
2
2
2
2
2
*
2
*
*
II
il
*
»
.
*
B
*
*
*
*
*
*
W
s
i
t
i
i
i
i
>
'
i
i
i
*
*
1 * Substantial Data
2 = Limited Data, or I to jor Assunption(s) Required for Use
* = Little or No Data
3-7
-------
TABLE 3-3. ADEQUACY OF AVAILABLE DATA SOURCES FOR EVALUATION
OF DSS INDUSTRIAL CATEGORIES (Continued)
^v MTA ELEMENTS
INDUSTRIAL ^N.
MTA SOURCES ^x.
Motor Vehicle Services
Honferrous Metals Forming
Non ferrous Metal! Manuficturing
Organic Chemicals Manufacturing
Paint Manufacture and Formulation
Pesticides Fonulatlon
Pesticides Manufacturing
Pharmaceutical Manufacturing
Photographic Chemicals and F1 \m Manufacturing
Plastics Molding and Forming
Plastics, Resins and Synthetic Fibers
Manufacturing
Porcelain Enameling
Printing and Publishing
Pulp and Paper Mills
Rubber Manufacture and Processing
Service Related Industrie! (other than entor
vehicle services)
Soap and Detergents, Cl Mining Preparation! and
Maxes Manufacture and Formulation
Stone, Clav, Class. Concrete, and Other
Mineral Products
Textile Milli
Timber Product! Procesitng
Transportation Services
Haste Reclamation Services
Naste Treatment and Disposal Services
Hholeiali Trade Industry
Wood Furniture Manufacture and Raf tut thing
MTA OH INDUSTRIAL DISCHAKERS
ember of Hazardous
Haste Operators
I
I
1
1
1
1
1
1
t
1
1
1
1
1
I
1
1
1
1
1
I
2
2
1
1
11
?l
2
I
I
1
1
1
1
1
1
1
1
1
1
1
I
2
1
1
I
1
1
2
t
HaurdMis Haste
Quantities Gemeratetf
2
2
*
1
2
2
i
2
*
2
I
2
2
2
2
2
*
*
>
*
'
2
2
im*ar of Mfrect
Hsctttrgers
2
I
I
I
1
1
1
1
1
1
I
1
1
1
2
2
2
2
1
1
'
2
2
KM/Priority
PvllvtMts Detected
I
I
1
1
I
I
I
I
I
1
1
1
1
2
*
2
I
I
*
KM/Prlority PellutMt
GoanamtratlM/NKS
1
I
I
I
1
1
1
1
1
1
1
I
I
2
2
I
I
Other KM tallMUmts
Detected
'
*
1
2
*
1
2
2
2
1
2
2
2
2
2
*
7
2
'*
ii
a
*
-
*
2
1
*
*
*
1
'
*
'
*
t
t
*
M
1
1
1
1
1
1
1
1
1
1
I
I
I
1
*
*
1
1
*
1. Substantial Data
2 - Limited Data or Major Asswptlon(s) Required for Uie
* * Little-or No Data
3-8
-------
Generally, the EPA/OSW data sources provided a substantial amount of data
on the types and quantities of hazardous wastes generated, treated, stored, or
disposed by an industrial category. Except for the SQG survey and the ISDB,
however, these same data sources provided little information on the number of
indirect discharging facilities and quantities of hazardous wastes discharged
to POTWs by these facilities. The SQG survey provided estimates by industrial
category for the types and quantities of hazardous wastes being discharged to
POTWs, but only for SQGs (I.e., less than 1,000 kg/mo). (The HSWA of 1984
changed the definition of SQGs from 1,000 kg/mo to 100 kg/mo. The SQG Survey
was conducted prior to the amendments.) The ISDB provided extensive data on
hazardous wastes and constituents discharged to POTWs, but only for a small
number of industrial categories (i.e., organic chemicals manufacturing; plas-
tics, resins, and synthetic fibers manufacturing; dye manufacture and
formulation; and pesticides manufacture). The ISDB was the only data source
that provided substantial data on loadings of hazardous constituents that are
not priority pollutants under the Clean Water Act (CWA).
The EPA/OW data sources shown in Table 3-2 contained general background
information as well as loadings for a limited number of hazardous constituents
in a majority of the DSS industrial categories. Also, EPA/OW discharge data
generally extended only to constituents that are also CWA priority pollutants.
The limited data reflect the scope of EPA/OW effluent guidelines rulemakings,
which focused on control of priority pollutant discharges by the various
industrial categories. EPA/OW did attempt, through the CWA Paragraph 4(c)
Program, to identify nonpriority pollutants present in process wastewaters
discharged to POTWs by various industrial categories (see Section 3.3.4.2).
Data collected for this program were used to assess the possible presence of
nonpriority hazardous pollutants in industrial wastewaters.
State and local data sources provided useful information on hazardous
constituents discharged to POTWs by facilities within the various industrial
categories. With some exceptions (e.g., Seattle Metro), State and local data
emphasized hazardous constituents that are also priority pollutants. Still,
these data sources often provided information on industrial categories that
were not covered by EPA/OW and EPA/OSW data sources.
3-9
-------
Table 3-3 summarizes the relative strengths and weaknesses of different
data sources for specific industrial categories. As indicated in this table,
these data sources provided extensive information on some industrial
categories (e.g., organic chemicals manufacturing) and little information on
other categories (e.g., hazardous waste site cleanups). Based on available
data sources for specific industrial categories, the 47 industrial categories
were divided into the following three groups:
t Organic chemicals industrial categories
Selected consent decree industrial categories (including the organic
chemicals industrial categories)
Other industrial categories potentially discharging hazardous wastes
to POTWs.
The organic chemicals industrial categories group, which accounts for a
substantial proportion of all organic hazardous wastes generated, is composed
of four industries: (1) dye manufacture and formulation; (2) organic chem-
icals manufacture; (3) plastics, resins, and synthetic fibers manufacture; and
(4) pesticides manufacture. Data on loadings of both priority and nonpriority
hazardous constituents discharged by the organic chemicals industrial cate-
gories were gathered from two unique data sources:
Data bases supporting ongoing EPA/OW effluent guidelines rulemakings
for the organic chemicals; plastics, resins, and synthetic fibers; and
pesticides manufacturing categories
The EPA/OSW ISDB, which incorporates data from RCRA 3007 question-
naires and sampling/analysis results.
Because of the accurate and extensive information on both RCRA wastes and
priority hazardous constituents discharged by the organic chemicals
industries, these industries as a group were analyzed.
The selected consent decree industrial categories are composed of 30
major industrial categories that have been regulated, or considered for
regulation, by EPA/OW as required by the CWA, and in accordance with the terms
of the 1976 NROC Consent Decree. As mentioned above, the selected consent
3-10
-------
decree industries group includes the four oryanic chemicals industrial cate-
gories. Existing data sources for these selected consent decree categories
contain substantial data on loadings of priority hazardous constituents, but
only limited data on loadings of listed and characteristic hazardous wastes
and nonpriority hazardous constituents. The remaining 17 industrial cate-
gories primarily consist of service-related industries. EPA/OW and EPA/OSW
data sources generally contained little information on these industrial
categories. Consequently, a variety of data sources were utilized to assess
potential hazardous waste discharges from these industrial categories.
3.1.3 Organization of the Chapter
The remainder of the chapter is divided into six sections. Section 3.2
presents and analyzes discharge data for the major organic chemicals indus-
trial categories. Section 3.3 presents and analyzes basic characteristic and
hazardous waste data for 30 selected consent decree industries. For com-
parative purposes, data for the four organics industrial categories presented
in Section 3.2 also are incorporated into this section. Section 3.4 presents
information from various data sources for 17 other industrial categories and
evaluates the potential for hazardous waste and constituent discharges to
POTWs from these industrial categories. Section 3.5 evaluates the production
and use of selected hazardous constituents (primarily RCRA solvents) in an
attempt to determine, the probable sources of pollutants known or believed to
be common in POTW influent wastewaters. Section 3.6 estimates hazardous
constituent loadings to POTWs from residential sources. Finally, Section 3.7
summarizes and evaluates the hazardous pollutant loadings from the major
industry categories.
3.2 TYPES AND QUANTITIES OF HAZARDOUS WASTES AND CONSTITUENTS DISCHARGED BY
THE ORGANIC CHEMICALS INDUSTRIAL CATEGORIES
The organic chemicals industries have been the focus of numerous studies
and regulatory initiatives undertaken by both EPA's OW and OSW. The Agency
has evaluated the organics industries in detail because they are composed of
numerous large and complex facilities that handle an array of chemical
intermediates, products, and wastes posing significant environmental concerns
if improperly managed. For the study's purposes, the organic chemicals
industry encompasses the following four categories:
3-11
-------
Dye Manufacture and Formulation
Organic Chemicals Manufacturing
Pesticides Manufacturing
Plastics, Resins, and Synthetic Fibers Manufacturing.
The pesticides manufacturing category does not include the pesticide
formulation segment, which is addressed as a separate category in Section 3.3
of this report.
The selection of these four categories for separate analysis should not
be Interpreted that these categories are the only significant sources of
organic hazardous constituents. Numerous other Industrial categories, such as
the petroleum refining, pharmaceutical manufacturing, and electroplating/metal
finishing categories, discharge large quantities of organic hazardous
constituents to POTWs. These other categories are examined in Section 3.3.
The analysis presented 1n Section 3.2 has two major objectives. First,
it estimates hazardous constituent loadings of both priority and nonpriority
pollutants to POTWs from these industries. For comparative purposes, these
results also have been incorporated into Section 3.3 of this chapter, which
presents hazardous constituent loadings estimates for 30 selected consent
decree categories, including the four organics categories. Second, the ISDB
was used to estimate generation and discharge rates for characteristic and
listed hazardous wastes. In estimating hazardous constituent loadings, the
analysis blends data derived from major EPA/OSW and EPA/OW data bases on these
industries. Consequently, the discussion of industry estimates identifies and
explains areas of major agreement or disagreement in estimates derived from
the two data sources. The remainder of Section 3.2 briefly discusses the
significance of the organics industries, describes methodologies used to
project hazardous waste and constituent loadings, and presents study findings
for the organics industries.
3.2.1 Background and Methodology for Evaluation of the Organic Chemicals
Industrial CategorTe?
A 1984 EPA report, National Survey of Hazardous Waste Generators and
Treatment, Storage and Disposal Facilities Regulated Under RCRA in 1981,
3-12
-------
estimated that the chemical and petroleum refining industry (SIC 28-29}
generated 71 percent of all RCRA hazardous wastes generated nationally in
1981. Other data sources, such as the EPA Hazardous Waste Data Management
System, also suggest the predominance of these industries as hazardous waste
generators. Many of the chemical products formulated by this industry
ultimately become the hazardous constituents discharged by the remaining
industries. Previous EPA/OW studies also have established that the organics
industries discharge substantial quantities of toxic pollutants to POTWs. In
its evaluation of the National Pretreatment Program, the pretreatment regula-
tory impact analysis (RIA) estimated that the organics industries discharge
38 percent of all priority pollutants and 56 percent of all organic priority
pollutants discharged to POTWs.
The need for effective regulation of these industries is reflected in
current EPA/OW and EPA/OSW regulatory programs. The proposed pretreatment
standards for the organic chemicals and plastics and synthetic fibers industry
(OCPSF) (which includes three OSS industrial categories: organic chemicals;
plastics, resins, and synthetic fibers; and dye manufacture and formulation)
published in the Federal Register on July 17, 1985 (50 FR 29068) reported that
42 percent of the approximately 1,000 OCPSF facilities discharged wastes to
POTWs at an estimated average daily process flow of 0.24 million gallons per
day (mgd) per plant. Research used to develop these proposed standards found
that "as a result of the wide variety and complexity of raw materials and
processes used and of products manufactured in the OCPSF industry, an excep-
tionally wide variety of pollutants are found in the wastewaters of this
industry." Furthermore, 39 percent of the indirect dischargers surveyed
reported either no treatment or no treatment beyond equalization ,and neutral-
ization; 47 percent utilized some physical/chemical treatment; and 14 percent
employed biological treatment of wastewaters. Final regulations for the
Pesticides Manufacturing and Formulation categories were promulgated in the
Federal Register on October 4, 1985 (50 FR 40672).
In EPA's OSW, organic chemical manufacturing wastes have received
considerable attention in the Hazardous Waste Identification and Listing
Program over the last 4 years. A survey of proposed hazardous waste listings
3-13
-------
and listings currently being evaluated for possible proposal for 23 product/
processes showed that only 5 out of 84 wastes are proposed for listing solely
because of toxic metal content. Seven wastes are being considered for listing
due to both metal and organic toxics, while 79 wastes are proposed for listing
because of their toxic organic constituents alone. These proposed listings
reflect EPA/OSW's current emphasis on the organics Industries.
Key data sources for the evaluation of the organics Industries were the
OSW ISDB and the OW/ITD data bases. Together, these data bases allowed
extensive characterization of hazardous waste generation and discharge
practices for the four organic chemicals industrial categories. Table 3-4
provides an overview of the types of data contained 1n the ISDB and ITD
data bases. As indicated 1n this table, the ISDB contains information on POTW
loadings of priority and nonpriorlty hazardous constituents and POTW loadings
of characteristic and listed hazardous wastes, but does not contain data on
treatment and removal of hazardous wastes and constituents. By comparison,
the ITD data bases for OCPSF and pesticide rulemakings contain information on
POTW loadings of priority hazardous constituents and on treatment and removal
of these constituents, but do not contain Information on loadings of non-
priority hazardous constituents, or characteristic and listed hazardous
wastes. The ISDB and ITD data bases provided overlapping data sources only
for loadings of priority hazardous constituents. All other data elements were
derived, exclusively from one of the two data bases.
3.2.1.1 Discussion and Comparison of ISDB and ITD Methodologies
This section provides a brief overview and comparison of the ISDB and ITD
methodologies employed to estimate hazardous waste and constituent discharges
to POTWs. More detailed descriptions of these methodologies appear in
Appendix D. During the early phases of the study, the ISDB and ITD data bases
were determined to be the best available sources of pollutant loadings data
for the organics industry. When the ISDB data base was separately compared to
ITD's organics and pesticide data bases, no data base was deemed superior to
the other. Therefore, to ensure that the strengths of each source were fully
incorporated in the analysis, and because of the substantial complexity and
differences of the data sources, the ISDB and ITD data bases were not
integrated to generate composite loadings.
3-14
-------
TABLE 3-4. TYPES OF DATA CONTAINED IN ITD AND ISDB DATABASES
ITD Data Bases
OCPSF and Pesticides)
ISDB Data Base
Data Contained
Data Base
in
Data Not Contained
in Data Base
Loadings of Priority
Hazardous Constituents
Treatment/Removal of
Hazardous Wastes and
Constituents
Loadings of Nonpriority
Hazardous Constituents
Loadings of RCRA
Characteristic and Listed
Wastes
Loadings of Priority
Hazardous Constituents
Loadings of Nonpriority
Hazardous Constituents
Loadings of RCRA
Characteristic and Listed
Wastes
t Treatment/Removal of
Hazardous Wastes and
Constituents
3-15
-------
A comparison of results from the two separate analyses revealed some
agreement on aggregate constituent loadings, but less agreement on
constituent-specific loadings. For the four industrial categories considered
(dye manufacture and formulation; organic chemicals; pesticide manufacturing;
and plastics, resins, and synthetic fibers), the total raw priority hazardous
constituent loadings were 31,442 kkg/yr based on the ISDB estimates, and
12,682 kkg/yr based on the ITD estimates. These results represent a 61
percent difference, a relatively minor divergence considering that estimates
were generated using different sources and analytical methodologies.
Constituent-specific comparisons, however, revealed more variable results,
including the presence of numerous pollutants identified by only one of the
two sources. These apparent discrepancies can be accounted for by closely
examining the data sources and methodologies.
As described further in Appendix D, the most fundamental differences in
the ISDB and ITD data lie in the purposes and objectives of the data bases and
the programs they support, the data collection methods, and the analytical
methodologies employed to produce estimates for this study. Developed for
EPA/OSW, the ISDB is based on RCRA Section 3007 surveys of the organic
chemical industry, which were aimed at identifying potential RCRA hazardous
wastes from industry or product groups of concern. The surveys were not
intended to be statistically representative of an industrial category or
product group. The selection of industries or products of concern was based
solely on OSW priorities and the availability or lack of information
characterizing the wastes of concern.
The ITD data bases, developed for EPA/OW, are based on CWA Section 308
surveys of the organics industry to support the development of effluent
guideline regulations. Although questionnaires were distributed to all known
organics manufacturers, they did not require facilities producing organic
chemicals at less than 50 percent of their total facility production to supply
waste composition data. General information was requested from these facili-
ties regarding products and process wastewater flows. The ISDB and ITD
surveys did not define the organics industry using the same criteria, although
every effort possible was made to account for this when extrapolating the
facility data to National estimates.
3-16
-------
Methodologies were developed to use these data sources to generate
hazardous constituent loading estimates for each industrial category (see
Appendix D). The ISDB methodology consisted essentially of estimating typical
values for hazardous constituent concentrations and waste quantities not
reported by the manufacturer and scaling up to National totals, based on the
percentage of total National production accounted for by ISDB data for each
industrial category. These scale-ups were not performed on a product or
product group basis, but were applied within each industrial category. The
ITD methodology extrapolated reported data to National estimates for similar
processes. The ISDB methodology assumes that wastestreams and constituents
included in the data base are representative of the remaining portions of the
industry, while the ITD methodology assumes that similar processes will
generate similar wastes. Obviously, neither of these assumptions will hold in
every case; therefore, hazardous constituent-specific loadings may be under-
estimated or overestimated in some instances. Under either methodology,
constituent loadings cannot be estimated for any hazardous constituent that is
not reported in the data base. These omissions account for hazardous
constituents that appear in only one data base.
Another methodological issue relates to the way in which hazardous
constituent concentrations are reported in the ISDB. Approximately one-half
of the concentration values are reported as ranges (i.e., 1 to 10 percent,
10 to 50 percent, etc.). In these instances, the mean of the range was used
to calculate pollutant loadings.
ISDB data were collected over several years (1981 through 1983), while
the ITD data represent manufacturing profiles for 1980 alone. Because 1981
and 1982 were depressed years economically for the organics industries, ITD
pollutant loadings would be expected to be higher than ISDB loadings, except
for the plastic and resin industry, which was surveyed by the ISDB in 1983, a
relatively strong year for the plastics industry/ ' Appendix D provides more
information on the status of the organics industry.
In summary, neither the ISDB nor ITD data bases were developed with the
DSS as their primary end use. All information sources have strengths and
3-17
-------
limitations that apply to this study. As discussed above, discrepancies exist
between the two estimates on a hazardous constituent-specific basis because of
the unique characteristics of each data source and the analytical method-
ologies applied to both. However, estimated hazardous constituent loadings
from the two data sources fall within reasonable intervals of agreement. The
two estimates presented in this report should be considered acceptable ranges
of values.
3.2.2 Presentation of Findings for the Four Organic Chemicals Industrial
Categories'
This section presents study findings for the four organic chemicals
Industrial categories. Initially, discharge characteristics, Including number
of indirect dischargers and POTW process flow, are presented for each cate-
gory. The following sections provide estimates for loadings of priority and
nonpriority hazardous constituents discharged by these categories. Estimates
of rates of generation and discharge of characteristic and listed hazardous
wastes also are presented and evaluated.
3.2.2.1 Discharge Characteristics of the Organic Chemicals Industrial
Categories
Data on discharge characteristics for the organlcs industries were
derived from ITD data bases supporting the effluent guidelines rulemakings for
the organic chemicals, plastics and synthetic fibers, and the pesticide
manufacturing categories. Table 3-5 provides a summary of discharge data for
the four organic chemicals industrial categories addressed in Section 3.2. As
Indicated in Table 3-5, the organics industries encompass an estimated 1,096
facilities, of which 468, or 43 percent of the total, are indirect dis-
chargers. Approximately one-half of all indirect dischargers are organic
chemical manufacturers. An additional one-third of the indirect dischargers
are plastics, resins, and synthetic fibers manufacturers.
The four organics categories discharge a total of 103 million gallons per
day of process wastewater to POTWs, As expected, the organic chemicals
manufacturing category, which discharges 66 mgd of process wastewater,
accounts for the largest share of all process wastewater (64 percent). The
3-18
-------
TABLE 3-5. DISCHARGE CHARACTERISTICS OF THE ORGANIC
CHEMICALS INDUSTRIAL CATEGORIES
Dye
Organic Manufacture Plastics, Resins,
Chemical and Organic and Synthetic Pesticides
Industry Formulation Chemicals Fibers Manufacturing Totals
Number of
Facilities* 58 537 382
Number of Indirect
Dischargers 47 230 153
Number of Direct
Dischargers 11 174 124
Number of Zero
Dischargers 2 142 112
119 1,096
38 468
45 354
25 281
Total Indirect
Process Flow
(MGD)
Total Direct
Process Flow
(MGD)
11.34
11.69
65.99
183.37
21.21
160.99
4.30
N/A
102.84
N/A
N/A: Not Available
*2 Dye, 7 Plastic, and 9 Organic facilities have both direct and indirect discharges and
are counted twice. Further, 11 Pesticide Manufacturing facilities do not generate
wastewaters.
3-19
-------
plastics, dyes, and pesticide categories contribute 21 mgd (20 percent of all
wastewater), 11 mgd {11 percent) and 4 mgd {4 percent), respectively, of all
process wastewater from the organlcs Industries to POTWs. Of the three
categories for which direct flow data were currently available, the dye
manufacture and formulation industrial category discharges the greatest
proportion (i.-e., 49 percent) of Its total process wastewater to POTWs.
3,2,2.2 Hazardous Constituent Loadings for the Four Organic Chemicals
Industrial Categories
Appendix E presents estimates for hazardous constituent loadings for the
four organic chemicals industrial categories. Appendix E presents loadings
both for priority hazardous constituents (I.e., CWA priority pollutants) and
nonprlorlty hazardous constituents. In addition, loadings estimates are
provided for three different treatment levels, including raw discharge, cur-
rent discharge (I.e., discharge at current treatment levels), and after PSES
discharge (I.e., discharge at treatment levels required to meet-proposed and
promulgated PSES limitations). In projecting after PSES loadings for the dye
manufacture and formulation; organic chemicals; and plastics, resins, and
synthetic fibers categories, the analysis incorporates proposed PSES
limitations developed for the ongoing effluent guidelines rulemaklng for the
OCPSF category. In estimating after PSES loadings for the pesticide
manufacturing category, the analysis utilizes recently promulgated PSES
limitations developed as part of the pesticides manufacturing rulemaklng.
EPA/OW analyses conducted during the OCPSF and pesticide rulemaking did
not evaluate treatment and removal rates for most nonpriority hazardous
constituents. As a result, the amounts of nonpriority hazardous constituents
discharged following PSES Implementation were determined by applying the
removal rates presented 1n Chapter 4. No industry 1n-plant controls were
assumed.
Table 3-6 presents a summary of hazardous constituents for the four
organic chemicals Industrial categories. Hazardous constituent loadings to
POTWs are segregated by metals (I.e., for this study, cyanide 1s Included as a
metal), priority organlcs, and nonpriority organics. This format allows
3-20
-------
TABLE 3-6. SUMMARY OF HAZARDOUS CONSTITUENT LOADINGS TO POTWs FOR ORGANIC CHEMICALS INDUSTRIAL CATEGORIES
ISDB -
Total Hazardous Metals
(kkg/yr)
Total Hazardous Organics -
Priority Constituents Only
(kkg/yr)
Total Hazardous Organics -
Nonpriority Constituents Only
(kkg/yr)
Constituents
Dye Manufacture and Formulation
Organic Chemicals Manufacturing
Plastics, Resins, and Synthetic
Fibers Manufacturing
Pesticides Manufacture
TOTALS
ITD
Data Bases - Priority
Constituents Only
Dye Manufacture and Formulation
Organic Chemicals Manufacturing
Plastics, Resins, and Synthetic
Fibers Manufacturing
Pesticides Manufacture
TOTALS
Raw
431
5,982
120
232
6,765
279
1,022
53
3
1,357
Current PSES
429 <1
5,531 552
120 9
116 2
6,196 563
278 <1
961 5
52 2
1 <1
1,292 8
Raw
434
15,931
8,514
536
25,415
206
6,067
2,200
2,852
11,325
Current PSES
434 <1
15,166 846
8,115 10
267 <1
24,982 856
206 <1
5,824 6
2,106 1
1,426 <1
9,562 8
Raw
11,400
13,918
10,188
28,055
63,561
N/A
N/A
N/A
N/A
N/A
Current
11,400
13,302
5,916
14,027
44,645
N/A
N/A
N/A
N/A
N/A
PSES
136
996
865
533
2,530
N/A
N/A
N/A
N/A
N/A
1
Includes cyanide
N/A - Not Available
-------
effective comparison of metals and priority organlcs loadings based on ITD and
ISDB data bases. Since the ITD data base does not contain data on nonprlorlty
RCRA organlcs, nonprlorlty organic loadings are derived solely from ISDB data
sources.
According to ISDB estimates, under raw conditions the organlcs Industries
discharge 6,765 metric tons per year of hazardous metals and cyanide (6,027
metric tons priority metals and cyanide, 738 metric tons of nonprlorlty
metals). Of this amount, organic chemicals manufacturing accounts for 5,982
metric tons per year, or 88 percent of the total quantity discharged. The ITD
data base projects significantly smaller raw metals and cyanide loadings of
1,357 metric tons per year (priority metals and cyanide only), but also shows
the relative importance of the organic chemicals manufacturing category, which
1s estimated to discharge approximately 75 percent of all hazardous metals.
As indicated in Tables 3-7 and 3-8, both the ITD and ISDB data bases show
substantial loadings of cyanide, chromium, lead, nickel, and selenium. Based
on ITD treatment/removal analyses, Table 3-6 shows that PSES implementation
should result in a 99 percent reduction in hazardous metal loadings to POTWs.
Both the ITD and ISDB data bases show substantial raw loadings of
priority organic constituents to POTWs. The ISDB data source projects a total
raw loading of 25,415 metric tons per year of priority organic constituents.
Of this total, 15,931 metric tons, or 63 percent, are attributed to organic
chemicals manufacturing, while an additional 8,514 metric tons, or 34 percent,
are attributed to plastic, resins, and synthetic fibers manufacturing.
According to ISDB estimates, both dye manufacture and formulation and pes-
ticide manufacturing are less significant sources of priority organic
constituents. The ITD data bases show a total raw loading for priority
organlcs of 11,325 metric tons per year. The ITD data base also demonstrates
the relative importance of the organic chemicals manufacturing category
(54 percent of all loadings) and the pesticides manufacturing category
(25 percent).
Based on treatment data contained 1n the ITD data bases, Table 3-6 shows
minimal constituent reductions at current treatment levels. For the PSES
3-22
-------
TABLE 3-7. TOP 20 HAZARDOUS CONSTITUENTS WITH THE HIGHEST RAW, CURRENT, AND PSES LOADING FOR
FOUR ORGANIC CHEMICALS INDUSTRIAL CATEGORIES - ITD DATA ONLY
C*J
CO
Hazardous
Constituent
Phenol
Benzene
4-Nitropheno1
To! uene
Cyanide
Acrolein
2,4-Dimethyl Phenol
Chlorobenzene
Lead and Compounds
Chromium and Compounds
Acrylonitrile
Ethyl Benzene
1 ,2-Dichloropropane
1 , 1 ,2-Tri chl oroethane
Methylene Chloride
Nitrobenzene
Selenium and Compounds
Naphthalene
Nickel and Compounds
Carbon Tetrachloride
Raw (kkg/yr)
4,504
1,536
1,191
1,126
847
783
648
613
242
188
173
123
104
80
61
55
36
34
32
23
Hazardous
Constituent
Current (kkg/yr)
Phenol
4-Nitrophenol
Benzene
Cyanide
Acrolein
To?uene
2,4-Dimethyl Phenol
Chlorobenzene
Lead and Compounds
Chromium and Compounds
Acrylonitrile
Ethyl Benzene
1,2-01 chl oroproparte
1,1,2-Trichloroethane
Nitrobenzene
Selenium and Compounds
naphthalene
Methylene Chloride
Nickel
Carbon Tetrachloride
4,367
1
189
848
805
746
745
555
307
229
183
163
119
94
72
50
33
33
33
32
19
Hazardous
Constituent
PSES (kkg/yr)
Chromium and Compounds
Nickel and Compounds
Antimony
Selenium and Compounds
Toluene
Lead
Bis(2-Ethy1 Hexyl) phthalate
Cadmium
Phenol
Benzene
Silver
Ethyl Benzene
Naphthalene
Methylene Chloride
Arsenic
Cyanide
Vinyl Chloride
Acrylonitrile
Dimethyl Phthalate
2,4-Dimethylphenol
1.756
1.109
1.054
0.857
0.841
0.627
0.549
0.491
0.424
0.405
0.398
0.266
0.237
0.231
0.207
0.187
0.147
0.129
0.107
0.72
-------
TABLE 3-8. TOP 20 HAZARDOUS CONSTITUENTS WITH THE HIGHEST RAW, CURRENT, AND PSES LOADING FOR
FOUR ORGANIC CHEMICALS INDUSTRIAL CATEGORIES - ISDB DATA ONLY
CO
Hazardous
Constituent
Methanol
Xylene
Phenol*
Formaldehyde
Acetone
Furfural
Anil ine
Tol uene*
Tetrahydrofuran
Methyl Isobutyl Ketone
Acrylonitrile*
Formic Acid
Benzene*
lead and Compounds*
Chromium and Compounds*
Ethyl Benzene*
Nickel and Compounds*
Chloroform*
Cyanide*
Selenium*
Raw {kkg/yr}
18,069
13,767
10,136
9,958
7.137
4,219
2,649
1,873
1,820
1,724
1,586
1.515
1,345
1,149
1,094
1,032
842
828
745
730
Hazardous
Constituent
Current (kkg/yr)
*Priority Pollutants
Methanol
Phenol*
Xylene
Formaldehyde
Furfural
Acetone
Aniline
Tet rahyd rofu ran
Methyl Isobutyl Ketone
Toluene*
Acrylonitrile*
Formic Acid
Benzene*
Lead and Compounds*
Ethylene Benzene*
Chromium and Compounds*
Chloroform*
Nickel and Compounds*
Cyanide*
Naphthalene*
*Prior1ty Pollutants
14,387
9,810
6,898
5,696
4.033
3.773
2,636
1,739
1,648
1,609
1,489
1,448
1,301
1,049
994
948
783
748
710
709
Hazardous
Constituent
Formaldehyde
Butyl Benzyl Phthalate*
Furfural
Xylene
Silver and Compounds*
Acetone
Hethyl Isobutyl Ketone
Formic Acid
Aniline
Cyclohexanone
Tetrahydrofuran
Nickel and Compounds*
Arsenic and Compounds*
2,4-Dinitrophenol*
Anthracene*
Chromium and Compounds*
TetracMoroethylene*
Chloroform*
Selenium and Compounds*
Chlorophenols
PSES (kkg/yr)
854
609
403
345
302
189
165
14S
132
87
87
87
86
68
56
32
31
25
15
14
^Priority Pollutants
-------
scenario, current ITD data project removal rates of greater than 99 percent
for the priority organic constituents. These substantial removal rates are
reflected in the reductions from raw and current discharge levels to PSES
levels for the three OCPSF segments and the pesticide manufacturing category.'
The two d-ata bases show some agreement on specific priority organic
constituents discharged by the organics industries. For example, all 5 of the
priority organics that appear in Table 3-8 among the top 20 constituents under
the raw and current discharge scenarios on the ISDB list {i.e., phenol,
toluene, acrylonitrile, benzene, and ethyl benzene) also are included among
the top 20 constituents on the ITD list {Table 3-7). Based on ITD data, other
significant priority organics include chlorobenzene, 4-nitrophenol,
2,4-dimethylphenol, acrolein, methylene chloride, 1,2-dichloropropane,
1,1,2-trichloroethane, naphthalene, and nitrobenzene.
Table 3-6 also projects loadings of nonpriority organic constituents.
The table shows a total raw loading of 63,561 metric tons per year of non-
priority organic constituents, and substantial loadings from each of the four
organics industries. These loadings, as well as projected current and PSES
loadings, demonstrate that the organics industries discharge substantial
quantities of RCRA hazardous constituents that presently are not regulated
under the CWA priority pollutant list. However, substantial incidental
removal of these pollutants occurs assuming implementation of fully acclimated
biological treatment systems. As indicated in Figure 3-1 and according to
ISDB data, the organics industries discharge raw wastewaters containing 2.5
kilograms of nonpriority organic constituents for each kilogram of priority
organic constituents. Although similar results can be anticipated for the
current and after PSES discharge scenarios, these ratios are not presented
here due to the uncertainty about incidental removal rates for nonpriority
pollutants at current and PSES treatment levels. Table 3-8 contains lists of
the top 20 ISDB constituents for raw, current, and after PSES scenarios.
Major nonpriority constituents on these lists include methanol, xylene,
formaldehyde, acetone, furfural, aniline, tetrahydrofuran, methyl isobutyl
ketone, formic acid, and cyclohexanone. Also, analysis of ISDB results
reveals the presence In organics industry wastewaters of numerous other
3-25
-------
C-J
ro
RAW DISCHARGE
Ratio of Nonpriority to Priority Constituents: 2.5
J
ConsHhwnte - 63.561
Priority Constituents -
15000 2OOOO 25OOO 3OOOO 39000 40000 4SOOO 50000 95000 8OOOO 65000 70000
kkg/y«ar
FIGURE 3-1. COMPARISON OF LOADINGS OF NONPRIORITY TO PRIORITY ORGANIC CONSTITUENTS
FOR THE FOUR ORGANICS CHEMICALS INDUSTRIES
-------
organic and inorganic compounds that are not included in existing RCRA or CWA
pollutant lists.
The pesticides group of hazardous organ'ics has been a major concern over
the past several years. Appendix £ presents the loadings of those hazardous
constituents utilized in the pesticides manufacturing process, as estimated by
both ITD and ISDB methodologies. Loadings to POTWs of specific active
ingredients discharged by pesticide manufacturing facilities have been
estimated ay ITD to support the recent pesticides rulemaking efforts. The
following summarizes these estimated loadings to POTWs:
Pesticide Hazardous
Constituent Groups
2,4-0, 2-4-DB, Alachlor
Atrazine, Di-chlorvos, Mevinphos
Parathion Ethyl, Parathion Methyl
Busan 40, Busan 05, Carbam-S,
KN Methyl, Mancozeb, Maneb,
Metham, ZAC, Zineb
Current Loading
_ (kg/year)
121,813
6,295
After PSES
Loading (kg/year)
1,858
68
Table 3-9 provides a summary of the loadings of volatile and ignitable/
reactive hazardous constituents to POTWs. The hazardous constituents repre-
sented in the table include 59 volatile and 49 ignitable/reactive constituents
identified from a review of the DSS constituent list of 165 constituents.
This analysis examined physical and chemical properties (i.e., flashpoint,
Henry's constant) of the hazardous constituents to determine ignitability and
potential for volatilization. Because many of these compounds are discharged
at low concentrations or are only marginally volatile, discharge of the
constituent does not necessarily imply a concomitant effect, such as volatil-
ization or explosion. Still, the analysis does indicate that substantial
quantities of volatile and ignitable/reactive constituents are discharged to
POTWs. According to ISOB data sources, approximately 63 percent of all
hazardous constituents discharged 1n raw wastes are ignitable/reactive, while
68 percent of these constituents are potentially volatile. According to ITD
data bases, 30 percent of priority hazardous constituents in raw wastes are
ignitable/reactive, while 22 percent of these constituents are potentially
3-27
-------
TABLE 3*9. LOADINGS OF VOLATILE AND IGNITABLE/REACTIVE CONSTITUENTS FROM
THE FOUR ORGANIC CHEMICALS INDUSTRIAL CATEGORIES
Total Volatile Total Ignitable/
Constituents (kkg/yr) Reactive Constituents (kkg/yr)
I SOB -
Priorit * and Nonpriority
Constituents
Dyes and Pigments
Organic Chemicals
Manufacturing
u>
ro Plastics, Resins, and
00 Synthetic Fibers
Pesticides Hanufacturing
TOTALS
ITD Data Base -
Priority Constituents
Only ,
Dyes and Pigments
Organic Chemicals
Manufacturing
Plastics, Resins, and
Synthetic Fibers
Pesticides Manufacturing
TOTALS
Raw
8,769
16,290
10,931
28,080
64,700
2
1,649
110
1,085
2,846
Current After PSES Raw
8,769 3 11,111
15,572 751 16,883
6,543 866 10,937
28,080 1,036 21,423
58,964 2,656 60,354
2 <1 2
1,576 2 2,379
91 1 110
1,085 <1 1,360
2,754 5 3,851
Current
11,111
16,165
6,546
21,423
55,245
2
2,276
92
1,360
3,730
After PSES
121
812
866
703
2,502
<1
2
<1
<1
5
-------
volatile. These loadings indicate that volatilization may be a significant
concern for discharges originating from the organics industries.
Because the ISDB has been developed by EPA/OSW primarily to assist the
Agency in identifying and listing (as hazardous wastes) specific process
wastes from the organic chemicals industries, data contained in ISDB provide
estimates of quantities of concentrated hazardous waste at the point of
production at industrial facilities. Accordingly, estimates derived from ISDB
do not consider the effects of dilution/mixing, volume reduction, or treatment
(e.g., neutralization, biological treatment, chemical precipitation, etc.) on
quantities of hazardous waste ultimately treated, stored, or disposed pursuant
to RCRA requirements. For this reason, estimates presented in this study
cannot be compared with other Agency hazardous waste estimates that consider
the effects of dilution or treatment.
3.2.2.3 RCRA Hazardous Waste Discharges to POTWs from the Four Organic
Chemicals Industrial Categories
As part of the Hazardous Waste Identification and Listing Program,
EPA/OSW has collected and compiled extensive information on the generation and
disposal of hazardous wastes by the organic chemicals industries in the
ISDB. This data base was used to estimate types and quantities of both
characteristic and listed hazardous waste discharged to POTWs by the four
organic chemicals industrial categories. EPA/OSW also has begun an effort to
collect hazardous waste data for the petroleum refining industry. While
nonconfidential RCRA 3007 questionnaires provided some useful data on
hazardous waste disposal practices, most of the petroleum refining data have
not been organized and computerized yet to allow effective comparison with the
other four organics categories.
Table 3-10 provides a detailed summary of hazardous waste data for the
four organics industries. The table disaggregates RCRA data by waste type,
industrial category, and disposal method. In some instances, related waste
types have been grouped together to mask confidential business information.
For example, three characteristic wastes from the pesticides industry have
been added together and designated "DXXX." This grouping technique prevents
3-29
-------
TABLE 3-10. PROFILE OF ULTIMATE DISPOSAL METHODS FOR CONCENTRATED HAZARDOUS HASTES
GENERATED BY FOUR ORGANIC CHEMICALS INDUSTRIES tt»2)
RCRA WASTE
DXXX
Subtotal
D081
Subtotal
1)002
Subtotal
1)1303
t*>
o Subtotal
EP Toxic
Subtotal
Extremely Hazardous
Subtotal
F002
Subtotal
, F003
Subtotal
F004
INDUSTRIES
Organic Chemicals
Pesticides
Plastics & Resins
Dyes and Pigments
Organic Chemicals
Pesticides
Plastics & Resins
Dyes and Pigments
Organic Chemicals
Pesticides
Plastics & Resins
Organic Chemicals
Plastics & Resins
Organic Chemicals
Pesticides
Plastics * Resins
Organic Chemicals
Pesticides
Plastics & Resins
Pesticides
Plastics & Resins
Organic Chemicals
Plastics & Resins
NUMBER
OF I SOB
WASTES
2
3
4
9
14
197
70
125
406
20
347
75
39
481
6
6
12
30
8
2
40
4
4
3
1
4
2
2
4
1
1
EXTRAPOLATED TOTAL
WASTE QUANTITY
(METRIC TONS/YR)
2,278.55
1,110.78
2,414.08
5,803.41
5.035.95 1
5,039,631.00 4
150,461.60 1
655,817.10 2
5,850,945.65 9
783,794.70 144
31,946,941.00 29
1,960,982.00 451
2,125,247.00 6
36,816,964.70 633
25,609.67
1,874.63
27,484.30
13,462,857.00
5,738.30
0.18
13,468,595.48
2,674.56
2,674.56
1,323.63
51.52
1,375.15
24,003.54 23
11.04
24,014.58 23
451.73
3,477.60
EXTRAPOLATED QUANTITY OF
TO POTW
--
0.00
,251.78
,559.09
,493.91
,106.80
,411.58
,693.10
,866.55
,795.40
,830.08
,185.13
0.00
0.30
0.18
0.48
--
0.00
,843.16
,843.16
TO NPDES
0.00
1,872,873.00
19.80
341,802.10
2,214,694.90
636,107.00
11,599,430.00
1,077,551.00
1,765,196.00
15,078,284.00
«
0.00
13,388,432.00
13,388,432.00
0.00
0.00
--
TO INJ. HELL
--
2,212.32
2,212.32
17,589.61
900.90
29.44
18,519.95
846.30
12,258,480.00
383,394.30
12,642,720.60
54.09
1.51
55.60
3,417.82
3,417.82
0.00
"
0.00
WASTES
TO PRI OTW
._
0.00
1,944.36
4,541.12
6,485.48
54,910.07
900.90
1,181.28
56,992.25
0.00
0.00
0.00
0.00
_
OTHER
2,278.55
1,110.78
301.76
3,691.09
3,784.17
3,144,610.00
146,102.60
307,337.70
3,601,834.47
2,148.30
8,004,254.00
47,340.81
352,039.80
8,405,782.91
25,555.58
1,873.12
27,428.70
71,006.22
5,738.30
76,744.52
2,674.56
2,674.56
1,323.63
51.52
1,375.15
160.38
11.04
171.42
451.73
3,477.60
Subtotal
3,929.33
0.00
0.00
0.00
0.00
3,929.33
-------
TABLE 3-10. PROFILE OF ULTIMATE DISPOSAL METHODS FOR CONCENTRATED HAZARDOUS HASTES
GENERATED BY FOUR ORGANIC CHEMICALS INDUSTRIES I1'2) (Continued)
RCRA WASTE
F005
Subtotal
KXXX
Subtotal
to PXXX
CO
H- Subtotal
Toxic
Subtotal
UXXX
Subtotal
TOTAL
INDUSTRIES
Pesticides
Plastics 4 Resins
Organic Chemicals
Pesticides
Plastics & Resins
Organic Chemicals
Dyes and Pigments
Organic Chemicals
Pesticides
Plastics & Resins
Organic Chemicals
Plastics & Resins
NUMBER
OF ISDB
HASTES
2
6
8
112
31
1
144
4
4
3
153
70
42
268
8
2
10
1,396
EXTRAPOLATED TOT/
HASTE QUANTITY
(METRIC TONS/YR)
1,291.95
54,316.80
55,608.75
1,045,131.00
95,153.85
1,586.08
1,141,870.93
1,231.71
1,231.71
3,194.55
4,252,467.00
360,763.10
446,830.50
5,063,255.15
8,923.16
25.76
8,948.92
62,472,702.62
\L
TO POTW
0.00
1,610.90
29,641.59
31,252.49
0.00
1,064.85
1,143.26
21,768.12
23,976.23
0.00
721,669.07
EXTRAPOLATED QUANTITY OF WASTES
TO NPDES
_-
0.00
63,922.78
20,660.31
84,583.09
0.00
240,038.80
145,067.70
11,341.76
396,448.26
3,958.11
3,958.11
31,166,400.36
TO INJ. WEIL
0.00
579,842.20
25,201.44
605,043.64
0.00
323,531.20
1,750.32
390,013.80
715,295.32
0.00
13,987,265.25
TO PR I OTW OTHER
1,291.95
54,316.80
0.00 55,608.75
399,755.20
19,650.51
1,686.08
0.00 420,991.79
1,231.71
0.00 1,231.71
2,129.70
3,687,754.00
0.89 192,176.10
45,475.03
0.89 3,927,534.83
4,965.05
25.76
0.00 4,990.81
63,478.62 16,533,990.04
1 .....
not consider the effects of dilution/mixing, volume reduction, or treatment on waste quantities ultimately treated, stored, or disposed pursuant to RCRA
requirements. Accordingly, these estimates cannot be compared with other Agency hazardous waste estimates that consider the effects of dilution and
treatment.
?
"Some double counting may occur between management practices.
-------
KEY TO TABLE 3-10. HASTE TYPES AS DEFINED BY RCRA §261.21-.33
I
CO
ro
DXXX - Generic listiny for solid wastes exhibitiny the characteristic of EP Toxicity (pesticides and EP metals).
D001 - A solid waste exhibiting the characteristic of ignitability.
DOU2 - A solid waste exhibiting the characteristic of corrosivity.
D003 - A solid waste exhibiting the characteristic of reactivity.
EP Toxic - A solid waste exhibiting the characteristic of EP Toxicity.
Extremely
Hazardous - An acute hazardous waste, as defined in §261.33.
F002 - A listing of hazardous wastes from nonspecific sources, which includes the following spent halogenated solvents:
tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-
1,2,2-trifIuoroethane, ortho-dichlorobenzene, trichloro-fluoromethane; and the still bottoms from the recovery of these solvents,
F003 - A listing of hazardous wastes from nonspecific sources, which includes the following spent nonhalogenated solvents:
xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, methanol;
and the still bottoms from the recovery of these solvent.
F004 - A listing of hazardous wastes from nonspecific sources, which includes the following spent nonhalogenated solvents:
cresols and cresylic acid, nitrobenzene; and the still bottoms from the recovery of these solvents.
F005 - A listing of hazardous wastes from nonspecific sources, which includes the following spent nonhalogenated solvents:
toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine; and the still bottoms from the recovery of these
solvents.
KXXX - A generic listing for hazardous wastes from specific sources.
PXXX - A generic listing for discarded commercial chemical products, off-specification species, container residues, and spill residues
thereof that are identified as acute hazardous wastes.
TOXIC - Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof that are
identified as toxic hazardous wastes.
UXXX - A generic listing for toxic hazardous wastes.
-------
possible identification of individual facility data associated with specific
hazardous waste codes. A key to the different waste codes follows the table.
Table 3-11 provides a summary of hazardous waste generation and discharge
data for the four organics industries and the petroleum refining industry. As
discussed previously, nonconfidential RCRA 3007 questionnaires were used to
estimate waste generation and discharge rates for the petroleum refining
industry. As indicated in Table 3-11, these five categories together generate
over 64 million metric tons of hazardous waste per year. Organic chemicals
manufacturing alone accounts for approximately 55 million metric tons per
year, or approximately 87 percent of all hazardous waste generated. The
remaining four categories each generate substantially smaller quantities of
hazardous waste.
As demonstrated in Figure 3-2, POTW disposal accounts for only a small
portion of all hazardous waste disposal, largely due to the current disposal
practices of the organic chemicals industries. Of the 62 million metric tons
of hazardous waste generated each year, only 720 thousand metric tons, or
1.2 percent of the total quantity, are discharged to POTWs. Alternatively,
approximately 50 percent of all hazardous waste is discharged to surface
waters under NPDES permits, 22 percent is disposed in underground injection
wells, while remaining wastes are incinerated, recovered, discharged to
privately owned treatment works, or disposed at land disposal facilities.
Figure 3-3 provides a source profile for hazardous wastes discharged by
the four organic chemicals industrial categories. As indicated in Figure 3-3,
most hazardous wastes discharged to POTWs originate from the pesticides
manufacturing and dye manufacture and formulation categories, which account
for 73 and 20 percent, respectively. The pesticides and dye industries
discharge 20 and 19 percent, respectively, of their industry wastes to POTWs.
On the other hand, the organic chemicals industry, which generates the largest
quantity of hazardous wastes, discharges only one-tenth of 1 percent of its
3-33
-------
TABLE 3-11. SUmARY OF HAZARDOUS WASTE GENERATION AND DISCHARGE RATES FOR FOUR 1
ORGANIC CHEMICALS INDUSTRIAL CATEGORIES AND PETROLEUM REFINING CATEGORY1
Industry
Dye Mfg. and Formulation
Organic Chemicals
Pesticides
Petroleum Refining*
Plastics and Resins
TOTALS
Total RCRA
Waste Generated
(MT/yr)
792,025
55,788,196
2,600,829
2,002,645
3,291,654
64,475,348
Total RCRA
Waste to POTWs
(MT/yr)
147,010
37,180
528,542
32,458
8,937
754,127
Percent Of Total
Waste Discharged
to POTWs (%)
19.5
4-9
70.1
4.3
1.2
1QQ%
Percent of Waste
Discharged to POTWs
(per industry)
18,6
0*1
20,3
1*6
0,3
1,2%
*Does not include hazardous wastes generated from Coal, Oil, and Petroleum Products portion of
this subcategory. Data presented were extrapolated from 71 nonconfidential RCRA 3007
questionnaires to the total industry response (171 facilities).
This table provides a profile of the ultimate disposal methods for concentrated hazardous wastes as
measured at the point of industrial production, and does not consider the effects of dilution/mixing,
volume reduction, or treatment on waste quantities ultimately treated, stored, or disposed pursuant to
RCRA requirements. Accordingly, these estimates cannot be compared with other Agency hazardous waste
estimates that consider the effects of dilution and treatment.
-------
PROFILE OF ULTIMATE DISPOSAL METHODS FOR CONCENTRATED HAZARDOUS HASTE
GENERATED BY FOUR ORGANIC CHEMICALS INDUSTRIAL CATEGORIES1
Tb4d Hazardous Waste 62X72.7O2 kkg/year
CO
i
CO
en
2ZAK
FIGURE 3-2.
This figure provides a profile of the ultimate disposal Methods for concentrated hazardous wastes as aeasured at the
point of Industrial production, and ooes not consider the effects of dilut1on/»1xfng. voluK reouction or treatKnt
on waste quantities ultimately treated, stored, or disposed of pursuant to HCRA requiraKnts. Accordingly, these
estimates cannot be compared with other Agency hazardous wast- estimates which consider the effects of dilution and
treatment.
-------
CO
I
CO
SOURCE PROFILE FOR CONCENTRATED HAZARDOUS HASTES ULTIMATELY DISCHARGED
BY FOUR ORGANIC CHEMICALS INDUSTRIAL CATEGORIES1
Told Hazardous Waste Discharged to POTWs: 721,669 kkg/year
Mf
528.542
73.2%
Plastics. Resin and Syn. Fibers Ufg.
8.957 kkg/y«ar
1.2%
Organic Chwnicate Mfg.
37.18O Ickg/ywr
5.2%
Dy« and Pfgmwit* Ufg.
147.O10 kkafymar
FIGURE 3-3
This figure provides a source profile for concentrated hazardous waste quantities as Measured at the point of industrial
production, and does not consider the effects of dilution/Mixing, volume reduction or treatment on waste quantities discharged
to POTUs. As indicated in the footnote to Figure 3.2, these quantities should not be interpreted as waste quantities treated,
stored, or disposed of pursuant to RCRA requirements.
-------
hazardous wastes to POTWs. Amendments to RCRA hazardous waste definitions
could significantly change the source profile for hazardous wastes discharged
to POTWs.
Figure 3-4 provides a profile of hazardous waste types discharged to
POTWs by the four organics industries. Figure 3-4 demonstrates that
89 percent of hazardous waste discharged to POTWs represents characteristic
waste. Corrosive wastes alone account for 88 percent of the total. The
remaining 12 percent are listed wastes, including spent solvents {3.3 percent
of all waste), K-code listed wastes (4.3 percent), and unspecified toxic
wastes (3.3 percent). The ISDB does not always provide specific information
on degree of treatment at these organics facilities. Still, in light of the
prohibited discharge standard for corrosive waste (i.e., pH less than 5.0) and
the significant use of equalization, neutralization, or more sophisticated
treatment within these industry groups, it is likely that most of the charac-
teristic waste receives some treatment prior to discharge to a POTW. Sub-
stantial changes in RCRA hazardous waste listings may correspondingly alter
the distribution of waste types discharged to POTWs.
3.3 TYPES AND QUANTITIES OF HAZARDOUS WASTES AND CONSTITUENTS DISCHARGED BY
SELECTED CONSENT DECREE INDUSTRIES
This section presents and evaluates the types and quantities of hazardous
wastes and constituents discharged by selected consent decree industrial
categories. Again, these industrial categories were selected from the list of
industrial categories contained in the 1976 NRDC Consent Decree for which the
EPA/OW was required to develop categorical standards. These selected consent
decree industrial categories (including the four organic chemicals industrial
categories discussed in Section 3.2) constitute the larger generators of
hazardous wastes for which hazardous constituent data were available from ITD,
either 1n terms of total quantity generated by the category as a whole or
generated by individual facilities within an industrial category. These
industry categories are:
3-37
-------
PROFILE OF HAZARDOUS WASTE TYPES DISCHARGED TO POTWs
BY FOUR ORGANIC CHEMICALS INDUSTRIAL CATEGORIES1
Total Hazardous Waste Discharged to POTWs: 72X669 kkg/year
CO
CO
Corrosive Waste (DOO2)
633.185 kkg/year
87.7X
Ignttable Wast* (DOOl)
9.412 kfcg/V*ar
1.3% ^
Spent Solvents (FQ03)
23.643
3.3X
Ustod Wosfe (Kxxx)
31.252
Toxte Waste
23.976 kfcg/Veor
3.3X
FIGURE 3-4
This figure provides a discharge profile for concentrated hazardous waste Quantities as Measured at the point of
industrial production, and does not consider the effects of dilution/Mixing,, voluve reduction or treatment on
waste quantities discharged to POTWs, As indicated in the footnote to Figure 3.2. these quantities should not
be interpreted as waste quantities treated, stored, or disposed of pursuant to RCRA requirements.
-------
Adhesives and Sealants
Battery Manufacturing
Coal, Oil, and Petroleum
Products and Refining
Dye Manufacturing and
Formulation
Electrical and Electronic
Components
Electroplating and Metal
Finishing
Equipment Manufacturing and
Assembly
Explosives Manufacturing
Gum and Wood Chemicals and
Related Oils
Industrial and Commercial
Laundries
Ink Manufacturing and
Formulation
Inorganic Chemicals
Manufacturing
Iron and Steel Manufacturing and
Forming
Leather Tanning and Finishing
Nonferrous Metals Forming
Nonferrous Metals Manufacturing
Organic Chemicals Manufacturing
Paint Manufacturing and
Formulation
Pesticides Formulation
Pesticides Manufacture
Pharmaceuticals Manufacturing
Photographic Chemicals and Film
Manufacturing
Plastics Molding and Forming
Plastics, Resins, and Synthetic
Fibers Manufacture
Porcelain Enameling
Printing and Publishing
Pulp and Paper Mills
Rubber Manufacturing and
Processing
t Textile Mills
Timber Products Processing.
3.3.1 Discharge Characteristics of Selected Consent Decree Industries
The discharge characteristics of the selected industrial categories
discussed in this section are presented in Table 3-12. These characteristics
are: number of direct, indirect, and zero discharge facilities; total number
of facilities; and the total indirect discharge flow for each industrial
category listed. The following five sources were used to develop the basic
characteristics for each industrial category:
DSS Industry Profile Forms
OSW ISDB (for organic chemicals industrial categories only)
3-39
-------
EPA Summary of ITD Rulemaking Activities
t ITD Development Documents
EPA Monitoring and Data Support Division (MDSD) Industry Status
Sheets.
The first data source, DSS Industry Profile Forms, were developed for use
during this study. The basic form, shown 1n Appendix F, was provided to ITD
Project Officers for the Industrial categories analyzed during this study.
DSS Industry Profile Forms were completed by ITD for a majority of the
selected consent decree industrial categories. The completed profile forms
received were treated as the most up-to-date information for a given category.
When DSS Industry Profile Forms were not available, then ITD Development
Documents and the EPA Summary of ITD Rulemaking Activities were used to gather
the basic characteristics for that industrial category. The basic charac-
teristics shown in Table 3-12 represent the industrial category and sub-
category(ies) , as utilized by ITD. Therefore, the numbers may not be totally
representative of the Industry categories developed for this study and
presented in Appendix C. For example, the data presented in Table 3-12 for
the Pulp and Paper industrial category exclude the paper products subcategory
included for this study.
Examination of Table 3-12 reveals that greater than 80 percent of the
indirect dischargers are from two service-related Industrial categories,
industrial and commercial laundries and printing and publishing. The indus-
trial and commercial laundries category also ranks third highest 1n total
indirect discharge flow, preceded only by pulp and paper and electroplating/
metal finishing. The printing and publishing category ranks first in number
of zero dischargers (zero discharger refers to facilities, that may or may not
be connected to a POTW, that generate a process wastewater that is not dis-
charged) followed by timber products processing and paint manufacturing and
formulation. Zero discharge industrial facilities still have potential to
dispose hazardous wastes into a POTW via spills and process changes, if they
are connected to a POTW. The number of zero dischargers shown in Table 3-12
for each industrial category does not differentiate between those industrial
facilities connected or not connected to POTWs. In summary, based on the data
3-40
-------
TABLE 3-12. DISCHARGE CHARACTERISTICS OF SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES
(INCLUDING ORGANIC CHEMICALS INDUSTRIAL CATEGORIES)
Industrial Category
Adhesives and Sealants
Battery Manufacturiny
Coal, Oil, Petroleum Products, and Refining
Dye Manufacturing and Formulation
Electrical and Electronic Components
Electroplating and Metal Finishing
Equipment Manufacturing and Assembly
Explosives Manufacturing
Gum and Wood Chemicals, and Related Oils
Industrial and Commercial Laundries
Ink Manufacturing and Formulation
Inorganic Chemicals Manufacturing
Iron and Steel Manufacturing and Forming
Leather Tanning and Finishing
Nonferrous Metals Forming
Nonferrous Metals Manufacturing
Organic Chemicals Manufacturing
Paint Manufacture and Formulation
Pesticides Formulation
Pesticides Manufacturing
Pharmaceuticals Manufacturing
Photographic Chemicals and Film Manufacturing
Plastics Molding and Forming6
Plastics, Resins, and Synthetic Fibers
Manufacturing
Porcelain Enameling
Printing and Publishing
Pulp and Paper Mills
Rubber Manufacturiny and Processing
Textile Mills
Timber Products Processing
Total Number of
Facil ities
503
254
170
58
379
13,502
N/Aa
170
120
68,800
460
193
1,020
160
741
448
537
1,500
1,255
119
465
142
2,587
382
116
56,337r
674C
l,576f
1,973
14,100
Number of
Indirect
Dischargers
298
149
45K
47b
270
10,561
N/A
4
10
68,635
223
31
162
141
228
123
230°
751
169
38
279
N/A
1,145
153b
88
38,679
261
512
974
7,000
Number of
Di rect
Dischargers
9
21
104.
llb
86
2,941
N/A
24
11
165
237
147
733
17
131
112b
174D
6
0
46
54
N/A
810
124b
28
84
338
1,064
215
500
Number of
Zero
Dischargers
196
84
21
2
23
0
N/A
14Z
99
0
0
15
125
2
382
213
142
743
1,086
25
134
30
632
112
0
17,564
56
0
235
6,600
Total Indirect
Discharge Flow
(MGD)
2.7
7.9
92.3
11.3
33.5
575.7
N/A
<1
3.0
526
<1
18.5
430.7
6.4
36.0
N/A
65.9
0.8
3.9
4.3
48.0
1.6
18.4
21.2
5.6
46.4
585
128.2
3392
-------
presented in Table 3-12, it would appear that if any substantial quantities of
hazardous wastes were generated by the service-related industrial categories,
then based on numbers of indirect and zero discharge facilities, these
facilities also would have the potential to discharge substantial amounts of
hazardous wastes to POTWs.
3.3.2 Priority Hazardous Constituent Loadings for the Selected Consent Decree
Industrial Categories
This section presents priority hazardous constituent loadings for each of
the selected consent decree industrial categories, including the organic
chemicals industrial categories.
3.3.2.1 Methodology for Development of Hazardous Constituent Loadings for the
Selected Consent Decree Industries
This section briefly describes the general methodology utilized to
develop priority hazardous constituent loadings for the selected consent
decree industry categories (the methodologies for development of loadings for
the organic chemicals industrial categories are described in Appendix D and
will not be repeated in this section). The primary data sources for the
hazardous constituent loadings were DSS Industry Profile Forms and ITD
Development Documents for each industry category. DSS Industry Profile Forms
submitted by ITD Project Officers were consulted first to obtain loadings.
Some profile forms contained amended or updated data for an industrial
category, which was not contained in Development Documents. In most cases,
however, reference to Development Documents was made in the profile forms to
obtain priority hazardous constituent loadings. For those industry categories
for which ITD had not submitted DSS Industry Profile Forms, appropriate
Development Documents were utilized.
Depending upon the way in which data were presented within a given
Development Document, raw priority hazardous constituent loadings were derived
primarily in one of three ways:
Screening and verification data presented by facility were used to
develop an average facility loading for the entire category or
preferably by subcategory. This average facility loading then was
3-42
-------
multiplied by the number of indirect discharge facilities within the
category or subcategory and summed to obtain a total category loading.
Screening and verification data presenting average concentrations for
the entire category or individual subcategories were multiplied by
total category or subcategory process flow to obtain a total category
loading (if data were available, frequency of occurrence was taken
into account).
Screening and verification data presenting average mass of
constituents per unit of production for the entire category or
individual subcategories were multiplied by the average production
given for an entire category or subcategory to obtain a total category
loading.
For those industrial categories that have been exempted from regulation
by categorical standards {through Paragraph 8 exclusions), estimates of
current loadings were performed to account for any treatment already in-place
by an industrial category. However, this estimate only was performed when
necessary data were available in ITO Development Documents, Where the
information was not available, a determination of current loadings was not
performed, and raw loadings were assumed to be equal to current loadings.
Further, for those exempt industrial categories, after PSES loadings also were
assumed to be equal to current loadings.
For those industrial categories where categorical pretreatment standards
are proposed or promulgated, an estimate of the reduction of hazardous
priority pollutant loadings as a result of implementation of the standards was
derived. Either these estimates of pollutant reductions were given in
appropriate Development Documents, or they were derived by back-calculating
loadings from the numerical standards for only the regulated pollutants.
Except for the organic chemicals industrial categories, where current loadings
were available, the current loadings were assumed to be equivalent to the
loadings after Implementation of pretreatment standards for these regulated
industrial categories. Although several categorical standards are proposed,
it was assumed that all categorical standards were promulgated and all
facilities are in compliance.
3-43
-------
Several key points and assumptions regarding the development of these
hazardous constituent loadings for the selected consent decree Industrial
categories are as follows:
An average of 250 operating days per year was assumed for all
industrial categories except Iron and steel; and coal, oil, and
petroleum products and refining, where 365 operating days per year
were assumed.
t No incidental removal of other nonregulated constituents was assumed
unless data were provided within ITO Development Documents. Some
reductions of all constituents may have been calculated for a given
category (I.e., leather tanning) 1f flow reduction was considered a
part of the treatment technology to meet categorical standards and
adequate information was provided.
In calculating loadings after implemention of pretreatment standards,
1t was assumed that all facilities within a given Industrial category
were in full compliance and discharging at the allowable level for
each regulated constituent.
Loadings do not account for any removals from a given industrial
facility to meet more stringent or comprehensive local pretreatment
standards applied by the POTW to which they discharge. In addition,
adjustments for local removal credits were not accounted for.
Appendix G presents the annual mass loadings of priority hazardous
constituents for the selected consent decree industrial categories, including
the organic chemicals Industrial categories. As previously discussed in
Section 3.2, data for the four organic chemicals industrial categories will be
presented as eight separate and distinct industrial categories. Again, these
categories comprise the following:
t Dye Manufacture and Formulation (ITD Data)
t Dye Manufacture and Formulation {ISDB Data)
Organic Chemicals Manufacturing (ITD Data)
Organic Chemicals Manufacturing (ISDB Data)
Plastics, Resins, and Synthetic Fibers Manufacturing (ITD Data)
Plastics, Resins, and Synthetic Fibers Manufacturing (ISDB Data)
Pesticides Manufacture (ITD Data)
Pesticides Manufacture (ISDB Data).
3-44
-------
Table 3-13 summarizes the total hazardous constituent loadings (priority
pollutant metals and priority pollutant organics only) under the raw, current,
and after implementation of pretreatment standards (herein referred to as
"after PSES") scenarios for each industrial category. Appendix G also
provides data for several industrial categories for nonhazardous priority
pollutant metals (i.e., copper and zinc), other hazardous metals (i.e.,
thallium and barium), other priority hazardous organics, and other nonpriority
hazardous organics. These data were incorporated into Appendix G for a
limited number of industrial categories, due primarily to the data sources
available for each industrial category and the methodology utilized for the
development of these loadings.
3.3.3 Analysis of Hazardous Constituent Loadings for the Selected Consent
Decree Industrial Categories
Based on the data presented in Appendix G and summarized in Table 3-13,
each industrial category was ranked according to hazardous constituent
loadings. Tables 3-14 and 3-15 present the top 10 selected consent decree
industrial categories (including the organic chemicals industrial categories)
with the highest total hazardous constituent loadings for priority pollutant
metals and organics, respectively, under the raw, current, and after PSES
scenarios. Table 3-16 presents the top 10 selected consent decree industrial
categories (including the organic chemicals industries) with the highest total
priority hazardous constituent loadings, also under the raw, current, and
after PSES .scenarios. To avoid double-counting for the organic chemicals
industrial categories that were analyzed during this study using both ITD and
ISDB methodologies, the higher of the two loadings calculated are shown in the
rankings in Tables 3-14 to 3-16, with the lower of the two loadings presented
in parentheses.
The electroplating/metal finishing industrial category accounts for the
highest raw hazardous metals loadings, followed by the organic chemicals
manufacturing (ISDB) category. Three of the organic chemicals industrial
categories [organic chemicals manufacturing (ISOB); dye manufacture and
formulation (ISDB); and plastics, resins, and synthetic fibers (ISDB)] are
present in the top 10 current hazardous metals loadings. This may be due in
3-45
-------
TABLE 3-13. LOADINGS OF TOTAL PRIORITY HAZARDOUS METALS AND CYANIDE
AND TOTAL PRIORITY HAZARDOUS ORGANICS FOR SELECTED CONSENT
DECREE INDUSTRIAL CATEGORIES*
INDUSTRIAL CATEGORY
TOTAL PRIORITY
HAZARDOUS METALS AND CYANIDE
(kkg/yr)
RAW CURRENT AFTER PSES
TOTAL PRIORITY
HAZARDOUS OKGANICS
(kkg/yr)
RAW CURRENT AFTER PSES
Adhesives & Sealants
Battery Mfg.
Dyes Mfg. and Formulation (ITD)
Dyes Mfg. and Formulation (ISDB)
Electrical & Electronic
Components
Electroplating & Metal
Finishing
Equipment Mfg. & Assembly
Explosive Mfg.
Gum & Wood Chemicals
Industrial & Comm. Laundries
Ink Mfg. & Formulation
Inorganic Chemicals Mfg.
Iron A Steel Mfg.
Leather Tanning & Finishing
Nonferrous Metal Forming
Nonferrous Metal Mfg.
Organic Chemicals Mfg. (ITD)
Organic Chemicals Mfg. (ISDB)
Paint Mfg. & Formulation
Pesticide Mfg. (ITD)
289
1509
279
431
158
42339
N/A
<1
2
595
3
1053
3920
5097
203
114
1021
5981
17
3
131
<1
278
429
74
1017
N/A
<1
2
502
3
103
97
375
2
1
961
5531
15
1
131
<1
<1
1
74
1017
N/A
<1
2
502
3
103
97
375
2
1
5
552
15
<1
97
<1
206
434
315
3631
7715
<1
51
984
<1
0
2715
210
N/A
9
4627
9068
49
2852
70
<1
206
434
32
175
7715
<1
51
984
<1
0
236
164
N/A
1
4406
8717
42
1426
70
<1
<1
1
32
175
7715
<1
51
984
<1
0
236
164
N/A
1
5
679
42
<1
3-46
-------
TABLE 3-13. LOADINGS OF TOTAL PRIORITY HAZARDOUS METALS AND CYANIDE
AND TOTAL PRIORITY HAZARDOUS ORGANICS FOR SELECTED CONSENT
DECREE INDUSTRIAL CATEGORIES1 (Continued)
INDUSTRIAL CATEGORY
TOTAL PRIORITY
HAZARDOUS METALS AND CYANIDE
(kkg/yr)
RAW CURRENT AFTER PSES
TOTAL PRIORITY
HAZARDOUS ORGANICS
(kkg/yr)
RAW CURRENT AFTER PSES
Pesticide Mfg. (ISDB)
Pesticides Formulation (ITD)
Petroleum Refining
Pharmaceutical Mfg.
Photo. Chemicals & Film Mfg.
Plastics Molding & Forming
Plastics, Resins & Syn.
Fibers (ITD)
Plastics, Resins & Syn.
Fibers (ISDB)
Porcelain Enameling
Printing & Publishing
Pulp & Paper Mills
Rubber Mfg.
Textile Mills
Timber Products
232
N/A
485
4563
184
9
52
120
177
155
100
3
79
3
116
0
485
35
66
9
52
120
17
145
100
3
79
3
2
0
485
35
66
9
2
9
17
145
100
3
79
3
326
N/A
1686
7369
5
19
2168
8498
1
17
806
15
370
34
163
<1
1686
7369
4
19
2075
8100
<1
16
749
15
370
11
<1
0
1686
7369
4'
'19
1
10
<1
16
749
15
370
11
Unless otherwise specified, loadings estimates are derived from ITD data sources.
3-47
-------
TABLE 3-14. TOP TEN INDUSTRIAL CATEGORIES WITH THE HIGHEST LOADINGS FOB
TOTAL HAZARDOUS CONSTANTS (PRIORITY METALS AND CYANIDE)1
INDUSTRIAL CATEGORY
Electroplating & Metal Finishing
Organic Chemical's Manufacturing - ISDB (ITD)
Leather Tanning & Finishing
Pharmaceutical Manufacturing
Iron & Steel Manufacturing
Battery Manufacturing
Inorganic Chemicals Manufacturing
Industrial & Commercial Laundries
Petroleum Refining
Dye Manufacturing and Formulation - ISDB (ITD)
INDUSTRIAL CATEGORY
Organic Chemicals Manufacturing - ISDB (ITD)
Electroplating & Metal Finishing
Industrial & Commercial Laundries
Petroleum Refining
Dye Manufacturing and Formulation - ISDB (ITD)
Leather Tanning & Finishing
Printing & Publishing
Adhesives & Sealants
Plastics, Resins, & Synthetic Fibers - ISDB
Inorganic Chemicals Manufacturing
INDUSTRIAL CATEGORY
(ITD)
Electroplating & Metal Finishing
Organic Chemicals Manufacturing - ISDB (ITD)
Industrial & Commercial Laundries
Petroleum Refining
Leather Tanning & Finishing
Printing & Publishing
Adhesives & Sealants
Inorganic Chemicals Manufacturing
Pulp & Paper Mills
Iron & Steel Manufacturing
RAW LOADING
(kkg/year)
42,339
5,981 (1,021)
5,097
4,563
3,920
1,509
1,053.
595
485
431 (279)
CURRENT LOADING
(kky/year)
5,531 (961)
1,017
502
485
429 (278)
375
145
131
120 (52)
103
AFTER PSES LOADING
(kkg/year)
1,017
552 (5)
502
484
375
145
131
103
100
97
1
Unless otherwise specified, loadings estimates are derived from ITD data
sources.
3-48
-------
TABLE 3-15. TOP TEN INDUSTRIAL CATEGORIES WITH THE HIGHEST LOADINGS
FOR TOTAL HAZARDOUS CONSTITUENTS (PRIORITY ORGANICS)1
INDUSTRIAL CATEGORY
Organic Chemicals Manufacturing - ISDB (ITD)
Plastics, Resins, & Synthetic Fibers - ISDB (ITD)
Equipment Manufacturing & Assembly
Pharmaceutical Manufacturing
Electroplating & Metal Finishing
Pesticides Manufacturing - ITD (ISDB)
Iron & Steel Manufacturing
Petroleum Refining
Industrial & Commercial Laundries
Pulp & Paper Mills
INDUSTRIAL CATEGORY
Organic Chemicals Manufacturing - ISDB (ITD)
Plastics, Resins, & Synthetic Fibers - ISDB (ITD)
Equipment Manufacturing & Assembly
Pharmaceutical Manufacturing
qupmen anuacurng s
Pharmaceutical Manufacturing
Petroleum Refining
- ITD
Pesticides Manufacturing - ITD (I
Industrial & Commercial Laundries
P ,p & Paper Mills
Dve Manufacturing and Formulation
Textile Mills
(ISDB)
- ISDB
RAW LOADING
(kkg/year)
9,068 (4,627)
8,498 (2,168)
7,715
7,368
3,631
2,852 (326)
2,715
1,686
984
806
CURRENT LOADING
(kkg/year)
8,717 (4,406)
8,100 (2,075)
7,715
7,369
1,686
1,426 (163)
984
749
434 (206)
370
INDUSTRIAL CATEGORY
Equipment Manufacturing & Assembly
Pharmaceutical Manufacturing
Petroleum Refining
Industrial & Commercial Laundries
Pulp & Paper Mills
Organic Chemicals Manufacturing - ISDB (ITD)
Textile Mills
Iron & Steel Manufacturing
Electroplating & Metal Finishing
Leather Tanning and Finishing
AFTER PSES LOADING
(kkg/year)
7,715
7,369
1,686
984
749
679 (5)
370
236
175
164
1
Unless otherwise specified, loadings estimates are derived from ITD data
sources.
3-49
-------
TABLE 3-16. TOP TEN INDUSTRIAL CATEGORIES WITH THE HIGHEST LOADINGS ,
FOR TOTAL HAZARDOUS CONSTITUENTS (ALL PRIORITY POLLUTANTS)
INDUSTRIAL CATEGORY
Electroplating & Metal Finishing
Organic Chemicals Manufacturing - ISDB (ITD)
Pharmaceutical Manufacturing
Plastics, Resins, & Synthetic Fibers - ISDB (ITD)
Equipment Manufacturing & Assembly
Iron & Steel Manufacturing
Leather Tanning & Finishing
Pesticides Manufacturing - ITD (ISDB)
Petroleum Refining
Industrial & Commercial Laundries
INDUSTRIAL CATEGORY
Organic Chemicals Manufacturing - ISDB
Plastics, Resins, & Synthetic Fibers -
Equipment Manufacturing & Assembly
Pharmaceutical Manufacturing
Petroleum Refining
Industrial & Commercial Laundries
Pesticide Manufacturing - ITD (ISDB)
Electroplating £ Metal Finishing
Dyes & Pigments - ISDB (ITD)
Pulp & Paper Mills
INDUSTRIAL CATEGORY
Equipment Manufacturing & Assembly
Pharmaceutical Manufacturing
Petroleum Refining
Industrial & Commercial Laundries
Electroplating & Metal Finishing
Organic Chemicals Manufacturing - ISDB
Pulp & Paper Mills
Leather Tanning & Finishing
Textile Mills
Iron and Steel Manufacturing
(ITD)
ISDB (ITD)
(ITD)
RAW LOADING
(kkg/year)
45,970
15,049 (5,648)
11,931
8,616 (2,221)
7,715
6,635
5,307
2,855 (558)
2,171
1,579
CURRENT LOADING
(kkg/year)
14,248 (5,367)
8,218 (2,127)
7,715
7,404
2,171
1,486
1,427 (279)
1,191
861 (484)
850
AFTER PSES LOADING
(kkg/year)
7,715
7,404
2,171
1,486
1,191
1,231 (10)
850
539
450
333
1
Unless otherwise specified, loadings estimates are derived from ITD data
sources.
3-50
-------
part to the methodologies utilized for estimating current loadings for the
organic chemicals industrial categories compared to the other selected consent
decree industrial categories. Briefly, current loadings for the organic
chemicals Industrial categories were estimated or actually calculated. On the
other hand, current loadings for the other selected consent decree industrial
categories were assumed to be equivalent to after PSES loadings either because
no PSES have been proposed or promulgated or because it was assumed that PSES
compliance dates already have passed for categories regulated by PSES. The
electroplating/metal finishing Industrial category also accounts for the
highest loading of hazardous metals after compliance with PSES. Under both
the current and after PSES scenarios, three industrial categories in the top
10 with the highest priority hazardous metals loadings are those that have
been exempted from regulation by categorical standards through the Paragraph 8
Exclusion in the 1976 NRDC Consent Decree with EPA (i.e., industrial and
commercial laundries, adhesives and sealants, and printing and publishing).
The organic chemicals industrial categories dominate the top 10 rankings
for the raw and current loadings for priority hazardous organics. Based upon
proposed categorical standards, however, the hazardous organics loadings
(priority only) drop significantly for these organic chemicals industrial
categories after PSES. Thus, other industrial categories account for the
majority of the top 10 organic hazardous constituent loadings in the after
PSES scenario. Again, several industrial categories exempt from regulation
under categorical standards or regulated for metal pollutant parameters only
appear in the top 10 hazardous constituent loadings, but in this instance for
priority organics (i.e., equipment manufacturing and assembly, pharmaceutical
manufacturing, Industrial and commercial laundries, and textile mills).
In terms of total hazardous constituent (priority pollutant) loadings,
the electroplating/metal finishing Industrial category ranks first and
accounts for almost 40 percent of the total raw loadings of the top 10. The
organic chemicals industries dominate the current loadings of the total
hazardous constituents and account for approximately 30 percent of total
current loading from the top 10 Industrial categories. Equipment manufacture
and assembly ranks first in total hazardous constituent loadings after PSES.
3-51
-------
Equipment manufacturing and assembly combined with the Industrial and commer-
cial laundries Industrial category, representing two Industrial categories
unregulated by categorical standards, account for approximately 35 percent of
the total hazardous constituent loadings after PSES for the top 10 Industrial
categories.
Based on data 1n Appendix G, Table 3-17 presents the top 20 hazardous
constituents {priority pollutants) with the highest loadings under the raw,
current, and after PSES scenarios. Table 3-17 shows that many of the top 20
hazardous constituents that appear 1n raw loadings from the selected consent
decree Industrial categories are either priority metals, organic solvents, or
cyanide. The priority metals tend to drop in rankings under the current and
after PSES scenarios. This 1s probably due to the fact that most categorical
standards regulate priority metal parameters, and thus a reduction in these
loadings would be expected. Alternatively, the priority organic solvents
remain high in total loadings in the current and after PSES scenarios due to
the lack of regulation of these solvents through categorical standards 1n many
of the selected consent decree Industrial categories.
PCBs and pesticides are two groups of hazardous organlcs that have been
of major concern over the past several years. At least for the selected
consent decree industrial categories, PCBs were not found in significant
quantities. PCBs are now banned from production 1n the United States, further
use of PCBs 1s strictly regulated, and PCBs are no longer used to the extent
that they were in the past. Pesticides were essentially absent from waste-
waters discharged to POTWs from facilities within the selected consent decree
industrial categories, except where their presence might be expected (I.e.,
pesticides manufacturing and pesticides formulation). Section 3.2.3 discusses
the loadings of hazardous constituents to POTWs for the pesticides manufac-
turing Industrial category. As for the pesticides formulation industrial
category, Appendix G provides loadings to POTWs for those hazardous con-
stituents (priority only) utilized in, and Identified 1n the wastewaters of,
pesticides formulating facilities. In support of ITD's recent pesticides
rulemaking efforts, estimates of specific pesticide active ingredients
loadings to POTWs were determined. Following 1s a summary of these estimated
3-52
-------
TABLE 3-17. TOP TWENTY HAZARDOUS CONSTITUENTS (PRIORITY POLLUTANTS)
WITH THE HIGHEST LOADINGS FOR THE SELECTED CONSENT DECREE
INDUSTRIAL CATEGORIES1
HAZARDOUS CONSTITUENT
Chromium and Compounds
Nickel and Compounds
Cyanide
Phenol
Methylene Chloride
1,1,1-Trichloroethane
Lead and Compounds
Toluene
Benzene
Ethyl Benzene
Trichloroethylene
Tetrachloroethylene
Chloroform
Bis{2-Ethyl Hexyl) Phthalate
2,4-Dimethyl Phenol
Naphthalene
Silver and Compounds
Arsenic and Compounds
Butyl Benzyl Phthalate
Acrolein
RAW LOADING (kkg/year)
30,194
14,521
14,424
13,002
5,681
5,U74
5,002
4,107
2,320
2,239
2,211
1,997
1,947
1,313
1,158
1,147
901
803
793
785
HAZARDOUS CONSTITUENT
Phenol
Methylene Chloride
1,1,1-Trichloroethane
To!uene
Ethyl Benzene
Chromium and Compounds
Chloroform
Benzene
Trichloroethylene
Lead and Compounds
Tetrachloroethylene
Nickel and Compounds
Cyanide
Bis(2-Ethyl Hexyl)Phthalate
Naphthalene
2,4-Dimethyl Phenol
Silver and Compounds
Acrolein
Butyl Benzyl Phthalate
Arsenic and Compounds
CURRENT LOADING (kkg/year)
10,739
5,480
3,925
3,618
2,179
2,058
1,900
1,859
1,725
1,563
1,506
1,452
1,436
1,207
917
789
749
748
732
704
3-53
-------
TABLE 3-17. TOP TVENTY HAZARDOUS CONSTITUENTS (PRIORITY POLLUTANTS)
WITH THE HIGHEST LOADINGS FOR THE SELECTED CONSENT DECREE
INDUSTRIAL CATEGORIES1 (Continued)
HAZARDOUS CONSTITUENT
Methylene Chloride
1,1,1-Trichloroethane
Toluene
Trichloroethylene
Tetrachloroethylene
Ethyl Benzene
Chromium and Compounds
Chloroform
Antimony and Compounds
Phenol
Nickel and Compounds
Butyl Benzyl Phthalate
Cyanide
Benzene
Bis(2-Ethyl Hexyl)Phthalate
Lead and Compounds
Silver and Compounds
2,4-Dimethyl phenol
Naphthalene
1,2-Dichloroethane
AFTER PSES LOADING (kkg/year)
5,399
3,924
2,012
1,720
1,410
1,189
1,142
1,142
986
929
790
670
631
564
532
519
360
234
212
120
'Loadings estimates are based largely on ITD data sources, but may include
some data derived from ISDB data for the organics industries.
3-54
-------
loadings to POTWs from pesticides formulators for those pesticides that also
are considered hazardous constituents:
Pesticide Hazardous
Constituent Group
Disulfoton, Diazinon, Dichlorvos,
Naled, Pyrethrins, and related
Pyrethrin compounds
Carbaryl, Chloropyrifos, Deet,
Malathion, Propanil, Propoxur,
3,4-Dichloroaniline
Current Loading
(kg/yr)
764
183
After PSES
loading (kg/yr)
751
18
Table 3-18 presents the total volatile and ignitable/reactive hazardous
constituents loadings (priority pollutants) for each of the selected consent
decree industrial categories. The loadings presented in Table 3-18 are
derived by adding the specific priority hazardous constituents considered
volatile and ignitable/reactive for this study and described in Chapter 2. As
discussed previously, because many of these constituents are discharged at low
concentrations or are only marginally volatile, discharge of these constit-
uents to POTWs may not always result in volatilization or explosions. The
purpose of Table 3-18 is to gauge the extent of discharge of RCRA charac-
teristic wastes from the selected consent decree industrial categories as
measured by specific hazardous constituents that are considered volatile or
ignitable/reactive. As illustrated in Table 3-18, two industrial categories
that are not associated with the organic chemicals industrial categories are
responsible for the two largest loadings of volatile hazardous constituents.
These two industrial categories are equipment manufacture and assembly and
pharmaceutical manufacturing. As described earlier, these two industrial
categories also are not regulated by categorical standards for organic
hazardous constituents, many of which also are considered volatile.
3.3.4 Analysis of Other Pertinent Data for the Selected Consent Decree
Industrial Categories
In addition to the data extracted from the DSS Industrial Profile Forms
provided by EPA and supplemented by ITD Development Documents and data bases,
data were incorporated from additional sources. The supplemental data
3-55
-------
TABLE 3-18. LOADINGS OF TOTAL VOLATILE POLLUTANTS (TVP) AND
TOTAL IGNITABLE/REACTIVE POLLUTANTS (TI/RP) FOR
SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES*
INDUSTRIAL
CATEGORY
Adhesives & Sealants
Battery Mfg.
Dyes & Pigments (ITD)
Dyes & Pigments (ISDB)
Electrical & Electronic
Comp.
Electroplating £ Metal
Finishing
Equipment Mfg. & Assembly
Explosive Mfg.
Gum & Wood Chemicals
Industrial & Comm. Laundries
Ink Mfg. & Formulation
Inorganic Chemicals Mfg.
Iron & Steel Manufacturing
Leather Tanning & Finishing
Nonferrous Metals Forming
Nonferrous Metals Mfg.
TVP LOADINGS*
RAW CURRENT
32,707
912
2,528
26.060
202,644
2,303,223
7,714,928
0
43,047
380,927
64
13,303
444,435
12,699
N/A
923
18,002
5
2,528
26,060
20,348
41,987
7,714,928
0
43,047
380,917
64
200
72,758
10,284
N/A
554
(kg/yr)
AFTER PSES
18,002
5
29
118
20,348
41,987
7,714,928
0
43,047
380,917
64
200
72,758
10,284
N/A
554
TI/RP LOADINGS* (kg/yr)
RAW CURRENT AFTER PSES
5,895
47
2,520
3,885
3,879
8,002,298
381,927
1
35,105
289,891
37
0
1,227,819
8,852
1,205
252
5,836
3
2,520
3,885
1,175
148,964
381,927
1
35,105
289,891
37
0
143,208
7,180
149
249
5,836
3
22
97
1,175
148,964
381,927
1
35,105
289,891
37
0
143,208
7,180
149
249
Organic Chemicals Mfg
{ITD}
Organic Chemicals Mfg
(ISDB)
1,649,746 1,576,830 2,961 2,379,952 2,276,539 2,426
4,390,912 4,227,327 65,151 3,882,678 3,767,671 5,630
3-56
-------
TABLE 3-18. LOADINGS OF TOTAL VOLATILE POLLUTANTS (TVP) AND
TOTAL IGNITABLE/REACTIVE POLLUTANTS (TI/RP) FOR
SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES* (Continued)
INDUSTRIAL
CATEGORY
TVP LOADINGS* (kg/yr) TI/RP LOADINGS* (kg/yr)
RAW CURRENT . AFTER PSES RAW CURRENT AFTER PSES
Paint Mfg. & Formulation
Pesticides Mfg. (ITD)
Pesticides Mfg. {ISDB)
Pesticides Formulation (ITD)
Petroleum Refining
Pharmaceutical Mfg.
Photo. Chemicals &
Film Mfg.
Plastics Molding & Forming
Plastics, Resins &
Syn. Fibers (ITD)
Plastics, Resins, & Synthetic
Fibers (ISDB)
Porcelain Enameling
Printing & Publishing
Pulp & Paper Mills
Rubber Mfg.
Textile Mills
Timber Products
47,075 40,234
2,165,868 1,082,934
333,098 16,549
N/A 249
40,234 32,561 27,558 27,558
389 2,718,248 1,359,124 391
138 287.878 143,939 16
0 N/A 29 0
1,218,364 1,218,364 1,218,364 1,537,976 1,537,976 1,537,976
6,994,833 6,994,833 6,994,833 5,846,715 1,319,073 1,319,073
463
4,447
110,005
430
4,447
91,020
430
4,447
550
852,005
219
11,399
576,992
15,093
252,527
3,268
727,610
184
10,591
576,992
15,093
252,527
3,268
9,396
184
10,591
576,992
15,093
252,527
3,268
2,229 1,867 1,867
1,011 1,011 1,011
110,126 92,059 498
852,972 728,577 9,400
107 90 90
23,066 21,513 21,513
375,260 375,260 375,260
15,093 15,093 15,093
184,117 184,117 184,117
2,933 1,616 1,616
*Priority volatile and ignitable/reactive constituents only. Unless otherwise specified,
loadings estimates are derived from ITD data sources.
3-57
-------
gathered assisted in filling data gaps, such as the presence of nonpriority
hazardous constituents and specific listed hazardous wastes being generated
and/or discharged to POTWs , as well as in augmenting priority hazardous
constituent data gathered from ITD.
Several additional data sources have been identified and evaluated for
possible use in the DSS. These are:
OSW SQG Survey Data
OW Paragraph 4(c) Sampling Data
OSW Hazardous Waste Data Management System
State/Local Industrial Data
Industrial Incidents Files.
3.3,4.1 OSW SQG Survey Data
In the preamble to the 1980 RCRA regulations, EPA stated that, based on
available data, 99 percent of hazardous waste generators produce less than
1,000 kg/month of hazardous waste and that this represents less than 1 percent
(2\
of the total hazardous waste generated/ ' Therefore, the Agency initially
suggested an exclusion level for those facilities that generate less than
1,000 kg/month of hazardous waste. These facilities exempted from full
regulation under RCRA often are referred to as SQGs. In the 1984 RCRA
Amendments, Congress added provisions, applicable to these SQGs, which will
result in changes to the current regulations. Under the new provisions,
facilities that generate 100 kg/month, but less than 1,000 kg/month, will have
to comply with those requirements that cover the transportation and disposal
f 3\
of hazardous waste/ ' The SQG Survey was conducted for OSW to assemble
information necessary to determine the economic and environmental Implications
of the available regulatory options.
The major objectives of the SQG Survey were to develop reliable estimates
of the types and numbers of SQGs, to identify types and quantities of
hazardous waste generated by these facilities, and to describe the methods by
(4\
which those wastes are managed. ' Approximately 50,000 of the estimated
600,000-660,000 establishments that were considered SQGs were surveyed,
3-58
-------
resulting 1n a data base containing nearly 19,000 responses. One hundred and
twenty-five SIC codes were chosen for Inclusion in the survey and combined
into 22 larger industry groups; the remaining SIC codes were excluded from the
survey because they were similar to those already included or because they
were unlikely to contain significant numbers of SQGs. These industry group-.
ings were determined primarily according to waste types that the establish-
ments 1n each of the SIC codes were expected to generate. For each waste-
stream, respondents were asked to indicate whether or not the firm generated
the waste, the quantity of waste generated, and how the waste was managed and
disposed. Two limitations exist in the survey data. First, some double
counting of SQGs and associated waste quantities exists when examining
breakdowns by management practices. Second, the results of the survey are
two-tiered: respondents provided detailed reports of their generation and
handling practices that were specifically targeted for their type of estab-
lishment, while for additional nontargeted wastes, they reported wastes that
were generated, but did not provide any indepth information concerning waste
quantities or management practices.
The SQG Survey data base was useful to the DSS since it provided
hazardous waste generation and disposal information for the SQGs within each
industrial category. Detailed data are presented for onsite storage, treat-
ment, recycling, and disposal activities, including discharge to POTWs. Using
the responses from the survey, the data were weighted using statistical models
along with knowledge of the industrial categories to estimate the total number
of SQGs in each industry and the amount of hazardous waste discharged
annually. A summary of the hazardous wastes discharged by SQGs to POTWs is
shown in Table 3-19 (the selected consent decree industrial categories are
shown in bold face).
The hazardous waste quantities shown in Table 3-19 represent only the
SQG segment of an industrial category. For a few selected consent decree
industrial categories made up predominantly of SQGs (i.e., industrial and
commercial laundries, printing and publishing); these hazardous waste quan-
tities in Table 3-19 may be representative of the entire Industrial category.
However, for many of the other selected consent 'decree industrial categories,
3-59
-------
TABLE 3-19. NUMBER OF INDIRECT DISCHARGES AND HAZARDOUS HASTE QUANTITIES FOR SMALL QUANTITY GENERATORS1
Weighted Total Quantity
Unweighted 9
of Facil ities
Industrial Category in Survey
Battery HHwfactvriAg
Construction Industry
Cosmetics, Franyrances, Etc.
Electrical ft Electrical Components
Clectroplating/Netal Finishing
Equipment Manufacturing
Explosives Manufacturing
Fertilizer Manufacturing
Gun ft Hood Chemicals ft Related Oils
Industrial ft Commercial Laundries
Ink Manufacturing
Inorganic Chemicals Manufacturing
Iron ft Steel Manufacturing
Laboratories & Hospitals
Leather Tanning ft Finishing
Misc. Chenricals Formulation
Motor Vehicles Services
Manferrous Metals Forming
Organic Chemicals, Plas., ft Svn. Fibers
Pesticides Manufacturing
Pharmaceuticals Manufacturing
Photographic Chemicals ft Film
Plastics Holding ft Forming
Porcelain Enameling
Printing * Publishing
Pulp ft Paper Hills
Rubber Manufacturing ft Processing
Service Related Industries
Soap ft Detergents
Stone, Clay, Glass, Etc.
Textile Mills
Timber Products Processing
Transportation Services
Wholesale ft Retail Trade
Wood Furniture Manufacture
TOTAL
3
86
56
9
65
258
59
44
4
530
61
46
11
333
12
169
292
3
84
29
63
4
192
8
4B2
95
22
1,716
170
13
55
121
213
119
102
5,529
Weighted Weighted * of
Total » of Facilities Discharging
Facilities to POTW
5
16,988
209
1,247
6,196
30,027
209
129
11
15,625
228
134
838
5,643
230
565
191,901
207
262
115
247
251
2,306
662
24,150
626
67
43.930
602
104
273
946
28.951
5,733
2,393
382,010
0
1,076
33
148
1,490
2,424
27
17
0
1,157
35
20
57
2,926
19
80
3,587
0
29
12
32
21
136
28
14,293
71
0
23,395
209
0
73
30
582
366
200
52,573
Of Hazardous Waste
Discharged to POTW
(Kg/ year)
0
242,088
69,960
1,693,548
3,252,264
5,423,8'
27
22
t
1,514,508
71,076
22,572
264,780
2,099,664
8,832
188,316
1,318,860
0
77,484
14,112
46,056
7,068
142,776
144
9,187,116
118,356
0
23,146,068
621,168
0
127,284
33,684
26,436
160,020
399,696
50,328,180
Weighted Total Quantity
of Hazardous Haste
Discharged to POTU
Per Facility
(Kg/year)
225
2,120
11,440
2,181)
2,240
1,030
1,330
1,310
2,030
1,130
4,650
720
465
2,350
370
2,670
1,180
1,440
335
1,050
5
640
1,670
990
2,970
1,740
1,120
45
440
2,000
960
^Derived from Reference (5)
-------
these SQG facilities represent only a small fraction of a larger industrial
category. Thus, the hazardous waste quantities presented for these industrial
categories 1n Table 3-19 are not totally representative.
In addition, the categorization of industries in the DSS differs from the
categorization chosen in the SQG Survey. SIC codes grouped as a unit in the
SQG Survey were separated into various industrial categories in this report.
Breaking up these clusters of representative SIC codes causes the statistical
validity of the information to decrease. Careful consideration was taken in
the incorporation of the 125 SIC codes used in the SQG Survey into the 47
industrial categories utilized in this study in order to obtain a represen-
tative sampling. Separation of SIC codes was minimized whenever possible to
keep the usefulness of the SQG Survey to this project as high as possible (the
breakdown of SIC codes into industrial categories is shown in Appendix C).
Finally, some double counting of waste quantities discharged to POTWs
occurred occasionally due to the restructuring of industrial categories for
this study. In a few instances, a SIC code fell into more than one industrial
category, which caused the waste quantity associated with this SIC code to
appear twice (e.g., SIC 3679 appears in the electrical and electronic com-
ponents industrial category as well as the electroplating/metal finishing
industrial category). The effect of double counting is estimated to increase
the total quantity of waste discharged to POTWs, shown 1n Table 3-19, by
approximately 5 percent (from 47,754 metric tons/year to 50,328 metric
tons/year).
Table 3-19 shows the printing and publishing (9,187,116 kg/yr), equipment
manufacture and assembly (5,423,820 kg/yr), and industrial and commercial
laundries (1,514,508 kg/yr) industrial categories together account for over
45 percent of the total quantity of hazardous wastes discharged to POTWs from
SQGs within the consent decree industrial categories. From a different
perspective, the SQG segment of the electrical and electronic components
industrial category has the highest quantity per facility (11,440 kg/yr) of
hazardous waste discharged to POTWs by SQGs.
3-61
-------
The SQG Survey data do not Include specific constituents found 1n the
hazardous waste discharges, but rather describe generic waste types, such as
Ignltable wastes, photographic wastes, and wastewater wood preservatives.
Table 3-20 lists the wastetype(s) that account for at least 90 percent of the
waste quantity discharged to POTWs by Industrial category, and attempts to
Identify typical constituents for each Industry that would account for the
hazardous nature of the waste. References used to characterize the waste
types Included sources such as:
Encyclopedia of Chemical Technology, Klrk-Othmer
Chemical Process Industries, Shreve & Brink
OSW Hazardous Waste Data Management System.
The hazardous waste constituents shown 1n Table 3-20 are compounds that would
be representative of the composition of the waste type(s), but are by no means
the only possible constituents for the waste type(s) present 1n each Indus-
trial category.
3.3.4.2 OW Paragraph 4(c) Data Base
Paragraph 4(c) of the NRDC Consent Decree required EPA to Identify
pollutants, other than the priority pollutants, being discharged to POTWs and
not susceptible to treatment or otherwise Incompatible with the POTW. EPA's
Athens Environmental Research Laboratory (AERL) established a program 1n 1978
to Identify these nonprlorlty pollutants 1n Industrial effluent samples
collected during the categorical standards development process/ ' Samples
were analyzed from POTWs and over 40 Industrial categories. A total of 1,565
compounds were detected at least once after comparing mass spectra from the
GC/MS runs to mass spectra of known compounds 1n the EPA/NIH library.
Frequency-of-occurrence and order-of-magn1tude concentrations were determined
for each compound. Each compound then was ranked according to frequency and
apparent concentration. AERL then determined whether an extract from the
original organic analyses of the samples was still available. Only 717
compounds were determined to be likely to be present 1n the available sample
extracts. A program was undertaken 1n which 385 of the 717 compounds were
confirmed to be present at apparent concentrations 1n the extracts. Many of
3-62
-------
TABLE 3-20. SMALL QUANTITY GENERATOR HAZARDOUS WASTE TYPE(S) ACCOUNTING FOR 90% OF
WASTE QUANTITY FOR SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES1
INDUSTRIAL CATEGORY*
TOTAL QUANTITY HAZARDOUS
WASTE DISCHARGED
TO POTWs (kg/yr)
HAZARDOUS WASTE TYPE(S)
ACCOUNTING FOR
90% OF WASTE QUANTITY
TYPICAL HAZARDOUS
WASTE CONSTITUENTS
CO
CT>
Electrical & Electronic 1,693,548
Components
Electroplating/Metal 3,252,264
Finishing
Equipment Manufacturing 5,423,820
Explosives 27,852
Ind. & Comm. Laundries 1,514,508
Ink Manufacture & Formu- 71,076
lation
Inorganic Chemicals 22,572
Iron & Steel Manufacturing 264,780
Leather Tanning & Finishing 8,832
Organic Chemicals 77,484
Pesticides Manufacturing 14,112
Pharmaceuticals 46,056
Photographic Chemicals 7,068
Strong Acid or Alkaline Wastes (80%)
Spent Plating Wastes (10%)
Spent Plating Wastes (50%)
Strong Acid or Alkaline Wastes (45%)
Strong Acid or Alkaline Wastes (70%)
Spent Plating Wastes (20%)
Strong Acid or Alkaline Wastes (98%)
Filtration Residue from Dry Cleaning (99%)
Strong Acid or Alkaline Wastes (50%)
Heavy Metal Solutions (35%)
Spent Solvents (10%)
Strong Acid or Alkaline Wastes (100%)
Strong Acid or Alkaline Wastes (100%)
Spent Solvents (100%)
Strong Acid or Alkaline Waste (50%)
Ignitable Wastes (25%)
Photographic Wastes (15%)
nitric acid, fluorides, arsenic,
sodium phosphate, sodium
carbonate, sodium hydroxide,
chromium
heavy metals, chlorinated
hydrocarbons, fluorides, sodium
hydroxide, cyanide
heavy metals, chlorinated
hydrocarbons, fluorides, sodium
hydroxide, cyanide
nitric acid, sulfuric acid
tetrachloroethylene, petroleum
solvents
lead, cadmium, chromium,
mercury, cyanide, alcohols,
esters, ketones, aromatic
hydrocarbons
assorted acids and caustics
sulfuric acid, hydrochloric acid
dimethyl amine, formaldehyde
hydrochloric acid, sulfuric
acids, assorted organics, heavy
metals
Pesticide Washing & Rinsing Solutions (100%) assorted pesticides
Strong Acid or Alkaline Wastes (60%)
Ignitable Wastes (40%)
Solution or Sludges with Photosilver (65%)
Spent Solvents (35%)
acetone, isopropyl alcohol,
toluene, methylene chloride
silver, cyanide, chromium,
benzene derivatives
Only industries that contain SQG Survey data are shown.
-------
TABLE 3-20. SHALL QUANTITY GENERATOR HAZARDOUS HASTE TYPE(S) ACCOUNTING FOR 901 OF
HASTE QUANTITY FOR SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES1 (Continued)
INDUSTRIAL CATEGORY'
TOTAL QUANTITY HAZARDOUS
WASTE DISCHARGED
TO POTWs (kg/yr.)
HAZARDOUS WASTE TYPE{S)
ACCOUNTING FOR
90% OF WASTE QUANTITY
TYPICAL HAZARDOUS
WASTE CONSTITUENTS
Plastics Molding & Forming 142,776
Porcelain Enameling 144
Printing & Publishing 9,187,116
Pulp * Paper 118,356
Textile Mills 127,284
Timber Products 33,684
Ignitable Wastes (55%)
Spent Solvents (45%)
Strong Acid or Alkaline Wastes (100%)
Photographic Wastes (75%)
Strong Acid or Alkaline Wastes (10%)
Spent Solvents (10%)
Spent Solvents (55%)
Strong Acid or Alkaline Wastes (40%)
Spent Solvents (90%)
Solution or Sludges with Photosilver (10%)
Wastewater Wood Preservatives (99%)
monomers (styrene, phenol,
butadiene, etc.), phthalates
boric acid, sodium carbonate
silver, cyanide, chromium,
ketones, alcohols, esters,
aromatic hydrocarbons
formaldehyde, dyes and pigments,
sulfuric acid, sodium hydroxide
acrylonitrile, chlorinated
phenols, silver, cyanide,
formaldehyde
pentachlorophenol, creosote,
arsenic
I0nly industries that contain SQG Survey data are shown.
-------
the sample extracts were several years old when analyzed, and thus volatiles
probably were not confirmed and concentrations may have changed due to
degradation. Fifty-six of these compounds were determined to be Incompatible
with POTWs, and 18 of these compounds were recommended for toxicity reviews,
based on a review of production/use and environmental fate Information. The
remaining 38 compounds were deleted since it was believed that those compounds
are discharged only in trace amounts to POTWs.
Table 3-21 summarizes the information collected by the Paragraph 4(c)
study for the selected consent decree industrial categories. Detections of
nonpriority hazardous constituents and the relative number of hazardous
constituents that appeared in wastes from each Industrial category are
provided. As described above, the Paragraph 4(c) data base lists concentra-
tions and frequencies of nonpriority hazardous constituents; however, it does
not give conclusive results. Constituent concentrations were "apparent con-
centrations" based on matching of mass spectra found to library mass spectra,
and frequencies in the data base refer to the total number of "apparent"
detections of each compound. Therefore, it is difficult to determine whether
the detections occurred in one plant, several plants, or a large number of
plants. There were no flow rates associated with the apparent concentrations
provided, so mass loadings could not be calculated using the data base.
Examining Table 3-21, the most predominant nonpriority hazardous
constituents detected in the selected consent decree industrial categories are
as follows:
Nonpriority Hazardous
Constituent
Cresols
Xylene
Acetophenone
Methyl Ethyl Ketone
Acetone
Number of Industrial
Categories Detected
18
18
17
16
15
These hazardous constituents would be expected to appear in the wastewaters in
many industrial categories because of their common use as solvents.
3-65
-------
TABLE 3-21. RESULTS FROM PARAGRAPH 4(c) STUDY FOR THE
SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES
CoMttftMDU
i i
S X
itU
jMif
33
ctrlul iM
KtfMlC GMVOMIItt
E)Mt
(Mil
i
tm
MtUf*
j"
SE
15
!i
II
ij
iMrfMlc
NMNrflctv
i*
ii
aMil
Mitg
LMt
M*
il
taifirrMt
(hnvfictur
3 K
Ii
P* IK Mnufic
Md Foiwlitl
t
L
ii
W I
ii
r
J-a
.!
K
?r
uttei
d Fvrvf
FrtHttiif tnd
Publ
I?
II
tuyl drier!*
C«M MtulfUe
CfclotcvMe
BIpfcMjrl JMw
EUqrl Acetate
Ethyl Etter
fctfcyl Etlq.1
fetltfl IscriMtyl Ketow
PMUcMmethixe
2-MCOl t
Pyrtdla
let rafeydrgf HTM
1 . 7 . 3> Irl cfcl ompropjm
Kjrle
torltjr PollHtMtx Kot Listed
Itere badetected im Every IXaitrUl Cattyry
m - *> o»t*
-------
Nonpriority hazardous constituents were detected in the majority of those
selected consent decree industrial categories evaluated in the Paragraph 4(c)
study. Those selected consent decree industrial categories with the most
nonpriority hazardous constituents detected are as follows:
Industrial Category
Organic Chemicals, Plastics, Resins,
and Synthetic Fibers
Paint Manufacture and Formulation
Ink Manufacture and Formulation
Inorganic Chemicals Manufacture
Electrical and Electronic Components
Number of Nonpriority Hazardous
Constttuents Detected
20
17
16
16
14
Certain industrial categories were represented by many facilities in the
Paragraph 4(c) study, and several industrial categories were represented by
only a few facilities. Therefore, the data for some industrial categories may
be representative of the entire industry, while for other industrial
categories it may not.
3.3.4.3 Hazardous Waste Data Management System
The Hazardous Waste Data Management System (HWDMS) ,is a data base
maintained by OSW to track the permit, compliance, and enforcement status of
RCRA hazardous waste handlers. The data base contains information for over
90,000 facilities. The facilities are classified as hazardous waste genera-
tors, transporters, treatment, storage, and/or disposal (TSD) facilities, or
nonregulated. Over 300 different data elements are used in HWDMS in describ-
ing these facilities. The data elements are updated weekly by EPA Regional
Offices.
Regarding this study, much of the data contained in HWDMS were useful in
several ways. During the initial stages of the study, HWDMS was used to
identify the extent of hazardous waste activity for each 4-digit SIC code
representing an industrial category. After industry categorization, the HWDMS
3-67
-------
data were used to describe the waste types generated 1n each Industrial cate-
gory. The data base also identifies RCRA permitted PQTWs that are hazardous
waste generators, TSD facilities, or transporters.
There are several limitations in using the HWDMS data. First, there may
have been problems with precautionary notification by facilities who received
the initial questionnaire from OSW. In short, there is a possibility that a
few facilities listed all hazardous wastes believed to be generated or handled
at that time or that could conceivably be generated or handled in the future.
Industry's concern was that if a waste was not recorded on the Initial
questionnaire, a facility would not ever be allowed to generate or handle that
hazardous waste. Therefore, as a precaution, some facilities may have listed
almost every possible characteristic and listed waste identified by EPA.
Secondly, double counting also has the potential to be a problem with HWDMS
since each facility may 11st up to four SIC codes when notifying OSW.
Therefore, waste data extracted from HWDMS may be counted in up to four
Industrial categories. In general, however, the majority of the facilities
included in HWDMS did not notify under several SIC codes or, if more than one
was listed, quite often fell into the same industrial category. Lastly, the
HWDMS data base does not provide specific Information regarding which of the
facilities notifying are indirect dischargers. Therefore, information
extracted from HWDMS is applicable to an industrial category as a whole, and
represents direct, indirect, and zero dischargers.
Appendix H presents a summary of the HWDMS data base for the selected
consent decree industrial categories. Approximately 240 RCRA characteristic
and listed wastes were found for the 30 selected consent decree industrial
categories. Hazardous wastes that appear in the most industrial categories
include the characteristic D-l1sted hazardous wastes (ignitable, corrosive,
reactive), the F-l1sted solvents (halogenated and nonhalogenated), and the EP
toxic metals (primarily lead and chromium). In general, these wastes appear
1n almost all the selected consent decree Industrial categories, with the
exception of industrial and commercial laundries, which had no data in HWDMS.
The solvent that appeared In the most industrial categories was acetone
(present 1n 24 selected consent decree industrial categories), followed by
3-68
-------
toluene, 1,1,1-trichloroethane, and methanol (present 1n 22 industrial
categories each).
Industrial categories that had the most types of listed wastes (in
descending order) were equipment manufacturing and assembly (135), inorganic
chemicals manufacturing (127), organic chemicals manufacturing (125),
adhesives and sealants (117), and plastics molding and forming (117). These
industrial categories are expected to contain a variety of wastes because of
the diversity of the products they make. The HWDMS data base brings out this
fact in that the larger the scope of products associated with an industrial
category, the more numerous the hazardous wastes associated with these
industries,
3.3.4.4 EPA Region/State/POTW Data
In an effort to augment information gathered from the OW and OSW
industrial data bases, data were collected from various EPA Regions, States,
and POTWs for the industrial categories evaluated during this study. The
first step was the development of a list of potential sources of industrial
hazardous waste data. After all potential sources of industrial hazardous
waste data were identified, data were collected via one of three methods:
telephone requests, written requests, and site visits. Generally, data
collected included wastewater flow rates and hazardous constituent concen-
trations in those wastewaters discharged to POTWs from any of the industrial
categories evaluated during this study. Although data were collected for all
industrial categories and for all hazardous constituents considered in this
study, emphasis was put on the collection of data for industrial categories
where little or no hazardous waste information existed.
Representativeness of data for specific industrial categories varied,
ranging from electroplating/metal finishing (141 facilities represented) to
porcelain enameling and gum and wood chemicals (1 facility each represented),
A detailed discussion regarding the methodologies utilized for the collection
of the data considered in this study, as well as a complete summary of the
data collected from these State/local sources for the industrial categories is
3-69
-------
provided 1n Appendix I. Pollutants not detected or zero concentrations were
not taken Into account. Therefore, the average concentrations shown 1n
Appendix I are not actual averages, but rather only mean values of the nonzero
concentrations. Further, 1n the majority of cases, the sample type (I.e.,
grab, 24-hour composite) was not Indicated for the data collected. Therefore,
the average concentrations shown 1n Appendix I may have been calculated using
both Instantaneous and long-term hazardous constituent concentrations.
Due to the limitations described above and the large amount of data
contained 1n Appendix I, 1t would be difficult to summarize the State and
local Industrial data. Therefore, analysis of the State and local data, as it
pertains to specific selected consent decree Industrial categories, will be
Incorporated Into Section 3.3.5, which summarizes the data presented
throughout Section 3.3.
In an effort to further supplement data gathered for this study, a
sampling program was Initiated by EPA specifically for this study. The goal
of this sampling program was to Identify the hazardous constituents present 1n
Indirect discharges from selected Industrial facilities and present 1n the
Influents and effluents at two POTWs. The Industrial facilities selected for
this sampling program Included a pharmaceutical manufacturer, a solvent
recovery facility, a paint manufacturer, and an Industrial laundry. Of the
two POTWs sampled, one was considered heavily Industrialized, while the other
predominantly serviced residential and commercial customers. The data
resulting from this sampling program are presented 1n Appendix J. This
appendix also provides the detection limits and analytical methods utilized
for all the parameters monitored during this study. Specific data for the
applicable Industrial facilities will be discussed within Sections 3.3.5 and
3.4.2 as they relate to each industrial category.
3.3.4.5 Industrial Incidents File
In order to evaluate further the effect of hazardous waste discharges on
POTWs from facilities within the various Industrial categories, Information
was gathered on specific incidents that have occurred at POTWs that were
caused by hazardous waste discharges from Industrial users. The data for
3-70
-------
these incidents were gathered primarily via one of three methods: a survey
distributed by the Association of Metropolitan Sewerage Agencies (AMSA) to its
members; a telephone survey of POTWs referred to by EPA Region and State
representatives as having specific incidents involving industrial hazardous
waste discharges; and documentation of incidents from technical journals,
newspapers; and other periodicals. Appendix K provides a more detailed
discussion on the collection of the incidents data and provides a summary of
those incidents that have occurred at POTWs.
The summary table in Appendix K for the selected consent decree
industrial categories shows the impact of hazardous waste or constituent
discharges on POTW operations. Analysis of specific incidents involving the
selected consent decree industrial categories will be incorporated into the
following section, which summarizes data presented throughout Section 3.3.
Several of the incidents described above were the result of a spill of a
hazardous waste or constituent within an industrial facility. Therefore, the
information in Appendix K does not necessarily represent typical hazardous
waste discharge practices for a given industrial category. Appendix K should
only provide a sense of the types of hazardous wastes handled by facilities
within an industrial category and the potential problems associated with the
discharge of these hazardous wastes or constituents to POTWs.
3.3.5 Summary of Hazardous Waste and Constituent Data Presented for the
Selected Consent Decree Industrial Categories
This section summarizes the hazardous waste and constituent data
presented throughout Section 3.3 for the selected consent decree industrial
categories. This summary will concentrate on those selected consent decree
industrial categories that, according to the data presented, may be respon-
sible for the discharge of significant quantities of hazardous wastes or
constituents to POTWs. However, this summary should not imply that those
industrial categories discussed in this section are the only industrial
categories that discharge or have the potential to discharge hazardous wastes
or constituents to POTWs. This is due primarily to the fact that limited
hazardous waste data exist for industrial categories, or data that do exist
are outdated and may not properly characterize hazardous waste practices for
3-71
-------
an Industrial category. This is especially true for the adhesives and
sealants and rubber manufacturing and processing industrial categories for
which limited data currently exist.
3,3.5.1 Electroplating/Metal Finishing
The electroplating/metal finishing category 1s responsible for the
discharge of significant quantities of hazardous wastes to POTws, as shown by
ITD hazardous constituent (priority only) loadings (45,970,546 kg/yr raw,
1,191,607 kg/yr current and after PSES) and SQG Survey hazardous waste
loadings (3,252,264 kg/yr) for the SQG segment of the category. Also, many
POTW incidents have occurred as a result of hazardous constituent discharges
(primarily acids, metals, and organic solvents) from facilities within the
electroplating/metal finishing category. Results from the AMSA survey (as
described in Appendix K) found electroplating/metal finishing facilities to be
considered "problem Industries" in 31 of the 66 POTWs surveyed. Analysis of
State and local data presented in Appendix I for the electroplating/metal
finishing industrial category also shows high average concentrations for
several hazardous priority metals (i.e., chromium, nickel) and several
hazardous priority and nonpriority organlcs (i.e., acetone, toluene, ethyl
benzene, 1,1,1-tMchloroethane). However, due to the attention the
electroplating/metal finishing category has received from a regulatory
standpoint (i.e., promulgation of categorical standards and RCRA listed
wastestreams), the category as a whole may not be as great of a concern as the
data may indicate, assuming that applicable wastewater discharge and hazardous
waste regulations are enforced against electroplating/ metal finishing
facilities. This would ensure control of hazardous priority metals and
organlcs.
Alternatively, a concern does arise for the electroplating/metal
finishing category 1n terms of the use and discharge of nonpriority hazardous
organics. The HWDMS data base (see Appendix H) shows that several RCRA
hazardous wastes are associated with electroplating/metal finishing facili-
ties. Specifically, several hazardous nonpriority organlcs, such as acetone
(U002), methanol (U154), methyl ethyl ketone (U159), and xylene (U239), were
present. Therefore, even with the compliance by electroplating/metal
3-72
-------
finishing facilities with categorical standards (specifically the total toxic
organlcs limitation), other nonpriority hazardous constituents currently may
be used and discharged to POTWs. An estimation of the quantities of these
hazardous nonpMority organlcs could not be made for this study.
3.3.5.2 Pharmaceuticals Manufacturing
Another selected consent decree Industrial category that 1s of concern
from the standpoint of significant hazardous waste and constituent discharges
to POTWs 1s the Pharmaceuticals manufacturing industrial category. There are
several reasons for concern in this industry, one of which stems from the
Incidents that have occurred at POTWs due to wastewater discharges containing
hazardous constituents, particularly organics, from facilities within the
pharmaceutical manufacturing category. These incidents have resulted mainly
in potential explosion situations. Also, the pharmaceutical manufacturing
industrial category ranks second in total hazardous constituent (priority
pollutant) loadings after the implementation of categorical pretreatment
standards (total cyanide is the only pollutant parameter regulated for the
pharmaceutical manufacturing category). As shown in Table 3-18 and Appendix
G, significant loadings of several volatile hazardous constituents (priority
pollutants) are estimated to be discharged currently by the pharmaceutical
manufacturing category. Specifically, the following are found in significant
quantities:
Volatile Hazardous Constituent
(Priority Pollutant)
Chloroform
Methylene Chloride
Toluene
Annual Loading
(kg/yr)
890,108
4,779,851
787,777
In May 1983, a 6-day sampling study performed for EPA simultaneously
evaluated pollutant concentrations at a pharmaceutical manufacturing facility
and the POTW to which the facility's wastewaters were discharged/ ' Detect-
able concentrations in the plant effluent of methylene chloride, phenol,
toluene, naphthalene, and isophorone were observed. Concentrations of
methylene chloride as high as 166,000 ug/1 were detected in the effluent from
3-73
-------
the industrial facility. The following is a summary of the average daily
discharge of hazardous organic constituents found in the facility's effluent
Hazardous Constituent
Methylene Chloride
Phenol
Toluene
Naphthalene
Isophorone
Daily Facility Effluent
(kg/day)
101.6
12.7
0.45
0.24
0.10
Furthermore, results from this study show that 85 percent of the mass of
methylene chloride in the POTW influent (with an average flow of 80 MGD)
originates from the Pharmaceuticals facility discharge (with an average flow
of 1 MGD).
Volatile hazardous constituents (nonpriority pollutants) also are used
extensively in the Pharmaceuticals manufacturing process. An attempt was made
to estimate the total amount of nonpriority volatile organic pollutants dis-
charged to POTWs by the pharmaceutical manufacturing category, based primarily
on data from a study performed by Research Triangle Park (RTP) and contained
( 0\
in the ITD Development Document for pharmaceutical manufacturing/ * The data
for this study, representing 26 pharmaceutical facilities accounting for 53
percent of total production within the pharmaceutical industry, were initially
supplied to RTP from the Pharmaceutical Manufacturing Association (PMA).
Table 3-22 presents the estimates of volatile hazardous constituents
(nonpriority) loadings from the Pharmaceutical Manufacturing industrial
category. As shown in Table 3-22, there are an estimated 14,800 metric tons
of volatile hazardous constituents (nonpriority pollutants only) discharged
annually to POTWs from the pharmaceutical manufacturing industrial category.
State and local data presented in Appendix I verify that several volatile
hazardous constituents are present in wastewaters discharged to POTWs from
facilities within the pharmaceutical manufacturing industrial category.
Specifically, high average concentrations are shown for acetone (9.65 mg/1),
toluene (2.84 mg/1), and xylene (1.00 mg/1). The HWDMS data base, shown in
3-74
-------
TABLE 3-22. ESTIMATED LOADINGS OF HAZARDOUS NONPRIORITY VOLATILE
ORGANIC POLLUTANTS FOR THE PHARMACEUTICAL MANUFACTURING
INDUSTRIAL CATEGORY*
Hazardous Nonpriority
Volatile Organic
Methanol
Acetone
Ethyl Acetate
Xyl ene
Methyl Ethyl Ketone
Butanol
Formaldehyde
Ethyl Ether
Acetonitrile
Pyridine
TOTAL
Estimated
Annual Loading
(kg/yr)
6,695,544
' 4,866,058
2,093,536
961,895
56,582
56,582
37,731
22,633
11,316
5,658
14,807,525
*Estimates were derived from data presented in the September 1983 EPA
"Development Document for Final Effluent Limitations Guidelines, New Source
Performance Standards and Pretreatment Standards for the Pharmaceutical
Manufacturing Point Source Category,"
3-75
-------
Appendix H, also provides verification of at least the presence of over
80 percent of the hazardous volatile organic constituents (as specific
U-listed compounds) considered in this study for the pharmaceutical
manufacturing industrial category.
Finally, as described in Section 3.3.4.4 and Appendix J, sampling results
from a 1-day sampling event performed by EPA for this study at a pharma-
ceutical manufacturing facility found significantly high concentrations of
priority and nonprlority hazardous organic constituents being discharged to a
POTW, Following is a summary of those hazardous constituents found in high
concentrations:
Hazardous Constituent
Acetone
Methylene Chloride
Toluene
1,2-Dichlorobenzene
1,2-Dichloroethane
Methyl Ethyl Ketone
Concentration (ug/1)
4,592
2,760
1,565
2,280
2,497
1,566
In summary, it would appear as though the discharge of hazardous
constituents (especially nonpriority and priority volatile organics) to POTWs
from the pharmaceutical manufacturing category is significant. Due to the
lack of regulation of these hazardous constituents for this industry, at least
in terms of categorical standards, the pharmaceutical manufacturing industry
would also be expected to continue discharging hazardous wastes at or near the
levels presented here,
3.3.5.3 Printing and Publishing
The printing and publishing industrial category is composed of between
20,000-40,000 indirect discharging facilities. These facilities are currently
exempt from regulation by categorical standards. As such, the total quan-
tities of hazardous wastes generated and possibly discharged to POTWs by the
entire industrial category would be expected to be large unless they are
regulated by local pretreatment programs. Alternatively, it could be expected
3-76
-------
that the total amount of hazardous wastes discharged by each printing and pub-
lishing facility within the category would be relatively small and would
probably not impact the POTW receiving the discharges. This scenario is
somewhat supported by the findings in the SQG Survey (see Table 3-19), whereby
the printing and publishing industrial category accounts for the largest quan-
tity of hazardous waste discharged to POTWs by the SQGs within selected
consent decree industrial categories (9,187,166 kg/yr). However, the amount
of hazardous wastes discharged by individual facilities within the printing
and publishing industrial category is one of the lowest of all the selected
consent decree industrial categories (640 kg/yr/facility).
Data provided in Appendix K shows that the amount of hazardous waste
discharged by individual printing and publishing facilities can affect POTWs.
Appendix K provides several examples of incidents where printing and pub-
lishing facilities have discharged solvents causing potential upsets of POTW
treatment systems and potential explosion situations at POTWs. The Paragraph
4(c) study (see Table 3-21) also presents documentation that 10 hazardous
constituents (nonpriority pollutants) were detected in wastewaters from
printing and publishing facilities. In particular, the following hazardous
organics were found: acetone, ethyl ether, methyl ethyl ketone, and xylene.
Quantities for hazardous nonpriority pollutant parameters could not be
calculated for this industrial category.
3.3.5.4 Electrical and Electronics Components
The electrical and electronics components industrial category is
composed of approximately 270 indirect dischargers, according to Table 3-12.
The SQG segment of this industrial category, according to the SQG survey
summary shown in Table 3-19, averages a discharge per facility of 11,440 kg/yr
of hazardous wastes to POTWs, the largest of the selected consent decree
industrial categories. The hazardous wastes described in the SQG survey for
the SQGs within the electrical and electronic components industrial category
are composed of strong acid or alkaline wastes and spent plating wastes.
Facilities in the electrical and electronic components industrial
category also were involved in several incidents resulting in potential
3-77
-------
explosions at POTWs. These Incidents occurred due to the discharge of
solvents utilized 1n manufacturing processes at electrical and electronic
components facilities. Hazardous priority organlcs discharges are regulated
as total toxic organlcs under categorical pretreatment standards for the
electrical and electronic components Industrial category. However, the use
and subsequent discharge of other hazardous constltutents {nonprlorlty
organlcs) still may be of concern according to data presented 1n the Paragraph
4(c) study and the HWDMS data bases. Of the selected consent decree Indus-
trial categories, the electrical and electronic components category had the
fourth highest number of nonprlorlty pollutants detected 1n the Paragraph 4(c)
study. Of these nonprlorlty pollutants, the following hazardous organlcs were
detected: acetone, methyl ethyl ketone, methyl Isobutyl ketone, and xylene.
The following hazardous wastes also were Identified 1n the HWDMS for elec-
trical and electronic components Industrial category: acetone (U002), methyl
Isobutyl ketone (U161), and xylene (U239).
3.3.5.5 Industrial and Commercial Laundries
The Industrial and commercial laundries Industrial category, estimated by
ITD to have over 68,000 facilities, has been exempted from regulation under
categorical pretreatment standards. Due primarily to the diversity of
services and operations found throughout the category, any of the hazardous
constituents could be expected to be present In wastewater discharges to
POTWs. The Industrial and commercial laundries category ranks fifth of the
selected consent decree categories 1n total hazardous constituent loadings
(priority pollutant only) to POTWs after the implementation of pretreatment
standards (1,486,000 kg/yr discharged). This category also ranks second out
of the selected consent decree industrial categories in hazardous wastes
discharged by SQGs to POTWs according to the SQG Survey shown in Table 3-19.
The SQG survey attributes almost all of the hazardous wastes discharged to
POTWs from the Industrial and commercial laundries category to filtration
residues from dry cleaning. These residues probably contain several hazardous
constituents, including tetrachloroethylene and various petroleum solvents.
Results from the AMSA survey (Appendix K) found that 16 out of the 66
POTWs responding considered industrial and commercial laundries as "problem
3-78
-------
industries." As a result of the EPA sampling program initiated for this study
(see Appendix J), several priority and nonpriority hazardous constituents were
detected in indirect discharges from an industrial laundry. Following is a
summary of the sampling results:
Hazardous Organic Constituent
Acetone
Bis (2-Ethylhexyl) Phthalate
N-Alkanes (C10-C20)
Isophorone
Toluene
1,1,1 Trichloroethane
Methyl Ethyl Ketone
Concentration (ug/1)
1,542
1,192
1,095
690
548
478
427
Because the industrial and commercial laundries category is not regulated
under categorical standards, the wastewater discharge practices are not
expected to change unless there is a change in regulatory status or local
limits are implemented at the POTW level.
3.3.5.6 Equipment Manufacture and Assembly
The equipment manufacture and assembly industrial category consists of
those facilities that generally fall into SIC code groups 34-38 (except
electroplating/metal finishing facilities). Estimates from OSW and OW for the
number of indirect dischargers within the category range from approximately
30,000-100,000. Facilities within this category (also referred to by ITD as
mechanical products manufacture) have been exempt from regulation under
categorical pretreatment standards. Of particular concern to this study is
the widespread use of degreasing solvents by equipment manufacture and
assembly facilities. Loadings for several of the solvents most used in this
category were estimated based upon data in the Electroplating/Metal Finishing
Development Document;* ' end use production data for these solvents from the
Chemical Economics Handbook/ ' and an estimate of 60,000 equipment
manufacture and assembly facilities. These estimates are as follows:
3-79
-------
Hazardous Constituent
(Priority Organic)
Benzene
Methylene Chloride
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
Trlchloroethylene
Loading to POTWs
(kg/yr)
152,773
534,706
1,298,572
229,160
3,819,331
1,680,505
Based upon estimates for only the six solvents shown above and the fact that
there are no categorical pretreatment standards, the equipment manufacture and
assembly category ranks first in terms of total hazardous constituent loadings
(priority only) for the selected consent decree Industrial categories after
the implementation of pretreatment standards (see Table 3-16).
According to the paragraph 4(c) study, several hazardous constituents
(nonpriority) also were detected in wastewater discharges from equipment
manufacture and assembly facilities. These hazardous constituents included
acetone, cresols, cyclohexane, methyl ethyl ketone, methyl isobutyl ketone,
and xylene. The equipment manufacture and assembly category also ranked first
in terms of the number of hazardous wastes identified in the HWDMS data base
(see Appendix H) for the selected consent decree industrial categories. The
diversity of hazardous wastes associated with this category, according to
HWDMS, were expected due to the numerous products manufactured. The equipment
manufacture and assembly category ranked second out of the selected consent
decree industrial categories in terms of total hazardous waste discharges to
POTWs from SQGs according to the SQG Survey (see Table 3-19). The hazardous
wastes identified in the SQG Survey as being discharged by SQGs within this
category were predominantly strong acid or alkaline wastes and spent plating
wastes. Again, due to lack of regulation by categorical pretreatment stan-
dards, the characteristics of hazardous waste and constituent discharges
within this industrial category are not expected to change unless limits are
imposed at the local level.
3-80
-------
3.3.5.7 Paint Manufacture and Formulation
According to the OW and OSW data bases reviewed for this study, the paint
manufacture and formulation industrial category does not account for the
discharge of large quantities of hazardous wastes or constituents to POTWs.
However, according to data in Appendix K, discharges from paint manufacture
and formulation facilities caused upsets of POTW biological treatment systems
and affected receiving stream water quality. The hazardous constituents found
in these discharges included solvents, toluene, and aniline.
As an example, a specific incident involving the discharge of hazardous
constituents by a paint manufacture and formulation facility to a POTW
resulted in potential explosion conditions throughout the POTWs collection
system/ ' Samples of the effluent taken by the POTW from the facility found
several hazardous constituents in high concentrations including toluene
(105,460 ug/1), ethyl benzene (329,342 ug/1), benzene (237 ug/1), and xylene
(654,420 ug/1}. High concentrations of hazardous constituents also were found
by the POTW at a pump station several miles downstream from the facility, in
eluding toluene (393 ug/1), ethyl benzene (843 ug/1), and xylene (42,599 ug/1)
Further, high concentrations of these hazardous constituents were found at the
POTW headworks and included toluene (71 ug/1), ethyl benzene (270 ug/1), and
xylene (1,222 ug/1).
Analysis of other State and local data provided in Appendix I for the
paint manufacture and formulation industrial category also show high average
and maximum concentrations of various hazardous constituents, including
acetone, carbon tetrachloride, ethyl benzene, methanol, methylene chloride,
N-butyl alcohol, phenol, and toluene. Of particular interest in the State and
local data is the fact that the average flow from paint manufacture and
formulation facilities is 42,600 gallons per day. Although this average flow
is substantially higher than the average estimated by ITD (1,000 gallons per
day), it may represent nonprocess as well as process flow.
The paint manufacture and formulation industrial category ranked second
in terms of total number of hazardous constituents (nonpriority) detected in
the Paragraph 4(c) study. Several hazardous constituents (nonpriority)
3-81
-------
detected include acetone, N-butyl alcohol, cresols, ethyl ether, methyl ethyl
ketone, methyl isobutyl ketone, and xylene. Finally, the paint manufacturing
facility sampled by EPA for this study (see Appendix J) was found to be
discharging several hazardous constituents to a POTW in significant quanti-
ties. Table 3-23 provides a summary of hazardous constituent concentrations
in both the raw and treated (onsite treatment before discharge to POTW) waste-
waters from this paint manufacturing facility. In summary, it appears that
facilities within the paint manufacture and formulation industrial category
have the potential to discharge significant quantities of hazardous con-
stituents (both priority and nonpriority) to POTWs. This is due primarily to
the lack of regulation by categorical pretreatment standards and the batch
discharge characteristics found at paint manufacturing and formulation
facilities.
3.3.5.8 Rubber Manufacturing and Processing
Although limited hazardous waste or constituent data exist, the rubber
manufacturing and processing industrial category may be of concern regarding
hazardous waste or constituent discharges to POTWs. This concern is due
primarily to the nature of the manufacturing processes utilized. According to
the Paragraph 4(c) data base (Table 3-21) and the HWDMS data base (Appendix
Vl), the hazardous constituents that would be expected to be present in process
wastewaters from rubber manufacture and processing facilities include de-
greasing and chemical formulation solvents (such as toluene [U220], 1,1,1-
trichloroethane [U226], tetrachloroethylene [U210], and xylene [U239]).
According to ITD estimates, there are approximately 500 indirect discharging
facilities in the rubber manufacturing and processing industrial category.
These facilities also have been exempt from regulation under categorical
pretreatment standards. Data from the SQG Survey (Table 3-19) indicate that
few of the indirect discharging rubber manufacturing and processing facilities
are SQGs of hazardous wastes.
3.3.5.9 Coal, Oil, and Petroleum Products and Refining
The coal, oil, and petroleum products and refining industrial category
may be responsible for the discharge of significant quantities of hazardous
wastes and constituents to POTWs. Based on data presented in Appendix G and
3-82
-------
TABLE 3-23.
Hazardous Constituent
Metals
Antimony
Arsenic
Barium
Cadmium
Chromium
Lead
Raw Wastewater
Concentrations
(ug/1)
58
1,260
30
4,620
122
Treated Wastewater
Concentrations*
(ug/1)
16
<5
253
<5
3,100
<5
Organics
Acetone
Ethyl benzene
Methylene Chloride
Phenol
Styrene
Toluene
Methyl Ethyl Ketone
4,576
2,183
481,612
1,818
2,329
621
119,736
4,340
1,237
366,752
1,472
1,608
352
106,502
*Prior to discharge to POTW
3-83
-------
Table 3-16, the petroleum refining segment of the coal, oil, and petroleum
products and refining Industrial category ranks third highest in terms of
total hazardous constituents (priority pollutant only) loadings to POTWs
(2,171,000 kkg/yr). Facilities within the petroleum refining segment of this
category are only regulated for several conventional and nonconventlonal
pollutant parameters by categorical pretreatment standards. These regulated
parameters Include oil and grease and ammonia. Although some incidental
removal may occur, no substantial reduction of the hazardous constituents
found 1n Table 3-16 would be expected as a result of the implementation of
categorical pretreatment standards by the petroleum refining industry.
In an attempt to estimate hazardous waste generation for this category,
nonconfidentlal RCRA 3007 Questionnaires submitted to and made available by
OSW were reviewed. Based on the review of these questionnaires {a total of 71
out of 171 facilities), it was estimated that 2,002,645 metric tons of
hazardous wastes are generated per year, of which 32,458 metric tons per year,
or approximately 2 percent of the total, are discharged to POTWs. The above
estimate is only for the petroleum refining segment of the coal, oil, and
petroleum products and refining industrial category,
3,4 ANALYSIS OF OTHER POTENTIAL SOURCES OF HAZARDOUS WASTE DISCHARGES TO
POTWS
3.4.1 Overview and Description of the Data Sources
The previous section of this Chapter (Section 3.3) presented estimates of
the types and quantities of hazardous wastes discharged to POTWs by selected
consent decree Industries, This section presents Information on hazardous
waste discharges from other potential industrial sources. These sources have
been grouped into the following industrial categories:
t Construction Industry
t Cosmetics, Fragrances, Flavors,
and Food Additives
f Electrical Generating Power
Plants and Electrical
Distribution Services
Service Related Industries
Soaps and Detergents, Cleaning
Preparations, and Waxes
Manufacture and Formulation
Stone, Clay, Glass, Concrete,
and Other Mineral Products
3-84
-------
Fertilizer Manufacture
Food and Food By-Products
Processing
Hazardous Uaste Site Cleanup
Laboratories and Hospitals
Miscellaneous Chemical
Formulations
Motor Vehicle Services
Transportation Services
Waste Reclamation Services
Waste Treatment and Disposal
Facilities
Wholesale and Retail Trade
t Wood Furniture Manufacture and
Refinishing.
These categories are discussed separately because traditional EPA/OW and
EPA/OSW data bases do not contain the types of information (i.e., number of
indirect dischargers, average pollutant concentrations in process wastewater,
etc.) necessary to estimate, at the National level, the quantities of hazard-
ous waste discharged to POTWs by these industrial categories. Many of these
categories also do not fall within the scope of the 1976 NRDC consent decree
either because they are relatively new industries that have emerged since
negotiation of the consent decree (e.g., waste reclamation sources, waste
treatment and disposal facilities, etc.) or because they traditionally have
been considered less significant waste sources due to their smaller size and
service-related orientation (e.g., motor vehicle services, service-related
industries, laboratories and hospitals, etc.). As a result, most of these
industrial categories never have been extensively reviewed, for regulatory
purposes, at the National level.
Due to the lack of comprehensive discharge data, Section 3,4 utilizes an
eclectic approach, relying on a variety of data sources to develop a composite
picture of each industrial category. These data sources include:
Dun's Marketing Services - which provide estimates of the number of
facilities encompassed by specific SIC codes/ ' (See Appendix L
a complete listing of data for applicable industrial categories.)
for
' SQG Data Base - which provides estimates for types and quantities of
hazardous waste generated and discharged to POTWs by SQGs within
specific industrial categories/ J (See Table 3-24 for data on these
categories.)
AMSA Survey Data - which enumerates numbers and types of industrial
facilities that are adversely affecting POTW operations. (See
Appendix K for a complete description of survey data,)
3-85
-------
HWDMS Data Base - which provides information on the types of
characteristic and listed wastes for facilities that treat, store, or
dispose hazardous wastes. (See Appendix M.)
POTW Incident File - which provides more detailed information on POTW
Incidents relating to the discharge of hazardous waste. Incident file
data were collected as a followup to the AMSA survey and to other
State/local contacts made at an initial phase in the study. (See
Appendix K for the entire POTW Incidents File.)
Industria! Sampl1ng Data - which includes industrial sampling data
collected by State and local authorities for a limited number of
facilities in each category. (See Appendix I for complete listing of
industrial sampling data.)
Specific Examples - which represent accounts taken from other data
sources, such as technical journals, magazines, and newspapers.
The following industrial profiles compile data from these various data sources
in an attempt to provide a qualitative estimate of the potential for discharge
of hazardous wastes and constituents by these industries. This approach,
which emphasizes qualitative rather than quantitative estimates, prevents
comparison of these industrial categories with the selected consent decree
industrial categories presented in Section 3.3, in terms of overall sig-
nificance and quantities of hazardous wastes and constituents discharged to
POTWs. Specifically, SQG estimates (shown in Table 3-24 and referred to
throughout this section) describe hazardous waste loadings to POTWs from the
SQG segment of a particular industrial category. Alternatively, Section 3.3
primarily describes the quantities of hazardous constituents discharged to
POTWs for each of the selected consent decree industrial categories.
3.4.2 Industrial Category profiles
In this section, each Industrial category listed previously will be
discussed in detail. Process operations for each category will be described,
and potential hazardous waste discharges to POTWs will be Identified and
characterized.
3.4.2.1 Cosmetics, Fragrances, Flavors, and Food Additives
The cosmetics industry encompasses an extensive variety of manufacturing
operations and commercial products. The list of subcategorles presented in
3-86
-------
TABLE 3-24. SMALL QUANTITY GENERATOR HAZARDOUS HASTE TYPE(S) ACCOUNTING FOR
90 PERCENT OF HASTE QUANTITY FOR OTHER INDUSTRIAL CATEGORIES
CO
00
INDUSTRIAL CATEGORY
Construction Industry
Cosmetics, Fragrances, etc.
Electric Generating Power
Plants
Fertilizers
Food & Food By-products
Hazardous Waste Site Cleanup
Laboratories and Hospitals
Miscellaneous Chemical
Formulators
Motor Vehicle Services
Service Related Industries
Soaps and Detergents
Stone, Clay, Glass, etc.
Transportation Services
WEIGHTED I OF
FACILITIES TOTAL QUANTITY HAZARDOUS
DISCHARGING WASTE DISCHARGED
TO POTH TO POTWS (kg/yr)
1,076
80
3,587
23,395
209
0
582
242,088
33
NA
17
NA
NA
2,926
69,960
NA
22,572
NA
NA
2,099,664
188,316
1,318,860
23,146,068
621,168
0*
26,436
HAZARDOUS WASTE TYPE(S)
ACCOUNTING FOR
90% OF WASTE QUANTITY
Ignitable Wastes (90%)
Strong Acid or Alkaline Wastes (60%)
Ignitable Wastes (30%)
TYPICAL HAZARDOUS WASTE CONSTITUENTS
Naphtha, Kerosene, Turpentine, Gasoline,
Diesel Fuel
Acetone, Ethyl Acetate
Strong Acid or Alkaline Wastes (100%) Ammonia, Phosphoric Acid, Sulfuric Acid
Spent Solvents (50%)
Ignitable Wastes (20%)
Strony Acid or Alkaline Wastes (15%)
Other Reactive Wastes (15%)
Strong Acid or Alkaline Wastes (60%)
Spent Sovlents (25%)
Pesticide Washing and Rinsing
Solution (10%)
Spent Solvents (90%)
Strong Acid or Alkaline Wastes (10%)
Photographic Wastes (36%)
Waste Formaldehyde (35%)
Solution or Sludges with
Photosilver (20%)
Pesticide Washing and Rinsing
Solution (50%)
Strong Acid or Alkaline Wastes (40%)
Spent Solvents (100%)
Acetone; Methyl Ethyl Ketone; Methyl
Isobutyl Ketone; Benzene; Toluene;
Methylene Chloride; Methanol;
Hydrochloric, sulfuric, nitric, and
chromic acids; Caustic soda
Solvents (e.g., as listed for
"Laboratories"), Pesticides, Chemical
Intermediates/Feedstocks (e.g.,
chlorobenzene, nitrobenzene, aniline)
Gasoline, Naphtha, Tetraethyl Lead,
Sulfuric Acid
Silver, Cyanide, Chromium, Formaldehyde,
Phenol, Pesticides
Sodium hydroxide, Potassium hydroxide,
Phenol, Cresols
Gasoline, Diesel Fuel, Naphtha (from
tank cleaning and hazardous waste
hauling operations, almost any RCRA
waste is possible)
-------
TABLE 3-24. SHALL QUANTITY GENERATOR HAZARDOUS WASTE TYPE(S) ACCOUNTING FOR
90 PERCENT OF WASTE QUANTITY FOR OTHER INDUSTRIAL CATEGORIES (Continued)
INDUSTRIAL CATEGORY
Waste Reclamation Services
Waste Treatment and Disposal
Wholesale and Retail Trade
Wood Furniture
to
i
CO
00
WEIGHTED I OF
FACILITIES
DISCHARGING
TO POTW
NA
NA
366
ZOO
TOTAL QUANTITY HAZARDOUS
HASTE DISCHARGED
TO POTMS (kg/yr)
NA
HAZARDOUS WASTE TYPE(S}
ACCOUNTING FOR
90% OF WASTE QUANTITY
NA
160,020
399,696
Ignitable Paint Wastes (25%)
Photographic Wastes (20%)
Spent Solvents (20%)
Wastewater Hood Preservative (15%)
Pesticide Washing and Rinsing
Solution (15%)
Filtration Residue from Dry
Cleaning (60%)
Spent Solvents (40%)
TYPICAL HAZARDOUS WASTE CONSTITUENTS
Cresols, Toluene, Silver, Cyanide,
Chromium, Pesticides, Naphtha,
Turpentine, Methyl Ethyl Ketone,
Methyl Isobutyl Ketone, Phthai ate
esters
Tetrachloroethylene, Methanol, Hethylene
Chloride, Hethyt Ethyl Ketone, Hethyl
Isobutyl Ketone, Phthalate esters.
Turpentine, Toluene
*Zero discharge of wastes to POTWs
NA - No available data
-------
Appendix C illustrates the diversity of this industry. According to Dun's
Marketing Service, there may be as many as 2,500 cosmetics, fragrances,
flavors, and/or food additives manufacturers located in the united States.
Still, the SQG data base (Table 3-24) projects only 209 SQGs in the category,
and only 33 SQGs that discharge their hazardous wastes to POTWs.
Table 3-24 indicates that the SQG segment of the cosmetics industry may
discharge hazardous wastes that are strongly acid or alkaline (60 percent of
all waste), or ignitable (30 percent). Constituents imparting the acid/
alkaline characteristic can be expected to be strong acids and bases, such as
sulfuric acid or caustic. The ignitable wastes consist of organic solvents
and plasticizers used in cosmetics manufacture and formulation, including
acetone, ethyl acetate, and toluene. Other hazardous solvents potentially
discharged by cosmetics manufacturers have been identified in the HWDMS data
base (Appendix M), and include solvents such as methyl ethyl ketone, methyl
isobutyl ketone, and butanol. Nitrobenzene, a constituent in soaps and shoe
polishes, also is listed. Appendix I presents State/local sampling data
relating to the discharge of hazardous constituents by cosmetics, fragrances,
flavors, and food additives industries. The most frequently identified pol-
lutants in these discharges are metals such as chromium, copper, lead, nickel,
and zinc (three occurrences each). Organic solvents (e.g., carbon tetra-
chloride, chloroform, tetrachloroethylene) and plasticizers (e.g., bis(2-
ethylhexyl) phthalate, butyl benzyl phthalate) also are identified in Appendix
I as being present in discharges from this industry.
3.4,2.2 Construction Industry
These industries are engaged in erecting houses and other buildings.
Dun's Marketing Service indicates that as many as 500,000 firms may be covered
by this category. The SQG data base (Table 3-24) estimates that 16,988
construction firms are SQGs and 1,076 firms, or approximately 6 percent of the
total, discharge their hazardous waste to POTWs. These indirect dischargers
discharge 242,088 kg/yr of hazardous waste, 90 percent of which is RCRA
ignitable waste. Examples of hazardous wastes that might be discharged by
construction firms include gasoline, diesel fuel, and various solvents, such
as naphtha and turpentine (see Table 3-24). The construction industry also
3-89
-------
may be a source of paint waste discharges to POTWs. Paint wastes contain
hazardous solvents such as toluene, methyl isobutyl ketone, methylene
chloride, trichloroethylene, and acetone.
3.4.2.3 Electrical Power Plants and Power Distribution
This category includes facilities engaged in the generation and trans-
mission of electric power, including fossil fuel and nuclear power plants.
These plants typically do not discharge large volumes of wastewaters to POTWs.
Most power plants are located adjacent to water bodies, and prefer to utilize
direct discharge for wastewaters. A major wastewater source from electrical
power plants is water from air emmission scrubber systems. This wastewater
will have a low pH, due to the hydrolysis of nitrogen and sulfur oxides, which
form the corresponding acids. Another source of wastewater would be primary
(boiler) and secondary loop blowdowns. For fossil fuel plants, these waste-
waters will be contaminated only with boiler water additives such as corrosion
inhibitors, etc. For nuclear power plants, primary, and even secondary, loop
wastewaters can contain radioactive materials, and special precautions
regarding handling and disposal must be observed. Another possible wastewater
source involves the regeneration of Ion exchange columns used to purify
incoming water.
According to Dun's Marketing Service, there may be as many as 3,150 power
plants and electrical transmission facilities. The HWDMS database (Appendix
M) lists hazardous wastes potentially discharged by these facilities. Of the
eleven hazardous wastes generated and listed in the database, most are
solvents used by electric power plants in relatively small amounts. Appendix
I presents State/local data on the discharge of hazardous wastes by electric
power plants. Only three heavy metals are Identified, including lead, nickel,
and zinc.
3.4.2.4 Fertilizer Manufacture
For the purpose of this report, fertilizer manufacture is interpreted
broadly to include the manufacture and formulation of nitrogen chemicals,
phosphorus chemicals, and sulfuric acid. According to Dun's Marketing
Service, as many as 1,600 firms manufacture fertilizers, it is not known how
3-90
-------
many of these firms discharge process wastes to POTWs. Exclusive of boiler
and cooling water blowdowns, wastewaters from manufacturing nitrogen chemicals
generally originate from condensors and/or scrubbers. These raw wastewaters
can be expected to contain elevated ammonia levels, and hence, elevated pH and
alkalinity levels as well. Wastewaters from urea production can be expected
to contain ammonium carbamate and biuret, both unusable by-products. Waste-
water from manufacturing phosphorus chemicals is produced similarly from gas
scrubbing. The pH of such wastewaters is between one and two, and the phos-
phate concentration (as phosphorus) can be as high as 5,000 mg/1/13' These
wastewaters periodically are purged and treated by lime addition prior to
discharge. Wastewaters from producing ammonium phosphates are similarly from
gas scrubbing. Depending on the purity of the raw materials, the wastewaters
from this process may contain fluoride, but most likely not elevated levels.
Elevated levels of ammonia and phosphates, however, will be.present.
The HWDMS data base (Appendix M) indicates that many hazardous organic
chemicals, principally solvents such as benzene, methyl ethyl ketone, or
methyl isobutyl ketone, may be found in fertilizer manufacturing wastes. The
SQG data base (Table 3-24), however, indicates that virtually all of the
projected hazardous waste loadings to POTWs (22,572 kg/yr) from fertilizer
industries consist of acid/alkaline wastes, resulting from ammonia and
phosphoric/sulfuric/nitric acids. An examination of fertilizer manufacturing
processes confirms that significant amounts of organic chemicals are not
involved. Therefore, the pollutant loadings to POTWs of the organics listed
in the HWDMS data base can be expected to be minor. Appendix I presents
State/local data on the discharge of hazardous wastes by fertilizer manufac-
turing firms. The pollutants listed consist of eight heavy metals and cyanide
identified in a single observation.
3.4.2.5 Food and Food By-Products Processing
This category includes the processing of meat, fish, vegetables, grain,
and milk into edible and inedible products. However* processing these foods
into edible products generally must take place without the use of hazardous
chemicals, owing to the restriction that the products must be fit for human
consumption. Hence, this section focuses on the manufacture of inedible
3-91
-------
products from foodstuffs. Dun's Marketing Service indicates that there may be
more than 26,000 food and food by-products industries located nationwide,
although it is not known how many are indirect dischargers. The HWDMS data
base (Appendix M) identifies hazardous wastes that potentially are discharged
by food and food by-products industries. Many of these wastes are solvents,
including toluene, methyl ethyl ketone, methyl isobutyl ketone, and methylene
chloride. Most of these solvents are used as extracting/leaching solvents.
Appendix I presents State/local sampling data relating to the discharge
of hazardous waste constituents by food and food by-products industries. Only
heavy metals {and cyanide) are listed in discharges by these firms. The most
frequently identified metals include copper (25 occurrences), zinc (24), and
cadmium (23). Additional data for one large food processing facility located
in New Jersey show approximately 12,000 kilograms of methylene chloride being
discharged over a 1-year period.^ ' According to Appendix K, a POTW in Ohio
has reported corrosion problems owing to acid wastes discharged by a food
processing firm. Remedial actions and enforcement actions have been taken to
resolve this matter. Also, a hexane discharge by a food processing facility
to a POTW located in Kentucky resulted 1n an explosion and serious damage to
the POTW collection system.
(15)
3.4.2.6 Hazardous Waste Site Cleanup
Hazardous waste site cleanup obviously does not fit into the classical
definition of industrial category. Still, hazardous waste site cleanup can be
a significant source of hazardous wastes and pollutants, particularly 1n
recent years with the passage of CERCLA (Superfund) and the implementation of
Federal, State, local, and private cleanups.
EPA estimates that there are almost 21,000 hazardous waste sites
(including Federal, State, and local) that are being cleaned up op that will
require cleanup.
(16)
This number does not include many minor cleanups
initiated by companies still operating (such as a local service station that
has had some gasoline leakage from its tanks). It is unknown how many of
these cleanups have involved or will involve discharging hazardous wastes to a
POTW. However, an EPA source*1 ' estimated that approximately 10 percent of
3-92
-------
the National priority list (NPL) Superfund sites ultimately will truck cleanup
wastes to POTWs. If it is assumed that 2,000 of these NPL sites will require
off-site disposal of their wastes, then approximately 200 sites can be
expected to utilize POTWs for disposing their cleanup wastes.
Hazardous waste site cleanups consist of: (!) removing hazardous waste
or hazardous constituents from the site and decontaminating the site, or
(2) containing the hazardous waste and preventing migration of the wastes from
the site. The types of sites involved include facilities that stored or
treated hazardous wastes in containers, tanks, or surface impoundments, or
disposed wastes in landfills or by other land disposal methods. Cleanups also
can include sites where the contents of underground tanks or buried hazardous
waste containers have leaked into adjacent soil, resulting in ground-water
contamination. Currently, one of the more common site cleanups involves
gasoline stations where underground gasoline tanks frequently leak due to
corrosion. The leaking gasoline contaminates the surrounding ground water,
resulting in contamination of drinking water supplies, surface waters, and/or
infiltration into POTW collection systems.
Types and sources of wastewaters resulting from site cleanups that may be
treated by a POTW include the following:
Leachate from landfills
Contaminated ground water from ground-water cleanups
t Aqueous wastes stored in containers, tanks, and surface impoundments
Treatment sludges from remedial treatment systems at cleanup sites
Stormwater runoff from contaminated soils
wastes from decontamination of containers, tanks, equipment,
buildings, pavement and surrounding areas.
Wastes from site cleanups may be discharged directly to the POTW, discharged
by separate pipe to the POTW, or hauled by truck or rail to the POTW.
3-93
-------
Appendix I presents State/local data regarding hazardous waste discharges
to POTWs as a result of hazardous waste site cleanup activities. Although the
data are very limited, the pollutants and concentrations shown are signifi-
cant. The organic chemicals listed in Appendix I for this category include
chlorinated derivatives of ethane and ethylene, which are used widely as
solvents for degreasing and other applications, and chlorinated derivatives of
benzene, which are used widely both as chemical intermediates and as solvents.
Various heavy metals also are listed for this category. The hazardous
constituents listed most frequently are chromium (5 occurrences), and o-, m-,
and p-dichlorobenzene (2 occurrences each). The hazardous constituents with
the highest average discharge concentrations are chromium (1758 mg/1), dis(2-
chloroethyl)ether (210 mg/1), chloroform (200 mg/1), toluene (22.4 mg/1),
tetrachlorobenzene (11.7 mg/1), and 1,2,4-trichlorobenzene (11,7 mg/1).
Only one incident related to a hazardous waste site cleanup was
identified during the investigation of incidents at POTWs. A POTW reported
that gasoline or gasoline contaminated water had been discharged from a site
contaminated with gasoline. In addition, Table 3-25 presents data for seven
hazardous waste cleanup sites where wastewaters were discharged to POTWs. The
data are taken from a March 1984 EPA report entitled Summary Report: Remedial
Response at Hazardous Waste Sites, which provides case studies for a variety
, .
of hazardous waste site cleanups. ;
3.4.2.7 Laboratories and Hospitals
Dun's Marketing Service data indicate that there may be as many as 30,000
hospitals and research, college, and medical laboratories in the United
States. The SQG data base (Table 3-24) estimates that 5,643 hospitals and
laboratories are SQGs, and that 2,926, or approximately 52 percent of the
total, discharge their hazardous wastes to POTWs. According to Table 3-24,
these 2,926 hospitals and laboratories discharge over 2 million kilograms per
year of hazardous wastes, including spent solvents (50 percent of all waste),
ignitable wastes (20 percent), strong acid or alkaline wastes (15 percent) and
other reactive wastes (15 percent). Common laboratory solvents include the
following hazardous materials: acetone, methyl ethyl ketone, methyl isobutyl
ketone, benzene, toluene, methylene chloride, and methanol. Strong acids/
3-94
-------
TABLE 3-25. DATA FOR HAZARDOUS HASTE CLEANUP SITES WHERE WASTES WERE DISCHARGED TO POTWs
to
01
Site Name/Location
Howe, Inc.
Brooklyn Center, MN
Anonymous Site C
Depere, WI
Chemical Recovery Systems, Inc,
Romulus, MI
College Point Site
Queens, NY
General Electric
Oakland, CA
N.U. Mauthe, Inc,
Appleton, WI
Quanta Resources
Queens, NY
Type of Incident
Fire in pesticides warehouse;
runoff from fire; contaminated
soil and ground water
Spills/dumps of chromic acid on
ground contaminated soils and
ground water
Leakage and dumping of still bottom
wastes contaminating soil and
ground water
PCB contaminated oil dumped into
1agoon
PCB contaminated soils at site from
spills/dumps off PCB oils
Soil and groundwater contamination
from plating waste leakage from
plating shop
Abandoned waste oil recycling
facility with about 500,000
gallons of wastes
Type and Quantity Waste Discharged
to POTW
Surface water: 2.1 x 105 yal.
(8 x 10° 1) fi
Groundwater; 90 x 10 gal.
(340 x 10bl)
Groundwater from runoff: 72,000
gal. (273,600 I) in 1981,
continued in 1982 and possibly
thereafter
Groundwater: 700-4,000 gpd
(2,600-15,152 Ipd) for unknown
period
Lagoon water: 318,000 gal
(1.2 x 10b 1)
Groundwater: 1,000-1,500 gal.
(3,800-5,700 I) per month for
unknown period
Surface water, runoff, and ground-
water: 273,000 yal (1.03 x 10°
1) from April to December 1982.
Unknown how long discharges
continued after 12/82.
Hazardous and nonhazardous water
from the site: 166,469 gal.
(630,085 1)
Waste Constituents
[Maximum Concentrations]
Approximately 100 different pesticides
and herbicides
[only sampling data in report was for
ice from runoff which showed a maximum
of 5,200 mg/1 of atrazinej
Hexavalent chromium [1,440 mg/1 to 4,300
mg/1]
Total Chromium [1,511 mg/1]
Chloroform [200 mg/1]
Phenol [18 mg/1]
PCB contaminated water pretreated to
lower 0*6 to <30 mg/1
[concentrations of PCB in water
unknown but PCB concentration in oil
reached 240 mg/1]
PCB contaminated groundwater pretreated
by oil water separation to an average
of 0.1 ppb PCBs.
Hexavalent chromium primarily
[230-420 mg/1]
Pretreated wastewater (pretreatment
consisted of oil/water separation,
physical/chemical treatment and
filtration)
[No effluent analyses reported, but
had to meet NYC Industrial Discharge
Criteria]
-------
bases used frequently in laboratories include caustic soda, hydrochloric acid,
sulfuric acid, nitric acid, and chromic acid. Broken thermometers or spilled
barometer reservoirs can result in mercury discharges to POTWs from
laboratories.
Inasmuch as most hospitals contain a laboratory, the wastes cited above
also are generated by hospitals. In addition to these wastes, phenol and
cresol-based disinfectants often are used by hospitals and may be discharged
to POTWs. Hospital anesthetics include chloroform and diethyl ether, which
may be discharged to POTWs in small amounts. Moreover, some RCRA-listed
hazardous waste constituents reported by hospitals in the HWDMS data base are
drugs, including chloroambucil, daunomycin, methylthiouracil, and mitomycin C.
Hospitals also employ x ray film developing processes that generate wastewater
contaminated with silver. However, some facilities have installed silver
recovery units to reduce silver discharges from these operations.
Appendix I presents State/local data on the discharge of hazardous
pollutants by laboratories and hospitals. The sampling data include numerous
heavy metals, solvents, and disinfecting compounds. The metals most fre-
quently identified are silver (67 occurrences), zinc (54), and copper (53).
The pollutants with the highest average discharge concentrations are toluene
(70 mg/1) and 1,2-dichloroethane (31 mg/1). Other significant pollutants
detected include toluene, 1,2-dichloroethane, methylene chloride, phenol, and
cyanide. One known POTW incident resulted from wastewater discharged from a
research laboratory (Appendix K). The POTW's wastewater treatment plant was
out of service for 2 days as a result of a fire at the laboratory facility,
which caused unknown chemicals to be discharged to the POTW's sewers. No
followup action was identified by the POTW.
3.4.2.8 Miscellaneous Chemical Formulations
The miscellaneous chemical formulations category includes a broad variety
of chemical processes that are not covered in other industrial categories,
such as inorganic and organic chemicals, plastics, pesticides, etc. The SQG
data base (Table 3-24) projects 565 generators and 80 indirect dischargers in
this category. These 80 SQG facilities are estimated to discharge 188,316
3-96
-------
kilograms of hazardous waste per year, Including strony acid or alkaline
wastes (60 percent of all wastes), spent solvents (25 percent), and pesticide
washing and rinsing solutions (10 percent).
The HWDMS data base (Appendix M) lists hazardous wastes potentially
discharged by the miscellaneous chemical industries of this category.
Predominant waste types for this category are solvents such as methanol,
methyl ethyl ketone, methyl isobutyl ketone, pyridine, acetone, and tetra-
chloroethylene. Appendix I presents State/local data on hazardous waste dis-
charges to POTWs by miscellaneous chemical formulators. The pollutants cited
consist principally of solvents (acetone, toluene, chloroform, etc.), solvent
degreasing compounds (1,1,1-trichloroethane, 1,1,2,2-tetrachloroethane, etc.),
plasticizers (phthalate esters), and metals. The pollutants most frequently
identified in Appendix I are chromium, lead, copper, nickel, zinc (4 occur-
rences each), and cyanide (3 occurrences). The pollutants with the highest
average discharge concentrations are acetone (2.9 mg/1), methanol (2.5 mg/1),
and cyanide (0.76 mg/1).
3.4.2.9 Motor Vehicle Services
Motor vehicle services include car and truck repair, body shop and
painting shop work, car washing, and service station products sale (gasoline,
oil). According to Dun's Marketing Service, there are as many as 433,000
firms providing these services nationwide. The SQG Survey (Table 3-24)
indicates that 191,901 motor vehicle operations are SQGs, while 3,587, or 2
percent of this total, are discharging wastewaters to POTWs. These 3,587
facilities are estimated to be discharging 1,318,860 kilograms per year of
hazardous wastes, including solvents (90 percent of all wastes) and strong
acid or alkaline wastes (10 percent).
Solvents used in small amounts at service stations for degreasing and
cleaning include chlorinated solvents, such as methylene chloride, and
petroleum products, such as kerosene and naphtha. Gasoline contains toxic
substances such as benzene, toluene, and tetraethyl lead. Other chemicals
used in significant amounts include diethyl ether, methanol, and sulfuric
acid. Waste lead-acid battery solutions constitute a source of lead and
3-97
-------
sulfuric acid. Also, painting operations will generate waste solvents and
paints. Paint wastes contain metal pigments, as well as ignitable organic
solvents, such as toluene, xylene, and naphtha.
Appendices I and K present State/local data regarding hazardous waste
discharges to -POTWs by motor vehicle services industries. Appendix I cites
heavy metals as hazardous pollutants commonly discharged by these industries.
The most frequently identified pollutants, as well as the pollutants found to
have the highest average concentrations, are zinc (73 occurrences, 775 mg/1),
copper (73 occurrences, 125 mg/1), and lead (70 occurrences, 2,324 mg/1).
These results largely reflect sampling efforts of a single POTW, which sampled
several radiator shops and detected extremely high levels of these metals in
process wastewaters discharged by these shops. The AMSA POTW survey data
(Appendix K) show that 10 of the 66 POTWs surveyed reported that discharges
from motor vehicle operations caused problems with the collection system or
treatment plant. Many POTWs reported gasoline spills into their collection
systems from service stations and other sources. These POTWs include
Albuquerque, NM; Bergen County, NO; Fort Worth, TX; Hartford, CT; Rochester,
NY; and the Washington Suburban Sanitary Commission (WSSC), MD. In general,
these incidents related to spills or leaking underground storage tanks.
However, in one case, gasoline was inadvertently pumped from a tank truck into
the public sewer rather than into an underground storage tank. The incidents
cited above caused a variety of POTW problems, including plant upsets and
explosions/fires (see Appendix K for details). As an example, an automobile
repair facility in Massachusetts was found to be discharging high-flash
(19)
naphtha (degreasing solvent), toluene, and xylene to the POTW/ Although
no serious damage occurred as a result of the incident, these discharge
practices significantly increased risk of fire/explosion and adverse health
impacts on POTW personnel.
3.4.2.10 Service-Related Industries
Firms within this category provide a wide variety of services to
commercial clients and/or private citizens. Dun's Marketing Service estimates
that as many as 1.16 million firms may be included in this category. Services
3-98
-------
with high potential for generating hazardous waste include agricultural ser-
vices, photographic processing, warehousing, pesticide spraying, disinfection
and extermination services, and funeral services.
The SQG Survey (Table 3-24) collected data on 1,716 facilities in this
industry and estimated that there were 43,390 SQGs in the United States.
Based on the SQG Survey, there are 23,395 facilities discharging to POTWs or
approximately 53 percent of the industry. As estimated by the SQG Survey,
these indirect dischargers account for over 23 million kilograms per year of
hazardous waste discharged to sewers, averaging approximately 1,000 kilograms
per year per facility.
According to Table 3-19, over half of the total hazardous waste
discharged to POTWs by SQGs comes from service-related industries. The
largest quantity of hazardous waste discharged from a single source within the
service-related industrial category is waste formaldehyde from funeral
parlors. Approximately 8 million kilograms a year from an estimated 12,000
facilities are discharged to the sewers. Photographic wastes containing
cyanide and chromium either in spent chemical baths or in sludges precipitated
out of these baths also account for approximately 8 million kilograms per
year. An additional 4 million kilograms per year of solutions or sludges con-
taining silver from photographic processing also are estimated to be dis-
charged to sewers. Photofinishing laboratories and commercial photographers
account for the majority of this waste. Other hazardous wastes discharged
from SQG facilities within the service-related industry originate from the
following sources:
Approximately 600,000 kilograms per year of waste pesticide solutions
from agricultural services and disinfecting and exterminating services
(potentially containing pesticides and disinfectants such as aldicarb,
lead arsenate, methoxychlor, disulfoton, 2,4-D, 2,4,5-T, pentachloro-
nitrobenzene, pentachlorophenol, ethylene dichloride, l,2-dibromo-3~
chloropropane, cresols, and phenols)
Approximately 500,000 kilograms per year of spent solvents from
funeral parlors; photofinishing labs, and furniture refinishers
(probably including basic solvents, such as benzene, toluene,
1,1,1-trichloroethane, and methylene chloride)
3-99
-------
t Approximately 350,000 kilograms per year of reactive wastes containing
ammonia from janitorial services
Approximately 200,000 kilograms per year dry cleaning filtration
residue probably containing tetrachloroethylene from furniture
reupholsterers.
Appendix I presents State/local data on the discharges of hazardous
wastes to POTWs by service-related firms, the majority of which were photo-
processing laboratories. The pollutants listed consist entirely of heavy
metals and cyanide. Organics data generally are lacking since POTWs generally
do not expend the resources to obtain organics data for service-related indus-
tries. The pollutants identified most frequently are silver (48 occurrences),
copper (32), zinc (32), and nickel (29). The pollutants with the highest
average discharge concentrations are cyanide (5.07 mg/1) and silver (3.85
mg/1). These.data support the conclusion that photographic processing
laboratories discharge a high level of metals and cyanide to the sewers. One
POTW has indicated that collection system corrosion problems have occurred due
to low pH discharges (as low as three) by a photofinishing facility (see
Appendix K).
3.4.2.11 Soaps and Detergents, Cleaning Preparations, and Waxes Manufacture
and Formulation
According to Dun's Marketing Service, as many as 3,600 firms manufacture
soaps, detergents, cleaning preparations/waxes. The SQG data base (Table
3-24} projects 602 SQGs overall, and 209 SQGs, or 35 percent of the total,
discharging wastes to POTWs. These wastes consist largely of pesticide
washing and rinsing solution (50 percent of all wastes discharged) and strong
acid or alkaline wastes (40 percent). Wastewaters from soap manufacture
consist mainly of tank washouts and spills/ leaks. Wastewater sources in some
cases also include barometric condensate, boiler blowdown, and intake water
treatment. Raw wastes from soap manufacture are generally high in pH and
alkalinity, due to the presence of caustic. Wastewaters from detergent
manufacture also originate from tank washing, spills, and leaks, as well as
from scrubbers. Wastewaters from detergent manufacture are generally low in
pH and high in acidity, due to the presence of sulfuric acid/ '
3-100
-------
Wastewaters from the manufacture of cleaning preparations and waxes
originate from a wide variety of chemical processes, and therefore defy simple
characterization. Based on information contained in the HWDMS data base
(Appendix M), constituents of wastewaters from the manufacture of cleaning
preparations, waxes, soaps, and detergents may include the following hazardous
compounds:
Phenols and cresols (disinfectants)
Methyl ethyl ketone, methyl isobutyl ketone, benzene, butanol ,
isobutanol, cyclohexane, toluene (solvents)
Ethyl acetate (textile cleaning preparations)
§ Nitrobenzene (soap, shoe polish additive).
Appendix I presents State/local data on the discharge of hazardous wastes by
soap and detergent manufacturing industries to PQTWs, and indicates that a
wide variety of organic solvents, chemical additives, and metals are dis-
charged by these industries. The most frequently detected pollutants for this
category include nickel, zinc, chromium, copper (14 occurrences each), cadmium
(13), antimony (12) and lead (12). The pollutant with the highest average
concentration was xylene (275 mg/1).
3.4.2.12 Stone, Clay, Glass, Concrete, and Other Mineral Products
This category .encompasses the extraction of mineral raw materials from
the earth and their direct conversion into products. Typical industries in
this category include glass manufacture, stone quarrying, processing of
asbestos into textile products, and talc and gypsum manufacture. According to
EPA's SQG Survey (Table 3-24), no hazardous wastes can be expected to be
discharged to POTWs from industries within this category that generate less
than 1,000 kg of hazardous waste per month. Within the glass manufacturing
industry, only two manufacturers of flat glass and five manufacturers of
(2\)
automotive glass discharge any wastewaters to POTWs/ ' Hazardous waste
quantities within these wastewaters can be considered negligible since the
only nonconventional contaminants present result from oil and machine
lubricant wash-in.
3-101
-------
Appendix M delineates hazardous wastes types that typically are generated
by industries within this category. Most of the specific chemical wastes
cited for this industrial category consist of organic solvents (acetone,
methylene chloride, toluene, etc.). These chemicals can be expected to be
used in only minimal amounts by these industries. Appendix I presents
State/local data regarding hazardous wastes discharged by industries within
the stone, clay, glass, and other mineral products category. The hazardous
constituents identified consist of organic solvents and plasticizers and heavy
metals. The most frequently identified pollutants are chromium, cadmium,
copper, lead, nickel, and zinc (5 occurrences each). The pollutants with the
highest average concentrations are phenol (b.2 mg/1), zinc {5.0 mg/1), and
nickel (2.0 mg/1).
3.4.2.13 Transportation Services
This category includes firms that maintain vehicles for transporting
people, cargo, and municipal and industrial waste. Dun's Marketing Service
indicates that as many as 150,000 firms perform these services. The following
types of firms are included in this category:
Ship maintenance
Airport services
Railroad car cleaning
Tank truck cleaning (cartage firms)
Municipal refuse hauling
Septage hauling
Drum reclamation
Hazardous waste hauling
Cargo handling facilities (terminals).
The 150,000 figure includes as many as 127,013 miscellaneous trucking and
(22)
warehouse operations and an estimated 12,343 hazardous waste haulers.
However, facilities that typically generate and discharge significant
quantities of wastes, such as tank truck cleaning, septage hauling, and drum
reclamation services, are not included.
3-102
-------
The EPA report, Investigation of New Industries, estimated that in 1978
there were 500 tank truck cleaning terminals and 400 drum cleaning facili-
(2?}
ties/ ' Using figures from the 1978 EPA report Source Assessment: Rail
Tank Car, Tank Truck, and Drum Cleaning, State of the Art, the report in-
dicated that wastewater discharges resulted from the cleaning of approximately
5,010,000 tank trucks and 14,580,000 drums per year/23' Quantities of
hazardous waste generated and discharged to POTWs by transportation service
facilities are unknown. The SQG Survey estimated that 582 transportation
service facilities discharge 26,436 kilograms per year of spent solvents to
POTWs. In addition, a 1981 EPA study estimated that drum reconditioning firms
generate approximately 74,000 metric tons (162 million Ibs) of hazardous
(24}
wastes per year/ '
Liquid waste haulers represent an additional source of hazardous waste
discharges to POTWs. Some of these discharges fall into the category of
illegal or midnight dumping, while other discharges result from legal dis-
charges by septage and liquid waste haulers to POTWs. The following incidents
provide examples of midnight dumping:
.(25)
In 1979 and 1980, a New Jersey waste hauler discharged an undetermined
number of drums of hazardous waste into its warehouse's sewer
Another New Jersey waste hauler discharged more than a quarter of a
million gallons of toxic wastes and sludge into a POTW's sewer
Also in New Jersey, a waste hauler trucked an estimated 3.2 million
gallons of flammable wastes to the hauler's owner's facility and
dumped these wastes into a POTW's sewers.
Review of hazardous waste-related incidents at POTWs (Appendix K) indicates
that the following incidents have occurred at POTWs as a result of waste
haulers:
POTW
Central Contra
Costa, CA
INCIDENT
Biological upset from solvents
discharged by liquid waste
hauler
3-103
-------
POTVJ
Orange County, CA
Marysville, NJ
Encino, CA
t San Diego, CA
INCIDENT
Caustic discharged by liquid
waste hauler
Biological upset from penta-
chlorophenol discharge; waste
hauler suspected
Collection system explosion/
fire attributed to septic waste
hauler's discharge
Collection system explosion/
fire attributed to liquid waste
hauler's discharge of gasoline.
In addition, several incidents were reported, but could not be traced to any
source. It is probable that some of these incidents can be attributed to
waste haulers. The AMSA POTW survey (Appendix K) indicates that 26 of 62
POTWs reported problems caused by midnight dumping. Additionally, 21 of these
POTWs reported problems with liquid septage haulers and 15 reported problems
with other liquid waste haulers.
It is estimated that 50-60 million storage drums were cleaned in
(22)
1984/ ' Many of these were cleaned by exposing the drums to high temper-
atures to burn off any residue, or cleaned with various cleaning agents,
similar to those used in tank car cleaning discussed above. Hazardous wastes
will be generated if the drum previously contained hazardous materials or if
the cleaning agents used are hazardous (e.g., caustic or corrosive). After
drums are cleaned, they may be repainted. Spray painting may occur in special
paint booths that utilize water curtains which are also a potential source of
hazardous waste discharges. Also, paint spills represent a potential source
of hazardous wastes to POTWs. The following hazardous waste-related incidents
caused by drum cleaning and reclamation facilities were reported by POTWs:
.{19)
A drum cleaning company in Massachusetts was found to be discharging
liquid chemical residues from barrels into the POTWs sewers.
Untreated caustic wastewater from a barrel washing operation also was
discharged to the sewers.
3-104
-------
An 8-acre drum cleaning and recycling plant in Texas was subjected to
regulatory action for discharging wastes directly into the city sewer
system.
An Iowa metal drum recycling operation that has been the cause of
chronic oil contamination of surface waters, as well as one onsite
fire, has been discharging 58 tons of spent caustic wastes annually to
the nearby POTW.
Further, sampling results of wastewater discharges from a drum reconditioning
facility in New York indicated significant quantities of hazardous constitu-
(261
ents. In summary, the hazardous constituents found in high concentrations
include: benzene (1,400 ug/1), ethyl benzene (1,400,000 ug/1 and 286,000
ug/1), toluene (1,400,000 ug/1 and 59,000 ug/1), phenol (6,830 mg/1 and 566
mg/1), and napthalene (24,000 ug/1 and 68,000 ug/1).
Hazardous wastes generated at ship cleaning facilities contain constitu-
ents of fresh paint such as chromium and lead pigments, and solvents such as
toluene. Heavy metals also can leach from used paint chips scraped from hulls
and discarded in a sewer. Spent strong acid or alkaline cleaning solutions
also constitute hazardous wastes that may be discharged at ship cleaning
facilities. Airports can generate hazardous wastes that include spilled
aviation fuel and degreasing solvents. Vehicles used to transport chemical
products, such as railroad tank cars and tank trucks, frequently are cleaned
out with various cleaning agents. Typical cleaning agents used are steam,
water, detergents, caustic or acid solutions, and solvents. The spent
cleaning solutions could contain virtually any hazardous waste, depending on
the chemicals most recently hauled. Spent solvents, however, appear to be the
most significant hazardous constituents of these wastes. These spent cleaning
solutions often are discharged to sewers with minimal pretreatment. Several
waste related incidents involving a tank car cleaning facility have occurred
(19)
in Cleveland, Ohio.v ' The tank car cleaning facility has a neutralization/
reacting chlorine operation that has resulted in the deaths of two employees
and numerous health-related incidents. The facility also has been illegally
discharging its cleaning wastes to the Cleveland sewer system.
3-105
-------
Another major source of hazardous waste dicharges to POTWs results from
tank truck spills. Appendix K indicates that the following incidents have
occurred at POTWs as a result of tank truck activities:
POTW
Alberquerque, NM
Anchorage, AK
Indianapolis, IN
Nashville, TN
Rochester, NY
St. Paul, MN
INCIDENT
gasoline spill washdowns
gasoline spill washdowns
gasoline spill washdowns; one
resulting in fire/explosion
gasoline spill washdowns
gasoline spill washdowns
gasoline spill washdowns.
Cargo handling facilities and petroleum tank farms/terminals also represent
potential sources of hazardous wastes. These wastes may be discharged to
POTWs as a result of tank overflows, spills, etc. Generally, these wastes can
be expected to consist of ignitable or toxic constituents such as benzene,
toluene, kerosene, naphtha, turpentine, methyl isobutyl ketone, hexane, etc.
The HWDMS data base (Appendix M) indicates that almost any hazardous
waste potentially could be discharged by facilities within this category.
State and local data (Appendix I) indicate that cyanide and 10 toxic metals,
as well as 24 organic compounds, were detected in significant amounts in
discharges from facilities within this category. According to Appendix I, the
most frequently identified hazardous constituents in discharges to POTWs by
industries within this category were nickel (17 occurrences), zinc (17), lead
(16), copper (16), chromium (15), and cadmium (13). The most frequently
identified toxic organics were toluene (8), trichloroethylene (6), and
1,1,1-trichloroethane (5). The pollutant with the highest average discharge
concentration identified is tetrachloroethylene (1.4 mg/1).
3.4.2.14 Waste Reclamation Services
The types of operations conducted at waste reclamation facilities are
varied and consist of facilities that are engaged primarily in the collection
3-106
-------
and reclamation of scrap and waste materials. Waste reclamation operations
generating significant quantities of wastes may include the following:
Waste oil reclamation by filtration, water separation, or other method
for reuse, or by incineration for heat recovery
Waste solvent reclamation by distillation, filtration, or other method
for reuse, or by incineration for heat recovery
Acid regeneration
Metal recovery from sludges
Battery salvage.
Appendix L shows the subcategories of waste reclamation service facilities.
The only subcateyory for which the number of facilities could be identified
was metals reclamation with as many as 9,450 facilities.
The SQG Survey did not report on waste reclamation facilities. Very
little data are available on the numbers of waste reclamation facilities that
generate hazardous waste or on the number of these facilities that discharge
wastes to POTWs. However, information from studies covering various segments
of the waste reclamation industry provides a profile of types and quantities
of wastes generated and potentially discharged by these facilities. In an EPA
report, Investigation of New Industries, SAIC estimated the number of solvent
nj-o)
reclaimers to be between 225 and 300.v ' The quantity of solvents reclaimed
in 1981 was estimated to be over 100 million gallons, with the quantity
expected to increase substantially over time. A report done by the California
Hazardous Waste Management Project (February 1983) showed that in Los Angeles
County alone there were three solvent recyclers with a combined capacity of
(271
5.85 million gallons per year/ ' Waste oil recyclers are another large
source of hazardous waste. From the above-referenced California report, nine
waste oil recycling firms were identified in Los Angeles County alone. These
nine facilities recover 18 million gallons of used oil annually.
Most waste reclamation operations generate wastes from removal of
contaminants from the waste being reclaimed. The resulting purified product
3-107
-------
then can be reused or burned for heat recovery. The types of wastes generated
and their corresponding sources include the following:
Oily aqueous wastes from oil/water separation
Sludges containing metals, oil, grit, or other contaminants from oil
filtration and purification operations
Sludges containing metals, grit, solvents, or other contaminants from
solvent distillation processes
Sludges containing metals, oil, grit, hydroxide compounds, or other
contaminants from acid regeneration and metal recovery operations
t PCB-contaminated waste oils and sludges from the reclamation of
electrical transformer and capacitor dielectric fluids
t Acid or acid-neutralized wastes containing metals from battery salvage
operations.
Waste reclamation facilities are also prone to spills and leaks of the wastes
being reclaimed, the purified products, and the wastes generated by the
reclamation operations. Waste reclamation facilities also have caused
problems with soil and ground-water contamination and, in many cases, have
eventually become hazardous waste cleanup sites. Some of these so-called
waste reclamation facilities were nothing more than indefinite waste storage
facilities that eventually closed, leaving the accumulated wastes behind.
The HWDMS data base (Appendix M) indicates that waste reclamation
facilities reported to EPA that they generate wastes considered EP toxic for
each of the RCRA-listed metals, as well as spent solvents, acids, plating and
cleaning baths, still bottoms, and oil sludges. Appendix I presents State/
local data concerning hazardous waste discharges to POTWs by waste reclamation
industries. Although data are limited, 32 toxic organic compounds, 6 metals,
and cyanide were detected at these sites. A variety of organic chemicals are
listed, such as toluene (utilized in fuels and as a solvent, especially in
paints), ethylbenzene (chemical intermediate for styrene manufacture and used
as a solvent), chlorobenzene (chemical intermediate and used as a solvent) and
chlorinated ethanes and ethylenes (used as solvents, especially in degreas-
ing). The most frequently identified pollutants listed in Appendix I are
3-108
-------
toluene (45 occurrences), 1,1,1-trichloroethane (36), methylene chloride (30),
tetrachloroethylene (27), trichloroethylene (25), and ethyl benzene (24). The
pollutants with the highest average concentrations are ethyl benzene (250
mg/1), xylene (170 mg/1) bromoform (83 mg/1), 1,1,1-trichloroethane (37 mg/1),
and tetrachloroethylene (21 mg/1).
Discharge data were collected for an indirect discharging solvent
recovery facility as a result of the EPA sampling program initiated for this
study (see Appendix J). The results of the sampling program for this facility
(sampled over a 1-day period) found several hazardous organic constituents in
high concentrations. A summary of the data collected for this solvent
recovery facility is as follows:
Hazardous Organic Constituent
Acetone
Benzene
Methylene Chloride
Toluene
Trichloroethane
1,1,2-Trichloroethane
1,1,2,2-Tetrachloroethane
Concentration (ug/1)
415,110
26,130
5,319
438
352
2,090
2,090
As the above data reveal, raw wastestreams from solvent recovery facilities
can be expected to contain common industrial organic solvents. The exact
composition and concentration profile of each wastestream would depend upon
the nature and composition of the waste solvent being reclaimed.
The AMSA POTW survey (Appendix K) showed that a total of seven waste
reclamation facilities were identified as problem industries. In a related
incident, one POTW reported problems caused by a waste reclamation facility.
A battery salvaging operation generated waste acids that were "midnight
dumped" over a period of 3 to 4 years. As a result of these discharges,
sections of sewer pipe and pumps had to be replaced. The company was forced
to shut down and halt its discharges.
3-109
-------
3.4.2.15 Waste Treatment and Disposal Facilities
The types of facilities in this category can be split up into two major
classes, including those that handle hazardous waste regulated under RCRA
Subtitle C and those that handle solid, nonhazardous waste. The first class
includes Subtitle C treatment, storage, and disposal facilities {TSDFs), which
EPA has estimated to number 4,961 (See Appendix L). About 4,000 of these
facilities are located at establishments that are classified as manufacturers.
The RCRA TSDFs include facilities that store or treat hazardous waste in
containers, tanks, surface impoundments, or wastepiles, or dispose hazardous
waste in landfills, surface impoundments, or incinerators. Generators that
store hazardous waste for less than 90 days or treat waste in tanks that are
part of a wastewater treatment system regulated under the NPDES or pretreat-
ment programs are not considered TSDFs under RCRA. The second major class
covers Subtitle D municipal and industrial landfills and surface impoundments.
A report developed by the Office of Technology Assessment estimated that there
may be as many as 202,562 waste units that qualify as Subtitle 0 land disposal
facilities/ ' A third, smaller class of waste treatment and disposal
facilities includes centralized industrial waste treatment facilities. Many
of these, however, are already included in the RCRA TSDF group.
Currently, there are no reliable estimates for the number of waste
treatment and disposal facilities that are indirect dischargers. Generally,
storage and land disposal facilities do not discharge wastes to POTWs.
However, in certain cases where contaminated runoff or leachate is collected,
the facility may truck these wastes to the POTW or discharge directly to the
POTW if the facility is connected to the POTW's sewerage system. Treatment
facilities and incineration facilities also may discharge wastes to POTWs.
These wastes include the effluent from the treatment systems, contaminated
runoff, and air pollution scrubber wastewater.
Wastes from waste treatment and disposal facilities may contain diverse
constituents and can be expected to reflect the makeup of the wastes being
treated at the facility. Landfills that accept many kinds of wastes,
particularly municipal landfills, also can generate leachate contaminated with
a variety of compounds. The HWDMS data base (Appendix M) shows the types of
3-110
-------
hazardous waste reportedly managed by RCRA TSOFs. As indicated, almost all
characteristic, and listed wastes regulated by RCRA have been reported as
potentially present at these facilities. Data from this appendix support a
conclusion that virtually any type of constituent may be present in wastes
from TSDFs.
Appendix I presents State/local data relating to hazardous wastes
discharged to POTWs by waste treatment and disposal facilities. Although the
data are limited, 38 organic compounds, 10 metals, and cyanide have been
detected in these effluents. A wide variety of organic compounds are listed,
including chlorinated ethanes and ethylenes (solvents, especially for
degreasing); chlorinated benzenes (solvents, chemical intermediates); phenol
(chemical intermediates, disinfectants, resins); methyl ethyl ketone/methyl
isobutyl ketone (paint solvents, paint removers); bis{2-ethylhexyl)phthalate
(plasticizers); chloroform/methylene chloride (volatile solvent applications,
including degreasing, paint removing), etc. The most frequently identified
hazardous constituents listed in Appendix I, however, are generally metals,
including nickel (55 occurrences), cyanide (54), copper (54), phenol (45),
chromium (41), lead (38)» cadmium (36), and zinc (35). The hazardous con-
stituents with the highest average discharge concentrations are: chloro-
benzene (6.3 mg/1), phenol (5.6 mg/1), tetrahydrofuran (5.5 mg/1), acetone
(3.3 mg/1), and zinc (3.3 mg/1). As further indication of hazardous con-
stituents discharged to POTWs, analytical data for the effluent from a waste
(14)
treatment and disposal company in New Jersey were obtained and reviewed/ '
Data for monthly averages of total toxic volatile organic compounds ranged
from a low of 0.32 ppm to 21.92 ppm for an 8-month period. The maximum single
value for the period was 137.27 ppm of toxic volatile organics.
Three incidents at POTWs caused by waste treatment and disposal
facilities were identified during the investigation of POTW incidents
{Appendix K). In the first case, the discharge of hazardous constituents
caused inhibition of treatment processes. In the second case, chlorinated
organics were discharged, producing hazardous odors in the collection system,
and forcing workers to leave the collection system. The offending company
installed a new treatment system to alleviate this problem. In the third
3-m
-------
case, a hazardous waste treatment and recycling facility connected to a POTW
and began discharging various wastes containing metals and solvents. These
discharges resulted in worker illness from solvent fumes, and severe con-
tamination of the POTW's sludge with metals discharged by the facility. When
sewer use ordinance provisions were enacted by the POTW to remedy the problem,
the company moved to another POTW's jurisdiction.
(22)
An EPA study, Investigation of New Industries, ' and the AMSA POTW
survey (Appendix K) show that the number of waste treatment and disposal
facilities are Increasing substantially. The AMSA POTW survey indicates that
the number of requests for connection to POTWs by waste treatment and disposal
facilities increased from 4 in 1981 to 13 in the first 6 months of 1985.
Consequently, these types of facilities will become an Increasing problem for
POTWs, particularly since existing pretreatment controls, such as categorical
standards, generally do not address wastewaters discharged by these facili-
ties, and information generally is not available to control these facilities
through the general prohibitions and local limits provisions in the General
Pretreatment Regulations.
3.4.2.16 Wholesale and Retail Trade
Companies in this category are Involved In selling industrial,
commercial, and household products. Appendix L indicates that more than
22,500 firms are engaged 1n this business. The SQG data base (Table 3-24)
projects 366 indirect discharges in this category out of a total number of
5,733 generators. These 366 facilities discharge an estimated 160,020
kilograms per year of different waste types, including ignitable paint wastes
(25 percent of all waste), photographic wastes (20 percent), spent solvents
(20 percent), wastewater wood preservatives (15 percent), and pesticide
washing and rinsing solutions (15 percent). Activities within this broad
category most likely to discharge hazardous wastes to sewers include sales of
chemical products, petroleum products, and Industrial supplies. Virtually any
product sold by these firms potentially can be discharged to a POTW as a
result of Improper handling, spills, discards of off-spec or aged chemicals,
etc. Commonly discharged hazardous wastes include volatile solvents 1n
discarded paint products, cresols In discarded creosote wood preservatives,
3-112
-------
household and commercial pesticide products, and commonly used petroleum
solvents and fuels such as naphtha, turpentine, or kerosene.
Appendix I presents State/local data on hazardous wastes discharged to
POTWs by wholesale trade industries. The hazardous constituents listed
consist of heavy metals, solvents, and plasticizers. The hazardous con-
stituents most frequently identified are cadmium, copper, mercury, nickel,
silver, and zinc. The hazardous constituents with the highest average
discharge concentrations are zinc (0,68 mg/1), lead (0.40 mg/1), and arsenic
(0.26 mg/1).
3.4.2.17 Wood Furniture Manufacture and Refinishing
Tndustries in this category produce furniture from wood and/or finish,
refinish, clean, and paint new and used wood furniture. According to Dun's
Marketing Service, there are as many as 31*000 of these firms nationwide. The
SQG Survey (Table 3-24) shows 2,393 generators, of which only 200 are pro-
jected to be discharging to POTWs. The SQG Survey shows that these 200
facilities discharge almost 400,000 kg of hazardous waste per year, including
filtration residue from dry cleaning (60 percent of all waste) and spent
solvents (40 percent). Most of these wastes are spent solvents and residues
from wood finishing, refinishing, cleaning, and painting operations.
Common solvents found in varnishes and paints applied to wood include
acetone, methyl ethyl ketone, methyl isobutyl ketone, methanol, toluene, and
methylene chloride. Polyurethane coatings, commonly used by wood furniture
refinishers, contain toluene diisocyanate as a resin monomer. Paints
generally contain plasticizers, such as dioctyl phthalate and bis(2-ethyl-
hexyl) phthalate, to reduce paint cracking upon aging. Other hazardous
constituents of paints include: various inorganic paint pigments, such as
litharge (PbO), red lead (PbgOj + PbO), and emerald green (Cr20(OH)4);
asbestos and barite (barium sulfate), which often are incorporated into paints
as extenders; and chlorinated phenols, which are added to latex paints as a
paint preservative. Paint stripping solvents generally consist of flammable
solvents, such as naphtha, turpentine, methyl ethyl ketone, toluene* methanol,
or methylene chloride. Paint strippers also may contain phenols and cresols.
3-113
-------
Another solvent, tetrachloroethylene, is used to dryclean upholstery and may
be used in substantial quantities by refinishing firms for this purpose.
Finally, creosote (cresols) may be added to some wood products as a
preservative.
The HWDMS data base (Appendix M) describes hazardous wastes typically
generated by wood furniture manufacturers and refinishers. These data support
the conclusion that the principal hazardous wastes generated by these firms
are volatile organic solvents from wood finishing and refinishing operations
described above. Additional major varnish and shellac solvents, cited in the
HWDMS data base, include ethyl ether, ethyl acetate, and cyclohexanone.
Appendix I presents State/local data on hazardous wastes discharged to POTWs
by wood furniture manufacturing, finishing, and refinishing firms. Although
sampling data for these firms are limited, they do show some high concen-
trations of organic solvents and heavy metals. Lead (4 occurrences each) was
identified most frequently. Two organic solvents, methanol and methylene
chloride, possess the highest average discharge concentrations (5,065 mg/1 and
1,474 mg/1, respectively). The AMSA survey data (Appendix K) show that, of
seven POTWs that have sampling data for wood furniture manufacture and
refinishing, two POTWs consider these facilities to be problem industries. In
one incident in Pensacola, FL, discharge of paint stripper resulted in a
biological upset of the POTW's treatment plant.
3.5 SOURCE EVALUATION OF HAZARDOUS CONSTITUENT LOADINGS TO POTW INFLUENT
WASTEWATERS
Previous sections of Chapter 3 have examined industrial survey/sampling
data to identify and characterize major sources of hazardous waste discharges
to POTWs, This section projects and evaluates hazardous constituent loadings
to POTW influent wastewaters, and describes possible industrial sources of
hazardous constituents known or believed to be common in POTW influent
wastewaters. Also, this section examines the possible correlation between
chemical use rates and hazardous constituent loadings to POTWs, and utilizes
this statistical relationship to project POTW influent loadings of selected
nonpriority pollutants. The final portion of Section 3.5 provides production/
use profiles for selected hazardous organic constituents.
3-114
-------
3.5.1 Projected National Loadings of Priority Hazardous Constituents to POTWs
In 1978, EPA initiated a project to study the occurrence and fate of
priority pollutants at 40 POTWs in the United States. This project, now
referred to as the 40 POTW Study, included an extensive sampling program for
all priority pollutants at 40 well-operated secondary treatment POTWs repre-
senting a variety of municipal treatment technologies, size ranges, and
(29}
industrial flow contributions/ ' The project also emphasized the develop-
ment of optimum POTW sampling methodologies and establishment of appropriate
analytical protocols and field and laboratory Quality Assurance/Quality
Control (QA/QCJ procedures for use during the entire study.
In selecting the 40 POTWs for sampling, EPA considered the following
factors;
Treatment processes
POTW size
t Amount of industrial contribution
Type of industrial contribution
POTW operating efficiency (i.e., meeting secondary treatment)
Actual flow as a percent of design capacity
Geographical distribution.
Overall, the POTW selection process incorporated a geographical and secondary
treatment type distribution that approximately profiled POTWs over 5 mgd
nationwide. The study evaluated at least one POTW from each EPA Region, and
POTWs from 25 different States. The number of plants in each EPA Region was
approximately proportional to the total number of POTWs over 5 mgd in that
region.
Total flow for the 40 POTWs was 1,739 mgd, or approximately 6.8 percent
of total POTW flow nationwide. The study focused primarily on POTWs greater
than 5 mgd in flow since these plants treat most of the Nation's wastewater
and are covered by the National pretreatment program. Industrial flow
contributions to these plants ranged from 0 to 50 percent, although the Agency
generally selected POTWs treating between 10 and 50 percent industrial
3-115
-------
wastewater flow. EPA selected POTWs accepting wastewater from a broad variety
of industries, and from most of the industrial categories encompassed by the
NRDC consent decree. The Agency attempted to select POTWs that were repre-
sentative of the National distribution for POTW size and industrial flow
percentages. Also, based on a comparison with industrial flow data from the
EPA NEEDS data base, the 40 POTWs appear to be fairly representative of the
mix of industrial flow percentages both for POTWs greater than 5 mgd in flow
and for all POTWs in the United States/30' Table 3-26 provides a comparison
of industrial flow contributions for wastewaters received by these three POTW
sets. Although not statistically representative of all POTW influent waste-
waters in the United States, the 40 POTW sampling data nonetheless provides a
rough profile of the types and quantities of priority hazardous constituents
discharged to POTWs Nationally.
The 40 POTW sampling data are also more reliable than other POTW sampling
data since they result from a project utilizing consistent and tested sampling
methodologies, analytical protocols and QA/QC procedures. Moreover, because
each POTW was sampled over a 6-day period, the 40 POTW data account more fully
for daily variation in pollutant loadings to individual POTWs. By comparison,
most other POTW priority pollutant sampling data result from 1-, 2-, or
occasionally, 3-day sampling sequences at individual POTWs.
In evaluating the representativeness of the 40 POTW data, the two
greatest concerns involve timing of the study and sample size. Because the
actual sampling for the 40 POTW study was conducted over a time period from
1979 to 1981, the data may not accurately reflect current priority hazardous
constituent loadings to POTWs, This concern is heightened somewhat in light
of the significant regulatory changes (e.g., RCRA implementation, pretreatment
implementation) that have occurred over the last 5 years. Also, sample size
for the 40 POTW study may not adequately represent the range of hazardous
constituent loadings, particularly organic constituent loadings, to POTWs
across the United States. In examining both 40 POTW data and other POTW
sampling data, it would appear that there may be extreme variations in organic
constituent pollutant loadings depending on the size and type of industrial
community contributing wastewater to a specific POTW. To meet this concern,
3-116
-------
40 POTW data were scrutinized for the presence of sampling data that could
severely skew National loadings projections. Alternative loading estimates
presented in this study reflect the existence of these statistical outliers in
the 40 POTW data base.
TABLE 3-26. COMPARISON OF INDUSTRIAL FLOW PERCENTAGES FOR
40 POTWS AND EPA NEEDS POTHS
% Indus-
trial Con-
tribution
0-10
11-30
>30
NEEDS Flow
40 POTW % of for POTW
Flow Total 40 >5 mgd
(mgd) POTW Flow (mgd)
692 40 6994
842 48 8749
205 12 4001
% of NEEDS Flow
Total NEEDS for all % of
Flow for POTWs Total NEEDS
POTW >5 mgd (mgd) POTW Flow
35 11,803 44
44 9901 37
20 4886 18
Table 3-27 provides estimates of National loadings for metals, cyanide,
and selected organic priority constituents based on POTW sampling data
contained in the 40 POTW study. As indicated in Table 3-27, two different
methodologies have been used in developing estimates for organic priority
constituent loadings. The first methodology utilizes flow-weighted average
constituent pollutant concentrations for influent wastewaters from all 40
POTWs evaluated in the study. The second, and preferred, methodology utilizes
flow-weighted averages, excluding organic priority constituent data from one
POTW (POTW #28) considered to be a statistical outlier in terms of the
quantities of certain organic priority constituents occurring in its influent
wastewater. This POTW receives approximately 6 million pounds per year of
organic priority constituents, an extreme value when compared with the other
39 POTWs evaluated in the 40 POTW study. Moreover, a review of ITD and ISDB
organics industry data revealed that the POTW was one of the largest known
receptors of process wastes from the organic chemicals and pesticide indus-
tries. Consequently, influent hazardous constituent loadings for this plant
were excluded for purposes of calculating the overall flow-weighted average
concentrations, but were included separately as part of total projected
organics loadings for all POTWs in the United States. The difficulties in
dealing with this POTW are indicative of the substantial, if not extreme,
3-117
-------
TABLE 3-27. NATIONAL HAZARDOUS PRIORITY CONSTITUENT LOADINGS
TO POTW INFLUENT
Inorganic Compounds
40 POTW
Influent
Frequency of
Detection
Antimony 14
Arsenic 15
Cadmium 56
Chromium 95
Cyanide 100
Lead 62
Mercury 70
Nickel 79
Selenium 9
Silver 71
Total
Organic Compounds
Acenaphthylene 0
Acrolein 0
Acrylonitrile 0
Anthracene 18
Benzene 61
Bis(2~ch1oroethoxy)methane 0
Bi s(2-chloroethyl)ether 0
Bis(2-ethyl hexylJphthalate 92
Bromomethane 3
Butyl benzyl phthalate 57
Carbon tetrachloride 9
Chlorobenzene 13
p-chloro-m-cresol 3
Chloroethane 3
Chloroform 91
Chloromethane 11
2-Chloronaphthalene 1
Di-n-butyl phthalate 64
1,2-Dichlorobenzene 23
1,3-Dichlor'obenzene 7
1,4-01chlorobenzene 17
Dlchlorodlfluoromethane - 2
1,1-Dichloroethane 31
1,2-Dichloroethane 15
1,1-Di chloroethylene 26
2,4-Dichlorophenol 7
National Influent
Loadings Based on
40 POTW
Data
(kg/yr)
158,230
132,471
636,599
5,151,668
15,120,147
4,386,278
22,078
3,013,726
18,398
367,976
28,717,499
0
0
0
29,430
677,076
0
0
1,847,241
253,903
596,121
467,330
139,830
7,359
3,679
673,396
831,626
3,679
360,616
379,015
69,915
73,595
412,133
33,117
17,320,646
103,033
7,359
National Influent
Loadings Based.
on 39 POTW
DataPOTW #28
Added separately
(kg/yr) _
0
0
0
29,430
354,110
0
0
1,712,750
115,977
345,298
278,195
136,304
11,007
3,669
515,210
316,698
132
298,688
320,420
69,713
70,128
412,133
33,237
7,699,450
54,652
7,338
3-118
-------
TABLE 3-27. NATIONAL HAZARDOUS PRIORITY CONSTITUENT LOADINGS
TO POTW INFLUENT (Continued)
Organic
Compounds (Continued)
1,2-Dichloropropane
01 ethyl phthalate
2 ,4-Di methyl phenol
Dimethyl phthalate
Di-n-octyl phthalate
Ethyl benzene
Hexachlorobutadlene
Hexachloroethane
Methyl ene chloride
Naphthalene
Nitrobenzene
N-nitrosodlmethylamlne
PCB
Pentachlorophenol
Phenol
1,1,2,2-Tetachloroethane
Tet rachl oroethyl ene
Toluene
Trans-1 ,2-di chl oroethyl ene
Tribromomethane
1,2,4-Trichlorobenzene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
Trichlorofluoromethane
2,4,6-Trichlorophenol
Vinyl chloride
other organics
(excl . pesticides)
40 POTW
Influent
Frequency of
Detection
(%)
7
53
10
11
7
80
0
1
92
49
0
0
1
29
79
7
95
96
62
2
10
85
7
90
9
5
6
National Influent
Loadings Based on
40 POTW
Data
(kg/yr)
772,750
125,111
25,758
33,117
62,555
1,162,805
0
11,039
8,846,151
298,060
0
0
11,039
250,224
2,557,435
44,157
6,774,444
10,391,651
165,569
3,679
316,459
12,356,645
55,196
3,131,478
69,915
3,679
342,218
147,190
National Influent
Loadings Based
on 39 POTW
DataPOTW #28
Added separately
Total
71,525,981
50,455
121,628
25,758
33,171
62,524
963,386
0
11,106
7,936,673
294,574
0
0
11,007
249,997
1,247,983
44,161
2,569,279
3,232,279
155,297
3,768
330,220
2,503,328
48,246
2,224,112
11,270
7,338
331,862
111,218
35,001,647
3-119
-------
variation in loadings of organics, both priority and nonpriority, to indivi-
dual POTWs throughout the Nation. Due to the highly site-specific nature of
organics discharges to POTWs, the 40 POTW study cannot fully account for
organics loadings to all POTWs.
As indicated in Table 3-27* a Scale-up of 40 POTW data shows National
POTW influent loading of approximately 29 million kilograms per year of
hazardous metals and cyanide. The most frequently detected hazardous
inoryanic pollutants include cyanide (100 percent), chromium (95 percent),
nickel (79 percent), silver (71 percent) and mercury (70 percent). Based on
mass loadings to POTWs, the five largest loadings of hazardous inorganic
pollutants are cyanide (15,120,147) kg/yr), chromium (5,151,668 kg/yr), lead
(4,386,278 kg/yr), nickel (3,013,726 kg/yr), and cadmium (636,599 kg/yr).
A scale-up of 40 POTW sampling data, excluding the POTW receiving high
volumes of organic waste, shows POTW influent loadings of approximately 35 mil-
lion kilograms per year of organic priority hazardous constituents. The most
frequently detected organics include toluene (96 percent), tetrachloroethylene
(95 percent), methylene chloride (92 percent), bis(2-ethyl hexyl) phthalate
(92 percent), chloroform (91 percent), trichloroethylene (90 percent), 1,1,1-
trichloroethane (85 percent), ethyl benzene (80 percent), phenol (79 percent),
and di-n-butyl phthalate (64 percent). Based on mass loadings, the 10 highest
hazardous priority organics are methylene chloride (7,936,673 kg/yr), 1,2-
dichloroethane (7,699,450 kg/yr), toluene (3,232,279 kg/yr), tetrachloro-
ethylene (2,569,279 kg/yr), 1,1,1-trichloroethane (2,503,328 kg/yr), trichloro-
ethylene (2,224,112 kg/yr), bis(2-ethyl hexyl) phthalate (1,712,750 kg/yr),
phenol (1,247,983 kg/yr), ethyl benzene (963,386 kg/yr), and chloroform
(515,210 kg/yr). Analysis of POTW influent data collected as part of the DSS
study supports these results. Most of the organic compounds cited above,
including phenol (389 detections), methylene chloride (241 detections), tetra-
chloroethylene (201 detections), toluene (192 detections), bis(2-ethyl hexyl)
phthalate (167 detections), chloroform (166 detections), ethyl benzene (132
detections), 1,1,1-trichloroethane (118 detections) and trichloroethylene (108
detections), are among the compounds most frequently detected by more recent
POTW sampling efforts. Both the 40 POTW and DSS sampling data show clearly
3-120
-------
the substantial loadings of common industrial solvents, particularly the
chlorinated solvents and plasticizers.
3.5.2 Estimates of National POTW Loadings of Selected Nonpriority Organic
Hazardous Constituents
Evaluation of 40 POTW, OSS, and Paragraph 4{c) plant influent data
indicate the prevalence of commonly used solvents and plasticizers (e.g.,
tetrachloroethylene, methylene chloride, bis(2-ethyl hexyl) phthalate, etc.).
These data suggest a possible correlation between production/use rates for
specific compounds and their loadings to POTW influents. Regression analysis
can be used to establish a statistical correlation between end use and
influent loadings for hazardous organic priority constituents, and then to
project loadings for selected nonpriority hazardous constituents.
In evaluating the correlation between use and discharge rates, two broad
use types, "intermediate use" and "end use," were established. Intermediate
use was defined to encompass use as a chemical intermediate in the organics
industries, including the organic chemicals, dye manufacture, and pesticides
industries. Together with discharges relating to actual production of a
compound, this distinction delimits a set of several hundred possible indus-
trial sources, including plants that produce the chemical, utilize the
chemical as an intermediate in a production process, or generate the compound
as a by-product. In many instances, a compound (e.g., vinyl chloride, acro-
lein, 1,2-dichloroethane, etc.) may be discharged in substantial quantities by
a limited number of industrial sources. Based on this supposition, one would
not expect to find any correlation between production or intermediate use and
POTW influent loadings for compounds that are used predominantly as chemical
intermediates.
By contrast, end use was defined to include a variety of uses by all
other industries, such as electroplaters, equipment manufacturers, laundries,
wood refinishers, pharmaceutical manufacturers, etc. This definition was
intended to encompass more widespread use of a compound as a solvent,
degreaser, dry cleaning agent, plasticizer, disinfectant, or similar use by a
large number of industrial operations. In these instances, thousands or even
3-121
-------
tens of thousands of industrial sources can potentially discharge the compound
to POTWs. Accordingly, one would expect a marked correlation between end use
rates and loadings of these compounds to POTWs,
Due to the need to collect detailed production and use data for specific
compounds, the analysis was limited to 40 organic hazardous constituents,
including OSS Tier 1 organic constituents (i.e., F-code solvents) and selected
DSS Tier 2 organic constituents frequently detected in POTW influents or
believed to be widely used as industrial solvents. Data on production and use
of these compounds were derived primarily from Stanford Research Institute's
Chemical Economic Handbook (CEH) which, after review of numerous data sources,
was determined to be the most comprehensive, up-to-date source of production/
use information.
(10)
Because use data were not always sufficiently disag-
gregated by use type, project researchers utilized best professional judgment
to apportion total use between intermediate and end use. Production/use data
represent estimates for the year 1981, or, lacking these data, for the next
closest year, corresponding to the sampling period (1979-1981) for the 40 POTW
study. Accordingly, production/use values used for the analysis are not
necessarily representative of current production/use values. Table 3-28
provides a summary of all production/use data utilized in the regression
analysis.
POTW influent loadings for specific compounds are derived from 40 POTW
plant sampling data. Regression analysis therefore focused exclusively on the
selected organic priority constituents. Again, for the purpose of evaluating
the correlation between influent loadings and end use, it was necessary to
consider the possible effects of statistical outliers for organics discharges
on National influent loadings. As a result, where organics data could
reasonably be attributed to discharge from organics industries, the data were
excluded for purposes of calculating flow-weighted hazardous constituent
concentration averages used to project National loadings. This procedure
resulted in the exclusion of organics data for one POTW (POTW #28) and a data
point for 1,2-dichloroethane at another POTW (POTW #30). Constituent loadings
used in the analysis are also summarized in Table 3-28.
3-122
-------
TABLE 3-28. USE AND INFLUENT LOADINGS DATA FOR SELECTED HAZARDOUS ORGANIC CONSTITUENTS
CO
I
ro
CJ
Organic Constituent
Toluene
1,1,1-Trichloroethane
Tetrachloroethylene
Xylene
Methyl ethyl ketone
Methylene chloride
Acetone
2-Ethyl hexyl phthalate
Phenols, phenolic resins
Di chlorod i f i uoromethane
Ethyl acetate
Tr i chloroethylene
Methanol
Butanol
Trichlorotrifluoroethane
Methyl i sobutyl ketone
Ethyl benzene
Butyl benzyl phthalate
Cresol
Carbon tetrachloride
Isobutanol
Formaldehyde
Carbon disulfrde
1,4-Di chlorobenzene
Chlororaethane
Chlorobenzene
Benzene
Diethyl phthalate
Dtbutyl phthalate
.Chloroform
Tr i chlorof1uoroetbane
Ethyl ether
Analine
1,2-Oi chlorobenzene
Nitrobenzene
Naphthalene
Dimethyl phthalate
1,2-Di chloroethane
Pyridine
Vinyl chloride
Dichloropropane
Production
Rate (kkg/yr)
4,652,550
279,450
326,250
3,012,750
210,600
266,400
964,800
115,650
1,062,000
225,000
105,750
99,000
2,639,250
355,950
59,090
67,500
2,995,200
31,500
61,650
327,150
56,700
953,100
174,600
32,850
211,363
106,650
3,496,500
7,650
8,100
182,250
74,090
5,400
285,300
20,700
405,900
160,200
2,260
5,670,900
6,750
3,150,000
360
Intermediate
Use Rate
(kkg/yr)
4,163,400
119,250
83,250
3,021,300
0
42,750
607,050
0
965,050
0
965,250
15,750
10,090
2,639,250
246,150
9,090
6,750
2,965,500
0
28,350
259,200
51,750
938,250
161,100
9,900
194,545
103,050
0
0
157,500
77,273
900
282,600
17,550
404,100
194,400
0
5,670,900
6,300
3,195,000
360
End Use Rate
(kkg/yr)
597,150
274,950
243,000
233,100
199,350
192,600
127,800
126,000
96,850
90,000
90,000
85,500
62,500
54,600
54,545
53,550
41,400
33,750
33,300
24,300
15,750
14,850
13,500
12,150
9,000
9,000
9,000
9,000
8,100
6,750
5,455
3,150
2,700
2,700
2,250
2,250
2,250
900
315
360
0
Frequency of
Detection 40
POTW (%)
96
85
95
--
92
92
79
2
90
80
57
9
17
11
13
61
53
64
91
9
23
49
11
6
7
National
Influent
Average.
Loading
(fcfcg/yr)
3,232
2,503
2,569
7,937
1,713
1,238
412
2,224
963
345
278
--
70
316
136
354
122
299
515
52
320
0
295
33
1
2
Loadings are projected from 40 POTW flow-weighted pollutant concentrations,
excluding oryanics data for POTW #28 and the 1,2-dichloroethane data point
for POTW #30 (considered an outlier in the data set).
-------
As anticipated, regression analysis demonstrated the absence of
any statistical correlation between production or intermediate use and
POTW influent loadings of the priority organics. This result was expected
since the discharge of many organic compounds (e.g., vinyl chloride,
1,2-dichloroethane) probably was associated with a limited number of possible
industrial sources whose significance was likely to be either overrepresented
or underrepresented by a limited POTW sample size (i.e., in this instance, 40
POTWs).
The regression analysis did demonstrate a marked correlation between end
use of specific compounds and their discharge to POTWs. Figure 3-5 provides a
scatter plot that illustrates this correlation between end use and POTW
influent loadings. A linear regression procedure established the following
relationship between end use and POTW influent loadings:
Y = 458 + .007 X
(R2 = .28)
where, Y = POTW influent loadings (kkg/yr)
X = End use (kkg/yr)
This equation has a correlation coefficient of 0.53, while the end use
coefficient has a t value of 3.07, indicating statistical significance at a
95 percent confidence level. This relationship indicates that approximately
0.7 of 1 percent of the quantity of a compound that finds end use ultimately
will be discharged to a POTW. Even with the inclusion of organics data for
POTW #28 and POTW #30, there is still a significant correlation between end
use rates and influent loadings, although projected loadings rates are
markedly higher {i.e., 1.9 percent of all end use). Due to data constraints,
the analysis did not consider other factors, such as treatment, incorporation
into final products, and volatility in collection systems, which also may be
statistically significant in predicting POTW influent loadings of these
compounds.
Based on the above analysis, Table 3-29 projects National POTW influent
loadings, attributable solely to end use, for selected nonpriority hazardous
constituents. These loadings do not account for loadings stemming from
3-124
-------
CO
i
ro
en
CORRELATION BETWEEN INDUSTRIAL END USE AND
AVERAGE NATIONAL POTW INFUJENT UOADINGS
1000OO
200000 30000O 400000
EJnd Use (metric tons/yaor)
sooooo
ftOOOOO
FIGURE 3-5
-------
TABLE 3-29. PROJECTED INFLUENT LOADINGS FOR SELECTED
NONPRIORITY ORGANIC HAZARDOUS CONSTITUENTS
Hazardous Constituent
Xylenes
Methyl ethyl ketone
Acetone
Ethyl acetate
Methanol
Butanol
Trichl orotri fl uoroethane
Methyl isobutyl ketone
Cresol
Isobutanol
Formaldehyde
Carbon disulfide
Ethyl ether
Aniline
Pyridine
End Use
(kkg/yr)
233,100
199,350
127,800,
90,000
65,250
54,000
54,000
53,550
33,300
15,750
14,850
13,500
3,150
2,700
315
Projected Influent Loadings1
(kkg/yr)
1,678
1,435
920
648
470
389
389
386
240
113
107
97
23
19
2
This table estimates POTW influent loadings attributable solely to
end use by nonorganics industries. As indicated in Section 3.2
and in the discussion of the 40 POTW study results, organics
industries may discharge substantial additional quantities of
these same compounds (e.g., xylene, acetone, formaldehyde, etc.).
3-126
-------
production or intermediate use by the organics industries. These projections
indicate that nonpriority hazardous constituents, such as xylene, methyl ethyl
ketone, acetone, ethyl acetate, and methanol, may be present in significant
quantities in POTW influent wastewaters. These conclusions are supported by
limited POTW sampling data collected for both the Paragraph 4(c) program and
for this study. Table 3-30 provides a summary of the organic hazardous
constituents, both priority and nonpriority, most frequently detected in the
Paragraph 4(c) sampling program. Many of the compounds appearing on this list
are the same compounds that are projected to occur in significant quantities
in POTW influents Nationally. Moreover, DSS POTW sampling data demonstrate
the presence, in significant concentrations, of these compounds in POTW
influents, including xylene, cresol, methyl ethyl ketone, methyl isobutyl
ketone, acetone, acetophenone, and aniline.
3,5.3 Production/Use Profiles for Selected Hazardous Organic Constituents
This portion of Section 3.5 provides production/use profiles for selected
hazardous organic constituents known or believed to be common in POTW influent
wastewaters. Each profile contains a summary of pertinent numerical data for
the compound, a narrative description of significant intermediate and end use
of the compound, and a listing of the industrial categories (nonorganic indus-
tries only) that have been identified as major end users of the chemical. End
use data were derived from the SRI Chemical Economic Handbook/ ' The list-
ing of industrial categories does not consider intermediate use by the organics
industries (i.e., organic chemicals, dye manufacture, and pesticides); most of
the compounds discussed below find substantial use in these industries.
Acetone
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 920 kkg/yr
Production Rate: 964,800 kkg/yr
Intermediate Use Rate: 607,050 kkg/yr
End Use Rate: 127,800 kkg/yr
3-127
-------
TABLE 3-30. OCCURRENCE OF HAZARDOUS ORGANIC CONSTITUENTS AT POTHS
BASED ON PARAGRAPH 4(c) SAMPLING DATA
Hazardous Organic Constituent
Tetrachloroethylene*
Cresol
Methylene Chloride*
Trichloroethylene*
Benzene*
Xyl ene
Toluene*
Chloroform*
Ethyl Benzene*
1,1,1-Trichloroethane*
Phenol*
Bis(2-Ethyl HexylJPhthalate*
Napthalene*
1,1-Dichloroethylene*
Diethyl Phthalate*
Acetone
Methyl Isobutyl Ketone
Di-N-Butyl Phthalate*
Di-N-Octyl Phthalate*
2,4-Dimethyl Phenol*
1,2-Dichlorobenzene*
Trans-l,2-Dichl oroethylene*
1,3-Dichlorobenzene*
1,4-Dichlorobenzene*
An i1i ne
PCB*
Methyl Ethyl Ketone
Butyl Benzyl Phthalate*
Acetophenone
Cyclohexane
Carbon Disulfide
2-Picoline
1,1-Dichloroethane*
Pentachlorophenol*
2,4,6-Trichlorophenol*
1,2,4-Trichlorobenzene*
Chlorobenzene*
Pyridine
Ethyl Ether
1,2-Dichloropropane*
Ethyl Acetate
Trichlorofluoromethane*
1,1,2-Trichloroethane*
Cyclohexanone
1,4-Dioxane
*0enotes CWA priority pollutant.
Source: Reference (6)
Number of Detections
226
169
157
123
114
112
111
107
93
90
80
46
41
39
35
33
30
28
26
24
17
16
14
13
12
11
10
10
7
7
6
6
4
4
4
4
3
3
2
2
2
1
1
1
1
3-128
-------
Acetone Is an Intermediate in the production of methyacrylic acids and
esters, methyl isobutyl ketone, bisphenol A, methyl isobutyl carbinol, aldol
chemicals, and certain drugs and Pharmaceuticals. It also is used as a
solvent for surface coatings, adhesives, printing inks, and paper coatings.
The synthetic fibers industry uses acetone as a spinning solvent in the
manufacture of cellulose acetate fiber. Other uses for acetone include using
the chemical as a solvent for acetylene, cellulose acetate sheeting, smokeless
powder, cements, and artificial leather, and as an extraction solvent in the
dewaxing of lubricating oils. The electronics industry uses acetone to clean
and dry printed circuits. Key industrial categories for end use include:
Pharmaceuticals
Paint
Electronics
Plastics forming
Printing/publishing
Ink
Equipment manufacturing
Wood refinishing
Electroplating.
Aniline
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 19 kkg/yr
Production Rate: 285,300 kkg/yr
Intermediate Use Rate: 282,600 kkg/yr
End Use Rate: 2,700 kkg/yr
Aniline is used primarily as a chemical intermediate. The chemicals
that are produced from this compound include MDI, various rubber-processing
chemicals, agricultural chemicals, hydroquinone, dyes, and Pharmaceuticals.
Other miscellaneous uses are as raw material for sodium and calcium
N-cyclohexanesulfomates, as an analytical reagent and corrosion inhibitor, and
3-129
-------
in photographic chemicals and specialty resins and fibers. Key industrial
categories for end use include:
Pharmaceuticals
Photographic chemicals.
Benzene
40 POTW Influent Frequency of Detection: 61 percent
Projected National Loadings to POTW Influent: 354 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 3,496,500 kkg/yr
Intermediate Use Rate: 5,008,500 kkg/yr
End Use Rate: 9,000 kkg/yr
Almost all of the domestic consumption of benzene can be accounted for by
the production of ethyl benzene, cumene, cyclohexane, nitrobenzene, detergent
alkylate, chlorobenzenes, and maleic anhydride. Other smaller intermediate
uses include the production of benzene hexachloride, benzene sulfonic acid,
biphenyl , hydroquinone, and resorcinol. Benzene has many small-volume markets
as a solvent, but has no major solvent application. As an aromatic, benzene
is a significant constituent of petroleum products such as stoddard solvent,
kerosene, naphtha, etc. Key industrial categories for end use include:
Laundries
Paint
t Equipment manufacturing
Motor vehicle services
t Pharmaceuticals
Transportation.
Bis(2-etnylhexyl) Phthalate
40 POTW Influent Frequency of Detection: 92 percent
Projected National Loadings to POTW Influent; 1,713 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 115,650 kkg/yr
Intermediate Use Rate: 0 kkg/yr
End Use Rate: 126,000 kkg/yr
3-130
-------
6is(2-ethylhexyl) phthalate is used most widely as a PVC plasticizer,
primarily in the production of calandered film, sheeting, and coated fabrics
It also has applications with polyvinylidene chloride synthetic elastomers,
and is used as a carrier and dispersing medium for other substances, such as
catalysts and intiators, pesticides, cosmetics, and colorants. High-purity
di(2-ethylhexyl)phthalate also is being used to replace PCBs as capacitor
fluid. Key industrial categories for end use include:
Plastics forming
t Paint
Equipment manufacturing
t Electronics,
Butanol
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 389 kkg/yr
Production Rate: 355,950 kkg/yr
Intermediate Use Rate: 246,150 kkg/yr
End Use Rate: 54,000 kkg/yr
Butanol is a solvent in paints and other surface coatings, and a
processing and formulating solvent for Pharmaceuticals, waxes, and other
resins. As an intermediate, it is used to manufacture butyl acrylate/
methacrylate, glycol ethers, butyl acetate, plasticizers, amino resins, and
butyl amine. It also is used as a cosolvent in tertiary oil recovery. Key
industrial categories for end use include:
Paint
Pharmaceuticals.
Butyl Benzyl Phthalate
40 POTW Influent Frequency of Detection: 57 percent
Projected National Loadings to POTW Influent: 345 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
3-131
-------
Production Rate: 31,500 kkg/yr
Intermediate Use Rate: 0 kkg/yr
End Use Rate; 33,750 kkg/yr
Butyl benzyl phthalate is a plasticizer used primarily for PVC flooring,
often with bis(2-ethyl hexyl} phthalate. It also is used in polyvinyl acetate
emulsions. Key industrial categories for end use include:
Plastics forming
Paint
Equipment manufacturing.
Carbon Disulfide
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 97 kkg/yr
Production Rate: 174,600 kkg/yr
Intermediate Use Rate: 161,100 kkg/yr
End Use Rate: 13,500 kkg/yr
The primary use of carbon disulfide is to manufacture rayon and
ceUoplane from regenerated cellulose and to synthesize carbon tetrachloride.
Carbon disulfide also functions as a rubber accelerator and a flotation agent,
and is used in the manufacture of pesticides and thiocyanates. There are no
key industrial categories for end use.
Carbon Tetrachloride
40 POTW Influent Frequency of Detection: 9 percent
Projected National Loadings to POTW Influent: 278 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 327,150 kkg/yr
Intermediate Use Rate: 259,200 kkg/yr
End Use Rate: 24,300 kkg/yr
3-132
-------
Carbon tetrachloHde serves as an Intermediate in the production of
fluorocarbons and various other organic compounds. It is used as a solvent
for metal degreasing, and for oils, fats, lacquers, varnishes, rubber com-
pounds, waxes, and resins. It has several uses in veterinary medicine and as
a pesticide. Other uses are as an extractant and as a drying agent for spark
plugs. Key industrial categories for end use include:
Laundries
Food processing
Equipment manufacturing
Pharmaceuticals
Paint.
Chlorobenzene
40 POTW Influent Frequency of Detection: 13 percent
Projected National Loadings to POTW Influent: 136 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 106,650 kkg/yr
Intermediate Use Rate: 103,050 kkg/yr
End Use Rate: 9,000 kkg/yr
Chlorobenzene (monochlorobenzene) is used most widely as a solvent in the
formulation of various insecticides and herbicides as well as MDI and TDI
(Toluene diisocyanate). It also is widely used as a degreaser for automobile
parts. Intermediate uses include the manufacture of nitrochlorobenzene,
diphenyl oxide, phenol, o- and p-phenylphenol, aniline, and silicon resin
producers. Key industrial categories for end use include:
Motor vehicle services <
Transportation
Pharmaceuticals.
Chloroform
40 POTW Influent Frequency of Detection: 91 percent
Projected National Loadings to POTW Influent: 515 kkg/yr
3-133
-------
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 182,250 kkg/yr
Intermediate Use Rate: 157,500 kky/yr
End Use Rate: 6,750 kkg/yr
Ninety percent of the chloroform consumption is used to manufacture
chlorodifluoromethane. Other applications include use as a solvent for
Pharmaceuticals, as a soil fumigant, as an extraction solvent for essential
oils, and use by the tobacco industry to prevent the mildewing of seedings.
Key industrial categories for end use include:
t Pharmaceuticals
t Hospitals.
Chloromethane
40 POTW Influent Frequency of Detection: 11 percent
Projected National Loadings to POTW Influent: 316
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 211,363 kkg/yr
Intermediate Use Rate: 194,545 kkg/yr
End Use Rate: 9,000 kkg/yr
Chloromethane is used to manufacture methyl cellulose, quaternary
ammonium compounds, triptane, 2,2,3-trimethyl butane, methyl mercaptan, and
various pesticides. Its primary use, however, is as an intermediate for
methylene chloride, chloroform, methylchlorosilanes, and trimethyl lead. It
is also a solvent for polymeration catalysts used to make butyl rubbers.
There are no key industrial categories for end use.
Cresols
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 240 kkg/yr
Production Rate: 61,650 kkg/yr
Intermediate Use Rate: 28,350 kkg/yr
End Use Rate: 33,300 kkg/yr
3-134
-------
Cresols include both mixed cresols and p-, o-, and m-cresol isomers.
These compounds are used primarily as intermediates in the production of
antioxidants such as 2,6-di-tert-butyl-p-cresol (BHT), salicylaldehyde,
specialty resins, herbicides, insecticides, Pharmaceuticals, and phosphate
esters. They also function as wire enamel solvents, ore flotation frothers,
disinfectants, fiber treatments, tanning agents, and metal degreasings agents.
Key industrial categories for end use include:
Electroplating
Equipment manufacturing
Textiles
Leather tanning
Wood refinishing
Hospitals
Pharmaceuticals
Transportation.
Di-N-Butyl Phthalate
40 POTW Influent Frequency of Detection: 64 percent
Projected National Loadings to POTW Influent: 299 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 8,100 kkg/yr
Intermediate Use Rate: 0 kkg/yr
End Use Rate: 8,100 kkg/yr
Dibutyl phthalate, also a plasticizer, is used primarily with adhesive
emulsions and, to some extent, plastisols for carpet backcoating. Key
industrial categories for end use include:
Plastics forming
Adhesives
Paint
Equipment manufacturing.
3-135
-------
1.2-Dichlorobenzene
40 POTW Influent Frequency of Detection: 23 percent
Projected National Loadings to POTW Influent: 320 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production .Rate: 20,700 kkg/yr
Intermediate Use Rate: 17,550 kkg/yr
End Use Rate: 2,700 kkg/yr
1,2-dichlorobenzene has its largest use in the production of various
organic chemicals, primarily 3,4-dichloroaniline. It also is used as a
process solvent in toluene diisocyanate production and as a solvent for paint
removers, engine cleaners, and deinking processes. 1,2-dichlorobenzene has
some use in dye manufacturing. Key industrial categories for end use include:
Wood finishing
Equipment manufacturing
Printing/publishing
Motor vehicle services.
Dichlorodi fl uoromethane
40 POTW Influent Frequency of Detection: 2 percent
Projected National Loadings to POTW Influent: 412 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 225,000 kkg/yr
Intermediate Use Rate: 22,500 kkg/yr
End Use Rate: 90,000 kkg/yr
Dichlorodifluoromethane is a fluorocarbon that is used most often as a
coolant in refrigeration units and as a blowing agent in manufacturing
flexible and rigid polyurethane foams. Smaller amounts function as chemical
intermediates and are used to sterilize surgical and pharmaceutical equipment.
It also may be used for food freezing and as a component of fire extinguishers.
Key industrial categories for end use include:
3-136
-------
Service-related industries
Plastics forming
Hospitals,
1,2-Dichloroethane
40 POTW Influent Frequency of Detection: 15 percent
Projected National Loadings to POTW Influent; 7,699 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 5,670,900 kkg/yr
Intermediate Use Rate: 5,670,900 kkg/yr
End Use Rate: 900 kkg/yr
1,2-dichloroethane is a major intermediate in the production of vinyl
chloride. An extremely small amount is used as a solvent for vinyl chloride,
in surface coatings, as a degreasing solvent, as a wetting and penetrating
agent, and as a lead scavenger in gasoline. Key industrial categories for end
use include:
Paint
Equipment manufacturing
t Motor vehicle services
Textiles.
1,4-Dichlorobenzene
40 POTW Influent Frequency of Detection: 17 percent
Projected National Loadings to POTW Influent: 70 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 32,850 kkg/yr
Intermediate Use Rate: 9,900 kkg/yr
End Use Rate: 12,150 kkg/yr
1,4-dichlorobenzene is used primarily in room deodorant blocks. It also
is used in moth control chemicals and to manufacture polyphenylene sulfide
resins. There are no key industrial categories for end use.
3-137
-------
Pi ethyl Phthalate
40 POTW Influent Frequency of Detection: 53 percent
Projected National Loadings to POTW Influent: 122 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 7,650 kkg/yr
Intermediate Use Rate: 0 kkg/yr
End Use Rate: 9,000 kkg/yr
Diethyl phthalate is a plasticizer that is used almost entirely with
cellulose ester plastics. Only a small amount is used with polyurethane
casting compounds. Key industrial categories for end use include:
Plastics forming
Paint
Equipment manufacturing.
Dimethyl Phthalate
40 POTW Influent Frequency of Detection: 11 percent
Projected National Loadings to POTW Influent: 33 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 2,250 kkg/yr
Intermediate Use Rate: 0 kkg/yr
End Use Rate: 2,250 kkg/yr
Dimethyl phthalate, like diethyl phthalate, is a plasticizer used almost
exclusively for cellulose ester plastics. It has few other uses. Key
industrial categories for end use include:
Plastics forming
Paint
Equipment manufacturing.
3-138
-------
Ethyl Acetate
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 648 kkg/yr
Production Rate: 105,750 kkg/yr
Intermediate Use Rate: 15,750 kkg/yr
End Use Rate: 90,000 kkg/yr
Most of ethyl acetate's use occurs in the surface coatings, plastics, and
printing industries where it is used as a solvent for cellosics and shellacs,
synthetic rubber and vinyl resins, and printing inks. Only a small portion of
the total ethyl acetate production is used for chemical synthesis. Key
industrial categories for end use include:
Paint
Ink
Printing/publishing
Plastics forming.
Ethyl Benzene
40 POTW Influent Frequency of Detection: 80 percent
Projected National Loadings to POTW Influent: 963 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 2,995,200 kkg/yr
Intermediate Use Rate: 2,965,500 kkg/yr
End Use Rate: 41,400 kkg/yr
Ninety-nine percent of all ethyl benzene is used to make styrene. Most
of the remaining 1 percent is used as a solvent, although some may be used to
produce diethyl benzene, acetophenone, and ethyl anthroquinone. Ethyl benzene
is a significant (i.e., 3-5 percent) constituent of mixed xylene solvents.
Key industrial categories for end use include:
Laundries
Paint
3-139
-------
Equipment manufacturing
Motor vehicle services
Pharmaceuticals
Transportation.
Ethyl Ether
40 POTW Influent Frequency of Detection:
N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 23 kkg/yr
Production Rate: 5,400 kkg/yr
Intermediate Use Rate: 900 kkg/yr
End Use Rate: 3,150 kkg/yr
The largest use of ethyl ether is as a solvent in the production of
smokeless powder. Smaller amounts are used as chemical intermediates, as a
general anesthetic, and other medicinal uses. Miscellaneous uses include its
use as a denaturant for ethyl alcohol. Key industrial categories for end use
include:
Pharmaceuticals
Hospitals.
Formaldehyde
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 107 kkg/yr
Production Rate: 953,100 kkg/yr
Intermediate Use Rate: 938,250 kkg/yr
End Use Rate: 14,850 kkg/yr
Formaldehyde is an intermediate in manufacturing urea-formaldehyde
resins, phenolic resins, acetylenic chemicals, polyacetyl resins, penta-
enrythritol, hexamethylene tetramine, melamine resins, trimethylolethane,
nitroparaffin, pyridine chemicals, trimethylolpropane, chelating agents,
4,4-methylene bis(phenyl isocyanate) (MDI), dyes, drilling mud additives, and
3-140
-------
rubber processing chemicals. The textile industry uses formaldehyde in
various textile-treating applications. It also is used in small amounts as a
preservative. Key industrial categories for end use include:
Textiles
Service-related industries
Pharmaceuticals
Pulp/paper
Photographic chemicals
Wood refinishing.
Isobutanol
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 113 kkg/yr
Production Rate: 56,700 kkg/yr
Intermediate Use Rate: 51,750 kkg/yr
End Use Rate: 15,750 kkg/yr
Isobutanol often replaces butanol in surface coatings. The pharma-
ceutical and pesticide industries also use it as a processing solvent. As an
intermediate, it is used in manufacturing isobutyl amine, lube oil additives,
isobutyl acetate, gasoline octane improvers, isobutyl acrylate and
methacrylate, and ami no resins. Key industrial categories for end use
include:
Paint
Pharmaceuticals
Photographic chemicals.
Methanol
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 470 kkg/yr
Production Rate: 3,212,550 kkg/yr
3-141
-------
Intermediate Use Rate: 2,639,250 kkg/yr
End Use Rate: 65,250 kkg/yr
The primary end uses of methanol are as a fuel, as a solvent in automatic
chemicals such as windshield washer solvent and surface coatings, and as an
antifreeze. It is used as an intermediate in the production of formaldehyde,
acetic acid, chloromethanes, methyl tertiary butyl ether, dimethyl terephtha-
late, methylmethacrylate, methylamines, glycolmethyl ethers, and as a
inhibitor of formaldehyde. Key industrial categories for end use include:
Motor vehicle services
Wood refinishing
Paint
Pharmaceuticals
Equipment manufacturing
Transportation.
Methylene Chloride
40 POTW Influent Frequency of Detection: 92 percent
Projected National Loadings to POTW Influent: 7,937 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 266,400 kkg/yr
Intermediate Use Rate: 42,750 kkg/yr
End Use Rate: 192,600 kkg/yr
Methylene chloride has no major chemical market as an intermediate, and
is used primarily as a solvent for paint removers, in vapor degreasing
operations, as an aerosol propel 1 ants, and as a blowing agent for urethane
foams. Other uses are in the processing of plastics and film; as a solvent in
numerous pharmaceutical applications; in the extraction of naturally occurring
heat-sensitive substances, caffeine from coffee, and beer flavoring from hops;
in the manufacture of photographic fiber and synthetic fiber; and as a
component of fire-extinguishing compounds. Key industrial categories for end
use include:
3-142
-------
Wood refinlshing
Equipment manufacturing
Electroplating
Motor vehicle services
t Transportation
Photographic chemicals
Pharmaceuticals
t Food processing.
Methyl Ethyl Ketone
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 1,435 kkg/yr
Production Rate: 210,600 kkg/yr
Intermediate Use Rate: 0
End Use Rate: 199,350 kkg/yr
Methyl ethyl ketone is used as a solvent, primarily for surface coatings,
but also for printing inks and magnetic tapes and as an extraction solvent for
lube oil dewaxing and hardwood pulping. Key industrial categories for end use
include:
Paint
Ink
Electronics
Pri nti ng/publ i shi ng
Pulp/paper
Adhesives
Pharmaceuticals
Equipment manufacturing.
Methyl Isobutyl Ketone (MlbK)
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 386 kkg/yr
3-143
-------
Production Rate: 67,500 kkg/yr
Intermediate Use Rate: 6,750 kkg/yr
End Use Rate: 53,550 kkg/yr
Methyl Isobutyl ketone 1s used as a solvent for nitrocellulose lacquers
and coating resins, such as vinyl polymer and copolymer and acrylic resins.
Other solvent uses are In the extraction of rare metals, agricultural Insec-
ticides, adheslves, and dewaxing mineral and tall oil. MlbK also is used as a
raw material for antioxidants such as N-(l,3,-dimethyl butyl }-N-phenyl
paraphenylene diamine, and 1s used extensively in the pharmaceutical Industry
as a solvent. Key industrial categories for end use include:
Paint
t Adhesives
0 Pharmaceuticals
Equipment manufacturing.
Naphthalene
40 POTW Influent Frequency of Detection: 49 percent
Projected National Loadings to POTW Influent; 295 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 160,200 kkg/yr
Intermediate Use Rate: 194,400 kkg/yr
End Use Rate: 2,250 kkg/yr
Naphthalene is used primarily as a chemical Intermediate. Phthalic
anhydride production uses the largest amount of naphthalene, followed by the
production of carbaryl, betanapthol, surface-active agents, tanning agents
(syntans), and moth repellant. Miscellaneous uses include its use as an
intermediate for dyes, a stabilizer for rubber chemicals, and as a solvent for
various oils, resins, and waxes. It also may be used as an intermediate for
asphalt components and stabilizers. Key industrial categories for end use
include:
3-144
-------
Motor vehicle services
Laundries
Equipment manufacturing
t Transportation,
Nitrobenzene
40 POTW Influent Frequency of Detection: 0 percent
Projected National Loadings to POTW Influent: 0 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 405,900 kkg/yr
Intermediate Use Rate: 404,100 kkg/yr
End Use Rate: 2,250 kkg/yr
Ninety-eight percent of all nitrobenzene is used to produce aniline. The
remainder is used to produce N-acetyl-para-amino-phenol (APAP), as a dye
intermediate, as a solvent for cellulose ether, and as a selective solvent in
the petroleum industry. There are no key industrial categories for end use.
Phenol
40 POTW Influent Frequency of Detection: 79 percent
Projected National Loadings to POTW Influent: 1,238 kkg/yr
Projected POTW Influent Loadings due to End use: N/A
Production Rate: 1,062,000 kkg/yr
Intermediate Use Rate: 965,250 kkg/yr
End Use Rate: 96,850 kkg/yr
Phenol is an intermediate for phenolic resins, epoxy resins, bisphenol A,
caprolactem, xylenols, adipic acid, salicylic acid, monylphenol, and dodecyl-
phenol. It is used as a solvent in petroleum refining, has intermediate uses
in the production of aniline, phosphate esters, and herbicide production, and
has miscellaneous uses in dyes and Pharmaceuticals. It also is used to make
pentachlorophenol (PCP). Key industrial categories for end use include:
Pharmaceuticals
Transportation
3-145
-------
Wood refinishlng
t Equipment manufacturing
Hospitals.
Pyridine
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 2 kkg/yr
Production Rate: 6,750 kkg/yr
Intermediate Use Rate: 6,300 kkg/yr
End Use Rate: 315 kkg/yr
Pyridine functions as a major intermediate in the production of such
agricultural chemials as paraquat and diquat. Other intermediate uses are in
the Pharmaceuticals and cosmetics industries. It also has small solvent uses
in the pharmaceutical and textile industries. Key industrial categories for
end use include:
Pharmaceuticals
Textiles.
Tetrachloroethylene
40 POTW Influent Frequency of Detection: 95 percent
Projected National Loadings to POTW Influent: 2,569 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 326,250 kkg/yr
Intermediate Use Rate: 83,250 kkg/yr
End Use Rate: 243,000 kkg/yr
Tetrachloroethylene, or perchloroethylene, is used primarily as a metal
cleaner and degreaser and as a solvent in dry cleaning and textile processing.
Smaller amounts are used as intermediates in the production of such fluoro-
carbons as trichlorotrifluoroethane, dichlorotetrafluoroethane, chloro-
pentafluoroethane, and hexafluoroethane. Key industrial categories for end
use include:
3-146
-------
Laundries
Uood refinishing
Textiles
Electroplating
Equipment manufacturing
Motor vehicle services
Electronics
Transportation
\
Pharmaceuticals.
Toluene
40 POTW Influent Frequency of Detection: 96 percent
Projected National Loadings to POTW Influent: 3,232 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 4,652,550 kkg/yr
Intermediate Use Rate: 4,163,400 kkg/yr
End Use Rate: 597,150 kkg/yr
Toluene blended back into gasoline is the largest single use for the
chemical. Sixty-five percent of the remaining toluene is used to produce
benzene through hydrodealkylation and 26 percent is used for solvents in
surface coatings, adhesives, inks, and Pharmaceuticals. The remainder is used
to produce toluene diisocyanate, vinyl toluene, cresols, benzaldehyde, toluene
sulfonic acids, toluene sulfonates, benzotrichloride, toluene diamine,
chlorotoluenes, toluene sulfonyl chloride, nitrotoluene, para-tert-butyl
benzoic acid, and is used for disproportionate to benzene and xylenes and as
a denaturant. Trinitrotoluene (TNT) was manufactured from toluene until the
late 1970s, at which time domestic production of TNT ceased. As an aromatic,
toluene is a significant constituent of petroleum products, such as stoddard
solvent, kerosene, naphtha, etc. Key industrial categories for end use
include:
Paint
Adhesives
Ink
3-147
-------
Pharmaceuticals
Laundries
Wood refinishing
Equipment manufacturing
Electroplating
t Motor vehicle services
Transportation.
1,1,1-Trichloroethane
40 POTW Influent Frequency of Detection: 85 percent
Projected National Loadings to POTW Influent: 2,503 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 279,450 kkg/yr
Intermediate Use Rate: 119,250 kkg/yr
End Use Rate: 274,950 kkg/yr
1,1,1-Trichloroethane is used primarily as a metal cleaning solvent,
particularly on electric machinery, plastics, and other items that might be
adversely affected by another solvent. It is also a component of aerosol
formulations, and is used as a chemical intermediate, a solvent in adnesives
and coatings formulations, a coolant and lubricant in cutting oils, an
extraction solvent, a drain cleaner, and a solvent in inks and fabric spotting
fluid. Key industrial categories for end use include:
Electronics
Plastics forming
Paint
Adhesives
Motor vehicle services
Ink
Pharmaceuticals
Electroplating
Equipment manufacturing
Transportation.
3-148
-------
Trichloroethylene
40 POTW Influent Frequency of Detection: 90 percent
Projected National Loadings to POTW Influent: 2,224 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 99,000 kkg/yr
Intermediate Use Rate: 10,800 kkg/yr
End Use Rate: 85,500 kkg/yr
Trichloroethylene, like the other chlorinated solvents 1,1,1-Trichloro-
ethane and tetrachloroethylene, is used primarily as a solvent for metal
cleaning and degreasing. It also is used as a chain terminator in the
production of PVC and to produce chloroacetic acid. Key industrial categories
for end use include:
Equipment manufacturing
Electroplating
t Motor vehicle services
Laundries
Transportation.
Trichlorotrifluoroethane
40 POTW Influent Frequency of Detection: 9 percent
Projected National Loadings to POTW Influent: NA
Projected POTW Influent Loadings due to End Use: 389 kkg/yr
Production Rate: 59,090 kkg/yr
Intermediate Use Rate: 9,090 kkg/yr
End Use Rate: 54,545 kkg/yr
Trichlorotrifluoroethane is a fluorocarbon that is used as a refrigerant
and a blowing agent in the polyurethane, polystyrene, and polyethylene foams.
It also is used heavily as a solvent in the electronics and aerospace indus-
tries for metal degreasing, cleaning semiconductor wafers, printed circuit
boards, and glass, and for plasma etching of printed circuit boards. In
textile processing, it is used for scouring finishing oils, drying yarn and
fabric, drycleaning, and as a chemical reaction medium. As a chemical
3-149
-------
intermediate, it is a precursor to chlorotrifluoroethylene, among others
industrial categories for end use include:
Key
Service-related industries
Electronics
Textiles.
Trichlorofl uoromethane
40 POTW Influent Frequency of Detection: 9 percent
Projected National Loadings to POTW Influent: 52 kkg/yr
Projected POTW Influent Loadings due to End Use: NA
Production Rate: 74,090 kkg/yr
Intermediate Use Rate: 77,230 kkg/yr
End Use Rate: 5,455 kkg/yr
Trichlorofluoromethane has its largest use as a blowing agent for
polyurethane( polystyrene, and polyethylene foams. Other uses are as a
refrigerant and a solvent in the electronics and textile industries. It has
minor uses as a chemical intermediate and sterilization medium. Key
industrial categories for-end use include:
Equipment manufacturing
Electronics
t Electroplating
t Textiles
Service-related industries.
Vin/1 Chloride and 1,2-Dichloropropane
40 POTW Influent Frequency of Detection: 6/7 percent
Projected National Loadings to POTW Influent: 332/50 kkg/yr
Projected POTW Influent Loadings due to End Use: N/A
Production Rate: 3,150,00/360 kkg/yr
Intermediate Use Rate: 3,195,000/360 kkg/yr
End Use Rate: 0/0 kkg/yr
3-150
-------
Vinyl chloride and 1,2-dichloropropane function wholly as chemical inter-
mediates. Most vinyl chloride is used to make polyvinyl chloride, but some
also is used to make vinylidene chloride copolymer, and is used as a comonomer
and an intermediate in the production of certain solvents. Dichloropropane is
an intermediate in the production of certain pesticides. There are no key
industrial categories for end use.
Xylenes
40 POTW Influent Frequency of Detection: N/A
Projected National Loadings to POTW Influent: N/A
Projected POTW Influent Loadings due to End Use: 1,678 kkg/yr
Production Rate: 3,012,750 kkg/yr
Intermediate Use Rate: 3,021,300 kkg/yr
End Use Rate: 233,100 kkg/yr
Xylenes include ortho-xylene, meta-xylene, para-xylene, and mixtures of
the three. Mixed xylenes are a source for individual isomer isolation, but
also are used as solvents and a high-octane component of gasoline. In smaller
amounts they are used as chlorinated plasticizers and as an intermediate in
paints and coatings, adhesives, rubber products, chemical manufacturing, and
agricultural products. The individual xylene isomers are used as chemical
intermediates. As an aromatic, xylenes may be significant constituents of
petroleum products, such as stoddard solvent, naphtha, kerosene, etc. Key
industrial categories for end use include:
t Paint
Adhesives
Laundries
Pharmaceuticals
Motor vehicle services
Electroplating
Equipment
Equipment manufacturing
t Wood refinishing.
3-151
-------
3.6 RESIDENTIAL CONTRIBUTION TO POTW INFLUENT LOADINGS
Previous sections of Chapter 3 have provided estimates of hazardous waste
and constituent loadings to POTWs from nondomestic sources. This section
estimates priority hazardous constituent discharges to POTWs by residential
sources. The analysis demonstrates that residential sources are a small but
significant source of hazardous constituent loadings to POTWs.
The analysis of residential loadings utilizes POTW sampling data from two
EPA/OW studies. As part of the Four City'study, EPA conducted sampling at a
variety of sites, including residential sites, commercial sites, industrial
(31 \
sites, POTW influent, and tap water/ ' Sampling data from both residential
(47 samples) and commercial sites (42 samples) were evaluated in determining
representative constituent concentrations for domestic sources. As part of
the 40 POTW Study,*29' EPA conducted sampling at two POTWs (#2 and #9) that
were known to receive minimal wastewater contributions from industrial
sources. To supplement data provided by the Four City Study, influent
sampling data for these two plants also were incorporated in the analysis.
To project National loadings for domestic sources, representative
pollutant concentrations were scaledup for the portion of National flow that
can be attributed to residential and commercial sources. According to the EPA
NEEDS Survey, 4.4 BSD, or 17 percent, of the total National flow of 26 BGD
represents industrial flow. The remainder, 21.6 BGD in flow, is assumed to be
residential and commercial flow/ '
Table 3-31 estimates National loadings and percent contribution from
domestic sources. To determine percent contribution, domestic loadings are
compared both with projected National POTW influent loadings based on 40 POTW
Study data and with estimates of the POTW industry loadings for selected
consent decree industries presented in Section 3.3 of this chapter. The table
shows projected domestic loadings of 5,563 kkg/yr and 2,633 kkg/yr for
hazardous metals* and priority organics, respectively. When compared with
projected POTW influent loadings, metal and organic loadings from domestic
*For the purposes of this discussion, the term "metals" should be interpreted
to include cyanide.
3-152
-------
TABU 3-31. RESIDENTIAL CONTRIBUTION TO OVERALL POTU
INFLUENT CONSTITUENT LOADINGS
CO
Total
Hazardous Organic
Constituents -
Priority Only
Total Hazardous
Metals (+Cn)
Projected
National
Residential
Loadings.
(kkg/yr)1
2,633
5,563
Projected
National
POTU
Influent
Loadings
kkg/yr
35,002
28,717
*
Percent
Residential
Contribution
Based on
POTW Influent
Loadings (%)
7.5
19.4
Projected
Cumulative
Industrial and
Residential
Loadings -
Raw Discharge
(kkg/yr)
40,056
67,974
Percent
Residential
Contribution
Based on
Cumulative
Loadings - Raw
Discharge (%)
6.5
8.2
Projected
Cumulative
Industrial and
Residential
Loadings , PSES
Discharge
(kkg/yr)
22,349
8,833
Percent
Residential
Contribution
Based on
Cumulative
Loadings - PSES
Discharge (%)
11.8
63.0
Calculation assumes 21.6 BGD residential flow out of a total National POTW flow of 26 BGD. Flow values are derived from the 1980
NEEDS Survey.
>
Tor organic constituents, calculations are based on scale-up of flow-weighted average concentrations, excluding POTU 128.
Estimate represents the sum of projected industrial loadings (raw discharge) and residential loadings.
Estimate represents the sum of projected industrial loadings (PSES discharge) and residential loadings.
-------
sources account for 7.5 and 19.4 percent, respectively, of loadings to POTWs.
The analysis demonstrates that domestic sources do contribute both metal and
organic hazardous constituents to POTWs, As presented in Table 3-31, the
comparison of domestic loadings with industrial loadings for raw and PSES
discharge scenarios demonstrates that the relative contribution of domestic
sources to overall loadings should increase as categorical standards are
implemented. Because PSES implementation will result in substantial control
of metals discharges by industrial sources, the domestic contribution of
hazardous metals is projected to increase from 8.2 to 63.0 percent of total
metals loadings. The principal hazardous metals in domestic wastewaters are
lead, chromium, cyanide, and nickel. Major organic constituents found in
domestic wastewater include chlorinated solvents (e.g., tetrachloroethylene,
trichloroethylene), aromatic hydrocarbons (e.g., toluene) and phthalate esters
[e.g., Bis(2-ethyl hexyl) phthalate].
3.7 SUMMARY
This section summarizes the types, quantities, and sources of hazardous
wastes discharged to POTWs.
3.7.1 Types, Sources, and Quantities of Hazardous Constituent Loadings to
HUTWS
As discussed in the introduction to Chapter 3, quantities of charac-
teristic and listed hazardous waste discharged cannot be determined for the
consent decree industries (except the organics industries) due to limitations
in existing data sources. As a result, the Agency has estimated loadings of
metal and organic hazardous constituents from the 30 selected consent decree
industries. Although loadings estimates generally are limited to priority
hazardous constituents, the scope of the EPA/OSW ISDB also allows estimation
of nonpriority hazardous constituent loadings and hazardous waste loadings
from the organics industries. For the 17 remaining industrial categories, EPA
has utilized a variety of data sources to assess the potential for discharge
of hazardous wastes by these categories.
In evaluating consitutent loadings, the Agency projected national
industrial loadings using ITD and ISDB data sources and national constituent
3-154
-------
loadings to POTW influents. Generally, POTW and industrial constituent
loadings show reasonable agreement. For organic constituents, an analysis of
the 40 POTW data base results in projected national loadings of between 35,000
and 71,000 metric tons of priority organics. Estimates for total industry raw
loadings qf priority organics range from 37,000 metric tons to 52,000 metric
tons per/year, depending on whether ITD or ISDB loadings are used. For metal
constituents, industry estimates for raw loadings (62,000 kkg/yr) based on ITO
loadings exceed projected POTW loadings (29,000 kkg/yr) based on 40 POTW
sampling data. The difference may reflect the degree to which pretreatment
programs have reduced levels from raw to current.
Table 3-32 provides estimates of the quantities of hazardous constituents
discharged to POTWs from the selected consent decree industrial categories
under the raw and PSES scenarios. Hazardous constituents (both priority and
nonpriority) also are broken out into two major groups of constituents:
metals {including cyanide) and organics.
Approximately 62,000 metric tons per year of hazardous metal constituents
are discharged to POTWs under the raw loadings scenario. These loadings of
hazardous metal constituents for the consent decree industries are estimated
to be reduced by approximately 95 percent after implementation of pretreatment
standards for the applicable industrial categories. This reduction results in
a PSES loading for hazardous metal constituents of 3,270 metric tons per year.
The major industrial source of priority hazardous metal constituents
under the raw loading scenario is the electroplating/metal finishing category,
which accounts for approximately 68 percent of the total metals loading.
Electroplating/metal finishing is also the major source of priority hazardous
metal constituents under the after PSES scenario. Other major sources under
~x
the after PSES scenario include laundries (15 percent of total metal
loadings), petroleum refining (15 percent), and leather tanning categories (12
percent),
For priority hazardous organic constituents, Table 3-32 shows that
between 37,000 and 52,000 metric tons per year are discharged to POTWs under
3-155
-------
TABLE 3-32. SUMMARY OF HAZARDOUS CONSTITUENT LOADINGS TO POTHs FOR THE
SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES*
CO
i
Industry
Category
Adhesives and
Sealants
Batt ?ry
Manufacturing
Coal, Oil,
Petroleum
Products and
Refining
Dye Manufacturing
and Formulation
Electrical and
Electronic
Components
Electroplating/
Metal Finishing
Equipment
Manufacture and
Assembly
Explosives
Manufacture
Gum and Wood
Chem., and
Related Oils
Industrial and
Commerc i al
Launder ies
Ink Manufacture
and Formulation
Inorganic
Chemicals
Manufacturing
Estimated
Number of
Indirect
Dischargers
298
149
45
47
270
10,561
ND
4
14
68,535
223
31
Priority Hazardous Constituents
Raw Loading
(kkg/yr)
Metals/CN Organics
289 97
1,509 <1
484 1,686
(428) (434)
279 206
158 315
42,339 3,631
ND 7,715
<1 <1
2 51
595 984
3 <1
1 ,053 0
After PSES Loading
(kkg/yr)
Metals/CN Organics
131 70
1 <1
484 1,686
(1) (1)
<1 <1
74 32
1,017 175
ND 7,715
<1 <1
2 51
502 984
3 <1
103 0
Nonpriority
Raw Loading
(kkg/yr)
Hazardous Constituents
Metals/CN Organic*
ND
ND
ND
(2) {11,
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
400)
ND
ND
ND
ND
ND
ND
ND
ND
ND
After PSES
(*kg/
Metals/CN
ND
ND
ND
(2)
ND
ND
ND
ND
ND
ND
ND
NO
ND
Loading
yr)
Organics
ND
ND
ND
(136)
ND
ND
ND
ND
ND
ND
ND
ND
ND
Total Hazardous Constituents
Raw Loading
(kkg/yr)
After PSES Loading
(kkg/yr)
Metals/CN Organics
289
1,509
484 1,
(431) (U,
279
158
42,339 3,
ND 7,
<1
2
595
3
1,053
97
<1
686
834)
206
315
631
715
<1
51
984
<1
0
Metals/CN
131
1
484
(3)
<1
74
1,017
ND
<1
2
502
3
103
Organics
70
<1
1,686
(136)
<1
32
175
7,715
<1
51
984
<1
0
-------
TABLE 3-32. SUMMARY OF HAZARDOUS CONSTITUENT LOADINGS TO POTWs FOR THE
SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES* (Continued)
Estimated
Number of
Industry Indirect
Cateyory Dischargers
Iron and Steel
Mfg. and
Forming
Leather Tanniny
and Finishing
Nonferrous Metals
Forming
Nonferrous Metals
Manufacturing
Organic Chemicals
Manufacturing
Paint Manufacture
and Formulation
Pesticides
Formulation
Pesticides
Manufacture
Pharmaceutical
Manufacturing
Photographic Chem.
and Film Mfg.
Plastics Molding
and Forming
Plastics, Resins
and Synthetic
Fibers Mfg.
Porcelain
Enameling
Printing and
Publishing
162
140
228
123
230
751
169
38
277
ND
1,145
153
88
38,679
Priority Hazardous Constituents
Raw Loading After PSES Loading
(kkg/yr) (kkg/yr)
Metals/CN
3,920
5,097
203
114
(5,251)
1,021
17
ND
(232)
3
4,563
184
9
(118)
53
177
155
Oryanics Metals/CN
2,715
210
ND
9
(15,931)
6,067
49
ND
(536)
2,852
7,369
5
19
(8,514)
2,200
1
17
97
375
2
1
(515)
5
15
0
(2)
35
66
9
2
17
145
Nonpriority Hazardous Constituents
Raw Loading After PSES Loading
(kkg/yr) (kkg/yr)
Organics Metals/CN
236
164
ND
1
(846)
6
42
0
'::>
7,369
4
19
(10)
1
-------
TABLE 3-32. SUMMARY OF HAZARDOUS CONSTITUENT LOADINGS TO POTUs FOR THE
SELECTED CONSENT DECREE INDUSTRIAL CATEGORIES* (Continued)
Ul
CO
Industry
Category
Pulp and
Paper Hills
Ru'ber
Manufacture
and Processing
Textile Hills
Timber Products
Processing
SUBTOTALS**
Projected
Residential
Loadings
TOTALS**
Est mated
Number of
Indirect
Dischargers
261
512
974
6,680
130,787
ND
130,787
Priority Hazardous Constituents
Raw Loading
(kkg/yr)
Hetals/CN Organics
100 806
2 15
79 370
3 34
(67,084) (51,513)
62,411 37,423
5,563 2,633
(72,647) (54,146)
67,974 40,056
Atter PSES Loading
Hetals/CN
100
2
79
3
(3,788)
3,270
5,563
(9,351)
8,833
Qrganics
749
15
370
11
(20,566)
19,716
2,633
(23,199)
22,349
Nonpriority Hazardous Constituents
Raw Loading
(kkg/yr)
Metals/CN
ND
ND
ND
ND
(736)
ND
ND
(736)
ND
Organics
ND
ND
ND
ND
(63,561)
ND
ND
(63,561)
ND
After PSES Loading
(kkg/yr)
Metals/CN
ND
ND
ND
ND
(41)
ND
ND
(41)
ND
Organics
ND
ND
ND
ND
(2,530)
ND
ND
(2,530)
ND
Total Hazardous Constituents
Raw Loading
(kkg/yr)
Hetals/CN Organics
100 806
2 15
79 370
3 34
(67,821) (115,074)
62,411 37,423
B.563 2,633
(73,384) (117,707)
67,974 40,056
Alter PbES Loading
(kkg/yr)
Hetals/CN
100
2
79
3
(3,829)
3,270
5,563
(9,392)
8,833
Organ ics
749
15
370
11
(23,091)
19,716
2,633
(25,724)
22,349
ND - No Data
* - Data shown in parentheses represent estimates from the OSW ISDB for each applicable industrial category.
** - Totals and subtotals calculated with ISDB values for applicable industrial categories (shown in parentheses) and with ITD data (shown
without parentheses). ND or less than one (<1) values were assumed to be zero.
-------
the raw loadings scenario from all the selected consent decree industrial
categories. These priority hazardous organic constituent raw loadings are
reduced overall by approximately 50 percent after the implementation of
pretreatment standards by applicable industrial categories. The total
priority hazardous organic constituent loadings after PSES are approximately
20,000 metric tons per year.
As shown in Table 3-32, several industrial categories contribute
significant quantities of priority hazardous organics to POTWs under the raw
loading scenario. These industrial categories include equipment manufacture
and assembly; organic chemicals manufacture; pharmaceutical manufacture;
electroplating/metal finishing; and plastics, resins, and synthetic fibers
manufacturing. The source profile for loadings of priority hazardous organic
constituents changes significantly after PSES implementation to exclude those
industrial categories regulated under categorical standards for priority
organics. As a result of PSES implementation, several industrial categories
currently not regulated for priority organics under categorical standards
become major sources of priority hazardous organic constituents. These
industrial categories include equipment manufacture, pharmaceutical
manufacture, petroleum refining, and industrial and commercial laundries.
Table 3-32 presents estimated loadings of nonpriority hazardous
constituents to POTWs from the organics industries. As described in Section
3.2, these nonpriority hazardous constituent loadings were developed utilizing
ISDB data for four organic chemicals industrial categories. Raw loadings to
POTWs of nonpriority hazardous constituents for these four organic chemical
industrial categories are estimated to be 64,000 metric tons per year, of
which only 736 metric tons include nonpriority hazardous metals. Based on
these estimates, the organics industries discharge wastewater containing over
2 kilograms of nonpriority organic constituents for each kilogram of priority
organic constituents. Incidental removals due to installation of a PSES
technology equivalent to an acclimated biological system and assuming removal
rates presented in Chapter 4 are obtained, an overall reduction of 95 percent
in loadings of the nonpriority hazardous organic constituents would be
obtained. Where those assumptions are not met, these reduction estimates may
be substantially overstated.
3-159
-------
Loadings of nonpriority hazardous constituents also may be significant
for remaining consent decree industrial categories. Although loadings data on
the discharge of nonpriority hazardous constituents to POTWs are not avail-
able, the presence of these nonpriority hazardous constituents in discharges
to POTWs has been documented extensively in various data sources for several
selected consent decree industrial categories, such as pharmaceutical manu-
facturing, paint manufacture and formulation, equipment manufacture and
assembly, and electrical and electronic equipment. POTW loadings projections
outlined in Section 3.5 and POTW influent data collected for this study also
support the conclusion that certain nonpriority organic constituents are
discharged to POTWs in significant quantities.
For the remaining 17 industrial categories (discussed in Section 3.4),
Table 3-33 presents types and quantities of hazardous wastes discharged to
POTWs. These data were extracted from the SQG survey, which contains data for
(5)
only 12 of these 17 industrial categories/ ' For these 12 industrial cate-
gories, it was estimated that a total of 28,294 metric tons of hazardous
wastes are discharged annually to POTWs. The industrial category discharging
the largest quantity of hazardous wastes to POTWs is the service-related
industry, which encompasses a wide range of facilities providing various
services (e.g., photographic processing, extermination services) to the public
sector. Three of the five industrial categories lacking hazardous waste or
constituent discharge data represent new, emerging Industries. These indus-
trial categories are hazardous waste site cleanup, waste reclamation services,
and waste treatment and disposal. Based on assessments of the limited data
available, facilities within these categories are already causing site-
specific problems and may represent a significant source of hazardous waste
discharges at the National level as well.
To project quantities of hazardous constituents discharged to POTWs by
domestic sources, an estimate of residential loadings of priority hazardous
constituents was developed in Section 3.6. As shown in Table 3-32, residen-
tial loadings of hazardous constituents account for 5,563 metric tons of
priority hazardous metal constituents and 2,633 metric tons of priority
3-160
-------
TABLE 3-33. QUANTITIES OF HAZARDOUS HASTETYPES DISCHARGED TO POTOs FROH
SHALL QUANTITY GENERATORS FOR OTHER INDUSTRIAL CATEGORIES
Industri al Category
Construction Industry
Cosmetics, Frags.,
1 lavors 8 Food Add.
Elec. Gen. Power
Plants 4 Elec. Dist.
Fertilizer
Manufacture
Food and Food
By-Products Processing
Hazardous Waste
Site Cleanup
OJ
_!_, Laboratories and
en Hospitals
Mi seel 1 aneous
Chemical Formulations
Motor Vehicle
Services
Service Related
Industries
Soaps 4 Detergents,
Manufacture & Form.
Stone, Clay, Glass,
and Other Products
Transportation
Services
Spent
Solvents
(kg/yr)
8,592
3,708
ND
0
ND
ND
1,005,204
49,488
1,151,544
577,488
28,560
0
26,436
lyn Stable
Wastes
215,028
19,572
ND
0
ND
ND
455,388
1,128
8,376
214,092
9,696
0
0
Strong Acid
or Alkal jne
Wastes
(kg/yr)
18,468
40,740
ND
22,560
ND
ND
329,196
112,056
158,940
339,864
266,904
0
0
Photographic
Wastes
(kg/yr)
0
0
ND
0
ND
NO
0
0
0
18,457,452
0
0
0
Pesticides
Wastes
(kg/yr)
0
5,940
ND
0
ND
ND
0
17,808
0
670,764
315,936
0
0
Reactive Other
Wastes Wastes
{kg/yr) ( kg/yr)
0 0
0 0
ND ND
0 12
ND ND
ND ND
309,672 204
7,836 0
0 0
14,244 2.872,164
0 72
0 0
0 0
Total
242,088
69, 960
ND
22,572
ND
ND
2,099,644
188,316
1,318,860
23,146,068
621,168
0
26 ,436
-------
ND-No Data
SOURCE: Reference (5)
TABLE 3-33. QUANTITIES OF HAZARDOUS MASTETYPES DISCHARGED TO POTUs FROM
SMALL QUANTITY GENERATORS FOR OTHER INDUSTRIAL CATEGORIES (Continued)
Industrial Category
Waste Reclamation
Services
Wa te Treatment
and Disposal
Wholesale and
Retail Trade
Spent
Solvents
(kg/yr)
HO
ND
32,256
ly ni table
Wastes
(kg/yr)
ND
ND
49,728
Strong Acid
or Alkaline
Wastes
U9/yr)
ND
ND
132
Photographic
Wastes
(kg/yr)
ND
ND
30,912
Pesticides
Wastes
(kg/yr)
ND
ND
22,884
Reactive
Wastes
(kg/yr)
ND
ND
0
Other
Wastes
(kg/yr)
ND
ND
24,108
Total
(fcg/yr)
ND
ND
160,020
Wood Furniture
Mfg. and RefinJshing
TOTALS
151,488 11,268 0 0 0 0 236,940 399,696
3,034,764 984,276 1,288,860 18,488,364 1,033,332 331,752 3,133,500 28,294,848
-------
hazardous organic constituents discharged annually. This analysis demon-
strates that domestic sources do contribute hazardous constituent loadings to
POTWs. The relative contribution of constituent loadings by domestic sources
should increase significantly with PSES implementation,
3,7.2 Analysis of Hazardous Waste Types Discharged to POTWs
Due to the types of data available, Agency review has emphasized industry
loadings of specific hazardous constituents, rather than wastes. Still,
constituents loadings data and other data collected and evaluated for this
study also enable EPA to examine the potential for discharge of characteristic
and listed wastes by various industrial sources. This section provides a
brief summary of Chapter 3 industrial data as it relates to the discharge of
hazardous wastes. RCRA characteristic wastes include ignitable, corrosive,
reactive, and EP toxic wastes. Each of those waste types is evaluated below.
The Chapter 3 analysis of volatile and ignitable constituents demon-
strates that numerous industrial categories discharge wastewaters containing
significant quantities of ignitable constituents. When discharged in sub-
stantial concentrations, these organic constituents, especially volatile
organics such as benzene, toluene, and xylene, may cause fire or explosion in
POTW collection and treatment systems. The POTW incidents file (Appendix K)
documents several discharges of ignitable wastes that have caused fire or
explosions in POTW systems.
The industry assessment similarly indicates that a broad range of
industries may generate and discharge corrosive or reactive wastes to POTWs.
An extensive review of ITD development documents reveals that numerous consent
decree industrial categories generate highly acidic or alkaline wastewaters.
Moreover, as estimated by the SQG Survey, a majority of the remaining cate-
gories also generate and discharge to POTWs strong acid or alkaline wastes.
Based on a review of ITD data, many industry wastestreams contain waste
constituents such as cyanide and sulfides that have reactive properties.
Discharges of reactive wastes also are documented in the POTW incidents file.
3-163
-------
Analysis of loadings of specific hazardous metals constituents reveals
that most of the selected consent decree industries discharge some quantity of
the EP toxic metal constituents in their wastewaters. Table 3-34 presents an
overview of major industrial sources of each EP toxic metal contaminant.
Table 3«34 does not provide estimates of hazardous waste quantities, but
rather shows the principal metal constituents in industry wastewaters, and the
extent of PSES controls on these constituents by comparing industry-wide
constituents concentrations (i.e., total industry mass loadings divided by
total industry flow) to EP toxic contaminant concentrations in RCRA regula-
tions. Table 3-34 demonstrates that categorical standards result in sub-
stantial control of EP toxic metals discharged by consent decree industries.
Some regulatory gaps remain for smaller sources, such as laundries and
printing/publishing operations.
The Agency has listed numerous wastes based on the presence in these
wastes of specific constituents that are either toxic or possess a charac-
teristic such as ignitability. Evaluation of the potential for discharge of
these wastes therefore may be tied to specific constituents that are likely to
be present in these wastes. The following discussion emphasizes selected
listed wastes including spent solvents, listed wastes for the metal finishing
industry, and listed wastes for the organics industries.
Sampling and use data collected for the industry assessment suggest that
numerous industrial categories discharge spent solvents. Table 3-35 demon-
strates the range of industries known or believed to discharge the 26 organic
constituents listed as spent solvents. Although actual sampling data for the
16 nonpriority pollutants are limited, several of these compounds (e.g.,
acetone, xylene, cresols, etc.) appear to find prevalent use among the consent
decree industries. The POTW incidents file also documents operational
problems associated with the discharge of these solvents, especially volatile,
ignitable compounds.
Appendix VII constituents for metal finishing wastes include hexavalent
chromium, nickel, cadmium and cyanide. Because these four waste constituents
are regulated specifically by categorical standards, pretreatment controls
3-164
-------
Ul
TABLE 3-34. COMPARISON OF INDUSTRY-HIDE METAL CONCENTRATIONS MITH
MAXIMUM EP CONTAMINANT CONCENTRATIONS1
CadBiiai
(Ibiiw EP
Cone. - 1.
lM EP
. * S.Oag/1)
Lead
xiM EP
CMC. - S.
Mercury
(Naxiaw» EP
(NlKlMM EP
COM. * 1.0«3/1)
Silver
(Nutaw
Cone. -
pstsl
X
fMf I
PSES
PSES
PSES
N
rev* I
>.Z5
MEW
~"
PSES]
>r
PSES/'I
FSES |
_>§_
>SES I
X
X
PSES I
PSES I
~
ES5 I
T.I
PSES
PSES
fax
>f
SES
PSES/'
JUo
PSES
KEV:
>1 * iMhtttry-wlde coiKMtration fruter thM 1001 of EP atxtaw conbwlunt concMtntlon
X2S iNdwtry-wide concMtration frcatcr ttum Kl of EP Mxt«M cMtwtMit coKeatratloii
>.l = iadustry-Mlde ccmcMtratlon (reater than 101 of EP mttimm conU«liu*t concNtratloa
9 Iwtettry-Klde concMtrttlon less than 10X of EP nxiaw coHUBiiunt concMtratton
- Poilytant specffically regulated by a categorical standard
Rafale does not provide estimates of hazardous waste quantities. Rather, it is intended to show
principal metal constituents in industry wastewaters, and extent of PSES controls on these constituents
Bariun is not included due to lack of sampling data
-------
TABLE 3-35. PROFILE OF INDUSTRIAL SOURCES OF ORGANIC CONSTITUENTS
WHICH ARE RCRA SPENT SOLVENTS
UMBIftlAL
CMECOH
OUMtC
COKTITUUIS llST
M SPUN SOLNUIS
tCtrMletlHf/NcUi
ftliMng*
* V
ii
3C
*8
5t
jJt
Hute TfMtae
pOMl
rnit
ture
MceUw
tnz
l-lutyl Aluhal
C«rhM Olmlf 1
1«tr«chl«rlel>
u
Chi
Cresals
Ml
Blchlaradl fl
EUyl AccUU
n
Etkjrl
3U
23
m
HZ
14
141
Ethyl EUwr
l.itt
zifii
113
Ibthylew Chl0rlde
14
12
I.MB
a
Methyl Ethyl BeUM*
Nethyl
KctoM
U
a
Pyrldt
n
letrcchlttraeUiyl
a
I.2M
31
MB
12
70
14
3M
31
14
l.l.t-lrlchlarae
u
1.M9
H
13
.ttl
20
1.1.2-Irlchloro-l.Z.2-1rifliMniethMe
U
M no or ISM data (All loadings are in metric tons/year)
IM »f Paragraph 4c uBpliftg data. BSS uopliftg data *r
*uu/iecai tMpiMB. «au
S - Ce*»tltimt believed to he pmcM U twhutry MHUMUr tatedi M review of Chi»Ur 3 use
pmfll* d«U. SQG dau or WBK data hasc.
Key: UMdiags reflect current loadings b*sed
P CotttituMt itfMtlfietf tasad M m
StaU/lecal »Mpll*B d*t»
* LiMdiMgs for these categoric* reflect PSES argMic* oMtntla (e.g.. HO).
{LM lMdt«f> My he slgalflcMtlr higher thM PStS |oadi«ft.
Sources: References (5), (6), Appendix I
-------
CHAPTER 4
FATE OF HAZARDOUS WASTE AND POLLUTANTS
IN POTW COLLECTION AND TREATMENT SYSTEMS
-------
-------
4. FATE OF HAZARDOUS WASTE AND POLLUTANTS IN
POTW COLLECTION AND TREATMENT SYSTEMS
4.1 BACKGROUND AND METHODOLOGY
Projected POTW influent loadings of DSS pollutants were discussed in
Chapter 3. The purpose of this chapter is to analyze the fate of these pol-
lutants once they are discharged to POTW collection/treatment systems. As
discussed in Chapter 2, 165 pollutants were selected to represent the haz-
ardous constituents being discharged to POTWs. Of these pollutants, 10 are
metals, 38 are pesticides, and 117 are organic pollutants. The physical/
chemical properties utilized in assessing the fate of each of these pollutants
are presented in Appendix N.
A POTW collection/treatment system is composed of three components:
(1) a conveyance system of underground sewer pipes that collect and transport
wastewater to a treatment facility; (?.} the treatment plant, which consists of
various unit processes designed to remove pollutants from the wastewater; and
(3) an outfall structure, which discharges treated effluent to a receiving
body of water. Pollutants can be removed from the wastewater and/or trans-
ferred to other media through five pathways:
Leaks in the collection system
Volatilization to the atmosphere
Biodegradation of pollutants
Partitioning of pollutants to sludge
Treatment plant pass through of pollutants to the receiving stream.
The determination of the fate of pollutants within these pathways is
dependent upon a number of complex and interrelated factors. These factors
include the design of the POTW collection/treatment system, how the system is
operated and maintained, the physical/chemical properties of the pollutants,
and the physical/chemical properties of the total wastestream. These factors
are highly site-specific and will vary among POTWs. Data generally are not
available to characterize each of these factors to the level of detail
necessary for a rigorous analysis. However, based on literature information
and recent EPA research, reliable estimates can be made.
4-1
-------
In searching the literature for information on the fate of DSS pollutants
in POTW sewers and collection systems, it was discovered that little is known
about DSS pollutant fate and behavior in POTW collection systems. Most of the
research and sampling study work has focused on pollutant concentrations,
either at the discharge point of specific industrial contributors or at the
POTW. In addition, lack of available data on ground-water contamination due
to leaking POTW collection systems makes it difficult to estimate the extent
of this problem.
Considerably more research has been conducted on the removability and
probable fate of DSS pollutants in POTW treatment plants. The portion of
these pollutants not present in a POTW effluent are removed by three principal
mechanisms: partitioning (sorption) to the solids and biomass, stripping and
desorption of volatile organics, and biodegradation of specific pollutants.
These three removal mechanisms in conventional wastewater treatment (i.e.,
primary-activated sludge) interact and complement each other in reducing
emissions to the receiving stream. Prediction of the removability and fate of
a given pollutant requires knowledge of the equilibrium and kinetic rates of
each mechanism.
Detailed data are limited, especially for kinetic rates. For the
purposes of estimating the removability and fate of the DSS pollutants and
projecting these loadings on a National basis, this study used the results of
recent research conducted by a toxics research group at EPA's Wastewater
Environmental Research Laboratory (WERL) in Cincinnati, Ohio. This work was
selected as the basis for the derivation of emission factors because it
represented a collective opinion of several individuals with experience in the
field'1'2'3'4'.
EPA-WERL based their conclusions on probable fate on their best
professional judgments (BPJ), and summarized literature data, their collective
knowledge of biodegradation literature, their "hands on" pilot experience with
pertinent DSS pollutant removability, and their experience with ongoing
treatability studies. They utilized Henry's Law Constants, octanol/water
partition coefficients, and qualitative biodegradation data in making the
estimates.
4-2
-------
The volatility parameter for DSS pollutants must consider the substance's
tendency to vaporize and its propensity to remain in solution. The principal
measure that has been used in the literature is Henry's Law Constant. Henry's
Law Constants are available or can be calculated from information available in
the literature for the majority of the DSS pollutants.
The Henry's Law Constant is a ratio of a substance's vapor pressure and
solubility. It measures a compound's tendency to partition between the
aqueous and gaseous phases at equilibrium. The higher a substance's Henry's
Law Constant, the more likely that compound is to migrate from water to air.
Henry's Law Constants are presented in the literature in various manners and
with various units. The most common formula given for Henry's Law Constant
and the one used in the estimates in this chapter is:
H
Pv
"Cs
where: H = Henry's Law Constant atm-m3
(at equilibrium) mole
Pv = Compound's vapor pressure in air (atm)
Cs = Compound's soluble concentration in water (mole/m3)
The octanol/water partition coefficient (K } is a measure of a
r ow'
compound's tendency to concentrate either in the organic phases or in water
at equilibrium. In general, the higher a compound's K , the more likely that
OW
compound will be to migrate from the aqueous phase and partition. Therefore,
compounds with high K values would be expected to adsorb more readily to the
ow fM
biomass during activated sludge treatment. v/
4.1.1 Summary of Current State of Knowledge on Pollutant Fate
Among the organic pollutants, the literature supports the contention that
there are three dominant processes ongoing at the same time within treatment
facilities causing the removal of pollutants from wastewater: (!) air
stripping and desorption; (2) sorption to solids or the biomass; and (3)
biodegradation. The extent to which each process contributes to the removal
4-3
-------
of pollutants from wastewater during treatment can vary significantly. It is
a function of both the physical and chemical characteristics of each pol-
lutant, as well as the conditions present in the particular treatment facil-
ity, such as the relative rate of aeration (which is governed by the rate of
oxygen/air flow), total area of the air/liquid interface, and the concen-
tration and activity of the mixed liquor volatile suspended solids (MLVSS).
These processes, as well as the conditions present throughout the treatment
process, will be discussed further below. Other removal mechanisms, such as
hydrolysis or photo-oxidation, may potentially play some role in the removal
of a specific pollutant; however, no discussion of these mechanisms appeared
in the literature. Recent studies have shown that the degree of acclimation
of a biological treatment system plays an important role in the fate of DSS
pollutants. Acclimated removals occur under conditions when a biological
treatment system has been fed relatively steady amounts of a pollutant and
biodegradation rates stabilize.
Partitioning (Adsorption)
The literature and research performed to date support the existence of a
direct relationship between a compound's water insolubility or hydrophobicity
and its affinity for the surface area and extent of surface area available in
the sorbent. A widely used tool for estimating insolubility and subsequent
potential for sorption of organic compounds onto particulates and biomass is
tne K_llt or the octanol/water partition coefficient. K.,. often is expressed
ow ow
as a logarithm to the base 10, or Log K . In general, compounds that have
ow
Log K values greater than 3.5 are significantly hydrophobic and adsorptive
UW
on solid organic matter, such as MLVSS or sludge. Compounds that have Log K
less than 3,5 more likely will be removed through biodegradation or, in the
case of a more volatile pollutant, through air stripping. Due to their
adsorptive nature, compounds having a high Log K also may be expected to
UW
concentrate in sludge. This expectation has been confirmed in at least one
recent study* ' that found a reasonably good correlation between primary
sludge concentration factors (computed by dividing the concentrations in the
primary sludge by the influent concentrations) and K . This study also found
ow
that, while substantial losses of volatile organic compounds during primary
clarification are due to volatilization, partitioning to the primary sludge
ow
4-4
-------
was not the primary removal mechanism since the concentrations in the primary
sludge were low. Additional factors that may affect the rate of adsorption
include the presence of other compounds, electrolytes, oils and greases, and
sorbents.
Volatilization
Pollutants are stripped from aeration basins in activated sludge systems
by diffusing through the surface of air bubbles used to aerate the system.
In addition, flumes, grit chambers, sumps, equalization basins, pH adjustment
stations, nutrient addition stations, clarifiers, oxidation basins, open stor-
age tanks, wastewater transfer lines, pipes, or ditches are all points where
volatilization can occur. In a 1984 field study of a wastewater treatment
system at an organic chemicals facility, 10-15 percent of influent toluene
volatilized in the primary system, 25-35 percent volatilized in the equaliza-
tion basins, and 10-34 percent volatilized from the aeration basins.
(14)
A
pollutant's ability to transfer into the air bubbles or desorb from water
surfaces is functionally dependent on its Henry's Law Constant (HC). Com-
pounds with high HC values (greater than 0.024) have been shown in the litera-
ture to be easily stripped. According to one study,* ' the air stripping rate
of a specific organic is also influenced by the concentration of that contami-
nant in the liquid being aerated. In addition, a pollutant's affinity to
adsorb onto the biomass is a mechanism that will reduce the amount of material
stripped during conventional treatment. It also has been shown that stripping
is most likely to be the dominant removal mechanism for many halogenated
compounds. The more halogenated a chemical compound is by weight, the more it
is likely that the compound will be removed by stripping. This contention is
confirmed by the high rates of volatilization (greater than 90 percent) that
have been reported in POTWs for VOCs such as 1,1,1-trichloroethane, trichloro-
fluoromethane, and dicnlorodifluoromethane. In comparison, lower volatiliza-
tion rates have been reported for nonhalogenated pollutants such as benzene
and toluene/ '
Biodegradation
Biodegradation plays a substantial and sometimes controlling role in
the ultimate fate of the volatile organics, especially those of moderate
4-5
-------
volatility 1n conventional wastewater treatment. The extent of biological
oxidation depends on the ease of biodegradatlon of the compound, availability
of co-metabolites serving as food to the biota, the quantity (concentration)
of biologically active solids (MLVSS) and oxygen, as well as the degree of
acclimation of the MLVSS.
As was discovered in one study/ ' the rate of blodegradatlon often is
controlled by the availability of oxygen. In a well-aerated system, for
compounds such as benzene and toluene that biodegrade to some degree under
normal aeration conditions, air stripping may be the dominant removal
mechanism. The extent of halogenation also influences the relative bio-
degradability of the compound (i.e., the more halogens in a chemical compound
by weight, the less biodegradation will be in evidence). Biochemical oxida-
tion is highest for organic priority pollutants having low Log K values
UW
(less than 3.5). In addition, air stripping has been shown to compete with
blodegradatlon as a removal mechanism in activated sludge treatment for some
compounds such as benzene, toluene, ethylbenzene, and chlorobenzene that have
relatively high Henry's Law Constants/ '
Among the three mechanisms discussed above, 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 concentration and activity of MLVSS. All of these factors are
critically dependent on how well the facility is run and the distribution,
characteristics, and concentrations of the pollutants in the wastewater. In
acclimated treatment systems, biodegradation is a more effective removal
mechanism. In unacclimated treatment systems, removal of many organics is
chiefly by volatilization and sorption to solids and blomass.' ' Dissolved
salts also affect all three removal mechanisms associated with activated
sludge treatment systems. Such factors as surface tension, interfacial ten-
sion, viscosity, and diffusion also must be considered in ultimate environ-
mental fate analysis/7' Design of the aeration basin Is also a critical
factor that affects removal mechanisms.
4-6
-------
4.1.2 Summary of Findings on Pollutant Fate
Volatile Organic Compounds (VOCs)
There is mounting evidence that many of the DSS pollutants only have
limited survival times under commonly encountered conditions. A large
percentage of the VOC mass is not accounted for in POTW effluents or sludge
streams. The disappearance occurs because of volatilization and biodegrada-
tion. Adsorption of volatile organics accounts for no more than 10 percent of
the VOCs in the influent.'9'
Acid Compounds
It is believed that most of the removal observed for the acid compound
group is through biodegradation. Biodegradation averaged about 84 percent
with equal partitioning of the remaining load between sludge (8 percent) and
(9)
the final effluent (8 percent}/ ' The influent and effluent concentrations
for 2-chlorophenol at POTWs are identical, which is likely the result of the
formation of this compound in the chlorination process, before discharge of
the final effluent. This compound also may be a chemical or bacterial degra-
dation product of other chlorinated compounds. The removal of 2,4-
dichlorophenol in POTWs also is reported as low, and at low influent concen-
trations, the expected effluent concentration is actually larger. This is
also a likely result of the chlorination process. The reduction factors for
tri- and pentachlorophenol are higher than observed for mono- and dichloro-
phenol because these compounds are not likely to be formed during chlorination
of the final effluent. The methylated phenols generally experience
greater percent removals than the chlorinated phenols, possibly due to their
greater biodegradability during aerobic treatment. NHrophenols show the
least reduction of any of the phenols during biological treatment due to their
relatively low degradability through the sewage treatment plant. The low
apparent sludge accumulation may be due to their low adsorption capacity onto
bacterial solids, which probably corresponds with the strong electronegative
character of the nitrogroup resulting from the inductive and resonance
electron withdrawal from the aromatic ring.
(10)
4-7
-------
Base/Neutral Compounds
Removal mechanisms for this group are the least uniform of all pollutant
groups. Most of the POTW Influent loadings for this group are contributed by
the phthalates/9' with certain phthalates [b1s(2-ethylhexyl) phthalate,
di-n-octyl phthalate] partitioning to the sludge while others (dimethyl
phthalate, diethyl phthalate} generally are removed via biodegradatlon. Other
more frequently detected base/neutral compounds, such as the chlorobenzenes,
range from low to moderate biodegradation and moderate to high sludge
partitioning. Volatilization for all chlorobenzenes generally falls 1n the
moderate range.
pesticides and PCBs
Compounds in this group generally experience fairly high removals in
activated sludge systems with the principal removal mechanisms being bio-
degradation and sludge partitioning. Substantial sludge accumulations were
noted for pesticides and herbicides in anaeroblcally digested sludge/ '
Metals
The decrease in the wastewater concentrations of all heavy metals
corresponded to increases in the sludge levels.
(10)
4.2 ANALYSIS OF POLLUTANT FATE WITHIN POTW COLLECTION SYSTEMS
4.2.1 Analysis of Pollutant Volatilization Within POTW Collection Systems
Little is known about DSS pollutant fate and behavior in POTW collection
systems. Most of the research and sampling study work performed previously
focused on pollutant concentrations either at the discharge point of specific
industrial contributors or at the POTW. However, there have been numerous
case studies involving sewer maintenance workers who have been injured or
killed from hazardous gases formed in sewers (see Appendix K). While most
accidents have been caused by the formation of hydrogen sulfide gases, more
recent incidents have been linked to certain organic pollutants that either
volatilized or reacted with hydrogen sulfide within the POTW collection
system.
4-8
-------
Study of pollutant behavior in sewers is complicated by many diverse
influences, including wastewater characteristics, flow volume, flow velocity,
variations in flow level, materials of construction, and rainfall events.
Moreover, collection systems are difficult and dangerous systems from which to
sample with any degree of accuracy. Therefore, because of the above-mentioned
limitations and hindrances to potential research, a quantitative estimate of
the amount of organic pollutants volatilized in POTW collection systems cannot
be made at this time. However, a recent sampling study in a large POTW col-
lection system revealed significant levels of many pollutants in the space
above wastewater surfaces in the interceptor sewer/ ' Also, on a qualita-
tive basis, recent EPA-WERL calculations using a shallow stream desorption
model indicate that volatile organics tend to desorb rapidly into the gas
phase in the sewers. This indicates that in combined storm and sanitary
sewers, transfer into the air of organics would occur at catch basins and
manholes, while transfer would be virtually nonexistent in separate sanitary
sewers with limited air exchange.
Although there is limited information on the quantitative fate of DSS
pollutants in POTW collection systems, a large body of information exists on
the relative volatility of various OSS pollutants in sewer systems related to
fire risk and explosion hazards. Table 4-1 presents a compilation of various
pollutant characteristics related to fire and explosion hazards for those DSS
pollutants with flashpoints that fall within the range of ambient temperatures
found in POTW collection systems. A rating of each pollutant's relative
health, flammability and reactivity risks also is included.
4.2.2 Analysis of Potential for Ground-Water Contamination
Although little is known about the fate of DSS pollutants in POTW
collection systems, even less is known about potential ground-water contami-
nation due to the migration of these pollutants from POTW collection systems.
In the past, Federal, State, and local regulatory authorities have focused
their attention on infiltration/inflow (I/I) problems associated with POTW
collection systems rather than potential incidents of outflow from sewers.
Therefore, little is known about the overall quantity of wastewater flow
escaping from POTW collection systems. However, based on the characteristics
4-9
-------
TABLE 4-1. SUMMARY OF FIRE/EXPLOSION RISK CHARACTERISTICS FOR THOSE
RCRA STUDY POLLUTANTS WHOSE FLASHPOINT IS BELOW AN AMBIENT
TEMPERATURE (100°F) THAT MIGHT BE FOUND IN POTW COLLECTION SYSTEMS
I
I'
o
Pollutant
TIER ONE
Acetone
H-Butyl Alcohol
Carbon Qisulfide
Chlorobenzene
Ethyl Acetate
Ethyl Benzene
Ethyt Ether
Methanol
Methyl Ethyl Ketone
Methyl IsobutyT Ketone
PyMdlne
Toluene
Xylenes
TIER TUP
Acetaldehyde
Acetonitrlle
Acetyl Chloride
Acroletn
Benzene
ChJoronethane
Cumene
Flanable
Flash Ignition Limits (% by Vol.
Point °f leap °F Lower Upper
-4.0
98
-22.0
82.0
24,0
59
-49
52
16
64
68
40
81-90
-38
42
40
-15
12
-50
96
869
650
194
1099
800
356
867
759
840
900
896
867-984
347
975
734
428
928
1170
795
2.5
1.4
1.3
1.3
2.0
1.0
1.9
6.0
1.4
1.2
1.8
1.2
1.0-1.1
4.0
3.0
1.1
2.8
1.3
8.1
0.9
13
11.2
50
9.6
11.5
6.7
36.0
36.0
11.4
8.0
12.4
7.1
7.0
60
16.0
2.7
31
7.9
17.4
6.5
J Boiling
Point °F
133
243
115
270
171
277
95
147
176
244
239
231
281-292
70
179
124
125
176
-11
306
Hazard Identification
Health FlaMability Reactivity
1
1
2
2
1
--
2
I
1
2
2
2
2
2
2
3
3
2
2
2
3
3
3
3
3
--
4
3
3
3
3
3
3
4
3
3
3
3
4
3
0
0
0
0
0
~
1
0
0
0
0
0
0
2
0
Z
2
0
0
0
-------
TABLE 4-1. SUMMARY OF FIRE/EXPLOSION RISK CHARACTERISTICS FOR THOSE
RCRA STUDY POLLUTANTS WHOSE FLASHPOINT IS BELOW AN AMBIENT
TEMPERATURE (100°F) THAT MIGHT BE FOUND IN POTV COLLECTION SYSTEMS (Continued)
Pollutant
Cyclohexane
1 , 1-D1 chl oroe thane
1 ,2-Oi chloroethane
1 , 2-Di chl oroethy 1 ene
1,2-Trans-DlchToroethylene
1 ,2-Dichloropropane
Dimethyl ami ne
p-Dioxane
Epichlorohydrin
Ethyl ene Oxide
Furan
Hydrazine
2-Nitropropane
Tetrabydrofuran
Vinyl Chloride
TIER 2A
Acrylonitrile
Methyl Mercaptan
Styrene
Flammable
Flash Ignition Limits (1 by Vol.
Point °F Temp °F Lower Upper
-4
22
56
-19
36
60
Gas
54
88
-20
32
100
75
6
Gas
32
~
88
473
--
775
1058
860
1035
752
356
772
1058
--
802
610
882
898
914
1.3
5.6
6.2
6.5
5.6
3.4
2.8
2.0
3.8
3.0
2.3
2.9
2.6
2
3.6
3.0
3.9
1.1
8.0
--
16
15.5
12.8
14.5
14.4
22
21.0
100
14.3
98
11.0
11.8
33.0
17
21.8
7.0
) Boi 1 i ng
Point *F
179
135-138
183
89
119
205
45
214
239
51
88
236
248
151
7
171
42.4
295
Hazard Identification
Health Flammability Reactivity
1
2
2
2
2
2
3
2
3
2
1
3
2
2
2
4
2
2
3
3
3
4
3
3
4
3
2
4
4
3
3
3
4
3
4
3
0
0
0
2
2
0
0
1
2
3
1
2
1
1
1
2
0
2
Source: "Fire Hazard Properties of Flatrmable Liquids, Gases and Volatile SoUds 1984," National Fire Protection
Association, 1984.
-------
TABLE 4-1. KEY TO CODES FOR HAZARD IDENTIFICATION INFORMATION
(Continued)
Reactivity (Stability).
The assignment of degrees in the reactivity
category is based upon the susceptibility of
materials to release energy either by themselves
or in combination with water. Fire exposure was
one of the factors considered along with
conditions of shock and pressure.
4 Materials which (in themselves) are readily
capable of detonation or of explosive
decomposition or explosive reaction of normal
temperatures and pressures. Includes
Materials which are sensitive to Mechanical
or localized thermal shock. If a chemical
with this hazard rating is in an advanced or
nassive fire, the area should be evacuated.
3 Materials which (in themselves) are capable
of detonation or of explosive decomposition
or of explosive reaction but which require a
strong initiating source or which must be
heated under confinement before initiation.
Includes Materials which are sensitive to
thermal or mechanical shock at elevated
temperatures and pressures or which react
explosively with water without requiring heat
or confinement. Fire fighting should be done
from an explosion-resistant location.
2 Materials which (in themselves) are normally
unstable and readily undergo violent chemical
change but do not detonate. Includes materi-
als which can undergo chemical change with
rapid release of energy at normal temper-
atures and pressures or which can undergo
violent chemical change at elevated
temperatures and pressures. Also includes
those materials which may react violently
with water or which may fora potentially
explosive mixtures with water. In advanced
or massive fires, fire fighting should be
done from a safe distance or from a protected
location.
1 Materials which (in themselves) are normally
stable but which nay become unstable at ele-
vated temperatures and pressures or which may
react with water with some release of energy
but not violently. Caution must be used in
approaching the fire and applying water.
0 Materials which (in themselves) are normally
stable even under fire exposure conditions
and which are not reactive with water.
Normal fire fighting procedures may be used.
Flamiability.
Susceptibility to burning is the basis for
assigning degrees within this category. The
method of attacking the fire is influenced by
this susceptibility factor. For further
information on this subject, refer to the column
on "Extinguishing Method" and to its explanation
on pages 5 and 6.
4 Very flammable gases or very volatile
flammable liquids. Shut off flow, and keep
cooling water streams on exposed tanks or
containers.
3 Materials which can be ignited under almost
all normal temperature conditions, water may
be ineffective because of the low flash
point.
2 Materials which must be moderately heated
before ignition will occur. Hater spray May
be used to extinguish the fire because the
material can be cooled below its flash point.
1 Materials that must be preheated before
ignition can occur. Water may cause frothing
if it gets below the surface of the liquid
and turns to steam. However, water fog
gently applied to the surface will cause a
frothing which will extinguish the fire.
0 Materials that will not burn.
Health.
In general, health hazard in fire fighting is
that of a single exposure which may vary from a
few seconds up to an hour. The physical
exertion demanded in fire fighting or other
emergency conditions may be expected to
intensify the effects of any exposure. Only
hazards arising out of an inherent property of
the Material are considered. The following
explanation is based upon protective equipment
normally used by fire fighters.
4 Materials too dangerous to health to expose
fire fighters. A few whiffs of the vapor
could cause death or the vapor or liquid
could be fatal on penetrating the fire
fighter's normal full protective clothing.
The normal full protective clothing and
breathing apparatus available to the average
fire department will not provide adequate
protection against inhalation or skin contact
with these materials.
3 Materials extremely hazardous to health but
areas may be entered with extreme care. Full
projtective clothing, including self-
contained breathing apparatus, coat, pants,
gloves, boots, and bands around legs, arms
and waist should be provided. Ho skin
surface should be exposed.
? Materials hazardous to health, but areas may
he entered freely with full-faced mask self-
contained breathing apparatus which provides
eye protection.
1 Materials only slightly hazardous to health.
It may be desirable to wear self-contained
breathing apparatus.
0 Materials which on exposure under fire
conditions would offer no hazard beyond that
of ordinary combustible material.
-------
of the types of sewer systems in use and the various areas where POTW
collections have been installed, some general conclusions regarding potential
ground-water contamination can be drawn:
Gravity flow collection systems would tend to have infiltration rather
than exfiltration.
Pressure sewers and nonpressure collection systems with a number of
pump stations may be more susceptible to exfiltration.
POTW collection systems installed in areas with relatively high water
tables generally will have more infiltration than exfiltration.
POTW collection systems installed in areas with low water tables may
be more susceptible to exfiltration during dry weather conditions.
4.3 ANALYSIS OF POLLUTANT FATE WITHIN POTW TREATMENT SYSTEMS
4.3.1 Evaluation of POTW Removal Efficiencies - Pass Through to Receiving
Waters
Appendix 0 presents the estimated acclimated and unacclimated removal
efficiences for all DSS pollutants. Since most of the unacclimated removal
efficiencies generated were ranges, the midpoint and the low-end of the
range were chosen to represent unacclimated removal efficiencies (the few
acclimated ranges were presented as midpoints). The majority of these
estimated removal efficiencies were obtained from EPA-WERL, which generated
them from priority pollutant data obtained from three EPA-WERL research
projects/6' 11,12,13) gp^.^ERL personnel also used their BPJ to extrapolate
removal efficiencies on priority pollutants for estimating removals for all
DSS pollutants. All estimated acclimated removal efficiencies generated by
EPA-WERL were based on the assumption that each pollutant enters the POTW at
500 ppb. The analysis assumes a conventional activated sludge treatment
system meeting secondary treatment requirements. In addition, it was assumed
that the pollutant being evaluated was discharged to the POTW with a group of
typical toxic pollutants at low background level concentrations. Experimental
data not based on these assumptions were adjusted accordingly in EPA-WERL's
BPJ estimates. Unacclimated percent removal estimates were obtained using
experimental data from one of the above-mentioned ongoing research studies^ '
and from EPA-WERL's knowledge of the available literature and its ongoing
4-13
-------
treatability studies. A limited amount of removal data on unacclimated
operation supported the development of the estimates both on overall removal
and on volatilization fractions.
Although these acclimated and unacclimated removal efficiencies are
considered accurate estimates using the study data provided, there is one
limitation in its use. The steady pollutant feed rates that were used in all
the acclimated experiments contrast with the slug loadings and batch dis-
charges which POTWs experience in everyday operation. Also, the efficient
operation of batch- and pilot-scale systems cannot be duplicated at the
majority of full-scale POTWs. However, full-scale POTWs would only experience
a limited number of pollutant loadings, which might cause removal efficiencies
to drop to the low end of the unacclimated removal efficiency range.
In an attempt to determine which estimate approximates actual full-scale
POTW removal efficiencies, a comparison was made between removals obtained
from the 40 POTW Study data base and corresponding DSS pollutant removal
estimates. Table 4-2 presents the acclimated and unacclimated percent removal
estimates made by EPA-WERL and the percent removals obtained using the 40 POTW
Study data for selected DSS pollutants. Although there are certain agree-
ments, EPA-WERL estimates of percent removal are not overwhelmingly in agree-
ment with the actual percent removal data from the 40 POTW Study. Therefore,
all three removal efficiencies will be presented to give a complete basis for
comparison of the data.
4.3.2 Analysis of Pollutant Volatilization Rates Within POTW Treatment
Systems
Appendix P presents the volatilization rates selected from the various
data sources for acclimated and unacclimated activated sludge treatment
systems. The majority of these volatilization rates were taken directly from
EPA-WERL's estimates with a few adjustments to certain pollutants, including
those made to assure completely unacclimated volatilization rates. Table 4-3
EPA-WERL assumed a background concentration of benzene and toluene in
domestic sewage that they assumed lowered volatilization and raised
biodegradation in unacclimated systems. To assure completely unacclimated
volatilization rates, the rates for these two compounds were adjusted higher
based on the unacclimated volatilization rates of two chemically similar, but
less prevalent compounds, xylene.and ethylbenzene.
4-14
-------
TABLE 4-3. COMPARISON OF ESTIMATED PERCENT REMOVALS
WITH THOSE OBTAINED USING THE 40 POTU
STUDY DATA BASE
Percent Removals
Pollutant
Arsenic
Cadmi urn
Chlorobenzene
Chromium
1,2-Dichlorobenzene
Di chlorodi f1uoromethane
Ethyl benzene
Lead
Mercury
Methylene chloride
Nitrobenzene
Selenium
Silver
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Trichlorofluoromethane
Acrolein
Antimony
Benzene
Bis(2-chloroethyl) ether
Bis(2-chloroethoxy) methane
Bis(2-ethylhexyl) phthalate
Bromomethane
Butyl benzyl phthalate
Para-chloro-meta-cresol
Chloroethane
Chloroform
Chloromethane
2-chloronaphthalene
Cyanide
Di-n-butyl phthalate
1,3-Oichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethane
1,2-DiChloroethane
1 ,l-Di chloroethylene
1,2-Trans-dichloroethylene
2,4-Dichlorophenol
1,2-Dichloropropane
Diethyl phthalate
2,4-Dimethylphenol
Acclimated
50
27
90
70
90
95
95
90
50
95
90
50
90
90
95
95
95
95
95
-
95
90
10
90
95
95
95
95
90
95
95
90
90
90
90
90
90
95
90
95
90
90
95
UnaccT
Median
_
-
90
-
87
95
90
-
-
87
25
-
-
85
90
90
87
90
95
-
90
50
10
90
95
90
50
90
80
90
80
-
90
87
87
80
50
90
80
55
70
75
85
imated
Low
-
90
-
85
95
90
-
. -
85
20
-
-
80
90
85
85
85
95
-
90
30
10
90
95
90
40
90
80
90
80
-
90
85
85
80
30
90
80
50
70
70
80
40 POTW
* (93.9)
86.6
* (99.5)
78.9
91.6
* (80.3)
96.0
88.5
82.0
**
-
-
91.3
80.1
97.6
87,6
92.0
* (97.9)
-
* (71.5)
94.1
-
-
73.5
* (100)
98.7
* (96.7)
-
67.6
97.4
-
**
88.2
* (100)
* (94.9)
* (100)
* (55.4)
* (81.1)
92.8
-
* (100)
* (99.2)
-
4-15
-------
TABLE 4-2. COMPARISON OF ESTIMATED PERCENT REMOVALS
WITH THOSE OBTAINED USING THE 40 POTW
STUDY DATA BASE (Continued)
Percent Removals
Pollutant
Dimethyl phthalate
Di-N-octyl phthalate
Hexachloro-1,3-butadiene
Hexachloroethane
Naphthalene
Nickel
N-Nitrosodimethyl amine
Pentachlorophenol
Phenol
1,1,2,2-Tetrachloroethane
Tribromomethane
1,2,4-Trichlorobenzene
1,1,2-Trichloroethane
2,4,6-Trichlorophenol
Vinyl chloride
Acenaphthylene
Acrylonitrile
Anthracene
2-Chlorophenol
2,4-Dinitrophenol
Mdrin
Chlordane
Endrin
Toxaphene
Unaccliinated
Acclimated MedianCow
95
90
95
95
95
35
90
95
95
90
65
85
80
95
95
95
95
95
90
90
90
95
95
65
90
90
90
75
75
25
85
25
35
85
25
55
95
90
75
90
65
75
90
90
90
90
60
90
90
90
70
70
20
80
20
30
85
20
50
95
90
70
90
60
70
90
90
90
90
40 POTW
60,
96,
*
*
*
*
(100)
(100)
98.1
47.5
(93,8)
(90.5)
(96.6)
(98.6)
99.8
* (83.1)
* (91.2)
NOTE: *Fewer than five of the POTWs had a percent removal for this pollutant.
Percent removal based on fewer than five POTWs is indicated in
parentheses.
**Percent removals were deleted due to analytical difficulties.
4-16
-------
TABLE 4-3. ADJUSTMENTS TO EPA-WERL'S ESTIMATED VOLATILIZATION RATES
POLLUTANT
CUNENE
OLD VOLATILIZATION RATES
ACCLIMATED UNACCHMATED
NEM VOLATILIZATION RATES
ACCLIMATED UNACCLIMATED
40
90
40
60
REASON
LOHERED UNACCLIHATED RATE BASED ON
A HIGH KQM WHICH MOULD CAUSE IT TO
PARTITION TO THE SLUDGE RATHER THAN
VOLATILIZE.
4s.
t>
NETHANETHIOL
1,1,2,2 - TETRACHLOROETHANE 40
1,1.1.2 - TETRACHLOROETHANE 80
DICHLQROPROPANOL
TETRAHYDROFURAN
TETRACHLOROBENZENE
10
10
90
90
80
10
10
40
40
50
10
30
30
60
60
60
50
70
30
RAISED BOTH RATES BASED ON HENRY'S
LAH CONSTANT, KOM VALUE AND THE COM-
POUND'S SOLUBILITY. VALUES HERE CHOSEN
BASED ON THE COMPOUND'S SIMILARITY TO
METHYLENE CHLORIDE.
LOWERED UNACLINATED RATE BASED ON COM-
POUND'S HIGH KOU, LOU HENRY'S CONSTANT
AND LOU BIODEGRADABILITY.
LOWERED BOTH RATES BASED ON RELATIVELY
HIGHER HENRY'S CONSTANT THAN 1,1,2,2-
TETRACHLQROETHANE. ^
LOWERED UNACCLINATED RATE BASED ON LOW
HENRY'S CONSTANT AND KOW AND RAPID
BIODEGRADABILITY.
RAISED BOTH RATES BASED ON ITS SIMILAR-
ITY TO FURAN. HOWEVER, SINCE THIS
COMPOUND'S HENRY'S CONSTANT IS AN
ORDER OF MAGNITUDE LOWER, IT'S RATES
WERE ADJUSTED LOWER THAN FURAN.
RAISED BOTH RATES BASED ON ITS SIMILAR-
ITY TO 1,2,4 - TRICHLOROBENZENE.
HOWEVER, SINCE THIS COMPOUND'S HENRY'S
CONSTANT IS AN ORDER OF MAGNITUDE LOWER
IT'S RATES HERE ADJESTED LOWER THAN
1,2.3 - TRICHLOROBENZENE.
-------
TABLE 4-3. ADJUSTMENTS TO EPA-HERL'S ESTIMATED VOLATILIZATION RATES (Continued)
POLLUTANT
BENZENE
TOLUENE
OLD VOLATILIZATION RATES
ACCLIMATED UNACCLIMATED
25
25
50
40
HEN VOLATILIZATION RATES
ACCLIMATED UNACCLIMATED
25 80
25
80
REASON
RAISED UNACCLIMATED RATE TO REPRESENTATIVE
RATE FOR OTHER CHEMICALLY SIMILAR COMPOUNDS
TO ASSURE TRULY UMCCLIMATED CONDITIONS.
(SEE FOOTNOTE IN TEXT)
RAISED UNACCLINATED RATE TO REPRESENTATIVE
RATE TO REPRESENTATIVE RATE FOR OTHER
CHEMICALLY SIMILAR COMPOUNDS TO ASSURE
TRULY UNACCLINATED CONDITIONS. (SEE FOOT-
NOTE IN TEXT)
NOTE: FOR COMPOUNDS MISSING EIHTER ACCLIMATED OR UNACCLIMATED VOLATILIZATION RATES,
THE EXISTING VALUE HAS SUBSTITUTED FOR THE MISSING ONE.
-------
presents the pollutants whose volatilization rates were adjusted and the
reasoning behind each adjustment.
In general, EPA-WERL's volatilization rate estimates were guided by data
from three EPA-WERL research projects/6*11*12'13^ Experimental data for a
limited set of pollutants were extracted from these studies and were extrapo-
lated to the remainder of the DSS pollutants based on a combination of
physical/chemical properties (Henry's Law Constant and Octanol/Water Partition
Coefficients) and BPJ. These estimates account for volatilization in both the
primary and secondary treatment systems, but do not account for volatilization
in such preliminary treatment components as grit chambers and equalization
basins and therefore may underestimate overall treatment system volatiliza-
tion. Using other evaluation criteria, such as boiling point and solubility
as well as review 'Of the existing literature, many of EPA-WERL's estimated
volatilization rates were confirmed. However, all the studies mentioned above
have utilized closed reactors, which may not simulate actual open-tank acti-
vated sludge conditions. Using certain open-tank experimental volatilization
results from the same ongoing EPA-WERL project^11' and adjusting the aeration
rate to a value more typical for a full-scale activated sludge system yielded
volatilization rates significantly higher than those derived by EPA-WERL.
In addition, a number of pollutants that were considered volatile for the
purposes of selection for this study were assigned acclimated and unacclimated
volatilization rates of zero by EPA-WERL. Since EPA-WERL's estimates were BPJ
for most of the OSS pollutants, and since these compounds would in most cases
be considered volatile pollutants, a baseline volatilization rate of 5 percent
was assigned to these pollutants.
4.3.3 Analysis of Sludge Removal Rates Within POTW Treatment Systems
The estimated sludge partition rates for each of the DSS pollutants are
presented in Appendix Q. The general methodology used to derive these rates
was as follows;
Calculate mass balances for each priority pollutant for each POTW in
the 40 POTW Study data base
4-19
-------
Calculate the fraction of the mass removed which was partitioned to
the sludge for each priority pollutant for each POTW
Average the fraction partitioned for each priority pollutant across
all POTWs
Group the average partition rates by the eight Henry's Law Constant/
Partition Coefficient groupings shown in Table 4-4
Calculate an average partition rate for each of the eight Henry's Law
Constant/partition Coefficient groupings and extrapolate these group
averages to the DSS pollutants in each group with no individual sludge
partition rate.
Data were not available to determine acclimated and unacclimated sludge
partition factors.
Certain editing rules were utilized to calculate the fraction of the mass
of pollutant removed that was partitioned to the sludge because of the rela-
tively low influent concentrations of certain pollutants found in the 40 POTW
Study data base. In reviewing the mass balance calculations and comparing
them to the average concentration values, it was determined that the mass
balances being calculated for certain pollutants were based on extremely low
pollutant concentrations that were not considered accurate for the purposes of
illustrating removals. Therefore, an editing rule was established that
allowed only those mass balance calculations with an influent mass of at least
2.0 Ibs/day to be used to derive the fraction partitioned for each pollutant
at each POTW.
The eight Henry's Law Constant/partition Coefficient groups and the
ranges for the constants associated with each group were developed by EPA-WERL
as a useful way to make their BPJ estimates for overall percentage removal and
volatilization rates while still taking into account the general physical/
chemical properties of the pollutants. For the same reasons, these same
groupings were utilized to project the individual sludge partition rates
obtained from the 40 POTW Study data base to the remainder of the DSS pol-
lutants. An incidental check of these individual sludge partition rates was
performed as part of the evaluation of biodegradation rates with the results
discussed in the following section.
4-20
-------
TABLE 4-4. HENRY'S LAW CONSTANT/PARTITION COEFFICIENT GROUPINGS
USED TO EXTRAPOLATE AVERAGE PARTITION RATES
Grouping
LOW Kow/LOW HC
LOW Kow/MODERATE HC
LOW Kow/HIGH HC
MODERATE Kow/LOW HC
Average
partition
Coefficient
Range of Values for Grouping
Kow(<102);HC(<10~3 atm-m3/Mole) 0.10
Kow(<102);HC(>10~3-<10~2 atm-m3/Mole) 0.1395
Kow(<102);HC(>10"2 atm-m3/Mole) 0.0075
-3
Kow(>10 -10 );HC(<10 atm-nr/Mole)
MODERATE Kow/HIGH HC
HIGH Kow/LOW HC
Kow{>102-104);HC{>10"2 atm-m3/Mole)
Kow(>104);HC(<10~3 atm-m3/Mole)
HIGH Kow/MODERATE HC Kow(>104);HC{>_10"3-<10"2 atm-m3/Mole)
0.079
MODERATE Kow/MODERATE HC Kow(>102-104);HC(>_10"3-<10"2 atm-m3/Mole) 0.149
0.035
0.366
0.0895
4-21
-------
4.3.4 Evaluation of POTU Biodegradation Processes
Table 4-5 presents the estimated acclimated and unacclimated rates of
biodegradation for the DSS pollutants for which Individual sludge partition
rates could be calculated. The general methodology used to derive these
blodegradatlon rates was to assume that all removal of a pollutant occurs via
three possible removal mechanisms: (1) volatilization; (2) partition to the
sludge; and (3) biodegradation. Using this assumption, the estimated fraction
blodegraded would be equal to the removal remaining after the estimated
fraction volatilized and the estimated fraction partitioned to the sludge have
been subtracted from 100 percent (or 1.00). The estimated acclimated and
unacclimated biodegradation rates listed in Table 4-5 have been calculated in
this manner using the estimated acclimated and unacclimated volatilization
rates and the single partition rate listed for each pollutant.
The comparison of the estimated acclimated biodegradation rate to the
qualitative BPJ estimate of each pollutant's biodegradability in Table 4-5
(which was obtained from EPA-WERL) allows not only a relative check of the
calculated biodegradation rates, but also a method to evaluate the estimates
of the fraction partitioned to the sludge. In performing this total evalu-
ation, a total removal balance error of +25 percent (or 0.25) was considered
acceptable when the relative inaccuracy of the analytical and sampling methods
for sludge samples is taken into account. Based on this evaluation procedure,
the following DSS pollutants remain inconsistent with biodegradation
estimates:
1,1,2,2-Tetrachloroethane - Biodegradation is listed qualitatively as
slow, but the estimated biodegradation rate for acclimated systems is
56 percent. Original volatilization rate of 90 percent may be more
appropriate for this pollutant than current 40 percent/60 percent.
1,1,2-Tricnloroethane - Biodegradation is listed qualitatively as slow,
but the estimated biodegradation rate for acclimated systems is 50
percent. No competing removal mechanism, so qualitative estimate may
have to be revised.
Di-N-Octyl Phthalate - Biodegradation is listed qualitatively as
moderate, but the estimated biodegradation rate for acclimated systems Is
92 percent. Dominant removal mechanism should be partitioning based on
very high Kow, but 40 POTW Study data show only 8 percent. Sludge
partition rate probably should be revised.
4-22
-------
TABLE 4-5. SUMMARY TABLE OF ESTIMATED FRACTION REMOVED: STRIPPED, PARTITIONED AND BIPDEGRADED
FOR THOSE POLLUTANTS WITH INDIVIDUAL FRACTION PARTITIONED FIGURES
i
rs>
OJ
Acclimated
Fraction
Pollutant Removed
1,2-Dichloroethane
Phenol
Naphthalene
1,1,2, 2-Tet rachl oroethane
1,1,2-Trichloroethaje
Diethyl Phthalate
Dimethyl Phthalate
Pentachl orophenol
Bis(2-Ethylhexyl)
Phthalate
Butyl Benzyl Phthalate
Di-n-Butyl Phthalate
Di-n-Octyl Phthalate
Anthracene
1,1-Dichloroethane
Chloroform
Trans-l,2-Dichloro-
Ethylene
1 ,2-Di chl oropropane
Chi orobenzene
1 , 2-Di chl orobenzene
1 ,3-Di chl orobenzene
1 ,4-Di chl orobenzene
Ethyl benzene
To? uene
Tri chl oroethyl ene
Benzene
1, 2, 4-Tri chl orobenzene
Vinyl Chloride
Bromoethane
Carbon Tetrachloride
01 chlorodi fl uoromethane
let rachl oroethyl ene
1,1, 1-Trichl oroethane
1,1-DI chl oroethyl ene
Tri chl orof 1 uoromethane
0.90
0.95
0.95
0.90
0.80
0.90
0.95
0.95
0.90
0.95
0.90
0.90
0.95
0.90
0.90
0.90
0.90
0.90
0.90
0.90
0.90
0.95
0.95
0.95
0.95
0.85
0.95
0.95
0.90
0.95
0.90
0.95
0.95
0.95
. Unacclimated .
Fraction Accl imated
Removed Fraction
Median Low Stripped
0.50
0.85
0.75
0.25
0.25
0.75
0.65
0.25
0.90
0.90
0.90
0.90
0.90
0.80
0.80
0.80
0.70
0.90
0.87
0.87
0.87
0.90
0.90
0.87
0.90
0.85
0.95
0.95
0.85
0.95
0.85
0.90
0.90
0.90
0.30
0,80
0.70
0.20
0.20
0.70
0.60
0.20
0.90
0.90
0.90
0.90
0.90
0.80
0.80
0.80
0.70
0.90
0.85
0.85
0.85
0.90
0.90
0.85
0.90
0.85
0.95
0.95
0.80
0.95
0.80
0.86
0.90
0.85
0.50
0
0.30
0.40
0.50
0
0
0
0
0
0
0
0
0.70
0.70
0.70
0.50
0.30
0.50
0.50
0.50
0.25
0.25
0.70
0.25
0.50
0.90
0.90
0.80
0.95
0.50
0.80
0.80
0.80
Unaccl imated
Fraction
Stripped
0.90
0
0.30
0.60
0.80
0
0
0
0
0
0
0
0
0.90
0.90
0.90
0.90
0.50
0.90
0.90
0.90
0.80
0.80
0.80
0.80
0.60
0.95
0.95
0.90
0.95
0.80
0.90
0.90
0.90
Fraction ~
Partitioned
To Sludge
0.05
0.15
0.28
0.04
0.
0.01
0
0.18
0.73
0.45
0.22
0.08
0.55
0
0.02
0.54
0
0.15
0.35
0.03
0.25
0.06
0.28
0.06
0.02
0.09
0.02
0
0.13
0
0.03
0.01
0
0
3
Acclimated
Fraction
Biodegrade
0.45
0.85
0.42
0.56
0.50
0.99
1.00
0.82
0.27
0.55
0.78
0.92
0.45
0.30
0.28
0
0.50
0.55
0.15
0.47
0.25
0.69
0.47
0.24
0.74
0.41
0.08
0.10
0.07
0.05
0.47
0.19
O.i.0
0.20
-3
Unaccl Imated
Fraction
Biodegrade
0.05
0.85
0.42
0.36
0.20
0.99
1.00
0.82
0.27
0.55
0.78
0.92
0.45
0.10
0.08
0
0.10
0.35
0
0.07
0
0.14
0
0.14
0.18
0.31
0.03
0.05
0
0.05
0.17
0.09
0.10
0.10
Relative ,
Acclimated
Biodegradability
Moderate
Rapid
Moderate
Slow
Slow
Rapid
Rapid
Moderate
Moderate
Rapid
Rapid
Moderate
Moderate
Moderate
Moderate
Moderate
Slow
Moderate
Slow
Slow
Slow
Rapid
Rapid
Moderate
Moderate
Slow
Moderate
Moderate
Moderate
Moderate
Moderate
Rapid
Moderate
Moderate
Note: 1. From 9/26/85 Memo from D.F. Bishop to T,P. O'Farrell "Estimation of Removability and Impact of RCRA Toxics"
2. Calculated using the Final Report "Fate of Priority Pollutants in Publicly Owned Treatment Works, Volume I"
3. Calculated by difference.
-------
1,2-Trans-Dichloroethylene - Biodegradation is listed qualitatively as
moderate, but tne estimated biodegradation rate for acclimated systems is
0 percent based on a sludge partition rate of 54 percent which is much
too high given a Kow = 34. Sludge partition rate probably should be
revised.
Since the remaining DSS pollutants will have biodegradation rates that
have been calculated using the estimated sludge partition rates that were
extrapolated with the eight Henry's Law Constant/Partition Coefficient groups,
it would be expected that more inconsistencies between calculated biodegrada-
tion rates and the qualitative biodegradation estimates will exist for these
DSS pollutants than for those DSS pollutants with actual sludge partition
rates. However, time would not allow a pollutant-by-pol1utant assessment of
these extrapolated rates.
4.3.5 Evaluation of Pollutant Interference with POTW Treatment Systems
Available information for interference as a result of DSS pollutants can
be classified into two groups. The first group contains a qualitative
assessment of POTW plant upsets supplemented by specific citations of case
studies where OSS pollutants had inhibited conventional activated sludge
units. The AMSA survey cited in this study presents these case studies of
POTW upsets and inhibitions. The survey reveals that DSS pollutants, such as
pesticides and many organic solvents, have significant detrimental effects on
the operation of conventional activated sludge processes.
The second group of sources present data on POTW upset and inhibition
levels that are experimental but quantitative in nature. A review of the
available literature was conducted of EPA documents, engineering journals, and
scientific experiments, and expert consensus BPJ estimates were gathered to
summarize the available knowledge of certain OSS pollutants within typical
(conventional activated sludge) POTW treatment processes. Table 4-6 summa-
rizes a recent literature review effort for certain DSS organics, inorganics,
and metals. An estimation of the threshold inhibitory effect concentration
for each compound for activated sludge, anaerobic digestion, and nitrification
unit processes also Is presented. In general, inhibitory analysis done under
steady-state conditions can be affected greatly by slow specific growth rates
4-24
-------
TABLE 4-6. REPORTED VALUES FOR BIOLOGICAL PROCESS TOLERANCE LIMITS
OF ORGANIC PRIORITY POLLUTANTS
Pollutant
Acenaphthene
Acrolein
Acrylomtrili
Beniene
Benitdine
Carbon TetrtchJorid*
Chloro benzene
1. 2,4-Trichloro benzene
Hexachloro benzene
1.2-Dichloroethane
1.1,1'Trichiorottham
Hexachloroethane
1,1'Dichioroethane
1.1.2-TrichJoroeihane
1 ,1,2.2-Tetncnloroethane
iiM2-Chiorotthyl) EtKer
2-Chloroethyl Vinyl Ether
:-ChIoronapnthalene
2.4,6-Trichlotophenol
par a Oloro-ww-cie »i
Chloroform
^Chloro phenol
1 ,2-Dichiorobenzene
l.3-Dichlorobenzene
1,4-Dichloro benzene
1 . t -Dtchiot oethylene
1 . 2-iranj-Dichloroethylene
2. 4-Dichloro phenol
l.i-DichlotoptopiJM
1.3-DicrUoropwpylene
:.4*Dimethylph*nol
2>Duwrotoluene
2.6-Dinitrotoluen*
\ ,2-DiphenylhydzuiM
EthylbctuiM
Ruofanihent
6ii-<2-ChlotoiJopropyD Ethet
Methytoiw Chloride
Chlorametham
Biomoform
Dichiorobromomethane
Ttichioro Quo rom ethane
Chlorodibtomomethane
Hexichiorobuudiene
Hcxachlorocyclopentadiene
Iiophoront
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2.4-Dimtrophenol
Activated
Sludie
Thctihold of Inhibitory Effect
Anaerobic
Digestion N itriflcation
mi/ 1* Reference m|;l* Reference mi/L* Reference
Nlb« 10
Nl at 62
NI itlS2
125
5
NI at 10
NI at 1
NI at 6
5
NI at 258
NI it 10
NI at :0
NI it 10
NI it 5
Nl at 201
NI at tO
NI at 10
Nl at 10
SO
NI it 10
NI at 10
NI at 10
5
S
5
Nl at 10
NI at 10
Nl Jl 75
NI at 182
NI at 10
Nl at 10
5
5
5
NI at 10
NI at 5
NI at 10
NI at 180
Nl at 10
Nl at 10
NI at 10
Nl at 10
NI at 10
NI at 10
NI at 15.4
500
500
NI at 10
Nl it 10
1
I
2
2 5 3
4
5 5 3
1 2.9 6
7 O.We 8
1
1
2 1 3
1
1
1
2 20 9
t
1
I
to
1
1 1 LI 10 3
I
1 0.23C S
. 1
t t.4c 8
1
1
2
2
t
1
1
1
1
I
1
t
100 3
2 3.3 6
1
I
1 0.7 3
I
1
I
12
13
13
1
1
t 150 3
4-25
-------
TABLE 4-6.
REPORTED VALUES FOR BIOLOGICAL PROCESS TOLERANCE LIMITS
OF ORGANIC PRIORITY POLLUTANTS (Continued)
TaMt I.
Threshold of Inhibitory Effect
Activated
Sludft
Anaerobic
Dl|t»ton
Nitrification
Pollutant
Reiennct m|/l* Refennci m»l* Reference
N*Nitrotodiph«iyluniM
N>Nitrow-di-N*prQpyUmim
Ptnuchloroplwiot
Fhtnol
WM2-Ethyl H«yl) FhUubtt
Butyl Bmzyl PhthaUn
DM-bmyL Fhtlulau
DkN-octyi Phthalit*
Dieihyl PhUialata
Dimtthyt Phthalatt
ChryMM
Aciiuptithytew
Anthncnt
Fluortnt
Phananthinw
Pyicnt
Tftiachlorotihyliiw
Tohiant
Tnchlorotthyl««
ArodoM242
Aioeloi*1254
Aroclor-1221
AIOclo^t232
Aioctoi'lOlfi
NI « 10
NI u 10
0.95
200
NI it 10
NI a 10
NI At 10
NI it 16.3
NI It 10
NI at 10
NI at 5
NI at 10
300
NI at 10
300
NI at 3
NI at 10
NI al 33
NI at 10
NI u 1
NI at I
NI at 1
NI u 10
NI at 1
1
1
7 0.2 14
13.16 4 3
1
I
1
12
1
1
I
1
13
1
13
1
1 20 3
12
1 20 3,9
17
17
17
I
17
*Unl«i othcrwiM indicand.
NI no inhibition at mud coOMntntioiu. No conccntntion a luted if reference lacked concentration
data.
cft wt/wt dry lotids.
4-26
-------
TABLE 4-6. REPORTED VALUES FOR BIOLOGICAL PROCESS TOLERANCE LIMITS
OF ORGANIC PRIORITY POLLUTANTS (Continued)
Potluuat
ThitihoWof Inhibitory Effect
Activtnd
Sludp
*n«tobic
OiiMtion
NttrtAcattot
ratfl*
Amnfc
Cftdmtim
Chfomtum
-------
for the activated sludge biomass along with substrate levels and the effec-
tiveness of the POTW's equalization to provide the necessary dilution to
prevent inhibition. Also, a biomass acclimated to a toxic substrate is still
subject to inhibition by that substrate, and hence the POTW should be designed
or modified to react to variations in flow rate and substrate concentration.
4,3,6 Estimating the Risk Posed by the Migration of Selected Contaminants
from POTW Surface Impoundments to Drfnk'ing Water Wells
An attempt was made to estimate the potential risk posed by the migration
of selected OSS pollutants from POTW surface impoundments to drinking water
wells using EPA's Toxic Location Model. This model had been used previously
to evaluate the risks posed to a population served by a drinking water well
located 600 meters downgradient from a leaking impoundment. Although qualita-
tive results were obtained fop four DSS pollutants through the use of the
Toxic Location Model, it was thought that more useful quantitative information
on migration of pollutants from leaking POTW surface impoundments will be
obtained from an ongoing EPA-OMPC study authorized under Section 3018(c) of
the RCRA amendments. The results of this ongoing study will be incorporated
into the final version of this report when and if they become available.
4.4 SUMMARY OF POLLUTANT FATE UZTHIN POTW COLLECTION AND TREATMENT SYSTEM
Table 4-7 presents the estimated loadings of OSS pollutants that are
being discharged to receiving waters based on acclimated and unacclimated
treatment system peformance.
Table 4-8 presents the estimated air emissions for DSS pollutants based
on acclimated and unacclimated treatment system performance. Table 4-8
includes estimated air emissions for those DSS Tier l, 2, and 2A pollutants
designated as volatile (which EPA-WERL assigned 0 percent volatilization
factors), assuming a baseline volatilization rate of 0.5 percent for accli-
mated systems and 5 percent for unacclimated systems. It should be noted that
unacclimated air emission loadings should be higher than those loadings
calculated for acclimated systems. However, due to the decrease in overall
removals going from acclimated to unacclimated systems, the total air emission
loadings do not reflect this trend and the adjustment of the unacclimated
4-28
-------
TABLE 4-7. LOADINGS TO SURFACE HATERS BASED ON POTU PASS THROUGH ANALYSIS
i
no
IO
Pollutant
Acetone
Arsenic
Barium
N-Butyl Alcohol
Cadmium
Carbon Disulflde
Carbon Tetrachloride
Chiorobenzene
Chromium
Cresols
Cyclohexanone
1,2-01chlorobenzene
Dichlorodi f1uoromethane
Ethyl Acetate
Ethyl Benzene
Ethyl Ether
Isobutanol
Lead
Mercury
Nethanol
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methylene Chloride
Nitrobenzene
Pyrldine
Selenium
Silver
Tetrachloroethylene
Toluene
1,1,1-Trlchloroethane
Trichloroethylene
Trichlorof1uoromethane
1.1,2-TC 1,2,2-TF Ethane
Xylenes
Acetaldehyde
Acetonecyanohyd ri n
Acetophenone
Acetyl Chloride
Acrolein
Aniline
Antimony
Benzene
p-Benzoquinone
Benzyl Chloride
Loading
Qb/yr)
8,317,227
66,575
0
17,440
189,856
0
225,086
687 ,835
4,660,026
0
1,282,984
377,071
0
188,860
4,802,939
0
0
3,449,009
42,439
31,717,755
4,081
3,632,156
12,087,478
128,085
50,021
142,577
130,587
3,321,221
8,291,692
8,652,375
3,803,526
1,198
0
15,207,171
4,545
0
0
0
1,648,576
5,811,272
221,685
4,099,249
0
230,338
Loading
-------
TABLE 4-7. LOADINGS TO SURFACE HATERS BASED ON POTH PASS THROUGH ANALYSIS (Continued)
i
GO
o
Pollutant
Bis-2-Chloroethoxy Methane
Bis-2-Chloroethyl Ether
Bis-2-Ethylhexyl Phthalate
Bromomethane
Butyl Benzyl Phthalate
p-Chloro-m-Cresol
Chloroethane
Chloroform
Chloromethane
2-Chloronaphthal ene
Cunene
Cyanide
Cyclohexane
Di-N-Butyl Phthalate
1,3-Dichlorobenzene
1,4-D1chlorobenzene
1,1-01 chloroethane
1,2-Dichloroethane
1,1 -01 chloroethylene
Trans-l,2-D1chloroethylene
2,4-01chlorophenol
1,2-Dichloropropane
Dlchloropropanol
Diethyl Phthalate
Dlmethylamlne
2,4-Dlmethyl phenol
Dimethyl Phthalate
Di-N-Octyl Phthalate
1,4-Dloxane
Dlphenyl Amine
Eplchlorohydrln
Ethylene Oxide
Formaldehyde
Formic Add
Furan
Furfural
Hexachloro-l,3-Butad1ene
Hexachloroethane
Hydrazine
Naphthalene
Nickel
2-N1tropropane
Loading
(Ib/yr)
23
3,480
2,660,146
813
1,613,930
82,918
15,173
4,189,128
27,230
1,481
174,573
3,165,294
0
85,332
7,471
583,874
29,666
302.706
33.224
4,456
17,453
209 .097
0
62,783
92,802
1.739,434
12,864
20,544
8,508
0
0
0
12,557,020
3,192,711
48,443
8,890,104 .
0
183
4,317
2.020,647
3,320,226
0
Loading
(kg/yr)
10
1,582
1,209.157
370
733,605
37,690
6,897
1,904.149
12,377
673
79,351
1,438,770
0
38,787
3.396
265,397
13,485
137,594
15,102
2,025
7,933
95,044
0
28,538
42,183
790,652
5,847
9,338
3,867
0
0
0
5,707,736
1,451,232
22,020
4,040,956
0
83
1,962
918,476
1,509,194
0
Acclimated
90%
10%
10%
5%
5%
5%
5%
10%
5%
5%
5%
40%
5%
10%
10%
10%
10%
10%
5%
10%
5%
10%
10%
10%
5%
5%
5%
10%
10%
10%
13%
10%
15%
10%
10%
10%
5%
5%
5%
5%
65%
5%
Unaccllmated
Range
Median
{%)
90%
50%
10%
5%
10%
50%
10%
20%
10%
20%
5%
40%
5%
10%
13%
13%
20%
50%
10%
20%
45%
30%
50%
25%
10%
15%
35%
10%
50%
35%
41%
50%
15%
10%
30%
40%
10%
10%
15%
25%
65%
5%
Low
_(%j_
90%
70%
10%
5%
10%
60%
10%
20%
10%
20%
5%
40%
5%
10%
15%
15%
20%
70%
10%
20%
50%
30%
70%
30%
10%
20%
40%
10%
60%
40%
75%
60%
20%
10%
30%
50%
10%
10%
20%
30%
65%
5%
Acclimated
Loading
(kg/yr)
9
158
120,916
18
36,680
1,885
345
190,415
619
34
3,968
575 ,508
0
3,879
340
26,540
1,348
13,759
755
203
397
9,504
0
2,854
2,109
39.533
292
934
387
0
0
0
856.160
145.123
2.202
404,096
0
4
98
45,924
980,976
0
Unaccllmated
Loading
Median
Ckg/yjrj
9
791
120,916
18
73,360
18,845
690
380 ,830
1,238
135
3.968
575,508
0
3,879
441
34,502
2.697
68,797
1,510
405
3,570
28,513
0
7.134
4,218
118,598
2,047
934
1,934
0
0
0
856,160
145,123
6,606
1,616,383
0
8
294
229.619
980,976
0
Low
(kg/yr)
9
1,107
120,916
18
73,360
22,614
690
380,830
1,238
135
3,968
575,508
0
3,879
509
39,810
2,697
96,316
1,510
405
3,967
28,513
0
8,561
4,218
158,130
2,339
934
2,320
0
0
0
1,141,547
145,123
6,606
2,020,478
0
8
392 v
275,543
980,976
0
-------
TABLE 4-7. LOADINGS TO SURFACE WATERS BASED ON POTH PASS THROUGH ANALYSIS (Continued)
Pollutant
N-N1trosod1methyl Amine
PCB
Pentachloroethane
Pentachlorophenol
Phenol
Phenylene Diamine
2-Picoline
Resorcinol
Tetrachlorobenzene
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrahydrofuran
Thiourea
Thlram
Tribromomethane
1,2,4-Tr i ch1oroben zene
1,1,2-Trlchloroethane
2,4,6-Trlchlorophenol
1,2,3-Trichloropropane
Vinyl Chloride
Acenaphthylene
Acrylamide
Acrylic Acid
Acrylonltrlle
Anthracene
Benzal Chloride
Benzotrichlorlde
2-Chlorophenol
Dibromomethane
3,3-Dimethoxy Benzldine
2,4-Dinitrophenol
Ethylene Thiourea
Mai elc Hydrazide
Methanethiol
p-Nitroaniline
Phosgene
PhthaMc Anhydride
Styrene
Toluene Diamine
Vanadium Pentoxide
Alachlor
Aldlcarb
Loading
(Ib/yr)
1,208
1,781
0
184,321
23,674,543
0
0
0
0
0
2,545
3,834,468
0
0
27
27,469
278,167
107,546
0
40,140
0
6,612
29
3,282,951
1,445,651
16,868
3,545
21,730
69,727
2,596
1,461,989
0
0
125
127,103
0
4,081
0
5,988
905
0
0
Loading
(kg/yr)
549
810
0
83,782
10,761,156
0
0
0
0
0
1,157
1,742,940
0
0
12
12,486
126,440
48,885
0
18,245
0
3,005
13
1,492,250
661,660
7,667
1,611
9,877
31,694
1,180
664,540
0
0
57
57,774
0
1,855
0
2,722
411
0
0
Acclimated
10%
8%
5%
5%
5%
10%
20%
5%
10%
5%
10%
5%
10%
10%
35%
15%
20%
5%
25%
5%
5%
10%
10%
10%
5%
10%
10%
5%
15%
20%
10%
15%
10%
5%
10%
0%
10%
10%
10%
75%
10%
10%
Unacclimated
Range
Median
_(%_)_
25%
8%
25%
75%
15%
25%
85%
25%
10%
10%
75%
25%
25%
25%
65%
15%
75%
45%
75%
5%
10%
38%
15%
25%
10%
45%
55%
35%
20%
70%
25%
33%
25%
23%
31%
0%
10%
10%
25%
75%
50%
50%
Low
(%)
30%
8%
30%
80%
20%
30%
90%
30%
10%
10%
80%
30%
30%
30%
70%
15%
80%
50%
80%
5%
10%
50%
20%
30%
10%
50%
60%
40%
20%
80%
30%
40%
30%
30%
40%
0%
10%
10%
30%
75%
70%
70%
Acclimated
Loading
(kg/yr)
55
65
0
4,189
538,058
0
0
0
0
0
116
87,147
0
0
4
1,873
25,288
2,444
0
912
0
301
1
149,225
33,083
767
161
494
4,754
236
66,454
0
0
3
5,777
0
186
0
272
309
0
0
Unacclimated
Loading
Median
(kg/yr) ^
137
65
0
62,837
1,614,173 2,
0
0
0
0
0
868
435,735
0
0
8
1,873
94,830
21,998
0
912
0
1,142
2
373,063
66,166
3,450
886
3,457
6,339
826
166,135
0
0
13
17,910
0
186
0
680
309
0
0
Low
kg/yr)
165
65
0
67,026
152,231
0
0
0
0
0
925
522,882
0
0
9
1,873
101,152
24,442
0
912
0
1,503
3
447,675
66,166
3,834
967
3,951
6,339
944
199,362
0
0
17
23,110
0
186
0
817
309
0
0
-------
TABLE 4-7. LOADINGS TO SURFACE WATERS BASED ON POTW PASS THROUGH ANALYSIS (Continued)
OJ
no
Pollutant
Aldrin
Antu
Atrazine
Bromacil
Captan
Carbofuran
Chlordane
Chlorobenzilate
2,4-D
2,4-DB
Diazlnon
Dichlorvos
Dlcofol
Dinoseb
Dlphenamid
Disulfolton
Dluron
Endrfn
FenthIon
Ferbam
Folex
HCPA
Methoxychlor
Hevinphos
Naled
Napthai am
Oxamyl
Parathion
Parathlon Methyl
Phorate
Pyrethn'ns
Sodium Fluoroacetate
Stlrofos
2,4,5-T
Toxaphene
Trlfluralln
Loading
(Ib/yr)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Acclimated
10%
10%
10%
10%
10%
10%
10%
10%
10%
10%
10%
10%
10%
10%
5%
10%
5%
5%
20%
10%
10%
5%
10%
10%
20%
10%
10%
100%
10%
10%
20%
5%
15%
10%
5%
10%
Unacclimated
Range
Median
(%)
10%
50%
65%
50%
50%
50%
10%
40%
40%
40%
40%
50%
10%
60%
40%
40%
50%
10%
45%
45%
40%
50%
10%
50%
50%
60%
50%
45%
45%
40%
40%
50%
40%
50%
10%
10%
Low
M
10%
70%
70%
70%
70%
70%
10%
50%
50%
50%
50%
70%
10%
70%
50%
50%
60%
10%
60%
60%
50%
60%
10%
70%
70%
70%
70%
60%
60%
50%
50%
70%
50%
60%
10%
10%
Acclimated
Loading
(kg/yr)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Unacclimated
Loading
Median Low
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
SUM 203,283,104 92,401,411
7,817,807 16,990,470 20,460,697
-------
TABLE 4-8. LOADINGS TO AIR BASED ON POTU AIR EMISSIONS ANALYSIS
i
CO
CO
Pollutant
Acetone
Arsenic
Barium
N-Butyl Alcohol
Cadmi urn
Carbon Bisulfide
Carbon Tetrachloride
Chiorobenzene
Chromium
Cresols
Cyclohexanone
1,2-Dichlorobenzene
01chlorodi f1uoromethane
Ethyl Acetate
Ethyl Benzene
Ethyl Ether
Isobutanol
Lead
Mercury
Methanol
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methylene Chloride
Nitrobenzene
Pyridlne
Selenium
Silver
Tet rachloroethy1ene
Toluene
1,1,1-Trichloroethane
Trlchloroethylene
Trlchlorofluoromethane
1,1,2-TC 1,2,2-TF Ethane
Xylenes
Acetaldehyde
Acetonecyanohydrln
Acetophenone
Acetyl Chloride
Acrolein
Aniline
Antimony
Benzene
p-Benzoquinone
Benzyl Chloride
Un ace 11 mated
Loading
(Ib/yr)
8,317,227
66,575
0
17,440
189,856
0
225,086
687,835
4,660,026
0
1,282,984
377,071
0
188,860
4,802,939
0
0
3,449,009
42,439
31,717,755
4,081
3,632,156
12,087,478
128,085
50,021
142,577
130,587
3,321,221
8,291,692
8,652,375
3,803,526
1,198
0
15,207,171
4,545
0
0
0
1,648,576
5,811,272
221,685
4,099,249
0
230,338
Loading
(kg/yr)
3,780,558
30,261
0
7,927
86,298
0
102,312
312,652
2,118,194
0
583,175
171,396
0
85,845
2,183,154
0
0
1,567,731
19,290
14,417,161
1,855
1,650,980
5,494,308
58,220
22.737
64,808
59,358
1,509,646
3,768,951
3,932,898
1,728,875
545
0
6,912,350
2,066
0
0
0
749,353
2,641,487
100,766
1,863,295
0
104,699
Acclimated
Removal
(X)
95.0%
50.0%
90.0%
95.0%
27.0%
95.0%
90.0%
90.0%
70.0%
95.0%
85.0%
90.0%
95.0%
95.0%
95.0%
95.0%
95.0%
70.0%
50.0%
100.0%
95.0%
90.0%
95.0%
90.0%
15.0%
50.0%
90.0%
90.0%
90.0%
95.0%
95.0%
95.0%
90.0%
95.0%
95.0%
90.0%
80.0%
95.0%
95.0%
95.0%
60.0%
95.0%
95.0%
90.0%
Removal
Median
(%)
50%
50%
90%
90%
27%
85%
85%
90%
70%
50%
50%
87%
95%
90%
90%
50%
90%
70%
50%
95%
50%
50%
87%
25%
15%
50%
90%
85%
90%
90%
87%
90%
85%
87%
95%
50%
50%
50%
95%
85%
60%
90%
50%
90%
Low
1*1
30%
50%
90%
90%
27%
80%
80%
90%
70%
40%
30%
85%
95%
90%
90%
30%
90%
70%
50%
95%
30%
30%
85%
20%
10%
50%
90%
80%
90%
85%
85%
85%
80%
85%
95%
30%
30%
30%
95%
80%
60%
90%
40%
90%
Rel eased
To Air
(%)
0.5%
0.0%
0.0%
0.0%
0.0%
80.0%
80.0%
30.0%
0.0%
0.0%
0.0%
50.0%
95.0%
0.5%
25.0%
10.0%
0.0%
0.0%
0.5%
0.5%
0.5%
0.0%
40.0%
0.0%
0.5%
0.0%
0.0%
50.0%
25.0%
80.0%
70.0%
80.0%
70.0%
25.0%
0.5%
0.0%
0.5%
0.5%
0.5%
0.0%
0.0%
25.0%
0.0%
25.0%
Unacclimated
Release
Median
(%)
5%
0%
0%
0%
0%
90%
90%
50%
0%
0%
0%
90%
95%
5%
80%
40%
0%
0%
5%
5%
5%
0%
60%
0%
5%
0%
0%
80%
80%
90%
80%
90%
80%
80%
5%
0%
5%
5%
5%
0%
0%
80%
0%
50%
Low
M
5%
0%
0%
0%
0%
90%
90%
50%
0%
0%
0%
90%
95%
5%
80%
40%
0%
0%
5%
5%
5%
0%
60%
0%
5X
0%
0%
80%
80%
90%
80%
90%
80%
80%
5%
0%
5%
5%
5%
0%
0%
80%
0%
50%
Acclimated
Loading
(kg/yr)
17,958
0
0
0
0
0
73,665
84,416
0
0
0
77,128
0
408
518,499
0
0
0
48
72,086
9
0
2,087;837
0
17
0
0
679,341
895,126
2,989,002
1,149,702
414
0
1,641,683
10
0
0
0
3.559
0
0
442,533
0
23.557
Unacclimated
Loading
Median
(kg/yr)
94,524
0
0
0
0
0
78,269
140,694
0
0
0
134,203
0
3,863
1,571,871
0
0
0
482
684,815
46
0
2,868,029
0
171
0
0
1,026,559
2,713,645
3,185,647
1,203,297
441
0
4,810,996
98
0
0
0
35,594
0
0
1,341,572
0
47,115
Low
(kg/yr)
56,708
0
0
0
0
0
73,665
140,694
0
0
0
131,118
0
3,863
1,571,871
0
0
0
482
684,815
28
0
2,802,097
0
114
0
0
966,173
2,713,645
3,008,667
1,175,635
417
0
4,700,398
98
0
0
0
35,594
0
0
1,341,572
0
47,115
-------
TABLE 4-8. LOADINGS TO AIR BASED ON POTU AIR EMISSIONS ANALYSIS (Continued)
Pollutant
Bis-2-Chloroethoxy Methane
B1s-2-Chloroethyl Ether
B1s-2-Ethylhexyl Phthalate
Bromomethane
Butyl Benzyl Phthalate
p-Chloro-m-Cresol
Chloroethane
Chloroform
Chloromethane
2-Chloronaphthalene
Cumene
Cyanide
Cyclohexane
D1-N-Butyl Phthalate
1,3-Dlchlorobenzene
1,4-01chlorobenzene
1,1-Dlchloroethane
1,2-Oichloroethane
l,l-D1chloroethylene
Trans-l.2-D1chloroethylene
2,4-Dlchlorophenol
1,2-Dlchloropropane
Dlchloropropanol
Dlethyl Phthalate
Dimethylamlne
2,4-Dinethyl Phenol
Dimethyl Phthalate
Di-N-Octyl Phthalate
1,4-Dloxane
Diphenyl Amine
Eplchlorohydrin
Ethylene Oxide
Formaldehyde
Formic Add
Furan
Furfural
Hexachloro-l,3-Butadiene
Hexachloroethane
Hydrazine
Naphthalene
Nickel
2-N1tropropane
N-N1trosod1methyl Amine
PCB
Unacclimated
Loading
(Ib/yr)
23
3,480
2,660,146
813
1,613,930
82,918
15,713
4,189,128
27,230
. 1,481
174,573
3.165,294
0
85,332
7,471
583,874
29,666
302,706
33,224
4.456
17.453
209.097
0
62.783
92,802
1,739,434
12,864
20.544
8,508
0
0
0
12,557,020
3,192,711
48.443
8,890,104
0
183
4,317
2.020,647
3,320,226
0
1.208
1,781
Loading
jkg/yr)
10
1,582
1,209,157
370
733,605
37,690
6,897
1,904,149
12,377
673
79,351
1,438,770
0
38,787
3,396
265,397
13,485
137,594
15,102
2,025
7,933
95.044
0
28,538
42,183
790,652
5,847
9,338
3,867
0
0
0
5,707,736
1,451,232
22,020
4,040,956
0
83
1,962
918,476
1,509,194
0
549
810
Acclimated
Removal
(%)
10.0%
90.0%
90.0%
95.0%
95.0%
95.0%
95.0%
90.0%
95.0%
95.0%
95.0%
60.0%
95.0%
90.0%
90.0%
90.0%
90.0%
90.0%
95.0%
90.0%
95.0%
90.0%
90.0%
90.0%
95.0%
95.0%
95.0%
90.0%
90.0%
90.0%
87.0%
90.0%
85.0%
90.0%
90.0%
90.0%
95.0%
95.0%
95.0%
95.0%
35.0%
95.0%
90.0%
92.0%
Removal
Median
(%)
10%
50%
90%
95%
90%
50%
90%
80%
90%
80%
95%
60%
95%
90%
87%
87%
80%
50%
90%
80%
55%
70%
50%
75%
90%
85%
65%
90%
50%
65%
59%
50%
85%
90%
70%
60%
90%
90%
85%
75%
35%
95%
75%
92%
Low
_(%_)_
10%
30%
90%
95%
90%
40%
90%
80%
90%
80%
95%
60%
95%
90%
85%
85%
80%
30%
90%
80%
50%
70%
30%
70%
90%
80%
60%
90%
40%
60%
25%
40%
80%
90%
70%
50%
90%
90%
80%
70%
35%
95%
70%
92%
Released
To A1r
(%)
0.0%
0.5%
0.0%
90.0%
0.0%
0.0%
80.0%
70.0%
90.0%
0.5%
40.0%
0.5%
10.0%
0.0%
50.0%
50.0%
70.0%
50.0%
80.0%
70.0%
0.0%
50.0%
10.0%
0.0%
0.5%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.5%
0.5%
0.5%
0.5%
0.5%
0.5%
0.5%
0.5%
0.5%
0.0%
90.0%
0.0%
10.0%
Unacclimated
Release
Median
C%L
0%
5%
0%
95%
0%
0%
90%
90%
95%
5%
60%
5%
90%
0%
90%
90%
90%
90%
90%
90%
0%
90%
50%
0%
5%
0%
0%
0%
0%
0%
0%
5%
5%
5%
5%
5%
5%
5%
5%
5%
0%
95%
0%
10%
LOW
1*1
0%
5%
0%
95%
0%
0%
90%
90%
95%
5%
60%
5%
90%
0%
90%
90%
90%
90%
90%
90%
0%
90%
50%
0%
5%
0%
0%
0%
0%
0%
0%
5%
5%
5%
5%
5%
5%
5%
5%
5%
0%
95%
0%
10%
Acclimated
Loading
(kg/yr)
0
7
0
316
0
0
5,242
1,199,614
10,583
3
30,154
4,316
0
0
1.528
119,429
8,495
61,917
11.477
1,276
0
42,770
0
0
200
0
0
0
0
0
0
0
24,258
6,531
99
18,184
0
0
9
4,363
0
0
0
74
Unacclimated
Loading
Median
(kg/yr)
0
40
0
334
0
0
5,586
1,370,987
10,583
27
45,230
43,163
0
0
2,659
207 .806
9,709
61,917
12,232
1,458
0
59,878
0
0
1,898
0
0
0
0
0
0
0
242,579
65,305
771
121.229
0
4
83
34,443
0
0
0
74
Low
Ikg/yr)
0
24
0
334
0
0
5,586
1,370,987
10.583
27
45.230
43.163
0
0
2,598
203.029
9,709
37,150
12,232
1,458
0
59,878
0
0
1,898
0
0
0
0
0
0
0
228,309
65,305
771
101,024
0
4
78
32,147
0
0
0
74
-------
TABLE 4-8. LOADINGS TO AIR BASED ON POTU AIR EMISSIONS ANALYSIS (Continued)
I
CJ
Ul
Pol 1utant
Pentachloroethane
Pentachlorophenol
Phenol
Phenylene Diamine
2-Picoline
Resorcinol
Tetrachlorobenzene
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrahydrofuran
Thlourea
Thiram
Trlbromometahne
1,2,4-Tri chlorobenzene
1,1,2-Trichloroethane
2,4,6-Tr1chlorophenol
1,2,3-Tri chloropropane
Vinyl Chloride
Acenaphthylene
Acrylamide
Acrylic Acid
Acrylonitrile
Anthracene
Benzal Chloride
Benzotrlchloride
2-Chlorophenol
Dibromomethane
3,3-Dimethoxy benzidine
2,4-Dinitrophenol
Ethylene Thiourea
Maleic Hydrazide
Methanethiol
p-Nitroanil1ne
Phosgene
Phthalic Anhydride
Styrene
Toluene Diamine
Vanadium Pentoxide
Alachlor
Aldicarb
Aldn'n
Antu
Atrazine
Bromacil
Unacclimated
Loading
(Ib/yr)
0
184,321
23,674,543
0
0
0
0
0
2,545
3,834,468
0
0
27
27 ,469
278,167
107.546
0
40,140
0
6,612
29
3,282,951
1,455,651
16,868
3,545
21,730
69,727
2,596
1,461,989
0
0
125
127,103
0
4,081
0
5,988
905
0
0
0
0
0
0
Loading
(kg/yr)
0
83,782
10,761,156
0
0
0
0
0
1,157
1,742,940
0
0
12
12,486
126,440
48,885
0
18,245
0
3,005
13
1,492,250
661,660
7,667
1,611
9,877
31.694
1,180
664,540
0
0
57
57,774
0
1,855
0
2,722
411
0
0
0
0
0
Q
Accl f mated
Removal
(%)
95.0%
95.0%
95.0%
90.0%
80.0%
95.0%
90.0%
95.0%
90.0%
95.0%
90.0%
90.0%
65.0%
85.0%
80.0%
95.0%
75.0%
95.0%
95.0%
90.0%
90.0%
90.0%
95.0%
90.0%
90.0%
95.0%
85.0%
80.0%
90.0%
85.0% '
90.0%
95.0%
90.0%
100.0%
90.0%
90.0%
90.0%
25.0%
90.0%
90.0%
90.0%
90.0%
90.0%
90.0%
Removal
Median
(%)
75%
25%
85%
75%
15%
75%
90%
90%
25%
75%
75%
75%
35%
85%
25%
55%
25%
95%
90%
62%
85%
75%
90%
55%
45%
65%
80%
30%
75%
67%
75%
77%
69%
100%
90%
90%
75%
25%
50%
50%
90%
50%
35%
50%
Low
1*1
70%
20%
80%
70%
10%
70%
90%
90%
20%
70%
70%
70%
30%
85%
20%
50%
20%
95%
90%
50%
80%
70%
90%
50%
40%
60%
80%
20%
70%
60%
70%
70%
60%
100%
90%
90%
70%
25%
30%
30%
90%
30%
30%
30%
Released
To Air
(%)
60.0%
0.0%
0.0%
0.0%
0.5%
0.0%
30.0%
50.0%
40.0%
30.0%
0.0%
0.0%
55.0%
50.0%
50.0%
0.0%
40.0%
90.0%
20.0%
0.0%
0.0%
0.5%
0.0%
0.0%
20.0%
0.0%
50.0%
0.0%
0.0%
0.0%
0.0%
40.0%
0.0%
0.5%
0.0%
25.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
Unaccl i mated
Release
Median
__(_*)-
60%
0%
0%
0%
5%
0%
30%
70%
60%
70%
0%
0%
60%
60%
80%
0%
70%
95%
60%
0%
0%
5%
0%
30%
30%
0%
80%
0%
0%
0%
0%
60%
0%
5%
0%
80%
0%
0%
0%
0%
0%
0%
0%
0%
Low
m
60%
0%
0%
0%
5%
0%
30%
70%
60%
70%
0%
0%
60%
60%
80%
0%
70%
95%
60%
0%
0%
5%
0%
30%
30%
0%
80%
0%
0%
0%
0%
60%
0%
5%
0%
80%
0%
0%
0%
0%
0%
0%
0%
0%
Acclimated
Loading
(kg/yr)
0
0
0
0
0
0
0
0
416
496,738
0
0
4
5,307
50,576
0
0
15,600
0
0
0
6,715
0
0
290
0
13,470
0
0
0
0
22
0
0
0
0
0
0
0
0
0
0
0
0
Unaccl i ma ted
Loading
Median
(kg/yr)
0
0
0
0
0
0
0
0
174
915,043
0
0
3
6,368
25,288
0
0
16,467
0
0
0
55,959
0
1,265
218
0
20,284
0
0
0
0
26
0
0
0
0
0
0
0
0
0
0
0
0
LOW
(kg/yr)
0
0
0
0
0
0
0
0
139
854,041
0
0
2
6,368
20,230
0
0
16 ,467
0
0
0
52,229
0
1,150
193
0
20,284
0
0
0
0
24
0
0
0
0
0
0
0
0
0
0
0
0
-------
TABLE 4-8. LOADINGS TO AIR BASED ON POTH AIR EMISSIONS ANALYSIS (Continued)
I
CO
CTt
Pollutant
Captan
Carbofuran
Chlordane
Chiorobenzllate
2,4-D
2,4-DB
D1az1non
Dlchlorvos
Ofcofol
Dinoseb
Dlphenamid
Dlsulfoton
01uron
Endrin
Fenthlon
Ferbam
Folex
MCPA
Methoxychlor
Mcvinphos
Naled
Napthalam
Qxamyt
ParathIon
Parathlon Methyl
Ptiorate
Pyrethrlns
Sodium Fluoroacetate
Stlrofos
2,4,5-T
Toxaphene
Trifluralin
UnaccHmated
Loading
(Ib/yr)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Loading
(fcg/yrl
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Acclimated
Removal
(%)
90.0*
90.0%
90.0%
90.0%
90.0%
90.0%
90.0%
90.0%
90.0%
90.0%
95.0%
90.0%
95.0%
95.0%
80.0%
90.0%
90.0%
95.0%
90.0%
90.0%
80.0%
90.0%
90.0%
0.0%
90.0%
90.0%
80.0%
95.0%
85.0%
90.0%
95.0%
90.0%
Removal
Median
{%)
50%
50%
90%
60%
60%
60%
60%
50%
90%
40%
60%
60%
50%
90%
55%
55%
60%
50%
90%
50%
50%
40%
50%
55%
55%
60%
60%
50%
60%
50%
90%
90%
Low
ill
30%
30%
90%
50%
50%
50%
50%
30%
90%
30%
50%
50%
40%
90%
40%
40%
50%
40%
90%
30%
30%
30%
30%
40%
40%
50%
50%
30%
50%
40%
90%
90%
Released
To Air
(«) .
0.0%
0.0%
10.0%
10.0%
0.0%
0.0%
0.0%
0.0%
50.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
60.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
60.0%
0.0%
UnaccHmated
Release
Median
(%)
0%
0%
10%
10%
0%
0%
0%
0%
50%
0%
0%
0%
0%
0%
0%
0%
0%
0%
60%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
80%
0%
Low
M
0%.
0%
10%
10%
0%
0%
0%
0%
50%
0%
0%
0%
0%
0%
0%
0%
0%
0%
60%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
80%
0%
Acclimated
Loading
(kg/yr)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Unaccllmated
Loading
Median Low
(kg/yr)
SUM 203,283,104 92,401,411
12,896,981 23,281,011 22,657,495
-------
volatilization fractions to correct these loadings could not be performed at
this time.
Table 4-9 presents the estimated loadings of DSS pollutants that are
expected to partition to the sludge. Due to the extrapolation of the average
partition fractions from the eight Henry's Law Constant/Partition Coefficient
groups to those DSS pollutants that do not have actual partition fractions,
higher or lower loadings to the sludge may be predicted for certain pollutants
than may occur for actual National loadings. This problem is discussed
further in Chapter 5.
4-37
-------
TABLE 4-9. LOADINGS TO SLUDGE BASED ON POTU SLUDGE PARTITIONING ANALYSIS
-P.
i
CJ
CO
Pollutant
Acetone
Arsenic
Barium
N-Butyl Alcohol
Cadmlurn
Carbon D1sulf1de
Carbon Tetrachloride
Chlorobenzene
Chromium
Cresols
Cyclohexane
1,2-Dichlorobenzene
Di chlorod 1 f1uoromethane
Ethyl Acetate
Ethyl Benzene
Ethyl Ether
Isobutanol
Lead
Mercury
Hethanol
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methylene Chloride
Nitrobenzene
Pyridine
Selenium
Silver
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
Trlchloroethylene
Trichlorofluoromethane
1,1,2-TC 1,2,2-TF Ethane
Xylenes
Acetaldehyde
Acetonecyanohydrin
Acetophenone
Acetyl Chloride
Acroleln
An 111ne
Antimony
Benzene
p-Benzoquinone
Benzyl Chloride
Unaccl imated
Loading
(Ib/yr)
8,317,227
66,575
0
17 ,440
189,856
0
225.086
687 ,835
4,660,026
0
1,282,984
377,071
0
188,860
4,802,939
0
0
3,449,009
42,439
31,717,755
4,081
3,632,156
12,087,478
128,085
50,021
142,577
130,587
3,321,221
8,291,692
8,652,375
3,803,526
1,198
0
15,207,171
4.545
0
0
0
1,648.576
5,811,272
221,685
4,099,249
0
230.338
Loading
jjtg/y_r)
3,780,558
30,261
0
7,927
86,298
0
102,312
312,652
2,118,194
0
583,175
171,396
0
85.845
2,183,154
0
0
1,567,731
19,290
14,417,161
1,855
1,650,980
5,494,308
58,220
22,737
64,808
59,358
1,509,646
3.768,951
3,932.898
1,728.875
545
0
6,912,350
2,066
0
0
0
749,353
2,641,487
100,766
1,863,295
0
104 ,699
Accl imated
Removal
(%)
95.0%
50.0%
90.0%
95.0%
27.0%
95.0%
90.0%
90.0%
70.0%
95.0%
85.0%
90.0%
95.0%
95.0%
95.0%
95.0%
95.0%
70.0%
50.0%
100.0%
95.0%
90.0%
95.0%
90.0%
15.0%
50.0%
90.0%
90.0%
95.0%
95.0%
95.0%
95.0%
90.0%
95.0%
95.0%
90.0%
80.0%
95.0%
95.0%
95.0%
60.0%
95.0%
95.0%
90.0%
Removal
Median
(%)
50%
50%
90%
90%
27%
85%
85%
90%
70%
50%
50%
87%
95%
90%
90%
50%
90%
70%
50%
95%
50%
50%
87%
25%
15%
50%
90%
85%
90%
90%
87%
90%
85%
87%
95%
50%
50%
50%
95%
85%
60%
90%
50%
90%
Low
M
30%
50%
90%
90%
27%
80%
80%
90%
70%
40%
'30%
85%
95% .
90%
90%
30%
90%
70%
50%
95%
30%
30%
85%
20%
10%
50%
90%
80%
90%
85%
85%
85%
80%
85%
95%
30%
30%
30%
95%
80%
60%
90%
40%
90%
Transfer
To Sludge
(%)
10%
100%
100%
10%
100%
1%
13%
15%
100%
8%
10%
35%
0%
10%
6%
10%
10%
100%
95%
10%
10%
10%
14%
10%
10%
100%
100%
3%
28%
1%
6%
0%
4%
15%
10%
10%
10%
10%
10%
10%
100%
2%
8%
8%
Unaccl Imated
Transfer
Median
(%)
10%
100%
100%
10%
100%
1%
10%
15%
100%
8%
10%
10%
0%
10%
6%
10%
10%
100%
95%
10%
10%
10%
14%
10%
10%
100%
100%
3%
20%
1%
6%
0%
4%
15%
10%
10%
10%
10%
10%
10%
100%
2%
8%
8%
Low
(%J
10%
100%
100%
10%
100%
1%
10%
15%
100%
8%
10%
10%
0%
10%
6%
10%
10%
100%
95%
10%
10%
10%
14%
10%
10%
100%
100%
3%
20%
1%
6%
0%
4%
15%
10%
10%
10%
10%
10%
10%
100%
2%
8%
8%
Acclimated
Loading
(kg/yr)
359,153
15.131
0
753
23,301
0
11,970
42,208
1,482,736
0
49,570
53,990
0
8,155
124,440
0
0
1,097,412
9,163
1,441,716
176
148 ,588
730,743
5,240
341
32,404
53,422
40,760
1,002,541
37 ,363
98.546
0
0
985,010
196
0
0
0
71,189
250,941
60,460
35,403
0
7.538
Unaccl imated
Loading
Med1 an
(kg/yr)
189,028
15.131
0
713
23.301
0
8,697
42.208
1,482.736
0
29,159
14,911
0
7,726
117,890
0
0
1,097,412
9,163
1,369,630
93
82,549
669,207
1,456
341
32,404
53,422
38,496
678,411
35,396
90,247
0
0
902,062
196
0
0
0
71,189
224,526
60,460
33,539
0
7,538
Low
(kg/yr)
113,417
15,131
0
713
23,301
0
8,185
42,208
1,482,736
0
17,459
14,569
0
7,726
117,890
0
0
1,097,412
9,163
1,369.630
56
49 ,529
653,823
1,164
227
32,404
53,422
36,232
678,411
33,430
88,173
0
0
881,325
196
0
0
0
71,189
211,319
60.460
33,539
0
7,538
-------
TABLE 4-9. LOADINGS TO SLUDGE BASED ON POTH SLUDGE PARTITIONING ANALYSIS (Continued)
Pollutant
B1s-2-Chloroethoxy Methane
Bis-2-Chloroethyl Ether
Bis-2-Ethylhexyl Phthalate
Bromomethane
Butyl Benzyl Phthalate
p-Chloro-m-Cresol
Chloroethane
Chloroform
Chloromethane
2-Chloronaphthalene
Cumene
Cyanide
Cyclohexane
Di-N-Butyl Phthalate
1,3-Dichlorobenzene
1,4-Oi chlorobenzene
1,1-Dichloroethane
l,2-D1chloroethane
1,1-01chloroethylene
Trans-1,2-Di chloroethylene
2,4-DIchlorophenol
1,2-Dichloropropane
Dichloropropanol
01 ethyl Phthalate
Dimethylamine
2,4-Dimethyl Phenol
Dimethyl Phthalate
Di-N-Octyl Phthalate
1,4-01oxane
Oiphenyl Amlne
Epichloronydrin
Ethylene Oxide
Formaldehyde
Formic Acid
Furan
Furfural
Hexachloro-l,3-Butadiene
Hexachloroethane
Hydrazine
Naphthalene
Nickel
2-Nitropropane
N-Nitrosodimethyl Amine
PCB
Pentachloroethane
Unacclimated
Loading
(Ib/yr)
23
3,480
2,660,146
813
1,613,930
82,918
15,173
4,189,128
27,230
1,481
174,573
3,165,294
0
85,332
7,471
583,874
29 ,666
302,706
33,224
4,456
17,453
209,097
0
62,783
92,802
1,739,434
12,864
20,544
8,508
0
0
0
12,557,020
3,192,711
48,443
8,890,104
0
183
4,317
2,020,647
3,320,226
0
1,208
1,781
0
Loading
[kg/yr)
10
1,582
1,209,157
370
733,605
37 ,690
6,897
1,904,149
12,377
673
79,351
1,438,770
0
38,787
3,396
265,397
13,485
137,594
15,102
2,025
7,933
95,044
0
28,538
42,183
790,652
5,847
9,338
3,867
0
0
0
5,707,736
1,451,232
22,020
4,040,956
0
83
1,962
918,476
1,509,194
0
549
810
0
Acclimated
Removal
(%)
10.0%
90.0%
90.0%
95.0%
95.0%
95.0%
95.0%
90.0%
95.0%
95.0%
95.0%
60.0%
95.0%
90.0%
90.0%
90.0%
90.0%
90.0%
95.0%
90.0%
95.0%
90.0%
90.0%
90.0%
95.0%
95.0%
95.0%
90.0%
90.0%
90.0%
87.0%
90.0%
85.0%
90.0%
90.0%
90.0%
95.0%
95.0%
95.0%
95.0%
35.0%
95.0%
90.0%
92.0%
95.0%
Removal
Median
_(%_)_.
10%
50%
90%
95%
90%
50%
90%
80%
90%
80%
95%
60%
95%
90%
87%
87%
80%
50%
90%
80%
55%
70%
50%
75%
90%
85%
65%
90%
50%
65%
59%
50%
85%
90%
70%
60%
90%
90%
85%
75%
35%
95%
75%
92%
75%
Low
Hi
10%
30%
90%
95%
90%
40%
90%
80%
90%
80%
95%
60%
95%
90%
85%
85%
80%
30%
90%
80%
50%
70%
30%
70%
90%
80%
60%
90%
40%
60%
25%
40%
80%
90%
70%
50%
90%
90%
80%
70%
35%
95%
70%
92%
70%
Transfer
To Sludge
(%)
10%
10%
73%
0%
45%
8%
1%
2%
1%
37%
4%
95%
4%
22%
3%
25%
0%
5%
0%
30%
8%
0%
10%
1%
10%
8%
0%
8%
10%
8%
10%
10%
10%
10%
14%
10%
9%
9%
10%
28%
100%
1%
10%
24%
15%
Unacclimated
Transfer
Median
(%)
10%
10%
73%
0%
45%
8%
1%
2%
1%
37%
4%
95%
4%
22%
3%
10%
0%
5%
0%
10%
8%
0%
10%
1%
10%
8%
0%
8%
10%
8%
10%
10%
10%
10%
14%
10%
9%
9%
10%
28%
100%
1%
10%
24%
15%
Low
Hi
10%
10%
73%
0%
45%
8%
1%
2%
1%
37%
4%
95%
4%
22%
3%
10%
0%
5%
0%
10%
8%
0%
10%
1%
10%
8%
0%
8%
10%
8%
10%
10%
10%
10%
14%
10%
9%
9%
10%
28%
100%
1%
10%
24%
15%
Acclimated
Loading
(kg/yr)
0
142
794,416
0
313,616
2,864
66
34,275
118
237
3,015
820,099
0
7,680
92
59,714
0
6,192
0
547
603
0
0
257
4,007
60,090
0
672
348
0
0
0
485,158
130,611
2,774
363,686
0
7
186
244,315
528,218
0
49
179
0
Unacclimated
Loading
Median
jkg/yr)
0
79
794,416
0
297,110
1,508
62
30,466
111
199
3,015
820,099
0
7,680
89
23,090
0
3,440
0
162
349
0
0
214
3,796
53,764
0
672
193
0
0
0
485,158
130,611
2,158
242,457
0
7
167
192,880
528,218
0
41
179
0
Low
jkg/yr)
0
47
794,416
0
297,110
1,206
62
30,466
111
199
3,015
820,099
0
7,680
87
22,559
0
2,064
0
162
317
0
0
200
3,796
50,602
0
672
155
0
0
0
456,619
130,611
2,158
202,048
0
7
157
180,021
528,218
0
38
179
0
-------
TABLE 4-9. LOADINGS TO SLUDGE BASED ON POTU SLUDGE PARTITIONING ANALYSIS (Continued)
Pollutant
Pentachlorophenol
Phenol
Phenylene Dlamine
2-P1coline
Resorcinol
Tetrachlorobenzene
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrahydrofuran
Thlourea
Thi ram
Tribromomethane
1,2,4-Trichlorobenzene
1,1,2-Trichloroethane
2,4,6-Tr1chlorophenol
1,2,3-Tr1chloropropane
Vinyl Chloride
Acenaphthylene
Acrylamide
Acrylic Acid
Acrylonltrlle
Anthracene
Benzal Chloride
Benzotrlchloride
2-Chlorophenol
Dibromometnane
3,3-D1methoxy benzldlne
2,4-Dinltrophenol
Ethylene Thlourea
Maleic Hydrazide
Methanethlol
p-N1troan111ne
Phosgene
PhthaUc anhydride
Styrene
Toluene Dlamine
Vanadium Pentoxlde
Alachlor
Aldlcarb
Aldrln
Antu
Atrazlne
Bromadl
Captan
Carbofuran
Unaccl 1 ma ted
Loading
Qb/yr)
184,321
23,674,543
0
0
0
0
0
2,545
3,834,468
0
0
27
27,469
278,167
107 ,546
0
40,140
0
6.612
29
3,282,951
1,455,651
16,868
3,545
21,730
69,727
2,596
1,461,989
0
0
125
127,103
0
4,081
0
5,988
905
0
0
0
0
0
0
0
0
Loading
(kg/yr)
83,782
10,761,156
0
0
0
0
0
1,157
1,742,940
0
0
12
12,486
126,440
48,885
0
18,245
0
3,005
13
1,492,250
661,660
7,667
1,611
9,877
31,694
1,180
664,540
0
0
57
57,774
0
1,855
0
2,722
411
0
0
0
0
0
0
0
0
Acclimated
Removal
(%)
95.0%
95.0%
90.0%
80.0%
95.0%
90.0%
95.0%
90.0%
95.0%
90.0%
90.0%
65.0%
85.0%
80.0%
95.0%
75.0%
95.0%
95.0%
90.0%
90.0%
90.0%
95.0%
90.0%
90.0%
95.0%
85.0%
80.0%
90.0%
85.0%
90.0%
95.0%
90.0%
100.0%
90.0%
90.0%
90.0%
25.0%
90.0%
90.0%
90.0%
90.0%
90.0%
90.0%
90.0%
90.0%
Removal
Median
(%)
25%
85%
75%
15%
75%
90%
90%
25%
75%
75%
75%
35%
85%
25%
55%
25%
95%
90%
62%
85%
75%
90%
55%
45%
65%
80%
30%
75%
67%
75%
77%
69%
100%
90%
90%
75%
25%
50%
50%
90%
50%
35%
50%
50%
50%
Low
M
20%
80%
70%
10%
70%
90%
90%
20%
70%
70%
70%
30%
85%
20%
50%
20%
95%
90%
50%
80%
70%
90%
50%
40%
60%
80%
20%
70%
60%
70%
70%
60%
100%
90%
90%
70%
25%
30%
30%
90%
30%
30%
30%
30%
30%
Transfer
To Sludge
(%)
18%
15%
10%
10%
10%
37%
4%
4%
10%
10%
10%
8%
9%
0%
8%
8%
2%
9%
10%
10%
10%
55%
8%
8%
8%
15%
10%
10%
10%
10%
10%
10%
10%
10%
15%
10%
10%
8%
10%
37%
10%
8%
10%
8%
10%
Unaccl imated
Transfer
Median
{%)
18%
15%
10%
10%
10%
37%
4%
4%
10%
10%
10%
8%
9%
0%
8%
8%
2%
9%
10%
10%
10%
55%
8%
8%
8%
15%
10%
10%
10%
10%
10%
10%
10%
10%
15%
10%
10%
8%
10%
37%
10%
8%
10%
8%
10%
Low
M
18%
15%
10%
10%
10%
37%
4%
4%
10%
10%
10%
8%
9%
0%
8%
8%
2%
9%
10%
10%
10%
55%
8%
8%
8%
15%
10%
10%
10%
10%
10%
10%
10%
10%
15%
10%
10%
8%
10%
37%
10%
8%
10%
8%
10%
Acclimated
Loading
(kg/yr)
14,327
1,533,465
0
0
0
0
0
42
165,579
0
0
1
955
0
3,715
0
347
0
270
1
134,303
345,717
552
116
751
4,041
94
59,809
0
0
5
5,200
0
167
0
245
10
0
0
0
0
0
0
0
0
Unaccl imated
Loading
Median
(kg/yr)
3,770
1,372,047
0
0
0
0
0
12
130,721
0
0
0
955
0
2,151
0
347
0
186
1
111,919
327,521
337
58
514
3,803
35
49,841
0
0
4
3,986
0
167
0
204
10
0
0
0
0
0
0
0
0
Low
(kg/yr)
3,016
1,291,339
0
0
0
0
0
9
122,006
0
0
0
955
0
1,955
0
347
0
150
1
104,458
327,521
307
52
474
3,803
24
46,518
0
0
4
3.466
0
167
0
191
10
0
0
0
0
0
0
0
0
-------
TABU 4-9. LOADINGS TO SLUDGE BASED ON POTN SLUDGE PARTITIONING ANALYSIS (Continued)
i
-p*
Pollutant
Chlordane
Chlorobenzllate
2,4-D
2,4-DB
Diazinon
Dichlorvos
Dicofol
Dinoseb
Diphenamid
Dlsulfolton
Dluron
Endrin
Fenthion
Ferbam
Folex
MCPA
Methoxychlor
Mevlnphos
Haled
Napthalam
Oxamyl
Parathion
Parathion Methyl
Phorate
Pyrethrlns
Sodium Fluoroacetate
St1rofos
2,4,5-T
Toxaphene
Trifluralin
Loading
(Ib/yr)
Loading
Unacclimated
Accl imated
Removal
(%)
90.0%
90.0%
90.0%
90.0%
90.0%
90.0%
90.0%
90.0%
95.0%
90.0%
95.0%
95.0%
80.0%
90.0%
90.0%
95.0%
90.0%
90.0%
80.0%
90.0%
90.0%
0.0%
90.0%
90.0%
80.0%
95.0%
85.0%
90.0%
95.0%
90.0%
Removal
Median
(%)
90%
60%
60%
60%
60%
50%
90%
40%
- 60%
60%
50%
90%
55%
55%
60%
50%
90%
50%
50%
40%
50%
55%
55%
60%
60%
50%
60%
50%
90%
90%
Low
M
90%
50%
50%
50%
50%
30%
90%
30%
50%
50%
40%
90%
40%
40%
50%
40%
90%
30%
30%
30%
30%
40%
40%
50%
50%
30%
50%
40%
90%
90%
Unacclimated
Transfer
To Sludge
(%)
37%
8%
8%
8%
8%
10%
9%
8%
ov
0%
HI
ot>
8%
37%
8%
&°t
o*
8%
8%
9%
10%
10%
10%
10%
8%
8%
8%
8%
10%
8%
8%
4%
37%
Transfer
Median
(*)
37%
8%
8%
8%
8%
10%
9%
8%
8%
8%
8%
37%
8%
8%
8%
8%
9%
10%
10%
10%
10%
8%
8%
8%
8%
10%
8%
4%
37%
Low
M
37%
8%
8%
8%
8%
10%
9%
8%
8%
8%
8%
37%
1W
Oft
0.1
Ok
fV9
O*
8%
9%
10%
10%
10%
10%
8%
8%
8%
8%
10%
8%
8%
4%
37%
Acclimated
Loading
(kg/yr)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Unacclimated
Loading
Median Low
(kg/yr) (kg/yr)
SUM 203,283,104 92.401,411
14,414,502 13,020,218 12,653,867
-------
-------
CHAPTER 5
EFFECTS OF DISCHARGES OF
DOMESTIC SEWAGE STUDY
POLLUTANTS TO POTWs
-------
-------
5. EFFECTS OF DISCHARGES OF DOMESTIC SEWAGE STUDY POLLUTANTS TO POTWS
5.1 INTRODUCTION
The purpose of this chapter is to document the potential for environ-
mental effects that result from the discharge, emission, and/or leaching of
DSS pollutants that are received for treatment by POTWs. Given that POTW and
EPA influent and effluent sampling efforts normally have been limited to the
126 priority pollutants identified under the NPDES program, this chapter's
documentation of potential effects has been limited largely to those priority
pollutants.
In lieu of being able to draw an exact cause-effect relationship among
discharge, emission, and leaching of DSS pollutants and environmental effects
(a difficult task even with complete data), an analysis was conducted of
potential effects on environmental media based on projected loadings» pol-
lutant characteristics, projected criteria exceedances, and related case
studies. A summary of the approach and the limitations in using this approach
are described below.
5.1.1 National Estimates of DSS Pollutant Releases
Based on the analyses discussed in Chapters 3 and 4 of this study, Table
5-1 was produced, which shows the expected National loadings of DSS pollutants
(except pesticides) to water, air, and sludge. (Pesticide loadings numbers
are not included in this table due to the proprietary nature of the data.)
The table was produced by using the current discharge loadings that were
generated in the Chapter 3 industry assessment. With the exception of three
metals, if a discrepancy in loadings existed between the ISDB and ITD data
base, the higher of the two values was selected for use in Table 5-1. Influ-
ent loadings appear in the left column of the table. The difference between
the influent loadings and the three media for organic chemicals was assumed to
result from biodegradable pollutants. Loadings to each medium were calculated
for three separate scenarios: acclimated loadings, median estimated unac-
climated loadings, and low estimated unacclimated loadings. As an example,
roughly 1.9 million kg/year of chloroform are received at POTWs, and the
unacclimated median loadings to the receiving media are approximately 381,000
5-1
-------
TABLE 5-1. LOADINGS OF DSS POLLUTANTS TO POTW AND RESULTANT RECEIVING ENVIRONMENTS
LOADINGS TO RECEIVING WATERS LOADINGS TO AIR LOADINGS TO SLUDGE
en
i
Pol 1 utartt
Acetone
Arsenic
Barium
N-Butyl Alcohol
Cadmium
Carbon Disulfide
Carbon Tetrachloride
Chlorobenzene
Chromium
Cresols
Cyclohexanone
1,2-Ui Chlorobenzene
Di chl orodi f 1 uoromethane
Ethyl Acetate
Ethyl Benzene
Ethyl Ether
Isobutanol
Lead
Mercury
Methanol
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methylene Chloride
Nitrobenzene
Pyridine
Selenium
Silver
Tet rachl oroethyl ene
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Trichl orof 1 uoromethane
1,1,Z-TC 1.2,2-TF Ethane
Xylenes
Acetaldehyde
Acetomecyanohydrin
Acetophenone
Acetyl Chloride
Acrolein
Aniline
Antimony
Benzene
p-Benzoquirione
Benzyl Chloride
Estimated
National
Loading
(kg/yr)
3,780,558
30,261
N.A.*
7,927
86,298
N.A.
102,312
312,652
2,118,194
N.A.
583,175
171,396
0
85,845
2,183,154
N.A.
N.A.
1,567,731
19,290
14,417,161
1,855
1,650,980
5,494,308
58,220
22,737
64,808
59,358
1,509,646
3,768,951
3,932,898
1,728,875
545
N.A.
6,912,350
2.066
N.A.
N.A.
N.A.
749,353
2.641,487
100,766
1,863,295
N.A.
104,699
Acclimated
Loading
< kg/yr)
189,028
15,131
396
62,998
10.231
31,265
635,458
87,476
17,140
0
4,292
109,158
470.319
9.645
0
93
165,098
274.715
5,822
19,236
32,404
5,936
150,965
188,448
196,645
86.444
27
345.618
103
37,468
132,074
40.306
93.165
10,470
Unacclimated Loading
Medl an Low
(kg/yr) (kg/yr)
1,890,279
15,131
793
62,998
15,347
31,265
635,458
291,587
22,281
0
8,585
218,315
470,319
9.645
720,858
928
825,490
714,260
43,665
19,326
32,404
5,936
226,447
376,895
393,290
224,754
54
898,606
103
37,468
396,223
40,306
186,330
10,470
2,646,390
15,131
793
62,998
20,462
31,265
635,458
408,222
25,709
0
8,585
218,315
470,319
9,645
720,858
1,299
1,155.686
824,146
46,576
20,463
32,404
5,936
301,929
376,895
589,935
259,331
82
1,036,853
103
3;, 468
528,297
40,306
1»6,330
10,470
Accl imated
Loading
(kg/yr)
17,958
0
0
0
73,665
84,416
0
0
77,128
0
408
518,499
0
48
72.086
9
0
2,087,837
0
17
0
0
679,341
895,126
2,989,002
1,149,702
414
1,641,683
10
3,559
0
0
442,533
23,557
Unacclimated
Median
(kg/yr)
94,514
0
0
0
78,269
140., 694
0
* 0
134,203
; 0
3,863
1,571,871 1
0
482
684,815
46
0
2,868,029 2
0
171
0
0
1,026,559
2,713,645 2
3,185,647 3
1,203,297 1
441
4.180,996 4
98
35,594
0
0
1,341,572 1
47,115
Loading
Low
(kg/yr)
56,708
0
0
0
73,665
140,694
0
0
131,118
0
3,863
,571,871
0
482
684,815
28
0
.802,097
0
114
0
0
966,173
,713.645
,008,667
,175,635
417
,700,398
98
35,594
0
0
.341,572
47,115
Acclimated
Loading
(ky/yr)
359,153
15,131
753
23,301
11,970
' 42,208
1,482,736
49,570
53,990
0
8,155
124,440
1,097.412
9,163
1,441,716
176
148,588
730,743
5,240
341
32,404
53,422
40,760
1,002,541
37,363
98,546
0
985,010
196
71,189
250,941
60,460
35,403
7,538
Unacclimated
Median
(kg/yr)
189,028
15,131
713
23.3U1
8,697
42,208
1,482,736 1,
29,159
14,911
0
7,726
117,890
1,097,412 1,
9,163
1,369,630 1,
93
82,549
669,207
1,456
341
32,404
53,422
38,496
678,411
35,396
90,247
0
902,062
196
71,189
224,526
60,460
33,539
7,538
Loading
Low
(kg/yr)
113,417
15,131
713
23,301
8,185
42.20B
482,736
17,495
14,569
0
7,726
117,890
097.412
9,163
369,630
56
49,529
653,823
1.164
227
32,404
53,422
36,232
678,411
33,430
88,173
0
881,325
196
71.189
211,319
60,460
33,539
7,538
*N.A. - Data Not Available.
-------
TABLE 5-1. LOADINGS OF DSS POLLUTANTS TO POTW AND RESULTANT RECEIVING ENVIRONMENTS (Continued)
LOADINGS TO RECEIVING WATERS
LOADINGS TO AIR
LOADINGS TO SLUDGE
Pollutant
Bis-2-Chloroethoxy Methane
Bis-2-Chloroethyl Ether
Bis-2-Ethylhexyl Phthalate
Bromomethane
Butyl Benzyl Phthalate
p-Chloro-m-Cresol
Chtorethane
Chloroform
Chloromethane
2-Chl oronapthal ene
Cumene
Cyanide
Cyclohexane
Di-N-Butyl Phthalate
1,3-Dichlorbenzene
1,4-Dichlorbenzene
1,1-Dichlorethane
1,2-Dichlorethane
1,1-Dichlorethylene
Trans- 1,2-Dichlorethyl ene
2,4-Dichlorophenol
1 ,2-Dichloropropane
Dichloropropanol
Diethyl Phthalate
Dimethylamine
2,4-Dimethyl Phenol
Dimethyl Phthalate
Di-N-Octyl Phthalate
1,4-Dioxane
Diphenyl Amine
Epichlorophydrin
Ethyl ene Oxide
Formaldehyde
Formic Acid
Furan
Furfural
Hexachlor-l,3-Butadiene
Hexachl oroethane
Hydra zine
Napthalene
Nickel
2-Nitropropane
N-Nitrosodimethyl Amine
PC8
Load t ng
(kg/yr)
0
0
1,209,157
370
733,605
37,690
6,897
1,904,144
14,167
24
79,351
1,439,410
0
38,787
3,396
265,397
13,485
137,933
15,530
2,025
12,838
95,044
0
28,538
42,183
790,652
5,847
9,338
3,757
0
0
0
5,707,736
1,451,232
22,020
4,040,956
0
0
1,869
918,476
1,431,256
0
549
293
Accl imated
Loading
(kg/yr)
0
0
120,916
18
36 ,680
1,885
345
190,414
708
1
3,968
143,941
0
3,879
340
26,540
1,348
13,793
776
203
642
9,504
0
2,854
2,109
39,533
292
934
376
0
0
0
856,160
145,123
2,202
404,096
0
0
93
45,924
930,317
0
55
23
Onaccl
Med i an
(ky/yr)
0
0
120,916
18
73,360
18,845
690
380,829
1,417
5
3,968
143,941
0
3,879
441
34,502
2,697
68,966
1,553
405
5,777
28,513
0
7,134
4,218
118,598
2,047
934
879
0
0
0
856,160
145,123
6,606
1,616,383
0
0
280
229,619
930,317
0
137
23
imated Release
Low
(kg/yr)
0
0
120,916
18
73,360
22,614
690
380,829
1,417
5
3,968
143,941
0
3,879
509
39,810
2,697
96,553
1,553
405
6,419
28,513
0
8,561
4,218
158,130
2,339
934
2,254
0
0
0
1,141,547
145,123
6,606
2,020,478
0
0
374
275,543
930,317
0
165
23
Accl imated
Load ing
(ky/yr)
0
0
0
316
0
0
5,242
1,199,610
12,113
1
30,154
0
0
0
1,528
119,429
8,495
62,070
11,802
1,276
0
42,770
0
0
2,004
0
0
0
0
0
0
0
242,579
65,305
991
181,843
0
0
89
43,628
0
0
0
27
Unaccl imated
Median
(kg/yr)
0
0
0
334
0
0
5,586
1,370,983 1
12,113
1
45,230
0
0
0
2,659
207,806
9,709
62,070
12,579
1,458
0
59,878
0
0
1,898
0
0
0
0
0
0
0
242,579
65,305
771
121,229
0
0
79
34,443
0
0
0
27
Loading
Low
(ky/yr)
0
0
0
334
0
0
5,586
,370,983
12,113
1
45,230
0
0
0
2,598
203,029
9,709
37,242
12,579
1,458
0
59,878
0
0
1,898
0
0
0
0
0
0
0
228,309
65,305
111
101,024
0
0
75
32,147
0
0
0
27
Accl imated
Loading
(ky/yr)
0
0
444,546
0
287,252
0
66
14,142
135
8
3,015
1,295,469
0
100
11
57,470
0
868
0
135
816
0
0
12
4,007
56,890
0
0
338
0
0
0
485,158
130,611
2,774
363,686
0
0
178
194,713
bOO,939
0
0
65
Unaccl imated
Median
(ky/yr)
0
0
444,546
0
272,133
0
62
12,571
128
7
3,015
1,295,469 1,
0
100
11
55,554
0
482
0
120
472
0
0
10
3,796
50,901
0
0
188
0
0
0
485,158
130,611
2,158
242,457
0
0
159
153,721
500,939
0
0
65
Loading
Low
(kg/yr)
0
0
444,546
0
272,133
0
62
12,571
128
7
3,015
295,469
0
100
11
54,277
0
289
0
120
430
0
0
9
3,796
47,907
0
0
150
0
0
0
456,619
130,611
2,158
202,048
0
0
150
143,473
500,939
0
0
65
-------
TABLE 5-1. LOADINGS OF DSS POLLUTANTS TO POTH AND RESULTANT RECEIVING ENVIRONMENTS (Continued)
LOADINGS TO RECEIVING WATERS
LOADINGS TO AIR
LOADINGS TO SLUDGE
Pollutant
Pentachlorethane
Pentachlorophenol
Phenol
Phenylene Diamine
2-Picol ine
Resorcinol
Tetrachl orobenzene
1,1,1 ,2-Tetrachl oroethane
1,1, 2, 2-Tetrachl oroethane
Tetrahydrofuran
Thiourea
Thiram
Tribromomethane
1, 2, 4-Trichl orobenzene
1 , 1 ,2-Tr ichl oroethane
2,4,6-Trichlorophenol
1,2,3-Trichloropropane
Vinyl Chloride
Acenaphthylene
Acryl amide
Acrylic Acid
Acrylonitrile
Anthracene
Benzal Chloride
Benzolrichloride
2-Chlorophenol
Dibromomethane
3,3-Dimethoxy benzidine
2,4-Dinitrophenol
Ethyl ene Thiourea
Haleic Hydrazide
Methanethiol
p-Nitroaniline
Phosgene
Phthal ic anhydride
Styrene
Toluene Diamine
Vanadium Pentoxide
*Alach)or
Aldicarb
Aldrin
Antu
Antrazine
Bromacil
Loading
(kg/yr)
0
83,781
10,761.152
0
0
0
0
0
1,157
1,742,940
0
0
12
12,486
126,440
48,902
0
18,245
0
3,005
13
1,492,250
661.660
104,699
1,611
9,877
18,097
1,180
664,540
0
U
1,855
33,156
0
1,855
0
2,722
411
Accl imated
Load i ng
(kg/yr)
0
4,189
538,058
0
0
0
0
0
116
87,147
0
0
4
1,873
25,288
2,445
0
912
0
301
1
492,250
33,083
10,470
161
494
2,715
236
66,454
0
0
93
3,316
0
186
0
272
309
Unacclimated Release
Median Low
(kg/yr) (kg/yr)
0
62,836
1.614,173
0
0
0
0
0
868
435,735
0
0
8
1,873
94,830
22,006
0
912
0
1,142
2
373,063
66,166
47,115
886
3,457
3,619
826
166,135
0
0
427
10,278
0
186
0
680
309
0
67,025
2,152,230
0
0
0
0
0
925
522,882
0
0
9
1,873
101,152
24,451
0
912
0
1,503
3
447,675
66,166
52,350
967
3,951
3,619
944
199,362
0
0
557
13,263
0
186
0
817
309
Accl imated
Loading
(kg/yr)
0
0
0
0
0
0
0
0
416
496,738
0
0
4
5,307
50,576
0
0
15,600
0
0
0
0
0
0
290
0
7,691
0
0
0
0
705
0
0
0
0
0
0
Unaccl imated
Median
(kg/yr)
0
0
0
0
0
0
0
0
174
915,043
0
0
3
6,368
25,288
0
0
16,467
0
0
0
55,959
0
17,275
218
0
11,582
0
0
0
0
857
0
0
0
0
0
0
Loading
Low
(kg/yr)
0
0
0
0
0
0
0
0
139
854,041
0
0
2
6,368
20,230
0
0
16,467
0
0
0
52,229
0
15,705
193
0
11,582
0
0
0
0
779
0
0
0
0
0
0
Acclimated
Loading
(kg/yr)
0
1,141
1,436,125
0
0
0
0
0
0
165,579
0
0
0
808
0
7
0
346
0
270
1
0
345,71?
7,538
116
751
2.307
94
59,809
0
0
176
2,984
0
167
0
245
10
Unacclimated
Med i an
(kg/yr)
0
300
1,284,954 1,
0
0
0
0
0
0
130,721
0
0
0
808
0
4
0
346
0
186
1
111,919
327,521
4,607
58
514
2,172
35
49.841
0
0
143
2,288
0
167
0
204
10
Loading
Low
0
240
209,368
0
0
0
0
0
0
122,006
0
0
0
808
0
4
0
346
0
150
1
104.458
327,521
4,188
52
474
2,172
24
46,518
0
0
130
1,989
0
167
0
191
10
*Pesticide loadings numbers were not included in this chart due to the proprietary nature of the data.
-------
TABLE 5-1. LOADINGS OF DSS POLLUTANTS TO POTW AND RESULTANT RECEIVING ENVIRONMENTS (Continued)
Pollutant
Estimated
National
Loading
(kg/yr)
LOADINGS TO RECEIVING WATERS
Acclimated Unacclimated Loading Acclimated
Loading Median Low Loading
(kg/yr) (kg/yr) (kg/yr) (kg/yr)
LOADINGS TO AIR
LOADINGS TO SLUDGE
Unacclimated
Median
(kg/yr)
Loading
Low
(kg/yr)
Acclimated
Loading
(kg/yr)
Unacclimated Loading
Median Low
{kg/yr) (kg/yr)
01
i
en
Captan
Carbofuran
Chlordane
Ohlorobenzilate
2,4-D
2,4-DB
Diazinon
Dichlorvos
Oicofol
Oinoseb
Diphenamid
Di sulfoton
Oi uron
Endrin
Fenthion
Ferbam
Folex
MCPA
Methoxychlor
Mev i nphos
Holed
Napthalam
Oxyanyl
Parathion
Parathion Methyl
Phorate
Pyrethrins
Sodium Fluoroacetate
Stlrofos
2.4,5-T
Toxaphene
Trifluralin
Pesticide loading numbers were not included in this chart due to the proprietary nature' of the data.
-------
kg/year, 1.4 million kg/year, and 30,500 kg/year to water, air, and sludge,
respectively. These National loadings estimates provide a rough yardstick for
measuring the significance of DSS pollutants received at POTWs and by the
receiving media.
Table 5-2 separates the information provided in Table 5-1 into five
pollutant classifications for a median unacclimated system and an acclimated
system: metals, volatiles, base neutrals, acids, and pesticides. This table
was developed by classifying an individual pollutant and summing the
partitioned amounts of all pollutants within a class. The classifications
provide a rough estimate of the total amounts of pollutants moving through the
various pathways and a method of selecting pollutants of concern from the
various receiving media based on total mass. The pesticide loadings used to
generate Table 5-2 could not be depicted individually in Table 5-1 because the
data are confidential.
The acclimated and unacclimated system scenarios represent the high and
low ends of the range of two of the three major removal mechanisms:
biodegradation and volatilization. Neither scenario takes into account
pollutant losses in the POTW collection systems and through combined sewer
overflows and both assume constant sludge partition fractions. These sce-
narios also do not account for POTWs achieving secondary treatment require-
ments (30 mg/1 BOD and 30 mg/1 TSS) using technologies other than conventional
activated sludge or for POTWs that are marine discharge facilities or are not
meeting secondary treatment requirements. The small amount of metals
transferred to the air and biodegraded is attributed to cyanide and mercury.
Given these limitations on the results presented in Table 5-2, the
following statements can be made. First, the assumption of constant sludge
partition fractions for both acclimated and unacclimated system scenarios is
not accurate and, combined with the decreased removal fractions going from
acclimated to unacclimated estimates, shows a decrease in the loadings to the
sludge when in fact both sludge loadings are equivalent or less than at the
unacclimated levels. The difference in these sludge loadings would be
attributed to biodegradation under the acclimated system scenario. However,
data were not available to adjust the sludge partition fractions so that they
5-6
-------
TABLE 5-2. SUWARY OF POLLUTANT LOADINGS
Median System Unacclimated
en
i
Pol 1 utant
Metals
Volatlles
Base Neutrals
Acids
Pesticides
TOTAL
Total
Loadings
kg/yr
6,995,081
50,825,712
22,208,302
12,366,825
56,033
92,451,953
Air
kg/yr
43,645
21,464,193
1,773,054
0
74
23,280,966
%
<1
42
8
0
1
25
kg/yr
2,828
6,917
5,251
1,990
28
17,016
Accl imated
Metals
Volatiles
Base Neutrals
Acids
Pesticides
TOTAL
6,955,081
50,825,712
22,208,302
12,366,825
56,033
92,451,953
4,365
12,113,572
778,962
0
4,483
12,901,382
<1
24
4
0
8
14
2,828
2,127
2,209
651
5
7,822
Water
,989
,532
,166
,768
,016
,471
System
,989
,566
,147
,568
,043
,313
%
40
14
24
16
50
18
40
4
10
5
9
8
Sludge
kg/yr
4,122,354
4,413,348
3,001,629
1,482,436
4,483
13,024,250
4,122,354
5,178,548
3,440,242
1,672,758
12,327
14,426,229
Biodegradation
% kg/yr %
59
9
14
12
8
14
59
10
15
14
22
16
18,030
12,182
8,893
23
39,130
39
31,406
15,779
10,042
34
57,302
93
,639
,453
,621
,538
,344
,373
,026
,951
,499
,180
,029
<1
35
55
72
42
43
<1
62
71
81
61
62
-------
accurately reflected acclimated system loadings to sludge. Second, the
largest shift of loadings from one removal mechanism to another when comparing
the unacclimated system loadings to the acclimated system,loadings is the 44
percent reduction of volatile organics going to the air and the 74 percent
increase in biodegradation of volatile organics. Although this shift is
predictable, the magnitude of this shift is questionable, and actual volatile
organic emissions to the air are probably somewhere in the range between
acclimated and unacclimated system scenarios. Third, due to the change in
removal fractions when comparing acclimated and unacclimated system scenarios,
the application of volatilization fractions causes acclimated volatilization
loadings to be greater than unacclimated volatilization loadings (both median
and low) for certain pollutants. This is not accurate; however, data were not
available to adjust the unacclimated volatilization fractions in order to
correct the unacclimated volatilization loadings.
Of the roughly 9.25 million kilograms of DSS pollutants released, 14 to
25 percent volatilizes to the air, 43 to 62 percent biodegrades, 14 to 16
percent partitions to the sludge, and 8 to 18 percent is discharged to surface
water. Figures 5-1 and 5-2 show the distribution of metals and organics
across POTWs and illustrate the misleading results that would be produced from
an effects analysis that spread the pollutants in Table 5-2 across all POTWs.
Metals and organics in the influent to each POTW in the 40 POTW Study were
summed and ranked from the lowest to the highest concentration. ' The
figures clearly show that total toxic metals and organics are not distributed
evenly across all POTWs. High concentrations of these pollutants are found in
a small percentage of POTWs. In all cases, the highest concentrations are
related directly to industrial discharge to POTWs. To perform an accurate
effects analysis, the distribution of DSS pollutants across all POTWs with
site-specific information on each POTW would be necessary.
The lack of effects criteria and data also restricts the effects
analysis. Table 5-3 is a summary of the criteria that are available for
performing the analysis. As shown, the data are limited primarily to priority
5-8
-------
TABLE 5-3. EFFECTS STUDY DATA LIMITATIONS
Category
Summary of Available Data
Available loadings information
Priority pollutants plus nonpriority
pollutants for the Organics Industry
(Section 3.2)
Available POTW effluent
concentrations
Priority pollutants
Available criteria by media:*
Water
Public drinking water supplies
Air
Sludge
65 priority pollutants
Subset of 18 priority pollutants plus 4
others
Subset of 4 priority pollutants
Subset of 16 chemicals and pathogens**
*See Appendix R for complete listing of available criteria and appropriate
references.
**These include 14 compounds for which EP toxicity limits have been set
(40 CFR 261.24).
5-9
-------
^ 6-S -
5.0
-------
en
i
25 .
^20-
F
c
O)
c
1 1
- 15.
O
c
o>
S-
o
u
1 10.
rd
-P
O
1
O
e
rj
^5.0,
4.0.
3.0.
2.0.
1.0
Ranking of Influent
- Total Toxic Organics *
Source: 40 POTW Study
»
-
. *
.
«
-
*
TT 1 1 1 M M M 1 MM M 1 ' ' 1 1 1 | 1 1 1 M I 1 1 1 11 1 1 1 1 M 1 1 1 1 1 1 1 1 -1
25
20
15
10
f
.5.0
4.0
.3.0
2.0
1.0
10
40
20 30
Number of Plants with Influent
FIGURE 5-2. DISTRIBUTION OF ORGANICS IN POTW INFLUENT
50
-------
pollutants in surface water. The lack of criteria and data on the distribu-
tion of DSS pollutants to POTWs prevents a detailed analysis of the effects on
surface water, air, and ground water.
Given these limitations, the following sections provide media-specific
analyses of potential environmental effects. Section 5.1 concerns the water
media, Section 5.2 concerns the air media, and Section 5.3 concerns the
effects of sludge on the land and ground water media. Conclusions are
provided in Section 5.4.
5.2 ASSESSMENT OF ENVIRONMENTAL EFFECTS ON SURFACE WATER QUALITY
This section examines the types of effects associated with DSS wastes
discharged from POTWs to surface water. Two complementary approaches were
used to determine the potential effect of DSE discharges on water quality.
The first approach involved comparing instream concentrations of DSS pol-
lutants with applicable criteria (both aquatic and human health) or standards
to determine potential impacts on surface water quality. A case study
approach also was used, which involved reviewing existing POTW bioassay
results. The review indicated that a number of POTWs had toxic discharges.
While these results did not address the contribution that DSS discharges might
have had on resultant toxicity, the results'are indicative of the fact that
secondary treatment, even with the imposition of currently promulgated and
soon to be promulgated pretreatment controls, may not offer sufficient
protection to the aquatic environment in all cases.
The results of this section indicate that a subset of DSS pollutants
exceeds water quality criteria even with the imposition of pretreatment
standards. These pollutants are not necessarily those that show the largest
loadings in Table 5-1. Indeed, this section shows that pollutants with
greater toxicity are the pollutants of concern to the water medium, even
though they may have lesser loadings than other pollutants. This situation is
further demonstrated by using the projected instream concentrations and is
supported by the case studies.
5-12
-------
5.2.1 Projected Instream Concentrations of DSS Pollutants
Projections of the effects of a discharge on water quality traditionally
are based on the comparison of instream wastewater concentrations (IWC) to
ambient water quality criteria. To derive IWCs, the dilution ratio (ratio of
wastewater discharge flow to receiving stream flow) is calculated and applied
to effluent concentration. An exceedance of criteria is indicative of the
pollutant's water quality effects, since the criteria were developed to
protect human health and the aquatic environment. Two separate calculations
are conducted, one for mean flow and one for low flow, with the latter 7Q10
low flow providing the "worst case" scenario. The term 7Q10 refers to the
average low flow for 7 consecutive days occurring on the average of once in
10 years.
The value of conducting dilution analyses for this study was limited
because of: (1) lack of available effluent or projected effluent concen-
trations to calculate instream concentrations for all DSS pollutants; and
(2) lack of available criteria for DSS pollutants. On the other hand, this
analysis also proved valuable in two ways. First, the results acknowledge
that POTW treatment will not result in "clean" discharges; that is to say,
exceedances do occur. Second, the projection of exceedances may mean that
other DSS pollutants with similar characteristics and effluent loadings also
may be passing through the treatment system and possibly creating water
quality problems.
The analysis involves three separate data bases. The first part of the
discussion summarizes the results of a 1983 report titled Addendum to the
Assessment of the Impacts of Industrial Discharges on Publicly Owned Treatment
f 91
Works.v ' This report is important because it describes the ambient improve-
ments that can be expected from implementing the pretreatment program. The
Addendum results are particularly valuable since they are derived from
wasteload modeling at 1,839 POTWs. The second and third analyses use actual
effluent concentrations measured at POTWs. The first of these data bases, the
40 POTW data base, measured a wider range of pollutants, but the data are
older than the information in the second data base, which is taken from three
separate sources: an AMSA survey
(3)
a limited survey of POTWs undertaken by
Region
, and State agencies.
5-13
-------
somewhat less effective in reducing exceedances when low flows are used to
predict exceedances. This analysis suggests that criteria exceedances will
continue even after implementation of the categorical standards, although less
frequently. Thus, the current technology-based standards cannot, in and of
themselves, resolve water quality concerns. Cadmium, silver, lead, and
cyanide remain the DSS constituents of concern from this study.
40 PQTW Study
Table 5-5 shows the number of human health criteria for ingestion of
drinking water and aquatic organisms that were exceeded by discharges of a
subset of the DSS pollutants found in municipal effluents from the 40 POTW
study. Although the Addendum study analyzed exceedances for 14 pollutants,
data available from the 40 POTW study allowed for the calculation of
exceedances for 51 pollutants. On the other hand, the 40 POTW data are from
1979 and do not reflect subsequent changes in effluent quality due to pre-
treatment or changes to RCRA. The 40 POTW study was conducted to determine
how well properly operated secondary treatment plants removed toxic pol-
1utants.
This study also differs from the Addendum analyses because human health
criteria were used rather than the aquatic toxicity criteria used in the
Addendum study. While this difference makes a comparison between results
difficult, it also means that a larger number of pollutants could be analyzed.
The Agency has adopted a more complete set of priority pollutant criteria for
human health (for 51 pollutants), whereas only 22 of 65 priority pollutants
have been assigned aquatic toxicity criteria (14 of which were assessed in the
Addendum).
Table 5-5 shows the pollutants discharged by POTWs that caused criteria
exceedances. Twenty-six of the pollutants caused at least one exceedance,
with several causing multiple exceedances. For example, chloroform exceeded
criteria for 14 of 18 available data points (78 percent) at both mean and low
(7Q10) flow. Discharges of cyanide, nickel, and tetrachloroethylene also
resulted in a large percentage of exceedances (greater than 60 percent).
Other pollutants discharged with a number of exceedances were mercury,
5-16
-------
TABLE
Benzene
Carbon Tetrachloride*
Hexachl orobenzene*
1,2-Dichl oroethane*
1,1,1-Tri chl oroethane
Hexachl oroethane
1 , 1 ,2-Tri chl oroethane*
5-5. HUMAN HEALTH CRITERIA
40 POTW DATA BASE
Number of POTWs with
Available Dilution Data
and Pollutant Detected
18
16
16
17
17
16
17
Bis (2-Chl oroethyl) Ether 16
2,4,6-Trichlorophenol*
Chloroform
1 ,2-Dichl orobenzene*
1 , 3-Di chl orobenzene*
1 ,4-Di chl orobenzene*
1,1-Di chl oroethane*
2,4-Dichlorophenol
Ethyl benzene*
Hexachl orobutadiene
Nitrobenzene
N-nitrosodimethylamine
Pentachlorophenol*
Phenol
Diethyl Phthalate
Dimethyl Phthalate
Tetrachl oroethyl ene*
Toluene*
Trichl oroethyl ene*
Vinyl Chloride
Aldrin
Dieldrin
Chlordane
DDT
Endrin
Heptachlor*
Lindane*
PCB 1242*
PCB 1254*
PCB 1221
PCB 1232
PCB 1248
PCB 1260
PCB 1016
Toxaphene
Arsenic*
Cadmium
Cyanide
Mercury
Nickel
Selenium*
; Silver
. Thallium
Chromium
16
18
17
17
17
17
16
18
16
16
16
17
18
17
18
18
18
18
17
17
16
16
16
16
16
17
16
16
16
16
16
16
16
16
17
17
18
17
18
16
18
16
17
EXCEEDANCES
Number of
Exceedances
at Low Flow
7
1
0
4
1
0
2
0
1
14
4
1
1
3
0
1
0
0
0
4
0
0
0
11
1
6
0
0
0
0
0
0
2
6
1
1
0
0
0
0
0
0
2
6
15
6
13
4
3
0
2
Number of
Exceedances
at Mean Flow
7
1
1
4
1
0
2
0
1
14
4
1
1
3
0
0
0
0
0
0
0
0
0
11
0
6
0
0
0
0
0
0
2
6
1
1
0
0
0
0
0
0
2
6
13
6
13
3
2
0
1
*Pollutants with violations that were not calculated in the "Addendum" study.
Source: Reference No. 2 __
5-17
-------
cadmium, trichloroethylene, and benzene. Neither trichloroethylene nor
tetrachloroethylene were considered in the Addendum analysis.
Other pollutants with calculated exceedances that did not appear in the
Addendum include: carbon tetrachloride, 1,2-dichloroethane, 1.1.2-
trichloroethane, and 2,4,6-trichlorophenol. However, as seen from Table 5-5,
most of these pollutants had very few exceedances. Many of the pollutants
(22) had no exceedances at all.
AMSA/Region V
The previous analyses demonstrated that exceedances of water quality
criteria can be expected even after POTW treatment for a wide range of DSS
pollutants. Another analysis was conducted using effluent data available from
the AMSA survey and effluent samples taken at selected POTWs by EPA's Region
V. The analysis of these data enabled 17 pollutants to be analyzed at up to
15 plants. The exceedance rate was much lower than that projected in the two
previous analyses, as shown in Table 5-6.
Criteria exceedance may not be solely of concern to the aquatic environ-
ment. An analysis of the proximity of drinking water intakes to pretreatment
POTWs showed that of the 529 drinking water treatment facilities that could be
identified downstream of pretreatment POTWs, 130, or about 25 percent of this
total, were located within 5 miles downstream. Of these, 107 facilities had
dilution rates of less than 25 to 1 at low flow. While no analysis of the
effectiveness of water supply systems was undertaken for purposes of this
study, this analysis does suggest that such systems should screen for these
pollutants in their influent and treated supplies.
5.2.2 Summary of Empirical Data
The previous section attempted to project water quality effects of DSE
discharges by POTWs. No clear-cut conclusions on water quality effects can be
drawn from the analysis, although the projections do suggest that certain
pollutants may be of concern either because of toxicity or prevalence in POTW
discharges. This section reviews additional case study information to assess
the potential effects of DSE discharges by POTWs and, to the extent possible,
verify the projected effects from the previous section.
5-18
-------
TABLE 5-6. HUNAN HEALTH CRITERIA EXCEEDANCES BASED ON
AMSA AND REGION V DATA
Pollutant
Barium
Cadmi um
Mercury
Selenium
Silver
Ethyl Benzene
Nickel
Cyanide
Benzene
Chloroform
1,2-Dichloroethane
Phenol
Tet rachloroethylene
Carbon Tetrachloride
Toluene
1,1,1-Trichloroethane
Pentachlorophenol
Number of
POTWs With Available
Dilution Data and
Pollutant Detected
1
14
U
4
8
5
15
5
2
7
1
10
6
3
7
5
2
Number of
Exceedances
at Low Flow
1
0
5
0
0
0
4
0
0
3
1
0
3
0
0
0
0
Number of
Exceedances
at Mean Flow
1
0
1
0
0
0
2
0
0
1
0
0
1
0
0
0
0
Source: Reference Nos. 3 and 5
5-19
-------
Bioassay data from three sources are included in this discussion: EPA
(5)
Region \P ', North Carolina Department of Natural Resources and Community
Development^ ', and the State of Florida/ ^ These sources represent only a
small portion of all bioassay work on NPDES permitted effluents. Currently,
39 States are using bioassays to test municipal and/or industrial effluents,
and the Agency is pursuing its biomonitoring program (see Tables 5-7 and 5-8).
The data verify that municipal effluents can be very toxic and/or
mutagenic. The State of North Carolina found that 32 percent of the POTWs it
tested had effluents with some degree of acute toxicity. As a result of these
findings, POTWs, the State undertook indepth toxicological analyses of
selected municipal discharge characteristics. It reviewed the POTWs1
pretreatment programs to determine significant industrial contributors,
sampled at various points in the system (i.e., influent, effluent, upstream,
and downstream), surveyed the fauna in the receiving stream, and performed
96-hour flow-through acute toxicity tests on the effluent.
Table 5-7 summarizes the results of North Carolina's studies. Most of
the POTWs had industrial user communities that were dominated by textile
plants. These textile plants discharged biocides [namely 5-chloro{2-2,4-
dichlorophenoxy) phenol, tributyl tin hydride, nonyl phenol, and other
phenols], which are used as fabric scouring agents, surfactants, deodorizers,
and dye levelers.
The impacts of these compounds on receiving streams were sometimes
substantial. For example, at one POTW a fish survey of the upstream and
downstream segments of the river revealed a significant discrepancy in
numbers. In the first 50 meters of the upstream segment, 23 fish of 3 species
were found. In the downstream 50 meter section, no fish were found. Similar
instances of severe downstream degradation resulting from POTW discharges were
documented. These effects generally included lack of species diversity or
predominance of pollutant-tolerant species (e.g., sludge worms).
5-20
-------
TABLE 5-7. SUMMARY OF INDEPTH NORTH CAROLINA POTW TOXICITY EXAMINATIONS
Name
Treatment Type
LC50s
Influent Effluent
Percent
Industrial Flow
Predominant
Industries
Detected
Organic Pollutants
Star
Trickling filter
Hiyh Point
(Westside)
Trickling filter
tn
ro
17.5% 60% 70%
14.5%
(10% for
96 hr flow
through)
17%
30%
43%
(64% for
96 hr flow
through)
Textiles
Newton Clark
Creek UHTP
Clarifiers, lime
addition, activated
sludge
P 25*
Note: chronic 12.5% ~ Textiles
bioassay showed
significant
depression in
reproductive
success
Phenols
Formaldehyde
Phenol ethoxylates
Phenols
Dibutyl phthalate
Ethyl hexanoic acid
Cholestenediol
Cholestadiene
Tributyl tin hydride
Formaldehyde
10 unidenti fied
organic peaks
Tributyl tin hydride
Ethyl methyl benzene
Trimethyl benzene
Di ethyl benzene
Tri chlorobenzene
Methyl propyl benzene
Petroleum oil
11 unidentified
organic peaks
High Point Trickling filter 26%
(Eastside) 50%
21%
(100% for
96 hr flow
through)
Burlington Activated sludge 20% 40%
with carbon None
None
(42% for
96 hr flow
through)
Phenols
Textiles Phenols
*P = percent mortality at highest concentration,
-------
TABLE 5-7. SUfWARY OF INDEPTH NORTH CAROLINA POTU TOXICITY EXAMINATIONS (Continued)
Name
Treatment Type
LCSOs
Influent Effluent
Percent
Industrial Flow
Predominant
Industries
Detected
Organic Pollutants
Asheboro
Trickling filter
Burlington
Eastside
Activated sludge
tn
I
ro
no
Rockwell
Southside
Trickling filter
Mt. Airy
Trickling filter
40%
35%
(20% for
96 hr flow
through)
39%
50%
(lb% for
y6 hr flow
through)
28%
55%
(37% for
96 hr flow
through)
46%
P 35*
28%
(16% for
96 hr flow
through)
33%
Textiles
Batteries
80%
Textiles
Phenols
Phenols
Tributyl tin hydride
5-Chloro-2-
(2,4-dkhlorophenoxy)
phenol
chlorine
3 unidentified
organic peaks
Tributyl tin hydride
Dimethyl pentene
Pentacosane
Octamethyl -
Cyclotetrasiloxane
Formaldehyde
Phenols
2 unidentified
organic peaks
Nonylphenol
Tributyl tin hydride
*P = percent mortality at highest concentration,
-------
Similar results were obtained from the EPA Region V bioassay tests.
According to the Region's acute toxicity tests, 53 percent of those plants
sampled had effluents that were acutely toxic to some degree. Furthermore, 18
percent of the POTWs tested had effluents that exhibited LC50s when diluted to
less than 50 percent.
The State of Florida is conducting a bioassay screening program of
municipal and industrial discharges. Bioassay results from that program show
that DSS pollutants, including the pesticides lindane and methoxychlor, are of
concern as toxic agents in municipal discharges. Other DSS pollutants that
were detected were mercury, cadmium, chromium, and lead. All of these
pollutants, with the exception of methoxychlor, which was not considered, were
found to have criteria exceedances in the previous section. Table.5-8
illustrates these results. Reading from the dechlorinated effluent column, it
is apparent that some of the effluents were very toxic. For example, the
Sebring plant's effluent had a LC50 toxicity of 12 percent. On the other
hand, Vero Beach's plant did not exhibit toxicity after chlorination.
These three separate bioassay studies demonstrate that POTWs, especially
those with a substantial percentage of industrial influent, can have a
deleterious effect on the environment. The studies also seem to point toward
the same pollutants as those that appeared in the dilution analyses as being
responsible for toxicity.
5.2.3 Conclusions
In the introduction to this chapter, projected loadings to different
media were estimated. Those projections showed 17 million kilograms of
hazardous constituents per year making their way to surface waters from
unacclimated systems. Ten pollutants contributed a total of 10.2 million
kilograms per year in unacclimated and 5.3 million kilograms in acclimated
systems, or roughly 60.2 to 67.4 percent of the total'being discharged to
surface waters. These.pollutants were acetone, nickel, formaldehyde,
chromium, cyanide, phenol, lead, furfural, xylene, and methylene chloride.
5-23
-------
TABLE 5-8. 1982-1984 FLORIDA BIOASSAY RESULTS - LC50 (48 hr)
Effluent
Facil ity Name
Jacksonville Beach STP
Marianna STP
Daytona Beach
Regional and
Bethune Point STPs
Fortenberry STP
Fort LautJerdale "B"
STP
St. Cloud STP
Fortenberry MWTP
Fortenberry WWTP
Sebring Airport STP
Kanapaha WWTP
St. Cloud STP
San ford STP
Vero Beach STP
NPDES I
FL0020231
FL0020117
FL0025984
FL0026816
FLOU20S24
FL0028959
FL0026816
FL0026816
FL0021288
FL0032379
FL0028959
FL0020141
FL0021661
Prechlorlnated
40%
D. pulex 54.2%
75.2%
18%
78.8%
78%
24.3%
31.2%
96.2%
40.2%
NT
28.7%
Chlorinated
43.6%
D. pulex 29
S. serruiat
70.3%
21%
9.0%
<5.6%
S.
22.2%
32%
<5.6%
1.9%
<5.6%
7.2%
NT
Decnlorinated
63.1%
.0% NT
us = 9.6%
46.4%
21%
78.6%
10%
serrulatus = 19.8%
19.0%
32%
12%
NT
55.3%
78.7%
NT
Comments
Test organism was M. bahia {toxicity attributed to "lindane and
to other chemical constituents")
Test organism was M. bahia {toxicity attributed to "lindane and
otner cnemicai constituents11) "24 nr test
Test organism was M. bahia {toxicity attributed to "lindane and
other chemical constituents1')
Test organism was M. bahia (toxicity attributed to "lindane and
malathion and other chemical constituents")
Test organism was M. bahia (toxicity attributed to "lindane and
other metal constituents")
Test organism was M. bahia (toxicity attributed to "lindane and
other metal constituents")
Test organism was M. bahia (toxicity attributed to lindane and
mercury)
Test organism was M. bahia. Tests were performed to determine
u alum treatment reduced toxicity. it was round to nave only
reduced it from 28.8% to 31.2%.
Test organism was D, pulex (toxicity attributed to cadmium,
chromium, lead, silver, zinc, and chlorine)
Test organism was D, pulex {toxicity was attributed to mercury.
zinc, several unidentified organics, and chlorine)
Test organism was 0. pulex (toxicity was attributed to lindane,
methoxycnior, several unidentified organics, copper, mercury,
zinc, silver, and chlorine)
Test organism was D. pulex
Test organism was M. bahia
Note: NT = Not Toxic
-------
Of these pollutants, cyanide, chromium, and lead experienced criteria
exceedances in the dilution analyses. Water quality criteria were not
available for furfural and formaldehyde. Consequently, criteria exceedance
projections could not be made. The analyses for the other pollutants did not
result in exceedances.
On the other hand, pollutants that had smaller loadings, but a more
significant number of exceedances, were: silver, tetrachloroethane,
trichloroethylene, tetrachloroethylene, chloroform, and lindane (lindane is
not a DSS pollutant, but was selected as representative of DSS pesticides).
Total unacclimated loadings for these compounds (except for lindane) were
calculated at roughly 1.9 million kg/year. Among these pollutants, the mean
loading was just over 243,461 kg/year, with chloroform being the most
prevalent (381,000 kg/yr) and 1,1,1,2-tetrachloroethane the least prevalent
(868 kg/yr). The relatively low level of loadings contributed by these
pollutants is in contrast to the toxic effects they produce, as measured by
the criteria exceedances they caused. Seven of these pollutants have been
assigned a CERCLA reportable quantity of one, representing a high level of
toxicity. Although chloroform is the least toxic, with a reportable quantity
of 5,000, it also is the most prevalent among these pollutants.
The bioassay case studies conducted by the States of North Carolina and
Florida found that some pollutants were often the cause of toxicity in
municipal effluents. Among those named by the States as toxic agents were
phenol, formaldehyde, lindane, silver, lead, and cadmium. Thus, the bioassay
results appear to confirm the criteria exceedance projections.
These results suggest that certain DSS pollutants do pass through POTW
treatment systems and are of concern to the surface water receiving environ-
ment. Other DSS pollutants, including those for which exceedances could not
be projected due either to a lack of criteria or available effluent data, are
also potentially of concern. Beyond the formulation of the National loading
projections for a subset of these DSS pollutants, little information exists on
potential effects.
5-25
-------
5.3 ASSESSMENT OF EFFECTS.OF AIR RELEASES
Air emissions from POTWs emanate from the treatment system and sludge
incinerators, as follows:
Volatilization of organic compounds contained in the discharge.
Organic compounds may volatilize enroute to the POTW and at the POTW
itself. These pollutants are emitted as gases to both the ambient air
and the workplace (POTW) environment.
t Incineration of sewage sludge with discharge constituents that have
adsorbed to sludge. Constituents are emitted to the ambient air
during sludge incineration. The emissions of concern include
particulates, chemicals that adsorb to those particulates, and
aerosols formed from the incomplete combustion of the hydrocarbons.
These emissions affect worker health and safety and ambient air quality.
Worker health and safety concerns arise from: (1) increased potential
for explosions from volatile constituents in the wastestream; and (2) acute
and chronic health effects from contact with volatilized pollutants. The risk
of explosions at a POTW was discussed in Chapter 4; it is discussed here only
as it relates to actual incidences and their impact on worker health and
safety. Acute health effects occur from exposure to a pollutant over a short
time period. These effects include neurotoxicity, dermatological problems,
and respiratory difficulties. Chronic health-effects result from long-term
exposure to pollutants at comparatively low concentrations. Carcinogenicity,
mutagenicity, and teratogenicity, or their potential, are the most common
measures of chronic effects.
Emissions also lead to the degradation of ambient air quality, which can
cause both environmental damage and acute and chronic human health effects.
These impacts are caused by increases in total suspended particulates (TSP) in
the atmosphere, increases in ambient concentrations of ozone due to the
photochemical oxidation of hydrocarbons emitted to the ambient air, and human
exposure to specific compounds.
Meteorological conditions can have a significant effect on conditions at
POTWs that potentially could affect both worker health and safety and ambient
5-26
-------
air quality. During the winter months, many POTW systems are enclosed,
reducing the ventilation of volatilized organics and thereby increasing both
the chance and severity of exposure to workers. In contrast, ambient air
impacts increase on warmer, sunny days when photo-oxidation (ozone production)
occurs more readily than at other times. Hazardous waste dumps or spills also
may expose workers to hazardous air emissions. The POTW incidents files and
AMSA survey results show that many discharges of organic chemicals occur as
illegal dumps and spills. Since POTW workers are not notified of these
discharges, they are vulnerable to the resulting toxic air emissions.
The effect of the incineration of contaminated municipal sludges on air
quality was not determined in this study because of a lack of adequate infor-
mation. However, emissions of metals from some sludge incinerators may create
localized problems. EPA is considering regulation of sewage sludge incinera-
tors for emissions of chromium, cadmium, and inorganic arsenic. Chromium and
cadmium are both candidates for listing as hazardous air pollutants under
Section 112 of the Clean Air Act, and arsenic already is listed. Preliminary
data suggest that most of the chromium emitted from sewage sludge incinerators
is not hexavalent, which reduces concern about this source (the only strong
health evidence regarding risk of chromium exposure applies to hexavalent
chromium). Sewage sludge incinerators are regulated under Section 112 for
emissions of beryllium and mercury. EPA is also reviewing the New Source
Performance Standard (NSPS) for sewage sludge incinerators. Currently, EPA
plans to require monitoring that will improve proper operation and maintenance
of these incinerators.
5.3.1 Description of Air Emissions from POTWs
Chapter 4 provided an indepth discussion of the processes that control
the fate of each pollutant in the POTW system. Henry's Law Constant, gener-
3
ally reported in units of atm-m /mole, expresses the equilibrium distribution
of the compound between air and water, indicating the relative ease with which
the compound may be removed from aqueous solution. Chemicals with relatively
high vapor pressures and low solubility, such as chloroform, are more likely
to vaporize and become airborne than chemicals with low vapor pressures, high
solubility, or a high affinity for adsorption to solids and sediment, such as
phenol.
5-27
-------
In this study, readily volatilized compounds have been defined as those
-3 3
having Henry's Law Constants >10 atm-m /mole. Those pollutants with Henry's
-5
Law Constants down to 10 are considered to be partially volatilized in the
POTW system and are treated as such in the quantitative analysis of POTW
emissions. In this assessment, only those compounds in the influent that have
been calculated to be volatile will be used to determine air effects.
Table 5-9 depicts the major pollutant emissions to air through
volatilization at the POTW. Ten pollutants are estimated to account for
greater than 90 percent of the total volatile emissions from the POTW. In
particular, 1,1,1-trichloroethane and methylene chloride are the most sig-
nificant emissions to the ambient air in terms of mass.
EPA is considering regulation of 41 highly volatile substances under
Section 112 of the CAA. These compounds commonly are found in aqueous
wastestreams and readily volatilize. Those compounds facing immediate
decision for listing as hazardous air pollutants are depicted in Table 5-10.
This list includes all of the compounds identified by the DSS as being of
concern due to volatilization from the POTW, with the exception of tetra-
hydrofuran. For the chemicals presented in Table 5-9, EPA has issued notices
of intent to list for methylene chloride, tetrachloroethylene, trichloro-
ethylene, and chloroform. Based on national emission estimates for these
compounds prepared by EPA's Air Office, POTWs appear to contribute from about
one to nine percent (depending on the pollutant) of total emissions from
identified sources (see 50 FR 39626, 52422, and 52880). EPA's Office of Air
Quality Planning and Standards is assessing POTWs as a source emitting these
compounds.
In a second study of emission releases from a wastewater treatment
plant, of the nine compounds studied, GCA found that benzene, toluene, and
I Q\
l-2,dichloroethane were the most significant compounds released to air.
This compares favorably with the National loadings fate data in Chapter 4,
which also showed that toluene and benzene are significant contributors to
total air emissions. While Chapter 4 indicates 1,2-dichloroethane is released
primarily to air, the National loadings for this compound are so small that it
5-28
-------
TABLE 5-9. MAJOR POLLUTANT EMISSIONS TO AIR BY POTW VOLATILIZATION
Pollutant
1,1,1-Tri chloroethane*
Methylene Chloride*
Xylenes*
Chloroform*
Trichloroethylene*
Toluene*
Tetrachloroethyl ene*
Ethyl Benzene*
Tetrahydrofuran
Benzene*
Emission (Kg/yr)
Acclimated
Unacclimated
Median
Low
2,989,002
2,087,837
1,641,683
1,199,614
1,149,702
895,126
679,341
518,499
496,738
442,533
3,185,647
2,868,029
4,810,996
1,370,987
1,203,297
2,713,645
1,026,559
1,571,871
915,043
1,341,572
3,008,667
2,802,097
4,700,398
1,370,987
1,175,635
2,713,645
996,173
1,571,871
854,041
1,341,572
*Pollutants considered for regulation under the CAA.
5-29
-------
TABLE 5-10. SUBSTANCES UNDER CONSIDERATION FOR LISTING UNDER
SECTION 112 OF THE CLEAN AIR ACT
Already Listed Under 112
Asbestos
Beryllium
Mercury
Vinyl Chloride
Benzene
Radionuclides
Inorganic Arsenic
Coke oven emissions
Decisions Not to List or Notices of Intent Not to List
Manganese
Nickel
Polycyclic organic matter
Acrylonitrile
Toluene
Methyl Chloroform (1,1,1-Trichloroethane)
Vinylidene Chloride (1,1-Dichloroethylene)
Epichlorohydrin
Hexachlorocyclopentadiene (HCCPO)
Chlorobenzenes
Chloroprene
Phenol
1,1,1-trichlorotrifluoroethane (Freon 113)
Notices of Intent to List
Cadmi urn
Chromium
Carbon Tetrachloride
1,3-Butadiene
Methylene Chloride (DichloromethaneJ*
Perchloroethylene (Tetrachl oroethylene)
Trichloroethylene
Ethylene Dichloride (1,2-Dichloroethane)
Chloroform
Ethylene Oxide
Dioxin
*Methylene chloride was addressed in a
EPA's plans to regulate under Section
Act. Perchloroethylene is also a
Federal Register notice announcing
4(f) of the Toxic Substances Control
candidate for 4(f) regulation.
5-30
-------
is not a significant contributor in this analysis. However, the Philadelphia
study (discussed later in this section) found that 1,2-dichloroethane was
emitted in significant amounts from the wastewater treatment plant and that
(91
benzene also was emitted in somewhat smaller amounts.v/ The major sources of
these pollutants are discharging to a small number of POTWs. For example,
there are approximately 15,000 wastewater treatment plants, but there are only
468 organic chemical industry plants discharging process wastewaters to POTWs.
5.3.2 Assessment of Effects
Because of time and budget constraints, a precise analysis of the
quantitative effects of air emissions due to DSE discharges was not possible
without POTW-specific data, such as that collected in the Philadelphia study.
In lieu of such information, qualitative analyses of potential effects were
completed using pollutant incident reports and case studies. The potential
effects to worker health and safety are:
t Risk of explosion
Acute health risk
Chronic health risk (other than cancer)
Chronic cancer risk.
Chapter 4 discussed those DSE compounds that pose a significant risk of
explosion. Table 5-11 lists 10 adverse health and safety episodes at POTWs;
this list also demonstrates that explosions can occur at POTWs as a result of
f 3\
influents received.v ' Pollutant incident reports from 10 POTWs reflect
occurrences of occupational health hazards in the collection and/or treatment
systems. No industrial hygiene samples of airborne concentrations were col-
lected when these occurrences took place. It is presumed that the concen-
trations exceeded the OSHA-specified permissible exposure limit or American
Council of Government and Industrial Hygienists-specified threshold limit
values. Appendix S lists the PELs and TLVs for each of the DSS pollutants.
Table 5-11 identifies the cities, pollutants, and worker health effects
associated with these incidents. The health-related effects of these
incidents range from the loss of one or more workers for part of a day to
several days, to one documented fatality.
5-31
-------
TABLE 5-11. DOCUMENTATION OF OCCUPATIONAL HEALTH HAZARDS
IN POTW COLLECTION AND TREATMENT SYSTEMS
POTW
POLLUTANT
WORKER EFFECTS
Baltimore, MD
Gloucester County, NJ
Louisville, KY
Mt. Pleasant, TN
Naugatuck, CT
Passaic Valley, NJ
Pennsauken, NO
St. Paul , MN
South Essex, MA
Tampa, FL
Benzene, toluene,
other solvents
1,1,1-Trichloroethane
Hexane
Organics and metals
Chlorine
Volatile compound
Benzene, toluene,
phenol, chloroform
Solvents
Hexavalent chromium
Organic solvent
Nausea
Fatality by inhalation
Nausea
Nausea
Fatality
Shortness of breath, skin
irritation
Shortness of breath, watery
eyes
Headaches
Skin irritation
Nausea
5-32
-------
The acute and chronic toxic effects of exposure to volatilized pollutants
are well-documented in medical and toxicological literature. These effects
are presented for the major pollutants that account for most of the total
volatile emissions in Table 5-12. The effects of these carcinogenic and
mutagenic pollutants range from irritations to skin, eyes, nose, or throat to
rapid unconsciousness and death. The acute effects of exposure vary
significantly based on the concentration to which workers are exposed.
While it is impossible to quantify the exposure levels at which workers
suffered effects from the incidents shown in Table 5-11, "it is presumed that
the levels exceeded the OSHA and ACGIH limits. It is likely that workers
exposed to pollutants (which could not always be specifically identified) may
not have recognized any danger; for example, the odor threshold for benzene
(which was positively identified in two incidents) is 12 ppm, while the OSHA
and ACGIH limits are both 10 ppm. Thus, POTW workers probably were exposed to
exceedances of the OSHA and ACGIH values before they detected the relatively
pleasant odor characteristic of benzene.
Ambient Air Quality
The CAA directs EPA to develop ambient air quality standards for certain
pollutants to protect public health and welfare. Operations at POTWs may
contribute to ambient concentrations of two of these pollutants: ozone and
particulate matter. The potential effects of POTW emissions on air quality
with regard to these pollutants are discussed below.
Many air pollutants are of health concerns for reasons other than their
contribution to ambient levels of criteria pollutants, such as ozone and
particulate matter. Many individual pollutants cause other health effects,
both acute and chronic, at certain levels of exposure. These health effects
include cancer, renal and liver toxicity, mutagenicity, teratogenicity, and
other health effects. For nonthreshold pollutants such as carcinogens, a risk
exists at any level of exposure. For noncarcinogenic pollutants, the highest
pollutant concentrations will affect workers in the sewer system and headworks
of the treatment plant, with concentrations and associated risks dropping off
5-33
-------
TABLE 5-12. TOXICITY OF 16 MAJOR VOLATILE POLLUTANTS
Pollutant
Classification
1,1-Trichloroethane Care i nogen
Methylene Chloride Hutagen
Tr ichloroethylene
Carcinogen
Exposure
Route
Breathing and
through the
skin
Breathing and
through the
skin
Breathing
tn
i
Chloroform
Xylenes
Carcinogen
Breathing and
through the
skin
Breathing and
through the
skin
Toluene
Tetrachloroethylene
Carcinogen
Breathing and
through the
skin
Breathing and
through the
skin
OSHA
Standard^
350 ppm
AC61H
Standard
350 ppm
500 ppm
100 ppm
100 ppm
50 ppm
50 ppm
100 ppm
10 ppm
100 ppm
200 ppm
100 ppm
100 ppm
50 ppm
Chronic
Effects
liver and adrenal
gland cancer in
animals; thickening
and cracking of the
skin.
Genetic changes in
living cells; lung
irritation; liver
damage; thickening
and cracking of the
skin.
Liver cancer in
animals; skin
irritation; liver
and kidney damage;
memory loss,
headache, and
depression.
Cancer of the liver,
kidneys, and thyroid
in animals; drying
and cracking of the
skin.
Drying and cracking
of the skin.
Liver and kidney
damage.
Liver cancer in
animals; drying and
cracking of the
skin.
Acute
Effects
Lightheadedness;
irregular heart
beat; irritation of
the eyes, nose,
mouth, and throat;
unconsciousness or
death.
Severe skin burns;
eye irritant; fluid
in the lungs;
fatigue and
shortness of breath;
rapid unconscious-
ness and death.
Irritation of the
eyes, nose, throat,
and lungs; fatigue,
dizziness, visual
disturbances, loss
of muscle control,
mental confusion,
and nausea.
Nose, throat, and
skin irritant;
dizziness.
Dizziness,
excitement,
drowsiness, and
uncoordination; eye,
nose, and throat
irritant; nausea,
vomiting, and
abdominal pain.
Fatigue, headache,
confusion, and
dizziness.
Liver and kidney
damage; lung, eye,
nose, mouth, and
throat irritant.
-------
TABLE 5-12. TOXICITY OF 16 MAJOR VOLATILE POLLUTANTS (Continued)
Pollutant
Classification
Exposure
i
OJ
Methanol
Ethyl Benzene
Tetrahydrofuran
Benzene
Carcinogen
Formaldehyde
Carcinogen
Furfural
Chlorobenzene
1,4-Dichlorobenzene
Acetone
Breathing and
through the
skin
Breathing
Breathing and
through the
skin
Breathing and
through the
skin
Breathing and
through the
skin
Breathing and
through the
skin
Breathing and
through the
skin
Breathing and
through the
skin
OSHA
jt andand
200 ppnt
200 ppm
10 ppm
Breathing and 3 ppm
through the
skin
5 ppm
75 ppm
50 ppm
1,000 ppm
ACGIH
Standard
200 ppm
100 ppm 100 ppm
200 ppm
10 ppm
2 ppm
2 ppm
75 ppm
50 ppm
750 ppm
Chronic
Effects
Liver damage; drying
and cracking of the
skin.
Liver and kidney
damage.
Leukemia; menstrual
disorders; damage to
blood-forming
organs.
Nose cancer in
animals; skin
allergy; asthma-like
allergies;
bronchitis.
Skin allergy;
numbness of the
tongue; liver
damage.
Liver, lung, and
kidney damage.
Nervous system
damage; skin
allergy; lung,
1iver, and kidney
damage; anemia.
Liver and kidney
damage; respiratory
irritation.
Acute
Effects
Eye, nose, throat,
and mouth irritant;
permanent blindness;
headaches,
dizziness, and
nausea; death
Irritation of the
eyes, nose, and
throat; loss of
muscle control; lung
irritation.
Headaches;
respiratory
discomfort or
failure.
Dizziness and
headaches;
convulsions and
coma; irritation of
the eyes, nose, and
throat.
Skin irritation and
burns; irritation of
the nose, mouth, and
throat; fluid in the
lungs; spasm of the
airway.
Skin irritation;
shortness of breath;
unconsciousness and
death.
Skin irritation;
eye, nose, mouth,
and throat
irritation; light-
headedness.
Headaches and
dizziness; swelling
around the eyes,
hands, and feet.
Skin or eye
irritation;
dizziness.
-------
with Increasing distance from the plant. For individual noncarcinogenic
pollutants, ambient concentrations outside the plant rarely will approach
levels causing threshold health effects. However, POTWs may emit chemical
mixtures consisting of several compounds with similar health effects. If the
cumulative health effects of these compounds are assessed, the combined
exposures may exceed threshold levels. Exposures to complex mixtures probably
will be most significant in areas where POTWs receive large amounts of
industrial wastewaters.
VQC Emissions
POTW operations contribute to ozone formation through emissions of
volatile organic compounds (VOC). These emissions can occur as an indirect
result of POTW treatment processes, and/or incineration of sewage sludge. Of
the approximately 1,500 pretreatment POTWs, 173 are located in ozone non-
attainment areas. No conclusions can be drawn regarding ozone nonattainment
areas and air emissions from POTWs, but one EPA study in Philadelphia
identified the city's largest POTW as the largest single source of unregulated
VOC emissions (455 kkg/yr) in the city. This study is described in the
following section. In drawing comparisons to ozone generation from VOC
emissions, there are several VOCs that are nonreactive (will not generate
ozone). These nonreactive VOCs are ethane, methane, 1,1,1-trichloroethane,
methylene chloride, and chlorinated fluorocarbons (CFCs). EPA also has
considered ruling that tetrachloroethylene is nonreactive.
In this analysis, total VOC emissions to the ambient air from POTWs were
estimated to range from 13,000 to 23,000 kkg/yr. This compares to the
approximately 19.9 million kkg/yr of VOC emissions from all sources nationally
(1983). Of this total, POTW emissions represent less than 1/10 of 1 percent.
This may be somewhat misleading, however, since no single source category
contributes more than a few percentage points to the totals Another way to
put VOC emissions from POTWs into perspective is to compare them to total
emissions from other VOC source categories.
As indicated earlier, the lack of site-specific data prevented more
detailed analysis of possible effects of POTW emissions on actual ozone
5-36
-------
concentrations in the ambient air. The 35 County Study suggested that a
significant portion of the VOC emission total from POTWs may be emitted by a
relatively small number of plants, probably no more than a dozen.*1U' These
plants receive a large amount of industrial wastewater and are probably among
the most significant VOC sources in those metropolitan areas where the plants
are located. The benefits of controlling VOC emissions and thereby reducing
ambient concentrations of ozone include reduction of both human health effects
and environmental damage. The health effects associated with ozone exposure
include both respiratory (lung function impairment and irritation of the
mucous membranes of the nose and throat) and nonrespiratory (eye irritation
and headaches) effects. The environmental benefits of reducing ozone
concentrations include reductions in damage to crops, forests, and ornamental
plants and materials. Reductions in ozone concentrations also improve
visibility. EPA has estimated the dollar value of controlling a ton of
ozone-producing VOC emissions to be $530, including all of the effects
mentioned above.* ' About half of the total benefits come from reductions in
agricultural crop damage.
EPA has no regulatory standards affecting VOC air emissions from POTWs.
As mentioned earlier, EPA is considering listing several compounds that are
emitted from POTW operations. Methylene chloride, tetrachloroethylene, tri-
chloroethylene, 1,2-dichloroethane, and chloroform are each candidates for
listing as hazardous air pollutants under Section 112 of the CAA. In
addition, methylene chloride and tetrachloroethylene are candidates for
regulation under Section 4(f) of the Toxic Substances Control Act.
In preparing for decisions on these compounds, EPA has developed
preliminary quantitative risk estimates for lifetime exposure to some of these
compounds. The following numbers represent plausible upper bounds of cancer
risk after a lifetime (70 years) of exposure. The unit risk factors were
obtained from the Carcinogen Assessment Group. The incidence estimates are an
aggregate estimate of the annual number of cases that might be expected.
These estimates were obtained by multiplying the lifetime risk estimates by
the number of people exposed and then dividing by 70 years.
5-37
-------
Compound
Chloroform
Tetrachloroethylene
Trichloroethylene
1,2-Dichloroethane
Maximum Individual
Lifetime Risk
2.0 x 10
1.3 x 10
1.1 x 10
5.0 x 10
-6
-6
-5
-4
Annual Incidence
Estimate
0.46
0.03
0.09
2.7
The Philadelphia Study
EPA has conducted multimedia environmental analyses in several metropol-
itan areas, notably Philadelphia, and that work has included assessments of
air emissions from POTWs. In developing the data base for the Philadelphia
study, the Philadelphia Water Department provided information on industrial
discharges to the city's Northeast Wastewater Treatment plant. This plant
received large discharges (over a ton a day) of volatile organics from a
single industrial facility. The onsite ambient air monitoring program was
conducted at one site upwind of the aeration basins and two sites downwind.
The results are summarized in Table 5-13. The differences between upwind and
downwind concentrations are striking, particularly for 1,2-dichloropropane and
1,2-dichloroethane.
A longer-term ambient monitoring program also was conducted in
Philadelphia. Ten monitoring sites were chosen, and samples were collected
every third day over a 90-day period. Earlier estimates of emissions from
volatilization at the POTW were made using mass balance calculations. These
emission estimates then were used in a dispersion model to estimate ambient
concentrations. In comparing observed to predicted concentrations, most
ambient measurements were higher than the predicted concentrations. The
difference appears to be due to incomplete assessment of some emission
sources and volatilization from sewer line wastewaters enroute to the POTW.
The study focused on methylene chloride, 1,2-dichloroethane,
1,2-dichloropropane, chloroform, carbon tetrachloride, trichloroethylene,
tetrachloroethylene, and benzene. The study's final emission estimates were
highest for 1,2-dichloropropane, 1,2-dichloroethane, and tetrachloroethylene
with 221 kkg/yr, 188 kkg/yr, and 41 kkg/yr, respectively. The emissions from
5-38
-------
TABLE 5-13. lEMD's AIR MONITORING RESULTS FOR PHILADELPHIA'S NORTH EAST MATER POLLUTION CONTROL PLANT
(ug/m3)
tn
I
CO
VD
Compound
Methylene Chloride
Chloroform
Carbon Tetrachloride
l,2-D1chloropropane
1,2-Dichloroethane
Trichloroethylene
Tetrachloroethylene
Benzene
Upwind
10/6/83
AM
1.71)
46. 40
NO
2.40
60.70
9.30
Downwind
10/6/83
AM Site 1
0.42
1.00
137.00
6. 80
1.80
90.20
3.10
Downwind
10/6/83
AM Site 2
1.70
54.50
2.60
2.10
13.60
0.77
Upwind
10/6/83
AM
0.77
20.40
1.50
29.60
5.00
Downwi nd
10/6/83
AM Site 1
0.24
1.80
102.00
8.30
4.W)
49.30
5.40
Downwi nd
10/6/83
AM Site 2
1.30
1.70
36.70
3.30
1.70
69.60
5.40
Upwind
10/7/83
AM
0.54
2.70
2.00
ND
6.70
11.80
12.30
Downwi nd
10/7/83
AM Site 1
1.40
0.06
2.30
569.90
242.40
21.30
149.00
5.40
Downwi nd
10/7/83
AM Site 2
0.95
2.10
318.60
135.80
10.70
69.50
4.00
Upwi nd
10/7/83
AM
0.95
0.12
ND
2.60
22.90
8.90
Downwi nd
10/7/83
AM Site 1
3.20
1.60
419.20
91.40
7.40
195.00
12.90
Downwi ni
10/7/83
AM Site ;
0.06
1.50
269.80
50.90
6.80
61.20
4.20
HIGHER DOWNWIND VALUES PARTICULARLY CLEAR FOR DCE AND DCP
-------
the POTW account for almost 50 percent of 1,2-dlchloropropane emissions and 30
percent of 1,2-dichloroethane emissions for the total metropolitan area. The
total emission estimate for volatilization of these eight compounds reached
455 kkg/yr. The POTW is probably the largest single source of VOC emissions
in the city. These discharges to the Philadelphia POTW have been linked to
the organic chemical industry.
EPA also estimated lifetime cancer risks associated with human exposure
to these eight compounds. Assuming that cancer risks are simply additive, the
cumulative maximum lifetime risk of cancer for the eight pollutants was
estimated at 5.6 x 10~ . ' Roughly 68 percent of that total is due to
-5
exposure to 1,2-dichloropropane at 3.8 x 10 , with 1,2-dichloroethane
-5
contributing another 21 percent at 1.2 x 10 . The other compounds contribute
the remaining 11 percent to the total risk.
In the Baltimore study, the maximum lifetime individual risk for benzene
emissions from the Patapsco POTW was estimated at 3.3 x 10"4.'13^ This was
based only on mass balance calculations and data obtained from EPA on bio-
degradation of specific compounds. No ambient monitoring was conducted.
Evaluation of air effects is perhaps the most difficult of the effects to
assess due to both a lack of applicable criteria and the lack of data on air
emissions from POTWs. What has been shown, however, is that large amounts of
pollutants are being emitted to the air. In fact, the air receives the
highest mass loadings of any of the receiving environments. Actual quan-
titative analysis supports the National loadings data that POTWs can be a
significant VOC source in a metropolitan area. Furthermore, there have been
documented effects of adverse impacts to worker health and safety from contact
with these volatile constituents. There is a considerable need for further
study of effects from air emissions at POTWs.
5.4 EFFECTS ON GROUND WATER
There are six possible pathways for the contamination of ground water by
the discharge of hazardous waste constituents to a POTW. These pathways are:
5-40
-------
Exfiltration from sewers
Leaks from unit processes at the wastewater treatment plant site,
including seepage from sludge piles
Land application of municipal sludge (land filling and land spreading)
Wastewater treatment lagoons
Land treatment of municipal wastewater
Deep well injection.
In 1985, EPA surveyed States to identify the major sources of ground
(14)
water pollution/ ' This was a qualitative survey based on indications
State employees had of their sources. The sources identified, in order of
most frequently cited were:
Leaking underground storage tanks
Septic tanks
Surface impoundments
Agricultural
t Municipal landfills
Onsite industrial landfills
Abandoned hazardous waste sites
Oil and gas brine pits
Other landfills
Salt water intrusion
Injection wells
Regulated hazardous waste sites
Highway de-icing
Land application/treatment.
The survey indicates that POTWs, including treatment tanks and collection
systems, are not considered a threat to ground water. On the other hand, they
may not be perceived as a problem simply due to a lack of available data.
Although not identified in the survey of States, exfiltration from sewers is
(15\
potentially of concern. In a 1977 Report to Congress1- ', the Agency iden-
tified municipal wastewater collection, treatment, and disposal practices as a
potential source of ground water contamination. The Report cited a few case
studies of ground water contamination resulting from such practices, but
5-41
-------
further reported that while widespread contamination may be suspected, "...the
magnitude is unknown." Further, the report focused on contamination from the
following constituents: dissolved and suspended solids, biochemical oxygen
demand, nitrates, and other commonly controlled pollutants.
Studies have shown that infiltration of ground water to sewers does occur
at many POTWs and under different hydrogeologic conditions, exfiltration is
possible. The fact that the collection system carries untreated raw waste-
water heightens the concern for the possible source. However, the lack of
information on the amount of exfiltration as presented in Chapter 4 limits
further analysis. Of the sources listed by the States, surface impoundments,
municipal landfills, salt water intrusion, injection wells, and land
application treatment are categories that could include POTW operations. All
of these categories are potential sources of hazardous constituents leaching
to ground water.
In response to Section 3018(c) of the HWSA of 1984, an EPA study is
underway to determine the impact of municipal wastewater treatment lagoons on
ground water. The lagoon study is to be completed by May 1987 and preliminary
results were not available for this report.
Land treatment systems include the disposal of treated effluents on land
for irrigation and further treatment of the wastewater by the soil. This
practice is conducted by just over 1,200 of 15,000 POTWs nationwide. POTWs
using this disposal method are required to perform thorough chemical analysis
and ground water monitoring. These facilities must comply with regulations
published in the Federal Register of February 2, 1976 (Vol. 41, p. 9160;
PRM 79-3, November 15, 1978), "Alternative Waste Management Techniques for
Land Treatment: Criteria for Best Practicable Waste Treatment Technology,"
that require disposal practices not to cause exceedances of drinking water
criteria at the point where the effluent mixes with the water table. Because
of the controls and regulatory scrutiny applied to land treatment systems,
these systems are assumed, for the purpose of this study, to produce minimal
ground water impacts.
5-42
-------
Deep well Injection of treated POTW effluents is limited to less than 100
of 15,000 facilities. Again, because of the regulatory scrutiny applied to
these facilities, they were assumed to produce minimal ground water impacts.
As a result of the above, this section is limited to a discussion of the
pollutants of concern in ground water, mobility of pollutants in soil, and
disposal of municipal sludge.
Siudge Disposal
The quantity of toxics in sludge that may enter ground water or the food
chain is directly related to the sludge disposal practices of the POTWs and
the amount of industrial flow that these POTWs receive. Fifty percent of
municipal sewage sludge either is disposed in landfills or is land applied.
As was demonstrated in earlier sections, the pretreatment POTWs receive the
bulk of the industrial flow. The sludge from these POTWs, therefore, can be
expected to contain most of the DSS pollutants. The fate of these substances
is highly dependent on the composition of the soil. The mobility of these
compounds depend on their reactivity with the soil components. The extent to
which they are taken up by plants and soil organisms depends on the individual
compound. Their degradability is dependent on their molecular structure, the
microbial population present, and climatic factors.
Table 5-14 is a summary of a survey of States' ground water monitoring
(14)
data/ ' The survey focused on volatile organic constituents, constituents
which are also of concern as DSS pollutants. However, as Table 5-2 demon-
strates, these pollutants will likely volatilize to air (24 or 43 percent) and
biodegrade in the treatment system (35 or 62 percent) if discharged to a POTW.
Little of the volatile organics in the influent will end up in the sludge (9
or 10 percent). As mentioned earlier, further studies may show that the
amount of volatiles removed to the sludge will be lower. The major concern of
volatile discharge to sewers resulting in ground water contamination is the
concern that wastewater may leak from pipes prior to reaching the POTW;
however, further study is needed before conclusions can be drawn about this
effect as a significant ground water contamination source.
5-43
-------
TABLE 5-14. SUMHARY OF NATIONWIDE GROUND WATER STATE
SUMKARIES OCCURRENCE DATA
(Random sample: n = 466)
Quantification'
Parameter limit ug/1
Tetrachloroethylene
Trichloroethylene
1,1,1-Tri chl oroethane
1,1-Dichloroethane
1 ,2-Di chl oroethyl enes
(cis and/or trans)
Carbon Tetrachloride
1 ,1-Di chl oroethyl ene
m-Xylene
o- + p-Xylene
Toluene
1,2-Dichloropropane
p-Dichlorobenzene
Ethyl benzene
Benzene
1,2-Dichloroethane
Vinyl Chloride
1,1,2-Trichl oroethane
1,1,1 ,2-Tetrachl oroethane
1,1, 2, 2-Tetrachl oroethane
Chlorobenzene
m-Dichlorobenzene
o-Di Chlorobenzene
Styrene
0.2
.2
.2
.2
.2
.2
.2
.2
.2
.5
.2
,5
.5
.5
.5
1
.2
.2
.5
.5
.5
.b
.5
, Positives
No.2
34
30
27
18
16
15
9
8
8
6
6
5
3
3
5
1
0
0
0
0
0
0
0
Percent
7.3
6.4
5.8
3.9
3.4
3.2
1.9
1.7
1.7
1.3
1.3
1.1
.6
.6
.6
.2
Median
ug/1 Max ug/1
0.5 23
1 78
.8 18
5 3.2
1.1 2
4 16
.3 6.3
.3 1.5
.3 .9
.8 2.9
.9 21
.7 1.3
.8 1.1
3 15
.6 1
1.1 1.1
Analytical detection limit
»
'Number of identifications above detection limit
5-44
-------
Table 5-2 shows that the major contribution to sludge comes from metals
(60 percent). The other pollutant classes provide only a minimal percentage
of mass to sludge. The DSS did not address zinc or copper, although these two
pollutants are major constituents of municipal wastewater and sludye.
Sludges are regulated by Subtitle D of RCRA (40 CFR Part 257) and
Section 405 of CWA. Subtitle D addresses RGBs, cadmium, and pathogens in
sludges that are land applied. In response to the Subtitle D regulation,
POTWs have been testing their sludge using the RCRA hazardous characteristics
test procedures: ignitability, corrosivity, reactivity, and EP toxicity. In
particular, the EP toxicity test has been considered most relevant for
characterizing sewage sludge. Based on these tests, most sludge has not been
shown to be hazardous. In the few cases where sludges were shown to be
hazardous, industrial discharge was the reason cited for failing the EP
toxicity test.
In response to the need for additional controls over municipal sludge
disposal, EPA currently is developing additional regulations pursuant to
Section 405 of CWA. Two approaches are being taken: one approach is to
develop State regulations for management of sludge disposal programs and the
second is to develop technical criteria for disposal of sludge. At this stage
in the regulatory development process, EPA has developed indices to prioritize
constituents in sludge that might be assessed. ^1&> These indices were used in
the following section to evaluate the DSS pollutants found in sludge.
These indices ranked 50 compounds found in sludge according to certain
effects that they might have in each disposal option. These indices were
calculated from the typical and worst case sludge concentrations. The
calculations of these indices were theoretical and, therefore, provide only a
qualitative measure of the effects of these compounds in sludge. The indices
considered multiple factors such as toxicity, uptake potential, mobility in
soil, and prevalence.
5-45
-------
The total industrial pollutant loadings (derived in Chapter 4) to sludge
by compound are shown in Table 5-1. The pollutants of greatest amounts in
sludge are shown in Table 5-15; they are phenol, chromium, methanol, toluene,
xylene, cyanide, bis(2-ethyl hexyljphthalate, nickel, and formaldehyde. The
presence of methanol in sludge is considered an artifact of the methodology
used in the DSS. The volume of methanol in the influent is so large that even
a small percentage being removed to sludge results in a large loading to the
sludge. Methanol in the influent will largely biodegrade or volatilize.
Hazard estimates for the land application of sludge were derived by EPA
for toxicity to soil biota, toxicity to predators of soil biota, phyto-
toxicity, plant uptake, toxicity to animals resulting from plant consumption,
toxicity to animals from sludge ingestion, human toxicity from plant con-
sumption, human toxicity from animal ingestion, and incidental soil ingestion
by humans. For landfilling, hazard indices were developed for ground water
contamination and human toxicity resulting from ground water contamination.
Table 5-16 shows the incremental hazard indices for landfilling of DSS
pollutants contained in sludge. These numbers represent the incremental risk
values associated with landfilling sewage sludge. These values give a
relative comparison of risk among the pollutants for specific environmental
pathways. RGBs, arsenic, and organic pesticides and herbicides are a problem
when sludge is land-filled, as are some metals. However, more mobile organic
compounds, such as benzene and trichloroethylene, also may create a hazard.
Table 5-17 shows the incremental hazard indices associated with the
various pathways related to land application of DSS pollutants. These indices
illustrate the significance of the bioaccumulation of toxics, particularly
organics, in the food chain. PCBs pose the most significant hazard, followed
by other organic herbicides and pesticides. Metals, such as cadmium, arsenic,
mercury, and nickel, are also a problem, but to a lesser degree.
Of the DSS compounds discharged in large quantities by industry, only
metals such as chromium, selenium, and arsenic are problems as indicated by
5-46
-------
TABLE 5-15. NATIONAL LOADINGS TO SLUDGE
Phenol
Chromium
Methanol
To!uene
Xylenes
Cyanide
Bis (2-Ethyl Hexyl)
Phthalate
Methylene Chloride
Nickel
Formaldehyde
Acclimated
1,533,465
1,482,736
1,441,726
1,002,541
985,010
820,099
794,416
730,743
528,218
485,158
Unacclimated Median Unacclimated Low
1,372,047
1,482,736
1,369,630
678,411
902,062
820,099
794,416
669,207
528,218
485,158
1,291,339
1,482,736
1,369,630
678,411
881,325
820,099
794,416
653,823
528,218
456,619
5-47
-------
TABLE 5-16. INCREMENTAL RANKING FOR LANDFILLING
Compound Incremental Value
>1000 Arsenic 51,000
PCBs 16,941
Chlordane 3,198
Toxaphene 2,045
Bis(2-ethyl hexyl)
phthalate 1,100
100-1000 NO POLLUTANTS
1-100 Trichloroethylene 56
Benzene 50
Cyanide 4.1
Mercury 3.3
<1 NO POLLUTANTS
Source: Reference No. 16
5-46
-------
TABLE 5-17. INCREMENTAL RANKING FOR LAND APPLICATION
Toxicity to Soil Biota
Predators
81.4
Cadmiurn
Aldrin/Dieldrin 1.5
Phytotoxicity
Cadmium 7.1
Chromium 1.4
Animal Toxicity from Plants
Cadmium1.0
Human Toxicity from Plants
PCB 14953.0
Chlordane 3100.0
Aldrin/Dieldrin 1300.0
Toxaphene 1245.0
Cadmium 95.0
Arsenic 1.5
Mercury
1.0
Human Toxicity from Animal Products Fed on Plants
PCB
Toxaphene
Chlordane
Aldrin/Dieldrin
Heptachlor
Mercury
Cadmi urn
64953.0
1345.0
180.0
100.0
7.0
2.75
2.5
Human Toxicity from Animals Ingesting Sludge
PCB
Aldrin/Dieldrin
Toxaphene
Chlordane
Hexachl orobutadi ene
Mercury
Cadmi urn
33947.0
9090.0
1845.0
448.0
130.0
12.5
2.2
Toxicity from Soil Ingestion
Arsenic 3100.0
PCB 171.0
Aldrin/Dieldrin 40.0
Chlordane 33.0
Toxaphene 21.0
Hexachlorobutadiene 8.9
Mercury 1.9
Cadmium 1.4
5-49
-------
TABLE 5-17. INCREMENTAL RANKING FOR LAND APPLICATION (Continued)
Human Aggregate Toxicity
109937.0
Aldrin/Dieldrin 11090.0
Toxaphene 4445.0
Chlordane 3900.0
Cadmium 100.0
Mercury 21.4
Nickel 11.9
Source: Reference No. 16
5-50
-------
the sludge indices for land application. Arsenic and organic compounds such
as bis(2-ethylhexyl)phthalate, trichloroethylene, and benzene are problems
with landfilling. On the other hand, certain metals and organics appearing in
large concentrations as determined by the 40 POTW study appear to have little
impact on ground water quality. Pollutants identified by EPA as problems when
landfilled or land applied, but not found to contribute major loadings in the
study are: zinc, molybdenum, copper, iron, hexachlorobenzene, benzo(a)pyrene,
DDT, heptachlor, lindane, and dimethylnitrosamine.
For the most part, the pollutants of concern from the sludge indices are
the same as those identified as being of concern in the DSS. Many pollutants
that were identified in the DSS as being of low concentration in the sludge,
such as chlordane or toxaphene, are still important in an overall analysis of
toxics in sludge. It is evident from the sludge indices that mass of
pollutants is not as important as a pollutant's toxicity. Thus, low level
concentrations of a pollutant, such as arsenic, are a significant risk if that
sludge is to be landfilled or landfarmed.
The sludge analysis has demonstrated that a potential for contamination
of surrounding or underlying soil and/or ground water does exist from disposal
of sludge containing DSS pollutants. An analysis of this type, nonetheless,
has many limitations; ground water contamination is a new field of study with
little available data on either ground water levels or the factors that affect
pollutant migration to ground water. Studies on contamination of land from
sludge disposal have largely focused on PCBs and cadmium and not on the
prevalent DSS or other priority pollutants.
5.5 CONCLUSIONS
The assessment of effects has been encumbered by the lack of specific
criteria and data on the distribution of DSS pollutant discharges to POTWs.
To the extent possible, this study estimated pollutant-specific loadings to
each of the respective receiving media. These data then were used, along with
supporting evidence from case studies, to make predictions on the possible
effects that could be expected from these discharges.
5-51
-------
The analysis predicted that between 82 and 92 percent of the hazardous
constituents could be removed from the wastestream by POTWs. The partitioning
of the pollutants will vary within chemical classification and type of
treatment system (acclimated and unacclimated).
Assessing effects in surface water requires an understanding of the
environment in which these POTWs discharge. Of those POTWs evaluated, a
majority discharge to small streams (i.e., these streams allow for a dilution
capacity of less than 25 to 1). Two separate assessments were conducted on
the effects of surface water discharges: an analysis of projected exceedances
of water quality criteria; and an evaluation of incidents demonstrating
effects from DSS discharges. Using two data bases, an evaluation of water
quality criteria exceedances was conducted for current conditions and after
PSES conditions. In both cases, exceedances were associated with both median
and low flow conditions at well-run secondary plants. Bioassays conducted on
POTWs with significant industrial contributions have demonstrated high levels
of toxicity to aquatic organisms. Many of these incidents have been tied to
industrial discharges. In many cases, a specific pollutant has been iden-
tified as the cause for the toxicity. In other cases, the pollutant has not
been identified. Additionally, the data show that environmental effects are
not necessarily related to the mass loading of the pollutants. Often, the
toxicity of a compound is primarily responsible for an effect, while the
concentration is only a secondary factor.
Effects from hazardous waste air emissions are difficult to characterize.
Between 24 and 42 percent of the volatile pollutants are emitted to the air.
Until recently, little attention was paid to volatile releases from POTWs.
While the direct source to the air is the POTW, the "actual" sources of a
large percentage of these pollutants are industrial users. Sampling and
analysis in Philadelphia served to heighten the awareness of how significant
POTW industrial users are as sources to total VOC emissions. This and other
studies have evaluated the potential risk to human life from uncontrolled
emissions emanating from a POTW. An immediate concern relates to the effects
on POTW workers of exposure to volatile compounds. There are 10 demonstrated
incidences of illness and 1 death from volatile emissions in POTWs. One
5-52
-------
reason that only 10 cases have been reported is that the odor threshold for
most of the volatile pollutants are above the toxicity level. Hence, while
adverse exposure could be occurring, pollutant levels are such that the worker
is unaware of the exposure. The pollutants shown to be released from POTWs to
the air are toxic and have significant health effects associated with their
exposure. Many of the pollutants identified in this study as a concern for
air emissions are now being considered for regulation by EPA under Section 112
of the Clean Water Act.
There are six possible pathways for contamination of ground water from
POTW effluent:
Exfiltration from sewers
Leaks from discrete unit operations at the wastewater treatment plant
Land application of municipal sludge
Wastewater treatment lagoons
Land treatment of municipal wastewater
t Deep well injection.
Because hazardous wastes are being discharged to sewers and infiltration is a
known problem with sewers, exfiltration may potentially produce ground water
contamination. Of the six possible pathways, exfiltration is the least known
and merits further study. Municipal sludge disposal and land treatment either
are regulated or are under consideration for regulation. Wastewater treatment
lagoons are being studied. As with water quality, the pollutants that
constitute the largest loadings to sludges are not the pollutants of concern
for land disposal of sludge.
The major conclusion that must be drawn from this effects analysis is
that further study is needed so that effects might better be assessed. In
particular:
Data on actual partitioning of hazardous pollutants in POTWs under
acclimated and unacclimated conditions are essential.
Increased monitoring is needed for measurement of volatile emissions
from POTWs, looking at all volatile constituents, to determine the
overall significance of this source.
5-53
-------
Further attention is warranted on detection and/or regulation of
volatile emissions that might adversely impact worker health and
safety.
Ground water quality data need to be gathered to assist in an
evaluation of municipal sludge disposal operations and POTWs as
possible contributors to ground water degradation; POTW exfiltration
warrants special attention.
More data need to be collected from bioassay programs. These should
be tied to full chemical characterization of the wastestream.
Sludge criteria should be developed, implemented, and enforced.
The preceding sections of this chapter have attempted to define the effects of
hazardous pollutant discharges to POTWs. Although some estimates have been
made, the strongest conclusion from the study has been that more data are
needed before effects can be assessed fully.
5-54
-------
CHAPTER 6
EVALUATION OF GOVERNMENT CONTROLS
ON HAZARDOUS WASTE DISCHARGES TO SEWERS
-------
-------
6. EVALUATION OF GOVERNMENT CONTROLS ON HAZARDOUS
WASTE DISCHARGES TO SEWERS
In the preceding chapters, the objectives of the Domestic Sewage Study
were presented and basic methods, such as pollutant selection, explained.
Major sources, types, and quantities of hazardous wastes discharged to sewers
were characterized and resultant releases to the environment and their effects
considered. The purpose of this chapter is to describe the effectiveness of
government programs in controlling the discharge of hazardous wastes to
sewers. In order to accomplish this, it is necessary to understand the
Resource Conservation and Recovery Act (RCRA), the Clean Water Act (CWA) and
the interaction of these statutes as a result of the discharge of hazardous
wastes to sewers, allowed under RCRA's Domestic Sewage Exclusion. In addi-
tion, other statutes that may control effects associated with the discharge of
hazardous wastes to sewers may be relevant, including the Occupational Health
and Safety Act, the Clean Air Act, and the Comprehensive Environmental
Response, Compensation, and Liability Act. (State and local laws also control
such effects to varying degrees.) The applicability of recent Agency efforts
to protect ground water is also discussed.
This chapter takes the following approach in explaining how hazardous
wastes come to be discharged to sewers and how existing government controls
regulate them:
6.1 - Rationale for Hazardous Waste Discharges to Sewers - brief overview
of RCRA and CWA; discussion of origins and implications of the
Domestic Sewage Exclusion and other routes by which POTWs receive
hazardous wastes.
6.2 - Statutory Mechanisms Controlling Hazardous Waste Discharges -
detailed analysis of RCRA, CWA, and other statutes which may
regulate DSE wastes; focuses especially on RCRA generator and TSDF
requirements and CWA pretreatment program.
6.3 - Evaluation of the Effectiveness of Pretreatment - examination of
the ability of pretreatment controls to address DSE wastes at the
National and local level.
6.4 - Conclusions - summary assessment of regulatory mechanisms under
RCRA, CWA, and other statutes affecting hazardous waste discharge
: to POTWs.
6-1
-------
6.1 RATIONALE FOR HAZARDOUS WASTE DISCHARGES TO SEWERS
6.1.1 RCRA/CWA Overview
This subsection briefly describes generation and treatment, storage and
disposal obligations under RCRA, and wastewater treatment and pretreatment
requirements under the CWA so that the reader has sufficient background to
understand the operation of the Domestic Sewage Exclusion. More detailed
discussions of RCRA and CWA are provided in Section 6.2 of this chapter.
The goal of the RCRA program is to require "cradle to grave" management
of hazardous wastes. RCRA coverage begins when a person or firm produces a
waste. The firm is required to categorize its waste, applying a two-part
regulatory test. First, the waste producer must determine if the waste is a
"solid waste," since, under RCRA, only solid wastes can be deemed hazardous
wastes. If the waste is a solid waste, then the firm is obligated to deter-
mine if it is also a hazardous waste (either a characteristic or listed
waste). The person or firm producing a waste which is hazardous is termed a
generator under RCRA. Generation of a hazardous waste marks the "cradle" in
the cradle-to-grave management chronology. Transportation, treatment, storage
and disposal of this hazardous waste then must be subject to a paper trail and
hazardous waste management requirements under RCRA. A generator must notify
EPA that he has produced a hazardous waste and must receive an EPA identifi-
cation number. If he ships the waste offsite for treatment, the receiving
treatment, storage and disposal facility must be authorized under RCRA to
receive the waste.
If the hazardous waste is transported off the generator's property, the
transporter is regulated by the hazardous waste management system, including
relevant Department of Transportation regulations. Further, the person
accepting such waste for treatment, storage, or disposal is also subject to
the RCRA regulatory framework, and thus must notify the Agency of this
activity. In accord with this scheme, over 73,000 generators, transporters,
and treatment, storage, and disposal facilities (TSDFs) of hazardous wastes
have notified EPA and the States (see Figure 6-1, taken from Summary Report on
RCRA Activities September, 1985, dated November 5, 1985). This number is
6-2
-------
G«n«infor
National Total: 56,002
I2S4S678910
Transporter
National Total: 12.549
23456
Rvgloni
7 a 9 *0
TSD
Naiionat Told: 4.867
I 23456764 10
Region*
FIGURE 6-1. GENERATORS, TRANSPORTERS, AND TSD'S (As of 9/30/85)
-------
expected to soon increase by another 100,000 to 175,000 establishments as the
new requirements for small quantity generators are imposed in the 1984 RCRA
Amendments. Hazardous waste TSDFs are subject to permitting requirements in
addition to notification requirements.
Hazardous wastes may be treated and then disposed in ways affecting all
environmental media air emissions from incinerators, wastewater discharges
from treatment systems, underground injection, soil and ground water con-
tamination from land treatment and disposal. The RCRA program controls
disposal of hazardous waste no matter what environmental media are involved.
The regulatory interest is in the management of hazardous waste, not just the
manner of disposal.
In contrast, the Clean Water Act principally protects one medium, the
Nation's waters, and accomplishes this by controlling the discharge of
pollutants from point and nonpoint sources. Although there are provisions of
CWA which require an assessment of environmental effects on other media, these
are aimed at incidental benefits rather than serving as central objectives.
The primary target of CWA is the wastewater discharger, whether that facility
discharges directly to the Nation's waters or indirectly, through a POTW.
This DSS report evaluates indirect dischargers to POTWs, parties controlled by
the National Pretreatment Program.
Whereas the RCRA program regulates any waste defined as hazardous, the
focus of CWA pretreatment programs is, first, on 34 industrial categories and
126 toxic pollutants, although it may, by statute, regulate additional
pollutants and industries. These industries are commonly referred to as
categorical industries and the 126 toxic pollutants are referred to as
Section 201 requires the Administrator to encourage waste management which
will result in "...the ultimate disposal of sludge in a manner that will not
result in environmental hazards." Section 304 requires that, in developing
technology-based guidelines, the Agency consider nonwater quality impacts.
The pretreatment regulations require that POTWs develop programs capable of
protecting sludge quality. The criteria for evaluating alternative waste
management techniques employing land application and land utilization
practices requires that the ground water affected meet drinking water stan-
dards for aquifers which can be potentially used for drinking water supply.
6-4
-------
priority pollutants. Indirect dischargers that are categorical industries
must make sure that wastewaters they discharge to publicly owned treatment
works (POTWs) comply with National pretreatment standards promulgated by EPA.
Industrial wastewaters, discharged by any nondomestic source to sewers,
which might do harm to POTWs or the environment, are regulated by specific
prohibitions under the pretreatment program. In addition, to ensure site-
specific regulation of indirect dischargers (also commonly referred to as
industrial users or "IUs,") approximately 1,500 POTWs nationally have been
required to have Federally approved local pretreatment programs. POTWs with
Federal programs are required to develop and implement additional procedural
and substantive controls (e.g., industrial waste surveys, local limits, etc.)
to protect plants and the environment. Other POTWs, not s.ubject to general
pretreatment requirements, are also required to develop local limits when
pollutants cause interference or pass through and such violations are likely
to recur.
The universe of facilities affected by the pretreatment program numbers
nearly 1,500 POTWs, approximately 14,000 categorical industries, and an
unknown number of noncategorical industries. In addition, all 15,000-plus
POTWs must enforce general and specific prohibitions contained in the General
Pretreatment Regulations. The RCRA program regulates about 73,000 generators,
transporters, and treatment, storage, and disposal facilities. It should be
noted that some facilities are regulated by both programs. Of special
interest to the Domestic Sewage Study are RCRA generators which are indirect
dischargers and POTWs which receive these wastes, either as a RCRA TSDF or
otherwise.
6.1.2 The Domestic Sewage Exclusion: Origins and Implications for
Generators/Industrial Users" -
This subsection explains how and why generators/IDs are allowed, under
RCRA, to discharge hazardous wastes to sewers as a result of the so-called
Domestic Sewage Exclusion (DSE). The DSE excludes "any mixture of domestic
sewage and other wastes that pass through a sewer system to a publicly owned
treatment works for treatment" from being defined as solid waste under RCRA.
For a waste to be considered hazardous under RCRA, it must first be a solid
6-5
-------
waste. Since this regulation provides that any indirect wastewater discharges
mixed with sewage in the sewer cannot be considered a solid waste, the
practical effect of the DSE is to exempt all industrial discharges that mix
with domestic wastes in the sewer system from RCRA manifesting and management
requirements, with the exception of RCRA notification requirements. It should
be noted that the exclusion is not explicitly conditioned on compliance with
other environmental controls (e.g., CWA, pretreatment standards) but on the
basis that a waste which is not defined as a RCRA solid waste cannot be a
hazardous waste.
6.1.2.1 Origins of the DSE
The DSE originated in the Solid Waste Disposal Act (SWDA) of 1965. The
1965 Act authorized limited research and grant programs to study solid waste
disposal practices, but excluded research on domestic sewage disposal from
inclusion, since construction grants were available under the Federal Water
Pollution Control Act to study and treat domestic sewage. The exclusion, at
this point, was not regulatory in nature, and did not revolve around the
distinction between solid and hazardous wastes, mentioned above.
The Resource Conservation and Recovery Act of 1976 (amending the SWDA)
required regulatory controls for dumping of solid wastes and for the genera-
tion, transportation, treatment, storage, and disposal of hazardous wastes.
The 1976 Act included the DSE in Section 1004(27) as a carry-over from the
1965 Act, although the legislative history did not specifically address the
intent behind the exclusion.
The 1980 RCRA regulations, implementing the 1976 Act, interpreted the DSE
to apply both to sanitary sewage and to mixtures of sanitary wastes with other
wastes in a sewer system as discussed above [See 40 CFR 261.4(a)(l)]. This
interpretation was based upon the Agency's determination that the legislative
policy reflected in the 1965 Act would also exempt mixed wastestreams since
they too would be subject to controls under the Clean Water Act. The preamble
to the 1980 RCRA regulations stated that not only did the construction grants
program provide financial assistance for the proper treatment of such wastes,
but that the pretreatment program also provided a basis to assure that
environmental problems did not result (See 45 FR 33097, May 19, 1980).
6-6
-------
The preamble did point out, however, that the exclusion was not based
upon any determination about the health and environmental risks presented by
such waste streams. As a matter of fact, the preamble acknowledged, some
mixtures of domestic sewage with other wastes may indeed present environmental
risks.
6.1.2.2 Regulatory Interpretation of the DSE
The Agency interpreted the exclusion to apply solely to wastes discharged
to POTWs, because only public sewage treatment plants are subject to the
construction grant and pretreatment programs. Consequently, the DSE is not
available to privately owned treatment works. The rationale for the DSE is
not that wastes mixed with domestic sewage are rendered harmless, but that
sufficient regulatory controls existed via the Clean Water Act, in particular
through the pretreatment program.
Another basic issue surrounding the DSE is when it takes effect. Since
the exemption only applies to nondomestic wastes which mix with domestic
sanitary wastes in a POTW, it is necessary to determine just when mixing
occurs. The Agency's interpretation is that the exemption begins when the
waste "...first enters a sewer system that will mix it with sanitary wastes
prior to storage or treatment by a POTW" (Federal Register 33097, May 19, 1980
emphasis added). Thus, the DSE may actually apply prior to actual mixing with
domestic sewage. The location and timing of the application of the exclusion
are also important because solid wastes may be deemed hazardous and subject to
RCRA requirements until "first entry." Industrial user responsibilities under
RCRA and the DSE are discussed further in Section 6.2 of this chapter.
6.1.3 Implications of DSE for POTUs and Other Routes for Hazardous Waste
Discharge to Sewers
As explained above, an industrial user, discharging wastes to sewers
pursuant to the DSE, is not releasing solid wastes, and by definition not
releasing hazardous wastes, to the POTW, Likewise, the POTW receiving these
wastes (hereinafter referred to as DSE wastes) is not receiving hazardous
wastes. Therefore, the POTW does not automatically become a treatment, stor-
age, and disposal facility as would other offsite waste treatment facilities
6-7
-------
under RCRA. Instead the POTW is simply receiving an industrial wastewater
discharge which may be subject to National and local pretreatment standards.
The only way that the POTW, receiving DSE wastes (and no other hazardous
waste) enters RCRA's hazardous waste management program is if, as a result of
wastewater treatment, the POTW produces a sludge which is determined to be
hazardous when tested under RCRA testing procedures (i.e., extraction pro-
cedures (EP) toxicity). The POTW that produces a hazardous sludge is a
generator subject to RCRA notification, identification, recordkeeping, and
waste management requirements. It should be noted that using current extrac-
tion procedures, few, if any, municipal sludges have been identified as haz-
ardous. If the POTW, in turn, decides to treat, store, or dispose of its own
hazardous sludge onsite, it also becomes a TSDF, subject to RCRA management
and permitting controls. If it ships its hazardous sludge offsite for
treatment or disposal, the POTW must comply with recordkeeping, manifesting,
and other controls imposed on hazardous waste generators. In Section 6.2 of
this chapter, a detailed discussion of POTW responsibilities as a hazardous
waste generator and/or TSDF are presented.
POTWs are regulated under RCRA by a second method if they receive
hazardous wastes by truck, rail, or dedicated pipe. POTWs accepting hazardous
waste in this manner are considered TSDFs. However, since these POTWs are
subject to environmental permitting under the CWA's National Pollutant
Discharge Elimination System, under EPA regulation these facilities are
eligible for a RCRA permit-by-rule provided certain requirements are satis-
fied. Further discussion is also provided in Section 6.2 on RCRA permit-
by-rule provisions. Under permit-by-rule requirements and the General
Pretreatment Regulations, a POTW may not accept hazardous waste received by
truck, rail, or dedicated pipe unless the wastes meet Federal and local
pretreatment requirements. In practical terms, then, hazardous wastes
received by these transport methods must be treated by industry to the same
extent that DSE wastewater discharges are to comply with pretreatment stan-
dards. However, POTWs receiving wastes by these transport methods need a RCRA
permit, while those receiving only DSE wastes do not. This distinction has
consequences for the corrective action requirements under the Hazardous Solid
Waste Amendments of 1984, discussed later.
6-8
-------
6,2 RELEVANT RCRA, CWA, AND OTHER STATUTORY/REGULATORY REQUIREMENTS
The sections above introduced the Domestic Sewage Exclusion and described
generally how it affects industrial user and POTW responsibilities under RCRA,
both in terms of generation and treatment, storage, and disposal obligations.
This subsection provides a more detailed analysis of hazardous waste manage-
ment under RCRA and applicable CWA controls on IUS and POTWs, including
pretreatment, permitting, and sludge disposal requirements. A discussion of
OSHA, Clean Air Act, and CERCLA provisions affecting hazardous wastes dis-
charged to sewers is also included.
6.2.1 RCRA's "Cradle to Grave" System
6.2.1.1 Waste Identification and Notification
As discussed briefly above, RCRA's regulatory framework is triggered by
the determination that a solid waste is a hazardous waste. The Agency has
established two methods by which a solid waste may be determined to be
hazardous: (1) if it exhibits hazardous waste characteristics (ignitability,
corrosivity, reactivity, and EP toxicity); or (2) if it is listed as such by
the Agency. These were discussed previously in Chapter 2.
Finally, a solid waste may be a hazardous waste if it is a waste mixture,
composed of both a hazardous waste and a solid waste. In the case of a waste
mixture composed of a listed hazardous waste and a solid waste, the mixture
rule {40 CFR 261,3) applies and the solid waste must be handled as a hazardous
waste when the listed waste is added. On the other hand, a solid waste mixed
with a nonlisted characteristic waste or a waste listed because it exhibits
hazardous characteristics need not be a hazardous waste if it does not exhibit
the characteristics of a hazardous waste. Steps 1-5 of Figure 6-2 show how a
waste is considered to be a hazardous waste.
6.2.1.2 Notification Requirements
RCRA 3010(a) requires that any person (generators, transporters, and
treatment, storage, and disposal facilities) handling a hazardous waste must
file a notification within 90 days of the first EPA regulations identifying
6-9
-------
KHM TO PHNCTIOi PROCESS
f-MoucTioi MOCESS
NOTE IS OKMTEB
EXEMPT raM FOUOHIK KM
GEKMTOR MQUIREMKTS:
HHIFEST
BIEMIM. (WWTS
EICEPTIOI KFWTS
PK-TMMSHM
261.4
cn
i
FIBST CRIEItS* SEHJI.
0 LOMtft It SOLID WSTC
PER 261.4 UOUSltM
M50 SEE 3018(4) cUrlftutio* (SUp U)
FIGURE 6-2. WHEN IS A WASTE A HAZARDOUS HASTE?
THE CASE OF THE INDUSTRIAL USER
-------
wastes as hazardous. (For subsequent regulations identifying wastes as
hazardous, notification is required when expressly called for by EPA.)
6.2.1.3 Generator Requirements
A generator of hazardous waste must have an EPA identification number
(see 40 CFR 262.12} prior to transporting, treating, storing, or disposing of
the hazardous waste. A regulated generator also must not deliver hazardous
waste to any transporter or treatment, storage, and disposal facility that
does not have an EPA identification number itself. Generators also need to
keep records of test results, waste analyses, or any other determination that
their waste is a hazardous waste for at least three years from the date the
waste was last sent for treatment, storage, or disposal (40 CFR 262.40).
These aspects of generator requirements are shown as step 6 of Figure 6-2 and
must be met by facilities that treat, store, or dispose onsite as well as
those that treat, store, or dispose offsite.
If a generator plans to treat, store, or dispose of a waste offsite, the
generator must fill out an EPA a manifest form containing the following
information for each load of hazardous waste shipped:
Generator name, address, telephone number and EPA identification
number
Transporter name and EPA identification number
Name, address, and EPA identification number of permitted facility
receiving waste
Description of hazardous wastes transported
Waste quantities, types, and number of containers
t Certification for proper packaging, marking, labeling and
transportation
Waste minimization certification
Manifest document number.
Upon delivery of waste to the transporter, the generator should sign and
date the manifest, have the transporter sign the manifest, retain one copy,
6-11
-------
and provide the transporter with all remaining copies. A generator who does
not receive, within 35 days, a manifest copy signed by the facility designated
to receive the waste must contact the transporter and designated facility to
determine what happened to the waste. The generator who has not received,
within 45 days, a signed manifest copy must submit an exception report to the
EPA Region,
Before transporting any hazardous waste offsite, a generator must comply
with packaging, labeling, marking, and placarding requirements. Generators
that ship their hazardous wastes offsite must prepare and submit a report to
the appropriate EPA Region of each even-numbered year. This report covers
hazardous waste generator activities during the previous odd-numbered calendar
year.
o
6.2.1.4 IU Responsibilities as a Generator
As discussed above, the Domestic Sewage Exclusion goes into effect when
the wastes "first enter" the system. However, this exclusion does not work to
exempt an industrial user from all RCRA requirements. If the industrial user
generates a waste during the production process, and if that waste fits the
extremely broad definition of a solid waste (step 3), then unless the solid
waste is excluded under the 261.4 exemptions (step 3A), the generator must
test to see if the solid waste is a hazardous waste.
RCRA and the implementing regulations define the term solid waste
broadly. According to 40 CFR 261.2, a solid waste is any "discarded material"
not specifically excluded from the definition. This may include solid,
liquid, semisolid, or contained gaseous materials. It also includes certain
waste materials which are recycled or reclaimed.
The next step (3A) is to determine whether the waste is excluded. Two
significant exclusions are the DSE, discussed before, and the wastewater
treatment exemption which applies to industrial wastewater discharges for
point source discharges subject to NPDES permits. Both exclusions have limits
to their application.
'All steps refer to Figure 6-2.
6-12
-------
In the case of the domestic sewage exemption, the preamble to the May 19,
1980 RCRA regulations (Fed. Reg. 33097) state that the exemption takes effect
when the waste "...first enters..." the sewer system. Consequently, if a
solid waste was generated prior to entry, the dischargers would need to meet
steps 4A, 4B, and 5, and thereby determine whether the solid waste was a
hazardous waste. If so, the discharger must obtain an identification number
and meet applicable recordkeeping requirements, e.g., maintenance of test
records. These are the same requirements that need be met by all generators
who treat, store, or dispose of hazardous wastes onsite. ---
This view is consistent with the Agency's interpretation of the limita-
tions on the industrial wastewater exclusion, which appears as a comment to 40
CFR 261.4. The substance of the comment is that the exclusion of industrial
wastewater discharges from the definition of solid waste "...applies only to
the actual point source discharge. It does not exclude industrial wastewaters
while they are being collected, stored, or treated before discharge, nor does
it exclude sludges that are generated by industrial wastewater treatment."
Consequently, an IU whose discharge is destined for treatment at a POTW is not
exempted from all generator requirements if he generates a hazardous solid
waste. Such dischargers must test to see if the solid waste is hazardous, and
if it is hazardous, notify the Agency of generator activities, obtain an ID
number and maintain records of testing for hazardousness (step 6).
If the waste is discharged to a POTW prior to any treatment, storage, or
disposal at the facility, at "first entry" the hazardous waste is no longer a
solid waste or, consequently, a hazardous waste. The DSE defines away the
regulated status of the discharge, although it may actually retain the
characteristics of a hazardous waste. The generator is excluded from further
RCRA generator requirements, including manifesting, pretransport requirements,
recordkeeping requirements for the manifest, and reporting requirements. If
the waste is treated onsite, any sludges generated from the facility's
wastewater treatment operation must also be tested for hazardousness (step 9).
Thus, the Ill's responsibilities under a DSE scenario are similar to the
generator with an onsite treatment, storage, or disposal facility. This
appears to give lUs an incentive not to treat wastes prior to discharge to the
6-13
-------
sewer. However, pretreatment requirements directly counter this result by
mandating treatment to achieve limits.
Although the DSE simplifies some industrial user RCRA responsibilities,
it complicates industrial users' RCRA reporting responsibilities. Do they
need to notify, must they receive an EPA identification number, etc.? Section
3018(d) of RCRA, added by the 1984 Amendment, clarifies that Section 3010
notification requirements apply to "...solid or dissolved material in domestic
sewage...." However, the Agency has not yet implemented this provision.
Notification forms have not been changed, and, apparently, few lUs have
notified.
6.2.1.5 POTW Responsibilities as a Generator
As discussed previously, a POTW may generate sludge with hazardous
characteristics as a result of the receipt of domestic and nondomestic wastes.
In this event, the POTW, like the IU» must meet all generator requirements for
these sludges. Also, like the industrial user, the type of generator require-
ments with which the POTW must comply differ depending on whether the waste is
disposed on or offsite. If the hazardous waste is to be treated, stored, or
disposed offsite, the generator must meet manifesting, pretransport, and
certain recordkeeping and reporting functions with which an onsite TSDF would
not need to comply with. Figure 6-3 illustrates POTW generator responsibi-
lities.
Incidentally, even if a POTW's sludge is not hazardous, the receipt of
hazardous waste may influence its ability to dispose of its sludge under the
land disposal criteria of Subtitle D of RCRA (40 CFR 257). 40 CFR 257
establishes criteria to determine which solid waste disposal facilities and
practices pose a reasonable probability of adverse effects on human health or
the environment. The criteria also provide guidelines for sewage sludge use
and disposal under Section 405{d) of CWA. These land disposal regulations
Since January of last year, the number of generators which appear in HWDMS as
notifiers has increased by about 6,800 (56,002 - 49,236 = 6,766). Source:
Summary Reports of RCRA Activities, OSW, USEPA. However, it has not been
determined why the increase has occurred, and it may have very little to do
with IU notifications.
6-14
-------
01 SUBJECT TO
IRIERIM STATUS OR
KMIT STNBMD US ISO's
265.1(c){10>
264.1(g)(«)
KTMO A:
261.IZ
262.34
2tt.«(c) and (d)
0
MUMDOUS
IMS1ES
nETKftTIOT MSTES
270.60(c)(4>
FIGURE 6-3. THE POTU AS A GENERATOR AND TSDF
-------
prohibit any sludge disposal practices that lead to the contamination of
ground water beyond the maximum contaminant levels established by the Safe
Drinking Water Act. In addition, these regulations also prohibit the land
application of any solid wastes containing cadmium and PCBs except under
prescribed conditions.
6.2.1.6 TSDF Requirements
- Overview
The acronym TSDF stands for treatment, storage, and disposal facility.
The majority of RCRA requirements deal with the regulation of these facili-
ties. The terms "treatment," "storage," and "disposal" are defined in 40 CFR
260.10(a) and appear in Table 6-1. The term "facility" and "disposal
facility" are defined in 40 CFR 260.lO(a) as well. These terms also appear on
Table 6-1. As can be seen from these definitions, a POTW which treats,
stores, or disposes of hazardous wastes is a RCRA TSDF.
Section 3004 of RCRA lists minimum TSDF requirements that the Agency's
regulations need to address (see Table 6-2). In response to this statutory
mandate, the Agency has developed two sets of regulations, one set for
"interim status" facilities (40 CFR 265) and a second set for "permitted"
facilities (40 CFR 264). Interim status is conferred on qualifying existing
TSD facilities until such time as they are issued a permit. The development
of interim status was based on the realization by Congress in Section 3005(e)
that an interim period was necessary to allow existing TSD facilities meeting
certain interim standards to operate until such time as the Agency could issue
a permit. A second set of standards, more stringent in many cases, are the
Section 264 permitting standards. Figure 6-4 (taken from "Summary Report on
RCRA Activities, September 1985") details the number of TSDFs projected to
require permits.
In response to the Congressional mandate for TSDF regulations, the Agency
fashioned the 264 and 265 requirements into the following subparts:
General Facility Standards, including such things as waste analysis,
security, inspection, personnel training requirements, and location
standards
6-16
-------
TABLE 6-1. RCRA DEFINITIONS FROM 40 CFR 260.10
"Treatment" means any method, technique, or process, including
neutralization, designed to change the physical, chemical, or biological
character or composition of any hazardous waste so as to neutralize .such
waste, or so as to recover energy or material resources from the waste, or so
as to render such waste nonhazardous, or less hazardous; safer to transport,
store, or dispose of; or amenable for recovery, amenable for storage, or
reduced in volume.
"Storage" means the holding of hazardous waste for a temporary period, at
the end of which the hazardous waste is treated, disposed of, or stored
elsewhere.
"Disposal" means the discharge, deposit, injection, dumping, spilling,
leaking, or placing of any solid waste or hazardous waste into or on any land
or water so that such solid waste or hazardous waste or any constituent
thereof may enter the environment or be emitted into the air or discharged
into any waters, including ground waters.
"Disposal facility" means a facility or part of a facility at which
hazardous waste is intentionally placed into or on any land or water, and at
which waste will remain after closure.
"Facility" means all contiguous land, and structure, or other
appurtenances, and improvements on the land, used for treating, storing, or
disposing of hazardous waste. A facility may consist of several treatment,
storage, or disposal operational units (e.g., one or more landfills, surface
impoundments, or combinations of them).
6-17
-------
TABLE 6-2. MINIMUM STATUTORY TSDF REQUIREMENTS
"(1) maintaining records of all hazardous wastes
identified or listed under this title which is treated,
stored, or disposed of, as the case may be, and the
manner in which such wastes were treated, stored, or
disposed of;
(2) satisfactory reporting, monitoring, and
inspection and compliance with the manifest system
referred to in Section 3002(5)
(3) treatment, storage, or disposal of all such waste
received by the facility pursuant to such operating
methods, techniques, and practices as may be
satisfactory to the Administrator
(4) the location, design, and construction of such
hazardous waste treatment, disposal, or storage
facilities
(5) contingency plans for effective action to
minimize unanticipated damage from any treatment,
storage, or disposal of any such hazardous waste
(6) the maintenance of operation of such facilities
and requiring such additional qualifications as to
ownership, continuity of operation, training for
personnel, and financial responsibility (including
financial responsibility for corrective action) as may
be necessary or desirable
(7) compliance with the requirements of section 3005
respecting permits for treatment, storage, or disposal."
6-18
-------
Storage and Treatment
National Total: 3,009
12345678910
ftogtont
Incineration
National Totd: 192
123456789)0
Disposal
National total: 1.304
12)43678910
Undassiffed
National Totat 362
FIGURE 6-4. TSD'S PROJECTED TO REQUIRE PERMITS (As of 9/30/85)
-------
Preparedness and Prevention, including communication and emergency
equipment plans
Contingency Plans, discussing facility plans and actions to be taken
in response to unplanned or hazardous situations
Manifest, Recordkeeping, and Reporting, including the maintenance of
operating records
Ground Water Protection, including requirements for monitoring and, in
the case of permitting standards, taking action to respond to releases
Closure and Post-Closure, discussing means to control, minimize, or
eliminate threats to numan health and the environment upon the
shutdown of a unit
Financial Responsibility, including the demonstration of the
facility's financial ability to close the facility, ensure post-
closure care, and demonstrate financial responsibility for bodily harm
and property damage to third parties
Technical Standards for Treatment, Storage, and Disposal Facilities,
with distinct requirements for tanks, surface impoundments,'waste
pile, land treatment, landfill, and incinerator facilities.
As stated above, all TSDFs must have interim status, or a RCRA permit, to
continue to operate as a hazardous waste treatment, storage, or disposal
facility. Certain types of hazardous waste management units (i.e., wastewater
treatment tanks and elementary neutralization units) have been exempted from
the requirements of 264 and 265. In addition, other types of facilities,
including publicly owned treatment works, have been exempted from these
requirements "...to the extent they are included in a RCRA permit by rule...."
[40 CFR 264.l(e)].
- The POTW as TSDF
The permit-by-rule requirements appear in 40 CFR 270.60(c). These
requirements were developed for POTWs accepting hazardous wastes brought to
the POTW by truck, rail, or dedicated pipe for treatment (Federal Register,
33097, May 19, 1980). Therefore, the permit by rule does not cover all POTWs
treating, storing, or disposing hazardous waste.
As described earlier, a hazardous waste discharged into the sewer system
pursuant to the DSE is no longer legally a solid waste, or a hazardous waste,
6-20
-------
upon "first entry" into the system. However, a POTW can generate a
"characteristic" hazardous waste, especially if it receives substantial
concentrations of DSE wastes. Facilities generating hazardous wastes as a
result of DSE influents would not be candidates for RCRA permits by rule
unless they also received hazardous wastes by the modes of transport listed
above.
6.2.1.7 Permit-by-Rule
A permit by rule has several important differences from a conventional
RCRA TSDF permit with regard to the degree to which RCRA regulations apply.
POTWs subject to RCRA permits by rule are only subject to a subset of RCRA
requirements. According to 270.60(c), a POTW receiving hazardous waste by
train, truck, or dedicated pipe for treatment may receive a RCRA permit by
rule if the facility:
(1) Has a NPDES permit
(2) Complies with the conditions of the permit
(3) Complies with the following regulations
(i) 40 CFR 264.11, identification number
(ii) 40 CFR 264.71, use of manifest system
(iii) 40 CFR 264.72, manifest discrepancies
(iv) 40 CFR 264.73(a), and (b)(l), operating record
(v) 40 CFR 264.75, biennial report
(vi) 40 CFR 264.76, unmanifested waste report
(4) If the waste met all Federal, State, and local pretreatment
requirements.
In the July 15, 1985 Federal Register, EPA promulgated the so-called
"codification rule" modifying its regulations to reflect many of the 1984
Amendments. As part of that rule, EPA added Section 270.60(c)(3)(vii)
requiring POTWs with permits issued after November 8, 1984 to comply with
Section 264.101 corrective action requirements. That provision, also added in
the July 15, 1985 Federal Register, has far ranging effects which are
discussed below. ;
6-21
-------
The substance of the permit-by-rule requirements, with the exception of
the newly added corrective action requirement, has a dual purpose: (1) to
"close the loop" of the manifest system, by requiring the POTW to meet
manifest and reporting requirements; and (2) to ensure that all wastes
received by truck, rail, or dedicated pipe at a POTW meet pretreatment
requirements and are thus controlled by Clean Water Act authorities. This
requirement acts to protect the POTW, sludge quality, and water quality.
In their current form, the permit-by-rule regulations do not include the
remaining substantive requirements (i.e., surface impoundment technical
standards, closure and post-closure care, and financial responsibility) with
which TSDFs subject to individual RCRA permits must comply. The permit-by-
rule was based on the assumption that the combination of pretreatment require-
ments and treatment at the POTW would provide sufficient protection to human
health and the environment.
POTWs that generate hazardous waste and treat, store, and dispose of
hazardous wastes are subject to more complete RCRA TSDF requirements. POTWs
that do require conventional RCRA permits must meet not only the pre-HSWA
Section 264 or 265 permitting or interim status requirements, but also newer
HSWA requirements.
6.2.1.8 Corrective Action Requirement
RCRA contains two new corrective action provisions: (1) Section 3004(u)
which provides that all facilities seeking a permit must conduct corrective
actions for releases of hazardous wastes or constituents from solid waste
management units; and (2) Section 3008(h) which provides the Agency with the
enforcement authority to order an interim status facility to take corrective
action at solid waste management units. The major difference between the two
authorties is that the Section 3004(u) authority is nondiscretionary with
respect to facilities subject to permitting requirements, whereas the 3008(u)
enforcement authority is discretionary.
6-22
-------
- §3004(u) Corrective Actions
As discussed above, a POTW may receive one of two types of RCRA permits:
a permit by rule or an individual RCRA permit. Prior to the passage of
Sections 3004(u) and 3008(h), RCRA's corrective action authorities were
limited to taking action at regulated units at permitted facilities (Part 264
Subpart F) or using the imminent endangerment authority of 7003 (normally used
in conjunction with CERCLA actions).
Before the enactment of the HSWA of 1984, the permit by rule did not
require compliance with the corrective action requirements of Part 264
Subpart F. As a result of the enactment of Section 3Q04(u), EPA added a
regulatory provision to its permit by rule regulations (§270.60) requiring
POTWs to take corrective action for releases at solid waste management units
within the facility boundary, whether or not those units now handle hazardous
wastes. In addition, Section 3004(v) requires the Agency to develop regula-
tions expanding the scope of corrective action authorities beyond the facility
boundary. Facilities seeking RCRA permits after November 8, 1984 would be
subject to 3004(u) corrective action for all units at the facility which
release hazardous waste or hazardous constituents into the environment.
While the Agency does not plan to require corrective action unless it is
necessary to protect human health and the environment, there may be substan-
tial costs in determining whether or not a release had occurred in the past
(e.g., sinking monitoring wells and analyzing results). Moreover, if correc-
tive action is required, the Agency estimates potential costs of ground water
cleanup at a one-quarter acre surface impoundment as a $249,000 annualized
present value cost for counter pumping the plume and treating it. First year
annualized costs for other source control methods ranged from $10,000 to
$450,000 (Fed. Reg. 28738, July 15, 1985). Actual costs will differ based on
site-specific conditions.
These costs were developed to reflect potential ground water
contamination cleanup costs. However, the Agency is interpreting the
provisions to encompass releases to all media, not only to ground water.
As was described in Chapter 5, the potential exists that releases have also
6-23
-------
occurred to surface water and air. The costs of cleanup in these media have
not been calculated. Nor has the Agency developed benchmark standards to
determine cleanup levels, although it is working on developing such
benchmarks.
- §3008(h) Corrective Actions
The 3008(h) authority is similar to the 3004(u) authority but its
applicability is limited to interim status facilities. Consequently,
facilities with permits by rule would not be subject to the interim status
provision. However, POTWs that generate hazardous sludges and treat, store,
or dispose of these sludges onsite as a result of the receipt of DSE wastes
are subject to this interim status provision. If they seek operating or
post-closure RCRA permits, they will also be subject to 3004(u)'s non-
discretionary authority.
Note also that all POTW TSDFs, like all other locally, State, or
Federally owned facilities, are now subject to annual inspections by EPA
inspectors. This requirement appears in 3007{d) of RCRA, newly added by the
HSWA.
6.2.1.9 Other HSWA Amendments
Other new statutory requirements may also have an effect on POTWs,
although in a less direct manner. Section 3005(e){2) requires that all land
disposal facilities submit a final application for a permit and (Part 265)
self-certification statement of compliance with RCRA interim status ground
water monitoring and financial responsibility requirements by November 8, 1985
or lose interim status (unless a closure plan is submitted). This provision
will have no direct impact on RCRA permitted POTWs unless they have ancillary
treatment storage or disposal operations. The indirect implications of this
provision on the POTW are potentially widespread and involve the disposal of
increased amounts of hazardous wastes to the sewers in the absence of other
disposal alternatives.
A land disposal facility may only receive hazardous wastes if it has
either interim status or a permit. Given that only eight land disposal
6-24
-------
facilities have RCRA permits, this provision applies to about 1,600 interim
status land disposal facilities.
The November Amendments modified RCRA in several significant ways, many
directed at precluding the disposal of hazardous wastes in land disposal
facilities. These modifications by statute are:
As of May 8, 1985, the disposal of bulk or noncontainerized liquid
hazardous wastes in landfills was prohibited
In conformance with statutorily mandated deadlines, certain specified
wastes may not be land disposed unless (1) a finding is made that
those wastes may be disposed of in land disposal units with reasonable
certainty that such disposal will not lead to migration of hazardous
wastes or constituents for as long as the wastes remain hazardous or
(2) they can be treated in a way which reduces toxicity and the
potential migration of hazardous wastes (time extensions and variances
are available)
Any landfill units or surface impoundment defined as a new unit,
replacement unit, or lateral expansion which first received waste
after November 8, 1984 must meet new minimum statutory requirements
for liner and leachate collection system design.
The overall impact of the above land disposal restrictions will be to
reduce the amount of waste that can be disposed of in land disposal units and
shift these wastes to treatment facilities; they will also reduce the number
of operating land diposal units. The diminished supply of land disposal units
and the increased costs associated with transportation to remaining offsite
land disposal and treatment facilities can have three potential effects, two
intended, one not: (1) force facilities to minimize waste generation; (2)
force facilities to adopt innovative destruction techniques; and (3) increase
facility incentives to illegally dispose of their wastes and/or increase waste
discharges to sewers and/or through direct discharge pipes.
As discussed above, the land disposal ban includes provisions for
treatment requirements for certain hazardous wastes subject to the ban. If
these wastes are treated to specific levels reducing the toxicity and poten-
tial migration of the waste, the waste residue is not subject to the prohibi-
tion. This provision, found in 3004(m) of the Act, is a potential mechanism
6-25
-------
for providing additional pretreatment controls. Section 3004(n), which
provides the Agency with the authority to develop regulations for the moni-
toring and control of air emissions at TSDFs, is another mechanism available
under RCRA which could provide for increased control over industrial users.
6.2.2 POTWs Jointly Regulated Under RCRA and CWA
A survey conducted by Association of Metropolitan Sewerage Agencies
(AMSA) on whether hazardous wastes are received by their members served as
another check of the number of POTWs engaged in hazardous waste handling was
reviewed. AMSA represents major metropolitan POTWs and, as such, represents a
skewed sample. Nevertheless, nearly all respondents indicated that wastes
containing hazardous constituents have been received at their treatment
plants. Spills, routine, and illegal discharges were identified as sources of
hazardous wastes to the system. In addition, according to the survey, 20
facilities received wastes from liquid hazardous waste haulers. Informal
followup discussions with operators of these POTWs indicated that they
completed the survey inaccurately and did not, in fact, receive hazardous
wastes from haulers. All of these operators indicated that they have not
knowingly accepted hazardous wastes. Some of the operators indicated that
they sample a subset of haulers on a random basis to ensure that they are not
receiving hazardous wastes. On occasion they have turned away haulers and
revoked their permits.
6.2.3 Administrative Responsibilities of the State and Federal Government
Under RCRA
Unlike the National Pretreatment Program, local governments have no role
in hazardous waste management under Subtitle C of RCRA. Therefore, unlike the
pretreatment program, the local control authority (i.e., the POTW) receives no
notification of hazardous waste activity from industrial users. Rather, this
information is either forwarded to the State or EPA. The statutory definition
of State responsibilities under RCRA appears in Section 3006.
Congress foresaw that States would receive authorization in a two-stage
process: "interim" authorization and final authorization. In the first
stage, States with "substantially equivalent" programs to Subtitle C could
6-26
-------
receive interim authorization. States could receive interim authorization, in
two phases, with the second phase divided into three components. Phase I
authorization allows for a State program consisting of identification and
listing of hazardous waste as well as, generator, transporter, and interim
status requirements for TSDFs. Phase II authorization enables the States to
administer a TSDF permit program. It is subdivided into three program
components corresponding to technical standards for different types of
regulated units (storage, incineration, land disposal facilities).
The second stage of the process is termed final authorization. A State
need not have achieved interim authorization to receive final authorization.
The final authorization stage is more stringent than the interim authorization
stage: State programs need be "equivalent" to (or more stringent than) the
Federal program to receive final authorization. Indeed, State law need not
include a domestic sewage exclusion for industrial users of POTWs, nor do they
need to provide permits-by-rule to POTWs. States can regulate POTWs receiving
hazardous waste by train, truck, or dedicated pipe as any other facility
receiving hazardous waste. See Table 6-3 for the status of State authoriza-
tion approvals. Note that the table refers to pre-HSWA authorization status.
While the HSWA [Section 3006(g)(2)] provides that the States can receive
interim and final authorization for the newly added provisions, no State has
received either interim or final authorization for the Amendments.
Section 3006(g)(l) provides that the requirements of the HSWA of 1984
take effect in interim and final authorized States at the same time as the
requirements take effect in nonauthorized States. In the absence of a State
having achieved interim or final authorization for HSWA requirements, the
Administrator must carry out the subject requirement. Section 3004(u)
requires that any permit issued after November 8, 1984 need address the
substantive requirements of the HSWA, e.g., corrective action. What this
means is that if a State has yet to receive authorization for a HSWA statutory
provision (e.g., corrective action), the State cannot issue a RCRA permit
under its own authority. Rather, it can only issue a "partial" permit. The
Agency would need to address the remaining portions of the permitting require-
ments of HSWA for the "partial" permit to be called a RCRA permit.
6-27
-------
TABLE 6-3. STATUS OF STATE FINAL AUTHORIZATIONS
(STATUS AS OF JANUARY 15, 1986)
STATE
DATE AUTHORIZED
FOR PRE-HSUA PROGRAM
DATE TENTATIVE NOTICE
PUBLISHED
Arizona
Arkansas
Colorado
Delaware
District of Columbia
Florida
Georgia
Guam
Illinois
Indiana
Kansas
Kentucky
Louisiana
Maryland
Massachusetts
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
December 4 1985
January 25 1985
November 2 1984
June 22 1984
March 22 1985
February 12 1985
August 21 1984
January 27 1986
October 17 1985
January 31 1985
February 7 1985
February 11 1985
February 7 1985
February 11 1985
June 27 1984
December 4 1985
July 25 1984
February 7 1985
November 1 1985
January 3 1985
February 21 1985
January 25 1985
December 31 1984
October 19 1984
January 10 1985
January 30 1986
November 22 1985
November 2 1984
February 5 1985
December 26 1984
October 24 1984
January 21 1985
December 18 1984
November 19 1985
November 19 1985
January 7 1986
December 6 1985
December 3 1985
December 6 1985
January 13 1986
November 27 1985
6-28
-------
Consequently, in the case of a POTW with TSDF status, a State cannot
issue a NPDES permit with a RCRA permit-by-rule corrective action provision
because States have not yet been authorized to permit for corrective action
requirements. Therefore, EPA would need to issue a RCRA partial permit for
the corrective action portion coincident with the State's issuance of a NPDES
permit.
6.2.4 Clean Water Act Controls
The foregoing discussion outlined key RCRA controls on waste generators
and TSDFs, and their implications for industrial users and POTWs. As it
showed, the Domestic Sewage Exclusion essentially works to relieve lUs from
most RCRA requirements if they discharge wastes to sewers, while at the same
time, allowing POTWs to receive and treat wastes without assuming the status
of a RCRA TSDF. As mentioned earlier, the DSE presumes that Clean Water Act
controls will limit the impacts of the discharge of hazardous waste mixed with
domestic wastes. This section discusses CWA provisions which might control
hazardous discharges.
Although the rationale for the DSE was equally based on construction
grant funding and pretreatment, it is apparent that the pretreatment program
has the more direct effect on the control of pollutants flowing into POTW
system. Consequently, this section concentrates on the pretreatment program's
role in controlling DSE discharges. In addition, other CWA provisions
affecting wastewater regulation are presented, including POTW permitting under
the National Pollutant Discharge Elimination System (NPDES) program, secondary
treatment and water quality-based permitting requirements, and municipal
sludge regulation.
6.2.4.1 The National Pretreatment Program
The purposes of the National Pretreatment Program are to prevent:
Interference with POTW operations
Pass through of pollutants to receiving waters
Contamination of municipal sludge
Exposure of workers to chemical hazards.
6-29
-------
Under the National Pretreatment Program, these purposes are accomplished by
implementing and enforcing the general pretreatment program, including:
Prohibited discharge standards
National categorical standards.
Both sets of standards are applicable nationally. All POTWs (approximately
15,000) must enforce specific and general prohibitions against any industry
hooked to their system. All categorical industries must comply with cate-
gorical standards even if they discharge to a POTW that does not have a
Federally approved local pretreatment program. In addition, POTWs are
required to develop local limits to prevent pass through, interference, and
sludge contamination.
The General Pretreatment Regulations (40 CFR 403) also require the
development of Federally approved local pretreatment programs by the following
classes of POTWs:
(1) POTWs with a total design flow greater than five million gallons per
day (mgd) and accepting IU pollutants subject to pretreatment
standards
(2) As determined by the Regional Administrator or State director, any
POTW with design flow less than five mgd accepting significant types
and quantities by industrial wastes or experiencing treatment
process upsets, NPDES permit violations or sludge contamination.
As stated earlier, approximately 1500 POTWs are required to develop
approved pretreatment programs. These POTWs have a total flow of almost
20 billion gallons per day, which constitutes almost 74 percent of total POTW
flow nationally. In addition, based on conservative NEEDS estimates, pre-
treatment POTWs receive 82 percent of the National industrial flow.
The rationale behind the DSE was that by imposing categorical standards,
general specific prohibitions, and local limits through the pretreatment
program, human health and the environment would be protected from hazardous
wastewaters. The following section explains some of the ways in which
pretreatment programs achieve these purposes.
6-30
-------
General Prohibitions
Section 403.5(a) establishes a general prohibition against the
introduction of pollutants into a POTW by a nondomestic source that passes
through or interferes with the operation or performance of the POTW. General
prohibitions apply to all industrial users regardless of whether the source is
subject to other National pretreatment standards (see the discussion below
under Categorical Standards) or Federal, State, or local pretreatment require-
ments.
Interference
An industrial user may not discharge substances in volumes or
concentrations that result in "interference" to POTW operations or the
environmental benefits of those operations. Proposed §403.3(i), 50 FR 25526,
June 19, 1985, defines "interference" as "a discharge by an industrial user
which, alone or in conjunction with discharges by other sources, inhibits or
disrupts the POTW, its treatment processes or operations, or its sludge pro-
cess, use or disposal, and which is a cause of a violation of any requirement
of the POTW's NPDES permit (including an increase in the magnitude or duration
of a violation) or of the prevention of sewage sludge use or disposal by the
POTW in accordance with §405 CWA; RCRA, including state regulations contained
in any state sludge management plan prepared pursuant to Subtitle D of the
SWDA; the Toxic Substances Control Act; the Marine Protection, Research and
Sanctuaries Act; or more stringent State or local regulations."
Pass Through
An industrial user may not discharge substances in volumes or
concentrations that "pass through" the POTW system. Proposed §403.3(n), 50 FR
25526, June 19, 1985, defines "pass through" as the discharge of pollutants
through the POTW into navigable waters in quantities or concentrations that,
aldne or in conjunction with discharges from other sources, is a cause of a
violation of any requirement of the POTW's NPDES permit (including an increase
in the magnitude or duration of a violation).
6-31
-------
Specific Prohibitions
Section 403.5(b) establishes specific prohibitions against the
introduction of pollutants into a POTW that will cause (1) a fire or explosion
hazard in the POTW; (2) corrosive structural damage to the POTW (but in no
case are discharges with pH lower than 5.0 allowed, unless the works is
specifically designed to accommodate such discharges); (3) interference by
solid or viscous pollutants that obstruct the flow in the POTW; (4) inter-
ference by the flow rate and/or pollutant concentration of any pollutant,
including oxygen demanding pollutants (BOD, etc.); and (5) interference due to
heat in amounts that inhibit biological activity in the POTW, but in no case
can heat cause the temperature at the POTW treatment plant to exceed 40
degrees C (104 degrees F) unless the approval authority, upon request of the
POTW, approves alternative temperature limits. The first two prohibitions
parallel characteristics under RCRA that make a solid waste a hazardous waste.
When Specific Limits Must Be Developed By POTW
Section 403.5(c) requires POTWs developing a pretreatment program to
develop and enforce specific limits to implement the general and specific
prohibitions. All other POTWs are required [in cases where pollutants con-
tributed by user(s) result in interference or pass through and such violation
is likely to recur] to develop and enforce specific effluent limits for
industrial user(s), and all other users, as appropriate, which, together with
appropriate changes in the POTW treatment plant's facilities or operation, are
necessary to ensure renewed and continued compliance with the POTW's NPDES
permit and sludge use or disposal practices.
Section 403.5(d) provides that specific prohibitions or limits on
pollutants or pollutant parameters developed by POTWs are deemed pretreatment
standards for the purposes of Section 307(b) of the Act, Therefore, the
specific prohibitions are federally enforceable.
Categorical Standards
Industrial users must comply with applicable National categorical
standards as well as local regulations imposed by the POTW. Each categorical
6-32
-------
pretreatment standard is a separate regulation developed in EPA's effluent
guidelines process and contains limitations for pollutants commonly discharged
by the specific industrial category. All firms regulated by a particular
category are subject to these standards, no matter where they are located.
Responsibilities of categorical industries include:
Complying with specific technology-based effluent limitations for
pollutants of concern, which may involve designing, purchasing, and
installing end-of-pipe pretreatment equipment or process changes
Operating and maintaining the installed technology properly to achieve
consistent compliance with standards
Monitoring discharges to determine compliance with standards according
to frequencies established by Federal or local rules
Reporting regularly to the control authority their compliance status
or progress towards compliance, as well as any unusual or emergency
conditions (several types of reports are required by 40 CFR 403.12).
These categorical standards are being developed by the Agency as required
by Section 307 of the CWA and the 1976 NRDC v. Train consent decree. Although
34 industries were defined as "categorical" for which pretreatment standards
were to be defined, the Agency has narrowed that list to 23 specific indus-
trial categories. The reduction to 23 categorical industries is a result of
several circumstances: 12 categories have been exempted; two industrial
categories organic chemicals, and plastic and synthetic fibers -- were
combined; the mechanical products category was incorporated into metal
finishing; and a new category, nonferrous metal forming, was added. See Table
6-6 for a listing of proposed and promulgated categorical standards.
The Agency targeted its review on these industries and on the 126 toxic
priority pollutants. As can be seen from Table 3-13, the Agency concentrated
its efforts on regulating the discharge of toxic metals. However, the Agency
has the authority to additionally regulate, and it has on occasion regulated,
pollutants other than the 126 toxics.
6-33
-------
6.2.5 Responsibilities at the Local, State, and Federal Level
The Pretreatment Regulations use the terms "Control Authority" and
"Approval Authority" to refer to the powers and responsibilities of each
governmental level. The Control Authority has the responsibility to ensure
that industrial users of the POTW system achieve and maintain compliance with
pretreatment standards and requirements. The Approval Authority is respon-
sible for overseeing the development and implementation of local pretreatment
programs. Mhen a local program is approved, the POTW becomes the Control
Authority. If the POTW does not have an approved program, the Approval
Authority, either the State or EPA, acts as the Control Authority. The State
becomes the Approval Authority only if it has an approved State pretreatment
program pursuant to §402(b) of the CWA. Otherwise, EPA Regions function as
the Approval Authority.
The POTW, as the Control Authority, has responsibility for developing,
implementing, and enforcing a local pretreatment program. This program must
provide the POTW with the authority and procedures to do the following:
Conduct an industrial waste survey (IWS) to identify significant
industrial users and to update this IWS periodically
t Apply and enforce the requirements of the Federal categorical pre-
treatment standards, the General Pretreatment Regulations, and any
other State or local regulations used to control nondomestic dis-
charges
Establish local effluent limits to protect the operation of its
treatment plant, the quality of the receiving water, and the quality
of its sludge
Monitor its industrial users to determine compliance and noncompliance
with Federal and local limits and standards
Require industrial users to submit Baseline Monitoring Reports,
Compliance Reports, and other reports as required by Section 40 CFR
403.12 of the General Pretreatment Regulations
Prepare and submit any information that may be required by the
Approval Authority to support the POTW's program implementation
activities (e.g., annual reports).
6-34
-------
As noted above, the National Pretreatment Program is designed for States
to act as the Approval Authority. Approval Authority responsibilities
include:
Reviewing and approving local pretreatment programs
Investigating noncompliance and performing audits of local pretreat-
ment programs to determine whether POTW activities and procedures
conform to program and permit requirements
Ensuring that Control Authorities are adequately enforcing
pretreatment standards and requirements.
To gain Approval Authority from EPA, a State must develop a pretreatment
program that shows that it has the necessary authority, resources, and
procedures to carry out the responsibilities outlined above. States may also
design a program under which the State is the Control Authority and no POTWs
are required to develop programs. In these cases, all development, implemen-
tation, and enforcement activities are conducted by the State, and there is no
need for local program review and approval. Connecticut, Vermont, Alabama,
Mississippi, New Jersey, and Nebraska have assumed either partial or total
responsibility for running local pretreatment programs in their States. Table
6-4 provides a list of approved NPOES and Pretreatment States.
Federal pretreatment program responsibilities are divided between the ten
EPA Regions and EPA Headquarters. Headquarters provides the National over-
view, direction, and oversight of the program while delegating most of the
administrative and programmatic functions related to enforcement to the
Regional offices.
EPA's Regional Offices are responsible for developing, implementing, and
overseeing State and local pretreatment programs. For those States with
approved pretreatment programs, the Regions provide general guidance, direc-
tion, and enforcement assistance. They are responsible for the overview and
evaluation of State programs, ensuring that they carry out all their delegated
responsibilities. However, where States have not been delegated Approval
Authority responsibilities the Region must take on these responsibilities as
6-35
-------
TABLE 6-4. STATE NPDES PROGRAM STATUS AS OF JUNE 1985
A1 abama
California
Colorado
Connecticut
Delaware
Georgia
Hawaii
Illinois
Indiana
Iowa
Kansas
Kentucky
Maryl and
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Jersey
New York
North Carolina
North Dakota
Ohio
Oregon
Pennsylvania
Rhode Island
South Carolina
Tennessee
Vermont
Virgin Islands
Virginia
Washington
West Virginia
Wisconsin
Wyomi ng
Approved
State
NPDES
Permit
Program
10-19-79
05-14-73
03-27-75
09-26-73
04-01-74
06-28-74
11-28-74
10-23-77
01-01-75
08-10-78
06-28-74
09-30-83
09-05-74
10-17-73
06-30-74
05-01-74
10-30-74
06-10-74
06-12-74
09-19-75
04-13-82
10-28-75
10-19-75
06-13-75
03-11-74
09-26-73
06-30-76
09-17-84
06-10-75
12-28-77
03-11-74
06-30-74
03-31-75
11-14-73
05-10-82
02-04-74
01-20-75
Approved
to
Regulate
Federal
Facilities
10-19-79
05-05-78
12-08-80
06-01-79
09-20-79
12-09-78
08-10-78
09-30-83
12-09-78
12-09-78
01-28-83
06-26-79
06-23-81
11-02-79
08-31-78
04-13-82
06-13-80
01-26-83
03-02-79
06-30-78
09-17-84
09-26-80
02-09-82
05-10-82
11-26-79
05-18-81
Approved
State
Pretreat-
ment
Program
10-19-79
06-03-81
03-12-81
08-12-83
06-03-81
09-30-83
04-16-85
07-16-79
05-13-82
06-03-81
09-07-84
04-13-83
06-14-82
07-27-83
03-12-81
09-17-84
04-09-82
08-10-83
03-16-82
05-10-82
12-24-80
6-36
-------
well. The Regions are also responsible for the identification and resolution
of problems that impede the implementation and administration of the pretreat-
ment program.
6.2.6 Other CHA Requirements Affecting Control of DSS Wastes
As indicated above, several other CWA provisions play a part in
establishing the fundamental goals that POTWs must meet in implementing
pretreatment requirements and treating wastewater. NPDES permit limits and
sludge management practices are specifically protected by the general prohibi-
tions against pass-through and interference. Thus, specific POTW effluent
limits and sludge disposal guidelines clearly will influence the extent to
which POTWs allow wastes containing hazardous constituents to be discharged to
their systems.
6.2.6.1 Municipal Permitting
As with other point sources, wastewater discharge controls are imposed on
municipalities under the NPDES program established in §402 of the Clean Water
Act. Under this permitting program, POTWs, which discharge directly into
surface waters, must apply for a NPDES permit. EPA or State permit writers
evaluate the volume and quality of municipal effluent, the pollution control
technology currently being employed, the applicability of National technology-
based standards, and receiving water quality to develop pollutant-specific
numerical effluent limits and removal requirements for the POTW's NPDES
permit. NPDES permits have a five-year duration and may incorporate other
conditions including development and operation of a pretreatment program,
submission of self-monitoring reports (discharge monitoring reports), and
compliance with interim compliance schedules. Municipalities with NPDES
permits are subject to both technology-based and water quality-based require-
ments.
6.2.6.2 Technology-Based Treatment (Secondary Treatment/Construction Grants
Regulation of municipal sewage treatment plants, pursuant to §201 of the
Clean Water Act, initially emphasized the control of conventional pollutants.
The Act required POTWs to meet limitations based on secondary treatment by
6-37
-------
1977. This deadline has since been extended for some POTWs. The construction
grants program was initiated to provide funding for POTWs that needed to
improve or build new treatment works to meet the requirements of the CWA. To
date, $40 billion has been expended in Federal assistance to sewage treatment
plants for construction, and approximately 3,400 sewage treatment plants have
been assisted.
Secondary treatment has been defined in terms of biochemical oxygen
demand, suspended solids, and pH control, POTWs are not usually required to
install specific technology to control toxic pollutants, although incidental
removal in secondary treatment may be quite high for some toxic pollutants.
Instead, the CWA envisions that, by implementation of pretreatment programs
and industrial compliance with categorical standards, toxic pollutants in
municipal effluents will be adequately controlled. In addition, POTWs are
subject to limits for toxic and other pollutants in NPDES permits, based on
water quality considerations.
6.2.6.3 Water Quality-Based Permitting
Water quality-based standards are employed to supplement technology-based
controls on municipal dischargers to meet water quality objectives. Under CWA
Section 303, water quality standards are developed by States, based either on
Federal water quality criteria or locally derived criteria, to address certain
water quality parameters for specific receiving water bodies. To establish
water quality standards, States designate desired uses for stream segments,
such as fishing, swimming, water supply, or industrial use. The most sen-
sitive use for each stream is protected by a set of ambient standards for
various pollutants, which then become the operative water quality standards.
Such water quality-based pollutant standards, in turn, are to be translated
into effluent limits needed to protect water quality and designated uses
pursuant to Sections 301 and 302 of the CWA, using wasteload allocation
techniques. Thirty-eight percent of total POTW flow nationally is treated
more stringently than required by technology-based standards. The majority of
the POTWs subject to the more stringent limits are required to remove addi-
tional amounts of conventional and nonconventional pollutants (e.g., ammonia,
phosphorus).
6-38
-------
Extension of the water quality-based approach to cover toxic pollutants
has been hindered by the absence of water quality criteria or State standards
for toxic pollutants. In fact, as was seen in Table 5-3, very few water
quality criteria exist for hazardous constituents being studied in the OSS.
Moreover, not all potentially toxic materials can be identified by chemical
methods, nor can interactive effects among pollutants always be positively
identified.
Recognizing this, EPA published a Policy for the Development of Water
Quality-Based Permit Limitations for Toxic Pollutants in 49 FR 9017. The
Policy discusses the use of an "integrated strategy" of both biological and
chemical testing "... to address toxic and nonconventional pollutants from
industrial and municipal sources." In the absence of numeric water quality
criteria and standards, the Agency advises that "... it is more feasible to
examine the whole effluent toxicity and instream impacts using biological
methods rather than attempt to identify all toxic pollutants, determine the
effects of each pollutant individually, and then attempt to assess their
collective effect." NPDES permittees may-also be required to conduct a
toxicity reduction evaluation (TRE) to determine control options for toxic
control. TREs will be used within industrial or municipal systems to isolate
sources of toxicity and define, control options. The Policy directs special
attention to POTWs that have a "significant contribution of industrial waste-
water," and goes on to say that POTWs are often significant sources of toxic
materials. The ultimate purpose of this effort is to design controls to meet
water quality standards. Therefore, POTWs with significant contributions of
industrial wastewater, including those that receive DSE wastewaters, should be
taking a harder look at setting local limits and more stringent prohibi-
tions.(6)
In addition, the Agency's water program recently conducted a study of the
use that EPA Regions and States are making of effluent bioassays in iden-
tifying water quality-limited bodies, setting controls, and assessing com-
pliance.^ ' That study showed that 39 States are now using bioassays for
these purposes and a few States are conducting a substantial amount of
bioassay work for the purpose of developing limits. In addition, eight of
6-39
-------
EPA's ten Regional offices are now using bioassays at some level to set
effluent controls. In light of these developments, POTWs and therefore IUs
may expect increased toxics regulation of wastewater discharges.
6.2.6.4 Regulation of Municipal Sludge Disposal
Section 405 of CWA requires development of regulations providing guide-
lines for the use and disposal of municipal sludge. Such regulations must
identify sludge use and disposal options, specify factors to be taken into
account in determining the practices applicable to each option, and identify
concentrations of pollutants that interfere with each option. To date,
regulations defining acceptable land disposal practices {40 CFR 257) have been
promulgated under the joint authority of CWA and Subtitle D of RCRA. Other
laws that govern municipal sludge use or disposal depend on the option
employed or the constituent present in the sludge. These include the Clean
Air Act (CAA), the Marine protection, Research, and Sanctuaries Act (MPRSA),
RCRA Subtitle C, and the Toxic Substances Control Act (TSCA). Use and
disposal of industrial wastewater treatment sludge is not subject to regula-
tion under CWA Section 405. Like municipal sludge, however, certain aspects
of industrial sludge use and disposal are governed by CAA, MPRSA, RCRA
Subtitles C and D, and TSCA.
Until recently, control of municipal sewage sludge management practices
has gone forward on a media-specific basis and has been controlled incon-
sistently by States. POTW operators rarely had access to comprehensive sludge
criteria to guide local limits decisions in their pretreatment programs. To
alleviate this gap, EPA is currently developing comprehensive sludge manage-
ment regulations under authority Section 405 of CWA.
The Agency is developing regulations governing municipal sludge manage-
ment in two parts: (l) a programmatic component (40 CFR 501 and 502), which
delineates the roles of the Federal and State governments and sets forth
minimum criteria for State sludge management programs; and (2) a technical
component (40 CFR 503), which sets forth numerical limits on sludges disposed
of by different practices (i.e., distribution and marketing, ocean dumping,
landfilling, land application, incineration), as well as best management
practices, treatment requirements, and monitoring and sampling protocols.
6-40
-------
As a first step in producing the technical regulations, the Agency
developed a list of pollutants for regulatory consideration. Twenty-six of
the pollutants currently being evaluated for sludge regulation are considered
hazardous (i.e., Tier 1 or Tier 2 pollutants, as defined in this report).
Therefore, for those 26 pollutants, the promulgation of technical regulations
in 1987 could establish new standards for the control of hazardous waste
discharges to POTWs.
6.2.6.5 Summary of CWA Controls Applicable to DSS Wastes
In essence, the CWA imposes a double net to control the environmental,
health, and plant impacts of industrial wastewater discharged to the sewers.
First, industries are subject to a range of standards -- categorical stan-
dards, general and specific prohibitions, and local limits -- to guarantee
that the receiving POTW and environment are protected. Authorized industrial
discharges are then incidentally and intentionally treated at the sewage
treatment plant to a level dictated by controls placed on the POTW itself to
ensure that POTW releases do not harm the environment (i.e., surface water and
media affected by sludge disposal). This process is intended to be iterative
where necessary. If any POTW cannot meet environmental objectives due to
industrial discharges, it must adjust its pretreatment controls to remediate
problems.
Thus, the CWA provides mechanisms for the site-specific and ongoing
evaluation of the acceptability of DSS loadings to POTWs and the environment.
Treatment requirements imposed on industrial users discharging hazardous
constituents may be both technology-based and responsive to ambient environ-
mental conditions. Administratively, DSS dischargers may be subject to
monitoring, reporting, permitting, and compliance obligations under the CWA
and its pretreatment requirements.
6.2.7 Other Statutory Controls Affecting the Discharge of Hazardous Wastes to
Sewers
Several other statutes may either directly or indirectly affect an
industry's ability to discharge hazardous wastes mixed with sewage to POTWs.
Principal among these are the Occupational Safety and Health Act, the Clean
6-41
-------
Air Act, and the Comprehensive Emergency Response, Compensation, and Liability
Act. These are discussed below.
6.2.7.1 OSHA/Worker Safety
Many of the hazardous pollutants in DSE wastes that are the subject of
this study are readily volatilized. Once volatilized, these pollutants may
pose a health risk to POTW workers through inhalation. This section examines
the extent of protection from workplace risks afforded to POTW workers by the
Federal Occupational Safety and Health Act (OSHA, 29 USC §650 et seq).
OSHA authorized the Secretary of Labor to establish health and safety.
standards and procedures applicable to employers and their employees engaged
in interstate commerce. By definition, though, "employer" does not include
"the United States or any State or political subdivision of a State" [Section
3(5) of OSHA]. Consequently, OSHA standards do not cover POTW workers since
they are typically employees of a State or a political subdivision of a State,
e.g., employees of municipalities or special districts.
Nevertheless, Section 18 of OSHA potentially provides some measure of
protection for State and local workers in an indirect way. States may submit
plans for assuming responsibility for developing and enforcing occupational
safety and health standards relating to safety and health issues for which a
Federal standard has been promulgated under Section 6 of OSHA. The Secretary
of Labor, under Section 18 of OSHA, shall approve a State plan if, inter alia,
that plan "contains satisfactory assurances that such State will, to the
extent permitted by its laws, establish and maintain an effective and com-
prehensive occupational safety and health program applicable to all employees
of public agencies of the State and its political subdivisions, which program
is as effective as the standards contained in an approved plan." Therefore,
where approved State plans exist, POTW workers are protected to the same
extent as private employees.
Currently, 26 States and territories have approved plans. Since the
remaining 30 States and territories have no plans, POTW workers are not
afforded protection under the auspices of OSHA. However, some States are
6-42
-------
contemplating developing their own plan of protection whether or not Federal
approval under OSHA is sought.
For POTW workers in States that have approved plans, some measure of
protection from exposure to toxic pollutants is afforded. These States must
develop and enforce, as part of their approved plan, the exposure standards
contained in the regulations at 29 CFR 1910.1000 to 1910.1046. Specifically,
29 CFR 1910.1000, contains a list of compounds that have maximum exposure
levels during the workday. Many of the compounds on the list are also
compounds that are part of this study (e.g., acetone).
Notwithstanding the existence of these ambient standards, protection may
be afforded workers through use of equipment (e.g., respirators), that effec-
tively reduces the exposure level instead of eliminating the source of the
compound. Nevertheless, a POTW might be able to utilize these standards to
support a local limit on the discharging industrial user. However, a State
can only enforce against the POTW for allowing a worker to be exposed to the
compound. In summary, the basic source of worker protection falls to the POTW
itself, for only the POTW has the knowledge and authority to clearly control
the discharge of the pollutant.
6.2.7.2 Air Pollution Control
A significant number of the hazardous pollutants found to be discharged
to sewers are volatile organic compounds (e.g., spent solvents, degreasers
that exhibit a high degree of volatility). These pollutants often volatilize
prior to or at the treatment plant. The compounds volatilize into the
atmosphere through manholes, lift stations, headworks, primary clarifiers,
aeration basins, and trickling filters. As noted above, when these hazardous
pollutants are permitted to concentrate in enclosed spaces, they present a
potential risk to POTW workers. Moreover, their release to the atmosphere may
create or exacerabate air pollution problems. Consequently, controlling the
entry of these pollutants into sewers is not only driven by concerns over
their presence in the water, but also their potential release to the atmo-
sphere. The following subsections describe the potential mechanisms for
controlling air emissions under the Clean Air Act, Resource Conservation and
Recovery Act, and Clean Water Act.
6-43
-------
The Clean Air Act
Ambient Air Standards and State Implementation Plans
The Clean Air Act (CAA) establishes a multifaceted approach to air
pollution control that involves a combination of Federal and State controls.
At the Federal level, the Administrator of EPA lists, pursuant to Section 108
of the CAA, each air pollutant the emission of which causes or contributes to
air pollution which may reasonably be anticipated to endanger public health
and welfare and the presence of which in the ambient air results from numerous
or diverse mobile or stationary sources. For these pollutants, known as
criteria pollutants, the Administrator then develops air quality criteria
documents that include amounts, sources, adverse effects, and information on
such other air pollutants that, when present in the atmosphere, may interact
to produce an adverse effect on public health or welfare.
Based on these criteria, EPA then develops National Ambient Air Quality
Standards that each State is responsible for attaining and maintaining within
its boundaries. Currently, ambient air quality standards exist for six air
pollutants: oxides of sulfur (SO ), oxides of nitrogen (NO ), carbon monoxide
X X
(CO), lead (Pb), ozone (0 ), and total suspended particulates (TSP). Once
ambient air quality standards are established, States are required under
Section 110 to develop plans [State implementation plans (SIPs)] for imple-
menting air pollution control standards for existing sources that will result
in the attainment and maintenance of ambient air quality standards. New
sources are required to comply with new source performance standards (NSPS)
promulgated by EPA, provided the source is within one of the industrial
categories. Otherwise, the State standards for similar existing sources are
applied.
None of the ambient standards directly addresses volatile organic
compounds (VOCs). However, ozone is generally produced from the oxidation or
reduction of VOCs, and ozone is partially controlled by reducing VOC emissions
to the atmosphere. Since many of the hazardous pollutants discharged to the
sewers are volatile organic compounds, regulating the entry of these organic
compounds to sewers and POTWs would assist in attaining or maintaining
compliance with the ambient ozone standards. To date, EPA has not addressed
6-44
-------
the release of volatile organic compounds from sewers and POTWs. However, it
is a subject that is being investigated by EPA. The results of the DSS
further support the effort to understand the magnitude of the VOC problem.
National Emission Standards for Hazardous Air Pollutants (NESH'APs)
The other primary mechanism for controlling air pollutants involves the
establishment of emission standards for specific pollutants on a National
basis. These National Emission Standards for Hazardous Air Pollutants
(NESHAPs), promulgated under authority of Section 112 of the CAA, apply to all
sources whether existing or new. EPA may establish a NESHAP for an air pol-
lutant for which there is no applicable ambient air quality standard and which
causes or contributes to air pollution which may reasonably be anticipated to
result in an increase in mortality or an increase in serious irreversible or
incapacitating reversible illness.
EPA has promulgated NESHAPs for beryllium, beryllium rocket motor firing,
mercury, vinyl chloride, radionuclides, equipment leaks of benzene, and
asbestos. NESHAPs can also be established for equipment leaks of other
volatile hdzardous air pollutants (VHAPs); however, the only VHAP thus far set
for equipment applies to leaks of benzene from pumps, valves, and compressors.
Therefore, except for benzene and vinyl chloride, NESHAPs have a limited
effect on controlling the environmental release of hazardous pollutants under
investigation in this study. NESHAPs are under consideration for pollutants
such as carbon tetrachloride, 1,3-butadiene, chromium, cadmium, and ethylene
dichloride. A complete listing is provided in Table 5-10. Standards for
these substances might have a more direct effect on DSS wastes.
Either the ambient air standards or NESHAPs regulatory mechanisms could
be used to control air releases of hazardous pollutants if EPA sought to do
so. However, control is complicated by the manner of release (e.g., manholes,
headworks, clarifiers), because they are not the typical point source that the
Agency has previously regulated. In fact, POTWs as air sources have greater
similarity to area sources. The CAA does provide for imposition of management
practices that could be employed to keep the volatile materials out of the
system before they can pose a problem.
6-45
-------
The Resource Conservation and Recovery Act
As mentioned earlier, RCRA regulates hazardous waste management as it
affects the environmental media. Prior to the passage of the amendments,
certain RCRA regulatory requirements did offer air emissions control. For
example, the interim status closure and post closure regulations for landfills
required the owner/operator to maintain and monitor a gas collection and
control system to control the escape of gases [40 CFR 265.310 (d)(3)]. With
the passage of the Amendments, however, the RCRA program has achieved addi-
tional authority to control air emissions. Those authorities are described
briefly below.
Section 3004(n) of RCRA, newly added by HSWA of 1984, imposed a 30-month
deadline to promulgate regulations for the monitoring and control of air
emissions at TSDFs. Section 3004(m) of RCRA, which authorizes the Agency to
promulgate treatment standards for wastes subject to the land disposal ban,
provides another mechanism for hazardous waste air emissions control. It
requires that standards be promulgated which "...substantially reduce the
likelihood of migration of hazardous constituents from the waste so that
short-term and long-term threats to human health and the environment be
minimized." A third RCRA provision with the potential for air emission
control appears in Section 3005(c). It enables the Agency to add terms to
permit conditions as determined necessary to protect human health and the
environment, beyond those conditions specifically required by the regulations.
This provision would enable the Agency to tailor permit conditions to include
air emission controls as necessary on a site-specific basis. Section 3004(u)
and 3008(h) authorize the Agency to take corrective action to address air
emissions, among releases to other environmental media, at RCRA permitted and
interim status facilities, respectively. In addition, in appropriate cases,
the Agency may address air emission problems using §7003 where those problems
may present an imminent and substantial endangerment of human health or the
environment.
6-46
-------
Clean Water Act
Water regulations, including categorical standards, local limits, and
general prohibitions, may dictate that source controls be employed by indus-
trial users not only to reduce wastewater concentrations but to prevent
volatilization. In fact, the CWA specifically identified "nonwater quality
objectives" as a basis for industrial wastewater regulation. In two recent
Federal Register notices, the Agency has indicated its intention to control
the volatilization of organic pollutants from wastewater treatment systems in
the organic chemicals, plastics, and synthetics fibers industries using the
industrial effluent control authorities of the Clean Water Act.
6*2.7.3 Releases Under CERCLA
Sections 103(a) and (b) of CERCLA require persons in charge of facilities
from which hazardous substances have been released, in quantities that are
equal to or greater than the reportable quantities, to notify the National
Response Center (NRC) of the release. [40 CFR Part 302]. These notification
provisions may apply, in certain instances, to wastewater discharges by
industries to POTWs and to POTW releases of waste^constituents to surface
waters, sludge, air, and ground water. Section 103(a) and (b) notification
provisions do not apply, however, to Federally permitted releases as defined
in Section 101 of CERCLA. Section 101(10)(J) of CERCLA defines Federally
permitted release to include the introduction of pollutants into POTWs if the
pollutant is subject to and in compliance with pollutant-specific categorical
standards and the generic prohibitions and the pollutant is specified in and
in compliance with enforceable requirements in a pretreatment program sub-
mitted for EPA approval by a State or local government. However, categorical
standards have only been set for a subset of industries. Thus, all other
industrial categories, as well as plants not in compliance with categorical
pretreatment requirements, would need to notify the NRC if releases exceeded
reportable quantities.
Additional provisions under CERCLA Section 101 define Federally permitted
releases to include discharges in compliance with a NPDES permit, discharges
resulting from circumstances identified, reviewed, and made part of the public
6-47
-------
record during NPDES permit issuance, and continuous or anticipated intermit-
tent discharges identified in a NPDES permit or application, which are caused
by events within the scope of relevant operating or treatment systems. These
provisions would operate to exempt certain POTW releases to surface waters,
but would not similarly extend to releases to sludge, air, and ground water.
The Agency has not yet proposed rules defining "federally permitted releases."
Dischargers to a POTW from a mobile source (e.g., liquid waste haulers)
need not report to the National Response Center if they have contracted with,
or otherwise received written permission from, the POTW operator to discharge
the waste, and meet the requirements discussed above for discharges to sewers.
Thus, the mobile source exemption parallels the permit-by-rule provisions of
RCRA.
Section 103(f) of CERCLA provides an alternative reporting mechanism for
releases which must be reported under RCRA Subtitle C and for releases
considered "continuous" or "stable in quantity and rate." Notification for
such releases is to be provided annually, and at such time as there is a
statistically significant increase in discharge quantity. Rules on defining
"continuous" have not been promulgated, but options being considered include
definitions that would exempt: (1) releases continuous during operating
hours; and (2) releases which are continuous during regularly-occurring batch
processes.
Other key CERCLA provisions may also apply to POTW releases. CERCLA
Section 107 establishes liability for any costs for removal or remedial action
and for any damage to natural resources caused by a release or threatened
release of a hazardous substance from a facility. This provision may, in
some instances, apply to POTW releases of waste constituents to surface
waters, sludge, air, and ground water.
6.2.7.4 EPA's Ground Water Strategy
The problem of ground water contamination has only recently been
recognized. EPA issued a ground water protection strategy in 1984 to
coordinate the protection of ground water through existing statutes (RCRA,
6-48
-------
CERCLA, CWA, SDWA, TSCA, and FIFRA), because no single Federal law provides
comprehensive ground water protection. This strategy sets forth EPA's
intentions to:
Strengthen State ground water programs
Cope with unaddressed ground water problems
Establish a framework for decisionmaking within EPA programs
t Strengthen EPA's internal ground water organization.
Although the strategy presents an aquifer classification scheme to guide
Federal decisionmaking, it does not directly address EPA's methods for dealing
with any specific ground water problems, including those potentially arising
from POTWs. A recent survey of State policies and problems, conducted by
EPA's Office of Ground Water Protection, also did not indicate that any States
had recognized problems with POTWs or had developed policies to deal with
them.
6.3 EVALUATION OF THE EFFECTIVENESS OF THE PRETREATMENT PROGRAM IN
CONTROLLING OSS WASTES
This section reports the implementation status of the pretreatment
controls and provides judgement as to what extent Federal, State, and local
pretreatment measures have been effective in limiting impacts from DSS wastes.
This analysis is subdivided into the key pretreatment areas affecting DSS
waste controls. First, a status report on implementation milestones is
provided, covering program approvals, audit results, and compliance data.
Then, effectiveness analyses are performed on principal pretreatment control
mechanisms including categorical standards, specific prohibitions, local
limits, and municipal spill and waste hauler controls. Finally, this section
examines municipal perceptions on the need for hazardous waste control at
POTWs.
A variety of data sources were employed to perform this evaluation.
Major assistance was provided by the Association of Metropolitan Sewerage
Agencies (AMSA), which circulated a survey on hazardous wastes to its member-
ship. Responses were then provided to EPA. (A summary of the survey results,
6-49
-------
along with the survey instrument are provided in Appendix K.) The survey was
sent to 107 AMSA members, and responses were received from 66, a 62 percent
response rate. In aggregate, the respondents have responsibility for 308
treatment plants, accounting for 39 percent of total POTW flow nationwide and
an estimated 47 percent of National industrial flow. It is unlikely that the
AMSA respondents are representative of all POTWs or even all pretreatment
POTWs, since they tend to be large, sophisticated metropolitan agencies.
Nonetheless, since they are located in major urban areas and they receive such
significant loadings of industrial wastes, it is likely that they have
extensive experience with hazardous waste discharges.
A second evaluative data source used was a report, prepared for EPA in
April 1985, which summarizes audits that had been performed on pretreatment
programs at 28 municipalities/ ' EPA performs audits on pretreatment
programs that have been approved for at least one year to determine pretreat-
ment program effectiveness, POTW compliance, and program areas warranting more
EPA technical assistance. Approximately 60 audits have been performed to
date. These audits are resource-intensive efforts, involving considerable
onsite inspection and review. They provide extremely detailed observations of
the success of pretreatment. While the audits focused on toxics control
generally, they should provide insight into POTW's ability to control DSS
wastes as well. The audits covered were conducted in EPA Regions I, III, IV,
VII, VIII, and X, providing geographic diversity, and evaluated ranging POTWs
in size from 0.6 MGD to 402 MGD.
Finally, extensive programmatic data from EPA was drawn upon -- from the
Office of Water Enforcement and Permits, EPA Regions, and the Industrial
Technology Division of the Office of Water Regulations and Standards.
6.3.1 Status of Pretreatment Program Implementation
EPA first issued the General Pretreatment Regulations for Existing and
New Sources of Pollution (40 CFR Part 403) on June 26, 1978. These regula-
tions were challenged by various parties. EPA entered into a settlement
agreement to propose and take final action on certain amendments to the 1978
regulations. After a public comment period, followed by additional regulatory
6-50
-------
development activities, the proposed amendments to the regulations were prom-
ulgated on January 28, 1981, with an effective date of March 30, 1981. On
March 27, 1981, EPA indefinitely postponed the effective date of certain por-
tions of the amendments in order to allow the Agency to conduct a Regulatory
Impact Analysis (RIA) as required by Executive Order 12291. On January 31,
1982, EPA reinstated the effectiveness of all but four of these amendments.
In July 1982, the U.S. Court of Appeals for the Third Circuit ruled on a
suit brought by the Natural Resources Defense Council (NRDC), which asserted
that EPA's postponement of the Regulations violated the Administrative
Procedures Act. The Court directed EPA to reinstate, all of the amendments to
the General Pretreatment Regulations effective March 30, 1981. Various
parties continued to challenge the pretreatment regulations and the electro-
plating categorical pretreatment standards. The pretreatment provisions
challenged were:
The definitions of "new source," "interference," and "pass through"
The combined wastestream formula
The removal credits provisions
The fundamentally different factors (PDF) variance provision.
In a decision of the U.S. Court of Appeals for the Third Circuit in September
1983, the Court ordered EPA to redefine pass through, interference, and new
source. The Court also upheld the electroplating standards, the combined
wastestream formula, and the removal credits provision. Subsequently in 1985,
the Supreme Court upheld EPA's fundamentally different factors variance.
Since 1981, EPA has promulgated amendments to the removal credits regulations.
These amendments are currently being challenged in the Third Circuit.
Program Approvals
As a result of these various delays, the development and implementation
of the National Pretreatment Program was hampered, and only about 40 percent
of approximately 1,500 POTWs required to develop pretreatment programs had
their programs approved by the July 1, 1983 deadline. Substantial progress
6-51
-------
has been made since major program questions have been resolved. Figure 6-5
illustrates the total number of local program approvals for the Fiscal Years
1982-1984 and projected Fiscal Year 1985. Table 6-5 breaks out program
approvals by EPA Region as of June 1985.
In terms of State pretreatment programs, 21 States currently have
received program approval out of the 37 NPDES States eligible to apply for
approval authority. Table 6-4 lists these States and the dates of their
program approval. In sum, after a slow start, a majority of States and POTWs
have approved programs.
Program Audits
To ascertain if pretreatment programs are being, effectively operated
after approval, EPA officials, with contractor assistance, have conducted
audits at numerous municipalities. Audit teams interviewed POTW officials
involved in the pretreatment program, accompanied sampling crews to observe
field and laboratory procedures, and reviewed files and budget data. The
audit teams evaluated the following:
1) Adequacy of the municipal sewer use ordinance
2) Existence of interjurisdictional agreements for POTWs receiving
wastes from more than one jurisdiction
3} Implementation of an industrial user permit system or other effective
control mechanism
4) Existence of adequate enforcement policies and procedures and a
willingness to take enforcement actions when necessary
5) Annual publication of significant violations in a local newspaper
6) Adoption and enforcement of the prohibited discharge standards in
40 CFR 403.5 for conventional pollutants, heat, pH, and flow in the
local ordinance
7) Enforcement of National categorical standards, including appropriate
application of the combined wastestream formula and institution of
industrial user reporting requirements
8} Implementation of local limits that have been derived from a
technical evaluation of POTW process inhibition levels, water quality
standards, and sludge disposal options
6-52
-------
a
UJ
CO
(Si
1400 -i
1300 -
1200 -
1100 -
1000 -
900 -
800 -
700 -
600 -
500 -
400 -
300 -
200 -
100 -
PROJECTED
1300
719
580
150
\
10/1/82
10/1/83
10/1/84
10/1/85
FIGURE 6-5. LOCAL PRETREATHENT PROGRAM APPROVALS
IN FY 82, 83, 84, AND 85
6-53
-------
TABLE 6-5. PRETREATMEKT PROGRAM APPROVAL STATUS
(6/30/85)
REGION
I
II
III
IV
V
VI
VII
VIII
IX
X
TOTALS
EPA
REQUIRED
68
57
133
28
107
122
13
52
121
21
722
EPA
APPROVED
45
37
75
22
48
108
13
19
118
21
484
STATE
REQUIRED
13
24
8
373
253
62
1
21
754
STATE
APPROVED
10
20
5
345
132
60
1
21
594
TOTAL
REQUIRED
81
81
141
401
360
122
75
52
122
42
1,477
TOTAL
APPROVED
55
57
80
367
180
108
73
19
119
42
1,100
6-54
-------
9) Adequate monitoring and laboratory practices including a QA/QC
program and chain-of-custody procedures
10) Maintenance of pretreatment program records and procedures to compile
data on new industrial users
11) Funding, staff, and equipment necessary to operate the program.
The following conclusions on the effectiveness of the 28 local programs
audited were drawn:
Most of the POTWs had sufficient legal authority to operate their
programs effectively. Only two of the 28 ordinances contained serious
deficiencies, lacking authority to take immediate action to halt an
industrial discharge in an emergency situation that threatens human
health or welfare.
Twenty-five of the 28 programs audited faced multijurisdictional
enforcement issues. Thirteen of the POTWs had not yet resolved all of
the interjurisdictional issues they face. Lack of resolution in
multijurisdictional situations means that there is no guarantee that
enforcement actions can be taken against industrial users outside the
boundaries of the municipality in which the POTW is located.
Although all of the programs audited use or intend to use permits to
regulate their industrial users, one third of the programs have
ineffective permit systems. Deficiencies ranged from total lack of a
system to failure to review and reissue expired permits.
Half of the POTWs had written adequate enforcement procedures, but few
of the POTWs have established policies that dictate when and what type
of enforcement actions are to be taken. Many had never taken formal
enforcement actions, although in seven cases there had been serious
violations. Personnel from most of the POTWs that were audited
expressed a reluctance to take any kind of formal action because it
might affect their relations with the industrial community.
All of the POTWs have Federally mandated prohibited discharge
standards in their sewer use ordinances. Their record on enforcement
of these standards was not ascertained. Enforcement of National
categorical standards was generally poor. More than half of the POTWs
audited had limits less stringent than categorical limits, did not
apply the combined wastestream formula when appropriate, or did not
yet know whether they, had any categorical industrial users. Also,
only four POTWs had implemented procedures to ensure that categorical
industrial users comply with the reporting requirements in 40 CFR
403.12 (i.e., baseline monitoring reports, reports on compliance with
categorical standards, and periodic reports on continuing compliance).
Only half of the POTWs had developed technically based local limits.
6-55
-------
f Monitoring programs were generally good. Twenty out of 28 had proper
' QA/QC prodedures. One deficiency was the lack of chain-of-custody
procedures at half of the POTWs, which could seriously hamper sub-
sequent enforcement actions. More than half of the POTWs lacked
adequate safety procedures.
Ten of the 28 POTWs had procedures for updating their industrial user
data. Staff from most of the POTWs that were lacking procedures
seemed to consider it an insignificant issue.
Sixteen of 28 programs had adequate data management systems. The most
common problem encountered was decentralized files, making a cross-
checking of permitting, inspection, and enforcement files difficult.
Four of the programs had major resource problems, primarily because
they had underestimated their staff and funding needs when the program
was developed.
Pretreatment Implementation Review Task Force (PIRT)
In February 1984, EPA established the Pretreatment Implementation Review
Task Force (PIRT), to review the status of implementation of the National
Pretreatment Program and to provide the Agency with recommendations for
improving the program. The day-to-day problems faced by POTWs, States,
industries, and EPA Regions in implementing the General Pretreatment
Regulations and the Categorical Pretreatment Standards regulations were
(Q\
reviewed.v ' PIRT identified five basic areas where improvement is needed:
Guidance to simplify and clarify the pretreatment program requirements
Enforcement of the requirements
Staffing and resources to implement the requirements
Definition of the roles and relationship between EPA, States, and
POTWs
Regulatory revisions.
A full discussion of the PIRT recommendations is presented in the Pretreatment
Implementation Review Task Force Final Report to the Administrator, EPA,
Office of Water Enforcement and Permits, January 30, 1985.
6-56
-------
In response to these recommendations, the following guidance materials
have been prepared or are in some stage of development by EPA:
Guidance Manual for Implementing Total Toxic Organics (TTO) Pretreat-
ment Standards (now available)
t Guidance Manual for Preparing and Reviewing Removal Credit
Applications (now available).
RCRA Notification Handbook (now available)
Categorical Standards Guidance
t Combined Wastestream Formula Guidance (now available)
Local Limits Guidance
Sludge Disposal Regulations
POTW Interference Guidance.
In addition to the above guidance materials, PIRT also made the following
recommendations:
EPA should expedite issuance of water quality standards
EPA should expeditiously develop sludge management and disposal
requi rements
EPA should publish guidance for the local regulation of private
research and development and Federal facilities
EPA should provide guidance on industrial monitoring frequency
EPA should develop an inspection training program for POTWs
EPA should develop a uniform data reporting format for the annual POTW
report
EPA and delegated States should step up their enforcement actions
against POTWs without program applications
EPA, delegated States, and POTWs with approved programs should step up
their enforcement actions against industrial users not submitting BMRs
and those not in compliance with categorical standards
The Federal government through EPA should increase the resources
available to implement the National Pretreatment Program by increasing
manpower at EPA and increasing grant funding to States and POTWs.
6-57
-------
Implementation Status of the Categorical Standards
The key vehicles for reducing toxic loadings to the Nation's sewers are
the pretreatment standards for categorical industries. After initial delays,
EPA has made considerable progress in promulgating these National standards.
As shown in Table 6-6, pretreatment standards have been issued for 22 cate-
gorical industries and are proposed for one other industry. By the end of
1985, the pretreatment compliance dates for 12 industries will have passed,
five will come due in 1986, four in 1987, and one in 1988.
Full implementation of the categorical standards will result in a
significant reduction in toxic loadings to POTWs. Estimates of the controls
afforded by categorical standards are provided in the next section. They
hinge upon substantial industrial compliance with the categorical standards.
For the few industries with compliance deadlines that have passed, it is
difficult for EPA or States to assess industrial compliance rates. They are
hampered by reporting discontinuities inherent to the General Pretreatment
Regulations, the lack of a National tracking system, the decentralized
administrative network, the large number of industries involved, and the
inadequacy of resources for Federal and State oversight.
In spite of EPA's inability to make accurate comprehensive compliance
projections for industries, selected assessments have been made that may be
indicative of National compliance trends. EPA conducted a recent effort to
evaluate the compliance status of 333 electroplating facilities associated
with 15 major National corporations. In EPA's assessment of these major
electroplating facilities, compliance information was available on 280
facilities and 78 facilities out of the 280 (28 percent) were found not to be
in compliance according to BMRs or other compliance information as of
September 1984. For an additional 52 facilities of the 280 (or 19 percent of
major industries) compliance status could not be confirmed. Thus, compliance
may be as high as 70 percent for these facilities. Table 6-7 summarizes the
status of the facilities inventoried by EPA. Since the firms examined in this
assessment were major corporations, it is conceivable that these numbers are
higher than actual National compliance rates.
6-58
-------
TABLE 6-6. SUMMARY STATUS OF NATIONAL CATEGORICAL PRETREATMENT STANDARDS:
MILESTONE DATES
SUMMARY STATUS OF NATIONAL CATEGORICAL PRETREATMENT STANDARDS: MILESTONE DATES
FINAL REGULATIONS
Ul
IO
Industry Category
Aluminum Forming
Battery Manufacturing
Coil Coating I
Coll Coating (Canmaking)
Copper Forming
Electrical Components I
Electrical Components II
Electroplating
Inorganic Chemicals I
Inorganic Chemicals II
Iron and Steel
Leather Tanning
Metal Finishing
Metal Molding and Casting
Nonferrous Metals Forming
Nonferrous Metals I
Nonferrous Metals II
Promulgation
Date
10-24-83
3-9-84
12-1-82
11-17-83
8-15-83
4-8-83
12-14-83
1-28-81
7-15-83
6-29-82
8-22-84
5-27-82
.11-23-82
7-15-83
10-8-85
8-23-85
3-8-84
9-20-85
Effective
Date
12-7-83
4-23-84
1-17-83
1-2-84
9-26-83
5-19-83
1-27-84
3-30-81
8-29-83
8-12-82
10-5-84
7-10-82
1-6-83
8-29-83
12-13-85
10-7-85
4-23-84
11-4-85
BMR Due Date
6-4-84
10-20-84
7-16-83
6-30-84
3-25-84
11-15-83
7-15-84
9-26-81 {Noninteg.)
6-25-83 (Integrated)
2-25-84 (TTO)
5-9-83
4-3-85
4-6-83
7-5-83
2-25-84
6-11-85
4-5-86
10-20-84
5-3-86
PSES
Compliance
Date
10-24-86
3-9-87
12-1-85
11-17-86
8-15-86
7-1-84 (TTO)3
11-8-85 (As)
7-14-86
4-27-84 (Noninteg.)
6-30-84 (Integrated)
7-15-86 (TTO)
8-12-85
6-29-85
8-22-87 (CuSO,,
NiS04)
7-10-85
11-25-85
6-30-84 (Part 433, TTO)2
7-10-85 (Part 420, TTO)
2-15-86 (Final)
10-31-88
8-23-88
3-9-87
9-20-88
-------
TABLE 6-6. SUMMARY STATUS OF NATIONAL CATEGORICAL PRETREATHENT STANDARDS:
MILESTONE DATES (Continued)
SUMMARY STATUS OF NATIONAL CATEGORICAL PRETREATMENT STANDARDS: MILESTONE DATES (Continued)
FINAL REGULATIONS
Industry Category
Pesticides
Petroleum Refining
Pharmaceuticals
Plastics Molding and
Forming
Porcelain Enameling
Pulp, Paper, Paperboard
Steam Electric
Textile Mills
o» Timber Products
o
Organic Chemicals
Promulgation
Date
10-4-85
10-18-82
10-27-83
12-17-84
11-24-82
11-18-82
11-19-82
9-2-82
1-26-81
(3-86)
Parentheses indicate expected milestone dates
Footnotes:
Effective
Date
11-18-85
12-1-82
12-12-83
1-30-85
1-7-83
1-3-83
1-2-83
10-18-82
3-30-81
PROPOSED
(5-86)
BMR Due Date
5-17-86
b-30-83
6-9-84
7-29-85
7-6-83
7-2-83
7-1-83
4-16-83
9-26-81
REGULATIONS
(11-86) (6-89)
for categories that do not yet have final
PSES
Contpl i ance
Date
11-18-88
12-1-85
10-27-86
..i
11-25-85
7-1-84
7-1-84
--1
1-26-84
3-21-83
standards.
(1) No numerical pretreatment limits have been established for these industrial categories, and there is no
final compliance date for categorical pretreatment standards. Firms in these categories are required to
comply only with the General Pretreatment Regulations in 40 CFR 403.
(2) Existing sources that are subject to the Metal Finishing standards in 40 CFR Part 433 must comply only
with the interim limit for Total Toxic Organics (TTO) by June 30, 1984. Plants also covered by 40 CFR
Part 420 must comply with the interim TTO limit by July 10, 1985. The compliance date for Metals,
Cyanide, and final TTO is February 15, 1986 for all sources.
(3) The compliance date for existing Phase I Electrical and Electronic Components manufacturers for TTO is
July 1, 1984. The compliance date for arsenic is November 8, 1985.
Note: The compliance date for any New Source (PSNS) is the same date as the commencement of the discharge.
-------
TABLE 6-7. COHPLIANCE STATUS OF MAJOR ELECTROPLATING FACILITIES
BY EPA REGION
ALL COMPLIANCE INFORMATION6
Number of
Region Facilities Identified
No. of Facilities
With Compliance
Information Located
I
II
III
IV
V
VI
VII
VIII
IX
X
TOTAL
15
31
25
39
153
14
16
2
33
5
333
14
27
21
26
133
10
14
1
29
5
280
Evaluated Compliance
Based on all Information
Yes (%)c
4 (29)
10 (37)
10 (48)
9 (35)
83 (62)
7 (70)
6 (43)
0 (0)
17 (59)
4 (80)
150 (54)
No (*)
4 (29)
12 (44)
6 (28)
4 (15)
36 (27)
2 (20)
6 (43)
0 (0)
8 (28)
0 (0)
78 (28)
UNK (%)
6 (42)
5 (19)
5 (24)
13 (50)
14 (11)
1 (10)
2 (14)
1 (100)
4 (14)
1 (20)
52 (18)
Percentages in parentheses are based on the number of facilities with BMRs located.
Includes all types of information: BMRs, POTW records, and industry-reported compliance data,
cPercentages in parentheses are based on the number of facilities with compliance information
located.
6-61
-------
6.3.2 Effectiveness of Categorical Standards
Scope of Categorical Standards/Industrial Categories Regulated
EPA has already promulgated or will promulgate categorical pretreatment
standards for 23 of the 34 industrial categories listed in the NRDC consent
decree. Once fully promulgated and implemented, these standards will encom-
pass at least 14,000 industrial users, including discharge sources in
important industrial categories such as the metal finishing, pesticides
manufacture and formulation, and organic chemicals, plastics and synthetic
fibers categories. At the same time, the Agency has determined, by authority
of Paragraph 8 of the NRDC Consent Decree, that national categorical standards
for all or part of twelve other industrial categories, including paint formu-
lation, printing and publishing, and auto and other laundries are not neces-
sary. Sources in these categories are still regulated under prohibited
discharge standards (e.g., pH, fire/ explosion, interference) enumerated in
the general pretreatment regulations (see 40 CFR Part 403), and may also be
specifically regulated under provision of local POTW ordinances.
Based on the scope of the NRDC consent decree and the extent of Paragraph
8 exemptions, potential industrial sources of hazardous waste discharges to
POTWs may not currently be regulated by categorical standards. These
potentially unregulated sources include new, emerging industries {e.g., waste
reduction, waste treatment) that are not addressed in the Consent Decree, and
smaller, more numerous service-oriented industries (e.g., laundries, printing/
publishing operations, motor vehicle services) that tend to discharge smaller
quantities of toxic pollutants on a facility-specific basis. Moreover, many
industrial sources practicing intermittent batch discharge of wastes (e.g.,
spent solvents, off-spec products) are not currently regulated by categorical
standards either because these discharge practices could not be adequately
characterized by industry sampling programs supporting rulemaking or because
these practices, by themselves, did not provide an adequate basis for
regulating an entire category.
6-62
-------
Scope of Categorical Standards/Priority RCRA Constituents Regulated
As discussed above, the effluent guideline rulemakings have focused
almost exclusively on the control of the 126 compounds on the priority
pollutant list. Because heavy metals are well represented on the priority
pollutant list and heavily regulated under categorical standards, implemen-
tation of existing categorical standards should produce substantial reductions
in loadings of hazardous metals (e.g., lead, cadmium, nickel) to POTWs. The
Chapter 3 industry assessment projects a 95 percent reduction in total
priority metals loadings to POTWs, and substantial reduction for major metals
sources such as the metal finishing, battery manufacturing, leather tanning
and inorganic chemicals industries.
Implementation of existing and proposed categorical standards will result
in less extensive control of discharges of organic hazardous constituents by
industrial sources than of metals. The Chapter 3 industry assessment projects
a 47 percent reduction in loadings of total organic hazardous constituents
(priority pollutants only) with full PSES implementation, assuming successful
promulgation of proposed categorical standards for key organics sources such
as the organic chemicals industries. The analysis shows that significant
organics sources (e.g., Pharmaceuticals, laundries, equipment manufacturing,
wood refinishing, petroleum refining) are largely unregulated under existing
categorical standards.
Limitations of categorical standards on the control of certain toxics
discharges, especially organics discharges, may be tied to the following
factors:
Scope of Paragraph 8 exemption. Under the CWA, the Agency must regu-
late pollutants which interfere with, pass through, or are otherwise
incompatible with POTWs, Under Paragraph 8 of the Consent Decree,
however, EPA may exclude from regulation by national categorical
standards categories and pollutants based on a number of consider-
ations including adequacy of analytical methods, treatability, or
redundancy with other pretreatment standards. Most significantly, the
Agency may exempt subcategories if such subcategories comprise less
than 5 percent of sources, discharge compatible pollutants, or where
quantities of incompatible pollutants are considered insignificant.
The Agency has used the Paragraph 8 exemption, in some cases, to
support decisions not to regulate toxic pollutants detected in
discharges by various sources.
6-63
-------
Uncertainty about volatilization In PQTWs. In order to determine
whether a pollutant is incompatible with POTW, the Agency has
traditionally compared BAT technology removal rates with POTW removal
rates, regulating the pollutant where POTW removal rates are less than
(or significantly less than) BAT removal rates. This pass through
analysis, then, depends heavily on availability of adequate experi-
mental and empirical data on industrial and POTW removal rates. The
40 POTW study provided some data on removal rates for certain priority
pollutants, especially organics, but these rates were extremely high
due to volatilization. To date, EPA has included air emissions from
the POTW in its calculation of a POTW's removal of pollutants from
wastewater. This has the effect of increasing the calculated POTW
removal rate, sometimes resulting in a higher removal rate than that
achieved by BAT. This calculation may, in turn, result in a decision
that the pollutant does not pass through the POTW and that pretreat-
ment standards thus need not be promulgated. Citing concerns about
worker safety and health, ozone formation and air toxics, the Agency,
as part of the OCPSF rulemaking, has stated its intent not to consider
pollutant volatilization to be considered removal. If successfully
applied, this principle would result in the control of an increased
number of volatile organic compounds currently discharged to POTWs.
Consideration of POTW interference. In reliance on the prohibited
discharge standards, EPA has placed considerably less emphasis in PSES
rulemakings on the potential for interference with POTW processes/
operations as a result of toxics discharges by industrial sources.
Examples of possible interference include fires/explosions, sewer line
corrosion, worker illness, inhibition, or upset of biological treat-
ment systems, and sludge contamination. With few exceptions, e.g.
leather tanning, the Agency has not undertaken systematic collection
of data (other than request for comments during rulemakings) on these
types of POTW incidents in support of rulemakings for specific indus-
trial categories. Analysis of data collected for the OSS study re-
veals that certain industries are frequently cited as "problem indus-
tries" by POTWs. These incidents often stem from irregular discharge
practices, especially intermittent batch dumping, which are difficult
to detect through routine monitoring by EPA, State, and POTW officials,
These and other considerations have, in some instances, hindered Agency
efforts to establish national categorical standards controlling toxics
discharges to POTWs.
Scope of Categorical Standards/Nonpriority RCRA Constituents Regulated
Because PSES rulemakings have focused largely on the 126 priority
pollutants, categorical standards may not ensure adequate control on the
discharge of other nonpriority RCRA hazardous constituents by industrial
sources. To the extent to which these constituents are treated incidentally
6-64
-------
along with regulated wastestreams, significant removal may be realized.
However, Incidental removals may be countered by wastestream segregation.
Currently, the RCRA Appendix VIII constituent list contains approximately 250
compounds, mostly organics, which are not included on the priority pollutant
list. The Chapter 3 industry assessment demonstrates that some 'industrial
categories, including the organic chemicals, pesticides, and pharmaceutical
industries, discharge substantial quantities of these nonpriority hazardous
constituents in process wastewaters. POTW influent sampling data collected
for this study also shows that a small number of nonpriority constituents are
discharged to POTW systems in significant quantities.
A major impediment to regulation of nonconventional pollutants under
categorical standards has been the lack of information on treatment and
removal of these pollutants by industrial and POTW treatment technologies.
Without this information, EPA cannot conduct the traditional pass through
analysis used to support PSES rulemakings. Recently, in conjunction with PSES
rulemaking for the pesticide manufacture and formulation category, the Agency
has utilized a principle known as "technology transfer" in an attempt to
regulate numerous nonconventional pesticide parameters. Technology transfer
allows EPA to project removal rates for nonconventional parameters by
extrapolating from available treatability data for compounds with similar
physical and chemical properties. If successfully applied, technology
transfer could provide a basis for the regulation of certain RCRA constituents
in the absence of a massive sampling program to assess removal of these
compounds by industrial and POTW treatment systems.
To date, the Agency has not exercised its CWA Section 307(a) authority to
add pollutants to the priority pollutant list. Moreover, the Paragraph 4(c)
Program has not resulted in additional regulation of toxics discharged by
various industrial sources. Under Paragraph 4c of the Consent Decree, EPA is
required to identify and regulate, based on examination of data collected for
BAT/PSES rulemakings, additional compounds detected in industrial discharges
and determined to be incompatible with POTW treatment systems. In evaluating
the 1,565 compounds detected in industrial wastewaters, the Agency identified
six incompatible compounds discharged by industrial sources. EPA has not yet
6-65
-------
completed regulatory action to control the discharge of these compounds.
Because of its limited scope the Paragraph 4(c) Program has yet to provide an
effective tool for the control of nonpriority RCRA constituents (see Chapter 2
for more information).
6.3.3 Effectiveness of Prohibited Discharge Standards
Under the General Pretreatment Regulations, prohibited discharge
standards include general and specific prohibitions on the discharge of
certain wastes to POTWs. Also, POTWs must develop local limits as necessary
to implement these prohibitions. Importantly, prohibited discharge standards
apply to pollutant discharges to POTWs from any nondomestic sources. As a
result, these standards may be applied to a range of industrial categories not
currently regulated under national categorical standards. This section
evaluates application of existing prohibited discharge standards, including
local limits, to control hazardous waste discharges to POTWs by diverse
industrial sources.
General Prohibitions
These provisions prohibit the discharge by any nondomestic source, of
pollutants that interfere with the operation or performance of a POTW or pass
through a POTW. At the present time, EPA has suspended the regulatory
definitions for "interference" and "pass through" due to litigation involving
the issue of causation. Under recently proposed definitions, interference and
pass through are defined as follows:
Interference - means a discharge by an industrial user which, alone or
in conjunction with discharges by other sources, inhibits or disrupts
the POTW, its treatment processes or operations, or its sludge
processes, use or disposal and which is the cause of a violation of
Pass through - means discharge of pollutants through a POTW into
navigable waters in quantities or concentrations, which, alone or in
conjunction with discharges from other sources, is a cause of a
violation of any requirement in a POTW's NPDES permit or of the
prevention of sewage sludge use or disposal in accordance with
Federal, State or local law.
See 50 FR 25526-27, June 19, 1985 for discussion of proposed definitions.
6-66
-------
The general prohibition against interference provides a legal basis for
the control of some hazardous waste discharges to POTWs. The prohibition can
be most effective in the control of intermittent slug load discharges of
hazardous wastes causing sudden inhibition or upset of biological treatment
processes. Enforcement of this prohibition, however, has been complicated by
technical difficulties confronted by POTWs in identifying the specific
pollutants which caused the inhibition or upset, and the source(s) of the
offending discharge. These technical difficulties are reflected in POTW
incidents evaluated in this study. Frequently, POTWs refer to generic
pollutant classes (e.g., solvents, organics) or unknown pollutants as the
causative agents for process or operational interferences and to suspected or
unknown sources of these pollutant slug loads. The interference prohibition
tends to be less effective in instances where toxic discharges only inhibit
treatment processes, resulting in marginal permit violations or decreased
plant efficiency.
Enforcement of the prohibition against discharges that contaminate sludge
are currently hindered by the absence of Federal, State and local standards
governing use and disposal of sewage sludge for some contaminants that may be
of concern. Currently, CWA Section 405 sludge use and disposal criteria con-
tain few limitations on toxic pollutants, especially organics. As mentioned,
these criteria are currently being developed. Now, where contamination
occurs, POTWs may have substantial difficulty in ascertaining sources of the
offending discharges, and apportioning liability for sludge contamination
among these sources.
The prohibition against pass through is presently less effective in
controlling hazardous waste discharges to POTWs due to the absence of water
quality standards and water quality-based NPDES effluent limitations governing
discharges of toxic pollutants, especially orgam'cs. Moreover, there are few
Federal water quality criteria to assist States in establishing water quality
standards for nonpriority hazardous constituents. Consequently, there are few
enforceable standards or criteria defining when pass through has actually
occurred. In certain instances, NPDES permits may contain priority pollutant
limits and generic prohibitions against discharges that harm aquatic life or
6-67
-------
receiving waters, but enforcement of these requirements will almost certainly
require extensive monitoring (water quality monitoring, biomonitoring,
bioassays) over time to determine causative pollutants and sources.
Specific Prohibitions
Specific prohibitions forbid the discharge of specific types of materials
which can have deleterious effects on POTW collection and treatment systems.
Currently, pretreatment regulations contain five specific prohibitions
applying to:
Pollutants which create fire/explosion hazard
Pollutants which cause corrosive damage
Pollutants which cause obstruction to flow within a POTW
Pollutants which cause interference with a POTW
Heat inhibiting POTW biological activity.
Specific prohibitions also apply to any nondomestic source discharging waste
to a POTW, Because specific prohibitions tend to apply at the point of
industrial discharge, these prohibitions provide more effective control over
discharges of hazardous wastes, particularly characteristic hazardous wastes.
Still, certain prohibitions remain somewhat vague in scope, particularly when
compared with the greater specificity of testing procedures used to charac-
terize hazardous waste. The discussion below focuses exclusively on specific
prohibitions for fire and explosion hazards and for corrosivity. The inter-
ference prohibition is analogous to the general prohibition for interference
discussed above, while prohibitions on heat and obstruction relate only
peripherally to the control of hazardous waste discharges.
The specific prohibition relating to fires and explosion applies to
"pollutants which create a fire or explosion hazard in the POTW." This
provision can be and has been utilized to control discharges of certain RCRA
characteristic wastes, particularly ignitable wastes and reactive wastes. The
RCRA characteristic of ignitability (40 CFR 261.21) encompasses waste which:
6-68
-------
Is a liquid, other than aqueous solution containing less than 24
percent alcohol by volume and has a flash point less than 60 degreees
Centigrade
Is not a liquid and is capable under standard temperature and
pressure, of causing fire through friction, absorption of moisture or
spontaneous chemical changes and, when ignited, burns so vigorously
and persistently that it creates a hazard
Is an ignitable compressed gas or an oxidizer pursuant to
49 CFR Part 173.
The RCRA characteristic of reactivity (40 CFR 261.23) encompasses waste
which:
Is normally unstable and readily undergoes violent change without
detonating
Reacts violently with water
Forms potentially explosive mixtures with water
When mixed with water or because it is cyanide or sulfide bearing
waste exposed to pH between 2 and 12.5, it generates toxic vapors
which may present a danger to human health or the environment
Is capable of detonation or explosive reaction or decomposition at
standard temperature and pressure, or if subjected to strong
initiating source or heated under confinement
Is a forbidden, Class A or Class B explosive pursuant to
49 CFR Part 173.
The pretreatment prohibition is broad enough in scope to control many of these
RCRA wastes. However, POTWs need further clarification and guidance to more
effectively utilize this regulatory tool to control ignitable and reactive
materials. Additional clarification and guidance would help POTWs improve
their ability to identify in advance those situations in which a fire or
explosion is likely to occur. Existing controls on ignitable and reactive
compounds are not being applied as effectively as possible, as reflected in
the Chapter 3 industry assessment, which shows the discharge of millions of
kilograms of ignitable materials such as aromatic hydrocarbons, ketones, and
aldehydes, and in the POTW incident file which documents numerous discharges
causing or creating a risk of fire or explosion in POTW systems (see Appendix
K).
6-69
-------
Although many POTWs have adopted generic fire and explosion provisions
analogous to the Federal provision, numerous other POTWs have enacted pro-
visions incorporating standardized measures for fire and explosion hazard or
prohibiting the discharge of certain pollutants and pollutant classes. As an
example of the former case, six of 33 POTW ordinances reviewed for this study
contain the following provision:
"At no time, shall two successive readings on an explosion
hazard meter, at the point of discharge into the [POTW] system
(or at any point in the system) be more than five percent (5%)
nor any single reading over ten percent (10%) of the Lower
Explosive Limit (LEL) of the water."
One ordinance contains a provision utilizing a flashpoint measure (235°F using
closed cup method) to regulate the discharge of liquid waste to public sewers.
Another ordinance explicitly prohibits the discharge of materials such as
gasoline, naphtha, kerosene, paints, lacquers, fuel oil, and other petroleum
products. A more extensive provision, found in several POTW ordinances,
limits the discharge of seventeen organic materials including:
gasoline ethers perchlorates
kerosene alcohols bromates
naphtha ketones carbides
benzene aldehydes hydrides
toluene peroxides sulfides
xylene chlorates
These types of ordinance provisions should drastically curtail use of sewers
for disposal of organic compounds, especially solvents commonly associated
with degreasing and painting operations. Where these "zero discharge"
provisions have been enacted, banned materials such as benzene, toluene, and
xylene have still been found in POTW influent wastewaters in significant
quantities, suggesting the need for more aggressive enforcement.
Many POTWs have also enacted additional provisions regulating materials
considered reactive wastes. Some POTWs have adopted numerical limits to
control pollutants, such as cyanide and sulfides, which may cause wastes to
6-70
-------
assume reactive characteristics. Several of the ordinances reviewed for this
study also contain a provision prohibiting the discharge of wastes which may
generate toxic forms under conditions found in POTW collection and treatment
systems* '.,-...,
The specific prohibition applying to corrosive wastes forbids the
discharge of:
"Pollutants which will cause corrosive structural damage to the
POTW, but in no case discharges with pH lower than 5.0, unless
the works is specifically designed to accommodate such
discharges."
The RCRA characteristic of corrosivity (40 CFR 261.22) applies to waste which:
Is aqueous and has a pH less than or equal to 2 or greater than 12.5
or
Is liquid and corrodes steel at a rate greater than 6.35 mm per year
at a test temperature of 55 degrees Centigrade.
By prohibiting wastes with a pH less than 5.0, the specific prohibition on
corrosive wastes will, if fully enforced, provide sufficient control on the
discharge of acidic (I.e., low pH) hazardous waste to sewers. The pretreat-
ment provision as is, however, does not contain a corresponding numerical pH
limitation on discharge of caustic wastes (i.e., high pH), and therefore may
not adequately control the discharge of these wastes to POTWs. Based on a
review of 33 ordinances for this study, many POTW ordinances contain more
stringent numerical limits on the discharge of caustic wastes. Generally
ranging between 9.0 and 11.0, these maximum pH limitations will, if adequately
enforced, prevent the discharge of caustic hazardous waste at these POTWs.
Local Limits
Under the General Pretreatment Regulations, POTWs administering local
pretreatment programs must develop and enforce local limits to implement
general and specific prohibitions. Although this limit-setting process offers
substantial potential for Improved control of hazardous wastes discharges,
6-71
-------
efforts by EPA, States, and POTWs to establish effective local limits have met
with only limited success. Confusion surrounding the interpretation of
regulatory requirements, the limited number of toxics criteria for water
quality protection and use and disposal of sewage sludge, and inadequate
resources have significantly hindered the development, by POTWs, of local
limits to control toxics discharges.
Based on a review of 33 POTW ordinances conducted for this study, it
would appear that most ordinances already contain numerical limitation on the
discharge of heavy metals, including EP toxic metals such as arsenic, cadmium,
chromium, and lead. POTW ordinances may also contain numerical limits con-
trolling other pollutants such as cyanide, phenols, and sulfides. Some
ordinances ban or restrict the discharge of certain highly toxic and persis-
tent compounds, particularly chlorinated pesticides and herbicides. Few
ordinances, however, contain specific numerical limits designed to control the
discharge of common organics such as chlorinated solvents. Only 2 of 33
ordinances reviewed contain limits for common solvents such as benzene, ethyl
benzene and methylene chloride. Both of these two ordinances, however,
regulate at least one nonpriority organic pollutant (e.g., carbon disulfide,
acetone, methanol, methyl ethyl ketone, cresols, isobutanol).
Many numerical limits currently contained in POTW ordinances have
resulted from the use of limit-setting methodologies which do not consider the
systematic effects (i.e., interference, pass through) of toxics discharges on
POTW systems. A report summarizing the findings of pretreatment program
audits conducted at 28 POTWs indicated that over half of the POTW ordinances
did not contain limits derived from a technical analysis of interference and
pass through concerns. In fact, it appears that some POTWs do not enforce
limits contained in their ordinances based on their conclusions that their
numerical limits are derived from questionable limit-setting methodologies
(e.g., adopted from other ordinances) or would, in their opinion, be
unrealistically stringent if actually enforced against nondomestic sources
discharging the regulated pollutant.
6-72
-------
To address these concerns about development and enforcement of local
limits, EPA has established a national policy designed to clarify regulatory
requirements relating to local limits. Under this policy, a POTW must perform
the following three functions in setting limits:
Perform industrial waste survey and sample influent, effluent, and
sludge to identify pollutants of concern
Determine, using best available information, the maximum loadings
which can be accepted by the treatment works without occurrence of
pass through, interference, or sludge contamination
Implement a system of local limits to assure that these loadings will
not be exceeded.
At a minimum, EPA will require POTWs to conduct this technical evaluation for
six metals, including cadmium, chromium, copper, lead, nickel and zinc. In
addition, based on site-specific information, the POTW must identify other
pollutants of concern which might reasonably be expected to be discharged to
the POTW in quantities which could pass through or interfere with the POTW,
contaminate the sludge, or jeopardize worker safety and health. Nevertheless,
without more technical information available to municipalities on POTW
interference, and pollutant fate and effects, POTWs will have a difficult time
developing local limits.
6.3.4 Effectiveness of Spill Control and Liquid Waste Hauler Controls
Two sources of hazardous waste discharges present special control
challenges to POTWs within the context of their pretreatment programs --
spills and discharges by liquid waste haulers. Neither is comprehensively
addressed in the General Pretreatment Regulations, although program mechanisms
and procedures may operate to minimize some of the risks associated with these
sources. The following subsections examine applicable pretreatment controls,
estimate the occurrence of spills and liquid waste hauler discharges to POTWs,
and highlight additional efforts taken by municipalities to address these
sources.
6-73
-------
Spills
The principal pretreatment provision directly pertaining to spills is the
requirement in 40 CFR 403.12 that industries subject to categorical standards
notify POTWs of slug loads of pollutant discharges that, because of flow rate
OP concentration, will interfere with or pass through the POTWs. No mandatory
follow-up is required, preventative measures are not specified, and imposition
of fines is not required. In addition, the prohibited discharge standards and
categorical standards may serve to regulate the presence and concentration of
constituents in spills. As discussed earlier, CERCLA exempts spills and
discharges to POTWs from reportable quantity spill reporting requirements,
provided that pretreatment standards are met. Thus, formal pretreatment
controls for spills are, essentially, incidental to overall toxics regulation
at P.OTWs.
Results from the AMSA survey, as well as a review of incidents at other
POTWs, indicate that spills to sewage treatment plants are frequent occur-
rences. Roughly two-thirds of all AMSA respondents reported that hazardous
wastes had been discharged to their plants as a result of spills. Perhaps as
a result, the AMSA respondents have taken steps beyond the pretreatment regu-
lations to prevent spills. According to the survey, virtually all AMSA
members require notification of spills, roughly two-thirds have comprehensive
accidental spill prevention programs for their POTWs, and three-quarters
report that they require industries to take spill prevention measures.
These results are somewhat contrary to other observations from audits and
program reviews which Indicate that less than half of all POTWs have spill
containment and prevention programs. Deficiencies observed Include a lack of
Information on materials stored onslte, a lack of resources necessary to
Inspect potential dischargers, and an Inability to identify a set of indus-
tries which constitute potential toxic dischargers. Also, system size and
Inadequacy of sampling procedures may make spill Identification difficult.
Nonetheless some Industries and POTWs do engage in extensive spill
control and prevention measures. The State of Pennsylvania, for example,
6-74
-------
requires all industries and commercial facilities to prepare and submit
Preparedness, Prevention and Contingency Plans. EPA Region X is requiring all
pretreatment POTWs to develop and implement spill plans and is developing an
accidental spill prevention plan guidance manual to assist POTWs in iden-
tifying likely industries, pollutant sources, and effective cleanup measures.
Components of local programs can easily be adapted to incorporate spill
measures. Some POTWs impose spill prevention measures (berms, contained
storage areas) in industrial permits. Others require lUs to submit formal
spill containment plans. Some POTWs have inspectors who conduct routine
inspections, look for potential spill conditions, and issue corrective orders
where necessary. Many municipalities have established communication links
with area fire and rescue departments so that POTWs are informed before
highway spills are flushed into sewers. Sensitivity to spills seems to be
increasing, and as a result further adaptions of pretreatment controls may be
expected.
Control of Liquid Waste Haulers
Discharges from liquid waste haulers are subject to the same categorical
standards, general and specific prohibitions, and local limits that any
industrial discharger to a POTW is under the pretreatment program. RCRA
singles out POTWs receiving hazardous wastes by truck or rail for regulation
under permit-by-rule.
Given their mobility and the variability of waste hauled, these sources
/-j\
do present unique enforcement issues for POTWs. The AMSA surveyVJ; indicates
that a substantial subset of POTWs receive wastes containing hazardous
constituents from liquid septage haulers (32 percent) and other liquid waste
haulers (23 percent of AMSA respondents). As described earlier, subsequent
discussions with POTW operators of these systems indicated that these POTWs
have not knowingly received manifested hazardous wastes from haulers. As also
described earlier, these POTWs have developed monitoring programs to identify
haulers seeking to dispose of hazardous waste and have turned these haulers
away. Forty percent of POTWs reported midnight dumping of hazardous wastes to
their systems. Mobile sources are a likely suspect in these situations. At
6-75
-------
the same time, AMSA cities report a diversity of special control measures for
liquid waste haulers. Sixty percent employ permits or agreements with the
specific trucking firm and 74 percent require the disposal of wastes at
designated points in the system (usually at a designated manhole or at the
plant itself). Interestingly, 17 out of the 66 POTWs require permits with the
actual waste source, rather than the transporter, and 20 cities employ a
manifest system. Roughly 60 percent of the cities perform some sampling on
batches prior to discharge.
Mobile sources do present unique control problems for cities. As
introduced by AMSA results, POTWs have employed four basic types of controls:
Control mechanisms - permits and manifests
Waste standards and limits
Discharge point to the POTW
Monitoring requirements - trucker, IU or POTW.
Each is discussed below.
POTWs usually employ a variety of control mechanisms to track the
disposal of liquid wastes. Some POTWs provide general permits to trucking
firms; others develop a permit for each discharge. In addition a cradle-
to-grave manifesting system involving all parties may be employed. This is
analogous to RCRA's permitting system.
POTWs that allow waste haulers to discharge to their systems sometimes
have separate standards and limits which may be more or less stringent than
those for IUs. Hauler discharge standards can range from allowing only
domestic septic wastes to allowing discharges of other nonhazardous industrial
waste.
The discharge point(s) set aside by POTWs for waste haulers and the
controls available at the point(s) can affect the types and quantities of
wastes discharged. If the discharge point is at the treatment plant or other
6-76
-------
controlled point (i.e., where a POTW worker can check and prevent the dis-
charge if necessary), the types of wastes that the waste hauler will discharge
are more likely to meet the POTWs standards. In addition, if the POTW has
facilities to hold wastes prior to discharge, analytical results can be
evaluated prior to discharge. However* if the discharge point is uncon-
trolled, then the hauler has the potential to discharge any kind of waste.
Related to the discharge point and whether or not it is controlled are
the POTWs monitoring requirements. Some POTWs require or conduct an analysis
of every load of waste prior to discharge; other POTWs do random analysis or
perform visual, pH, or other simple tests to check the waste prior to dis-
charge. Others, however, only require the hauler to log in or report to the
POTWs that a load has been discharged. Rarely do POTWs have time to examine
analytical results prior to discharge. However, truckers know that if they
discharge any prohibited wastes, they may be banned from future use of the
POTW as well as being subject to CWA enforcement action.
Waste hauler controls the POTW utilizes should vary with the types and
quantities of wastes discharged. If the POTW combines strict waste standards
and limits with a controlled discharge point and regular monitoring, this
control method should reduce and possibly eliminate hazardous waste discharges
from waste haulers.
Liquid waste haulers also present a distinct enforcement challenge. The
threat of terminating sewer service, which tends to be an effective method for
correcting illegal discharges from fixed sources, can only be employed as an
enforcement tool against mobile sources, such as septic haulers, that regu-
larly utilize POTW facilities. Some States and localities have established ad
hoc hazardous waste strike forces to cope with these problems, particularly
where they transcend State and local jurisdictional boundaries. Many POTWs
have not yet developed extensive procedures for detecting and investigating
hazardous waste discharges by mobile sources.
6.3.5 Municipal Perceptions on the Need for Hazardous Waste Control at POTWs
The foregoing subsections constitute an evaluation of the effectiveness
of pretreatment program components in controlling DSE wastes. This analysis
6-77
-------
suggests that after some delay, significant progress has been and continues to
be made to implement pretreatment programs and standards. Substantial toxic
reductions have been realized at some POTWs (especially for metals) and
increased compliance by industrial facilities currently subject to categorical
standards (e.g., the electroplating and metal finishing industries) should
bring about further reductions. However, little control has been directed at
nonpriority hazardous constituents. In addition, evaluation of specific
prohibitions and local limits suggest that these mechanisms have been employed
effectively by some cities to address local problems from industries such as
paint plants and industrial laundries. Given additional technical assistance
and regulatory incentives (toxic permit limits for POTWs, sludge criteria),
more POTWs could develop local limits designed to prevent the discharge of
deleterious hazardous waste to their systems. Finally, controls have also
been adopted for spills and mobile sources.
A principal determinant affecting existing and future municipal efforts
to control hazardous wastes is local perception of the existence and severity
of problems associated with hazardous waste discharges. Do POTWs know whether
hazardous wastes are being discharged to their systems? Are they sampling to
ascertain the presence and sources of these wastes? What impacts have been
felt as a result of these wastes? What responses have cities taken and what
future regulatory steps should be pursued to address hazardous wastes? As a
final step in estimating the potential effectiveness of local pretreatment
activities in controlling hazardous wastes, AMSA POTW responses to these
questions are considered.
5
Hazardous Waste Discharges to Municipal Sewers
Two-thirds of AMSA's responding POTWs report that hazardous wastes are
discharged to municipal collection systems. When queried about the
types of wastes they receive, cities indicated receiving the full
gamut of waste types. The top three wastes were corrosive wastes,
solvents, and plating baths/sludges, reported at over half of the
5
In response to the survey, POTWs reported on practices involving what they
believed to be hazardous wastes as defined by RCRA. Therefore, the term
"hazardous wastes" should be construed here to refer to wastes and waste-
waters (e.g., electroplating baths), as opposed to specific hazardous
constituents.
6-78
-------
responding POTWs. Listed and ignitable wastes had been discharged to
one-third of the POTWs. The most frequently reported reason for
hazardous wastes entering systems was spills reported by 60 percent of
POTWs. Batch, routine, and illegal discharges were mentioned by half
of all the responding cities as generic waste sources. Forty percent
of AMSA cities reported midnight dumping in their systems. Twenty
percent of the AMSA systems indicated that they received wastes from
hazardous waste treatment facilities. Further, POTW respondents
reported a significant increase in hook-up requests from hazardous
waste treatment or reclamation facilities in 1984 and 1985. None of
these data indicates the volume or frequency of hazardous waste
receipt to AMSA POTWs.
Municipal Hazardous Waste Sampling and Analytical Efforts
Virtually all of the AMSA respondents indicate that they perform
sampling and analysis of plant influents, effluents, and industrial
effluents for hazardous wastes (57, 61, and 62 POTW affirmative
responses, respectively). In terms of the specific pollutants
analyzed, all POTWs report performing metals analysis, while roughly
half of the cities engage in toxic organics analysis. Eighty percent
of the AMSA respondents report making special efforts to identify
hazardous waste discharges in their systems. These efforts ranged
from special sampling studies (e.g., Seattle Metro's Toxicant
Pretreatment Study) and manhole surveillance programs, to demand
monitoring after spills.
Impacts of Hazardous Wastes Discharged to Sewers
The results of the AMSA survey pertaining to impacts experienced due
to hazardous wastes receipt are anomalous. One quarter of the
responding municipalities Indicated that problems had occurred at
their plants due to hazardous wastes. Yet when specific impacts were
explored, almost half reported explosions, fires, or threats thereof
and almost an equal number reported corrosion 1n their collection
systems. Forty percent of the AMSA respondents indicate that Indus-
trial wastes caused upsets of biological treatment and 25 percent
reported NPDES permit violations associated with Industrial wastes.
Control of Hazardous Waste Discharges
Fifty-nine out of the 66 AMSA respondents assert that they have
regulatory controls In place to control hazardous wastes. The vast
majority report that they have local limits for metals, and over half
had limits for toxic organics. Two-thirds of the cities do not
believe that a lack of Federal standards or effects or control tech-
nology Information has deterred from local efforts to control hazard-
ous discharge. However, 60 percent of the respondents acknowledged a
need for Increased regulation of toxic organics. There was no con-
sensus on the best approach to fill this need although local limits
were preferred over promulgation of additional Federal categorical
standards.
6-79
-------
As expressed initially, the representativeness of AMSA survey results for
all U.S. POTWs is not asserted. While an excellent data source, encompassing
roughly half of the industrial discharges estimated nationally, AMSA cities
are believed to be larger, more urban, and more sophisticated than the POTWs
nationally. With this caveat in mind, the survey results do confirm that many
sewage treatment plants are receiving hazardous wastes, that efforts to
identify and regulate hazardous wastes are being undertaken, and that impacts
are being felt at POTWs. Further, municipalities indicate that they expect
hazardous waste discharges to increase and additional controls to be
warranted.
6.4 CONCLUSIONS
This chapter has presented an overview of hazardous waste management
requirements under RCRA, wastewater treatment and pretreatment requirements
under the CWA, and other relevant statutory authorities which may affect the
discharge or subsequent release of DSE wastes to the environment. In
particular, controls on the discharge of hazardous wastes to sewers under the
DSE by industrial users/generators have been discussed. In addition, the
regulatory obligations of POTWs receiving both DSE wastes and hazardous wastes
have been discussed.
The purpose of this analysis was to determine if current regulatory
mechanisms and statutory authorities are adequate to control impacts from the
discharge of DSE wastes. This evaluation has focused mainly on the effective-
ness of existing controls, with efforts having been made to take implementa-
tion status and compliance rates into account. However, possible improvements
to programs being implemented under existing statutory authorities have also
been factored into this evaluation.
The overall finding which can be drawn from this regulatory evaluation
(and the technical findings contained in the preceding chapters) is that
sufficient authorities exist under the CWA and RCRA to control the known
impacts associated with the discharge of hazardous wastes to sewers, and that
substantial amounts of priority pollutant hazardous waste constituents have
been regulated under CWA authorities. This basic finding supports retention
6-80
-------
of the domestic sewage exclusion at the present time, recognizing the logic of
RCRA's reliance, principally, on the CWA's pretreatment program, for regula-
tion of the discharge of aqueous hazardous wastes to sewers. At the same time,
the foregoing analysis has identified gaps in existing Federal pretreatment
standards and weaknesses in local pretreatment programs which could be
improved (under existing authorities) to better protect human health and the
environment.
Additionally, a basic lack of information on releases to ground water and
air from POTWs as a result of hazardous (as well as other domestic and
industrial wastewater) discharges suggests that further study be undertaken to
evaluate potential impacts prior to the assessment of the need for additional
regulatory controls. Existing CWA authorities, supplemented by RCRA, could
probably be applied to reduce impacts, if found. Nevertheless, both Impacts
and control options need more extensive study before final conclusions or
recommendations can be drawn.
Supplemental points supporting the above conclusion are provided in the
following discussions of: 1) the logic and rationale for the domestic sewage
exclusion; 2) the effectiveness of CWA pretreatment controls;, and 3) the
appropriateness of other CWA/RCRA controls on POTWs receiving hazardous waste.
6.4.1 The Logic and Rationale for DSE: Effective Interaction Between CWA and
RCRA
The domestic sewage exclusion (DSE) coordinates the regulatory controls
imposed by RCRA and CWA. Under the DSE, discharges of hazardous waste mixed
with domestic sewage remain regulated under the CWA, including the CWA's
pretreatment requirements. Major pretreatment program controls have tradi-
tionally emphasized the control of waste by treatment, at the industrial
source, and prior to discharge to public sewers. Treatment of the concen-
trated industrial wastewater prevents the discharge of hazardous constituents
to POTW collection systems and thus minimizes the release of these con-
stituents to all media, including surface water, sludge, air, and ground
water. Certainly, the information and analysis included in the report does
not question the logic of continuing this approach of control of pollutants at
their source.
6-81
-------
The report has shown that the pretreatment program has been an effective
means of reducing the discharge of many hazardous constituents to POTWs. At
the same time, the report has identified areas where information is lacking
and areas where further actions could take place to remove additional
hazardous constituents from POTWs.
In the absence of the DSE, RCRA waste management requirements would be
layered on top of CWA provisions for control of hazardous waste discharges to
sewers and would impose a variety of additional requirements on POTWs. This
action would require an integration of both programs. It is unclear if the
final integrated program would be substantively different that the existing
pretreatment program with improvements as called for in this report.
For these reasons, this study recommends the retention of the DSE at the
present time and identifies areas where the pretreatment program should be
improved to control hazardous waste discharges to sewers. In addition, the
report describes where information is lacking. If future studies indicate
that further controls are needed to address potential problems such as air and
ground water releases at lUs and POTWs, it would then be appropriate to
reconsider whether modification or elimination of the OSE is required to
implement such controls.
6.4.2 The Effectiveness of CMA Pretreatment Controls
The rationale for the DSE is that pretreatment controls on hazardous
waste discharges will ensure protection to the POTW and receiving environ-
ments. In essence, technology-based and water quality-based standards and
local limits developed by EPA and POTW wastewater treatment experts under
the auspices of the pretreatment program should lead to treatment by IUs/
generators prior to discharge to sewers. The proximity of municipal control
authorities to discharging Industries, along with the wide range of compliance
tools available 1n Federally approved local programs (Industrial Inventories,
inspection, permitting, local limits, reporting, etc.) affords a unique oppor-
tunity for direct, site-specific control of hazardous discharges. Concep-
tually, this seems to be a very logical way of ensuring effective treatment of
hazardous wastes. Section 6.2.4 and 6.3 of this chapter have provided an
6-82
-------
indepth explanation and evaluation of the design and implementation of
pretreatment controls for control of DSE wastes. Summary observations
include:
The substantive pretreatment standards (categorical standards and
general and specific prohibitions) are direct mechanisms for National
regulation of industrial discharges to sewers.
Currently, categorical standards do not cover all industries or
pollutants of concern to the RCRA program.
Categorical pretreatment standards have mainly been targeted at metals
and are predicted to bring about significant reductions in the
discharge of toxic/hazardous wastes from industries such as the
electroplating and metal finishing industries. Standards for the
largest organic discharger, the organic chemicals industry, are to be
promulgated in the year 1986. These standards should address metals
and organic pollutants, including volatile organics.
Categorical standards have not regulated major toxic organic
discharges of pollutants such as methylene chloride, 1,1,1-
trichloroethane, toluene, and ethyl benzene. Major industrial sources
of these unregulated pollutants include the Pharmaceuticals, Equipment
Manufacturers, and Petroleum Refining industries. EPA has announced
its plans to reexamine the need for additional pretreatment standards
for the Pharmaceutical industry (50 FR 36638; September 9, 1985).
The general and specific pretreatment prohibitions can be effective
tools for limiting characteristic hazardous waste discharges to
sewers. For example, pH restrictions may effectively control the
discharge of acidic hazardous wastes and interference prohibitions
may limit reactive wastes. Other prohibitions (e.g., against
explosions) may warrant better definition.
Possible expansion of the definitions of interference and pass through
in the General Pretreatment Regulations to cover air emissions and/or
ground water releases may improve pretreatment controls for
volatilization or ground water contamination.
Local limits can be well-placed to control the impacts of other
hazardous wastes on a site-specific basis to supplement categorical
standards and the prohibitions. Some cities have used them effec-
tively, particularly for metals. Widespread development of local
limits for toxic and hazardous organic compounds will require greater
resources for Campling, analysis, and systems evaluation, and greater
technical assistance.
Key regulatory procedures, inherent in local pretreatment programs are
effective tools for hazardous waste discharge regulation. Source
identification, permitting, sampling and analysis, inspections, and
enforcement and oversight activities by POTWs provide mechanisms for
6-83
-------
DSE waste control. POTWs may also be ideally suited to assist with
regulation of small quantity generators.
Pretreatment procedures need to be extended to cover all sources of
hazardous wastes to POTWs. For example, joint inspections by State or
Federal RCRA and pretreatment officials could supplement existing
resources and provide better integration of controls.
In particular, EPA has not yet implemented Section 3018(d) of RCRA,
Consequently, generators are not yet providing information under this
Section. Further, the RCRA amendments never envisioned that POTWs
would receive these data, and therefore POTWs are left out of RCRA's
paperwork trail even though they may receive hazardous waste.
Sections 3004(m) and (n) of RCRA, which address land disposal ban and
air emission controls respectively, might additionally serve as
potential mechanisms for controlling industrial user discharges.
The effectiveness of the existing program and the implementation of
additional controls for hazardous waste depend on additional local,
State, and Federal resources.
Additional controls for spills and liquid waste haulers are needed
under the pretreatment program to ensure identification and adequate
control of these sources.
On balance, pretreatment programs have controlled substantial amounts of
hazardous constituents, and pretreatment authorities, with some adjustments,
seem well-designed to control the known impacts of DSE wastes. Existing tools
should be employed to deal with the full range of sources and wastes which are
or will be discharged.
6.4.3 Appropriateness Of Other RCRA/CWA Controls On POTHs Receiving Hazardous
Wastes and the Environme'nt'
The majority of Chapter 6 has dealt with the domestic sewage exclusion
and the effectiveness of Federal and local pretreatment controls in regulating
resultant hazardous discharges. A directly related issue is the adequacy of
CWA/RCRA regulation of POTWs which are the recipients of hazardous wastes.
Resolution of this issue requires consideration, on the one hand, of RCRA's
TSDF requirements, and in particular, the permit-by-rule and corrective action
provisions. On the other hand, pertinent water controls include municipal
NPDES permitting, pretreatment controls, and municipal sludge management
requirements.
6-84
-------
RCRA TSDF provisions currently regulate POTWs differently depending on
how they receive hazardous wastes. If a plant receives hazardous waste as a
DSE waste in a domestic sewer pipe, then the POTW is not automatically con-
sidered a TSDF. If a POTW receives the same waste by truck, rail, or dedi-
cated pipe, the POTW is subject to RCRA permit-by-rule provisions including
corrective action. All of these wastes, including those received by truck
must comply with applicable pretreatment standards. This differential
regulatory approach, based solely on the mode by which the waste is received,
may not be justified on an environmental basis. The more appropriate approach
would consider whether specific hazardous wastes are causing environmental
effects at the POTW or on the receiving environment. Additional study is
needed to determine whether there are POTWs with site specific problems
associated with hazardous waste that require consideration of additional
controls. It appears that few, if any, POTWs are currently knowingly
receiving manifested hazardous wastes.
One obvious finding that may guide the development of additional RCRA
controls is the fact that CWA controls are appropriate for limiting surface
water and sludge-related impacts from POTWs, but only have an indirect ability
to control air or groundwater releases from POTWs receiving hazardous wastes.
On the other hand, RCRA authorities are sufficiently broad to permit control
of ground water and air releases from TSDFs.
Alternatively, other statutes might be invoked to control these releases.
For example, VOC regulation under the Clean Air Act might be expanded to cover
releases from POTWs. EPA's Office of Air Quality Planning and Standards is
currently developing an air emissions regulation for TSDFs. POTWs receiving
hazardous wastes could conceivably be covered under this regulation.
Other statutes (e.g., OSHA, CERCLA) may have some utility in controlling
the deleterious effects associated with DSE discharges and releases from
POTWs. For example, CERCLA reportable quantity provisions for spill reporting
may assist in regulation of spills to POTWs once the issue of Federally
permitted releases is resolved. Either CERCLA or RCRA authorities may be
employed as additional enforcement authorities where problems have occurred as
6-85
-------
a result of illegal dumping. In addition, RCRA 3004(m) and (n) authorities
are also potential mechanisms for improving pretreatment source controls on
industrial users.
In trying to resolve the issue of POTW as TSDF, it became apparent that
the status of a POTW as a regulated party under RCRA was unclear to municipal-
ities as well as State and Federal hazardous waste regulators. An evaluation
of HWDMS data on POTW notifications indicated confusion among all parties.
Hence, clarification in regulations or guidance should be a significant step
in ensuring that POTWs receive appropriate attention should they assume the
role of hazardous waste treater.
As a final point, it should be noted that recent changes to RCRA --
restrictions on land disposal and expansion of coverage of small quantity
generators especially -- will probably increase industrial use of the domestic
sewage exclusion to dispose of hazardous wastes. At the same time, the HSWA
extended notification requirements to DSE dischargers, and water and sludge
standards and control techniques are being developed to enhance toxics
regulation in the Nation's water program. Improvements under the CWA and RCRA
should facilitate control of these expected increased discharges.
6-86
-------
CHAPTER 7
FINDINGS AND RECOMMENDATIONS
-------
-------
7. FINDINGS AND RECOMMENDATIONS
7.1 INTRODUCTION
In preceding chapters, EPA identified and characterized sources, types,
and quantities of hazardous wastes discharged to POTWs, and examined the fate
and effects of these wastes once discharged to public sewers. Moreover, the
study discussed and evaluated existing statutory, regulatory, and programmatic
authorities to control hazardous waste discharges to POTWs. This chapter
summarizes the findings of the Domestic Sewage Study in the following three
areas:
Sources, types, and quantities of hazardous wastes currently
discharged to POTWs
Fate of hazardous waste discharges within POTW collection and treat-
ment systems, and potential effects of these wastes on POTW opera-
tions, human health, and the environment
Adequacy of existing controls on the discharge of hazardous wastes.
This chapter also presents a set of recommendations identifying
technical, regulatory, and administrative issues which warrant further
attention.
7.2 FINDINGS
In performing its source evaluation, EPA collected information on waste
discharges from 47 industrial categories and the residential sector. The OSS
analysis provides detailed loadings estimates for 30 selected consent decree
industries. EPA presently does not have sufficient data to characterize fully
waste discharges by the remaining 17 industrial categories, although it
appears, based on limited available data, that certain of these categories may
be discharging significant quantities of waste.
After assessing the various data sources available for performance of the
DSS, EPA adopted a technical approach that provides estimates for loadings of
specific hazardous constituents (e.g., benzene, tetrachloroethylene, acetone,
etc.) rather than generic RCRA waste types (e.g., spent solvents, electro-
plating baths, still bottoms, etc.). The Agency collected and evaluated
7-1
-------
discharge data for 165 selected hazardous constituents. Because of data
limitations, the analysis provides more extensive estimates for loadings of
priority hazardous constituents (i.e., CWA priority pollutants) rather than
nonpriority hazardous constituents. More comprehensive assessment of haz-
ardous waste discharges, then, is heavily dependent on the collection of
additional data on discharges of generic RCRA waste types and nonpriority
hazardous constituents to POTWs. Evaluation of the fate and effects of
hazardous waste discharges in POTWs is similarly hindered by the limitations
on existing technical data for specific constituents, especially nonpriority
constituents.
Findings on Sources, Types, and Quantities of Hazardous Constituents
Discharged to sewers
The DSS source assessment evaluated discharge data for 47 industrial
categories and the residential sector and identified approximately
160,000 industrial and commercial facilities discharging wastes that
contain the hazardous constituents. Together, these facilities dis-
charge an estimated 3,200 mgd of process wastewater, constituting
approximately 12 percent of total POTW flow. The 30 selected consent
decree industries discharge 62,000 metric tons per year of the haz-
ardous metal constituents at raw discharge levels, and 3,300 metric
tons per year of the hazardous metal constituents, assuming full PSES
reductions. With full implementation and enforcement, categorical
standards should produce a 94 percent reduction in metal constituent
loadings from the consent decree industries.
These same industries discharge between 37,000 and 52,000 metric tons
per year of the priority organic constituents at raw discharge levels,
and approximately 20,000 metric tons per year of these constituents,
assuming implementation of existing and proposed PSES standards. At
projected PSES control levels, categorical standards will provide
reductions in organic constituent loadings of between 47 and 60 per-
cent. Relative contributions of metal and priority organic constitu-
ents from the residential sector will increase significantly following
PSES implementation.
- Discharge of Characteristic Wastes to POTWs
Significant quantities of ignitable, corrosive, and reactive
hazardous wastes are discharged to POTWs. POTW operational
problems, including sewer line corrosion, actual or threatened
explosions and generation of toxic fumes, which may result from
these discharges, have been documented. A review of categorical
standards, prohibited discharge standards, and selected POTW
ordinances demonstrates that existing pretreatment standards may
not adequately control the discharge of certain types of
7-2
-------
characteristic wastes. For other waste types, regulatory controls
are already adequate, indicating a need instead for more aggressive
enforcement and additional spill control measures to minimize these
discharges.
- Discharge of Hazardous Metals/Cyanide to POTWs
The consent decree industries discharge approximately 62,000 metric
tons per year of hazardous metals and cyanide to POTWs under a raw
loadings scenario. The electroplating/metal finishing industry
accounts for 68 percent of total raw loadings. Other major metals/
cyanide sources include the organic chemicals, leather tanning,
Pharmaceuticals, iron and steel, battery, and inorganic chemicals
industries. Other possible sources include motor vehicle opera-
tions and service-related industries.
The Chapter 3 industry assessment projects a 94 percent reduction
in metals/cyanide loadings from consent decree industries under the
PSES scenario. Accordingly, full PSES implementation should
provide substantial controls on hazardous metals (including EP
toxic metals) and cyanide discharges from known major sources.
Nonetheless, pretreatment program data indicate that as many as 30
percent of all electroplating/metal finishing firms have not
complied yet with categorical standards for electroplaters/metal
finishers. Consequently, aggressive enforcement of metal finishing
and other categorical standards will be necessary to ensure full
control of metals/cyanide discharges under existing categorical
standards.
- Discharge of Priority Organic Constituents to POTWs
The consent decree industries discharge between 37,000 and 52,000
metric tons per year of priority organic constituents under a raw
loadings scenario. Major priority organics sources include the
organic chemicals, plastics, resins and synthetic fibers, equipment
manufacturing, Pharmaceuticals, electroplating/metal finishing,
iron and steel, petroleum refining, laundries, and pesticide
manufacturing industries. A number of other possible industrial
sources also were identified, including hazardous waste treatment
facilities, wood refinishers, and laboratories.
An evaluation of organics discharge data demonstrates the
importance of current PSES rulemakings for the organic chemicals
and pesticide industries in controlling major organics sources.
Assuming full implementation of the proposed OCPSF standard and the
recently promulgated pesticide manufacturing standards, overall
PSES implementation will result in an estimated 47 to 60 percent
reduction in priority organics loadings to POTWs from consent
decree industries. Nonetheless, other significant organics
sources, such as Pharmaceuticals, equipment manufacturing, laundry,
and petroleum refining industries are not controlled currently at
the Federal level under existing categorical standards.
7-3
-------
- Discharge of Nonpriority RCRA Constituents to POTWs
EPA currently lacks the data necessary to estimate loadings of
nonpriority RCRA constituents from most industrial categories.
Still, the Industry Studies Data Base contains substantial non-
priority constituent data for the four organic chemicals industrial
categories. Based on ISDB, raw loadings to POTWs of nonpriority
hazardous constituents are estimated to be approximately 64,000
metric tons per year, of which only 736 metric tons constitute
nonpriority metals. This analysis indicates that the major
organics industries discharge approximately 2.5 kilograms of non-
priority constituents for each kilogram of priority constituents.
Information collected from a variety of data sources suggests that
nonpriority constituents also are discharged in significant quan-
tities by numerous other industries. Even if extensive loadings
information existed, there is a lack of technical data necessary to
determine fate and effects of these compounds. Before EPA can
effectively regulate any of these compounds, it will be necessary
to improve our knowledge of the sources, quantities, and impacts of
these constituents.
- Discharge of Solvents and Other Common Organics to POTWs
Certain priority organics, especially chlorinated solvents,
aromatic hydrocarbons, and phthalate esters, frequently are
detected in POTW influent wastewaters. Nonpriority organic
solvents, such as xylene, methyl ethyl ketone, acetone, ethyl
acetate, methanol, and others also are projected to be common
constituents of POTW wastewaters. The prevalence of these organic
compounds in POTW wastewater raises concerns about potential
effects on human health, the environment, and POTW operations when
discharged to sewers.
Solvents may be discharged by a broad range of industrial
categories. Consequently, any regulatory strategy to develop
and implement solvent controls must adequately reflect the number
and variety of possible sources of solvent wastes.
- Discharge of Wastes to POTWs by Small Quantity Generators
Data from the Small Quantity Generator Data Base demonstrate that
small quantity generators discharge wastes containing hazardous
constituents to POTWs. Data were not available to quantify
loadings of hazardous constituents in these wastes. Major SQG
sources include motor vehicle operations, service-related indus-
tries, wood refinishers, laundries, printing/publishing operations,
laboratories/hospitals, and construction firms. Major waste types
include spent solvents, ignitable waste, acid/alkaline wastes,
photographic wastes, formaldehyde wastes, and pesticide wastes.
Stringent regulation of SQG wastes under the RCRA program may
result in the increased discharge of these wastes to POTWs as an
alternative to land disposal and other restricted disposal methods.
Due to the large number of SQG facilities discharging to POTWs,
7-4
-------
implementation of pretreatment controls on the discharge of SQG
wastes may require the commitment of substantial programmatic
resources at the Federal, State, and POTW levels.
- Discharges By Hazardous Waste Management Facilities
Limited data exist on discharges to POTWs by the range of hazardous
waste management facilities. Sources include hazardous waste site
cleanups (e.g., CERCLA, State, local, and private cleanups), trans-
portation (e.g., tank/truck cleaning, drum/barrel reconditioning,
liquid waste haulers), waste reclamation (e.g., waste oil recy-
clers, solvent reclaimers, battery salvagers), and waste treatment
and disposal industries (e.g., landfills, surface impoundments,
centralized waste treatment facilities). Many of these new dis-
charge sources stem from hazardous waste cleanups under CERCLA and
parallel State statutes and from implementation of RCRA programs
requiring the development of waste management capacity necessary to
recycle, transport, treat, store, or dispose of hazardous wastes.
Data collected for the industry assessment demonstrate that these
facilities are discharging wastewaters to POTWs and, in some
instances, causing operational problems at POTWs.
- Spills/Slug Loads of Hazardous Waste to POTWs
Spills to sewage treatment plants do occur and may cause major
operational problems at these facilities. In the AMSA survey,
approximately 60 percent of POTW respondents indicated that they
received hazardous wastes as a result of spills to public sewers.
Also, over 50 percent reported receiving batch discharges of
hazardous waste from connected industries. As documented by POTW
incidents data, these discharges may be the cause of a variety of
POTW operational problems, including worker illness, actual or
threatened explosion, biological upset/inhibition, toxic fumes,
corrosion, and contamination of sludge and receiving waters.
Presently, Federal pretreatment regulations require slug load
notification by industries, but do not require POTWs or industries
to implement spill prevention and containment controls. Although
some POTWs have adopted storage and spill control measures, others
are poorly prepared to cope with spills and slug load discharges of
hazardous wastes from industries.
- Discharges by Liquid Waste Haulers to POTWs
Liquid waste haulers are also a source of hazardous waste
discharges to POTWs. Thirty-two percent of POTW respondents in
the AMSA survey reported receiving hazardous waste discharges from
septage haulers, while 23 percent of the respondents reported haz-
ardous waste discharges from other liquid waste haulers. Followup
discussions with AMSA respondents reporting the receipt of haz-
ardous wastes from these sources have indicated that none of these
POTWs actually receive RCRA-manifested hazardous wastes, but that
many of these POTWs are concerned about possible undetected dis-
charges by haulers of hazardous wastes mixed with septage wastes
7-5
-------
and other nonhazardous liquid wastes. Approximately 40 percent of
the AMSA respondents cited illegal discharges by midnight dumping
sources, some of which are likely to be liquid waste haulers dis-
charging surreptitiously to public sewers. Review of POTW and
industrial data confirms that liquid waste haulers, including
midnight dumpers, frequently utilize public sewers for waste
disposal.
Presently, Federal pretreatment standards regulate the discharge of
industrial wastes by liquid waste haulers. As indicated in the
AMSA Survey, some POTWs already have instituted local controls,
such as permits/agreements, manifesting requirements, designated
manholes, and sampling programs for discharges by liquid waste
haulers. Control of hazardous waste discharges by midnight dumpers
will rely heavily on the integrity of the RCRA manifest system and
efficacy of enforcement by Federal, State, and local officials.
Evaluation of the Fate and Effects of DSE Wastes
The analysis of the fate and effects of DSS pollutant discharges to
POTWs shows clearly that environmental degradation can occur as a
result of these discharges. However, quantitative estimates of these
effects are hampered by a lack of environmental criteria and a lack of
available data on these effects. There are four significant pollutant
fates within POTW treatment systems air-stripping, adsorption to
sludge, biodegradation, and pass through to receiving waters. An
estimated total annual loading of 92 million kilograms of hazardous
pollutants enter POTWs nationwide. While these loadings are impor-
tant, an analysis of effects on sludge and water quality shows that
the significant effects are associated with the toxicity and charac-
teristics of the specific pollutants and not just the quantities of
hazardous pollutants entering the environment. The following items
elucidate these overall conclusions:
- Pollutant Fate Uithin POTW Treatment Systems
Assuming a fully acclimated biological treatment system, EPA
estimates that 92 percent of all pollutants are removed by POTWs
from discharges to surface waters. Under this scenario, 14 percent
of all pollutants are air-stripped, 16 percent are removed to
sludge, 62 percent are biodegraded, while 8 percent pass through to
receiving waters. Assuming unacclimated POTW treatment, an
estimated 82 percent of all pollutants are removed by POTWs from
discharges to surface waters. Under this second scenario, 25
percent of all pollutants are air-stripped, 14 percent are removed
to sludge, 43 percent are biodegraded, while 18 percent pass
through to receiving waters. As indicated by these projections,
the degree of biological acclimation in POTW treatment units may
significantly affect overall POTW removal efficiencies, as well as
pollutant fate within treatment systems. Generally, as system
acclimation decreases, POTW removal efficiencies tend to decrease,
while pollutant quantities air-stripped tend to increase due to
7-6
-------
reductions in competing processes such as biodegradation. Without
additional information on wastewater discharge patterns and
biological acclimation rates, EPA cannot at this time determine
which treatment scenario is more representative of actual treatment
conditions at POTWs accepting industrial wastewater.
- Potential Water Quality Effects of POTW Dischargers
Water quality analyses conducted by EPA and two States predict that
POTW effluent discharges may have adverse water quality impacts.
The Chapter 5 dilution modeling analysis, comparing in-stream con-
centrations of POTW effluent to EPA water quality criteria, pro-
jects exceedances of water quality criteria for human health and
aquatic life. Moreover, bioassay studies conducted by EPA Region
V and the States of Florida and North Carolina document the toxic
and mutagenic properties of some POTW effluents containing indus-
trial wastewaters. The need for protection of drinking water
quality is underscored by an EPA analysis, which has identified a
total of 529 drinking water treatment facilities downstream of
pretreatment POTWs, and 130 facilities (25 percent of this total)
within 5 miles downstream of a pretreatment POTW outfall.
- Ambient Air Quality Effects of POTW Emissions
EPA estimates that between 12.9 and 23.2 million kilograms per year
of volatile pollutants are emitted by POTWs to ambient air. Ten
volatile pollutants are projected to account for over 90 percent of
total emissions. POTW emission of volatile organics has been
confirmed by EPA through ambient monitoring at Philadelphia and
other POTWs.
POTW VOC emissions appear to represent a small contribution
nationally to ozone formation in ambient air. While the signifi-
cance of this contribution is unknown, EPA currently is considering
controlling even small VOC sources in nonattainment areas. EPA has
identified 173 pretreatment POTWs located in ozone nonattainment
areas. POTWs also may emit significant quantities of air toxics as
a result of industrial discharges to POTWs. Nine of the 10 pol-
lutants estimated to be emitted in the largest quantities by POTWs
have been or are being considered by EPA for regulation as haz-
ardous pollutants under the Clean Air Act. Comprehensive evaluation
of health effects of these and other volatile pollutants is
hampered substantially by difficulties in measuring emissions for
POTWs, limited understanding of pollutant fate in ambient air, and
lack of human health criteria for exposures to toxics in the
ambient air environment.
- Environmental Effects of Sewage Sludge Disposal
The study indicates that between 14 and 16 percent of all DSS
constituents are removed to sewage sludge. Metal hazardous con-
stituents constitute 59 percent of this total. Based on Agency
technical work supporting the development of technical criteria
7-7
-------
under CWA §405, major pollutants of concern for landfil1 ing and
land application of sewage sludge include metals (e.g., arsenic,
cadmium, mercury, chromium, and nickel), PCBs, and chlorinated
pesticides. Because POTW sewage sludges rarely fail the EP
toxicity test for RCRA hazardous wastes, these sludges generally
are regulated under RCRA Subtitle D and CWA §405, as well as State
and local laws.
- Ground Water Contamination Due to Leaks from POTW Collection and
Treatment Systems
To date, there are few data indicating whether leaks from POTW
collection, treatment, and residuals disposal systems have caused
ground water contamination. As a result, conclusions on the extent
of ground water contamination due to POTW releases must await
further technical evaluation of POTW operational characteristics as
they relate to ground water. In response to Section 3018(c) of
HSWA of 1984, EPA currently is examining the effects of municipal
wastewater treatment lagoons on ground water. This study, however,
will not consider ground water impacts of other possible POTW
sources, such as exfiltration from collection systems.
Adequacy of Existing Government Controls on the Discharge of Hazardous
Wastes to Sewers
Substantial amounts of hazardous waste constituents have been
regulated and sufficient authorities exist under the CWA and RCRA to
control the known impacts associated with the discharge of hazardous
wastes to sewers. This finding supports retention of the DSE at the
present time, recognizing the logic of RCRA's reliance on the CWA's
pretreatment program for regulation of the discharge of aqueous
hazardous wastes to sewers. At the same time, deficiencies exist in
Federal pretreatment standards and weaknesses in local pretreatment
programs that could be improved, under existing authorities, to better
protect human health and the environment.
A basic lack of information on releases of hazardous waste to ground
water and air from POTWs requires that further study be undertaken
prior to completion of the assessment of the need for additional
regulatory controls. These potential impacts may require increased
reliance on RCRA and/or other statutes to fill gaps in protection
afforded by provisions of the CWA.
- Retention of the Domestic Sewage Exclusion
The DSE provides continuity between the regulatory controls imposed
by RCRA and the CWA. RCRA rules do not apply to hazardous wastes
upon "first entry" to the sewer system. Once hazardous wastes
enter the sewer system, CWA's pretreatment program becomes the sole
applicable control program. From a regulatory standpoint, CWA
authorities can work as an effective mechanism to control hazardous
waste discharges to sewer systems. On a practical level, however,
7-8
-------
CWA controls have not been employed to the extent possible to
regulate organic priority pollutants and nonpriority pollutants.
Nonetheless, sufficient latitude exists within the statutory
framework to develop regulations and guidance that can result in
more extensive control of these pollutants. RCRA authorities may
also afford a mechanism to provide additional pretreatment controls
on industrial users.
The Clean Water Act may not have sufficient authorities to take
actions to remediate potential air emission and ground water con-
tamination incidents which might be associated with the discharges
of these wastes to POTWs. Authorities under other statutes (e.g.,
RCRA, CAA, CERCLA) may be appropriate as corrective tools if these
incidents prove to warrant attention.
Effectiveness of Categorical Pretreatment
The implementation of categorical standards can result in
substantial reduction of pollutants discharged. The effectiveness
of the categorical pretreatment program has been restricted by:
(!) the industries regulated under the progran; and (2) the
pollutants covered by available standards. The findings of this
study demonstrate the need to consider the development of cate-
gorical standards for additional industries (e.g., paint and ink
formulation, printing and publishing, laundries, emerging hazardous
waste service industries such as solvent reclaimers). The findings
also demonstrate that currently promulgated, or soon to be promul-
gated, regulations for the metal finishing, pharmaceutical, and
organics industries do not specifically regulate nonpriority
organics, despite the fact that many of these pollutants are
discharged in significant concentrations and/or loadings.
Effectiveness of Local Pretreatment
Nearly 1,500 POTWs are required to develop and implement local
pretreatment programs under the General Pretreatment Regulations to
ensure the protection of POTW operations, the receiving environ-
ment, and worker health and safety. The general and specific
prohibition requirements of the regulations provide significant
latitude for POTWs to control the discharge of DSS pollutants.
However, due to a variety of factors, including a lack of infor-
mation on pollutant sources, technical guidance, and uneven program
implementation, including compliance activities, these requirements
have not worked to their fullest capacity to limit the discharge of
DSS pollutants. Improved technical guidance on the sources of DSS
pollutants, and available treatment mechanisms, can enhance POTW
control of these pollutants. In addition, an increased number of
environmental criteria and standards for surface water and sludges
can assist the POTW in designing appropriate local limits.
Administrative mechanisms available in Federally approved local
programs (e.g., industrial surveys, permitting, reporting require-
ments, inspections) should provide excellent vehicles for
7-9
-------
controlling hazardous waste discharges. POTWs are well-positioned
to assist with the regulation of SQGs. The effectiveness of the
existing program and implementation of additional controls for
hazardous wastes depend on additional Federal, State, and local
resources.
- Coordination of RCRA/CWA Activities
Several recent hazardous waste management developments should
affect the types, sources and amounts of hazardous wastes being
discharged to sewers. These include new restrictions on land
disposal, extension of RCRA requirements to more SQGs, the closing
of disposal facilities due to loss of interim status, and imple-
mentation of corrective action requirements. While only a small
percentage of hazardous wastes currently are discharged to sewers,
reductions in disposal capacity as a result of the above changes
potentially will cause an increase in the use of sewers for waste
disposal. The Office of Solid Waste and the Office of Water will
need to coordinate regulatory efforts to ensure that these
increases do not harm POTW operations, human health, or the
environment.
Coordination of future RCRA activities should include source
identification and waste listing/regulation. Coordination of
hazardous waste generator notification requirements under Section
3018(d) of RCRA is needed to ensure proper handling of information
collected from industries discharging hazardous waste to sewers.
7.3 RECOMMENDATIONS
The following four recommendations for improving control of discharges of
hazardous wastes to sewers have been derived from the findings of the Domestic
Sewage Study:
t Additional research, data collection, and analysis is necessary to
fill information gaps on sources and quantities of hazardous wastes,
their fate and effects in POTW systems and the environment, and the
design of any additional regulatory controls which might be necessary.
Improvements can be made to Federal categorical standards and local
pretreatment controls to enhance control of hazardous wastes
discharged to sewers.
EPA should emphasize the improvement of controls on hazardous wastes
through ongoing implementation of Water Programs. This will require
coordination with the water quality program, sludge management
program, and enforcement programs.
RCRA, CERCLA, and the CAA should be considered along with CWA to
control hazardous waste discharges and/or receiving POTWs if the
recommended research indicates the presence of problems.
7-10
-------
These recommendations are elucidated by the section below which provides
additional detail on areas potentially deserving attention under each recom-
mendation. Some items identified overlap others. Thus, choices will need to
be made before a final regulatory agenda is set to meet Section 3018(b) of the
RCRA amendments. Nonetheless, these lists present a broad range of additional
activities which EPA may consider as means for improving hazardous waste
controls. All recommendations are contingent upon Agency priorities and the
availability of resources at the Federal, State, and local levels.
Research and Data Collection and Analysis to Fill Informational Gaps
- Development and refinement of sampling/analytical protocols and
standards for nonpriority pollutants
- Evaluation of sources and control of RCRA solvents discharged to
POTWs
- Assessment of incidence and effects of midnight dumping into sewers
- Development and refinement of techniques for monitoring air
releases from POTWs, and collection of data on emissions of VOCs
and air toxics from POTWs
- Continuation of research on pollutant fate within POTW collection
and treatment systems, including examination of effects of bio-
logical acclimation on POTW removal efficiencies and pollutant fate
- Continuation of research on the effects (human health and
environment) of the discharge of hazardous constituents to POTWs
- Assessment of possible POTW sources of ground water contamination
including exfiltration from sewers and contamination due to
leachates from landfills handling sewage sludges
- Development of additional water quality and sludge criteria for
RCRA constituents, especially for nonpriority constituents
Improvement of Pretreatment Standards
- Inclusion of selected RCRA constituents on CWA priority pollutant
list or adoption of equivalent approach for regulation of these
constituents
- Modification of categorical standards for existing consent decree
industries to improve control of organic priority constituents and
nonpriority constituents
7-11
-------
Promulgation of categorical standards for industrial categories not
included in NRDC consent decree
Modification of prohibited discharge standards to improve control
of characteristic hazardous wastes and solvents
Emphasis on Ongoing Water Program Implementation Efforts
- Expansion of pretreatment controls on spills and batch discharges
of DSE wastes
- Implementation of RCRA Section 3018(d) notification requirements
for industries discharging hazardous wastes to POTWs
- Improvement of controls on discharges by liquid waste haulers,
including stronger enforcement against illegal discharges by
midnight dumpers
- Improvement/implementation of local limits at the POTW level on the
discharge of organics
- Stringent enforcement of existing PSES standards
- Expanded use of biomonitoring techniques and water quality-based
permitting to improve protection of receiving waters
- Continued development and implementation of technical criteria for
use/disposal of sewage sludge
Identification and Application of Other Environmental Controls
- Evaluation and implementation of VOC, NESHAPS and State air toxics
controls for POTWs emissions including consideration of controls on
industrial discharges which result in POTW emissions.
- Evaluation of alternative regulatory control programs {RCRA,
CERCLA, CWA, and CAA) applied to POTWs if further studies and
analysis show need for additional controls.
7-12
-------
LIST OF REFERENCES
-------
-------
CHAPTER 1
LIST OF REFERENCES
1. Congressional Record, H 9150, daily edition: November 3, 1983.
-1-
-------
CHAPTER 2
LIST OF REFERENCES
1. U.S. Congress, House of Representatives, Hearings before the Subcommittee
on Investigations and Review of the Committee on Public Works and
Transportation. Committee Print Number 95-32, pages 399-405.
2. U.S. Environmental Protection Agency, Office of Water Regulations and
Standards, Paragraph 4fc) Program, Summary Report. Washington, DC:
January 1984.
3. Based on types of data sources and other considerations, the DSS
industrial categories were divided into "organics industries" and
"nonorganics industries." Organics industries include the organic
chemicals, dye/pigments, petroleum refining, rubber, and pesticide
industries. Nonorganic industries include all remaining industrial
categories. See Chapter 3 for a complete discussion of the DSS
industry classification scheme.
-2-
-------
1.
2.
3.
4.
5.
6.
7.
8.
9.
CHAPTER 3
LIST OF REFERENCES
U.S. International Trade Commission, Synthetic Organic Chemicals: United
States Production and Sales. Washington, DC:U.S. Government Printing
Office, 1981, 1982, 1983.
Resource Conservation and Recovery Act, PL 96-463, October 15, 1980, 42
USC 6901.
Hazardous and Solid Waste Amendments of 1984, PL 98-616, November 8,
1984, 42 USC 6901 et. seq.
Abt Associates, Inc., National Small Quantity Hazardous Waste Generator
Survey. Prepared for the U.S. Environmental Protection Agency, Office
of Solid Waste, February 1985.
U.S. Environmental Protection Agency, Office of Solid Waste, National
Small Quantity Hazardous Waste Generator Survey Data Base.
, Office of Water Regulations and Standards, Paragraph 4(c)
program. Summary Report. Washington, DC: U.S. Environmental
protection Agency, January 1984.
E.C. Jordan Co., EPA Food Industry Group Pretreatment Standards
Evaluation for Tfte Pharmaceutical Manufacturing category.Prepared for
the U.S. Environmental Protection Agency, Effluent Guidelines Division,
August 1983.
U.S. Environmental protection Agency, Effluent Guidelines Division,
Development Document for Final Effluent Limitations Guidelines, New
Source Performance Standards and Pretreatment Standards for the
Pharmaceutical Manufacturing Point Source Category. September 1983.
, Effluent Guidelines Division, proposed Development Document
for Effluent Limitations Guidelines and Standards for the Metal
Finishing Point Source Category. EPA-440/l-82/091-b. August 1982.
10. Standard Research Institute, Chemical Economic Handbook. 1984.
11. Luh, Mike, Baltimore Department of Public Works, Memorandum to
Doug Murtland, SAIC. September 25, 1985.
12. Dun*s Marketing Service, Standard Industrial Classification Statistics.
1984.
13. U.S. Environmental protection Agency, Effluent Guidelines Division,
Development Document for Effluent Limitations Guidelines for New Source
Performance Standards for the Basic Fertilizer Chemicals Segment of the
Fertilizer Manufacturing Point Source Category.NTIS PB-238 652.
March 1974.
-3-
-------
14. Goldstein, Ken, New Jersey Department of Environmental protection, Data
submitted to SAIC. August 1985.
15. U.S. Environmental Protection Agency, Office of Public Affairs, EPA
Journal , Vol. 11, Number 7, September 1985.
16. _ , Emergency and Remedial Response Information System.
17. Taft, James, Memorandum to Martha Prothro, Director, Permits Division.
Subject: An Assessment of the Number of POTWs Covered by a RCRA Permit
By Rule. September 12, 1985.
18. U.S. Environmental Protection Agency, Summary Report: Remedial Response
at Hazardous Waste Sites. 1984.
19. _ , Office of Solid Waste, Hazardous Waste Damage Incident Data
Base,
, Effluent Guidelines Division, Development Document for
Effluent Limitations Guidelines and New Source Performance Standards
for the Soap and Detergent Manufacturing Point Source Category. NTTS
PB-238 613. April 1974.
21- , Effluent Guidelines Division, Development Document for
Effluent Limitations Guidelines and New "Source Performance Standards
for the Textile, Friction Materials and Sealing Devices Segment of the
Asbestos Manufacturing Point Source Category! NTIS PB-240 860.
December 1974.
22. JRB Associates, Investigation of New Industries. Prepared for U.S.
Environmental Protection Agency, Office of Analysis and Evaluation,
October 19, 1984.
23. U.S. Environmental protection Agency, Source Assessment: Rail Tank Car,
Tank Truck, and Drum Cleaning, State of the Art. 1978.
24. Arthur D. Little, Draft Economic Impact Analysis of Subtitle C; Resource
Conservation and Recovery Act of 1976. October 19, 1984.
25. Phi 1 adel phia Inqui rer , "Despite Tougher Laws, Waste Haulers Find
Loopholes," Sunday, November 27, 1983.
26. Kelleher, Joe, New York State Department of Environmental Protection,
Data submitted to SAIC. September 1985.
27. Southern California Hazardous Waste Management Project, Hazardous Waste
Generation and Facility Development Needs in Southern California, ~~
Revised Draft. February 1983.
28. JRB Associates, Evaluation of RCRA Subtitle D Facilities. Draft.
Prepared for the U.S. Congress, Office of Technology Assessment,
January 20, 1984.
-4-
-------
29. U.S. Environmental protection Agency, Fate of Priority Pollutants in
Publicly Owned Treatment Works. Volumes I and II. EPA-440/1-82-303,
September 1982.
30. , Office of Water program Operations, NEEDS Survey Report to
Congress, User's Manual. EPA-430/9-84-011. 1984.
31. , Sources of Toxic Pollutants Found in Influents to Sewage
Treatment plants.Volumes III and VI.June 1979.
-5-
-------
CHAPTER 3
ADDITIONAL REFERENCES
U.S. Environmental protection Agency, Addendum: Assessment of the Impacts of
industrial Discharges on Publicly Owned Treatment Works. February 25, 1983
__ _ , Development Document for Effluent Limitations Guidelines and New
Source Performance standards Beet Sugar Processing Subcategory of the Sug₯r
Processing point Source Category. NTIS PB-238 462. January 1974.
_ , Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Dairy Product Processing point Source
Category. NTIS PB-238 835. May 1974.
_ , Proposed Development Document for Effluent Limitations Guidelines
and Standards for the Paint Formulating Point Source Catego"ry^ ~~
EPA-440/l-79-049-b. December 1979.
_ , Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Grain Processing Segment of the Grain
Mills Point Source Category. NTIS PB-238 316. March 1974.
_ , Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Building, Construction and PapeT
Segment of the Asbestos Manufacturing Point Source Category. NTIS PB-238
February 1974.
, Final Development Document for Effluent Limitations Guidelines and
Standards for the Aluminum Forming Point Source Category.Volumes I and II.
EPA-440/1-84-073. June 1984.
, Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Renderer Segment of the Meat products
and Rendering Processing Point Source Category.NTIS PB-253 572.
January 1975.
__ , Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Apple, Citrus and potato Processing
Segment of the Canned and Preserved Fruits and Vegetables Point Source"
Category. NTIS PB-238 649. March 1974.
, Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Fish Heal, Salmon, Bottom Fish, Clam,
Oyster, Sardine, scallop, Herring, and ADaione Segment of tne Canned and
Preserved Fish and Seafood Processing Industry Point Source Category. NTIS
PB-256 840.September 1975.
, Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Builders Paper and Roofing Felt Segment
of the Builders Paper and Board Mills Point Source Category"NTIS PB-238
076. May 1974.
-6-
-------
Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Synthetic Resins Segment of the
Plastics and Synthetic Materials Manufacturing Point Source Category.
PB-239 241.March 1974.
NTIS
, Proposed Development Document for Effluent Limitations Guidelines
and standards tor the Metal Molding and Casting (Foundries) Point source
Category.Volumes I and II.EPA-440/l-82-070-b.November 1982.
, proposed Development Document for Effluent Limitations Guidelines
and Standards for the Ink Formulating Point Source Category,
EPA-440/l-79-090-b.December 1979."
, Development Document for Expanded Best practicable Control
Technology, Best Conventional Pollutant Control Technology, Best Available
Technology, New Source Performance Technology, and Pretreatment Technology,
in the Pesticide Chemicals Industry^EPA-440/l-82-079-b; NTIS PB-83-153
171. November 1982.
, Draft Development Document for Effluent Guidelines and Standards
for the Auto and Other Laundries Point Source Category. October 1980.
, Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category.
Phase II; Secondary Mercury Supplement.July 1984.
, Final Development Document for Effluent Limitations Guidelines New
Source Performance Standards and Pretreatment Standards tor the Petroleum
Refining point Source Category. NTIS PB-83-172569. October 1982.
, Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category.
Metallurgical Acid Plants Supplement.May 1984.
. Development Document for Effluent Limitations Guidelines and
Standard's for the Nonferrous Metals Manufacturing Point Source Category.
Secondary Lead Supplement.May 1984.
Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category.
Primary Columbium - Tantalum Supplement.May 1984.
, Development Document for Effluent Limitations Guidelines and
Standard's for the Nonferrous Metals Manufacturing Point Source Category.
Primary Copper Supplement.May 1984.
, Development Document for Effluent Limitations Guidelines and
Standards for the Pharmaceutical Point Source Category.EPA-440/1-82-084.
November 1982.
, Development Document for Effluent Limitations Guidelines and
Standard's for the Nonferrous Metals Manufacturing Point Source Category.
Primary Antimony Supplement,July 1984.
-7-
-------
, Development Document for Effluent Limitations Guidelines and
Standards for the Timber Products Point Source Category. EPA-440/1-81-023,
January 1981.
, Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category.
May 1984.
, Development Document for Effluent Limitations Guidelines for the
Electrical and Electronic Components point Source Category.Phase 2.
December 1983.
, Development Document for Effluent Limitations Guidelines and
Standards for the Petroleum Refining Point Source Category.
EPA-440/l-79-014-b. December 1979.
, Development Document for Effluent Limitations Guidelines and
Standard's for the Pulp, Paper, and Paperfaoard and the Builders' Paper and
Board Mills Point Source Category.EPA-440/1-82-025.October 1982.
, Development Document for Effluent Limitations Guidelines and
Standards for the Copper Forming.EPA-440/1-84-074.March 1984.
, Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category.
Phase II; Secondary Uranium Supplement. July 1984.
, Development Document for Effluent Limitations Guidelines and
Standards for Battery Manufacturing Point Source Category.Volumes I and
TT.EPA-440/1-84-067. August 1984.
, Development Document for Effluent Limitations Guidelines for the
Electrical and Electronic Components Point Source Category, phase I.
April 21, 1983.
, Development Document for Effluent Limitations Guidelines and
Standard's for the Porcelain Enameling Point Source Category.
EPA-440/1-82-072. November 1982.
, Development Document for Effluent Limitations Guidelines and
Standards for the Leather Tanning and Finishing Point Source Category.
EPA-440/1-79-016. July 1979.
, Development Document for Effluent Limitations Guidelines and
Standards for the Leather Tanning and Finishing Point Source Category.
EPA-440/1-82-016.November 1982.
, Development Document for Effluent Limitations Guidelines and
Standard's for the Nonferrous Metals Manufacturing Point Source Category.
Secondary Aluminum Supplement. May 1984.
-------
, Development Document for Effluent Limitations Guidelines and
Standards for the Electroplating Point Source Category. EPA-440/1-79-003.
August 1979.
_ , Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category.
Primary Aluminum Supplement. May 1984* ~~ "
» Development Document for Effluent Limitations guidelines and
Standard's for the Nonferrous Metals Manufacturing Point Source Category.
Primary Lead Supplement. May 1984. '
, Development Document for Effluent Limitations Guidelines and
Standard's for the Nonferrous Metals Manufacturing Point Source Category.
Primary Tungsten Supplement. May 1984.
, Development Document for Effluent Limitations Guidelines and
Standard's for the Gum and Wood Chemicals Manufacturing Point Source"
Category. EPA-440/1-79-078-D. December 1979.
_ , Development Document for Effluent Limitations Guidelines and
Standards for the Foundries (Metal Molding and Casting) Point Source"
Category. EPA-440/l-80-070-a. April 1980.
_ , Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category.
Primary Precious Metals and Mercury Supplement. July 1984.
Development Document for Effluent Limitations Guidelines and
Standards for the Inorganic Chemicals Manufacturing Point Source Category,
EPA-440/l-80-007-b.June 1980.
, Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing point Source Category.
Phase II; Bauxite Refining Supplement.July 1984.
, Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category.
Phase II; primary and Secondary Titanium Supplement.July 1984.
, Development Document for Effluent Limitations Guidelines and
Standard's for the Nonferrpus Metals Manufacturing Point Source Category.
Phase II; Secondary Nickel Supplement.July 1984.
, Development Document for Effluent Limitations Guidelines and
Standards for the Photographic Equipment and Supplies Segment of the
Photographic Point Source Category. EPA-440/l-80-077-a. May 1980.
_, Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category.
Primary Zinc Supplement,May 1984.
-9-
-------
Development Document for Interim Final Effluent Limitations
Guidelines and Proposed New Source performance Standards for the Explosives
Manufacturing Point Source Category.tPA-440/l-76-060-j~.March 1976.
, Development Document for Proposed Effluent Limitations Guidelines
and Standards for the Shipbuilding and Repair Point Source Category.
EPA-440/l-79-076-b.December 1979.
Dun's Marketing Service, Standard Industrial Classification Statistics. 1984.
E.G. Jordan Co, Priority Pollutants in Publicly Owned Treatment Works -
Summary Report. Draft. Prepared for U.S. Environmental protection Agency,
industrial lecnnology Division, April 1985.
U.S. Environmental Protection Agency, Fate of Priority Pollutants In publicly
Owned Treatment Works. Interim RepoTTI tPA-440/1-80-301. wasmngton, DC:
U.S. Environmental protection Agency, October 1980.
Federal Register, Vol. 50, No. 137, p. 29068, July 17, 1985. Proposed Rule:
Organic Chemicals and plastics and Synthetic Fibers; Point Source Category
Effluent Limitations Guidelines pretreatment Standards; and Standards of
Performance for New Sources.
Federal Register, Vol. 49, No. 247, p. 49784, December 21, 1984. Proposed
Rule: Hazardous Waste Management System; Identification and Listing of
Hazardous Waste.
Franklin Associates, Industrial Resource Recovery Practices Petroleum
Refineries and Related Industries (SIC 29).Final Report.Prepared for
U.S. Environmental Protection Agency, Office of Solid Waste, January 1983.
U.S. Environmental Protection Agency, Guideline Documentation for the Control
of Water Pollution in the photographic Processing Industry.
EPA-440/1-81-082-9. April 1981.
JRB Associates, Industrial Resource Recovery practices: Leather and Leather
Products (SIC 31).Prepared for U.S. Environmental Protection Agency,
Office of Solid Waste and Emergency Response, February 1982.
Franklin Associates, Industrial Resource Recovery practices: petroleum
Refineries and Related Industries (SIC 29). Draft Final Report. Prepared
for U.S. Environmental Protection Agency, Office of Solid Waste, June 15,
1982.
, Industrial Resource Recovery Practices: Textile Mill Products
Industries (SIC 22). Draft Final Report, prepared for U.S. Environmental
protection Agency, Office of Solid Waste, June 1982.
Goldstein, Ken, New Jersey Department of Natural Resources, Industry Studies -
Small Generator Studies. Prepared for Joe Kelleher or Max Goldman, N.Y.
State Department of Environmental Conservation.
-10-
-------
JRB Associates, 308 Questionnaire Data Base for the Establishment of Effluent
Guidelines for the Organic Chemicals, Plastics and Synthetic Fibers
Industrial Point Source Category. Prepared for U.S. Environmental
protection Agency, Effluent Guidelines Division, Office of Water Regulations
and Standards, 1983.
JRB Associates, Industrial Technology Division pesticides Data Base. Prepared
for U.S. Environmental protection Agency, Office of Water Regulations and
Standards, 1985.
JRB Associates, Industry Studies Data Base. Prepared for U.S. Environmental
Protection Agency, Office of Solid Waste, Waste Identification Branch, 1985.
JRB Associates, JRB Hazard Classification System for Waste Constituents.
Prepared for U.S. Environmental Protection Agency, Office of Solid Waste,
January 22, 1985.
Abt Associates, National Small Quantity Hazardous Waste Generator Survey.
Prepared for U.S. Environmental Protection Agency, Office of Solid Waste,
February 1985.
U.S. Environmental protection Agency, Office of Air Quality Planning and
Standards, Organic Solvent Cleaner Background Information for Proposed
Standards. EPA-450/2-78-045a. October 1979.
Pope-Reid Associates, Inc., Assessment of the Fate of SQG Hazardous Wastes in
POTWs. Draft Final Report, prepared for U.S. Environmental Protection
Ayency, Office of Policy Analysis, July 1985.
PEI Associates, Inc., primary Lead Smelting and Refining Industry. Prepared
for U.S. Environmental Protection Agency, Office or Research and
Development, Industrial Environmental Research Laboratory, Cincinnati, Ohio,
November 1984.
U.S. Environmental protection Agency, Region II, Technical Assistance to
Gloversville Johnstown, and Fulton County, NY in the Analysis of
Alternatives for Tannery and Other Industrial Waste Management. Technical
Assistance Panels program Report. Contract No. 68-01-4893 and 68-01-6002.
Office of Management and Budget, Statistical Policy Division, Standard
Industrial Classification Manual. 1972.
U.S. Environmental Protection Agency, Effluent Guidelines Division, Summary of
Available Information on the Levels and Control of Toxic Pollutants
Discharges in the Printing and Publishing Point Source Category.
EPA-440/1-83/400.October 1983.
, Supplement for Pretreatment to the Development Document for the
Inorganic Chemicals Manufacture Point Source Category.EPA-440/1-77/087A.
July 1977.
Camp Dresser and McKee Inc., The Wastewater Treatment Exemption, prepared for
the U.S. Environmental Protection Agency, Waste Management and Economics
Division, September 30, 1984.
-11-
-------
U.S. Environmental Protection Agency, Treatabillty Studies for the Inorganic
Chemicals Manufacture Point Source Category.EPA-440/1-80/103.July 1980.
, Office of Solid Waste, Hazardous Waste Data Management System.
, Office of Water Regulations and Standards, Monitoring Data Support
Division Data Base.
, Office of Solid Waste, National Survey of Hazardous Waste
Generators and Treatment, Storage and Disposal Facilities (RIA Data Base).
, Office of Water Regulations and Standards, Paragraph 4C Data Base.
, Office of Water Regulations and Standards, Summary of Effluent
Characteristics and Guidelines for Selected Industrial Point Source
CategoriesIndustry status Sheets:Volumes I and II.August 5, 1983
(Revised July 26, 1984).
Denit, Jeffrey, Director, Effluent Guidelines Division, Memo. Subject:
Summary of the Effluent Guidelines Division Rulemakings Activities.
September 1, 1984.
U.S. Environmental protection Agency, Office of Solid Waste, National Survey
of Hazardous Waste Generators and Treatment, Storage, and Disposal
Facilities Regulated Under RCRA In 1981.EPA-530/SW-84-005.ffprT] 1984.
, Final Development Document for Effluent Limitations Guidelines and
Standards for the Metal Finishing Point Source Category.EPA-440/1-83/091.
June 1983.
, Final Development Document for Effluent Limitations Guidelines and
Standards for the Iron and Steel Manufacturing point Source Category^
Volumes I, II, III, IV, V, and VI.EPA-440/1-83/091. June 1983.
, Final Development Document for Effluent Limitations Guidelines and
Standards for the Coil Coating Point Source Category.EPA-440/1-82/071.
October 1982.
Municipality of Metropolitan Seattle, Toxicant Pretreatment Planning Study,
Water Quality Division. October 1984.
, Proposed Development Document for Effluent Limitations Guidelines
and Standards for the Plastics Molding and Forming point Source Category.
EPA-440/l-84/069-b. February 1984.
-12-
-------
CHAPTER 4
LIST OF REFERENCES
1. Bishop, D.F., Memorandum to T.P. O'Farrell. Subject: Estimation of
Removability and Impact of Priority 1 RCRA Toxics. May 22, 1985.
2- , Memorandum to T.P. O'Farrell. Subject: Volatile Emissions
or RCRA priority 1 Organics in Sewers. June 3, 1985.
3. , Memorandum to T.P. O'Farrell. Subject: Follow-up
Estimations of Removability and Impact of Priority 1, 2* 3 and Tier 2A
RCRA Toxics. September 13, 1985.
, Memorandum to T.P. O'Farrell. Subject: Estimation of
Removability and Impact of RCRA Toxics. September 26, 1985.
5. Dixon, Gina and Bremen, Bill (Versar), Memorandum to Forest Reinhardt.
Subject: Technical Background and Estimation Methods for Assessing A1r
Releases from Sewage Treatment Plants. October 11, 1984.
6. Petrasek, A.C., et. al., "Removal and Partitioning of Volatile Organic
Priority pollutants in Wastewater Treatment," presented at the Ninth
U.S.-Japan Conference on Sewage Treatment Technology, Tokyo, Japan,
September 1983.
7. Strier, Murray P., Memorandum to the Record. Subject: Response to
Comments from Chemical Manufacturers Association (CMA) of August 17,
1983 to Proposed Effluent Limitations for the Organic Chemicals and
Plastics and Synthetic Fibers Category (FR Vol. 48, No. 55, March 21,
1983). May 17, 1985.
8. __ , Memorandum to the Record. Subject: Significant
Consequences of Telephone Conversation with Or. Kincannon of Oklahoma
State University Regarding his Bench-Scale Activated Sludge Reactor
Studies. May 7, 1985.
9. E.G. Jordan Co., Priority Pollutants in Publicly Owned Treatment Morks -
Summary Report.prepared tor U.S. Environmental protection Agency,
January 1984.
10. DeWalle, F.B., et. al., Presence of priority Pollutants in Sewage and
Their Removal in Sewage Treatment plants. Prepared for the U.S.
Environmental Protection Agency.
11. Weber, W.W. and Jones, B.E., Toxic Substances Removal in Activated Sludge
and PAC Treatment Systems. Draft Report.Cincinnati, Ohio:Water
Engineering Research Laboratory, U.S. Environmental Protection Agency,
1985.
12. Unpublished EPA/WERL research project performed at Purdue University..
-13-
-------
13. Petrasek, A.C., and Kugelman, I.J., "Metals Removal and Partitioning in
Conventional Wastewater Treatment Plants," Journal of the Water
Pollution Control Federation, Vol. 55, p. 1183 (1983").
14. Berglund, R.L., Whipple, G.M., Hansen, O.L., Alsop, G.M., Siegrist, T.W.,
Wilker, B.E., and Dempsey, C.R. "Fate of Low Solubility Chemicals in a
petroleum Chemical Wastewater Treatment Facility." Presented at the
National Meeting of AICHE, August 1985.
15. Lucas, A.P., Health Hazard Evaluation Report No. HETA 81-207-945,
Metropolitan Sewer District, Cincinnati, Ohio. Cincinnati, Ohio:
National Institute for Occupational Safety and Health, 1981.
-14-
-------
CHAPTER 4
ADDITIONAL REFERENCES
Bishop, Dolloff F., Role of Municipal Wastewater Treatment In Control of
Toxics. EPA-6009/D-82-360; NTIS PB-152447.September 1982.
Environ Corporation, "Characterization of Constituents from Selected Waste
Streams" (listed in 40 CFR 261). Washington, DC: U.S. Environmental
Protection Agency, August 3, 1984.
Geating, John, Literature Study of the Biodegradability of Chemicals in Water.
Vol. I. EPA-600/22-81-175/176; NTIS PB 82-100843. Cincinnati, Ohio:
Municipal Environmental Research Laboratory, U.S. Environmental Protection
Agency, October 1981.
Hannah, Sidney A., et al. "Comparative Removal of Toxic Pollutants by Six
Wastewater Treatment processes." Cincinnati, Ohio: Water Engineering
Research Laboratory, U.S. Environmental Protection Agency, April 1985.
Kieslich, Klaus, Microblal Transformations of Non-Steroid Cyclic Compounds.
Germany: John Wiley & Sons, Thieme Publishing, 1976.
Kirsch, E.J., et al., Fate of Eight Organic Priority Pollutants in Biological
Waste Treatment. Draft Report. Cincinnati, Ohio: Water Engineering
Research Laboratory, U.S. Environmental Protection Agency, 1985.
Booz Allen & Hamilton, Sludge Management project Model Risk Analysis Exercise,
Municipal Sludge Generation and Distribution: Nationwide Estimates.
Prepared for U.S. Environmental protection Agency Sludge Task Force, January
18, 1983.
Blankenship, Eric (JRB Associates), Memorandum to Paul Storch. Subject: POTW
Pollutant Removal. September 8, 1981.
Camp Dresser & McKee, A Comparison of Studies of Toxic Substances in POTW
Sludge. Prepared for U.S. Environmental protection Agency, August 1984.
U.S. Environmental Protection Agency, Interim Report of the EPA Sludge Task
Force. Washington, DC: U.S. Environmental Protection Agency, August 1983.
, Development Document for Proposed Effluent Limitations Guidelines
and New Performance Standards for the Organic Chemicals andTplastics and
Synthetic Fibers Industry.February 1983.
Strier, Murray P., Memorandum to the Record. Subject: Evidence that Air
Stripping Rates of Toluene Exceeds it Biological Oxidation Rates in Aeration
Basins from Three Independent References. May 24, 1985.
U.S. Environmental Protection Agency, Office of Water program Operations,
State and Local Pretreatment programs. Vol. I. EPA-430/9-76-017.
Washington, DC: U.S. Environmental Protection Agency, January 1977.
-15-
-------
, 304(g) Guidance Document; Revised Pretreatment Guidelines. Vol.
I. Washington, DC: U.S. Environmental protection Agency, October 1981.
Tabak, H.H., et al., "Biodegradation Studies for Predicting the Environmental
Fate of Organic Priority Pollutants," in proceedings of the AOAC Symposium.
94th AOAC Meeting, 1980.
Versar, Inc., Physical-Chemical Properties and Categorization of RCRA Wastes
According to Volatility. Draft Report. Cincinnati, Ohio: Industrial
tnvironmentai xesearcn Laboratory, U.S. Environmental protection Agency,
April 30, 1984.
VanZile, L. and Long, D.» "Computer Management of Industrial Wastes,"
Operations Forum, Vol. 2, No. 7, July 1985.
Booz Allen & Hamilton, Description and Comparison of Municipal Sewage Sludge
generation and Disposal Data Bases"Prepared for the U.S. Environmental
Protection Agency, July 26, 1982.
Time, Henry and Leblanc, Pauline, Permits Division, Region V, Memorandum to
Glenn Pratt, Chief, Permits Section, Region V, U.S. Environmental protection
Agency. August 17, 1984.
Williams, John, Site Director, Philadelphia Integrated Environmental
Management Project, Memorandum to Richard Kinch, Executive Director,
Pretreatment Implementation Review Task Force, July 30, 1984.
Haggert, B. and Harkov, Ron, Office of Science & Research, New Jersey
Department of Environmental protection, Untitled Report.
Pratt, Glenn, Chief, Permits Section, Region V, Memorandum to Joseph paisie,
Chief, Technical Analysis Section, ARB, U.S. Environmental protection
Agency. August 29, 1984.
National Fire Protection Association, Fire Hazard Properties of Flammable
liquids, Gases and Volatile Solids, 1984. NFPA 325M-1984.
-16-
-------
CHAPTER 5
LIST OF REFERENCES
1.
2.
3.
4.
5.
6.
7.
8.
9.
U.S. Environmental Protection Agency, Effluent Guidelines Division, Fates
of Priority Pollutants in Publicly Owned Treatment Works. Final
Report.EPA-440/1-80-303.Washington, DC:U.S. Environmental
protection Agency, September 1982.
, Addendum: Assessment of Impacts of Industrial Discharges on
Publicly Owned Treatment Works. February 25, 1983.
Science Applications International Corporation, AMSA Survey Results.
Prepared for the U.S. Environmental Protection Agency, Office of Water
Regulations and Standards, August 1985.
Olson, C.R. and Shaeffer, D., Mutagenicity Testing of Industrial and
Municipal Effluents by the Illinois Environmental Protection Agency.
Springfield, IL:Illinois Environmental Protection Agency, 1983.
Henry, Timothy, Permits Section, Region V, Personal Correspondence.
August 22, 1985.
Tedder, Steve W., Head, Technical Services Branch, State of North
Carolina, Department of Natural Resources and Community Development,
Personal Correspondence. August 13, 1985.
State of Florida, Department of Environmental Regulation, Bioassay
Testing Program, June 1979-September 1982. April 1983 and October 14,
1983.'
U.S. Environmental Protection Agency, Office of Air Quality Planning :and
Standards, Emissions Data and Model Review for Wastewater Treatment
Operation. Draft Technical Note.August 1985.!:
, Office of Policy, Planning and Evaluation (IEMD), Evaluation
of the Performance of the Dispersion Model SHORTZ for Predicting
Concentrations of Air Toxics in the U.S. Environmental protection
Agency's Philadelphia Geographic StuBy!Draft Report.February 8,
1985.
10. Versar, Inc. and American Management Systems, Hazardous Air Pollutants:
A Preliminary Exposure and Risk Assessment for 35 U.S. Counties.
September 1984.
11. U.S. Environmental Protection Agency, Cost and Benefits of Reducing Lead
in Gasoline. Final Regulatory Impact Analysis.EPA 230-05-85-006.
February 1985.
12. Industrial Economics, Inc., Cost-Effectiveness Analysis of Strategies to
Reduce Human Health Risk in Philadelphia.May 1985.
-17-
-------
13.
14.
15.
16.
U.S. Environmental Protection Agency, Office of Water, Volatilization of
Organic Compounds from Municipal Sewage Treatment Plants, Overview of~
IEMD Findings.Briefing Paper.September 1985.
, Office of Ground Water Protection, Overview of State Ground
Water Programs Summaries. Vol. I. March 1985.
, Office of Water Program Operations, NEEDS Survey Report to
Congress, User's Manual. EPA-430/9-84-011. 1984.
, Office of Water Regulations and Standards/Wastewater Solids
Criteria Branch, Summary of Environmental profiles and Hazard Indices
for Constituents or Municipal Sludge.July 1985.
-18-
-------
CHAPTER 6
LIST OF REFERENCES
1. Meddle, Bruce, Memo to OSW Senior Staff.
RCRA Activities. July 1985.
Subject: Summary Report on
2. Levy, Steve, permits and State Programs Division, Office of Solid Waste,
U.S. Environmental Protection Agency, Personal Correspondence.
3. Science Applications International Corporation, AMSA Survey Results.
prepared for the U.S. Environmental Protection Agency, Office of Water
Regulations and Standards, August 1985.
4. U.S. Environmental Protection Agency, Office of Solid Waste, Permits and
State Programs Division, Authorization of State Hazardous Waste
programs. September 1985.
5. Hall, Ridgeway, M., et al., Hazardous Waste Handbook. 5th Edition.
Government Institutes, October 1984.
6. Hanmer, Rebecca, Director, Office of Water Enforcement and Permits,
Memorandum to Regional Water Management Division Directors and NPDES
State Directors. Subject: Local Limits Requirements for POTW
Pretreatment Programs. August 5, 1985.
7. Notzon, Ned, Director, Monitoring and Data Support Division, Memo to Ed
Conlon, Acting Director, Office of Water Regulations and Standards.
Subject: Regions and States Use of Bioassays. September 1985.
8. JRB Associates, Draft Summary of Pretreatment Audit Reports, prepared
for the U.S. Environmental Protection Agency, Office of Water
Enforcement and permits, December 1984.
9. U.S. Environmental Protection Agency, Office of Water Enforcement and
Permits, Pretreatment Implementation Review Task Force Final Report to
the Administrator.January 30, 1985.
GOVERNMENT PRINTING OFFICB 1986-i*91--191-ij6115
-19-
-------
-------
-------
-------
-------
&EPA
United States
Environmental Protection
Agency \r{\ 552
Washington, DC 20460
Official Business
Penalty for Private Use
$300
------- |