United States
Environmental Protection
Agency
Office of Water
(4303)
EPA821-B-97-011
January 1998
Development Document
for Proposed Effluent
Limitations Guidelines and
Standards for Industrial
Waste Combustors
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DEVELOPMENT DOCUMENT
FOR
PROPOSED EFFLUENT LIMITATIONS
GUIDELINES AND STANDARDS
FOR THE
INDUSTRIAL WASTE COMBUSTOR SUBCATEGORY
OF THE
WASTE COMBUSTORS POINT SOURCE CATEGORY
Carol M. Browner
Administrator
Robert Perciasepe
Assistant Administrator, Office of Water
Sheila Frace
Acting Director, Engineering and Analysis Division
Elwood H. Forsht
Chief, Chemicals and Metals Branch
Samantha Hopkins
Project Manager
December 1997
U.S. Environmental Protection Agency
Office of Water
Washington, DC 20460
Additional Support by Contract No. 68-C5-0041
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ES-1
SECTION I STATUTORY REQUIREMENT 1-1
1.1 LEGAL AUTHORITY 1-1
1.1.1 Best Practicable Control Technology Currently Available (BPT)
(Section 304(b)(l) of the CWA) 1-1
1.1.2 Best Conventional Pollutant Control Technology (BCT)
(Section 304(a)(4) of the CWA) 1-2
1.1.3 Best Available Technology Economically Achievable (BAT)
(Sections 304(b)(2)(B) of the CWA) 1-2
1.1.4 New Source Performance Standards (NSPS)
(Section 306 of the CWA) 1-3
1.1.5 Pretreatment Standards for Existing Sources (PSES)
(Section 307(b) of the CWA) 1-3
1.1.6 Pretreatment Standards for New Sources (PSNS)
(Section 307(b) of the CWA) 1-4
1.2 SECTION 304(M) REQUIREMENTS AND LITIGATION 1-4
SECTION 2 DATA COLLECTION 2-1
2.1 CLEAN WATER ACT SECTION 308 QUESTIONNAIRES AND
SCREENER SURVEYS 2-2
2.1.1 Development of Questionnaires and Screener Surveys 2-2
2.1.2 Distribution of Screener Surveys and Questionnaires 2-4
2.2 SAMPLING PROGRAM 2-5
2.2.1 Pre-1989 Sampling Program 2-5
2.2.2 1993 - 1995 Sampling Program 2-6
2.2.2.1 Facility Selection 2-6
2.2.2.2 5-Day Sampling Episodes 2-7
SECTION 3 DESCRIPTION OF THE INDUSTRY 3-1
3.1 GENERAL INFORMATION 3-1
3.2 SCOPE OF THIS REGULATION 3-3
3.2.1 Commercial IWC Facilities 3-3
3.2.2 Captive and Intra-company IWC Facilities 3-3
3.3 SUMMARY INFORMATION ON 84 COMMERCIAL IWC FACILITIES . . 3-5
3.4 SUMMARY INFORMATION ON 26 COMMERCIAL IWC FACILITIES
WHICH GENERATE IWC WASTEWATER 3-6
3.4.1 RCRA Designation of 26 IWC Facilities 3-8
3.4.2 Waste Burned at 26 IWC Facilities 3-9
3.4.3 Air Pollution Control Systems for 26 IWC Facilities 3-9
3.5 SUMMARY INFORMATION ON 11 COMMERCIAL IWC FACILITIES
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WHICH GENERATE AND DISCHARGE IWC WASTEWATER 3-12
3.6 INDUSTRY SUBCATEGORIZATION 3-13
SECTION 4 WASTEWATER USE AND WASTEWATER CHARACTERIZATION .... 4-1
4.1 WATER USE AND SOURCES OF WASTEWATER 4-1
4.2 WATER USE BY MODE OF DISCHARGE 4-2
4.3 WASTEWATER CHARACTERIZATION 4-3
4.3.1 Conventional Pollutants 4-4
4.3.2 Priority and Non-Conventional Pollutants 4-7
4.4 WASTEWATER POLLUTANT DISCHARGES 4-7
SECTION 5 POLLUTANTS AND POLLUTANT PARAMETERS SECLECTED FOR
REGULATION 5-1
5.1 POLLUTANT PARAMETERS 5-1
5.2 PRIORITY AND NON-CONVENTIONAL POLLUTANTS 5-1
5.2.1 Dioxins/Furans in Industrial Waste Combustor Subcategory 5-2
5.2.2 Selection of Priority and Non-Conventional Pollutants for Regulation 5-5
5.3 SELECTION OF POLLUTANTS TO BE REGULATED FOR PSES AND
PSNS 5-7
5.3.1 Pass-Through Analysis Approach 5-8
5.3.2 50 POTW Study Database 5-8
5.3.3. RREL Treatabiliiy DataBase 5-9
5.3.4 Final POTW Data Editing 5-10
5.3.5 Final Pass-Through Analysis Results 5-11
SECTION 6 WASTEWATER TREATMENT TECHNOLOGIES 6-1
6.1 AVAILABLE BAT AND PSES TECHNOLOGIES 6-2
6.1.1 Physical/Chemical Treatment 6-2
6.1.1.1 Equalization 6-2
6.1.1.2 Neutralization or pH Control 6-3
6.1.1.3 Flocculation 6-5
6.1.1.4 Gravity-Assisted Separation 6-7
6.1.1.5 Chemical Precipitation 6-9
6.1.1.6 Stripping 6-11
6.1.1.7 Filtration 6-11
6.1.1.7.1 Sand/Multi-Media Filtration 6-14
6.1.1.7.2 Fabric Filters 6-16
6.1.1.7.3 Ultrafiltration 6-16
6.1.1.8 Carbon Adsorption 6-18
6.1.1.9 Chromium Reduction 6-20
6.1.2 Sludge Handling 6-20
6.1.2.1 Sludge Slurrying 6-22
6.1.2.2 Vacuum Filtration 6-22
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6.1.2.3 Pressure Filtration 6-22
6.1.2.4 Centrifuges 6-25
6.1.2.5 Dryer 6-25
6.1.3 Zero Discharge Options 6-26
6.1.3.1 Incineration . 6-26
6.1.3.2 Off-Site Disposal 6-26
6.1.3.3 Evaporation/Land Applied 6-26
6.2 TREATMENT OPTIONS FOR OTHER WASTEWATERS GENERATED BY
IWC OPERATIONS 6-26
6.2.1 Chemical Oxidation 6-27
6.2.2 Zero Discharge Options 6-28
6.2.2.1 Deep Well Disposal 6-30
6.3 OTHER WASTEWATER TREATMENT TECHNOLOGIES 6-30
6.4 TREATMENT PERFORMANCE AND DEVELOPMENT OF REGULATORY
OPTIONS . 6-31
6.4.1 Performance of EPA Sampled Treatment Processes 6-31
6.4.1.1 Treatment Performance for Episode #4646 6-31
6.4.1.2 Treatment Performance for Episode #4671 6-38
6.4.1.3 Treatment Performance for Episode #4733 6-43
6.4.2 Rationale Used for Selection of BAT Treatment Technologies 6-47
SECTION 7 ENGINEERING COSTS 7-1
7.1 COSTS DEVELOPMENT 7-2
7.1.1 Sources of CostData 7-2
7.1.1.1 Cost Models 7-2
7.1.1.2 Vendor Data 7-3
7.1.1.3 Waste Treatment Industry Phase II: Incinerators 308
Questionnaire Costing Data 7-4
7.1.1.4 Other EPA Effluent Guideline Studies . . . 7-4
7.1.2 Benchmark Analysis and Evaluation Criteria 7-4
7.1.3 Selection of Final CostModels 7-7
7.2 ENGINEERING COSTING METHODOLOGY 7-8
7.2.1 Treatment Costing Methodology 7-9
7.2.2 Option Costing Methodology 7-11
7.3 TREATMENT TECHNOLOGIES COSTING . 7-13
7.3.1 Physical/Chemical Wastewater Treatment Technology Costs 7-15
7.3,1.1 Chemical Feed Systems 7-15
7.3.1.2 Pumping 7-33
7.3.1.3 Rapid Mix Tanks 7-33
7.3.1.4 Flocculation 7-38
7.3.1.5 Primary Clarification 7-41
7.3.1.6 Secondary Clarification 7-41
7.3.1.7 Multi-Media Filtration 7-44
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7.3.2 Sludge Treatment and Disposal 7-48
7.3.2.1 Plate and Frame Pressure Filtration 7-48
7.3.2.2 Filter Cake Disposal Costs 7-51
7.4 ADDITIONAL COSTS 7-51
7.4.1 Retrofit and Upgrade Costs 7-52
7.4.2 Land Costs 7-52
7.4.3 RCRA Permit Modification Costs 7-53
7.4.4 Monitoring Costs 7-53
7.5 WASTEWATER OFF-SITE DISPOSAL COSTS 7-55
7.6 COSTSFORREGULATORYOPTIONS 7-56
7.6.1 BPT/BAT Costs 7-56
7.6.1.1 BPT/BAT Option A: Two-Stage Chemical
Precipitation 7-56
7.6.1.2 BPT/BAT Option B: Two-Stage Chemical Precipitation and
Multi-Media Filtration 7-57
7.6.2 PSES Costs .......: 7-57
7.6.2.1 PSES Option A: Two-Stage Chemical Precipitation . . 7-57
7.6.2.2 PSES Option B: Two-Stage Chemical Precipitation and
Multi-Media Filtration 7-60
7.6.3 New Source-Performance Standards Costs 7-60
7.6.4 Pretreatment Standards for New Sources Costs 7-60
SECTION 8 DEVELOPMENT OF LIMITATIONS AND STANDARDS 8-1
8.1 ESTABLISHMENT OF BPT 8-1
8.2 BCT 8-6
8.3 BAT 8-6
8.4 NSPS 8-6
8.5 PSES 8-8
8.6 PSNS 8-10
8.7 COST OF TECHNOLOGY OPTIONS 8-10
8.7.1 Proposed BPT Costs 8-11
8.7.2 Proposed BCT/BAT Costs 8-11
8.7.3 Proposed PSES Costs 8-11
8.8 POLLUTANT REDUCTIONS 8-12
8.8.1 Conventional Pollutant Reductions 8-12
8.8.2 Priority and Nonconventional Pollutant Reductions 8-12
8.8.2.1 Methodology 8-12
8.8.2.2 Direct Discharges (BPT/BAT) 8-13
8.8.2.3 PSES Effluent Discharges to POTWs 8-13
SECTION 9 NON-WATER QUALITY IMPACTS 9-1
9.1 AJRPOLLUTION - 9-1
9.2 SOLID WASTE 9-2
IV
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9.3 ENERGY REQUIREMENTS 9-3
Appendix A Range of Pollutant Influent Concentrations of the Pooled Daily Data from the
Three 5-Day EPA Sampling Episodes for all Analytes
Appendix B ACRONYMS AND DEFINITIONS
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LIST OF TABLES
ES-1 Technology Basis of BPT Effluent Limitations
ES-2 Cost of Implementing Regulations (in millions of 199? dollars)
3-1 Number of Thermal Units at Each of the 84IWC Facility Locations
3 -2 Types of Thermal Units at 84 IWC Facilities
3-3 Amount of Waste Treated by 84 Commercial Facilities in Calendar Year 1992 (Tons)
3-4 Quantity of Process Wastewater Generated by 84 IWC Facilities in Calendar Year 1992
(Thousand Gallons)
3-5 1992 RCRA Designation of 26 Commercial Facilities
3-6 Number of Customers/Facilities Served in 1992 by 26 Commercial Facilities
3-7 Types of Air Pollution Control Systems at 26 Commercial Facilities
3-8 Air Pollutants for Which Add-On Control Systems are in Operation for 26 Commercial
Facilities
3-9 Scrubbing Liquor Used in Air Pollution Control Sytems of 26 Commercial Facilities
3-10 Type of Water Recirculation System Used in Air Pollution Control Systems of the 26 IWC
Facilities
4-1 Amount of IWC Wastewater Discharged
4-2 Range of Pollutant Influent Concentrations (ug/1)
4-3 IWC Industry Current Performance
5-1 Breakdown of Detected Dioxin/Furans During IWC Sampling Program
5-2 Pollutants Excluded from Regulation Due to the Concentration Detected for the IWC
Industry
5-3 Pollutants Excluded from Regulation Due to Ineffective Treatment for the IWC
Industry
5-4 Pollutants Indirectly Controlled Through Regulation of Other Pollutants
5-5 Pollutants Selected for Regulation for the IWC Industry
5-6 Final POTW Removals for IWC Industry Pollutants
5-7 Final Pass-Through Results for TWC Industy Options A and B
6-1 Description of IWC Sampling Episodes
6-2 Treatment Technology Performance for Facility 4646?
6-3 Treatment Technology Performance for Facility 4671?
6-4 Treatment Technology Performance for Facility 4733?
6-5 Primary Chemical Precipitation Treatment Technology Performance Comparison
6-6 Secondary Chemical Precipitation and Filtration Treatment Technology Performance
Comparison
7-1 Benchmark Analysis Cost Comparison
7-2 Breakdown of Costing Method by Treatment Technology
7-3 Additional Cost Factors
7-4 Regulatory Option Wastewater Treatment Technology Breakdown
7-5 Chemical Addition Design Method
7-6 Treatment Chemical Costs
7-7 Sodium Hydroxide Requirements for Chemical Precipitation
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7-8 State Land Costs
7-9 Analytical Monitoring Costs
7-10 IWC Facilities Costed for Off-Site Disposal
8-1 BPT Effluent Limitations (mg/1)
8-2 PSES Effluent Limitations (mg/1)
8-3. Direct Discharge Loads (in Ibs.)
8-4. Indirect Discharge Loads (in Ibs.)
9-1 Filter Cake Generation for the IWC Industry
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LIST OF FIGURES
6-1 Equalization
6-2 Neutralization
6-3 Clarification System Incorporating Coagulation and Flocculation
6-4 Chemical Precipitation System Design
6-5 Typical Air Stripping System
6-6 Multimedia Filtration
6-7 Ultrafiltration System Diagram
6-8 Granular Activated Carbon Adsorption
6-9 Chromium Reduction
6-10 Vacuum Filtration
6-11 Plate and Frame Pressure Filtration System Diagram
6-12 Cyanide Destruction
6-13 EPA Sampling Episode 4646 - IWC Wastewater Treatment System Block Flow Diagram
with Sampling Locations
6-14 EPA Sampling Episode 4671 - IWC Wastewater Treatment System Block Flow Diagram
with Sampling Locations
6-15 EPA Sampling Episode 4733 - IWC Wastewater Treatment System Block Flow Diagram
with Sampling Locations
7-1 Option-Specific Costing Logic Flow Diagram
7-2 Sodium Hydroxide Capital Cost Curve
7-3 Sodium Hydroxide O&M Cost Curve
7-4 Ferric Chloride Capital Cost Curve
7-5 Ferric Chloride O&M Cost Curve
7-6 Sodium Bisulfite Capital Cost Curve
7-7 Sodium Bisulfite O&M Cost Curve
7-8 Hydrochloric Acid Capital Cost Curve
7-9 Hydrochloric Acid O&M Cost Curve
7-10 Polymer Feed Capital Cost Curve
7-11 Polymer Feed O&M Cost Curve
7-12 Wastewater Pumping Capital Cost Curve
7-13 Wastewater Pumping O&M Cost Curve
7-14 Mix Tank Capital Cost Curve
7-15 Mix Tank O&M Cost Curve
7-16 Flocculation Capital Cost Curve
7-17 Flocculation O&M Cost Curve
7-18 Primary Clarifier Capital Cost Curve
7-19 Primary Clarifier O&M Cost Curve
7-20 Secondary Clarifier Capital Cost Curve
7-21 Secondary Clarifier O&M Cost Curve
7-22 Multimedia Filtration Capital Cost Curve
7-23 Sludge Dewatering Capital Cost Curve
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7-24 Sludge Dewatering O&M Cost Curve
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EXECUTIVE SUMMARY
EPA has proposed technology-based limits for the discharge of pollutants into navigable
waters of the United States and into publicly-owned treatment works by existing and new facilities
that are engaged in combustion of industrial waste from off-site facilities - the Industrial Waste
Combustor Subcategory of the Waste Combustors Point Source Category. This proposed regulation
establishes effluent limitations guidelines for direct dischargers based on the following treatment
technologies: "best practicable control technology" (BPT), "best conventional pollutant control
technology" (BCT), anc* "best available technology economically achievable" (BAT). New source
performance standards are based on "best demonstrated technology". The proposal also establishes
pretreatment standards for new and existing indirect dischargers.
EPA identified 84 facilities in the Industrial Waste Combustor Industry. The scope of the
Industrial Waste Combustor Industry includes: commercially-operating hazardous waste combustor
facilities regulated as "incinerators" or "boilers and industrial furnaces" under the Resource
Conservation and Recovery Act (RCRA) as well as commercially-operating non-hazardous waste
industrial waste combustor facilities. The proposed effluent limitations guidelines and standards are
intended to cover wastewater discharges resulting from air pollution control systems, flue gas quench
systems and slag quench systems associated with the operation of industrial waste combustors. Any
other discharges associated with the operations of industrial waste combustors (e.g., truck washing
water and boiler blowdown) are not included in the regulation. EPA has estimated that the proposed
regulation will apply to 11 facilities which discharge specified IWC wastewater. Eight facilities
discharge directly and three discharge indirectly to publicly-owned treatment works (POTWs).
The EPA evaluated various treatment technologies in developing the effluent limitations and
standards. Table ES-1 lists the treatment technologies that are proposed for the BPT limitations and
for the PSES pretreatment standards. The treatment technologies proposed for BPT are the same
technologies proposed for BCT, BAT and NSPS. The treatment technologies proposed for PSES
are the same treatment technologies proposed for PSNS.
ES-1
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Table ES-1. Technology Basis for Effluent Limitations and Pretreatment Standards
Proposed
40CFR
Suboart
Type
Technology Basis
444
BPT,BAT,BCT, and
NSPS Effluent
Limitations
Primary Precipitation, Solid-Liquid Separation,
Secondary Precipitation, Solid-Liquid Separation,
and Sand Filtration
444
PSES and PSNS
Pretreatment Standards
Primary Precipitation, Solid-Liquid Separation,
Secondary Precipitation and Solid-Liquid Separation
After identifying treatment technologies, the EPA calculated facility costs to upgrade facility
operations to achieve the proposed limitations based on the selected technology options. Table ES-2
presents the capital and operating and maintenance costs associated with the proposed technology
options. In addition to the costs for upgrading facility operations, costs were also developed for:
additional land requirements, additional wastewater monitoring requirements for the proposed
regulation, and RCRA permit modifications, when necessary. Overall, the proposed technology
options are estimated to have a post-tax annualized cost of $1.381 million (in 1992$) for direct
dischargers and $0.531 million (in 1992$) for indirect dischargers.
Table ES-2. Cost of Implementing Regulations [in Millions of 1992 dollars]
Type
BPT, BAT, BCT, and NSPS
Effluent Limitations
PSES and PSNS
Pretreatment Standards
Number
of
Facilities
8
3
Capital Costs
[in 1992$]
6.346
2.090
Annual O & M
Costs
[in 1992$]
1.255
0.529
ES-2
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SECTION 1
STATUTORY REQUIREMENTS
Effluent limitations guidelines and standards for the Industrial Waste Combustor Industry
were proposed under the authority of Section 301, 304, 306, 307, 308 and 501 of the Clean Water
Act (CWA) (the Federal Water Pollution Control Act Amendments of 1972, 33 U.S.C. 1251 et seq.,
as amended by the Clean Water Act of 1977, Pub. L. 95-217, and the Water Quality Act of 1987,
Pub. L. 100-4), also referred to as "the Act".
1.1
LEGAL A UTHOWTY
The Federal Water Pollution Control Act Amendments of 1972 established a comprehensive
program to "restore and maintain the chemical, physical, and biological integrity of the Nation's
waters". (Section 101(a)). To implement the Act, EPA is required to issue effluent limitations
guidelines and pretreatment standards for industrial discharges. These guidelines and standards are
summarized briefly in the following sections.
1.1.1
Best Practicable Control Technology Currently Available (BPT)
(Section 304(b)(l) of the CWA)
In the guidelines, EPA defines BPT effluent limits for conventional, priority, and non-
conventional pollutants. In specifying BPT, EPA looks at a number of factors. EPA first considers
the cost of achieving effluent reductions in relation to the effluent reduction benefits. The Agency
next considers: 1) the age of the equipment and facilities, the processes employed and any required
process changes, engineering aspects of the control technologies, non-water quality environmental
impacts (including energy requirements), and such other factors as the Agency deems appropriate
(CWA §304(b)(l)(B)). Traditionally, EPA establishes BPT effluent limitations based on the average
of the best performances of facilities within the industry of various ages, sizes, processes or other
common characteristics. Where, however, existing performance within a category or subcategory
is uniformly inadequate, EPA may require higher levels of control than currently in place in an
industrial category (or subcategory) if the Agency determines that the technology can be practically
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applied. BPT may be transferred from a different subcategory or category.
In the initial stages of EPA CWA regulation, EPA efforts emphasized the achievement of BPT
limitations for control of the "classical" pollutants (e.g., TSS, pH, BODS). However, nothing on the
face of the statute specifically restricted BPT limitations to such pollutants. Following passage of the
CWA of 1977 with its requirement for point sources to achieve best available technology limitations
to control discharges of toxic pollutants, EPA shifted its focus to address the listed priority pollutants
under the guidelines program. BPT guidelines continue to include limitations to address all
pollutants.
1.1.2 Best Conventional Pollutant Control Technology (BCT)
(Section 304(a)(4) of the CWA)
The 1977 Amendments added Section 301 (b)(2)(E) to the Act establishing BCT for
discharges of conventional pollutants from existing industrial point sources. Section 304(a)(4)
designated the following as conventional pollutants: biochemical oxygen demanding pollutants
(BOD), total suspended solids (TSS), fecal coliform, pH, and any additional pollutants defined by the
Administrator as conventional. The Administrator designated oil and grease as an additional
conventional pollutant on July 30, 1979 (44 FR 44501). BCT is not an additional limitation, but
replaces BAT for the control of conventional pollutants. In addition to other factors specified in
Section 304(b)(4)(B), the Act requires that BCT limitations be established in light of a two-part
"cost-effectiveness" test [American Paper Institute v. EPA, 660 F.2d 954 (4th Cir. 1981)]. EPA's
current methodology for the general development of BCT limitations was issued in 1986 (51 FR
24974; July 9, 1986).
1.1.3 Best Available Technology Economically Achievable (BAT)
(Sections 304(b)(2)(B) of the CWA)
In general, BAT effluent limitations guidelines represent the best economically achievable
performance of plants in the industrial subcategory or category. The CWA establishes BAT as a
principle means of controlling the direct discharge of priority and non-conventional pollutants to
waters of the United States. The factors considered in assessing BAT include the cost of achieving
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BAT effluent reductions, the age of equipment and facilities involved, the process employed, potential
process changes, and non-water quality environmental impacts, including energy requirements. The
Agency retains considerable discretion in assigning the weight to be accorded these factors. Unlike
BPT limitations, BAT limitations may be based on effluent reductions attainable through changes in
a facility's processes and operations. As with BPT, where existing performance is uniformly
inadequate, BAT may require a higher level of performance than is currently being achieved based
on technology transferred from a different subcategory or category. BAT may be based upon process
changes or internal controls, even when these technologies are not common industry practice.
1.1.4
New Source Performance Standards (NSPS)
(Section 306 of the CWA)
NSPS reflect effluent reductions that are achievable based on the best available demonstrated
treatment technology. New plants have the opportunity to install the best and most efficient
production processes and wastewater treatment technologies. As a result, NSPS should represent
the most stringent controls attainable through the application of the best available control technology
for all pollutants (i.e., conventional, non-conventional, and priority pollutants). In establishing NSPS,
EPA is directed to take into consideration the cost of achieving the effluent reduction and any non-
water quality environmental impacts and energy requirements.
1.1.5
Pretreatment Standards for Existing Sources (PSES)
(Section 307(b) of the CWA)
PSES are designed to prevent the discharge of pollutants that pass-through, interfere-with,
or are otherwise incompatible with the operation of publicly-owned treatment works (POTWs). The
CWA authorized EPA to establish pretreatment standards for pollutants that pass-through POTWs
or interfere with treatment processes or sludge disposal methods at a POTW. Pretreatment standards
are technology-based and analogous to BAT effluent limitations guidelines.
The general Pretreatment Regulations, which set forth the framework for the implementation
of categorical pretreatment standards, are found in 40 CFR Part 403. Those regulations contain a
definition of pass-through that addresses localized rather than national instances of pass-through and
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established pretreatment standards that apply to all non-domestic dischargers (52 FR 1586; January
14,1987).
1.1.6 Pretreatment Standards for New Sources (PSNS)
(Section 307(b) of the CWA)
Like PSES, PSNS are designed to prevent the discharges of pollutants that pass-through,
interfere-with, or are otherwise incompatible with the operation of POTWs. PSNS are to be issued
at the same time as NSPS. New indirect dischargers have the opportunity to incorporate into their
plants the best available demonstrated technologies. The Agency considers the same factors in
promulgating PSNS as it considers in promulgating NSPS.
1.2 SECTION 304(M) REQUIREMENTS AND LITIGATION
Section 304(m) of the CWA (33 U.S.C. 1314(m)), added by the Water Quality Act of 1987,
requires EPA to establish schedules for (I) reviewing and revising existing effluent limitations
guidelines and standards ("effluent guidelines"), and (ii) promulgating new effluent guidelines. On
January 2,1990, EPA published an Effluent Guidelines Plan (55 FR 80), that included schedules for
developing new and revised effluent guidelines for several industry categories. One of the industries
for which the Agency established a schedule was the "Hazardous Waste Treatment, Phase IT'
category. EPA subsequently changed the category name "Hazardous Waste Treatment, Phase IT
to "Landfills and Incinerators".
Natural Resources Defense Council, Inc. (NRDC) and Public Citizen, Inc. challenged the
Effluent Guidelines Plan in a suit filed in U.S. District Court for the District of Columbia (NRDC et
al v. Reitty, Civ. No. 89-2980). The district court entered a Consent Decree in this litigation on
January 31, 1992. The Decree required, among other things, that EPA propose effluent guidelines
for the "Landfills and Incinerators" category by December 1995 and take final action on these effluent
guidelines by December 1997. On February 4,1997, the court approved modifications to the Decree
which revised the deadlines to November 1997 for proposal and November 1999 for final action.
EPA provided notice of these modifications on February 26, 1997 at 62 FR 8726. Also, although
"Landfills and Incinerators" is listed as a single entry in the Consent Decree schedule, EPA is
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publishing two separate rulemaking actions in the Federal Register.
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SECTION 2
DATA COLLECTION
In 1986, the Agency initiated a study of waste treatment facilities which receive waste from
off site for treatment, recovery, or disposal. The Agency looked at various segments of the waste
management industry including combustors, centralized waste treatment facilities, landfills, fuel
blending operations, and waste solidification/stabilization processes (Preliminary Data Summary for
the Hazardous Waste Treatment Industry, EPA 440-1-89-100, September 1989).
Development of effluent limitations guidelines and standards for the Industrial Waste
Combustor Subcategory began in 1993. EPA originally looked at RCRA hazardous waste
incinerators, RCRA boilers and industrial furnaces (BIFs), and non-hazardous combustion units that
treat industrial waste. Sewage sludge incinerators, municipal waste incinerators, and medical waste
incinerators were not included in the 1989 study or in the initial data collection effort in 1993. EPA
limited this phase of the rulemaking to the development of regulations for Industrial Waste
Combustors.
EPA has gathered and evaluated technical and economic data from various sources in the
course of developing the effluent limitations guidelines and standards for the Industrial Waste
Combustor Industry. These data sources include:
Responses to EPA's "1992 Waste Treatment Industry Phase EL: Incinerators Screener
Survey",
Responses to EPA's "1994 Waste Treatment Industry Phase II: Incinerators
Questionnaire",
Responses to EPA's " 1994 Detailed Monitoring Questionnaire",
EPA's 1993 - 1995 sampling of selected IWC facilities
Literature data, and
Facility NPDES and POTW wastewater discharge permit data.
EPA has used data from these sources to profile the industry with respect to: wastes received
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for treatment or recovery, treatment/recovery processes, geographical distribution, and waste-water
and solid waste disposal practices. EPA then characterized the wastewater generated by
treatment/recovery operations through an evaluation of water usage, type of discharge or disposal,
and the occurrence of conventional, non-conventional, and priority pollutants.
2.1
2.1.1
CLEAN WATER ACT SECTION 308 QUESTIONNAIRES AND SCREENER
SURVEYS
Development of Questionnaires andScreener Surveys
A major source of information and data used in developing effluent limitations guidelines and
standards is industry responses to questionnaires and screener surveys distributed by EPA under the
Authority of Section 308 of the CWA. The questionnaires typically request information concerning
treatment processes, wastes received for treatment, and disposal practices, as well as wastewater
treatment system performance data. Questionnaires also request financial and economic data for use
in assessing economic impacts and the economic achievability of technology options. Screener
surveys generally request less detailed information than the questionnaires regarding treatment
processes, wastes received for treatment, and disposal practices.
EPA used its experience with previous questionnaires to develop one screener survey (the
1992 Waste Treatment Industry Phase IE: Incinerators Screener Survey) and two questionnaires (the
1994 Waste Treatment Industry Phase II: Incinerators Questionnaire and the Detailed Monitoring
Questionnaire) for this project. The 1992 Waste Treatment Industry Phase II: Incinerators Screener
Survey was designed to obtain general information on facility operations from a census of the
industry. The 1994 Waste Treatment Industry Phase II: Incinerators Questionnaire was designed
to request 1992 technical, economic, and financial data to describe industrial operations adequately
from a census of facilities in the industry that were operating commercially and from a sample of
facilities in the industry that were not operating commercially. The Detailed Monitoring
Questionnaire was designed to elicit daily analytical data from a limited number of facilities which
would be selected after receipt and review of the 1994 Waste Treatment Industry Phase II:
Incinerators Questionnaire responses.
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For the 1994 Waste Treatment Industry Phase IE: Incinerators Questionnaire, EPA wanted
to minimize the burden to IWC facilities. Thus, only a statistical sample of the non-commercial
facilities meeting the preliminary scope qualifications received the 1994 Waste Treatment Industry
Phase II: Incinerators Questionnaire. The questionnaire specifically requested information on:
combustion processes,
types of waste received for combustion,
wastewater and solid waste disposal practices,
ancillary waste management operations,
summary analytical monitoring data,
the degree of co-combustion (combustion of waste received from off site with other
on-site industrial waste),
cost of waste combustion processes, and
the extent of wastewater recycling or reuse at facilities.
In the 1994 Waste Treatment Industry Phase IE: Incinerators Questionnaire, EPA requested
summary monitoring data from all recipients, but summary information is not sufficient for
determining limitations and industry variability. Therefore, the Detailed Monitoring Questionnaire
was designed to collect daily analytical data from a limited number of facilities. Facilities were chosen
to complete the Detailed Monitoring Questionnaire based on technical information submitted in the
1994 Waste Treatment Industry Phase E: Incinerators Questionnaire. The burden was minimized
in the Detailed Monitoring Questionnaire by tailoring the questionnaire to the facility operations.
EPA sent draft screener surveys and questionnaires to industry trade associations, incinerator
facilities who had expressed interest, and environmental groups for review and comment. A pre-test
for both the 1992 Waste Treatment Industry Phase II: Incinerators Screener Survey and the 1994
Waste Treatment Industry Phase II: Incinerators Questionnaire was conducted at nine IWC facilities
to determine if the type of information necessary would be received from the questions posed as well
as to determine if questions were designed to minimize the burden to facilities. Based on comments
from the reviewers, EPA modified the draft questionnaire.
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As required by the Paperwork Reduction Act, 44 U.S.C. 3501 et seq., EPA submitted the
questionnaire package (including the 1992 Waste Treatment Industry Phase II: Incinerators Screener
Survey and the 1994 Waste Treatment Industry Phase II: Incinerators Questionnaire and the Detailed
Monitoring Questionnaire) to the Office of Management and Budget (OMB) for review. EPA also
redistributed the questionnaire package to industry trade associations, IWC facilities, environmental
groups, and to any others who requested a copy of the questionnaire package.
2.1.2 Distribution of Screener Surveys and Questionnaires
Under the authority of Section 308 of the CWA, EPA sent the Waste Treatment Industry
Phase II: Incinerators 1992 Screener Survey (OMB Approval Number: 2040-0162, Expired:
08/31/96) in September 1993 to 606 facilities that the Agency had identified as possible Industrial
Waste Combustor facilities. EPA identified the 606 facilities as possible IWC facilities from various
sources; such as, companies listed in the 1992 Environmental Information (El) Directory, companies
that were listed as incinerators in the RCRIS National Oversight Database (November 1992 and
February 1993 versions), companies that were listed as BIF Facilities by EPA (updated December
1992), and incinerator facilities identified in the development of the Centralized Waste Treatment
Industry effluent guidelines. Since the Industrial Waste Combustor Subcategory was not represented
by a SIC code at the time of the survey, identification of facilities was difficult. The screener survey
requested summary information on: (1) the types of wastes accepted for combustion; (2) the types
of combustion units at a facility; (3) the quantity, treatment, and disposal of wastewater generated
from combustion operations; (4) available analytical monitoring data on wastewater treatment; and
(5) the degree of co-treatment (treatment of Industrial Waste Combustor wastewater with wastewater
from other industrial operations at the facility). The responses from 564 facilities indicated that 3 57
facilities burned industrial waste in 1992. The remaining 207 did not bum industrial waste in 1992.
Of the 357 facilities that burned industrial waste, 142 did not generate any Industrial Waste
Combustor wastewater as a result of their combustion operations. Of the remaining 215 facilities that
generated Industrial Waste Combustor wastewater, 59 operated commercially, and 156 only burned
wastes generated on site, and/or only burned wastes generated from off-site facilities under the same
corporate structure.
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Following an analysis of the screener survey results, EPA sent the 1994 Waste Treatment
Industry Phase II: Incinerators Questionnaire (OMB Approval Number: 2040-0167, Expired:
12/31/96) in March, 1994 to selected facilities which burned industrial waste and generated Industrial
Waste Combustor wastewater. EPA sent the questionnaire to all 59 of the commercial facilities and
all 16 of the non-commercial facilities that burned non-hazardous industrial waste. Further, EPA sent
32 of the remaining 140 non-commercial facilities a questionnaire. These 32 facilities were selected
%
based on a statistical random sample. The questionnaire specifically requested information on: (1)
the type of wastes accepted for treatment; (2) the types of combustion units at a facility; (3) the types
of air pollution control devices used to control emissions from the combustion units at a facility; (4)
the quantity, treatment, and disposal of wastewater generated from combustion operations; (5)
available analytical monitoring data on wastewater treatment; (6) the degree of co-treatment
(treatment of Industrial Waste Combustor wastewater with wastewater from other industrial
operations at the facility); and (7) the extent of wastewater recycling and/or reuse at the facility.
Information was also obtained through follow-up telephone calls and written requests for clarification
of questionnaire responses.
EPA also requested a subset of Industrial Waste Combustor facilities that received a
questionnaire to submit wastewater monitoring data in the form of individual data points rather than
monthly or annual aggregates. Only facilities that had identified a sample point location where the
stream was over 50 percent Industrial Waste Combustor wastewater received the Detailed
Monitoring Questionnaire. These wastewater monitoring data included information on pollutant
concentrations at various points in the wastewater treatment processes. Data were requested from
26 facilities. Sixteen of these facilities operated commercially and 10 operated non-commercially.
2.2
SAMPLING PROGRAM
2.2.1
Pre-1989 Sampling Program
In the sampling program for the 1989 Hazardous Waste Treatment Industry Study, 12
facilities were sampled to characterize the wastes received and evaluate the on-site treatment
technology performance at combustors, landfills, and hazardous waste treatment facilities. Since all
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of the facilities sampled had more than one on-site operation (e.g., combustion and landfill leachate
generation), the data collected can not be used for this project because data were collected for mixed
waste streams and the waste characteristics and treatment technology performance for the combustor
facilities cannot be differentiated. Information collected in the study is presented in the Preliminary
Data Summary for the Hazardous Waste Treatment Industry (EPA 440/1-89/100, September 1989).
2.2.2
1993 -1995 Sampling Program
2.2.2.1
Facility Selection
Between 1993 and 1995, EPA visited 14 Industrial Waste Combustor facilities. Eight of the
fourteen Industrial Waste Combustors EPA visited were captive facilities because captive facilities
were still being considered for inclusion in the scope of the Industrial Waste Combustor regulation
at the time of the site visits. During each visit, EPA gathered the following information:
the process for accepting waste for combustion,
the types of waste accepted for combustion,
design and operating procedures for combustion technologies,
general facility management practices,
,i
water discharge options,
solid waste disposal practices, and
other facility operations.
EPA also took one grab sample of untreated Industrial Waste Combustor scrubber blowdown water
at 12 of the 14 facilities. EPA analyzed most of these grab-samples for over 450 analytes to identify
pollutants at these facilities. The grab samples from the 12 site visits allowed EPA to assess whether
there was a significant difference in raw wastewater characteristics from a wide variety of combustion
unit types. (See Section 3 for a description of the types of combustion units.) EPA determined that
the raw wastewater characteristics were similar for all types of combustion units both in the types of
pollutants detected and the concentrations of pollutants detected. Specifically, organics,
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pesticides/herbicides, and dioxins/furans were generally only detected, if at all, in low concentrations
in the grab samples. (See Section 5 of this document for a discussion of dioxins/furans found at seven
of the twelve Industrial Waste Combustor facilities sampled.) However, a variety of metal analytes
were detected in significant concentrations in the grab samples.
Based on these data and the responses to the 1994 Waste Treatment Industry Phase EL:
Incinerators Questionnaire, EPA selected three of the Industrial Waste Combustor facilities for the
BAT sampling program in order to collect data to characterize discharges and the performance of
selected treatment systems. Using data supplied by the facilities, EPA applied five criteria in initially
selecting which facilities to sample. The criteria were based on whether the wastewater treatment
system: (1) was effective in removing pollutants; (2) treated wastes received from a variety of sources
(solids as well as liquids); (3) employed either novel treatment technologies or applied traditional
treatment technologies in a novel manner, (4) applied waste management practices that increased the
effectiveness of the treatment unit; and (5) discharged its treated wastewater under a NPDES permit.
The other 11 facilities visited were not sampled because they did not meet these criteria. Eight of
these eleven facilities visited did not operate commercially, and are thus no longer in the scope of the
project.
2.2.2.2
Five-Day Sampling Episodes
After a facility was chosen to participate in the five-day sampling program, a draft sampling
plan was prepared which described the location of sample points and analyses to be performed at
specific sample points, as well as the procedures to be followed during the sampling episode. Prior
to sampling, a copy of the draft sampling plan was provided to the facility for review and comment
to ensure that EPA properly described and understood facility operations. All comments were
incorporated into the final sampling plan. During the sampling episode, teams of EPA employees and
contractors collected and preserved samples. Samples were sent to EPA approved laboratories for
analysis. Samples were collected at both influent and effluent points. Samples were also taken at
intermediate points to assess the performance of individual treatment units. Facilities were given the
option to split all samples with EPA, but most facilities split only effluent sample points with EPA.
Following the sampling episode, a draft sampling report was prepared that included descriptions of
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the treatment/recovery processes, sampling procedures, and analytical results. After all information
was gathered, the reports were provided to facilities for review and comment. Corrections were
incorporated into the final report. The facilities also identified any information in the draft sampling
report that were considered to be Confidential Business Information (CBI).
During each sampling episode, wastewater treatment system influent and effluent streams
were sampled. Samples were also taken at intermediate points to assess the performance of individual
treatment units. Selected sampling information is summarized in Section 4 and Appendix A of this
document. In all sampling episodes, samples were analyzed for over 450 analytes to identify the
pollutants at these facilities. Again, organic compounds, pesticides/herbicides, and dioxins/furans were
generally only detected in low concentrations in the composite daily samples, if they were detected
at all. Dioxin/furan analytes were not detected in the sampling episode used to establish
BPT/BAT/PSES. However, dioxin/furan analytes were found in the two other sampling episodes
(see discussion in Section 5 of this document).
EPA completed the three sampling episodes for the Industrial Waste Combustor Subcategory
from 1994 to 1995. Selection of facilities to be sampled was limited due to the small number of
facilities in the scope of the project. Only eight of the operating facilities identified discharged their
treated wastewater under a 1S1PDES permit. Of these eight facilities, only five burned solid as well
as liquid waste. All of the facilities sampled used some form of chemical precipitation for treatment
of the metal-bearing waste streams. All of the facilities were direct dischargers and were therefore
designed to effectively treat the one conventional pollutant found in this industry, TSS. Data from
two of these facilities could not be used to calculate the proposed limitations and standards in
combination with the third facility because they did not employ the selected treatment technology.
However, data from all three facilities were used to characterize the raw waste streams. Thus, only
one sampling episode contained data which were used to characterize the treatment technology
performance of the Industrial Waste Combustors Industry.
Information on waste stream characteristics is included in Section 4 of this document and
system performance is included in Section 6.
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SECTION 3
DESCRIPTION OF THE INDUSTRY AND SUBCATEGORIZATION
3.1
GENERAL INFORMATION
The universe of combustion facilities currently in operation in the United State is broad.
These include municipal waste incinerators that bum household and other municipal trash and
incinerators that bum hazardous wastes. Other types of incinerators include those that bum medical
wastes exclusively and sewage sludge incinerators for incineration of POTWs' wastewater treatment
residual sludge. In addition, some boilers and industrial furnaces (e.g., cement kilns) may burn waste
materials for fuel.
While many industries began incinerating some of their wastes as early as the late 1950's, the
current market for waste combustion (particularly combustion of hazardous wastes) is essentially a
creature of the Resource Conservation and Recovery Act (RCRA) and EPA's resulting regulation
of hazardous waste disposal. Among the major regulatory spurs to combustion of hazardous wastes
have been the land-ban restrictions under the Hazardous and Solid Waste Amendments (HSWA) of
1984 and clean-up agreements for Superfund sites called "Records of Decision" (RODs).
Prior to the promulgation of EPA's Land Disposal Restrictions (LDRs)(40 CFR Part 268),
hazardous waste generators were free to send untreated wastes directly to landfills. The LDRs
mandated alternative treatment standards for wastes, known as Best Demonstrated Available
Technologies (BDATs). Quite often, combustion was the stipulated BDAT. Future modifications
to the LDRs may either increase or decrease the quantity of wastes directed to the combustion sector.
The LDRs have also influenced hazardous waste management under the Comprehensive
Environmental Response, Compensation, and Liability Act(CERCLA)(42U.S.C §§ 9601, et. seq.).
The RODs set out the clean-up plan for contaminated sites under CERCLA. A key attribute of the
RODs is the choice of remediation technology. Incineration is often a technology selected for
remediation. While remediation efforts contribute a minority of the wastes managed by combustion,
combustion has been used frequently on remediation projects. In addition, future Congressional
changes to CERCLA may affect remediation disposal volumes directed to the combustion sector.
The Agency proposed a draft Waste Minimization and Combustion Strategy in 1993 and 1994
3-1 ,
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to promote better combustion of hazardous waste and encourage reduced generation of wastes. The
key projects under the broad umbrella of the strategy are: "Revised Standards for Hazardous Waste
Combustors" 61 FR 17358, April 1996, the Waste Minimization National Plan completed in May
1995, and the "RCRA Expanded Public Participation Rule" 60 FR 63417, December 1995. Waste
minimization will directly affect waste volumes sent to the combustion and all other waste
management sectors.
In recent years, a number of contrary forces have contributed to a reduction in the volume of
wastes being incinerated. Declines in waste volumes and disposal prices have been attributed to:
waste minimization by waste generators, intense price competition driven by overcapacity, and
changes in the competitive balance between cement kilns (and other commercial Boilers and Industrial
Furnaces (BIFs)) and commercial incinerators. These trends have been offset by factors such as
increased overall waste generation as part of general economic improvement, Industrial Waste
Combustors consolidation, and reductions in on-site combustion.
The segment of the universe of combustion units for which EPA is proposing regulations
includes all units which operate commercially and which use controlled flame combustion in the
treatment or recovery of industrial waste. For example, industrial boilers, industrial furnaces, rotary
kiln incinerators, and liquid-injection incinerators are all types of units included in the Industrial Waste
Combustor Industry.
Combustion or recovery operations at these facilities generate the following types of
wastewater, described more fully in Section 4: air pollution control wastewater, flue gas quench
wastewater, slag quench, truck/equipment wash water, container wash water, laboratory drain
wastewater, and floor washings from process areas. Typical non-wastewater by-products of
combustion or recovery operations may include: slag or ash developed in the combustion unit itself,
and emission particles collected using air pollution control systems. There are many different types
of air pollution control systems in use by combustion units. The types employed by combustion units
include, but are not limited to: packed towers (which use a caustic scrubbing solution for the removal
of acid gases), baghouses (which remove particles and do not use any water), wet electrostatic
precipitators (which remove particles using water but do not generate a wastewater stream), and
venturi scrubbers (which remove particles using water and generate a wastewater stream). Thus, the
3-2
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amount of wastewater and types of wastewater generated by a combustion unit are directly dependent
upon the types of air pollution control systems employed by the combustion unit.
3.2
SCOPE OF THE REGULATION
3.2.1
Commercial IWC Facilities
EPA proposed effluent limitations guidelines and pretreatment standards for new and existing
commercial facilities that are engaged in the combustion of industrial waste received from off-site
facilities not under the same corporate ownership as the industrial waste combustor. The proposal
would not apply to wastewater generated in burning wastes from intracompany transfers exclusively
and/or from on-site industrial processes exclusively.
The proposed regulation applies to the discharge of wastewater associated with the operation
of the following:
RCRA Incinerators (as defined in 40 CFR 260.10 and in the Definitions Section of
this document),
RCRA Boiler and Industrial Furnaces (BIFs) (as defined in 40 CFR 260.10 and in the
Definitions Section of this document), and
Non-hazardous commercial combustors.
3.2.2
Captive and Infra-company IWC Facilities
As noted above, the proposal would not apply to wastewater discharges associated with
combustion units that burn only wastes generated on site. Furthermore, wastewater discharges from
RCRA hazardous incinerators, RCRA BIFs, and non-hazardous combustors that bum waste
generated off site from facilities that are under the same corporate ownership (or effective control)
as the combustor are similarly not included within the scope of this proposal. Facilities subject to the
guidelines and standards would include commercial facilities whose operation is the combustion of
off-site generated industrial waste as well as industrial or manufacturing combustors that burn waste
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received from off-site facilities that are not within the same corporate structure.
As noted, facilities which only burn waste from off-site facilities under the same corporate
structure (intracompany facility) and/or only bum waste generated on site (captive facility) are not
included in the scope of the IWC proposal. EPA has decided not to include these facilities within the
scope of this regulation for the following reasons. First, based on its survey, EPA identified (as of
1992) approximately 185 captive facilities and 89 facilities that burn wastes received from other
facilities within the same corporate umbrella.1 A significant number of these facilities generated no
Industrial Waste Combustor wastewater. EPA's data show that 73 captive facilities (39 percent) and
36 intracompany facilities (42 percent) generated no wastewater as a result of their industrial waste
combustor operations. Second, EPA believes the wastewater generated by Industrial Waste
Combustor operations at most of the captive and intracompany facilities that EPA has identified are
already subject to national effluent limitations (or pretreatment standards) based on the manufacturing
operations at the facility. Specifically, 140 of the 156 captive and intracompany facilities which
received a screener survey and generated Industrial Waste Combustor wastewater as a result of their
combustion operations: 1) were either previously identified as subject to other effluent guidelines by
EPA; or 2) identified themselves as subject to other effluent guidelines. There are 97 facilities subject
to the Organic Chemicals, Plastics and Synthetic Fibers category (40 CFR Part 414), 17 facilities
subject to the Pharmaceuticals category (40 CFR Part 439), 16 facilities subject to the Steam Electric
Power Generating category (40 CFR Part 423), 3 facilities subject to the Pesticide Manufacturing
category (40 CFR Part 455), and 7 facilities subject to other categories. EPA could not identify an
effluent guideline category applicable to their discharges for the remaining 16 of the 156 identified
captive and intracompany facilities (five of these are federal facilities).
Also, 83 percent of all captive facilities and 73 percent of all intracompany facilities reported
that the combustion unit wastewaters made up less than 20 percent of the final wastewater stream
discharged from each facility. EPA concluded that, in these circumstances, it is likely that the
1As explained in Section 2, EPA conducted an extensive survey (with follow-up
questionnaire), in part, to characterize the universe of facilities being considered for regulation.
Following proposal, EPA plans to review its screener survey and questionnaire results in order to
confirm the accuracy of its assignment of wastewater flows and facilities as captive,
intracompany, or commercial Industrial Waste Combustors.
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Industrial Waste Combustor waste streams are being treated along with other categorical waste.
Also, 71 percent of all captive facilities and 67 percent of all intracompany facilities reported that their
IWC wastewater is covered as process wastewater under existing EPA effluent limitations (40 CFR
Parts 405-471). This indicates that most Industrial Waste Combustor waste streams are subject either
directly (where discharged separately) or when mixed with other wastes subject to national effluent
guidelines (or pretreatment standards) comparable to those being considered here. Given these facts,
EPA has concluded preliminarily that it should not include such captive or intracompany facilities
within the scope of the proposed IWC rule.
3.3
SUMMARY INFORMATION ON 84 COMMERCIAL IWC FACILITIES
For 1992, EPA identified 84 combustor facilities that accept hazardous or non-hazardous
industrial waste from off-site facilities not under the same corporate umbrella for combustion. The
following tables provide summary information from the 1992 Waste Treatment Industry Phase II:
Incinerators Screener Survey on these 84 combustor facilities.
Many of the 84 commercial IWC facilities have more than one unit on site. The majority of
facilities with two or more units on site operate boilers, industrial furnaces, or cement, lime, or
aggregate kilns. Table 3-1 presents the number of thermal units at each of the 84 IWC facilities.
Table 3-1. Number of Thermal Units at Each of the 84 Commercial IWC Facility Locations
Number of Units
Number of Facilities
1
39
2
23
3
9
4
6
5
2
6
1
7
0
8
0
>8
1
There are more industrial furnaces, boilers, cement kilns, lime kilns, and aggregate kilns than
any other unit types. However, more than one of these units often exist at a single facility. Table 3-2
presents the unit types at all 84 IWC facilities.
Most of the waste burned by the 84 IWC facilities is hazardous or non-hazardous industrial
waste containing organic compounds. Only one facility indicated that it burned waste containing
dioxins/furans, and only four facilities indicated burning waste regulated under the Toxic Substances
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Table 3-2. Types of Thermal Units at 84 Commercial IWC Facilities
Type of Thermal Unit
Rotary Kiln Incinerator
Liquid Injection Incinerator
Fluidized-Bed Incinerator
Multiple-Hearth Incinerator
Fixed-Hearth Incinerator
Pyrolytic Destructor
Industrial Boiler
Industrial Furnace
Cement, Lime, or Aggregate Kiln
Other
Number of Each Unit Type
23
. . 17
1
6
3
3
32
38
31
19
Control Act (TSCA). Table 3-3 presents the types and amount of waste treated at all 84 IWC
facilities.
For the proposed IWC regulations, only air pollution control water, slag quench and flue gas
quench are considered "IWC Wastewater." The largest wastewater stream generated by the 84 IWC
facilities, stormwater runoff, is regulated under other effluent guidelines. The industry also generates
large quantities of boiler blowdown. Boiler blowdown wastewater was not considered for regulation
for this industry because it does not come into contact with any of the wastes being burned. Table
3-4 presents the quantity of process wastewater generated by the 84 IWC facilities.
3.4
SUMMARY INFORMATION ON 26 COMMERCIAL IWC FACILITIES WHICH
GENERATE IWC WASTEWATER
Following the distribution of the screener survey, EPA sent the 1994 Waste Treatment
Industry Phase IE: Incinerators Questionnaire to only those commercial facilities that generated IWC
wastewater. Fifty-eight of the 84 commercial IWC facilities did not generate any IWC wastewater;
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Table 3-3. Amount of Waste Treated by 84 Commercial IWC Facilities in Calendar Year
1992 (Tons)
Waste Type
Tons
1-
50
51-
100
101-
500
501-
1,000
1,001-
5,000
5,001-
10,000
>
10,000
#of
Facilities
Non-RCRA
Sewage Sludge
Municipal Waste
Containing Metals
Containing Organics
All Other Types
0
0
3
13
7
1
0
0
4
0
0
0
4
10
5
0
1
1
1
1
0
1
4
11
7
0
0
1
5
0
0
0
4
7
1
1
2
17
51
21
RCRA
Containing Metals
Containing Organics
Containing
Dioxins/Furans
Containing Pesticides/
Herbicides
All Other Types
6
10
0
0
3
0
2
0
2
0
3
6
1
1
1
3
5
0
1
1
7
5
0
8
1
2
6
0
0
1
20
32
0
1
6
41
66
1
13
13
Special
Radioactive Wastes
TSCA Wastes (PCBs)
Medical Wastes
1
0
0
0
0
0
0
0
1
0
0
0
0
1
0
0
0
0
0
3
0
1
4
1
thus, EPA only has detailed operation information on the 26 commercial IWC facilities that generated
wastewater. The following tables provide summary information from the 1994 Waste Treatment
Industry Phase II: Incinerators Questionnaire from these 26 combustor facilities.
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Table 3-4. Quantity of Process Wastewater Generated by 84 Commercial IWC Facilities
in Calendar Year 1992 (Thousand Gallons)
Type of Process Water
None
Air Pollution Control
Wastewater
Slag Quench
Process Area Washdown
Truck/Equipment Wash
Water
Container Wash Water
Stormwater Runoff
Laboratory Wastewater
Flue Gas Quench
Wastewater
Boiler Blowdown
Other
Gallons (1,000s)
0-
5
25
2
1
6
2
2
2
5
2
6
2
5-
15
0
1
0
2
0
0
2
0
0
1
0
15-
50
0
2
2
3
2
1
0
0
1
3
3
50-
100
0
2
0
1
2
1
2
2
0
1
0
100-
500
0
0
2
5
2
1
3
3
0
0
0
500-
750
0
0
0
0
0
1
3
0
0
3
0
>750
0
14
0
4
3
0
17
1
8
11
9
#of
Facilities
25
21
5
21
11
6
29
11
11
25
14
3.4.1 RCRA Designation of 26 Commercial IWC Facilities
Most of the 26 facilities that generate IWC wastewater are regulated as incinerators under
RCRA. Very few boilers and industrial furnaces regulated under RCRA generate air pollution
control wastewater, flue gas quench, or slag quench. There were no non-RCRA industrial waste
\
combustors that generated IWC wastewater identified by EPA. Table 3-5 presents the RCRA
designation of the 26 commercial facilities.
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Table 3-5. 1992 RCRA Designation of 26 Commercial IWC Facilities
Hazardous Waste Incinerator
Boiler and/or Industrial Furnace
Exempt under 40 CFR Part 264 Subpart O
Total Thermal Units
25
8
0
3.4.2
Waste Burned at 26 IWC Facilities
The number of customers served by a facility varies greatly in this industry. Some facilities
burn primarily waste generated on site and take very few waste shipments from facilities not under
their corporate structure. Other facilities operate a Strictly commercial operation, serving hundreds
or thousands of customers on a regular basis. Table 3-6 presents the number of customers served by
the 26 commercial facilities.
Table 3-6. Number of Customers/Facilities Served in 1992 by 26 Commercial IWC
Facilities
Minimum
Maximum
Mean
Median
Total
Number of Customers
1
4,000
807
75
27,452
3.4.3 Air Pollution Control Systems for 26 Commercial IWC Facilities
The type of air pollution control system used by an IWC facility has a direct effect on the
characteristics and quantity of the IWC wastewater generated by that facility. Table 3 -7 presents the
types of air pollution control systems in use at the 26 commercial facilities. Table 3-8 presents the
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types of air pollutants for which add-on control systems are in operation for the 26 IWC facilities.
Some of these systems do not generate any wastewater (e.g., a fabric filter for particulate removal).
Other systems would generate wastewater (e.g., a packed tower scrubber with lime used for
halogenated acid gas removal).
Table 3-7. Types of Air Pollution Control Systems at 26 Commercial IWC Facilities
Type of Air Pollution Control System
Spray Chamber Scrubber
Impingement Baffle Scrubber
Wet Cyclone (including multiclones)
Venturi Scrubber
Sieve Tray Tower
Packed Tower
Ionizing Wet Scrubber
Wet Electrostatic Precipitator
Fabric Filter
Dry Scrubber
Spray Dryer
Other (Includes: Demister; Dry Cyclone; Dry Electrostatic
Precipitator; Horizontal Packed Absorber; Scrubber Quench
Unit; Steam Atomization)
Total Thermal Units
16
2
2
12
2
16
4
3
11
2
1
14
Of the facilities that use water in their air pollution control systems, the chemicals added to
the water and the types of water recirculation systems vary greatly by facility. The addition of
chemicals to the water is dependent upon the purpose of the scrubbing system (e.g., no chemicals
would be used to trap particulates in a cyclonic scrubber and sodium hydroxide would be used to
remove halogenated acid gases in a packed tower scrubber.) The chemicals added to the scrubber
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Table 3-8. Air Pollutants for Which Add-On Control Systems are in Operation for 26
Commercial IWC Facilities
Air Pollutant
None
Halogenated Acid Gases
Sulfur Compounds
Nitrogen Compounds
Particulates
Metals
Other (Organics)
Total Thermal Units
2
21
19
7
30
23
1
water would have a direct effect on the characteristics of the wastewater generated. Table 3-9
presents the types of scrubbing liquors in use at the 26 commercial IWC facilities.
Table 3-9. Scrubbing Liquor Used in Air Pollution Control Systems of 26 Commercial
IWC Facilities
Scrubbing Liquor
None
Water With No Added Chemicals
Sodium Hydroxide
Lime Slurry
Other (Includes: Lime-Hydrated; Sodium Carbonate
Solution; Sulfuric Acid)
Total Thermal Units
7
13
17
8
7
The type of water recirculation system used by a facility also has a direct effect on the amount
of wastewater generated. If a facility operated a closed loop air pollution control system with no
discharge, no wastewater would be generated. Alternately, a facility that did not recirculate its air
pollution control system wastewater, would tend to generate a large quantity of wastewater. Table
3-11
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3-10 presents the types of water recirculation systems.
Table 3-10. Type of Water Recirculation System Used in Air Pollution Control Systems at
the 26 Commercial IWC Facilities
Water Recirculation System
None (once through)
Closed Loop (no discharge)
Recirculating with Intermittent Slowdown
Recirculating with Continuous Slowdown
Total Thermal Units
2
7
1
14
3.5
SUMMARY INFORMATION ON 11 COMMERCIAL IWC FACILITIES WHICH
GENERATE AND DISCHARGE IWC WASTEWATER
Thirteen of the twenty-six facilities generate Industrial Waste Combustor wastewater but do
not discharge the wastewater to a receiving stream or to a POTW. These facilities are considered
"zero or alternative dischargers" and use a variety of methods to dispose of their wastewater. At
these facilities: (1) wastewater is sent off site for treatment or disposal (four facilities); (2) wastewater,
is burned or evaporated on site (five facilities); (3) wastewater is sent to a surface impoundment on
site (three facilities); and (4) wastewater is injected underground on site (one facility). Thus, EPA
has identified only 13 facilities that were discharging Industrial Waste Combustor wastewater to a
receiving stream or to a POTW in 1992. Of these 13 facilities, 2 facilities have either stopped
accepting waste from off site for combustion or have closed their combustion operations since 1992.
Eight of the eleven open facilities discharge their Industrial Waste Combustor wastewater to a
receiving stream and three of the eleven facilities discharge their Industrial Waste Combustor
wastewater to a POTW. These 11 facilities are found near the industries generating the wastes
undergoing combustion.
The 11 open facilities identified by EPA operate a wide variety of combustion units. Four
facilities operate rotary kilns and are regulated as incinerators under RCRA. Three facilities operate
liquid injection incinerators and are regulated as incinerators under RCRA. Three facilities operate
3-12
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furnaces and are regulated as BIFs under RCRA. One facility operates a liquid injection device and
is regulated as a BIF under RCRA. And, one facility operates a combustion device that is not
regulated as a BIF or as an incinerator under RCRA.
The 11 open facilities identified by EPA use a wide variety of air pollution control systems.
The types of air pollution control systems in use are: fabric filters, spray chamber scrubbers, packed
tower scrubbers, ionizing wet scrubbers, venturi scrubbers, dry scrubbers, dry cyclones, and wet
electrostatic precipitators. Ten of the 11 open facilities use more than one of the air pollution control
systems listed above. Six of the eleven facilities use a combination of wet and dry air pollution
control systems. Four of the eleven facilities use only wet air pollution control systems. It is
unknown what types of air pollution systems are used by two of the facilities.
3.6
INDUSTRY SUBCATEGORIZATION
Division of an industry into groupings entitled "subcategories" provides a mechanism for
addressing variations between products, raw materials, processes, and other parameters which result
in distinctly different effluent characteristics. Regulation of an industry by subcategory provides that
each has a uniform set of effluent limitations which take into account technology achievability and
economic impacts unique to that subcategory.
The factors considered in the regulation of the Industrial Waste Combustor Industry include:
waste type received;
type of combustion process;
air pollution control used;
nature of wastewater generated;
facility size, age, and location;
non-water quality impact characteristics; and
treatment technologies and costs.
EPA evaluated these factors and determined that subcategorization is not required.
For most facilities in this industry, a wide variety of wastes are combusted. These facilities,
3-13
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however, employ the same wastewater treatment technologies regardless of the specific type of waste
being combusted in a given day.
EPA concluded that a number of factors did not provide an appropriate basis for
subcategorization. The Agency concluded that the age of a facility should not be a basis for
subcategorization because many older facilities have unilaterally improved or modified their treatment
process over time. Facility size is also not a useful technical basis for subcategorization for the
Industrial Waste Combustor Industry because wastes can be burned to the same level regardless of
the facility size and has no significant relation to the quality or character of the wastewaters generated
or treatment performance. Likewise, facility location is not a good basis for subcategorization; no
consistent differences in wastewater treatment performance or costs exist because of geographical
location. Non-water quality characteristics (waste treatment residuals and air emission effects) did
not constitute a basis for subcategorization. The environmental effects associated with disposal of
waste treatment residual or the transport of potentially hazardous wastewater are a result of
individual facility practices. The Agency did not identify any consistent basis for these decisions that
would support subcategorization. Treatment costs do not appear to be a basis for subcategorization
because costs will vary and are dependent on the following waste stream variables: flow rates, waste
quality, waste energy content, and pollutant loadings. Therefore, treatment costs were not used as
a factor in determining subcategories.
EPA identified three factors with significance for potentially subcategorizing the Industrial
Waste Combustor Industry: the type of waste received for treatment, the type of air pollution control
system used by a facility, and the types of Industrial Waste Combustor wastewater sources (e.g.,
container wash water vs. air pollution control water).
A review of untreated Industrial Waste Combustor air pollution control system wastewater
showed that there is some difference in the concentration of pollutants between solid and liquid waste
combustion units. In particular, for nine of the 27 metals analyzed at six Industrial Waste Combustor
facilities, the average concentration of a particular metal was higher in the water from facilities that
burned solids (as well as liquids) than in facilities that burned liquids only. EPA believes that this
difference is probably the result of two factors: the type of air pollution control employed by the
facilities and the amount of wastewater generated. Specifically, the data reviewed by EPA showed
3-14
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that two of the three facilities that burn liquid waste use dry scrubbing devices prior to using
scrubbing devices which generate wastewater. One of these facilities uses a baghouse initially and
the other uses a fabric filter. These dry scrubbers would remove some of the metals which would
have ended up in the wastewater stream. In comparison, only one of the three facilities that bum
solids uses a dry scrubbing device prior to using scrubber devices which generate wastewater. This
facility uses an electrostatic pretipitator initially. In addition, all three of the facilities that burn liquid
waste do not recycle any of their wastewater for reuse in the scrubbing system following partial
wastewater treatment. In comparison, two of the three facilities that burn solids recycle some of their
partially treated wastewater for reuse in their scrubbing system. One of these facilities recycles 60
percent and the other recycles 82 percent. The reuse of partially treated wastewater would have the
effect of reducing the wastewater discharge and increasing the concentration of metals in the recycled
wastewater. Thus, it is difficult to assess whether there is in fact any significant difference in the
concentrations of pollutants in wastewater from facilities burning solid versus liquid waste. This
situation in general makes subcategorizing on this basis difficult. Therefore, EPA has concluded that
available data do not support subcategorization either by the type of waste received for treatment or
the type of air pollution control system used by a facility.
Based on analysis of the Industrial Waste Combustor Industry, EPA has determined that it
should not subcategorize the Industrial Waste Combustors for purposes of determining appropriate
limitations arid standards.
3-15
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-------
SECTION 4
WASTEWATER USE AND WASTEWATER CHARACTERIZATION
In 1993, under authority of Section 308 of the Clean Water Act (CWA), the EPA distributed
the "Waste Treatment Industry Phase II: Incinerators 1992 Screener Survey" and, subsequently, the
"1994 Waste Treatment Industry Phase II: Incinerators Questionnaire" to facilities that EPA had
identified as possible IWC facilities. Responses to the screener survey and questionnaire indicated
that, in 1992, 13 IWC facilities operated commercially and discharged their IWC wastewater to a
receiving stream or to a POTW. Of these 13 facilities, 2 facilities have either stopped accepting waste
from off site for combustion or have closed their combustion operations since 1992. Thus, this
section presents information on water use at only the remaining 11 facilities. This section also
presents information on wastewater characteristics for the IWC facilities that were sampled by EPA
and for some of those facilities that provided self-monitoring data.
4.1
WATER USE AND SOURCES OF WASTEWATER
Approximately 861 million gallons of wastewater are generated and discharged annually at
the 11 Industrial Waste Combustor facilities. EPA has identified the sources described below as
contributing to wastewater discharges at Industrial Waste Combustor operations. Only air pollution
control wastewater, flue gas quench, and slag quench, however, would be subject to the proposed
effluent limitations and standards. Most of the wastewater generated by Industrial Waste Combustor
operations result from these sources.
a. Air Pollution Control System Wastewater. Particulate matter in the effluent gas stream of an
Industrial Waste Combustor is removed by four main physical mechanisms (Handbook of Hazardous
Waste Incineration. Brunner 1989). One mechanism is interception, which is the collision between
a water droplet and a particle. Another method is gravitational force, which causes a particle to fall
out of the direction of the streamline. The third mechanism is impingement, which causes a water
particle to fall out of the streamline due to inertia. Finally, contraction and expansion of a gas stream
allow particulate matter to be removed from the stream. Thus, removal of particulate matter can be
accomplished with or without the use of water. Depending upon the type of waste being burned,
4-1
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Industrial Waste Combustors may produce acid gases in the air pollution control system. In order
to collect these acid gases, a caustic solution is generally used in a wet scrubbing system.
b. Flue Gas Quench Wastewater. Water is used to rapidly cool the gas emissions from
combustion units. There are many types of air pollution control systems that are used to quench the
gas emission from Industrial Waste Combustors. For example, in packed tower scrubbing systems,
water enters from the top of the tower and gas enters from the bottom. Water droplets collect on the
packing material and are rinsed off by the water stream entering the top of the tower (Handbook of
Hazardous Waste Incineration. Brunner 1989). This rapidly cools the gas stream along with
removing some particulate matter.
c. Slag Quench Wastewater. Water is used to cool molten material generated in slagging-type
combustors.
d. Truck/Equipment Wash Water. Water is used to clean the inside of trucks and the equipment
used for transporting wastes.
e. Container Wash Water. Water is used to clean the insides of waste containers.
f. Laboratory Wastewater. Water is used in on-site laboratories which characterize incoming
waste streams and monitor on-site treatment performance.
g. Floor Washings and Other Wastewater from Process Area. This includes stormwater which
comes in direct contact with the waste or waste handling and treatment areas. (Stormwater which
does not come into contact with the wastes would not be subject to today's proposed limitations and
standards. However, this stormwater is covered under the NPDES stormwater rule, 40 CFR 122.26).
4.2 WATER USE BY MODE OF DISCHARGE
As mentioned in Section 4.1, approximately 861 million gallons of wastewater were
discharged from 11 of the 84 commercial industrial combustors identified by EPA based on
questionnaire responses. Eight of the 11 facilities discharge wastewater directly into a receiving
stream or body of water. The other three facilities discharge indirectly by introducing their
wastewater into a publicly-owned treatment works (POTW). Table 4-1 presents the total, average,
and range of discharge flow rates for the eight direct and the three indirect discharging facilities.
There are 71 facilities that either do not generate any Industrial Waste Combustor wastewater (58)
4-2
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or do not discharge their wastewater to a receiving stream or POTW (13) as discussed previously.
In general, the primary types of wastewater discharges from discharging facilities are: air pollution
control system wastewater and flue gas quench. EPA is using the phrase "Industrial Waste
Combustor wastewater" to refer to these three types of wastewaters only. Other types of wastewater
generated as a result of combustor operations (e.g., truck washing water) are not considered
"Industrial Waste Combustor wastewater".
This regulation applies to direct and indirect discharges only.
Table 4-1. Amount of IWC Wastewater Discharged
Type of
Discharger
Direct
Indirect
Number of
Facilities
8
3
Total Amount of
IWC Wastewater
Discharged
(Gallons/Day)
2,110,799
225,812
Average Amount
of IWC
Wastewater
Discharged
(Gallons/Day)
263,850
75,271
Range In Amount
of IWC
Wastewater
Discharged
(Gallons/Day)
14 to 1,000,286
89 to 11 3, 867
4.3
WASTEWATER CHARACTERIZATION
The Agency's five-day sampling program for this industry detected 21 pollutants
(conventional, priority, and non-conventional) in waste streams at treatable levels at the facility that
provides the basis for the BPT/BAT limits. Two additional pollutants were detected at treatable
levels in the two other five-day sampling episodes: strontium and dichlorprop. The quantity of these
pollutants currently being discharged from all facilities is difficult to assess. Limited monitoring data
are available from facilities for the list of pollutants identified from the Agency's sampling program
prior to commingling of these wastewaters with non-contaminated stormwater and other industrial
wastewater before discharge. EPA used monitoring data supplied in the 1994 Waste Treatment
Industry Phase II: Incinerators Questionnaire and data supplied in the Detailed Monitoring
Questionnaire, wastewater permit information, and EPA sampling data to estimate raw waste and
4-3
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current pollutant discharge levels. EPA used a "non-process wastewater" factor to quantify the
amount of non-contaminated storm-water and other industrial process water in a facility's discharge.
Section 4.4 of this document provides a more detailed description of "non-process wastewater"
factors and their use. A facility's current discharge of treated Industrial Waste Combustor wastewater
was calculated using the monitoring data supplied multiplied by the "non-process wastewater" factor.
4.3.1
Conventional Pollutants
The most appropriate conventional pollutant parameters for characterizing untreated
wastewater and wastewater discharged by IWC facilities are:
Total Suspended Solids, and
pH
Total solids in wastewater are defined as the residue remaining upon evaporation at just above
the boiling point. Total suspended solids (TSS) is the portion of the total solids that can be filtered
out of the solution using a 1 micron filter. Untreated wastewater TSS content is a function of the
type and form of waste accepted for treatment (e.g., wastewater that results from the combustion of
solid waste receipts would tend to have higher TSS values than waste received in a liquid form). TSS
can also be due to treatment chemicals added to the wastewater as it is being generated (e.g., a
caustic solution may be used in an IWC air pollution control system). The total solids are composed
of matter which is settleable, in suspension or in solution, and can be removed in a variety of ways,
such as during the metals precipitation process or by multimedia filtration, depending on a facility's
operation. Untreated wastewater TSS levels found in the three five-day EPA sampling episodes are
presented in Table 4-2.
The pH of a solution is a unitless measurement which represents the acidity or alkalinity of
a wastewater stream, based on the dissociation of the acid or base in the solution into hydrogen (H+)
or hydroxide (OH-) ions, respectively. Untreated wastewater pH is a function of the source of waste
receipts as well as a function of the chemicals used in the air pollution control devices. This
parameter can vary widely from facility to facility. Control of pH is necessary to achieve proper
4-4
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removal of pollutants in the BPT/B AT treatment system (chemical precipitation).
As shown in Table 4-2, raw waste five-day biochemical oxygen demand and oil and grease
are very low, ranging from 1 mg/1 to 53 mg/1 and from 5 mg/1 (not detected) to 6 mg/1, respectively.
Both of these parameters are indirect measures of the organic strength of wastewater. The
wastewater sampled by EPA is generated from air pollution control systems and consists primarily
of inorganic pollutants and very low concentrations of organic compounds because they are destroyed
during combustion. (Furthermore, a more direct measure of the organic strength of the raw
wastewater, total organic carbon, also shown in Table 4-2, only ranges from 10 mg/1 (not detected)
to 16 mg/1).
Table 4-2. Range of Pollutant Influent Concentrations of the Pooled Daily Data form the
Three Five-Day EPA Sampling Episodes (ug/1)
Pollutant
Aluminum
Ammonia as Nitrogen
Antimony
Arsenic
BODS
Boron
Cadmium
Calcium
Chemical Oxygen Demand
Chloride
Chromium
Copper
Fluoride
Iron
Mean
897.6
14,312.4
268.2
166.4
9,960
1,604.6
312.2
293,146.0
343,140.0
6,833,746.7
127.2
1,786.7
82,620.5
2,904.1
Minimum
13.6
100.0
7.8
4.6
1,000
918.0
1.8
8,140.0
67,000.0
1,010,000.0
5.8
8.5
16,500.0
149.0
Maximum
2,538.0
75,000.0
958.8
827.2
53,000
3,760.0
2,616.0
1,270,000.0
1,036,000.0
17,002,400.0
529.2
10,554.0
360,000.0
10,838.0
4-5
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Table 4-2. (Continued)
Pollutant
Lead
Manganese
Mercury
Molybdenum
Nitrate/Nitrite
Oil and Grease
Phosphorus
Potassium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Tin
Titanium
Total Dissolved Solids
Total Organic Carbon
Total Phosphorus
Total Sulfide
Total Suspended Solids
Zinc
Dichlorprop
MCPP
Mean
1,613.9
114.7
21.1
336.7
2,650.9
5,067
32,480.0
77,743.0
102,8
15,414.0
98.9
3,443,333.3
630.2
400,788.1
665.9
777.7
12,815,853.3
10,485
1,088.6
28,261.3
122,553.3
3,718.8
7.7
375.7
Minimum
2.1
4.0
0.2
4.6
360.0
5,000
3,210.0
1,310.0
2.3
5,380.0
1.0
6,400.0
100.0
2,145.0
14.5
5.0
158,000.0
10,000
10.0
1,000.0
4,000.0
89.8
1.0
50.0
Maximum
13,248.0
388.0
115.4
1024 .4
4,560.0
6,000
225,800.0
195,400.0
429.2
28,100.0
390.8
11,250,600.0
2,280.0
1,078,240.0
6,046.0
4,474.2
32,641,200.0
16,000
4,460.0
103,200.0
522,000.0
12,310.0
47.0
2,594.0
4-6
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4.3.2
Priority and Non-Conventional Pollutants
Table 4-2 below presents the range of the pooled daily pollutant influent concentration data
from the three five-day EPA sampling episodes. This table includes treatment chemicals and nutrients
found in IWC wastewater as well as pollutants to be removed from IWC wastewater. Appendix A
presents this information for all pollutants analyzed in the three five-day EPA sampling episodes.
4.4
WASTEWATER POLLUTANT DISCHARGES
As previously discussed, most of the effluent monitoring data received from facilities included
non-IWC wastewater, such as other industrial waste streams and stormwater. Due to the lack of
effluent data for IWC wastewater, the EPA had to develop various methods to estimate their current
wastewater pollutant discharge. This section describes the various methodologies used to estimate
current performance.
Most of the data supplied by the IWC facilities represented data that included non-IWC
wastewater in the form of noncontaminated stormwater and other industrial stormwater prior to
discharge. Therefore, the amount of a pollutant in the final effluent would be equal to the amount
of the pollutant in the IWC process in addition to the amount in the non-IWC process, as shown in
Equation 4.1.
TOTAL
* 17
r
IWC
NON-IWC
NON-IWC
(4.1)
where:
CT
-TOTAL
'IWC
Concentration of pollutant in the combined wastewater stream the
concentration reported in the Incinerators Questionnaire, the Incinerators
Detailed Monitoring Questionnaire, in POTW permits, in NPDES permits, or
from EPA sampling program.
Flowrate of total wastewater stream.
Concentration of pollutant in the IWC (and other similar) wastewater
4-7
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streams.
Flowrate of IWC (and other similar) wastewater streams.
Concentration of pollutant in stormwater or non-contact wastewater
streams.
Flowrate of stormwater or non-contact wastewater streams.
Stormwater or non-contact wastewater was assumed to be significantly lower in concentration
in comparison to the IWC wastewater, and thus, the concentration of non-IWC wastewater streams
was set equal to zero. This assumption simplifies Equation 4.1 as shown in Equation 4.2 below.
Also, other industrial wastewater streams were assumed to have the same concentrations as the IWC
wastewater streams.
CT F
TOTAL
* F
IWC
(4.2)
For each facility, the EPA calculated the portion of IWC wastewater in the facility discharge
and then calculated the IWC effluent concentration by solving Equation 4.2. Thus, the non-process
wastewater factor is the flowrate of the total wastewater stream divided by the flowrate of the IWC
(and other similar) wastewater stream.
The hierarchy of data used to estimate current loading concentrations was as follows:
1.) Detailed Monitoring Questionnaire (DMQ) for the Incinerators Industry data from
effluent sample locations for 1992. The facility's long-term monitoring data was supplied in this
questionnaire. Often, this data had to be corrected for inclusion of non-IWC wastewater streams
using Equation 4.2 above.
2.) Detailed Monitoring Report (DMR) data from effluent sample locations for 1992. The
facility's long-term monitoring data was supplied to EPA in this report. Often, this data had to be
corrected for inclusion of non-IWC wastewater streams using Equation 4.2 above.
3.) Waste Treatment Industry Phase BE: Incinerators Questionnaire data from effluent
sample locations for 1992. The facility's year-long monitoring data was supplied in this
questionnaire. Often, this data had to be corrected for inclusion of non-IWC wastewater streams
4-8
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using Equation 4.2 above.
4.) POTW or NPDES permit effluent concentrations for 1992. Often, this data had to be
corrected for inclusion of non-IWC wastewater streams using Equation 4.2 above.
5.) EPA Five-Day Sampling Data for Three IWC facilities. This data was used either for
specific facilities sampled or averages were obtained to model facilities for which limited data was
available.
6.) Averages from Similar Facilities. Data averages from similar facilities were used to model
current loadings concentrations for facilities for which limited data was available.
The average, flow-weighted, estimated current discharge concentration for facilities in the
IWC Industry is presented in Table 4-3.
4-9
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Table 4-3. IWC Industry Current Discharge Concentration
Pollutant
CHEMICAL OXYGEN DEMAND
TOTAL DISSOLVED SOLIDS
TOTAL SUSPENDED SOLIDS
ALUMINUM
ANTIMONY
ARSENIC
BORON
CADMIUM
CHROMIUM
COPPER
IRON
LEAD
MANGANESE
MERCURY
MOLYBDENUM
SELENIUM
SILVER
TIN
TITANIUM
ZINC
Discharge
Concentration
145.2
10,430.0
30.6
663.7
559.0
217.7
1,614.9
118.4
4,276.9
944.2
306.2
363.4
156.2
10.6
239.2
34.2
31.0
88.4
79.6
385.6
Unit
mg/1
mg/1
mg/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
4-10
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SECTION 5
POLLUTANTS AND POLLUTANT PARAMETERS SELECTED FOR
REGULATION
As previously discussed, EPA evaluated wastewater sampling data that was collected for this
industry in order to determine the pollutants that were further evaluated for the proposed regulation;
the "pollutants of concern" for the Industrial Waste Combustor (IWC) Industry. This section
discusses the pollutants and pollutant parameters detected in the Industrial Waste Combustor
Industry.
5.1
POLLUTANT PARAMETERS
In addition to looking at specific pollutants in wastewater, EPA also relies on a number of
other yardsticks for evaluating water quality. Some of these pollutant parameters, like total
suspended solids (TSS), measure the conventional pollutants while others, like chemical oxygen
demand (COD), are surrogates for non-conventional pollutants like ammonia. Traditionally, EPA
has regulated conventional pollutants only in direct discharge permits and has not regulated
discharges of conventional pollutants by facilities which are indirect dischargers.
The pollutant parameters proposed for regulation are a function of the characteristics of IWC
wastewater. In the IWC wastewater, TSS, COD, and total dissolved solids (TDS) were the only
pollutant parameters found at treatable concentrations. COD is not proposed for regulation because
the technology selected for BPT/BAT will not effectively reduce COD levels. Also, TDS is not
proposed for regulation because EPA's data showed that the treatment chemicals associated with the
technology selected for BPT/BAT increase the TDS levels. EPA is proposing to regulate TSS. The
level of TSS detected in IWC wastewater is important because of its correlation to treatment unit
effectiveness.
5.2
PRIORITY AND NON-CONVENTIONAL POLLUTANTS
During sampling visits at the beginning of EPA's study of this industry, EPA analyzed for
more than 450 priority, conventional, and non-conventional pollutants, listed in Appendix A. All
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pollutants listed in Appendix A have EPA approved analytical methods, including RCRA and TSCA
compounds. All of these pollutants were analyzed to characterize the full range of wastewater
pollutants that are observed in the IWC Industry.
The Agency has not proposed to regulate any pollutant that was not detected in the sampling
episodes at least three times at a significant concentration. Dioxins/furans were not selected for
regulation because they were detected infrequently and at low concentrations. A further discussion
of dioxins/furans in the IWC Industry appears below.
5.2.1 Dioxins/Furans in Industrial Waste Combustor Subcategory
1. Background. Scientific research has identified 210 isomers of chlorinated dibenzo-p-dioxins
(ODD) and chlorinated dibenzofurans (CDF). EPA attention has primarily focused on the 2,3,7,8-
substituted congeners, a priority pollutant under the CWA, of which 2,3,7,8- TCDD and 2,3,7,8-
TCDF are considered the most toxic. Evidence suggests that'non-2,3,7,8-substituted congeners may
not be as toxic. Some sources report that these non-2,3,7,8-substituted congeners may either be
broken down or quickly eliminated by biological systems.
Dioxins and furans are formed as a by-product during many industrial and combustion
activities, as well as during several other processes. The combustion activities that may create dioxins
under certain conditions may include:
Combustion of chlorinated compounds; including PCBs;
Some metals are suspected to serve as catalysts in the formation of dioxin/furans;
Metal processing and smelting;
Petroleum refining;
Chlorinated organic compound manufacturing.
2. Dioxin/Furans in Industrial Waste Combustor Wastewater. EPA identified a number of
dioxin/furan compounds as present in the untreated wastewater streams at seven of the twelve
facilities sampled (including grab and composite samples). Two of the facilities with dioxins detected
in their Industrial Waste Combustor wastewater are now closed and no longer within the scope of
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the proposed rule, so data from these facilities has not been further considered here. Thus, the
following discussion relates to data from the ten remaining facilities (a total of 32 aqueous samples).
Table 5-1 below summarizes the dioxin/furans detected in IWC wastewaters during the sampling
program. Similar isomers that contain the 2,3,7,8 base were grouped together for this analysis due
to their similar nature and characteristics.
Table 5-1. Breakdown of Detected Dioxin/Furans During IWC Sampling Program
Dioxin/Furan
2,3,7,8- TCDF
2,3,7,8- PeCDF
2,3,7,8- HxCDD
2,3,7,8- HxCDF
2,3,7,8- HpCDD
2,3,7,8- HpCDF
OCDD
OCDF
Toxic
Equivalent
Value
(TEQ)
0.1
0.5
0.1
0.1
0.01
0.01
0.001
0.001
Universal
Treatment
Standards
63,000 pg/1
35,000 pg/1
63,000 pg/1
63,000 pg/1
none
none
none
none
Mean
concentrations
IWC Industry
(detects only)
17 pg/1
93 pg/1
68 pg/1
249 pg/1
272 pg/1
939pg/l
971 pg/1
6165 pg/1
Total # of
aqueous
samples
detected
(out of 32)
2
1
1
7
5
7
10
6
#of
facilities
detected
(out of 10)
2
1
1
3
4
4
5
4
It is important to note that EPA did not detect 2,3,7,8-TCDD (the most toxic congener) or
2,3,7,8-PeCDD in the raw wastewater samples collected. The dioxin/furans detected in untreated
Industrial Waste Combustor wastewaters during EPA sampling at 10 sites show that these
dioxin/furans were all detected at levels significantly (orders of magnitude) below the "Universal
Treatment Standard" (40 CFR 268.48) level established under RCRA for dioxins/furans. In addition,
low levels of HpCDD and OCDD (as indicated above) are generally considered pervasive in the
environment and Universal Treatment Standards have not been set for these compounds. EPA
identified no dioxin/furans in the Industrial Waste Combustor wastewater treated effluent.
5-3
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CDD/CDFs are lipophilic and hydrophobic. As such, they are most often associated, or have
an affinity for, suspended particulates in wastewater matrices. The more highly chlorinated isomers
(i.e. the hepta- and octa- congeners) are.the least volatile and more likely to be removed through
particulate adsorption or filtration. While recommended treatment technologies differ according to
the wastewater characteristics, there is some evidence that dioxins generally will bind with suspended
solids and some sources (EPAKREL Treatability database) have asserted that these compounds may
be removed by precipitation and filtration technologies.
Of the three week long sampling episodes conducted by EPA, the episode from which
BAT/BPT limits were developed had no dioxins detected in the influent or effluent. At the other two
facilities, HpCDD, HpCDF, OCDD, and OCDF were detected in the influent but none were detected
in the effluent. Both facilities employed a combination of chemical precipitation and filtration that
may have contributed to these removals.
The most toxic congener, 2,3,7,8- TCDD, was never detected in Industrial Waste Combustor
scrubber water during the sampling program; and the CDD/CDFs detected were neither detected at
most facilities sampled nor found in any significant quantity. The toxic equivalent (TEQ) values
found in the Industrial Waste Combustor wastewater were low when compared to other dioxin
sources in industry. The detected congeners were of the highly chlorinated type which may be treated
by the methods recommended by this guideline (chemical precipitation, filtration). Also, since no
dioxins were detected in the treated effluents at any of the three facilities EPA sampled, this may be
evidence of dioxin removals.
Based on EPA's sampling program, no CDD/CDF met the criteria for wastewater regulation
in the proposed rule.
The Agency has proposed CDD/CDF air emission limits of 0.2 ng/dscm from the stacks of
hazardous waste burning incinerators (see 61 FR 17358 of 4/19/96 and 62 FR 24212 of 5/2/97), and
believes that the incinerators have to operate with good combustion conditions to meet the proposed
emission limits. In the final Land Disposal Restrictions (LDR) rulemaking that set treatment
standards for CDD/CDF constituents in non-wastewater and wastewater from F032, the Agency has
established (62 FR 26000,5/12/97) incineration as the BOAT, after which the CDD/CDF constituents
do not have to be analyzed in the effluent. EPA, therefore, considers that dioxins/furans will be
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sufficiently destroyed given good combustion practices.
5.2.2 Selection of Priority and Non-Conventional Pollutants for Regulation
The priority and non-conventional pollutants proposed for regulation were determined by
reviewing sampling data from the facility used for the proposed BPT/BAT technology. If a pollutant
was not detected at all in the Sampling Program for the BPT/B AT facility, it was dropped from the
analysis.
The initial pollutants of concern were the pollutants that were detected a minimum of three
times in the BPT/B AT facility raw waste stream. EPA applied a minimum number of times (3) for
detection as a rule of thumb so as to focus attention only on those pollutants likely to be present in
wastewater at Industrial Waste Combustor facilities. Pollutants not detected at least three times were
removed from the list of pollutants considered for regulation. Next, pollutants used as treatment
chemicals and pollutants known to be nutrients in water were also removed from the list for further
consideration. These pollutants are: ammonia as nitrogen, nitrate/nitrite, calcium, chloride, fluoride,
phosphorus, potassium, silicon, sodium, sulfur, total phosphorus, and total sulfide. These pollutants
are either added to the wastewater during treatment or are naturally present in the source water.
Additional pollutants were removed from the list of pollutants considered for regulation if the
average of the influent concentrations (with non-detect values set at the detection limit) was below
a treatable level in the BPT/BAT sampling episode. For most pollutants, the concentration was set
at 10 times the method detection limit. For aluminum, the concentration was set at 5 times the
method detection limit of 200ug/L because 200ug/L is a high method detection limit. Also, for lead,
the concentration was set at 3 times the detection limit of 50ug/l due to the toxicity of lead in water.
These pollutants are presented in Table 5-2.
Other pollutants were excluded from regulation because the technology option proposed was
not effective in treating the pollutant EPA applied the following test: if pollutant concentrations
increase across the treatment system or the pollutant concentrations decrease by an insignificant
amount, the pollutant was not considered effectively treated. These pollutants are listed in Table 5-3.
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Table 5-2. Pollutants Excluded from Regulation Due to the Concentration Detected for the
IVVC Industry
Pollutants
BOD
Hexavalent Chromium
Barium
Cobalt
Lithium
Magnesium
Nickel
Strontium
Thallium
Vanadium
Bis(2-ethylhexyl)Phthalate
N-Hexacosane
N-Octacosane
N-Triacontane
Table 5-3. Pollutants Excluded from Regulation Due to Ineffective Treatment for the IWC
Industry
Pollutants
Boron
Manganese
MCPP
Finally, pollutants were excluded from further consideration for regulation if they are
indirectly controlled through regulation of other pollutants by the proposed regulations. These
pollutants are listed in Table 5-4.
After evaluating all of these factors, the Agency selected 11 pollutants for regulation. The
final list of pollutants to be regulated is presented in Table 5-5.
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Table 5-4. Pollutants Indirectly Controlled Through Regulation of Other Pollutants
Pollutants
Aluminum
Antimony
Iron
Molybdenum
Selenium
Tin
Table 5-5. Pollutants Selected for Regulation for the IWC Industry
Pollutants
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
pH
Silver
Titanium
Total Suspended Solids
Zinc
5.3
SELECTION OF POLLUTANTS TO BE REGULATED FOR PSESAND PSNS
Indirect dischargers in the IWC Industry send their wastewater streams to a POTW for further
treatment, unlike direct dischargers, whose wastewater will receive no further treatment once it leaves
their facility. Therefore, the levels of pollutants allowable in the wastewater of an indirect discharger
are dependent upon: (1) whether a given pollutant "passes through" the POTW's treatment system
or (2) whether additional treatment provided by the POTW will result in removal of the pollutant to
a level equivalent to that obtained through treatment by a direct discharger.
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5.3.1 Pass-Through Analysis Approach
To establish PSES, EPA must first determine which of the IWC Industry pollutants of concern
(Identified earlier in this section) pass-through, interfere with, or are incompatible with the operation
of POTWs (including interferences with sludge disposal practices). EPA determines pollutant pass-
through by comparing the percentage removed by POTWs with the percentage removed by direct
dischargers using BPT/BAT technology. A pollutant "passes through" POTWs when the average
percentage removed by well-operated POTWs nationwide (those meeting secondary treatment
requirements) is less than the percentage removed by TWC direct dischargers complying with
BPT/BAT limitations for a given pollutant. EPA has assumed, for the purposes of this analysis and
based upon the data received, that the untreated wastewater at indirect discharge facilities is not
significantly different from direct discharge facilities.
This approach to the definition of pass-through analysis satisfies two competing objectives
set by Congress: (1) that standards for indirect dischargers be equivalent to standards for direct
dischargers and (2) that the treatment capability and performance of the POTW be recognized and
taken into account in regulating the discharge of pollutants from indirect dischargers. Rather than
compare the mass or concentration of pollutants discharged by the POTW with the mass or
concentration of pollutants discharged by a BAT facility, EPA compares the percentage of the
pollutants removed by the facility with the POTW removal. EPA takes this approach because a
comparison of mass or concentration of pollutants in a POTW effluent with pollutants in a BAT
facility's effluent would not take into account the mass of pollutants discharged to the POTW from
non-industrial sources, nor the dilution of the pollutants in the POTW effluent to lower
concentrations from the addition of large amounts of non-industrial wastewater.
5.3.2
50-POTW Study Database
For past effluent guidelines, a study of 50 well-operated POTWs was used for the pass-
through analysis. This study is referred to as the "The Fate of Priority Pollutants in Publicly Owned
Treatment Works", September 1982 [EPA 440/1-82/303]. Because the data collected for evaluating
POTW removals included influent levels of pollutants that were close to the detection limit, the
5-8
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POTW data were edited to eliminate influent levels less than 10 times the minimum level and the
corresponding effluent values, except in the cases where none of the influent concentrations exceeded
10 times the minimum level. In the latter case, where no influent data exceeded 10 times the
minimum level, the data were edited to eliminate influent values less than 5 times the minimum level.
Further, where no influent data exceeded 5 times the minimum level, the data were edited to eliminate
influent values less than 20 ug/1 and the corresponding effluent values. These editing rules were used
to allow for the possibility that low POTW removal simply reflected the low influent levels.
EPA then averaged the remaining influent data and also averaged the remaining effluent data
from the 50-POTW database. The percent removals achieved for each pollutant was determined from
these averaged influent and effluent levels. This percent removal was then compared to the percent
removal for the BAT option treatment technology.
5.3.3
REEL Treatability Database
Due to the large number of pollutants considered for this industry, additional data from the
EPA Risk Reduction Engineering Laboratory (RREL) Treatability Database were used to supplement
the 50-POTW Study data. (The EPA Risk Reduction Engineering Laboratory is now called the
National Risk Management Research Laboratory (NRMRL). The editing rules used for the POTW
database needed to be modified due to the organization of the RREL database.
For each of the pollutants of concern not found in the 50-POTW database, data from the
liquid waste portions of the RREL Treatability Database were obtained. These files were edited so
that only treatment technology data for activated sludge (including secondary clarification), aerobic
lagoons, and activated sludge (including secondary clarification) with filtration were used. These
technologies are representative of typical POTW secondary treatment options. The files were further
edited to include only information pertaining to domestic or industrial wastewater, unless only other
types of wastewater data were available. Only full-scale or pilot-scale data were used; bench-scale
data were edited out. Only data from a paper in a peer-reviewed journal or government report or
database were retained; all lesser-quality references were not used. Additionally, the retained
references were reviewed and non-applicable study data were accordingly eliminated. Because the
database is organized into groupings of influent values, the influent editing rules used for the 50-
5-9
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POTW Study database could not be applied here. From the remaining pollutant removal data, the
average percent removal for each pollutant was calculated.
5.3.4
Final POTW Data Editing
For each pollutant, the edited percent removals from the 50-POTW Study and RREL
Treatability Database were compared. The final percent removal for each pollutant was selected
based on a data hierarchy, which was related to the quality of the data source. This hierarchy was:
1. 50-POTW Study Data (lOx NOMDL edit)
2. 50-POTW Study Data (5x NOMDL edit)
3. 50-POTW Study Data (20ug/l edit)
4. RREL Treatability Data (domestic wastewater only edit)
5. RREL Treatability Data (domestic and industrial wastewater edit).
The final POTW removals for the IWC Industry pollutants, determined via the data use
hierarchy, are presented in Table 5-6.
Table 5-6. Final POTW Removals for IWC Industry Pollutants
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Silver
Titanium
Zinc
CAS
Number
7440382
7440439
7440473
7440508
7439921
7439976
7440224
7440326
7440666
Removal
Percent
66
90
82
90
85
90
59
79
81
Source of Data
50-POTW - (20ug/l edit)
50-POTW - (lOx NOMDL edit)
50-POTW - (lOx NOMDL edit)
50-POTW - (lOx NOMDL edit)
50-POTW - (lOx NOMDL edit)
50-POTW - (lOx NOMDL edit)
50-POTW - (20ug/l edit)
RREL - (domestic wastewater edit)
50-POTW - (lOx NOMDL edit)
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5.3.5 Final Pass-Through Analysis Results
For each IWC pollutant in each option, the daily removals were calculated using the
BPT/BAT data. Then, the average overall BPT/BAT removal was calculated for each pollutant from
the daily removals. The averaging of daily removals is appropriate for this industry as BPT/BAT
treatment technologies typically have retention times of less than one day. For the final pass-through
analysis, the final POTW removal data determined for each IWC pollutant was compared to the
percent removal achieved for that pollutant using the BPT/BAT option treatment technologies. Of
the nine pollutants regulated under BPT/BAT, all were found to pass through for Regulatory Options
A and B and are proposed for PSES. The final pass through analysis results for the IWC Options are
presented in Table 5-7.
Table 5-7. Final Pass-Through Results for IWC Industry Options A and B
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Silver
Titanium
Zinc
Option Removal
(Percent)
A
99
94
95
99
99
91
91
99
99
B
98
98
95
99
99
97
98
99
99
POTW
Removal
(Percent)
66
90
82
90
85
90
59
79
81
Final Pass-Through
A
YES
YES
YES
YES
YES
YES
YES
YES
YES
B
YES
YES
YES
YES
YES
YES
YES
YES
YES
5-11
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SECTION 6
WASTEWATER TREATMENT TECHNOLOGIES
This section describes the technologies available for the treatment of wastewater generated
by the 84 commercial facilities within the Industrial Waste Combustor (IWC) Industry. This section
also presents an evaluation of performance data on treatment systems collected by EPA during field
sampling programs and the rationale used in the development of the proposed regulatory options.
Specifically, Section 6.1 describes the technologies used by commercial IWC facilities to treat air
pollution control, flue gas quench, and ash/slag quench wastewaters, which are the only types of
wastewater proposed for regulation. Section 6.2 describes technologies used by commercial IWC
facilities for the treatment of wastewater generated as a result of IWC operations (e.g. container wash
water and truck wash water) for which EPA is not proposing regulations. Section 6.3 lists
technologies used by commercial IWC facilities for the treatment of wastewater generated as a result
of other operations on-site (e.g. landfill leachate and sanitary water). Section 6.4 presents the EPA
performance data on selected treatment technologies, as well as, the rationale used in selecting the
treatment technologies for the regulatory options.
Of the 84 commercial IWC facilities, 39 facilities generate no wastewater. A breakdown of
the types of wastewaters collected at the remaining 45 commercial IWC facilities which generate
wastewater is as follows:
Type of wastewater collected
Number of commercial IWC facilities
IWC wastewaters only 8
(air pollution control, ash/slag quench, flue gas quench)
wastewaters generated from IWC operations only 7
(container, area, and truck wash waters)
other on-site wastewaters only 9
(sanitary wastewater, leachates)
IWC wastewaters and wastewaters generated from
IWC operations 15
IWC wastewaters, wastewaters generated from IWC operations,
and other on-site wastewaters 3
wastewaters generated from IWC operations and other on-site
wastewaters 3
6-1
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As demonstrated above, only 26 of the 84 commercial IWC facilities generate IWC
wastewaters and therefore, were considered to be within the scope of this proposed regulation.
6.1
AVAILABLE BAT AND PSES TECHNOLOGIES
Commercial IWC facilities use either physical/chemical treatment technology to treat IWC
wastewaters or treatment and disposal methods that result in no discharge of IWC wastewaters.
Through its CWA Section 308 Questionnaire, EPA obtained information on nine different
wastewater treatment technologies currently in use by the 26 commercial IWC facilities for the
treatment of air pollution control, flue gas quench, and ash/slag quench wastewater. In addition, EPA
collected other detailed information on available technologies.from engineering plant visits to a
number of IWC facilities. The data presented in Section 6.4 are based on these data collection
activities.
6.1.1
Physical/Chemical Treatment
6.1.1.1
Equalization
Wastewater generation rates at incinerators are sometimes variable due to variations in bum
rates and system down times. To allow for the equalization of pollutant loadings and flow rates,
IWC wastewaters may be collected in tanks or lined ponds prior to treatment. These are designed
with sufficient capacity to hold the peak flows and thus dampen the variation in hydraulic and
pollutant loads. Minimization of this variability increases the performance and reliability of down
stream treatment systems, and can reduce the size of subsequent treatment by reducing the maximum
flow rates and concentrations of pollutants that they will experience. Equalization also lowers the
operating costs of associated treatment units by reducing instantaneous treatment capacity demand
and by optimizing the amount of treatment chemicals required for a less erratic set of treatment
variables. TheEPA's Section 308 Questionnaire database identifies 12 facilities that use equalization
technology as part of their treatment of IWC wastewaters.
6-2
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Equalization systems consist of steel or fiberglass holding tanks or lined ponds that provide
sufficient capacity to contain peak flow conditions and wastewater volumes of high pollutant
loadings. Detention times can vary from a few hours to several days, with one day being a typical
value. Some equalization systems contain mechanical mixing systems that enhance the equalization
process.
A breakdown of equalization systems used is as follows:
Equalization Type
Unstirred
Mechanically stirred
Number of Units
8
4
A typical equalization system is shown in Figure 6-1.
6.1.1.2
Neutralization or pH Control
In the treatment of IWC wastewaters, neutralization or pH control systems are used in
conjunction with certain chemical treatment processes, such as chemical precipitation, to adjust the
pH of the wastewater to optimize process control. Acids, such as sulfuric acid or hydrochloric acid,
are added to reduce pH, whereas, alkalis, such as sodium hydroxides, are added to raise pH values.
Neutralization may be performed in a holding tank, rapid mix tank, or an equalization tank.
Neutralization systems are widely used at IWC facilities for pH control in chemical precipitation
systems. Chemicals, such as sodium hydroxide or lime, are frequently used in order to raise the pH
of the wastewater to a range somewhere between 9 to 12 in order to optimize precipitation of metal
compounds. Acids, such as hydrochloric acid, is also used in conjunction with ferric chloride for
chemical precipitation. Neutralization systems at the end of a treatment system are typically designed
to control the pH of the discharge to between 6 and 9. There are 16 neutralization systems in place
among the commercial IWC facilities that use various caustic and/or alkalis to treat IWC
wastewaters. A breakdown of these neutralization systems is as follows:
6-3
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Wastewater
Influent
Equalization Tank
Equalized
Wastewater
Effluent
Figure 6-1. Equalization
6-4
-------
Type of Neutralization
Caustic
Lime
Acid
Multiple chemicals
Other
Number of Units
5
1
3
6
1
Figure 6-2 presents a flow diagram for a typical neutralization system.
6.1.1.3 Flocculation
Flocculation is a treatment technology used to enhance sedimentation or filtration treatment.
Flocculation precedes these processes and consists usually of a rapid mix tank, or in-line mixer and
a flocculation tank. The waste stream is initially mixed while a flocculation chemical is added.
Flocculants adhere readily to suspended solids and each other to facilitate gravity sedimentation or
filtration. Coagulants can be added to reduce the electrostatic surface charges and enhance the
formation of complex hydrous oxides. Coagulation allows for the formation of larger, heavier
particles, or flocculants (which are usually formed in a flocculation chamber), that can settle faster.
There are three different types of flocculants commonly used; inorganic electrolytes, natural organic
polymers, and synthetic polyelectrolytes. The selection of the specific treatment chemical is highly
dependent upon the characteristics and chemical properties of the contaminants. A rapid mix tank
is usually designed for a detention time ranging from 15 seconds to several minutes. After mixing, the
coagulated wastewater flows to a flocculation basin where slow mixing of the waste occurs. The
slow mixing allows for the particles to agglomerate into heavier, more settleable solids. Mixing is
provided either by mechanical paddle mixers or by diffused air. Flocculation basins are typically
designed for a detention time of 15 to 60 minutes. There are seven flocculation systems used among
the commercial IWC facilities used to treat IWC wastewaters.
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Wastewater
Influent
Neutralization Tank
Acid
Caustic
pH monitor/control
Neutralized
Wastewater
Effluent
Figure 6-2 Neutralization
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6.1.1.4
Gravity-Assisted Separation
Gravity-assisted separation is a simple, economical, and widely used method for the treatment
of IWC wastewaters. There are 14 such systems in place at the commercial IWC facilities.
Clarification systems remove suspended matter by allowing the wastewater to become quiescent. As
a result; suspended matter, which is heavier than water, settles to the bottom, forming a sludge which
can be removed. This process may take place in specially designed tanks, or in earthen ponds and
basins. Sedimentation units at IWC facilities are typically used as either primary treatment options
to remove suspended solids or following a chemical precipitation process.
Clarifiers may be rectangular, square, or circular in shape. In rectangular tanks, wastewater
flows from one end of the tank to the other with settled sludge collected into a hopper located at one
end of the tank. In circular tanks, flow enters from the center and flows towards the outside edge
with sludge collected in a center hopper. Treated wastewater exits the clarifier by flowing over a weir
located at the top of the clarifier. Sludge which accumulates in the bottom of the clarifiers is
periodically removed and iS'typically stabilized and/or dewatered prior to disposal.
Flocculation systems are commonly used in conjunction with gravity assisted clarification
systems in order to improve their solids removal efficiency. Some clarifiers are designed with a center
well to introduce flocculants and allow for coagulation in order to improve removal efficiencies. A
schematic of atypical clarification system using coagulation and flocculation is shown in Figure 6-3.
The main design parameters used in designing a clarifier are the overflow rate, detention time and the
side water depth. The overflow rate is the measure of the flow as a function of the surface area of
the clarifier. Typical design parameters used for both primary and secondary clarifiers are presented
below:
Design Parameter Primary
Overflow rate, gpd/sq ft 600-1,000
Detention time, min 90-150
Minimum Side water depth, ft 8
Secondary
500-700
90-150
10
Source: ASCE/WEF, Design ofMunicipal Wastewater Treatment Plants, 1991.
There are three facilities that use corrugated plate interceptor technology. These systems
include a series of small (approximately 2 inch square) inclined tubes in the clarification settling zone.
The suspended matter must only travel a short distance, when settling or floating, before they reach
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Coagulant
Influent
Clarffier
Rapid Mix
Tank
Flocculating
Tank
Effluent
*- Sludge
Figure 6-3: Clarification System Incorporating Coagulation and Flocculation
6-8
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a surface of the tube. At the tubes' surface, the suspended matter further coagulate. Because of the
enhanced removal mechanism, corrugated plate interceptor units can have much smaller settling
chambers than standard clarifiers.
6.1.1.5 Chemical Precipitation
Chemical precipitation is used for the removal of metal compounds from wastewater. In the
chemical precipitation process, soluble metallic ions and certain anions, which are found in IWC
«r
wastewaters, are converted to insoluble forms, which precipitate from the solution. Most metals are
relatively insoluble as hydroxides, sulfides, or carbonates. Coagulation processes are used in
conjunction with precipitation in order to facilitate removal by agglomeration of suspended and
colloidal materials. The precipitated metals are subsequently removed from the wastewater stream
by liquid filtration or clarification (or some other form of gravity assisted sedimentation). Other
treatment processes such as equalization, chemical oxidation or reduction (e.g., hexavalent chromium
reduction), precede the chemical precipitation process. The performance of the chemical precipitation
process is affected by chemical interactions, temperature, pH, solubility of waste contaminants, and
mixing effects. There are a total of nine chemical precipitation systems in use by the commercial IWC
facilities to treat IWC wastewater.
Common precipitation chemicals used in the IWC industry include lime, sodium hydroxide,
soda ash, sodium sulfide, and alum. Other chemicals used in the precipitation process for pH
adjustment and/or coagulation include sulfuric and phosphoric acid, ferric chloride, and
poly electrolytes. Many facilities use, or have the means to use, a combination of these chemicals.
Precipitation using sodium hydroxide or lime is the conventional method of removing metals from
wastewater. However, sulfide precipitation is also frequently used instead of hydroxide precipitation
in order to remove certain metal ions. Hydroxide precipitation is effective in removing such metals
as antimony, arsenic, chromium, copper, lead, mercury, nickel, and zinc. Sulfide precipitation is more
appropriate for removing mercury, lead, and silver. Carbonate precipitation, while not frequently
used in the Incinerator industry, is another method of chemical precipitation and is used primarily to
remove antimony and lead. Alum, another precipitant/coagulant agent infrequently used, forms
aluminum hydroxides in wastewaters containing calcium or magnesium bicarbonate alkalinity.
6-9
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Aluminum hydroxide is an insoluble gelatinous floe which settles slowly and entraps suspended
materials. For metals such as arsenic and cadmium, coprecipitation with iron or aluminum is an
effective treatment process.
Hydroxide precipitation using lime or sodium hydroxide is the most commonly used means
of chemical precipitation in the Incinerator industry, and of these, lime is used more often than sodium
hydroxide. The chief advantage of lime over caustic is its lower cost. However, lime is more difficult
to handle and feed, as it must be slaked, slurried, and mixed, and can plug the feed system lines. Lime
precipitation also produces a larger volume of sludge. The reaction mechanism for precipitation of
a divalent metal using lime is shown below:
Ca(OH)2 - M(OH)2 + Ca+
The reaction mechanism for precipitation of a divalent metal using sodium hydroxide is as
follows:
2NaOH -* M(OH)2
In addition to the type of treatment chemical chosen, another important design factor in the
chemical precipitation operation is pH. Metal hydroxides are amphoteric, meaning that they can react
chemically as acids or bases. As such, their solubilities increase toward both lower and higher pH
levels. Therefore, there is an optimum pH for precipitation for each metal, which corresponds to its
point of minimum solubility. Another key consideration in a chemical precipitation application is the
detention time in the sedimentation phase of the process, which is specific to the wastewater being
treated and the desired effluent quality.
The first step of a chemical precipitation process is pH adjustment and the addition of
coagulants. This process usually takes place in separate mixing and flocculation tanks. After mixing
the wastewater with treatment chemicals, the resultant mixture is allowed to agglomerate in the
flocculation tank which is slowly mixed by either mechanical means, such as mixers, or recirculation
pumping. The wastewater then undergoes a separation/dewatering process such as clarification or
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filtration, where the precipitated metals are removed from solution. In a clarification system, a
flocculent, such as a polymer, is sometimes added to aid in the settling process. The resulting sludge
from the clarifier or filter must be further treated, disposed, or recycled. A typical chemical
precipitation system is shown in Figure 6-4.
6.1.1.6
Stripping
Stripping refers to the removal of pollutant compounds from a wastewater by the passage of
air, steam, or other gas, through the liquid. The stripped volatile components are generally condensed
and recovered for reuse, disposal, or allowed to be stripped into the atmosphere. If the pollutants
are in sufficiently low concentrations, the gaseous phase can be emitted through a stack without
treatment.
Air stripping is a process in which air is brought into contact with the liquid. During this
contact, the volatile compounds move from the liquid to the gas stream. The process usually takes
place in a stripping tower (as shown in Figure 6-5) which consists of a vertical shell filled with
packing material to increase the surface area for gas-liquid contact. Usually, the liquid flows down
through the stripping column and air passes upward in a counter-current fashion. Another orientation
is called "crossflow", where the air is pulled through the sides of the tower along its entire length.
There is only one commercial IWC facility that use air stripping as a treatment option for the
removal of excess treatment chemicals contained in its flue gas quench wastewater.
6.1.1.7
Filtration
Filtration is a method for separating solid particles from wastewaters through the use of a
porous medium. The driving force in filtration is a pressure gradient, caused by gravity, centrifugal
force, vacuum, or higher than atmospheric pressure. Filtration treatment processes can be used at
IWC facilities to remove solids from wastewaters after a chemical precipitation treatment step, or can
used as the primary source of treatment. Filtration processes include a broad range of media and
membrane separation technologies from sand filtration to ultrafiltration. To aid in removal, the filter
medium may be precoated with a filtration aid such as ground cellulose or diatomaceous earth.
6-11
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Wastewater
Influent
Chemical Precipitation Tank
Figure 6-4. Chemical Precipitation System Design
6-12
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Wastewater
Influent
Air
Blower
Off-gas
Distributor
Packing
Treated
Effluent
Figure 6-5. Typical Air Stripping System
6-13
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Commercial IWC facilities currently have the following types of filtration systems in operation
to treat their IWC wastewaters:
Type of Filtration System Number of Units
Sand 3
Granular multimedia 1
Fabric 1
Ultrafiltration 1
Dissolved compounds in IWC wastewaters can be pretreated by chemical precipitation
processes to convert the compound to an insoluble solid particle before filtration. Polymers can be
injected into the filter feed piping downstream of feed pumps to enhance flocculation of smaller floccs
that may escape an upstream clarifier.
The following paragraphs describe each type of filtration system.
6.1.1.7.1 Sand/Multimedia Filtration
Granular bed filtration in the IWC industry is used primarily for achieving supplemental
removal of residual suspended solids from the effluent of chemical treatment processes, or rarely, as
the primary form of wastewater treatment. These filters can be operated either by gravity or in a
pressure vessel. In granular bed filtration, the wastewater stream is sent through a bed containing one
or more layers of different granular materials. The solids are retained in the voids between the media
particles while the wastewater passes through the bed. Typical media used in granular bed filters
include anthracite coal, sand, and garnet. These media can be used alone, such as in sand filtration,
or in a multimedia combination. Multimedia filters are designed such that the individual layers of
media remain fairly discrete. This is accomplished by selecting appropriate filter loading rates, media
grain size, and bed density. Hydraulic loading rates for a multi-media filter is between 4 to 10 gpm/sq
ft. A typical multimedia filter vessel is shown in Figure 6-6.
The complete filtration process involves two phases: filtration and backwashing. As the filter
becomes filled with trapped solids, the efficiency of the filtration process falls off. Head loss is a
measure of solids trapped in the filter. As the head loss across the filter bed increases to a limiting
6-14
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Coarse Media
Finer Media
Finest Media
Support
Underdrain Chamber
Wastewater Influent
Coal
Silica Sand
Garnet
Gravel
t
Treated Effluent
->- Backwash
Backwash
Figure 6-6: Multimedia Filtration
6-15
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value, the end of the filter run is reached and the filter must be backwashed to remove the suspended
solids in the bed. During backwashing, the flow through the filter is reversed so that the solids
trapped in the media are dislodged and can exit the filter. The bed may also be agitated with air to
aid in solids removal. The backwash water is then recycled back into the wastewater feed stream.
6.1.1.7.2
Fabric Filters
Fabric filters consist of a vessel that contains a cloth or paper barrier through which the
wastewater must pass. The suspended matter is screened by the fabric, and the effectiveness of the
filter depends on the mesh size of the fabric. Fabric filters may either be backwashed, or built as
disposable units.
For waters having less than 10 mg/1 suspended solids, cartridge fabric filters may be cost
effective. Cartridge filters have very low capital cost and can remove particles of one micron or
larger in size. Using two-stage cartridge filters (coarse and fine) in series extends the life of the fine
cartridge. Disposable or backwashable bag filters are also available and may be quite cost effective
for certain applications. Typically, these fabric filters act as a pre-filter and are used to remove
suspended solids prior to other filtrations systems in order to protect membranes and equipment and
reduce solids fouling.
6.1.1.7.3
Ultrafiltration
Ultrafiltration uses a semi-permeable, microporous membrane, through which the wastewater
is passed under pressure. Water and low molecular weight solutes, such as salts and surfactants, pass
through the membrane and are removed as permeate. Emulsified oils and suspended solids are
rejected by the membrane and removed with some of the wastewater as a concentrated liquid. The
concentrate is recirculated through the membrane unit until the flow of permeate drops, while the
permeate can either be discharged or passed along to another treatment unit. The concentrate is
usually stored and held for further treatment or disposal. Several types of Ultrafiltration membranes
configurations are available: tubular, spiral wound, hollow fiber, and plate and frame. A typical
Ultrafiltration system is presented in Figure 6-7.
6-16
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Wastewater
Feed
Permeate (Treated Effluent)
Membrane Cross-section
Concentrate
Figure 6-7. Ultrafiltration System Diagram
6-17
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Ultrafiltration in the IWC industry is used for the treatment of metal-bearing wastewaters.
It can remove substances with molecular weights greater than 500, including suspended solids, oil
and grease, and complexed heavy metals. Ultrafiltration is used when the solute molecules are greater
than ten times the size of the solvent molecules, and are less than one-half micron. The primary
design consideration in Ultrafiltration is the membrane selection. A membrane pore size is chosen
based on the size of the contaminant particles targeted for removal. Other design parameters to be
considered are the solids concentration, viscosity, and temperature of the feed stream, and the
membrane permeability and thickness.
6.1.1.8 Carbon Adsorption
Granular activated carbon adsorption (GAC) is a physical separation process in which organic
and inorganic materials are removed from wastewater by adsorption, attraction, and/or accumulation
of the compounds on the surface of the carbon granules. While the primary removal mechanism is
adsorption, the activated carbon also acts as a filter for additional pollutant removal. Adsorption
capacities of 0.5 to 10 percent by weight are typical. Spent carbon can be regenerated thermally on
site by processes such as wet-air oxidation or steam stripping. For smaller operations, spent carbon
can be regenerated off site or sent for directly for disposal. Vendors of carbon typically, under
contract, exchange spent carbon with fresh carbon.
Activated carbon systems usually consist of a vessel containing a bed of carbon (typically 4
to 12 feet in depth), whereby the wastewater is either passed upflow or downflow through the filter
bed. A carbon adsorption vessel is shown in Figure 6-8. Carbon vessels are typically operated under
pressure, however some designs use gravity beds. For smaller applications, GAC systems are also
available in canister systems which can be readily changed-out and sent for either off-site regeneration
or disposal. The key design parameter is the adsorption capacity of the GAC, which is a measure of
the mass of contaminant adsorbed per unit mass of carbon, and is a function of the chemical
compounds being removed, type of carbon used, and process and operating conditions. The volume
of carbon required is based upon the COD of the wastewater to be treated and desired frequency of
carbon change-outs. The vessel is typically designed for an empty bed contact time of 15 to 60
minutes. Non-polar, high molecular weight organics with low solubility are readily adsorbed using
6-18
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Fresh
Carbon
Fill
Collector/
Distributor
Spent
Carbon
Discharge
Wastewater
Influent
Backwash
Backwash
Treated
Effluent
Figure 6-8. Granular Activated Carbon Adsorption
6-19
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GAG. Certain organic compounds'have a competitive advantage for adsorption onto the GAG, which
results in compounds being preferentially adsorbed or causing other less competitive compounds to
be desorbed from the GAG. Most organic compounds and some metals typically found in IWC
wastewaters are effectively removed using GAG. Two commercial IWC facility employs GAG for
treatment of IWC wastewaters.
6.1.1.9
Chromium Reduction
Chemical reduction processes involve a chemical reaction in which electrons are transferred
from one chemical to another in order to reduce the chemical state of a contaminant. The main
application of chemical reduction in IWC wastewater treatment is the reduction of hexavalent
chromium to trivalent chromium. The reduction enables the trivalent chromium to be precipitated
from solution in conjunction with other metallic salts. Sodium bisulfate is the reducing agents used
by the one commercial IWC facility that incorporates reduction technology for treatment of its IWC
wastewater.
Once the chromium has been reduced to the trivalent state, it can be further treated in a
chemical precipitation process, where it is removed as a metal hydroxide or sulfide. A typical
chromium reduction process is shown in Figure 6-9.
6.1.2 Sludge Handling
Sludges are generated by a number of treatment technologies, including gravity-assisted
separation and filtration. These sludges are further processed at IWC facilities using various methods.
Listed below are the number of commercial IWC facilities which employ each type of sludge handling
process.
Type of Sludge Handling
Sludge Slurrying
Vacuum Filtration
Pressure Filtration
Centrifuge
Dryer
Number of Units
1
1
7
1
1
6-20
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Sulfuric
Acid
Treatment
Chemical
r~T
pH Controller
Wastewater
Influent
Chemical Controller
Reaction Tank
- Treated
Effluent
Figure 6-9. Chromium Reduction
6-21
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The following paragraphs describe each type of sludge handling system.
6.1.2.1 Sludge Slurrying
Sludge slunying is the process of transporting sludge from one treatment process to another.
It can only be applied to liquid sludges that can be pumped through a pipe under pressure. Only one
commercial IWC facility utilizes a sludge slurry process.
6.1.2.2
Vacuum FUtration
A typical vacuum filtration unit is shown in Figure 6-10. Vacuum filtration provides more
aggressive sludge drying by placing the sludge on a screen or mesh and drawing a vacuum through
the screen, which draws the liquid out of the sludge. Often the screen is oriented on a cylindrical
support, which rotates. The sludge is distributed over the cylinder as it rotates. As the screen
rotates, the dried sludge is removed with a scraper, and collected in a hopper placed below the
filtration unit. These units can dry sludges to approximately 30 to 50 percent solids. Only one
commercial IWC facility utilizes vacuum filtration for sludge dewatering.
6.1.2.3
Pressure Filtration
The plate and frame pressure filtration system is the most common process used by the IWC
industry to dewater sludges from physical/chemical treatment processes. Seven commercial IWC
facilities use a plate and frame pressure filtration system to dewater sludge. 'Sludges generated by
IWC wastewater treatment processes are typically 2 to 5 percent solids by weight. These sludges are
then dewatered to a 30 to 50 percent solids by weight using a plate and frame filter. Sludges from
treatment systems can be thickened by gravity or stabilized prior to dewatering, or may be processed
directly with the plate and frame pressure filtration unit..
A pressure filter consists of a series of screens (see Figure 6-11) upon which the sludge is
applied under pressure. A precoat material may be applied to the screens to aid in solids removal.
The applied pressure forces the liquid through the screen, leaving the solids to accumulate behind the
screen. Filtrate which passes through the screen media is typically recirculated back to the head of
6-22
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Filter Cake
Discharge
Hopper
Spray Wash
Figure 6-10. Vacuum Filtration
6-23
-------
Fixed End
Sludge
Influent
Filtrate
Filter Cloth
Filter Cake
Plate Assembly
Figure 6-11: Plate and Frame Pressure Filtration System Diagram
6-24
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the on-site wastewater treatment plant. Screens (also referred to as plates) are held by frames placed
side by side and held together with a vice-type mechanism. The unit processes sludge until all of the
plates are filled with dry sludge as indicated by a marked rise in the application pressure. Afterwards,
the vice holding the plates is loosened and the frames separated. Dried sludge is manually scraped
from the plates and collected in a hopper for final disposal. The size of the filter and the number of
plates utilized depends not only on the amount of solids produced by treatment processes, but also
is highly dependent on the desired operational requirements for the filter (e.g., shifts per day). A plate
and frame pressure filter can produce a sludge with a higher solids content than most other methods
of sludge dewatering. Pressure filters offer operational flexibility since they are typically operated in
a batch mode.
6.1.2.4
Centrifuges
Centrifuges use centripetal force to separate the liquid from the sludge solids. The sludge
enters the top of a rapidly spinning cylinder where the solids are "thrown" to the outer wall of the
vessel. The separated solids are continually removed through an orifice on the outer wall, and the
liquid stream is collected at the bottom.
Because the unit is spinning rapidly, and sludge often contains abrasive materials, centrifuges
often require a high level of maintenance. Centrifuges typically dry sludges to the range of 20 to 30
percent solids by weight. Only one commercial IWC facility utilizes a centrifuges for sludge
dewatering.
6.1.2.5
Dryer
One commercial IWC facility employs a sludge dryer to remove the moisture from its sludge
prior to disposal of the solid waste. The sludge dryer uses thermal energy derived from steam or
electricity to evaporate the moisture from the sludge in a drying bed/tank.
6-25
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6.1.3
Zero Discharge Options
Some IWC facilities use treatment and disposal practices that result in no discharge of IWC
wastewaters to surface waters. These practices are described below.
6.1.3.1
Incineration
Two commercial IWC facilities generate annual flow rates of 108,100 and 300,000 gallons
and dispose of their IWC wastewater exclusively by incinerating them on site. Normally, these
wastewater flows are minimal compared to the amount of fuel and/or waste the thermal unit handles,
and as such, these IWC facilities find it cheaper to dispose of their wastewaters in this fashion rather
than utilizing other disposal methods.
6.1.3.2
Off-Site Disposal
Three commercial IWC facilities transport their wastewater off site to either another IWC
facility's wastewater treatment system or to a Centralized Wastewater Treatment (CWT) facility for
ultimate disposal. These three facilities generate annual flow rates of 18,250 gallons, 10,000 gallons,
and 43 million gallons. A fourth facility with an annual flow rate of 4.865 million gallons sells their
wastewater as oil well completion fluid.
6.1.3.3 Evaporation/Land Applied
One commercial IWC facility with an annual flow rate of approximately 100 million gallons
discharges its IWC wastewater into on-site surface impoundments as a means of ultimate disposal.
There is no discharge to a receiving water from these impoundments. Rather, water is lost by
evaporation.
6.2
TREATMENT OPTIONS FOR OTHER WASTEWATERS GENERATED BY
IWC OPERATIONS
Commercial IWC facilities employ the same two treatment options (physical/chemical
treatment or zero discharge) to treat other wastewaters generated as a result of IWC operations (see
6-26
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Section 4). Most of the same treatment technologies are used to treat these secondary wastewaters
as are being used to treat IWC wastewaters. The EPA's Section 308 Questionnaire obtained
information on eight different technologies currently in use by 39 commercial IWC facilities for the
treatment of various wash down waters, run-off from IWC areas, and laboratory wastewater. A
breakdown of these treatment systems is shown below:
Treatment technology
Equalization
Neutralization
Flocculation
Gravity Assisted Separation
Chemical Precipitation
Air Stripping
Carbon Adsorption
Chemical Oxidation
Sludge Handling
Number of commercial IWC facilities
8
9
6
8
6
1
5
3
11
Each of the above treatment technologies, with the exception of chemical oxidation, has been
previously described in Section 6.1. As for IWC wastewaters, the design and operation of these
treatment systems to treat other wastewaters generated by IWC operations are the same. Since the
amount of wastewater generated by other IWC operations is minimal as compared to IWC
wastewater flow rates, these small flows are typically mixed with IWC wastewaters for treatment in
the physical/chemical treatment system. Below is a description of the only new treatment technology
listed above that was not described in the previous section: chemical oxidation.
6.2.1
Chemical Oxidation
Chemical oxidation treatment processes may be used to remove ammonia, to reduce the
concentration of residual organics, and to reduce the bacterial and viral content of wastewaters. IWC
facilities that use chemical oxidation processes use them for the treatment of other out-of-scope
wastewaters generated at these facilities, such as landfill leachate, storm water, groundwater, or
sanitary wastewater. Both chlorine and ozone can be used to destroy some residual organics in
6-27
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wastewater. When these chemicals are used for this purpose, disinfection of the wastewater is usually
an added benefit A further benefit of using ozone is the removal of color. Ozone can also be
combined with hydrogen peroxide for removing organic compounds in contaminated wastewater.
Oxidation is also used to convert pollutants to terminal end products or to intermediate products that
are more readily biodegradable or more readily removed by adsorption. There are three commercial
IWC facilities that use chemical oxidation units as part of their treatment process to treat secondary
IWC wastewaters.
Chemical oxidation is a chemical reaction process in which one or more electrons are
transferred from the chemical being oxidized to the chemical initiating the transfer (the oxidizing
agent). The electron acceptor may be another element, including an oxygen molecule, or it may be
a chemical species containing oxygen, such as hydrogen peroxide and chlorine dioxide or some other
electron acceptor. This process is also effective in destroying cyanide and toxic organic compounds.
Figure 6-12 illustrates one such chemical oxidation process. According to the Section 308
Questionnaire data, IWC facilities use chemical oxidation processes to treat organic pollutants and
as a disinfectant When treating organic wastes, these processes use oxidizing chemicals, such as
hydrogen peroxide, or ozone. As a disinfection process, an oxidant (usually chlorine) is added to the
wastewater in the form of either chlorine dioxide or sodium hypochlorite. Other disinfectant
chemicals include ozone, peroxide, and calcium hypochlorite. Once the oxidant is mixed with the
wastewater, sufficient detention time is allowed (usually 30 minutes) for the disinfecting reactions to
occur.
6.2.2 Zero Discharge Options
Other rWC facilities use treatment and disposal practices that result in no discharge of their
secondary IWC wastewaters to surface waters. A breakdown of the zero discharge options for
secondary IWC wastewaters at commercial IWC facilities is as follows:
Zero discharge option Number of commercial IWC facilities
Incineration 2
Off-site disposal 5
6-28
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Caustic Feed
Hypochlorite or Chlorine Feed
Wastewater
Influent
Acid Feed
"-H-.
Treated
Effluent
First Stage
Second Stage
Figure 6-12. Cyanide Destruction
6-29
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Evaporated/land applied 2
Recycled 3
Deep well disposal 2
Most of the above zero discharge options, with the exception of deep well disposal, have
been described previously in section 6.1.3. Below is a description of the only new zero discharge
option listed above that was not described in the previous section; deep well disposal.
6.2.2.1 Deep Well Disposal
Deep well disposal consists of pumping the wastewater into a disposal well which discharges
the liquid into a deep aquifer. These aquifers do not typically contain potable water and commonly
are brackish. These aquifers are thoroughly characterized to insure that they are not
hydrogeologically connected to an aquifer which is or has the potential to be used for potable water.
Characterization confirms the existence of impervious layers of rock above and below the aquifer in
order to prevent the migration of pollutants.
6.3 OTHER ON-SITE WASTEWATER TREATMENT TECHNOLOGIES
There are other treatment technologies used by commercial IWC facilities to treat other on-
site wastewaters Qeachates, sanitary wastewater). Some facilities may use one or more of the
technologies described above for the treatment of these wastewaters. Four commercial IWC
facilities use some form of biological treatment as the preferred method of treatment of leachates and
other organic wastewaters. The biological treatment technologies used at these IWC facilities are
listed below:
Treatment technology Number of Facilities
Activated sludge 1
Trickling filter 1
PAC system (powdered activated carbon) 2
6-30
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6.4
TREATMENT PERFORMANCE AND DEVELOPMENT OF REGULATORY
OPTIONS
This section presents an evaluation of performance data on treatment systems collected by
EPA during field sampling programs and the rationale used in the development of the proposed
regulatory options.
6.4.1
Performance of EPA Sampled Treatment Processes
To collect data on potential BAT treatment technologies, Questionnaire responses were
reviewed to identify candidate facilities that had well operated and designed wastewater treatment
systems. EPA conducted site visits to 13IWC facilities to evaluate treatment systems; based on these
site visits, three facilities were selected for a five consecutive day sampling episode (Episode ED #s
4646,4671, and 4733). Atthese facilities, EPA collected data on a variety of physical and chemical
treatment processes. Technologies evaluated at the selected sampling facilities include hydroxide
precipitation, sulfide precipitation, sedimentation, carbon adsorption, sand filtration and ultrafiltration.
Table 6-1 presents a summary of the treatment technologies sampled during each EPA sampling
episode. Summaries of the treatment system performance data collected by EPA during each of these
sampling episodes are presented below.
6.4.1.1
Treatment Performance for Episode #4646
EPA performed a week-long sampling program, episode # 4646. This facility was evaluated
by EPA in order to obtain performance data on several treatment technologies installed at this facility
including hydroxide precipitation, ferric chloride precipitation, and sand filtration. A flow diagram
of the IWC wastewater treatment system sampled during episode # 4626 is presented in Figure 6-13.
The wastewater treatment system used at this IWC facility treats wastewater from the air pollution
control system (quench chamber run-down and packed tower wastewater) and the ionizing wet
scrubber. The wastewater treatment system is comprised of two separate systems both of which were
sampled by EPA. The primary system is part of the primary water circulation loop that serves the
incinerator and consists of chromium reduction and hydroxide precipitation treatment followed by
6-31
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6-33
-------
sedimentation. Only the precipitation portion of the primary system was sampled by EPA.
Slowdown from the primary loop is treated in the secondary system. Treatment in the secondary
loop consists of precipitation using ferric chloride followed by sedimentation and sand filtration.
Table 6-2 presents a summary of percent removal data collected at episode #4646 for the
performance of the entire treatment system, both the primary and secondary system, as well as the
primary system, secondary system, and sand filter separately. Percent removal efficiencies for the
processes were calculated by first obtaining an average concentration based upon the daily sampling
results for each sample collection location (influent and effluent point to the treatment process).
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Percent Removal = [Concentration Influent - Concentration Effluent] xlOO
Concentration Influent
Negative percent removals for a treatment process were reported on the table as "0.0" percent
removals.
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sampling points 01, 02, and 04 (see Figure 6-13). Influent concentration data was obtained using
a flow-weighted average for sample points 01 and 02. Effluent from the primary treatment system
was represented by sample point 04. As demonstrated on the Table 6-2, the primary treatment
system experienced good overall removals for TSS (90.9 percent). COD was removed at 70.9
percent, whereas, no removal was observed for TDS. Many of the metals observed in the influent
were removed to high levels; these include aluminum, cadmium, chromium, copper, iron, lead, tin,
titanium, and zinc. Other metals also with limited removals include manganese (66.5 percent),
mercury (63.9 percent), silver (40.3 percent), and strontium (19.7 percent). Poor removal efficiencies
were observed for in the primary system for antimony, arsenic, boron, molybdenum, and selenium.
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sampling points 04 and 05 (see Figure 6-13). Influent concentration data to the secondary system
was obtained using sampling point 04 which is also the effluent from the primary system. Effluent
from the secondary treatment system was represented by sample point 05. As demonstrated on the
6-34
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Table 6-2, the secondary treatment system experienced no additional removals for TSS or COD. As
in the primary system, no removal was observed for TDS. For those metals for which there was little
or no removal in the primary system, improved removals were generally observed in the second
system. These metals include antimony (62.9 percent), arsenic (98.2 percent), selenium (81.1
percent), and silver (94.4 percent). Other metals for which adequate removals were observed in the
primary system also experienced additional removals in the secondary system. The data show the
following removals: cadmium (72.9 percent), chromium (81.3 percent), copper (94.2 percent),
mercury (87.7 percent), and titanium (88.2 percent).
The treatment efficiency of the sand filter was evaluated using the data obtained from
sampling points 05 and 06 (see Figure 6-13). Influent concentration data was obtained using sample
point 05 which represents the discharge from the secondary treatment system. Effluent from the sand
filter, as well as, the overall effluent from the treatment process was represented by sample point 06.
As demonstrated on the Table 6-2, the treatment system achieved a removal rate for TSS of 59.0
percent. No removals were observed for COD or TDS. Additional metals were removed by the sand
filter including cadmium, copper, iron, selenium, silver, and zinc. Limited additional removals were
also observed for aluminum and mercury.
The treatment efficiency of the entire treatment system was evaluated using the data obtained
from sampling points 01, 02, and 06 (see Figure 6-13). Influent concentration data was obtained
using a flow-weighted average for sample points 01 and 02. Effluent from the treatment system was
represented by sample point 06. As demonstrated on the Table 6-2, the treatment system achieved
good overall removal for TSS (95.5 percent). COD was removed at 51.9 percent, whereas, no
removal was observed for TDS. Many of the metals observed in the influent were removed to levels
exceeding 95 percent removal. These include arsenic, cadmium, chromium, copper, iron, lead,
mercury, silver, tin, titanium, and zinc. Other metals also with high removals include aluminum (85.5
percent) and selenium (89.1 percent). Overall poor removal efficiencies were observed for antimony
(48.5 percent) and molybdenum (38.0 percent). No removals were observed for the treatment system
for boron, manganese, and strontium. Dichloroprop, a pesticide parameter, was detected in the
influent in low levels and was not detected in the effluent. MCPP did not experience any removal
through the treatment system.
6-37
-------
6.4.1.2
Treatment Performance for Episode #4671
EPA performed a week-long sampling program, episode #4671. This facility was evaluated
by EPA to obtain performance data on various treatment units which are in operation at this facility,
including a combination sulfide and hydroxide precipitation process, conventional hydroxide
precipitation, and ultrafiltration. A flow diagram of the IWC wastewater treatment system sampled
during episode # 4671 is presented in Figure 6-14. The wastewater treatment system used at this
IWC facility treats wastewater from the air pollution control system. The air pollution control system
consists of a quench tank, packed tower, and a venturi scrubber. The wastewater treatment system
is comprised of two separate systems both of which were sampled by EPA. The primary system is
part of the primary water circulation loop that serves the incinerator. Treatment processes for the
primary system consists of sulfide precipitation using ferrous sulfate followed by hydroxide
precipitation using sodium hydroxide and lime and then followed by sedimentation. The facility treats
the discharge from the primary loop in the secondary system. Treatment in the secondary loop
consists of hydroxide precipitation using sodium hydroxide followed by sedimentation and
ultrafiltration. Table 6-3 presents a summary of percent removal data collected at episode #4671 for
the performance of the entire treatment system, both the primary and secondary system, and for the
primary system only.
The treatment efficiency of the primary treatment system was evaluated using the data
obtained from sampling points 01 and 02 (see Figure 6-14). Influent concentration data for the
primary system was obtained using sample point 01. Effluent from the primary treatment system was
represented by sample point 02. As demonstrated on Table 6-3, the primary treatment system
removal rate for TSS was 70.6 percent. COD was removed at 12.3 percent, whereas, TDS was
removed at 7.8 percent. Metals with high removal rates in the primary system include: aluminum
(83.1 percent), chromium (97.4 percent), copper (72.0 percent), iron (93.4 percent), lead (90.4
percent), and titanium (95.1 percent). The system achieved limited removals for other metals through
the primary system. These include boron, cadmium, manganese, mercury, tin, and zinc. Poor to no
removals were observed for antimony, arsenic, molybdenum, silver, and strontium. However,
influent concentrations to the primary treatment system for some metals, such as arsenic, cadmium,
6-38
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6-41
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silver, and zinc, were low or not detected. Therefore, the influent concentrations for these parameters
are close to the treatability levels using chemical precipitation, making it difficult to achieve additional
removals for these pollutants. For example, cadmium was found in the influent and effluent of the
primary treatment system at concentrations of 4.2 ug/1 and 2.4 ug/1, respectively. This resulted in a
percent removal of only 43.1 percent. Therefore, the low percent removal efficiency is a function of
the low influent concentration (near treatability levels) and not indicative of poor performance...
The treatment efficiency of the secondary treatment system was evaluated using the data
obtained from sampling points 02 and 03 (see Figure 6-14). Influent concentration data to the
secondary system was obtained using sample point 02, which is the effluent from the primary system.
Effluent from the secondary treatment system was represented by sample point 03. As demonstrated
on the Table 6-3,1he secondary treatment system removal rate for TSS was 80.5 percent. COD was
removed at 32.0 percent, whereas, IDS was removed at 4.9 percent. Metals with high removal rates
or removed to non-detectable levels in the secondary system include; aluminum, cadmium, chromium,
lead, manganese, mercury, silver, tin, and zinc. Limited additional removals were observed for
copper and iron. Poor removals were observed in the secondary system for antimony, boron,
molybdenum, and strontium.
The treatment efficiency of the entire treatment system, both primary and secondary treatment
system, was evaluated using the data obtained from sampling points 01 and 03 (see Figure 6-14).
Influent concentration data was obtained using sample point 01. Effluent from the entire treatment
system was represented by sample point 03. As demonstrated on the Table 6-3, the treatment system
achieved good overall removals for TSS (94.3 percent). COD was removed at 40.3 percent,
whereas, TDS was removed at 12.3 percent. Selenium, dichloroprop, and MCPP were not detected
in the influent or effluent Many of the metals observed in the influent were removed to levels
exceeding 95 percent removal; these include aluminum, chromium, iron, lead, manganese, and
titanium. Other metals also with high removals or removed to non-detectable levels include cadmium
(90.7 percent), copper (84.5 percent), mercury (69.9 percent), silver (64.1 percent), and tin (42.8
percent). Poor removal efficiencies were observed for the entire treatment system for antimony (14.4
percent), boron (37.9 percent), molybdenum (14.6 percent), and strontium (4.8 percent). Arsenic
was observed at below treatable levels throughout the system.
6-42
-------
6.4.1.3 Treatment Performance for Episode #4733
EPA performed a week-long sampling program, episode #4733. This facility was evaluated
by EPA to obtain performance data on various treatment units which are in operation at this facility,
including sulfide precipitation, Lancy filtration, and carbon adsorption. A flow diagram of the IWC
wastewater treatment system sampled during episode # 4733 is presented in Figure 6-15. The
wastewater treatment system used at this IWC facility treats wastewater from the air pollution control
system. The air pollution control system consists of a quench tank and a wet scrubber. Table 6-4
presents a summary of percent removal data collected at episode #4733 for the performance of the
sulfide precipitation and Lancy filtration process, carbon adsorption system, and the entire treatment
system.
The treatment efficiency of the sulfide precipitation and Lancy filtration system was evaluated
using the data obtained from sampling points 01 and 02 (see Figure 6-15). Influent concentration
data to the primary system was obtained using sample point 01. Effluent from the first-stage
treatment system was represented by sample point 02. As demonstrated on the Table 6-4, the first-
stage treatment system had non-detectable levels in the influent for TSS, aluminum, cadmium, lead,
molybdenum, silver, strontium, and MCPP. Other parameters were observed in the influent at levels
near to or below treatable levels, such as antimony, arsenic, and copper. COD was removed at 11.8
percent, whereas, no removal was observed for TDS. Metals with high removal rates in the first-
stage system include; chromium (84.4 percent), iron (85.3 percent), manganese (86.3 percent),
mercury (94.0 percent), and zinc (92.2 percent). Titanium was removed to non-detectable levels in
the first-stage system. The treatment system achieved limited removal of selenium through the first-
stage primary system (25.6 percent). Poor to no removals were observed for boron and tin.
The treatment efficiency of the carbon adsorption system was evaluated using the data
obtained from sampling points 02 and 04 (see Figure 6-15). Influent concentration data to the
carbon adsorption system was obtained using sample point 02, which is also the effluent from the
first-stage treatment system. Effluent from the carbon adsorption system was represented by sample
point 04 which is also the effluent point for the entire treatment system. As demonstrated on Table
6-4, the carbon adsorption system had non-detectable levels in the influent for the same parameters
6-43
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6-46
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as in the first-stage system, plus the metals removed to non-detectable levels in the first-stage system,
such as chromium, manganese, mercury, and titanium. Additional removals were observed for iron
(96.2 percent), tin (66.4 percent), and zinc (69.8 percent). No removals in the carbon adsorption
system were observed for boron and selenium. As in the first-stage system, antimony, arsenic, and
copper are at concentrations in the influent below treatable levels.
The treatment efficiency of the entire treatment system, both first-stage sulfide precipitation,
Lancy filtration, and carbon adsorption, was evaluated using the data obtained from sampling points
01 and 04 (see Figure 6-15). Influent concentration data was obtained using sample point 01.
Effluent from the entire treatment system was represented by sample point 04. As demonstrated on
Table 6-4, the treatment system achieved a COD removal of 17.9 percent, whereas, there is no
removal for IDS. For the overall treatment system, the metals with high removal rates include
chromium, iron, manganese, mercury, titanium, and zinc. Poor removals were observed for selenium
and tin. Other metals were only detected at concentrations at or near treatable levels. Dichlorprop
was removed to non-detectable levels at 94.7 percent. MCPP was not detected in the influent or
effluent from the treatment system.
6.4.2 Rationale Used for Selection of BAT Treatment Technologies
This section presents the rationale used in selecting the treatment technologies used in the
proposed regulatory options. Treatment technologies used at episode 4733 were not considered for
further evaluation, since influent concentrations for many parameters were low and performance data
for the treatment systems could not adequately be ascertained. Therefore, the technologies utilized
at episodes 4646 and 4671 were further evaluated in order to select the most appropriate technologies
to be used as the basis for the BAT options. The basis of this evaluation consists of a comparative
analysis of the performance data for the proposed BAT treatment technologies based upon EPA
sampling data.
Table 6-5 presents a summary of the percent removal data collected at EPA sampling episodes
4646 and 4671 for the primary chemical precipitation systems. As demonstrated on this table, both
chemical precipitation systems achieved similar removals for many of the same metal parameters.
Although the loadings for some metal parameters were lower for episode 4671 which resulted in
6-47
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6-48
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lower percent removals, the overall concentrations for some of the pollutants were treated to similar
concentration levels as those for episode 4646. For instance, manganese percent removal for episode
4671 was only 33.8 percent, however the effluent concentration of 74.3 ug/1 was comparable to that
of episode 4646 of 76.6 ug/1 during which a 66.5 percent removal was achieved. Metals which
experienced good overall removals in both chemical precipitation treatment systems include
aluminum, cadmium, chromium, copper, iron, lead, manganese, mercury, tin, titanium, and zinc.
Neither system was effective in treating antimony, arsenic, boron, selenium, silver, and strontium.
Episode 4646 had higher removals for TSS (90.9 percent) and COD (70.9 percent).
Next, an evaluation of the secondary precipitation process plus filtration for both facilities was
performed. Table 6-6 presents a summary of the percent removal data collected at EPA for sampling
episodes 4646 and 4671 for the secondary precipitation process and sand filter or ultrafiltration
process, respectively. As demonstrated on this table, either process resulted in low effluent
concentrations for many of the metal parameters; such as cadmium, chromium, copper, iron, lead,
mercury, and zinc. However, the most significant difference between the two systems is the removal
of antimony (66.3 percent), arsenic (98.4 percent), and selenium (90.1 percent) in the secondary
system for episode 4646. Episode 4671, which employs a secondary treatment system consisting of
hydroxide precipitation and ultrafiltration, did not achieve significant removals for antimony, arsenic,
or selenium.
Overall both facilities achieved similar removals and/or treated to the same degree for many
of the metal parameters which are readily removed by chemical precipitation using sodium hydroxide;
including but not limited to cadmium, chromium, copper, iron, lead, mercury, and zinc. Both facilities
utilized a two tiered approach in the design of their treatment system using some type of a chemical
precipitation process to provide treatment. Primary treatment system design are comparable at both
facilities and are designed to remove similar pollutants. Both primary treatment systems are designed
to remove those metals which readily precipitate out of solution at a high pH range using a sodium
hydroxide precipitation treatment process. Based upon EPA sampling data, this treatment process
was determined not to be very effective in treating antimony, arsenic, boron, selenium, silver, and
strontium. The treatment system at episode 4671 uses a secondary treatment system targeted to
achieve additional removals for the same parameters which receive initial removals in the primary
6-49
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6-50
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system. Chemical precipitation by hydroxide precipitation is once again utilized with ultrafiltration
as a polishing step in the secondary system. The design of this treatment system is primarily due to
the characteristics of the wastewater at this facility, as well as a function of the discharge limitations
in their NPDES permit During the sampling episode, the facility for episode 4671 was permitted for
antimony (2,000 ug/1 daily maximum) and for arsenic (100 ug/1 daily maximum). However, neither
of these two parameters were observed in the influent at levels above their respective discharge
limitation in EPA's sampling episode. Therefore, the design and operation of the treatment system
at episode 4671 is not driven by the removals of parameters such as antimony or arsenic, but rather
by other metals which are removed by hydroxide precipitation; such as aluminum. Conversely, the
facility for episode 4646 is designed to remove those metals in the secondary treatment process which
are not readily removed by hydroxide precipitation. At the time of the sampling episode, this facility's
NPDES permit contains discharge limitations for antimony (600 ug/1 daily maximum), arsenic (100
ug/1 daily maximum), selenium (100 ug/1 daily maximum), and silver (100 ug/1 daily maximum). Each
of these parameters were observed in the influent to the treatment system at concentrations over their
respective discharge limitation. Therefore, the wastewater treatment system used at episode 4646
is designed and operated with a secondary treatment system consisting of chemical precipitation at
a low pH range by ferric chloride and multimedia filtration aimed at removing these additional metal
parameters which are not removed by hydroxide precipitation in the primary treatment system.
Based upon the results of the above comparative analysis of chemical precipitation and
filtration processes used at IWC facilities sampled by EPA, the proposed regulatory options utilize
unit treatment processes such as those found at episode 4646. Performance data from this facility
indicates that a primary chemical precipitation system utilizing a sodium hydroxide precipitation
process can readily achieve high removals for many metal parameters. A secondary system consisting
of chemical precipitation using ferric chloride and sand filtration can effectively remove additional
metals not readily removed by hydroxide precipitation, such as antimony, arsenic, and selenium, as
well as, achieve high additional removals for other metals which are removed by hydroxide
precipitation. Therefore, the combining of these treatment processes results in a highly effective
treatment operation which can readily accommodate the pollutants of interest for the IWC industry.
6-51
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-------
SECTION 7
ENGINEERING COSTS
This section of the Industrial Waste Combustor (IWC) Industry Development Document
presents the following information: sources of cost data along with a benchmark analysis of models;
engineering costing methodology and description of each type of additional cost to comply with
proposed options; individual treatment technology costs; and individual compliance costs for each
facility in the database for each proposed option.
This chapter contains the following sections:
Section 7.1 presents a discussion of the various costing options that were evaluated.
The criteria used to evaluate these costing options are presented, as well as a
benchmark analysis to compare the accuracy of each of these options. The selected
costing option is also presented in this section.
Section 7.2 presents a discussion of the costing methodology used to develop
regulatory costs. This section discusses the methodology used to cost treatment
systems and components, as well as to develop regulatory option costs.
Section 7.3 presents the costing method used to cost for individual treatment
technologies which comprise the regulatory options. Cost curves and equations
developed for each treatment technology are presented in this section.
Section 7.4 presents the approach to developing additional regulatory costs associated
with the implementation of the IWC regulation. Additional costs which were
developed include retrofit, monitoring, RCRA permit modification, and land costs.
Section 7.5 presents the wastewater off-site disposal costs used for facilities with very
low flow rates of IWC wastewater.
Section 7.6 presents summary tables of the total compliance costs, by facility, for each
of the IWC Industry regulatory options, including BPT/BAT and PSES. Also
presented in this section are the compliance costs for NSPS and PSNS.
7-1
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7.1
COSTS DEVELOPMENT
This section presents a discussion of the various costing options which were evaluated in
order to calculate compliance costs for the IWC Industry. A discussion of the selection criteria used
to evaluate these costing options are presented in this section, as well as a benchmark analysis to
compare the accuracy of each of these options. The selected costing option is then presented.
7.1.1 Sources of Cost Data
The following sections present the various costing sources considered in developing
regulatory costs for the IWC Industry, including computer models, vendor quotes, the Waste
Treatment Industry Phase II: Incinerators 308 Questionnaire, and other effluent guidelines.
7.1.1.1
Cost Models
Cost estimates of wastewater treatment systems are required to be developed in order to
evaluate the economic impact of the regulation. Mathematical cost models were used to assist in
developing estimated costs. In a mathematical cost model, various design and vendor data are
combined to develop cost equations which describe costs as a function of system parameters, such
as flow. Using such models readily allows for iterative costing to be performed to assist in option
selection.
For developing costs for the IWC Industry regulation, two commonly used cost models were
evaluated:
Computer-Assisted Procedure for the Design and Evaluation of Wastewater
Treatment Systems (CAPDET), developed by the U.S. Army Corps of Engineers.
WAV Costs Program (WWC), Version 2.0, developed by CWC Engineering
Software.
CAPDET is intended to provide planning level cost estimates to analyze alternate design
technologies for wastewater treatment systems. It was developed to estimate treatment system costs
primarily for high flow, municipal wastewater applications. Modules are used which represent
7-2
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physical, chemical, and biological treatment unit processes. Equations in each of these modules are
based upon engineering principles historically used for wastewater treatment plant design. Modules
can be linked together to represent entire treatment trains. CAPDET designs and costs various
treatment trains and ranks them with respect to present worth, capital, operating, or energy costs.
WWC is a cost model developed by Culp/Wesner/Culp from a variety of engineering sources,
including vendor supplied data, actual plant construction data, unit takeoffs from actual and
conceptual designs, and published data. The program allows for the costing of various unit processes.
As with CAPDET, this program allows for these unit processes to be strung together to develop cost
for treatment trains. WWC does not perform the design of the unit process, but rather prompts the
user to provide design input parameters which form the basis for the costing. The WWC program
is provided with a separate spreadsheet program entitled Design Criteria Guidelines to assist in
developing the input parameters to the costing program. The Design Criteria Guidelines is a
spreadsheet of treatment component design equations which is supplied using default parameters to
assist hi designing particular treatment units. Default parameters are based upon commonly accepted
design criteria used in wastewater treatment. Flexibility is provided with this spreadsheet, in that
particular design parameters can be modified to best satisfy given situations. Once design inputs are
entered into the program, the WWC costing program yields both construction and operation and
maintenance (O&M) costs for the system.
7.1.1.2
Vendor Data
For certain treatment processes, the cost models do not yield acceptable and valid treatment
costs. In these instances, it was more reliable to obtain equipment and maintenance costs directly
from treatment system or component manufacturers. Information on the wastewater characteristics
was provided to the vendor in order to determine accurately the appropriate treatment unit and sizing.
Vendor quotes were used to determine cost curves for multi-media filtration and for sludge
dewatering using plate and frame technology. The cost curves used are based on the vendor quotes
and information obtained as part of the CWT effluent guidelines effort.
7-3
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7.1.1.3 Waste Treatment Industry Phase II: Incinerators 308 Questionnaire Costing
Data
The Waste Treatment Industry Phase II: Incinerators 308 Questionnaire costing data was
only utilized in the benchmark analysis to compare the accuracy of the costing models and is
discussed further in Section 7.1.2.
7.1.1.4
Other EPA Effluent Guideline Studies
Other EPA effluent studies, such as the Organic Chemicals and Plastics and Synthetic Fibers
(OCPSF) industry effluent guidelines, were reviewed in order to obtain additional costing background
and supportive information. However, costs developed as part of other industrial effluent guidelines
were not used in costing for this industry, with the exception of the CWT effluent guideline data
referenced ha Section 7.1.1.2 above.
7.1.2 Benchmark Analysis and Evaluation Criteria
A benchmark analysis was performed to gauge the accuracy of the costing models presented
above. This benchmark analysis used actual costs provided in the Incinerator 308 questionnaires as
compared to costs generated using various costing options. Two BPT/BAT facilities (Questionnaire
ED#s 4646 and 4671) were selected to be used in the benchmark analysis. The BPT/BAT facilities
had installed treatment systems similar to the proposed regulatory options. Treatment technologies
which were used in the benchmark analysis include:
equalization
chemical precipitation
sedimentation
multimedia filtration
Table 7-1 presents a cost comparison of capital and O&M costs for the above technologies.
Costs were developed using the average design flow of the selected BPT/BAT facilities and average
7-4
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pollutant loadings (see Section 4.0). This table presents costs developed using the WWC program,
CAPDET, and vendor quotes, as compared to industry provided treatment system capital and O&M
costs provided in the 308 Technical Questionnaires for the BPT/BAT facilities.
Capital costs provided in the 308 Technical Questionnaire for chemical precipitation systems
installed at facility ID#s 4646 and 4671 were $2,207,000 and $1,215,000, respectively.
Questionnaire capital cost for the second-stage chemical precipitation system and filtration process
at facility ID # 4646 is $2,751,000, whereas, the capital cost for the second-stage chemical
precipitation at facility ID # 4671 is $2,265,000. As demonstrated on Table 7-1, capital costs
developed by the WWC program for the various treatment technologies were typically close to the
actual costs as provided in the questionnaire. For the WWC program, the range of accuracy in
predicting treatment component capital costs ranged from plus 76.6 percent for the chemical
precipitation system for facility ID# 4671 to a minus 34.8 percent for the second-stage chemical
precipitation system also for facility ID# 4671. The range of accuracy for the CAPDET program
capital costs was greater than that of the WWC program and ranged from a positive 110.6 percent
for the chemical precipitation system for facility ID# 4646 to a minus 46.6 percent for the second-
stage chemical precipitation and filtration system at the same facility. Vendor quotes consistently had
a large varaibility from actual questionnaire costs and were typically much lower.
O&M costs provided in the 308 Technical Questionnaire for chemical precipitation systems
installed at facility ED#s 4646 and 4671 were $910,000 and $1,837,000, respectively. Questionnaire
O&M cost for the second-stage chemical precipitation system and filtration process at facility ID #
4646 is $315,000, whereas, the O&M cost for the second-stage chemical precipitation at facility ID
# 4671 is $363,000. As demonstrated on Table 7-1, O&M costs developed by the WWC program
for the various treatment technologies were typically close to the actual costs as provided in the
questionnaire. For the WWC program, the range of accuracy in predicting treatment component
O&M costs ranged from plus 89.1 percent for the second-stage chemical precipitation system for
facility ID# 4671 to a minus 26.4 percent for the second-stage chemical precipitation and filtration
system for facility ID# 4646. The ranges of accuracy for the CAPDET program and vendor quotes
in predicting O&M costs were typically greater than the WWC program costs or were significantly
lower than questionnaire provided costs.
7-5
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Table 7-1. Costing Source Comparison
Capital Costs
1992 Dollars
wwc
CAPDET
4646 Chem Precip 4646 2-stage Chem Precip 4671 Chem Precip 4671 2-stage Chem Precip
and Sand Filtration
2,206,980 2,751,204 1,214,563 2,265,009
3,543,264 2,950,035 2,144,446 1,476,821
4,948,779 1,475,480 942,216 3,072,253
399,878 3,314,930 319,206 670,158
2000 f
BB Questionnaire
B1WWC
OB CAPDET
BB Vendor Quotes
Questionnaire
WWC
CAPDBT
Vendor Quotes
4646 Chem Precip
910,000
1,355,505
585,855
860,867
4646 2-stage Chem Precip
and Sand Filtration
315,000
231,728
99,036
222,135
4671 Chem Precip 4671 2-stage Chem Precip
1,837,000
1,864,219
515,859
361,623
363,000
686,360
466,848
151,889
7-6
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Therefore, the benchmark analysis demonstrated that the WWC cost program consistently
developed capital and O&M costs which are considered acceptable estimates of actual costs when
compared to questionnaire responses. Whereas, both CAPDET and vendor quotes were determined
not to be as accurate or consistent in estimating capital and O&M costs for these technologies.
The following criteria was used in order to evaluate the costing options and to select the
appropriate option for developing the IWC Industry costing methodology:
Does the model contain costing modules representative of the various wastewater
technologies in use or planned for use in the IWC Industry?
Can the program produce costs in the expected flow range experienced in this
industry?
Can the model be adapted to cost entire treatment trains used in the IWC Industry?
Is sufficient documentation available regarding the assumptions and sources of data
so that costs are credible and defensible?
Is the model capable of providing detailed capital and operation and maintenance
costs with unit costing breakdowns?
Is the program capable of altering the default design criteria in order to accurately
represent actual design criteria indicative of the IWC Industry?
7.1.3
Selection of Final Cost Models
Based upon the results of the benchmark analysis and an evaluation using the criteria above,
the WWC costing program was selected for costing the majority of the treatment technologies. It
was determined that the WWC produces reliable capital and O&M costs for a wide range of
treatment technologies. As demonstrated on Table 7-1, WWC program costs were consistently
accurate in predicating both capital and O&M costs for those wastewater treatment systems at the
selected BPT/BAT facilities. Capital costs predicted by CAPDET for these various treatment systems
were typically less consistent and were either much higher or lower than Questionnaire provided
costs. O&M costs developed with CAPDET were typically low compared to Questionnaire costs.
In addition, CAPDET could not cost all of the technologies needed for the IWC Industry and was
7-7
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determined not to be as accurate in predicting costs in the low flow range that characterize the IWC
industry. Vendor quotes for both capital and O&M costs in general were much lower than
Questionnaire costs. Therefore, CAPDET and vendor quotes (except as provided for below) were
not used for costing.
The WWC computer-based costing program best satisfies the selection criteria presented
above. The program can cost a wide range of typical and innovative treatment unit operations and
can combine these unit operations to develop system costs. Since the WWC program is a computer
based program, it readily allows for the repeated development of costs for a number of facilities. The
program utilizes cost modules which can accommodate the range of flows and design input
parameters needed to cost the IWC Industry. Costs developed by this program are based upon a
number of sources, including actual construction and operation costs, as well as published data.
Costs are presented in a breakdown summary table which contains unit costs and totals. Finally, the
WWC program is adaptable to cost unit operations based upon specified design criteria, as well as
flow rate. Certain unit operations are costed strictly based upon the input of flow rate, whereas other
unit operations are costed based upon a combination of flow rate and design loadings or component
size. The Design Criteria Guidelines spreadsheet is used in conjunction with the program to aid in
determining particular treatment component design input parameters. This spreadsheet is based upon
design default values, which can readily be modified in order to develop costs based upon particular
design parameters common in the IWC Industry.
However, there were particular instances where the WWC program did not produce reliable
cost information, such as for multi-media filtration and sludge dewatering facilities. WWC program
costs for these technologies were excessively high as compared to industry provided costs in the 308
Questionnaire. For these technologies, vendor quotes were more accurate in predicating costs and,
therefore, were used to provide costs.
7.2
ENGINEERING COSTING METHODOLOGY
This section presents the costing methodology used to develop treatment technology and
BPT/BAT and PSES option costs for the IWC Industry. Additional costs to comply with this
regulation, such as monitoring costs, are presented in a latter discussion in Section 7.4 of this chapter.
7-8
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7.2.1 Treatment Costing Methodology
The following discussion presents a detailed summary of the technical approach used to
estimate treatment technology costs for each in-scope facility in the IWC database. For each facility
in the database and for each proposed option, EPA developed total capital and annual operation and
maintenance treatment costs to upgrade existing wastewater treatment system, or to install new
treatment technologies, in order to comply with the long term averages (LTAs). Facilities were
costed primarily using the WWC costing program. Vendor cost curves, as developed in the CWT
industry study, were used for multimedia filtration and sludge dewatering costing. Table 7-2 presents
a breakdown of the costing method used for each treatment technology.
Table 7-2. Breakdown of Costing Method by Treatment Technology
Treatment
Technology
Cost Using
WWC Program
Cost Using Vendor
Quotes1
Key Design
Parameters)
Flocculation, Mixing
& Pumping
Chemical Feed
System
Primary & Secondary
Clarification
Multimedia Filtration
Sludge Filter Press
X
Flow rate
X
X
Flow rate & POI
Metals
Flow rate
X
X
Flow rate
Flow rate
(1) Cost curves developed using vendor quotes in the CWT guideline effort.
7-9
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In using the WWC computer model to develop treatment technology costs, the first step was
to use the Design Criteria Guidelines spreadsheet to develop input parameters for the computer
costing program. Actual pollutant loadings from the facility were used whenever possible. If
pollutant loadings were not available for a particular parameter, EPA used an estimated concentration
developed based on combined waste stream loadings or loadings from similar facilities. The facility's
baseline flow rate and the regulatory option LTAs were also used in the design of the unit operation.
Certain key design parameters, such as total suspended solids, are used directly in the WWC program,
and accompanying Design Criteria Guidelines spreadsheet, to design the various treatment unit
operations, such as a clarifier. Selected pollutant of concern (POC) metals were used to assist in the
design of BPT/BAT chemical precipitation systems. These metals typically impose a large
requirement for the various precipitating agents, thereby governing the chemical feed system design.
A more detailed discussion of individual treatment technology costing and their design parameters
is presented in Section 7.3. The design parameters from the Design Criteria Guidelines spreadsheet
were next used as input for the WWC costing program to develop the installed capital and O&M
costs.
Individual treatment component costs were developed by the WWC program by using the
corresponding module provided by the program for that particular technology. Technology-specific
design parameters were input into the WWC program. The WWC program then calculated both
installed capital costs and annual O&M costs. Treatment technology costs developed by the WWC
costing program were corrected to 1992 costs using the Engineering News Record (ENR) published
indexes. After the installed capital and annual O&M costs were developed for each facility, selected
cost factors, as shown in Table 7-3, were applied to the results to develop total capital and O&M
costs. Capital costs developed by the program include the cost of the treatment unit and some
ancillary equipment associated with that technology (see Section 7.3 for further information on
particular items costed for each technology). O&M costs for treatment chemicals, labor, materials,
electricity, and fuel are included in the computer program O&M costs.
7-10
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Table 7-3. Additional Cost Factors
Type
Capital
O&M
Factor
Site Work & Interface Piping
General Contractor Overhead
Engineering
Instrumentation & Controls
Buildings
Site Improvements
Legal, Fiscal, & Administrative
Interest During Construction
Contingency
Retrofit (if necessary)
Taxes & Insurance
% of Capital Cost
18
10
12
13
6
10
2
9
8
20
21
(1) 2 percent of total capital costs, which includes WWC computer costs and capital costs listed
above.
7.2.2 Option Costing Methodology
The following discussion presents a detailed summary of the technical approach used to
estimate the BPT/BAT and PSES option costs for each in-scope facility in the IWC database. Zero
discharge facilities were not costed for any of the regulatory options. The costing methodology used
to develop facility-specific BPT/BAT and PSES option compliance costs is presented graphically on
the flow diagram in Figure 7-1.
For each proposed BPT/BAT and PSES regulatory option, it was first determined whether
a facility was complying with the LTAs of each pollutant considered for regulation. None of the
facilities were in compliance with the LTAs, and were therefore assigned additional equipment and/or
upgrade costs to achieve compliance with that option. The next step was to determine whether a
7-11
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facility had already installed treatment unit operations capable of complying with the LTAs. If a
facility already had BPT/BAT, PSES or equivalent treatment installed, the facility was only assigned
costs for treatment system upgrades.
For facilities that did not have BPT/BAT or PSES treatment systems or equivalent, costs were
developed for the additional unit operations and/or system upgrades necessary to meet each LTA.
Facilities which were already close to compliance with the LTAs were costed for upgrades in order
to achieve BPT/BAT levels. Upgrade costs were developed using the WWC costing program
whenever possible, and included either additional equipment to be installed on existing unit processes,
expansion of existing equipment, or operational changes. Examples of upgrade costs include such
items as a new or expanded chemical feed system, or unproved or expanded sedimentation
capabilities. If a facility had no treatment system, or one that could not achieve desired levels with
upgrades or minor additions, an entire BPT/BAT treatment system was costed for that facility.
Once all of the individual treatment technology requirements for each facility were established,
individual capital and O&M treatment technology costs were developed as previously described
above in Section 7.2.1. In order to estimate the total compliance cost for a regulatory option it is
necessary to sum all of the individual component treatment technology costs. Table 7-4 presents each
of the proposed regulatory options in the IWC Industry and Hie corresponding treatment technologies
costed for each.
7.3
TREATMENT TECHNOLOGIES COSTING
The following sections describe how costs were developed for the BPT/BAT/PSES treatment
technologies. Specific assumptions are discussed for each treatment technology regarding the
equipment used, flow ranges, input and design parameters, and design and cost calculations. Table
7-2, previously referenced, presented the selected costing method which was used to cost each of the
treatment technologies used in the proposed BPT/BAT and PSES options. The following subsections
present a detailed discussion on how each of the treatment technologies presented in Table 7-3 were
costed. Costs are presented as physical/chemical wastewater treatment costs, and sludge treatment
and disposal costs.
7-13
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BPT/BCT
CODE
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SSCRIPTION
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7-14
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7.3.1
Physical/Chemical Wastewater Treatment Technology Costs
Table 7-4 presents a breakdown of the WWC treatment modules used in costing each
treatment technology for each of the proposed regulatory options. The following sections present
a description of costs for each physical/chemical wastewater treatment technology used in the
proposed regulation. Capital and O&M cost curves were developed for specific technologies and
system components. These curves, which represent cost as a function of flow rate or other system
design parameter, were developed using a commercial statistical software package (SlideWrite Plus
Version 2.1). First, costs were developed using the WWC program for each technology or
component using as a design basis five different flow rates or other system design parameters
(depending upon the governing design parameter). For instance, a technology costed on the basis
of flow would have costs developed by the WWC program at 0.01 million gallons per day (MOD),
0.05 MOD, 0.1 MGD, 0.5 MOD, and 1.0 MOD. Ranges for the five selected points to cost were
based upon a review of the flow or technology design parameters for all facilities in the database and
were selected in order to bracket the range from low to high. Next, these five data points
(flow/design parameter and associated cost) were entered into the commercial statistical software
program. Cost curves to model the total capital and O&M costs were then developed by the program
using curve fitting routines. A second order natural log equation format was used to develop all
curves. All cost curves yielded total capital and O&M costs, unless otherwise noted.
7.3.1.1 Chemical Feed Systems
The following section presents the methodology used to calculate the chemical addition feed
rates used with each applicable regulatory option. Table 7-5 presents a breakdown of the design
process used for each type of chemical feed. Chemical costs presented in Table 7-6 were taken from
the September 1992 Chemical Marketing Reporter.
For facilities with existing chemical precipitation systems, an evaluation was made as to
whether the system was achieving the regulatory option LTAs. If the existing system was achieving
LTAs, no additional chemical costs were necessary. However, if the facility was not achieving the
7-15
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Table 7-5. Chemical Addition Design Method
Chemical
Basis for Design
Stoichiometry
Reference1 (mg/L)
Hydrochloric Acid
Sodium Hydroxide
Polymer
Sodium Bisulfate
Ferric Chloride
X
X
X
2.0
75
(1) Source: Industrial Water Pollution Control, 2nd Edition (Reference X).
Table 7-6. Treatment Chemical Costs
Treatment Chemical
Ferric Chloride
Hydrochloric Acid
Polymer
Sodium Bisulfate
Sodium Hydroxide
Cost1
$200/ton
$72/ton
$2.25/lb
$230/ton
$350/ton
(1) Source: 1992 Chemical Marketing Reporter
LTAs for an option, the facility was costed for an upgrade to the chemical precipitation system. First,
the stoichiometric requirements were determined for each metal to be removed to the LTA level. If
the current feed rates were within the calculated feed rates no additional costs were calculated. For
facilities currently feeding less than the calculated amounts, the particular facility was costed for an
7-16
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upgrade to add additional precipitation chemicals, such as a coagulant, or expand their existing
chemical feed system to accommodate larger dosage rates.
Facilities without an installed chemical precipitation system were costed for an entire metals
precipitation system. The chemical feed rates used at a particular facility for either an upgrade or a
new system were based upon stoichiometric requirements, pH adjustments, and buffering ability of
the raw influent.
In developing the CWT proposed industry guideline, EPA's analysis led the agency to
conclude that the stoichiometric requirements for chemical addition far outweighed the pH and buffer
requirements. It was determined that 150 percent of the stoichiometric requirement would
sufficiently accommodate for pH adjustment and buffering of the solution. An additional 50 percent
of the stoichiometric requirement was included to react with metals not on the POC list. Finally, an
additional 10 percent was added as excess. Therefore, a total of 210 percent of the stoichiometric
requirement was used in developing costs.
Sodium Hydroxide Feed Systems
The stoichiometric requirement for sodium hydroxide to remove a particular metal is based
upon the generic equation:
valence,
Ib
treatment chemical
M removed
year
^,
A
M
^
A
treatment chemical
M
val(,nrp
vaience
^
'
NaiCa
where, M is the target metal and MW is the molecular weight.
The calculated amounts of sodium hydroxide to remove a pound of each of the selected metal
pollutants of concern are presented in Table 7-7. For indirect dischargers, only those metals which
were determined to pass through a POTW were used in determining the stoichiometric requirements.
The other metals present in the wastewater will be accommodated for by the additional 110 percent
of the stoichiometric requirement. Sodium hydroxide chemical feed system costs were developed for
many facilities using the WWC costing program. Actual facility loadings were used to establish the
sodium hydroxide dosage requirement. WWC unit process 45 was used to develop capital and O&M
7-17
-------
Table 7-7. Sodium Hydroxide Requirements for Chemical Precipitation
Pollutant
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum.
Selenium
Silver
Tin
Titanium
Dosage Rate
Sodium Hydroxide (Ib/lb metal removed)
4.45
1.64
2.67
11.10
0.71
2.31
1.26
2.15
0.77
2.91
0.40
2.50
2.03
0.74
1.35
3.34
costs for sodium hydroxide feed systems. The capital and O&M cost curves developed for sodium
hydroxide feed systems, based upon the calculated dosages, are presented as Equations 7-1 and 7-2,
respectively.
7-18
-------
where:
ln(Y) = 10.653 - 0.1841n(X) + 0.0401n(X)2
ln(Y) = 8.508 - 0.04641n(X) + 0.0141n(X)2
X = Dosage Rate (Ib/day), and
Y-Cost (1992$)
(7-1)
(7-2)
Figures 7-2 and 7-3 graphically present the sodium hydroxide feed system capital and O&M
cost curves, respectively.
Cost for a sodium hydroxide feed system are estimated using the WWC unit process cost
number 45. Costs are based on sodium hydroxide dosage rates between 10-10,000 Ib/day, with dry
sodium hydroxide used at rates less than 200 Ib/day, and liquid sodium hydroxide used at higher feed
rates. The costing program assumes that dry sodium hydroxide (98.9 percent pure) is delivered in
drums and mixed to a 10 percent solution on-site. A volumetric feeder is used to feed sodium
hydroxide to one of two tanks; one for mixing the 10 percent solution, and one for feeding. Two
tanks are necessary for this process because of the slow rate of sodium hydroxide addition due to the
high heat of solution. Each tank is equipped with a mixer and a dual-head metering pump, used to
convey the 10 percent solution to the point of application. Pipe and valving is required to convey
water to the dry sodium hydroxide mixing tanks and between the metering pumps and the point of
application.
A 50 percent sodium hydroxide solution is purchased, premixed and delivered by bulk
transport for feed rates greater than 200 Ib/day. The 50 percent solution contains 6.38 pounds of
sodium hydroxide per gallon, which is stored in fiberglass reinforced polyester tanks designed to a
hold 15 day capacity. Dual-head metering pumps are used to convey the liquid solution to the point
of application, and a standby metering pump is provided in all systems. The storage tanks are located
indoors, since 50 percent sodium hydroxide begins to crystallize at temperatures less than 54°F.
Ferric Chloride Feed Systems
Ferric chloride feed systems were costed using the WWC unit process 40. Costs were based
upon a dosage rate of 75 mg/1 of ferric chloride. The capital and O&M cost curves developed for
7-19
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ferric chloride feed systems are based upon the calculated dosage and are presented as Equations 7-3
and 7-4, respectively.
where:
ln(Y) = 11.199 - 0.1361n(X) + 0.0541n(X)2
ln(Y) = 8.808 - 0.4081n(X) + 0.0741n(X)2
X = Dosage Rate (Ib/hr), and
Y = Cost (1992$)
(7-3)
(7-4)
Figures 7-4 and 7-5 graphically present the ferric chloride feed system capital and O&M cost
curves, respectively. Costs for ferric chloride feed facilities are based on storage and feeding a 43
percent solution of ferric chloride with a weight of 12 pounds per gallon (5.2 Ibs dry ferric
chloride/gallon). The solution is stored in covered fiberglass reinforced polyester tanks designed to
hold a 15 day supply. Cost estimates include dual-head metering pumps (one standby) with materials
suitable for ferric chloride and 150 feet of stainless steel pipe and associated valves. Automatic or
feed back controls are excluded.
Sodium Bisulfite Feed Systems
Sodium bisulfite feed systems were costed using the WWC unit process 42. Costs were based
upon a stoichiometric requirement of 2.81 mg/1 of sodium bisulfite per 1 mg/1 of total chromium. The
capital and O&M cost curves developed for sodium bisulfite feed systems are based upon the
calculated dosage and are presented as Equations 7-7 and 7-8, respectively.
where:
ln(Y) = 10.822452 - 0.0109971n(X) + 0.0386911n(X)2
ln(Y) = 8.418772 + 0.518241n(X) + 0.03983 81n(X)2
X = Dosage Rate (Ib/hr), and
Y = Cost (1992$)
(7-7)
(7-8)
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Figures 7-6 and 7-7 graphically present the sodium bisulfite feed system capital and O&M cost
curves, respectively.
A 5 minute detention period is provided in the dissolving tank. Fifteen days of storage is
included using mild steel storage hoppers which are located indoors. Sodium bisulfite is conveyed
pneumatically from bulk delivery trucks to the hoppers, with the blower located on the delivery truck.
\
Hopper costs include dust collectors. Bag loaders are used on the feeder in systems too small for
bulk systems. Volumetric feeders are used for all installations. Solution tanks are located directly
beneath the storage hoppers. Conveyance from the solution tanks to the point of application is by
dual-head diaphragm metering pumps.
Hydrochloric Acid Feed Systems
Hydrochloric acid is necessary to neutralize the waste stream or adjust the waste stream for
chemical treatment. The amount necessary was calculated using the following equation.
mg/L H2SO4 =
1L
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4 v 98,000 mg _,
To allow for solution buffering, 10 percent excess acid was added.
Hydrochloric acid feed systems were costed using the WWC unit process 46. The capital and
O&M cost curves developed for hydrochloric acid feed systems, based upon the calculated feed rate,
are presented as Equations 7-9 and 7-10, respectively.
where:
ln(Y) = 10.431273 - 0.1968121n(X) + 0.0442471n(X)2
ln(Y) = 7.630396 + 0.3123051n(X) - 0.0024191n(X)2
X = Feed Rate (gpd), and
Y = Cost (1992$)
(7-9)
(7-10)
Figures 7-8 and 7-9 graphically present the hydrochloric acid feed system capital and O&M
cost curves, respectively.
7-25
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Costs are based on systems capable of metering concentrated acid from a storage tank directly
to the point of application. For feed rates up to up to 200 gpd, the concentrated acid is delivered in
drums and stored indoors. At higher flow rates, the acid is delivered in bulk and stored outdoors in
fiberglass reinforced polyester tanks. Acid is stored for 15 days, and a standby metering pump is
included for all installations.
Polymer Feed Systems
WWC unit process 34 was used to cost for polymer feed systems. Polymer dosage rate in
Ib/hr was calculated based upon a target concentration of 2 mg/1 using the facility's flow rate.
Although this module is designed to cost for a liquid alum feed system, costs generated by this
module were determined to be more reasonable and accurate in developing polymer system costs than
the WWC unit process 43 for polymer feed systems. The capital and O&M unloaded cost curves
developed for polymer feed systems are presented as Equations 7-11 and 7-12, respectively.
where:
ln(Y) = 10.539595 - 0.137711n(X) + 0.0524031n(X)2
ln(Y) = 9.900596 + 0.997031n(X) + 0.000191n(X)2
X = Dosage Rate (Ib/hr), and
Y = Cost (1992$)
(7-11)
(7-12)
Figures 7-10 and 7-11 graphically present the polymer feed system capital and O&M cost
curves, respectively.
Polymer is stored for 15 days in fiberglass reinforced polyester tanks. For smaller
installations, the tanks are located indoors and left uncovered, and for larger installations the tanks
are covered and vented, with insulation and heating provided. Dual-head metering pumps deliver the
polymer from the storage tank and meter the flow to the point of application. Feed costs include 150
feet of 316 stainless steel pipe, along with fittings and valves, for each metering pump. A standby
metering pump is included for each installation.
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7.3.1.2 Pumping
Wastewater pumping costs were estimated using WWC unit process 92, and are based on
flow rate. The capital and O&M cost curves developed for pumping are presented as Equations 7-13
and 7-14, respectively.
ln(Y) = 10.048 + 0.1671n(X) - 0.0011n(X)2 (7-13)
ln(Y) = 7.499 + 0.0241n(X) + 0.04291n(X)2 (7-14)
where:
X = Flow Rate (gpm), and
Y = Cost (1992$)
Figures 7-12 and 7-13 graphically present the pumping capital and O&M cost curves,
respectively.
7.3.1.3
Rapid Mix Tanks
Capital and O&M costs for rapid mix tanks were estimated using the WWC unit process 104
and are based on reinforced concrete basins. The capital and O&M cost curves developed for rapid
mix tanks based upon flow rate are presented as Equations 7-15 and 7-16, respectively.
where:
ln(Y) = 12.234467 - 0.6778981n(X) + 0.0781431n(X)2
ln(Y) = 10.730231 + 0.6141411n(X) + 0.0832211n(X)2
X = Flow Rate (MOD), and
Y = Cost (1992 $)
(7-15)
(7-16)
Figures 7-14 and 7-15 graphically present the rapid mix tank capital and O&M cost curves,
respectively.
Common wall construction is assumed for multiple basins. Costs include vertical shaft,
variable speed turbine mixers with 304 stainless steel shafts, paddles, and motors. Costs are based
7-33
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on a G value (G is the mean temporal velocity gradient which describes the degree of mixing; i.e.,
the greater the value of G the greater the degree of mixing) of 300 (3 ft-lbs/sec/cu. ft.) and a water
temperature of 15°C. The energy requirements are a function of G value, water temperature, and
an overall mechanism efficiency of 70 percent.
7.3.1.4
Flocculation
A cost curve was developed for flocculation using the WWC cost program. WWC unit
process 72 was used. Costs for flocculation were based upon a function of flow at a hydraulic
detention time of 20 minutes. The capital and O&M cost curves developed for flocculation are
presented as Equations 7-17 and 7-18, respectively.
where:
ln(Y) = 11.744579 + 0.6331781n(X) - 0.0155851n(X)2
ln(Y) = 8.817304 + 0.5333821n(X) + 0.0024271n(X)2
X = Flow Rate (MOD), and
Y= Cost (1992$)
(7-17)
(7-18)
Figures 7-16 and 7-17 graphically present the flocculation capital and O&M cost curves,
respectively. Cost estimates for flocculation basins are based on rectangular-shaped, reinforced
concrete structures with a depth of 12 feet and length-to-width ratio of 4:1. Horizontal paddle
flocculators were used in costing because they are less expensive and more efficient. Manufactured
equipment costs are based on a G value (G is the mean temporal velocity gradient which describes
the degree of mixing; i.e., the greater the value of G the greater the degree of mixing) of 80. Cost
estimates for drive units are based on variable speed drives for maximum flexibility, and although
common drives for two or more parallel basins are often utilized, the costs are based on individual
drives for each basin.
Energy requirements are based on a G value 80 and an overall motor/mechanism efficiency
of 60 percent. Labor requirements are based on routine operation and maintenance of 15
min/day/basin and a 4 hour oil change every 6 months.
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7.3.1.5
Primary Clarification
Cost curves were developed for primary clarification using the WWC cost program. WWC
unit process 118 for a rectangular basin with a 12 foot side wall depth was used . Costs for primary
clarification were based upon a function of flow rate, using an overflow rate of 900 gallons per day
per square feet in calculating tank size. The capital and O&M cost curves developed for primary
clarification are presented as Equations 7-19 and 7-20, respectively.
ln(Y) = 12.517967 + 0.5756521n(X) + 0.0093 961n(X)2 . (7-19)
ln(Y) = 10.011664 + 0.2682721n(X) + 0.002411n(X)2 (7-20)
where:
X = Flow Rate (MOD), and
Y = Cost (1992$)
Figures 7-18 and 7-19 graphically present the primary clarification capital and O&M cost
curves, respectively.
Estimated costs are based on rectangular basins with a 12 foot side water depth (SWD), and
chain and flight sludge collectors. Costs for the structure assumed common wall construction, and
include the chain and flight collector, collector drive mechanism, weirs, the reinforced concrete
structure complete with inlet and outlet troughs, a sludge sump, and sludge withdrawal piping.
7.3.1.6
Secondary Clarification
Cost curves were developed for secondary clarification using the WWC cost program. WWC
unit process 118 for a rectangular basin with a 12 foot side wall depth, and chain and flight collectors
was used. Costs for secondary clarification were based upon a function of flow rate, using an
overflow rate of 600 gallons per day per square feet in calculating tank size. The capital and O&M
cost curves developed for secondary clarification are presented as Equations 7-21 and 7-22,
respectively.
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(7-21)
(7-22)
where:
ln(Y) = 12.834601 + 0.6886751n(X) + 0.0354321n(X)2
ln(Y) = 10.197762 + 0.3399521n(X) + 0.0158221n(X)2
X = Flow Rate (MOD), and
Y = Cost (1992$)
Figures 7-20 and 7-21 graphically present the secondary clarification capital and O&M cost
curves, respectively. Costs for the structure assumed common wall construction, and include the
chain and flight collector, collector drive mechanism, weirs, the reinforced concrete structure
complete with inlet and outlet troughs, a sludge sump, and sludge withdrawal piping. Yard piping
to and from the clarifier is not included in the above costs, but accounted for by the engineering cost
factors.
7.3.1.7
Multimedia Filtration
A capital cost curve, as a function of flow rate, was developed for a multimedia filtration
system using vendor supplied quotes. The cost curve used in this study was developed as part of the
CWT effluent guidelines effort. The capital cost curve developed for multimedia filtration is
presented as Equation 7-23.
where:
ln(Y) = 12.265 + 0.6581n(X) + 0.0361n(X)2 (7-23)
X = Flow Rate (MOD), and
Y = Capital Cost (1992 $)
O&M costs for filter operation were estimated as 50 percent of the capital cost. Figure 7-22
graphically presents the multimedia filtration capital cost curve.
The total capital costs for the multimedia filtration systems represent equipment and
installation costs. The total construction cost includes the costs of the filter, instrumentation and
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controls, pumps, piping, and installation. The operation and maintenance costs include energy usage,
maintenance, labor, taxes, and insurance.
7.3.2 Sludge Treatment and Disposal
The method of developing sludge treatment and disposal costs are presented in the following
sections.
7.3.2.1
Plate and Frame Pressure Filtration
Regulatory costs for sludge dewatering were developed using cost curves from the CWT
effluent guideline effort. Costs are for a sludge dewatering system using a plate and frame pressure
filter, and are based upon flow rate. Only facilities without installed sludge treatment were costed.
The capital and O&M cost curves developed for a plate and frame filter press sludge
dewatering are presented as Equations 7-24 and 7-25, respectively.
where:
ln(Y) = 15.022877 + 1.11992161n(X) + 0.063 00 lln(X)2
ln(Y) = 12.52046 + 0.7132331n(X) + 0.0667011n(X)2
X = Flow (MOD), and
Y = Cost (1992$)
(7-24)
(7-25)
Figures 7-23 and 7-24 graphically present the plate and frame sludge dewatering capital and
O&M cost curves, respectively. For facilities with a flow rate of less than 1,500 gallons per day, the
O&M costs were estimated as 50 percent of the capital cost.
The components of the plate and frame pressure filtration system include: filter plates, filter
cloth, hydraulic pumps, pneumatic booster pumps, control panel, connector pipes, and support
platform. Equipment and operational costs were obtained from manufacturers' recommendations.
The capital cost equation was developed by adding installation, engineering, and contingency costs
to the vendors' equipment costs. The O&M costs were based on estimated electricity usage,
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maintenance, labor, taxes and insurance, and filter cake disposal costs. The labor requirement for the
plate and frame pressure filtration system was approximated at 30 minutes per cycle per filter press.
7.3.2.2 Filter Cake Disposal Costs
Filter cake was costed for off-site disposal at a landfill. A facility's filter cake generation was
calculated using the difference between the facility's loadings and allowable effluent concentration.
A facility's total influent loading was calculated by taking the sum of the average metals and TSS
concentrations multiplied by the baseline flow. Effluent concentrations were developed similarly
using the LTAs for each option. Then, the sludge generation in the treatment system was calculated
as the influent loading minus the amount in effluent loading, converted to an annual amount (Ibs/yr).
The amount of treatment chemicals added to the system (based upon BPT/PSES option) was also
included in the calculation of sludge generation. The amount of total sludge generated hi the
treatment system was then converted to a wet weight basis assuming 35 percent solids filter cake.
Off-site disposal costs were estimated at $0.19/lb and was based upon the medium cost reported by
IWC facilities in questionnaire responses. This cost includes transportation, handling, conditioning,
and disposal of the cake. Costs are based upon a filter cake of 35 percent solids.
7.4
ADDITIONAL COSTS
In order to complete the costing for each proposed regulatory option, costs other than
treatment component costs were developed. These additional costs are required in order to
accommodate for other costs associated with the development of the guideline. The following
additional costs were included in the total guideline option costs for each facility, as needed:
retrofit
monitoring
RCRA permit modifications
land costs
7-51
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Each of these additional costs are further discussed and defined in the following sections.
Total facility compliance costs under each proposed BPT/BAT and PSES option were developed by
adding individual treatment technology costs with these additional costs.
Final capital costs developed for each facility were then amortized using a 7 percent interest
rate over 15 years. This annualized capital cost was then added to the annual O&M cost to develop
a total annual cost for each guideline option.
7.4.1 Retrofit and Upgrade Costs
A retrofit cost factor was applied when additional equipment or processes were needed to be
added to existing systems. Retrofit costs cover the need for system modifications and components,
such as piping, valves, controls, etc., which are necessary in order to connect new treatment units and
processes to an existing treatment facility. An upgrade cost factor was also applied to allow for
existing treatment systems to be enhanced to provide sufficient treatment capability. The combined
retrofit and upgrade cost factor was estimated at 25 percent of the installed capital cost of the
equipment.
7.4.2
Land Costs
Land costs provide for the value of the land requirements needed for the installation of the
proposed treatment technology. Land costs were estimated based upon the expected land
requirements for the proposed new treatment units. Land size increments of either 0.5, 1 or 2 acres
were used depending on the expected size of the required treatment system.
Land costs vary greatly across the country depending upon the region and state. Therefore,
a national average would not be appropriate for costing purposes. State-specific unit land costs
($/acre) were developed for each state. These state-specific unit land costs were based upon the
average land costs for suburban sites in each state and were obtained from the 1990 Guide to
Industrial and Real Estate Office Markets Survey. Costs were corrected to 1992 dollars using
engineering cost factors.
According to the survey, unimproved sites are the most desirable location for development
and are generally zoned for industrial usage. State-specific unit land costs were developed by
7-52
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averaging the reported unimproved site survey data for the various size ranges (zero to 10 acres, 10
to 100 acres, and greater than 100 acres). Regional averages were used for states which did not have
data provided. Hawaii was not used in developing regional average costs, due to extremely high
costs. Table 7-8 presents the developed state-specific unit land costs used in costing. Facility land
costs in the proposed regulatory options varied from $11,500 to $237,628.
7.4.3 RCRA Permit Modification Costs
A cost associated with the modification of an existing RCRA Part B permit was included for
all hazardous waste facilities requiring an upgrade or additional treatment processes. Legal,
administrative, public relations, monitoring, and engineering fees are included in this cost. This cost
was added to the installed capital for the new or modified equipment. Permit modification costs were
estimated at $50,000 for the initial new or modified equipment, with an additional $10,000 for each
new or modified piece of equipment. A permit modification cost of $50,000 was also provided for
facilities not requiring new or modified equipment in order to allow for permit modifications due to
operational changes imposed by this regulation. Facility costs for permit modification in the proposed
regulatory options ranged from $50,000 to $130,000.
7.4.4 Monitoring Costs
Costs were developed for the monitoring of treatment system effluent. Costs were developed
for both direct and indirect dischargers and were based upon the following assumptions:
Monitoring costs are based on the number of outfalls through which wastewater is
discharged. The costs associated with a single outfall is multiplied by the total
number of outfalls to arrive at the total cost for a facility. The estimated monitoring
costs are incremental to the costs already incurred by the facility.
The capital costs for flow monitoring equipment are included in the estimates.
7-53
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Table 7-8. State Land Costs1
State
Alabama
Alaska2
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho2
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana2
Land Cost
(1992 $/acre)
24,595
87,593
49,790
17,170
325,000
47,045
58,570
58,806
68,335
78,408
1,176,120
87,593
39,204
22,764
9,670
7,605
31,363
61,158
21,170
121,532
64,687
14,740
22,738
14,113
43,124
87,593
State
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota2
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island2
South Carolina
South Dakota2
Tennessee
Texas
Utah2
Vermont2
Virginia
Washington
West Virginia2
Wisconsin
Wyoming2
Washington, DC
Land Cost
(1992 $/acre)
26,659
39,204
57,238
96,598
29,083
118,814
36,590
22,127
15,744
26,267
54,886
34,892
64,608
23,000
22,127
22,543
5.1,488
87,593
64,608
43,124
68,764
51,133
18,818
87,593.
188,179
(1) Source: 1990 Guide to Industrial and Real Estate Office Markets Survey.
(2) No data available for State, regional average used.
7-54
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Sample collection costs (equipment and labor) and sample shipment costs are not
included in the estimates because it is assumed that the facility is already conducting
these activities as part of its current permit requirements.
Based upon a review of current monitoring practices at IWC facilities, many conventional and
non-conventional parameters, as well as metals, are already being monitored on a routine basis.
Therefore, monitoring costs were developed based upon daily monitoring of TSS and weekly
monitoring of metals. Current compliance monitoring for existing facilities is generally less than the
frequency used for estimating the monitoring costs of this proposal. Table 7-9 presents the
monitoring costs per sample type for the IWC Industry.
Table 7-9. Analytical Monitoring Costs
Pollutants
TSS
Metals
Cost/Sample (S)1
6.00
35.00/metal
Notes:
(1) Cost based on 1995 analytical laboratory costs adjusted to 1992 dollars.
7.5
WASTEWATER OFF-SITE DISPOSAL COSTS
An evaluation was conducted to determine whether it would be more cost effective for low
flow facilities to have their IWC wastewaters hauled off-site and treated/disposed at a centralized
waste treatment facility, as opposed to on-site treatment. Total annual costs for new or upgraded
wastewater treatment facilities were compared to the costs for off-site treatment at a CWT facility.
Off-site disposal costs were estimated at $0.25 per gallon of wastewater treated. Transportation
costs were added to the off-site treatment costs at a rate of $3.00 per loaded mile using an average
distance of 250 miles to the treatment facility. Transportation costs were based upon the use of a
5,000-gallon tanker truck load. Facilities which treat their wastewaters off-site are considered zero
7-55
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dischargers and hence do not incur ancillary costs such as residual disposal, monitoring and land,
except for permit modification costs. For regulatory costing, the lower of the two costs were used;
on-site verses off-site treatment. Table 7-10 presents the facilities which were costed using off-site
treatment.
Table 7-10. IWC Facilities Costed for Off-Site Disposal
Facility ID#
5037
5624
Flow
(gpd)
96
28
BPT/PSES Option A and B Cost
($/yr)
23,448
10,727
7.6 COSTS FOR REGULATORY OPTIONS
The following sections present the treatment costs for complying with the proposed IWC
guideline for the BPT/BAT, PSES, NSPS, and PSNS options.
7.6.1 BPT/BATCosts
Two BPT/BAT options were proposed based upon the treatment technology sampled at
the selected BPT/BAT facility. Engineering costs for these two BPT/BAT options are presented
below.
7.6.1.1 BPT/BAT Option A: Two-stage Chemical Precipitation
BPT/BAT Option A consists of a two-stage chemical precipitation treatment system using
sodium hydroxide in the first precipitation stage with ferric chloride and sodium hydroxide in the
second stage. Sodium bisulfite is used at the head of the treatment system for chromium removal.
7-56
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Sludge dewatering is also provided in this option. Table 7-11 presents the total capital and O&M
costs for this option. This table also presents the total amortized annual cost for each facility.
7.6.1.2 BPT/BAT Option B: Two-stage Chemical Precipitation and Multimedia
Filtration
BPT/BAT Option B is BPT/BAT Option A with the addition of a multimedia filter at the end
of the treatment process. BPT/BAT Option B consists of a two-stage chemical precipitation
treatment system using sodium hydroxide in the first precipitation stage with ferric chloride and
sodium hydroxide in the second stage. Sodium bisulfite is used at the head of the treatment system
for chromium removal. A multimedia filter is provided at the end of the treatment system to polish
the effluent Sludge dewatering is also provided in this option. Table 7-12 presents the total capital
and O&M costs for this option. This table also presents the total amortized annual cost for each
facility.
7.6.2
PSES Costs
Two PSES options were proposed based upon the technology sampled at the -selected
BPT/BAT facility. These two PSES options are equivalent to the two BPT/BAT options presented
above. Engineering costs for these two PSES options are presented below.
7.6.2.1
PSES Option A: Two-stage Chemical Precipitation
PSES Option A consists of a two-stage chemical precipitation treatment system using sodium
hydroxide in the first precipitation stage with ferric chloride and sodium hydroxide in the second
stage. Sodium bisulfite is used at the head of the treatment system for chromium removal. Sludge
dewatering is also provided in this option. This PSES option is equivalent to BPT/BAT Option A.
Table 7-11 (previously referenced) presents the total capital and O&M costs for this option. This
table also presents the total amortized annual cost for each facility.
7-57
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7-59
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7.6.2.2 PSES Option B: Two-stage Chemical Precipitation and Multimedia Filtration
PSES Option B consists of a two-stage chemical precipitation treatment system using sodium
hydroxide in the first precipitation stage with ferric chloride and sodium hydroxide in the second
stage. Sodium bisulfite is used at the head of the treatment system for chromium removal. A
multimedia filter is provided at the end of the treatment system. Sludge dewatering is also provided
in this option. This PSES option is equivalent to BPT/BAT Option B. Table 7-12 (previously
referenced) presents the total capital and O&M costs for this option. This table also presents the total
amortized annual cost for each facility.
7.6.3 New Source Performance Standards Costs
The proposed New Source Performance Standards (NSPS) for the IWC Industry is equivalent
to the limitations proposed for BPT/BCT/BAT Option B. Therefore, NSPS consists of a two-stage
chemical precipitation treatment system using sodium hydroxide in the first precipitation stage with
ferric chloride and sodium hydroxide in the second stage. Sodium bisulfite is used at the head of the
treatment system for chromium reduction. A multimedia filter is provided at the end of the treatment
system to polish the effluent. Sludge dewatering is also provided in this option. NSPS costs were
estimated using an industry average flow rate of approximately 214,500 gpd and loadings similar to
the representative BPT/BAT facility (see Section X.O). The total NSPS amortized annual cost is
$527,322 assuming an average facility daily flow of 214,500 gpd. A breakdown of the NSPS capital
and O&M costs are presented on Table 7-13.
7.6.4 Pretreatment Standards for New Sources Costs
The proposed Pretreatment Standards for New Sources (PSNS) for the IWC Industry is
equivalent to the limitations proposed for PSES Option A. This option is also equivalent to BPT,
BCT, and BAT Option A. Therefore, PSNS consists of a two-stage chemical precipitation treatment
system using sodium hydroxide in the first precipitation stage with ferric chloride and sodium
hydroxide in the second stage. Sodium bisulfite is used at the head of the treatment system for
chromium reductioa Sludge dewatering is also provided in this option. PSNS costs were estimated
7-60
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7-61
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using an industry average flow rate of approximately 214,500 gpd and loadings similar to the
representative BPT/BAT facility (see Section X.O). The total PSNS amortized annual cost is
$474,164 assuming an average facility flow of 214,500 gpd. A breakdown of the PSNS capital and
O&M costs are presented on Table 7-13, referenced above.
7-62
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SECTION 8
DEVELOPMENT OF LIMITATIONS AND STANDARDS
This section describes various waste treatment technologies and their costs, pollutants
proposed for regulation, and pollutant reductions associated with the different treatment technologies
evaluated for the proposed effluent limitations guidelines and standards for the Industrial Waste
Combustor (IWC) Industry. The limitations and standards discussed in this section are Best
Practicable Control Technology Currently Available (BPT), Best Conventional Pollutant Control
Technology (BCT), Best Available Technology Economically Achievable (BAT), New Source
Performance Standards (NSPS), Pretreatment Standards for Existing Sources (PSES), and
Pretreatment Standards for New Sources (PSNS).
8.1
ESTABLISHMENT OF BPT
Generally, EPA bases BPT upon the average of the best current performance (in terms of
pollutant removals in treated effluent) by facilities of various sizes, ages, and unit processes within
an industry subcategory. The factors considered in establishing BPT include: (1) the total cost of
applying the technology relative to pollutant reductions, (2) the age of process equipment and
facilities, (3) the processes employed and required process changes, (4) the engineering aspects of
the control technology, (5) non-water quality environmental impacts such as energy requirements,
air pollution, and solid waste generation, and (6) such other factors as the Administrator deems
appropriate (Section 304(b)(2)(B) of the Act). As noted, BPT technology represents the average of
the best existing performances of facilities within the industry. EPA looks at the performance of the
best operated treatment systems and calculates limitations from some level of average performance
of these "best" facilities. For example, in the BPT limitations for the OCPSF Category, EPA
identified "best" facilities on a BOD performance criteria of achieving a 95 percent BOD removal or
a BOD effluent level of 40 mg/1 (52 FR 42535, November 5, 1987). When existing performance is
uniformly inadequate, EPA may require a higher level of control than is currently in place in an
industrial category if EPA determines that the technology can be practically applied. BPT may be
transferred from a different subcategory or category. However, BPT normally focuses on end-of-
8-1
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process treatment rather than process changes or internal controls, except when these technologies
are common industry practice.
The cost/effluent reduction inquiry for BPT is a limited balancing one, committed to EPA's
discretion, that does not require the Agency to quantify effluent reduction benefits in monetary terms.
(See, e.g., American Iron and Steel v. EPA, 526 F. 2d 1027 (3rd Cir., 1975.)) In balancing costs
against the effluent reduction benefits, EPA considers the volume and nature of discharges expected
after application of BPT, the general environmental effects of pollutants, and the cost and economic
impacts of the required level of pollution control. In developing guidelines, the Act does not require
or permit consideration of water quality problems attributable to particular point sources, or water
quality improvements in particular bodies of water. Therefore, EPA has not considered these factors
in developing the proposed limitations. (See Weyerhaeuser Company v. Costle, 590 F. 2d 1011
(D.C. Cir. 1978)).
EPA concluded that the wastewater treatment performance of the facilities it surveyed was,
with very limited exceptions, inadequate and that only two facilities are using best practicable,
currently available technology. Even at these two facilities, only one had a significant amount of
pollutants at "treatable levels". Thus, the proposed BPT effluent limitations will be based on the data
from this one treatment system only.
As pointed out previously, IWC facilities burn highly variable wastes that, in many cases, are
process residuals and sludges from other point source categories. The wastewater produced in
combustion of these wastes contains a wide variety of metals. Chemical precipitation for these metals
at a single pH is not adequate treatment for metals removal from such a highly variable waste stream.
EPA's review of existing permit limitations for the direct dischargers show that, in most cases, the
dischargers are subject to "best professional judgment" concentration limitations which were
developed from guidelines for facilities treating and discharging much more specific waste streams
(e.g., OCPSF limitations).
In determining BPT, EPA evaluated metals precipitation as the principal treatment practice
within the IWC Industry. Nine of the eleven facilities in the Industry use some type of metals
precipitation as a means for waste treatment. The precipitation techniques used by facilities varied
in the treatment chemicals used and in the number of stages of precipitation used.
8-2
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The two currently available treatment systems for which the EPA assessed performance for
BPT are:
Option A : Primary Precipitation, Solid-Liquid Separation, Secondary Precipitation,
and Solid-Liquid Separation. Under Option A, BPT limitations would be based upon
two stages of chemical precipitation, each followed by some form of separation and
sludge dewatering. The pH levels used for the two stages of chemical precipitation
would be different in order to promote optimal removal of metals because different
metals are preferentially removed at different pH levels. In addition, the first stage of
chemical precipitation is preceded by chromium reduction, when necessary. In some
cases, BPT limitations would require the current treatment technologies in place to
be improved by use of increased quantities of treatment chemicals and additional
chemical precipitation/sludge dewatering systems.
Option B: Primary Precipitation, Solid-Liquid Separation, Secondary Precipitation,
Solid-Liquid Separation, and Sand Filtration. The second option evaluated for BPT
for Industrial Waste Combustor facilities would be based on the same technology as
Option A with the addition of sand filtration at the end of the treatment train.
The Agency is proposing to adopt BPT effluent limitations for 11 pollutants based on Option
B for the Industrial Waste Combustor Industry. These limitations were developed based on an
engineering evaluation of the average level of pollutant reduction achieved through application of the
best practical control technology currently available for the discharges of the regulated pollutants.
The proposed daily maximum and monthly average BPT limitations for the TWC Industry are
presented in Table 8-1. Long-term averages, daily variability factors, and monthly variability factors
for Option B are also presented in Table 8-1. A combination of two different methodologies was
used in the development of the variability factors (monthly and daily) for this option. Specifically,
pollutant-specific variability factors were calculated and used when a metal pollutant was detected
a sufficient number of times in the effluent sampling data. However, when a metal pollutant could
not be calculated using the effluent sampling data, a group-level variability factor was used. The
8-3
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group-level variability factor is the median of the pollutant-level variability factors calculated for the
entire group of metals found in significant concentrations in the IWC Industry. See Section 5.2.2,
Tables 5-2, 5-3, and 5-4 for a complete list of the metals included in the analysis. The Statistical
Support Document of Proposed Effluent Limitations Guidelines and Standards for Industrial Waste
Combustors (EPA 821-B-97-008) provides more detailed information on the development of the
limitations for this option.
Table 8-1. BPT Effluent Limitations (mg/1)
Pollutant or
Pollutant
Parameter
Long-Term
Average
(mg/1)
Daily
Variability
Factor
(Rounded)
Monthly
Variability
Factor
(Rounded)
Maximum for
Any One Day
(mg/1)
Monthly
Average
(mg/I)
Conventional Pollutants
TSS
PH
5.84
4.2
1.3
24.3
7.46
(1)
Priority and Non-Conventional Pollutants
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Silver
Titanium
Zinc
0.00827
0.0220
0.0100
0.0103
0.0468
0.00200
0.00500
0.00738
0 0243
8.3
6.2
2.0
2.2
2.0
2.0
2.0
6.0
_22
2.0
2.2
1.3
1.3
1.3
1.3
1.3
2.2
1 S
0.0166
0.137
0.0205
0.0224
0.0957
0.00409
0.0102
0.0442
00532
0.0162
0.0493
0.0130
0.0131
0.0606
0.00259
0.00648
0.0159
00354
(l)Within the range 6.0 to 9.0 pH units.
EPA's tentative decision to base BPT limitations on Option B treatment reflects primarily an
8-4
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evaluation of three factors: the degree of effluent reduction attainable, the total cost of the proposed
treatment technologies in relation to the effluent reductions achieved, and potential non-water quality
benefits. No basis could be found for identifying different BPT limitations based on age, size, process
or other engineering factors. Neither the age nor the size of the IWC facility will significantly affect
either the character or treatability of the wastes or the cost of treatment. Further, the treatment
process and engineering aspects of the technologies considered have a relatively insignificant effect
because in most cases they represent fine tuning or add-ons to treatment technology already in use.
These factors consequently did not weigh heavily in the development of these guidelines.
The demonstrated effluent reductions attainable through the Option B control technology
represent the BPT performance attainable through the application of demonstrated treatment
measures currently in operation in this industry. Option B was chosen for the following reasons.
First, these removals are demonstrated by a facility and can readily be applied to all facilities. The
adoption of this level of control would represent a significant reduction in pollutants discharged into
the environment (from 181,000 to 54,000 pounds of TSS and metals). Second, the Agency assessed
the total cost of water pollution controls likely to be incurred for Option B in relation to the effluent
reduction and determined these costs were economically reasonable.
EPA estimated the cost of installing Option A and B BPT technologies at the direct
discharging facilities. The pretax total estimated annualized cost in 1992 dollars is approximately
$1.736 million (if BPT is Option A) and approximately $1.952 million (if BPT is Option B). EPA
concluded the cost of installation of either of these control technologies is clearly economically
achievable. EPA's assessment shows that none of the direct discharging facilities will experience a
line closure as a result of the installation of the necessary technology.
The Agency proposes to select Option B because, EPA concluded that the use of sand
filtration as the final treatment step is the best practicable treatment technology currently in. operation
for the industry. Consequently, effluent levels associated with this treatment option would represent
BPT performance levels. Also, Option A was rejected because the greater removals obtained through
the addition of sand filtration at Option B were obtained at a relatively insignificant increase in costs
over Option A.
8-5
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8.2
BCT
EPA is proposing BCT equivalent to the BPT guidelines for the conventional pollutants
covered under BPT. In developing BCT limits, EPA considered whether there are technologies that
achieve greater removals of conventional pollutants than proposed for BPT, and whether those
technologies are cost-reasonable according to the BCT Cost Test. EPA identified no technologies
that can achieve greater removals of conventional pollutants than proposed for BPT that are also
cost-reasonable under the BCT Cost Test, and accordingly, EPA proposes BCT effluent limitations
equal to the proposed BPT effluent limitations guidelines and pretreatment standards.
8.3
BAT
EPA is proposing BAT effluent limitations for the Industrial Waste Combustor Industry based
upon the same technologies evaluated and proposed for BPT. The proposed BAT effluent limitations
would control identified priority and non-conventional pollutants discharged from facilities. EPA has
not identified any more stringent treatment technology option which it considered to represent BAT
level of control applicable to facilities in this industry. EPA considered and rejected zero discharge
as possible BAT technology for the reasons explained below.
8.4
NSPS
As previously noted, under Section 306 of the Act, new industrial direct dischargers must
comply with standards which reflect the greatest degree of effluent reduction achievable through
application of the best available demonstrated control technologies. Congress envisioned that new
treatment systems could meet tighter controls than existing sources because of the opportunity to
incorporate the most efficient processes and treatment systems into plant design. Therefore,
Congress directed EPA to consider the best demonstrated process changes, in-plant controls,
operating methods and end-of-pipe treatment technologies that reduce pollution to the maximum
extent feasible.
EPA is proposing NSPS that would control the same conventional, priority, and non-
conventional pollutants proposed for control by the BPT effluent limitations. The technologies used
8-6
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to control pollutants at existing facilities are fully applicable to new facilities. Furthermore, EPA has
not identified any technologies or combinations of technologies that are demonstrated for new
sources that are more effective than those used to establish BPT/BCT/BAT for existing sources.
Therefore, EPA is proposing NSPS limitations that are identical to those proposed for
BPT/BCT/BAT.
EPA is specifically considering whether it should adopt BPT/BAT and NSPS of zero
discharge, since so many facilities are currently not generating or not discharging any wastewater as
a result of Industrial Waste Combustor operations (see Section 3 of this document). There are two
primary means of achieving zero discharge: the use of dry scrubbing operations or off-site disposal
of Industrial Waste Combustor wastewater. EPA evaluated the cost for facilities to dispose of
Industrial Waste Combustor wastewater off site and found it was less expensive than on-site
treatment of the wastewater for only three of the eleven facilities. EPA also evaluated the cost for
facilities to bum the IWC wastewater streams they generated and found that it was also significantly
more costly than wastewater treatment EPA did not evaluate the cost for all facilities to replace their
wet scrubbing systems with dry scrubbing systems, as the wet scrubbing systems have been
established as the best performers (according to the HWC proposed regulation) for removing acid
gases and dioxins from effluent gas streams. Also, dry scrubbing systems have the adverse affect of
generating an unstable solid to be disposed of in a landfill, as opposed to the stable solids generated
by wastewater treatment of air pollution control wastewater. Given the apparent environmental
superiority of wet versus dry scrubbers, EPA has decided a zero discharge requirement could have
unacceptable non-water quality effects. EPA also did not evaluate the cost for all facilities to recycle
Industrial Waste Combustor wastewater, as EPA discovered that only certain types of air pollution
control systems working in conjunction with one another are able to accomplish total recycle of
wastewater. Thus, new air pollution control systems would have to be costed for all facilities along
with recycling systems.
Overall, zero discharge is not being proposed as BPT/BAT because EPA believes that the cost
to facilities to change current air pollution control systems are too high. Also, zero discharge is not
being proposed as BPT/BAT or NSPS because the change may cause unacceptable non-water quality
impacts.
8-7
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8.5
PSES
Indirect dischargers in the Industrial Waste Combustor Industry, like the direct dischargers,
accept for treatment wastes containing many priority and non-conventional pollutants. As in the case
of direct dischargers, indirect dischargers may be expected to discharge many of these non-
combustible low-volatility pollutants to POTWs at significant mass and concentration levels. EPA
estimates that the three identified indirect dischargers annually discharge approximately 49,000
pounds of metals to POTWs.
Section 307(b) requires EPA to promulgate pretreatment standards to prevent pass-through
of pollutants from POTWs to waters of the U.S. or to prevent pollutants from interfering with the
operation of POTWs. EPA is establishing PSES for this industry to prevent pass-through of the same
pollutants controlled by BAT from POTWs to waters of the U.S.
EPA considered the same two regulatory options as in the BPT/BCT/B AT analysis to reduce
the discharge of pollutants by Industrial Waste Combustor facilities. The Agency is proposing to
adopt PSES pretreatment standards based on Option A for the Industrial Waste Combustor Industry.
The technology for Options A and B are the same except that Option A does not require the use of
sand filtration as the last treatment step.
In assessing PSES, EPA considered the age, size, process, other engineering factors, and non-
water quality impacts pertinent to the facilities treating wastes in this subcategory. No basis could
be found for identifying different PSES standards based on age, size, process or other engineering
factors.
The Agency is proposing pretreatment standards for existing sources (PSES) for all priority
and non-conventional pollutants regulated under BPT/BAT. The proposed daily maximum and
monthly average PSES pretreatment standards for the IWC Industry are presented in Table 8-2.
Long-term averages, daily variability factors and monthly variability factors for Option A are also
presented in Table 8-2. A combination of two different methodologies was used in the development
of the variability factors (monthly and daily) for this option. Specifically, pollutant-specific variability
factors were calculated and used when a metal pollutant was detected a sufficient number of times
in the effluent sampling data. However, when a metal pollutant could not be calculated using the
effluent sampling data, a group-level variability factor was used. The group-level variability factor
8-8
-------
is the median of the pollutant-level variability factors calculated for the entire group of metals found
in significant concentrations in the IWC Industry. See Section 5.2.2, Tables 5-2, 5-3, and 5-4 for a
complete list of the metals included in the analysis. The Statistical Support Document of Proposed
Effluent Limitations Guidelines and Standards for Industrial Waste Combustors (EPA 821-B-97-
008) provides more detailed information on the development of the pretreatment standards for this
option. These standards would apply to existing facilities in the Industrial Waste Combustor Industry
that indirectly discharge wastewater to publicly-owned treatment works (POTWs). PSES set at these
points would prevent pass-through of pollutants and help control sludge contamination.
Table 8-2. PSES Pretreatment Standards (mg/1)
Pollutant or
Pollutant
Parameter
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Silver
Titanium
7Jnr
Long-
Term
Average
(mg/1)
0.00952
0.0623
0.0100
0.0196
0.0477
0.00264
0.00949
0.00389
0 122
Daily
Variability
Factor
(Rounded)
3.4
7.8
2.0
3.5
2.0
2.0
2.0
3.3
_20
Monthly
Variability
Factor
(Rounded)
1.8
2.6
1,3
1.6
1.3
1.3
1.3
1.5
1 3
Maximum for
Any One Day
(mg/1)
0.0323
0.484
0.0203
0.0684
0.0968
0.00536
0.0193
0.0131
0 248
Monthly
Average
(mg/1)
0.0172
0.160
0.0130
0.0322
0.0620
0.00343
0.0123
0.00614
0 159
EPA estimated the cost and economic impact of installing Option A and B PSES technologies
at the indirect discharging facilities. The pretax total estimated annualized cost in 1992 dollars is
approximately $758,000 (if PSES is Option A) and approximately $798,000 (if PSES is Option B).
EPA concluded the cost of installation of either of these control technologies is clearly economically
achievable. EPA's assessment shows that only one of the indirect discharging facilities will experience
8-9
-------
a line closure as a result of the installation of the necessary technology.
EPA is not, however, proposing PSES based on Option B for the following reasons. EPA
has determined that, after achievements of Option A treatment levels, metal pollutants do not pass
through in amounts that would justify requiring the additional Option B treatment step, sand filtration.
The additional removals obtained by sand filtration are small, less than 57 Ib.eq. per year discharged
to receiving streams. POTW removals for the regulated pollutants range from 59 percent to 90
percent The total additional removals associated with the Option B technology represents less than
one percent of total Ib.eq. removals. Consequently, requiring PSES limits based on the Option B
technology is not justified by the small quantity of pollutants involved.
8.6
PSNS
Section 307(c) of the Act requires EPA to promulgate pretreatment standards for new sources
(PSNS) at the same time it promulgates new source performance standards (NSPS). New indirect
discharging facilities, like new direct discharging facilities, have the opportunity to incorporate the
best available demonstrated technologies, process changes, in-facility controls, and end-of-pipe
treatment technologies.
As set forth in Section 5.3 of this document, EPA determined that all of the pollutants selected
for regulation for the Industrial Waste Combustor Industry pass-through POTWs. The same
technologies discussed previously for BAT, NSPS, and PSES are available as the basis for PSNS.
EPA is proposing that pretreatment standards for new sources be set equal to PSES for
priority and non-conventional pollutants. The Agency is proposing to establish PSNS for the same
priority and non-conventional pollutants as are being proposed for PSES. EPA considered the cost
of the proposed PSNS technology for new facilities. EPA concluded that such costs are not so great
as to present a barrier to entry, as demonstrated by the fact that currently operating facilities are using
these technologies. The Agency considered energy requirements and other non-water quality
environmental impacts and found no basis for any different standards than the selected PSNS.
8.7 COST OF TECHNOLOGY OPTIONS
The Agency estimated the cost for Industrial Waste Combustor facilities to achieve each of
8-10
-------
the proposed effluent limitations and standards. All cost estimates in this section are presented in
1992 dollars. The cost components reported in this section represent estimates of the investment cost
of purchasing and installing equipment, the annual operating and maintenance costs associated with
that equipment, additional costs for discharge monitoring, and costs for facilities to modify existing
RCRA permits. The following sections present costs for BPT, BCT, BAT and PSES.
8.7.1
Proposed BPT Costs
The Agency estimated the cost of implementing the proposed BPT effluent limitations
guidelines and pretreatment standards by calculating the engineering costs of meeting the required
effluent limitations for each direct discharging IWC. This facility-specific engineering cost assessment
for BPT began with a review of present waste treatment technologies. For facilities without a
treatment technology in place equivalent to the BPT technology, the EPA estimated the cost to
upgrade its treatment technology, and to use additional treatment chemicals to achieve the new
discharge standards. The only facilities given no cost for compliance were facilities with the
treatment in place prescribed for the option. Details pertaining to the development of the technology
costs are included in Section 7. The capital expenditures for the process change component of
proposed BPT are estimated to be $ 6.3 million with annual O&M costs of $1.3 million for the eight
facilities under Regulatory Option B, which is: Primary Precipitation, Solid-Liquid Separation,
Secondary Precipitation, Solid-Liquid Separation, and Sand Filtration.
8.7.2
ProposedECT/BAT Costs
The Agency estimated that there would be no cost of compliance for implementing proposed
BCT/BAT, because the technology is identical to BPT and the costs are included with proposed BPT.
8.7.3
Proposed PSES Costs
The Agency estimated the cost for implementing proposed PSES with the same assumptions
and methodology used to estimate cost of implementing BPT. The capital expenditures for the
process change component of PSES are estimated to be $2.1 million with annual O&M costs of $528
8-11
-------
thousand for the three facilities under Regulatory Option A, which is: Primary Precipitation, Solid-
Liquid Separation, Secondary Precipitation, and Solid-Liquid Separation.
8.8 POLLUTANT REDUCTIONS
8.8.1 Conventional Pollutant Reductions
EPA has calculated how much the adoption of the proposed BPT/BCT limitations would
reduce the total quantity of conventional pollutants that are discharged. To do this, the Agency
developed an estimate of the long-term average (LTA) loading of TSS that would be discharged after
the implementation of BPT. Next, the BPT/BCT LTA for TSS was multiplied by 1992 wastewater
flows for each direct discharging facility in the industry to calculate BPT/BCT mass discharge
loadings for TSS for each facility. The BPT/BCT mass discharge loadings were subtracted from the
estimated current loadings to calculate the pollutant reductions for each facility. The Agency
estimates that the proposed regulations will reduce TSS discharges by approximately 120,000 pounds
per year for the eight facilities under Regulatory Option B. The current discharges and BPT/BCT
discharges for TSS are listed in Table 8-3.
8.8.2 Priority and Non-conventional Pollutant Reductions
8.8.2.1 Methodology
The proposed BPT, BCT, BAT and PSES, if promulgated, will also reduce discharges of
priority and non-conventional pollutants. Applying the same methodology used to estimate
conventional pollutant reductions attributable to application of BPT/BCT control technology, EPA
has also estimated priority and non-conventional pollutant reductions for each facility. Because EPA
has proposed BAT limitations equivalent to BPT, there are obviously no further pollutant reductions
associated with BAT limitations.
Current loadings were estimated using the questionnaire data supplied by the industry, data
collected by the Agency in the field sampling program, facility POTW permit information and facility
8-12
-------
NPDES permit information. For many facilities, data were not available for all pollutants of concern
or without the addition of other non-IWC wastewater. Therefore, methodologies were developed
to estimate current performance for the industry (see Section 4.4 of this document).
In the construction of the plant-specific pollutant by pollutant loadings, in any case where the
technology option generated an estimated pollutant loading in excess of the current loading, the
option loading was set equal to the current loading. The rationale for the adoption of this
methodology is consistency with and similarity to the "anti-backsliding" provisions. Also, a well
designed and operated treatment system should not increase pollutant loadings above current practice.
(It should be noted in the situation described above, no removal of the specific pollutant at the
specific plant is achieved under the technology option).
8.8.2.2 Direct Discharges (BPT/BAT)
The Agency estimates that proposed BPT/BAT regulations will reduce direct discharges of
priority and non-conventional pollutants by approximately 6,800 pounds per year for the eight
facilities under Regulatory Option B. The current discharges and BPT/BCT discharges for priority
and non-conventional pollutants are listed in Table 8-3.
8.8.2.3
PSES Effluent Discharges to POTWs
The Agency estimates that proposed PSES regulations will reduce indirect discharges of
priority and non-conventional pollutants to POTWs by approximately 47,000 pounds per year for the
three facilities under Regulatory Option A. The current discharges and BPT/BCT discharges for
priority and non-conventional pollutants are listed in Table 8-4.
8-13
-------
Table 8-3. Direct Discharge Loads (in Ibs.)
Pollutant Name
Total Suspended Solids
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
{Molybdenum
Selenium
Silver
Tin
Titanium
Zinc
Total
CAS NO
C-009
7429905
7440360
7440382
7440428
7440439
7440473
7440508
7439896
7439921
7439965
7439976
7439987
7782492
7440224
7440315
7440326
7440666
Current Load
157,365
1,221
3,907
372
10,446
368
375
682
803
659
1,028
27
1,527
175
181
354
291
1,116
180.897
Option A Load
69,675
1,007
1,770
45
10,089
276
65
127
677
215
1,013
9
1,527
121
58
207
26
549
87.455
Option B Load
37,698
945
1,631
41
10,209
108
65
67
403
214
1,028
8
1,527
84
32
200
47
157
54.463
Note: One facility is expected to ship wastewater off site for disposal. The facility has a current load
of 3 Ibs. and has been assigned 0 Ibs. in the option loads.
8-14
-------
Table 8-4. Indirect Discharge Loads (in Ibs.)
Pollutant Name
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Selenium
Silver
Tin
Titanium
Zinc
Total
CAS NO
7429905
7440360
7440382
7440428
7440439
7440473
7440508
7439896
7439921
7439965
7439976
7439987
7782492
7440224
7440315
7440326
7440666
Current Load
3,518
97
1,192
1,148
482
30,074
6,059
1,383
1,935
102
49
199
74
46
277
Til
1,663
48 574
Option A Load
67
4
3
581
21
3
7
373
16
62
1
83
18
3
11
1
42
1 298
Option B Load
55
£
3
590
8
3
3
44
16
62
1
83
9
/
z
11
3
8
904
Note: One facility is projected to cease combustion operations while the facility will remain open (a
line closure). The facility has a current load of 42,159 Ibs. and has been assigned 0 Ibs. in the option
loads. Another facility is expected to ship wastewater off site for disposal. The facility has a current
load of 7 Ibs. and has been assigned 0 Ibs. in the option loads.
8-15
-------
-------
SECTION 9
NON-WATER QUALITY IMPACTS
Section 304(b) and 306 of the Clean Water Act require EPA to consider non-water quality
environmental impacts (including energy requirements) associated with effluent limitations and
guidelines. Pursuant to these requirements, EPA has considered the possible effect of the proposed
Industrial Waste Combustors (IWC) BPT, BCT, BAT, NSPS, PSES, and PSNS regulations on air
pollution, solid waste generation, and energy consumption. In evaluating the environmental impacts
across all media, it has been determined that the impacts discussed below are minimal and are justified
by the benefits associated with compliance with the IWC regulations.
During IWC wastewater treatment, the pollutants of concern are either removed from the
wastewater stream, concentrated, or destroyed. If the pollutants are removed, they are either
transferred from the wastewater stream to another medium (e.g., VOC emissions to the atmosphere)
or end up as a treatment residual, such as sludge. Subsequent removal of pollutants to another media
and the disposition of these wastewater treatment residuals result in non-water quality impacts. Non-
water quality impacts evaluated for the IWC Industry regulations include air pollution and solid waste
generation.
Wastewater treatment also results in other, non-water, non-residual, impacts. These impacts
are the consumption of energy used to power the wastewater treatment equipment.
9.1
AIR POLLUTION
IWC facilities treat wastewater streams which contain very low concentrations of volatile
organic compounds (VOCs). These concentrations for most organic pollutants are typically below
treatable levels. This is due to the nearly total destruction of organic pollutants in the original wastes
through the combustion process, which prevents many of these pollutants from being detected in
wastewaters and from being released into the atmosphere and affecting air quality. Losses through
fugitive emission is not expected to be significant as most of the organics present in the IWC
wastewater typically have low volatility. While the wastewater streams usually pass through
collection units, cooling towers, and treatment units that are open to the atmosphere, this exposure
9-1
-------
is not expected to result in any significant volatilization of VOCs from the wastewater.
Since there are no significant air emissions generated by the proposed treatment technologies,
EPA believes that there are essentially no adverse air quality impacts anticipated as a result of the
IWC regulations.
9.2
SOLID WASTE
Several of the wastewater treatment technologies used to comply with the proposed IWC
regulations generate a solid waste. The costs for disposal of these waste residuals were included in
the compliance cost estimates prepared for the regulatory options.
The solid waste treatment residual generated as a result of implementation of these regulations
is filter cake from chemical precipitation processes. In the proposed BPT/PSES wastewater
treatment trains of the IWC Industry, hydroxide and ferric chloride precipitation of metals generates
a sludge residual. For BPT/BAT Option B, backwash from the multi-media filter is recirculated back
to the treatment system prior to the chemical precipitation processes, therefore all solids are removed
from the proposed treatment process in the clarifiers. This sludge is dewatered, and the resultant
filter cake is typically disposed of off site into a landfill. It is expected that the filter cake generated
from chemical precipitation will contain high concentrations of metals. As a result, this filter cake
may be a RCRA hazardous waste. Depending upon the wastewater usage and the resultant
characteristics of the sludge, the sludge generated at a particular facility may be either a listed or
characteristic hazardous waste, pursuant to 40 CFR 261 regulations (Identification and Listing of
Hazardous Waste). These filter cakes are considered to be a characteristic hazardous waste based
upon toxicity when the waste exceeds allowable standards based upon the Toxicity Characteristic
Leaching Procedure or exhibits other hazardous characteristics as defined under 40 CFR 261 Subpart
C (e.g., ignitability, corrosivity, or reactivity). Filter cake may also be considered a RCRA listed
waste (e.g., waste which are hazardous based upon definition as per 40 CFR 261 Subpart D)
depending upon the types of wastewater produced by the combustion process and whether it is in
contact with the wastes being combusted or residuals from the combustion process. EPA evaluated
the cost of disposing hazardous and non-hazardous filter cake. In the IWC economic evaluation,
contract hauling for off-site disposal in a Subtitle C or D landfill was the method costed.
9-2
-------
It is estimated that compliance with the proposed BPT/PSES Options would result in the
disposal of 1.276 million pounds of hazardous and non-hazardous filter cake. The estimated filter
cake generation rate by combustor type is presented in Table 9-1 below.
Table 9-1. Filter Cake Generation for the IWC Industry
Combustor Type
BIFs
Incinerators
Total
Filter Cake Generated
million pounds/year
Indirect
0.529
0
0.529
Direct
0
0.747
0.747
Total
0.529
0.747
1.276
EPA believes that the disposal of this filter cake would not have an adverse effect on. the
environment or result in the release of pollutants in the filter cake to other media. The disposal of
these wastes into controlled Subtitle D or C landfills are strictly regulated by the RCRA program.
New landfills are required to meet lining requirements to prevent the release of contaminates and to
capture leachate. Landfill capacity throughout the country can readily accommodate the additional
solid waste expected to be generated by the institution of this regulation. For costing purposes, it was
assumed that these solid wastes would be considered hazardous and will be disposed of into permitted
RCRA landfills with appropriate treatment of these filter cakes prior to disposition to achieve
compliance with applicable RCRA Land Ban treatment requirements (e.g., stabilization) pursuant
with 40 CFR 268 regulations, if necessary.
9.3
ENERGY REQUIREMENTS
In each of the proposed regulatory options, operation of wastewater treatment equipment
results in the consumption of energy. This energy is used to power pumps, mixers, and other
equipment components, to power lighting and controls, and to generate heat. Since the two
9-3
-------
regulatory options are comparable with the exception of the multi-media filter, Option B was used
in determining the most conservative estimate of energy usage for the IWC Industry. The proposed
IWC Option B would require the consumption of 1,790 thousand kilowatt-hours per year of
electricity for both direct and indirect dischargers. This is the equivalent of 1003 barrels per year of
#2 fuel oil, as compared with the 1992 rate of consumption in the United States of 40.6 million
barrels per year. Option B, with the highest energy demand, represents an increase in the production
or importation of oil of 2.5 x 10"5 percent annually. Based upon this relatively low increase in oil
consumption, EPA believes that the implementation of this regulation would cause no substantial
impact to the oil industry.
In 1992, approximately 2,797.2 billion kilowatt hours of electric power were generated in the
United States. The additional energy consumption requirements for Option B, which has the greatest
energy demand of the two options, corresponds to approximately 6.1 x 10"7 percent of the national
requirements: This increase in energy requirements to implement the BPT/PSES technologies will
result in an air emissions impact from electric power generating facilities. It is expected, that air
emissions parameters generated by electric producing facilities, such as particulates, NOX and SO2,
will be impacted. This increase in air emissions is expected to be directly proportional to the increase
in energy requirements, or in the case of Option B approximately 6.1 x 10'7percent EPA believes
this additional increase in air emissions from electric generating facilities to be minimal and will result
in no substantial impact to air emissions or detrimental results to air quality.
9-4
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APPENDIX B
ACRONYMS AND DEFINITIONS
Administrator - The Administrator of the U.S. Environmental Protection Agency
Agency The U.S. Environmental Protection Agency
BAT - The best available technology economically achievable, as described in Sec. 304(b)(2) of the
CWA.
BCT ~ The best conventional pollutant control technology, as described in Sec 304(b)(4) of the
CWA.
BODS ~ Biochemical oxygen demand - Five Day. A measure of biochemical decomposition of
organic matter in a water sample. It is determined by measuring the dissolved oxygen consumed by
microorganisms to oxidize the organic contaminants in a water sample under standard laboratory
conditions of five days and 70°C. BOD5 is not related to the oxygen requirements in chemical
combustion.
Boiler means an enclosed device using controlled flame combustion and having the following
characteristics:
(1) (T) The unit must have physical provisions for recovering and exporting thermal energy in the
form of steam, heated fluids, or heated gases; and
(ii) The unit's combustion chamber and primary energy recovery section(s) must be of integral
design. To be of integral design, the combustion chamber and the primary energy recovery section(s)
(such as waterwalls and superheaters) must be physically formed into one manufactured or assembled
unit A unit in which the combustion chamber and the primary energy recovery section(s) are j oined
only by ducts or connections carrying flue gas is not integrally designed; however, secondary energy
recovery equipment (such as economizers or air preheaters) need not be physically formed into the
same unit as the combustion chamber and the primary energy recovery section. The following units
are not precluded from being boilers solely because they are not of integral design: process heaters
(units that transfer energy directly to a process stream), and fluidized bed combustion units; and
(iii) While in operation, the unit must maintain a thermal energy recovery efficiency of at least
60 percent, calculated in terms of the recovered energy compared with the thermal value of the fuel;
and
Civ) The unit must export and utilize at least 75 percent of the recovered energy, calculated
on an annual basis. In this calculation, no credit shall be given for recovered heat used internally in
the same unit. (Examples of internal use are the preheating of fuel or combustion air, and the driving
of induced or forced draft fans or feedwater pumps); or
(2) The unit is one which the Regional Administrator has determined, on a case-by-case basis, to be
a boiler, after considering the standards in Section 260.32.
BPT - The best practicable control technology currently available, as described in Sec. 304(b)(l) of
the CWA.
Captive - Used to describe a facility that only accepts waste generated on site and/or by the owner
operator at the facility.
Centralized waste treatment facility - Any facility that treats any hazardous or non-hazardous
industrial wastes received from off-site by tanker truck, trailer/roll-off bins, drums, barge, pipeline,
or other forms of shipment. A "centralized waste treatment facility" includes 1) a facility that treats
waste received from off-site exclusively and 2) a facility that treats wastes generated on-site as well
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as waste received from off-site.
Clarification - A treatment designed to remove suspended materials from wastewater-typically by
sedimentation.
Clean Water Act (CWA) - The Federal Water Pollution Control Act Amendments of 1972 (33
U.S.C. 1251 et seq.), as amended, inter alia, by the Clean Water Act of 1977 (Public Law 95-217)
and the Water Quality Act of 1987 (Public Law 100-4).
Closed - A facility or portion thereof that is currently not receiving or accepting wastes and has
undergone final closure.
Combustion Unit - A device for waste treatment which uses elevated temperatures as the primary
means to change the chemical, physical, biological character or composition of the waste. Examples
of combustion units are incinerators, fuel processors, boilers, industrial furnaces, and kilns.
Commercial facility - Facilities that accept waste from off-site for treatment from facilities not
under the same ownership as their facility. Commercial operations are usually made available for a
fee or other remuneration. Commercial waste treatment does not have to be the primary activity at
a facility for an operation or unit to be considered "commercial."
Conventional pollutants - The pollutants identified in Sec. 304(a)(4) of the CWA and the
regulations thereunder (biochemical oxygen demand (BOD5), total suspended solids (TSS), oil and
grease, fecal coliform, and pH).
Direct discharger - A facility that discharges or may discharge treated or untreated pollutants into
waters of the United States.
Disposal - Intentional placement of waste or waste treatment residual into or on any land where the
material will remain after closure. Waste or residual placed into any water is not defined as disposal,
but as discharge.
Effluent ~ Wastewater discharges.
Effluent limitation Any restriction, including schedules of compliance, established by a State or
the Administrator on quantities, rates, and concentrations of chemical, physical, biological, and other
constituents which are discharged from point sources into navigable waters, the waters of the
contiguous zone, or the ocean. (CWA Sections 301(b) and 304(b).)
EA Economic Analysis
EPA The U.S. Environmental Protection Agency.
Facility A facility is all contiguous property owned, operated, leased or under the control of the
same person. The contiguous property may be divided by public or private right-of-way.
Hazardous Waste Any waste, including wastewaters defined as hazardous under RCRA, Toxic
Substances Control Act (TSCA), or any state law.
Incinerator means any enclosed device that:
(1) Uses controlled flame combustion and neither meets the criteria for classification as a boiler,
sludge dryer, or carbon regeneration unit, nor is listed as an industrial furnace; or
(2) Meets the definition of infrared incinerator or plasma arc incinerator.
Indirect discharger A facility that discharges or may discharge pollutants into a publicly-owned
treatment works.
Industrial Furnace - means any of the following enclosed devices that are integral components of
manufacturing processes and that use thermal treatment to accomplish recovery of materials or
energy:
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(1) Cement kilns
(2) Lime kilns
(3) Aggregate kilns
(4) Phosphate kilns
(5) Coke ovens
(6) Blast furnaces
(7) Smelting, melting and refining furnaces (including pyrometallurgical devices such as
cupolas, reverberator furnaces, sintering machine, roasters, and foundry furnaces)
(8) Titanium dioxide chloride process oxidation reactors
(9) Methane reforming furnaces
(10) Pulping liquor recovery furnaces
(11) Combustion devices used in the recovery of sulfur values from spent sulfuric acid
(12) Halogen acid furnaces (HAFs) for the production of acid from halogenated hazardous
waste generated by chemical production facilities where the furnace is located on the site of a
chemical production facility, the acid product has a halogen acid content of at least 3 percent, the acid
product is used in a manufacturing process, and except for hazardous waste burned as fuel, hazardous
waste fed to the furnace has a minimum halogen content of 20 percent as generated.
(13) Such other devices as the Administrator may, after notice and comment, add to this list
on the basis of one or more of the following factors:
(I) The design and use of the device primarily to accomplish recovery of material products;
(ii) The use of the device to bum or reduce raw materials to make a material product;
(iii) The use of the device to burn or reduce secondary materials as effective substitutes for
raw materials, in processes using raw materials as principal feedstocks;
(iv) The use of the device to bum or reduce secondary materials as ingredients in an industrial
process to make a material product;
(v) The use of the device in common industrial practice to produce a material product; and,
(vi) Other factors, as appropriate.
Industrial Waste Hazardous or non-hazardous waste generated from industrial operation. This
definition excludes refuse and infectious wastes.
Industrial Waste Combustor facility Any thermal unit that burns any hazardous or non-
hazardous industrial wastes received from off-site from facilities not under their same corporate
structure or subject to the same ownership. This term includes the following: a facility that burns
waste received from off-site exclusively as well as a facility that burns wastes generated pn-site and
waste received from off-site. Examples of a commercial industrial waste combustor facility include:
rotary kiln incinerators, cement kilns, lime kilns, aggregate kilns, boilers, etc.
Industrial Waste Combustor wastewater - Water used in air pollution control systems of industrial
waste combustion operations or water used to quench flue gas or slag generated as a result of
industrial waste combustion operations.
Intracompany A facility that treats, disposes, or recycles/recovers wastes generated by off-site
facilities under the same corporate ownership. The facility may also treat on-site generated wastes.
If any waste from other facilities not under the same corporate ownership is accepted for a fee or
other remunerations, the facility is considered commercial.
LTA Long-term Average. For purposes of the effluent guidelines, LTAs are defined as average
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pollutant levels achieved over a period of time by a technology option. LTAs were used in
developing the limitations and standards in today's proposed regulation.
Minimum level The level at which an analytical system gives recognizable signals and an
acceptable calibration point.
Municipal Facility A facility which is owned or operated by a municipal, county, or regional
government.
New Source - "New source" is defined at 40 CFR 122.2 and 122.29.
Non-conventional pollutants Pollutants that are neither conventional pollutants nor priority
pollutants listed at 40 CFR Section 401.
Non-detect value A concentration-based measurement reported below the sample specific
detection limit that can reliably be measured by the analytical method for the pollutant.
Non-hazardous waste All waste not defined as hazardous under federal or state law.
Non-water quality environmental impact An environmental impact of a control or treatment
technology, other than to surface waters.
NPDES The National Pollutant Discharge Elimination System authorized under Sec. 402 of the
CWA. NPDES requires permits for discharge of pollutants from any point source into waters of the
United States.
NSPS New Source Performance Standards
OCPSF - Organic Chemicals, Plastics, and Synthetic Fibers Manufacturing Effluent Guideline.
Off-site - "Off-site" means outside the boundaries of a facility.
On-site "On-site" means within the boundaries of a facility.
Outfall The mouth of conduit drains and other conduits from which a facility effluent discharges
into receiving waters.
Point Source Category A category of sources of water pollutants.
POTW or POTWs - Publicly-owned treatment works, as defined at 40 CFR 403.3(o).
Pretreatment Standard a regulation that establishes industrial wastewater effluent quality as
required for discharge to a POTW. (CWA Section 307(b).)
Priority Pollutants - The pollutants designated by EPA as priority in 40 CFR Part 423 Appendix
A.
Process wastewater "Process Wastewater" is defined at 40 CFR 122.2.
PSES Pretreatment standards for existing sources of indirect discharges, under Sec. 307(b) of the
CWA.
PSNS - Pretreatment standards for new sources of indirect discharges, under Sec. 307(b) and (c)
of the CWA.
RCRA Resource Conservation and Recovery Act (PL 94-580) of 1976, as amended.
Residuals The material remaining after a natural or technological process has taken place, e.g., the
sludge remaining after initial wastewater treatment.
Sewage Sludge Sludge generated by a sewage treatment plant or POTW.
Sludge The accumulated solids separated from liquids during processing.
Small business Businesses with annual sales revenues less than $6 million. This is the Small
Business Administration definition of small business for SIC code 4953, Refuse Systems (13 CFR
Ch.l, § 121.601)
Solids For the purpose of this notice, a waste that has a very low moisture content, is not free-
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flowing, and does not release free liquids. This definition deals with the physical state of the waste,
not the RCRA definition.
Treatment Any activity designed to change the character or composition of any waste so as to
prepare it for transportation, storage, or disposal; render it amenable for recycling or recovery; or
reduce it in volume.
TSS Total Suspended Solids. A measure of the amount of particulate matter that is suspended in
a water sample. The measure is obtained by filtering a water sample of known volume. The
particulate material retained on the filter is then dried and weighed.
Waste Receipt Wastes received for combustion.
Wastewater treatment system A facility, including contiguous land and structures, used to
receive and treat wastewater. The discharge of a pollutant from such a facility is subject to regulation
under the Clean Water Act.
Waters of the United States - The same meaning set forth in 40 CFR 122.2
Zero discharge No discharge of pollutants to waters of the United States or to a POTW. Also
included in this definition are discharge of pollutants by way of evaporation, deep-well injection, off-
site transfer and land application.
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