Jffimlf WatePS
^5^^^*^KJras&¥Bffi ''ffiiS^VviiW^iiis^^
%; ^:<.: -Bij'
l||Uijgmij||§S;^
L11 tJ w t; 11LI cl 11 mm" U; V V d o
:!T-:
H^rjrG sum G n r 10 GI U;St:|^vs^^i^yjjt^ii^^Hi
-------
-------
Development Document for
Effluent Limitations Guidelines
and Standards for the
Centralized Waste Treatment
Industry — Final
Volume I
(EPAS21-R-00-020)
Carol M. Browner
Administrator ,.„, _
J. Charles Fox
Assistant Administrator, Office of Water
Geoffrey Hr Grubb.s
Director, Office of Science and Technology
Sheila E. Frace
Director, Engineering and Analysis Division
Elwood H. Forsht
Chief, Chemicals and Metals Branch
Jan S. Matuszko
Project Manager
Timothy E. Connor
Project Engineer
William J. Wheeler
Project Economist
Maria D. Smith
Project Statistician
August 2000
U.S. Environmental Protection Agency, Office of Water
Washington, DC 20460
-------
ACKNOWLEDGEMENTS AND DISCLAIMER
The Agency would like to acknowledge the contributions of Jan Matuszko, Elwood Forsht, Ronald
Jordan, Maria Smith, Richard Witt, Timothy Connor, Ahmar Siddiqui, Hugh Wise, and Beverly
Randolph to development of this technical document. In addition EPA acknowledges the contribution
of Science Applications International Corporation and Westat.
Neither the United States government nor any of its employees, contractors, subcontractors,
or other employees makes any warranty, expressed or implied, or assumes any legal liability or
responsibility for any third party's use of, or the results of such use of, any information, apparatus,
product, or process discussed in this report, or represents that its use by such-a third party would not
infringe on privately owned rights.
-------
TABLE OF CONTENTS
Volume I;
EXECUTIVE SUMMARY Executive Summary-1
Es.l BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
AVAILABLE (BPT) .. Executive Summary-2
Es.2 BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
(BCT) Executive Summaiy-2
Es.3 BEST AVAILABLE TECHNOLOGY ECONOMICALLY
ACHIEVABLE (BAT) ; Executive Summary-2
Es.4 NEW SOURCE PERFORMANCE STANDARDS (NSPS) ........ Executive Summaiy-3
Es.5 PRETREATMENT STANDARDS FOR EXISTING SOURCES-
(PSES)-r-.~ Executive Summary-3
Es.6 PRETREATMENT STANDARDS FOR NEW SOURCES (PSNS) ... Executive,Summaiy-r3
CEapter 1 BACKGROUND ; ; M
1.0 LEGAL AUTHORITY : 1-1
1.1 LEGISLATIVE BACKGROUND 1-1
1.1.1- Clean Water Act . l-l
1.1.1.1 Best Practicable Control Technology Currently Available
(BPT) - Sec.304(b)(l) of the CWA l-l
1.1.1.2 Best Conventional Pollutant Control Technology (BCT) -
Sec. 304(b)(4) of the CWA '.-... 1-2
1.1.1.3 Best Available Technology Economically Achievable (BAT) -
Sec. 304(b)(2) of the CWA 1-2
1.1.1.4 'New Source Performance Standards (NSPS) - Sec. 306 of the
CWA 1-2
1.1.1.5 Pretreatment Standards for Existing Sources (PSES) - Sec.
307(b) of the CWA . . : 1-3
1.1.1.6 Pretreatment Standards for New Sources (PSNS) -
Sec. 307(b) of the CWA 1-3
1.1.2 Section 304(m) Requirements and Litigation 1-3
1.1.3 The Land Disposal Restrictions Program: 1-4
1.1.3.1 Introduction to RCRA Land Disposal Restrictions (LDR) .. 1-4
1.1.3.2 Overlap Between LDR Standards and the Centralized Waste
Treatment Industry Effluent Guidelines 1-5
-------
Table of Contents
Development Document for the CWT Point Source Category
1.2 CENTRALIZED WASTE TREATMENT INDUSTRY EFFLUENT GUIDELINE
RULEMAKING HISTORY 1-5
7.2.1 January 27,1995 Proposal 1-5
1.2.2 September 16,1996 Notice of Data Availability 1-6
1.2.3 January 13,1999 Supplemental Proposal 1-6
Chapter 2 DATA COLLECTION 2-1
2.1 PRELIMINARY.DATASUMMARY 2-1
2.2 CLEAN WATER ACT SECTION 308 QUESTIONNAIRES 2-2
2.2.1 Development of Questionnaires 2-2
2.2.2 Distribution of Questionnaires . . ..... . ... 2-3-
2.3 WASTEWATER SAMPLING AND SITE VISITS ; 2-3
2.3.1 Pre-1989 Sampling Program 2-3
2.3.2 1989-1997 Site Visits 2-4
2.3.3 Sampling Episodes .......: 2-4
2.3.3.7 Facility Selection 2-4
2.3.3.2 Sampling Episodes „ 2-5
2.3.3.3 Metal-Bearing Waste Treatment and Recovery Sampling . . 2-11
2.3.3.4 Oily Waste Treatment and Recovery Sampling 2-11
2.3.3.5 Organic-Bearing Waste Treatment and Recovery Sampling 2-12
2.3.4 1998 Characterization Sampling of Oil Tr.eatm.ent and Recovery
Facilities '. 2-12
2.4 PUBLIC COMMENTS TO THE 1995 PROPOSAL, THE 1996 NOTICE OF DATA
AVAILABILITY, AND THE 1999 SUPPLEMENTAL PROPOSAL 2-13
2.5 ADDITIONAL DATA SOURCES 2-14
2.5.7 Additional Databases . 2-14
2.5.2 Laboratory Study on the Effect of Total Dissolved Solids on Metals
Precipitation 2-15
2.6 PUBLIC PARTICIPATION 2-16
Chapter 3 SCOPE/APPLICABILITY OF THE FINAL REGULATION . . 3-1
3.7 APPLICABILITY : 3-1
3.7.7 Manufacturing Facilities . 3-1
3.7.2 Pipeline Transfers (Fixed Delivery Systems) 3-6
3.7.3 Product Stewardship . 3-8
3.7.4 Federally-Owned Facilities 3-10
3.7.5 Marine Generated Wastes 3-11
3.7.5 Publicly Owned Treatment Works (POTWs) 3-12
3.7.7 . Thermal Drying of POTWBiosolids 3-15
-------
Table of Contents
Development Document for the CWT Point Source Catesorv
3.1.8 Transporters and/or Transportation Equipment Cleaners 3-15
3.1.9 Landfill-Wastewaters , 3-16
3.1.10 Incineration Activities 3-17
3.1.11 Solids, Soils, and Sludges 3-17
3.1.12 Scrap Metal Processors and Auto Salvage Operations 3-18
3.1.13 Transfer Stations . 3-18
3.1.14 Stabilization 3-18
3.1.15 Waste, Wastewater, or Used Material Re-use. . 3-19
3.1.16 Recovery and Recycling Operations 3-19
3.1.17 Silver Recovery Operations from Used Photographic and X-Ray
Materials 3-20
3.1.18 High Temperature Metals Recovery . . ~J. 3-21
3.1.19- SolventRecycling/Fuel Blending 3-22
3.1.20 Re-refining 3-23
3.1.21 Used Oil Filter and Oily Absorbent Recycling 3-23
3.1.22,. :Gredse Trap/Interceptor Wastes 3-24
3.1.23 Food Processing Wastes 3-25
3.1.24 Sanitary Wastes and/or Chemical Toilet Wastes 3-25
3.1.25 Treatability, Research and Development, and Analytical Studies . 3-25
Chapter 4 DESCRIPTION OF THE INDUSTRY 4-1
4.1 INDUSTRY SIZE '.......-.- 4.1
4.2 GENERAL DESCRIPTION 4-1
4.3 WATER USE AND SOURCES OF WASTEWATER 4.4
4.4 VOLUME BY TYPE OF DISCHARGE ;.. 4.5
4.5 OFF-SITE TREATMENT INCENTIVES AND COMPARABLE TREATMENT '. 4-6
Chapter 5 INDUSTRY SUBCATEGORIZATION '. . 5-1
5.1 METHODOLOGY AND FACTORS CONSIDERED AS THE BASIS FOR
SUBCATEGORIZATION 5-1
5.2 SUBCATEGORIES '.....'. 5-2
5.3 SUBCATEGORYDESCRIPTIONS 5-2
5.3.7 Metals Subcategory 5-2
5.3.2 Oils Subcategory '. . 5.3
5.3.3 Organics Subcategory 5.3
5.4 MULTIPLE WASTESTREAM SUBCATEGORY 5-4
5.5 OTHER REGULATORY OPTIONS CONSIDERED FOR THE OVLSSUBCATEGORY .... 5-5
-------
Table of Contents
Development Document for the CWT Point Source Category
5.5.1 Consideration of Regulatory Options on the Basis of Revenue .... 5-5
5.5.2 Consideration of Regulatory Options on the Basis of Flow 5-6
5.5.3 Consideration of Regulatory Options on the Basis of the RCRA
Classification of the Waste Receipts 5-7
Chapter 6 POLLUTANTS OF CONCERN FOR THE CENTRALIZED WASTE
TREATMENT INDUSTRY ,6-1
6.1 METHODOLOGY 6-1
6.2 POLLUTANTS OF CONCERNFOS THE METALS SUBCATEGORY 6-27
6.3 POLLUTANTS OF CONCERN FOR THE OILS SUBCATEGORY 6:27
6.4 POLLUTANTS OF CONCERN FOR THE ORGANICS SUBCATEGORY 6-28
Chapter 7 POLLUTANTS SELECTED FOR REGULATION 7-1
7.1 TREATMENT CHEMICALS 7-1
7.2 NON-CONVENTIONAL BULK PARAMETERS 7-1
7.3 POLLUTANTS NOT DETECTED AT TREATABLE LEVELS 7-1
7.4 POLLUTANTS NOT TREATED 7-5
7.5 VOLATILE POLLUTANTS 7-5
7.6 POLLUTANTS SELECTED FOR PRETREATMENT STANDARDS AND
PRETREATMENT STANDARDS FOR NEW SOURCES (INDIRECT DISCHARGERS) .. 7-13
7.6.1 Background 7-13
7.6.2 Determination of Percent Removals for Well-Operated POTWs .. 7-13
7.6.3 Methodology for Determining Treatment Technology Percent
Removals 7-20
7.6.4 Pass-Through Analysis Results 7-20
7.6.4.1 Pass-Through Analysis Results for the Metals Subcategory 7-20
7.6.4.2 Pass-Through Analysis Results for the Oils Subcategory .. 7-22
7.6.413 Pass-Through Analysis Results for the Organics
Subcategory . . 7-24
7.7 FINAL LIST OF POLLUTANTS SELECTED FOR REGULATION ...,..- 7-25
7.7.1 Direct Dischargers 7-25
7.7.2 Indirect Dischargers '. . . 7-31
IV
-------
Table of Contents
Development Document for the CWT Point Source Category
Chapter 8 WASTEWATER TREATMENT TECHNOLOGIES 8-1
8.1 TECHNOLOGIES CURRENTLYIN USE 8-1
8.2 TECHNOLOGY DESCRIPTIONS 8-2
8.2.1 Best Management Practices : 8-2
8.2.2 Physical/Chemical/Thermal Treatment 8-3
5.2.2.1 Equalization ' 8-3
8.2.2.2 Neutralization 8-5
'8.2.2.3 Flocculation/Coagulation 8-5
8.2.2.4 Emulsion Breaking 8-8
8.2.2.5 Gravity Assisted Separation 8-10
1. GRAVITY OIL/WATER SEPARATION 8-10
2. CLARIFICATION 8-10
3. DISSOLVED AIR FLOTATION 8-13
8.2.2.6 Chromium^Reduction 8-15
8.2.2.7 Cyanide Destruction -8-16
8.2.2.8 Chemical Precipitation : 8-19
. 8.2.2.9 Filtration 8-24
1. SAND FILTRATION 8-24
2. MULTIMEDIA FILTRATION 8-25
3. PLATE AND FRAME PRESSURE FILTRATION 8-26
4. MEMBRANE FILTRATION - 8-28-
A. ULTRAFILTRATION 8-28
B. REVERSE OSMOSIS 8-28
5. LANCY FILTRATION .: 8-30
8.2.2.10 Carbon Adsorption 8-33
8.2.2.11 Ion Exchange ..: 1 . . .'. 8-35"
8.2.2.12 Electrolytic Recovery 8-36
8.2.2.13 Stripping ' 8-39
1. AIR STRIPPING 8-39
8.2.2.14 Liquid Carbon Dioxide Extraction 8-41
8.2.3 Biological Treatment 8-41
8.2.3.1 Sequencing Batch Reactors ; . . 8-43
8.2.3.2 Attached Growth Biological Treatment Systems ........ 8-45
1. TRICKLING FILTERS 8-45
2. BIOTOWERS ., '.- 8-47
8.2.3.3 Activated Sludge 8-47
8.2.4 Sludge Treatment and Disposal 8-51
8.2.4.1 Plate and Frame Pressure Filtration 8-52
8.2.4.2 Belt Pressure Filtration 8-54
8.2.4.3 Vacuum Filtration 8-54
8.2.4.4 Filter Cake Disposal 8-57
8.2.5 Zero or Alternate Discharge Treatment Options . 8-57
8.3
REFERENCES
8-59
-------
Table of Contents
Development Document for the CWT Point Source Category
Chapter 9 REGULATORY OPTIONS CONSIDERED AND SELECTED FOR
BASIS OFREGULATION 9-1
9.1 ESTABLISHMENT OF BPT 9-1
9.1.1 Technological Options Considered as the Basis for the Metals
Subcategory Limitations and Standards . 9-2
9.1.1.1 Rationale for the Final Metals Subcategory BPT
. Limitations 9-4
9.1.2 Technological Options Considered as the Basis for the Oils
Subcategory Limitations and Standards 9-6
9.1.2.1 Rationale for the Oils Subcategory BPT Limitations 9-8
9.1.3 Technological Options Considered as the Basis for the Organics
Subcategory Limitations and Standards 9-9
9.1.3.1 Rationale for the Organics Subcategory BPT Limitations . 9-10
9.1.4 Rationale for Multiple Wastestream Subcategory BPT Limitations 9-11
9.2 BEST CONVENTIONAL TECHNOLOGY (BCT)_ 9-12
9.3 BEST AVAILABLE TECHNOLOGY (BAT) , 9-12
9.4 NEW SOURCE PERFORMANCE STANDARDS (NSPS) 9-13
9.5 PRETREATMENT STANDARDS FOR EXISTING SOURCES (PSES) 9-14
9.6 PRETREATMENT STANDARDS FOR NEW SOURCES (PSNS) 9-16
Chapter 10 DATA CONVENTIONS AND CALCULATIONS OF LIMITATIONS
AND STANDARDS „ . .' 10-1
10.1 FACILITY SELECTION ; : 10-1
10.1.1 Selection of Facilities for More than One Option . . . . 10-1
10.1.2 Data from a Facility for More than One Time Period 10-2
10.1.3 Data from a Facility for the Same Time Period , 10-2
10.1.4 Different Treatment Trains at a Facility 10-3
10.2 SAMPLE POINT SELECTION 10-3
10.2.1 Effluent Sample Point 10-3
10.2.2 Influent Sample Point 10-3
10.2.3 Special Cases . . . 10-3
10.3 DETERMINATION OF BATCH AND CONTINUOUS FLOW SYSTEMS , 10-4
10.4 DATA SELECTION 10-4
10.4.1 Data Exclusions and Substitutions 10-4
10.4.1.1 Operational Difficulties 10-5
10:4.1.2 Treatment Not Reflective of BPT/BCT/BAT Treatment ... 10-5
VI
-------
Table of Contents
Development Document for the CWT Point Source Category
10.4.1.3 Exclusions to EPA Sampling Data Based Upon the
Availability of the Influent and Effluent 10-6
10.4.1.4 More Reliable Results Available 10-6
10.4.1.5 Data from the Facilities Which Accepted Waste from More
than One Subcategory 10-7
10.4.1.6 Data Collected by EPA and the Facility on the Same Day 10-8
10.4.1.7 Substitution Using the Baseline Values 10-8
10.4.1.8 Corrections to the Database and Changes in Data
Selections . . 10-9
10.4.2 Data Aggregation ; . , 10-10
10.4.2.1 Aggregation of Field Duplicates . . . . 10-11
10.4.2.2 Aggregation of Grab Samples and Multiple Daily Values 10-12
10.4.2.3 Aggregation of Data Across Streams ("Flow-
Weighting") ; 10-13
10.4.3 Data Editing Criteria 10-14
l0.4.3~LLang=.Term Average Test 10-15
10.4.3.2 Percent Removal Test 10-15
10.4.3.3 Evaluation of Self-Monitoring Data . 10-16
10.4:3.4 Examples of Applying Data Editing Criteria 10-17
10.5 DEVELOPMENT OF LONG-TERM AVERAGES : 10-19
10.5.1 Estimation of Facility-Specific Long-Term Averages . . 10-20
10.5.2 Estimation of Pollutant-Specific Long-Term Averages . 10-20
10.5.3 Baseline Values Substituted for Long-Term Averages^ ... .... . 10-20
10.6 DEVELOPMENT OF VARIABILITY FACTORS 10-21
10.6.1 Basic Overview of the Modified Delta-Lognormal Distribution . 10-21
10.6.2 Continuous and Discrete Portions of the Modified
Delta-Lognormal Distribution 10-24
10.6.3 Combining the Continuous and Discrete Portions of the Modified
Delta-Lognormal Distribution 10-24
10.6.4 Estimation Under th~e Modified Delta-Lognormal Distribution .. 10-25
10.6.5 Estimation of Facility-Specific Variability Factors . 10-27
10.6.5.1 Facility Data Set Requirements , 10-27
10.6.5.2 Estimation of Facility-Specific Daily Variability Factors 10-28
10.6.5.3 Estimation of Facility-Specific Monthly Variability
Factors 10-29
10.6.5.4 Evaluation of Facility-Specific Variability Factors .... 10-33
10.6.6 Estimation of Pollutant-Specific Variability Factors 10-33
10.6.7 Cases when Pollutant-Specific Variability Factors Could Not Be
Calculated .,....'...... 10-34
10.6.7.1 Group-Level Variability Factors 10-35
10.6.7.2 Organics Variability Factors 10-35
10.7 LIMITATIONS ." 10-36
10.7.1 Steps Used to Derive Limitations 10-37
10.7.2 Example : 10-39
10.8 TRANSFERS OF LIMITATIONS 10-40
Vll
-------
Table of Contents
Development Document for the CWT Point Source Category
10.8.1 Transfer of Oil and Grease Limitation for Metals Subcategory
from Option 4 to Option 3 : 10-40
10.8.2 Transfer of Arsenic for Metals Subcategory from Option 1A to
. Option 4 10-41
10.8.3 Transfer of Lead for Metals Subcategory from Option 4 to
Option 3 10-41
10.8.4 Transfers of Limitations from Other Rulemakings to CWT
Industry ,. 10-42
10.8.4.1 Transfer of BOD s and TSS for the Organics Subcategory 10-42
10.8.4.2 Transfer of TSS for Option 4 of the Metals Subcategory , 10-44
10.9 LIMITATIONS FOR THE MULTIPLE WASTESTREAM SUBCATEGORY 10-45
10.10 REFERENCES 10-47
Chapter 11 COST OF TREATMENT TECHNOLOGIES 11-1
11.1 COSTS DEVELOPMENT 11-1
11.1.1 Technology Costs - . - - - H-l'
• 11.1.2 Option Costs 11-2
ll.l-.2-.k'LandRequirements and Costs 11-3
11.1.2.2 Operation and Maintenance Costs 11-3
11.2 PHYSICAL/CHEMICAL WASTEWATER TREATMENT TECHNOLOGY COSTS 11-5
11.2.1 Chemical Precipitation 11-5
11.2.1.1 Selective Metals Precipitation - Metals Option 2 and 3 . . 11-5
11.2.1.2 Secondary Precipitation - Metals Option 2 and 3 11-7
11.2.1.3 Tertiary Precipitation andpHAdjustment -Metals
Option 3 - - - - H-8
11.2.L4 Primary Chemical Precipitation - Metals Option 4 . . . . 11-10
1L2.1.5 Secondary (Sulfide) Precipitation for. Metals Option 4 . . 11-12
11.2.2 Plate and Frame Liquid Filtration and Clarification 11-13
11.2.2.1 Plate and Frame Liquid Filtration Following Selective
Metals Precipitation' 11-14
11.2.2.2 Clarification for Metals Options 2, 3, and 4 11-14
11.2.3 Equalization ' 11-17
11.2.4 ' Air Stripping 11-19
11.2.5 Multi-Media Filtration : 11-20
11.2.6 Cyanide Destruction '. 11-21
11.2.7 Secondary Gravity Separation : 11-22
11.2.8 Dissolved Air Flotation 11-23
11.3 BIOLOGICAL WASTEWATER TREATMENT TECHNOLOGY COSTS 11-26
11.3.1 Sequencing Batch Reactors 11-26
11.4 SLUDGE TREATMENT AND DISPOSAL COSTS 11-26
11.4.1 Plate and Frame Pressure Filtration - Sludge Stream ........ 11-27
vm
-------
Table of Contents
Development Document for the CWT Point Source Category
11.4.2 Filter CakeDisposal 11-29
11.5 ADDITIONAL COSTS 11-30
11.5.1 Retrofit Costs 11-30
11.5.2 Monitoring Costs 11-31
11.5.3 LandCosts . . . . 11-32
11.6 REFERENCES 11-42
11.7 SUMMARY OF COST OF TECHNOLOGY OPTIONS 11-43
11.7.1 BPTCosts 11-43
11.7.2 BCT/BATCosts 11-43
11.7.3 PSESCosts . : . i 11-43
Chapter 12- POLLUTANT LOADING AND REMOVAL ESTIMATES 12-1
12.1 INTRODUCTION ; .. . 12-1
12.2-. DATA-SOURCES ,., 12-1
12.3 METHODOLOGY USED TO DEVELOP CURRENT LOADINGS ESTIMATES 12-2
12.3.1 Current Loadings Estimates for the Metals Subcategory 12-2
1'2'.37T. T Raw Loadings for the Metals Subcategory . . . 12-6™
12.3.1.2 Primary Precipitation with Solids-Liquid Separation
Loadings .........!. 12-7
12.3.1.3 Secondary Precipitation with Solids-Liquid,Separation
Loadings '....' 12-8
12.3.1.4 Technology Basis for the Option 4 Loadings 12-8
12.3.1.5 Selective Metals Precipitation (Option 3) Loadings 12-8
12.3.2 Current Loadings Estimates for the Oils Subcategory 12-9
12.3.2.1 Issues Associated with Oils Current Performance
Analyses 12-13
12.3.2.2 Estimation of Emulsion Breaking/Gravity Separation
Loadings '. 12-22
12.3.3 Organics Subcategory Current Loadings 12-22
12.4 METHODOLOGY USED TO ESTIMATE POST-COMPLIANCE LOADINGS 12-27
12.5 METHODOLOGY USED TO ESTIMATE POLLUTANT REMOVALS 12-32
12.6 POLLUTANT LOADINGS AND REMOVALS 12-32
Chapter 13 NON-WATER QUALITY IMPACTS 13-1
13.1 AlRPOLLUTION 13-1
13.2 SOLID WASTE 13-3
IX
-------
Table of Contents
Development Document for the CWT Point Source Category
13.3 ENERGY REQUIREMENTS 13-5
13.4 LABOR REQUIREMENTS 13-5
Chapter 14 IMPLEMENTATION ... : . ., . 14-1
14.1 COMPLIANCE DATES 14-1
14.1.1 Existing Direct Dischargers 14-1
14.1.2 Existing Indirect Dischargers .' 14-1
14.1.1 New Direct or Indirect Dischargers 14-1
14.2 GENERAL APPLICABILITY 14-1
14.3 APPLICABLE WASTE STREAMS 14-1
14.4 SUBCATEGORY DESCRIPTIONS 14-2
14.4.1 Metals Subcategory Description 14-3
14.4.2 Oils Subcategory Description 14-3
14.4.3 Organics Subcategory Description 14-3
14.4.4 Multiple Wastestream Subcategory Description 14-4
14.5 FACILITYSUBCATEGORIZATION IDENTIFICATION 14-4
14.6 ON-SITE GENERATED WASTEWATER SUBCATEGORY DETERMINATION 14-8
14.7 SUBCATEGORY DETERMINATION IN EPA QUESTIONNAIRE DATA BASE 14-8
14.7.1 Wastes Classified in the Metals Subcategory - Questionnaire
Responses 14-8
14.7.2 Wastes Classified in the Oils Subcategory - Questionnaire
Responses 14-8
14.7.3 Wastes Classified in the Organics Subcategory - Questionnaire
Responses 14-8
14.8 ESTABLISHING LIMITATIONS AND STANDARDS FOR FACILITY DISCHARGES ... 14-18
14.8.1 Implementation for Facilities in Multiple CWT Subcategories . . 14-18
14.8.1.1 Comply with Limitations or Standards for Sribcategory
A,BorC. 14-19'
14.8.1.2 Comply with Limitations or Standards for Subcategory D 14-20
14.8.1.2.1 EQUIVALENT TREATMENT
DETERMINATION FOR SUBCATEGORY
D 14-22
14.8.2 Implementation for Facilities with Cyanide Subset . 14-24
14.8.3 CWT Facilities Also Covered By Another Point Source
Category 14-24
14.8.3.1 Direct Discharging Facilities , 14-24
14.8.3.2 Indirect Discharging Facilities 14-26
-------
Table of Contents
Development Document for the CWT Point Source Category
14.8.3.3 Exceptions to Guidance Provided for CWT Facilities
Also Covered By Another Point Source Category 14-28
14.8.3.3.1 TRANSPORTATION EQUIPMENT
CLEANING (TEC) 14-28
14.8.3.3.2 LANDFILLS 14-28
Chapter 15 ANALYTICAL METHODS AND BASELINE VALUES 15-1
15.1 INTRODUCTION '. 15.1
15.2 ANALYTICAL RESULTS 15-1
15.5 NOMINAL QUANTITATION LIMITS 15-2
15.4 BASELINE VALUES 15-3
15.5 ANALYTICAL METHODS 15-5
15.5.1 Methods 1624,1625,1664 (Organics, HEM) 15-5
15.5.2 Method 413.1 (Oil and Grease) 15-5
15.5.3 Method 1620 15-5
15.5.4 Method 85.01 (ChlorinatedPhenolics) 15-6
15.5.5 Methods 2)4658 "and 376.1 (Total Sulfide). 15=7
15.5.6 Methods 410.1, 410.2, and 410.4 (COD andD-COD) 15-7
15.5.7 Method420.2 (TotalPhenols) 15-8
15.5.* Method 218.4 and 3500D (Hexavalent Chromium) 15-8
15.5.9 Methods 335.2 (Total Cyanide) 15-8
15.5.10 Methods 335.1, 353.2, and 353.3 (Nitrate/Nitrite) 15-9
15.5.11 Methods 350.1, 350.2, and 350.3 (Ammonia as Nitrogen) 15-9
15.5.12 Remaining Methods 15-9
15.6 ANALYTICAL METHOD DEVELOPMENT EFFORTS 15-9
LIST OF DEFINITIONS List of Definitions-1
LIST OF ACRONYMS . . List of Acronyms-1
INDEX . . ; ;...'... Index-1
XI
-------
Table of Contents
Development Document for the CWT Point Source Category
Volume II:
Appendix A POLLUTANT GROUPING Appendix A-l
Appendix B DATA SELECTION Appendix B-l
Appendix C LISTING OF DAILY INFLUENT AND EFFLUENT
MEASUREMENTS
Appendix C-l
Appendix D ATTACHMENTS TO CHAPTER 10 Appendix D-l
Appendix E LISTING OF POLLUTANTS OF CONCERN AND CAS
NUMBERS Appendix E-l
xu
-------
LIST OF TABLES
Chapter 1
Table 1-1
Table 1-2
Technology Basis for 1995 BPT Effluent Limitations 1-6
Technology Basis for 1999 Supplemental Proposal 1-8
Chemical Compounds Analyzed Under EPA Analytical Methods .... 2-7
Chapter 2
Table 2-1
Chapter 3
Table 3-1 Summary of the Frequency of the Types of Activities and
Dispositions Reported 3-9
Table 3-2 Summary of Frequency of Each Product Class Reported by
Facilities 3-9
Table 3-3 Examples of Regulated and Non-Regulated CWT Operations 3-27
Chapter 4
Table 4-1 Geographic Distribution of CWTrFacilities-(163-Faeilities^. . . 4-3,
Table-4-2= Waste Form Codes Reported by CWT Facilities in 1989 ' 4-3
Table 4-3 RCRA Codes Reported by Facilities in 1989 4-3
Table 4-4 Facility Discharge Options 4-6
Table 4-5 . Quantity of Wastewater Discharged (223 Facilities) 4-6
Chapter 6
Table 6-1 Pollutants of Concern for the Metals Subcategory 6-5
Table 6-2 Pollutants of Concern for the Oils Subcategory 6-7
Table 6-3 Pollutants of Concern for the Organics Subcategory '. . . 6-10
Table 6-4 Pollutants Not Selected as Pollutants of Concern for the Metals
Subcategory 6-12
Table 6-5 Pollutants Not Selected as Pollutants of Concern for the Oils
Subcategory 6-17
Table 6-6 Pollutants Not Selected as Pollutants of Concern for the Organics
Subcategory 6-22
Chapter?
Table 7-1 Pollutants of Concern Not Detected at Treatable Levels 7-4
Table 7-2 Volatile Pollutant Properties By Subcategory . : 7-7
Table 7-3 Non-Regulated Volatile Pollutants by Subcategory and Option 7-12
Table 7-4 CWT Pass-Through Analysis Generic POTW Percent Removals . . 7-17
Table 7-5 Final POTW Percent Removals 7-18
Table 7-6 Final Pass-Through Results For Metals Subcategory Option 4 7-21
Table 7-7 Final Pass-Through Results For Oils Subcategory Options 8 and 9 . . 7-22
List of Tables-1
-------
List of Tables
Development Document for the CWTPoint Source Category
Table 7-8 Final Pass-Through Results For Organics Subcategory Option 4 ... 7-24
Table 7-9 Pollutants Eliminated Due to Non-Optimal Performance 7-25
Table 7-10 Pollutants Eliminated Since Technology Basis is Not Standard
Method of Treatment . .' 7-26
Table 7-11 .Frequency of Detection of n-Paraffins in CWT Oils Subcategory
Wastes .- . 7-28
Table 7-12 Frequency of Detection of Polyaromatic Hydrocarbons in CWT
Oils Subcategory Wastes 7-29
Table 7-13 Frequency of Detection of Phthalates in CWT Oils Subcategory
Wastes 7-30
Table 7-14 Final List of Regulated Pollutants for Direct: Discharging-CWTs . .-- 7-31
Table 7-15 Final List of Regulated Pollutants for Indirect Discharging CWT
Facilities 7-33
Chapter 8
Table 8-1 , Percent Treatment In-place by Subcategory and by Method of Wastewater
Disposal 8-2
Chapter 10
Table 10-1 Aggregation of Field Duplicates . 10-12
Table 10-2 Aggregation of Grab Samples and Daily Values 10-13
Table 10-3 Aggregation of Data Across Streams 10-14-
Table 10-4 Metals Subcategory: Long-Term Averages Replaced by the
Baseline Values 10-21
Table 10-5 Cases where Pollutant Variability Factors Could Not be
Calculated ' 10-35
Table 10-6 Long-Term Averages and Variability Factors Corresponding to
Example for Hypothetical Group X 10-40
Table 10-7 BODS and TSS Parameters for Organics Subcategory 10-44
Table 10-8 TSS Parameters for Metal Finishing . . 10-45
Table 10-9 Options Corresponding to Multiple Wastestream Subcategory .... 10-45
Table 10-10 BPT Limitations for Wastestreams from All Three Subcategories . 10-46
Chapter 11
Table 11-1 Standard Capital Cost Algorithm . . 11-2
Table 11-2 Standard Operation and Maintenance Cost Factor Breakdown . . . . : 11-3
Table 11-3 CWT Treatment Technology Costing Index - A Guide to the
Costing Methodology Sections 11-4
Table 11-4 Cost Equations for Selective Metals Precipitation in Metals
Options 2 and 3 11-6
Table 11-5 Cost Equations for Secondary Chemical Precipitation in Metals
Options 2 and 3 . - 11-8
Table 11-6 Cost Equations for Tertiary Chemical Precipitation in Metals
Option3 11-9
Table 11-7 Cost Equations for Primary Chemical Precipitation in Metals
Option 4 11-12
Table 11-8 Cost Equations for Secondary (Sulfide) Precipitation for Metals
Option 4 11-13
ListofTables-2
-------
List of Tables
Development Document for the CWT Point Source Category
Table 11-9 Cost Equations for Clarification and Plate and Frame Liquid
Filtration in Metals Option 2,3,4 11-17
Table 11-10 Design Parameters Used for Equalization in CAPDET Program . . 11-18
Table 11-11 Summary of Cost Equations for Equalization 11-19
Table 11-12 Cost Equations for Air Stripping 11-20
Table 11-13 Cost Equations for Multi-Media Filtration '11-21
Table 11-14 Cost Equations for Cyanide Destruction 11-22
Table 11-15 Cost Equations for: Secondary Gravity Separation . . 11-23
Table 11-16A Estimate Holding Tank Capacities for DAF Systems 11-24
Table 11-16B Estimate L.abor Requirements for DAF Systems 11-24
Table 11-17 Cost Equations for Dissolved Air Flotation (DAF) in Oils Options
8 and 9 '._ 11-25
Table 11-18 Cost Equations for Sequencing Batch Reactors 11-26
Table 11-19 Cost Equations for Plate and Frame Sludge Filtration in Metals
Options 2, 3 and 4 . : Il--28~
Table 11-20 Cost Equations for Filter Cake Disposal for Metals Options 2 and
3 11-30
Table 11-21 Monitoring Frequency Requirements 11-31
Table 11-22 Analytical Cost Estimates , 11-32
Table 11-23 State Land Costs for the CWT Industry Cost Exercise 11-33
Table 11-24 Cost of Implementing BPT Regulations [in 1997 dollars] 11-43
Table 11-25 Cost of Implementing PSES Regulations [in 1997 dollars] . 11-44
Chapter 12
Table 12-1 Metals Subcategory Pollutant-Concentration Profiles for Current
Loadings , . 12-4
Table 12-2 Example of Metals Subcategory Influent Pollutant Concentration
Calculations 12-7
Table 12-3 . Treatment-in-Place Credit Applied to Oils Facilities 12-13
Table 12-4 Biphasic Sample Calculations (Summary of rules for combining
aqueous/organic phase cones.) 12-15
Table 12-5 Examples of Combining Aqueous and Organic Phases for Sample
32823 . 12-16
Table 12-6A Example of Substitution Methods for Non-Detected Measurements
of Hypothetical Pollutant X 12-18
Table 12-6B Difference in Oils Subcategory Loadings After Non-Detect
Replacement Using EPA Approach 12-19
Table 12-7 Long-Term Average Concentrations For Emulsion Breaking/Gravity
Separation Effluent . 12-20
Table 12-8 Organics Subcategory Baseline Long-Term Averages 12-25
Table 12-9 Long-Term Average Concentrations (ug/L) for All Pollutants of
Concern 12-28
Table 12-10 Summary of Pollutant Loadings and Reductions for the CWT
Metals Subcategory 12-33
Table 12-11 Summary of Pollutant Loadings and Reductions for the CWT Oils
Subcategory Subcategory ....'. 12-35
Table 12-12 Summary of Pollutant Loadings and Reductions for the CWT
Organics Subcategory 12-38
Table 12-13 Summary of Pollutant Loadings and Reductions for the Entire CWT
Industry 12-39
List of Tables-3
-------
List of Tables
Development Document for the CWT Point Source Category
Chapter 13
Table 13-1
Table 13-2
Table 13-3
Table 13-4
Table 13-5
Chapter 14
Table 14-1
Table 14-2
Table 14-3
Table 14-4
Table 14-5
Chapter 15 .
Table 15-1
Projected Air Emissions at CWT Facilities . 13-3
Projected Incremental Filter Cake Generation at CWT Facilities . . . 13-4
National Volume of Hazardous and Non-hazardous Waste Sent to
Landfills , .... 13-4
Projected Energy Requirements.for CWT Facilities 13-6
Projected Labor Requirements for CWT Facilities 13-6
Waste Receipt Classification 14-5
RCRA and Waste Form Codes Reported by Facilities in 1989 .... 14-10
Waste Form Codes in the Metals Subcategory 14-16
Waste Form Codes in the Oils Subcategory 14-16
Waste Form Codes in the Organics Subcategory 14-17
Analytical Methods and Baseline Values 15-4
ListofTables-4
-------
LIST OF FIGURES
Chapter 6
Figure 6-1
Chapter 7
Pollutant of Concern Methodology . . 6-4
Figure 7-1 Selection of Pollutants That May Be Regulated for Direct Discharges
for Each Subcategory .' 7-2
Figure 7-2 Selection of Pollutants to be Regulated for Indirect Discharges for
Each Subcategory -..-•:• -_ .• ,.7-3.,-
Figure 7-3 Determination of Volatile Pollutants for Oils Subcategory .'. 7-6
Chapters
Figure 8-1 Equalization System Diagram 8-4
Figure 8-2 Neutralization System Diagram 8-6
Figure 8-3 Clarification System Incorporating Coagulation and Flocculation 8-7
Figure 8-4 Emulsion Breaking System Diagram 8-9
Figure.8-5- Gravity Separation System Diagram . '8-IT"
Figure 8-6 Clarification System Diagram 8-12
Figure 8-7 Dissolved Air Flotation System-Diagram. .„„., 8-14
Figure 8-8 Chromium Reduction System Diagram 8-17
Figure 8-9 Cyanide Destruction by Alkaline Chlorination 8-18
Figure ,8-10 Chemical Precipitation System Diagram ; . 8-20
Figure 8-11 Calculated Solubilities of Metal Hydroxides 8-23
Figure 8-12 Multi-Media Filtration System Diagram 8-27
Figure 8-13 Ultrafiltration System Diagram 8-29
Figure 8-14 Reverse Osmosis System Diagram , 8-31
Figure 8-15 Lancy Filtration System Diagram 8-32
Figure 8-16 Carbon Adsorption System Diagram . . r 8-34
Figure 8-17 Ion Exchange System Diagram 8-37
Figure 8-18 Electrolytic Recovery System Diagram 8-38
Figure 8-19 Air Stripping System Diagram ' 8-40
Figure 8-20 Liquid CO2 Extraction System Diagram 8-42
Figure 8-21 Sequencing Batch Reactor System Diagram 8-44
Figure 8-22 Trickling Filter System Diagram 8-46
Figure 8-23 Biotower System Diagram 8-48
Figure 8-24 Activated Sludge System Diagram . 8-49
Figure 8-25 Plate and Frame Filter Press System Diagram 8-53
Figure 8-26 Belt Pressure Filtration System Diagram . 8-55
Figure 8-27 Vacuum Filtration System Diagram -,- - 8-56
Chapter 10
Figure 10-1 Modified Delta-Lognormal Distribution . ....-.' 10-23
List of Figures-1
-------
List of Figures
Development Document for the CWT Point Source Category
Chapter 11
Figure 11-1 Metals Option 4 Model Facility Diagram 11-34
Figure 11-2 Treatment Diagram For Oils Option 9 Facility Improvements .... 11-38
Chapter 12
Figure 12-1 Calculation of Current Loadings for Oils Subcategory 12-11
Chapter 14
Figure 14-1 Waste Receipt Subcategory Classification Diagram 14-7
Figure 14-2 Facility Accepting Waste in All Three Subcategories With
Treatment in Each 14-19
Figure 14-3 Facility Accepting Waste in All Three Subcategories-With"
Treatment in Each and Combined Outfall 14-21
Figure 14-4 Facility Which Accepts Wastes in Multiple Subcategories and
Treats Separately . . .' , 14-22
Figure 14-5 Categorical Manufacturing Facility Which Also Operates as a
CWT '. " 14-25
Figure 14-6 Facility that Commingles Wastestreams after Treatment - 14-26
Figure 14-7 Template of a CWT Waste Receipt/Acceptance Form 14-29
List of Figures-2
-------
EXECUTIVE SUMMARY
This technical development document
describes the technical bases for the final
Effluent Limitations Guidelines, Pretreatment
Standards, and New Source Performance
Standards for the Centralized Waste Treatment
(CWT) Industry Point Source Category. The
regulation (40 CFR Part 437) establishes
technology-based effluent limitations guidelines
and standards to reduce the discharge of
pollutants into waters of the United- States and
into publicly owned treatment .works (POTWs)
by existing and new facilities that treat or recover
hazardous or non-hazardous industrial waste,
wastewater, or- used., material from off- site.
Although the numerical effluent limitations and
standards are based on specific processes or
treatment technologies to control pollutant
discharges, EPA does not require dischargers to
use these technologies. Individual facilities may
meet the numerical requirements using whatever
types of treatment technologies, process changes,
and waste management practices they choose.
The regulation controls discharges from the
treatment and recovery of metal-bearing waste
receipts, oily waste receipts,'and organic waste
receipts. The wastewater flows covered by the
rule include both off-site and on-site generated
wastewater. This includes materials received
from off-site, solubilization water, used
oil/emulsion breaking wastewater, tanker
truck/drum/roll-off box washes, equipment
washes, air pollution control waters, laboratory-
derived wastewater, wastewater from on-site
industrial waste combustors and landfills, and
contaminated stormwater.
EPA developed different limitations and
standards for the CWT operations depending on
the type of waste received for treatment or
recovery. EPA established four subcategories
for the CWT industry:
Subcategory A: Facilitie's that treat or
recover metal from metal-bearing waste,
wastewater, or used material received from
off-site ("metals subcategory");
• Subcategory B: Facilities that treat or
recover oil from oily waste, wastewater, or
used material received from off-site ("oils
subcategory");
Subcategory- C: Facilities that treat or
recover organics from organic waste,
wastewater, or used material received from
off-site ("organics subcategory");
Subcategory D: Facilities that treat or-
recover some combination of metal-bearing,
oily, and organic waste, wastewater, or used
material received from off-site ("multiple
wastestream subcategory").
The multiple wastestream subcategory simplifies
implementation of the rule and compliance
monitoring for CWT facilities that treat wastes
subject to more than one of Subcategories A, B,
and C. These facilities may elect to comply with
the provisions of the multiple wastestream
subcategory rather than the applicable provisions
of subcategories A, B, or C. However, these
facilities must certify that an equivalent treatment
system is installed and properly designed,
maintained, and operated.
Executive Summary-1
-------
Executive Summary
Development Document for the CWTPoint Source Category
BEST PRACTICABLE CONTROL
TECHNOLOGY CURRENTLY A VAILABLE
(BPT) Es.l
The technology basis for the metals
treatment and recovery subcategory BPT
limitations is primary chemical precipitation,
liquid-solid separation, secondary chemical
precipitation, clarification, and sand filtration.
For facilities that accept concentrated cyanide,
metal-bearing wastestream, the rule is based on
in-plant cyanide removal prior to metals
treatment. The technology basis for in-plant
cyanide control is alkaline chlorination in a two-
step process.
The technology basis for the oils treatment
and recovery subcategory BPT limitations is
emulsion breaking/gravity separation, secondary
gravity separation and dissolved air flotation.
The technology basis for the organics
treatment and recovery subcategory BPT
limitations is equalization and biological treatment
(sequential batch reactor).
The BPT model technology long-term
averages and effluent limitations for the metals,
oils, and organics subcategories are listed in
Table 1. The model technology long-term
averages should be considered as design and
operating targets - presented for informational
purposes only. They are not effluent limitations
and do not appear in 40 CFR Part 437. The
long-term averages used in developing the
effluent limitations are values that plants should
•design and operate to achieve on a consistent
average basis. Plants that do this and maintain
reasonable control over their operating and
treatment system variability should have no
difficulty in meeting the limitations. Plants that
operate above the long-term averages must
achieve good control of their treatment system
variability to meet the limitations.
The BPT limitations for the multiple
wastestream subcategory are subdivided into
four segments. Each segment applies to one of
the possible combinations of the first three
subcategories of wastestreams. The multiple
wastestream subcategory limitations were
derived by combining BPT pollutant limitations
from each possible combination of subcategories
and selecting the most stringent pollutant value
where they overlap1. Therefore, the technology
bases for the multiple wastestream subcategory
limitations reflect the technology basis for each
applicable subcategory as detailed above. These
limits may only apply to those facilities that
accept wastes in multiple subcategories and elect
to comply with the requirements of the multiple
wastestream subcategory.
The BPT multiple wastestream long-term
averages and limitations are listed in Table 2 for
mixtures of:'
• metal-bearing, oils, and organics waste
receipts,
• metal-bearing and oils waste receipts,
• metal-bearing and organics waste receipts,
and
• oils and organics waste receipts.
BEST CONVENTIONAL POLLUTANT
CONTROL. TECHNOLOGY (BCT)
Es.2
The BCT effluent limitations for the
conventional pollutant parameters (BOD5, O&G,
and TSS) are equivalent to the BPT limitations
listed in Tables 1 and 2 for all subcategories.
BEST AVAILABLE, TECHNOLOGY
ECONOMICALLY ACHIEVABLE (BAT)
Es.3
The BAT effluent limitations for the priority
and non-conventional pollutants are equivalent to
the BPT limitations listed in Tables 1 and 2 for
all subcategories.
'EPA selected the most stringent maximum
monthly average limitations and its corresponding
maximum daily limitation. .
Executive Summary-2
-------
Executive Summary
Development Document for the CWTPoint Source Category
NEW SOURCE PERFORMANCE STANDARDS
(NSPS) Es.4
For the oils and the orgahics subcategories,
NSPS standards for the conventional, priority,
and non-conventional pollutants are equivalent to
the BPT/BCT/BAT limitations.
For the metals subcategory, NSPS standards
are based on the recovery of metals for reuse
through selective metals chemical precipitation,
liquid-solid separation, secondary chemical
precipitation, liquid-solid separation, and tertiary
chemical precipitation and clarification. For in-
plant cyanide control of concentrated cyanide
wastes, the in-plant technology basis is alkaline
chlorination in a two-step process. The NSPS
long-term averages and standards for the metals,
oils, and organics subcategories are listed in
Table 3.
As was the case for BPT/BCT/BAT, the
NSPS standards for the multiple wastestream
subcategory are subdivided into four segments.
The technology basis for the NSPS standards for
the multiple wastestream subcategory reflect the
technology bases for the applicable
subcategories. The NSPS multiple wastestream
long-term standards are listed in Table 4.
PRETREATMENT STANDARDS FOR EXISTING
SOURCES (PSES) Es. 5
PSES standards are established for those
BAT pollutants that are determined to pass
through or otherwise interfere with the
operations of publicly owned treatment works
(POTWs). For the metals and organics
subcategories the priority and non-conventional
pollutant PSES standards are based on the same
technology as the BPT/BAT limitations for those
pollutants that pass through POTWs.
For the oils subcategory, the technology
basis for PSES is emulsion breaking/gravity
separation, and dissolved air flotation. The
PSES long-term averages and standards for the
metals, oils, and organics subcategories are listed
in Table 5. '
The PSES standards for the multiple
wastestream subcategory are also subdivided into
four segments. The technology basis for
pretreatinent standards for the multiple
wastestream subcategory reflect the technology
bases for the applicable subcategories. The
PSES multiple wastestream long-term averages
and standards are listed in Table 6.
PRETREATMENT STANDARDS FOR NEW
SOURCES (PSNS)
Es.6
For the metals and organics subcategories,
the technology bases for PSNS are equivalent to
PSES. For the oils subcategory, the. technology
basis is equivalent to BPT/BAT. The PSNS
long-term averages and standards for those
pollutants that are. determined to pass through
POTWs are listed in Table 7 for the metals, oils,
and organics subcategories .
The PSNS standards for the multiple
wastestream subcategory are subdivided into
four segments. The technology bases for the
multiple wastestream subcategory new source
standards reflect-the technology bases for the
applicable subcategories. The PSNS multiple
wastestream long-term averages and standards
are listed in Table 8.
Executive Summary-3
-------
I
o
i
-------
£ §» :
1 2 5
1 > "1
U s S -< g
E? B
O A
OJD «
•22 fi'
I 1|'
u
'5
I
O g
c? Is w **
. 2 1 S (2
£ai
» I i i
c iS < g
to -a -
t 1
M M E
O) J 5n 5
S"3 P
s -5
"a ' Q cs
tn g
5
i
A) g .& S)
tal
£3 « C
e; IM C
0 " '5
. £ S •< 5
<. O ^
s -2
ff 1 E
S M >-> 3
2 "5 •§
Q Q «
J2 S
u
S g
' % 1 f 1
0 < H (-,
tl
w "Sb E
•< a* s
U PS Z
s
1
1
(2
es
1
i-i in xo OSOT-iCC
oo CTS i— <; »•* \o «s in i— i— < oc
*c
1 1
1 o . 1
£ g'g |
1 -s -s 1 1 1 1 S £
2t«(«w~;eicB>~' .S 1—
52£Sofe'Sis5
|3UOQP!1l9« J;^
Oo ACr^b C&
-------
?
1
2
estream com
' D mixed was
e>
a
J
w
1_
limitations fo
s and BPT
O
ft
Table Executive Summary-2. CWT de
£• 0
j= oa
S 2 H
i? 1 53 s
« =
si
S J §
S >. E
s = s
s a s
rt"
5 |
£ a, e »
Mf §•
.3 3 <§ £
s a |
* = 1
5 5 a S «
3 .0 -s <; s
• £
:r 1 _
1 2 1
• ». °
™ = "i
? « s
„• a s
i
* e
t™ GO e —
fill
» o 1
i 2 1
s s > 3
a S E < S
a =
M !
* 3 S
i : .. Q E
r-l
*" ^ S ~
fill
3 fifti
£ a E
- s I s «
^ «C < •£
' 1 i
y *.£
Ti =
Q S
i2 a s -
f S f ff
J < Q H
CAS
Pollutant Parameters Registry
Number
»*-
M "it O\ 4, ovotn mo\ o vo. vo^« oo "o *•
•Vrooo^^o M r* in f*i
VO O\
T VDO P- O(»rtC\O
SO\ — r- r** t— oorocn r--«— eN ioooc4«o O\OTJ- OCN- oo ^Ofn«— i\or-
r< t- T-H o\ r* «>
•i^t*-HO(*)'«rr4 oo oo «/i o o\ vo *-( ^^ oo ^o
•^•ooo-Nr^M-v ^ooswi^^r^c^^o-f o oor-
0x0 ^*-<»
r* n o
r»^tr o^o^ooooooomn^^ooooN o oo
r< r* o
*-< »n . •
VO @ -
os-n1 vo>n Troor-o c\o
m m — r- m vi r- ooo ^ \c o\ — • o m • d *n —
oeooooo — tn O\O^-VOOO» r- »-«a\fs r^^-r-
i— i -^- — < >3 r*l -^T «S OOV) OO 1/1 O O\ VO O «0VO*M OO'O*-*
oo\o *-4»-(*sort»-«r^ — o»^±^ro*-'OOTr oso o , I-H oo o *«*)in oooo
vo « r* o fi
^4 i— i m
vo 8
OT veto TTOOC-O ,O\wiO\O
O oo M o oo — m ovo^vooor^oommoo >O(*i — *or-u"»«noo
Oro«n —• O C«l ^ — — — OOOv — MOOOOm OOOOOOO — —
— 00 l«SVO --(OrrtTrftl-^iMr-.
nr-o\ *?7*?*T"T T '*? ^-^ **'7*?NO<:<<;cfle3mOc
I
1
w
-------
c: k.
s I
E
3
e .2
.§> a,
J • Q
i I
< a
s
- '.a 2
3 -S
x . |
,- s S? i
= fe "H
= ~ >
- = S <
w X
a. I.
1 S1!
„ = S ^
= 5 " ,r
5 s < ;
1
3 : §
*!
a S
i I a «
3 < Q H
"So E
|
!•
«t
c-
oooono
oo oo
.•H O O
r4 vo
\o ^— oc
CO — "~
o" O o"
S 8
O O
£>
«..
00
g
1
s
W
oo oo tn
fo o\ o in
o o f*i o o
1
"O
1
vo
H
ooooooo
i in in o
o.
T3
O
-------
i
1
&
§,
"5
s
.0*
•o
te
1
TJ>
CO
CU
CO
z
1
s
.1
i
O
i
I
S
CO
ble Excculive
a
>. o E
f
1 2!
1 > g
S •< ^
O -3 2
& «
o "D
e* cs
S K >, 1
3 *s »5
y3 o *^
• ^
8 2
O
S
-1 1
j < a £
o §J x
S 4* 5
a 1
O v M
g> 55 |
~ - .-.
•§ <=> |
« 2
i
jwj
5
e
i I & I
3 < Q H
>> o E
•3 M 3
HI
*g ^j< ^3
< n
o **
ce s
S M E
» 1 "B
» a J
J2
»
i^
p e> — «
*& t'f 1
_§<
£• *•
w •§> E
< 0 S
O C5 2
£
£
"S
g
§
B<
•3
&.
a\ r*-
o c*i *o r*
ffi S °'
es ' NO
ON ' oo
ro \o o" o
NO »-•
© S
— uS O O
r-
o vo i~< en (M o m co f^ *^o
COO O i-5 O O O CO O O O
en fo *^
es • es
t*- t*- r- vo o o t*-
r< r» " " *"" ™'in"r-
so CN
-cdvi o'oooo.r^o 'oo
M ON M fO fS
c«en oo ^Oe7O^ O\O\
u O 0 S ? ? ? ? ? S S S
*
w
B • .
i ' .
QH ^ JS*
2 « 1 1
p § 1 & 1 - fe.
g W j§^SE|,.fe-§ |
IfSgiiiiiliiiii
UCQOHS^^CaOUOUO^S
in o vo so
vo d f*~ *n TH v)
Os *"T ON c? O CO
0
en
r* T en
*-< o\ i-( en ^H
O ^S| CN ^ O CO
*4 O Cs O O Tf
«
m CM in o co
ON en o o o co
O* O CN O" O* ' O
ON r-
ON vo r*=- o= o oe
o ** o in ^ o
r« o o •<* - . o.- .. o
o
in 1-1 w1-- co
en d d co = - do
r, G ' • gSS
^ O o" en o' O*
co M r- 2 oo
o vo 12 m o in in
o o o o o o o
oo in ON oo ,
r- »-* o o o o vo
o o o o o o o
_
en o o S ° «o
o o" o o o o" o
SSSS2SS2 ^ „ « T „ r.
S-SSoS'Soi ssffi^ss
r-t-r-t-c-r-t-^ voosvoi-«r-co
O)
1
A 0)
w •§ 2
H 03
i B 1 I M
e = eS o 5 tiuS
=j 5 S3 sa>^..5 = g
ta HM 3 3 S3 Z S a, « a* ° S
tlll.sll.1 ilflill
SzcocoHH>s]O<:<:<(aeas5
S
w
-------
u
^»
o
Sfl
V
3
5
(X)
1
.a
i
k.
O
M
£"
jr
i
V)
o"
^
1
33
3
I
i
5
-o
n
T3
C
55
(X
.3
•8
1
I
-2-
03
g
tin
«
1
CQ
g
£
do
3
in
U
>> u E
•s DC :
£ a S
HI
E
^™* M
a g
|»t
< a H -
f a 1
1 2 J
o §i ^"
S -5 |
E
P
P a
III
>> « s
S w) 3
HI
H
•S? c
Q 'g
S
„
t8>
Sr
t2
>» U
*; S
"So E
1U g
e! z '
2
a
u
E
Pollutant Para
t^
rj
o
oo
ON
O
«
?!
0
oo
oo
Carbazole
*H in
tn S
o o
oo
r^ c\
ON \0
^4 O
^ s
32 g
O 0
tn
o
oo
*^
ON
O
oo
3
m m
i s 2
— — g
U (5 Q
i i =
\o
m
o
ro
o
o
0
o
m
r^-
1
Q)
«
2,3-Dichloroar
ob
so
o
o
m
in
o
o
r-
o
0
o
SO
o
Fluoranthcne
0
o
ON
00
tn
o
R
0
rrt
in
s
m
n-Octadecane
oo
0
in
f)
p
,
£
oo
o
o
f*J
(O
•o
0
,-)
SO
2
0>
jSi
2
I
SO
O
o
m
w
o
0.0858
M
oo
00
"o
c
n
o
„,..
JJT"
.-§
P
c3
c
B-
c»
_g
O\
«
H
ra
a
dc
iS
CQ
"c
o
J3
8
c
§
o
<§
s.
•a
OJ
aj
on
- The promul
#
I
a
-------
^^
£
1
"55
c
f
cstream co
%
sgory D mixed w
brSubcat
1
CO
;cls and NS!
s
b>
1
Table Executive Summary-4. CWT
anlcs (B & c;
S?
5
„
5
1
o
\
ls(A&B)
O
3
*
a
r
i
^
5
j?
i
»
£> 0
1 ? 1
0 0 g
i V
W 3
ll
^ a a 2
til
I ^
1 E
w §
I
if'ii
>. 0 £
1 2-i
C 1« ^
S " a
1 1
£" *
a S
£ °
J= M c
n S •=
0 0 g
i I
=? "i
.,*.••
5 £ •€ Q £
&fe-
CAS
Pollutant Parameters Regis
Numl
m oo o
VJ T*> fl
\0 CM Tf
— * 06
>* CM
fM ON CM.rt CM OO CM f- —1 OO
m vo oo in ON oo
fS — •* oo c*l
C3
W
W-
1
S
W
-------
0"
jf
c
a
M
o
o
o
i
S
'S
on
£r
O
£
K.
i
pa
S
5
a
U
=a
ee
^
»
s
5
.2
5
£
a
u
1
w
1
•3
1
•n
c
S
|
[7
M
5
55
1
!
•3
Is
CS
i
f1 S
(!
S
F
t.
, E
i"
5 ^j ^
1
t'i
Q S
£& &
>> a, I
HI
s 3 s
1
•if
Q S
ff>
t2
Number
oc
o
0
oo
oo
1— <
0
o
o
o
r-
oo
oo
o
o
=,»
oo
oo
o
3
0
io
oo
o
o
oo
oo
0
o
tn
8
o
1
I
o>
2
s
=
Butylbenzyl \
vo
r^
0
oo
ON
0
tn
o
i>
**i
o
°°,
in-
o
0
t-
o
oo
ON
o
5
o
00
oo
Carbazole
IT
0
ON
*•«
OO
o
VO
o
^
g
0
vo
tn
o
0\
^
i
o
oo
"o
H
u
o
in
c
0
oo
ON
vo
0
CM
oo
o
o
(S
o
oo
ON
o
CN
g
CJ
1
00
S
0
CN
OO
vo
O
O
in
1
o
"e
U
cu
r- vc
^ c:
0 0
ON O
0 0
o
OO CO
S g
O O
(£
O
o
PJ
r-
0
o
o
0
rn
"^'
o
°°,
ON
O
oo
0
•^ o
o o
^
CO f*3
^ f^
ON O
0 0
O
oo m
s s
o o
in in
oo r-.
^ <**
4 00
2 g
u
n
Hs
c
C3
n-Decane
2,3-Dichloro
00
S S
0 0
r-
in co
o m
0 0
CO
si
CJ
0 0
0 f?
5 3
VO ^
O ON
f4 m
Fluorantheni
n-Octadecam
'"*
VO
(T>
S
o
oo
o
in
VO
fn
s
0
00
o
s
">
a
ci
oo
I
ts vo
CO O
0 0
*
r- tj
0 0
oo
— < o;
O 0
00 C
0 0
o in
r- v
o o
"oc
0 0
fS NO
GO C
o o
o in
r^ m
0 0
00
vo tn
*— ' OO
5 o
3 •?
oo vo
1-N 00
i— < GO
"o
s
a
£
Pyridine
2,4,6-Trichlo
.3
•2
_g
a\
vo
5
a,
"i
§
^>
o,
T3
S
O.
H
I
-------
I
>,
a
J*~>
g
w
1
1
«
S
•0
&
H
>
O
&
j£
3
W
2
'able Exccuti1
*-*
u
1*
ea
S
S
j3
3
1
"£
1
?.
o
¥
g
y?
A
5
•»
'
i
l H
S c* *
1
i
M E
3
— * X
a i
g
fw e>
fst-
f-
tfj
•s 111
C3
1 S
S
£3 X
Q S :
5 < Q E-
>k 0 §
•s ea e
I S 1
| III
1
co E
•— * x
S §
I, ! 6 3
III I
•li
< I1 1
6 « 2
v>
ij
S
1
"c
I
in *-t m ve
^ VO O fl
o\ in (S o
G9 O O O
oo en
»•*-•• -- - - M o\ c^
O O\ VO O
*-I t-H O O
CM O
o" o* o o"
SSSSS'Pcs S vcSS-S
oo^cooori o TJ- o o mo
t^- t^ t^_ m.M ^ o\ r-es t*«
r^-vos-^^rcsin r^ os = r< m« r; rx
* tn' "" "
ooo't^oo',— o mo'o" o o o o o ,
* en • t-
cscs^ri e^ oo\^roo
^ ,2 ^i^^^i mo o\so^^or40o
oo o in • o ^r § ^* o m^^oooor4
*^ in
g
o"o o — oo'vooo" — 0000*00
«££££££ SSS25SSSSS 2 «?;
1
.=
S * m
to ^ H & .S
H ^ 2 s " ^1
-------
£ !
I I
3 w
f'g. E
~ S .3
ir
2
fr
3
«3
v)
6
til
II*
03 .
a S
tl
2 'Si E
•< W 3
O DS '2:
s
00
-------
o
a
I
B C I
5 S «
S
ovao
V)
o o-
c5
c\
-^«Sr~^-« « i »K=,2S_
^•OCOO\COCNO t^^ONm^fncNvovD^
OOOOOOOf^OOCNv^OOOOOO
^S oosSoo
ooooooo^ooenrni-^oooocN
m
0000000*00-0 — —^cJooooo
en
ON
en
•»oooas.oonoo
oo\o c--
— o c
oo o
*. i
f fl
^1
a S
*o ON
o o
vo, — •
— vi
— • -^
c3 o*
-
en
CN
! ;
"3 DU
" PJ
§ » "i
vi envoo^
s
cn — « oo m
-------
-------
1
o
Q>
1
n
J"°
c
I
CO
c*
•g
C3
1
3
.i
2
|s
t~
i
CO
o
_>
i
JJ
2
^
H
E
>. 0 §
1 2l
fS > £
2 -< 2
& 1'
1 " i
w £? x
i 73 K
3 <§ S
"5
* 1 a
fill
>» O 3
•3 CO n
= g J
a -a 1 1 1
fr |
i 1
| w |-
3 >» ^''
* ^ a
^2 P !S
O
|
*£ |.§ »
5 < Q iS
E
1 •§ i -1 i
3£ ^
1 w - §
1 *l
i Si
S
s §
lilt
u1 ^
< "1 i
o K z:
„
0
E
g
5
Is
^
*o
c-
° I/I i~* V) NO
\O NO O fl
OS U1 *S O
O o O O
1-H
»-< es Cs t*>
O O\ NO O
^ -^ 0 C3
«M]O »n i-(Noi>
OOOOOOON o TT o o o
"" r- t- « o o m woo oo
ooovooom o 0600 o
* in
ro — ' ' to t*- oo r-- CM ' — • oo
o* o c> f- o '• o" »-* o" c*io"o" o
,
ON
cs r- i-i oo r-»
r«^^ OOi-iO M^ •^•'^•OI^^^NO
OO O tn O t-4 f® O O i-t O O O O O O
« r-
'^ NO ^ O\ •* MO vi. 'V M O o* ^* t^
oo oinoTrg-HO fn^oooocs
S
O\ O VI -^ OO ON O
oo* o" — o* o NO o o" — * ooooo'o
-VO^O^^U,^.,^
soooCNfnt^oo^ rsr-ootNONr* »-«' fMr^No r^oor^l^ll"'1jl
^OO^^^^ ONOsONOWOOOOO °??^^ « *•*
' s
"e3
JZ
to •*•• -,
td J3 2
"5 *-N H &• .5
w *i >, £3» ^
2 -s ' < g . - «
I §~ i §1« ni ^Ll , ll if 111 li
f~^c S*S*S 2^ a « "« ^ *^* "o^^ccacSCS Ci *£ r1! o Q "^
'00
g
'•§
o
(D
^
-------
I*
e
i 131
o
S
£?
o.
1 Sf E
III
i
CO
R
D S
O CN
O O
I!,
—; X
Q S
£+ c*
*I
S,
. S
T 7
vo m
o a\
r* »/l
C S ;S
C T3 >.
2 S E-
o a >4
-------
i
f
1
-as-
vastcstream c
•a
•1
Q
>,
1
1
standards
ets and PSl
F
c
u
.-a
^
Table Executive Summary-8. C
•anics (B & C)
c
o
^^
rganics (A & C
0
Oils (A & 11)
s
>
3
i
:
i
b
5
I
!
*
Standards
(7
e<
5
Standards
}
Standards
i
f?
5
e
63
S
8
I
<
O
*o I
S a1 1
- g § g
s< I
1
— -I
K •§" |>
* „ 1
= a. E
§ g g
E
Iff
»« 1
1 §1
S -5 S
1
Q S
< Q £
|||
S •< «3
E
7a S
Q IS
I 52
I'll
$*
s
Pollutant Parameters F
is
o
o
s
o"
s s
0 0
o o
CM
S S3
5 o
. 5 S
0 0
a\
m m
2 §
o* o
.,
J3 12
0 §
O 0
<=> r«
v> 00
0 0
METAL ANALYTES
Antimony 7
Arsenic 7
oo
o
o
s
vo
o
0
i
S3
o o
o
— oo
S 8
o o
.«
5r 5?
o
CM °°
CM 0
o o
„ CN
ON en
o o
i 1
*n *o
en
o od
0 vo
S g
o S
O ' *-c
m o
— ; o
S S
o o
§ S
o o
..
? M
S3 2
O Ck
„ ^.
ti CO
Chromium 7
Cobalt 7
00 V) O i-l vo *-i
OCNTTTr2^oovci1
OOi-NOOOOOO
r^ o ON ^»- oo
s
VI 'rt' OO ON ^
0 0 — 0 0 0' 0* 0* O*
ON
g ^ j.- o oo g
o?s-«oooooo
r* O ON TT GO
omfni-foooor1*.
8.
S -*vo OOCM oo lovi —
o — — oooooo
t- »-t 00 (S
o in COV>OI-HVOM
«*1 O ON ^ CO
o<=>ON\o^rror^ oo
OON— 'CNOOOO*5f
oo— oooooo
vot-'OfSTrvive^vo
r^oor4ONC4*«4Nr4 vo
ONONOtSOOOO O
en
u
i V ^
&• 1 - 1 ill
| || j | = 1 1 s |
^H vo *•* VI t^-. VI
f-i n m r4 -^ c
oooooo
V) OO CO CO f
O O i-H O O O
ts — >o oo oo f
vp
-------
=8
a
•3 s
I
S
'I-I
2 I
I
cc
Q-S-
^ s
«
O r^i
0 0
0 <*)
0, 0 '
s S
o o
£ S S
rn
0 OS CO
in oo
1 9 -:
•t?
«
3-
o
3
o
-------
-------
Chapter
BACKGROUND
This chapter provides background
information on the development of this final
rule. The first sections detail the. legislative
background while the later sections provide
information on the 1995 CWT proposal, 1996
CWT Notice of Data Availability, and the 1999
CWT supplemental proposal.
LEGAL AUTHORITY
1.0
These regulations are proposed'under the
authority of Sections 301, 304, 306, 307, 308,
402, and 501 of the Clean Water Act, 33
U.S.C.1311,1314,1316,1317;1318,1342,and
1361.
LEGISLATIVE BACKGROUND
Clean Water Act
1.1
1.1.1
Congress adopted the Clean Water Act
(CWA) to "restore and maintain the chemical,
physical, and biological integrity of the Nation's
waters" (Section 101(a), 33 U.S.C. 1251(a)).
To achieve this goal, the CWA prohibits the
discharge of pollutants into navigable waters
except in compliance with the statute. The Clean
Water Act confronts the problem of water
pollution on a number of different fronts. Its
primary reliance, however, is on establishing
restrictions on the types and amounts of
pollutants discharged from various industrial,
commercial, and public sources of wastewater.
Congress recognized that regulating only
those sources that discharge effluent directly into
the nation's waters would not be sufficient to
achieve the CWA's goals. • Consequently, the
CWA requires EPA to promulgate nationally
applicable pretreatment standards which restrict
pollutant discharges for those who discharge
wastewater indirectly through sewers flowing to
publicly-owned treatment works (POTWs)
(Section 307(b) and (c), 33 U.S.C. 1317(b) &
(c)). National pretreatment standards are
established for those pollutants in wastewater
from indirect dischargers' which- may pass
through or interfere with POTW operations.
Generally, pretreatment standards are designed
to ensure that wastewater from direct and
indirect industrial dischargers are subject to
similar levels of treatment. In addition, POTWs
are required to implement local treatment limits
applicable toJheir industrial indirect dischargers
to satisfy any... local requirements (40 CFR
403.5):
Direct dischargers must comply with effluent
limitations in National Pollutant Discharge
Elimination System ("NPDES") permits; indirect
dischargers must comply with pretreatment
standards. These limitations and standards are
established by regulation for categories of
industrial dischargers and are based on the
degree of control that can be achieved using
various levels of pollution control technology.
Best Practicable Control Technology
Currently Available (BPT) -
Sec. 304(b)(l) of the CWA
1.1.1.1
In the guidelines, EPA defines BPT effluent
limits for conventional, priority,1 and non-
'In the initial stages of EPA CWA regulation, EPA
efforts emphasized the achievement of BPT
limitations for control of the "classical" pollutants
(for example, TSS, pH, BODS). However, nothing
on the face of the statute explicitly restricted BPT
limitation to such pollutants. Following passage of
the Clean Water Act of 1977 with its requirement
for points sources to achieve best, available
1-1
-------
Chapter 1 Background
Development Document for the CWTPoint Source Category
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 also considers: 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~facflities-withhr the
industry of various ages, sizes, processes or
other common characteristics. Where, however,
existing performance is uniformly inadequate,
EPA may require higher levels of control than
currently in place in an industrial category if the
Agency determines thatthe technology can be
practically applied.
Best Conventional Pollutant Control
Technology (BCT) - Sec. 304(b)(4)
of the CWA 1.1.1.2
The 1977 amendments to the CWA required
EPA to identify effluent reduction levels for
conventional pollutants associated with BCT
technology for discharges from existing industrial
point sources. In addition to other factors
specified in Section 304(b)(4)(B), the CWA
requires that EPA establish BCT limitations after
consideration of a two part "cost-reasonableness"
test EPA explained its methodology for the
development of BCT limitations in My 1986 (51
FR 24974).
Section 304(a)(4) designates the following as
conventional pollutants: biochemical oxygen
(continued on next page)
technology limitations to control discharges of
toxic pollutants, EPA shifted the focus of the
guidelines program to address the listed priority
pollutants. BPT guidelines continue to include
limitations to address all pollutants.
demand (BOD5), 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).
Best Available Technology
Economically Achievable (BAT) —
Sec. 304(b)(2) of the CWA 1.1.1.3
In general,, BAT effluent limitations
guidelines represent the best economically
achievable performance of plants in the industrial
subcategory or category. The factors considered
in assessing BAT include the cost of achieving
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.
New Source Performance Standards
(NSPS) - Sec. 306 of the CWA
1.1.1.4
NSPS reflect effluent reductions that are
achievable based on the best available
demonstrated control technology. New facilities
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
1-2
-------
Chapter 1 Background
Development Document for the CWTPoint Source Category
available control technology for all pollutants
(that is, conventional, nonconventional, 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.
Pretreatment Standards for Existing
Sources(PSES)~~ Sec. 307(b)ofthe
CWA _.. 1.1.1.5
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 (POTW). The
CWA authorizes EPA to establish pretreatment
standards for pollutants that pass-through
POTWs or interfere with treatment processes or
sludge disposal.: methods. at POTWs;
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 at 40 CFR Part 403. Those
regulations contain a definition of pass-through
that addresses localized rather than national
instances of pass-through and establish
pretreatment standards that apply to all
non-domestic dischargers. See 52 FR 1586,
January 14, 1987.
Pretreatment Standards for New
Sources (PSNS) - Sec. 307(b) of
the CWA
1.1.1.6
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.
Section 304(m) Requirements and
Litigation
1.1.2
Section 304(m) of the CWA, added by the
Water Quality Act of 1987, requires EPA to
establish schedules for (1) reviewing and revising
existing effluent limitations guidelines and
standards- ("effluent guidelines") and (2)
promulgating new effluent guidelines. On
January 2, 1990, EPA published an Effluent
Guidelines Plan (55 FR 80) that established
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 Centralized Waste
Treatment Industry.
The Natural Resources Defense Council
(NRDG) and Public Citizen, Inc. filed suit
against the Agency, alleging violation of Section.
304(m) and other statutory authorities requiring
promulgation of effluent guidelines (NRDC et
al. v. Browner. Civ. No. 89-2980 (D.D.C.)).
Under the terms of a consent decree, dated
January 31, 1992, which settled the litigation,
EPA agreed, among other things, to propose
effluent guidelines for the "Centralized Waste
Treatment Industry Category by April 31, 1994
and take final action on these effluent guidelines
by January 31, 1996. On February 4, 1997, the
court approved modifications to the Decree
which revised the deadline to August 1999 for
final action.. EPA provided notice of these
modifications on February 26, 1997 at 62 FR
8726. Due to the need to examine issues raised
during the Small Business Advocacy Review
(SBAR) process, the court approved a
modification to the Decree that again extended
the deadline for final action to August, 2000.
1-3
-------
Chapter 1 Background
Development Document for the CWTPoint Source Category
The Land Disposal
Restrictions Program: 1.1.3
Introduction to RCRA Land Disposal
Restrictions (LDR) 1.1.3.1
The Hazardous and Solid Waste
Amendments (HSWA) to the Resource
Conservation and Recovery Act (RCRA),
enacted on November 8, 1984, largely prohibit
the land disposal of untreated hazardous wastes.
Once a hazardous waste is prohibited from land
disposal, the statute provides only two options
for legal land disposal: meet the treatment
standard for the waste prior to land disposal, or,
dispose of the waste in a land disposal unit that
has been found to satisfy the statutory no
migration test A no migration unit is one from
which there will be no migration of hazardous
constituents for as long as the waste remains
hazardous (RCRA Sections 3004 (d),(e),(g)(5)).
Under section 3004, the treatment standards
that EPA develops may be expressed as either
constituent concentration levels or as specific
methods of treatment. The criteria for these
standards is that they must substantially diminish
the toxicity of the waste or substantially reduce
the likelihood of migration of hazardous
constituents from the waste so that short-term
and long-term threats to human health and the
environment are minimized (RCRA Section
3004(m)(l)). For purposes of the restrictions,
the RCRA program defines land disposal to
include any placement of hazardous waste in a
landfill, surface impoundment, waste pile,
injection well, land treatment facility, salt dome
formation, salt bed formation, or underground
mine or cave. Land disposal restrictions are
published in 40 CFR Part 268.
EPA has used hazardous waste treatability
data as the basis for land disposal restrictions
standards. First, EPA has identified Best
Demonstrated Available Treatment Technology
(BDAT) for each listed hazardous waste.
BDAT is that treatment technology that EPA
finds to be the most effective for a waste which
is also readily available to generators and
treaters. In some cases, EPA has designated, for'
a particular waste stream, a treatment technology
which has. been shown to successfully treat a
similar, but more difficult to treat, waste stream.
This ensured that the land disposal restrictions
standards for a listed waste stream were
achievable since they always reflected the actual
treatability of the waste itself or of a more
refractory waste.
As part of the Land Disposal Restrictions
(LDR), Universal Treatment Standards (UTS)
were promulgated as part of the RCRA phase
" two final rule (July 27,1994). The UTS are a
series of concentrations for wastewaters arid
non-wastewaters that provide a single treatment
standard for each constituent. Previously, the
LDR regulated constituents according "to the
identity of the original waste; thus, several
numerical treatment standards might exist for
each constituent. The UTS simplified the
standards by having only one treatment standard-
for~each constituentin_any, waste.residue.
The LDR treatment standards established
under RCRA may differ from the Clean Water
Act effluent guidelines proposed here today both
in their format and in the numerical values set for
each constituent. The differences result from the
use of different legal criteria for developing the
limits and resulting differences in the technical
and economic criteria and data sets used for
establishing the respective limits. The
differences in format of the LDR and effluent
guidelines is that LDR establishes a single daily
limit for each pollutant parameter whereas the
effluent guidelines establish monthly and daily
limits. Additionally, the effluent guidelines
provide for several types of discharge, including
new vs. existing sources, and indirect vs. direct
discharge. .'
The differences in numerical limits
established under the Clean Water Act may
differ, not only from LDR and UTS, but also
from point-source category to point-source
category (for example, Electroplating, 40 CFR
1-4
-------
Chapter 1 Background
Development Document for the CWTPoint Source Category
Part 413; and Metal Finishing, 40 CFR Part
433). The effluent guidelines limitations and
Standards are industry-specific, subcategory-
specific, and technology-based. The numerical
limits are typically based on different data sets
that reflect the performance of specific
wastewater management and treatment practices.
Differences in the limits reflect differences in the
statutory factors that the Administrator is
required to consider in developing technically and
economically achievable- limitations- and
standards — manufacturing products and
processes (which, for CWTs involves types of
waste received for treatment), raw materials,
wastewater characteristics, treatability, facility
size, geographic location, age of facility and
equipment, non-water quality environmental
impacts, and energy requirements. A
consequence of these differing approaches is that
similar waste streams can be regulated at
'different levels.
Overlap Between LDR Standards and
the -Centralized Waste Treatment
Industry Effluent Guidelines
1.1.3.2
EPA's survey for this guideline identified no
facilities discharging wastewater effluent to land
disposal units. There is consequently no overlap
between the proposed regulations for the CWT
Industry and the Universal Treatment Standards:
Any CWT facility, however, discharging effluent
to a land disposal unit that meets these limitations
'and standards would meet the Universal
Treatment Standards.
"centralized waste treatment facilities." As
proposed, these effluent limitations guidelines
and pretreatment standards would have applied
to "any facility that treats any hazardous or non-
hazardous industrial waste received from off-site
by tanker truck, trailer/roll-off bins, drums, barge
or other forms of shipment." Facilities which
received waste from off-site solely from via
pipeline were excluded from the proposed rule.
Facilities proposed for regulation included both
stand-alone waste treatment and recovery
facilities that treat waste received from off-site as
well as those facilities that treat on-site generated
process wastewater with wastes received from
off-site.
The Agency proposed limitations and
standards for an estimated 85 facilities hi three
subcategories. • The subcategories for the -
centralized waste treatment (CWT) industry-
were metal-bearing waste treatment and
recovery, oily waste treatment and recovery, and-
organic waste treatment and recovery. EPA
based the BPT effluent limitations proposed in
1995 on the technologies listed in Table 1.1
below. EPA based BCT, BAT, NSPS, PSES,
and PSNS on the same technologies as BPT.
CENTRALIZED WASTE TREATMENT
INDUSTRY EFFLUENT GUIDELINE
RULEMAKING HISTORY
January 27,1995 Proposal
1.2
1.2.1
On January 27, 1995 (60 FR 5464), EPA
proposed regulations to reduce discharges to
navigable waters of toxic, conventional, and non-
conventional pollutants hi treated wastewater
from facilities defined in the proposal as
1-5
-------
Chanter 1 Background
Development Document for the CWTPoint Source Category
Table 1-1. Technology Basis for J995 BPT Effluent Limitations
Proposed Name of
Subpart Subcategory
Technology Basis
Metal-Bearing
Waste Treatment and
Recovery
Selective Metals Precipitation, Pressure Filtration,
Secondary Precipitation, Solid-Liquid Separation, and
Tertiary Precipitation
For Metal-Bearing Waste Which Includes
Concentrated Cyanide Streams:
Pretreatment by Alkaline Chlorination
at Elevated Operating Conditions-
B
C
Oily Waste
Treatment and
Recovery
Organic Waste
Treatment and
Recovery
Ultrafiltration or Ultrafiltration, Carbon Adsorption, and
Reverse Osmosis
Equalization,-AirStripprng, Biological-Treatment; and
Multimedia- Filtration
September 16,1996 Notice of Data
Availability
1.2.2
Based on comments received on the 1995"
proposal and new information, EPA reexamined
its conclusions about the Oily Waste Treatment
and Recovery subcategory, or "oils
subcategory". (The 1995 proposal had defined
facilities in this subcategory as "facilities that
treat, and/or recover oil from oily waste received
from off-site.") Subsequently, in 1996 EPA
noticed the availability of the new data on this
subcategory. EPA explained that it had
underestimated the size of the oils subcategory,
and that the data used to develop the original
proposal may have mischaracterized this portion
of the CWT industry. EPA had based its original
estimates on the size of this segment of the
industry on information obtained from the 1991
Waste Treatment Industry Questionnaire. The
basis year for the questionnaire was 1989. Many
of the new oils facilities discussed in this notice
began operation after 1989. EPA concluded that
many of these facilities may have started up or
modified their existing operations in response to
requirements in EPA regulations, specifically, the
provisions of 40 CFR 279, promulgated on
September 10, 1992 (Standards for the
Management of Used Oil). These regulations
govern the handling of used oils under the Solid
Waste Disposal Act and CERCLA. EPA's 1996
notice discussed the additional facilities, provided
a revised description of the subcategory and
described how the 1995 proposal limitations and
standards, if promulgated, would have affected
such facilities. The notice, among other items,
also solicited comments on the 'use of dissolved
air flotation in this subcategory.
January 13,1999 Supplemental
Proposal
1.2.3
On January 13, 1999 (64 FR 2280), EPA
published a supplemental proposal which
represented the Agency's second look at Clean
Water Act national effluent limitations and
standards for wastewater discharges from
centralized waste treatment facilities. The
supplemental proposal presented revised
limitations and standards based on :the new
information obtained from comments to the 1996
1-6
-------
Chapter 1 Background
Development Document for the CWT Point Source Category
Notice of Data Availability and additional field
sampling data. It also included changes to the
scope of the rule.
In the supplemental proposal, the Agency
proposed limitations and standards that EPA
estimated would apply to 206 facilities in three
subcategories. These subcategories were the
same as those proposed in 1995: metal-bearing
waste treatment and recovery, used/waste oil
treatment and recovery, and organic waste
treatment. EPA based the BPT effluent
limitations proposed in 1999 on different
technologies than those selected at the time of
the 1995 proposal. The technology basis for the
supplemental proposal are listed in Table 1.2
below.
Table 1-2. Technology Basis for 1999 Supplemental Proposal
Proposed Name of
Subpart Subcategory
Technology Basis
B
Metal-Bearing
Waste Treatment and
Recovery
Used/Waste Oil
Treatment and
Recovery
Organic Waste
Treatment
Batch Precipitation, Liquid-Solid Separation, Secondary
Precipitation, Clarification, and Sand Filtration
For Metal-Bearing Waste Which Includes Concentrated
Cyanide Streams:
Alkaline Ghlorination-m a-two step process•---•'
Emulsion Breaking/Gravity Separation, Secondary Gravity"
SeparatkHrand'Dissolved Air Flotation-
Equalization and Biological Treatment
For the metals subcategory, EPA proposed
limitations and standards for BCT, BAT, and
PSES based on the same technologies as BPT,
but based NSPS and PSNS on a different
technology: selective metals precipitation, liquid-
solid separation, secondary precipitation, liquid-
solid separation, tertiary precipitation, and
clarification.
For the oils subcategory, EPA proposed to
base BCT, BAT, NSPS, and PSNS on the same
technologies as BPT, but based PSES on a
different technology: emulsion breaking/gravity
separation and dissolved air flotation.
For the organics subcategory, EPA based
BCT, BAT, NSPS, PSES, and PSNS on the
same technologies as BPT.
1-7
-------
-------
Chapter
DATA COLLECTION
EPA gathered and evaluated technical and
economic data from various sources in the
course of developing the effluent limitations
guidelines and standards for the centralized waste
treatment industry. These data sources include
the following:
• EPA''sPreliminaryData Summary for the
Hazardous Waste Treatment Industry,
• Responses to EPA's "1991 Waste
Treatment Industry Questionnaire";
• Responses to EPA's "Detailed Monitoring
Questionnaire";
• EPA's 1990 - 1997 sampling of-selected-
Centralized waste treatment facilities;
• EPA's 1998 characterization sampling of oil
treatment and recovery facilities;- :
• Public comments, to EPA's, 1995 Proposed
Rule;
• Public comments to EPA's 1996 Notice of
Data Availability;
• Public comments to EPA's 1999
Supplemental Proposal;
• Contact with members of the industry,
environmental groups, pretreatment
coordinators, Association of Municipal
Sewage Authorities (AMSA), regional, state,
and other government representatives; and
• Other literature data, commercial
publications, and EPA data bases.
EPA used data from these sources to profile
the industry with respect to the following:
wastes received for treatment and/or recovery;
treatment/recovery processes; geographical
distribution; and wastewater 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.
The remainder of this chapter details the
data sources utilized in the development of this
final rule.
PRELIMINARY DATA SUMMARY
2.1
EPA began an effort to develop effluent
limitations guidelines and pretreatment standards
for waste treatment operations in 1986. In this
initial study, EPA looked at a range of facilities,
including centralized waste treatment facilities,
landfills- and industrial waste combustors, that
received hazardous waste from off-site for
treatment, recovery,'or disposal. The purpose of
the- study.-was-.io characterize the hazardous
waste treatment industry, its operations, and
pollutant discharges into national waters. EPA
published the results of this study in the
Preliminary Data Summary for the Hazardous
Waste Treatment Industry in 1989 (EPA
440/1-89/100). During the same time period,
EPA conducted two similar, but separate, studies
of the solvent recycling industry and the used oil
reclamation and re-refining industry. In 1989,
EPA also published the results of these studies in
two reports entitled the Preliminary Data
Summary for the Solvent Recycling Industry
(EPA 440/1-89/102) and the Preliminary Data
Summary for Used Oil Reclamation and Re-
refining Industry (EPA 440/1-89/014).
Based on a thorough analysis of the data
presented in the Preliminary Data Summary for
the Hazardous Waste Treatment Industry, EPA
decided it should develop effluent limitations
guidelines and standards for the centralized waste
treatment industry. EPA also decided to develop
standards for landfills and industrial waste
combustors which were promulgated in the
2-1
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
Federal Register on January 19, 2000 (65 FR
3007) and January 27, 2000 (65 FR 4360)
respectively. In addition to centralized waste
treatment facilities, EPA also studied fuel
blending operations and waste solidification/
stabilization facilities. As detailed and defined in
the applicability section of the preamble to this
final rule, EPA has decided not to promulgate
nationally applicable effluent limitations
guidelines and standards for fuel blending and
stabilization operations at this time.
CLEAN WATER ACT SECTION308
QUESTIONNAIRES 2.2
Development of Questionnaires 2.2.1
Amajor source of information and data used
in developing the effluent limitations guidelines
and standards for the CWT category is industry
responses to questionnaires distributed by EPA
under the authority of Section 308 of the CWA.
EPA developed'two questionnaires, the 1991
Waste Treatmentlndustry Questionnaire and the
Detailed Monitoring Questionnaire, for this
study. The 1991 Waste Treatment Industry
Questionnaire was designed to request 1989
technical, economic, and financial data from,
what EPA believed to be, a census of the
industry. The Detailed Monitoring Questionnaire
was designed to elicit daily analytical data from
a limited number of facilities which would be
chosen after receipt and review of the 1991
Waste Treatment Industry Questionnaire
responses.
In order to minimize the burden to
centralized waste treatment facilities, EPA
designed the 1991 Waste Treatment Industry
Questionnaire such that recipients could use
information reported in their 1989 Hazardous
Waste Biennial Report as well as any other
readily accessible data. The technical portion of
the questionnaire, Part A, specifically requested
information on the following:
• Treatment/recovery processes;
• Types and quantities of waste received for
treatment;
• The industrial waste management practices
used;
• Ancillary waste management operations;
• The quantity, treatment, and disposal of
wastewater generated during industrial waste
management;
• Summary analytical monitoring data;
• The degree of co-treatment (treatment of
CWT wastewater with wastewater from
other industrial operations at the facility);
.• Cost of the waste treatment/recovery
processes; and
• The extent of wastewater recycling or reuse
at facilities.
Since the summary monitoring information
requested hi the 1991 Waste Treatment Industry
Questionnaire was- not- sufficient- for
determination of limitations and industry
variability,.. EPA designed a .follow-up
questionnaire, the Detailed Monitoring
Questionnaire (DMQ), to collect daily analytical
data from a limited number of facilities. EPA
requested all DMQ facilities to submit effluent
wastewater monitoring data hi the form of
individual data points rather than monthly
aggregates, generally for the 1990 calendar year.
Some facilities were also requested to submit
monitoring data for intermediate waste treatment
points in an effort to obtain pollutant removal
information across specified treatment.
technologies.
Since most CWT facilities do not have
analytical data for their wastewater treatment
system influent, EPA additionally requested
DMQ facilities to submit copies of then: waste
receipts for a six week period. Waste receipts
are detailed logs of individual waste shipments
sent to a CWT for treatment. EPA selected a six.
week period to rninimize the burden to recipients
and to create a manageable database.
EPA sent draft questionnaires to industry
trade associations, treatment facilities that had
2-2
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Catesorv
expressed interest, and environmental groups for
review and comment. EPA also conducted a
pre-test of the 1991 Waste Treatment Industry
Questionnaire at nine centralized waste treatment
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.
EPA did not conduct a pre-test of the Detailed
Monitoring Questionnaire due to the project
schedule limitations.
Based on comments from the reviewers,
EPA determined the draft questionnaire required
minor adjustments in the technical section and
substantial revisions for both the economic and
financial sections. EPA anticipated extensive
comments, since this was EPA's first attempt at
requesting detailed information from a service
industry as opposed to a manufacturing-based
industry.
As required by the Paperwork Reduction
Act, 44 U.S.C. 3501 et seq., EPA submitted the
questionnaire package (including the revised
1991 Waste Treatment Industry Questionnaire
and the Detailed Monitoring Questionnaire) to
the Office of Management and Budget (OMB)
for review, and published a notice in the Federal
Register to announce the questionnaire was
available for review and comment (55 FR
45161). EPA also redistributed the questionnaire
package to industry trade associations,
centralized waste treatment industry facilities,
and environmental groups that had provided
comments on the previous draft and to any
others who requested a copy of the questionnaire
package.
No additional comments were received and
OMB cleared the entire questionnaire package
for distribution on April 10, 1991.
Distribution of Questionnaires
2.2.2
In 1991, under the authority of Section 308
of the CWA, EPA sent the Waste Treatment
Industry Questionnaire to 455 facilities that the
Agency had identified as possible CWT facilities.
Because there is no specific centralized waste
treatment industry Standard Industrial Code
(SIC), identification of facilities was difficult.
EPA looked to directories of treatment facilities,
other Agency information sources, and even
telephone directories to identify the 455 facilities
which received the questionnaires. EPA
received responses from 413 facilities indicating
that 89 treated or recovered material from off-
site industrial waste in 1989. The remaining 324
facilities did. not treat or recover materials from
industrial waste from off-site. Four of the 89
facilities only received waste via a pipeline (fixed
delivery system) from the original source of
wastewater generation.
EPA obtained additional information from
the 1991 . Waste Treatment Industry
Questionnaire recipients through follow-up phone
calls and written requests for clarification of
questionnaire responses.
-After evaluation of the 1991 Waste
Treatment Industry Questionnaire responses,
EPAselected 20 in-scope facilities from the 1991
Waste Treatment Industry Questionnaire mailing
list to complete the Detailed Monitoring
Questionnaire. These facilities were selected
based on: the types and quantities of wastes
received for treatment; the quantity of on-site
generated wastewater not resulting from
treatment or recovery of off-site generated
waste; the treatment/recovery technologies and
practices; and the facility's wastewater discharge
permit requirements. All 20 DMQ recipients
responded.
WASTEWATER SAMPLING AND SITE VISITS 2.3
Pre-1989 Sampling Program 2.3.1
From 1986 to 1987, EPA conducted site"
visits and sampled at twelve facilities to
characterize the waste streams and on-site
treatment technology performance at hazardous
waste incinerators, Subtitle C and D landfills, .and
hazardous waste treatment facilities as part of the
2-3
-------
Chapter 2 Data Collection
Development Document for the'CWTPoint Source Category
Hazardous Waste Treatment Industry Study. All
of the facilities in this sampling program had
multiple operations, such as incineration and
commercial wastewater treatment. The sampling
program did not focus on characterizing the
individual waste streams from individual
operations. Therefore, the data collected cannot
be used for the characterization of centralized
waste treatment wastewater, the assessment of
treatment performance, or the development of
limitations and standards. Information collected
in the study is presented in Has Preliminary Data
Summary for the Hazardous Waste Treatment
Industry (EPA 440/1-89/100).
1989 -1997 Site Visits
2.3.2
Between 1989 and 1993, EPA visited 27
centralized waste treatment facilities. The
purpose of these visits was to collect various
information about the operation of CWTs, and,
in most cases, to evaluate each facility as a
potential week-long sampling candidate. EPA
selected these facilities based on .the information
gathered by EPA during the selection of the
Waste Treatment Industry Questionnaire
recipients and the subsequent questionnaire
responses.
In late 1994, EPA visited an additional four
facilities which specialize in the treatment of bilge
waters and other dilute oily wastes. These
facilities were not in operation at the time the
questionnaire was mailed, but were identified by
EPA through contact with the industry and
AMSA. EPA visited these facilities to evaluate
them as potential .sampling candidates and to
determine if CWT operations at facilities which
accept dilute oily wastes or used material were
significantly different than CWT operations at
facilities that accept concentrated oily wastes.
Following the 1995 proposal, EPA visited
nine centralized waste treatment facilities,
including eight additional oils facilities and one
metals facility which had also been visited prior
to the proposal. EPA selected these facilities
based on information obtained by EPA through
proposal public comments, industry contacts,
and EPA regional staff. In late 1997, EPA
visited two pipeline facilities identified prior to
the proposal (one via the questionnaire and the
second through review of the Organic Chemicals,
Plastics and Synthetic Fibers (OCPSF) database
and follow-up phone calls) in order to
characterize operations at pipeline facilities.
During each facility site visit, EPA gathered
the following information:
•- The process for accepting waste ,for
treatment or recovery;
• The types of waste accepted for treatment;
• Design and operating procedures for
treatment technologies;
• The location of potential sampling points;
• Site specific sampling requirements;
• Wastewater generated on-site and its
sources;""
•• Wastewater discharge option and limitations;
• Solid waste disposal practices;
• General facility management practices; and
• Other facility operations.
Site visit reports were prepared for all visits and
are located in the regulatory record for this
proposal.
Sampling Episodes
Facility Selection
2.3.3
2.3.3.1
EPA selected facilities to be sampled by
reviewing the information received during site
visits and assessing whether the wastewater
treatment system (1) was theoretically effective
in removing pollutants, (2) treated wastes
received from a variety.,of sources, (3) was
operated in such a way as to optimize the
performance of the treatment technologies, and
(4) applied waste management practices that
increased the effectiveness of the treatment unit.
EPA also evaluated whether the CWT
portion of each facility flow was adequate to
2-4
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
assess the treatment system performance for the
centralized waste treatment waste stream. At
some facilities, the centralized waste treatment
operations were minor portions of the overall site
operation. In such cases, where the centralized
waste treatment waste stream is commingled
with non-centralized waste treatment streams
prior to treatment, characterization of this waste
stream and assessment of treatment performance
is difficult. Therefore, data from these
commingled systems could not be used to
establish effluent limitations guidelines and
standards for, the centralized waste treatment
industry.
Another important consideration in the
sampling facility selection process was the
commingling of wastes from more than one
centralized waste treatment subcategory. For
example,- many facilities treated metal-bearing
and oily waste in the same treatment system. In
such cases, EPA did not select these facilities for
treatment technology sampling since EPA could
not determine whether a decrease in pollutant
concentrations in the commingled stream would
be due to an efficient treatment system, or
dilution.
Using the criteria detailed above, EPA
selected 14 facilities to sample in order to collect
wastewater treatment efficiency data to be used
to establish effluent limitations guidelines and
standards for the centralized waste treatment
industry. Twelve-facilities were sampled prior
to the 1995 proposal and .four facilities (two
additional and two resampled) were sampled
after the proposal. . •
Sampling Episodes
2.3.3.2
After EPA selected a facility to sample, EPA
prepared a draft sampling plan which described
the location of sample points, the analysis to be
performed at specified sample points, and the
procedures to be followed during the sampling
episode. Prior to sampling, EPA provided a
copy of the draft sampling plan to the facility for
review and comment to ensure EPA properly
described and understood facility operations. All
comments were incorporated into the final
sampling plan.
During the sampling episode, EPA collected
samples of influent, intermediate, and effluent
streams, preserved the samples, and sent them to
EP A-approved laboratories.. Facilities were given
the option to split samples with EPA, but most
facilities declined. Sampling episodes were
generally conducted over a five-day period
during which EPA obtained 24-hour composite
samples -for continuous systems and grab
samples for batch systems.
Following the sampling episode, EPA
prepared a draft sampling report that included
descriptions of the treatment/recovery processes,
samplingprocedures, and analytical results. EPA
provided draft reports to facilities for comment
and review. All corrections were incorporated
into the final report. Both final sampling-plans
and reports for all episodes are located in the
regulatory record for this promulgated rule.
The specific constituents analyzed at each
episode and sampling point varied and depended
on the waste type being treated and the treatment
technology being evaluated. At the initial two
sampling episodes, the entire spectrum 'of
chemical compounds for which there are
EP A-approved analytical methods were analyzed
(more than 480 compounds). Table 2-1
provides a complete list of these pollutants (this
is a more complete and accurate list than in the
1999 Technical Development Document). After
a review of the initial analytical data, the number
of constituents analyzed was decreased by
omitting analyses for dioxins/furans,
pesticides/herbicides, methanol, ethanol, and
formaldehyde. Pesticides/herbicides were
analyzed on a limited basis depending on the
treatment chemicals used at facilities.
Dioxin/furan analysis was only performed on a
limited basis for solid/filter cake samples to
assess possible environmental impacts.
Data resulting from the influent samples
2-5
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
contributed to the characterization of this
industry, development of the list of pollutants of
concern, and development of raw waste
characteristics. EPA used the influent,
intermediate, and effluent points to analyze the
efficacy of treatment at the facilities and to
develop current discharge concentrations,
loadings, and treatment technology options for
the centralized waste treatment industry. Finally,
EPA used data collected from the effluent points
to calculate the long term averages (LTAs) for
each of the regulatory options. The use of this
data is discussed in detail in subsequent chapters.
2-6
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
Table 2-1. Chemical Compounds Analyzed Under EPA Analytical Methods
Pollutant
Cas Num
CLASSSICAL WET CHEMISTRY
Amenable cyanide
Ammonia as nitrogen
BOD
BOD 5-day
Chloride
COD
DCOD
Fluoride
Hexane extractable material
Hexavalent chromium
Nitrate/nitrite
pH
Recoverable oil & grease
SGT-HEM
TDS
TOC
Total cyanide
Total phenols
Total phosphorus
Total solids
Totalsulfide
Total sulfide (iodometric)
TSS
C-025
766441-7 '
C-003
C-002
16887-00-6
C-004
G-004D
16984-48-8
G-036
18540-29-9
C-005
C-006
C-007
C-037
C-010
C-012
57-12-5
C-020
14265-44-2 '
C-008
18496-25-8
18496-25-8
C-009
1613: Diomis/FURANS
2378-TCDD
2378-TCDF
12378-PECDD
12378-PECDF
23478-PECDF-
123478-HXCDD
123678-HXCDD
123789-HXCDD
I23478-HXCDF
123678-HXCDF
123789-HXCDF
234678-HXCDF
1234678-HPCDD
1234678-HPCDF
1234789-HPCDF
OCDD
OCDF
Total HPCDD
Total HPCDF
Total HXCDD
Total HXCDF
Total PECDD
Total PECDF
Total TCDD
Total TCDF
1746-01-6
51207-31-9
"40321-764
57117-41-6
57117-31-4
39227-28-6
57653-85-7
19408-74-3
70648-26-9
57117-44-9
72918-21-9
60851-34-5.
35822-46-9
67562-39-4
55673-89-7
3268-87-9
39001-02-0
37871-00-4
38998-75-3
34465-46-8
55684-94-1
36088-22-9
30402-15-4
41903-57-5
55722-27-5
1618: PESTICIDES/HERBICIDES
2,4,5-T
2,4,5-TP
2,4-D
2,4-DB •
4,4'-DDD
4,4'-DDE
4.4'-DDT
93-76-5
93-72-1
94-75-7
94-82-6
72-54-8
72-55-9 '
50-29-3
Pollutant
Aldrin
Alpha-BHC
Alpha-chlordane
Azinphos ethyl
Azinphos methyl
Beta-BHC
Captafol
Captan
Carbophenothion
Chlorfenvinphos
Chlorobenzilate
Chlorpyrifos
Coumaphos
Dalapon
DEF
Delta-BHC
Demeton
Diallate
Diazinon
Dicamba
Dichlofenthion
Dichlone
Dichlorprop
Dichlorvos
Dicrotophos
Dieldrin
Dimethoate
Dinoseb
Dioxathion
Disulfoton
Endosulfan I
Endosulfan II
Endosulfan sulfate
Endrin
Endrin aldehyde.
Endrin ketone
EPN
Ethion
Ethoprop
Famphur
Fensulfothion
Fenthion
Gamma-BHC
Gamma-chlordane
Heptachlor
Heptachlor epoxide
HXMeth.phosphoramide
Isodrin
Kepone
Leptophos
Malathion
MCPA
MCPP
Merphos
MetHoxychlor
Methyl chlorpyrifos
Methyl parathion
Methvl trithion
Cas Num
309-00-2
319-84-6
5103-71-9
2642-71-9
86-50-0
319-85-7
2425-06-1
133-06-2
786-19-6
470-90-6
510-15-6
2921-88-2
56-724
75-99-0
78-48-8
319-86-8
8065-48-3
2303-164
333-41-5
1918-00-9
97-17-6
117-80-6
120-36-5
62-73-7
141-66-2
60-57-1
60-51-5
88-85-7
78-34-2
298-04-4
959-98-8
33213-65-9
1031-07-8
72-20-8
7421-934
53494-70-5
2104-64-5
563-12-2
1319448-4
52-85-7
115-90-2
55-38-9
58-89-9
5103-74-2
7644-8
1024-57-3
680-31-9
465-73^6
143-50X)
21609-90-5
121-75-5
94-74-6
7085-19-0
150-50-5
72-43-5
5598-13-0
298-00-0
953-17-3
Pollutant
Mevinphos
Mirex
Monocrotophos
Naled
Nitrofen
Parathion (Ethyl)
PCB1016
PCB 1221
PCB 1232
PCB 1242
PCB 1248
PCB 1254
PCB 1260
PCNB
Phorate
Phosmet
Phosphamidon
Phosphamidon E
Phosphamidon Z
Ronnel
Sulfotep
Sulprofos
TEPP
Terbufos
Tetrachlorvinphos
Toxaphene
Trichlorfon
Trichloronate
Tricresylphosphate
Trifluralin
Trimethylphosphate
Cas Num
7786-34-7
2385-85-5
6923-22-4
300-76-5
1836-75-5
56-38-2
12674-11-2
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
82-68-8
298-02-2
732-11-6
13171-21-6
297-994
23783-98-4
299-84-3-
3689-24-5
3540043-2
107-49-3
13071-79-9
22248-79-9
8001-35-2
52-68-6
327-98-0
-• 78-303
1582-09-8
512-56-1
/ 656: PESTICIDES/HERBICIDES
(l,2)DB-(3)C-propane
4,4'-DDD
4,4'-DDE
4,4'-DDT
Acephate
Alachlor
Aldrin
Alpha-BHC
Alpha-chlordane
Atrazine
Benzfluralin
Beta-BHC
Bromaqil
Bromoxynil octanoate
Butachlor
Captafol
Captan
Carbophenothion
Chlorobenzilate
Chloroneb
Chloropropylate
Chlorothalonil
Cis-permethrin
Dacthal (DCPA)
Delta-BHC
Diallate A
92-12-8
72-54-8
72-55-9
50-29-3
30560-19-1
15972-60-8
309-00-2
319-84-6
5103-71-9
1912-24-9
1861^tO-l
319-85-7
31440-9
1689-99-2
23184-66-9
2425-06-1
133-06-2
786-19-6
510-15-6
2675-77-6
5836-10-2
1897-45-6
61949-76-6
1861-32-1
319-86-8
2303-1 6-4A
2-7
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
Table 2-1. Chemical Compounds Analyzed Under EPA Analytical Methods (continued)
Pollutant
DiallateB
Dichlone
Dicofo!
Dicldrin
Endosulfan I
Endosulfan II
Endrin
Endrin aldehyde
Endrin kctone
Ethalfiuralin
Etridiazole
Fcnarimol
Gamma-BHC
Gamma-chlordane
Hcptachlor
Hcptachlor epoxide
Isodrin
Isopropalin
Kcpone
Mcthoxychlor '
Metribuzin
Mircx
Nitrofcn
Noflurazon
PCB1016
PCS 1221
PCS 1232
PCS 1242
FOB 1248
PCB1254
PCB1260
Pcndamcthalin
PCNB
Pcrthanc
Propachlor
Propanil
Propazine
Simazinc
Strobanc
Tctbacil
Tcrbuthylazine
Toxaphcne
Trans-pcrmethrin
Triadimcfon
Trifluralin
CasNum
230-3 16-4B
117-80-6
115-32-2
60-57-1
959-98-8
33213-65-9
72-20-8
7421-93-4
53494-70-5
55283-68-6
2593-15-9
60168-88-9
58-89-9
5103-74-2
76-44-8
1024-57-3
465-73-6
33820-53-0
143-50-0
72-43-5
21087-64-9
2385-85-5
1836-75-5
27314-13-2
12674-11-2
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
40487-42-1
82-68-8
72-56-0
1918-16-7
709-98-8
139-40-2
122-34-9
8001-50-1
5902-51-2
5915-41-3
8001-35-2
61949-77-7
4312143-3
1582-09-8
85.01: CHLORINATED PHENOUCS
2,3,4,6-tetrachlorophenol
2,3,6-trichlorophenol
2,4,5- trichlorophenol
2,4,6-trichIorophenol
2,4-dichlorophenol
2,6-dichlorophenol
2-syringaldehyde
3,4,5-trichlorocatechol
3,4,5-trichIoroguaiacol
3,4,6- trichloroguaiacol
3,4-dichlorophenol
^ ^-dichlorocfltechol
58-90-2
933-75-5 •
95-95-4
88-06-2
120-83-2
87-65-0
134-96-3
56961-20-7
57057-83-7
60712-44-9
95-77-2
H67V92-2
Pollutant
3,5-dichlorophenoI
3,6-dichlorocatechol
4,5,6-trichIoroguaiacol
4,5-dichlorocatechol
4,5-dichloroguaiacol
4,6-dichIoroguaiacol .
4-chloroguaiacol
4-chIorophenol
5,6-dichlorovanilIin
5-chloroguaiacoI
6-chlorovanillin
Pentachlorophenol
Tetrachlorocatechol
Tetrachloroguaiacol
Trichlorosyringol
1620: METALS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Bismuth
Boron
Cadmium
Calcium ,
Cerium
Chromium
Cobalt
Copper
Dysprosium
Erbium
Europium
Gadolinium
Gallium
Germanium
Gold
Hafnium
Holmium
Indium
Iodine
Indium
Iron
Lanthanum
Lead
Lithium
Lutetium
Magnesium
Manganese
Mercury
Molybdenum
Neodymium
Nickel
Niobium
Osmium
Palladium
Phosphorus
Platinum
Potassium
CasNum
591-35-5
3938-16-7
2668-24-8
3428-24-8
2460-49-3
16766-31-7
16766-30-6
106-48-9
18268-69-4
3743-23-5
18268-76-3
87-86-5
1198-55-6
2539-17-5
2539-26-6
7429-90-5
7440-364).
7440-38-2
7440-39:3
744041-7
7440-69-9-
744042-8-
744043-9
7440-70-2
7440-45-1
7440-47-3
744048-4
' 7440-50-8 .
7429-91-6
7440-52-0
7440-53-1-
7440-54-2
7440-55-3
7440-564
7440-57-5
7440-58-6
7440-60-0
7440-74-6
7553-56-2
7439-88-5
7439-89-6
7439-91-0
7439-92-1
7439-93-2
7439.94-3
7439-954
7439-96-5
7439-97-6
7439-98-7
7440-00-8
7440-02-0
7440-03-1
7440-04-2
7440-05-3
7723-14-0
7440-064
7440-OQ-7
Pollutant
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Tantalum
Tellurium
Terbium
Thallium
Thorium
Thulium
Tin
Titanium
Tungsten
Uranium '-' -
Vanadium
Ytterbium
Yttrium
Zinc
Zirconium
Cas Num
7440-104)
7440-15-5
7440-16-6
7440-18-8
7440-19-9
7440-20-2
778249-2
7440-2L-3
7440-224
7440-23-5
7440-24-6
7704-34-9
7440-25-7
13494-80-9
7440-27-9
7440-28-0
7440-29-1
7440-304
7440-31-5
7440-32-6
744033-7"
7440-61-1
7440-62-2
7440-644
7440-65-5
7440-66-6
7440-67-7
1624: VOLATILE ORGANICS _
1,1,1 ,2-tetrachloroethane
1,1,1 -trichloroethane
1,1,2,2-tetrachloroethane
1 , 1 ,2-trichloroethane
1 , 1 -dichloroethane
1,1-dichloroethene
1,2,3-trichloropropane
1,2-dibromoethane
1,2-dichloroethane
1 ,2-dichloropropane
1,3-butadiene, 2-chloro-
1 ,3-dichloropropane
1,4-dioxane
2-butanone
2-chIoroethylvinyl ether
2-hexanone
2-propanone
2-propen-l-ol
2-propenal
2-propenenitrile, 2-methyl-
3-chloropropene
4-methyl-2-pentanone
Acrylonitrile
Benzene
BromodicKloromethane
Bromomethane
Carbon disulfide
Chloroacetonitrile
Chlorobenzene
Phloroethane
630-20-6
71-55-6
79-34-5
79-00-5
75-34-3
75-354
96-184
106-934
107-06-2
78-87-5
126-99-8 .
142-28-9
123-91-1
78-93-3
110-75-8
591-78-6
67-64-1
107-18-6
107-02-8
126-98-7
107-05-1
108-10-1
107-13-1
7143-2
75-274
74-83-9
75-15-0
107-14-2
108-90-7
7VM-?
2-8
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
Table 2-1. Chemical Compounds Analyzed Under EPA Analytical Methods (continued)
Pollutant
Chloroform
Chloromethane
Cis- 1,3-dichloropropene
Crotonaldehyde
Dibromochloromethane
Dibromomethane
Diethyl ether
Ethyl cyanide
Ethyl methacrylate
Ethylbenzene
lodomethane
Isobutyl alcohol
M+P-xylene
M-xylene
Methyl methacrylate
Methylene chloride
OfP-xylene
O-xylene
Tetrachloroethene
Tatrachloromethane
Toluene
Trans- 1 ,2-dichloroethene
Trans- 1 ,3-dichloropropene
Trans-r,4-dichloro-2-b"utene
Tribromomethane
Trichloroethene
Trichlorofluoromethane
Vinyl acetate
Vinyl chloride
CasNum
. 67-66-3
74-87-3
10061-01-5
4170-30-3
124-48-1
74-95-3
60-29-7
107-12-0
97-63-2
l(X)-41-4
74-88^t
78-83-1
179601-23-1
108-38-3
80-62-6
75-09-2
136777-61-2
95-47-6
127-18-4
56-23-5
108-88-3
156-60-5
10061-02-6
1T03W5'
75-25-2
79-01-6
75-69-4
108-05-4
75-01-4
I625:SEMIVOLATILEORGANICS
1 ,2,3-trichlorobenzene
1 ,2,3-trimethoxybenzene
1 ,2,4,5-tetrachlorobenzene
1 ,2,4-trichloroben2ene
1 ,2-dibromo-3-chloropropane
1,2-dichlorobenzene
1 ,2-diphenylhydrazine
l,2:3,4-diepoxybutane
1,3,5-trithiane
l,3-dichloro-2-propanol
1,3-dichlorobenzene
1 ,4-dichIorobenzene
1 ,4-dinitrobenzene
1 ,4-naphthoquinone
1 ,5-naphthalenediamine
l-bromo-2-chlorobenzene
l-bromo-3-chIorobenzene
l-chIoro-3-nitrobenzene
1 -methy Ifluorene
1 -methy Iphenanthrene
I-naphthylamine •
l-phenylnaphthalene
2,3,4,6-tetrachlorophenol
2,3,6-trichlorophenol
2,3-benzofluorene
2,3-dichloroaniline
2,3-dichIoronitrobenzene
2,4.5-trichIoronhenol
87-61-6
634-36-6
95-94-3
120-82-1
96-12-8
95-50-1
122-66-7
1464-53-5
291-21-4
96-23-1
541-73-1
106-46-7
100-254
130-154
2243-62-1
694-80-4
108-37-2
121-73-3
1730-37-6
832-69-9
134-32-7
605-02-7
58-90-2
933-75-5
243-17-4
608-27-5
3209-22-1
95-95^'
Pollutant
2,4,6-trichlorophenol
2,4-dichIorophenol
2,4-dimethylphenol
2,4-dinitrophenol
2,4-dinitrotoluene
2,6-di-tert-butyl-p-benzoquinone
2,6-dichloro-4-nitroaniline
2,6-dichlorophenol
2,6-dinitrotoluene
2-(methylthio)benzothiazoIe
2-chloronaphthalene
2-chlorophenol
2-isopropyInaphthalene
2-methylbenzothiazole
2-methylnaphthalene
2-nitroaniline
2-nitrophenol
2-phenylnaphthalene
2-picoline
3,3'-dichlorobenzidine
3,3'dimethoxybenzidine
3,6-dimethylphenanthrene
3-methylchoIanthrene
3;nitroaniline
4,4'-methyIenebis(2-chloroaniIine)
4,5-methylene phenanthrene
4-arhinobiphenyl
4-bromophenyl phenyl ether
4-chlorc— 2-nitroaniline
4-chloro-3-methyIphenol
4-chlorophenyI phenyl ether
4-nitrophenol
5-nitro-o-toluidine
7, 1 2-dimethybenz(a)anthracene
Acenaphthene
Acenaphthylene
Acetophenone
Alpha-terpineol
Aniline
Aniline, 2,4,5-trimethyl-
Anthracene
Aramite
Benzanthrone
Benzenethiol
Behzidine
Benzo(a)anthracehe
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Benzoic Acid
Benzonitrile, 3,5-dibromo-4-hydroxy-
Benzyl alcohol
Beta-naphthylamine
Biphenyl
Biphenyl, 4-nitro-
Bis(2-chloroethoxy)methane
Bis(2-chloroethvn ether
CasNum
88-06-2
120-83-2
105-67-9
51-28-5
121-14-2
719-22-2
99-30-9
87-65-0
606-20-2
615-22-5
91-58-7
95-57-8
2027-17-0
120-75-2
91-57-6
88-744
88-75-5
612-94-2
109-06-8
91-94-1
119-90-4
1576-67-6
5649-5
99-09-2
101-14-4
203-64-5
92-67-1
101-55-3
89-634
59-50-7
7005-72-3
100-02-7
99-55-8
57-97-6
83-32-9
208-96-8
98-86-2
98-55-5
62-53-3
137-17-7
120-12-7
. 140-57-8
82-05-3
108-98-5
92-87-5
56-55-3
50-32-8
205-99-2
191-24-2
207-08-9
65-85-0
1689-84-5
100-51-6
91-59-8
92-52-4
92-93-3
111-91-1
111^14-4
Pollutant
Bis(2-chloroisopropyl) ether
Bis(2-ethylhexyl) phthalate
Butyl benzyl phthalate
Carbazole
Chrysene
Crotoxyphos
Di-n-butyl phthalate
Di-n-octyl phthalate
Di-n-propylnitrosamine
Dibenzo(a,h)anthracene
Dibenzofuran
Dibehzothiophene
Diethyl phthalate
Dimethyl phthalate ;
Dimethyl sulfone
Diphenyl ether
Diphenylamine
Diphenyldisulfide
Ethane, pentachloro-
Ethyl methanesulfonate
Ethylenethiourea
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloropropene
Hexanoic acid
Indeno( 1 ,2,3-cd)pyrene
Isophorone
Isosafrole
Longifolene
Malachite green
Mestranol
Methapyrilene
Methyl methanesulfonate
N,N-dimethyIformamide •
N-decane
N-docosane
N-dodecane
N-eicosane
N-hexacosane
N-hexadecane
N-nitrosodi-n-burylamine
N-nitrosodiethylamine
N-nitrosodimethylamine
N-nitrosodiphenylamine
N-nitrosomethylethylamine
N-nitrosomethylphenylamine
N-nitrosomorpholine
N-nitrosopiperidine
N-octacosane
N-octadecane
N-tetracosane
N-tetradecane
N-triacontane
Naphthalene
Cas Num
108-60-1
117-81-7
85-68-7
86-74-8
218-01-9
7700-17-6
84-74-2
117-84-0
621-64-7
53-70-3
132-64-9
132-65-0
84-66-2
131-11-3
67-71-0
101-84-8
122-39-4
882-33-7
76-01-7
62-50-0
9&4S-7
206-44-0
86-73-7
118-74-1 •
87-68-3
77-47-4
67=72=L_
1888-71-7 .
• 142-62-1
193-39-5
. 78-59-1
120-58-1
475-20-7
569-64-2
72-33-3
91-80-5
66-27-3
68-12-2
124-18-5
629-97-0
112-40-3
112-95-8
630-01-3
544-76-3
924-16-3
55-18-5
62-75-9
86-30-6
10595-95-6
614-00-6
59-89-2
100-75-4
630-02-4
59345-3
646-31-1
629-59-4
638-68-6
91-20-3
2-9
-------
Chapter 2 Data Collection
Development Document for the CWT Point Source Category
Table 2-1. Chemical Compounds Analyzed Under EPA Analytical Methods (continued)
Pollutant
Nitrobenzene
O-anisidine
O-crcsol
O-toIuidinc
O-toIuidinc, 5-chloro-
P-chloroaniline
P-crcsol
P-cymcne
P-dimcthylaminoazobenzene
P-nitroaniline
Pentachlorobenzene
Pcntachlorophcnol
Pcntamethylbenzene
Pcrylcne
Phcnacctin
Cas Num
98-95-3
90-04-0
95-48-7
95-53-4
95-79-4
10547-8
10644-5
99-87-6
60-11-7
100-01-6
608-93-5
87-86-5
700-12-9
198-55-0
62-44-2
Pollutant
Phenanthrene
Phenol
Phenol, 2-methyl4,6-dinitro-
Phenothiazine
Pronamide
Pyrene
Pyridine
Resorcinol
Safrole
Squalene '
Styrene
Thianaphthene
Thioacetamide
THioxanthe-9-one
Toluene, 2,4-diamino-
CasNum
85-01-8
108-95-2
534-52-1
92-84-2
23950-58-5
129-00-0
110-86-1
10846-3
94-59-7
7683-64-9
10042-5
95-15-8
62-55-5 .
• 492-22-8
95-80-7
Pollutant Cas Num
Triphenylene 217-594
Tripropyleneglycol methyl ether 20324-33-8
630.1: PESTICIDES/HERBICIDES
Dithiocarbamate anion 4384-82-1
1648: TOTAL ORGANIC HALIDES
Total Organic Halides (TOX) C022
/ 650: ADSOKBABLE ORGANIC HALIDES
Adsorbable organic halides (AOX) 59473-04-0
SOJS.-ETHANOL/METHANOL ..
Ethanol 64-17-5
Methanol 67-56-1
REGION 9: FORMALDEHYDE
Formaldehyde 50-00-0
2-10
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
Metal-Bearing Waste Treatment and
Recovery Sampling
2.3.3.3
Between 1989 and 1994, EPA conducted six
sampling episodes at facilities classified in the
metals subcategory. Two of these facilities were
re-sampled in 1996 following the proposal. Only
one of those facilities sampled discharged to a
surface water. The rest are indirect dischargers.
All of the facilities used metals precipitation
as a means for treatment, but each of the
systems was unique due to the treatment
chemicals used and the system configuration and
operation. Most facilities precipitated metals in
batches. One facility segregated waste shipments
into separate batches to optimize the precipitation
of specific metals, then commingled the treated
batches to precipitate additional metals. Another
facility had a continuous system for precipitation
in which the wastewater flowed through a series
of treatment chambers, each using a different
treatment chemical. EPA evaluated the
following treatment technologies: primary,
secondary, and tertiary precipitation, selective
metals precipitation, gravity separation, multi-
media filtration, clarification, liquid and sludge
filtration, and treatment technologies for cyanide
destruction.
EPA conducted sampling at metals facilities
after the 1995 proposal to determine what effect
total dissolved solids (TDS) concentrations had
on the performance of metals precipitation
processes. This issue was raised in public
comments to the 1995 proposed rule. EPA
resampled two facilities which had been sampled
prior to the first proposal. The first facility
formed the technology basis for the 1995
proposed metals subcategory regulatory option
and the second was a facility with high levels of
TDS in the influent waste stream. EPA was
interested in obtaining additional data from the
proposal option facility since they had altered
their treatment systems from those previously
sampled and because EPA failed to collect TDS
information during the original sampling episode.
EPA was interested in collecting additional data
from the second facility because the facility has
high TDS values. EPA used data from both of
the post-proposal sampling episodes to develop
regulatory options considered for the re-proposal
and the final rule.
Oily Waste Treatment and Recovery
Sampling
2.3.3.4
Between 1989 and 1994, EPA conducted
four sampling episodes at oils subcategory
facilities. Two additional oils facilities were
sampled in 1996 following the'proposal. All six
are indirect dischargers and performed an initial
gravity separation step with or without emulsion
breaking to remove oil from the wastewater. At
two facilities, however, the wastewater from the
separation step was commingled with other
non=oily wastewater prior to further treatment.
As such, EPA could only use data-from these
facilities~to 'characterize the .waste streams after
emulsion breaking. The other four facilities
treated the wastewater from the initial separation
step without commingling with non-oils
subcategory wastewaters in systems specifically
designed to treat oily wastewater. EPA
evaluated the following treatment technologies
for this subcategory: gravity separation, emulsion
breaking, ultrafiltration, dissolved air flotation,
biological treatment, reverse osmosis, carbon
adsorption, and air stripping.
EPA conducted sampling at oils facilities in
late 1994 (just before the proposal) and again'
after the proposal to address concerns raised at
the 1994 public meeting and in the proposal
public comments. Specifically, in regard to oils
wastewater treatment, the commenters stated
that (l).the facility which formed the technology
basis for EPA's 1995 proposed option did not
treat wastes which were representative of the
wastes treated by many other oils facilities, and
(2) EPA should evaluate dissolved air flotation as
a- basis for the regulatory option. All three of the
facilities sampled between 1994 and 1996
2-11
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
utilized dissolved air flotation and treated wastes
which were generally more dilute than those
treated by the 1995 proposal option facility.
EPA used data from both of the post-proposal
sampling episodes to develop regulatory options
considered for the 1999 supplemental proposal.
Data from the 1994 episode were not used to
develop a regulatory option due to non-optimal
performance and highly diluted influent streams;
however, EPA used data from this facility to
characterize the waste stream after emulsion
breaking.
Organic-Bearing Waste Treatment and
Recovery Sampling 2.3.3.5
EPA had difficulty identifying facilities that
could be used to characterize waste streams and
assess treatment technology performance in the
organics subcategory. A large portion of the
facilities, whose organic waste treatment
operations EPAr evaluated, had other industrial
operations on-site. For these facilities, CWT
waste streams represented a minor component of
the overall facility flow..
Between 1989 and 1994, EPA did identify
and sample three facilities that treated a
significant volume of off-site generated organic
waste relative to non-CWT flows. None of
these faculties were direct discharging faculties.
EPA evaluated several treatment technologies,
including the following: air stripping, biological
treatment in a sequential batch reactor,
multi-media filtration, coagulation/flocculation,
carbon adsorption, and CO2 extraction. EPA
chose not to use data from one of the three
facilities in calculating effluent levels achievable
with its in-place technologies because the facility
was experiencing operational difficulties with the
treatment system at the time of sampling. In
addition, after reviewing the facility's waste
receipts during the sampling episode, EPA
determined that the facility accepted both oils
subcategory and organics subcategory
wastestreams and commingled them for
treatment. EPA has also not used data from a
second facility in calculating effluent levels
achievable with its in-place technologies because,
after reviewing this facility's waste receipts
during the sampling episode, EPA determined
that this facility also accepted both oils
subcategory and organics subcategory
wastestreams , and commingled them for
treatment.
1998 Characterization Sampling_ofQil
Treatment and Recovery Facilities- 2.3.4.
EPA received many comments to, the
original proposal concerning the size and
diversity of the oils treatment and recovery
subcategory. Many suggested that the
subcategpry needed to be further subdivided in
an effort to better-depict the industry. As a
result, in 1998, EPA conducted-site visits at
eleven facilities which treat and/or recover non-
hazardous oils wastes, oily wastewater, or used
oil material from off-site. While the mformation
collected at these facilities was similar to
information collected during previous site visits,
these facilities were selected based on waste
receipts. The facilities represent a diverse mix of
facility size, treatment processes, and
geographical locations. EPA collected
wastewater samples of their waste receipts and
discharged effluent at 11 of these facilities.
These samples were one-time grabs and were
analyzed for metals, classicals, and semi-volatile
organic compounds. In the 1999 supplemental
proposal, EPA had not yet incorporated these
results (except for influent data from E5046) in
developing limitations. At a public hearing on
February 18, 1999, EPA described the relevant
sampling data, the constraints of evaluating this
data, and a comparison of data from hazardous
and non-hazardous waste streams. This data
showed that, while the mean and median values
of influent concentration of hazardous
wastestream data are greater than for non-
hazardous wastestreams for most pollutants
2-12
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Catesorv
examined, the ranges of concentration for the
hazardous and non-hazardous wastestreams
overlap for most pollutants. In its presentation,
EPA indicated that it planned to re-examine the
oils subcategory in terms of pollutant loadings,
removals, limitations and standards, costs,
impacts, and benefits. EPA requested comment
on this issue, and extended the comment period
for this issue by 30 days after the public hearing.
EPA's presentation is included in the public
record for this rulemaking as DCN 28.1.1 (other
supporting information is in Section 28). These
data were incorporated into the final analyses
related to identifying pollutants of concern and
calculating pollutant reductions.
PUBLIC COMMENTS TO THE 1995 PROPOSAL,
THE 1996 NOTICE OF DA TA A VAILABILITY,
AND THE 1999 SUPPLEMENTAL PROPOSAL 2.4
In addition to data obtained through the
Waste Treatment Industry Questionnaire, DMQ,
site visits and sampling episodes, commenters on
the January 27, 1995 proposal (60 FR 5464),
the September 16, 1996 Notice of Data
Availability (61 FR 48805), and the January 13,
1999 supplemental proposal (64 FR 2280)
provided data to EPA. In fact, much of EPA's
current characterization of the oily waste
treatment and recovery subcategory is based on,
comments to the 1996 Notice of Data
Availability.
As described earlier, following the 1995
proposal, EPA revised its estimate of the number
of facilities in the oils subcategory and' its
description of the oils subcategory. Using new
information provided by the industry during the
1995. proposal comment period in conjunction
with questionnaire responses and sampling data
used to develop the proposal, EPA
recharacterized this subcategory of the industry.
This recharacterization reflected new data on the
wastes treated by the subcategory, the
technology in-place, and the pollutants
discharged. As part of this recharacterization,
EPA developed individual profiles for each of the
newly identified oils facilities by modeling current
wastewater treatment performance and treated
effluent discharge flow rates. In addition,
assuming the same treatment technology options
identified at proposal, EPA recalculated the
projected costs of the proposed options under
consideration,, expected pollutant reductions
associated with the options, and the projected
economic impacts. EPA presented its
recharacterization of the oils subcategory in the
September 1996 Notice of Data Availability (61
FR 48806).
At the time of the 1995 proposal, EPA
estimated' there were 35 facilities in the oily
waste, treatment and recovery subcategory.
Through comments received in response to the
proposed rule, and communication with the
industry, the National Oil Recyclers Association,
and EPA-Regional staff, EPA identified an
additional 240 facilities that appeared to treat oily
wastes - from- off-siter While= attempting^ to
confirm mailing addresses for each facility, EPA
discovered that 20 of these facilities were either
closed or could not be located. EPA then
revised its profile of the oily waste treatment and
recovery subcategory to include 220
newly-identified facilities. The information in the
Notice of Data Availability was based on these
220 additional facilities.
In lieu of sending questionnaires out to the
newly-identified oils facilities to collect technical
and economic information, EPA used data from
secondary sources to estimate facility
characteristics such as wastewater flow. For
most facilities, information about total facility
revenue and employment were available from
public sources (such as Dunn and Bradstreet).
EPA then used statistical procedures to match,
the newly-identified facilities to similar facilities
that had provided responses to the 1991 Waste
Treatment Industry Questionnaire. This
matching enabled EPA to estimate the flow of
treated wastewater from each of the newly
identified facilities. Where EPA had actual
2-13
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
estimates for facility characteristics from the
facility or public sources, EPA used the reported
values. The estimated facility characteristics
included the following:
• RCRA status;
• Waste volumes;
• Recovered oil volume;
• Wastewater volumes treated and discharged;
• Wastewater discharge option;
• Wastewater characteristics;
• Treatment technologies utilized; and
• Economic information.
EPA hoped to obtain information from each of
the newly identified faculties through comments
to the 1996 Notice of Data Availability. In order
to facilitate that effort, copies of the Notice and
the individual facility profile were mailed to each
of the 220 newly identified facilities. Of these,
EPA received comments and revised profiles
from 100. Therefore, 120 facilities did not
provide comments to the Notice-or revised
facility profiles.
EPA determined the following about the list
of newly identified oils facilities:
• 50 faculties were within the scope of the
oily waste treatment and recovery
subcategory;
• 16 facih'ties were fuel blenders;
• 31 faculties were out of scope of the oily
waste treatment and recovery subcategory;
and
• 3 faculties were closed.
EPA polled 9 of the 120 non-commenting
facilities and determined that approximately half
are within the scope of the industry. As a result,
EPA estimates that half, or sixty, of the 120
non-commenting facilities are within the scope of
the oily waste treatment and recovery
subcategory. As to these sixty facilities that did
not comment, EPA does not necessarily have
facility specific information for them.
Finally, through comments to the Notice,
EPA also obtained facility specific information
on 19 facilities that EPA had not previously
identified as possible CWT oils subcategory
facilities.
Therefore, EPA's updated data base
includes facility-specific information for a total of
104 facilities that are within the scope of the oily
waste treatment and recovery subcategory. This
total included the 50 facilities for which. EPA
prepared facility information sheets, 19 new
facilities,identified.through.the Notice,- ancL35
facilities from the questionnaire data base. The
number of in-scope facilities from the
questionnaire data base changed from the time of
proposal due to other facility applicability issues,
as discussed in Section 3.1, Finally, as
described'above, EPA estimated that the entire
population of oils subcategory facilities includes
an additional 60 facilities for which EPA does
not have facility -specific information. This.,
brought the total estimate of oils facilities to 164."
Commenters also submitted'data'during the
1999 comment period. These data were of
varying nature and included data characterizing
influent and effluent wastestreams at facilities in
all subcategories. Most of these data were not
from the option technologies or were from mixed
wastestreams. However, one facility submitted
concentration data for three of its metal-bearing
wastestreams. The Agency has used this
submitted data to refine its understanding of
CWT wastes and to aid in calculation of.
loadings, identification of pollutants of concern,
and development of final limitations and
standards.
ADDITIONAL DATA SOURCES
Additional Databases
2.5
2.5.1
Several other data sources were used in
developing effluent guidelines for the centralized
waste treatment industry. EPA used the data
included in the report entitled Fate of Priority
Pollutants in Publicly Owned Treatment Works
2-14
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
(EPA 440/1-82/303, September 1982),
commonly referred to as the "50 POTW Study",
in determining those pollutants that would pass
through a POTW. EPA's National Risk
Management Research Laboratory (NRMRL),
formerly called the Risk Reduction Engineering
Laboratory (RREL), treatability data base was
used to supplement the information provided by
the 50 POTW Study. A description of
references is presented in Section 7.6.2.
Laboratory Study on the Effect of Total
Dissolved Solids on Metals
Precipitation 2.5.2
During the comment period for the 1995
proposal, EPA received comments which
asserted that high levels of total dissolved solids
(TDS) in CWT wastewaters may compromise a
CWT's ability to meet the proposed metal
subcategory limitations. The data indicated that
for some metal-contaminated wastewaters, as
TDS levels increased, the solubility of the metal
in wastewater also increased.. As such, the
commenters claimed that metal-contaminated
wastewaters with high TDS could not be treated
to achieve the proposed limitations.
At the time of the original proposal, EPA had
no data on TDS levels in CWT wastewaters.
None of the facilities provided TDS data in their
response to the Waste Treatment Industry
Questionnaire or the Detailed Monitoring
Questionnaire. Additionally, during the sampling
episodes prior to the 1995 proposal, EPA did not
collect TDS data. As such, EPA lacked the data
to estimate TDS levels in wastewaters at me
CWT facility which formed the technology basis
for the 1995 proposed metals subcategory
limitations. '
In order to address the comment, EPA (1)
collected additional information on TDS levels in
metals subcategory wastewaters; (2) conducted
additional sampling; (3) consulted literature
sources; and (4) conducted bench scale studies.
First, EPA needed to determine the range of
TDS levels hi CWT metals subcategory
wastewaters. , As such, EPA contacted the
metals subcategory Waste Treatment Industry
Questionnaire respondents to determine the level
of TDS in their wastewaters. Most CWT
facilities do not collect information on the level
of TDS hi their wastewaters. Those facilities
that provided information indicated that TDS
levels in CWT metals subcategory wastewaters
range from 10,000 ppm to 100,000 ppm (1-10
percent).
Second, EPA resampled the facility which
formed the technology basis for the 1995
proposed metals subcategory limitations as well
as one other metals subcategory facility, in part,
to determine TDS levels in their wastewaters.
EPA found TDS levels of 17,000 to-8i;000
mg/L.
Third, EPA consulted various literature
sources to obtain information about the. effect of
TDS levels on chemical precipitation. EPA
found no data or information which related
directly to TDS effects on chemical precipitation.
. Fourth, EPA conducted a laboratory study
designed to determine the effect of TDS levels
on chemical precipitation treatment performance.
In this study, EPA conducted a series of bench-
scale experiments on five metals: arsenic,
chromium, copper, nickel and titanium. These.
metals were selected because (1) they are
commonly found in CWT metals subcategory
wastewaters, (2) their optimal precipitation is
carried out in a range of pH levels; and/or (3) the
data provided in the comments indicated that
TDS may have a negative effect on the
precipitation of these metals. The preliminary
statistical analyses of the data from these studies
show no consistent relationship among the five
metals, pH levels, TDS concentrations and
chemical precipitation effectiveness using
hydroxide or a combination of hydroxide and
sulfide. (DCN 23.32 describes the study and the
statistical analyses in further detail.)
Therefore, because none of these four
sources provided consistent and convincing
2-15
-------
Chapter 2 Data Collection
Development Document for the CWT Point Source Category
evidence that TDS compromises a facility's
ability to meet the final metal subcategory
limitations, EPA has not incorporated the TDS
levels into the development of limitations on
metals discharges.
PUBLIC PARTICIPATION
2.6
EPA has strived to encourage the
participation of all interested parties throughout
the development of the CWT guidelines and
standards. EPA has met with various industry
representatives including the Environmental
Technology Council (formerly the Hazardous
Waste Treatment Council), the National Solid
Waste Management Association (NSWMA), the
National Oil Recyclers Association (NORA), and
the Chemical Manufacturers Association (CMA).
EP Ahas also participated hi industry meetings as
well as meetings with individual companies that
may be affected by this regulation. EPA also.
met with environmental groups • including
members of the Natural Resources Defense
Council. Finally, EPA has made a concerted
effort to consult with EPA regional staff,
pretreatment coordinators, and other state and
local entities that will be responsible for
implementing this regulation.
EPA sponsored two public meetings, one
prior to the original proposal on March 8, 1994
and one prior to this re-proposal on July 27,
1997. The purpose of the public meetings was
to share information about the content and status
of the proposed regulation. The public meetings
also gave interested parties an opportunity to
provide information and data on key issues.
On March 24, 1995 (following the original
proposal), July 29,1997 (following the Notice of
'Availability), and February 18, 1999 (following
the supplemental proposal), EPA sponsored
workshops and public meetings. The purpose of
the workshops was to provide information about
the proposed regulation and to present topics on
which EPA was soliciting comments. The public
meetings gave interested parties the opportunity
to present oral comments on the proposed
regulation.
.Finally, as detailed in fosEconomic Analysis
of Effluent Limitations Guidelines and
Standards for the Centralized Waste Treatment
Industry (EPA 821-R-98-019) , on November 6,
1997, EPA convened a Small Business
Regulatory Flexibility Act (SBREFA) Review
Panel in preparing this final rule. The review
panel was composed of employees of the EPA
program office developing this-proposalj the
Office of Information and Regulatory Affairs
within the Office of Management and Budget
and the Chief Counsel for Advocacy of the Small
Business Administration (SBA). The panel met
over the course of two months and collected the
advice and recommendations of representatives
of small entities that may be affected by this rule
and reported their comments as1 well- as- the
Panel's findings on the following:
• The type and number of'small-entities' that
would be subject to the proposal.
« Record keeping, reporting and other
compliance requirements that the proposal
would impose on small entities subject to the
proposal, if promulgated.
•. Identification of relevant Federal rules that
may overlap or conflict with the proposed
rule.
• Description of significant regulatory
alternatives to the proposed rule which
accomplish the stated objectives of the CWA
and minimize any significant economic.
The small entity CWT population was
represented by members of the National Oil
Recyclers Association (NORA), the
Environmental Technology Council, and a law
firm representing a coalition of CWTs in
Michigan. EPA provided each of the small entity
representatives and panel members many
materials related to the development of this rule.
As such, the small entity representatives had the
opportunity to comment on many aspects of this
2-16
-------
Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
promulgated guideline in addition to those
specified above. All of the small entity
comments and the panel findings are detailed in
the "Final Report of the SBREFA Small
Business Advocacy Review Panel on EPA's
Planned Proposed Rule for Effluent Limitations
Guidelines and Standards for the Waste
Treatment Industry" which is located in the
regulatory record accompanying this rale.
2-17
-------
-------
Chapter
SCOPE/APPLICABILITY OF THE FINAL REGULATION
EPA received numerous comments on the
1995 proposal and 1996 Notice of Data
Availability concerning the applicability of this
. rule to various operations. Consequently, EPA
devoted significant discussion in the 1999
supplemental proposal to applicability issues.
Again, in response, EPA received numerous
comments on applicability issues. Many
commenters were simply seeking clarification of
the coverage of this rule to a specific operation.
Table 3-3,.located at the end of this chapter,
.provides a general overview of the applicability
of the final rule on potentially-covered facilities
and is based on some of the issues raised during
the ..public .comment periods. While many of
these issues were discussed in the 1999
supplemental proposal and, in most cases, the
final guideline retains the same approach as those
explained in the supplemental proposal, EPA
presents a detailed discussion of these issues in
Sections 3.1.1 through 3.1.25.
APPLICABILITY
3.1
The universe of facilities which would be
potentially subject to this guideline, except where
noted otherwise, include the following. First,
EPA is establishing limitations arid pretreatment
standards for stand-alone waste treatment and
recovery facilities receiving materials from off-
site — classic "centralized waste treaters". These
facilities may treat either for recovery or disposal
or recycle hazardous or non-hazardous waste,
hazardous or non-hazardous wastewater, and/or
used material received from off-site. Second,
while EPA is generally not subjecting discharges
from waste treatment systems at facilities
primarily engaged in other industrial operations to
the scope of this rule, the rule will regulate at
least a portion of their wastewater in certain
circumstances. Thus, industrial facilities which
process their own, on-site generated, process
wastewater along with hazardous or non-
hazardous wastes, wastewaters, and/or used
material received from off-site may be subject to
this rule, witturespect to a portion of their
discharge unless certain conditions are met.-.
The Wastewater flows covered by this rule
include some or all flows related to off-site waste
receipts and on-site CWT wastewater generated
as a result of CWT operations. The kinds of on-
site CWT wastewater generated at these facilities
include, for example, the following: solubilization
wastewater, emulsion breaking/gravity separation
wastewater, used oil processing wastewater,
treatment'equipment washes, transport washes.
(tanker truck, drum, and roll-off boxes),
laboratory-derived wastewater-, air-- pollution-
control wastewater, industrial waste combustor
wastewater from on-site industrial waste
combustors, landfill wastewater from on-site
landfills, and contaminated storm water. A
detailed discussion of CWT wastewaters is
provided in Chapter 4. In summary, all
wastewater discharges to a receiving stream or
the introduction of wastewater to a publicly
owned treatment works from a facility which this
regulation defines as a centralized waste
treatment facility are subject to the provisions of
this rule unless specifically excluded. The
following sections discuss the applicability of the
CWT rule to various wastewater discharges
associated with centralized waste treatment
operations.
Manufacturing Facilities
3.1.1
At the time of the original proposal, EPA
defined a centralized waste treatment facility as
any facility which received waste from off-site
3-1
-------
Chapter 3 Scope/Applicability OfThe Final Regulation Development Document for the C WT Point Source Category
for treatment or recovery on a commercial or
non-commercial basis. Non-commercial facilities
were defined as facilities that accept off-site
wastes from facilities under the same ownership.
Throughout the development of this rule,
EPA has contemplated that the rule would apply -
to wastewater discharges from facilities that,
while primarily engaged in other industrial
operations, also may treat and/or treat for
recovery or recycle hazardous or non-hazardous
waste or wastewater and/or off-site wastes or
used materials. These facilities primarily treat
wastes generated as a result of their own on-site
manufacturing operations. Their wastewater
discharges are, by and large, already subject to
effluent guidelines and standards (some
treatment operations, however, may be located
at manufacturing facilities which are not subject
to effluent guidelines and standards). All of
these facilities also accept off-site generated
wastes for treatment. In some instances, a
facility under the same corporate ownership
generates these off-site wastes. The facility
treats these intra-company transfers on a non-
commercial basis. In other instances, the off-site
wastestreams originate from a company under a
different ownership — an niter-company transfer.
In some instances, the off-site wastes received at
these industrial facilities are generated by a
facility performing the same manufacturing
operations, while in other instances, the off-site
wastestreams are generated by facilities engaged
in entirely unrelated manufacturing operations.
Some receive a constant wastestream from only
a handful of customers and some receive a wide
variety of wastestreams from hundreds of
customers.
EPAreceived extensive comment concerning
how the CWT rule should apply to facilities that
provide waste treatment and/or recovery
operations for off-site generated wastes, but
whose primary business is something other than
waste treatment or recovery. In general,
commenters urged EPA to limit the scope of the
regulation in one of several ways. Commenters
suggested restricting the scope to any of the
following:
• facilities whose sole purpose is the treatment
of off-site wastes and wastewaters; or
facilities which only accept off-site wastes
on a commercial basis; or
• facilities which accept off-site wastes which
are not produced as a result of industrial
operations subject to the same effluent
guidelines and standards as the on-site
. generated wastes or off-site,wastes which
are not compatible with the on-site generated
wastes and the on-site wastewater treatment
system; or
• manufacturing facilities which accept off-site
wastes in excess of a de minimis level.
EPA reexamined the database of facilities"
which form the basis of the CWT rule. EPA's
database contains information on 17
manufacturing facilities which commingle waste
generated by on-site manufacturing activities for
treatment with waste generated off-site and one
manufacturingfacility which does not commingle
waste generated by on-site manufacturing
activities for treatment with waste generate off-
site. Nine of these facilities treat waste on a non-
commercial basis only and nine treat waste on a
commercial basis. Of the eighteen facilities, eight
facilities only accept and treat off-site wastes
which are from the same categorical process as
the on-site generated waste streams. Ten of the
facilities, however, accept off-site wastes which
are not subject to the same categorical standards
as the on-site generated wastewater. The
percentage of off-site wastewaters being
commingled for treatment with on-site
wastewater varies from 0.06% to 80% with the
total volumes varying between 87,000 gallons
per year to 381 million gallons per year.
The guidelines, as proposed in 1995, would
have included both types of facilities within the
scope of this rule. EPA included these facilities
in the 1995 proposed CWT rule to ensure that all
wastes receive adequate treatment — even those
shipped between facilities already subject to
3-2
-------
Chapter 3 Scope/Applicability OfThe Final Regulation Development Document for the CWT Point Source Category
existing effluent limitations guidelines and
standards (EPA agrees that, for off-site wastes
which are generated by the same categorical
process as on-site generated wastes,
intracompany and intercompany transfers are a
viable and often preferable method to treat waste
streams efficiently at a reduced cost. EPA does
not want to discourage these management
practices. EPA is still concerned, however, that
the effluent limitations and categorical standards
currently in place may not ensure, adequate
treatment in circumstances where the off-site
generated wastes are not from the same
categorical group as the on-site generated wastes..
It is not duplicative to include within the scope of
the CWT guideline, wastewater that results from
the treatment of off-site wastes not subject to the
guidelines and standards applicable to the
treatment of wastewater generated on-site.
Additionally, .even though the primary business at
these facilities is not the treatment of off-site
wastes, EPA does not believe that the burden to
these facilities exceeds that of the facilities whose
primary business is the treatment of off-site
wastes. EPA has included these facilities in all of
its economic analyses).
In the supplemental proposal, EPA proposed
subjecting centralized waste treatment operations
at manufacturing facilities to the provisions of the
rule unless one of the following conditions was
met:
• In the case of manufacturing facilities
subject to national effluent limitations
guidelines for existing sources, standards of
performance for new sources, or
pretreatment standards for new and existing
sources (national effluent guidelines and
standards), if the process or operation
generating the wastes received from off-site
for treatment is subject to the same national
effluent guidelines and standards as the
process or operation generating the on-site
wastes; or
In the case of manufacturing facilities not
subject to existing national effluent guidelines
and standards, if the process or operation
generating the waste received from off-site is
from the same industry (other than the waste
treatment industry) and of a similar nature to
the waste generated on-site.
After careful consideration of comments and
further review of its database, EPA continues to
regard this approach as appropriate, with some
modifications. EPA has concluded that many
manufacturing facilities,, even, though they are
engaged primarily in another business, are also
engaged in traditional CWT activities and,
therefore, should be subject to this rule. EPA
.has been unable to establish any direct
correlation between the source of the off-site
waste (intra-company or inter-company) and the
similarity (or compatibility with)'of the off-site
waste to the on-site generated wastes that would^
support a blanket exclusion from this rule, for.,
intra-company waste treatment EPA further
concludes that all off-site wastewaters should be
treated effectively irrespective of their volume,
or their volume in relation to the volume of on-
site generated waste and, thus, has rejected any
exception for small volumes. As explained in the
1999 proposal, EPA's primary concern is that
the effluent guidelines and standards currently in
place for one industry may not ensure adequate
treatment for wastes generated at another
industry.
EPA has, however, concluded that there are
circumstances where an off-site waste will
receive adequate treatment at the treating facility
even though the off-site waste may be- generated
by a manufacturing process that (if treated at the
generating location) would be subject to a
different set of effluent guidelines and standards
than .the effluent guidelines and standards
applicable to the treating site. The record for this
rule provides information and data on such
facilities that support EPA's conclusion. An
example is a pesticide formulating and packaging
facility (PFPR), subject to 40 CFR 455 Subpart
C, which sends its wastewaters off-site for
treatment to a facility which manufactures the
3-3
-------
Chapter 3 Scope/Applicabflity Of The Final Regulation Development Document for the CWT Point Source Category
pesticide active ingredients (the manufacturing
facility is subject to a separate set of effluent
guidelines -and standards specific to pesticide
manufacturers, 40 CFR 455 Subpart A and B).
In this case, the same pollutants are likely to be
present in the off-site and on-site generated
wastewaters, even though the wastewaters are
subject to different regulations. Therefore, the
treating facility will need to use treatment
appropriate for efficient removal.,of these
pollutants. This situation would not be covered
by this rule.
As a second example, consider a petroleum
refinery that accepts off-site wastewaters. If the
petroleum refinery (SIC Code 2911) accepts
wastes generated off-site at petroleum
distribution terminals (SIC Code 4612, 4613,
5171, and 5172), then the former is subject to.
effluent guidelines and standards for petroleum
refineries (40 CFR 419), but the latter is not
currently subject to any national effluent
guidelines. However, the wastewaters generated
at petroleum marketing terminals are based on
materials manufactured at the refineries, and
therefore would likely reflect the same pollutant
profile. This situation would not be covered by
this rule.
A third example involves clean-up activities
at manufacturing sites. As part of clean-up
operations at its facility, one commenter (called
facility A) noted that it accepts contaminated
groundwater from a different manufacturing
facility located next door (facility B). The
contaminated groundwater site (while not located
on facility A, the treating facility) was
contaminated by the manufacturing process at
the treating site (facility A) and not at the site
where located (facility B). Therefore, the
contaminated wastewater would be similar and
compatible with the on-site generated wastewater
at facility A. In this case, the CWT rule would
not apply.
EPA received information on each of the
examples provided in comment on the rule. The
comments detail instances in which the off-site
wastewaters, while not subject to the same
national effluent guidelines and standards as the
wastewater generated on-site, are similar to the
on-site generated manufacturing wastewaters and
compatible with the on-site treatment system. In
these cases, EPA concluded that the application
of the CWT rule may not result in increased
environmental protection, but simply add an
additional layer of complexity for the treating
facility and the permit writer.
Furthermore, EPA determined there are
other instances of off-site waste acceptance at
manufacturing facilities in which the off-site
wastes, while not from the same industrial
category, are similar to the on-site generated
manufacturing wastewaters and compatible, with
the manufacturing wastewater treatment system.
Consequently, for purposes of this rule, EPA has
decidedJhat,, where, the dischargers establishes
that the wastes being treated are of similar nature
and compatible with treatment of the on-site
"wastes, the CWT limitations and standards will
not apply to the resulting discharge. EPA
concluded that,. in those circumstances, the
permit writer should instead apply the limitations
applicable to the treatment of on-site wastewater
to wastewaters generated through treatment of
the off-site waste. Under the approach adopted
for the final rule, the permit writer will determine
whether the off-site generated waste accepted for
treatment and/or recovery at a manufacturing
facility (whether subject to national effluent
guidelines and standards or not) and commingled
for treatment in the on-site treatment system is
similar to the on-site generated wastes and
compatible with the on-site treatment system! If
it is, the discharge of the treated effluent should
be subject to the applicable on-site limitations (or
standards) even if the off-site wastes would be
subject to a different set of national effluent
guidelines and standards as the on-site generated
wastes (or no national effluent guidelines and
standards) if treated where generated. In the
event that the permit writer makes this
determination, the treating facility would be
subject to the on-site limits only and not subject
to the CWT guideline.
3-4
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
For this final rule, EPA has not rigidly
defined when a waste is of similar character and
the treatment of it is compatible with the
treatment of the on-site wastes, believing that
permit writers are in the best position to
determine this term. Permit writers should
compare the wastewaters at the manufacturing
facility to the off-site generated wastewaters
(constituents and concentrations) and the
appropriateness of the treatment system to the
off-site generated wastewaters on a case by case
basis. The final guideline commits the decision
that an off-site wastewater is similar and
compatible (and thus whether CWT limitations
or standards would apply) to the permit writer.
A treating facility must submit information
demonstrating to the permit writer that the off-
site waste is similar- and compatible.-- EPA
cautions permit writers that the judgment of
"similar and compatible" should be made based
only.on the development of a full record on this
issue.' If the treating facility has not clearly
established that the off-site wastewaters are
similar to the on-site generated mamifacturing
wastewaters and compatible with the treatment
system in the permit writer's best judgment, the
permit writer must apply the CWT limitations to
the treating facility.
Therefore, EPA has concluded that
centralized waste treatment operations at
manufacturing facilities will be subject to
provisions of the rule unless one of the following
conditions is met: -
• In the case of a facility subject to national
effluent limitation guidelines for existing
sources, standards of performance for new
sources, or pretreatment standards for new
and existing sources, . if the facility
demonstrates that the wastes received from
off-site for treatment and/or recovery are
generated in a process or operation that
would be subject to the same national
effluent guidelines and standards as the
process or operation generating the on-site
wastes; or
• In the case of a facility subject to national
effluent guidelines and standards if the
facility demonstrates that the waste received
from off-site is similar in nature to the waste
generated on-site and compatible with the
on-site treatment system; or
• In the case of a facility not subject to
national effluent limitations and standards, if
the facility demonstrates that the waste
received from off-site is similar in nature to
the waste generated on-site and compatible
with the on-site treatment system.
EPA contemplates that this approach would
be implemented in the following manner. A
facility that is currently subject to national
effluent limitation guidelines or pretreatment
standards "receives wastewater from off-site for
treatment. The wastewater is commingled for
treatment with manufacturing., wastewater
generated on-site. If the off-site'wastewater is
subject to the same limitations or standards as
the onsite wastewater (or would be if treated
where generated) or if the off-site wastewater is
similar to the onsite wastewater and compatible
with the treatment system, the CWT limitations
would not apply to the discharge associated with
the off-site wastewater flows. In that case, •
another guideline or standard applies. If,
however, the off-site wastewater is not subject to
the same national limitation guidelines or
standards (or if none exist) and if the off-site
wastewater is not similar to the onsite
wastewater and compatible with the treatment
system, that portion of the discharge associated
with the off-site flow would be subject to CWT
requirements (of course, the portion of the
wastewater generated on-site remains subject to
applicable limitations and standards for the
facility). If the off-site and on-site wastewaters
are commingled prior to discharge, the permit
writer would use the '"combined wastestream
formula" or "building block approach" to
determine limitations for the commingled
wastestream (see Chapter 14).
Certain facilities that are subject to the CWT
3-5
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
regulations because they accept wastes whose
treatment is not compatible with the treatment of
wastes generated on-site may nevertheless be
subject to limitations and standards based On the
otherwise applicable provisions of 40 CFR
Subchapter N. Thus, the final regulations
provide for the permit writer or pretreatment
control authority to develop "alternative
limitations and standards" for certain facilities in
a narrow set of circumstances (see e.g., 40 CFR
437.10(b)). Under this approach, which EPA
discussed in the 1999 proposal, permit writers
could require manufacturing-facilities that treat
off-site wastes to meet all otherwise-applicable
categorical limitations and standards for the
industries from which the waste was generated.
This approach would also determine limitations
or standards for any commingled on-site and off-
site wastewater using the "combined
wastestream formula" or "building block -
approach." The permit writer would apply the
categorical limitations from the ..industries
generating the wastewater, rather than the CWT
limitations, to the off-site portion of the
commingled wastestream. The use of the
combined wastestream formula and building
block approaches for CWT wastes is discussed
further in Section XIV.F of the 1999 proposal
(64 FR 2342-2343). The permit writer (or
pretreatment control authority) may establish
alternative limitations and standards only when a
facility receives continuous flows of process
wastewaters with relatively consistent pollutant
profiles from no more than five customers.
EPA's information shows that, in practice, permit
writers are currently following this approach for
facilities that treat off-site waste for no more
than five facilities. This approach is not
appropriate for facilities that receive variable off-
site wastewaters or that service more than a
handful of customers.
After further consideration of-the above
described alternative and careful consideration of
comments received on this alternative, EPA
determined that the permit writer (or local
pretreatment authority) should have the option in
a limited set of circumstances of applying the
applicable categorical limitations or standards to
the off-site wastestreams. This is the approach
described above. Thus, the final rule authorizes
permit writers(at their discretion) to subject the
wastewater associated with the treatment of the
off-site wastes to limitations and standards based
on the categorical limitations from the industries
generating the wastewater, rather than applying
'the CWT limitations to the off-site portion of the
commingled wastestream. Consequently, the
applicability provisions of Subparts A-, ~&, C and.
D provide for such authority. See 40 CFR §§
437.10(b), 437.20(b), 437.30(b) & 437.40(b).
Pipeline Transfers
(Fixed Delivery Systems)
3.1.2
EPA did not propose to apply CWT
limitations and standards to facilities that receive
off-site wastes-for treatment solely via an open
or enclosed' conduit (for example, pipeline,
channels, ditches^ trenches^ etc.).- EPA did not
propose to include pipeline facilities because,
based on information obtained by the Agency,
facilities that receive all their wastes through a
pipeline or trench (fixed delivery systems) from
the original source of waste generation receive
continuous flows of process wastewater with
relatively consistent pollutant profiles. These
wastewaters are traditional wastewaters from the
applicable industrial category that generally
remain constant from day to day in terms of the
concentration and type of pollutant parameters.
Unlike traditional CWT facilities, their customers
and wastewater sources do. not change and are
limited by the physical and monetary constraints
associated with pipelines.
EPA has reevaluated the database for this
rule. EPA received questionnaire responses
from four centralized waste treatment facilities
which receive their waste streams solely via
pipeline. EPA also examined the database that
was developed for the organic chemicals,
plastics, and synthetic fibers (OCPSF) effluent
limitations guidelines to gather additional data on
3-6
-------
Chapter 3 Scope/Applicability OfThe Final Regulation Development Document for the CWT Point Source Category
OCPSF facilities which also have centralized
waste treatment operations. Based on the
OCPSF database, 16 additional facilities are
treating wastewater received solely via pipeline
from off-site for treatment. A review of the
CWT and OCPSF databases supplemented by
telephone calls to selected facilities reveals that
one facility no longer accepts wastes from off-
site, one facility is now operating as a POTW,
and 11 facilities only accept off-site wastes that
were generated by a facility within the same
category as on-site generated waste. (The latter
facilities, under the criteria explained above,
would no longer be within the scope of "the
proposed rule because they are already subject
to existing effluent guidelines and standards.)-
Therefore, EPA identified 7 faculties which
receive off-site wastes solely via-pipeline which
may be subject to this ralemaking.
Of these seven facilities, one is a dedicated
treatment facility which is not located at a-
manufacturing site. The other six pipeline
facilities are located at manufacturing- facilities
which are already covered by an existing effluent
limitation guideline. All of the facilities are direct
dischargers and all receive waste receipts from
no more than five customers (many, receive
waste receipts from three or fewer customers).
Since the 1995 proposal, EPA conducted site
visits at two of these pipeline facilities.
Information collected during these site visits
confirmed EPA's original conclusion that wastes
received by pipeline are more consistent in
strength and treatability than "typical" CWT
wastewaters. These wastewaters are traditional
wastewaters from the applicable industrial
category that generally remain relatively constant
from day to day in terms of the concentration
and type of pollutant parameters. Unlike
traditional CWTs, their customers and
wastewater sources 'do not change and are
limited by the physical and monetary constraints
associated with pipelines.
. EPAhas also reviewed the discharge permits
for each of these pipeline facilities. EPA found
that, in all cases, permit writers had carefully
applied the "building block approach" in
establishing the facility's discharge limitations.
Therefore, in all cases, the treating facility was
required to treat each of the piped wastewaters
to comply with otherwise applicable effluent
guidelines and standards.
EPA did not receive any information in
response to the 1999 proposed rule that has
convinced the Agency to change its treatment of
pipeline facilities for purposes of this rule.
Consequently, the scope of this final rule
excludes wastes that are piped to waste treatment
facilities. See 40 CFR § 437.1.(b)(3-)_ These
wastes wflT continue to Be subject to otherwise
applicable effluent guidelines-and standards. In
EPA!s~ view,_it_is_more, appropriate for permit
writers to develop limitations for treatment
facilities that receive wastewater by pipeline on
an individual basis by applying ..the "combined
wastestream formula" or "building block"
approach. --•>-•
There are two exceptions to this approach.
The first is for facilities that receive-waste via -
conduit (that is, pipeline, trenches, ditches, etc.)
from facilities that are acting merely as waste
collection or consolidation centers that are not
the original source of the waste. These
wastewaters are subject to the CWT rule. The
basis for EPA's exclusion of waste treatment
facilities receiving wastes by pipeline from the
scope of the rule was that such facilities did not
receive the same types of varying wastes'as
CWT facilities receiving wastes by truck or
tanker. Pipeline facilities receive flows of wastes
with consistent pollutant profiles. Waste
consolidators, on the other hand, which send
their flows to a treatment facility via pipeline are
delivering wastes like those typically received by
CWT facilities in tanks or trucks. See 40 CFR §
437.1(b)(3). The second is for facilities that
serve as both CWT facilities and pipeline
facilities (i.e., receive waste from off-site via
pipeline as well as some other mode of
transportation such as trucks). If this type of
facility commingles the trucked and piped waste
prior to discharge, then both the trucked and
3-7
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
piped wastewaters at these facilities are subject
to the CWT rule. The basis for the pipeline
exclusion no longer applies because the addition
of hauled waste introduces variability in pollutant
concentrations and characteristics that are not
true for the piped wastes. See 40 CFR §
437.1(b)(3). However, if such a facility
discharges these wastewaters separately, then
only the trucked off-site wastewater is subject to
provisions of the CWT rule and the piped waste
subject to limitations and standards based on the
applicable 40 CI^SubchapterN limitations and"
standards. POTWs are not considered CWTs
and are not subject to the limitations and
standards of this rule. However, as discussed
more fully in Section 3.1.6, POTWs should not
be receiving wastes from industrial users subject
to national effluent guidelines and standards
(either by pipeline or otherwise) that do not
comply with applicable pretreament standards.
Product Stewardship
3.1.3,
Many members of the manufacturing
community have adopted "product stewardship"
programs as an additional service for their
customers to promote recycling and reuse of
products and to reduce the potential for adverse
environmental impacts from chemical products.
Many commenters have defined "product
stewardship" in this way: "taking back spent,
used, or unused products, shipping and storage
containers with product residues, off-
specification products and waste materials from
use of products." Generally, whenever possible,
these manufacturing plants recover, and reuse
materials in chemical processes at their facility.
Manufacturing companies that cannot reuse the
spent, used, or unused materials returned to
them treat these materials/wastewaters in their
wastewater treatment plant. With few
exceptions, all of the materials (which are not
reused in the manufacturing process) that are
treated in the on-site wastewater treatment
systems appear to have been produced in the
same effluent limitations guidelines point source
category as the on-site manufactured materials.
In industry's view, such materials are inherently
compatible with the treatment system. EPA
' received no specific information on these product
.stewardship activities in the responses to the 308
Waste Treatment Industry Questionnaire. EPA
obtained information on this program from
comment responses to the 1995 CWT proposal
and in discussions with industry since the 1995
proposal. As part of their comment to the 1995
proposal, the Chemical Manufacturer's
Association (CMA) provided results of a survey
of their members on product stewardship
activities. Based on these survey results, which
are shown in Table 3-1 and Table 3-2, the vast
majority of materials received under the product
stewardship programs are materials received for
product rework. A small amount is classified as
residual recycling and an even smaller amount is
classified as drum take backs. Of the materials
received, the vast majority is reused in the
manufacturing process. With few exceptions, all
of the materials (which are not reused in the
manufacturingprocess)Jhat are treated in the on-
site wastewater treatment systems, appear to be
from the same categorical group as the on-site
manufactured materials.
3-8
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
Table 3-1. Summary of the Frequency of the Types of Activities and Dispositions Reported
Activity
Disposition
Item .
Drum Returns
Residual Recycling
Product Rework
Other
Rework/Reuse
On-site Wastewater Treatment
Off-site Disposal
Number
3.
7
50
2
53
22
29
% of Total7
5%
12%
86%
3%
91%
38%
50%
7Based on information submitted by 33 CMA member facilities. Of these 33 members, 13 reported
information concerning more than one product type, or activity. Therefore, the percentage of the
total is based on 58 separate entries on the survey.
Table 3-2. Summary of Frequency of Each Product Class Reported by Facilities
Product Class Number of Facilities
Polymers, Plastics,.and Resins
OrganicjChemicals
Solvents and Petroleum Products
Inorganic Chemicals
Pesticides
Unspecified
17
6
3 '
4
2
. 4
Percent of Total ;
52%
18%
9%
12%
: 6%
12%
'Based on Responses from 33 CMA facilities.
In the proposal, EPA explained that it had
decided to apply the same approach to
wastewater generated from materials that are
taken back for recycle or re-use as is applied to
wastewater received from off-site by a
manufacturing facility (i.e., if the materials
received from off-site under the product
stewardship program would.be subject to the
same limitations and standards for the same
categorical industry as the on-site generated
manufacturing wastes, the treating facility would
not be subject to CWT requirements). Because
EPA remained concerned that circumstances
exist in which used materials or waste products
may not be compatible with the otherwise
existing treatment system, EPA did not propose
a blanket exemption for product stewardship
activities from the scope of this rulemaking.
EPA proposed that those activities that
wastewater from the treatment of used products
or waste materials would be subject to the CWT
rule if it were not produced at facilities subject to
the same provisions of Subchapter N as
wastewater from the treatment of the other on-
site generated wastes.
EPA received numerous comments on its
proposed approach for treating product
stewardship activities. Many commenters
claimed that 'the proposed rule would deter
product stewardship activities, and that EPA
should not include any product stewardship
activities in the scope of the CWT rule. Some
commented that these materials are generally not
"treated", but re-used or recovered, and that for
that reason they were fundamentally different
from other wastes in the CWT industry. Others
3-9
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
commented that while EPA's intent seemed to
be appropriate, the language was much too
restrictive. For example, commenters noted that
when a product goes off-site to another
manufacturing facility which is subject to
different categorical standards, the product
(while it remains unchanged) would then be
subjectto a different set of categorical standards.
If the manufacturing facilities which originally
produced the product took back the off-spec
'product from its customer, the proposal, as
written, would require that the treating facility be
subject to CWT guidelines even though the off-
spec waste would clearly be the same as those
generated on-site.
EPA applauds the efforts of manufacturing
facilities to reduce pollution and the
environmental impacts of theirproducts and does.
not want to discourage these practices.
Consequently, EPA has decided-that-product
stewardship activities at a manufacturing facility-,
which involve taking back their unused products, "
shipping and storage-containers'with' product
residues, and off-spec products should not be
subject to provisions of the CWT rule.
EPAremains concerned, however, about the
treatment of spent, used, or waste materials
returned to the original manufacturer. EPA's
concern is that treatment of the spent, used, or
waste materials with the on-site wastewater may
not be .compatible with the otherwise existing
treatment system. The fact that these materials
may be accepted for re-use or recycling rather
than "treatment" does not ensure that resulting
wastewaters would be inherently compatible with
the treatment system. EPA is unable to see how
such activities differ from waste recovery
operations that the Agency has concluded should
be subject to these guidelines. For example, a
facility manufactures industrial chemicals which
are then sent to a customer which uses these
chemicals in the manufacture of printed circuit
boards. The inorganic chemical manufacturer
accepts spent etchants (waste materials from use
of product) from its customer for recovery and
re-use of certain metals in their inorganic
chemical manufacturing process. fNfote that
CWT facilities not located at manufacturing sites
also accept spent etchants). The recovery
process generates a wastewater. This
wastewater may contain many pollutants which
were not present in the wastewater generated in
manufacturing the inorganic chemical and which
may not be compatible with, or effectively
treated, hi the treatment process at the inorganic
chemical manufacturing facility. The same may
be true if the accepting facility determined that
spent etchant could not be effectively reused and
recovered and directed the material to their
wastewater treatment system.
Therefore, EPA has concluded that product
stewardship activities that involve taking back
spent, used, or waste materials from use of
products should, as a general matter, be subject
to provisions of this rule unless any of the
exclusions established for manufacturing
facilities, as= explained in Section 3.1.1, would
apply. Thus, those activities that involve used
products or waste materials that are not subject
to effluent guidelines or standards from the same
category as the on-site generated wastes or that
are not similar to the on-site generated
manufacturing wastes and compatible with the
treatment systems (as determined by the permit
writer) are- subject to the rule. EPA does not
believe this approach will curtail product
stewardshipjictivities, in general, but will ensure
that all wastes are treated effectively.
Federally-Owned Facilities
3.1.4
Throughout development of this rule, EPA's
database has included information on CWT
facilities owned by the federal government. It
has always been EPA's intention that federal
facilities which accept wastes, wastewater, or
used material from off-site for treatment and/or
recovery of materials would be subject to
provisions of this rule unless they meet the
conditions under which the rule would not apply,
e.g. treated off-site wastes subject to the same
40 CFR Subchapter N provisions as the federal
3-10
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
facility.
EPA's database contains information on 23
federally owned facilities that operate treatment
systems. EPA has determined that 15 of these
facilities are not subject to provisions of the
CWT rule because they do not accept off-site
wastes. Of the remaining facilities, 6 are not
subject to provisions of the CWT rule because
they perform CWT activities to which the rule
would not apply. Therefore, EPA has identified
1 federally-owned CWT facility that is subject to
this rule. EPA has included this facility in all of
its analyses. ' .
Marine Generated Wastes
3.1.5
EPA received many comments on the
original proposal relating to marine generated
wastes. Since these wastes are often generated
while a ship is at sea and subsequently off-loaded
at port for treatment,, the. treatment, site could...
arguably be classified as a CWT due to its
acceptance of "off site wastes. Commenters,
however, claimed that marine generated wastes
should not be subject to the CWT rule for the
following reasons:
• Unlike most CWT waste streams, bilge
and/or ballast water is generally dilute and
not toxic; and
• Most of the bilge water is generated while
the ship is docked. If only the small portion
of bilge water contained in the ship upon
docking is subject to regulation, it would be
expensive and inefficient to monitor only
that small portion for compliance with the
CWT rule.
EPA reexamined its database concerning
these wastes as well as additional data on the
characteristics of these types of wastes provided
through comments to the 1995 proposal. Based
on data provided by industry on bilge and ballast
water characteristics, bilge and ballast water can
vary greatly in terms of the breadth of analytes
and the concentration of the analytes from one
ship to another. In most instances, the analytes
and concentrations are similar to those found in
wastes typical of the oils subcategory. EPA
found that while some shipyards have specialized
treatment centers for bilge and/or ballast wastes,
some of these wastes are being treated at
traditional CWTs.
In the proposed rule (64 FR 2291), EPA
defined "marine waste" as waste generated as
part of the normal maintenance and operation of
a ship, boat, or barge operating on inland, coastal
or open waters. Such wastes may include ballast
water, bilge water; and other wastes generated as -
part of routine ship operations. The proposal
further explained that EPA considered
wastewatef off-loaded from a ship as being
generated on-site at the point where it is off-
loaded provided-that~the_waste is.generated-as .
part of the routine maintenance and operation of
the ship on which it originated while at sea. The
waste is not considered an off-site generated
waste (and thus subject to CWT requirements)
as long as it is treated'and discharged at the ship "
servicing facility where it is off-loaded.
Therefore, EPA proposed not to include these
facilities as CWT facilities. The proposal further
clarified that if marine generated wastes are off-
loaded and subsequently sent to a CWT facility
at a separate location and commingled with other
covered wastewater, these facilities and their
wastestreams would be subject to provisions of
this rule.
After careful consideration of comments,
EPA has not modified its approach for marine _
generated waste with one exception. For today's
rule, EPA defines marine waste as waste
generated as part of the normal maintenance and
operation of a ship, boat, or barge operating on
inland, coastal or open waters, or while berthed.
See 40.CFR § 437.1(c)(2). In response to
commenters' requests for clarification, EPA has
changed the definition to clarify that wastes
generated while ships are berthed are part of
normal maintenance and operational activities
and are thus "on-site." As a further point of
clarification, waste generated while a ship is
3-11
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
berthed is not an off-site generated waste so long"
as it is treated and discharged at the ship
servicing facility where it is off-loaded. If,
however, marine generated wastes are off-loaded
and subsequently sent to a CWT facility at a
separate location and commingled with other
covered wastewater, these facilities and their
wastestreams are subject to provisions of this
rule.
Publicly Owned Treatment Works
(POTWs)
3.1.6
Comments to the 1995 and, 1999 CWT
proposals establish that large and small POTWs
• accept a large volume of hauled wastes. A
special discharge survey conducted by the
Association of Metropolitan Sewerage Agencies
(AMSA) indicates that 42.5 percent of POTW
respondents accept hauled industrial wastes.-
This study was submitted as comment to -the
1995 CWT proposal. Based on comments to the*
1999 proposal, EPA believes this is likely an
underestimate of current activities.
A large quantity of the wastes trucked to
POTWs is septage and chemical toilet wastes.
EPA did not evaluate these wastes for regulation
and they are not subject to this rule. EPA would
expect that POTWs would adequately treat these
sanitary waste flows because EPA would expect
septage and chemical toilet wastes to closely
resemble sewage with respect to organic content.
POTWs also receive significant volumes of
trucked industrial and commercial wastes.
Examples of these include wastes subject to
pretreatment standards under 40 CFR subchapter
N, as well as wastes not subject to national
effluent guidelines and standards. These wastes .
may include oil-water emulsions or mixtures,
coolants, tank cleaning water, bilge water,
restaurant grease trap wastes, groundwater
remediation water, contaminated storm water
run-off, interceptor wastewaters, and used
glycols. CWT facilities also treat many of these
wastes and discharges from these operations may
be subject to the final CWT limits.
EPA received numerous comments on how
the CWT rule should apply to POTWs.
Commenters were largely divided on the
applicability of the CWT rule to POTWs. All of
the POTWs that commented on the proposal
agreed that the CWT rule should not apply to
POTWs. . They stated that under the CWA,
effluent guidelines and pretreatment standards do
not apply to POTWs. Rather, as established by
the CWA, POTWs are subject to secondary
treatment and water quality standards. These
commenters further stated that POTWs generally
accept trucked wastes as a service to their
community to insure that -these-wastes-receive
proper treatment. Commenting POTWs further
cited that trucked wastes comprise a de minimis
portion of the total volume of wastewater treated
at their facilities.
Non-POTW commenters were, on the other
hand,-unanimous in stating that the CWT.rule
should apply to POTWs. These commenters
asserted that POTWs and CWT facilities are
competing for many of the same wastestreams,
and therefore POTWs should be subject to the
same standards as CWT facilities. These
commenters stated that POTWs are actively
competing for wastestreams not subject to
national effluent guidelines and standards, and
cautioned that EPA should be concerned that this
hauled waste is being accepted with little or no ,
documentation regarding the source, little or no
monitoring of the shipments when they arrive,
and no pretreatment before mixing with the
normal POTW influent. They also expressed
concern that POTWs often do not have
equivalent treatment compared to CWT facilities
and that pollutant reductions are often due to
dilution rather than treatment. Finally, many
CWT facilities commented that by not including
POTWs in the scope of the CWT rule, EPA '
might actually increase the discharge of
pollutants to the nation's waters since waste
generators will have an incentive to ship directly
to POTWs thus skipping what would have been
effective pretreatment at the CWT facility.
It is clear from reviewing the comments that
3-12
-------
Chapter 3 Scope/Applicability OfThe Final Regulation Development Document for the CWT Point Source Category
many commenters may misunderstand the
interaction between effluent 'guidelines and
pretreatment standards, and they are
consequently confused about how this guideline
will affect POTW operations. The following
discussion is intended as clarification. Under the
CWA, all direct dischargers must comply with
technology-based effluent guidelines and any
more stringent limitations necessary to meet
State water quality standards. In ,the case of
certain pollutants and for certain categories and
classes of direct dischargers, EPA promulgates -
guidelines that establish these technology-based
limitations. In the case of POTWs, the CWA
specifically identifies the technology — secondary
treatment - that is the basis for POTW effluent
limitations.
In addition, the CWA also requires EPA to
establish pretreatment standards for indirect
dischargers,- thoseJntroducing wastewater to a
POTW either by pipe or sewer or by
transporting the waste by truck or rail to the
POTW. These standards are designed to
prevent the discharges of pollutants that pass-
through, interfere or are otherwise incompatible
with POTW operations. The standards are
technology-based and analogous to technology-
based effluent limitations applicable to direct
dischargers. Once EPA has established
pretreatment standards, no indirect discharger
may introduce wastewater to a POTW for which
there are pretreatment standards except in
compliance with the standard. The CWA
specifically prohibits the owner or operator of
any source from violating a pretreatment
standard (see section 307(d) of the CWA). This
prohibition applies whether the wastewater is
discharged through a sewer system or sent to a
POTW.by truck or rail.
The CWA. does authorize a POTW, in
limited circumstances, to revise pretreatment
standards for a discharger to. take account of the
, POTW's actual removal of a particular pollutant.
"Removal credits" may be available to a
discharger generally under the following
conditions. First, the granting of the removal
credit by the POTW must not cause a violation
of the POTWs permit limitations or conditions.
Second, the POTW's treatment of the pollutant
must not result in a sewage sludge that cannot be
use of disposed of in accordance with sewage
sludge regulations promulgated pursuant to
section 405 of the CWA (see section 307(b) of
the CWA).
EPA has promulgated regulations at 40 CFR
Part 403 (General Pretreatment Regulations for
Existing and New Sources of Pollution) that
establish pretreatment standards and_
requirements that apply to any source
introducing pollutants from a non-domestic
source into a POTW. These standards include
a general prohibition on the introduction of any
pollutant that might pass through or interfere as
well as prohibitions on specific pollutants such as'
those that may create a fire or explosion hazard
or corrosive structural damage. EPA has also
promulgated' national effluent pretreatment
standards (like the pretreatment standards
promulgated here today) for specific industry
categories as separate regulations at 40 CFR
subchapter N.'
The regulations at 40 CFR Part 403 also
require all POTWs with a design flow greater
than 5 MGD per day to develop a pretreatment
program. Moreover, EPA or a State may require
a POTW with a design flow that is less than or
equal to 5 MGD to develop a pretreatment
program if warranted by circumstances in order
to prevent pass through or interference (see 40
CFR 403.8(a)). These pretreatment programs
must require compliance with all applicable
pretreatment standards and requirements by
industrial users of the POTW (see 40 CFR
403.8(f)(ii)). Furthermore, each POTW
developing a pretreatment program must develop
and enforce specific local limits to implement the
general and specific prohibition against pass-
through and interference (see 40 CFR 403.5(c)).
Thus, any POTW subject to the requirement to
develop a pretreatment program that accepts
waste that does not comply with a general or
specific prohibition or with national effluent
3-13
-------
Chapter 3 Scope/Applicability OfThe Final Regulation Development Document for the CWT Point Source Category
pretreatment standards is in violation of the
regulations.
Consequently, following promulgation of this
rule, POTWs with pretreatment programs that
receive wastestreams both subject to and not
regulated by national effluent standards and
limitations must ensure the wastestreams do not
violate these requirements. In practice, with .
respect to the wastestreams discussed by
commenters, this means that a POTW may not
accept untreated wastestreams subject to national
effluent guidelines and standards. These would
include wastestreams subject to pretreatment
standards in 40 CFR subchapter N (e.g.,
electroplatingwastes). Moreover, a POTW may
not accept certain other streams not subject to
national guidelines and standards such as oil-
water emulsions or mixtures if those streams'
contain pollutants that would pass through or
interfere with POTW .operation. Note that 40
CFR 403.5(b)(5) specifically prohibits the
introduction into a POTW of petroleum oil that
will cause pass-through or interference. Given
EPA's conclusion that oily wastewaters contain
pollutants that will pass-through-POTWs; it is
likely that many POTWs are accepting wastes
for treatment that contain pollutants that will pass
through.
EPA is concerned that wastestreams
accepted at POTWs, both those subject to and
those not regulated by national effluent guidelines
and standards, receive proper treatment. • In
1999, EPA's Office of Wastewater Management
published the "Guidance Manual for the Control
of Wastes Hauled to Publicly Owned Treatment
Works" (EPA 833-B-98-003, September 1999).
This document again stresses that national
effluent pretreatment standards apply to waste
generated by national effluent guidelines and
standards (40 CFR parts 401 to 471), whether
the waste is introduced to the POTW through
the sewer system or hauled to the POTW.
Moreover, EPA regulations require that POTWs
must ensure pretreatment of wastes subject to
national effluent standards received at 'the
POTW regardless of the mode of transportation.
Similarly, because a POTW must ensure that
no user is introducing pollutants into the POTW
that would pass-through the POTW into the
receiving waters or interfere with the POTW
operation, EPA strongly recommends that each
POTW should document and monitor all hauled
wastestreams to ensure that necessary
pretreatment steps have been performed. The
guidance establishes a waste acceptance
procedure that clearly resembles that generally
performed at CWT facilities. Further, in the
case of wastestreams not subject to national
guidelines and standards, the POTW should also
monitor the hauled wastestreams to ensure that
pollutant reductions at the POTW will be
achieved through treatment and not dilution.
Based on the types of hauled wastewater
that commenters have indicated POTWs accept,
EPA shares the concern of many commenters
that pollutant reductions in these hauled
wastewaters at POTWs are largely due to
dilution. EPA'reminds POTWs that wastewaters
that .contain significant quantities of metal
pollutants, significant quantities o"f petroleum-
based oil and grease, or significant quantities of
non-biodegradable organic constituents should be
pretreated by the generating facility or ' an
appropriate treatment facility prior to acceptance
at the POTW. EPA further reminds POTWs
that this remains true regardless of whether or
not these wastewaters comprise a de minirnis
portion of the total volume of the wastewaters
treated at their facility. EPA concluded that if
POTWs monitor hauled .wastes appropriately
and additionally ensure that all hauled wastes not
subject to national effluent guidelines and
standards can be effectively treated with their
biological treatment systems then many of the
issues raised by non-POTW commenters will be
alleviated.
Finally, if a POTW chooses to establish a
pretreatment business as ah addition to their
operation, they may, in given circumstances, be
subject to provisions of this rule. EPA is aware
of a POTW that plans to open a wastewater
treatment system to operate in conjunction with
3-14
-------
Chapter 3 Scope/Applicability Oflhe Final Regulation Development Document for the CWT Point Source Category
its POTW operations. This facility would accept
wastewaters subject to national guidelines and
standards, treat them, and then discharge them to
the POTW's treatment plant. The acceptance by
a POTW of wastes subject to national effluent
guidelines and standards that do not comply with
pretreatment standards would seem to violate the
requirements noted previously unless the POTW
has revised the applicable standards to take
account of its removal of certain pollutants.
EPA's regulations at 40 CFR § 403.7 describe
the process for obtaining removal credits and
identifying the pollutants for which removal
credits may be available. Under the current
regulations, removal credits are only available for
a limited number of pollutants. The 1999 notice
described the removal credits program and when
and for what pollutants such credits might be
available at 64 FR 2339-10. EPA would note
that the new wastewater treatment system would,
itself be a POTW (or part of the POTW) and,
thus, any wastewater introduced to it must meet
all applicable pretreatment standards. However,
because POTWs are already covered by the
technology requirements (i.e., secondary
treatment) specified in the CWA (40 CFR 133),
they are not considered CWT facilities and are
not within the scope of this rule.
Thermal Drying of POTW Biosolids 3.1.7
The thermal drying of POTW biosolids was
not a focus of EPA's initial regulatory effort to
develop this guideline. Consequently, EPA did
not target thermal dryers during its data
collection activities. However, commenters to
the 1999 proposal provided information on
thermal drying activities and requested EPA's
views as to whether such operations would be
subject to this rule. Thermal dryers accept off-
site generated POTW biosolids (sludges that
remain after wastewater treatment .at a POTW)
and treat these biosolids with a variety of
technologies (e.g. rotary drum dryers) to form
pellets. These biosolids can then be land applied.
The thermal drying process generates two
primary wastewater streams: facility water wash
down and blowdown from wet scrubbers. These
wastewaters are discharged back to the POTW
that produced the biosolids.
Commenters to the 1999 proposal requested
that EPA not include these activities within the
scope of this rule for the following reasons:
The POTW and the thermal dryer form a
closed loop system. POTWs are the sole
source of off-site waste received by thermal
dryers. All wastewaters generated from the
treatment of these biosolids are returned to
the generator (the POTW).
• All storage and processing areas at these
facilities are enclosed. Therefore, this
material poses very little or no threat to
storm water.
• Thermal drying activities bear little
resemblance to the other regulated activities.
Mandated testing parameters and other
requirements under the CWT rale have little
applicability to biosolids processing.
EPA agrees with commenters that thermal
drying of biosolids should not be subject to
provisions of the CWT rule. Because the only
source of off-site wastes received at these drying
facilities is biosolids produced at the POTW, the
wastewater being generated from thermal drying
of these biosolids should contain the same
pollutants being treated at the POTW. As a
result, the .wastewater should be completely
compatible with the treatment system at the
POTW and should not cause any pass-through
or interference. Consequently, thermal drying of
POTW biosolids is not subject to provisions of
the CWT rule. See 40 CFR § 437.1(b)(4).
Transporters and/or Transportation
Equipment Cleaners
3.1.8
Facilities that treat wastewater that results
from cleaning tanker trucks, rail tank cars, or
barges may be subject to the provisions of this
rule if not subject to the Transportation
3-15
-------
Chapter 3 Scope/Applicability OfThe Final Regulation Development Document for the CWT Point Source Category
Equipment Cleaning (TEC) Point Source
Category guidelines (40 CFR Part 442). Thus,
the CWT rule does not apply to discharges from
wastewater treatment at facilities engaged
exclusively in cleaning the interiors of
transportation equipment covered by the TEC
regulation. EPA promulgated these guidelines on
August 1-4, 2000 at 65 FR 49666. The TEC
regulation applies to facilities that solely accept
tanks which have been previously emptied or
that contain a small amount of product, called a
"heel," typically accounting for less than one
percent of the volume of the tank. A facility that
accepts for cleaning a tank truck, rail tank car, or
barge not "empty" for purposes of TEC may be
subject to the provisions established for the
CWT rule.
There are some facilities that are engaged in
traditional CWT activities and also, engaged in
traditional TEC activities. If the'wastewaters
from the two operations are commingled, under
the approach adopted forTEC, the commingled'
wastewater flow from the transportation
equipment cleaning activities would be subject to
CWT limits. Therefore, a facility performing
transportation equipment cleaning as well as
other CWT services that commingles these
wastes is a CWT facility and all of the
wastewater discharges are subject to provisions
of this rule. If, however, a facility is performing
both operations and the wastestreams are not
commingled (that is, transportation equipment
cleaning process wastewater is treated in one
system and CWT wastes are treated in a second,
separate system), both the TEC rule and CWT
rule apply to the respective wastewaters. See 40
CFR § 437.1(b)(10).
As a further point of clarification, the CWT
rule does apply to transportation equipment
cleaning wastewater received from off-site.
Transportation equipment cleaning wastes
received from off-site that are treated at CWT
facilities along with other off-site wastes are
subject to provisions of this rule.
Landfill Wastewaters
3.1.9
EPApublished effluent limitations guidelines
for Landfills (40 CFR Part 445) at 65 FR 3007
(January '19, 2000). There, EPA established
limits for facilities which operate landfills subject
to the provisions established in 40 CFR Parts
257,258,264, and 265. The final Landfills rule
limitations do not apply to wastewater associated
with landfills operated in conjunction with other
industrial or commercial operations in most
circumstances.
In the CWT industry, there are some
facilities that are engaged both in CWT activities
and in operating landfills. For the CWT final
rule, EPA's approach- to-facilities-which- treat
mixtures of CWT wastewater and landfill
wastewater is consistent with that established for
the landfill guideline. Therefore, a facility
performing landfill activities as well as other
CWT services that commingles the wastewater
is a CWT facility only, and all of the wastewater
discharges are subject to the provisions of this
rule. If a. facility is performing both operations
and the wastestreams are not commingled (that
is, landfill wastewater is treated in one treatment
system and CWT wastewater is treated in a
second, separate, treatment system),. the
provisions of the Landfill rule and CWT rule
apply to their respective wastewater.
Additionally, under the approach established
in the Landfills rulemaking, CWT facilities which
are dedicated to landfill wastewater only,
whether they are located at a landfill site or not,
are subject to the effluent limitations for
Landfills. These dedicated landfill CWT
facilities are not subject to provisions of the
CWT rulemaking.
As a further point of clarification, landfill
wastewater is not specifically excluded from
provisions of this rule. Landfill wastewater that
is treated at CWT facilities along with other
covered off-site wastestreams are subject to
provisions of this rule. Furthermore, a landfill
that commingles for treatment its own landfill
wastewater with other landfill wastewater only is
3-16
-------
Chapter 3 Scope/Applicability OfThe Final Regulation Development Document for the CWT Point Source Category
subject to the Landfill limits in the circumstances
described in Section 3.1.1 above.
Incineration Activities
3.1.10
In January 2000, EPA promulgated effluent
guidelines and pretreatment standards for
wastewater discharges from a limited segment of
the waste combustion industry at 65 FR 4360
(January 27,2000). This regulation, codified at
40 CFR Part 444, applies to the discharge from
a "commercial hazardous waste combustor"
(CHWC). CHWCs are commercial incinerators
that treat or recover energy-from hazardous
industrial waste.
There may be certain industrial facilities (for
whom EPA has established guidelines limitations
or,standards in 40 CFR,subpart N) which are
subject to the CWT regulation that also operate
incinerators or GHWCs. For the CWLfinaLrule^
EPA has adopted the same approach it has
followed for other industrial facilities subject to
national limitations and standards. Where a
facility treats CHWC (or other, incinerator
wastewater) -with CWT wastewater, the permit
writer (or local control authority) would establish
discharge limitations (or pretreatment standards)
by using a flow-weighted combination of the
CHWC limitations/standards (or BPJ incinerator
wastewater limitations/standards) and the CWT
limitations/standards. Thus, an organic chemical
facility with an on-site CHWC (or other
incinerator) that is also a CWT would be subject
to combined wastestream formula pretreatment
standards or building block limitations based on
all three 40 CFR subpart N regulations.
Additionally, a facility which only treats
CHWC wastewater (or other incinerator
wastewaters or waste that is similar in nature as
determined by the permitting authority, see
Section 3.1.1), whether located at a CHWC site
or not, would be subject not.to the CWT
regulations but to the otherwise applicable
limitations or standards (either CHWC or, in the
case of non-CHWC incinerator wastewater,
limitations or standards developed by the permit
writer or local control authority). EPA notes,
however, that it has not identified any CWT
facilities that are dedicated to CHWC (or other
incineration) wastewaters only.
Further, incineration wastewaters are not
specifically excluded from provisions of this rule.
Incineration wastewaters received from off-site
that are treated at CWT facilities along with
other covered off-site wastestreams are subject
to CWT limitations and provisions of this rule.
Solids, Soils, and Sludges
3.1.11
EPA did not distinguish in its information
gathering efforts between those waste treatment
and recovery facilities treating aqueous waste
and those treating non-aqueous wastes or a
combination of both. Thus, EPA's 308 Waste
Treatment Industry- Questionnaire and related
CWTDetailedMonitorihg Questionnaire (DMQ)
asked for information on CWT operations
without regardJo the type of waste treated.
EPA's sampling program also included facilities
that accepted both-aqueous"and"solid wastes for;
treatment and/or recovery. In fact, the 'facility
that forms the technology basis for the metals
subcategbry limitations treats both liquid and
solid wastes. A facility that accepts wastes from
off-site for treatment and/or recovery that
generates a wastewater is subject to the CWT
rule regardless of whether the wastes are
aqueous or non-aqueous. Therefore, wastewater
generated in the treatment of solids received
from off-site is subject to the CWT rule.
As a further point of clarification, the main
concern in the treatment or recycling of off-site
"solid wastes" is that pollutants contained in the
solid waste may be transferred to a process or
contact water resulting in a wastewater that may .
require treatment. Examples of such
wastewaters include, but are not limited to the
following:
entrained water directly removed through
dewatering operations (for example, sludge
dewatering);
3-17
-------
Chapter 3 Scope/Applicability Ofllie Final Regulation Development Document for the CWT Point Source Category
• contact water added to wash or leach
contaminants from the waste material; and
• storm water that comes in direct contact
with waste material which contain liquids.
The treatment or recovery of solids that remain
in solid form when contacted with water and
which do not leach any chemicals into the water
are not subject to this rule. Examples of
excluded solids recovery operations are the
recycling of aluminum cans, glass and plastic,
bottles. As a further point of clarification, any
wastewater. generated, at a municipal recycling
center is not subject to provisions of this rule.
Scrap Metal Processors and Auto
Salvage Operations 3.1.12
During development of this regulation, EPA
did not examine facilities engaged in scrap metal
processing or auto salvage operations as part of
its study. EPA did not attempt to collect
information on these types of operations.
However, commenters to the 1999 proposal
provided some information, on these, activities
Commenters noted that these operations often
generate contaminated wastewaters as a
secondary part of their operations. As described
by commenters, wastewater is often produced
when rainwater comes in contact with the scrap
metal and/or automobiles during collection and
storage. This rainwater then becomes
contaminated with oily residue from the scrap
metal and/or automobiles. Contaminated storm
water is the only wastewater resulting from these
operations.
Because contaminated storm water
generated from centralized scrap metal
processing or auto salvage operations would, as
the regulatory language is specified, be subject to
regulation, EPA considered whether it had a
basis for regulating wastewaters from these
operations. Other than the limited information
supplied by commenters, EPA has very little data
concerning these activities and the facilities that
, conduct these activities. As a result, EPA
concluded that it should not include within the
scope, of the guideline wastewaters generated
from centralized scrap metal processing or auto
salvage at this time. EPA would expect that
permit writers would develop limitations or local
limits to establish site-specific permit
requirements for any centralized scrap metal
processing or auto salvage operations generating
and discharging a contaminated stormwater.
Transfer Stations
3.1.13
During the initial stages of development of
this rule, EPA did not envision transfer stations
as part of the centralized waste treatment
industry. As such, EPA did not attempt to
collect information on the operation of transfer
stations. However, EPA received comment to
the_ 1999 proposal,asking that EPA clarify its
coverage of these facilities by this rule.
EPA has very little information on the
operation of transfer stations. Based* on
comments, while transfer stations could fall
within the definition of a CW-T since they-accept
off-site industrial wastes, they do not perform
any treatment or recovery of the off-site wastes.
Transfer stations simply facilitate the distribution
of wastes for disposal. Consequently, EPA has
concluded that transfer stations should not be
subject to provisions of the CWT rule.
Stabilization
3.1.14
As explained in the 1999 proposal, EPA
concluded that, by definition,
stabilization/solidification operations are "dry"
and do not produce any wastewater. As such,
EPA did not propose to include
stabilization/solidification processes in the CWT
rule. At that time, EPA also explained that it was
considering a subcategory for stabilization
operations with a zero discharge requirement,
and requested comment on this approach.
EPA received very little comment on
stabilization/solidification and no new data from
industry following the 1999 proposal. One
3-18
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
'commenter suggested EPA require
stabilization/solidification operations to be zero
discharge. Another suggested EPA use the same
approach proposed for facilities handling used oil
filters. A third commented that EPA should not
promulgate a zero discharge requirement
because, in the event that a wastewater is
produced by stabilization/solidification
operations, the facility would not have the option
to treat the wastewater on-site.
EPA re-examinedits- database and concluded
that the while "solidification / stabilization"
processes do not themselves produce any
wastewater, there are often wastewaters
associated with these processes. The major
wastewater reported by questionnaire
respondents associated with
stabilization/soh'dification operations is equipment
wash down. Further,- the~database shows that
many of the-wastes accepted from off-site for
stabiuzation/solidification are the same or similar
to wastes accepted for other covered CWT
operations.
Consequently, EPA is not promulgating a
subcategory for stabilization/solidification with a
zero discharge requirement. EPA agrees with
commenters that, in the event that there are
wastewaters produced by or associated with
these operations, facilities should have the option
of choosing whether to treat the wastes on-site or
through other means. If these operations
produce a wastewater, then the discharge of
wastewater from these facilities should be
subject to provisions of this rule. Therefore,
"dry" stabilization/solidification operations
themselves are not subject to provisions of the .
CWT rule. However, wastewater discharges
from stabilization/solidification operations that
are performed on waste received from off site
are subject to provisions of this rule. This
approach is consistent with EPA's approach to
fuel blending operations and used oil filter
management.
Waste, Wastewater, or Used Material
Re-use 3.1.15
EPA recognizes that some facilities accept
wastewater from off-site for. re-use rather than
treatment or recovery. The intent in accepting
these off-site "treated" wastewaters is to replace
potable water or more expensive pure water
obtained from wells, surface waters, etc.
Examples include, but are not limited to the
following:
• the acceptance of wastewater from off-site
for use in place of potable water in industrial
processes;
• the use of secondary POTW effluents as
non-contact, cooling water; and
•- the use-of storm water in place ofpotable-
"water at shared industrial facilities located in
industrial parks.
Likewise, EPA is also aware that some facilities
accept used materials such as spent pickle liquor
for re-use as a^treatment-chemical in place of-
virgin treatment chemicals.
EPA applauds all pollution prevention
activities, especially those that allow treated
wastewater or spent chemicals to be re-used
rather than discharged. EPA does not define this
type of activity as treatment or recovery.
Therefore, the acceptance of off-site wastewater
or spent chemicals for re-use in the treatment
system or other industrial process is not a CWT
activity and is not subject to provisions of this
rule.
Recovery and Recycling Operations 3.1.16
Many CWT facilities perform recovery
activities that lead to recycling of materials either
at the recovering site or at another location. The
purpose of these activities is to recycle product
back into a use for which it was originally
intended, not the treatment and disposal of
wastewater streams. Examples of such activities
include but are not limited to the following: used
oil processing, used glycol recovery, fuel
3-19
-------
Chapter 3 Scope/Applicability OfThe Final Regulation Development Document for the CWT Point Source Category
blending, metals recovery, and re-refining.
Many commenters to both the 1995 proposal
and the 1999 proposal noted that these activities
should not be included, under the scope of this
rule because they are not "treatment," but
"recovery" activities.
EPAapplauds efforts to reduce pollution and
the ancillary adverse consequences to the
environment associated with product disposal
and does not want to discourage these practices.
However, EPA also recognizes that, while the
intent of these activities is not treatment of a
"wastewater" but rather recovery of a used or
waste material, wastewater is usually generated
from these recovery processes.. Generally, the
facility performing the recovery activity also
performs on-site treatment of the resulting
wastewater. EPA wants to ensure that these
wastewaters receive appropriate treatment.
From the beginning of its data gathering
activities associated with the development of this
rule, EPA has included recycling and recovery
activities along with wastewater treatment
activities. In fact, EPA developed sections of the
308 Questionnaire to specifically target the
collection of information on metals, solids, oils,
and organics recovery activities. Many of the
facilities visited and sampled by EPA perform
recovery operations. Some of these facilities
refer to themselves as "recyclers" and not
"wastewater treatment facilities." EPA's
sampling data show that in many instances the
pollutants and concentrations of pollutants in
wastewaters generated from recycling/recovery
activities are very similar or more concentrated
than wastewaters accepted for "treatment" only.
In fact, many facilities that perform recovery
operations combine the wastewater generated
from the recovery operations with other off-site
wastewater received for treatment.
Consequently, EPA has concluded that recovery
operations are included in the scope of this rule.
Therefore, unless specifically stated elsewhere,
facilities that recycle and recover off-site waste,
wastewaters and/or used materials are considered
"centralized waste treatment facilities" and are
subject to provisions of this rule. However, if
metals recovery operations are subject to the
secondary metals provisions of 40 CFR 421, the
Nonferrous Metals Manufacturing Point Source
Category, then the provisions of this part do not
apply. These secondary metals subcategories are
Subpart C (Secondary Aluminum Smelting
Subcategory), Subpart F (Secondary Copper
Subcategory), Subpart L (Secondary Silver
Subcate'gory), Subpart M (Secondary Lead
Subcategory), Subpart P (Primary and
Secondary Germanium and Gallium
Subcategory), Subpart Q (Secondary Indium
Subcategory), Subpart R (Secondary Mercury
Subcategory), Subpart T (-Secondary"
Molybdenum and Vanadium Subcategory),
Subpart V (Secondary Nickel Subcategory),
Subpart X_ (Secondary Precious Metals
Subcategory), Subpart Z (Secondary Tantalum
Subcategory), Subpart AA (Secondary Tin
Subcategory), Subpart AB (Primary and
Secondary Titanium Subcategory), Subpart AC
(Secondary Tungsten and Cobalt Subcategory),
and Subpart AD (secondary Uranium
Subcategory).
Silver Recovery Operations front Used
Photographic and X-Ray Materials 3.1.17
At the time of the 1999 proposal, EPA
proposed not to include electrolytic
plating/metallic, replacement silver recovery
operations of used photographic and x-ray
materials within the scope of this rule. The
Agency based its conclusion on the fundamental
difference in technology used to recover silver at
facilities devoted exclusively to treatment of
photographic and x-ray wastes. However, for
off-site wastes that are treated/recovered at these
facilities through any other process and/or waste
generated at these facilities as a result of any
other centralized treatment/recovery process, the
Agency proposed that these wastewaters would
be subject to provisions of this rule.
The Agency received many comments to the
1999 proposal that supported EPA's decision to
3-20
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
not include electrolytic plating/metallic
replacement silver recovery operation of used
photographic and x-ray materials within the
scope of. this rule. However, commenters
additionally noted that while many of these
facilities primarily use electrolytic plating
followed by metallic replacement in silver
recovery operations, there are other processes
that are also utilized. Commenters further noted
that new silver recovery technologies are
emerging and being studied and developed on a
regular basis. As such, commenters asked EPA
to not include silver recovery operations from.
used photographic and x-ray materials regardless
of the method used to recover the silver.
EPA agrees with commenters that facilities
that are devoted exclusively to the centralized
recovery of silver from photographic and x-ray
wastes should not be covered by this rule,
regardless of the type of process used to recover
the silver. As such, facilities that exclusively
perform .centralized silver recovery from used
photographic and x-ray wastes are not subject to
provisions of this-rule. EPA would expect that,
as is the case now-with wastewater discharges
associated with this operation, the control
authority would determine whether to apply the
provisions of 40 CFR 421, Subpart L (the
Secondary Silver Subcategory of the Nonferrous
Metals Manufacturing Regulation) or establish
BPJ, site-specific permit requirements..
There are some facilities, however, which
are engaged in traditional CWT activities and
also engaged in centralized silver recovery from
photographic and x-ray materials. If the
wastewaters from the two operations are
commingled, the commingled silver recovery
wastewater flow would be subject to CWT
limits. Therefore, a facility performing
centralized silver recovery from used
photographic and x-ray materials as well as some
other covered CWT services that commingles
these wastes are subject to provision of the
CWT rule. All of the wastewater discharges are
subject to provisions of this rule. If, however, a
facility is performing both operations and the
wastestreams are not commingled (that is, silver
recovery wastewater is treated in one system and
CWT wastes are treated in a second, separate
system), the permit writer should apply the
provision of 40 CFR 421,, if applicable, or
continue to establish BPJ, site-specific permit
requirements for the discharge associated with
the silver recovery operations and apply the
CWT rule to the wastewaters associated with the
other covered CWT activities.
As a further point of clarification,
wastewater generated as-a-result of- centralized
silver recovery operations are not specifically
, excluded from provisions of this rule. Silver
recovery wastewaters that are treated at CWT
facilities with other covered off-site wastestreams,
are subject to provisions of this rule.
High Temperature Metals Recovery 31.18
EPAis-aware of three facilities in the U.S.
that recover metal using a "high temperature
_metals recovery" process (HTMR). HTMR
facilities recycle metal-bearing materials in a
pyrometallurgicalprocess that employs veryhigh-
temperature furnaces. These facilities do not use
the water-based precipitation/filtration
technologies to recover metals from wastewater
observed at metals subcategory facilities
throughout the CWT industry. At the tune of
the proposal, EPA believed that all HTMR
processes were '"dry" (i.e., did not produce, a
wastewater). Consequently, in the 1999
proposal, EPA proposed not to include facilities
that perform high temperature metals recovery
(HTMR) within the coverage of this rule. EPA
further requested comment on whether. EPA
should promulgate a zero discharge requirement
for facilities that utilize the HTMR process.
Based on comment to the proposal, EPA has
concluded that while most HTMR processes are
dry, one of the three known HTMR facilities
produces a wastewater (scrubber blowdown).
As such, EPA has concluded that a zero
. discharge requirement for HTMR facilities is
inappropriate and has not included it in the final
3-21
-------
Chapters Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
CWT rule. However, upon further examination
of the comments and its database, EPA has
concluded that HTMR facilities that generate a
wastewater should be included within the scope
of the CWT rule. While the HTMR process is
different from other recycling technologies
studied by EPA for this rulemaking, EPA has
concluded that the wastewater produced from
HTMR operations contains many of the CWT
metals subcategory pollutants of concern and
that the concentration of these pollutants falls
solidly within the range of wastewaters in the
CWT metals subcategory. As such, while the
HTMR process may be different from water-
based precipitation technologies, the,resulting
wastewaters are similar (see DCN 33.2.1).
Therefore, it is appropriate for EPA to establish™
limits for HTMR wastewaters using the metals
subcategory technology basis and these limits will
be achievable. EPA has revised all of its analysis
to-reflect the inclusion of these "non-dry"
HTMR facilities within the scope of the CWT
rule. However, if high temperature metals
recovery operations are subject to any of the
secondary metals provisions of 40 CFR 421, the
Nonferrous Metals Manufacturing Point Source
Category, then the provisions of this part do not
apply. See Section 3.1.16 for a list of the
secondary metals subcategories.
Solvent Recycling/Fuel Blending 3.1.19
The solvent recycling industry was studied
by the EPA in the 1980s. EPA published its
findings in the "Preliminary Data Summary for
the Solvent Recycling Industry" (EPA 440/1-
89/102) in September 1989 which describes this
industry and the processes utilized. This
document defines solvent recovery as "the
recycling of spent solvents that are not the
byproduct or waste product of a manufacturing
process or cleaning operation located on the
same site." Spent solvents are generally recycled
in two main operations. Traditional solvent
recovery involves pretreatment of the waste
stream (in some cases) and separation of the
solvent mixtures by specially constructed
distillation columns. In most cases, traditional
solvent recovery is performed at organic
chemical manufacturing facilities. As such,
wastewater discharges resulting from this process
are subject to effluent limitations guidelines and
standards for the organic chemicals industry (40
CFR 414).
EPA is aware that there are, a few facilities
which perform commercial solvent recovery
operations. Some perform solvent recovery of
spent-or contaminated chemicals received from
pharmaceutical and other chemical-
manufacturing companies. Some recycle spent
solvents generated by parts washers and other
cleaning devices operated by automotive shops,
dry cleaners, and other small businesses. These
commercial solvent recovery facilities, because
they are not located at an organic manufacturing-
facility, are not directly subject to effluent
limitations guidelines and standards- for- the
organic chemicals industry (40 CFR 414).
Based on comments to the 1999™ CWT
proposal, EPA considered whether it should
regulate commercial solvent recovery facilities
under the provisions of this rule. EPA has
determined, however, not to include these
commercial solvent recovery operations within
the scope of this rule at this time. Throughout
the development of this rule, EPA has clearly
stated that traditional solvent recovery operations
would not be included within the scope of this
rule. In developing its database to support this .
rule, while EPA did collect limited information .
on these activities, EPA intentionally excluded
known solvent recoverers from its data collection
activities. As such, EPA has only limited data on
solvent recovery activities which are not already
subject to OCPSF. It did not obtain information
to characterize the wastewaters generated at such
i,. operations. Thus, EPA has no basis for
determining whether or not such operations are
sufficiently similar to the organic waste
subcategory so that they may properly be
regulated as organic waste streams. Therefore,
wastewaters resulting from traditional solvent
3-22
-------
Chapter 3 Scope/Applicability OfThe Final Regulation Development Document for the CWT Point.Source Category
recovery activities as defined above are not
subject to this effluent guidelines. For
wastewaters associated with traditional solvent
recovery activities located at organic chemical
manufacturing facilities, permit writers should
use OCPSF to establish discharge requirements.
For commercial traditional solvent recovery
activities (not located at an organic chemical
manufacturing site), permit writers should use
Best Professional Judgement or local limits to
establish site-specific permit requirements.
Fuel blending is the second main operation
which falls under the definition of solvent
recovery. Fuel blending is the process of mixing
wastes for the purpose of regenerating a fuel for
reuse. At the time of the 1995 proposal, fuel
blending operations were excluded from ~the.
CWT rule, since EPA believed the fuel blending
process was "dry" (that is, no wastewaters were
produced). Based^ on comments to the original
proposal and the Notice of Data Availability,
EP Ahas concluded that this is valid and that true
fuel blenders do not generate any process
wastewaters and are, therefore, zero dischargers. ~~
EPA is concerned, however, that the term "fuel
blending" may be loosely applied to any process
where recovered hydrocarbons are combined as
a fuel product. Such operations occur at nearly
all used oil and fuel recovery facilities.
Therefore, "dry" fuel blending operations are
excluded from the CWT rule. In the event that
wastewater is generated at a CWT fuel blending
facility, the discharge of wastewaters associated
with these operations are subject to this rule.
Re-refining
3.1.20
When EPA initially proposed guidelines and
standards for CWT facilities, the regulations
would have limited discharges from used oil
reprocessors/reclaimers, but did not specifically
include or exclude discharges from used oil re-
refiners . During review of information received
on the proposal and assessment of the
information collected, the Agency, at one point,
considered limiting the scope of this regulation to
reprocessors/reclaimers only because it was not
clear whether re-refiners actually generated
wastewater. However, further data gathering
efforts have revealed that re-refiners may
generate wastewater and that the principal
sources of re-refining wastewaters are essentially
the same as for reprocessors/reclaimers.
Consequently, the re-refining wastewater is
included within the scope of this rale.
The used oil reclamation and re-refining
industry was studied by EPA in the 1980s. EPA
published the "Preliminary Data Summary for
the Used Oil Reclamation and Re-Refining
Industry" (EPA 440/1-89/014) in September
1989 which describes this industry and the
processes utilized. This document generally
characterizes the industry in terms of the types
of equipment used to process the used oil. Minor
processors (reclaimers) generally separate water
and solids from the used oil using simple settling
technology, primarily in-line filtering and gravity
settling with or without heat addition. Major
processors (reclaimers) generally use various
combinations of more sophisticated technology
including screen filtration, heated settling,
centrifugation, and light fraction distillation
primarily to remove water. Re-refiners generally
use the most sophisticated systems which
generally include, in addition to the previous
technologies, a vacuum distillation step to
separate the oil into different components.
The final rule applies to the process
wastewater discharges from used oil re-refining
operations. The principal sources of wastewater
include oil-water gravity separation (often
accompanied by chemical/thermal emulsion
breaking) and' dehydration unit operations
(including light distillation and the first stage of
vacuum distillation). EPA has, to date, identified
two re-refining facilities.
Used Oil Filter and Oily Absorbent
Recycling
3.1.21
EPA did not obtain information on used oil
filter or oily-absorbent (oil soaked or
3-23
-------
Chapters Scope/Applicabflity Of The Final Regulation Development Document for the CWT Point Source Category
contaminated disposable rags, paper, or pads) •
recycling through the Waste Treatment Industry
Questionnaire. However, in response to the
September 1996 Notice of Data Availability and
the 1999 proposal, EPA received comments
from facilities which recycle used oil filters and
oily absorbents. In addition, EPA also visited
several used oil reprocessors that recycle used oil
filters or oily absorbents as part of their
operations.
Used oil filter and oily absorbent recycling
processes range from simple crushing and
draining of entrained oil to more involved
processes where filters or absorbent materials are
shredded and the metal and filter material are
separated. Generally, the resulting used oil is
recycled, the separated metal product is sold to
a smelter, and the separated filter material is sold
as a solid fuel. Based on information collected•—
during EPA's site visits and comments to the
1999 proposal, wastewater may be generated
during all phases of the recycling activity
including collection activities, plant maintenance,
and air pollution control. EPA notes, however,
that based on its observations, many of these
activities are "dry" and do not produce
associated wastewaters. In fact, at the time of
the 1999 proposal, EPA believed these activities
were largely "dry" and requested comment on
whether EPA should promulgate azero discharge
requirement for facilities performing used oil .
filter recovery.
As detailed above, based on comment to the
proposal, EPA no longer believes that all used oil
filter and absorbent recycling activities are dry.
As such, EPA has concluded that a zero
discharge requirement for these activities is
inappropriate and has not included it in the final
CWT rule. However, upon further examination
of the comments and its database, EPA has
concluded that used oil filter and absorbent
recovery facilities which generate a wastewater
should be included within the scope of the CWT,
rule. While EPA does not have data in its
database on the characteristics .of these
wastewaters, these wastewaters are often
combined with other covered CWT wastewaters
for treatment. Further, since the material being
recovered is primarily used oil, EPA has every
reason to believe that any resulting wastewaters
will be similar (in terms of constituents and
concentration) to wastewaters generated from
used oil recovery. As such, EPA has concluded
that these operations should be regulated as are
other centralized used oil recovery activities.
Where information is available to EPA on these
operations, EPA has revised its analysis to reflect
the inclusion of these "non-dry" used-oiL filter
and absorbent facilities within the scope of the
CWT rule.
Grease Trap/Interceptor Wastes
3.1.22
EPA received comments on coverage of
grease,-sand, and oil-interceptor wastes by the
CWT rule during the comment period for the
original proposal, the 1996 Notice of Data
Availability, and the 1999 proposal. Some of
these wastes are from non-industrial sources and
some are from industrial sources. Some are
treated at central locations designed to
exclusively treat grease trap/interceptor wastes
and some of these wastes are treated at
traditional CWT facilities with traditional CWT
wastes. Examples of the types of'customers
which generate,. these grease trap/interceptor
wastes include, but are not limited to, the
following: auto and truck maintenance and repair
shops, auto body and parts shops, car washes,
gas stations, commercial bottling facilities, food
and produce distribution shops, restaurants, and
tire shops.
Throughout the development of this rule,
EPA has directed its efforts to CWT operations
that treat and/or recover off-site industrial
wastes. -As such, grease/trap interceptor wastes
would not fall within the scope of this rule.
Grease trap/interceptor wastes are defined as
animal or vegetable fats/oils from grease traps or
interceptors generated by facilities engaged in
food service activities. Such facilities include,
but are not limited to, restaurants, cafeterias,
3-24
-------
Chapter 3 Scope/'Applicability OfThe Final Regulation Development Document for the CWT Point Source Category
caterers, commercial bottling facilities, and food
and distribution shops. Excluded grease
trap/interceptor vrastes should not contain any
hazardous chemicals or materials that would
prevent the fats/oils from being recovered and
recycled.
Wastewater discharges from the centralized
treatment of wastes produced from oil
interceptors, however, which are designed to
collect.,petroleum-based oils, sand,, etc. from
industrial type processes, are a different case and
EPA has determined that this wastewater is
properly subject.to this rule. Examples of
facilities that produce oil interceptor waste
include, but are not limited to, auto and truck
maintenance and repair shops; auto body and
parts shops; car washes; and gas stations. EPA
collected data on the types and concentrations of
pollutants in oil interceptor wastes through
comments and EPA sampling. The data show,
that like other CWT wastes, the concentration of
pollutants can vary greatly from one wastestream
to another. EPA's sampling data show that these
materials can be very similar in nature and
concentration to other wastes covered by this
rule. Consequently, EPA has determined these
wastes should be included within the scope of
this rule.
food processors/manufacturers.
Sanitary Wastes and/or Chemical
Toilet Wastes
3.1.24
Food Processing Wastes
3.1.23
During development of this rule, EPA did
not collect information from facilities engaged in
centralized waste treatment of food processing
wastes. As detailed in Section 3.1.22, EPA
envisioned that this rule would.be limited to the
treatment and/or recovery of off-site industrial
wastes. While food processing may be an
"industrial" activity, these wastes do not contain
heavy metals, concentrated organics, or
petroleum based oils. In terms of contaminants
of concern, these wastes are similar to those
generated by cafeterias, restaurants, etc.
Consequently, the final guidelines will not apply
to animal and vegetable fats/oils wastewaters at
CWT facilities, specifically those generated by
The CWT rule would regulate facilities
which treat, or recover materials from, off-site
industrial wastes and wastewaters. Sanitary
wastes such as chemical toilet wastes and
septage are not covered by the provisions of the
CWT rule. EPA expects that permit writers
would develop BPJ limitations or local limits to
establish -site-specific- permit- requirements for
any commercial sanitary waste treatment facility.
Similarly, sanitary wastes or chemical-toilet-
wastes received from off-site and treated at an
industrial facility or a CWT facility are not
subject to the provisions of the CWT rule. If
these wastes are mixed with industrial wastes,
EPA would expect that, as is the case now with
ancillary sanitary waste flows mixed for
treatment at facilities subject to national effluent
guidelines and standards, the permit writer would
establish BPJ, site-specific permit requirements.
Treatability, Research and
Development, and Analytical Studies 3.1.25
During the initial stages of development of
this rule, EPA did not envision regulation of
facilities which accept off-site wastes for
treatability studies, research and development, or
chemical or physical analysis. As such, EPA did
not attempt to collect information on these
activities. However, EPA received comment to
its proposals asking that EPA clarify its coverage
of these activities by this rule.
EPA has very little information on these
activities. Based on comments, these activities,
arguably, would fall within the definition of
Centralized Waste Treatment since they accept
off-site wastes. The purpose of these activities
is not treatment or recovery, but rather the
evaluation of different treatment techniques.
Consequently, . EPA has concluded that
treatability, research and development or
analytical activities should not be subject to
3-25
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
provisions of the CWT rule.
Permit writers and local authorities should
use their Best Professional Judgment (BPJ) and
local limits authority to establish limitations and
standards for these wastestreams. Under EPA's
regulations, permit writers or local control
authorities must include technology-based limits
either for any toxic pollutant which is or may be
discharged at a level greater than the level which
can be achieved by treatment requirements
appropriate to the permittee or for any pollutant
which may pass through or interfere with-POTW
operations. (See 40 CFR §§ 122.44(e), 125.3.)
See also 40.CFR § 403.5. EPA"would expect
that, in some cases, wastewater associated with
these activities might look very much like the
wastestreams regulated under this rule. In those
circumstances, permit writers (and local control
authorities) may want to consider the technical
development document developed for the CWT
guideUnewhenthepermitwriterestabh'shescase- ,„
by-case limitations under NPDES regulations at
40 CFR § 125.3 or the" control" authority . • .- --
establishes local limits under . the General
Pretreatment Regulations at 40 CFR § 403.5.
EPA notes that if a CWT facility accepts
off-site wastes for treatability, research and
development, or analytical activities, and
commingles any resulting wastewaters with other
covered wastewaters prior to discharge, these .
wastewaters would be subject to provisions of
this rule.
3-26
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
Table 3-3. Examples of Regulated and Non-Regulated CWT Operations
Centralized Waste Treatment
Activity
Those performed at federally
owned facilities
POTWs
Thermal drying of POTW
biosolids
Sanitary wastes or toilet wastes
Food processing wastes
Manufacturing facilities
• Regulated by this rule
All federally owned CWT
operations
None
None
None
None
Those that accept off-site wastes
Not Regulated by this rule
None
All
All
All
AU
All others
For Further
Info See:
Section 3.1.4
Section 3.1.6
Section 3.1.7
Section 3.1.24
Section 3. 1.23
Section 3.1.1
Product stewardship"
Petroleum refineries (SIC Code
2911) and petroleum distribution
terminals (SIC Code 4612,4613,
5171,5172)
Pulp and paper off-site landfill
leachates
Pipeline materials
Recycle/recovery activities
for treatment and/or recovery that
are not generated in a
manufacturing process subject to
the same limitations/standards as
on-site generated waste or that the
permit writer determines are not
similar to, and compatible with, fee
on-site-waste
Those that accept waste materials
from use of their products that are
not similar to, and compatible with,
treatmentof-waste-generated,on- _.
site
For off-site materials other than .
those listed in the next column, see
discussion for manufacturing
facilities.
None
Materials received via pipeline
from waste consolidators or
commingled with other covered
CWT wastewaters
All unless specifically excluded
elsewhere
Those that accept back then-
unused products, shipping and
storage containers with product
residues, and off-specification
products
Those that receive and manage
off-site petroleum-containing
materials generated by petroleum
exploration, production,
transportation, refining and
marketing activities
Those that receive off-site
leachates which are from
dedicated pulp and paper landfills
All other piped materials"
Section 3.1.3
Section 3.1.1~
Section 3.1.1
Section 3.1.2
Section 3.1.16
Traditional solvent recovery
Fuel blenders
Scrap metals recyclers
Silver recovery
Used oil filters
. None
Those that generate a wastewater
None
Only included where wastewater
generated from these activities is
commingled with other covered
waters
Those that generate a wastewater
AU
"Dry" operations
AH
All others
"Dry" operations
Section 3.
Section 3.
Section 3.
Section 3.
Section 3.
.1.19
.1.19
,1.12
,1.17
.1.21
3-27
-------
Chapter 3 Scope/Applicability Of The Final Regulation Development Document for the CWT Point Source Category
Centralized Waste Treatment
Activity
HTMR
Used glycol recovery
Re-refining
Solids, soils, and sludges
Stabilization/Solidification
Transfer stations and recycling
Regulated by this rule
Those that generate a wastewater
All
All
Those activities which generate a
wastewater unless specifically
excluded elsewhere
Those that generate a wastewater
None
Not Regulated by this rule
"Dry" operations
None
None
"Dry" operations
"Dry" operations
AH-
For Further
Info See:
Section 3.1.18
Section 3.1. 16
Section 3.1.20
Section 3. 1.11
Section 3. 1.14
Section 3.1.13
centers
Incinerators
Transportation and/or
transportation equipment
cleaning
Landfills
Grease trap/interceptor wastes
Marine generated wastes
Waste, wastewater or used
material re-use
Treatability, research and
development, or analytical
activities
All others
Only included where wastewater
generated from these activities is
commingled with other covered
waters
Only included where wastewater
generated from these activities is
commingled with other covered
waters
Those which contain petroleum
based oils -•
Only included where wastewater
generated from these activities is
commingled with other covered
waters
Those activities not listed in the
next column or excluded
elsewhere
Only included where wastewater
generated from these activities is
commingled with other covered
waters
Facilities which accept off-site Section 3.1.10
wastes exclusively for
incineration activities
All others- Section 3.1.8
All others Section 3.1.9
Those which contain animal or Section 3.1.22
vegetable fats/oils
All others , Section 3.1.5
Not covered if the wastewater is Section 3.1.1-5
accepted for use in place of
potable water or if materials are
accepted in place of virgin
treatment chemicals.
All others Section 3.1,25
3-28
-------
Chapter
.."• .'•• . 4
DESCRIPTION OF THE INDUSTRY
The adoption of the increased pollution
control measures required by CWA and
RCRA requirements had a number of ancillary
effects, one of which has been the formation and
development of a waste treatment industry.
Several factors have contributed to the growth of
this industry. These include: (a) the manner in
which manufacturing facilities have elected to
comply with CWA and RCRA requirements; (b)
EPA's distinction 'for regulatory purposes
between on- and off-site treatment of wastewater
in the CWA guidelines program; and (c) the
RCRA 1992 used oil management requirements.
A manufacturing facility's options for
managing wastes include on-site treatment or
sending them off-site. Because a large number of
operations (both large and small) have chosen to
send their wastes off-site, specialized facilities
have developed whose sole commercial
operation is the handling of wastewater treatment
residuals and industrial process by-products.
Many promulgated effluent guidelines also
encouraged the creation of these central
treatment centers. Inconsistent treatment of
facilities which send their waste off-site to CWT
facilities in the guidelines program has resulted in
wastewater that is treated off-site being subject
to inconsistent standards. EPA acknowledges
that this may have created a loop-hole for
dischargers to avoid treating their wastewater to
standards comparable to categorical standards
before discharge. Additionally, RCRA
regulations, such as the 1992 used oil
management requirements (40 CFR 279)
significantly influenced the size and service
provided by this industry.
INDUSTRY SIZE
4.1
Based upon responses to EPA's data
gathering efforts, the Agency now estimates that
there are approximately 223 centralized waste
treatment facilities in 38 States. As shown below
in Table 4-1, the major concentration of
centralized waste treatment facilities is in EPA
Regions 4, 5, and 6, due to the proximity of the
industries generating the wastes undergoing
treatment. Changes in the estimate of the total
number of CWT facilities since the 1999
proposal reflect facilities that were included~or "
excluded because of scope changes or
clarification. EPA is aware that CWT facilities
have entered—or- left. the. centralized,,, waste^
treatment market. This is expected in a service
industry. Even so, EPA is comfortable -that its
estimate of facilities is reasonable and has not
adjusted.it, other than to account for scope
changes and clarifications.
As detailed in Chapter 2, while .EPA
estimates there are 223 CWT facilities, EPA only
has facility-specific information for 163 of these
facilities. In preparing the final limitations and
standards, EPA conducted its analysis with the
known facility specific information and then used
the actual data to develop additional information
to represent the entire population. Unless
otherwise stated, information presented in this
document represents the entire population.
Table 4-1 provides an example where data is
only presented for the facilities for which EPA
has facility-specific information.
GENERAL DESCRIPTION
4.2
Centralized waste treatment facilities do not
fall into a single description and are as varied as
4-1
-------
Chapter 4 Description of the Industry Development Document for the CWT Point Source Category
the wastes they accept. Some treat wastes from
a few generating facilities while others treat
wastes from hundreds of generators. Some treat
only certain types of waste while others accept
many wastes. Some treat non-hazardous wastes
exclusively while others treat hazardous and non-
hazardous wastes. Some primarily treat
concentrated wastes while others primarily treat
more dilute wastes. For some, their primary
business is the treatment of other company's
wastes while, for others, centralized waste
treatment is ancillary to their main business.
At the time of the original proposal, a few of
the facilities in the industry database solely
accepted wastes classified as non-hazardous'
under RCRA. The remaining facilities accepted
either hazardous wastes only or a combination of
hazardous and non-hazardous wastes. Now,
however, the vast majority of the oils facilities
accept non-hazardous materials only. As such,
EPA believes the market for centralized waste
treatment of non-hazardous materials has
increased during the 1990s.
EPA has detailed waste receipt information
for the facilities in the 1991 Waste Treatment
Industry Questionnaire data base. Of the 85
in-scope facilities from the Questionnaire data
base, 71 of them are RCRA-permitted treatment,
storage, and disposal facilities (TSDFs). As
such, most of these facilities were able to use
information reported in the 1989 Biennial
Hazardous Waste Report to classify the waste
accepted for treatment by the appropriate Waste
Form and RCRA codes. The Waste Form and
RCRA codes reported by the questionnaire
respondents are listed in Table 4-2 and Table 4-
3, respectively. (Table 14-2 in Chapter 14 lists
these Waste Form and RCRA codes along with
their associated property and/or pollutants).
Some questionnaire respondents, especially those
that treat non-hazardous waste, did not report
the Waste Form Code information due to the
variety and complexity of their operations.
EPA does not have detailed RCRA code and
' waste code information on waste receipts for the
facilities identified after the original proposal. It
is known that the majority of these facilities
accept non-hazardous wastes. Of the 78
post-proposal oily waste facilities for which EPA
has specific data, only 20 are RCRA-perrnitted
TSDFs.
Centralized waste treatment facilities service
a variety of customers. A CWT generally
receives a variety of wastes daily from dozens of
customers. Some customers routinely generate
a particular wastestream and are unable to
provide effective on-site treatment of that
particular wastestream. Some customers utilize
CWT facilities because they generate
wastestreams only sporadically (for example tank
removal, tank cleaning and remediation wastes)
and are unable to economically provide effective
on-site treatment of these wastes. Others, many
which are small businesses, utilize CWT facilities
as their primary source of wastewater treatment.
4-2
-------
Chapter 4 Description of the Industry Development Document for the CWT Point Source Category
Table 4-1. Geographic Distribution of CWT Facilities (163 Facilities)
Region
.1
2
3
4
''
State
Connecticut
Maine
Massachusetts
Rhode Island
New Jersey
New York
Delaware
Maryland
Pennsylvania
Virginia
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
#of
CWTs
5
1
1
1
7
4
1
. 2
7
6
3
9
3
3
1
3
2
8
% of Region
State
CWTs
4
.9
5
Illinois
Indiana
Michigan
#of
% of
CWTs CWTs
Minnesota
6.8
Ohio
Wisconsin
9.8
6
7
19,6
8
9
10
Louisiana
Oklahoma
Texas
Iowa
Kansas
Missouri
Colorado
Montana
Arizona .
California
Hawaii
Nevada
Oregon
.
,
Washington-
Table 4-2
. Waste Form Codes Reported by CWT Facilities in
1989'
7
5
11
2
13
-4
5
2
14
1
2
1
2
1
1
13
1
1
2
8 „_..
25.8
12.9
2.5
1.8
9.8
.._ ~
6.1
Waste Form Codes
B001
B101
B102
B103
B104
BIOS
B106 B112
B107 B113
BIOS B114
B109 B115
B110 B116
Bill B117
'Table 14-2 in Chapter 14
Table 4-3
B119
B201
B202
B203
B204
B205
B206
B207
B208
B209
B210
B211
B219
B305
B306
B307
B308
B309
B310
B312
B313
B315
B316
B319
B501
B502
B504
B505
B506
B507
B508
B510
B511
B513
B515
B518
B519
B601
B603
B604
B605
B607
B608
B609
lists Waste Form Codes and their associated properties.
. RCRA Codes Reported by Facilities in 19892
RCRA Codes
D001
D002
D003
D004
D005
D006
D007
D008
D009
D010
D011
DO 12 F009
D017 F010
D035 F011
F001 F012
F002 F019
F003 F039
F004 K001
F005 K011.
F006 KOI 3
F007 K014
F008 KOI 5
K016
K031
K035
K044
K045
K048
K049
K050
K051
K052
K061
K063
K064
K086
K093
K094
K098
K103
K104
P011
P012
P013
P020
P022
P028 .
P029
P030
P040
P044
P048
P050
P063
P064
P069
P071
P074
P078
P087
P089
P098
P104
P106
P121
P123
U002
U003
U008
U009
U012
U013
U019
U020
U031
U044
U045
U052
U054
U057
U069
U080
U092
U098
U105
U106
U107
U113
U118
U122
U125
.U134
U135
U139
U140
U150
U151
U154
U159
U161
U162
U188
U190
U205
U210
U213
U220
U226
U228
U239
Table 14-2 in Chapter 14 lists Waste Form Codes and their associated properties.
4-3
-------
Chapter4 Description of the Industry Development Document for the CWT Point Source Category
Before a CWT accepts a waste for
treatment, the waste generally undergoes
rigorous screening for compatibility with other
wastes being treated at the facility. Waste
generators initially furnish the treatment facility
with a sample of the waste stream to be treated.
The sample is analyzed to characterize the level
of pollutants in the sample and bench-scale
treatabiliry tests are performed to determine what
treatment is necessary to treat the waste stream.
After all analyses and tests are performed, the
treatment facility determines the cost for treating
the waste stream. If the waste generator accepts
the cost of treatment, shipments of the waste
stream to the' treatment facility will begin.
Generally, for each truck load of waste received
for treatment, the treatment facility collects a
sample from ,the shipment and analyzes the
sample to determine if it is similar to the initial"
sample tested.- If the sample is similar, the
shipment of waste will be treated. If the sample
is not similar but falls within an allowable range
as determined by the treatment facility, the
treatment facility will reevaluate the estimated
cost of treatment for the shipment. Then, the
waste generator decides if the waste will remain
at the treatment facility for treatment. If the
sample is not similar and does not fall within an
allowable range, the treatment facility will decline
the shipment for treatment.
Treatment facilities and waste generators
complete extensive paperwork during the waste
acceptance process. Most of the paperwork is
required by Federal, State, and local regulations.
The amount of paperwork necessary for
accepting a waste stream emphasizes the
difficulty of operating centralized waste
treatment facilities.
WATER USE AND SOURCES OF WASTEWATER 4.3
Approximately 2.0 billion gallons of
wastewater are generated annually at CWT
facilities. It is difficult to determine the quantity
of wastes attributable to different sources
because facilities generally mix the wastewater
prior to treatment. EPA has, as a general matter,
however, identified the sources described below
as contributing to wastewater discharges at CWT
operations that would be subject to the proposed
effluent limitations and standards.
Waste Receipts. Most off-site waste received by
CWT facilities is aqueous. These aqueous off-
site waste receipts comprise the largest portion of
the wastewater treated at CWT" facilities.
Typical waste receipts for the metals subcategory
include but are not limited to the following:
spent electroplating baths and sludges, spent
anodizing solutions, metal finishing rinse water
and sludges, and chromate and cyanide wastes.
Types of waste accepted for treatment in the oils
subcategory include, but are not limited to, the
following: lubricants, used petroleum products,
used oils, oil spill clean-up, bilge water, tank
clean out, off-specification fuels, and
underground, storage tank,,remediation, waste..
Types of wastes accepted for treatment in the
organic? subcategory include, but are not limited
to the following: landfill leachate, groundwater
clean-up, solvent-bearing waste, off-specification
organic products, still bottoms, used antifreeze,
and wastewater from chemical product
operations and paint washes.
Solubilization- Water. A portion of the off-site
waste receipts is in a solid form. Water may be
added to the waste to render it treatable.
Used Oil Emulsion-Breaking Wastewater., The'
wastewater generated as a result of the emulsion
breaking, or gravity separation process used
during the processing of used oil constitutes a
major portion of the wastewater treated at oils
facilities. EPA estimates that, at a typical oils
facility, half of the wastewater treated is a result
of oil/water separation processes.
Tanker Truck/Drum/Roll-Off Box Washes.
Water is used to clean the equipment used for
4-4
-------
Chapter 4 Description of the Industry Development Document for the CWT Point Source Category
transporting wastes. The amount of waste water
generated was difficult to assess because the
wash water is normally added to the wastes or
used as solubilization water.
Equipment Washes. Water is used to clean
waste treatment equipment during unit shut
downs or in between batches of waste.
Air Pollution Control Scrubber Blow-Down.
Water or acidic or basic solution is used in air
emission control scrubbers to control fumes from
treatment tanks, storage tanks, and other
treatment equipment.
Laboratory-Derived Wastewater. Water is used
in on-site laboratories which characterize.
incoming waste streams and monitor on-site
treatment performance.
Industrial-- Waste.....Combustor* or. Landfill'
Wastewater from On-SiteLandfills. Wastewater
is generated at some CWT facilities as a result of
on-site landfilling or incineration activities.
Contaminated Stormwater. This is stonnwater
which comes in direct contact with the waste or
waste handling and treatment areas. If this
contaminated CWT stonnwater is introduced to
the treatment system, its discharge is subject to
the promulgated limitations. The Agency is not
regulating under the CWT guideline non-contact
Stormwater or contaminated stonnwater not
introduced to the treatment system. Such flows
may, in certain circumstances, require permitting
under EPA's existing permitting program under
40 CFR 122.26(b)(14) and 40 CFR403. CWT
facilities that introduce non-contaminated
Stormwater into their treatment system will need
to identify this as a source of non-CWT
wastewater in their treatment system in their
permit applications. This is necessary so that the
permit writer may take account of these flows hi
developing permit limitations that reflect actual
treatment.
VOLUME BY TYPE OF DISCHARGE
4.4
In general, three basic options are available
for disposal of wastewater treatment effluent:
direct, indirect, and zero (of alternative)
discharge. Some facilities utilize more than one
option (for example, a portion of their
wastewater is discharged to a surface water and
a portion is evaporated). Direct dischargers are
facilities which discharge effluent directly to a
surface -water: •Indirect dischargers are facilities -
which discharge effluent to a publicly-owned
treatment works (POTW). Zero or alternative
dischargers do not generate a wastewater or do
not discharge to a-surface water or POTW. The
types of zero or alternative discharge identified in
the- GWT industry- are- underground injection
control (UIC), off-site transfer for further
treatment or-disposal, evaporation, and" no
wastewater generation. Table 4-4 _lists the
number of facilities utilizing each discharge
option.
Average facility wastewater .discharge
information is presented in Table 4-5 for the
indirect and direct discharge options. The
proposed effluent limitations guidelines and
standards for the CWT industry do not apply to
facilities with a zero or alternative discharge.
4-5
-------
Chapter 4 Description of the Industry Development Document for the CWT Point Source Category
Table 4-4. Facility Discharge Options
Discharge Option
Direct
Indirect
Indirect and off-site transfer
Indirect and no wastewater generation
UIC
Off-site transfer
Evaporation
Off-site transfer and evaporation
Zero (not specified)
Total
No. of Facilities with
Soecific Data
12
105
1
2
7
14
3
1
18
163
No. ofScaled-Up
Facilities
14
148
1
2
9
22 .
5
1
21
223
Table 4-5. Quantity of Wastewater Discharged (223 Facilities)
Discharge
Option
Direct
Indirect
Quantity, of Wastewater Discharged (Million gallons/year) -
Total
535
1,547
Average
• 38.2
10.2
Minimum
0.078
0.0013
Maximum
225
177
OFF-SITE TREATMENT INCENTIVES AND
COMPARABLE TREATMENT
4.5
As noted before, the adoption, of the
increased pollution control measures required by
the CWA and RCRA regulation was a significant
factor in the formation and development of the
centralized waste treatment industry; Major
contributors to the growth of this industry
include EPA decisions about how to structure its
CWA effluent limitations guidelines program as
well as the manner in which manufacturing
facilities have elected to comply with CWA and
RCRA requirements.
The CWA requires the establishment of
limitations and standards for categories of point
sources that discharge into.surface waters or
introduce pollutants into publicly owned
treatment works. At present, facilities that do
not discharge wastewater (or introduce pollutants
to POTWs) may not be subject to the
requirements of 40 CFR Subchapter N Parts
400 to 471. Such facilities include
manufacturing or service facilities that generate
no process wastewater, facilities that recycle all
contaminated waters, and facilities that use some
kind of alternative disposal technology or
practice (for example, deep well injection,
incineration, evaporation, surface impoundment,
land application, and transfer to a centralized
waste treatment facility).
Thus, for example, in implementing CWA
and RCRA requirements in the electroplating
industry, many facilities made process
modifications to conserve and recycle process
wastewater, to extend the lives of plating baths,
and to minimize the generation of wastewater
treatment sludges. As the volumes of
wastewater were reduced, it became
economically attractive to transfer electroplating
metal-bearing wastewater to off-site centralized
4-6
-------
Chapter 4 Description of the Industry Development Document for the CWT Point Source Category
waste treatment facilities for treatment or metals
recovery rather than to invest in on-site
treatment systems. In the case of the organic
chemicals, plastics, and synthetic fibers (OCPSF)
industry, many facilities transferred selected
process residuals and small volumes of process
wastewater to off-site centralized waste
treatment facilities. When estimating the
engineering costs for the OCPSF industry to
comply with the OCPSF regulation, the Agency
assumed, based on economies of scale, in the
case of facilities with wastewater flows less than
500 gallons per day, such plants would use off-
site rather than on-site wastewater treatment.
xThe Agency believes that any wastes
transferred to an off-site CWT, facility should be
treated to at least the same level as required for,,
the same wastes if ~ treated on-site at the
manufacturing facility. In the absence of
appropriate- regulations -to ensure- at-least -
comparable or adequate treatment, the CWT
facility may inadvertently offer an economic
incentive for increasing the pollutant load to the
environment. One of the Agency's primary
concerns is the potential for a discharger to
reduce its wastewater pollutant concentrations
through dilution rather than through appropriate
treatment. The final standard is designed to
ensure that wastes transferred to centralized
waste treatment facilities would be treated to the
same levels as on-site treatment or to adequate
levels.
This is illustrated by. the information the
Agency obtained during the data gathering
activities for the 1995 proposal. EPA visited 27
centralized waste treatment facilities in an effort
to identify well-designed, well-operated candidate
treatment systems for sampling. Two of the
principal criteria for selecting plants for sampling
were based on whether the plant applied waste
management practices that, increased the
effectiveness of the treatment system and
whether the treatment system was .effective in
removing pollutants. This, effort was
complicated by the level of dilution and co-
dilution of one type of waste with another. For
example, many facilities treated metal-bearing
and oily wastes in the same treatment system
and many facilities mixed non-CWT wastewater
with CWT wastewater. Mixing metal-bearing
with no^metal-bearing oily wastewater and
mixing CWT with non-CWT wastewater
provides a dilution effect which generally reduces
the efficiency of the wastewater treatment
system. Of the 27 plants visited; many were not
sampled because of the problems of assessing
CWT treatment efficiencies due to dilution^of'
one type of wastewater with another.
The final limitations would ensure, to the
extent possible, that metal-bearing wastes are
treated with metals control technology, that oily
wastes are treated wiuT'oils^ control technology,
and that organic wastes are treated with organics
control technology.
In developing the final guidelines, EPA noted
a wide variation in the size of CWT facilities and
the level of treatment provided by these facilities.
Often, pollutant removals were poor, and, in
some cases, significantly lower than would have
been required had the wastewaters been treated
at the site where generated. In particular, EPA's
survey indicated that some facilities were
employing only the most basic pollution control
equipment and, as a result, achieved low
pollutant removals relative to that easily obtained
through the use of other, readily available
pollutant control technology. Further, EPA had
difficulty in identifying more than a handful of
facilities throughout the CWT industry that were
achieving optimal removals.
4-7
-------
-------
Chapter
5
INDUSTRY SUBCATEGORIZATION
METHODOLOGY AND FACTORS
CONSIDERED As THE BASIS
FOR SUBCATEGORIZATION
5.1
The CWA requires EPA, in developing
effluent limitations guidelines and
pretreatment standards that represent the best
available technology economically achievable for
a particular industry category, to consider a
number of different factors. Among others,
these include the age of the equipment and
facilities in the category, manufacturing
processes employed, types of treatment
technology to reduce effluent discharges, and the
cost of effluent reductions (Section 304(b)(2)(b)_
of the CWA, 33 U.S.C. § 1314(b)(2)(B)). The
statute also authorizes EPA to take into account
other factors that the Agency deems appropriate.
One way in which the Agency has taken
some of these factors into account is by breaking
down categories of industries into separate
classes of similar characteristics. This recognizes
-'the major differences among companies within
an industry that may reflect, for example,
different manufacturing processes or other
factors. One result of subdividing an industry by
subcategories is to safeguard against overzealous
regulatory standards, increase the confidence that
the regulations are practicable, and diminish the
need to address variations between facilities
through a variance process ( Weyerhaeuser Co. y.
Costle, 590 F.2d 1011, 1053 (D.C. Cir. 1978)).
The centralized waste treatment industry, as
previously explained, is not typical of many of
the industries regulated under the CWA because
it does not produce a product. Therefore, EPA
considered certain additional factors that
specifically apply to centralized waste treatment
operations in its evaluation of how to establish
appropriate limitations and standards and
whether further subcategorization was
warranted. Additionally, EPA did not consider
certain other factors typically appropriate when
subcategorizing manufacturing facilities as
relevant when evaluating this industry. The
factors EPA considered in the subcategorization
of the centralized waste treatment industry
include the following:
• Facility age;
• Facility size;
• Facility location;
• Non-water quality impacts;
• Treatment technologies and costs;
• RCRA classification;
• Type of wastes received for treatment; and
• Nature of wastewater generated.
EPA concluded that certain of these factors
did not support further subcategorization of this
industry. The Agency concluded that the age of
a facility is not a basis for subcategorization, as
many older facilities have unilaterally improved
or modified their treatment processes over time.
EPA also decided that facility size was not an
appropriate basis for subcategorizing. EPA
identified three parameters as relative measures
of facility size: number of employees, amount of
waste receipts accepted, and wastewater flow.
EPA found that CWTs of varying sizes generate
similar wastewaters and use similar treatment
technologies. Furthermore,, wastes can be
treated to the same level regardless of the facility
size. Likewise, facility location is not a good
basis for subcategorization. Based on the data
collected, no consistent differences in wastewater
treatment technologies or performance exist
5-1
-------
Chapter 5 Industry Subcategorization
Development Document for the CWT Point Source Category
because of geographical location. EPA
recognizes, however, that geographic location
may have an effect on the market for CWT
services, the cost charged for these services, and
the value of recovered product. These issues are
addressed in the Economic Assessment
Document
While non-water quality characteristics (solid
waste and air emission effects) are of concern to
EPA, these characteristics did not constitute a
basis for subcategorization. Environmental
impacts from solid waste disposal and from the
transport of potentially hazardous wastewater are
a result of individual facility practices and EPA
'could not identify any common characteristics
particular to a given segment of the industry.
EPA did not use treatment costs as a basis for
subcategorization because costs will vary and are
dependent on the following waste stream
variables: flow rates, wastewater quality, and
pollutant loadings. Finally, EPA concluded that
the RCRA classification was not an appropriate
basis for subcategorization, as the type of waste'
accepted for treatment appears to be more
important than whether the waste was classified
as hazardous or non-hazardous.
EPA identified only one factor of primary
significance for subcategorizing the centralized
waste treatment industry — the type of waste
received for treatment or recovery. This factor
encompasses many of the other
subcategorization factors. The type of treatment
processes used, nature of wastewater generated,
solids generated, and potential air emissions
directly correlate to the type of wastes received
for treatment or recovery. For the final
standards, EPA reviewed its earlier
subcategorization approach and decided to retain
it It is still EPA's conclusion that the type of
waste received for treatment or recovery is the
only appropriate basis for subcategorization of
this industry.
SUBCATEGORIES
5.2
Based on the type of wastes accepted for
treatment or recovery, EPA has determined that
there are four subcategories appropriate for the
centralized waste treatment industry:
• Subcategory A: Facilities that treat or recover
metal from metal-bearing waste, wastewater,
or used material received from off-site
(Metals Subcategory);.
• Subcategory B: Facilities that treat or
recover oil from oily waste, wastewater, or
used material received from off-site (Oils
Subcategory); and
• Subcategory C: Facilities that treat or recover
organics from other organic waste,
wastewater, or used material received from
off-site (Organics Subcategory); and
• Subcategory D: Facilities that treat or recover
some combination of metal-bearing, oily, or
organic waste, wastewater, or used materials
..received from off-site (Multiple Waste
Stream Subcategory).
SUBCATEGORY DESCRIPTIONS
Metals Subcategory
53
5.3.1
The facilities in this subcategory are those
treating metal-bearing waste received from
off-site and/or recover metals from off-site
metal-bearing wastes. Currently, EPA has
identified 59 facilities in this subcategory.
Fifty-two facilities treat metal-bearing waste
exclusively, while another six facilities recover
metals from the wastes for sale in commerce or
for return to industrial processes. One facility
provides metal-bearing waste treatment in
addition to conducting a metals recovery
operation. The vast majority of these facilities
have RCRA permits to accept hazardous waste.
Types of wastes accepted for treatment include
spent electroplating baths and sludges, spent
anodizing solutions, metal finishing rinse water
• and sludge, and chromate wastes.
5-2
-------
Chapter 5 Industry Subcategorization
Development Document for the CWT Point Source Category
The typical treatment process used for
metal-bearing waste is precipitation with lime or
caustic followed by filtration. The sludge
generated is then landfilled in a RCRA Subtitle C
or D landfill depending on its content. Most
facilities that recover metals do not generate a
sludge that requires disposal. Instead, the
sludges are sold for metal content. In addition to
treating metal bearing wastestreams, many
facilities in this subcategory also treat cyanide
wastestreams, many of which are
highly-concentrated and complex. Because the
presence of cyanide may interfere with the
chemical precipitation process, these facilities
generally 'pfetreat to remove cyanide and then
commingle the prerreated cyanide wastewaters
with the other metal-containing wastewaters.
EPA estimates that nineteen of the metals
facilities-also treat cyanide wastestreams.
Oils Subcategory "
5.3.2
The facilities in this subcategory are those
that treat oily waste, wastewater, or used
material received from off-site and/or recover oil
from off-site oily materials. Currently, EPA
estimates that there are 164 facilities in this
subcategory. Among the types of waste
accepted for treatment are lubricants, used
petroleum products, used oils, oil spill clean-up,
bilge water, tank clean-out, off-specification
fuels, and underground storage tank remediation
waste. Many facilities in this subcategory only
provide treatment for oily wastewaters while
others pretreat the oily wastes for contaminants
such as water and then blend the resulting oil
residual to form a product, usually fuel. Most
facilities perform both types of operations. EPA
estimates that 53 of these facilities only treat oily
wastewaters and 36 facilities primarily recover oil
for re-use. The remaining 75 facilities both treat
oily waste and recover oil for re-use.
At the time of the original proposal, EPA
believed that 85 percent of oils facilities were
primarily accepting concentrated,, difficult-
to-treat, stable, oil-water emulsions containing
more than 10 percent oil. However, during
post-proposal data collection, EPA learned that
many of the wastes treated for oil content at
these facilities were fairly dilute and consisted of
less than 10 percent oils. While some facilities
are accepting the more concentrated wastes, the
majority of facilities in this subcategory are
treating less concentrated wastes.
Further, at the time of the original proposal,
only three of the facilities included in the data
base for this subcategory were identified as
solely accepting wastes classified as
non-hazardous under RCRA. The remaining
facilities accepted either hazardous wastes alone
or a. combination of hazardous and
non-hazardous wastes. In contrast, based on
more recent information, EPA has concluded
that the majority of facilities in this subcategory
only accept wastes that would be classified by
RCRA as non-hazardous:
The most widely-used treatment technology
in this subcategory is gravity separation and/or
emulsion breaking. One-third of this industry
only uses gravity separation and/or emulsion
breaking to treat oily wastestreams. One-third of
the industry also utilizes chemical precipitation
and one-quarter also utilizes dissolved air
flotation (DAF).
Organics Subcategory
5.3.3
The facilities in this subcategory are those
that treat organic waste received from off-site
and/or recover organics from off-site organic
wastes. EPA estimates that there are 25 facilities
in this subcategory. The majority of these
facilities have RCRA permits to accept
hazardous waste. Among the types of wastes
accepted at these facilities are landfill leachate,
groundwater cleanup, solvent-bearing waste, off-
specification organic products, still bottoms, used
antifreeze, and wastewater from chemical
product operations and paint washes.
All of the organics facilities which discharge
5-3
-------
Chapter S Industry Subcategorization
Development Document for the CWT Point Source Category
to a surface water use equalization and some
form of biological treatment to handle the
wastewater. The vast majority of organics
facilities which discharge to a POTW primarily
use equalization. One third of all the organics
facilities also use activated carbon adsorption.
Most of the facilities in the organics subcategory
have other industrial operations as well, and the
centralized waste treatment wastes are mixed
with these wastewaters prior to treatment. The
relatively constant make-up of on-site
wastewater can support the operation of
conventional, continuous biological treatment
processes, which otherwise could be upset by the
variability of the off-site waste receipts.
MULTIPLE WASTESTREAMSUBCATEGORY 5.4
EPAbasedthe 1999 proposal on establishing
limitations and standards for three subcategories
of CWT facilities: facilities treating either metals,
ofl, or organic wastes and wastewater. As
explained in the proposal, EPA was considering
developing mixed waste subcategory limitations
for facilities which treated wastes in more than
one subcategory. EPA indicated that such
limitations and standards would be established by
combining pollutant limitations from all three
subcategories, selecting the most stringent value
where they overlap.
EPA's consideration of this option
responded to comments to the 1995 proposal
and the 1996 Notice of Data Availability. The
primary reason some members of the waste
treatment industry favored development of a
multiple wastestream subcategory was to
simplify implementation for facilities treating
wastes covered by multiple subcategories. As
detailed in the 1999 proposal, EPA's primary
reason for not proposing (and adopting) this
option was its concern that facilities that accept
wastes in multiple subcategories need to provide
effective treatment of all waste receipts. This
concern was based on EPA's data that showed
such facilities did not currently have adequate
treatment-in-place. While these facilities meet
their permit limitations, EPA concluded that
compliance was likely achieved through co-
dilution of dissimilar wastes rather than
treatment. As a result, EPA determined that
adoption of multiple wastestream subcategory
limitations as described above could arguably
encourage ineffective treatment, EPA solicited
comments on ways to develop a multiple
wastestream subcategory which ensures
treatment rather than dilution. The vast majority
of comments on the 1999 proposal supported the
establishment of a multiple wastestream
subcategory for this rule, and re-iterated their
concerns about implementing the three-.
subcategory- scheme- at- multiple-subcategory
facilities. One commenter suggested a way to
implement a fourth subcategory while ensuring
treatment. This commented suggested that EPA
follow the. approach taken for .the. Pesticide,.
Formulating, Packaging- and Repackaging
(PFPR) Point Source category (40 CFR Part
455). Under this approach, multiple wastestream
subcategory facilities would have the option of 1)
monitoring for compliance with the appropriate
subcategory limitations after each treatment step
or 2) monitoring for compliance with the multiple
wastestream subcategory limitations at a
combined discharge point and certifying that
equivalent treatment to that which would be
required for each subcategory waste separately is
installed and properly designed, maintained, and
operated. This option would eliminate the use of .
the combined waste stream formula or building
block approach in calculating limits or standards
for multiple wastestream subcategory CWT
facilities (The combined waste stream formula
and the building block approach are discussed in
more detail in Chapter 14 of the this document).
Commenters suggested that an equivalent
treatment system could be defined as a
wastewater treatment system that is
demonstrated to achieve comparable removals to
the treatment system on which EPA based the
limitations and standards. Ways of
5-4
-------
Chapter 5 Industry Subcategorization
Development Document for the CWT Point Source Category
demonstrating equivalence might include data
from recognized sources of information on
pollution control, treatability tests, or self-
monitoring data showing comparable removals to
the applicable pollution control technology.
EPAhas now concluded that the approaches
adopted hi the PFPR rule address the concerns
identified earlier. EPA agrees with commenters
that developing appropriate limitations on a site-
specific basis for multiple wastestream facilities
presents many challenges and that the use of a
multiple wastestream subcategory would simplify
implementation of the rule. Moreover, the limits
applied to multiple wastestream treaters would be
a compilation of the most stringent limits from
each applicable subcategory and would generally
be similar to or stricter than the limits-calculated
via the application of the combined waste stream
formula or building block approach.. Most
significantly, the equivalent treatment
certification requirement would address EPA's
concerns that the wastes receive adequate
treatment.
Therefore, EPA has established a 'fourth
subcategory: the mixed waste subcategory.
Chapter 14 of this document details the manner
in which EPA envisions the mixed waste
subcategory will be implemented. Further, EPA
has prepared a guidance manual to aid permit
writers/control authorities as well as CWT
facilities hi implementing the certification process
(available January 2001).
OTHER REGULATORY OPTIONS
CONSIDERED FOR THE OILS
SUBCATEGORY 5.5
Consideration of Regulatory Options
on the Basis of Revenue 5.5.1
As detailed in the 1999 proposal, among
other alternatives, EPA looked at whether it
should develop alternative regulatory
requirements for the oils subcategory facilities
based on revenue because of potential adverse
economic consequences to small businesses.
The SBAR Panel, convened by EPA, discussed
this option. Among the regulatory alternatives
discussed by the panel and detailed in the 1999
proposal was limiting the scope of the rule to
minimize impacts. Under this approach, EPA
would not establish national pretreatment
standards for indirect dischargers owned by small
companies.with less than $6 million in annual
revenue. EPA did not propose to limit the scope
of the rule based on this approach but did
request comment on the issue. •
Concerning the recommendation that EPA
establish alternative limitations and standards on
the basis of revenue, commenters largely
supported EPA's conclusion that this approach
should not be adopted., Commenters stated that
small businesses should be subject to the same
standards and requirements as other industrial
users in this category because of the following
reasons:
• the limitations and standards are
economically achievable for small CWT
facilities;
the perception that small CWT facilities do
not have the potential to cause significant
impacts to the environment is not true; .
• the quantity and toxicity of pollutants present
are the only relevant factors for determining
impacts to receiving streams and POTWs
from CWT discharges;
• the business size is irrelevant to the impact
of a facility's discharges;
• a small facility can have as great an impact
on the environment as a large facility;
there would be no incentive to ensure wastes
are adequately treated at all CWT facilities;
small facilities could operate at a fraction of
the cost (since they would not have to meet
the limitations and standards) and capture
more' market share leading to more wastes
going to the POTW untreated; and
large facilities could easily manipulate their
corporate structure to take advantage of
small business exemptions.
5-5
-------
Chapter 5 Industry Subcategorization
Development Document for the CWT Point Source Category
None of the commenters supported a small
business exclusion, but a few noted that EPA
should look at reducing monitoring requirements
for small businesses in order to reduce their costs
of compliance without compromising effective
treatment None of the commenters provided
EPA with any other suggestions on ways to
mitigate small business concerns that EPA had
not already considered. After careful
consideration of the comments and its database,
EPA has decided that it should not limit the
scope of the CWT rule based on revenue.
Consideration of Regulatory Options
on the Basis of Flow
5.5.2
As detailed in the 1999 proposal, among
other alternatives, EPA-looked at whether it
should develop alternative regulatory
requirements for the oils subcategory facilities
based on wastewater flow level because of
potential adverse economic consequences to
small businesses. The SBAR Panel, convened
by EPA, discussed this option. Among the
regulatory alternatives discussed by the panel and
detailed in the 1999 proposal was limiting the
scope of the rule to rnioimize impacts. Under
this approach, EPA would not establish national
pretreatment standards for indirect oils
dischargers with flows under 3.5 million gallons
per year, or alternately for non-hazardous oils
facilities with flows under either 3.5 or 7.5
MGY. The SBAR Panel noted, in particular,
that excluding indirect dischargers with flows of
less than 3.5 MGY would significantly reduce
the economic impact of the rule on small
businesses while reducing pollutant removals by
an estimated 6%. EPA did not propose to limit
'the scope of the rule based on these approaches
but did request comment on the issue.
Concerning the recommendation that EPA
establish alternative limitations and standards on
the basis of flow, commenters largely supported
EPA's conclusion that this approach should not
be adopted. Commenters stated that low flow
facilities should be subject to the same standards
and requirements as other industrial users in this
category because of the following reasons:
• . the perception that small CWT facilities do
not have the potential to cause significant
impacts to the environment is not true;
• the amount of pollutants in wastewater for a
CWT facility is not a function solely of the
• volume of wastes that the facility receives;
• the quantity of pollutants present and the
toxicity of the pollutants are the only
relevant factors for determining impacts to
receiving streams and POTWs from CWT
discharges;
• a small facility can have as great an impact
on the environment as a large facility;
there would be no incentive to ensure wastes
are adequately treated at all CWT faculties;
and
« small facilities could operate at a fraction of
the cost (since they would not have to meet
the limitations and-standards)-and-capture
more market share leading to more wastes
going to the POTW untreated.
None of the commenters supported an exclusion
based on flow, but a few noted that EPA should
look at reducing monitoring requirements for
small businesses in order to reduce their costs of
compliance without compromising effective
treatment None of the commenters provided
EPA with any other suggestions on ways to
mitigate small business concerns that EPA had
not akeady considered. After careful
consideration of the comments and its database,
EPA has decided that it should not limit the
scope of the CWT rule based on flow.
5-6
-------
Chapter 5 Industry Subcategorization
Development Document for the CWT Point Source Category
Consideration of Regulatory Options
on the Basis of the RCRA
Classification of the Waste Receipts 5.5.3
As explained in the 1999 proposal, among
other alternatives, EPA was considering whether
it should develop limitations and standards for
two categories (rather than a single category) of
oils treatment facilities. The Small Business
Advocacy Review (SBAR) Panel for this rule,
convened by EPA in November 1997, discussed
this option. For a detailed summary of the
panel's findings and discussion, see the 1999
proposal and "Final Report of the SBREFA
Small Business Advocacy Review Panel .on
EPA's Planned Proposed Rule for Effluent
Limitations Guidelines and Standards for the
Centralized Waste Treatment Industry" (DCN
21.5.1); Under thiF'approach EPA would
establish different limllations and standards for
oils subcategory facilities, depending on whether
they treat RCRA subtitle C hazardous wastes
(either exclusively or in combination with non-
hazardous wastes) or treat only non-hazardous
wastes.
At the time of the SBAR Panel, EPA had
collected certain information on facilities that
treat a mixture of hazardous and non-hazardous
wastes as well as facilities that treat non-
hazardous wastes only. The bulk of the data
was from RCRA facilities treating RCRA subtitle
C hazardous waste together with non-hazardous
waste. The data on wastestreams did not show
a significant difference in the types of pollutants
for the streams being treated at RCRA and at
non-RCRA permitted facilities or the treatability
of those pollutants. Although the data did
suggest that pollutant concentrations tended to be
somewhat higher in raw waste going to RCRA
permitted facilities, which in turn suggested that
treatment would be more cost-effective at such
facilities, the information EPA had collected
from non-RCRA permitted facilities was
insufficient to support the conclusion that EPA
should differentiate between oils facilities on the
basis of RCRA classification of the wastes
treated at the facility. Consequently, EPA did
not propose different regulatory requirements for
facilities based on distinctions between hazardous
and non-hazardous wastes.
EPA, following the SBAR panel, collected
wastewater samples at twelve other facilities that
treat only non-hazardous materials. EPA
collected the samples in order to broaden the
database -with additional information on the
pollutant profiles of the wastes that are treated at
these facilities. While EPA included the •
analytical results of the sampling efforts in the
Appendix of the technical development
document for the proposal, EPA had not, at the
time of the proposal, reviewed the data in detail
or compared the data to the earlier data it had
collected. As the proposal also explained, EPA
planned to review the data in detail and present
a preliminary assessment of its findings at- a-
pubh'c-hearing-during the comment period for the-
proposal. • •
At a public hearing on February 18, 1999,
EPA described the relevant sampling data, the
constraints of evaluating this data, and a
comparison of data from hazardous .and non-
hazardous waste streams. This data showed
that, while the mean and median values of
influent concentration of hazardous wastestream
data are greater than for non-hazardous
wastestreams for most pollutants examined, the
ranges of concentration for the hazardous and
non-hazardous wastestreams overlap for most
pollutants. In its presentation, EPA indicated
that it planned to re-examine the oils subcategory
in terms of pollutant loadings, removals,
limitations and standards, costs, impacts, and
benefits. EPA requested comment on this issue,
and extended the comment period for this issue
to 30 days after the public hearing. EPA's
presentation is included in the public record for
this rulemaking as DCN 28.1.1 (other supporting
information is in Section 28).
Five commenters provided specific input on
basing regulatory options for the oils subcategory
5-7
-------
Chanter 5 Industry Subcateeorization
Development Document for the CWT Point Source Category
on the RCRA classification of the waste receipts.
Two commenters supported differentiation on
this basis. They asserted that there are
significant differences between facilities that
accept non-hazardous wastes and those that
accept a combination of hazardous and non-
hazardous waste in terms of pollutant loadings
and the number and type of pollutants, the types
of treatment methods employed, and price
structures. Three commenters opposed
differentiation based on RCRA classification.
These commenters do not believe that RCRA
classification is a critical distinction, but rather
believe that RCRA classification often has no
'impact on the treatability of the waste or final
effluent quality. They commented that non-
hazardous waste receipts have approximately the
same constituents as hazardous waste receipts.
From an environmental perspective, they believe
that it is irrelevant whether the source of'the
pollutants of concern is a hazardous or non-
hazardous facility.
EPA has reexamined this data using the
same standards it applied earlier in 'this
rulemaking for determining pollutants of concern
for this industry (see Chapter 6 of this
document). Based on this review, EPA
determined that the pollutants of concern for
non-hazardous facilities are largely the same as
those previously identified for the oils
subcategory (EPA had based its earlier ,
conclusion on data from facilities processing a
mix of hazardous and non-hazardous waste
receipts).
EPA also loolced to see if the treatment
technologies at strictly non-hazardous facilities
differ from those at facilities that accept both
hazardous and non-hazardous wastes. EPA's
database shows that the range of treatment
technologies employed at both types of facilities
is similar.
Essentially, the only operational difference
EPA has observed between hazardous and non-
hazardous oils treatment facilities is that
hazardous oils waste facilities treat wastes with
higher influent concentrations. EPA's data show
that the average pollutant concentrations in non-
hazardous wastes are lower than in hazardous
wastes. Consequently, pollutant loadings,
removals and treatment cost estimates will differ
to some extent depending on the RCRA
classification of the wastes that are treated. As
explained above, however, both types of facilities
treat for the same pollutants and the
concentration ranges of .these pollutants overlap
at hazardous and non-hazardous operations. In
these circumstances, the characteristics of wastes
treated at hazardous operations do not require a
different •treatment technology from that used at
non-hazardous operations. The choice of
treatment technology for a particular facility is a
function primarily of the effluent concentration
required, not of any inherent differences in the
wastes being treated.. As. a. result,. EPA.
concluded that there is no basis in the chemistry
of the wastewaters being treated which
supported development of different limitations
and standards for hazardous and non-hazardous
oils facilities. Furthermore, after evaluating
treatment technology costs, EPA found that the
costs for RCRA permitted facilities were
equivalent to those for non-RCRA facilities,
although, as noted above, loadings reductions at
the non-RCRA permitted facilities will generally
be lower. Given these factors, EPA decided that
it should not develop different limitations and
standards for RCRA hazardous and non-
hazardous oils facilities. DCN33.1.1 discusses
the determination hi more detail. EPA notes,
however, that its estimates of loadings, removals,
and revenue generated from treating the different
types of wastes take account of differences in
the type of wastes treated.
5-8
-------
Chapter
POLLUTANTS OF CONCERN FOR THE
CENTRALIZED WASTE TREATMENT INDUSTRY
A3 discussed previously, wastewater receipts
treated at centralized waste treatment
facilities may have significantly different
pollutants and pollutant loads depending on the
customer and the process generating the waste
receipt. In fact, at many CWT facilities, the
pollutants and pollutant loads may vary daily and
from batch to batch. As a result, it is difficult to
characterize "typical" CWT wastewaters. In
fact, one of the distinguishing characteristics of
CWT wastewaters (as compared to traditional
wastewaters "subject to national effluent
guidelines and standards) is that there is always
the exception to the rule. For example, at one
facility, EPA analyzed samples of wastewater
received for treatment from a single facility that
were obtained during three different, non-
consecutive weeks. EPA found that the weekly
waste receipts varied from the most concentrated
(in terms of metal pollutants) to one of the least
concentrated (in terms of metal pollutants).
METHODOLOGY
6.1
EPA determined pollutants of concern for
the CWT industry by assessing EPA sampling
data and industry-supplied self-monitoring data.
Because, industry has provided very little
quantitative data on the concentrations of
pollutants entering their wastewater treatment
system, EPA was only able to use such data
from a single facility in the metals subcategory.
For the metals and organics subcategory,
EPA collected and analyzed samples of
wastewater to determine the pollutants of
concern at influent points to the wastewater
treatment systems. For the oils subcategory,
EPA collected samples following emulsion
breaking and/or gravity separation. The pollutant
concentrations at these points are lower than the
original waste receipt concentrations as a result
of the commingling of a variety of waste
streams, and, in the case of the oils subcategory,
as a result of pretreatment. In most cases, EPA
could not collect samples from individual waste
shipments because of physical constraints and
excessive analytical costs.
EPA used two different analytical methods
to analyze samples for oil and grease during the
development of this guideline. EPA analyzed
samples collected prior to the 1995 proposal
using Method 413.1. This method uses freon
and is being phased out. EPA analyzed oil and
grease samples collected after the 1995 proposal
usingthe newly promulgated EPAMethod 1664.
Method 1664 is used to measure oil and grease
as hexane extractable material (HEM) and to
measure silica gel treated-hexane extractable
material (SGT-HEM). EPA believes that oil and
grease measurements from Method 413.1 and
Method 1664 are comparable and has used the
data interchangeably.
EPA collected influent sampling data over a
limited time span (generally one to five days).
The samples represent a snapshotof the receipts
accepted for treatment during the time the
samples were collected. Because waste receipts
may vary significantly from day to day, EPA can
not know if, in fact, the data are also
representative of waste receipts during any other
time period. If EPA had sampled at more
facilities or over longer periods of time, EPA
would expect to observe a wider range of flows,
6-1
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
pollutants, and pollutant concentrations in CWT
industry raw wastewater. This has complicated
the selection of pollutants of concern and
regulated pollutants, and the estimation of
current performance and removals associated
with this rulemaking. Historically, in developing
national effluent guidelines and standards, unlike
the case for CWT waste receipts, influent
wastestreams are generally consistent in strength
and nature.
To establish the pollutants of concern, EPA
reviewed the analytical data from influent
wastewater samples to determine the number of,
times a pollutant was detected at treatable levels.
EPA set treatable levels at ten times the baseline
level1 to ensure that pollutants detected as only
trace amounts would not be selected. In the
results presented today, EPA modified the
baseline values used in the 1999 proposal to be
consistent with those presented in chapter 15 of
this document. However, EPA used all the
available relevant data in these analyses and has
provided opportunities for public comment.
After reviewing the comments, EPA has1
concluded that it has adequately characterized
CWT flows, pollutants, and pollutant
concentrations.
For most organic pollutants, the baseline
value is 10 ug/L. Therefore, for most organic
parameters, EPA has defined treatable levels as
100 ug/L. For metals pollutants the baseline
values range from 0.2 ug/L to 1000 ug/L.
EPA obtained the initial pollutants of
concern listing for each subcategory by
establishing which parameters were detected at
treatable levels in at least 10 percent of the
influent wastewater samples. Ten percent was
used to account for the variability of CWT
wastewaters. As 'mentioned previously in
Section 2.3.3.2, after the initial two sampling
episodes EPA discontinued the analyses for
'This chapter in the 1998 Development
Document inaccurately refers to the baseline .
value as the 'method detection limit.'
dioxins/furans, pesticides/herbicides, methanol,
ethanol, and formaldehyde. As a result these
parameters were not included in the pollutants of
concern analysis. EPA also excluded amenable
cyanide from the analyses because the detection
of total cyanide in a particular sample sometimes
determined whether the laboratory would
analyze for amenable cyanide in that sample.
Table B-l in Appendix B identifies the
episodes and sample points used in the pollutants
of concern analysis. For the organics
subcategory, the episodes and sample points are
the same as for the 1999 proposal. 'For the
metals subcategory, EPA made some changes in
the data selection after a thorough review of the
process diagrams for the sampled facilities and
the analyses performed on the wastewater
samples collected from particular sample points.
EPA also-included self-monitoring" data from one
facility. For the oils subcategory, EPA included
all of the sample points and episodes included in -
the 1999 proposal. Also, EPA has included-
samples" fronr the- characterization sampling
described in section 2.3:4.
The concentration values corresponding to
duplicate samples were averaged using the
methodology in Table 10-1.
• For sample points with continuous flow
systems, EPA aggregated the data values
corresponding to multiple samples into a single
daily value usingthe methodology in Table 10-2.
For example, oil and grease samples are typically
collected four times a day and the laboratory
results are mathematically combined into a single
daily value for each day.
The references to 'sample' or 'samples' in
the remainder of this chapter refer to the
concentration values after averaging duplicates
and aggregating multiple daily values.
Figure 6-1 depicts the methodology EFA
used to select pollutants of concern for each
subcategory.
Tables 6-1 through 6-3 provide a listing of
the pollutants that were determined to be
pollutants of concern for each subcategory.
6-2
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
These tables list the pollutant name, CAS
number, the number of times the pollutant was
analyzed, the number of detects, the baseline
value, the number of detects at treatable levels,
and the minimum and maximum concentration
detected. Tables 6-4 through 6-6 provide a
listing of the pollutants that were not considered
to be pollutants of concern for each subcategory
and the reason they were not selected. While
EPA generally uses the parameters established as
pollutants of concern to estimate pollutant
loadings and pollutant removals, EPA only
selected some of these parameters for regulation.
The regulated pollutants are - a subset of the
pollutants of concern and are discussed in
Chapter 7. Chapter 12 discusses pollutant
loading and removal estimates.
6-3
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
.ola! kt oE piSutanJE analyzed for ca=&
3c I
Iodine vabc m at bast
ID'.o: it-
taut^
Paliiai is a POC far th= su^atsaMy
Mutant is net a FQC far flie
Pdblaut is net aPOC for the
suteattguy
Ptlbtact; is tct aPOC fa tLt
Figure 6-1. Pollutant of Concern Methodology
6-4
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-1. Pollutants of Concern for the Metals Subcategory
Pollutant
CLASSICALS OR CONVENTIONALS
Ammonia as Nitrogen
Biochemical Oxygen Demand
BOD 5-Day (carbonaceous)
Chemical Oxygen Demand (COD)
Chloride
D-Chemical Oxygen Demand
Fluoride
Hexavalent Chromium
'Nitrate/Nitrite-
Oil & Grease
Tptal Cyanide
Total Dissolved Solids
Total Organi&Carbon (TOC)
Total Phenols
Total Phosphorus
Total Sulfide
Total Suspended Solids
METALS
Aluminum
Antimony
Arsenic " ~
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Gallium
Indium
Iodine
Indium
Iron
Lanthanum
Lead
Lithium
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Osmium
Phosphorus
Potassium
Selenium
Silicon
Silver
Snriinm
# Times
Cas No. Analyzed #
Detects
766441-7
C-003
C-002
C-004
16887-00-6
C-004D
1698448-8
18540-29-9
C-005.
C-007
57-12-5
C-010
C-012
C-020
14265-44-2
18496-25-8
C-009
7429-90-5
7440-3&0
7440-38-2
7440-41-7
744G42-8
7440-43-9
7440-70-2 '
7440-47-3
744048-4
7440-50-8 .
7440-55-3
7440-74-6
7553-56-2
7439-88-5
7439-89-6
7439-91-0
7439-92-1
7439-93-2
7439-954
7439-96-5
• 7439-97-6
7439-98-7
7440-02-0
7440-04-2
7723-144)
7440-09-7
7782-49-2
7440-21-3
7440-224
7440-23 -5
90
82
6
89
25
4
90
78
90- .
68
38
30
90
84
85
84
95
'
90
95
95 .
90
90
95 •
90
95
90
95
39
39
38
39
90
39
95
3?
90
95
95
90
95
39
38
39
95
39
95
90
90
67 '
6
88
25
4
90
43
,.8g-,.. _
48
25
30
87
58
77
-,. =28.,.
95
87
63
69-
42
89 .
91
90
95
77
95
9
21
10
13
89
9
90
20
83
94
76
78
95
17
31
38
36 '
37
' 76
90
Baseline # Detects Minimum
>10xBV Cone.
value
(ug/1)
50.0
2,000.0
2,000.0
5,000.0
1,000.0 -
5,000.0
100.0
10.0
50.0
5,000.0
20.0
10,000.0
1,000.0
50.0
• 10.0
1,000.0
4,000.0
(ug/1)
200.0,
20.0
10.0
5.0
100.0
5.0
5,000.0
10.0
50.0
25.0
500.0
1,000.0
1,000.0
1,000.0
100.0
100.0
50.0
100.0
5,000.0
15.0
0.2
10.0'
40.0
100.0
1,000.0
1,000.0
5.0
100.0
10.0
50000
84
53
6
87
25
4
' 79
• 22
81
15
25
30
85
10
77
15-
91
76,
47
50 -
17
87
85 '
85
94
56
95
5
11
10
11
88
4
83
12
44 '
84
73
71
95
8
25
38
33
35
60
X9
(ug/1)
300
4,000
336,000
48,000
262,000
2,700,000
123
1 '
90
4,500
288
12,700,000
. 6,600
11
380
80
10,000
(ug/1)
388
20
17
1
441
7
6,630
73
15
635
1,125
800
23,800
400'
222
484
136
103
5,920
26
1
11
539
149
1,730
15,100
3
111
4
4R 300
Maximum
Cone.
(ug/1)
1,650,000
10,800,000
. 3,030,000
85,500,000
62,000,000
11,000,000
28,000,000
40,000,000
40,000,000
143,000
13,300,000
223,000,000
49,300,000-
2,900
15,000,000
1;10G,000
237,000,000
(ug/1)
3,090,000-
1,160,000
1,220,000
1,190
1,420,000
19,300,000
9,100,000
65,000,000
10,900,000
40,200,000
36^50
61,200
537,000
253,000
9,400,000
1,660
4,390,000
795,000
2,980,000
6,480,000
3,100
1,390,000
3200,000
21,800
2,550,000
9,720,000
11,800
1,330,000
130,000
77.700.000
6-5
-------
Chapter 6 Pollutants of Concern for the CVVT Industry
Development Document for the CWT Point Source Category
Table 6-1. Pollutants of Concern for the Metals Subcategory
Pollutant
Strontium
Sulfur
Tantalum
Tellurium
Thallium
Tin
'Titanium
Vanadium
Yttrium
Zinc
Zirconium
ORCANICS
1,1,1-Trichlorocthane
1,1-Dichloroethcnc
1,4-Dioxanc
2-Butanonc
2-Propanone
4-Mcthyl-2-Pcntanone
BcnzoicAcid
Benzyl Alcohol
Bis(2-Ethylhexyl) Phthalate
Carbon Disulfidc
Chloroform
Dibromochloromethane
HcxanoicAcid
m-Xylene
Methylcnc Chloride
n,n-DimcthyIformamide
Phenol
Pyridine
Toluene
Trichloroethcne
# Times
Cas No. Analyzed #,
Detects
7440-24-6
7704-34-9
7440-25-7
13494-80-9
7440-28-0
7440-31-5
7440-32-6
7440-62-2
7440-65-5
7440-66-6
7440-67-7
71-55-6
75-35-4
123-91-1
78-93-3
67-64-1
108-10-1
65-85-0
100-51-6
117-81-7
75-15-0
67-66-3
12448-1
142-62-1
108-38-3
75-09-2
68-12-2
108-95-2
110-86-1
108-88-3
7Q-01-6
39
38
39
39
90
95
95
90
90
95
39
27
27
27
27
27
27
22
22
22
27 "
27
27
22
27
27
22
22
22
27
77
17
38
7
4
29
83
82
59
59
' 94
17
5
5
, 5
9
- 25
"" 7
.... 19
5
7
9
5
3
7
7
16
12
5
5
9
8
Baseline # Detects
>10xBV
. value
100.0
1,000.0
500.0
1,000.0
10.0
30.0
5.0
50.0 •
5.0
20.0
100.0
' (ug/1)
10.0
10.0
10.0
50.0
50.0
50.0
50.0
10.0
,10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
inn
13
38
4
4
16
77
75
32
39
92
5
3
5
5
8
16
5
14
4 .
6
7
5
3.
6
3-
8
8
3
5
5
' 5
Minimum
Cone.
202
157,000
1,270
11,700
13
55
9
11
2
166
. 200
(ug/1)
38
142
404 '..
65
52
73
193
13, ..
18
11
161
105
99
25
11
11
61
140
47
1?
Maximum
Cone.
16,300
38,000,000
20,000
182,000
275,000
15,100,000
7,500,000
364,000
900
21,400,000
4,860
(ug/1)
601
3,735
83352
71,.102
488,102
9j295
36,756
7,929
1,063
' 2,396'
731
723
1,256
646
734
583
341
1,684
1,977
360
6-6
-------
Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-2. Pollutants of Concern for the Oils Subcategory
Pollutant
CLASSICALS OR CONVENTIONALS
Ammonia as Nitrogen
Biochemical Oxygen Demand
Chemical Oxygen Demand (COD)
Chloride
Fluoride
Nitrate/Nitrite
Oil & Grease
SGT-HEM
Total Cyanide
Total Dissolved Solids
Total Organic Carbon (TOC)
Total Phenols
Total Phosphorus
Total Suspended Solids
METALS
Aluminum
Antimony
Arsenic
Barium,
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Germanium
Iron
Lead
Lutetium
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Potassium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Tantalum
Tin
Titanium
Zinc
ORGANICS
\ \ \ Trichloropthane
CasNo.
7664-41-7
C-003
C-004
16887-00-6
1698448-8
C-005
C-007
C-037
57-12-5
C-010
C-012
C-020
14265-44-2
C-009
7429-90-5
7440-36-0
7440-38-2 "•
7440-39-3 ._ : J_
7440-42-8
7440-43-9 -•
7440-70-2
7440-47-3
744048-4
7440-50-8
7440-564
7439-89-6
7439-92-1
7439-94-3
7439-954
7439-96-5
7439-97-6
7439-98-7
7440-02-0
7723-14-0
7440-09-7
7782-49-2
7440-21-3
7440-22-4
7440-23-5 "
7440-24-6
7704-34-9
7440-25-7
7440-31-5
7440-32-6
7440-66-6
71 SS 6
# Times Baseline # Detects
Analyzed # value >10xBV
39
54
54
14
39
39
54
25
18
29
54.
39
39
54
54
54
54
-'.-'54
54
• 54
. 54
54
54
54
19
54
54 .
19
54
54
54
54
54
17
19
54
19 •
54
54
19
17
19
.54
54
54
28
39
54
54
14
38
37
54
25
12
29
54-
39
39
53
51
41
51
54
54
42
- 54=-.-
52
42
53
2
54
52
3
54
54
42
49
52
17
19
25
19
32
53
13
17
3
39
38
• 54
73
(ug/1)
50.0
2,000.0
5,000.0
1,000.0
100.0
50.0
5,000.0
5,000.0
20.0
10,000.0
1,000.0,
50.0
ioio
4,000.0
(ug/1)
200.0
20.0
10.0
200.0
100.0
5.0
5,000.0
10.0
50.0
25.0
500.0
100.0
50.0
100.0
5,000.0
15.0
0.2
10.0
40.0
1,000.0
1,000.0
5.0
100.0
10.0
5,000.0
• 100.0
1,000.0
500.0
30.0
5.0
20.0
(ug/1)
100
39
54
54
14
34
32
53
22
5
29
54
38
39
51
44
9
33
17
54.
31
45
39
'25
44
2
52.
38
3
23
. 53
21
47
39
16
19
12
19
6
52
8
17
2
31
35
51
1Q
Minimum
Cone.
(ug/l)
13,500
500,000
1,440,000
19,400
115
130
37^00
17,500
22 •
1,270,000
-298,000,
42
650
34,000
(ug/1)
213-
17
6
12 .
1,050
9
-"•• 5J155
9
9
11
10,250
494
34
1,165
4,560
22
0
15
27
4,033
23,550
9
1,862
8
12,400
128
90,600
1,474
63
8
34
(ug/0
10
Maximum
Cone.
(ug/1)
1,310,000
62,500,000
824,000,000
6,180,000
330,000
103,000
180,000,000
40,100,000
980
40,200,000
157,000,000
185,000
' 19,000,000
59,600,000
(ug/1)
582,000'
2,410
9^170-
•7,290
1,710,000
860
810,000
... 7,178
116,000
80,482
12^60
630,000
37300
1,315
753,000
44,500
'313
19,500
'81,050
239,000
2,880,000
1,000
87,920
7,740
11,200,000
3,470
3,712,000
15,190
6,216
1,540
94,543
(ug/1)
144S5
6-7
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-2. Pollutants of Concern for the Oils Subcategory
Pollutant
1,1-Dichloroethene
1,2,4-Trichlorobenzene
1 ,2-Dichlorobcnzenc
1,2-DichIoroethanc
1 ,4-Dichlorobenzene
1,4-Dioxane
l-Mcthylfluorcne
1-Methylphcnanthrene
2,3-Bcnzofluorene
2,4-Dimethylphcnol
2-Butanonc
. 2-hopropyInaphthalene
2-MethylnaphthaIene
2-Propanone
3,6-Dimcthylphenanthrene
4-Chloro-3-Methylphenol
4-MethyI-2-Pentanone
Acenaphthcne
AIpha-TcrpineoI
Aniline
Anthracene
Benzene
Benzo(a)anthracene
BenzoicAcid
Benzyl Alcohol
Biphenyl
Bis{2-Ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Carbazole
Carbon Bisulfide
Chlorobcnzcne
Chlorofonn
Chryscne
Dibcnzofuran
Dibcnzothiophene
Dicthyl Phthalate
Diphcnyl Ether
Ethylbcnzene
Fluoranthcnc
Fluorcnc
Hcxanoic Acid
m+p Xylene
m-Xylcne
Mcthylcnc Chloride
n.n-Dirncthylformamide
n-Dccanc
n-Docosanc
n-Dodecanc
n-Fieosnnp
CasNo.
75-35-4
120-82-1
95-50-1
107-06-2
106-46-7
123-91-1
1730-37-6 .
832-69-9
243-17-4
105-67-9
78-93-3
2027-17-0
91-57-6
67-64-1
1576-67-6
59-50-7
108-10-1
83-32-9
98-55-5
62-53-3
120-12-T
71-43-2
56-55-3
65-85-0
100-51-6
92-52-4
117-81-7
85-68-7
86-74-8
75-15-0
108-90-7
67-66-3
218-01-9
132-64-9
132-65-0
84-66-2
101-84-8
• 100-41-4
20644-0
86-73-7
142-62-1
179601-23-1
108-38-3
75-09-2
68-12-2
124-18-5
629-97-0
112-40-3
1 17-QS-8
# Times
Analyzed #
28
39
39
28
39
28
39
39 ,
39
39
• 28
39
39
28 •
39
38
28
3?
39
39
39
28
39
39
39 '
39
39
39
39
28
28
28
39
39
39
39
39
28
39
39
39
5
28
28
39
39
39
39
•}Q
• 7
8
4
12
7
3
8
11
6
11
26-
5
28
27-
5
20
22
8
13
5
12
28
12
30 •
13
18
18
7
6
14
11
12
12
7
10
10
8
28
15
11
32
5
23
25
7
29
24
30
"¥>
Baseline # Detects Minimum
value >10xBV Cone
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
50.0
10.0
10.0
50.0
10.0
10.0
50.0
10.0
10.0
10.0
10.0
10.0
10.0
50.0
10.0
10.0
10.0
10.0
20.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
. 10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
100
6
8
4
10
7
3
7
9
6
9
24-,
4
25
27-
5
20
15
7
11
5 . :..
9
24 '
8
30
11
14
13 '
6
4
6
6
12
• 10
6
9
10
8
25
11
10
31
5
22
16
6
27
20
30
7R
11
359
171
14
454
189
42
92
162
48
- 57.-.
68
80
974
114
101'
199
65
57
142
27
70
25
598
40
36
33
64'
81
10
12
160
39
32
38
145
149
14
30
73
56
838
24
13
83
62
17
125
SR
Maximum
Cone
1,968
18,899
4,186
713
2,334
1,323
5,803
7,111
2,755
2,171
178,748-
125,180
46,108.
2,099340
2,762
83,825
20,489
13,418
2,245
367
18,951
20,425
6,303
163,050
12,700
10,171
838,450
49,069
1,459
2,335
326
1,828
8,879
13,786
5,448
9,309
13,751
18,579"
28,873
15,756
495,899
1,650'
32,639
10,524
803
579,220
66,926
472,570
319 ORO
6-8
-------
Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-2. Pollutants of Concern for the Oils Subcategory
Pollutant
n-Hexacosane
n-Hexadecane
n-Octacosane
n-Octadecane
n-Tetracosane
n-Tetradecane
Naphthalene
o+p Xylene
o-Cresol
o-Toluidine
o-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
Phenanthrene
Phenol
Pyrene
Pyridine
Styrene
Tetrachloroethene
Toluene
Trichloroethene
# Times
Cas No. Analyzed
630-01-3
544-76-3
630-02-4
593-45-3
646-31-1
629-59-4"
91-20-3
136777-61-2
95^8-7
95-53-4
95-47-6
10644-5
99-87-6
700-12-9
85-01-8
108-95-2
129-00-0
110-86-L.
10042-5 '-
127-18-4
108-88-3
79-01-6. -
70^74-^^ R
39
39
39
39
38 •
39
39
28
39
39
5
39
39
39
39
39
39
39
39
28
28
28
39
Baseline # Detects . Minimum Maximum
# value >10xBV Cone. Cone.
13
33
4
. 32
17
33
33
23
17
7
5
26
10
7
22
36
16
• 10
8-
19
28
15
13
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0-
10.0
10.0
10.0
Q<50
10
33
4
29
12
31
31
18
16
4
5
25
10
7
17
36
14
6
7 ••
18
26
10
n
16
. 159
101
47
18
78
24
14
85
26
561
15
232
116
12
375
11
14 -
28
24
51
. 18.
1495
9,561
1,367,970
22,733
901,920
12,111
2,560,460
53,949
16,584
8,273
248
1,141
3,607
6,601
11,186
49,016
48,640
22,763
1,280-
1,019
12,789
99,209
7,125
3R3.151
6-9
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-3. Pollutants of Concern for the Organics Subcategory
Pollutant
CLASSICALS OR CONVENTIO.VALS
Ammonia as Nitrogen
Biochemical Oxygen Demand
Chemical Oxygen Demand (COD)
D-Cbcmical Oxygen Demand
Fluoride
Nitrate/nitrite
Total Cyanide
Total Organic Carbon (TOC)
Total Sulfidc
Total Suspcnded'Solids
METALS
Aluminum
Antimony
Arsenic
Barium
Boron
Calcium
Chromium
Cobalt
Copper
Iodine
Iron
Lead
Lithium
Manganese
Molybdenum
Nickel
Phosphorus
Potassium
Silicon
Sodium
Strontium
Sulfur
Tin
Titanium
Zinc
ORGANICS
,1,1 ,2-Tetrachlorocthane
, 1 , 1-Trichloroethane
, 1 ,2,2-Tetrachloroethane
, 1 ,2-Trichlorocthane
,1-Dichlorocthane
,1-Dichloroethene
1 A3-Triehloropropane
1 ,2-Dibromocthane
1 ,2-Dichlorobenzcne
1,2-Dichlorocthane
1 .3-Dichloronronnne
CasNo.
766441-7
C-003
C-004
C-004D
1698448-8
C-005
57-12-5
C-012.
- 18496-25-8
C-009
7429-90-5
7440-360
7440-38-2
7440-39-3
7440-42-8
7440-70-2
7440-47-3-
7440-4&4
7440-50-8
7553-56-2
7439-89-6
7439-92-1
7439-93-2
7439-96-5
. 7439-98-7
7440-02-0
7723-14-0
7440-09-7
7440-21-3
7440-23-5
7440-24-6
7704-34-9
7440-31-5
7440-32-6
7440-666
630-20-6
71-55-6
79-34-5
79-00-5
75-34-3
75-35-4
96-lS^t
106-93^1
95-50-1
107-06-2
142-2R-9
# Times
Analyzed
5
5
5
5
5
5
5
5...
5
5
5
5
5,
5 -
5
5 '
5_
- 5
5
5
5
5
5
5
5
5
5
5
5
5 .
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5 '
s
#
5
5
5
5
5
4
5
5
3
5
5 ,
4
5
5
5
5
4
4
5
4
5
4
5
5
5
5
4
5 -
5
5
5
5
4
5
5 '
5
5
1
5
5
5
5
5
1
4
1
Baseline
value
(ug/l)
50.0
2,000.0
5,000.0
5,000.0
100.0
50.0
20.0
1,000.0
1,000.0
4,000.0
(ug/l)
200.0
20.0
10.0
200.0
100.0
5,000.0
10.0
50.0
25.0
" 1,000.0
100.0
50.0
100.0
15.0
10.0
40.0
1,000.0
1,000.0
100.0
5,000.0
100.0
1,000.0
30.0
5.0
20.0
(ug/l)
10.0
10.0
10.0
.10.0
10.0
10.0
10.0
10.0
10.0
10.0
inn
# Detects
>10xBV
5
5
5
5
2 •
4
5
5 ,
2
4
4
3~
1
2
5
5
2
_ 3 "
4
1 ""
5
1
. . 5
5
4
4
1
5
5
5
5
5
2
1
4
5
4
1
5
2
5
4
5
1
•4
1
Minimum
Cone.
(ug/l)
83,000
790,000
1,400,000
1,200,000
600
100,000
760
510,000
4,000
33,000
(ug/I)
148
14fr
8
1,030
2,950
1,025,000
63
253
7
3,800
2,360
109
1,100
179
33
55
3,000
383,000
1,550
2,470,000
3,900
12,800
200
9
40
(ug/l)
249
74
8,602
776
23
112
100
297
479
855
7R6
Maximum
Cone.
("g/l)
2,400,000
7,550,000
11,000,000
9,900,000
1,950
340,000
7,800
3,750,000
24,000
3,700,000
(«g/l)
7,660
r;54Q-
152
136,000
4,320
1,410,000
274
. 731
2,690
15,100
6,430
687
18,750
513
6,950
2,610
15,900
1,240,000
3,600
6,390,000
14,000
1,990,000
2,530
64
1,210
(ug/l)
2,573
320
8,602
6,781
108
461
839
6,094
479
5,748
786
6-10
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-3. Pollutants of Concern for the Organics Subcategory
Pollutant
2,3,4,6-Tetrachlorophenol
2,3-DichIoroaniline
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4-DimethylphenoI
2-Butanone
2-Propanone
3,4,5-Trichlorocatechol
3,4,6-Trichloroguaiacol
3,4-Dichlorophenol
3,5-DichIorophenol
3,6-Dichlorocatechol
4,5,6-Trichloroguaiacol ,
4,5-DichloroguaiacoI
4-Chloro-3-Methylphenol
4-Chlorophenol
4-Methyl-2-Pentanone
S^efiloroguaiacol" "~ '--'•'
6-ChIorovanilIin
Acetophenone
Aniline
Benzene
BenzqicAcid
Bromodichloromethane
Carbon Disulfide
Chlorobenzene
Chloroform
Dimethyl Sulfone
Ethylenethiourea
Hexachloroethane
Hexanoic Acid ,
. Isophorone
m-Xylene
Methylene Chloride
n,n-Dimethylformamide
o+p Xylene
o-Cresol
p-Cresol
Eentachlorophenol
Phenol
Pyridine
Tetrachloroethene
Tetrachloromethane
Toluene
Trans- 1 ,2-Dichloroethene
Trichloroethene
Vinvl Chloride
# Times
Cas No. Analyzed
58-90-2
608-27-5
95-95^
88^06-2
105-67-9
78-93-3
67-64-1
56961-20-7
60712-44-9
95-77-2 .
591-35-5 .
3938-16-7
2668-24-8
2460-49-3
, 59-50-7
106-48-9
108-10-1
- - 3743-23-5
18268-76-3"
98-86-2
62-53-3
7M3-2
65-85-0
75-27-4
75-15-0
108-90-7
67-66-3
67-71-0
9^45-7
67-72-1
142-62-1
78-59-1
108-38-3
75-09-2
68-12-2
136777-61-2
95-48-7
10&44-5
. 87-86-5
108-95-2
110-86-1
127-18-4
. 56-23-5
108-88-3
156-60-5
79-01-6
7*5-0) -4
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5"
5
5
5 •"
5
5
5
5
. 5
5
5 •
5
5
5
5
5
5
5
5
5
5
5
5
5'
5
5
5
5
5 '
#.
5
3
4
4
1
5
5
' 2
2
4
3
1
2
1
' 1
4
5
1
1
4
2
5
2
, 5
4
4
4
3
2
2
3
2
5
4 .
3
5
4
4
4
4
5
4
5
, 5
5
4'
<$
Baseline # Detects
value >10xBV
20.0
10.0
10.0
10.0
10.0
50.0
50.0
0.8
.. 0.8
0.8
0.8
0.8
0.8
0.8
10.0
240.0
50.0
160.0 ,
0:8S
10.0
10.0
10.0 -
50.0
10.0 '
10.0
10.0
10.0
10.0
20.0
10.0
. 10.0
10.0
10.0
10.0
10.0
10.0 '
10.0
10.0
50.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
100
5
3
4
- 4
1
5
5
1
1
4
3
1
1
1
1
2
4
1
i~"
4
'2
, 3
2
1
1
1
4
3
2
1
3
1
1
4
2
1
4
4
4
4
4
4
5
5
5
4
1
Minimum Maximum
Cone. Cone.
. 1,189
109
114
148
683
894
1,215
2
7
71
38
12
4
9
204
1,450
290 '
2,350
38
336
178
30
5,649
26
14
70 =
5,224
315
8,306
75
1,111
60
45
2,596
23
.13
7,162
220
657
483
29
2,235
1,862
• 148
1,171
3^51
290
,5,397
636
579
1,091
683
5,063
12,435
46
12
470
170
12
62
9
204
7,940
4,038
2,350
38
739
392
. 179
15,760
197
' 1,147
101
32301
892
9,655
101
4,963
141
310
87,256
225
113
14,313
911
1,354
9,491
444
19,496
16,126
2,053
5",147
23,649
L226
6-11
-------
Chapter 6 Pollutants of Concern for the CVVT Industry
Development Docunientfor the CWTPoint Source Category
Table 6-4. Pollutants Not Selected as Pollutants of Concern for the Metals Subcategory
Pollutant
CLASSICALS ORCONVENTIONALS
SOT-HEM
METALS
Barium
Bismuth
Cerium
Dysprosium
Erbium
Europium
Gadolinium
Germanium
Gold
Hafnium
Holmium
Lutetium
Ncodymium
Niobium
Palladium
Platinum
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Terbium
Thorium
Thulium
Tungsten
Uranium
Ytterbium
ORGANICS
1,1,1,2-TctiachIoroethane
1,1 .V-Tctrachloroethane
1 , 1 ,2-TrichIoroe thane
1 , 1-Dichloroc thane
1,2,3-Trichlorobcnzene
1,2,3-Trichloropropane
1,2,3-Trimcthoxy benzene
1 ,2,4,5-TctrachIorobenzene
t ,2,4-Trichlorobenzcne
1 ,2-Dibromo-3-Chloropropane
1,2-Dibromoc thane
1 ,2-DichIorobenzene
1,2-DichIorocthane
1 ,2-Dichloropropanc
1,2-Diphcnylhydrazine
l^:3,4-Dicpoxy butane
1,3,5-Trithiane
1 VRtrtflHiffnp 2-rhTom
Cas No.
C-037
7440-39-3
7440-69-9
744CM5-1
7429-91-6
7440-52-0
7440-53-1
7440-54-2
7440-56-4
7440-57-5
7440-58-6
7440-60-0
7439.94,3
7440-00-8
7440-03-1
7440-05-3
7440-06-4
7440-10-0
7440-15-5
7440-16-6
7440-18-8
,_ 744
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-4. Pollutants Not Selected as Pollutants of Concern for the Metals Subcategory
Pollutant •
1 ,3-Dichloro-2-Propanol
1 ,3-Dichlorobenzene
1 ,3-Dichloropropane
1 ,4-DichIorobenzene
1 ,4-Dinitrobenzene
1 ,4-Naphthoquinone
1 ,5-NaphthaIenediamine
l-Bromo-2-ChIorobenzene
l-Bromo-3-Chlorobenzene
l-Chloro-3-Nitrobenzene
I-Methylfluorene
1-Methylphenanthrene
l-Naphthylamine
l-Phenylnaphthalene
2,3 ,4,6-Tetrachlorophenol
2,3,6-Trichlorophenol -
2,3-Benzofluorene
2,3-Dichlorpanilihe
2,3-DicMoronitrobenzene-
2,4,5-TrichIorophenoL, '.; „ ' .
2,4,6-TrichIorophenol
2,4-Dichloropb.enol
2,4-Dimethylphenol
2,4-DinitrophenoI
2,4-Dinitrotoluene
2,6-Di-Tert-Butyl-P-Benzoquinone
2,6-Dichloro-4-Nitroaniline
2,6-Dichlorophenol
2,6-Dinitrotoluene
2-(methylthio)benzothiazole
2-ChloroethylvinyI Ether
2-ChIoronaphthalene
2-ChlorophenoI
2-Hexanone
2-Isopropylnaphthalene
2-Methylbenzothioazole
2-Methylnaphthalene •
2-Nitroaniline
2-Nitrophenol
2-Phenylnaphthalene
2-PicoIine
2-Propen-l-Ol
2-PropenaI
2-Propenenitrile, 2-Methyl-
3,3-Dichlorobenzidine
3,3-Dimethoxybenzidine
3,6-Dimethylphenanthrene
3-Chloropropene
3-MethylchoIanthrene
3 Nitroanitine
Cas No.
96-23-1
' . 541-73-1
142-28-9
10&46-7
100-25^
130-15-4
2243-62-1
694-8O4
108-37-2
121-73-3
1730-37-6
832-69-9
134-32-7
605-02-7
58-90-2
933-75-5
243-17-4
608-27-5
3209-22-1^'
95-95^4"'"
88-06-2
120-83-2
105-67-9
51-28-5
121-14-2
719-22-2
99-30-9
87-65-0
606-20-2
615-22-5
110-75-8
91-58-7
95-57-8
591-78-6
2027-17-0
120-75-2
91-57-6
88-744
88-75-5 •
612-94-2
109-06-8
107-18-6
107-02-8
126-98-7
91-94-1
119-904
1576-67-6
107-05-1
5649-5
99-09-?
Never Detected Detected in < 10%
Detected <10xBV of infuent samples
X
X
X
X
X
X
X
"X~'\
x .
X . . .
X
X
X
X
X
X
X
X
X
• x
Xv'
X ' ~.
X
x .
X
X
x
X
X
x . •
X
X
X
X
X
, X
X
X
. • X
X
X
X
X
X
X
X
X
X
X
X -
6-13
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-4. Pollutants Not Selected as .Pollutants of Concern for the Metals Subcategory
Pollutant
4,4'-McihyIenebis(2-Ch!oroaniline)
4,5-Mcthylene Phenanthrene
4-Aminobiphenyl
4-BromophenyI Phenyl Ether
4-Chloro-2-NitroaniIine
4-Chloro-3-MethyIphenol
4-Chlorophenylphenyl Ether
4-Nitrophcnol
5-Nitro-O-ToIuidine
7,12-Dimethylben2(a)arithracene
Acenaphthene
Accnaphthylcne
Acctophcnone
Aciylonitrile
AIpha-Tcrpineol
Aniline
Aniline, 2,4,5-Trimethyl-
Amhraccnc
Aramile
Benzan throne
Benzene
Bcnzencthiol
Benzidine
Benzo(a)anthiacene
Bcnzo(a)pyrcne
Benzo(b)fluoranthene
Bcnzo(ghi)pcrylcnc
Benzo{fc)fluoranthene
Bcnzonitrilc, 3,5-Dibromo-4-Hydroxy-
Bcta-Naphthylamine
Biphcnyl
Biphcnyl, 4-Nitro
Bis(2-Chloroethoxy)methane
Bis(2-Chloroethyl) Ether
Bis(2-Chloroisopropyl) Ether
Bromodichloromethane
Bromomcthane
Butyl Benzyl Phthalate
Carbazolc
Chloroacctonitriie
Chlorobcnzcne
Chloroethane
Chloromcthane
Chryscnc
Cis- 1 ,3-Dichloropropene
CrotonaJdchyde
Crotoxyphos
Di-N-Butyl Phthalate
Di-N-Octyl Phthalate
Oi-N-Pmnvtnitrrramine
CasNo.
101-14^
203-64-5
92-67-1
101-55-3
89-63-4
59-50-7
7005-72-3
100^)2-7
99-55-8
57-97-6
83-32-9
208-96-8
98-86-2
107-13-1
98-55-5
62-53-3
137-17-7
• 120-12-7
140-57-8
82-05-3
71-43-2
108-98-5
92-87-5
56-55-3
50-32-8
205-99-2
191-24-2
207-08-9
1689-84-5
91-59-8
92-52-4
92-93-3
111-91-1
111-4*4
108-60-1
75-27-4
74-83-9
85-68-7
86-74-8
107-14-2
108-90-7
75-00-3
74-87-3
218-01-9
10061-01-5
4170-30-3
7700-17-6
84-74-2
117-84-0
6?l-ffil-7
Never Detected Detected in <10%
Detected <10xBV of infuent samples
X
X
X
X
X .
X
X
X
X
X
X
X
X
X
X
X
X ,
X
X
X
X
X
.X
X
X
X '
X
X
X
X
X
X
X
X
X
'X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
6-14
-------
Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-4. Pollutants Not Selected as Pollutants of Concern for the Metals Subcategory
Pollutant
Dibenzo(a,h)anthracene
Dibenzofuran
Dibenzothiophene
Dibromomethane
Diethyl Ether
Diethyl Phthalate
Dimethyl Phthalate
Dimethyl Sulfone
Diphenyl Ether
Diphenylamine
Diphenyldisulfide
Ethane, Pentachloro-
Ethyl Cyanide
Ethyl Methacrylate
Ethyl Methanesulfonate
Ethylberizene
Ethylenethiourea
Fluorarithene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene-
Hexachloroethane
Hexachloropropene
Indeno( 1 ,2,3-Cd)pyrene
lodomethane
Isobutyl Alcohol
Isophorone
Isosafrole
Longifolene
Malachite Green
Mestranol
Methapyrilene
Methyl Methacrylate
Methyl Methanesulfonate
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Nitrosodi-n-Butylamine
n-Nitrosodiethylamine
n-Nitrosodimethylamine
n-Nitrosodiphenylamine
n-Nitrosomethylethylamine
n-Nitrosomethylphenylamine
n-Nitrosomorpholine
n-Nitrosopiperidine
Cas No.
53-70-3
132-64-9
132-65-0
74-95-3
60-29-7
84-66-2
131-11-3
.67-71-0
101-84-8
•122-39-4
882-33-7
76-OL-7
107-12-0
97-63-2
62-50-0
100-41-4
96-45-1
206-44-0^
86-73-7
118-74-1
87-68-3
..-77-47^,..,.,
67-72-1
1888-71-7
193-39-5
74-88-4
78-83-1
78-59-1
120-58-1
' 475-20-7
569-64-2
72-33-3
91-80-5
80-62-6
66-27-3
124-18-5
629-97-0
112-40-3
112-95-8
630-01-3
544-76-3
924-16-3
55-18-5
62-75-9
86-30-6
10595-95-6
614-00-6
59-89-2
100-75-4
630-09-4
Never Detected
Detected <10xBV
' X
X
X
X
X
X
p
X
X
X
X
X
X
X
X-
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Detected in < 10%
of infuent samples
X
X
X
X
. X- • - • -
"Tx." .
x
X
X
X
X
X
X
X
X
6-15
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-4. Pollutants Not Selected as Pollutants of Concern for the Metals Subcategory
Pollutant
n-Octadccane
n-Tctracosane
n-Tetradccane
n-Triacontanc
Naphthalene
Nitrobenzene
o+p Xylenc
o-Anisidine
o-Crcsol
o-Toluidinc
o-Toluidine, 5-Chloro-
p-Chloroaniline
p-Crcsol
p-Cymene
p-Dimethylaminoazobenzene
p-Nitroaniline
Pcntachlorobcnzcnc
Pcntachlorophenol *
Pcntamcthylbenzene
Pcrylcne
Phenacetin
Phenanthrcnc
Phenol, 2-Methyl-4,6-Dinitro-
Phcnothiazinc
Pronamidc
Pyrenc
Rcsorcinol
Safrolc
Squalcne
Styrcnc
Tctrachlorocthenc
Tctrachloromcthanc
Thianaphthcne
Thioacctamidc
Thioxanthc-9-One
Toluene, 2,4-Diaminc-
Trans- 1 ,2-Dichloroethene
Trans-l,3-DichIoropropcne
Trans-l,4-DichIoro-2-Butene
Tribromomethanc
Trichlorofluoromethane *
Triphenylenc
Tripropyleneglycol Methyl Ether
Vinyl Acetate
Vinvl OilnnA-
Cas No.
593-45-3
646-31-1
629-59^1
638-68-6
91-20-3
' 98-95-3
136777-61-2
90-04-0
95^8-7
95-53^
95-79-4
10M7-8
10&44-S
99-87-6
60-11-7
100-01-3
608-93-5
87-86-5 '
700-12-9
198-55-0
62-44-2
85-01-8
534-52-1
92-84-2
23950-58-5
129-00-0
108-46-3
94-59-7
7683-64-9
100-42-5
127-18-4
56-23-5
95-15-8
62-55-5
492-22-8
95-80-7
156-60-5
10061-02-6
110-57-6
75-25-2
75-69-4
217-59-4
20324-33-8
108-05-4
Never Detected Detected in <10%
Detected <10xBV of infuent samples
x
x
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x
X
X
X
X- .... -
x- -
X
X
X
X
X
X
X
X
X
X
X •
x •
' X
x .
X
X
X
X
X
X
X
X
•y
6-16
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-5. Pollutants Not Selected as Pollutants of Concern for the Oils Subcategory
Pollutant
CLASSICALS OR CONVENTIONALS
Hexavalent Chromium
Total Sulfide
METALS
Beryllium
Bismuth
Cerium
Dysprosium
Erbium
Europium
Gadolinium
Gallium
Gold
Hafnium
Holmium
Indium
Iodine
Indium
Lanthanum . ..t
Lithium
Neodymium
Niobium
Osmium
Palladium
Platinum
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Tellurium
Terbium
Thallium
Thorium
Thulium
Tungsten
Uranium
Vanadium
Ytterbium
Yttrium
Zirconium
ORGAMCS
1 , 1 ,1,2-Tetrachloroethane
1 , 1 ,2,2-Tetrachloroethane
1 , 1 ,2-Trichloroethane
1,1-Dichloroethane
1 ,2,3-Trichlorobenzene
1 ? ^-TricWoronronane
Never
CasNo. Detected
18540-29-9
18496-25-8
744O41-7
7440-69-9
7440-45-1
7429-91-6
7440-52-0
7440-53-1
7440-54-2
7440-55-3
7440-57-5
7440-58-6
7440-60-0
7440-74-6
• • ' • . . 7553-56-2
7439-88-5
7439-91-0
7439;93-2"
. / . 7440=00=8_
7440-03-1
7440-04-2
7440-05-3
7440-064
7440-10-0
7440-15-5
7440-16-6
7440-18-8
7440-19-9
7440-20-2
13494-80-9 ,
'7440-27-9
7440-28-0
7440-29-1
7440-30-4
7440-33-7
7440-61-1
7440-62-2
7440-64-4
7440-65-5
7440-67-7
630-20-6
79-34-5
79-00-5
, 75-34-3
87-61-6
9
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-5. Pollutants Not Selected as Pollutants of Concern for the Oils Subcategory
Pollutant
lA3-Trimethoxybcnzene
1,2,4,5-Tetrachlorobenzene
l,2-Dibromo-3-Ch!oropropane
1 ,2-Dibromoe thane
1 ,2-Dichloropropane
1^2-Diphcnylhydraane
l,2:3,4-Diepoxy butane
1,3,5-Trithhne
1,3-Butadiene, 2-Chloro
l,3-Dichloro-2-PropanoI
1 ,3-DichIorobenzene
1,3-DichIoropropanc
1,4-Dinitrobcnzenc
1,4-Naphthoquinone
1 ,5-Naphthalcncdiamine
l-Bromo-2-Chlorobenzene
l-Bromo-3-Chlorobcnzene
l-CWoro-3-Nitrobenzene
l-Naphthylamine
1 -Phcnylnaphthalene
2,3,4,6-TctrachIorophcnoI
2,3,6-Trichlorophenol
2,3-Dichloroaniline
2,3-DichIoronitrobenzene
2,4,5-Trichlorophenol
2,4,6-TrichlorophenoI
2,4-DichIorophcno!
2,4-Dinitrophenol
2,4-DinitrotoIuenc
2,6-Di-Tcrt-Butyl-P-Bcnzoquinone
2,6-DichIoro-4-Nitroaniline
2,6-Dichlorophenol
2,6-Dinitrotoluene
2-(methyIthio)benzothJ azoic
2-Chlorocthylvinyl Ether
2-ChloronaphthaIene
2-Chlorophcnol
2-Hcxanonc
2-Mcthylbcnzothioazole
2-Nitroanilinc
2-Nitrophenol
2-PhcnyInaphthalcne
2-Picolinc
2-Propcn-l-Ol
2-Propenal
2-Propcncnitrile, 2-Methyl-
3,3'-Dichlorobenzidine
3,3-Dimcthoxybenzidine
Cas No.
634-36-6
95-94-3
96-12-8
106-934
78-87-5
122-66-7
1464-53-5
291-214
126-99-8
96-23-1
541-73-1 '
142-28-9
100-254
130-154
2243-62-1
694-804
108-37-2
121-73-3 '
13432-7-'.
605-02-7
58-90-2
933-75-5
608-27-5
3209-22-1
95-954
88-06-2
120-83-2
51-28-5
121-14-2
719-22-2
99-30-9
87-65-0
606-20-2
615-22-5
110-75-8
91-58-7
95-57-8
591-78-6
120-75-2
88-744
88-75-5
612-94-2
109-06-8
107-18-6
107-02-8
126-98-7
91-94-1
119-904
Never Detected Detected in < 10%
Detected <10 x BV of infuent
samples
X
X
x
X
x '
x
x
x
x
x
X
X
X ' ' . '
X
X
X
X
X"
x-
x
X
X
X
X
X
X
X
X
x
X
X
X
X .
X
X
X
X
X
X
X
X
X
X
x
X
X
X
X
6-18
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-5. Pollutants Not Selected as Pollutants of Concern for the Oils Subcategory
Pollutant
3-Methylcholanthrsne
3-Nitroaniline
4,4'-Methylenebis(2-Chloroaniline)
4,5-Methylene Phenanthrene
4-Aminobiphenyl
4-Bromophenyl Phenyl Ether
4-CMoro-2-Nitroaniline
4-ChlorophenyIphenyl-Ether
4-NitrophenoI
5-Nitro-o-Toluidine
7, 12-Dimethylbenz(a)anthracene
Acenaphthylene
Acetophenone
Acrylonitrile
Aniline, 2,4,5-Trimethyl-
Aramite
Benzanthrone
Benzenethiol
Benzidine
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Benzonitrile, 3,5-Dibromo-4-Hydroxy-
Beta-Naphthylamine
Biphenyl, 4-Nitro
Bis(2-Chloroethoxy)methane
Bis(2-Chloroethyl) Ether
Bis(2-Chloroisopropyl) Ether
Bromodichloromethane
Bromomethane
Chloroacetonitrile
Chloroethane
Chloromethane
Cis- 1 ,3-Dichloropropene
Crotonaldehyde
Crotoxyphos
Di-n-Butyl Phthalate
Di-n-Octyl Phthalate
Di-n-Propylnitrosamine
Dibenzo(a,h)anthracene
Dibromochloromethane
Dibromomethane
Diethyl Ether
Dimethyl Phthalate
Dimethyl Sulfone
Diphenylamine
Diphenyldisulfide
Fthane Pentachloro-
Never Detected Detected in <10%
CasNo. Detected <10xBV ofinfuent
samples
5649-5
99-09-2
101-144
203-64-5
92-67-1
101-55-3
89-63-4
7005-72:3
100-02-7
99-55-8
57-97-6
208-96-8
98-86-2
107-13-1
137-17-7
140-57-8
82-05-3
108-98-5
92-87-5 ,
50-32-8
' 205-99-2
191-24-2
207-08-9
1689-84-5
• 91-59-8
92-93-3
111-91-1
111-444
108-60-1
75-27-4
74-83-9
107-14-2
75-00-3
74-87-3
10061-01-5
4170-30-3
7700-17-6
84-74-2
117-84-0
621-64-7
53-70-3.
124-48-1
.74-95-3
60-2977
131-11-3
67-71-0
122-394
882-33-7
76-01-7
X
X
X
x •
X
X
X
X
X
X
_
X
X
X
X
X
x. •
-.
- .
X
X
X
X
X'
x •
X
X
X
X
X .
X
X
X
. x .
X
X
X
X
X
. X
X
X
X
. X- .
X
X
X
X
X
X
X
X
6-19
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-5. Pollutants Not Selected as Pollutants of Concern for the Oils Subcategory
Pollutant
Ethyl Cyanide
Ethyl Methacrylate
Ethyl Mcthancsulfonate
Ethylcnethiourea
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachlorocthanc
Hcxachloropropene
In Jeno( 1 ,2,3-Cd)pyrene
lodomethane
Isobutyl Alcohol
Isophorone
Isosafrolc
Longifolcne
Malachite Green
Mestranol
Mcthapyrilene
Methyl Methacrylate "
Methyl Mcthancsulfonate
n-Nitrosodi-n-Butylamine
n-Nitrosodicthylamine
n-Nitrosodimetbylamine
n-Nitrosodiphenylamine
n-Nitrosomcthylcthylamine
n-Nitrosomcthylphenylamine
n-Nitrosomorpholine
n-Nitrosopipcridine
n-Triacontane
Nitrobenzene
o-Anisidine
o-Toluidine, 5-Chloro-
p-Chloroaniline
p-Dimcthylaminoazobenzene
p-Nitroaniline
Pcntachlorobenzene
Pcntachlorophcnol
Perylcne
Phcnacctin
Phenol, 2-Methyl-4,6-Dinitro-
JPhcnothiazine
Pronamidc
Resorcinol
Safrolc
Squalcnc
Tctrachloromethane
Thianaphthene
Thioacetamide
Thmxnnthc-O-One '
Cas No.
107-12-0
97-63-2
62-50-0
9645-7
118-74-1
87-68-3
77-47-4
e 67-72-1
' 1888-71-7
193-39-5
74-88-4
78-83-1
78-59-1
120-58-1
475-20-7
569-64-2
72-33-3
91-80-5
80-62-6
66-27-3
924-16-3
55-18-5
62-75-9
86-30-6
10595-95-6
614-00-6
59-89-2
100-75-4
638-68-6
. 98-95-3
90-04-0
95-79-4
106-47-8
60-11-7
100-01-6
608-93-5
87-86-5
198-55-0
' 62-44-2
534-52-1
92-84-2
23950-58-5
108-46-3
94-59-7
7683-64-9
56-23-5
95-15-8
62-55-5
4Q7-77-R
Never Detected Detected in < 10%
Detected <10xBV ofinfuent
samples
x
X
x
x
x
x
x
x
x
x
x
x
X
.X
X
X
X
X
x , .
X
. X
x .
X
' x
X
X
X
X
X
X
X
x ' .
. X
X
X
X
X
X
x
X
X
X
X
X
X
X
X
X
X
6-20
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-5. Pollutants Not Selected as Pollutants of Concern for the Oils Subcategory
Never Detected Detected in < 10%
Pollutant CasNo. Detected <10xBV ofinfuent
samples
Toluene, 2,4-Diamino-. 95-80-7 • .X
Trans-1,2-Dichlorpethene 156-60-5 X
Trans- 1,3-Dichloropropene 10061-02-6 X
Trans-l,4-Dichlorp-2-Butene 110-57-6 X
Tribromomethane 75-25-2 X
Trichlorofluoromethane '' 75-69-4 X
Triphenylene 217-59-4 X
Vinyl Acetate 108-05-4 X
Vinvl Chloride ; - 75-01 -4 ' X
6-21
-------
Chapters Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-6. Pollutants Not Selected as Pollutants of Concern for the Organics Subcategory
Pollutant
CLASSICAL^ OR CONVENTIONALS
Oil & Crease
METALS
Beryllium
Bismuth
Cadmium
Cerium
Dysprosium
Erbium
Europium
Gadolinium
Gallium
Germanium
Gold
Hafnium
Holmium
Indium
Indium
Lanthanum
Lutctium
Magnesium
Mercury
Ncodymium
Niobium
Osmium
Palladium
Platinum
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Selenium
Silver
Tantalum
Tellurium
Terbium
Thallium
Thorium
Thulium
Tungsten
Uranium
Vanadium
Ytterbium
Yttrium
Zirconium
ORGANICS
1,2,3-Trichlorobenzene
1 ?.^-Trimethoxvben7ene
Cas No.
C-007
7440-41-7
7440-69-9
744043-9
7440-45-1
7429-91-6
7440-52-0
7440-53-1
7440-54-2
7440-55-3
7440-564
7440-57-5
7440-58-6
7440-60-0
7440-74-6
7439-88-5
7439-91-0
7439-94-3
7439-95-4
7439-97-6
7440-00-8
7440-03-1
7440-04-2
7440-05-3
7440-06-4
7440-10-0
7440-15-5
7440-16-6
7440-18-8
7440-19-9
7440-20-2
7782-49-2
7440-22-4
7440-25-7
13494-80-9
7440-27-9
7440-28-0
7440-29-1
7440-304
7440-33-7
7440-61-1
7440-62-2
7440-644
7440-65-5
7440-67-7
87-61-6
6^4-^6-6
Never Detected Detected in < 10%
Detected <10 x BV of infuent samples
X
X
X
X
X
X
X
X
x
X
X
X "
X
X
X
X
X
X
x
X . .
"X"
X
X
X
x
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X •
X
X
X
X
X
X
6-22
-------
Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-6. Pollutants Not Selected as Pollutants of Concern for the Organics Subcategory
Pollutant
1,2,4,5-Tetrachlorobenzene
1 ,2,4-Trichlorobenzene
l,2-Dibromo-3-Chloropropane
1 ,2-Dichloropropane
1 ,2-Diphenylhydrazine
l,2:3,4-Diepoxybutane
1,3,5-Trithiane
1,3-Butadiene, 2-Chloro
l,3-Dichloro-2-Propanol
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1 ,4-Dinitrobenzene
1,4-Dioxane
1 ,4-Naphthoquinone
1 ,5-Naphthalenediamine
l-Bromo-2-ChIorobenzene
l-Bromo-3-ChIorobenzene-
l-Chloro-3-Nitrobenzene -
1-Methylfluorene - -
1-Methylphenanthrene
1-Naphthylamine
l-Phenylnaphthalene
2,3,6-Trichlorophenol
2,3-Benzofluorene •
2,3-Dichloronitrobenzene
2,4-Dichlorophenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Di-Tert-Butyl-P-Benzoquinone
2,6-DichIoro-4-Nitroaniline
2,6-Dichlorophenol
2,6-Dinitrotoluene
2-(Methylthio)Benzothiazole
2-Chloroethylvinyl Ether
2-ChloronaphthaIene
2-Chlorophenol
2-Hexanone
2-Isopropylhaphthalene
2-MethylbenzothioazoIe
2-Methylnaphthalene
2-NitroaniIine
2-Nitrophenol
2-PhenyInaphthalene
2-PicoIine
2-Propen-l-Ol
2-Propenal
2-Propenenitrile, 2-Methyl-
2-Syringaldehyde
3,3'-DichIorobenzidine
Cas No.
95-94-3
120-82-1
96-12-8
78-87-5
122-66-7
1464-53-5
291-21-4
126-99-8
96-23-1
541-73-1
106-46-7
100-25-4 .
123-91-1
130-15-4
2243-62-1
694-80-4
108-37-2
121-73-3
1730-37-6
832-69-9
134-32-7 '
605-02-7
933-75-5
243-17-4
3209-22-1
120-83-2
51-28-5
121-14-2
719-22-2
99-30-9
87-65-0
. 606-20-2
615-22-5
110-75-8
91-58-7
95-57-8
591-78-6
2027-17-0
120-75-2 '
91-57-6
88-7^4
88-75-5
612-94-2
109-06-8
107-18-6
107-02-8
126-98-7
134-96-3
91-94-1
I 19 QO-4
Never Detected Detected in <10%
Detected <10xBV of infuent samples
X
X
X
X
X
X
X
X
x . .•'.'..-.
X
X
X-
x •
X ,
X
X •
X
X
X "
X
X
"X* •-....
X
X -
X
X
X
X
X
X
X
X
x . .
X
X
X
X
X
-x
x • • •
X '
x' • ' ' . .
X .
X
X
X -• "
X
X
X
x
6-23
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-6. Pollutants Not Selected as Pollutants of Concern for the Organics Subcategory
Pollutant
3,4,5-TrichloroguaiacoI
3,5-Dichlorocatecbol
3, 6-DimethyIphenan throne
3-Chloropropene
3-Mcthylcholanthrene
3-Nitroaniline
4,4'-Mcthylenebis(2-Chloroaniline)
4,5-DichIorocatechol
4,5-Mcthylcne Phenanthrene
4,6-Dichloroguaiacol
4-Aminobiphenyl
4-Bromophenyl Phenyl Ether
4-ChIoro-2-Nitroaniline
4-Chloroguaiacol
4-Chlorophcnylphenyl Ether
4-NitrophenoI
5,6-DichlorovanilIin
5-Nitro-o-Toluidine
7,12-Dimethylbcnz(a)anthracene
Accnaphthene
Accnaphthylcne
Acrylonitrile
Alpha-TcrpineoI
Aniline, 2,4,5-TrimethyI-~
Anthracene
Aramite
Benzanthrone
Benzeoethiol
Bcnzidinc
Benzo(a)anthracene
Benzo(a)pyrcne
Bcnzo(b)fluoranthene
Bcnzo(ghi)pcrylene
Bcnzo(k)fluoranthene
Benzonitrilc, 3,5-Dibromo-4-Hydroxy-
Bcnzyl Alcohol
Beta-Naphthylamine
Biphcnyl
Biphenyl,4-Nitro
Bis(2-Chloroethoxy)methane
Bis(2-Ch!oroethyl) Ether
Bis(2-Chlo"roisopropyl) Ether
Bis(2-Ethylhcxyl) Phthalate
Bromomcthane
Butyl Benzyl Phthalate
Carbazolc
Chloroacctonitrile
Chlorocthanc
Chloromethane
-Chrvsenr
CasNo.
57057-83-7
13673-92-2
1576-67-6
107-05-1
56-49-5
99-09-2 .
101-14-4
3428-24-8
203-64-5
16766-31-7
92-67-1
101-55-3
89-63-4
16766-30-6
7005-72-3
100-02-7
18268-69-4
99-55-8
57-97-6
83-32-9
208-96-8
107-13-1
98-55-5
137-17-7 .
120-12-7
140-57-8
82-05-3
108-98-5
92-87-5
56-55-3
50-32-8
205-99-2
191-24-2
207-08-9
1689-84-5
100-51-*
91-59-8 .
92-52-4
92-93-3
111-91-1
11W4-4
108-60-1
117-81-7
74-83-9
85-68-7
86-74-8
107-14-2
75-00-3
74-87-3
71R-01-Q
Never Detected Detected in < 10%
Detected <10 x BV of infuent samples
x , •
x •
X
X
X
X
X
.X
X
X
X
X'
X
X
'x
X
X
x
X
X
X
X
X '
X
X
X
X
X
X
X . • •'
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X .
X
X
X
X
X
6-24
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-6. Pollutants Not Selected as Pollutants of Concern for the Organics Subcategory
Pollutant
Cis- 1 ,3-Dichloropropene
Crotonaldehyde
Crotoxyphos
Di-n-Butyl Phthalate
Di-n-OctylPhthalate
Di-n-Propylnitrosamine
Dibenzo(a,h)anthracene
Dibenzofuran
Dibenzothiophene
Dibromochloromethane
Dibromomethane
Diethyl Ether
Diethyl Phthalate
Dimethyl Phthalate
Diphenyl Ether
Diphenylamine
Diphenyldisulfide
Ethane, Pentachloro-
Ethyl Cyanide
Ethyl Methacrylate
Ethyl Methanesulfonate
Ethylbenzene
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloropropene
Indeno( 1 ,2,3-Cd)pyrene
lodomethane
Isobutyl Alcohol .
Isosafrole
Longifolene
Malachite Green
Mestranol
Methapyrilene
Methyl Methacrylate
Methyl Methanesulfonate
n-Decane
n-Docosane
n-Dodecane .
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Nitrosodi-n-Butylamine
n-Nitrosodiethylamine
n-Nitrosodimethylamine
n-Nitrosodiphenylamine
n-Nitrosomethylethylamine
n-Nitro^omethvlTilienvlfirninp
Cas No.
10061-01-5
. 4170-30-3
77CKM7-6
84-74-2
117-84-0
621-64-7
53-70-3
132-64-9
132-65-0
124-48-1
74-95-3
60-29-7
84-66-2
131-11-3
101-84-8
122-39-4
882-33-7
76-01-7
107-12-0
97-63-2
6250-0.
10041-4
206-44-0
86-73-7
118-74-1
87-68-3
77-47-4
1888-71-7
193-39-5
74-88-4
78-83-1
120-5&1
475-20-7
569-64-2
72-33-3
91-80-5
80-62-6
66-27-3
124-18-5
629-97-0
112-40-3
112-95-8
630-01-3
544-76-3
924-16-3
55-18-5
62-75-9
86-30^
10595-95-6
614-00-6
Never Detected Detected in <10%
Detected <10 x BV of infuent samples
X
X
X
X . '
X
X
X
x
X
x ' -
X
X
x •
X
X
x •
x
X
X
X
X . -
x , _,_ . , .
. X
X
X
X
X
X ,
X
X
X
X
X
x
X
X
X
X
X
X
X
x •
X
X
X
x
X
X
X
x. • • '
6-25
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-6. Pollutants Not Selected as Pollutants of Concern for the Organics Subcategory
Pollutant
n-Nitiosomorpholine
n-Nitrosopipcridine
n-Octacosane
n-Octadccane
n-Tetracosane
n-Tetradccanc
n-Triacontane
Naphthalene
Nitrobenzene
o-Anisidine
o-Toluidinc
o-Toluidine, 5-Chloro-
p-Chloroanilinc
p-Cymcne
p-Dimethylaminoazobenzene
p-Nitroaniline
Pcntachlorobenzene
Pcntamcthylbcnzene
Pciylcne
Phenacctin
Phcnanthrene
Phenol, 2-MethyI-4,6-Dinitro-
Phcnothiazine
Pronamide
Pyrene
Rcsorcinol
Safrolc
Squalene
Styrcnc
Tetrachlorocatechol
Tetrachloroguaiacol
Thianaphthcnc
Thioacctamide
Thioxanthe-9-Onc
Toluene, 2,4-Diamino-
Trans-l,3-Dichloropropene
Trans-l,4-Dichloro-2-Butene
Tribromomcthane
Trichlorofluoromethane
Trichlorosyringol
Triphcnylcne
Tripropylencglycol Methyl Ether
Vinvl AccMti>
Cas No.
59-89-2
100-75-4
630-02-4
593-45-3
646-31-1
629-59-4
638-68-6
91-20-3
98-95-3
90-04-0
95-53^
95-79-4
10fr47-8
99-87-6
60-11-7
100-01-6
608-93-5
700-12-9
198-55-0
62-44-2
8S-01-8-
534-52-1
92-84-2
23950-58-5
129-00-0
108-46-3
94-59-7
7683-64-9
100^2-5
1198-55-6
2539-17-5
.95-15-8
62-55-5
492-22-8
95-80-7
10061-02-6
110-57-6
75-25-2
75-69-4
2539-26-6
217-59-4
20324-33-8
inR-rvui-
Never Detected Detected in <10%
Detected <10xBV of infuent samples
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X . ,
X
X .
X--
X
X
X
X
X
X
X
X
X
x •
X
X
X
X
X
X .
X
X
X
X
X
V
6-26
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
POLLUTANTS OF CONCERN FOR THE
METALS SUBCATEGORY
6.2
Wastewaters treated at CWT facilities in the
metals subcategory contain a range of
conventional, toxic, and non-conventional
pollutants. EPA analyzed influent samples for
320 conventional, classical, metal, and organic
pollutants. EPA identified 78 pollutants of
concern, including 41 metals, 20 organics, and
17 classical and conventional pollutants as
presented in Table 6-1 and including pH. EPA
excluded 242-pollutants from further.? review
because they did not pass the pollutant of"
concern criteria. Table 6-4 lists these pollutants,
including 167 pollutants that were never detected
at any sampling episode, 19 pollutants that were
detected at a concentration less than ten times
the baseline value, and 56 pollutants that were
present at treatable levels in less than ten percent
of the influent samples. EPA selected only 24
percent of the .list of pollutants analyzed as
pollutants of concern, and as expected, the
greatest number.of pollutants of-concern in the
metals subcategory were found in the metals
group.
Facilities in the metals subcategory had the
highest occurrence and broadest-range of metals
detected in their raw wastewater. The sampling
identified a total of 41 metals/semi-metals above
treatable levels, compared to 31 metals/semi-
metals in the oils subcategory, and 25 metals in
the organics subcategory. Maximum metals
concentrations in the metals subcategory were
generally at least an order of magnitude higher
than metals in the oils and organics
subcategories, and were often two to three
orders of magnitude greater. Wastewaters
contained significant concentrations of common
non-conventional metals such as aluminum, iron,
and tin. In addition, given the processes
generating these Wastewaters, waste receipts in
this subcategory generally contained toxic heavy
metals. Toxic metals found in the highest
concentrations were cadmium, chromium,"
cobalt, copper, nickel, and zinc. •
EPA detected four conventional pollutants
(BOD5, TSS, oil and grease, and pH) and 13
classical pollutants above treatable levels in the
metals subcategory, including hexavalent
chromiuni, which was not found at treatable
levels in the oils subcategory (EPA did not obtain
any data on hexavalent chromium for the
organics subcategory).
Concentrations for total cyanide, chloride,
fluoride, nitrate/nitrite, TDS, TSS, 'and total
sulfide were significantly higher for metals
'facilities than for " facilities in, the other
subcategories (EPA did not obtain any data on
chloride and TDS for the organics subcategory).
While sampling showed organic pollutants at
selected facilities in the metals subcategory, these
were not typically found in wastewaters resulting
from this subcategory. Many-metals- facilities-
have placed acceptance restrictions on the
concentration of organic pollutants allowed in the
off-site wastestreams. Of the 233 organic
pollutants analyzed in the metals subcategory,
EPA only detected 20 in more than 10 percent of
the samples, as compared to 73 in the oils
subcategory and 58 in the organics subcategory.
However, of the organic compounds detected in
the metals subcategory, only one, specifically,
dibromochloromethane, was not detected in any
other subcategory. EPA sampling detected all
other organic pollutants in the metals subcategory
at relatively low concentrations, as compared to.
the oils and organics subcategories. •
POLLUTANTS OF CONCERN FOR THE OILS
SUBCATEGORY
6.3
As detailed in Chapters 2 and 12, EPA does
not have data to characterize raw wastewater for
the oils subcategory. Therefore, EPA based its
influent wastewater characterization for this
subcategory on an evaluation of samples
obtained following the initial gravity
separation/emulsion breaking step. EPA
6-27
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
analyzed these samples for 321 conventional,
classical, metal, and organic pollutants. EPA
identified 118 pollutants of concern, including 73
organics, 31 metals/semi-metals, 13 classicals,
and four conventional pollutants, pH plus the
three presented in Table 6-2. EPA eliminated
202 pollutants after applying its criteria for
selecting pollutants of concern. Table 6-5 lists
these pollutants, including 145 pollutants that'
were never detected at any sampling episode, 17
pollutants that were detected at a concentration
less than ten times the baseline value, and 40
pollutants that were present at treatable levels in
less than ten percent of the influent samples.
EPA selected slightly more than 30 percent of
the list of pollutants analyzed as pollutants of
concern, the majority of which were organic
pollutants.
Facilities in the oils subcategory had the
broadest spectrum of pollutants of concern in
their raw wastewater—with 4 conventional
pollutants, 13 classical pollutants, and more than
100 organics and metals/semi-metals. As
expected, oil and grease concentrations in this
subcategory were significantly higher than for the
other subcategories, and varied greatly from one
facility to the next, ranging from 37.5 mg/L to
180,000 mg/L (see Table 6-2) after the first
stage of treatment. The concentrations of
ammonia, BOD5, COD, TOC, total phenols, and
total phosphorus were also higher for facilities in
the oils subcategory.
Wastewaters contained significant
concentrations of both non-conventional and
toxic metals such as aluminum, boron, cobalt,
iron, manganese, and zinc. EPA's sampling data
show most pollutant ,of concern metals were
detected at higher concentrations in the oils
subcategory than those found in the organics
subcategory, but at significantly lower
concentrations than those found in the metals
subcategory. Germanium and lutetium were the
only metals/semi-metals detected at a treatable
level in the oils subcategory but not in one or
both of the other two subcategories.
Of the 73 organic pollutants selected as
pollutants of concern in the oils subcategory, 43
were not present at treatable levels in the other
two subcategories. Twenty seven pollutants of
concern organics were common to both the oils
and organics subcategories, but more than half of
these organics were detected in oily wastewater
at concentrations "one to three orders • of
magnitude higher than those found in the
organics subcategory wastewaters. Organic
pollutants found in the highest concentrations
were straight chain hydrocarbons such as. n-
decane andn-tetradecane, and aromatics such as
naphthalene and bis(2-ethylhexyl)phthalate.
EPA also detected polyaromatic hydrocarbons,
such as fluoranthene in the wastewaters of oils
faculties.
In the 1999 proposal, EPA had identified
benzo(a)pyrene as a pollutantof concern for the"-
oils subcategory. After further evaluation of the
laboratory reports,2 EPA corrected some
reported amounts, for benzo(a)pyrene. After
these corrections were made to the database,
benzo(a)pyrene failed to meet EPA's criteria to
be a pollutant of concern.
POLLUTANTS OF CONCERN FOR THE
ORGANICS SUBCA TEGORY
6.4
Wastewaters treated at CWT facilities in the
organics subcategory contain a range of
conventional, toxic, and non-conventional
pollutants. EPA analyzed influent samples for
334 classical, metal, and organic pollutants. EPA
identified 93 pollutants of concern, including 58
organic pollutants, 25 metals/semi-metals, 8
classicals, and 3 conventional pollutants, pH plus
the two presented in Table 6-3. EPA excluded
240 pollutants because they did not pass the
pollutant of concern criteria. Table 6-6 presents
these pollutants, including .214 pollutants that
were never detected at any sampling episode,
2For more details, see DCN.
record for this rule.
in the
6-28
-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
and 26 pollutants that were detected at a
concentration less than ten times the baseline
value. EPA determined that only 28 percent of
the list of pollutants analyzed were pollutants of
concern.
As expected, wastewaters contained
significant concentrations of organic parameters,
many of which were highly volatile. However,
although EPA analyzed wastewater samples in
the organics subcategory for a more extensive list
of organics than samples in the metals or oils
subcategories, EPA selected only 23 percent of
those organic pollutants analyzed as pollutants of
concern. EPA selected as pollutants of concern
a total of 58 organics in the influent samples
analyzed. Thirty one of these organics were
present in the organics subcategory but not in the
oils subcategory. EPA determined that the
remaining 27 organics were pollutants of concern
for both the organics and oils subcategories.
EPA's sampling detected only six of these
organic pollutants at higher concentrations at
organics facilities, specifically, chloroform,
methylene chloride, o-cresol, tetrachloroethene,
trichloroethene, and 1,2-dichloroethane. EPA
determined that only eight classical pollutants
were pollutants of concern for this subcategory,
and most of these were detected at lower
concentrations than those found in the metals
and oils subcategories.
The sampling detected a total of 25
metals/semi-metals above treatable levels, but
these were present at concentrations significantly
lower than in the metals subcategory. EPA's
assessment showed that only five pollutant of
concern metals/semi-metals (barium, calcium,
iodine, lithium, and strontium) were detected at
concentrations above those found hi the oils
subcategory.
6-29
-------
-------
Chapter
POLLUTANTS SELECTED FOR REGULATION
hapter 6 details the pollutants of concern for
ch subcategory and the methodology
used in selecting the pollutants. As expected for
the CWT industry; these pollutants-of concern
lists contain a broad spectrum of pollutants.
EPA has, however, .chosen not.to.regulate all of.
these parameters;- This'chapter details the
pollutants of concern which were not selected for
regulation under each technology option selected
as the basis for the final Hmitations and standards
and provides a justification for eliminating these
pollutants (the technology options are detailed in
Chapter 9). Additionally, Figures 7-1 and 7-2
illustrate the procedures used to select the
regulated pollutants for direct and indirect
dischargers.
TREATMENT CHEMICALS
7.1
EPA excluded all pollutants which may serve
as treatment chemicals: aluminum, boron,
calcium, chloride, fluoride, iron, magnesium,
manganese, phosphorus, potassium, sodium, and
sulfur. EPA eliminated these pollutants because
regulation of these pollutants could interfere with
their beneficial use as wastewater treatment
additives.
NON-CONVENTIONAL BULK PARAMETERS 7.2
EPA excluded many non-conventional bulk
parameters such as total dissolved solids (TDS),
chemical oxygen demand (COD), organic carbon
(TOC), nitrate/nitrite, SGT-HEM, total phenols,
total phosphorus, and total sulfide. EPA
excluded these parameters 'because it is more
appropriate to target specific compounds of
interest rather than a parameter which measures
a variety of pollutants for this industry. The
specific pollutants which comprise the bulk
parameter may or may not be of concern to
EPA.
POLLUTANTS NOT DETECTED AT
TREATABLE LEVELS
7.3
EPA eliminated pollutants that were present
below treatable concentrations in wastewater
influent to the treatment system(s) selected as
the basis for effluent limitations. EPA evaluated
the data at each sampling episode separately.
Section 10.4.3.1 describes this data editing
criteria in greater detail and pjovides an example.
Briefly,.thisprocedure,was nicknamed the "long--
term average test" and«-was-performed- as-
follows. For a pollutant to be retained, the
pollutant first had to be detected at any level in
the influent samples at least 50 percent of the
time during any sampling episode. The pollutant
also had to be detected in the influent samples at
treatable levels (ten times the baseline value1) in
at least fifty percent of the samples; or b) the
mean of the influent samples for the entire
facility had to be greater than or equal to ten
times the baseline value. EPA added the second
condition to account for instances where a slug
of pollutant was treated during the sampling
episode. EPA added this condition since the
CWT industry's waste receipts vary daily and
EPA wanted to incorporate these variations in
the calculations of long term averages and
limitations. Pollutants excluded from regulation
for the selected subcategory options because
they were not detected at treatable levels are
presented in Table 7-1.
'See Chapter 15 for a description of
baseline values.
7-1
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
POCIist
JiPOCatrtatnunt
ItfOCa.
naH.-conasentttstu3.bulk
traattdqffactt>xfyet
PZ/EATfcrctft
ash&a srffbw
Itmitaitons ara
et
aiigft&lctmt
Aettmeat feliictsdBPTfacStt
~
Etnct
Fes
POCvOi notbe restated for A t
tubcatesxy
Yes
fOCvOlnntbereffdatedforiUp
rakcatagary
Far
mbsatofary
Figure 7-1. Selection of Pollutants That May Be Regulated for Direct Discharges for Each Subcategory
7-2
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
KaguLatedPolhilnyits
fer&reet DbcJiar&tt
Yet
POCwtiL not la ragMadfe
Figure 7-2. Selection of Pollutants to be Regulated for Indirect Discharges for Each Subcategory
7-3
-------
1
c
1
43
cd
to
•"3-
•&-
§
CO
I
•2
&
5
'S
I
1 -
*o
c
O
CO
•55
•S -2
4^
-------
POLLUTANTS NOT TREATED
7.4
EPA excluded all pollutants for which the
selected technology option was ineffective (i.e.,
pollutant concentrations remained the same or
increased across the treatment system). For the
organics subcategory, the selected treatment
technology did not effectively treat chromium,
lithium, nickel, and tin. For the oils subcategory,
phenol in option 8 and 2-propane in options 8
and 9 were not effectively treated. For the
metals subcategory, all pollutants of concern at
treatable levels were effectively treated.
VOLA TILE POLLUTANTS
7.5
EPA detected volatile organic pollutants in
the waste receipts of all three subcategories. For
this rule, EPA defines a volatile pollutant as a
pollutant which has a Henry's Law constant in
excess of 10"4 atm-m- mot1.-' For each
subcategory, Table 7-2 lists., the organic-
pollutants (those analyzed using method 1624 or
1625) and ammonia with their Henry's-Law
constant For pollutants in the oils subcategory,
the solubility in water was reported in addition to
the Henry's Law constant to_determine-whether
volatile pollutants remained in the oil-phase or
volatilized from the aqueous phase. If no data
were available on the Henry's Law constant or
solubility for a particular pollutant, then the
pollutant was assigned an average pollutant group
value. Pollutant groups were developed by
combining pollutants with similar structures. If
no data were available for any pollutant in the
group, then all pollutants in the group were not
considered volatile. The assignment of pollutant
groups is discussed in more'detail in Section
7.6.2.
7-5
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
POC List for Oils Subcategory )'
Is the pollutant organic?
Is the pollutant's
solubility in water £-10 BV?
(=100 ug/L)
Does the
pollutant have a Henry's Law
constant > 10*
(atm*n?)/mol?
Pollutant is volatile
The pollutant is not volatile
Pollutant is in oily phase
and not volatile
Pollutant is not volatile
Figure 7-3. Determination of Volatile Pollutants for Oils Subcategory
7-6
-------
••
>->
§>
ta
o
00
pa
u
••g
co
CH
a
"o
P-.
w
"«
1
oi
t~-
1
t~*
JS %
_0
•J3
ea
1 0.
*
3 ^ I1
li
W OT W CO , W C/3 CQCQ.Q
s g s s g s s s g s „ s s 0
^^?>^^>.^^><^>,>,>>c
§ :
£X
P
S
0
ut O O CM v^
OL CN . CM (S 0)
^ m CM ro ' rn ~^ - — ' vi
•f""i ^p ^5 ^3 f"^ ^p ^3 ^5
ea @s ' s • s s s
CO CM ^-" "^" vD Ox ON C^
r^^-* CM^l" OO i— < t-^ CM
S S SS S SS SS S S'SS
tL] i ti til E^ p!r~ PIT' W** E£T~f*]~ C& ~&T fi £3
CN^S°SoSoON2;2rn2. °
•^j- uS — * m_ ,rn. ,^^ . csV ^^ as. CM CM rn CM
.
XXXX'XX XX X
XX XX XX XXX
XX X
j3jjC5'^8
r-2 fi rG 10 t^ f*"i ?^ ^^ JT\ ^^ ^R CM ^3 • S2
s
o> « o a>
g °vc w rtc
1 1 J J" "§ J H J ^ J i- J S
£3 »fi 2 2 -»2 2.— c;22-§c>24>
I1 11 1 1 '1 ^. "| M 1 1 "1 "1 1 |
S S -1« ^ ^ — T ^ CM CM CM CM** CM" TJ* -9
« — . W CO ' «
o 2 ^
MOMOMO3COO w ^
?N >» >» >* >^ >v >
g g
& . • £
F
2 c
0 C
»n
CM
? ? • i
s a £
VO CM CN
c-i - .
SS S S S S V T
[i3 ~W i J i 'W^'Ei fi ti S i S i
g S 5?' ^ ^8 CM o. T* 5? 71- ?\
[**• CN *"* rO CM "^T
• X X XXXXXX
X X X X X
X
v,^-^^«o^^^^^^w
SSSSSSSsoSSSvc
'V ^c
v?T^i.Pifi.c^T;rc"lc"5SiA^
EnST^^SaNof--^^^
O\ ^3 *^" ^^ ^^ S^ O^ OO ON ^^ ^^ "^
«-i
a
"3 |
§ 'o _c
g •_'•§, "o "3 •§ 'S
^ |--|j^-n.-n.§l|j
^3 OS *O< *J"' O O »S P *S C
2 S **-! 2 ,-gj* ,fc "73 *^a ^ "S ^ ^c
I1 §. I 1 | 3 '£ ^ 1 '|, 1 J
C &, m m ^j- t
-------
g g g I
g g g
- '
t
I
s
I
I
o
fO CO
? ?
» W M
« CM o
°y T ""!
—H CO «S
- s-;
I §..$
•*i m
So o
i' (il «
XX X XX X X
X
X XX XX XXXXXXXX'XX.XXXXX X
X
X
X
XX
.X
in m -<4- u-i if) tn CM
CM CM CM CM CM CM O
vo vo vo vo vo vo in
S
cs co o *
-------
31 §
f
•s
C3 c*i
b
I
11
§•
2
8BB
§•§•§•
c§.<§^
O
0.
C
I
C
*
•
—3 CM en "
CQ
o
p-
o
r-
§>
I
.£>
"
x
xxx
xxxx
XX XXXXXXXXXXXXXX XX X X X X X X
X
O
-------
.gs
— ^r
J9 O
1 1
C-.
O
CM
r-;c>
.
o
oo o «n ^H —<
o o o oo
£>
o
f
1
00
m"
5
x ;*: xxxxx ><
XXXXXX X XX
X
X
<2
a> *-
e jg
I!
o o
•?
CM
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
As shown in Table 7-2, volatile pollutants
were regularly detected at treatable levels in
waste receipts from CWT facilities, particularly
in the oils and organics subcategory. An "X" in
a subcategory column indicates that the analyte
was detected at treated levels and not previously
eliminated in sections 7.2 through 7.4. However,
treatment technologies currently used at many of
these facilities, while removing the pollutants
from the wastewater, do not'treat" the volatiles.
The. volatile pollutants are simply transferred to .
the air. For examplerin the metals subcategory,
wastewater treatment technologies are generally
based on chemical precipitation, and the removal
of volatile pollutants from wastewater following
treatment with chemical precipitation is due to
volatilization. Some CWT facilities recognize
that volatilization may be occurring, and have
installed air stripping systems equipped with
emissions, control to- effectively remove- the- ••
pollutants from both the water and the air.
EP Aevaluated various wastewater treatment
technologies during the development of this rule.
These technologies were considered because of
their efficacy in removing pollutants from
wastewater. Since EPA is concerned about
removing pollutants from all environmental
media, EPA also evaluated wastewater treatment
trains for the oils and organics subcategories
which included air stripping with emissions
control.
EPA did not regulate any predominantly
volatile parameters. The non-regulated volatile
parameters for the metals, organics, and oils
subcategory options that were not already
excluded as detailed in Sections 7.1, 7.2, 7.3,
and 7.4 are presented in Table 7-3. Unlike the
metals and the organics subcategories, for the
oils subcategory, volatilization can not be
predicted using the Henry's Law constant only.
Henry's Law constants are established for
pollutants in an aqueous phase, only. For other
non-aqueous single phase or two-phase systems
(such as oil-water), other volatilization constants
.apply. Estimating these constants in oil-water
mixtures can lead to engineering calculations
which are generally based on empirical data.
EPA chose an approach which is depicted in
Figure 7-3 and discussed below. First, EPA
reviewed water solubility data to estimate
whether the organic pollutants would be
primarily in an oil phase or aqueous phase. For
pollutants which have a solubility less than ten
times the baseline value (the same edit used to
determine pollutants of concern and pollutants at
treatable levels), EPA assumed that the amount
-of-pollutants hi the aqueous phase would be
negligible_-and that all of the pollutant would be
primarily in an oil phase. For pollutants which
"have a solubility greater than ten times the
baseline value, EPA assumed that the amount of
pollutant in the oil phase would be negligible and
that all of the pollutant would be primarily in an -
aqueous phase. For pollutants determined to be
in an aqueous phase, EPA then reviewed the
'Henry's law constant in-the same-manner as the-
other two "subcategories. For pollutants
determined to be in an oil phase, EPA assumed
that volatilization would be negligible (regardless
of their volatility in the aqueous phase) and has
not categorized them as volatile pollutants.
Even though EPA has not regulated volatile
pollutants through this rulemaking, EPA
encourages all facilities which accept waste
receipts containing volatile pollutants to
incorporate air stripping with overhead recovery
into their wastewater treatment systems. EPA
also notes that CWT facilities determined to be
major sources of hazardous air pollutants are
subject to maximum achievable control
technology (MACT) as promulgated for, off-site
waste and recovery operations on July 1, 1996
(61 FR 34140) as 40 CFR Part 63.
7-11
-------
T-l1l
—i -ye> -a ^i--a gwS'cjTp
~£~
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for, the CWT Point Source Category
POLLUTANTS SELECTED FOR
PRETREATMENT STANDARDS AND
PRETREATMENTSTANDARDS FOR NEW
SOURCES (INDIRECT DISCHARGERS)
Background
7.6
7.6.1
Unlike direct dischargers whose wastewater
will receive no further treatment once it leaves
the facility, indirect dischargers send their
wastewater to POTWs for further treatment.
EPA establishes pretreatment standards for those
BAT pollutants that pass through POTWs.
Therefore, for indirect dischargers, before
establishing pretrearment standards, EPA
examines whether the pollutants discharged by-
the industry "pass through" POTWs to waters of.
the,U.S. or interfere with POTW operations or
sludge disposal practices. Generally, to
determine if,pollutants pass- through, POTWs,
EPA compares the percentage of the pollutant
removed~by well-operated POTWs achieving
. secondary, treatment with the percentage, of .the
pollutant removed by facilities meeting BAT
effluent limitations. A pollutant is determined to
"pass through" POTWs when the median
percentage removed by well-operated POTWs is
less than the median percentage removed by
direct dischargers complying with BAT effluent
limitations. In this manner, EPA can ensure that
the combined treatment at indirect discharging
facilities and POTWs is at least equivalent to that
obtained through treatment by direct dischargers.
This approach to the definition of pass-
through 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 POTWs 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 POTWs with the mass or
concentration of pollutants discharged by BAT
facilities, EPA compares the percentage of the
pollutants removed by BAT facilities to the
POTW removals. EPA takes this approach
because a comparison of the mass or
concentration of pollutants in POTW effluents
with pollutants in BAT facility effluents would
not take into account the mass of pollutants
discharged to the POTW from other industrial
and non-industrial sources, nor the dilution of the
pollutants in the POTW to lower concentrations
from the addition of large amounts of other
industrial and non-industrial water.
In selecting the regulated pollutants under the
pretrearment standards, EPA starts with the toxic
and non-conventional pollutants regulated for
direct dischargers under BAT. For this analysis,
EPA does not include the four regulated BPT
conventionalparameters, BOD5, total suspended
solids (TSS), oil and grease (measured as HEM),
and pH because POTWs are designed to treat
these parameters. Therefore^:- for this
rulemakingv EPA- evaluated-31- pollutants for
metals,option 4,_51 pollutants for oils option Pi-
arid 23 pollutants for Organics Option 4 for
PSES .and PSNS regulation. The following
sections describe the methodology used in-
determining median percent removals for the
BAT technologies, median percent removals for
"well-operated" POTWs, and the results of
EPA's pass-through analysis.
Determination of Percent Removals
for Well-Operated POTWs
7.6.2
The primary source of the POTW percent
removal data was the "Fate of Priority Pollutants
in Publicly Owned Treatment Works" (EPA
440/1-82/303, September 1982), commonly
referred to as the "50-POTW Study". However,
the 50-POTW Study did not contain data for all
pollutants for which the pass-through analysis
was required. Therefore, EPA obtained
additional data from EPA's National Risk
Management Research Laboratory's (NRMRL)
Treatability Database (formerly called the Risk
Reduction Engineering Laboratory (RREL)
7-13
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
Treatability Database). These sources and their
uses are discussed below.
The 50-POTW Study presents data on the
performance of 50 well-operated POTWs that
employ secondary biological treatment in
removing pollutants.
At the time of the 50-POTW sampling
program, which spanned approximately 2 '/£
years (July 1978 to November 1980), EPA
collected samples at selected POTWs across the.
U.S. The samples were subsequently analyzed
by either EPA or EPA-contract laboratories.
These samples were analyzed for 3 conventional,
16 non-conventional, and 126 priority toxic
pollutants using test procedures (analytical
methods) specified by the Agency or in use at
the laboratories. Laboratories typically reported
the analytical method used along.with the test
results. However, for those cases in which the-
laboratory specified no analytical method, EPA
was able to-identify the method.based on-the-
nature of the results and knowledge of the
methods available at the time.
Each laboratory reported results for" the'
pollutants for which it tested. If the laboratory
found a pollutant to be present, the laboratory
reported a result. If the laboratory found the
pollutant not to be present, the laboratory
reported either that the pollutant was "not
detected" or a value with a "less than" sign (<)
indicating that the pollutant was below that value.
The value reported along with the "less than"
sign was the lowest level to which the laboratory
believed it could reliably measure. EPA
subsequently established these lowest levels as
the minimum levels of quantisation (MLs). In
some instances, different laboratories reported
different MLs for the same pollutant using the
same analytical method.
Because of the variety of reporting protocols
among the 50-POTW Study laboratories (pages
27 to 30, 50-POTW Study), EPA reviewed the
percent removal calculations used in the pass-
through analysis for previous industry studies,
including those performed when developing the
CWT proposal and effluent guidelines for
Organic Chemicals, Plastics, and Synthetic
Fibers Manufacturing, Landfills, and Commercial
Hazardous Waste Combustors. EPA found that,
for 11 parameters, different analytical minimum
levels were reported for different rulemaldng
studies (9 of the 25 metals, cyanide, and one of
the 42 organics).
To provide consistency for data analylsis and
establishment of removal efficiencies, EPA
reviewed the 50-POTW Study, standardized the
reported MLs for use in the CWT final rules and
other ruflemaking efforts.
In using the 50-POTW Study data to
estimate percent removals, EPA has established
data editing criteria for determining pollutant
percent removals. Some of the editing criteria
are based on differences between POTW and
industry BAT treatment system influent
concentrations. For many toxic pollutants,
PO-TW influent concentrations were much lower
than those of BAT treatment systems. For many
pollutants, particularly organic pollutants, the
effluent concentrations from" both POTW and
BAT treatment systems, were below the level
that could be found or measured. As noted in
the 50-POTW Study, analytical laboratories
reported pollutant concentrations below the
analytical minimum level (ML), qualitatively, as
"not detected" or "trace," and reported a
measured value above this level. Subsequent
rulemaking studies such as the 1987 OCPSF
study used the analytical method ML established •
in 40 CFR Part 136 for laboratory data reported
below the analytical ML. Use-of the ML may
overestimate the effluent concentration and
underestimate the percent removal. Because the
data collected for evaluating POTW percent
removals included both effluent and influent
levels that were close to the analytical ML, EPA
devised hierarchal data editing criteria to exclude
data with low influent concentration levels,
thereby minimizing the possibility that low
POTW removals might simply reflect low
7-14
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
influent concentrations instead of being a true
measure of treatment effectiveness.
EPA has generally used hierarchic data
editing criteria for the pollutants in the 50-POTW
Study. For the final CWT rule, the editing
criteria include the following:
1) substitute the standardized pollutant-
specific analytical ML for values reported as
"not detected," "trace," "less than [followed
by a number]," or a number" less than the
standardized analytical ML,
2) retain pollutant influent and corresponding
effluent values if the average pollutant
influent level is greater than_or equal to 10
times the pollutant ML (lOxML), and
3) if none of the average pollutant influent
concentrations are at least 10 times the ML,
then retain average influent values greater
than or equal to two times the ML (2xML)_
along with the corresponding average
effluent values. (EPA used 2xML for the
final rule, instead of the 20 ug/1 criterion
used atproposaLbecause.it,.more accurately
reflects the pollutant-specific .data than using
a fixed numerical cut-off. For the majority
of pollutants 2xML is 20 ug/1. Therefore,
this correction does not affect the percent
removal estimates for most organic
pollutants. However, it affects the metal
pollutants because their MLs range from 0.2
to 5,000 ug/1.)
EPA then calculates each POTW percent
removal for each pollutant based on its average
influent and its average' effluent values. The
national POTW percent removal used for each
pollutant in the pass-through test is the median
value of all the POTW pollutant specific percent
removals.
Additionally, due to the large number of
pollutants of concern for the CWT industry,
EPA also used data from the National Risk
Management Research Laboratory (NRMRL)
Treatability Database to augment the POTW
database for the pollutants which the 50-POTW
Study did not cover. This database provides
information, by pollutant, on removals obtained
by various treatment technologies. The database
provides the user with the specific data source
and the industry from which the wastewater was
generated. For each pollutant of concern EPA
considered for this rule not found in the 50-
.POTW database, EPA used .data from' the
NRMRL database, using only treatment
technologies representative of typical POTW
secondary treatment operations (activated sludge,
activated sludge with filtration, aerated lagoons).
EPA further edited these files to include
information pertaining only to domestic or
industrial wastewater. EPA used pilot-scale and
full-scale data only, and eliminated bench-scale
data and data from less reliable references.
EPA selected the final percent removal for
each ^pollutant based on a data hierarchy, which
was related to the quality of the data-source.
The. following-data source, hierarchy was" used"
for selecting a percent removal for a pollutant: 1)
if available, the median percent removal from the
50-POTW Study was chosen using all POTWs
data with influent levels greater than or equal to
10 times the pollutant ML, 2) if not available, the
median percent removal from the 50-POTW
Study was chosen using all POTWs data with
influent levels greater than 2 times the pollutant
ML, 3) if not available, the average percent
removal from the NRMRL Treatability Database
was chosen using only domestic wastewater, 4)
if not available, the average percent removal
from the NRMRL • Treatability Database was
chosen using domestic and industrial wastewater,
and finally 5) a pollutant was assigned an average
. group percent removal, or "generic" removal if
no other data was available. Pollutant groups
were developed by combining pollutants with
similar chemical structures (a complete list of
pollutants and pollutant groupings are available in
Appendix A). EPA calculated the average group
percent removal by using all pollutants in the
group with selected percent removals from either
7-15
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
the 50-POTW Study or the NRMRL Treatability
Database. EPA then averaged percent removals
together to determine the average group percent
removal. Pollutant groups and generic removals
used in the pass-through analysis are presented in
Table 7-4. Only groups A (metals), J (anilines),
and CC (n-paraffins) are presented in Table 7-4
since these are the only groups for which EPA
assigned an average group percent removal in its
pass-through analysis. The final POTW percent
removal assigned to each pollutant is presented in
Table 7-5, along with the source and data
hierarchy of each removal.
7-16
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
Table 7-4. CWT Pass-Through Analysis Generic POTW Percent Removals
Pollutant
Group A: Metals
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Indium
Lead
Lithium
Mercury
Molybdenum
Nickel
Silver
Strontium
Thallium
Tin
Titanium
Vanadium
Yttrium _"
Zinc, ,
Zirconium
Average Group Removal
CAS NO.
7440-39-3
7440-41-7
7440-43-9
7440-47-3
7440-48-4
7440-50-8
7439-88-5
7439-92-1
7439-93-2
7439-97-6
7439-98-7
7440-02-0
7440-22-4
7440-24-6
7440-28-0
7440-31-5
7440-32-6
7440-62-2,,
7440-65-5
— - 7-4-40-66-6
7440-17-7
% Removal
55.15
61.23
90.05
80.33
10.19
84.20
74.00
77.45
26.00
90.16
18.93
51.44
88.28
14.83
53.80
42.63
91.82
8.28.
21.04
79.14-
55:95-
Source
50POTW-2XML
RREL5-(INDWW)
50 POTW -10 XML
50 POTW -10 XML
50POTW-2XML
50POTW-10XML
RREL 5 - (ALL WW)
50 POTW -10 XML
RREL 5- (ALL WW)
50POTW-10XML
50 POTW -10 XML
50 POTW -10 XML
50 POTW -10 XML
.RREL5-(DOMWW)-
RREL-5-(ALLWW)
50 POTW- 2 XML
50POTW-10XML
• 50,EOTW-2XML
50 POTW- 2 XML
"50 POTW - 10-X ML
Average Group Removal
.
•- • •• - .--.-.
Pollutant
Group J: Anilines
Aniline '
Carbazole
Average Group Removal
CAS NO.
62-53-3
86-74-8
% Removal
93.41
93.41
Source
RREL 5- (ALL WW)
Average Group Removal
Pollutant
Group CC: n-Paraffins
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octacosane
n-Octadecane
nrTetracosane
n-Tetradecane
Average Group Removal
CAS NO.
124-18-5
629-97-0
1 12-40-3
112-95-8
630-01-3
544-76-3
630-02-4
593-45-3
646-31-1
629-59-4
% Removal
9.00
88.00
95.05
92.40
71.11
Source
RREL 5- (ALL WW)
RREL 5- (ALL WW)
RREL 5- (ALL WW)
RREL 5- (ALL WW)
Average Group Removal
Average Group Removal
Average Group Removal
Average Group Removal
Average Group Removal
Average Group Removal .
7-17
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
Table 7-5. Final POTW Percent Removals
Pollutant
CLASSICAL
Ammonia as N
Hexavalent Chromium
Total Cyanide
METALS
Antimony
Arsenic
Barium
Beryllium •
Cadmium
Chromium
Cobalt
Copper
Indium
Lanthanium
Lead
Lithium
Mercury
Molybdenum
Nickel"
Osmium
Selenium
Silicon
Silver
Strontium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Zirconium
ORGANICS
2-butanone
2-propanone
2,3-dichloroaniline
2,4,6-trichlorophenol
4-chloro-3-methylphenol
Acenaphthene
Acetophenone
Metals
X
X
X
X
X
X
X
X
X
X
X
X
. x-
X
X •
"X"
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Oils
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Organics CAS NO.
X 766-41-7
18540-29-9
X 57-12-5
X 7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-3
X 7440-48-4
X 7440-50-8
7439-88-5
7439-91-0
7439-92-1
7439-93-2-
7439-9-7-6
X 7439-98-7
7440-02-6
7440-04-2
7782-49-2
X 7440-21-3
7440-22-4
X ' 7440-24-6
7440-28-0
7440-31-5
7440-32-6
7440-62-2
7440-65-5
X 7440-66-6
7440-67-7
X 78-93-3 .
X 67-64-1
X 608-27-5
X 88-06-2
' 59-50-7
83-32-9
X 98-86-2
Percent
Removal
38.94
5.68
70.44
66.78
65.77
55.15
61.23
90.05
80.33
10.19
84.20
74.00
54.44
77.45
26.00
90:16"
18.93
51.44
48.00
34.33
27.29
88.28
14.83
53.80
42.63
91.82
8.28
21.04
79.14
54.44
96.60
83.75
41.00
28.00
63.00
98.29
95.34
Source
50POTW-10XML
RREL5-(ALLWW)
50 POTW -10 XML
•
50 POTW - 2 X ML
50POTW-2XML
50 POTW- 2 XML
RREL 5- (ALL WW)
50POTW-10XML
50POTW-10XML
50 POTW- 2XML
50POTW-10XML
RREL 5 - (ALL WW)
Generic Removal-Group A
50 POTW -10 XML
RREL 5- (ALL WW)
'50POTW-10-XML-
50POTW-10XML
50 POTW - 10 X ML
RREL 5- (ALL WW)
RREL 5- (DOM WW)
RREL 5- (ALL WW)
50 POTW -10 XML
RREL 5- (DOM WW)
RREL 5- (ALL WW)
50 POTW- 2 XML
50POTW-10XML
50POTW-2XML
RREL 5- (ALL WW)
50 POTW -10 XML
Generic Removal-Group A
RREL 5 - (ALL WW)
RREL 5- (ALL WW)
RREL 5 - (ALL WW)
RREL 5- (ALL WW)
RREL 5 - (IND WW)
50 POTW -10 XML
RREL 5 - (ALL WW)
7-18
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
Table 7-5. Final POTW Percent Removals
Pollutant Metals Oils Organics CAS NO. Percent Source
Removal
Alpha-terpineol
Aniline
Anthracene
Benzo (a) anthracine
Benzoic Acid X
Bis(2-ethylhexyl) phthalate
Butyl benzyl phthalate
Carbazole
Chrysene
Diethyl phthalate
Fluoranthene
Fluorene
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexadecane
n-Octadecane
n-Tetracosane
n-Tetradecane
n,n-Dimethylformamide X
o-Cresol
p-Cresol
Pentachlorophenol
Phenol
Pyrene
Pyridine X
X
X
X
X
X X
X
X
X
X
X
X
X
X.
X
X
X
X
X
X
X
X X
X X
X X
X
X .X
X
X X
988-55-5
62-53-3
120-12-7
56-55-3
65-85-0
117-81-7
85-68-7 _
86-74-8
218-01-9
84-66-2
206-44-0
86-73-7
124-18-5
629-97-0
112-40-3
112-95-8
544-76-3
593-45-3.-
646-31-1
. 629-59-4—
68-12-2-
95.48-7 —
106-44-5
87-86-5
108-95-2
129-00-0
110-86-1
94.40
93.41
95.56
97.50
80.50
59.78
94.33
62.00
96.90
59.73
42.46
69.85
9.00
88.00
95.05
92.40
71.11
71.11
71.11
71:11
84.75
52.50
71.67
35.92
95.25
83.90
95.40
RREL 5 - (IND WW)
RREL5-(ALLWW)
50 POTW -10 XML
RREL 5- (DOM WW)
RREL 5 - (INDWW)-
50POTW-10XML
50 POTW - 10 X ML
Generic Removal-Group J
RREL 5- (DOM WW)
50 POTW -2X ML
50 POTW -2X ML
50 POTW -2X ML
RREL 5- (IND WW)
RREL 5- (IND WW)
. RREL 5- (IND WW^
RREL 5- (IND WW)
Generic Removal-Group CC
Generic Removal-Group CC
Generic Removal-Group CC
Generic Removal-Group CC
RREL 5- (IND WW)
RREL 5- (IND WW)
RREL 5- (IND WW)
50POTW-2XML
50 POTW -10 XML
RREL 5- (DOM WW)
RREL 5- (IND WW)
7-19
-------
Chapter 7 Pollutants Selected for Regulation
, Development Document for the CWT Point Source Category
Methodology for Determining
Treatment, Technology Percent
Removals
Pass-Through Analysis Results
7.6.4
7.6.3
EPA calculated treatment percent removals
for each subcategory BAT option with the data
used to determine the long-term averages.
Therefore, the data used to calculate BAT
treatment percent removals included the influent
and effluent data for pollutants that were
detected in the influent at treatable levels,
excluding data for pollutants which were not
treated by the technology, and excluding data
that were associated with process upsets. In one
sampling episode, EPA had only one effluent
measurement and multiple influent
measurements. In this one case, EPA kept only
the influent measurements from the same day as
the effluent measurement.
After the data were edited, EPA used the
following methodology to calculate percent
removal:
1) For each pollutant and each sampled
facility, EPA averaged the influent data
and effluent data to give an average
influent concentration and an average
effluent concentration, respectively.
2) EPA calculated percent removals for each
pollutant and each sampling episode from
the average influent and average effluent
concentrations using the following equation:
% Removal = (Avg Influent - Avg Effluent") x 100
Average Influent
3) EPA calculated the BAT median percent
removal for each pollutant for each option
from the facility-specific percent removals.
Section 10.4.3.2 discusses this in greater detail
and provides and example.
The results of the Pass-Through Analysis are
presented in Tables 7-6 through 7-8 by
subcategory and treatment option.
Pass-Through Analysis Results for the
.Metals Subcategory
7.6.4.1
For metals subcategory option 4, pass-
through results are presented in Table 7-6. All
non-conventional pollutants analyzed passed
through, and all metals passed through with the
exception of zirconium. However, for organic
pollutants analyzed, only benzoic acid passed
through. All pollutants that passed through may
be regulated under PSES and PSNS.
7-20
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
Table 7-6. Final Pass-Through Results For Metals Subcategory Option 4
Pollutant Parameter Option 4 Removal (%) Median POTW Removal (%) Pass-Through
CLASSICALS
Hexavalent Chromium
Total Cyanide
METALS
Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Iridium
Lead
Lithium
Mercury
Molybdenum
Nickel
Selenium
Silicon
Silver
Strontium
Tin
Titanium
Vanadium
Yttrium
Zinc
Zirconium
ORGANICS
2-Butanone
2-Propanone
Benzoic Acid
n,n-Dimethylformamide
Pyridine
98.01
99.30
94.30
91.74
99.97
99.91
98.47
99.91
99,69
99.95
66.83 • —
98.38
26.40
99.59' "
57154- -- —
.98.58 _._.,.,
99.62" "
95.89
99.94
99.84
99.46
95.39
99.93
42.13
74.72
65.62
82.99
54.81 •
48.49
5.68
70.44
66.78
65.77
90.05
80.33-
10.19
84.20
74.00
77.45-
26.00
90.16
18.93
51.44--
34.33 _
27.29
88.28
14.83
42.63
. 91.82
8.28
21.04
79.14
54.97
•
96.60
83.75
80.50
84.75
95.40
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes-
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
• yes
no
no
no
yes
no
no
7-21
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
Pass-Through Analysis Results for the Oils Subcategory
7.6.4.2
The final pass-through analysis results for the oils subcategory options 8 and 9 are presented in
Table 7-7. Several metals and organic pollutants passed through, and therefore may be regulated under
PSESandPSNS. :
Table 7-7. Final Pass-Through Results For Oils Subcategory Options 8 and 9
Pollutant Parameter
CLASSICALS
Total Cyanide
METALS
Antimony
Arsenic
Barium
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Silicon
Strontium
Tin
Titanium
Zinc
ORGANICS
2-Butanone
4-chloro-3-methylphenol*
Acenapthene
Alpha-terpineol
Anthracene
Benzo (a) anthracene
Benzoic acid
Bis(2-elhylhexyl)phthalate
Butyl benzyl phthalate
Carbazole
Chrysene
Diethyl phthalate
Fluoranthene
Option 8
Removal (%)
64.38
87.99
57.64
91.91
88.07
80.54
52.20
91.09- -
92.64
77.43
53.73
41.24
36.94 ~
54.16
50.68
90.77
89.99
80.33
15.41
-
96.75
94.77
97.07
94.38
6.54
93.22
92.19
81.09
96.93
77.01
96.24
, Option 9
Removal (%)
64.38
87.99
57.64
9L91
88.07
86.24
52.20
90.02
. 88.26
77.43
53.73
41.24
36.94
54.16
50.68
90.77
89.99
83.48
15.41
27.48
96.75
94.77
96.67
95.69
19.32
93.66
92.19
81.09
97.22
63.97
95.21
Median POTW
Removal (%)
"
70,44
66.78 .
65.77
55.15
90.05
80.33
10.19
84.20
77.45
90.16
18,93-
51.44
• 34.33
27.29
14.83
42.63
91.82
79.14
96.60
63.00
98.29
94.40
95.56
97.50
• 80.50
59.78
94.33
62.00
96.90
59.73
42.46
Pass-Through
no
ye"s~"
no
yes
no
yes
yes
yes
yes
no
• yes
no •
yes •
yes
yes
yes
no
yes
no
no
no
yes
yes
no
no
yes
no
yes
yes
yes
ves
7-22
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
Fluorene
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexadecane
n-Octadecane
n-Tetradecane
o-cresol*
p-cresol*
Phenol
Pyrene
Pyridine
95.32
97.36
97.25
94.14
95.88
97.38
97.32
97.26
-
- - *
53.68
97.10
21.45
92.86
94.98
96.87
96.50
95.54
96.53
97.20
96.85
21.08
34.88
14.88
97.63 .
21.45
69.85
9.00
88.00
95.05
92.40
, 71.11
71.11
71.11
52.50
71.67
95.25
83.90
95.40
yes
yes
yes
no for 8/
yes for 9
yes
yes
yes-
yes
no —
no
no
yes
no
* Not applicable for option 8
7-23
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
Pass-Through Analysis Results for the Organics Subcategory
7.6.4.3
The results of the pass-through analysis for the organics subcategory option 4 is presented in Table
7-8. Several metals and organic pollutants passed through, and therefore may be regulated under PSES
andPSNS.
Table 7-8. Final Pass-Through Results For Organics Subcategory Option 4
Pollutant Parameter
CLASSICALS
Total Cyanide
METALS
Antimony
Cobalt
Copper
Molybdenum
Silicon
Strontium
Zinc
ORGANICS
2-butanone
2-propanone
2,3-dichloroaniIine
2,4,6-trichlorophenol
Acetophenone
Aniline
Benzoic Acid
n,n-Dimethylfbrmamide
o-Cresol
p-Cresol
Pentachlorophenol
Phenol
Pyridine
Option 4 Removal (%)
33.46
33.27
17.31
38.04
57.10
4.71
59.51
60.51
69.20
68.57
80.45
45.16
92.44
92.88
94.29
89.26
98.39
85.38
23.19
87.08
61.69
Median POTW Removal (%)
70.44
66.78
10.19
84.20
18.93
88.28
14.83
79.14
96.60
83.75
41.00
28.00
95.34
93.41
80.50
84.75
52.50-
7.1.67
35.92
95.25
95.40
Pass-Through
no
no
yes
no
yes
no
yes
no
no
no
yes
yes
no
no
yes
yes
yes
yes
no
no
no
7-24
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the, CWT Point Source Category
FINAL LIST OF POLLUTANTS SELECTED FOR REGULATION
Direct Dischargers
7.7
7.7.1
After EPA eliminated pollutants.of concern which were treatment chemicals, non-conventional bulk
parameters, not detected at treatable levels, not treated, or volatile, EPA still had a lengthy list of
pollutants which could be regulated — particularly in the oils subcategory. EPA further eliminated
pollutants that were identified during screening, but not analyzed in a quantitative manner2. These
pollutants are indium, iridium, lanthanum, lithium, osmium, silicon, strontium, and zirconium. EPA
also eliminated pollutants that are not toxic as quantified by their toxic weighting factor (TWF)3. A
single pollutant, yttrium, has a TWF of zero and was, therefore, eliminated. EPA also eliminated
pollutants that were removed by the proposed treatment technologies, but whose removal was not
optimal. EPA eliminated pollutants that were removed by less than 30% with the proposed technology
options for the organics subcategory and by less than 50% with the proposed technology options for
the metals'and oils subcategories. These pollutants are listed in Table 7-9.
Table 7-9. Pollutants Eliminated Due to Non-Optimal Performance
Metals Option 4
BOD5
Molybdenum
Pyridine
Metals Option 3 Oils Option 8
Molybdenum _ BOD5
Nickel
Selenium
Benzoic Acid
p.-Cres.oll.
,' Pyridine
2-butanone
Oils Option 9
BOD5
Nickel
Selenium
Benzoic Acid
o-Cresol
p-Cresol
Phenol
Pyridine
2-butanone
4-methyl-2-pentanone
Organics Option 4
Cobalt
Pentachlorophenol
EPA also eliminated those pollutants for which the treatment technology forming the basis of the
option is not a standard method of treatment. For example, chemical precipitation systems are not
designed to remove BOD5. Table 7-10 lists these pollutants for each subcategory and option.
2Analyses for these pollutants were not subject to the quality assurance/quality control (QA/QC) procedures
required by analytical Method 1620.
3Toxic weighting factors are derived from chronic aquatic life criteria and human health criteria established
for the consumption offish. Toxic weighting factors can be used to compare the toxicity of one pollutant relative to
another and are normalized based on the toxicity of copper. TWFs are discussed in detail in the Cost Effectiveness
Analysis Document.
"Removals for this pollutant for option 8 were greater than 50%. However, since removals for this pollutant
for option 9 (the BAT selected option) were less than 50%, for consistency, they were similarly eliminated for option
7-25
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
Table 7-10. Pollutants Eliminated Since Technology Basis is Not Standard Method of Treatment
Metals Option 4 Metals Option 3 Oils Option 8/9 Organics Option 3/4~
BODj
Boron
2-butanone
2-propanone
benzoic acid
n,n-Dimethylformamide
BOD5
n,n-Dimethylformamide
Total Cyanide
Total Cyanide
For the metals subcategory, 2 pollutants,
beryllium and thallium, remained for metals
option 3, but has been eliminated for metals
option 4. For consistency, EPA eliminated these
two pollutants. EPA also eliminated hexavalent
chromium because it has regulated total
chromium. EPA's final list of regulated
pollutants for direct dischargers in the metals
subcategory is based on these additional edits.
For the organics subcategory, EPA
eliminated benzoic acid because of its low and
highly variable recovery using EPA Methods 625
and 1625. EPA also eliminated n,n-
dimethylformamidebecause there is no approved
method for this pollutant. EPA's final list of
regulated pollutants for direct discharges in the
organics subcategory is based on these additional
edits.
For the oils subcategory, EPA eliminated
alpha terpineol. EPA only has data from a single
episode that passed its data editing criteria (see
Chapter 10) upon which to develop limits for
alpha terpineol. EPA subsequently eliminated
this data because the effluent samples also
contained high levels of phenol (alpha terpineol
measurements can be affected by high phenol
levels). Further, two pollutants, n-tetracosane
and n,n-dimethylformamide remained for one oil
option, but had been eliminated for the other.
For consistency, EPA eliminated these two
pollutants.
Also, for the organic pollutants in the oils
subcategory, EPA further reduced the number of
regulated pollutants as detailed in the following
paragraphs. EPA selected this approach based
on comments to the 1995 proposal. This
approach uses- the•- same methodology as
proposed in 1999. However this analysis reflects
corrections to the CWT sampling analytical
database.
EPA organized the remaining organic
pollutants in the oils subcategory into pollutant
groups. As described in Section 7.6.2, pollutant
groups were developed by combining pollutants
of similar structures. The remaining list of'
organic pollutants in the oils subcategory are in
four pollutant groups: n-paraffins, polyafomatic
hydrocarbons, phthalates, and anilines. EPA
reviewed the influent characterization data from
the oils subcategory facilities (including the
additional data collected at non-hazardous oils
facilities) to determine which pollutants in each
structural group are generally detected together.
If pollutants in a structural group are always
detected together, then EPA can establish some
(or one) pollutants in each group as indicator
pollutants. Since the effectiveness of the
treatment technologies which form the basis of
the proposed oils subcategory limitations is
similar for pollutants in each group, EPA can be
confident that regulation of the group indicator
pollutant(s) will ensure control of all the group
pollutants. This approach allows EPA to reduce
the list of regulated pollutants for the oils
subcategory substantially. Tables 7-11, 7-12,
and 7-13 summarize the data for each structural
group with more than one pollutant remaining.
In these tables, an "X" indicates the pollutant
was detected at the sampled facility while a
7-26
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
"blank" indicates the pollutant was not detected
at the sampled facility.
At the time of the 1999 proposal, EPA
selected n-decane and n-octadecane from the n-
paraffins group. Data for n-paraffins continue to
show that while n-decane is usually detected in
.combination with other n-paraffins, it does not
respond to treatment in a similar manner as other
n-paraffins. Therefore, no other n-paraffins hi
this group can be used as an indicator of n-
decane. At the time of the proposal, EPA
selected n-octadecane because -the data showed
that it would be an appropriate indicator for the
remainder of the n-paraffins. With one
exception, this remains -accurate. The one
exception is n-hexadecane. EPA analysis now
shows that n-octadecane was detected in 13 of
. the facilities sampled'and that n-hexadecane was
detected in these same 13 facilities and one
other. The additional detection represents a
single grab sample. In EPA's view, a single grab
sample does not warrant the regulation- of an-
additional or different pollutant. Consequently,
EPA continues to select n-octadecane along with
n-decane from the n-paraffins group.
At the time of the 1999 proposal, EPA's
data showed that either fluoranthene or pyrene
would be an appropriate indicator for the
polyaromatic hydrocarbon group and EPA
selected fluoranthene. With one exception, this
remains accurate. The one exception is pyrene.
EPA analysis now shows that fluroanthene was
detected in six of the facilities sampled and that
pyrene was detected in these same six facilities
and one other. The additional detection
represents a single grab sample. In EPA's view,
a single grab sample does not warrant the
regulation of a different pollutant. Consequently,
EPA continues to select fluroanthene from the
polyaromatic group.
At the time of the 1999 proposal, EPA's
data showed that bis(2-ethylhexyl)phthalate and
butyl benzyl phthalate should be selected for the
phthalate group. This remains accurate.
Consequently, EPA selected both of these
compounds from the phthalate group.
Finally, carbazole is the only pollutant
remaining from the aniline group. Therefore,
EPA selected carbazole from the aniline group.
EPA's final list of regulated pollutants for
direct dischargers in the oils subcategory is based
on these additional edits/selections.
Table 7-14 shows the final list of pollutants
selected for regulation in all subcategories for
direct dischargers.
7-27
-------
g
"w
CS
O
u"
'S
CO
CO
o
H
O
i
s
2
ra
&,
».
O
"h
1
u
Q
t»-
o
1
U
cr
i
t2
£ -2
(u c w
•So0
I u S
3 ^_. •
(2* C3 o
t—t CO Ctf
nj -*^ fr^.
*-. O *"^
o ^>
p
"S
03
*
a
CL,
O
z
s
*
*4
»— t
a
0
IX,
W
•Q
O
pa
<
S
C3
B
"o
0.
^ en
O) fM
X X
X
X
X X
X
X X
X X
X" X
X X
X X
X X
X X
X X
, "°
3 "3.
s s
c2 ca
co
H j§
"&, ^
C ca
ca -T-i
" 13
a> •*-•
M 8
•a t>
ea -a
u o
13 a
O CO
t> ^
co -g
rR f-«
& |
1 1
=2 ^
O ^i
PH C3
II 43
X -f
JO
cu
2
bO
I
S
S.
2
.
•o
u
JS
o
JS
T3
8
o
a
"S
•o
rru
o c
& o
"> .-a
u
o
o
oo
CM
-------
«
1
bi
o ^5 NO
X
X
rS rN ^ ^ ^
X X X X X X X
1
X X X X X X X
X X X X X X X
X X X X X X
I
s
§ £ ' s
i s s „ |
i=i o c^ i2 *£ a?
p O N^, " C C
« 2 o M ca w g
1 1 S b .§ § - e
•^ ^ CQ CJ fr t fT t p_,
• -
• .ti
'3
-^ "d
p> u
S "3,
3 S
fi , . cC
CO
0 w •
r^t r&
* "S
J 8
•*-> gj
CS -Q
•a f
Pollutant was
ik = Pollutant
II 43
X f
g
cs
T3
.8
I
3
o
•a
u
8
S3
"3.
o
a.
S
I'
•§
u
co"
>
«s «
fi °
o §
CO §
£ §
o
u
ON
CN
-------
"55
^
o
ct
s
1
CO
5
^
O
'i
—
"o
.s
s
tt
0
"s
_o
—
Q
o
&
c
CJ
1
en
t
S
V
** S CO
"1 (3 a
1Z ra Is
OM 05 C3
2 ^J ^*
o 5
H -S
Q
"3
C3
u.
ed
cx
«u
O
z
-
*-»
*— 4
a
o
b
w
Q
U
CQ
s
5
J3
~3
P-.
OS
CO
00
X
X
"X
X
X
X
X
X
"
X
X
JO
a
~5
Q.
O
'S
t
CO
S
ON
CO
X
X
X
X
0
eg
.C
t
1
|
^
m
ON
0
X
X
X
ylphthalate
^
0
5
•
£,
^M
1
"S.
i
w
5
'cB
"O
O
•o
llutant was
.2
ii
X
•s"
'3
1
"&
CO
CO
u
i
o
1
•o
"o
c
CO
a
S
= Pollutant
•g
•
b
o
o
o
fl
&.
T3
u
co to
->
•?-? cd
O
O S3
b O
^ -a
o
o
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
Table 7-14. Final List of Regulated Pollutants for Direct Discharging CWTs
Metals Subcategory
Option 4
(BPT, BAT)
TSS
Oil and Grease
Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Nickel •
pH
Selenium
Silver
Tin
Titanium
' Total cyanide
Vanadium
Zinc-
,
Metals Subcategory
Option 3 (NSPS)
TSS
Oil and Grease
Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Nickel
pH
Selenium
Silver
Tin
Titanium
Total cyanide
Vanadium
Zinc .
Oils Subcategory
Option 9
BPT, BAT, NSPS
Oil and Grease
TSS
Antimony
Arsenic
Barium
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Molybdenum
pH
Tin
Titanium
Zinc
Bis(2-ethylhexyl)phthalate
Butylbenzyl phthalate
Carbazole .
Fluoranthene
N-decane
N-octadecane
Organics Subcategory
Option 4
BPT, BAT, NSPS
BOD5
TSS
Antimony
Copper
Molybdenum
Zinc --
Acetophenone
Aniline
o-Cresol
p-Cresol
PH
Phenol
Pyridine
2-butanone
2-propanone
2',3-dichloro'anilihe
2,4, 6-trichlorophenol
Indirect Dischargers
7.7.2
Consideration of Indicator Parameters for the
Oils Subcategory
As detailed in the 1999 proposal, EPA
looked at various ways to reduce the costs of this
rule (particularly the costs to small businesses)
while ensuring proper treatment of off-site
wastes. One of the options considered by EPA
and discussed in the 1999 proposal was
providing an alternative comph'ance-monitoring
regime for indirect discharging facilities in the oils
Subcategory. Under this alternative monitoring
approach, facilities could choose to (1) monitor
for all regulated pollutants, or (2) monitor for the
conventional parameters, metal parameters, and
monitor for the regulated organic pollutants in
this subcategory using an indicator parameter
such as hexane extractable material (HEM) or
silica gel treated-hexane extractable material
(SGT-HEM). The 1999 proposal further'noted
that EPA was conducting a study to determine
which organic pollutants are measured by SGT-
HEM and HEM and solicited comment on the
use of indicator parameters.
Many commenters responded to EPA's
request with essentially an equivalent number
opposing and favoring the use of indicator
parameters. The commenters that supported its
use cited the decreased analytical costs and the
wide range of organic compounds that can be
measured with these analyses. Commenters that
did not support the use of SGT-HEM or HEM
as indicator pollutants raised a number of
concerns including the following:
• these measurements are non-specific and
highly subject to interferences;
• no direct and quantified correlation has
ever been developed between HEM (or
7-31
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
SGT-HEM) and specific organic
pollutants;
• there is no evidence that regulating HEM
or SGT-HEM would result in adequate
regulation of toxics;
• the determination has not been made that
the organic pollutants of interest are
measured by either HEM or SGT-HEM;
and
• SGT-HEM does not measure all of the
regulated pollutants, particularly
polyaromatic hydrocarbons (PAHs).
None of the commenters suggested possible
alternative indicator parameters:
During its development of proposed effluent
limitations guidelines and pretreatment standards
for the industrial laundries point source category,
EPA evaluated the suitability of SGT-HEM and
HEM as indicator parameters for that
rulemaldng. EPA presented the results of its
study in a Notice of Data Availability" on
December 23, 1998 (63 FR 71054). In the
study, EPA attempted to identify compounds
present in HEM/SGT-HEM extracts from
industrial laundry wastewaters using gas
chromatography/mass spectroscopy (GC/MS) in
order to determine which pollutants of concern
might be components of, and therefore measured
by, HEM or SGT-HEM. However, EPA was
only able to identify approximately two percent
of the constituents present in the waste stream.
Most of these constituents' identified were
alkanes. In general, the data from this study
also do not support the use of SGT-HEM as an
appropriate indicator parameter for the organic
pollutants present in CWT wastewaters since
few of these pollutants were identified in the
HEM/SGT-HEM extract.
As part of its consideration of the use of an
indicator parameter for this rule, EPA again
reviewed the data from the industrial laundries
study as well as the data collected here. EPA
statistically analyzed the relationship between
seven organic pollutants and SGT-HEM or
HEM. EPA's data show general trends of
increasing concentrations of HEM and SGT-
HEM with increasing concentrations of organic
pollutants. However, the data demonstrate
substantial variability and, despite this general
trend, EPA noted that the non-detected values
for organics were associated with just about
every level of HEM and ' SGT-HEM and
conversely, that high levels of some organic
pollutants were associated with low levels of
HEM/SGT-HEM. As a result, EPA cannot
demonstrate that establishing a numerical limit
for SGT-HEM or HEM would provide
consistent control of the organic pollutants by the
model treatment technologies.
Therefore, while EPA is cognizant of the
cost savings that can be achieved in some
instances by using indicator parameters, EPAhas
rejected this alternative monitoring approach for
CWT wastewaters.
Final List of Regulatory Parameters for
Indirect Discharging CWT Facilities
As detailed in Section 7.6, all pollutants
regulated for direct dischargers which pass-
through well-operated POTWs are regulated for
indirect dischargers. Table 7-15 shows the final
list of regulated pollutants for indirect dischargers
selected by EPA.
7-32
-------
Chapter 7 Pollutants Selected for Regulation
Development Document for the CWT Point Source Category
Table 7-15. Final List of Regulated Pollutants for Indirect Discharging CWT Facilities _^
Metals Subcategory Oils Subcategory Organics Subcategory
Option 4 Option 8 (PSES) - Option 3
PSES/PSNS Option 9 (PSNS) - . ' - PSES,PSNS
Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Nickel
Selenium
Silver
Tin
Titanium
Total cyanide
Vanadium
Zinc
Antimony
Barium
Chromium
Cobalt
Copper
Lead
Molybdenum
Tin
Zinc
Bis(2-ethylhexyl)phthalate
Carbazole
Fluoranthene
N-decane
N-octadecane
Molybdenum
o-Cresol
p-Cresol
2,3 -dichloroaniline
2,4,6-trichlorophenol
.'
'
7-33
-------
-------
Chapter
8
WASTEWATER TREATMENT TECHNOLOGIES
This section discusses a number of
wastewater treatment technologies
considered by EPA for the development of these
guidelines and standards for the CWT Industry.
Many of these technologies are being used
currently at CWT facilities. This section also
reviews other technologies with potential
application in treating certain CWT pollutants of
concern.
Facilities in the CWT industry use a wide
variety of technologies for treating wastes
received for treatment or recovery operations'
and wastewater generated on site. The.
technologies are groupedJmto the following five
categories for this discussions, =
• Best Management Practices, section 8.2.1;
• Physical/Chemical/Thermal Treatment,
section 8.2.2;
• Biological Treatment, section 8.2.3;
• Sludge Treatment and Disposal, section
8.2.4; and •
• Zero Discharge Options, section 8.2.5.
The processes reviewed here include both
those that remove pollutant contaminants in
wastewater and those that destroy them. Using
a wastewater treatment technology that removes,
rather than destroys, a pollutant will produce a
treatment residual. In many instances, this
residual is in the form of a sludge, that, typically,
a CWT further treats on site in preparation for
disposal. Section 8.2.4 discusses technologies
for dewatering sludges to concentrate them prior
to disposal. In the case .of other types of
treatment residuals, such as spent activated
carbon and filter media, CWT facilities generally
send those off site to a vendor facility for
management.
TECHNOLOGIES CURRENTLY IN USE
8.1
EPA obtained information on the treatment
technologies in use in the CWT industry from
responses to the Waste-Treatment Industry-
(WTI) Questionnaire, . site visits, public
comments to the original proposal and the 1996
Notice of Data Availability. As described in
Section 4, of the estimated 205 CWT facilities,
EPA has obtained detailed facility-specific
technology information for 116 of the direct and
rndirect .dischargingT.CWT' - facilities: Although -
EPA has facility-specific information for 145
faculties, only 116 of these facilities provided
technology information. The detail provided
regarding the technology information differs
depending on the source. Information for the 65
facilities that completed the WTI Questionnaire
was the most explicit because the questionnaire
contained a detailed checklist of wastewater
treatment technologies, many of which are
discussed in this section. Technology
information from other sources, however, is
much less descriptive.
Table 8-1 presents treatment technology
information by subcategory for the 116 indirect
and direct discharging CWT facilities for which.
EPA has facility-specific treatment technology
information. The information in Table 8-1 has
not been scaled to represent the entire population
of CWT facilities. Responses to the WTI
Questionnaire provide the primary basis for the
technology information for the metals and the
organics subcategories. Comments to the 1996
Notice of Data Availability provide the primary
source of the technology information for the oils
subcategory. It should be noted that a number
of facilities commingle different subcategory
wastes for treatment. EPA has attributed these
8-1
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
treatment technologies to all appropriate
subcategories.
Table 8-1. Percent Treatment In-place by Subcategory and by Method of Wastewater Disposal
Disposal Type
Number of Facilities with
Treatment Technology Data
Equalization*
Neutralization*
Flocculation*
Emulsion Breaking
Gravity-Assisted Separation
Skimming''
Plate/Tube Separation*
Dissolved Air Flotation
Chromium Reduction*
Cyanide Destruction*
Chemical Precipitation
Filtration
Sand Filtration*
Mutimedia Filtration*
Ultrafiltration
Reverse Osmosis*
Carbon Adsorption
Ion Exchange*
Air Stripping
Biological Treatment
Activated Sludge
Sequencing Batch
Reactors*
Vacuum Filtration*
Pressure Filtration*
Metals Subcategory
Direct Indirect
9;
78
89
44
11
89
22
0
22
33
33
78
44
11
11
0
11
22
0
0
56
33
0
11
67
41'
68
73
51
29
61
• 27
10 -
5
76
46
88
32
15
5
0
0
12
2
7
2
0
2
17
61
Oils Subcategorv
Direct Indirect
3M.
100
100
100
33
100
100
0-
33
0
100
0
33 '
0
0
0
0
67
0 .
0
100
100
0
100
100
80"
65
61
48
• 56
85"
58
..... 19.. .
23
48
23
34
19
16
0
8
3
18
0
11
11
0 •
0
. 6
39
Organics Subcategorv
Direct Indirect
4'
75
100
75
25
100
25 ,
o<, •
50
0
25
25
25
0
0
0
0
0
0
0
100
100
0
25
75 •
14'
71
,. 57
. 57 •
50
64
57
2.1=-,
0
57
29
64
21
21
7
0
0
21
0
0
7
0
7
7
36
'Sum does not add to 116 facilities. Some facilities treat wastes in multiple subcategories.
2Of the 3 direct discharging oils facilities for which EPA has facility-specific information, only one
completed the WTI Questionnaire.
3Of the 80 indirect discharging oils facilities for which EPA has facility-specific information, only 31
completed the WTI Questionnaire.
*Informationfor these technologies for the oils subcategory is based on responses to the WTI Questionnaire
only.
TECHNOLOGY DESCRIPTIONS
BestManagement Practices
8.2
8.2.1
In addition to physical/chemical treatment
technologies, CWT facilities employ a number of
ancillary means to prevent or reduce the
discharge of pollutants. These efforts are termed
"best management practices. EPA believes that
CWT facilities should design best management
8-2
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
practices in the CWT industry with the following
objectives in mind:
• Maximize the amount of waste materials and
residuals that are recycled rather than
disposed as residuals, as waste water, or as
waste material.
• Maximize recycling and reuse of
wastewaters generated on site.
• Minimize the introduction of uncontaminated
wastewaters into the treatment waste stream.
• Encourage waste generators to minimize the
mixing of different wastes.
• Segregate wastes for treatment particularly
where waste segregation would improve
treatment performance and maximize
opportunities for recycling:
Waste segregation is one of the most
important tools available for maximizing-waste-
recycling and improving treatment performance.
For example,. separate treatment of wastes
containing different types of metals allows the
recovery of the individual metals from the
resultant sludges. Similarly, separate treatment
collection and treatment of waste oils will allow
recycling. Many oils subcategory facilities
currently practice waste oil recycling.
Physical/Chemical/Thermal Treatment 8.2.2
Equalization 8.2.2.1
GENERAL DESCRIPTION
The wastes received at many facilities in the
CWT industry vary considerably in both strength
and volume. Waste treatment facilities often
need to equalize wastes by holding wastestreams
in a tank for a certain period of time prior to
treatment in order to obtain a stable waste stream
which is easier' to treat. CWT facilities
frequently use holding tanks to consolidate small
waste volumes and to rninimize the variability of
incoming wastes prior to certain treatment
operations. The receiving or initial treatment
tanks of a facility often serve as equalization
tanks. • ..
The equalization tank serves many
functions. Facilities use equalization tanks to
consolidate smaller volumes of wastes so that,
for batch treatment systems, full batch volumes
are available. For continuous treatment systems,
facilities equalize the waste volumes so that they
may introduce effluent to downstream processes
at a uniform rate and strength. This dampens
the effect of peak and minimum flows.
Introducing a waste stream with a more uniform
pollutant profile to the treatment system
facilitates control of the operation of downstream
treatment units, resulting in more predictable and
uniform treatment results. Equalization tanks are
usually equipped with agitators or aerators where
mixing of- the- wastewater is- desired ~and- to-
preverit suspended solids from settling to the
bottom of the unit. An example of effective
equalization is the mixing_of acid and alkaline
wastes. Figure 8-1 illustrates an equalization
system:"' -
EPA does not consider the use of
equalization tanks for dilution as a legitemate
use. In this context, EPA defines dilution as the
mixing of more concentrated wastes with greater
volumes of less concentrated wastes in a manner
that reduces the concentration of pollutant in the
concentrated wastes to a level that enables the
facility to avoid treatment of the pollutant.
8-3
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Wastewater
Influent,
Equalization Tank
Equalized
Wastewater
Effluent
Figure 8-1. Equalization System Diagram
8-4
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
INDUSTRY PRACTICE
EPA found equalization being used at
facilities in all of the CWT subcategories. Of
the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning the use of equalization,
44 operate equalization systems. Of these,
approximately 44 percent emply unstirred tanks
and 56 percent use stirred or aerated tanks.
The combining of separate waste receipts
in large receiving tanks provides for effective
equalization even though- it is not necessarily
recognized as such. Nearly every facility
visited by EPA performed equalization, either
in tanks specifically designed for that purpose
or in waste receiving, tanks. Consequently,
EPA has concluded that equalization is
underreported in the data-base., ,
Neutralization
8.2.2.2
GENERAL DESCRIPTION
Wastewaters treated~at"CWT~ facilities'have"
a wide range of pH values depending on the
types of wastes accepted. Untreated
wastewater may require neutralization to
eliminate either high or low pH values prior to
certain treatment systems, such as biological
treatment. Facilities often use neutralization
systems also in conjunction with certain
chemical treatment processes, such as chemical
precipitation, to adjust the pH of the
Wastewater to optimize treatment efficiencies.
These facilities may add acids, such as sulfuric
acid or hydrochloric acid, to reduce pH, and
alkalies, such as sodium hydroxides, to raise
pH values. Many metals subcategory facilities
use waste acids and waste alkalies for pH
adjustment. Neutralization may be performed
in a holding tank, rapid mix tank, or an
equalization tank. Typically, facilities use
neutralization systems at the end of a treatment
system to control the pH of the discharge to
between 6 and 9 in order to meet NPDES and
POTW pretreatment limitations.
Figure 8-2 presents a flow diagram for a
typical neutralization system.
INDUSTRY PRACTICE
EPA found neutralization systems in-place
at facilities identified in all of the CWT
subcategories. Of the 65 CWT facilities in
EPA's WTI Questionnaire data base that
provided information concerning the use of •
neutralization, 45 operate neutralization
systems. •
Flocculation/Coagulation
. 8.2.2.3
GENERAL DESCRIPTION
Flocculation is the stirring or agitation of
chemically-treated water to induce coagulation.
The terms coagulation and flocculation are
often used interchangeably. More specifically,
"coagulation" is,the.reduction_oflthe, net:
electrical repulsive forces at particle surfaces
by addition of coagulating chemicals, whereas
"flocculation" is'the agglomeration of the
destabilized particles by chemical joining and
bridging. Flocculation enhances sedimentation
or filtration treatment system performance by
increasing particle size resulting in increased
settling rates and filter capture rates.
Flocculation generally precedes
sedimentation and filtration processes and
usually consists of a rapid mix tank or in-line
mixer, and a flocculation tank. The waste
stream is initially mixed while a coagulant
and/or a coagulant aid is added. A rapid mix
tank is usually designed for a detention time of
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 the
particles to agglomerate into heavier, more,
settleable/filterable solids. Either mechanical
paddle mixers or diffused air provides mixing.
Flocculation basins are typically designed for a
detention time of 15 to 60 minutes. Figure 8-3
presents a diagram of a clarification system
incorporating coagulation and flocculation.
8-5
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWTPoint Source Category
Wastewater
Influent
ir V
Neutralization Tank
acid
caustic
pH monitor/
control
Neutralized
Wastewater
Effluent
Figure 8-2. Neutralization System Diagram
8-6
-------
Chanter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
Coagulant
Influent
Rapid Mix
Tank
Flocculating
Tank
Clarifier
Effluent
Sludge
Figure 8-3. .Clarification System Incorporating Coagulation and Flocculation
8-7
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Cateeorv
There are three different types of treatment
chemicals commonly used in
coagulation/flocculation processes: 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. Many CWT
facilities use bench-scale jar tests to determine
the appropriate type and optimal dosage of
coagulant/flocculent for a given waste stream.
INDUSTRY PRACTICE ~
Chemical treatment methods to enhance
the separation of pollutants-from water-asa-
solid residual may include both chemical
precipitation and coagulation/flocculation.
Chemical precipitation is the conversion of
soluble pollutants such as metals into an
insoluble precipitate and^is described* '"'
separately. Flocculation is often an integral
step in chemical precipitation, gravity
separation, and filtration. Of the 65 CWT
facilities in EPA's WTI Questionnaire data
base that provided information concerning the
use of coagulation/flocculation, 31 operate
coagulation/flocculation systems. However,
due to the integral nature of flocculation in
chemical precipitation and coagulation, and the
interchangeable use of the terminology, the use
of coagulation/flocculation at CWT facilities
may have been underreported.
Emulsion Breaking
8.2.2.4
GENERAL DESCRIPTION.
One process used to treat emulsified
oil/water mixtures is emulsion breaking. An
emulsion, by definition, is either stable or
unstable. A stable emulsion is one where small
droplets of oil are dispersed within the water
and are prevented from coalescing by repulsive
electrical surface charges that are often a result
of the presence of emulsifying agents and/or
surfactants. In stable emulsions, coalescing
and settling of the dispersed oil droplets would
occur very slowly or not at all. Stable
emulsions are often intentionally formed by
chemical addition to stabilize the oil mixture for
a specific application. Some examples of stable
emulsified oils are metal-working coolants,
lubricants, and antioxidants. An unstable
emulsion, or dispersion, settles very rapidly and
does not require treatment to break the
emulsion.
Emulsion breaking is achieved through the
addition of chemicals and/or heat to the
emulsified oil/water mixture. The most
commonly-used method of emulsion breaking
is acid-cracking where sulfuric or hydrochloric
acid is added to the oil/water mixture until the
pH reaches 1 or 2. An alternative to acid-
cracking is chemical treatment using
emulsion-breaking chemicals such as
surfactants and coagulants. After addition of
the treatment chemical, the tank contents are
mixed. After the emulsion bond is broken, the
oil residue is allowed to float to the top of the
tank. - At this point, heat (100 to 150° F) may
be applied to speed the separation process.
The oil is then skimmed by mechanical means,
or the water is decanted from the bottom of the
tank. The oil residue is then further processed
or disposed. A diagram of an emulsion
breaking system is presented in Figure 8-4.
INDUSTRY PRACTICE
Emulsion breaking is a common process in
the CWT industry. Of the 116 CWT facilities
in EPA's WTI Questionnaire and NOA
comment data base that provided information
concerning the use of emulsion breaking, 49
operate emulsion breaking systems. Forty-six
of the 83 oils subcategory facilities in EPA's
data base use emulsion-breaking. As such,
EPA has concluded that emulsion breaking is
the baseline, current performance technology
for oils subcategory facilities that treat
emulsified oily wastes.
8-8
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
Chemical
Addition
Oil
Residua
Sludge
Figure 8-4. Emulsion Breaking System Diagram
8-9
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
Gravity Assisted Separation 8.2.2.5
1. GRA VITY OIL/WA TER SEPARA TION
GENERAL DESCRIPTION
Like emulsion breaking, another in-place
treatment process used to remove oil and grease
and related pollutants from oil/water mixtures is
gravity separation. Unlike emulsion breaking,
gravity separation is only effective for the bulk
removal of free oil and grease. It is not effective
in the removal of emulsified or soluble oils/
Gravity separation is often used in conjunction
with emulsion breaking at CWT faculties.
Gravity separation may be performed using
specially designed tanks or it may_occur within
storage tanks. During gravity oil/water
separation, the wastewater is held under
quiescent conditions long enough to.allow the,oil_
droplets, which have a lower specific gravity
than water, to rise and form a layer., on the
surface. Large droplets rise more readily than
smaller droplets. Once the oil has risen to the
surface of the wastewater, it must be removed.
This is done mechanically via skimmers, baffles,
plates, slotted pipes, or dip tubes. When
treatment or storage tanks serve as gravity
separators, the oil may be decanted off the
surface or, alternately, the separated water may
be drawn off the bottom until the oil layer
appears. The resulting oily residue from a
gravity separator must then be further processed
or disposed.
Because gravity separation is such a widely-
used technology, there is an abundance of
equipment configurations available. A very
common unit is the API (American Petroleum
Institute) separator, shown in Figure 8-5. This
unit uses an overflow and an underflow baffle to
skim the floating oil layer from the surface.
Another oil/water gravity separation process
utilizes parallel plates which shorten the
necessary retention time by shortening the
distance the oil droplets must travel before
separation occurs.
INDUSTRY PRACTICE
Of the 116 CWT facilities hi EPA's WTI
Questionnaire and NOA comment data base that
provided information concerning the use of
oil/water gravity separation, 16 operate skimming
systems, seven operate coalescing plate or tube
separation systems, and 42 operate oil/water
gravity separation systems. Oil/water separation
is such an integral step at oils subcategory
facilities that every oils subcategory- facility
visited by EPA performed gravity oil/water
separation, either in tanks specifically designed
for that purpose or in waste receiving or storage
tanks.
2. CLARIFIGATION
GENERAL DESCRIPTION
Like oil/water— separators, clarification
systems utilize gravity to provide continuous,
lowrCosLseparation and removal of particulates,
flocculated impurities, and precipitates from
water. These' systems typically follow
wastewater treatment processes which generate
suspended solids, such as chemical precipitation
and biological treatment.
In a clarifier, wastewater is allowed to flow
slowly and uniformly, permitting the solids more
dense than water to settle to the bottom. The
clarified wastewater is discharged by flowing
from the top of the clarifier over a weir. Solids
accumulate at the bottom of a clarifier and a
sludge must be periodically removed, dewatered
and disposed. Conventional clarifiers are
typically circular or rectangular tanks. Some
specialized types of clarifiers additionally
incorporate tubes, plates, or lamellar networks to
increase the settling area. A circular clarification
system is illustrated in Figure 8-6.
8-10
-------
Chanter 8 Waste-water Treatment Technologies Development Document for the CWT Point Source Category
Oil Retention
Baffle
Wactawater
Influent
Diffusion Device £J!L
(vertical baffle) Skimmer
Scraper
Sludge
Hopper
Oil
Retention
Baffle
Treated
Effluent
Figure 8-5. Gravity Separation System Diagram
• 8-11
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Skimming Scraper
Overt low W»fr
Influent
Sludg* Removal
Figure 8-6. Clarification System Diagram '
8-12
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
INDUSTRY PRACTICE
Of the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning the use of clarification
systems, 39 operate settling systems and seven
operate coalescing plate or tube separation
systems. EPA did not obtain detailed enough
treatment technology information from the
Notice of Data Availability comments for the oils
subcategory facilities to determine the presence
or absence of "clarification systems. In general,
oils subcategory facilities are more likely to
utilize gravity oil/water separation. However,
oils facilities that also utilize solids generation
processes such as chemical precipitation or:
biological treatment as part of their waste
treatment train will likely utilize clarification
systems.
3. DISSOLVED AIR-FLOTATION
GENERAL DESCRIPTION
Flotation is the process of using fine bubbles
to induce suspended particles to rise to the
surface of a tank where they can be collected
and removed. Gas bubbles are introduced into
the wastewater and attach themselves to the
particles, thereby reducing their specific gravity
and causing them to float. Fine bubbles may be
generated by dispersing air mechanically, by
drawing them from the water using a vacuum, or
by forcing air into solution under elevated
pressure followed by pressure release. The
latter, called dissolved air flotation (DAF), is the
flotation process used most frequently by CWT
facilities and is the focus of the remaining
discussion.
DAF is commonly used to remove
suspended solids and dispersed oil and grease
from oily wastewater. It may effectively reduce
the sedimentation times of suspended particles
that have a specific gravity close to that of water.
Such particles may include both solids with
specific gravity slightly greater than water and
oil/grease particles with specific gravity slightly
less than water. Flotation processes are
particularly useful for inducing the removal of
oil-wet solids that may exhibit a combined
specific gravity nearly the same as water. Oil-
wet solids are difficult to remove from
wastewater using gravity sedimentation alone,
even when extended sedimentation times are
utilized. Figure 8-7 is a flow diagram of a DAF
system.
The major components of a conventional
DAF unit include a centrifugal pump, a retention
tank, an air compressor, and a flotation tank.
For small volume systems, the entire influent
wastewater stream is pressurized and contacted
with airm a retention tank for several minutes to
allow time., for^the, air., to-, dissolve.- The_
pressurized water that is nearly saturated with air
is then passed through a pressure reducing valve
and introduced-into the flotation tank near the
bottom. In larger units, rather than pressurizing
the entire wastewater stream, a portion of the
flotation cell effluent is recycled through me
pressurizing pump and the retention tank. The
recycled flow" is then mixed" with " the
unpressurized main stream just prior to entering
the flotation tank.
As soon as the pressure is released, the
supersaturated air begins to come out of solution
in the form of fine bubbles. The bubbles attach
to suspended particles and become enmeshed in
sludge floes, floating them to the surface. The
float is continuously swept from the tank surface
and is discharged over the end wall of the tank..
Sludge, if generated, may be collected from the
bottom of the tank. The mechanics of the
bubble-particle interaction include: (1)
attachment of the bubbles on the particle surface,
(2) collision between a bubble and a particle, (3)
agglomeration of individual particles or a floe
structure as the bubbles rise, and (4) absorption
of the bubbles into a floe structure as it forms.
As such, surface chemistry plays a critical role in
the effective performance of air flotation.
8-13
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWTPoint Source Category
Float Removal Device
Float
Wastewater
Influent
(Saturated
with Air)
Float
Flotation
Tank
Treated
Effluent
Baffle
->- Sludge (If Produced)
Figure 8-7. Dissolved Air Flotation System Diagram
8-14
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
Other operating variables which affect the
performance, of DAF include the operating
pressure, recycle ratio, detention time, the
air/solids ratio, solids and hydraulic loading rates,
and the application of chemical aids.
The operating pressure of the retention tank
influences the size of the bubbles released. If the
bubbles are too large, they do not attach readily
to the suspended particles. If the bubbles are too
fine, they_will disperse and break up_fragile floe.
Wastewater treatment textbooks generally
recommend a bubble size of 100 micrometers.
The most practical way to establish the proper
rise rate is to conduct experiments at various air
pressures.
The_ air-to-solids ratio in the DAF unit
determines the effluent quality and solids--
concentration in the float. This is because
adequate air bubbles are needed to float-
suspended-solids to the surface of the tank;
Partial flotation of solids will occur if inadequate
or excessive amounts of air bubbles are present.
Researchers-Have, demonstrated:- that - the«™
addition of chemicals td the water stream is an
effective means of increasing the efficiencies of
DAF treatment systems. The use of coagulants
can drastically increase the oil removal efficiency
of DAF units. Three types of chemicals are
generally utilized to improve the efficiency of air
flotation units used for treatment of produced
water; these chemicals are surface active agents,
coagulating agents, and polyelectrolytes. The
use of treatment chemicals may also enhance the
removal of metals in air flotation, units. EPA's
collection of data from the CWT industry has
shown that many facilities use DAF systems to
remove metals from their waste streams.
INDUSTRY PRACTICE
Of the 116 CWT facilities in EPA's WTI
Questionnaire and NOA comment data base that
provided information concerning use of DAF, 21
, operate DAF systems.
Chromium Reduction
8.2.2.6
GENERAL DESCRIPTION
Reduction is a chemical reaction in which
electrons are transferred from one chemical to
another. The main reduction application at
CWT facilities is the reduction of hexavalent
chromium to trivalent chromium, which is
subsequently precipitated from the wastewater in
conjunction with other metallic salts. A low pH
of 2 to 3 will promote chromium reduction
reactions. At pH levels above 5, the reduction
rate is slow. Oxidizing agents such as dissolved
oxygen and ferric iron interfere with the
reduction process by consuming the reducing
agent.
The use of strong reducing agents such as
sulfur dioxide, sodium bisulfite, sodium
metabisulfite, and ferrous sulfate also
promotesshexavalent chromium reduction. The
two' most commonly used reducing agents in the
CWT industry- are sodium metabisulfite or
sodium bisulfite and gaseous sulfur dioxide. The
remaining discussion will focus on chromium
reduction using these agents only. Figure 8-8 is
a diagram of a chromium reduction system.
Chromium reduction using sodium
metabisulfite (Na2S2O5) and sodium bisulfite
(NaHSO3) are essentially similar. The
mechanism for the reaction using sodium
bisulfite as the reducing agent is:
3NaHSO3 +
- Cr2(SO4)3
3H2SO4
2H2CrO4
3NaHSO4
5H2O
The hexavalent chromium is reduced to
trivalent chromium using sodium metabisulfite,
with sulfuric acid used to lower the pH of the
solution. The amount of sodium metabisulfite
needed to reduce the hexavalent chromium is
reported as 3 parts of sodium bisulfite per part of
chromium, while the amount of sulfuric acid is 1
part per part of chromium. The theoretical
retention time is about 30 to 60 minutes.
A second process uses sulfur dioxide (SO2)
as the reducing agent. The reaction mechanism
is as follows:
8-15
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
3SO
3H2O
3H2SO3
3H2SO3 + 2H2CrO4 - Cr2(SO4)3
5H2O
The hexavalent chromium is reduced to
trivalent chromium using sulfur dioxide, with
sulfuric, acid used to lower the pH of the
solution. The amount of sulfur dioxide needed
to reduce the hexavalent chromium is reported as
1 .9 parts of sulfur dioxide per part of chromium,
while the amount of sulfuric acid is 1 part per
part of chromium. At a pH of 3, the theoretical
retention time is approximately 30 to 45 minutes.
INDUSTRY PRACTICE
Of the 65 CWT facilities hi EPA's WTF
Questionnaire data base that provided
information concerning the use of chromium
reduction, 35 operate chromium reduction
systems. All of the 35 facilities are in the metals
subcategory. At these 35 facilities, there are four
sulfur dioxide processes, 21 sodium bisulfite
processes, and two sodium metabisulfite
processes. The remaining systems use various
other reducing agents.
Cyanide Destruction
8.2.2.7
GENERAL DESCRIPTION
Electroplating and metal finishing operations
produce the major portion of cyanide-bearing
wastes accepted at CWT facilities. EPA
observed three separate cyanide destruction
techniques during site visits at CWT facilities.
The first two methods are alkaline chlorination
with gaseous chlorine and alkaline chlorination
with sodium hypochlorite. The third method is
a cyanide destruction process, details of which
the generator has claimed are confidential
business information (CBI). The two alkaline
chlorination procedures are discussed here.
Alkaline chlorination can destroy free
dissolved hydrogen cyanide and can oxidize all
simple and some complex inorganic cyanides. It,
however, cannot effectively oxidize stable iron,
copper, and nickel cyanide complexes. The
addition of heat to the alkaline chlorination
process can facilitate the more complete
destruction of total cyanides. The use of an
extended retention time can also improve overall
cyanide destruction. Figure 8-9 is a diagram of
an alkaline chlorination system.
In alkaline chlorination using gaseous
chlorine, the oxidation process is accomplished
by direct addition of chlorine (C12) as the oxidizer
and sodium hydroxide (NaOH) to maintain pH
levels. The reaction mechanism is as follows:
NaCN + C12 + 2NaOH
- NaCNO + 2NaCl + H2O-
2NaCNO + 3C12 + 6NaOH
- 2NaHCO3 + N2 + 6NaCl + 2H2O
• The destruction of the cyanide takes place in
iwo stages. The primary reaction is the partial
oxidation of the cyanide to cyanate at a pH
above 9. In the second stage, .the pH is lowered-,
to a range of 8 to 8.5 for the oxidation of the
cyanate to nitrogen and carbon dioxide (as
sodium bicarbonate). Each part of "cyanide
requires 2.73 parts of chlorine to convert it to- -
cyanate and an additional 4.1 parts of chlorine to
oxidize the cyanate to nitrogen and carbon
dioxide. At least 1.125 parts of sodium
hydroxide are required to control the pH with
each stage.
Alkaline chlprination can also be conducted
with sodium hypochlorite (NaOCl) as the
oxidizer. The oxidation of cyanide waste using
sodium hypochlorite is similar to the gaseous
chlorine process. The reaction mechanism is:
NaCN + NaOCl - NaCNO + NaCl
2NaCNO + 3NaOCl + H2O
- 2NaHCO3 + N2 + 3NaCl
In the first step, cyanide is oxidized to
cyanate with the pH maintained in the range of 9
to. 11. The second step oxidizes cyanate to
carbon dioxide (as sodium bicarbonate) and
nitrogen at a controlled pH of 8.5. The amount
of sodium hypochlorite and sodium hydroxide
needed to perform the oxidation is 7.5 parts and
8 parts per part of cyanide, respectively.
8-16
-------
Chabter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Sulhirlc
Acid
Treatment
Chemical
.V:- V
pH Controller
Wastewater
Influent
Chemical Controller
-Treated
Effluent
Reaction Tank
Figure 8-8. Chromium Reduction System Diagram
8-17
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Caustic Feed
Hypochlorite or Chlorine Feed
Wastewater ^
Influent —
Acid Feed
Treated
Effluent
First Stage
> '
Second S
age
Figure 8.9 Cyanide Destruction by Alkaline Chlorination
8-18
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
INDUSTRY PRACTICE
Of the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning the use of cyanide
destruction, 22 operate cyanide destruction
systems. All of the 22 facilities are in the metals
subcategory. Of these 22 facilities, one is a
thermal unit, one is the CBI unit, and the rest are
chemical reagent systems.
Chemical Precipitation
8.2.2.8
. GENERAL DESCRIPTION
Many ' CWT facilities „ use- chemical-
precipitation to remove metal compounds from
wastewater. Chemical precipitation converts
soluble, metallic ions and certain anions to
insoluble forms, which precipitate-from solution-
Chemical precipitation is usually-performed in-
conjunction with coagulation/flocculation
processes which facilitate the "agglomeration'of
suspended and colloidal material. Most metals
are relatively insoluble as hydroxides, sulfides, or
carbonates. Coagulation/flocculation processes
are used in conjunction, with precipitation 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 separation).
Other treatment processes such as equalization,
or chemical oxidation or reduction (e.g.,
hexavalent chromium reduction) usually precede
the chemical precipitation process. Chemical
interactions, temperature, pH, solubility of waste
contaminants, and mixing effects all affect the
performance of the chemical precipitation
process.
Chemical precipitation is a two-step process.
At CWT facilities, it is typically performed in
batch operations. In the first step, precipitants
are mixed with the wastewater, typically by
mechanical means, such as mixers, allowing the
formation of the insoluble metal precipitants.
The detention time in this step of the process is
specific to the wastewater being treated, the
treatment chemicals used, and the desired
effluent quality. In the second step, the
precipitated metals are removed from the
wastewater, typically through filtration or
clarification. If clarification is used, a flocculent
is sometimes added to aid 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 8-10.
Various chemicals may be used as
precipitants. These include lime,' sodium
hydroxide (caustic), soda ash, sodium sulfide,
and ferrous sulfate- Other chemicals used in the,
precipitation process for pH adjustment and/or
coagulation include sulfuric-andphosphoric.acid,,.
ferric chloride, and pblyelectrolytes. Often,
facilities use a combination of these chemicals.
CWT facilities -generally use hydroxide
precipitation and/or sulfide-- precipitation.
Hydroxide precipitation is effective in removing
metals such as antimony, arsenic, chromium,
copper, lead, mercury, nickel, and zinc. Sulfide-
precipitation is used instead of, or in addition to,
hydroxide precipitation to remove specific metal
ions including lead, copper, silver, cadmium,
zinc, mercury, nickel, thallium, arsenic,
antimony, and vanadium. Both hydroxide and
sulfide precipitation are discussed in greater detail
below.
8-19
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Wastewater
Influent
I
Treatment Chemical
do
, „
Chemical Controller
Chemical Precipitation Tank
->-Treated
Effluent
Figure 8-10. Chemical Precipitation System Diagram
8-20
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
Hydroxide precipitation using lime or caustic
is the most commonly-used means of chemical
precipitation at CWT facilities. Of these, lime is
used more often than caustic. The reaction
mechanism for each of these is as follows:
Ca(OH)2 - M(OH)2i
2NaOH - M(OH)2l
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 also produces a larger volume of sludge
than caustic, and the sludge- is generally not
suitable for reclamation due to its homogeneous
nature.
Sulfide precipitation is the next most
commonly-used meansrofchemicarprecipitation-
at CWT facilities. It is used to remove lead,
copper, silver, cadmium, zinc, mercury, nickel; '
thallium, arsenic, antimony, and vanadium from
wastewaters: An advantage of the sulfide
process over the hydroxide process is that it can
reduce hexavalent chromium to the trivalent state
under the same process conditions required for
metals precipitation. The use of sulfides also
allows for the precipitation of metals when
chelating agents are present. The two most
common sulfide precipitation processes are the
soluble sulfide process and the insoluble sulfide
(Sulfex) process.
In the soluble sulfide process, either sodium
sulfide or sodium hydrosulfide, both highly
soluble, is added in high concentration either as
a liquid reagent or from rapid mix tanks using
solid reagents. This high concentration of
soluble sulfides results in rapid precipitation of
metals which then results in the generation of
fine precipitate particles and hydrated colloidal
particles. These fine particles do not settle or
filter well without the addition of coagulating and
flocculating agents to aid in the formation of
larger, fast-settling floe. The high concentration
of soluble sulfides may also lead to the
generation of highly toxic and odorous hydrogen
sulfide gas. To control this problem, the
treatment facility must carefully control the
dosage and/or the process vessels must be
enclosed and vacuum evacuated. The reaction
mechanism for soluble sulfide precipitation is as
follows:
MT +S" - MSI
The basic principle governing the insoluble
sulfide process is that ferrous sulfide- (FeS)- will--
disassociate into ferrous and sulfide ions, as
predicted by its solubility, producing a sulfide
concentration of approximately 2 mg/1 under
normal conditions..^ In the insoluble sulfide
process, a slurry, of ... freshly- prepared FeS
(prepared by reactive FeSO4 and NaHS) is added
to the wastewater. As the sulfide ions are
consumed in precipitating the metal pollutants,
additional FeS will disassociate. This will
continue as long as other heavy metals with
lower, equilibrium constants are present in
solution. Because most heavy metals . have
sulfides that are less soluble than ferrous sulfate,
they will precipitate as metal sulfides. In
addition, if given enough time, any metal
hydroxides present will dissolve and precipitate
out as sulfides. If the operation is performed
under alkaline conditions, the released ferrous
ion will precipitate out as a hydroxide. The
following reactions occur when FeS is added to
a solution that contains dissolved metal and metal
hydroxide: , •
M++ +S" -* MSI
M(OH)2- M++
One advantage of the insoluble sulfide
process over the soluble sulfide process is that
8-21
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
the insoluble sulfide process generates no
detectable H2S gas odor. This is because the
dissolved sulfide concentration is maintained at a
relatively low concentration. Disadvantages of
the insoluble sulfide process include considerably
higher than stoichiometric reagent consumption
and significantly higher sludge generation than
either the hydroxide or soluble sulfide process.
Wastewater treatment facilities often choose
to combine hydroxide precipitation and sulfide
precipitation for optimal metals removal. A
common configuration is a two-stage process in
which hydroxide precipitation is followed by
sulfide precipitation with each stage followed by
a separate solids removal step. This will produce
the high quality effluent of the sulfide
precipitation process while significantly reducing-
the volume of sludge generated and the
consumption of sulfide reagent.
In addition to the type of treatment chemical
chosen, another important operational variable in
chemical precipitation is pH.- Metal hydroxides
are amphoteric, meaning 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 hydroxide precipitation for each metal, which
corresponds to its point of minimum solubility.
Figure 8-11 presents calculated solubilities of
metalhydroxides. For example, as demonstrated
in this figure, the optimum pH range where zinc
is the least soluble is between 8 and 10. The
solubility of metal sulfides is not as sensitive to
changes in pH as hydroxides and generally
decreases as pH increases. The typical operating
pH range for sulfide precipitation is between 7
and 9. Arsenic and antimony are exceptions to
this rule and require a pH below 7 for optimum
removal. As such, another advantage of sulfide
precipitation over hydroxide precipitation is that
.most metals can be removed to extremely low
concentrations at a single pH.
For Wastewater contaminated with a single ,
metal, selecting the optimum treatment chemical
and treatment pH for precipitation simply
requires the identification of the treatment
chemical/pH combination that produces the
lowest solubility of that metal. This is typically
done using a series of bench-scale treatability
tests. . However, when wastewater is
contaminated with more than one metal, as is
often the case for wastewaters at CWT facilities,
selecting the optimum treatment chemical and
pH for a single-stage precipitation process
becomes more difficult and often involves a
tradeoff between optimal removal* of'two or
more metals. In general, for wastewater
contaminated with multiple metals, EPA has
concluded that a single-stage precipitation
process does not pro vide for adequate treatment.
In such cases, a- series of chemical treatment
steps using different pH values and/or different
treatment chemicals may be more appropriate.
Each of these- -treatment steps- needs-to -be-
followed by-a-soh"ds separation step in order to
prevent the resolubilization of metal precipitates
during the subsequent treatment step.
8-22
-------
Chanter 8 Wastewater Treatment Technologies Development Document for the CWTPoint Source Category
100
10 12 14
0.0001
Figure 8-11. Calculated Solubilities of Metal Hydroxides
8-23
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
In order to take advantage of the effects of
pH and treatment chemical selection on metals
precipitation, a facility may hold its wastes and
segregate them by pollutant content for
treatment This type of waste treatment
management, called selective metals
precipitation, may be adopted in order to.
optimize the recovery of specific metal
pollutants. In instances where the segregated
wastes contain several metals, the pH of the
precipitation process may be adjusted so that the
desired metal for recovery, is precipitated in
greater proportion than the other metals.
Multiple precipitation steps are then performed in
series on a single waste stream using different pH.
values, resulting in different metals being
selectively precipitated into separate sludges.
The production of specific sludges containing
only the target metals makes the sludges more
suitable for reclamation. If the sludge is to be
sold to a smelter for re-use, then hydroxide
precipitation using- only caustic- should™ be-
performed. The calcium compounds from lime
would interfere with the smelting process.
Selective precipitation is advantageous
because the metals may be reclaimed and re-
used rather than disposed as a sludge in a landfill
and because it allows for optimal removal of the
metals of concern. However, selective metals
precipitation does have additional costs such as
those associated with the extra tanks and
operating personnel required for waste
segregation.
INDUSTRY PRACTICE
Of the 116 CWT facilities in EPA's WTI
Questionnaire and NOA comment data base that
provided information concerning the use of
chemical precipitation, 57 operate chemical
precipitation systems. Fifty-one of these
facilities treat metals subcategory wastewaters.
As discussed previously, a single facility may use
several chemical precipitation steps, depending
upon the type of waste being treated. Of the 51
chemical precipitation systems at metals
subcategory facilities, 13 operate secondary
precipitation processes, four operate tertiary
precipitation processes, and one employs
selective chemical precipitation processes.
Filtration
8.2.2.9
Filtration is a method for separating solid
particles from a fluid through the use of a porous
medium. The driving force in filtration is a
pressure gradient caused by gravity, centrifugal
force, pressure, or a vacuum. CWT facilities use
filtration treatment processes to remove solids
from wastewaters after physical/chemical or
biological treatment, or as the primary source of
waste treatment. Filtration processes utilized in
the CWT • industry include a broad range of
media and membrane separation technologies.
To aid in removal, the filter medium may be
precoated with a filtration aid such as ground
cellulose.ordiatomaceous earth. Polymers are
sometimes injected" into the filter feed" piping.
downstream.,..of,., feed ..pumps to enhance
flocculation of smaller floes to improve splids
capture. The following sections discuss the
various types of filtration in use at CWT
facilities.
1. SAND FILTRA TION
GENERAL DESCRIPTION
Sand filtration processes consist of either a
fixed or moving bed of media that traps and
removes suspended solids from water passing
through, the media. There are two types of fixed
sand bed filters: pressure and gravity. Pressure
filters contain media in an enclosed, watertight
pressure vessel and require a feed pump to force
the water through the media. A gravity filter
operates on the basis of differential pressure of a
static head of water above the media, which
causes flow through the filter. Filter loading rates
for sand filters are typically between 2 to 6
gpm/sq-ft.
8-24
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
Fixed media filters have influent and effluent
distribution systems consisting of pipes and
fittings. A stainless steel screen covered with
gravel generally serves as the tank bottom and
support for the sand. Dirty water enters the top
of the filter and travels downward.
Moving bed filters use an air lift pump and
draft tube to recirculate sand from the bottom to
the top of the filter vessel, which is usually open
at the top. Dirty water entering the filter at the
bottom must travel upward, countercurrently,
through the downward moving fluidized sand
bed. Particles are .strained from the-rising water
and carried downward with the sand. Due to the
difference in specific gravity, the lighter particles
are removed from the filter when the sand is
recycled through a separation box often located
at the top of the filter. The heavier sand falls
back into the filter, while the lighter particles are
washed over-a weir-to -waste.- —
Both fixed media and moving bed filters
build up Head'loss over time. Head loss is a
measure of solids trapped in the filter. As the
filter becomes filled-with trapped solids, .the—
efficiency of the filtration process falls off, and
the filter must be backwashed. Reversing the
flow will backwash filters so that the solids in the
media are dislodged and may exit the filter.
Sometimes air is dispersed into the sand bed to
scour the media.
Fixed bed filters may be automatically
backwashed when the differential pressure
exceeds a preset limit or when a timer starts the .
backwash cycle. A supply of clean backwash
water is required. Backwash water and trapped
particles are commonly discharged to an
equalization tank upstream of the wastewater
treatment system's gravity separation system or
screen for removal. Moving bed. filters are
continuously backwashed and have a constant
rate of effluent flow.
INDUSTRY PRACTICE
Of the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning use of sand filtration,
eight operate sand filtration systems.
2. MULTIMEDIA FILTRATION
GENERAL DESCRIPTION
CWT facilities may use multimedia, or
granular bed, filtration to achieve supplemental
removal of residual suspended solids from the
effluent of chemical and biological treatment
processes. In granular bed filtration, the
wastewater stream is sent through a bed
containing two 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 xoal,-sand, and-garnet.. _
-A multimedia filter is designed so that the
finer, denser media is at the bottom and the
coarser, less dense media at the top. A common
arrangement is garnet at the bottom of the bed,
sand in the middle, and anthracite coal at the top.
Some mixing of these layers occurs and is
anticipated. During filtration, the removal of the
suspended solids is accomplished by a complex
process involving one or more mechanisms such
as straining, sedimentation, interception,
impaction, and adsorption. The medium size is
the principal characteristic, that affects the
filtration operation. If the medium is too small,'
•much of the driving force will be wasted in
overcoming the frictional resistance of the filter
bed. If the medium is too large, small particles
will travel through the bed, preventing optimum
filtration.
By designing the filter bed so that pore size
decreases from the influent to the effluent side of
the bed, different size particles are filtered out at
different depths (larger particles first) of the filter
bed. This helps prevent the build up of a single
8-25
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
layer of solids at the bed surface which can
quickly increase the pressure drop over the bed
resulting in shorter filter runs and more frequent
backwash cycles. Thus, the advantage of
multimedia filtration over sand filtration is longer
filter runs and less frequent backwash cycles.
The flow pattern of multimedia filters is
usually top-to-bottom. Upflow filters, horizontal
filters, and biflow filters are also used. Figure 8-
12 is a top-to-bottom multimedia filter. The
classic multimedia filter operates by gravity.
However, pressure filters are occasionally used.
The complete filtration process involves two
phases: filtration and backwasbing. 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 value, the end of the filter run is reached
and the filter must-be backwashed-to-remove the
suspended solids in the bed. During
backwasbing, 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. Backwash water and trapped particles
are commonly discharged to an equalization tank
upstream of the wastewater treatment system's
gravity separation system or screen for removal.
An important feature in filtration and
backwashing is the underdrain. The underdrain
is the support structure for the filtration bed.
The underdrain provides an area for the
accumulation of the filtered water without it
being clogged from the filtered solids or the
media particles. During backwash, the
underdrain provides even flow distribution over
thebed. This is important because the backwash
flowrate is set so that the filter bed expands but
the media is not carried out with the backwashed
solids. The media with different densities then
settle back down in somewhat discrete layers at
the end of the backwash step.
INDUSTRY PRACTICE
Of the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning use of multimedia
filtration, four operate multimedia filtration
systems.
3. PLATE AND FRAME PRESSURE FILTRATION
GENERAL DESCRIPTION
Another filtration system for the removal of
solids from waste streams is a plate and frame
pressure filtration systems. Although plate and
frame filter presses are more commonly used for
dewatering sludges, they are also used to remove
solids directly from wastewater streams. The
liquid stream plate and frame pressure filtration
system is identical to the system used for the
sludge stream (section 8.4.1) with the exception
of. a, lower solids level in the.influent stream.
The same equipment is used for- both
applications, with the difference being the sizing._
of the sludge and liquid units. See section 8.4.1
for a detailed description of plate and -frame ,
pressure filtration. No CWT facilities in EPA's
database use plate and frame filtration.
8-26
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWTPoint Source Category
Wastewater Influent
Coarse Media—>
Finer Media —>
Finest Media
Support
Underdrain Chamber.
Backwash
Backwash
Treated Effluent
Figure 8-12. • Multi-Media Filtration System Diagram
, ' 8-27
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
4. MEMBRANE FILTRATION
GENERAL DESCRIPTION
Membrane filtration systems are processes
which employ semi-permeable membranes and
a pressure differential to remove solids in
wastestreams. Reverse osmosis and
ultrafiltration are two commonly-used membrane
filtration processes,
A. ULTRAFILTRATION
GENERAL DESCRIPTION
CWT facilities commonly use ultrafiltration
(UF) for the treatment of metal-finishing
wastewater and oily wastes. It" can remove
substances with molecular weights greater than
500, including suspended solids, oil and grease,
large organic molecules, and complexed heavy
metals. UF can be used when.: the- solute
molecules are greater than ten times the size of
the solvent molecules, and are less than one-half
micron. In the CWT industry, UF is applied in
the treatment of oil/water emulsions. Oil/water
emulsions contain both soluble and insoluble oil.
Typically the insoluble oil is removed from the
emulsion by gravity separation assisted by
emulsion breaking. The soluble oil is then
removed by UF. Oily wastewater containing 0.1
to 10 percent oil can be effectively treated by
UF. Figure 8-13 shows a UF system.
In UF, a semi-permeable microporous
membrane performs the separation. Wastewater
is sent through membrane modules under
pressure. Water and low-molecular -weight
solutes (for example, salts and some surfactants)
pass through the membrane and are removed as
permeate. Emulsified oil and suspended solids
are rejected by the membrane and are removed
as concentrate. The concentrate is recirculated
through the membrane unit until the flow of
permeate drops. The permeate may either be
discharged or passed along to another treatment
unit. The concentrate is contained and held for
further treatment or disposal. An important
advantage of UF over reverse osmosis is that the
concentrate, may be treated to remove the
concentrated solids and the separated water may
then be retreated through the UF system.
The primary design consideration in UF 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, pressure differential, and the
membrane permeability and thickness. The rate
at which a membrane fouls is also an important
design consideration.
INDUSTRY PRACTICE
Of the 116 CWT facilities in EPA's WTI
Questionnaire and NOA comment data base that
provided- information- concerning use of
ultrafiltration, six operate ultrafiltration systems.
B. REVERSE OSMOSIS
GENERAL DESCRIPTION
Reverse osmosis (RO) is a process for
separating dissolved solids from water. CWT
facilities commonly use RO in treating oily or
metal-bearing wastewater. RO is applicable
when the solute molecules are approximately the
same size as the solvent molecules. A
semi-permeable, microporous membrane and
pressure are used to perform the separation. RO -'
systems are typically used as polishing processes,
prior to final discharge of the treated wastewater.
Reverse osmosis systems have been
demonstrated to be effective in removing,
dissolved metals.
8-28
-------
Chanter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Permeate (Treated Effluent)
Wastewater
Feed
Concentrate
Membrane Cross-section
Figure 8-13. Ultrafiltration System Diagram
8-29
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
Osmosis is the diffusion of a solvent (such as
water) across a semi-permeable membrane from
a less concentrated solution into a more
concentrated solution. In the reverse osmosis
process, pressure greater than the normal
osmotic pressure is applied to the more
concentrated solution (the waste stream being
treated), forcing the purified water through the
membrane and into the less concentrated stream
• which is called the permeate. The low-
molecular-weight solutes (for example, salts and
some surfactants) do not pass through the
membrane. They are'referred to as concentrate.
The concentrate is recirculated through the
membrane unit until the flow of permeate drops.
The permeate can either be discharged or passed
alongtoanothertreatmentunit.- The concentrate
is contained and held for further treatment or
disposal. Figure 5M4 shows an RO system.
The performance of an RO system is
dependent upon the dissolved solids
concentration and temperature of the feed
stream, the applied pressure, and the type of
membrane selected. The key RO membrane
properties to be considered are: selectivity for
water over ions, permeation rate, and durability.
RO modules are available in various membrane
configurations, such as spiral-wound, tubular,
hollow-fiber, and plate and frame. In addition to
the membrane modules, other capital items
needed for an RO installation include pumps,
piping, instrumentation, and storage tanks. The
major operating cost is attributed to membrane
replacement. A major consideration for RO
systems is the disposal of the concentrate due to
its elevated concentrations of salts, metals, and
other dissolved solids.
INDUSTRY PRACTICE
Of the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning use of reverse osmosis,
two operate reverse osmosis systems.
5. LANCYFILTRATION
GENERAL DESCRIPTION
The Lancy Sorption Filter System is a
patented method for the continuous recovery of
heavy metals. The Lancy sorption filtration
process-may reduce metals not-removed by
conventional waste treatment technologies to low
concentrations.
In the first stage of the Lancy filtration
process, a soluble sulfide is added to the
wastewater in a reaction tank, converting most of
the heavy metals to sulfides. From the sulfide
reaction tank, the solution is passed through the
sorption filter media. Precipitated metal sulfides
and other suspended solids are filtered out. Any
remaining.soluble metals are absorbed by the
media. Excess soluble sulfides are also removed
from the waste stream.
The Lancy filtration process reportedly
reduces zinc, silver, copper, lead, and cadmium
to less than 0705~mg/l and mercury to less than 2
Aig/L In addition to the effective removal of
heavy metals, the. system has a high solids
filtration capacity and a fully automatic,
continuous operation. The system continuously
recycles and reuses the same filter media thereby
saving on operating costs. The system may be
installed with a choice of media discharge - slurry
or solid cake. Figure 8-15 illustrates the Lancy
Sorption Filtration System.
8-30
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
Wastewater
Feed-
Permeate (Treated Effluent)
Concentrate
Membrane Cross-section
Figure 8-14. Reverse Osmosis System Diagram
8-31
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Wastewater
brilliant
3 ,
Recycle
Tank
Figure 8-15. Lancy Filtration System Diagram
8-32
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
INDUSTRY PRACTICE .
Of the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning use of filtration systems,
only one operates the Lancy Sorptidn Filtration
System. This unit is used for polishing effluent
from a treatment sequence including chemical.
precipitation, clarification, and sand filtration.
EPA obtained performance data for. this system
during a,sampling episode at one of the metals
subcategory facilities. The performance data
showed that some metals were reduced to the
target levels while the concentration of some
pollutants increased. This may not represent
optimal performance of the system, however,
because the facility reported that they were
experiencing operational problems throughout the
sampling episode. • .
Carbon Adsorption
8.2.2.10
GENERAL DESCRIPTION
Activated carbon adsorption is a---
demonstrated wastewater treatment technology
that uses activated carbon to remove dissolved
organic pollutants from wastewater. The
activated carbon is. made from many
carbonaceous sources including coal, coke, peat,
wood, and coconut shells. The carbon source
material is "activated" by treating it with an
oxidizing gas to form a highly porous structure
with a large internal surface area. CWT facilities
generally use granular forms of activated carbon
(GAC) in fixed bed columns to treat wastewater.
However, some use powdered activated carbon
(PAC) alone or in conjunction with biological
treatment. Figure 8-16 presents a diagram of a
fixed-bed GAC collumn.
In a fixed bed system, the wastewater enters
the top of the unit and is allowed to flow
downward through a bed of granular activated
carbon. As the wastewater comes into contact
with the activated carbon, the dissolved organic
compounds adsorb onto the surface of the
activated carbon. In the upper area of the bed,
the pollutants are rapidly adsorbed. As more
wastewater passes through the bed, this rapid
adsorption zone moves downward until it
reaches the bottom of the bed. At this point, all
of the available adsorption sites are filled and the
carbon is said to be exhausted. This condition
can be detected by an increase in the effluent
pollutant concentration, and is called
breakthrough.
GAC systems are usually comprised of
several beds operated in series. This design
allows the first bed to go to exhaustion, while the
other beds still have the capacity to treat to an
acceptable effluent quality. The carbon in the
first bed is replaced, and the second bed then
becomes the lead bedr The^GAC system piping-
is designed to allow switching of bed order.
After the carbon is exhausted, it can be,
removed and regenerated. Usually heat or steam
is .used to reverse the adsorption process. The
light organic compounds are volatilized and the
heavy organic compounds are pyrolyzed. Spent
carbon may also be regenerated by contactingit
with a solvent which dissolves the adsorbed
pollutants. Depending on system size and
economics, some facilities may choose to dispose
of the spent carbon instead of regenerating it.
For very . large applications, an on-site
regeneration facility is more economical. For
smaller applications, such as in the CWT
industry, it is generally cost-effective to use a
vendor service to deliver regenerated carbon and
remove the spent carbon. These vendors
transport the spent carbon to their centralized
facilities for regeneration..
8-33
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
Fresh
Carbon
Fill
Collector/
Distributor"
Spent
Carbon -<-
Discharge
Wastewater
Influent
Backwash
Backwash
Treated
Effluent
Figure 8-16. Carbon Adsorption System Diagram
8-34
-------
Chanter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
The carbon adsorption mechanism is
complicated and, although the attraction is
primarily physical, is a combination of physical,
chemical, and electrostatic interactions between
the activated carbon and the organic compound.
The key design parameter for activated carbon is
the adsorption capacity of the carbon. The
adsorption capacity is a measure of the mass of
contaminant adsorbed per unit mass of activated
carbon and is a function of the compound being
adsorbed, the type of carbon used, and the
process design and operating conditions. In
general, the adsorption capacity is inversely
proportional to the adsorbate solubility.
Nonpolar, high molecular weight orgahics with
low, solubility are readily adsorbed. Polar, low
molecular weight organics with high solubilities
are more poorly adsorbed. ''_"..'—- .
Competitive adsorption between compounds
has an effect on adsorption. The carbon may
preferentially adsorb one compound over
another. This competition could result in an
adsorbed compound being desorbed 'fronrthe
carbon. This is most pronounced when carbon
adsorption is used to treat wastewater with highly
variable pollutant character and concentration.
INDUSTRY PRACTICE
Of the 116 CWT facilities 'in EPA's WTI
Questionnaire andNOA comment data base that
provided information concerning use of carbon
adsorption, 17 operate carbon adsorption
systems.
Ion Exchange
8.2.2.11
GENERAL DESCRIPTION
A common process employed to remove
heavy metals from relatively low-concentration
waste streams, such as electroplating wastewater,
is ion exchange. A key advantage of the ion
exchange process is that the metal contaminants
can be recovered and reused. Another
advantage is that ion exchange may be designed
to remove certain metals only, providing
effective removal of these metals from highly-
contaminated wastewater. A disadvantage is that
the resins may be fouled by some organic
substances.
In an ion exchange system, the wastewater
stream is passed through a bed of resin. The
resin contains bound groups of ionic charge on
its surface, which are exchanged for ions of the
same charge in the wastewater. Resins are
classified by type, either cationic or anionic. The
selection is dependent upon the wastewater
contaminant to be removed. A commonly-used
resin is polystyrene copolymerized with
divinylbenzene.
The ion exchange process involves four
steps: treatment, backwash, regeneration, and
rinse. During the treatment step, wastewater is
passed: through, the:-resin- bed ..and ions are
exchanged until pollutant breakthrough occurs.
The resin is then backwashed to reclassify the
bed and to remove suspended solidsr During the
regeneration step, the" resin is contacted with
1 • either an 'acidic or 'alkaline solution containing
high concentrations of the ion originally present
in the resin. This "reverses" the ion exchange
process and removes the metal ions from the
resin. The bed is then rinsed to remove residual
regenerating solution. The resulting
contaminated regenerating solution must be
further processed for reuse or disposal.
Depending upon system size and economics,
some facilities choose to remove the spent resin
and replace it with resin regenerated off-site
instead of regenerating the resin in-place.
Ion exchange equipment ranges from simple,
inexpensive systems such as domestic water
softeners, to large, continuous industrial
applications. The most commonly-encountered
industrial setup is a fixed-bed resin in a vertical
column, where the resin is regenerated in-place.
Figure 8-17 is a diagram of this type of system.
These systems may be designed so that the
regenerant flow is concurrent or countercurrent
8-35
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
to the treatment flow. A countercurrent design,
although more complex to operate, provides a
higher treatment efficiency. The beds may
contain a single type of resin for selective
treatment, or the beds may be mixed to provide
for more complete deionization of the waste
stream. Often, individual beds containing
different resins are arranged in series, which
makes regeneration easier than in the .mixed bed
system.
INDUSTRY PRACTICE
EPA is aware'of only one CWT facility
using ion exchange.
Electrolytic Recovery
8.2.2.12
GENERAL DESCRIPTION
Another process for reclaiming metals from
wastewater is electrolytic recovery. It is a
common technology in the electroplatingrmining,
and electronic industries. It is-used for the
recovery of copper, zinc, silver, cadmium, gold,
and other heavy metals. Nickel is poorly
recovered due to its low standard potential.
The electrolytic recovery process uses an
oxidation and reduction, reaction. Conductive
electrodes (anodes and cathodes) are immersed
in the metal-bearing wastewater, with an electric
potential applied to them. At the cathode, a
metal ion is reduced to its elemental form
(electron-consurning reaction). At the same
time, gases such as oxygen, hydrogen, or
nitrogen form at the anode (electron-producing
reaction). After the metal coating on the cathode
reaches a desired thickness, it may be removed
and recovered! The metal-stripped cathode can
then be used as the anode.
The' equipment consists of an
electrochemical reactor with electrodes, a gas-
venting system, recirculation pumps, and a
power supply. Figure 8-18'ia a diagram of an
electrolytic recovery system. Electrochemical
reactors are typically designed to produce high
flow rates to increase the process efficiency.
A conventional electrolytic recovery system
is effective for the recovery of metals from
relatively high-concentration wastewater. A
specialized adaptation of electrolytic recovery,
called extended surface electrolysis, or ESE,
operates effectively at lower concentration levels.
The ESE system uses a spiral cell containing a
flow-through cathode which has a very open
structure and therefore a lower resistance to fluid
flow. This also provides a larger electrode
surface. ESE systems are often used for the
recovery of copper,. lead, mercury, silver, and
gold.
INDUSTRY PRACTICE
Of the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning use of electrolytic
recovery,,, three,, operate, electrolytic recovery
systems. -
8-36
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Wastewater
Influent
Used
Regenerant
Regenerant
Solution
Distributor
Support
Treated
Effluent
Figure 8-17. Ion Exchange System Diagram
8-37
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
++
M +20-->4JI
Deposited
Metal
Porous Insulating Separator
1/20.
Figure 8-18. Electrolytic Recovery System Diagram
8-38
-------
Chanter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
Stripping
8.2.2.13-
Stripping is a method for removing dissolved
volatile organic compounds from wastewater.
The removal is accomplished by passing air or
steam through the agitated waste stream. The
primary difference between air stripping and
steam stripping is that steam stripping is operated
at higher temperatures and the resultant off-gas
stream is usually condensed and recovered or
incinerated. The off-gas from air stripping
contains non-condenseable air which must be
either passed through an adsorption unit or
incinerated in order to prevent transfer of the
volatile pollutants to the environment EPA is
not aware of any applications of steam stripping
technologies in the CWT industry.
1. AIR STRIPPING ~
GENERAL-DESCRIPTION
Air stripping is effective in removing
dissolved volatile organic compounds from
wastewater. The removal is accomplished by
passing high volumes of air through the agitated
wastewater stream. The process results in a
contaminated off-gas stream which, depending
upon air emissions standards, usually requires air
pollution control equipment. Stripping can
be performed in tanks or in spray or packed
towers. Treatment in packed towers is the most
efficient application. The packing typically
consists of plastic rings or saddles. The two
types of towers that are commonly used, cross-
flow and countercurrent, differ in design only in
the location of the air inlets. In the cross-flow
tower, the air is drawn through the sides for the
total height of the packing. The countercurrent
. tower draws the entire air flow from the bottom.
Cross-flow towers have been found to be more
susceptible to scaling problems and are less
efficient than countercurrent towers. Figure 8-19
is a countercurrent air stripper.
The driving force of the air stripping mass-
transfer operation is the difference in
concentrations between the air and water
streams. Pollutants are transferred from the
more concentrated wastewater stream to the less
concentrated air stream until equilibrium is
reached. This equilibrium relationship is known
as Henry's Law. The strippability of a pollutant
is expressed as its Henry's'Law Constant, which-
is a function of both its volatility or vapor
pressure and solubility.
Air strippers are designed according to the
strippability of the pollutants to be removed. For
evaluation purposes, organic pollutants can be
divided into three general strippability ranges
(low, medium, and high) according to then-
Henry's Law Constants. The low strippability
group (Henry's Law Constants of 10"4 [mg/m3
air]/[mg/m3 water] and lower) are not effectively
removed-Pollutants in the medium (10"1 to 10~4)
andhigh^lO"1 and greater) groups are effectively
stripped. Pollutants with lower Henry's law.
constants require greater column height, more
trays or packing material, greater temperature,
and more frequent cleaning than pollutants with
a higher strippability.
The air stripping process is adversely
affected by low temperatures. Air strippers
experience lower efficiencies at lower
temperatures, with the possibility of freezing
within the tower. For this reason, depending on
the location of the tower, it may be necessary to
preheat the wastewater and the air feed streams.
The column and packing materials must be
cleaned regularly to ensure that low effluent
levels are attained.
8-39
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
Wastewater
Influent
Blower
Off-gas
Distributor
Support
Treated
Effluent
Figure 8-19. Air Stripping System Diagram
8-40
-------
'Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
Air stripping has proved to be an effective
process in the removal of volatile pollutants from
wastewater. It is generally limited to influent
concentrations of less than 100 mg/1 organics.
Well-designed and operated systems can achieve
over 99 percent removals.
INDUSTRY PRACTICE
Of the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning use of air stripping, 11
operate air stripping systems.
Liquid Carbon Dioxide Extraction 8.2.2.14
GENERAL DESCRIPTION
Liquid carbon dioxide (CO2) extraction is a
process used to' extract and recover organic
contaminants from aqueous waste streams. A
licensed, commercial application of .this~
technology is utilized in the-GWT industry under
the name "Clean Extraction System" (CES).
The process may be effective in the-removal of
organic substances such as hydrocarbons,
aldehydes and ketones, nitriles, halogenated
compounds, phenols, esters, and heterocyclics.
It is not effective in the removal of some
compounds which are Very water-soluble, such
as ethylene glycol, and low molecular weight
alcohols., It may provide an alternative in the
treatment of waste streams which historically
have been incinerated.
In liquid carbon dioxide extraction, the waste
stream is fed into the top of a pressurized
extraction tower containing perforated plates,
where it is contacted with a countercurrent
stream of liquefied CO2. The organic
contaminants in the waste stream are dissolved in
the CO2; this extract is then sent to a separator,
where the CO2 is redistilled The distilled CO2
vapor is compressed and reused. The
concentrated organics bottoms from the
separator can then be disposed or recovered.
The treated wastewater stream which exits the
extractor (raffinate) is pressure-reduced and may
be further treated for residual organics removal
if necessary to meet discharge standards. Figure
8-20 is a diagram of the CES is presented in.
INDUSTRY PRACTICE
EPA is aware of only one facility using this
technology in the CWT industry.- Pilot-scale
information submitted to EPA by the CWT
facility showed effective removal for a variety of
organic compounds. EPA sampled, this
commercial CWT CES unit during this
rulemaking effort.. Performance was not
optimal, however, as the facility reported
operational problems with the unit throughout the
sampling episode.
Biological Treatment
8.2.3
A portion of the CWT industry accepts •
waste receipts that contain organic pollutants,
which are often amenable to biological
degradation.' This subset of CWT facilities is
referred to as the organics subcategory. In
addition, a portion of the facilities in the oils
subcategory also use biological treatment to treat
wastewater separated from oily wastes.
Biological treatment systems use microbes •
which consume, and thereby destroy, organic
compounds as a food source. The microbes use
the organic compounds as both a source of
carbon and as a source of energy. These
microbes may also need supplemental nutrients
for growth, such as nitrogen and phosphorus, if
the waste stream is deficient in these nutrients.
Aerobic microbes require oxygen to grow,
whereas anaerobic microbes will grow only in the
absence of oxygen. Facultative microbes are an
adaptive type of microbe that can grow with or
without oxygen.
8-41
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Extract
Vapor CO2
Feed
MNHIIIM^
I
Extractor
Liquid CCfe
js:
I
Separator
Makeup
CO,
Compressor
Water
Organic*
Figure 8-20. - Liquid CO2 Extraction System Diagram
8-42
-------
Chanter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
The success of biological treatment is
dependent on many factors, such as the pH and
temperature of the wastewater, the nature of the
pollutants, the nutrient requirements of the
microbes, the presence of inhibiting pollutants,
and variations in the feed stream loading.
Certain compounds, such as heavy metals, may
be toxic to the microorganisms and must be
removed from the waste stream prior to
biological treatment. Load variations are a major
concern; especially-irrthe-eWT- industry, where
waste receipts vary over time in both
concentration.and volume.
There are several adaptations of biological-^
treatment.,. These adaptations differ in three. _
basic ways. First, a system may be aerobic,
anaerobic, or facultative. Second, the
microorganisms may either be attached to a
surface (as in a trickling filter), or be unattached"
in a liquid suspension (as in an activated~sludgej
system);* Third, the: operationimay be: eitherr
batch oixcontinuous-
Of the 116 facilities in the WTI-
Questionnaire and NO A comment data base that
responded to EPA's inquiry concerning the use
of biological treatment, 17 operate biological
treatment systems. There were no anaerobic
systems reported. Theses systems include
sequencing batch reactors, attached growth
systems (biotowers and trickling filters) and
activated sludge systems. With the exception of
trickling filters, EPA sampled at least one
application of each of the following biological
treatment technologies during the development of
these effluent guidelines.
Sequencing Batch Reactors
8.2.3.1
GENERAL DESCRIPTION
A sequencing batch reactor (SBR) is a
suspended growth system in which wastewater is
mixed with existing biological fioc in an aeration
basin. SBRs are unique hi that a single tank acts
as an equalization tank, an aeration tank, and a
clarifier. An SBR is operated on a batch basis
where the wastewater is mixed and aerated with
the biological floe for a specific period of time.
The contents of the basin are allowed to settle
and the supernatant is decanted. The batch
operation of an SBR makes it a useful biological
treatment option for the CWT industry, where
the wastewater volumes and characteristics are
often highly-variable. Each batch-can be treated
differently depending on waste characteristics.
Figure 8-21 shows an SBR. -•- -
The SBR has a four cycle process: fill,
react, settle, and decant. The fill cycle has two
phases The first phase, called static fill,
introduces the wastewater to the system under
static conditions. This is an anaerobic period and
may enhance biological phosphorus uptake.
During., the second phase of the fill cycle
wastewater is mechanically mixed to eliminate
the scum.layer and prepare the microorganisms-
to receive oxygen. In the second cycle, the react
cycle, aeration is performed. The react cyclers
a-time-dependent process where wastewater is
continually mixed' and aerated, allowing the
biological degradation process to occur. The
third cycle, called the settling cycle, provides
quiescent conditions throughout the tank and
may accommodate low settling rates by
increasing the settling time. During the last or
decant cycle, the treated wastewater is decanted
by subsurface withdrawal from below the scum
layer. This treated, clarified effluent may then
be further treated or discharged.
8-43
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWTPoint Source Category
Process
Cycle
Fill
React
Settle
Decant
Figure 8-21. Sequencing Batch Reactor System Diagram
8-44
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
When the quantity of biomass hi the SBR
exceeds that needed for operation, the excess
biomass is removed. The sludge that is removed
from the SBR may.be reduced in volume by
thickening and dewatering using any of the
sludge treatment processes discussed in section
8.2.4. The dewatered sludge may be disposed in
a landfill or used as an agricultural fertilizer.
An SBR carries out all of the functions of a
conventional continuous flow activated sludge
process, such as equalization, biological
treatment, and sedimentation, in a time sequence
rather than a space sequence. Detention times
and loadings vary with eachbatch* and~are highly
dependent on the specific raw wastewater
loadings. Typically, an SBR operates with a-
hydraulic detention-time of 1 to, 10 days -and a
sludge retention time of 10 to 30 days. The"
mixed" liquor suspended" solids (MLSS).
concentration is maintained at 3,500 to 10,000
mg/1. The overall control of the system may be
accomplished automatically^ by ~ using' level"
sensors or timing devices. By using a single"tank-
to perform all of the required functions
associated with biological treatment, an SBR
reduces land requirements. It also provides for
greater operation flexibility for treating wastes
with viable .characteristics by allowing the
capability to vary detention time and mode of
aeration in each stage. SBRs also may be used
to achieve complete mtrification/denitrification
and phosphorus removal.
INDUSTRY PRACTICE
EPA is aware of only one CWT facility that
uses an SBR. This facility is in the organics
subcategory, and its SBR unit was sampled
during the development of these effluent
guidelines.
Attached Growth Biological
Treatment Systems
8.2.3.2
Another system used to biodegrade the
organic components of a wastewater is the
attached growth biological treatment system. In
these systems, the biomass adheres to the
surfaces of rigid supporting media. As
wastewater contacts the supporting medium, a
thin-film biological slime develops and coats the
surfaces. As this film (consisting primarily of
bacteria, protozoa, and fungi) grows, the slime
periodically breaks off the medium- and-'is-
replaced by new growth. This phenomenon of
losing the slime layer is called sloughing and is
primarily a function of organic and hydraulic
loadings on the system. The effluent from the
system is usually.discharged to a clarifier to settle
and remove the agglomeratedlolids".
Attached- growth biological-systems_are
appropriate for treating industrial wastewaters
amenable to aerobic biological treatment. When
used hi conjunction with suitable pre- and post-
treatment processes, attached -growth-biological
systems remove suspended and colloidal
materials effectively. The two major types of
attached growth systems used at CWT facilities
are trickling filters and biotowers. This section
describes these processes.
1. TRICKLING FILTERS
GENERAL DESCRIPTION
Trickling filtration is an aerobic fixed-film
biological treatment process that consists of a
structure, packed with inert medium such as
rock, wood, or plastic. The wastewater is
distributed over the upper surface of the medium
by either a fixed spray nozzle system or a
rotating distribution system. The inert medium
develops a biological slime that absorbs and
biodegrades organic pollutants. Air flows
through the filter by convection, thereby
providing the oxygen needed to maintain aerobic
conditions. Figure 8-22 is a flow diagram of a
trickling filter.
8-45
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Figure 8-22. Trickling Filter System Diagram
8-46
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
Trickling filters are classified as low-rate or
high-rate, depending on the organic loading.
Typical design organic loading values range from
5 to 25 pounds and 25 to 45 pounds BOD5 per
1,000 cubic feet per day for low-rate and high-
rate, respectively. A low-rate filter generally has
a media bed depth of 1.5 to 3 meters and does
not use recirculation. A high-rate filter may have
a bed depth from 1 to 9 meters and recirculates
a portion of the effluent for further treatment.
INDUSTRY PRACTICE
EPA is aware of only one CWT facility that
uses a trickling filter. This facility is in the oils
subcategory.
• GENERAL DESCRIPTION
A variation of a trickling filtration process is
the aerobic biotower. Biotowers may be-
operated in a continuous or semi-continuous
manner and may be operated in an upflow or
downflow manner. In the downflow mode,
influent is pumped to the top of a tower, where
it flows by gravity through the tower. The tower
is packed with plastic or redwood media
containing the attached microbial growth.
Biological degradation occurs as the wastewater
passes over the media. Treated wastewater
collects in the bottom of the tower. If needed,
additional oxygen is provided via air blowers
countercurrent to the wastewater flow. In the
upflow mode, the wastewater stream is fed into
the bottom of the biotower and is passed up
through the packing along with diffused air
supplied by air blowers. The treated effluent
exits from the top of the biotower.
Variations of this treatment process involve
the inoculation of the raw influent with bacteria
and the addition of nutrients. Wastewater
collected in the biotowers 'is delivered to a
clarifier to separate the biological solids from the
treated effluent. A diagram of a biotower is
presented in Figure 8-23.
INDUSTRY PRACTICE
EPA is aware of two biotowers in operation
in the CWT Industry. One system treats a waste
stream which is primarily composed of leachate
from an on-site landfill operation. The other
system treats high-TOC wastewater from a
metals recovery operation. EPA conducted
sampling at this facility during the development
of these effluent guidelines.
Activated Sludge
8.2.3.3
GENERAL DESCRIPTION
The activated sludge process is a
continuous-flow, aerobic- biological treatment
process that employs suspended^growth aerobic-
microorganisms to biodegrade organic
contaminants. In this process, a suspension of
aerobic- microorganisms is maintained by
mechanical mixing or turbulence" induced, by-
diffused aerators in an aeration basin. This
suspension of microorganisms is called the mixed
liquor. Figure 8-24 is a diagram of a
conventional activated sludge'system;
8-47
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWTPoint Source Category
Inoculum
Nutrient
Solution
Wastewater
Influent
Treated
Effluent
Blower
Figure 8-23. Biotower System Diagram
8-48
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Secondary
Clarification
Wastewater
Influent
T
Aeration
Basin
Recycled Sludge
Treated
Effluent
Waste
Excess
Sludge
Figure 8-24. Activated Sludge System Diagram
8-49
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
Influent is introduced into the aeration basin
and is allowed to mix with the contents. A series
of biochemical reactions is performed in the
aeration basin, degrading organics and generating
new biomass. Microorganisms oxidize the
soluble and suspended organic pollutants to
carbon dioxide and water using the available
supplied oxygen. These organisms also
agglomerate colloidal and particulate solids.
After a specific contact period in the aeration
basin, the mixture is passed to a settling tank, or
clarifier, where the microorganisms,are separated
from the treated water. A major .portion of the
settled solids in the clarifier is recycled back to
the aeration system to maintain the desired
concentration of microorganisms in the reactor.
The remainder of the settled solids is wasted and
sent to sludge-handling facilities.
To ensure.biological stabilization of organic
compounds in activated sludge systems,
adequate nutrientlevels must be available to the
biomass. The primary nutrients are nitrogen and
phosphorus. Lack of these nutrients can impair
biological activity and result in reduced removal
efficiencies. Certain wastes may have low
concentrations of nitrogen and phosphorus
relative to the oxygen demand. As a result,
nutrient supplements (e.g., phosphoric acid
addition for additional phosphorus) have been
used in activated sludge systems at CWT
faculties.
The effectiveness of the activated sludge
process is governed by several design and
operation variables. The key variables are
organic loading, sludge retention time, hydraulic
or aeration detention time, and oxygen
requirements. The organic loading is described
as the food-to-microorganism (F/M) ratio, or
kilograms of BODS applied daily to the system
per kilogram of mixed liquor suspended solids
(MLSS). The MLSS in the aeration tank is
determined by the rate and concentration of
activated sludge returned to the tank. The
organic loading (F/M ratio) affects the BOD5
removal, oxygen requirements, biomass
production, and the settleabiliry of the biomass.
The sludge retention time (SRT) or sludge age is
a measure of the average retention time of solids
in the activated sludge system. The SRT affects
the degree of treatment and production of waste
sludge. A high SRT results hi a high quantity of
solids in the system and therefore a higher degree
of treatment- while also resulting in the
production of less waste sludge. The hydraulic
detention time determines the size of the aeration
tank and is calculated using the F/M ratio, SRT,
and MLSS. Oxygen requirements are based on
the amount required for .biodegradation of
organic matter and the amount required for
endogenous respiration of the microorganisms.
The.design.parameters will vary with the type of
wastewater to be treated and are usually
determined in a treatability study.
Modifications of the activated:sludge'process;'
are common, as the process is extremely
versatile and can be adapted for a wide variety of
organically contaminated wastewaters. The
typical modification may include a variation of
one or more of the key design parameters,
including the F/M loading, aeration location and
type, sludge return, and contact basin
configuration. The modifications in practice
have been identified by the major characteristics
that distinguish the particular configuration. The
characteristic types and modifications are briefly
described as follows:
• Conventional The aeration tanks are long
and narrow, with plug flow (i.e., little
forward or backwards mixing).
• Complete Mix The aeration tanks are
shorter and wider, and the aerators,
diffusers, and entry points of the influent
and return sludge are arranged so that the
wastewater mixes completely.
8-50
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
Tapered Aeration A modification of the
conventional process in which the diffusers
are arranged to supply more air to the
influent end of the tank, where the oxygen
demand is highest.
Step Aeration A modification of the
conventional process in which the
wastewater is introduced to the aeration tank
at several points, lowering the peak oxygen
demand." "
High Rate Activated Sludge A modification
of conventional or tapered aeration in which
the aeration times are shorter, the pollutants
loadings .are higher per unit mass of
microorganisms'in'the'tank;•- The'rate of
BOD5 removal'forthis process is higherthan
that of conventional activated sludge
processes, but the total removals are lower.
PureOxygen An activated sludge variation
in-which pure oxygen instead-of air is-added
to-the aeration tanks, the tanks are covered,
and the oxygen-containing off-gas is
recycled. Compared to normal air aeration,
pure oxygen aeration requires a smaller
aeration tank volume and treats high-strength
wastewaters and widely fluctuating organic
loadings more efficiently.
Extended Aeration A variation of complete
mix in Which low organic loadings and long
aeration times permit more complete
wastewater degradation and partial aerobic
digestion of the microorganisms.
Contact Stabilization An activated sludge
modification using two aeration stages. In
the first, wastewater is aerated with the
return sludge in the contact tank for 30 to 90
minutes, allowing finely suspended colloidal
and dissolved organics to absorb to the
activated sludge. The solids are settled out
in a clarifier and then aerated in the sludge
aeration (stabilization) tank for 3 to 6 hours
before flowing into the first aeration tank.
• Oxidation Ditch Activated Sludge An
extended aeration process in which aeration
and mixing are provided by brush rotors
placed across a race-track-shaped basin.
Waste enters the ditch at one end, is aerated-
by the rotors, and circulates.
INDUSTRY PRACTICE
Because activated sludge systems are
sensitive to the loading and flow variations
typically found at CWT facilities, equalization is
often" required prior to activated- sludge
treatment. Of the 65 CWT facilities in EPA's.
-WTI Questionnaire data base tHat "provided
information concerning use of activated sludge,.
four operate activated sludge systems.
Sludge Treatment and Disposal
8.2.4
Several of the waste treatment processes
used in the CWT industry generate a sludge.
These processes include chemical precipitation of
metals, clarification, filtration, and biological
treatment. Some oily waste treatment processes,
such as dissolved air flotation and centrifugation,
also produce sludges. These sludges typically
contain between one and five percent solids.
They require dewatering to concentrate them and
prepare them for transport and/or disposal.
Sludges are dewatered using pressure,
gravity, vacuum, or centrifugal force. There are
several widely-used, commercially-available
methods for sludge dewatering. Plate and frame
pressure filtration, belt pressure filtration, and
vacuum filtration are the primary methods used
for sludge dewatering at CWT facilities. A plate
and frame filter press can produce the driest filter
cake of these three systems, followed by the belt
press, and lastly, the vacuum filter. Each of
8-51
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
these sludge dewatering methods are discussed
below.
, In some instances, depending upon the
nature of the sludge and the dewatering process
used, the sludge may first be stabilized,
conditioned, and/or thickened prior to
dewatering. Certain sludges require stabilization
(via chemical addition or biological digestion)
because they have an objectionable odor or are
a health threat Sludges produced by the CWT
industry usually do not fall into this category.
Sludge conditioning is used to improve
dewaterability;:it can be accomplished via the
addition of heat or chemicals. Sludge thickening,
or concentration; reduces the volume of sludge
to be dewatered and is accomplished by gravity
settling, flotation, or centrifugation.
Plate and Frame Pressure Filtration 8.2:4'.'!'
GENERAL DESCRIPTION
Plate and frame pressure filtration systems is
a widely used method for the removal of solids
from waste streams. In the CWT industry, plate
and frame pressure filtration system are used for
filtering solids out of treated wastewater .streams
and sludges. The same equipment is used for
both applications, with the difference being the
solids level in the influent stream and the sizing
of the sludge and liquid units. Figure 8-25 is a
plate and frame filter press.
A plate and frame filter press consists of a
number of recessed filter plates or trays
connected to a frame and pressed together
between a fixed end and a moving end. Each
plate is constructed with a drainage surface on
the depressed portion of the face. Filter cloth is
mounted on the face of each plate and then the
plates are pressed together. The sludge is
pumped under pressure into the chambers
between the plates of the assembly while water
passes through the media "and drams to the
filtrate outlets. The solids are retained in the
cavities of the filter press between the cloth
surfaces and form a cake that ultimately fills the
chamber. At the end of the cycle when the
filtrate flow stops, the pressure is released and
the plates are separated. The filter cake drops
into a hopper below the press. The filter cake
may then be disposed in a landfill. The filter
cloth is washed before the next cycle begins.
The key advantage of plate and frame
pressure filtration is that it can produce a drier
filter cake than is possible with the other
methods of sludge dewatering. In a typical plate
'and frame pressure filtration unit, the filter cake
may exhibit a dry solids content between 30 and
50 percent. It is well-suited for use in the CWT
industry as it is a batch process. However, its
batch operation results in greater operating labor
requirements.
8-52
-------
Chanter 8 Wastewater Treatment Technologies Development Document for the CWTPoint Source Category
8-53
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWT Point Source Category
INDUSTRY PRACTICE
Of the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning the use of pressure
filtration, 34 operate pressure filtration systems.
Of these 34 facilities, 25 operate plate and frame
pressure filtration systems, three operate belt
pressure filtration systems, and six did not
specify the type of presure filtration systems
• utilized.
Belt Pressure Filtration
8.2.4.2
GENERAL DESCRIPTION
A belt pressure filtration system uses gravity
followed by mechanical compression and shear
force to produce a sludge filter cake. Belt filter
presses are continuous-- systems- which,-are--
commonly used to dewater biological treatment
sludge. Most belt filter installations are preceded
by a flocculation step, where polymer is added to
create a sludge which has the strength to
withstand being compressed between the belts
without being squeezed out. Figure 8-26 shows
a typical belt filter press.
Duringthepress operation, the sludge stream
is fed onto the first of two moving cloth filter
belts. The sludge is gravity-thickened as the
water drains through the belt. As the belt holding
the sludge advances, it approaches a second
moving belt As the first and second belts move
closer -together, the sludge is compressed
between them. The pressure is increased as the
two belts travel together over and under a series
of rollers. The turning of the belts around the
rollers shear the cake which furthers the
dewatering process. At the end of the roller
pass, the belts move apart and the cake drops
off. The feed belt is washed before the sludge
feed point. The dropped filter cake may then be
disposed.
The advantages of a belt filtration system are
its lower labor requirements and lower power
consumption. The disadvantages are that the
belt filter presses produce a poorer quality
filtrate, and require a relatively large volume of
belt wash water.
Typical belt filtration applications may
dewater an undigested activated sludge to a cake
containing 15 to 25 percent solids. Heat-treated,
digested sludges may be reduced to a cake of up
to 50 percent solids.
INDUSTRY PRACTICE
Of the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning the use of pressure
filtration, 36 operate pressure filtration systems.
Of these 34 facilities, 25'operate plate and frame
pressure filtration systems, three operate belt
pressure filtration systems, and six did not
specify the type of presure filtration systems
utilized.
Vacuum Filtration
8.2.4.3
GENERAL DESCRIPTION
A commonly-used process for dewatering
sludge is rotary vacuum filtration. These filters
come in drum, coil, and belt configurations. The
filter medium may be made of cloth, coil springs,
or wire-mesh fabric. A typical application is a
rotary vacuum belt filter; a diagram of this
equipment is shown in Figure 8-27.
8-54
-------
Chapter 8 Wastewater Treatment Technologies Development Document for the CWTPoint Source Category
Sludge
Influent
7 \\ U
V* JL ^Oy Spray Wa
Wash Water
Drainage Compression Shear
Zone Zone Zone
Cake
Figure 8-26. Belt Pressure Filtration System Diagram
8-55
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
Vacuum
Source
Filter Cake
Discharge
^ ^ ^ ^
.^., -- ^^—^JJUr-'^^Viif^J^j;!..^!!^^
Figure 8-27. Vacuum Filtration System Diagram
8-56
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
In a rotary vacuum belt filter, a continuous
belt of filter fabric is wound around a horizontal
rotating drum and rollers. The drum is
perforated and is connected to a vacuum. The
drum is partially immersed in a shallow tank
containing the sludge. As the drum rotates, the
vacuum which is applied to the inside of the
drum draws the sludge onto the filter fabric. The
water from the sludge passes through the filter
and into the drum, where it exits via a discharge
port. As the fabric leaves the drum and passes
over the roller, the vacuum is released." The
filter cake drops off of the belt as it turns around
the roller. The filter cake may then be disposed.
Vacuum filtration may .reduce activated
sludge to 'a cake containing 12 to 20 percent
solids. Lime sludge may be reduced to a cake of
25 to 40 percent solids.
Because vacuum filtration systems are
relatively expensive to operate, they are usually
preceded by a thickening step which reduces the
volume of sludge to be dewatered. An
advantage of vacuum filtration is that it is a
continuous process and therefore requires less
operator attention.
INDUSTRY-PRACTICE
Of the 65 CWT facilities in EPA's WTI
Questionnaire data base that provided
information concerning the use of vacuum
filtration, eight operate vacuum filtration
systems.
Zero or Alternate Discharge
Treatment Options
8.2.5
Filter Cake Disposal
8.2.4.4
After a sludge is dewatered, the resultant
filter cake must be disposed. The most common
method of filter cake management used in the
CWT industry is transport to an off-site landfill
for disposal. Other disposal options are
incineration or land application. Land application
is usually restricted to biological treatment
residuals.
This section discusses zero discharge
wastewater treatment and disposal methods. In
this context, zero discharge refers to any
wastewater disposal method other than indirect
discharge to a POTW or direct discharge to a
surface water. A common zero discharge
method employed by CWT facilities that
generate small volumes of wastewater is'
transportation-.of_the«wastewater to an off-site
disposal facility such as another CWT facility.
Other methods discussed below include deep
well disposal, evaporation, and solidification.
Deep well disposal consists of pumping the
wastewater into a disposal -well, that-discharges-
the-liquid into-a-deep aquifer.r Normally, these
aquifers are thoroughly characterized to insure
that they are not hydrogeologically-connected to
a drinking, water supply. The characterization
requires the confirmation^oisthe~existence-of~
impervious layers of rock- above and below
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
INDUSTRY PRACTICE
EPA has information for 24 CWT facilities not
discharging directly to surface waters or POTWs
that employ zero and alternate discharge
methods. Of those 24'facilities, seven dispose of
wastewater by deep well injection, 13 transport
wastewater to an off-site commercial or intra-
company wastewater treatment facility, two
dispose of wastewater by evaporation, one
solidifies wastewater and landfills it on-site, and
one discharges wastewater to a privately-owned
treatment works.
8-58
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
REFERENCES
8.3
Standard Methods for Examination of Water and Wastewater, 15th Edition, Washington DC.
Henricks, David, Inspectors Guide for Evaluation of Municipal Wastewater Treatment Plants.
Culp/Wesner/Culp, El Dorado Hills, CA, 1979.
Technical Practice Committee. Operation of Wastewater Treatment Plants. MOP/11, Washington, DC,
1976.
Clark, Viesman, and Hasner, Water Supply and Pollution Control Harper and Row Publishers, New
York, NY, 1977.
Environmental Engineering Division; Computer Assisted Procedure For the Design and Evaluation of
Wastewater Treatment Systems' (CAPPED. U. S. Army Engineer Waterways Experiment Station,
Vicksburg, MS, 1981. .
1991 Waste Treatment Industry Questionnaire, U.S. Environmental Protection Agency, Washington,
DC. ' " -'
Osmonics, Historical Perspective of Ultrafiltration and Reverse Osmosis Membrane Development.
Minnetonka, MN, 1984.
Organic Chemicals and-Plastics and Synthetic Fibers CC-GPSF) Cost Document. SAIC..1987.
Effluent Guidelines Division. Development Document for Effluent Limitations Guidelines & Standards
for the Metal Finishing. Point Source Category. Office of Water Regulation & Standards, U.S. EPA,
Washington, DC, June 1983. .
Effluent Guidelines Division, Development Document For Effluent Limitations Guidelines and
Standards for the Organic Chemicals. Plastics and Synthetic Fibers COCPSFX Volume II, Point Source
Category, EPA 440/1-87/009, Washington, DC, October 1987.'
Engineering News Record (ENR), McGraw-Hill Co., New York, NY, March 30, 1992.
Comparative Statistics of Industrial and Office Real Estate Markets. Society of Industrial and Office
Realtors of the National Association of Realtors, Washington, DC, 1990.
Effluent Guidelines Division. Development Document for Effluent Limitations Guidelines & Standards
for the Pesticides Industry. Point Source Category, EPA 440/1-85/079, Washington, DC, October,
1985.
Peters, M., and Timmerhaus, K.. Plant Design and Economics for Chemical Engineers, McGraw-Hill.
New York, NY, 1991.
Chemical Marketing Reporter. Schnell Publishing Company, Inc., New York, NY, May 10, 1993.
Palmer, S.K., Breton, M.A., Nunno, T.J., Sullivan, D.M., .and Supprenaut, N.F., Metal/Cyanide
Containing Wastes Treatment Technologies. Alliance Technical Corp., Bedford, MA, 1988.
8-59
-------
Chapter 8 Wastewater Treatment Technologies
Development Document for the CWTPoint Source Category
Freeman, H.M., Standard Handbook of Hazardous Waste Treatment and Disposal. U.S. EPA,
McGraw-Hill, New York, NY, 1989.
Corbitt, Robert, Standard Handbook of Environmental Engineering. McGraw-Hill Publishing Co., New
York, NY, 1990.
Perry, H., Chemical Engineers Handbook. 5th Edition. McGraw-Hill, New York, NY, 1973.
Development Document for BAT. Pretreatment Technology and New Source Performance
Technology for the Pesticide Chemical Industry. USEPA, April 1992.
Vestergaard, Clean Harbors Technology Corporation to SAIC - letter dated 10/13/93.
Brown and Root, Inc., "Determination of Best Practicable Control Technology Currently Available to
Remove Oil and Gas," prepared for Sheen Technical Subcommittee, Offshore Operators Committee,
New Orleans, (March 1974).
Churchill, R.L., "A Critical Analysis of Flotation Performance," American Institute of Chemical
Engineers, 290-299, (1978).
Leech, C.A., "Oil-Flotation Processes for Cleaning Oil Field Produced Water," Shell Offshore, Inc.,
Bakersfield, CA, (1987).
Luthy, R.C., "Removal of Emulsified Oil with Organic Coagulants and Dissolved Air Flotation." Journal
Water Pollution Control Federation. C1978X 331-346. -
Lysyj, L, et al., "Effectiveness of .Offshore.. Produced, Water Treatment," API et al., Oil Spill
prevention, Behavior Control and Clean-up Conference (Atlanta, GA) Proceedings, (March 1981).
Pearson, S.C., "Factors Influencing Oil Removal Efficiency in Dissolved Air Flotation Units," 4th
Annual Industrial Pollution Conference, Houston, TX, (1976).
Viessman, W., And Hammer, M.J., Water Supply and Pollution Control Harper Collins Publishers,
New York, NY, 1993.
Wyer, R.H., et al., "Evaluation of Wastewater Treatment Technology for Offshore Oil Production
Facilities," Offshore Technology Conference, Dallas, TX, (1975).
Eckenfelder, Welsey, Industrial Pollution Control New York: McGraw-Hill, 1989.
Joint Task Force, Design of Municipal Wastewater Treatment Plants. MOP 8, Alexandria: Water
Environment Federation, 1991.
Tchobanoglous, George, Wastewater Engineering. 2nd Ed., New York: McGraw-Hill, 1979.
Development Document for the Proposed Effluent Limitations Guidelines and Standards for the
Landfills Point Source Category. USEPA. January, 1998.
Development Document for the Proposed Effluent Limitations Guidelines and Standards for Industrial
Waste Combustors. USEPA. December 1997.
8-60
-------
Chapter
9
REGULATORY OPTIONS CONSIDERED AND
SELECTED FOR BASIS OF REGULATION
This section presents the technology options
considered by EPA as the basis for the
effluent limitations guidelines and standards for
the CWT industry. It also describes the
methodology for EPA's selection of the final
technology options. The limitations. and
standards discussed in this section are Best
Practicable-» Control, Technology Currently
Available..(BET), 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).
ESTABLISHMENT OF BPT
9.1
Section 304(b)(l)(A) requires EPA to
identify effluent reductions attainable through the
application . of "best practicable control
technology currently available for classes and
categories of point sources." EPA determines
BPT effluent levels based upon the average of
the best existing performance by facilities of
various sizes, ages, and unit processes within
each industrial category or subcategory.
However, in industrial categories where present
practices are uniformly inadequate, EPA may
determine that BPT requires higher levels of
control than any currently in place if the
technology to achieve those levels can be
practicably applied.
In addition, CWA Section 304(b)(l)(B)
requires a cost reasonableness assessment for
BPT limitations. In determining the BPT limits,
EPA must consider the total cost of treatment
technologies in relation to the effluent reduction
benefits achieved. ;
In balancing costs against the benefits.of
effluent reduction, EPA considers the volume
and nature of expected discharges after
application of BPT, the general environmental
effects of pollutants, and the cost and economic
_,.. impacts of the required level of pollution"
control.
. In assessing BPT for this industry, EPA
considered age, size, unit processes, other
engineering factors, and non-water quality
impacts pertinent to the facilities treating waste
in each" subcategory. For all subcategorieSj-no
basis could be found for identifying different
BPT limitations based on age, size, process, or
, other engineering factors for the reasons
previously discussed. For a service industry
whose service is wastewater treatment, the
pertinent factors for establishing the limitations
are cost of treatment, the level of effluent
reductions obtainable, and non-water quality
effects.
EPA determined that, while some CWT
facilities are providing adequate treatment of all
wastestreams, wastewater treatment at some
CWT facilities is poor. EPA has determined
that facilities which mix different types of highly
concentrated CWT wastes with non-CWT
wastestreams or with storm water are not
providing BPT treatment. In addition, while
some CWT facilities pretreat subcategory
wastestreams for optimal removal prior to
commingling, some facilities mix wastes from
different subcategories without pretreatment.
This practice essentially dilutes the waste rather
than treats the waste. As such, the mass of
9-1
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWT Point Source Category
pollutants being discharged at some CWT
facilities is higher than that which can be
achieved, given the demonstrated removal
capacity of treatment systems that the Agency
reviewed. Many CWT facilities recognize that
commingling often leads only to dilution and have
encouraged their customers to segregate wastes
as much as possible. Waste minimization
techniques at most manufacturing facilities have
also led to increased waste stream segregation.
Comparison of EPA sampling data and CWT
industry-supplied monitoring information
establishes that, in the case of metal-bearing,
wastestreams, virtually all the facilities are
discharging large amounts of heavy metals. As
measured by total suspended solids (TSS) levels
following treatment^ TSS--concentrations—are-
substantially higher- than, levels - observed at
facilities in other industry categories employing
the very same treatment technology.- -
In the case of oil discharges, many facilities
are achieving low removal of oil and grease
relative to the performance required-for-other.
point source categories. Many collect samples
infrequently' to analyze for metal and organic
constituents in their discharge since these
parameters are not included in their discharge
permits. Further, facilities treating organic
wastes, while successfully removing organic
pollutants through biological treatment, fail to
remove metals associated with these organic
wastes.
The poor pollutant removal performance
observed for some direct discharging CWT
facilities is not unexpected. As pointed out
previously, some of these facilities are treating
highly concentrated wastes that, in many cases,
are process residuals and sludges from other
point source categories. EPA's review of permit
limitations for the direct dischargers show that, in
most cases, the dischargers are subject to "best
professional judgment" limitations which were
based primarily on guidelines for facilities treating
and discharging much more dilute wastestreams.
EPA has concluded that treatment performance
in the industry is often inadequate and that the
mass of pollutants being discharged is high,
given the demonstrated removal capability of
treatment option that the Agency has reviewed.
EPA's options to evaluate treatment
systems in place at direct discharging CWTs
were extremely limited since most of the
facih'ties in this industry are indirect dischargers.
This is particularly true of the metals and oils
facilities. Many indirect discharging CWTs are
not ' required to control discharges of
conventional pollutants because the receiving
POTWs are designed to achieve removal of
conventional pollutants and therefore, generally
do' not monitor or optimize the performance of
their treatment systems for control of
conventional pollutants. Because BPT applies
to direct dischargers, the data used to establish
limitations and standards are normally collected
fronrsuch facilities; For this rule, EPA relied on
information and data, from, widely available
treatment technologies in use at CWT facilities
discharging indirectly,— so,caUed,I'technology
transfer." EPA concluded that certain
technologies in place at indirect discharging
CWT facilities are appropriate for use as the
basis for regulation of direct dischargers. '
Technological Options Considered as
the Basis for the Metals Subcategory
Limitations and Standards 9.1.1
EPAhas considered four technology options
in establishing BPT effluent level reductions for
the metals subcategory. All rely on chemical
precipitation, to reduce the discharge of
pollutants from CWT facilities. The four
technology options are as follows:
Option 1: chemical precipitation, and
liquid solid separation;
Option 2: selective metals precipitation,
liquid-solid separation,
secondary precipitation, and
liquid-solid separation;
Option 3: selective metals precipitation,
secondary precipitation, liquid-
9-2
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWT Point Source Category
solid separation, tertiary
precipitation, and clarification;
and
Option 4: primary precipitation, liquid-
solid separation, secondary
precipitation, liquid solid
separation, and sand filtration.
As detailed in the 1995 proposal and the
1999 supplemental proposal, while single stage
chemical precipitation followed by liquid-solid
separation is widely used in this subcategpry,_
EPA dropped it from further consideration at the
time of the original proposal. EPA concluded
that single stage, chemical precipitation of mixed
disparate metal-bearing waste streams is not an
acceptable technology-basis for BPT. limitations.
The Agency also dropped" the option" 2"
technology at the time of the 1999 proposal
because it estimated that the option 2~and~option
3 technologies have nearly equivalent costs and
that pollutant removals are greater for option 3.
Therefore, EPA now eonsiders-two technology-
options as the basis for the metals subcategory
limitations and standards. Each is explained in
detail below.
METALS SUBCATEGORY OPTION 3' - SELECTIVE
METALS PRECIPITATION. LIQUID-SOLID
SEPARATION. SECONDARY PRECIPITATION.
LIQUID-SOLID SEPARATION. TERTIARY
PRECIPITATION. AND CLARIFICATION
The first treatment option (option 3) that
EPA evaluated is based on "selective metals
precipitation." "Selective metals precipitation" is
a specialized metals removal technology that
tailors precipitation conditions to the metal to be
removed. The extent to which a metal is
precipitated from a solution will vary with a
number of factors including pH, temperature, and
.., 'The numbering of options reflects the
numbering for the 1999 proposal. Option 3 was
first considered for the 1995 proposal. Option 4 is
a techno logy EPA evaluated for the 1999 proposal.
treatment chemicals. Selective metals
precipitation adjusts these conditions
sequentially in order to provide maximum
precipitation of metals. Selective metals
precipitation requires segregation of incoming'
wastestreams and careful characterization of the
metals content of the waste stream. Next, there
are multiple precipitations in batches at different
pH levels in order to achieve maximum removal
of specific metals. Selective metals precipitation
results in the formation of a metal-rich filter
cake. This treatment option requires numerous
treatment tanks and personnel to handle
.incoming wastestreams, greater quantities of
treatment chemicals, and better control of the
precipitation steps. One of the benefits of this
technology, however, is that it results in a metal-
rich filter cake that facilities employing this
treatment: have the option of-selling- as. feed
material for metal reclamation. For metal
streams which contain concentrated cyanide
complexes, achievement of the BPT limitations
under this option would require alkaline
chlorination in a two step process prior to metals
treatment. These BPT cyanide limitations are
discussed in greater detail below.
METALS SUBCATEGORY OPTION 4' - PRIMARY
PRECIPITATION. LIQUID-SOLID SEPARATION.
SECONDARY PRECIPITATION. AND SAND
FILTRATION
The second technology EPA evaluated as
the technology basis for limitations and
standards in the metals subcategory is option 4, •
a two stage precipitation process. The first
stage of this technology is similar to the option
1 chemical precipitation technology considered
(and rejected) during the development of this
rule and is based on chemical precipitation,
followed by some form of solids separation and
sludge dewatering. In option 4, however, a
second precipitation step is also performed
followed by sand filtration. Under option 4, the
treater varies pH levels and treatment chemicals
in order to promote optimal removal of the wide
9-3
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWTPoint Source Category
range of metal pollutants found in CWT metals
wastewaters. Since most CWT metal facilities
utilize single-stage chemical precipitation only,
generally limitations and standards based on
option 4 would require some facilities to more
carefully control their treatment steps, increase
quantities of treatment chemicals they use,
perform an additional precipitation step, and add
a clarification sand filtration step. Once again,
for metals which contain concentrated cyanide
complexes, like option 3, alkaline chlorination in
a two step process is also part of the option 4
treatment process.
Rationale for the Final Metals
Subcategory BPT Limitations
9.1.1.1
For the final CWT rule, EPA established
BPT limitations for the metals subcategory based
on the option 4; technology. The™Agency-
concluded that this treatment system represented
the bestpracticable technology currently available
and should be the basis for the BPT metals
limitations for the following reasons. First, the
option 4 technology is one that is readily
applicable to all facilities that are treating metal-
bearing waste streams. It is based on a
technology including two-stage chemical
precipitation that is currently used at
approximately 25 percent of the facilities in this
subcategory. Second, the adoption of this level
of control would represent a significant reduction
in pollutants discharged into the environment by
facilities in this subcategory. Option 4 would
annually remove approximately 4.1 million
pounds of TSS and metals now discharged to the
Nation's waters. Third, the Agency assessed the
total cost of water pollution controls likely to be
incurred for option 4 in relation to the effluent
reduction benefits and determined these costs
were reasonable- S0.40 per pound ($1997). In
the 1999 proposal, EPA explained why it rejected
metals option 3 as the basis for BPT. See 64 FR
2280 at 2306.
The Agency used chemical precipitation
treatment technology performance data from, the
Metal Finishing regulation (40 CFR Part 433) to
establish direct discharge limitations for TSS
because the facility from which the option 4
limitations were derived is an indirect discharger
and the treatment system is not necessarily
designed for optimum removal of conventional
parameters, due to the lack of stringent local
limits for these parameters. EPA has concluded
that the transfer of this data is appropriate given
the absence of adequate treatment technology
for this pollutant at the only otherwise well-
operated BPT CWT facility examined by EPA.
Based on a review of the data, EPA concluded
that similar wastes (in terms of TSS
concentrations) are being'treated at both metal
finishing and centralized waste treatment
facilities, and that the use of the metal finishing
data to derive TSS limits forJhis subcategory is
warranted. Because the technology basis for the
transferred limitations includes clarification
rather than sand filtration, the Agency also
included a clarification step- prior to sand
filtration (which the option 4 facility does not
have) in the technology basis for option 4 for
facilities subject to BPT. Therefore, because
the technology basis for CWT is based on
primary chemical precipitation, primary
clarification, secondary chemical precipitation,
secondary clarification, and sand filtration and
the technology basis for Metal Finishing is based
on primary precipitation and clarification only,
EPA concluded that CWT facilities will perform
similarly (or better) when treating TSS in wastes
in this subcategory.
BPT limitations established by option. 4
(except TSS) are based on data from a single,
well-operated system. Generally, for purposes
of defining BPT effluent limitations, EPA looks
at the performance of the best treatment
technology and calculates limitations from some
level of average performance measured at
facilities that employ this "best" treatment
technology. In reviewing technologies currently
in use in this subcategory, however, EPA found
that facilities generally utilize a single stage
chemical precipitation step — a technology
9-4
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWT Point Source Category
which does not achieve adequate metals removals
for the waste streams observed at these
operations. EPA did identify facilities that utilize
additionalmetals wastewater treatment, generally
secondary chemical precipitation, but without the
final multimedia filtration step. Also, EPA found
that only the BPT model facility accepts a full
spectrum of waste, often with extremely high
metals concentrations and provides, therefore, a
suitable basis to determine the performance that
a well-designed and operated system can achieve
for a wide range of raw waste concentrations.
Consequently, EPA adopted BPT limitations.
based on performance data from this facility. For
further discussion, see the 1999 proposal at 64
FR 2280-2357.
CYANIDE SUBSET
TECHNOLOGIESrEVALUATED-
As discussed above, the presence of high
cyanide concentrations detrimentally, affects the
performance of metal precipitation processes due
to the formation- of- metal^cyanide complexes.
Effective treatment of such wastes typically
involves a cyanide destruction step prior to any
metal precipitation steps. Consequently, in the
case of metal streams which contain concentrated
cyanide complexes, EPA concluded an additional
treatment step is required to destroy cyanide prior
to metals precipitation. During development of
this rule, EPA considered the following three
regulatory options for the destruction of cyanide.
CYANIDE SUBSET OPTION 1 - ALKALINE
CHLORINATION
The option 1 technology, alkaline
chlorinatiori, is widely used for cyanide
destruction in this industry as well as hi others:
For this subset, it represents current
performance. While this technology can
effectively treat non-complexed, dilute cyanide -
bearing wastestreams, it is often ineffective in
treating concentrated cyanide complexes.
CYANIDE SUBSET OPTION 2 - ALKALINE
CHLORINATION IN A TWO STEP PROCESS
The cyanide option 2 technology is alkaline
chlorination hi a two step process. In the first
step, cyanide is oxidized to cyanate in a pH
range of 9 to 11. The second step oxidizes
cyanate to carbon dioxide and nitrogen at a
controlled pH of 8.5. EPA's data demonstrate
that this technology is effective in treating
concentrated cyanide complexes.
CYANIDE SUBSET OPTION 3 - CONFIDENTIAL
CYANIDE DESTRUCTION
EPA evaluated a third technology which is
extremely effective in reducing cyanide
(including concentrated cyanide complexes).
Application of this' technology resulted in
cyanide reductions of 99.8 percent for both
amenable and total-,cyanide. The option 3
technology is also claimed confidential
. As detailedmthe'1995 and 1999 proposals,
the cyanide option 3 technology is a proprietary
process that does not employ off-the-shelf
technology. Consequently, EPA dropped it
from further consideration since it is not publicly
available.
RATIONALE FOR FINAL CYANIDE SUBSET BPT
LIMITATIONS
EPA based' the final BPT limitations on
cyanide option 2. .This is the same technology
that was the basis for the 1999 proposed
limitations. There are several reasons supporting
the selection of limitations based on cyanide
option 2, as explained in detail in the 1999
proposal at 64 FR 2309. First, the facility
achieving cyanide option 2 removals accepts a
full spectrum of cyanide waste. Consequently,
the treatment • used by the cyanide option 2
facility can be readily applied to all facilities in
the subset ;of this subcategory. Second,
adoption of this level of control would represent
a significant reduction in pollutants discharged
into the environment by facilities in this subset.
9-5
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWT Point Source Category
Finally, the Agency assessed the total cost for
cyanide option 2 in relation to the effluent
reduction benefits and determined these costs
were economically reasonable.
Technological Options Considered as
the Basis for the Oils Subcaiegory
Limitations and Standards
9.1.2
EPA has considered twelve technology
options in establishing BPT effluent reduction
levels for the oils subcategory during
development of this rule. The first four options
were evaluated at the time of the 1995 proposal
(60 FR 5478); the other eight options, following
the 1995 proposal. The twelve technology
options considered are as follows:
Option 1: emulsion breaking/gravity
separation;
Option 2: emulsion breaking/gravity
separation and ultrafiltration;.
Option 3: emulsion breaking/gravity
separation, ultrafiltration, carbon
adsorption, and reverse osmosis;
Option 4: emulsion breaking/gravity
separation, ultrafiltration, carbon
adsorption, reverse osmosis, and
carbon adsorption;
Option 5: emulsion breaking/gravity '
separation, ultrafiltration, and
chemical precipitation;
Option 6: emulsion breaking/gravity
separation, dissolved air flotation,
and gravity separation;
Option 7: emulsion breaking/gravity
separation, secondary gravity
separation, dissolved air flotation,
and biological treatment;
Option 8: emulsion breaking/gravity
separation and dissolved' air
flotation;
Option 8v: emulsion breaking/gravity
separation, air stripping, and
dissolved air flotation;
Option 9: emulsion-breaking/gravity
separation, secondary gravity
separation, and dissolved air
flotation;
Option 9v: emulsion breaking/gravity
separation, air stripping,
secondary gravity separation, and
dissolved air flotation; and
Option 10: emulsion breaking/gravity
separation and secondary gravity
separation.
As detailed in the 1995 proposal and 1999
supplemental proposal, while emulsion
breaking/gravity separation (option 1) is widely
used in this subcategory, the data EPA has
examined supports the Agency's concerns that
the performance of emulsion breaking and/or
gravity separation unit operations are inadequate
because they do not achieve acceptable pollutant
removals. For example, one of-'the facilities in
the oils subcategory that EPA sampled
discharged a biphasic sample (oil and water)
from the emulsion breaking/gravity separation
unit during an EPA sampling-visit. When- EPA-
analyzed the sample, the biphasic liquid stream
had a relatively small organic phase percentage,
yet contained extremely high overall
concentrations of toxic pollutants, especially
priority, semi-volatile organics (such as
polynuclear aromatic hydrocarbons, phthalates,
aromatic hydrocarbons, n-paraffins, and
phenols). Hence, the Agency concluded that
gravity separation systems without further .
treatment provide inadequate removals.
Consequently, EPA dropped the oils option 1
technology from further consideration.
The Agency also dropped the option 4
technology (emulsion breaking/gravity
separation, ultrafiltration, carbon adsorption,
reverse osmosis, and carbon adsorption) from
consideration at the time of the original proposal
because EPA's analysis showed that some
poEutant concentrations actually increased
following the additional carbon adsorption.
At the time of the 1995 proposal, the
9-6
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWT Point Source Category
Agency co-proposed BPT limitations based on'
emulsion breaking/gravity separation, and
ultrafiltration as well as emulsion breaking/gravity
separation and ultrafiltration with added carbon
adsorption and reverse osmosis to remove metal
compounds found at significant levels in this
subcategory. Because the costs associated with
the latter option were four times higher than
ultrafiltration alone, EPA was concerned about its
impacts on facilities in this subcategory. After
the 1995 proposal, EPA* collected additional
information on facilities in the oils subcategory.
and revisited its conclusion about the size and
nature of the oils subcategory. EPA published a
Nptice of Data Availability in 1996 describing the
new information and EPA's revised assessment
of the oils subcategory. Based on analyses
presented in the 1996 Notice, EPA determined it
should no longer consider .emulsion
breaking/gravity separation and ulfrafiltration with
added treatment steps (option 3) as the basis for
BPT limitations because the projected total costs
relative to effluent reductions benefit were not
economically reasonable.
Based on comments to the" 1995 proposal
and the 1996 Notice of Data Availability, EPA
was strongly encouraged to look at alternate
technology options to emulsion breaking/gravity
filtration and ultrafiltration. This concern was
driven in large measure by the fact that many of
the facilities in the oils, subcategory are classified
as "small businesses" and the economic cost of
installing and operating ultrafiltration technology
was quite high. Additionally, many commenters
stated that ultrafiltration is a sophisticated
technology which would be difficult to operate
and maintain with the majority of these
wastestreams. Commenters also noted that the
Agency had failed to consider non-water quality
impacts adequately — particularly those
associated with the disposal of the concentrated
filtrate from these operations. As a result, based
on comments to the original proposal, the 1996
Notice of Data Availability, and additional site
visits, EPA identified several other treatment
options that were efficient, produced tighter oil
and grease limits, and were less expensive. As
such, EPA did not consider emulsion
breaking/gravity separation and ultrafiltration
(option 2) as an appropriate technology for
limitations for the oils subcategory.
Following the 1995 proposal and the 1996
Notice of Data Availability, EPA preUminarily
considered options 5 - 9v in establishing BPT
effluent reduction levels for ..this subcategory.
However, EPA dropped options 5, 6, and 7
early in the process. EPA dropped option 5
since it reh'ed on .ultrafiltration which, as
described previously, the Agency determined
. was inappropriate for this subcategory. The
Agency dropped option 6 since EPA is unaware
of any CWT facilities that currently use the
option 6 treatment technologies in the sequence
considered. Finally, EPA dropped option 7
because EPA's sampling" data"showed" little"
additional pollutant reduction associated with the
addition of "the biological treatment system.
Following the SBREFA panel, at the request
of panel members, EPA also examined another
option, option 10, which is based on emulsion
breaking/gravity, separation followed by a
second gravity separation step. At the time of
the 1999 proposal the Agency concluded it
should not.propose BPT limitations based on
this technology because EPA's data show that
this technology alone did not adequately control .
the metal pollutants of concern relative to other
widely available technologies.
Finally, as described in more detail in the
1999 proposal (See 64 FR 2311), the Agency
dropped option 8v and 9v from consideration
because the addition of air stripping with
overhead recovery or destruction would not
achieve any substantial additional removal of
volatile and semi-volaitel parameters from the
wastewater. The discharge limits would be the '
same with or without the additional technology
basis of air stripping with overhead recovery.
Consequently, EPA now considers only two'
technology options for the basis for establishing
the oils subcategory limitations and standards.
These are as follows:
9-7
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWT Point Source Category
Option 82: emulsion breaking/gravity
separation and dissolved air
flotation; and
Option 9*: emulsion breaking/gravity
separation, secondary gravity
separation, and dissolved air
flotation
Each of these are discussed below.
• OILS SUBCATEGORY OPTION 82 - DISSOLVED AlR
FLOTATION
The technology basis for option 8 is
dissolved air flotation (DAF). DAF separates
solid or liquid particles from a liquid phase by
introducing air bubbles into the liquid phase. The
bubbles attach to the particles and rise to the top
of the mixture. Often chemicals are added to
increase the removal of metal constituents.
Generally, limitations and standards based on
option 8 would require facilities to more carefully
control their treatment systems and/or to install
and operate a DAF.system.' For-oils srreams=with~
significant concentrations of metals, option 8
would also require increased quantities of
treatment chemicals to enhance metals removals.
PELS SUBCATEGORY OPTION 92 - SECONDARY
GRAVITY SEPARATION AND DISSOLVED AIR
FLOTATION
The technology basis for limitations based on
option 9 is secondary gravity separation and
DAF. Secondary gravity separation involves
using a series of tanks to separate the oil and
water and then skimming the oily component off.
The resulting water moves to the next step. The
gravity separation steps are then followed by
DAF. As mentioned previously, EPA concluded
2As noted above, EPA is no longer considering
oils Options 1- 4 proposed in 1995. During
development of the 1999 proposal, EPA also
preliminarily considered seven other options
numbered 5 - 9v. EPA has chosen to focus its
attention on options 8 and 9.
all oils facilities currently utilize some form of
gravity separation, although most perform
primary gravity separation only. Generally,
limitations and standards based on option 9
would require facilities to more carefully control
their treatment systems, perform additional
gravity separation steps, and/or install and
operate a DAF system. For oils streams with
relatively high concentrations of metals, option
9 would also require the use of increased
quantities of treatment chemicals to enhance the
removal of metals.
Rationale for Oils Subcategory BPT
Limitations - 9.1.2.1
The technology basis for the final BPT .
limitations , is, oils option 9: emulsion
breaking/gravity separation, secondary gravity
separation and dissolved air flotation.. This is
the same technology that was the Basis for the
1999 proposed limitations. EPA notes that all
direct discharging oils facilities already have
treatmeM-in-place equivalent to secondary
gravity separation. Therefore, EPA can not
consider the option 8 technology as the basis for
BPT limitations in the oils subcategory.
EPA developed the final limitations for this
option using sampling data from facilities both
with and without the secondary, gravity
separation step. EPA's data show that the
secondary gravity separation step may not
always be necessary to meet the final
limitations, depending on the level of treatment
in the initial gravity-separation/emulsion-
breaking step. EPA's data show there is a wide
range of pollutants being discharged from this
initial treatment step. EPA concluded that if
many of the facilities optimize treatment at this
level, the secondary gravity separation step may
not be required. However, EPA estimated the
costs to comply with the limitations with the
secondary gravity separation step included to
ensure this technology option's economic
achievability.
9-8
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWTPoint Source Category
The Agency adopted BPT limitations for
the oils subcategory based on option 9, emulsion
breaking/gravity separation, secondary gravity
separation and dissolved air flotation for two
reasons. First, the adoption of this level of
control would represent a significant reduction in
pollutants discharged into the environment by
facilities in this subcategory. Second, the Agency
assessed the total costs of water pollution
controls- likely, to be incurred for this option in
relation to the effluent reduction benefits and
determined these costs-were, reasonable, at
$0.63/lb ($1997). EPA believes it is important to
note that BPT limitations for conventional
parameters-established by option 9 are-based on
data from a single, well-operated, indirect-
discharging system. Generally, for purposes of
defining BPT effluent limitations, EPA looks at
the performance of the best treatment technology
and" calculates limitations from some level of
average performance measured at facilities that
employ this "best" treatment technology. The
facilities sampled as the technology basis for this
subcategory, however™ were not required" to
optimize their oil and grease or TSS removals
because they discharge to POTWs. Current
POTW/local permit limitations for oil and grease
in this subcategory range from 100 mg/L to 2,000
mg/L and for TSS from 250 mg/L to 10,000
mg/L. Many have no oil and grease or TSS
limits at all. EPA concluded that only one of the
systems in this subcategory for which EPA has
data was designed to remove oil and grease and
TSS effectively. EPA concluded that the oil and
grease and TSS removals are uniformly
inadequate at the other facilities included in the
BPT limitations calculations for other parameters.
Consequently, EPA based the oil and grease and
TSS limitations on data from a single facility.
Technological Options Considered as
the Basis for the Organics Subcategory
Limitations and Standards 9.1.3
EPA has considered four technology options
in establishing limitations and standards for the
organics subcategory during development of this
rule. The four technology options are as
follows:
Option 1: equalization, air stripping with
emissions control, biological
treatment, and multimedia
filtration;
Option 2: equalization, air stripping with
emissions control, biological
treatment, multimedia filtration,
and carbon adsorption;
Option 3: equalization, air-stripping with
emissions control, and biological
treatment; and
Option 4: equalization and biological
treatment.
The 1999 proposal explained that the
Agency dropped option 2 from further
consideration-, because EPA's sampling data
showed- that, following the carbon adsorption
step, specific pollutants. of concern actually
increased.- The 1999 proposal also explained
that EPA dropped option 1 from consideration
because the multimedia filtration step is
primarily included to protect the carbon
adsorption unit installed downstream from high
TSS levels. Since EPA rejected option 2 which
includes the carbon adsorption unit, EPA
similarly rejected the option which includes the
multimedia filtrations step.
Also, as described in more detail in the 1999
proposal (see 64 FR 2312), the Agency dropped
option 3 from consideration because the addition
of air stripping with overhead recovery or
destruction would not achieve any substantial
additional removal of volatile and semi-volatile
parameters from the wastewater. Effluent
limitations and standards based on option 3
treatment would be essentially the same as those
established by option 4.
Consequently, for the final CWT rule, EPA
considered only one technology basis, option 4,
for the development of limitations and standards
for the organics subcategory.
9-9
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWT Point Source Category
Rationale for Organics Subcategory
BPT Limitations . .
9.1.3.1
•The technology basis for the final BPT
limitations is organics option 4: equalization and
biological treatment. Biological treatment for
this option is in the form of a sequential batch
reactor. This is the same technology that was
the basis for the 1999 proposed limitations. The
preamble to the proposal provided further
explanation of EPA's decision (64 FR 2311-12).
The Agency concluded that this treatment
system represented the best practicable
technology currently available and should be the
basis for the BPT organics limitations for several
reasons. The technology is already used at the
four direct discharging facilities that treat organic
wastes and results in the removal of 28,700 Ibs
annually of conventional pollutants (at baseline).
Moreover, because the treatment is in place, the
cost of compliance with the limitations will
obviously be reasonable.
Unlike the other BPT limitations adopted in
the final CWT rule, the adoption of limitations
based on option 4 will not, in all probability,
result in any significant change in the quantity of
pollutants discharged into the environment by
facilities in this subcategory. As noted, EPA's
data suggests that all direct discharging facilities in
this subcategory currently employ equalization
and biological treatment systems, and EPA
assumed that all those facilities will be able to
meet the BPT limitations without additional
capital or operating costs. If any facilities were to
incur increased operating costs associated with
the limits, EPA concluded these increases are
negligible and has not quantified them. Many of
these facilities are not currently required to
monitor for organic parameters or are only
required to monitor a couple of times a year.
Thus, the estimated costs for complying with
BPT limitations for this subcategory are
associated with additional monitoring only. The
Agency determined the additional monitoring is
warranted, and will promote more effective and
consistent treatment at these facilities.
The selected BPT option is based on the
performance of a single indirect discharging
facility. While EPA identified four direct
discharging organics subcategory facilities that
utilize biological treatment, EPA did not use data
from these facilities to establish limitations
because they commingle organics subcategory
wastewaters with other CWT subcategory
wastewaters or wastewaters subject to other
national, effluent guidelines and standards.
Many facilities that are treating wastes that will
be subject to effluent limitations for the Organic
Waste Subcategpry_also operate other industrial
processes that generate much larger amounts of
wastewater than the quantity of off-site
generated, organic waste receipts. The off-site
generated organic waste receipts are directly
mixed with the- wastewater from- the- other
industrial processes for treatment. Therefore,
identifying facilities to sample for limitations
development was- difficult because- the waste
received for treatment and treatment unit
effectiveness • could not be properly
characterized for off-site generated waste. The
treatment system on which EPA based option 4
was one of the few facilities identified which
treated organic waste receipts separately from
other on-site industrial wastewater.
The Agency used biological treatment
performance data from the Thermosetting Resin
Subcategory of the QCPSF regulation to
establish direct discharge limitations for BOD5
and TSS because the facility from which
Option 4 limitations were derived is an indirect
discharger and the treatment system is not
operated to effectively remove conventional
pollutants. EPA has concluded that the transfer
of this data is appropriate given the absence of
adequate treatment technology for these
pollutants at the only otherwise well-operated
BPT CWT facility in this subcategory that the
Agency was able to evaluate. Moreover, EPA
concluded that the biological treatment systems
at CWT facilities will perform similarly to those
at OCPSF facilities. EPA based this conclusion
on its review of the NPDES permits for the four
9-10
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWT Point Source Category
direct discharging facilities in this subcategory.
Two of these facilities are. located at
manufacturing facilities that commingle their
wastewater for treatment and are already subject
to OCPSF. The other two facilities have
conventional pollutant limits which are lower than
those adopted for the final CWT rule. EPA has
concluded that all of these facilities should be
able to comply with the transferred limitations
without incurring additional costs. Likewise,-
EPA has not estimated any additional pollutant
removals associated with this data transfer.
Rationale for Multiple Wastestream
Subcategory BPI'Limitations
9.1.4
EPA-developed four sets of limitations for
each of the possible combinations of the three
subcategories of wastestreams: oils and metals,
oils and organics, metals and organics, and oils,
metals and organics. The multiple wastestream
subcategory-" limitations were derived by
combining BPT pollutant limitations from up to
all three subcategories selecting the most stringent
values where they overlap3. Therefore, the
technology basis for the multiple wastestream
subcategory limitations reflects the technology
basis for the applicable subcategories.
Multiple wastestream subcategory limitations
are only available to CWT facilities which accept
waste in multiple subcategories. These facilities
must certify as well as demonstrate that their
treatment system obtains equivalent removals to
those which are the basis for the separate
subcategory limits. The multiple wastestream
subcategory allows the facility to monitor for
compliance just prior to discharge rather than
directly following treatment of each
subcategory's waste stream. For multiple
subcategory facilities, this option simplifies
implementation and reduces monitoring costs.
EPA has, however, estimated additional burden
associated with the certification process in
"National Pollutant Discharge Elimination
System (NPDES) /Compliance
Assessment/Certification Information," ICR
(No. 1427.05), for direct dischargers and
"National Pretfeatment Program (40 CFR part
403)," ICR (No. 0002.08), for indirect
dischargers.
EPA has determined these limitations are
also best practicable technology limitations for
facilities that operate in one or more CWT
categories for the following reasons. EPA has
concluded that, for multiple subcategory
faculties, the limitations adopted in this
subcategory in combination with the certification
process will provide pollutant removals equal to
or greater than those projected if the facility-
elects to comply with the individual subcategory,,,
limitations. Further, analysis shows that the
costs for multi-subcategory facilities to comply
with" the multiple wastestream subcategory_
limitations-are generally equal to or-less-than the-
costs - associated, -with- complying with- -each
applicable subcategory's limitations individually.
Because EPA determined that costs of
complyingwith the individual subcategory limits
are achievable and costs of complying with the
multiple subcategory limits are no greater, EPA
concluded that the multiple wastestream
subcategory limits are economically achievable.
3EPA selected the most stringent maximum
monthly average limitations and its corresponding
maximum daily limitation.
9-11
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWT Point Source Category
BEST CONVENTIONAL TECHNOLOGY (BCT) 9.2
For the final CWT rule, EPA adopted BCT
limitations equivalent to BPT for all
subcategories. In deciding whether to adopt
different BCT limits, EPA considered whether
there are technologies that achieve greater
removals of conventional pollutants than adopted
for BPT, and whether those technologies are
cost-reasonable under the standards established .
by the CWA, and implemented through
regulation. EPA generally refers to the decision
criteria as the "BCT Cost Test." For all four
subcategories, EPA identified no technologies - -
that can achieve greater removals of conventional
pollutants than those that are the basis for BPT
that are also cost-reasonable under the BCT Cost
Test. Accordingly, EPA adopted BCT effluent
limitations equal to the BPT effluent limitations.
BEST A VAJLABLETECHNOLOGY (BA T) 9;3~
EPA adopted BAT effluent limitations for all...
subcategories,o£the_CW,T_industry.based,on,the
same technologies selected as the basis for BPT
for each subcategory. The BAT limitations are
the same as the BPT limitations for p_riprity_and
non-conventional pollutants. As described in the
BPT discussion, in general, the adoption of this
level of control will represent a significant
reduction in pollutants discharged into the
environment by facilities in this industry.
Additionally, EPA has evaluated the economic
impacts associated with compliance and found
the technologies to be economically achievable.
With the exception of the metals
subcategory, EPA has not identified any more
stringent treatment technology option different
from those evaluated for BPT that might
represent best available technology economically
achievable for this industry. For the metals
subcategory, EPA did consider as BAT
technology a treatment technology that it had
evaluated for the 1999 proposal, option 3, based
on the use of selective metals precipitation.
However, as detailed in the proposal (64 FR
2307-2308, 2312), there is little additional toxic
removal associated with option 3 while the costs
to the industry for are four times greater than
the cost of the BPT option, option 44.
EPA has concluded that it should not adopt
BAT limitations based on option 3 for several
reasons. First, the. option 3 technology may not
be the best "available" technology for existing
metals subcategory facilities because physical
constraints may prevent its use at certain
facilities. Currently, only one facility in the
metals subcategory is employing selective metals.
precipitation,,whicLrequires the separation arid-
holding of wastestreams in numerous treatment
tanks. EPA is aware that some facilities do not
have, and may not be able to obtain, sufficient
space to install the additional treatment tanks- -
that - would -be- needed- for- selective- metals
precipitation. Second, while the, removals,,,
associated with option 4 are not as great as
those calculated for option 3, achievement of
limitations based on the option 4 technology will
still represent a significant advance in removals
for the industry over those obtained from
conventional'precipitation technology. Given
these factors, EPA has concluded it should
adopt BAT limitations based on the option 4
technology.
. For the oils and organics subcategories, as
detailed in the proposal (64 FR 2312-2313),
EPA has evaluated treatment technologies for
BAT limitations, which theoretically should
provide greater removal of pollutants of
concern. For example, EPA identified an add-
on treatment technology to technologies
considered for BPT — carbon adsorption — that
should have further increased removals of
pollutants of concern. However, EPA's data
show increases rather than decreases in •
concentrations of specific pollutants of concern.
EPA has found that the treatment performance
4 EPA's data show that option 3 would remove
approximately 6 % more additional toxic pound-
equivalents than option 4.
9-12
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWTPoint Source Category
of activated carbon is sometimes unreliable due
to the competitive adsorption and desorption of
pollutants that have different affinities for
adsorption on activated carbon. Also, pH
changes of the wastewater going through the
carbon adsorption system may cause stable metal
complexes to dissolve and thus cause an increase
in some metal concentrations through the
adsorption system. Consequently, EPA did not
adopt BAT limitations based on this technology.
.. NEWSOURCE.PEREORMANCE
STANDARDS (NSPS),.
9.4
Under Section 306 of the Act, EPA must
propose and promulgate-Federal standards- of
performance for categories of new sources.
Section 306(e) provides that, after the effective
date of the standards of performance, the owner
or operator of a new. source.may not operate the
source in violation of any applicable standard of
performance. The statute defines "standard of
performance" as a standard for the control of the
discharge of pollutants which reflects the greatest
degree of effluent reduction achievable through
application of the best available demonstrated
control technologies, processes, operating
methods or other alternatives, including, where
practicable, a standard permitting no discharge of
pollutants (see Section 306(a)(l) of the CWA, 33
U.S.C. § 1316(a)(l)). 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
(see general discussion of legislative history in
American Iron and Steel Institute v. EPA, 526
F.2d 1027, 1057-59 (3rd Cir. 1975)). In
establishing these standards, Congress directed
EPA to consider the cost of achieving the effluent
reduction and any non-water quality
environmental impacts and energy requirements.
As the legislative history of the CWA makes
clear, consideration of cost in establishing new
source standards is given less weight than in
establishing BAT limitations because pollution
control alternatives are available to new sources
that would not be available to existing sources
•(see Legis. Hist. (Sen. Muskie statement of
House-Senate Conference Report on 1972
Act)).
For the oils and the organics subcategory;
EPA promulgated NSPS that would control the
same conventional, priority, and non-
conventional pollutants as the BPT effluent
limitations. The technologies used to control
pollutants at existing facilities are fully applicable
to new facilities. Therefore, EPA promulgated
NSPS oils and organics subeategory limitations
that are identical to BPT/BCT/BAT.
For the metals subcategory, however, EPA
promulgated NSPS effluent limitations based on
a technology which is different from that that
used to establish BPT/BCT/BAT limitations.
EPA promulgated NSPS for the metals
subcategory based on the NSPS technology
proposed in 1999 — selective metals
precipitation, liquid-solid separation, secondary
precipitation, liquid-solid separation, and tertiary
precipitation and clarification. This technology
'(option 3) provides the most stringent controls
attainable through the application of
demonstrated technology. EPA has concluded
that this technology is the best demonstrated
control technology for removing metals from the
metal waste streams typically treated in the
CWT industry. Additionally, EPA has
concluded that there is no barrier to entry for
new sources to install, operate, and maintain
treatment systems that will achieve discharge
levels associated with these option 3
technologies.
An additional critical factor in EPA's
decision is that new facilities will not face the
same constraints on using selective metals
precipitation that existing facilities may. Thus,
new facilities in configuring then; operation will
have the opportunity to provide sufficient space
to operate the multiple tanks associated with the
option 3 technology.
EPA's determination to establish new
source limitations based on option 3 is also tied
9-13
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWTPoint Source Category
to its conclusion that facilities using this
technology have the technical capability to
recover and reuse metals, whereas facilities
employing technologies to comply with option 4
limitations do not generally have the capability to
reuse the metals and will dispose of metal-bearing
sludges in landfills. EPA's analysis shows that in
the event that a new facility elects to recover and
re-use metals -rather than simply treating the
wastes, the start-up costs for the option 3
technology may actually be less than the start-up
costs for the option 4 technology. This is
because of the significant reduction in RCRA
permitting costs associated with recycling
activities versus wastewater treatment activities.
Furthermore, EPA has examined the market for
re-use of metals and has concluded-that these
markets exist. Consequently, EPA has concluded
that metals re-use with option 3 is viable. As
such, this technology selection promotes the-
objectives of both the Clean Water Act-and the
Pollution Prevention Act While =EEA- has-
concluded there is no barrier to entry associated
with the option 3 technology, EPA recognizes
that a CWT metals recycling facility will be
required to be somewhat more selective about the
waste receipts it accepts than a CWT treatment
facility. However, EPA's data show that the
vast majority of metal-bearing wastewaters
accepted at CWT facilities are not dilute. In
EPA's view, this is because generating facilities
elect to treat dilute metal-bearing wastestreams
on-site because of the ease in treating these
wastes and the costs associated with the transport
and treatment of these dilute wastes off-site.
Also, there is a large amount of capacity available
at existing CWT metals subcategory facilities.
Consequently, EPA has concluded that existing
CWT metals subcategory facilities already
provide adequate capacity for dilute metal-
bearing wastestreams in the event that the
frequency of dilute wastes being transferred off-
site for treatment increases. Finally, EPA notes
that new CWT metals subcategory facilities are
not required to install the option 3 technology or
to recover metals. However, EPA's economic
analyses show that new sources should carefully
consider recycling as an alternative to
wastewater treatment.
The Agency used performance data from
the CWT metals subcategory BAT limitations
data set to promulgate NSPS limitations for oil
and grease because the facility from which the
NSPS limitations were derived did not have oil
and grease in its influent at treatable levels
during EPA's sampling episodes. EPA has
concluded that transfer of this data is
appropriate given that the technology basis for
NSPS includes selective metals precipitation and
an additional precipitation step. As such,- EPA
has every reason to conclude that facilities
employing the NSPS technology could achieve
the limitations, given the fact that the oil and
grease limitations are based on performance at
a facility employing fewer treatment steps.
As was the case- for BPT/BAT, the
technology basis for the multiple wastestream
subcategory-new- source .limitations reflects the
technology basis for the- applicable
subcategories.
PRETREATMENTSTANDARDS FOR
EXISTING SOURCES (PSES)
9.5
Section 307(b) of the Clean Water Act
requires EPA to promulgate pretreatment
standards for pollutants that are not susceptible
to treatment by POTWs or which would
interfere with the operation of POTWs. EPA
looks at a number of factors in deciding whether
a pollutant is not susceptible to treatment at a
POTW or would interfere with POTW
operations — the predicate to establishment of
pretreatment standards. First, EPA assesses the
pollutant removals achieved by directly
discharging CWT facilities using BAT treatment;
Second, for CWT facilities that are indirect
'dischargers, EPA estimates the quantity of
pollutants likely to be discharged to receiving
waters after POTW removals. Third, EPA
studies whether any of the pollutants introduced
to POTWs by CWT facilities interfere with or
9-14
-------
Chanter 9 Reeulatorv Options Considered and Selected Development Document for the CWTPoint Source Category
' are otherwise incompatible with POTW
operations. In some cases, EPA also looks at
the costs, other economic impacts, likely effluent
reduction benefits, and treatment systems
• currently in-place at CWT facilities.
Among the factors EPA considers before
. establishing pretreatment standards is whether the
pollutants discharged by an industry pass through
a POTW or interfere with the POTW operation
or sludge disposal practices. One of the tools
traditionally used by EPA in evaluating whether
pollutants pass through a POTW, is a comparison
of the percentage of a pollutant removed by
POTWs with the percentage of the pollutant
removed by discharging facilities applying BAT.
In most cases, EPA has concluded that a
pollutant passes through the POTW when the-
median percentage removed nationwide by-
representative POTWs (those meeting secondary
•treatment-requirements) is less than the median
percentage removed by facilities complying with
BAT effluent limitations guidelines for that
pollutant. For a full explanation.,of how. EPA
performs its removal analysis, see Chapter 7T
For the metal and organics subcategories, the
Agency promulgated pretreatment standards for
existing sources (PSES) based on the same
technologies as adopted for BPT and BAT5.
EPA has determined that the technologies that
form the basis for PSES for this final rule are
economically achievable for both subcategories.
These standards will apply to existing facilities in
the metals and organics subcategories of the
CWT industry that introduce wastewater to
publicly-owned treatment works (POTWs).
These standards will prevent pass-through of
pollutants from POTWs into receiving streams
and also help control contamination of POTW
sludge. The final CWT pretreatment standards
represent a national baseline for treatment of
5 For the metals subcategory, the technology
basis for PSES does not include the second
clarification step since this step was only included
to meet the transferred TSS limitations that apply to
direct dischargers only.
CWT wastewaters.- Local authorities may
establish stricter limitations (based on site-
specific water quality concerns or other local
factors) where necessary.
For the oils subcategory, EPA proposed to
base PSES on option 8 even though option 9
(the BAT technology) achieved greater
removals. Option 8 is the same technology as
option 9, but does not include the secondary
gravity separation step. At that time, -the
economic analysis showed that the additional
costs associated with option 9 resulted in higher
economic impacts for the subcategory. In
. particular, EPA expressed concerns about the
economic impacts of., the more expensive
technology for small businesses in the oils
subcategoryr Furthermore, EPA estimated that
pollutant removals,.(in, pound-equivalents) for
option 9 were only one percent higher than the
removals for option 8.
Following proposal, EPA finalized its
estimates of costs, loadings reductions, and
economic impacts,, and then re-examined its
technology .selection for PSES hi the oils
subcategory. As part of this examination, EPA
carefully considered the impacts of both option
8 and option 9 and the differences between
them. EPA also looked at subsets of the oils
facilities, including the set of small businesses.
Based on an evaluation of all factors, EPA has
not changed the technology basis from the 1999
proposal and set PSES standards for the oils
subcategory based on option 8.
The Agency's economic analysis is
discussed in detail in Section X of the final
preamble and Chapter 5 of the final EA.
Briefly, in evaluating economic impacts, EPA
looks at a variety of impacts to facilities and
firms (in particular, small businesses). For this
industry, EPA determined that the most relevant
economic impacts are on CWT processes and
facilities. Waste industries such as the CWT
industry are difficult to model economically;
EPA's first attempts to model CWT operations
as part of a larger facility greatly overestimated
closures (see Section 7.2 of the 1995 EA and 64
9-15
-------
Chapter 9 Regulatory Options Considered and Selected Development Document for the CWT Point Source Category
FR 2326). EPA therefore decided to examine the
impacts on the CWT operations and, in
particular, the profitability of individual CWT
processes and facilities (note that a CWT
'Tacility" is all of the CWT processes at a given
facility and does not include the non-CWT
operations at a given facility).
EPA estimates that option 8 wuTcost $8.2
million per year while option 9 would cost $11.9
million per year. As discussed in Section X.H of
the final preamble, based on these costs EPA
projects 10 process closures (4.7 percent of
indirect oils processes) and 12 facility closures
(9.4 percent of indirect oils -facilities) associated
with option 8. EPA projects 15 process closures
(7.0 percent of indirect oils processes) and 12
facility closures associated with option 9. The
incremental economic impact of option 9 relative
to option 8 for oils, indirect dischargers is thus
five process closures. For small businesses,
however, EPA projects-two process closures (2.1
percent of indirect oils processes owned by small
businesses) and eight facility closures (14.0
percent of indirect oils facilities owned by small
businesses) for option 8. EPA projects seven
process closures (7-4 percent of indirect oils
processes owned by small businesses) and eight
facility closures for option 9. Thus, small
businesses represent a significant share of facility
closures and all of the additional process closures
associated with moving from option 8 to option
9. However, EPA estimates lower additional
pollutant removals between option 8 and option
9 than estimated in 1999. For the final rule, EPA
estimates an incremental pollutant reduction of
only 2,644 pound-equivalents between option 8
and option 9, compared to 3,658 pound
equivalents estimated at the 1999 proposal (see
Section IVJ of the final preamble for a
discussion of changes in estimated pollutant
reductions). EPA has determined that achieving
these slight additional pound-.equivalent removals
does not warrant imposition of the additional cost
and impacts of option 9. All of these reasons
support the selection of option 8 as the PSES
technology basis. Therefore, EPA promulgated
PSES standards for the oils subcategory
, technology based on option 8
In determining economic achievability for
indirect dischargers in the oils subcategory, EPA
acknowledges that .its estimates of the impacts
are not trivial (e.g., an almost 10% facility
closure rate). However, EPA has determined
that"the standards are" economically achievable
for the oils subcategory as a whole. EPA has
concluded that, in the circumstances of this
industry, the costs reflect appropriate levels for4
PSES control for a number of reasons. First,
costs are high because a significant number of
facilities in the oils subcategory will require
major upgrades.to their in-place treatment. The
information collected for this rulemaking shows
that many of the facilities with the larger impacts
have little effective treatment in place. Second,
this rule represents the first tune EPA has
established limitations and standards for this
• industry, so. some economic impact may- be
expected (American lr.on,and Steel Institute v.
EPA, 526 F.2d 1027-4 Osi^Cir, 1975)).-.
As was the case for BPT/BAT, the
technology basis for-pretreatment standards for
the multiple wastestream subcategory reflect the
technology bases for the applicable
subcategories.
PRETREATMENTSTANDARDS FOR NEW
SOURCES (PSNS)
9.6
EPA established pretreatment standards for
new sources that are equal to NSPS for priority
and non-conventional pollutants for the oils and
organics subcategories. Since the pass-through
analysis remains unchanged, for these
subcategories, the Agency established PSNS for
the same priority and non-conventional
pollutants as were established for PSES. EPA
considered the cost of the PSNS technology for
new oils and organics 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
9-16
-------
Chapter 9 Regulatory Options Considered and Selected
requirements and other non-water quality
environmental impacts and found no basis for
any different standards than the selected PSNS.
For the metals subcategory, however, EPA
establishedPSNS based on a different technology
than that proposed in 1999. At that time, EPA
proposed to base PSNS on the option 3
technology. For the final rule, however, EPA
based the pretreatment standards for new sources
on the option 4 technology. EPA concluded the
additional removals projected with the option 3
technology for indirect dischargers do not justify
the selection of option 3. This is because, unlike
in the case of direct dischargers,, a significant
share of the ^additional pollutant removals
associated with. option.3 for indirect dischargers
will occur at the POTW anyway.
As was the'case for PSES^ the technology
basis for the multiple wastestream subcategory
new source limitations reflects the technology
basis for the applicable subcategories.
9-17
-------
-------
Chapter
10
DATA CONVENTIONS AND CALCULATIONS OF
LIMITATIONS AND STANDARDS
This chapter describes the data selection, data
conventions, and statistical methodology
used by EPA in calculating the long-term
averages, variability factors, and limitations.
Effluent" limitations and standards1 for each
subcategory are based on long-term average
effluent- values and variability factors that
account'for variation Jn«treatment,perfonnance^
within a particular treatment technology over
time. This.chapter replaces the discussion of
how limitations were determined in the 1995
statistical support document2 and Chapter 10 of
the Development Document for the 1999
proposal.
FACILITY SELECTION
10.1
In determining the .long-term averages and
limitations for each pollutant of concern and each
subcategory option, EPA first evaluated
information about individual facilities and the
analytical data from their treatment systems. As
a result of this evaluation, EPA selected only
those facilities that operated the model
technology to achieve adequate pollutant
removals for use in calculating subcategory long-
term averages and limitations. EPA used data
from the appropriate influent and effluent sample
points to develop the long-term averages,
'In the remainder of this chapter,
references to 'limitations' includes 'standards.'
2Statistical Support Document For
Proposed Effluent Limitations Guidelines And
Standards For The Centralized Waste
Treatment Industry, EPA 821-R-95-005, January
1995.
variability factors, and limitations. Tables B-2
and B-3 of Appendix B identifies these facilities
and sampling points for the regulatory options.
Selection of Facilities for More than
One Option
10.1.1
- EPA selected some facilities for more than
one subcategory option if the facility treated its
wastes using more than one of the model
technologies. • For tiie-oils subcategory, faculties
4814A and4814B had the model technology for
option 8.3 The model technology for option 9 is
a combination of the option 8 model technology
and an additional pretreatment step of gravity
separation. The limitations for this option are
based on data from facilities 4813, 4814A,
4814B, and 651.4 Even though the technology
'basis for option 9 is based on an additional
treatment step, EPA included the data from the
option 8 facilities to ensure that the limitations
were based on facilities which treat the full
3In the 1999 proposal, EPA included
facility 651 in this option. However, after the
proposal, EPA re-evaluated the technology at this
facility and determined that its technology was
more sophisticated than option 8 and thus, the data
from this facility were excluded from option 8.
. 4In the 1999 proposal, EPA referred to
facility 651 as facility 701. Similarly, EPA
referred to facility 650 as 700. However,
elsewhere in the CWT record, the identifiers 700
and 701 correspond to two other facilities. To
minimize the confusion, EPA is using the
identifiers 650 and 651 for the self-monitoring
data and retaining the identifiers 700 and 701 for
the other facilities.
10-1
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
breadth of pollutants and pollutant concentrations
found in oils subcategory wastes. Thus, EPA
selected these facilities to characterize both
model technologies for options 8 and 9.
Data from a Facility for More than
One Time Period
10.1.2
If the concentration data from a facility were
collected over two or more distinct time periods,
EPA analyzed the data 'from each time period
separately. In the documentation, EPA identifies
each time period with a distinct "facility"
identifier. For example, facilities 4378 and 4803
are actually one facility, but the corresponding
data are from two time periods. In effluent
guidelines for other industrial categories, EPA
has made similar assumptions for such data,
because data from different time periods
generally characterize different operating
conditions due to changes such as management,
personnelj.and procedures.
Data from a Facility for the Same
Time Period
10.1.3
If EPA obtained the concentration data from
both an EPA sampling episode and self-
monitoring data for the same time period, EPA
combined the data from both sources into a
single data set for the statistical analyses.
This approach was consistent with EPA's
treatment of facility 651 in the 1999 proposal. In
this case, the facility provided effluent
measurements collected on four consecutive
days by the control authority and effluent
measurements collected once a month by the
facility. EPA, however, only collected influent
and effluent measurements on one day. EPA
excluded the effluent measurements from the
EPA sampling episode in its calculations because
the sample was collected as a grab sample rather
than as a composite sample of the continuous
flow system at that sample point (measurements
from continuous flow systems are generally
composite, rather than grab, samples).
However, EPA retained the influent
measurements because influent measurements
were otherwise unavailable and this information
was crucial for determining if the facility
accepted wastes containing the pollutants that
were measured in the effluent. EPA also xised
this influent information in evaluating the
pollutant removals for facility 651 (in this
document, the EPA sampling data and the self-
monitoring data are collectively identified as
'facility 651'; the EPA sampling data also is
identified as 'E5046').
This approach was also used for the data for
option 4 of the metals subcategory in calculating
the long-term averages; variability-factors, and
limitations. In the calculations for the 1999
proposal, EPA had'used the data from EPA's
sampling episode 4798 and the facility-supplied
self-monitoring data (called facility 650) as if
they~were,collected,at separate,facilities.. EPA.;
received comments suggesting that EPA .should
combine the sampling episode .' and" selfer
. monitoring data sets into a single data set for
limitations development. EPA also received
comments that the limitations could not be met.
by the facilities with the model technologies. For
this option, EPA believes that the combined
dataset is more appropriate for limitations
development. The resulting values for the long-
term averages and limitations are generally
greater than the values used for the 1999
proposal. However, EPA notes that it continued
to use only sampling .episode data in the data
editing criteria because this was the only source
of influent data. For better comparisons between
influent and effluent data, EPA also used only
the effluent data from the sampling episode in
the percent removals part of. the data editing
criteria (section 10.4.3.2) because the sampling
dates and analytical methods were identical for
both influent and effluent data.
10-2
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Different Treatment Trains at a
Facility
10.1.4
Although EPA collected all the data for
Episode 4814 during the same time period and
from the same facility, EPA has determined that
data from facility 4814 should be used to
characterize two separate facilities. Facility 4814
has two entirely separate treatment trains which
EPA sampled separately. Because the systems
were operated separately and treated different
wastes,. EPA-has treated the data as if they were
collected from two different facilities (EPA has-
identified the systems as 4814A and 4814B).
This is also consistent with EPA's
conventions for the characterization sampling
used in developing the current loadings for the
oils subcategory (see section 12.3.2)._ In that
analysis, EPA- considered treatment^ trains-
separately for two of the facilities. The different
treatment trains were identified as 5053A,
5053B, 5054A, and 5054B.
SAMPLE POINT SELECTION
Effluent Sample Point
10.2
10.2.1
For each facility used in developing the
limitations, EPA selected the effluent sample
point representing wastewater discharged by the
model technology which was the basis for that
subcategory option. For example, the effluent
discharged from sample point SP12 at facility
1987 is the effluent resulting from the model
technology selected for option 4 of the organics
subcategory.
Influent Sample Point
10.2.2
Influent data were available for all EPA
sampling episodes. However, relevant influent
data were not available for any of the self-
monitoring effluent data except for Facility 651
(as explained in section 10.O). As detailed in
Chapter 12, for the. metals and organics
subcategories, influent data represent pollutant
concentrations hi "raw", untreated wastes. For
the oils subcategory, however, influent data
represent pollutant concentrations following
emulsion breaking/gravity separation. Therefore,
for each facility, EPA determined the relevant
influent sample point for the waste entering the
model technology selected as the basis for that
subcategory option.
In some cases, EPA estimated influent
pollutant concentrations by combining pollutant
measurements from two or more influent sample,
points-into a, single, flow-weighted value. For
example, in option 3 of the metals subcategory,
EPA collected influent samples at five points
(SP01, SP03, SP05, SP07, andSPIO) during the
sampling episode at Facility 4803. EPA
calculated a single value from these five sampling
points representing the influent to the model
technology using the methodology described in-
Section 10:4:33: ' :
Special Cases
10.2.3
-As detailed previously in Chapter 2, for
samples collected during EPA sampling episodes,
EPA did not analyze for the full spectrum of
pollutants at each sampling point. The specific
constituents analyzed at each episode and
samplingpoint varied and depended on the waste
type being treated and the treatment technology
being evaluated. For example, for the metals
subcategory, EPA did not generally analyze for
organic pollutants in effluent from chemical
precipitation and clarification. Therefore, in
some cases, for specific pollutants, EPA selected
a different sample point to represent influent to
and effluent from the model treatment
technology than the sample point selected for all
other pollutants. For example, for Episode 4803
in metals option 3, EPA,selected sample point 15
to represent the effluent from the model
technology. Since EPA did not analyze the
wastewater collected at sample point 15 for oil
and grease/n-hexane extractable material (HEM),
silica gel treated n-hexane extractable material
(SGT-HEM), total cyanide, and organic
10-3
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
constituents, for these pollutants only, EPA
selected sample point 16 to represent the effluent
point for Episode 4803 of metals option 3. EPA'
concluded that this is appropriate since the
treatment step between sample point 15 and
sample point 16 should not have affected the
levels of these pollutants in the wastewater.
Other such cases are identified in the tables in
Appendix B and in the CBI record (for the oils
subcategory).
DETERMINATION OF BATCH AND
CONTINUOUS FLOW SYSTEMS
10.3
. For each influent and effluent sample point
of interest, EPA determined whether wastewater
flows were 'continuous' or 'batch.' These
designations are provided in the tables in
Appendix B.
At sample points associated with continuous
flow processes, EPA- collected composite
samples for all analytes except for oiTand grease
and HEM for which the analytical methods
specify grab samples. Also, if EPA field
composited samples of batches for each day at
a batch flow system, the statistical analyses used
the data as if they were from continuous flow
systems.
At sample points associated with batch flow
processes, EPA usually collected grab samples of
different batches.
For self-monitoring data, EPA assumed the
wastewater flow to be either continuous or batch
based on the type of discharge at the facility (i.e.,
continuous or batch discharge).
EPA made different assumptions in
analyzing the data depending on the two types of
flow processes. For each sample point
associated with a continuous flow process, EPA
aggregated all measurements within a day to
obtain one value for the day. This daily value
was then used in the calculations of long-term
averages, variability factors, and limitations. For
example, if samples were collected at the sample
point on four consecutive days, the long-term
average would be the arithmetic average of four
daily values. (Sections 10.4.2 and 10.5 discuss
data aggregation and calculation of long-term
averages, respectively.) In contrast, for each
sample point associated with a batch flow
process, EPA aggregated the.measurements to
obtain one value for each batch. This batch
value was then used as if it were a daily value.
For example, if one sample was collected from
each .of-20-batches treated on four consecutive
days (i.e., a total of 20 samples during a four day
period), the long-term average for the facility
would be the arithmetic average of the 20 batch
values.
For simplicity, the remainder of the chapter
refers to. both, types, of.aggregated. values (i.e.,
daily and batch values) as 'daily values.' In
addition, references to 'sampling day' or 'day'
mean either a sampling day at a continuous flow
facility or-a batch from aJsatcbJlow facility.
DATA SELECTION
10:4
After the 1999 proposal, EPA re-evaluated
the- bases for the data exclusions and
assumptions used in calculating limitations. As a
result of its review of sampling episode reports,
EPA retained the same exclusions and
assumptions with some minor modifications.
EPA also performed a detailed review of the
analytical data. As a result, EPA's database was
corrected and the corrected version has been
placed in the record for this rule'making.
The modifications to the data exclusions and
assumptions and the corrections to the database
are discussed in this section.
Data Exclusions and Substitutions
10.4.1
In some cases, EPA did not use all of the
data detailed in Appendix B to calculate long-
term averages, variability factors and limitations.
This section details these data exclusions and
substitutions. Other than the data exclusions and
substitutions described in this section and those
resulting from the data editing procedures
10-4
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
(described in section 10.4.3), EPA has used all
the data from the facilities and sample points
presented in Appendix B.
Operational Difficulties
10.4.1.1
EPA excluded data that were collected while
the facility was experiencing operational
difficulties. For the data used in calculating long-
term averages and limitations, this occurred
during sampling at episode 4814 only. During
the.second day of sampling, 9/17/9,6, me, facility
was required to shut-down and re-start the
operation of both of its DAF systems due to poor
performance and equipment failures. As such,
EPA excluded all data collected on 9/17/96
associated with sample point 09 at facility 4814A
and sample point 10 at facility 4814B.
Treatment Not Reflective of
EPT/BCT/BAT Treatment
10.4.1.2
EPA reviewed the effluent data used to
develop the limitations and excluded any facility
data set where the long-term average did not
reflect the performance expected by
BPT/BCT/BAT treatment. As a result of this
review, EPA excluded some of the metals and
conventipnals data as representing less than
optimal treatment.
EPA continued to exclude the mercury
values from facility 602 in option 3 of the metals
subcategory (these were previously excluded for
the 1999 proposal). EPA excluded these values
because the smallest value was 1 ug/L when the
largest effluent value obtained during two
different EPA sampling episodes at that facility
was almost five times less at 0.21 ug/L.
EPA also continued to exclude nickel from
facility 651s in option 9 of the oils subcategory
because it had one extremely large effluent value
of 25,000 ug/L. The facility indicated that the
waste receipts from a single source were
unexpectedly concentrated with nickel and the
facility did not optimize its treatment accordingly.
The facility no longer handles such highly
concentrated nickel wastes.
As a result of its review after the 1999
proposal, EPA excluded all of the metals data
from sampling, episode 4813 because its
treatment system generally demonstrated poor
removals"ofmetalsrFormost-metals, the facility .
had low levels in the influent and the .data did not
even pass EPA's data editing criteria described in
section 10.4.3.1. For the remaining metals, the
facility generally demonstrated poor removals
with much lower influentand effluent levels than
the other facilities used as«abasis for that option.
By removing these data, the limitations-fortwo-
analytes, copper and zinc, have higher values
than those hi the 1999 proposal.
As explained in section 10:8, as a result of its
review after the 1999 proposal, EPA transferred
the limitations for lead for metals option 4 to
metals option 3. However, in the group
variability factor6 calculations, EPA retained
these data because they still represent the
5Although the Development Document
for 1999 proposal did not cite this exclusion,
EPA excluded these data in the 1999 proposal. In
any case, the data do not pass the LTA test
described in Section 10.4.3.1 and thus would not
have been included in any calculations for the
limitations, even if they had not been specifically
excluded.
6As explained later in this chapter, EPA
generally used pollutant variability factors rather
than group variability factors in calculating the
limitations. For a few pollutants, however,
pollutant variability factors could not be
calculated because the data were mostly non-
detects. In these cases, EPA used group
variability factors or the organics variability
factors instead.
10-5
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
variability expected by the model technologies
for option 3.
'The remaining excluded facility data sets
were for conventional parameters (i.e., oil and
grease, BOD5, and TSS) and EPA also excluded
these for the 1999 proposal. In all cases, these
data sets were collected at facilities that are
indirect dischargers that are not required to
optimize performance of their system for
removal of these pollutants. In most cases, the
conventional pollutants are not limited by the
POTW and the facility is not required to monitor
for these pollutants. These exclusions were for
oil and grease (facilities 4813,4814A, and 4814B
for option 9 of the oils subcategory), BOD5
(facility 1987 for option 4 of the organics
subcategory), TSS (facility 1987 for option 4 of
the organics subcategory, and facilities 4798 and
700 for option 4 of the metals subcategory).
Similarly, in calculating long-term averages
for oils option 9, EPA excludeitheiTSS data for
facilities 4813, 4814A, and 4814B. However,
EPA used these data to calculate variability
factors for TSS for oils option 9 because EPA
concluded that the data reflected the overall
variability associated with the model technology
(Sections 10.5, 10.6, and 10.7 describe the
development of the long-term averages,
variability factors, and limitations, respectively).
Exclusions to EPA Sampling Data
Based Upon the Availability of the
Influent and Effluent
10.4.1.3
After the 1999 proposal, EPA reviewed its
assumptions based on the availability of influent
and effluent data. For the final CWT rule, EPA
has retained these same assumptions. This
section describes those assumptions.
For the data from the EPA sampling
episodes, EPA determined the availability of the
7EPA did not similarly exclude data for
facilities 4814A and 4814B from the option 8
calculations since EPA did not select this option
as the basis of the BPT/BCT limitations.
influent and effluent data for each sampling day.
Both influent and effluent levels are important in
evaluating whether the treatment system
efficiently removed the pollutants. In addition,
the pollutant levels in the influent indicate
whether the pollutants existed at treatable levels.
In most cases, both influent and effluent data
were available for a given day.
For the cases when effluent data were
unavailable for some days, but influent data were
available, EPA generally determined that the
influent data still provided useful information
about the pollutant levels and should be retained.
However, for the organic pollutants at facility
4378, the effluent data were only available for
one day while the influent data were available for
several days. In this case, EPA determined that
the percent removals for the facility should be
calculated by pairing the influent and effluent
levels for that single day. Otherwise, the percent
removals would'be calculated" using an average
over several days of influent compared to one
effluent value from a single day. However, all of
the influent data were used for the long-term
average test described in section 10.4.3.1. This
is because the test only considers influent data
and does not consider effluent .values..
When effluent data were available but
influent data were unavailable, EPA determined
that the effluent data should be excluded from
further consideration. Without the influent data,
EPA could not evaluate the treatabiliiy of the
pollutants and the effectiveness of the treatment
system.
More Reliable Results Available
10.4.1.4
In some cases, EPA had analytical data
which represent a single facility (andtime period)
that were analyzed by two different laboratories
or using two different analytical methods. For
several of these cases, EPA determined that one
analytical result was more reliable than the other
and excluded the less reliable result. This section
describes these cases.
10-6
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
In limited instances, facility 650 (used for
metals subcategory option 4) provided two
analytical results for the same date from different
laboratories. For the'total cyanide effluent data
collected on 11/6/96, the analytical results from
the two laboratories differed considerably. This
facility considered the result generated by the
off-site laboratory to be more reliable than the
result generated by its on-site laboratory and
recommended-that---EPA- use the off-site data
only. EPA agrees with this suggestion and has
used only the value from the off-site laboratory
in the final rule (this is the same assumption used
in the 1999 proposal).
Some chlorinated phenolics in episode 1987
(used for the organics subcategory8) were
analyzed by both Method ~851"OT" and' Method
1625. Thusrfor a given sample,-EPA obtained"
two results for each chlorinated phenolic. Of the
pollutants of concern for the organics
subcategory, these., compounds were
pentachlorophenol, 2,3,4,6-tetrachlorophenol,
2,4,5-trichlorophenol, and 2,4,6-trichlorophenol.
Where two results were provided for the same
pollutant in a sample, EPA used the analytical
result from Method 1625 in the final rule and in
the 1999 proposal. This decision is based on the
knowledge that Method 1625 is an isotope
dilution GC/MS procedure, and therefore
produces more reliable results than Method
85.01.
After the 1999 proposal, EPA excluded the
remaining Method 85.01 data in calculating
variability factors used to develop the limitations.
As explained in Chapter 15, Method 85.01 was
only used to analyze samples from one CWT
sampling episode and has been replaced by
Method 1653. Because of some large
discrepancies between some of the values from
8EPA also used the data from E1987 for
the metals subcategory to determine pollutants of
concern and baseline loadings. However, none of
the chlorinated phenolics were pollutants of
concern for the metals subcategory.
Method 85.01 and Method 1625 (which also was
used to analyze some chlorinated phenolics),
EPA decided that it was more appropriate to
exclude all Method 85.01 data from any of the
calculations for limitations. This included
calculation of group variability factors as
described in section 10.6.7. However, when
Method 1625 data were not available for the
analyte, EPA retained the Method 85.01 data as
the best available information to calculate current
loadings for the organics subcategory.. as
described in section 12.3.3.
Data from Facilities Which Accepted
Waste from More than One
Subcategory 10.4.1.5
For the final rule,,,EPA also continued to.
exclude data that were collected during time
periods, when the- facility treated wastes from
more than one CWT subcategory. For metals •
option 4, EPA excluded the data for all analytes
when oil and grease values in the effluent were
greater than 143 mg/L. Such high values were
obtained in the, effluent monitoring data provided
by the facility, but not in the data from EPA's
sampling episode at that facility. As is common
practice, the facility monitored its effluent and
not its influent. This meant that EPA was unable
to fully evaluate the cause of such high levels of
oil and grease in the effluent. However, EPA
concluded that these oil and grease levels
indicated the facility treated both oils and metals
subcategory wastes on those days and the data
were not representative of the metals wastes
alone. EPA concluded that the value of 143
mg/L indicated that the wastes were a
combination of oils and metals wastes because
143 mgTL was the highest value measured for oil
and grease in the influent samples collected at
any other metals subcategory facility. Because
such 'high levels are common in the oils
subcategory, EPA considers values of oil and
grease in the, effluent above this level to indicate
that the facility was also treating oils subcategory
wastes. For the days when such high levels were
10-7
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
reported, EPA excluded the oil and grease data
and the data for other analytes from its
calculations for metals option 4.
Data Collected by EPA and the
Facility on the Same Day
. 10.4.1.6
After the 1999 proposal, EPA determined
that it was appropriate to combine the data from
the EPA sampling episodes and the facility's self-
monitoring data from the same time period (see
section 10.1.3) for metals option 47 EPA
generally retained both measurements for all
analytes where both the self-monitoring data and
the sampling episode data contained
measurements for the same, day. In the
analyses, EPA arithmetically averaged the two
values-to-obtain .a-single daily value.
The only exception to this general rule was
for the oil and grease measurements; For this-
analyte, EPA collected a series of grab samples
throughout each day while the-facility collected-
a single grab sample. Without referring to
detailed information about the facility's sample
collection on that day, EPA could not determine
if the grab sample should be combined-with-one-
of EPA's grab samples from approximately the
same time period or whether the time periods
were substantially different. Furthermore, it is
also likely that the facility used a different
method than EPA in its laboratory analysis (EPA
used Method 1664 and, at that tune, facilities
more commonly used Method 413.1).
Substitution Using the Baseline
Values
10.4.1.7
In determining the pollutants of concern
(Chapter 6), calculating the baseline loadings
(Chapter 12), and developing the pollutant long-
term averages and limitations, EPA compared
each laboratory-reported sample result to a
baseline value (defined in Chapter 15). For
certain pollutants, EPA substituted a larger value
than the measured value or sample-specific
detection limit These pollutants were measured
by Methods 1624 and 1625 (organic pollutants)
and Method 1664 (n-hexane extractable material
(HEM) and silica gel treated ri-hexane extractable
material (SGT-HEM)). For these pollutants,
EPA substituted the baseline value and assumed
that the measurement was non-detected when a
measured value or sample-specific detection limit
was reported with a value less than the baseline
value.9 For example, if the baseline value was
10 ug/1 and the laboratory reported a detected
value of 5 ug/1, EPA" assumed" thar the
concentration was non-detected with a sample-
specific detection limit of 10 ug/1. This was
consistent with the procedure used in the 1999
proposal.
For consistency, when the oil and grease
values (measured by Method 413-.-1) -for facility-
651 were below the Method 1664 baseline value
of 5 mg/L, EPA considered the measurement to
be non-detected with a sample-specific detection,
limit of 5 mg/L m>the calculations for both-the-
1999 proposal and the final rule.
As explained in Chapters^ 15; andr 12; in-
determining the pollutants of concern and the
pollutant loadings, respectively, EPA used the
baseline value for semiquantitative analytes from
episode 1987. However, in calculating the long-
term averages and limitations, this substitution
was unnecessary because these data either had
reported measured values or sample-specific
detection limits.
Other than the exceptions in this subsection,
for all other pollutants at this and other episodes,
EPA used the reported measured value or
sample-specific detection limit in its calculations.
9For p-cresol, EPA used the baseline
value of 10 ug/L (which was based on the results
of one early study of the analytical method) in all
analyses except in calculating the limitations. In
• calculating limitations, EPA used the value of 20
ug/L which is identified as the minimum level in
the final rule.
10-8
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Corrections to the Database and
Changes in Data Selections
10.4.1.8
After the 1999 proposal, EPA re-examined
its databases and corrected some errors.
Correcting two errors in the facility 602
database slightly changed the nickel and arsenic
long-term averages and limitations for option 3 of
the metals subcategory. For nickel, EPA
corrected one value of 1000 ug/L to 10 ug/L
(previously, it was the maximum value hi the
data set; it is now the minimum value). EPA
also included one additional value for arsenic
which had previously, been overlooked (this
value was close to the average value).
For the data coUected-diuing-EPA_sampling_
episodes at some oils subcategory facilities, EPA
also corrected some; of the semi-volatile values
measured by .Method 1625. These values had
been over-adjusted'for dilution during chemical
analysis at the laboratory. As-a result of these
corrections, some - measurements had lower
values than those used in the 1999 proposal. In
addition, some values were corrected to be
below detection and were then identified as
'non-detected' with sample-specific detection
limits equal to the baseline values from Method
1625. None of the effluent values changed that
were used in calculating the limitations. The
adjusted data were for concentrated samples
from non-effluent sample points (e.g., influent).
These adjusted data values were used to
determine the pollutants of concern, the industry
current loadings, and the influent levels used in
the data editing criteria which determined if the
data should be used in developing the limitations.
As a result of these changes, some analytes, such
as benzo(a)pyrene, which had been identified as
pollutants of concern in the 1999 proposal, were
no longer identified as pollutants of concern and
were not used hi calculating the current loadings
or the group variability factors. Other than
changes to the pollutants of concern, EPA
cannot readily determine the impact of these
corrections to its current loadings for the oils
subcategory because EPA also made
methodology changes for these calculations as
.described in Chapter 12. It is easier for EPA to
determine the effect of these data corrections on
the results of the data editing criteria. This can
be done by comparing the influent results in
Appendix C hi this document to Appendix C in
the 1999 proposal Development Document For
example, the daily influent value for
acenaphthene for facility 651 (which is the
influent from episode 5046) has changed from
366 ug/L to 238 ug/fc:10~None-ofthe corrections
to the data-from Method 1625 changed the
selection'of regulated.analytes or the values of
the limitations and group variability factors.
In developing the pollutants of concern for
all., three- subcategories for the 1999 proposal,
EPAintended.to select those pollutants that were-
detected (at treatable levels) 10 percent of the
time. However, in reviewing the computer
programs prior to promulgating the final rule,
EPA determined that the programs selected those
analytes detected 50 percent of the time. For the
final rule, EPA has-corrected its programs-to 10
percent This correction has little effect onthe -
final selection of pollutants of concern and no
effect on the choice of regulated pollutants.
However, it did change a few of the pollutants
used in developing group variability factors. One
such case is lithium in the oils subcategory which
was previously used hi the group variability
factor calculations (for the metals group), but is
no longer a pollutant -of concern and
consequently has been excluded from those
calculations. Changes to the pollutants of
concern are identified in DCN 36.1.1.
In its data editing criteria, EPA changed the
wastestream flows for the influent sample points
for facility 4803 hi metals option 3. For the
IOIn the proposal Development
Document, Appendix C incorrectly identifies the
sampling date for facility 651 as 04/06/98. The
correct date is 03/03/98 which corresponds to the
influent from episode 5046.
10-9
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
1999 proposal, EPA used the average flow at
each sample point. For the final rule, EPA used
the flow corresponding to each sample point on
the" day that it was sampled because this provides
more accurate estimates. As a result of this
change in the flows, for the final rule, selenium
passed the data editing criteria (previously it had
failed). Because EPA indicated its intention to
regulate selenium for the metals subcategory in
the 1999 proposal, the final rule regulates
selenium for option 3 (which is the basis for
NSPS). The change in the flows also changed
the analytes that passed the data editing criteria
and that subsequently were used for group
variability factor calculations for metals option 3.
These can be identified by comparing
Attachment 10-1 in Appendix E of the 1999
proposal Development Document to the
Appendix D in this document.
For the final rule, EPA also incorporated the
changes described in-Ghapter^? in-its selection-of
analytes used to develop- the- group- variability-
factors and the analytes selected for regulation.
For example,,in the metals subcategory, EPA
excluded maganese as a regulated analyte and
from the group variability factor calculations
because it is used as a treatment chemical and its
variability could be different than analytes treated
by the model technologies.
Data Aggregation
10.4.2
In some cases, EPA determined that two or
more samples had to be mathematically
aggregated to obtain a single value that could be
used in other calculations. In some cases, this
meant that field duplicates, grab samples, and/or
multiple daily observations were aggregated for
a single sample point or batch. In other cases,
data from multiple sample points were
aggregated to obtain a single value representing
the influent to the model technology (aggregating
over multiple sample points was not necessary
for effluent from the model technologies because
the effluent data for any one particular analyte
were all obtained from a single sample point at
each facility).
In all aggregation procedures, EPA
considered the censoring type associated with the
data. EPA considered measured values to be
detected. In statistical terms, the censoring type
for such data was 'non-censored' (NC).
Measurements reported as being less than some
sample-specific detection limit (e.g., <10 rng/L)
are censored and were considered to be non-
detected (ND). In the tables and data listings in
this document and the record for the rulemaking,
EPA has used the abbreviations NC and ND to
indicate the censoring types.''
The distinction between the two censoring
types is important because the procedure used to
determine the variability factors considers
censoring type explicitly. This estimation
procedure modeled the facility data sets using the
modified delta-lognormal distribution. In-this—-
distribution, data are modeled as a mixture of
two—distributions corresponding to different
process conditions. Because this industry treats
different types of waste from day to day, EPA
assumed that the process conditions leading to
non-detected values are generally different than
process conditions leading to the detected values
(for example, a facility may treat wastewater
with relatively high levels of organics and low
levels of metals and the next day treat wastes
that have high metals concentrations and non-
detectable levels of organics). Thus, EPA
concluded that the distinctions between detected
and non-detected measurements were important'
in estimating the variability factors.
Because each aggregated data value entered
into the model as a single value, the censoring
11 In very few instances, some of the
laboratories reported numerical results for
specific pollutants detected in the samples as
"right-censored." Right-censored measurements
are those that were reported as being greater than
the highest calibration value of the analysis (e.g.,
>1000 ug/L). EPA used these values as though
they were non-censored. ,
10-10
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
type associated with that value was also
important. In many cases, a single aggregated
value was created from unaggregated data that
were all either detected or non-detected. In the
remaining cases with a mixture of detected and
non-detected unaggregated values, EPA
determined that the resulting aggregated value
should be considered to be detected because the
pollutant was measured at detectable levels.
This section describes each" of "the different
aggregation procedures. They are presented hi
the order that the aggregation was performed.
That is, field duplicates were aggregated first,
grab and multiple samples second, and finally
multiple.streams. For example,.if EPA has four
pairs of data (i.e., four influent samples and four
duplicate influent samples), then EPA aggregated
each of the four pairs to obtain four values -- one
for each pair of data. These four values were
then-aggregated-to.obtaurone daily value for the
influent stream at that particular sample point.
As a further example, suppose the same facility
had two additional streams entering 'into -the
treatment system. Thus, the influent into the
treatment system would be characterized by the
combination of the pollutant levels at three
different sample points for the three streams. To
obtain one value to characterize the influent, the
pollutant levels at the three sample points would
be 'flow-weighted' by the wastewater flow at
each sample point The following three sections
specify the procedures used to aggregate field
duplicates, grab samples (and daily values), and
multiple influent streams, respectively. These
aggregation procedures are the same as those
used in the 1999 proposal.
Aggregation of Field Duplicates 10.4.2.1
During the EPA sampling episodes, EPA
collected a small number of field duplicates.
Generally, ten percent of the number of samples
collected were.duplicated. Field duplicates are
two samples collected for the same sampling
point at approximately the same time, assigned
different sample numbers, and flagged as
duplicates for a single sample point at a facility.
Because the analytical data from each
duplicate pair characterize the same conditions at
that time at a single sampling point, EPA
aggregated the data to obtain one data value for
those conditions. The data value associated with
those conditions was the arithmetic average of
the duplicate pair.
In most cases, both duplicates in a pair had
the same censoring type. In these cases, the
censoring type of the aggregate was the same as
the duplicates. In the remaining cases, one
duplicate was a non-censored value and the other
duplicate was a non-detected value. In these
.cases, -EPA determined that the appropriate
censoring" type of the aggregate "was
'non-censored' because the pollutant had been
present in one sample (even if the other duplicate
had a zero value12, the pollutant still would have-
been present if the samples had been physically
combined). Table 10-1 summarizes the
procedure for aggregating the analytical results
from the field duplicates. This aggregation step
for the duplicate pairs was the first step in the
aggregation procedures for both influent and
effluent measurements.
12This is presented as a 'worst-case'
scenario. In practice, the laboratories cannot
measure 'zero' values. Rather they report that the
value is less than some level (see Chapter 15).
10-11
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Table 10-1. Aggregation of Field Duplicates
If the field duplicates are: Censoring type of Value of aggregate is:
average is:
One non-censored and
one non-detected
Formulas for
aggregate value of
duplicates:
Both non-censored
Both non-detected
NC
ND
arithmetic average of
measured values
arithmetic average of
(NC,+NC2)/2
(DL,+DL2)/2
sample-specific detection
limits
NC arithmetic average of (NC + DL)/2
measured value and sample-
specific detection limit
NC=non-censored(or detected) ND=non-detected
DL=sample-specific detection limit
Aggregation of Grab Samples and
Multiple Daily Values-
10.4.2.2
This section describes the aggregation-of-
grab samples and multiple daily values for
effluent sample points associated with continuous
flow facilities (defined in section 10.3)r "
During the EPA sampling episodes, EPA
collected two types of samples: grab and
composite. Typically, for a continuous flow
system, EPA collected composite samples;
however, for oil and grease, the method specifies
that grab samples must be used. For that
pollutant, EPA collected multiple (usually four)
grab samples during a sampling day at a sample
point associated with a continuous flow system.
To obtain one value characterizing the pollutant
levels at the sample point on a single day, EPA
mathematically aggregated the measurements
from the grab samples.
In the self-monitoring data, facilities
occasionally reported more than one value for a
single day. If the sample point was associated
with a continuous flow system, then EPA
mathematically aggregated the results to obtain
one daily value.
EPA used the same procedure for grab
samples and multiple daily values. The
procedure arithmetically averaged, the
measurements to obtain a single value for the
day. When one or more measurements were
non-censored, EPA determined that "the"
appropriate censoring type of the aggregate was
'non-censored' because the pollutant was
present. Table 10-2 summarizes the procedure.
10-12
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Table 10-2. Aggregation of Grab Samples and Daily Values
If the grab or multiple Censoring type of Daily value is:
samples are: Daily Value is: '•
Formulas for Calculating
Daily Value:
All non-censored
All non-detected
NC arithmetic average of
measured values
ND arithmetic average of sample-
specific detection limits
Mixture of non-censored
and non-detected values
(total number of
observations is.n==k+m),.
NC
arithmetic average of - .-
measured values and sample— *- "
specific detection limits y JVC- + / DL-
• • 1=1 1=1
n
NC=non-censored (or detected)
ND=non-detected
DL=sample-specific
detection limit
Aggregation of Data Across
Streams ("Flow- Weighting ")
10.4:2:3-
After field duplicates and grab samples-were,
aggregated, the data were further aggregated
across sample points. This step was necessary
when more than one sample point characterized
the wastestream of concern. For example, this
situation occurred for facility 4803 where five
different wastestreams entered into the treatment
process. EPA sampled each of these
wastestreams individually at sample points SP01,
SP03, SP05, SP07, and SP10. In aggregating
values across sample points, if one or more of
the values were non-censored, then the
aggregated result was non-censored (because the
pollutant was present in at least one stream).
When all of the values were non-detected, then
the aggregated result was considered to be non-
detected. The procedure for aggregating data
across streams is summarized in Table 10-3.
The .following example demonstrates the
procedure for hypothetical pollutant X at a
facility with three streams entering into the
treatment system on day 1 of the sampling
episode.
10-13
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Example of calculating an aggregated flow-weighted value:
Day Sample Point
1 SP33
1 SP34
1 SP35
Flow (gal)
10,000
20,000
5,000
Concentration (ug/L)
10
50
100
Censoring
ND
. NC
ND
Calculation to obtain aggregated, flow-weighted value:
(I0,000ga/x IQug/L) + (20,000 galx 50 tig IL) + (5,000 ga/x lOOug/L) _ •
10,000gal+ 20,000gal+ 5,000gal ~ ' "g
Because one of the three values was non-censored, the aggregated value of 45:7 ug/L is non-censored.
Table 10-3. Aggregation of Data Across Streams
If the n observations are:
Censoring
type, is:
Formulas for value of aggregate^
All non-censored
All non-detected
Mixture of k non-censored and
m non-detected
(total number of observations is
n=k+m)
NC
ND
NC
1=1
flow i
i=\
DLt xflo\vt
NC=non-censored(or detected) ND=non-detected
DL=sample-specific detection limit
Data Editing Criteria 10.4.3 the long-term averages and limitations. These
criteria were specified by the 'long-term average
After excluding some data (as detailed in tesf (or LTA test) aiid 'percent removals test.'
Section 10.4.1) and aggregating the data (section For each of the reguiatory options and
10.4.2), EPA -applied data editing criteria to pollutants of concern evaluated for long-term
select facility date sets to be used in calculating
10-14
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
averages and limitations, Attachment 10-1 in
Appendix D indicates whether the data from the
EPA sampling episodes failed the data editing
criteria, indicates when no data were available
for a pollutant at any of the facilities, or provides
the facility-specific long-term average (calculated
as described in section 10.5). Table 12-9
presents the results on an option-level basis. If
all of the facility data sets within an option failed
the tests, then the table indicates that the analyte
failed the tests. Otherwise^ the table lists the
pollutant long-term average calculated using the
facility data sets that passed the tests (see section
10.5.2).
The criteria for the self-monitoring" data-
depended upon the results of the data editing
criteria for facility data sets from the EPA
sampling episodes.
These data editing criteria for the EPA
sampling episodes and the self-monitoring, data
are described in the following ^sections. .These
criteria are the same as-used-4h the" 1999
proposal. However, the following discussion
provides additional clarification and information.
Long-Term Average Test
10.4.3.1
EPA established the long-term average test
('LTA test') to ensure that the pollutants were
present in the influent at sufficient concentrations
to evaluate treatment effectiveness at the facility.
After the data aggregation described in section
10.4.2, EPA compared the daily values of the
influent and their long-term average to the
baseline values described in Chapter 15. The
influent had to pass a basic requirement and one
of the following two steps to pass the LTA test:
Basic Requirement: Fifty percent of the
influent measurements had to be detected at any
level.
If the data set passed this basic requirement,
the data set then had to pass one of the following
two conditions:
Step 1: Fifty .percent of the influent
measurements had to be detected at
concentration levels at treatable levels
which was any value equal to or greater
than ten times the baseline value for the
pollutant (the baseline values are listed
in Attachment 15-1); or
Step 2: The influent long-term average had to
be equal to or greater than ten times the
baseline value (Section 10.5 describes
the calculations for long-term averages).
If the data set failed the basic requirement,
then-EPA automatically_ set Step 1 and Step 2 to
'fail.'
When the data set at a facility failed the
basic requirement or-both steps, EPA excluded
the effluent data for the facility in calculating the
long-term averages, variability- factors,, and.-
limitations for the corresponding option in the
subcategory.
'For example, at facility 1987, if the arsenic
data from influent sample point 07B failed any of
the editing criteria, then the effluent data at
sample point SP12 were excluded from
calculatingthe long-term averages and limitations
for option 4 of the organics subcategory.
In performing the LTA test, EPA used the
influent sample points identified in Table B-2 in
Appendix B. An example of the LTA test is
provided in section 10.4.3.4. •
Percent Removal Test
10.4.3.2
If the influent data passed either step in the
LTA test, then EPA calculated the facility's
influent and effluent averages using the
aggregation steps previously described. This is a
deviation from the procedure used in the 1999
proposal where EPA did not aggregate batches,
grabs, or multiple daily values (oHier than
duplicates) as an interim step prior to obtaining
one overall value for the wastestream. This
procedure is now consistent with the calculations
for the influent averages used in LTA test (in
10-15
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
section 10.4.3.1) and the effluent long-term
averages used in the limitations (in section 10.7).
The percent removal test compared the'
influent and effluent averages to determine if the
treatment associated with.the effluent sample
point removed any of the pollutant. If the
removals were negative, then EPA excluded the
effluent data from developing the long-term
averages and limitations.
Percentremoval=
Influent average- Effluentaverage
Iiifluentaverage
xlOO
. • In performing the percent removals test for
each facility, EPA used the influent and
corresponding effluent points identified in Tables
B-2 and B-3, respectively, in Appendix B.
Section 10.4.3.4 provides,-an. example of the
percent removal test
Evaluation of Self-Monitoring Data 10.4.3.3
EPAused self-monitoring data for effluent at
three facilities in "developing "the long-term
averages and limitations. These facilities were
602, 650, and 651. These facilities provided
concentration values for some of the pollutants
that EPA considered in developing the long-term
averages and limitations. However, the self-
monitoring data were for effluent only (i.e., no
influent data were provided). In its evaluation of
the data, EPA determined that influent data
provided critical evidence that the facility treated
wastes containing these pollutants. Thus, EPA
used influent data from its sampling episodes to
determine if the facility accepted wastes
containing these pollutants.
For facility 651, EPA collected influent
information during the same time period as the
effluent data provided by the facility. As
described in section 10.1, EPA used this influent
information with the facility 651 effluent data.
For facility 602, EPA considered the
pollutant levels in the influent at the EPA
sampling episodes. As explained in section 10.1,
different facility numbers may refer to the same
facility. For option 3 of the metals subcategory,
facilities 602, 4378, and 4803 are the same
facility (Facilities 4378 and 4803 were EPA
sampling episodes). If the influent data at facility
4378 or facility 4803 met the data editing criteria
(i.e., LTA test and percent removals test), then
EPA used the effluent data from facility 602 in
calculating the long-term averages and limitations
for the pollutant. If "the influent data for the
pollutant at facility 4378 and facility 4803 did not
meet the criteria, then EPA excluded the data
from facility 602.
In a similar manner, facilities 4798 and 650
for option 4 of the metals subcategory were
linked. As described in section 10.1.3, EPA
used the data from the EPA sampling episode
4798 in the data editing criteriar-In-developing-
the limitations, EPA used the combined data set
from the sampling episode 4798 and facility 650.
Thus, if the influent data-for a pollutant at facility
4798 passed the LTA test and the influent and
effluent data passed the percent removals test,
then EPA used the effluent data from the
combined data set in calculating the long-term
averages and limitations for the pollutant. If the
data for the pollutant at facility 4798 did not
meet the criteria, then EPA excluded the
combined data set in calculating the long-term
averages and limitations for the pollutant.
10-16
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Examples of Applying Data Editing
Criteria
10.4.3.4
This section provides four examples of
applying the data editing criteria described in
sections 10.4.3.1 and 10.4.3.2. In the following
examples, there is a short summary of the
purpose of the example, followed by a listing of
the data. After the data, there is another short
summary that provides the results 'of the data
editing criteria demonstrated in the example.
In each of the data listings, the column
"Concentration value" lists the reported data
values prior to aggregating duplicates (if the data
is from a duplicate pair, then the phrase '- dup'
follows the concentration value and the matching
duplicate is listed either directly above or below
that value). The column "Influent daily value
(aggregated)" provides one value for each day
after aggregating any duplicate samples (Table
10-1 identifies the methodology for aggregating
duplicates). If the "Concentration value" column
is not provided, then none of the data were
duplicates. In these cases, the "Influent daily
value" is provided with the phrase "(aggregated)"
omitted from the column heading. Unless
specified in the example summary, the censoring
is indicated after, the concentration and daily
values (NC=non-censored and ND=non-
detected).
EXAMPLE 1: This is an-example of the ETA-tesfr (section-l:0.4371:)-where the data meet the general
requirement, pass Step 1, but fail Step 2. Because the data pass Step 1, they pass the LTA test. This
example uses the n,n-dimethylformamide data from sampling episode-1987..' The influent sample point
is 07B. The baseline value is 10 ug/L. So, the 'treatable level is any value equal.to or greater than
10*10 ug/L=100 ug/L.
Date Sample was
CoUected
16-M-90
17-M-90
18-M-90
19-Jul-90
20-M-90
Concentration Influent daily value Detected at Detected at
value (aggregated) any level? treatable levels?
(ug/L) (ug/L)
10 (ND)
no data
34.2 (NC) - dup
12.5 (ND)- dup
132.45 (NC)
225.19 (NC)
10 (ND)
no data
23.35 (NC)
132.45 (NC)
225.19(NC)
No
n/a
Yes,
Yes
Yes
• No
n/a
no
Yes
Yes
Basic Requirement is met: 3 of the 4 daily values were detected.
Step 1 passes: 2 of the 4 daily values were detected at treatable levels.
Step 2 fails: The influent long-term average is less than the treatable level of 100 ug/L. (The influent
long-term average is the arithmetic average of the four influent daily values and is equal to 97.75 ug/L
which is less than 100 ug/L.)
LTA Test passes: Data pass one of the steps, Step 1.
EXAMPLE 2: This is an example of the percent removal test (section 10.4.3.2) where the data have
passed the LTA Test. This example uses the n,n-dimethylformamide data from example 1. The
influent sample point is again sample point 07B and the effluent point is sample point 12 (which does
not have any duplicates, so the reported value for each sample is the same as the daily average). All
10-17
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
of the effluent data are non-detected (ND).
Date Sample was Influent daily value Effluent daily value
Collected '(aggregated) (ug/L)
(ug/L)
16-M-90
17-M-90
18-M-90
19-M-90
20-M-90
Averages:
10 (ND)
no data
23.35 (NC)
132.45 (NC)
225.19 (NC)
97.75
10 (ND)
10 (ND)
12.5 (ND)
10 (ND)
10 (ND)
10.5
The percent removal is then:
97.75-105
97.75
-x 100 = 893%
Percent removals test passes: Data pass because the percent removal is greater than zero at 89.3%.
EXAMPLE 3: This is an example of flow-weighting to obtain one of the daily values that was used
in calculating the facility long-term average in Step 2~of the LTA test. As explained in section 10.4.2.3,
this step was necessary when more than one sample point characterized the wastestream of concern.
This example shows the flow-weighted calculations to obtain one of the daily values used to calculate
the facility long-term average (which is calculated as the arithmetic average of the four daily values for
the sampling episode). ..These aluminum data are from the-influent sample points«for-episode-4803v
Of the five influent sample points selected from episode 4803 for the metals data, only sample points
05 and 10 have any data for aluminum on 6/13/96. Batch samples were collected at each of these
sampling points. The batches at each sample point are identified by the characters A, B, C, and D
immediately after the sample point (for example, batches 05B, IOC). All of the values were detected
(non-censored or 'NC').
Sample Point
and Batch
Column
Abbrev.
OSB
05C
totals spOS
10A
10B
IOC
10D
totals splO
Influent daily value
(ug/L)
A
1,910,000
1,180,000
164,000
160,000
169,000
144,000
Flow for
batch
(gal/day)
B
18,000
18,000
36,000
3,850
5,775
3,850
5,775
19,250
Flow
*Influent daily
value
A*B
34380,000,000
21,240,000,000
55,620,000,000
631,400,000
924,000,000
650,650,000
831,600,000
3,037,650,000
• total of flow*influent
daily values/
total flow at sample
jgpint
C=£A*B/IB
1,545,000
157,800
totals for day:
Daily average:
Average Flow at
Sample Point
D=average(B)
18,000
4,813
22,813
total E/total
E=C*D
27,810,000,000
759,412,500
28,569,412,500
0=1,252,358 ug/L
10-18
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
EXAMPLE 4: This is an example where the facility influent long-term averages are different for the
LTA test and the percent removals test. This example uses the data from carbon disulfide at facility
4378 sample point 8 where all of the amounts were detected. As shown below, the influent average
for the LTA test is 1,709 and the influent average for the percent removals test is 1,664:
For the LTA test, the data are:
Date
05/11/1992
05/12/1992
05/13/1992
05/14/1992
05/15/1992
Sample ,
Number
22415
22439
22481-dup
22494-dup
• 22518
22533
Concentration Influent daily value
value (aggregated)
(ug/L) (ug/L)
2,395.75
31-7,64=
2,346.56
1,623.12
1,664.00
2,184.97 '
facility average:
2,395.75
317.64
1,984.84
1,664.00
2,184.97
1,709.44
For the percent removals test, only the data for 5/14/92 is retained as this is the only sampling day-for-
which effluent data is available (see section 10.4.1.3). So, the data for the other days is 'not applicable'
as shown below.
Date
05/11/1992
05/12/1992
05/13/1992
05/14/1992
05/15/1992
Sample
Number
22415
22439
22481-dup
22494-dup
22518
22533
Concentration
value
(ug/L)
NA
NA<
NA
NA
1,664.00
NA
Influent daily value
(aggregated)
(ug/L)
NA
NA
NA
1,664.00
NA
facility average:
1,664.00
DEVELOPMENT OF LONG-TERM AVERAGES 10.5
In order to develop the limitations for the
CWT industry, it was necessary to calculate
long-term averages and variability factors. This
section discusses the calculation of long-term
averages by facility ("facility-specific") and by
option ("pollutant-specific").
For each pollutant of concern (see Chapter
6), EPA calculated long-term averages for each
regulatory option and each subcategory. The
long-term average represents the average
performance level that a facility with well-
designed and operated model technologies is
capable of achieving. These long-term averages
for each option and subcategory are listed in
Table 12-9.
EPA calculated the long-term average for
each pollutant for each facility by arithmetically
averaging the pollutant concentrations. The
pollutant long-term average for an option was the
. median of the long-term averages from selected
facilities with the technology basis for the option.
The following two subsections describe the
estimation of the facility-specific and pollutant-
specific long-term averages. This procedure is
10-19
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
the same as that used for the 1999 proposal.
Estimation of Facility-Specific
Long-Term Averages
10.5.1
The facility-specific long-term average for
each pollutant for each facility is the arithmetic
average of the daily pollutant concentrations of
wastewater from the facility. EPA substituted
the sample-specific detection limit foreach non-
detected measurement.
For example, for facility A, if the
concentration values for hypothetical pollutant X
are:
10 mg/1,
13 mg/1, •
non-detect ("ND") with sample-specific
detection limit = 5 mg/1,
12 mg/1, and
15 mg/1
then the facility-specific long-term average is
calculated using the sample-specific detection
limit of 5 mg/1 for the non-detected
measurement. This facility-specific long-term
average is equal to the average of the five values:
(10 + 13 + 5 + 12 + 15)/5 mg/L = 11 mg/L.
Attachment 10-2 in Appendix D lists the
facility-specific long-term averages for the
regulated pollutants.
Estimation of Pollutant-Specific
Long-Term Averages
10.5.2
The pollutant-specific long-term average was
the median of the facility-specific long-term
averages from the facilities with the model
technologies for the optionl The median is the
midpoint of the values ordered (i.e., ranked)
from smallest to largest. -If there is an odd
number of values (with n=number of values),
then the value of the (n+l)/2 ordered observation
is the median. If there are an even number of
values, then the two values of the n/2 and
[(n/2)+l] ordered observations are arithmetically
averaged to obtain the median value.
For example, for subcategory Y option Z, if
the four (i.e., n=4) facility-specific long-term
averages for pollutant X are:
Facility Long-term average
20 mg/1
9 mg/1
16 mg/1
10 mg/1
A
B
C
D
then the ordered values are:
Facility Long-term average-
B 9 mg/1
D 10 mg/1
C 16 mg/1
A . 20 mg/1
and the pollutant-specific long-term average Jbr,
option Z is the .median of the ordered values
(i.e., the average of the 2nd and 3rd ordered
values):
(10+16)/2 mg/1 = 13 mg/1.
The pollutant-specific long-term averages
were used in developing the limitations for each
pollutant within each regulatory option.
Attachment 10-3 in Appendix D lists the
pollutant-specific long-term averages for the
regulated pollutants.
Baseline Values Substituted for
Long-Term Averages
10,5.3
After calculating the pollutant-specific long-
term averages for the regulatory options, EPA
compared these values to the baseline values
provided in Chapter 15. EPA performed this
comparison in response to comments on the
1995 proposal. These comments stated that it
was not possible to measure to the low levels
required in that proposal. EPA agreed with such
10-20
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
comments and adjusted the pollutant-specific
long-term averages accordingly. If the pollutant-
specific long-term average was less than the
baseline value, EPA substituted the baseline
value for the pollutant-specific long-term
average. Table 10-4 identifies the pollutants
where this situation occurs for the regulated
analytes in the final rule. This situation occurred
only for metals pollutants in the metals
subcategory.
Table 10-4. Metals Subcategory: Long-Term
Averages Replaced by the Baseline Values
Option Pollutant
Baseline Pollutant-
Value specific
(mg/L) Long-Term
Average
(mg/L)
3
4
silver
tin
titanium^ .
• vanadium •
vanadium
10
30 ~
5
50
50
4.5 '
28.25
3:5---.
11.0
11.9
DEVELOPMENT OF VARIABILITY FACTORS W.6
In developing the variability factors used in
calculating the limitations, EPA first developed
facility-specific variability factors using the
modified delta-lognormal distribution. Second,
EPA used these facility-specific variability
factors to develop the pollutant-specific
variability factors. Third, EPA used these
pollutant-specific variability factors to develop
the group-level variability factors (Appendix A
identifies the assignment of pollutants to groups).
Fourth, EPA used the group-level variability
factors to develop organic variability factors for
some pollutants in the oils and organics
subcategories.
In the 1999 proposal, EPA generally used
the group-level variability factors to calculate the
proposed limitations. EPA requested comment
on whether the pollutant-specific variability
factors or the group-level variability factors were
more appropriate for calculating the limitations.
EPA received several comments that stated the
pollutant-specific variability factors were more
appropriate as estimates for the corresponding
pollutants. In calculating the limitations for the
final rule, EPA has used the pollutant-specific
"i
variability factors wherever possible. EPA even
relaxed its criteria for calculating facility-specific
variability factors to obtain more pollutant- '
specific variability factors. For the remaining
pollutants where pollutant-specific variability
factors could not be calculated, EPA used either
the group-level-variability factor or the organics-.
variability factors.
The following sections describe the modified
delta-lognormal distribution and the estimation of
the facility-specific,. pollutant-specific, group-
level, and organics variability factors. Except as
noted, EPA has used the same statistical-
methodology as in the 1999 proposal; -however,
EPA has provided a different explanation which
simplifies the computations.
Basic Overview of the Modified
Delta-Lognormal Distribution
10.6.1
EPA selected the modified delta-lognormal
distribution to model pollutant effluent
concentrations from the CWT industry in
developing the variability factors. In this
industry, wastewater is generated from treating
wastes from different sources and industrial
processes. A typical effluent data set from a
facility in this industry consists of a mixture of
measured (detected) and non-detected values.
Within a data set, gaps between the values of
detected measurements and the sample-specific
detection limits associated with non-detected
measurements may indicate that different
pollutants were present in the different industrial
wastes treated by a facility. Non-detected
measurements may indicate that the pollutant is
not generated by a particular source or industrial
process. The modified delta-lognormal
10-21
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
distribution is appropriate for such data sets
because it models the data as a 'mixture of
measurements that follow a lognormal
distribution and non-detect measurements that
occur with a certain probability. The model also
allows for the possibility that non-detect
measurements occur at multiple sample-specific
detection limits. Because the data appeared to fit
the modified delta-lognormal model reasonably
well, EPA believes that this model is the most
appropriate model of those evaluated for the
CWT industry data.
The modified delta-lognormal distribution is
a modification of the 'delta distribution' originally
developed by Aitchison and Brown.13 While this
distribution was originally developed to model
economic data, other researchers have shown the
application to environmental data.— The
resulting mixed distributional model, that
combines a continuous density portion with a
discrete-valued spike at zero, is also known as
the delta-lognormal distribution. The delta in the
name refers to the proportion of the_.oyerall
distribution contained in the discrete
distributional spike at zero, that is, the proportion
of zero amounts. The remaining non-zero, non-
censored (NC) amounts are grouped together
and fit to a lognormal distribution.
EPA modified this delta-lognormal
distribution to incorporate multiple detection
limits. In the modification of the delta portion,
the single spike located at zero is replaced by a
discrete distribution made up of multiple spikes.
Each spike in this modification is associated with
a distinct sample-specific detection limit
"Aitchison, J. and Brown, J.A.C. (1963)
The Lognormal Distribution. Cambridge
University Press, pages 87-99.
'"Owen, WJ. and T.A. DeRouen. 1980.
"Estimation of the Mean for Lognormal Data
Containing Zeroes and Left-Censored Values,
with Applications to the Measurement of Worker
Exposure to Air Contaminants." Biometrics,
'36:707-719.
associated with non-detected (ND)
measurements in the database.15 A lognormal
density is used to represent the set of measured
values. This modification of the delta-lognormal
distribution is illustrated in Figure 10-1.
The following two subsections describe the
delta and lognormal portions of the modified
delta-lognormal distribution in further detail.
1 Previously, EPA had modified the
delta-lognormal model to account for non-
detected measurements by placing the
distributional "spike" at a single positive value,
usually equal to the nominal method detection
limit, rather than at zero. For further details, see
Kahn and Rubin, 1989. This adaptation was used
in developing limitations and standards for the
organic chemicals, plastics, and synthetic fibers
(OCPSF) and pesticides manufacturing
rulemakings. EPA has used the current
modification in several, more recent,
rulemakings.
10-22
-------
Chapter 10 Data Conventions & Calculations of Limitations Development DocumentJor^heC^TPoaifSourceCatego>y_
Figure 10-1
Modified Delta -Lognormal Distribution
Censoring Type
IMC
ND
10-23
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Continuous and Discrete Portions of the Modified Delta-Lognormal Distribution
10.6.2
The discrete portion of the modified delta-lognormal distribution models the non-detected values
corresponding to the k reported sample-specific detection limits. In the model, 8 represents the
proportion of non-detected values and is the sum of smaller fractions, 8i; each representing the
proportion of non-detected values associated with each distinct detection limit value. By letting D ; equal
the value of the fh smallest distinct detection limit in the data set and the random variable XD represents
a randomly chosen non-detected measurement, the cumulative distribution function of the discrete
portion of the modified delta-lognormal model can be mathematically expressed as: '
5.
0
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Multiple detection limits for non-detect measurements are incorporated, as are measured ("detected")
values. The same basic framework can be used even if there are no non-detected values in the data
set (in this case, it is the same as the lognormal distribution). Thus, the modified delta-lognormal
distribution offers a large degree of flexibility in modeling effluent data.
The modified delta-lognormal random variable U can be expressed as a combination of three other
independent variables, that is,
. .(7)
where XD represents a random non-detect from the discrete portion of the distribution, Xc represents
a random detected measurement from the continuous lognormal portion, and Iu is an indicator variable
signaling whether any particular random measurement, u, is non-detected or non-censored (that is, Iu=l
if u is non-detected; ^=0 if u is non-censored). Using a weighted sum, the cumulative distribution
function from the discrete portion of the distribution (equation 1) can be combined with the function
from the continuous portion (equation 4) to obtain the overall cumulative probability distribution of the
modified delta-lognormal distribution as follows,
(8)
wherev-Dj-is the'value-of the-i* sample-specific detection limit. —... •
The expected value of the .random variable U can be derived as a weighted sum of the expected
values of the discrete and continuous portions of the distribution (equations 2 and 5,- respectively) as
follows - - - -
In a similar manner, the expected value of the random variable squared can be written as a
weighted 'sum of the expected values of the squares of the discrete and continuous portions of the
distribution as follows
(10)
Although written in terms of U, the following relationship holds for all random variables, U, XD, and
(U)
So using equation 11 to solve for Var(U), and applying the relationships in equations 9 and 10, the
variance of U can be obtained as
(12)
Estimation Under the Modified Delta-Lognormal Distribution
10.6.4
In order to use the modified delta-lognormal model to calculate limitations, the parameters of the
distribution are estimated from the data. These estimates are then used to calculate the limitations.
The parameters <5, and 5 are estimated from the data using the following formulas:
10-25
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
7=1
(13)
n
where nd is the number of non-detected measurements, dj,j = 1 to nd, are the detection limits for the
non-detected measurements, n is the number of measurements (both detected and non-detected) and
!(...) is an indicator function equal to one if the phrase within the parentheses is true and zero
otherwise. The "hat" over the parameters indicates that they are estimated from the data.
The expected value and the variance of the lognormal portion of the modified delta-lognoimal
distribution can be calculated from the data as:
.(14)
(15)
The parameters of the continuous portion of the modified delta-logriormal distribution,^ and a, are
estimated by •
nc
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Var(U) =
(20)
The next section applies the modified delta-lognormal distribution to the data for estimating facility-
specific variability factors for the CWT industry. Equations 17 through 20 are particularly important
in the estimation of -facility-specific variability factors described in the next section.
Estimation of Facility-Specific Variability Factors
10.6.5
This section applies the methodology described in the previous section to the estimation of facility-
specific variability factors for each pollutant. For each facility, EPA estimated the daily variability
factors by fitting a modified delta-lognormal distribution to the daily, measurements for each pollutant.
In contrast, EPA estimated monthly variability factors by fitting a modified delta-lognormal distribution
to the monthly averages for the pollutant at the facility. EPA developed these averages using the same
number of measurements as the assumed monitoring frequency for the pollutant. EPA is assuming that
some pollutants such as organics will be monitored weekly (approximately four times a month) and
others will be monitored daily (approximately 20 times a month).16 Chapter 11 identifies theseassumed
monitoring frequencies. The following sections describe the facility data set requirements EPA used
in estimating variability factors, and its estimation of facility-specific daily and monthly variability
factors used in developing the limitations. These facility-specific variability factors are listed in
Attachment 10-2-in Appendix D.
Facility Data Set Requirements
10.6.5.1
Estimates of the necessary parameters for the lognormal portion of the distribution can be
calculated with as few as two distinct detected values in a data set (in order to calculate the variance
of the modified delta-lognormal distribution, two distinct detected values are the minimum number that
can be used and still obtain an estimate of the variance for the distribution).
EPA used the facility data set for a pollutant if the data set contained three or more observations
with two or more distinct detected concentration values. This requirement was slightly less stringent
than the requirement in the 1999 proposal. EPA relaxed the requirement in order to calculate a few
additional pollutant-specific variability factors which was the preference stated in comments to the 1999
proposal. If EPA had not relaxed this requirement, it would have had to use more group-level
variability factors instead of pollutant-specific variability factors in developing the limitations for the
final rule. . . '
Further, as in the 1999 proposal, each facility data set for a pollutant had to pass the data editing
criteria described in section 10.4.3.
In statistical terms, each measurement was assumed to be independently and identically distributed
from the other measurements of that pollutant in the facility data set.
1 Compliance with the monthly average limitations will be required in the final rulemaking regardless of
the number of samples analyzed and averaged.
10-27
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Estimation of Facility-Specific Daily Variability Factors .
10.6.5.2
The facility-specific daily variability factor is a function of the expected value, and the 99th
percentile of the modified delta-lognormal distribution fit to the daily concentration values of the
pollutant in the wastewater from the facility. The expected value, was estimated using equation 19.
The 99th percentile of the modified delta-lognormal distribution fit to each data set was estimated
by using an iterative approach. First, the pollutant-specific detection limits were ordered from smallest
to largest Next, the cumulative distribution function, p, for each detection limit was computed.. The
general form, for a given value c, was:
8
t+(l-6)
*>
ln(c)-/2
(21)
where is the standard normal cumulative distribution function. Next, the interval containing the 99th
percentile was identified: Finally, the 99* percentile-of the modified delta-lognormal distribution was
calculated. The following steps were completed to compute the estimated 99th percentile of each data
subset:
Step 1 Using equation-21^ k-values of p-at-c=Da, m=l-,...,k were computed and labeled pm.
Step 2 The smallest value of m (m=l,...,k)', such that pm > 0.99, was determined,andJabeled,as,pj.,,
If no such m existed, steps 3 and 4 were skipped and step 5 was computed instead.
Step 3 Computed p* = p,- - 5j.
Step 4 If p*< 0.99, then
else if p*_> 0.99, then
P99 = exp
z=l
1-8
(22)
where <£>"' is the inverse normal distribution function.
Step 5 If no such m exists such that pm > 0.99 (m=l,...,k), then
= exp
-i
0.99-5
1-5
The facility-specific daily variability factor, VF1, was then calculated as:
P99
VFl = -
E(U)
(23)
(24)
10-28
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Estimation of Facility-Specific Monthly Variability Factors
10.6.5.3
EPA estimated the monthly variability factors by fitting a modified delta-lognormal distribution to
the monthly averages. EPA developed these averages using the same number of measurements as the
assumed monitoring frequency for the pollutant. EPA is assuming that some pollutants such as organics
will be monitored weekly (approximately four times a month) and others will be monitored daily
(approximately 20 times a month). Chapter 11 identifies these assumed monitoring frequencies.
ESTIMATION OF FACILITY-SPECIFIC 4-DAY VARIABILITY FACTORS
Variability factors based on 4-day monthly averages were estimated for pollutants with the
monitoring frequency assumed to be weekly (approximately four-times a.month)...In order to calculate...
the 4-day variability-factors (VF4)r the assumption-was-made that the approximating disrribution.of
C/4, the sample mean for a random sample of four independent concentrations, was also derived from :
the modified delta-lognormal distribution.17-18 To obtain the expected value of the 4-day averages,
equation 19 is modified for the mean of the distribution of 4-day averages in equation 25:
E(U4) = S4E(x4)D+(\-S4}E(x4)(
(25)
where
A denotes-the-meari-of-the-discrete-pprtion of the distribution of the average of four
independent concentrations, (i.e., when all observations are non-detected values) and (^J^, denotes
the mean of the continuous lognormal portion (i.e., when any observations are detected).
First, it was assumed that the probability of detection (8) on each of the four days was independent
•of the measurements on the other three days (as explained hi section 10.6.5.1, daily measurements
were also assumed to be independent) and therefore, 84 = S4. Because the measurements are assumed
to be independent, the following relationships hold:
(26)
Var
I7This assumption appeared to be reasonable for the pulp and paper industry data that had percentages of •
non-detected and detected measurements similar to the data sets for the CWT industry. This conclusion was based
on the results of a simulation of 7,000 4-day averages. A description of this simulation and the results are
provided in the record for the proposed rulemaking. -
18As described in section 10.4, when non-detected measurements are aggregated with non-censored
measurements, EPA determined that the result should be considered non-censored.
10-29
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWTPoint Source Category
Substituting into equation 25 and solving for the expected value of the continuous portion of the
distribution gives:
(27)
Using the relationship in equation 19 for the averages of 4 daily measurements and substituting terms
from equation 26 and solving for the variance of the continuous portion of U4 gives:
(28)
Using equations 17 and 18 and solving for the parameters of the lognormal distribution describing the
distribution of
gives:
04 =ln
Var(.
X
and
(29)
In finding the estimated 95th percentile of the average of four observations, four non-detects, not
all at the same sample-specific detection limit, can generate an average that is not necessarily equal to
D,, D2,..., or Dk. Consequently, more than k discrete points exist in the distribution of the 4-day
averages. For example, the average of four non-detects at k=2 detection limits, are at the following
discrete points with the associated probabilities:
1
2
3
4
5
45?82
(2D1+2£>2)/4 68 {
When all four observations are non-detected values, and when k distinct non-detected values exist,
10-30
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Documentfor the CWT Point Source Category
the multinomial distribution can be used to determine associated probabilities. That is,
Pr
«* A
4
4!
(30)
where Uj is the number of non-detected measurements in the data set with the D; detection limit. The
number of possible discrete points, k*, for k=l,2,3,4, and 5 are as follows:
k kl •
11
2 5 --, —
3 ' 15
" • ' 4 35
5 70 . •
• To find the estimated 95th percentile of the distribution of the average of four observations, the
same basic steps (described in section 10;6-.5.2)-as-for the- 99- percentile of me distribution of daily
observations, were used with the following changes:
Step 1 Change P99 to P95, and 0.99 to 0.95.
Step 2 "Change D^ to D^j*7 the weighted'averages of the sample-specific detection limits.-
Step3 Change-Sjto.6^ '
Step 4 Change k to k*, the number of possible discrete points based on k detection limits. _,
Step 5 Change the estimates of 6, /£ ,and <7 to estimates of S4, fi.^ and (J^ respectively.
Then, using El U4 j = E(Uj, the estimate of the facility-specific 4-day variability factor, VF4, was
calculated as: .
* (31)
E(U)
AUTOCORRELATION IN THE DAILY MEASUREMENTS
Before estimating the facility-specific 20-day variability factors, EPA considered whether
autocorrelation was likely to be present in the effluent data. When data are said to be positively
autocorrelated, it means that measurements taken at consecutive time periods are related. For example,
positive autocorrelation would be present in the data if the final effluent concentration of oil and grease
was relatively high one day and was likely to remain at similar high values the next and possibly
succeeding days. Because EPA is assuming that some pollutants (BOD5, TSS, oil and grease, metals
(in the metals subcategory), and total cyanide) will be monitored daily, EPA based the 20-day variability
10-31
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
factors on the distribution of the averages of 20 measurements.19 If concentrations measured on
consecutive days were positively correlated, then the autocorrelation would have had an effect on the
estimate of the variance of the monthly average and thus on the 20-day variability factor. (The
estimate of the long-term average and the daily variability factor are generally only slightly affected by
autocorrelation.) • .
In EPA's view, autocorrelation in any significant amount is unlikely to be present in daily
measurements in wastewater from this industry. Thus, EPA has not incorporated autocorrelation into
its estimates of the 20-day variability factors. In many industries, measurements in final effluent are
likely to be similar from one day to the next because of the consistency from day-to-day in the
production processes and in final effluent discharges due to the hydraulic retention tim&of wastewater.
in basins, holding ponds, and other components of wastewater treatment systems. Unlike these other
industries, where the industrial processes are expected to produce the same type of wastewater-from
one day to the next, the wastewater from CWT industry is generated by treating wastes from different
sources and industrial processes. The wastes treated on a given day will often be "different than the
waste treated on the-following day; Because of this,- autocorrelation-would-be expected-to be absent
from measurements of wastewater from the CWT industry. ," —
EPA concluded that a statistical evaluation of appropriate data sets would likely support its assertion
that autocorrelation is absent from daily measurements in the CWT industry. However, the monitoring
data that EPA received"in response tbats" multiple requests were, insufficient for,the purpose of
evaluating the autocorrelation.— To^determine autocorrelation urthe= data™ many measurements for
each pollutant would be'required-'with values for every single day over an extended period-of time.
ESTIMATION OF FACILITY-SPECIFIC 20-DAY VARIABILITY FACTORS
Based upon the discussion on autocorrelation in the previous section, it was assumed that
consecutive daily measurements were independent of one another, and therefore
E(U2Q)=E(U) and
20
(32)
where E(U) and Var(U} were calculated as shown in section 10.6.4 (see equations 19 and 20).
Finally, since U20 is approximately normally distributed by the Central Limit Theorem, the estimate of
the 95th percentile of a 20-day mean and the corresponding facility-specific 20-day variability factor
(VF20) were approximated by
P9520 =
(33)
"in other rulemakings, EPA has used the averages of 30 measurements when the assumed monitoring
frequency was daily measurements throughout the month. However, many CWT facilities are closed on weekends.
Therefore, EPA assumed that 20 daily measurements rather than 30 would be collected each month.
20In the 1995 statistical support document, EPA included a discussion of the autocorrelation in the
effluent data from facility 602. The document states that the facility provided 'sufficient amounts of pollutant
measurements.' That statement is not correct. To have sufficient amounts of data, the data set would need to
include many more measurements for every single day. In addition, in the 1995 document, the conclusions about
statistical significance were flawed due to an error in the software.
10-32
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
By using the substitutions in equation 32, equation 33 simplified to
P9520=%) + [0-1 (0.95)|^
(34)
Then, the estimate of the facility-specific 20-day variability factor, VF20, was calculated using:
**•
VF2Q=— because E(U20)=E(U) (35)
where $"'(0.95) is the 95th percentile of the inverse normal distribution.
Evaluation of Facility-Specific
Variability Factors
10.6.5.4
Estimates of the necessary parameters for
the lognormal portion of the distribution can be
calculated~with as few as two distihct measured
values in a data set (in order to calculate the
variance); However, these estimates can-be-
unstable (as can estimates from larger data sets).
As stated in section 10.6.5.1, EPA used the
modified delta-lognormal distribution to develop
facility-specific variability factors for data sets
that had a three or more observations with two
or more distinct measured concentration values.
Some variance estimates produced
unexpected results such as a daily variability
factor with a value less than 1.0 which would
result in a limitation with a value less than the
long-term average. This was an indication that
the estimate of <7 (the log standard deviation)
was unstable. To identify situations producing
unexpected results, EPA reviewed all of the
variability factors and compared daily to monthly
variability factors. EPA determined that when
the faculty's daily variability factor was less than
1.0, the daily and monthly variability factors for
that pollutant at that facility should be excluded
from further consideration. In developing the
limitations for the final rule, EPA found that this
situation no longer existed. Thus, none of the
facility-specific variability factors were excluded
for this reason.
Similarly, when the facility's monthly
variability factors for a pollutant were greater
than the daily variability factor, EPA's intention
was to exclude the daily and monthly variability
factors from further consideration. This was the
case for the cadmium and. acenaphthene data
from facility 4814B in oils options 8 and 9.
If the daily variability factor was greater than
10.5, EPAreviewed the da'ta to determine if one
or more values were the result of process upsets
or data errors. With the exception of nickel from
facility 651 (see section 10.4.1.2)rEPA did not
find any reason to exclude the data and has
retained all such variability factors.
EPA also excluded the facility-specific
variability factors for 2,4,6-trichlorophenol from
facility 1987 in option 4 of the organics
subcategory. The facility data set had three non-
detected values, all with sample-specific sample-
specific detection limits greater than the detected
values. For this reason, EPA determined that it
was not appropriate to model this data set using
the, modified delta-lognormal distribution.
In all other cases, EPA used the calculated
facility-specific variability factors in calculating
the pollutant-specific variability factors.
Attachment 10-2 in Appendix D lists the
facility-specific variability factors.
Estimation of Pollutant-Specific
Variability Factors
10.6.6
After the facility-specific variability factors
were estimated for a pollutant as described in
section 10.6.5, the pollutant-specific daily
variability factor was calculated as the mean of
10-33
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
the facility-specific daily variability factors for
that pollutant in the subcategory and option.
Likewise, the pollutant-specific monthly
variability factor was the mean of the facility-
specific monthly variability factors for that
pollutant in the subcategory and option. For
example, for oils option 8, the cobalt daily
variability factor was the mean of the cobalt daily
variability factors from facilities 4814A and
facility 4814B. A more detailed example of
estimating pollutanfespecific. monthly variability
factors is provided in section 10.7.2. Attachment
10-3 in Appendix D lists the-pollutanf-specific
variability factors.
In the 1999 proposal, EPA requested
comments on whether EPA should use pollutant-
specific variability factors or group-level
variability factors in calculatmgJhe.limitations.
The comments recommended" using the
pollutant-specific variability factors and this is
what EPA has used whenever possible hi
developing the limitations and standards for the
final rule. The next section discusses the cases
where EPA was unable to calculate the pollutant-
specific variability factors and used the group
variability factors or the organics variability
factors.
Cases when Pollutant-Specific
Variability Factors Could Not Be
Calculated
10.6.7
Afterthe pollutant-specific variability factors
were estimated as described in section 10.6.6,
EPA identified several pollutants for which
variability, factors could not be calculated due to
the data restrictions that requiring a minimum of
three observations with a minimum of two
distinct detected values (that could be used to
calculate the variance). For example, if a
pollutant had all non-detected values in the
effluent, then it was not possible to calculate
pollutant-specific variability factors. Table 10-5
lists the pollutants for which EPA was unable to
calculate pollutant-specific variability factors.
Of these pollutants identified in Table 10-5,
EPA was able to calculate group variability
factors for pollutants in the metals, phenols,
phthalate, and chlorophenols groups. For the
remaining cases, EPA calculated organics
variability factors. The following two sections
describe the group-level variability factors and
the organics variability factors.
10-34
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Table 10-5. Cases where Pollutant Variability Factors Could Not be Calculated
Subcategory Option Pollutant
Metals 3
4
8-.-
Oils
9
Organics 4
Antimony
Mercury
Silver
Tin
Titanium
Vanadium
Tin
Bis(2-ethylhexyl) phthalate
Carbazole
Tin
Butylbenzyl phthalate
Bis(2-ethylhexyl) phthalate
Carbazole
Acetophenone
Aniline
2,3-dichloroaniline
p-cresol'
-274,6-Trichlorophenol
Variability Factors Used Source of variability
Daily
5.208
3.185
4.350
2.329
2.310
2.586
3.128
3.414
3.948
3.175
10:228
1.811
Monthly
1.469
1.225
1.323
1.369
1.367
1.536
1.538
1.614
- 1.820
1.566
3.009
1.242
lactors
Semi-metals group
Metals group
Metals group
Metals group
Phthalates group
Organics VFs
Metals group:
Phthalates group
Organics VFs
Organics VEs-
Phenols group
Chlorophenols group
Group-Level Variability Factors
10.6.7.1
Appendix-A identifies the pollutant groups
for all pollutants of concern except conventional
and classical pollutants. EPA assigned the
pollutants to groups containing pollutants that
had similar chemical structure (e.g., the metals
group consisted of metal pollutants).
There are two types of designations assigned
to the pollutants within each group. Some
pollutants were only used to estimate the current
loadings for Chapter 12. The remaining
pollutants were used for both the current
loadings and in calculating facility-specific
variability factors. Each type is identified with
different designations 'Load' and 'VF & Load'
in Appendix A. Although many pollutants are
identified as appropriate for calculating group
variability factors, EPA did not use group
variability factors from all groups. Attachment
10-4 in Appendix D identifies the groups and
interim calculations for the group variability
factors that EPA used for the final regulations.
For those pollutants for which EPA used
group variability factors, EPA concluded that the
variability of the pollutants in each group would
be- similar-because the chemrcal'~structure~of-
these pollutants is similar therefore the treatment
system would perform similarly. Thus, EPA
concluded that using group variability factors for
a particular pollutant is appropriate when the
pollutant-specific variability factors could not be
calculated for an option in a subcategory.
The group-level daily variability factor was
the median of the pollutant-specific daily
variability factors for the pollutants within the
group. Similarly for the monthly variability
factors, the group-level monthly variability factor
was the median of the pollutant-specific monthly
variability factors for the pollutants within the
group. These values are listed in Table 10-5.
Organics Variability Factors
10.6.7.2
For carbazole in the oils subcategory and
three organic pollutants (acetophenone, aniline,
and 2,3-dichloroaniline) in the organics
subcategory, each pollutant's structural group
10-35
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
either had only one pollutant of concern assigned
to it or only one pollutant of concern in the group
passed the data editing criteria (section 10.4.3).
Even when a pollutant in the group passed the
data editing criteria, the data restrictions (i.e.,
three or more observations with two or more
distinct detected values) meant that neither
pollutant-specific nor group-level variability
factors could be calculated for these pollutants.
Instead, EPA developed organics variability
factors using the group variability factors that
could be calculated for the following groups of
organic pollutants: aliphatic alcohols, amides,
aliphatic amines, anilines, chloroanilines,
chlorophenols, aromatic ketones, n-paraffins,
polyaromatic hydrocarbons (PAHs), phenols;
phthalates, polyglycol monoethers, pyridines, and
aromatic sulfides. EPA used these groups
because they largely represent the. non-volatile^
pollutants considered for regulation in the final
rule. EPA excluded the volatile pollutant groups
because their removals* are largely due to
volatilization rather than treatment.
The organics daily variability factor was the
median of the group-level daily variability factors
for the selected groups. Similarly for the
monthly variability factors, the organics monthly
variability factor was the median of the group-
level monthly variability factors for the selected
groups. These values are provided in Table
10-5. Attachment 10-4 in Appendix D identifies
the groups and interim calculations for the
organics variability factors.
In the 1999 proposal for those cases without
pollutant-specific and group-level variability
factors, EPA transferred variability factors using
other group-level variability factors in the option
for the subcategory. EPA calculated the
transferred variability factors as the median of
the group-level variability factors from all groups
except the metals, semi-metals, and non-metals
groups. This included conventional and classical
pollutants, each of which was considered as a
separate group in the 1999 proposal (but are
excluded from all groups in the final rule). In the
1995 proposal, EPA proposed using fraction-
level variability factors when group-level
variability factors were unavailable. Rather than
these two alternatives, EPAhas determined that
its organics variability factors are more
appropriate for the organic pollutants and has
used them in calculating the limitations in the
final rule.
LIMITATIONS
10.7
The limitations and standards are the result
of multiplying the long-term averages by the
appropriate variability factors. The same basic
procedures apply to the calculation of all
limitations "and" standards for this industry,_
regardless-of whether the technology is BPT,
BCT,,BAT, JSTSPS, PSES or PSNS.
The limitations for pollutants for each option
are,.... provided" as 'daily maximums' and
'maximums for monthly averages.' Definitions
provided in 40 CFR 122.2 state that the daily-
maximum limitation is the "highest allowable
'daily discharge'" and the maximum for monthly
average limitation (also referred to as the
"monthly average limitation") is the "highest
allowable.average of 'daily discharges' over a
calendar month, calculated as the sum of all
'daily discharges' measured during a calendar
month divided by the number of 'daily
discharges' measured during that month." Daily
discharges are defined to be the '"discharge of a
pollutant' measured during a calendar day or any
24-hour period that reasonably represents the
calendar day for purposes of samplings."
EPA calculates the limitations based upon
percentiles chosen with the intention, on one
hand, to be high enough to accommodate
reasonably anticipated variability within control
of the facility and, on the other hand, to be low
enough to reflect a level of performaDce
consistent with the Clean Water Act requirement
that these effluent limitations be based on the
"best" technologies. The daily maximum
limitation is an estimate of the 99th percentile of
the distribution of the daily measurements. The
10-36
-------
Chapter 10 Data Conventions & Calculations of Limitations
•Development Document for the CWT Point Source Category
monthly average limitation is an estimate of the
95th percentile of the distribution of the monthly
averages of the daily measurements.
In establishing daily maximum limitations,
EPA's objective is to restrict the discharges on a
• daily basis at a level that is achievable for a
facility that targets its treatment at the long-term
average. EPA acknowledges that variability
around the long-term average results from
normal operations. This variability means that
occasionally facilities may discharge at a level
that is greater than the long-term average. This .
variability also means that facilities may
occasionally discharge at a level that is
considerably lower than the long-term average.
To allow for these possibly higher daily
discharges, EPA has established the daily
maximum limitation.- A facility that discharges
consistently at a level near the daily maximum
limitation wouldnot be operating its treatment to
achieve the long-term, average which is part of-
EPA's objective in establishing . the daily
maximum limitations.
In establishing monthly average limitations,
EPA's objective is to provide an additional
restriction that supports EPA's objective of
having facilities target their average discharges to
achieve the" long-term average. The monthly
average limitation requires continuous
dischargers to provide on-going control, on a
monthly basis, that complements controls
imposed by the daily maximum limitation. In
order to meet the monthly average limitation, a
facility must counterbalance a value near the
daily maximum limitation with one or more
values well below the daily maximum limitation.
To achieve compliance, these values must result
in a monthly average value at or below the
monthly average limitation.
In the first of two steps in estimating both
types of limitations, EPA determines an average
performance level (the "long-term average"
discussed in section 10.7) that a facility with
Well-designed and operated model technologies
(which reflect the appropriate level of control) is
capable of achieving. This long-term average is
calculated from the data from the facilities using
the model technologies for the option. EPA
expects that all facilities subject to the limitations
will design and operate their treatment systems to
achieve the long-term average performance level
on a consistent basis because facilities with well-
designed and operated model technologies have
demonstrated that this can be done.
In the second step of developing a limitation,
EPA determines an allowance for the variation in"
pollutant concentrations when processed through
extensive and well designed treatment systems.
This allowance for variance incorporates all
components of variability including shipping,
sampling, storage, and analytical variability. This
allowance is incorporated into the limitations
through the use of the variability factors-
(discussed in section 10.6) which are calculated
from the data from the facilities using the model
technologies. If a facility operates its treatment^
systemuto:meet;the relevant long-term average,;
EP A expectsjhe, facility, to-be able to meet the_
limitations. Variability factors assure that normal -
fluctuations in a facility's treatment are
accounted for in the limitations. By accounting
for these reasonable excursions above the long-
term average, EPA's use of variability factors
results in limitations that are generally well above
the actual long-term averages.
The limitations are listed in Attachment 10-5
in Appendix D.
Steps Used to Derive Limitations
10.7.1
This section summarizes the steps used to
derive the limitations. These steps were used
separately for the daily maximum limitation and
the monthly average limitation. Depending on
the assumed monitoring frequency (see chapter
11) of the pollutant, either the 4-day variability
factor or the 20-day variability factor was used in
deriving the monthly average limitation.
For each regulated analyte in the option for
a subcategory, EPA performed the following
10-37
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
steps in calculating the limitations:
Step 1 EPA calculated the facility-specific long-
term averages and variability factors for
all facilities that had the model
technology for the option in the
subcategory. EPA calculated facility-
specific variability factors when the
facility had three or more observations
with two or more distinct detected
values (required to calculate the
variance). In addition, the facility data
set for the pollutant had to meet the data
editing criteria.
Step 2 EPA calculated the median of the
facility-specific long-term averages as
the pollutant long-term average.
Step 3 EPA calculated the mean of the facility-
specific variability factors from the
facilities with the model technology to
provide the pollutant-specific variability
factors for each pollutant
Step 4 For the regulated pollutants for which
Steps 1 and 3 failed to provide
variability factors for thatpollutant, EPA
calculated the group-level variability
factor using the median of the pollutant-
specific variability factors for the
pollutants within each group.
Step 5 For the organic pollutants for which
Steps 1, 3, and 4 failed to provide any
variability factors, EPA calculated the
organics variability factors as the median
of selected groups of organic pollutants.
Step 6 In most cases, EPA calculated the
limitation for a pollutant using the
product of the pollutant-specific long-
term average and the pollutant-specific
variability factor. If the pollutant-
specific variability factor could not be
estimated (because none of the facility-
specific variability factors could be
estimated), then EPA used the group-
level variability factor or the organics
variability factor;
10-38
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Example
10.7.2
This example illustrates the derivation of limitations using the steps described
above. In this example, four pollutants, A, B, C, and D all belong to hypothetical
group X. The facility-specific long-term averages and variability factors for the
pollutants are shown in Attachments 10-1 and 10-3, respectively (step 1). Table 10-6
shows the pollutant-specific long-term averages and variability factors calculated as
described in step 2. Then, using the procedure in step 3, the group-level variability
factor (see attachment 10-4 in Appendix D) is the median of the variability factors for
pollutants A, B, and C (D is excluded because facility-specific variability factors could
not be calculated for any of the facilities that provided data on pollutant D). -
• The group-level daily variability factor for group X is 2.2 which is the median of
2.2 (pollutant A), 2.4 (pollutant B), and 2.1(pollutant C).
"'• ' The group-level 4-day variability factor for group X is J .4 which is the median of
1.5 (pollutant A), 1.4 (pollutant B), and 1.2 (pollutant C).
In this example, the limitations are calculated using the pollutant-specific long-term
averages, pollutant-specific variability factors, and the group-level variability factors-
in the following way:
Daily maximum limitation for pollutants A, B, and C
= pollutant-specific long-term average * pollutant-specific daily variability factor
For.pollutants A, B, and C, the daiiyjnaximum limitations are:
Pollutant A: 15 mg/1 * 2.2 = 331 mg/L "'
Pollutant B: 14 mg/1 * 2.4 = 33.6 mg/L
Pollutant C:: 22 mg/1 * 2.1 =46.2 mg/L
Daily maximum limitation for pollutant D
= pollutant-specific long-term average * group-level daily variability factor
= 20 mg/1 * 2.2 = 44 mg/L
Monthly average limitation for pollutants A, B, and C
= pollutant-specific long-term average * pollutant-specific 4-day variability factor
Pollutant A: 15 mg/1 * 1.5 = 22.5 mg/L
Pollutant B: 14 mg/1 * 1.4 = 20 mg/L
Pollutant C: 22 mg/1 * 1.2 = 26.4 mg/L
Monthly average limitation for. pollutant D
= pollutant-specific long-term average * group-level 4-day variability factor .
= 20 mg/1 * 1.4 = 28 mg/L
10-39
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Table 10-6. Long-Teim Averages and Variability Factors Corresponding to Example for Hypothetical
Group X
Pollutant Facility
Long-term Daily Variability 4-day Variability
Average (mg/1) Factor Factor
A
B
G
D
Al
A2
A3
A4
A5
Pollutant-
specific
Bl
B2
B3
B4
Pollutant-
specific
Cl
C2 .
C3
Pollutant-
specific
Dl
D2
D3
Pollutant- "'
specific
10
12
15
20
26
15
(median)
17 '
.16
10
12
14
(median)- -
22
24
12
22
(median)--
20
22
14 ._
'20
(median)
2.1
2.3
2.0
1.8
2.8
2.2
(mean)
2.7
2.2
2.3
*
2.4
(mean)
-1.9
*-
2.3
2.1
(mean)
*
*
*
*
1.4
1.5
1.4
1.3 •
1.9 ,
1.5
(mean)
1.7
1.2
1.3
*
1.4
(mean)
1,1--- __..
*-.
1.3-
1.2
(mean)"
*
*
*
*
could not be estimated (i.e., the data set did not contain three or more observations with
two or more distinct detected values.)
TRANSFERS OF LIMITATIONS
10.8
In some cases, EPA was either unable to
calculate a limitation using the available data for
an option or determined that the treatment
provided by facilities employing the option did
not represent the appropriate level of treatment
for the model technologies. In these cases, EPA
transferred limitations from another option or
from another industrial category. The following
sections describe each case where the limitations,
were transferred.
Transfer of Oil and Grease Limitation
for Metals Subcategory from Option 4
to Option 3 10.8.1
Because of the relatively low levels of oil
and grease in the influent of the facilities with the
model technology for metals option 3, application
of the data editing criteria (described in section
10.4.3.1) resulted in excluding the oil and grease
effluent data from all facilities for this option.
Because the data for option 4 pass the data
editing criteria, this indicates that oil and grease
is present in the types of influent wastes in lids
subcategory. Thus, EPA determined that this
parameter should be regulated for both options in
this subcategory.
EPA based the oil and grease limitations for
10-40
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Documentfor the CWTPoint Source Category
option 3 upon data from the option 4 model
technology. In effect, EPA has transferred the
oil and grease limitations from option 4 to option
3. EPA has concluded that transfer of these data
are appropriate given that the technology basis
for metals option 3 includes additional treatment
steps than the technology basis for metals option
4. As such, EPA has every reason to conclude
that facilities employing the option 3 technology
could achieve the limitations based on the option
4 technology. This is the same assumption used
for the 1999 proposal.
Transfer of Arsenic for Metals
Subcategory front Option 1A to
Option 4
10.8.2
Similarly, because of the relatively low levels
bfafsenic in the influent of the facilities with thS-
model technology.for metals option 4,.application
of the data editing criteria (described^in section
10.4.3.1) resulted hi excluding the effluent data™
-from-this option.
Because the data for option 1A pass the data_
editing criteria, this indicates .that arsenic is
present in the types of influent wastes in this
subcategory. In addition, the arsenic data for
option 3 pass the data editing criteria. Thus,
. EPA determined that this parameter should be
regulated for both options in this subcategory.
However, option 3 is a more sophisticated
technology than option 4, so EPA chose to use
the data from option 1A to develop limitations
for option 4. In effect, EPA has transferred the
arsenic limitations from option 1A to option 4.
EPA has concluded that transfer of these data
are appropriate given 'that the technology basis
for metals option 4 includes additional treatment
steps and should provide better removals than
option 1A. As such, EPA expects that facilities
utilizing the option 4 technologies can achieve
arsenic effluent concentration levels at least as
low as the values from facilities using the option
1A technologies. Thus, EPA has transferred the
arsenic limitations from option 1A to option 4.
In the 1999 proposal, EPA transferred the
long-term average from arsenic from option 1A
and used the group-level variability factors from
option 4. Under the data restrictions for the
1999 proposal (which were more stringent than
those for the final rule), silicon was the only
pollutant in the semi-metals group for which
EPA could calculate variability factors to apply
to the arsenic limitations. The daily variability
factor for silicon was among the lowest
calculated^ for:the 1999-proposal. - After the
proposal, EPA determined that the arsenic
effluent values for option 4 have different
variability than those for silicon/1 Thus, EPA
also transferred the arsenic variability-factors, „
from option 1A for the final rule. By transferring
both the long-term average and the variability
factors from option 1A to option 4, EPAhas, in
effect^transferred'the-limitations-.-"-
Transfer of Lead for Metals
Subeategory front Option 4 to
Options 10.8.3
For option 3, EPA used the data from the
two sampling episodes and the self-monitoring-
data to develop a daily maximum standard for
lead. Based upon these data, the daily maximum
standard would be 0.329 mg/L. However, all
four data values from the second sampling
episode were greater than this daily maximum
standard. In EPA's view, the data from this
second sampling episode should be less than the
daily maximum standard, because the facility's
permit required the facility to have more
carefully controlled lead discharges during the
second sampling episode than the time periods,
corresponding to the self-monitoring data and the
first sampling episode. Therefore, EPA
concluded that facilities employing this
technology option may not be able to comply
with this daily maximum standard for lead. To
2 'As detailed in Chapter 7, EPA analyzed
silicon using semi-quantitative methods. In
contrast, arsenic is analyzed quantitatively.
10-41
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWTPoint Source Category
resolve this, EPA transferred the daily maximum
(1.32 mg/L) and monthly average standards
(0.283 mg/L) for lead from metals option 4.
These standards are based on less treatment
technology than the option 3 technology and
EPA expects an option 3 model facility to be able
to comply with these standards.
Transfers of Limitations from Other
Rulemakings to CWT Industry
10.8.4
In some cases, the model technology did not
optimally remove BODS and TSS for an.option
in a subcategory. In EPA's view, this occurred
because the limitations are largely based on
indirect discharging facilities that are not required
to control or optimize their treatment systems for-
the removal of conventional parameters. Thus,
EPA transferred the BPT/BCT/NSPS limitations
(for direct dischargers data) from effluent
guidelines from other industries with similar ,
wastewaters arid treatment technologies. In one
case, EPA transferred the BPT/BCT TSS
limitations from the Metal Finishing rulemaking
to the metals subcategory BPT/BCT limitations
(option 4). In the other case, EPA transferred
the BPT/BCT BOD5 and TSS limitations from
the Organic Chemical, Plastics, and Synthetic
Fibers (OCPSF) rulemaking to the organics
subcategory BPT/BCT/NSPS limitations (option
4). EPA used different procedures from the one
discussed in section 10.7.1 to develop 'the
limitations for BODS and TSS for the organics
subcategory and TSS for option 4 in the metals
subcategory. The following sections describe
these different procedures.
Transfer of BOD5 and TSS for the
Organics Subcategory
10.8.4.1
EPA based the transferred limitations of
BODj and TSS for the organics subcategory on-
biological treatment performance data used to
develop the limitations .for the thermosetting
resins subcategory in the Organic Chemicals,
Plastics, and Synthetic Fibers (OCPSF) industry
rulemaking. As described in the final CWT
preamble, EPA determined that the transfer of
the data was warranted because facilities in. the
organics subcategory treat wastes similar to
wastes treated by OCPSF facilities.
For the organics subcategory of the CWT
industry, the daily maximum limitations for
BOD5 and TSS were transferred directly from
the OCPSF rulemaking. No modifications were
required before transferring these daily maximum
limitations.
Some modifications of the OCPSF monthly
average limitations were- required before the
values could be transferred to the CWT industry.
The OCPSF limitations for BOD5 and TSS were
based on assumptions of a monitoring frequency
of 30 days and the presence of autocorrelation in
the measurements. In the rulemaking for the
CWT industry, the monthly limitations forBOD5
and TSS were.basedon,an.assumed monitoring
frequency of 20"days and no autocorrelation (see
section 10.6:5r3.2 for a discussion of the absence
of autocorrelation in trie 'CWT data). Therefore,
the following conversion steps were necessary to-
convert the OCPSF 30-day variability factors to
20-day variability factors.
10-42
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
The following formula was used in the OCPSF rulemaking to calculate the 30-day variability
factors. This formula incorporates autocorrelation, p, between measurements on adjacent days (i.e.,
the lag-1 autocorrelation).
= l +1.6451
30
(36)
where the function/30(p,0). represents the additional variability attributable to autocorrelation, and is
given by
2
30
(37)
The above two-formulas-can be generahzed to estimate n-day variability factors. These formulas are:
VFn=l + 1.645
n > 2
where
h
(38-)r.
(39).
For the limitations, the autocorrelation, p, has been assumed to be absent; thus, the value of p is set
equal to zero. Therefore, the value offa(0,a) is equal to 1, and equation 38 becomes:
VFn=l + 1.645
n>2
(40)
n
Because all of the values were detected (i.e., there were no non-detected measurements) in the OCPSF
data base for BOD5 and TSS, the modified delta-lognormal distribution of these data is the same as the
lognormal distribution (i.e., the delta portion does not enter into the calculations because it is used to
model non-detect measurements). Therefore, an estimate of o2 was obtained from the daily variability
factor from the lognormal distribution by using the following equation:
l£l
"2 (41)
where $"'(0.99) is the 99th percentile of the inverse normal distribution. (The value of $'!(0.99) is
2.326.) By solving this equation using maximum likelihood estimation for a and substituting it into
equation 40, an estimate of VFn may be obtained. Finally, the n-day limitation is calculated as:
VF
. , Limit =-^- ' , (42)
" E(X)
10-43
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
The expected value, E(X) can be estimated by solving for E(X) in the following equation for the daily
maximum limitation (which is the same for both the OCPSF, and the CWT industry):
Limit =
1 ~ *(*)
to obtain
Limit
(43)
(44)
Then, equation 40 (using the estimate of o2 from equation 41) and equation 44 can be substituted into
equation 42 to obtain:
/
Limit n =
Limit
1 + 1.645-
S-i
n
(45)
In particular, for the monthly, average limitation based on assuming daily monitoring (i.e.,
approximately 20 times a month),-the limitation is
Limit2Q =
Limit\
VF,
1+1.645-
20
(46)
Table 10-7 provides the values,of the BOD^and.TSSJimitations and other parameters for the
thermosetting resins subcategory from,the,OCP,SF industry andthe organics^subcategory in the CWT
industry. . ;
o
Long-Term Average (mg/1)
VF,
VFM
VFjo
Daily Maximum Limitation (mg/1)
Monthly Average Limitation (mg/1)
OCPSF: Thermosetting
Resins Subcategory
. BOD5
0.6971
41
3.97
1.58
n/a
163
61
TSS
Centralized Waste
Treatment:
Organics Subcategory
BOD5
0.8174 0.6971
45 41
4.79 3.97
1.45 n/a
n/a 1.29
216 163
TSS
0.8174
45
4.79
n/a
1.36
216
Transfer of TSS for Option 4 of the
Metals Subcategory 10.8.2.2
For TSS for option 4 of the metals
subcategory, EPA transferred the limitations
directly from the Metal Finishing ralemaking (see
Table 10-8). EPA based the Metal Finishing
monthly average limitation for TSS upon an
assumed monitoring frequency of ten days per
month and the absence of autocorrelation in the
10-44
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
measurements. EPA has also assumed an
absence of autocorrelation in TSS for the CWT
industry. However, EPA assumed a monitoring
frequency of 20 measurements a month for TSS
for the CWT industry, rather than the ten
measurements assumed in the metal finishing
rulemaking. EPA determined that it was
unnecessary to adjust the monthly average
limitation from the metal finishing rulemaking for
the increase in monitoring frequency. This
adjustment would have-resulted in a monthly
average limitation with a slightly lower-value than-
the value from the metal finishing rule (the
monitoring frequency does not effect the value
of long-term averages and daily maximum
limitations).
feS;., TSS Parameters for Metal Finishing
TSS(mg/L)._
Metal Finishing TSS Values
Long-Term Average (mg/1) 16.8
Daily variability factor 3.59
Monthly Variability Factor 1.85
Assumed monitoring frequency 10/month
Daily Maximum Limitation (mg/1) 60.0
Monthly Average Limitation (mg/1) 31.0
LIMITATIONS FOR THE MULTIPLE
WASTESTREAM SUBCATEGORY
10.9
As described in section FV.F and XHI.A.5,
after the 1999 proposal, EPA developed one
additional subcategory for the CWT industry.
This 'Multiple Wastestream Subcategory' applies
to facilities that treat wastes in more than one
subcategory and meet other requirements as
explained in Chapters 5 and 14.
For each type of limitation or standard (i.e.,
BPT, BCT, BAT, NSPS, PSES, PSNS), EPA
developed four sets of limitations for each of the
possible combinations of the three subcategories
of wastestreams: oils and metals, oils and
organics, metals and organics, and oils, metals
and organics. Table 10-9 identifies the options
corresponding to each of these types of
limitations and standards.
Table 10-9. Options Corresponding to Multiple
Wastestream Subcategory
BPT
BCT
BAT
NSPS
P-SES-
PSNS
Metals
4
4
4
3
- .4
- "4
Oils
9
9
• 9
9
8
9
Organics
4
4
4
4
4
4
Some pollutants are .only regulated in one of
the metals, oils, or organics subcategories. For
these- pollutants;- the -limitations are directly
transferred to the - multiple Wastestream
subcategory." For other pollutants regulated by-
more than one of the metals, oils, or organics
subcategories,^ the - multiple- wastestreamr
subcategory limitations" were derived by selecting,
the most stringent monthly average limitation and
its corresponding maximum daily limitation. In
almost all cases, the most stringent monthly
average limitation and the most stringent daily
maximum limitation were derived from the same
subcategory. Table 10-10 shows some BPT
limitations for all four subcategories for three of
the regulated pollutants.
Regardless of the source of the limitations,
facilities in the multiple Wastestream subcategory
are expected to design and operate then-
treatment systems in a manner that will ensure
compliance with the limitations. Facilities that
are designed and operated to achieve long-term
average effluent levels should be capable of
compliance the with limitations at all times.
10-45
-------
Chapter 10 Data Conventions & Calculations of Limitations
Development Document for the CWT Point Source Category
Table 10-10 BPT Limitations for Wastestreaiiis from All Three Subcategories
BPT
on&
Grease
Antimony
Pyridine
Long-Term Average
Daily Maximum
Limitation
Monthly Average
Limitation
Long-Term Average
Daily Maximum. ..
Limitation
Monthly Average
Limitation
Long-Term Average
Daily Maximum- •
Limitation
Monthly Average
Limitation
Metals
Option 4
34.3
205
50.2
0.170
0.249
' 0.206
N/A
N/A-
N/A
Oils
Option 9
28.3
127
38.0
0.103
0.237
0.141
N/A
N/A
N/A
Organics Multiple
Option 4 Wastestream
N/A
N/A
N/A
0.569
0.928
0.679
0.116
0,370-
0.182
28.3
127
38.0
0.103
0.237
0.141
0.116
0.370
0.182
Values for
Multiple
wastestream
subcategory
selected from:
Oils option 9
(because the
monthly average
limitation is the
most-Stringent)
Oils option 9
Organics 4
N/A: not regulated for that subcategory
10-46
-
-------
Chapter 10 Data Conventions & Calculations of Limitations Development Document for the CWT Point Source Category
REFERENCES 10.10
Aitchison, J. and J.A.C. Brown. 1963. The Lognormal Distribution. Cambridge University Press,
New York:
Barakat, R. 1976. "Stuns of Independent Lognormally Distributed Random Variables." Journal of
the Optical Society of America, 66: 211-216.
Cohen, A. Clifford. 1976. Progressively Censored Sampling in the Three Parameter Log-Normal
Distribution. Technometrics, 18:99-103.
Crow, E.L. and Shimizu. 1988. Lognormal Distributions: Theory and Applications. Marcel Dekker,
Inc., New York.
Engineering and Analysis Division, EPA. "Comment Response Document (Volume VI)." Record...
Section 30.11, DCN 14497 in the Pulp and Paper Phase I Rulemaking Docket..
Engineering and Analysis Division, EPA. "Statistical Support Document for the Pulp 'and Paper."-.
Industry: Subpart B." November 1997, Record Section 22.5, DCN 14496 in the Pulp and Paper
Phase I Rulemaking Docket.
Fuller, W:A^ 1976. Introduction to Statistical Time Series. John Wiley & Sons,-New York.
Kahn, H.D., andM.B. Rubin. 1989. "Use of Statistical Methods in Industrial Water Pollution Control -
Regulations in the United States." Environmental Monitoring and Assessment. Vol. 12:129-148.
Owen, WJ. and T.A. DeRouen. 1980. Estimation of the Mean for Lognormal Data- Containing—
Zeroes and Left-Censored Values, with Applications to the Measurement of Worker Exposure to
. Air Contaminants. Biometrics, 36:707-719.
U.S. Environmental Protection Agency, Effluent Guidelines Division. 1983. Development Document
for Effluent Limitations Guidelines and Standards for the Metal Finishing Point Source Category:
Final EPA 440/1-83/091. Pages A-l to A-7, A-ll, A-12, and VH-260 to VII-262.
U.S. Environmental Protection Agency, Industrial Technology Division. 1987. Development
.Document for Effluent Limitations Guidelines and Standards for the Organic Chemicals, Plastics.
and Synthetic Fibers Point Source Category. Volume I, Volume n. EPA 440/1-87/009.
U.S. Environmental Protection Agency, Office of Water. 1993. Statistical Support Document for
Proposed Effluent Limitations Guidelines and Standards for the Pulp; Paper, and Paperboard Point
Source Category. EPA-821-R-93-Q23.
U.S. Environmental Protection Agency, Office of Water. 1995. Statistical Support Document for
Proposed Effluent Limitations Guidelines and Standards for the Centralized Waste Treatment
Industry. EPA 821-R.95-005. .
10-47
-------
-------
Chapter
11
COST OF TREATMENT TECHNOLOGIES
This chapter explains what EPA has
estimated it will cost to comply with the
CWT effluent limitations guidelines and
standards. Section 11.1 provides a general
description of how EPA developed costs for .the
different individual treatment technology and
regulatory option considered for this rale.
Sections 11.2 through 11.4 describe the
development of costs for each of the wastewater
and sludge treatment technologies evaluated.
Section 11.5.describes additional compliance
costs not related to a specific technology that a
facility may incur. These additional items are
retrofit costs, monitoring costs, RCRA permit .
modification costs, and land costs.
In Section 11.6, • EPA presents some
examples of capital and O&M cost calculations
for CWT facilities using this methodology.
Finally, Section 11.7 summarizes, by
subcategory, the total capital expenditures and
annual O&M costs for implementing the
regulation. Appendix D contains, by
subcategory, the facility-specific capital, O&M,
land, RCRA, and monitoring cost estimates for
each facility to comply with the limitations and
standards.
COSTS DEVELOPMENT
Technology Costs
11.1
11.1.1
EPA obtained cost information for the
technologies that it considered in developing the
limitations guidelines and standards from the
following sources:
• The data base developed from the
information provided in response to the 1991
Waste Treatment Industry (WTI)
Questionnaire (this contained some process
cost information, and EPA used this
wherever possible);
• Technical information developed for other
rulemaking such as the guidelines and
standards for the Organic Chemicals,
." Plastics,, and Synthetic Fibers (OCPSF)
category, Metal Products and Machinery
(MP&M) category, and Industrial Laundries
industries category;
• Engineering literature;
• Data obtained in sampling at the CWT
model facilities; and
• Cost quotations obtained from vendors
(EPA used these extensively in estimating
- the cost of the various technologies).-
The total costs developed by EPA include
the following elements: capital costs of
investment in pollutant control equipment, annual
O&M costs, land requirement costs, sludge
disposal costs, monitoring costs, and retrofit
costs. Because 1989 is the base year for the
WTI Questionnaire, EPA scaled all of the costs
either up or down to 1989 dollars using the
Engineering News Record (ENR) Construction
Cost Index. EPA uses a 1989 base year to
facilitate comparison from guideline to guideline.
EPA based the capital costs for the
technologies, primarily on cost quotations from
vendors. Table 11-1 lists the standard factors
used to estimate the capital costs. Equipment
costs typically include the cost of the treatment
unit and some ancillary equipment associated
with that technology. Other investment costs in
addition to the equipment cost include piping,
instrumentation and controls, pumps, installation,
engineering, delivery, and contingency.
EPA estimated certain design parameters for
costing purposes. One such parameter is the
11-1
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
flow rate used to size many of the treatment
technologies. EPA used the total daily flow in all
cases, unless specifically stated. The total daily
flow represents the annual flow divided by 260,
the standard number of operating days for a
CWT per year.
EPA derived the annual O&M costs for the
various systems from vendors' information or
from engineering literature, unless otherwise
stated. The annual O&M costs represent the
costs of maintenance, taxes and insurance, labor,
energy, treatment chemicals (if needed), and
residuals management (also if needed). Table
11-2 lists the standard factors EPA used to
estimate the O&M costs.
Sections 11.2 through 11.4 present cost
equations for capital costs, O&M costs, and land
requirements for each technology and option.
For most technologies, EPA also developed
capital cost upgrade and O&M cost upgrade
equations. EPA used these equations for
facilities which already have the treatment
technology forming the basis of the option (or
some portion of the treatment -technology) in
place. EPA also presents the flow rate ranges
recommended for use in each equation. EPA is
confident the equations are representative of
costs for such facilities within these ranges.
Outside these ranges, the equations become
extrapolations. These equations, in EPA's
views, do not yield reliable results below the
recommended low flow rate.
Table 11-1. Standard Capital Cost Algorithm
Factor
Capital Cost
Equipment Cost
Installation
Piping
Instrumentation and Controls
Total Construction Cost
Technology-Specific Cost
25 to 55 percent of Equipment Cost
31 to 66 percent of Equipment Cost
6 to 30 percent of Equipment Cost
Equipment+Installation + Piping
+ Instrumentation and Controls
Contingency
15 percent of Total Construction Cost
15 percent of Total Construction Cost
Total Indirect Cost
Engineering + Contingency
Total Capital Cost
Total Construction Cost + Total Indirect
Cost
Option Costs
11.1.2
EPA developed engineering costs for each of
the individual treatment technologies which EPA
considered in developing the CWT limitations
guidelines and standards. This chapter breaks
down these technology-specific costs into capital,
O&M, and land components. To estimate the
cost of any individual regulatory option EPA
considered for this guideline, it is necessary to
sum the costs of the individual treatment
technologies which make up that option. In a
few instances, an option consists of only one
treatment technology. In those instances, the
option cost is obviously equal to the technology
cost. Table 11-3 shows the CWT subcategory
technology options EPA considered. The table
lists the treatment technologies included in each
option, and indicates the subsections which
provide the corresponding cost information.
EPA generally calculated the capital and
O&M costs for each of the individual treatment
technologies using a flow rate range of 1 gallon
per day to five million gallons per day.
However, the flow rate ranges recommended
11-2
-------
Chanter 11 Cost of Treatment Technoloeies
Development Document for the CWTPoint Source Category
for use in the equations are in a smaller range.
Sections 11.2 to 11.4 present these ranges for
each cost equation.
Land Requirements and Costs
11.1.2.1
EPA calculated land requirements for each
piece of new equipment based on the equipment
dimensions. The land requirements include the
total area needed for the equipment plus
peripherals (pumps, controls, access areas, etc.).
Additionally, EPA included a 20-foot perimeter
around each unit. In the cases where adjacent
tanks or pieces of equipment were required, EPA
Table 11-2. Standard Operation and Maintenance Cost Factor Breakdown
used a 20-foot perimeter for each piece of
equipment, and used the minimum area
requirements possible. The tables throughout
Sections 11.2 to 11.4 present the land
requirement equations for each technology. EPA
then multiplied the land requirements by the
corresponding land costs (as detailed in 11.5.4)
to obtain facility specific land cost estimates.
Factor
O&M Cost (1989 $/year)
Maintenance^-
Taxes and Insurance
Labor-
Electricity
Chemicals:
Lime (Calcium Hydroxide)
Polymer
Sodium Hydroxide (100 percent solution)
Sodium Hydroxide (50 percent solution)
Sodium Hypochlorite
Sulfbric Acid
Aries Tek Ltd Cationic Polymer
Ferrous Sulfate
HydratedLime
Sodium Sulfide
Residuals Management ^^
4 percent of Total Capital Cost
2 percent of Total Capital_Cost
$30,300 to $31,200 per man-year
$0.08 per kilowatt-hour
$57 per ton "
$3.38 per pound
$560 per ton
$275 per ton
$0.64 per pound
$80 per ton
$1.34perpound
$0.09 per pound
$0.04 per pound
$0.30 per pound
Technology-Specific Cost
Total O&M Cost
Maintenance + Taxes and Insurance + Labor
+ Electricity + Chemicals + Residuals
Operation and Maintenance Costs 11.1.2.2
EPA based O&M costs on estimated energy
usage, maintenance, labor, taxes and insurance,
and chemical usage cost. With the principal
exception of chemical usage and labor costs,
EPA calculated the O&M costs using a single
methodology. This methodology is relatively
consistent for each treatment technology, unless
specifically noted otherwise.
EPA's energy usage costs include electricity,
lighting, and controls. EPA estimated electricity
requirements at 0.5 Kwhr per 1,000 gallons of
wastewater treated. EPA assumed lighting and
controls to cost $1,000 per year and electricity
cost $0.08 per Kwhr. Manufacturers'
recommendations form the basis of these
estimates.
11-3
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Cateeorv
EPA based maintenance, taxes, and
insurance on a percentage of the total capital cost
as detailed in Table 11-2.
Chemical usage and labor requirements are
technology specific. These costs are detailed for
each specific technology according to the index
given in Table 11-3.
Table 11-3. CWT Treatment Technology Costing Index - A Guide to the Costing Methodology Sections
Subcategory/
Option
Metals 2
Metals 3
Metals 4
Metals - Cyanide Waste Pretreatment
Oils 8
OilsSv
Oils 9
Ofls9v
Organics4
OrganicsS
Treatment Technology
Selective Metals Precipitation
Plate and Frame Liquid Filtration
Secondary Chemical Precipitation
Clarification .
Plate and Frame Sludge Filtration
Filter Cake Disposal
Selective Metals Precipitation
Plate and Frame Liquid Filtration
Secondary Chemical Precipitation
Clarification
Tertiary Chemical Precipitation and pH Adjustment
Clarification
Plate and Frame Sludge Filtration-
Filter Cake Disposal
Primary Chemical Precipitation
Clarification
Secondary (Sulfide) Chemical Precipitation
Secondary Clarification (for Direct Dischargers Only)
Multi-Media Filtration
Plate and Frame Sludge Filtration'
Cyanide Destruction at Special Operating Conditions
Dissolved Air Flotation
Dissolved Air Flotation
Air Stripping
. Secondary Gravity Separation
Dissolved Air Flotation
Secondary Gravity Separation
Dissolved Air Flotation
Air Stripping
Equalization
Sequencing Batch Reactor
Equalization
Sequencing Batch Reactor
Air Stripping
Section
11.2.1.1
11.2.2.1
11.2.1.2
11.2.2.2
11.4.1
11.4.2
11.2.1.1
11.2.2.1
11:2.1:2
11.2.2.2,.
11.2.1.3
11.2.2.2
11.4.1-
11.4.2
11.2.1.4
11.2.2.2
11.2.1.5
11.2.2.2
11.2.5
11.4.1
11.2.6
11.2.8
11.28
11.2.4
11.2.7
11.2.8
11.2.7
11.2.8
11.2.4
11.2.3
11.3.1
11.2.3
11.3.1
11.2.4
'Metals option 4 sludge filtration includes filter cake disposal.
11-4
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
PHYSICAL/CHEMICAL WASTEWATER
TREATMENT TECHNOLOGY COSTS 11.2
Chemical Precipitation 11.2.1
Wastewater treatment facilities widely use
chemical precipitation systems to remove
dissolved metals from wastewater. EPA
evaluated systems that utilize sulfide, lime, and
caustic as the precipitants because of their
common use in CWT chemical precipitation
systems and their, effectiveness in removing -
dissolved metals.
Selective Metals Precipitation —
Metals Options 2 and 3
11.2.1.1
" Among the technologies EPA evaluated for
treating metal-bearing wastestreams were
systems that, "selectively" removed, metals.-
These are systems-designed.^- address the fact
that different metals are- more- efflciently,
removed~at"different~pHs; These systems
perform a series of precipitations at different pHs
in order to maximize removals. The selective
metals precipitation equipment assumed by EPA
for costing purposes for Metals option 2 and
Metals option 3 consists of four mixed reaction
tanks, each sized for 25 percent of the total daily
flow, with pumps and treatment chemical feed
systems. EPA costed for four reaction tanks to
allow a facility to segregate its wastes into small
batches, thereby facilitating metals recovery and
avoiding interference with other incoming waste
receipts. EPA assumed that these four tanks
would provide adequate surge and equalization
capacity for a metals subcategory CWT. EPA
based costs on a four batch per day treatment
schedule (that is, the sum of four batch volumes
equals the facility's daily incoming waste
volume).
As shown in Table 11-3, plate and frame
liquid filtration follows . selective metals
precipitation for Metals options '2 and 3. EPA
has not presented the costing discussion for plate
and frame liquid filtration in this section (consult
section 11.2.3.2). Likewise, Sections 11.4.1 and
11.4.2 discuss sludge filtration and filter cake
disposal. .
CAPITAL COSTS
Because only one facility in the metals
subcategory has selective metals precipitation in-
place, EPA included selected metals precipitation
capital costs for all facilities (except one) for
Metals options 2 and 3.
EPA obtained the equipment capital cost
estimates for the selective metals precipitation
systems, from vendor quotations. These costs
include the cost of the mixed reaction tanks with"
pumps and treatment chemical feed systems..
The total construction cost estimates include
installation, piping and instrumentation^ and
controls,- The,,total capital cost includes
engineering and contingency at a percentage of
the total construction cost plus the total
construction cost (as-explained-in-Table 11-1)..
Table 11-4 at the end of this section presents the
equation for calculating selective metals
precipitation capital costs for Metals option 2 and
option 3. .'
CHEMICAL USAGE AND LABOR
REQUIREMENT COSTS
EPA based the labor requirements for
"selective metals precipitation on the model
facility's operation. EPA estimated the labor
cost at eight man-hours per batch (four treatment
tanks per batch, two hours per treatment tank
per batch).
EPA estimated selective metals precipitation
chemical costs based on stoichiometric, pH
adjustment, and buffer adjustment
requirements. For facilities with no form of
chemical precipitation in-place, EPA based the
stoichiometric requirements on the amount of
chemicals required to precipitate each of the
metal and semi-metal pollutants of concern from
the metals subcategory average raw influent
concentrations to current performance levels (see
Chapter 12 for a discussion of raw influent
11-5
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
concentrations and current loadings). The
chemicals used were caustic at 40 percent of the
required removals and lime at 60 percent of the
requiredremovals (caustic at 40 percent and lime
at 60 percent add up to 100 percent of the
stoichiometric requirements.) These chemical
dosages reflect the operation-of the selective
metals precipitation model facility. Selective
metals precipitation uses a relatively high
percentage of caustic because the sludge resulting
from caustic precipitation is amenable to metals
recovery. EPA estimated the pH adjustment and
buffer adjustment requirements to be 40 percent
of the stoichiometric requirement. EPA added
'an excess of 10 percent to the pH and buffer
adjustment requirements, bringing the-total-to 50-
percent EPA included a 10 percent excess
because this is typical of the operation of the
CWT facilities visited and sampled by EPA.
EPA estimated selective metals
precipitation upgrade costs for facilities that
currently utilize some form of chemical
precipitation. Based on responses to the Waste
Treatment Industry Questionnaire, EPA assumed
that the in-place chemical precipitation systems
use a dosage ratio of 25% caustic and 75% lime
and achieve a reduction of pollutants from "raw"
to "current" levels. The selective metals
precipitation upgrade would require 'a change in
the existing dosage mix to 40% caustic and 60 %
lime. Therefore, the selective metals
precipitation upgrade for facilities with in-place
chemical precipitation is the increase in caustic
cost ( from 25 % to 40%) minus the lime credit
(to decrease from 75% to 60%).~
Table 11-4 .presents the O&M cost equation
for selective-metals precipitation along with the
O&M upgrade cost equation for facilities with
primary and secondary chemical precipitation in-
place.
Table 11-4. Gbst Equations for Selective Metals'Precipitation in Metals Options 2 and 3
Description
Equation
Recommended. Flow
Rate Range (MOD)
Capital cost
O&M cost for facilities without chem.
precipitation treatment in-place
O&M upgrade cost for facilities with
precipitation in-place
Land requirements
ln(Yl) = 14.461+0.5441n(X)+fl.0000047(ln(X))2 . 1.0 E-6 to 5.0
ln(Y2) = 15.6402 + l.OOllnpQ + 0.04857(ln(X))2
3.4 E -5 to 5.0
ln(Y2) = 14.2545 + 0.80661n(X) + 0.04214(ln(X))2 7.4 E -5 to 5.0
ln(Y3) = -0.575 + 0.4201n(X) + 0.025(ln(X))2 1.6 E -2 to 4.0
Yl=Capital Costs (1989$)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 - Land Requirement (Acres)
X=Flow Rate (million gallons per day)
11-6
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
Secondary Precipitation —
Metals Options 2 and 3
11.2.1.2
The secondary precipitation system in the
model technology for Metals option 2 and Metals
option 3 follows selective metals precipitation
and plate and frame liquid filtration. This
secondary chemical precipitation equipment
consists of a single mixed reaction tank with
pumps and a treatment chemical feed system,
which is sized for the full daily batch volume.
As shown in Table n-3;"clanfication follows
secondary - chemical precipitation for Metals
options 2 and 3. Section 11.2.2.2 discusses the
costing for clarification following secondary
precipitation. Sections 11.4.1 and 11.4.2 discuss
sludge filtration and the associated filter cake
disposal.
Many facilities in the metals subcategory
currently have chemical precipitation units in-
place. For these facilities, cost upgrades may be
appropriate. EPA used the following set of rules
to decide whether a facility's costs should be
based on-a full cost equation or-an upgrade
equation for the secondary chemical precipitation
step of metals options 2 and 3:
• Facilities with no chemical precipitation in-
place should use the full capital and O&M
costs;
• Facilities with primary chemical precipitation
in-place should assume no capital costs, no
land requirements, but an O&M upgrade
cost for the primary step; and
• Facilities with secondary chemical
precipitation currently 'in-place should
assume no capital costs, no land
requirements, and no O&M costs for the
secondary step.
CAPITAL COSTS
For facilities that have no chemical
precipitation in-place, EPA calculated capital cost
estimates for the secondary, precipitation
treatment systems from vendor, quotations.
. EPA estimated the other components (i.e.,
piping, instrumentation and controls, etc.) of the
total capital cost by applying the same factors
and additional costs as detailed for selective
metals precipitation (see Section 11.2.1.1 above).
Table 11-5 at the end of this section shows the
capital cost equation for secondary precipitation
in Metals option 2 and option 3.
For the facilities that have at least primary
chemical precipitation- in-place, EPA assumed
that the capital" cost for the secondary
precipitation treatment system would be zero.
The in-place primary chemical precipitation
systems woukTserve as secondary precipitation
systems after the installation of upstream
selective metals precipitation units.
CHEMICAL USAGE AND LABOR "
REQUIREMENT COSTS -
EPA developed O&M cost estimates for the
secondary precipitation-step-of Metals option-2
and 3 for facilities with and-without chemical
precipitation currently in-place. For-facilities-
with no chemical precipitation in-place, EPA
calculated the amount of lime required to
precipitate each of the metals and semi-metals
from the metals subcategory current
performance concentrations (achieved with the
previously explained selective metals
precipitation step) to the Metals option 2 long-
term average concentrations. EPA then added a
ten percent excess dosage factor and based the
chemical addition costs on the required amount
of lime' only, which is based on the operation of
the model facility for this technology. EPA
assumed the labor cost to be two hours per
batch, • based on recommendations from
manufacturers.
For facilities with chemical precipitation in-
, place, EPA calculated an O&M upgrade cost. In
calculating the O&M upgrade cost, EPA
assumed that there would be no additional costs
associated with any of the components of the
annual O&M cost, except for increased chemical
costs.
11-7
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
Because EPA already applied credit for
chemical 'costs for facilities with primary
precipitation in estimating the selective metals
precipitation chemical costs, the chemical
upgrade costs for facilities with primary
precipitation are identical to facilities with no
chemical precipitation in-place.
Because EPA assumed that facilities with
secondary precipitation would achieve>the metals
option 2 long term average concentrations with
their current system and chemical additions (after
installing the selective metals precipitation
system), EPA assumed these facilities would not'
incur any additional chemical costs. In turn,
EPA also assumed that facilities with secondary
precipitation units in-place would incur no O&M
upgrade costs. •
Table 11-5. Cost Equations for Secondary Chemical Precipitation in Metals Options 2 and 3
Description
Equation
Recommended Flow
Rate Range (MGD)
Capital cost
O&M cost for facilities with no
chemical precipitation in-place
O&M upgrade cost for facilities with
primary precipitation in-place
Land requirements
In (Yl) = 13.829 + 0.5441n(X) + 0.00000496(ln(X))2
In (Y2) = 11.6553 + 0.483481n(X) + 0.02485(ln(X))2
In (Y2) = 9.97021 + 1.001621n(X) + 0:00037(lh(X))2
In (Y3) = -1.15 + 0.4491n(X) + 0.027(ln(X))2
1.0E-6to5.0
6.5 E -5 to 5.0
5.0 E -4 to 5.0
4.0 E -3 to 1.0
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3- Land Requirement (Acres)
X=How Rate (million gallons per day)
Tertiary Precipitation andpH
Adjustment — Metals Option 3
11.2.1.3
The tertiary chemical precipitation step for
Metals option 3 follows the secondary
precipitation and clarification steps. This tertiary
precipitation system consists of a rapid mix
neutralization tank and a pH adjustment tank. In
this step, the wastewater is fed to the rapid mix
neutralization-tank where lime slurry is added to
raise the pH to 11.0. Effluent from the
neutralization tank then flows to a clarifier for
solids removal. The clarifier overflow goes to a
pH adjustment tank where sulfuric acid is added
to achieve the desired final pH of 9.0. " This
section explains the development of the cost
estimates for the rapid mix neutralization tank
and the pH adjustment tank. Sections 11.2.2.2,
11.4.1, and 11.4.2 discuss clarification, sludge
filtration, and associated filter cake disposal.
CAPITAL COSTS
EPA developed the capital cost estimates for
the rapid mix tank assuming continuous flow and
a 15-minute detention time, .which is based on
the model facility's standard operation. The
equipment cost includes one tank, one agitator,
and one lime feed system.
EPA developed the capital cost estimates for
the pH adjustment tank assuming continuous
flow and a five-minute detention time, also based
on the model facility's operation. The
equipment cost includes one tank, one agitator,
and one sulfuric acid feed system.
EPA estimated the other components (i.e.,
piping, instrumentation and controls, etc.) of the
total capital cost for both the rapid mix and pH
11-8
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
adjustment tank by applying the same factors
and additional costs as detailed for selective
metals precipitation (see Section 11.2.1.1 above).
Table 11-6 at the end of this section presents the
capital cost equations for the rapid mix and pH
adjustment tanks.
CHEMICAL USAGE AND LABOR
REQUIREMENT COSTS
EPA did not assign O&M costs, and in turn,
chemical usage and labor requirement costs for
tertiary^ precipitation and pH adjustment to the
few facilities which have tertiary precipitation
(and pH adjustment) systems in-place. For those
facilities without tertiary precipitation (and pH
adjustment) in-place, EPA estimated the labor
requirements at one man-hour per day for the
rapid mix and pH adjustment tanks. EPA based
this estimate on the model facility's typical
operation.
EPA estimated chemical costs for the rapid
mix tank based on lime addition to achieve the
stoichiometric requirements of reducing the
metals in the wastewater from the Metals option
2 long-term averages to the Metals option 3 long-
term averages, with a 10 percent excess. EPA
estimated the chemical requirements for the pH
acid to lower the pH from 1 l-.O to 9.0, based on
the model facility's operation. Table 11-6 the
O&M cost equations for the rapid mix tank and
pH adjustment tank.
Table 11-6. Cost Equations for Tertiary Chemical Precipitation in Metals Option 3
Description
Equation
Recommended
Flow Rate Range
(MOD)
Capital cost for rapid mix tank
Capital cost for pH adjustment tank
O&M cost for rapid mix tank
O&M cost for pH adjustment tank
Land requirements for rapid mix tank
Land requirements for pH adjust, tank
ln(Yl) = 12.318 + 0.5431n(X) - 6.000179(ln(X))2
ln(Yl) = 11.721 + 0.543In(X) + 0.000139(In(X))2
ln(Y2) = 9.98761 + Q.375141n(X) + 0.02124(In(X))2
ln(Y2) = 9.71626 + 0.332751n(X) + 0.0196(!n(X))2
ln(Y3) = -2.330 + 0.3521n(X) + 0.0190n(X))2
ln(Y3) = -2.67 + 0.30to(X) + 0.033(ln(X))2
1.0E-5to5.0
1.0E-5to5.0
1.6 E -4 to 5.0
2.5 E -4 to 5.0
1.0 E-2 to 5.0
1.0 E -2 to 5.0
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X = Flow Rate (million gallons per day)
11-9
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
Primary Chemical Precipitation -.
Metals Option 4
11.2.1.4
The primary chemical precipitation system
equipment for the model technology for Metals
option 4 consists of a mixed reaction tank with
pumps, a treatment chemical feed system, and
an unmixed wastewater holding tank. EPA
designed the system to operate on a batch basis,
treating one batch per day, .five days per week.
The average chemical precipitation batch
duration reported by respondents to the WTI
Questionnaire was four hours. Therefore, a one
batch per day treatment schedule should provide
sufficient time for the average facility to pump,
treat, and test its waste. EPA also included a
holdingtank, equal to the daily waste volume, up
to a maximum size of 5,000 gallons (equivalent
to the average tank truck receipt volume
throughout the industry), to allow facilities
flexibility in managing waste receipts (the Metals
option 4 model facility, utilizes a holding tank).
As shown in Table 11-3, clarification follows
primary chemical precipitation for metals option
4. The costing discussion for clarification
following primary precipitation in Metals option
4 is presented in section 11.2.2.2. Sections
11.4.1 and 11.4.2 discuss sludge filtration and
the associated filter cake disposal.
CAPITAL COSTS
EPA developed total capital cost estimates
for the Metals option 4 primary chemical
precipitation systems. For facilities with no
chemical precipitation units in-place, the
components of the chemical precipitation system
included a precipitation tank with a mixer,
pumps, and a feed system. In addition, EPA
included a holding tank equal to the size of the
precipitation tank, up to 5,000 gallons. EPA
obtained these cost estimates from
manufacturer's recommendations.
EPA estimated the other components (i.e.,
piping, instrumentation and controls, etc.) of the
total capital cost for both the rapid mix and pH
adjustment tank by applying the same factors
and additional costs as detailed for selective
metals precipitation (see Section 11.2.1.1 above).
For facilities that already have any chemical
precipitation (treatment in-place), EPA included
as capital expense only the cost of a holding
tank. Table 11-7 presents the capital cost
equations for primary chemical precipitation and
the holding tank only for Metals option 4.
LABOR AND CHEMICAL COSTS
EPA approximated the labor cost for primary
chemical precipitation in Metals option 4 at two
hours per batch, one batch per day. EPA based
this approach on the model facility's operation.
EPA estimated chemical costs based- on,
stoichiometric, pH adjustment, and buffer
adjustment requirements. For facilities with no
chemical precipitation in-place, EPA based the
stoichiometric requirements on the amount of
chemicals. required to precipitate each , of the
metal pollutants of concern from the metals
subcategory average raw influent concentrations
to Metals option 4 (Sample Point - 03)
concentrations. Metals option 4, Sample Point -
03 concentrations represent the sampled effluent
from primary chemical precipitation at the model
facility. The chemicals used were lime at 75
percent of the required removals and caustic at
25 percent of the required removals, which are
based on the option facility's operation. EPA
estimated the pH adjustment and buffer
adjustment requirements to be 50 percent of the
stoichiometric requirement, which includes a. 10
percent excess of chemical dosage. Table 11-7
presents the O&M cost equation for primary
chemical precipitation in Metals option 4 for
facilities with no treatment in-place.
For facilities which already have chemical
precipitation treatment in-place, EPA estimated
an O&M upgrade cost. EPA assumed that
facilities with primary chemical precipitation in-
place have effluent concentrations exiting the
primary precipitation/solid-liquids separation
system equal to the metals subcategory primary
. 11-10
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
precipitation current loadings. Similarly, EPA
assumed that facilities with secondary chemical
precipitation in place have effluent
concentrations exiting the secondary
precipitation/solid-liquids separation system equal
to metals subcategory secondary precipitation
current loadings (see chapter 12 for a detailed
discussion of metals subcategory primary and
secondary chemical precipitation current
loadings).
For the portion, of the O&M upgrade
equation associated with energy, maintenance,
and labor, EPA calculated the percentage
difference between the primary precipitation
current loadings and Metals option 4 (Sample,
Point - 03) concentrations; For facilities which
currently have primary precipitation systems this
difference is an increase of approximately two
• percent:. Therefore, EPA calculated the energy,
maintenance, and labor components of the O&M
upgrade cost for facilities with primary chemical-
precipitation in-place at two percent of the O&M
cost for facilities with no chemical precipitation
in-rplace-.-
For the portion of the O&M upgrade
equation associated with energy, maintenance,
and labor, EPA calculated the percentage
difference between secondary precipitation
current loadings and Metals option 4 (Sample
Point - 03) concentrations. For secondary
precipitation systems, this difference is also an
increase of approximately two percent1.
Therefore, EPA calculated the energy,
maintenance, and labor components of the O&M
upgrade cost for facilities with secondary
chemical precipitation in-place at two percent of
the O&M cost for facilities with no chemical
precipitation in-place.
For the chemical cost portion of the O&M
upgrade, EPA also calculated upgrade costs
depending on whether the facility had primary
precipitation or secondary precipitation currently
in-place. For facilities with primary precipitation,-
EPA calculated chemical upgrade costs based on
current-to-Metals option 4 (Sample Point - 03)
removals. Similarly for facilities with secondary
precipitation, EPA calculated chemical upgrade
costs based on secondary precipitation removals
to Metals option 4 (Sample Point - 03) removals.
In both cases, EPA did not include costs for pH
adjustment or buffering chemicals-since these
chemicals should already be used in the in-place
treatment-system: Frnally,JEPA"included a 10
percent excess of chemical dosage to the
stoichiometric requirements of the precipitation
chemicals.
EPA then combined the energy, maintenance
and labor components of the O&M upgrade with
the chemical portion of the O&M upgrade to
develop two sets of O&M upgrade equations for
the primary chemical precipitation portion of
Metals option 4. Table 11-7 presents these cost
equations for Metals option 4 (primary chemical
precipitation O&M upgrade costs) for facilities
with primary and secondary treatment in place. •
^While pollutant concentrations resulting
.from secondary chemical precipitation are
generally lower than those resulting from primary
chemical precipitation, the percentage increase
(when rounded) for primary and secondary
precipitation are the same.
11-11
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Catesorv
Table 11-7. Cost Equations for Primary Chemical Precipitation in Metals Option 4
Description
Equation
Recommended Flow
Rate Range (MOD)
Capital cost for primary precipitation and ln(Yl) '
no treatment in-place
Capital cost for holding tank only-used ln(Yl):
for facilities with chemical precipitation
currently in-place.
O&M cost for primary precipitation and ln(Y2) =
no treatment in-place
O&M upgrade for facilities with primary ln(Y2) =
precipitation in-place
O&M upgrade for facilities with MY3) =
secondary precipitation in-place
Land requirements hi(Y3) =
Land requirements (associated with ln(Y3) =
holding tank only)
= 14.019 + 0.4811n(X) - 0.00307(ln(X))2
= 10.671 - 0.0831n(X) - 0.032
-------
Chanter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
LABOR AND CHEMICAL COSTS
For facilities with no secondary precipitation
systems in-place, EPA estimated the labor
requirements at two hours per batch, one batch
per day. EPA based this estimate on standard
operation at the Metals option 4 model facility.
For secondary sulfide precipitation in Metals
option 4, EPA did not base the chemical cost
estimates on stoichiometric requirements.
Instead, EPA estimated the chemical costs based
on dosage rates for the addition of polymer and
ferrous sulfide obtained during the sampling of
the Metals option 4 model plant with BAT
performance. Table 11-8 presents the O&M
cost equation for the Metals option 4, secondary
sulfide precipitation.
Table 11-8. Cost Equations for Secondary (Sulfide) Precipitation for Metals Option 4
Description
Equation
Recommended Flow
Rat& Range (MGD)
Capital cost for secondary precip. and no In (Yl) = 13.829 + 0.544]n(JQ + 0.00000496(ln(X))2
treatment in-place
O&M cost for secondary precip. and no In (Y2) =12.076 + 0.634561n(X) + 0.03678(Tn(X))2
treatment in-place —
Land requirements .
In (Y3) = -1.15 + 0.4491n(X) + 0.027(ln(X))2
1.0E-6to5.0
1,8 E -4 to 5.0
2.5 E-4 to 1.0
Yl= Capital Coste (1989$)-
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acies)
X=Flow Rate (million gallons per day)
Plate and Frame Liquid
Filtration and Clarification
11.2.2
Clarification systems provide continuous,
low-cost separation and removal of suspended
solids from water. Waste treatment facilities use
clarification to remove particulates, flocculated
impurities, and precipitants, often following
chemical precipitation. Similarly, waste
treatment facilities also use plate and frame
pressure systems to remove solids from waste
streams. As described in this section, these plate
and frame filtration systems serve the same
function as clarification and are used to remove
solids following chemical precipitation from
liquid wastestreams. The^ major difference
between clarification systems and plate and
frame liquid filtration systems is that the sludge
generated by clarification generally needs to be
processed further prior to landfilling, whereas,
the sludge generated by plate and. frame liquid
filtration does not.
EPA costed facilities to include a plate and
frame liquid filtration system following selective
metals precipitation in Metals options 2 and 3.
The components of the plate and frame liquid
filtration system include: filter plates, filter cloth,
hydraulic pumps, control panel, connector pipes,
and a support platform. Since EPA costed all
metals facilities for selective metals precipitation
systems for metals options 2 and 3 (except the
one facility which already utilizes this
technology), EPA also costed all metals facilities
for plate and frame liquid filtration systems.
Consequently, EPA did not develop any upgrade
costs associated with the use of plate and frame
liquid filtration.
EPA also costed facilities to include a
clarifier following secondary precipitation for
Metals option 2 and following both secondary
11-13
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Catesorv
and tertiary precipitation for Metals option 3.
For Metals option 4, EPA costed facilities to
include a clarifier following primary chemical
precipitation and following secondary
precipitation (for direct dischargers only). EPA
designed and costed a single clarification system
for all options and locations in the treatment
train. The components of this clarification
system include a clarification unit, flocculation
unit, pumps, motor, foundation, and accessories.
Plate and Frame Liquid Filtration
Following Selective Metals
Precipitation
11.2.2.1
CAPITAL COSTS
The plate and- frame liquid filtration
equipment following the selective- metals-
precipitation step for the model technology in
Metals option 2 and 3 consists of two plate and
frame liquid filtration systems. EPA^assumed
that each system would be used to-process-two»
batches per day for a total of-four batches. EPA
costed the plate and frame liquid filtration
systems in this manner to allow facilities to
segregate their wastes into smaller batches,
thereby facilitating selective metals recovery.
EPA sized each of the units to process a batch
consisting of 25 percent of the daily flow and
assumed that the influent to the plate and frame
filtration units would consist of 96 percent liquid
and four percent (40,000 mg/1) solids (based on
the model facility). EPA based the capital cost
equation for plate and frame liquid filtration for
Metals options 2 and 3 on information provided
by vendors. Table 11-9 lists this capital cost
equation.
CHEMICAL USAGE AND LABOR REQUIREMENTS
EPA estimated-that labor requirements for
plate and frame liquid filtration for Metals
options 2 and 3 would be 30 minutes per batch
per filter press (based on the metals options 2
and 3 model facility). There are no chemicals
associated with the operation of the plate and
frame filtration systems. EPA estimated the
remaining components of O&M using the factors
listed in Table 11-2. Table 11-9 lists the O&M
equation for plate and frame liquid filtration.
Even though the metal-rich sludge generated
from selective metals precipitation and plate and
frame liquid filtration may be recycled and re-
used, EPA additionally included^osts associated
with disposal of these sludges in a landfill. The
discussion for filter cake disposal is presented
separately in Section 11.4.2. These disposal
costs are additional O&M costs which must be
added to the O&M costs calculated above to
obtain the total O&M costs" associated with plate
and frame liquid filtration for Metals options 2
and 3.
Clarification for Metals Options
2,3, and 4
1-1.2.2.2
CAPITAL COSTS
EPA obtained the capital cost estimate for
clarification systems from vendors. EPA
designed the clarification system assuming ,an
influent total suspended solids' (TSS)
concentration of 40,000 mg/L (four percent
solids) and an effluent TSS concentration of
200,000 mg/L (20 percent solids). In addition,
EPA assumed a design overflow rate of 600
gpd/ft2, EPA estimated the influent and effluent
TSS concentrations and overflow rate based on
the WTI Questionnaire response for
Questionnaire ID 105. The capital cost equation
for clarification is presented in Table 11-9 at the '
end of this section. As detailed earlier, the same
capital cost equation is used for all of 'the
clarification systems for all of the metals options
regardless of its location in the treatment train.
EPA did not develop capital cost upgrades for
facilities which already have clarification systems
in-place. Therefore, facilities which currently
have clarifiers have no land or capital costs.
CHEMICAL USAGE AND LABOR REQUIREMENTS
EPA estimated the labor requirements for
11-14
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
the clarification systems for Metals options 2 and
3 following secondary precipitation and Metals
option 4 following primary and secondary (for
direct dischargers only) precipitation at three
hours per day for low-flow clarifiers and four to
six hours per day for high-flow clarifiers. Based
on manufacturers recommendations, EPA
selected the flow cut-off between high-flow and
low-flow systems to be 1000 gallons per day.
For the clarifier following tertiary precipitation in
Metals option 3 only, EPA estimated the labor
requirement at one hour per day (based on the
operation of the Metals option 3 model facility).
For all clarifiers for all metals options and
treatment train locations, EPA estimated a
polymer dosage rate of 2.0 mg per liter of
wastewater (for the flocculation step) based on
the MP&M industry cost model. EPA estimated
the remaining components of O&M using the
factors listed in Table 11-2. Table 11-9 lists the
two cost equations developed for,clarification.
One equation is used for the clarifier following,
the tertiary precipitation step of Metals option 3
and the other equation is used for all.other
Metals options and locations in the treatment
train.
As shown in Table 11-3, sludge filtration
follows clarification for the secondary
precipitation step of Metals options 2 and 3 and
the primary and secondary (direct dischargers
only) of Metals option 4. Section 11.4.1 and
11.4.2 present the costing discussion and
equations for sludge filtration and the associated
filter cake disposal.
For facilities which already have clarification
systems or plate and frame liquid filtration
systems in-place for each option and location hi
the treatment train, EPA estimated clarification
upgrade costs. EPA assumed that in-place
clarification systems and in-place plate and frame
liquid filtration systems are equivalent.
Therefore, if a facility has. an in-place liquid
filtration system which can serve the same
purpose as a clarifier, EPA costed this facility for
an Up-grade only and not a new clarification
system.
For the clarification step following secondary
precipitation hi Metals options 2 and 3, hi order
to quantify the O&M increase necessary for the
O&M upgrade, EPA compared the difference
between secondary precipitation current
performance concentrations and the Metals
option 2 long- term averages. EPA determined
facilities would need to increase 'their current
removals by 3 percent. Therefore, for in-place
clarification systems (or plate and frame liquid
filtration systems) which could serve as the
clarifier following secondary chemical
precipitation for Metals option 2 and 3, EPA
included an O&M cost upgrade of three percent
of the O&M costs for a brand new system
(except for taxes, insurance, and maintenance
which are a function of the capital cost). Table
11-9 lists the O&M upgrade equations for
clarification following- secondary chemical:
precipitationforMetals option2 and3 (one for
facilities which currently have a clarifier and one
for_ facilities, which currently .have a plate and
frame liquid filtration system).
• For facilities which already have clarifiers or
plate and frame liquid filtration systems in-place
which could serve as the clarifier following the
tertiary chemical precipitation of Metals option 3,
EPA did not estimate any O&M upgrade costs.
EPA assumed the in-place technologies could
perform as well as (or better) than the
technology costed by EPA.
For facilities which already have clarifiers or
plate and frame liquid filtration systems in-place
which could serve as the clarifier following the
primary chemical precipitation of Metals option
4, EPA compared the difference between
primary precipitation current loadings and the
long-term averages for Metals option 4, Sample
Point - 03 (Sarnple Point - 03 follows primary
precipitation and clarification at the Metals option1
4 model facility). EPA determined that facilities
would need to increase their removals by 2%.
Therefore, for in-place clarification systems (or
plate and frame liquid filtration systems) which
could serve as the clarifier following primary
chemical precipitation for Metals option 4, EPA
11-15
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
included an O&M cost upgrade of two percent
of the O&M costs for a brand new system
(except for taxes, insurance, and maintenance
which are a function of the capital cost). Table
11-9 lists the O&M upgrade equations for
clarification following primary chemical
precipitation for Metals option 4 (one for
facilities which currently have a clarifier and one
for facilities which currently have a plate and
frame liquid filtration system).
EPA did not' calculate an O&M upgrade
equation for the clarification step following
secondary chemical precipitation (direct
dischargers only) of Metals option 4. EPA
costed all direct discharging facilities for a new
clarification system following secondary chemical
precipitation for Metals option 4 since none of
the direct discharging metals facilities had
treatment in-place for this stepr
11-16
-------
Chanter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
Table 11-9. Cost Equations for Clarification and Plate and Frame Liquid Filtration in Metals Option 2,3,4
Description
Equation
Recommended How
Rate Range (MOD)
Capital cost for plate and frame liquid filtration ln(Yl) = 14.024 + 0.8591n(X). + 0.040(ln(X))2
- Metals Options 2 and 31
Capital Cost for Clarification - Metals Options ln(Yl) = 11.552 + 0.4091n(X) + 0.020(Tn(X))2
2,3, and 4 v
O&M cost for plate and frame liquid filtration - ln(Y2) = 13.056 + 0.1931n(X) + 0.00343(ln(X))2
Metals Options 2 and 3;
O&M cost for Clarification - Metals Options ln(Y2) = 10.673 + 0.2381n(X) + 0.013(ln(X))2
1.0 E -6 to 1.0
.4.0 E -5 to 1.0
1.0 E -6 to 1.0
1.2 E -4 to 1.0
8.0 E-5 to 1.0
7.0 E-5 to 1.0
O&M cost for clarification - Metals Option 3* ln(Y2) = 10.294 + 0.3621n(X) + 0.019(ln(X))2
O&M upgrade for Clarification -Metals ln(Y2) = 7.166 + 0.2381n(X)+'0.013(ln(X))2
Options 2 and 3 facilities which currently have
clarification in-place5
O&M upgrade for Clarification -Metals ln(Y2) = 8.707 + 0.3331n(X) + 0.012(hi(X))2 • 1.0 E-6 to 1.0
Options 2 and 3 facilities which currently have
plate&fiame liquid filtration in-place
O&U-upgrad&far Clarification- ln(Y2) = 6.8135+ 0.33151n(X) + 0.0242(ln(X))2 1.2 E-3 to 1.0
Metals Option4* -..--•
O&M upgrade forplate and frame Kquid ln(Y2) = 12.0242 + 1.176761n(X)'+ 0.05005(ln(X))2 1.0 E-6 to 1.0
filtration - Metals Option4 •• •
Land requirements-for plate and frame liquid InfYSJ^-l.eSS + O.lSSlnpp^OiOOgtfcGQ)!:. i:0"E*-61o W
filtration-Metals Options-2 and 3
Land requirements for clarification ln(Y3) =-1.773 +0.5131n(X) + 0.046(ta(X))2 1.0 E-2 to 1.0
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X=Flow Rate (million gallons per day) ,
•'Follows selective metals precipitation
3For metals option 3, this Aquation is used for clarification following secondary chemical precipitation only
*Ihis equation is used for clarification following tertiary precipitation only.
5For Metals Option 3, this equation is used for clarification following secondary precipitation only. No
O&M upgrade costs included for tertiary precipitation.
''Tnis equation is used for clarification following primary precipitation only. No facilities require O&M
upgrades for clarification following secondary chemical precipitation.
Equalization
11.2.3
To improve treatment, facilities often =need
to equalize wastes by holding them in a tank.
The CWT industry frequently uses equalization
to minimize the variability of incoming wastes
effectively. - . -
EPA costed an equalization system which
consists of a mechanical aeration basin based on
responses to the WTI Questionnaire. EPA
obtained the equalization cost estimates from the
1983 U.S. Army Corps of Engineers' Computer
Assisted Procedure for Design and Evaluation of
Wastewater Treatment Systems (CAPDET).
EPA originally used this program to estimate
- equalization costs for the OCPSF Industry.
Tablell-10 lists the default design parameters
that EPA used in the CAPDET program. These
default design parameters are reasonable for the
CWT industry since they reflect values seen in
the CWT industry. For example, the default
detention time (24 hours) is appropriate since
11-17
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the C*WT Pnin-t
this was the median equalization detention time
reported by respondents to the WTI
Questionnaire.
Table 11-10. Design Parameters Used for
Equalization in CAPDET Program
Aerator mixing=0.03 HP per 1,000 gallons;
Oxygen requirements = 15.0 mg/l per hour;
Dissolved oxygen in basin=2.0 mg/l;
Depth of basin=6.0 feet; and
Detention time=24 hours.
LAND REQUIREMENTS
EPA used the CAPDET program to develop
land requirements for the equalization systems.
EPA scaled up the requirements to represent the
total land required for the system plus peripherals
(pumps, controls, access areas, etc.). The land
requirement equation for equalization systems is
also presented in Table 11-11.
. • EPA did not calculate capital or O&M
upgrade equations for equalization. If a CWT
facility currently has an equalization tank in-
place, the facility received no costs associated
with equalization. EPA assumed that the
equalization tanks currently in-place at CWT
facilities would perform as well as (or better
than) the system costed by EPA.
CAPITAL COSTS
The CAPDET program calculates capital
costs which are "total project costs." These
"total project costs" include all of the items
previously listed in Table 11-1 as well as
miscellaneous' nonconstruction costs, 201
planning costs, technical costs, land costs,
interest during construction, and laboratory costs.
Therefore, to obtain capital costs for the
equalization systems for this industry, EPA
calculated capital costs based on total project
costs minus: miscellaneous nonconstruction
costs, 201 planning costs, technical costs, land
costs, interest during construction, and laboratory
costs. Table 11-11 at the end of this section
presents the resulting capital cost equation for
equalization.
OPERATION AND MAINTENANCE COSTS
EPA obtained O&M costs directly from the
initial year O&M costs produced by the
CAPDET program. Table 11-11 presents the
O&M cost equation for equalization systems.
11-18
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category •
Table 11-11. Summary of Cost Equations for Equalization
Description
Equation
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)..
X = Row Rate (million gallons per day)
Recommended Flow
Rate Range (MOD)
Capital cost for equalization
O&M cost for equalization
Land requirements
ln(Yl) = 12.057 + 0.4331n(X) + 0.043(ln(X))2 ,
ln(Y2) = 1 1.723 + 0.31 lln(X) + 0.019(ln(X))2
to(Y3) = -0.912 + 1.1201n(X) + 0.01 10n(X))2
6.6 E -3 to 5.0
3.0 E -4 to 5.0
1.4 E -2 to 5.0 •
Air Stripping
11.2.4
Air stripping is an effective wastewater
treatment method for removing dissolved gases and
volatile compounds from wastewater streams. The
technology passes high volumes of air through an
agitated gas-water mixture. This promotes
volatilzation of compounds, and, preferably
capture in air pollution control systems „
The air stripping-system costed by-EPA-
includes transfer pumps, control panels, blowers,
and ancillary equipment. EPA also- included
catalytic oxidizers as part of the system for air
pollution control purposes.
If a CWT facility currently has an air stripping
system in-place, EPA did not assign the facility any
costs associated with air stripping. EPA assumed
that the air stripping systems currently in-place at
CWT facilities would perform as well as (or better
than) the system costed by EPA.
CAPITAL COSTS
EPA's air stripping system is designed to
remove pollutants with medium to high volatilities.
EPA used the pollutant 1,2-dichloroethane, which
has a Henry's Law Constant of 9.14 E -4
atm*L/mol, as the design basis with an influent
concentration of 4,000 jig/L and an effluent
concentration of 68 ug/L. EPA based these
concentration on information collected on the
model facility's operation. EPA used the same.
design basis for the air stripping systems costed for
the option 8v and 9v in the oils subcategory.
EPA obtained the equipment costs from vendor
quotations. Table 11-13 at the end of this section
presents the capital cost equation for air stripping
systems.
OPERATION AND MAINTENANCE COSTS
For air stripping^ O&M costs mcludeelectriciiy,"
maintenance, labor, catalyst replacement, and taxes
and insurance. EPA obtained the O&M costs from
the same vendor which' provided the.,capitaT"cost'
estimates.
EPA based the electricity usage for the air
strippers on the amount of horsepower needed to
operate the system and approximated the electricity
usage for the catalytic oxidizers at 50 percent of the
electricity used for the air strippers. EPA based
both the horsepower requirements and the
electricity requirements for the catalytic oxidizer on
vendor's recommendations. EPA estimated the
labor requirement for the air stripping system at
three hours per day, which is based on the model
facility's operation. EPA assumed that the catalyst
beds in the catalytic oxidizer would require
replacement every four years based on the rule of
thumb (provided by the vendor) that precious metal
catalysts have a lifetime of approximately four
years. EPA divided the costs for replacing the
spent catalysts by.four to convert them to annual
costs. As is the standard used by EPA for this
industry, taxes and insurance were estimated at 2
percent of the total capital cost. Table 11-12
presents the resulting O&M cost equation for air
stripping systems.
11-19
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
Table 11-12. Cost Equations for Air Stripping
Description
Equation
Recommended Flow
' Rate Range(MGD)
Capital cost for air stripping
O&M cost for air stripping
Land requirements
ln(Yl) = 12.899 + 0.4861n(X) + 0.031(ln(X))2
ln(Y2) = 10.865 + 0.2981n(X) + 0.021(ln(X))2
ln(Y3) = -2,207-+ 0.5361n(X) + 0.042(lnCX))2
4.0 B^ to 1.0
8.5 E -4 to 1.0
0.1 to 1.0
Yl - Capital Costs (1989 $)
Y2=Operation and Maintenance Costs (1989 $ /year)'
Y3 = LandRequnement (Acres)
X=Row Rate (million gallons per day)
Multi-Media Filtration
11.2.5
Filtration is a proven technology for the
removal of residual suspended solids from
wastewater. The multimedia filtration system
costed by EPA for this industry is a system...
which contains sand and- anthracite coal,.
supported by gravel.
EPA based the design for the model-
multimedia filtration system on the TSS effluent"
long- term average concentration, for Metals
option 4—15 mg/L. EPA assumed that the
average influent TSS concentration to the
multimedia filtration system would range from 75
to 100 mg/L. EPA based the influent
concentration range on vendor's
recommendations on realistic TSS concentrations
resulting from wastewater treatment following
chemical precipitation and clarification.
EPA did not calculate capital or O&M
upgrade equations for multi-media filtration. If a
CWT facility currently has a multimedia filter in-
place, EPA assigned the facility no costs
associated with multi-media filtration: EPA
assumed that the multi-media filter currently in-
place at CWT facilities would perform as well as
(or better than) the system costed by EPA.
CAPITAL COSTS
EPA based the capital costs of multi-media
filters on vendor's recommendations. Table 11-
13 presents the resulting capital cost equation for
multi-media filtration systems.
CHEMICAL USAGE AND LABOR
REQUIREMENT COSTS
EPA estimated the labor requirement for the
multi-media filtration system at four-hours per
day, which is based on manufacturer's
recommendations. There are no chemicals
associated with the operation of a multimedia
filter. Table 11-1-3 presents -the O&M?-cost;
equation for the multi-media filtration- system.—
11-20
-------
Chanter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
Table 11-13. Cost Equations for Multi-Media Filtration
Description
Equation
How Rate
Range (MOD)
Capital cost for multi-media filtration
O&M cost for multi-media filtration
Land requirements
' ln(Yl) = 12.0126 + 0.480251n(X) + 0.04623(ln(X)f
ln(Y2) = 11.5039 + 0.724581n(X) + 0.09535(ln(X))2
ln(Y3) = -2.6569 + 0.193711n(X) + o:02496(ln(X))2
5.7 E -3 to 1.0
2.3 E -2 to 1.0
2.4 E -2 to 1.0
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X = How Rate (million gallons per day)
Cyanide Destruction
11.2.6
Many CWTs achieved required cyanide
destruction by oxidation.. These facilities
primarily use chlorine (in either the elemental or
hypochlorite form) as the oxidizing agent in this
process. Oxidation of cyanide with chlorine is
called alkaline chlorination. .,
The oxidation of cyanide waste using sodium-
hypochlorite is a two step process. In the first
step, cyanide is oxidized to cyanate in the
presence of hypochlorite, and sodium hydroxide
is used to maintain a pH range of 9 to 11. The
second step oxidizes cyanate to carbon dioxide
and nitrogen at a controlled pH of 8.5. The
amounts of sodium hypochlorite and sodium
hydroxide needed to perform the oxidation are
8.5 parts and 8.0 parts per part of cyanide,
respectively. At these levels, the total reduction
occurs at a retention time of 16 to 20 hours.
The application of heat can facilitate the more
complete destruction of total cyanide.
The cyanide destruction system costed by
EPA includes a two-stage reactor with a
retention time of 16 hours, feed system and
controls, pumps, piping, and foundation. The
two-stage reactor includes a covered tank, mixer,
and containment tank. EPA designed the system
based on a total cyanide influent concentration of
4,633,710 ug/L and an effluent concentration of
total cyanide of 135,661 ug/L. EPA based these
influent and effluent concentrations on data
collected during EPA's sampling oFcyanide
destruction systems.
Because the system used by the facility
which forms the basis of the cyanide limitations
and standards-uses special operation conditions,
EPA assigned fulLcapital-and O&M costs to -all
facilities which perform cyanide destruction.
CAPITAL COSTS . .
EPA obtained the capital costs curves for
cyanide destruction systems with special
operating conditions from vendor services. Table
11-14 presents the capital cost equation. ,
CHEMICAL USAGE AND LABOR
REQUIREMENT COSTS
In estimating chemical usage and labor
requirements, EPA assumed the systems would
treat one batch per day. . EPA based this
assumption on responses- to the WTI
Questionnaire. Based on vendor's
recommendations, EPA estimated the labor
requirement for the cyanide destruction to be
three hours per day. EPA determined the amount
of sodium hypochlorite and sodium hydroxide
required based on the stochiometric amounts to
maintain the proper pH and chlorine
concentrations to facilitate the cyanide
destruction as described earlier. Table 11-14
presents the O&M cost equation for cyanide
destruction.
11-21
-------
Chapter 11 Cost of Treatinent Technologies
Development Document for the CWT Point Snurrp Cntpvnr
Table 11-14. Cost Equations for Cyanide Destruction
Description
Equation
Recommended Flow
Rate Range (MOD)
Capital cost for cyanide destruction
O&M cost for cyanide destruction
Land requirements
ln(Y 1) = 13.977 + 0.5461n(X) + 0.0033(ln(X))2 1.0 E -6 to 1.0
ln(Y2) = 18.237 + 1.3181n(X) + 0.04993(ln(X))2 . 1.0 E -5 to 1.0
ln(Y3) = -1.168 + 0.4191n(X) + 0.021(ln(X))2 . 1.0 E -4 to 1.0
Yl - Capital Costs (1989 $)
Y2 ^ Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X=Row Rate (million gallons per day)
Secondary Gravity Separation
11.2.7 secondary gravity separation.
Primary gravity separation provides oil and
grease removal from oily wastewater. During
gravity separation, the wastewater is held, in,,
tanks under quiescent conditions long enough to
allow the oil droplets to rise and form a layer on
the surface,-where, itis, skimmedr*
Secondary, gravity^ separation systems
provide additional oil and grease removal for oily
wastewater. Oily wastewater, after primary
gravity separation/emulsion breaking, is pumped
into a series of skimming tanks where additional
oil and grease removal is obtained before the
wastewater enters the dissolved air flotation unit.
The secondary gravity separation equipment
discussed here consists of a series of three
skimming tanks in series. The ancillary
equipment for each tank consists of a mix tank
with pumps and skimming equipment.
In estimating capital and O&M cost
associated with secondary gravity separation,
EPA assumed that facilities either currently have
or do not have secondary gravity separation.
Therefore, EPA did not develop any secondary
gravity separation upgrade costs.
CAPITAL COSTS
EPA obtained the capital cost estimates for
the secondary gravity separation system from
vendor quotes. Table 11-15 at the end of this
section presents the capital cost equation for
CHEMICAL USAGE AND LABOR
' REQUIREMENT COSTS
EPA estimated the labor requirement to
operate secondary gravity "separation to be 3 to
9 hours per day-dependmg..on,the,,size_of.the,
system. EPA obtained this estimate from one of
the moderfacilities for Oils' option^.:. There-are.
no chemicals associated with the operation of the
secondary gravity separation system. Table 11 -
15 presents the O&M Cost equation for the
secondary gravity separation system.
11-22
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
Table 11-15. Cost Equations for Secondary Gravity Separation
Description
Equation
Recommended Flow
Rate Range (MOD)
Capital cost for secondary gravity separation ln(Yl) = 14.3209 + 0.387741n(X) - 0.01793(In(X))2
O&M cost for secondary gravity separation ln(Y2) = 12.0759 + 0:44011n(X) + 0.01544(ln(X))2
Land requirements' ln(Y3) = -0.2869 + 0.313871n(X) + 0.01191(ln(X))2
5.0 E -4 to 5.0
5.0 E -4 to 5.0
1.0 E-6 to 1.0
Yl= Capital Costs (1989$)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X=Flow Rate (million gallons per day)
Dissolved Air Flotation
1T.2.8
Flotation is the process of inducing
suspended particles to rise to the surface of a
tank where they can be collected'and removed.
Dissolved Air Flotation (DAF) is one of several
flotation techniques employed in the treatment of
oily wastewater. DAF is commonly used to
extract free and dispersed oil and grease from
oily wastewater.
CAPITAL COSTS
EPA developed capital cost estimates for
dissolved air flotation systems for the oils
subcategory options 8 and 9. EPA based the
capital cost estimates for the DAF units on
quotations from vendors. EPA assigned facilities
with DAF units currently in-place no capital
costs. For facilities with no DAF treatment in-
place, the DAF system consists of a feed unit, a
chemical addition mix tank, and a flotation tank.
EPA also included a sludge filtration/dewatering
unit. EPA developed capital cost estimates for a
series of flow rates ranging from 25 gpm (0.036
MOD) to 1000 gpm (1.44 MOD). EPA was
unable to obtain costs estimates for units with
flows below 25 gallons per minute since
manufacturers do not sell systems smaller than
those designed for flows below 25 gallons per
minute. .
The current DAF system capital cost
estimates include a sludge filtration/dewatering
unit. For facilities which do not have a DAF unit
in-place, but have other treatment systems that
produce sludge (i.e. chemical precipitation and/or
biological treatment), EPA assumed that the
existing sludge filtration unit could accommodate
the additional sludge produced by the DAF unit.
For these facilities, EPA did not include sludge
filtration/dewatering costs hi the capital' cost-
estimates. EPA refers to the capital cost equation
for these facilities as "modified" DAF costs.
Table 11-17 at the end of this section presents
the resulting total capital cost equations for the
DAF and "modified" DAF treatment systems.
Because the smallest design capacity for
DAF systems that EPA could obtain from
vendors is 25 gpm and since more than 75
percent of the oils subcategory facilities have
flow rates lower than 25 gpm, EPA assumed that
only facilities with flow rates above 20 gpm
would operate their DAF systems everyday (i.e.
five days per week). EPA assumed that the rest
of the facilities could hold their wastewater and
run their DAF systems from one to four days per
week depending on their flowrate. Facilities that
are not operating their DAF treatment systems
everyday would need to install a holding tank to
hold their wastewater until treatment. Therefore,
for facilities that do not currently have DAF
treatment in place and have flow rates less than
20 gallons per minute, EPA additionally included
costs for a holding tank. For these facilities, EPA
based capital costs on a combination of DAF
costs (or modified DAF costs) and holding tank
costs. Table 11-16A lists the capacity of the
11-23
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
holding tank costa
Table 11-16A Esti
for]
Howrate(GPM)
<5
5-10
10-15
15-20
>20
:d for various flowrates.
mate Holding Tank Capacities
DAF Systems
Holding Tank Capacity (gallons)
7,200
14,400
21,600
28,800
none
Table 11-16B. Estimate Labor .Requirements for
DAFSystems
Flowrate T , _ . . , , . . .
,_,_-., Labor Requirements (days/week)
<5
5-10
10-15
15-20
>20
1
2
3
.4
5
Table 11-17 at the end of this section presents
the resulting capital cost equation for the holding
tank associated with the DAF and modified DAF
systems.
CHEMICAL USAGE AND LABOR-
REQUIREMENT COSTS.-
EPA estimated the labor requirements
associated with the model technology- at four
hours per day for the,, small, systems to eight
hours per day for the large systems," which is
based on the average of the Oils options 8 and 9
model facilities. EPA used the same labor
estimate for DAF and "modified" DAF systems.
As discussed in the capital cost section, EPA
has assumed that facilities with flow rates below
20 gpm will not operate the DAF daily.
Therefore, for these lower flow rate facilities,
EPA only included labor to operate the DAF (or
"modified" DAF) systems for the days the
system will be operational. Table 11-16B lists
the number of days per week EPA assumed,
these lower flow facilities would operate their
DAF systems.
As detailed earlier, however, EPA also
assumed that facilities with flow rates below 20
gpm, would also operate a holding tank.
Therefore, for facilities with flow rates below 20
gallons per minute, EPA included additional labor
to operate the holding tank.
EPA-calculated chemical cost estimates for
DAF and "modified" DAF systems based on
additions • of alummum-sulfate,caustic soda, and
polymer. - EPA-costed for-facilities to add 550
mg/L alum, 335 mg/L polymer and 1680 mg/L
of NaOH. EPA also rncludecLcosls, for. perlite
addition at 0.25 Ibs per Ib of dry solids for sludge
conditioning and sludge dewatering operations
(for DAF, but not "modified" DAF systems).
EPA based the chemical additions on
information gathered from literature, the
database for the Industrial Laundries Industry
guidelines and standards, and sampled facilities.
Finally, similar to the labor requirements
shown hi table 11-16B, EPA based chemical
usage cost estimates for the DAF and modified
DAF systems assuming five days per week
operation for facilities with flowrates greater than
20 gpm and from one to four days per week for
facilities with flowrates of 5 to 20 gpm.
Table 11-17 at the end of this section
presents the four equations relating the various
types of O&M costs developed for DAF
treatment for facilities with no DAF treatment.
For facilities with DAF treatment in-place,
EPA estimated O&M. upgrade costs. . These
facilities would need to improve pollutant
11-24
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
removals from their current DAF current
performance concentrations to the Oils option 8
and option 9 long-term averages. As detailed in
Chapter 12, EPA does not have 'Current
performance concentration data for the majority
of the oils facilities with DAF treatment in-place.
EPA does, however, have seven long-term
sampling data sets which represent effluent
concentrations from, emulsion breaking/gravity
separation. While the pollutant concentrations in
wastewater exiting emulsion breaking/gravity
separation treatment are higher (in some cases,
considerably . higher) than the pollutant
concentrations in wastewater.. exiting.- DAE_
treatment, EPA has, nevertheless, used the
emulsion breaking/gravity separation long-term
sampling data sets to estimate DAF upgrade
costs. For each of the seven emulsion
breaking/gravity separation data sets, EPA
calculated the percent difference between these
concentrations and the option 8 and option 9
long-term averages. The median of these seven
calculated percentages is 25 percent.
Therefore, EPA estimated the energy, labor,
and chemical cost components of the O&M
upgrade cost as 25 percent of the full O&M cost
of a new system. EPA assumed that
maintenance, and taxes and insurance would be
zero since they .are functions of the capital cost
(that is, there is no capital cost for the upgrade)..
EP A developed two separate O&M upgrade cost
equations for facilities which currently have DAF
treatment in" place — one for facilities with
flowrates up to 20 gpm and one for facilities with
flow rates greater than 20 gpm. Table 11-17
presents the two equations representing O&M
upgrade costs for facilities with DAF treatment
in-place.
Table-1 r-171 Cost Equations for Dissolved Air Flotation (DAF) in Oils Options 8 and 9
Description
Equation-
Recommended Flow
Rate Range (MGD)-
Total capital cost for DAF to(Yl) =
Total capital cost for modified DAF to(Yl) =
Holding tank capital cost for DAF and ln(Yl) =
modified DAF'
O&M cost for DAF with flowrate above 20 ln(Y2) =
gpm
O&M cost for modified DAF with flowrate ln(Y2) =
above 20 gpm
O&M cost for DAF with flowrate up to 20 ln(Y2)
gpm
O&M cost for modified DAF with flowrate ln(Y2)
up to 20 gpm
O&M upgrade for DAF with flowrate below ln(Y2)
20 gpm
O&M upgrade for DAF with flowrate above ln(Y2):
20 gpm
Land required for holding tank' ln(Y3) •
Land required for DAF and modified DAF ln(Y3):
13.9518 + 0.29445Jn(X) - 0.12049(ln(X))2
= 13.509 + 0.294451n(X) - 0.12049(ln(X))2
= 12.5122 -0.155001n(X) -0.5618(ln(X))2
= 14:5532 + 0.964951n(X) + 0.01219(to(X))2
= 14.5396 + 0.976291n(X) + 0.01451(ln(X))2
=.21.2446 + 4.148231n(X) + 0.36585(to(X))2
= 21.2005 + 4.074491n(X) + 0.34557(In(X))2
= 19.0459 + 3.55881n(X) + 0.255530n(X))2
= 13.1281 + 0.997781n(X) + 0.01892(ln(X))2
= -1.0661 + 0.100661n(X) + 0.00214(ln(X))2
= -6.5107 + 0.512171n(X) - 0.01892(ln(X))2
0.036 to 1.44
0.036 to 1.44
5.0 E -4 to 0.05
0.036 to 1.44
0.036 to 1.44
7.2 E -3 to 0.029
7.2 E -3 to 0.029
7.2 E -3 to 0.029
0,036 to 1.44
5.0 E-4 to 0.05
0.036 to 1.44
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X = Flow Rate (million gallons per day)
'Only facilities with flow rates below 20 gpm receive holding tank costs.
11-25
-------
Chanter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
BIOLOGICAL WASTEWATER
TREATMENT TECHNOLOGY COSTS 11.3
SequencingBatchReactors 11.3.1
A sequencing batch reactor (SBR) is a
suspended growth system in which wastewater is
mixed with retained biological floe in an aeration
basin. SBR's are unique in that a single tank acts
as an equalization tank, an aeration tank, and a
clarifier.
The SBR system costed by EPA for the-
model technology consists of a SBR tank,
sludge handling equipment, feed system and
controls, pumps, .piping, blowers, and valves.
The design parameters that EPA used for the
SBR system were the average influent and
effluent BOD5, ammonia, and nitrate-nitrite
concentrations. The average influent
concentrations were 4800 mg/L, 995 mg/L, and
46 mg/L for BOD5, ammonia, and nitrate-nitrite,
respectively. The average effluent BOD5,
ammonia, and nitrate-nitrite concentrations used'
were 1,600 mg/1, 615.mg/l, and 1,0 mg/1,
respectively. EPA obtained these concentrations
from the sampling data at the SBR model
facility. EPA assumed that all existing
biological treatment systems in-place at organics
subcategory facilities can meet the limitations of
this rule without incurring cost. This includes
facilities which utilize any form of biological
treatment—not just SBRs. Therefore, the costs
presented here only apply to facilities without
• biological treatment in-place. EPA did not
develop SBR upgrade costs for either capital or
O&M.
Although biological treatment (SBR's)
systems can be used throughout the United
States, the design of the systems should vary due
to climate conditions. Plants in colder climates
should design their systems to account for lower
biodegradability rates during the colder seasons.
Therefore, EPA has taken these added costs into
accountin its costing procedures (see Section 3.1
of the Detailed Costing Document).
CAPITAL COSTS
EPA estimated the capital costs for the SBR
systems using vendor quotes which include
installation costs. Table 11-18 at the end of this
section presents the SBR capital cost equation.
OPERATION AND MAINTENANCE COSTS
The O&M costs-forthe SBR system-include
electricityrinaintenance, labor, and taxes and
insurance.. No chemicals are utilized in the SBR
system. EPA assumed- the labor- requirements-
for the SBR system to be four hours per day and
based electricity costs on horsepower
requirements. EPA obtained the labor and
horsepower requirements from- vendors; EPA
estimated maintenance, taxes, and insurance
using the factors detailed in Table 11-2. Table
11-18 presents the SBR O&M cost equation.
Table 11-18. Cost Equations for Sequencing Batch Reactors
Description
Equation
Recommended
Flow Rate
Range(MGD)
Capital cost for sequencing batch reactors
O&M cost for sequencing batch reactors
Land requirements
ln(Yl) = 15.707 + 0.5121n(X) + 0.0022(In(X))2
ln(Y2) = 14.1015 + 0.815671n(X) + 0.039320n(X))2
ln(Y3) = -0.531 + 0.9061n(X) + 0.072(ln(X))2
1.0 E -7 to 1.0
3.4 E-7 to 1.0
1.9 E -3 to 1.0
Yl = Capital Costs (1989$)
Y2 - Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X=How Rate (million gallons per day)
11-26
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
SLVDGE TREATMENT AND DISPOSAL
COSTS 1L4
Plate and Frame Pressure Filtration —
Sludge Stream 11.4.1
Pressure filtration systems are used for the
removal of solids from waste streams. This
section details sludge stream filtration which is
used to treat the~solids removed by the clarifiers
in the metals options.
The pressure filtration system costed by
EPA for sludge stream filtration consists of a
plate and frame filtration system. The
components of the plate and frame filtration
system include: filter plates, filter cloth, hydraulic
pumps, pneumatic booster pumps, control panel,
connector pipes, and a support platform. For
design purposess EPA assumed the sludge stream
to consist of 80 percent liquid and 20 percent
(200,000 mg/l)"solids. EPA additionally assumed
the sludge stream to be 20 percent of the total
volume of wastewater treated. EPA based these
design parameters on CWT Questionnaire 105.
. In costing for sludge stream treatment, if a
facility does not have sludge filtration systems in-
place, EPA estimated capital costs to add a plate
and frame pressure filtration system to their on-
site treatment train2. If a facility's treatment train
includes more than one clarification step in its
treatment train (such as for Metals option 3),
EPA only costed the facility for a single plate and
frame filtration system. EPA assumed one plate
and frame filtration system could be used to
2BF a facility only had to be costed for a
plate and frame pressure filtration system fo
process the sludge produced during the tertiary
chemical precipitation and clarifications steps of
metals Option 3, EPA did not cost the facility for
a plate and frame pressure filtration system.
Likewise, EPA assumed no O&M costs
associated with the treatment of sludge from the
tertiary chemical precipitation and clarification
steps in Metals Option 3. EPA assumed that the
total suspended solids concentration at this point
is so low that sludge stream filtration is
unnecessary.
process the sludge from multiple clarifiers.
Likewise, if a facility already had a sludge
filtration system in-place, EPA assumed that the .
in-place system would be sufficient and did not
estimate any sludge filtration capital costs for
these facilities.
CAPITAL COSTS '
EPA developed the capital cost equation for
plate and frame sludge filtration by adding
installation, engineering,.and contingency-costs to_,
vendors' equipment cost estimates. EPA used
the same capital cost equation for the plate and
frame sludge filtration system for all of the
metals options. Table 11-19 presents the plate
and frame sludge filtration system capital cost
equation.
• - - - OPERATION AND MAINTENANCE COSTS
• The operation and maintenance costs for
metals option 2- and 3 plate and frame sludge
filtration consist -of labor, electricity,
maintenance, and taxes and insurance. EPA
approximated the labor requirements for the plate
and frame sludge filtration system to be thirty
minutes per batch based on the Metals option 2
and 3 model facility. Because no chemicals are
used with the plate and frame sludge filtration
units, EPA did not include costs for chemicals.
EPA estimated electricity; maintenance, and-
taxes and insurance using the factors listed in
Table 11-2. Table 11-19 lists the resulting plate
and frame sludge filtration O&M cost equation.
For facilities which already have a sludge
filtration system in-place, EPA included plate and
frame filtration O&M upgrade costs. Since the
sludge generated from the secondary
precipitation and clarification steps in metals
option 2 and 3 is the sludge which requires
treatment for these options, these facilities would
be required to improve pollutant removals from
their secondary precipitation current performance
concentrations to the long term averages for
Metals options 2. Therefore, EPA calculated the
11-27
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
percent difference between secondary
precipitation current performance and the Metals
option 2 long-term averages. EPA determined
this percentage to be an increase of three
percent.
As such, for facilities which currently have
sludge filtration systems in place, for metals
option 2 and 3, EPA included an O&M upgrade
cost which is three percent of the O&M costs of
a new system (except for taxes and insurance,
which are a function of the capital cost). Table
11.19 presents the O&M upgradexosLequation.
for sludge filtration in Metals option 2 and option
3.
OPERATION AND MAINTENANCE COSTS
METALS OPTION 4
The operation and maintenance costs for •
metals option 4 consists of labor, chemical
usage, electricity,' maintenance, taxes, and"
insurance, and filter cake disposal. The O&M
plate and fiame sludge filtration costing
methodology for Metals option 4 is very similar
to the one discussed previously for Metals option
2 and 3. The primary differences in the
methodologies are the estimation of labor, the
inclusion of filter cake disposal, and the G'&M
upgrade methodology.
EPA approximated the labor requirement for
Metals option 4 plate and frame sludge filtration
systems at 2 to 8 hours per day depending on the
size of the system. As was the case for metals
option 2 and 3, no chemicals are used in the
-plate and frame sludge filtration units for metals
option 4, and EPA estimated electricity,
maintenance and taxes and insurance using the
factors listed in Table 11-2. EPA also included
filter»cake disposal costs at $0.74 per gallon of
filter cake. A detailed discussion of the basis-for
the filter cake disposal costs is presented in~
Section 11.4.2. Table 11-19 presents the O&M
cost equation,rfor- ,sludge.xfiltration= fot Metals--
option 4.
Table 11-19. Cost Equations-for-P/ate and Frame Sludge Filtration in Metals Options 2,3 and 4
Description
Equation
Recommended Flow
Rate Range (MOD)
Capital costs for plate and fiame sludge
filtration
O&M costs for sludge filtration for Metals
Option 2 and 3/i5
O&M costs for sludge filtration for Metals
Option4
O&M upgrade costs for sludge filtration for
•Metals Option 23A5
O&M upgrade cost for sludge filtration for
Metals Option 4*
Land requirements for sludge filtration
ln(Yl) = 14.827 + 1.0871n(X) + 0.0050(ln(X))2
ln(Y2) = 12.239 + 0.3881n(X) + 0'.016Qn(X))2
ln(Y2) = 15.9321 + 1.1771n(X) + 0.04697(ln(X))2
ln(Y2) = 8.499 + 0.33 lln(X) + 0.013(ln(X))2 ,
ln(Y2) = 12.014 + 1.178461n(X) + 0.050(In(X))2
ln(Y3) = -1.971 + 0.2811n(X) + 0.018(ln(X))2
2.0 E-5 to 1.0
2.0 E-5 to 1.0
1.0 E-5 to 1.0
2.0 E -5 to 1.0
1.0 E-5 to 1.0
1.8 E-3 to 1.0
Yl = Capital Costs (1989$)
.Y2 = Operation and Maintenance Costs (1989$/year) • •
Y3 — Land Requirement (Acres)
X=Flow Rate (million gallons per day)
'Following secondary chemical precipitation/clarification only. EPA assumed -the sludge generated from
tertiary precipitation/clarification would not be a significant quantity.
•'This equation does not include filter cake, disposal costs.
''This equation includes filter cake disposal costs.
11-28
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
For facilities which ahready have a sludge
filtration system in-place, EPA included sludge
stream filtration O&M upgrade costs, For
Metals option 4, EPA included these O&M
upgrade costs for processing the sludge generated
from the primary precipitation and clarification
steps3. These facilities would need to improve
pollutant removals from their primary
precipitation current performance concentrations
to Metals option 4 (Sample Point - 03)
concentrations. This sample point represents the,_
effluent from the liquid-solids separation unit
following primary chemical precipitation at the
Metals-option 4 model facility. Therefore, EPA
calculated the percent difference between
primary precipitation current performance
concentrations and Metals option 4 (Sample
Point - 03) concentrations. EPA determined that
there was an increase of two percent.
As-such, for facilities..which currently,have
sludge filtration systems in place, for metals
option-4fEPA~included"an O&M'cost Upgrade of"
two percent of the total O&M costs (exceptibr
taxes and insurance, which are a function of the
capital cost). Table 11-19 presents the O&M
upgrade cost equation for sludge filtration for
Metals option.
Filter Cake Disposal
11.4.2
The liquid stream and sludge stream pressure
filtration systems presented in Sections 11.2.3
and 11.4.1, respectively, generate a filter cake
residual. There is an annual O&M cost that is
associated with the disposal of this residual. This
cost must be added to the pressure filtration
equipment O&M costs to arrive at the total
O&M costs for pressure filtration operation4. .
To determine the cost of transporting and
disposing filter cake to an off-site facility, EPA
performed an analysis on a subset of
questionnaire respondents in the WTI
Questionnaire response database. This subset
consists of metals subcategory facilities that are
direct and/or indirect dischargers and that
provided information on contract haul and .
disposal cost to hazardous (Subtitle C) and non-
. hazardoustSubtitle D) landfills. From this set of
responses, EPA tabulated two sets of costs —
those reported for Subtitle C contract haul and
disposal and those reported for Subtitle D
contract haul and disposal, the reported costs for
both the Subtitle C and Subtitle D contract
haul/disposal. EPA then edited this information
by excluding data that was incomplete or that
was not separated by RCRA classification.
EPA used the reported costs information-in
this data set to determine the median, .cost for
both-the Subtitle C'and Subtitle D disposal
options, and then calculated the weighted
average of these median costs. The average was
weighted to reflect the ratio of hazardous (67
percent) to nonhazardous (33 percent) waste
receipts at these Metals Subcategory facilities.
The final disposal cost is $0.74 per gallon of
filter cake.
EPA calculated a single disposal cost for
filter cake using both hazardous and non-
hazardous landfilling costs. Certain facilities will
incur costs, however, that, in reality, are higher
and others will incur costs that, in reality, are
lower. Thus, some low revenue metals
subcategory facilities that generate non-
hazardous sludge may show a higher economic
burden than is representative. On the other
hand, some low revenue metals subcategory
facilities that .generate hazardous sludge may
3 EPA did not include O&M upgrade
costs for the sludge generated from the secondary
precipitation and clarification step (direct
dischargers only).
4Note that these costs have already been
included in the O&M equation, for plate and frame
sludge filtration for Metals Option 4.
11-29
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
show a lower economic burden than is
representative. EPA has concluded that in the
end, these over- and under estimates will balance
out to provide a representative cost across the
industry.
Table 11-20 presents the O&M cost
equation for filter cake disposal for Metals option
2 and option 3. Table 11-20 additionally
presents an O&M upgrade for filter cake
disposal resulting from Metals option 2 and
option 3 for facilities that already generate filter
cake as part of their operation.
This upgrade is 3 percent of the cost of the
O&M upgrade for facilities that do not already
generate filter cake as a part of their operation.
EPA used 3 percent because this was the same
percentage calculated for plate and frame sludge
filtration for these same options.
Table 11-20. Cost Equations for Filter Cake Disposal for Metals Options 2 and 3;
Description
Equation
Recommended Flow
Rate Range (GPM)
O&M cost for filter cake disposal
O&M upgrade for filter cake disposal
Z = 0.109169 + 7,695,499.8(X)
Z = 0.101186 + 230,879.8(X)
1.0 E -6 to 1.0
1.0 E -6 to 1.0
Z - Filter Cake Disposal Cost (1989 $ / year)
X~ Flow Rate (million gallons per day) _, ..
'Filter cake disposal costs for Metals Option 4 are included in the sludge filtration equations.
ADDITIONAL COSTS
Retrofit Costs
11.5
11.5.1
EPA assigned costs to the CWT Industry on
both an option- and facility-specific basis. The
option-specific approach estimated compliance
cost for a sequence of individual treatment
technologies, corresponding to a particular
regulatory option,, for a subset of facilities
defined as belonging to that regulatory
subcategory. Within the costing of a specific
regulatory option, EPA assigned treatment
technology costs on a facility-specific basis
depending upon the technologies determined to
be currently in-place at the facility.
Once EPA determined that a treatment
technology cost should be assigned to a particular
facility, EPA considered two scenarios. The first
was the installation of a new individual treatment
technology as a part of a new treatment train.
The full capital costs presented in Subsections
11.2 through 11.4 of this document apply to this
scenario. The second scenario was the
installation of a new individual treatment
technology- which-would-have-to be- integrated
into an existing in-place treatment train. For
these facilities, EPA applied retrofit costs.
These retrofit costs cover such items as piping
and structural modifications which would be
required in .an existing piece of equipment to
accommodate the installation of a new piece of
equipment prior to or within an existing treatment
train.
For all facilities which received retrofit costs,
EPA added a retrofit factor of 20 percent of the
total capital cost of the newly-installed or
upgraded treatment technology unit that would
need to be integrated into an existing treatment
train. These costs are in addition to the specific
treatment technology capital costs calculated with
the technology'specific equations described in
earlier sections. '
11-30
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
Monitoring Costs
11.5.2
CWT facilities that discharge process
wastewater directly to a receiving stream or
indirectly to a POTW will have monitoring costs.
EPA regulations require both direct discharge
with NPDES permits .and indirect dischargers
subject to categorical pretreatment standards to
monitor their effluent.
EPA used the following generalizations to
estimate the CWT monitoring costs:
1. EPA included analytical cost for parameters
at each subcategory as follows:
•TSS, O&G, Cr+6, total CN, and full
metals analyses for the metals subcategory
direct dischargers, and Cr+6, total CN,
and full metals analyses for the metals
subcategory indirect dischargers;
• TSS, O&G, and full metals and serni-
volatiles analyses for the oils subcategory
option 8 and 9 direct dischargers, and full
metals, and semi-volatiles for oils
- subcategory- options 8 and 9 ; indirect
dischargers;
• TSS, O&G, and full metals, volatiles and
semi-volatiles analyses for the oils
subcategory direct dischargers, and full
metals, volatiles, and semi-volatiles for oils
subcategory option 8V and 9V indirect
dischargers;
• TSS, BOD5, O&G, 6 individual metals,
volatiles, and semi-volatiles analyses for
the organics subcategory option 3 'direct
dischargers, and 6 individual metals,
volatiles, and semi-volatiles analyses for
the organics subcategory option 3 indirect
dischargers; and~
• TSS, BOD5, O&G, 6 individual metals,
and • semi-volatiles analyses for the
organics subcategory option 4 direct
dischargers, and 6 individual metals and
semi-volatiles analyses for the organics
subcategory, option 4 indirect disehargersr-
EP A notes that these analytical costs may be
overstated for the oils and-the organics
subcategories because EPA's final list of
regulated pollutants for these subcategories do
not include all of the parameters included above.
2. The monitoring frequencies are listed in
Table 11-21 and are as follows:
Table 11-21. Monitoring Frequency Requirements
Parameter
Conventionals*
Total Cyanide and Cr+6
Metals
Semi-Volatile Organics
Volatile Organics
Monitoring Frequency (samples/month)
Metals Subcategory
20
20
20
-
' -
Oils Subcategory
20
-
4
4
4**
Organics Subcategory
20
-
4
4
4** . -
*Conventional monitoring for direct dischargers only.
**Volatile organics monitoring for oils option 8V and 9V and organics option 3 only.
3. For faculties in multiple subcategories, EPA
applied full multiple, subcategory-specific
monitoring costs.
4. EPA based the monitoring costs on the
number of outfalls through which process
wastewater is discharged. EPA multiplied
11-31
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
the cost for a single outfall by the number of
outfalls to arrive at the total costs for a
facility. For facilities for which this
information is not available, EPA assumed a
single outfall per facility.
5. EPA did not base monitoring costs on flow
rate.
6. EPA did not include sample collection costs
(labor and equipment) and sample shipping
costs, and
7. The monitoring cost (based on frequency
and analytical methods) are incremental to
the monitoring currently being incurred by
the CWT Industry. EPA applied credit to
facilities for current momtoring^in-pjace
(MIP). For facilities- where actual
monitoring frequencies are unknown, EPA
estimated monitoring frequencies based on
other subcategory facilities with known
monitoring frequencies. ,
Table 11-22 shows the cost of the analyses
needed to determine compliance for the CWT
pollutants. EPA obtained these costs from actual
quotes given by vendors and converted to 1989
dollars using the ENR's Construction Cost Index.
Table 11-22. Analytical Cost Estimates
Analyses
BOD5
TSS
O&G
Cr+6
Total CN
Metals:
Total (27 Metals)
Per Metal1
Volatile Organics (method 1624)2
Semi-volatile Organics (method
1625)2
Cost
($1989)
$20
$10
$32
$20
$30-
$335
$335
$35
$285
$615
'For 10 or more metals, use the full metals
analysis cost of $335.
2There is no incremental cost per compound for •
methods 1624 and 1625 (although theremay be-a-
slight savings if the entire scan does not have to -
be reported). Use the full method cost, regardless
of the actual number of constituent parameters
required. . .
Land Costs
11.5.3
An important factor in the calculation of
treatment technology costs is the value of the
land needed for the installation of the technology.
To determine the amount of land required for
costing purposes, EPA calculated the land
requirements for each treatment technology for
the range of system sizes. EPA fit these land
requirements to a curve and calculated land
requirements, in acres, for every treatment
system costed. EPA then multiplied the
individual land requirements by the
corresponding state land cost estimates to obtain
facility-specific cost estimates.
EPA used different land cost estimates for
each state rather than a single nationwide average
since land costs may vary widely across the
country. To estimate land costs for each state,
EPA obtained average land costs for suburban
sites for each state from the 1990 Guide to
Industrial and Real Estate Office Markets
11-32
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
survey. EPA based these land costs on
"unimproved sites" since, according to the
survey, they are the most desirable.
The survey additionally provides land costs
broken down by size ranges. These are zero to
10 acres, 10 to 100 acres, and greater than 100
acres. Because CWT facilities fall into all three
size ranges (based on responses to the WTI
Questionnaire), EPA averaged the three size-
specific land costs for each state to arrive at the
final land costs for each state.
The survey did not provide land cost
estimates for Alaska, Idaho, Montana, North
Dakota, Rhode Island, South Dakota, Utah,
Vermont or West Virginia. For these states,
EPA used regional averages of land costs, EPA
determined the states comprising each region also
based on the aforementioned survey since the
survey categorizes the states by geographical
region (northeast, north central, south, and
west). In estimating the regional average costs
for the western region, EPA did not include
Hawaii since Hawaii's land cost is high and
would have skewed the regional average.
Table 11-23 lists the4and-cost-per acre^for
each state. As Table 11-23 indicates, the least
expensive state is Kansas with a land cost of
$7,042 per acre and the most expensive state is
Hawaii with a land.cost of $1,089,000 per acre.
table 11-23. Slate Land Costs for the CWT Industry Cost Exercise
State
Alabama
Alaska*
Arizona
Arkansas
• California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho*
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana*
Land Cost per Acre (1989 $)
0.00
0.00
0.00
o.oo-"-
0.00
0.00
0.00
0.00
0.00
0.00
1,089,000
81,105 .
36,300
21,078
8,954
7,042
29,040
56,628
19,602
112,530
59,895
13,649
21,054
• 13,068
39,930
81,105
State
Nebraska
Nevada
New Hampshire •
New Jersey- -
New Mexico
New York
North Carolina
North Dakota*
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island*
South Carolina
South Dakota*
Tennessee
Texas
Utah*
Vermont*
Virginia
Washington
West Virginia*
Wisconsin
Wyoming*
Washington DC
Land Cost per Acre (1989 $)
24,684
36,300
52,998
89,443
26,929
110,013 .
33,880
. 20,488
14,578
24,321
50,820
32,307
. 59,822
21,296
20,488
20,873
47,674
81,105
. 59,822
39,930
• 63,670
47,345
17,424
81,105
174,240
* No data available for state, used regional average.
11-33
-------
Chapter 11 Cost of Treatment Technologies
Development'Document for the CWTPoint Source Category
EXAMPLE J1-1:
Costing exercise for direct discharging metals subcategory facility with treatment in-place.
Example Facililv Information:
Current Treatment In-Place:
Primary Chemical Precipitation + Clarification+Plate and Frame Sludge Filtration
Daily How = .0,12196 MOD (Miliion,GaUons/Day)
[NOTE: Daily Flow=X in costing equations]
Treatment Upgrades To Be Costed:
Primary Chemical Precipitation Upgrade -f- Clarifier Upgrade + Sludge Filtration Upgrade
Full Treatment Technologies To Be Costed:
Secondary Chemical Precipitation + Secondary Clarification+Multimedia Filtration
Section.1 1.2.1.4
Section 11. 2:13"
Section 11.4.1.1
Figure 11-1. Metals Option 4 Model Facility Diagram
11-34
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
EXAMPLE 11-1, CONTINUED:
Capital Costs: •
• Primary chemical precipitation wpgraJe, from Table 11-7, Section 112.1.4.
The maximum size holding tank to be costed for a primary chemical precip.
upgrade is 0.005 MOD. In addition, there is a 20% retrofit cost for the upgrade.
In(Yl) = 10.671 -0.083*In(X)-0.032*(h(X))2
= 10.671 - 0.083*ln(0.005) - 0.032*(ln(0.005))2
= 10.212
.-. Yl =$27,240.25* 1.2 = $321688.30*
• Clarification capital cost z/pgrarfe, following primary precipitation = $0.00 *
• Sludge filtration capital cost upgrade = $0.00 *
• Secondary chemical precipitation, full capital costs, fromJable 11-8, Section 11.2.1.5
ln(Yl) = 13.829 + 0.544*ln(X) + 4.96E-6*(ln(X))2
= 12.68441
/. Yl" . = $322,678.63 *
• Clarification, following secondary chemical precipitation, from Table 11-9, Section
11.2.2.2
=1 1.552 + 0.409*ln(X) + 0.020*(ln(X))2
= 10.77998 :
Yl =$48,049.17* •
Multi-media filtration capital costs, from Table 1 1-13, Section 1 1.2.5
ln(Yl) = 12.0126 + 0.48025*ln(X) + 0.04623*(ln(X))2
= 11.20679
Yl =$73,628.54*
Total capital cost (TCC)
TCC =£(Thdividual Capital Costs)
TCC = $477,045 •
11-35
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
EXAMPLE ll-l, CONTINUED: .
Operation and Maintenance Costs:
• Primaiy chemical precipitation O&M upgrade, from Table 1 1-7, Section 1 1 .2. 1 .4
In(Y2) = 11.6203 + 1.05998*ln(X) + 0.04602*(ln(X))2
= 11.6203 + 1.05998*ln(0.12196) + 0.04602*(ln(0.12196))2
= 9.59377
.-. Y2 =$14,673.09*
• Clarification O&M upgrade, following primary chemical precipitation, from Table 11-9,
Section 1122
ln(Y2) = 6.81347 + 033'l49*ln(X) + 0.0242*(ln(X))2
= 6.22313
/. Y2 =$50428*
Sludge filtration O&M upgrade, from Table 1 1-19, Section 1 1.4.1
ln(Y2) = 12.014 +1.17846*ln(X) + 0.05026*(ln(X))2
= 9.75695
Y2 =$17273.90* (which incluSes filter cake disposal costs)
Secondary chemical precipitation O&M costs, from Table 11-8, Section 1 1 2. 1 .5
In(Y2) = 12.076 + 0.63456*lnCX) + 0.03678*(lri(X))2
= 10.9037
Y2 =$54,375.79*
Clarification O&M costs, following secondary chemical precipitation, from Table 11-9,
Section 11222
ln(Y2) = 10.673 + 0238*ta(X) + 0.013*
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category •
EXAMPLE 11-1, CONTINUED:
Land Requirements:
• Primary chemical precipitation upgrade land requirement associated with capital cost
upgrade (Table 11-7, section 112.1.4). The maximum size holding tank to be costed for
a primary chemical precipitation upgrade is 0.005 MGD.
ln(Y3) =-2.866-0.0231n(X)-0.006(ln(X))2
=-2.866 - 0.0231n(0.005) - 0.006(ln(0.005))2
= -2.913
.-. Y3 = 0.054 acre*
• Clarifier, following primary chemical precipitation, land requirement = 0.0 acre*
• Sludge filtration unit land requirement = 0.0 acre*
• Secondary chemical precipitation land requirement, from Table 11-8, Section 112.1.5
ln(Y3) =-L15 + 0.449*ln(X) + 0.027*(ln(X))2
' ....' =-1.975
.'. . Y3-~ , —0.-l-39-aer&*-
•- - Glaiification, following secondary chemical precipitation, land requirement, from Table 11-
' . 9,~Sectionl 1.2.2.2
ln(Y3) = -1.773 + 0.513*ta(X) + 0.046*(ln(X))2
= -2.6487
.-. Y3 =0.071 acre*
• Multimedia filtration land requirement, from Table 11-13, Section 112.5
ln(Y3) =-2.6569+ 0.1937*ln(X) + 0.02496*(ln(X))2
= -2.95396
.-. Y3 =0.0521 acre*
« Total land requirement (ILR)
TLR =Y, (Individual Land Requirement)
.-. TLR =0.316 acre •
11-37
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
EXAMPLE 11-2:
Costing exercise for a direct discharging oils subcategory facility with only emulsion
breaking/gravity separation in-place. »
Sample Facflity Information:
Current Treatment In-Place:
Primary Emulsion Breaking/Gravity Separation
Daily Row = 0.0081 MOD (MMon Gallons/Day) [= 5.63 gpm]
[NOTE: Daily Flow=X in costing equations]
Treatment Upgrades-To Be Gosted-
None , .
Full Treatment Technologies To Be Costed
Secondary Gravity Separation + Dissolved Air Rotation (DAF)
Seotaax 11.2.8
Section 11.2.9
Deserved Air
Flotatim
Figure 11-2. Treatment Diagram For Oils Option 9 Facility Improvements
11-38
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
EXAMPLE 11-2, CONTINUED:
Capital Costs:
Secondary gravity separation, from Table 11-15, Section 1 1 .2.7
ln(Yl) = 14.3209 + 0.38774*ln(X)-0.01793*(ln(X))2
= 14.3209 -0.38774*ln(0.0081)-0.01793*(ln(0.0081))2 .
= 12.0377
Yl =$169,014:42-*-
Dissolved air flotation costs, from Table 11-17, Section 11.2.8
ln(Yl) = 13.9518 + 029445*ln(X) - 0.12049*(Tn(X))2
= 11.6415
Yl' =$113,720.41*
Holding tank for dissolved air flotation (flow < 20 gpm, hence holding tank is sized),
from Table 11-17, Section 11.2.8
ln(Yl) = 12.5122 -0.15500*In(X).-0.05618*(ln(X))2 _ - .
= 11.9557
Yl = $155,700.75 «•
Total capital cost (T-CC) • •
TCC =£ (Individual Capital Costs)
TCC = $438,436 •
11-39
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
EXAMPLE 11-2, CONTINUED:
Operation and Maintenance Costs:
• Secondary gravity separation, from Table 11-15, Section 11.2.7
ln(Y2) = 12.0759 + 0.4401*ln(X) + 0.01594*(Tn(X))2
= 12.0759 + 0.4401*ln(0.0081) + 0.01594*(Tn(0.0081))2
= 10.3261
Y2 =$30,519.46 +
• Dissolved air flotation (flow < 20 gpm), from Table 11-17, Section 112.8
In(Y2) = 212446 + 4.14823*ta(X) + 0.36585*(In(X))2
= 9.7523
Y2 = $17,193.12 •»•
• Total Operation and Maintenance Cost (O&MTot),
O&MTot = £ (Individual Q& M Costs)
O&MTol= 847,713 •
11-40
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
EXAMPLE 11-2, CONTINUED:
Land Requirements:
• Secondaiy gravity separation, Table 11-15, Section 11.2.7
ln(Y3) = -0.2869 + 0.31387*ln(X) + 0.01191*(ln(X))2
= -0.2869 + 0.31387*ln(0.0081) + 0.01191*(ln(0.0081))2
= -1.5222
Y3 =0.218 acre*
• Dissolved air flotation (sized at 25 gpm, the minimum available), from Table 11-17,
Section 11.2.8 : ' ' '
ln(Y3>- =-0:5107+ 0.51217*ln(X)-0.01892*(]n(X))2 _. - •
= -2.4224
Y3 =0.089 acre*
• Holding tank, from Table 11-17, Section-l.L2.8- • ....
ln(Y3) =-1.5772+ 0.35955*ln(X) + 0.02013*(ln(X))2
= -1.5012
Y3 =0.223 acre* . -
• Total land requirement"(TLR)
TLR , =£ (Individual Land Requirement)
TLR =0.53 acre •
11-41
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
REFERENCES 11-6
Standard Methods for Examination of Water and Wastewater, 15* Edition, Washington, DC.
Henricks, David, Inspectors Guide for Evaluation of Municipal Wastewater Treatment Plants.
CulpAVesnei/Culp, El Dorado Hills, CA, 1979.
Technical Practice Committee, Operation of Wastewater Treatment Plants. MOP/11, Washington, DC, 1976.
Clark, Viesman, and Hasner, Water Supply and Pollution Control Harper and Row Publishers, New York, NY,
1977.
1991 Waste Treatment Industry Questionnaire Respondents Data Base. U. S. Environmental Protection
Agency, Washington, DC.
Osmonics, Historical Perspective of Ultrafiltration and Reverse Osmosis Membrane Development.
Minnetonka, MM, 1984.
Organic Chemicals and Plastics and Synthetic Fibers fOCPSF) Cost Document. SAIC. 1987.
Effluent Guidelines Division, Development Document For Effluent Limitations Guidelines and Standards for
the Organic Chemicals. Plastics and Synthetic Fibers (OCPSF). Volume n, Point Source Category, EPA
440/1-87/009, Washington, DC, October 1987.
Engineering News Record (ENRX McGraw-Hill New York. NY. March 30.1992.
Comparative Statistics of Industrial and Office Real Estate Markets. Society of Industrial and Office Realtors
of the National Association of Realtors, Washington, DC, 1990.
Peters, M, and Timmerhaus, K., Plant Design and Economics for Chemical Engineers. McGraw-Hill, New
York, NY, 1991.
Chemical Marketing Reporter. Schnell Publishing Company, Inc., New York, NY, May 10,1993.
Palmer, SJC, Breton, MA., Nunno, TJ., Sullivan, D.M., and Supprenaut, N.F., Metal/Cyanide Containing
Wastes Treatment Technologies. Alliance Technical Corporation, Bedford, MA, 1988.
Freeman, HJVT., Standard Handbook of Ha2ardous Waste Treatment and Disposal U.S. Environmental
Protection Agency, McGraw-Hill, New York, NY, 1989.
Development Document for the Proposed Effluent Limitations Guidelines and Standards for the Metal
Products and Machinery Phase 1 Point Source Category. U.S. Environmental Protection Agency, EPA 821-R-
95-021, April 1995. . .
Control and Treatment Technology for the Metal Finishing Industry. Sulfide Precipitation. Summary Report
EPA 625/8-80-003, April 1980.
11-42
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
SUMMARY OF COST OF TECHNOLOGY
OPTIONS
11.7
This section summarizes the estimated
capital and annual O&M expenditures for CWT
facilities to achieve each of the effluent
limitations and standards. All cost estimates in
this section are expressed in terms of 1997
dollars.
BPTCosts
11.7.1
BPT costs apply to all CWT facilities that
discharge wastewater to surface waters (direct
dischargers). Table 11-24 summarizes, by
subcategory, the total capital expenditures and
annual O&M costs for implementing BPT.
Table 11-24. Cost of Implementing BPT Regulations [in 1997 dollars]
Subcategory
Metals Treatment and-Recovery^
Oils Treatment and Recovery
Organics Treatment
Multiple Wastestream Subcategory:
Combined Regulatory Option*
Number of
Facilities''
9
5
4
3
14
Total Capital
Costs
4,069,600
1,168,100
80,000
1,836,200
5,317,700
Annual O&M Costs
3,103,200
432,100
215,800
3,618,300
3,751,100
'There are 14 direct dischargers. Because some direct dischargers include operations in more than one
subcategory, the sum of the facilities with operations in any one subcategory exceeds the total number of
facilities.
2 This estimate assumes that all facilities that accept waste in multiple subcategories elect to comply with the
single Subcategory limitations.
3 This total assumes that 'all facilities that accept waste in multiple subcategories elect to comply with each
set of limitations separately.
EPAnotes that this BPT cost summary does
not include the additional capital costs of the
second clarifier that may be associated with the
transferred TSS limitations for the metals
subcategory. EPA will re-visit its BPT costs
estimates for this subcategory prior to
promulgation.
PSESCosts
11.7.3
BCT/BAT Costs
11.7.2
The Agency estimated that there would be
no incremental cost of, compliance for
implementing BCT/BAT, because the technology
used to develop BCT/BAT limitations is identical
to BPT and the costs are included wjth BPT.
The Agency estimated the cost for
implementing PSES applying the same
assumptions and methodology used to estimate
cost of implementing BPT. The major
difference is that the PSES costs are applied to
all CWT facilities that discharge wastewater to a
POTW (indirect dischargers). Table 11-25
summarizes, by subcategory, the capital
expenditures and annual O&M costs for
implementing PSES.
11-43
-------
Chapter 11 Cost of Treatment Technologies
Development Document for the CWTPoint Source Category
Table 11-25. Cost of Implementing PSES Regulations [in 1997 dollars]
Subcategoiy
Metals Treatment and Recovery
Oils Treatment and Recovery -
Organics Treatment
Mutliple Wastestream Subcategoiy2
Combined Regulatory Option3
Number of
' Facilities7
44
127
16
24
151
Total Capital
Costs
11,111,100
23,834,000
17,709,200
44,576,100
52,654,300
Annual O&M Costs
10,242,100
12,484,400
2,766,200
20,392,700
25,792,700
'There are 151 indirect dischargers. Because some indirect dischargers include operations in more than one
subcategory, the sum of the facilities with operations in any one subcategory exceeds the total number of
facilities.
3 This estimate assumes that all facilities that accept waste in multiple subcategories elect to comply with the
single Subcategoiy limitations.
3 This total assumes that all facilities that accept waste in multiple subcategories elect to comply with each
set of limitations separately.
11-44
-------
Chapter
12
POLLUTANT LOADING AND REMOVAL ESTIMATES
INTRODUCTION
12.1
This chapter presents annualpollutant loading
and removal estimates for the CWT
industry associated with each of the
subcategories and regulatory options considered
by EPA in developingthe effluent limitations and
pretreatment standards. EPA estimated the
pollutant loadings and removals from CWT
facilities to evaluate the effectiveness of different
treatment technologies and to evaluate how
costly these regulatory options were in terms of
pollutant removals.- EPA, also., used this
information in analyzing potential benefits'from
the removal of pollutants discharged to surface
waters directly or indirectly through publicly
owned treatment works (POTWs), EPA
estimated raw, current, and post-compliance
pollutant loadings and pollutant removals for the
industry using data collected from the industry
throughout development of the rule. This
assessment uses the following definitions for
raw, current, and post-compliance pollutant
loadings:
• Raw loadings — For the metals and organics
subcategory, raw loadings represent CWT
waste receipts, that is, typically untreated
wastewater.as received from customers. For
the oils subcategory, raw loadings represent
the effluent from the initial processing of oil
bearing, CWT waste receipts, that is,
effluent from emulsion breaking and/or
gravity separation.
•. Current loadings — These are the pollutant
loadings in CWT wastewater that are
currently being discharged to POTWs and
surface waters. These loadings account for
wastewater treatment currently in place at
CWT facilities.
• Post-compliance loadings — These are the
pollutant loadings in CWT wastewater that
would be discharged to POTWs and surface
waters upon compliance with the rule. EPA
calculated these loadings assuming that all
CWT facilities would achieve treatment at
least equivalent to that which may be
achieved by employing the technology
option selected as the basis of rne limitations
or standards?-
The following information is presented in
this chapter:
• Section 12.2 summarizes the data sources
used to estimate pollutant loadings and
removals;
• Section 12.3 discusses the methodology used
to estimate current loadings;
• Section 12.4 discusses the methodology used
to estimate post-compliance pollutant
loadings;
• Section 12.5 discusses the methodology used
to estimate pollutant removals;
• Section 12.6 presents the pollutant loadings
and removals for each regulatory option,
including current and post-compliance
pollutant loadings.
DATA SOURCES
12.2
As previously explained in Chapter 2, EPA
primarily relied on four data sources to estimate
pollutant loadings and removals: industry
responses to the 1991 Waste Treatment Industry
Questionnaire, industry responses to the Detailed
12-1
-------
Chanter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
Monitoring Questionnaire, wastewater sampling
data collected by EPA, and data provided in
comments to the proposals. Chapter 2 of this
document discusses each of these data sources in
detail.
METHODOLOGY USED TO DEVELOP
CURRENT LOADINGS ESTIMA TES
12.3
EPA calculates current loadings for a specific
facility using the effluent flow rate of the facility
and the concentration of pollutants in its effluent
obtained from effluent monitoring data. EPA
does not have data for every facility in the
database to calculate current loadings. For some,
EPA has no effluent monitoring data, while for
others, EPA may have only limited monitoring
data for a few parameters. In some cases, EPA
has effluent monitoring-data, but the data do not
represent CWT wastewaters only. As discussed
previously, most CWT facilities commingle
CWT wastewaters with non-CWT wastewaters
such as industrial wastestreams or stormwater
prior to monitoring'for compliance. Most CWT
facilities with waste receipts in more than one
subcategory commingle CWT wastestreams prior
to monitoring for performance. Some facility
supplied data, therefore, is insufficient for
estimating current loadings.
When possible, EPA determined current
loadings for an individual facility based on
information reported by that facility. For most
CWT facilities, however, EPA had'to estimate
current loadings. EPA's methodology differs
depending on the subcategory of CWT facilities
and individual facility characteristics. Factors
that EPA took into account in estimating current
loadings include: 1) the analytical data available
for the subcategory; 2) the characteristics of the
facilities in the subcategory; and 3) the facility's
treatment tram. For facilities in multiple
subcategories, EPA estimated loadings for that
portion of the wastestream in each subcategory
and subsequently added them together. The
sections that follow discuss the current loadings
methodologies for each subcategory.
EPA refers to sample points at specific
episodes throughout this chapter. However,
diagrams of the sample facilities are not
provided. EPA refrained from including the
diagrams due to'confidentiality concerns. All
facility diagrams are available in the record for
this rule, with those claimed confidential in the
CBI portion of the record.
Current Loadings Estimates for
the Metals Subcategory 12.3.7
EPA calculated current loadings for the
metals subcategory facilities by assigning
pollutant concentrations based on the type of
treatment currently in-glace at each facility.
EPA assigned in-place treatment for this-"
subcategory in one of five classes:"
1) raw, or no metals treatment;
2) primary precipitation with solids-liquid
separation;
3) primary precipitation with solids-liquid
separation plus secondary precipitation with
solids-liquid separation;
4) primary precipitation with solids-liquid
separation plus secondary precipitation with
solids-liquid separation followed by multi-
media filtration (EPA based the
BPT/BAT/PSES/PSNS limitations and
standards for this subcategory on this
technology); and
5) selective metals precipitation with solids-
liquid separation plus secondary precipitation
with solids-liquid separation plus tertiary
precipitation with solids-liquid separation
(EPA based the NSPS limitations and
standards on this technology).
Table 12.1 shows the current loadings estimates
for each classification and the following five
sections (12.3.1.1 through 12.3.1.5) detail the
estimation procedure for each classification.
EPA notes that, due to differences among
12-2
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTPoint Source Category
datasets used to calculate loading classes,
"common sense" reductions of some pollutants
with increasing technology are not always
displayed in Table 12.1.
12-3
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTPoint Source Category
Table 12.1 Metals Subcategory Pollutant Concentration Profiles for Current Loadings
Pollutant of Concern
Raw .
Treatment
Primary Secondary BAT
Precipitation Precipitation Option Technology
Selective
Metals
Precipitation
CLASSICAL OR CONVENTIONAL PARAMETERS (mg/L)
Ammonia as nitrogen
Biochcm. oxygen demand
Chemical oxygen demand
Chloride
Fluoride
Hexavalent chromium
Nitrate/nitrite
Oil and grease
Total cyanide
Total dissolved solids
Total organic carbon'
Total phenols
Total phosphorus
Total sulfide
Total suspended olids
METAL PARAMETERS (ug/L)
Aluminum
Antimony
Arsenic
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Gallium
Indium
Iodine
Indium
Iron
Lanthanum
Lead
Lithium
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Osmium
Phosphorus
Potassium
Selenium
Silicon
Silver
Sodium
184.34
1326.82
10,889.83
17,570.78
1,416.38
1,364.96
3,243.72
29.67
.8.00
60,992.86
1,938.79
1.65
690.21
58.17
31,587.34
362,855
80,937
56,873
39
119^94
549,749
1,132,699
851,525
362,914
2,514,805
5,045
11,839
95,940 .
51,823
1,210,265
779
167,649
67,827
209,520
182,587
276
51,575
430,971
1,917
347,146
' 2,003,938
561
212,884
1,172
21329.820
347.65
5,043.83 .
12,696.25
35,966.67
49.72"
4.02
3,102.17
- 75.86
1.29
52,040.00
3,598.17
5.57
43.10
29.21
494.85
28,264
4,152
181
3-
35,0477 •-
254"
4,163,233
3,986
214
1,796
2,473
3,820
15,075
4,554
16,076
413
1,909
35,757
6,107
1,551
.21
5,833
20,083
440
36,543
2,361,444
277
4378
223
16.662.444
112.71 •
670.17
2,362.67
33,966.67
82.85
0.36
974.93
12.11
3.64
48,400.00
451.55
3.16
39.63
17.57
673.81
27,628-
679 '
246
8
• 23,811~
6,792
308,935
19,125
223
419
2,600
5,250
1,000
5,250
11,533
550
281 •
2,495
5,035
1360
2
3,053
1,668
550
1,152,950
748,817
577
2,752
87
18.921.667
15.63
159.60 '
1,333.33
18,000.00
66.27
0.80
531.67
34.34
0.17
42,566.67
236.33
N/A'
31.68
N/A'
16.80
856-
170
. 84
, N/A;
8;403-
58
20,000
1,675 •
115
744
N/A'
N/A'
N/A'
500.
5,752
N/A'
. 177
1,927
N/A'
49
1
1,747.
1,161
. N/A'
27,529
410,000
280
1,447
26
15.100.000
9.12
28.33
198.56
2,243.75
...... _ 235
0.03
12.61
3434-
N/A'
18,112.50
,19.64
N/A'-
29.32
24.95
9.25
73
""21""
11
1
,7,290
82
407,167
40
57
169
N/A'
500
N/A'
N/A'
387
100
55
N/A'
.753.
12
0
528
255
100
544
54,175
56
356
5
5,776,250
12-4
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
Pollutant of Concern
Strontium
Sulfur
Tantalum
Tellurium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Zirconium
ORGANIC PARAMETERS (ug/L)
Benzoic acid
Benzyl alcohol
Bis(2-ethylhexyl) phthalate '
Carbon Bisulfide
Chloroform
Dibromochloromethane
Hexanoic acid
M-xylene
Methylene chloride -
N^i-dimethylfbrmamide
Phenol
Pyridine
Toluene
Trichloroethene
1,1,1-trichloroethane
1 , 1 -dichloroethene
1,4-dioxane
2-butanone
2-propanone
4-methyl-2-pentanone
Raw Primary
Treatment Precipitation
4,818
10,754,912
4,924
16,939
7,556
903,260
532,387
30,258
144
2,007,752
1,256
1,939
1,648
. 292
187
' 64 .
64
215
64
264---;-;.
131 —
166
' 82
166
114
64
64
64 •
323
3,712
320
5,759
1,802,233
2,000
4,000
103
2,397
152
45
30
3,625
1,270
N/A'
N/A;
645
N/A'
332
108
N/A'
N/A'
165
N/A'
6,869
' N/A'
420
108
135
170
N/A'
N/A'
N/A'
'N/A'
Secondary BAT
Precipitation Option Technology
1,831
2,203,333
2,750
5,500
144
434
51
83
43
2,052
1,330
9,716
745
10
83
1,418
10
23
10
23
76
45
.10
10
10
10
10
10
61
246
50
100
1,214,000
N/A'
N/A'
N/A'
90,
57
12
5
413
1,287
3,522
N/A'
N/A'
N/A'
149
50
N/A'
N/A'
N/A'
68
N/A'
87
N/A'
442
N/A'
N/A'
N/A'
1,272
13,081
N/A'
Selective
Metals
Precipitation
N/A'
2,820,000
N/A'
N/A'
21
28
. . 4
11
4
206
N/A'
N/A'
N/A'
N/A'
10
• N/A'
N/A'~
N/A1
.... N/A/
N/A'
- N/A'
N/A'
N/A'
N/A'
.N/A'
N/A'
N/A'
N/A'
N/A'
N/A'
•N/A'
'Concentration values for certain pollutants were not available for some classifications.
12-5
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
Raw Loadings for the Metals
Subcategory
12.3.1.1
EPA classified metals subcategory facilities
with no chemical precipitation in the "raw" class
(even if they had other treatment in place,'such
as activated carbon). EPA assigned the "raw"
current loadings estimates to three facilities in the
metals subcategory. EPA based its estimates for
raw wastewaters on data from 13 sample points
at six sampling episodes and one sample point
from data supplied by a facility in comments to
the 1999 proposal (refer to Table 12-2 for
sample episode and sample point-identifiers).
The data from these episodes include
composite samples from continuous~ flow
systems and grab samples from-batch, flow
systems.
Fornon-detectedmeasurements, EPAused
the sample-specific detection limit except for
certain analytes from the semi^quantitative
screen component of Method 1620 for episode
1987. In 1990, when-these analyses were
performed, the laboratory's standard convention
to report non-quantitated results from semi-
quantitative analysis was to populate the
summary form with 'ND' rather than reporting
sample-specific limits. This was the case for'
indium, iridium, lanthanum, osmium, tantalum,
and tellurium. With the exception of indium and
iridium, EPAused the analyte baseline value for
such non-detected results (see chapter 15 for
baseline values). For indium and iridium, where
the largest detected value was substantially less
than the baseline value, EPA used the largest
detected value for the non-detected
measurements at sample point 2 for episode
1987.
The data from 11 of the 13 sample points
from EPA sampling episodes are from batch
flow systems. During each day of sampling at
these 11 facilities, EPA collected grab samples
from one or more batches processed each day by
the batch flow systems (for some sample points,
EPA did not obtain samples on each day for
various reasons such as the treatment associated
with that sample point was not used that day).
After averaging the values from field duplicate
samples, EPA calculated a daily average for each
pollutant at each facility. For example, if EPA
collected grab samples, of two batches during a
single day, EPA averaged the two results to
obtain the daily average.
Conversely, the-data from, the remaining.
two sample points at EPA sampling episodes and
the industry effluent monitoring data for facility
652 were all obtained from continuous flow
systems. Except for field duplicates and oil and
grease/HEM, EPA obtained only one
measurement for each day (considered to be the
daily average) from a composite sample taken
from each continuous -flow system. EPA
averaged values from duplicate field samples
before performing any other calculations.
Because oil and grease/HEM can only be
obtained as grab samples, EPA typically obtained
four samples each day and arithmetically
averaged the results to obtain one daily value for
that pollutant. '
Once EPA obtained the daily averages for
each of the sample points, EPA calculated 'the
raw pollutant concentration as the average of the
daily averages at the 14 sample. points (13
sample points from EPA sampling episode and
one sample point from industry supplied effluent
monitoring data).
As an illustrative example, Table. 12-2
shows the data used to obtain the raw
wastewater estimation for aluminum: 362,855
ug/L. Table 12-2 shows that this estimation
comes from 38 daily averages (some from
continuous systems and some from batch
systems) from 91 analyses. Raw wastewater
estimations for other pollutants were calculated
in a similar manner.
12-6
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTPoint Source Category
Table 12-2 Example of Metals Subcategory Influent Pollutant Concentration Calculations'
Sample Point
Episode 4378-01
Episode 4378-03
Episode 4055-01
Episode 1987-01
Episode 1987-02
Episode 4393-01
Episode 4382-07
Episode 4393-05
Episode 4803-01
Episode 4803-03
Episode 4803-05
Episode 4803-07
Episode 4803-10
Facility 652-01
Raw Aluminum Daily Averages (ug/L)
389,338
2,080,000
51,800
839,000
577,500
3,730
84,400
72,400
723
5,040
97,800
58,900"
66,925
"~
189,223
1,542,500
1,670,000
792,000
53,400
29,400
139,000
3,765
1,545,000
101,466"
3,128
745,000
260,000
859,000
171,000
6,150
159^50-
8376
70367 563,250
145,000 330,000
15,900 11,200
47,575-
# of measurements
26 (5 are duplicate values)
16 (2 are duplicate values)
3
' - 3
3 ( 1 is a duplicate value)
2(1 is a non-detect value)
6 (1 duplicate value)
6 (1 is a duplicate and
non-detect value)
1
_ '- . . . 1
• • 3
1
20 (4 are duplicate values)
no data provided
'The Raw Aluminum Concentration is 362,855 ug/L — the average of daily values in the tabler •
Primary Precipitation with Solids-
Liquid Separation Loadings '
12.3.1.2
EPA estimated pollutant concentrations
resulting from primary precipitation and solids-
liquid separation using data from EPA salnpling
episodes and industry supplied effluent
monitoring data. EPA used data from three
sampling episodes and effluent monitoring data
submitted by two facilities. These data were
used to represent the current loadings for 32 of
the metals subcategory facilities. The episodes
used are from the detailed monitoring
questionnaire 613 (industry supplied effluent
monitoring data), sample point 16; industry
effluent monitoring data supplied in comments tp
the proposal for facility 652, sample point 2;
episode 4382, sample point 8; episode 1987,
. sample point 3; and episode 4798, sample point
3.
For episode 4382, EPA excluded all data for.
organics, oil and grease, BOD5, COD, TOC,
nitrate/nitrite, and ammonia as nitrogen because
they did not represent metals subcategory
wastewater exclusively. EPA also excluded data
for these analytes from this episode, but different
sample points, in calculating the raw loadings
(section 12.3.1.1) and the secondary
precipitation with solids-liquid separation loadings
(section 12.3.1.3).
For non-detected measurements; EPA-used-
the same assumptions as for the data described
in section 12.3.1.1. For indium and indium,
where the largest detected value was
substantially less than the baseline value, EPA
used the largest detected value for the non-
detected measurements at sample point 3 for
episode 1987.
The facility supplied effluent monitoring data
from facility 613 was collected as grab samples
from batch flow systems. The facility collected
a single grab sample each day. This single value
was the daily average for the facility.
Conversely, for this treatment technology,
the data from the EPA sampling episodes and the
industry effluent monitoring data for facility 652
were all obtained from continuous flow systems.
Except for field duplicates and oil and
grease/HEM, EPA obtained only one
measurement for each day (considered to be the
daily average) from a composite sample taken
12-7
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
from each continuous flow system. EPA
averaged values from duplicate field samples
before performing any other calculations.
Because oil and grease/HEM can only be
obtained as grab samples, EPArypically obtained
four samples each day and arithmetically
averaged the results to obtain one daily value for
that pollutant
After calculating daily averages, EPA then
calculated a facility average for each pollutant as
the arithmetic average of the daily averages at
that facility. These facility averages were, then
arithmetically averaged to obtain the pollutant
concentration average. Table 12.1 shows these
pollutant average concentrations representing
primary precipitation for the relevant pollutants
of concern;
Secondary Precipitation with Solids-
Liquid Separation Loadings 12.3.1.3
EPA estimated current loadings for facilities
with secondary chemical precipitation using data
from three sampling points at~ three separate"
episodes and industry supplied effluent
monitoring data from one facility. These are
episode 4393, sample point 13; episode 4382,
sample point 12; episode 4798, sample point 4;
and industry effluent monitoring data supplied in
comments to the 1995 proposal for facility 652,
sample point 3.
All of the data from this treatment
technology were obtained from continuous flow
systems. EPA used the sample-specific
detection limit for all • non-detected
measurements. Except for field duplicates and
oil and grease/HEM, EPA obtained only one
measurement for each "day from composite
samples taken from these continuous flow
systems. EPA averaged values from duplicate
field samples before performing any other
calculations. Because oil and grease/HEM can
only be obtained as grab samples, EPA typically
obtained four samples each day and
arithmetically averaged the results to obtain one
daily value for that pollutant.
After obtaining one value for each day, EPA
then calculated a facility average for each
pollutant as the arithmetic average of the daily
averages at that facility. These facility averages
were then arithmetically averaged to obtain the
pollutant concentration average. Table 12.1
shows these pollutant average 'concentrations
representing secondary precipitation w.itrTsolids-
liquid separation for the relevant pollutants of
concern.
Technology Basis for the,OptionA
Loadings
12.3.1.4
EPA used the long-term averages from
Metals Option 4 — batch primary precipitation
with solids-liquid separation plus secondary
precipitation with, solids-liquid separation
followed by multi-media-filtration— to represent
current loadings, at three facilitiesrin: the:metals:
subcategory (Chapter 10 describes the method
for calculating these long-term averages for each
pollutant). The~facility..sampled,by_EPAT1hat
employs the technology basis for the
BPT/BAT/PSES Option, obviously, is assigned
its current loadings. EPA modeled the loadings
for two faculties that utilize tertiary precipitation
with the BPT/BAT/PSES option current
loadings. EPA believes that facilities utilizing
tertiary precipitation will not need to alter their
systems to meet the limitations. By assigning
current loadings estimates based on the Option 4
technology basis to the tertiary systems, EPA
may have overestimated current loadings at these
two facilities. However, EPA does not estimate
any post-compliance pollutant reductions at these
facilities.
Selective Metals Precipitation
(Option 3) Loadings
12.3.1.5
Only one facility in the metals subcategory
utilizes selective metals precipitation. EPA
sampled this facility during development of this
rule. Therefore, the current loadings pollutant
12-8
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
concentrations for this facility are not estimates,
but measured data. Table 12.1 summarizes
these pollutant concentrations (Chapter 10
describes the method for calculating the pollutant
concentrations).
Current Loadings Estimates for the
Oils Subcategory
12.3.2
Based on questionnaire responses and site
visits, EPA found that all facilities whiclrtreat
oily waste-waters, for which EPA has data,
currently employ emulsion breaking and/or,.
gravity separation. If emulsions are present in
the incoming waste receipts, the facility first
makes use of emulsion-breaking.- If not, the
waste receipts generally bypass emulsion
breaking and the facility processes the waste
through a gravity separation step for gross
separation of the water and the oil phases^ A-
facility may often follow up these pretreatment
steps by other wastewater treatment technologies
or substitue them for -dehydration operationsr
Therefore, EPA believes that, at a minimum, it
may characterize current loadings for oils
subcategory discharges by analyzing samples
obtained from the effluent of emulsion
breaking/gravity separation.
At the time of the 1999 proposal, EPA used
seven data sets to represent effluent from
emulsion breaking/gravity separation systems.
EPA collected these seven data sets during long-
term EPA sampling episodes at various types of
oily waste facilities. Six of these seven data sets
represent facilities that treat oily wastewater and
recover/process used oil. One facility, that
primarily accepts bilge water, performs oily
wastewater treatment only. The annual volume '
of treated oily wastewater discharged at these
facilities ranges from 174,000 gallons/year to 35
million gallons/year. Two of the data sets
represent facilities that only accept non-
hazardous wastes, while the other five data sets
represent facilities which are permitted by RCRA
to additionally accept hazardous wastes.
For each pollutant of concern, each of the
seven emulsion breaking/gravity separation long-
term sampling data sets contains the mean
concentration of the data collected over the
sampling episode (a duration of two to five
days). This mean includes measured (detected)
and non-detected values. The value substituted
for each non-detected measurement was either
1) the sample-specific detection limit or 2) the
average of the measured (detected) values across
all seven data sets,._ Section^ 12.3L2..L diseusses_
EPA's representation of non-detect values for
this analysis. Section 12.3.2.1 further discusses
EPA's representation of the one biphasic sample.
For each episode and each pollutant, the table
presents the mean concentration of..the,,data_
collected over me~samplingepisoder Figurel2-i-
shows the procedure EPA used to estimate the
mean concentration data over the seven sampling
episodes.
EPA has facility-specific information in its
database for 84 oils subcategory facilities. Of
these 84 facilities, EPA has long-term sampling
data for seven and grab sample data for 12
others which, were part of the 1998
characterization sampling of oil treatment and
recovery facilities (see Chapter 2, .section 3.4).
For the remainder of the facilities, EPA does not
have current loadings data. EPA does, however,
have facility-specific information on the volume
of wastewater being discharged and the
treatment train currently in use. EPA evaluated
several ways to associate the emulsion
brealdng/gravity separation data sets to each of
the faculties for which EPA needed to estimate
current performance. EPA, therefore, reviewed
the data sets to determine if there was a
relationship between the concentration of
pollutants, and facility flow, but found no
evidence of relationship.
Consequently, for the 1999 proposal, EPA
randomly assigned one of the seven long-term
sampling data sets to each of the facilities that
required current loadings estimates. For facilities
12-9
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTPoint Source Category
which only employ emulsion breaking/gravity
separation, EPA estimated current loadings for
each pollutant using values in the randomly
assigned data set For facilities which use
additional treatment after that step, EPAfurther
reduced the pollutant loadings' for certain
pollutants (or all pollutants depending on the
technology) in the randomly assigned data set to
account for the additional treatment-in-place at
the facility.
Afterthe 1999proposal, EPAreevaluatedits
methodology of randomly assigning data sets to .
the oils subcategory facilities. EPA determined
that it would be more appropriate to assign the
same average concentration for each pollutant to
all facilities. In calculating these- average-
concentrations for a pollutant, EPA used the
seven data sets plus the data- from- the 1-1-
facilities in the 1998 characterization sampling
effort. EPA collected, at a minimum;, a single-
grab sample from emulsion breaking/gravity
separation at each faculty, (for three 'facilities,
EPA collected duplicate field samples and these
values were averaged together before any other ,
calculations).
All but one of the EPA sampling episodes
were at faculties with continuous flow systems.
Except for field duplicates and oil and
grease/HEM, EPA obtained only one
measurement for each day from composite
samples taken from these continuous flow
systems. EPA averaged values from duplicate
field samples before performing any other
calculations. Because oil and grease/HEM can
only be obtained as grab samples, EPA typically
obtained four samples each day and
arithmetically averaged the results to obtain one
daily value forthatpollutant. EPA calculated the
facility average as the arithmetic average of the
daily values.
For the one remaining facility that had a
batch system, EPA collected grab samples of
different batches. EPA averaged the values from
duplicate samples before performing any other
calculations. EPA then calculated the facility
average as the arithmetic average of the batches.
EPA calculated pollutant concentration
loadings using RCRA and non-RCRA facilities
separately. Each of the 18 facilities was assigned
to the RCRA or non-RCRA subset except for
one facility which was assigned to both
categories. This facility has a RCRA permit to
accept and treat RCRA waste, but treated
exclusively -non-RCRA' waste during EPA's
sampling. For each pollutant, EPA men
calculated an overall pollutant concentration
loading for the RCRA subset and another for the
non-RCRA subset -
Because the sample sizes of the 18 facilities
ranged from a single sample to 20 samples (for
the.facih'ty».with.,the.batch flow system), EPA
determined that a weighted average of the facility
averages using.weights,equal to the square root
of the sample size would be appropriate. As a
simplified, hypothetical example for pollutant X,
given two facilities and one had five samples
with a facility average of 20 mg/L and the other
facility had two samples with a facility average of
100 mg/L, the pollutant average (PA) would be
51 mg/L as shown in the following equation:
PA =
_ J5(20mgIL) + V2(lOOmg/ L)
= 51mg/L
Table 12-7 presents the pollutant concentration
loadings (labeled as long-term averages (LTA) in
the table) for both the RCRA and non-RCRA
subsets.
12-10
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
tha data
from the facilities
obtaii ons value for
each pollutant
Calculals pollutant
L7A for ths lacility
as m-sai of its caily
values
7cr each pollutant,
examine the: Aia
Jfrcin each S5rr.pl-s
Calculate
of dstsctsc values
frtarn all fac
Ccinpa'-e each
sscople-specific
detection limit (K-.~)
, toMNC
Calculate f cllu:aal
LTAJfor Hie laciliLy
as mean or its biitch
values
Figure 12-1 Calculation of Current Loadings for Oils Subcategory
12-11
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
TREATMENT-IN-PLACE
As mentioned previously, there are many
configurations of treatment. trains in. this
subcategory. While EPA does not have sampling
data representing each of these treatment
configurations, EPA does have sampling data
representing each of the individual treatment
technologies currently in place at oily waste
facilities. While EPA collected all of the data at
CWT facilities, EPA collected some of the data
it used to develop treatment-in-place credits at
facilities in other CWT subcategories; For some
technologies,- EPA has sampling data from a
single facility, while for others, EPA has
sampling data from multiple CWT facilities.
In order to estimate the current pollutant
reductions due to additional treatment-in-place at
oils facilities, for each technology, EPA compiled
and reviewed all CWT sampling data for which
EPA collected influent and effluent data. EPA
subjected'the-infiuent data-to a similarscreening-
process as the one used in determining long-term
averages. For each episode, EPA retained
influent and effluent data for a specific pollutant
only if the pollutant was detected in the influent
at treatable levels (10 times the baseline value1)
at least 50 percent of the time. For each facility,
EPA then calculated an "average" percent
removal for metals (averaging the percent
removal for each metal), an "average" percent
removal for organics, and an "average" percent
removal for BODS TSS, and oil and grease.
EPA rounded the averages to the nearest 5
percent When the "average" percent removal
for more than one third of the pollutants in a
compound class (i.e., metals, organics, BOD5
TSS, and oil and grease) was zero or less, EPA
set the "average" percent removal for the class
of compounds equal to zero. EPA recognizes
that treatment technologies are not equally
effective in reducing all metals and/or all organics
from wastewater, but believes this provides a
'Defined in chapter 15.
reasonable estimate. The result is that, for some
. pollutants, EPA believes it may have
underestimated the removals associated with the
additional treatment-in-place, while for oilier
pollutants, EPA may have overestimated the
removals.
Table 12-3 shows the percent removal
credited to each technology. For technologies
that EPA evaluated at more than one CWT
facility, the value for each class of compounds
represents the lowest value at the facilities. For
example, EPA sampled at two facilities that use
multimedia filtration. The average percent
removal of metal pollutants at facility 1 and
facility 2 is 60 percent and 30 percent,
respectively. Table 12-3 shows that EPA used
—30 percent to estimate metals removal, in
.multimedia-filtration systems.. EPA believes-that,
-using the lower percent removal of the "best"
performers provides a reasonable estimate of the
percent removals of these technologies for 'the
rest of the industry and may even overstate 'the
percent removals for some facilities that may not
be operating the treatment technologies
efficiently.
For some classes of compounds and some
technologies, EPA does not have empirical data
from the CWT industry to estimate percent
removals. For these cases, EPA assumed
percent removals based on engineering
judgement. EPA assumed that air stripping is
only effective for the removal of volatile and
semi-volatile organic pollutants. EPA also
assumed that chemical precipitation is ineffective
for the treatment of organic pollutants. Finally,
EPA assumed a 50 percent reduction in organic
CWT pollutants through carbon adsorption
treatment. EPA recognizes that carbon
adsorption, given the correct design and
operating conditions can achieve much higher
pollutant removals. However, for this industry,
EPA believes that the complex matrices,
variability in waste receipts, and high loadings
would compromise carbon adsorption
12-12.
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTPoint Source Category
performance without regeneration or replacement
of the carbon beds based on breakthrough of a
range of organic pollutants.
In determining current loadings for facilities
with additional treatment-in-place, EPA then
reduced the current loadings concentrations
established for the facility with gravity
separation/emulsion breaking alone by the
appropriate percent removal as defined above.
For facilities with multiple treatment technologies
in their treatment train, EPA credited each of the
treatment technologies in the order that the
process occurs in their treatment train.
Table 12-3 Treatment-in-Place Credit Applied to Oils Facilities
Pollutant
Treatment Technology
oup Chemical Carbon Air Stripping
Precipitation Adsorption
BOD5
Oil and
grease....
TSS
Metals
Organics
0
45
85
75
0*
0
45
0
0
50*
0*
0*
0*
0*
70
Ultra- Biological Multi-media/Sand
filtration Filtration
55
85
~ 100
75 .
85
50
65
50
15
75
10
0
55 .
30
0
DAP Secondary
ScDEirtion
10
60
80.
50 ..
40
5
30
0
0-
. 50
*Value is based on engineering judgement.
Issues Associated with Oils Current
Performance Analyses
12.3.2.1
This section describes four issues associated
with estimating the current performance of the
oils subcategory. The first issue is the dilution
required in analyses of some highly concentrated
samples representing the baseline, technology
(emulsion breaking/gravity separation). The
second issue is the appropriate procedure for
incorporating the concentrations of a biphasic
sample into the estimates of current
performance. The third issue is the
appropriateness of various substitution methods
for the non-detected measurements, especially of
diluted samples.
DILUTION OF SAMPLES. DURING
LABORATORY ANALYSIS
Effluent from emulsion breaking/gravity
separation operations may be highly
concentrated, which may present difficulties in
analyzing such effluent. Consequently, in its
analysis of some samples, EPA needed to dilute
the samples in order to reduce matrix difficulties
(such as interference) to facilitate the detection
or quantitation of certain target compounds. For
some organic compounds, EPA also had to dilute
samples where a highly concentrated sample
could not be concentrated to the method-
specified final volume.
If EPA diluted a sample for analytical
purposes, EPA adjusted the particular pollutant
measurement to correct for the dilution. For
example, if a sample was diluted by 100 and the
measurement was 7.9 ug/L, the reported value
was adjusted to 790 ug/L (i.e., 7.9 ug/L*100).
In general, the sample-specific detection limits
(DLs) for a pollutant were equal to or greater
than the baseline value described in Chapter 15.
Because wastes generated using the BAT
technologies will be less concentrated than
emulsion breaking/gravity separation operations,
in EPA's view, effluent samples collected to
demonstrate compliance with the final limitations
and standards will not require dilution and
therefore not result in effluent values with large
sample-specific DLs. Further, a laboratory can
12-13
-------
Chanter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
overcome potential analytical interferences using
procedures" such, as those suggested in the
Guidance on the Evaluation, Resolution, and
Documentation of Analytical Problems
Associated with Compliance Monitoring (EPA
821-B-93-001). Thus, in demonstrating
compliance, EPA would not allow dilution of a
sample to a sample-specific DL greater than the
limitation or standard.
BIPHASIC SAMPLES
EPA used a number of different analytical
methods to determine the pollutant levels in the
effluent samples from facilities that employ
chemical emulsion breaking/gravity separation
for treating oily wastewater. Each method is .
specific to a particular analyte or to structurally, '
similar chemical compounds such as volatile"
organics (analyzed by Method 1624) and
semivolatile organics (analyzed by Method„
1625). In developing the laboratory procedures
described in Method 1625, EPA included a-
procedure for analyzing aqueous samples and
another procedure for analyzing biphasic
samples. Some effluent samples from emulsion
breaking/gravity separation were biphasic. That
is, each sample separated" into two distinct layers,
an aqueous layer and an organic one. In these
instances, if the phases could not be mixed, EPA
analyzed each phase (or layer) separately. Thus,
each pollutant in a sample.analyzed by Method
1625 had two analytical results, one for the
organic phase and the other for the aqueous
phase. There were three such samples in the oils
subcategory. Only sample -number 32823
(episode 4814B), however, represents oily
wastes following emulsion breaking/gravity
separation. This sample is part of one of the
nineteen data sets representing emulsion
breaking/gravity separation used to calculate
pollutant concentration loadings for facilities
without concentration data. For this biphasic
sample, EPA combined the two concentration
values into a single value for each pollutant
analyzed using Method 1625. The discussion
below describes the procedures for combining
the two concentration values and Table 12-4
summarizes these procedures. Table 12-5
provides examples of these procedures. DCN2
23.13 lists the combined values for the samples.
If the pollutant was detected in the organic
phase, EPA adjusted the analytical results to
account for the percent of the sample hi each
phase. For sample 32823, 96 percent of the
sample volume was aqueous and the remaining
4 percent was organic. Thus, EPA multiplied the
aqueous value (detected value or sample^specific,
DL) by 0.96 and the organic value by 0.04.
EPA then summed the two adjusted values to
obtain the total concentration value for the
pollutant in the sample.
If the pollutant was not detected in the
organic phase, EPA used several "different
procedures depending on the pollutant and its
concentration in the aqueous phase.- A factor
which complicated EPA's analysis was that
sample-specific DLs for pollutants in the organic- •
phase were 10003 times greater than the
minimum levels for Method 1625. When a
measurement result indicates that a pollutant is
not detected, then the reported sample-specific
DL is an upper bound for the actual
concentration of the pollutant in the sample.
When some sample-specific DLs for the organic
phase (which were 1000 times the minimum
level) were multiplied by 0.04, the adjusted non-
detected values were greater .than the measured
amount in the aqueous phase. EPA concluded
that substituting the sample-specific DL for the
non-detected results in the organic phase in these
2 Items identified with document control
numbers (DCN) are located in the record to the
final rulemaking.
3 Because the volume of the organic phase
was small,- the organic phase sample required
dilution (by 1000) for analysis. In contrast, the
aqueous phase had sufficient amount so that it was
not diluted.
12-14
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
circumstances might over-estimate the amount of
pollutant in the sample. Thus, EPA applied one
of-the two alternative, substitution procedures
described below for the sample-specific DLs
resulting from the organic phase.
First, if EPA did not detect the pollutant in
either phase, EPA considered the sample" to be
non-detect at the sample-specific DL of the
aqueous phase. This value for the aqueous
phase was equal to the minimum level specified
in Method"! 625. \;
Second, if the pollutant was detected "in the
aqueous phase (and non-detected in the.organic-
phase), EPA used a procedure that compared the
non-detected~organlc values to the detected
aqueous value adjusted by apartition ratio (550).
EPA determined this partition ratio using the -
average- of the ratios of the detected organic
phase concentrations to the detected aqueous
phase concentrations for the pollutants that had
detected values in both phases. There were
twenty-two pollutants that were used to calculate
this value of 550. These pollutants are in four
structural groupings of organic pollutants:
chlorobenzenes, phenols, aromatic ethers, and
polynuclear aromatic hydrocarbons. The ratios
were similar in each of the structural groupings;
consequently, EPA determined that a single
value for the partition ratio was appropriate.
EPA then multiplied the aqueous phase
concentration value by this partition ratio of 550.
If this value was less than the sample-specific
DL-of the-pollutant4n-the.organic,phase, EPA
substituted this value for the organic phase
sample-specific DL. Otherwise, EPA used the
organic phase sample-specific DL. EPA then
multiplied'the-values-for the*aqueous and organic-
phases by the relative volume~amounts (0.96 and
0.04, respectively) and summed them-to obtain.
one value for the sample.
Table" 12-4. Diphasic Sample Calculations (Summary_of rules for combining aqueous/organic phase cones.)
Censoring types (i.e., detected or non-detected)-
Aqueous phase
NC
ND
ND
NC
Organic phase
NC
NC
ND
ND (DI>550*AQ)
ND flDL<=550*ACO
Combined result
(same as aqueous)
NC
ND
ND
NC
Method for-obtaining
combined value
0.96*AQ + 0.04*ORG
0.96* AQ (use DL) + 0.04*ORG
AQ(useDL)
0.96* AQ + 0.04*(550*AQ)
0.96*AO + 0.04*ORG ("use DU
AQ = value for aqueous phase
ORG = value for organic phase
NC = non-censored (detected)
ND = non-detected .
DL = sample-specific detection limit
12-15
-------
Chanter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
Table 12-5. Examples of Combining Aqueous and Organic Phases for Sample 32823
Pollutant
Accnaphthene
4,5-methylene
phenanthrene f
Aniline
1-phenyl
-naphthalene J
Alpha-
teipineol
Reported Cones. (ug/L) Concentration Calculation for Sample
Aqueous Organic (ug/L)
Phase Phase
668.6 319,400 13,418 (0.96*668.6 ug/L)
+ (0.04*319,400 ug/L)
ND(10) 163,500 ND (6,550) ,(0.96*10 ug/L)
+ (0.04*163,500 ug/L)
ND(10)* ND (10,000) ND(10)
10.49 ND (10,000) 240.9 (0.96*10:49 ug/L)
+(0.04*550*10.49 ug/L)
1,885.8 ND (10,000) 2,210 (1,885.8 ug/L*0.96)
+ (10,000 ug/L*0.04)
Comment
Concentrations are
weighted by relative
volume in each phase: 96%
aqueous and 4% organic
no calculation necessary
The'sarnple-specific DL of
10,000 ug/L for the organic
phase is greater than 5570
ug/L (i.e., 550 times 10.49
ug/L)
The sample-specific DL of
10,000 ug/L for the organic
phase is less than 1,037,190
(i.e., 550 times'l 885.8 ug/L)
* ND=non-detected measurement The sample7SpecificJDLjs,provided,in the parentheses. ,,, _„"
t None of measurements of the pollutants of concern from this sample resulted in a non-detected measurement for the
aqueous phase with a detected measurement for the organic phase. This analyte.is shown for demonstration'purposes."
J None of measurements of the pollutants of concern from this sample resulted in a detected measurement for the aqueous
phase with a sample-specific DL for the organic phase that was greater than 550 times the measurement from the aqueous
phase. This'analvteris-showrrfordemonstration purposes. • ,
NON-DETECT DATA IN COMPLEX SAMPLES
EPA included values for measurements
reported as "non-detected" when it calculated the
mean for each pollutant of concern in the
emulsion breaking/gravity separation data sets.
In some instances, the measurements reported as
non-detected had sample-specific detection limits
that were well in excess of the pollutant's
baseline value (defined in section 15). The high
sample-specific detection limits occurred because
the samples contained many pollutants which
interfered with the analytical techniques. EPA
considered several approaches for handling these
sample-specific non-detected measurements
because, by definition, if a pollutant is 'not
detected', then the pollutant is either not present
at all (that is, the concentration is equal to zero)
or has a concentration value somewhere between
zero and the sample-specific detection limit
(DL).
EPA considered the following five
approaches to selecting a value to substitute for
non-detected measurements in emulsion
breaking/gravity separation samples:
1. Assume .that the pollutant is not present in
the sample and substitute zero for the non-
detected measurement (that is, ND=0).
2. Assume that the pollutant is present in the
sample at a concentration equal to the
baseline Value (BV) for analytical results as
defined in chapter 15 (that is, ND=BV)).
3. Assume that the pollutant is present at a
concentration equal to half the sample-
specific DL (that is, ND=DL/2). (In general,
the values of the sample-specific DLs are
equal to or greater than -the values of the
baseline values used in the second
approach.)
4. Assume that the pollutant is present at a
concentration equal to the sample-specific
DL (that is, ND=DL). This is the
12-16
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
substitution approach that was used in the
1995 proposal, for the influent pollutant
loadings for the other two subcategories, and
for the final limitations and standards for all
three subcategories.
5. Assume that the pollutant is present at a
concentration equal to either-the sample-
specific DL or the mean of the detected (or
non-censored) values (MNC) of the
pollutant4 EPA used the lower of the two
values (that is, ND=minimum of-DL or-
MNC). For each pollutant, EPA calculated-
two MNC values: one using the data from
the RCRA facilities; the other using data
from the non-RCRA facilities. EPA then
compared the sample-specific detection
limits to the appropriate MNC value
depending-on whether" the facility was
RCRA or non-RCRA.
EPA ultimately selected the approach
described-in-5_ The., Agency,.concluded that
approach 5 provides the most realistic estimate
of current performance from these data sets.
Table 12-6A shows how EPA applied the
five substitution approaches to data for
hypothetical pollutant X for seven facilities
(which were the only ones used when EPA
evaluated these methods. For the finalrule, EPA
4For each pollutant measured by Method
1625, EPA calculated the mean (or average) of
the detected (or non-censored) values (MNC)
using all detected values in the eleven data sets
except for the biphasic sample. The substitutions
were only applied to non-detected measurements
observed in aqueous samples because the non-
detected measurements in the biphasic sample
were evaluated separately as described in the
previous section. While EPA believes that
biphasic samples can result from some wastes in
this subcategory after processing through
emulsion breaking/gravity separation, EPA
believes that it is appropriate to use only detected
measurements from aqueous samples in
calculating the mean that will be compared to each
sample-specific DL in aqueous samples.
included the additional 12 characterization
facilities in these calculations and distinguished
between RCRA and non-RCRA facilities). The
example shows the types of calculations EPA
performed in comparing the five approaches for
the seven facilities. The example includes
faculties that treat wastes on a batch and
continuous basis. It-also includes a mixture of
detected and non-detected measurements as well
as duplicate samples. For each facility, the table
lists—the- analytical results reported by the
laboratory-for pollutant Xv If the reported value
is non-detected, then this analytical result is
identified in the table as "ND" with the reported
sample-specific DL in the parenthesis. If the
value is detected, the analytical (measured) result
is shown in the table and is identical in all five
approaches because the substitutions apply only
to non-detected values. Finally, for seven
facilities, the table shows, five long-term averages
for pollutant X — one for each of the five
substitution approaches.
12-17
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTPoint Source Category
Table 12-6 A. Example of Substitution Methods for Non-Detected Measurements of Hypothetical Pollutant X
Facility Sampling Day or
Batch Number
A**
B
C
D
Batch 1
Batch 1
Batch 2
Batch 3
Batch 4
Day 1
Day 2
Day I
Day 2
Day 3 •
Dayl
Reported
• Values
(«g/L)
99
95
ND (300)*
84
258
A.-LTA
ND (100)
ND (1000)
RLTA
57
84
26
GLTA
73
Day 2 (duplicate) ND (100) *
Day 2 (duplicate) ND (10) -
E
F
G
Day 3
Dayl
Day 2
Day3
Day4-
Day 5
Dayl
Day 2
Day 3
Day 4
Day5
Dayl
Day 2
Day 3
Day 4
MNC =
62
D:LTA
411
257
79
ND (1000)
ND(220)
E.-LTA
ND (300)
320
44
47
180
F:LTA
1234
855
661
1377
G:LTA
Approach 1 Approach 2
ND=0 ND=BV t
(BV=10ug/L)
99
95
0
84
258
122
0
0
0
57
84
26
56
73
0"
0
62
45
411
257
79
_ 0
0
149
0
320
44
47
180
118
1234
855
661
1377
1032
99
95
10
84
258
125
10
10
10
57
84
26
56
73
10
10
62
48
411
257
79 .
10
10
153
10
320
44
47
180
120
1234
855
661
1377
1032
Approach 3 Approach 4 Approach 5
ND=DL/2 ND=DL ND=
min(DL,MNC)
99
95
150
84
258
160
50 ,
500
275
57
84
26
56
73"
•-. 50". ,
5
62_
54
411
257 -
79
5,00
110
271
150
320
44 .
47
180
•148
1234
855
661
1377
1032
99
95
300
84
258
197'
100-
1000
550
57
84
26
56
73
100
10
62
63
411
257
79
1000
220
393
300
320'
44
47
180
178
1234
855.
661
1377
1032
99
95
300 '
84
258
197
100
315
208 .
57,
84
26
56
' 73
100
10
62
63
411
257
79
315
220
256
300
320
44 •
47
180
178
1234
855
661
1377
1032
315 (MNC = mean of detected values from all seven facilities)
* ND=non-detected measurement The sample-specific detection limit is provided in the parentheses.
•f BV=baseline value for analytical results — see chapter 15
** The 7 data sets used in this table was expanded to include 19 total data sets for the final rule.
While Table 12-6A provides an example
using the five approaches, 'DCN 23.8 in the
record shows the results of the substitution
values under the first four approaches to the
actual seven concentration data sets from "the
seven facilities with emulsion breaking/gravity
separation.. DCN 23.21 shows the results of
using the fifth approach. After evaluating the
five approaches, EPA preferred Approach 5
because it tended to rninimize the effect of
12-18
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
sample-specific large detection levels on the long-
term averages while providing reasonable
estimates of the actual concentrations.
Furthermore, EPA felt that Approach 5 was
superior to the other four approaches. In
particular, the first and second approaches
(substitutions of zero or the BV, respectively, for
non-detects) are poor choices because they are
likely to provide unrealistically low estimates of
the analyte concentrations in samples with high
sample-specific detection limits, especially when
all "detected" values are substantially greater than
zero and the BV. In addition, the third and
fourth approaches (substitution of the sample-
specific DE or DE/2, respectively) are poor
choices because-the substitutions could exceed
the detected'values in some cases, and-thus,
possibly could over estimate the concentrations
in non-detected measurements. EPA's analyses
also show that there is little or no difference in
the averages between using the sample-specific
Db or half the-sample-specific DL for many of
the facility/analyte data sets. Thus, EPA has
followed the approach outlined in 5 above
because it concluded that this approach provides
reasonable estimates of the actual concentrations
because the substituted values are neither
unrealisticaUy .low nor exceed the greatest
detected value. .
Table 12-7 shows the option long-term
averages for each pollutant for the RCRA and
non-RCRA facilities separately. For each
pollutant in each subset (RCRA and non-RCRA),
the table provides a long-term average without
any replacements and another long-term average
where sample-specific detection limits greater
than the MNC value have been replaced with the
MNC value. DCN XXX provides the facility
long-term averages that were used to calculate
these pollutant long-term averages.
Table 12-6B shows the relative effects (at
the time-of the 1999 proposal) of EPA's
preferred approach in comparison to Approach 1
on the estimates of priority, conventional, and
non-priority pollutant concentrations for baseline-
loadings and the total removals changes for toxic
weighted pollutants. In comparison to Approach
1 (EPA's original method), EPA's preferred (or
'replaced!) .approach (that is, Approach 5) had
little noticeable effect on the baseline loadings for
the oils subcategory. In other words, the current
loadings are approximately .the same using either
approach. There is, however, a significant
decrease in toxic pound-equivalent removals with
EPA's preferred approach. Hence, overall toxic
pound-equivalent removal estimates using-EPA's-
preferred approach decreased by approximately
34% from those calculated using its original
approach (that is, substituting the sample-specific
detection limit for all non-detected
measurements). The cost effectiveness
document provides more information on toxic
pound-equivalent removals.
Table 12-6B. Difference in Oils Subcategory Loadings After Non-Detect Replacement Using EPA Approach*
Priority Metals &
Organics Current Loading
(percent change)
Non-Priority Metals & Conventional Pollutant Current Pound-Equivalent
Organics Current Loading Loading - Net Removals
(percent change) (percent change) (percent change)
-5
+ 1
0
-34
* Data is from a comparison performed for 1999 proposal. Final estimates may vary slightly.
12-19
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTPoint Source Category
Table 12-7. Long-Term Average Concentrations-For Emulsion Breaking/Gravity Separation Effluent
Pollutant
CAS Number
LTA for RCRA Facilities
Without With
Replacement Replacement
LTA forNon-RCRA Facilities
Without With
Replacement Replacement
CLASSICAL OR CONVENTIONAL PARAMETERS (mg/L)
Ammonia as nitrogen
Biochcm. oxygen demand
Chemical oxygen demand
Chloride
Fluoride
Nitrate/nitrite
Oil and grease
SGT-HEM
Total cyanide
Total dissolved solids
Total organic carbon
Total phenols
Total phosphorus
Total suspended solids
METAL PARAMETERS (ug/L)
Aluminum -
Antimony
Arsenic
Barium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Germanium
Iron
Lead
Lutetium
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Potassium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Tantalum
Tin
Titanium
Zinc
7664-41-7
C-003
C-004
16887-00-6
16984-48-8
C-005
C-007
C-037
57-12-5
C-010
C-012
C-020
14265-44-2
C-009
7429-90-5
7440-36-0
7440-38-2
7440-39-3
7440-42-8
7440-43-9
7440-70-2
7440-47-3
7440-48-4
7440-50-8
7440-56-4
7439-89-6
7439-92-1
7439-94-3
7439-95-4
7439-96-5
7439-97-6
7439-98-7
7440-02-0
7723-14-0
7440-09-7
7782-49-2
7440-21-3
7440-22-4
7440-23-5
7440-24-6
7704-34-9
7440-25-7 •
7440-31-5
7440-32-6
7440-66-6
' 135.37
7,826.66
44,683.32
2,635.01
69.73
25.69
18,690.42
1,442.70
0.24
16,363.93
6,243.59
14.63
1,264.87
. 6,531.56
36,941
978
1,328
2,491 "...
156,850
175
224^57
2,023
6,074
10,697
12,845
219,497
6,085
2,385
75,066
8,237
7
2,725
20,512
81,096
670,251 •
123
41,939
563
2,808,044
3,408
2,048,228
12,923
1,672
353
30,887
135.37
7,826.66
44,683.32
2,635.01
69.73
25.69
18,690.42
1,442.70
0:24
16,363.93
6,243.59
14.63
1,264.87
6,531.56
36,941
243
1,328
2,491
156,850
161
224,357
2,023
6,074
10,697
4,349
219,497
6,085
589
75,066
' 8,237
7
2,725
20,512
81,096
, 670,251
112
41,939'
503
2,808,044
1,654
2,048,228
4,349
1,264
353 .
30,887
111.02
14,160.55 .
75,458.21
31.91 '
26.85
6.90
6,130.09
3,467.85
0.02
11,124.49
15,661.45
40.85
3,724.63
5,167.65
49,641
774
102
664
122,998
43
183,129
218
2,077
837
20,888
56,564
975
4,178
131,463
2,758
20
4,640
. 1,228
22,987
660,839
30
15,861
52
2,376,236
4,181
151,420 "
20,888
494
71
14,488
111.02
14,160.55
75,458.21
31.91
26.85
6.90
6,130.09
3,467.85
0.02
11,124.49
15,661.45
40.85
3,724.63
5,167.65
49,641
261
80-.
664
122,998 •
27
183,129
218
2,077
837
20,888
56,564
975
4,178
131,463
2,758
20
4,640
1,180
22,987
660,839
18
15,861 '
8
2,376,236
114
151,420
20,888
151
59
14,488
ORGANIC PARAMETERS (ug/L)
Accnaphthene
Alpha-terpineol
Aniline
83-32-9 -•
98-55-5
62-53-3
2,109 .
1,739
1.209
1,364
1,031
201
325
476
334
83
304
108
12-20
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTPoint Source Category
Pollutant
Anthracene
Benzene
Benzo(a)anthracene
Benzoic acid
Benzyl alcohol
Biphenyl
Bis(2-ethylhexyl)phthalate
Butyl benzyl phthalate
Carbazole
Carbon disulfide
Ghlorobenzene
Chloroform
Chrysene '
Dibenzofuran
Dibenzothiophene
Diethyl phthalate „
Diphenyhetherg -
Ethylbenzene
Fluoranthene-
FluorenelV .
Hexanoic acid
m+p xylene
m-xylene
Methylene chloride
ii^-dimethylformamide
n-decane
n-docosane
n-dodecane
n-eicosane
n-hexacosane
n-hexadecane
n-octacosane
n-octadecane
n-tetracosane
n-tetradecane
Naphthalene
o-fp xylene
o-cresol
o-toluidine
o-xylene
p-cresol
p-cymene
Pentamethylbenzene
Phenanthrene
Phenol
Pyrene
Pyridine
Styrene
Tetrachloroethene
Toluene
Trichloroethene
Tripropyleneglycol
methyl ether
1.1 1 -trichloroethane
LTA for RCRA Facilities LTA for Non-RCRA Facilities
CAS Number Without With Without With
Replacement Replacement Replacement Replacement
120-12-7
71-43-2
56-55-3
65-85-0
100-51-6
92-52-4
117-81-7
85-68-7
86-74-8
75-15-0
108-90-7
67-66-3
2r8sOT-9-
132-64-9
132-65-0
84-66-2
101e84-8i .
100-41-4
206-44-0 :
86*73=7 ~ "
142-62-1
179601-23-1
108-38-3
75-09-2
68-12-2.
124-18-5
629-97-0
112-40-3
112-95-8
630-01-3
544-76-3
630-02-4
593-45-3
646-31-1
629-59-4
91-20-3
136777-61-2
95-48-7
95-53-4
95-47-6
106^4-5
99-87-6
700-12-9
85-01-8
108-95-2
129-00-0
110-86-1
100-42-5
127-18-4
108-88-3
79-01-6 '
20324-33-8
71-55-6
2,348
4,572
1,563
15,419
1,276
1,788
51,495 .
4,886 — •--
2,500
371
283.
558
1;708
2,060
1,513
2,228
1,205
4,964
3,i38-_-_: ...."'
2,257 1 . .
5,295
1,043--- ,.
7,008 .-
2,965
1,229 ;
. 71,555
2,434.
58,682
28,807
1,892
106,817
2,036
66,771
2,174
194,564
11,560
4,660
1,695
1,211
700
1,145
1,536
2,303
5,654
6,406
2,719
1,371
1,299
2,238
22,758
876
44,553
2078
1,591
4,572
551
14,689
334
889
51,495
4,886--
552
257
126_. _
482
710 "
1,263
544
1,658
122
4,964-
" 2,433
1,513
5,254
1,043
.. 7,008
2,965
407
71,555
1,712
58,682
28,807
1,288
106,817
1,995
66,771
1,771
194,564
11,560
4,660
1,091
158
700
939
824
1,717
5,241
6,345
1,994
483
329
2,238
22,758
876
43,295
2078
370
520
363
15,851
1,354
1,158 -
1,472
2,370—-
629
240
10 .
10
401
319
416
355
1,590
403-
335
366
54,805
432
133
343
1,969
4,789
11,095
1,626
557
85,199 .
316
6,854
546
50,390
3,065
494
1,357
322
1,018
878
309
937
16,610
1,512
313
377
1,779
1,952
22
5,008
54 . • •
182
520
167
15,851
1,329
1,158
1,472
2j370~
109
240
_. 10
10
252
66
282
206
1,590
403 -
96
154-
54,805
432 ,
133
104
1,969
4,789
11,095
1,588
•427
85,199
94
6,854
529
50,390
3,065
494
1,327
67
1,018
878
309
937
16,610
1,512 •
34
190
1,779 •
• 1,952
22
4,785
54
12-21
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
Pollutant
1,1-dichloroethene
1,2,4-trichloiDbenzene
1,2-dicWorobenzene
1,2-dicWoroe thane
1 ,4-dichlorobenzene
1,4-dioxane
1-methylfluorene
1-methylphenanthrene
2^-benzofluorene
2,4-dimethylphenor
2-butanone
2-isopropylnaphthalene
2-methylnaphthalene
2-propanone
3,6-dimethylphenanthrene
4-chloro-3-methylphenol
4-methvl-2-pentanone
CAS Number
75-35-4
120-82-1
95-50-1
107-06-2
10&46-7
123-91-1
1730-37-6
832-69-9
243-17-4
105-67^9
78-93-3
2027-17-0
91-57-6
67-64-1
1576-67-6
59-50-7
108-10-1
LTA for RCRA Facilities LTA for Non-RCRA Facilities
Without With Without With
Replacement Replacement Replacement Replacement
370
3,283
1,438
352
1,503
349
1,529
1,557
1,218'
• 1,266
17,599
• 8,649
6,955
158,534
1,194
12,407
6.496
275
2,921'
389
215
762
312
553
666
1,218
314
17,599
8,649
6,605
158,534
1,194
12,407
6.496
10
309
309
10
309
32
370
597
415
482
1,081
414
2,013
8,453
418
1,245
642
10
309
309
10
309
32 '
220
561
301
369
1,081
296
2,013
=8,453-
309
1,245
642
Estimation-of:Emulsion^Breaking£
Gravity Separation Loadings^
12.3.2.2
For the 1999 proposal, EPA randomly
assigned one of the seven emulsion
breaking/gravity separation data sets to each oils
facility for which EPA needed to estimate
current performance; however, the SBREFA
Panel raised the concern that this approach may
not have resulted in a representative assignment
of loadings. For the final rule, EPA has
developed another procedure to obtain average
concentrations using all seven data sets and the
characterization sampling described in Chapter 2.
The following explains EPA's final
procedure. To obtain estimates of current
pollutant loadings associated • with emulsion
breaking/gravity separation, EPA developed
estimates of the pollutant loadings at each of the
84 facilities identified as having wastestreams in
the oils subcategory. To obtain estimates of
pollutant loadings, EPA needed concentration
and flow information for all facilities. EPA had
flow information from all facilities, but had
varied data on pollutant concentrations from only
nineteen facilities where EPA had sampled the
emulsion breaking/gravity separation operations.
Section 12.3.2.1 describes these nineteen
concentration data sets. For each facility in
EPA°'s oils'subcategory database, EPA assigned
either the RCRA or non-RCRA long-term
average to the facility depending on its RCRA
status. Then, EPA estimated each facility's
pollutant loadings as the product of the total oils
wastewater flow at the facility and the pollutant
concentrations in its assigned data set.
Organics Subcategory Current
Loadings
12.3.3
EPA had limited available data from the
organics subcategory and very h'tfle data which
represent organic subcategory CWT wastewater
only. The vast majority of organic facilities
commingle large quantities of non-CWT
wastewater prior to the point of discharge.
Therefore, EPA estimated current loadings based
on the treatment technologies in place except for
the two facilities for which EPA has analytical
data representing organic subcategory
wastewater only.
Based on a review of technologies currently
used at organic subcategory facilities, EPA
placed in-place treatment for this subcategory in
12-22
-------
Chapter 12 Pollutant Loading and Removal Estimated Development Document for the CWT Point Source Category
one of five classes:
1) raw;
2) filtration only;
3) carbon adsorption;
4) biological treatment; and
5) biological treatment and multimedia
filtration.
The discussion below describes the
methodology EPA used to estimate current
loadings for-each-classification. Table 12-.8 lists
the current performance estimates for each
classification. This table does not include current"
loadingsestimates for all pollutants of concern in
the organics subcategory.
EPA used the first classification ("raw") for
seven- organic_ subcategory, -facilities, with-no.,
reported treatment in place for the reduction of
organic constituents. EPA based its current
loadings estimate for "raw wastewater" on EPA
sampling data at two organic. facilities. These
were Episode 1987, sample points OVAand 07B
and Episode 4472, sample point 01. Because the
data at Episode 4472 represents both organic and
oils subcategory wastes, the raw loadings for
metals pollutants were based upon the Episode
1987 data alone5.
For each episode and sample point, EPA
collected one composite sample for the entire
day. In addition, EPA collected a few field
duplicates that were also composite samples that
correspond to the pollutants of concern. EPA
then averaged duplicate samples before
performing any other calculations so that there
was only one daily average for each day for each
pollutant of concern.
For each pollutant of concern and each
facility, EPA calculated a long-term average as
the arithmetic average of the daily averages.
This mean includes measured (detected) and
EPA's data show that the concentration of
metal pollutants in oils subcategory wastes are generally
greater than in organics subcategory wastes.
non-detected values. For non-detected values,
EPA used the sample-specific detection limit.
For two cases where the resulted were reported
as non-detected, EPAused the baseline value for
the pollutant (described in section 15) because
the laboratory did not report the sample-specific
detection limits. These two cases were for
iodine and phosphorus at episode 1987.
Once EPA had calculated the long-term
average for each facility and each .pollutant of
concern, EPA then calculated the mean (that is,
arithmetic average) of the long-term averages
from the two facilities for each pollutant of
concern to estimate the "raw" current loadings
concentrations reported in Table 12-8.
EPA classified in the second category
("filtration only") three organic subcategory
facilities which only had multi-media or sand
filtration as the on-site treatment technology for-
the organic waste stream. For these facilities,
EPA adjusted the "raw wastewater"
concentrations to account for 55 percent removal
of TSS, 30 percent removal of metal parameters,
10 percent removal of BODS, and no removal of
other classical or organic pollutants. EPA
estimated the percent reductions for facilities in
this group using the procedure previously
described in Section 12.3.2.
EPA placed in the third category two organic
subcategory facilities with carbon adsorption
(usually preceded by sand or multi-media
filtration). EPA adjusted the "raw wastewater"
concentrations to account for 50 percent removal
of organic pollutants, and no removal of all other
pollutants. Again, EPA also estimated the
percent removals for facilities in this category
using the procedure previously described in
Section 12.3.2.
EPA based the current loadings
concentrations for the fourth and fifth
classification on EPA sampling data collected at
Episode 1987. EPA calculated the current
loadings estimates for each pollutant of concern
using a similar procedure to that described above
12-23
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTPoint Source Category
for the "raw" organics subcategory current
performance.
EPA based the percent removals for five
organic subcategory facilities in the fourth
classification (biological treatment) on analytical
data collected at sample point 12 at episode
1987. For the classicals, conventional, and
metals pollutants, if the long-term average at
sample point 12 was greater than the value at
sample point 7 at episode 1987, EPA used the
value of sample point 7. This is because the
treatment technology was ineffective for these
specific pollutants.
For the two organic subcategory facilities in
the fifth classification (biological treatment and
multimedia filtration) EPA based removals on
analytical data collected at sample point 14 for
conventional, classicals, and metals. EPA based
the removals for organics on the data collected at
sample point 12 because EPA did not analyze
any samples for organics from sample point 14.
This is because no additional organics removals
were expected between the two treatment steps.
12-24
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Catesorv
Table 12-8: Organics Subcategory Baseline Long-Term Averages
Pollutant
Raw
Filtration
Only
Carbon
Adsorption
Biological
Treatment
Biological
Treatment and
Multimedia
Filtration
CLASSICAL OR CONVENTIONAL PARAMETERS (mg/L)
Ammonia as nitrogen
Biochem. oxygen demand
Chemical oxygen demand
Fluoride
Nitrate/nitrite
Total cyanide
Total organic carbon
Total sulfide -
Total suspended solids
METAL PARAMETERS (ug/L)
Aluminum
Antimony
Arsenic
Barium" ~
Boron
Calcium
Chromium
Cobalt
Copper
Iodine
Iron
Lead
Lithium
Manganese
Molybdenum
Nickel
Phosphorus
Potassium
Silicon
Sodium
Strontium
Sulfur
Tin "
Titanium
Zinc
ORGANIC PARAMETERS (ug/L)
Acetophenone
Aniline
Benzene
Benzoic.acid
Bromodichloromethane
Carbon disulfide
Chlorobenzene
Chloroform
Dimethyl sulfbne
Ethylenethiourea
Hexachloroethane
Hexanoic acid
Isoohorone
5,680
24,224
75,730
" 7
93
3
31,804
4
1,319
4,808
687
74
28,343
3,490
1,249,000-.-
109
425
910-
6,270
3,833
340
9,730
292
1,765
1,632
5,740
973,600
2,590
4,459,000
6,870
1,283,960
. 670
27
781
1,481
1,350
2,765
9,914
542
626
535
7,039
1,449
4,383
1,311
2,051
2.006
5,680
21,802
75,730
7
93
3
31,804
4
725-
1,442
206
22~
.8,503
1,047
374,700
33
128
273-
1,881
• 1,150
102
2,919
88
529
490
1,722
292,080
777
1,337,700
2,061
385,188
201
8
234
1,481
1,350
2,765
9,914
'• 542
626
535
7,039
1,449
4,383
1,311
2,051
2006
5,680
24,224
75,730
7
93
3
31,804
4
' 1,319-
4,808
687
74
28,343
3,490
1,249,000
109
425
9-10-^
6,270
3,833
340
9,730
292
1,765
1,632
5,740
973,600
2,590
4,459,000
6,870
1,283,960
670
27
781
741
675
1,382
4,957
271
313
267
3,519
724
2,192
656
1,026
1 003
1,060
2,440
3,560
8
2
2
1,006
3
480
2,474
569
" : 74
2,766
3,490 •
286,000
109-
.425-
-. — .- 704—.
6,270
3,833
314
9,730
227
943
1,632
5,740
973,600
2,590
4,459,000
2,060
1,283,960
670
27
382
36
11
.10
.320
10
16
10
73
158
4,400
11
64
14
616.0
1,564.0
2,940.0
2.3
0;2
2.1
968.0
1'.8
399.2
291.0
92.0
80.0
1,120.0
3;090:0
641,000.0
54.0.-.
170.0
171:0—
5,800.0
2,040.0
66.0
9,400.0
360.0
253.0
1,850.0
1,700.0
971,000.0 .
1,600.0
5,310,000.0
6,000.0
563,000.0
789.0
19.0
127.0
35.9
10.5 .
10.0
320.0
10.0
16.5
10.0
72.6
. 157.7
4,400.2
10.5
64.0
13 9
12-25
-------
Chapter 12 Pollutant Loading and Removal Estimates . Development Document for the CWT Point Source Category
Pollutant
M-xylene
Methylene chloride
N,n-dirnethylforrnarnide
Ofpxylene
O-crcsol
P-crcsol
PentacMorophenol
Phenol
Pyridine
Tetrachloroethene
Tetrachlororaethane
Toluene
Trans-l,2-dichloroethene
TricWoroethene
Vinyl chloride
1 , 1 , 1 ,2-tetrachloroethane
1,1,1-trichloroethane
1,1,22-tetrachloroethane
1,1,2-trichloroethane
1,1-dichloroe thane
1,1-dichloroethene
1,23-tricnloropropane
1 ^-dibromoe thane
1,2-dichlorobenzene
1,2-dichloroe thane
1,3-dichloropropane
2^,4,6-tetrachlorophenol
2,3-dichIoroanfline
2,4,5-trichlorophenol
2,4,6-trichlorophenol
2,4-dimethylphenol
2-butanone
2-propanone
3,4,5-trichlorocatechol
3,4,6-trichloroguaiacol
3,4-dichlorophenol
3,5-dichlorophenol
3,6-dichlorocatechol
4,5,6-trichloroguaiacol
4,5-dichloroguaiacol
4-chloro-3-methylphenol
4-chlorophenol
4-methyl-2-pentanone
5-chloroguaiacol
6-chlorovaniJlin
Raw .
1,197
1,958,967
34,838
705
6,195
3,322
6,870
6,616
3,853
3,955
3,087
746,077 •
1,597 -
6,439
775
939
1,429
. 1,364
1,731
' 538
610
644
,2,406
2^37
• 4,478
533
3,728
1,401
1,411
1,462
1,402
59,796
6,848,786
10
4
144
69
3
14
2
1,342
3,770
3,312
598
8
Filtration
Only
1,197
1,958,967
34,838
705
6,195
3322
6,870
6,616
3,853
3,955
3,087
746,077
1,597" "
6,439
775
939
1,429
1,364
1,731
538
610
644
2,406.
2^37 "
4,478
533
3,728
1,401
1,411
1,462
1,402
59,796
6,848,786
10
4
144
69
3
14
2
1342
3,770
3,312
598
8
Biological
_ . „.,.,' Treatment and
Carbon Biological - . . ,. .
Multimedia
Adsorption Treatment _..
Filtration
599
979,483
17,419
352
3,098
1,661
3,435-
3^08
1,927
1,978
1,544
373,039
799' "
3,220
388
469
714
682
865
269
305
322
1,203. .
1,118
2,239
266
1,864
701
706
731
701
29,898
3,424,393
' 5 .
2
- 72
35
2
7
1
671
1,885
1,656
299 .
• 4
10
204
11
10 •
185
66
791
362
116
112
14
10
22
69
10
10
10
10
13
10
10
10
10
15
10
. 10
629
23
97
86
11
878
2,061 •
1
1
30
1
1
1
13
64
243
146
' 1,595
1
10.0
204.5
10.5
10.0
184.8
66.2
791.1
362.0
116.5
112.1
14.4
10.0
21.5
69.4
10.0
10.0
io.o
10.0
13.3
10.0
10.0
10.0
10.1
15.1
10.0
10.0
629.0
23.0
96.8
85.8
10.5
878.1
2,061.3
0.8
0.8
30.4
0.8
0.8
0.8
12.9
64.0
242.5
146.2
1,595.0
0.8
12-26
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTP.oint Source Catezorv
METHODOLOGY USED TO ESTIMATE
POST-COMPLIANCE LOADINGS
12.4
Post-compliance pollutant loadings for'each
regulatory option represent the total industry
wastewater pollutant loadings after
implementation of the rule. For each option,
EPA determined an average performance level
(the "long-term average") that a facility with well
designed and operated - model technologies
(which reflect the appropriate level of control) is
capable of achieving. In most cases, EPA
calculated these long-term averages using data
from CWT facilities operating model
technologies. For a few parameters, EPA
determined that CWT performance was
uniformly inadequate and transferred effluent
long-term averages from other sourcesr
To- estimate- post-compliance pollutant
loadings for each facility for a particular option,
EPA used the long-term average concentrations,
the facility's annual wastewater discharge flow,
and a conversation factor in the following
equation:
Postcompliance long- term average concentration (mg / L.) *
Facility annual dischargeflowfL/ yr)*
*' 453,600mg
= Facility postcompliance annual loading (Ibs / yr)
standards and limitations take into account the
level of treatment variation well within the
capability of an individual CWT facility to
control. If a facility is designed and operated to
achieve the long-term average on a consistent
basis, and if the facility maintains adequate
control of treatment variation, the allowance for
variability provided in the limitations is sufficient.
Table 12-9 presents the long-term averages
for the-selected-option for each subcategory.
. The pollutants for which data is presented in
Table 12-9 represent the pollutants of concern at
treatable levels at the facilities which form the
basis of the options. The pollutants selected for
regulation are a much smaller subset.
EPA expects that all facilities subject to the
effluent limitations and standards will design and
operate their treatment systems to achieve the
long-term average performance level on a
consistent basis because facilities with well-
designed and operated model technologies have
demonstrated that this can be done. Further,
EPA has accounted for potential treatment
system variability in pollutant removal through
the use of variability factors. The variability
factors used to calculate the limitations and
standards were determined from data for the
same facilities employing the treatment
technology forming the basis for the rule.
Consequently, EPA has concluded that the
12-27
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
Table 12-9. Long-Term Average Concentrations (ug/L) for All Pollutants of Concern
Pollutant of Concern
Ammonia as nitrogen
Biochem. oxygen demand
Chemical oxygen demand
Chloride
Fluoride
Hexavalent chromium
Nitrate/nitrite
Oil and Grease
SGT-HEM
Total cyanide
Total dissolved Solids
Total organic Carbon
Total phenols
Total phosphorus
Total sulfide
Total suspended solids -
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron'
Cadmium
Calcium
Chromium
Cobalt
Copper
Gallium
Germanium
Indium
Iodine
Indium
Iron
Lanthanum
Lead
Lithium
Lutetiuin
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Osmium
Phosphorus
Potassium
Selenium
Silicon
Metals Metals Option 4
Options BPT/BAT/
.NSPS , PSES/PSNS
9.12
28.33
198.56
2,243.75
2.35
0.03
12.61
Failed tests
Failed tests
18,112.50
19.64
Failed tests
29.32
24.95
9.25
72.56
21.25-
11.15
1.00
7,290.00
81.93
407,166.67
39.75
57.42
169.03
Failed tests
500.00 '
Failed tests
Failed tests
387.21
100.00
55.11
Failed tests
752.54
11.62
0.20
527.69
254.84
100.00
544.00 '
54,175.00
56.25
355.75
15.63
159.60
1,333.33
, 18,000.00
66.27
0.80
531.67
1 34.34
0.17
42,566.67
236.33
Failed tests
31.68
Failed tests
16.80
856.33
170.00
Failed tests'
'Failed tests
8,403.33
58.03
20,000.00
1,674.50
114.50
744.16
Failed tests
Failed tests
Failed tests
500.00
5,752.34
Failed tests
176.75
1,926.67
Failed tests
48.70
0.56
1,746.67
1,161.49
Failed tests
27,529.03
• 410,000.00
279.80
1.446.67
Oils Oils Option 9
Option 8 BPT/BAT/
PSES NSPS/PSNS
184.38
7,621.25
17,745.83
1,568.75
36.25
46.21
No data
142.80
0.11
Failed tests
3,433.75
17.84
37:03^.
No data
14,072.50
103.06
. 789.33
220.50
22,462.50
7.46
' 172,787.50
323.40
7,417.04
256.66
Failed tests
53,366.67
148.70
Failed tests
62,900.00
5,406.46
3.09
1,542.75
1,473.92
44,962.08
411,750.00
107.49
19.000.00
97.22
7,621.25
20,490.00
1,568.75
36.25
20.75
28.33
42.53
0.11
Failed tests
5,578.88
20.16
31.36
25.50
14,072.50-
- 103.06
: 789.33
220.50
22,462.50
7.46
172,787.50
183.13
7,417.04
156.75
Failed tests
53,366.67
98.58
Failed tests
,62,900.00
5,406.46 .
3.09
1,542.75
1,473.92
44,962.08
411,750.00
107.49
19.000.00
Orgamcs
Option 4
ALL
1,060.00
41.00
3,560.00
Failed tests
2.28
2.18
1,006.00
2.80
45.00
2,474:00-
569.40
Failed tests
Failed tests
Failed tests
,
286,000.00
Failed tests
437.20
. 703.60
Failed tests
3,948.00
, Failed tests
Failed tests
227.00
942.80
Failed tests
Failed tests
Failed tests
2.680.00
12-28
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
Pollutant of Concern
Silver
Sodium
Strontium •
Sulfur
Tantalum
Tellurium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Zirconium
Acenaphthene
Acetophenone
Alpha-terpineol
Aniline
Anthracene; • .- -
Benzene
Benzo(a)anthracene
Benzoic acid
Benzyl alcohol
Biphenyl
Bis(2-ethylhexyl) pjithalate
Bromodichloromethane
Butyl benzyl phthalate
Carbazole
Carbon disulfide
Chlorobenzene
Chloroform
Chrysene
Dibenzofuran
Dibenzothiophene
Dibromochloromethane
Diethyl phthalate
Dimethyl sulfbne
Diphenyl ether
Ethylbenzene
Ethylenethiourea
Fluoianthene
Fluorene
Hexachloroethane
Hexanoic acid
Isophorone
M+p xylene
M-xylene
Methylene chloride
N,n-dimethylformamide
N-decane
Metals Metals Option 4
Option 3 BPT/BAT/
NSPS PSES/PSNS
4.50
5,776,250.00
Failed tests
2,820,000.00
Failed tests
Failed tests
20.79
28.25
3.50
11.00
3.50
206.22
Failed tests
........
- -
Failed tests-
Failed tests
Failed tests
10.00
Failed tests '
Failed tests
Failed tests
Failed tests
Failed tests
Failed tests
26.44
15,100,000
100.00
1,214,000.00
Failed tests
Failed tests
Failed tests
89.77
56.87
11.93
5.00
413.27
1,286.67
3,521.67
Failed tests
Failed tests
Failed tests
148.61
50.45
Failed tests
Failed tests
Failed tests
68.13
Oils Oils Option 9
Option 8 BPT/BAT/
PSES NSPS/PSNS
Failed tests
Failed tests
774.63
Failed tests
Failed tests
_..106.97
21.73 '
3,448.54
137.27" '"
48:33
Failed tests -
16427
1,058,81
106.76
25,581.42'
Failed tests
76.21
115.74
54.98 '
151.45
28.11
87.48
379.09
79.43
135.25
'95.76
759.14
Failed tests
971.29
253.37
243.11
9,253.62
422.95
1,520.33
. 4,242.03
Failed tests
2.369.97
Failed tests
Failed tests
774.63
Failed tests
, Failed tests
106.97
21.73
3,138.75
137.27
48.33-
Failed tests
90r71
1,058.81
'" 59.71
37,349.63
80:65
135.71
62.8T
54.98
151.45
28.11
87.48
379.09
48.48
135.25
59.44
365.93
981.54
423.30
17.29
129.60
9,253.62 '
422.95
940.96
4,242.03
Failed tests
238.16
Organics
Option 4
ALL
Failed tests
2,060.00
1,370,000.00
Failed tests
Failed tests
381.80
35.87
10.50
10.00
320.00
Failed tests
Failed tests
Failed tests
72.62
157.70'
4,400.23
Failed tests
64.00
Failed tests
10.00
204.48
10.50
12-29
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
Metals Metals Option 4 Oils Oils Option 9
Options BPT/BAT/ Option 8 BPT/BAT/
Pollutant of Concern NSPS PSES/PSNS PSES NSPS/PSNS
N-docosane
N-dodecane
N-eicosane
N-faexacosane
N-hexadecane
N-octacosane
N-octadecane
N-tetracosane
N-tetradecane
Naphthalene
Ofpxylene
0-cresol
O-toluidine
O-xylene
P-cresol
P-cymene,
Pentachlorophenol
Pentaraethylbenzene
Phcnanthrene
Phenol Failed tests
Pyrene
Pyridine Failed tests
Styrene-
Tetrachloroethene
Tetrachloroniethane
Toluene Failed tests
Trans-l,2-dichloroethene
Trichloroethene Failed tests
Tripropyleneglycol methyl ether
Vinyl chloride
1,1,1,2-tetrachloroethane
1,1,1-trichloroethane Failed tests
1,1,2,2-tetrachloroethane
1,1,2-trichloroethane
1,1-dichloroethane
1,1-dichloroethene Failed tests
1 A3-trichloropropane
1,2,4-trichlorobenzene
1,2-dibromoethane
1,2-dichlorobenzene
1 ,2-dichloroethane
1 ,3-dichloropropane
1 ,4-dichlorobenzene
1,4-dioxane Failed tests
1-melhylfluorene
1 -methy Iphenanthrene
23,4,6-tetrachlorophenol
2,3-benzofluorene
23-dichloroaniline
75.33
3,834.84
615.76
Failed tests
, 1,386.70
Failed tests
792.62
Failed tests
1,820.50
1,014.23
1,873.00
Failed tests
Failed tests
268.52
630.49
55.59,,
48.33-
649.72
Failed tests Failed tests
131.77
86.97 624.78
56.991
' 475.45
Failed tests 6,104.68
441.63 669.61
478.50
Failed tests 162.78
•
Failed tests 219.48
117.45'
48.33-
272.57
87.35
Failed tests Failed tests
48.33
76.32
Failed tests ,
20.77
233.80
51.76
Failed tests
2,551.36
Failed tests
202.66 ,
Failed tests
3,303.90
248.73
1,218.53
1,769.86
Failed tests
268.52
956.84
55.5a
48.33
81.76
30,681.00-
58.00
624.78
56:99
475.45
3,613.18
669.61
478.50 •
162.78
219.48
' 117.45
48.33
272.57
87.35
Failed tests
. 33.65 .
54.47
54.98
Organics
Option 4
ALL
Failed tests
184.78
66.24
, 791.15
362.03 -
116.46"-
112.09
14.44
10.00
21.51
69.42
10.00
10.00
10.00
Failed tests
13.30
10.00
10.00
10.00
10.14
Failed tests
10.00
Failed tests
628.96
23.04
12-30
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Cateeorv
Pollutant of Concern
2,4,5-trichlorophenol
2,4,6-trichlorophenol ,
2,4-dimethylphenol
2-butanone
2-isopropylnaphthalene
2-methylnaphthalene
2-propanone
3 ,4,5-trichlorocatechol
3,4,6-trichloroguaiacol
3,4-dichlorophenol
3,5-dichlorophenol
3,6-dichlorocatechor '
3,6-dimethylphenanthrene
4,5,6-trichloroguaiacol
4,5-dichIqroguaiacol
4-chloro-3-rnethylphenol
4-chlorophenol
4-methyl-2-pentanoner :
5-cWoroguaiacol -
6-chlorovanillin
Metals Metals Option 4 Oils Oils Option 9
Options BPT/BAT/ Option 8 BPT/BAT/
NSPS PSES/PSNS PSES NSPS/PSNS
Failed tests
Failed tests 1,272.48 11,390.45
Failed tests
1,540.02
Failed tests 13,081.47 failed tests
Failed tests
Failed tests
Failedtests- Failed-tests' 7,848.00
Failed tests
11,390.45
Failed tests
160.58
Failed tests
52.33
655.39
6,624.87
Organics
Option 4
ALL
96.76
85.76
Failed tests
878.12
2,061.28
0.80
Failed tests
30.40
0.80
Failed tests
Failed tests-
Failed tests
Failed tests
242.50 '
146.16
Failedtests -
Failed test
'As explainedin section 10, EPA used the long-term average from metals option'l A for arsenic even though the option 4 data
failed the test. • , '
A blank entry indicates the analyte is not a pollutant of concern for the subcategory.
12-31
-------
Chanter 12 Pollutant Loadine and Removal Estimates Development Document for the CWT Point Source Category
METHODOLOGY USED TO ESTIMATE
POLLUTANT REMOVALS
12.5
For each regulatory option, the difference
between baseline loadings and post-compliance
loadings represent the pollutant removals. For
direct discharging CWT facilities, this represents
removals of pollutants being discharged to
surface waters. For indirect dischargers, this
represents removals of pollutants being
discharged to POTWs less the removals
achieved by POTWs. EPA calculated the
pollutant removals for each facility using the
following equation:
Baseline Loadings- Postcompliance Loadings
= Pollutant Removals
EEA-Used the following methodology to
estimate pollutant removals:
1) If the post-compliance loading .of a pollutant
was higher than the baseline loading, EPA
set the removal to zero;
2) If EPA did not identify a particular pollutant
in the wastewater of a facility at baseline and
that pollutant was present at baseline in the
wastewater of a facility used as the basis for
determining limitations and standards
associated with one of the regulatory
options, EPA set the removal to zero.);
3) If EPA did not calculate a long-term average
for a pollutant for a technology option (i.e.,
the post-compliance loading for the pollutant
could not be calculated), EPA set the
removal to zero; and
4) For indirect dischargers, EPA additionally
reduced the pollutant removal estimate by
the POTW removal percentage. Therefore,
the pollutant removal estimates for indirect
.dischargers only account for pollutant
removals over and above the POTW
removals.
POLLUTANT LOADINGS AND REMOVALS 12.6
EPA estimated annual baseline and post-
compliance loadings for each of the
subcategories and the respective regulatory
options using the methodology described in
Sections 12.3 through 12.5 of this document.
For the oils subcategory, EPA extrapolated the
facility-specific loadings and removals from the
84 in-scope discharging facilities to provide
estimates of an estimated total population of 141
discharging oils facilities. Facilities with no
wastewater discharge ("zero dischargers") have
no pollutant loadings or removals.
. Tables 12-10 through 12-13 present the total
baseline and post-compliance loadings and-the_
pollutant removals for the facilities -in each
subcategory;
12-32
-------
Chapter 12 Pollutant Loading and Removal Estimates .Development Document for the CWTPoint Source Category
Table 12-10. Summary of Pollutant Loadings and Reductions for the CWT Metals Subcategory7
Pollutant of Concern
Current Wastewater Pollutant
Loading
flb/vr)
Direct . Indirect
Dischargers Dischargers
Post-Compliance
Pollutant Loading
flb/vr)
Direct Indirecl
Dischargers Dischargers
Post-Compliance Pollutant
Reductions
flb/vr)
Direct Indirect
Dischargers Dischargers
CONVENTIONAL OR CLASSICAL PARAMETERS
Ammonia as N
BODj
COD
Cyanide, total
•HEM (oil & grease)-'
Hexavalent chromium
Nitrate/nitrite
Phenols, total
Phosphorus, total
Sulfide, total (lod.)
TDS
TOC
TSS
991,937
13,300,815
35,051,565
6,213
224,690
169,960
8,966,661
17^13
242,069
111,051
191,398,163
9,580,389
5,533,906
N/A
N/A
N/A
497
N/A
15,789
N/A
- - - • 4,760
171,842
2,690
190,280,123
3,693,856
. N/A"
60,504
576,413
4,791,127
539
121,568
2,425
1,867,927
2,917
129,555
111,051
160,479,788
839,288
64,680
N/A
N/A
N/A •
58
N/A
2,841
N/A
660
127,905
2,690
158,109,561
283,579
N/A
931,432
. 12,724,402
30,260,438
5,674
103,122
167,535
7,098,734
14397
112,514
0
30,918,375
8,741,101
5,469,226
. N/A
N/A
N/A
440
N/A
12,948
N/A
4,099
43,937
0
32,170,561
" 3,410,277
N/A
METAL OR SEMI-METAL PARAMETERS
Aluminum
Antimony
Arsenic
Beryllium
Boron
Cadmium
Calcium
Chloride
Chromium
Cobalt
Copper
Fluoride
Indium
Iron
Lead
Lithium
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Potassium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Tin
Titanium
Vanadium
Yttrium
Zinc
Zirconium
ORGANIC PARAMETERS
Benzoic acid
137,478
20399-
7,330
20
127,035
71,235
11,008,982
123,304,754
126,679
43,211
299,047
365,007
22,404
192,066
24,634
100,202
44,670
26,434
86
23,596
101,936
1,166,861
6,805,699
1,307
38,467
772
64,553,546
16,574
9,513,625
111,997
62,688
. 3,733
131
245,781
5,317
16,016
9,521" -
' -4,839
. 297
6
100,693
546...
13,016,845
106,487,827
' 4,925
1,444
1,838
103,061
4,731,
11,439
1,571
90,690
20,253
4,068
7"
17,528-
33,817
215,032.
5,095340
833
12,245
94
66,330,106
17380
6,341,910
5,861
136
238
97
3,655
2,324
2331
3;042~
608
507
20
34,055
240
82,743
64350,877
- 5,883
437
2,419
192,226
2,069
20,370 '
654
7,971
44,670
178
2
6,447
4,226
96,649
1,468,873
1,008
5,288
95
56,513,563
414
5,022,530
332
195
49
20
1,577
5,278
10.455
299'
228
194
6
25,900
23
73,852
54,743,908
• 1,330
415
449
97,935
525
4,183
161
5,756
20,253
'127
0.2
5,717
2,201
33,988
1,001,254
736
4,247
13
59,324,636
344
. 4,199,022
208
19
44 '
16
- 348
2,314
1.729
• 134;43~6~
19,791
6,823
o"
92,981
70,995
10,926,239
58,953,877
120,796
42,773
296,628
172,781
20336
171,696
23,980
92,231
0
26,256
84
17,148
97,710
1,070,211
5,336,826
300'
33,179
677
8,039,983
16,160
4,491,095
111,665
62,493
3,684
112
244,204
39
5.562
9,223
4,61 1"
102
0
74,793
. 523
12,942,993
51,743,920
3,596
1,029
1,389
5,126
4,207
7,256
1,411
84,933
0
3,941
7
11,811
31,616
181,044
4,094,086
98
7,998
82
7,005,470
17,036
2,142,889
5,653
117
194
81
3,307
10
602
12-33
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
Table 12-10. Summary of Pollutant Loadings and Reductions for the CWT Metals Subcategory7
Pollutant of Concern
Butanone
Carbon disulfide
Dibromochloromethane
Methylene chloride
N,n-nitrosomorpholine
N^i-dimethyl&nnamide
Pyridine
Toluene
Trichloroethylene
1,1-dichlroethene
1,1,1-trichloroethane
2-Propanone
Current Wastewater Pollutant
Loading
flb/vrt
Direct Indireci
Dischargers Dischargers
1,592 40
561 132
. 316 . 69
462 261
240 50
453 75
278 14
1,072 54
572 58
438- ' 143
352 44
18.231 2.393
Post-Compliance
Pollutant Loading
Ob/vr)
Direct Indireci
Dischargers Dischargers
1,592 40
561 , 132
172 34
462 261
240 50
282 42
278- 14
1,072 54
572 58
438 143
352 44
18.231 2.393
Post-Compliance Pollutant
Reductions
flb/vr)
Direct Indirect
Dischargers Dischargers
0 0
0 0
144 36
0 0
• o o
171 33
0 0
0 0
0 0
0 0
0 0
0 0
'All loadings and reductions take into account the removals by POTWs for indirect dischargers.
JHEM - Hexane Extractable Material
12-34
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
Table 12-11. Summary of Pollutant Loadings and Reductions for the CWT Oils Subcategory7
Pollutant of Concern
Current Wastewater Pollutant
Loading
flb/vr)
Direct Indireci
Dischargers Dischargers
Post-Compliance
Pollutant Loading
flb/vr)
Direct Indirec
Dischargers Discharger
Post-Compliance Pollutant
Reductions
Ob/vr)
Direct Indirect
Dischargers Dischargers
CONVENTIONAL OR CLASSICAL PARAMETERS
Ammonia as Nitrogen
BOD5
COD
Cyanide, Total
HEM(and O&G)-'
Nitrate/Nitrite
Phenols, Total
Phosphorus; Total ,
SGT-HEM
TDS
TOC
TSS
11,783
1,502,944
8,008,834
3
206,539
732
- 924
547,900"
116,841
i;i80,709
1,662,244
428,553
499,382
N/A
N/A
137
N/A
N/A
32,528
14,017,083
N/A
N/A
•N/A
N/A
11,783
1,411,602
4,032,459
3
5,574
732
924
6,171
8,370
1,180,709
1,097,930
96,593
.. 499,382
N/A
N/A
84
N/A
N/A
22,118
309,268-
N/A
-N/A
N/A
. N/A
0
91,343
3,976,375
0
200,965
0
0.
541,729
108,472
0
564314
331,960
0
.N/A
N/A
54
N/A'
N/A
10,410
13,707,815
N/A
N/A
' N/A
N/A
METAL OR SEMI-METAL PARAMETERS-- v---
Aluminum
Antimony
Arsenic
Barium
Boron
Cadmium
Chromium
Cobalt
Copper
Germanium
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Selenium
Silicon
Silver
Strontium
Sulfur
Tin
Titanium
Zinc
ORGANIC PARAMETERS
Acenapthene
Alpha-terpinol
Aniline
Anthracene
Benzene
Benzo(a)anthracene
Benzoic Acid
7,302
38
12:"
98
18,093
4
32
306
123
3,073
8,321
143
19,339
406
3
683
174
3,381
3
2,333
1
17
22,274 .
22.,
9
2,131
2
7
2
4
12
4
358
19,032
412
845
2,814
499,752
35
800
• 15,055
3,239
37,018
98,443
2,989
468,308
14,539
7'
15,709
18,430
63,798 .
161
87,686
101
2,658
3,338,602
1,486
64
. 20,399
38
133
40
126
427
32
13.156
2,714
19
12
42
14,479
1
32
306
22
3,073
4,275
19
11,369
406
1
291
174
3,381
3
2,333
1
17
22,274
19
:4
399
2
7
2
4
12
4
358
8,729~
234'
589
754
372,148
' 6_
301
15,055
325
37,018
55,072
280
342,703
12,004
2
8,521
3,785
48,447
157
64,452
101
1,616
3,338,602
397
14
5,666
11
117
40
43
221
17
13.156
'" 4,589
19
0
56
3,615
: 3
0
0
101
0
4,046
124
7,970
0
2
392
0
0
0
0
0
Q
0
3
5
1,732
0
0
0
0
0
0
0
10303"
178
256
2,061
127,604
30
500
0
2,914
0
43,371
2,709
125,605
2,534
5 .
7,188
14,645
15,351
4
23,234
0
1,042
0
1,089
50
14,734
27
16
- 0
83
206
15
0
12-35
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTPoint Source Category
Table 12-11. Summary of Pollutant Loadings and Reductions for the CWT Oils Subcategory7
Pollutant of Concern
Benzyl alcohol
Biphenyl
Bis(2-Gthylhexyl) phthalate
Butyl benzyl phtbalate
Carbazole
Carbon disulfide
Chlorobenzene
Chloroform
Chryscne
Di-n-butyl phthalate
•Dibcnzofuran
Dibenzothiopene
Dielhyl phthalate
Diphenyl ether
Ehtylbenzene
Fluoranthcne
Fluorcnc
Hexanoic acid
O+p-xylene
N-decane
N-docosane
N-dodecane
N-eicosane
N-hexacosane
N-hexadecane
N-octadecane
N-tetracosane
N-tetradecane
Npi-dimethylibnnamide
Naphthalene
O-cresol
M-xylene
P-cresol
P-cymene
Pentamethylbenzene
Phenanthrene
Phenol
Pyrene
Pyridine
Styrene
Tetrachloroethylene
Toluene
Trichloroethene
Tripropyleneglycol methyl ether
1-mcthylfluorene
1 -methylphenanthrene
1,1-dichloroethene
1 , 1 , 1 -trichloroethane
1 ,2-dichloroethane
Current Wastewater Pollutant
Loading
* Ob/vrt
Direct Indireci
Dischargers Dischargers
30
26
33
54
2
5
0
0
6
0
1
6
5
_ • 36-
9
2
3"
1,239
11
45
108 '
251
36
10
1,926
155
12
1,139
2
69
30
10
23
20
7
21
376
34
1
4
40
44
0
108
5
13
0
1
0
958
173
31,747
793
425
171
8
193
. 55
9
45
247
1,209
106
520
2,189
796
26,763
2,835
99,608
1,972
5,811
3,525
899
116,435
33,731
1,187
123,887
116
1,364
2,588
563
1,226
8
297
528
2,735
1,174
37
65
1,297
1,477
175
36,509
223
402
128
303
37
Post-Compliance
Pollutant Loading
flb/vr>
Direct Indirec
Dischargers Discharger:
16 958
26 24
12 388
11 26
2 260
5 37
0 -- .., , 6
0 167
6 19
Post-Compliance Pollutant
Reductions
flb/vr)
Direct Indirect
Dischargers Dischargers
14 0 .
1 150
21 31,360
43 767
0 165
0 135
0 1
0 26
0 36
0 9, 0 0
1 13
6 105
5 -•• 841
36 — — ... 106
9 230
2 581
' 3- ' " 331
0 32
0 141
0 369
0 0
0 290
0 1,608
0 465
1,239 - 8,878- • 0 17,885-
11 1,830
45 11,667
4 75
46 1,421
10 342
10 899
502 3,343
40 1,894
12- 1,187
650 4393
2 116
49 406
30 2,588
10 255
23 966
11 1
7 35
16 209
376 2,735
11 176
1 37
4 . 27
. 40 546
44 787
0 149
93 1,888
5 60
11 95
0 128
1 61
0 17
0 1,005
0 87,941
104 1,897
205 4,390
26 3,183
0 0
1,424 113,092
115 31,837
0 0
48? 119,494
0 . 0
20 958
0 0
0 308
0 260
9 7
0 262
5 319'
0 0
23 999
0 . 0
0 39
; 0 751
0 690
0 26
16 34,620
0 163
2 '.' 307
0 1
0 242
0 21
12-36
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Catesorv
Table 12-11. Summary of Pollutant Loadings and Reductions for the CWT Oils Subcategory7
Pollutant of Concern
1 ,2,4-hichlorobenzene
1 ,4-dichlorobenzene
1,4-dioxane
2,3-benzofluorene
2,4-dimethylphenol
2-methylnaphthalene
2-phenylnaphthalene
2-propanone
3,6-dimethylphenanthrene
4-methvl-2-nentanone
Current Wastewater Pollutant
Loading
flb/vrt
Direct Indirec
Dischargers Dischargers
7 435
7 956
1 296
..7 239
8 747
46 11,115
3 317
191 41345
7 407
28 7,996
15 1 369
Post-Compliance
Pollutant Loading
flb/vrt
Direct Indirec
Dischargers Discharger:
7 58
7 319
1 296
7 239
8 747
32 6,500
3 317
191 41,345
......7 . 407
28 7,996
15 1 369
Post-Compliance Pollutant
Reductions
flb/vrt
Direct Indirect
Dischargers Dischargers
0 377
0 637
0 0
0 0
0 0
14 4,615
0 0
0 . 0
0 0
0 0
0 0
'All loadings and reductions take into account the removals by POTWs for indirect dischargers.
-HEM - Hexane Extractable Material
12-37
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWTPoint Source Category
Table 12-12. Summary of Pollutant Loadings and Reductions for the CWT Organics Subcategory
Pollutant of Concern
Current Wastewater Pollutant
Loading
flb/vrt
Direct Indirect
Dischargers Dischargers
Post-Compliance
Pollutant Loading
flb/vr)
Direct Indirec
Dischargers Dischargers
Post-Compliance Pollutant
Reductions
flb/vrt
Direct Indirect
Dischargers Dischargers
CONVENTIONAL OR CLASSICAL PARAMETERS
Ammonia as N
BODj
COD
Cyanide
TOC
TSS
METAL OR SEMI-METALJBARJ
Aluminum
Antimony
Calcium
Cobalt
Copper
Iron
Manganese
Molybdenum
Silicon
Strontium
Sulfur
Zinc
ORGANIC PARAMETERS
Acetophenone
Benzene
Chloroform
Hexanoic acid
Methylene chloride
M-xylene
O-cresol
Pentachlorophenol
Phenol
Pyridine
P-cresol
Tetrachloroethene
Tetrachloromethane
Toluene
Trans-l,2-dichloroethene
Trichloroethene
Vinyl chloride
1 , 1 , 1 ,2-te trachloroethane
1,1,1-trichloro ethane
1,1,2-tricHoroethane
1,1-dichloroethene
1 ,2,3-trichloropropane
1 ,2-dibromoethane
1 ,2-dichloroethane
2,3,4,6-tetrachlorophenol
2,3-dichloroaniline
2,4,5-trichlorophenol
2-butanone
2-propanone
4-methvl-2-rientanone
138,389
318,555
464,777
285
131,339 '
62,667
^METERS,
323
74
1 37^39
57
92
515
30
123
350
269
178,861
50
5
• 1 '
' 9
8
27
1
24
103
47
15
9
15
2
1
3
9
1
1
1
2
1
• 1
1
1
82
3
13
115
269
19
1,076,771
833,340
4,396,709
308
2,934,599
- 42,088
312
57
276,063
92
40-
457
143
381
724
1,835
356,145
50
20
120
" .942 "
99
262,279
637
863
1,758
92
52
277
. 407
289
8,377
570
'443
114
796
182
879
412
1,596
1,821
307
739
252
302
1,011
362,747
1.022
138,389
318,555
464,777
285
131,339
62,667
323
74
37^39
57
92
515
30
'123
350
269
178,861
50
5
1
9
8'
27
1
24
103
47
15
9
15
2
1
3
9
2
1
82
3
13
115
269
19
582,889
488,569
2,033,935
278
1,332,109
26,739
277
50
121,864
92
35
457 .
136
264-
724
1,118
356,145
35
9
95
618
44
105,492
565
363
841
40
22
115
304
224 ,
3,387
490
297
105
723 -
159
747
386
1,490
1,473
221
375
109
136
661
167,960
955
0
0
0
0
0
0
0
0
0
. 0
0
0-
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
• o
0
0
0
493,881
344,770
2,362,774
31
1,602,490
15,350
35
7
154,199
0
6
0
7
117
0
' 717
0
15
12
25
324
56
156,788
72
500
917
52
30
161
104
65
4,990
80
147
9
73
24
132
26
105
348
86
364
143
166
351
194,787
67
'All loadings and reductions take into account the removals by POTWs for indirect dischargers.
12-38
-------
Chapter 12 Pollutant Loading and Removal Estimates Development Document for the CWT Point Source Category
Table 12-13. Summary of Pollutant Loadings and Reductions for the Entire CWT Industry7
Pollutant of Concern*
CONVENTIONALS
PRIORITY METALS
NON-CONVENTIONAL METALS*
PRIORITY ORGANICS
NON-CONVENTIONAL
ORGANICS
Current Wastewater
Pollutant Loading
flb/vr)
Direct Indirect
Dischargers Dischargers
Post-Compliance
Pollutant Loading
Ob/vrt
Direct Indirec
Dischargers Discharger;
Post-Compliance Pollutant
Reductions
flb/vrt
' Direct Indirect
Dischargers Dischargers
21,578,700 N/A 2,657,700 N/A 18,921,000 N/A
901,300 99,800 18,000 17,100 883,300 82,700
1,018,500 1,565,400 171,900 992,000 846,500 573,300
3,900 . 326,700 3,700 122,700 100 204,000
44,200 915,100 35,900 295,200 8,300 619,900
'All loadings and reductions take into account the removals by POTWs for indirect dischargers.
-Note the following are not included: cyanide, total phosphorus, total phenols, TOC, COD, TDS, Ammonia as N, and other
nonconventional classical parameters .
•'Does not include calcium, -chloride, fluoride, phosphorus, potassium, sodium, and sulfur
12-39
-------
-------
Chapter
13
NON-WATER QUALITY IMPACTS
Sections 304(b) and 306 of the Clean Water
Act provide that non-water quality
environmental impacts are among the factors
EPA must consider in establishing effluent
limitations guidelines and standards. These
impacts are the environmental consequences not
directly associated with wastewater that may be
associated with, the regulatory options
considered.- For this rule, EPA evaluated the
potential effect of the selected options on air"
emissions, solid waste generation, and energy
consumption.'
This section quantifies the non-water quality
impacts associated with the options considered •
for the final rule. Cost estimates' for the impacts,
and the methods used to estimate these costs, are
discussed in Chapter 11 of this document. In all
cases, the costs associated with non-water
quality impacts were included in EPA's cost
estimates used in the economic evaluation of the
promulgated limitations and standards.
Am POLLUTION
13.1
CWT facilities receive and produce
wastewaters that contain significant
concentrations of organic compounds, some of
which are listed in Title 3 of the Clean Air Act
Amendments (CAAA) of 1990. These
wastewaters often pass through a series of
collection and treatment units. These units are
open to the atmosphere and allow wastewater
containing organic compounds to contact
ambient air. Atmospheric exposure of the
organic-containing wastewater may result in
significant water-to-air transfers of volatile
organic compounds (VOCs).
The primary sources of VOCs in the CWT
industry are the wastes treated in the oils and the
organics subcategory. In general, CWT facilities
have not installed air or wastewater treatment
technologies designed to control.the release of
VOCs to the atmosphere. Additionally, most
CWT facilities do not employ best management
practices designed to control VOC emissions
— (such as covering their -treatment tanks).
Therefore, as soon as these VOC-containing oil
and organic subcategory wastewaters contact
ambient air, volatilization will begin to occur.
Thus, volatilization of VOCs andUAPs from
wastewater may begin immediately on receipt, as~
the wastewater enters the CWT facility, or as the
wastewater is discharged from the process unit
Emissions can also occur from wastewater
collection units such as process drains, manholes,
trenches; sumps, junction boxes, and from
wastewater treatment units such as screens,
settling basins, equalization basins, biological
aeration basins, dissolved ak flotation systems,
chemical precipitation systems, air or steam
strippers lacking air emission control devices, and
any other units where the wastewater is in
contact with the air. In some cases, volatilization
will begin at the facility and continue as the
wastewaters are discharged to the local river or
POTW.
As discussed in 1999 proposal, EPA
considered including air stripping in the
technology basis for the final limitations and
standards, but rejected it because it would not
have resulted in significantly different limitations.
Because this rule would not allow any less
stringent control of VOCs than is currently in
place at most CWT facilities, EPA does not
13-1
-------
Chapter 13 Non-Water Quality Impacts Development Document for the CWT Point Source Category
project any net increase in air emissions from
volatilization of organic pollutants due to the
Agency's final action. As such, no adverse air
impacts are expected to occur as a result of these
regulations.
Table 13-1 provides information on
incremental VOC emissions resulting from
implementation of the proposed rule at CWT oils
and organics facilities. EPA has noLprovided
information for the metals subcategory, but
concluded these emissions would be negligible.
For this analysis, EPA defined a volatile pollutant
as described in Chapter 7 and calculated volatile
pollutant baseline and post-compliance loadings
and reductions as described in Chapter 12. EPA
additionally assumed that 80% of the volatile
pollutant reduction would be due to volatilization.
EPA selected 80% based on an assessment, of
information developed during the development of«-
OCPSF guidelines (see pages 275-285 of the
October 1987 "Development Document for
Effluent Limitations Guidelines and Standards
for the OCPSF Point Source Category (EPA
440/1-87/009)). In EPA's view, the information
presented in Table 13-1 represents a "worst-
case" scenario in terms of incremental volatile air
emissions, , since the analysis assumes no
volatilization of pollutants at baseline. As
explained earlier, EPA found that the majority of
these pollutants are already being volatilized in
the absence of additional treatment-technologies.
Table 13-1 also shows that, for this worst-
case scenario, the sum of the annual VOC air
emissions at CWT facilities would not exceed
400 tons of HAPs. Under the Clean Air Act,
major sources of pollution by HAPs are defined
as having either: (1) a total emission of 25
tons/year or higher for the total HAPs from all
emission points at a facility; or (2) an emission of
10 tons/year or higher from all emission points at
a facility. Based on these criteria, incremental air
emissions from this worst-case scenario analysis
of the final BPT/BAT/PSES organics
subcategory options would cause three facilities
' to be classified as major sources. For the oils
and metals subcategories, EPA does not project
any major sources due to incremental removals.
Since EPA concluded that the three organics
subcategory CWT facilities classified as major
sources would be classified as such in the
absence of the implementation of the final rule,
EPA has determined that air emission impacts
from the selected options are acceptable.
Although this rule is not based on technology
that uses air stripping with emissions control to
abate the release of volatile pollutants, EPA-
encourages all facilities which accept waste
containing volatile pollutants to incorporate air
stripping with overhead recovery or destruction
into their wastewater treatment systems.
Additionally, EPA also notes that CWT sources
of hazardous air pollutants are subject to
maximum achievable control technology
(MACT) as promulgated for off-site waste and
recovery operations on July 1, 1996 (61 FR
34140) as 40 CFR Part 63.
Finally, EPA notes that the increased energy
requirements discussed in Section 13.3- may
result in increased emissions of combustion
byproducts associated with energy production.
Given the relatively small projected increases in
energy use, however, EPA does not anticipate
that this effect would be significant.
13-2
-------
Chapter 13 Non-Water Quality Impacts Development Document for the CWT Point Source Category
Table 13-1. Projected Air Emissions at CWT Facilities
Subcategory
Oils
Organics
VOCs Emitted
(tons/yr)
69
329
Priority VOCs
Emitted
(tons/yr)
32
323
Number of
Projected MACT*
Facilities
0
3
Major Constituents
Toluene
Methylene Chloride
and Toluene
* MACT requires 25 tons of volatile emissions for a facility to be a major source or 10 tons of a
single pollutant at a single facility.
SOLID WASTE
13.2
Solid waste will be generated-due to a
number of the treatment technologies selected as
the basis for this rule. These wastes include
sludge from biological treatment systems,
chemical precipitation and clarification systems,
and gravity separation and dissolved air flotation
systems. EPA estimated" costs for off-site
disposal in Subtitle C and D landfills of the solid
wastes generated due to .the implementation of
the technologies selected as the basis of the final
CWT limitations and standards. These costs
were included in the economic evaluation of the
selected technologies.
To estimate the incremental sludge generated
from the selected options, EPA subtracted the
volume of sludge currently being generated by
the CWT facilities from the estimated volume of
sludge that would be generated after
implementation of the options. EPA calculated
the volume of sludge currently being generated
by CWT facilities for all sludge-generating
technologies currently being operated at CWT
facilities. EPA then calculated the volume of
sludge that would be generated by CWT facilities
after implementation of the final rule. Table 13-
2 presents the estimated increase in volumes of
filter cake generated by CWT facilities that
would result from implementation of the
promulgated limitations and standards.
The precipitation and subsequent separation
processes selected as the technology basis for the
metals subcategory will produce a metal-rich
filter cake. In most instances, the resulting filter
cake will require disposal in Subtitle C and D
landfills. EPA estimates that the annual increase
in filter cake generated by the metals subcategory
facilities will be 3.7 million gallons. In evaluating
the economic impact of sludge disposal, EPA
assumed that all of the sludge generated would
be disposed in a landfill. This assumption does
not take into consideration the fact that an
undetermined portion of the generated filter cake
may be recovered in secondary metals
manufacturing processes rather than being
disposed in a landfill.
The dissolved air flotation system and
additional gravity separation step selected as the
technology basis for the oils subcategory will
produce a metal-rich filter press cake that
requires disposal This filter cake may be either
disposed in Subtitle C and D landfills or in some
cases through incineration. EPA estimates that
the annual increase in filter cake generated by the
oils subcategory facilities will be 22.7 million
gallons. These estimates are based on
implementation of option 8 technology for
indirect dischargers (PSES) and option 9 for
direct dischargers (BPT/BAT). EPA applied a
scale-up factor to include the estimated volume
of filter cake generated by the NOA non-
respondents. In evaluating the economic impact
of sludge disposal, EPA assumed that all of the
sludge generated would be disposed in a landfill.
Finally, the biological treatment selected as
the technology basis for the organics subcategory
will produce a filter cake that consists primarily
13-3
-------
Chapter 13 Non-Water Quality Impacts Development Document for the CWT Point Source Category
of biosolids and requires disposal. This filter
cake can be disposed by a variety of means
including disposal at Subtitle C and Subtitle D
landfills, incineration, composting, and land
application. However, contaminants contained in
the sludges may limit the use of composting and
land application. EPA estimates that the annual
increase in filter cake generated by the organics
subcategory facilities will be 4.3 million gallons.
In evaluating the economic impact of sludge
disposal, EPA assumed that all of the sludge
generated would be disposed in a landfill.
Table 13-3 presents the percentage of the
national volume of hazardous andnon-hazardous
waste sent to landfills represented by the increase
for each regulatory option. The information
presented in this table represents the tonnage of
waste accepted by landfills in 1992 and was
based on information collected during the- -
development of the proposed Landfills Point
Source Category (see pages 3-32 of the January
1998 "Development Document for Proposed
Effluent Limitations Guidelines and Standards
for the Landfills Point Source Category" (EPA-
821-R-97-022)). EPA has concluded that the
disposal of these filter cakes and/or sludges will
not have an adverse effect on the environment or
result in the release of pollutants in the filter cake
to other media. EPA made this conclusion for
two reasons. First, EPA estimates that the
additional solid wastes disposed in landfills as a
result of this regulation will be less than 0.19% of
the annual tonnage of waste currently disposed in
landfills. Second, the disposal of these wastes
into controlled Subtitle ~G and D landfills is
strictly, regulated by the.RCRA program.
Table 13-2. Projected Incremental Filter Cake Generation at CWT Facilities
CWT
Subcategory
Metals
Oils
Organics
Total
Filter Cake Generated (million gal/yr)
Option
4
8
9
4
-
Indirect
0.
10
2.
13
80
.04
89
.73
Hazardous
Direct
1.68
0
0
1.68
Total
2.48
10.04
0
2.89
15.41
Non-Hazardous
Indirect
0.40
12.28
1.42
14.1
Direct
0.83
0.36
0
1.19
Total
1.23
12.28
0.36
1.42
15.29
Table 13-3. National Volume of Hazardous and Non-hazardous Waste Sent to Landfills
CWT
Subcategory
Metals
Oils
Organics
Total
Option
4
8
9
4
Percentage of Annual Tonnage of Waste
Disposed in National Landfills
Hazardous
0.032
6.093
0
0.024
0.149
Non-hazardous
0.004
0.028
0.001
0.003
0.036
13-4
-------
Chapter 13 Non-Water Quality. Impacts Development Document for the CWT Point Source Category
. ENERGY REQUIREMENTS
13.3
EPA estimates that the attainment of BPT,
BCT, BAT, and PSES will increase energy
consumption by a small increment over present
industry use. With the exception of the oils
subcategory, the projected increase in energy
consumption is primarily due to the incorporation
of components such as power pumps, mixers,
blowers, and controls. For the metals
subcategory, EPA projects an increased energy
usage of 3.5 million kilowatt hours per-year-and,
for the organics subcategory, an increased energy
usage of 0.5 million-kilowatt hours per year. For
the oils subcategory, however, the main energy
requirement in today's rule is for the operation of
dissolved air flotation units. Dissolved air
flotation units require air _ sparging _ to. help
separate the waste stream. For the oils
subcategory, EPA projects an increased energy
usage of 3.4 million kilowatt hours per year.
Overall, an increase of 7.5 million kilowatt-hours
per year would be required for today's regulation
which equates to 4210 barrels of oil per day. In
1996, the United States consumed 18.3 million
barrels of oil per day.
LABOR REQUIREMENTS
13.4
The installation of new wastewater treatment
equipment along with improvements in the
operation of existing equipment for compliance
with the proposed limitations and standards
would result in increased operating labor
requirements for CWT facilities. It is estimated
that compliance with the CWT regulations would
result in industry-wide employment gains. Table
13-5 presents the estimated increase in labor
requirements for the CWT industry.
13-5
-------
Chapter 13 Non-Water Quality Impacts Development Document for the CWT Point Source Category
Table 13-4. Projected Energy Requirements for CWT Facilities
Energy Usage (kwh/yr)
CWT Subcategory
Option Indirect. Direct
Dischargers Dischargers *"""
Metals
Cyanide Waste
Pretreatment
Oils
Organics
Total
4 1,805,3.69 1,551,195- 3,356,564
2 129,000 18,046
147,046
8> 3,336,584 - 3,336,584
9 . - 137,061 137,061
4 505,175 24,069
529,244
' - 5,776,128 1,730,371 . 7,506,499
Table 13-5. Projected Labor.Requirements, for CWT, Facilities. __
Operating Labor Requirements
„ , . Option
Subcategory
Metals 4
Cyanide
Waste 2
Pretreatment
8
Oils
9
Organics 4
Total
Indirect Dischargers Direct Dischargers
(Hours/yr) (Men/yr) (Hours/yr) (Men/yr)
85,448 ' . 42.7 27,105 13.6
16,425 8.2 2,190 1.1 '
57,825 25.9
2,496 . 1,2
29,042 14.5 936 0.5 .
188,740 91.3 32,727 16.4
Total
(Hours/yr) (Men/yr)
112V553-" 56.3
18-.615 9.3
57,825 25.9
2,496 1.2
29,978 15
221,467 107,7
13-6
-------
Chapter
14
IMPLEMENTATION
Effluent limitations and pretreatment
standards act as a primary mechanism to
control the discharges of pollutants to waters of
the United States. These limitations and
standards are applied to individual facilities
through NPDES permits and through POTW,
pretreatment programs.
Implementation of a regulation is a critical
step in the regulatory process. If a regulation is
not effectively implemented, the removals and
environmental benefits estimated for the
regulation may- -not be achieved. Likewise,
ineffective implementation could hinder the
facility's 'operations without^ achieving the™
estimated environmental benefits. In discussions
with permit writers and control authorities, many
stated that close communication with CWT
facilities is important for effective
implementation of discharge requirements.
Permit writers and control authorities need to
have a thorough understanding of a CWT
facility's operations to effectively implement this
rule. Likewise, CWT facilities must maintain
close communication with the waste generators
in order to accurately characterize and treat the
incoming waste streams.
This chapter provides direction to permit
writers, control authorities, and CWT facilities to
aid in the implementation of this rule. Interested
parties should also consult the Small Entity
Compliance Guide for the Final Effluent
Limitations. Guidelines. Pretreatment Standards
and New Source Performance Standards for the
Centralized Waste Treatment Industry.
Based on local site-specific factors, the
permit writer or control authority may establish
limitations and standards for pollutants not
covered by this regulation and may require more
stringent limits or standards for covered
pollutants.
COMPLIANCE DATES
Existing Direct Dischargers
14.1
14.1.1
New and reissued Federal and State NPDES
permits to direct dischargers must immediately
include the CWT'effluent limitations (BAT) if
applicable.
Existing Indirect Dischargers
14.1.2
Existing indirect dischargers (discharge to a
POTWs) must comply with the applicable CWT
pretreatment standards (PSES) no later than
three years after publication of the final rule hi
the Federal Register.
New_ Direct or Indirect Dischargers 14.1.3
New direct or indirect discharging sources
must comply with applicable limitations or
standards on the date the new sources begin
operations. New direct dischargers must comply
with NSPS while new indirect sources must
comply with PSNS. New direct and indirect
sources are those that began CWT construction
after publication of the final rule in the Federal
Register.
GENERAL APPLICABILITY
14.2
Chapter 3 details the applicability of the
CWT rule to various operations. Permit writers
and control authorities should closely examine all
CWT operations to determine if they should be
subject to provisions of this rule.
APPLICABLE WASTESTREAMS
14.3
Chapter 5 describes the sources of
wastewater for the CWT industry, which include
the following:
14-1
-------
Chanter 14 Implementation
Development Document for the CWTPoint Source Category
Off-site-generated wastewater:
• Waste receipts via tanker truck,
trailer/roll-off bins, and drums.
On-site-generated wastewater:
• Equipment/area washdown
• Water separated from recovered/recycled
materials
• Contact/wash water from recovery and
treatment operations
• Transport container washdown
• Solubilization water
• Laboratory-derived wastewater
• Air pollution control wastewater
1 • Landfill wastewater from on-site landfills
• Contaminated stormwater.
These waste streams are classified as
process wastewaters-and are, thus, subject to the
appropriate subcategory discharge standards.
Uncontaminated stormwater should not be mixed
with waste receipts prior to complete treatment
of the waste receipts since this arrangement may
allow discharge standards to be met by dilution
rather than proper treatment. Only
contaminated stormwater (i.e. stormwater which
comes in direct contact with waste receipts or
waste handling and treatment areas) should be
classified as a process wastewater. During site
visits "at CWT facilities, EPA observed many
circumstances in which uncontaminated
stormwater was commingled with the CWT
wastewaters prior to treatment or was added
after treatment prior to effluent discharge
monitoring. EPA believes that permit writers
and control authorities should be responsible for
determining which stormwater sources warrant
designation as process wastewater. Additionally,
permit writers and control authorities should
require facilities to monitor and meet their CWT
discharge requirements following wastewater
treatment and prior to combining these treated
CWT wastewaters with non-process
wastewaters. If a permit writer or control
authority allows a facility to combine treated
CWT wastewaters with non-process wastewaters
prior to compliance monitoring, the permit writer
or control authority should ensure that the non-
contaminated stormwater dilution flow is
factored into the facility's discharge
requirements.
EPA has also observed situations where.
stormwater, contaminated and uncontaminated,
was recycled as process water (e.g., as
solubilization water for solid wastes to render the
wastes treatable). In these instances, dilution is
not-the major source of pollutant reductions
(treatment). Rather, this leads to reduced
wastewater--discharges. Permit writers and
control authorities should investigate
opportunities for use of such alternatives and
encourage such practices wherever feasible.
SUBCATEGORY DESCRIPTIONS
14.4
One of the most important aspects of
implementation-is-the determination of which
subcategoryV limitations are applicable to sr
facility's operation^). As detailed in Chapter 5,
EP\A established a subcategorization scheme
based on the character of the wastes being
treated and the treatment technologies utilized.
The subcategories are as follows:
Subcategory A: Metals Subcategory:
Facilities which treat or recover metal from
metal-bearing waste, wastewater, or used
material received from offsite;
Subcategory B: Oils Subcategory:
Facilities which treat.or recover oil from oily
waste, wastewater, or used material received
from offsite;
Subcategory C: Organics Subcategory:
Facilities which treat or recover
• organics from organic waste,
wastewater, or used material received
from offsite; and
14-2
-------
Chapter 14 Implementation
Development Document for the CWTPoint Source Catesorv
Subcategory D: Multiple Wastestream
Subcategory:
Facilities which treat or recover some
combination of metal-bearing, oily, or
organic waste, wastewater, or used
material received from off-site.
The subcategory determination is based
primarily on the type of process generating the
waste, the characteristics of the waste, and the
type of treatment technologies which would be
effective in treating the wastes. It is important to
note that a wide range of pollutants were
detected in all four subcategories. That is,
organic constituents were detected in metal
subcategory wastewater and vice versa. The
following sections provide a summary description
of the wastes in each of the four subcategories;
a more detailed presentation is in Chapter 5.
wastes that contain significant quantities of
inorganics and/or metals should be classified in
the metals subcategory.
Metals Subcategory Description
14.4.1
Waste receipts" - classified irr the metals
subcategory include, but are not limited, to the
following: spent electroplating baths and
' sludges, spent anodizing solutions, air pollution
control water and . sludges, incineration
wastewaters, waste liquid mercury, metal
finishing rinse water and sludges, chromate
wastes, cyanide-containing wastes,- and waste
acids and bases. The primary concern with
metals subcategory waste streams is the
concentration of metal constituents, and some
form of chemical precipitation with solid-liquid .
separation is essential. These raw waste
streams generally contain few organic
constituents and have low oil and grease levels.
The range of oil and grease levels in metal
subcategory wastestreams sampled by EPA was
5 mg/L (the minimum analytical detection limit)
to 143 mg/L. The average oil and grease level
measured at metals facilities by EPA was 39
mg/L. As expected, metal concentrations in
wastes from this subcategory were generally high
in comparison to other subcategories. In general,
Oil Subcategory Description
14.4.2
Waste receipts classified in the oils
subcategory include, but are not limited to the
following: lubricants, used petroleum products,
used oils, oil spill clean-up, interceptor wastes,
bilge water, tank cleanout, off-specification fuels,
and underground storage tank remediation waste.
Based on EPA's sampling data, oil and grease
concentrations in these streams following
emulsion breaking and/or gravity .separation..
range from 38 mg/L to 180,000 mg/L. The
facility average value is 5,976 mg/L. Based on
.information provided by industry, oil and grease
content in these waste receipts prior to emulsion
breaking and/or gravity separation varies
between-0.1% and 99.6% (1,000 mg/L to
996,000. mg/L).- -Additionally, .as measured after
emulsion breaking and/or gravity separation,
these oily wastewaters generally contain a broad
range of organic and metal constituents.
Therefore, while the primary concern is often a
reduction in oil and grease levels, oils
subcategory wastewaters also require treatment
for metal constituents and organic constituents.
In general, wastes that do not contain a
recoverable quantity of oil should not be
classified as being in the oils subcategory. The
only exception to this would be wastes
contaminated with gasoline or other hydrocarbon
fuels.
Organics Subcategory Description 14.4.3
Waste receipts classified in the organics
subcategory include, but are not limited to, the
following: landfill leachate, contaminated
groundwater clean-up, solvent-bearing waste,
off-specification organic product, still bottoms,
wastewater from adhesives and epoxies, and
wastewater from chemical product operations
14-3
-------
Chanter 14 ImDlementation
Development Document for the CWTPoint Source Category
and paint washes. These wastes generally
contain a wide variety and concentration of
organic compounds, low concentrations of metal
compounds (as compared to waste receipts in the
metals subcategory), and low concentrations of
oil and grease. The concentration of oil and
grease in organic subcategory samples measured
by EPA ranged from 2mg/L to 42 mg/L, with an
average value of 22 mg/L. The primary concern
for organic wastestreams is the reduction in
organic constituents, which generally requires
some form of biological treatment. In general,
wastes that do not contain significant quantities
of inorganics, metals, or recoverable quantities of
oil or fuel should be classified as belonging to the
organics subcategory.
Multiple Wastestream Subcategory
Description
14.4.4
Waste receipts in the multiple wastestream
subcategory can all be classified in one of the
first three subcategories. This subcategory may-
apply to a CWT facility which accepts waste
receipts from more than a single subcategory
listed above. For example, a CWT multiple
wastestream subcategory facility may accept
electroplatingbaths and sludges and used oils and
oily wastewater. The multiple wastestream
subcategory determination can only be made
after the metals, oils, and organics subcategory
classifications have been completed.
FACILITY SUBCATEGORIZATION
IDENTIFICATION
14.5
EPA believes that the paperwork and
analyses currently performed at CWT facilities
as part of their waste acceptance procedures (as
outlined in Chapter 4) provide CWT facilities
with sufficient information to make a
subcategory determination.- EPA based its
recommended subcategorization determination
procedure on information generally obtained
during these waste acceptance and confirmation
procedures. EPA discourages permit writers and
control authorities from requiring additional
monitoring or paperwork solely for the purpose
of subcategory determinations, unless a CWT
facility's waste acceptance procedures are
inadequate. EPA believes that if CWT facilities
follow EPA's recommendations, they should
easily be able to classify then: wastes. Permit
writers and control authorities would only need
to satisfy themselves that the facility made a
good-faith effort to determine the category of
wastes treated. In most cases, as detailed below,
EPA believes the subcategory determiriation can
be made on the type of waste receipt, e.g.,
metal-bearing sludge, waste oil, landfill leachate.
Certainly, in EPA's estimation, all CWT'facilities
should, at a minimum, collect adequate,
information from the generator on the type of~
waste receipt since this is the minimum-
information required by CWT facilities to
effectively treat off-site wastes.
To determine an existing facility's,
subcategory classifications), the facility should
review data for a period of one year on" its
incoming wastes (collected at the point where the.
shipment is received at the facility and recorded
on forms similar to the template of a waste
acceptance form shown as Figure 14-7 at'the end
of this chapter). For a one year period, the
facility should first use Table 14-1 to classify
each of its waste receipts into Subcatesory A,
B. or C.
14-4
-------
Chapter 14 Implementation
Development Document for the CWT Point Source Category
Table 14-1. Waste Receipt Classification
Metals Subcategory
spent electroplating baths and/or sludges
metal finishing rinse water and sludges
chromate wastes
air pollution control blow down water and sludges
spent anodizing solutions
incineration wastewaters
waste liquid mercury
cyanide-containing wastes (> 136 mg/L)
waste acids and bases with or without metals
cleaning, rinsing, and surface preparation solutions from
electroplating or phosphating operations
vibratory deburring wastewater
alkaline and acid solutions used to clean metal parts or equipment
Oils Subcategory
used oils
oil-water emulsions or mixtures
lubricants
coolants
contaminated groundwater clean-up from petroleum sources
used petroleum products
oil spill clean-up —
bilge water
rinse/wash waters from petroleum sources
interceptor wastes
off-specification fuels
underground storage remediation waste
tank clean-out from petroleum or oily sources
non-contact used glycols
aqueous and oil mixtures from parts cleaning operations
wastewater from oil bearing paint washes
Organics Subcategory
landfill leachate
contaminated groundwater clean-up from non-petroleum sources
solvent-bearing wastes
off-specification organic product
still bottoms
byproduct waste glycol
wastewater from paint washes
wastewater from adhesives and/or epoxies formulation
wastewater from organic chemical product operations
tank clean-out from organic, non-petroleum sources
If the CWT facility receives the wastes
listed in Table 14-1, the subcategory
determination is made solely from this
information. If, however, the wastes are
unknown or not listed above, EPA recommends
that the facility use the following hierarchy to
characterize the wastes it is treating and identify
the appropriate regulatory subcategory:
1). If the waste receipt contains oil and
grease at or in excess of 100 mg/L, the
waste receipt should be classified in the
oils subcategory;
14-5
-------
Chanter 14 Imolementatibn
Development Document for the CWT Point Source Category
2). If the waste receipt contains oil and
grease <100 mg/L, and has any of the
pollutants listed below in concentrations
in excess of the values listed below, the
waste receipt should be classified in the
metals subcategory.
cadmium 0.2 mg/L
chromium 8.9 mg/L
copper 4.9 mg/L .,
nickel 37.5 mg/L
3). If the waste receipt contains oil and
grease < 100 mg/L, and does not have
concentrations of cadmium, chromium,
copper, or nickel above any of the
values listed,above, the.waste receipt
should be classified in the organics
subcategory.
This process is also illustrated hi Figure 14-1.
Members of the CWT industry have.
expressed concern that wastes may be received
from the generator as a "mixed waste", Le., a-
single waste receipt may be classified in more
than one subcategory. Based on the information
collected during the development of this rule,
using the subcategorization procedure
recommended in this section, EPA is able to
classify each waste receipt identified by the
industry into the appropriate subcategory.
Therefore, EPA believes that these "mixed waste
receipt"' concerns have been addressed in the
current subcategorization procedure.
Once the facility's subcategory determination
has been made based on a year of waste receipt
information, EPA recommends that the facility
should not be required to repeat this
determination process unnecessarily. However,
if a CWT facility alters its operation to accept
wastes from another subcategory (or no longer
accepts waste from a subcategory), the facility
should notify the appropriate permit writer or
control authority and the subcategory
determination should be reevaluated. EPA notes
that current regulations require notification to the
permitting or control authority when significant
changes occur. EPA also recommends that the
subcategory determination be re-evaluated
whenever the permit or pretreament agreement
(or control mechanism) is re-issued, though this
would not necessarily require complete
characterization of a subsequent year's waste
receipts if there is no indication that the make-up
of the facility's receipts had significantly
changed.
For new CWT facilities, the facility should
estimate the percentage of waste receipts
expected in each subcategory. Alternatively, the
facility could compare the treatment technologies
being installed to the selected treatment
technologies for each subcategory. After the
initial year of'operation, the permit writer or
control authority should reassess the facility's
subcategory determination and follow- the
procedures outlined for existing facilities.
14-6
-------
Chapter 14 Implementation
Develovment Document for the CWT Pnint Sn
Is the waste receipt titled
in Talk 14-1?
No
Does the receipt contain
ad and grease at or tn
excess oflOQmg/2,?-
No
DDGI it hove any of the
fdUavrtnznataktM.
ceucentrattax exeeedt&g:
Caamtum:
Ohrensan:
Nickd: tf.
No
The waste recept is in the
or panics tiibcotegcay
Yes
Tex
Yes
Consult TaUe 14-1 for
tateatefffrtzatton
The waste receipt is in the
otls sabsategory
The wastereca&tls tn the
metals subcategpry
Figure 14-1. Waste Receipt Subcategory Classification Diagram
14-7
-------
Chanter 14 Imolementation
Development Document for the CWTPoint Source Category
ON-SITE GENERATED WASTEWATER .
SUBCATEGORY DETERMINATION
14.6
Section 14.5 describes the subcategory
determination for off-site waste receipts. For
other on-site generated wastewater sources, such
as those described in Section 14.3, wastewater
generated in support of, or as the result of,
activities associated with each ' subcategory
should be classified in that subcategory. For
facilities that are classified in a single
subcategory, the facility should generally classify
on-site wastewater in that subc,ategory. For
facilities that are classified in more than one
subcategory, however, the facility should
apportion the on-site generated wastewater to the
appropriate subcategory., Certain waste streams
may be associated with more than one
subcategory, such as stormwater,.equipment/area
washdown, air pollution control wastewater, etc.
For these wastewater sources, the volume
generated should be apportioned to each
associated subcategory. For example, for
contaminated stormwater, the volume can be
apportioned based on the proportion of the
surface area associated with operations in each
subcategory. Equipment/area washdown may be
assigned to a subcategory based on the volume
of waste treated in each subcategory.
Alternatively, control authorities may assign the
on-site wastestreams to a subcategory based on
the appropriateness of the selected subcategory
treatment technologies. EPA notes that this is
only necessary for multiple subcategory
facilities which elect not to comply with
Subcategory D limitations or standards.
SUBCATEGORY DETERMINATION IN EPA
QUESTIONNAIRE DATA BASE
14.7
In order to estimate the quantities of
wastewater being discharged and current
pollutant loads, pollutant reductions, post
compliance costs, and environmental benefits for
each subcategory, EPA developed a
methodology to classify waste streams for CWT
facilities in the EPA Waste Treatment Industry
Questionnaire database into each of the
subcategories. Using the RCRA and Waste Form
Codes listed in Table 14-2, EPA developed rules
for making subcategory assignments of the waste
receipts reported in the 308 Questionnaires.
The rules rely primarily on Waste Form Codes
(where available) plus RCRA wastes codes.
Wastes Classified in the Metals
Subcategory - Questionnaire
Responses
14.7.1
The wastes that EPA classified in the metals
subcategory include the following:
• All wastes reported in Section G, Metals
Recovery, of the 308 Questionnaire; and
• All wastes with Waste Form Codes-and
RCRA codes meeting the criteria specified in
Table 14-3.
Wastes Classified in The Oils
Subcategory - Questionnaire
Responses
14.7.2
The wastes EPA 'classified in the oils
subcategory include the following:
• All wastes reported in Section E, Waste Oil
Recovery, of the 308 Questionnaire;
• All wastes reported in Section H, Fuel
Blending Operations, of the 308
Questionnaire that generate a wastewater as
a result of the fuel blending operations; .and
• All wastes with Waste Form Codes and
RCRA codes meeting the criteria in Table
14-4.
Wastes Classified in the Organics
Subcategory - Questionnaire
Responses
14.7.3
The wastes EPA classified in the organics
subcategory include the following:
14-8
-------
Chapter 14 Implementation
Development Document for the CWTPoint Source Category
All wastes with Waste Foim Codes and
RCRA codes meeting the criteria specified in
Table 14-5.
14-9
-------
Chapter 14 Implementation
Development Document for the CWTPoint Source Category
Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
RCRA CODES
D001 * Ignitable Waste '
D002 Corrosive Waste
D003 Reactive Waste
D004 Arsenic
D005 Barium
D006 Cadmium
D007 Chromium
D008 Lead . .
D009 Mercury .
DO 10 Selenium
DO 11 Silver
D012 Endrin(l,2,3,4,10,10-liexachlorc-l,7-epoxy-i,4,4a,5,6,7,8,8a-octahydro-l,4-endo-5,8-dimeth-ano-
napthalene)
DO 17 2,4,5-TP Silvex (2,4,5-trichlorophenixypropionic acid)
DOSS Methyl ethyl ketone=
FOO1 The following spent halogenated solvents used in degreasing: tetrachloroethylene; trichloroethane;
carbon tetrachloride and chlorinated fluorocarbons and all spent solvent mixtures/blends used in
degreasing containing, before use, a total of 10 percent or more (by-volume) of one or more of the-
above halogenated solvents or those solvents listed in F002, F004, and F005; and still bottoms from the
recovery of these spent solvents and spent solvent mixtures
F002 The following spent halogenated solvents: tetrachloroethylene; 1,1,1 -trichloroethane; chlorobenzene;
l,l,2-trichloro-l,2,2- trifluoroethane; ortho-dichlorobenzene; trichloroethane; all spent solvent
mixtures/blends containing, before use, a total of 10 percent or more (by volume) of one or more of the
above halogenated solvents or those solvents listed in F001, F004, and F005; and still bottoms from the
recovery of these spent solvents and spent solvent mixtures
F003 The following spent nonhalogenated solvents: xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether,
methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends
containing, before use, one or more of the above nonhalogenated solvents, and a total of 10 percent or
more (by volume) of one or more of those solvents listed in F001, F002, F004, and F005-1 and still
bottoms from the recovery of these spent solvents and spent solvent mixtures.
F004 The following spent nonhalogenated solvents: cresols, cresylic acid, and nitrobenzene; and the still
bottoms from the recovery of these solvents; all spent solvent mixtures/blends containing before use a
total of 10 percent or more (by volume) of one or more of the above nonhalogenated solvents or those
solvents listed in F001, F002, and F005; and still bottoms from the recovery of these spent solvents and
spent solvent mixtures
F005 The following spent nonhalogenated solvents: toluene, methyl ethyl ketone, carbon disulfide,
isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent mixtures/blends
containing, before use, a total of 10 percent or more (by volume) of one or more of the above
nonhalogenated solvents or those solvents listed in F001, F002, or F004; and still bottoms from the
recovery of these spent solvents and spent solvents mixtures
F006 Wastewater treatment sludges from electroplating operations except from the following processes: (1)
sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel; (3) zinc plating (segregated basis)
on carbon steel; (4) aluminum or zinc-aluminum plating on carbon steel: (5) cleaning/stripping
associated with tin, zinc, and aluminum plating on carbon steel; and (6) chemical etching and milling of
aluminum
F007 Spent cyanide plating bath solutions from electroplating operations
14-10
-------
Chapter 14 Implementation
Development. Document for the CWTPoint Source Cateeorv
Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
F008
F009
F010
F011
F012
F019
F039
K001
K011
,.K013
KOL4
K015
KQ16,.
K031
K035
K044
K045
K050
K051
K052
K061
K064
K086
K093
K094
K098
K103
P011
P012
P013
P020
P022
Plating bath residues from the bottom of plating baths from electroplating operations in which cyanides
are used in the process
Spent stripping and cleaning bath solutions from electroplating operations in which cyanides are used in
the process
Quenching bath residues from oil baths from metal heat treating operations in which cyanides are used
in the process
Spent cyanide solutions from slat bath pot cleaning from metal heat treating operations
Quenching waste water treatment sludges from metal heat treating operations in which cyanides are
used in the process
Wastewater treatment sludges from the chemical conversion coating of aluminum
Multi-source leachate
Bottom sediment sludge from the treatment of wastewater from wood preserving processes that use
creosote and/or pentachlorophenol
Bottom stream from the wastewater stripper in the production of acrylonitrile
Bottom stream from the acetonitrile column in the produption of acrylonitrile
Bottoms-from the acetonitrile purification column in the production of acrylonitrile
Still bottoms^from the:distillation of benzyl chloride-7
...Heavy ends or distillation residues from the production of carbon tetrachloride
By-product salts generated in the production of MSMA_and,cacodylic acid
Wastewater treatment sludges generated in the production of creosote
Wastewater treatment sludges from the manufacturing and processing of explosives
Spent carbon from the treatment of wastewater containing explosives K048 air flotation (DAF) float
from the petroleum refining industry K049 Slop oil emulsion solids from the petroleum refining
industry
Heat exchanger bundle cleaning sludge from the petroleum refining industry
API separator sludge from the petroleum refining industry
Tank bottoms (leaded) from the petroleum refining industry
Emission control dust/sludge from the primary production of steel in electric furnaces
Acid plant blowdown slurry/sludge resulting from the thickening of blowdown slurry from primary
copper production •
Solvent washes and sludges, caustic washes and sludges, or water washes and sludges from cleaning tubs
and equipment used in the formulation of ink from pigments, driers, soaps, and stabilizers containing
chromium and lead
Distillation light ends from the production of phthalic anhydride from ortho-xylene
Distillation bottoms from the production of phthalic anhydride from ortho-xylene
Untreated process wastewater from the production of toxaphene
Process residues from aniline extraction from the production of aniline K.104 Combined wastewater
streams generated from nitrobenzene/aniline production '
Arsenic pentoxide (t)
Arsenic (III) oxide (t) Arsenic trioxide (t)
Barium cyanide
Dinoseb, Phenol,2,4-dinitro-6-(l-methylpropyl)-
Carbon bisulfide (t)
Carbon disulfide (t)
14-11
-------
Chanter 14 Implementation
Development Document for the CWTPoint Source Category
Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
P028 Benzene, (chloromethyl)
-Benzyl chloride . '
P029 Copper cyanides
P030 Cyanides (soluble cyanide salts), not elsewhere specified (t)
P040 0,0-diethyl 0-pyrazinyl phosphorothioate
Phosphorothioic acid, 0,0-diethyl 0:pyrazinyl ester
P044 Dimethoate (t)
Phosphorodithioic acid,
0,0-dimethyl S-[2-(methylamino)-2-oxoethyl]ester (t)
P048 2,4-dinitrophenol
Phenol,2,4-dinitro-
P050 Endosulfan " ' '
5-norbomene-2,3-dimethanol,
l,4,5,6,7,7-hexachloro,cyclicsulfite
P063 Hydrocyanic acid
Hydrogen cyanide
P064 Methyl isocyanate
Isocyanic acid, methyl ester
P069 2-methyllactonitrile
Propanenitrile,2-hydroxy-2-methyl-
P071 0,0-dimethyl 0-p-nitrophenyl phosphorothioate
Methyl parathion
P074 Nickel (H) cyanide
Nickel cyanide
P078 Nitrogen (TV) oxide
Nitrogen dioxide
P087 Osmium tetroxide
Osmium oxide
P089 Parathion (t)
Phosphorothiotic acid,0,0-diethyl 0-(p-nitrophenyl) ester (t)
P098 Potassium cyanide
PI04 Silver cyanide
P106 Sodium cyanide
P121 Zinc cyanide
PI 23 Toxaphene
Camphene,octachloro-
U002 2-propanone (i)
Acetone (i)
U003 Ethanenitrile (i,t)
Acetonitrile (i,t)
U008 2-propenoic acid (i)
Acrvlic acid (I)
14-12
-------
Chapter 14 Implementation
Development Document for the CWTPoint Source Catesorv
Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
U009 • 2-propenenitrile
Acrylonitrile
U012 Benzenamine (i,t)-
Aniline (i,t)
U019 Benzene (i,t)
U020 Benzenesulfonyl chloride (c,r)
Benzenesulfonic acid chloride (c,r)
U031 l-butanol(i)
N-butyl alcohol (i)
U044 Methane^ trichloro—
Chloroform
•U045 Methane,chloro-(i,t)
Methyl chloride (i,t)
U052 Cresylicacid
Cresols.,, .
U057 Cyclohexanone (i)
U069- DibutyLphthalate .
1,2-benzenedicarboxylicacidrdibutyI ester - .
U080 Methane.dichloro-
Methylene chloride
U092 Methanamine, N-methyl-(i)
Dimethylamine (i) . '
U098 Hydrazine, 1,1-dimethyl-
1,1 -dimethylhydrazine
U105 2,4-dinotrotoluene
Benzene, l-methyl-2,4-dinitro-
U106 2,6-dinitrotoluene
Benzene, l-methyl-2,6-dinitro
U107 Di-n-octyl phthalate
1-2-benzenedicarboxylic acid, di-n-octyl ester
Ul 13 2-propenoic acid, ethyl ester (i)
Ethyl acrylate (i)
Ul 18 2-propenoic acid, 2-methyl-, ethyl ester
Ethyl methacrylate
U122 Formaldehyde
Methylene oxide
U125 Furfural (i)
2-furancarboxaldehyde (i)
U134 Hydrogen fluoride (c,t)
Hydrofluoric acid (c,t)
U135 Sulfur hydride
Hydrogen sulfide
14-13
-------
Chanter 14 Imolementation
Development Document for the CWT Point Source Category
Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
U139 Ferric dextran
Iron dextran
U140 1 -propanol, 2-methyl- (i,t)
Isobutyl alcohol (i,t)
U150 Melphalan
Alanine, 3-[p-bis(2-chloroethyl)amino] phenyl-,L-
U151 Mercury
U154 Methanol(i)
Methyl alcohol (i)
U159 Methyl ethyl ketone(i,t)
2-butanone (i,t)
U161 4-methyl-2-pentanone (i)
Methyl isobutyl ketone (i)
U162 2-propenoic acid,2-methyl-5methyl ester (i,t)
Methyl methacrylate (i,t)
U188 Phenol
Benzene, hydroxyr
U190 Phthalic anhydride-
1,2-benzenedicarboxylic acid anhydride
U205 Selenium disulfide (r,t)
Sulfur selenide (r,t)
U210 Tetrachloroethylene • - ' .
Ethene, 1,1,2,2-tetrachloro
U213 Tetrahydrofuran (i)
Furan, tetrahydro- (i)
U220 Toluene
Benzene, methyl- .
U226 1,1,1-trichloroethane
Methylchloroform
U228 Trichloroethylene
Trichloroethene .
U239 Xylene(i)
Benzene, dimethyl- (i,t)
WASTE FORM CODES
B001 Lab packs of old chemicals only
B101 Aqueous waste with low solvent
B102 Aqueous waste with low other toxic organics
B103 Spent acid with metals
B104 Spent acid without metals
BIOS Acidic aqueous waste
B106 Caustic solution with metals but no cyanides
B107 Caustic solution with metals and cyanides
R108 Caustic solution with cvanides but no metals
14-14
-------
Chapter 14 Implementation
Development Document for the CWT Point Source Cateeorv
Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
B109 Spent caustic
B110 Caustic aqueous waste
Bill Aqueous waste with reactive sulfides
B112 Aqueous waste with other reactives (e.g., explosives)
B113. Other aqueous waste with high dissolved solids
B114 Other aqueous waste with low dissolved solids
B115 Scrubber water
B116..,, Leachate
B117 Waste liquid mercury
B119 Other inorganic liquids
B201 Concentrated solvent-water solution
B202 Halogenated (e.g., chlorinated) solvent
B203 Nonhalogenated solvent
B204 Halogenated/Nonhalogenated solvent-mixture-
B205" 'Oil-water emulsion or mixture
B206 Waste oil
B207 Concentrated aqueous solution of other organics
B208 Concentrated phenolics
B209 Organic paint, ink, lacquer, or varnish
B210 Adhesive or epoxies
B211 Paint thinner or petroleum distillates
B219 Other organic liquids
B305 "Dry" lime or metal hydroxide solids chemically "fixed"
B3 06 "Dry" lime or metal hydroxide solids not "fixed"
B307 Metal scale, filings, or scrap
B308 Empty or crushed metal drums or containers
B309 Batteries or Battery parts, casings, cores
B310 Spent solid filters or adsorbents
B312 Metal-cyanides.salts/chemicals
B313 Reactive cyanides salts/chemicals
B315 Other reactive salts/chemicals
B316 Other metal salts/chemicals
B319 Other waste inorganic solids
B501 Lime sludge without metals-
B502 Lime sludge with metals/metal hydroxide sludge
B504 Other wastewater treatment sludge
B505 Untreated plating sludge without cyanides
B506 Untreated plating sludge with cyanides
B507 Other sludges with cyanides
B508 Sludge with reactive sulfides
B510 Degreasing sludge with metal scale or filings
B511 Air pollution control device sludge (e.g., fly ash, wet scrubber sludge)
B513 Sediment or lagoon dragout contaminated with inorganics only
B515 Asbestos slurry or sludge
14-15
-------
Chanter 14 Implementation
Development Document for the CWT Point Source Category
Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
B519 • Other inorganic sludges
B601 Still bottoms of halogenated (e.g., chlorinated) solvents or other organic liquids
B603 Oily sludge
B604 Organic paint or ink sludge
B605 Reactive or polymerized organics
B607 Biological treatment sludge
B608 Sewage or other untreated biological sludge
B609 Other organic sludges •
Table 14-3. Waste Form Codes in the Metals Subcategory
All Inorganic
Liquids
All Inorganic
Solids
All Inorganic
Sludges
Waste Form Codes
B101-B119
Waste Form Codes
B301-B319
Waste Form Codes
B501-B519
Exceptions:*
Waste Form Codes B116, and B101, B102, B119
when combined with RCRA Codes:
F001-F005 and other organic F, K, P, and U Codes
Exceptions: "_' .,, -•- ..
Waste Form Code B301
when combined with RCRA. Codes:,. -
F001-F005 and other organic F, K, P, and U Codes
Exceptions:* , .
Waste Form Code B5i2
when combined with RCRA Codes:
F001-F005 and other organic F, K, P, and U Codes
* These exceptions were classified as belonging in the organics subcategory
Table 14-4. Waste Form Codes in the Oils Subcategory
Organic Liquids
Organic Sludge
Waste Form Codes
B205, B206
Waste Form Code
B603
Exceptions:
None
Exceptions:
None
14-16
-------
Chapter 14 Implementation
Development Document for the CWT Point Source Cateporv
Table 14-5. Waste Form Codes in the Organics Subcategory
Organic Liquids
Organic Solids
Organic Sludges
Inorganic Liquids
Waste Form Codes
B201-B204, B207-B219
Waste Form Codes
B401-B409
Waste Form Codes
B601, B602, B604-B609
Waste Form Codes
B101,B102,B116,B119
Exceptions:
None
Exceptions:
None
Exceptions:
None
when combined with RCRA Codes:
F001-F005 and other organic F, K,
P.andU
Inorganic Solids- Waste Form Code B301
Inorganic Sludges Waste Form Code B512
Codes
when combined with RCRA Codes:
F001-F005-and-otherorganic F, K,P, and-U-
Codes
when combined with RCRA Codes:
F001-F005 and other organic F, K, P, and U
Codes
For wastes that cannot be easily classified
into a subcategory, such as lab-packs, the
subcategory determination was based on other
information provided such as RCRA codes and
descriptive comments. Therefore, some
judgement is required in assigning some waste
receipts to a subcategory.
14-17
-------
Chanter 14 ImDlementation
Development Document for the CWT Point Source Category
ESTABLISHING LIMITATIONS AND
STANDARDS FOR FACILITY DISCHARGES
14.8
In establishing limitations and standards for
CWT facilities, the permit writer or control
authority must ensure that the CWT facility has
an optimal waste management program. First,
the permit writer or control authority should
verify that the CWT facility is identifying and
segregating waste streams to the extent possible
since segregation of similar waste streams is the
first step in obtaining optimal mass removals of
pollutants from industrial wastes. Next, the
permit writer or control authority should Verify
that the CWT facility is employing treatment.
technologies designed'and operated to optimally
treat all off-site waste receipts. For example,
biological treatment is inefficient for treating.
concentrated 'metals waste streams- like^.those-
found in the metals subcategory or wastestreams
with oil and grease compositions and
concentrations like those found in the oils
subcategory. In fact, concentrated metals
streams and high levels of oil and grease
compromise the ability of biological treatment
systems to function. Likewise, emulsion
breaking/gravity separation, and/or dissolved air
flotation is typically insufficient for treating
concentrated metals wastewaters or wastewaters
containing organic pollutants which solubilize
readily in water. Finally, chemical precipitation
is insufficient for treating organic wastes and
waste streams with high oil 'and grease
concentrations.
Once the permit writer or control authority
has established that the CWT facility is
segregating its waste receipts and has appropriate
treatment technologies in place for all off-site
waste receipts, the permit writer or control
authority can then establish limitations or
standards which ensure that the CWT facility is
operating its treatment technologies optimally:
Available guidance in calculating NPDES
categorical limitations for direct discharge
facilities can be found in the U.S. EPA NPDES
Permit Writers' Manual (December 1996, EPA-
833-B-96-003). Sources of information used for
calculating Federal pretreatment standards for
indirect discharge facilities include 40 CFR Part
403.6, the Guidance Manual for the Use of
Production-Based Pretreatment Standards and
the Combined Waste Stream Formula
(September 1985), and EPA's Industrial User
Permitting Guidance Manual (September 1989).
The CWT limitations and standards for each
subcategory are listed in Tables 1 through 8 of
the Executive Summary at the beginning of this
document. •
Implementation for Facilities in
Multiple CWTSubcategories
14.8.1
EPA estimates that many facilities in the
CWT industry accept wastes in two or more
subcategories (a combination of wastes in
Subcategory A, B or C). This situation is
different from the case in Which metal-bearing
waste streams may include low-level organic
pollutants or that oily wastes may include low
level metal pollutants due to the origin of the
waste stream accepted for treatment.
For these multi-subcategory CWT facilities
which combine subcategory wastes prior to
discharge, guidance provided during development
of this rule required that control authorities
apply either the building block approach (see
Section 14.8.4.1) or the combined waste stream
formula (see Section 14.8.4.2) as appropriate to
develop combined limitations or standards.
As promulgated, however, neither the
building block approach nor the combined waste
stream formula apply in developing limitations or
standards for multi-subcategory CWT facilities.
Rather, multiple subcategory facilities may
comply with this rule in one of two ways: 1)
facilities may elect to comply with the limitations
or standards for each applicable subcategory
directly following treatment (before commingling
with different subcategory wastes); or 2) facilities
may certify equivalent treatment and comply
14-18
-------
Chapter 14 Implementation
Development Document for the CWTPoint Source Cateporv
with one of the four sets of limitations or
standards for the multiple wastestream
subcategory (Subcategory D). Each of these
options is discussed further below.
Comply with Limitations or Standards
for Subcategory A, B or C 14.8.1.1
If a CWT facility elects to comply with each
applicable subcategory's limitations or standards
individually, the permit writer or control
authority should establish compliance monitoring
for each applicable subcategory directly following
treatment of each subcategory's waste steam
(and apply the appropriate limitations or
standards at that point). As a further point of
clarification, the permit writer or control
authority should not allow CWT facilities to
commingle waste streams , from different
subcategories prior to monitoring for compliance
with each subcategory's limitations or standards.
Example 14-1 illustrates this approach. EPA
notes that multiple subcategory facilities which
elect to comply with each applicable
subcategory's limits or standards individually do
not have to demonstrate equivalent treatment
(see Section 14.8.1.2).
Example 14-1
Facility A accepts wastes in all three CWT subcategories with separate subcategory
treatment systems and has elected to comply with each set ofpretreatment standards
separately. This facility treats 20,000 I/day of metal-bearing wastes; 10,000 I/day
of oily wastes," and 45,000, I/day of organic wastes and discharges to its local
POTW.
Metals Waste
20,000 L/day
Sample
Point !•
Oils Waste
10,000 L/day
Sample
Point 2
Organics Waste
45,000 L/day
Sample
Point3
Figure 14-2. Facility.Accepting Waste in All Three Subcategories With Treatment in Eaci
14-19
-------
Chapter 14 Implementation
Development Document for the CWT'Point Source Category
For this example, the control authority establishes monitoring points 1,2, and 3. The control
authority requires that the facility comply with the metals subcategory pretreatment standards
at Sample Point 1, the oils subcategory pretreatment standards at Sample Point 2, and the
organics subcategory pretreatment standards at Sample Point 3. Note that the specific analytes
requiring compliance monitoring vary at each sampling point since the pollutants regulated vary
among subcategories.
Comply with Limitations or Standards
for Subcategory D 14.8.1.2
If a multi-subcategory CWT facility elects to
comply with the limitations or standards for
Subcategory D, then the permit writer or control
authority establishes a single monitoring point
prior to discharge and applies 1he appropriate set
of limitations or standards from Subcategory D
(for example, if a CWT facility accepts wastes in
both the metals and oils subcategory, the permit
writer or control authority establishes limits or
standards for Subcategory D facilities which
commingle wastes from Subcategories A and B). ,
Examples 14-2>and 14-3 illustrate this approach.
EPA notes that under this approach, the permit
writer or control authority must allow a multi-
subcategory facility to commingle wastestreams
prior to discharge. Also, facilities which select .
this compliance method must first establish
equivalent treatment as detailed in Section
14.8.1.2.1 below.
14-20
-------
Chapter 14 Implementation
Development Document for the CWT Paint Snurr? Cntpcrnr
Example 14-2
Facility B accepts wastes in all three CWT subcategories with separate subcategory
treatment systems and has elected to comply with Subcategory Dpretreatment standards
at a combined outfall. This facility treats 20,000 I/day of metal-bearing wastes, 10,000
I/day of oily wastes, and 45,000 I/day of organic wastes and discharges to its local
POTW.
Metals
20,001
\
•Waste . Otis
)Uday IQOQt
f >
Waste
tL/day
f
Metals Ok
Treatment . Treatment-
\
f
ussciriBrgp
75. QGQL/tbiy
Qreant
4L,OOt
\
-s Waste
tUday
f
Treatment
Figure 14-3. FaeOtiy Accepting Waste in M Three SuJbcateeprtas Wtffi Treatment to £a£i
AndConbtnedOiOfaU
For this example, the control authority establishes a single monitoring point as indicated. The
control authority requires the facility to comply with Subcategory D pretreatment standards for
facilities which commingle wastes from Subcategory A, B, and C.
14-21
-------
Chanter 14 Imolementation
Development Document for the CWT Point Source Category
Example 14-3: Facility Which Accepts Wastes in Multiple Subcategories and Treats the
Wastewater Sequentially
Facility C accepts waste in the oils and metals subcategory. The total volume of
wastewater discharged to the local POTW is 100,000 liters per day. The facility
segregates oils and metals waste receipts and first treats the oils waste receipts
using two stage emulsion breaking/gravity separation and dissolved air flotation
(see Figure 14-4). The facility then commingles this wastewater with metal
subcategory waste receipts and treats the combined wastestreams using primary and
secondary chemical precipitation and solid/liquid separation followed by
multimedia filtration.
Maiali Watte
Oils Waste
£&
TreatauMt
\
r~ »—
x^
Metds
Treatment
Discharge
•s,
•*"
For this example, like example 14-2, the control authority establishes a single monitoring point.
This monitoring point follows the metals treatment. The control authority requires that the
facility comply with Subcategory D pretreatment standards for facilities which commingle
wastes from Subcategories A and B.
EQUIVALENT TREATMENT
DETERMINATION FOR
SUBCATEGORYD
14.8.1.2.1
Before amulti-subcategory CWT facility can
elect to comply with limitations or standards
from Subcategory D, it must first demonstrate
equivalent treatment for each applicable
wastestream. The CWT rule defines equivalent
treatment as "a wastewater treatment system that
achieves comparable pollutant removals to the
applicable treatment technology selected as the
basis for the limits and standards." The
following outlines the procedure for
demonstrating equivalent treatment.
First, facilities which desire this option must
submit an initial request to their permit writer or
control authority certifying that their treatment
train includes all applicable equivalent treatment
systems. This initial certification would include,
at a minimum, the applicable Subcategories (i.e.,
metals, oils, organics), a listing of and
descriptions of the treatment technologies and
operating conditions used to treat wastes in each
subcategory, and the justification for making an
equivalent treatment determination. For
example, a facility which accepts metals
subcategory and oils subcategory wastewaters
could show that its treatment train includes two-
stage oil/water separation, two-stage chemical
14-22
-------
Chapter 14 Implementation
Development Document for the CWT Point Source Category
precipitation, and dissolved air flotation operated
in a similar manner to the model technology
costed by EPA. Since these axe the treatment
technologies selected as the basis for this rule,
the equivalent treatment determination could be
established. However, EPA is not defining
"equivalent treatment" as specific treatment
technologies or the technology bases, but rather
as a "wastewater treatment system that is
demonstrated in literature, tractability tests, or
self-monitoring data to remove a similar level of
the appropriate pollutants as the applicable
treatment technology selected as'die basis for the
applicable regulations." While EPA is leaving the
decision as to whether a particular treatment train
is "equivalent treatment" to the permit writer or
control authority's best professional judgement,
the Small Entity Compliance Guide for this rule
provides several examples of cases "where EPA
believes equivalent treatment is demonstrated.
EPA notes that the requesting facility is
responsible for providing the permit writer or
control authority with enough information and/or
data to make the equivalent treatment
determination. This initial certification statement
must be signed by the responsible corporate
officer as defined in 40 CFR 403.12(1) or 40
CFR 122.22. If the permit writer or control
authority determines that equivalent treatment is
demonstrated, then the permit writer or control
authority will issue discharge requirements based
on one of the four subsets of limitations or
standards promulgated for the mixed waste
subcategory. If the facility has not demonstrated
equivalent treatment, then the permit writer or
control authority will not allow the CWT facility
to comply with limitations or standards from
Subcategory D. Rather, the permit writer or
control authority will issue discharge
requirements based on the appropriate limitations
or standards from Subcategory A, B or C and
require that these requirements be met prior to
commingling (See Section 14.8.1.1).
Once the facility has established equivalent
treatment, the facility shall submit an annual
certification statement which indicates that the
treatment technologies are being utilized in the
manner set forth in its original certification or a
justification to allow modification of the practices
listed in its initial certification. If the information
contained in the initial certification statement is
still applicable, a facility shall simply state that in
a letter to the permit writer or control authority,
and the letter shall constitute the periodic
statement. However, if the facility has modified
its treatment system in any way, it shall submit
v the'revised informatiofrin aTnannersimilar to the
initial certification. Once again, the permit writer -
or control authority will use BE/B.J, in reviewing
"any modifications.
Finally, the facility shall be required to
maintain on-site compliance paperwork. The on-
site compliance paperwork should include
information from the initial and periodic
certifications,. but must also include: (1) the
supporting documentation for any modifications
that have been made to the treatment system; (2)
a method for demonstrating that the treatment
system is well operated and maintained; and (3)
a discussion of the rationale for choosing the
method of demonstration. Proper operation and
maintenance of a system includes a qualified
person to operate the system, use of correct
treatment chemicals in appropriate quantities,
and operation of the system within the stated
design parameters. For example, a facility may
operate dissolved air flotation. The method for
demonstrating the dissolved air flotation system
is well operated can be as simple as marntaining
records on the temperature and pH, the
chemicals added (including quantity), the
duration of treatment, recycle ratio, and physical
characteristics of the wastewater before and after
dissolved air flotation. Alternatively, the facility
could monitor for selected parameters for the
purpose of demonstrating effective treatment.
This could include any pollutant or a
combination of pollutants. The implementation
manual for the CWT rule provides additional
examples.
14-23
-------
Chanter 14 ImDlernentation
Development Document for the CWTPoint Source Category
Permit writers and control authorities may
inspect the CWT facility at any time to confirm
that the listed practices are being employed, that
the treatment system is well operated and
maintained, and that the necessary paperwork
provides sufficient justification for any
modifications.
Implementation for Facilities with
Cyanide Subset
14.8.2
Whenever a CWT facility accepts a waste
receipt that contains more than 136 mg/L of total
cyanide, the CWT facility must monitor for
cyanide when the wastewater exits the cyanide
destruction process rather than after mixing with
other process wastewater. Alternatively, the
facility may monitor for compliance after mixing
if the cyanide limitations are adjusted using the
"building block approach" or "combined waste
stream formula," assuming- the- cyanide
limitations do not fall below the minimum
analyticaldetection limit For further information
on the "building block approach" or "combined
waste stream formula", see section 14.8.4.
CWT Facilities Also Covered By
Another Point Source Category
14.8.3
As detailed in Chapter 3, some
manufacturing facilities, which are subject to
existing effluent guidelines and standards, may
also be subject to provisions of this rule. In all
cases, these manufacturing facilities accept waste
from off-site for treatment and/or recovery
which are generated from a different categorical
process as the on-site generated wastes. EPA is
particularly concerned that these facilities
demonstrate compliance with all applicable
effluent guidelines and pretreatment standards —
including this rule.
Direct Discharging Facilities
14.8.3.1
For determination of effluent limits where
there are multiple categories, the effluent
guidelines are applied using a flow-weighted
combination of the appropriate guideline for each
category(i.e., "the building block approach").
Where a facility treats a CWT wastestream and
process wastewater from other non-CWT
industrial operations, the effluent guidelines
would be applied by using a flow-weighted
combination of the BPT/BAT limitations for the
CWT and the other non-CWT industrial
operations to derive the appropriate limitations.
Example 14-4, on the next page, illustrates the
daily maximum limitations calculations for a
CWT facility which is also subject to another
effluent guideline.
14-24
-------
Chapter 14 Implementation
Development Document for the CWT Point Source Category
Example 14-4 Categorical Manufacturing Facility Which Also Operates as a CWT
Facility
Facility D is a manufacturing facility currently discharging wastewater to the local
river under the OCPSF point source category. Facility D also performs CWT operations
and accepts off-site metal-bearing wastes for treatment. Facility D commingles the on-site
wastewater and the off-site wastewater together for treatment in an activated sludge system.
The total volume of wastewater discharged at Facility D is 100,000 liters per day. 'The total
volume of wastewater contributed by the off-site wastewater is 10,000 liters per day.
Wastes
s CWT
Metals Wastes
Treatment
Figu-£ 1 -f-S. Cfategpi'KiilManv.faeffl'DigFaciliiy Which Mso Q>0-at£S as a. CWT
Facility D will be required to monitor and demonstrate that it has complied with the CWT
metals BAT limitations. Since Facility D commingles the wastestreams and has no treatment
in place for the metals wastestreams, Facility D will be unable to demonstrate compliance with
the BAT limits through treatment rather than dilution. Therefore, Facility D can not
commingle the CWT metals wastestreams and on-site OCPSF wastestreams for treatment.
If Facility D chose to install metals treatment for the off-site wastewater and wanted to
commingle the effluent from the metals treatment and the biological treatment at a single
discharge point (See Figure 14-6 on the next page), the permit writer would use the building
block approach to determine the limitations. Using .lead and chromium as examples, for the
metals subcategory, EPA has promulgated BAT monthly average limits of 3.07 mg/L for
chromium and 0.283 mg/L for lead. Since the OCPSF facility has no limits for chromium
and lead, the contribution for the OCPSF wastewaters would be zero. Therefore, the
chromium monthly average limit would be ( 0.1 x 3.07) + (0.9 x 0) = 0.307 mg/1 and the lead
monthly average limit would be (0.1 x 0.283) x (0.9 x 0) = 0.0283 mg/L Since the monthly
average limit for lead is below the muiimum analytical detection level (.050 mg/1), the facility
would be required to demonstrate compliance with the lead limit for the CWT metals
subcategory prior to commingling at the outfall. The monthly average and daily maximum
limitations for other pollutants would be calculated in a similar manner. Since EPA has not
proposed any BAT limits for organic pollutants under the metals subcategory of the CWT
point source category, the contribution for these pollutants would be zer.o.
14-25
-------
Chapter 14 Implementation
Development Document for the CWT Point Source Category
Off-Site
CWTMetals Wastes
10,000 L/day
Metals
Treatment
On^Site OCPSF
Wastes
90,000 L/day
Organics
Treatment
Discharge
100,000L/day ,
Figure 14-6. Facility That Commingles Wastestreams After Treatment
Indirect Discharging Facilities
14.8.3.2
For determination of pretreatment standards
where there are multiple categories, the
prefreatment standards are applied using the
"combined waste stream formula" as defined in
40 CFR § 403.6(e). The combined wastestream
formuk (CWF) is based on three types of
wastestreams that can exist at an industrial
facility: regulated, unregulated, and dilute. As
defined (40 CFR 403), a regulated wastestream
is a wastestream from an industrial process that
is regulated by a categorical standard for
pollutant x. An unregulated wastestream is a
wastestream that is not covered by categorical
pretreatment standards and not classified as
dilute, or one that is not regulated for the
pollutant in question although it is regulated for
others. A dilute wastestream is defined to
include sanitary wastewater, noncontact cooling
water and boiler blowdown, and wastestreams
listed in Appendix D to 40 CFR 403.
Therefore, as described in 40 CFR 403, the
combined waste stream formula is
F - F
r r
where CT =
C,=
(14-1)
the alternate concentration
limit for the combined
wastestream;
the categorical pretreatment
standard concentration limit
for a pollutant in the regulated
stream.i; • • •
the average daily flow of
stream i;
the average daily flow from
dilute wastestreams .as defined
in 40 CFR 403; and
the total daily average flow
including regulated,
14-26
-------
Chapter 14 Implementation
Development Document for the CWT Point Source Category
.unregulated, and dilution
wastestreams.
Using example 14-4 above, but assuming the
facility discharges to the local POTW, there are
no dilution flows. Therefore, the CWF equation
reduces in the following manner:
, (14-2)
N
i=l
Using chromium andlead as examples again,
EPA has promulgated monthly average
pretreatment standards of 3.07 mg/L for
chromium and 0.283 mg/L for lead. Since the
OCPSF facility has no pretreatment standards
for chromium and lead, these wastestreams are
defined as "unregulated." Therefore, for this
example, the only regulated wastestream is the
oils subcategory flow and the chromium monthly
average limit would be (10,000 x 3.07)710,000
= 3.07 mg/1 and the lead monthly average limit
would be (10,000 x 0.283)710,000 = 0.283 mg/1.
The monthly average and daily maximum
pretreatment standards for other pollutants would
be calculated in a similar manner. Since EPA
has'not proposed any pretreatment standards for
organic pollutants under the metals subcategory
of the CWT point source category, for organic
pollutants the CWT wastestreams. would be
unregulated and would not effect the allowable
discharge concentration of organic pollutants as
required by OCPSF. For additional information
on the application of the combined waste stream
formula, see the Guidance Manual for the Use of
Production-Based Pretreatment Standards and
the Combined Waste Stream Formula.
However, as discussed on pages 3-2 to 3-3
of this guidance manual, unregulated streams are
presumed, for purposes of using the CWF, to
contain pollutants of concern at a significant
level. In effect, the CWF "gives credit" for
pollutants which might be present in the
unregulated wastestream. Rather than treating
the unregulated flow as dilution, which would
result in lowering the allowable concentration of.
a pollutant, the CWF allows the pollutant to be
discharged in the unregulated wastestream at the
same concentration as the standard for the
regulated wastestream that is being discharged.
This is based on the assumption that if pollutants
are present in the unregulated wastestream, they
will be-treated to the same level as in the
regulated wastestream. In—some- cases,
unregulated wastestreams may not actually
contain pollutants of concern at a significant-
level. Even if this is the case, they are still
considered unregulated when applying the
formula. However, if the control authority is
concerned that an unregulated stream is actually
acting as dilution,. a local or state control
authority can use its own legal authority to
establish a limit more stringent than would be
derived using the formula in the manner
prescribed by the Federal regulations.
Therefore, the control authority could apply its
best professional judgment to derive the same
chromium and lead limits as those derived in
Example 14-4 for the direct discharge example.
In the case of chromium the BPJ pretreatment
standard could be 0.307 mg/1 rather than the
CWF result of 3.07 mg/1. Similarly for lead, the
BPJ pretreatment standard could be 0.283 mg/1
rather than the CWF result of 0.283 mg/1.
14-27
-------
Chapter 14 Implementation
Development Document for the CWT Point Source Category
Exceptions to Guidance Provided for
CWT Facilities Also Covered By
Another Point Source Category 14.8.3.3
The only exceptions to the guidance
provided in sections 14.8,4.1 and 14.8.4.2 are
for facilities also subject to effluent guidelines
and preatreatment standards for Transportation
Equipment Cleaning (40 CFR 442) and effluent
guidelines for Landfills (40 CFR 445). The
application of the CWT rule to each of these
types of facilities is discussed below.
TRANSPORTATION EQUIPMENT
t CLEANING (TEC) 14:8.3.3.1
There are some facilities which are engaged
in both traditional CWT activities and traditional
TEC activities. "If the wastewaters from the two
operations are commingled, under the approach
adopted for TEC, the commingled wastewater
flow from the transportation equipment cleaning •
activities would be subject to CWT limits.
Therefore, a facility performing transportation
equipment cleaning as well as other CWT
services that commingles these wastes is a CWT
facility and all of the wastewater discharges are
subject to provisions of this rule. If, however, a
facility is performing both operations and the
waste streams are not commingled (that is,
transportation equipment cleaning process
wastewater is treated in one system and CWT
wastes are treated in a second, separate system),
both the TEC rule and CWT rule apply to the
respective wastewaters. If, however, the
wastewaters from the two separate treatment
systems are combined after treatment but prior
to discharge monitoring, discharge requirements
would be calculated by applying the "building
block approach" or the "combined waste stream
formula" as detailed in Sections 14.8.4.1 and
14.8.4.2.
LANDFILLS
14.8.3.3.2
In the CWT industry, there are some
facilities which are engaged both in CWT
activities and in operating landfills. For the CWT
final rule, EPA's approach to facilities which
treat mixtures of CWT wastewater and landfill
wastewater is consistent with that established for
the landfill guideline. Therefore, a facility
performing landfill activities, as well as other
CWT services, and commingles the wastewater
is a CWT facility only, and all of the wastewater
discharges are subject to the provisions of this
rule. If a facility is performing both operations
and the waste streams are not commingled (that
is, landfill wastewater is treated hi one treatment
system and CWT wastewater is treated.in a
second, separate treatment system), the
provisions of the Landfill rule and CWT rule
apply to its respective wastewaters. If, however,
the wastewaters from the two separate treatment
systems are "combined after treatment, but prior
to discharge monitoring, discharge requirements
would be calculated by applying the "building
block approach" or the "combined waste stream
formula" as detailed in Sections 14.8.4.1 and
14.8.4.2.
14-28
-------
Chapter 14 Implementation
Development Document for the CWT Point Source Category
ANYFIRM . GENERATOR'S WASTE PROFILE NUMBER
ANYTOWN, USA MATERIAL PROFILE SHEET
(555)555-1212 _ NEW
AMENDMENT
GENERATOR
Name
Address
Technical Contact Phone
Shipping Contact Phone
• Business Contact Phone
EPA IDS
BROKER OR SALESPERSON
Name
Address
Contact | Phone
TRANSPORTER
Name
Address
f
Contact I Phone
EPA ID # •
WASTE DESCRIPTION
CHEMICAL & PHYSICAL STATE
Liquid Multilayered
Semi-liquid Bilayered
Solid Single Phase
PH
. <. 2 8-10
2-4 10-12
4-6 i12
6-8 N/A
Odor
TSS
Color
Flash Point
% Bottoms Sediment
% Debris
% Ash
Specific Gravity
PROCESS DESCRIPTION
(Describe process generating waste stream. Include a list of virgin materials and their Material Safety Data Sheets.)
CHEMICAL CONSTITUENTS
Petroleum Phase Aqueous Phase
OTHER CONSTITUENTS
% Oil
METALS (PPM)
Arsenic
Cadmium
Chromium
Copper
Lead
Magnesium
Mercury
Nickel
Tin
Zinc
SHIPPING INFORMATION
RCRA Code
Shipping Method
Volume (gallons)
Figure 14-7. Template of a CWT Waste Receipt/Acceptance Form
. 14-29
-------
-------
Chapter
15
ANALYTICAL METHODS AND BASELINE VALUES
INTRODUCTION
15.1
This chapter describes the analytical methods
that EPA used to analyze the samples
collected during EPA's data gathering efforts at
a number of facilities (these sampling efforts are
described in Chapter 2). It also discusses how
EPA treated the results of its sample analysis for
purposes- of •identifying pollutants of concern
(described in Chapter 6), determining the
loadings (Chapter 12), and calculating the
limitations,, and standards (Chapter 10).
EPA contracted with various laboratories to
analyze the samples. The laboratories analyzed •
the samples using the methods identified in Table
15.1 and provided most of the results as liquid
concentrations (e.g., micrograms per liter
(ug/L)). In a few instances, the results were
provided as solids (e.g., milligrams per kilogram
(mg/Kg)). In those instances, EPA converted
the solids results into liquid concentration units
by using a conversion factor based upon the
percent of solids in the sample. In the rare'cases
that the percent solids was not available, EPA
excluded the data from its analyses. None of
these excluded data were for the analytes
regulated by today's rule.
EPA compared each laboratory-reported (or
converted) analytical result for each pollutant to
a baseline value in order to determine whether to
use the value as reported by the laboratory. In
most'cases, the baseline value was the "nominal
quantitation limit"1 stipulated for the specific
method used to measure a particular pollutant.
'in other sections in this document and in
the preamble to the rulemaking, EPA sometimes
uses the term "minimum analytical detection
limit" when it refers to nominal quantitation limit
or the baseline value.
In general, the term "nominal quantitation limit"
is used here to describe the smallest quantity of
an analyte that can be measured reliably with a
particular analytical method. In some cases,
however, EPA used a value lower than the
nominal quantitation limit as the baseline value
because data demonstrated that reliable
measurements could be obtained at a lower level.
In a few instances, EPA has concluded that the
nominal quantitation limit for a specified method
was less than the level that laboratories could
reliably achieve— For those pollutants, EPA
modified the nominal quantitation limit upward
and used a higher value as the baseline value.
•Sections 15.3 and 15.4 provide further
explanation, .of nominal quantitation limits and
baseline values. Table 15-1 sets forth the
analytical methods and baseline, values used for
each pollutant in identifying pollutants of
concern-, developing the loadings, and calculating
limitations and standards.
ANALYTICAL RESULTS
15.2
The laboratories expressed the result of the
analysis either numerically or as "not
quantitated"2 for a pollutant in a sample. When
the result is expressed numerically, then the
pollutant was quantitated3 in the sample. For
example, for a hypothetical pollutant X, the
2Elsewhere in this document and hi the
preamble to the rulemaking, EPA refers to
pollutants as "not detected" or "non-detected."
This chapter uses the term "not quantitated" or
"non-quantitated" rather than non-detected.
3Elsewhere in this document and in the
preamble to the rulemaking, EPA refers to
pollutants as "detected." This chapter uses the
term "quantitated" rather than detected.
15-1
-------
Chapter 15 Analytical Methods and Baseline Values .Development Document for the CWT Point Source Category
result would be reported as "15 ug/L" when the
laboratory quantitated the amount of pollutant X
in the sample as being 15 ug/L. For the non-
quantitated results, for each sample, the
laboratories reported a "sample-specific
quantitation limit"4 For example, for the
hypothetical pollutant X, the result would be
reported as "<10 ug/L" when the laboratory
could not quantitate the amount of pollutant X in
^the sample. That is, the analytical result
indicated a value less than the sample-specific
quantitation limit of 10 ug/L. The actual amount
of pollutant X in that sample is between zero
(i.e., the pollutant is not present) and 10 ug/L.
The sample-specific quantitation limit for a
particular pollutant is generally the smallest
quantity in the calibration range that may be
measured reliably in any given sample. If a
pollutant is reported as not quantitated in a
particularwastewater sample, this doesnotmean
that the pollutant is not present in the -
wastewater, merely that analytical techniques"
(whether because of instrument limitations, ~
pollutant interactions or other reasons) do not
permit its measurement at levels below the
sample-specific quantitation limit.
In a few instances, some of the laboratories
reported numerical results for specific pollutants
detected hi the samples as "right-censored."
Right-censored measurements are those that
were reported as being greater than the highest
calibration value of the analysis (e.g., >1000
ug/L).
In its calculations, EPA generally substituted
the value of the reported sample-specific
quantitation limit for each non-quantitated result.
In a few cases when the sample-specific
quantitation limit was less than the baseline
value, EPA substituted the baseline value for the
4Elsewhere in this document and in the
preamble to the rulemaking, EPA refers to a
"sample-specific quantitation limit" as a "sample-
specific detection limit" or, more simply, as a
"detection limit."
non-quantitated result. In a few instances when
the quantitated value was below the baseline
value, EPA considered these values to be non-
quantitated in the statistical analyses and
substituted the baseline value for the measured
value. For the rare instances when the
laboratory reported a measurement as right-
censored, EPA used the highest calibration value
in its calculations.
NOMINAL QUANTITATION LIMITS
15.3
Protocols used for determination of nominal
quantitation limits in a particular method depend
on the definitions and conventions that EPA used"
at the time the method was developed. The
nominal quantitation limits associated with the
methods addressed in the following sections fall
Tnto-three- general-categories; The -first category
includes Methods 1624, 1625, and 1664, which
used the minimum level (ML)'definition as-the
lowest level at which the entire analytical system
must give a recognizable signal and an acceptable
calibration point for the analyte. The second
category pertains specifically to Method 1620,
and is explained in detail in section 15.5.3. The
third category pertains to the remainder of the
methpds (i.e., the National Council for Air and
Stream Improvement, Inc. (NCASI) Method
85.01 and the classical wet chemistry methods),
in which a variety of terms are used to describe
the lowest level at which measurement results
are quantitated. In some cases (especially with
the classical wet chemistry analytes) the methods
are older (1970s and 1980s) and different
concepts of quantitation apply. These methods
typically list a measurement range or lower limit
of measurement. The terms differ by method
and, as discussed in subsequent sections, the
levels presented are not always representative of
the lowest levels laboratories can achieve
currently. For those methods associated with a
calibration procedure, the laboratories
demonstrated through a low point calibration
standard that they were capable of reliable
15-2
-------
Chapter 15 Analytical Methods and Baseline Values Development Document for the CWT Point Source Category
quantitation at method-specified (or lower)
levels. In such cases these nominal quantitation
limits are operationally equivalent to the ML
(though not specifically identified as such in the
methods). In the case of titrimetric or
gravimetric methods, the laboratory adhered to
the established lower limit of the measurement
range published in the, methods. Details of the
specific methods are presented in Section 15.5.
BASELINE VALUES
15.4
Before using the data to identify pollutants of
"" concern, determine the loadings, and calculate
the limitations and standards; EPA compared
each analytical result (i.e., quantitated value or
sample-specific quantitation limit for a non- ,
quantitated value) to a baseHne value for the
pollutant. For example, if a facility data set had
..five values for oil and grease of which two were
non-quantitated with sample-specific quantitation
limits of 10 mg/L and the remaining three values
were quantitated with measurements of 20 mg/L,
25 mg/L, and 50 mg/L, then all five values (10
mg/L, 10 mg/L, 20 mg/L, 25 mg/L, and 50
mg/L) were compared to the baseline value of 5
mg/L for oil and grease. In most cases, the
detected values and sample-specific quantitation
limits were equal to or greater than the baseline
values.
In general, the baseline value was equal to
the nominal quantitation limit identified for the
method. For example, for total cyanide, the
baseline value was 0.02 mg/L which is the same
as the nominal quantitation limit of 0.02 mg/L for
total cyanide in Method 335.2.
EPA made several exceptions to this general
rule when EPA determined that the baseline
value should differ from the nominal quantitation
limit as specified in the method for a pollutant.
For example, EPA determined that the baseline
value for COD by Method'410.1 should be 5
mg/L rather than the nominal quantitation limit of
50 mg/L. (Section 15.5.6 explains this decision.)
EPA made exceptions to the general rule based
upon EPA's knowledge about the methods,
experiences with laboratories using those
methods, and the need for a single baseline value
for each pollutant. For example, EPA selected a
baseline value to be less than a nominal
quantitation limit when the laboratories
demonstrated through calibration or other quality
control (QC) data that reliable measurements of
the pollutant could be made at a lower level. For
these pollutants, the nominal quantitation limits
reported -in the methods are overestimates of
what laboratories can reliably achieve and, the
.baseline values were adjusted downwards.
Another example is when EPA selected baseline
values greater than the nominal'quantitation
limits because the nominal quantitation limits
could not be reliably achieved. A third example.
is when EPA selected a single baseline value
when the pollutant was measured by two' or
more methods, each with a different nominal
quantitation limit.
The following section provides a brief
description of the analytical methods and
explains any differences between the-nominal
quantitation limits and the baseline values.
15-3
-------
Chapter 15 Analytical Methods and Baseline Values Development Document for the CWT Point Source Category
Table 15-1 Analytical Methods and Baseline Values
Method
D4658
160.1
1602
1620
1624
1625
1664
1664
209F
218.4
325.1
3253
335.2
340.1
3402
350.1
3502
3503
3500D"
353.1
3532
3533
3652
3653
376.1
405.1
405.1
410.1
410.1
4102
410.4
413.1
415.1
4202
5210
85.01
Analyte
Total sulfide
Total dissolved solids
Total suspended solids
Metals compounds
Organic'compounds
Organic compounds
HEM
SGT-HEM
Total solids
Hexavalcnt chromium
Chloride
Chloride
Total cyanide
Fluoride
Fluoride
Ammonia as nitrogen
Ammonia as nitrogen
Ammonia as nitrogen
Hexavalent chromium
Nitrate/nitrite
Nitrate/nitrite
Nitrate/nitrite
Total phosphorus
Total phosphorus
Total sulfide
Carbonaceous BOD,
BODS
COD
D-COD '
COD
COD
Oil and grease
Total organic carbon
Total phenols
BOD,
Chlorinated phenolics
CAS Number
18496-25-8
C-010
C-009
*
*
*
C-036
C-037
C-008
18540-29-9
16887-00-6
16887-00-6
57-12-5
16984-48-8
16984-48-8
7664=41-7
7664-41-7
7664-41-7
18540-29-9
C-005
C-005
C-005
14265-44-2
14265-44-2
18496-25-8
C-002
C-003
C-004
C-004D
C-004
C-004
C-007
C-012
C-020
C-003
*
Nominal
Quantitation
Value
0.04
10.0
4.0
5.0
5.0
10.0
0.01
1.0
1.0
0.02
0:1~
0.1
0.01
0.05'
0.03
0.1
0.01
0.05-
0.01
0.01
0.01
1.0
2.0
2.0
50.0
50.0
5.0
3.0*
20.0
5.0,
1.0
0.01
2.0
Baseline Value
1.0
10.0
4.0
5.0
5.0
10.0
. 0.01
1.0
1.0
0.02
0:1"
0.1
0.05
. 0.05
0.05
0.01-
0.05
0.05
0.05
0.01
0.01
1.0
• 2.0
2.0
5.0**
5.0**
5.0**
5.0
5.0
1.0
0.05
2.0
Unit
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L—
mg/L
mg/L
mgOL.
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Assumption for Reported
Values ' < Baseline Value
used reported value'
n/a
n/a
used reported value
modified
modified
modified
modified
n/a
used reported value
n/a
n/a
used reported value
n/a- -
n/a
n/a
n/a
n/a
n/a --'--•
used reported value
used reported value
used reported value
n/a . ••
n/a
used reported value
n/a
used reported value
n/a
n/a
n/a
n/a
used reported value
n/a
used reported value
n/a
n/a
* If the entry in this column indicates that EPA 'used the reported value' for a particular analyte, then EPA used either the quann'tated value or the sample-
spccific quantitation limit reported by the laboratory. If the entry is 'n/a' then none of the data that EPA used in its analyses were reported below the
baseline value.
•The method analyzed a number of pollutants. Attachment 15-1 identifies all pollutants that EPA considered (see section 2) and their baseline values.
In general, the baseline values are equal to the nominal quantitation limits.
"The baseline value was adjusted to reflect the lowest nominal quantitation limitofthetitrimetric procedures (i.e., 410.1 and410.2). See Section 15.5.6
fora detailed explanation.
'Method 410.4 lists two different quanitation limits that are dependent upon whether the automated or manual protocols are followed. The automated
method limit=3 mg/L and the manual method limit=20 mg/L.
15-4
-------
Chapter 15 Analytical Methods and Baseline Values Development Document for the CWT Point Source Category
ANALYTICAL METHODS
15.5
Table 15-1 provides a summary of the
analytical methods, the associated pollutants
measured by the method, the nominal
quantitation levels, the baseline levels, and the
assumptions for values reported below the
baseline levels. Attachment 15-1 provides a
more complete list of the pollutants and their
baseline values. The following subsections
provide additional information supporting the
summary in Table 15-1. '
Methods 1624,1625,1664
(Organics, HEM)
15.5.1
As stated earlier, Methods 1624 and 1625
for organic compoundsrand- Method 16645~for
H-hexane~exrractable~material (HEM) and silica
gel treated «-hexane exrractable material (SGT-
HEM)S use the minimum level concept for
quantitation of the pollutants measured by the
methods. The ML is defined as the lowest level
at which the entire analytical system must give a
recognizable signal and an acceptable calibration
point for the analyte. When an ML is published
in a method, the Agency has demonstrated that
the ML can be achieved in at least one well-
operated laboratory, and when that laboratory or
another laboratory uses that method, the
laboratory is required to demonstrate, through
calibration of the instrument or analytical system,
that it can make measurements at the ML. For
these methods, EPA used the niinimum levels as
the baseline values.
If a quantitated value or sample-specific
quantitation limit was reported with a value less
than the ML specified in a method, EPA
5See final rulemaking at 64 Federal
Register 26315, May 14, 1999.
6SGT-HEM measures non-polar material
(i.e., n-hexane extractable material that is not
absorbed by silica gel). Method 1664 measures
both oil and grease and non-polar material.
substituted the value of the ML and assumed
that the measurement was non-quantitated7. For
example, if the ML was 10 ug/L and the
laboratory reported a quantitated value of 5 ug/L,
EPA assumed that the concentration was non-
quantitated with a sample-specific quantitation
limit of 10 ug/L.
Method 413.1 (Oil and Grease) 15.5.2
Method 413.1 was used in early sampling
episodes to measure-pollutant concentrations of
oil-and grease.- Because this method requires
freon, an ozone depleting solvent, to perform the
analysis, EPA developed and- recently
promulgated Method 1664 to replace the
procedures currently approved at 40 CFR 136.
The same nominal quantitation limit of 5 mg/L
applies to both methods for measuring oil and
grease and- HEM.
Of the data used to identify the pollutants of
concern and calculate pollutant loadings, a few of
the quantitated values from Method 413.1 were
lower than the nominal quantitation limit. EPA
used the values as reported in its analyses. .
(None of the sample-specific quantitation limits
were less than the nominal quantitation limit.)
Of the data used to develop the limitations,
none of the quantitated values and sample-
specific quantitation limits were less than the
nominal quantitation limit.
Method 1620
15.5.3
Method 1620, which measures the amounts
of specific metals in samples, uses the concept of
an instrument detection limit (IDL), which is
defined as "the smallest signal above background
7For p-cresol, EPA used 10 ug/L as the
ML in many of its data analyses. However, in
developing the limitations and standards for the.
organics subcategory EPA used the correct ML of
20 ug/L.
15-5
-------
Chapter 15 Analytical Methods and Baseline Values Development Document for the CWTPoint Source Category
noise that an instrument can detect reliably."8
IDLs are determined on a quarterly basis by each
analytical laboratory participating in the data
gathering efforts by EPA's Engineering and
Analysis Division (EAD) and are, therefore,
laboratory-specific and time-specific. Data
reporting practices for Method 1620 analysis
follow conventional metals reporting practices
used in other EPA programs, in which values are
reported at or above the IDL. Though Method
1620 does contain minimum levels (MLs), these
MLs pre-date EPA's recent refinement of the
minimum level concept. The ML values
associated with Method 1620 are based on a
consensus opinion reached between EPA and
laboratories during the 1980s regarding-levels
that could be considered reliable quantitation
limits when using Method 1620. These limits do
not reflect advances in technology, and
instmmentation,since.theJ980s. Consequently,
the IDLs were used as the baseline for reporting; -
purposes, with the general understanding that
reliable results can be produced at or above the
IDL.
The Method 1620 ML values were used as
the baseline values in the data screening, with the
exception of two analytes: boron and lead.
Based on laboratory feedback years agor it was
determined that the boron ML of 10 ug/L
specified in Table 9 of Method 1620 could not
be reliably achieved. Consequently, for the
purposes of EAD's data gathering under the
metals contracts, the ML for boron was adjusted
to 100 ug/L. In the case of lead, which has an
ML of 5 ug/L associated with graphite furnace
atomic absorption (GFAA) spectroscopy
analysis, EAD determined that it was not
necessary to measure down to such low levels,
and that lead could be analyzed by inductively
coupled plasma atomic emission (ICP)
, 8Keith, L.H., W. Crummett, J. Deegan,
R.A. Libby, J.K. Taylor, G. Wentler (1983).
"Principles of Environmental Analysis," '
Analytical Chemistry, Volume 55, Page 2217.
spectroscopy instead. Consequently, the ML
requirement was adjusted to 50 ug/L.
In one sampling episode (1987), the
laboratory did not provide sample-specific limits9
for the 42-element semiquantitative screen
component of Method 1620. In 1990, when
these analyses were performed, the laboratory's
standard convention to report non-quantitated
results from semiquantitative analysis was to
populate the summary form with 'ND' rather
than reporting sample-specific limits. In
identifyingpollutants of concern and determining
the loadings, EPA generally-assumed that-the-
sample-specific limits were,equaLto the.baseline
values for the pollutant (none of these pollutants
were regulated in this rule).
Though the baseline values were derived
from the MLs (or adjusted MLs) in Method
1620,.. EPA used the laboratory reported
quantitated values and sample-specific
quantitation— limits (or substituted baseline
values), which captured concentrations down to
the IDLs, in identifying the pollutants of concern
and calculating. the pollutant loadings and
limitations. If the long-term average for a
pollutant was less than the baseline value,
however, EPA substituted the baseline value for
the long-term average and re-calculated the
limitation using this revised long-term average
and the variability factor.
Method 85.01
(Chlorinated Phenolics)
15.5.4
NCASI Method 85.01 was used to analyze
some samples associated with the organics
subcategory for chlorinated phenolics. This gas
chromafography/electron capture detector
(GC/ECD) method predates EPA Method 1653
9These limits are lower threshold limits
(LTLs) and are based upon signal-to-rioise ratio
for each element. As such, these are different
than the quantitation limits as defined in this
section.
15-6
-------
Chapter 15 Analytical Methods and Baseline Values,; Development Document for the CWT Point Source Category
for chlorinated phenolics determination, and was
only used for analysis of samples under one
CWT sampling episode (Episode 1987, collected
in 1990). Method 1653 is an isotope dilution gas
chromatography/mass spectrometry (GC/MS)
method.
Some chlorinated phenolics in Episode 1987
were analyzed by both Method 85.01 and
Method 1625. Thus, for a given sample, there
were two results for a specific chlorinated
phenolic compound. Of the pollutants of
concern, these compounds were
pentachlorophenol, 2,3,4,6- tetrachlorophenol,
2,4,5-trichlorophenol, and 2,4,6-trichlorophenol.
Where two results were provided for the same
pollutant in a sample, EPA used the analytical
result from Method 162-5. This decision is based:
on the knowledge that Method 1625 is an isotope
dilution GC/MS procedure and, therefore,
produces more_ reliable results'than~ Method-
85.01.
For the remaining chlorinated phenolics
analytes that were determined by Method 85.01,
EPA used the laboratory-specffic quantitatibn
limits as the baseline values. These laboratory-
specific quantitation limits were established by
the laboratory through its calibration procedures.
The quantitation limits reported were
representative of a low level calibration standard
concentration, thereby complying with the
minimum level definition of the lowest level at
which the entire analytical system gives a
recognizable signal and an acceptable calibration
point.
EPA used the data from Method 85.01 to
identify pollutants of concern and to determine
pollutant loadings. In all cases, the quantitated
values and sample-specific quantitation limits
were greater than or equal to the baseline value
associated with the pollutant.
EPAhas not used the Method 85.01 results
in calculating any limitations or standards. EPA
is regulating one of the analytes measured by this
method; however, the data used to calculate the
limitations and standards were generated by
Method 1625.
Methods D4658 and 376.1
(Total Sulfide)
15.5.5
Total sulfide was analyzed by Methods
376.1 and D4658, each of which have different
nominal quantitation limits. Method 376.1 has a
nominal quantitation limit of 1 mg/L, while
Method D4658 has a nominal quantitation limit
of ,0.04 mg/L., Rather-thaa use. two, different
baseline values for the same pollutant, EPA used
the maximum of the two values (i.e., 1 mg/L) as
the baseline value.
In some cases, the reported quantitated value
or sample-specific quantitation limit was lower
than- the-nominal quantitation limits identified in
the method., EPA used these values as reported
in identifying the pollutants of concern and,
calculating the. pollutant loadings_(EPA did not
regulate total sulfide in this rule).
Methods 410.1, 410.2, and 410.4
(COD and D-COD)
15.5.6
Methods 410.1,410.2, and 410.4 were used
to measure chemical oxygen demand (COD)
concentrations. In addition, Method 410.1 was
used to measure the dissolved chemical oxygen
demand (D-COD) concentrations in Episode
1987.
Methods 410.1 and 410.2 are titrimetric
procedures that follow identical analytical
protocols, with the exception of the
concentration level of the reagents used for the
titration. Method 410.1 is designed to measure
"mid-level" concentrations greater than 50 mg/L
for COD and D-COD. Method 410.2 is
designed to measure "low-level" concentrations
of these parameters in the range of 5-50 mg/L.
When one of the participating laboratories
analyzes a sample, they are required to measure
down to the lowest quantitation limit possible.
Consequently, if the laboratory analyzes a
sample using Method 410.1 and obtains a non-
15-7
-------
Chapter 15 Analytical Methods and Baseline Values Development Document for the CWT Point Source Catesorv
quantitated result, it must reanalyze the sample
usingMethod410.2. Therefore, the quantitation
limit reported for non-quantitations will be equal
to 5 mg/L, unless sample dilutions were required
because of matrix complexities. Method 410.4
is a colorimetric procedure with a measurement,
range of 3-900 mg/L for automated procedures
and measurement range of 20-900 mg/L for
manual procedures.
For all COD "data, EPA used the baseline
value of 5 mg/L that is associated with the lower
quantitation limit for the titrimetric procedures
because most of the data had been obtained by
the titrimetric procedures (i:e., Methods 410. Tor
410.2). Regardless of the method used to
analyze COD and D-COD, all quantitated values
and sample-specific quantitation limits used to
identify the pollutants of concern and calculate
the pollutant loadings were greater than,the
nominal quantitation limit of 5 mg/L (EPA did
not regulate COD and D-COD in this rule):
Method 218.4 and 3500D
(Hexavalent Chromium)
15.5.8
Method 420.2 (Total Phenols)
15.5.7
Method 420.2 was used to analyze for total
phenols. The method reports two "working
ranges"; one with a lower range limit of 0.002
mg/L and the other with a lower range limit of
0.01 mg/L. In this case, EPA's experience with
the laboratories has indicated that some can meet
the lower limits of the method-specified range
and others cannot. Consequently, EPA
determined that the baseline value should be 0.05
mg/L, which reflects the quantitation limit that all
participating laboratories were capable of
achieving.
In some cases, the quantitated value or the
sample-specific quantitation limit was lower than
the baseline value of 0.05 mg/L. Because some
laboratories have demonstrated that they can
quantitate to lower levels, EPA used these values
as reported in identifying pollutants of concern
and calculating the pollutant loadings (EPA did
not regulate total phenols in this rule).
Hexavalent chromium was determined by
Methods 218.4 and 3500D. Because most of
the samples were analyzed using Method 218.4,
its baseline value of 0.01 mg/L was used for all
hexavalent chromium results. For some samples
analyzed by Method 218.4, the quantitated value
or sample-specific quantitation limit was lower
than the nominal quantitation limit identified in
the method. (None of the data used from
Method 3500D were less than the nominal
quantitation limit.) EPA used these values as
reported in identifying the pollutants of concern
and calculating the pollutant loadings. In
calculating the limitations and standards, none of
the- quantitated values or sample-specific
quantitation limits were lower than the .nominal
quantitation limitidentified in the method (EPA
did not regulate hexavalent chromium in this
rule).
Method 335.2 (Total Cyanide)
15.5:9
Samples were analyzed for total cyanide
using Method 335.2. The nominal quantitation
limit and the baseline value were the same.
In some cases, the reported sample-specific
quantitation limit was lower than, the baseline
value for the pollutant. (None of the quantitated
values was lower than the baseline value.)
Because some laboratories have demonstrated
that they can quantitate to lower levels, EPA
used these values as reported in identifying the
pollutants of concern and calculating the
pollutant loadings. None of the data used to
calculate the limitations were lower than the
baseline value.
15-8
-------
Chapter 15 Analytical Methods and Baseline Values Development Document for the CWTPoint Source Category
Methods 353.1, 353.2, and 353.3
(Nitrate/Nitrite)
15.5.10
Nitrate/nitrite was determined by three EPA
methods, each of which list slightly different
nominal quantitation limits, which are expressed
in the methods as the lower limit of the
measurement range. Methods 353.1 and 353.2
are automated colorimetric procedures with
quantitation limits of 0.01 and 0.05 mg/L,
respectively. Method 353.3 is a cadmium
reduction, spectrophotometric procedure with a
nominal quantitation limit of 0.01 mg/L. Rather
than use two different baseline values for the
same pollutant, EPA used the maximum of the
two values (i.e.-, 0.05 mg/L) as the baseline.
In several instances.; the reported quantitated
values orsample-specific quantitation limits were
below the O'.OSTng/L baseline value. Because the
laboratory~demonstrated that it could quantitate
at lower levels, EPA used these values as
reported in identifying the pollutants of concern
and calculating the pollutant loadings (EPA did
not regulate nitrate/nitrite in this rule).
Methods 350.1, 350.2, and 350.3
(Ammonia as Nitrogen)
15.5.11
Ammonia as Nitrogen was measured by
three different procedures, each of which were
associated with a different nominal quantitation
limit Method 350.1 is an automated
colorimetric procedure with a lower
measurement range limit of 0.01 mg/L. Method
350.2 utilizes either colorimetric, titrimetric, or
electrode procedures to measure ammonia, and
has a lower measurement range limit of (a) 0.05
mg/L. .for the colorimetric and electrode
procedures and (b) 0.01 mg/L for the titrimetric
procedure. Method 350.3 determines ammonia
potentiometrically using an ion selective
ammonia electrode and a pH meter and has a
lower measurement range limit of 0.03 mg/L.
Rather than use different baseline values for the
same pollutant, EPA used the maximum of the
values (i.e., 0.05 mg/L)'as .the baseline.
None of the quantitated values and sample-
specific quantitation limits used to identify the
pollutants of concern and calculate the pollutant
loadings were less than the baseline value (EPA
did not regulate ammonia as nitrogen in this
rule). ,
Remaining Methods
15.5.12
The previous subsections in section 15.5
identify many of the methods used to analyze the
wastewater samples. The remaining methods
were: 160.1 (total dissolved solids), 160.2 (total-
suspended solids), 209F (total solids), 325.1 and
325.3 (chloride), 340-1 and 340.2 (fluoride),
365:2-and 365.3 (total phosphorus), 405.1 (5-
day biochemical oxygen demand (BOD5) and
carbonaceous BOD5), 5210 (BOD5), and 415.1
(total organic carbon). For these methods, the_
nominal quantitation limits and the baseline
values were equal. .In addition, none of the
quantitated values were reported below the
nominal quantitation limits. For one sample, the
sample-specific quantitation limit for BOD5 was
less than the nominal quantitation limit. EPA
used this sample-specific quantitation limit in
identifying pollutants of concern and calculating
pollutant loadings for BOD5.
Of the pollutants measured by these
methods, EPA proposed limitations for total
suspended solids (TSS) and BOD5.
ANALYTICAL METHOD
DEVELOPMENT EFFORTS
15.6
Section 304(h) of the Clean Water Act
directs EPA to promulgate guidelines establishing
test procedures for the analysis of pollutants.
These test procedures (methods) are used to
determine the presence and concentration of
pollutants in wastewater, and are used for
compliance monitoring and for filing applications
for the NPDES program under 40 CFR 122.21,
122.41, 122.44 and 123.25, and for the
15-9
-------
Chapter IS Analytical Methods and Baseline Values Development Document for the CWTPoint Source Category
implementation of the pretreatment standards
under 40 CFR 403.10 and 403.12. EPA
publishes test procedures for the wastewater
program at 40 CFR 136.3. Currently approved
methods for metals and cyanide are included in
the table of approved inorganic test procedures at
40 CFR 136.3, Table I-B. Table I-C at 40 CFR
136.3 lists approved methods for measurement
of non-pesticide organic pollutants, and Table I-
D lists approved methods for the toxic pesticide
pollutants and for other pesticide pollutants.
Dischargers must use the test methods
promulgated at 40 CFR Part 136.3 or
incorporated by reference in the tables to
monitor pollutant discharges from the centralized
waste treatment (CWT) industry, unless
specified otherwise in part 437 or by the
permitting authority.
The final CWT rule amends 40 CFR Part
136, Appendix A, to specify the applicability of
certain methods for specific wastestreams. The
amendments accomplish several objectives,
which are outlined in the following paragraphs.
Briefly, the amendments clarify' EPA's intent
regarding the applicability of Methods 625 and
1625 for some of the pollutant parameters in the
final rule for Centralized Waste Treatment
facilities and also for some of the pollutant
parameters in 40 CFR 445 (Landfills Point
Source Category).
The 1999 CWT proposal (at 64 FR 2297)
stated that 11 CWT semivolatile organic
pollutants and two CWT volatile organic
pollutants (2-butanone and 2-propanone) were
not listed in Table I-C at 40 CFR 136.3. Even
though these 13 analytes were not shown in
Table I-C, there were already approved test
methods for six of these 13, as follows. EPA
Method 1624 lists 2-butanone and 2-propanone,
provides performance data for these two
analytes, and is an approved method for these
two analytes. EPA Method 1625 lists four of the
11 CWT semivolatile organic pollutants with
relevant performance data and is an approved
method for these four analytes (alpha-terpineol,
carbazole, n-decane, and n-octadecane).
In the 1999 CWT proposal, EPA proposed
to expand the analyte list for the 'already-
approved methods and also to allow modified
versions of Methods 625 and 1625. The Docket
for the proposed rulemaking included the
proposed modifications to Methods 625 and
1625 regarding expansion of the analyte list. The
expanded list covered 17 pollutants in total,
including all of the proposed CWT semivolatile
organic pollutants. For 7 of those analytes,
performance data were not available for either
method and these data were not included in the
Docket at proposal. EPA also noted its plans for
further validation of the method modifications.
Since proposal, EPA has gathered
performance data on the additional seven CWT
analytes and additional analytes of interest^for --
other industry categories. In January 2000, EPA
amended Methods 625 and 1625 by adding the,.
performance data for the additional analytes.
The amendments consist of'text^ performance
data, and quality control'(QC) acceptance criteria
for the additional analytes. This information will
allow a laboratory to practice the methods with
the additional analytes as an integral part. The
QC acceptance criteria for the additional analytes
were validated in single-laboratory studies. The
January 2000 amendments were part of the
rulemaking notice for the effluent limitations
guidelines and standards for the Landfills Point
Source Category (65 FR 3008, January 19,
2000). EPA's intent was to promulgate
amendments to Methods 625 and 1625 that
would allow the use of those methods for
specific pollutants regulated in 40 CFR Part 445
(i.e., Landfills) for purposes of that rule only.
Some of the pollutants had also been included in
the CWT proposal. Subsequent to the Landfills •
promulgation, EPA received inquiries about the
scope and applicability of the amendments to the
test methods. In response to those inquiries,
EPA published a notice of data availability
(NODA) and request for comment on the data
collected for the additional analytes (see 65 FR
15-10
-------
Development Document for the CWT Point Source Category
41391, July 5, 2000).
The NODA clarified EPA's intent regarding
the method amendments by explaining that the
amendments published on January 1 9, 2000 "...
are applicable only to the five regulated
pollutants in the Landfills rule when found in the
waste streams regulated under that rule" (65 FR
41392). The NODA also announced EPA's.
plans to further amend the methods, in the final
CWT. rulemaking (i.e., this" rulemaking)- to
specify that the revisions to Methods 625 and-
r625"apply to the pollutants promulgated in the
final CWT_.rule and only for the wastestreams
regulated in the final CWT rule. In the final
CWT amendments to 40 CFR Part 136,
Appendix A, EPA thus clarifies its intent
regarding- the scope of method amendments.
Specifically, the amendments include additional
textto.the Introduction section of the attachment
at, the.. end of Methods 625 and 1625 and '
footnotes .to Tables -in- the -attachment. The-
amendments'delineate the scope of Methods 625
and-1625 regarding compliance with monitoring
requirements for the wastestreams covered by 40
CFR Parts 437 and 445. In addition, EPA
deleted from the attachment to the methods
those analytes not covered by the Landfills and
CWT final rules.
15-11
-------
Chapter 15 Analytical Methods and Baseline Values Development Document for the CWT Point Source Category
Attachment 15-1 Analytical Methods and Baseline Values
Pollutant
CLASSICALS OR CONVENTIONALS
Ammonia as nitrogen
Biochemical oxygen demand (BOD)
BOD 5-day (carbonaceous)
Chemical oxygen demand (COD)
Chloride •
D-Chemical oxygen demand
Fluoride
Hexane extractable material (HEM)
Hexavalent chromium
Nitrate/nitrite
SGT-HEM
Total cyanide
Total dissolved solids
Total organic carbon (TOC)
Total phenols
Total phosphorus
Total recoverable oil and grease
Total solids
Total sulfide
Total suspended solids
METALS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Bismuth
Boron
Cadmium
Calcium
Cerium . ,
Chromium
Cobalt
CAS -No.
7664-41-7
C-003
C-002
C-004
16887-00-6
C-004D
16984-48-8
C-036
18540-29-9
C-005
C-037
57-12-5
C-010
C-012
C-020
14265-44.2
C-007
C-008
18496-25-8
C-009
7429-90-5
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-69-9
7440-42-8
7440-43-9
7440-70-2
7440-45-1
7440-47-3
7440-48-4
Method
350.1
350.2 .
350.3
405.1
5210
405.1
410.1
410.2
410.4
410:4
325.1
325.3
410.1
340.1
340.2
1664
218.4
3500
353.1
353.2
353.3 - .
1664
335.2 ,
160.1
415.1
420.1
420.2
365.2
365.3
413.1
209F
376.1
D4658
160.2
1620
1620
1620
1620
1620
• 1620
1620
1620
1620
1620
1620
1620
Baseline
Value
0.05
0.05
0.05
2.00
2.00
2.00
5.00
5.00
5.00
5.00.
1.00
1.00
5.00
0.10
0.10
5.00
0.01
0:0-1--
0.05
0.05
0:05
5.00 -
0.02
10.00
1.00
0.05
0.05
0.01
0.01
5.00
10.00
1.00
1.00
4.00
200.00
20.00
10.00
200.00
5.00
100.00
100.00
5.00
5000.00
1000.00
10.00
50.00
Unit
mg/L
mg/L
mg/L,
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L'
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
'mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
%
mg/L
mg/L
mg/L
ug/L
ug/L '
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
-ue/L
•15-12
-------
Chapter 15 Analytical Methods and Baseline Values Development Document for the CWT Pnint fin
Pollutant
Copper
Dysprosium
Erbium
Europium
Gadolinium
Gallium
Germanium
Gold
Hafnium
Holmium
Indium
Iodine
Iridium
Iron
Lanthanum
Lead
Lithium
Eutetium
• Magnesium
Manganese
Mercury-
Molybdenum
Neodymium
Nickel
Niobium
Osmium
Palladium
Phosphorus
Platinum
Potassium
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Tantalum
Tellurium
Terbium
Thallium
Thorium
Thulium
Tin
Titanium
CAS No.
7440-50-8
7429-91-6
7440-52-0
7440-53-1
1 7440-54-2
7440-55-3
7440-56-4
7440-57-5
7440-58-6
7440-60-0
7440-74-6
.7553-56-2
' . 7439-88-5
7439-89-6
7439_91-0
7439-92-1
7439-93-2
7439-94-3
7439-95^-4""
7439-96-5
T43P-97-6
7439-98-7
7440-00-8
7440-02-0
7440-03-1
7440-04-2
7440-05-3
7723-14-0
7440-06-4
. 7440-09-7
7440-10-0
7440-15-5
7440-16-6
7440-18-8
7440-19-9
7440-20-2
7782-49-2
7440-21-3
7440-22-4
7440-23-5
7440-24-6
7704-34-9
7440-25-7
13494-80-9
7440-27-9
7440-28-0
7440-29-1
7440-30-4
7440-31-5
7440-32-6
Method
1620
1620
1620
1620
1620
1620 -
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620-
1620
1620 ~
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620 ,
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
1620
Baseline
„ . Unit
25.00 ug/L
100.00 ug/L
100.00 ug/L
100.00 ug/L
500.00 ug/L
500.00 ug/L
500.00 ug/L
1000.00 ug/L
1000.00 ug/L
500.00 ug/L
1000.00 ug/L
.- 1000.00 ug/L
1000.00 ug/L
100.00 ug/L
lOO^OO ug/L
50.00 ugVL
100.00- ug/L
100.00 ug/L
5000.00 ug/L
~ 15,00- ugflL...
'0:Z(T ug/L
10700 ug/L
500.00 ug/L
40.00 ug/L
1000.00 ug/L
100.00 ,ug/L
500.00 ug/L
1000.00 ug/L
1000.00 ug/L
1000.00 ug/L
1000.00 ug/L
1000.00 ug/L
1000.00 ug/L
•1000.00 ug/L
500.00 ug/L
100.00 ug/L
5.00 ug/L
100.00 ug/L
10.00 ug/L
5000.00 ug/L
100.00 ug/L
1000.00 ug/L
500.00 ug/L
1000.00 ug/L
500.00 ug/L
10.00 ug/L
1000.00 ug/L
500.00 ug/L
30.00 ug/L
15-13
-------
Chanter 15 Analytical Methods and Baseline Values Development Document for the CWT Point Source Category
Pollutant
Tungsten
Uranium
Vanadium
Ytterbium
Yttrium
Zinc
Zirconium
ORGANICS
Acenaphthene
Acenaphthylene
Acetophenone
Acrylonitrile
Alpha-terpineol
Aniline
Aniline, 2,4,5-trimethyl-
Anthracene
Aramite
Benzanthrone
Benzene
Benzenethiol
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Benzoicacid .
Benzonitrile, 3,5-dibromo-4-hydroxy-
Benzyl alcohol
Beta-naphthylamine
Biphenyl
Biphenyl, 4-nitro
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl) ether
Bis(2-chloroisopropyl) ether
Bis(2-ethylhexyl) phthalate
Bromodichloromethane
Bromomethane
Butyl benzyl phthalate
Carbazole
Carbon Bisulfide
Chloroacetonitrile
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
Chrysene
Cis-1 ,3-dichloropropene
Crotonaldehyde
Crotoxvphos
CAS No.
7440-33-7
7440-61-1
7440-62-2
7440-64-4
7440-65-5
7440-66-6
7440-67-7
83-32-9.
208-96-8
98-86-2
107-13-1
98-55-5
62-53-3
137-17-7
120127
140-57-8
82-05-3
71-43-2
108-98-5
92-87-5
56-55-3
50-32-8
205-99-2
191-24-2
207-08-9
65-85-0
1689-84-5
100-51-6
91-59-8
92-52-4
92-93-3
111-91-1
111-44-4
108-60-1
117-81-7
75-27-4
74-83-9
85-68-7
86-74-8
75-15-0
107-14-2
108-90-7
75-00-3
67-66-3
' 74-87-3
218-01-9
10061-01-5
4170-30-3
7700-17-6
Method
1620
1620
1620
1620
1620
1620.
1620
1625
1625
1625
1624
„ 1625
1625
1625
1625
1625
1625
1624
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
• 1625
1625
1625
1625
1625
1625
1624
1624
' 1625
1625 .
1624
1624
1624
1624 .
1624
1624
1625
1624
1624
1625
Baseline
Value
1000.00
1000.00
50.00
100.00
5.00
20.00
100.00
10.00'
10.00
-. 10.00.
50.00
10.00
10.00
20.00 '
10.00
50.00
50.00
10.00
10.00
- 50.00^
10.00
10.00
10.00
20.00
10.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
10.00
10.00
50.00
99.00
Unit
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L-
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L,
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
•ug/L
ug/L
ug/L '
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
15-14
-------
Chapter 15 Analytical Methods and Baseline Values Development Document for the CWTPoint Source Catesorv
Pollutant
Di-n-butyl,phthalate
Di-n-octyl phthalate
Di-n-propylnitrosamine
Dibenzo(a,h)anthracene
Dibenzofuran
Dibenzothiophene
Dibromochloromethane
Dibromomethane
Diethyl ether
Diethyl phthalate
Dimethyl phthalate
Dimethyl sulfone
Diphenyl ether
DipHenylamine
Diphenyldisulfide
Ethane, pentachloro-
Ethyl cyanide
Ethyl methacrylate
Ethyl methanesulfonate
Ethylbenzene
Ethylenethrourea-
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloropropene
Hexanoic acid
Indeno(l,2,3-cd)pyrene
lodomethane
Isobutyl alcohol
Isophorone
Isosafrole
Longifolene
m+p Xylene
M-xylene
Malachite Green
Mestranol
Methapyrilene
Methyl methacrylate
Methyl methanesulfonate
Methylene chloride
n,n-dimethylformamide
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
CAS No.
84-74-2
117-84-0
621-64-7
53-70-3
132-64-9
132-65-0
124-48-1
74-95-3
.60-29-7
84-66-2
131-11-3
67-71-0
101-84-8
122-39-4
.. 882-33-7
76-01-7
107-12-0
97-63-2
. 62-50-0
100-41-4
96-45-7
206-44-0
86-73-7
118174-1
87-68-3
77-47-4
67-72-1
1888-71-7
142-62-1
193-39-5
74-88-4
78-83-1 .
78-59-1
120-58-1
475-20-7
179601-23-1
108-38-3
569-64-2
72-33-3 ' •
91r80-5
80-62-6
66-27-3
75-09-2
68-12-2
124-18-5
629-97-0
112-40-3
112-95-8
630-01-3
544-76-3
Method
1625
1625
1625
1625
1625
1625
1624
1624
1624
1625 -
1625
1625
1625
1625
1625
1625
1624
1624
1625
1624
1625
1625
1625"
1625"
1625
1625
1625
1625
1625
1625
1624
1624
1625
1625
1625
1624
1624
1625
1625
1625
1624
1625
1624
1625
1625
1625
1625
1625
1625
1625
Baseline
Value
10.00
10.00
20.00
20.00
10.00
10.00
, 10.00
10.00
50.00
10.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00-
10.00
20.00
10.00
20,00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
10.00
. 10.00
10.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10 00
Unit
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L,.
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L-
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
15-15
-------
Chanter 15 Analytical Methods and Baseline Values Development Document for the CWT Point Source Category
Pollutant
n-Nitrosodi-n-butylamine
n-Nitrosodiethylamine
n-Nitrosodimethylamine
n-Nitrosodiphenylamine
n-Nitrosomethylethylamine
n-Nitrosomethylphenylamine
n-Nitrosomorpholine
n-Nitrosopiperidine
n-Octacosane
n-Octadecane
n-Tetracosahe
n-Tetradecane
n-Triacontane
Naphthalene
Nitrobenzene
o+p Xylene
o-Anisidine - »
o-Cresol
o-Toluidine '
o-Toluidine, 5-chIoro-
o-Xylene
p-Chloroaniline
p-Cresol ~
p-Cymene
p-Dimethylaminoazobenzene
p-Nitroaniline
Pentachlorobenzene
Pentachlorophenol
Pentachlorophenol
Pentamethylbenzene
Perylene
Phenacetin
Phenanthrene
Phenol
Phenol, 2-methyl-4,6-dinitro-
Phenothiazine
Pronamide
Pyrene
Pyridine
Resorcinol
Safrole
Squalene
Styrene
Tetrachlorocatechol
Tetrachloroethene
Tetrachloroguaiacol
Tetrachloromethane
Thianaphthene
Thioacetamide
T"hioxanthe-9-one
CAS No.
924-16-3
55-18-5
62-75-9
86-30-6
10595-95-6
614-00-6
59-89-2
100-75-4
630.-02-4
593-45-3
646-31-1
629-59-4
638-68-6-
91-20-3
98-95-3
136777-61-2
90-04-0
95-48-7
95-53-4"
95-79-4
95-47-6
106-47-8
106-44-5
99-87-6
60-11-7
100-01-6
608-93-5
87-86-5
87-86-5 '
700-12-9
198-55-0
62-44-2
85-01-8
108-95-2
534-52-1
92-84-2
23950-58-5
129-00-0
110-86-1
108-46-3.
94-59-7
7683-64-9
100-42-5
1198-55-6
127-18-4
2539-17-5
, 56-23-5
95-15-8
62-55-5
492-22-8
Method
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625 -
1625
1625 -
1624
1625
1625
1625 i; "
, 1625
' 1624
1625
1625
1625
1625
1625
.1625
1625
85.01
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
, 1625
85.01
1624
85.01
1624
1625
1625
1625
Baseline
Value
10.00
10.00
50.00
20.00
10.00
99.00
10.00
. 10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00-
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
50.00
20.00
50.00
0.80
10.00
10.00
10.00
10.00
10.00
20.00
50.00
10.00
10.00
10.00
50.00
10.00
99.00
10.00
0.80
10.00
0.80
10.00
10.00
20.00
20.00
Unit
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
Ug/L.
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
•ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
15-16
-------
Chapter 15 Analytical Methods and Baseline Values Development Document for the CWTPoint Source Cntp
Pollutant
Toluene
Toluene, 2,4-diamino-
Trans- 1 ,2-dichloroethene
Trans- 1 ,3-dichloropropene
Trans- 1 ,4-dichloro-2-butene
Tribromomethane
Trichloroethene
Trichlorofluoromethane
Trichlorosyringol
Triphenylene
Tripropyleneglycol methyl ether
Vinyl acetate
Vinyl chloride
1 , 1, 1 ;2-tetrachloroethane
1 , 1 , 1 -trichloroethane
1 , 1 ,2,2-tetrachloroethane
1 , 1 ,2-trichlorbethane
1 , 1 -dichloroethane
1 ; 1 -dichloroethene •
1 ,2,3-trichlorobenzene
•1,2,3-trichloropropane
1 ,2,3-trimethoxybenzene
1,2,4,5-tetrachlorobenzene
1 ,2,4-trichlorobenzene
1 ,2-dibromo-3-chloropropane
1 ,2-dibromoethane
1 ,2-dichlorobenzene
1 ,2-dichloroethane
1 ,2-dichloropropane
1 ,2-diphenylhydrazine
1 ,2:3,4-diepoxybutane
1,3,5-trithiane
1,3-butadiene, 2-chloro
1 ,3-dichloro-2-propanol
1,3-dichlorobenzene
1 ,3-dichloropropane
1 ,4-dichlorobenzene
1 ,4-dinitrobenzene
1,4-dioxane
1 ,4-naphthoquinone
1 ,5-naphthalenediamine
1 -bromo-2-chlorobenzene
1 -bromo-3-chlorobenzene
1 -chloro-3-nitrobenzene
1 -methylfluorene
1 -methylphenanthrene
1 -naphthylamine
1 -phenvlnaphthalene
CAS No.
108-88-3
95-80-7
156-60-5
10061-02-6
110-57-6
75-25-2
79-01-6
75-69.4
2539-26-6.
217-59-4 .
20324-33-8
108-05-4
75-01-4
630-20-6
71-55-6
79-34-5
79-00-5
75-34-3
75-35-4
87-61-6
96-18-4 •
634-36-6.
95-94-3
120-82-1
96-12-8-
106-93-4
95-50-1
107-06-2
78-87-5
122-66-7
1464-53-5
291-21-4
126-99-8
96-23-1
541-73-1
142-28-9
106-46-7 ,
100-25-4
123-91-1
130-15-4
2243-62-1
694-80-4
. 108-37-2
121-73-3
1730-37-6
832-69-9
134-32-7
605-02-7
Method
1624
1625
1624
1624
1624
1624
1624
1624
85!01
1625
1625
- 1624
1624
1624
1624 :
1624
1624
1624
1624
1625
1624
1625
1625 .
1625
1625 •
1624
1625
1624
1624
1625
1625
1625
1624-
1625
1625
1624
1625
1625
1624
1625
1625
1625
1625
1625
1625
1625
1625
1625
Baseline
w i Unit
10.00 ug/L
99.00 ug/L
10.00 ug/L
10.00 ug/L
50.00 ug/L
10.00 ug/L
10.00 ug/L
10.00 ug/L
0.80 ug/L
10.00 ug/L
99.00 ug/L
50.00 ug/L
10.00 ug/L
10.00 ug/L
10.00 ug/L
10.00 ug/L
.10.00 ug/L
10.00 ug/L
10.00- ug/L
LO.OO ug/L
10.00 ug/L
10.00 ug/L
10.00 ug/L
10.00 ug/L
20.00 ug/L
10.00 ug/L
10.00 ug/L
10.00 ug/L
10.00 ug/L
20.00 ug/L
20.00 ug/L
50.00 ug/L
10.00 ug/L
10.00 ug/L
10.00. ug/L
10.00 ug/L
10.00 ug/L
20.00 ug/L
10.00 ug/L
99.00 ug/L
99.00 ug/L
10.00 ug/L
10.00 ug/L
50.00 ug/L
10.00 . ug/L
10.00 ug/L
10.00 ug/L
15-17
-------
Chanter 15 Analytical Methods and Baseline Values Development Document for the CWT Point Source Category
Pollutant
2,3,4,6-tetrachlorophenol
2,3,6-trichlorophenol
2,3-benzofluorene
2,3-dichloroaniline
2,3-dichloronitrobenzene
2,4,5-trichlorophenol
2,4,6-trichlorophenol
2,4-dichlorophenol
2,4-dimethylphenol
2,4-dinitrophenol
2,4-dinitrotoluene
2,6-di-tert-butyl-p-benzoquinon&,
2,6-dichloro-4-nitroaniline '
2,6-dichlorophenol
2,6-dinitrotoluene
2-(methylthio)benzothiazole-
2-butanone
2-chloroethylvinyl ether
2-chloronaphthalene
2-chlorophenol
2-hexanone
2-isopropylnaphthalene
2-methylbenzothioazole
2-methylnaphthalene
2-nitroaniline
2-nitrophenol
2-phenylnaphthalene
2-picoline
2-propanone
2-propen-l-ol
2-propenal
2-propenenitrile, 2-methyl-
2-syringaldehyde
3,3'-dichlorobenzidine
3,3-dimethoxybenzidine
3,4,5-trichlorocatechol
3,4,5-trichloroguaiacol
3,4,6-trichloroguaiacol
3,4-dichlorophenol
3,5-dichlorocatechol
3,5-dichlorophenol
3,6-dichlorocatechol
3,6-dimethylphenanthrene
3-chloroproDene
CAS No.
58-90-2
933-75-5
243-17-4 ,
608-27-5
3209-22-1
95-95-4
88-06-2
120-83-2
105-67-9
51-28-5
121-14-2
71SL-22=2_
99-30-9
87-65-6...
606-20-2
615-22-5.
78-93-3
110-75-8
91-58-7
95-57-8
591-78-6
2027-17-0
120-75-2
91-57-6
88-74-4
88-75-5
612-94-2
109-06-8
67-64-1
107-18-6
107-02-8
126-98-7
134-96-3
91-94-1
119-90-4
56961-20-7
57057-83-7
60712-44-9
95-77-2
13673-92-2
591-35-5
- 3938-16-7 .
1576-67-6
107-05-1
Method
1625
85.01
1625
85.01
• 1625
1625
1625
1625
85.01
1625
85.01
1625
85.01 "
1625
1625
1625
J625
1625
1.625 :
85.01. .
1625
...1625
1624
.1624--
1625..
1625
1624
1625
1625
1625
1625
1625
1625
1625
1624
1624
1624
1624
85.01
1625
1625
85.01
85.01
85.01
85.01
85.01
85.01
85.01
1625
1624
Baseline
Value
20.00
0.80
10.00
0.80
. 10.00
10.00
, 50.00
10.00
0.80
10.00
0.80
10.00
0.80
10.00
50.00
10.00-
99.00
99.00
10.00
0.80.,
10.00
• 10.00
50.00-
10.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
50.00
10.00
50.00
10,00
0.80
50.00
50.00
0.80
0.80
0.80
0.80
0.80
0.80
0.80
10.00
10.00
Unit
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L,.,
ug/L
ug/L
ug/L-
ug/L- -
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L .
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ua;/L
15-18
-------
Chapter 15 'Analytical Methods and Baseline Values Development Document for the CWT Point Source Category
Pollutant
CAS No.
Method
Baseline
Value
Unit
3 -methylcholanthrene
3-nitroaniline
4,4'-methylenebis(2-chloroaniline)
4,5,6-trichloroguaiacol
4,5-dichlorocatechol
• 4,5-dichloroguaiacol
4,5-methylene phenanthrene
4,6-dichloroguaiacol
4-aminobiphenyl
4-bromophenyl phenyl ether
4-chloro-2^nitroaniline
4-chloro-3-methylphenol
4-chloroguaiacol
4-chlorophenol •
4-chlorophenylphenyl ether
4-methyl-2-pentanone
4-nitrophenol
5,6-dichlorovanillin
5-chloroguaiacol
5-nitro-o-toluidine
6-chlorovanillin
7. 1 2-dimethvIbenz('a<)anthracene
56-49-5
99-09-2
101-14-4
2668-24-8
3428-24-8
2460-49-3
203-64-5
16766-31-7
92-67-1
10.U5.S--3-
89-63-4
59-50-7
16766-30-6
106-48-9
7005-72-3
108-10-1
100-02-7
18268-69-4
3743-23-5
99-55-8
' 18268-76:3
57.97-6 .--•
1625
1625
1625
85.01
85.01
85.01
1625
85.01
1625
1625
1625
1625
85.01
.85.01
1625
1624
1625
85.01-
- 85.01
1625
85.01
1625
10.00
20.00
20.00
0.80
0.80
0.80
10.00
0.80
10.00
10.00
20.00
10.00
160.00
240.00
10.00
50.00
50.00
0.80-
160.00
10.00
0.80
10.00
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L,
ug/L
ug/L
ug/L
ug/L
ug/L—
ug/L
ug/L
ug/L
ug/L
15-19
-------
-------
LIST OF DEFINITIONS
Administrator - The Administrator of the U.S. Environmental Protection Agency.
Agency - The U.S. Environmental Protection Agency.
Average Monthly Discharge Limitation - The highest allowable average of "daily discharges" over
a calendar month, calculated as the sum of all "daily discharges" measured during the calendar
month divided by the number of "daily discharges" measured during the month.
B
;^ The;b"est"available'technology;economically achievable, applicable to effluent limitations to
be achieved by July 1, 1984, for industrial discharges to surface waters, as defined by Sec.
304(b)(2)(B) of the CWA. . .... "" ......
BCT - The best conventional pollutant controltechnology, applicable to discharges of conventional^
pollutants from existing industrial point sources, as defined by Sec. 304(b)(4) of the CWA. .
BPT - The best practicable control technology currently available, applicable to effluent limitations
to be achieved by July 1, 1977, for industrial discharges to surface waters, as defined by Sec.
304(b)(l) of the CWA.
Centralized Waste Treatment Facility - Any facility that treats and/or recovers or recycles any
hazardous or non-hazardous industrial waste, hazardous or non-hazardous industrial wastewater,
and/or used material from off-site. "CWT facility" includes both a facility that treats waste received
from off-site exclusively, as well as a facility that treats wastes generated on-site and waste received
from off-site. For example, an organic chemical manufacturing plant may, in certain circumstances,
be a CWT facility if it treats industrial wastes received from off-site as well as industrial waste
generated at the organic chemical manufacturing plant. CWT facilities include re-refiners and may
be owned by the federal government.
Centralized Waste Treatment Wastewater - Wastewater generated as a result of CWT activities.
CWT wastewater sources may include, but are not limited to the following: liquid waste receipts,
solubilizationwater, used oil emulsion-breaking wastewater, tanker truck/drum/roll-off box washes,
equipment washes, air pollution control scrubber blow-down, laboratory-derived wastewater, on-site
industrial waste combustor wastewaters, on-site landfill wastewaters, and cpntaminated storm water.
List of Definitions-1
-------
List of Definitions
Development Document for the CWTPoint Source Category
Clean Water Act (CWA) - The Federal Water Pollution Control ActAmendments of 1972 (33
U.S.C. Section 1251 etseq.1. as amended by the Clean Water Act of '1977 (Pub. L. 95-217), and the
Water Quality Act of 1987 (Pub. L. 100-4).
Clean Water Act (CWA) Section 308 Questionnaire - A questionnaire sent to facilities under the
authority of Section 308 of the CWA, which requests information to be used in the development of
national effluent guidelines and standards.
Commercial Facility - A CWT facility that accepts off-site generated wastes, wastewaters, or used
material from other facilities not under the same ownership as this facility. Commercial operations
are usually made available for a fee or other remuneration.
.Contaminated Storm Water - Storm water which comes in direct contact with the waste or waste
handling and treatment areas.
Conventional Pollutants - Constituents of wastewater as determined by Sec. 304(a)(4) of the CWA,
including, but not limited to, pollutants classified as biochemical oxygen demand, total suspended
solids, oil and grease, fecal coliform, and pHL _.
CWT - Centralized Waste Treatment.
D.
Daily Discharge - The discharge of a pollutant measured during any calendar day or any 24-hour
period that reasonably represents a calendar day.
Detailed Monitoring Questionnaire (DMQ) - Questionnaires sent to collect monitoring data from
20 selected CWT facilities based on responses to the Section 308 Questionnaire.
Direct Discharger - A facility that discharges or may discharge treated or untreated wastewaters
into waters of the United States.
E
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)).
Existing Source - Any facility from which there is or may be a discharge of pollutants, the
construction of which is commenced after the promulgation of standards of performance under Sec.
306 of the CWA.
List of Definitions-2
-------
List of Definitions
Development Document for the CWT Point Source Category
Facility - All contiguous property owned, operated, leased or under the control of the same person
or entity
Fuel Blending - The process of mixing waste, wastewater, or used material for the purpose of
regenerating a fuel for re-use.
EL
Hazardous Waste -Any-waste, including wastewater, defined as hazardous under RCRA, TSCA,
or any state law.
High Temperature Metals Recovery (HTMR) - A metals recovery process in which solid forms
of metal containing materials are processed with a heat-based pyrometallurgical technology to
produce a remelt alloy which can then be sold~as feed'materiaMn the production'of metals.
In-scope - Facilities and/or wastewaters that EPA proposes to be subject to this-guideline.
Indirect Discharger - A facility that discharges or may discharge wastewaters into a publicly-owned
treatment works.
Instrument Detection Limit (TDL) - The smallest signal above background noise that an instrument
can detect reliably.
Intercompany Transfer - Transfer to facilities that treat and/or recycle/recover waste, wastewater,
and/or used material generated by off-site facilities not under the same corporate ownership. These
facilities are also referred to as "commercial" CWTs.
Intracompany Transfer - Transfer to facilities that treat and/or recycle/recover waste, wastewater,
and/or used material generated by off-site facilities under the same corporate ownership. These
facilities are also referred to as "non-commercial" CWTs.
LTA - Long-Term Average. For purposes of the effluent guidelines, average pollutant levels
achieved over a period of time by a facility, sub category, or technology option. LTAs were used in
developing the limitations and standards in today's proposed regulation.
List of Definitions-3
-------
List of Definitions
Development Document for the CWT Point Source Category
M
Marine-generated Waste - Waste, wastewater, and/or used material generated as part of the normal
maintenance and operation of a ship, boat, or barge operating on inland, coastal, or open waters, or
while berthed.
Metal-bearing Wastes - Wastes and/or used materials that contain significant quantities of metal
pollutants, but not significant quantities of oil and grease (generally less than 100. mg/L), from
manufacturing or processing facilities or other commercial operations. These wastes include, but
are not limited to, spent electroplating_baths and sludges, metal finishing rinse water and sludges,
chromate wastes, air pollution control blow down water and sludges, Spent anodizing solutions,
incineration air pollution control wastewaters, waste liquid mercury, cyanide containing wastes
greater than 136 mg/L, and waste acids and bases with or, in the case of acids and bases only,
without metals.
Minimum Level - The lowest level at which the entire analytical system must give a recognizable
signals and an acceptable calibration point for the analyte.
Mixed Commercial/Non-commercial Facility - Facilities that treat and/or recycle/recover waste,
wastewater, and/or used material generated by off-site, facilities both under the same corporate
ownership and different corporate ownership.
Multiple Wastestream CWT Facility - A CWT facility which accepts waste in more than one
CWT subcategory (metals, oils, or organics) and combines any portion of these different subcategory
wastes at any point prior to the compliance discharge, sampling location.
N
National Pollutant Discharge Elimination System (NPDES) Permit - A permit to discharge
wastewater into waters of the United States issued under the National Pollutant Discharge
Elimination system, authorized by Section 402 of the CWA.
New Source - Any facility from which there is or may be a discharge of pollutants, the construction
of which is commenced after the proposal of regulations prescribing a standard of performance under
section 306 of the Act and 403.3(k).
Nominal Quantitation Limit - The smallest quantity of an analyte that can be measured reliably
with a particular analytical method.
Non-commercial Facility - Facilities that accept waste from off-site for treatment and/or recovery
from generating facilities under the same corporate ownership as the CWT facility.
List of Definitions-4
-------
List of Definitions
Development Document for the CWTPoint Source Category
Non-contaminated Stormwater - Storm water which does not come into direct contact with the
waste or waste handling and treatment areas.
Non-conventional Pollutants - Pollutants that are neither conventional pollutants nor priority
pollutants listed at 40 CFR Section 401.
Non-detect Value - the analyte is below the level of detection that can be reliably measured by the
analytical method. This is also known, in statistical terms, as left-censoring.
Non-water Quality Environmental Impact - Deleterious aspects of control and treatment
technologies applicable to point source category-wastes,.including,,buLnot limited to air pollution,
noise, radiation, sludge and solid waste generation, and energy used.
NSPS - New Sources'Performance Standards, applicable to industrial facilities whose construction
is begun after the publication of the proposed regulations, as defined by Sec. 306 of the CWA.
o
OCPSF - Organic chemicals, plastics, and synthetic fibers manufacturing point source category (40
CFRPart414).
Off-site - Outside the boundaries of a facility.
Oily Absorbent Recycling - The process of recycling oil-soaked or contaminated disposable rags,
paper, or pads for the purpose of regenerating a fuel for reuse.
Oily Wastes - Wastes and/or used materials that contain oil and grease (generally at or in excess of
100 mg/L) from manufacturing or processing facilities or other commercial operations. These
wastes include, but are not limited to, used oils, oil-water emulsions or mixtures, lubricants, coolants,
contaminated groundwater clean-up from petroleum sources, used petroleum products, oil spill
clean-up, bilge water, rinse/wash waters from petroleum sources, interceptor wastes,, off-
specification fuels, underground storage remediation waste, and tank clean out from petroleum or
oily sources. -
Oligopoly - A market structure with few competitors, in which each producer is aware of his
competitors' actions and has a significant influence on market price and quantity.
On Site - The same or geographically contiguous property, which may be divided by a public or
private right-of-way, provided the entrance and exit between the properties is at a crossroads
intersection, and access is by crossing as opposed to going along the right-of-way. Non-contiguous
properties owned by the same company or locality but connected by a right-of-way, which it
controls, and to which the public does not have access, is also considered on-site property.
List of Definitions-5
-------
List of Definitions
Development Document for the CWTPoint Source Category
Organic-bearing Wastes - Wastes and/or used materials that contain organic pollutants, but not a
significant quantity of oil and grease (generally less than 100 mg/L) from manufacturing or
processing facilities or other commercial operations. These wastes include, but are not limited to,
landfill leachate, contaminated ground-water clean-up from non-petroleum sources, solvent-bearing
wastes, off-specification organic product, still bottoms, waste byproduct glycols, wastewater from
paint washes, wastewater from adhesives and/or epoxies formulation, wastewater from chemical
product operations, and tank clean-out from organic, non-petroleum sources.
Outfall - The mouth of conduit drains and other conduits from which a facility effluent discharges
into receiving waters.
Out-of-scope - Out-of-scope facilities are facilities which only perform centralized waste treatment
activities which EPA has not determined to be subject to provisions of this guideline or facilities that
do not accept off-site waste for treatment.
E
Pipeline - "Pipeline" means an open or closed conduit used for the conveyance of material. A
pipeline includes a channel, pipe, tube, trench, ditch or fixed delivery system.
Pass Through - A pollutant is determined to "pass through" a POTW when the average percentage
removed by an efficiently operated POTW is less than the average percentage removed by the
industry's direct dischargers that are using well-defined, well-operated BAT technology.
Point Source - Any discernable, confined, and discrete conveyance from which pollutants axe or
may be discharged. .
Pollutants of Concern (POCs) - Pollutants commonly found in centralized waste treatment
wastewaters. For the purposes of this guideline, a POC is a pollutant that is detected at or above
a treatable level in influent wastewater samples from centralized waste treatment facilities.
Additionally, a CWT POC must be present in at least ten percent of the influent wastewater samples.
Priority Pollutant - One hundred twenty-six compounds that are a subset of the 65 toxic pollutants
and classes of pollutants outlined in Section 307 of the CWA. The priority pollutants are specified
in the NRDC settlement agreement (Natural Resources Defense Council et al v. Train, 8 E.R.C. 2120
[D.D.C. 1976], modified 12 E.R.C. 1833 [D.D.C. 1979]).
Product Stewardship - A manufacturer's treatment or recovery of its own unused products, shipping
and storage containers with product residues, off-specification products, and does not include spent
or used materials from use of its products.
List of Definitions-6
-------
List of Definitions
Development Document for the CWTPoint Source Cafp&nrv
PSES - Pretreatment standards for existing sources of indirect discharges, under Sec. 307(b) of the
GWA.
PSNS - Pretreatment standards for new sources .of indirect discharges, under Sec. 307(b) of the
CWA.
Publicly Owned Treatment Works (POTW) - Any device or system, owned by a state or
municipality, used in the treatment (including recycling and reclamation) of municipal sewage or
industrial wastes of a liquid nature that is owned by a state or municipality. This includes sewers,
pipes, or other conveyances only if they convey wastewater to a POTW providing treatment (40 CFR
122.2).
R
RCRA - The Resource Conservation and Recovery Act of 1976 (RCRA) (42 U.S.C. Section 6901
et seq-X which regulates-the generation^ treatment, storage, disposal, or recycling of solid and
hazardous wastes.
Re-refining - Distillation, hydrotreating, and/or other treatment employing acid, caustic, solvent,
clay and/or chemicals of used oil in order to produce high quality base stock for lubricants or other
petroleum products.
Recovery - The recycling or processing of a waste, wastewater, or used material such that the
material, or a portion thereof, may be reused or converted to a raw material, intermediate, or product.
S - ' :
SIC - Standard Industrial Classification (SIC). A numerical categorization system used by the U.S.
Department of Commerce to catalogue economic activity. SIC codes refer to the products, or group
of products, produced or distributed, or to services rendered by an operating establishment. SIC
codes are used to group establishments by the economic activities in which they are engaged. SIC
codes often denote a facility's primary, secondary, tertiary, etc. economic activities.
Sample-specific Quantitation Limit - The smallest quantity in the experimental calibration range
that may be measured reliably in any given sample •
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) which is being used to characterize the CWT industry.
Solidification - The addition of sorbents to convert liquid or semi-liquid waste to a solid by means
of adsorption, absorption or both. The process is usually accompanied by stabilization.
List of Definitions-7
-------
List of Definitions
Development Document for the CWTPoint Source Category
Solvent Recovery - Fuel blending operations and the recycling of spent solvents through separation
of solvent mixtures in distillation columns. Solvent recovery may require an additional, pretreatment
step prior to distillation.
Stabilization - A waste process that decreases the mobility of waste constituents by means of a
chemical reaction. For the purpose of this rule, chemical precipitation is not a technique for
stabilization.
Subchapter N - Refers to Subchapter N of Chapter I of Title 40 of the Federal Regulations: This
includes, but is riot limited to, the industrial categorical standards included in 40.CFR Parts 405
through 471.
Treatment - Any method, technique, or process designed to change the physical, chemical .or
biological character or composition of any metal-bearing, oily, or organic-waste so'as to neutralize--
such wastes, to render,sucLwastes amenable=to-discharge or to-recover-energy-or-recover-metal, oil;-
or organic content from the wastes.
Used Oil Filter Recycling - The process of crushing and draining of used oil filters of entrained oil
and/or shredding and separation of used oil filters.
E
Variability Factor - Used in calculating a limitation (or standard) to allow for reasonable variation
in pollutant concentrations when processed through extensive and well designed treatment systems.
Variability factors assure that normal fluctuations in a facility's treatment are accounted for in .the
limitations. By accounting for these reasonable excursions above, the long-term average, EPA's use
of variability factors results in limitations that are generally well above the actual long-term
averages.
w.
Waste - Includes aqueous, non-aqueous, and solid waste, wastewater, and/or used material.
Waste Receipt - Wastes, wastewater or used material received for treatment and/or recovery. Waste
receipts can be liquids or solids.
List of Definitions-8
-------
List of Definitions
Development Document for the CWTPoint Source Cateeorv
Zero or Alternative Discharge - No discharge of pollutants to waters of the United States or to a
POTW. Also included in this definition are disposal of pollutants by way of evaporation, deep-well
injection, off-site transfer, and land application.
List of Definitions-9
-------
-------
LIST OF ACRONYMS
A
AMSA: Association of Municipal Sewage
Authorities
API: American Petroleum Institute
JB
BAT: Best Available Technology
(Economically Achievable)
BCTf Best C6riventionar(P611utant Control)
Technology
BDAT: Best Demonstrated Available
(Treatment) Technology •
BOD: Biological Oxygen Demand
BPJ: Best Professional Judgement —
BPT: Best Practicable (Control)
Technology (Currently Available)
c
CBI:
Confidential Business Information
CERCLA: Comprehensive Environmental
Response, Compensation, and
Liability Act
CMA: Chemical Manufacturers Association
COD: Chemical Oxygen Demand
CWA: Clean Water Act
CWT: Centralized Waste Treatment
D
DAF: Dissolved Air Flotation
DL: Detection Limit
DMQ: Detailed Monitoring Questionnaire
E ' ,
BAD: Engineering and Analysis Division
ELG: Effluent Limitations Guidelines
ENR: Engineering-News Record-
EPA: Environmental-Protection-Agency
F
F/M:_ Eood-to-microorganism,(ratio)-
a
GAC: Granular Activated Carbon
GC/ECD: Gas Chromatography/Electron
Capture Detector
GFAA: Graphite Furnace Atomic Absorption
H
HAP: Hazardous Air Pollutant
HEM: Hexane-Extractable Material
HSWA: Hazardous and Solid Waste
Amendments
HTMR: High •Temperature Metals Recovery
ICP: Inductively Coupled Plasma (Atomic
Emission Spectroscopy)
IDL: Instrument Detection Limit
List of Acronyms-1 , •
-------
i^t fvf Afronvms
Development Document for the CWT Point Source Category
LDR: Land Disposal Restriction
LTA: Long-term Average
' MACT: Maximum Achievable Control- __
Technology
MADL: Minimum Analytical Detection Limit
MGD: Million Gallons per Day
MIP: Monitoring-u>place-
ML: Minimum Level
MLSS: Mixed Liquor Suspended Solids
MNC: Mean Non-censored (Value)
tf
ND: Non-detected
NO A: Notice of (Data) Availability
NORA: National Oil Recyclers Association
NPDES: National Pollutant Discharge
Elimination System
NRDC: Natural Resources Defense Council
NRMRL: National Risk Management
Research Laboratory; formerly
RREL
•NSPS: New Source Performance Standards
NSWMA: National Solid Waste Management
Association
o
O&M: Operation and Maintenance
OCPSF: Organic Chemicals, Plastics, and
Synthetic Fibers
OMB: Office of Management and Budget
PAC: Powdered Activated Carbon
POC: Pollutant of Concern
POTW: Publicly Owned Treatment Works
PSES : Pretreatment Standards for Existing
Sources
PSNS: ' Pretreatment Standards for New
Sources
a
QC:
R
Quality Control
RCRA: Resource Conservation and Recovery
Act
RO: Reverse Osmosis
RREL: Risk Reduction Engineering
Laboratory; now known as NRMRL
s
SBA: Small Business Administration
SBR: Sequencing Batch Reactor
SBREFA: Small Business Regulatory
Flexibility Act
SGT-HEM: Silica Gel-Treated Hexane-
Extractable Material
SIC: Standard Industrial Code
SRT: Sludge Retention Time
List of Acronyms-2
-------
List of Acronyms
Development Document for the CWTPoint Source Category
TDS:
TEC:
TOC:
TSDF:
TSS:
TWF:
u
UF:
UIC:
UTS:
V
VOC:
w
\VTI:
Total Dissolved Solids
Transportation Equipment Cleaning
Total Organic Carbon
Treatment, Storage, and Disposal
Facility
Total Suspended Solids
Toxic Weighting Factor
Ultrafiltration
Underground Injection-Control
Universal Treatment Standards
Volatile Organic Compound
Waste Treatment Industry
List of Acronyms-3
-------
-------
INDEX
Activated Sludge: 7-15, 8-2, 8-43, 8-45, 8-47, 8-49, 8-50, 8-51, 8-54, 8-57, 14-25
Alternate Discharge Methods: 8-58
Analytical Costs: 6-1,7-31,11-31
Analytical Methods: 2-5, 6-1, 7-24,7-25,10-2, 10-4,10-6, 10-8, 11-32, 12-14,15-1, 15-3 15-5
15-9
Applicability - Federally-Owned Facilities: 3-10
Food Processing Wastes: 3-25
Grease Trap/Interceptor Wastes: 3-24
High Temperature Metals Recovery: 3-21
Incineration Activities: 3-17
Landfill Wastewaters: 3-16 -
Manufacturing Facilities: 3-T
Marine Generated'Wastes: 3-11
Pipeline Transfers (FixedDelivery Systems): 3*6—
ProductStewardship: 3-8
Publicly Owned Treatment Works (POTWs): 3-12
Re-refining: 3-23
Recovery and Recycling Operations: 3-19
Sanitary Wastes and/or Chemical Toilet Wastes: 3-25
Scrap Metal Processors and Auto Salvage Operations: 3-18
Silver Recovery Operations from Used Photographic & X-Ray Materials: 3-20
Solids, Soils, and Sludges: 3-17
Solvent Recycling/Fuel Blending: 3-22
Stabilization: 3-18
Thermal Drying of POTWBiosolids: 3-15
Transfer Stations: 3-18
Transporters and/or Transportation Equipment Cleaners: 3-15
Treatability, Research and Development, and Analytical Studies: 3-25
Used Oil Filter and Oily Absorbent Recycling: 3-23
Waste, Waste-water, or Used Material Re-use: 3-19
Attached Growth Biological Treatment System: 8-45
B
BAT: Executive Summary-2, Executive Summary-3, 1,2, 1-3, 1-5, 1-7, 7-13 7-14 7-20 7-25 7-
27,9-1, 9-12,9-13,9-14,9-15,9-16,10-5,10-36,10-45,11-13,11-43,12-2,12-4,12-5,12-
Index-1
-------
Develovment Document for the CWTPoint Source Category
8, 12-13, 12-28, 12-29, 12-30, 12-31, 13-2, 13-3, 13-5, 14-1, 14-24, 14-25
BCT: Executive Summary-2, Executive Summaiy-3,1-2,1-5,1-7,9-1,9-12,9-13,10-5,10-6, 10-
36,10-42,10-45,11-43,13-5
Belt Pressure Filtration: 8-51,8-54,8-55
Best Management Practices: 8-1, 8-2,13-1
Biological Treatment: Executive Summary-2, 1-6, 1-7, 2-11, 2-12, 3-14, 5-4, 7-14, 8-1, 8-2,
8-5, 8-10, 8-13,8-24, 8-25, 8-33, 8-41, 8-43, 8-45, 8-47/8-51, 8-54, 8-
57, 9-2, 9-6,9-7, 9-9, 9-10,10-42,11-23,11-26, 12-23,12-24, 12-25,
12-26,13-3,14-4,14-16,14-18,14-25,14-27..
Biotowers: 8-43, 8-45, 8-47, 8-48
BOD: 2-7,6-5,11-32,15-4,15-12 -;-••
Boron: 2-8,6-5, 6-7, 6-10, 6-28,7-1,7-26,12-4,12-20,12-25,-12-28,12-33,12-35, 15-6,15-12
BPT: Executive Summary-2, Executive Summary-3, Executive Summary-4, Executive Summary-
4, 1-1, 1-2, 1-5, 1-6,1^7, 7-13, 7-31, 9-1, 9-2, 9-3, 9^4.,.9-5, 9-6, 9-7, 9-8, 9-9, 9-10, 9-11,
9-12,9-13,9-14,9-15, 9-16,10-5, 10-6,10-36, 10-42,10-45, 10-46,11-43, 12-2,12-8, 12-
28, 12-29, 12-30,12-3T,'13-2; 13-3; 13-5; F4-24
Capital Costs: 11-1,11-2,11-5,11-6,11-7, 11-8,11-9,11-10, 11-12,11-13, 11-14,11-17,11-18,
11-19,11-20,11-21,11-21,11-22,11-23,11-25,11-26,11-27,11-28,11-30,11-35,
11-39,11-43,11-44
Carbon Adsorption: 1-6,2-11,2-12,5-4, 8-2, 8-33,8-34, 8-35,9-6,9-7,9-9,9-12,9-13,12-12,
12-13,12-23,12-25,12-26
Chemical Precipitation: Executive Summary-2, Executive Summary-3,2-15,5-3,7-11,7-25, 8-2,
8-5, 8-8, 8-10, 8-13,8-19, 8-20, 8-21, 8-22, 8-24, 8-33, 8-51, 9-2,9-3,9-
4,9-5,9-6,10-3,11-4,11-5,11-6,11-7,11-8,11-9,11-10,11-1-1,11-12,
11-13,11-14,11-15,11-16,11-17,11-20,11-23,11-27,11-28,11-29,11-
34, 11-35, 11-36, 11-37, 12-6,12-8, 12-12, 12-13, 13-1, 13-3, 14-3, 14-
18, 14-22
Chromium Reduction: 8-2,8-15,8-16,8-17,8-19
Clarification: Executive Summary-2, Executive Summary-3,1-7,2-3,2-11,3-1,3-11,3-13,3-16,
Index-2
-------
Index
Development Document for the CWTPoint Source Catesrorv
3-17,3-18,3-21,4-1,8-5,8-7,8-10,8-12,8-13,8-19,8-33,8-51,9-3,9-4,9-13,9-
15, 10-3,10-15,11-4,11-7,11-8,11-10,11-12,11-13,11-14,11-15,11-16, 11-17,
11-20, 11-27, 11-28, 11-29, 11-34,11-35; 11-36, 11-37
Coagulation: 2-12, 8-5, 8-7, 8-8, 8-15, 8-19, 8-21
Conventional Pollutants: Executive Summary-2, Executive Summary-3, 1-2, 6-27, 6-28, 7-13,
7-20, 9-2, 9-10, 9-12, 9-16, 10-6
Cyanide: Executive Sununary-2, Executive Summary-3, Executive Summary-4, Executive
Summary-6, Executive Summary-8, Executive Summary-10, Executive Summary-12,
Executive Summary-14, Executive Summary-16, Executive Summary-18,1-6,1-7,2-7,
2-9,2-11,4-4, 5-3, 6-2, 6-5, 6-7, 6-10, 6-15, 6^-20, 6-25, 6-27, 7-4, 7-14, 7-18, 7-21, 7-
22,7-24,7-26,7-3,1,7-33,8-16,9-3,9-4,9-5,,9-6,10,3,10-7,10-31,11-21,11-31,12-4, .
12-20,12-25,12-28,12-33,12-35,12-38,12-35,13-6,14-3,14^5,14-LO,J4=L1,JL4J2,..
14-14-,-14-15, 14-24,15-3, 15-4, 15-8,-15-10, 15-12, 15-15
Cyanide Destruction: 2-11, 8-2, 8-16, 8-18, 8-19, 9-5, 11-4, 11-21,11-22, 14-24
D .--- -- . ' . •
Dissolved Air Flotation: Executive Summary-2, Executive Summary3,1-6,1-7, 2-11, 2-12, 5-3,
8-2, 8-13, 8-14, 8-51, 9-6, 9-8, 9-9, 11-4, 11-22, 11-23, 11-25, 11-38,
11-39, 11-40, 11-41, 13-1, 13-3, 13-5, 14-18, 14-22, 14-23
as "DAF": 5-3, 8-13, 8-15, 9-8, 10-5, 11-23, 11-24, 11-25, 11-38, 12-13, 14-11
E
Electrolytic Recovery: 8-36, 8-38
Emulsion Breaking/Gravity Separation: Executive Summary-2, Executive Summary-3, 1-7,3-
1, 8-10, 9-6, 9-7, 9-8, 9-9, 10-3, 11-25, 11-38, 12-9,
12-10, 12-13, 12-14, 12-16, 12-17, 12-18, 12-20, 12-
-22, 14-18, 14-22
Equalization: Executive Summary-2,1-6,1-7,5-4,8-2,8-3,8-4,8-5,8-19,8-25,8-26,8-43, 8-45,
8-51,9-9,9-10,11-4,11-5,11-17,11-18,11-19,11-26,13-1
Filter Cake Disposal: 8-57,11-4,11-5,11-7,11-8,11-10,11-14,11-15,11-28,11-29,11-30,11-36
Index-3
-------
Index
Development Document for the CWT Point Source Category
Filtration- Belt Pressure Filtration: 8-51,8-54,8-55
Lancy Filtration: 8-30, 8-32
Liquid Filtration: 8-19, 11-4, 11-5, 11-7, 11-13, 11-14, 11-15, 11-16, 11-17
Membrane Filtration: 8-28
Multimedia Filtration: 1-6,2-11,8-25,8-26,9-5,9-9,11-12,11-20,11-34, 11-36,
11-37, 12-2, 12-12, 12-23, 12-24, 12-25, 12-26, 14-22
Plate and Frame Filtration: 8-26, 11-13, 11-14, 11-27
Reverse Osmosis: -1-6,2-11,8-2,8-28,8-30,8-31,9-6,9-7
Sand Filtration: Executive Summary-2,1-7, 8-2, 8-24,8-25, 8-26, 8-33,9-3,9-
4, 12-13, 12-23
Sludge Filtration: 2-11,11-4,11-5,11-7,11-8,11-10,11-15,11-23,11-27, 11-28,,,
H-29H-l-30rl-l-34, 11-3.5, 11-36, 11-37
• Ultrafiltration: 1-6, 2-11, 8-2, 8-28, 8-29, 9-6, 9-7, 12-13
Vacuum Filtration: 8-2,8-51,8-54,8-56,8-57
Fixed Delivery-Systems^ 2-3
Flocculation: 2-12, 8-2, 8-5, 8-7, 8-8, 8-10, 8-19, •8-2r,-8-24r8-54,-H-Brl-l-14rl 1-15
Flocculation/Coagulation: 8-5
Gravity Separation: see Emulsion Breaking/Gravity Separation
Secondary Gravity Separation: Executive Summary-2, 1-7, 9-6, 9-8, 9-9,
9-15, 11-4, 11-22, 11-23, 11-38, 11-39,
H_40, 11-41
H.
Hexane Extractable Material: 2-7, 6-1, 7-31, 10-3, 10^7, 12-34, 12-37, 15-5, 15-12
as "HEM": 6-1, 7-13, 7-31, 7-32, 10-3, 10-4, 10-8, 12-6, 12-7, 12-8, 12-10,
12-20, 12-28,12-33, 12-34, 12-35, 12-37 15-4, 15-5, 15-12
Ion Exchange: 8-2, 8-35, 8-36, 8-37
Index-4
-------
r
Index
Development Document for the CWT Point Source Category
Land Costs: 11-1, 11-3, 11-18, 11-32, 11-33
Land Disposal Regulations (as LDR): 1-4,1-5
Land Requirements: 11-1,11-3, Ilr6,11-8,11-9,11-12,11-13,11-17,11-18,11-19,11-20,11-
21,11-22,11-23,11-25,11-26,11-28,11-37,11-41'
Landfills: Executive Summary-1, 1-4,2-1,2-3, 3-1, 3-16, 3-17, 3-27, 3-28,4-4,4-5, 5-3, 7-14, 8-
24, 8-45, 8-47, 8-52, 8-57, 8-58, 9-14,11-14,11-29,13-3, 13-4, 14-2,14-3,14-4,14-5,
14-28,15-10,15-11
Liquid Carbon Dioxide Extraction: 8-41
Long-Term Average: Executive Summary-1, Executive Summary-5, Executive Summary-6,
Executive Summary-7, Executive Summaiy-8, Executive Sumrnary-9,
Executive Summary-10, Executive Summaiy-11, Executive Summary-12,....
ExecutiveSummaryr13,- Executive Summary-14,Executive-Summary-1-5^
Executive Summary-16, Executive Summary-17, Executive Summary-18,
Executive Summary-19,10-1,10-4,10-5,10-6,10-14,10-15,10-17,10-17,
10-18, 10-19, 10-20, 10-2ULO-32, 10-33, 10-37, 10-38, 10-3 9f 10-40,.TO- ~
" - 41,10-44,10-45,~10^H6;n-8;i 1-20,12-19,12-20,12-22,12-23,12-24,12-
27, 12-28, 12-31, 12-32, 15-6
as "LTA": 2-6, 10-5, 10-14, 10-15, 10-16, 10-17, 10-18, 10-19, 12-10, 12-18, 12-20,
12-21, 12-22- -
M
i • '
Metals Subcategory: Executive Summary-1, Executive Summary-3,1-7,2-11,2-15,3-17,3-20,
3-21, 3-22, 4-4, 5-2, 6-1, 6-2,'6-5, 6-6, 6-12, 6-13, 6-14, 6-15, 6-16, 6-27,
6-28,6-29,7-5,7-11,7-20,7-21,7-26,7-31,7-33,8-2,8-5,8-16,8-19,8-
24, 8-33,9-2, 9-3,9-4, 9-12, 9-13,9-14,9-15,9-17,10-2,10-3,10-5,10-6,
10-7, 10-9, 10-10, 10-16, 10-21, 10-31, 10-40, 10-41, 10-42, 10-44, 11-5,
11-7,11-10,11-11,11-29,11-31,11-34,11-43, 12-2,12-4,12-6,12-7, 12-
8,12-33,12-34,13-2,13-3,13-5,14-2,14-3,14-4,14-5,14-6,14-8,14-16,
14-18, 14-20, 14-22, 14-25, 14-27
Cyanide Subset of Metals Subcategory: 9-5, 14-24
Mixed Waste (Subcategory): 5-4,5-5,14-6,14-23
Index-5
-------
Index
Development Document for the CWTPoint Source Category
Monitoring Frequency: 10-27,10-29, 10-32, 10-37, 10-42,10-44, 10-45, 11-31
Multiple Wastestream Subcategory: Executive Summary-1, Executive Summary-2, Executive
" ' Summary-3,5-4,5-5,9-11,9-14,9^16,9-17,10-45,10-46,
11-43,14-3,14-4,14-19
Neutralization: 8-2, 8-5, 8-6, 11-8
Non-detect: 10-20, 10-22,10-25, 10-43, 12-7, 12-9, 12-15, 12-16, 12-19
Non-detect Replacement: 12-19
a
Oil and Grease:' 1-2, 3-14, 6-1, 6-2, 6-27, 6-28, 7-4, 7-13, 7-31, 8-10, 8-13, 8-28, 9-2, 9-7, 9-9,
9-14,10-3,10-4,10-6,10-7,10-8,10-12; 10-31,10-40; 10-41,11-22, li-23,12-
4, 12-6,12-7, 12-8, 12-10,12-12,12-13, 12-20, 12-28, 14-3, 14-4, 14-5, 14-6,
14-18, 15-3, 15-4, 15-5,15-12
Option -
Metals Option 2:
Metals Option 3:
Metals Option 4:
Oils Option 8:
Oils Option 8v:
Oils Option 9:
Oils Option 9v:
Organics Option 3:
Organics Option 4:
11-5, 11-7, 11-8, il-9, 11-13, 11-14, 11-15, 11-27, Ilr28, 11-30.
7-4,7-12,7-25,7-26,9-4,10-3,10-4,10-5,10-9, 10-10, 10-40, 10-
41, 11-5, 11-7,11-8, 11-9, 11-14, 11-15, 11-17, 11-27, 12-28, 12-
29, 12-30, 12-31
7-4, 7-12, 7-13, 7-25,7-26, 10-5, 10-7,10-8,10-41, 10-42,10-46,
11-4, 11-10, 11-11,11-12, 11-13, 11-14, 11-15, 11-16, 11-17, 11-
20, 11-28, 11-29, 11-30, 11-34, 12-8, 12-28, 12-29, 12-30, 12-31
7-4, 7-12, 7-25, 7-26, 10-34, 11-25, 12-28, 12-29, 12-30, 12-31
9-6,9-7,11-4,11-19,11-31
7-12,7-13,7-25, 9-8,10-6,10-46,11-22,11-38, 12-28,12-29, 12-
30, 12-31
9-6, 9-7, 9-8, 11-4, 11-19, 11-31
7-4,7-26,11-31
7-12, 7-13, 7-25, 9-10, 10-46, 12-28, 12-29, 12-30, 12-31
Oils Subcategory: Executive Summary-l, Executive Summary-3,1-6,1-7,2-11,2-12,2-13, 2-14,
3-11, 4-4, 5-2, 5-3, 5-5, 5-6, 5-7, 5-8, 6-1, 6-2, 6-7, 6-8, 6-9, 6-17, 6-18, 6-19,
6-20, 6-21, 6-27, 6-28, 6-29, 7-5, 7-6, 7-11,7-22, 7-25, 7-26, 7-27, 7-28, 7-29,
7-30,7-31,7-33, 8-1, 8-2, 8-3, 8-8, 8-10, 8-13, 8-41, 8-47,9-6,9-7,9-8,9-9,9-
15,9-16,10-1,10-2,10-3,10-4,10-5,10-6,10-7,10-9,10-35,11-19,11-23,11-
31,11-38,12-1, 12-9, 12-10,12-11, 12-13,12-14,12-19, 12-22, 12-23, 12-32,
Index-6
-------
Index
Development Document for the CWTPoint Source Catesorv
12-35,12-36,12-37,13-3,13-5,14-2,14-3,14-5,14-8,14-16,14-18,14-20,4-
22, 14-27
Operation and Maintenance (O&M) Costs: 11-1, 11-2, 11-3, 11-6, 11-7, 11-8, 11-9, 11-10,
11-11,11-12,11-13,11-14,11-15,11-16,11-17,
11-18, 11-19, 11-20, 11-21, 11-22, 11-23, 11-24,
11-25, 11-26, 11-27, 11-28, 11-29, 11-30, 11-31,.
11-32, 11-36, 11-40, 11-43, 11-44
Organics Subcategoryr
Executive Summary-1, 1-7; 2-12; 4-4; 5-2, 5-3, 5-4, 6-1, 6-2, 6-10, 6-
11, 6-22, 6-23, 6-24, 6-25, 6-26, 6-27, 6-28, 6-29, 7-5, 7-11, 7-24, 7-25,
7-26, 7-31, 7-33, 8-2; 8-41, 8-45, 9-9, 9-10, 9-13,10-3; 10-6, 10-7, 10-
15, 10-33, 10-35:, 10-42, 10-44, 11-26, 11-31, 12-1, 12-22, 12-23, 12-
24, 12-25, 12-38, 13-1, 13-2, 13-3, 13-4, 13-5, 14-2, 14-3, 14-4, 14-5,
14-6,14-8,14-16,14-17,14-20,15-5,15-6
Out-of-scope: 2-14
Pipeline: 1-5, 2-3, 2-4, 3-6, 3-7, 3-8, 3-27
POT W Removal: '7-2 1,7-22, 7-24, 7-24, 12-32 ' •
Priority Pollutants: 1-2, 1-3, 2-1, 2-14, 7-13
Publicly Owned Treatment Works: Executive Summary-1, Executive Summaiy-3, 1-1, 1-3, 2-
' '. " "~14, 3-1, 3-12, 3-14, 4-5, 4-6, 7-13, 9-15, 12-1
as "PO7W": Executive Summary-1, Executive Summary-3, 1-1, 1-3, 2-
15,3-7,3-8,3-12,3-13,3-14,3-15,3-19,3-26,3-27,4-5,
4-6,5-4,5-5,5-6,7-13,7-14,7-15,7-16,7-17,7-18,7-19,
7-21, 7-22, 7-24, 7-32, 8-5, 8-57, 8-58, 9-2, 9-9, 9-14, 9-15,
9-17, 10-6, 11-31, 11-43, 12-1, 12-32, 12-34, 12-37, 12-38,
12-39,13-1,14-1,14-19,14-21,14-22,14-27
R
RCRA:
1-4,2-14, 4-1,4-2,4-3,4-6, 5-1, 5-2, 5-3, 5-7, 5-8, 9-14,11-1, 11-29,12-9, 12-10, 12-
17,12-19,12-22,13-4,14-8,14-9,14-10,14-11,14-12,14-13,14-14,14-15,14-16,14-
17 '
Index-7
-------
Index
Development Document for the CWTPoint Source Category
Sampling: 1-7,2-1,2-3,2-4,2-5,2-11,2-12,2-13,2-15,3-17, 3-20, 3-25,4-7, 5-7, 6-1, 6-2, 6-27,
6-28,6-29,7-1,7-14,7-20,7-26,8-33,8-41,8-47,9-2,9-6,9-7,9-8,9-9,9-14,10-1,10-
2,10-3,10-4,10-5,10-6,10-7,10-8,10-9,10-11,10-12,10-15,10-16,10-17,10-18,10-
19,10-37,10-41,11-1,11-13,11-21,11-25,11-26,12-2,12-6,12-7,12-8,12-9; 12-10,
12-12,12-18,12-22,12-23, 14-3, 14-20, 15-1,15-5, 15-6, 15-7
Scope: see Applicability
Sequencing Batch Reactors: 8-43,8-44,11-4,11-26
as "SBR": 8-43,• 8-45-, H-26-
Silica-gel-treated"Hexane Extractable Material: 6-1,7-31
as "SGT-HEM": 2-7, 6-1, 7-1, 7-4, 7-31, 7-32, 10-3, 10-8, 12-
20, 12-28, 12-35, 15-4, 15-5, 15-12
Sludge Treatment and Disposal: 8-1, 8-51, 11-27
Stripping: 1-6,2-11,2-12,7-11,8-2,8-39, 8-40, 8-41,9-6,9-7,9-9,11-4,11-19,11-20; 12-12,12-
13, 13-1, 13-2,,14-10, 14-11
Air Stripping: 1-6, 2-11, 2-12, 7-4, 8-2, 8-39, 8-40, 8-41, 9-6, 9-7, 9-9, 11-4, 11-19,
11-20, 12-12, 12-13, 13-1, 13-2 •
Total Dissolved Solids: 2-11, 2-15, 6-5, 6-7, 7-1,12-4, 12-20, 12-28, 15-4, 15-9, 15-12
as "IDS": 2-7,2-11, 2-15,2-16, 6-27, 7-1, 12-33, 12-35, 12-39
Total Suspended Solids (as "TSS"): Executive Summary-2, Executive Summary-4, Executive
Summary-6, Executive Summary-8, Executive Summary-
10,1-1,1-2,2-7,6-27,7-13,7-31,9-2,9-4,9-9,9-10,9-15,
10-6,10-31,10-42,10-43,10-44,10-45,11-14,11-20,11-
31, 11-32, 11-43, 12-12, 12-13, 12-23, 12-33, 12-35, 12-
38, 15-9
Treatment-in-place: 5-4, 8-2,9-8, 9-16,11-6, 11-10,11-12, 11-13, 11-16,11-23, 11-24, 11-25,
11-26, 11-34, 11-38, 12-6, 12-10, 12-12, 12-13, 12-23, 14-25
Index-8
-------
Index
Development Document for the CWT Point Source Catepnrv
Trickling Filters: 8-43, 8-45, 8-47
Variability Factor:
10-5, 10-9, 10-21,10-28,10-31,10-32,10-33,10-34,10-35, 10-36,10-37,
10-38, 10-39, 10-40, 10-41, 10-43, 10-45, 15-6
Zero Discharge: 3-18, 3-19, 3-21, 3-24, 8-1, 8-57
Index-9
-------
------- |