&EPA
            United States
            Environmental Protection
            Agency
           Office Of Water
           (4303)
EPA821-R-94-002
March 1994
Development Document For Best
Available Technology, Pretreatment
Technology, And New Source
Performance Technology For The
Pesticide Formulaing, Packaging,
And Repackaging Industry

Proposed

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                       PROPOSED

          TECHNICAL  DEVELOPMENT  DOCUMENT

                       FOR THE

PESTICIDE  FORMULATING,   PACKAGING  AND  REPACKAGING

         EFFLUENT  LIMITATIONS   GUIDELINES,

            PRETREATMENT  STANDARDS,  AND

         NEW  SOURCE  PERFORMANCE  STANDARDS
                   Carol M. Browner
                     Administrator

                   Robert Perciasepe
            Administrator, Office of Water

                  Thomas P. O'Farrell
      Director,  Engineering and Analysis Division

                    Marvin B.  Rubin
                 Chief, Energy Branch

                   Janet K. Goodwin
                    Project Officer
                Written and Prepared by

                    Shari H. Zuskin
               Assistant Project Officer
           Engineering and Analysis Division
           Office of Science and Technology
         U.S. Environmental Protection Agency
                Washington,  D.C.   20460

                    March 31, 1994

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                            Table  of  Contents
                                                                       Page




SECTION  1  - INTRODUCTION




1 . 0   LEGAL  AUTHORITY   .  .  ....................    1-1




1 . 1   BACKGROUND     .......... .  .  ...........      1-1




      1.1.1   Clean  Water Act    ...........  .....      1-1




      1.1.2   Section  304 (m)  Requirements  and  Litigation     .   .      1-6




      1.1.3   Pollution  Prevention  Act     ...........      1-7




      1.1.4   Prior  Regulation  and  Litigation  for  the  Pesticide




              Chemicals  Category      ..............      1-8




1.2   SCOPE  OF  TODAY'S PROPOSED RULE     ............     1-12









SECTION  2 - SUMMARY




2 . 0   OVERVIEW OP  THE INDUSTRY     ...............      2-1




2 . 1   SUMMARY OF  THE  PROPOSED  REGULATIONS    ..........      2-7




      2.1.1   Applicability  of  the  Proposed  Regulations    .  .   .      2-7




      2.1.2   Subcategory  C:   PFPR  and PFPR/Manufacturers    .   .      2-9




      2.1.3   Subcategory  E :    Refilling  Establishments     .  .   .     2-12








SECTION  3 - INDUSTRY  DESCRIPTION




3 . 0   INTRODUCTION     .....................      3-1




3 . 1   DATA COLLECTION  METHODS    ................      3-1




      3.1.1   Existing  Databases:   Pesticide  Registration  Process    3-3




      3.1.2   Selection of PAIs  for Study    ..........      3-4




      3.1.3   The  Pesticide  Formulating,   Packaging and Repackaging




              Facility Survey for 1988     ...........     3-21

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                      Table  of  Contents   (continued)


                                                                      Page


        3.1.3.1   Development  of  the  "Pesticide  Formulating,


                   Packaging  and  Repackaging Survey for 1988".  .     3-21


        3.1.3.2   Distribution  of  the  "Pesticide  Formulating,


                   Packaging  and  Repackaging Survey for  1988".  .    3-23


        3.1.3.3    Calculation  of  Stratified  National  Estimates  .   3-27


        3.1.3.4    Data  Collected  by  Pesticide   Formulating,


                   Packaging  and  Repackaging  Facility  Survey        3-32


      3.1.4   EPA's Site  Visiting  &  Sampling  of  Selected  Pesticide


              Formulators,   Packagers  and Repackagers   	     3-33


        3.1.4.1   Site  Visits      	     3-34


        3.1.4.2   Wastewater  Sampling     	     3-38


      3.1.5   Industry-Supplied  Data     	     3-42


      3.1.6   EPA  Bench-Scale  Treatability  Studies     	     3-43

                                                                   o
      3.1.7   Data Transfers  from  Pesticide Manufacturing


              Subcategories  and Other  Sources     	     3-44


3.2   OVERVIEW  OF  THE  INDUSTRY      	     3-50


      3.2.1   National  Estimates  Characterizing  the PFPR  Industry   3-51


        3.2.1.1   Facility Type      	     3-52


        3.2.1.2   Ownership  Type  and  Geographic  Location    . .     3-53


        3.2.1.3   Market Type      	     3-54


        3.2.1.4   Facilities  That   Discontinued   PFPR  Production  .   3-55


        3.2.1.5   Production    	     3-56


        3.2.1.6   Product  Types      	     3-58


        3.2.1.7   Pesticide  Active  Ingredient  Usage     ....     3-60


        3.2.1.8   Production  Lines    	     3-63

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                    Table  of  Contents   (continued)









                                                                       Page



         3.2.1.9    Line  Operating  Schedules    	    3-65




3 . 3   PESTICIDE  FORMULATING,   PACKAGING  AND  REPACKAGING PROCESSES   3-65









SECTION  4  -  INDUSTRY  SUBCATEGORIZATION




4 . 0   INTRODUCTION     	     4_!




4 . 1   BACKGROUND     	     4_2




4 . 2   CURRENT  SUBCATEGORIZATION BASIS    	     4-3




      4.2.1   Product Type      	     4_g




      4.2.2   Raw Materials     	     4-6




      4.2.3   Type  of  Operations  Performed:    Formulating,  Packaging,




              and Repackaging  Operations      	     4-8




      4.2.4   Nature  of Waste  Generated     	    4-11




      4.2.5   Dominant  Product     	    4-12




      4.2.6   Plant  Size     	    4_13




      4.2.7   Plant  Age	    4_14




      4.2.8   Plant  Location	   4-14




      4.2.9   Non-Water  Quality Characteristics    	    4-16




      4.2.10  Treatment  Costs  and  Energy  Requirements    ....    4-18




4 . 3   PROPOSED   SUBCATEGORIES     	    4-20









SECTION  5  -  WATER  USE  AND  WASTEWATER CHARACTERISTICS




5 . 0   INTRODUCTION    .	      5-1




5 . 1   WATER  USE AND  SOURCES  OF  WASTEWATER    	      5-2




      5.1.1   Wastewater  Sources      	      5-2
                                    111

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                    Table  of  Contents   (continued)
                                                                       Page




5.1.2National Estimates  of Water  Use      	      5-5




      5.1.3   Water  Use  -  Production  Normalized  Volumes    .  .  .      5-8




      5.1.4   Water  Use  -  Cleaning  Sequences  and Formulation




              Types   	     5-19




5.2   WASTEWATER VOLUME  BY  DISCHARGE MODE    	     5-19




      5.2.1   Definitions     	     5-19




      5.2.2   Discharge  Status of  PFPR  Industry    	     5-20




5 . 3   WASTEWATER  DESTINATIONS    	     5-23




5 . 4   WASTEWATER DATA COLLECTION  RESULTS	     5-31




      5.4.1   Industry  Supplied  Self-Monitoring Data      ....     5-31




      5.4.2   EPA  PFPR Sampling  Program    	     5-34









SECTION  6  -  POLLUTION  PARAMETERS  SELECTED FOR  REGULATION




6. 0   INTRODUCTION	      6-1




6.1   CONVENTIONAL  POLLUTANTS    	      6-2




6 . 2   PRIORITY  POLLUTANTS    	      6-5




6 . 3   PESTICIDE  ACTIVE INGREDIENTS     	      6-9









SECTION  7 -  TECHNOLOGY  SELECTION  AND METHODS  TO ACHIEVE  THE EFFLUENT




LIMITATIONS




7 . 0   INTRODUCTION     	      7-1




7 . 1   WASTEWATER TREATMENT  IN THE  PFPR  INDUSTRY	  .      7-3




      7.1.1   Carbon  Adsorption    	      7-4




      7.1.2   Hydrolysis      	      7-7







                                     iv

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                     Table  of  Contents  (continued)
                                                                       Page



      7.1.3   Chemical  Oxidation/Ultraviolet  Decomposition   .   .      7-9




      7.1.4   Membrane  Filtration    	     7-11




      7.1.5   Emulsion  Breaking    	     7-15




      7.1.6   Chemical  Precipitation/Separation     	     7-23




      7.1.7   Pre-  or  Post-Treatment     	     7-25




fc     7.1.8   Disposal   o£  Solid  Residue  from Treatment     .  .  .     7-29




 7 . 2  WASTEWATER  SAMPLING    	     7-31




      7.2.0   Introduction     .....  	     7-31




      7.2.1   Treatment  System Performance     	     7-32




      7.2.2   Reuse of  Treated Wastewater    	     7-49




 7 . 3  TREATABILITY   STUDIES     	     7-64




 7 . 4  POLLUTION  PREVENTION,  RECYCLE/REUSE  PRACTICES    	     7-81




      7.4.1   Pollution Prevention  Data  Gathering Efforts    .  .     7-84




      7.4.2   Pollution Prevention  and  Recycle/Reuse Practices




               Found at  PFPR Facilities     	     7-85




      7.4.3   Description  of  Process  Wastewater  Sources    .  .  .     7-87




      7.4.4   Applying   Pollution  Prevention  Practices  to  Specific




               Wastewater Sources      	     7-90




         7.4.4.1     Shipping  Container/Drum  Cleaning    	     7-90




         7.4.4.2     Bulk  Tank  Rinsate     	     7-93




         7.4.4.3    Equipment  Interior Cleaning     	     7-95




         7.4.4.4    Aerosol  Container   (DOT)   Leak  Testing    .  .  .   7-100




         7.4.4.5    Floor/Wall/Equipment  Exterior  Cleaning    .  .   7-102




         7.4.4.6    Leaks and  Spills   	   7-105

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        7.4.4.7   Air  Pollution  or Odor  Control  Scrubbers     .    7-107




        7.4.4.8   Safety Equipment  Cleaning     	    7-108




        7.4.4.9   Laboratory Equipment  Cleaning     	    7-109




        7.4.4.10  Precipitation  Runoff     	    7-110




                        Table of  Con-tents   (continued)









                                                                       Page




        7.4.4.11  Secondary Containment  in the  Bulk  Storage




                   Area    	    7-110




        7.4.4.12  Containment  Pad  in  the Loading/Unloading




                   Area    	    7-112









SECTION  8 -  ENGINEERING  COSTS




8.0   INTRODUCTION	8-1




8.1   REGULATORY OPTIONS	8-2




8.2   ENGINEERING COSTING METHODOLOGY	8-4




      8.2.1   Costing  Methodology for  Sanitizer  Facilities	8-7




      8.2.2   Costing  Methodology  for  Refilling Establishments.  .   .8-8




8.3   DEVELOPMENT OF PFPR COST MODEL  AND  INPUT  DATASETS	8-9




      8.3.1   Development  of the  PFPR Cost Model from  the




              Manufacturers Cost Model	8-10




      8.3.2   PFPR Cost Model	8-12




      8.3.3   Cost Model  Input Datasets	8-21




8.4   DESIGN  AND COST ALGORITHMS	8-41




      8.4.1   UTS Module  Design  and Cost  Algorithm	8-41




      8.4.2   Storage and Reuse  Cost Module	8-78




      8.4.3   Off-Site  Disposal Cost Module	8-81






                                     vi

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                    Table  of  Contents   (continued)
                                                                       Page
 SECTION  9  -  BEST  PRACTICABLE CONTROL  TECHNOLOGY  (BPT)




 9.0   INTRODUCTION     	




 9 . 1   BPT  APPLICABILITY     	




      9.1.1   Pesticide  Chemicals  Formulating,  Packaging  and




              Repackaging   (Subcategory  C)     	




      9.1.2   Repackaging  of  Agricultural   Pesticides  Performed  by




              Refilling Establishments  (Subcategory  E)




 9 . 2   SUMMARY OF  PROPOSED  BPT LIMITATIONS
  9-1




  9-1









  9-1









  9-5




  9-9
 10-3
SECTION  10  -  BEST  CONVENTIONAL POLLUTANT  CONTROL  TECHNOLOGY




10.0  INTRODUCTION     ....................




10.1  SUMMARY OF  PROPOSED BCT  LIMITATIONS    .........




      10.1.1  Pesticide  Chemicals  Formulating,  Packaging  and




              Repackaging  (Subcategory C)     .........       10-3




      10.1.2  Repackaging  of Agricultural  Pesticides  Performed  by




              Refilling Establishments  (Subcategory  E)    ...       10-3
SECTION  11  -  BEST AVAILABLE  TECHNOLOGY ECONOMICALLY ACHIEVABLE




11.0  INTRODUCTION     	




11.1  SUMMARY  OF  PROPOSED  BAT  LIMITATIONS




11.1.1   Pesticide  Chemicals  Formulating,  Packaging  and




              Repackaging  (Subcategory  C)    	
 11-1




 11-2








11-2

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                    Table  of  Contents   (continued)
11.1.2  Repackaging  of Agricultural  Pesticides  Performed  by




              Refilling  Establishments   (Subcategory  E)    .
                                                                       Page
11-2
SECTION  12 -  PRETREATMENT  STANDARDS  FOR EXISTING  SOURCES  (PSES)




12 . 0  INTRODUCTION     	       12-1




 .2 . 1  PESTICIDE  CHEMICALS  FORMULATING,  PACKAGING  AND  REPACKAGING




      (SUBCATEGORX-  C)     	       12-5




      12.1.1  Introduction	       12-5




      12.1.2  Pass  Through  Discussion    	       12-6




      12.1.3  Universal  Treatment  System  (UTS)    	       12-8




      12.1.4  Options  Selection  for  Subcategory C:




              PFPR   (Including  PFPR/Manufacturers)     	      12-11




         12.1.4.1   Regulatory  Options  Considered     	      12-11




         12.1.4.2   Selected  Option  for  the  Expanded




                    Coverage:  3/S.l      	      12-15




         12.1.4.3   Discussion  of  Options  Not  Selected    ...      12-20




12.2     OPTIONS SELECTION  FOR SUBCATEGORY  E:




         REFILLING  ESTABLISHMENTS     	      12-26




      12.2.1  Repackaging of  Agricultural  Pesticides  Performed  by




              Refilling  Establishments  (Subcategory  E)    ...      12-26









SECTION  13 -  NEW  SOURCE PERFORMANCE  STANDARDS   (NSPS)  AND




PRETREATMENT  STANDARDS  FOR  NEW   SOURCES   (PSNS)




13.0  INTRODUCTION     	       13-1







                                    viii

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                    Table  of  Contents   (continued)










                                                                       Page




13.1 SUMMARY  OF PROPOSED  NSPS  AND  PSNS  STANDARDS    	       13-2




      13.1.1   Pesticide Chemicals  Formulating,  Packaging  and




               Repackaging   (Subcategory  C)    	       13-2




      13.1.2   Repackaging   of  Agricultural  Pesticides  Performed by




               Refilling Establishments   (Subcategory E)    ...        13-4









SECTION  14  -  REGULATORY   IMPLEMENTATION




14.0 INTRODUCTION      	       14-1




14.1 IMPLEMENTATION  OF ZERO  DISCHARGE     	       14-1




14.2 UPSET AND BYPASS  PROVISIONS    	       14-2




14.3 VARIANCES  AND  MODIFICATIONS    	       14-4




14.4 RELATIONSHIP  TO  NPDES  PERMITS AND  MONITORING  REQUIREMENTS      14-6




14.5 BEST  MANAGEMENT  PRACTICES    	       14-8




14.6 ANALYTICAL  METHODS     	       14_g









SECTION  15 -  WATER  QUALITY  ANALYSIS




15.1 WATER QUALITY ANALYSES	\       15-1









SECTION  16 -  NON-WATER  QUALITY ENVIRONMENTAL  IMPACTS




16.1 NON-WATER  QUALITY ENVIRONMENTAL  IMPACTS    	       16-1




      16.1.1  Air  Pollution   	       16_!




      16.1.2  Solid Waste    	       16-2




      16.1.3  Energy  Requirements    	       16-3
                                     IX

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                    Table  of  Contents   (continued)
                                                                        Page




Appendix A  —  Glossary of Terms	      A-l




Appendix  B -  Definitions  of Pesticide  Product  Formulation




              Types	      B-l




Appendix C  -  Priority Pollutant  List	       C-l




Appendix D  -  Proposed Regulation	       D-l




Appendix E  -  Transfer of Hydrolysis Data	       E-l




Appendix  P -  Comparison  of Median Concentrations  Vs.   Sampled




              Concentrations  	      F-l




Appendix G  -  Sample PFPR Facility Costs	       G-l




Appendix  H -  Summary of  Treatment Technologies  for PAIs  and




              PAI  groups	      H-l

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                              List  of  Tables
3-1  List  of Pesticide  Active Ingredients  (272  PAIs)  ....




4-1  Sanitizer  Active  Ingxedients	




5-1  Water Use  by Wastewater Source	




5-2  National  Estimated  of  Number of  Water-Using  Facilities




      by  Discharge Mode and  Subcategory  	




5-3  Total  Process  Wastewater Volume  by  Destination and



      Subcategory  	




5-4  Total  Process  Wastewater Volume  for  Zero Dischargers  by




      Destination  and Subcategory  	




5-5  Total  Process  Wastewater Volume  by  Destination and



      Subgroup	




5-6  PAIs with  Self-Monitoring  Data	




5-7  Summary Statistics  on the Analytical  Database




6-1  Priority  Pollutants  for  Which  No  Self-Monitoring  Data



      Was Submitted  	




6-2  Priority  Pollutants  Measured Above  Detection  Limit in



      Self-Monitoring Database	




6-3  Priority  Pollutants  in Wastewater  at Sampled  PFPR



      Facilities	




6-4  PAIs Found  Above  Detection  Limit in  Self-Monitoring



      Database	




6-5   PAIs Found  Above  Detection  Limit in  Analytical



      Sampling Database  	
 Page




 3-8




  4-5




  5-5









 5-21









 5-25









 5-27









 5-29




 5-33




 5-39









 6-6









 6-7









 6-8









6-10









6-10
                                     XI

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                      List  of  Tables   (continued)








                                                                        Page




7-1   PAI  Percent: Removals  Achieved  by  the  Ultraf iltration/AC




      Treatment System First Episode	       7-33




7-2   PAI  Percent Removals  Achieved  by  the  Ultraf iltration/AC




      Treatment System Second  Episode	      7-33




7-3   PAI  Percent Removals Achieved  During  Treatment  at




      Second Facility.  .  . ,	      7-35




7—4   PAX  Percent Removals Achieved  During  Treatment  at




      Third Facility	      7-38




7-5   PAI  Percent Removals Achieved  for  the  Non-Process




      Precipitation Treatment  System 	      7-39




7-6   PAI  Percent Removals  Achieved  for  the  Process  Wastewater




      Treatment System	      7-41




7-7   PAI Percent  Removals  Achieved for the  Fifth  System .   .  .       7-44




7-8   PAI  Percent Removals  Achieved  by the  Clarification




      System and  the  Biological  Oxidation System at  the




      Final Facility  Sampled	      7-47




7-9   Achievable  Effluent  Concentrations  Used  for  Estimating




      Compliance Costs for  PAIs  from PFPR Sampling	       7-52




7-10  Comparison  of  the  Estimated LTA  vs.   Achievable  Effluent




      Data from the  Sampling   of  Treat  and Reuse  Systems.  .   .  .       7-54




7-11  Results  for Membrane  (UF/RO)  Separation  Treatability




      Study	      7-69




12-1  PSES Costs  and Pollutant Removals for  the  272  PAIs .  .  .     12-13




12-2  Santizer  Active Ingredients	     12-18

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                      List,  of  Tables  (continued)









                                                                        Page



£-1   pKa  Values  of  Hydrolysis  Products  for  Select PFP  PAIs




      and PAI Groups	      E-5




F-l   Comparison of  Calculated vs.  Sampled  Concentrations.  .   .        F-3




G-l   Facility Wastewater Stream Volumes	       G-5




G-2   Facility 340 Universal  Treatment System  - Option  3  ...       G-6




G-3   Facility 340 Storage and Reuse	     G-15




G-4   Facility 340 Universal  Treatment System -  Option 3/S  .   .      G-18




G-5   Facility 2669  Universal  Treatment  System -  Option 3.  .   .      G-19




G-6   Facility 2669  Universal  Treatment  System -  Option  3/S.  .      G-28




G-7   Facility 7227  Universal  Treatment  System -  Option 3.  .   .      G-29




G-8   Option 3 and 3/S  Compliance  Costs	     G-38




H-l   Summary of  Treatment Technologies  for PAIs  and PAI  Groups      H-l
                                    xiii

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                             List  of  Figures
3-1   Typical  Liquid Formulation Process  	




3-2   Typical  Dry Formulation Processes	




5-1   Distribution  of  Facilities,  by  Ranges of  Production-




      Normalized.  Volumes and  Line  Specific  Wastewater  Source




      = Drum/Shipping Container Rinsate	




5-2   Distribution  of  Facilities,  by  Ranges of  Production-




      Normalized  Volumes and  Line  Specific  Wastewater  Source




      =3 Equipment Interior  Cleaning	




5-3   Distribution  of  Facilities,  by  Ranges of  Production-




      Normalized  Volumes and  Line  Specific  Wastewater  Source




      s Scrubber Water 	




5-4   Distribution  of  Facilities,  by  Ranges of  Production-




      Normalized  Volumes and  Line  Specific  Wastewater  Source




      = Spills and  Leaks  Cleanup  	




5-5   Distribution  of  Facilities,  by  Ranges of  Production-




      Normalized  Volumes and  Line  Specific  Wastewater  Source




      = Equipment Exterior/Floor Wash	




5-6   Distribution  of  Facilities,  by  Ranges of  Production-




      Normalized  Volumes and  Line  Specific  Wastewater  Source




      — Lab Water	




5-7   Distribution  of  Facilities,  by  Ranges of  Production-




      Normalized  Volumes and  Line  Specific  Wastewater  Source




      — Precipitation Runoff 	
Page




3-69




3-69
5-10
5-11
5-12
5-13
5-14
5-15
5-16
                                    xiv

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                      List:  of  Figures  (continued)









                                                                        Page



5-8   Distribution  of  Facilities,  by  Ranges  of  Production-




      Normalized  Volumes  and  Line  Specific  Wastewater  Source




      = Safety  Equipment  Rinsate 	      5-17




5-9   Distribution  of  Facilities,  by  Ranges  of  Production-




      Normalized  Volumes  and  Line  Specific  Wastewater  Source



      = DOT  Testing	    5-18




7-1   Oil  and  Grease Effluent  Concentrations at  Reuse  Facilities    7-58




7-2   COD  Effluent  Concentrations  at  Reuse Facilities  	     7-59




7-3   TOG  Effluent  Concentrations  at  Reuse Facilities  	     7-60




7-4   Acetone  Effluent  Concentrations  at Reuse  Facilities  .   .  .     7-61




8-1   Small UTS System  Design	    8-47




8-2   Large UTS System  Design	    8-48




E-l   Plot of  In k2  vs.  1/T  for  1,3-Dichloropropene	     E-13




E-2   Plot of  In  k2 vs.  1/T  for Atrazine at pH  14	     E-14




E-3   Plot of  In  A vs.  pH  for Atrazine	    E-15




E-4   Plot of  In  k2 vs.  1/T for EDB at pH 7	    E-17




E-5   Plot of  In  A vs.  pH  for EDB	    E-18




E-6   Plot of  In  k2 vs.  1/T  for Mexacarbate at  pH  7	     E-l9




E-7   Plot of  In  A vs.  pH  for Mexacarbate	     E-20
                                     xv

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                             SECTION  1




                           INTRODUCTION
 1.0
LEGAL  AUTHORITY
           This regulation is  being proposed under the authorities



 of  Sections  301,  304, 306, 307, and 501 of  the  Clean  Water  Act



_ (the  Federal Water Pollxrtion  Control Act Amendments of 1972,  33



 U.S.C.  1251  et seq., as amended by  the Clean Water Act of 1977,



 Pub.  L.  95-217, and the Water Quality Act of 1987, Pub.  L.  100-4),



 also  referred  to  as "the Act."
 1. 1
BACKGROUND
 1.1.1
Clean  Water  Act
           The Federal Water Pollution  Control Act Amendments of



 1972 established a comprehensive program to  "restore and maintain



 the chemical, physical, and biological integrity  of the Nation's



 waters,"  (Section 101(a) ).  To implement the  Act,  EPA  is to  issue



 effluent  limitations guidelines, pretreatment standards and  new



 source performance standards for industrial dischargers.
                                1-1

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These guidelines and standards are summarized briefly below:








           1.    Best  Practicable  Control Technology Currently



                Available (BPT^   (Section 304 (b) (1)  of the Act) .








           BPT effluent  limitations guidelines are  generally  based



on the average of the best existing performance by plants of



various sizes, ages, and unit processes within the category or



subcategory for control of pollutants.








           In establishing BPT effluent  limitations  guidelines, EPA



considers the total cost of -achieving effluent reductions in



relation to the effluent reduction benefits, the age of equipment



and facilities involved, the processes employed, process changes



required, engineering aspects of the control technologies,



non-water quality environmental impacts, (including energy



requirements)  and other factors as the EPA Administrator deems



appropriate (Section 304(b)  (1) (B) of the Act).  The Agency



considers the category or subcategory-wide cost of applying the



technology in relation to the effluent reduction benefits.  Where



existing performance is uniformly inadequate, BPT may be



transferred from a different subcategory or category.
                                1-2

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           2.   Best Avai3.able Technology Economically Achievable




                (BAT)  (Sections 304 (b) (2) (B) and 307(a) (2) of the



                Act) .








           In general, BAT effluent limitations represent the best



existing  economically achievable  performance of plants in the



industrial  subcategory or category.   The Act establishes BAT as



the principal  national means of controlling the direct discharge



of priority pollutants and nonconventional  pollutants to navigable



waters.   The factors considered in assessing BAT include the age



of equipment and  facilities involved,  the process  employed,



potential process changes,  and non-water quality environmental



impacts  (including energy requirements,  (Section 304(b)(2)(B)).



The Agency  retains considerable discretion  in  assigning the  weight



to be accorded these factors.  As with BPT,  where  existing



performance is uniformly inadequate, BAT may be transferred  from a



different subcategory or category.  BAT  may include process



changes or  internal controls,  even when  these  technologies are not



common industry practice.








          3.    Best Conventional  Pollutant  Control Technology




                (BCT)  (Section 304(a) (4)  of  the Act) .
          The  1977  Amendments  added Section 301(b)(2)(E)  to  the



Act establishing BCT for discharges  of conventional pollutants



from existing industrial point sources.  Section 304 (a) (4)



designated the following as conventional pollutants:  Biochemical





                                1-3

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oxygen demanding pollutants  (BOD5) ,  total suspended solids (TSS) ,




fecal coliform, pH, and any additional pollutants defined by the



Administrator as conventional.  The Administrator designated oil



and grease as an additional conventional pollutant on July 30,



1979  (44 FR 44501) .
          BCT  is  not  an  additional limitation, but replaces BAT



    the control of conventional pollutants.  In addition to other



factors specified in Section 304 (b) (4) (B) ,  the Act requires that



BCT limitations be established in light of a two part



"cost— reasonableness" test.  [American Paper Institute v. EPAf 660



F.2d 954  (4th Cir. 1981)].  EPA's current methodology for the



general development of BCT limitations was issued in 1986 (51 FR



24974; July 9, 1986) .
          4.    New Source Performance  Standards  (NSPS)  (Section



                306 of the Act) .







          NSPS  are based  on the best available demonstrated



treatment technology.  New plants have the opportunity to install



the best and most  efficient production processes and wastewater



treatment technologies.  As a result,  NSPS should represent the



most stringent numerical values attainable through the application



of the best available control technology for all pollutants  (i.e.,



conventional, nonconventional, and priority pollutants) .  In



establishing NSPS, EPA is directed to take into consideration the
                                1-4

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cost of achieving the effluent reduction and any non-water quality



environmental impacts and energy requirements.
           5.    Pretreatment  Standards  for Existing  Sources (PSES1



                (Section 307 (b)  of the  Act) .
           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



Act requires pretreatment standards for pollutants that pass



through POTWs or interfere with POTWs'  treatment processes or



sludge disposal methods.  The legislative history of the 1977 Act



indicates  that pretreatment standards are to be technology-based



and analogous to the BAT effluent limitations guidelines for



removal of toxic pollutants.   For the purpose of determining



whether to promulgate national category-wide pretreatment



standards, EPA generally determines that there is pass-through of



a pollutant and thus a need for categorical standards if the



nationwide average percent of a pollutant removed by well-operated



POTWs achieving secondary treatment is  less than the percent



removed by the BAT model treatment system.
          The General Pretreatment Regulations, which set forth



the framework for the implementation of categorical pretreatment



standards, are found at 40 CFR Part 403.   (Those regulations



contain a definition of pass-through that addresses localized



rather than national instances of pass-through and does not use





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 the percent  removal comparison  test  described above.   See  52  FR



 1586, January  14,  1987.)
           6.    Pretreatment Standards for New Sources (PSNS)




                (Section 307(b)  of the Act).
           Like PSES,  PSNS are designed to prevent the discharges



 of pollutants  that pass through,  interfere with,  or are  otherwise



 incompatible with the operation of POTWs.   PSNS are to be  issued



 at the same time as NSPS.  New indirect dischargers,  like  the new



 direct dischargers, have  the  opportunity  to incorporate  into their



 plants the best available demonstrated technologies.   The  Agency



 considers the  same factors in promulgating PSNS as  it considers  in



 promulgating NSPS.
1.1.2
Section  304(ml   Requirements  and Liti era tion
           Section 304 (m)  of the Clean Water Act (33 U.S.C.



 1314(m)),  added by the Water Quality  Act of 1987,  requires EPA to



 establish  schedules for  (i) reviewing and revising existing



 effluent limitations guidelines  and standards  ("effluent



 guidelines"), and (ii) promulgating new  effluent  guidelines.   On



 January 2, 1990,  EPA published an Effluent  Guidelines Plan  (55 £R



 80), in which schedules were established for developing new and



 revised effluent  guidelines for  several industry categories.  One



 of the industries for which the  Agency established a schedule was



•the Pesticide Chemicals category.




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           Natural Resources Defense Council, Inc. (NRDC) and



Public  Citizen,  Inc.,  challenged the Effluent Guidelines Plan in  a



suit  filed in  U.S.  District Court for the District of Columbia




 (NRPC st.  al. v.  Reilly,  Civ.  No.  89-2980) .   The plaintiffs  charged



that  EPA's plan  did not  meet  the requirements of Section 304 (m) .



A Consent  Decree in this litigation was  entered by the Court  on



January 31, 1992.   The Decree requires,  among other  things, that



EPA propose effluent guidelines  for the  formulating,  packaging and



repackaging subcategories of  the  Pesticide  Chemicals  category by



January,  1994, and  take  final action by  August  1995.   EPA filed a



motion  with the  court  in November,  1993  requesting an extension of



time  until  March 31, 1994 for the EPA Administrator to sign the



proposed regulations.
1.1.3
Pollution
j nn  Act
           In the  Pollution Prevention Act of 1990  (42  U.S.C.  13101



et seq., Pub.L. 101-508, November 5,  1990),  Congress declared



pollution prevention to be the national policy of the United




States.  The Act declares that pollution  should be prevented or



reduced whenever feasible; pollution  that cannot be prevented



should be recycled or reused in an environmentally safe manner



wherever feasible; pollution that cannot be  recycled should be



treated; and disposal or release into the environment should be



chosen only as a last resort.
                                1-7

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                 Regulation  and  Iiiticration  for  the  Pesticide



          Chemicals  Cateor
          EPA promulgated BPT for the Pesticides Chemicals



Industry on April 25, 1978  (43 FR 17776; 40 CFR Part 455),  and



September 29, 1978  (43 FR 44846; 40 CFR Part 455) .'   BPT



limitations requiring zero discharge of process wastewater



pollutants to navigable waters were set for all pesticide



formulating and packaging operations (Subcategory C) .








          At  that time BPT  effluent limitations guidelines were



also established for the Organic and Metallo-Organic Pesticide



Chemicals Manufacturing Subcategories (Subcategories A and B,



respectively) .  The BPT effluent limitations guidelines



established limitations for chemical oxygen-demand  (COD) , BODs,




TSS, and  pH  for wastewaters discharged by the organic pesticide



active ingredient (PAI) manufacturing subcategory (Subcategory A) ,



except that discharges of these pollutants resulting from the



manufacture of 25 organic PAIs and classes of PAIs  were



specifically  excluded from the limitations.  In addition, BPT set



a limitation  for Subcategory A on total pesticide discharge which



was applicable to the manufacture of 49 specifically listed



organic PAIs.  BPT limitations requiring zero discharge of process



wastewater pollutants were set for metallo-organic PAIs containing
                                1-8

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 arsenic, mercury,  cadmium,  or  copper.
           Several industry members  challenged the BPT regulation



on April 26,  1978  and  the  U.S. Court of Appeals remanded them on



two minor  issues  FBASF Wyandotfce Corp. v. Costlef  596 F.2d  637



 (1st Cir.  1979),  cert . denied, Eli Lilly v. Costler 444  U.S.  1096




 (1980) ] .   The Agency subsequently addressed the two issues  on




remand and the Court upheld the regulations in their entirety



 [BASF  Wvandotte Corp.  v. Cns-M P>r 614 F . 2d 21  (1st  Cir. 1980)].
           On  November 30,  1982,  EPA proposed  additional



regulations to control the discharge of wastewater pollutants  from



pesticide  chemical operations to navigable waters and to POTWs  (47



F_R 53994) .  The proposed regulations included effluent  limitations



guidelines based upon BPT, BAT, BCT, NSPS, PSES, and PSNS.  The



proposed effluent limitations guidelines and standards  covered the



organic pesticide chemicals manufacturing segment, the



metallo-organic chemicals manufacturing segment and the



formulating/packaging segment of the pesticide chemical industry.



In addition, the Agency proposed guidelines for test procedures to



analyze the nonconventional pesticide pollutants covered by these



regulations on February 10, 1983 (48 F_R 8250) .
          Based on the new information collected by EPA in



response to the comments on the November 30,  1982 proposal,  on



June 13, 1984, EPA published a Notice of Availability (NOA)  of new



information (49 ER 24492) .   In this NOA,  the  Agency indicated it





                                1-9

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was considering changing its approach to developing regulations



for this industry.  EPA requested comments on the data.  EPA



published a second NOA of new information on January 24, 1985,



which primarily made available for public review technical and



economic data which had previously been claimed confidential by



industry.








          EPA issued a final rule on October 4, 1985,  that limited



the discharge of pollutants into navigable waters and  into POTWs



(50 FR 40672).  The regulation included effluent limitations



guidelines and standards for the BAT, NSPS, PSES, and  PSNS levels



of control for new and existing facilities that were engaged in



the manufacture and/or formulation and packaging of pesticides.



The regulation also established analytical methods for 61 PAIs for



which the Agency had not previously promulgated approved test



procedures.
          Several parties filed petitions  in the Court of Appeals



challenging various aspects of the pesticide regulation  rChemical



Specialties Manufacturers Association,, et al. r v. EPA (86-8024) ] .



After a review of the database supporting the regulation the



Agency found flaws in the basis for these effluent limitations



guidelines and standards.   Subsequently, the Agency and the



parties filed a joint motion for a voluntary remand of the



regulation in the Eleventh Circuit Court of Appeals.   The Court



dismissed the case on July 25, 1986, in response to the Joint



Motion.   Upon consideration of the parties' motion to modify the





                                1-10

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dismissal,  on August 29, 1986, the Court modified its order to



clarify the terms of the dismissal.  The Eleventh Circuit Court of



Appeals ordered that:   (1) the effluent limitation guidelines and



standards  for the pesticide chemicals industry be remanded to EPA



for reconsideration and further rulemaking; and  (2) EPA publish a



FEDERAL REGISTER notice removing the remanded pesticide regulation



from the Code of Federal Regulat-.j ons (CFR) .








           EPA  formally  withdrew the regulations  from the  Code of



Federal Regulations on December 15, 1986  (51 EE 44911) .  Although




no errors  were found in the analytical methods promulgated October



4, 1985, these methods were- also withdrawn to allow for further



testing and possible revision.  The BPT limitations that were



published  on April 25, 1978 and September 29, 1978 were not



affected by the withdrawal notice and remain in effect.  Those



existing BPT limitations regulations are not proposed to be



changed with the proposed regulation.   EPA is not requesting and



will not evaluate public comment on the 1978 BPT limitations.  To



redevelop  the additional effluent guidelines for the pesticides



industry,  EPA split the project into two parts.  EPA first



promulgated effluent guidelines for the pesticide manufacturing



industry (58 FR 50638,  September 28,  1993).  These proposed



regulations for the pesticide formulating, packaging and



repackaging industry comprise the second part of this effort.
                               1-11

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1.2
SCOPE  OF  TODAY'S  PROPOSED  RULE
          The regulation proposed today  covers two  formulating,

packaging and repackaging subcategories of the pesticide chemicals

industry:
                Subcategory C:   Formulators,  packagers  and
                repackagers of  pesticide chemicals,  including
                formulating,  packaging and repackaging  operations
                at pesticide manufacturing facilities  (PFPR and
                PFPR/Manufacturers);  and

                Subcategory E:   Repackagers of agricultural
                pesticide chemicals  at refilling establishments
                (Refilling Establishments).
          EPA has addressed the  Organic  (Subcategory A) and Metallo-

Organic (Subcategory B) Pesticide Chemicals Manufacturing

subcategories in a separate  rulemaking (58 FR 50637, September 28,

1993).  Subcategory D was designated for the promulgation of

analytical methods.
        The proposed regulations expand the current effluent

limitations guidelines and standards to include  BCT, BAT, NSPS,

PSES and PSNS for new and existing facilities in Subcategory C

(PFPR and PFPR/Manufacturers) and develop BPT, BCT, BAT, NSPS,

PSES and PSNS for new and existing facilities who repackage

agricultural pesticide chemicals at refilling establishments

(Subcategory E).   EPA has decided not to create a Subcategory for

the formulators,  packagers and repackagers (PFPR) of sanitizer

chemicals.  Instead these facilities fall under Subcategory C as

PFPR facilities.   However, in order to minimize the economic


                                1-12

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 impacts on these small businesses, these regulations propose



 slightly different Pretreatment Standards (see Section 12) for



 existing indirect discharging small sanitizer facilities compared



 to the remainder of Subcategory C facilities. In addition, BCT for



 conventional pollutants is proposed to be set equal to BPT for all



 subcategories in the pesticide formulating and packaging industry.
^        The proposed effluent limitations guidelines and standards



 are intended to cover discharges generated during the formulating,



 packaging and repackaging of cill EPA registered pesticide



 products.  However, under PSES and PSNS EPA is proposing an



 exemption to the coverage for sodium hypochlorite (see Section



 12).   These guidelines apply to at least ten specific process



 wastewater sources (see Section 2.1.1), including rinsates from



 cleaning operations.   These guidelines do not apply to wastewater



 generated by on site employee showers, laundries or fire



 protection test water.  These guidelines do not apply to the



 production of pesticide products through an intended chemical



 reaction (i.e., manufacturing).  Formulation does not involve



 intended chemical reactions, but does involve the process of



 mixing,  blending or diluting one or more pesticide active



 ingredients (PAIs)  with one or more other active or inert



 ingredients to obtain a product used for additional processing or



 an end-use (retail) product.  The manufacture of PAIs through a



 chemical reaction are covered by the Pesticide Chemicals



 Manufacturing effluent guidelines (58 FR 50638, September 28,



 1993).   The PFPR guidelines are also intended to apply to the





                                1-13

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repackaging of agricultural pesticide chemicals at refilling



establishments, but at this time do not apply to custom blending



or custom application that may also be performed at these



refilling establishments.
                               1-14

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                             SECTION  2
                              SUMMARY
2. 0
OVERVIEW  OF  THE  INDUSTRY
      The  industry as  a  whole  is referred to as the pesticide



formulating, packaging  and repackaging (PFPR)  industry.  The  '



subcategories are  referred to as:   PFPR or Subcategory C for the



pesticides chemicals  formulating,  packaging and repackaging



subcategory  {including  sanitizer chemicals formulating, packaging



and repackaging);  and refilling establishments or Subcategory E



for the repackaging of  agricultural pesticide chemicals at




refilling establishments whose principal business is retail'sales.



The refilling establishments represent a new population that was



identified in the  survey of pesticide producing establishments.
     Based on the data from the 1988 FATES database, the pesticide



PFPR industry is made up of an estimated 5,200 facilities.



Approximately 3,240 of these facilities are represented by an



extraction of the FATES database.   This extraction contains only



those facilities who formulate, package or repackage one or more



of the 272 PAIs covered by the pesticide manufacturing rule (see



Table 3-1 for a list of the 272 PAIs) .   Upon reviewing the  data



collected by the survey questionnaire,  EPA found that,



approximately,  only 2,400 of the 3,240  facilities listed in the






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 FATES  database had  actually performed pesticide  formulating,
 packaging  and/or  repackaging  in  1988  (the  840  other  facilities  are
 referred to  as non-PFPR facilities).   Therefore,  EPA accounted  for
 the  non-PFPR facilities and re-estimated the number  of  PFPR
 facilities who formulated, packaged and repackaged  aJLl PAIs
 covered by this proposed regulation and found  that there were
 3,900  PFPR facilities  in 1988.
      ^
fc     In 1990, EPA sent questionnaires to a statistically selected
 random sample of  facilities based on  the 3240  facilities in the
 1988 FATES database and the 90 facilities  included in the 1986
 pesticide  manufacturing census.   The  questionnaire requested 1988
 data on the  formulating,  packaging and repackaging processes at
 these  facilities.   Based on the  responses  to the industry
 questionnaire and follow-up telephone calls, EPA extrapolated the
 data to the  national population.   The results  from the
 extrapolated data are  referred to in  the following sections as
 "national  estimates."  (Detailed  information on the development  of
 the  questionnaire and  the stratification of the  population is
 provided in  Section 3.1).
      EPA has used these national estimates to characterize the
 Pesticide Chemicals Formulating,  Packaging and Repackaging (PFPR)
 Industry.  As  stated above,  according to  the  national  estimates of
 the  survey data there were approximately  2,400 facilities
 performing pesticide formulating, packaging and repackaging

                                 2-2

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operations with the 272 PAIs in 1988.  This industry is heavily




concentrated in the mid-west and the south-east portions of the



United States.  Approximately 80% of the water using facilities



are considered small businesses by the Small Business



Administration's definition  {< 500 firm employees).  The 2439 PFPR



facilities fall into the two subcategories being considered for



this proposed regulation as follows:








          Subcategory C:   1257 PFPR and 48 PFPR/Manufacturers



          Subcategory E:   1134 Refilling Establishments
     The number of refilling  establishments is  significantly lower



than the population estimates for these types of facilities based



on all PAIs and registration data, and is also lower that the



estimates for the number of these facilities presently in



existence,  made by EPA in its proposed containment rule  (40 CFR



Part 165, 59 FR 6712, February 11, 1994)  and by estimates of



members of this industry.  EPA believes this discrepancy between



the 1988 and current numbers of facilities is due to the fact that



repackaging into refillable containers was still a growing market,



particularly in 1988.  In addition some industry representatives



indicated that because it was so early in the creation of this



market, many of the refilling establishments were unaware that



their new service of repackaging pesticide products required them



to be registered establishments and to report their annual



production to the Agency.  Thus, it is possible that many






                                2-3

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refilling establishments were not included in the population from



which our sample was drawn.








     Relative to the Pesticide  Chemicals Manufacturing  Industry,



the PFPR Industry uses a small  amount of water in their



formulating,  packaging and repackaging operations.   Median annual



(1988) volumes of water used for PFPR operations by subcategory



are as follows:








      •    Subcategory  C:  PFPR = 2,300 gal/yr and



          PFPR/Manufacturers =  242,120 gal/yr



      •    Subcategory  E:   Refilling Establishments



          =720 gal/yr








In comparison, the Pesticide Chemicals Manufacturing Industry's



1986 median annual volume of water  used/generated in pesticide



manufacturing is 1,318,600 gallons  per facility for the 90



manufacturing facilities included in the 1986 census.
      The  PFPR industry formulates,  packages and repackages



pesticide products for use in several markets.  These markets



include:



      •    Agriculture,  including livestock;



      •    Institutional/commercial  use, e.g., janitorial,



          hospitals,  food service establishments;



      •    Industrial  use  products,  i.e., slimicides used in pulp





                                 2-4

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           and paper production and biocides used in cooling



           towers;



           Consumer home,  lawn and garden;



           Wood preservatives and coatings;



           Products used  for formulating pesticides, i.e.,



           intermediate pesticide products;



           Non-agricultural professional use products;



           Products used  as an additive to non-pesticide products;



           and




           Government, for non-institutional use, e.g., highway



           departments, mosquito control districts, public



           utilities, or  military.
     Typically  facilities use batch operations when formulating



and packaging pesticide products.  Because the production at these



facilities is not continuous and most equipment is not dedicated



to production of a single product, the formulation and packaging



equipment is 'cleaned when changing over to the next formulation.



Also, many facilities operate on the principle of "just-in-time''



production.  This production philosophy reduces inventory and the



associated storage space.  However, when operating under "just-in-



time" production, the schedule is constantly changing according to



customer demand and may increase the number of cleanouts of



production equipment.  Wastewaters are not generated by the actual



formulating or packaging process  (as they are in pesticide



manufacturing).  The main sources of process wastewater at PFPR






                                2-5

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facilities are cleaning waters.  The wastewaters generated at PFPR



facilities are typically recycled (on- of off- site), discharged



to a POTW  (Publicly Owned Treatment Works) or sent off-site to an



incinerator.








     In terms of discharge status, the industry is  approximately



73% zero discharge, 26% indirect discharge (to Publicly Owned



Treatment Works),  and 1% direct discharge.  The facilities that



directly discharge seem to present an inconsistency with the 1978



promulgated BPT limitations which call for zero discharge of



wastewater pollutants to navigable waters.  A  small number of



PFPR/Manufacturers facilities combine their formulating and



packaging wastewaters with their manufacturing wastewaters for



discharge by using the zero allowance for the pollutants in the



formulating and packaging wastewater in their permits.  Because



they, nevertheless, meet their permit limitations that were



derived based on their pesticides manufacturing wastewater only,



these facilities are continuing to discharge certain quantities of



pesticide formulating and packaging wastewaters.
     A wide variety of raw materials are used in the pesticide



chemicals formulating and packaging industry creating a variety of



pesticide types (fungicide,  insecticide, herbicide ...) and



formulation types that can be produced by the PFPR industry.  The



inert ingredients that are typically mixed with PAIs during the



formulation of pesticide products include water, surfactants and





                                2-6

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organic solvents  for  liquid products and clay, talc or other

carrier materials for dry products.   These materials contribute to

the wide variety  of pollutants that  are found in the wastewaters

of this industry.  This  includes conventional pollutants   (BOD5,

Oil & Grease and  TSS) , a. variety of  toxic priority pollutants, and

a large number of nonconventional pollutants  (i.e., COD and the

PAIs).  The 272 PAIs  (listed on Table 3-1)  are organic and

metallo-organic pesticide active ingredients manufactured by the

pesticide chemicals manufacturing industry for use in formulated

pesticide products.



2 . 1       SUMMARY  OF  THE  PROPOSED  REGULATIONS



2.1.1    Applicability  of  the Proposed   Regulations



      The proposed pesticide chemicals formulating, packaging and

repackaging regulations  would apply  to process wastewater

discharges from existing and new pesticide chemicals formulating,

packaging and repackaging facilities.  EPA proposed to define the

applicability of  this proposed regulation to include the

formulating, packaging or repackaging of all registered products

except in the case of the indirect dischargers* the applicability

will exclude products which  contain  the active ingredient sodium
     iBPT  (which applies to direct dischargers)  is not being amended and,
therefore,  includes the formulating, packaging and repackaging of sodium
hypochlorite.  EPA is soliciting comment in the preamble on this subject.
                                 2-7

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hypochlorite  (which may also be referred to as bleach) .   It is



commonly classified as an inorganic chemical even though it has



registered pesticidal uses.  EPA notes that it would be



inappropriate to combine wastewater generated from the



formulating, packaging or repackaging of sodium hypochlorite with



wastewater from other active ingredients due to the high



probability that sodium hypochlorite will react with the organic



active ingredients and inerts found in other PFPR wastewaters.



Thus, EPA expects that wastewaters generated from the formulating,



packaging and repackaging of sodium hypochlorite are kept separate



from other PFPR wastewaters even in facilities where they coexist.








     EPA has  separated the PFPR  industry process wastewater



sources into two groups:  interior sources and non-interior



sources.  The following wastewater sources are considered to be



process wastewaters:








     Interior  sources:



           •     drum/shipping  container  rinsate



           •     bulk  container rinsate



           •     equipment  interior  wash  water
     Non-Interior  sources:



           •     floor/wall/equipment  exterior  wash water



           •     leak and spill cleanup water



           •     air or odor  pollution control  scrubber water






                                2-8

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           •     safety equipment wash  water



           •     contaminated precipitation runoff



           •     aerosol container (DOT)  leak test water



           •     laboratory equipment rinsate








Wastewater sources such as contaminated precipitation runoff and



leak and spill cleanup water include wastewater collected in



secondary containment  structures or on loading pads at refilling



establishments.  These regulations do not apply to wastewaters



generated by on-site employee showers, laundries,  or fire



protection test water  (see Section 5 for discussion).
2.1.2
Subcateuorv C:
PFPR  and  PEPR/Manufacturers
BPT



     EPA promulgated BPT effluent limitations guidelines in 1978



(40 JEE 17776; 43 F_R 44846; 40 CFR Part 455) applicable to



pesticide chemicals formulating and packaging processes.  The BPT



limitations require that there be no discharge of process



wastewater pollutants to navigable waters.   Repackaging operations



(except those at refilling establishments - see Subcategory E)



have always been included within the scope of Subcategory C: PFPR



and PFPR/Manufacturers.  In this rulemaking, EPA is proposing to



make this coverage of repackaging explicit in the title and



applicability sections of the regulation.  This is a clarification



only.  EPA is proposing no substantive changes to the existing BPT






                                2-9

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limitations  (i.e., those promulgated in 1978)  for Subcategory C.






BCT


     The Agency proposes in this regulation to set BCT equal to


BPT for conventional pollutants under Subcategory C:   PFPR and


PFPR/Manufacturers.   In setting BCT limitations,  EPA examines


whether the technology basis of BCT can provide further removal of


conventional pollutants under BPT (and the technology basis passes


a two-part cost-reasonableness test).   In this proposed regulation


the BPT limitations require no discharge, therefore;  a BCT


limitation could not provide further removal of conventional


pollutants.






BAT  and NSPS


     EPA is proposing to set BAT and NSPS limitations for


Subcategory C equal to BPT: no discharge of process wastewater


pollutants to navigable waters.






PSES  and  PSNS
                  \

     Currently there are no national standards regulating indirect


discharges from the pesticide chemicals formulating,  packaging,


and repackaging industry.  For Subcategory C:   PFPR and


PFPR/Manuf acturers,  EPA is proposing to set PSES  and PSNS that


will require no discharge of process wastewater pollutants.   These


standards would apply to all facilities with the  exception of
                               2-10

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small sanitizer  facilities2. These  standards are based on  zero

discharge through  reduced flow with pollution prevention,-water

conservation, recycle  and reuse of the interior wastewater sources

(see Section 2.1)  followed by  the use of the "Universal  Treatment

System"  (UTS) for  treatment and reuse of the remaining wastewater.



     Different PSES have been proposed for  small  sanitizer

facilities.  Facilities  that formulate,  package and  repackage

265,000 Ibs/yr of  products formulated with  specified sanitizer

active ingredients will  have to achieve zero of the  interior

wastewater sources but,  will be allowed to  discharge the non-

interior wastewater sources to POTWs.   PSNS is not being proposed

with the sanitizer exemption (see Section 13 for discussion).


     The Universal Treatment System is a small, flexible system

which may include  the  following treatment technologies:  emulsion

breaking, hydrolysis,  chemical oxidation, sulfide precipitation

(for removing metals)  and activated carbon.  These treatment

technologies and the UTS are fully described in this document in

Sections 7.2 and 7.4,  respectively.
     2Small sanitizer facilities are facilities which formulate, package or
repackage 265,000 Ibs/yr or less of all registered products containing
sanitizer active ingredients (listed in Section 12) and no other active
ingredients at a single pesticide producing establishment (i.e., a single PFPR
facility).

                                2-11

-------
2.1.3
STifocatecrorv  E:
Refi.lli.ncr Establishments
BPT,  BAT,  PSES,  NSPS,  &  PSNS



     Limitations and standards do not  currently exist  for



Subcategory E.   Subcategory E  has been created  to include coverage



of repackaging operations performed at refilling establishments.



Refilling establishments are often referred to  as ag-chem dealers



and are defined  as:  an establishment which is  registered with EPA



as a producing establishment  (as  required by FIFRA Section 7 and



40 CFR Part 167)  where  the activity of repackaging pesticide



product into refillable containers occurs.  This segment is



relatively new to the industry and involves the repackaging of



bulk pesticides  (mainly herbicides) for retail  sales, as a product



or a service, for agricultural purposes.  These facilities differ



greatly from facilities in Subcategory C.  As mentioned in Section



2.1.2, an in depth discussion  on the subcategorization of the



industry is presented in Section  4 of this document.








     EPA's Office of Pesticide Products  (OPP) is proposing to



require secondary containment  and loading pads  for refilling



establishments  (59 FR 6712 February 11, 1994) .  Once these



containment structures  are in  place precipitation and leaks and



spills that fall within the structure, along with minibulk



rinsates, will be collected and will create a possible point



source.
                                2-12

-------
     EPA is proposing limitations and  standards  (BPT, BAT, PSES,



NSPS, PSNS) that require no discharge of process wastewater



pollutants.  These limitations and standards are based on zero



discharge through secondary containment, loading pads and sumps



for holding collected wastewater and spills for reuse as product



in application to fields.  Wastewater generated from other



services performed at refilling establishments, including custom



blending and custom application, are not covered by the proposed



regulation.








BCT




     The Agency proposes in this regulation to set BCT equal to



BPT for conventional pollutants under Subcategory E:   Refilling



Establishments.  In setting BCT limitations, EPA examines whether



the technology basis of BCT can provide further removal of



conventional pollutants under BPT (and the technology basis passes



a two-part cost test).   In this proposed regulation the BPT



limitations require no  discharge, therefore; a BCT limitation



could not provide further removal of conventional pollutants.
                               2-13

-------

-------
                             SECTION  3


                      INDUSTRY  DESCRIPTION


3 . 0  INTRODUCTION


     This section discusses  characteristics of the Pesticide
Chemicals Formulating^ Packaging and Repackaging (PFPR)  Industry
and presents the following topics:


                •     Methods of data collection  used by  EPA;
                •     Overview of the industry; and
                •     Pesticide formulating, packaging, and
                     repackaging processes.


3 . 1  DATA COLLECTION  METHODS


     EPA has gathered and evaluated technical data from various
sources in the course of developing the effluent limitations
guidelines and standards for the Pesticide Chemicals  Formulating,
Packaging and Repackaging Industry.  These data sources  include:
           Responses  to EPA's  Questionnaire entitled "Pesticide
           Formulating,  Packaging and Repackaging Survey for 1988";

          EPA's 1990-1993 sampling and site visiting of selected
          pesticide  formulators, packagers and repackagers;
                                3-1

-------
      •     Industry  self-monitoring data;

      •     EPA treatability studies;

      •     Previous  EPA Office of Water  studies  of  Pesticides
           Industry;

      •     Literature  data;

      •     Data transferred  from the Pesticide Chemicals
           Manufacturing Rulemaking including:   industry
           treatability  studies, EPA treatability studies and EPA's
           sampling of selected manufacturers;

      •     Office of Pesticide Programs  (OPP) databases; and

      •     Other EPA studies of Pesticides Industry.

EPA used data from these sources to profile the industry with
respect to:  production by pesticide type and formulation type;
PFPR processes; market type; geographical distribution; water
usage; and wastewater generation,  pollution prevention practices,
treatment, and disposal.  EPA then characterized the wastewater
generated by PFPR operations through an evaluation of water use,
type of discharge or disposal,  and the occurrence of conventional,
nonconventional,  and priority pollutants.
                                3-2

-------
3.1.1     Existing  Databases;




           Process
Pesticide Reo-istrati
      A pesticide, as  defined by the  Federal  Insecticide,



Fungicide, and Rodenticide Act  (FIFRA),  includes  "any substance or



mixture of substances intended for preventing, destroying,



repelling, or mitigating any pest, and any substance or mixture of



substances intended for use as a plant regulator, defoliant, or



desiccant."  Under FIFRA all pesticides  must be registered with



EPA prior to shipment, delivery, or  sale in the United States.  A



pesticide product is a formulated product; that is, it is a




mixture of an "active ingredient"  (the PAI) and "inert" diluents.



Each  formulation has a distinct registration.
     Mandatory reporting of yearly pesticide production is



required by FIFRA along with the pesticide registration process.



Pesticide producing establishments, including formulating,



packaging, or repackaging (PFPR) facilities, are required to



provide information to EPA on registered pesticide products, such



as product registration numbers, product classification, type and



use, and production rates.   These data are submitted as part of




the "Pesticide Report for Pesticide-Producing Establishments" (EPA



Form 3540-16)  and are stored in the FIFRA  (Federal Insecticide,



Fungicide, and Rodenticide Act) and TSCA (Toxic Substances



Control Act) Enforcement System  (FATES) database administered  by



EPA's Office of Prevention,  Pesticides Toxic Substances (OPPTS).






                                3-3

-------
     FATES was  initiated as a project by the EPA Office of



Enforcement, Pesticide and Toxic Substances Enforcement Division,



in the fall of  1979 and  contains information on pesticide product



registrations based on annual reporting mandated by FIFRA. The



FATES database  has since been renamed and is currently referred to



as SSTS  (Section Seven Tracking System).








     Accessing  the OPPTS database gave the population data from



which the stratified random sample of formulating, packaging and



repackaging facilities were drawn.  The databases for more recent



years (1989 through 1991) were also accessed to identify any



changes in the  make-up of the industry and to evaluate the



applicability of the proposed regulation.
3.1.2
Selection  of  PAIs  for  Study
     For the Pesticide  Chemicals Formulating, Packaging and



Repackaging Category, there are 272 PAIs or classes of PAIs that



EPA collected data on for this proposed regulation.  As mentioned



in Section 1, prior to  1988, the Pesticide Chemicals Industrial



Category was being studied in order to develop effluent guidelines



under one rulemaking which contained both manufacturers and



formulator/packager/repackager segments of the industry.  In 1988



EPA separated these two segments for separate effluent guidelines



development.  As a starting point, EPA continued to use the same






                                3-4

-------
list  of  272  PAIs  or  classes  of  PAIs  under consideration for the



development  of  the Pesticide Manufacturing effluent guidelines for



the Pesticide Formulating, Packaging and Repackaging effluent



guidelines.   (Note:  For  the final rule covering organic pesticide



chemical manufacturing, three active ingredients were dropped from



coverage:  biphenyl  since it was no  longer a registered pesticide



active ingredient and ortho- and para-dichlorobenzene whose



manufacture  is  covered by another effluent guidelines regulation.)







      As  EPA  has developed these effluent guidelines, EPA realized



the need to  expand the scope of the  PAIs covered beyond the 272



PAIs.  There are  approximately  330 additional PAIs that are



formulated,  packaged and  repackaged  into registered pesticide



products.  Many of these  additional  PAIs are used in the same



facilities and  are mixed  with one or more of the 272 PAIs in



formulating  operations.   One inorganic active ingredient is being



specifically exempted from the  proposed PSES and PSNS regulations:



sodium hypochlorite  (bleach) .   EPA  has been able to use the FATES



database to  collect  limited  data on  these additional PAIs.



However, EPA believes that questionnaire and site visit data can



be applied to these  additional  PAIs  based on information collected



at facilities that formulate, package and repackage both the 272



PAIs and the additional PAIs.
     The following discussion is presented in the Proposed



Pesticide Manufacturing Technical Development Document [September






                                3-5

-------
1993; EPA-821-R-93-016] and has been incorporated in this document



to explain the basis for the selection of the 272'PAIs considered



for regulation under the Pesticide Manufacturing effluent



guidelines:








     The  initial basis for this list was the 284 PAIs and classes



of PAIs presented in Appendix 2 of the October 4, 1985 regulation



(50 ZE 40672).  These 284 PAIs were originally selected in 1977 on



the basis of  significant production and/or commercial use.  EPA



then expanded this list to 835 PAIs by adding the following group



of PAIs:








           •    All  salts and esters of listed organic acids  (such



               as 2,4-D);




           •    All  metallo-organic PAIs  (consisting of an organic



               portion bonded to arsenic, cadmium, copper, or



               mercury);




           •    All  organo-tin PAIs;




           •    All  PAIs that appeared to be structurally similar



               to other listed PAIs (such as organo-phosphorus



               pesticides); and




           •    Any  other PAIs with an analytical method previously



               demonstrated to be applicable to wastewater.
     EPA excluded from this list of 835 PAIs those PAIs already



subject to regulation under other effluent guidelines -






                                3-6

-------
specifically, those regulated by OCPSF (40 CFR Part 414),



Inorganic Chemicals Manufacturing (40 CFR part 415),  and



Pharmaceuticals (40 CFR Part 439).   Information provided to EPA



under FIFRA indicated that 335 of those 835 PAIs were produced in



1984-1985, and the other 500 were not produced for domestic use in



either 1984 or 1985.  An additional 15 (of the 835) were added to



the 335 PAIs because those 15 PAIs  had been manufactured prior to



1984 and might still be manufactured for export.  The list of 350



PAIs and derivatives, such as salts and esters, was then



consolidated by putting salts and esters of a PAI into a PAI



class, to arrive at a total of 270  PAIs and classes of PAIs.



Because the consolidated classes include all elements of the



class, such as all salts and esters of 2,4-D (i.e., not just those



in use in 1986), the 270 PAIs and classes of PAIs actually include



606 of the 835 specific PAIs.  Table 3-1 lists the PAIs and



classes of PAIs considered for regulation.
                                3-7

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                                         3-20

-------
3.1.3     The  Pesticide  Formulating,  Packaging  and



           Repackaging  Facility  Survey  for  1988








     The  following sections  (3.1.3.1-4) discuss the EPA



questionnaire,  "Pesticide Formulating, Packaging and Repackaging



Facility  Survey for 1988."  The discussions focus on the



development and distribution of the questionnaire, as well as, the



types of  data collected and the calculation of the national




estimates  from the collected survey data.   This questionnaire



constitutes a major source of the data EPA has collected in the



development of the pesticide formulating,  packaging and



repackaging effluent guidelines.
3.1.3.1
Development of the "Pesticide Formulating,.




Packaging and Repackaging Survev for 1988"
     A major source of information and data used in developing



effluent limitations guidelines and standards is industry



responses to questionnaires distributed by EPA under the authority



of Section 308 of the Clean Waiter Act.  These questionnaires



typically request information concerning production processes and



pollutant generation,  treatment, and disposal,  as well as



wastewater treatment system performance data.  Questionnaires also



request financial and economic data for use in assessing economic






                                3-21

-------
impacts and the economic achievability of technology options.
     EPA used its experience with previous questionnaires,



including the questionnaire distributed to the pesticides



manufacturing portion of the Pesticide Chemicals Industry, to



develop a draft questionnaire for this study.  In 1988, EPA sent



the draft questionnaire to pesticide industry trade associations,



environmental public interest groups and a number of pesticide



formulator/packagers for review and comment.  Based on the



comments from those reviewers and nine site visits to pesticide



formulating and packaging facilities, EPA revised the draft



questionnaire.  EPA clarified definitions and included a



dictionary to define terminology, reformatted the questionnaire to



make it easier to complete, and decided to request financial



information on an entire facility basis rather than for pesticide



related activities only.  Prior to pretesting the questionnaire,



the newly revised draft questionnaire was again distributed for



comment to the industry and trade associations.  In 1989, the



revised draft questionnaire was pretested at nine other pesticide



formulating/packaging facilities.  After facility personnel



returned completed questionnaires to EPA, EPA and its contractors



visited the facilities to evaluate the accuracy and completeness



of responses, to estimate the burden on the respondents and to



learn what sections respondents found difficult or confusing.  In



response to the facilities' comments (mostly editorial),  EPA



revised the questionnaire again.






                               3-22

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      As required by the Paperwork Reduction Act, 44 U.S.C. 3501 et




 seq., EPA submitted the revised questionnaire to the Office of



 Management and Budget for review, and published a notice in the



 Federal Register that the questionnaire was available for review



 and comment.   EPA also distributed the revised questionnaire to



 the same industry trade associations, pesticide industry



 facilities, and environmental groups that had provided comments on



"the previous  draft and to any others who requested a copy of the



 draft questionnaire.








      Based on additional comments received, EPA made changes to



 the questionnaire.  EPA increased the estimate of the respondent



 burden and added a question to the Introduction which allowed



 respondents that no longer formulated and/or packaged pesticide



 products to skip the  detailed technical and economic sections of



 the questionnaire.  OMB cleared the questionnaire for distribution



 on January 30,  1990 without comment (cleared under OMB control



 number 2040-0139).








 3-1.3.2   Distribution of the "Pesticide Formulating. Packaging



           and Repackaging Survey for 1988"
      In 1990,  under authority of Section 308 of the Clean Water



 Act,  the Environmental Protection Agency (EPA)  distributed



 questionnaires to selected facilities identified as pesticide






                                3-23

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formulators, packagers, or repackagers.  The questionnaires,



entitled  "Pesticides Formulating, Packaging, and Repackaging



Facility  Survey  for 1988," were intended to survey operations



producing pesticide products containing one or more of the same



272 pesticide active ingredients  (PAIs) or classes of PAIs that



were the  focus of the EPA's Pesticide Manufacturing Effluent



Guidelines rulemaking.  These PAIs are listed on (see Table 3-1).



The majority of  facilities were identified through the FATES



database  administered by OPPTS  (FATES is discussed in Section



3.1.1).
     FATES data  files were accessed to obtain information on



product registrations containing one or more of the 272 targeted



PAIs.  This dataset was used to define a sampling frame of 3,241



facilities identified in the 1988 Fates database as formulators,



packagers, or repackagers of these PAIs.  The sampling frame was



partitioned into 51 strata.  The stratification was done according



to pesticide production amount (large, medium, small,  and tiny)



and pesticide type  (fungicide, herbicide, insecticide, and other



and combinations of these types for facilities that formulate



and/or package more than one type.) The sample size for each of



the 51 strata was statistically determined to minimize



coefficients of variation as explained in Chapter Two  of the



vvReport on Formulating, Packaging and Repackaging (PFPR)  Facility



Surveys of 1988."  A total of 611 facilities was selected randomly



from the sampling frame to comprise the questionnaire  survey






                               3-24

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sample.  The survey was also distributed to a census of 91



pesticide manufacturers that also formulate, package or repackage



pesticides which were identified from the "Pesticide Manufacturing



Facility Census for 1986".  Two of the 611 sampled facilities and



two of the 91 manufacturers were sampled twice and received



duplicate surveys so the actual number of facilities sent surveys



was 609 sampled facilities and 89 manufacturers for a total of



698 surveyed facilities.  EPA received responses from 676 (587



randomly sampled facilities and 89 manufacturers)  of the 698



facilities that received the questionnaire  (a 97 percent response



rate).
     Of the 676 facilities that responded to the survey, 349



indicated that they were formulating, packaging or repackaging



pesticide products in 1988 and 203 were refilling establishments.



One hundred nineteen  (119) facilities did not formulate and



package pesticide products in 1988.  Of the remaining 5 facilities



that responded, 3 had gone out of business, one was released from



completing a questionnaire and one sampled facility merged with a



second sampled facility.  A small number of facilities (22) did



not submit questionnaires.  EPA believes most of these facilities



are refilling establishments by virtue of their stratum,  the



company name and their locations.  Based on the responses to the



surveys from the randomly sampled facilities and the census of



manufacturers, quantitative estimates of pesticide formulating,



packaging or repackaging activities were computed for the entire






                               3-25

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 U.S. population of such facilities.








      EPA also received questionnaires from six facilities that



 were not selected in the random sample or part of the census of



 manufacturers.   Three of these facilities had participated in a



 pretest of the  questionnaire but were not chosen in the sample.



 The remaining three facilities were  facilities that asked if they



 might submit voluntary surveys.   The responses to these



••questionnaires  were reviewed but for statistical reasons were



 omitted from any further analysis for the purpose of national



 population estimates.








      Details of the survey sample design are provided in Chapter 2



 of the "Report  on Formulating,  Packaging,  and Repackaging (PFPR)



 Facility Surveys of 1988".








      The questionnaire consisted of  an introduction and three



 parts:




      •    Part  A.  Technical Information;



      •    Part  B.  Financial and Economic Information; and



      •    Part  C.  Contact Information and Certification.








      Based on the questionnaire structure,  facilities may have



 been exempt from completing  Part A or B for one of the following



 reasons:
                                3-26

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           1.    The facility did not formulate,  package,  or
                repackage in 1988 any registered pesticide product
                containing one or more of the 272 PAIs considered
                for regulation (119 facilities in this category);

           2.    The facility did not report using any water in its
                pesticide formulating, packaging, or repackaging
                operations in 1988 (108 PFPR facilities in this
                category); or

           3.    After December 31, 1988,  the facility had
                discontinued production of pesticide products
                containing PAIs considered for regulation (40 PFPR
                facilities in this category).
     To date 552 surveyed facilities have been  identified  as being

pesticide formulating, packaging and/or repackaging  facilities  in

1988.  Three hundred forty nine  (349) of these  facilities  fall

under the proposed subcategory C:  (PFPR and PFPR/Manufacturers)

with 270 of these facilities using water in their PFPR operations.

The remaining 203 facilities were identified through their

responses as refilling establishments  (Subcategory E), 135 of

these facilities have been identified as water  users.



3.1.3.3   Calculation of St.ratified National Estimates



     As discussed in Section 3.1.3.2,  the Pesticide  Formulating,

Packaging,  and Repackaging Facility Survey of 1988 was mailed to a

stratified random sample of U.S. pesticide production packager

(PFPR)  facilities,  with stratification done according to pesticide

production amount (large,  medium, small,  and tiny)  and pesticide

type (fungicide,  herbicide,  insecticide,  other,  and  combinations
                                3-27

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of these types  for  facilities that formulate and/or package more



than one type) .  The  survey was also distributed to a census of



pesticide manufacturers that also formulate, package or repackage



pesticides.  Based  on the responses to these surveys, weighted



statistical estimates of pesticide formulating, packaging or



repackaging activities were computed for the entire U.S.



population of such  facilities.  The results of these computations



will be referred to as national stratified estimates.  The



national stratified estimates generated, include point estimates



of totals, means  (i.e., averages) and medians  (i.e., the point at



which an equal  number of responses are above and below the value),



and their associated  standard errors.








     Details of the statistical methodology used to generate



estimates are provided in Chapter Three of the "Report on



Formulating, Packaging, and Repackaging (PFPR)  Facility Surveys of



1988."  The discussion that follows explains how EPA statistically



addressed two complicating factors of the PFPR survey:



misclassification of  some facilities in the sample frame and



missing data.
     The PFPR  survey design called for a two-way stratification of



the population of PFPR facilities.  The FATES database, which was



used to identify members of the target population,  contains



several fields with information on facility production, including



actual production for the previous year and estimated production






                                3-28

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for the upcoming year arid types of pesticides produced for these



years.  When the database was accessed in early 1990, the target



facilities were originally classified into strata based on each



facility's estimated 1989 production level and type of pesticide



product.  As such, the sample facilities were selected at random



from strata based on 1989 estimated production characteristics,



when the ultimate goal was to report production characteristics



for strata based on 1988 production levels and product types.  In




statistical terms, some of the facilities classified using the



original scheme were misclassified under the desired scheme for



stratification based on 1988 production (e.g., a facility



classified as "large" based on its estimated 1989 production level



might instead be classified as "medium" when the 1988 production



level was used).  Because of this misclassification, the sample



had to be post-stratified into the correct 1988-based strata.



Also, the typical formulas used to generate national estimates of



means, totals, and standard errors of these estimates are not



wholly correct.  Instead, alternate formulas were used to generate



national estimates of totals and standard errors of these totals



in Sampling Techniquesr 3rd Edition by Cochran (1977, p.143-144) .
     In general misclassification of members in the final strata



can impact the estimated standard error.  Most often,  a larger



variance will be estimated than what would be obtained using the



typical formulas for stratified random samples.  However, for the



pesticide survey data, the degree of misclassification is small






                                3-29

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enough that a large change in the estimated standard errors was



not expected.  To test this expectation, one would ideally



rechoose sample facilities based on the actual 1988 production



levels and product type and re-estimate standard errors using the



typical formulas for a stratified random sample with no



misclassification.  Since that is not feasible, a reasonable



comparison can still be made by examining the standard errors



obtained by applying the usual formulas to the original



stratification scheme based on 1989 projected production levels.



Because the same algorithm would be used for selecting the number



of facilities within each stratum, regardless of the



stratification scheme employed, it can be assumed that the



estimated standard errors from the original stratification will be



representative of the results that would have been computed had



the actual 1988 production characteristics been used to stratify



the target population initially.
     Comparison of the estimates for selected survey questions,



including the distribution of facility revenues and the



distribution of facilities ownership and operation type, indicates



that, as expected, the estimated standard errors on the national



totals are generally larger after using Cochran's formulas to



account for the misclassification than those computed assuming no



misclassification.  The magnitude of the differences was quite



small (usually no more than one or two percent)  for the standard



errors on the overall totals, but was in a few cases 20 percent or





                               3-30

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more for very small strata.








     Though restratification of the survey facilities often



increases the estimated standard errors,  the national totals



themselves will be exactly the same mathematically,  as long as the



same set of facilities is used to compute the estimates.  In the



PFPR project, a small number of facilities which were included in



the sample because of projected 1989 production figures did not



have any actual production in 1988.  These facilities were



therefore not a part of the targeted facility universe and so were



excluded from the restratified calculations.  Even so, the overall



national totals showed very minor changes (on the order of at most



four to five percent) when the restratified estimates were



compared with totals based on the original strata.








     A second complicating factor concerns missing responses.



Because some facilities failed to answer all the survey questions,



data were imputed for missing responses.   The amount of missing



data was negligible in most cases.   The only case where a



significant amount of delta was imputed involved wastewater volumes



and production-normalized wastewater volumes, which were reported



on a line-by-line basis for each combination of wastewater source



and destination.  Approximately 10% of the volume and/or production-



normalized volume entries were missing and were subsequently



imputed.
                                3-31

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 3.1.3.4    Data Collected by Pesticide Formulating.  Packaging and



           Repackaging Facility Survey








      The questionnaire specifically requested information on:  (1)



 the  PFPR processes used;  (2) the  quantity,  destination,  treatment,



 and  disposal of wastewater  generated during pesticide  formulation,



 packaging and  repackaging;  (3)  the  analytical monitoring data



 available for  PFPR wastewaters;  (4)  the  information  on



 treatability studies performed by or for facilities;  (5)  the



 degree of co-treatment  (treatment of PFPR wastewater mixed with



 wastewater from PAI manufacturing or other  industrial  operations



 at the facility); and  (6) the  extent of  wastewater recycling



 and/or reuse at the facility.   Information  was also  obtained



 through  follow-up telephone calls and written requests for



 clarification  of questionnaire  responses.
     EPA also requested that pesticide  formulating, packaging  and



repackaging facilities submit wastewater self-monitoring data.



Fifty facilities submitted some form of self-monitoring data.  Six



facility submitted data only for conventional pollutants, while



ten  (10) of the 50 facilities submitted conventional pollutant



data along with priority pollutant and/or nonconventional



pollutant data (including the PAIs).  However, much of these data



were not useful in characterizing pesticide process wastewaters.



In many cases,  only one detection was reported for a specific



pollutant,  or the sampling locations represented commingled






                               3-32

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wastewaters containing pollutant discharges from other industrial



processes,  such as pesticide manufacturing, organic chemical



manufacturing (OCPSF)  or non-pesticide product formulation.  Often



the data represented sampling results only at the end-of-pipe



plant discharge.  As will be discussed in Section 5,



self-monitoring data from only 10 facilities were useful in



characterizing priority pollutant discharges in raw pesticide



process wastewaters covering 89 PAIs.








     A summary of the information obtained from the questionnaire



is presented in this document.  It also reflects the additional



data obtained from follow-up telephone calls and written requests



for clarification of the information provided in responses to the



questionnaire.








3.1.4     EPA's Site  Visiting &  Sampling  of  Selected



          Pesticide  Formulators.   Packagers  and Repackaoers
     In order to develop effluent guidelines for this industry,




EPA conducted site visits and sampling at a number of PFPR



(including sanitizer facilities), PFPR/manufacturers and refilling



establishments.  Typically, during guidelines development, EPA



depends on a sampling program to characterize the raw wastewater



and to establish which treatment systems operate at BAT levels.



However, in the case of the PFPR industry EPA was not able to



conduct as extensive a sampling program as in the past.  This is




                                3-33

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because:  (1)   only 12 facilities in this  industry  survey

population  operate on site treatment systems  that  treated only

PFPR  water  (one of the 12  was a voluntary survey participant and

not part  of the sample);   (2)   facility operating  schedules are

very  unpredictable due to  the batch nature of their operations and

just-in-time production philosophy;   and  (3)  due to the batch

nature  of the formulating,  packaging and  repackaging processes,

treatment is almost always operated on a  batch basis making it

very  difficult to  characterize long-term  treatment performance

(long-term  even for a 3-day period) .   Therefore, EPA had to

implement a more widespread and in  depth  site visiting program

than  it has with past effluent guidelines.  The following

discussions provide an overview of  both the PFPR industry site

visiting  and sampling programs.
3.1.4.1
Site Visits
     EPA performed site  visits  at  51  facilities  (2 facilities are

not survey facilities and, therefore, did not fill out a

questionnaire).  As mentioned above,  these site visits were

performed to provide EPA with an in depth look at actual PFPR

operations.  The purpose of an  individual site visit was to:


     •    evaluate the facility's  water use and discharge
          practices with the purpose  of determining their ability
          to  comply with the various  regulatory approaches;

     •    gather information on different and/or typical water
          use,  water conservation, pollution prevention and best
                                3-34

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          management practices in the PFPR industry;

     •    evaluate the  facility's suitability for sampling; and

     •    evaluate the  facility as a possible candidate for
          treatability  testing.


     To ensure that EPA was getting a full picture of the industry

through the site visits, EPA selected a variety of facilities.

These facilities were selected to provide a distribution across:

geographical areas, facility subgroups/market types, water use

types,  cleaning sequences used and facility type (PFPR,

PFPR/Manufacturer, Sanitizer, Refilling Establishment).

Facilities were also selected if they were expected to have

implemented pollution prevention practices or have treatment

systems (especially systems for the purpose of treatment and

reuse) .



Subgroup Analysis
     A large part of site visit selection was based on the

"Subgroup Analysis."   [Note:  the subgroups are not subcategories

and are not being used in the regulatory sense.]  When selecting

sites to visit, EPA created a varied selection by trying to visit

10% of the total number of facilities in each subgroup. The

subgroups were developed to ascertain trends in water usage, water

discharge or disposal methods, and production.  Refilling

establishments were not included in this analysis and were

selected for site visits on a separate basis.


                                3-35

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     Subgroups were initially developed from the market question

in the questionnaire.   Facilities were asked to provide the

percentages of facility revenues from pesticide products that

could be attributed to different markets.   These markets are

listed in Section 2.0  and include:  agricultural, institutional,

industrial, wood preservatives,  additives, consumer home,  lawn and

garden, non-agricultural professional use, pesticide formulation,

and government use. EPA used these market types as a starting

point and developed 10 subgroups.  Unlike  market types, subgroups

are not solely based on percentage of facility revenues,  but also

on the types and amounts of the  pesticide  products produced.



The 10 subgroups are defined as:

     •    Aerosol—All  PFPR water users that operated a
          Department of Transportation  (DOT) test bath in any PFPR
          operation.  These facilities are not included in any
          other group, regardless of other activities at the
          facility.

     •    Agriculture—All  PFPR facilities with at  least  90% of
          1988 PFPR revenues from the agriculture market that did
          not fall into any other subgroup.  This subgroup also
          includes facilities identified as "agriculture" through
          a review of  their products handled and their revenue
          markets.

          Consumer  Home Products—All  PFPR facilities  with 1988
          PFPR revenues from the consumer  home,  lawn, and garden
          market that  handled products specifically aimed at the
          home portion of the market (including household
          cleaners).

     •    Consumer  Lawn and  Garden—All  PFPR  facilities  with
          1988 PFPR revenues from the consumer home, lawn,  and
          garden market that handled products specifically aimed
          at the lawn  and garden portion of the market.
                               3-36

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          Industrial—All  PFPR facilities with at  least  9'0%  of
          1988 PFPR revenues from the industrial market that did
          not fall into any other subgroup.
                                        4
     •    Institutional—All PFPR facilities  reporting at least
          90% of 1988 PFPR revenues from the disinfectant or
          institutional market or facilities reporting at least
          50% of the facility's PFPR production from products with
          a product type of "disinfectant," "sanitizer," or
          "sterilizer" that did not fall into any other subgroup.
          This subgroup also includes facilities identified as
          "institutional" through a review of their products
          handled and their revenue markets; however, it does not
          include those facilities placed in the consumer home
          products subgroup.

     •    Manufacturers—-All PFPR facilities  that also
          manufactured one or more pesticide active ingredients
          (PAIs) in 1986.  These facilities are not included in
          any other group,  regardless of other activities at the
          facility.

     •    Organo-Metallic—All PFPR  facilities reporting at
          least 90% of 1988 PFPR revenues from the wood
          preservatives market or facilities reporting at least
          50% of the facility's PFPR production from handling
          products contaiining organo-metallic PAIs, including
          organo-copper,  organo-mercury, or organo-tin PAIs that
          did not fall into any other subgroup.

          Organo-Metallic/Industrial—PFPR  facilities  that
          fall into both the organo-metallic and the industrial
          subgroups.

     •    Other—All PFPR  facilities  that  do not  fall into any of
          the above categories.  This subgroup does not include
          those facilities that were placed in a subgroup based on
          the products and markets that appeared to represent the
          majority of operations at the facility,  even if the
          facility did not meet all the criteria for the subgroup.


Facilities that  initially fell into the "other" subgroup or met

the criteria for more  than  one subgroup were reviewed to determine

the subgroup that appeared  to represent the majority of operations

at the facility.   The  subgroup determination was completed by
                               3-37

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 reviewing the markets and the products reported in the



 questionnaire.








      EPA has analyzed the trends in water usage, water



 discharge/disposal methods,  and production and used them to



 identify facilities within the subgroups that are currently



 achieving the proposed regulatory option (i.e.,  zero discharge



 through recycle or reuse of wastewater), as well as facilities



•that  do not currently meet this option.   This information has been



 used  to select facilities for site visits and to coordinate



 additional data gathering activities.   See Section 5 for detailed



 information on water use and wastewater characteristics.
 3.1.4.2
Wastewater Sampling
      Fourteen sampling episodes have been conducted at  13  PFPR



 facilities  since 1988 (one facility was  sampled under two



 different episodes).   Seven (7)  of the 14 episodes  included



 sampling of wastewater treatment systems and all 14  included



 sampling for raw wastewater characterization.   EPA  has  not sampled



 any wastewater from refilling establishments,  however,  seven



 refilling establishments have been visited.
      Raw wastewater characterization data were collected to



provide  EPA with concentration data for  PFPR wastewaters for a



number of different wastewater sources.   EPA collected 72 raw






                                3-38

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wastewater samples at 13 different facilities which contained 32



different PAIs.  Wasteweiter samples were collected for the



following wastewater sources:  equipment interior cleaning,



exterior equipment/floor wash, scrubber water, DOT test bath, drum




rinsate, laboratory equipment cleaning water, laundry and showers.



A number of these samples were collected to characterize



wastewater that was intended for reuse (the concentration of PAIs



in these samples is expected to be high).  Samples of commingled



wastewater sources were also collected.  Raw wastewater samples



are typically analyzed for levels of conventional pollutants, non-



conventional pollutants  (including PAIs), metals, semi-volatile



and volatile organics.  The results of this data collection are



discussed in Section 5.5.
     Facilities were  selected for sampling of treatment systems



after an evaluation of existing data and responses to the



questionnaire and follow-up telephone conversations.  Facilities



were selected for sampling if:  (1)  the facilities were operating



an apparently effective wastewater treatment system (especially if



the water treated was intended for reuse); (2)   the treatment



system was used to treat PFPR wastewater only;  (3)  the treatment



system was similar to a system EPA was evaluating in a




treatability study  (the facility treatment system could then be



used as a benchmark); (4)  the expected PAIs could be analyzed



using developed analytical methods; and (5)   the facility was



treating wastewater that contained PAIs (or structural groups) for






                                3-39

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 which data was lacking.








      As mentioned above,  sampling of wastewater treatment systems



 occurred at 7  of the  14 episodes.  EPA sampled  wastewaters



 containing 32  different PAIs.  The treatment technologies that



 were  sampled to test  treatment performance include:  activated



 carbon adsorption, membrane filtration (ultrafiltration and cross-



 flow  filtration),  ozonation, clarification and  biological



 oxidation.   EPA analyzed  the levels  of pollutants and the overall



 performance of the treatment systems.  In addition EPA conducted



 treatability studies  with both synthetic and actual PFPR  facility



 wastewater  to  test the treatment performance of activated carbon



 adsorption,  chemical  oxidation by ozone/UV, ultrafiltration and



 reverse  osmosis,  chemical precipitation,  hydrolysis and emulsion



 breaking.   These  treatability tests  are discussed in Section



 3.1.6.
     Prior to a  sampling episode at a PFPR facility,



representatives  from the Agency conducted an engineering site



visit.  These visits are described in the discussion on site



visits in Section 3.1.4.1.  Following the visit, a draft sampling



plan was prepared which provided the rationale for the selection



of sampling locations as well as the procedures to be followed



during sampling.  A copy of this draft plan was provided to the



plant for comments prior to any wastewater sampling to ensure that



the sample sites selected would properly characterize the process






                               3-40

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wastewater and evaluate the wastewater treatment system.  In



addition to the sampling plan, EPA collected information on the



active ingredients to be; sampled to allow arrangements to be made



for the chemical analysis of the active ingredients.








     During the sampling episode, teams of EPA engineers and EPA




contractor engineers and technicians collected and preserved



samples and shipped them to EPA contract laboratories for



analysis.  Levels of conventional pollutants, nonconventional



pollutants (including the pesticide active ingredients), and



priority pollutants were measured in raw wastewater and treated



effluent.  EPA always offered to split the samples with the



facility.  When facilities chose to split samples with EPA, either



the facility accepted the split samples provided by the EPA or



plant personnel independently collected wastewater from the EPA



sampling sites.  Following the sampling episode, a draft trip



report was prepared that included descriptions of the PFPR



operations and treatment processes, sampling procedures,



analytical results, QA/QC evaluation,  and discussion of the raw



wastewater composition and treatment system performance.  The



report was provided to the sampled facility for review and



comment, and any corrections were incorporated into the report.



The facilities also identified any information in the draft report



that the facility considered confidential business information.
                               3-41

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3.1.5
Industry-Supplied  Data
     Some POTWs  require indirect  dischargers  to  monitor their



effluent.  To make  use  of  this  self-monitoring data, the



questionnaire requested that  each respondent  provide all



monitoring data  available  for 1988 on  raw waste  loads, individual



process stream measurements,  pollutant concentration profiles, or



any other data on pollutants  associated with  the formulation,



packaging or repackaging of pesticide  products containing one or



more of the 272  PAIs targeted for detailed data  collection.  As



mentioned in Section 3.1.3.4, EPA received self-monitoring data



from 50 facilities  along with the responses to the questionnaire.



EPA later requested a number  of facilities to provide additional



monitoring data.  Facilities  selected  to provide additional data



were those with  monthly discharge reports to  POTWs.  EPA requested



that all monitoring data be provided in the form of individual



data points rather  than as monthly aggregates.   Much of the self-



monitoring data  cannot  be used  in developing  effluent guidelines



because the data provided  is  not  for wastewater  from PFPR



operations only.  Most  of these facilities monitor their



wastewater discharge downstream from PFPR operations.  At that



point the PFPR wastewaters have been commingled  with either



pesticides manufacturing, organic chemicals manufacturing,  or non-



pesticide product formulating wastewaters.  The  self-monitoring



data was also of limited use  because many POTWs  do not require the



PFPR facilities  to  monitor for  pesticide active  ingredients (only






                                3-42

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for conventionals,  COD, pH, organics or metals).  For additional



details on industry-supplied  data  see the discussion in Section 5.








     Pesticide  wastewater treatability studies  performed by or for



the facility were also requested by EPA.  Twenty three facilities



supplied treatability data.   Only  8 of the 23 were PFPR stand



alone facilities, the other 15 were PFPR/Manufacturers.  To the



extent possible, these additional  data were also considered in the



development of  the  effluent guidelines.  Because treatability data



were lacking for some PAls, individual PAIs, which were expected



to be treatable with a specific technology, were targeted for



treatability studies.  EPA collected samples of actual PFPR



process wastewater  at plants  producing those PAIs.  Following



sample collection,  the samples were transferred to an EPA



contractor for  bench scale testing.  The data were then used to



develop PAI removals for  use  in costing facilities for treatment



technology options.
3.1.6
EPA  Bench-Scale
i t-.^r
     EPA conducted a number of bench-scale studies to evaluate the



treatability of pesticide containing wastewaters by various



treatment technologies.  Three of these treatability studies were



conducted solely to support the PFPR effluent guidelines, while



one study was conducted for use in both the Pesticide



Manufacturing and the PFPR effluent guidelines.  These






                               3-43

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technologies  included hydrolysis, membrane filtration



 (ultrafiltration, microfiltration and reverse osmosis), activated



carbon adsorption,  chemical oxidation by ozone accompanied by



irradiation with ultraviolet light and, finally, emulsion breaking



through chemical addition.  Treatability studies were conducted



both on clean water to which PAIs were added ("synthetic



wastewaters") and on actual pesticide formulating, packaging and



repackaging process wastewaters.








     The discussion on the treatability studies conducted to



support'the PFPR proposed rulemaking can be found in Section 7.3



of this document.








3.1.7    Data   Transfers  from  Pesticide  Manufacturing



          StibeateCTori.es  and  Other  Sources
     EPA is relying on the data collected under the pesticide



manufacturers rulemaking as a basis for estimating the



treatability of active ingredients in the universal treatment



system.  EPA has transferred treatability data for activated



carbon, hydrolysis and metals precipitation.   Transferred



treatability data for activated carbon adsorption are based on



analyses of properties of both individual and groups of active



ingredients, such as molecular weight, aromaticity and solubility,



Transfers of treatability data for hydrolysis have been



extrapolated to operating conditions of pH 12 and temperature of






                               3-44

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60°C (see Appendix E for details of hydrolysis data transfers).

Treatability data for chemical oxidation via alkaline chlorination

were not transferred, because there was no technical basis for

such a transfer.



     EPA transferred treatability data from the following sources,

listed in order of preference.

     1.   Pesticides manufacturing active ingredient or active
          ingredient group BAT limitations development data.  The
          data are transferred from the manufacturing database to
          support BAT limitations if the treatment is based on
          activated carbon adsorption, chemical oxidation,
          hydrolysis, a combination of these technologies, or
          precipitation of organo-metallic active ingredients or
          active ingredient groups.

     2.   EPA bench-scale treatability study reports.

     3.   EPA sampling episode reports.

     4.   Industry treatability study reports, literature
          articles, and other data sources.


     Pretreatment to remove emulsions is expected to improve the

treatability of pesticide formulating, packaging or repackaging

wastewater by the BAT treatment technologies to the same levels

that EPA identified for active ingredients in the pesticide

manufacturing rule.  Therefore, treatment technologies and

associated treatability data  (typically obtained from full-scale

treatment systems) used to establish the BAT limitations for the

manufacturing subcategory may be considered applicable to the same

active ingredients or active ingredient groups in the formulating,

packaging or repackaging subcategory.  Where such full-scale data
                               3-45

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do not exist, it may be more  difficult to determine whether a



particular technology will  effectively treat a particular active



ingredient or active ingredient  group.  To determine whether



technologies are effective  when  full-scale data were not



available, EPA analyzed the treatability data provided in



treatability study reports, EPA  sampling trip reports, and other



data sources.  Treatability data from the pesticide manufacturing



record pertaining to the treatment of active ingredients or active



ingredient groups by activated carbon adsorption, chemical



oxidation, hydrolysis and precipitation are included in the



pesticide formulating, packaging or repackaging treatability



database.
     The final pesticide manufacturing effluent guidelines  (58 FR



50637) established BAT limits  for 53 active ingredients or active



ingredient groups based on these treatment technologies.  These



BAT limits are typically based on- full-scale treatability data



that also apply to pesticide formulators, packagers or repackagers



(assuming similar treatability of wastewater matrices once the



wastewater has been treated through an emulsion breaking or



chemical precipitation step).  Achievable effluent concentrations



may be available for full-scale activated carbon adsorption or



hydrolysis treatment systems,  but the carbon saturation loadings



or hydrolysis half-lives may be unknown due to a lack of influent



concentration data.  Of the BAT limitations for the 53 active



ingredients or active ingredient groups, 24 are based on activated





                               3-46

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carbon adsorption, 14 are based on chemical oxidation,  11  are



based on hydrolysis and 4 are based on a  combination of hydrolysis



and activated carbon adsorption.  None of the manufacturing BAT



limits for active ingredients or active ingredient groups  are



based on precipitation since the organo-metallic subcategory



 (Subpart B) BAT limitations were deferred.








     Hydrolysis is considered an effective treatment technique for



a specific active ingredient or active ingredient group when




treatability data are available for that  active ingredient



demonstrating half-lives of less than 720 minutes  (12 hours), and



a removal of 90 percent or greater at a temperature of  60°C or



less and a pH of 12 or less.  Hydrolysis  treatability data



demonstrating a half-life of greater than 720 minutes (12 hours)



at a temperature of 60°C and a pH of 12 are considered  ineffective



in treating the active ingredients or active ingredients groups.
     EPA conducted both extrapolations of hydrolysis treatability



data to operating conditions of 60°C and pH 12 and transfers of



hydrolysis treatability data to PAIs and PAI groups with



insufficient experimental treatability data.  Hydrolysis



treatability data extrapolations were conducted where sufficient



hydrolysis treatability data were available at conditions other



than 60°C  and pH 12,  and were based on kinetically derived



relationships.  Hydrolysis data transfers to PAIs and PAI groups



with insufficient experimental treatability data were conducted






                               3-47

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based on an analysis of the chemical structures of PAIs or PAI




groups and the pKa values  of the hydrolysis leaving group.  A more




detailed description of the hydrolysis treatability data transfers



is provided in the Appendix E of this document.








     Active ingredient specific activated  carbon adsorption



treatability data showing  any carbon saturation loading, or an



active ingredient or active ingredient group removal of 90 percent



or greater, are considered to be removed by activated carbon



adsorption treatment.  The availability of active ingredient



specific saturation loading data shows that it is possible to



remove the active ingredient  (or group) from the pesticide



formulating, packaging or  repackaging wastewaters using activated



carbon, although a high rate of carbon usage may be required.



Activated carbon adsorption treatability data demonstrating an



active ingredient removal  of less than 90 percent reflects



marginal treatment by activated carbon.








     Chemical oxidation treatability data  demonstrating an active



ingredient  (or group) removal of greater than 90 percent is



considered effective.  Chemical oxidation treatability data



demonstrating an active ingredient removal of less than 90 percent



is considered marginal or  ineffective.  Percent removal data were



not available from several chemical oxidation treatability data



sources.
                                3-48

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      Hydrolysis treatability studies conducted under the  current



formulating,  packaging or  repackaging and manufacturing rulemaking



development provide data for 44  active ingredients or active



ingredient groups.   Hydrolysis treatability  studies conducted



under previous  pesticide rulemaking  efforts  provide data  for an




additional five active ingredients or active ingredient groups.



Activated carbon adsorption  treatability studies conducted under



the current formulating, packaging or repackaging and



manufacturing rulemaking efforts provide data  for 37 active



ingredients or  active  ingredient groups.  Chemical oxidation



treatability  studies conducted under the current pesticides



rulemaking efforts  provide data  for  11 active  ingredients.  The



studies conducted under other previous pesticides rulemaking



efforts do not  provide for any additional data.
     A search  of the  manufacturing  rulemaking record was performed



to identify treatability information from technical literature,



treatment technology  vendors, and other sources.  Information



obtained from  this search includes:  (1) previously published EPA



documents addressing  pesticides; (2) technical journal articles



containing information on the treatability of active ingredients



or active ingredient  groups; and (3) reports from technology



vendors containing information about the performance and



effectiveness  of  their equipment in treating active ingredients or



active ingredient groups.  These sources contain information on a



variety of active ingredient or active ingredient group treatment






                                3-49

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 technologies;  however,  only information  on the  treatment



 technologies applicable to the formulating, packaging or



 repackaging subcategories were considered.








 3.2  OVERVIEW  OF THE   INDUSTRY








      As described in Section 2,  based on the  data from the 1988



 FATES database and the  survey questionnaire,  the  pesticide PFPR



•industry is made up  of  an estimated  3800 facilities.   (The survey,



 the FATES database and  the extrapolation process  are  described in



 Sections 3.1.1 and 3.1.3).








       In 1988, approximately 2400  of these facilities formulated,



 packaged or repackaged  the 272 PAIs  that were the focus of the



 survey.   Thirteen hundred and five  (1305)  facilities  were



 estimated to be PFPR facilities  (including 48 pesticide



 manufacturers  that are  also PFPR facilities) , while the remaining



 1134 were estimated  to  be refilling  establishments.   There are



 approximately  an estimated 700 additional PFPR  facilities  and 675



 refilling establishments along with  13 additional



 PFPR/Manufacturers.   These additional facilities  formulate,



 package  and repackage products containing only  the non-272 PAIs.



 These additional facilities bring the total number of facilities



 to  3800.   The  following discussion describes  some of  the survey



 data along with the  national estimates based  on the 272 PAIs.
                                3-50

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3.2.1    National  Estimateas  Characterizing  the  PFPR

          Industry



     In 1990, EPA sent questionnaires to 708 facilities.  As

described in Section 3.1.3.2,  EPA randomly selected these

facilities from approximately 3,240 facilities extracted from the

1988 FATES database along with 90 facilities from the 1986 census

of pesticide manufacturers.   In addition,  there were three

facilities that requested to participate in the survey and three

facilities that received that questionnaire as part of the pretest

(the voluntary and pretest questionnaire were not used for

national population estimates).   Again,  the basis of extracted

database and the pesticide manufacturing census were the 272 PAIs.

The operations that define the industry are defined below:
               Formulation is the process of mixing, blending, or
               diluting one or more pesticide active ingredients
               with one or more other active or inert ingredients,
               without a chemical reaction that changes one active
               ingredient into another active ingredient, to
               obtain a manufacturing use product or an end use
               product.

               Packaging is enclosing or placing a formulated
               pesticide active ingredient into a marketable
               container.

               Repackaging is the direct transference of a single
               pesticide active ingredient or single formulation
               from any marketable container to another marketable
               container, without intentionally mixing in any
               inerts, diluents, solvents, other active
               ingredients, or other materials of any sort.
     The rest of the section discusses some general
                               3-51

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characteristics of the  industry based on an extrapolation of the



349 PFPR facilities and 203  refilling establishments that



completed the introduction portion of the questionnaire and



reported formulating, packaging, or repackaging a pesticide



product in 1988.  Additionally, this section addresses the general



characteristics of the  population that reported discontinuing



pesticide formulating,  packaging, or repackaging production after



December 31, 1988 based on an extrapolation of responses to the



questionnaire received  from  40 facilities  (19 PFPR facilities and



22 refilling establishments).  In addition to the questionnaire,



EPA also conducted a follow-up phone survey of 28 refilling



establishments.








3.2.1.1   Facility Type
     Facilities in the PFPR  industry typically conduct more than



one type of operation to produce pesticide products.  In fact, EPA



estimates that when excluding refilling establishments less than



5% of the PFPR facilities only formulate, package, or repackage



products.  The PFPR industry primarily comprises facilities that



either formulate and package pesticide products  (68%), or



facilities that formulate, package, and repackage pesticide



product(22%).  A small group of facilities performs other



combinations of these operations  (e.g., package and repackage



only) as well.  One hundred percent of the refilling



establishments perform repackaging only and do not formulate or






                               3-52

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package pesticide  products.   However,  an  estimated  921  refilling



establishments perform custom blending or provide application



services and  some  also sell  bulk  fertilizer  products.








     Facilities  of the PFPR  industry do not  necessarily have



similar characteristics to one another.   As  discussed below, PFPR



facilities may have different ownership types, geographic



locations, market  types, water uses,  and  may formulate, package,



or repackage  different varieties  of  pesticide products.








3.2.1.2    Ownership Type and Geographic Location








     An estimated  98%  of the Subcategory  C facilities are operated



by either single-facility companies  or multiple-facility



companies.  Only an estimated 2%  of -the PFPR facilities are



estimated to  have  a cooperative ownership  (e.g., multiple owners



who purchase  and distribute  pesticide  products among themselves).



On the other  hand,  an  estimated 40%  of refilling establishments



are multiple-facility  companies.  The  remaining  60% are equally



divided among single-facility companies and  cooperative



ownerships.
     When looking at the estimated national distribution of PFPR



facilities by EPA regions, EPA found that the PFPR industry is



concentrated in the midwestern and south eastern portions of the



United States.  The largest concentration of PFPR facilities is in






                                3-53

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Regions  IV and V where  approximately 45% of the Subcategory C



facilities are located.  The refilling establishments are located



in Regions V and VII  (32% and 49%, respectively).  However, PFPR



facilities can be found in every geographic region of the United



States.
 3.2.1.3
Market Type
     Facilities  were  requested to report the percentage breakdown



of their 1988 PFPR revenues by market type.  For refilling



establishments,  greater than 90% of these facilities derive their



revenues from the agricultural market.  The other 10% is derived



from multiple markets  (i.e., no one market represents 100% of the



facility's revenue).  Revenues coming from the agricultural market



also constituted the largest percentage, approximately 65%, of the



PFPR  revenues.  Approximately equal numbers of facilities  (=250)



are estimated to have 100% of their revenues derived from the



institutional/commercial market or from multiple markets.



Seventeen percent of the PFPR facilities are estimated to have



100% of their revenue from the agricultural market,  which as



stated previously accounts for 65% of the total revenues taken in



from pesticide formulating and packaging.
     The questionnaire also requested facilities to report the



percentage of PFPR revenues generated by the export of pesticide



products.  The majority  (93%)  of the PFPR facilities that engage






                                3-54

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in exporting pesticide products are estimated to derive less than



10% of their revenues from exporting pesticide products and only a



very small number  (0.8%) are estimated to derive greater than 90%



of their revenue from exports.  Even fewer refilling



establishments derive revenue from exports.  Approximately 99%



derive less than 10% of their revenue from exports.








3.2.1.4   Facilities That Discontinued PFPR Production








     An estimated  78 PFPR facilities and 140 refilling



establishments discontinued production of pesticide formulating,



packaging, and repackaging operations after December 31, 1988.



Facilities that have discontinued production were required to



complete the Introduction portion of the questionnaire,  but were



exempt from completing the technical and economic portions.








     The PFPR facilities that discontinued production are mainly



located in EPA regions IV, VI and VII; while the refilling



establishments that discontinued production are located in Regions



V, VI and VII.  Approximately 37% of the facilities are estimated



to have discontinued PFPR production were facilities that



formulate and package pesticide products, as compared with an



estimated 68% of the population overall.   One hundred percent of



the refilling establishments that discontinued production were



facilities that repackaged only.  Furthermore,  of the facilities



that discontinued production, approximately 27% of the facilities






                                3-55

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that are estimated to,have discontinued production derived 100% of



their revenues from the agricultural market as compared with 17%



for the PFPR facilities still in operation.  Facilities that



discontinued PFPR production are estimated to be either a single



or multi-facility.  None of the facilities are estimated to have a



cooperative ownership  (less than 2% of all the PFPR facilities



reported a cooperative ownership).  The largest number of



refilling establishments that reported discontinuing production



were single facility companies.
3.2.1.5
Production
     In the Introduction of the questionnaire, PFPR facilities



were required to report products'containing at least one of the



272 PAIs that were formulated, packaged, or repackaged at their



facility in 1988.  The pounds of 1988 production for each product



were obtained from the FATES database or from the individual



facilities if production data were unavailable from FATES.  The



repackaged amount does not include the quantity of product that



facilities may have custom blended or commercially applied.  The



amount of pesticide production reported by PFPR facilities is



subject to double counting (e.g.,  a product may be formulated



and/or packaged at one facility,  and packaged or repackaged at



another facility).
     EPA estimates that Subcategory C facilities formulated,
                               3-56

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packaged, or repackaged approximately 9,000 products containing at



least one of the 272 PAIs that were the focus of the survey



questionnaire.  In addition, EPA found that refilling




establishments repackaged approximately 4,000 products  (522 unique



products).   Based on the median, the "typical" refilling



establishment reported repackaging four different products in



1988.  Approximately 1,000 of the 9,000 products and 850 of the



4,000 products were produced at non-water using Subcategory C



facilities and refilling establishments, respectively.  Because



these non-water using facilities were exempt from completing the



technical portion of the questionnaire, limited data are available



for the approximately 182 million pounds of product formulated,



packaged, or repackaged by these facilities.  Therefore, the



remaining discussion reflects EPA's estimates of the national



distribution of PFPR facilities that used water in 1988 and



formulated, packaged and/or repackaged one or more of the 272 PAIs



covered by the survey.








     EPA estimates that there are 988 Subcategory C facilities and



835 refilling establishments that used water during their PFPR



operations  in 1988.  Total production using the 272 PAIs is



estimated to amount to 4.9 billion pounds of registered pesticide



product containing an estimated 1,6 billion pounds of active



ingredient.  As mentioned previously, the pesticide production



reported by PFPR facilities is subject to double counting.
                                3-57

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 3.2.1.6
Product Tvnes
      EPA's Office of Pesticide Programs  classified each pesticide

 active ingredient by pesticide type  (i.e., each PAI was classified

 as  an insecticide,  herbicide,  nematicide, rodenticide,  germicide,

 etc.).   Utilizing these classifications,  individual products

 formulated,  packaged,  or repackaged  in 1988 were placed into  one

 of  the following pesticide-type groups:   herbicide,

 disinfectant/fungicide,  insecticide/rodenticide, or a combination

 of  these types.   These pesticide types are defined below:
           •    The herbicide classification applies to products
                that contain PAIs used primarily for the control of
                weeds.

           •    The disinfectant/fungicide classification applies
                to products that contain PAIs used for the control
                of germs,  bacteria,  viruses,  and/or fungi.

           •    The insecticide/rodenticide classification applies
                to any products that contain PAIs used for the
                control of insects,  nematodes,  mollusks,  and/or
                rodents (rats,  mice,  gophers,  etc.).

           •    Products containing  multiple PAIs that fall into
                more than one of these three categories are
                classified as combination-type products.


When  analyzing data for the water using  facilities, EPA  found that

for facilities  in Subcategory C  (excluding sanitizers),

approximately 41% of the products estimated to be produced by

these facilities were classified as an insecticide/rodenticide,

however, these products composed only about 24% of total

production  in pounds by these water-using facilities.  On the
                                3-58

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other hand, although an estimated 22% of the products were



classified as a herbicide, these products constitute an estimated



half of the total 1988 production in pounds by water-using PFPR



facilities.  For the sanitizer segment of the water using



Subcategory C facilities, EPA found that 90% of the products



produced are disinfectants/fungicides and account for greater than



80% of the production in pounds.  When conducting the same



analysis for refilling establishments, EPA found that 97% of the



reported products and 95% of the total 1988 production in pounds



were classified as herbicides.








     The Office of Pesticide Programs also classified products by



their type of formulation (definitions of formulation types can be



found in Appendix B).  Overall,  the largest percentage of products



are estimated to be emulsifiable concentrates (35%), while the



products with the largest percentage of production in pounds is



estimated to be granular products (29%).   However, for the



sanitizers 81% of the products are formulated as soluble



concentrates, while 60% of the pounds produced are formulated as



solutions ready-to-use.  The largest percentage of products



reported to be repackaged by refilling establishments are



emulsifiable concentrates which composed over 73% of the products



repackaged and 75% of the total 1988 production pounds.
                               3-59

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 3.2.1.7   Pesticide Active Ingredient Usage








      Detailed  data  collected  through the  questionnaire  indicates



 that  products  that  are formulated, packaged, or repackaged contain



 various percentages of PAI.   Some products  may contain  less than



 1% of PAI by weight, while others may contain over 99%  of PAI by



 weight.  Individual PAI usage was determined by multiplying the



 pounds of production of each product  by the percent of  each



 individual PAI contained in the product.  The pesticide products



 at refilling establishments tend to be more concentrated, due to



 the purpose  of their end use.  Over  half the products  repackaged



 by water using refilling establishments in  1988 contained between



 40 and 50 percent active ingredient and approximately 15 percent



 of the products contained between 80  - 90 percent active



 ingredient.
     Each of the 272 PAIs or classes of PAIs that were the focus



of the survey have been assigned a toxicity factor by EPA that



characterizes the individual active ingredient's relative



potential harm to the health of humans, animals, and the



environment.  The toxicity factors, which range from 0 to 37,333,



are standardized by relating them to copper, which is given a



toxicity factor of 1.   By multiplying each PAI's 1988 usage by its



toxicity factor, a weighted usage was calculated for each PAI. For



the Subcategory C,  Atrazine (PAI 60)  had the highest usage in



1988, but Terbufos (PAI 255)  had the highest weighted usage due to






                               3-60

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 the combination  of a relatively high toxicity factor (560)  and

 relatively high  usage (~ 38 million pounds).   When looking  at  the

 refilling establishments,  EPTC (PAI 246)  had the highest usage in

 1988,  while Parathion Methyl (PAI 107)  had the highest  weighted

 usage  due to its relatively high toxicity factor of 800. Once

 again,  the estimated PAI usage may be subject to double counting.



     The five PAIs that had the highest estimated use in products

'that were formulated,  packaged,  or repackaged by the water-using

 PFPR facilities  (excluding refilling establishments)  are listed

 below:
                Atrazine, PAI  60,  is  a herbicide used to control
                various weeds mainly on corn and sorghum crops.   An
                estimated 278 million pounds of Atrazine was used
                in products formulated, packaged, or repackaged by
                water-using PFPR facilities in 1988.

                Alachlor,, PAI  54,  is  used as a pre-emergence
                herbicide to control certain grasses and weeds in a
                variety of crops such as corn, cotton, soybeans,
                and potatoes.  An estimated 141 million pounds of
                Alachlor was used in products formulated, packaged,
                or repackaged by the water-using PFPR facilities in
                1988.

                Cyanazine, PAI  25,  is used as a pre-emergence or
                post-emergence herbicide for corn,  or as weed
                control on fallow cropland.  An estimated 107
                million pounds of cyanazine was used in products
                formulated,  packaged,  or repackaged by the water-
                using PFPR facilities  in 1988.

                Methyl Bromide,  PAI 160,  is used  as  a space
                fumigant to control insects and rodents in
                greenhouses,  grain elevators, and other areas used
                to store various commodities.  It may also be used
                as a preplant soil fumigation to control fungi,
                nematodes,  and weeds.   'An estimated 95 million
                                3-61

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                pounds  of methyl bromide  was used  in products
                formulated,  packaged,  or  repackaged by the water-
                using PFPR facilities  in  1988.

                Glyphosate, PAI  138,  is  a  non-selective,  non-
                residual post-emergence herbicide  used for annual
                and biennial grasses,  sedges and broad-leaved
                weeds.   An estimated 86 million pounds of
                glyphosate was  used in products formulated,
                packaged or repackaged by the water-using PFPR
                facilities in 1988.
     The five PAIs that had the highest estimated use in products

repackaged at refilling establishments are listed below:
                EPTC,  PAI 246,  is used as a herbicide to control
                perennial grassy weeds  in a variety of crops  such
                as  beans,  legumes,  potatoes, and  corn.  An
                estimated 22  million pounds were  used in products
                repackaged by the water-using  refilling
                establishments  in 1988.

                Alachlor, PAI 54, is used  as  a pre-emergence
                herbicide to  control certain grasses  and weeds  in  a
                variety of crops such as  corn, cotton, soybeans,
                and potatoes.   An estimated 6  million pounds  of
                Alachlor were used in products repackaged by  the
                water-using refilling establishments  in 1988.

                Metolachlor,  PAI 165,  is  used as a  pre-emergence
                and preplant  herbicide  to control weeds in a
                variety of crops such as  corn, soybean, peanuts,
                potatoes,  cotton and grain sorghum.   An estimated  4
                million pounds  of Metolachlor  were used in products
                repackaged by the water-using  refilling
                establishments  in 1988.

                Atrazine, PAI 60, is a herbicide used to control
                various weeds mainly on corn and  sorghum crops.  An
                estimated 3.7 million pounds of Atrazine were used
                in  products repackaged  by water-using refilling
                establishments  in 1988.

                Butylate, PAI 130,  is used as a  pre-emergence
                herbicide for grassy weed mainly  on corn.  An
                estimated 1.7 million pounds of Butylate were used
                in  products repackaged  by water-using refilling
                                3-62

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                establishments  in 1988.


 3.2.1.8   Production  Lines


      For the purposes of this survey, a  "line" is defined as:

          Equipment and interconnecting piping or hoses
          arranged in a  specific sequence to mix, blend,
          impregnate, or package,  or  repackage pesticide
          products.   These  products contain one or more
          pesticide active  ingredients with other materials
          to impart specific desirable physical properties
          for a product  or  device, or to  achieve  a desired
          pesticide active  ingredient concentration  for a
          particular  product or  device, or to  package it into
          marketable  containers.   The line begins with  the
          opening  of  shipping  containers  or the transfer of
          active ingredient(s) and other  materials from a
          manufacturer or another formulator/packager,  or
          from  inventory of bulk storage.  The line  ends with
          the packaging  or  repackaging of a product  into
          marketable  containers  or into tanks  for
          application.


     Production lines range from complex  configurations involving

numerous formulating and packaging steps to simpler lines that

transfer product from storage to a marketable  container.

Typically, facilities that  formulate  and package products,  operate

lines that include one or more storage tanks,   one or more

formulating processes such  as mixing,  blending, grinding, milling,

and filtering,   and a final  packaging  process.   Facilities that

solely package products typically transfer a product from a

storage tank into a marketable container, and  facilities that

solely repackage products transfer product from one marketable

container into  another marketable container.   In particular,  the

production lines at refilling establishments typically consist of
                                3-63

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a bulk storage tank, a minibulk tank into which the product is



repackaged, and any  interconnecting hoses and piping.  Typical



refilling establishments utilized three repackaging lines in 1988.



Facilities that merely relabel a product container are not under



scope of this survey.  The average market value of a line at a



PFPR facility is estimated to be $216,000 and the median value is



estimated to be $10,120.  The gap in magnitude between average and



median is representative of the fact that most of the facilities



attach a relatively  modest market value (half estimated a value



less than $10,120) while relatively few facilities attach a very



high market value to their production lines bringing the average



up to $216,000.  The average market value of a repackaging line at



a refilling establishment is estimated to be $3,650 and the median



value is estimated to be $1,960.
     The number of products formulated, packaged, or repackaged on



each line varies from line to line and from facility to facility.



Some lines are dedicated to one product while others may handle



ten or more.  Certain lines produce a variety of pesticide



products that contain the same or a similar pesticide active



ingredient, while other lines produce pesticides that contain a



variety of different active ingredients.   Some lines are also used



to formulate, package, or repackage products that have different



formulation types.








     It is important to note that the two formulation types,






                               3-64

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 "Formulation  Intermediate" and "Technical Chemical," although



 defined as unique formulation types by EPA's Office of Pesticide



 Programs, may be similar to other formulation types handled on a



 PFPR line.








 3.2.1.9   Line  Operating Schedules








          The questionnaire requested facilities to report which



 months each PFPR line was in operation in 1988, and to estimate



 the total number of days and hours each line was in operation in



 1988.  Most lines (66%) at PFPR facilities are operated 80 days or



 less in the production of registered products that contain one of



 the 272 active ingredients covered by the survey.  A high



 proportion (28%) of lines are estimated to be in operation 10 days



 or less per year.  At refilling establishments, about half the



 lines are operated on an as needed basis,  while the other half of



 the lines were reported as being operated for only one period.



 The majority  of repackaging lines at refilling establishments were



 in operation  in the months of March, April and June.








 3 . 3 PESTICIDE   FORMULATING,  PACKAGING  AND  REPACKAGING



     PROCESSES








     This section describes PFPR processes and provides general



diagrams for both liquid and dry formulation processes.
                               3-65

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to where it is applied.








     The use of refillable containers became widespread during the



1980's to reduce the numbers of empty pesticide containers needing



to be disposed of by farmers.  In general,  registrants distribute



large undivided quantities of pesticides to dealerships (refilling



establishments) where the products are stored in large bulk tanks.



The dealer then repackages the pesticide from the bulk storage



tanks to portable minibulk containers that generally have



capacities around 100 gallons.  The increased use of refillable



containers led to an increased amount of herbicide stored in bulk



quantities and the need to have a secondary containment system



built around the bulk storage tanks.  The Office of Pesticide



Programs has recently proposed a regulation to require such



secondary containment systems  (59 FR 6712;  February 11, 1994).
                                3-68

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                             SECTION  4

                   INDUSTRY   SUBCATEGORIZATION
4 . 0
INTRODUCTION
     The division of a point source category into groupings

entitled "subcategories" provides a mechanism for addressing

variations between products, raw materials, processes, and other

parameters which result in distinctly different effluent

characteristics.   Regulation of a category by subcategory provides

that each subcategory has a uniform set of effluent limitations

which take into account technological achievability and economic

impacts unique to that subcategory.



     The factors EPA has considered in the subcategorization of

the pesticide point source category include:
                    Product type;
                    Raw materials;
                    Type of operations performed;
                    Nature of waste  generated;
                    Dominant product;
                    Plant size;
                    Plant age;
                    Plant location;
                    Non-water quality characteristics; and
                    Treatment costs  and energy requirements
     EPA evaluated these factors and determined that

subcategorization is necessary.   These evaluations are discussed
                                4-1

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in detail in the following sections.  The pesticide chemicals

point source category was divided into four subcategories for the

purpose of issuing effluent limitations.   (One subpart of 40 CFR

455 was designated for incorporation of analytical methods -

"Subpart D:  Test Methods for Pesticide Pollutants."  The four

subcategories with effluent limitations are:



     A.   Organic pesticide chemicals manufacturing;

     B.   Metallo-organic pesticide chemicals manufacturing;

     C.   Formulators, packagers  and repackagers of pesticide
          chemicals,  including  formulating, packaging and
          repackaging at pesticide  manufacturing facilities;

     E.   Repackagers of pesticide  chemicals at refilling
          establishments.


Subcategories A and B, covering the pesticide chemicals

manufacturing industry,  have already been  addressed in a separate

rulemaking published  in  the Federal Register on September 28, 1993

 (58 FR 50638) .
4.1
BACKGROUND
     Under the  1978 BPT  rulemaking, EPA divided the pesticide

chemicals point source category  into three subcategories.  These

three subcategories were:   (1) organic pesticide chemicals

subcategory, which applied  to the manufacture of organic pesticide

active ingredients;   (2) the metallo-organic pesticide chemicals

subcategory, which applied  to the manufacture of metallo-organic


                                 4-2

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pesticide active ingredients; and   (3) the pesticide chemicals

formulating and packaging  subcategory, which applied to the

formulating and packaging  of all pesticide products.  As a result

of the development of the  September 28, 1993 Pesticide

Manufacturing rulemaking,  a separate subpart (D) of the rule was

identified for the analytical test methods.
4 .2
CURRENT  SUBCATEGORIZATION  BASIS
     In the current study, the Agency has developed new data and

has evaluated these data to determine the appropriate

•subcategorization.  Based on this evaluation, the Agency believes

there are two distinct subcategories within the formulating,

packaging and repackaging industry.  This subcategorization scheme

explicitly includes repackaging operations into both subcategories

and creates a new subcategory  for regulation.  The subcategories,

as proposed, are:
     Subcategory C - Formulators,  packagers  and  repackagers  of
                     pesticide chemicals,  including  formulating,
                     packaging and repackaging at pesticide
                     manufacturing facilities;

     Subcategory E - Repackagers  of agricultural pesticide
                     chemicals at  refilling  establishments.


      EPA considered creating a third subcategory for the

formulators, packagers and repackagers of certain active

ingredients which are used in sanitizer chemical products.   These
                                4-3

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active  ingredients are listed on Table 4-1.  As  presented in the

following  discussion,  sanitizer facilities are similar to the

other PFPR facilities  with respect to the types  of operations,

however, sanitizer product facilities are different in certain

market  and technical characteristics.  Therefore,  for existing

indirect discharging facilities only, EPA decided  to segment the

pretreatment  standards and provide separate limitations for

sanitizers in order to reduce the cost and economic impacts on

these small entities.   These separate limitations  will only apply

to sanitizer  facilities who formulate, package or  repackage small

quantities1 of sanitizer products ("small sanitizer  facilities").



     Unlike the  sanitizers, the refilling establishments clearly

differ  from the  rest of the population in terms  of the repackaging

operations they  perform, the raw materials used, water use and

wastewater treatment requirements and costs.  The  following

paragraphs discuss EPA's consideration of the factors (see Section

4.0) in determining appropriate subcategories for  the formulating,

packaging  and repackaging  operations in the  Pesticides Chemicals

Point Source  Category.
     iSmall quantities of sanitizer products means the formulating,  packaging
or repackaging of 265,000 Ibs/yr or less of all registered products containing
the sanitizer active ingredients listed on Table 4-1 and no other active
ingredients at a single pesticide producing establishment (i.e., a single PFPR
facility).


                                 4-4

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                                     Table  4-1
                          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-l-(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-clichlorobenzyl 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.
                                           4-5

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 4.2.1
Product  Type
      The PFPR industry produces pesticide products that fall into



 four basic pesticide types:  fungicide,  insecticide,  herbicide  and'



 other.   These pesticide types may be formulated into  product as 16



 different formulation types (i.e., solution,  emulsifiable



 concentrate,  granular, powder, etc.).   (See Appendix  B  for



 definitions of formulation types).  The  combination of  pesticide



•type and formulation type create far too many categories to  define



 a clear basis for subcategorization.   Also, facilities  in this



 industry change their product line frequently in response to



 customer demand and; therefore,  it would be difficult for



 permitting authorities to keep track of  the correct subcategory.



 But  most importantly, EPA has surveyed and visited facilities with



 a variety of product types and has not seen evidence  of



 differences in water use based on product type.   Therefore,  EPA



 did  not find product type as an appropriate basis for



 subcategorization of the pesticides formulating,  packaging and



 repackaging industry.
 4.2.2
Raw  Materials
      This industry uses a great variety of raw materials  in  their



operations,  including individual pesticide active  ingredients,



thus,  it  is  not practical to identify subcategories by specific



raw materials  or active ingredients.   In terms  of  applicability,






                                 4-6

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differences  in raw materials  (by grouping them)  do play  a  role  in



identifying  the sanitizer chemical product facilities.   As



identified previously,  the raw materials  that  distinguish this



group  are  the  sanitizer pesticide active  ingredients  listed  in



Table  4-1.   However,  the activities that  the sanitizer chemicals



facilities perform with these  raw materials  (i.e., formulating  and



packaging) are not different from other PFPR facilities.




Therefore, EPA does not believe that raw  materials provide a basis



for subcategorizing the sanitizer facilities.








     When  looking at  the raw materials used by refilling



establishments,  EPA recognized that the raw materials were



different  from the raw  materials  used by  the PFPR facilities.   The



"raw material" used at  refilling  establishments  is bulk  registered



pesticide product  which is  simply transferred  into another



container  (i.e., minibulk).  Meanwhile, the raw materials at PFPR



facilities are pesticide  active ingredients (PAIs) and inert



ingredients which  require mixing  to result in a registered



pesticide product.  Therefore, EPA believes that the differences



in raw materials contribute to the  decision to subcategorize



refilling establishments.
                                4-7

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4.2.3    Type  of  Operations  Performed:



          Formulating.  Packaging,   and  Repackaging



          Operations
     Facilities that formulate, package, and repackage pesticide



products, with the exception of the refilling establishments,  have



many common characteristics.  As discussed in Section 3.3,



formulating and packaging operations consist of mixing (without an



intended chemical reaction)  pesticide active ingredients  (PAIs)



with inert ingredients and then placing this product in a



marketable container.  Typically, these facilities, operate on a



batch basis and use a combination of equipment including mixing



vessels  (which may be heated), storage tanks, transfer hoses and



filling equipment for liquid products and blenders,  grinders,



sieves, storage tanks and hoppers for dry products.   Wastewater at



these facilities is generated from  cleaning operations including



rinsing of raw material containers, equipment interiors and



exteriors and floors in the process areas.  EPA has seen



widespread implementation of a variety of pollution prevention



practices at these facilities (see Section 7.4 for discussion on



these practices).  Some facilities may operate on a seasonal



schedule, but many facilities have product lines which provide



them with almost yearly production.  The customers of these



formulating, packaging and repackaging facilities are not the



product end-users, but rather distributors or retail dealers.   In



terms of typical operations the refilling establishments  (of






                                4-8

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agricultural pesticide  chemicals) seem to be the exception to



rule.
      These  refilling establishments perform repackaging of




agricultural  chemicals  and  do not perform formulating or initial



packaging of  products.  Repackaging as an operation is inherently



different from formulating/packaging operations.  Repackaging is



defined as  the direct transference of a single PAI or single



formulation from any marketable container (typically a stationary



bulk  container) to another  marketable container, without



intentionally mixing in any inerts, diluents,  solvents, other



active ingredients,  or  other materials of any sort.  These



facilities  typically handle bulk agricultural herbicide products



(and  possibly some fungicides).  Similar to operations at



formulating and packaging facilities, repackaging operations are



also  conducted on a  batch basis, but there some differences in the



equipment used and the  sources from which wastewater is generated.



Generally,  refilling establishments employ the use of bulk storage



tanks, transfer piping, pumps and refillable marketable containers



(minibulks  or tote tanks).  At most refilling establishments this



equipment is kept in a  diked secondary containment system.   Not



unlike the  rest of the  PFPR industry, wastewater is generated by



cleaning equipment.  However,  many of the process wastewater



sources found in PFPR industry are not found at refilling



establishments (i.e., aerosol DOT test bath water,  pollution



control scrubber water, interior cleaning rinsate from formulating






                                4-9

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mix tanks) and vice versa.  At refilling establishments,



wastewater is generated by cleaning stationary bulk tanks, triple-



rinsing refillable minibulk containers upon return, and collecting



leaks and spills or contaminated precipitation runoff that fall



within the containment structure.  In addition, operations at



refilling establishments are seasonal and, therefore, their



wastewater generation is also seasonal.








      Another difference between the refilling establishments and



the other facilities in this industry is the customer of the



product/service.  By definition this proposed effluent guideline



for refilling establishments applies to establishments engaged in



retail sales.  The customer of these facilities is usually the



end-user of the pesticide product (i.e., farmers).  Refilling



establishments may provide additional pesticide services to their



customers such as custom blending or custom application to fields.



They may also provide fertilizer chemical sales and services as




well.








     EPA believes that the refilling establishments are a



homogenous group and are sufficiently different from the other



facilities in this industry to justify subcategorization.  In



addition EPA believes that the type of operations performed in



this industry (formulating, packaging and/or repackaging) is an



appropriate basis for subcategorization.
                                4-10

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4.2.4
Nature  of  Waste  Generated
     Based on an analysis of the data available to EPA, there  are



no consistent differences in the amount and identity of pollutants



 (except for the active ingredient(s)) from different pesticide



formulating, packaging and repackaging facilities.  Virtually all



wastewater is derived from cleaning the equipment and the



surrounding areas.  In pesticide formulating, packaging and



repackaging operations where water is used, the volumes of water



used to perform cleaning operations vary in the industry.  PFPR



facilities who also manufacture pesticide active ingredients



generally use more water than other facilities in the industry.



This is because these facilities are usually larger and produce



 (in volume or pounds)  more formulated pesticide products than non-



manufacturer PFPR facilities.  The increase in water use and



wastewater generation at these PFPR/manufacturers is relative to



their increase in production and, therefore, EPA concludes that a



larger volume of water can be recycled back into the process.  To



demonstrate,  the median water use volumes for PFPR facilities and



PFPR/Manufacturers are approximately 2,300 gal/yr and 242,000



gal/yr, respectively.   However,  the production normalized volumes,



which takes production into account, are more comparable at 3.74



gal/1,000 Ib produced for PFPR facilities and 1.09 gal/1,000 Ib



produced for PFPR/Manufacturers.
     On the average, the formulators, packagers and repackagers of
                               4-11

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sanitizer products use  slightly larger volumes of water in their



operations than other PFPR  facilities.  Products formulated with



sanitizer chemicals are typically water based and are much more



dilute in terms of PAI  concentration than many of the other



pesticide products.  In addition, the toxicity of the sanitizer



chemicals is relatively low compared to most other pesticide



active ingredients.








     . The differences in the nature  of the wastes generated was



considered to be one factor that could tend to lead to a



subcategorization of facilities who formulate, package or



repackage sanitizer chemicals, but  alone was judged not to be an



appropriate basis to subcategorize  this industry.
4.2.5
Product
     As discussed in  Section  4.2.1, there are a large number of



products produced in  the pesticide formulating, packaging and



repackaging industry  due to the variety of pesticide types and



formulation types.  The PFPR  facilities formulated, packaged or



repackaged an estimated 9,000 products containing one or more of



the 272 pesticide  active ingredients which were the focus of the



survey.  Whereas,  the refilling establishments repackaged their



"dominant product" (i.e., agricultural herbicides) into 522 unique



products.  Also, the  refilling establishments serve only one



market type:  agricultural.   This causes the prevailing use of






                                4-12

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their products to be the application of  agricultural herbicides to



farmers'  fields;  while,  PFPR products may  be used as home, lawn



and  garden,  industrial and institutional or agricultural products.



Therefore, EPA believes  subcategorization  based on dominant



product produced  serves  as an appropriate  basis for•



subcategorization for the refilling establishments.
4.2.6
Plant  Size
      Plant size and production capacity  do not impact



characteristics of  wastewater  generated  during the formulating,



packaging  or  repackaging of  pesticide products based on data



available  to  EPA.   Many facilities  in this industry are not solely



pesticide  formulating, packaging and repackaging facilities.  They



may perform pesticide manufacturing, organic chemicals



manufacturing (OCPSF) and formulating, packaging or repackaging of



other non-pesticide products.   Therefore, plant size is not as



easily defined  as it is in an  industry that strictly performs one



operation.  The size of the plant will not affect the




effectiveness of treatment technologies  (i.e., the pollutant



concentration levels in the effluent that can be achieved with



treatment  technologies), although it can affect the cost of



treatment  equipment  and the cost of treatment per unit of



production.  EPA believes the  "Universal Treatment System" (see



Section 7.3 for detailed description) is flexible enough to work



for facilities  with  very small  wastewater flows,  as well as






                                4-13

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facilities with large wastewater flows.  EPA believes that



wastewater treated through the Universal Treatment System can be



reused, if not in formulations, than for cleaning floors or



equipment exteriors.  Overall, EPA does not believe that plant



size is an appropriate method of subcategorization for the



pesticide formulating, packaging and repackaging industry.
4.2.7
Plant  Aae
     The age of a plant or a production line can sometimes have a



direct bearing on the number of product changeovers on that given



line and, therefore, the volume of wastewater generated.  It is



more likely that an older plant will not have segregated equipment



and will need to clean lines more frequently due to product



changeover.  However, EPA has visited older plants that have



either switched to segregated equipment or have implemented less



expensive pollution prevention techniques, such as adding spray



nozzles to hoses or using floor scrubbing machines, to reduce



wastewater generation to the levels of newer plants.   Both older



and newer plants have been able to achieve zero discharge through



pollution prevention, recycle and-reuse.  Therefore,



subcategorization on the basis of plant age is not appropriate.
4.2.8
     As discussed in Section 3, the majority of pesticide
                               4-14

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formulating, packaging and repackaging facilities are located in



the Mid-western and South-eastern portion of the United States.



Many of the refilling establishments are also located in the



South-central United States.  Based on analyses of existing data,



plant location has little effect on wastewater quality, although



it may affect ,the cost of treatment and disposal of process



wastes.
     Location may have some effect on wastewater discharge



practices.  While most refilling establishments are either in



rural locations or in small towns near agricultural areas, many of



the PFPR facilities are located in urban areas.  In particular,



the PFPR facilities that serve the industrial and institutional/



commercial markets (sanitizers)  are located in urban areas.  These



facilities have a very different pattern of wastewater discharge



than the rest of the industry.  Virtually 100% of the sanitizer



facilities discharge to POTWs, while approximately 60% of the non-



sanitizer PFPR facilities achieve zero discharge of process



wastewaters.  The Agency is unsure if the type of business these



facilities are engaged in and the markets that they serve result



in their being located in urban areas,  thus providing them with



access to POTWs.  It is also possible that all facilities that



were more rural in their location and thus also direct dischargers



either got out of the business of making their products or became



dischargers to POTWs as a response to the BPT zero discharge



limitations promulgated in 1978.






                                4-15

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      Location can also affect costs associated with treatment.



Facilities in urban areas  have higher land costs  and tend to have



less  empty or unused space for treatment  units.   Distance from the



plant to an off-site disposal location may also increase costs of



off-site disposal of solid or liquid waste.







      Climatic conditions,  such as drought,  may affect  the water



use at a facility.   At the time of the survey, California was



experiencing  severe drought conditions.   EPA has  noticed that the



lack  of and cost  of water  in this part of the  country  encouraged



many  innovative pollution  prevention,  water conservation and reuse



techniques at  those facilities.  However,  many of  these same



techniques have been implemented in areas of net  precipitation



(i.e., Florida).








      EPA believes that location may contribute to the  decision to



segment the sanitizer facilities,  but  alone is not an  appropriate



basis for subcategorization.
4.2.9
Non-Water  Quality
     Non-water quality environmental impacts from the pesticide



formulating, packaging and repackaging industry result from solid



waste disposal, transportation of wastes to off-site locations for



treatment or disposal, and emissions of volatile organic compounds






                                4-16

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and particulates  to the air.   The  impact  from  solid waste disposal



is dependent  upon the treatment  technology  employed by a facility



and the  quantity  and quality  of  solid waste generated by that



facility.   Contract hauling of small  volumes of wastewater from



pesticide  formulating,  packaging and  repackaging may create a




hazard through the transportation  of  potentially hazardous



materials.  However,  both  of  these impacts  are a result of




individual  facility practices, rather than  a trend of different



segments of the industry.








     Air emissions from the pesticide formulating, packaging and



repackaging industry are somewhat  related to the active ingredient



product (s)  and the inert ingredients  used.  Most PAIs are very low



in volatility  compared  to  the  various  solvents added as inerts or



present as  contaminants of the inerts.  Since many of the same



solvents are used in  formulating many  different pesticide products



air pollution  control problems are not unique to any segment of



this industry.  For example, baghouses or wet scrubbing devices



are used tovremove particulates and vapors at many facilities.








     Based  on  these discussions, the Agency believes that



subcategorization  on the basis of non-water quality



characteristics is not  needed.
                                4-17

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 4.2.10
Treatment  Costs  and  Knerov Requirements
      As  the basis for the  zero  discharge option, the   "Universal



 Treatment  System" is  adaptable  for treating a variety  of pesticide



 active ingredients, formulation types, matrices  (including



 emulsions)  and batch  sizes.  However, the cost of treatment and



 the  energy required will vary depending on batch size  and



 wastewater characteristics,  i.e., the amount and identity of



'"pollutants in the wastewater.







      As  discussed earlier,  in order  to minimize the cost and



 economic impacts  on these  small entities, facilities that



 formulate,  package and repackage small quantities of sanitizer



 chemicals  have to achieve  zero  discharge of only the interior



 sources  of process wastewater.  EPA  has decided that segmenting



 the  Pretreatment  Standards  for  Existing Sources based  on treatment



 costs is appropriate  but is not creating a separate subcategory



 for  the  small sanitizer facilities.  Those sanitizers  below the



 production cutoff (265,000  Ibs/yr) will be required to meet zero



 discharge  of the  interior  wastewater sources  (interior equipment,



 bulk tank  and raw material  drum rinsates) through pollution



 prevention and reuse,  but  will  be exempt from meeting  national



 limitations or standards on the non-interior process wastewater



 sources.  (See Section 12  for a detailed discussion on option



 selection.)
                                4-18

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     In the case of the refilling establishments, very few



facilities are not achieving zero discharge already.  The "best"



available technology in this segment of the industry is not a



treatment technology, but is the use of a secondary containment



structure for collection followed by recovery of the product value



through application to farmers'  fields.  The water-using refilling



establishments generate a median of approximately 720 gallons



annually.  These wastewaters are expected in the containment



system and loading area, whereafter they can be held in a tank or



container.  The few facilities that are estimated to be



discharging (19 facilities)  discharge a total estimate volume of



1500 gallons annually to POTWs.   This represents an average volume



of approximately 78 gallons per facility which can be held in a



single minibulk container, which costs about $300.








     The PFPR facilities are also expected to be able to



recycle/reuse wastewaters, however some wastewater sources are



expected to require treatment before they can be recycled.  EPA



has estimated costs for storage of wastewater and treatment



through the Universal Treatment System at approximately $32,000



per PFPR facility annually.
     As discussed in Section 4.2.2, the refilling establishments



are being subcategorized on the basis of raw materials, dominant



product, and the repackaging operations performed at their



facilities.  The fact that the identified best available






                               4-19

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 technologies  are  different for the Subcategory  C  facilities versus

 the  refilling establishments  tends to confirm that  creating a

 separate subcategory  for the  refilling establishments  is

 appropriate.



 4 . 3  PROPOSED  SUBCATEGORIES



      Based on the differences in the raw materials  used,  the

 dominant product,  the type of operations  performed  and the

 available  treatment technology and the associated costs EPA has

 defined two subcategories for the pesticide formulating,  packaging

 and  repackaging industry:



      Subcategory  C - Formulators, packagers and repackagers of
                     pesticide chemicals, including formulating,
                     packaging and repackaging at pesticide
                     manufacturing facilities;

      Subcategory  E - Repackagers of agricultural pesticide
                     chemicals at refilling establishments.


      The following paragraphs describe in brief detail the

 applicability of the  proposed effluent  limitations  guidelines and

 standards.  A more detailed discussion  is presented-in Section 2.1

 of this document.



      The proposed  regulations expand the  current  effluent

 limitations guidelines and standards  to include BCT, BAT,  NSPS,

PSES and PSNS for new and existing facilities in Subcategory C
                                4-20

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 (PFPR and PFPR/Manufacturers) and develop BPT, BCT, BAT, NSPS,



PSES and PSNS for new and existing facilities who repackage



agricultural pesticide chemicals at refilling establishments



 (Subcategory E).  Again, EPA has decided not to create a



subcategory for the formulators, packagers and repackagers of



sanitizer chemicals.  Instead these facilities fall under



Subcategory C as PFPR facilities.  However, in order to minimize



the economic impacts of these small businesses, indirect



discharging sanitizer facilities whose sanitizer production fall



below the production cutoff of 265,000 Ibs/yr have slightly



different Pretreatment Standards  (See Section 12) than the



remainder of Subcategory C facilities.  In addition, BCT for



conventional pollutants is proposed to be set equal to BPT for all



subcategories in the pesticide formulating and packaging industry.
     The proposed effluent  limitations guidelines and standards



are intended to cover discharges generated during the formulating,



packaging and repackaging of all EPA registered pesticide



products. However, under PSES and PSNS EPA is proposing an



exemption to the coverage for sodium hypochlorite (see Section



12).   These guidelines apply to at least ten specific process



wastewater sources  (see Section 2.1.1), including rinsates from



cleaning operations.  These guidelines do not apply to wastewater



generated by on site employee showers, laundries or fire



protection test water.  These guidelines do not apply to the



production of pesticide products through an intended chemical






                                4-21

-------
reaction  (i.e., manufacturing).  Formulation does not involve



intended chemical reactions, but does involve the process of



mixing, blending or diluting one or more pesticide active



ingredients  (PAIs) with one.or more other active or inert



ingredients to obtain a product used for additional processing or



an end-use  (retail) product.  The manufacture of PAIs through a



chemical reaction are covered by the Pesticide Chemicals



Manufacturing effluent guidelines (58 FR 50638,  September 28,



1993).  The PFPR guidelines are also intended to apply to the



repackaging of agricultural pesticide chemicals  at refilling



establishments, but at this time do not apply to custom blending



or custom application that may also be performed at these



refilling establishments.
                               4-22

-------
                             SECTION  5








          WATER  USE AND WASTEWATER  CHARACTERIZATION








5 . 0 INTRODUCTION








     In  1990, under  the authority of Section 308 of the Clean



Water Act, the Environmental Protection Agency (EPA)  distributed



questionnaires entitled, "Pesticide Formulating,  Packaging and



Repackaging Survey for 1988," to 707 selected facilities



identified by EPA as pesticide formulators, packagers or



repackagers.  The selection process used is discussed in detail in



Section 3.1.3 of  this document.  This survey was  focused on the



272 PAIs that were studied for the pesticide manufacturing



effluent guidelines  (58 FR 50637).  Each facility selected for the



survey (with the  exception of the three voluntary submissions and



the three pretests) represents some number of other facilities



when the data is extrapolated to the entire population.   These



extrapolations are referred to as national estimates  and are



presented in this section.
     National estimates of the questionnaire responses indicate



that 2439 facilities were performing formulating,  packaging or



repackaging in 1988.  These facilities can be broken down by water



use status:  1806 water users and 633 non-water users.   The



national estimates presented in this section focus on the 1806






                                5-1

-------
water-using facilities.  This  section also presents information on



process wastewater characteristics  for those wastewater sources



that were sampled by EPA or for which facilities provided self-



monitoring data.








5. 1 WATER USE AND  SOURCES  OF  WASTEWATER
5.1.1
r  Sources
     As described in Section  3.4, pesticide formulating, packaging



and repackaging operations are typically performed on liquid lines



or dry lines. Liquid lines generally involve the use of agitated



mixing equipment, where dry lines involve the use of grinding



equipment and sieves.  However, these lines can be combined when



formulating with liquid pesticide active ingredient that is then



sprayed onto a dry substrate  (inert carrier).  Basic process flow



diagrams for liquid and dry formulation processes are presented in



Section 3, Figures 3-1 and 3-2.
     When looking at the process flow diagrams, it is not easy to



locate the wastewater sources for this industry.  The wastewater



sources found in the PFPR industry are typically due to cleaning



of equipment and related process areas and, therefore, do not



appear on process flow diagrams.  EPA is proposing to regulate all



but three of the PFPR wastewater sources.  Thus, the proposed



regulation is intended to apply at least to the following ten






                                5-2

-------
wastewater sources that were reported to exist by the surveyed

facilities :

     •    Interior Cleaning - water used to clean the interior of
          any formulating, packaging, or repackaging equipment,
          including routine cleaning, product changeover cleaning,
          or special or non routine cleaning of equipment
          interiors :

               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 another pesticide
             ;  product, to a non-pesticide product, or  to idle
               equipment condition, or

          —   Special or Non Routine Cleaning - cleaning due to
               situations which did not normally occur  during
               routine operations, such as cleaning due to
               equipment failure, use of binders, dyes, carriers,
               and other materials, that require additional
               cleaning time or larger volumes of water;
          Floor. Wall, or Ex-h^ri or Equipment Wash Water  -  water
          used to clean floors, walls, and/or exteriors  of
          equipment at the PFPR facility;
          Bulk Tank Rinsate - water used to rinse bulk  containers
          used to store pesticide products;

          Shipping Container Rinsate - water rinses of  the
          containers used to ship raw materials, finished
          products, and/or waste products prior to reuse or
          disposal of the containers;

          Leaks and Spills Cleanup Water - water used to clean up
          leaks and spills which occurred during PFPR operations;

          Air or Odor Pollution Control Scrubber Water  - water
          used in air emissions control scrubbers;

          DOT Leak Test Wat-.er - water used to perform aerosol leak
          tests for Department of Transportation (DOT)
          requirements ;

          Safety Equipment Wash Water - water used to clean
                                5-3

-------
          personal protective equipment such as gloves, splash
          aprons, air-purifying respirators, worn by employees
          working in PFPR operation and safety showers;

     •    Laboratory Equipment Wash Water  — water used to clean
          laboratory equipment associated  with PFPR operations;
          and

     •    Contaminated Precipitation Runoff - rainwater or snow
          melt believed to be contaminated with pesticide active
          ingredients.

     The 1978 BPT regulation does not define whether employee

showers and on-site laundry facilities are process wastewater

sources.  For this proposed regulation,  EPA has decided to

specifically not include the following three wastewater sources

reported in the questionnaire:
     •    Shower Water - shower water used by employees working in
          PFPR operations;

     •    Laundry Water - water used for laundering clothing worn
          by employees working in PFPR operations; and

     •    Fire Protection Test Water — water used to test fire
          protection equipment at PFPR facilities.


     EPA has carefully thought about whether to include the above

wastewater sources and has decided not to include them for a

variety of reasons.  In the case of water generated at an on site

laundry, EPA believes that this wastewater, due to its soapy

nature, may be better handled by a biological treatment unit

(possibly at a POTW) and treated in combination with other

sanitary wastes from the facility.  Also,  EPA does not want to

create incentives for creating other environmental or worker

exposure problems by sending the uniforms to industrial laundries
                                5-4

-------
 or home with the employees.   Some facilities have been able to



 avoid washing uniforms that  may be highly contaminated by



 requiring disposable Tyvek coveralls to be worn over the uniforms



 when performing operations with a high risk of splashing or



 airborne dust.  In the case  of on site showers, as with laundries,



 EPA does not want to create  incentives that may increase worker



 exposure problems.  Also, many PFPR facilities conduct other



 operations besides pesticide formulating and packaging at the  same



kfacility and,  therefore,  the same employee may work on PFPR



 operations and non-PFPR operations in the same shift.   Unlike



 other wastewater sources  that have the potential for being



 combined with non-PFPR wastewaters,  EPA does not believe that  a



 facility can easily segregate or account for the pollutants



 generated from the PFPR operations in the shower water.   EPA has



 decided not to include fire  protection test water because it is



 generated on an intermittent basis at relatively low volumes and



 has little chance of being contaminated.  Also, fire protection



 test water does not appear to be a wastewater source common to the



 overall industry.  It was reported by only one surveyed facility.
 5.1.2
National Estimates  of Water Us
      Table 5-1 presents the national estimates of water use  (in



gallons/year)  for the industry by wastewater  source  for each



proposed  subcategory.  (Note:   For the purpose of presenting data



in this section,  the sanitize}: segment of Subcategory C will be






                                 5-5

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-------
broken out separately from the rest of the subcategory as will the



PFPR/Manufacturers) .   It is important to note that the use of the



term "water use" here does not include the water facilities use



initially as part of the formulated product.   This is because



water that is the base of the formulation becomes product and is



not considered a possible wastewater source.   It is also important



to note that the water use is not presented as a daily flow, but



instead as a yearly total.  Just as the production of formulated



product (or repackaging) is a batch process,  so is the generation



of wastewater at these facilities.
     Wastewater sources on Table 5-1 have been categorized as Type



I or Type II sources.  For Type I wastewaters,  Table 5-1 shows



that interior equipment cleaning is the largest wastewater source



for both PFPR and refilling establishments,  followed closely by



equipment exterior/floor wash for PFPR and raw material



drum/shipping container rinsate for the refilling establishments.



Through telephone contacts EPA found that many surveyed refilling



establishments reported minibulk rinsate as  interior equipment



cleaning while others reported it as drum rinsate.  For the



PFPR/manufacturers, the largest wastewater source is equipment



exterior/floor wash followed by air pollution control water



(scrubber water and baghouse cleaning)  and then drum/shipping



container rinsate.








     For the sanitizer segment of Subcategory C, the largest






                                5-7

-------
          wastewater  source  was  equipment  exterior/floor  wash which  includes



          general equipment  wash water.  The  second largest  wastewater



          source for  sanitizers  was  interior  equipment  cleaning  water.



          General equipment  wash water is  not named as  one of the  ten



          specific wastewater  sources,  but this  wastewater is process



          related and is most  closely  associated to exterior equipment



          cleaning water.  Just  as with exterior equipment cleaning  water,



          general equipment  wash water most often does  not come  from one



         • product or  production  line and cannot  be directly  reused without



          prior treatment.  (Please note, in the  case of the



          PFPR/manufacturers equipment exterior/floor wash includes  general



          equipment wash water and maintenance).








              For Type II wastewater  sources,  Table 5-1  shows that



          contaminated precipitation runoff is the largest wastewater source



          for PFPR, PFPR/manufacturers and refilling establishments  followed



          by laboratory rinsate  for  PFPR and  PFPR/manufacturers  and  safety



          equipment rinsate  for  refilling  establishments.  .However,



          laboratory  rinsate is  the  largest Type  II wastewater source for



          sanitizers.
         5.1.3
Water  Use  —  Production Normalized  Volumes
              EPA was able to use the  questionnaire data  in  combination



         with the production data provided by the FATES database  (see



         Section 3) or by individual facilities to calculate production





                                         5-8
_

-------
normalized volumes  (PNVs) for each wastewater source at each



facility.  These PNVs can then be extrapolated to the national



population and displayed as a distribution on bar graphs.  EPA



recognizes that water use at PFPR facilities is not necessarily



proportional to production; however, using production normalized



volumes helps to provide a basis for comparison between large and



small facilities.  Figures 5-1 through 5-9 present the national



estimates of the production normalized volumes by wastewater



source for sanitizer facilities, PFPR, PFPR/manufacturers and



refilling establishments.
                                5-9

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-------
5.1.4     Water  Use  — Cleaning1  Sequences  and  Formulation
           Types

     Facilities were  asked to provide  the  sequence  of cleaning
steps used for interior equipment  cleaning for  each reported
production line.  Facilities  chose from a  list  of cleaning  steps
including:  solvent cleaning,  steam stripping,  water cleaning,
abrasive/mechanical cleaning,  detergent cleaning, final water
rinse, final solvent  rinse, absorbent  addition, and other.  As
discussed  in section  4.2.1, the  industry produces a varied
combination of pesticide and  formulation types.  The variety of
formulation types may account  for  the  variety of cleaning
sequences  reported in the  questionnaire for interior equipment
cleaning.  For example, facilities that formulate products  with
high viscosity or dyes, may choose to  perform multiple rinses or
use a detergent or other abrasive  when rinsing  the  equipment.
However, EPA has found that, although  the  formulation type  may
dictate the relative  amount of water used, it does  not necessarily
dictate the ability to recycle or  reuse the cleaning water.


5 . 2  WASTEWATER  VOLUME  BY  DISCHARGE  MODE
5.2.1
Definitions
     Direct discharge, refers to the discharge of a pollutant or
pollutants directly to waters of the United States (not to a
publicly owned treatment works).  Facilities that directly

                               5-19

-------
discharge wastewaters do  so under the National Pollutant Discharge



Elimination System  (NPDES) permit program.








      Indirect  discharge refers  to the discharge of pollutants



indirectly to  waters of the United States, through publicly owned



treatment works  (POTWs).








      No  discharge  for zero discharge) refers to facilities that do



not discharge  their wastewaters to waters of the United States, as



a result of either reuse  of process water back into the product,



no water use,  recycle off-site or within the plant in other



processes, or  disposal off-site or on-site that does not result in



a discharge to waters of  the United States (e.g.,  by incineration,



evaporation, or deepwell  injection).
5.2.2
Discharge Status  of PFPR Indus-brv
     According to the national estimates, there are 22 direct



dischargers, 630 indirect dischargers, and 1784 zero dischargers.



There are also three  (3) facilities that are both direct and



indirect dischargers.  Table 5-2 presents summarizes the breakdown



by discharge mode and subcategory for the PFPR industry.
     Two interesting facts about the zero discharge facilities



emerge when analyzing the industry breakdown by discharge mode and



subcategory.  First, approximately 633 of the 1784 zero





                                5-20

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                                      5-21

-------
 dischargers do not use water in their formulating, packaging or



repackaging operations.  Second, approximately 1115 of the 1784



zero dischargers fall into Subcategory E:  Refilling



Establishments.  Although EPA was limited to the data that could



be collected from non-water users achieving zero discharge, EPA



did collect extensive data through the questionnaire and site



visits on the practices at facilities who use water and are able



to achieve zero discharge.  EPA has summarized these practices in



Section 7.4 of this document.  Also, EPA's numerous actual site



visit reports have been made available in the public record for



this proposed rulemaking.
     As discussed in Section 2.0, the fact that some facilities



are direct discharge facilities may appear inconsistent with the



1978 BPT limitation  prohibiting all direct discharges.  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 specified in their permits.





                               5-22

-------
The recently issued pesticide manufacturing regulation (58 FR
50637, September 28, 1993)  sets production-based BAT limits for
specific active ingredients.   These limits supersede the previous
concentration-based BPT limit for "total pesticides."  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 meet the
limits in their new permits.


5 . 3  WASTEWATER  DESTINATIONS


     There are nine destinations reported by surveyed facilities
for PFPR process wastewater in 1988.  These destinations  include:


     Discharge  Options
          NPDES or Direct-.
                                    - water discharged directly to
          waters  of the  United States (not  a publicly owned
          treatment works) ;  or
          POTW or Indirect: Pi
                                     - water discharge indirectly
          to waters of the United States through publicly owned
          treatment works  (POTWs) ,  but not  through private
          wastewater treatment systems.

     Recycle/Reuse  Options

     *    Recycle/Reuse - water is  recycled or reused on-  or
         off-site  in PFPR product  formulations, cleaning  cycles
         of PFPR equipment, or non-PFPR operations.
                               5-23

-------
     Disposal  Options
          Off-Site  Disposal  - water  is contract hauled as either a
          wastewater  or  as hazardous waste to a centralized
          wastewater  treatment  facility, for deepwell injection,
          or to  an  unspecified  disposal;

          Incineration - water  is  incinerated either on- or
          off-site;

          Septic System  - water is released to an on-site septic
          system;

          Storage - water is stored  on-site for periodic removal;

          Evaporation -  water is evaporated or percolated from an
          impoundment or pond on-site; or

          Land Application - water is applied to facility's land.
     Tables  5-3 through  5-5 present the total national estimate

volume going to each wastewater destination.  Each of the three

tables presents the picture a little differently:  Table 5-3

presents by  subcategory  for all facilities; Table 5-4 presents by

subcategory  for the zero discharge facilities; and Table 5-5

presents by  subgroup.  The discussion on these tables is presented

below.



     As stated above, Table 5-3 presents the total national

estimate volume going to each wastewater destination by

subcategory.  This table shows that a large number of facilities in

this industry are practicing some recycle and reuse of their

wastewater.  The table also shows that the water-using refilling
                                5-24

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-------
 establishments are consistent in their practice of recycling off-



 site by using the rinsewaters as make-up water for custom



 application to farmers' fields.  However, the PFPR and



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 destination as do the other subcategories.  The sanitizers, as a



 group, send a relatively high proportion of their wastewater to



 POTWs.  Note that land application was not reported by the



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 These facilities are recycling off-site by using the collected



 wastewaters as make-up water for applications to farmers' fields.








     Table 5-4 presents the same information for the zero



 discharge facilities as Table 5-3 did for all facilities.  The most



 important piece of information presented by this table is the data



that demonstrates the large extent to which recycling is practiced



at these facilities.   EPA realizes that with a zero discharge



regulation, facilities may choose zero discharge options other than



recycle/reuse and that these options may increase cross-media



transfers.  However,  basing its assumption on what facilities are



currently doing (i.e.,  Table 5-4),  EPA believes that recycling on-



or off-site will be the predominant method by which zero discharge



is achieved.
                               5-26

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     Finally, EPA looked at the wastewater destinations by



subgroup (definitions of the subgroups are given in Section



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5-5 shows that the majority of wastewater generated is either



recycled on- or off-site or sent to a POTW.  In the case of the



Manufacturers, there is a relatively large number of gallons/year



directly discharged through NPDES permits.  For subgroups such as



Agriculture, Organo-metallic products, and Combination organo-



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subgroups only relatively small volumes of wastewater are being



incinerated or contract hauled for disposal.  As discussed in



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differences in water use or wastewater discharge by one specific




subgroup.
                                5-28

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-------
 5 . 4  WASTEWATER  DATA  COLLECTION  RESULTS








      Section 3.1  of this document  introduced  the  many  wastewater



 data  collection efforts undertaken for development of  these



 regulations.  Studies that produced data on raw wastewater




 characteristics include industry-supplied self-monitoring data



 submitted along with and as a follow-up to the industry survey



 questionnaire and data obtained from EPA sampling at pesticide




 formulating, packaging and repackaging (PFPR) facilities.  Results



 of these data gathering efforts are described in more  detail below,
5.4.1
Industry  Supplied  Self-Monitoring
     As part of the PFPR survey questionnaire, EPA requested that



pesticide formulating, packaging and repackaging facilities submit



any available wastewater monitoring data and requested that these



data be submitted as individual data points (as opposed to monthly



averages, for example).   In response, 34 facilities submitted self-



monitoring data along with the questionnaire.   EPA later requested



facilities with monthly discharge reports to POTWs to provide



additional data to EPA.   EPA received data for conventional and



priority pollutants,  as  well as for PAIs and other non-conventional



pollutants,  such as COD.  However,  these monitoring data usually



represented pollutant concentrations in end-of-pipe wastewater



streams (usually commingled with pesticide manufacturing,  organic



chemicals manufacturing  (OCPSF),  or non-pesticide formulating






                               5-31

-------
operations) and; therefore, EPA could not determine the true



contribution of the PFPR operations to the pollutant concentrations



reported.  In addition, much of the self-monitor ing data was also



of limited use because many POTWs do not require the PFPR



facilities to monitor for pesticide active ingredients  (only for



conventionaIs, COD, pH, organics or metals).








     Following inspection of the data submitted, data received



from ten facilities in Subcategory C: PFPR and PFPR/Manufacturer



were entered into the self-monitoring database.  None of these



facilities are sanitizer PFPR facilities or refilling



establishments.  However, two of these facilities were also



pesticide manufacturers and six of the ten facilities also engage



in repackaging activities.  The types of pesticides these



facilities formulate and/or package vary considerably, but all



appear to be medium or large-size operations, with the majority



qualifying as large.  The geographical distribution of these



facilities was very representative of the industry with five in



Region 7, three in Region 4 and two in Region 9.
     Data on the concentration of pesticide active ingredients



(PAIs)  in facility wastewaters were submitted for 89 individual



PAIs.   These concentration data were used along with EPA sampling



data to help determine raw pollutant loadings used in costing the



industry for regulatory options.  A list of the 89 PAIs for which



self-monitoring data were submitted is presented in Table 5-6.






                                5-32

-------
                                Table 5-6

                    PAIs  With  Self-Monitoring  Data
1,3-dichloropropene
aldicarb
benfluralin
bromacil
captan
chlordane
chlorpyrifos
chrotoxyphos
DEF
dicamba
dicofol
diphenamid
DNBP (dinoseb)
EPN or santox
ethoprop
fensulfothion
guthion
linuron
merphos or folex
methoxychlor
mexacarbate
naled
parathion
pentachlorophenol
phorate
propachlor
pydrin (fenualerate)
ronnel or fenchlorphos
temephos
trifluralin
2,4-D
aminocarb
benomyl
bromomethane
carbaryl
chloropropham
cinnerin I (allethrin)
cycloate or ro-neet
demeton or systox
dichlone
dimethoate
disulfoton
DNOC
EPTC or EPTAM
endosulfan I
fenthion
heptachlor
malathion
methiocarb or mesurol
metolachlor
MGK 264
oxamyl
parathion methyl
perthane or ethylan
piperonyl butoxide
propham
pyrethrins
siduron or tupersan
terbufos or counter
Vapam	
alachlor
atrazine
bolstar
carbofuran
chloroxuron
coumaphos
DDVP (dichlorvos)
diazinon
dichloran or DCNA
dioxathion
diuron
endrin
ethion
endosulfan II
fluometuron
lindane
MCPP or mecoprop
methomyl
mevinphos
monuron
oxyfluorfen
PCNB
phenothrin (sumithrin)
prometon or caparol
propoxur
resmethrin
sut an (butylate}
toxaphene
vernolate or vernam
                                     5-33

-------
      Self-monitoring data were submitted for 113 priority



 pollutants.   Even more so than the  PAI  data,  the data  submitted for



 the priority pollutants may not necessarily  characterize  the  PFPR



 operations at a particular facility.  This is because  the priority



 pollutants in the commingled wastewaters  can be  attributed  to many



 different processes at the facility, where PAIs  are more  likely to



 only be linked to PFPR or pesticide manufacturing operations.   In



 addition to  some quantitative data  on priority pollutants,  EPA



fccollected some qualitative data on  priority  pollutants through  the



 survey questionnaire.   Within the survey  population 19 facilities



 reported 11  unique priority pollutants  used  in cleaning solutions;



 45 facilities reported using 42 unique  priority  pollutants  in their



 raw materials;  and 35  facilities used 14  unique  priority  pollutants



 as inert ingredients.
 5.4.2
EPA  PFPR  Sampling  Prooram
      As  discussed in Section  3.1.4, EPA was not able to  conduct as



 extensive a  sampling program  as was conducted when developing



 effluent guidelines  for  other industries.  This was because:  (1)



 only  12 facilities in this industry operate on site treatment



 systems that treat only  PFPR  wastewater; and (2)  facility



 operating schedules  are  very  unpredictable due to the batch nature



 of their operations  and  just-in-time production philosophy.  These



 difficulties with conducting  the sampling program are discussed in



 the following paragraphs.






                                5-34

-------
      The relatively low number of facilities with on-site



treatment not only made it difficult  for EPA to  locate  facilities



with  "BAT-level"  treatment,  but also  it  affected the collection of



samples  for raw wastewater characterization.  Usually facilities



are selected as candidates for wastewater sampling if they have



treatment systems that demonstrate a  high level  of performance.



When  EPA is on site at these facilities  to sample a treatment



system,  additional sampling is performed to characterize the raw



wastewater from various sources that  feed into the treatment



system.   Because  so few PFPR facilities  had treatment systems, only



seven full scale  sampling  efforts  were undertaken, limiting the



number of samples taken to characterize  raw wastewaters.  In an



effort to supplement the raw wastewater  characterization data, EPA



conducted a number of  one-time "grab" sampling episodes while



conducting site visits.
     There  are  two  factors  associated with organizing a sampling



program with the typical operating schedules of the facilities in



the PFPR industry that have caused EPA difficulty.  First, unlike



industries  with continuous production (i.e., pesticides



manufacturing), the PFPR industry typically utilizes batch




production.  Second, PFPR facilities do not operate long campaigns,



but instead schedule production week to week.  The frequently



changing production schedules at PFPR facilities made it quite



difficult for EPA to schedule sampling episodes and to acquire EPA






                                5-35

-------
contract laboratories to perform the analytical analysis.  However,



even with these difficulties, EPA did sample a wide variety of



wastewater sources at 14 facilities for raw wastewater



characterization data. The sampling episodes also allowed EPA to



test analytical methods for the PAIs.   Results of these sampling



program are discussed in the following paragraphs.








     As previously mentioned, EPA conducted two different types of



sampling episodes.  Sampling was either performed as a one-time



"grab" while on a one day site visit at a facility or as a three



day full-scale sampling of a treatment system.  A total of 70



wastewater samples were collected for a variety of PAIs at the



following wastewater sources:  equipment interior rinsates,



equipment exterior rinsates/floor wash, scrubber water, DOT test



bath, raw material drum/shipping container rinsate, laboratory,



laundry and showers.  A number of these samples were collected to



characterize wastewater that was intended for reuse, therefore, EPA



expected the concentration of PAIs in these samples to be high.



With the exception of the DOT test baths, showers and laundries the



wastewater sources are only generated following PFPR production



during cleanup and, therefore, are not continuous.   The batch



nature of the wastewater generation along with the batch operation



of the treatment systems made it quite difficult for EPA to conduct



typical composite sampling or make use of automatic sampling



equipment over the three day sampling period.
                                5-36

-------
     Typically, an automatic sampler could not be used.   Instead



discrete equal volume grab samples, or aliquots, were manually



collected at equal time intervals and added to the compositing



container (a specially clean 10-liter glass jar).  At the end of



each daily sampling period, each composite sample was poured into



specially cleaned individual fraction containers for shipment to



the EPA contract laboratories.  These fractions included analyses



for: Group I (BOD5,  TSS,  total fluoride,  and pH) ; Group II (TOC,




COD, ammonia nitrogen, and nitrate and nitrite nitrogen);



extractable (semi-volatile) organics; metals; and the pesticide



active ingredient(s).  The fractions for volatile organics,



cyanide, and oil and grease analyses were not poured from the




composite containers, but manually collected as individual grab



samples during each daily sampling period.
     After the individual sample fraction containers were filled



each day, they were preserved according to EPA protocol.  In



addition, the samples were maintained at 4°C (using ice) during



storage and shipment, with the exception of the metals fraction



which does not need to be kept iced.  The purpose of this procedure



was to minimize any potential degradation reactions, including



biological activity, that could occur in the samples prior to



analysis.  It was not necessary to follow this procedure for the



metals fraction since these analyses are not specific to the



compounds containing the metal analyte but rather are reported as



total metals contained in the sample (such as total copper,  total





                                5-37

-------
mercury, etc.) .








     Table 5-7 presents  an  overall  statistical  summary of the



wastewater sampling data including the maximum, minimum, mean and



median concentration values for individual classical pollutants,



individual PAIs and individual priority pollutants found to be



present in PFPR wastewaters.  The table lists the analytical method



minimum detection level  for each pollutant and the percentage of



non-detects found.  This table excludes PAIs or priority pollutants



in the following sample  categories:  shower, laundry, commingled



raw, effluent or treated.  These sample types were excluded from



the summary data to provide a more accurate picture of the raw



wastewater concentrations from PFPR process wastewater sources.



The concentrations of PAIs, COD and some specific conventional



pollutants in treated streams are discussed in Section 7.2.2:



Reuse of Treated Wastewater.
                                5-38

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                                     5-41

-------

-------
                             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

-------
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

-------
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

-------
      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

-------
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.
                                6-5

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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

-------
                              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

-------
     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.
                               6-8

-------
 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

-------
                                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

-------
                             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

-------
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

-------
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

-------
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

-------
 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

-------
      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

-------
       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





                               7-12

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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






                                7-13

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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





                                7-14

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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






                                7-15

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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
                                7-16

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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.
                                7-17

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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.






                               7-18

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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






                                7-19

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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





                                7-20

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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






                                7-21

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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
                               7-22

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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






                               7-23

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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


                                7-24

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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






                                7-25

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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:
                               7-26

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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:


                               7-27

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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.
                                7-28

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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






                                7-29

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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





                               7-30

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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






                                7-31

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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:
                                7-32

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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
                                   7-33

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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





                               7-34

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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:
                                7-40

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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






                               7-42

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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

-------
 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






                               7-63

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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.






                                7-64

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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






                                7-65

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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





                                7-66

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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






                               7-67

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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,
                                7-68

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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.
                                    7-69

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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.
                                7-70

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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






                                7-71

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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
                                7-72

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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
                               7-73

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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) .


                                 7-74

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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






                               7-75

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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






                                7-76

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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






                               7-77

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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






                                7-78

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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.
                                7-79

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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






                                 7-80

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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





                               7-81

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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




                                7-83

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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,




                                7-84

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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.
                                7-85

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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





                                7-86

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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
                               7-87

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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,
                                 7-88

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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




                                7-90

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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




                                7-92

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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
                                7-93

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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




                                7-94

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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


                               7-95

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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




                                7-96

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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




                                7-98

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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
                                7-99

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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.
                               7-100

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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





                               7-101

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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




                               7-102

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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





                                7-103

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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




                               7-104

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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





                               7-105

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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





                                7-106

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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
                               7-107

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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.




                               7-108

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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





                               7-109

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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





                               7-110

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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
                               7-111

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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




                               7-112

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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.
                               7-113

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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
                               8-1

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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
                                8-2

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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
                               8-3

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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
                                8-4

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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





                               8-5

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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

                                8-6

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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

                               8-7

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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.
                                8-8

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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

                               8-9

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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

                               8-10

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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





                               8-11

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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,





                                8-12

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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).
                               8-13

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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
                               8-14

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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
                               8-15

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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
                               8-16

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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

                              8-17

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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.
                                8-18

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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






                               8-19

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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
                               8-20

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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





                               8-21

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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
                                8-22

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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.
                               8-23

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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.
                               8-24

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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

-------
          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

-------
                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

-------
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

-------
           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

-------
 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

-------
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

-------
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

-------
 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

-------
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





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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
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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:
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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
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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.
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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
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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.

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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.
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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
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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
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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.
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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.
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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:
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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
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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
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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





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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
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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.
                               8-74

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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






                               8-75

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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
                               8-76

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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
                               8-77

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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

                               8-78

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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





                               8-79

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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





                               8-80

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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





                               8-81

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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.
                               8-82

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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.
                               8-83

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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.
                               8-84

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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
                               8-85

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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
                               8-86

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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.
                               8-87

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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
                               8-88

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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.

                               8-89

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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
                               8-90

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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
                               8-91

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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:

                               8-92

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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.
                               8-93

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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.





                               8-94

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Annual incineration costs = $447/drum * # drums/year
                 + $300 * loads/year
                         8-95

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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






                                9-1

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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






                                9-2

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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






                                9-3

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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.
                                 9-4

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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





                                9-5

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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
                                 9-6

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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






                                9-7

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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.





                                11-2

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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
                               12-1

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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.
                                12-4

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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.






                               12-7

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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
                                12-9

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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.
                               12-10

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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,
                               12-11

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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.
                          12-12

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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.
                               12-13

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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






                               12-14

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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






                               12-15

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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.
                               12-16

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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.
                     12-17

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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.
                                           12-18

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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






                               12-19

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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






                               12-20

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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






                               12-21

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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.






                               12-22

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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






                               12-23

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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






                               12-24

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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.)






                               12-25

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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
                               12-26

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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).
                               12-27

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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.
                                13-1

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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





                                13-2

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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.

                                13-3

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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.
                               13-4

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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


                                14-1

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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
                                14-2

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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,
                               14-3

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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






                                14-4

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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.






                                14-5

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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.






                                14-6

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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.
                               14-7

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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.
                                14-8

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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.

                                14-9

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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.
                                14-10

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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






                               15-1

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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





                                15-2

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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.
                                16-4

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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



                               A-l

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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.
                                     B-l

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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.
                                      B-2

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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)
                                       C-l

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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)
                                       C-2

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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.

                                         D-l

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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

                                          D-2

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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

                                          D-3

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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.
                                        D-5

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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.
                                E-l

-------
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
                                 E-2

-------
 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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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

-------
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-------
              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

-------
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-------
                    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

-------
                        
 £
 o
                     O

                     s
                     o

                     1
                     UJ
             88
             o  o
   OL.
   O
    I


   I

   *
   •s
   o
r- E
   OS

   S
   CM
   r«-

   >»
   P


   if
   o
   o
3
I
£



 5
            8    =r
                  •3
                  co
                  u.

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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

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                        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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