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SECTION 6
POLLUTANT PARAMETERS SELECTED FOR REGULATION
6 . 0 INTRODUCTION
The pesticide chemicals formulating, packaging and
repackaging (PFPR) industry generates process wastewaters
containing a variety of pollutants. Most of this process
kwastewater does not receive treatment for discharge, but is either
reused directly, reused after storage, reused following treatment
or indirectly discharged to a POTW. The Agency is proposing zero
discharge of wastewater pollutants from the PFPR industry (with
the exception of non-interior streams for indirect discharging
sanitizer chemical facilities — see Section 12).
Typically, this section sets out the rationale for either
including or excluding specific pollutants for regulation.
However, this proposed regulation calls for zero discharge of
process wastewater pollutants, therefore, all process wastewater
pollutants are controlled by this regulation. Thus, for this
regulation this section will serve to describe which pollutants
have been found, through EPA's data gathering process, at PFPR
facilities. The portions of the data gathering effort that
contributed to this section include the PFPR Facility Survey-
Questionnaire for 1988, the sampling analytical database and the
self-monitoring database (described in Section 5.4). Wastewater
6-1
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characterization is discussed separately below for conventional
pollutants, priority pollutants and PAIs.
6 . 1 CONVENTIONAL POLLUTANTS
•Conventional pollutants include:
• Biochemical Oxygen Demand (BOD5) ;
• Total Suspended Solids (TSS);
pH;
• Oil and Grease (O&G); and
• Fecal Coliform.
The most widely used measure of general organic pollution in'
wastewater is five-day biochemical oxygen demand (BOD5) . BOD5 is
the quantity of oxygen used- in the aerobic stabilization of
wastewater streams. This analytical determination involves the
measurement of dissolved oxygen used by microorganisms to
biodegrade organic matter and varies with the amount of
biodegradable matter that can be assimilated by biological
organisms under aerobic conditions. The nature of specific
chemicals discharged into wastewater affects the BOD5 due to the
differences in susceptibility of different molecular structures to
microbiological degradation. Compounds with lower susceptibility
to decomposition by microorganisms or that are more toxic to
microorganisms tend to exhibit lower BOD5 values, even though the
total amount of organic pollutant may be much higher than
compounds exhibiting substantially higher BOD5 values. Therefore,
while BOD5 is a useful gross measure of organic pollutant, it does
6-2
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not give a useful measure of specific pollutants, particularly
priority pollutants and PAIs.
Total solids in wastewater is defined as the residue
remaining upon evaporation at just above the boiling point. Total
suspended solids (TSS) is the portion of the total solids that can
be filtered out of solution using a 1 micron filter. The total
solids are composed of matter which is settleable, in suspension,
or in solution and can be organic, inorganic, or a mixture of
both.
Raw wastewater TSS content is a function of the active
ingredients and inert ingredients used, as well as, the
formulation type (i.e., floor wash water from a dry formulation
area may have more fine solids than floor wash water from a liquid
formulation area) . It can also be a function of a number of other
external factors, including stormwater runoff and runoff from
material storage areas. Solids may be washed into collection
trenches and sumps when facilities perform exterior equipment
rinsing or floor washing.
pH is a unitless measurement which represents the acidity or
alkalinity of a wastewater stream (or any aqueous solution), based
on the dissociation of the acid or base in the solution into
hydrogen (H+) or hydroxide (OH~) ions, respectively.
6-3
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Raw wastewater pH can be a function of the nature of the
processes contributing to the waste stream. This parameter can
vary widely from facility to facility and wastewater source to
wastewater source. Fluctuations in pH are readily reduced by
equalization followed by neutralization, if necessary. Control of
pH is important regardless of the final disposition of the
wastewater stream to maintain favorable conditions for various
treatment system unit operations or for reuse.
b
Raw wastewater oil and grease (O&G) is an important parameter
in some wastewaters as it can interfere with the smooth operation
of wastewater treatment units. Many PFPR facilities use
hydrocarbon petroleum distillates or other raw materials high in
oil and grease content as inert ingredients in pesticide
formulations. However, in terms of indicating the level of
pesticide active ingredient in the wastewater, oil and grease does
not provide a good measure.
The drinking water standard for microbial contamination is
based on coliform bacteria. The presence of coliform bacteria in
wastewater, a microorganism that resides in the human intestinal
tract, indicates that the wastewater has been contaminated with,
feces from humans or other warm-blooded animals. Coliform
bacteria is not expected to be present in the PAI contaminated
wastewater streams generated by PFPR facilities. EPA did not
pursue any further data collection efforts characterizing fecal
6-4
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coliform in pesticide formulating, packaging and repackaging for
this regulation.
6 . 2 PRIORITY POLLUTANTS
Data characterizing the pesticide formulating, packaging and
repackaging wastewater with respect to priority pollutants have
been gathered by EPA qualitatively from industry responses to the
questionnaire and quantitatively from industry supplied
self-monitoring data and EPA sampling and analysis episodes. A
complete list of priority pollutants can be found in Appendix Y.
As explained in Section 5.4.1, the Self-Monitoring (SM)
database consists of data collected from ten facilities. EPA has
examined the data and has found that all but 11 of the priority
pollutants (including three that have been since removed from the
list) were monitored for and have been placed in the SM database.
These 11 pollutants for which no self-monitoring data was
submitted are listed in Table 6-1.
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Table 6-1
Priority Pollutants Por Which No Self-Monitoring Data Was
Submitted
pentachlorophenol
butyl benzyl phthalate
chlordane (technical mixtures and metabolites)
Alpha-BHC
Beta-BHC
antimony (total)
asbestos (fibrous)
beryllium (total)
selenium (total)
thallium (total)
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
Of the remaining 118 priority pollutants 30 have been
reported in self-monitoring data above their detection limit.
These 30 pollutants are listed in Table 6-2. EPA notes that
because the self-monitoring data were not collected from all
facilities in the sample population Table 6-2 may not represent a
complete list of the priority pollutants found in the PFPR
industry.
6-6
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Table 6-2
Priority Pollutants Measured Above Detection Limit in
Self-Monitoring Data
1,1,l-trichloroethane
1,1-dichloroethane
1,3-dichlorobenzene
2-chloronaphthalene
4,4-DDD
4,4-DDE
4,4-DDT
aldrin
arsenic
trichloroethylene
BBC-Gamma (Lindane)
chlorodibromomethane
chloroform
chromium
copper
dichloromethane
dieldrin
ethylbenzene
zinc
endrin
dichlorobronomethane
endosulfan I
endosulf an II
heptachlor
hexachlorobenzene
lead
nickel
phenol
tetrachloroethylene
toluene
In addition to the SM database, information was collected on
priority pollutants in Section 7 of the questionnaire. In this
section of the questionnaire facilities were asked to indicate if
they used any cleaning solutions, inert ingredients or other raw
materials containing priority pollutants when producing products
containing one or more of the 272 pesticide active ingredients.
Facilities were also asked to indicate the specific priority
pollutant(s) used in each case. According to the questionnaire
results: 11 unique priority pollutants were used in cleaning
solutions at 19 unique facilities; 42 unique priority pollutants
were used as raw materials at 45 unique facilities; and 14 unique
priority pollutants were used as inert formulation ingredients at
35 unique facilities.
6-7
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EPA was also able to examine which priority pollutants were
present in PFPR wastewater through the analytical sampling
database. This database contains analytical information gathered
through EPA sampling episodes at 13 facilities. Thirty three
priority pollutants were reported above the detection limit in the
database (see Table 6-3). However, nineteen were all from one
sampling episode (as indicated with an asterisk on Table 6-3).
Table 6-3
Priority Pollutants in Wastewater at Sampled PFPR Facilities
* trans-1,3-dichloropropene
* benzene
* butyl benzyl phthalate
chloroform
*"Di-n-octyl phthalate
* diethyl phthalate
* fluoranthene
methyl chloride
naphthalene
* pyrene
toluene
* 1,1-dichloroethene
* 1,1,2,2-tetrachloroethane
* 1,2-diphenyIhydraz ine
2-chlorophenol
" 2,4-dichlorophenol
* 4-chloro-3-methylphenol
* acroline
bis(2-ethylhexyl) phthalate
carbon tetrachloride
* Di-n-butyl phthalate
* Di-n-propylnitrosamine
ethylbenzene
* isophorone
methylene chloride
phenol
tetrachloroethene
* 1,1-dichloroethane
* 1,1, l-!-trichloroethane
* 1,2-dichloroethane
1,2,4-trichlorobenzene .
2,3,7,8-TCDD
* 2,6-dinitrotoluene
*These priority pollutants were detected at the same facility and
at no other facility.
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6.3 PESTICIDE ACTIVE INGREDIENTS
Most pesticide active ingredients are considered non-
conventional pollutants (a few are priority pollutants) . The
other non-conventional pollutants (e.g., COD, TOC, BOD, TSS,
Ammonia-Nitrogen) are not discussed in this section. A discussion
of the wastewater characterization of non-conventional pollutants
can be found in Section 5.
The self-monitoring database and the analytical sampling
database provide a good idea of the various PAIs and their
concentration in PFPR wastewaters, but this data does not provide
a complete wastewater characterization. As mentioned earlier, EPA
was not able to perform as extensive a sampling program as usual
which means that if, for example, a particular PAI was not found
when sampling or reported in the self-monitoring data that does
not mean it will not be found in PFPR wastewaters. In fact, EPA
assumes that the active ingredient (s) in a given product will be
present in process wastewater generated in conjunction with the
formulation, packaging or repackaging of that product.
Ninety-one PAIs were monitored for in the self-monitoring
database. Thirty-six PAIs were reported above their detection
limits. These PAIs are listed in Table 6-4. Under EPA's sampling
program, PFPR wastewaters were tested for a total of 45 individual
PAIs (site specific) . Thirteen of these PAIs were in samples that
6-9
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Table 6-4
PAIs Found above Detection Limits in Self-Monitoring Database
atrazine
carbofuran
diazinon
dimethoate
endrin
endoBulfan I
guthion
MCPP or Mecoprop
matolachlor
phorate
sutan or butylate
tetrachloroethylene
vernolate or vernam
cycloate or ro-neet
dicamba
disulfoton
EPTC or EPTAM
endosulfan II
heptachlor
merphos or folex
parathion
propachlor
temephos
trifluralin
carbaryl
DEF
dichloran or DCNA
DNBP (Dinosed)
ethion
fluometuron
malathion
methoxychlor
PCNB
propham
terbufos or counter
Vapam
were categorized as shower, laundry, 'commingled raw, effluent or
treated. However, of the 32 PAIs that were analyzed in raw
wastewater samples, 27 PAIs were found at concentrations above the
detection limits. These PAIs are listed in Table 6-5.
Table 6-5
PAIs Found Above Detection Limits in Analytical sampling Database
allethrin
captan
diazinon
endosulfan I
fluometuron
metolachlor
napropamide
piperonyl
tetramethrin
2.4-D
atrazine
carbaryl
dicamba
endosulfan II
maleic hydrazide
MCPP
permethrin cis
propoxur
maneb
deet
dimethoate
fenvalerate
methylene bis (thiocyanate)
MGK 264
permethrin trans
sumithrin
tri-organo tin
6-10
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SECTION 7
TECHNOLOGY SELECTION AND METHODS TO ACHIEVE THE EFFLUENT
LIMITATIONS
7 . 0 INTRODUCTION
This section describes the technologies and practices used by
or currently available to the pesticide formulating, packaging and
repackaging (PFPR) industry to meet the proposed effluent
guidelines limitations and standards. The treatment technologies
applicable to the waste-waters of the PFPR industry are described
in this section, followed by a summary of treatment performance
achievable by these technologies, based on the EPA treatability
studies and the information in the PFPR treatability database.
This section not only describes the wastewater control and
treatment technologies, but provides a descriptive discussion of
the pollution prevention and recycle/reuse practices used in or
available to this industry to achieve zero discharge of wastewater
pollutants.
Section 7.1 presents a description of the current and
proposed treatment technologies available in the PFPR industry for
treatment of conventional pollutants, nonconventional pollutants
(including PAIs), and priority pollutants. A discussion on the
disposal of solid residues and the control of air emissions that
7-1
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are generated from these practices and treatment technologies is
also presented.
Section 7.2 discusses the performance of treatment systems
included in the PFPR Analytical Database. This database consists
of the analytical and performance data gathered at seven PFPR
facilities under the EPA sampling program. Many of these systems
were similar to systems that were used in EPA bench-scale
treatability tests and, therefore, served as benchmarks for the
performance of the treatability studies. The performance of the
treatment technologies that were tested by EPA as part of the
bench-scale treatability tests are discussed in Section 7.3. This
section also includes a detailed description of the performance
and applicability of the Universal Treatment System (UTS) which is
utilized as a treat and reuse system.
Section 7.4 describes in detail the practices that EPA
believes will enable PFPR facilities to meet the proposed effluent
guidelines. These practices include pollution prevention (P2) and
recycle/reuse practices. Pollution prevention practices include
elimination of pollution at the source, either by reducing water
used in the process, using in-process recycle/reuse, or reduction
of pollutants in the wastewater through raw material conservation
(i.e., getting more product in the final product and less in the
wastewater). In a PFPR facility a combination of pollution
prevention, recycle/reuse and, possibly, treatment for reuse will
. 7-2
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be necessary to achieve the zero discharge limitation as proposed
in the regulation. The full consideration of source reduction is
optimal in any activity. Yet the Agency recognizes that it is not
always possible to rely entirely on source reduction. .In those
cases the goal is .to move as far up the environmental management
hierarchy as possible. Our experience reveals that the most
practical solution is often a hybrid of source reduction,
recycling, and treatment. Therefore, Section 7.4 attempts to
present the practices as they are currently being implemented in
industry and identifies those practices believed to be the best
method for dealing with a particular wastewater source.
7 . 1 WASTEWATER TREATMENT IN THE PFPR INDUSTRY
The major treatment technologies currently employed by or
available to facilities in the pesticide formulating, packaging
and repackaging industry to treat wastewaters on-site are:
activated carbon adsorption, hydrolysis, membrane filtration
(reverse osmosis, ultrafiltration and cross-flow filtration),
chemical oxidation (by alkaline chlorination or ozone/UV) ,
emulsion breaking and chemical precipitation (for metals). As
previously discussed, the majority of PFPR facilities do not have
on-site treatment systems, but a number of facilities in this
industry do use some treatment technologies to treat their PFPR
wastewaters. The treatment technologies are typically used as
pre- or post-treatment for pH adjustment or removal of suspended
7-3
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solids (and not for PAI removal) prior to either discharge or
recycle/reuse. These technologies include the following:
neutralization, equalization and clarification/filtration. EPA
would like to note that biological treatment and steam stripping
have been proven to remove some PAIs and priority pollutants that
may be found in pesticide containing wastewaters (see Pesticide
Manufacturing Effluent Guidelines Development Document EPA-821-R-
93-016, September, 1993), but EPA believes these technologies to
be cost prohibitive for PFPR facilities and, therefore, EPA is not
considering them appropriate for this industry.
Either through EPA's sampling program or treatability
studies, the following six technologies have been demonstrated to
provide treatment of PAIs and/or priority pollutants in the
pesticide chemicals manufacturing industry:
Carbon Adsorption;
Chemical Oxidation/Ultraviolet Decomposition;
Chemical Precipitation;
Emulsion Breaking;
Hydrolys is; and
Membrane Filtration
A description of each of these technologies is presented
below.
7-4
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7.1.1
Carbon Adsorption
Adsorption is the primary mechanism for removal of organic
pollutants from wastewater by activated carbon. Activated carbon
has a very large surface area per unit mass which is available for
assimilation of contaminants. The main driving forces for
adsorption of a solute on the adsorbent is attraction of the
solute (or adsorbate) to the adsorbent and/or a hydrophobic
(water-disliking) characteristic of the adsorbate.
Biodegradation of contaminants from microbial growth on the
carbon can improve organics removal and reduce the carbon usage
rate for certain wastewaters, but adsorption is the primary
mechanism for organics removal. Some biologically degradable
compounds are difficult to adsorb and prediction of degradation
rates is difficult, so biodegradation is not usually considered in
the design of activated carbon systems unless an extensive
pilot-scale study is conducted.
The carbon adsorption capacity (the mass of the contaminant
adsorbed per mass of carbon) for specific organic contaminants is
related to the characteristics of the compound, the carbon
characteristics, the process design, and the process conditions.
In general, adsorption capacity is inversely proportional to the
adsorbate solubility. Within a homologous series of organic
compounds, adsorption increases with increasing molecular weight
7-5
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since solubility decreases with increasing molecular weight (e.g.,
Parathion is more strongly adsorbed than EPTC) . Thus non-polar,
high molecular weight organics with low solubility are adsorbed
more readily than polar, low molecular weight organics with high
solubilities. Competitive adsorption of other compounds has a
major effect on adsorption (i.e., the carbon may begin
preferentially adsorbing one compound over another compound and
may even begin desorbing the other compound) . Process conditions
•(such as pH and temperature), process design factors (such as the
use of granular versus powdered carbon, contact time, and number
of columns in series), and carbon characteristics (such as the raw
material source of carbon, particle size and pore volume) also
effect adsorption capacity.
When the adsorptive capacity of the carbon is exhausted, the
spent carbon is either disposed of or regenerated, the choice is
generally determined by economics. The carbon is regenerated by
removing the adsorbed organics from the carbon. Three methods for
carbon regeneration are steam regeneration, thermal regeneration,
and physicochemical regeneration. Thermal and steam regeneration
volatilize the organics which are removed from the carbon in the
gas phase. Afterburners are required to ensure destruction of the
organic vapors and a scrubber may be necessary to remove
particulates. Physicochemical regeneration removes the organics
by a solvent, which can be a water solution. Thermal and steam
regeneration are most commonly used for carbon from wastewater
7-6
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treatment.
Activated carbon is commonly utilized in the form of
granular-carbon columns that operate in either an upflow or
downflow mode. Powdered carbon is used less frequently for
wast.ewater treatment due to the difficulty of regeneration and
reactor system design considerations although it may be used in
conjunction with biological treatment systems.
Carbon adsorption has been demonstrated as an effective
treatment technology for both pesticide manufacturing and
formulating, packaging and repackaging industry wastewaters. EPA
sampling and treatability studies were performed on systems with
activated carbon adsorption, and the results of these studies are
discussed in Sections 7.2 and 7.3.
7.1.2
Hydrolysis
Hydrolysis is a chemical reaction in which organic compounds
react with a base or water and break into smaller (and less toxic)
compounds. Usually the hydroxyl group (OH-) is introduced into the
reactant (target organic compound), displacing another group:
O o
II II
(RO)z-P-S-R + OH- > (R0)2 -P-OH + (SR)~
7-7
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Carbamate hydrolysis occurs by the following reaction:
O
/ \ OH-
RI-N o - R3 + H2o ---- > R3oH
co2
I
R2
The acid hydronium ion can also enter into hydrolysis reactions .
As the reactions above illustrate, hydrolysis is a
destructive technology in which the original molecule forms two or
more new molecules. In some cases, the reaction continues and
other products are formed.
The primary design parameter considered for hydrolysis is the
half-life, which is the time required to react 50% of the original
compound. The half-life of a reaction is generally dependent on
the reaction pH and temperature and the reactant molecule (in this
case, specific PAIs) . Hydrolysis reactions can be catalyzed at
low pH, high pH, or both, depending on the PAI . In general, an
increase in temperature will increase the hydrolysis rate.
Improving the conditions for the hydrolysis reaction results in a
shorter half-life, and therefore, the size of the reaction vessel
required is reduced.
7-8
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As applied to the pesticides industry, hydrolysis is an
effective treatment technology for destruction of PAI contaminants
in wastewater by elevating the temperature and pH. Both EPA
sampling and treatability studies were performed on systems using
hydrolysis, and the results of these studies are discussed in
Sections 7.2 and 7.3.
7.1.3
Oxidation/nitraviolet DeeomposH-i rm
Chemical oxidation is used in wastewater treatment to modify
toxic or otherwise objectionable substances by the addition of an
oxidizing agent. Chemical oxidation is a reaction process in
which one or more electrons are transferred from the oxidizing
chemical (electron donor) to the targeted pollutants (electron
acceptor) causing their destruction. Oxidants typically used in
industry include chlorine, hydrogen peroxide, ozone, and potassium
permanganate. Of these oxidants, chlorine is most commonly used
under alkaline conditions (in the form of sodium hypochlorite) to
destroy such compounds as cyanide (metal finishing, inorganic
chemicals, and pesticides industry) and pesticides.
The major drawback to alkaline chlorination of pesticide
manufacturing wastewaters is the potential production of
chlorinated organic compounds which must subsequently be removed
by an additional treatment technology. Under the pesticides
manufacturing rulemaking development, chloroform,
. 7-9
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bromodichloromethane, and dibromochloromethane were not present in
the raw wastewaters but were detected in at least two of the
bench—scale test reactors. Steam stripping, air stripping, and
activated carbon adsorption are three treatment technologies which
are capable of removing chlorinated organic compounds from
wastewater. At large wastewater flow rates, steam stripping and
air stripping are more economical than carbon adsorption. Because
of the cross media, i.e., air emissions, problems associated with
air stripping, steam stripping was identified as the method for
removing chlorinated organic pollutants for the manufacturing
facilities producing PAIs with BAT/PSES limitations based on
chemical oxidation. At low flow rates, such as those found at
PFPR facilities, carbon adsorption becomes the more economical
treatment technology, because steam stripping (and air stripping)
has very large capital costs. Therefore, the costing algorithm
for the pesticide formulating, packaging and repackaging industry
relies on the activated carbon system to remove chlorinated
oxidation products.
A recent oxidation technology to emerge for the oxidation of
dithiocarbamate PAIs is ozone in combination with ultraviolet
light. This technology, initially developed for the metal
finishing industry to treat iron complexed cyanide, has recently
been suggested as an alternative to chlorine oxidation for
treatment of pesticide manufacturing wastewaters. The ozone-UV
light process focuses on the production of the highly oxidative
7-10
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hydroxyl radicals from the absorption of UV light (254 nanometers
wavelength) by ozone. These hydroxyl radicals completely oxidize
the PAI (e.g., to carbon dioxide, nitrate, sulfate and water)
avoiding the formation of halogenated organic compounds such as
those produced during alkaline chlorination.
7.1.4
Membrane Filtratii
Membrane filtration is a term applied to a group of processes
that can be used to separate suspended, colloidal, and dissolved
solutes from a process wastewciter. Membrane filtration processes
utilize a pressure driven, semipermeable membrane to achieve
selective separations. Much of the selectivity is established by
designations relative to pore size. The pore size of the membrane
will be relatively large if precipitates or suspended materials
are to be removed, or very small for the removal of inorganic
salts or organic molecules. During operation, the feed solution
flows across the surface of the membrane, clean water permeates
the membrane, and the contaminants and a portion of the feed
remain. The clean or treated water is referred to as the permeate
or product water stream, while the stream containing the
contaminants is called the concentrate, brine, or reject.
In a typical industrial application, the product water steam
will either be discharged, or more likely, recycled back to the
manufacturing process. The reject stream is normally disposed,
7-11
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but in those situations where the reject does not contain any
specifically objectionable materials, it too can potentially be
recycled back to the process. As an example, a reject stream from
a system treating a wastewater generated from many different
processes would likely have to be disposed. However, if the
membrane system were used on a process where the wastestream
contained only a specific PAI, the reject stream could possibly be
recycled back to the process. Depending on the characteristics of
the wastewater and the type of process used, 50-95% of the feed
stream will be recovered for reuse as product water. An EPA
treatability study conducted with ultrafiltration and reverse
osmosis indicates that the reject stream contains high
concentrations of total dissolved solids (TDS), calcium and
sodium, as well as PAI.
Types of membrane filtration systems available include
microfiltration, ultrafiltration (UF), and reverse osmosis (RO).
Microfilters are generally capable of removing suspended and
colloidal matter with diameters greater than 0.1 micron (3.94 x
10~6 inches) . The systems can be operated at feed pressures of
less than 50 psig. The feed stream does not require extensive
pretreatment, and the membrane is relatively resistant to fouling
and can be easily cleaned. A microfiltration system would not be
an effective method of treatment unless the PAIs were insoluble or
were attached to other suspended material in the wastewater.
Microfiltration has been used in the pesticide industry in
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applications where an adsorbent material and/or flocculent is
added prior to the membrane system. The PAIs are adsorbed or
become attached to the floe which forms and is ultimately
separated by the microfilter. Microfilters are capable of
recovering up to 95% of the feed stream as product water.
Ultrafiltration is similar to microfiltration, with the
difference being that a UF membrane has smaller pores. The
"tightest" UF membrane is typically capable of rejecting molecules
having diameters greater than 0.001 micron (3.94 x 10-8 inches) or
nominal molecular weights, greater than 2000. The systems operate
at feed pressures of 50-200 psig. Some pretreatment may be
necessary to prevent membrane fouling. UF systems would only be
effective in removing PAIs which are insoluble or attached to
other suspended material (most PAIs have molecular weights from
150 to 500 molecular weight units). For most UF designs, the
introduction of adsorbents or flocculants to the feed stream is
not recommended since they may plug the membrane module. UF
systems are also capable of recovery of up to 90-95% of the feed
as product water.
Reverse osmosis systems have the ability to reject dissolved
organic and inorganic molecules. For organic (noncharged)
molecules such as PAIs, membrane rejection is a function of the
membrane pore size. Typically, membranes with' a pore size of
0.0001 to 0.001 microns are used to remove PAIs. RO membranes
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have been shown to be capable of removing the majority of PAIs
with molecular weights greater than 200. Unlike microfiltration
and ultrafiltration, RO membranes are capable of rejecting
inorganic ions. The mechanism for salt rejection is the
electro-chemical interaction between the membrane and the
constituents in the wastewater. Based on the strength of their
ionic charge (valence) , the ions are repelled from the charged
surface of the membrane and will not pass through the pores.
Although RO membranes may be rated based on molecular weight
cutoff, they are normally rated on their ability to reject sodium
chloride. Typical sodium chloride rejection for an industrial
type membrane would be 90-95 percent.
RO systems used in industrial applications are designed to
operate at feed pressures of 250-600 psig. RO membranes are very
susceptible to fouling and may require an extensive degree of
pretreatment. Oxidants which may attack the membrane,
particulates, oil, grease, and other materials which could cause a
film or scale to form must be removed by pretreatment. The RO
product water stream will usually be of very high quality and
suitable for discharge, or more importantly, reuse in the
manufacturing process. Standard practice is to dispose of the
reject stream. Dissolved solids present in the feed stream will
be concentrated in the reject and will limit the opportunities for
recycle. RO systems will be capable of recovering 50-90% of the
feed as product water. The recovery that can be obtained as well
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as the required feed pressure to operate the system will be a
function of the dissolved solids concentration in the feed.
The membranes used in the filtration process are made from a
number of different materials. Microfiltration membranes are
commonly made from woven polyester or ceramic materials. UF and
RO membranes are fabricated .from cellulose acetate, polysulfone,
polyamide, or other polymeric materials. The most common material
•is cellulose acetate. Although cellulose acetate membranes are
lower cost and not as susceptible to fouling, removal of some low
molecular weight PAIs such as carbaryl, fluometuron,
chloropropham, and atrazine have been shown to be only marginal.
In addition, mass balances conducted for short-term tests have
shown a significant amount of the PAI rejection may be due to
adsorption to the membrane as opposed to rejection by it.
Discussions and results of EPA sampling and treatability
studies involving membrane filtration systems can be found in
Sections 7.2 and 7.3, respectively.
7.1.5
Emulsion Brealel
There are two types of emulsions. The first type is
basically oily wastewater (oil in water, or O/W), where some type
of hydrophobic solvent or oil is dispersed in an aqueous medium.
Emulsion breaking (resolution) for oily wastewater may be
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performed as follows:
1. Coagulation - Coagulation breaks emulsions through the
addition of acid, an iron or aluminum salt (which will
form sludge), or an uncharged adsorbent (clay or lime)
to the wastewater. Acid addition will generally cause
the oil to float, allowing it to be skimmed off. Sludge
formation breaks the emulsion by adsorbing the oil
molecules to the settled particles. Sludge formation is
then followed by flocculation for sludge removal.
2. Addition of Organic Demulsifiers — A wide range of
polymers are available for demulsifying oily wastewater
streams. Wastewater testing is usually required in
order to determine which demulsifier is most effective.
A demulsifier's applicability is based on such
attributes as its molecular weight and charge density.
3. Dissolved Air Flotation (DAF1 - This is a liquid-solid
separation process, generally used as a
sludge-thickening operation, in which air bubbles flow
upward through the wastewater carrying suspended solids
and oil droplets to the surface for removal by skimming.
DAF effectiveness can be improved through the addition
of polymer flotation aids.
The second type of emulsion is a water-in-oil (or W/O)
emulsion, in which an aqueous phase is dispersed in oil or some
other hydrophobic solvent. Emulsion breaking for W/O emulsions
may be performed by the following chemical methods, each requiring
thorough mixing and heating to 120-180°F:
1- Acidification - Acidification is effective for cases
where the acid dissolves solid materials in the emulsion
that are maintaining surface tensions in the emulsion.
2. Addition of Organic Demulsifiers - Addition of all
organic demulsifying agent with both hydrophobic and
hydrophilic groups can be effective in demulsification
by changing the charge densities of the dispersed phase.
3. Physical Treatment Techniques - Breaking W/O emulsions
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can also be done by physical means, such as heating and
centrifugation.
Chemical Emulsion Breaking
When using chemical emulsion breaking (followed by gravity
differential separation) several factors should be considered.
These are: the type of chemicals, dosage and sequence of
addition, pH, mechanical shear and agitation, heat and retention
time.
Polymers, alum, ferric chloride and organic emulsion
breakers, break emulsions by neutralizing repulsive charges
between particles, precipitating or salting out emulsifying agents
or altering the interfacial film between the oil and water so it
is readily broken. Reactive cations (e.g., H(+l), Al(+3), Fe(+3),
and cationic polymers) are particularly effective in breaking
dilute O-W emulsions. Once the charges have been neutralized or
the interfacial film broken, the small oil droplets and suspended
solids will be adsorbed on the surface of the floe that is formed,
or break out and float to the top. Various types of emulsion
breaking chemicals are used for the. various types of oils.
If more than one chemical is required, the sequence of
addition can make quite a difference in both the emulsion breaking
efficiency and the necessary chemical dosages.
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In addition, pH plays an important role in emulsion breaking,
especially if cationic inorganic chemicals, such as alum, are used
as coagulants. A depressed pH in the range of 2 to 4 keeps the
aluminum ion in its most positive state where it can function most
effectively for charge neutralization. After some of the oil is
broken free and skimmed, raising the pH into the 6 to 8 range with
lime or caustic will cause the aluminum to hydrolyze and
precipitate as aluminum hydroxide. This floe entraps or adsorbs
destabilized oil droplets which can then be separated from the
water phase. Cationic polymers can break emulsions over a wider
pH range and thus avoid acid corrosion and the additional sludge
generated from neutralization; however, an inorganic flocculant is
usually required to supplement the polymer emulsion breaker's
adsorptive properties.
Mixing is important in breaking O-W emulsions. Proper
chemical feed and dispersion is required for effective results.
Mixing also causes collisions which help break the emulsion, and
subsequently helps to agglomerate droplets.
In all emulsions, the mix of two immiscible liquids has a
specific gravity very close to that of water. Heating lowers the
viscosity and increases the apparent specific gravity differential
between oil and water. Heating also increases the frequency of
droplet collisions, which helps to rupture the interfacial film.
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Chemical emulsion breaking was tested by EPA as part of the
Universal Treatment System treatability study. Details and
results are discussed in Section 7.3.
Thermal Emulsion Breaking
Although EPA has not seen thermal emulsion breaking
demonstrated in the PFPR industry, it is commonly used in the
metals and mechanical products industries. Dispersed oil droplets
in an emulsified wastewater can be destabilized by the application
of heat to the wastewater. Thermal emulsion breaking (TEB) or the
evaporation-decantation-condensation process is used to separate
the emulsified wastewater into distilled water, oils and other
floating materials, and sludge.
Raw waste is fed to a main reaction chamber. Warm air is
passed over a large revolving drum which is partially submerged in
the waste. Some water evaporates from the surface of the drum and
is carried upward through a filter and a condensing unit. The
condensed water is discharged or reused as process make-up, while
the air is reheated and returned to the evaporation stage. As the
water evaporates in the main chamber, oil concentration increases.
This enhances agglomeration and gravity separation of oils. The
separated oils and other floating materials flow over a weir into
a decanting chamber. A rotating drum skimmer picks up oil from
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the surface of the decanting chamber and discharges it for
possible reprocessing or contractor removal. Meanwhile, oily
water is being drawn from the bottom of the decanting chamber,
reheated and sent back into the main conveyorized chamber. Solids
which settle out in the main chamber are removed by conveyor belt.
This conveyor belt, called a flight scraper, moves slowly so as
not to interfere with the settling of suspended solids.
The performance of a thermal emulsion breaker is dependent
primarily on the characteristics of the raw wastewater and the
proper maintenance and functioning of the process components.
Some emulsions may contain volatile compounds which could escape
with the distilled water. In systems where the water is recycled
back to process, however, this problem is essentially eliminated.
Use of Emulsion Breaking in the PFPR Industry
Although Emulsion Breaking is a pretreatment step, its
importance to the treatment of the PFPR wastewaters has lead EPA
to consider it as a major part of the treatment technology train
for treating PFPR wastewaters. The importance of the emulsion
breaking step becomes apparent when treating wastewaters
containing matrices that are formed during the formulating of
certain pesticide products or when wastewaters from different
pesticide products are commingled. Many pesticide products are
formulated with surfactants, emulsifiers or petroleum hydrocarbons
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as inert materials in order to achieve specific application
characteristics. When these "inerts" mix with other components in
the wastewater, emulsions may form. These emulsions may cause
matrix interferences and lead to reduced performance efficiency of
many treatment unit operations (hydrolysis, chemical oxidation,
carbon adsorption). EPA believes that, in many situations, an
emulsion breaking step will be a necessary step before PFPR
wastewaters can be treated effectively.
As discussed in detail in Section 7.3, EPA collected actual
PFPR facility wastewater to use in the treatability study on the
Universal Treatment System. This study included the testing of
chemically assisted emulsion breaking with various coagulants.
EPA purposely collected wastewater from two facilities where the
wastewater would present a real "challenge" to the treatment
system being tested. These wastewaters were not only believed to
contain a variety of PAIs from different products (due to
commingling of wastewaters), but to contain a mix of inert
materials that would create an emulsion, therefore, presenting
"matrix interference" problems.
Several PFPR facilities already have emulsion breaking
operations in-place. Examples of emulsion breaking technologies
at these facilities, as well as emulsion breaking technologies
discussed in the final development document for the Metal Molding
and Castings (Foundries) effluent guidelines limitations (see
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Development Document, EPA 440/1-85/070), include:
1. One of the sampled PFPR facilities uses heat to break
what appears to be an oil-in-water emulsion.
2. One PFPR facility indicated in their questionnaire
response that acidification with sulfuric acid is used
to "spring" oils from the facility's wastewater, after
which the oils are skimmed.
3. Another sampled PFPR facility performs acidification
(apparently for coagulation) and flocculation followed
by settling.
4. One PFPR facility uses "Fenton's Process," which is an
oxidation technology utilizing ozonation in the presence
of a ferrous sulfate catalyst, followed by pH adjustment
for sludge precipitation. This process is designed to
oxidize oils and greases (as well as any other organic
pollutants in the wastewater) to carbon dioxide and
water, as well as precipitate metals. A variation of
this process uses microfiltration to remove suspended
solids, instead of settling.
5. Some foundries, as well as facilities in other metals
industries, employ chemical emulsion breaking, in which
the wastewater pH is adjusted to between 3 and 4, iron
or aluminum salt is added, the wastewater is allowed to
separate (use of heat decreases separation time), and
finally lime is added to precipitate metals.
6. Some foundries, as well as facilities in other metals
industries, also employ thermal emulsion breaking, in
which wastewater is brought into contact with a rotating
drum. The drum is half-submerged in the wastewater.
Hot air is blown over the drum, evaporating the
wastewater and leaving the oil behind in the remaining
wastewater. The increased oil concentration enhances
further separation, and the oil is finally skimmed.
Very little discharge monitoring data were available
characterizing the effluents from emulsion breaking technologies
found at the facilities discussed above. However, some PFPR
facilities are known to treat their wastewaters following emulsion
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breaking (i.e., chemically assisted clarification). EPA conducted
sampling of treatment systems which include a pretreatment step
to break the emulsions (pretreatment steps that were sampled
include ultrafiltration prior to activated carbon adsorption or
flocculation and clarification). EPA has also conducted a
treatability test of chemically assisted emulsion breaking (as
part of the Universal Treatment System). Results of the sampling
episodes and the Universal Treatment System Treatability Study are
presented in Sections 7.2 and 7.3, respectively.
Based on the information cited above, information gathered on
the PFPR industry through the questionnaire and sampling, and
information on equipment gathered through vendors, a design and
cost algorithm has been developed. The algorithm calculates .
estimated treatment costs for an emulsion breaking system, as part
of the Universal Treatment System, based upon acidification and
heating of wastewater. (See Section 8 for details on the emulsion
breaking cost algorithm.)
7.1.6
Chemical Precipitation/Separation
Chemical precipitation is a separation technology in which
the addition of chemicals during treatment results in the
formation of insoluble solid precipitates from the organic or
inorganic compounds in the wastewater. Filtration then separates
the solids formed from the wastewater. Chemical precipitation is
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generally carried out in four phases:
1. Addition of the chemical to the wastewater;
2. Rapid (flash) mixing to distribute the chemical homogeneously
into the wastewater;
3. Slow mixing to promote particle growth by various
flocculation mechanisms; and
4. Filtration to remove the flocculated solid particles.
Chemical precipitation is used frequently as a technology to
remove metals from industrial wastewaters. The precipitated
metals may then be removed by physical means such as clarification
(settling), filtration, or centrifugation.
Hydroxide precipitation is the conventional method of
removing metals from wastewater and was identified as a BAT
treatment technology for pesticide manufacturing facilities
manufacturing certain metallo-organic PAIs. Reagents such as
slaked lime (CA(OH)2) or sodium hydroxide are added to the
wastewater to adjust the pH to the point where metal hydroxides
exhibit minimum solubilities and are precipitated. Sodium
hydroxide is more expensive than lime, but generates a smaller
volume of hydroxide sludge.
Hydrogen sulfide, ferrous sulfide, or soluble sulfide salts,
such as sodium sulfide, are used to precipitate many heavy metal
sulfides. Because most metal sulfides are even less soluble than
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metal hydroxides at alkaline pH levels, greater metal removal can
often be accomplished through the use of sulfide rather than
hydroxide as a chemical precipitant. In addition, sulfide can
precipitate metals complexed with most complexing agents.
Carbonate precipitation is another method of removing metals from
wastewater by adding carbonate reagents such as calcium carbonate
to the wastewater to precipitate metal carbonates.
Chemical precipitation operates at ambient conditions and is
well suited to automatic control. Hydroxide precipitation removes
metal ions such as antimony, arsenic, trivalent chromium, copper,
lead, mercury, nickel, and zinc, but does not remove metals
complexed with complexing agents. Sulfide precipitation can be
used to remove mercury, lead, and silver and complexed metals
while carbonate precipitation removes antimony and lead from
wastewater.
The design and cost algorithm for the PFPR industry
calculates costs for chemical precipitation based on a combination
of hydroxide and sulfide precipitation. (See Section 8 for
details).
7.1.7
Pre- or
The pesticide chemicals manufacturing industry uses
equalization, neutralization, and/or filtration to treat process
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wastewaters before additional treatment or discharge. These pre-
and post-treatment technologies can also be found in the PFPR
industry.
Equalization
Equalization dampens flow and pollutant concentration
variation of wastewater prior to subsequent downstream treatment.
By reducing the variability of the raw waste loading, equalization
can significantly improve the performance of downstream treatment
processes that are more efficient if operated at or near uniform
hydraulic, organic, and solids loading rates. Increased treatment
efficiency reduces effluent variability associated with slug raw
waste loadings. Equalization is accomplished in a holding tank or
a pond. The retention time of the tank or pond should be
sufficiently long to dilute the effects of any highly concentrated
continuous flow or batch discharges on treatment unit performance.
Neutralization
Neutralization adjusts either an acidic or a basic waste
stream to a more neutral pH. Neutralization of acidic or basic
waste streams is used in the following situations:
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To enhance precipitation of certain dissolved metals;
To prevent metal corrosion and damage to other
construction materials;
As a preliminary treatment allowing effective operation
of the biological treatment process;
To provide neutral pH water for recycle uses; and/or,
To reduce detrimental effects on a facility's receiving
water.
Neutralization may be accomplished in either a collection
tank, rapid mix tank, or equalization tank by commingling acidic
and alkaline wastes, or by the addition of chemicals. Alkaline
wastewaters are typically neutralized by adding sulfuric or
hydrochloric acid, or compressed carbon dioxide. Acidic
wastewaters may be neutralized with limestone or lime slurries,
soda ash, or caustic soda. The selection of neutralizing agents
depends upon cost, availability, ease of use, reaction byproducts,
reaction rates, and quantities of sludge formed. The most
commonly used chemicals are lime (to raise the pH) and sulfuric
acid (to lower the pH).
Filtration
Filtration is a separation technology designed to remove
solids from a wastewater stream by passage of most of the
wastewater through a material that retains the solids on or within
itself. Filters can be classified by the following factors:
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The driving force (i.e., the manner by which the
filtrate is induced to flow, either by gravity or
pressure);
The function (i.e., whether the filtrate or the
filtered material is the product of greater value);
The operating cycle (i.e., whether the filter
process occurs continuously or batchwise);
The nature of the solids (i.e., the size of the
particles being filtered out); and.
The filtration mechanism (i.e., whether the
filtered solids are stopped at the surface of the
medium and pile up to form a filter cake or are
trapped within the pores (spaces) or body of the
filter medium).
Clarification
Clarification can be used as either a pre- or post-
treatment step. Clarification tanks are often referred to as
primary or secondary sedimentation tanks. Clarification serves as
a means to: (1) remove settleable solids; (2) remove free oil &
grease and other floating material; and (3) reduce the organic
load on receiving waters or POTWs . According to Metcalf & Eddy' s
Wastewater Engineering,. 3rd ed., "Efficiently designed and
operated primary sedimentation tanks should remove from 50 to 70
percent of the suspended solids and from 25 to 45 percent of the
BODs." These removals represent achievable levels for domestic
sewage and for industrial pesticide containing wastewaters.
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7.1.8
Disposal of Solid Residue from Treatment
Many of the wastewater treatment processes discussed in
previous parts of this section generate solid residues (i.e.,
sludges). Treatment processes generating solid residues include
chemical precipitation, emulsion breaking and clarification.
Certain membrane filtration processes can generate a solid
residue, but in most cases the concentrate residue is still in
kliquid form and may be recovered for its product value. Sludge is
treated prior to disposal to reduce its volume and to render it
inoffensive (i.e., less odorous). Sludge treatment alternatives
include thickening, stabilization, conditioning, and dewatering.
Sludge disposal options include combustion and disposal to land.
Sludge Treatment Alternative**
Sludge thickening is the first step in removing water from
sludges to reduce their volume. It is generally accomplished by
physical means, including gravity settling, flotation, and
centrifugation. Stabilization makes sludge less odorous and
putrescible, and reduces the pathogenic organism content. The
technologies available for sludge stabilization include chlorine
oxidation, lime stabilization, heat treatment, anaerobic
digestion, and aerobic digestion. Conditioning involves the
biological, chemical, or physical treatment of a sludge to enhance
subsequent dewatering techniques. The most common methods used to
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condition sludge are thermal and chemical conditioning.
Dewatering is the removal of water from solids to achieve a volume
reduction greater than that achieved by thickening. This process
is desirable for preparing sludge for disposal and for reducing
the sludge volume and mass to achieve lower transportation and
disposal costs. Some common dewatering methods include filtration
in a vacuum filter, filter press, or belt filter, centrifugation,
thermal drying in beds , and drying in lagoons .
Disposal Alternatives
Combustion serves as a means for the ultimate disposal of
organic constituents found "in sludge. Some common equipment and
methods used to incinerate sludge include fluidized bed reactors,
multiple hearth furnaces, atomized spray combustion, flash drying
incineration, and wet air oxidation. Environmental impacts of
combustion technology that should be considered include the
effects of discharges to the atmosphere (particles and other toxic
or noxious emissions) , to surface waters (scrubber water
discharges) , and to land disposal (ash) .
The disposal of sludge to land may include the application of
the sludge on land as a soil conditioner and as a source of
fertilizer for plants. This is typically used with sludges from
biological treatment systems. In addition, sludge can be
stockpiled in landfills or permanent lagoons. In selecting a land
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disposal site, consideration must be given to guard against
pollution of groundwater or surface water.
7.2 WASTEWATER SAMPLING
7.2.0 Introduction
EPA performed seven sampling episodes for treatment
performance at six PFPR facilities to obtain data on treatment
system performance (one facility was sampled twice). This section
describes the treatment systems and presents performance data
obtained during the EPA sampling episodes for both individual
treatment unit operations and for overall system performance.
When indicated, the overall system percent removal is averaged
over the number of individual runs performed. This section does
not describe the additional seven wastewater sampling episodes
conducted to obtain data for raw wastewater characterization.
These sampling episodes were typically one day wgrab" sampling
episodes.
Removal efficiencies are calculated using the difference
between the concentrations of constituents in the effluent and the
influent wastewaters in each treatment step. No removal (NR)
efficiency is reported when the effluent concentration of a
constituent is greater than the influent concentration. For
constituents detected in the influent stream but not detected in
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the effluent stream, the removal efficiency is calculated using
the effluent detection limit as the effluent concentration and the
removal is reported as greater than (>) this value. For example,
if toluene is detected at 100 |lg/L in the influent and is not
detected (at a detection limit of less than 5 }ig/L) in the
effluent, the removal efficiency is calculated to be greater than
(>) 95 percent.
7.2.1
Treatment Svs-hem Performance
The system at one facility consists of an ultrafiltration
membrane followed by an activated carbon unit through which
process wastewater is treated for reuse. This system was sampled
during two separate episodes. During each episode, two separate
treatment runs of herbicide and insecticide wastewaters were
performed. The herbicide pesticide active ingredients (PAIs)
analyzed in the wastewater that were treated through the system
included: 2,4-D, dicamba, MCPP and prometon; the insecticide PAIs
analyzed in the wastewater that were treated through the system
included: carbaryl, chlorpyrifos, diazinon and disulfoton. The
percent of PAI removed during treatment is presented below for
both the individual unit operations and the overall system during
each episode:
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Table 7-1
PAI Percent Removals Achieved by the
Ultrafiltration/AC Treatment System
First Episode
Herbicide*
Insecticide
PAI Name
2,4-D
Dicamba
MCPP
Prometon
Carbaryl
Chlorpyrifos
Diazinon
Disulfoton
Removal By
Dltrafltration
39.83
2.08
61 . 67
19.23
22.77
99.47
81.82
97.82
Removal By
Activated Carbon
99,99
>99.98
99.99
>97.33
99.99
80.71
79.17
Overall
Removal
99.99
>99.98
>99.99
>97.85
>99.99
>99.69
96.49
>99.55
Table 7-2
PAI Percent Removals Achieved by the
Ultrafiltration/AC Treatment System - Second Episode
Herbicide*
Xn*ecticide
PAX Name
2,4-D
Dicamba
MCPP
Prometon
Carbaryl
Chlorpyrifos
Diazinon
Disulfoton
Removal By
Ultrafltration
NR
6.93
ND
49.10
NR
>99.92
NR
59.26
Removal By
Activated Carbon
99.99
>99.98
99.60
>99.91
99.97
ND
99.48
99.98
Overall
Removal
99.99
>99.99
>99.29
>99.96
99.97
99.77
99.27
99.99
NOTES:
ND = PAI concentration below detection limit in influent
stream.
NR = No removal
Calculated percent removals not corrected to reflect
significant figures'.
As discussed in Section 7.1, ultrafiltration (UF) is a type
of membrane filtration that is typically used to separate
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suspended or colloidal solutes from wastewater and is typically
capable of rejecting molecules with molecular weights above 2000.
Because most PAIs have molecular weights between 150 and 500, UF
is not effective for removing dissolved PAIs; however, due to the
hydrophobic nature of many PAIs, the PAIs adhere to suspended
solids in the wastewater and these solids are effectively rejected
by the UF membrane. The data from the two episodes show that, in
general, the insecticidal PAIs were removed by the UF unit to a
greater degree that the herbicidal PAIs.
In addition'to the PAIs removed, the ultrafiltration unit
effectively removed oil and grease and total suspended solids
(TSS). An average of 94% and 88% of the oil and grease was
removed by the UF unit from the herbicide and insecticide
wastewater, respectively. In addition, an average of greater than
97% and greater than 91% of the total suspended solids was removed
from the herbicide and insecticide wastewater, respectively.
Following ultrafiltration the wastewater is treated through
activated carbon treatment. Adsorption is the primary mechanism
for removal of organic constituents from wastewater through
activated carbon treatment. The main driving force for adsorption
is the attraction of the solute to the carbon and/or the
hydrophobic nature of the solute. In general, activated carbon
was highly effective in removing PAIs from the sampled PFPR
wastewaters. Each of the PAIs was either removed to below
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detection limits or removed in excess of 99%, with the exception
of diazinon during the second sampling episode. The treatment
system, including UF and activated carbon, was effective at
removing at least 96% (and in many cases >99%) of the PAIs in the
wastewater.
The second treatment system sampled consists of clarification
followed by ozonation and activated carbon and is also a treat and
reuse system. EPA collected samples for three treatment runs:
two with wastewaters containing atrazine and one with wastewaters
containing pendimethalin. The percent of PAI removed during
treatment is presented in the table below for the individual unit
operations and the overall system during each treatment run.
Table 7-3
PAI Percent Removals Achieved During Treatment
at Second Facility
PAI Name
Atrazine 1
2
Pendimethalin
Removal By
Clarification
(*)
93.98
92.04
99.96
Removal By
Ozonation
(%)
14.77
NR
61.67
Removal By
Activated
Carbon
(*)
99.93
99.94
>99.35
Overall
Removal
(%)
>99.99
99.99
>99.99
NOTES:
ND = PAI concentration below detection limit in influent
stream.
NR = No removal
Calculated percent removals not corrected to reflect
significant figures.
7-35
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Clarification is commonly used to settle suspended particles
from wastewater (see Section 7.1 for detailed description). •
Clarification was very effective in removing atrazine and
pendimethalin from the clarifier influent. Atrazine
and pendimethalin have low solubilities in water and are therefore
more likely to adhere to solids in the wastewater. Because
clarification is designed to reduce the solids content of the
water, PAIs that adhere to solids will be effectively removed
during clarification. In contrast, the more water soluble PAIs
are not likely to be removed during clarification since they are
dissolved in the water rather than adhered to the solids. In
addition to removing >92% of the PAIs, the clarification unit
removed and average of 94 % of the oil and grease and an average
of 80% of the total suspended solids during the three treatment
runs.
As discussed in Section 7.1, ozonation is an aggressive
oxidation process in which one or more electrons are transferred
from the ozone to the wastewater constituent. Pendimethalin in
the ozonation unit feed was reduced by 62%, while there was
essentially no change in the concentration of atrazine. However,
carbon was very effective at removing 99% or greater of the
remaining PAIs in the wastewater and the overall system was
effective at removing >99.99% of the PAIs in the wastewater.
The third treatment system that was sampled was not used for
7-36
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the purpose of treating wastewaters to reusable levels, but as
pretreatment prior to indirect discharge to a POTW. The system
consists of clarification followed by activated carbon. Following
clarification, the PFPR process line wastewaters at this facility
are commingled with pesticide manufacturing wastewaters,
laboratory rinsate and drum rinsate prior to activated carbon
treatment. One treatment run of the clarification unit and three
individual treatment runs of the activated carbon unit were
sampled by EPA. EPA analyzed the wastewater treated through the
clarifier for 2,4-D only; however, the concentration for 2,4-D
showed an increase through the clarifier, thus, a removal could
not be calculated. TSS removal through the clarification unit was
84 percent.
The data presented below represent PAI removals achieved
through the activated carbon unit for the individual days of
sampling and the average percent removal by the activated carbon
unit over the three days.
7-37
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Table 7-4
PAX Percent Removal Achieved During Treatment at
the Third Facility
FAX Name
2,4-D
Fluometuron
Metolachlor
Propachlor
Activated Carbon
Removal
Day 1
53.85
44.83
>98.82
80.00
Removal
Day 2
58.57
86.87
>96.55
82.86
Removal
Day 3
41.33
74.12
>98.57
79.37
Average
Removal
51.25
68.61
>97.98
80.74
NOTES:
ND = PAI concentration below detection limit in influent stream.
NR — No removal
Calculated percent removals not corrected to reflect significant
figures.
The four PAIs were removed through the activated carbon unit,
on average, by greater than 50 percent. Under the pesticides
manufacturing effluent guidelines and standards studies, the
activated carbon treatment system at this facility was found to be
achieving less than optimal removals of the manufactured PAI,
which may account for the lower than expected removals through the
carbon unit for the PAIs.
Treatment at the fourth facility actually consists of two
systems. The first system is used to treat non-process area
precipitation (stormwater), and consists of a multimedia filter
followed by an activated carbon unit. This system is used to
pretreat the wastewater prior to indirect discharge to a POTW.
7-38
_
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The non-process area precipitation treatment system was
sampled by EPA during one treatment run for the following PAIs:
carbosulfan, chlorpyrifos, diazinon, endosulfan I, endosulfan II,
malathion, oryzalin, oxyfluorfen and permethrin. The results are
shown in the tables below.
Table 7-5
PAI Percent Removals Achieved for the
Non-Process Precipitation Treatment System
PAI Name
Carbosulfan
Chlorpyrifos
Diazinon
Endosulfan I
Endosulfan
II
Malathion
Oryzalin
Oxyfluorfen
Permethrin
Removzil
By
Multimedia
Filtration
ND
11.36
NR
65.71
83.75
47.62
NR
ND
>68.25
Removal By
Activated
Carbon
(%)
ND
81.03
63.16
90.00
95.13
98.33
54.74
ND
72.00
Overall
Removal
(%)
83.18
58.82
96.57
99.21
99.13
54.74
>75.00
91.11
NOTES:
ND = PAI concentration below detection limit in influent
stream.
NR = NO removal
Calculated percent removals not corrected to reflect
significant figures.
Multimedia filtration is a technology used to separate solids
from the wastewater. There was little change in the
concentrations of most of the PAIs during multimedia filtration,
but TSS was reduced by 79% and oil and grease by 55 percent.
Activated carbon was effective at reducing concentrations of PAIs
7-39
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remaining in the wastewater following multimedia filtration,
leading to overall removals of >90% for four of the PAIs.
The second system at this facility is used to treat process
wastewater, and consists of a microfiltration unit followed by
activated carbon. The microfiltration unit is a cross-flow
filtration system. In this system, suspended matter in the
wastewater, or in a precoat solution, deposits on the inner walls
of the unit, forming a dynamic filter. The surface of the dynamic
filter is continuously formed by axial flow of the wastewater
through tubes. The dynamic filter enhances the performance of the
microfilter to achieve results similar to an ultrafiltration unit.
The rnicrofiltration system at this facility treated 1,500- to
4,300-gallon batches of wastewater during the sampling episode.
The process wastewater in this system is treated and primarily
reused for rinsing drums/shipping containers.
During the sampling episode, three batches of process
wastewater were treated through the microfiltration system. The
samples were analyzed for the same PAIs as the samples from the
multimedia filtration system, as well as the PAIs dimethoate and
Vapam®. The results are given as 3-day averages on the table
below:
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Table 7-6
PAI Percent: Removals Achieved for the
Process Wastewater Treatment System
PAX Name
Carbosulfan
Chlorpyrifos
Diazinon
Dimethoate
Endosulfan I
Endosulfan II
Malathion
Oryzalin
Oxyfluorfen
Permethrin
Vapam
Removal
By
Microfiltration
(%)
>88.89
NR
>83.81
>61.52
>99.91
>99.75
>96.58
NR
38.05
>55.97
NR
Removal
By
Activated
Carbon
ND
>98.21
99.93
ND
ND
ND
ND
>99.94
98.87
>99.80
>93.48
Overall
Removal
>99.89
>84.84
>84.84
>99.96
>99.99
>99.99
>99.99
>99.83
99.16
>99.90
96.78
NOTES:
ND = PAI concentration below detection limit in influent
stream.
NR = No removal
Calculated, percent removals not corrected to reflect
significant figures.
Some of the more water soluble PAIs, such as Vapam®, showed
little or no removal through the microfiltration unit. However/
Chlorpyrifos, oryzalin, oxyfluorfen, permethrin, Vapam® had one or
more day where negative removal occurred, which significantly
lowered the average mircrofiltration removal. For example, when
only looking at Days 1 and 2, both Chlorpyrifos and permethrin had
average microfiltration removals in excess of 96 percent.
Microfiltration, as with ultra-filtration, is not effective for
7-41
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removing dissolved PAIs; however, due to the hydrophobia nature of
many PAIs, the PAIs adhere to suspended solids in the wastewater,
and these solids are effectively rejected by the microfiltration
unit. Carbosulfan, diazinon, dimethoate, endosulfan I and II and
malathion were all removed to below detection limits by the
microfiltration unit.
Microfiltration was also effective at reducing the
concentration of oil and grease and TSS in the wastewater. The 3-
day removal of oil and grease through microfiltration was >77%
with a removal greater than 93 percent on Day one. Over the three
day sampling episode, no removal of TSS occurred on Day 3 but a 2-
day average removal of >64%" through microf iltration was achieved.
The microfiltration unit was followed by an activated carbon
unit. Activated carbon was effective at reducing the
concentrations of PAIs remaining in the wastewater following
microfiltration by more than 90% (in most cases, by more than 98
percent). The overall performance of the microfiltration system
followed by activated carbon achieved PAI removal efficiencies
greater than 99%, with the exceptions of chlorpyrifos, diazinon
and Vapam®.
The microfiltration unit followed by activated carbon showed
better PAI removal than the multimedia filter followed by
activated carbon. As stated above, the process wastewater
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treatment system is intended to treat for reuse, whereas, the
other system pretreats precipitation prior to discharge to a POTW.
This difference means that the process wastewater treatment system
must have high PAI removals, while the other system must only meet
the POTW's pretreatment levels. This facility does not discharge
the process area wastewater to the POTW because the POTW requires
they meet drinking water standards (which they do not feel they
can do consistently). Also, because one system is treating
process wastewater while the other is treating non-process area
precipitation. The influent levels to the process wastewater
treatment system are much higher than those of the non-process
area precipitation system. An average PAI concentration of 45,000
Jig/L was present in the process wastewater influent versus an
average PAI concentration of 25 Jlg/L in the non-process area
precipitation influent. Also, the detection limits are often
lower for the non-process area precipitation because the matrices
are less complex; therefore, removals are not always shown below
detection.
The fifth system that was sampled is very similar to the
process wastewater treatment system mention above. It consists of
a cross-flow filtration (microfiltration) unit followed by
activated carbon. This unit has a newer vertical design and
treated smaller batches (100- to 300-gallons) of wastewater during
the sampling episode than the batches treated at the fourth
facility.
7-43
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EPA collected samples from this system during treatment of
three batches of process wastewater which were being treated for
reuse. The samples taken during this sampling episode were
analyzed for the following PAIs: benthiocarb, bromacil, diuron,
tebuthiuron and terbufos. The percent of PAI removed during
treatment is presented below for both the individual unit
operations and the overall system (Note: the performance data for
this system are presented as averages of the three treatment
runs).
Table 7-7
PAI Percent Removals Achieved for the Fifth
System
PAI Name
Benthiocarb
Bromacil
Diuron
Tebuthiuron
Terbufos
Removal By
Microfiltration
<%)
30.94
NR
NR
NR
NR
Removal By
Activated
Carbon
98.42
89.72
99.66
89.09
98.75
Overall
Removal
98.80
88.76
99.56
90.31
98.49
NOTES:
ND « PAI concentration below detection limit in influent
stream.
NR = No removal
Calculated percent removals not corrected to reflect
significant figures.
The results are oiven as 3-dav averaaes.
No removal was calculated for four of five PAIs through
microfiltration because negative removal occurred on at least one
day for each of these PAIs. When looking at individual daily
7-44
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removals, bromacil was removed at >40% on Day 3 and tebuthiuron
and terbufos had 2-day averages of 66.59% and 76.53%,
respectively. The activated carbon unit achieved removals in
excess of 89% for two of five PAIs and >98% for the other three
PAIs.
The performance data for the overall system show high PAI
removals (>98% for 3 of 5 PAIs). As with the other
microfiltration system, the unit performs relatively well at
removing TSS (51%) and oil and grease (26%).
EPA is continuing to explore the option of microfiltration or
ultrafiltration as an alternative to the chemical/thermal emulsion
breaking pretreatment step of the Universal Treatment System (see
Section 7.3 and 8 for details on the UTS) . EPA has also used
wastewater from this facility to perform an UF/RO membrane
separation bench-scale treatability test (see Section 7.3).
[Note: At present microfiltration and ultrafiltration are not part
of the UTS and have not been included in the compliance cost
estimates.]
The final system that was sampled uses a two-step system to
treat wastewater for reuse. The wastewater is first sent through
a flocculation and flash mixing unit and a lamella clarification
unit, primarily to reduce TSS. The majority of the clarified
wastewater is then recycled to the process areas for reuse. A
7-45
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portion of the clarified wastewater is periodically sent on to the
second part of the treatment system, biological treatment. The
biological treatment system consists of two bioreactors
(Bioreactor A and Bioreactor B), operated in parallel. The
bioreactors are designed primarily to reduce the concentration of
2,4-D, as well as other PAIs and semi-volatile organic compounds
in the wastewater prior to reuse in the facility-wide scrubber
system.
During the sampling episode the facility was
7-46
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producing pesticide products containing the following PAIs:
atrazine, 2,4-D, diazinon, dicamba and MCPP. The percent PAI
removed during treatment is presented below for each treatment run
sampled from both systems. Averages of PAI removals for each
system are also presented below:
Table 7-8
PAI Percent Removals Achieved by the Clarification
System and the Biological Oxidation System at the
Final Facility Sampled
PAI Name
Atrazine
2,4-D
Diazinon
Dicamba
MCPP
Atrazine
2, 4-D
Diazinon
Dicamba
MCPP
% ' Removal
Day 1
12.23
NR
18.83
NR
NR
% Removal
Bioreactor
A
24.65
>99.86
>89.94
27.40
99.70
Clarification
% Removal
Day 2
NR
NR
26.64
NR
0.64
Biological
% Removal
Bioreactor B
Batch 1
4.04
>99.45
>61.37
NR
99.97
% Removal
Day 3
NR
43.11
37.56
28.74
58.30
Oxidation
% Removal
Bioreactor B
Batch 2
0.53
>99.31
94.76
NR
99.95
Average
Removal ( % )
3.01
NR
27.68
NR
2.01
Average
Removal (%)
9.74
>99.54
>88.02
NR
99.87
NOTES:
ND = PAI concentration below detection limit in influent
stream.
NR = No removal
Calculated percent removals not corrected to reflect
significant figures.
7-47
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As mentioned earlier, the clarif ier system may remove the
less water soluble constituents which adhere to other solids
removed during clarification. As seen on the table above, on Day
1 the clarif ier achieved low removals of atrazine, while on both
Days 1 and 2 the clarifier achieved slight removals of diazinon
(22%) . However, the removal efficiencies for the PAIs through the
clarifier increased on Day 3 . Four of the five PAIs (excluding
atrazine) showed removals between 28% and 58%. (Note: the
influent levels of each PAI were similar from day to day, i.e.,
the concentration of atrazine on Day 1, Day 2 and Day 3 = 8800
In addition to PAI removals, the clarification unit was
effective at reducing the TSS in the wastewater (3-day average
>50%) . However, the unit showed little or no removal of oil and
grease, as well as other conventional and non-conventional
pollutants.
As discussed in Section 7.1, biological treatment is a
destruction technology in which toxic organic pollutants in
wastewaters are degraded by microorganisms. These microorganisms
oxidize soluble organics and agglomerate colloidal and particulate
solids. In general, biotreatment was effective in removing 2,4-D
(>99%), diazinon (82%), and MCPP (>99%). It is important to note
that this particular facility specifically operates the
biotreatment unit until 2,4-D concentrations are below 5 mg/L.
7-48
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Atrazine and dicamba were not effectively removed during
biotreatment at this facility. The removals of atrazine and
dicamba in Bioreactor A were approximately 25% and 27%,
respectively; however, in Bioreactor B, on both days 1 and 2,
there was either insignificant or no removal. This may be
explained by the differences in the time of aeration in the
reactors: 90 hours in A, 67 hours in Bdayl and 24 hours in Bday2.
The biological system achieved high removals of oil and
grease (94.04% removal on average) and moderate removals of other
conventional pollutants (BOD, COD, TOC, TSS and total cyanide) on
all three days. (Note: Inefficient solids settling may have
contributed to lower removals in general.)
7.2.2
of Treated Waafcewater-
As discussed in the previous section, five of the six
facilities sampled by EPA use their treatment system to produce
reusable water. The facilities may reuse the treated water for a
specific purpose such as rinsing raw material drums or as make-up
water in the air pollution control scrubber system. Facilities
may also use the treated water for washing floors in pesticide
production areas or elsewhere in the facility. Some facilities
may even use the treated wastewater by returning it to the
formulations. The following paragraphs discuss the ability of
7-49
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facilities to reuse treated wastewaters and the concentrations of
pollutants found in the reuse waters.
When sampling the five PFPR treat and reuse systems, EPA.
collected effluent concentration data on 23 different PAIs. EPA
compared these effluent concentrations to the effluent
concentrations used for these PAIs for the PFPR compliance cost
estimates. The effluent concentrations used in the costing effort
were derived from the pesticides manufacturing best available
technology performance long term average (LTA) concentrations.
Because not all 23 of these PAIs had BAT limitations promulgated
under the pesticide manufacturing rulemaking, data transfers were
used to provide LTAs for the PFPR costing effort.
As mentioned above, when costing the industry to comply with
the proposed regulation, EPA estimated achievable PAI effluent
concentrations from the Universal Treatment System (see Sections
7.3 and 8.4). For pesticide active ingredients (PAIs) that have
pesticide manufacturing limitations which are based on one of the
UTS technologies (i.e., activated carbon, hydrolysis, chemical
oxidation, chemical precipitation), achievable effluent
concentrations were based on LTA concentrations from data derived
from the development of the pesticide manufacturing effluent
limitations guidelines. When pesticide manufacturing limitations
existed but were not based on one of the four technologies
mentioned above, treatability data for one of the UTS technologies
7-50
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was used to back up the manufacturing LTA concentration. When
pesticide manufacturing limitations did not exist, EPA transferred
LTA concentration data within structural groups (using the highest
LTA in the structural group). When there was no LTA for any PAI
within a given structural group, EPA transferred the 90th
percentile highest LTA, which means that 90% of the PAIs with
manufacturing limits have LTAs less than the transferred limit.
For the purpose of comparing the 23 PAIs for which actual
PFPR treatment system effluent concentration data was collected to
the LTA concentration data estimated for each of these PAIs, EPA
used the LTAs presented in Table 7-9. In addition to the LTA
concentrations, the table lists the source of the LTA. As
mentioned in the previous paragraph, the table indicates whether
the data were derived from: (1) a pesticide manufacturing BAT
limitation; (2) a data transfer within the structural group; or
(3) a 90th percentile highest data transfer. For 13 of the 23
7-51
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Table 7-9
Achievable Effluent Concentrations Used for Estimating
Compliance Costs for PAIs from PFPR Sampling
PAI
2, 4-D
Atrazine
Bromacil
Carbaryl
Carbosulfan
Chlorpyrifos
Diazinon
Dicamba
Dimethoate
Disulfoton
Diuron
Endosulfan I
Endosulfan II
Malathion
MCPP
Oryzalin
Oxyfluorfen
Pendimethalin
Permethrin
Prometon
Tebuthiuron
Terbufos
Vapam.
Estimated LTA
Concentration
Used for
Costing
(mg/L)
0.0020
0.0111
0.4310
0.0714
0.0085
0.0056
0.0319
0.0026
0.0072
0.0100
0.0152
0.0127
0.0127
0.0034
0.0020
0.2000
0.2000
0.0107
0.0003
0.0882
0.0040
0.0080
0.2000
Source of
Concentration Data
Pesticide Manufacturing BAT
Pesticide Manufacturing BAT
Pesticide Manufacturing BAT
Transfer within structural group
Transfer within structural group
Pesticide Manufacturing BAT
Pesticide Manufacturing BAT
Transfer within structural group
Transfer within structural group
Pesticide Manufacturing BAT
Pesticide Manufacturing BAT
Transfer within structural group
Transfer within structural group
Transfer within structural group
Transfer within structural group
90th percent ile highest transfer
90th percentile highest transfer
Pesticide Manufacturing BAT
Pesticide Manufacturing BAT
Pesticide Manufacturing BAT
Pesticide Manufacturing BAT
Pesticide Manufacturing BAT
Transer within structural group
7-52
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PAIs, EPA used LTA concentrations from pesticide manufacturing BAT
limitations. EPA transferred the highest LTA concentration within
the structural group for eight of the 23 PAIs. For the remaining
two PAIs, the 90th percentile highest data transfer was used.
EPA believes that costing PFPR facilities to achieve
manufacturing limitations for the purpose of reusing their
wastewater to be an accurate, if not conservative, approach. As
••this discussion will demonstrate, there are examples of facilities
that have been able to reuse wastewaters at concentrations that
are higher or approximately equal to the LTA concentrations that
were used in the costing effort. There are also examples of the
PFPR treatment systems reducing PAI concentrations below the LTA
concentration of the pesticide manufacturing best available
technology performance. A discussion on the comparison of
achievable effluent concentrations from EPA's sampling program
versus the LTA concentration data used for costing purposes is
presented in the following paragraphs. Table 7-10 presents both
the achievable effluent concentrations from EPA's sampling program
and the estimated LTA concentration data used for costing
purposes. The sampling data are presented for each episode where
the PAI was detected and may represent the average of multiple
days of sampling for a particular episode. Actual effluent data
from a particular episode have been categorized as either greater
than the estimated LTA used for costing purposes or within the
same range or less than the estimated LTA. [Note: During some
7-53
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assumption that treatment systems used by PFPR facilities perform
well (i.e., can achieve the manufacturing BAT LTA concentrations)
and that this water can then be reused.
The remaining PAIs fell into a third scenario. EPA found
that for bromacil, chlorpyrifos, disulfoton, endosulfan I,
endosulfan II, oryzalin, oxyfluorfen, pendimethalin and prometoh
the PFPR treatment systems were achieving effluent concentrations
kthat were lower than the estimated LTA concentrations. This
difference may be due to the wastewater matrices associated with
PFPR wastewaters being more conducive to treatment by the
Universal Treatment System, or that the use of ultraf iltration
followed by activated carbon may be better suited to handle these
wastewaters, especially on a batch basis, and prepare them for
reuse .
Even when treat and reuse systems reduce PAI concentrations
to very low levels, they may not be as efficient at reducing other
pollutants. However, many of these facilities still reuse the
treated water with relatively high levels of conventional
pollutants, COD (non-conventional) or acetone1. Therefore, in
addition to analyzing the concentration of PAIs in reuse waters,
Acetone is a volatile organic pollutant and is often found in pesticide
formulating and packaging wastewaters, particularly, following activated
carbon treatment. (When activated carbon is nearing saturation, it may
selectively desorb pollutants in order to adsorb other pollutants for which it
has a greater affinity.) Acetone is believed to be a common contaminant in
isopropyl alcohol which is often used as a solvent or for cleaning in PFPR
facilities .
7-56
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EPA looked at the following pollutants: COD, oil and grease, TOC
and acetone.
The following figures (7-1 through 7-4) display the
concentrations of these pollutants found in PFPR wastewaters
following treatment in the treatment and reuse systems discussed
in Section 7.2.1. [Note:. The data from one facility (Facility F)
that has a treat and reuse system is not represented on the bar
graphs. This facility uses a two part system consisting of
clarification for reuse followed by biological oxidation for
reuse. The concentration data from this facility were of a
different order of magnitude than data from other facilities and
could not be presented on the same bar graph. The data from this
facility is discussed in the text.]
7-57
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7-61
-------
These figures demonstrate that PFPR facilities can reuse
their wastewaters following treatment although the concentrations
are above non-detect levels. As with the PAIs, some systems
achieved very low effluent concentrations while others did not.
Regardless, all the these facilities do reuse their treated
wastewaters.
As shown by Figure 7—1, oil and grease (O&G) effluent
concentrations are generally very low, i.e., less than 1 mg/1.
However, one facility (Facility E in Figure 7-1) uses a
microfiltration system followed by activated carbon unit and
achieves an O&G effluent concentration as high as 62 mg/1. This
facility reuses its wastewater for general facility cleaning.
Also, Facility F (not shown on the bar graph) has average O&G
effluent concentrations of 320 mg/1 and 39 mg/1 through the
clarification unit and the bioreactors, respectively.
In terms of chemical oxygen demand (COD), the concentrations
fall between 750 mg/1 and 1500 mg/1 (Figure 7-2). However, at one
facility that uses a ultrafiltration system followed by activated
carbon, EPA measured the COD in the treated effluent to be at
approximately 2,550 mg/1. This facility reuses their water in the
facility wherever it's needed. In addition the facility that does
not appear on the bar graph (Facility F) had an average COD
effluent concentration of 12,000 mg/1 from the clarifier and an
7-62
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average COD of 5,325 mg/1 from the bioreactors. Again, this
facility is able to recycle the clarified water back to the
production areas for reuse and to reuse the water that was treated
through the bioreactors in the facility-wide scrubber system.
As shown by Figure 7-3, TOC effluent concentration generally
falls between 250 mg/1 and 700 mg/1. However, one facility which
uses an ultrafiltration system followed by activated carbon is
able to reuse their wastewater with TOC levels at 1500 mg/1. in
addition, Facility F reuses its treated wastewater with average
TOC effluent concentrations of 4,065 mg/1 and 1,650 mg/1 from the
clarification unit and from the bioreactors, respectively.
Finally, as shown in Figure 7-4, the concentrations of
acetone in the reuse water fall over a large range. The bar graph
uses a logarithmic scale in order to present all the data on one
figure. The concentrations approximately range from 50 M-g/1 to
9,000 ^lg/1. However, one facility (Facility B in Figure 7-4),
which uses ultrafiltration followed by activated carbon
adsorption, is able to reuse their wastewater with 65,600,000
M-g/1. Acetone was not detected in the reuse water at Facility F.
In summary, EPA believes that treatment systems, specifically
those meant for treat and reuse, at PFPR facilities are able to
reduce the concentrations of pollutants in PFPR wastewaters to
reusable levels. For the PAIs, these reusable levels are
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typically in the same range as the long term average
concentrations (derived from the pesticide manufacturing BAT long
term average concentrations) used for estimating compliance costs
for the PFPR facilities. However, as demonstrated by the data in
Table 7-10, facilities have still been able to reuse treated
wastewaters even though the PAI concentrations in those waters are
high when compared to LTA concentrations used for costing.
Facilities are also able to reuse these treated wastewaters when
the concentration of conventional pollutants and/or COD are not
reduced below detection.
7.3
TREATABILITY STUDIES
As part of EPA's data gathering effort (discussed in Section
3.1.6) EPA conducted a number of bench-scale studies to evaluate
the treatability of pesticide containing wastewaters by various
treatment technologies. The purpose of these studies was to
expand the treatability information available on various pesticide
active ingredients in order to verify the effectiveness of a given
technology on PFPR wastewater matrices and to evaluate the ability
of some technologies to allow for recovery of product. Included
in these studies, is a bench-scale study of a treatment system
that will be referred to as the "Universal Treatment System"
(UTS). Detailed discussions of these treatability studies are
presented in the following paragraphs. Many of the studies tested
treatment systems rather than individual treatment technologies.
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Therefore, the discussions are set up on a study-by-study basis,
as opposed to a technology-by-technology basis (except for the
initial discussion involving a membrane separation study conducted
as part of the pesticide manufacturing rulemaking).
Membrane Separation
Prior to any treatability work in support of the PFPR
**effluent guidelines, a pesticide manufacturing bench-scale
treatability study was conducted. This study evaluated seven
different types of reverse osmosis . (RO) membranes using two
synthetic feed solutions containing 19 different PAIs. This study
concluded that the best overall performance was obtained with a
thin film composite (TFC) membrane. The test results are
summarized in a July 1991 report entitled "Membrane Filtration
Treatability Study."
A follow-up study was conducted to evaluate RO treatment
using actual wastewater generated by a PFPR facility. This study
used a bench-scale RO module to determine if membrane separation
technology could be used to create a high quality water stream
(permeate) suitable for reuse from raw PFPR wastewater. This
study measured removals for 9 PAIs. Although the technology
produced a "clean" permeate stream, there were membrane fouling
problems. It was recommended that prefereatment technologies
should be evaluated to reduce suspended solids and oil and grease
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in PFPR wastewaters to a concentration acceptable for long-term RO
membrane operation. The test results are presented in a report
entitled "Bench-Scale Membrane Treatability Study, Pesticide
Formulating, Packaging and Repackaging Industry, 1993."
A third RO membrane bench-scale treatability study was
performed using actual wastewater from two different PFPR
facilities ("Site" A and "Site B"). However, this test
incorporated the recommendations of the previous test and included
a pretreatment step prior to the reverse osmosis step. Two
different pretreatment systems were tested: ultrafiltration (UF)
and chemical precipitation. Therefore, one set (one run for Site
A and one for Site B) of tests consisted of ultrafiltration
followed by reverse osmosis, while the other set consisted of
chemical precipitation jar tests followed by reverse osmosis. The
wastewaters from Site A contained the following PAIs: 2,4-D,
dicamba, MCPP and prometon. The wastewaters from Site B
contained: benthiocarb, bromacil, diuron, tebuthiuron and
terbufos. As part of this study, both the permeate and
concentrate streams were evaluated for reuse in the process or as
product.
As mentioned above, wastewaters from Site A and B were run
separately through the UF/RO setup. Two separate systems were
used for the ultrafiltration and reverse osmosis tests. The
bench-scale systems were designed to use commercially available
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ultraflitration and reverse osmosis equipment, while keeping the
size of the systems as small as possible. This design approach
was selected to provide results representative of a full-scale
system, while minimizing the amount of wastewater which had to be
collected, shipped, and ultimately disposed. The UF membrane used
for the bench-scale test was a tubular-type system. Tubular
membrane systems resist fouling better than either spiral wound or
hollow-fiber types. The RO module was a spiral wound
configuration, thin-film composite membrane and was the same
membrane type that was used in the previous EPA study.
The results of the UF/RO study show this treatment sequence
was effective in removing the nine PAIs present in the wastewaters
taken from the two PFPR facilities. In addition to high PAI
removal, ultrafiltration pretreatment prevented rapid fouling of
the RO membrane. Table 7-x presents a summary of the study
results for Site A and Site B.
For all but one of the nine PAIs (2,4-D, dicamba, MCPP,
prometon, bromacil, benthiocarb, diuron, terbufos and tebuthiuron)
better than 96% removal was achieved by the treatment sequence.
The removal for MCPP could not be calculated because the
concentration in the feed was below the analytical detection
limit. Data for bromacil indicate that overall it was reduced by
98.2%; however, this percent removal may misrepresent the
treatment performance because there is some indication the
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measurement of bromacil in the untreated wastewater was affected
by analytical interference. The system also achieved high
removals of total suspended solids and oil and grease. Removals
for TSS through the RO unit could not be calculated because the
ultrafiltration unit reduced the TSS, for both Sites A and B,
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Summary of
Table 7-11
Results for Membrane (UF/RO)
Treatability Study
Separation
Pollutant
Total Suspended Solids
Total Organic Carbon
Oil & Grease
Chemical Oxygen Demand
2, 4-D
Dicamba
MCPP
Prometon
Bromacil
Benthiocarb
Diuron
Terbuf os
Tebuthiuron
Removals by
Ultrafiltration (%)
Site A
98.2
20.2
59.4
23. 9
14.5
6.7
—
30.5
Site B
99. 9
29.8
89. 6
32.5
-
88. 6
37
99.8
49.1
Removals by Reverse
Osmosis (%)
Site A
M.
95.2
>98.1
96.1
99.4
99.5
99.5
Site B
97 . 1
>94.7
97.5
98.2
98 . 0
98.5
96.3
99.2
Note: Removals for MCPP and TSS (for RO only) could not be calculated
because the feed concentrations were below the analytical detection limits
for these pollutant parameters. Removal by ultrafiltration could not be
calculated for bromacil because the permeate concentration was greater
than the feed concentration.
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below the analytical detection limit. The average removal of TSS
achieved by the ultrafiltration unit was 99.05 percent. The UF/RO
system achieved an average oil and grease removal of >96.4
percent.
: The UF/RO treatment sequence appears to be a very effective
alternative to the Universal Treatment System, at least for high
molecular weight PAIs, to achieve a treated water that can be
reused in the facility. It is less clear whether the concentrated
waste created by either of these treatment steps can be recovered
for its product value. The samples taken from the concentrate
fraction show high concentrations of the PAIs, however, there are
also high concentrations of sodium, calcium and total dissolved
solids which could prevent the recovery of these wastes.
In addition to the treatability study on UF/RO, EPA performed
wastewater sampling on one UF/RO system and two microfiltration
systems (see Section 7.2). One of the microfiltration systems is
operated at one of the PFPR facilities used for the treatability
study. In an effort to use the full-scale system as a benchmark
for the bench-scale system, EPA collected water containing the
same PAIs for the treatability test as were present in the
treatment performance sampling episode. The treatment performance
data of the bench-scale versus full-scale systems are compared in
the discussion below.
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The UF/RO bench-scale system performed slightly better than
the full-scale microfiltration/AC system at removing bromacil
(98.2% vs. 89.7%) and tebuthiuron (99.2% vs. 89.1%). However, the
opposite is true for benthiocarb (98.0% vs. 98.4%), diuron (98.5%
vs. 99.7%) and terbufos (96.3% vs. 98.8%). The bench-scale UF/RO
performed better at removing oil and grease (>94.7% vs. 26.0%) and
TSS (99.9% vs. 51.0%) than the full-scale system. As demonstrated
by the data presented above, the bench-scale DF/RO pollutant
removals are consistent with removals achieved by the full-scale
membrane separation system.
As an alternative to ultrafiltration, EPA tested chemical
separation as the pretreatment step to the RO module. A series of
jar tests were conducted to evaluate different coagulants and to
establish an optimum dosage. Coagulants that were evaluated
included alum, lime and ferric chloride. Polymer additions were
also evaluated as a means of improving the effluent quality.
Among other things the results showed that the ultrafiltration was
the more effective pretreatment step for removing oil and grease
(O&G) . The O&G removal by physical chemical treatment was 37.6%,
while 59.4% was removed by ultrafiltration. However, the removal
of TSS was high for both physical/chemical (96.4%) and
ultrafiltration (98.2%). in addition, physical/chemical
pretreatment was slightly more effective than ultrafiltration in
removing most PAIs, with the exception of 2,4-D for which the
removals were comparable. This difference is most likely due to
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the fact that ultrafiltration membrane, due to their high
molecular weight cutoff, are not designed for PAI removal.
However, good removals of TSS and O&G can be achieved with
ultrafiltration, making it an attractive pretreatment option.
As mentioned above, the performance achieved by the UF/RO
system as a whole and the UF alone as a pretreatment step make
them very attractive as an alternative treatment system to the
more conventional physical/chemical treatments. Identification of
UF/RO as "BAT" technology may be given more serious consideration
for the final rule. A fully detailed description of the tests and
the results can be found in a report entitled "Membrane Separation
Study for the Pesticide Formulator Packager Project."
Pydrolysis and Activated Carbon on Pyrethrins
The treatability of combined pyrethrin (the sum of pyrethrin
I and pyrethrin II) in wastewater was investigated through
hydrolysis and activated carbon adsorption bench-scale testing.
Pyrethrin-containing wastewater from a pesticide manufacturing
facility was used for the bench-scale tests. A full description
of the tests and results can be found in a report entitled
"Pyrethrin Wastewater Treatability Study Report."
The effectiveness of hydrolysis treatment on pyrethrin-
containing wastewater was evaluated through bench-scale testing
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under two hydrolysis conditions, alkaline (pH 12) and acidic
(pH 2) . Both the pH 12 and pH 2 runs were conducted at a
temperature of 60°C. In brief, the test results are as follows:
At an elevated temperature (60°C), pyrethrin hydrolyzes more
rapidly under alkaline conditions, with a calculated half-life
value of 1.2 'hours at pH 12. Under the acidic conditions, the
calculated half-life was 77 hours at pH 2.
Tests were also conducted on the pyrethrin-containing
wastewater to determine the effectiveness of pyrethrin removal
through carbon treatment. Six different carbon dosages were
tested to develop a carbon isotherm for pyrethrin. The tests
showed that the treatment of pyrethrin-containing wastewaters with
activated carbon requires high carbon dosage rates, a 5,000 mg/L
carbon dosage resulted in a reduction of combined pyrethrin from
100 mg/L to less than 1.0 mg/L. This means that with a 10 gallon
per minute flow rate, the carbon column would have a service life
of 11.4 days for combined pyrethrins at 110 mg/L initial
concentration. Therefore pyrethrins are adsorbed by the activated
carbon column, however, the test results show that the more
practical treatment technology (first step) for treating pyrethrin
containing wastewaters is hydrolysis.
Treatment
PFPR facilities often generate wastewater on multiple
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production lines. Because the wastewater volumes are usually
small, however, it is not practical to operate dedicated
wastewater treatment systems to serve individual lines.
Recognizing the need for operational simplicity, EPA believes that
centralized wastewater treatment is more appropriate and has
conceptualized a single BAT treatment system for PFPR facilities
that the Agency is terming the "Universal Treatment System." As
envisioned by EPA, the Universal Treatment System (UTS) would be
sized to handle small volumes of wastewater on a batch basis and
would combine the most commonly used treatment technologies for
pesticide active ingredients, hydrolysis, chemical oxidation,
activated carbon and sulfide precipitation (for metals), with one
or more pretreatment steps, such as emulsion breaking, solids
settling, and filtration (see Section 7.1 for discussion on
treatment technologies). The BAT performance of the pesticide
active ingredient treatment technologies is well demonstrated and
they serve as the full or partial basis for most of the
manufacturers' active ingredient limitations2. EPA believes that
the UTS, relying on these treatment technologies, can provide
treated effluent suitable for reuse in PFPR operations with
respect to all PAIs. (See .Section 7.2.2 for discussion on
pollutant concentrations in reuse water).
Treatment systems similar to the Universal Treatment System
2Sulfide precipitation is not the basis of the recently proposed
pesticide manufacturing limitations because EPA deferred setting limitations,
beyond BPT, for the organo-metallic subcategory (40 CFR 455, Subpart B) .
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are in operation at PFPR facilities that are currently reusing
treated wastewater. These facilities employ activated carbon as
the primary active ingredient treatment step, usually following
solids settling or filtration pretreatment steps and achieve
between 98 and 99 percent removal of the active ingredient
constituents in most cases (see Section 7.2 for treatment
performance data achieved by such systems).
The Agency has developed an active ingredient treatability
dataset, based on full-scale treatment system data, treatability
study information, and data transfers, that show that all of the
272 active ingredients originally considered under this rulemaking
are amenable to one or more of the UTS treatment technologies (see
Appendix H). For some active ingredients, a different treatment
technology, such as resin adsorption or solvent extraction, may
have served as the basis for manufacturers' limitation because it
was in use at a given facility and judged to represent BAT
performance based on monitoring data. In some cases, the use of
these types of technologies, rather than the UTS, might be more
appropriate at a PFPR facility if the facility is only handling an
active ingredient that requires that technology. The wastewater
matrix at PFPR facilities, however, may be more complex than the
manufacturer's wastewater containing the same active ingredient,
and therefore the treatment technologies identified as BAT for the
manufacturers' limitations may not achieve the same levels of PAI
removal without substantial pretreatment to remove
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emulsifiers/surfactants. In addition, for most PFPR facilities,
the commingled wastewater will contain multiple active
ingredients. EPA finds that all of these PAIs will be amenable to
the more common treatment technologies comprising the UTS for
purposes of removing the PAIs and other pollutants to levels that
would allow recycle or reuse at the facility. Furthermore, a
treatment system relying on a technology such as solvent
extraction to remove an active ingredient would still require
activated carbon polishing to adsorb other wastewater
constituents, including residual extraction solvent, before the
treated wastewater could be reused. Rather than attempting to
integrate these other technologies of resin adsorption, solvent
extraction or others into a centralized wastewater treatment
scheme, EPA believes that the Universal Treatment System offers a
more consistent, simple, and cost-effective design and, therefore,
represents the best available technology at PFPR facilities.
As stated above, EPA developed a treatability dataset for the
272 active ingredients in order to ensure that the Universal
Treatment System technologies will be effective in providing
treated effluent suitable for reuse. EPA evaluated full-scale and
bench-scale treatability data available for the 272 active
ingredients, including those where a different technology basis
was used to support the manufacturers' limitation. The Agency
also developed technical treatability data transfer methodologies
for the transfer of activated carbon adsorption and hydrolysis
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treatability data between structurally-similar active ingredients.
In determining the efficacy of the treatment technologies in
the UTS for the pesticide active ingredients in PFPR facility
wastewater, EPA also factored in the need for pretreatment steps.
PFPR facility wastewater may contain emulsifiers, surfactants,
solids, organic constituents in addition to the active
ingredients, and other pollutants that may interfere with active
ingredient removals across the treatment technologies. The Agency
examined existing PFPR facility treatment systems and a
vendor-supplied treatment system designed to be applicable at all
PFPR facilities. The Agency's concept of the Universal Treatment
System includes emulsion breaking, oil layer removal and off-site
disposal as a hazardous waste, solids separation and removal, and
removal of any remaining large particles by in-line strainers
prior to activated carbon adsorption (see Section 8.4 for the
engineering costs associated with the UTS).
Final effluent from the Universal Treatment System is
expected to be suitable for reuse as general pesticide production
area cleanup water. Based on the active ingredient treatability
dataset and information from PFPR facilities that treat and reuse
pesticide process wastewater, the Agency believes that Universal
Treatment System is applicable, and cost-effective, to all PFPR
facilities. Therefore, EPA is basing the treat and reuse portion
of the proposed zero discharge limitations (see Section 2.1) on
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the UTS. Accordingly, the best available technology identified by
EPA for this proposal for the purpose of setting PSES standards
consists of recycle/reuse practices, preceded by treatment with
the UTS where necessary. Application of this BAT will enable all
PFPR facilities to achieve the zero discharge requirements
contained in the proposal.
The UTS bench-scale study was initiated in order to provide
data on the feasibility of merging the UTS unit operations into
one system and was evaluated by testing both synthetic (or clean
water) and actual PFPR wastewaters. Four PAIs were spiked into
clean water to make a synthetic wastewater for initial testing to
determine if the UTS effectively removes PAIs. The four PAIs were
bromacil, tebuthiuron, propoxur and diuron. These PAIs were
selected based on what was expected in the actual facility
wastewaters that were to be collected. The synthetic wastewaters
went through the following treatment steps: hydrolysis, chemical
oxidation via ozone/ultraviolet light oxidation and activated
carbon adsorption. The emulsion breaking step was not performed
on the synthetic wastewaters because these waters consisted only
of PAIs and water and, therefore, did not contain emulsions.
The second set of PAIs tested were contained in an actual
PFPR facility wastewater. The PAIs included: benthiocarb,
bromacil, diuron, tebuthiuron and terbufos. The purpose of this
set of tests was to determine if the UTS effectively removes PAIs
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and other organic pollutants present in actual PFPR wastewaters
(i.e., those with potential matrix interference problems). The
wastewater went through the following treatment steps: emulsion
breaking by coagulation, pH adjustment, flocculation and settling;
hydrolysis, chemical oxidation via ozone/ultraviolet light
oxidation and activated carbon adsorption. In addition, as a
separate aspect of the evaluation, the adsorption properties of
these 5 PAIs were determined using accelerated column tests (ACT).
These bench-scale (ACT) results are used to estimate. full-scale
carbon system performance, design and costs.
The last set of wastewaters tested in the UTS was also actual
PFPR facility wastewaters and contained both allethrin and
permethrin. These wastewaters were treated by the UTS using
emulsion breaking, hydrolysis and activated carbon adsorption.
Based on results from the previously conducted "Pyrethrin
Wastewater Treatability Study," EPA assumed that the pyrethrins
were amenable to hydrolysis treatment and, therefore, did not
require the chemical oxidation step of the treatment train.
The treated effluent was analyzed for pesticide active
ingredients (PAIs), volatile and semi-volatile organics, and other
wastewater parameters such as total organic carbon (TOC), oil and
grease, and turbidity. A brief description of the test results is
provided in the following paragraphs.
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Bench-scale test results using the PFPR wastewater generated
at Facility A indicate the concentrations of the target pesticide
active ingredients (bromacil, tebuthiuron, diuron, terbufos, and
benthiocarb) can be reduced to less than their analytical limit of
detection (>99.99% removal) by chemical assisted clarification
(i.e., emulsion breaking), Ozone/UV light oxidation and activated
carbon adsorption. Chemical assisted clarification, using ferric
chloride and a polyelectrolyte, removed turbidity, a major portion
• of the oil and grease and some TOG. Bench test data showed that
the PAIs were oxidized using a continuous ozone dosage of 76
mg/L/minute at a UV intensity of 3 W/L. The overall TOG, COD, oil
and grease and TSS removals achieved for Facility A were: 36.2%,
30.5%, >99.5% and 99.2%, respectively.
Oxidation converted a portion of the soluble organics in the
Facility A wastewater into insoluble precipitates which required a
second chemical assisted clarification prior to carbon adsorption.
Results of carbon isotherm tests and a carbon adsorption column
test indicate oxidation generates short chained organic acids and
alcohols which are poorly adsorbed on carbon. This results in a
TOC concentration of 6,000 mg/1 in the final effluent.
Bench-scale test results for a PFPR wastewater collected at
Facility B indicate chemical assisted clarification using ferric
chloride and a polyelectrolyte removes the majority of allethrin
and permethrin, oil and grease and turbidity. Alkaline hydrolysis
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at pH 12 and 60°C followed by carbon adsorption decreased the
concentrations of allethrin and permethrin to less than their
analytical limit of detection (>99.99% removal). Carbon
adsorption effluents contained approximately 800 mg/L of TOC, of
which nearly 60 percent was derived from isopropyl alcohol.
Isopropyl alcohol is a solvent used to clean equipment in the PFPR
facility. The overall TOC, COD, oil and grease and TSS removals
achieved for Facility B were: 84.8%, 79.1%, 98.0% and 83.2%,
respectively.
Detailed results of this treatability test can be found in a
report entitled « Evaluation of the Universal Treatment System for
Treatment of Pesticide Formulator/Packager Wastewater."
7.4
POLLUTION PREVENTION, RECYCLE/REUSE PRACTICES
In developing these guidelines and standards, EPA has
addressed the Pollution Prevention Act of 1990. Under this Act,
Congress established a national policy to prevent or reduce
pollution at the source whenever feasible. This policy is
referred to as pollution prevention, or source reduction, and may
include in-process recycling practices. The following guidelines,
known as the environmental management hierarchy, were set to
implement the pollution prevention policy: pollution should be
prevented or reduced at the source whenever feasible; pollution
that cannot be prevented should be recycled or reused in an
environmentally safe manner whenever feasible; pollution that
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cannot be prevented or recycled should be treated in an
environmentally safe manner whenever feasible; pollution should be
disposed or released into the environment in an environmentally
safe manner only as a last resort.
As discussed in Section 2.0, this proposed regulation sets
zero discharge for PFPR and PFPR/Manufacturers and for refilling
establishments. However, for small sanitizer3 facilities (a
segment of Subcategory C) zero discharge has been set only for the
interior process wastewater sources; therefore, these facilities
are exempt from the zero discharge requirement for non-interior
process wastewater sources. Under the proposed regulation the
exterior wastewater sources will be exempt from regulation (see
Section 12 for basis of exemption). The focus of the basis for
this proposed zero discharge regulation is pollution prevention
(P2), reuse and recycle. Both raw material and water conservation
can fall under the heading of pollution prevention, reuse and
recycle and both are discussed throughout this section. In
addition to describing these pollution prevention, recycle/reuse
and water conservation practices, EPA has also estimated the
savings that might be realized due to water savings and product
recovery associated with these practices (see Economic Impact
Analysis Report for detailed discussion).
3Sanitizer facilities only benefit from the exemption if they formulate,
package or repackage 265;000 Ibs/yr or less of all registered products
containing specified (see Table 12-2) sanitizer active ingredients and no
other active ingredients at a single pesticide producing establishment (i.e.,
a single PFPR facility).
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In this section EPA has noted the cases in which media
transfers may .occur as a result of using certain methods that have
less impact on water. This notation illustrates EPA's interest in
beginning to take a more wholistic, multimedia view of our rules.
Although the use of some methods may reduce the impact to water,
these methods may not, when considered from a multimedia
perspective, lead to an overall environmental improvement.
Facilities contemplating use of any of the methods which may
result in media transfer need to carefully weigh the trade-offs
before a decision is made.
EPA would like to note that it recognizes that source
reduction in the context of pesticide use generally has other
important components. These include improving efficiency in
pesticide production and formulating processes, improving
application efficiencies, encouraging integrated pest management
and low input sustainable agricultural practices, and encouraging
the use of safer pesticides when pesticides are necessary.
Currently, EPA is pursuing efforts in these other areas. For
example, the Office of Pesticides Programs' Notice of Proposed
Rulemaking on pesticide containers and containment (February 11,
1994; 59 FR 6712) which proposes to reduce the numbers of
pesticide containers needing disposal by setting standards and
guidelines for the use of refillable containers.
The following sections provide: a brief discussion on the
pollution prevention data gathering efforts, a general description
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of pollution prevention, recycle and reuse practices that are
widely practiced in this industry, a description of the process
wastewater sources, a discussion on how to apply pollution
prevention, recycle/reuse techniques to these wastewater sources
and specific examples of exemplary and/or creative pollution
prevention, recycle and reuse practices.
7.4.1
Pollution Prevention Data Gathering Efforts
EPA has been gathering technical data on the PFPR industry,
including descriptions of pesticide production processes, water
usage, and water treatment from several sources.
As described in Section 3.1, EPA distributed questionnaires
to selected facilities identified as pesticide formulators,
packagers, and/or repackagers. These questionnaires were intended
to survey 1988 pesticide formulating, packaging and repackaging
operations and water use (including reuse and recycle practices)
at the selected facilities. Information was also collected through
follow-up telephone calls and written requests for clarification
of questionnaire responses.
An additional source of information is the trip/site visit
reports. Between 1989 and 1993, EPA visited approximately 50 PFPR
facilities in order to gather information on production processes
and pollution prevention techniques employed by these facilities,
as well as information pertaining to wastewater generation,
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treatment, and disposal..
EPA also conducted telephone follow-up calls to obtain
clarification of the information submitted in the 1988
questionnaire by 43 PFPR facilities that reported transporting any
PFPR wastewater off site for disposal. These questions focused on
the type of hazards present in PFPR wastewaters that are disposed,
and the methods employed to minimize generation of these
wastewaters. A more complete discussion of these facilities is
presented in the January 6, 1993 memorandum entitled "Summary of
Practices at Contract Haul Facilities."
7-4-2 Pollution—Prevention and ReeVf!l*»/Reiig«»
Found at PFPR
The PFPR industry employs many pollution prevention, recycle
and reuse practices. Wastewaters generated at these facilities
are mainly generated by cleaning the PFPR production areas and
associated equipment. Because the wastewaters are cleaning
rinsates and are not, for example, waters of reaction, the
pollution prevention practices are not as process specific as they
are in the Pesticide Manufacturing Industry. Therefore, the
Agency has been able to identify pollution prevention,
recycle/reuse practices that are widely accepted and practiced by
this industry. It is the Agency's opinion that some or all of
these practices can be implemented at all PFPR facilities.
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These pollution prevention, recycle and reuse practices fall
into three groups: actual production practices, housekeeping
practices, and practices that employ the use of equipment that by
design promote pollution prevention. Some of these
practices/equipment listed below conserve water, others reduce the
amount of active ingredient or pesticide product in the
wastewater, while others may prevent the creation of a wastewater
altogether. (Please note: EPA does acknowledge that some of
these practices/equipment may lead to media transfers or increased
energy consumption.)
Production practices include:
• triple-rinsing raw material shipping containers
directly into the formulation
• scheduling production to minimize cleanouts
• segregating formulating/packaging equipment by:
- individual product
solvent- versus water-based formulations
product "families" (products that contain
similar PAIs in different concentrations)
• storing interior equipment rinsewaters for use in
future formulation of same product
• packaging products directly out of formulation
vessels
• using raw material drums for packaging final
products
• dedicating equipment (possibly only mix tank or
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agitator) for hard to clean formulations
Housekeeping practices include:
performing preventative maintenance on all valves,
fittings and pumps
placing drip pans under leaky valves and fittings
cleaning up spills or leaks in outdoor bulk
containment areas to prevent contamination of
stormwater
Equipment that promote pollution prevention by reducing or
eliminating wastewater generation include:
• low volume - high pressure hoses
• spray nozzle attachments for hoses
• squeegees and mops
low volume/recirculating floor scrubbing machines
portable steam cleaners
• drum triple rinsing stations (described later)
• roofs over outdoor tank farms
A description of how these pollution prevention,
recycle/reuse and water conservation are applied by formulating,
packaging, repackaging facilities is provided in Section 7.4.4.
7 • 4 • 3
of Process
L£S
Process wastewater is defined in 40 CFR 122.2 and in the PFPR
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questionnaire as "any water which, during manufacturing or
processing, comes into direct contact with or results from the
production or use of any raw material, byproduct, intermediate
product, finished product, or waste product." Ten specific
sources of PFPR process wastewater were reported in the facility
questionnaires as generated by PFPR facilities in 1988. They are:
Shipping Container/Drum Rinsate - water used to
rinse shipping containers for raw materials,
finished products, and/or waste products prior to
reuse or disposal of the containers;
• Bulk Tank Rinsate - water used to rinse bulk
storage containers for pesticide raw materials and
products;
• Interior Equipment Wash Water - water used to clean
the interior of any formulating, packaging, or
repackaging equipment such as:
Routine Cleaning - regular or periodic
cleaning of equipment interiors,
— Product Changeover Cleaning - cleaning due to
product changeover, which is defined as
changing from one pesticide product to either
another pesticide product, to a non-pesticide
product, or to idle equipment condition, or
— Special or Non-routine Cleaning - cleaning due
to situations which do not normally occur
during routine operations, such as equipment
failure or the use of binders, dyes, carriers,
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and other materials, which require additional
cleaning time or larger volumes of water;
Aerosol Container (DOT! Leak Test Water - water
used to perform aerosol leak tests for Department
of Transportation (DOT) requirements;
Wall, or Exterior Equipment Wash Water -
water used to clean floors, walls, and/or exteriors
of equipment at the PFPR facility;
Leaks and Spills Cleanup water - water used to
clean up leaks and spills which occur during PFPR
operations;
Air or Odor Pollution Control Scrubber Water -
water used in air emissions control scrubbers;
Safety Equipment Wash Wat-er - water used to clean
personal protective equipment such as gloves,
splash aprons, or air-purifying respirators worn by
employees working in PFPR operations;
Laboratory Equipment Wash Water - water used to
clean laboratory equipment associated with PFPR
operations; and
Contaminated Precipitation Runo-F-F - rainwater or
snow melt believed to be contaminated with
pesticide active ingredients.
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7.4.4 Applying Pollution Prevention — Practices
Secific Was "he water Sources
This section presents a stream by stream discussion of
pollution prevention (P2) , recycle/reuse and water conservation
practices in the PFPR industry. These practices have been
identified by EPA as effective in reducing the volume of
wastewater generated during PFPR operations and have been observed
in use at PFPR facilities, PFPR/manufacturing facilities, and
agrichemical dealers. Each of the ten sources of wastewater is
discussed and options are offered on how to reduce or reuse each
one. The discussions of applicable practices follow the pollution
prevention hierarchy developed by EPA — prevention, recycling,
treatment, and disposal or release. Minimization of the
wastewater generated for any stream is considered to be part of
the prevention step, since pollution is being prevented or reduced
at the source, as explained in Section 6602 (b) of the Pollution
Prevention Act of 1990.
7.4.4.1 Shipping Container/Drum Cleaning
PFPR facilities frequently receive pesticide raw materials in
containers such as 55-gallon steel or 30-gallon fiber drums. In
some cases, the empty drums are returned to the supplier, but
usually the PFPR facility is responsible for disposal of the
drums. The simplest, most cost effective and best approach for
the prevention of pollution used at many PFPR facilities is to
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rinse empty pesticide drums prior to disposal to capture PAI
residue for direct reuse in product formulations. The facility
not only eliminates a potential highly contaminated wastewater
source, but also is able to recover the product value of the raw
material .
Rinsing procedures for pesticide drums are provided in 40
mCFR, Part 165. The most common method of drum rinsing in the PFPR
industry is triple rinsing. After a drum containing pesticide
active ingredients or pesticide products is emptied it should be
triple rinsed with the solvent (organic solvent or water) that
will be used in the formulation. This prevents the creation of a
rinsate that cannot be added directly to the formulation (i.e., a
facility will not be able to reuse a water-based rinsate in the
formulation of a solvent -based product) .
Some facilities employ a high-pressure, low-volume wash
system equipped with a hose and a spray nozzle to triple rinse
drums; volumes of 5 to 15 gallons of water used per drum have been
reported. Although EPA has identified many facilities that reuse
these rinsates directly into product formulations, other
facilities treat and reuse drum rinsate for further drum or
equipment rinsing. if the rinsate cannot be reused directly into
product formulations, the Agency believes that one effective
pollution prevention/recycle technique for the shipping
container/drum cleaning process is the use of drum rinsing
stations to reduce wastewater generation.
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One of the facilities visited uses a three-cell station for
triple rinsing drums: using the first cell's water for the first
rinse, the second cell for the second rinse, and the third cell
for the final rinse. The rinse water in the first cell is reused
until it is visually too contaminated to be used further. At that
time, it is removed from the cell and the rinse water from the
second cell is transferred into the first cell. The rinse water
from the third cell is transferred into the second cell, and the
third cell is refilled with clean water. Each cell contains
approximately 100 gallons of water, and approximately 70 drums can
be rinsed before the first-cell requires water changing.
During another site visit a unique, closed-loop set-up for
emptying and triple rinsing raw material drums was observed.
The system was designed by the facility to: aid them in the
emptying of drums and performing the triple rinsing procedure,
eliminate the need for storage of the water (or solvent) for
reuse, and prevent mathematical errors by the operators during the
weighing out of raw materials and water (or solvent).
The system consists of two 55 gallon drums, a formulation
tank and connecting hoses. One of the drums is permanently fixed
on top of the formulation tank. The formulation tank and drum are
situated on a load cell (used for weighing) . Placed on the ground
next to the formulation tank is the second drum which contains raw
material and is still full. One hose is used to vacuum out the raw
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material and subsequent rinsate and transfer it to the drum on the
formulation tank/load cell. The other hose is equipped with a
doughnut shaped nozzle which provides the triple rinse by spraying
the interior of the now empty raw material drum. The rinsate that
is created by the triple rinse procedure is automatically sucked
out by the vacuum line and is transferred to the drum on the
formulation tank/load cell.
The load cell can be used to weigh the amount of raw material
and/or rinsate that is added to the formulation by zeroing out the
weight of the tank and drum. This allows the volume of both raw
material and rinse water (or solvent) to be factored into the
total volume of water (or solvent) required in the formulation.
The drum on top of the formulation tank is equipped with a spring-
loaded valve which enables the operator to take weight
measurements prior to emptying the contents of the drum into the
mix tank. This set-up has almost completely eliminated operator
math errors and related formulation specification problems.
It is the Agency's opinion that the best and most cost
effective way to eliminate rinsewater from raw material drum
cleaning is to triple rinse the residue directly into the
formulation being produced.
7.4.4.2 Bulk Tank Rinsate
PFPR facilities sometimes produce large quantities of
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formulated pesticide products and receive large quantities of raw
materials used to produce pesticide products which are stored on
site in bulk tanks. These tanks are typically rinsed only when it
becomes necessary to use the tank for storage of a different
material. For example, a facility may store bulk quantities of a
pesticide product used for soybean crops during the spring and
then switch in the summer to storing a pesticide product used for
corn crops. Each time the facility switches the product stored in
a bulk tank, the tank is rinsed. Bulk tanks are sometimes also
rinsed at the end of a season as a part of general maintenance
procedures.
Recovery of product value from bulk tank rinsates is a common
pollution prevention practice in the PFPR industry. Bulk tank
rinsates have been reused by some PFPR facilities into product
formulations and by some agrichemical facilities in commercial
application of pesticides (as make-up water). Facilities can
usually store this rinsate on site until the opportunity to reuse
it is available.
Another effective pollution prevention technique i.s to
minimize the amount of rinsate generated during bulk tank cleaning
by using high-pressure, low-volume washers. Some PFPR facilities
have also demonstrated that the use of squeegees reduces
wastewater generation during the cleaning of bulk tanks. The
smaller the volume of water needed to clean the bulk tank, the
more readily the entire volume can be recovered by adding to
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product or make-up in an application.
It is the Agency's opinion that the best and most cost
effective way to eliminate rinsewater from bulk tank rinsate is to
dedicate these tanks to specific raw materials or products. If
this is not possible then changeover should be minimized and the
rinsates should be stored for reuse in future formulations or for
make-up water in custom application.
7.4.4.3 Equipment Interior Cleaning
Formulated and packaged products may be either liquid
(including emulsifiable concentrates) or solid (dry). A liquid
formulating and packaging line often consists of mix tanks, melt
kettles (if necessary), transfer piping or hoses and pumps,
filters prior to packaging, and a packaging hopper and fillers
operating over a conveyor belt. A dry formulating and packaging
line often consists of crushing, pulverizing, grinding, and/or
milling equipment; blenders, screening equipment, and the
packaging equipment. Repackaging is often a simple process of
*
transferring material manually from one container into another of
different size. For both liquid and dry operations, the packaging
equipment is often portable.
PFPR facilities generally do not dedicate line equipment to a
specific product because most facilities produce many products
using the same equipment. Often the equipment is used for
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short-term production campaigns, and can be used for both
pesticide and non-pesticide products. To ensure product quality,
the production line equipment is normally cleaned between product
changeovers. Many facilities perform routine periodic cleaning of
production lines for maintenance and, on occasion, also perform
special or non-routine cleaning due to equipment failures or the
use of materials that require additional cleaning time or cleaning
solvents. Different types of lines (i.e., dry, liquid,
emulsifiable concentrates, etc.) require different cleaning
methods, such as water or solvent rinsing, flushing with solid
material, mechanical abrasion, or a combination of these
techniques.
Lines handling dry products are usually cleaned by flushing
with the solid, inert material (such as clay) used as the carrier
for the products handled on the line. EPA has observed this
practice at several facilities. It may be followed by rinsing
with water when additional cleaning is required. Liquid lines are
usually rinsed between changeovers with either water or an organic
solvent, depending on the production just completed and the
product to be produced next on the line. Water cleaning is also
performed for routine maintenance.
Changeover cleanings can be eliminated or greatly reduced by
dedicating equipment to specific products or groups of products.
Although entire lines are not generally dedicated, EPA is aware of
many facilities that dedicate formulation mix tanks, thereby
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eliminating one of the most.highly contaminated wastewater streams
generated at PFPR facilities. Facilities also dedicate lines to
the production of a specific product type, such as water-based
versus solvent-based products, thereby reducing the number of
cleanings required, and allowing for greater reuse of the cleaning
water or solvent.
Another effective pollution prevention technique identified
by EPA is the use of production scheduling to reduce the number of
product changeovers, which reduces the number of equipment
interior cleanings required. Facilities may also reduce the
number of changeover cleanings required or the quantity of water
or solvent used for cleaning by scheduling products in groups or
"families." Products may lend themselves to production sequencing
if they have common PAIs,, assuming the products also have the same
solvent base (including water). A product with a PAI, such as
MCPP can be followed by a product containing 2,4-D, MCPP and
dicamba. Where other raw material cross contamination problems
are not a concern, no cleaning would be required between
changeovers. Facilities that have implemented this technique have
conducted testing to ensure product quality is not adversely
affected.
Scheduling production according to the packaging type can
reduce changeover cleanings of packaging equipment. Packaging
lines are often able to handle containers of different sizes and a
slight adjustment to one packaging line, such as the addition of a
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short length of hose, may prevent the use of an entirely different
set of packaging equipment that would also require cleaning.
Packaging can also be performed directly out of the formulation
vessels, with or without the use of portable filling units, to
avoid the use and subsequent cleaning of interim storage tanks and
transfer hoses.
Another effective pollution prevention/water conservation
technique is to minimize the quantity of rinsewater generated by
equipment interior cleaning by equipping water hoses with
hand-control devices (for example, spray-gun nozzles such as those
used on garden hoses) to prevent free flow of water from
unattended hoses, and employing high-pressure, low-volume washers
instead of ordinary hoses. One of the facilities visited
indicated that the use of high-pressure washers reduced typical
equipment interior rinse volumes from 20 gallons per rinse to 10
gallons per rinse.
Steam cleaning can also be a particularly effective method to
clean viscous products that otherwise require considerable water
and/or detergent to remove. Many facilities have access to steam
from boilers on-site, however, if there is no existing source of
steam, steam cleaning equipment is available for purchase.
Although steam generation can increase energy consumption and add
NOx and SOx pollutants to the atmosphere, there are benefits to be
gained. Facilities may end up creating a much smaller volume of
wastewater and may potentially avoid the need to use detergents or
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other cleaning agents which could prevent product recovery. The
Agency cautions that steam could be a poor choice for cleaning
applications where volatile organic solvents or inerts are part of
the product as the steam would accelerate the volatization of the
organics.
Facilities also clean equipment interiors by using squeegees
to remove the product from the formulation vessel and by using
absorbent "pigs" for cleaning products out of the transfer lines
before equipment rinsing. These techniques minimize the quantity
of cleaning water required. Regardless of whether or not residual
product is removed from equipment interiors before rinsing,
equipment interior rinsate can typically be reused as makeup water
the next time that a water-based product is being formulated.
One facility that was visited by EPA employs a unique method
of cleaning to reduce the volume of water needed to clean
equipment interiors. At this facility the production lines are
,'
hooked to dedicated product storage tanks. Prior to rinsing these
production lines, the facility uses air to "blow" the residual
product in the line back to product storage. Not only will these
lines require less water to get them clean/ but the residual
product that is blown back to storage is not diluted and should
not affect the product specifications in any way.
It is the Agency's opinion that the best way to eliminate
rinsewater from equipment interior cleaning is to dedicate
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equipment in some way (i.e., if equipment cannot be dedicated
completely to the production of a single product, either dedicate
the formulation tank or dedicate to a "product family") . When the
generation of rinsewaters cannot be avoided, the equipment should
be rinsed using hoses with spray nozzles and the rinsates should
be stored for reuse in future formulations. Also, rinsewaters
from formulation of many dry products can be totally eliminated by
flushing with the solid, inert material (such as clay) used as the
carrier for the products handled on the line. This inert material
is then stored for reuse in the next formulation of that product.
7.4.4.4 Aerosol Container (DOT) Leak Testing
The DOT test bath water, used in testing aerosol cans for
leaks, is a source of wastewater at aerosol packaging facilities
since it must be changed periodically, due to the buildup of
contaminants in the water. Leaking cans, or occasionally
exploding cans, contaminate the water bath with pesticide product.
Can exteriors may also contaminate the bath water since they may
have product or solvent on them from the can filling step.
According to several facilities, pesticide products and solvents
can cause visibility problems in the bath water and leave an oily
residue on the cans exiting the bath. One of the facilities
visited also indicated that rust particles in the bath water can
foul steam sparging equipment (used to heat the bath), requiring
that the bath be dumped and refilled.
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No method of eliminating this source of wastewater has been
identified; however, the volume of water used may be minimized
through the use of a contained water bath as opposed to a
continuous overflow water bath. A contained water bath is
completely emptied and refilled with water when required, based
upon visual inspection by the operator. Therefore, the quantity
of wastewater generated is dependent on the volume of the bath
(200 gallons is a typical volume of the contained water baths at
visited facilities) and the frequency of refilling. One of the
facilities visited uses a contained water bath and heats the bath
with steam to ensure that the temperature of cans reach 130°F.
This facility indicated that steam condensation causes some
overflow which is conducted out of the bath via a standpipe. A
continuous overflow bath constantly replaces the water in the
bath, keeping it clean but a constant stream of wastewater is
generated. Depending on the overflow rate of the bath, a
continuous overflow bath may generate more wastewater per
production unit than a contained water bath.
Another of the facilities visited employs a can washing step
prior to the DOT test bath, presenting an additional source of
wastewater. This can washing is performed, at operator
discretion, to reduce the quantity of contaminants entering the
bath water. The effectiveness of this step has not been
quantitatively determined.
EPA hopes to explore additional options for reducing this
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wastewater source between proposal and promulgation. One option
which has not yet been tested is the incorporation of an oil
skimming step to reduce the frequency of changing the DOT bath
water. Another option which EPA believes is applicable to DOT
test bath water is to treat this water through the Universal
Treatment System and reuse this water as, for example, DOT test
bath water or floor wash water.
At present, it is the Agency's opinion that the best way to
reduce wastewater generated by aerosol container (DOT) leak
testing is to use a contained water bath where the water is
changed out when it is determined to be "dirty" by visual
inspection.
7.4.4.5 Floor/Wall/Equipment Exterior Cleaning
During the course of formulating and packaging operations,
the exteriors of equipment may become soiled from drips, spills,
and dust (especially when in the vicinity of dust and other dry
lines). The floors in the formulating and packaging areas become
dirty from the same circumstances, and from normal traffic. PFPR
facilities clean the equipment exteriors and floors for general
housekeeping purposes, and to keep sources of product
contamination to a minimum. When water is used, these cleaning
procedures become a source of wastewater.
Equipment exteriors and floor areas of dry formulating and
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packaging lines are typically cleaned without the use of water.
Vacuuming, scraping, and other mechanical means are used to clean
the areas around these lines. Floors and equipment exteriors
associated with liquid lines, and occasionally dry lines when an
especially thorough cleaning is desired, are rinsed with water (or
an appropriate organic solvent). While some facilities routinely
clean equipment exteriors and floors, or do so at all changeovers
^between certain products, many facilities have indicated that
equipment exterior and floor cleanings are performed only when
required through visual inspections by the operators or facility
management. Wastewater from the cleaning of walls around
formulating and packaging lines appears to be rarely generated.
The quantity of water used annually for equipment exterior or
floor cleaning varies widely from facility to facility, from
several gallons to thousands of gallons.
This wastewater source can be minimized through the use of
high-pressure, low-volume washers rather than ordinary water
hoses. Where ordinary hoses are used, facilities have noted that
attaching spray nozzles or other devices to prevent free flow of
water from unattended hoses has reduced water use. Additionally,
steam cleaning (see Section 7.4.4.3) rather than water cleaning of
equipment exteriors is practiced at some facilities to reduce the
amount of wastewater generated.
Instead of hosing down the exterior of a piece of equipment,
the Agency has identified some facilities that wipe the exterior
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using rags, or use a solvent cleaner, such as a commercially
available stainless steel cleaner. This does avoid the generation
of a wastewater stream, but does create a solid waste which,
depending on the solvent used, could be considered a hazardous
waste. Squeegees are also used to clean equipment exteriors and
floors, and are not disposed after single uses. It may be
possible to dedicate squeegees to a certain line or piece of
equipment, but the use of squeegees may still require some water.
Automated floor scrubbers are also employed at some facilities in
place of hosing down floors. Using a floor scrubbing machine
takes advantage of their ability to recirculate the cleaning water
and can use as little as 5 -to 15 gallons per use. Mopping, using
a single bucket of water, can also be employed in place of hosing.
Floor mopping can generate as little as 10 gallons of water per
cleaning.
EPA has been to a number of facilities who reuse their floor
wash water with and without filtering. One facility has set up
its production equipment on a steel grated, mezzanine platform
directly above a collection sump. Following production, the
equipment and the floor of the platform, on which the operator
stands when formulating product, are rinsed down and the water is
allowed to drip into the sump. A pump and a filter have been
installed in the sump area to enable the operator to transfer this
rinsate back into the formulation tank the next time he is ready
to formulate. This sump is also connected to floor trenches in
the packaging area for the same product. When the exterior of the
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packaging equipment and the floors in this area are rinsed, this
water is directed to the trenches and eventually ends up in the
collection sump for reuse.
It is the Agency's opinion that wastewater generated from
floor and equipment cleaning can be best reduced by: (1) sweeping
the area before rinsing; (2) cleaning on visual inspection rather
than routine/daily cleaning; (3) using a floor scrubbing machine
or a mop and a bucket to clean the floors; and (4) using a high
pressure, low volume hose with a spray nozzle or a steam cleaning
machine to clean equipment exteriors.
7.4.4.6 Leaks and Spills
Leaks and spills occur during the normal course of
formulating and packaging operations. Leaks originate at hose
connections or valves. Spills of raw materials occur from bulk
storage tanks or during addition of raw materials to mix tanks.
Product spills occur from bulk storage tanks or during packaging,
from overfilling containers, missing the container to be filled,
or tipping of filled containers before capping.
Leaks can be reduced by preventive maintenance such as
checking equipment and connections before use or on a regular
basis, while good housekeeping procedures like keeping work areas
uncluttered can help in the prevention of spills. If leaks do
occur, simple measures such as placing drip pans under the leaks
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or hoppers under packaging fillers can either eliminate or
minimize the quantity of water required for cleanup and aid in
retaining the product value. Leaks and spills of dry products can
be vacuumed or swept without generating any wastewater. Liquid
leaks and spills can be collected into a trench or sump (for
reuse, discharge, or disposal) with a squeegee, leaving only a
residue to be mopped or hosed down if further water cleanup is
fcrequired. Liquid leaks and spills can also be cleaned up using
absorbent material, such as absorbent pads or soda ash. For an
acidic product, the use of soda ash or a similar base material
will also serve to neutralize the spill. If a residue remains,
some water may be used for mopping or hosing the area down, but
methods•to reduce floor wash should be implemented whenever
possible. Note that using an absorbent material may be the best
practice for cleaning up small scale solvent-based leaks and
spill, however, EPA does recognize the media transfer to solid
waste disposal. EPA has observed that many facilities cleanup
leaks and spills from water-based products with water and then
treat it as floor wash, however, these facilities cleanup leaks
and spills from solvent-based products with absorbent materials.
Therefore, good housekeeping practices may be even more important
in the case of organic solvent-based product spills and leaks
because, if not prevented, these spills and leaks may have to be
cleaned up with absorbent material and disposed.
Direct reuse of leaks and spills is another possible
pollution prevention technique. If drip pans or other containers
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are used to catch leaks and spills, the material (either water-
based or solvent-based) can be immediately reused in the product
being formulated or packaged, or stored for use in the next
product batch. Collection hoppers or tubs can be installed
beneath packaging fillers to capture spills and immediately direct
the spills back to the fillers. Leaks or spills around bulk
storage tanks can be contained by dikes, which, in fact, are often
required by state regulations. (EPA recently proposed federal
regulations for containment structures at agricultural refilling
establishments and at certain other facilities.)
It is the Agency's opinion that wastewater generated from
leak and spill cleanup can best be reduced by performing regular
preventative maintenance, including checking valves and fittings
for leaks. Another best management practice, particularly in the
case of dedicated filling equipment, is the use of drip pans. The
collection of leaks and spills in drip pans may enable a facility
to directly reuse the collected product and retain the product
value.
7.4.4.7 Air Pollution or Odor Control Scrubbers
Some PFPR facilities employ wet scrubbers to reduce air
emissions from PFPR operations. Facilities that also perform
non-PFPR operations may employ scrubbers that are not specific to
PFPR operations, but instead serve the general facility.
Scrubbers can be operated with continuously recycled water until
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replacement of the contaminated water is necessary (as practiced
by one of the facilities visited) or they can be operated with a
bleed steam (blowdown) on a continuous basis.
Many PFPR facilities employ dry air pollution control
equipment, such as carbon filters and baghouses, thus
accomplishing air pollution reduction without generating
wastewater.
Some facilities may only need a wet scrubber on one
particular process (i.e., a dedicated scrubber). These facilities
have been able to use the scrubber blowdown or changed-out
scrubber water as make-up water in the formulation of that
particular product. Some facilities with non-dedicated scrubbers
have been able to use the scrubber blowdown or changed-out
scrubber water for floor or equipment exterior cleaning.
7.4.4.8 Safety Equipment Cleaning
Most PFPR facilities employ the use of safety equipment,
including safety showers and eye washes, gloves, respirators, and
rubber boots to protect individuals from the dangers associated
with some raw materials and the production of PFPR products.
Wastewater is generated from routine checks of safety showers,
routine flushes of eye wash stations (to ensure the station is
clean and operable), and rinsing of boots, gloves, and
respirators.
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Quantities of contaminated wastewater generated from safety
equipment cleaning are generally on the order of several gallons
or tens of gallons. Some facilities are successful in avoiding
the generation of this type of wastewater by the use of disposable
safety clothing (gloves, dust masks) that do not require cleaning.
EPA does realize that the use of disposable protective clothing
may be considered a media transfer. The reduction in worker
exposure may be an important decision making factor when
considering the trade-offs using disposable safety equipment.
7.4.4.9 Laboratory Equipment Cleaning
Many PFPR facilities operate on-site laboratories for
conducting quality control (QC) tests of raw materials and
formulated products. Wastewater is generated from these tests and
from cleaning glassware used in the tests.
One effective pollution prevention/reuse technique for
laboratory equipment cleaning is to dedicate laboratory sinks to
certain products, and collect any wastewater generated from the
testing of those products either for reuse in the product or for
transfer back to the PAI manufacturer or product registrant. In
the cases where solvents are often used in conjunction with the QC
tests performed in the laboratory; the facility may not be able to
reuse the solvent-contaminated water. One facility employs the
use of a small activated carbon unit to treat their lab water
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(activated carbon as a treatment technology is discussed in
Section 7.1).
7.4.4.10
Precipitation Runoff
This source of wastewater includes all precipitation that
falls on PFPR facilities that is believed to be contaminated.
Contaminated precipitation runoff can be prevented by bringing all
PFPR operations indoors, as many PFPR facilities have done, or
roofing outdoor storage 'tanks and dikes, which has also been done
at many PFPR facilities. The roofs must extend low enough to
prevent crosswinds from blowing rain into spill-containment dikes.
To prevent rainwater contamination, the drain spouts and gutters
should conduct roof runoff to areas away from PFPR operations, and
the roofs should be kept in good repair.
7.4.4.11
Secondary Containment in the Bulk Storage
Area
Containment systems enclosing the pesticide bulk liquid
storage area are usually constructed of a floor and a dike that is
sufficiently high to contain the volume of the largest tank plus
an additional 10% to 25% safety factor. If the outside storage
area is uncovered, the containment system is usually designed to
contain 6 inches of precipitation in addition to 110% to 125% of
the volume of the largest tank. Typically, facilities construct
the secondary containment system with steel reinforced concrete
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that is 6- to 10-inches thick and coated with an appropriate
sealant. The floor may be slightly sloped to a sump area from
which any spillage or collected precipitation can be easily
pumped.
Facilities that provide commercial application services are
likely to collect and reuse any precipitation that accumulates in
the containment system during the spring and summer months. In
fact, some agrichemical facilities require such large volumes of
water for their application operations that any precipitation
accumulated is pumped into application trucks for immediate use.
However, it may be difficult for other facilities that do not
require large volumes of water or do not offer any application
services to reuse all the precipitation collected in the
containment system. These facilities should keep the containment
system free of any spilled pesticides so that precipitation
falling into the containment system does not become contaminated.
Other facilities house their pesticide bulk storage area inside of
a building or a covered area to eliminate precipitation from
collecting in the containment system. In addition to potentially
avoiding generating a contaminated wastewater that must be
controlled, enclosing the bulk storage area also protects it from
vandalism and from severe weather such as cold winters.
Enclosing containment structures is not a BAT basis for this
proposed rulemaking, nor is it a requirement of the Office of
Pesticides Programs proposed containment rule. However, the
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Agency considers roofing a bulk storage area and loading pad a
prudent and pollution-preventing action by refilling
establishments. EPA does also recognize that there may be
barriers in some areas to enclosing bulk storage areas under roof,
such as fire code restrictions.
7.4.4.12
Containment Pad in the Loading/Unloading Area
Agrichemical dealers sometimes install loading/containment
pads in the operation area to contain and collect any product
spills that may occur during pesticide loading operations. The
pad is usually installed contiguous to the bulk storage area so
that it will also contain any spills which may occur during the
loading of the bulk storage tanks and the repackaging of
pesticides into smaller containers. Facilities may also conduct
all their pesticide cleaning operations, such as the rinsing of
minibulk containers, directly on the pad in order to contain and
collect the rinsates.
The pad is normally constructed of concrete and is sloped to
a sump area. Some of the contacted facilities reported that the
sump area is divided into individual collection basins so that the
facilities can segregate wastewaters contaminated by different
products and reuse these wastewaters for application operations.
For instance, facilities in the Midwest frequently have two
collection basins; one basin is used to collect wastewaters
contaminated with corn herbicides and the other is used to collect
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wastewaters contaminated with soybean herbicides. As part of the
wastewater collection system, some facilities install one or more
tanks to store wastewater until it can be land applied while other
facilities use portable minibulk tanks to store the wastewater.
When facilities collect wastewaters that must be segregated by
different types of pesticides, to avoid contamination, multiple
storage tanks are used.
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SECTION 8
ENGINEERING COSTS
8.0
INTRODUCTION
This section discusses the costs of compliance for the
PFPR industry with the proposed effluent guidelines. Section 8.1
reviews the regulatory options and Section 8.2 describes the
engineering costing methodology used to estimate compliance costs
and pollutant loadings associated with these options. Section
8.3 describes the development of the PFPR cost model and the
facility- and PAI-specific input datasets. Section 8.4 provides
a detailed description of the design and cost algorithms used for
the various costing modules included in the cost model. The
national estimates of the costs and pollutant loadings for the
PFPR industry are discussed by regulatory option in Sections 9 -
13. For further analysis of the costs and loadings, as they
apply to the economic impact analysis, see the Economic Impact
Analysis Report (EIA).
8.1
REGULATORY OPTIONS
EPA considered five regulatory options (for Subcategory
C: PFPR and PFPR/Manufacturers) as part of the development of the
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effluent limitations guidelines for the PFPR industry. The five
regulatory options are explained below:
Option 1: Facilities may discharge all PFPR
wastewater after first reducing PAI concentrations
to levels consistent with Pesticide Manufacturers
BAT PAI limitations. PFPR compliance costs for
Option 1 are estimated based on using the
Universal Treatment System (the "UTS") to treat
facility PFPR wastewater (see Section 7.3 for a
description of the UTS).
•Option 2: Facilities are required to achieve zero
discharge of interior PFPR wastewater streams
based on the following pollution prevention and
disposal practices: recycle/reuse of some
interior streams in order to recover product value
in the wastewater, treatment and reuse of interior
streams that cannot be reused into a subsequent
batch of the same product formulation, and
contract hauling for off-site incineration of
treatment residuals. Non-interior PFPR wastewater
streams may be treated and discharged based on the
same PAI removal requirements as Option 1. PFPR
compliance costs for the non-interior streams are
estimated based on using the UTS to treat facility
PFPR wastewater.
Option 3: Facilities are required to achieve zero
discharge of interior streams using the same
pollution prevention and disposal practices as
required for Option 2. In addition, facilities
are required to achieve zero discharge of
non-interior streams based on treatment and reuse.
PFPR compliance costs for treatment and reuse are
estimated by using the UTS to achieve the same PAI
removals as for Option 2.
Option 3/S: Option 3/S is a variation of
Option 3 applicable to facilities generating
wastewater streams containing only sanitizer PAIs.
Non-interior streams from these "sanitizer"
facilities may be discharged without treatment if
these streams contain only sanitizer PAIs and
total sanitizer production is below the de minimis
production cutoff. Sanitizer facilities must
still achieve zero discharge for their interior
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PFPR wastewater streams, based on the Option 3
pollution prevention practices.
Option 4 s Facilities are required to achieve zero
discharge for all PFPR wastewater, based on the
Option 3 pollution prevention practices for
interior streams and off-site incineration for
non-interior streams.
Option 5s Facilities are required to achieve zero
discharge for all PFPR wastewater, based on
off-site incineration.
Interior wastewater streams consist of interior PFPR
process equipment cleaning wastewater, bulk PAI or pesticide
product storage tank rinsates, and shipping/raw material
container rinsates. Non-interior wastewater streams consist of
floor, wall, or PFPR process equipment exterior cleaning
wastewater, leaks and spills clean-up water, air or odor
pollution control scrubber water, aerosol can (DOT) leak test
water, safety equipment washwater, laboratory equipment wash
water, and contaminated precipitation runoff. Shower and laundry
and fire protection test wastewater sources are not included in
this regulation and therefore are not factored into the costs and
loadings.
8.2
ENGINEERING COSTING METHODOLOGY
In developing these regulatory options, EPA assessed
the economic impact of the proposed regulatory options on the
PFPR industry. The economic burden is a function of the
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estimated costs of compliance to achieve the proposed effluent
limitations, which may include the initial capital cost required
to construct any necessary treatment system(s) as well as the
annual operating and maintenance (O&M) costs for that system,
including the cost of monitoring for compliance with the
limitations.
Estimation of these costs typically begins by
identifying the pollution prevention practices and wastewater
treatment technologies that can be used to achieve the effluent
limitations. Data are then gathered from facilities within the
industry already using these practices and/or operating these
treatment technologies, equipment vendors, reference guides,
literature, and other applicable sources to determine the
estimated costs associated with each practice or technology. The
technology costs vary based on such design parameters as
wastewater flow rate, extent of pollutant reduction required to
achieve effluent limitations, and type of pollutant(s). Most
information sources list these costs in the form of cost curves,
which are graphic representations of cost as a function of flow
rate, removal efficiency, pollutant-specific treatability
parameters (such as hydrolysis half-life or carbon saturation
loading), and other design parameters. Cost curves can also be
generated by varying these parameters and estimating the
associated change in the equipment and material costs. Costs for
individual facilities or groups of facilities sharing similar
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operating characteristics can then be calculated based on these
cost curves. A computerized model can efficiently calculate
these costs based on equations representing these cost curves.
EPA used this methodology to develop a cost model for
the PFPR industry. EPA identified pollution prevention practices
and wastewater characterization and reuse/disposal information
from the 1988 PFPR questionnaire responses, facility site visits
and sampling trips, and from the FATES database. Applicable PAI
removal/destruction technologies and associated treatability data
were determined based on information contained in the project
record compiled during the development of effluent guidelines for
the Pesticides Manufacturing Industry ("Manufacturers") and in
the project record for the PFPR regulation. These data sources
consist of wastewater sampling analytical results, EPA and
industry-supplied treatability studies, and literature
information. Cost curves for these treatment technologies were
then developed based on the design and cost algorithms developed
for the Manufacturers cost model, revised to reflect conditions
specific to the PFPR industry. These cost curves were compiled
into a computerized spreadsheet cost model, which uses input
datasets containing facility- and PAI-specific data to estimate
compliance costs for the 167 surveyed facilities that discharged
wastewater from PFPR operations in 1988. As discussed in the
following sections, the final PFPR cost model consists of
individual spreadsheet modules that calculate the costs and
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loadings associated with the treatment of PFPR wastewater (the
UTS module), storage and reuse of facility interior rinsate
wastewater streams, and off-site disposal of PFPR wastewater.
8.2.1
Costing Methodology for Sanitizer Facilities
Sanitizer facilities are facilities that formulate,
package, or repackage one or more pesticide products that contain
only sanitizer PAIs. As a variation to Option 3, Option 3S
allows facilities producing less than 265,000 pounds per year of
sanitizer products to discharge, without treatment, non-interior
PFPR wastewater streams containing only sanitizer PAIs (the
"sanitizer exemption"). Sanitizer facilities do not lose the
exemption if they produce non-sanitizer products, but exempted
wastewaters cannot contain non-sanitizer PAIs.Facilities below ,
the production threshold that also formulate, package, or
repackage pesticide products that contain non-sanitizer PAIs may
also qualify for the sanitizer exemption. Under Option 3S, these
facilities may discharge non-interior PFPR wastewater streams as
long as the only PAIs in the wastewater are sanitizer PAIs.
Based on facility responses to the PFPR questionnaire
and information in the FATES database, a total of 39 surveyed
facilities were identified as having wastewater streams that may
contain only sanitizer PAIs, as well as sanitizer productions of
less than 265,000 pounds per year. Under Option 3S, these
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facilities received compliance costs based on storage and reuse
of interior streams that could be recycled, treatment and reuse
of interior streams that could not be recycled, and treatment and
reuse of non-interior streams containing non-sanitizer PAIs.
Option 3S costs were lower than the corresponding Option 3 costs
for 21 facilities.
8.2.2
Costing Methodology for Refilling Establishments
A total of three surveyed Subcategory E: Refilling
Establishments reported discharging a total of 270 gallons of
wastewater in 1988. These three surveyed facilities represent
twenty facilities in the national estimates for which costs are
estimated. Two regulatory options were developed for refilling
establishments. The first option, storage and reuse, was based
on the observed practice of wastewater reuse in subsequent
product formulations. The second option was based on achieving
zero discharge of all PFPR wastewater via contract hauling for
off-site incineration. For the first option, the compliance
costs are limited to the capital costs associated with a 250-
gallon polyethylene storage tank and a 1/2 horsepower (hp) pump.
The O&M costs, which normally include containment and pump
energy, are assumed to be zero since these containment costs are
covered under the Office of Pesticides Programs Residue Removal
and Secondary Containment regulations (59 FR 6712; February 11,
1994). Energy associated with the low volumes at these refilling
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establishments should be negligible. The off-site disposal
module (described in Section 8.4.3) was used to calculate costs
for the contract haul option.
8.3
DEVELOPMENT OF PFPR COST MODEL AND INPUT D&TASETS
This section describes the development and components
of the PFPR cost model. Section 8.3.1 discusses the evolution of
the PFPR cost model from the cost model used during the
development of the Manufacturers effluent guidelines. Section
8.3.2 discusses the technical basis for the three treatment
technology modules making up the PFPR cost model: the wastewater
treatment module (the UTS module), the storage and reuse module,
and the contract hauling for off-site disposal module. Section
8.3.3 discusses the development and the function of the input
datasets.
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8.3.1 Development of the PFPR Cost Model from the
Mapufac't'urers Cost Model
Treatment technologies applicable to the
removal/destruction of PAIs were initially identified and
characterized during development of effluent guidelines for the
pesticide manufacturing industry, and further evaluated during
the PFPR proposed rule development. These treatment technologies
include activated carbon, biological treatment, chemical
oxidation, distillation, hydrolysis, hydroxide precipitation,
resin adsorption, and solvent extraction. The cost model
developed for the pesticide manufacturing rulemaking includes
cost modules for each of these technologies, as well as a module
for contract hauling of wastewater for off-site incineration.
The applicability of each of the Manufacturers' cost
model treatment technologies to the PFPR industry was evaluated
based on data obtained from PFPR questionnaire responses, from
site visits and sampling visits conducted at PFPR facilities, and
from EPA treatability studies. These sources indicate that the
most generally applicable wastewater treatment technologies for
PFPR facilities are activated carbon, chemical oxidation,
hydrolysis, and chemical (hydroxide or sulfide) precipitation.
In addition, due to the lower wastewater flow rates commonly
found at PFPR facilities, contract hauling of wastewater for
off-site incineration is usually a more economically viable
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disposal option than it is for pesticide manufacturers. Finally,
these sources indicate that many PFPR facilities conduct
wastewater recycling, some perform treatment operations, and
several do both. Wastewater recycling operations typically
consist of storage and reuse of wastewater, usually into the next
production batch of the same pesticide product. PFPR facility
pollution prevention, wastewater conservation, and
recycling/reuse practices are discussed in Section 7.4 of this
document.
Revised versions of the activated carbon, chemical
oxidation, hydrolysis, chemical precipitation, and contract
hauling for off-site incineration cost modules from the
Manufacturers' cost model were incorporated into the PFPR cost
model. (These treatment technologies are described in Section
7.1). In addition, new modules were developed for inclusion in
the PFPR cost model for emulsion breaking (also described in
Section 7.1) and storage/containment. These technologies were
chosen for inclusion in the PFPR cost model because they are
commercially available at a scale applicable to the smaller PFPR
wastewater volumes, have been used for wastewater treatment at
PFPR facilities, or are necessary to ensure that the PFPR cost
model contains technologies applicable to all PFPR wastewater
streams. The emulsion breaking cost module estimates the costs
for equipment and chemicals needed to remove oils, emulsifiers,
and surfactants from PFPR wastewaters prior to PAI treatment. A
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separate cost module for wastewater storage and containment is
required in lieu of the storage and containment design and cost
algorithms in the Manufacturers' cost model, as the
Manufacturers' storage and containment algorithms are not
applicable to the lower PFPR industry wastewater volumes. The
revised cost curves and design and costing algorithms used in
each of these cost modules are discussed in the Final Pesticide
Formulators. Packagers, and Repackagers Cost and Loadings Report.
dated March 31, 1994 (the "final PFPR cost report").
8.3.2
PFPR Cost Model
A final PFPR cost model was developed to estimate
compliance costs and loadings specific to each of the five
regulatory options discussed in Section 8.1. Since the
regulatory options range from treatment and discharge of PFPR
wastewater to zero discharge of PFPR wastewater, the final PFPR
cost model contains modules that can design the necessary
equipment and estimate the resulting costs for treatment, storage
and reuse systems, or off-site disposal. Each module is a
compilation of computer spreadsheets driven by spreadsheet macros
that automatically calculate costs and loadings for individual
PFPR facilities based on facility-specific data in the PFPR
questionnaire database. By using the appropriate inputs and
combining the outputs from these modules in different
combinations, compliance costs may be estimated for each
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regulatory option. These combinations are discussed in Section
8.3.3.5.
8.3.2.1 Wastewater Treatment Module (The "UTS" Module)
The current UTS module was developed from the
individual cost modules for each treatment technology. Test runs
were conducted using the individual cost modules to calculate
treatment and discharge compliance costs for seven PFPR
facilities. Analysis of these test runs indicated that a
treatment train incorporating emulsion breaking, hydrolysis,
activated carbon, chemical oxidation, and chemical precipitation
would be capable of treating PFPR wastewaters to levels meeting
the requirements of Options 1, 2, and 3. Therefore, a
standardized, or "universal," treatment system was developed that
is applicable, with minimal facility-specific modifications, to
every water-using PFPR facility.
The Universal Treatment System consists of raw
wastewater storage tanks (with capacity to hold up to three
month's generation of wastewater or the facility's maximum
wastewater volume generated at one time in 1988, whichever volume
is larger); a jacketed process treatment vessel(s) in which
emulsion breaking, chemical oxidation, hydrolysis, and chemical
precipitation take place; an activated carbon system consisting
of a feed storage tank, a grit pre-filter, a 3-bed absorber unit,
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and, if required due to size, a backwash system; and effluent
storage tanks equal in capacity to the raw wastewater storage
tanks. These wastewater treatment technologies are explained in
Section 7.1 and are discussed in relation to the UTS module in
the following paragraphs. EPA points out that the model
calculates costs under the assumption that hydrolysis and
chemical oxidation are carried out only when required (based upon
the treatability information described in Section 8.3). Emulsion
'breaking pretreatment and activated carbon adsorption, however,
are always assumed to be carried out on the wastewater and
therefore their costs are always included. This approach is
conservative, because it is likely that not all facilities will
need to use emulsion breaking to treat their wastewaters.
Emulsion Breaking
Many pesticide formulations involve mixing emulsifiers
and other surfactants with the PAI(s) in order to achieve
specific application characteristics. Wastewater streams
containing these emulsifiers may be difficult to treat, as the
emulsifiers may interfere with the removal or destruction of
PAI(s) or other pollutants. As a result, pretreatment by
emulsion breaking has been identified as the first step in the
'best available technology" using the UTS process vessel(s).
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Based on information gathered on the PFPR industry
through the questionnaire and sampling, and information on
equipment gathered through vendors, a design and cost algorithm
has been developed that calculates estimated treatment costs for
an emulsion breaking system based on acidification and heating of
wastewater. The wastewater is heated to 60°C (140°F) with steam,
acidified to pH 3 with sulfuric acid, agitated for 1 hour, and
then allowed to settle for 23 hours. The oil layer is either
skimmed off the top of the tank with a wet vacuum pump (for small
systems) , or separated from the aqueous phase by pumping the
aqueous phase into a second process vessel (for large systems)„
The demulsified wastewater is neutralized with sodium hydroxide.
Chemical Oxidation
As described in Section 7.1, chemical oxidation is used
in wastewater treatment to destroy certain organic pollutants by
the addition of an oxidizing agent (e.g., ozone, permanganate,
chlorine dioxide, or chlorine). Chemical oxidation has been
demonstrated by the pesticide industry and in EPA treatability
studies to be effective at destroying alkyl halide, DDT-type,
phenoxy, phosphorothioate, and dithiocarbamate PAIs in pesticide
manufacturing facility wastewaters.
Based on the available data, the UTS cost module
includes a chemical oxidation (via alkaline chlorination) design
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and cost algorithm. Wastewater pH is raised to 12 with sodium
hydroxide, mixed with a 10% sodium hypochlorite (NaOCl) solution,
held for a four-hour residence time, and neutralized with
sulfuric acid. The UTS cost module relies on the activated
carbon system to remove chlorinated oxidation products.
Hydrolysis
Hydrolysis is a chemical reaction in which organic
compounds react with a base (hydroxide compound) or water and
break into smaller (and less toxic) compounds (see Section 7.1
for detailed discussion).
Although most PAIs and classes of PAIs will hydrolyze
at ambient conditions to some extent, half-lives in many cases
are measured in terms of weeks, months, or years. Significant
hydrolysis needs to occur in a relatively short period of time to
be considered as a viable treatment process. Treatability study
data reported in the literature have indicated that carbamate,
phosphate, phosphorothioate, and phosphorodithioate based PAIs
are subject to fairly rapid hydrolysis under the proper
conditions. EPA conducted a treatability study on 38 PAIs in
these pesticide groups and in the urea group to determine
hydrolysis rates at pHs of 2.0, 7.0, and 12.0 and at temperatures
of 20°C and 60°C. At elevated temperature (60°C) and high pH
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(12) conditions, most of these PAIs had half-lives of less than
30 minutes.
The UTS cost module hydrolysis design and cost
algorithm calculates treatment costs based on elevating the
wastewater's pH and temperature. Wastewater is heated to 60°C
(140°F) with steam, mixed with sufficient sodium hydroxide to
raise the pH to 12, agitated for the required residence time (as
determined by the longest PAI half-life), and neutralized with
sulfuric acid.
Chemical Precipitation
As described in Section 7.1, chemical precipitation is
a separation technology in which the addition of chemicals during
treatment results in the formation of insoluble solid
precipitates. Settling or filtration then separates the solids
formed from the wastewater.
The UTS cost module chemical precipitation design and
cost algorithm calculates treatment costs based on a combination
of hydroxide and sulfide precipitation. Wastewater pH is raised
to 12 with sodium hydroxide, mixed with sodium sulfide, held for
a 15-hour residence time to allow for settling, and neutralized
with sulfuric acid. Settled solids are drained from the process
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vessel, and residual solids are removed in the downstream
strainer and activated carbon system.
Carbon Adsorption
Granular activated carbon (GAG) has been demonstrated
to be a practical method of removing a wide range of organic
contaminants from industrial wastewater. In the pesticide
manufacturing industry, activated carbon adsorption has been used
to treat wastewater containing PAIs in the following structural
groups: acetamides, aryl halides, benzonitriles, carbamates,
phenols, phosphorodithioates, pyrethrins, s-triazines, tricyclic,
toluidines, and ureas.
In addition, EPA and industry activated carbon
treatability studies have demonstrated sufficient treatability of
pesticides in the acetanilide and uracil structural groups to
establish this treatment as a basis for control of specific PAIs
in these groups. Carbon has also been shown in treatability
studies to be an effective polishing control for thiocarbamate
PAIs.
The activated carbon system consists of a feed tank, a
transfer pump, three carbon beds, and either a cartridge pre-
filter or a backwash system (depending on the size of the
activated carbon beds selected). The feed tank is designed to
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hold the volume of wastewater in the process vessel (s) before it
is discharged to the carbon beds. The module selects one of five
activated carbon models with a configuration consisting of three
carbon beds operating in series; the five models can handle flows
ranging from less than one gallon per minute (gpm) up to 700 gpm.
The three-bed design, with effluent from the second bed monitored
for breakthrough, maximizes the carbon usage efficiency of the
system. New carbon is used in the third bed to polish effluent
from the second bed. When breakthrough is detected from the
second bed, the first bed is sent for off-site regeneration, the
second bed becomes the first bed, the third bed becomes the
second bed, and a fresh carbon bed is brought on-line as the
third bed.
The activated carbon module accounts for solids removal
from the wastewater by incorporating either a cartridge
pre-filter or a backwash system into the carbon system design. A
cartridge pre-filter is selected if one of the two smaller
activated carbon models is chosen and a backwash system is
designed if one of the three larger activated carbon models is
chosen. The backwash system consists of a pump and two tanks,
one tank to accumulate and store treated wastewater for use as a
backwash fluid and the other tank to store spent backwash fluid.
The spent backwash fluid is recycled to the raw wastewater feed
tank.
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Equations used to size the system, estimate the carbon
usage rate, and estimate capital and operating and maintenance
costs can be found in Section 8.4.
8.3.2.2 Storage and Reuse Module
The storage and reuse cost module estimates costs
associated with the storage and containment of PFPR wastewaters
prior to reuse. A facility that recycles and reuses wastewater
may store the wastewater in drums, or they may elect to install
multiple tanks in order to segregate wastewater streams
contaminated with different PAIs or PAI types (i.e., herbicides,
insecticides, etc.). This module determines, on a line-specific
basis, whether drum or tank storage is required; the number,
size, and cost of the drums or tanks; and the necessary size and
resulting costs of a secondary containment system enclosing the
wastewater storage area. (See details of the design and costing
algorithm in Section 8.4.)
8.3.2.3 Off-Site Disposal Module
The off-site disposal module calculates off-site
disposal costs based on contract hauling PFPR wastewater for
off-site incineration. Off-site disposal costs can be calculated
for stream-specific wastewater sources or for the entire
wastewater flow from a facility. The module optimizes a storage
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design consisting of either a tank storage system or a 55-gallon
drum storage system. The module then calculates the associated
transportation and incineration costs. (See details of the
design and costing algorithm in Section 8.4.)
8.3.3
Cost Model Input Datasets
The cost model contains separate datasets for estimated
facility-specific influent PAI concentrations; facility-specific
wastewater flow rates; facility- and stream-specific wastewater
treatment and discharge status (based on the regulatory options);
and PAI-specific treatability data and achievable effluent
concentrations. These input datasets are based on information on
PFPR wastewater streams containing the 272 PAIs from the
Manufacturers rule, and are discussed in the following
paragraphs. The actual datasets can be found in the final PFPR
cost report. These datasets were extrapolated to cover the non-
272 PAIs using production data from the FATES database. The
extrapolation of the cost model input datasets to the non-272
PAIs is discussed in Section 8.3.3.5.
8.3.3.1 Influent Concentrations
Facility-specific PAI concentration data are estimated
based on questionnaire data and sampling data. These PAI
concentrations are estimated by a program which combines
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facility-specific stream types and stream flow rate data obtained
from the PFPR questionnaire with stream-specific PAI
concentration data obtained from EPA sampling episodes. PAI
loadings are estimated for each stream at each facility, and
overall facility PAI loadings are estimated by summing the
stream-specific PAI loadings. Stream-specific PAI loadings are
estimated by first identifying the PAIs that could be in each
stream (from information reported in the questionnaire) and then
using sampling data to estimate the concentration for each of
these PAIs. It is assumed that the PAI(s) used in each pesticide
product that is formulated, packaged or repackaged on each
production line is contained in the wastewater streams generated
by that line. It is also assumed that all PAIs formulated,
packaged and repackaged by each facility are in the facility's
non-line-specific wastewater streams. The concentration of each
PAI in the facility's commingled wastewater (i.e., all line- and
non-line-specific streams) is then estimated by dividing the sum
of the stream-specific loadings for each PAI by the total
commingled wastewater flow rate.
The PAI concentrations for each stream are extrapolated
from the sampling data in the PFPR analytical database. These
sampling data were collected at thirteen PFPR facilities and have
been sorted by stream type and PAI. For most stream types, the
current sampling dataset lacks concentration data for numerous
PAIs. That is, sampling data may be available for atrazine in
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interior cleaning streams but not for atrazine in floor wash
samples, and data may not be available for certain other PAIs in
any stream type. As a result, extrapolated values are used for
many PAI-stream type pairs, based on the following hierarchy:
Actual PAI concentration data are used for
specific stream types when available;
PAI concentration data are transferred to
structurally similar PAIs within the same stream
type if no actual concentration data are
available; and
Median values of all the PAI concentration data
points within the same stream type are transferred
to all remaining PAIs lacking concentration data
for this stream type.
Data characterizing the PAI concentrations in
commingled PFPR wastewater stream effluents from two sampled
facilities were compared with the corresponding PAI
concentrations back-calculated using the above methodology, in
order to evaluate the extrapolations. The extrapolation of
median concentration values appears to yield the most "realistic"
set of PAI concentrations (a comparison of these results is
contained in Appendix F of this document).
8.3.3.2 Facility Wastewater Volumes
Comprehensive volume data are available for individual
water-using PFPR facilities in the PFPR industry sample, based on
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the responses and follow-up correspondence to the 1988 PFPR
questionnaire. Annual wastewater volumes for individual
line-specific and non-line-specific PFPR wastewater streams are
documented in each quesstionnaire, along with the destination for
each stream. Based on this breakdown of the volume data, the
volume of wastewater generated by stream type (e.g., floor wash)
and the total volume of PFPR wastewater discharged in 1988 could
be determined for each facility. All PFPR wastewater sources
except shower and laundry water and fire protection test water
(which are not being proposed for regulation) are included in the
volume calculations. (The reasons for excluding shower, laundry
and fire protection test water from regulation are presented in
Section 5.1.1 of this document). Facilities reporting multiple
wastewater streams but only partial wastewater volume information
are costed based on the wastewater volume information provided.
Likewise, if a facility reported generating wastewater in 1988
but did not provide any volume data, no compliance costs are
estimated for this facility. In addition, PFPR wastewater
streams that were recycled on- or off-site, contract hauled from
the facility for treatment or disposal, or handled in any manner
other than being discharged in 1988, are not included in. the
volume calculation. If a percentage of a wastewater stream was
discharged from a facility in 1988, only the volume corresponding
to that percentage is included in the volume calculated for that
facility.
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To optimize the design of the UTS at each facility, the
cost model provides for storage of all PFPR wastewater generated
during each quarter of the year based on which months the line
was reported to be in operation in 1988. To determine the number
of calendar quarters that each PFPR facility was in operation,
the calendar year is split into four quarters, with January
through March constituting the first quarter, April through June
constituting the second quarter, July through September
constituting the third quarter, and October through December
constituting the fourth quarter. If a PFPR line was in operation
in any month of a certain quarter of 1988, the PFPR facility is
considered to have been in operation during that quarter.
Wastewater reported for a specific line in the questionnaire is
split evenly among all quarters that the line was in operation in
1988. For example, if a PFPR facility operated a line in June
and December of 1988, any wastewater reported to be generated on
that line would be split evenly between the second and fourth
quarters. Any non-line-specific wastewater reported is split
evenly among the quarters that the facility reported conducting
PFPR operations in 1988. For example, if a PFPR facility has two
lines with the first in operation during the first two quarters
of 1988 and the second in operation during the second two
quarters of 1988, any non-line-specific wastewater would be split
evenly among all four quarters.
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The model utilizes the quarterly volumes to determine
the appropriate design size of the wastewater storage tank(s),
the batch treatment vessel, and the carbon adsorption system.
The model compares the wastewater storage capacity based on the
highest quarterly volumes with the maximum amount of wastewater
discharged from any source at any one time, in order to ensure
that adequate storage is available.
8-25
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8.3.3.3 wastewater Stream Cost Codes
The cost model calculates costs and loadings on a
wastewater stream-specific basis at each PFPR facility, according
to the applicability of pollution prevention and recycle/reuse
measures to each stream. These cost codes indicate whether the
water can be reused directly (without treatment or storage) ,
stored and reused, or treated and reused, or whether the stream
must be contract hauled for disposal off site. In general,
rinsates generated from a specific line are considered directly
reusable if the product formulated on that line uses water and is
formulated multiple times over the course of the year. The
stored rinsate water could then be used in the next formulation
of the product. Treated wastewater (in which PAIs are treated to
concentrations equal to or less than 0.8 ppm) is considered
reusable in exterior cleaning applications and in some
facility-specific product formulations or interior cleaning
operations, regardless of the wastewater stream source.
Each stream was assigned a cost code dependant on a
conservative evaluation of the quality of wastewater generated
and the ability to reuse or treat and reuse that water. Stream
cost codes may include a choice for contract hauling for off-site
incineration. This is used when costing regulatory Option 4
(pollution prevention and reuse for interior sources with
contract hauling for off-site incineration for other wastewater
8-26
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sources) or Option 5 (contract hauling for off-site incineration
of the entire wastewater volume) . The codes are:
Code A Stream is costed for storage and reuse;
Code B Stream is costed for contract hauling for
off-site disposal (currently no streams are
coded B);
Code C Stream is costed for treatment and reuse;
Code D Stream is costed for treatment and reuse or
for contract hauling for off-site disposal by
incineration;
Code E No cost associated with the reuse of this
stream;
Code F Line with special interior cleaning - a
portion of the interior water costed for
storage and reuse (Code A) and a portion
costed for treatment and reuse or contract
hauling for off-site disposal by incineration
(Code D); and
Code G Line with a break in operations greater than
90 days - a portion of the interior water is
costed for storage and reuse (Code A), and a
portion is costed for treatment and reuse or
contract hauling for off-site disposal for
incineration (Code D).
EPA is designating facility wastewater streams as
either interior or non-interior. All non-interior streams are
assigned either code D, if they were discharged in 1988, or code
E, if they were recycled or otherwise disposed of in 1988.
Interior streams consist of non-line-specific drum
rinsates, non-line-specific bulk tank rinsates, and line-specific
8-27
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interior cleaning streams. In general, interior streams are
considered to be reusable without treatment. Drum rinsates are
assumed to be reusable into a product formulation without storage
or treatment, and therefore receive Code E. Bulk tank rinsates
are also assumed to be reusable into product formulations without
treatment, and therefore receive either Code A or Code E,
depending upon whether a facility generating this stream already
reuses or contract hauls the wastewater.
Interior cleaning streams may, however, exhibit certain
characteristics which make them difficult to reuse. Interior
cleaning streams were evaluated based on these characteristics or
on the process generating the rinsate. The following
characteristics were identified:
Lines that do not formulate products: Cleaning
wastewater generated on lines that only package or
repackage products cannot be reused into any other
product formulation. These streams receive code
D.
Lines that handle dry or emulsifiable concentrate
products; Cleaning wastewater from lines that
handle dry or emulsifiable concentrate products
cannot be reused in these formulations since these
products do not contain water. Since it is
impossible to determine the portion of water on
the line which is due to only these products,
these streams receive code D.
Lines at toll formulators; These facilities may not
make a product more than once in any given time
period and therefore may not be able to reuse
cleaning water directly into product formulations.
These streams receive code D.
8-28
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Lines that have production breaks exceeding 90 days;
Facilities that operate sporadically throughout
the year may have production gaps exceeding 90
days. As a result, a portion of the annual amount
of cleaning wastewater generated on the line might
not be reused within a 90-day period from the time
of generation and may be subject to RCRA storage
rules. These streams initially receive code G.
The portion of wastewater that can be reused
within 90 days is assigned code A, and the
remaining wastewater is assigned code D.
Lines that hcive special cleaning operations;
Facilities may have difficulty reusing cleaning
wastewater from these operations directly into
product formulations since special cleanings are
often unplanned and may contain many different
PAIs or generate large quantities of water. These
streams initially receive code F. Based on
facility-specific analysis of other cleaning
streams on the same line, water that can be reused
into products formulated on that line is given
code A, and the remaining water is given code D.
Lines that generate more wastewater than can be
potentially reused: Based on the available
information, twenty lines were identified as.
generating more water from cleaning operations
than was assumed could be reused directly into
product formulations. The volume of water that
could be reused into the product formulations was
calculated as follows:
1) First, the pounds of PAI reported to be in
the product was calculated. The percent of
PAI(s) provided by the facility in Section 3
of the questionnaire were used to determine
this value:
Total Pounds
of Production
x Total % of
PAI in Product
Pounds of
PAI
8-29
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2) Next, the calculated pounds of PAI (from #1)
were subtracted from the total pounds of
product to determine the pounds of product
remaining:
Total Pounds
of Production
Pounds of
PAI
Pounds of
Product
Remaining
3) The pounds of product remaining (from #2)
were converted to gallons:
Pounds of
Product
Remaining
4)
8.34 pounds
gallon
Gallons of
Product
Remaining
It was assumed that cleaning water could be
used to make up 50% of this volume:
Gallons of Product
Remaining
50% = Gallons of
water that can
be reused in
formulation
5) This value was compared to the volume of
interior cleaning water generated on the
line:
Gallons of water that can
be reused in formulation
> OR <
Total interior
cleaning water
generated on
the line
For lines that generated more water than is
assumed to be directly reused or stored for reuse,
all water generated on these lines is assigned
cost Code D (treatment and reuse or contract
hauling for off-site disposal, depending on the
option).
Line-specific interior cleaning streams that do not
exhibit any of the above characteristics (#1 - 6) are assumed to
be reusable into product formulations without treatment, and
therefore receive Code A (storage and reuse).
8-30
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Waste streams that were not discharged directly (via
NPDES discharge point) or indirectly (to a POTW) in 1988 are
assigned Code E (no cost for the reuse of these streams) . These
streams were either recycled or otherwise disposed of via a zero
wastewater discharge method.
8.3.3.4 PAI Treatabilxty Dataset
For each PAI or PAI structural group, the PFPR cost
model identifies the applicable UTS treatment technology. This
treatment technology is the "BAT" treatment technology associated
with the PAI. A UTS treatment technology is applicable if
treatability data demons; tr at ing effective treatment are available
from the Manufacturers' or PFPR project records. Where more than
one treatment technology is applicable, the cost model designates
only one technology as etpplicable in the following order: (1)
precipitation; (2) hydrolysis; (3) chemical oxidation; (4)
activated carbon adsorption. However, treatability data are not
available for all combinations of technologies and PAIs or PAI
structural groups. Where treatability data are not available for
a particular PAI or PAI structural group, treatability data are
transferred to the PAI or PAI structural group. The treatability
8-31
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data transfer methods are described below for each UTS
technology:
Precipitation—The PFPR cost model assumes that all
organo-metallic PAIs are amenable to precipitation
treatment.
Hydrolysis— The PFPR cost model uses hydrolysis
treatability data transfers as well as treatability
data extrapolations. For a limited set of structural
groups, an analysis of the chemical structure of the
PAIs and the acid strength of the hydrolysis leaving
group, as measured by the negative log of the
dissociation constant, pKa, may be used to estimate
hydrolysis rates1. For structurally similar PAIs, as
pKa decreases, the rate of hydrolysis increases. Using
this method, hydrolysis rates are transferred within
particular structural groups from PAIs having leaving
groups with higher pKa values to PAIs having leaving
groups with lower pKa values.
The UTS module of the PFP cost model costs PFP
facilities to conduct the hydrolysis step at pH 12,
60°C. However, hydrolysis treatability data are
available for some PAIs only at conditions other than
pH 12, 60°C. Where sufficient hydrolysis treatability
data are available at conditions other than pH 12 and
60°C, the PFPR cost model uses hydrolysis rates
estimated by extrapolating the data to the conditions
of pH 12 and 60°C using kinetically derived
relationships based on the Arrhenius equation.
Chemical Oxidation— The PFPR cost model does not use
transfers of chemical oxidation treatability data.
Carbon Adsorption—The PFPR cost model uses transfers
of activated carbon treatability data based on
structural similarities and chemical properties. The
PFPR cost model transfers parameters for Freundlich
adsorption isotherms, so that the PFPR cost model can
calculate more accurate saturation loadings for each
PAI at each facility.
1 Lyman, W.J. et al. Handbook of Chemical Property
Estimation Methods. McGraw-Hill Book Company, 1981.
8-32
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Activated carbon treatability data were transferred
only to PAIs identified as amenable to activated carbon
adsorption. Compounds that are amenable to activated
carbon adsorption typically display the following
characteristics: (1) low water solubility; (2)
aromaticity; and (3) high molecular weight.2 PAIs with
treatability data showing that the PAIs are amenable to
carbon adsorption, and PAIs exhibiting characteristics
typical of compounds amenable to carbon adsorption, are
identified asi PAIs amenable to activated carbon
adsorption.
The amount of activated carbon needed to remove a PAI
from wastewater may be estimated using saturation
loadings. However, saturation loadings are a function
of the concentration of the PAI in the wastewater. A
Freundlich isotherm shows the concentration dependence
of saturation loadings at a constant temperature, and
is described by the empirical constants K and 1/n. The
PFPR cost model uses K and 1/n values for PAIs to
calculate activated carbon costs for each facility.
Freundlich constants are transferred within structural
groups to PAIs lacking Freundlich constants if an
analysis of available treatability data, water
solubility, aromaticity, and molecular weight indicates
that the PAI is as amenable to carbon adsorption as the
PAI from which the data would be transferred. If a PAI
is identified as amenable to activated carbon but is
not within the same structural group as a PAI from
which Freundlich constants can be transferred, then
90th percentile lowest Freundlich constants are
assigned to that PAI. The 90th percentile Freundlich
isotherm is an isotherm that shows saturation loadings
lower than 90 percent of all PAIs at any given
concentrat i on.
Hydrolysis half-lives and activated carbon Freundlich
parameters are used by the cost model to determine batch times
and carbon usage requirements. PAIs that are treatable by
2 U.S. Environmentcil Protection Agency, Municipal
Environmental Research Laboratory. Carbon Adsorption Isotherms
for Toxic Orcranics. EPA-600/8-80-023. Cincinnati, Ohio, April
1980.
8-33
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precipitation or chemical oxidation trigger certain design and
costing algorithms in the cost model. These algorithms include
cost functions for energy and materials which are based on flow
rate and batch volume. No PAI-specific data are used in
calculating the costs associated with precipitation and chemical
oxidation treatment costs other than identifying the PAIs
amenable to these treatment technologies. A more thorough
description of the available treatability data and data transfers
is contained in the Final Pesticides Formulators, Packagers, and
Repackagers Treatability Database Report, dated March 31, 1994.
As with the influent concentration dataset, achievable
effluent concentration data are not available for all PAIs.
Therefore, achievable effluent concentrations are extrapolated
from other PAIs, based on the following methodology:
PAIs with numerical Manufacturers' BAT limitations
are assumed to be treatable to the same achievable
effluent concentrations as determined under the
Manufacturers' rulemaking following pretreatment
to break emulsions.
PAIs without numerical Manufacturers' BAT
limitations that are in the same structural group
as a PAI with BAT limits are assumed to be
treatable to the same achievable effluent
concentration.
PAIs that do not have numerical Manufacturers' BAT
limitations and that are not structurally similar
to PAIs with numerical BAT limitations are assumed
to be treatable to conservatively high effluent
concentration. This extrapolated concentration is
equal to the 90th percentile highest effluent
8-34
-------
concentration of all the PAIs with numerical BAT
limitations.
Each PAI has a "BAT" treatment technology associated with it,
which is presented in Appendix H of this document. This PAI
treatability dataset is used by the cost model to determine which
treatment technologies need to be sized and costed. The
achievable effluent concentration for each PAI is required by the
cost model to determine batch times, reagent quantities, and
carbon usage requirements. PAI hydrolysis half-lives and PAI
carbon saturation loadings are also used by the cost model to
determine batch times and carbon requirements.
8.3.3.5 Extrapolation Of Input Data Sets To Non-272 PAIs
The PFPR cost model input data sets are based on
information available for the 272 PAIs listed in the
Manufacturers' regulation. However, the PFPR regulation is also
applicable to PAIs not listed in the Manufacturers' regulation
(non-272 PAIs). The PFPR cost model extrapolates the input data
sets to the non-272 PAIs based on 1988 production data contained
in the FATES database. Because the 272 PAIs represent a wide
variety of chemical properties, structural groups, and
treatabilities, the treatability data sets for the 272 PAIs are
also extrapolated to the non-272 PAIs.
8-35
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The influent concentration dataset for the 272 PAIs is
based on questionnaire and sampling data from a wide variety of
PFPR facilities handling PAIs from a number of structural groups.
The influent concentration dataset currently extrapolates PAI
concentrations, on a stream-specific basis, to any of the 272
PAIs where questionnaire or sampling data are not available.
Because of the wide variety of influent data available for the
272 PAIs, these data are also extrapolated to the non-272 PAIs.
The PFPR cost model assumes that the concentrations of the
non-272 PAIs present at each PFPR facility are the same as the
concentrations of the 272 PAIs. For example, if the total
concentration of the 272 PAIs is 1,000 mg/L, then the total
concentration of the non-272 PAIs is also assumed to be 1,000
mg/L. The amount of wastewater associated with the non-272 PAIs,
which is used in conjunction with the extrapolated concentration
to estimate the non-272 loadings, is discussed below.
The facility wastewater volume dataset is extrapolated
to the non-272 PAIs based on the production of 272 and non-272
pesticides products in the 1988 FATES database. The amount of
wastewater generation per pound of product containing one or more
of the 272 PAIs is assumed to be equivalent to the amount of
wastewater generated per pound of product containing the non-272
PAIs. This assumption may provide a conservatively high estimate
of total facility wastewater volume because many wastewater
volumes reported for the products containing 272 PAIs may already
8-36
-------
include the wastewaters associated with the non-272 PAIs. For
example, at a facility where stormwater is not segregated by
product, the stormwater reported for the 272 PAIs may also
include the stormwater associated with the non-272 PAIs, and
would be double counted. This would result in a conservatively
high cost estimate for the facility.
Cost codes were assigned to the wastewater associated
with the products containing non-272 PAIs based on the assumption
that facilities would generate the same types of wastewaters for
products containing the non-272 PAIs as for products containing
the 272 PAIs. Thus, the wastewater volumes associated with the
non-272 PAIs are assigned the same cost codes as the wastewater
volumes containing the 272 PAIs.
The UTS design employs a variety of treatment
technologies to ensure that all PAIs present in each facility's
wastewater will be effectively treated. The UTS treatment system
is expected to effectively treat the 272 PAIs. Because the 272
PAIs represent a wide range of chemical properties, chemical
structures, and relative treatabilities, the UTS is also expected
to achieve effective treatment of the non-272 PAIs. The PFP cost
model uses the same UTS technologies developed for each facility
to treat both the 272 and non-272 PAIs present at the facility.
8-37
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The achievable effluent concentration dataset is based
on information gathered from the Manufacturers' and PFPR project
records. Because these data represent achievable effluents from
a wide variety of PAIs and structural groups, the achievable
effluent concentrations were transferred to the 272 PAIs lacking
achievable effluent data. The achievable effluent concentration
dataset are also transferred to the non-272 PAIs. As a result,
the PFPR cost model uses the same achievable effluent
concentration dataset for both the 272 and non-272 PAIs.
8.3.3.6 Cost Model Output
Each module in the cost model generates capital costs
and O&M costs. In addition, the UTS module calculates land costs
(calculated for those facilities that indicated in the
questionnaire that they lack the necessary land for a wastewater
treatment plant) and monitoring costs. The final costs for each
facility consist of the combined capital cost, including the land
cost, from each of the modules and the combined O&M cost,
including the monitoring cost, from each of the modules. The
following combinations of modules are used for the five
regulatory options:
Option i: All PFPR wastewater discharged in 1988
is costed for treatment and discharge. Therefore,
only the UTS module is used.
8-38
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Option 2: Facility wastewater streams coded A are
costed for storage and reuse, streams coded C and
D are costed for treatment and discharge, and
streams coded E are considered reusable at no
cost. Therefore, the storage and reuse module is
used for the code A streams and the UTS module is
used for the code C and code D streams.
Option 3: PFPR wastewater streams coded A are
costed for storage and reuse, streams coded C and
D are costed for treatment and reuse, and streams
coded E are considered reusable at no cost.
Therefore, the storage and reuse module is used
for the code A streams and the UTS module is used
for the code C and code D streams. Options 2 and
3 are assumed to be equivalent in cost; only the
effluent loadings change.
Optipn 4: PFPR wastewater streams coded A are
costed for storage and reuse, streams coded C and
D are costed for off-site disposal by
incineration, and streams coded E are considered
reusable at no cost. Therefore, the storage and
reuse module is used for the code A streams and
the off-site disposal module is used for the code
C and'code D streams.
Option 5: All PFPR wastewater discharged in 1988
is costed for off-site disposal by incineration.
Therefore, only the off-site disposal module is
used.
Cost runs for three facilities, with line item costs, are
presented in Appendix G,,
8.4
DESIGN AND COST ALGORITHMS
This section presents the details and equations used to
develop the cost and dessign algorithms. The UTS module is
discussed in Section 8.4.1; the storage and reuse module is
discussed in Section 8.4.2; and the contract hauling for off-site
8-39
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disposal by incineration module is discussed in Section 8.4.3.
The calculated outputs (costs and pollutant loadings) from the
model are discussed in Sections 9-13 and in the final PFPR cost
report.
8.4.1
UTS Module Design and Cost Algorithm
This section presents the design and cost equations in
the UTS cost module. The UTS cost module is used to determine
facility-specific design parameters and associated capital and
annual O&M costs for all elements making up the universal
treatment system. These elements include:
1. Wastewater storage tanks (discussed in Section
8.4.1.1);
2. One or more process vessels in which batch
physical/chemical treatment steps (emulsion
breaking, hydrolysis, chemical oxidation, and
chemical precipitation) take place (Section
8.4.1.2);
3. An activated carbon treatment system (Section
8.4.1.3);
4. Ancillary pumps and strainers (Section 8.4.1.4);
5. Containment for treatment system equipment and
treatment chemicals (Section 8.4.1.5);
6. Disposal of solid waste residuals (Section
8.4.1.6);
8-40
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7. Land required for the treatment system (Section
8.4.1.7); and,
8. Effluent monitoring (Section 8.4.1.8).
The UTS module determines design parameters based on
facility-specific wastewater volumes and PAIs, and PAI-specific
concentration and treatability data. For Option 1, the facility-
and PAI-specific input datasets are based on all PFPR wastewater
streams discharged at each facility. For Options 2 and 3, the
datasets are based only on streams coded C and D. Once each
treatment system component is sized, the component's costs are
calculated using cost curves obtained from vendor and literature
sources. Copies of all vendor information and other design and
cost data used to develop the cost curves are contained in the
final PFPR cost report.
Some PFPR facilities make use of various filtration
technologies (such as ultrafiltration (UF) and microfiltration)
instead of physical/chemical treatment to produce reusable
effluent. Vendor and PFPR facility information indicate that UF
is a viable technology for both emulsion breaking and for PAI
removal. EPA included design and cost equations for UF in the
UTS cost module, in order to conduct a sensitivity analysis on
the costs associated with the addition of UF to the UTS design.
These equations are presented in Section 8.4.1.9. EPA concluded
that UF adds relatively small capital costs and very small O&M
8-41
-------
costs to the overall UTS costs; however, EPA also concluded that
the incremental treatment provided by UF to the emulsion breaking
and PAI removal steps was not required to achieve effluent
suitable for reuse. As a result, UF is not part of the treatment
system costed for each facility requiring treatment under Options
1, 2, and 3.
8.4.1.1 Wastewater Storage Design and Cost
The UTS module utilizes facility wastewater volume data
to configure both a raw wastewater storage system and a treated
effluent wastewater holding system. The raw wastewater storage
system provides sufficient storage for the maximum size and
number of quarterly wastewater treatment batches through the
process treatment tank. The effluent wastewater holding system,
set equal in volume to the raw wastewater storage system,
provides sufficient storage to test treatment performance prior
to discharge or reuse, and also to minimize the analytical
monitoring costs. Both the raw wastewater and effluent
wastewater storage systems are configured with capacities equal
to a design flow of 120% of the largest of the quarterly volumes
or 120% of the largest batch volume. This calculation ensures
that both storage systems have sufficient capacity to handle the
largest volume of water generated in any one quarter of a year.
Tank sizes range from a minimum of 250 gallons to a maximum of
30,000 gallons (based on vendor literature). Tanks smaller than
8-42
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2,000 gallons are polyethylene tanks and tanks larger than 2,000
gallons are carbon steel tanks. Tank sizes are rounded up to the
next 100 gallons. If the design flow is larger than 30,000
gallons, multiple storage tanks are configured for each storage
system.
8.4.1.2 Process Vessel(s) Design and Cost
The UTS includes a process vessel for batch emulsion
breaking, hydrolysis (if required), chemical oxidation (if
required), and chemical precipitation (if required). The process
vessel is a carbon steel tank equipped with a steam jacket and an
agitator, and has a capacity between 1,000 and 3,000 gallons.
The treatment system cost model spreadsheet determines
the number and size of process vessels required to adequately
treat the design flow in 90 days or less (to prevent triggering
any possible RCRA storage requirements).
The design algorithm is a function of the volume of
wastewater to be treated and the required vessel residence time.
The spreadsheet calculates a required residence time based on the
required time to treat the wastewater for emulsion breaking,
hydrolysis, chemical oxidation, and chemical precipitation. Six
hours are allotted for the chemical oxidation step, 24 hours for
the emulsion breaking step, 15 hours for chemical precipitation,
8-43
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and the necessary time required for hydrolysis, based on the half
lives of the PAIs handled at the facility that are amenable to
hydrolysis (the UTS module determines the time required for
hydrolysis based on the PAI with the lonqest half life) . The
lengths of time required to perform the individual treatment
steps are added and the total number of days (based on 24 hours
per day) required to treat a batch of wastewater is calculated.
The UTS module next optimizes the process vessel size.
Once the required batch treatment time is estimated, the UTS
module selects the smallest vessel that could treat the design
flow in 90 days and calculates costs associated with the selected
vessel. The UTS module then selects the next largest vessel (in
500 gallon increments) and calculates costs to determine whether
a larger vessel would be more cost effective. A larger vessel
would require a larger capital cost but may result in lower O&M
costs because fewer batches of wastewater would have to be
processed through the vessel (resulting in lower labor and energy
costs). If the larger vessel is cheaper than the smaller vessel,
the UTS module then selects the next largest size vessel and
compares costs once again. This process continues until the
least expensive vessel (between 1,000 and 3,000 gallons) is
chosen. In order to compare costs of the different process
vessels, the module uses annualized costs. Annualized costs are
estimated by amortizing the capital costs over ten years
8-44
-------
(assuming 10% interest) and adding the amortized capital costs to
the annual O&M costs.
If a 3,000-gallon vessel is not large enough to treat
the design flow in 90 days, multiple process vessels are included
in the design. In addition, the UTS design algorithm has both
small and large system designs from which to choose. "Small"
PFPR facilities (facilities that treat fewer than 5 batches of
wastewater per quarter) should be able to treat PFPR wastewater
on a batch basis. In this case, the oil layer from the emulsion
breaking step is skimmed off the top of the water in the process
vessel. Additional hydrolysis, chemical oxidation, and sulfide
precipitation steps, as required, take place in the same vessel.
The facility has the flexibility of pumping the aqueous phase of
the demulsified wastewater out of the process vessel, removing
the oil layer as a sludge for disposal, and pumping the
demulsified wastewater back into the process vessel for further
treatment. "Large" facilities (facilities that treat over 5
batches of wastewater per quarter) are assumed to treat PFPR
wastewater on an ongoing basis and may not enjoy this
flexibility. As a result, the UTS design for "large" facilities
consists of two process vessels in series. Emulsion breaking
takes place in the first vessel, and hydrolysis, chemical
oxidation, and sulfide precipitation steps, as needed, take place
in the second vessel. Figures 8-1 and 8-2 are schematic diagrams
8-45
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of the UTS designs for small and large PFPR facilities,
respectively.
The cost equation for carbon-steel, jacketed, agitated
tanks was derived from information in Chemical Engineering
Magazine ('Process Equipment"; April 5, 1982; Richard S. Hall,
Jay Matley, Kenneth J. McNaughton):
Process Vessel Cost ($ per vessel) = 2,030 + (1.4 x volume) -
[2.0X10"4 x volume2]
The final process vessel cost is the unit process
vessel cost multiplied by the number of vessels required,
multiplied by a 48% delivery and installation factor (based on
information from the textbook Plant Design & Economics for
Chemical Engineers, by Max Peters and Klaus Timmerhaus), and
adjusted to 1988 dollars via the Marshall & Swift Index for
process equipment in Chemical Engineering Magazine (July 1984 and
January 1992).
The agitator is designed based on the process vessel
size. The minimum agitator size is 0.5 hp for a 1,000-gallon
vessel, and increases in size by 0.5 hp per 1,000 gallons of
8-46
-------
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8-48
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capacity. The agitator cost is included in the cost of the
process vessel.
Treatment Requirements
The UTS module next calculates the amount of steam,
treatment chemicals (H2SO4, NaOH, NaOCl, and Na2S) , -labor, energy,
and other materials required to treat the annual wastewater
volume, based on the estimated number of treatment batches
required each year. The module also calculates the area required
to store a 6-month supply of treatment chemicals on containment
pallets. Lastly, the UTS module estimates the annual volume of
demulsified oil that would be skimmed from the wastewater after
being treated in the process treatment vessel. This amount is
based on the annual volume of wastewater and the average
concentration of oil and grease measured in PFPR wastewater
samples collected by the Agency.
Steam Requirements
Steam heat is required for emulsion breaking and
hydrolysis. The UTS cost module designs both treatment steps to
operate at 140°F. The module assumes the influent wastewater
temperature to be 50°F, and that negligible heat loss occurs
across the process vessel's jacket. The steam requirement (SR)
is calculated by the equation: *
8-49
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SR (Ib/batch) = heat required (BTU) / heat of vaporization
BTU/lb)
with the heat required (HR) calculated by the equation:
HR (BTU) = vessel volume (gal) x temperature rise x (8.34 Ib/gal)
x (1 BTU/lb °F)
From steam tables, AH^ for 15 psig saturated steam at
140 °F is 945 BTU/lb. Therefore:
SR (Ib/batch) = 0.794 x vessel volume (gal)
This steam requirement is summed for all emulsion
breaking and hydrolysis treatment batches in order to determine
the annual steam requirement for each facility. The UTS module
uses a steam cost of $0.0015 per pound, adjusted from 1980
dollars to 1988 dollars, from Plant Design & Economics for
Chemical Engineers.
8-50
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Sulfuric Acid Requirements
Sulfuric acid (H2SO4) is used to lower the pH for
emulsion breaking and to neutralize treated wastewater following
hydrolysis, chemical oxidation, and chemical precipitation steps.
According to vendor information, 49 mg/L of 100% H2SO4
are required to adjust wastewater pH from 7 to 3. Assuming 50%
H2SO4 is used, this figure is doubled to 98 mg/L, and multiplying
this figure by a factor of 2 (to ensure sufficient acidification)
yields 196 mg/L, or 0.196 g/L. This figure converts to
approximately 0.0016 Ib H2SO4 per gallon of wastewater. As a
result, the acid requirement (AR) for emulsion breaking is
calculated by:
AR (Ib/yr) = 0.0016 Ib H2SO4 x batch volume (gallon) x
annual number of batches
For pH neutralization following alkaline wastewater
treatment steps, the same vendor information that indicates
0.49 g/L of 100% H2SO4 are required to adjust wastewater pH from
12 to 7 is used. Assuming 50% H2SO4 is used, this figure is
doubled to 0.98 g/L, and multiplying this figure by a factor of 2
(to ensure sufficient acidification) yields 1.96 g/L. This
figure converts to approximately 0.016 Ib H2SO4 per gallon of
8-51
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wastewater. As a result, the acid requirement (AR) for the
alkaline wastewater treatment steps is calculated by:
AR (Ib/yr) = 0.016 Ib H2SO4 x batch volume (gallon)
This acid requirement is summed for all emulsion
breaking and alkaline treatment batches in order to determine the
annual H2SO4 requirement for each facility, with a minimum amount
equal to 55 gallons (640 pounds at 50% strength). The UTS module
uses a H2S04 cost of $0.75 per pound for 50% H2SO4/ adjusted from
1992 dollars to 1988 dollars, based on a vendor quote.
The UTS cost module also accounts for the secondary
containment of drums of H2SO4 on spill pallets. Sufficient
storage is provided for a 6 month supply of acid.
Sodium Hydroxide Requirements
Sodium hydroxide (NaOH) is used to elevate the pH for
hydrolysis, chemical oxidation, and chemical precipitation, and
to neutralize treated wastewater following emulsion breaking.
According to vendor information, 0.00366 pounds of 100%
NaOH are required to adjust the pH of 1 gallon of wastewater from
3 to 12. Assuming 50% caustic is used, this figure is doubled to
0.00732 pounds per gallon. As a result, the NaOH requirement
8-52
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(NR) for the alkaline wastewater treatment steps is calculated
by:
NR (Ib/yr) = 0.00732 Ib NaOH x batch volume (gallons)
This NaOH requirement is summed for all alkaline
treatment batches in order to determine the annual NaOH
requirement for each facility, with a minimum amount equal to 55
gallons (690 pounds at 50% strength). The UTS module uses a NaOH
cost of $0.16 per pound, adjusted from 1992 dollars to 1988
dollars, based on vendor information.
The UTS cost module also accounts for the secondary
containment of drums of NaOH on spill pallets. Sufficient
storage is provided for a 6 month supply.
Sodium Hypochlorite Requirements
Sodium hypochlorite (NaOCl) is used for chemical
oxidation via alkaline chlorination. A 10% NaOCl solution is
used as the chlorinating agent (NaOCl was used in the EPA
alkaline chlorination treatability study). Based on the
treatability study, a conservative estimate of 1,000 milligrams
of chlorine are required for every liter of wastewater. This
results in an NaOCl feed rate of 19.2 gallons per 1,000 gallons
8-53
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of wastewater. Therefore, the chlorine requirement (CR) for
alkaline chlorination is calculated by:
CR (gal/yr) =19.2 gallons/1,000 gallons x batch volume (gallons)
This chlorine requirement is summed for all alkaline
chlorination treatment batches in order to determine the annual
NaOCl requirement for each facility, with a minimum amount equal
to 55 gallons. The UTS module uses a NaOCl costs of $0.67 per
gallon, adjusted to 1988 dollars, based on vendor information.
The UTS cost module also accounts for the secondary
containment of drums of NaOCl on spill pallets. Sufficient
storage is provided for a 6 month supply.
Sodium Sulfide Requirements
Sodium sulfide (Na2S) is used when chemical
precipitation is required. Information concerning the amount of
Na2S needed for precipitation were available from EPA
treatability studies and rulemaking development documents, and
from vendors. According to these sources, 0.416 pounds of Na2S
per 1,000 gallons of wastewater is effective in precipitating out
metals. Therefore, the sulfide requirement (SR) for chemical
precipitation is calculated by:
8-54
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SR (lb/yr) = 0.416 pounds/1,000 gallons x batch volume (gallon)
This sulfide requirement is summed for all chemical
precipitation treatment, batches in order to determine the annual
Na2S requirement for each facility, with a minimum amount equal
to 55 gallons. The UTS module uses a Na2S costs of $0.75 per
pound, adjusted from 1992 dollars to 1988 dollars, based on
vendor information.
The UTS cost module also accounts for the secondary
containment of drums of Na2S on spill pallets. Sufficient
storage is provided for a 6 month supply.
Labor Requirement
Labor is estimated on a per batch basis. Each batch of
wastewater processed is assumed to require one hour for pumping
and four hours for chemical addition, wastewater testing, and
other miscellaneous maintenance requirements. An extra hour is
allocated if chemical precipitation is required.
The labor cost is calculated at $19.15 per hour for
unionized operating engineers, adjusted from 1991 dollars to 1988
dollars, based on information from the Richardson Construction
Cost Trend Reporter.
8-55
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Energy Requirement
The total energy requirement is the sum of the energy
needed for the wet vacuum pump (if included in the design) and
the agitator (the process vessel feed pump energy requirement is
discussed in Section 8.4.1.5). The wet vacuum pump is 3 HP and
operates for 0.5 hours per batch, and the agitator is 0.5 HP per
1,000 gallons of process vessel capacity and operates 8 hours per
batch. With 0.746 kw-hr/HP-hr and assuming both the wet vacuum
pump and the agitator operate at 70% efficiency, the total energy
requirement is calculated by:
Total Energy (kw-hr) = Wet Vacuum Pump Energy + Agitator Energy
Wet Vacuum Pump Energy (kw-hr) = # Batches x 0.5 hours x 3 HP x
0.746 x 1/0.7 .
Agitator Energy (kw-hr) = # Batches x 8 hours x 0.5 HP x
(wwVol/1,000) x 0.746 x 1/0.7
The energy cost is calculated at $0.083 per kw-hr, in
1988 dollars, based on U.S. Census data.
Capital Costs of the Process Vessel Batch Treatment System
Capital costs are estimated for the process vessel(s),
wet vacuum pump, and containment pallets used to store the
8-56
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treatment chemicals. These costs account for the actual
equipment costs as well as the delivery and installation of the
equipment. An additional 3% of equipment costs is added to
account for miscellaneous costs associated with the process
vessel system, and an eidditional 10% of equipment costs is added
to account for engineering, administration, and legal costs.
Operating and Maintenance Costs of the Process Vessel Batch
Treatment System
Annual operating and maintenance (O&M) costs are
estimated for labor, energy, steam, and treatment chemical costs.
An additional 3% of the total capital costs associated with the
process vessel system is added to the annual O&M costs to account
for any miscellaneous O&M costs. Another 1% of the total capital
costs is added to the O&M costs to account for annual insurance
costs.
8-57
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8.4.1.3 Carbon Adsorption Unit
Granular Activated Carbon System Sizing
The cost model designs and optimizes the activated
carbon system using a similar methodology as the one used to
optimize the process vessel design. The spreadsheet first
identifies the smallest activated carbon model that would
adequately handle the quarterly flow at a facility (at a default
empty bed residence time (EBRT) of 60 minutes) and estimates
capital and O&M costs for the system. The spreadsheet then
selects the next largest size model and compares that model's
annualized costs with the smaller model's annualized costs to
determine which model is more cost effective. The larger model
would have a higher capital cost but may have lower overall costs
due to fewer carbon bed change-outs. If the larger size results
in less expensive overall costs, the spreadsheet selects the next
largest size model and compares costs once again. This process
continues until the most cost effective of the five activated
carbon models is selected.
To determine the appropriate GAC model, the module
first compares the volume required with the volume capacity of
8-58
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each model. The module determines the volume required using the
following equation:
Volume Required {gal} = Flow {gpm} x EBRT {min}
Using this volume, the module selects the appropriate sized GAG
model (a model that will provide volume equal to or greater than
the volume required) . The module also checks to be sure that the
hydraulic loading of the GAG system does not exceed the
recommended rate of 5 gpm/ft2. The module calculates the
hydraulic loading by dividing the flow rate in gallons per minute
by the cross-sectional area of the selected GAG unit.. If the
selected unit does not result in a hydraulic loading of greater
than 5 gpm/ft2, and provides sufficient volume for the system
flow rate and EBRT, then that unit is appropriate.
Carbon Usage Rate
The carbon usage rate is calculated using the following
parameters: PAI influent concentrations, achievable PAI effluent
concentrations, flow rate, and the saturated loading (based on
8-59
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Energy Costs
Energy is required for the backwash pumping and for the
building. For backwash pump costs, the following equations are
used:
Energy Usage (kw-hr/yr) = # production days x 24 hrs/day
x pump power (hp) x 0.746 kw/hp
Annual Energy Cost = energy usage (kw-hr/yr) x energy cost
($/kw-hr)
However, as the backwash pumps only operate 20 min/day
the usage is reduced by a factor of 20/(60 x 24) = 0.014.
The cost of electricity used in this module is
estimated using a unit value of $0.10/kw-hr. The 1987
statistical abstract reports an energy cost of $0.083/kw-hr for
1984. Using CPI Indexes, this value was indexed to the 1988 cost
of $0.10/kw-hr.
Monitoring Costs
Monitoring costs are calculated by multiplying the
annual number of activated carbon treatment batches by the TOC
analytical cost of $31 per analysis, based on analytical lab
quotes.
8-62
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Carbon Cost
Information on carbon costs was obtained from an
activated carbon unit vendor during the development of the
Manufacturers cost model. For regenerated carbon, the purchase
cost was $0.65/lb in 1990 and the cost to regenerate carbon was
$0.15/lb. Freight costs were $1.50/mile when delivering
2,000-pound bulk bins and $2.50/mile when delivering 20,000-pound
bulk loads. These costs are indexed from 1990 dollars to 1988
dollars.
8.4.1.4 Pumps and Strainers Design and Cost
The UTS cost module also includes process vessel feed
pumps, activated carbon system feed pumps, blowdown waste storage
pump (for large systems), and in-line strainers to filter out
coarse particles. The number and sizes of the pumps and
strainers is based on the UTS size. Small systems have one
process vessel, and therefore one process vessel feed pump and
one in-line strainer. Large systems have separate process
vessels for emulsion breaking pretreatment and for alkaline
wastewater treatment steps. As a result, the large UTS systems
would have multiple process vessel feed pumps; one per vessel.
The large UTS systems also include two in-line strainers.
8-63
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Bach process vessel has one centrifugal pump system.
In addition, the UTS design includes a centrifugal waste pump for
transferring stored blowdown waste to tanker trucks. Each
centrifugal pump system is designed to have a capacity equivalent
to the nominal flow rate in gallons per minute (gpm) of the
wastewater flow rate to the UTS. If the flow rate is less than 5
gpm, the module assumes a minimum flow rate of 5 gpm, and
therefore a minimum pump capacity of 5 gpm. Pump capacities,
power requirements, and costs are presented in the final PFPR
cost report. The table presents small pump and large pump cost
curves; the large pump cost curve is utilized for pump
requirements exceeding 250 gpm.
Annual O&M costs for the pumps and strainers include
pump energy costs and strainer cleaning labor costs. Pump energy
costs are calculated using the same equations as the activated
carbon backwash pump energy costs. Annual strainer cleaning
labor is estimated to be 15 minutes per strainer per batch. The
same labor rates as noted in the process vessel module are used
in this module to determine the total labor cost.
8-64
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8.4.1.5 Containment System Design and Cost
The treatment, system design includes a concrete
containment system that encloses the wastewater storage tank(s),
the process vessel(s), the activated carbon feed tanJc(s) , the
activated carbon bed(s), the backwash system (if one is specified
by the model), and the waste disposal tank. The. containment
system consists of a concrete pad and a 2.5-foot concrete dike
and is designed to contain at least 125% of the volume of the
largest tank specified by the cost model.
To determine the required area and perimeter of the
containment system (c/s), the module calculates the following
three quantities:
Amount of area required for the tanks - the spreadsheet
calculates the area in square feet needed for each
individual tank and then adds the areas to
determine a total space required to house the
tanks. This number is multiplied by 1.2 to
provide space for other equipment (such as pumps,
etc.).
Amount of containment provided - using the total space
required, the module then calculates the
containment that this space would provide in
gallons.
Amount of containment = [(area of c/s {sq. ft.} -
2(area displaced by tanks)) * 2.5 ft] * 7.48 gal/ft3
8-65
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3. Amount of containment required - 125% of the volume of
the largest tank is required. This accounts for
any precipitation that may build up in the
containment system. Thus, if the largest tank
specified is a 20,000-gallon tank:
Containment required = 1.25 * 20,000 gal = 25,000 gal
If the amount of containment provided is not
sufficient, then the spreadsheet automatically determines the
area required to provide sufficient containment. This is
calculated by the following equation:
Area of c/s {sq. ft.} = [(area of c/s required {gal} x
1 ft3/?.48 gal) / 2.5 ft] + S(area displaced by tanks)
The perimeter of the containment system is estimated by the
following equation:
perimeter {ft} = integer [sq.rt.(area of c/s {sq. ft.}) + 1] x 4
Capital Costs of the Containment System
Capital costs are estimated for the construction of a
concrete pad and concrete dike for a containment system as well
as the initial application of a protective coating on the
containment system. An additional 30% of the costs of the
concrete containment system is added for fees and design costs.
An additional 5% of the containment system cost and the fees and
8-66
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design costs is added to account for contingency costs. All
costs are indexed from 1991 dollars to 1988 dollars. Each of
these costs is described below:
Concrete Floor - An EPA/OPP report estimates a 1991
cost of $4 per square foot of installed reinforced
concrete. Thus the cost of the concrete floor is
estimated by:
1991 cost = $4 x area of c/s {sq. ft.}
Concrete Dike - The EPA/OPP report estimates a cost of
$16 per lineal foot of dike for a height of 2.5 feet.
Thus the cost of the concrete dike is estimated by:
1991 cost — $16 x perimeter of c/s {ft}
Floor Coating - The EPA/OPP report estimates a cost of
$0.90 per square foot to adequately coat the concrete
floor with an appropriate sealant.
1991 Cost = $0.90 x area of c/s {sq. ft.}
Dike Coating - The EPA/OPP report estimates a cost of
$0.90 per square foot of concrete.
1991 cost = $0.90 x height of dike {ft} x perimeter of c/s {ft}
Operating and Maintenance Costs of the Containment System
,- «•
The cost model estimates annual costs associated with
the upkeep of the containment system. Costs are estimated
assuming that the concrete containment system would be recoated
every three years with a protective sealant. An estimated
recoating cost of $.90 per square foot is used in the module.
The coating costs are amortized over three years to estimate an
annual coating cost.
8-67
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1991 Recoating Cost = $.90 x [(area of c/s {sq. ft.} -
area displaced by tanks {sq. ft.}) + (ht. of dike {sq. ft.}
x perimeter of dike {ft})]
This cost is then indexed from 1991 dollars to 1988 dollars.
8.4.1.6 Waste Disposal Design and Cost
The UTS cost module includes design and cost algorithms
for off-site disposal of the reject stream from emulsion breaking
and settled solids from chemical precipitation. Off-site
disposal consists of contract hauling for off-site incineration.
The size of the off-site disposal stream is calculated
based on sampling data and the facility-specific wastewater flow
rate. EPA sampling data indicate an average oil and grease
concentration of 0.2% (2,000 ppm) in raw, commingled PFPR
wastewater. The UTS design assumes that this oil and grease
measurement is representative of the amount of oil and other
emulsifiers in PFPR facility wastewater. The emulsion breaking
oil layer volume is therefore calculated by multiplying the
wastewater flow rate by 0.2%. The solids contribution from
chemical precipitation is assumed to be .equal to the mass of
sodium sulfide added to the process vessel.
8-68
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A sensitivity analysis was conducted on the impact of
varying the percentage of wastewater disposed of as UTS blowdown
(consisting of the oil layer from emulsion breaking, settled
solids from chemical precipitation, and additional blowdown from
the UTS) and the duration of storage of UTS wastes. Compliance
costs were calculated based on blowdown rates ranging from 0.2%
of the UTS feed rate to 10% of the UTS feed rate. Compliance
costs were also calculated based on solid waste storage times of
one quarter (90 days) or one year.
At some facilities, the actual reject stream from
de-emulsification, or ultrafiltration, or some other solids and
oil and grease removal operation might be greater than the
estimated 0.2% depending on the facilities7 wastewater matrices.
Vendor information for ultrafiltration systems approximate this
figure at between 5 and 10 percent. In addition, PFPR facilities
may need to incorporate a "blowdown" stream, larger than the 0.2%
de-emulsification reject stream, into their treatment system to
prevent the buildup of dissolved solids from the reuse of their
treated wastewater. To determine the sensitivity of the
estimated UTS operating costs to the assumed blowdown rate, PFPR
facility O&M costs (including capital costs amortized @10% for 10
years) have been estimated based upon the following waste
disposal analyses:
8-69
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Slowdown streams of 0%, 5%, and 10%, assuming that
waste is transported off site at least once,every
90 days (based on the assumption that the waste is
hazardous and is covered by RCRA storage
regulations); and
Slowdown streams of 0%, 5%, and 10%, assuming that
waste is transported off site once per year (based
on the assumption that the waste is not considered
a hazardous waste).
EPA's estimates for hauling every 90 days show a
significant increase in costs,occurs between the 0% blowdown and
the 5% blowdown calculations, while a smaller increase occurs
between the 5% blowdown and the 10% blowdown calculations. Since
most PFPR facilities would not generate a blowdown stream larger
than a full truckload (regardless of whether the blowdown is 5%
or 10%) , and the transportation costs to haul the waste 500 miles
is a significant portion of the total disposal costs, the
difference between the disposal costs assuming a 5% blowdown and
the costs assuming a 10% blowdown is due only to the additional
incineration fees (about $5 per gallon). For some facilities the
estimated costs for the 5% blowdown and the 10% blowdown
scenarios are identical. These facilities would generate small
volumes of waste and, because non-bulk incineration fees are
charged by 55-gallon drums, the disposal costs are identical
(i.e., the incineration fee is the same for 20, 30, or 50 gallons
of waste since these volumes are less than one 55-gallon drum).
EPA also estimated costs assuming that waste is only hauled off
site once per year. These costs are significantly lower than the
8-70
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costs estimated with the 90-day assumption because transportation
costs are only incurred once rather than quarterly.
The UTS cost module calculates costs for a storage tank
sized to hold the maximum quarterly off-site disposal stream
volume. The module also calculates off-site disposal O&M costs
for the oil layer stream on a quarterly basis, and for the
settled solids stream on an annual basis. The O&M costs include
the transportation and incineration costs. These costs are
discussed in detail in Section 8.4.3.
8.4.1.7
Land cost
Land costs are calculated for the facilities that
indicated in their PFPR questionnaire response that they lack
space for a wastewater treatment system. The size required for
the containment system is used as the amount of land required for
the treatment system. State-specific land costs were derived
from the Industrial Real Estate Market Survey. 1989. The cost
module determines if land is required, identifies the facility's
state, calculates space requirements, and calculates the total
land cost based on the land cost for that state.
8.4.1.8 Monitoring
8-71
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In addition to the TOG analytical costs associated with
the operation of the activated carbon adsorption system, PFPR
facilities may incur analytical monitoring costs as part of
evaluating treatment system performance or, in the case of
Options 1 or 2 being the selected option, demonstrating
compliance with numerical discharge limitations. Although
Options 3 and 3/S would essentially require zero discharge and,
thus, there would be no numeric standards with which to
demonstrate compliance, there is also a component of treatment
(UTS) in the cost model when costing these two options. The
Agency assumes facilities will monitor wastewater after treatment
and before recycling it back to the facility to ensure it has
been adequately treated. The cost model therefore contains a
monitoring cost dataset, consisting of the analytical methods
used to detect individual PAIs and corresponding method costs,
that is used to estimate monitoring costs for Options 1, 2, 3 and
3/S.
The analytical methods dataset has been compiled
primarily from the August 1993 Methods for the Determination of
Nonconventional Pesticides in Municipal and Industrial
Wastewater. a compendium of EPA-approved analytical methods for
those PAIs where Manufacturers' limits were proposed. Additional
PAI analytical methods discussed in analytical reports from
treatability studies and sampling episodes conducted by EPA to
support development of effluent limitations guidelines and
8-72
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standards for the pesticides industry have been included when
available. Finally, costs have been extrapolated for some PAIs,
based on the following methodology:
Use of the same method(s) as for
structurally-similar PAIs for those PAIs without
approved methods. In cases where more than one
method is available for structurally-similar PAIs,
the most expensive method is used to estimate
costs.
Analytical methods are assumed to cost $200 (an
approximate average cost of PAI analytical
methods) for those PAIs lacking analytical methods
and methods for structurally-similar PAIs.
The treatment system design includes effluent storage
with sufficient capacity to hold the volume of wastewater
generated by each facility each quarter. As a result, monitoring
is costed on a quarterly basis. If a facility handles several
PAIs that can be analyzed with the same method, that analysis
would only be run one time per quarter. The model determines the
minimum number of analyses required by the PAIs assumed present
in each facility's wastewater. The analytical methods and costs
for each PAI are included in the treatability dataset and can be'
found in Appendix B of this document.
8.4.1.9 Ultrafiltration
An alternative pretreatment method to remove oil and
grease is to process PFPR wastewater through a ultrafiltration
8-73
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(UF) unit. Ultrafiltration is a type of membrane separation
(filtration) in which a pressure driven, semipermeable membrane
is used to achieve selective separations of suspended and
colloidal solutes from a process wastewater. The "tightest" UF
membrane is typically capable of rejecting molecules having
diameters greater than 0.001 micron (3.94 x 10"8 inches) or
nominal molecular weights greater than 2000. During operation,
the feed solution flows across the surface of the membrane, clean
water permeates the membrane, and the contaminants and a portion
of the feed remain. UF systems operate at feed pressures of
50-200 pounds per square inch gauge (psig). Some pretreatment
may be necessary to prevent membrane fouling. UF systems are
capable of recovery of up to 90-95 percent of the feed as product
water. •
Although UF is a viable technology for PFPR
wastewaters, EPA is not currently using UF as a basis for setting
limitations and standards in the proposed effluent guidelines.
However, EPA did develop a design and cost algorithm for
Ultrafiltration. At present, this algorithm is not activated
when running the UTS cost module. The UF design and cost
algorithm is briefly discussed below for the purpose of providing
a complete discussion of the engineering costing work performed
for this proposal. EPA also performed a sensitivity analysis on
the cost of adding the UF unit to the UTS, as discussed in
Section 8.4.1.
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There are two UTS designs that incorporate UF for
pretreatment. Small UTS systems (that handle up to five
treatment batches per q;uarter) would replace emulsion breaking
with UF. Vendor information and limited field sampling data
indicates that UF is effective in separating an aqueous stream
from an emulsified oil stream, with a reject rate of between 5%
and 10 percent. The reject rate is specific to the particular
wastewater feed composition. Large UTS systems retain a separate
emulsion breaking step to minimize the emulsifier load on the UF
Unit. This separate step also decreases the volume of the reject
stream from the UF unit. De-emulsified wastewater treated
through the second process vessel for hydrolysis, chemical
oxidation, and/or sulfide precipitation is pumped through the UF
unit a second time to remove any solids in the effluent that did
not settle out in the process vessel. This treatment reduces the
solids in the activated carbon system feed and minimizes the
activated carbon system backwash requirements.
The UF design and cost algorithm is based on the use of
one of five UF units at a particular vendor. The size, power
requirements and cost of these units are presented in the final
PFPR cost report. The units are sized based on the batch volume
treated through the UTS. The UF design is based on the capacity
of the UF unit and the number of UF units required to handle the
daily UTS volume. The spreadsheet then determines the total
capital cost (in 1988 dollars, including delivery and
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installation) and O&M costs. O&M costs include labor and energy
costs. UF operation is assumed to require 1 hour of labor per
batch, at $17.21 per hour (in 1988 dollars).
8.4.2
Storage and Reuse Cost Module
This section presents a discussion of the storage and
reuse (S&R) cost module. This module accounts for all costs (in
1988 dollars) associated with the purchase and installation of
wastewater storage drums and tanks, the construction and upkeep
of a containment system, and any applicable land costs.
8.4.2.1 Storage Design
The S&R module first determines line-specific storage
requirements for each facility. Input data from the PFPR
questionnaire database includes the number of lines at each
facility and the number of products and the' annual wastewater
volume on each line. The module then calculates the number of
drums or tanks (and tank sizes, if tank storage is required)
needed to store the wastewater associated with each product on
each line.
The S&R module calculates a design flow and required
storage capacity for each line. The module makes the assumption
that each product generates an equal amount of wastewater on each
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line. The design flow is calculated by dividing the wastewater
flow rate on each line by the number of products. The required
storage capacity is 120% of the design flow. Drum storage is
selected for smaller capacity requirements. Either one or two
drums per product are selected, based on the design flow. If
this capacity exceeds 110 gallons (two 55-gallon tanks), then
tank storage is selected for the line. For tank storage, the
module also calculates the containment area required, based on
the containment algorithm discussed in Section 8.4.1.5.
The S&R module also includes a 3 hp centrifugal pump
for transferring wastewater between the line equipment and the
storage tanks or drums. The design is for a portable pump, so
that only one should be required regardless of the number of
lines or products.
8.4.2.2 Containment: Design
The S&R module determines the area displaced and the
containment area required for each storage tank. The module then
uses the algorithm discussed in Section 8.4.1.5 to calculate the
containment costs for a concrete pad and 2.5-foot concrete dike,
as well as the initial coating of the containment system.
Containment pallets are used for drum containment.
8.4.2.3 Capital Costs
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The capital costs consist of the tank costs, pump
costs, drum costs and containment costs. According to vendor
information, each drum costs $55, which is then indexed in the
module to 1988 dollars. Containment costs are calculated for the
concrete floor, the 2.5-foot concrete dike, the floor coating,
and the dike coating. All capital costs are increased by 30% for
added fees and design costs. An additional 5% is added for
miscellaneous costs.
8.4.2.4
O&M Costs
The O&M costs consist of the pump energy requirement
and containment system recoating. These costs are calculated .
using the algorithms discussed in Sections 8.4.1.4 and 8.4.1.5,
with the coating costs amortized over three year periods. All
costs are indexed to 1988.
8.4.3
Off-Site Disposal Cost Module
This section presents a discussion of the off-site
disposal, or contract haul (CH), cost module. The CH module
calculates off-site disposal costs based on contract hauling PFPR
wastewater for off-site incineration.
Off-site disposal costs can be calculated for
stream-specific wastewater sources (e.g., code C and D streams
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for Option 4, as discussed in Section 8.3.3.3) or for the entire
wastewater flow from a facility (e.g., Option 5). The CH module
utilizes quarterly wastewater volume data to configure a
wastewater storage system that has the capacity to hold the
quarterly design flow (120% of the largest of the quarterly
volumes and the large batch volume). This calculation ensures
that the storage system can handle at least the volume of water
generated in any one quarter of a year.
The CH module optimizes a storage design consisting of
either a tank storage system or a 55-gallon drum storage system.
For each facility, the CH module designs and costs each storage
system and then selects the less expensive design. In order to
compare costs of the tank and drum storage designs, the module
annualizes total costs for each system by amortizing capital
costs over ten years (assuming 10% interest) and adding these
costs to the O&M costs.
The cost of contract hauling wastewater off site for
incineration depends on the volume of wastewater being hauled and
how often the wastewater must be hauled. Hauling frequency is
based on the conservative assumption that wastewater is not
stored on site for longer than 90 days. (Facilities may not have
any RCRA hazardous pesticide waste and, therefore, would be able
to store/hold their waste for longer than 90 days.) Thus, if a
PFPR facility generated wastewater throughout the year, the
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facility would incur costs of at least one disposal trip per
quarter of operation, even if the volume of wastewater generated
was very small. For example, if a facility generated 250 gallons
each quarter of the year, the facility would incur costs for
hauling 250 gallons of wastewater off site at least four times.
If another facility generated 1,000 gallons of wastewater
annually but generated all the wastewater in one. quarter, this
facility would incur costs for hauling the wastewater off site
only once. Although the actual incineration fees would be the
same for both facilities (based on a per gallon unit cost of
incinerating hazardous pesticide wastewaters), the total costs
would be much higher for the first facility due to the additional
disposal trips (mileage fees) required and the additional
sampling analyses required for each batch of wastewater being
incinerated.
8.4.3.1 System Design - Tank Storage
The CH module configures a storage system consisting of
a tank and centrifugal pump that can handle the design flow. If
the design flow is larger than 30,000 gallons, multiple storage
tanks are configured. Tanks having a volume of less than 2,000
gallons are constructed of polyethylene while tanks having a
volume of 2,000 gallons or greater are constructed of carbon
steel. In addition to the storage tank(s), the module also
includes the cost of a centrifugal pump to transfer the
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wastewater from the storage tank to a truck used to haul the
wastewater. The tank sizing and cost algorithms are the same as
those discussed in Section 8.4.1. A 70 gpm pump is specified for
tank storage, because it can transfer 5,000 gallons of wastewater
to a tanker truck in under 2 hours.
The CH module next estimates the number of disposal
trips that would be required to haul a facility's wastewater off
site. For the tank storage configuration, the module assumes
that all wastewater would be hauled in 5,000-gallon tank trucks.
The CH module design also includes a concrete
containment system to enclose the wastewater storage tank(s).
The containment system consists of a concrete pad and concrete
dike, and is designed to contain at least 125% of the volume of
the largest tank specified.
Capital Costs of the Tank Storage Design
The CH module estimates capital costs for the storage
tank(s) and the transfer pump. These costs account for the
actual 'equipment costs as well as the delivery and installation
of the equipment. The module also estimates costs for the
construction of the containment system. Capital costs are
estimated for the construction of the concrete pad and concrete
dike as well as the initial application of a protective coating
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on the containment system. The containment cost equations are
presented in Section 8.4.1. An additional 30% of the costs of
the concrete containment system is added for fees and design
costs. An additional 5% of the cost of the containment system
cost is added to account for contingency costs. All costs are
indexed to 1988 dollars.
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Operating and Maintenance Costs of the Tank Storage Design
The CH modules estimates annual O&M costs associated
with the tank storage design, which include labor, energy,
transportation, and incineration costs. The labor costs cover
the labor required to routinely check the integrity of the tanks
and the labor required to transfer the wastewater from the
storage tanks to the trucks used for hauling. The energy costs
cover the energy required to operate the transfer pump. Annual
transportation costs are based on the number of annual disposal
trips required. The module estimates transportation costs based
on a 500-mile trip. Estimated transportation costs also account
for demurrage fees that are typically charged while a truck is
being loaded. The demurrage cost is independent of the volume of
wastewater being hauled in the 5,000-gallon tank truck. In other
words, the demurrage cost estimated for transporting 500 gallons
of wastewater would be the same as the cost estimated for
transporting 5,000 gallons of wastewater. Annual incineration
costs are estimated based on a unit cost per gallon of wastewater
incinerated. The module also accounts for an analysis fee
typically charged by incineration facilities for each batch of
wastewater incinerated.
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Tank inspection costs
Inspection of the integrity of the facility storage
tank is estimated to take 15 minutes per day, as recommended by
CAPDET, the Army Corps of Engineers wastewater treatment cost
model modified for use in estimating compliance costs for the
Pesticides Manufacturers Industry effluent limitations
guidelines. Thus, the annual inspection time can be figured as
follows:
Annual Inspection Time {hrs} = (15 min./day * 60 min./hr) x
90 days/quarter x # quarters/year
To determine labor costs, the annual inspection time is
multiplied by an estimated labor rate in 1988 dollars:
Annual Inspection Costs = Annual Inspection Time {hrs} x
1988 Labor rate {$/hr}
The 1988 labor rate is estimated using a 1991 hourly
rate of $19.15 for a plant operator, indexed to $17.21 in 1988
dollars.
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Truck Loading Costs
The truck loading costs include the cost of labor
incurred for the time spent loading the tank truck with
wastewater. It takes approximately 3 hours to fill a
5,000-gallon tank truck based on the following estimates:
Connect time
Disconnect time
Loading time
= 0.5 hr
= 0.5 hr
= 5,000 gal/70 gpm
= 72 min or 1.2 hr
Total time
= 2.2 hr
A conservative estimate of 3 hours is used. Thus, the annual
truck loading costs can be figured by the following:
Annual Costs =
(labor rate {$/hr} x 3 hr) x # loads per
year
$52 per load * # loads per year
Pump Energy Costs
The pump is assumed to operate only when the storage
tank is being emptied into a tank truck. The pump designed for
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this model is a 70 gpm pump requiring a 3 hp motor. Thus, for
every load, the pump requires the following amount of energy:
Energy per load {kw-hr} =
2 hr x 3 hp x 0.746 (kw/hp)
4.476 (kw-hr/load)
A unit energy cost is estimated using the 1984 cost reported
in a U.S. Census Report and indexed to 1988 dollars.
Annual Pump Energy Costs - 4.476 kw-hr/load * $0.100/kw-hr *
# loads/year
Transportation Costs
All PFP wastewater is hauled in bulk by a 5,000-gallon tank
truck when tank storage is designed. Transportation fees include
the cost per mile to haul the wastewater to an incineration
facility plus any applicable demurrage fee. The highest estimate
of transportation fees quoted from a vendor was $5.00 per loaded
mile.
Transportation costs for bulk wastewater also includes a
demurrage fee incurred for each load. Most transportation
services allow for 2 hours free demurrage time for both loading
and unloading the truck (total of 4 hours), and charge $80/hr
thereafter (highest quote). Because this module assumes a
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loading and unloading time of 3 hours each, a total demurrage fee
of $160 is incurred for each load.
Thus, the annual transportation costs, indexed to 1988
dollars, can be estimated as follows:
Annual Transportation Costs = # loads per year *
[$5/mi * 500 mi + $160 demurrage] * 852.0/932.9
= $2,445/load * # loads per year
Incineration Costs
Incineration costs for the tank storage design include an
incineration fee per gallon of wastewater as well as a sampling
and analysis fee per load of wastewater. The disposal fee used
in this module is $4.67 per gallon of pesticide wastewater plus
$300 sampling and analysis fee per load of wastewater. These
costs were estimated from the following sources:
1982 OCPSF Industry Information
From the 1982 Technical Development Document for the OCPSF
Industry, an estimated incineration fee of $0.90/gal is used for
bulk pesticide wastewaters.
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1990 Vendor Quotes
In 1990, vendor quotes were obtained when incineration costs
were being estimated for the Pesticide Chemicals Manufacturing
Industry. An estimated incineration fee of $6.00/gal is used for
bulk pesticide wastewaters.
1992 Vendor Quotes
In developing this cost module, vendor quotes were obtained
in March, 1992 for incineration fees. The highest quote obtained
was $7.10 per gallon of pesticide wastewater in bulk form.
Using the estimated costs for these three years, a linear
regression was performed to estimate the 1988 incineration costs
to be $4.67/gal.
Disposal costs also include a $300 sampling fee per
wastewater load. This cost was obtained from vendors and is used
for a 1988 estimation.
Annual disposal costs = $4.67/gal * # gal wastewater/yr +$300 *
# loads/yr
Containment Costs
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The final costs that the CH module estimates are the annual
costs associated with the upkeep of the containment system.
Costs are estimated to recoat the concrete containment system
every three years with a protective sealant. The coating costs
are amortized over three years to determine an annual coating
cost. The containment system sizing and cost algorithms are the
same as those discussed in Section 8.4.1.5.
8.4.3.2 System Design - Drum storage
The CH module also configures a storage system designed for
drum storage. Based on the annual volume of wastewater generated
at a facility and how often the wastewater is generated, the
module estimates the number of drums required to store the
wastewater and the number of disposal trips required to haul the
wastewater off site for incineration.
The only capital costs associated with the drum storage
design is the purchase of containment pallets used to store and
contain drums of wastewater. According to vendor information,
each containment pallet costs $349. The model estimates costs
for the containment pallets based on the number of drums required
to store the design flow. All costs are indexed to 1988, the
year of the PFPR questionnaire.
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The CH module estimates annual O&M costs associated with the
drum storage design, which include drum purchase, labor,
transportation, and incineration costs. The labor costs cover
the labor required to routinely check the integrity of the drums,
and the labor required to load the drums onto the trucks used for
hauling. Annual transportation costs are based on the number of
annual disposal trips required. Estimated transportation costs
also account for demurrage fees that are typically charged while
a truck is being loaded. Unlike the transportation costs
estimated for tank storage, the transportation costs estimated
for drum storage depend on the volume of wastewater being hauled
each disposal trip. For instance, the cost estimated for a truck
to haul five drums would be substantially lower than the cost
estimated for a truck to haul 80 drums. Annual disposal costs
are estimated based on a unit cost per gallon of wastewater being
incinerated. The module also accounts for an analysis fee
typically charged by incineration facilities .for each batch of
wastewater being incinerated. All costs are indexed to 1988, the
year of the PFPR questionnaire.
Drum Purchase costs
According to vendors, the typical cost of a 55~gallon,
DOT-approved drum constructed of carbon steel is $55 (including
delivery) in 1992. (Refurbished drums that meet DOT
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specifications may also be used to store wastewater at a lower
cost). This cost is indexed to 1988 dollars.
Annual drum purchase cost = # drums per year * $50.23/drum
Drum inspection Costs
Similar to the tank storage design, an inspection time of 15
minutes per day is assumed for each production day. The 1988
salary of $17.21/hr (as derived in the tank storage design) is
assumed.
Annual inspection cost = (15 min/day * 1 hr/60 min * # production
days/yr) * $17.21/hr
Transportation Costs
For the drum storage design, all drums are assumed to be
hauled by an appropriate size flat-bed truck or van.
Transportation fees include the cost per mile to haul the drums
to an incineration facility (default value of 500 miles) plus any
demurrage fee. For transportation of drummed wastewaters, the
cost depends on the number of drums being hauled. For full truck
loads (40 to 80 drums), a 1992 fee of $5.00 per loaded mile is
used. This fee, indexed to 1988 dollars, is $4.57 per loaded
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mile. Thus, with a default distance of 500 miles, the
transportation cost of a full truckload is estimated at $2,285.
For loads that are less than 40 drums, a distribution of
price by number of drums was provided by a vendor, and these
costs are used to develop an equation. The following costs were
provided:
Number of Drums
1-10
11 - 20
21 - 30
31 - 40
1992 Cost (default
distance of 500 miles)
$790
$900
$1,000
$1,190
Using these data, transportation costs are estimated using
the following equation:
1992 Cost = 13 * number of drums + $710
1988 Cost = 852.0/932.9 * (1992 costs)
Transportation costs must also account for any demurrage
fees. As in the tank storage design, it is assumed that
transportation facilities allow 2 free hours for loading and
unloading the truck (4 total hours) and charge $80 per hour
thereafter. As recommended by CAPDET, an estimated rate of 4
drums per hour is used for loading and unloading the truck.
Thus, the following equation is used to estimate loading and
unloading costs:
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Annual demurrage fees = (2 * # drums per year - 4 *
# trips per year) * $80/hr
If the equation yields a negative number, then no demurrage
fee is incurred.
incineration Costs
Incineration costs for the drum storage design include an
incineration fee per gallon of wastewater as well as a sampling
and analysis fee per truck load of wastewater. The incineration
fee used is $8.13 per gallon of pesticide wastewater (or $447 per
drum) and a $300 sampling fee per load.
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1982 OCPSF Industry Information
From the 1982 Technical Development Document for the OCPSF
Industry, an estimated incineration fee of $1.50/gal is used for
drummed pesticide wastewaters.
1990 Vendor Quotes
In 1990, vendor quotes were obtained when incineration costs
were being estimated for the Pesticide Chemicals Manufacturing
Industry. An estimated incineration fee of $10.00/gal is used
for drummed pesticide wastewaters.
1992 Vendor Quotes
In developing this cost module, vendor quotes were obtained
in March, 1992 for incineration fees. The highest quote obtained
was $700 per drum or $12.73 per gallon.
Using these estimated costs for these three years, a linear
regression was performed to estimate the 1988 incineration costs
to be $8.13 per gallon.
Incineration costs also include a $300 sampling fee per
wastewater load. This cost was obtained from vendors and is used
for a 1988 estimation.
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Annual incineration costs = $447/drum * # drums/year
+ $300 * loads/year
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SECTION 9
BEST PRACTICABLE CONTROL TECHNOLOGY (BPT)
9. 0 INTRODUCTION
EPA promulgated BPT for the Pesticide Chemicals Point Source
Category, including Subpart C: Pesticide Formulating and
Packaging, on April 25, 1978 (43 EB, 17776) and September 29, 1978
(43 F_R 44846) . BPT limitations requiring zero discharge of
process wastewater pollutants to navigable waters were set for all
pesticide formulating and packaging operations (Subcategory C).
9 . 1 BPT APPLICABILITY
9.1.1
Pesticide Chemicals Fo rmu1at ina.
EPA is not proposing any substantive amendments -to the
existing BPT provisions applicable to Subcategory C, established
in 1978. However, for clarification purposes, EPA is proposing to
add the word repackaging to the title and the applicability
provision for this subpart (455.40) . This change is being
proposed to clarify the types of operations covered and does not
expand the current coverage of the BPT effluent limitations
guidelines. The term "packagers" in the Subpart C applicability
provision, 40 CFR 455.40, was always intended to cover repackaging
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under the term packaging.
BPT limitations for-this subcategory require zero discharge
of wastewater pollutants. EPA's information shows that the
majority of pesticide formulating, packaging and repackaging
(PFPR) facilities are complying with this requirement by virtue of
the large numbers of facilities which reported zero discharge (an
estimated 66 percent of the survey population) and because nearly
all facilities that reported discharging are indirect dischargers
(to POTWs) and are not covered by the BPT limitations.
The BPT technologies identified in the 1978 regulation as
capable of achieving zero discharge were water conservation, reuse
and recycle practices, with any residual water being evaporated or
hauled off-site to a landfill. Several facilities that
participated in a study of the industry for that rulemaking
reported using evaporation as the principal means for disposing
of wastewater from their formulating and packaging operations.
Since that time, the practice of disposing of liquid hazardous
wastes in landfills has been banned, (Nevertheless, one recently
surveyed facility did indicate that they send wastewater to a
landfill.) Additionally, EPA finds that disposal of wastewater by
evaporation is now a less preferred practice, because of concerns
about pollutant transfers among media (e.g., air, soil,
groundwater). In our recent survey, EPA has found that only a
small proportion of PFPR facilities use evaporation to achieve
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zero discharge. Mostly, zero discharge is attained through
recycle and reuse, though some facilities report hauling their
wastewater off-site. Off-site destinations include incinerators,
deep wells, and commercial waste treaters (in some cases, wastes
are sent to the registrant or manufacturer). Some facilities that
are achieving zero discharge have gone to considerable expense and
installed state-of-the-art wastewater treatment and reuse/recycle
practices to accomplish it.
Because of recent revisions to the effluent guidelines for
pesticide manufacturers (September 28, 1993; 58 FR 50637), some of
the facilities that manufacture pesticide active ingredients and
also formulate and package pesticide products may have to change
their current practices to comply with the existing BPT
regulations for formulating and packaging. A number of the direct
discharging pesticide manufacturers that also formulate and
package have been combining pesticide manufacturing wastewaters
with wastewaters generated from pesticide formulating and
packaging. They are able to combine these wastewaters and still
achieve the limits in their NPDES permits, which provide numeric
discharge limits for pollutants generated in the pesticide
manufacturing process. Although they are given no allowance for
the pollutants present in their formulating and packaging
wastewater they have been able to discharge this wastewater
because the treatment systems reduce the pollutants in the
combined wastewater to the level that is specified in their
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permits. The recently issued pesticide manufacturing regulation
sets production-based BAT limits for specific pesticide active
ingredients. These limits supersede the previous concentration
based BPT limit for "total pesticides" which controls the sum of a
number of specific PAIs, not individual PAIs. Due to these newly
issued BAT limits, it is unlikely that pesticide manufacturing
facilities will be able to continue to discharge their formulating
and packaging wastewater and still be in compliance with their new
permit limitations for some of the individual PAIs.
The costs incurred by these direct discharging
PFPR/Manufacturers need not be accounted for in this rulemaking
because BPT is already set at zero discharge. Nevertheless, to
understand the magnitude of these costs, EPA has estimated the
costs and performed an analysis of their economic impacts. EPA's
analysis concludes that there would be no significant adverse
economic impacts due to these costs.
For the remainder of the subcategory, EPA does not project
any costs associated with BPT regulations for any direct
discharging pesticide formulating, packaging or repackaging
facilities, because BPT for Subcategory C is not being amended.
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9.1-2 Repackaging of Agricultural Pesticides Performed
by Refilling Establishments (Subeatecrory E)
As discussed in earlier sections, refilling establishments
generate wastewater through cleaning minibulk containers and bulk
storage tanks; also, contaminated stormwater often falls inside
their containment systems. BPT for these wastewaters from
repackaging operations is proposed to be zero discharge of process
wastewater pollutants.
The existing BPT regulations do not cover refilling
establishments. As previously discussed, the practice of
refilling minibulks, etc. did not begin until the 1980s, i.e.,
after the original BPT regulation was promulgated in 1978.
Further, the refillers are different from the general packagers
and repackagers because of differences in the raw materials used,
the dominant product, the type of operations performed, the
treatment technology and the associated costs (See Section 4 for
detailed discussion). These types of facilities were not part of
the database for the original BPT regulations and were not
considered in the development of those regulations.
EPA finds that secondary containment of bulk storage areas
and loading pads, plus the collection, holding and eventual reuse
of rinsates, contaminated stormwater and leaks and spills
represents the best practicable technology for the refillers
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subcategory. The Agency's Office of Pesticide Programs has
proposed a regulation under FIFRA that would require refilling
establishments for agricultural pesticides to build secondary
containment structures and loading pads to certain specifications
(February 11, 1994; 59 FR 6712). The secondary containment
structures are designed to collect spills, rinsates from
containers and contaminated stormwater. The proposed effluent
guidelines build on this proposed requirement to contain
contaminated wastewater by proposing that the contained wastewater
may not be discharged. It is likely, therefore, that the
wastewater will be held until such time as it can be applied as
pesticide on a site compatible with the product label or used as
make-up water in an application of pesticide chemical to an
appropriate site. Of the estimated 1134 facilities (based on the
1988 survey) that would be affected by today's proposal, EPA's
questionnaire responses indicate that 98 percent or an estimated
1101 facilities already achieve zero discharge, primarily by
holding contaminated wastewater and reusing it as make-up water.
Thus, this practice not only eliminates the discharge of
wastewater but also allows the facility to recover the value of
the product in the wastewater. Accordingly, for purposes of
setting BPT regulations, EPA concludes that this proposal
represents the average of the best performance at existing
facilities. Indeed, because the proposal is to require zero
discharge, this also represents the best performance at any
existing facility, and therefore EPA is also identifying zero
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discharge as the basis for BAT and PSES regulations (see Sections
11 and 12) .
Since the Office of Pesticide Programs proposed rule would
already require these facilities to contain any contaminated
wastewater, the Office of Water does not expect there to be a
significant additional cost associated with the holding of this
water until such time as it can be used as make-up in commercial
application. (The costs associated with the refilling
establishments are discussed in Sections 8.4 and 12.2). There are
estimated to be no existing direct dischargers in this
subcategory.
As mentioned above, the sources of wastewater from refilling
establishments derive primarily from rinsates generated from
cleaning minibulk containers and bulk storage tanks. Another
source of wastewater that might contribute a significant volume is
contaminated stormwater. The current practice for many refilling
establishments is to contain and hold contaminated stormwater
until it can be used as make-up in a commercial application.
However, this source can be virtually eliminated by covering the
bulk storage area and loading pad under roof. According to an
industry representative, it is becoming a widespread practice for
many of the midwestern refilling establishments to do this. In
addition to potentially avoiding the generation of a contaminated
wastewater that must be controlled, enclosing the bulk storage
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area also protects it from vandalism and from severe weather such
as cold winters. Enclosing containment structures is not a basis
for the proposed regulation, nor is it a requirement of the Office
of Pesticide Programs proposed containment rule. However, the
Agency would certainly consider roofing a bulk storage area and
loading pad a prudent and pollution-preventing action by refilling
establishments. EPA does also recognize that there may be
barriers in some areas to enclosing bulk storage under roofs, such
as fire code restrictions.
EPA recognizes that it is not uncommon for refilling
establishments to have more than one pesticide product on-site to
be used on different crops. For example, it is common in the
midwest for a refilling establishment to have bulk Bicep®
(atrazine and metolachlor) that is applied to corn early in the
season, and also have Freedom® (alachlor and trifluralin), which
is applied to soybeans later in the growing season. Mixtures of
rinsates of the two products (Bicep® and Freedom®) cannot be used
in an application mixture if there is no crop for which the two
pesticides are mutually labelled. In estimating costs, the Agency
has assumed that the containment system, including separate
holding tanks, will segregate pesticide products to avoid spills
and stormwater from becoming cross contaminated. EPA has seen
this segregation in containment systems at refilling
establishments which have been designed to comply with local
requirements.
9-8
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9 . 2 SUMMARY OF PROPOSED BPT LIMITATIONS
Subcategory C: There shall be no discharge of wastewater
pollutants to navigable waters.
Subcategory E: There shall be no discharge of wastewater
pollutants to navigable waters.
9-9
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SECTION 10
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY (BCT)
10. 0
INTRODUCTION
The 1977 Amendments to the Clean Water Act added Section
301(b) (2) (E), establishing "best conventional pollutant control
technology" (BCT) for the discharge of conventional pollutants
from existing industrial point sources. Section 304(a)(4)
designated the following as conventional pollutants: BOD5, TSS,
fecal coliform, pH, and any additional pollutants defined by the
Administrator as conventional. On July 30, 1979 (44 FR 44501),
the Administrator designated oil and grease as a conventional
pollutant.
The BCT effluent limitations guidelines are not additional
guidelines, but instead, replace guidelines based on the
application of the "best available technology economically
achievable" (BAT) for the control of conventional pollutants. BAT
effluent limitations guidelines remain in effect for
nonconventional and toxic pollutants. Effluent limitations based
on BCT may not be less stringent than the limitations based on
"best practicable control technology currently available" (BPT).
Thus, BPT limitations are a "floor" below which BCT limitations
10-1
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cannot be established.
In addition to other factors specified in Section
304(b)(4)(B), the CWA requires that the BCT effluent limitations
guidelines be assessed in light of a two-part
"cost—reasonableness" test [see American Paper Institute v. EPAf
660 F 2d 954 (4th Cir. 1981)]. The first test compares the cost
for private industry to reduce its discharge of conventional
pollutants with the cost to publicly owned treatment works (POTWs)
for similar levels of reduction in their discharge of these
pollutants. The se'cond test examines the cost-effectiveness of
additional industrial treatment beyond BPT. EPA must find that
the limitations are "reasonable" under both tests before
establishing them as BCT. If the BCT technology fails the first
test, there is no need to conduct the second test, because the
technology must pass both tests. EPA promulgated a methodology
for establishing BCT effluent limitations guidelines on July 9,
1986 (51 ER 24974).
The Agency is proposing to establish BCT limitations for each
of the two subcategories that are equivalent to the BPT limits and
based upon the same control technologies. Accordingly, there
would be no additional costs associated with the BCT regulations.
Implementation of these limitations is discussed in Section
14 of this document.
10-2
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10 . 1
SUMMARY OF PROPOSED BCT LIMITATIONS
10.1.1 Pesticide Chemicals Formulating1. Packaging and.
Repackaging fg Tib category C^
EPA is proposing to establish BCT limitations for this
subcategory that are equivalent to the limitations established for
BPT. Since BPT requires zero discharge of process wastewater
pollutants and there can be no more stringent limitations, EPA
believes an equivalent technology basis is appropriate for BCT.
10.1.2 Repackaging &£ — Agricultural Pesticides Performed
Refilling Establishments t Sub eat ego r-v El
EPA is proposing to establish BCT limitations for this
subcategory that are equivalent to the limitation established for
BPT. Since BPT requires zero discharge of process wastewater
pollutants and there can be no more stringent limitations, EPA
believes an equivalent technology basis is appropriate for BCT.
10-3
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SECTION 11
BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
11.0 INTRODUCTION
The factors considered in establishing the best available
technology economically achievable (BAT) level of control include:
the age of process equipment and facilities, the processes
employed, process changes, the engineering aspects of applying
various types of control techniques, the costs of applying the
control technology, non-water quality environmental impacts such
as energy requirements, air pollution and solid waste generation,
and such other factors as the Administrator deems appropriate
(Section 304(b)(2)(B) of the Act). In general, the BAT technology
level represents the best existing economically achievable
performance among plants with shared characteristics. Where
existing wastewater treatment performance is uniformly inadequate,
BAT technology may be transferred from a different subcategory or
industrial category. BAT may also include process changes or
internal plant controls which are not common industry practice.
The Agency is proposing to establish BAT for each of the two
subcategories on the equivalent technology basis as BPT.
Accordingly, there would be no additional costs associated with
the BAT regulations.
11-1
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Implementation of these limitations is discussed in Section
14 of this document.
11. 1 SUMMARY OF PROPOSED BAT LIMITATIONS
11.1.1 Pesticide- Chemicals Formulating, Packaging and
Repackaging (Subcategory C)
EPA is proposing to establish BAT limitations for this
subcategory that are equivalent to the limitations established for
BPT (i.e., zero discharge of process wastewater pollutants, for all
facilities). Since BPT requires zero discharge of process
wastewater pollutants and there can be no more stringent
limitations, EPA believes an equivalent technology basis is
appropriate for BAT.
11.1.2 Repackaging- of Agricultural Pesticides Performed
bv Refilling Establishments (Subcateoorv E)
EPA is proposing to establish BAT limitations for this
subcategory that are equivalent to the limitation established for
BPT (i.e., zero discharge of process wastewater pollutants for all
facilities). Since BPT requires zero discharge of process
wastewater pollutants and there can be no more stringent
limitations, EPA believes an equivalent technology basis is
appropriate for BAT.
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SECTION 12
PRETREATMENT STANDARDS FOR EXISTING SOURCES (PSES)
12.0
INTRODUCTION
Section 307(b) of the Clean Water Act (CWA) calls for
EPA to promulgate pretreatment standards for existing sources
(PSES). PSES are designed to prevent the discharge of pollutants
that pass through, interfere with, or are otherwise incompatible
with the operation of publicly owned treatment works (POTWs). The
legislative history of the Clean Water Act of 1977 indicates that
pretreatment standards are to be technology-based and analogous to
the best available technology economically achievable for direct
dischargers.
The Agency is proposing to establish PSES on the basis of
zero discharge. The best available technologies identified as a
basis for these proposed standards consist of recycle and reuse of
wastewater and treatment with the Universal Treatment System,
where necessary, of wastewater for recycle/reuse. However, EPA
proposes to provide an exemption from these pretreatment standards
for non-interior wastewater sources from the formulating,
packaging and repackaging of small quantities of sanitizer
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chemical products1.
Implementation of these standards is discussed in Section 14
of this document.
The detailed evaluation of the technology-based options is
described in the following portions of this section. This
evaluation utilizes, as a basis, the results of the survey which
focused on facilities involved in formulating, packaging and
repackaging the 272 pesticide active ingredients (PAIs); 269 of
these PAIs were covered in the recently promulgated manufacturing
effluent guidelines and standards (September 28, 1993). Using the
survey data from the 675 survey respondents (including refilling
establishments and 48 manufacturers that are also PFPR facilities)
estimates were made to include all facilities involved in
processing the 272 active ingredients. Based on these estimates,
approximately 2400 facilities are covered by the proposed rule.
In addition, information obtained from the survey and EPA facility
visits and sampling episodes were used to evaluate approximately
1300 of these 2400 facilities that have PFPR lines that process
both the 272 active ingredients and other active ingredients (non-
272 PAIs) covered by the proposal. Using the FIFRA registration
data for the base year of 1988, approximately 1500 additional
iSmall quantities of sanitizer products means the formulating, packaging
or repackaging of 265,000 Ibs/yr or less of all registered products containing
specified (see Table 12-2) sanitizer active ingredients and no other active
ingredients at a single pesticide producing establishment (i.e., a single PFPR
facility).
12-2
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facilities not included in the survey estimation were identified
as processing only non-272 PAIs. Thus, a total of approximately
3900 PFPR facilities are estimated to be covered by the proposed
PSES.
While on the 51 site visits, EPA has made observations and
had discussions with facility personnel that leads EPA to conclude
that, in general, the production practices, pollution prevention
practices and treatment practices (where they exist) are the same
for the products containing the 272 PAIs and those containing the
non-272 PAIs. Thirty-nine of the 51 site visited facilities also
formulate, package or repackage non-272 PAIs. Based on the
formulating, packaging and repackaging practices and the types of
products being similar or the same at the 1500 facilities
processing non-272 PAIs as those seen and/or reported as part of
the database for the 272 PAIs covering 2400 facilities,
extrapolation of the detailed evaluation was used to provide for
coverage of all PFPR facilities and refilling establishments.
The only FIFRA registered products that are not covered are
pesticide products containing the active ingredient sodium
hypochlorite (also called bleach). EPA proposes to exclude sodium
hypochlorite from the applicability of PSES because it is commonly
classified as an inorganic chemical even though it has pesticidal
uses. EPA notes that it would be inappropriate to combine
wastewater generated from the formulating, packaging and
12-3
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repackaging of sodium hypochlorite with wastewater from other
active ingredients due to the high probability that the sodium
hypochlorite will react with the organic active ingredients and
inerts found in other PFPR wastewaters. It may react with these
organic chemicals to form chlorinated organic compounds. Thus,
EPA expects that the wastewaters generated from the formulating,
packaging and repackaging of sodium hypochlorite are kept separate
from other PFPR wastewaters even in facilities where they coexist
(approximately 900 facilities formulate, package or repackage
sodium hypochlorite only).
In summary, EPA proposes not to include sodium hypochlorite
PFPR waste streams within the scope of the proposed regulations
for indirect dischargers because sodium hypochlorite is commonly
classified as an inorganic chemical and not as a pesticide and
because sodium hypochlorite PFPR waste streams are generally
expected to be segregated and treated separately from the
remaining PFPR waste streams. EPA recognizes that the existing
BPT zero discharge requirement would apply to the sodium
hypochlorite PFPR direct dischargers. EPA is not proposing to
amend that requirement, since it has been in place since the 1978
BPT rulemaking and there is no information that this approach
should be changed.
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12.1 PESTICIDE CHEMICALS FORMULATING, PACKAGING AND
REPACKAGING (SUBCATEGORY C)
12.1 . 1
Introduction
EPA's survey of the pesticide formulating, packaging and
repackaging subcategory estimates that out of an estimated 1300
(Subcategory C) facilities that are formulating, packaging and
repackaging the 272 PAIs which were the focus of the survey,
approximately 669 are achieving zero discharge of process
wastewater. Virtually all of the estimated 633 discharging
facilities are indirect dischargers (to POTWs). Of the zero
discharge facilities, slightly more than half (327), based on
survey responses, do not use water for any of the purposes
identified as being process-related sources of wastewater. The
remaining 342 facilities are estimated (based on the survey
responses) to generate wastewater and to achieve zero discharge of
that wastewater through a combination of direct recycle, treatment
and recycle, and/or off-site disposal. EPA assumes that many of
these 342 facilities would be discharging directly, if it were
allowed. EPA examined the wastewater disposal practices of these
facilities along with the indirect discharging facilities and made
a determination as to what constituted the best available
technologies which serve as the basis for PSES.
Indirect dischargers in the pesticide formulating, packaging
12-5
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and repackaging industry use as raw materials many nonconventional
pollutants (such as the active ingredients) and priority
pollutants (in some cases as the active ingredient and in many
cases as product "inerts"). They may be expected to discharge
many of these pollutants to POTWs at significant mass or
concentration levels, or both. EPA estimates that indirect
dischargers of products containing one or more of the 272 organic
pesticides annually discharge approximately 115,400 pounds of
wastewater pollutants to POTWs.
12.1.2
Pass Through Discussion
EPA determines which pollutants to regulate in PSES on the
basis of whether or not they pass through, interfere with, or are
incompatible with the operation of POTWs (including interference
with sludge practices). EPA evaluates pollutant pass through by
comparing the average percentage removed nationwide by
well-operated POTWs (those meeting secondary treatment
requirements) with the percentage removed by' directly discharging
facilities applying BAT for that pollutant. When the average
percentage removed by well-operated POTWs is less than the
percentage removed applying BAT, the pollutant is said to pass
through.
As with the pesticide manufacturing rule (58 FR 50637), EPA
has very little empirical data on the active ingredient removals
12-6
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actually achieved by POTWs. Therefore, the Agency is relying on
laboratory test data to estimate the active ingredient removal
performance that would be achieved by biotreatment at
well-operated POTWs applying secondary treatment. The results of
this laboratory study are reported in the Domestic Sewage Study
(DSS) (Report to Congress on the Discharge of Hazardous Waste to
Publicly Owned Treatment Works, February 1986, EPA/530-SW-86-004),
and were also used to demonstrate pass through for the pesticide
chemicals manufacturing rule. The DSS provides laboratory data
under ideal conditions to estimate biotreatment removal
efficiencies at POTWs for different organic active ingredient
structural groups.
EPA has identified zero discharge of wastewater pollutants as
the best available technology, and this translates to 100 percent
removal of active ingredient pollutants, which is considerably
greater than the removals achieved by biotreatment under
laboratory conditions for the active ingredients. For each of
these active ingredient structural groups, the DSS shows that
average BAT removal efficiencies are considerably greater than the
average active ingredient removals achieved by biotreatment under
laboratory conditions for each of the active ingredients (100
percent removal by the technologies identified as BAT versus an
optimistic estimate of 50 percent or less removal by the POTW as
reported in the DSS). Accordingly, active ingredients were deemed
to pass through the treatment systems at POTWs.
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EPA also analyzed pass through data for priority pollutants.
In the pesticide manufacturing rule, EPA found that four priority
pollutants (phenol, 2-chlorophenol, 2,4-dichlorophenol and 2,4-
dimethylphenol) did not pass through the POTW. However, EPA is
not proposing to exempt these priority pollutants from meeting
PSES requirements for the PFPR facilities. EPA would only exempt
these priority pollutants if they were pollutants in a PFPR
facility waste stream that was completely segregated, i.e., there
were no PAIs or other priority pollutants in the waste stream.
However, because facilities would be required to achieve zero
discharge of the active ingredient, it would be inappropriate to
exempt any priority pollutant from regulation on the basis that it
does not pass through a POTW, because it will never be isolated in
a wastewater stream resulting from pesticide formulating,
packaging or repackaging.
12.1.3
Universal Treatment System (UTS)
The pesticide formulating, packaging and repackaging
wastewater is expected to contain the constituents of the
pesticide product being formulated, thus, EPA needed to identify a
treatment system that could be applied to wastewaters containing a
variety of active ingredients with different treatment
requirements. For example, it could be possible that a facility
would formulate and package a product containing an active
12-8
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ingredient that is best treated by hydrolysis and another product
that contains an active ingredient that is best treated by
chemical oxidation. To handle these diverse treatment
requirements EPA conceptualized a treatment system termed the
Universal Treatment System (UTS) as described in Sections 7 and 8
of this document. This system can treat pesticide formulating,
packaging or repackaging wastewater with hydrolysis, chemical
oxidation, metal separation and activated carbon or a combination
of these technologies depending on the active ingredients needing
to be controlled. The UTS also can accomplish chemical/thermal
emulsion breaking, which controls emulsifiers and surfactants that
are added to some pesticide products as inert ingredients.
Emulsion breaking may be needed as an initial step to improve the
treatability of the wastewater. As described in Section 7.3, the
Agency conducted a treatability study using pesticide formulating,
packaging and repackaging process wastewater from two facilities
to demonstrate the performance of the UTS.
EPA envisions the UTS as being a flexible treatment system
that can treat for a variety of active ingredients, be sized to
handle the small volumes generated by PFPR facilities, and be
operated on a batch basis. EPA expects that the majority of
facilities needing treatment will need less than the full array of
control technologies provided in the UTS.
The full Universal Treatment System may not currently be
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available on a commercial basis as an off-the-shelf system, but
EPA believes that in many cases there are commercially available
systems that will be suitable for a specific facility's needs.
Many of the pesticide formulating, packaging or repackaging
facilities that do have treatment have purchased off-the-shelf
treatment units such as ultrafiltration membranes and activated
carbon systems.
Given the small number of facilities with adequate treatment
in-place and the considerable diversity of wastewater
characteristics expected to be found at PFPR facilities, EPA
believes the Universal Treatment System reflects the best
available technology for wastewater treatment, but is by no means
the only technology available to achieve the proposed standards.
As described previously in Section 7.2, three of the facilities
sampled employed membrane separation technology in combination
with activated carbon technology. EPA also identified five PFPR
facilities either through its survey or voluntary submissions that
practice pollution prevention and treat and recycle their
wastewater. Although none of these five facilities had a
prototype "Universal Treatment System," each had developed a
treatment system that in concert with other recycle/reuse and some
off-site disposal primarily of sludges generated by the treatment
technologies employed, allowed these facilities to achieve zero
discharge of wastewater.
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12.1 .4
Options Selection for Subcateyory C:
PFPR (Including PFPR/Mamafaff-hM-nar-g \
Based on the best available technologies identified by EPA,
i.e., relying on the Universal Treatment System where treatment
would be needed and on pollution prevention practices and water '
conservation that lead to the recycle and reuse of wastewater, EPA
developed five regulatory options that were considered for PSES.
The Agency estimated the cost and pollutant removal expected to be
incurred for each option and evaluated the economic impacts and
cost effectiveness of these options. The Agency selected the
proposed regulatory approach based on the economic and technical
achievability of the options. Also, all toxic pollutants would be
regulated under each option, since all would be likely to pass
through a POTW or interfere with its operations.
12.1.4 .1
Regulatory Options Considered
The options considered for PSES are as follows:
Option 1 would set numeric discharge limits for various
pollutants based on end-of-pipe treatment for the entire
wastewater volume currently generated by PFPR facilities
through the Universal Treatment System and discharge of the
entire volume to POTWs.
Option 2 adds pollution prevention and reuse by requiring
that wastewaters generated from cleaning the interiors of
formulating and packaging equipment, bulk tanks and raw
material and shipping containers be recycled back into the
product to recover the product value in the wastewaters.
Numeric discharge limits would be set for other wastewaters,
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which would still be expected to be treated through the
Universal Treatment System and discharged to POTWs.
Option 3 would be based on the same technology and pollution
prevention and reuse practices as the Option 2. However,
this option would include recycling of all process wastewater
by recycling the wastewater back to the facility in some
cases after treatment through the Universal Treatment System
instead of allowing a discharge after treatment.
Option 3/S is the same as Option 3 for all PFPR facilities,
except for those facilities that formulate, package and
repackage products with sanitizer active ingredients and
whose sanitizer production is less than 265,000 Ibs/yr.
Based on the level of impacts imposed on facilities that
formulate, package or repackage small quantities of sanitizer
products (see Table 12-2) and on the small amounts of
pollutant discharges from non-interior wastewater sources at
sanitizer facilities, EPA developed this option which
requires these sanitizer PFPR facilities to achieve zero
discharge of interior wastewaters only. Other wastewater
sources generated at sanitizer PFPR facilities would not be
subject to pretreatment standards.
Option 4 incorporates the pollution prevention and reuse
aspects of Options 2 and 3, but instead of treatment, assumes
that wastewaters that cannot be recycled will be disposed of
by off-site incineration.
Option 5 is based on disposal of all wastewater through
off-site incineration.
Table 12-1 is presented to show the total annualized
costs and pollutant removals for each option. These costs
and removals only take into account the 272 PAIs which were
the focus of the data collection. A brief discussion of the
additional costs incurred when considering all PAIs covered
by the proposed regulation is presented in the next section
(2.1.4.2). Therefore, the discussion immediately below will
focus on the Options as they relate to the PFPR of the 272
PAIs only.
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Table 12-1
PSES Costs and Pollutant Removals
for the 272 PAIs
Options
1
2
3
3/S
4
5
Total Annual! zed
Cost:
$xnxn
33.6
28.7
28.7
26.1
290
364
Pollutant Removals
• Ibs
• toxic Ib equivalents
• 111,653
12,127,666
111,683
• 12,127,666
• 111,996
• 12,134,050
111,793
12,134,031
• 111,996
• 12,134,050
111,996
• 12,134,050
Option 1 is more costly and estimated to cause more economic
impacts than Options 2, 3, and 3/S due to a higher volume of water
that is expected to be treated through the Universal Treatment
System. Options 2 and 3 are estimated to have the same costs and
level of economic impacts since both options are based on the same
technology. For simplification and because the technology is
essentially identical the costs are presented to be identical.
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In reality Option 3 costs could be lower than Option 2,
because sampling data indicate that facilities which do treat
wastewater for recycling back to the facility do not achieve the
same degree of pollutant removal from the wastewater that would be
required to comply with numeric standards (see Section 7.2.2).
However, Option 3 achieves greater pollutant removals than Option
2 since it requires the treated wastewater to be recycled rather
than discharged as allowed by Option 2. Option 3/S is less costly
than Options 2 and 3, and is expected to cause fewer economic
impacts. Option 4 is more costly than Options 1 through 3/S and
Option 5 is more costly than Option 4, though both Option 4 and 5
achieve the same removals as Option 3. [Note: Options 3, 4 and 5
provide a removal level (zero discharge) for PSES that is
consistent with the requirements for direct dischargers.]
Option 3/S was selected to be the basis for pretreatment
standards for existing sources when addressing the 272 PAIs that
were the focus of the data collection for the proposed rule.
Option 3/S represents the performance of the best available
technology economically achievable, incorporating the best
existing practices of pollution prevention, recycle/reuse and
water conservation in this subcategory. Option 3/S imposes lesser
costs than all other options and achieves greater pollutant
removals than Options 1 and 2. Options 3, 4 and 5 which require
zero discharge from all wastewater sources remove only slightly
more pollutants. The very small difference in pollutant removals
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between 3/S and Options 3, 4 and 5 is due to small sanitizer
chemical facilities being required to treat and recycle their
exterior wastewater sources under Options 3, 4, or 5.
12.1.4.2 Selected Option for the Expanded Coverage: 3/S.l
In order to provide coverage of the proposed rule to the
facilities formulating, packaging and repackaging the additional
PAIs not included as part of the 272 identified in the survey (the
"non-272 PAIs"). an additional option was evaluated (Option
3/S.l). This option was developed and costs were estimated that-
include facility costs for the control and treatment of the
wastewaters from the'PFPR of products containing the non-272 PAIs
at the facilities costed for Option 3/S, who PFPR both 272 and
non-272 products, and approximately 1500 additional facilities who
PFPR only non-272 products. Option 3/S.l still provides an
exemption for small sanitizer facilities.
EPA has estimated the additional costs associated with 3/S.l.
In comparison to Option 3/S, where the total annualized cost was
$26.1 million with one facility closure and 136 line closures
conversions, there are additional costs and impacts. Total
annualized costs (including the expanded coverage) are estimated
at $40.1 million for the facilities that PFPR both 272 and non-272
products and $16.0 million for the 1500 facilities who PFPR only
non-272 products. .This brings the total annualized cost for the
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non-272 products. This brings the total annualized cost for the
regulation to $56.1 million. For Option 3/S.l, impacts are
estimated at 2 facility closures and 250 line closures or
conversions. For the same reasons presented in Section 2.1.4.1
for Option 3/S, Option 3/S.l is the selected option for the basis
of the pretreatment standards addressing all PAIs covered by this
proposed regulation.
Under Option 3/S.l, EPA is proposing to establish
separate standards for the formulating, packaging and repackaging
of products with sanitizer chemicals, when the total sanitizer
production is less than 265,000 Ibs/yr. The standards would
require these sanitizer facilities to achieve zero discharge from
interior wastewater sources only. The production cut-off of
265,000 Ibs/yr represents the production level of the largest
facility that benefits by an exemption of wastewater treatment
requirements for non-interior wastewater sources. This production
level applies to the facilities sum total pounds of all sanitizer
registered products containing one or more of the sanitizer active
ingredients on Table 12-2 and no other active ingredients.
EPA proposes this exemption for facilities that
formulate, package or repackage less than 265,000 Ibs/yr sanitizer
products for the following reasons:
1. The impacts on them are significant, due primarily to
the costs of having to install treatment for their
non-interior streams.
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The amount of pollutants associated with their
non-interior streams is insignificant — about 21
toxic-weighted pound equivalents per year (total for the
segment when addressing the 272 PAI only) and about 196.
Therefore, excluding their non-interior streams from
coverage results in basically the same overall reduction
in pollutants discharged by the PFPR industry but
significantly eases the burden on these small entities.
This is consistent with the objectives of the Regulatory
Flexibility Act, which directs agencies to examine "any
significant alternatives to the proposed rule which
accomplish the stated objectives of applicable statutes
and which minimize any significant economic impact of
the proposed rule on small entities." (RFA Section
603). Section 603 also specifically mentions exemptions
from coverage of the rule as one type of alternative
that could be examined.
EPA also notes that sanitizer products, in contrast to
most other pesticide products, are intended to be
discharged to sinks and drains with normal use and
therefore large quantities of the products themselves
(apart from the PFPR waste 'streams) end up at the POTW.
EPA is not aware that these products are causing any
interferences at POTWs. Further, discharging this small
additional amount of sanitizer chemicals to POTWs would
not materially increase the total amount of these
chemicals being discharged to POTWs.
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Table 12-2
Sanitizer Active Ingredients
CAS No.
Shaugh-
nessy
Code
Active Ingredient Name
00121-54-0
34375-28-5
00134-31-6
15716-02-6
68424-85-1
15716-02-6
00064-02-8
08008-57-9
07647-01-0
08002-09-3
53516-76-0
08001-54-5
08045-21-4
53516-75-9
68391-05-9
68424-85-1
61789-71-7
68424-85-1
68989-02-6
07173-51-5
85409-23-0
05538-94-3
68607-28-3
68607-28-3
00497-19-8
07664-38-2
69122
99001
59804
69134
69105
69134
39107
40501
45901
46621
67002
69104
69106
69111
69112
69119
69137
69140
69141
69145
69149
69154
69165
69166
69173
69194
73506
76001
Benzethonium Chloride (Hyamine 1622)
2-(Hydroxymethyl) amino ethanol (HAE)
Oxine-sulfate
Methyl dodecylbenzyltrimethyl ammonium chloride (Hyamine 2389)
Alkyl dimethyl benzyl ammonium chloride (Hyamine 3500)
Methylbenzethonium chloride
Tetrasodium ethylenediaminetetraacetate*
Essential oils
Hydrogen chloride*
Alkyl-l-benzyl-1— (2-hydroxyethyl) -2-imidazolinium chloride
Pine oil
Alkyl dimethyl benzyl ammonium chloride
Alkyl dimethyl benzyl ammonium chloride
Alkyl dimethyl ethylbenzyl ammonium chloride
Alkyl dimethyl 1—naphthylmethyl ammonium chloride
Dialkyl methyl benzyl ammonium chloride
Alkyl dimethyl benzyl ammonium chloride
Alkyl dimethyl benzyl ammonium chloride
Alkyl dimethyl benzyl ammonium chloride
Alkyl dimethyl 3,4-dichlorobenzyl ammonium chloride
Didecyl dimethyl ammonium chloride
Alkyl dimethyl ethylbenzyl ammonium chloride
Octyl decyl dimethyl ammonium chloride
Dioctyl dimethyl ammonium chloride
Oxydiethylenebis(alkyl dimethyl ammonium chloride)
Alkyl dimethyl benzyl ammonium chloride
Sodium carbonate*
Phosphoric acid*
* These active ingredients shall only be considered sanitizer active ingredients
when they are formulated, packaged or repackaged with the other active ingredients
on this list and no other active ingredients.
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EPA expects that facilities which formulate, package or
repackage both pesticide chemicals products and sanitizer
chemicals products will not realize any relief in their regulatory
requirements through Option 3/S (and 3/S.l) as compared to Option
3. This is because the non-interior wastewater sources which the
Agency is proposing to exclude from coverage (equipment exterior
cleaning, floor washing, laboratory equipment cleaning, safety
equipment cleaning, air pollution scrubbers, DOT leak test bath
water and contaminated precipitation runoff) under the sanitizer
chemicals facilities tend to be related to the activities
occurring throughout the facility and are usually not related to
specific products or even specific production lines. Therefore,
unless a combined facility has dedicated lines that physically
separate the sanitizer and non-sanitizer wastewaters, the non-
interior PFPR wastewater sources will contain both sanitizer and
non-sanitizer chemicals and will be controlled by the pretreatment
standards for the non-sanitizer chemical active ingredients. EPA
emphasizes that for products containing both sanitizer active
ingredients and other PAIs, the formulating, packaging and
repackaging of these products would not be subject to the
sanitizer exemption.
EPA has not provided the same exemption from the BPT, BAT and
BCT requirements. EPA has evaluated whether this would be
appropriate, but could find no basis for expanding the exemption
to BPT, BAT and BCT requirements. The BPT requirements have
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covered all PFPR waste streams since those issued in 1978, and EPA
believes there is no reason to relax those requirements.
12.1.4.3
Discussion of Options Not Selected
The following discussion of the options not selected reflects
estimated costs and pollutant removals for the wastewater
generated from the formulating, packaging or repackaging of the
272 pesticide active ingredients only.
Option 1 is estimated to cost $33.6 million ammally for the
2400 facilities covered by the detailed analysis, and would remove
an estimated 111,653 pounds of active ingredients per year. EPA's
analysis of the impacts of these costs projects that eleven plants
would close and 189 plants would discontinue their pesticides
production (i.e. would have line conversions). EPA's estimates
are based on the cost required to install a Universal Treatment
System, including one or more of the identified BAT control
technologies plus holding tanks, pumps, and piping as needed. EPA
assumed that this cost would be imposed on all facilities that
currently discharge to POTWs and that no existing facilities
would have any savings due to treatment already in place. EPA
estimated costs on a plant-by-plant basis for all plants surveyed
that reported discharge of process wastewater to a POTW. Although
there are a small number of surveyed facilities that reported
treating their wastewater prior to discharging it to a POTW, in
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most cases this treatment was not intended to control active
ingredients. For the majority of facilities, EPA costed treatment
technology (and equipment to accomplish recycle and reuse as
needed) for the total volume reported in the questionnaire as
being discharged currently. For facilities that are both
pesticide manufacturers and PFPR facilities, EPA costed these
facilities for only the wastewater treatment and recycle/reuse
equipment that is needed beyond the equipment these facilities
already have in place.
Option 1 was rejected because it does not incorporate any
pollution prevention, recycle or water conservation techniques
that are widely demonstrated and practiced in this industry.
Therefore, it does not represent the best available technology.
EPA also notes that there would be an additional burden on the
regulated community because of the large number of pollutants for
which the Agency would have to establish standards and for which
facilities would need to monitor. Also, under Option 1, the
Agency would be unable to control the discharge of all pollutants
due to a lack of analytical methods .for some active ingredients.
EPA did consider setting standards for one or more pollutants that
could be used as surrogates for which the monitoring could
demonstrate that facilities are achieving treatment and removal of
the active ingredients and other pollutants from their wastewater.
The Agency considered, for example, using immunoassays as a less
expensive alternate method for demonstrating compliance. EPA
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performed tests using these immunoassay techniques as written up
in Environmental Lab; June/July 1993, Vol. 5, Number 3, page 27.
As stated in this article, the immunoassay tests appear to work
reasonably well if,the monitoring involves a relatively small
number of analytes overall. However, since there are only a few
ingredient-specific immunoassay tests available, EPA does not
consider this method of determining compliance to be feasible at
present. EPA also considered the possibility of using Total
Organic Carbon (TOG) or the Chemical Oxygen Demand (COD) as
measures of the performance of wastewater treatment in removing
active ingredients and other pollutants. This alternative was
also rejected because it would be very difficult to establish a
specific concentration of TOC or COD that would reflect adequate
treatment and removal of the active ingredients and other
pollutants for all of the diverse wastewater matrices found at
pesticide formulating, packaging or repackaging facilities.
Lastly, the Agency gave some consideration to a measurement of the
toxicity of the wastewater. This was also rejected, because
toxicity measurements are in no way specific to any given
pollutant and they are not expected to be sensitive at the levels
that represent good wastewater treatment.
The burden associated with monitoring for each specific
regulated pollutant could have been alleviated had EPA been able
to identify a suitable surrogate pollutant(s) for formulating,
packaging or repackaging facilities.
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Option 2 is estimated to cost $28.7 million annually for the
2400 facilities, and would be expected to remove 111,683 pounds of
active ingredients per year. The estimated costs for Option 2 are
slightly lower than the estimated costs for Option 1,-due to a
lower volume of wastewater that is expected to be treated by the
Universal Treatment System. Since EPA believes that wastewater
from rinsing the interior of shipping containers can be directly
added to the product being formulated, EPA has estimated that no
cost is associated with the recycle of this stream. EPA has
estimated the cost of holding the rinsate from cleaning equipment
interiors and bulk storage tanks. This cost is based on the
greatest volume expected to be generated over a 90 day period.
EPA has assumed that facilities will hold these wastewater sources
no longer than 90-days in order to avoid the possibility of being
classified a RCRA waste storage facility, and separate holding
tanks to avoid cross-contamination of wastewater were costed for
each product the facility reported making. If there is a gap in
production of greater than 90-days based on the reported
production schedule for a given product it was assumed that the
volume would be combined with other pesticide process wastewater
for treatment through the Universal Treatment System. Generally,
wastewater volumes from interior cleaning were costed for recycle
only and were not part of the hydraulic load that was costed for
treatment through the Universal Treatment System. Therefore the
Universal Treatment System can be smaller than the system costed
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for Option 1. EPA estimates that the economic impact of Option 2
would be one possible plant closure and 192 line conversions.
Option 2 was rejected even though it does incorporate
pollution prevention practices, because it does not represent the
best performance of facilities in this subcategory. In addition,
EPA would still need to establish standards for a long list of
pollutants and there would still be some pollutants for which the
discharge would be uncontrolled. As discussed previously an
estimated 669 of the 1305 PFPR facilities (not including refilling
establishments) are achieving zero discharge. EPA could find no
significant difference between facilities that use but do not
discharge wastewater versus facilities that do discharge. There
is no significant difference in production processes, volumes
produced, type of products made, active ingredients used,
geographic location or any other factor. Therefore, EPA concludes
that requirements for indirect dischargers must be equivalent to
direct discharge requirements, after taking into account the pass
through of pollutants. Therefore, Option 2 for PSES was rejected
because it would allow a discharge and thus result in inconsistent
requirements for PSES compared to BPT/BAT for direct dischargers.
Option 3 is also estimated to cost $28.7 million annually for
the 2400 facilities and result in one plant closure and 188
product line closures or conversions. However Option 3 is
estimated to remove 111,996 pounds per year of active ingredient
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pollutants. As discussed previously, Option 3 was not selected
because the costs and economic impacts associated with this option
could be reduced for a specific group of small entities (sanitizer
facilities) which discharge a minimal amount of pollutants from
the non-interior wastewater sources.
Options 4 and 5 were rejected because they rely on
transferring wastewater pollutants to other media as part of their
approach. In addition their very high cost would result in
greater economic impacts on many facilities. Option 4 is
estimated to cost $290 million and Option 5 is estimated to cost
$364 million for the 2400 facilities. The projected economic
impacts include 8 plant closures for both Options with 193 product
line closures or conversions for Option 4 and 230 product line
closures or conversions for Option 5. It should be noted that
there are small numbers of facilities that could find it less
expensive to practice pollution prevention on the interior
cleaning wastewaters and send the rest of their pesticide
formulating, packaging or repackaging wastewater off-site for
disposal than it will be for them to install a treatment system to
handle these wastes. EPA is providing suggestions for handling
wastewaters and treating and/or recycling them in an efficient,
low-cost manner such that these facilities can be dissuaded from
opting to transfer wastewater pollutants to other media. (See
Section 7.4 of this document and Chapter X of the Economic Impact
Analysis Report for details.)
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12.2 OPTIONS SELECTION FOR SUBCATEGORY E:
REFILLING ESTABLISHMENTS
12.2.1 Repackaging of Agricultural Pesticides Performed
by Refilling- Establishments (Subeategory EV
EPA is proposing to establish pretreatment standards for
refilling establishments that repackage agricultural pesticide
products based on achieving zero discharge of wastewater
pollutants to POTWs. Using the same approach to evaluating the
pass through of wastewater pollutants as is discussed for
Subcategory C, EPA expects that the pesticide active ingredient
pollutants present in process wastewaters from refilling
operations will pass through POTWs. As with pass through
analysis for Subcategory C, an optimistic estimate of 50 percent
removal of active ingredients by well-operated secondary POTWs
does not come close to matching 100 percent removal achieved by
the proposed BAT regulation.
The options considered for this Subcategory are as follows:
Option 1 would set zero discharge through secondary
containment, loading pads and sumps for holding collected
wastewater and spills for reuse as product in application to
fields.
Option 2 is the same as Option I, but the collected
wastewater and spills would not be reused but instead would
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be hauled off-site for incineration.
The selected technology basis for this proposal is secondary
containment of bulk storage areas and loading pads and reuse of
the collected rinsates, contaminated precipitation and leaks and
spills for use in application to fields (Option 1).
The average volume of wastewater discharged reported by
refilling establishments is approximately 79 gallons per year per
facility. EPA assumes volumes of this magnitude can be held in a
minibulk container until such a time as it can be reused. Only an
estimated 19 refilling establishments out of 1134 were discharging
their wastewater (in 1988) and, therefore, would incur costs from
this proposed zero discharge regulation. EPA estimates a captial
cost of about $300 for the minibulk for holding and reusing the
contaminated wastewaters. Therefore, EPA finds the costs are
economically achievable (see Economic Impact Analysis Report).
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SECTION 13
NEW SOURCE PERFORMANCE STANDARDS (NSPS) AND
PRETREATMENT STANDARDS FOR NEW SOURCES (PSNS)
13. 0
INTRODUCTION
New source performance standards (NSPS) under Section 306 of
the Clean Water Act represent the most stringent numerical values
attainable through the application of the best available
demonstrated control technology for all pollutants (conventional,
nonconventional, and priority pollutants).
Section 307(c) of the Clean Water Act calls for EPA to
promulgate pretreatment standards for new sources (PSNS) at the
same time that it promulgates new source performance standards
(NSPS). New indirect discharging facilities, like new direct
discharging facilities, have the opportunity to incorporate the
best available demonstrated technologies, including process
changes, in-plant controls, and end-of-pipe treatment
technologies, and to use plant site selection to ensure adequate
treatment system installation.
Implementation of these standards is discussed in Section 14
of this document.
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13.1
SUMMARY OF PROPOSED NSPS AND PSNS STANDARDS
13.1.1 Pesticide Chemicals Formulati-ny, Paekayi.ny and
( Subeateor C^
EPA is proposing to establish NSPS as zero discharge,
equivalent to the BAT requirements for existing sources . Zero
discharge represents best available and best demonstrated
technology for the pesticide formulating, packaging and
repackaging subcategory as a whole. The economic impact analysis
for existing sources shows that this regulatory approach (termed
Option 3 in Section 12) , which does not provide an exemption to
small sanitizer facilities, would be economically achievable for
the industry. , EPA believes that new sources will be able to
comply with zero discharge for all process wastewater sources at
costs that are similar to or less than the costs for existing
facilities . This is because new sources can apply control
technologies and pollution prevention techniques (including
dedicated lines and pressurized hoses for equipment cleaning) more
efficiently than sources that need to retrofit for those
technologies. EPA's analysis concludes that a zero discharge
requirement for new source direct dischargers would be
economically achievable and would not be a barrier to entry.
EPA is proposing to set pretreatment standards for new
sources (PSNS - covering indirect dischargers) equivalent to NSPS
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standards (which cover direct dischargers), i.e., at zero
discharge for all PFPR process wastewater sources with no
exemption for small sanitizer facilities. For the reasons stated
above with respect to the NSPS standards, EPA finds that the PSNS
regulations would be economically achievable and not a barrier to
entry.
Although EPA is proposing to exempt the non-interior
wastewater sources of the small sanitizer facilities from this
zero discharge requirement for existing facilities .(PSES), EPA is
not proposing to include this same exemption for the new source
pretreatment facilities (PSNS). The rationale for the PSES
exemption of the non-interior wastewater sources at small
sanitizer facilities is based on EPA's findings that the impacts
on existing small entities would be significantly reduced by the
exemption while the associated additional loading of toxic
pollutants would be small. with respect to new source
pretreaters, EPA does not have sufficient information to conclude
that the size and economic conditions of those new sources, the
impacts on those sources and the associated loadings of toxic
pollutants, would justify a similar exemption for the non-interior
wastewater sources for new indirectly discharging sanitizer
facilities.
EPA believes this to be economically achievable and does not
expect this to present a barrier to entry.
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13.1.2 Repackaging of Agricultural Pesticides Performed
by Refilling- Establishments fSubcateyory EV
EPA is proposing to establish NSPS and PSNS as equivalent to
the zero discharge BAT requirements for existing sources.
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SECTION 14
REGULATORY IMPLEMENTATION
14 . 0
INTRODUCTION
The purpose of this section is to provide assistance and
direction to permit writers and control authorities to aid in
their implementation of this zero discharge regulation. This
section will also discuss the relationship of upset and bypass
provisions, variances and modifications, best management practices
and analytical methods to the proposed limitations and standards.
14.1
IMPLEMENTATION OF ZERO DISCHARGE
In previous regulations compliance with zero discharge
limitations or standards may have been achieved by measuring the
level of pollutants in the regulated process wastewater with EPA
approved analytical methods. However, EPA expects that only
process flow will be used by permitting and control authorities to
assess compliance with this regulation. This would be done by
examining the flow volume of wastewater discharges, and generally
would preclude the need for analytical measurements of the
pollutants in the process wastewater. EPA expects this method of
demonstrating compliance will be used for several reasons:
• Products being formulated, packaged or repackaged vary
from facility-to-facility and year-to-year (even within
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the same facility); making consistent monitoring very
difficult;
• Monitoring for all possible pesticide active ingredients
is very expensive given the large number of formulations
that are processed within each facility; and
• Even when a facility is complying, some PAI may be
detected during end-of-pipe monitoring from "non-
process" wastewater sources (i.e., shower and laundry).
Therefore, EPA expects that zero discharge would generally be
achieved through no discharge of the regulated process wastewaters
and could be monitored through routine certification of no-
discharge compliance and on-site/in-facility inspections. During
inspections, facilities would demonstrate, for example, closed-
loop processes, storage of wastewater for reuse, closed floor
drains, sumps and floor trenches with no outlets or drains and
segregated "sinks" for collection of laboratory equipment cleaning
rinsates. Several facilities that were visited during the
development of the proposed regulation used "tracking systems" to
keep track of the wastewater that was in storage for use in future
formulations. Some facilities used a computerized system while
others used a sign-in/sign-out sheet on a clipboard in the storage
area. A "tracking system" may provide the permitting authority
with added assurance that a facility is storing water for future
formulation and not discharging to the POTW.
14.2
UPSET AND BYPASS PROVISIONS
A recurring issue is whether industry limitations and
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standards should include provisions authorizing noncompliance with
effluent limitations during periods of "upset" or "bypass". An
upset, sometimes called an "excursion," is an unintentional and
temporary noncompliance with technology-based effluent limitations
occurring for reasons beyond the reasonable control of the
permittee. EPA believes that upset provisions are necessary to
recognize an affirmative defense for an exceptional incident.
Because technology-based limitations can require only what
properly designed, maintained and operated technology can achieve,
it is claimed that liability for such situations is improper.
When confronted with this issue, courts have been divided on the
question of whether an explicit upset or excursion exemption is
necessary or whether upset or excursion incidents may be handled
through EPA's exercise of enforcement discretion. (Compare
Marathon Oil Co. y. F.PA, 564 F.2d 1253 (9th Cir. 1977) with
Weyerhaeuser V. Cop1-1*», 590 F.2d 1011 (B.C. Cir. 1978). See also
American Petroleum Institute v. EPAr 540 F.2d 1023 (10th Cir.
1976); CPC International Inc. v. Train, 540 F.2d 973 (4th Cir.
1976)); and FMC Corp. v. Tr-a-inr 539 F.2d 973 (4th Cir. 1976).)
While an upset is an unintentional episode during which
effluent limitations are exceeded, a bypass is an act .of
intentional noncompliance during which wastewater treatment
facilities are circumvented in emergency situations.
EPA has both upset and bypass provisions in NPDES permits,
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and has promulgated NPDES and pretreatment regulations which
include upset and bypass permit provisions. (See 45 FR 33290,
33448; 40 CFR 122.60(g)(h), May 19, 1980 403.16 and 403.17). The
upset provision establishes an upset as an affirmative defense to
prosecution for violation of technology-based effluent
limitations. The bypass provision authorizes bypassing to prevent
loss of life, personal injury, or severe property damage. Since
the limitations and standards are proposed to be set at zero
discharge and there are already upset and bypass provisions in
NPDES permits and pretreatment regulations, EPA will let local
control authorities deal with individual upsets or requests for
bypass.
14.3
VARIANCES AND MODIFICATIONS
Upon the promulgation of these regulations, the effluent
limitations for the appropriate subcategory must be applied in all
Federal and State NPDES permits issued to direct dischargers in
the pesticide formulating, packaging or repackaging industry. In
addition, the pretreatment standards are directly applicable to
indirect dischargers.
For the BPT effluent limitations, the only exception to the
binding limitations is EPA's "fundamentally different factors"
("FDF") variance (40 CFR Part 125 Subpart D). This variance
recognizes factors concerning a particular discharger which are
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fundamentally different from the factors considered in this
rulemaking. Although this variance clause was set forth in EPA's
1973-1976 effluent guidelines, it is now included in the NPDES
regulations and not the specific industry regulations. (See 44
FR 32854, 32893 [June 7, 1979] for an explanation of the
"fundamentally different factors" variance). The procedures for
application for a BPT FDF variance are set forth at 40 CFR
122.21 (m) (1) (i) (A) .
Dischargers subject to the BAT limitations proposed in these
regulations may also apply for an FDF variance, under the
provisions of sec. 301(n) of the Act, which regulates BAT, BCT,
and pretreatment FDFs. In addition, BAT limitations for
nonconventional pollutants may be modified under sec. 301 (c) of
the Act for economic reasons and 301(g) of the Act for water
quality reasons. Under sec. 301(1) of the Act, these latter two
statutory modifications are not applicable to "toxic" or
conventional pollutants.
New sources subject to NSPS are not eligible for EPA's
"fundamentally different factors" variance or any .statutory or
regulatory modifications. (See duPont v. Trainr supra.)
Dischargers subject to pretreatment standards for existing
sources (PSES) are also subject to the "fundamentally different
factors" variance and credits for pollutants removed by POTWs.
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Dischargers subject to pretreatment standards for new sources
(PSNS) are subject only to the removal credit provision. The
procedure for FDF variances are set forth in 40 CFR Part 403.13
and for removal credits in 40 CFR Part 403.7.
14.4 RELATIONSHIP TO NPDES PERMITS AND MONITORING
REQUIREMENTS
The BAT and NSPS limitations in the proposed rule would be
applied to individual pesticide plants through NPDES permits
issued by EPA or authorized State agencies under section 402 of
the Act. This section adds more detail on the relation between
this regulation and NPDES permits. Some discussion on
implementation of this regulation by NPDES permit writers is
discussed in Section 14.1.
Beyond the actual details of implementing the EPA regulation,
one issue is how this regulation will affect the powers of NPDES
permit-issuing authorities. EPA has developed the limitations and
standards in the proposed rule to cover the typical facility for
this point source category. In specific cases, the NPDES
permitting authority may have to establish permit limits on
pollutants (in waste streams) that are not covered by this
regulation. This regulation does not restrict the power of any
permitting authority to act in any manner consistent with law or
these or any other EPA regulations, guideline, or policy.
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A concern of permit writers, as well as local control
authorities, may be the apparent contradiction of writing a
discharge permit for a zero discharge regulation. During
development of the proposed regulation, EPA contacted a few permit
writers who wrote NPDES permits for facilities that reported zero
discharge in the survey. EPA obtained copies of these permits,
and found that because the facilities still had wastewater
discharges due to sanitary wastewater or other non-PFPR
operations, the permit writers were able to specify zero discharge
of the PFPR process wastewater streams.
Even if a facility is total no discharge, an NPDES permit may
be requested by the facility to provide upset provisions which
would not apply to discharge in the absence of a permit.
Another topic of concern is the operation of EPA's NPDES
enforcement program, which was an important consideration in
developing the proposal. The Agency emphasizes that although the
Clean Water Act is a strict liability statute, EPA can initiate
enforcement proceedings at its discretion. EPA has exercised and
intends to exercise that discretion in a manner that recognizes
and promotes good faith compliance.
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14.5
BEST MANAGEMENT PRACTICES
Section 304(e) of the Act authorizes the Administrator to
prescribe "best management practices" (BMPs). EPA may develop
BMPs that apply to all industrial sites or to a designated
industrial category and may offer guidance to permit authorities
in establishing management practices required by unique
circumstances at a given plant. Many practices that could be
considered as BMPs have been observed in the PFPR industry. EPA
has seen widespread use of pollution prevention, water
conservation and recycle/reuse practices along with the use of
dikes, curbs, and other control measures to contain leaks and
spills. Further, as described previously, the Office of Pesticide
Programs is proposing to require secondary containment•systems at
refilling establishments for agricultural pesticides. However,
due to the variety of products, formulation types and level of
sophistication in the formulating and packaging equipment, EPA
believes that establishing BMPs in a national effluent guideline
may not provide enough flexibility to the industry to achieve the
zero discharge requirements of this regulation in the way that is
most efficient and appropriate for each facility.. EPA does
recognize that on a facility-by-facility basis a permit writer may
choose to incorporate BMPs into the permit.
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14.6 ANALYTICAL METHODS
Section 304(h) of the Act directs EPA to promulgate
guidelines establishing test methods for the analysis of
pollutants. These 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 122.41(j) (4) and 122.21(g) (7), and for the
pretreatment program under 40 CFR 403.12(g)(4) and (h). To date,
EPA has promulgated methods for conventional pollutants, toxic
pollutants, and for some nonconventional pollutants. The five
conventional pollutants are defined at 40 CFR 401.16. Table I-B
at 40 CFR 136 lists the analytical methods approved for these
pollutants. The 65 toxic metals and organic pollutants and
classes of pollutants are defined at 40 CFR 401.15. From the list
of 65 classes of toxic pollutants EPA identified a list of 126
"Priority Pollutants." This list of Priority Pollutants is shown,
for example, at 40 CFR Part 423, Appendix A. The list includes
non-pesticide organic pollutants, metal pollutants, cyanide,
asbestos, and pesticide pollutants. 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.
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EPA believes that the analytical methods for pesticide active
ingredients contained in the methods compendium for the
promulgated pesticide manufacturing effluent guidelines and
standards ("Methods for the Determination of Nonconventional
Pesticides in Municipal and Industrial Wastewater, Volumes I and
II,"/EPA-821-R-93-010-A;-B) will perform equally well on treated
pesticide formulating, packaging or repackaging wastewaters as on
pesticide manufacturing wastewaters. Raw wastewater samples may
on occasion require some separation prior to analysis, analogous
to the emulsion breaking or chemically assisted clarification
treatment included in EPA's costed BAT technology. Many of these
methods have in fact been used on the PFPR sampled wastewaters.
All of the active ingredient pollutant data that .supports the
proposed effluent limitations were generated using analytical
methods that employ the latest in analytical technology. EPA may
decide to promulgate these methods (which are contained in Part
455 of the rule) ,as allowable methods under 40 CFR Part 136.
However, as mentioned previously, EPA expects' that only process
flow be used by permitting and Control Authorities as a means of
assuring compliance with today's proposal.
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SECTION 15
WATER QUALITY ANALYSIS
15.1
WATER QUALITY ANALYSES
Most of the PAIs being regulated have at least one toxic
effect (human health carcinogen and/or systemic toxicant or
aquatic toxicant). Many of these pollutants have the potential to
bioaccumulate and persist in the environment. Various studies
have demonstrated the bioaccumulation of pesticides in aquatic
life and accumulation of pesticides in sediments. Documented
human health impacts at pesticide formulating, packaging, and
repackaging (PFPR) facilities include respiratory disease and
impaired liver function, primarily through worker exposure.
Numerous incidents of groundwater and soil contamination at
refilling establishments, largely due to spills, are identified in
the Office of Pesticide Programs proposed "Standards for Pesticide
Containers and Containment". According to a 1991 study, an
estimated 45 to 75 percent of the refilling establishments in
Wisconsin will require soil remediation and 29 to 63 percent of
the commercial agrichemical facilities potentially exceed the
State's groundwater standards for pesticides. An estimated 40 to
50 percent of refilling establishments in Iowa may require
groundwater remediation. Seventy to 80 percent of the detections
of pesticides in groundwater in Kansas can be traced back to
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refilling establishments. Groundwater contamination by pesticides
is documented at numerous refilling establishments in Michigan,
Illinois, and Utah.
The water quality benefits of controlling the indirect
discharges from PFPR facilities are evaluated by modelling the
impact of those discharges on receiving streams. The effects of
POTW wastewater discharges of 106 PAIs were evaluated at current
and proposed treatment levels for 81 indirect discharging PFPR
facilities which discharge to 74 POTWs on 72 receiving streams.
Water quality models were used to project pollutant in-stream
concentrations based on estimated releases at current and Option 1
levels (see Section 12 for discussion of options); the in-stream
concentrations were then compared to EPA published water quality
criteria or to documented toxic effect levels where EPA water
quality criteria are not available for certain PAIs. Instream
pollutant considerations are modelled for Option 1, the highest
wastewater load option; if no effects are projected to occur for
Option 1, none are projected to occur for the proposed option.
The in-stream pollutant concentration for one pollutant is
projected to exceed human health criteria or human toxic effect
levels in one receiving stream at current discharge levels. The
in-stream pollutant concentrations for 21 pollutants are projected
to exceed chronic aquatic life criteria or aquatic toxic effect
levels in 18 streams at current discharge levels. No exceedances
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of human health or aquatic life criteria or toxic levels are
projected to occur for Option 1; consequently, no exceedances are
projected to occur for the proposed option.
The potential impacts of these indirect discharging PFPR
facilities were also evaluated in terms of inhibition of POTW
operation and contamination of sludge. Potential biological
inhibition problems are projected to occur at five POTWs for six
PAIs; no sludge contamination problems are projected to occur at
current discharge conditions. No potential biological inhibition
or sludge contamination problems are projected to occur for Option
1; consequently, no problems are projected to occur for the
proposed option.
The POTW inhibition and sludge values used in this analysis
are not, in general, regulatory values. They are based upon
engineering and health estimates contained in guidance or
guidelines published by EPA and other sources. Thus, EPA is not
basing its regulatory approach for pretreatment discharge levels
upon the finding that some pollutants interfere with POTWs by
impairing their treatment effectiveness. However, the values used
in the analysis do help indicate the potential benefits for POTW
operation that may result from the compliance with the proposed
opt ion.
15-3
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SECTION 16
NON-WATER QUALITY ENVIRONMENTAL IMPACTS
16.1
NON-WATER QUALITY ENVIRONMENTAL IMPACTS
The elimination or reduction.of one form of pollution may
create or aggravate other environmental problems. Therefore,
Sections 304 (b) and 306 of the Act call for EPA to consider the
non-water quality environmental impacts of effluent limitations
guidelines and standards. Accordingly, EPA has considered the
effect of these regulations on air pollution, solid waste
generation, and energy consumption. These estimates include the
non-water quality impacts from the formulating, packaging and
repackaging of both the 272 PAIs and the non-272 PAIs.
16.1.1
Air Pollution
EPA estimates that facilities may emit 62,200 pounds of
volatile priority pollutants during the treatment process. EPA
does not anticipate significant losses of active ingredients as
most have low volatility. This loss would occur during the
emulsion breaking, hydrolysis and/or chemical oxidation treatment
steps where the addition of heat is likely to promote the release
of the priority pollutants. The air emission estimate is based on
the use of open vessels. Because EPA has developed costs for
closed vessels, our estimate is likely to over estimate the actual
16-1
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losses due to volatilization from treatment. It is possible that
there may be some emissions of priority pollutants during cleaning
of equipment or containers, particularly if high-pressure cleaning
or steam cleaning is used.
EPA estimates that without this regulation 968,000 pounds of
volatile priority pollutants are being discharged to POTWs. An
estimated 499,651 pounds will be lost in the form of emissions as
the water is treated by POTW's. Thus, today's proposal will
reduce the quantity of volatile pollutant emissions to 176,000.
In addition, the emissions will now be localized and more suitable
for capture and treatment.
16.1.2
Solid Waste
EPA estimates there will be 2,038,000 pounds of sludge
generated from emulsion breaking and sulfide precipitation
treatment annually. This sludge is generated from treatment
through the Universal Treatment System. EPA has assumed that the
sludge generated via emulsion breaking and sulfide precipitation
will be hauled to hazardous waste incinerators. In addition
7,400,000 pounds annually of spent activated carbon will be
generated annually. It is assumed that the activated carbon will
be sent off-site for regeneration, which means that it would not
become a waste. There is a possibility of air emissions generated
as a result of the incineration and regeneration of these sludges
16-2
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and wastewater from the air pollution scrubber associated with
most scrubbers. However, hazardous waste incinerators are
required to destroy contaminants up to 99.99%, thus if there are
any residuals they would be at very low concentration. EPA
believes this proposed regulation is consistent with the goals
established for EPA's Draft Strategy for Combustion of Hazardous
Waste, May 1993. This draft strategy establishes as its first
goal wa strong preference for source reduction over waste
management, and thereby reduce the long-term demand for combustion
and other waste management facilities."
16.1.3 Ener
EPA estimates that the attainment of BAT, NSPS, PSES and PSNS
will increase energy consumption by a small increment over present
industry use. The main energy requirement of the proposed
technologies is the generation of steam that is used in the
treatment vessel to accomplish emulsion breaking and hydrolysis.
Steam provides the heat energy to assist with the separation of
emulsified phases and increase the rate at which active
ingredients hydrolyze . It is estimated that about 194 million
pounds per year of steam would be required by the Universal
Treatment System. This would require approximately 42,000 barrels
of oil annually; the United States currently consumes about 19
million barrels per day.
16-3
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Additionally, EPA estimates that the operation of the
Universal Treatment System will consume 1,760,000 kilowatt hours
per year. This is expended by the pumps and agitators used in
treatment and associated with the storage of water until it can be
reused.
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Appendix A
Glossary of Terms
Act - The Clean Water Act
Agency - U.S. Environmental Protection Agency
BAT -The best available technology economically achievable, as
defined by section 304(b)(2)(B) of the Act.
BCT -The best conventional pollutant control technology, as
defined by Section 204(b)(4) of the Act.
BMP -Best management practices, as defined by section 304(e) of
the Act.
BPT -The best practicable control technology currently available,
as defined by section 304(b)(l) of the Act.
Clean Water Act - The Federal Water Pollution Control Act
Amendments of 1972 (33 U.S.C. 1251 et seq.), as amended by the
Clean Water Act of 1977 (pub.L. 95-217), and the Water Quality
Act of 1987 (Pub.L. 100-4).
Conventional Pollutants - Constituents of wastewater as
determined by section 304(a)(4) of the Act,.including, but not
limited to, pollutants classified as biochemical oxygen demand,
suspended solids, oil and grease, fecal coliform, and pH.
Direct Discharger - An industrial discharger that introduces
wastewater to a water of the United States with or without
treatment by the discharger.
Effluent Limitation - A maximum amount, per unit of time,
production or other unit, of each specific constituent of the
effluent from an existing point source that is subject to
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limitation. Effluent limitations may be expressed as a mass
loading in pound per 1,000 pound of active ingredient produced or
as a concentration in milligrams per liter.
End-of-Pipe Treatment (EOF) - Refers to those processes that
treat a plant waste stream for pollutant removal prior to
discharge. EOF technologies are classified as primary (physical
separation processes), secondary (biological processes), and
tertiary (treatment following secondary) processes. Different
combinations of these treatment technologies may be used
depending on the nature of the pollutants to be removed and the
degree of removal required.
Indirect Discharger - An industrial discharger that introduces
wastewater into a publicly owned treatment works.
In-Plant Control or Treatment Technologies - Controls or measures
applied within the manufacturing process to reduce or eliminate
pollutant and hydraulic loadings of loadings of raw wastewater.
Typical in-plant control measures include process modification,
instrumentation, recovery of raw materials, solvents, products or
by-products or by-products, and water recycle.
Nonconventional Pollutants - Pollutants that have not been
designated as either conventional pollutants or priority
pollutants.
NPDES - National Pollutant Discharge Elimination system, a
Federal Program requiring industry dischargers, including
municipalities, to obtain permits to discharge pollutants to the
nation's water, under section 402 of the Act.
A-2
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OCPSF - Organic chemicals, plastics, and synthetic fibers
manufacturing point source category (40 CFR part 414).
PAI - Pesticide Active Ingredient.
POTW - Publicly owned treatment works.
Priority Pollutants - The toxic pollutants listed in 40 CFR part
423, appendix A.
PSES - Pretreatment Standards for existing sources of indirect
discharges, under section 307(b) of the Act.
PSNS - Pretreatment stcindards for new sources of indirect
discharges under section
307(b) and (c)of the Act.
SIC - Standards Industrial Classification, a numerical
categoriazation scheme used by the U.S. Department of Commerce to
denote segments of industry.
Technical Development Eiocument - Development Document for
Effluent Limitations Gudielines and Standards for the Pesticide
Chemicals Formulators, Packagers and Repackagers Point Source
Category.
A-3
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Appendix B
DEFINITIONS OF PESTICIDE PRODUCT FORMULATION TYPES
The following definitions of pesticide product formulations were provided by
EPA's Office of Pesticide Programs:
Crystalline:
Dust:
Emulsifiable Concentrate:
Flowable concentrate:
Formulation Intermediate:
Granular:
Impregnated Materials:
Invert Emulsion:
Pelletted/Tabletted:
Pressurized Gas:
An essentially pure chemical in solid
form, such as copper sulfate (for water
treatments) and paradichlorobenzene (moth
crystals).
Active ingredient mixed with a powdered
dry inert substance such as talc or clay;
applied dry.
Always diluted for use; diluent is a
liquid with polar characteristics opposite
that of solvent in formulation; usually
contains emulsifiers such as glycols,
sulfonates, etc.
A suspension of solid or semi-solid active
ingredient in a liquid; always diluted for
use; also called flowable solid.
Technical chemical to which something has
been added, e.g. a stabilizer; for
formulating use only.
Vermiculite, attaclay, ground walnut
shells, or other similar coarse particles
impregnated with an active ingredient.
May be either a useful article or material
impregnated with a pesticide (e.g., no-
pest-strip, towellettes, weed-killing
bars, roach tape, etc.).
Emulsion consisting of water droplets
surrounded by oil (a common emulsion
consists of oil droplets surrounded by
water).
Active ingredient mixed with binders,
fillers and/or other inerts and formed
into a pellet, tablet, or cake; also
includes capsules (encapsulated' material
which contains active ingredient alone or
with inerts.
Active ingredients are gaseous at room
temperature and atmospheric pressure;
packaged under pressure in a tank, or
spray can; self-pressurized; sometimes
called liquified gases.
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Pressurized Liquid:
Soluble Concentrate:
Solution:
Technical Chemical:
Water-dispersible Granules:
Wettable Powder:
Wettable Powder/Dust:
Active ingredients are solid or liquid at
room temperature and atmospheric pressure;
packaged under pressure with appropriate
solvents and propellants in a tank or
spray can; released for use as an aerosol
or liquid spray.
Always diluted for use, forming a true
solution; diluent is a solvent with the
same polar characteristics as that of the
materials in the formulation.
Used without dilution; may be a liquid,
lotion, or paste.
Raw chemical ingredients as manufactured
with no additives; usually 90% or greater
active ingredient; ordinarily for
formulating use only, but sometimes used
directly as a ULV (ultra low volume)
spray.
A granular formulation made to mix with
water, usually for use as a spray; also
called a dry flowable.
Used as a suspension mixed in water.
Can be used either as a wettable powder in
liquid suspension or dry as a dust.
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Appendix C
Priority Pollutants List
acenaphthene
acrolein
aerylonitrile
benzene
benzidine
carbon tetrachloride
(tetrachloromethane)
chlorobenzene
1,2,4-trichlorobenzene
hexaohlorobenzene
1,2-dichloroethane
1,1,1-trichloroethane
hexachloroethane
1,1-dichloroethane
1,1,2-trichloroethane
1,1,2,2-tetrachloroethane
chloroethane
bis(chloromethyl ether (deleted)
bis(2-chloroethyl)ether
2-chloroethyl vinyl ether(mixed)
2-chloronaphthalene
2,3,6-trichlorophenol
parachlorometacresol
chloroform (trichloromethane)
2-chlorophenol
1,2-dichlorobenzene
1,3-dichlorobenzene
1,4-dichlorobenzene
3,3-dichlorobenzidine
1,1-dichloroethylene
1,2-trans-dichloroethylene
2,4-dichlorophenol
1,2-dichloropropane
1,3-dichloropropylene (1,3-
dichloropropene)
2,4-dimethylphenol
2,4-dinitrotoluene
2,6—dinitrotoluene
1,2-diphenylhydrazine
ethylbenzene
fluoranthene
4-chlorophenyl phenyl ether
4-bromophenyl phenyl ether
bis(2-chloroisopropyl) ether
bis(2-chloroethoxy) methane
tetrachloroethylene
toluene
trichloroethylene
vinyl chloride (chloroethylene)
aldrin
dieldrin
chlordane (technical mixtures
and metabolites)
4,4'-DDT
4,4'-DDE )p-p'-DDX)
4,4'-DDD (p-p'-TDE)
methylene chloride (dichloromethane)
methyl chloride (chloromethane)
methyl bromide (bromomethane)
bromoform (tribromomethane)
dichlorobromomethane
trichlorofluoromethane (deleted)
dichlorofluoromethane (deleted)
chlorodibromomethane
hexachlorobutadlene
hexachlorocyclopentadiene
isophorone
naphthalene
nitrobenzene
2-nitrophenol
4-nitrophenol
2,4-dinitrophenol
4,64,6-dinitro-o-cresol
N-nitrosodimethylamine
N-nitrosodiphenylamine
N-nitrosodi-n-propylamine
pentachlorophenol
phenol
bis(2-ethylhexyl)phthalate
buty benzyl phthalate
di-n-butyl phthalate
di-n-octyl phthalate
diethyl phthalate
dimethyl phthalate
1,2-benzanthracene (benz(o)anthracene)
benzo(a)pyrene(3,4—benzopyrene)
3,4-benzofluoranthene (benzo(b)
fluoranthene)
11,12-benzofluoranthene (benzo(k)
fluoranthene)
chrysene
acenaphthylene
anthracene
1,1,2-benzoperylene (benzo(ghi) perylene)
fluorene
phenanthrene
1,2,5,6-dibenzanthracene (dibenzo(a,h)
anthracene)
indeno(1,2,3-cd)pyrene(2,3-o-
phenylenepyrene)
pyrene
PCB-1254 (Arochlor 1254)
PCB-1221 (Arochlor 1221)
PCB-1232 (Arochlor 1232)
PCB-1248 (Arochlor 1248)
PCB-1260 (Arochlor 1260)
PCB_1016 (Arochlor 1016)
toxaphene
antimony (total)
arsenic (total)
asbestos (fibrous)
beryllium (total)
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Alpha-endosulfan
Beta-endosulfan
endosulfan sulfate
endrin
endrin aldehyde
heptachlor
heptachlor epoxide
Alpha-BHC
Beta-BHC
Gamma-BHC (lindane)
Delta-BHC
PCB-1242 (Arochlor 1242)
cadmium (total)
chromium (total)
copper (total)
cyanide (total)
lead (total)
mercury (total)
nickel (total)
selenium (total)
silver (total)
thallium (total
zinc (total)
2,3,7,8-tetrachlorodibenzo-p-dloxin (TCDD)
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Appendix D
Proposed Regulation
For the reasons set forth in the preamble, 40 CFR Part 455 is proposed to be amended as
follows:
PART 455 - PESTICIDE CHEMICALS
1. Section 455.10 is proposed to be amended by adding paragraph (g) through (j) to read
as follows:
§455.10 General definitions
(g) "Sanitizer Active Ingredients" means the pesticide active ingredients
listed in Table 8.
(h) "Refilling Establishment" means an establishment where the activity of
repackaging pesticide product into refillable containers occurs.
(i) "Interior Cleaning Wastewater Sources" means wastewater that is
generated from cleaning or rinsing the interior of pesticide formulating,
packaging or repackaging equipment, or from cleaning or rinsing the
interior of raw materials containers, shipping containers or bulk storage
tanks.
(j) "Small Quantities of Sanitizer Products" means the formulating,
packaging and repackaging of 265,000 pounds/year or less of all
registered products containing sanitizer active ingredients and no other
active ingredients at a single pesticide producing establishment.
2. Section 455.40 is proposed to be amended to read as follows:
§ 455.40 Applicability; description of the pesticide chemicals formulating,
packaging and repackaging subcategory.
(a) The provisions of this subpart are applicable to discharges resulting
from all pesticide formulating, packaging and repackaging operations
except as provided in subsections (b) and (c).
(b) The provisions of this subpart do not apply to repackaging of
agricultural pesticides performed at refilling establishments whose
principal business is retail sales.
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(c) The provisions of this subpart do not apply to wastewater discharges
from the operation of employee showers, fire protection equipment test
and laundry facilities.
3. New Sections 455.43, 455.44, 455.45, 455.46, 455.47, are proposed to be added to
Subpart C to read as follows:
§ 455.43 Effluent limitations guidelines representing the degree of effluent
reduction attainable by the application of the best conventional
pollutant control technology (BCT).
Except as provided in 40 CFR 125.30-32, any existing point source subject to
this subpart must achieve the effluent limitations representing the degree of effluent
reduction attainable by the application of best conventional pollutant control
technology: There shall be no discharge of process wastewater pollutants to navigable
waters.
§ 455.44 Effluent limitations guidelines representing the degree of effluent
reduction attainable by the application of the best available
control technology economically achievable (BAT).
Except as provided in 40 CFR 125.30-32, any existing point source subject to
this Subpart must achieve the effluent limitations representing the degree of effluent
reduction attainable by the application of the best available technology: There shall
be no discharge of process wastewater pollutants.
455.45
New Source Performance Standards (NSPS)
Any new source subject to this subpart which discharges process wastewater
pollutants must meet the following standards: There shall be no discharge of process
wastewater pollutants.
§ 455.46 Pretreatment Standards for existing sources (PSES).
(a) Except as provided in subsections (b) and (c), any existing source
subject to this subpart which introduces pollutants into a publicly owned
treatment works must comply with 40 CFR 403 and achieve the
pretreatment standards for existing sources as follows: There shall be
no discharge of process wastewater pollutants.
(b) Any wastewater from.the formulating, packaging and repackaging of
small quantities of sanitizer products at any existing source which
introduces pollutants into a publicly owned treatment works must
comply with 40 CFR 403 and achieve the pretreatment standards for
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existing sources as follows: there shall be no discharge of process
wastewater pollutants from Interior Cleaning Wastewater Sources.
(c) The provisions of this section do not apply to discharges resulting from
the formulating, packaging or repackaging of the inorganic active
ingredient sodium hypochlorite (also referred to as bleach).
§ 455.47 Pretreatment standards for new sources (PSNS).
(a) Except as provided in paragraph (b), any new source subject to this
subpart which introduces pollutants into a publicly owned treatment
works must comply with 40 CFR 403 and achieve the pretreatment
standards for new sources as follows: There shall be no discharge of
process wastewater pollutants.
(b) The provisions of this section do not apply to discharges resulting from
the formulating, packaging or repackaging of the inorganic active
ingredient sodium hypochlorite (also referred to as bleach).
40. A new subpart E is proposed as follows:
Subpart E - Repackaging of Agricultural Pesticides Performed by Refilling Establishments
whose principal business is retail sales.
§ 455.60 Applicability; description of the repackaging of agricultural pesticides
performed by refilling establishments whose principal business is retail
sales subcategory.
The limitations and standards of this subpart shall'apply to the repackaging of
agricultural pesticides performed by refilling establishments whose principal business
is retail sales.
§ 455.61 Special Definitions
(a) "Process Wastewaters" for this subpart shall include refillable container
rinsate, wastewater generated by clean-up of leaks and spills and contaminated
precipitation.
§ 455.62 Effluent limitations guidelines representing the degree of effluent
reduction attainable by the application of the best practicable pollutant
control technology (BPT).
Except as provided in 40 CFR 125.30 - 32, any existing point source subject
to this subpart must achieve effluent limitations representing the degree of effluent
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reduction attainable by the application of the best practicable pollutant control
technology: There shall be no discharge of process wastewater pollutants.
§ 455.63 Effluent limitations guidelines representing the degree of effluent
reduction attainable by the application of the best conventional pollutant
control technology (BCT).
Except as provided in 40 CFR 125.30 - 32, any existing point source subject
to this subpart must achieve effluent limitations representing the degree of effluent
reduction attainable by the application of the best conventional pollution control
technology: There shall be no discharge of process wastewater pollutants.
§ 455.64 Effluent limitations guidelines representing the degree of effluent
reduction attainable by the application of the best available technology
economically achievable (BAT).
Except as provided in 40 CFR 125.30 - 32, any existing point source subject
to this subpart must achieve effluent limitations representing the degree of effluent
reduction attainable by the application of the best available technology economically
achievable: There shall be no discharge of process wastewater pollutants.
§ 455.65 New Source Performance Standards (NSPS).
Any new source subject to this subpart which discharges process wastewater
pollutants must meet the following standards: There shall be no discharge of process
wastewater pollutants.
§ 455.66 Pretreatment standards for existing sources (PSES).
Any existing source subject to this subpart which introduces pollutants into a
publicly owned treatment works must comply with 40 CFR 403 and achieve the
pretreatment standards for existing sources as follows: There shall be no discharge of
process wastewater pollutants.
§ 455.67 Pretreatment Standards for New Sources (PSNS).
Any new source subject to this subpart which introduces pollutants into a
publicly owned treatment works must comply with 40 CFR 403 and achieve the
pretreatment standards for existing sources as follows: There shall be no discharge of
process wastewater pollutants.
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Table 8
List of Sanitizer Active Ingredients
CAS No.
00121-54-0
34375-28-5
00134-31-6
15716-02-6
Shaughnessy
Codes
69122
99001
59804
69134
68424-85-1
15716-02-6
00064-02-8
08008-57-9
07647-01-0
08002-09-3
53516-76-0
08001-54-5
08045-21-4
53516-75-9
68391-05-9
68424-85-1
61789-71-7
68424-85-1
68989-02-6
07173-51-5
85409-23-0
05538-94-3
68607-28-3
68607-28-3
00497-19-8
07664-38-2
69105
69134
39107
40501
45901
46621
67002
69104
69106
69111
69112
69119
69137
69140
69141
69145
69149
69154
69165
69166
69173
69194
73506
76001
Benzethonium Chloride (Hyamine 1622)
2-(Hyroxymethyl) amino ethanol (HAE)
Oxine-sulfate
Methyl dodecylbenzyltrimethyl ammonium chloride (Hyamine
2389)
Alkyl demethyl benzyl ammonium chloride (Hyamine 3500)
Methylbenzethonium chloride
Tetrasodium ethylenediaminetetraacetate*
Essential oils
Hydrogen chloride*
Alkyl-l-benzyl-l-(2-hydroxyethyl)-2-imidazolinium chloride
Pine oil
Alkyl dimethyl benzyl ammonium chloride
Alkyl dimethyl benzyl ammonium chloride
Alkyl dimethyl ethylbenzyl ammonium chloride
Alkyl dimethly 1-naphthylmethyl ammonium chloride
Dialkyl methyl benzyl ammonium chloride
Alkyl dimethyl benzyl ammonium chloride
Alkyl dimethyl benzyl ammonium chloride
Alkyl dimethyl benzyl ammonium chloride
Alkyl dimethyl 3,4-dichlorobenzyl ammonium chloride
Didecyl dimethyl ammonium chloride
Alkyl dimethyl ethylbenzyl ammonium chloride
Ocytl decyl dimethyl ammonium chloride
Dioctyl dimethyl ammonium chloride
Oxydiethylenebis(alkyl dimethyl ammonium chloride)
Alkyl dimethyl benzyl ammonium chloride
Sodium carbonate*
Phosphoric acid*
* These active ingredients shall only be considered sanitizer active ingredients when they are
formulated, packaged or repackaged with the other active ingredients on this list and no other
active ingredients.
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Appendix E
Hydrolysis Treatability Data Transfers
Hydrolysis is an aqueous chemical reaction in which a
molecule is broken into two or more organic molecules. As a PAI
or PAI group wastewater treatment technology, hydrolysis typically
takes place at elevated pH and temperature. At these conditions,
the hydrolysis reaction consists of displacing a functional group
on a molecule with a hydroxyl group (OH~) . For example, the
hydrolysis of organophosphate PAIs or PAI groups ( (RO) 2-P(O)-(OX)),
where P is phosphorus, O is oxygen, R is an alkyl group (usually a
methyl or ethyl group) and X is any organic radical, typically
involves the base-promoted formation of a weak organic acid (H-OX)
and a dialkyl phosphate ((RO) 2-P(O)-OH) .
Two types of data gaps exist within the hydrolysis
treatability data. First, there are many PAIs or PAI groups for
which no treatability data, hydrolysis or otherwise, exist. For
some of these PAIs or PAI groups, hydrolysis data may be
transferred from structurally-similar PAIs or PAI groups with
hydrolysis treatability data, based on hydrolysis rate estimation
techniques. However, these techniques are limited in
applicability to only a few types of structures. Second,
half-life data (the common measurement unit of the hydrolysis
reaction rate for a particular constituent) are available for 31
PAIs or PAI groups at conditions other than those considered
optimum for wastewater treatment (in the case of the PFP Universal
Treatment System (UTS) being developed under the costing effort
for the PFP rulemaking proposal, the conditions are pH 12 and
60°C). Data transfers may be conducted for these PAIs or PAI
groups by extrapolating PAI or PAI group data measured at
conditions other than pH 12 and 60°C to these conditions using
kinetically-derived relationships, provided sufficient data are
available to calculate the pH and temperature dependency of the
hydrolysis rate constant.
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E. 1 Hydrolysis Treatability Data Transfer Using Rate
Estimation Techniques
Data Transfer Method
Hydrolysis treatability data indicate that one or more PAIs
or PAI groups in the following structural groups are amenable to
hydrolysis: carbamate, DTT, heterocyclic, lindane, phosphate,
phosphorothioate, phosphorodithioate, phosphorotrithioate,
pyrethrin, and symmetrical triazine. However, there are some PAIs
or PAI groups in these structural groups that lack treatability
data. These PAIs or PAI groups may, to some extent, be amenable
to hydrolysis. In addition, PAIs or PAI groups containing one of
the following reactive function groups may tend to hydrolyze
readily: alkyl halide, ester, phosphate, thiophosphate,
carbamate, epoxide, and nitrile. The PAIs or PAI groups
containing these reactive functional groups but lacking
treatability data are in the following structural groups: alkyl
halide, chloropropionanilide, dithiocarbamate, ester,
phosphoroamidothioate, phthalamide, and amobam (which is from the
miscellaneous structural group).
All of the PAIs or PAI groups within the'following structural
groups are considered amenable to hydrolysis based on the
available treatability data and an analysis of the chemical
structure of the PAIs or PAI groups: alkyl halide, carbamate,
chloropropionanilide, DDT, dithiocarbamate, ester,' heterocyclic,
lindane, phosphate, phosphoroamidothioate, phosphorodithioate,
phosphorothioate, phosphorotrithioate, phthalamide, pyrethrin, and
symmetrical triazine. However, actual transfers of hydrolysis
data are limited to those structural groups for which hydrolysis
rate estimation techniques are available. Hydrolysis estimation
techniques are available only for the carbamate, phosphorothioate,
phosphate, and phosphorodithioate structural groups. The transfer
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of treatability data within these structural groups is discussed
below.
Hydrolysis Data Transfers
Half-life data can be transferred within the carbamate,
phosphate, phosphorothioate, and phosphorodithioate structural
groups based on an analysis of the dissociation constant (pKa
value) of the hydrolysis leaving group, typically a weak organic
acid. For example, the hydrolysis of generic organophosphate PAIs
or PAI groups follows the reaction:
.(RO) 2-P (O)-OX + OH- (+ H20) -> (RO) 2-P (0)-OH + (H)-OX
Where the (H)-OX will most likely dissociate in alkaline solution.
For carbamate and organophosphorus compounds the rate of
hydrolysis is expected to increase as the acid strength of H-OX
increases, as measured by the negative log of the H-OX
dissociation constant, pKa. As a result, the rate of hydrolysis
increases for organophosphate PAIs or PAI groups with H-OX
complexes that have decreasing pKa values. Using pKa values
tabulated in reference texts and pKa estimation techniques,
relative rates of hydrolysis may be estimated for PAIs or PAI
groups based on the half-lives and pKa values of structurally
similar PAIs or PAI groups.
For some PAIs or PAI groups, the degradation product that is
not the leaving group may affect the rate of hydrolysis. For
example, under alkaline hydrolysis conditions, the methyl
derivative of a PAI or PAI group hydrolyzes faster than the ethyl
derivative, for constant X. For example, the half life of methyl
parathion is 6 minutes shorter than ethyl parathion at pH 12 and
60°C. There is no hydrolysis rate estimation method available to
account for the effect of the structure of the degradation product
E-3
-------
that is not the leaving group. However, this effect is not
expected to cause a large change in the predicted hydrolysis half
life, and should not significantly change the cost estimates for
treatment of PFP wastewaters. Therefore, the hydrolysis
treatability data transfer methodology assumes that the
degradation product that is not the leaving group does not affect
the hydrolysis reaction rate.
Table E-l lists the PAIs or PAI groups and structural groups
for which hydrolysis treatability data transfers have been
performed. The table identifies the PAIs or PAI groups,
structural groups, whether treatability data are available, pKa
value of the hydrolysis leaving group,
E-4
-------
(3/22/94) Table E-l
pKa Values of Hydrolysis Products for Select PFP PAIs and PAI Groups
PAI # PAI Name
166 Mexacarbate
201 Propoxur
038 Landrin-1
013 Landrin-2
048 Aminocarb
040 Methiocarb
061 Bendiocarb
146 Karabutilate
075 Carbaryl
272 Chloropropham
145 Propham
228 Previcur N
095 Desmedipham
100 Thiophanate Ethyl
260 Thiophanate Methyl
062 Benomyl
209 Phenmedipham
076 Carbofiiran
156 Methomyl
055 Aldicarb
077 Carbosulfan
195 Oxamyl
042 Polyphase
153 Mefluidide
170 Napropamide
197 Bolstar
127 Ethoprop
106 Dimethoate
186 Azinphos Methyl (Guthion)
113 Dioxathion
183 Disulfoton
126 Ethion
150 Malathion
212 Phorate
185 Phosmet
251 Bensulide or Betesan
155 Methidathion
213 Phosalone
255 Terbufos or Counter
199 Santox (EPN)
200 Fonofos
222 Profenofos
131 Famphur
253 Temephos
133 Fenthion or Baytex
182 Fensulfothion
184 Fenitrothion
234 Fenchlorphos or Ronnel
203 Parathion Ethyl
107 Parathion Methyl
Structural Group
Carbatnate
Carbamate
Carbamate
Caibamate
Caibamate
Caibamate
Caibamate
Carbamate
Caibamate
Caibamate
Caibamate
Caibamate
Caibamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
E-5
Hydrolysis
Treatability
Data (1)
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
Hydrolysis
Product
pKa Value
12.04
10.87
10.72
10.72
10.63
10.36
10.33
9.89
9.34
-1.58
-1.58
-1.58
-1.65
-1.65
-1.65
-2.00
-2.00
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
(SD)
(SD)
-1.58
-1.58
-4.08
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
9.994 (SD)
-1.653 (SD)
10.86
9.99
9.93
9.53
8.52
8.50
7.37
7.15
7.15
Source
(2) Hammett
(2) Hammett
(2) Hammett
(2) Hammett
(2) Hammett
(2) Hammett
(2) Hammett
(2) Hammett
(3)
(2) Taft
(2) Taft
(2) Taft
(2) Taft
(2) Taft
(2) Taft
(2) Taft
(2) Taft
(2) Taft
(2) Taft
(2) Taft
(2)
(2) Taft
(4)
(2) Hammett
(2) Hammett
(4)
(2) Hammett
(2) Hammett
(4)
(4)
(4)
-------
(3/22/94)
Table E-l
pKa Values of Hydrolysis Products for Select PFP PAIs and PAI Groups
PAI#
PAI Name
198 Sulprofos Oxon
086 Chlorpyrifos
085 Chlorpyrifos Methyl
181 Coumaphos
094 Denieton
103 Diazinon
180 Aspon
187 Oxydetneton Methyl
179 Sulfotepp
012 Dichlorvos
022 Mevinphos
024 Chlorfenvinphos
084 Stirofos
108 Dicrotophos
109 Crotoxyphos
173 Nalcd
214 Phosphamidon
Structural Group
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphate
Phosphate
Phosphate
Phosphate
Phosphate
Phosphate
Phosphate
Phosphate
Hydrolysis
Treatability
Data (1)
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
Hydrolysis
Product
pKa Value
-1.58
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Source
(2) Taft
Footnotes;
(1)
(2)
0)
(4)
Key;
A "Yes" indicates that data are available indicating a hydrolysis half life of less than 12 hours
at pH 12 and 60 degrees celsius.
Lyman, WJ. et al. Handbook of Chemical Property Estimation Methods. McGraw-Hill Book Company, 1981.
CRC Handbook of Chemistry and Physics, 60th Edition. Weast, R.C., editor. CRC Press, Inc.
Boca Raton, Florida, 1980.
Lange's Handbook of Chemistry, 13th Edition. Dean, J.K., editor. McGraw-Hill Book Company, 1985.
Not Available - pKa of hydrolyisis products is not available in the literature and is not calculable
using available estimation techniques.
(SD) - Transfer of hydrolysis data based on structural analysis is not considered appropriate because
the structure of the PAI is significantly different from other PAIs in the structural group.
E-6
-------
and source of the leaving group pKa value. The table is sorted by
structural group and pKa value within each structural group. A
"yes" in the "Hydrolysis Treatability Data" column indicates that
data are available showing effective treatment of the PAI or PAI
group by hydrolysis. A blank in the "Hydrolysis Treatability
Data" column indicates that data are not available showing
effective hydrolysis of the PAI or PAI group. "Not Available" is
listed in the pKa value column if the pKa value of the leaving
group is not available in the identified literature, and cannot be
calculated with available pKa value estimation techniques. " (SD)"
is listed in the pKa value column if the leaving group cannot be
identified for the PAI or PAI group because the structure of the
PAI or PAI group is significantly different from other PAIs or PAI
groups within the structural group, or transfer of hydrolysis data
is inappropriate due to dissimilarities in structure between the
PAI or PAI group and other PAIs or PAI groups within the
structural group. The numbers listed in the "Source" column
correspond to the reference text listed in the footnotes to Table
E-l from which the pKa value is available. pKa values determined
by estimation methods are designated as "Taft" or "Hammett"
according to the method used for estimating the pKa value. The
transfer of hydrolysis treatability data for each structural group
listed in Table E-l is described below.
Carbamate—EPA treatability study half-life data are
available for seven carbamate PAIs or PAI groups: carbofuran,
carbaryl, aminocarb, methomyl, methiocarb, chlorpropham, and
propham, and therefore, these PAIs were not considered as
recipients of data transfers. The highest leaving group pKa value
for carbamate PAIs or PAI groups with EPA treatability study
half-life data is 10.63 (aminocarb, half-life <30 minutes). A
hydrolysis half-life of <30 minutes is transferred to bendiocarb,
karabutylate, previcur N, desmedipham, thiophanate ethyl,
thiophanate methyl,- benomyl, and phenmedipham, because these PAIs
or PAI groups are all carbamate PAIs or PAI groups without
E-7
-------
treatability data that have expected leaving group pKa values less
than that of aminocarb. In addition, the Manufacturers' BAT limit
for benomyl is based on hydrolysis, and other treatability data
indicate hydrolysis is an effective treatment for desmedipham and
phenemedipham. The expected leaving group pKa values for
mexacarbate, propoxur, landrin-1, and landrin-2 are greater than
10.63, therefore hydrolysis half-life data are not transferred to
these PAIs or PAI groups. Hydrolysis treatability data are not
transferred to aldicarb, carbosulfan, polyphase, and oxamyl
because the pKa values of their leaving groups cannot be
identified. Hydrolysis treatability data are not transferred to
napropamide and mefluidide because the chemical structure of these
PAIs or PAI groups is significantly different from other
carbamates.
Ph.osph.orodi.thi.oate—PAIs or PAI groups within the
phosphorodithioate structural group have two distinct structural
types. Santox and fonofos are considered separately from the
remaining phosphorodithioate PAIs or PAI groups because their
structure is significantly different. Hydrolysis transfer data
are needed for 6 of the 16 phosphorodithioate PAIs or PAI groups:
ethoprop, bensulide, methidathion, phosalone, terbufos, and
fonofos. Leaving group pKa values can be determined for 5 of the
PAIs or PAI groups within the phosphorodithioate structural group,
including fonofos and santox. A hydrolysis half-life of <30
minutes can be transferred from santox to fonofos. No hydrolysis
treatability data are transferred to the remaining PAIs or PAI
groups with phosphorodithioate structures because their leaving
groups cannot be identified, or the highest pKa value for a PAI or
PAI group with hydrolysis treatability data is lower than the pKa
values for the PAIs or PAI groups without data.
Phosphorothioate—EPA treatability study half-life data are
available for 11 phosphorothioate PAIs or PAI groups: famphur,
fenthion, fensulfothion, fenchlorphos, parathion ethyl, parathion
E-8
-------
methyl, chlorpyrifos, chlorpyrifos methyl, coumaphos, demeton, and
diazinon. The highest leaving group pKa value for
phosphorothioate PAIs or PAI groups with EPA treatability study
half-life data is 9.99 (famphur, half-life 6 minutes). A
hydrolysis half-life of 6 minutes is transferred to temephos,
fenitrothion, and sulprofos oxon, because these PAIs or PAI groups
are all phosphorothioate PAIs or PAI groups without treatability
data that have expected leaving group pKa values less than that of
famphur. In addition, other treatability data indicate hydrolysis
is an effective treatment for fenitrothion. The expected leaving
group pKa value for profenofos is greater than 9.99, therefore
hydrolysis half-life data are not transferred to this PAI.
Hydrolysis treatability data are not transferred to aspon,
oxydemeton methyl, and sulfotepp because the pKa values of their
leaving groups cannot be identified.
Phosphate—pKa values of the hydrolysis leaving groups of
phosphate PAIs or PAI groups cannot be identified; therefore,
hydrolysis half-life data are not transferred between phosphate
PAIs or PAI groups.
E. 2 PAI-Specific Hydrolysis Data Extrapolated to pH 12 and
60°C
Data Extrapolation Method
For several PAIs or PAI groups, hydrolysis data are available
in the Pesticide Manufacturers' or PFP project records, but at
conditions other that pH 12 and 60°C. Hydrolysis treatability
information in the record for the 1978 Pesticides BPT rule
includes a methodology by which hydrolysis data obtained at
ambient and acidic conditions, as well as slightly alkaline
conditions, may be extrapolated to heated and strongly alkaline
conditions. This methodology requires half-life data measured at
several temperatures for the same pH.
E-9
-------
Given the hydrolysis reaction (using a generic
organophosphate PAI or PAI group as an example):
(RO) 2-P (0) -OX + OH- -> (RO) 2-P (O) -OH + HOX
the rate of reaction would be:
r = -dPAI/dt = k2[PAI] [OH-]
where:
PAI = (RO) 2-P (O)-OX
k2 = second-order rate constant.
Arrhenius' equation may be used to model kinetic rate
constants at varying temperatures. The second order rate constant
ka would therefore be:
k2 = Ae-Ea/RT
where:
T — temperature (°K)
R « 1.987 cal/mole-°K
Ea = activation energy (cal/mol)
A = constant (1/mol-min)
k2 = second order rate constant (1/mole-min).
As the pH increases, the hydroxyl ion concentration becomes
much larger than the PAI or PAI group concentration, which results
in a pseudo-first order rate equation. The rate of reaction
becomes:
Integrating:
r = -dPAI/dt = ki[PAI]
PAI/PAI0 =
The half-life equation is therefore:
ti/2 = ln(2)/k!
where:
E-10
-------
ti/2 = half-life in minutes
ki = pseudo-first order rate constant (min-i) .
The pseudo-first order rate constant is related to the second
order rate constant by the following equation:
where:
kx = k2 * 10-pOH
pOH = -log[OH-] = 14 - pH.
The hydrolysis half-life at elevated pH and temperature can
therefore be extrapolated from half-life data measured at other
pHs and/or temperatures, using the following methodology. First,
it is necessary to define the values of the constants A and Ea/R
in Arrhenius" equation at the pH at which the available hydrolysis
data were measured. Plotting In k2 versus 1/T yields a slope equal
to the activation energy coefficient -Ea/R and an intercept equal
to In A. Data collected and analyzed in the record to the 1978
BPT rule indicate that lines plotted for half-life data measured
at different pHs are approximately parallel. The parallel lines
indicate that the activation energy coefficient is nearly constant
with respect to pH. Since the rate constant varies with pH, In A
will also vary with pH. Plotting In A versus pH, based on
half-life data measured at different pHs, should yield a straight
line. This plot may then be used to determine the In A value for
the PAI or PAI group at the desired pH, and the activation energy
coefficient can then be figured in, along with the desired
temperature, in order to calculate the second-order rate constant.
The pOH is then factored in order to calculate the pseudo-first
order rate constant, which in turn yields the half-life at the
heated and alkaline conditions. This approach appears to be
technically valid for PAIs or PAI groups with adequate hydrolysis
rate data measured at different pHs and temperatures. Most PAIs
or PAI groups requiring this type of data transfer, however, have
only limited data.
E-ll
-------
Hydrolysis Data Extrapolations
PAIs or PAI groups for which a half-life at pH 12 and 60°C can
be estimated are identified based on the availability of
hydrolysis half-life data for each PAI. Only four PAIs or PAI
groups for which no half-life data are available at pH 12 and 60°C
(1,3-dichloropropene, atrazine, EDB, and mexacarbate) have
sufficient hydrolysis data available to perform half-life
estimations. The estimation of half-lives for each of these PAIs
or PAI groups is described in the following paragraphs.
1,3-dichloropropene—Hydrolysis half-life data are
available for 1,3-dichloropropene at pH values of 5, 7, and 9 at
temperatures of 10, 20, and 30°C. The hydrolysis rate of
1,3-dichloropropene is reported to be independent of pH, but does
depend on temperature. Figure E-l shows the temperature
dependence of the 1,3-dichloropropene hydrolysis rate. The
hydrolysis half-life of 1,3-dichloropropene at 60°C is estimated to
be 120 minutes.
Atrazine—Hydrolysis half-life data are available for
atrazine at pH values of 12, 12.9, and 14 at 25°C, at pH 16 at
80°C, and at pH 14 at 100°C. (A pH greater than 14 may be achieved
in saturated NaOH solutions or with the use of organic solvents).
Figure E-2 shows the temperature dependence of the atrazine
hydrolysis rate, and is based on the hydrolysis data at pH 14 at
temperatures of 25 and 100°C. Figure E-3 shows the pH dependance
of the atrazine hydrolysis rate, based on all available hydrolysis
half-life data for atrazine. The hydrolysis half-life of atrazine
at pH 12 at 60°C is estimated to be 731 minutes.
E-12
-------
Figure E-l
Plot of In k2 vs. 1/T for 1,3-DichIoropropene
X,
e
In k2 = (-11952)(1/T) + 46.806
4.0
0.0033
i i
0.0034 0.0035
D Ink2
0.0036
1/T (Deg. K)
E-13
-------
Figure E-2
Plot of In k2 vs. 1/T for Atrazine at pH 14
(3.0)
(3.5)-
(4.0)-
(4.5)-
(5.0)-
(5.5)'
(6.0)
Ink2= (-3910)(1/T) + 7.156
Jnk2(pH14)
0.0026 0.0028 0.0030 0.0032 0.0034
1/T (Deg. K)
E-14
-------
Figure E-3
Plot of In A vs. pH for Atrazine
14'
13-
12-
11-
10-
9-
8-
7
lnA= (-0.800)(pH) + 21.351
O D
11 12 13
14
i
15
InA
16 17
pH
E-15
-------
EDB—Hydrolysis half-life data are available for EDB at pH 7
at temperatures of 30, 45, and 60°C, at pH 7.5 at temperatures of
50 and 70°C, and at pH 9 at temperatures of 30, 45, and 60°C.
Figure E-4 shows the temperature dependence of the EDB hydrolysis
rate at pH 7. Figure E-5 shows the pH dependance of EDB and is
based on calculations of an average value of the Arrhenius
constant "A" for each pH. The half-life of EDB at pH 12 at 60°C is
estimated to be 1,850 minutes.
Mexacarbate—Hydrolysis half-life data are available for
mexacarbate at pH 7 at temperatures of 10, 20, and 28°C, and at pH
8.42 at temperatures of 10, 20, and 28°C. Figure E-6 shows the
temperature dependence of the mexacarbate hydrolysis rate at pH 7.
Figure E-7 shows the pH dependance of mexacarbate based on
calculations of an average value of the Arrhenius constant "A" for
each pH. The half-life of mexacarbate at pH 12 at 60°C is
estimated to be 2.4 minutes.
E-16
-------
Figure E-4
Plot of In k2 vs. 1/T for EDB at pH 7
In k2 = (-11697)(1/T) + 41.055
lnk2(pH7)
0.0029 0.0030 0.0031 0.0032 0.0033
1/T (Deg. K)
E-17
-------
Figure E-5
Plot of In A vs. pH for EDB
42-
41-
40-
39-
38-
37-
In A = (-1.804)(pH) + 53.495
D In A
7.0 7.5 8.0 8.5 9.0 9.5
pH
E-18
-------
Figure E-6
Plot of In k2 vs. 1/T for Mexacarbate at pH 7
7.000
6.500-
6.000-
5^00-
5.000-
4.500-
4.000
In k2 = (-11224)(1/T) + 43.732
lnk2(pH7)
0.0033
0.0034
0.0035
0.0036
1/T (Deg. K)
E-19
-------
Figure E-7
Plot of In A vs. pH for Mexacarbate
44-
44-
43-
42-
42-
42'
lnA= (-1.332)(pH) + 53.059
D MA
6.5 7.0 7.5 8.0 8.5 9.0
pH
E-20
-------
Appendix F
Comparison of Median Concentrations
Vs. Sampled Concentrations
Commingled raw (influent) PFPR wastewater samples were
collected and analyzed during two sampling episodes. A total of
nine PAIs were detected in the wastewater from these two
facilities. In addition these PAIs were reported in their 1988
production. As a result, both analytical and calculated PAI
concentrations exist for these two facilities for these nine PAIs.
Table F-l presents a comparison between the range of analytical
results and the calculated concentrations (median concentrations
and 90th percentile concentrations) for each of the nine PAIs.
[Note: PAI names have been sanitized for confidentiality.] The
calculated influent concentrations used for the PFPR costs and
loadings are labelled "median PAI concentrations." The median
calculated influent PAI concentrations are greater than the median
sampled concentrations for three of the four PAIs for which both
types of concentrations were available for Episode A, and for four
of the five such PAIs for Episode B. Concentrations in bold type
represent the highest concentration for each PAI.
For comparison purposes, influent PAI concentrations were
recalculated based on the transfer of the 90th percentile highest
F-l
-------
PAI concentrations for each stream type. These concentrations are
labelled "high PAI concentrations." The 90th percentile
calculated concentrations are greater than the median sampled
influent concentrations for all four of the PAIs in Episode A and
for four of the five in Episode B. In addition, however, the 90th
percentile calculated concentrations are also one to two orders of
magnitude greater than the maximum sampled concentrations for
three of the four PAIs sampled in Episode A and four of the five
in Episode B. This result indicated that transferring 90th
percentile high influent PAI concentrations to PAIs lacking
analytical data results in the calculation of commingled raw
wastewater PAI concentrations that are much higher than actually
sampled. Transferring median PAI concentrations results in
calculated PAI concentrations that are much closer to the sampled
concentrations.
F-2
-------
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-------
-------
Appendix G: Sample PFPR Facility Costs
This appendix presents the Option 3 and 3S compliance
cost for three surveyed PFPR facilities, and discusses how the
costing methodology presented in Section 8 is applied to each of
these facilities. Option 3 costs are estimated based on storage
and reuse of most PFPR interior equipment cleaning wastewater
streams, direct reuse of drum shipping container rinsates and
most bulk storage tank rinsates, and treatment and reuse of all
other discharged PFPR wastewater streams. Option 3S costs are
equal to the Option 3 costs, except for exterior PFPR wastewater
streams that only contain "sanitizer" PAIs; these streams may be
discharged without treatment. Table G-l identifies the three
facilities and lists their PFPR wastewater and PAI data. The
three facilities, 340, 2669, and 7227, were selected based on
wastewater volume and PAIs expected to be in each facility's
wastewater. Tables G-2 through G-4 present the line item
treatment and storage costs for facility 340. Tables G-5 and G-6
present the line item•treatment costs for facility 2669. Table
G-7 presents the line item treatment costs for facility 7227
(treatment costs are only included under Option 3 for this
facility). Table G-8 presents the overall Option 3 and 3S
compliance costs for each facility.
G-l
-------
Facility 340
Facility 340 discharged a total of 48,487 gallons of
PFPR wastewater in 1988. Interior equipment cleaning water that
can be reused without treatment totals 20,446 gallons. This
water would incur storage and reuse costs. The remaining 28,041
gallons of wastewater would require treatment prior to reuse
under Option 3. Table G-2 presents the itemized UTS. Option 3
design parameters and component costs. Table G-2 lists the
influent and achievable effluent PAI concentrations,
corresponding treatability data, and design and cost information
for the following components: the wastewater storage tanks; the
process vessel(s); the activated carbon system; pumps and
strainers; containment; solids disposal; and land, monitoring,
and miscellaneous costs. Likewise, Table G-3 presents the
itemized storage and reuse design parameter and component costs.
Table G-3 lists the storage requirements for each line, and the
costs associated with the tanks, drums, and containment system.
The total Option 3 costs equal the sum of the UTS capital and
annual operating and maintenance (O&M) costs, $56,569 and
$25,838, respectively, and the storage and reuse, capital and O&M
costs, $27,868 and $815, respectively.
Facility 340 discharged a total of 12,607 gallons of
non-interior PFPR wastewater that only contains sanitizer PAIs,
Under Option 3S, this wastewater is considered exempt from the
G-2
-------
PFPR regulation and may be discharged without treatment. The
Option 3S costs are therefore based on storage and reuse of the
20,446 gallons of interior equipment cleaning water, and the
treatment and reuse of the remaining 15,434 gallons. The Table
G-3 storage and reuse costs remain unchanged, and the UTS capital
and O&M costs are reduced to $33,348 and $18,617, respectively.
The Option 3S UTS component costs are summarized on Table G-4.
Facility 2669
Facility 2669 discharged a total of 1,101,823 gallons
of wastewater in 1988. None of this water included reusable
interior equipment cleaning water. As a result, the Option 3
compliance costs are estimated based on the treatment and reuse
of all 1,101,823 gallons. Table G-5 presents the itemized UTS
Option 3 design parameters and component costs. The UTS capital
cost equals $1,789,487 and the UTS O&M cost equals $427,023.
Facility 2669 discharged 47,490 gallons of wastewater
considered exempt under Option 3S. The Option 3S costs are
therefore based on the treatment and reuse of the remaining
1,054,333 gallons. The UTS capital cost is reduced to $1,760,369
and the UTS O&M cost is reduced to $422,970. The Option 3S UTS
component costs are summarized on Table G-6.
G-3
-------
Facility 7227
Facility 7227 discharged a total of 1,903 gallons of
wastewater in 1988. None of this water included reusable
interior equipment cleaning water. As a result, the Option 3
compliance costs are estimated based on the treatment and reuse
of all 1,903 gallons. Table G-7 presents the itemized UTS Option
3 design parameters and component costs. The UTS capital cost
equals $26,974 and the UTS O&M cost equals $10,843.
All 1,903 gallons of"wastewater discharged by the
facility is considered exempt under Option 3S. As a result, the
facility does not incur Option 3S compliance costs.
G-4
-------
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ss
CO
s
00 <-l T-4
•* o
w
e2
G-5
-------
i
0
1
13
in
|
1
Ti
"E
o
~ g
OJ
O tD -3~
*•% ^% ro
52 S
S
e
i
1
•g
1
•a
3
ra
j_
t
33
1
^
G-6
-------
Table 2 (cont.)
Facility 340 Universal Treatment System - Option 3
TOTAL CAPITAL COSTS
Wastewater Storage Costs: $11,062
Process Vessel .Costs: $11,563
Activated Carbon Costs: $4,926
Pump/Strainers Costs: $7,207
Ultrafiltration Costs: $0
Containment Costs: $8,229
Disposal Costs: $319
Total Equipment Costs: $43,306
Land Purchase Costs: $271
Miscellaneous Equipment Costs: $8,661
Engineering/Admin ./Legal Costs: $4,331
FACILITY CAPITAL COSTS:
$56,569 j
TOTAL O & M COSTS
Process Vessel Costs: $3,067
Activated Carbon Costs: $11,573
Pump/Strainers Costs: $576
Ultrafiltration Costs: $0
Containment Costs: $558
Disposal Costs: $6,201
Monitoring Costs: $1,600
Annual O & M Costs: $23,576
Miscellaneous Q & M Costs: $1,697
Insurance Costs: $566
FACILITY O & M COSTS:
$25.838
G-7
-------
r
Table 2 (cont)
Facility 340 Universal Treatment System - Option 3
D&T* & 3TQ8AOE '
<. s *• W
Annual Flow (gal):
28,041
Large Batch Flow (gal):
Number of Quarters WW Generated:
Quarter 1 Flow (gal):
Quarter 2 Flow (gal):
Quarters Flow (gal):
Quarter 4 Flow (gal):
Design Flow (gal):
7,010
4
7,010
7,010
7,010
7,010
8,412
3TEWATER STORAGE DESIGN I :
iv..^ -".-.v ^ ^ / *• VA-•'•'>•:%% v AV*^ «/ dw
Raw Wastewater Storage
Number of Tanks: 1
Volume of Tanks: 9,000
Type of Tanks: Carbon Steel
Effluent Wastewater Storage
Number of Tanks: 1
Volume of Tanks: 9,000
Type of Tanks: Carbon Steel
STORAGE TANK CAPITAL COSTS
Cost per tank:
Total Tank Capital Costs:
$5,531
$11,062
-------
Table 2 (conl.)
Facility 340 Universal Treatment System - Option 3
Required Suffide Praopittfon Tim* (hrs):
Required HydroV«s Tim* (hra):
Required Chem. Ox Turn (ha):
Required Emulsion Breaking Tim* (his):
Total Treatment Time (hf»):
Total Treatment Tim* (days):
0
0
0
24
24
1
Process V*ss*i 1
Number of Proem Vessels:
Volumeo( Process Visuli (gal):
Number of Annual Treatment Batches:
1
1000
ProcwsV*sMl2
Number of Procnx Veuala: 1
Voluroeof Proc«uVe»Mb(gal): 1000
Auxiliary Equlpmmt
NumbarofAgitaton: 2
Agitator Power (npfrmMl): 1
Wat Vacuum Pump: 0
Powar of W«t Vacuum Puny (hp): 0
Tnulmant Raqulramants
Staam (ttyr):
Acid (be 50% H2SO4/yt):
Chlorina (gal 10% NaOCVyr)
Sodium Suffid*(t>aNa2S/yr):
AcidSto«s»ArMRaqurad( U COSTS
Labor (man-hts/yr):
Ubor Costs:
145
2495
Procass Vassal Agtator 124
Wet Vacuum Pump: p_
Total Energy Requirements: 124
Annual Enargy Costa: 10
Staam Cost: 87
Caustic Cost: 43
• Acid Cost 432
Chlorine Cost: 0
• Sodium SurSde Cost 0
Annual O 4 H Costs:
3067J
G-9
-------
Table 2 (conL)
Facility 340 Universal Treatment System - Option 3
-;.:AC»»ATSJ'C*RBON SYSTEM SESfiSS
Feed Tank Design
Number of Tanks:
Tank(s) Volume (gal):
Tank(s) Type:
AC System Onlgn
EBRT (mln):
Design Flow (gal):
Quarterly Flow (gal):
Daily Flow Rate (gpd):
Row Rate (gpm):
1
1.000
Carbon Steel
120
8.412
93.47
0.19
Required AC Vessel Vol. (gal):
AC System Type:
Number of Vessels In Series:
Backwash System:
Backwash Rate (gpm):
Backwash Pump Power (hp):
Backwash Volume (gal):
Carbon Usage (Ibtyear):
Carbon per Vessel (Ib/vessel):
Adsorbers per year.
AC SYSTEM CAPITAL COSTS
Feed Tank Cost:
Total Feed Tank Costs:
Cost per AC Unit:
Total AC System Cost:
Backwash System Cost:
Total AC System Capital Co«t»:£
AC SYSTEM O & M COSTS
Labor (man-hours):
Quarter 1:
Quarter 2:
Quarters:
Quarter 4:
Annual man-hours:
Annual Labor Costs:
Energy Requirements (kw-hr/yr)
Backwash Pump:.
Annual Energy Costs:
AC Vessel Replacement Cost:
Annual Carbon Costs:
Annual TOC Monitoring Costs:
MA
NA
NA
1,584
165
10
$1,026
$1.026
$1.300
$3.900
$0
$4.926 |
5
S
5
5
20
$344
$0
$1,033
$10,330
Total AC System O&M Costs:[
$11.573 I
G-10
-------
^ ... Table 2 (com.)
Facility 340 Universal Treatment System - Option 3
Large
2
50
1.5
50
1.5
Yes
0.5
Large or Small System:
Number of Process Vessel Pumps:
Capacity of Process Vessel Pumps (gpm):
Power of Process Vessel Pumps (hp):
Capacity of AC Feed Pump:
Power of AC Feed Pump:
Waste Pump:
Power of Waste Pump (hp):
Number of In-Line Strainers:
PUMP/STRAINER CAPITAL COSTS
Cost per Process Vessel Pump:
Cost for AC Feed Pump:
Cost for Waste Pump:
Cost per !n-Line Strainer:
Total Pump/Strainer Capital Costs :f
PUMP/STRAINER Q & M COSTS
Vessel Pumps:
AC Pump:
Waste Pump:
Total Energy Required (kw-hr/yr):
Annual Energy Costs:
Strainer Cleaning Labor (hrs/yr):
Annual Labor Costs:
Annual Pump/Strainer O & M Costs:
$1,747
$1,747
$275
$845
$7,207
93
3,837
0
3,929
$326
14.5
$250
$576
G-ll
-------
r
Table 2 (cont.)
Facility 340 Universal Treatment System - Option 3
System Component Number of Tanks Size of Tanks Dia.
Influent Storage Tanks
Effluent Storage Tanks
Process Vessels
AC Feed Tank(s)
AC System
1
1
2
1
0
1
9,000
9,000
1,000
1,000
0
250
of Tanks ' Area Displaced Area Required
11
11
5.33
5.33
0
3.33
95.0
95.0
44.6
22.3
0.0
8.7
289.0
289.0
256.7
128.4
0.0
87.0
Amount of Space Required (sf):
Containment Provided (gal):
Containment Required (gal):
CS Area (sf):
CS Perimeter (ft):
Containment Capital Costs
Concrete Floor (1991 Cost):
Concrete Dike (1991 Cost):
Floor Coaling (1991 Cost):
Dike Coating (1991 Cost):
Total CIS Cost (1988 Cost):
Total Capttal Costs (1988):
1,260
14,877
11,250
1,260
142
5,041
2,063
1.134
8,494
$7,757
$8.229 I
AC Containment Costs
Capital Costs (1988):
O&M Costs (1988):
$472
$42
Recoating Every 3 Years
Floor Recoating:
Dike Recoating:
Total Recoating Cost:
Ammortized Recoating Cost:
1,094
312
$1,284
$516
TotalO&MCost(1988):
$558
G-12
-------
Table 2 (com.)
Facility 340 Universal Treatment System - Option 3
' ': \ - WASTE DBPOSAL , , -N
•• *• ' f f ff A% % -,•?
Fteject Wastewater
Quarter 1 Wastewater:
Quarter 2 Wastewater:
Quarter 3 Wastewater:
Quarter 4 Wastewater:
Maximum quarterly wastewater:
PrecipjtatJon_Sonds _Rernova[
Solid Disposal (Ib/yr):
DISPOSAL CAPITAL COSTS
Number of Wastewater Storage Tanks:
Wastewater Storage Tank Size:
Wastewater Storage Tank Cost:
14.02
14.02
14.02
14.02
14.02
0.00
1
250
$319
Total Disposal Capital Costs:
$319
DISPOSAL O & M COSTS
Quarter 1 Wastewater Disposal Cost:
Quarter 2 Wastewater Disposal Cost:
Quarter 3 Wastewater Disposal Cost:
Quarter 4 Wastewater Disposal Cost:
Solid Disposal Cost:
Total Disposal O & M Costs:!
$1,550
$1,550
$1,550
$1,550
$0
$6,201
G-13
-------
r
Table 2 (cont.)
Facility 340 Universal Treatment System - Option 3
Monitoring Costs per Quarter: $400
Annual Monitoring Costs: $1,600
Land Cost ($/sq. ft.): $0.22
Land Requirement (sq. ft.): 1,260
Total Land Purchase Cost: . $271
G-14
-------
i
I
•a
to
CO o>
£ 2
A o
£w
o
TT
CO
o
•2
§
"3
0.
CO
i:
|
^
3
^
•o
^
3»
0
f)
3
£
i
3
in
CM
in
g"
1
Q.
E
o.
^
^"
O
.
o>
§•
ffl
at
Sin o
tn o
1
a.
1
i
W
I
CD
o
Q
"3
£
•
-------
Tables (cont.)
Facility 340 Storage and Reuse
Tanks
Amount of Space Required (sf):
(includes 20% extra space)
Containment Provided (gal):
Containment Required (gal):
1 .909
24,898
1,250
CS Area (sf):
CS Perimeter (ft):
1,909
1751
Concrete Floor (1991 Cost): 7,635
Concrete Dike (1991 Cost): 2,539
ROOT Coating (1991 Cost): 1,718
Dike Coating (1991 Cost): 315
Total C/S Cost (1988 Cost):
Fees & Design Cost:
Contingency Cost:
Re
-------
Table 3 (cent.)
Facility 340 Storage and Reuse
Size
250
500
1,000
1,500
2,000
2,500 -
3,000
3,500
4,000
4,500
5,000
6,000
7,000
8,000
9,000
10,000
11,000
12,000
13,000
14,000
15,000
16,000
17,000
18,000
19,000
20,000
21,000
22,000
23,000
24,000
25,000
26,000
27,000
28,000
29,000
30,000
Cost
$236
$435
$801
$740
$878
$1,020
$1,166
$1 ,31 7
$1,472
$1,632
$1 ,797
$2,139
$2,498
$2,876
$3,271
$3,685
$6,277
$6,373
$6,476
$6,586
$6,703
$6,827
$6,953
$7,096
$7,241
$7,394
$7,553
$7,720
$7,893
$8,074
$8,262
$8,457
$8,659
$8,868
$9,084
$9,308
Tanks
1988 Cost
$216
$397
$731
$846
$1 ,003
$1,165
$1,332
$1 ,505
$1,682
$1,865
$2,052
$2,443
$2,854
$3,285
$3,737
$4,209
$7,171
$7,281
$7,398
$7,523
$7,657
$7,799
$7,948
$8,106
$8,272
• $8,446
$8,629
$8,819
$9,017
$9,224
$9,439
$9,661
$9,892
$10,131
$10,378
$10,633
Installed
$319
$588
$1,083
$1,251
$1,484
$1,724
$1 ,972
$2,227
$2,490
$2,760
$3,038
$3,616
$4,224
$4.862
$5,531
$6,230
$10,613
$10,775
$1 0,949
$11,135
$11,332
$11,542
$11,764
$11,997
$12,243
$12,501
$12,770
$13,052
$13,346
$13,651 .
$13,969
$14,299
$14,640
$14,994
$15,360
$15,737
Type
Poly
Poly
Poly
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
.Steel
• Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Steel
Diameter
3.33
4
5.33
5.33
7.33
7.33
8
8
8.33
8.33
9
10
11
11
11
12
12
12
13
13
14
14
15
15
15
16
16
16
16
16
17
17
17
17
18
19
G-17
-------
Table 4
Facility 340 Universal Treatment System - Option 3S
TOTAL CAPITAL COSTS
Wastewater Storage Costs:
Process Vessel Costs:
Activated Carbon Costs:
Pump/Strainers Costs:
Ultrafiltration Costs:
Containment Costs:
Disposal Costs:
Total Equipment Costs:
Land Purchase Costs:
Miscellaneous Equipment Costs:
Engineering/AdminVLegal Costs:
$6,075
$6,194
$4,926
$1,404
$0
$6,576
$319
$25,494-
$205
$5,099
$2,549
FACILITY CAPITAL COSTS:
$33.348
TOTAL O & M COSTS
Process Vessel Costs: $1,883
Activated Carbon Costs: $6,969
Pump/Strainers Costs: $176
Ultrafiltration Costs: $0
Containment Costs: $454
Disposal Costs: . $6,201
Monitoring Costs: $1,600
Annual O & M Costs: $17,283
Miscellaneous O & M Costs: $1,000
Insurance Costs: $333
FACILITY O & M COSTS:
$18,617
G-18
-------
,0
•s.
o
•£
o
to £
«o
2 £
g o
lit
tO f-~ 3
CO IO —;
CM 2
2
X
I
I
8
JD
s
o
88
o o"
O a>
E
I
CM .
O
CO
2
I
5
I
C O
8
i
§
10 ^.
s l
3
CO
co
G-19
-------
Table 5 (cont.)
Facility 2669 Universal Treatment System - Option 3
TOTAL CAPITAL COSTS
Wastewater Storage Costs: $359,855
Process Vessel Costs: $29,493
Activated Carbon Costs: $887,514
Pump/Strainers Costs: $1 1 ,021
Ultrafiltration Costs: $0
Containment Costs: $87,619
Disposal Costs: $1 ,026
Total Equipment Costs: $1 ,376,528
Land Purchase Costs: $0
Miscellaneous Equipment Costs: $275,306
Engineering/AdminVLegal Costs: $137,653
FACILITY CAPITAL COSTS: $1, 789.487 j
TOTAL O & M COSTS
Process Vessel Costs: $41,854
Activated Carbon Costs: $283,277
Pump/Strainers Costs: $2,986
Ultrafiltration Costs: $0
Containment Costs: $5,215
Disposal Costs: $21,311
Monitoring Costs: $800
Annual O & M Costs: $355,443
Miscellaneous O & M Costs: $53,685
Insurance Costs: $17,895
FACILITY O & M COSTS: $427.023 |
G-20
-------
Table 5 (cont.)
Facility 2669 Universal Treatment System - Option 3
„'; vWASTEWATSf* DATA
Annual Flow (gal): 1,101,823
Large Batch Flow (gal): 275,456
Number of Quarters WW Generated: 4
Quarter 1 Flow (gal): 275,456
Quarter 2 Flow (gal): 275,456
Quarter 3 Flow (gal): 275,456
Quarter 4 Flow (gal): 275,456
Design Flow (gal): 330,547
Raw Wastewater Storage
Number of Tanks: 12
Volume of Tanks: 28,000
Type of Tanks: Carbon Steel
Effluent Wastewater Storage
Number of Tanks: 12
Volume of Tanks: 28,000
Type of Tanks: Carbon Steel
STORAGE TANK CAPITAL COSTS
Cost per tank:
total Tank Capital Costs: [
$14,994
$359,855
G-21
-------
Table 5 (cent.)
Facility 2669 Universal Treatment System - Option 3
Required Suffide Precipitation Time (hra):
Required Hydrolyeis Tim* (hra):
Required Chem. Ox Tim* (hts):
Required Emulsion Breaking Time (his):
Total Treatment Time (hra):
Total Treatment Time (days):
0
0
0
24
24
1
Process Vessel 1
Number of Process Vessels: ' 2
Volume of Process Vessels (g«l): 2000
Number of Annual Treatment Batches: 278
(MRtqanttj
Process Vessel 2
Number of Process Vessels: 2
Volume of Process Vessels (gal): 2000
Auxiliary Equipment
Number of Agitators: 4
Agitator Power (hp/vessel): 1
Wet Vacuum Pump: 0
Power of Wet Vacuum Pump (hp): 0
Treatment Requirement!
Steam (bryr): 1753152
Add (bs 50% H2SO*yr): 18833
Caustic (be 50% NaOH/yr): 16527
Chlorine (gal 10% NaOCI/yr) 0
Sodium SutSdeflbsNaZSyr): 0
Acid Storage Area Required (sq. ft): 42
Caustic Storage Area Required (sq.ft.): 42
Chlorine Storage Required (sq. ft): 0
Sodium SuKde Storage Required (sq. ft): 0
PROCESS VESSEL CAPITAL COSTS
Cost per Process Vessel:
Total Vessel Costs:
Cost for Wet Vacuum Pump:
Sjoraj]eAreaCpBts:_
Acid Storage Area:
Caustic Storage Area:
Chlorine Storage Area:
8816
27262
1275
956
0
Total Capital Costs: \_
PROCESS VESSEL O > U COSTS
Labor (man-hn/yr):
Labor Costs:
1380
23750
Energy Requirements jkw-hr/^r)
"process Vessel Aortattr" 4708
Wet Vacuum Pump: 0_
Total Energy Requirements: 4708
Annual Energy Costs: 391
Steam Cost: 3200
Caustic Cost 1040
Acid Cost: 13374
Chlorine Cost: 0
Sodium SuKde Cost: 0
Annual O & U Costs:
41884
G-22
-------
Table 5 (cont)
Facility 2669 Universal Treatment System - Option 3
Feed Tank Design
Number of Tanks:
Tank(s) Volume (gal):
Tank(s) Type:
AC System Design
EBRT (min):
Design Flow (g_al):_
Quarterly Flow (gal):
Daily Flow Rate (gpd):
Flow Rate (gpm):
Required AC Vessel Vol. (gal):
1
4.000
Carbon Steel
30
330.547
3672.74
7.65
77
AC System Type:
Number of Vessels in Series:
Backwash System:
Backwash Rate (gpm):
Backwash Pump Power (hp):
Backwash Volume (gal):
Carbon Usage (Ib/year):
Carbon per Vessel (ItWessel):
Adsorbers per year.
AC SYSTEM CAPITAL COSTS
Feed Tank Cost:
Total Feed Tank Costs:
Cost per AC Unit:
Total AC System Cost:
Backwash System Cost:
Total AC System Capital Co«ts:£
AC SYSTEM O & M COSTS
Labor (man-hours):
Quarter 1:
.Quarter 2:
Quarter 3:
Quarter 4:
Annual man-hours:
Annual Labor Costs:
Energy Requirements (kw-hrjyr)
Backwash Pump: _
Annual Energy Costs:
AC Vessel Replacement Cost:
Annual Carbon Costs:
Annual TOG Monitoring Costs:
560
12
112,000
257,148
20,000
13
$2.490
$2,490
$285.910
$857,730
$27.294
$887.514 |
25
25
25
25
100
$1,721
0_
$0
$21.000
$273,000
$8.556
Total AC System O&M Costs:!
$283,277 I
G-23
-------
Table 5 (cont.)
Facility 2669 Universal Treatment System - Option 3
^i;\"PUMFSAlibST^lNERS T
Large or Small System:
Number of Process Vessel Pumps:
Capacity of Process Vessel Pumps (gpm):
Power of Process Vessel Pumps (hp):
Capacity of AC Feed Pump:
Power of AC Feed Pump:
Waste Pump:
Power of Waste Pump (hp):
Large
Yes
0.5
4
75
3
50
1.5
Number of In-Line Strainers:
PUMP/STRAINER CAPITAL COSTS
Cost per Process Vessel Pump:
Cost for AC Feed Pump:
Cost for Waste Pump:
Cost per In-Line Strainer:
Total Pump/Strainer Capital Costs:[
PUMP/STRAINER O & M COSTS
Vessel Pumps:
AC Pump:
Waste Pump:
Total Energy Required (kw-hr/yr):
Annual Energy Costs:
Strainer Cleaning Labor (hrs/yr):
Annual Labor Costs:
Annual Pump/Strainer 0 & M Costs:
$1,827
$1,747
$275
$845
$11,021
3,530
3,837
1
7,367
$611
138
$2,375
$2,986
G-24
-------
Table 5 (cont.)
Facility 2669 Universal Treatment System - Option 3
System Component
Influent Storage Tanks
Effluent Storage Tanks
Process Vessels
AC Feed Tank(s)
AC System
Waste Disposal Tank
Number of Tanks
12
12
4
1
6
1
Size of Tanks
28,000
28.000
2,000
4,000
12,000
1,000
17
17
7.33
8.33
7.5
5.33
2723.8
2723.8
168.8
54.5
265.1
22.3
6348.0
6348.0
710.8
205.3
1093.5
Amount of Space Required (sf):
Containment Provided (gal):
Containment Required (gal):
CS Area (sf):
CS Perimeter (ft):
Containment Capita! Costs
Concrete Floor (1991 Cost):
Concrete Dike (1991 Cost):
Floor Coating (1991 Cost):
Dike Coating (1991 Cost):
Total C/S Cost (1988 Cost):
Total Capital Costs (1988):
Total O & M Cost (1988):
17',801
177,165
35,000
17,801
534
71,203
7,754
16,021
961
"95,939"
$87,619
$87,619
_Recoating Every 3 Years
Floor Recoating: ' 13,027
Dike Recoating: 1,174
Total Recoating Cost: $12,969
Ammortized Recoating Cost: $5,215
$5.215]
AC Containment Costs
Capital Costs (1988):
O&MCosts(1988):
$0
$0
G-25
-------
Table 5 (cont.)
Facility 2669 Universal Treatment System - Option 3
;\7f WASTE DISPOSAL
Reject Wastewater
Quarter 1 Wastewater:
Quarter 2 Wastewater:
Quarter 3 Wastewater:
Quarter 4 Wastewater:
Maximum quarterly wastewater:
Solid Disposal (Ib/yr):
DISPOSAL CAPITAL COSTS
Number of Wastewater Storage Tanks:
Wastewater Storage Tank Size:
Wastewater Storage Tank Cost:
550.91
550.91
550.91
550.91.
550.91
0.00
1
1000
$1,026
Total Disposal Capital Costs:
$1,026
DISPOSAL O & M COSTS
Quarter 1 Wastewater Disposal Cost:
Quarter 2 Wastewater Disposal Cost-
Quarter 3 Wastewater Disposal Cost:
Quarter 4 Wastewater Disposal Cost:
Solid Disposal Cost:
Total Disposal O & M Costs:
$5,328
$5,328
$5,328
$5,328
$0
$21,311
G-26
-------
Table 5 (cont.)
Facility 2669 Universal Treatment System - Option 3
Monitoring Costs per Quarter:
Annual Monitoring Costs:
Land Cost ($/sc :.):
Land Requirement (sq. :i.):
Total Land Purchase Cost:
$200
$800
$0.00
17,801
$0
-------
Table 6
Facility 2669 Universal Treatment System - Option 3S
TOTAL CAPITAL COSTS
Wastewater Storage Costs:
Process Vessel Costs:
Activated Carbon Costs:
Pump/Strainers Costs:
Ultrafiltration Costs:
Containment Costs:
Disposal Costs:
Total Equipment Costs:
Land Purchase Costs:
Miscellaneous Equipment Costs:
Engineering/Admin Aegal Costs:
$337,91 1
$29,175
$887,514
$1 1 ,021
$0
$87,484
$1 ,026
$1,354,130
$0
$270,826
$135,413
FACILITY CAPITAL COSTS: $1.760,369 j
TOTAL O & M COSTS
Process Vessel Costs: $40,039
Activated Carbon Costs: $282,836
Pump/Strainers Costs: $2,870
Ultrafiltration Costs: $0
Containment Costs: $5,142
Disposal Costs: $20,867
Monitoring Costs: $800
Annual O & M Costs: $352,556
Miscellaneous 0 & M Costs: $52,811
Insurance Costs: $17,604
FACILITY O & M COSTS: $422.970 |
G-28
-------
£
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88
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OS
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r«-
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P
if
o
o
3
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£
5
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co
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<
G-29
-------
Table 7 (cont.)
Facility 7227 Universal Treatment System - Option 3
TOTAL CAPITAL COSTS
Wastewater Storage Costs: $2,053
Process Vessel Costs: $6,194
Activated Carbon Costs: $4,926
Pump/Strainers Costs: $1,404
Ultrafiltration Costs: $0
Containment Costs: $5,298
Disposal Costs: $319
Total Equipment Costs: $20,195
Land Purchase Costs: $721
Miscellaneous Equipment Costs: $4,039
Engineering/Admin ./Legal Costs: $2,019
j FACILITY CAPITAL COSTS: $26,9741
TOTAL O & M COSTS
Process Vessel Costs:
Activated Carbon Costs:
Pump/Strainers Costs:
Ultrafiltration Costs:
Containment Costs:
Disposal Costs:
Monitoring Costs:
$827
$1,432
$124
$0
$380
$6,201
$800
Annual O & M Costs:
Miscellaneous O & M Costs:
Insurance Costs:
$9,764
$809
$270
FACILITY O & M COSTS:
$10.843 j
G-30
-------
Table 7 (cont)
Facility 7227 Universal Treatment System - Option 3
Annual Flow (gal):
Large Batch Flow (gal):
Number of Quarters WW Generated:
Quarter 1 Flow (gal):
Quarter 2 Flow (gal):
Quarter 3 Flow (gal):
Quarter 4 Flow (gal):
Design Flow (gal):
1,903
476
4
476
476
476
476
571
Raw Wastewater Storage
Number of Tanks: 1
Volume of Tanks: 1,000
Type of Tanks: Carbon Steel
Effluent Wastewater Storage
Number of Tanks: 1
Volume of Tanks: 1,000
Type of Tanks: Carbon Steel
STORAGE TANK CAPITAL COSTS
Cost per tank:
Total Tank Capital Costs:
$1,026
$2,053
-------
Table 7 (cont.)
Facility 7227 Universal Treatmant System • Option 3
Required SuKde Pmdprtrton Tim* (hrs): 0
Required Hydrolysis Time (hra): 0
Required Chem. Ox Tim* (tirs): 0
B«ouir»d Emulsion Breaking Time (hn»): 24^
Total Treatment Time (hrs): 24
Total Treatment Tim* (days): 1
Process Vessel 1
Number of Process V«u»l*:
Vobrn* o< PTOCMI Vinili (a«l):
Numtw o( Annual Trutmrnt Batch**:
Proem Vuul 2
1
1000
Numtor of Prooa* V*«Ml>:
Vokim* o( PRXM* VMMto (gal):
AuxJUary Equipment
Numter o< Aghatcn:
•V*t Vacuum Pump:
Powv oi W*t Vacuum Pump (hp):
Steam (byt):
O%H2SOVyr):
Cau«ic(lHi50%N«OHVr):
Acid Storage ATM R*quirad(aq. ft):
Caustic Storage Ar«* Required (tq. ft.):
Chlorine Stooge Required (sq. ft):
Sodium SuKde Storage Required (sq.ft.):
3176
S40
680
0
0
21
21
0
0
PROCESS VESSEL CAPITAL COSTS
Cost per Process Vessel:
Total V*as*l Costi:
Cost for Wet Vacuum Pump:
Storage Area Costa:.
-- _-.--.--
Cauaic Storage Area:
Chlorine Storage Area:
5463
5463
310
0
Total Capital COetrL,
^PROCESS VESSEL O * U COSTS
Labor (man-tirfyr):
Labor Costa:
6194I
SO
344
Energy ReguiwmjnB jkwjitful
"proceasVesselAoitator. 17
Wet Vacuum Pump: «_
Total Energy Requirements: 23
Annual Energy Costs: 2
Steam Cose 6
CauafcCost: 43
Acid Cot 432
Chlorine Cost: 0
Sodium Suffide Cost: 0
AmwalOtUCo*H:[[
8271
G-32
-------
Table 7 (cent)
Facility 7227 Universal Treatment System - Option 3
Fted Tank Dwlgn
Number of Tanks:
TanK(s) Volume (gal):
Tank(s) Type:
AC System Design
EBRT (mln):
Design Flow (flal):
Quarterly Ftow (gal):
Daily Row Rate (gpd):
Flow Rate (gpm):
Required AC Vessel Vol. (gal):
Carbon Steel
1
1,000
30
571
6.34
0.01
AC System Type:
Number of Vessels In Series:
Backwash System:
Backwash Rale (gpm):
Backwash Pump Power (hp):
Backwash Volume (gal):
Carbon Usage (Ittyeer):
Carbon per Vessel (Ib/Vessel):
Adsorbers per yean
AC SYSTEM CAPITAL COSTS
Feed Tank Cost:
Total Feed Tank Costs:
Cost per AC Unit:
Total AC System Cost:
Backwash System Cost:
Total AC Syittm Capital Costs: [|
AC SYSTEM QAM COSTS
Labor (man-hours):
Quarter 1:
• Quarter 2:
Quarters:
Quarter 4:
Annual man-hours:
Annual Labor Costs:
Energy Requirements (kw-hr/yr)
Backwash Pump: _
Annual Energy Costs:
AC Vessel Replacement Cost:
Annual Carbon Costs:
Annual TOC Monitoring Costs:
NA
NA
NA
102
165
1
$1,026
$1,026
$1,300
$3.900
$0
$4.926 |
4
4
4
4
16
$275
0_
$0
$1,033
$1.033
$124
Total AC System O&M Costa:|_
$1.4321
G-33
-------
Table 7 (cont.)
Facility 7227 Universal Treatment System - Option 3
Large or Small System:
Number of Process Vessel Pumps:
Capacity of Process Vessel Pumps (gpm):
Power of Process Vessel Pumps (hp):
Capacity of AC Feed Pump:
Power of AC Feed Pump:
Waste Pump:
Power of Waste Pump (hp):
Small
No
NA
1
40
0.5
20
0.5
Number of In-Line Strainers:
PUMP/STRAINER CAPITAL COSTS
Cost per Process Vessel Pump:
Cost for AC Feed Pump:
Cost for Waste Pump:
Cost per In-Line Strainer:
Total Pump/Strainer Capital Costs:
PUMP/STRAINER O & M COSTS
_ Annual_Energy_ Re_qu jrements (jwlvfyfL _
Vessel"Pumps:
AC Pump:
Waste Pump:
Total Energy Required (kw-hr/yr):
Annual Energy Costs:
Strainer Cleaning Labor (hrs/yr):
Annual Labor Costs:
Annual Pump/Strainer O & M Costs:
$284
$275
$0
$845
$1,404
2
1,279
0
1,281
$106
$17
$124
G-34
-------
Table 7 (cont.)
Facility 7227 Universal Treatment System - Option 3
CONTAINMENT DEStGW
System Component Number of Tanks Size of Tanks Dia
Influent Storage Tanks
Effluent Storage Tanks
Process Vessels
AC Feed Tank(s)
AC System
Waste Disposal Tank
1
1
1
1
0
1
1.000
1,000
1,000
1,000
0
250
of Tanks Area Displaced Area Required
5.33
5.33
5.33
5.33
0
3.33
22.3
22.3
22.3
22.3
0.0
8.7
1
128.4
128.4
1284
128.4
0 0
87.0
Amount of Space Required (sf):
Containment Provided (gal):
Containment Required (gal):
CS Area (sf):
CS Perimeter (ft):
Containment Capital Costs
Concrete Floor (1991 Cost):
Concrete Dike (1991 Cost):
Floor Coating (1991 Cost):
Dike Coating (1991 Cost):
Total C/S Cost (1988 Cost):
Total Capital Costs (1988):
Floor Recoating:
Dike Recoating:
Total Recoating Cost:
Ammortized Recoating Cost:
| Total O & M Cost (1988):
721
9,315
1,250
721
1071
2,883
1,560
649
193
5,285
$4,826
$5,298
685
236
$841
$338
AC Containment Costs
Capital Costs (1988):
O&M Costs (1988):
$472
$42
§380
G-35
-------
Table 7 (cont.)
Facility 7227 Universal Treatment System - Option 3
?X WASTE DISPOSAL , / „'
Reject Wastewater
Quarter 1 Wastewater:
Quarter 2 Wastewater:
Quarter 3 Wastewater:
Quarter 4 Wastewater:
Maximum quarterly wastewater:
Pr^igitatjon_SpIids_Rernova[
Solid Disposal (Ib/yr):
DISPOSAL CAPITAL COSTS
Number of Wastewater Storage Tanks:
Wastewater Storage Tank Size:
Wastewater Storage Tank Cost:
0.95
0.95
0.95
0.95
0.95
0.00
1
250
$319
Total Disposal Capital Costs: [
$319
DISPOSAL O & M COSTS
Quarter 1 Wastewater Disposal Cost:
Quarter 2 Wastewater Disposal Cost:
Quarter 3 Wastewater Disposal Cost:
Quarter 4 Wastewater Disposal Cost:
Solid Disposal Cost:
Total Disposal O & M Costs:
$1,550
$1,550
$1,550
$1,550
$0
$6,201
G-36
-------
Table 7 (cont.)
Facility 7227 Universal Treatment System - Option 3
$200
$800
$1 .00
721
$721
Monitoring Costs per Quarter:
Annual Monitoring Costs:
Land Cost ($/sq. ft.):
Land Requirement (sq. ft.):
Total Land Purchase Cost:
-------
Table 8:
Option 3 and 3S Compliance Costs
Option 3 Option 3S
Capital Options Capital Option 3S
Facility ID Cost O&M Cost Cost O&M Cost
340 $84,437 $26,653 $61,216 $19,432
2669 $1,789,487 $427,023 $1,760,369 $422,970
7227 $26,974 $10,843 $0 $0
G-38
-------
Appendix H
Summary of Treatment Technologies for PAIs and PAI Groups (1)
PAI#
014
015
016
017
027
030
031
034
046
047
238
115
136
242
026
054
070
165
036
227
081
092
160
067
116
020
080
098
110
129
193
202
205
204
053
078
069
123
177
262
PAI Name
2,3,6-T, S&E or Fenac
2,4,5-T and 2,4,5-T, S&E
2,4-D (2,4-D, S&E)
2,4-DB, S&E
MCPA, S&E
Dichlorprop, S&E
MCPP, S&E or Mecoprop
Chlorprop, S&E
CPA, S&E
MCPB, S&E
Silvex
Diphenamide
Fluoroacetamide
Sodium Fluoroacetate
Propachlor
Alachlor
Butachlor
Metolachlor
HAE
Propionic Acid
Chloropicrin
Dalapon
Methyl Bromide
Biphenyl
Diphenylamine
Dichloran or DCNA
Chloroneb
Dicamba
DCPA
Chlorobenzilate
o-Dichlorobenzene
p-Dichlorobenzene
PCNB
Pendimethalin
Acifluorfen
Chloramben
Bromoxynil
EndothaU (EndothaU S&E)
MGK264
Toxaphene
Structural Group
2,4-D
2,4-D
2,4-D
2,4-D
2,4-D
2,4-D
2,4-D
2,4-D
2,4-D
2,4-D
2,4-D
Acetamide
Acetamide
Acetamide
Acetanilide
Acetanilide
Acetanilide
Acetanilide
Alcohol
Alkyl Acid
Alkyl Halide
Alkyl Halide
Alkyl Halide
Aryl
Aryl Amine
Aryl Halide
Aryl Halide
Aryl Halide
Aryl Halide
Aryl Halide
Aryl Halide
Aryl Halide
Aryl Halide
Benzeneamine
Benzoic Acid
Benzoic Acid
Benzonitrile
Bicyclic
Bicyclic
Bicyclic
Technology
Basis
AC
AC (2)
CO
AC
AC
AC
AC (2)
AC
AC
AC
AC (2)
AC (2)
AC
AC
AC (2)
AC
AC (2)
AC
AC
AC
CO
AC
AC
AC
AC
AC
CO
AC (2)
AC
AC
AC
AC
AC (2)
AC (2)
AC
AC
AC (2)
AC
AC
AC (2)
Data
Transfer?
("X"=YES) (3)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Transfer
Basis (4)
2,4-DB
2,4-DB
2,4-DB
2,4-DB
2,4-DB
2,4-DB
90th
90th
90th
90th
90th
90th
90th
DCPA
DCPA
90th
90th
90th
90th
H-l
-------
Appendix H
Summary of Treatment Technologies for PAIs and PAI Groups (1)
PAI it PAI Name
013 Landrin-2
038 Landrin-1
040 Methiocarb or Mesurol
042 Polyphase
048 Aminocarb
055 Aldicarb
061 Bendiocarb
062 Benomyl
075 Carbaryl
076 Cubofuran
077 Carbosulfkn
095 Desmedipham
100 Thiophanate Ethyl
145 Propham
146 Karabutilate
153 Mefluidide
156 Methomyl
166 Mexacaibate
170 Napropamide
195 Oxamyl
201 Propoxur
209 Phenmedipham
228 Previcur N
260 Thiophanate Methyl
009 Hexachlorophene
010 Tetrachlorophene
041 Propanil
043 Coumafuryl or Fumarin
265 Warfarin
091 Cycloheximide
001 Dicofol
101 Perthane
158 Methoxychlor
Structural Group
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Caibamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Carbamate
Chlorobenzamide
Chlorophene
Chlorophene
Chlorophene
Chloropropionanilide
Chloropropionanilide
Coumarin
Coumarin
Cyclic Ketone
DDT
DDT
DDT
Technology
Basis <
AC
AC
HD
AC
HD
HD
HD
HD
HD
HD
AC
HD
HD
HD
HD
AC
HD
HD
AC
HD
HD
HD
HD
HD
HD
AC
AC
AC (2)
AC
AC
AC
AC
HD
Transfer?
"X"=YES) (3)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Transfer
Basis (4)
Graph
Graph
90th
Aminocarb
Aminocarb
Graph
Aminocarb
Aminocarb
Graph
Extrapolated
Graph
Aminocarb
Aminocarb
90th
90th
90th
90th
90th
H-2
-------
Appendix H
Summary of Treatment Technologies for PAIs and PAI Groups (1)
PAT#
023
087
102
134
151
152
167
172
218
219
220
241
243
261
267
268
003
005
097
064
117
157
216
093
028
032
035
049
175
210
240
259
002
059
114
118
063
147
PAI Name
Sulfidlate
Mancozeb
EXD
Ferbam
Mancb
Manam
Metiram
Nabam
Busan 85 or Arylane
Busan40
KN Methyl
Carbam-S or Sodam
Vapam or Metham Sodium
Thiram
Zineb
Ziram
EDB
1 ,3-Dichloropropene
DBCP
Benzyl Benzoate
MGK 326
Methoprene
Piperonyl Butoxide
Dienochlor
Octhilinone
Thiabcndazole
Busan 72 or TCMTB
Etridiazole
Norflurazon
Nemazine
Sodium Bentazon
Dazomct
Maleic Hydrazide
Amitraz
Diphacinone
Nabonate
BHC
Lindanc
i
Structural Group
Dithiocarbamatc
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate .
EDB
EDB
EDB
Ester
Ester
Ester
Ester
HCp
Heterocyclic
Heterocyclic
Heterocyclic
Heterocyclic
Heterocyclic
Heterocyclic
Heterocyclic
Heterocyclic
Hydrazide
Iminamide
Indandione
Isocyanate
Lindanc
Lindane
Data
Technology Transfer? Transfer
Basis ("X"=YES)(3) Basis (4)
AC
AC
AC
AC
AC (2)
AC
AC
CO
CO
CO
CO
CO
CO
AC
AC
AC
AC
HD
AC
AC
AC
AC
AC
AC
AC
AC
HD
AC
AC (2)
AC
CO
CO
AC
AC
AC
CO
HD
AC
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Vapam
Vapam
Vapam
Vapam
90th
Vapam
Vapam
Vapam
Vapam
90th
Extrapolated
90th
90th
90th
90th
90th
90th
90th
Graph
90th
90th
90th
H-3
-------
Appendix H
Summary of Treatment Technologies for PAIs and PAI Groups (1)
PAI#
021
029
037
071
096
164
196
221
225
235
007
056
105
120
121
149
159
162
217
066
006
072
161
088
089
190
191
192
266
044
112
206
211
258
019
PAI Name
Biu«n90
Pindonc
Chlorophacinone
Giv-gard
Amobtm
Oxyfluorfcn
MetasolJ26
Propargite
Mcxidc or Rotenone
Dowicil75
HyamincSSOO
Benzethonium Chloride
Metasol DGH
Dodine
Malachite Green
Methylbenzethonium Chloride
Hyamine2389
PBED or WSCP (Busan 77)
Thenarsazine Oxide
Cacodylic Acid
Monosodium Methyl Arsenals
Bioquin (Copper)
Copper EDTA
Organo-Copper Pesticides
Organo-Mercury Pesticides
Orcano-Tin Pesticides
Zinc MET
DNOC
Dinoseb
PCP or Penta
Phenylphenol
Tetrachlorophcnol
Dinocap
Structural Group
Miscellaneous
Miscellaneous
Miscellaneous
Miscellaneous
Miscellaneous
Miscellaneous
Miscellaneous
Miscellaneous
Miscellaneous
Miscellaneous
Miscellaneous
NR4
NR4
NR4
NR4
NR4
NR4
NR4
NR4
NR4
Nitrobenzoate
Organoarsenic
Organoaisenic
Organoarsenic
Organoarsenic
Organocadmium
Organocopper
Organocopper
Organocopper
Organomercury
Organotin
Organozinc
Phenol
Phenol
Phenol
Phenol
Phenol
Phenylcrotonate
Technology Transfer? Transfer
Basis ("X"=YES) (3) Basis (4)
AC
AC
AC
AC
AC
AC
AC (2)
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
AC
PT
PT
PT
PT
PT
PT
PT
AC
AC (2)
AC
AC
AC
AC
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
90th
90th
90th
90th
90th
90th
90th
90th
90th
90th
90th
90th
90th
90th
90th
90th
90th
90th
Organo-Tin
Organo-Tin
Organo-Tin
Organo-Tin
Phenylphenol
Phenylphenol
90th
H-4
-------
Appendix H
Summary of Treatment Technologies for PAIs and PAI Groups (1)
PAI # PAI Name
012 Dichlorvos
022 Mcvinphos
024 Chlorfcnvinphos
084 Stirofos
108 Dicrotophos
109 Crotoxyphos
173 Naled
214 Phosphamidon
111 Trichlorofon
128 Fenamiphos
138 Glyphosate (Glyphosate S&E)
139 Glyphosine
052 Acephate or Oithene
143 Isofcnphos
154 Methamidophos
106 Dimethoate
113 Dioxathion
126 Ethion
127 Ethoprop
150 Malathion
155 Methidathion
183 Disulfoton
185 Phosmet
186 Azinphos Methyl (Guthion)
197 Bolstar
199 Santox (EPN)
200 Fonofos
212 Phorate
213 Phosalonc
251 Bensulide or Betesan
255 Terbufos or Counter
Structural Group
Phosphate
Phosphate
Phosphate
Phosphate
Phosphate
Phosphate
Phosphate
Phosphate
Phosphonate
Phosphoroamidate
Phosphoroamidate
Phosphoroamidate
Phosphoroamidothioate
Phosphoroamidothioate
Phosphoroamidothioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Phosphorodithioate
Technology
Basis
HD
HD
AC
HD
AC
AC
HD
HD
AC
AC
CO
AC
AC
AC
AC
HD
HD
HD
AC
HD
AC
HD
HD
HD
AC
HD
HD
HD
HD
AC
AC
Data
Transfer?
("X"=YES) (3)
X
X
X
X
X
X
X
X
X
X
X
X
X
Transfer
Basis (4)
Stirofos
90th
Stirofos
90th
90th
90th
90th
Isophenophos
Graph
Graph
Graph
Santox
Graph
H-5
-------
Appendix H
Summary of Treatment Technologies for PAIs and PAI Groups (1)
PAT#
004
008
018
025
033
058
060
142
223
224
226
239
256
257
PAI Name
VancideTH
Triadimefon
Cyantzine or Bladex
BclclcneSlO
Atrazine
Prometon or Caparol
Simazinc
Terbuthylazine
Technology Transfer? Transfer
Smictural Group Basb ("X"=YES) (3) Basis (4)
s-Triazine
s-Triazinc
i-Triazinc
s-Triazine
s-Triazine
s-Triazine
s-Triazine
s-Triazine
s-Triazine
s-Triazine
s-Triazine
s-Triazine
s-Triazine
AC X
AC X
AC X
AC
AC X
AC (2)
HD X
AC
CO
AC (2)
AC (2)
AC
AC
AC (2)
Graph
Graph
Graph
Graph
Extrapolated
Footnotes:
(1) This table can also be found in "Final Pesticides Formulators, Packagers, And Repackages Treatability
Database Report," Radian Corporation, 1994, Table 2-1.
(2) Treatability data indicate this PAI or PAI group is amenable to activated carbon adsorption.
However, Freundlich isotherm data are not available. Isotherm data are transferred for costing purposes.
(3) "X" is indicated only where data are transferred to the PAI or PAI group.
(4) A PAI or PAI group in the "Transfer Basb" column indicates a data transfer from the PAI or PAI group listed.
"Extrapolated" in the "Transfer Basis" column indicates that half-life data are extrapolated to pH 12, 60 degrees C.
"90th" in the "Transfer Basis" column indicates that the constants for the 90th percentile lowest Freundlich isotherm
are transferred to the PAI or PAI group.
"Graph" in the "Transfer Basis" column indicates that the constants for the minimum Freundlich isotherm for
the structural group are transferred to the PAI or PAI group.
AC Activated carbon adsorption
CO Chemical oxidation
HD Hydrolysis
PT Precipitation
S&E Salts and esters
H-8
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